-SAMPLE PETITION-
ANKARA SENTINEL ( ) TO THE FAMILY COURT
Prosecutor
ADDRESS :
ATTORNEY :
ADDRESS :
PHONE :
DEFENDANT
ADDRESS :…
CASE VALUE : 6.000,00 TL (Court of Cassation 2. The date of 10.01.2017 of the Law Department is 2016/25335 E. – 2017/187 K. In accordance with ilami No. 1, the increase has been calculated on the requested annual child support fee)
SUBJECT OF CLAIM: It is requested that the alimony paid to the client be increased by TL 500.00 to TL 1,500.00 and that it be decided to apply an increase in the rate of PPI to the amount of alimony provided each year.
INSTRUCTIONS :
1.Client A….. B…..,
Previously, the defendant filed a lawsuit against his wife demanding alimony, the case in question is Ankara ….. 2018 of the Family Court/….. May, 2018/….. The number of decisions was finalized in favor of the plaintiff client, the decision was finalized and an injunction of TL 1,000.00 was decided in favor of the plaintiff client. (Ankara ….. 2018 of the Family Court/….. May, 2018/….. A subpoena of the decision file is requested)
2.Taking into account the time elapsed since the opening of the alimony case mentioned above and the current economic conditions, the amount of 1.0000,00 TL has become very insufficient. In addition, the defendant’s salary and income increased, inflation and cost increased, but there was no increase in the amount of alimony for the plaintiff client (which the plaintiff client has no other income). With the pandemic process that has affected the whole world and our country, these figures have lost their meaning and are not achieving their purpose in the face of the cost of life and economic conditions.
3.The client lives alone and has no income. The children of the plaintiff client also live separately from him, and they also do not have any economic assistance to the plaintiff client.
4.Resulted from the date of alimony to 3 years 3 years to be inflation on a lot of data even for the recent increase in the TSI, the respondent’s income, the increase in cost of living, the plaintiff no income given today’s economic conditions and the lack of your client, the client imposed in favor of the plaintiff shall be admitted without regard to the amount of any increase in the rate expected. For these reasons, the business has been obliged to substitute this Alimony Increase Case.
LEGAL REASONS : HMK, TMK, Av. Blood. And other related legislation
THE EVIDENCE :
1-Subpoena of Family Population Records and Population Records Belonging to the Parties
2-Social and Economic Situation Research, Salary information of the defendant, subpoena from the relevant institution, SSI records
3-Land Registry Records
4-Tax Office Records
5-Bank Records
6-Records Kept in Official Apartments
7- Ankara ….. 2018 of the Family Court/….. May, 2018/….. Subpoena of the numbered decision file
8-Subpoena of Ppi/Cpi rates and subpoena of inflation rates from CBRT, TURKSTAT and related institutions
9-Witness Statements (If deemed necessary, they are requested to be listened to)
E….. F…..
G….. H…..
10-Expert Report
11-Discovery
12-Oath of Office
13-Precedent Supreme Court decisions
14-All kinds of legal evidence
CONCLUSION AND REQUEST: For the reasons described above, which will be considered by Your Dear Court if you re,
1- ACCEPTANCE of our rightful cause,
2- The alimony paid by the defendant is increased by 500.00 TL and increased to 1,500.00 TL from the date of the case,
3-APPLYING AN INCREASE in the PPI rate every year to the child support provided,
4- All kinds of trial expenses and fees are transferred to the opposite party of the power of attorney,
To be determined
we request it by proxy.25.07.2021
Plaintiff A….. B….. Attorney