SAMPLE PETITION-
ANKARA RELATED (APPEAL AUTHORITY) FAMILY COURT
(About to Be Sent)
ANKARA ( ) FAMILY COURT
D.NO:2021/…..
REQUESTING
DEFENDANT :
ADDRESS :………
ATTORNEY :
ADDRESS :
PHONE :
PROSECUTOR :
ADDRESS :…
SUBJECT OF REQUEST: Ankara ( ) Family Court../../…. Date, 2021/… E. it consists in submitting our objections to the numbered protection decision.
INSTRUCTIONS
The above merits of your court are given within the scope of the registered file../../…. According to the Law No. 6284 dated, the Decision to Protect has been learned by us and our objections against this decision are presented below during the period.
In the said decision, a suspension and an injunction were issued against the client, which is a decision made taking into account the unilateral demands and biased evidence of the requesting party, and the requesting party is personally malicious. That is to say:
It is unknown to whom and when the so-called conversation recordings submitted by the requesting party in the petition october were sent. Because the plaintiff client has not met with the respondent party requesting a divorce after the divorce has been filed, he does not even know the phone number. The client has not seen the requesting party for many years.
The authenticity of the unreal speech recordings submitted by the requesting party is not accepted by us. The requesting party, especially after the client raised the issue of divorce, began to provoke and harass the client by phone (himself or through others). At this point, we are requesting a subpoena of GSM records. Because when the subpoena of these records is provided, it will be revealed that the claims of the requesting party are not true.
In addition, the document showing the so-called messages october in the request attachment does not contain the conversations and messages of the requesting party. Even the fact that such a one-sided conversation took place is contrary to the usual course of life. The requesting party has issued this protection order in order to force the client. Because already the client has not seen him for many years.
LEGAL REASONS : HMK, TMK, Lawyer. And other related legislation
EVIDENCE: Message and mail outputs (a subpoena is requested from the GSM company.),Witnesses (if necessary, they will be presented to the expert), Expert Witness, discovery, oath, all other evidence
Witnesses:
E….. (I.D NO:.:………….)
………………….. University of Ankara
F….. (I.D:NO.:………….)
………………….. Ostim Yenimahalle Ankara
We reserve the right to present evidence against the evidence presented/submitted by the counterparty
CONCLUSION AND CLAIM : For all the reasons described above and which will be considered by your court you’re;
1-Ankara ( ) Family Court../../…. according to Law No. 6284 dated The abolition of the Protection Decision,
2-If your court believes otherwise, the file has been deposited with the relevant authority for decision,
we request that the decision be made by proxy. 10/12/2021
THE REQUESTING DEFENDANT