-SAMPLE PETITION-
ANKARA SENTRY FAMILY COURT
THE REQUESTER :
ADDRESS :……
ATTORNEY :
ADDRESS :
PHONE :
DEFENDANT :
ADDRESS :…
CASE VALUE : ………. TL
SUBJECT OF REQUEST: It consists of a request that the client will receive trappings due to the termination of the marriage union.
INSTRUCTIONS
The client and the defendant ../../…. He has been married in his history and has no joint children from his marriages. Since the date the client and the defendant were married ….. They live together in the family residence at Batıkent Yenimahalle Ankara.
There has been a long-standing decimation between the parties and there are often violent fights. ../../…. In its history, a debate between the parties has started again; this debate has decayed to verbal and physical violence. After this last argument, the client was forced to leave the house by the defendant.
As a result of the physical and psychological violence he saw and the pressures he saw about leaving the house, the client was forced to leave the house as a runaway. Ankara … The contentious divorce case has been substituted by us with the file No. 2022 /… of the Family Court (ANNEX-1), and the trial of this case is still ongoing.
In a short time, the client had the opportunity to buy only a few pieces of clothing and his personal belongings. All of the many items and trappings belonging to him have remained in the family residence in which the defendant is located and are not being delivered to the client. The client, who has to leave his personal receivables at home as the subject of this case, is experiencing a great financial victimization.
The trappings and values in question are as follows:
1-…..
2-….
As a result of all these explanations, it has been necessary to request the return of the above-mentioned trappings to the client that the client has and that remain with the defendant in this case that we have substituted as a result of all these explanations.
LEGAL REASONS: TMK, HMK, Law on Advocacy and other relevant legislation
EVIDENCE : Photos and video recordings of the wedding ceremony, Ankara … Family Court file No. 2022 /…, witness, expert witness, discovery and other all delail
CONCLUSION AND CLAIM: For all the reasons explained above; provided that our rights to claim the excess are reserved;
1- Acceptance of our case and return of the trappings subject to the case from the defendant to the client,
2- The cost of the trappings subject to the lawsuit if they are not found exactly ………. To be taken from the defendant and given to the client with the legal interest of TL,
3-We request by proxy that the decision to leave the trial expenses and the power of attorney fee to the defendant be made. 13.01.2022
PLAINTIFF A… B… DEPUTY