TO THE ANKARA FAMILY COURT ON DUTY

Plaintiff: first and last name (T.C ID Number)

 

Address

 

Attorney: At. First And Last Name

 

Address

 

Defendant: first and last name (T.C ID Number)

 

Address

 

Subject: divorce due to adultery, material and moral compensation, custody and subsidiary alimony is our petition for claim.

 

INSTRUCTIONS:

 

(This part must be filled out in accordance with the procedure specified by the legislator in the articles, taking into account the content of the specific event.)

 

1 -) the parties …/…/… were married on their date and have joint children from these marriages. One of the common boys …. he was born and the other one … was born. The profession of the plaintiff is …… and his monthly income is … TL, and the defendant is…….. and his monthly income is … TL.

 

2 -) The Marriage of the parties was shaken due to the fact that the defendant was completely defective, the marriage became unbearable for the parties. He found out that the defendant had been cheating on the plaintiff client for months and was having an affair with someone else. (The events related to the matter alleged in this section should be explained by evidence.)

 

3 -) it will be fixed by the evidence presented to the court and collected that the defendant deceived the plaintiff.

 

For this reason, the parties are divorced on the basis of adultery, custody of the joint children is given to the client’s mother as a precaution while the case continues and finally at the end of the case, the plaintiff is given to the client…. TL material,……. Monthly for joint children with immaterial compensation in TL ………..’er TL was necessary to open the relevant case so that it could be decided to pay alimony as a precautionary measure while the case was ongoing and to continue as a subsidiary alimony at the end of the case.

 

Legal evidence: witnesses, hotel records, photos, message documents and any related legal evidence. (Evidence to prove the allegation of adultery should be indicated here.)

 

Legal reasons: Code of Civil Procedure, Turkish Civil Code and related legislation.

 

Result and demand: for the reasons detailed above;

 

1 -) divorce of the parties due to adultery,

 

2 -) The defendant shall pay … TL material, … TL immaterial compensation to the plaintiff due to the defect of the spouse,

 

3 -) custody of Joint children should be given to the client’s mother as a precaution while the case continues and finally at the end of the case,

 

4 -) Joint children monthly ………..’er TL to be paid alimony to continue as a precautionary measure and as a subsidiary alimony at the end of the case while the case continues,

 

5 -) we respectfully supply and demand that the decision to pay the costs of the trial and the power of attorney fee be made by the defendant.

 

Acting Plaintiff