03 Nov EXAMPLE OF A PRECAUTIONARY ALIMONY PETITION
TO THE JUDICATURE OF …
SUBJECT : The measure consists of the request for alimony.
EXPLANATIONS: 1-Our client is the defendant’s wife of 10 years. He has 3 children from his marriages, one of whom is 9 and the other two are 7 (twins). All three children are in primary school.
2-The defendant has been coming home late on the pretext of business trips for about 4 years and has been staying out from time to time. Although our client is disturbed by the situation, he has not made his voice heard to this day due to the influence of his young children and his environment.
3-For about 3 months, the defendant has completely left the house. He is not interested in our client, nor in his young children.The house where our client and the defendant lived together was left to our client by his own father. Our client, after getting married, left the workplace where she worked as a secretary and became a housewife. There is no income at the moment either. The defendant is engaged in insurance. His earnings are 4,000,000,000 per month.-TL (Four billion TL) is around.
4-Relatives and friends who intervened could not Decipher the current situation. Although the future of the marriage is unknown, our client does not intend to file for divorce for the time being in terms of the future of the children. However, he needs the help of his wife for his own livelihood and the care of children.
5-Per month from the defendant to our client ……. for each child ……. total ……. we demand precautionary alimony.
LEGAL REASONS : MK.m.162 and other articles of law.
EVIDENCE : Population records,witness
RESPONSE TIME : 10 Days
THE RESULT OF THE CLAIM : For the reasons explained, the defendant, our client, per month ……….. for each child ……. total ……. we request that it be decided to pay precautionary alimony, to attach alimony as a precautionary measure for the needs of our client and his children during the continuation of the case, to impose trial expenses on the defendant, and to rule on our behalf as a Lawyer on the other party’s proxy fee in accordance with Paragraph 164 / last of the Attorney’s Law No. 1136 amended by Law No. 4667.