TO THE HONORABLE COURT
…….
PARTY REQUESTING THE NOTICE OF DEFAULT:…….
ATTORNEY :…….
OPPOSING PARTY :…….
SUBJECT: Request for a warning due to abandonment.
EXPLANATIONS: 1-Our client has been married to the opposing party for 15 years. The population records are in ……. Province, ……. District, ……. Neighborhood, Volume No; ……., Family No;……., Sequence No; ……. They have four children named AYŞE, FATMA, SEYFİ, and Sevgi.
2-Our client is a housewife, and the defendant works as a truck driver and travels abroad. The opposing party stays abroad for 1 week to 10 days each time he leaves the country for work. Our client and the children have become accustomed to this situation. However, her husband has not returned home for four months since his last trip and has not contacted either his wife or children.
3-Our client learned that her husband had rented another house for himself in Izmir, bought furniture for the house, and had a telephone installed, and she even called her husband on this telephone to invite him home. His spouse stated that he would not return home again and yelled at him. The other party has not fulfilled any of his marital responsibilities for four months. Moreover, he has left his home without any valid reason.
4-Our client is inviting him to his home because he is thinking about his long-lasting marriage and the future of his children.
5-The home we are inviting the other party to is the very home they abandoned four months ago. (………….. neighborhood, No:15, Floor:2, İzmit.) Our client is always at home. Nevertheless, a key has been left with ………………., who is a neighbor at the same address. The key can be picked up at any time of the day.
6-Although the other party is responsible for the household expenses, we will transfer the travel expenses determined by the court for the return to the home to the other party.
REQUEST: For the reasons stated above, we request that the court order the other party to return to their home and spouse within one month, and that they be warned that, otherwise, a divorce case will be filed in accordance with Article 132 of the Civil Code.
ATTORNEY ISSUING THE WARNING
