Application For Marriage
TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEY :…….
DEFENDANTS :…….
SUBJECT : We request that the defendants be prohibited from marrying.
EXPLANATIONS: 1-We request the prohibition of the marriage of our client, who has recently divorced, to the defendant ……. with the other defendant …….
2-The defendants ……. and our client ……. were divorced by the decision of the Civil Court of First Instance dated ……. and numbered ……. The divorce decision was served to the parties and has become final as it was not appealed.
3-The defendant was married to our client and, while the divorce proceedings were ongoing, mentioned to our client that she was pregnant with their mutual friend’s child. Due to the tension surrounding the divorce, our client did not mention this matter to our client.
4- Since the divorce was amicable, it was finalized in a very short time. Our client learned later that his ex-wife was pregnant. We have now learned that the defendant is about to get married.
5- The defendant’s marriage in this situation may cause confusion regarding the paternity of the child to be born. We request that the defendant, who is pregnant with our client’s child, be prohibited from marrying during the waiting period.
LEGAL REASONS: MK.m.93 et seq., 103, 104.
EVIDENCE: Population records, divorce file.
RESPONSE PERIOD: 10 days
CONCLUSION: For the reasons stated above, we request that the marriage between the defendants be prohibited, that a provisional measure be issued to prevent the marriage contract until the end of the trial, taking into account that our client’s former spouse is pregnant, and that the costs of the trial be borne by the defendant. We request that the opposing party’s attorney’s fees be awarded to us as attorneys in accordance with the last paragraph of Article 164 of the Attorney Law No. 1136, as amended by Law No. 4667.
PLAINTIFF’S ATTORNEY