TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT: …….
SUBJECT: Divorce and Alimony Claim Due to Severe Mistreatment.
EXPLANATIONS: 1-Our client has been married to the defendant for 8 years. The marriage is registered in the population registry of ……. Province, ……. District, ……. Neighborhood, ……. Volume No., ……. Page No., and ……. Register No. They have three children named Elif, Semih, and Sadiye.
2-The defendant has fallen into a state of depression due to being unemployed for the past two years. He comes home drunk almost every night and beats both his wife, our client, and their children. He also uses profanity and insults both our client and our client’s family.
3-Their neighbors, who live in the same apartment building, have often witnessed their fights, and on several occasions, our client has been forced to seek refuge with her neighbors along with her children. Those who intervened have warned the defendant on several occasions, but the defendant has not corrected his behavior, and it has not been possible to restore the marriage to its former state due to his own misconduct.
4-The defendant’s ongoing behavior demonstrates that the benefits expected from this marriage can no longer be achieved. We request that the court grant our client a divorce from the defendant.
5-The defendant’s lifestyle shows that he is unable to care for his children. For this reason, we request that custody of the three children be granted to the plaintiff and that the defendant be ordered to pay monthly alimony of …….TL for the plaintiff and …….TL for each child, for a total of …….TL per month.
LEGAL GROUNDS: HUMK, MK, and Relevant Legislation
EVIDENCE: Population Registry, Witnesses, Legal and All Types of Evidence.
RESPONSE PERIOD: 10 days
CONCLUSION: For the reasons stated above, we request that the parties be granted a divorce, that custody of the children be granted to the plaintiff, that the plaintiff be granted monthly …….-TL in interim alimony, which may be converted to poverty alimony in the future, and that the defendant be ordered to pay monthly ……. -TL in child support for each child, the defendant to be liable for litigation costs, and the attorney’s fees of the opposing party to be awarded to us as attorneys in accordance with Article 164/final paragraph of the Lawyers’ Act No. 1136, as amended by Law No. 4667.
PLAINTIFF’S ATTORNEY
