Petition For Divorce On The Grounds Of Adultery
[Enter Court Information] TO THE HONORABLE COURT
[Enter Location Information]
PLAINTIFF: [Enter Name]
ATTORNEY: [Enter Attorney Information]
DEFENDANT: [Enter Name]
SUBJECT: Divorce on the grounds of adultery.
STATEMENTS: 1-My client has been married to the defendant for 22 years. They have six children from their marriage. The marriage records are located in [Enter province] Province, [Enter district] District, [Enter neighborhood] Neighborhood, [Enter volume number] Volume No., [Enter page number] Page No., and [Enter registry serial number] Registry Serial No.
2-The defendant is a market vendor who occasionally travels outside the city to sell fruits and vegetables at markets and fairs. My client has been sewing at home for years and contributes to her husband’s livelihood and the household expenses.
3-My client has been hearing rumors for a long time that her husband is cheating on her. The defendant, who has been coming home only on weekends for some time, told my client that his work was busy and that he was therefore sometimes forced to sleep in his truck. When this situation continued for more than six months, my client became suspicious and began following her husband. Upon observing that her husband was regularly visiting another home located at [Enter address information] in the [Enter district information] district, our client discovered through her investigation that her husband was living as husband and wife with another woman.
4-In this matter, the defendant acted quite brazenly: she had her own name inscribed on the doorbell and had a telephone line installed in the house under her own name with the subscriber number …………. Worse still, our client learned that the defendant had a son with this woman. When our client confronted the defendant about the situation, she did not deny it but admitted to it.
5-The defendant is not currently living with our client and the children. He is using the home at the above address with the other woman he is living with. The defendant’s infidelity is proven both by his own statements, the testimony of witnesses, and the child born from his illegitimate relationship.
6-We request that the court grant our client a divorce from the defendant. Additionally, we request that the court order [Enter amount] TL in spousal support for our client, to be converted to maintenance upon divorce, and [Enter amount] TL in interim child support for each of the children.
LEGAL GROUNDS: Turkish Civil Code Article 129 and other applicable legal provisions.
EVIDENCE: Population registry records, witnesses, DNA tests, and all relevant medical reports, as well as other evidence.
RESPONSE PERIOD: 10 days.
REQUESTED RELIEF: Based on the stated reasons, we request that the parties be divorced on grounds of adultery, that custody of the minor children be granted to the plaintiff, that the defendant be ordered to pay the plaintiff monthly spousal support of [Enter amount] TL and monthly child support of [Enter amount] TL in child support from the defendant, the litigation costs to be borne by the defendant, and that the opposing party’s attorney’s fees be awarded to us as attorneys pursuant to the final paragraph of Article 164 of the Lawyers’ Act No. 1136, as amended by Law No. 4667.
PLAINTIFF’S ATTORNEY