Petition for Protection of Children’s Property
TO THE JUDGE OF ISTANBUL FAMILY COURT
THE PLAINTIFF :
DEFENDANT : (Custody Right Holder)
SUBJECT : Protection of children’s property
EXPLANATIONS
1- With the previous lawsuit between our client and the defendant custodial right holder, it was decided to divorce them with the decision numbered 2014/XXX Main and 2016/XX Decision of Istanbul XXth Family Court. With the divorce decision, the custody of XXXX and XXXX, the joint children of our client and the defendant spouse, was also given to the defendant mother, and this decision was finalized by notifying the parties after the approval of the Supreme Court.
2- In accordance with the provisions of the Turkish Civil Code, the spouse who has the right of custody after the divorce must submit a book showing the breakdown of the assets of the child to the court. In addition, he/she must immediately notify the court of any significant changes in the assets of the child for any reason. We are obliged to apply to the court for the determination of the assets of XXXX and XXXXX, the joint children of the client and the defendant, and for the protection of these identified assets.
EVIDENCE : Witnesses, Court Decree of Divorce, and other legal evidence.
CONCLUSION AND REQUEST : For the reasons briefly explained above and to be taken into consideration by your court ex officio, we submit to your request and opinion that the existing assets of the client and the defendant’s joint children XXXX and XXXXX be determined, that these assets be taken under protection, and that the costs of the proceedings and attorney’s fees be imposed on the other party.
Plaintiff Attorney