TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT : Request for Reorganization of Personal Relations with the Child.
EXPLANATIONS: 1-My client and the defendant ended their 8-year marriage by mutual agreement. The parties’ applications were accepted by the ……. Civil Court of First Instance, and the decision regarding the divorce, dated ……. , Case No. ……. and Decision No. ……. , was served on the parties and became final.
2-In the judgment, the parties’ joint child, Ayla, was awarded to the defendant mother. Our client, who works outside the city, agreed to see the child only during summer vacations, and the court made the arrangement accordingly. Our client also continues to pay the alimony in the amount of ……. as determined by the court on a regular basis.
3-Our client has completed his work outside the city and has started working again in the same city as the defendant and the child. He informed his ex-wife that he wanted to see his child every weekend according to this arrangement, without affecting the child’s schooling, but his request was rejected.
4-The child needs his father’s love as much as his mother’s love. It is our client’s natural right to see his child regularly. The defendant is preventing this.
5-We request that the court reconsider our client’s relationship with the child, taking into account our client’s new circumstances, and decide that he should see his child every weekend.
LEGAL GROUNDS: Civil Code and other legislation.
EVIDENCE: Divorce decree, witnesses, enforcement file, other evidence.
RESPONSE PERIOD: 10 days
REQUESTED OUTCOME: For the reasons stated above, we request that the relationship between our client and his child be reorganized, that the defendant who caused the lawsuit to be filed pay the expenses, and that the attorney’s fees of the opposing party 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