Sample Petition For Interim Alimony
TO THE HONORABLE COURT
…….
PLAINTIFF:…….
ATTORNEY:…….
DEFENDANT:…….
SUBJECT: Request for Alimony.
EXPLANATIONS: 1-Our client has been married to the defendant for 10 years. They have three children, one aged 9 and two aged 7 (twins). All three children are in primary school.
2-For approximately 4 years, the defendant has been coming home late, sometimes staying out overnight, using business trips as an excuse. Although our client is disturbed by the situation, she has not spoken up until now due to the influence of her young children and her surroundings.
3-The defendant has completely abandoned the home for approximately 3 months. He is not concerned with either our client or their young children. The home where our client and the defendant lived together was inherited by our client from her father. After getting married, our client left her job as a secretary and became a housewife. She currently has no income. The defendant works in insurance. His income is around 4,000,000,000 TL (four billion TL) per month.
4-Relatives and friends who intervened have been unable to remedy the situation. Although the future of the marriage is uncertain, our client does not intend to file for divorce at this time for the sake of the children’s future. However, she needs her husband’s help for her own livelihood and the care of the children.
5-We request provisional alimony from the defendant in the amount of …… per month for our client and …… for each child, for a total of …….
LEGAL GROUNDS: MK.m.162 and other articles of law.
EVIDENCE: Population records, witnesses.
RESPONSE PERIOD: 10 days.
CONCLUSION: For the reasons stated, the Defendant shall pay monthly maintenance of ……….. for our client and …… for each child, totaling ……. Furthermore, as a precautionary measure during the proceedings, maintenance shall be awarded for the needs of our client and the children, and the costs of the proceedings shall 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
…….
