-SAMPLE Petition-
TO ANKARA ON DUTY ( ) FAMILY COURT
REQUESTING :
ADDRESS :
ATTORNEY:
ADDRESS :
TELEPHONE :
DEFENDANT:
ADDRESS :………
CASE VALUE: ………. TL
SUBJECT OF THE DEMAND: It consists of our demand for compensation for the loss suffered by the client due to the breach of the engagement between the parties due to the defendant’s faulty behavior.
DESCRIPTIONS
Plaintiff A… B… and defendant C… D…, …. By renting an engagement hall at Batıkent Yenimahalle Ankara, ../../…. In their history, they were engaged in an engagement ceremony in which the close circles of the parties also participated. Photographs of the engagement ceremony are attached. (ANNEX 1)
After the engagement, shopping for houses and weddings began; Many expenses have been incurred. However, as the marriage date approached, the attitude of the defendant and his family towards the client and his family began to change. The material burden of the purchased goods was tried to be put on the plaintiff client and his family; Tensions arose between the parties.
The family of the defendant got involved in all the household goods taken and caused the parties to get nervous. Thus, the defendant plaintiff took a stand against the client and started not to participate in the expenses incurred. Despite all this, the plaintiff client still continued to provide household goods with the belief that they would establish a happier home.
Common friends of the parties who are aware of the defendant’s attitude towards the client ../…/…. Historically, they hosted the parties in their homes; During the conversation, the defendant suddenly rose up and started insulting the plaintiff client and declared that he broke the engagement. This incident was witnessed by the friends of the parties, and the witness list is attached to our petition. (ANNEX-2)
The defendant broke off the engagement without just cause, and offended his client in the presence of his close friends. As a result of the situation, the plaintiff client suffered a great mental breakdown and was left alone in the middle.
The payments made for the goods bought both for the engagement ceremony and later for the marriage union were left to the plaintiff client, and the client was left alone after suffering material damage as well as the moral damage. The payments made by the client to the engagement hall, the cost of food/beverage and the invoices for the payments made are presented in the appendix to this petition. (Annex-3) In addition to this, he bought many items for the marriage union by trusting the defendant, and the invoices for these items are presented in the annex of this petition. (ANNEX-4)
Due to the fact that the defendant, who broke the engagement without a just cause, was obliged to compensate the material damage inflicted on his client, it became necessary to open this lawsuit.
LEGAL REASONS: TMK, HMK, Attorneyship Law and other relevant legislation
EVIDENCES: Photographs of the engagement ceremony, invoices for the payments made to the engagement hall, food/beverage cost and other engagement payments, witnesses, invoices for the items purchased to be used in the marriage union, witness, expert report, discovery and all other evidence.
RESULT AND DEMAND: For all the reasons explained above; without prejudice to our claim rights regarding the surplus;
1- The legal interest of the defendant, who broke the engagement without a just cause, of the damage inflicted on the client in the amount of ..… TL from the defendant,
2- By proxy, we request that it be decided to leave the trial expenses and attorney’s fees to the defendant. 11.01.2022
ATTORNEY A… B… ATTORNEY
