TO FAMILY COURT JUDGE;
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS :
SUBJECT : It is our petition that includes our requests for divorce and alimony due to mental illness.
DESCRIPTIONS :
1-) Our client married the defendant’s wife on …/…/…. As it can be understood from the family identity record presented in the annex of our petition (Appendix 1), the couple has two children named … and … from this marriage. One of the children is … years old and the other is … years old and both are young.
2-) After a while after the couple’s marriage, there were some changes in the behavior and behavior of the defendant spouse. So much so that the defendant spouse began to exhibit increasingly unstable behaviors, to have serious difficulties in making a decision on any issue, and to feel and experience some things that did not really happen as if they had actually happened. In the meantime, an intense forgetfulness, which was never seen before, also occurred in the defendant spouse.
3-) Upon the developments, the defendant’s spouse, who underwent a serious health screening with the initiatives of our client, was diagnosed with …. … As can be clearly understood from the report prepared by the Chief Physician of the Mental and Neurological Diseases Hospital (Appendix 2), the aforementioned disease is a medically incurable disease, but it can only be kept under control at a certain level. In the mentioned report, it is clearly stated that the defendant spouse should be kept under observation for a certain period of time.
4-) Due to the situation in question, the joint life of the couple has become increasingly unbearable. This negative situation of the defendant spouse sometimes even poses a serious danger for the young joint children. This last point will be clarified by the statements of our witnesses, whose names and addresses are written in the witness list (Annex 3), if your court deems it appropriate. Moreover, both of the joint children are still young and in need of mother’s care and attention. For this reason, we demand that the joint children stay with our client throughout the case, and that their custody be given to our client when it is decided to divorce the couple.
5-) Our client is a housewife and does not have any income. Currently, she is staying with her parents with her children. Since the economic situation of her parents is not good, she cannot get enough support from them. Both of the joint children are still young and in need of mother’s care and attention. For this reason, we demand that during the lawsuit, a total of … TL of alimony, which is … TL for our client and … TL for each child, and that the joint children stay with our client throughout the trial.
6-) Due to the reasons we have tried to explain above, it has become necessary to open this lawsuit.
LEGAL REASONS :
LEGAL EVIDENCE: Family identity record sample, photocopy of identity card, report dated …/…/…, witness statements, expert examination.
CONCLUSION AND REQUEST: For the reasons we tried to explain above, the divorce of the parties, the joint children staying with our client during the trial, the custody of the couple to be given to our client in case of divorce, a monthly … TL for our client and a monthly … TL for each of the joint children, a total of … TL. We request, by proxy, that it be decided that this alimony will continue as poverty and participation alimony after the divorce, and that the trial expenses and attorney’s fee be charged to the defendant. …/…/…
APPENDIX 1. Copy of family identity record and ID card,
…/…/… dated …. Hatanesi’s report numbered …
The names and addresses of the witnesses and the subjects they will testify
list of witnesses,
A copy of a certified power of attorney containing one special authorization.
Plaintiff’s Attorney
Lawyer
