TO FAMILY COURT
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS :
SUBJECT : From our request for the delivery of the goods as a trustee with the determination of the goods
consists of.
DESCRIPTIONS :
1-) Our client and the defendant got married on …/…/…. As it can be understood from the family identity record presented in the Annex (ANNEX-1), the parties have a child named ….. from this marriage.
2-) About ….. months ago, the defendant sent our client to his father’s house, declaring that he did not want him anymore, even though he had no faults. After a while, she filed a divorce case in the Family Court. It was decided to reject the case, as the conditions for uncontested divorce did not occur as claimed by the plaintiff within the scope of the file. (ANNEX-2)
3-) Our client could not take the jewelry worn at the wedding and other belongings while leaving the house belonging to the defendant. The items are still in the possession of the defendant. In new divorce cases to be opened in the future, there is a danger that the defendant will hide the belongings by claiming that the belongings are not his own.
4-) In order to prevent the victimization of our client, it has become necessary to go to the court to determine the belongings in the presence of experts and witnesses.
The list of items we want to detect is as follows:
LEGAL REASONS :
LEGAL EVIDENCE: 1. Family population registration sample
…Family Court decision numbered …/… E. …/… K.
Witnesses to testify with their names and addresses
witness list, which shows the subjects
CONCLUSION AND CLAIM: For the reasons we have tried to explain above, we submit and request, by proxy, on behalf of our client, that the goods belonging to our client, which we have listed above, are found on the other side, that the values of the goods are determined by taking into account the expert statements, and that the delivery of the goods as a trustee is decided. …/…/…
ATTACHMENTS: 1. Example of family birth registration
…Family Court decision numbered …/… E. …/… K.
The names and addresses of the witnesses and the subjects they will testify
shows witness list,
One copy of certified power of attorney.
Plaintiff’s Attorney
Lawyer
