-SAMPLE Petition-
TO THE FAMILY COURT OF ANKARA (APPEAL AUTHORITY)
(To be sent)
TO ANKARA ( ) FAMILY COURT
D.NO: 2021/…..
REQUESTED
DEFENDANT:
ADDRESS :………
ATTORNEY:
ADDRESS :
TELEPHONE :
Plaintiff:
ADDRESS :…
SUBJECT OF THE REQUEST: Ankara ( ) Family Court ../../…. The date consists of the submission of our objections to the protection decision numbered 2021/… E.
DESCRIPTIONS
The ../../…. We have learned about the Protection Decision According to the Law No. 6284 dated and our objections to the said decision are presented below.
In the aforementioned decision, a decision of suspension and injunction was given for the client, this decision was made by taking into account the unilateral demands and biased evidence of the requesting party, and the requesting party is in bad faith. Namely:
It is unknown to whom and when the so-called speech recordings submitted by the requesting party in the annex of the petition were sent. Because the plaintiff client did not meet with the requesting defendant after the divorce case was filed, and he does not even know his phone number. The client has not seen the requesting party for years.
We do not accept the authenticity of the unrealistic recordings submitted by the requesting party. The requesting party started to provoke and harass the client by telephone (either by himself or by others), especially after the client brought up the issue of divorce. At this point, we request the subpoena of the GSM records. Because when these records are summoned, it will be revealed that the claims of the requesting party are not true.
In addition, the document showing the so-called messaging attached to the request does not include the requesting party’s conversations and messages. Even having such a one-sided conversation is against the normal flow of life. The requesting party has issued this protection order in order to put the client in trouble. Because the client has not seen him for years.
LEGAL REASONS: HMK, TMK, Atty. Blood. And other relevant legislation
EVIDENCE: Message and e-mail printouts (subpoena is requested from GSM company), Witnesses (will be presented later if necessary), Expert, discovery, oath, all other evidence
Witnesses:
E….. (T.C.:………….)
………………….. Batıkent Yenimahalle Ankara
F….. (T.C.:………….)
………………….. Ostim Yenimahalle Ankara
We reserve the right to present evidence against the evidence presented/to be submitted by the opposing party.
CONCLUSION AND REQUEST: For all the reasons explained above and to be taken into account by your Court ex officio;
1-Ankara ( ) Family Court’s ../../…. Annulment of the Protection Order in accordance with the Law No. 6284 dated
2- If your court thinks otherwise, the file is submitted to the relevant authority for a decision,
We request a decision by proxy. 10/12/2021
