TO Mr. JUDICIARY
…….
COMPLAINANT :…….
ATTORNEY: …….
DEFENDANT:…….
CRIME: NON-COMPLIANCE WITH THE CHILD DELIVERY
EXPLANATIONS: Our client and the defendant ……. on ……. Court of First Instance ……. Main and ……. They were divorced by decision no.
2- During their marriage, their joint children were given to the defendant mother .. aged .. The court decided that little ….. was to be seen by his father every Saturday between 11:00 and 16:30 in the morning.
3- Our client wanted to settle this meeting by agreement without involving the bailiffs, but the defendant did not agree to this. Thereupon, the verdict was given by our client ../../…. on …… Enforcement Directorate ../…. It has been put into execution with the file numbered E. and 55 Execution Orders on this matter have been notified to the accused and it has been finalized.
4-The defendant persists in not complying with the verdict of the verdict. Although our client went to take the child with the officer for 3 weekends, the accused kidnapped the child on the grounds that he was taking the child to the doctor. Although he was warned in the execution file, the doctor did not submit the report either.
5-Defendant’s İİK. According to Article 25/a and 341, we want the criminal act to be punished.
LEGAL REASONS:
EVIDENCE: Enforcement File, witnesses
RESULT OF THE REQUEST: For the reasons explained, we request that the accused be punished, the costs of the trial be charged to the accused, and that the attorney’s fee of the other party be decided on our behalf as an Attorney in accordance with the 164/last paragraph of the Law on Attorneyship No. 1136 amended by Law No. 4667.
COMPLAINT ATTORNEY
