Petition for the Protection of Children’s Property
TO THE ISTANBUL FAMILY COURT
PLAINTIFF:
DEFENDANT: (Custody Holder)
SUBJECT: Protection of children’s property
EXPLANATIONS
1- Our client and the defendant, who has custody rights, were previously involved in a lawsuit, and the Istanbul XXth Family Court ruled on their divorce with its decision numbered 2014/XXX and 2016/XX. Along with the divorce decree, custody of our client’s and the defendant’s children, XXXX and XXXX, was granted to the defendant mother, and this decision became final after being notified to the parties following approval by the Court of Appeals.
2- In accordance with the provisions of the Turkish Civil Code, the spouse who has custody rights after the divorce is required to submit to the court a ledger showing the inventory of the child’s property. In addition, any significant changes in the child’s property for any reason must be reported to the court immediately. We are required to apply to the court for the determination of the property of XXXX and XXXXX, the joint children of the client and the defendant, and for the protection of this determined property.
EVIDENCE: Witness, court divorce decree, and other legal evidence.
CONCLUSION AND REQUEST: For the reasons briefly explained above and to be considered ex officio by your court, we respectfully request that you determine the current assets of the client and the defendant’s joint children XXXX and XXXXX, place these assets under protection, and order the other party to bear the costs of the proceedings and attorney’s fees.
Plaintiff’s Attorney