…….TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT: Request for an Increase in the Monthly ……………….. Alimony to ……. and for it to be Set at Monthly …….
EXPLANATIONS :1-The defendant ……. and our client ……. were divorced by the judgment of the Civil Court of First Instance dated ……. , No. ……. E. and ……. K.
2-As a result of the divorce, custody of the couple’s child, ……. born on ……., was granted to the mother. No alimony was awarded for the joint child in this judgment. However, due to worsening living conditions and the resulting increase in the child’s expenses and school costs, our client filed a lawsuit at the ……. Civil Court of First Instance, file no. ……. E., requesting alimony for the joint child.
3- The ……. Civil Court of First Instance, with its ruling dated ……. and numbered ……. E. and ……. K., has ordered monthly child support of …….-TL for the joint child …….
4- The monthly child support of …….-TL awarded in ……. has become insufficient due to current economic conditions and the growth and increased needs of the child. The child, Necdet Onur, is currently in the sixth grade at Anadolu High School.
5-The improvement in the defendant’s financial situation, the decline in the purchasing power of money in the face of high inflation, and the increase in the needs of the joint child have made it necessary to file this lawsuit.
LEGAL GROUNDS: HUMK, MK, and Related Legislation
EVIDENCE:
….. 1 AHM ../… E. File Number
….. 2 AHM ../… E. File Number
Investigation of the Parties’ Financial and Economic Situation
Population Records, Witnesses, Legal and Other Discretionary Evidence
RESULT OF THE CLAIM: For the reasons stated, we request that the monthly alimony of ……. be increased by ……. to ……. per month, that the costs of the proceedings be borne by the defendant, and that the opposing party’s attorney’s fees be awarded to us as attorneys, in accordance with the last paragraph of Article 164 of the Attorney Law No. 1136, as amended by Law No. 4667.
PLAINTIFF’S ATTORNEY