Sample Complaint Letter For Violation Of Alimony Conditions
ANKARA ON-CALL ENFORCEMENT CRIMINAL COURT
COMPLAINANT
(CREDITOR):
ATTORNEYS:
DEFENDANT
(DEBTOR):
SUBJECT: Our request for the punishment of the debtor who has failed to pay alimony.
OFFENSE: Failure to comply with the decision regarding alimony pursuant to Article 344 of the Code of Enforcement and Bankruptcy.
EXPLANATIONS:
1- The parties were divorced by the decision of the Ankara 6th Family Court dated … with case number … E. – … K. (ATTACHMENT-1) The decision has been appealed by us.
2- Pursuant to the decision issued by the Ankara 6th Family Court, provisional alimony of 1000.00 TL was awarded to the client from the date of the lawsuit until the date of the decision, and 600.00 TL was awarded from the date of the decision onwards. (ATTACHMENT-2)
3- Based on this decision, enforcement proceedings have been initiated from the Ankara 1st Enforcement Directorate’s file numbered … E.
5- The debtor failed to make alimony payments for September, October, and November 2021, making it necessary to file this lawsuit.
LEGAL GROUNDS: IİK and other legal regulations
EVIDENCE: Without prejudice to our right to present evidence against the evidence of the opposing party;
1- The judgment of the Ankara 6th Family Court numbered … E. – … K. (ATTACHMENT-1)
2- Ankara 1st Enforcement Directorate file numbered … E. (We request its summons.)
3- And any other legal evidence.
CONCLUSION AND REQUEST: For the reasons explained above, we request that the debtor, who has failed to pay alimony, be punished in accordance with Article 344 of the Enforcement and Bankruptcy Law, and that the defendant be ordered to pay the court costs and attorney’s fees. Sincerely. …/…/..
Attorney for the Complainant
Atty.