TO THE HONORABLE COURT
…….
PLAINTIFF: …….
ATTORNEY: …….
DEFENDANT: …….
SUBJECT: Request for the Reorganization of Personal Relations with the Child.
EXPLANATIONS: 1-My client and the defendant ended their 8-year marriage by mutual agreement. The parties’ applications were accepted by the ……. Civil Court of First Instance, and the decision regarding the divorce, dated ……. with case number ……. and decision number ……. , was served to the parties and became final.
2-In the judgment, the parties’ joint child, Ayla, was awarded to the defendant mother. Since our client works outside the city, he agreed to see the child only during summer vacations, and the court made the arrangement accordingly. Our client also continues to pay the alimony in the amount of ……. as determined by the court on a regular basis.
3-Our client has completed his work outside the city and has started working again in the same city as the defendant and the child. He informed his ex-wife that he wanted to see his child every weekend according to this arrangement, without affecting the child’s schooling, but his request was denied.
4-The child needs his father’s love as much as his mother’s love. It is our client’s natural right to see his child regularly. The defendant is preventing this.
5-We request that your court reconsider our client’s relationship with the child, taking into account our client’s new situation, and decide that he should see his child every weekend.
LEGAL GROUNDS: Civil Code and other legislation.
EVIDENCE: Divorce decree, witnesses, enforcement file, other evidence.
RESPONSE PERIOD: 10 days
RESULT OF THE REQUEST: For the reasons stated, we request that our client’s relationship with his child be reorganized, that the defendant who caused the lawsuit to be filed pay the costs, 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