Divorce Petition For Cruel Treatment And Alimony
…… TO THE HONORABLE COURT
…….
PLAINTIFF: …….
ATTORNEY: …….
DEFENDANT: …….
SUBJECT: Divorce and Alimony Request Due to Severe Abuse.
EXPLANATIONS : 1-Our client has been married to the defendant for 8 years. The marriage is registered in the population registry of ……. Province, ……. District, ……. Neighborhood, ……. Volume No., ……. Page No., and ……. Register No. They have three children named Elif, Semih, and Sadiye.
2-The defendant has fallen into a state of depression over the last two years due to being unemployed. He comes home drunk almost every night and beats both his wife, our client, and their children. He also uses foul language and insults both our client and our client’s family.
3-Their neighbors, who live in the same apartment building, have often witnessed their fights, and on several occasions, our client has been forced to seek refuge with her neighbors along with her children. Those who intervened have warned the defendant on several occasions, but the defendant has not corrected his behavior, and it has not been possible to restore the marital union, which has been disrupted due to his own fault.
4-The plaintiff’s ongoing behavior shows that the benefits expected from this marriage can no longer be achieved. We request that our client be granted a divorce from the defendant.
5-The defendant’s lifestyle shows that he/she is unable to care for the children. Therefore, we request that custody of the three children be granted to the plaintiff and that the defendant be ordered to pay monthly alimony of …….TL for the plaintiff and …….TL for each child, for a total of …….TL per month.
LEGAL GROUNDS: HUMK, MK. And Related Legislation
EVIDENCE: Population Registry, Witnesses, Legal and All Types of Evidence.
RESPONSE PERIOD: 10 days
CONCLUSION: For the reasons stated, the parties shall be divorced, custody of the joint children shall be granted to the plaintiff, the plaintiff mother shall be awarded monthly …….-TL as a precautionary measure, to be converted into alimony for poverty in the future, and monthly ……. -TL in child support for each child from the defendant, the defendant to bear the costs of the proceedings, and the attorney’s fees of the opposing party to 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