Divorce On Grounds Of Indecency
TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT : Our request for divorce due to dishonor.
EXPLANATIONS: 1-Our client has been married to the defendant for 12 years. Population records are in ……. Province, ……. District, ……. Neighborhood, ……. Volume No., ……. Page No., ……. Register No. The parties have 3 children from this marriage.
2-The defendant has neglected the home for a long time and has not fulfilled the obligations of the marriage. The defendant spends time with friends who are not well-regarded in the community and generally have criminal records for theft, drugs, etc.
3-This situation has negatively affected our client and his family’s life. Our client lives in a small town, and his neighbors have cut off relations with him because of his wife’s friends.
4-The defendant’s relatives have been told about the situation, but the defendant has not responded. He has also been to the police station several times with his friends. Although he does not yet have a criminal record, this situation alone has been enough to wear down our client, who is not accustomed to this kind of family life.
5-We request that our client be granted a divorce from the defendant, who leads a disreputable life.
LEGAL GROUNDS: MK.m.131 and other legal regulations.
EVIDENCE: Population registry, witness statements, and all types of evidence.
RESPONSE PERIOD: 10 days.
RESULT OF THE REQUEST: For the reasons stated, we request that the parties be divorced, that custody of the minor children be granted to the plaintiff mother, 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, pursuant to the last paragraph of Article 164 of the Attorney Act No. 1136, as amended by Act No. 4667.
PLAINTIFF’S ATTORNEY