Petition for Identification and Return of Valuable Items
… TO THE FAMILY COURT
Case Number: …/…
REQUESTING PARTY FOR PROPERTY INSPECTION : Name and Surname (Turkish Republic Identity Number: …) – Address REPRESENTATIVE: Lawyer's Name and Surname – Address – Telephone RESPONDING PARTY: Name and Surname – Address
SUBJECT: Request for identification of goods and determination of their value
EXPLANATIONS:
1- My client and the defendant were married in [year] and have been living separately for a long time due to disagreements between them. During their marriage, many valuable items and materials were acquired and accumulated. However, as the divorce process progressed, it became clear that the defendant had seized my client's personal belongings and acquired some valuable items.
2- During the divorce process, my client learned that some of her valuable personal belongings and materials used jointly were in the defendant's house. It is necessary to list these items and determine their location. Therefore, we request that your court conduct an inventory of these items.
3- My client states that the location of the materials must be determined in order to claim compensation for the items in case of loss or damage. Since there is a risk that the defendant may conceal or diminish the value of the items, no action should be taken without an inventory process.
4- There is uncertainty regarding the nature of the items; therefore, this inventory process is necessary to definitively determine which items belong to the defendant and which belong to my client.
ITEM LIST:
- 1 Electric Piano
- 1 Silver-Framed Mirror
- 2 Modern Art Paintings
- 1 Leather Sofa Set
- 1 Bridal Jewelry Set (Gold and Diamond)
- 2 Luxury Watches
- 1 Set of Porcelain Wedding Gifts
- 1 Bedroom Set (Bed, Pillow, Duvet)
- 2 Antique Coffee Tables
- 1 Ironing Board and Iron
- 1 Television Unit
- 3 Wedding Photos and Album
- 1 Set of Glass Serving Sets
- 1 Set of Cutlery
- 2 Fashion Bags
- 1 Antique Clock
- 1 Acoustic Guitar
- 1 Refrigerator
- 1 Set of Cameras
EVIDENCE:
- Family Court file number …/… Case, …/… Decision
- Witness statements
- Photographs and list of items
- Wedding documents, invoices, and purchase documents
WITNESSES:
- Name and Surname – (Turkish Republic Identity Number: …) – Address
- Name and Surname – (Turkish Republic Identity Number: …) – Address
LEGAL GROUNDS:
Relevant provisions of the Turkish Civil Code, Family Law and related legislation.
CONCLUSION AND REQUEST:
For the reasons explained above, I request that an expert report be obtained to determine the location of the items owned by my client and to ascertain the value of the lost or damaged items; if the items cannot be found, that witness and expert statements be used to determine their value; and that the court costs and attorney's fees be borne by the opposing party. …/…./….
Name and Surname of the Attorney Requesting the Determination Signature