Complaint Petition Regarding the Crime of Child Abduction

TO THE REPUBLIC PROSECUTOR'S OFFICE

ISTANBUL

COMPLAINANT:

• Name and Surname: (Your First and Last Name)
• Turkish Republic Identity Number: (Your Turkish Republic Identity Number)
• Address: (Your Full Address)

SUSPICIOUS:

• Name and Surname: (Suspect's Name and Surname)
• Turkish Republic Identity Number: (Suspect's Turkish Republic Identity Number, if available)
• Address: (Suspect's address, if known)

CRIME: Child Kidnapping

DATE OF CRIME: (Date the child was abducted)

SUBJECT: Request to file a complaint regarding the crime of child abduction and to initiate public prosecution against the suspect.

EXPLANATIONS:

I married the suspect in ... year and we had a child named ... from this marriage. We divorced by mutual agreement in ... year and the custody of our child was given to me by the decision of the ... Family Court, case number .../...

However, the suspect, my ex-husband, abducted our child on …/…/… by taking him off the school bus. I have received information that the suspect took our child and left the country.

The suspect took our child without my consent or knowledge, despite me having custody rights. This act constitutes the crime of "child abduction" as defined in Article 234 of the Turkish Penal Code.

Both my child and I are experiencing significant psychological trauma due to the kidnapping. I demand that my child be found and returned to me as soon as possible, and that the suspect be punished.

EVIDENCE:

• Divorce decision,
• The child's birth certificate,
• The document showing the suspect's departure information from the country
• Statements from the school bus driver and eyewitnesses.

LEGAL GROUNDS: Turkish Penal Code Article 234 and related legislation.

CONCLUSION AND REQUEST:

For the reasons explained above;

• We request that an investigation be launched and a public prosecution be initiated against the suspect… for the crime of kidnapping a child
• I want our child, ..., to be found and returned to me as soon as possible
• A travel ban should be imposed on the suspect
• I respectfully request and demand that the court order the suspect to pay the court costs and attorney's fees.

History: …/…/…

Signature

(Your First and Last Name)

APPENDIX: (List of documents to attach, if any)