Divorce Petition Based on Abandonment - Divorce Lawyer

TO THE FAMILY COURT

PLAINTIFF: (Turkish Republic Identity Number: XXXX)

ATTORNEY: Lawyer (Name, Surname, Bar Association Registration Number: XXXX)

DEFENDANT: (Turkish Republic Identity Number: XXXX)

SUBJECT: Divorce due to abandonment.

EXPLANATIONS:

1. My client and the defendant were married on (date). However, they have no children.

2. My client is employed as a worker. The defendant is a housewife. Approximately (a certain period of time) ago, the defendant left the shared residence under the pretext of visiting her family in (city/region) and has not returned since.

3. Throughout their marriage, my client tried to meet his wife's expectations, showed her respect, did everything he could for her, and expressed his love to his beloved wife as if he were living his last moments. However, the defendant showed no respect for the institution of marriage and abandoned their shared home based on a lie.
4. My client has used every possible means to contact the defendant, including telephone and letter, but the defendant has been indifferent to these efforts. On the contrary, the defendant has undermined my client's attempts to achieve his goal by saying, "Don't call me again," causing him to lose faith. My client, not content with this, has also sent a court-ordered cease and desist letter to the defendant to make him seriously consider his actions and attempt to persuade him to return to their shared residence. Unfortunately, all of my client's efforts have been lost to despair.

EVIDENCE: Population registration certificate, court summons, (previous case file number), witness statements, and other legal evidence.

LEGAL GROUNDS: Article 164 of the Turkish Civil Code and related legislation.

CONCLUSION AND REQUEST: For the reasons stated above, I respectfully request and demand that the parties be divorced, that the divorce decree be registered in the civil registry upon its finalization, and that the court costs and attorney's fees be borne by the defendant.

(History)

(Lawyer's Name, Surname, Signature)