Petition for Family Home Annotation

TO THE DUTY FAMILY COURT
OF ISTANBUL

PLAINTIFF: Name and Surname (Turkish Republic Identity Number: …) - Address
REPRESENTATIVE: Lawyer's Name and Surname - Address
DEFENDANT: Name and Surname (Turkish Republic Identity Number: …) - Address
SUBJECT: Request for establishment of a family home annotation

EXPLANATIONS:

1. My client, ..., married the defendant, ..., in ... year, and the plaintiff and defendant purchased a house located at ... address and lived there together. However, due to the defendant's family creating difficulties, the title deed of this house couldonly be transferred to the defendant's name. Due to the violence and ill-treatment inflicted on my client by the defendant during the marriage, and due to many other problems, we have filed a lawsuit against the defendant in the ... Family Court, case number .../..., seeking divorce, alimony, and material and moral damages. This lawsuit, filed by us and with the defendant as the counterclaimant, is still pending.
2. The defendant is currently acting in bad faith due to the divorce proceedings initiated by my client. Therefore, my client is concerned that the defendant may sell the property in question, which was used as the family home during their marriage but is registered in the defendant's name.
3. For the reasons stated above, there is a risk that the property in question, registered in the defendant's name but used as a joint residence, may be transferred by the defendant due to the increasing unrest caused by the divorce proceedings. To prevent this, we have filed this lawsuit to establish the joint residence located at the address of … and registered in the land registry as … Province, … District, … Village, … Location, … Plot, … Parcel No. as a family home, andto request a precautionary measure to be placed on the property's title deed to prevent its transfer until the end of the lawsuit.

EVIDENCE:

1. Land Registry Records
2. Population records
3. Residence certificate
4. Witness statements
5. Expert examination
6. Discovery
7. Sworn testimony and all legal evidence

LEGAL GROUNDS: Turkish Civil Code (TMK) and other relevant legal legislation.

CONCLUSION AND REQUEST: For the reasons briefly presented and explained above, we respectfully request and demand, on behalf of our client, that our case be accepted, that the jointly owned residence located at … address, registered in the land registry as … province, … district, … village, … locality, … plot, … parcel no., where the parties resided together during their marriage, be established as a family home, that a precautionary measure be placed on the land registry record to prevent the transfer of the property in question to third parties, including forced sales, until the end of the case, and that the court costs and attorney's fees be borne by the opposing party.

…/…/…

Plaintiff's
Attorney's Name, Surname, and
Signature