Request for Return of Items

TO THE DUTY FAMILY COURT

PLAINTIFF:
Name and Surname – (Turkish Republic Identity Number) – Address

ATTORNEY:
Lawyer's Name and Surname – Address

DEFENDANT:
Name and Surname – (Turkish Republic Identity Number) – Address

SUBJECT:
The plaintiff requests the return of the household goods belonging to our client in kind, or, if this is not possible, the collection of a total amount of … TL together with legal interest from the date of the lawsuit.

EXPLANATIONS:

1. Subject of the Case and Development of Events:
   My client, the plaintiff, and the defendant were divorced by the Family Court of …/… with case number …/… and decision number …/… dated …/…/…. During the divorce process, a disagreement arose between the parties regarding the division of acquired property. Some household items belonging to my client were unjustly withheld by the defendant.
2. Unlawful Retention of Client's Belongings:
   Some valuable household items (television, white goods, sofa set, and other personal belongings) that my client purchased with her personal savings prior to the divorce and for which invoices were issued in her name, are being unlawfully used by the defendant. This situation has caused my client significant hardship.
3. Regarding the Monetary Value of the Items and the Necessity of Their Return
   : The client requests the return of the items in kind. However, if return is not possible, the client is required to pay the value determined by expert appraisal. The invoices submitted by the client prove that these items are in their possession.
4. Legal and Financial Liability of the Defendant:
   By failing to return the client's belongings, the defendant has acted in violation of both the Civil Code and the rules regarding the division of property after divorce. Therefore, the client is exercising their right to file a lawsuit for the return of the withheld items in kind or for the recovery of their monetary value.

EVIDENCE:

• The court decision regarding the divorce decree,
• Invoices and purchase documents for the items,
• Witness statements,
• Expert examination and all necessary legal evidence.

LEGAL GROUNDS:
Turkish Civil Code, Code of Civil Procedure and related legislation.

CONCLUSION AND REQUEST:
For the reasons presented and explained above,

1. The items in question should be returned in their original condition
2. If the return of the items in kind is not possible, the defendant shall be ordered to pay a total of … TL, determined by expert examination, together with legal interest accruing from the date of the lawsuit
3. On behalf of my client, I respectfully request and demand that the court order the defendant to pay the court costs and attorney's fees.

Date
Plaintiff's
Attorney's Name and Surname
Signature