SAMPLE PETITION FOR DIVORCE AND ITS ANTI-CONSEQUENCES

TO THE DUTY FAMILY COURT / ANKARA

PLAINTIFF:   Gamze Kaya - 12345678901 - Armağan Mahallesi, Gün Sokak, Park Caddesi, No:8, Apartment:2, Altındağ, Ankara

REPRESENTATIVE:   Eren Gümüş-Kaya Mahallesi, Hayat Sokak, Uzun Caddesi, No:12, Apartment:10, Altındağ, Ankara

DEFENDANT:   Kadir Kaya - Armağan Mahallesi, Gün Sokak, Park Caddesi, No:8, Apartment:2, Altındağ, Ankara

SUBJECT OF THE CASE:   Divorce, compensation for material and moral damages, interim measures, alimony and child support.

EXPLANATIONS:

1- My client married the defendant on June 16, 2018. They have a child, Eray, from this marriage. The defendant's excessively jealous and controlling behavior over time has fundamentally shaken the marital union. Therefore, the parties have decided to terminate their marriage.

2-In this context, it has become necessary to request the divorce of the parties, the granting of custody of their joint child Eray to the plaintiff mother, the payment of material compensation for the lost earnings of my client due to the defendant's excessive jealousy and dismissal of my client from his job, the payment of moral compensation for the severe psychological pressure on my client due to the defendant's excessively restrictive actions and the resulting need for my client to meticulously consider every action, and the provisional alimony of 8,000 Turkish Lira per month for my client and 5,000 Turkish Lira per month for the joint child as of the date of the lawsuit, with the continuation of the 8,000 Turkish Lira per month provisional alimony awarded to my client as spousal support and the 5,000 Turkish Lira per month provisional alimony awarded for the joint child as child support after the divorce decree becomes final.

EVIDENCE: 1-Witness statements, 2-Text exchanges, 3-Population registry records, 4-Documents relating to financial status, 5-All other relevant evidence.

WITNESSES: 

1- Aytaç Güner-12345667887-Armağan Mahallesi, Gün Sokak, Park Caddesi, No:8, Apartment:3, Altındağ, Ankara

2-Sevtap Yılmaz-32415678947-Armağan Mahallesi, Gün Sokak, Park Caddesi, No:8, Apartment:1, Altındağ, Ankara

LEGAL GROUNDS: Turkish Civil Code Articles 166, 169, 174, 175, 182 and related legislation.

REQUESTED OUTCOME:  For the reasons explained above and to be considered ex officio, I respectfully request and demand that the lawsuit be accepted, that the parties be divorced, that the divorce be registered in the population registry upon finalization, that the custody of the joint child be given to the plaintiff mother, that the defendant be awarded 50,000 Turkish Lira in material damages and 20,000 Turkish Lira in moral damages, that a monthly interim alimony of 8,000 Turkish Lira be awarded to my client as of the date of the lawsuit, and a monthly interim alimony of 5,000 Turkish Lira be awarded to their joint children, that the monthly interim alimony of 8,000 Turkish Lira awarded in favor of my client continue as poverty alimony upon finalization of the divorce decree, and that the monthly interim alimony of 5,000 Turkish Lira awarded for their joint children continue as child support, and that the court costs and attorney's fees be borne by the defendant. 16/09/2024

PLAINTIFF'S ATTORNEY

LAWYER EREN GUMUS

SIGNATURE