sample petition for divorce due to adultery
ANKARA FAMILY COURT ON DUTY
THE PLAINTIFF Name- Surname (Turkish ID Number)
Address
AGENT Attorney Name-Surname
Address
DEFENDANT Name-Surname (Turkish ID Number)
Address
SUBJECT: Divorce due to adultery, pecuniary and non-pecuniary damages, custody and maintenance.
EXPLANATIONS:
(This section should be filled in by considering the content of the concrete case within the scope of the procedure specified by the Legislator)
1-) The parties were married on …/…/…/… and they have … joint children from this marriage. One of the joint children was born in …. and the other was born in ….. The plaintiff’s occupation is …… and his monthly income is … TL, the defendant is ……… and his monthly income is … TL.
2-) The marriage of the parties has been shaken due to the full fault of the defendant and the marriage has become unbearable for the parties. The defendant cheated on the plaintiff for months and had an affair with someone else. (In this section, the events related to the alleged matter should be explained with evidence).
3-) The fact that the defendant cheated on the plaintiff will be established by the evidence presented to the court and to be collected.
For this reason, the parties are divorced on the grounds of adultery, the custody of the joint children is given to the plaintiff mother as a precautionary measure while the case is pending and definitively at the end of the case, the plaintiff client …. TL pecuniary, ……. TL and ……….. TL per month to the joint children during the pendency of the lawsuit and at the end of the lawsuit, it has become necessary to file the relevant lawsuit in order to decide to pay alimony to continue as subsidiary alimony.
LEGAL EVIDENCES Witnesses, hotel records, photographs, message documents and all kinds of relevant legal evidence. (Evidence to prove the allegation of adultery should be specified here.)
LEGAL GROUNDS: CCP, TMK and related legal legislation.
CONCLUSION and REQUEST: For the reasons explained in detail above;
1-) Divorce of the parties due to adultery,
2-) The defendant spouse to pay the plaintiff … TL pecuniary compensation and … TL non-pecuniary compensation due to his/her fault,
3-) To give the custody of the joint children to the client mother as a precautionary measure while the case is pending and definitively at the end of the case,
4-) To pay alimony to the joint children in the amount of ……….. TL per month as a precautionary measure during the pendency of the case and at the end of the case to continue as subsidiary alimony,
5-) We respectfully request and demand that the defendant be ordered to pay the trial expenses and attorney fees.
Plaintiff Attorney
Attorney Name Surname