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Draft, on behalf of the respondent wife, a notice of motion, along with an affidavit in support thereof, in and for custody of a minor girl.
IN THE FAMILY COURT AT TIRUPATI
NOTICE OF MOTION NO. 80 OF 2010
MATRIMONIAL PETITION NO: 101 OF 2010
Sushmitha …… Petitioner
Goutham …… Respondent.
I sushmitha of Tirupati, Hindu Indian inhabitant residing at T.K. Street, 4th Road, Tirupati do hereby solemnly affirm and say as follows.
(1) I say that I was married to the respondent on 01.04.2004 at Tirupati according to traditional Hindu rites until 2010. I had cohabited with the respondent at Tirupati and had a son Rahul by the said marriage. The said Rahul is now 5 years of age.
(2) I say that until November 2010, our matrimonial life was quite happy and harmonions. Thereafter, the respondent took to heavy drinking and began to show disgust, contempt and neglect towards me and towards the said Rahul.
(3) I say that the respondent has physically assaulted me on several occasions and is guilty of gross cruelty as more particularly stated in my petition. I further say that the respondent is also guilty of desecrating me as stated more fully in the said petition. I say that I have therefore prayed for a dissolution of the said marriage in the said petition.
(4) I say that I am a housewife with no independent source of income. I further say, that the respondent is the Branch Manager of Indian Bank and is drawing a monthly salary of 4000/-
(5) I say that I am clearly attached to the said Rahul and fear physical, assaults on him by the said respondent if his custody.
(6) I therefore, submit that this notice of motion be made absolute with costs.
Solemnly Affirmed at Tirupati. Sushmitha
This 2nd December, 2010 Before me
Advocates for the petitioner City, Civil CourtTirupati