… FAMILY COURT JUDGE
PLAINTIFF : TC
ADDRESS :
ATTORNEY :
DEFENDANT :
ADDRESS :
SUBJECT : It consists in our request to recognize paternity in relation to a child born in marriage.
INSTRUCTIONS
1-) Our client and the defendant , …/…/… – …/…/… dec…………… at the actual address
i have lived together and this union is due to the marriage that is planned to take place in the future ….. the year has been continued.
2-) As a result of the sexual union between our client and the defendant during the said association, the defendant became pregnant and as a result of this incident, our client told the defendant that he wanted to get married officially several times, but the defendant party did not decry the marriage.
3-) Our client has repeatedly tried to reach the defendant during the ongoing pregnancy process, but the defendant has responded negatively to all interview requests. In fact, our client even wanted to cover the maternity and hospital costs, but there was no way to reach the defendant. In October to this situation, the interested parties whose names are included in the witness list (Annex -1) presented in the annex to our petition will also give october on the situation if deemed appropriate by your court.
4-) The little one was born on …/…/… history. (ANNEX -2) The defendant did not call our client in any way after the birth and did not even give our client the opportunity to fulfill at least his financial obligations.
5-) The father of the minor is our client. This situation will be definitely revealed by the research and examinations to be carried out by your court, and even by the DNA test to be performed.
6-) For all these reasons, our client was obliged to file a lawsuit in order to be recognized as the father of the minor.
LEGAL REASONS : 4721 P. K. m. 295, 296, 299, 5490 P. K. m. 28
LEGAL EVIDENCE : Hospital Birth record, population records, DNA Test,
witness statements
CONCLUSION AND REQUEST : For the reasons described above, we respectfully request that our client be recognized as the father of the minor, that the expenses of the trial and the attorney’s fee be charged to the opposite party on behalf of our client. …/…/…
ECLAIR:
1-) The names and addresses of the witnesses and the subjects they will testify to
the following is a list of witnesses
2-) …/…/… dated……Hospital birth records
3-) An example of an approved power of attorney
Acting Plaintiff
