TO FAMILY COURT JUDGE;
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS :
SUBJECT : Our request for determination of paternity and precautionary alimony
is related.
DESCRIPTIONS :
1-) Our client and the defendant were married for 3 years. A marriage ceremony was held between the parties, but the official marriage was not held. In the meantime, the parties lived together for … months, and during this time they went on vacation together many times and were together. Subsequently, our client became pregnant from the defendant. (ANNEX 1)
2-) Our client, on …/…/…… ……………. She gave birth to a child named (Appendix 2) When our client told his future wife that he was expecting a baby, the defendant left our client, saying that he lied to force her to marry and that the child was not his. However, with the DNA test to be made by the Honorable Court, it will be possible to prove that the joint child is from the defendant’s side. In this case, with the determination of the paternity of the child, during the lawsuit …………. TL measure, after the decision becomes final …………. It has become necessary to file this lawsuit in order for the TL participation alimony to be collected from the defendant and paid to our client.
LEGAL REASONS: 4721 S. K. m. 301, 302, 303, 304, 337.
LEGAL EVIDENCE:
1-) Pregnancy test results of our client.
2-)… The doctor’s report dated …/../… obtained from the Chief Physician of the…Hospital.
3-) Witnesses, engagement and travel photos, all kinds of examinations and health reports, all kinds of evidence.
CONCLUSION AND REQUEST: For the reasons explained above, it has been determined that the defendant is the father of the joint child………………, monthly ………………… TL temporary alimony is taken from the defendant to the plaintiff and given to the plaintiff, in order to turn into child maintenance after the decision is finalized, We request that the expenses be borne by the other party, and that the attorney’s fee of the other party be decided on our behalf as an Attorney in accordance with the 164/last paragraph of the Law No. 1136, amended by the Law No. 4667.
ATTACHMENTS:
1-) Pregnancy test results of our client.
2-)… The doctor’s report dated …/../… obtained from the Chief Physician of the…Hospital.
3-) A witness list showing the names and addresses of the witnesses and the subjects they will witness.
4-) One copy of approved power of attorney.
Plaintiff’s Attorney
