29 May Paternity Case
… TO THE FAMILY COURT JUDGE
PLAINTIFF :
ADDRESS :
Acting :
DEFENDANT :
Address :
Subject: it consists of the determination of paternity and our claim for compensation.
INSTRUCTIONS
1 -) our client and the defendant , …/…/… – …/…/… between dates …….. he actually lived together at the address and this union was planned to take place in the future because of the marriage ….. the year was continued. As a result of the sexual relationship between my client and the defendant during the said Union, my client became pregnant, and as a result of this incident, he repeatedly told the defendant that he wanted to marry formally, but the marriage that was promised by the defendant did not take place. While the defendant was not officially married to my pregnant client, he also began to have an affair with another woman while they were in actual union. My client did not leave the house, despite learning of the Union in question, and struggled to persuade the defendant to marry even under these circumstances. But as the defendant did not agree to marry …./…../….. he has left home in his history.
2 -) Our client continued his life under very difficult circumstances after the defendant left the House. Because she was pregnant, she was unable to work, and because she had no other income, she had real difficulties in maintaining her life. During the course of her pregnancy, she tried repeatedly to reach the defendant, but the defendant responded negatively to all interview requests. Our client was alone during the pregnancy, as well as alone during the birth and covered the costs of birth and hospital costs (Annex-1) in very difficult circumstances. In fact, the relevant persons whose names are included in the witness list (annex -2) presented in the annex to our petition will also give an explanation of the situation if deemed appropriate by the court.
3 -) small ……… …/…/… born in history. (Appendix -3) The defendant did not seek our client and the child in any way after the birth, nor did he make any effort, even at least to fulfill his financial obligations.
4 -) The defendant knows from the beginning that they will have a joint child with the client. And even photos of the defendant while the client was pregnant are available. (Appendix -4) also the defendant’s minor …..it can also be determined by the research and examination that he is the father.
5-) for all these reasons, the court is small ……’the determination of the defendant and of his father ….. TL birth of the expense …….. TL subsistence expense, ……….. TL has been obliged to demand the collection of the expenses required by pregnancy and childbirth from the defendant.
Legal reasons: 4721 S. K. m. 301, 302, 303, 304
Legal evidence: Hospital Birth Records, population records, DNA testing, photographs, witness statements
RESULT AND PROMPT
For the reasons described above, the defendant is a minor ……..’s identification as the father, ….. TL birth expense, ……. TL six weeks of subsistence expenses before and after birth ……. The total cost of pregnancy and childbirth is … TL.I respectfully request on behalf of our client that the decision be taken to remove the defendant, the costs of the trial and the power of Attorney be charged to the other party. …/…/…
Attachments: 1 -) … / … / … dated …..hospital receipts
2 -) names and addresses of witnesses and issues to testify
shows witness list
3 -) … / … / … dated …..Hospital birth records
4 -) 4 photos taken with the defendant while the client is pregnant
5 -) One certified power of attorney sample
Acting Plaintiff
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