… FAMILY COURT JUDICATURE

PLAINTIFF : TC
address :
attorney :
DEFENDANT :
ADDRESS :
SUBJECT : Recognition of paternity in relation to a child born in marriage consists of our desire.

INSTRUCTIONS

1-) Our client and the defendant , …/…/……. actually at the address
they lived together and this union is due to the marriage that is planned to take place in the future ….. it has been maintained for years.
2-) As a result of the sexual union between our client and the defendant during the said union, the defendant became pregnant and as a result of this incident, our client repeatedly told the defendant that he wanted to marry officially, but the defendant party did not dec to the marriage.
3-) Our client has repeatedly tried to reach the defendant during the pregnancy process, but the defendant has responded negatively to all interview requests. In fact, our client even wanted to cover maternity and hospital expenses, but there was no way to reach the defendant. October 1, October 19, 2019 – The relevant persons whose names are included in the witness list (APPENDIX -1) presented in the annex to our petition regarding this situation will also give explanations about the situation if deemed appropriate by your court.
4-) The little one was born on …/…/… date. (OCTOBER -2) The defendant did not call our client in any way after the birth and did not even give our client the opportunity to at least fulfill his financial obligations.
5-) The father of the minor is our client. This situation will be revealed definitively with the research and examinations to be carried out by your Court and even with the DNA test to be done.
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 Pp. K. m. 28
LEGAL EVIDENCE : Hospital Birth registration, population records, DNA Testing,
witness statements
CONCLUSION AND REQUEST: For the reasons described above, we respectfully request on behalf of our client that it be decided that our client will be recognized as the father of the minor and that the trial expenses and the attorney’s fee be charged to the opposite party. …/…/…

ANNEXES:

1-) The names and addresses of the witnesses and the subjects they will testify to
shows witness list
2-) …/…/… dated …..Hospital birth records
3-) An example of a certified power of attorney

Plaintiff’s Attorney

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