… TO THE FAMILY COURT JUDGE
Plaintiff: TR
ADDRESS :
ATTORNEY:
DEFENDANT:
ADDRESS :
SUBJECT : It consists of our request to recognize the paternity of the child born in wedlock.
DESCRIPTIONS
1-) Our client and the defendant were actually at the address …..… between …/…/… – …/…/…
lived together and this union continued for ….. years due to the marriage planned to take place in the future.
2-) As a result of the sexual intercourse between our client and the defendant during the said union, the defendant became pregnant and as a result of this event, our client repeatedly told the defendant that he wanted to get married officially, but the defendant did not approach the marriage.
3-) Our client tried many times to reach the defendant during the pregnancy, but the defendant gave a negative response to all requests for meeting. Our client even wanted to cover the birth and hospital expenses, but he could not reach the defendant. Related to this situation, those whose names are included in the witness list (Annex-1) attached to our petition will also give an explanation about the situation, if deemed appropriate by your court.
4-) Küçük was born on …/…/…. (Annex -2) The defendant did not call our client in any way after the birth and even did not give our client an opportunity to fulfill his financial obligations at least.
5-) The father of the minor is our client. This situation will be revealed with the researches and examinations to be carried out by your Court and even the DNA test to be made.
6-) For all these reasons, an obligation to file a lawsuit has arisen for our client to be recognized as the father of the minor.
LEGAL REASONS: 4721 S. K. m. 295, 296, 299, 5490 S. K. m. 28
LEGAL EVIDENCE: Hospital Birth registration, population records, DNA Test,
witness statements
CONCLUSION AND REQUEST: For the reasons explained above, we respectfully request that our client be recognized as the father of the minor, and that the litigation expenses and attorney’s fees be charged to the other party, on behalf of our client. …/…/…
ATTACHMENTS:
1-) The names and addresses of the witnesses and the subjects they will testify
shows witness list
2-) …..Hospital birth records dated …/…/…
3-) One copy of approved power of attorney
Plaintiff’s Attorney
Hunting.