Establishment Of Paternity And Request For Provision Alimony
…… TO THE JUDGE OF THE FAMILY COURT;
THE PLAINTIFF :
TC ID NUMBER :
ADDRESS :
PROXY :
(legal representatives of the parties, if any)
DEFENDANT :
ADDRESS :
SUBJECT : Our request for determination of paternity and injunction alimony
is related.
EXPLANATIONS :
1-) Our client and the defendant were married for 3 years. A marriage ceremony was held between the parties, but no official marriage ceremony was held. While this was the case, 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 by the defendant. (Annex 1)
2-)Our client gave birth to a child named ……………. on …/…/……. (Annex 2) When our client told her future husband that she was expecting a baby, the defendant left our client, saying that she was lying to force her to get married and that the child was not his. However, the DNA test to be conducted by the Honorable Court will be able to prove that the joint child is from the defendant’s side. In this case, with the determination of the paternity of the child, …………. TL precautionary measures during the lawsuit and …………. TL maintenance during the period of the lawsuit and after the finalization of the decision, it has become necessary to file this lawsuit for the payment of the child support from the defendant to our client.
LEGAL GROUNDS : 4721 S. Code Art. 301, 302, 303, 304, 337.
LEGAL EVIDENCES :
1-) Pregnancy test results of our client.
2-) The doctor’s report dated …/…/… dated …/…/… from the Chief Physician of…Hospital.
3-) Witnesses, engagement and trip photos, all kinds of examination and health reports, all kinds of evidence.
CONCLUSION AND REQUEST : For the reasons explained above, we request that it be determined that the defendant is the father of the joint child………………, that the monthly …………… TL cautionary alimony be taken from the defendant and given to the plaintiff to be converted into participation alimony after the decision is finalized, that the trial expenses be charged to the other party, and that the opposing party’s attorney fee be awarded on our behalf as a lawyer in accordance with the 164/last paragraph of the Attorneyship Law No. 1136 amended by Law No. 4667.
ANNEXES :
1-) Pregnancy test results of our client.
2-) Doctor’s report dated …/…/…/… from …/…Hospital Chief Physician’s Office.
3-) Witness list showing the names and addresses of the witnesses and the subjects they will testify.
4-) One approved power of attorney sample.
Plaintiff Representative
ATT.
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