Petition For Establishment Of Paternity And Alimony
…. TO THE HONORABLE JUDGE
THE PLAINTIFF :…….
DEFENDANT :…….
ATTORNEY:…….
SUBJECT : Establishment of Paternity and Alimony
EXPLANATIONS : 1-Our client was engaged to the defendant for 2 years and then separated. During this engagement period, they went on vacation together many times and were together. There are photos of our client taken at the hotels and beaches where they stayed together. We will present these to the court as evidence.
2- Our client, who stepped into a very sacred union such as marriage in the presence of everyone, trusted his future wife and did not hesitate to enter into such a relationship.
3-When our client told her future husband that she was expecting a baby, the defendant abandoned her, saying that she had lied to force him to marry her and that the child was not his. Our client was hurt and could not leave the house for days. Despite everything, our client gave birth to her child. She gave birth to a baby girl.
4-The child belongs to the defendant. It is impossible for our client to have a relationship with someone else due to her upbringing and family structure.
5-The child has not yet been born for 1 year. On behalf of the mother, it is necessary to file this lawsuit against the defendant who has not accepted the child within the legal period and to obtain a decision from your court to correct the child’s genealogy and to request alimony for the child in need of care.
LEGAL GROUNDS Article 249 et seq.
EVIDENCE : Witnesses, engagement and travel photos, all kinds of examinations and medical reports, all kinds of evidence.
RESULT OF THE PETITION : For the reasons explained, we request that it be decided that the father of our client’s daughter is the defendant ……., that the child be registered in the birth registry of the father, that the defendant pay a monthly alimony of …….Tl for the child during the continuation of the case, that the costs of the proceedings 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.
ATTORNEY FOR THE PLAINTIFF
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