Recognition Of Paternity Of A Child Born Within The Marriage Union
… FAMILY COURT JUDGE
THE PLAINTIFF : TC
ADDRESS :
ATTORNEY :
DEFENDANT :
ADDRESS :
SUBJECT : It consists of our request for recognition of paternity regarding the child born in marriage.
EXPLANATIONS
1-) Between our client and the defendant, …/…/… – …/…/…/… between the dates …/…/…
They 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 aforementioned union, the defendant became pregnant and as a result of this incident, our client told the defendant many times that she wanted to get married officially, but the defendant did not want to get married.
3-) Our client tried many times to reach the defendant during the pregnancy, but the defendant responded negatively to all requests for a meeting. Our client even wanted to cover the birth and hospital expenses, but did not have the opportunity to reach the respondent. Regarding this situation, the relevant persons whose names are included in the witness list (Annex -1) attached to our petition will also give explanations regarding the situation if deemed appropriate by your court.
4-) The minor was born on …/…/…/… (Annex -2) The defendant did not call our client in any way after the birth and did not even give our client the opportunity to fulfill at least his financial obligations.
5-) The father of the minor is our client. This situation will be definitively revealed by the investigations and examinations to be made by your Court and even by a DNA test.
6-) For all these reasons, it has become necessary to file a lawsuit for our client to be recognized as the father of the minor.
LEGAL GROUNDS : 4721 S. K. art. 295, 296, 299, 5490 S. K. art. 28
LEGAL EVIDENCE : Hospital birth record, civil registry, DNA test,
witness statements
CONCLUSION AND REQUEST : For the reasons explained above, we respectfully request on behalf of our client that our client be recognized as the father of the minor and that the costs of the proceedings and attorney’s fees be charged to the other party. …/…/…
ANNEXES:
1-) The names and addresses of the witnesses and the subjects they will testify about
shows witness list
2-) …..Hospital birth records dated …/…/…
3-) One approved power of attorney sample
Counsel for the Plaintiff