ANTALYA … FAMILY COURT
PLAINTIFF : ……………….. (T.C. …………………….. )
Address
AGENT : Atty…………
Address
DEFENDANTS :
1.
2.
3.
SUBJECT : It is our petition containing our request for the determination of paternity (paternity lawsuit).
EXPLANATIONS :
With this petition, we hereby submit to the court our request for the establishment of paternity between the plaintiff and the defendant in line with the client’s request. Our explanations regarding the dispute in question are as follows.
Before the birth of the client, the client’s mother and the defendant ……………………………………..
…………………………………………………
………………………………………………
The relationship between the …………………………………………….. mother and the defendant has ended. Witness statements regarding this process are important and the witness list will be notified to your honourable court.
As we have explained above, a genealogical bond has been established between the client and his mother in accordance with Article 282 of the Turkish Civil Code …………………………………………… “The genealogical bond between the child and the mother is established by birth.” Client’s mother ………………
…………….
…………………
……………….. has continued his life with victimizations. 1………………………….
There is no family relationship with ………………………………………..
In order to determine that the defendant is the father of our client, we request that a medical examination report be prepared by the Forensic Medicine Institution on the samples taken from the father.
Article 282- Paternity between the child and the mother is established by birth.
Paternity between the child and the father is established by marriage with the mother, recognition or judgement of a judge.
………………………………..
………………………………..
………………………….
Article 301- The mother and the child may request the court to determine the paternity between the child and the father. The lawsuit shall be filed against the father, or if the father is dead, against his heirs. It is governed by this provision. …………………………………………
…………………..
…………………….
…………………… to be added as a party to the case and to be notified to the public prosecutor and the Treasury.
The paternity of the client with his father has not been established until today. In this case, it has become necessary to file this lawsuit for the establishment of paternity.
LEGAL GROUNDS : Turkish Civil Code Articles 282/2, 301, 303 and related legislation.
LEGAL EVIDENCE : Population records, hospital records, witnesses, expert examination, oath, DNA test, medical examination report and all kinds of relevant evidence.
CONCLUSION-DEMAND : For the reasons explained above and to be taken into consideration ex officio by your honourable court;
Firstly, the heirs should be identified and ………………………….
He’s right ……………….
Determination of the client’s ………………… between……………. and……………………..SINA
All kinds of judgement costs and attorney fees shall be charged to the other party,
We request a judgement by proxy.
Plaintiff Representative
Lawyer…..
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