Paternity Litigation
… FAMILY COURT JUDGE
PLAINTIFF :
ADDRESS :
PROXY :
DEFENDANT :
ADDRESS :
SUBJECT : It consists of our Request for Judicial Determination of Paternity and Compensation.
EXPLANATIONS
1-) Our client and the defendant actually lived together at …….. between …/…/… – …/…/… dates and this union continued for ….. years due to the marriage planned to take place in the future. As a result of the sexual intercourse between my client and the defendant during the said union, my client became pregnant and as a result of this incident, she told the defendant many times that she wanted to get married officially, but the marriage promised by the defendant could not be realized. The defendant did not officially marry my client, who became pregnant, and at the same time started to have a relationship with another woman while the actual union was continuing. Although my client found out about this relationship, she did not leave the house and tried to convince the defendant to get married even under these circumstances. However, the defendant did not accept the marriage and left the house on …./…../……
2-) Our client continued her life under very difficult conditions after the defendant left the house. Since she was pregnant, she could not work, and since she had no other income, she had great difficulties in sustaining her life in real terms. She repeatedly tried to reach the defendant during her pregnancy, but the defendant responded negatively to all her requests for a meeting. Not only was our client alone during her pregnancy, but she was also alone during the birth and had to pay for the delivery and hospital expenses (Annex 1) under very difficult conditions. In fact, the relevant persons whose names are included in the witness list (ANNEX -2) attached to our petition regarding this situation will also provide explanations regarding the situation if deemed appropriate by your court.
3-) The little ……… was born on …/…/…/… (Annex -3) After the birth, the defendant did not call our client and the child in any way and did not even make any effort to fulfill at least his financial obligations.
4-) The defendant knew from the beginning that he and the client would have a child together. And there are even photographs taken with the defendant while the client was pregnant. (Annex -4) In addition, it will be possible to determine that the defendant is the father of little ….. through research and investigations.
5-) For all these reasons, I request your Court to determine that the defendant is the father of …… and to award ….. TL birth expenses, …….. TL living expenses, ……….. TL for the expenses required by pregnancy and childbirth from the defendant.
LEGAL GROUNDS : 4721 S. Code Art. 301, 302, 303, 304
LEGAL EVIDENCE : Hospital Birth record, population records, DNA Test, photographs, witness statements
CONCLUSION AND REQUEST
For the reasons explained above, the defendant is determined as the father of the minor …….., ….. TL birth expenses, ……. TL living expenses for six weeks before and after the birth and ……. TL, and other expenses required by pregnancy and childbirth, and I respectfully request on behalf of our client that the defendant be ordered to be charged the costs of the proceedings and the attorney’s fee to the other party. …/…/…
ATTACHMENTS 1-) …/…/…/… dated …..hospital receipts
2-) Witness list showing the names and addresses of the witnesses and the subjects they will testify
3-)…/…/…/… dated …..Hospital birth records
4-) 4 photographs taken with the defendant while the client was pregnant
5-) One approved power of attorney sample
Plaintiff’s Attorney