Petition For Paternity Case
ANTALYA ON DUTY ( ) FAMILY COURT
THE PLAINTIFF :A….. B…. (T.C.:………..)
ADDRESS
AGENT :Lawyer …………………..
ADDRESS
DEFENDANT :D….. E…. (T.C.:………..)
ADDRESS
SUBJECT OF THE CASE :
Paternity lawsuit (determination of paternity) and alimony claims.
OUR EXPLANATIONS
The client’s mother C…. B…. and the defendant D…. E…., …. They met through their mutual friends and started to live together. This relationship is also known by their close circle. When it was understood that the client’s mother C… B…. was pregnant from this extramarital union, the parties decided to get married, but they could not continue their relationship as a result of the disagreements between them in this process leading to marriage. Witness statements regarding this process are important and the list of witnesses is attached to this petition. (Annex-1)
../../…. On the date …. Hospital (hospital records are attached as Annex 2), the plaintiff client was born. Article 282 of the Turkish Civil Code states that “The paternity bond between the child and the mother is established by birth.” Pursuant to this Article, a paternity bond was established between the client and his mother and the client was registered in the household of his mother C… B… (Annex-3)
The paternity between the client and the defendant has not yet been established, and in accordance with Article 301 of the TMK, “The mother and the child may request the court to determine the paternity between the child and the father.” According to the same article, the paternity case is notified to the Public Prosecutor and the Treasury; We demand that the paternity of the defendant be ruled first and that a paternity bond between the client and the defendant be established.
With the custody of the minor client remaining with his mother. It is decided to establish a personal relationship between the minor client and the defendant D… E…, and a monthly ……. TL per month for the expenses of the client.
LEGAL GROUNDS :
CPC, TMK, Av. Law. and other relevant legislation
EVIDENCE :
Hospital records, civil registry records, witnesses, experts, oaths and other evidence.
We reserve our right to present evidence against the evidence presented / to be presented by the other party.
CONCLUSION AND DEMAND :
For the reasons explained above and to be taken into consideration ex officio by your Honourable Court
1-Acceptance of our lawsuit and all our demands,
2- Ruling on the paternity of the defendant and establishing paternity between the client and the defendant,
3- To establish a personal relationship between the defendant D… E… and the minor client, with the custody of the minor client remaining with his mother,
4-Monthly ……. for the client’s expenses TL per month for the expenses of the client,
5- We request by proxy that all kinds of trial expenses and attorney fees be decided to be charged to the other party.10.02.2022
Plaintiff’s Counsel
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