TO FAMILY COURT
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS :
SUBJECT : Our request for determination of paternity and precautionary alimony
is related.
DESCRIPTIONS :
1-) Our client and the defendant met and after a short while they decided to get married. A marriage ceremony was held between the parties, but the official marriage was not held. The parties lived together for … months and during this time our client became pregnant with the defendant. (ANNEX 1)
2-) Our client, on …/…/…… ……………. She gave birth to a child named (Appendix 2) Even after the couple’s children were born, the defendant did not marry, nor did he accept his child. However, with the DNA test to be made by the Honorable Court, it will be possible to prove that the joint child is from the defendant’s side. In this case, with the determination of the paternity of the child, during the lawsuit …………. TL measure, after the decision becomes final …………. It has become necessary to file this lawsuit in order for the TL participation alimony to be collected from the defendant and paid to our client.
LEGAL REASONS: 4721 S. K. m. 301, 302, 303, 304, 337.
LEGAL EVIDENCE:
1-) Pregnancy test results of our client.
2-)… The doctor’s report dated …/../… obtained from the Chief Physician of the…Hospital.
3-) A witness list showing the names and addresses of the witnesses and the subjects they will witness.
CONCLUSION AND REQUEST: For the reasons explained above, it has been determined that the defendant is the father of the joint child………………, monthly ………………… TL temporary alimony is taken from the defendant to the plaintiff and given to the plaintiff, in order to turn into child maintenance after the decision is finalized, We respectfully request that it be decided that the expenses and attorney’s fees be charged to the other party. …/…/…
ATTACHMENTS:
1-) Pregnancy test results of our client.
2-)… The doctor’s report dated …/../… obtained from the Chief Physician of the…Hospital.
3-) A witness list showing the names and addresses of the witnesses and the subjects they will witness.
4-) One copy of approved power of attorney.
Plaintiff’s Attorney
Lawyer
