TO THE FAMILY COURT
PLAINTIFF:
ADDRESS:
ATTORNEY:
DEFENDANT:
ADDRESS:
SUBJECT: Determination of Paternity and Our Claim for Compensation.
EXPLANATIONS
1-) Our client and the defendant, registered on …/…/… – …/…/…, actually lived together in …..… locations, and this cohabitation lasted for ….. years due to plans for a future marriage. During this cohabitation, my client became pregnant as a result of sexual relations between my client and the defendant.
Consequently, my client wanted to officially marry the defendant, but the defendant never went through with the expected marriage. Although the defendant did not officially marry my pregnant client, he began a relationship with another woman while the de facto cohabitation continued. Despite learning about this relationship, my client did not leave the home and tried to convince the defendant to marry her even under these circumstances. However, the defendant not only refused to marry her but also left the home on …./…../…..
2-) After the defendant left home, our client endured very difficult conditions. She was unable to work due to her pregnancy and, having no other income, faced significant hardship throughout this period. During her pregnancy, she attempted to contact the defendant to make amends, but the defendant responded negatively to all requests for communication. Our client was alone during her pregnancy and gave birth alone, and she had great difficulty covering the delivery and hospital expenses (ATTACHMENT-1). In fact, if deemed appropriate by your court, the relevant explanations should be provided by the persons listed in the witness list (ATTACHMENT-2) submitted with our petition.
3-)
The minor ……… was born on …/…/… (Appendix -3). After the birth, the defendant did not contact our client or the child in any way and did not even make any effort to fulfill his minimum financial obligations.
4-) The defendant has been aware of the client’s pregnancy from the outset. There are even photographs taken with the defendant while the client was pregnant. (ATTACHMENT -4) Furthermore, it can be determined through research and investigation that the defendant is the father of the minor ……
5-) The entire purchase transaction resulted in the. Determination that the defendant is the father of the minor…… And the request for the defendant to pay …… TL for birth expenses, …….. T L for transition expenses, and ……….. TL for fertility and birth expenses.
LEGAL GROUNDS: 4721 SK m. 301, 302, 303, 304
LEGAL EVIDENCE: Hospital birth record, population records, DNA test, photographs, witness statements
CONCLUSION AND REQUEST
I request that the defendant be identified as the father of the minor…….. That a total of … TL be collected from the defendant for the birth expenses, ……. T L for the transition expenses for the six weeks before and after the birth, and ……. TL for other expenses related to the birth, for a total of … TL, and that the compensation and attorney’s fees. Be agreed upon in the contract at regular intervals. I request compensation on behalf of our client. …/…/…
ATTACHMENTS: 1-) Receipts from …..hospital dated …/…/…
2-) Names and addresses of witnesses and the subjects they will testify about
Showing the list
3-) …..Hospital birth record dated …/…/…
4-) Four photographs taken by the defendant while the client was pregnant
5-) One copy of a continuing power of attorney
Plaintiff’s Attorney