… FAMILY COURT JUDGE
PLAINTIFF: TC
ADDRESS:
ATTORNEY:
DEFENDANT:
ADDRESS:
SUBJECT: Our request for the recognition of paternity of a child born during the marriage.
INSTRUCTIONS
1-) Our client and the defendant lived together at the address …………… from …/…/… to …/…/…
and this cohabitation has continued for … years due to a planned future marriage.
2-) During this cohabitation, the defendant became pregnant as a result of sexual intercourse between our client and the defendant. Following this incident, our client formally expressed his desire to marry the defendant on several occasions, but the defendant did not object to the marriage.
3-) Throughout the ongoing pregnancy, our client attempted to contact the defendant on numerous occasions, but the defendant responded negatively to all requests for a meeting. In fact, our client offered to cover the costs of childbirth and hospital expenses, but there was no way to reach the defendant. In October, the relevant parties listed in the witness list attached to our petition (Appendix -1) will also provide information regarding this matter, should your court deem it appropriate.
4-) The minor child was born on …/…/… (Exhibit 2). The defendant did not contact our client in any way after the birth and did not even give our client the opportunity to fulfill his financial obligations.
5-) Our client is the child’s father. This fact will be definitively established through the investigations and examinations to be conducted by your court and even through a DNA test.
6-) For all these reasons, our client has been compelled to file this lawsuit to be recognized as the child’s father.
LEGAL GROUNDS:
Turkish Civil Code Art. 295, 296, 299; Turkish Family Code Art. 28
LEGAL EVIDENCE: Hospital birth record, population registry records, DNA test,
witness statements
CONCLUSION AND REQUEST: For the reasons explained above, we respectfully request that our client be recognized as the father of the minor, and that the court costs and attorney’s fees be imposed on the opposing party in our client’s favor. …/…/…
ECLAIR:
1-) The names and addresses of the witnesses, along with the matters they will testify regarding,
are listed below.
2-) Hospital birth records dated …/…/…
3-) A certified copy of the power of attorney
Plaintiff’s Counsel