…….HONORABLE JUDGE
…….
PLAINTIFF: …….
CAPACITY: …….
DEFENDANT: …….
SUBJECT: Paternity Determination and Child Support
STATEMENTS:
1-Our client ended her relationship with the defendant after a two-year engagement. During this engagement period, they went on vacation together on numerous occasions and spent time together. There are photographs of our client taken at the hotels and beaches where they stayed together. We will submit these to the court as evidence.
2-When our client took the step toward such a sacred union as marriage in the presence of everyone, she trusted her future spouse and did not hesitate to enter into such a relationship.
3-When our client told her future spouse that she was pregnant, the defendant abandoned her, claiming that she had lied to force him into marriage and that the child was not his. Our client was deeply upset and could not leave the house for days. Despite everything, our client gave birth to a baby girl.
4-The child belongs to the defendant. Due to our client’s upbringing and family structure, it is not possible for her to have a relationship with anyone else.
5-The child was born just one year ago. It was necessary to file this lawsuit on behalf of the mother against the defendant, who did not acknowledge the child within the legal timeframe, to rectify the child’s status and to seek child support for the child in need of care.
LEGAL GROUNDS:
Turkish Civil Code, Article 249, and others.
EVIDENCE: Witness statements, engagement and travel photographs, all medical examinations and reports, and any other evidence.
REQUESTED RELIEF: For the reasons stated above, we request that the court rule in our client’s daughter’s favor, transferring custody of the child to the father, ordering the defendant to pay monthly child support for the child during the pendency of the case, imposing litigation costs on the opposing party, and determining the opposing party’s attorney’s fees in our favor pursuant to Article 164 of the Attorney’s Act No. 1136 (as last amended by Law No. 4667).
ATTORNEY FOR THE PLAINTIFF