TO THE DEAR JUDICATURE OF THE FAMILY COURT
…….
PLAINTIFF :…….
ATTORNEY:…….
RESPONDENT :…….
SUBJECT : Determination of Paternity and Alimony
EXPLANATIONS: 1-Our client broke up with the defendant after being engaged for 2 years. During these periods of engagement, they have repeatedly been on vacation together and have been together. There are photos of our client taken at the hotels and beaches where they stayed together. We will present these to the court as evidence.
2-Our client, who stepped into a very sacred relationship such as marriage in the presence of everyone, trusted his future wife and did not hesitate to enter into such a relationship.
3-When our client told his future wife that he was expecting a baby, the defendant left our client, saying that he lied to force him to get married and that the child was not his. Our client was hurt and couldn’t leave the house for days. Despite everything, our client gave birth to her child. He gave birth to a daughter.
4-The child belongs to the defendant. It is impossible for our client to have a relationship with someone else due to the way he was raised and the family structure.
5-The child has not yet been born for 1 year. It was necessary to open this case on behalf of the mother against the defendant who did not accept the child within the legal period and get a decision from your court to correct the cause of the child and ask for alimony for the child in need of care.
LEGAL REASONS: MK(Civil Code) Article 249 et al.
EVIDENCE: Witnesses, photos of engagements and trips, all kinds of examinations and medical reports, all kinds of evidence.
RESULT OF THE REQUEST : For the reasons described, the defendant of the father of our client’s daughter …….. we demand that it be decided that the child be transferred to the father’s nufus register, that the defendant pay monthly alimony for the child during the continuation of the case, that the trial expenses be transferred to the opposite party, that the opposing party’s attorney fee be decided on our behalf in accordance with Paragraph 164/last amended by Law No. 4667 of the Law No. 1136 of the Attorney’s Law No. 164 / last.
PLAINTIFF’S ATTORNEY
