ANTALYA SENTRY FAMILY COURT
PROSECUTOR/
APPLICANT :A….. B….. (ID NO.:…………….)
ADDRESS
ATTORNEY :Attorney ………..
SUBJECT OF THE LAWSUIT : Recognition of the Genealogical connection Consists in Submitting our Lawsuit Petition.
OUR EXPLANATIONS
Client A….. B….. C… D… …. They met through mutual friends; they began to live together. This union is also known to his close circle. After it became clear that C… Dec was pregnant from this extramarital union, the parties decided to get married, but as a result of disagreements between them during this process leading up to the marriage, they could not continue their relationship. Witness statements related to this process are important and the witness list is presented in October annex to this petition. (October-1)
../../…. In history, …. October 2) Little E…D… was born in his hospital (hospital records are attached October-2). Article 282 of the Decr “The genealogical bond between the child and the parent is established by birth.” According to it, a genealogical bond was established between E…Dec… and his mother, and E…D… his mother was registered in the C… D… Household. (October-3)
Although a marriage union has not been established between the mother and the father, the client wants to be the father of his child and take him into Dec population. The client has no objection to the fact that the minor remains in the custody of Dec mother, but he demands that a personal relationship be established between him and the minor.
Client A.. B.. since he wants to establish a genealogical connection between them and a minor E… D… of his own blood, and Article 295/1 of the TMK, “Recognition occurs with a written application by the father to the population officer or the court, or Dec declaration that he will make in an official deed or will.” In accordance with it, it has been necessary to apply to your court.
LEGAL REASONS : HMK, TMK m.295/1, Av. Blood. And other relevant legislation
EVIDENCE: Hospital records, Photographs, Population records, witness, expert witness, oath and other evidence.
CONCLUSION AND CLAIM : For the reasons described above and which will be considered by your Esteemed Court you’re,
1-ACCEPTANCE of our case and all our requests,
2- The Decider of the plaintiff’s paternity and the establishment of a genealogical bond between them and the minor E… D…,
3- We request by proxy that Dec decision be made to establish a personal relationship between the client and the fact that the custody of the minor E… D… remains with his mother.25.03.2022
Deputy Plaintiff
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