TO THE FAMILY COURT
PLAINTIFF: … (claiming that he is not the father)
TR ID ID NUMBER:
ATTORNEYS:
ADDRESS:
DEFENDANT: … (mother who gave birth)
… (child) trustee
ADDRESS:
SUBJECT: Denial of lineage.
EVIDENCE: 1. Population records, 2. Birth certificates, 3. Witnesses, 4. Doctor’s report, 5. Forensic medical examination and all other legal evidence.
LEGAL REASON: TMY 285 and relevant legislation
EXPLANATIONS:
Our plaintiff client married the defendant B… on …….
However, in the month of the marriage of the parties, defendant B… gave birth to defendant C…. Our client did not have a relationship with the defendant B… before their marriage.
The newborn child was born on ……day. Therefore, it is not possible for the father of the defendant child to be our client. For this reason, the necessity of filing this lawsuit has arisen.
For this reason, it must be determined that our client is not the father of the defendant child.
CONCLUSION AND REQUEST: Since it will be understood that the father of the minor defendant C… is not our client for the reasons explained above, we respectfully and without notice request that the paternity of the defendant C… be REJECTED in accordance with Article 286 of the TMK.
Plaintiff…
Deputy Atty.