Petition for Denial of Paternity and Cancellation of Population Registry Record

TO THE DUTY FAMILY COURT
OF ISTANBUL

PLAINTIFF: Name and Surname (Turkish Republic Identity Number) – Address
REPRESENTATIVE: Lawyer's Name and Surname – Address
DEFENDANTS: 1- Mother, Name and Surname (Turkish Republic Identity Number) – Address
2- Minor, Name and Surname (Turkish Republic Identity Number) – Address
SUBJECT: Our request for the denial of paternity.

EXPLANATIONS:

1. The plaintiff's client and the defendant were married on …/…/… and two innocent children, … and …, were born from this marriage. However, my client harbored serious suspicions that her spouse was constantly cheating on her. These suspicions were solidified when it was revealed that their daughter, … years old, was not my client's biological child. My client learned this fact approximately 20 days ago through her spouse's painful verbal confessions and a report provided to her by third parties. The report was prepared by Istanbul Genetic Group Health Services Ltd. Co., dated …/…/…, and confirms my client's suspicions. (Appendix - Copy of the report on the parentage of … and … prepared by Istanbul Genetic Group Health Services Ltd. Co., dated …/…/…).
2. For my client, maintaining paternal ties with her children has become an unthinkable idea due to the psychological breakdown she is currently experiencing.
3. The genetic report obtained and the defendant's explicit statements definitively establish that the client is not the biological father of the minor. During this process, a request has been made to appoint a guardian to represent the minor, and the guardian will be included in the case. Since the client is not the biological father of the minor, it has become necessary to file a lawsuit requesting the denial of paternity.

EVIDENCE:

• Population Family Registration Table
• Witness testimony
• A copy of the report regarding the parental relationship of … and …, dated …/…/…, prepared by … Genetic Group Health Services Ltd
• Identity register copy
• Other evidence

LEGAL GROUNDS: Turkish Civil Code Article 286/1 and related legislation.

CONCLUSION AND REQUEST: For the reasons briefly explained above, I respectfully request and demand that the court accept the case, reject the paternity of the minor …, cancel the population registry record in the plaintiff's name, and order the opposing party to pay the court costs and attorney's fees. …/…/…

Plaintiff's
attorney's name and surname,
signature