Fill and Sign the Minnesota Complaint 497312386 Form

STATE OF MINNESOTA DISTRICT COURT COUNTY OF             JUDICIAL DISTRICT FAMILY COURT DIVISION In Re the Matter of: Court File No.             , Plaintiff, COMPLAINT (parentage alleged AND By mother)       , Defendant , * * * * * * * * * * * * * * * * * * Plaintiff, being first duly sworn, alleges for her cause of action: I. The true and correct names, addresses, and social security numbers of Plaintiff and Defendant are: Plaintiff: __________________________ __________________________ __________________________ SSN: ____________________ Defendant: __________________________ __________________________ __________________________ SSN: ____________________ II. Plaintiff is being represented in these proceedings by _____________________________ , of Firm , Address 1 , City , State Zip . III. Plaintiff's date of birth is ____________________ , 20 ____ , and she is ____________________ ( ____ ) years of age. Defendant's date of birth is ____________________ , 20 ____ , and he is ____________________ ( ____ ) years of age. IV. Plaintiff (and the minor child) reside(s) in the County of ____________________ , State of Minnesota and Defendant resides in the County of ____________________ , State of Minnesota. - 1 - V. On or about the ______ day of ____________________ , 20 ____ , in the City of ____________________ , County of ______________ , and State of ____________________ , Plaintiff, ____________________ , and Defendant, ____________________ , had sexual intercourse. VI. Plaintiff, ____________________ , on the ____ day of ____________________ , 20 ____ , in the County of ____________________ , State of Minnesota, gave birth (out of wedlock) to a (male)(female) child, which child has been named ____________________ . VII. Defendant, ____________________ , is the father of said child. VIII. A (declaration)(recognition) of parentage, pursuant to Minn. Stat. '(257.34)(257.75) has (not) been signed by (Plaintiff) (Defendant) (the parties). (Defendant's name appears on the child's birth certificate.) (Plaintiff is a) (The parties are) fit and proper custodian(s) for said minor child, and the best interests of the child will be served if (Plaintiff is)(the parties are) awarded (sole)(joint) legal and (Plaintiff is awarded sole) physical custody. IX. Defendant has the ability to contribute to the support of said minor child. X. Plaintiff incurred hospital and medical expenses as a result of her pregnancy and the birth of said minor child. XI. Plaintiff is employed as a ____________________ by ____________________ , located at ____________________ . She has gross income of $ ____________________ per ____________________ and net income of $ ____________________ per ____________________ . Defendant is employed as a ____________________ by ____________________ , located at ____________________ . He has gross income of $ ____________________ per ____________________ and net income of $ ____________________ per ____________________ . Plaintiff is dependent upon Defendant for a contribution to her medical and confinement expenses and to the support of the minor child(ren) of the parties. Neither party receives public assistance. WHEREFORE, Plaintiff prays for the Judgment and Decree of this Court as follows: ADJUDICATION 1. Adjudicating Defendant, ____________________ , to be the father of the minor child, ____________________ , born ____________________ currently age ____________________ ( ____ ). CUSTODY/VISITATION 1. Granting ____________________ legal and physical custody of said minor child subject to _____________ 's right to (reasonable)(supervised)(reasonable and liberal) visitation. - 2 - 2 2. Granting Plaintiff and Defendant joint legal custody of said minor child and designating ____________________ as (his)(her) sole physical custodian subject to ____________________ 's right to (reasonable) (supervised) (reasonable and liberal) visitation. 3. Granting Plaintiff and Defendant joint legal and physical custody of said minor child. 4. Ordering such custody, care and control of said minor child as the Court deems in (his)(her) best interest. CHILD SUPPORT 1. Ordering such support for said minor child as the Court deems just, fair and equitable. 2. Ordering ____________________ to pay to ____________________ a reasonable sum of money for the support of said minor child. 3. Reserving the issue of support for said minor child. 4. Requiring Defendant to pay a reasonable sum of money to ____________________ for the confinement expenses of Plaintiff and said minor child. 5. Requiring Defendant to pay a reasonable proportion of the expenses for the support of said minor child for the past two years. INCOME WITHHOLDING 1. Requiring that the child support payment by ____________________ to ____________________ be made by income withholding pursuant to Minn. Stat. §518.613. INSURANCE 1. Requiring that ( ____________________ )(both parties) provide medical (and dental) insurance for the benefit of said minor child in a just and equitable manner. NAME CHANGE 1. Ordering that the minor child's name be changed from ____________________ to ____________________ . SUCH OTHER 1. For such other and further relief as the Court deems just, fair and equitable in the - 3 - 3 premises. Dated: ____________________ Firm By _________________________ _________________________ Printed Name _________________________ _________________________ _________________________ Address _________________________ Telephone Attorney for ______________ - 4 - 4 VERIFICATION STATE OF MINNESOTA ) ) SS. COUNTY OF ______________ ) ________________________ , being first duly sworn, upon oath deposes and says that she is the Plaintiff in the above-entitled action; that she has read the foregoing Complaint, knows the contents thereof and that the same is true and correct, except as to those matters therein stated on information and belief and as to those matters she believes them to be true. ______________________________ Name of Client Plaintiff Dated: _______________________ Plaintiff Subscribed and sworn to before me this _____ day of ____________ , 20 ___ . _______________________________ NOTARY PUBLIC - 5 - 5 ACKNOWLEDGMENT STATE OF MINNESOTA ) ) SS. COUNTY OF ______________ ) ____________________________ , the attorney for Plaintiff in the above-captioned matter, and ____________________________ , Plaintiff herein, hereby acknowledge that pursuant to Minn. Stat. §549.21, costs, disbursements, witness fees and reasonable attorneys' fees may be awarded to Defendant in the event Plaintiff is found to be acting in bad faith and/or asserting a frivolous claim. ______________________________ _____________________________ Name of Client Plaintiff Subscribed and sworn to before me this _____ day of ______________ , 20 ___ . _____________________________ Notary Public _____________________________ Attorney for Plaintiff Subscribed and sworn to before me this _____ day of ______________ , 20 ___ . _____________________________ Notary Public - 6 - 6