IN THE CHANCERY COURT OF COUNTY, MISSISSIPPI
, PLAINTIFF(S)
vs. NO.
, DEFENDANT(S)
COMPLAINT FOR ORDER OF FILIATION
COMES NOW, Plaintiff, , and files this her Complaint for Order of Filiation, and
would show unto the court the following facts, to-wit.
1.
is a bona fide adult resident citizen of County, Mississippi who resides at
, , Mississippi.
2.
is a bona fide adult resident citizen of County, Mississippi who may be
served with process of this court at , , Mississippi .
3.
That counsel for , Honorable , shall be served with a copy of this Complaint
by sending a copy of the same to him/her by certified mail, return receipt requested, at ,
, Mississippi or by delivering a copy of the Complaint to at his/her usual
business address.
4.
That , Attorney General, State of Mississippi, shall be served with a copy of
this Complaint by sending a copy of the same to him/her at his/her office in the , ,
, Mississippi.
5.
On or about , , the Plaintiff gave birth to a male/female child, , of
whom the Defendant is the paternal parent.
6.
At the time of the birth of the minor child, the Plaintiff was married but separated from
from whom she is now divorced. is a necessary party to this action and shall be
noticed accordingly, at his current address of , , Mississippi .
7.
That in conforinity with the Uniform Child Custody Jurisdiction Act, Miss. Code Ann.
Section 93 - 23 - 17 (Supp. 1994), Plaintiff avers the following:
a) The minor child presently resides with the mother.
b) That the minor child has lived with the natural mother from the date of birth until
present.
c) That the Plaintiff and Defendant have not participated in any manner in any other
litigation concerning the custody of said child named herein in this of any other matter.
d) That the Plaintiff has no other information of any custody proceeding concerning
the child named herein pending in a court of this or any other state, and
e) That Plaintiff knows of no other person not a party to this proceeding who has
physical custody of the child named herein, or claims to have custody or visitation rights with
regard to the child named herein.
8.
Plaintiff alleges that the mother is a fit and proper person for the custody of the minor
child and that the child's best interest would be served by granting Plaintiff custody subject only
to supervised visitation rights of the Defendant.
WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that upon a final hearing in
this matter, the court will award her the following permanent relief:
1. That this court enter a judgment of filiation that the Defendant is the father of the
child.
2. That the child shall inherit from the Defendant as could the natural children of the
father under the statutes of decent and distribution in this state.
3. A reasonable amount from the Defendant as child support for support and
maintenance of the minor child for the remainder of the child's minority.
4. That the Defendant be ordered to pay back child support for the space of
year(s) prior to the filing of this Complaint.
5. That the Defendant be ordered to provide health insurance and pay ( )
of any and all medical expenses not covered under said insurance for the minor child.
6. That the Defendant be ordered to pay ( ) of any and all college
expenses of the minor child.
7. That the Plaintiff be granted physical and legal custody of the minor child,
subject to supervised visitation rights of the Defendant.
8. That the Defendant be required to pay a reasonable sum unto the Plaintiff which
shall be used to compensate his/her attorney for services in connection with this civil action.
9. That of the State of Mississippi alter the certificate of birth of the minor
child to reflect the Defendant as the natural father.
Plaintiff further prays for any such other relief, either general or specific, to which he
may be entitled.
Respectfully submitted,
_______________________________________
Attorney for
Of Counsel:
Telephone:
MSB #
Attorney for
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