IN THE SUPERIOR COURT OF CLAYTON COUNTY

STATE OF GEORGIA

TDE CIVIL ACTION

PETITIONER
FILE NO.: ______________
vs.

J W J,
RESPONDENT

VERIFIED PETITION TO ESTABLISH PATERNITY AND

FOR LEGITIMATION

COMES NOW, Petitioner TDE (hereinafter Petitioner) and files Petition to

Establish Paternity and For Legitimation, and states the following in support of
his petition.
1.
I believe that I am the father of the following minor child, born out of
wedlock: JE, a Female Child, whose Date of Birth is June 28, 2005.

2.
Jurisdiction and venue are proper in this Court because the Respondent
mother resides in Clayton County, Georgia.

3.
The Respondent, JWJ, is the child’s mother; the mother’s address is: XXX
XXX XXXXX Clayton County, Georgia 30349.

4.
The mother was not married to anyone at the time of the child’s conception
or birth, and to Petitioner’s knowledge, the mother has come forward with no other
man’s name as father to the child.

5.
The child lives with the Respondent/Mother and resides at the address listed
in ¶3.

6.
The mother and I did have a romantic sexual relationship before the
mother’s pregnancy, and she named me as father at the hospital where the child
was born, the necessary and requisite requirements are met.

7.
The mother has stated in a Court of law that I am not the natural parent, I am
attempting to acquire a transcript of said hearing.

8.
Because the paternity of the child has not been legally established by a
Court, or by operation of law, I MOVE the Court to Order the mother, the child,
and myself submit to genetic tests as specified in O.C.G.A. §19-7-45, to be
conducted by a laboratory certified by the American Association of Blood Banks,
and/or be performed by a duly qualified licensed practicing physician, duly
qualified immunologist, or other qualified person; and that this court determine the
number and qualifications of the experts.

9.
In the event testing shows that I am the natural parent of the child, I want to

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legitimate my relationship with the child, as provided in O.C.G.A. §19-7-22, so
that the child will have full rights as my child, and I will have full rights as the
father or the child. I believe that legitimation would be in the child’s best interests.

7.
Because the child already has my last name, it will not be necessary to
change the Birth records, or the child’s last name.

8.
There is no current Court Order instructing that I pay child support, although
I voluntarily paid child support until I was informed that I could not have visitation
with my child.

9.
It recently came to my attention that the mother, on July 9, 2009, through an
attorney, filed Civil action No.: 2009csXXXX 06 in Clayton County Superior
Court, assigned to Judge Benefield, cause of action “Child Support”.

10.
The Docket Report for the civil action reflects that the mother knowingly
provided the wrong address, and on 09/07/2009 “unable to serve” was entered.

THEREFORE, the Petitioner asks:

That process issue and the Respondent be served with a copy of this Petition

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to Establish Paternity and For Legitimation;

That the Court Order the mother, the child, and myself submit to genetic
tests as specified in O.C.G.A. §19-7-45, to be conducted by a laboratory certified
by the American Association of Blood Banks, and/or be performed by a duly
qualified licensed practicing physician, duly qualified immunologist, or other
qualified person; and that this court determine the number and qualifications of the
experts.

I ask that should the above testing verify that the child is my natural child,
that the Court enter an Order legitimating my relationship with the child, so that
the child will be recognized as my legitimate child, capable of inheriting in the
same manner as if born in wedlock;

That the child continue using E as surname;

I ask that the Court enter an Order providing for specific, liberal visitation
privileges for me with the minor child (a desired schedule is attached as “Exhibit
A”);

I ask that the Court enter an Order granting Joint legal custody of the minor
child to be shared between the legal parents, with shared decision-making authority
and full access to all information, concerning the child’s education, religious
triaging and medical care;

I ask that the Court grant such other and further relief as the Court deems
fair and proper.

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 Respectfully submitted this _____ day of December, 2009

By: ____________________________
TDE, Pro Se
XXXXXXXX Lane
XXXXXXXX Ga XXXXX
(000) 000-1234

VERIFICATION
My name is TDE and I am the Petitioner in this action. I hereby swear or
affirm, before a Notary Public, that I have read this Petition to Establish Paternity
and For Legitimation which I am filing in Court with this Verification, and the
facts stated in the document are true.

_________________________
Petitioner

Subscribed and Sworn before me

This 1st day of December, 2009

___________________________
NOTARY PUBLIC