NAME PO BOX SAIPAN MP 96950 TELEPHONE NO

NAME PO BOX SAIPAN MP 96950 TELEPHONE NO




Name:

Name:

P.O. Box _______

Saipan, MP 96950


Telephone No.:


PRO SE

IN THE SUPERIOR COURT

OF THE

COMMONWEALTH OF THE NORTHERN MARIANA ISLANDS


(Name of Mother) )

and ) FCD PA CIVIL ACTION NO. ___-______

[Name of Child(ren)], )

Minor Child(ren) )

)

Plaintiffs, ) COMPLAINT TO ESTABLISH

) PARENT-CHILD RELATIONSHIP

)

vs. )

)

(Name of Alleged Father), )

)

Defendant. )

)



  1. This case arises under the Uniform Parentage Act, 8 CMC §§ 1700-26.


  1. The Court has jurisdiction of the claims pursuant to 8CMC § 1708 and 8 CMC § 1534.


  1. Plaintiff, (Name of Mother), is a resident of Saipan, Commonwealth of the Northern Mariana Islands. Through this action, Plaintiff seeks to establish the relationship of parent and child between her child(ren) and Defendant, and to obtain an order of child support.


  1. Plaintiff and Defendant engaged in sexual intercourse together on various occasions from approximately (Month and Year) to (Month and Year).


  1. Plaintiff and Defendant lived together from (Month and Year) to (Month and Year).


  1. On, [birth date(s)], Plaintiff gave birth to (a male/female child, Child's Name)/the following children: list Children's Names and their gender), at Saipan, CNMI.


  1. The Father of the minor child(ren) is the Defendant, (Name of Defendant), who resides in Saipan, CNMI. Defendant acknowledged paternity by signing the birth certificate. See attached Exhibit “A”.


  1. The Defendant, (Name of Defendant), is employed and has the ability to support the minor child. Despite his obligation to do so, Defendant has failed to adequately support said minor child.


  1. Plaintiff, (Name of Plaintiff), has custody, care and control of the minor child.


  1. Plaintiff, (Name of Plaintiff), and [Name of Minor Child(ren)] are entitled to an order adjudging (Name of Defendant) to be the father of the minor child(ren), (Name of Minor Child(ren), pursuant to the Uniform Parentage Act, 8 CMC §§ 1700-26, for an order of child support, custody, and for other appropriate relief.


WHEREFORE, Plaintiff prays for the following relief:


  1. An order adjudging Defendant,(Name of Defendant),to be the Father of (Name of Minor Child/ren) pursuant to 8 CMC §§ 1700-26;


  1. An award of custody and child support to (Name of Plaintiff), including retroactive child support from the child’s date of birth, pursuant to 8 CMC §1715;


  1. An order that Defendant shall provide full insurance coverage and/or cash payments for medical, dental, and eye care expenses for the minor child wherever incurred;


  1. Cost and attorney’s fees pursuant to 8 CMC § 1716; and for such other relief as the Court deems just and equitable.


VERIFICATION

I, (Name of Plaintiff) declare under penalty of perjury that the foregoing Complaint is true and correct to the best of my knowledge. This declaration was executed on the day of , 20___, at Saipan, CNMI.


Typed Name and Signature of Natural Mother


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