Plaintiff: Liang XX, female, Han nationality, born in ×××1973, ID number: 46002519736 ××××, living in XX Town Ceramics Factory, Hainan Province, and telephone number: 15965438. Defendant: Sun Xx, male, Han nationality, born on1971××××, ID number: 44010419713×××, family. Claim 1: The illegitimate daughter (born on August 23rd, 2009) between the plaintiff and the defendant is required to be raised by the plaintiff according to law, and the defendant pays the plaintiff 10 with a monthly maintenance fee of 3,000 yuan until the daughter reaches the age of 18; 2. Request the defendant to bear all litigation costs in this case according to law. Facts and reasons Plaintiff Liang XX met Defendant Sun XX through the Internet in May 2008. At that time, the defendant claimed to be unmarried and wanted to find a girlfriend to get married, and completely concealed the real situation of being married and interacted with the plaintiff. In the process of their communication, the plaintiff has repeatedly asked to marry the defendant, but the defendant has shirked on the grounds that his parents and brothers are in Canada and there is no owner to marry the plaintiff in Guangzhou. The plaintiff is convinced of this and no longer asks questions. It was not until June 5438+ 10, 2009 that the plaintiff found out that she was pregnant for one month. The defendant was very happy when she knew it, so the plaintiff urged the defendant to register her marriage again. The defendant said that he had to consult with his parents. It was not until the defendant was pregnant for 5 months that the plaintiff repeatedly asked him to say that he actually had a family. This sudden fact made the plaintiff like a bolt from the blue, so he quarreled with the defendant many times and asked him to pay for the child being taken out of the hospital, but the defendant insisted that the plaintiff give birth to the child. Until August 23, 2009, accompanied by the defendant, the plaintiff went to Guangzhou Zhongshan Third Hospital to give birth to a daughter, and all expenses for the plaintiff's admission and production were paid by the defendant. On the day when the plaintiff was discharged from the hospital, because the daughter born to the plaintiff had high jaundice and needed hospitalization, the defendant had to take care of her daughter as an excuse to transfer her to a hospital near her unit for hospitalization and take her and the plaintiff's daughter away. After that, the plaintiff never saw her daughter again. On May 4th, 20 10, the plaintiff went to the defendant company, namely Guangzhou XX Industrial Corporation (located in XX Building, West of Huangpu Avenue) to ask for a visit. The defendant pushed the plaintiff away while she was not looking, but the plaintiff still couldn't see her daughter. Because the plaintiff was anxious about her daughter, she went to the defendant's residence to find the defendant and her daughter, and learned that the defendant's wife was infertile from the security office downstairs in the defendant's community. Later, the plaintiff went to the defendant's parents' residence to make a statement. The defendant and his wife threatened the plaintiff on the phone, saying: To make the plaintiff's life worse than death, no matter how much money it costs, someone must find the plaintiff and kill him! To sum up, the defendant lied to the plaintiff that he was married and gave birth to a daughter, and took the plaintiff's daughter away, which not only seriously hurt the plaintiff's feelings, seriously affected the plaintiff's future marriage life, but also made the plaintiff feel the pain of separation of flesh and blood! Request the people's court to support all the plaintiff's claims according to law and safeguard the plaintiff's legitimate rights and interests! To the witness of Yuexiu District People's Court in Guangzhou: It is not difficult to write a complaint of child support for illegitimate children on xxxxxxx. As long as the actual situation and litigation requirements are explained in detail in the complaint, it will be a better complaint. If you find it troublesome to write a complaint, you can entrust a senior lawyer to help you write a complaint for child support for illegitimate children through the lawyer 365 website.
Legal objectivity:
Article 1085 of the Civil Code of People's Republic of China (PRC) * * * After divorce, if the children are directly raised by one party, the other party shall bear part or all of the maintenance. The amount and duration of the expenses shall be agreed upon by both parties; If the agreement fails, the people's court shall make a judgment. The agreement or judgment stipulated in the preceding paragraph shall not prevent the children from making reasonable demands to either parent over the original agreement or judgment when necessary. Article 121 of the Civil Procedure Law of People's Republic of China (PRC): (1) The name, sex, age, nationality, occupation, work unit, domicile and contact information of the plaintiff, the name and domicile of the legal person or other organization, and the name, position and contact information of the legal representative or principal responsible person; (2) Information such as the name, gender, work unit and domicile of the defendant, and information such as the name and domicile of the legal person or other organization; (3) the request and the facts and reasons on which it is based; (4) Evidence and its sources, names and residences of witnesses.