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70 Demand Model For Increase in Food Quota
70 Demand Model For Increase in Food Quota
Plaintiff: XXXXXXXXXXXXXXXXXXXXXXXXXX.
Respondent: XXXXXXXXXXXXXXXXXXXXXXXXXX
Postulation
FACTS
SECOND: Subsequently, the THIRD FAMILY COURT OF MEDELLÍN , where the paternity
challenge process was conducted, through file 2012-1323 ruled: “Judicially declaring that Mr.
XXXXXXXXXXXXXXXXXXXXXXXXXX, identified with citizenship card No. 91'271,583, is the
extramarital father of the child XXXXXXXXXXXXXXXXXXXXXXXXXX, born on October 18, 2009,
and of Mrs. XXXXXXXXXXXXXXXXXXXXXXXXXX; establishing as a maintenance fee payable
by Mr. XXXXXXXXXXXXXXXXXXXXXXXX and in favor of XXXXXXXXXXXXXXXXXXXXXXXX,
the equivalent of twenty-five percent (25%) of what constitutes the legal monthly minimum wage
in force in Colombia, and two additional installments for the same percentage that will be paid in
the months of June and December of each year, an amount that must be delivered directly to
Mrs. every month, counted from the execution of this ruling.”
XXXXXXXXXXXXXXXXXXXXXXXXXX
RC: 1,032,017,701
MONTHLY ANNUAL
BILLS
VALUE VALUE
Rent $ $
200.000 2.400.000
$ $
Public Services (Water, Energy, Gas) 35.000 420.000
$ $
Television, Internet, Telephone 40.000 480.000
$ $
Feeding 378.000 4.536.000
Toiletries (bath soap, shampoo, toothpaste, toothbrush, detergent, perfume, $ $
toilet paper, liquid soap) 33.000 396.000
$ $
Medications, Dolex, Scott Emulsion 20.000 240.000
$ $
Moderating fees in the Eps SURA (health and dentistry) 10.000 120.000
$ $
Transportation - Medical Appointments 30.000 360.000
$ $
Hair cut (once a month) 9.000 108.000
$ $
College registration (once a year) 37.629 451.548
$ $
School monthly fee 244.800 2.937.600
$ $
school transportation 160.000 1.920.000
$ $
School uniforms (once a year) 37.417 449.004
$ $
School supplies (once a year) 7.500 90.000
$ $
Soccer School - Monthly Fee 80.000 960.000
$ $
Soccer School - Sports uniform (once a year) 12.500 150.000
$ $
Soccer School - Transportation from home to school (month) 144.000 1.728.000
$ $
Clothing (shirt, pants, underwear, socks, shoes, belt) 2 times a year 33.000 396.000
$ $
Toys 12.500 150.000
$ $
Birthday gift (18 - October) 15.000 180.000
$ $
Babysitter 300.000 3.600.000
$ $
TOTAL EXPENSES - XXXXXXXXXXXXXXXXXXXXXXXXXX 1.839.346 22.072.152
NOTE : There are annual expenses, such as: School tuition, school and sports uniforms, school supplies and
a birthday gift. In this case, they are placed deferred in 12 months of the year, so that they are taken into
account within the child's child support quota XXXXXXXXXXXXXXXXXXXXXXXXXX.
FIFTH: Once the hearing began, no agreement was reached between the parties and
consequently the RECORD OF NON-AGREEMENT was issued.
FIRST: That the REVIEW OF THE SUPPORT FEE be carried out and the INCREASE OF THE FEE
currently provided by Mr. XXXXXXXXXXXXXXXXXXXXXXXXXXX is DECREED , for his son
XXXXXXXXXXXXXXXXXXXXXXXXXX, in accordance with the income and economic capacity that
the defendant has today.
EVIDENCE
DOCUMENTARIES
JOB
FOUNDATIONS OF LAW
I base this claim on the provisions of article 111 of law 1098 of 2006, article 390 of the General
Process Code.
COMPETENCE
Due to the nature of the matter, and the domicile of the minor, you are competent, Mr. Judge, to hear
this process.
ANNEXES
With this complaint, I attach the documents mentioned in the documentary evidence section, and the
following:
1. Power of attorney in my favor, duly authenticated.
2. Proof of non-agreement.
3. Civil Registry of the minor.
4. Sentence of the process of challenging paternity and extramarital affiliation through file 2012-1323
5. Copy of the complaint for transfer to the defendant.
6. Copy of the demand for transfer to the public ministry
7. Copy of the complaint for the court file.
NOTIFICATIONS
Demanding:
Receive personal notifications in XXXXXXXXXXXXXXXXXXXXXXXXXX, Medellín
Telephone: XXXXXXXXXXXXXXXX
Defendant:
Receive personal notifications at XXXXXXXXXXXXXXXXXXXXXXXXXX.
The subscript:
I receive personal notifications at the Legal Office Fundación Universitaria Luis Amigo Transversal
51ª No 67B 90 Medellín- Antioquia.
Sincerely,
XXXXXXXXXXXXXXXXXXXXXXXXXX
DC XXXXXXXXXXXXXXXXXXXXXXXXXX
Legal Office Luis Amigo University Foundation Law Practitioner.