Download as doc, pdf, or txt
Download as doc, pdf, or txt
You are on page 1of 4

Lady)

FAMILY JUDGE OF THE MEDELLIN-ANTIOQUIA CIRCUIT (R)


AND. S. d.

Reference: Demand for review of food quota (Quota increase).

Plaintiff: XXXXXXXXXXXXXXXXXXXXXXXXXX.
Respondent: XXXXXXXXXXXXXXXXXXXXXXXXXX

Postulation

XXXXXXXXXXXXXXXXXXXXXXXXXX , identified with ID number XXXXXXXXXXXXXXXX of


Medellín-Ant, attached to the Legal Office of the LUIS AMIGÓ UNIVERSITY FOUNDATION,
approved by resolution 287 of December 16, 2002, acting as legal representative of
XXXXXXXXXXXXXXXXXXXXXXXX, identified with citizenship ID XXXXXXXXXX of Envi gado ,
Antioquia, in order to initiate, process and bring to its completion a DEMAND FOR INCREASE IN
THE FEE INCREASE (FEE INCREASE), against Mr. XXXXXXXXXXXXXXXXXXXXXXXXXX , of
legal age, identified with citizenship card No. Bucaramanga, Santander.

Demanding libel, which is based on the following:

FACTS

FIRST : Ms. XXXXXXXXXXXXXXXXXXXXXXXXXX and Mr.


XXXXXXXXXXXXXXXXXXXXXXXXXX are the parents of the minor
XXXXXXXXXXXXXXXXXXXXXXXXXX , according to the civil birth registration certificate which is
provided as PROOF and ANNEX No. 1. ,

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.”

THIRD: Mrs. XXXXXXXXXXXXXXXXXXXXXXXXXX affirms that Mr.


XXXXXXXXXXXXXXXXXXXXXXXXXX, who has recorded the monthly alimony quota
established by the THIRD FAMILY COURT OF MEDELLÍN, which has been insufficient for the
proper support of her son; According to my daughter, the expenses of the minor
XXXXXXXXXXXXXXXXXXXXXXXXXX are:

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.

FOURTH: On September 15, 2014, Mr. XXXXXXXXXXXXXXXXXXXXXXXXXXXX and Mrs.


XXXXXXXXXXXXXXXXXXXXXXXXXXXX were summoned for the conciliation hearing at the
Legal Office of the Luis Amigó University Foundation for the review and increase of the food
quota.

FIFTH: Once the hearing began, no agreement was reached between the parties and
consequently the RECORD OF NON-AGREEMENT was issued.

SIXTH: The minor XXXXXXXXXXXXXXXXXXXXXXXXXX does not have a health contributory


regime, Mr. XXXXXXXXXXXXXXXXXXXXXXXXXXXX is not affiliated as a beneficiary for
healthcare procedures.
PRETENTIONS

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.

SECOND: Mr. XXXXXXXXXXXXXXXXXXXXXXXXXX is ordered to deposit the value of the new


installment to Mrs. NATALIA ARIAS MUÑETON, in her personal account, or in the absence of this, at
the orders of her Office at the Agrarian bank, during the first five (5) of each month .

THIRD: That he be ordered to pay procedural costs.

EVIDENCE

I ask the office to consider as such:

DOCUMENTARIES

1. Birth certificate of the child.


2. Proof of non-agreement.
3. Judgment of the THIRD FAMILY COURT OF MEDELLÍN , where the process of challenging
paternity and extramarital filiation was conducted through file 2012-1323, ruled: Judicially
declaring that Mr. XXXXXXXXXXXXXXXXXXXXXXXXXX was the father of the minor.

JOB

I respectfully request that the COMPANY XXXXXXXXXXXXXXXXXXXXXXXX be notified, so that


they certify whether Mr. XXXXXXXXXXXXXXXXXXXXXXXXXX is a worker of the same, type of
contract, length of time he has been performing his work (seniority), position and the value of what
constitutes salary and social benefits which accrues monthly.

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.

You might also like