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40 Fam. L.Q. 51 (2006-2007)
The Innocent Third Party: Victims of Paternity Fraud

handle is hein.journals/famlq40 and id is 67 raw text is: The Innocent Third Party:
Victims of Paternity Fraud
BY RONALD K. HENRY*
The public good is in nothing more essentially interested, than
in the protection of every individual's private rights. **
I. Introduction
During her divorce proceedings, Bonnie repeatedly claimed that Doug
Richardson was the father of her child, but the child told Doug that Bonnie
stated that Abraham Flores was his real father. The court refused Doug's
request for a continuance to obtain counsel to assist in contesting paterni-
ty.' The Michigan Court of Appeals affirmed.2 A paternity test excluded
Doug as a possible father of the child.' Bonnie resumed living with
Abraham, but Doug was forced to pay child support into the household of
the child's real father. Later, Bonnie and Abraham broke up with a formal
change of custody from Bonnie to Abraham. The Michigan State Court
* Ronald K. Henry is a partner in the law firm of Kaye Scholer LLP in Washington, D.C.
The author wishes to thank Jahna M. Hartwig, Kevin Donohue, and C61ine Bondard, associates
at Kaye Scholer, for their extensive and tireless assistance in preparing this article.
** WILLIAM BLACKSTONE, 1 COMMENTARIES ON THE LAW OF ENGLAND 135.
1. Transcript of Hearing at 3, 6, Richardson v. Richardson, Court No. 91-7019, (Cir. Ct.
Bay Cty., Mich., Mar. 23, 1992) (on file with author). Bonnie's counsel showed some pity, stat-
ing on the record: I'm not trying to deny Mr. Richardson his opportunity to have counsel. I
believe that people ought to have an attorney if they want to. Id.
2. Richardson v. Richardson, No. 157567 (Mich. Ct. App. Nov. 23, 1994) (unpublished,
on file with author). In a two-paragraph opinion, the court of appeals wrote: After reviewing
Defendant's brief, we note he has failed to cite any authority supporting his position. We will
not search for authority to sustain a party's position. We decline to address issues not properly
presented. Id.
3. Letter from Henry Gershowitz, Ph.D., Director, National Legal Laboratories, Inc., to
Richard 0. Milster (Sept. 7, 1992) (on file with author).

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