SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF JEFFERSON
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Index No. EF2024-00001995,
Date Summons Filed: 05/06/2024
ROSE-MARIE CRYSTAL A.K.A. ROSE-MARIE CRYSTALBARRY A.K.A. ROSE-MARIE CRYSTAL-MCCLUNG, Plaintiff,
– against –
ROBERT PAUL CRYSTALBARRY, Defendant.
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Plaintiff designates Jefferson County as the place of trial. The basis of venue is CPLR Sec. 509.
AMENDED SUMMONS WITH NOTICE
Plaintiff resides at 511 W. 44th Street, Apt. 11A, New York, NY 10036.
ACTION FOR DIVORCE
To the above named Defendant: YOU ARE HEREBY SUMMONED to serve a notice of appearance on the Plaintiff’s Attorneys within twenty (20) days after the service of this summons, exclusive of the day of service (or within thirty (30) days after the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear, judgment will be taken against you by default for the relief demanded in the notice set forth below.
David Centeno, Esq.
David Centeno Law, PC, Attorneys for Plaintiff
300 International Drive, Suite 100
Buffalo, NY 14221
Tel.: 866-830-2064
NOTICE: The nature of this action is to dissolve the marriage between the parties, on the grounds: DRL Section 170 subd. (2) – the abandonment of the Plaintiff by the Defendant for a period of more than one year. The relief sought is a judgment of absolute divorce in favor of the Plaintiff dissolving the marriage between the parties in this action. The nature of any ancillary or additional relief demanded is: That the parties acknowledge and agree that the Plaintiff is currently pregnant, and the Defendant is not presumed to be the biological father. As such, neither party is seeking custody or child support of the unborn child. That the Family Court shall have concurrent jurisdiction with the Supreme Court with respect to any future issues of child support, custody and visitation. That the parties do not require maintenance and no claim will be made by either party for maintenance. The Plaintiff is not seeking maintenance as payee as described in the Notice of Guideline Maintenance. That the parties do not require payment of counsel and experts’ fees and expenses. That both parties may resume the use of any prior surname. That the Court grant such other and further relief as the Court may deem fit and proper. The parties have divided up the marital property, and no claim will be made by either party under equitable distribution.