Yeah

Páginas: 23 (5705 palabras) Publicado: 10 de noviembre de 2012
INITIAL BRIEF

C. First Judge Civil Trial
TENANCINGO JUDICIAL DISTRICT
STATE OF MEXICO
THIS

LOURDES GARCIA ALMANZA, on my own behalf and on behalf of my minor children YAIR JERONIMO AND REYNA GUADALUPE ZEPEDA GARCIA surname, indicating an address to hear and receive all kinds of notifications over the agreements located in the office of the public defender based in the ground floor of thebuilding occupied by the courts of the High Court of Tenancingo, Mexico and to authorize my behalf as well as get them to pick up personal documents on behalf AL LIC. GRACIELA TORRES Favila and LIC. LAURA MILLAN CASTRO, CRISTINA ALEJANDRA SANCHES GUTIERREZ, ELIDE MATA JESUS ​​PEREZ on public advocates.
that judgments of family order in exercise of responsible personal action I come to sueJERONIMO ZEPEDA HERNANDEZ who is domiciled to be located in UNITED STATES OF AMERICA HOUSTON TEXAS Street between Capitol and HARRIBU 7405 NUMBER under the headquarters the defendant is outside this judicial district outside the country therefore request that it be called a letter rogatory to this opportunity to state in what corresponds to his right who claimed the following benefits:

1. - Finalcustody and guardian for the minor children of my subscribed YAIR JERONIMO ZEPEDA GARCIA AND REYNA GUADALUPE ZEPEDA GARCIA surname.
2. - The payment of alimony definitely in favor of my younger sons YAIR JERONIMO ZEPEDA GARCIA and REYNA GUADALUPE ZEPEDA GARCIA surname.
3. - Ensuring the final alimony for my younger children YAIR JERONIMO ZEPEDA GARCIA and REYNA GUADALUPE ZEPEDA GARCIA surname.
5.- The payment of expenses and

FACTS

1. - That in 2000 the undersigned civil marriage contracted with Mr. JERONIMO ZEPEDA HERNANDEZ, as I credit with the certified copy of the marriage certificate that annexed hereto our marriage relationship procreate two children as we credited with certified copies of birth certificates that annexed hereto constitute our home in Calle Miguel Hidalgo St.Nicholas countless Malinalco town where I am currently living with my younger children.
2. - As the beginning of our relationship things were more or less bearable with normal problems leading a harmonious relationship, seeking always subscribed to fulfill my duties as wife and homemaker and my even husband met its obligation to provide food to both signed and our minor children.
3. - So, when Iwas subscribed pregnant with my second child the defendant in this case I proposed to go to work in the United States in order that we might have a better future for our children, at first subscribed disagreed not wanting we parted but over many talks was that we agreed that the defendant would be only for a while and come back to us to be together, and did so in 2006 my husband even went to workin the United States of America and to date has not returned, at which time the defendant has ignored to fulfill its obligation to provide food to the undersigned and our younger children and despite the work signed as maid that I get I'm short for the support of my minor children that is why I feel the need to sue in the way that I do.

4. - Affection for certifying the financial solvency ofthe defendant revealed his lordship that the defendant serves as a construction worker in the country illegally and are filing their income received for eight dollars an hour labor each workday.
MEASURES PROVICIONALES

1. - The provisional alimony for my younger children YAIR JERONIMO ZEPEDA GACIA and surname REYNA GUADALUPE ZEPEDA GARCIA
2. - The guard for temporary custody of my minor childrensigned YAIR JERONIMO ZEPEDA GARCIA and surname REYNA GUADALUPE ZEPEDA GARCIA
And in order to comply with the provisions of Articles 2134, 2135 and other related and applicable Code of Civil Procedure of the State of Mexico since the moment I offer myself as evidence of the following:

TESTS

1. - The defendant's confessional by Jerónimo Zepeda Hernández who shall appear in person and...
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