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• CAliSE NO. 231-499531-11
•
IN THE MATTER OF § IN THE DISTRICT COURT
THE MARRIAGE OF §
§ 2'·
,:::-.--
CINDY ANN PUGA u; :-'\.~
AND
§
§ 231sr JUDICIAL DISTRICT'' -·
JAVIERPUGA §
,. ·-
§ __ ,
AND IN THE INTEREST OF § r4 -·-
"X\
CASANDRA MARIE PUGA,
A MINOR CIIILD
§
§ TARRANT COUNTY, TEXAS?"
~c
0· -
FIRST AMENDED PETITION FOR DIVORCE
1. Di.~coverv Level
Discovery in this case isintended to be conducted under level 2 of rule 190 of the Texas
Rules of Civil Procedure.
2. Partie.'i
This suit is brought by CINDY ANN PUGA, Petitioner. The last three numbers of CINDY
ANN PUGA'S driver's license number are 397. The last three numbers of CINDY ANN PUGA'S
Social Security number are 778.
JAVIER PUGA is Respondent.
3. Domicile
Petitioner has been a domiciliary of Texas for the preceding six-month period and a resident
of this county for the preceding ninety-day period.
4. Service
Process should be served on Respondent, JAVIER PUGA, at 2717 Ave. C, Apt. #3, Fort Worth, TX
76106.
First Amended Petition for Divorce (Cause #231-499531-J/)
Pagel
Marriage ofPuga & Puga and ITJO Casandra Marie Puga, Minor Child
Lilw Chnic, Texas Wt>sley,m Umver~ity School of Law • 1515 Commerct' Stn'et • Fort Worth, Tt>Xd~ 76102 • (817) 212-4123 • Fax (1117) 212-4124
----------------------------------------· ---- ------------------------------------------- .
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5. ProtectiJ•e Order Statement
No protective order under title 4 of the Texas Family Code is in effect, and no application for
a protective order is pending with regard to the parties to this suit.
6. Dates o(Aiarriage and Separation
The parties were married on or about April24, 200 I, and ceased to live together as husband
and wife on or about September 21, 2003.
7. Ground.fi [or DiJ•ora
The marriage has become insupportable because of discord or conflict of personalities
between Petitioner and Respondent that destroys the legitimate ends of the marriage relationship and
prevents any reasonable expectation of reconciliation.
Petitioner and Respondent have lived apart without cohabitation for at least three years.
8. Child o{/he Marriage
Petitioner and Respondent are parents of the following child of this marriage who is under the
continuing jurisdiction of the 231st District Court of Tarrant County, Texas:
Name: CASANDRA MARIE PUGA
Sex: Female
Birth date: February 2, 2000
There are current court-orders regarding conservatorship affecting the child the subject of this
suit under Cause No. 231-3317-1-6-0", the latest order of which was granted and signed on October
28, 2010. Petitioner is requesting that no change or modification be made as to any of the orders in
that suit. Petitioner requests that Cause No. 231-331746-02 be consolidated into this divorce suit.
Fir.1·t Amended Petition for Divorce (Cause #23/-499531- I I)
Marriage ofPu~a & f'uga and /T/0 CasanJra Marie Puga, Minor Child
Information required
• by section 154.181(b) of the Texas
•
Family Code is provided in the
statement attached as Exhibit A.
No property of consequence is o\\ned or possessed by the child the subject of this suit.
9. Children Born During the !llarriage Not o(the !tfarriage
Petitioner is the mother ofthc following children who were born during the marriage but are
not of the marriage:
Name: MARTIN ALEXANDER MARQliEZ
Sex: Male
nirth date: August 6, 2004
Name: JOSE ANGEL ONOFRE
Sex: Male
Birth date: June 23, 2006
Name: ANDREW BRYAN SANCHEZ
Sex: Male
£lirth date: October 23. 2008
Respondent, JAVIER PUGA, was adjudicated NOT to be the biological father of MARTI~
ALEXANDER MARQUEZ, on April 24, 2008, in Cause No. 231-331746-02.
The above named child. ANDREW BRYAN SANCIIEZ, was the subject of a suit filed by
the Texas Attorney General, under Cause No. 360-462495-09. That suit was Nonsuited on May 6,
2010, because of the inability to find and serve this child"s alleged father, EMMANUEL SANCIIEZ-
TRIANA.
First Amended PI!IITion for Di\'orce (Cuuse #:! 3/-4Y9531-ll)
Marriuge of Puga & Puga and /T/0 Casandra Murie Puga, Minor ( 'hild
• •
Further, there is a pending suit filed by the Texas Attorney General with regard to the child
JOSE ANGEL OJ';OFRE, Cause No. 231-498637-11, which names AROLDO EDUARDO
ONOFRE as this child" s biological father.
Petitioner requests that the Court find and enter orders accordingly that the Respondent in
this suit, JAVIER PUGA, be found NOT to be the father ofMARTIN ALEXANDER MARQUEZ,
ANDREW BRYAN SANCHEZ, or JOSE ALEXANDER ONOFRE.
10. Division o[Communifl' Propertr
Petitioner believes Petitioner and Respondent will enter into an agreement for the division of
their estate. If such an agreement is made, Petitioner requests the Court to approve the agreement
and divide their estate in a manner consistent with the agreement. If such an agreement is not made,
Petitioner requests the Court to divide their estate in a manner that the Court deems just and right, as
provided by law.
11. Reque~t (or Change o[Name
Petitioner requests a change of name to CINDY ANN MARQUEZ.
12. Prarer
Petitioner prays that the Court grant a divorce and all other relief requested in this amended
petition.
Petitioner prays that Petitioner's name be changed as requested above.
Petitioner prays for general relief.
First Amendl!d Petition ji1r Divorce (Cause #231-41.)1)531-/l) Page.J
Marriage ofPuga & Puga and /T/0 Ca~andra Marie Puga, Minor Child
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Respectfully submitted,
TEXAS WESLEY AN LAW CLINIC
1515 Commerce Street
Ft. Worth, Texas 76102
Tel: (817) 212-4123
Fax: (817) 212-4124
!ly:~,-6-~
CELESTINA L CONTRERAS
State Bar No. 04712260
Attorney for Petitioner
lly~~~RM~;~
State Bar No. 24064429
Legal Intern for Petitioner
CERTIFICATE OF SERVICE
We hereby certify that a true and correct copy of this First Amended Petition for Divorce
has been sent by certified mail to the Texas Attorney General in accordance with the Texas Rules
of Civil Procedure on this 3 J ~day of August 20 II.
CELESTINA L CONTRERAS
State Bar No. 04712260
Attorney for Petitioner
State Bar No. 24064429
Legal Intern for Petitioner
First Amt>nded Petition for Divorce (Cause #23!-499531-11) Puge5
Afarria}!.e of Puga &Puga and IT/0 Casandra Marie Pu}!.a, Minor Child
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• CAliSE NO. 231-499531-11 • IN THE MATTER OF § IN THE DISTRICT COURT THE MARRIAGE OF § § 2'· ,:::-.-- CINDY ANN PUGA u; :-'\.~ AND § § 231sr JUDICIAL DISTRICT'' -· JAVIERPUGA § ,. ·- § __ , AND IN THE INTEREST OF § r4 -·- "X\ CASANDRA MARIE PUGA, A MINOR CIIILD § § TARRANT COUNTY, TEXAS?" ~c 0· - FIRST AMENDED PETITION FOR DIVORCE 1. Di.~coverv Level Discovery in this case isintended to be conducted under level 2 of rule 190 of the Texas Rules of Civil Procedure. 2. Partie.'i This suit is brought by CINDY ANN PUGA, Petitioner. The last three numbers of CINDY ANN PUGA'S driver's license number are 397. The last three numbers of CINDY ANN PUGA'S Social Security number are 778. JAVIER PUGA is Respondent. 3. Domicile Petitioner has been a domiciliary of Texas for the preceding six-month period and a resident of this county for the preceding ninety-day period. 4. Service Process should be served on Respondent, JAVIER PUGA, at 2717 Ave. C, Apt. #3, Fort Worth, TX 76106. First Amended Petition for Divorce (Cause #231-499531-J/) Pagel Marriage ofPuga & Puga and ITJO Casandra Marie Puga, Minor Child Lilw Chnic, Texas Wt>sley,m Umver~ity School of Law • 1515 Commerct' Stn'et • Fort Worth, Tt>Xd~ 76102 • (817) 212-4123 • Fax (1117) 212-4124 ----------------------------------------· ---- ------------------------------------------- . • • 5. ProtectiJ•e Order Statement No protective order under title 4 of the Texas Family Code is in effect, and no application for a protective order is pending with regard to the parties to this suit. 6. Dates o(Aiarriage and Separation The parties were married on or about April24, 200 I, and ceased to live together as husband and wife on or about September 21, 2003. 7. Ground.fi [or DiJ•ora The marriage has become insupportable because of discord or conflict of personalities between Petitioner and Respondent that destroys the legitimate ends of the marriage relationship and prevents any reasonable expectation of reconciliation. Petitioner and Respondent have lived apart without cohabitation for at least three years. 8. Child o{/he Marriage Petitioner and Respondent are parents of the following child of this marriage who is under the continuing jurisdiction of the 231st District Court of Tarrant County, Texas: Name: CASANDRA MARIE PUGA Sex: Female Birth date: February 2, 2000 There are current court-orders regarding conservatorship affecting the child the subject of this suit under Cause No. 231-3317-1-6-0", the latest order of which was granted and signed on October 28, 2010. Petitioner is requesting that no change or modification be made as to any of the orders in that suit. Petitioner requests that Cause No. 231-331746-02 be consolidated into this divorce suit. Fir.1·t Amended Petition for Divorce (Cause #23/-499531- I I) Marriage ofPu~a & f'uga and /T/0 CasanJra Marie Puga, Minor Child Information required • by section 154.181(b) of the Texas • Family Code is provided in the statement attached as Exhibit A. No property of consequence is o\\ned or possessed by the child the subject of this suit. 9. Children Born During the !llarriage Not o(the !tfarriage Petitioner is the mother ofthc following children who were born during the marriage but are not of the marriage: Name: MARTIN ALEXANDER MARQliEZ Sex: Male nirth date: August 6, 2004 Name: JOSE ANGEL ONOFRE Sex: Male Birth date: June 23, 2006 Name: ANDREW BRYAN SANCHEZ Sex: Male £lirth date: October 23. 2008 Respondent, JAVIER PUGA, was adjudicated NOT to be the biological father of MARTI~ ALEXANDER MARQUEZ, on April 24, 2008, in Cause No. 231-331746-02. The above named child. ANDREW BRYAN SANCIIEZ, was the subject of a suit filed by the Texas Attorney General, under Cause No. 360-462495-09. That suit was Nonsuited on May 6, 2010, because of the inability to find and serve this child"s alleged father, EMMANUEL SANCIIEZ- TRIANA. First Amended PI!IITion for Di\'orce (Cuuse #:! 3/-4Y9531-ll) Marriuge of Puga & Puga and /T/0 Casandra Murie Puga, Minor ( 'hild • • Further, there is a pending suit filed by the Texas Attorney General with regard to the child JOSE ANGEL OJ';OFRE, Cause No. 231-498637-11, which names AROLDO EDUARDO ONOFRE as this child" s biological father. Petitioner requests that the Court find and enter orders accordingly that the Respondent in this suit, JAVIER PUGA, be found NOT to be the father ofMARTIN ALEXANDER MARQUEZ, ANDREW BRYAN SANCHEZ, or JOSE ALEXANDER ONOFRE. 10. Division o[Communifl' Propertr Petitioner believes Petitioner and Respondent will enter into an agreement for the division of their estate. If such an agreement is made, Petitioner requests the Court to approve the agreement and divide their estate in a manner consistent with the agreement. If such an agreement is not made, Petitioner requests the Court to divide their estate in a manner that the Court deems just and right, as provided by law. 11. Reque~t (or Change o[Name Petitioner requests a change of name to CINDY ANN MARQUEZ. 12. Prarer Petitioner prays that the Court grant a divorce and all other relief requested in this amended petition. Petitioner prays that Petitioner's name be changed as requested above. Petitioner prays for general relief. First Amendl!d Petition ji1r Divorce (Cause #231-41.)1)531-/l) Page.J Marriage ofPuga & Puga and /T/0 Ca~andra Marie Puga, Minor Child • • Respectfully submitted, TEXAS WESLEY AN LAW CLINIC 1515 Commerce Street Ft. Worth, Texas 76102 Tel: (817) 212-4123 Fax: (817) 212-4124 !ly:~,-6-~ CELESTINA L CONTRERAS State Bar No. 04712260 Attorney for Petitioner lly~~~RM~;~ State Bar No. 24064429 Legal Intern for Petitioner CERTIFICATE OF SERVICE We hereby certify that a true and correct copy of this First Amended Petition for Divorce has been sent by certified mail to the Texas Attorney General in accordance with the Texas Rules of Civil Procedure on this 3 J ~day of August 20 II. CELESTINA L CONTRERAS State Bar No. 04712260 Attorney for Petitioner State Bar No. 24064429 Legal Intern for Petitioner First Amt>nded Petition for Divorce (Cause #23!-499531-11) Puge5 Afarria}!.e of Puga &Puga and IT/0 Casandra Marie Pu}!.a, Minor Child