On September 23, 2021 a
Complaint,Petition
was filed
involving a dispute between
Dor Cse Western And Dta,
Pagan, Kimberly Ann,
and
Sanchez, Kivanny,
for Paternity Managed
in the District Court of Hampden County.
Preview
Commonwealth of Massachusetts
The Trial Court
Probate and Family Court Department
Division Hampden Docket No.
COMPLAINT TO ESTABLISH PATERNITY PURSUANT TO G.L. c. 209C
Massachusetts Department of Revenue
Child Support Enforcement Division
on behalf of
Kimberly Ann Pagan , Plaintiffv. Kivanny Sanchez , Defendant
AND Department of Transitional Assistance
1. The Child Support Enforcement Division of the Massachusetts Department of Revenue brings this
complaint pursuant to G. L. c. 119A, § 3 and c. 209C on behalf of the plaintiff(s) noted above.
2. The child who is the subject of this complaint is:
JAYLANNIS NICOLE MORALES
3. The child was born on: 04/18/2012
4. The name of the child's custodian is:
KIMBERLY ANN PAGAN
5. The child's custodian is the child's: Mother
6. The child resides with the custodian in Massachusetts in the County of: Hampden
7. The mother of the child named above is:
KIMBERLY ANN PAGAN
215 E DWIGHT ST
APT 201
HOLYOKE, MA 01040-6105
8. The father of the child named above is:
KIVANNY SANCHEZ
14 LAUREL ST
FL 2
HOLYOKE, MA 01040-3512
9. The mother and father of the child are not married to each other.
10. No other parties need to be joined pursuant to G. L. c. 209C, § 6. The mother of the child was not married at
the time of the child's birth and was not married within 300 days before the birth of the child.
F70541 06/16 42053300 Page 1 of 2
11. The Massachusetts Department of Revenue requests that the court:
adjudicate the defendant to be the father of the child.
order the mother / father to pay child support in an amount consistent with the child support
guidelines.
order the mother / father to provide private health care coverage that is reasonable in cost and
accessible to the child, or if private health care coverage is currently not reasonable in cost and
accessible to the child, order the mother / father to pay cash medical support until such private
health care coverage becomes available.
order the mother / father to pay reimbursement for past support provided to the child.
order the mother / father to pay the costs of the child's unreimbursed medical expenses.
order such other relief as the court deems appropriate.
Massachusetts Department of Revenue
Child Support Enforcement Division
By its attorney,
09/23/2021 /s/ OSVALDO ALMODOVAR
Date OSVALDO ALMODOVAR
Counsel
PO BOX 7057
BOSTON, MA 02204-7057
(413)784-1025Ext:21407
ALMODOVAOS@DOR.STATE.MA.US
BBO#: 690129
F70541 06/16 42053300 Page 2 of 2
Document Filed Date
September 23, 2021
Case Filing Date
September 23, 2021
Category
Paternity Managed
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