DEMAND FOR CHILD SUPPORT

honorable : Presiding Judge of the Court

of Peace

In special assignments for children,

girls and adolescents

From the home of the boy, girl and

District adolescent

Judicial of [Santo Domingo District]

SUBJECT : Demand for Alimony

Juana Bueno

Lawyer Dte.: Santiago Rosado Suriel and JDLS

Defendant PedroFadul

Defendant :

Honorable Magistrate:

In the city of Santo Domingo, National District, Capital of the Republic

Dominican Republic, on the twenty-fifth (25th) day of the month of December in the year two thousand.
nineteen (2019); ACTING: a requirement of Mrs. Juana
Pérez], Dominican, of legal age, married, holder of the Identity card and
Electoral No. [000-000-0000], domiciled and resident in this city of Santo
Sunday, National District, who acts in his own name and on his own behalf.
person, having the appointed special lawyers as the LICENSED.
Santiago Rosado Suriel and JDLS, both Dominicans, of legal age,
married, Lawyers of the Courts of the Republic, holders of the identification card of
identity and electoral Nos. 001- and 001-, respectively, Lawyers of the
Courts of the Republic with ongoing permanent study in
the PKMMERKALEGAL, a bureau of consulting lawyers, advisors, and tax experts
litigants, with registered office at Gral. Luperon #101 Altos in the sector of
New City of Santo Domingo, National District,
809-539-7871 post office electronics:
pkmmerkalegal@gmail.comypkmmerkalegal@hotmail.com,Web:www.pkmmerk
alegal.com, headquarters, where my applicant makes a formal choice of domicile for
all the purposes and legal consequences of this act, arising and
successive;
YO: ______________________________________________________________,
duly appointed, received, and sworn in for the purposes of my ministry,
EXPLICITLY, and acting within the limits of my jurisdiction, I have
moved to the street [Maño Saviñon], No., Urbanization [la Sabella], from this
city of Santo Domingo, National District, which is where he has his residence and
residence, Mr. [Pedro Fadul], according to act No. [05], dated 25/12/2019,
contentious in No Agreement between the parties raised by the monitoring magistrate
attached [] for family matter concerning the [] Court District
of Peace of the jurisdiction of the National District, and once there, speaking with
according to me
he declared and said to be ________________________________________of me
I HAVE NOTIFIED my requested party, MR. [Pedro Fadul], that my
Requester Mrs. [Juana Bueno], summons and notifies to appear, as it may be
of law and place, [the day, hour and year] summoned within the legal deadline before
to know the audience, in order to respect their right to defense, by Ministry
from Lawyer, (9:00), morning hours, before the Court, []Jurisdiction of
Peace Court of the jurisdiction of the National District, in its powers in
special attributions of children and adolescents of the Child's home
and Adolescent of the Judicial District of [Santo Domingo], located at [place, address]
and streets], to the Court that will hold said Tribunal, to hear the CLAIM
IN ALIMONY, set to be addressed on the date indicated at the
purposes, means, and reasons that are listed subsequently:

1. To my requester, Mrs. [Juana Bueno], She is currently divorced.

Mr. [Pedro Fadul] with whom on the date [02/08/2000] they had a daughter who
it was duly declared by the referred father, who to this moment refuses
to grant child support for your daughter from the completion of her first year until
the date;

2. The girl is already five years old and that the indicated Mr. [Pedro
Fadul has not complied with any request to fulfill his obligation to
father, for the last notification was carried out in good faith with an act of
payment demand for maintenance, prodigiously threatening to guide
the demand for alimony arises from the sealed act with No.
00/2019, dated 0/00/2019, protocolized by the ordinary clerk of the [Ninth
Criminal Chamber of the First Instance Court of the National District

3. That Mr. Pedro Fadul referred to ignored such summons,

what the applicant decided to place in the hands of the inspector, recorded in the []
jurisdiction of the Peace Court of the Judicial District of [} not reaching
no agreement on the amount to be paid for the years owed and the pension
food support that must be paid by law;
4. Alimony is a procedure aimed at obtaining a
judicial recognition that orders the payment of alimony in favor of
a food scientist (daughter);

5. That is, the child, girl, or adolescent has the right to receive food from
of his father or mother and responsible person;

6. To whom will the mother, the father, or others have the right to claim for alimony?
person responsible for the custody and care of the child
teenager

7. The competent court to hear the maintenance claim is

the Peace Court, in special powers regarding children and adolescents of
home of the Child, Girl and Adolescent, and will be governed by the procedure
established in the Law;

8. The judge, when determining the amount of the pension, is based on

the evidence provided by the parties to justify an income or expense;

9. To what, the requirements that the law has established to guide

demand for alimony are the following, Birth certificate of
minor, identity and electoral card (father, mother or guardian), the requirements are
minimums, to allow the exercise of this right;

10. To what extent, the demand for alimony or child support, is

established in the Code for the Protection of Children and Adolescents (Law
136-03), and is intended for parents, mothers, or guardians; so that they
provide the necessary support for the sustenance and development of minors.

11. For all the above and for what this court might graciously accept for
Your elevated spirit of justice, we request the following:

12. That anyone who succumbs to justice will be condemned to pay the
costs according to the provisions of Articles 130 and 131 of the Code of Civil Procedure;

WHEREAS: That for all these reasons of fact and law and those
will be provided through irrefutable evidence in a public hearing if applicable
necessary, HEAR my required defendant MR. [Pedro Fadul], to me
Requester Mrs. [Juana Bueno], ask the presiding judge magistrate of this
Justice of the Peace in its powers regarding minors, to issue a ruling on the merits of the case.
the following way:

FIRST: DECLARE the present claim as good and valid for being regular
in form and just in terms of substance and in accordance with law and legislation;
SECOND: ORDER Mr. [Pedro Fadul] to pay the total amount of the
maintenance owed for a period of five years equal to the sum of [60,000] for
years overdue;

THIRD: TO CONDEMN Mr. to pay the monthly amount for the concept of
maintenance (RD$ 5,000.00), for the reasons stated above
Mrs. [Juana Bueno]

FOURTH: TO CONDEMN the defendant to pay the costs of the proceeding,

ordering their distraction and benefit to the concluding lawyers, graduates.
Santiago Rosado Suriel and JDLS.

FIFTH: ORDER the immediate execution to intervene regardless of any

resource that is filed against it;

UNDER THE BROADEST RESERVES OF RIGHTS AND ACTIONS

And so that my requested party, MR. [Pedro Fadul], does not attempt to plead ignorance and
subsequent ignorance of the content of this act, which consists of [1] (3)
leaves, this is how I have notified, declared, and warned him, and I have left him a faithful copy
in accordance with their original, sealed, signed, and initialed by our bailiff,
I hereby certify and attest.

RD$___________
I certify and attest.
THE SHERIFF

Juana Bueno

PKMMERKALEGAL:PKMMerkalegal@gmail.com- 809539-7871
 AUTHENTIC ACT OF DIVORCE BY MUTUAL CONSENT

ACT NUMBER: 09. In the city of Santo Domingo, National District,

Dominican Republic, on the twenty-fourth (24th) day of the month of September of the year
Two Thousand Fifteen (2015), before me, LICENSED Alfonso Duran Vargas,
Dominican, of legal age, single marital status, bearer of the identity card
and electoral No. 0000000000, Public Notary Lawyer of the Number of
National District, registration No. 0000, with its professional office open at the
Avenida 21 de la Duarte, number 21, Apartment 4-4, from Luperon of this city
from Santo Domingo, assisted in a real and continuous manner by the witnesses
required instruments for this effect, free of blemishes and incapacities, suitable for
right, individuals whom I certify to know, Mr. Pancho Duran, Dominican,
of legal age, single, merchant, holder of the identity and electoral card
00000000000, domiciled and residing at 255th Street, No. 26, Malacia sector,
National District, Dominican Republic, and Juana Suero, Dominican, mayor
of age, private employee, holder of the Identity and Electoral Card
Number 000000000, residing at 564th Street No. 12, of the Sector
The Villas, Herrera, Santo Domingo Oeste municipality, Santo Domingo Province,
Dominican Republic, HAVE APPEARED freely and voluntarily the
Mr. Francisco María REYES, of Dominican nationality, of legal age.
with Identity and Electoral Card Number 053-3658920-1, residing and
currently residing at Bollona Street No. 64, in the Los Profesores Sector of
Law, National District, Dominican Republic And, Pablo Suarez, Dominican
of legal age, holder of identity and electoral ID No. 555-6352896-1,
domiciled and resident at 23 Ballena Street, in the Teachers Sector of
Law, National District, Dominican Republic, jointly THEY HAVE
STATED THE FOLLOWING: That on the twenty-ninth (29th) day of the month of
December of the year Two Thousand Seven (2007), were married before the Official
of the Civil Registry of the Second Circumscription of Santo Domingo, which
registered in Book No. 00004 of civil marriage records,
Folio No. 0097, Act No. 000399, Year 2007 and that within said marriage not
they had children. Who are currently within the allowed period according to
the law to carry out their divorce by mutual consent. That both have
AGREED to proceed with their DIVORCE BY MUTUAL CONSENT, and that
being within the conditions required by the Law, by means of this act,
The CONVENTIONS AND STIPULATIONS that are to govern are hereby recorded.
his divorce for mutual consent, the which onesson the
FIRST: That considering that within the marriage they did not acquire
goods, they do not have to provide anything about it, so there are no goods to
divide between them; SECOND: That the wife will reside, while it lasts
divorce procedure, at your current address and residence, before
THIRD: That the wife hereby renounces any claim to her
The husband passed the alimony, as she is capable of providing for herself.
needs. FOURTH: That in view of the fact that within the marriage they did not procreate
children, do not have to provide anything about them; FIFTH: That both spouses
to grant POWER as broad and sufficient as necessary to the
Licensed MARLENY ESTEFANY DEL CARMEN RAMIREZ, so that in her
As a lawyer, I completed all the necessary procedures for the process.
of the divorce by mutual consent of the parties, which power is
accepted by said lawyer, present at this moment, who signs the
I present this act as a sign of acceptance, declaring that I have my study of
Lawyer open at Avenida José Contreras, No. 28, University Zone,
Gazcue, National District, where the lawyer's office makes selection of
address of the parties for the purposes and consequences of the procedure of
divorce. THIS WAS SAID AND GRANTED before me, Notary Public, in
the testimony of what precedes is drafted in this act, to which I have given
reading aloud to the individuals present, who after finding it
they proceed to sign it together with me and before me, Notary Public; signing
also the witnesses and the duly authorized representative, as previously indicated. Therefore, I certify and give

Fe.

JUANA SUERO Francisco María REYES

Appearing party Appearer

________________________________
____________________________
Pablo Suarez Pancho Duran
Witness Witness

_____________________________________
MARLENY ESTEFANY DEL CARMEN RAMIREZ
Attorney-in-fact

LICENSED ALFONSO DURAN VARGAS

Attorney Public Notary No. 3275