Summons and Complaint

Summons and Complaint SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION/FAMILY PART HUDSON COUNTY DOCKET NO.: FM-09-001576-25 SUMMONS From The State of New Jersey To The Defendant(s) Named Below: The plaintiff, named above, has filed a lawsuit against you in the Superior Court of New Jersey. The complaint attached to this summons states the basis for this lawsuit. If you dispute this complaint, you or your attorney must file a written answer or motion and proof of service with the deputy clerk of the Superior Court in the county listed above within 35 days from the date you received this summons, not counting the date you received it. (A directory of the addresses of each deputy clerk of the Superior Court is available in the Civil Division Management Office in the county listed above and online at http://www.judiciary.state.nj.us/pro se/10153_deptyclerklawref.pdf.) If the complaint is one in foreclosure, then you must file your written answer or motion and proof of service with the Clerk of the Superior Court, Hughes Justice Complex, P.O. Box 971, Trenton, NJ 08625-0971. A filing fee payable to the Treasurer, State of New Jersey and a completed Case Information Statement (available from the deputy clerk of the Superior Court) must accompany your answer or motion when it is filed. You must also send a copy of your answer or motion to plaintiff's attorney whose name and address appear above, or to plaintiff, if no attorney is named above. A telephone call will not protect your rights; you must file and serve a written answer or motion (with fee of $175.00 and completed Case Information Statement) if you want the court to hear your defense. If you do not file and serve a written answer or motion within 35 days, the court may enter a judgment against you for the relief plaintiff demands, plus interest and costs of suit. If judgment is entered against you, the Sheriff may seize your money, wages or property to pay all or part of the judgment. If you cannot afford an attorney, you may call the Legal Services office in the county where you live or the Legal Services of New Jersey Statewide Hotline at 1-888-LSNJ-LAW (1-888-576-5529). If you do not have an attorney and are not eligible for free legal assistance, you may obtain a referral to an attorney by calling one of the Lawyer Referral Services. A directory with contact information for local Legal Services Offices and Lawyer Referral Services is available in the Civil Division Management Office in the county listed above and online at http://www.judiciary.state.nj.us/prose/10153_deptyclerklawref.pdf Dated: December 4, 2025 /s/ Michelle M. Smith Clerk of the Superior Court Name of Defendant to Be Served: Nelson Garcia Martinez Address of Defendant to Be Served: 114 2nd Street, Apt. 1D, Ridgefield Park, New Jersey 07660 FREEMAN LAW CENTER, LLC Brian C. Freeman, ESQ. - Attorney ID: 009901983 97 Newkirk Street , Suite 328 Jersey City, NJ 07306 Phone: (201) 222-7765 Email: bfreeman@freemanhugheslaw.com Attorney(s) for Plaintiff JENNIFER MARIN, SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION – FAMILY PART Plaintiff, HUDSON COUNTY vs. DOCKET NO. FM-09-001576-25 NELSON GARCIA MARTINEZ, CIVIL ACTION COMPLAINT FOR DIVORCE Defendant. Plaintiff, Jennifer Marin, residing at 326 60th Street, Apt. 4, in West New York, County of Hudson and State of New Jersey, says by way of Complaint against the Defendant that: 1. Plaintiff, Jennifer Marin, presently resides at in 326 60th Street, Apartment 4, West New York, New Jersey, County of Hudson, and State of New Jersey. 2. Defendant, Nelson Garcia Martinez, resides at 114 2nd Street, Apartment 1D, Ridgefield, New Jersey 07660, County of Berge, and State of New Jersey. 3. Plaintiff was lawfully married to Nelson Garcia Martinez, the Defendant herein, on March 24, 2019 in the of, County of and State of New Jersey in a civil ceremony. 4. The Plaintiff was a bona fide resident of the State of New Jersey when the cause of action arose pursuant to N.J.S.A. 2A:34-2 (i) and has ever since continued so to be such bona fide resident down to the time of the commencement of this action. 5. Venue is proper in Hudson County as Plaintiff was domiciled at 326 60th Street, Apartment 4, West New York, New Jersey 07093 at the time the within cause of action arose. 6. Activity of the Defendant specifically permits this cause of action under the provisions of N.J.S.A 2A:34-2 as follows: A. Irreconcilable differences have caused the breakdown of the marriage for a period of at least six (6) consecutive months. Pursuant to N.J.S.A. 2A:34-2(i), the marriage should be dissolved as there is no reasonable prospect of reconciliation. 7. No children were born of the marriage. 8. There have been no previous family actions between the parties in any court regarding the marriage or its dissolution. 9. No real or personal property was acquired by the parties during the marriage which is subject to equitable distribution. WHEREFORE, Plaintiff demands judgment: a) Dissolving the marriage between the parties; b) For such further relief as the Court may deem just and equitable. DATED: March 6, 2025 BRIAN C. FREEMAN Attorney(s) for Plaintiff December 9 2025 LNYS0419914 $103.84