Summons and Complaint for Divorce – RAUL MARIO PASSEGGI v INDRANIE PASSEGGI FM-20-001178-26
DANIEL YANIV, ESQ
YANIV & ASSOCIATES, PC
972 Route 45, Suite 205, Pomona, New York 10970
(646) 395-9100
COMPLAINT
SUPERIOR COURT OF NEW JERSEY
UNION COUNTY
CHANCERY DIVISION-FAMILY PART
Docket No. FM-20-001178-26
The Plaintiff, by YANIV & ASSOCIATES, PC, complaining of the Defendant, states:
1. This action is brought by the Plaintiff, RAUL MARIO PASSEGGI, who at the time of the cause of action accrued was a bona fide resident of Union County, State of New Jersey, residing at 1 Gibson Place, Elizabeth, New Jersey 07208 and has ever since and for more than one year next preceding the commencement of this action, continues to be such bona fide resident.
2. The Defendant in this action is INDRANIE PASSEGGI, whose residence is unknown.
3. The Defendant is not in the military service of the United States, New Jersey or any other state or territory.
4. This court has jurisdiction to hear this action for divorce. The Plaintiff has resided in New Jersey for a continuous period of one year preceding the commencement of this action.
5. The Plaintiff and Defendant were lawfully married to each other on December 7, 1993, in the City of New York, the County of Kings, and the State of New York.
6. There is no minor child as a result of this marriage, and no child is expected. There are two adult children of the marriage, namely: Nina Passeggi, born on January 25, 2002 and Angela Passeggi, born on July 21, 1987.
7. The grounds for divorce are as follows: the parties have irreconcilable differences which have caused the breakdown of the marriage for six months and which make it appear that the marriage should be dissolved and that there is no reasonable prospect of reconciliation (New Jersey Revised Statutes, Title 2A, Chapter 34-2).
8. There have been no previous proceedings between the parties respecting the marriage or dissolution thereof or the support or maintenance of Plaintiff.
WHEREFORE, the Plaintiff prays that the Court issue a judgment dissolving the marriage between the parties to this action and granting the following relief:
a. Dissolving the marriage between the parties, pursuant to N.J.S.A. 2A:34-2(i);
b. Determining and fixing just, reasonable and proper support for the plaintiff and security by defendant for the payment of same;
c. Equitably distributing all property which was legally and/or beneficially acquired by the parties or either of them during the marriage;
d. Compelling defendant to pay plaintiff's counsel fees and costs; and
e. Granting plaintiff such further and additional relief as the Court may deem just and equitable.
Dated: January 29, 2026 /s/ Daniel Yaniv, Esq., Yaniv & Associates, PC
SUMMONS
RAUL MARIO PASSEGGI v INDRANIE PASSEGGI
SUPERIOR COURT OF NEW JERSEY
UNION COUNTY
CHANCERY DIVISION-FAMILY PART
Docket No. FM-20-001178-26
STATE OF NEW JERSEY, to the above-named Defendant: INDRANIE PASSEGGI
FROM THE STATE OF NEW JERSEY
TO THE DEFENDANT NAMED ABOVE:
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 of the 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 Union county within 35 days from the date you receive this summons, not counting the date you received it. (The address of each deputy clerk of the Superior Court is Superior Court, Civil Records Dept., Albender Building, 1st Fl. 1143-1145 E. Jersey St. Elizabeth, NJ 07201.) A filing fee payable to the Treasurer, State of New Jersey, 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 the 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 and completed Case Information Statement) if you want the court to consider your answer or motion. The Case Information Statement is available from the deputy clerk of the Superior Court or at www.judiciary.state.nj.us/prose/10482_fam_cis.pdf.
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 the lawsuit. 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 this case is pending at telephone number (201) 792-6363 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 the Lawyer Referral Services in the county where this case is pending at telephone number (201) 798-2727. A directory with contact information for all local Legal Service Offices and Lawyer Referral Services is available in the Civil Division Management Office of the county where this case is pending and online at www.judiciary.state.nj.us/prose/10153_deptyclerklawref.pdf.
Dated: April 9, 2026 /s/ Michelle M. Smith
Michelle M. Smith, Clerk
Name of Defendant to be served: INDRANIE PASSEGGI
Address of Defendant to be served: 809 Allen Street, Elizabeth, New Jersey 07202-2509
July 11 2026
LNYS0555243
$89.76