Summons and Complaint for Divorce

Summons and Complaint for Divorce Superior Court of New Jersey Atlantic County Chancery Division - Family Part Heather Ashley Migliaccio v. James John Migliaccio, Jr. Docket No. FM-01-246-24 SUMMONS TO: James John Migliaccio, Jr. Address Unknown From the State of New Jersey To the Defendant, James John Migliaccio, Jr. Plaintiff, Heather Ashley Migliaccio, has filed a Complaint for Divorce against you in the Superior Court of New Jersey, Chancery Division, Family Part, Atlantic County. The Complaint states the basis for the divorce action. If you dispute this complaint, you or your attorney must file a written answer or motion and proof of service with the clerk of the family part in Atlantic County within 35 days from the date you received this summons, not counting the date you received it. The address for the clerk of the family part in Atlantic County is Direct Filing, Family Part, Superior Court of New Jersey, Atlantic County Civil Courthouse, 1201 Bacharach Boulevard, Atlantic City, New Jersey 08401. A filing fee in the amount of $175.00 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 below. A telephone call will not protect your rights; you must file and serve a written answer or motion (with fee of $175.00) 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 judgment against you for the relief Plaintiff demands. 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 Atlantic County and online at http://www.njcourts.gov. COMPLAINT The Plaintiff, Heather Ashley Migliaccio, residing at 4704 Summersweet Drive, in the Township of Hamilton (Mays Landing), County of Atlantic and State of New Jersey, by way of complaint, says: FIRST COUNT - IRRECONCILABLE DIFFERENCES 1. She as lawfully married to the Defendant, JAMES JOHN MIGLIACCIO, JR., on June 29, 2020, in a civil ceremony performed in Las Vegas, Nevada. 2. The Plaintiffs was bona fide resident of the State of New Jersey when this cause of action arose and has ever since and for more than one (1) year next preceding the commencement of this action continued to be such a bona fide resident. 3. To the best of Plaintiff's knowledge, information and belief, the Defendant currently resides at 111 Twin Oaks Road, Lake Charles, Louisiana 70607. 4. Irreconcilable differencees between the parties have caused the breakdown of the marriage for a period of six months prior to the filing of the within complaint. 5. There is no reasonable prospect of reconciliation between the parties. 6. At the time the cause of action for divorce arose, Plaintiff resided at 4704 Summersweet Drive, in the Township of Hamilton (Mays Landing), County of Atlantic and State of New Jersey. 7. The parties do not have any children together and none are expected. 8. This is Plaintiff's first marriage. 9. To the best of Plaintiff's knowledge, information and belief, this is the Defendant's first marriage. 10. There has been no previous proceedings between the plaintiff and the defendant respecting the marriage or its dissolution or respecting the maintenance of either party. WHEREFORE, Plaintiff demands judgment: (a) Dissolving the marriage between the parties pursuant to N.J.S.A. 2A:34-2; (b) For leave of court allowing Plaintiff to resume her birth name of Heather Ashley Smith. (c) For such other relief as the court deems equitable and just. Robert A. Loefflad, Esquire KingBarnes, LLC 2600 New Road Northfield, New Jersey 08225 Tel (609) 522-7530 Email: rloefflad@kingbarnes.com COMPLAINT December 10,17,24,31 2025 LSAR0421111