SECOND JUDICIAL DISTRICT COURT
STATE OF NEW MEXICO
COUNTY OF BERNALILLO
NO.2011-04188
BETTY JO MENGER,
Petitioner,
v.
CARL S. MENGER, III
Respondent.
VERIFIED PETITION FOR DISSOLUTION OF MARRIAGE
COMES NOW Petitioner, by and through counsel, Rudolph B. Chavez, and states:
1. The parties have, or at least one of them has, resided in theCountyofBernalillo, State ofNew Mexico, for at least six months prior to the filing of this petition.
2. The parties were married on August 30, 2008, in the State ofTexas, and have been husband and wife since that time.
3. There has been no child born of this marriage and none are expected.
4. Due to differences in temperament and outlook the Petitioner and Respondent have not been able to live together harmoniously, and state of irreconcilable incompatibility exists between them.
5. The Petitioner has acquired certain separate estate and property which should be awarded to Petitioner. The Respondent has acquired certain separate estate and property which should be awarded to Respondent. The parties have acquired no property by the community of their marriage.
6. The parties have incurred certain community obligations which should be allocated between them (Tax Debt of $3,000).
7. The Respondent is an able bodied person capable of being self supporting.
WHEREFORE, Petitioner prays that the Court:
A. Dissolve the marriage between the parties on the grounds of incompatibility;
B. Ascertain and allocate the separate and community estate and property of the respective parties;
C. Allocate responsibility for the parties’ outstanding community obligations;
D. Waive the thirty day waiting period in this cause;
E. Award such other and further relief as the Court may deem just and proper.
Respectfully submitted by:
/s/ Rudolph B. Chavez
RUDOLPH B. CHAVEZ
Attorney for Petitioner
2014 Central Ave.SW
Albuquerque,NM87104
(505) 242-5500
HCS Pub. December 16, 23, 30, 2011
