STATE OF NEW MEXICO
COUNTY OF BERNALILLO
SECOND JUDICIAL DISTRICT
No.D-202-DM-2017-01298
STEFANIE L. BOSTIAN,
Petitioner,
vs.
DAVID C. BOSTIAN,
Respondent.
VERIFIED PETITION FOR DISSOLUTION OF MARRIAGE
COMES NOW Petitioner, Stefanie L. Bostian, by and through her counsel of record, NEW MEXICO LEGAL GROUP, P.C. (Jessica C. Roth, Esq.) and hereby petitions the Court for the Dissolution of her Marriage to David C. Bostian. In doing so, Petitioner states the following:
1. Petitioner has been a resident of the State of New Mexico for six months immediately preceding the filing of this Petition.
2. The parties were married on November 25, 2003 in Albuquerque, New Mexico and since that time have remained husband and wife.
3. A state of incompatibility exists between the parties, because of discord and conflict of personalities, destroying the legitimate ends of the marital relationship and preventing reasonable expectation of reconciliation.
4. There are three minor children of the marriage, namely Jaden Bostian, born April 2004, now age 13 years old; Emma Bostian, born April 2007, now age 9; and Alys Bostian, born December 2010, now age 6.
5. The parties are fit and proper parents to share joint legal custody of the minor children with Petitioner having primary physical custody and an appropriate
timesharing plan with Respondent as in the best interest of the minor children.
6. Child support should be set according to the New Mexico Child Support Guidelines.
7. Petitioner has not participated as a party, witness or in any other capacity in any other litigation concerning the custody of the children in New Mexico or any other state.
8. Petitioner has no information of any custody proceeding concerning the children pending in New Mexico or any other state.
9. Petitioner knows of no person not a party to these proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children.
10. The parties have accumulated community property and community debt throughout the course of their marriage which should be equitably divided.
11. Any separate property should be ratified as the separate property of the party owning such property.
12. Petitioner desires to change her name to Stefanie Linn Gordon.
WHEREFORE, Petitioner respectfully requests the following relief:
A. For a Decree of Dissolution of Marriage;
B. Award the Parties joint legal custody of the minor children with Petitioner having primary physical custody and an appropriate timesharing plan with Respondent as in the best interest of the minor children.
C. For child support m accordance with New Mexico Child Support Guidelines;
D. For an Order equitably dividing the community property and community debts of the parties;
E. For an order ratifying any separate property and separate debts to the party owning such property or owing such debts;
F. For Petitioner’s costs and attorney’s fees incurred herein;
G. For an order allowing Petitioner to change her name to Stefanie Linn Gordon; and
H. For such other and further relief as to this Court may seem just and proper.
Respectfully submitted,
NEW MEXICO LEGAL GROUP, PC
By:/s/ Jessica C. Roth
Jessica C. Roth, Esq.
Attorney for Petitioner
2701 Arizona St. NE
Albuquerque,NM 87110
(505) 843-7303
VERIFICATION
STATE OF NEW MEXICO )
COUNTY OF BERNALILLO)ss.
STEFANIE BOSTIAN, being first duly sworn upon oath, deposes and states: that Petitioner has read, knows and understands the contents of the foregoing Petition and that the statements herein made are true of Petitioner ‘s own knowledge and belief.
That the Petitioner understands the Petitioner is bound by the Temporary Domestic Order at the time the Petition is filed, and Petitioner understands the contents of the Temporary Domestic Order.
/s/ Stefanie Bostian
STEFANIE BOSTIAN, Petitioner
Subscribed and sworn to before me this 25th day of April, 2017.
/s/ Esther Peterson
Notary Public
My commission expires: November 17, 2020
Official Seal
ESTHER PETERSON
Notary Public
State of New Mexico
My Commission Expires 11/17/20
HCS Pub. May 20, 27, June 3, 2022
