SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
_____________________________________
Rasheed Abiaka,
Plaintiff
-against-
Lulu Mahinda Abiaka,
Defendants
Index No. 50309/2023
ANSWER TO ACTION FOR DIVORCE
FIRST Defendant herein, ADMITS the averments in the first paragraph of the
Complaint, and affirms that she is over the age of 18 years old.
SECOND Defendant ADMITS the averments in the second paragraph, and affirms that
Plaintiff has resided in New York State continuously for at least two years preceding this action.
THIRD Defendant ADMITS the averments in the third paragraph, and affirms that the
parties herein were married on March 18, 2000 in Brooklyn, Kings County, New York.
Defendant also affirms that the marriage was conducted by a clergyman, minister or by a leader
for the Society for Ethical Culture.
FOURTH Defendant DENIES the averments in the third paragraph that there are no
children of the marriage under the age of 21. On the contrary, Defendant asserts that there is one
child of the marriage. The child’s name is ______________, he was born on ____________. The
child is 21 years old, and is severely autistic. Defendant is the legal guardian and full-time
caregiver of the child.
Defendant admits that Plaintiff resides at 35 Midwood St, Brooklyn, NY 11225.
Defendant and the child reside at 119 County Hwy 38, East Worcester, NY 120 64.
FIFTH Defendant ADMITS the averments in the fifth paragraph, and admits that the
relationship between Plaintiff and Defendant has irretrievably broken down for at least six
months.
SIXTH Defendant DENIES the averments in the sixth paragraph that there is no other
divorce or matrimonial action between the parties. On the contrary, Defendant has filed for child
support modification in Kings County, NY. The case number is _______________. The next
hearing day for the matter is in May.
WHEREFORE Defendant demands the Court to consider the said assertions, and issue a
favorable judgment. Defendant also prays for any other relief that is just.
Dated: _________________
Respectfully submitted,
___________________________
Lulu Mahinda Abiaka
CERTIFICATE OF MAILING
I, LULU MAHINDA ABIAKA, certified on this ______day of March 2023, I deposited a
true copy of the above to the Plaintiff, by placing the documents with prepaid postage in the
United States mailbox address:
Rasheed Abiaka
35 Midwood St
Brooklyn, NY 11225
(718) 312-9451
___________________________
Lulu Mahinda Abiaka
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