Legal Defense Against Divorce Petition

Answer to Complaint

I, Ismael Cordova Conde, by my own right, designating as my address for receiving notifications House West Fourth Street 345, this city, respectfully appear before you to state:

Being within the prescribed period, I hereby answer the complaint filed against me as follows:

• I deny the plaintiff's right to demand the dissolution of the marriage bond that unites us.
• I deny the plaintiff's right to demand payment of the expenses and costs of this lawsuit.

I base this response on the facts and legal grounds detailed below:

Facts of the Case

1. It is true that the plaintiff and the undersigned were married on the date specified by the applicant, under the regime of conjugal partnership.
2. It is true that the matrimonial home is located at the address stated by the plaintiff.
3. It is not true that the undersigned has left the conjugal home for more than six months without justified reason. Therefore, the undersigned has not caused the grounds for divorce provided by Section VIII of Article 267 of the Civil Code.

Exceptions and Defenses

I hereby present the following exceptions and defenses:

1. I oppose any defense that arises from the answer I have provided to the issues of fact and law presented in the demand.
2. The plaintiff lacks legal grounds to claim divorce, as I have always lived in the marital home, which I have never abandoned, contrary to what the plaintiff alleges in this lawsuit. I can fully substantiate this with oral evidence.

Evidence Offered

I offer the following evidence, linking it with each and every one of the issues of fact contained in the preface of this reply, and with the issues of fact contained in the chapter on exceptions and defenses:

• Judicial Confession: The plaintiff, regarding the positions articulated on the day and time set for the verification of this proof, having been duly summoned, requesting that his confession be declared admitted if he fails to attend without just cause.
• Testimonial Evidence: From Doctors Enrique Romero, Soledad Sago, Freud, and Portet, who will appear on the day and time set for the reception of this evidence.
• Instrumental Evidence: All actions favoring the interests of the undersigned.
• Presumptive Evidence: Legal and human presumptions, in the terms stated above.

Request to the Court

To the Honorable Judge, I respectfully request:

1. To consider me as having presented this written answer in due time, along with the demand and opposing exceptions and defenses to which I refer.
2. To accept, admit, and manage the evidence mentioned herein.
3. To issue a final judgment resolving that the undersigned continue with the marriage bond, as there are no circumstances justifying its termination.

Formal Declaration

PROTEST AS REQUIRED.

Tuxtla Gutiérrez, Chiapas, September 4, 2003.