Filing # 201226445 E-Filed 06/24/2024 05:10:50 PM

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL

CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA

FAMILY DIVISON
VANESSA GARCIA AZZAM,
CASE NO.: 2024-001692-FC-04
PETITIONER/WIFE,

AND

ALEJANDRO MANUEL DIAZ DE LA PORTILLA,

RESPONDENT/HUSBAND. /

ANSWER TO PETITION FOR DISSOLUTION OF MARRIAGE

AND COUNTER PETITION FOR DISSOLUTION OF MARRIAGE

COMES NOW the Respondent/Husband in the above-styled case, ALEJANDRO

MANUEL DIAZ DE LA PORTILLA, files his Answer to the Petition for Dissolution of Marriage,

and responds to each paragraph as follows:

1. Respondent admits the allegations in Paragraph 1 of the Petition.

2. Respondent admits the allegations in Paragraph 2 of the Petition.

3. Respondent admits the allegations in Paragraph 3 of the Petition.

4. Respondent admits the allegations in Paragraph 4 of the Petition.

5. Respondent admits the allegations in Paragraph 5 of the Petition

6. Respondent admits the allegations in Paragraph 6 of the Petition.

7. Respondent admits the allegations in Paragraph 7 of the Petition.

8. Respondent admits the allegations in Paragraph 8 of the Petition.

9. Respondent denies the allegations in Paragraph 9 of the Petition. Contrary to

Petitioner’s sworn statement in the Petition for Dissolution of Marriage, the parties

did acquire marital assets and marital liabilities during the course of the marriage

that must be equitably distributed.

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 10. Respondent denies the allegations in Paragraph 10 of the Petition.

11. Any Paragraph not specifically addressed is hereby denied.

COUNTER PETITION FOR DISSOLUTION OF MARRIAGE

1. NATURE OF ACTION This is an action for dissolution of marriage between

ALEJANDRO MANUEL DIAZ DE LA PORTILLA, Counter Petitioner/Husband (hereinafter

referred to as “Husband”) and VANESSA GARCIA AZZAM, Counter Respondent/Wife

(hereinafter referred to as “Wife”).

2. JURISDICTION AND VENUE Both parties have resided in the State of Florida

for at least six months prior to filing this Counter Petition. Venue is proper in this Circuit because

Miami-Dade County is where the intact marriage of the parties was last evidenced by a

continuing union and by the intent to remain here and married to each other.

3. NON-MILITARY STATUS Both parties are over the age of eighteen years and

neither party is, nor has been within the thirty-day period immediately prior to this date, enlisted

in the military service of the United States of America as defined by the Servicemembers Civil

Relief Act of 2003.

4. MARRIAGE OF THE PARTIES The Husband and Wife were married to each

other on May 19, 2023.

5. GROUNDS FOR DISSOLUTION The marriage between the parties is

irretrievably broken.

6. MINOR OR DEPENDENT CHILDREN There are no minor or dependent

children common to both parties. The Wife is not pregnant with a child common to both parties.

7. EQUITABLE DISTRIBUTION There are marital assets subject to equitable

distribution including, but not limited to: jewelry, designer clothing, shoes and accessories,

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electronics, household goods and furnishings, bank accounts, and retirement accounts. There

are marital liabilities subject to equitable distribution including, but not limited to: revolving

charge accounts and lease agreements. The Court must set apart to each spouse that spouse’s

nonmarital assets and liabilities and must equitably distribute all marital assets and liabilities

under Florida Statute §61.075.

8. ATTORNEYS’ FEES AND COSTS As a result of participating in this action,

the Husband has been required to retain the services of the undersigned attorney to represent

him and has agreed to pay his attorney a reasonable fee. The Husband has the need for, and

the Wife has the ability to pay Husband’s attorneys’ fees, expert witness fees, suit money and

costs. Pursuant to Florida Statute §61.16, Rosen v. Rosen, (Fla. 1997), Moakley v. Smallwood,

730 So.2d 286 (Fla. 3d DCA 1999) and other applicable case law, the Husband is entitled to

an award of attorneys’ fees, expert witness fees, suit money and costs, both temporarily and

permanently, especially if the Wife engages in unnecessary litigation.

WHEREFORE, the Counter Petitioner/Husband, Alejandro Manuel Diaz de la Portilla,

demands a judgment dissolving the parties’ marriage, equitably distributing all marital assets

and marital liabilities, awarding attorneys’ fees, expert witness fees, suit money and costs,

granting further relief consistent with this Counter Petition and granting such other relief as this

Honorable Court deems just and necessary.

I understand that I am swearing or affirming under oath to the truthfulness of the claims

made in this Counter Petition and that the punishment for knowingly making a false statement

includes fines and/or imprisonment.

Dated: June 24, 2024

Alejandro Manuel Diaz de la Portilla

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 CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing was served via the Florida

Court’s E-Filing Portal on the person below on June 24, 2024.

Maria E. Medel, Esq., Attorney for Petitioner, mariaemedel@hotmail.com

/s/ Yulema Figueroa, Esq.

YULEMA FIGUEROA, PLLC
Attorney for the Respondent
8660 W. Flagler Street Ste. 203
Miami, Florida 33144
Telephone: (305) 552-9600
E-mail: figueroalaw@aol.com
Florida Bar No. 109843