Fink v. Goldblatt

This is a motion for leave to serve an amended answer by adding affirmative defenses and to dismiss the amended complaint for lack of jurisdiction of the subject of the action or to dismiss for legal insufficiency.

The amended complaint seeks to rescind a separation agreement which provides for support of two children in defendant wife’s custody. The answer consists of a general denial of the material allegations of the complaint. The proposed amended answer seeks to add affirmative defenses of a Mexican divorce decree by due process and the incorporation therein of the separation agreement,…