(Name of Plaintiff)
(Address)
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) / SUPERIOR COURT OF NEW JERSEY
CHANCERY DIVISION
Plaintiff / FAMILY PART, / COUNTY
vs. / CASE NO.
, / COMPLAINT FOR DIVORCE
Defendant
COMES, , Plaintiff, and files this Complaint for Divorce, and would state in support thereof the following:
1. This Court has jurisdiction of the parties and subject matter pursuant to New Jersey Statutes Annotated; Title 2A, Chapters 34-8 and 34-10.
2. Plaintiff would show that Plaintiff was an actual bona fide resident and domiciliary of County, New Jersey, at the time this cause of action arose and has ever since for more than twelve (12) months preceding the commencement of this suit continued to be such bona fide resident. Further, that Plaintiff is domiciled in, and is and has been an actual bona fide resident of New Jersey at the time of bringing such this suit.
3. The Parties were lawfully married on day of , 20 in
County, .
1. There are minor children of the Parties. (List all minor children below.)
Name Present Address Sex Date of Birth Soc. Sec. No.
I was a party or witness in the following case involving our child(ren) (provide all specifics including the state, the court, the case number, the type of case and the date of the child custody order, if any):
I know of the following court case that could affect our child(ren) (provide all specifics including the court, the case number, the type of case and the date of the child custody order, if any):
In addition to the parents, the following person/s claim custody, visitation or child support for our child(ren) (list names and addresses):
If our child(ren) has/have lived with someone other than a parent, the names and present addresses of the person(s) with whom our child(ren) has/have lived during the past five years is:
1. All matters involving custody/visitation and child support have been resolved and the terms agreed to in the Separation and Property Settlement Agreement mentioned below and attached hereto.
2. All matters involving property of the marriage, both real and personal, have been resolved, or will be resolved, and the terms agreed to in the Separation and Property Settlement Agreement mentioned below. All debts are likewise to be resolved by the parties in the separation agreement.
3. Both parties to the marriage are of legal age and are mentally competent.
4. From and after ______day of ______, 2____, and up to the present, irreconcilable differences have caused the breakdown of the marriage between Plaintiff and Defendant. Irreconcilable differences have existed between the Parties for six (6) months or more and make it appear that the marriage should be dissolved and is with no reasonable prospect of reconciliation, in compliance with New Jersey Statutes Annotated; Title 2A, Chapters 34--2. The parties therefore request a decree of divorce on the ground of irreconcilable differences of a period of six (6) months or more with no reasonable prospect of reconciliation.
5. The current residences of the Parties are as follows:
Husband: / Wife:Address: / Address:
Plaintiff resided at the following address when the cause of action arose:
.
1. Party does does not request restoration of my
former name, , pursuant to New Jersey Statutes Annotated; Title 2A, Chapters 34-21.
1. The Plaintiff further states the following: I do not know of any other cases in the State of New Jersey or any state or territory involving the same claim or subject matter as this case.
2. The Parties have executed, or intend to execute, a Separation and Property Settlement Agreement disposing of all jointly owned property and settling all jointly owed debts and rights and liabilities of the parties. If executed already, a copy of which is attached hereto as Exhibit "A".
WHEREFORE, Plaintiff, requests that:
a. The Court grant the Parties a Divorce on the ground of irreconcilable differences of a period of six (6) months or more without reasonable prospect of reconciliation, in accordance with New Jersey Statutes Annotated; Title 2A, Chapters 34--2;
b. That the Separation and Property Settlement Agreement disposing of all jointly owned property and settling all jointly owed debts and rights and liabilities of the parties as well as all custody/visitation and child support issues be incorporated into the final judgment of divorce;
c. Party, , requests that she be restored her maiden name of
, pursuant to New Jersey Statutes Annotated; Title 2A, Chapters 34-21.
a. That the Court will grant such other relief as deemed appropriate;
Respectfully submitted,
Signature of Plaintiff
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