Transcript
IN THE CHANCERY COURT OF STATE OF MISSISSIPPI IN THE MATTER OF THE DISSOLUTION OF MARRIAGE OF
AND
BY JOINT COMPLAINT
) ) ) ) ) ) ) ) ) ) )
COUNTY
CASE NO.
JOINT COMPLAINT FOR DIVORCE COMES NOW,
and
, Husband
and Wife, and file this Joint Complaint for Divorce and in support hereof would show unto the Court the following, to-wit: 1.
This Court has jurisdiction of the parties and subject matter pursuant to the laws of
the State of Mississippi. 2.
The Parties are actual and bona fide adult resident citizens of
County, Mississippi, and have been for more than six (6) months next preceding the filing of this Joint Complaint. 3. separated in 4.
The Parties were married on the County, Mississippi, on Since the date of said separation, the
day of day of day of
Parties have not cohabited as husband and wife. 5.
The present address of the Parties are as follows:
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, 20
, and , 20 , 20
. , the
6.
The Parties allege that they are entitled to a Divorce on the grounds of irreconcilable
differences. 7.
There is no reasonable expectation that the parties will reconcile.
8.
There are
9.
minor child(ren) of the marriage; namely, , born
day of
, 20
,
, born
day of
, 20
,
, born
day of
, 20
,
, born
day of
, 20
.
Neither party has participated, as a party, witness, or in any other capacity, in any
other litigation concerning the custody of the parties' minor children in Mississippi or any other state. 10.
Neither party has any knowledge of any custody proceeding concerning the parties'
minor children pending in a court of Mississippi or any other state. 11.
Neither party knows of a person not a party to this proceeding who has physical
custody of the parties' minor children or who claims to have custody or visitation rights with respect to the parties' minor children. 12.
All matters involving custody and support of the above named children have been
resolved and the terms agreed to in the Separation and Property Settlement Agreement attached herein as Exhibit “A”. 13.
All matters involving property of the marriage, both real and personal, have been
resolved and the terms agreed to in the Separation and Property Settlement Agreement. All debts have likewise been resolved by the parties in the Separation and Property Settlement Agreement attached herein as Exhibit “A”. 14.
Party
, requests that her former name of be restored unto her. This request is not made for any illegal or
fraudulent reason. -2-
15.
The Parties further state the following: We do not know of any other cases in the State of Mississippi or any other state or territory involving the same claim or subject matter as this case. OR We know of the following related cases concerning the same claim or subject matter as this case.
WHEREFORE, PREMISES CONSIDERED,
and
pray that: (A)
The Court grant the parties a Divorce on the grounds of irreconcilable differences;
(B)
That the terms of the Separation and Property Settlement Agreement in which all
issues of custody and support of the children of the marriage are resolved and which disposes of all jointly owned property and settling all jointly owed debts and rights and liabilities of the parties, a copy of which is attached hereto as Exhibit “A”, be incorporated into the final judgement of divorce: (C)
For judgment and relief as set forth in this Complaint.
(D)
For such other relief and judgment as is just and equitable in the premises
Respectfully submitted, Husband’s Printed Name Husband’s Signature Wife’s Printed Name Wife’s Signature
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STATE OF MISSISSIPPI COUNTY OF PERSONALLY appeared before me, the undersigned authority in and for the county and state aforesaid, the within named,
, one of the
Co-Plaintiffs, who, being by me first duly sworn, stated on oath that the matters, facts and averments set forth, contained and alleged in the above and foregoing Joint Complaint for Divorce are true and correct as therein stated.
Signature: Print Name: SWORN TO AND SUBSCRIBED this the
day of
, 20
.
____________________________________ NOTARY PUBLIC MY COMMISSION EXPIRES:
STATE OF MISSISSIPPI COUNTY OF PERSONALLY appeared before me, the undersigned authority in and for the county and state aforesaid, the within named,
, one of the
Co-Plaintiffs, who, being by me first duly sworn, stated on oath that the matters, facts and averments set forth, contained and alleged in the above and foregoing Joint Complaint for Divorce are true and correct as therein stated.
Signature: Print Name: SWORN TO AND SUBSCRIBED this the
day of
, 20
.
____________________________________ NOTARY PUBLIC MY COMMISSION EXPIRES:
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