Fill and Sign the Allegations Petition Form

_______________ : _______ JUDICIAL DISTRICT COURT VS : PARISH OF _______ , LOUISIANA _______________ : DOCKET NO. ____ ______________________________________________________________________________ ANSWER AND RECONVENTIONAL DEMAND NOW INTO COURT, through undersigned counsel, comes _______________ , who, in answer to Plaintiff's petition for divorce, respectfully represents that: l. The allegations of Paragraph 1 of the petition for divorce are admitted. 2. The allegations of Paragraph 2 of the petition for divorce are admitted. 3. The allegations of Paragraph 3 of the petition for divorce are admitted. 4. The allegations of Paragraph 4 of the petition for divorce are admitted. 5. The allegations of Paragraph 5 of the petition for divorce are denied. 6. The allegations of Paragraph 6 of the petition for divorce are denied. 7. The allegations of Paragraph 7 of the petition for divorce are denied. 8. The allegations of Paragraph 8 of the petition for divorce are denied. 9. The allegations of Paragraph 9 of the petition for divorce are denied. 10. The allegations of Paragraph 10 of the petition for divorce are denied. 11. The allegations of Paragraph 11 of the petition for divorce are denied. 12. The allegations of Paragraph 12 of the petition for divorce are denied. 13. The allegations of Paragraph 13 of the petition for divorce are denied. 14. The allegations of Paragraph 14 of the petition for divorce are denied. AND NOW ASSUMING the position of Plaintiff in reconvention, _______________ respectfully represents that: I. Defendant in reconvention has engaged in extramarital affairs, during the marriage between Plaintiff and Defendant. II. Because of the Defendant = s adultery, Petitioner desires a divorce from the Defendant, pursuant to Civil Code Article 103-2. III Two (2) children were born between Plaintiff and Defendant, namely, _______________ and _______________ , both minors, who are presently in the care, custody and control of the Plaintiff in reconvention, _______________ , and your Plaintiff in reconvention avers that it would be in the best interest of the minor children that their custody be awarded jointly to Plaintiff and Defendant, with residency of said children to be with Plaintiff in reconvention, _______________ , subject to Defendant = s rights of reasonable visitation to be determined by this Honorable Court. IV. Plaintiff in reconvention is currently occupying and desires the exclusive use and occupancy of the community home located at _______________ , Louisiana ____ , and use of the community movables located therein, pending the dissolution of the community properties. V. Some community property was acquired during the existence of this marriage, and Plaintiff in reconvention desires to be recognized as the owner of an undivided one-half (l/2) interest in and to said property, reserving unto him the right to seek a judicial or extra-judicial partition thereof at any time in the future. VI. Since irreparable injury, loss or damage may otherwise result, to protect plaintiff in reconvention = s interest in the community property, it is necessary that both an injunction and a preliminary injunction be issued herein, enjoining the defendant in reconvention from disposing of, alienating or encumbering any of the community property. Unless restrained from doing so, the defendant in reconvention will dispose of, alienate or encumber some or all of the community property before notice can be served and a hearing had on the application for a preliminary injunction, resulting in immediate and irreparable injury, loss or damage to petitioner and defendant; hence, it is necessary that a temporary restraining order be issued immediately in the form and substance of the injunction and the preliminary injunctions mentioned above. WHEREFORE, plaintiff in reconvention, _______________ , pray that there be judgment herein in favor of plaintiff in reconvention, _______________ , decreeing a divorce a vinculo matrimonii, pursuant to Civil Code Article 103-2, adultery, dissolving the bonds of matrimony heretofore existing between them. Plaintiff in reconvention further prays that defendant in reconvention, _______________ , be ordered to show cause on the ____ day of ___________ 20 ____ , at ______ o = clock ___.M. why Judgment should not be rendered in favor of plaintiff in reconvention pursuant to Civil Code Article 103-2, adultery, as follows: 1. Joint custody should not be awarded to plaintiff and defendant, with residency of the minor children to be with plaintiff in reconvention, with defendant in reconvention being granted reasonable visitation rights. 2. Plaintiff in reconvention should not be granted the exclusive use and occupancy of the community home located at _______________ , Louisiana ____ , and the community movables located therein, pending the dissolution of the community properties. Respectfully Submitted: ____________________________ _______________ _______________ _______ , LA ____ ( ____ ) _______ La. Bar Roll No. ____ Attorney for Defendant Please serve defendant in reconvention through her counsel of record: _______________ _______________ _______ , LA ____ _______________ : _______ JUDICIAL DISTRICT COURT VS : PARISH OF _______ , LOUISIANA _______________ : DOCKET NO. ____ ______________________________________________________________________________ ORDER Considering the foregoing Pleadings: IT IS ORDERED that Judgment be rendered herein against defendant in reconvention and in favor of plaintiff in reconvention, decreeing a divorce between the parties, pursuant to Civil Code Article 103-2, adultery, and condemning Defendant to pay all costs of these proceedings. IT IS FURTHER ORDERED that Plaintiff, _______________ , be ordered to show cause on ________________, 20 ____ , at _________ o = clock ___.M. why Judgment should not be rendered in favor of plaintiff in reconvention and against defendant in reconvention, pursuant to Civil Code Article 103-2, adultery, as follows: 1. Joint custody should not be awarded to plaintiff and defendant, with residency of the minor children to be with plaintiff in reconvention, with defendant in reconvention being granted reasonable visitation rights. 2. Plaintiff in reconvention should not be granted the exclusive use and occupancy of the community home located at _______________ , _______________ , Louisiana ____ , and the community movables located therein, pending the dissolution of the community properties. SIGNED this _____ day of ________________, 20 ____ , at __________________, Louisiana. ____________________________ DISTRICT JUDGE