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Fill and Sign the Annulment 497319454 Form

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______________________ ______________________ ______________________ Attorney for Plaintiff _______________________, Plaintiff, vs. ______________________, Defendant. SUPERIOR COURT OF NEW JERSEY [Insert] COUNTY CHANCERY DIVISION - FAMILY PART DOCKET NO.: CIVIL ACTION VERIFIED COMPLAINT FOR ANNULMENT Plaintiff, _________________, residing at [insert address], [insert County] County, New Jersey, by way of verified complaint, says: FIRST COUNT 3544. The plaintiff was a bona fide resident of the State of [insert State] at the time of the commencement of this action. 3545. The defendant resides at [insert address], County of [insert County], State of [insert State]. Upon information and belief he has always been a resident of the State of [insert State] and as of the filing of this complaint he continues to be a resident. 3546. On the [insert date] day of [insert month], [insert year], a form of ceremony of marriage took place between the plaintiff and the defendant in [insert City and State], in a civil ceremony performed by the Honorable [insert judge]. Appended hereto as Exhibit 1 is a true copy of the parties = marriage certificate evidencing said ceremony. 3547. No children were born of the purported marriage between the plaintiff and the defendant. 3548. When the ceremony of marriage between the plaintiff and the defendant was performed the plaintiff was ignorant of the facts set forth below and believed the defendant had been forthright in disclosing his intentions, beliefs, and wishes to the plaintiff before their wedding ceremony, to wit; rrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrr. The defendant concealed his belief that he would enter into a loving marriage and be faithful to the plaintiff and instead, the defendant proclaimed B immediately following his marriage to the plaintiff B that he was incapable of fidelity and that he believed in infidelity and in fact, the defendant confessed to the plaintiff just after their marriage that he was emotionally involved with another woman; ssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssssss. The defendant concealed his intention not to reside and cohabitate with the plaintiff such that following the marriage the defendant, after repeated requests by the plaintiff to cohabitate with her, refused to, and has never, cohabitated as husband and wife thus causing a great shock to the plaintiff; tttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttt. The defendant concealed his marriage to the plaintiff from co-workers causing her anguish and distress; uuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuu. Immediately following the marriage the plaintiff repeatedly asked to see and spend time with the defendant who refused to spend any substantial time with the defendant; and vvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvvv. Contrary to the plaintiff = s expectations and much to her shock, immediately after the marriage, feeling things were not right between the parties, the plaintiff repeatedly suggested counseling and other options to the defendant to try to salvage the marriage however, the defendant told the plaintiff that the marriage was A over @ and that he A thought for a long time @ that the marriage would not work indicating his belief that he entered into a marriage which he believed would fail even before it began. 6. Because the defendant never disclosed, prior to the marriage, his true intentions and instead misrepresented his true intentions he acted contrary to what the plaintiff reasonably believed when she agreed to marry him and as such the defendant acted fraudulently in contravention to N.J.S.A. 2A:34-1(d). 7. The actions of the defendant also evince a lack of mutual assent to the marital relationship in contravention to N.J.S.A. 2A:34-1(d). 8. Additionally, the actions of the defendant evince fraud as to the essentials of the marriage in contravention to N.J.S.A. 2A:34-1(d). 9. There have been no previous matrimonial actions between the parties. 10. In this action the plaintiff is not seeking any award of alimony nor is their any property of the parties which must be divided or apportioned. 11. Neither party has subsequently ratified the marriage in accordance with N.J.S.A. 2A:34- 1(d). WHEREFORE, plaintiff demands judgment: A. Declaring and adjudging the purported marriage between the parties to be null and void and annulled as per N.J.S.A. 2A:34-1; and B. For such further relief as the court may deem just and equitable. Dated __________________________ Attorneys for Plaintiff VERIFICATION 1. I am the plaintiff in the foregoing complaint. 2. I have read the complaint and the allegations made therein are true to the best of my knowledge, information and belief. The said complaint is made in truth and good faith and without collusion for the causes set forth therein. 3. The matter in controversy in the within action is not the subject of any other action pending in any court or a pending arbitration proceeding, nor is any such court action or arbitration proceeding presently contemplated. There are no other persons who should be joined in this action at this time. 4. I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. Dated: _______________________ Client

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