Fill and Sign the Form Irreconcilable Differences Complaint

IN THE CHANCERY COURT OF ________________________________COUNTY STATE OF MISSISSIPPI _______________________________________________ PLAINTIFF (Name of Plaintiff) VS. CAUSE NO._____________ ________________________________________________ DEFENDANT (Name of Defendant) Motion for Blood Tests in Order to Help Determine Paternity Comes now ________________________________________________________ (Name of Plaintiff), Plaintiff, in the above-captioned cause, by and through her attorney, and moves this Court for an order, pursuant to Section 93-9-21(2) of the Mississippi Code of 1972, as amended, requiring the parties and the child to submit to a physical examination for the purpose of ascertaining blood type and blood subtypes, so as to assist the Court in determining the paternity of the said child by comparison of blood types. I. Plaintiff is the Mother of the child who is the subject of the action and would show that there is a controversy between Plaintiff and Defendant as to the paternity of the said child. II. The names of the parties are as follows: A. Defendant’s name is ___________________________________________ (Name of Defendant). B. Plaintiff’s name is ____________________________________________ (Name of Plaintiff. C. The name of the child is ________________________________________ (Name of Child).
(name of parties) the action is against defendant and is commenced in the said state court of Jackson County. I1. The parties are represented by and . In accordance with section 9-3-19 of the Mississippi code of 1972, as amended, the plaintiff requests an order entered directing the parties to submit to a physical examination for the purpose of ascertaining the blood type and blood subtypes, to assist in determining the paternity of the child by comparison of blood types. I3. The issue of liability was raised by the plaintiff in the action by and through her attorney wherein the issue of liability was raised by the plaintiff in the action by and through her attorney wherein the issue of negligence was raised by the plaintiff by and through her attorney as to the defendants and cause defendant to pay a judgment to the plaintiff as follows: (1) in the case of defendant, and/or defendant's employer/agent/witnesses. (2) in the case of plaintiff, and/or plaintiff's spouse. (3) in the case of defendant's employer/agent, as defined in section 4 of the labor code, Mississippi code of 1972; and (4) in the case of defendant's spouse, as defined in section 6(d)(i) and (ii) of the labor code; and (5) in the case of defendant, and, respectively, plaintiff's employer/agent, as defined in section 4 of the labor code; and (6) in the case of defendant, and, or plaintiff's spouse, as defined in section 6(d) of the labor code. I. Defendant is an employee of defendant's employer, and/or an agent for defendant's employer, and/or a witness for defendant's employer; and (1) plaintiff's employer, agent, witness, or witness agent is a . (2) plaintiff's employer, witness, or witness agent has committed negligence which created the situation where plaintiff lost the child. (ii) the plaintiff's legal representative is. (iii) the plaintiff is the mother of the child who is the subject of the action and would show that there is a controversy between plaintiff and defendant as to the paternity of the said child. (iv) the name of the party is. (4) the blood type of the child is . (5) the child was not born during the year preceding the incident which caused the loss