IN THE CHANCERY COURT OF COUNTY, MISSISSIPPI
IN THE MATTER OF THE DISSOLUTION
OF THE MARRIAGE OF
AND
CO-PLAINTIFFS NO.
JOINT COMPLAINT FOR DIVORCE
COMES NOW and , Co-Plaintiffs, and file this their Joint Complaint for
Divorce, and would respectfully show unto the Court the following:
I.
Co-Plaintiff resides at ; both parties are adult residents citizens of
County, Mississippi, bona fide residents of the State of Mississippi, and have been for more than
six (6) months next preceding the filing of this Joint Complaint for Divorce.
II.
Both Co-Plaintiffs are members of the race.
III.
The parties were married on . child(ren) has/have been born to this
marriage; namely, , born and , born . Both parties are fit and proper
persons to have the permanent care, control and custody of the minor child(ren) of the parties,
but said minor child(ren) shall reside with the father/mother with reasonable visitation with the
father/mother .
IV.
The parties were separated in and have not cohabited as man and wife since said
separation.
V.
Co-Plaintiffs would show that they are entitled to a divorce on the grounds of
irreconcilable differences.
VI.
Co-Plaintiffs have executed a Separation and Child Custody and Property Settlement
Agreement disposing 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".
VII.
That in the event that a Judgment of Divorce is granted to these parties, they will keep
each other informed of their respective addresses, including state, city, street, house number and
telephone number (if available); that the parties shall within five days of either changing their
address, so long as their child(ren) is/are a minor(s), notify the Clerk of this Court of his/her new
address in writing, including therein the file number of this action, and he/she shall furnish the
other party a copy of such notice.
WHEREFORE, PREMISES CONSIDERED, Co-Plaintiffs pray that this their Joint
Complaint for Divorce be received and filed, and that the Court will enter a Judgment granting
the Co-Plaintiffs the following relief:
a. Awarding Co-Plaintiffs a divorce absolute;
b. The Separation and Child Custody and Property Settlement Agreement attached
hereto as Exhibit "A" be made a part of the Final Judgment.
Co-Plaintiffs pray for general relief.
____________________________________
____________________________________
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.
____________________________________
SWORN TO AND SUBSCRIBED this the day of , .
_____________________________________
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 , on 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 and therein stated.
____________________________________
SWORN TO AND SUBSCRIBED this the day of , .
___________________________________
NOTARY PUBLIC
MY COMMISSION EXPIRES:
_______________________
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