Fill and Sign the Motion to Dismiss Complaint and Request for Hearing Form

IN THE CIRCUIT COURT OF _____________________ COUNTY, ALABAMAFIELD(l), )PLAINTIFF, )CIVIL ACTION NUMBERV. )FIELD(3)FIELD(2), )DEFENDANT.) COMPLAINT Plaintiff, FIELD(l), represents and shows unto Your Honors as follows: 1. That Plaintiff is over the age of nineteen (19) years and has been a bona fide resident citizen of the State of Alabama for more than six (6) months next preceding the filing of this Complaint for divorce. The Defendant is over the age of nineteen (19) years and has been a bona fide resident citizen of the State of Alabama for more than six (6) months next preceding the filing of this Complaint for divorce.2. Plaintiff and Defendant were married on FIELD(4), and they have lived together as husband and wife until, to-wit, FIELD(5), after which time they separated and have not lived together as husband and wife. 3. That there FIELD(6) born during this marriage, namely FIELD(7). is not pregnant. 4. Plaintiff states that there is a complete incompatibility of temperament such that the Plaintiff and Defendant can no longer live together. Plaintiff states that there has been an irretrievable breakdown of the marriage and that further attempts at reconciliation are impractical or futile and not in the best interests of the parties. 5. Plaintiff states that the Plaintiff and Defendant have accumulated, during the marriage of the parties, an interest in or title to certain properties including cash, FIELD(8), furniture, furnishings, automobiles, and other property. 6. Plaintiff states that the Plaintiff and Defendant have incurred certain debts during the marriage of the parties. 7. Plaintiff states that she is without sufficient funds with which to pay her attorney of record. WHEREFORE, PREMISES CONSIDERED, the Plaintiff prays that this Honorable Court will enter a Final Judgment granting therein relief to the Plaintiff as follows: a. By divorcing the parties each from the other; b. By entering an order awarding custody of the children and child support to her; c. By ordering a fair and equitable division of all property acquired by the parties during the marriage; d. By ordering a fair and equitable division of the debts incurred during the marriage of the parties; e. By ordering a fair amount to be paid to her by Defendant for alimony; and, f. By awarding a sufficient sum to be paid to her by Defendant with which to pay her attorneys of record. g.By granting to the Plaintiff such other, further and general relief as to which in equity and good conscience she may be entitled. ______________________________ FIELD(9) Attorney for Plaintiff (Address) (Telephone) PLAINTIFF'S ADDRESS: DEFENDANT'S ADDRESS: