New Jersey Divorce Complaint

Complaint for Divorce

COMES, , Plaintiff, and files this Complaint for Divorce, and would state in support thereof the following:

1. This Court has jurisdiction of the parties and subject matter pursuant to New Jersey Statutes Annotated; Title 2A, Chapters 34-8 and 34-10.

2. Plaintiff would show that Plaintiff was an actual bona fide resident and domiciliary of County, New Jersey, at the time this cause of action arose and has ever since for more that twelve (12) months preceding the commencement of this suit continued to be such bona fide resident. Further, that Plaintiff is domiciled in, and is and has been an actual bona fide resident of New Jersey at the time of bringing such this suit.

3. The Parties were lawfully married on day of , 20 in County, .

4. There were no minor children of the Parties. All children of the parties are adults over the age of 18 years, emancipated and self-supportive. Wife is not now pregnant.

5. All matters involving property of the marriage, both real and personal, have been resolved, or will be resolved, and the terms agreed to in the Separation and Property Settlement Agreement mentioned below. All debts are likewise to be resolved by the parties in the separation agreement.

6. Both parties to the marriage are of legal age and are mentally competent.

7. From and after day of , 20, and up to the present, Plaintiff and Defendant have lived separate and apart, in separate habitations, without any cohabitation and without interruption. The Parties have so lived separate and apart, in separate habitations, without interruption for eighteen (18) months or more with no reasonable prospect of reconciliation, in compliance with New Jersey Statutes Annotated; Title 2A, Chapters 34--2. The parties therefore request a decree of divorce on the ground of living separate and apart for a period of eighteen (18) months with no reasonable prospect of reconciliation.

8. The current residences of the Parties are as follows:

Plaintiff resided at the following address when the cause of action arose:

9. Party does does not request restoration of my former name, , pursuant to New Jersey Statutes Annotated; Title 2A, Chapters 34-21.

10. The Plaintiff further state the following: I do not know of any other cases in the State of New Jersey or any state or territory involving the same claim or subject matter as this case.

11. The Parties have executed, or intend to execute, a Separation and Property Settlement Agreement disposing of all jointly owned property and settling all jointly owed debts and rights and liabilities of the parties. If executed already, a copy of which is attached hereto as Exhibit "A".

WHEREFORE, Plaintiff, requests that:

a) The Court grant the Parties a Divorce on the ground of living separate and apart, in separate habitations for a period of eighteen (18) months without reasonable prospect of reconciliation, in accordance with New Jersey Statutes Annotated; Title 2A, Chapters 34--2;

b) That the Separation and Property Settlement Agreement disposing of all jointly owned property and settling all jointly owed debts and rights and liabilities of the parties be incorporated into the final judgment of divorce;

c) Party, , requests that she be restored her maiden name of , pursuant to New Jersey Statutes Annotated; Title 2A, Chapters 34-21.

d) That the Court will grant such other relief as deemed appropriate;

Respectfully submitted,