New Jersey Complaint for Divorce

Complaint for Divorce

JOHN LAWYER, ESQ.

12 MAIN STREET

ANYWHERE, USA

Attorney for Plaintiff

The Plaintiff, John Doe, residing at by way of Complaint against the Defendant, says:

1. The plaintiff was lawfully married to the defendant on , at a religious ceremony in

2. There were no children borne of this marriage.

3. The plaintiff was a bona fide resident of the State of when this cause of action arose, and has ever since and for more than one year next preceding the commencement of this action, continued to be such a bona fide resident.

4. The defendant now maintains a residence at

5. The defendant has been guilty of extreme cruelty toward the plaintiff continuing through the marriage and more specifically set forth in Exhibit A attached herein and incorporated hereof. These acts of extreme cruelty have caused the plaintiff physical and emotional harm and it is unfair and unreasonable to require the plaintiff to remain married to the defendant.

6. More than months have elapsed since the last act of extreme cruelty complained of as constituting plaintiff's cause of action herein. The acts of extreme cruelty committed by the defendant within the period of three months prior to the filing of this complaint, as above set forth, are alleged not as constituting in whole or in part the cause of action set forth herein, but as relating back to qualify and characterize the acts constituting said cause of action.

7. Property, real and/or personal was legally and beneficially acquired by the parties, or either of them, during the course of the marriage.

8. There have been no previous proceedings between the plaintiff and the defendant respecting dissolution of the marriage or maintenance of either party in any Court.

WHEREFORE, the plaintiff demands judgment:

(a) Dissolving the marriage between the parties;

(b) Awarding custody of the unemancipated children born of the marriage to the plaintiff;

(c) Equitably distributing all property, both real and personal, owned or acquired by the parties during the course of the marriage, pursuant to ; and

(d) For such further relief as the Court may deem equitable and just.

CERTIFICATION OF VERIFICATION AND NON-COLLUSION AND CERTIFICATION PURSUANT TO R.4:5-1

I, John Doe, do hereby certify that:

1. I am the plaintiff in the foregoing Complaint.

2. The allegations of the Complaint are true to the best of my knowledge, information and belief.

3. The Complaint is made in truth and in good faith and without collusion for the causes set forth therein.

4. To the best of my knowledge and belief, this matter in controversy is not the subject of any other action pending in any Court or of a pending arbitration proceeding, nor is any such proceeding contemplated at this time.

5. To the best of my knowledge and belief, there are no other parties who must be joined in this action.

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.

EXHIBIT A

The defendant has chosen a career and expressed an interest in music over her obligations and dedication to her marriage and the plaintiff and her actions have made the plaintiff feel alone and inadequate.

The defendant has chosen and pursued a career in music which has required her to be away from home for extended periods of time without any, or little, contact with the plaintiff.

The defendant has repeatedly failed to meet her financial obligations under her marriage by leaving all financial responsibility to the plaintiff despite her ability to earn a satisfactory income.