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1
VIRGINIA: IN THE CIRCUIT COURT OF THE COUNTY OF HENRICO
XXX, ) )
Plaintiff, ) )
v. ) Case No. )
YYY, )
)
Defendant. )
DEPOSITIONS IN SUPPORT OF DIVORCEFROM THE BOND OF MATRIMONY
The depositions of XXX and WWW, were taken before me, the
undersigned Notary Public, at the Law Offices of Attorney Name,
Address, City, State, Zip, on DDD, to be read as evidence on behalf
of XXX in support of his Complaint for a divorce from the bond of matrimony.
Those in attendance at the taking of these depositions:
XXX Plaintiff
WWW Witness
Attorney Name Attorney for Plaintiff
NNN Notary Public
The plaintiff, XXX, being duly sworn, did depose and state as follows:
EXAMINATION by Attorney Name, Attorney for the plaintiff.
Q. Please state your name and address?
A. My name is XXX and I reside at EEE, Richmond, Virginia, which is in the City of Richmond, Virginia.
Q. Are you the plaintiff in a certain divorce case styled XXX v. YYY, currently pending in the Circuit Court of the County of
Henrico, Virginia?
A. Yes, I am.
Q. What is your social security number?
A. SSS-SS-SSSS.
2
Q. What is your wife’s social security number?
A. TTT-TT-TTTT.
Q. When and where were you and the defendant married?
A. We were married in Richmond, Virginia, on DDD.
Q. Are there any minor children born of this marriage or adopted?
A. Yes. We have one child.
Q. What is the child’s name and date of birth?
A. KKK, born DDD.
Q. Are any children expected?
A. No.
Q. Have you been domiciled in and bona fide resident of Virginia for more than six months preceding the commencement of this suit?
A. Yes.
Q. Are you and the defendant over the age of eighteen years?
A. Yes.
Q. Are either of you in the Armed Forces of the United States of America?
A. No.
Q. Where did you and the defendant last cohabit together as man and wife?
A. We last lived together in the City of Richmond, Virginia.
Q. When did you separate?
A. We separated on DDD.
Q. When you separated did you intend to make the separation a permanent one?
A. Yes.
3
Q. Have you lived separate and apart, without any cohabitation and without interruption since that date?
A. Yes.
Q. Have you and your wife settled all matters relating to property?
A. Yes, we have.
Q. Did you and your wife enter into a property settlement agreement?
A. Yes.
Q. Mr. XXX, I show you this document and ask if this is the agreement which you entered into with your wife?
A. Yes, it is. [The property settlement agreement, dated DDD, was marked for
identification as "Exhibit 1.]
Q. Who has physical custody of your child?
A. My wife does. That was handled by the ________ Juvenile Court.
Q. Mr. XXX, is reconciliation with your wife probable or possible?
A. No, it is not. [The right of cross-examination of the witness by counsel for
the defendant is reserved].
AND FURTHER THE DEPONENT SAYETH NOT
_____________________________ XXX
4
The witness, WWW, being duly sworn, did depose and state as
follows:
Q. Please state your name and address?
A. My name is WWW and I live at AAA.
Q. What is the nature of your relationship with the plaintiff, XXX?
A. I am his friend.
Q. When and where were the parties married?
A. They were married in Richmond, Virginia, on DDD.
Q. Are there any minor children born of this marriage or adopted?
A. Yes, they have one child.
Q. What is the child’s name and date of birth?
A. KKK, born DDD.
Q. Are any children expected?
A. No.
Q. Has the plaintiff been domiciled in and a bona fide resident of Virginia for more than six months preceding the institution of
this suit?
A. Yes.
Q. Are the plaintiff and the defendant both over the age of eighteen years?
A. Yes.
Q. Are either of the parties in the Armed Forces of the United States of America?
A. No, they are not.
Q. Where did the plaintiff and the defendant last live together as man and wife?
A. In the City of Richmond, Virginia.
5
Q. When did they separate?
A. They separated on DDD.
Q. Did the parties intend to make the separation a permanent one?
A. Yes.
Q. Since that date have they lived separate and apart without interruption and without cohabitation?
A. Yes, they have.
Q. To your knowledge is reconciliation between the parties probable or possible?
A. No. [The right of cross-examination of the witness by counsel for
the defendant is reserved].
AND FURTHER THE DEPONENT SAYETH NOT.
_____________________________ WWW
6
COMMONWEALTH OF VIRGINIA;
COUNTY OF CHESTERFIELD; To-Wit:I, the undersigned Notary Public, do certify that I am a
Notary Public for the Commonwealth of Virginia, at large; that XXX
and WWW, deponents above, appeared before me on the ______ day of
______________, 2004, and after being duly sworn, answered the
questions above listed with the answers noted and each signed in my
presence after being duly sworn. This is a true and accurate record
of the proceedings herein.
_____________________________
Notary Public
My commission expires:__________________
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