Fill and Sign the Upholstered and Stuffed Articles Act Form

THIS DOCUMENT IS NOT LEGAL ADVICE, IT IS FOR INFORMATIONAL PURPOSES ONLY. ANY SIMILARITIES TO REAL PEOPLE OR SITUATIONS ARE UNINTENTIONAL. IN THE CHANCERY/CIRCUIT COURT OF SHELBY COUNTY, TENNESSEE FOR THE THIRTIETH JUDICIAL DISTRICT SARAH SUSAN SHIPMAN SMITH, Plaintiff, vs. DOCKET NO.__________________ STEVEN SCOTT SMITH, PART/DIVISION_______________ Defendant. ______________________________________________________________________________ COMPLAINT FOR ABSOLUTE DIVORCE ______________________________________________________________________________ TO THE HONORABLE CHANCELLORS AND CIRCUIT COURT JUDGES OF SHELBY COUNTY, TENNESSEE: Comes now the Plaintiff, SARAH SUSAN SHIPMAN SMITH, also referred to as “WIFE,” and sues the Defendant, STEVEN SCOTT SMITH, also referred to as “HUSBAND,” for an absolute divorce, and for cause of action would respectfully state and show to the Court as follows: I. JURISDICTION That Plaintiff is an adult resident of Shelby County, Tennessee and has been for more than six (6) months preceding the filing of this Complaint for Divorce. The Defendant is an adult resident of Shelby County, Tennessee and has been for more than six (6) months preceding the filing of this Complaint for Divorce. The acts complained of were committed while the parties were residents of Tennessee. II. 1 THIS DOCUMENT IS NOT LEGAL ADVICE, IT IS FOR INFORMATIONAL PURPOSES ONLY. ANY SIMILARITIES TO REAL PEOPLE OR SITUATIONS ARE UNINTENTIONAL. STATISTICAL DATA The Plaintiff would show the following statistical information concerning the parties in the marriage is true and correct as required by T.C.A. 36-4-106: WIFE: a. Full maiden name of Wife: Sarah Susan Shipman Smith b. Race: Caucasian c. Residence: 123 Normal St., Memphis, TN 38111 d. Length of residence in Tennessee: 22 years e. Date and place of birth: 01/01/1970; Ohio f. Number of previous marriages: 0 g. Member of the Armed Services of the United States: No h. Employed: Comcast, Winchester Rd., Memphis, TN HUSBAND: i. Full name of Husband: Steven Scott Smith j. Race: Caucasian k. Residence address: 456 Normal St., Memphis, TN 38111 l. Length of residence in Tennessee: 25 years m. Date and place of birth: 02/02/1969; Mississippi n. Number of previous marriages: 1 o. Member of the Armed Services of the United States: No 2 THIS DOCUMENT IS NOT LEGAL ADVICE, IT IS FOR INFORMATIONAL PURPOSES ONLY. ANY SIMILARITIES TO REAL PEOPLE OR SITUATIONS ARE UNINTENTIONAL. p. Employed: FedEx, Airways Blvd., Memphis, TN q. Date and place of marriage of the parties: 03/03/2003; Honolulu, HI r. Date of separation of the parties: 04/04/2009 s. Residence of the parties at the time of separation: 123 Normal St., Memphis, TN 38111 t. Minor children born of this marriage and their dates of birth: Sally Sandra Smith, 05/05/05; and Shelton Sanders Smith, 06/06/06. III AVERMENTS 1. The parties’ children live and have lived in Shelby County, Tennessee, for the last six (6) months and specifically at the following places within the last five (5) years: a. 123 Normal St., Memphis, TN 38111 (Mother) b. 789 Normal St., Memphis, TN 38111 (Both Parents) 2. Plaintiff has not participated in other litigation concerning the custody of the subject of this custody litigation. Plaintiff does not have information of any other custody proceeding concerning the subject of this custody litigation in any Court of this or any other state. Plaintiff does not know of any person not a party to this proceeding, who has physical custody of the subject of the custody litigation, or claims to have custody, or visitation rights with respect to the subject of this custody litigation. 3. The best interest of the children will be served by awarding said children to the Plaintiff who is a fit and proper person to have custody of said children. In the alternative, Plaintiff requests joint custody of the parties’ children. IV GROUNDS 1. Irreconcilable differences have arisen between the parties that will prevent them from living together as husband and wife. 3 THIS DOCUMENT IS NOT LEGAL ADVICE, IT IS FOR INFORMATIONAL PURPOSES ONLY. ANY SIMILARITIES TO REAL PEOPLE OR SITUATIONS ARE UNINTENTIONAL. V PRAYERS WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that: 1. Upon the hearing of this cause the Plaintiff be awarded a Final Decree of Absolute Divorce from the Defendant. 2. The Court adjust and adjudicate the respective rights and interests of the parties in all jointly owned property and vest title to such property in Plaintiff as alimony in solido, or in the alternative, pursuant to TCA §36-4-21 to the extent the court deems appropriate. 3. The Court approve a Marital Dissolution Agreement if entered into between the parties and amend the pleadings if necessary to comply with the terms of the Marital Dissolution Agreement. 4. Plaintiff be restored to her maiden name of Shipman. 5. Plaintiff be awarded custody of the parties’ minor children, child support, attorney’s fees and suit expenses for defending the interest of said children, and that said child support be assigned from the Defendant’s income. 6. Plaintiff be awarded such other further and general relief to which Plaintiff may prove entitled. Respectfully Submitted, Cheetham & Howe Law Firm, PLLC __________________________________________ DEWEY CHEETHAM, BPR #012345 Attorney for Plaintiff 1234 Germantown Rd. Germantown, TN 38138 901.123.4567 tel. 901.765.4321 fax STATE OF TENNESSEE COUNTY OF SHELBY 4 THIS DOCUMENT IS NOT LEGAL ADVICE, IT IS FOR INFORMATIONAL PURPOSES ONLY. ANY SIMILARITIES TO REAL PEOPLE OR SITUATIONS ARE UNINTENTIONAL. I, SARAH SUSAN SHIPMAN SMITH, make oath that the facts stated in the foregoing Complaint for Divorce are true to the best of my knowledge and belief; that it is not filed in levity or in collusion, but in sincerity and truth, for the causes mentioned in said bill. __________________________________________ SARAH SUSAN SHIPMAN SMITH On this the _____ day of ______________, 20_____, before me, a Notary Public, in and for the aforesaid state and county, personally appeared SARAH SUSAN SHIPMAN SMITH, to me known to be the person described in and who executed the foregoing Complaint for Absolute Divorce, and acknowledged that he/she executed the same as his/her free act and deed. ___________________________________ NOTARY PUBLIC My Commission Expires: __________________ Service of a copy of this Complaint for Absolute Divorce upon the Shelby County Divorce Referee is acknowledged this _________ day of ____________________, 20______. __________________________________________ DIVORCE REFEREE 5