Divorce Complaint

IN THE CIRCUIT COURT OF CLAY COUNTY, FLORIDA

FAMILY LAW DIVISION

 

IN RE: THE MARRIAGE OF

 

Husband,

CASE NO.:

and

 

Wife.

___________________________________/

FIRST AMENDED VERIFIED PETITION FOR DISSOLUTION OF MARRIAGE

 (“Wife”) petitions the Court for entry of a Final Judgment of Dissolution of Marriage. In support of the relief requested, she states:

BACKGROUND

  1. Husband and Wife were married to each other on _ July 11 _, in 1997.

  2. On or about June 15, 2009 , Husband and Wife separated and continue to live apart.

  3. Husband and Wife have been residents of the State of Florida for more than six (6) months prior to the filing of this Petition.

  4. Husband and Wife have no children together and no other children were born of the marriage, no other children were adopted, and no children are expected.

SOLDIERS AND SAILORS RELIEF ACT DECLARATION

  1. Neither party is a member of the Armed Forces of the United States nor has either party been within a period of thirty (30) days immediately preceding the filing of this action.

 

COUNT I

(Dissolution of Marriage)

  1. PETITION FOR DISSOLUTION: This is an action for dissolution of marriage.

  2. Wife restates the allegations set forth in paragraphs 1 through 6 above.

  3. GROUNDS FOR DISSOLUTION: The marriage between Husband and Wife is irretrievably broken and cannot be restored.

  4. MARITAL RESIDENCE: Husband and Wife are the joint owners of real property located at REDACTED PLACE (the “Marital Residence”). The Court should distribute the Marital Residence to the Wife and should order the Husband to issue a Quit Claim Deed to the Wife for the same.

  5. EQUITABLE DISTRIBUTION OF MARITAL PROPERTY: Husband and Wife have not acquired any other real property as well as certain personal property, both tangible and intangible, of any value.

  6. EQUITABLE DISTRIBUTION OF MARITAL LIABILITIES: Husband and Wife have not acquired certain debts and liabilities that should be equitably distributed by the Court as part of this dissolution of marriage proceeding.

  7. ALIMONY: Husband should pay alimony to the Wife in the sum of $3,000.00 per month continuing until Wife dies or until Wife remarries (whichever comes earlier).

  8. ATTORNEY FEES: Wife has retained the undersigned to represent her in this cause and has incurred attorney’s fees and costs with respect to this proceeding. Wife should be awarded attorneys’ fees and costs for the same.

WHEREFORE, the Court should:

(a) Enter a Final Judgment of Dissolution of Marriage dissolving the marriage between the parties;

(b) Distribute the Marital Residence to the Wife;

(c) Provide that Husband pays alimony to the Wife in the sum of $3,000.00 per month;

(d) Award Wife the reasonable attorney’s fees and costs;

(e) Award Wife all other relief to which Wife may be entitled.

VERIFICATION OF WIFE

I understand that I am swearing or affirming under oath to the truthfulness of the claims made herein the Verified Joint Petition for Dissolution of Marriage and that the punishment for knowingly making a false statement includes fines and/or imprisonment.

 

STATE OF FLORIDA

COUNTY OF _______________________

 

SWORN TO or affirmed and signed before me this _____ day of______________.

/s/ Michael Massey

Fla. Bar No. 153680

Massey & Duffy

855 E. Univ. Ave.

Gainesville, FL 32601

352-505-8900

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