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Complaint in Divorce — Uncontested

IN THE COURT OF COMMON PLEAS OF [1. County] COUNTY, PENNSYLVANIA Civil Action Law No. [2. Case Number] [3. Plaintiff Full Name], Plaintiff, vs. [4. Defendant Full Name], Defendant. Comes now the Plaintiff, [3. Plaintiff Full Name], and files this Complaint in Divorce against the Defendant, [4. Defendant Full Name], and in support thereof respectfully states:

Jurisdiction and Residency

Plaintiff has been a resident of the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint, in accordance with 23 Pa.C.S. § 3104. This Court has jurisdiction over the parties and the subject matter of this action.

Marriage Information

The parties were lawfully married on [5. Date of Marriage] in [6. City and State of Marriage], and separated on [7. Date of Separation]. There are no minor children born of or adopted during this marriage.

Grounds for Divorce

The parties have consented to the divorce by mutual consent, in accordance with 23 Pa.C.S. § 3301(c). The marriage is irretrievably broken and should be dissolved.

Property and Debt Division

The parties have reached a full and complete agreement regarding the division of all marital property, assets, and debts. The terms of this division are as follows: [8. Property and Debt Division Terms]

Spousal Support and Alimony

The parties have agreed that spousal support and alimony shall be as follows: [9. Spousal Support and Alimony Terms]

Request for Relief

WHEREFORE, Plaintiff respectfully requests that this Court: (a) enter a Decree in Divorce dissolving the marriage of the parties; (b) approve the parties' agreement regarding property, debts, spousal support, and alimony; (c) restore Plaintiff's former name of [10. Former Name], if requested; and (d) grant such other and further relief as the Court deems just and proper. Dated: [11. Date of Signing]

Verification

I, [3. Plaintiff Full Name], verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief, under penalty of perjury. Executed this [12. Execution Date] day of [13. Execution Month, Year], at [14. City and State of Execution].

Complaint in Divorce — Contested

IN THE COURT OF COMMON PLEAS OF [1. County] COUNTY, PENNSYLVANIA Civil Action Law No. [2. Case Number] [3. Plaintiff Full Name], Plaintiff, vs. [4. Defendant Full Name], Defendant. Comes now the Plaintiff, [3. Plaintiff Full Name], and files this Complaint in Divorce against the Defendant, [4. Defendant Full Name], and in support thereof respectfully states:

Jurisdiction and Residency

Plaintiff has been a resident of the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint, in accordance with 23 Pa.C.S. § 3104. This Court has jurisdiction over the parties and the subject matter of this action.

Marriage Information

The parties were lawfully married on [5. Date of Marriage] in [6. City and State of Marriage], and separated on [7. Date of Separation]. The parties have lived separate and apart for a period of at least one year immediately preceding the filing of this Complaint. There are no minor children born of or adopted during this marriage.

Grounds for Divorce

The marriage is irretrievably broken, and the parties have lived separate and apart for a period of at least one year, in accordance with 23 Pa.C.S. § 3301(d). The marriage should be dissolved.

Property and Debt Division

The parties are unable to agree on the division of their marital property, assets, and debts. Plaintiff requests that this Court equitably divide the parties' marital property and debts in accordance with 23 Pa.C.S. § 3501. The relevant marital assets and liabilities include: [8. Property and Debt Description]

Spousal Support and Alimony

The parties are unable to agree on spousal support and alimony. Plaintiff requests that the Court award spousal support and alimony in an amount and for a duration that is just and equitable, considering the factors set forth in 23 Pa.C.S. § 3701. Relevant facts include: [9. Spousal Support and Alimony Facts]

Request for Relief

WHEREFORE, Plaintiff respectfully requests that this Court: (a) enter a Decree in Divorce dissolving the marriage of the parties; (b) equitably divide the parties' marital property and debts; (c) award spousal support and alimony as the Court deems just and equitable; (d) restore Plaintiff's former name of [10. Former Name], if requested; and (e) grant such other and further relief as the Court deems just and proper. Dated: [11. Date of Signing]

Verification

I, [3. Plaintiff Full Name], verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief, under penalty of perjury. Executed this [12. Execution Date] day of [13. Execution Month, Year], at [14. City and State of Execution].

Complaint in Divorce — Uncontested with Children

IN THE COURT OF COMMON PLEAS OF [1. County] COUNTY, PENNSYLVANIA Civil Action Law No. [2. Case Number] [3. Plaintiff Full Name], Plaintiff, vs. [4. Defendant Full Name], Defendant. Comes now the Plaintiff, [3. Plaintiff Full Name], and files this Complaint in Divorce against the Defendant, [4. Defendant Full Name], and in support thereof respectfully states:

Jurisdiction and Residency

Plaintiff has been a resident of the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint, in accordance with 23 Pa.C.S. § 3104. This Court has jurisdiction over the parties and the subject matter of this action.

Marriage Information

The parties were lawfully married on [5. Date of Marriage] in [6. City and State of Marriage], and separated on [7. Date of Separation]. There are [8. Number of Children] minor child(ren) born of or adopted during this marriage: [9. Children Names and Birthdates].

Grounds for Divorce

The parties have consented to the divorce by mutual consent, in accordance with 23 Pa.C.S. § 3301(c). The marriage is irretrievably broken and should be dissolved.

Custody and Parenting Plan

The parties have reached a full agreement regarding legal and physical custody of the minor child(ren), in accordance with the best interests of the child(ren) under 23 Pa.C.S. § 5328. The agreed parenting plan is as follows: [10. Parenting Plan Terms]

Child Support

The parties have reached an agreement on child support consistent with the Pennsylvania Child Support Guidelines (23 Pa.C.S. § 4322). The agreed monthly child support amount is [11. Child Support Amount], payable by [12. Paying Parent] to [13. Receiving Parent]. Additional terms: [14. Child Support Additional Terms]

Medical and Childcare Expenses

Unreimbursed medical, dental, vision, and childcare expenses for the minor child(ren) shall be shared as follows: [15. Medical and Childcare Terms]

Property and Debt Division

The parties have reached a full and complete agreement regarding the division of all marital property, assets, and debts. The terms of this division are as follows: [16. Property and Debt Division Terms]

Spousal Support and Alimony

The parties have agreed that spousal support and alimony shall be as follows: [17. Spousal Support and Alimony Terms]

Request for Relief

WHEREFORE, Plaintiff respectfully requests that this Court: (a) enter a Decree in Divorce dissolving the marriage of the parties; (b) approve the parties' parenting plan regarding legal and physical custody of the minor child(ren); (c) order child support in accordance with the parties' agreement and the Pennsylvania Child Support Guidelines; (d) approve the parties' property and debt division; (e) restore Plaintiff's former name of [18. Former Name], if requested; and (f) grant such other and further relief as the Court deems just and proper. Dated: [19. Date of Signing]

Verification

I, [3. Plaintiff Full Name], verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief, under penalty of perjury. Executed this [20. Execution Date] day of [21. Execution Month, Year], at [22. City and State of Execution].

Complaint in Divorce — Contested with Children

IN THE COURT OF COMMON PLEAS OF [1. County] COUNTY, PENNSYLVANIA Civil Action Law No. [2. Case Number] [3. Plaintiff Full Name], Plaintiff, vs. [4. Defendant Full Name], Defendant. Comes now the Plaintiff, [3. Plaintiff Full Name], and files this Complaint in Divorce against the Defendant, [4. Defendant Full Name], and in support thereof respectfully states:

Jurisdiction and Residency

Plaintiff has been a resident of the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint, in accordance with 23 Pa.C.S. § 3104. This Court has jurisdiction over the parties and the subject matter of this action.

Marriage Information

The parties were lawfully married on [5. Date of Marriage] in [6. City and State of Marriage], and separated on [7. Date of Separation]. The parties have lived separate and apart for a period of at least one year immediately preceding the filing of this Complaint. There are [8. Number of Children] minor child(ren) born of or adopted during this marriage: [9. Children Names and Birthdates].

Grounds for Divorce

The marriage is irretrievably broken, and the parties have lived separate and apart for a period of at least one year, in accordance with 23 Pa.C.S. § 3301(d). The marriage should be dissolved.

Custody and Parenting Plan

The parties are unable to agree on legal or physical custody of the minor child(ren). Plaintiff requests that the Court award custody and establish a parenting plan in accordance with the best interests of the child(ren) under 23 Pa.C.S. § 5328. Relevant facts include: [10. Custody Dispute Facts]

Child Support

The parties are unable to agree on child support. Plaintiff requests that the Court order child support in accordance with the Pennsylvania Child Support Guidelines (23 Pa.C.S. § 4322). Relevant facts include: [11. Child Support Facts]

Medical, Dental, and Childcare Expenses

Unreimbursed medical, dental, vision, and childcare expenses for the minor child(ren) shall be allocated as follows, or as the Court determines equitable: [12. Medical and Childcare Terms]

Property and Debt Division

The parties are unable to agree on the division of their marital property, assets, and debts. Plaintiff requests that the Court equitably divide the parties' marital property and debts in accordance with 23 Pa.C.S. § 3501. The relevant marital assets and liabilities include: [13. Property and Debt Description]

Spousal Support and Alimony

The parties are unable to agree on spousal support and alimony. Plaintiff requests that the Court award spousal support and alimony as the Court deems just and equitable under 23 Pa.C.S. § 3701. Relevant facts include: [14. Spousal Support and Alimony Facts]

Request for Relief

WHEREFORE, Plaintiff respectfully requests that this Court: (a) enter a Decree in Divorce dissolving the marriage of the parties; (b) determine legal and physical custody and establish a parenting plan in the best interests of the minor child(ren); (c) order child support in accordance with the Pennsylvania Child Support Guidelines; (d) equitably divide the parties' marital property and debts; (e) award spousal support and alimony as the Court deems just and equitable; (f) restore Plaintiff's former name of [15. Former Name], if requested; and (g) grant such other and further relief as the Court deems just and proper. Dated: [16. Date of Signing]

Verification

I, [3. Plaintiff Full Name], verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief, under penalty of perjury. Executed this [17. Execution Date] day of [18. Execution Month, Year], at [19. City and State of Execution].