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Complaint for Divorce — Uncontested

IN THE CIRCUIT COURT OF [1. County] COUNTY, ALABAMA Case 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 for Divorce against the Defendant, [4. Defendant Full Name], and in support thereof respectfully states:

Jurisdiction and Residency

Plaintiff has been a bona fide resident of the State of Alabama for more than six (6) months immediately preceding the filing of this Complaint, in accordance with Ala. Code § 30-2-5, and resides in [1. County] County, Alabama. 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 marriage is irretrievably broken, and there is no reasonable possibility of reconciliation. The parties' marriage should be dissolved on the ground of incompatibility, as permitted under Alabama law.

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

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

Separation Agreement

The parties have executed a written Separation Agreement dated [10. Agreement Date], which fully resolves all issues between the parties. Plaintiff requests that this Court approve the Agreement and incorporate it into the Final Judgment of Divorce.

Request for Relief

WHEREFORE, Plaintiff respectfully requests that this Court: (a) enter a Final Judgment of Divorce dissolving the marriage of the parties; (b) approve and incorporate the parties' Separation Agreement; (c) restore Plaintiff's former name of [11. Former Name], if requested; and (d) grant such other and further relief as the Court deems just and proper. Dated: [12. Date of Signing]

Verification

I, [3. Plaintiff Full Name], do solemnly affirm under penalty of perjury that the foregoing statements are true and correct to the best of my knowledge, information, and belief. Executed this [13. Execution Date] day of [14. Execution Month, Year], at [15. City and State of Execution].

Complaint for Divorce — Contested

IN THE CIRCUIT COURT OF [1. County] COUNTY, ALABAMA Case 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 for Divorce against the Defendant, [4. Defendant Full Name], and in support thereof respectfully states:

Jurisdiction and Residency

Plaintiff has been a bona fide resident of the State of Alabama for more than six (6) months immediately preceding the filing of this Complaint, in accordance with Ala. Code § 30-2-5, and resides in [1. County] County, Alabama. 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 marriage is irretrievably broken, and there is no reasonable possibility of reconciliation. The parties' marriage should be dissolved on the ground of incompatibility, as permitted under Alabama law.

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 pursuant to Alabama's equitable distribution principles. The relevant marital assets and liabilities include: [8. Property and Debt Description]

Spousal Support

The parties are unable to agree on spousal support. Plaintiff requests that the Court award spousal support in an amount and for a duration that is equitable, considering the length of the marriage, the parties' respective incomes, earning capacities, and needs. Relevant facts include: [9. Spousal Support Facts]

Request for Relief

WHEREFORE, Plaintiff respectfully requests that this Court: (a) enter a Final Judgment of Divorce dissolving the marriage of the parties; (b) equitably divide the parties' marital property and debts; (c) award spousal support as the Court deems 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], do solemnly affirm under penalty of perjury that the foregoing statements are true and correct to the best of my knowledge, information, and belief. Executed this [12. Execution Date] day of [13. Execution Month, Year], at [14. City and State of Execution].

Complaint for Divorce — Uncontested with Children

IN THE CIRCUIT COURT OF [1. County] COUNTY, ALABAMA Case 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 for Divorce against the Defendant, [4. Defendant Full Name], and in support thereof respectfully states:

Jurisdiction and Residency

Plaintiff has been a bona fide resident of the State of Alabama for more than six (6) months immediately preceding the filing of this Complaint, in accordance with Ala. Code § 30-2-5, and resides in [1. County] County, Alabama. 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 marriage is irretrievably broken, and there is no reasonable possibility of reconciliation. The parties' marriage should be dissolved on the ground of incompatibility, as permitted under Alabama law.

Custody and Parenting Plan

The parties have reached a full agreement regarding legal and physical custody of the minor child(ren). 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 Alabama Child Support Guidelines. 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

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

Separation Agreement

The parties have executed a written Separation Agreement dated [18. Agreement Date], which fully resolves all issues between the parties, including the custody and support provisions above. Plaintiff requests that this Court approve the Agreement and incorporate it into the Final Judgment of Divorce.

Request for Relief

WHEREFORE, Plaintiff respectfully requests that this Court: (a) enter a Final Judgment of Divorce dissolving the marriage of the parties; (b) approve the parties' Parenting Plan and Separation Agreement; (c) order child support in accordance with the parties' agreement; (d) restore Plaintiff's former name of [19. Former Name], if requested; and (e) grant such other and further relief as the Court deems just and proper. Dated: [20. Date of Signing]

Verification

I, [3. Plaintiff Full Name], do solemnly affirm under penalty of perjury that the foregoing statements are true and correct to the best of my knowledge, information, and belief. Executed this [21. Execution Date] day of [22. Execution Month, Year], at [23. City and State of Execution].

Complaint for Divorce — Contested with Children

IN THE CIRCUIT COURT OF [1. County] COUNTY, ALABAMA Case 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 for Divorce against the Defendant, [4. Defendant Full Name], and in support thereof respectfully states:

Jurisdiction and Residency

Plaintiff has been a bona fide resident of the State of Alabama for more than six (6) months immediately preceding the filing of this Complaint, in accordance with Ala. Code § 30-2-5, and resides in [1. County] County, Alabama. 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 marriage is irretrievably broken, and there is no reasonable possibility of reconciliation. The parties' marriage should be dissolved on the ground of incompatibility, as permitted under Alabama law.

Custody and Parenting Time

The parties are unable to agree on legal custody, physical custody, or parenting time for the minor child(ren). Plaintiff requests that the Court determine a custody and parenting arrangement that serves the best interests of the child(ren) under Alabama law, considering the factors set forth in Ala. Code § 30-3-152. 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 Alabama Child Support Guidelines. 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. The relevant marital assets and liabilities include: [13. Property and Debt Description]

Spousal Support

The parties are unable to agree on spousal support. Plaintiff requests that the Court award spousal support as the Court deems equitable. Relevant facts include: [14. Spousal Support Facts]

Request for Relief

WHEREFORE, Plaintiff respectfully requests that this Court: (a) enter a Final Judgment of Divorce dissolving the marriage of the parties; (b) determine legal and physical custody and parenting time in the best interests of the minor child(ren); (c) order child support in accordance with the Alabama Child Support Guidelines; (d) equitably divide the parties' marital property and debts; (e) award spousal support as the Court deems 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], do solemnly affirm under penalty of perjury that the foregoing statements are true and correct to the best of my knowledge, information, and belief. Executed this [17. Execution Date] day of [18. Execution Month, Year], at [19. City and State of Execution].