Complaint for Divorce — Contested with Children
IN THE CIRCUIT COURT OF [1. County] COUNTY, ARKANSAS, CHANCERY DIVISION
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 resident of the State of Arkansas for at least sixty (60) days immediately preceding the filing of this Complaint, in accordance with A.C.A. § 9-12-104, and resides in [1. County] County, Arkansas. 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 lived separate and apart from each other for a continuous period of eighteen (18) months without cohabitation, and there is no reasonable expectation of reconciliation. Plaintiff seeks a divorce on this ground as permitted under Arkansas law.
Custody and Parenting Time
The parties are unable to agree on custody or visitation for the minor child(ren). Plaintiff requests that the Court award custody and set a visitation schedule in accordance with the best interests of the child(ren). 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 Arkansas Child Support Guidelines (Administrative Order No. 10). 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 reasonable. Relevant facts include: [14. Spousal Support Facts]
Request for Relief
WHEREFORE, Plaintiff respectfully requests that this Court:
(a) enter a Decree of Divorce dissolving the marriage of the parties;
(b) determine custody and visitation in the best interests of the minor child(ren);
(c) order child support in accordance with the Arkansas Child Support Guidelines;
(d) equitably divide the parties' marital property and debts;
(e) award spousal support as the Court deems reasonable;
(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], declare 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].