Complaint for Divorce — Contested with Children
IN THE SUPERIOR COURT OF [1. County] COUNTY, STATE OF GEORGIA
CIVIL ACTION FILE 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 shows this Court:
Jurisdiction and Residency
Plaintiff has been a bona fide resident of the State of Georgia for at least six (6) months immediately preceding the filing of this Complaint, in accordance with O.C.G.A. § 19-5-2. 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 prospect of reconciliation, in accordance with O.C.G.A. § 19-5-3. The marriage should be dissolved.
Custody and Parenting Time
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 O.C.G.A. § 19-9-3. 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 Georgia Child Support Guidelines (O.C.G.A. § 19-6-15). 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]
Alimony
The parties are unable to agree on alimony. Plaintiff requests that the Court award alimony as the Court deems equitable. Relevant facts include: [14. Alimony Facts]
Request for Relief
WHEREFORE, Plaintiff respectfully requests that this Court:
(a) grant a total 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 Georgia Child Support Guidelines;
(d) equitably divide the parties' marital property and debts;
(e) award alimony 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], 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].