Complaint for Divorce — Uncontested with Children (1A Joint Petition)
COMMONWEALTH OF MASSACHUSETTS
THE TRIAL COURT
PROBATE AND FAMILY COURT DEPARTMENT
[1. County] DIVISION
Docket No: [2. Docket 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], pursuant to G.L. c. 208, § 1A (joint petition), and in support thereof respectfully states:
Jurisdiction and Residency
Plaintiff has been a resident of the Commonwealth of Massachusetts for at least one (1) year immediately preceding the filing of this Complaint, in accordance with G.L. c. 208, § 4. 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 has irretrievably broken down, and there is no reasonable possibility of reconciliation, in accordance with G.L. c. 208, § 1A. The parties have executed a written separation agreement resolving all issues, including custody, support, and parenting time. The marriage 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 G.L. c. 208, § 28. 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 Massachusetts 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]
Alimony
The parties have agreed that alimony shall be as follows: [17. Alimony Terms]
Request for Relief
WHEREFORE, Plaintiff respectfully requests that this Court:
(a) enter a Judgment of Divorce dissolving the marriage of the parties;
(b) approve the parties' separation agreement and Parenting Plan;
(c) order child support in accordance with the parties' agreement and the Massachusetts 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], declare under the penalties of perjury that the foregoing statements are true and correct to the best of my knowledge, information, and belief.
Executed this [20. Execution Date] day of [21. Execution Month, Year], at [22. City and State of Execution].