Complaint for Divorce — Contested with Children
IN THE CIRCUIT COURT FOR THE COUNTY OF [1. County], MICHIGAN
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 Michigan for at least one hundred eighty (180) days and a resident of [1. County] County for at least ten (10) days immediately preceding the filing of this Complaint, in accordance with MCL 552.9. 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
There has been a breakdown of the marriage relationship to the extent that the objects of matrimony have been destroyed and there remains no reasonable likelihood that the marriage can be preserved, in accordance with MCL 552.6. 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 time schedule in accordance with the best interests of the child(ren) under MCL 722.23. 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 Michigan Child Support Formula. 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 just and reasonable. Relevant facts include: [14. Spousal Support Facts]
Request for Relief
WHEREFORE, Plaintiff respectfully requests that this Court:
(a) enter a Judgment of Divorce dissolving the marriage of the parties;
(b) determine legal and physical custody and establish a parenting time schedule in the best interests of the minor child(ren);
(c) order child support in accordance with the Michigan Child Support Formula;
(d) equitably divide the parties' marital property and debts;
(e) award spousal support as the Court deems just and 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].