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Complaint for Divorce — Uncontested

IN THE CHANCERY COURT OF [1. County] COUNTY, MISSISSIPPI

Cause No: [2. Cause 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 Mississippi for at least six (6) months immediately preceding the filing of this Complaint, in accordance with Miss. Code Ann. § 93-5-5. 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 parties have irreconcilable differences, and the marriage has broken down irretrievably, in accordance with Miss. Code Ann. § 93-5-2. The parties have executed a written agreement resolving all issues. The marriage should be dissolved.

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, also known as alimony, shall be as follows: [9. Spousal Support Terms]

Request for Relief

WHEREFORE, Plaintiff respectfully requests that this Court:

(a) grant a divorce dissolving the marriage of the parties;
(b) approve the parties' agreement regarding property, debts, and spousal support;
(c) restore Plaintiff's former name of [10. Former Name], if requested; and
(d) grant such other and further relief as the Court deems just and proper.

Dated: [11. 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 [12. Execution Date] day of [13. Execution Month, Year], at [14. City and State of Execution].

Complaint for Divorce — Contested

IN THE CHANCERY COURT OF [1. County] COUNTY, MISSISSIPPI

Cause No: [2. Cause 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 Mississippi for at least six (6) months immediately preceding the filing of this Complaint, in accordance with Miss. Code Ann. § 93-5-5. 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 parties have irreconcilable differences, and the marriage has broken down irretrievably, in accordance with Miss. Code Ann. § 93-5-2. The marriage should be dissolved.

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. 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 relevant factors. Relevant facts include: [9. Spousal Support Facts]

Request for Relief

WHEREFORE, Plaintiff respectfully requests that this Court:

(a) grant a 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], declare 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 CHANCERY COURT OF [1. County] COUNTY, MISSISSIPPI

Cause No: [2. Cause 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 Mississippi for at least six (6) months immediately preceding the filing of this Complaint, in accordance with Miss. Code Ann. § 93-5-5. 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 irreconcilable differences, and the marriage has broken down irretrievably, in accordance with Miss. Code Ann. § 93-5-2. The parties have executed a written agreement resolving all issues. 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 Miss. Code Ann. § 93-5-24. 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 Mississippi Child Support Guidelines (Miss. Code Ann. § 43-19-101). 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]

Request for Relief

WHEREFORE, Plaintiff respectfully requests that this Court:

(a) grant a divorce dissolving the marriage of the parties;
(b) approve the parties' Parenting Plan regarding custody;
(c) order child support in accordance with the parties' agreement and the Mississippi 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 penalty 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].

Complaint for Divorce — Contested with Children

IN THE CHANCERY COURT OF [1. County] COUNTY, MISSISSIPPI

Cause No: [2. Cause 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 Mississippi for at least six (6) months immediately preceding the filing of this Complaint, in accordance with Miss. Code Ann. § 93-5-5. 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 irreconcilable differences, and the marriage has broken down irretrievably, in accordance with Miss. Code Ann. § 93-5-2. 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 Miss. Code Ann. § 93-5-24. 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 Mississippi Child Support Guidelines (Miss. Code Ann. § 43-19-101). 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) grant a 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 Mississippi 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], 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].