Family Law: PA250-02
Common Wealth of Massachusetts
Division: Middlesex The Trial Court Docket No.23-400 Probate and Family Court Department
Complaint for Divorce
Patty Bean, Plaintiffv. David Bean, Defendant
1. Plaintiff, who resides at 123 West Golf Road, Middlesex County, Boston, MA, 12345 was lawfully married to the defendant who now resides at 456 East Lark Street, Suffolk County, Boston, MA 12345. Neither Plaintiff nor Defendant served in the Military. [Massachusetts General Laws Annotated; Chapter 208, Sections 4, 5, and 6]
2. The parties were married at St. Anne’s Church, Boston, MA on April 5, 2001, and last lived together at 123 West Golf Road, Middlesex County, Boston, MA 12345 on March 10, 2011.
3. The minor or dependent child (ren) of this marriage are/is Male: David Bean Jr. 06/01/2003 Female: Patricia Bean 06/05/2006
4. Plaintiff certifies that no previous action for divorce, annulment, or affirmation of marriage separation support, desertion, living apart for justifiable cause, or custody of child (ren) has been brought by either party against the other than No Fault Divorce [Massachusetts General Laws Annotated; Chapter 208, Sections 1, 1A, and 1B]
5. On or about March 10, 2011, David Bean, Defendant Bean moved from the family home due to Patty Bean accepting a job offer in Rhode Island as a Principle of a High School. One year prior Patty was offered the same a principle position in Rhode Island with a 15% salary increase; however, David Bean would not allow her to relocate with the children since it is 100 miles from Boston. Patty subsequently turned down the job offer. Massachusetts General Laws Annotated; Chapter 208, Sections 1, 1A, and 1B].
6. Wherefore, the Plaintiff requests the court:
[X] Grant a Divorce