Draft a Divorce Complaint
Commonwealth of Massachusetts
Return Date: _______ The Trial Court Complaint Date: 12/10/2013
Probate and Family Court Department
COMPLAINT FOR DIVORCE PURSUANT TO G.L. c. 208 § 1B
Patty Bean, Plaintiff V. David Bean, Defendant
1) Plaintiff who resides at123 West Golf Road, in the city of Boston, in the county of Suffolk in the state of Massachusetts, 12345 was lawfully married to the defendant who resides at 456 East Lark Street, in the city of Boston, the county of Suffolk in the state of Massachusetts, 12345.
2) The parties were married in Boston, Massachusetts on April 5, 2003 and last lived together at 123 West Golf Road, Boston, Massachusetts on November 7, 2013.
3) Plaintiff has lived in the Commonwealth of Massachusetts for at least twelve months preceding the filing of the complaint.
4) The minor or dependent children of this marriage are: David Bean Jr. born on June 5, 2005 Patricia Bean born on July 1, 2008
5) The minor or dependent children are residing with plaintiff at above said estate of 123 West Golf Road, Boston, Massachusetts.
6) Plaintiff certifies that no previous action for divorce, annulment or affirmation of marriage, separate support, desertion, living apart for justifiable cause or custody of children has been brought by either party against the other except for this action. The plaintiff received a high school principal job offer in Westerly, Rhode Island, which plaintiff turndown due to defendant’s refusal to relocate there. As a result, the marriage began to deteriorate with the plaintiff and defendant arguing in the presence of the children. The plaintiff received a second offer for the same job that included a substantial salary increase and a pension plan, short term and long term disability, medical and dental insurance for the plaintiff’s family. However, the defendant still refused to relocate.
7) Therefore, on or about November 7, 2013 an
Return Date: _______ The Trial Court Complaint Date: 12/10/2013
Probate and Family Court Department
COMPLAINT FOR DIVORCE PURSUANT TO G.L. c. 208 § 1B
Patty Bean, Plaintiff V. David Bean, Defendant
1) Plaintiff who resides at123 West Golf Road, in the city of Boston, in the county of Suffolk in the state of Massachusetts, 12345 was lawfully married to the defendant who resides at 456 East Lark Street, in the city of Boston, the county of Suffolk in the state of Massachusetts, 12345.
2) The parties were married in Boston, Massachusetts on April 5, 2003 and last lived together at 123 West Golf Road, Boston, Massachusetts on November 7, 2013.
3) Plaintiff has lived in the Commonwealth of Massachusetts for at least twelve months preceding the filing of the complaint.
4) The minor or dependent children of this marriage are: David Bean Jr. born on June 5, 2005 Patricia Bean born on July 1, 2008
5) The minor or dependent children are residing with plaintiff at above said estate of 123 West Golf Road, Boston, Massachusetts.
6) Plaintiff certifies that no previous action for divorce, annulment or affirmation of marriage, separate support, desertion, living apart for justifiable cause or custody of children has been brought by either party against the other except for this action. The plaintiff received a high school principal job offer in Westerly, Rhode Island, which plaintiff turndown due to defendant’s refusal to relocate there. As a result, the marriage began to deteriorate with the plaintiff and defendant arguing in the presence of the children. The plaintiff received a second offer for the same job that included a substantial salary increase and a pension plan, short term and long term disability, medical and dental insurance for the plaintiff’s family. However, the defendant still refused to relocate.
7) Therefore, on or about November 7, 2013 an