Fillable Printable Answer and Counterclaim of Defendant to Complaint for Divorce - Massachusetts

Answer and Counterclaim of Defendant to Complaint for Divorce - Massachusetts

Family Law Advocacy for Low and Moderate Income Litigants, 2nd Edition 2008

EXHIBIT 5E—Answer and Counterclaim

of Defendant to Complaint for Divorce

COMMONWEALTH OF MASSACHUSETTS

Suffolk, ss.Probate and Family Court Dept.

Docket Number No. 000000

)

Sheila Jones,)

Plaintiff)

)

v.)

)

Stanley Jones,)

Defendant)

)

DEFENDANT’S ANSWER AND COUNTERCLAIMS

Defendant, Stanley Jones, submits the following answer and counterclaims to plaintiff’s complaint for divorce:

1.Defendant admits in part and denies in part the allegations set forth in paragraph 1 of the Complaint for

Divorce. Defendant admits that the plaintiff resides at 1234 High Street, Melrose, MA. However, defendant

denies that he resides at 8765 Main Street, Woburn, MA. Defendant resides at 5678 Cedar Street, Woburn, MA.

2.Defendant admits the allegations set forth in paragraph 2 of the Complaint.

3.Defendant admits the allegations set forth in paragraph 3 of the Complaint.

4.Defendant admits the allegations set forth in paragraph 4 of the Complaint.

5.Defendant admits the allegations set forth in paragraph 5 of the Complaint.

COUNTERCLAIM FOR DIVORCE

6.Defendant adopts and pleads the allegations set forth in paragraphs 2 through 5 of the plaintiff’s complaint for

divorce and paragraph 1 as corrected above.

WHEREFORE, defendant requests that the Court:

(a)grant a divorce for irretrievable breakdown pursuant to G.L. c. 208, § 1B;

(b)grant defendant custody of the minor child, Maria Louisa Jones;

(c)order plaintiff to pay a suitable amount of child support;

(d)order a division of marital property; and

(e)other relief as this Court deems just.

Respectfully submitted

by himself,

____________________

Stanley Jones

Date:

Family Law Advocacy for Low and Moderate Income Litigants, 2nd Edition 2008

CERTIFICATE OF SERVICE

I, Stanley Jones, certify that, on June 20, 2007, I served a copy of Defendant’s Answer and Counterclaims upon

plaintiff Sheila Jones, Framingham, MA 01701, by first-class mail.

____________________

Stanley Jones