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

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

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
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