Fillable Printable Divorce Complaint Example - Alabama
Fillable Printable Divorce Complaint Example - Alabama
Divorce Complaint Example - Alabama
DOCUMENT I
IN THE CIRCUIT COURT
FOR TUSCALOOSA COUNTY, ALABAMA
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ELECTRONICALLY FILED
8/28/2015 9:23AM
63-DR-20 15-900426.00
CIRCUlT COURT OF
TUSCALOOSA COUNTY, ALABAMA
MAGARIA HAMNER BOBO, CLERK
DIANNE JONES BENTLEY
Plaintiff,
v.
ROBERT J. BENTLEY
Defendant.
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CASE NO.
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) DR
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COMPLAINT
1.
Plaintiff and Defendant are both over the age of nineteen (19) years, are bona fide
residents of the state of Alabama and have been residents of the state of Alabama for more than
six (6) months next preceding the filing of this Complaint.
2.
Plaintiff and Defendant were lawfully married to each other on or about July 24,
1965, and lived together thereafter as husband and wife until they separated on or about January
2015.
3.
There were four (4) children of the marriage, all having attained the age of
majority, and the Plaintiff is not pregnant.
4.
Plaintiff states that there is such a complete incompatibility of temperament that
the parties can no longer live together. That there exists a conflict of personalities which
destroys the legitimate aims of matrimony and all possibilities of reconciliation are futile.
5.
Plaintiff further avers that their marriage has suffered an irretrievable breakdown
and that further attempts at reconciliation are impractical and not in the best interests of the
parties.
6.
Plaintiff states that the Plaintiff and Defendant have accumulated, during the
marriage of the parties, an interest in or title to certain properties including cash, real estate,
furniture, furnishings, automobiles, and other property.
7.
Plaintiff further avers that the Plaintiff and Defendant have incurred certain debts
during the marriage of the parties.
8.
Plaintiff further avers that she is without sufficient funds with which to support
herself and to pay her attorney of record for his services rendered to her in this cause. Plaintiff
DOCUMENT I
Complaint
Bentley v. Bentley
Page2
further avers that the Defendant is an able-bodied man, gainfully employed, and is well able to
pay the debts of the parties incurred during the marriage, to pay to the Plaintiff a reasonable sum
for her support and maintenance, and to pay to the Plaintiff a reasonable sum with which to pay
her attorney of record for his services to her in this cause.
WHEREFORE, PREMISES CONSIDERED,
Plaintiff prays that the Court will take
jurisdiction of this cause, that the said
ROBERT J. BENTLEY
be made a party defendant to this
Complaint, that service of process be issued to him as required by law and the rules of this
Honorable Court, making him a party defendant to this cause and requiring him to plead, answer
or otherwise defend this action within the time prescribed by law and the rules of this Court; or,
failing that, suffer a default judgment against him. Further, that upon a final hearing of this
cause, your Honor will grant to the Plaintiff an absolute divorce from the Defendant.
Plaintiff further prays that the Court will make an equitable and fair division of all
personal property acquired by the parties during the marriage.
Plaintiff further prays that the Court order the Defendant to pay to Plaintiff a fair amount
for alimony in gross and also pay to her periodic alimony.
Plaintiff further prays that the Court will award to her sole title to the real property
acquired by the parties during the marriage.
Plaintiff further prays that the Court order the Defendant to pay the debts incurred by the
parties during the marriage.
Plaintiff further prays that the Court order the Defendant to pay to her a reasonable sum
with which to pay her attorney of record.
Plaintiff prays for such other, further, different or more general relief to which she may be
entitled.
DIANNEBE EY
STATE OF ALABAMA)
f\--r-A- .<. f}
COUNTY)
Before me, the undersigned, a Notary Public in and for said County and State, personally
appeared 1 DIANNE BENTLEY, who, being first duly sworn, deposes and says that
DOCUMENT I
Complaint
_Bentley v. Bentley
Page3
the matters and things contained in the foregoing Complaint are true and correct to the best of her
knowledge and information.
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Sworn to and subscribed before me
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ENWRIGHT,
Attorney for Plaintiff
NAJJAR DENABURG, P.C.
2125 Morris Avenue
Birmingham, AL 35203
(205) 250-8464
Plaintiffs Address:
11 Ridgeland
Tuscaloosa, AL 35406
Defendant's Address:
1142 South Perry Street
Montgomery, AL 36104
