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Fillable Printable Petition for Dissolution of Marriage - Missouri
Fillable Printable Petition for Dissolution of Marriage - Missouri
Petition for Dissolution of Marriage - Missouri
1
IN THE CIRCUIT COURT OF ST. CHARLES COUNTY, MISSOURI
FAMILY COURT DIVISION
In Re the Marriage of: )
)
JANE DOE )
)
Petitioner, )
)
vs. ) Cause No.
) Division
)
JOHN DOE )
)
Respondent. )
PETITION FOR DISSOLUTION OF MARRIAGE
1. That Petitioner is and has been a resident of the State of Missouri for ninety (90)
days immediately preceding the filing of this Petition, now residing at 2 Oak
Lane, Mayberry, Missouri.
2. Respondent has been a resident of the State of Missouri for more than ninety (90)
days immediately preceding the filing of this Petition, now residing at 5 Pear Tree
Lane, Mayberry, Missouri.
3. The last four digits of Petitioner’s Social Security Number are xxx-xx-1234 and
Petitioner is currently employed.
4. The last four digits of Respondent’s Social Security Number are xxx-xx-4321
and Respondent is currently employed.
5. Petitioner and Respondent were married in Mayberry, Missouri on June 9, 1997.
Said marriage is registered in St. Charles County, Missouri.
6. Petitioner and Respondent were separated on or about January 1, 2010.
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7. Petitioner is not pregnant.
8. That there is no reasonable likelihood that the marriage of the parties can be
preserved and, therefore, the marriage of the parties is irretrievably
broken.
9. Attached to this Petition are Petitioner’s:
Statement of Income & Expense
Financial Statement
Proposed Parenting Plan
Form 14
which are hereby incorporated by reference as if fully set forth herein.
10. The Petitioner and Respondent have accumulated property during the
course of the marriage, as well as certain obligations and
Petitioner requests that the marital property and debts be
divided in a fair and equitable manner. The Petitioner requests
the Court set over to each their separate/non-marital property.
11. Petitioner is without adequate funds and assets with which to
pay counsel and the costs that may accrue herein and would respectfully
request a reasonable amount of attorney fees.
12. There has been two (2) minor children born while parties were
married, to-wit:
Johnny Doe, Jr Age: 12 SSN: xxx-xx-5555
Elizabeth Doe Age: 9 SSN: xxx-xx-4444
13. For the sixty (60) days immediately prior to the filing of this matter the
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minor children have resided as follows:
At 2 Oak Lane, Mayberry, Missouri
14. Petitioner has not participated in any capacity in any other
litigation concerning the custody of the minor children herein in this or any other
State.
15. Petitioner has no information of any custody proceedings
concerning the said minor children pending in a Court of this or any other
state.
16. Petitioner knows of no person not a party to these proceedings
who has actual physical custody of the minor children herein or claims to
have custody or visitation rights with respect to said minor children herein.
17. Petitioner states that it would be in the best interest of the minor
children herein if their care, custody and control were placed in and
awarded to Petitioner and Respondent all as more specifically set forth in her
Parenting Plan attached hereto and incorporated herein by reference as if fully
set forth.
18. Neither the Petitioner nor the Respondent is a member of any of the Armed
Forces of the United States of America.
WHEREFORE, Petitioner prays that an order and Judgment of Dissolution of Marriage
entered as follows:
That the marital property of Petitioner and Respondent should be equitably
divided between the Petitioner and Respondent;
That the Court set over to each party their separate property.
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That the Petitioner and Respondent should be given the care, custody and
control of the minor children born to the marriage of the parties, pursuant
to the Parenting Plan filed herein.
That the Court should make adequate provisions for the support of said
minor children herein.
That Respondent be ordered to pay Petitioner’s reasonable attorney fees
and costs herein incurred.
For such other Orders as the Court may deem just and proper under the
circumstances and as allowed and provided by law.
Watkins Law Firm, P.C.
______________________________ By: ______________________________
Jane Doe Michael B. Watkins #24071
Petitioner Attorney for Petitioner
9979 WingHaven Blvd., Suite 210
O’Fallon, MO 63368
636-625-6448 Office
636-625-3721 Fax
[email protected] E-mail
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STATE OF MISSOURI )
) ss.
COUNTY OF _______________________ )
COMES NOW Jane Doe, of lawful age, being duly sworn, upon her oath, acknowledges
that she has read the foregoing and that the statements contained therein are true and correct to
her best knowledge and belief.
_________________________________
Jane Doe, Petitioner
Subscribed and sworn to before me, a Notary Public, at my office in the County and State
aforesaid, on this ______ day of _________________________, 2010.
_________________________________
Notary Public
My Commission Expires:
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