___________________________________,. . . . . . . . . . . . . . . . . . . PLAINTIFF, VS. CAUSE NUMBER 54-DR-2014-_________-______ ___________________________________,. . . . . . . . . . . . . . . . . . DEFENDANT. COMPLAINT FOR DIVORCE Comes now the plaintiff, PRO SE, and for her cause of action states: 1. JURISDICTION is invoked pursuant to the provisions of Ark. Code Ann. 9-12- 301 ET SEQ. 2. MARRIAGE AND SEPARATION: Plaintiff and Defendant were married on _____________________, in Phillips County, Arkansas and they last lived together as husband and wife on or about ___________________________ 3. RESIDENCE: Plaintiff is a resident of Phillips County, Arkansas and has so resided for more than 60 days immediately prior to the bringing of this action. Defendant is a resident of Phillips County, Arkansas. Defendant is a life-long resident of Phillips County, Arkansas. 4. CHILDREN: No children were born during this marriage and none are expected. Plaintiff and Defendants are the parents of no children together.. 5. CUSTODY: Plaintiff is presently in custody of the minor children and is the fit and proper person to maintain custody of the children. Defendant _______________ VS _______________ COMPLIANT FOR DIVORCE PAGE 1 OF 3 should be ordered to pay such support as is reasonably calculated to assist in proper nurturing of the minor children consistent with the Arkansas Family Support Chart. 6. PROPERTY: The parties, as husband and wife, have acquired no real property during their marriage and all of the personal property has been divided prior to the separation. All other property was divided prior to the filing of this complaint. 7. GROUNDS FOR DIVORCE: The grounds for this divorce are pursuant to Ark. Code Ann. 9-12-301 ET SEQ. 8. RESTRAINING ORDER: That a Temporary Restraining Order is necessary in order to preserve peace and harmony pendite lite. 9. FEES AND COSTS: That the plaintiff is entitled to recover reasonable attorneys fees and costs in this matter. WHEREFORE, PREMISES CONSIDERED, the plaintiff, prays that the bonds of matrimony heretofore existing between her and the Defendant be dissolved, set aside and forever held for naught, and that the Plaintiff shall have an absolute divorce from Defendant; that the Plaintiff be granted the property requested in Paragraph 5; that her maiden name ______________________ be restored; that the Defendant be Temporarily Restrained from Plaintiff, her home, and ; her work place; that Plaintiff recover her costs including attorneys fees and for any and all other relief to which Plaintiff may be entitled. Respectfully submitted on July 9, 2014 _____________________________, Plaintiff Name:___________________________ Address:_________________________ Address:_________________________ _______________ VS _______________ COMPLIANT FOR DIVORCE PAGE 2 OF 3 Phone Number: ______________________ Verification I, the undersigned, do hereby affirm that the statements made above have been read by me and I have found them to be true and correct to the best of my knowledge and information. I make this statement under penalty of perjury. By: __________________________, Plaintiff Subscribed and sworn to before me, a Notary Public on this the ______ day of July, 2014. My Commission Expires: Notary Public
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