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COMES NOW the Petitioner, Jane Anderson, by and through her attorney, Mark
and has been for three months immediately prior to the filing of this action.
Fork, UT 84650, and has been a resident of the State of Utah for her entire life.
3. Respondent’s Residence. Respondent resides at 500 Eagle Lane, St. Paul,
Ramsey County, Minnesota 55123, and has been a resident of the State of Minnesota for
six months.
January 15, 2005, Provo, Utah County, State of Utah, and are presently married.
The Defendant has agreed to file an Affidavit of Consent in this cause. Neither the
Plaintiff nor Defendant has been involved in any litigation or other proceeding involving
the other party in this or any other jurisdiction with respect to their marriage or any other
domestic matter.
6. Grounds. For many months past, there have been numerous and
substantial irreconcilable differences that have arisen between the parties for which
8. Personal Property. The parties have acquired personal property. The use
of the personal property should be awarded as the parties have already divided it.
9. Vehicles. The Petitioner should be awarded the 2001 Honda Civic and
will hold the Respondent harmless from any obligations or encumbrances on the vehicle.
The Respondent should be awarded the 2003 Toyota Tundra and will hold the Petitioner
10. Debt. The parties acquired debts during the marriage. Each party will
assume, and hold the other harmless from liability on each and every debt incurred
solely in his or her own name. The Respondent will pay the jointly held credit card
11. Savings and Checking Accounts. The Petitioner and Respondent own a
savings account. The Petitioner should be awarded a greater proportion of this asset
13. Attorney Fees and Costs. Due to the Respondents ability to pay, the
Respondent will reimburse the Petitioner for all her reasonable attorney's fees and
______________________________
Mark Willis, Attorney for Petitioner
NOW, THEREFORE, Petitioner requests that the court order a DECREE OF
DIVORCE and such further relief as Plaintiff may have requested herein.
Verification
I, Jane Louise Anderson-Dixon, affirm under penalty of perjury that I am the Petitioner in
the foregoing COMPLAINT FOR DIVORCE and that all statements in this Petition are
accurate to the best of my knowledge. I have filed this Complaint in good faith and have
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_____________________________________________
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Petitioner's Signature Date
Acknowledgment Certificate
State of Utah )
§
County of Utah )
On this 4th day of December, in the year 2005, before me a notary public, personally
appeared Jane Louise Anderson-Dixon, who proved on the basis of satisfactory
evidence to be the person whose name is subscribed to this instrument, and
acknowledged (she) executed the same. Witness my hand and official seal.
_________________________
NOTARY PUBLIC