Simple Bill of Complaint for Divorce
[No children; Uncontested based on separation; PSA]
VIRGINIA:
IN THE CIRCUIT COURT FOR FAIRFAX COUNTY
MARY Z. MISREY
Plaintiff,
vs.
JOHN V. MISREY
Defendant.
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CL NO: 07 - 12345
COMPLAINT FOR DIVORCE
COMES NOW the Plaintiff, by counsel, and as and for her Complaint for
Divorce, she states as follows:
1. The parties hereto were lawfully married to each other on June 15, 1985
in Arlington, Virginia.
2. There were no children born or adopted of the marriage.
3. Both parties hereto are over the age of eighteen years. Neither party is an
active duty member of the Armed Forces of the United States.
4.
The Plaintiff is a resident and bona fide domiciliary of the
Commonwealth of Virginia and has been for more than six months prior to the
filing of this suit. The parties last cohabited as husband and wife in Fairfax
County, Virginia. .
5. The parties separated and ceased cohabiting together as husband and
wife on September 6, 2005, with the intent to terminate the marriage. They have
remained separated without any cohabitation and without interruption since the
aforesaid date, and their intention to remain separate has continued to the present
time, constituting a period now in excess of one year.
6. The parties have entered into a written Property Settlement Agreement
dated January 22, 2007, which Agreement resolves all matters of property and
support between them.
WHEREFORE, your Complainant prays:
a. That she be granted a divorce a vinculo matrimonii on the grounds that
the parties have lived separate and apart from each other, without any
cohabitation, for more than one year, pursuant to Virginia Code §20-91 (9);
b. That the parties’ Property Settlement Agreement of January 22, 2007 be
ratified, affirmed and incorporated, but not merged, into the Final Decree of
Divorce entered in this matter pursuant to Virginia Code §20-109.1.
Respectfully submitted,
Mary Z. Misrey,
By Counsel
Counsel for Complainant
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