I. Jurisdiction
1.1. This Court has jurisdiction over this matter pursuant to [state specific statute, e.g., “Texas Family Code § 6.301”].
1.2. Petitioner has been a domiciliary of the State of [State] for at least six (6) months and a resident of [County] for at least ninety (90) days preceding the filing of this Petition.
II. Parties
2.1. Petitioner: [Full Name], residing at [Petitioner’s Address].
2.2. Respondent: [Full Name], believed to reside at [Respondent’s Address].
III. Marriage
3.1. Petitioner and Respondent were lawfully married on [Date of Marriage] in [City, State].
3.2. The parties ceased to live together as husband and wife on or about [Date of Separation].
IV. Grounds for Divorce
4.1. The marriage has become insupportable because of discord or conflict of personalities that destroys the legitimate ends of the marital relationship, and there is no reasonable expectation of reconciliation.
[Optional Additional Grounds, if applicable]:
4.2. Respondent has committed acts of adultery.
4.3. Respondent has engaged in cruel treatment towards Petitioner that renders further living together insupportable.
V. Children of the Marriage
5.1. [Select one:]
- There are no children born to or adopted by the parties during the marriage, and no children are expected.
- There are [number] children of the marriage: [Child’s Full Name], born on [DOB], and [Child’s Full Name], born on [DOB].
5.2. Petitioner requests the Court determine conservatorship, possession, access, and child support in the best interest of the children pursuant to [state statute, e.g., “Texas Family Code § 153.002”].
VI. Property Division
6.1. Petitioner believes the parties have accumulated community property during the marriage. Petitioner requests that the Court divide the marital estate in a manner that is just and right under [state statute, e.g., “Texas Family Code § 7.001”].
6.2. Petitioner also requests confirmation of separate property, including but not limited to:
- [Description of Separate Property, e.g., “Inheritance from family member”].
VII. Spousal Maintenance
7.1. [Optional] Petitioner requests spousal maintenance in accordance with [state statute, e.g., “Texas Family Code § 8.051”], as Respondent has the ability to pay and Petitioner lacks sufficient property or earning ability to meet their reasonable needs.
VIII. Prayer
WHEREFORE, PREMISES CONSIDERED, Petitioner respectfully prays that upon final hearing, the Court:
- Grant a divorce dissolving the marriage between Petitioner and Respondent;
- Award a just and right division of the marital estate;
- Confirm Petitioner’s separate property;
- Determine conservatorship, possession, access, and child support in the best interest of the children, if applicable;
- Award spousal maintenance, if applicable; and
- Grant such other and further relief as the Court deems just and proper.
