Unit 5 Midterm Project
Draft a Divorce Complaint
Prof: Stacey Calloway
Commonwealth of Massachusetts
Complaint for Divorce
Patty Bean, Plaintiff v. David Bean, Defendant
Plaintiff and Defendant were married on the 5th day of April 2000, and lived together at 123 West Golf Road, Boston, Suffolk, MA 12345
Plaintiff currently resides at 123 West Golf Road, Boston, MA, 12345 and has so for the last 5 years.
Defendant, David Bean, currently resides at 456 East Lark Street, Boston, MA 12345.
A copy of the marriage license has been attached hereto
The parties are not members of the military.
Plaintiff has lived in the Commonwealth of Massachusetts for at least twelve months preceding the filing of the complaint.
There are minor or dependent children of this marriage
David Bean Jr. born on June 5, 2005
Patricia Bean born on July 1, 2008
The children are residing with the plaintiff at 123 West Golf Road, Boston, Massachusetts.
Plaintiff …show more content…
c. 208 § 1, 1A, and 1B. The parties’ career paths had led to deterioration of the marriage, and neither can reconcile an agreement to saving their marriage. The career paths of the two parties are separate and distinct and the parties can reach no mutual understanding or agreement for reconciliation of the marriage. Defendant Bean moved from the family home due to. One year prior, Patty was offered the same offer with a 15% salary increase; to be a high school principal at a high school in Westerly, Rhode Island, however, David Bean would not allow her to relocate with the children since it is 100 miles from Boston. There was a substantial salary increase and benefits that include a pension plan, short term and long term disability, medical and dental insurance for her and her family. Once again, David refused to relocate. Therefore, she is filing for divorce. She believes her marriage to be irretrievably