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IN THE CIRCUIT COURT FOR _________COUNTY, ALABAMA

_____________________________, )
Plaintiff )
)
vs ) CIVIL ACTION NO. ____________
)
_____________________________, )
Defendant )

COMPLAINT

The Plaintiff brings this Complaint against the Defendant and respectfully shows unto the
Court as follows:

l. The Plaintiff and Defendant are over the age of 18 years and are bona fide residents
of _________________County, Alabama, having so resided for six months next preceding the filing
of this Complaint.

2. The parties were married to each other on ___________________ in


__________________________ and have lived together as husband and wife until on or about
__________________________, when they separated and have not lived together as husband and
wife since that date.

3. There [has or have] been ______ [child or children] born unto the parties; namely,
_____________________, a [boy or girl], approximately _____ years of age;
____________________, a [boy or girl], approximately _______years of age.

4. The parties are incompatible and their tastes, natures, views, likes and dislikes have
become widely separated and divergent so that the parties have been and are at the time of the filing
of this Complaint, incompatible to such an extent that it is impossible for them to live together as
husband and wife; there is no possibility of a reconciliation between the parties hereto and there
remains such an incompatible temperament between them that a happy marital status can no longer
exist.

5. The parties have entered into a Settlement Agreement which has been filed
concurrently with this Complaint.

WHEREFORE, THE PREMISES CONSIDERED, the Plaintiff prays that, upon a final
hearing of this cause, the Court will grant to the plaintiff a Divorce A VINCULO MATRIMONII
from the Defendant.

Complaint
______________________________
Attorney for Plaintiff
(firm name), (address), (phone number)

Complaint

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