IN THE CIRCUIT COURT OF COLE COUNTY, MISSOURI 

IN RE THE MARRIAGE OF

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Jean Alicia Johnson

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  101 Elm Street

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Jefferson City, Missouri 65101

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SS#: 456-65-6890   

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                                      Petitioner,

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            CASE NO. ________

 

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And

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            Division       ________

 

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John Henry Johnson

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123 Standing Creek Drive

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Jefferson City, Missouri  65101

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SS#: 298-56-5032

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                                    Respondent.

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PETITION FOR DISSOLUTION OF MARRIAGE            

This Petition is for dissolution of marriage and it is alleged on oath as follows: 

            1.         Petitioner resides at 101 Elm Street, Jefferson City, Missouri 65101 and has resided in the State of Missouri for at least ninety (90) days immediately prior to the filing of this Petition.

            2.         Petitioner and Respondent were married on January 14, 2000 in the state of Missouri and the marriage is registered in Cole County, Missouri.  

            3.         The parties separated on or about March 24, 2001.  

            4.        There are two minor children born to or adopted by the Parties. The names and dates of birth are: Cindy Alice Johnson, 01/21/01; Mark Anthony Johnson, 02/28/03. The wife is not now pregnant.

            5.         Petitioner and Respondent entered into an Agreement resolving all issues of the marriage, which is recorded in their Property Settlement Agreement and Child Care Plan, a true and correct copy of which is attached to this Complaint as Exhibit A. 

            6.         Petitioner is employed by Acme Cleaners, 1879 Short Street, Johnson City, Missouri 65102 and Petitioner's social security number is 456-65-6890.   Respondent is employed by Mason Brick Construction, 1769 Crescent Avenue, Jefferson City, Missouri 65103 and Respondent's social security number is 298-56-5032 .  

            7.       There is no reasonable likelihood that the marriage between Petitioner and Respondent can be preserved, and therefore, the marriage is irretrievably broken. 

WHEREFORE, Petitioner prays for its orders: 

            a.         dissolving the marriage between the Petitioner and Respondent; 

            b.         dividing the marital property between Petitioner and Respondent according to law and settling all marital and non-marital property and debts of the parties and resolving child issues as specified in the attached Property Settlement Agreement and Child Care Plan;  

c.         and granting such other and further relief as to this Court seems just and proper in the circumstances. 

            Wife wishes to retain the last name of Stinson upon the date of the divorce.

 

___________________________________

Signature of Petitioner

Jean Alicia Johnson

 

 

 

STATE OF MISSOURI

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)ss.

County of Jefferson

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On this _____ day of _________________, _____ before me the undersigned notary public, personally appeared ________________________, the Petitioner herein, who executed the foregoing Petition and acknowledged that the statements contained therein are true and correct.

 

                                                                                    ___________________________________

Notary Public

My commission expires:

 

_________________