PETITION FOR DISSOLUTION OF MARRIAGE
Petition is for dissolution of marriage and it is alleged on oath as
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.
Petitioner and Respondent were married on January 14, 2000 in the
state of Missouri and the marriage is registered in Cole County,
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.
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”.
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
There is no reasonable likelihood that the marriage between
Petitioner and Respondent can be preserved, and therefore, the marriage
is irretrievably broken.
Petitioner prays for its orders:
dissolving the marriage between the Petitioner and Respondent;
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;
and granting such other and further relief as to this Court seems
just and proper in the circumstances.
wishes to retain the last name of Stinson upon the date of the divorce.
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.
My commission expires: