Beruflich Dokumente
Kultur Dokumente
STATE OF ALABAMA
VKW
Respondent PETITION FOR DIVORCE
COMES NOW, PMW. who files this Verified Petition for Divorce.
PARTIES
636 Wildass Dr., Pelham, AL 35124, his phone number is (205) xxx-xxxx; and
3. Respondent’s full name is VLW, her maiden name is Xxxxx; she is 26 years
old, and currently resides at 821 Roundtree Plaza, AL 35064, her phone number is
6. Petitioner and Respondent have one female child born into their marriage,
whose name is KAW, and whose date of birth is August 16, 2005, and who is
pregnant.
JURISDICTION
8. This Court is that of proper jurisdiction to hear this cause; it has been filed in
the circuit court of the county in which the Respondent resides, in compliance with
§30-2-4.
other proceeding involving the other party in this or any other jurisdiction with
2009, and was schedule to be released just before Thanksgiving, had her mother
advise Petitioner that Respondent wanted Petitioner moved from the marital home
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before she arrived back from the hospital.
11. Petitioner, without having talked with Respondent, and believing the request
was for a temporary basis, and that Respondent just needed a little space and to
have some time to herself, complied with the request and left their home.
unknown male entity that, from all appearances, and to the best of Petitioner’s
knowledge and belief, is living with and having an adulterous relationship with
13. Petitioner, who had previously been the primary caregiver, has been denied
all parental rights, and all contact with, including but not limited to telephone
conversations, his daughter, and has not been allowed visitation with his daughter
at all.1
14. Petitioner wishes a dissolution of marriage based on the grounds that there
has been an irretrievable breakdown of the marriage and that further attempts at
reconciliation are impractical or futile and not in the best interests of the parties or
family.
15. Petitioner and Respondent have not communicated with one another since
1 The rights to … raise one’s children have been deemed ‘essential,’ Meyer v
Nebraska, ... ‘basic civil rights of man,’ Skinner v Oklahoma, 316 US 535, 541
(1942), and ‘[r]ights far more precious ... than property rights,’ May v Anderson,
345 US 528, 533 (1953)
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before Thanksgiving 2009; they have not discussed or entered into a Marital
CUSTODY/VISITATION
16. During the marriage, one child was born to Petitioner and Respondent:
17. After the birth of Petitioner’s daughter, Petitioner worked night shift so that
18. Petitioner spent the entire day, every day, with the child while the mother
was at work; he was at home when the child awoke, and home when the child went
to sleep at night. Petitioner was more the primary caregiver than the Respondent
was.
19. Because Respondent and the male entity living with her, have barred any
contact between Petitioner and his child, the presumption is that Respondent and
the male entity have been undermining the relationship between Petitioner and his
child.
20. The male entity at Respondent’s home has verbally abused Petitioner, using
foul language unfit for a child, when Petitioner has attempted to telephone
Respondent or the child; the presumption is that Respondent and the male entity
have indeed hurt the relationship between Petitioner and his daughter.
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21. Respondent’s refusal to allow visitation or even communication between
Petitioner and his daughter, shows that there will be visitation interference should
the daughter and Respondent should he be granted sole physical and legal custody.
23. For the above stated reasons, this Court should grant sole physical and legal
24. Petitioner would find a fair and equitable visitation schedule for Respondent
2 In Troxel v. Granville, 530 U.S. 57 (2000), the United States Supreme Court
issued a landmark opinion on parental liberty, and said: “In subsequent cases also,
we have recognized the fundamental right of parents to make decisions concerning
the care, custody, and control of their children…Wisconsin v. Yoder, 406 U.S. 205,
232, 32 L. Ed. 2d 15, 92 S. Ct. 1526 (1972) ("The history and culture of Western
civilization reflect a strong tradition of parental concern for the nurture and
upbringing of their children. This primary role of the parents in the upbringing of
their children is now established beyond debate as an enduring American
tradition"); Quilloin v. Walcott, 434 U.S. 246, 255, 54 L. Ed. 2d 511, 98 S. Ct. 549
(1978) ("We have recognized on numerous occasions that the relationship between
parent and child is constitutionally protected"); Parham v. J. R., 442 U.S. 584,
602, 61 L. Ed. 2d 101, 99 S. Ct. 2493 (1979) ("Our jurisprudence historically has
reflected Western civilization concepts of the family as a unit with broad parental
authority over minor children. Our cases have consistently followed that course");
Santosky v. Kramer, 455 U.S. 745, 753, 71 L. Ed. 2d 599, 102 S. Ct. 1388 (1982)
(discussing "the fundamental liberty interest of natural parents in the care, custody,
and management of their child"); Glucksberg, supra, at 720 ("In a long line of
cases, we have held that, in addition to the specific freedoms protected by the Bill
of Rights, the 'liberty' specially protected by the Due Process Clause includes the
right ... to direct the education and upbringing of one's children" (citing Meyer and
Pierce)). In light of this extensive precedent, it cannot now be doubted that the Due
Process Clause of the Fourteenth Amendment protects the fundamental right of
parents to make decisions concerning the care, custody, and control of their
children. [emphasis supplied]
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acceptable and would not interfere with visitation, or attempt to undermine or
25. Should the Court find custody in favor of Respondent, Petitioner requests
“Exhibit A”
PROPERTY
26. Prior to or during the marriage, the Petitioner acquired the separate property
listed on the attached “Exhibit B”. That property should be confirmed as the
27. Petitioner and Respondent rented their residence, so there is no real property
involved.
28. During the marriage, Petitioner and Respondent acquired several items, none
of which Petitioner has any wish to have as his own; therefore, there is no
29. It would be fair and equitable for the Petitioner and Respondent to be
responsible for their own debts, and hold the other harmless for any further liability
3 The only one thing Petitioner really wants that was part of the marriage, is his
daughter, and his Right to be a parent, part of her rearing, and prevent being
alienated from her.
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30. Petitioners and Respondent have been separated since November 2009, it
would be fair and equitable for the court to order that each party will be
responsible for and pay any debt incurred by that party since the date of separation.
The court should order each party to pay those debts as or before they become due
and to hold the other party harmless from any obligation concerning those debts.
31. Should Respondent desire to have her maiden name returned, Petitioner has
no objection.
32. Wherefore Petitioner requests that the Court enter JUDGMENT FOR
DIVORCE and such further relief as Petitioner may have requested herein.
By: ___________________________
PMW Pro Se
636 Wildass Dr.
Pelham, AL 35124
(205) xxx-xxxx
VERIFICATION
I, PMW., on this ____ day of February, 2010 after first being duly sworn, state that
I am the person described in the above document as Petitioner, and that I signed
the above document in the presence of a Notary, and Verified that the information
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contained in the foregoing Petition for Divorce is true and correct, based on first-
hand personal knowledge, and that I signed the document as a free and voluntary
act for the purposes stated therein.
___________________________
PMW
Seal
______________________________
NOTARY PUBLIC, State of Alabama
MY Commission Expires: ___________