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INTHECHANCERYCOURTOFPEARLRIVER

COUNTY
STATEOFMISSISSIPPI
INTHEMATTEROFTHEDISSOLUTIONOF
MARRIAGEOF
SHELLYLINMCGEHEE
AND
MICHEALEDMONDMCGEHEEJR
BYJOINTCOMPLAINT

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CASENO.

JOINTCOMPLAINTFORDIVORCE
COMES NOW, SHELLYLINMCGEHEE and MICHAELEDMONDMCGEHEE
JR, Husband and Wife, and file this Joint Complaint for Divorce and in support hereof would
show unto the Court the following, to-wit:
1.

This Court has jurisdiction of the parties and subject matter pursuant to the laws of

the State of Mississippi.


2.

The Parties are actual and bona fide adult resident citizens of PEARLRIVER

County, Mississippi, and have been for more than six (6) months next preceding the filing of this
Joint Complaint.
3.

The Parties were married on the 15th day of September, 2007, and

separated in PEARLRIVER County,


Mississippi, on 13th day of MARCH, 2015.
4.

Since the date of said separation, the 13TH day of MARCH, 2015, the

Parties have not cohabited as husband and wife.

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5.

ThepresentaddressofthePartiesareasfollows:SHELLYLINMCGEHEE73

PEARIDGEROAD,PICAYUNE,MS39466
MICHAELEDMONDMCGEHEEJR130ALANROADCARRIERE,MS39426

6.

ThePartiesallegethattheyareentitledtoaDivorceonthegroundsofirreconcilable

differences.
7.

Thereisnoreasonableexpectationthatthepartieswillreconcile.

8.

There are ONE minor child(ren) of the marriage; namely,

DESTYNEJEAND.MCGEHEE, born 5th day of MAY, 2008,

, born day of , 20,

, born day of , 20,

,born

dayof

,20

.
9.

Neitherpartyhasparticipated,asaparty,witness,orinanyothercapacity,inany

otherlitigationconcerningthecustodyoftheparties'minorchildreninMississippioranyotherstate.
10.

Neitherpartyhasanyknowledgeofanycustodyproceedingconcerningtheparties'

minorchildrenpendinginacourtofMississippioranyotherstate.
11.

Neitherpartyknowsofapersonnotapartytothisproceedingwhohasphysical

custodyoftheparties'minorchildrenorwhoclaimstohavecustodyorvisitationrightswithrespect
totheparties'minorchildren.
12.

All matters involving custody and support of the above named children have been

resolved and the terms agreed to in the Separation and Property Settlement Agreement attached
herein as Exhibit A.

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13.

All matters involving property of the marriage, both real and personal, have been

resolved and the terms agreed to in the Separation and Property Settlement Agreement. All debts
have likewise been resolved by the parties in the Separation and Property Settlement Agreement
attached herein as Exhibit A.
14.

Party , requests that her former name of

be restored unto her. This request is not made for any illegal or
fraudulent reason.
15.

The Parties further state the following:


We do not know of any other cases in the State of Mississippi or any other state or
territory involving the same claim or subject matter as this case.
OR
We know of the following related cases concerning the same claim or subject matter
as this case.

WHEREFORE, PREMISES CONSIDERED, SHELLYLINMCGEHEE and


MICHAELEDMONDMCGEHEEJR pray that:
(A)

The Court grant the parties a Divorce on the grounds of irreconcilable differences;

(B)

That the terms of the Separation and Property Settlement Agreement in which all

issues of custody and support of the children of the marriage are resolved and which disposes of all
jointly owned property and settling all jointly owed debts and rights and liabilities of the parties, a
copy of which is attached hereto as Exhibit A, be incorporated into the final judgement of divorce:
(C)

For judgment and relief as set forth in this Complaint.

(D)

For such other relief and judgment as is just and equitable in the premises
Respectfully submitted,

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Husbands Printed Name MICHAELEDMOND


MCGEHEEJR
Husbands Signature
Wifes Printed Name SHELLYLINMCGEHEE
Wifes Signature

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STATE OF MISSISSIPPI
COUNTY OF PEARLRIVER
PERSONALLY appeared before me, the undersigned authority in and for the
county and state aforesaid, the within named, , one of the
Co-Plaintiffs, who, being by me first duly sworn, stated on oath that the matters, facts and
averments set forth, contained and alleged in the above and foregoing Joint Complaint for
Divorce are true and correct as therein stated.
Signature:
Print Name:
SWORN TO AND SUBSCRIBED this the day of , 20.
____________________________________
NOTARY PUBLIC
MY COMMISSION EXPIRES:
STATE OF MISSISSIPPI
COUNTY OF
PERSONALLY appeared before me, the undersigned authority in and for the
county and state aforesaid, the within named, , one of the
Co-Plaintiffs, who, being by me first duly sworn, stated on oath that the matters, facts and
averments set forth, contained and alleged in the above and foregoing Joint Complaint for
Divorce are true and correct as therein stated.
Signature:
Print Name:
SWORN TO AND SUBSCRIBED this the day of , 20.
____________________________________
NOTARY PUBLIC

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MY COMMISSION EXPIRES:

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