Complaint for Divorce

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE

COUNTY OF GUILFORD SUPERIOR COURT DIVISION

 

JENISE ANNETTE BONNER-POPE     § Case No. 21-CVD-2817

Plaintiff,     §

  1.     § AMENDED COMPLAINT FOR  
  •     ABSOLUTE DIVORCE

TODD POPE     §

Defendant.     §

 

NOW COMES Jenise Annette Bonner-Pope, Plaintiff, requesting for absolute divorce from Todd Pope, Defendant, and for cause would show this Honorable Court as follows:

  • PARTIES
  1. Plaintiff Jenise Annette Bonner-Pope is a female adult of sound mind and a resident of Insert Full Address, State and ZIP Code. She is married to Todd Pope.
  2. Defendant Todd Pope is a male adult of sound mind and a resident of Insert Full Address, State and ZIP Code. He is the husband of Jenise Annette Bonner-Pope.
  • JURISDICTION AND VENUE
  1. Jurisdiction exists in this court pursuant to North Carolina General Statute § 50-5.
  2. Venue is proper in this court because the causes of action occurred within Guilford County.
  • FACTS
  1. Plaintiff and Defendant got married on December 30th, 2015.
  2. Plaintiff and Defendant separated on January 5th, 2020.
  3. Plaintiff and Defendant have lived separately since the date of separation.
  4. Plaintiff intended for the separation to be permanent.
  5. There are no minor children who were born of the marriage of the parties, nor are the parties expecting any child(ren).
  6. There have been no previous proceedings between the parties respecting the marriage or its dissolution or respecting the maintenance of either party.
  • ALIMONY
  1. Plaintiff moves for alimony pursuant to North Carolina General Statute § 50-16.3A.
  2. Plaintiff is the dependent spouse and Defendant is the supporting spouse. Throughout the marriage, Plaintiff was dependent on Defendant for maintenance and support.
  3. Plaintiff wishes to obtain alimony from Defendant.
  4. Plaintiff did not engage in any form of marital misconduct prior to or on the date of separation.
  • POSTSEPARATION SUPPORT
  1. Plaintiff works as Insert Occupation at Insert Place of Work and earns Insert Amount Per Year in Dollars. The amount is not enough for Plaintiff to meet her reasonable needs.
  2. Defendant works as Insert Occupation at Insert Place of Work and earns Insert Amount Per Year in Dollars. As the supporting spouse, Defendant has the ability to pay postseparation support.
  3. Plaintiff wishes to obtain postseparation support from Defendant.
  4. Plaintiff did not engage in any form of marital misconduct prior to or on the date of separation.
  • PRAYER FOR RELIEF

REASONS WHEREFORE, Plaintiff respectfully requests this Honorable Court to grant the following reliefs:

  1. That the bonds of matrimony heretofore existing between Plaintiff and Defendant be dissolved and a judgment of absolute divorce be granted to Plaintiff from Defendant;
  2. That this Complaint be treated as an affidavit for purposes of Summary Judgment;
  3. That Plaintiff be allowed to resume the use of her maiden name. The name Plaintiff desires to resume is Bonner.
  4. Equitable distribution of property, both real and personal, acquired by the parties during the course of the marriage;
  5. Equitable allocation of marital debt;
  6. Award Plaintiff postseparation support;
  7. Award Plaintiff alimony;
  8. Award Plaintiff counsel fees;
  9. Such equitable relief as may be appropriate under the circumstances; and
  10. Award such further relief as this Honorable Court deems necessary and proper.

 

Respectfully Submitted,

______________________________

Jenise Annette Bonner-Pope

Insert Address

Insert State & ZIP Code

Insert Phone Number

Insert Email

VERIFICATION

I, Jenise Annette Bonner-Pope, being duly sworn deposes and says that she is the Plaintiff in the above entitled action, that she has read the foregoing Complaint and knows the contents thereof. That the same is true of her own knowledge except as to those matters and things stated upon information and belief, and as to those things, she believes them to be true.

_________________________________

(Sign in the presence of a Notary Public)

Sworn to and subscribed before me this the _____ day of ____________________, 2021.

______________________________

Notary Public

________________________________________

(Printed name of Notary Public)

My Commission Expires: ____________________

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing document was sent on the (Date) day of (Month) (Year) by regular U.S. mail, by facsimile, or certified mail, return receipt requested, to the following parties or attorneys of record:

(Name of Defendant’s Attorney), Attorney at Law

 

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