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5, Neither Plaintifl'nor Defendant is in the military or naval service of the United States
or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940
and its Amt'!ndments,
6, Plaintiff avers that there are no children of the parties under tht'! age of 18,
7, The cause(s) of action and sectioll(s) of Divorce Code under which Plaintiff is
proceeding are:
A, Section 3301(c), The marriage of the pal1ies is irretrievably broken,
After ninety (90) days have elapsed from the date of the filing of this Complaint.
Plaintiff intends to file an Atlidavit consenting to a diVorce, PlaintitT believes that
Defendant may also tile such an Atlidavit.
8, Section 3301(d) The marriage of the parties is irretrievably broken,
The Plaintiff and Defendant separated on or about Febnlary 1, 1997,
8, There have been no prior actiolls in divorce between the parties,
9, Plaintiffhas been advised of the availability of counseling and that Plaintiff may have
the right to request the parties to participate in counseling,
10, The parties may entcr into a written agreement with regard to support, alimony and
property division In the event that such an agreement is executed by the parties. the agreement may
be incorporated by the Court into the final Decree of Divorce,
WHEREFORE, Plainti!f requests your Honorable Coutl to enter a Decree in Divorce,
divorcing Plaintiff and Defendant,
COIJNT II
EQUITABLE DISTRIBUTION
11. Paragraphs I through 10 of this Complaint are incorporated herein by reference as
though set forth in full,
12, Plaintiff' and Defendant have acquired property, both real and personal during their
marriage from the date of their marriage until on 01' about February 1, 1997, the date of their
sepllration,
13, Plaintiff and Defendant have been unable to agree as to an equitable division of said
property,
WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital
property,
COUNT III
ALIMONY
14, Paragraphs 1 through 10 of this Complaint are incorporated herein by reference as
though set forth in lull,
15, Plaintiff'lacks sufficient property to provide for her reasonable means and is unable
to support herself through appropriate employment.
16, Plaintiff requires reasonable support to adequately maintain herself in accordanoe with
the standard of living established during the marriage,
WHEREFORE, Plaintiff requests your Honorable Court to enter an award of alimony in her
favor,
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8, Admitted,
9, After a thorough investigation the Defendant is without sufficient
knowledge and/or information to form a belief as to the tmth of the averments contained
in Paragraph 9 and the same are therefore denied,
10, Paragraph 10 contains a conclusion of law and no responsive pleading is
therefor necessary,
WHEREFORE, Defendant requests you Honorable Court to enter a Decree in
Divorce, divorcing Plaintiff and Defendant,
COUNT II
EQUITABLE DISTRIBUTION
11. Paragraphs 1 through 10 of this Answer are incorporated herein by
reference as though set forth in full,
12. Paragraph 12 is admitted in part and denied in part, It is admitted that the
parties have acquired both real and personal property during the marriage, However, it is
denied that the parties separated on February I, 1997, rather the date of separation is
believed and therefor averred to be September 20, 1996,
13, Admitted,
WHEREFORE, Defendant requests your Honorable Court to equitably distribute
all marital property,
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