Below is a jurisdiction‑neutral model Petition for Dissolution of Marriage that you can file after tailoring it to the governing jurisdiction’s statutes, rules, and required forms. Because family law is strictly jurisdiction‑specific, you must insert the appropriate statutory citations (e.g., residency requirements, grounds, equitable distribution/community property standards, custody statutes, child support guidelines, UCCJEA provisions in the U.S.) and conform formatting to local court rules. If you provide the jurisdiction and facts, I can tailor this to the controlling law and add the correct authorities.
[COURT CAPTION]
In the [Name of Court] of [County/Parish/District], [State/Province], [Country]
Wang Min, )
Petitioner, )
) Case No.: [To be assigned]
v. )
) Petition for Dissolution of Marriage
Zhao Qiang, ) (Divorce)
Respondent. )
_____________________________________________)
Petitioner Wang Min (“Petitioner”), by and through undersigned counsel [or pro se], respectfully alleges as follows against Respondent Zhao Qiang (“Respondent”):
A. Jurisdiction and Venue
1. Subject‑matter jurisdiction is proper under [cite controlling statute granting jurisdiction over dissolution actions, e.g., [Statute §___]].
2. Petitioner has been domiciled and actually resident in [State/Province] for at least [statutory period] immediately preceding the filing of this Petition, as required by [Statute §___].
3. Venue is proper in [County] pursuant to [Statute §___] because [Petitioner/Respondent] resides in this county and/or the parties last cohabited here.
4. The Court has personal jurisdiction over Respondent under [Statute/Rule §___ or long‑arm provision], because [Respondent resides in this State/maintains a domicile/minimum contacts; marital domicile was in this State; acts giving rise to the claim occurred here].
B. Marriage and Separation
5. The parties were lawfully married on [date] in [city, state/province, country].
6. The parties separated on or about [date], and since that time have lived separate and apart.
7. The marriage is irretrievably broken/no longer supportable due to irreconcilable differences [or other applicable statutory ground—e.g., incompatibility, separation for [X] months, etc.] as provided in [Statute §___]. There is no reasonable prospect of reconciliation.
8. Neither party is currently a party to another action for divorce involving this marriage; no judgment of dissolution has been entered previously; and there are no impediments to dissolution.
C. Children of the Marriage
[Include this section if applicable; otherwise state there are no minor children born of or adopted into the marriage.]
9. The parties are the parents of the following minor child(ren): [Full name(s) and date(s) of birth].
10. For the purposes of jurisdiction over child custody, the child(ren) have resided in [State/Province] for at least six consecutive months immediately preceding filing, and this State is the child(ren)’s “home state” within the meaning of [UCCJEA or local custody statute citation]. No other court has issued a custody determination concerning the child(ren), and no custody proceeding is pending in another jurisdiction, to Petitioner’s knowledge. [Attach or include the required custody affidavit if mandated by local law.]
11. It is in the child(ren)’s best interests, under [Statute §___ and controlling case law], that the Court allocate parental responsibilities, legal custody/decision‑making, physical custody/parenting time, and child support as requested herein.
D. Property, Debts, and Disclosure
12. Marital/community property subject to distribution includes, without limitation: the marital residence located at [address or description], household goods, vehicles, bank and brokerage accounts, retirement and pension interests, equity/stock options, business interests, and any other property acquired during the marriage as defined by [Statute §___].
13. Separate property includes, without limitation: property acquired prior to the marriage; property acquired by gift or inheritance; and property excluded by valid agreement, all as defined by [Statute §___].
14. Marital/community debts include, without limitation: mortgage(s), consumer debts, vehicle loans, tax liabilities, and other obligations incurred during the marriage.
15. Petitioner requests full and timely exchange of financial disclosures as required by [Rule/Statute §___], and division of marital/community estate in accordance with [equitable distribution/community property] principles under [Statute §___ and pertinent case law, e.g., [Case Name], [citation]].
E. Spousal Support (Alimony/Maintenance)
16. Petitioner requests temporary and final spousal support pursuant to [Statute §___], in an amount and duration the Court deems just, considering the statutory factors including the length of the marriage, the standard of living during the marriage, the parties’ incomes and earning capacities, health, ages, contributions to the marriage (including homemaking and career support), and tax consequences. See [Statute §___; leading cases, e.g., [Case Name], [citation]].
[If Petitioner is not seeking spousal support, state that no support is sought and waive same, if appropriate.]
F. Child Custody, Parenting Time, and Support
17. Custody and Parenting Time. Petitioner seeks an allocation of parental responsibilities and a parenting plan consistent with the child(ren)’s best interests under [Statute §___], awarding [sole/shared] legal custody (decision‑making authority) and [primary/shared] physical custody, with a parenting time schedule to ensure frequent and continuing contact with both parents, subject to appropriate safeguards.
18. Child Support. Petitioner requests child support consistent with the child support guidelines under [Statute §___ and implementing regulations/rules], including base support, health insurance coverage, work‑related childcare, and allocation of unreimbursed medical expenses, with deviations from the guidelines as warranted by the statutory factors and supported by findings.
19. Tax Dependent/Exemptions. Petitioner requests allocation of dependency exemptions and credits consistent with [Statute §___] and federal law, taking into account the parties’ relative financial circumstances.
G. Temporary (Pendente Lite) Relief
20. Petitioner requests temporary orders pending final judgment, including: exclusive use and possession of the marital residence; temporary custody/parenting time; temporary child support; temporary spousal support; injunctive relief restraining the transfer, concealment, or dissipation of assets; an order maintaining existing insurance (medical, dental, life, auto, homeowners); and an award of interim attorneys’ fees and costs, under [Statute/Rule §___ and case law].
H. Marital Settlement Agreements
21. If the parties execute a written settlement agreement addressing some or all issues (property division, spousal support, custody, parenting time, child support), Petitioner requests that the Court approve, incorporate, and, where appropriate, merge the agreement into the judgment, subject to the Court’s independent review of child‑related provisions for best interests compliance.
I. Restoration of Name
22. Upon entry of judgment, Petitioner requests restoration of Petitioner’s former name: [former name], as authorized by [Statute §___].
J. Attorneys’ Fees and Costs
23. Petitioner requests an award of reasonable attorneys’ fees, expert fees, and costs pursuant to [Statute §___] based on the parties’ relative financial circumstances and any litigation conduct necessitating fee‑shifting. See [leading case(s), citation].
K. Other Relief
24. Petitioner requests such other and further legal and equitable relief as the Court deems just and proper.
Prayer for Relief
Petitioner respectfully prays that the Court:
a. Enter a Judgment of Dissolution of Marriage on the ground(s) authorized by [Statute §___];
b. Confirm the Court’s jurisdiction and venue as proper;
c. Allocate parental responsibilities and enter a parenting plan in the child(ren)’s best interests, as set forth above;
d. Order child support per the guidelines (with any warranted deviations) and allocate health insurance and unreimbursed medical expenses;
e. Award temporary and/or final spousal support as justice requires;
f. Equitably divide marital/community property and allocate debts, with appropriate findings and, if necessary, QDROs or similar orders for retirement assets;
g. Enter temporary restraining orders/injunctions against asset dissipation and require maintenance of insurance pending judgment;
h. Approve and incorporate any settlement agreement of the parties;
i. Restore Petitioner’s former name, if requested;
j. Award attorneys’ fees, expert fees, and costs to Petitioner; and
k. Grant such other relief as is proper.
Verification
I, Wang Min, am the Petitioner in this action. I have read the foregoing Petition for Dissolution of Marriage and declare under penalty of perjury under the laws of [State/Province/Country] that the facts stated therein are true and correct to the best of my knowledge, information, and belief.
Date: [________] ______________________________
Wang Min, Petitioner
Signature Block
Submitted by:
[Attorney Name], Esq. [Bar No. _____]
[Law Firm]
[Address]
[Telephone]
[Email]
Attorney for Petitioner
[If pro se: include Petitioner’s contact information and any required privacy notices.]
Certificate of Service
I certify that on [date], I served a true and correct copy of the foregoing Petition for Dissolution of Marriage, together with the Summons and all required initiating documents, by [method of service authorized by local rules/statute] upon:
Zhao Qiang
[Service Address]
[City, State/Province, Postal Code, Country]
__________________________________
[Name/Signature]
Important filing notes (jurisdiction‑specific; attach or file separately as required):
- Civil cover sheet and Summons (or Notice of Family Claim).
- Required affidavits/disclosures (e.g., UCCJEA affidavit if minor children; financial affidavit; parenting class certificate if mandated).
- Local standing orders in domestic relations cases.
- Proposed temporary orders, where appropriate.
If you provide the jurisdiction, marriage/separation details, whether there are minor children (with their domicile history), and any initial positions on property division and support, I will revise this into a jurisdiction‑specific pleading with precise statutory and case citations and conform it to local formatting and filing requirements.
