NAME OF ATTORNEY, ESQUIRE
Attorney ID No. 00000				Attorney for Plaintiff
Street Address
Philadelphia, PA 19100
Tele: 215-
________________________

NAME OF PLAINTIFF					:	COURT OF COMMON PLEAS
								PHILADELPHIA COUNTY
							:	FAMILY DIVISION
	vs.
							:		TERM, 20
NAME OF DEFENDANT				:	NO.
complaint in divorce
count I
Dissolution of Marriage
1.	Plaintiff, JOHN DOE, is an adult individual who currently resides at 1234 Main Street, Philadelphia, PA.
2.	Defendant, JANE SMITH DOE, is an adult individual who currently resides at 1234 Main Street, Philadelphia, PA.
3.	Plaintiff and defendant are sui juris, and both have been residents of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint.
4.	The parties were married on January 1, 2000, in Philadelphia, Pennsylvania. A photostatic copy of the marriage certificate is attached hereto, made a part hereof and marked Exhibit “A”.
5.	Neither plaintiff nor defendant is in the military or naval service of the United States or its allies within the provisions of the Servicemembers Civil Relief Act of 2003 and its amendments.
6.	There have been no prior actions of divorce or for annulment between the parties.
7.	The parties have/have not entered into a written agreement as to equitable distribution of marital property, alimony, alimony pendente lite, custody, child support, spousal support, counsel fees and costs.
8.	Plaintiff acknowledges that he has been advised of the availability of counseling between the parties and that he may have the right to request that the court require the parties to participate in such counseling in certain instances.
9.	Plaintiff alleges the following grounds for the dissolution of the marriage:
a.	The marriage is irretrievably broken [and/or]
b.	The parties have lived separate and apart for a period of more than two years [and/or]
c.	The marriage is irretreivably broken, and after ninety (90) days have elapsed from the date of service of this complaint, the plaintiff intends to file an affidavit consenting to a divorce. The Plaintiff believes the defendant will also file such an affidavit
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce pursuant to Sections 3301(c) and 3301(d) of the divorce code.
count II
Equitable Distribution
10.	The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full.
11.	The parties have legally and beneficially acquired property, both real and personal, during the marriage from the date of marriage, January 1, 2000, to January 1, 2012, the date of separation.
12.	The parties have been unable to agree as to an equitable division of said property.
WHEREFORE, Plaintiff requests the Court to equitably divide all marital property pursuant to Section 3502 of the Divorce Code.
count III
Alimony
13.	The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full.
14.	Plaintiff lacks sufficient property to provide for his reasonable needs and is unable to support himself through appropriate employment.
15.	Plaintiff requires reasonable support to adequately maintain himself in accordance with the standard of living established during the marriage.
WHEREFORE Plaintiff requests this Honorable Court to enter an award of alimony pursuant to Section 3701 of the Divorce Code.
count IV
Request for Alimony Pendente Lite, Counsel Fees,
Costs and Expenses under Sections 3104(a)(1)
and 3702 of the Divorce Code
16.	The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full.
17.	Plaintiff has employed counsel, but is unable to pay the necessary and reasonable attorney’s fees for said counsel.
WHEREFORE Plaintiff requests this Honorable Court to enter an award of interim counsel fees, costs and expenses, until final hearing and thereupon to award such additional counsel fees, costs and expenses as is deemed appropriate pursuant to Sections 3104 and 3323(b) of the Divorce Code.
count V
Approval and Incorporation of Possible
Property Settlement Agreement into Divorce Decree
18.	The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full.
19.	The public policy of the Commonwealth of Pennsylvania encourages parties to a marital dispute to negotiate a settlement of their differences.
20.	While no settlement has been reached as of the date of filing of this complaint, plaintiff is and has always been willing to negotiate a fair and reasonable settlement of all matters with defendant.
21.	In the event that a written settlement agreement is entered into between the parties prior to the time of hearing on this complaint, plaintiff desires that such written agreement be approved by the Court and incorporated in any divorce decree which may be entered dissolving the marriage between the parties.
WHEREFORE, if a written settlement agreement is reached Plaintiff respectfully requests that the Court approve and incorporate such agreement in the final divorce decree, pursuant to sections 3104(a)(1) and (4) and section 3323(b) of the Divorce Code.
______________________________________
	NAME OF ATTORNEY, Esquire
	Attorney for Plaintiff
V e r i f i c a t i o n
Plaintiff verifies that the statements made in this Complaint in Divorce are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities.
______________________________________
	JOHN DOE, Plaintiff
Date:__________________