§ Form 15 Complaint for Divorce

Codes > Wyoming Rules of Civil Procedure > Appendix of > Form 15

Form 15. Complaint for Divorce

    1. (Here set out the grounds upon which the court's jurisdiction depends.)

    2. Plaintiff has resided in the State of Wyoming for 60 days immediately preceding the time of filing this complaint. Plaintiff is a resident of the County of Laramie, State of Wyoming.

    3. Plaintiff and defendant were married to each other on June 1, 1975, at Cheyenne, Wyoming.

    4. One child, A.B., was born on June 1, 1976, as issue of said marriage. Plaintiff is a fit and proper person to have primary care, control and custody of said child.

    5. Such irreconcilable differences now exist between the parties that there is no hope for continuing a viable marital relationship.

    6. The parties own real and personal property as follows: (here describe)

    7. The defendant has and is capable of earning an income sufficient to pay for the support of plaintiff and A.B., and to pay the plaintiff's attorney's fee in this matter.

    Wherefore plaintiff demands:

    (1) That a decree of divorce be granted to the plaintiff dissolving the marriage to defendant;

   (2) That plaintiff be awarded the primary care, control and custody of the child A.B. subject to reasonable visitation rights of defendant;

   (3) That defendant pay to plaintiff a reasonable sum for plaintiff's support and the support of A.B. during the pendency of this action, a reasonable attorney's fee, and costs;

    (4) That defendant pay to plaintiff a reasonable sum as alimony and a reasonable sum for the support of A.B. during the minority of A.B;

    (5) That the court decree a just and equitable division of the property of the parties.