Complaint For Divorce
Complaint For Divorce
STATE OF GEORGIA
*
BARBARA CLARK-JENKINS, *
Plaintiff, *
* CIVIL ACTION FILE NO.
v. *
*
FRANKLIN DELANO JENKINS, *
Defendant. *
*
COMES NOW the Plaintiff in the above-styled action and submits this complaint for Divorce
1.
of Clayton County at 962 Forest Glen, Jonesboro, GA 30238 for more than six (6) months prior to
the filing of this action and the Defendant, FRANKLIN DELANO JENKINS, is a resident of the
State of Georgia and a resident of Clayton County at 962 Forest Glen, Jonesboro, GA 30238.
2.
Jurisdiction and venue are proper in ths Court. The Defendant has consented to the
Jurisdiction of this Court and has acknowledged service of process and jurisdiction of this Court.
3.
The parties were married in Jonesboro, Clayton County, Georgia on September 21, 2013.
4.
The parties separated on November 21, 2016, and have remained in a bona fide state of
separation since that date. There are no minor children of this marriage.
5.
The parties shall divide any and all marital property as outlined in the settlement agreement
6.
This divorce is filed on the basis that the marriage between the parties is irretrievably broken
without any prospect of reconciliation within the contemplation of the Official Code of Georgia
Annotated, § 19-5-3(13) and that the parties hereto are entitled to a total divorce, that is to say, a
1. That the Plaintiff be granted a divorce and vinculo matrimonii from the Defendant;
2. That the Plaintiff is awarded any further equitable relief as this Court deems just and
proper.
*
BARBARA CLARK-JENKINS, *
Plaintiff, *
* CIVIL ACTION FILE NO.
v. *
*
FRANKLIN DELANO JENKINS, *
Defendant. *
*
VERIFICATION
Personally appeared before me, the undersigned officer duly authorized to administer oaths,
BARBARA CLARK-JENKINS, Plaintiff, who after being duly sworn, deposes and states that the
facts contained in the foregoing Complaint for Divorce are true and correct to the best of my
NOTARY PUBLIC