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Petition Dissolution of Mar

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Submitted By adred85
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IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, DOMESTIC RELATIONS DIVISION

IN RE THE MARRIAGE OF: ) )
JOHN SMITH, ) Petitioner, ) ) and ) No. ____________ )
JANE SMITH, ) Respondent. )

PETITION FOR DISSOLUTION OF MARRIAGE

NOW COMES the Petitioner, JOHN SMITH, by and through his attorney, Darryl Apperton and Cabrini Green Legal Aid, petitions this court for a Dissolution of Marriage and states as follows:

1. Petitioner is now residing in the County of Cook, State of Illinois, and has so resided for at least the past 90 days.

2. The parties were lawfully married on December 4, 2003 and the marriage was registered in Cook County, Illinois.

3. Petitioner is 25 years of age and is employed at CVS Pharmacy.

4. Respondent is 25 years of age and is employed at U.S. Bank.

5. There were two children born to the parties, namely JULIE SMITH, born September 14, 2004, and JIMMY SMITH, born January 4, 2006. There were no other children born to or adopted of the marriage and the Respondent is not currently pregnant.

6. The parties have not lived together as husband and wife since November 25, 2006.

7. Since the parties’ separation, the minor children have resided with Petitioner.

8. At the time of filing this Petition for Dissolution of Marriage, the Petitioner is not aware of any pending action involving the minor children.

9. Irreconcilable differences have caused an irretrievable breakdown in the marriage. Further attempts at reconciliation would not be in the best interests of the family.

10. Prior to the marriage and during the marriage, the Petitioner acquired certain items of non-marital and marital property.

11. During the marriage, the parties have not incurred any marital debts which are outstanding at the time of filing this petition.

12. Respondent’s last name at the time of this marriage was Jones.

WHEREFORE, the Petitioner, JOHN SMITH, prays that this Honorable Court enter an Order:

A. Dissolving the marriage of the parties;

B. Awarding to the Petitioner his non-marital property and an equitable share of the marital property;

C. Granting sole care, custody, and control of the minor children, to the Petitioner;

D. Setting a specific and certain visitation schedule between the Respondent and the minor child;

E. Ordering the Respondent to pay permanent child support in accordance with the statutory guidelines;

F. Barring the Respondent from receiving maintenance from the Petitioner;

G. Ordering that each party be responsible for his or her own attorney’s fees and costs in connection with this matter;

H. Ordering that both parties be responsible for their own debts incurred after the date of separation;

I. Granting such other relief as it deems just and proper.

__________________________________
John Smith

__________________________________
Darryl Apperton

Darryl Apperton
Cabrini Green Legal Aid
740 N. Milwaukee Avenue
Chicago, Illinois 60642
(312) 738-2452
Attorney No. _______
STATE OF ILLINOIS ) ) SS
COUNTY OF COOK )

V E R I F I C A T I O N

JOHN SMITH, being first duly sworn on oath, deposes and says that he is the Petitioner in the above Petition for Dissolution of Marriage, by him subscribed, and that he has read the contents thereof and knows them to be true in substance and in fact.

______________________________ John Smith

Subscribed and Sworn to before me

this ____ day of _______________________, 2008.

_____________________________
NOTARY PUBLIC

Darryl Apperton
Cabrini Green Legal Aid
740 N. Milwaukee Avenue
Chicago, Illinois 60642
(312) 738-2452
Attorney No. _______riage

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