In the case of a divorce lawsuit, it should be noted that the corresponding litigation claims must be clear, such as granting the plaintiff and the defendant a divorce, child support, property division, division of creditor's rights and debts, whether there is compensation for damages from the innocent party, and financial assistance expenses for economic difficulties. The following is a civil complaint for divorce for your reference.
Civil Complaint.
Plaintiff: Zheng Moumou, female, born on December 19, 1991, Han nationality, from XX County, Jiangxi Province, living at No. 12, Yangzikeng Group, Dongkeng Village, XX Township, XX County, citizenship number: XX07321991121953XX, **15XX00315XX.
Defendant: Lv Moumou, male, born on February 7, 1979, Han nationality, from XX County, Jiangxi Province, living at No. 60, Group 2, Lu Wu, XX Village, XX Township, XX County, citizenship number: XX21331979020728XX, **157X97560XX.
Litigation Claims. 1. The judgment grants the divorce of the plaintiff and the defendant. 2. It is decided that the son born to both parties, Lu X, shall be raised by the defendant, and the daughter Lu X shall be raised by the plaintiff, and each party shall be responsible for the maintenance of their respective children. 3. Divide the joint property of husband and wife (about 200,000 yuan) in accordance with the law. 4. The defendant was ordered to pay the plaintiff 50,000 yuan in damages. 5. The defendant shall bear the litigation costs of this case.
Facts & Reasons.
During the Mid-Autumn Festival in 2009, the plaintiff and the defendant met while working in Hongmen Industrial Park in XX County, and after the "turnstile ceremony" was held in the first month of 2010, the two parties officially lived together, giving birth to a son Lu on November 27, 2010 and a daughter Lu on August 7, 2012. After the plaintiff gave birth to his son Lu Han, he found that the defendant often gambled, the plaintiff dissuaded the defendant, the defendant was very impatient with this, sometimes the defendant gambled without gambling funds, and forcibly asked the plaintiff to take money, the plaintiff did not give it, and the defendant committed domestic violence, and at the same time, the defendant was often suspicious, suspecting that the plaintiff had cheated on Douyin live broadcast, which actually did not exist at all, and in the first half of 2017, the defendant committed serious domestic violence against the plaintiff, and then the defendant issued a guarantee to the plaintiff to promise that domestic violence would not be committed in the future, and the defendant signed the guarantee, and the defendant's relatives also signed on it。 In March 2018, the plaintiff and the defendant were working in Xintang, Guangzhou, and the defendant again inflicted domestic violence on the plaintiff, and the plaintiff could only rush back to XX's hometown, and then the defendant sent the plaintiff to the outpatient clinic of XX County Hospital of Traditional Chinese Medicine**. On July 26, 2021, the plaintiff and the defendant negotiated a divorce and formally separated at the same time, and the defendant agreed to the divorce and sent a divorce agreement to the plaintiff, proposing that one child should be raised, half of the house should be raised by one person, and half of the debt should be paid by one person. On August 15, 2022, the plaintiff filed a lawsuit with your court for divorce from the defendant, and on September 6, 2022, your court ruled that the divorce was not allowed, and the plaintiff and the defendant have been separated again for one year.
To sum up, the relationship between the husband and wife of the plaintiff and the defendant has completely broken down, and in order to end this marriage, the court hereby makes a judgment as requested.
Sincerely. The People's Court of XX County.
Applicant: September 8, 2023.
Thanks to [Kunming Xiangya Education Information Consulting*** for sponsoring the creation of legal content".