HomeMy WebLinkAbout1806 i
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BETTY T. CRAFT, IN THE CIRCUIT COURT OF
Plaintiff, ~ '82 Ma~ -3 ~}g :QZJEFFERSON COUNTY, ALABAMA
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VS p L. C~i,~E~:: ~i (EQUITY} ` . , . ,
AF~t~ i : ~ ~
EDWARD CRAFT, t*~ ~ ` ; l~~,.,C~~~ ~
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Defendant. ) Civil Action No.
COMPLAINT
Comes now the Plaintiff in the above styled cause and represents
unto the Court ae follows: ~
1. Your Plaintiff is over the age of nineteen years and is a bona
fide resident citizen of Jefferson County, Alabama, and has been euch for
more than six months next preceding the fi2ing of this complaint. Your
defendant is over the age of nineteen yesrs and is a bona fide resident
citizen of Jefferson County, Alabaiaa, and has been such for more than six
months next preceding the filing of this complaint.
2. The parties hereto were married on, to-wit: June 30, 1979, and
thexeafter lived together as husband and wife until they separated
January 22, 1982, and since that time have not lived together as husband
and wife.
3. There exists such a complete incompatibility of temperament
that the parties can no longer live together.
4. There was one chi2d born as a result of this marriage namely,
Kristy Yvonne Craft.
5. Plaintiff avers that slie has no funds with vhich to pay her
attorney of record in this cause and that defendant is either gainfully
employed or is able to be gainfully employed and is able to pay a reasanable
attorneys fee to her attorney of record in this cause.
6. Plaintiff further avers that she is employed part-time and is
in need of funds for support of the minor child of the parties and for
herself and that the defendant ia either gainfully employed or is able
to be gainfully employed and is able to pay such support for said child
and the Plaintiff.
7. Plaintiff further avers that the parties awn household furniture
and furnishings and other personal property she has in her possession
and that the plaintiff is in need of a part of this property.
(~t?erefore, the Plaintiff prays that the defendant be made a party
defendant to this cause and to that end that all needful process of this
court isaue to hian and that he be required to ~come in and answer s11 the
averments of the foregoina complaint, and that upon a final hearing of
this cause, the court grant to the Plai~ltiff a divorce A Vinculo Matrimonii
from the Defendant.
eooK 674 PacEi$Q~
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