COMPLAINT FOR DIVORCE (IRRECONCILABLE DIFFERENCES)

State of New Jersey

IN THE SUPERIOR COURT OF NEW JERSEY

CHANCERY DIVISION, FAMILY PART

[COUNTY] COUNTY

[PLAINTIFF NAME],

Plaintiff,

v.

[DEFENDANT NAME],

Defendant.

DOCKET NO.: ____________-__________

COMPLAINT FOR DIVORCE

I. PARTIES AND JURISDICTION

1. Plaintiff, [FULL LEGAL NAME], resides at [STREET ADDRESS], [CITY], [COUNTY] County, New Jersey [ZIP CODE], and has been a resident of the State of New Jersey for more than one (1) year immediately preceding the filing of this Complaint.

> N.J.S.A. 2A:34-10 provides: "No action for divorce... shall be maintained unless at the time the action is commenced one of the parties is and has been for 1 year next preceding the commencement of the action a bona fide resident of this State."

2. Defendant, [FULL LEGAL NAME], resides at [STREET ADDRESS], [CITY], [STATE] [ZIP CODE].

3. Plaintiff and Defendant were married on [DATE OF MARRIAGE] in [CITY], [STATE], in a ceremony officiated by [OFFICIANT NAME/TITLE].

4. A certified copy of the marriage certificate is available from [STATE/VITAL RECORDS OFFICE].

II. CHILDREN OF THE MARRIAGE

5. [SELECT ONE:]

☐ No children were born of or adopted during this marriage.

☐ The following child(ren) were born of or adopted during this marriage:

6. No children are expected as issue of this marriage.

7. ☐ All children currently reside with Plaintiff.

☐ All children currently reside with Defendant.

☐ Children reside with Plaintiff and Defendant according to the following arrangement: [DESCRIBE]

III. GROUNDS FOR DIVORCE

8. Plaintiff seeks a divorce on the ground of irreconcilable differences pursuant to N.J.S.A. 2A:34-2(i).

> N.J.S.A. 2A:34-2(i) provides: "Irreconcilable differences which have caused the breakdown of the marriage for a period of 6 months and which make it appear that the marriage should be dissolved and that there is no reasonable prospect of reconciliation."

9. Irreconcilable differences have existed between Plaintiff and Defendant for a period of at least six (6) months immediately preceding the filing of this Complaint.

10. These differences have caused the complete and irretrievable breakdown of the marriage.

11. There is no reasonable prospect of reconciliation between the parties.

12. The marriage is irretrievably broken and should be dissolved.

IV. PROPERTY AND ASSETS

13. The parties [own / do not own] real property. If applicable, the marital residence is located at: [ADDRESS], [CITY], [COUNTY] County, New Jersey [ZIP CODE].

14. The parties have accumulated the following significant marital assets:

• [ ] Bank accounts
• [ ] Retirement accounts (401k, IRA, pension)
• [ ] Vehicles
• [ ] Real property
• [ ] Household furnishings
• [ ] Other: [SPECIFY]

15. The parties have the following outstanding debts and liabilities:

• [ ] Mortgage(s)
• [ ] Credit card debt
• [ ] Auto loans
• [ ] Student loans
• [ ] Other: [SPECIFY]

16. ☐ The parties have entered into a Property Settlement Agreement dated [DATE], a copy of which is attached hereto as Exhibit A.

☐ The parties have not yet resolved issues of property division and reserve the right to address same.

V. ALIMONY/SPOUSAL SUPPORT

17. ☐ Plaintiff waives any claim for alimony.

☐ Defendant is requested to pay alimony to Plaintiff in the amount of $_______ per month for a period of _______ years.

☐ The issue of alimony is reserved for later determination.

VI. CUSTODY AND SUPPORT (IF APPLICABLE)

18. If there are children of the marriage:

☐ Plaintiff requests sole legal and physical custody.

☐ Plaintiff requests joint legal custody with [Plaintiff / Defendant] having primary physical custody.

☐ The parties have entered into a Parenting Plan dated [DATE], a copy of which is attached hereto as Exhibit B.

☐ Custody and parenting time issues are reserved for later determination.

19. Child support shall be determined in accordance with the New Jersey Child Support Guidelines, N.J.A.C. 5:6-7, based upon the parties' respective incomes and the parenting time schedule.

VII. NAME CHANGE

20. ☐ Plaintiff desires to restore [her/his] former name of: [FORMER NAME].

☐ Plaintiff does not seek a name change.

VIII. OTHER RELIEF

21. Plaintiff requests such other and further relief as the Court deems just and equitable.

IX. RESIDENCY AND VENUE

22. Venue is proper in [COUNTY] County pursuant to N.J.S.A. 2A:34-10 because:

☐ Plaintiff has resided in this county for more than one (1) year preceding the filing of this Complaint.

☐ Defendant resides in this county.

☐ This is where the cause of action accrued.

WHEREFORE, Plaintiff respectfully requests that this Honorable Court:

A. Dissolve the marriage between the parties on the ground of irreconcilable differences;

B. Equitably distribute the marital property and debts;

C. [IF APPLICABLE] Award custody of the minor child(ren) to [Plaintiff / jointly];

D. [IF APPLICABLE] Order child support in accordance with the New Jersey Child Support Guidelines;

E. [IF APPLICABLE] Award alimony to Plaintiff in the amount requested;

F. [IF APPLICABLE] Restore Plaintiff's former name;

G. Grant such other and further relief as the Court deems just and equitable.

VERIFICATION

STATE OF NEW JERSEY

COUNTY OF [COUNTY]

CERTIFICATION PURSUANT TO R. 1:4-4(b)

I certify that the foregoing statements made by me are true. I am aware that

if any of the foregoing statements made by me are willfully false, I am

subject to punishment.

Date: _______________

________________________________

[PLAINTIFF SIGNATURE]

[PRINTED NAME]

[ADDRESS]

[PHONE]

N.J.R. 1:4-4(b)

CERTIFICATION OF INSURANCE COVERAGE

I, [PLAINTIFF FULL NAME], hereby certify that:

1. There [is / is not] existing health insurance coverage applicable to the parties and any children of the marriage.

1. If coverage exists, it is provided by:

• Insurance Company: [NAME]
• Policy Number: [NUMBER]
• Covered Parties: [NAMES]

________________________________

[PLAINTIFF SIGNATURE]

[DATE]

CERTIFICATION OF NON-COLLUSION

I, [PLAINTIFF FULL NAME], hereby certify that:

1. The allegations contained in this Complaint are true to the best of my knowledge and belief.

1. This action is not being maintained by collusion with the Defendant for the purpose of obtaining a divorce.

1. I have not entered into any agreement, understanding, or conspiracy to suppress evidence or to present false or contrived testimony.

1. The grounds for divorce stated herein are made in good faith.

________________________________

[PLAINTIFF SIGNATURE]

[DATE]

CERTIFICATE OF SERVICE

I, [PLAINTIFF FULL NAME], hereby certify that on [DATE], I served a true copy of the within Complaint for Divorce upon:

[DEFENDANT FULL NAME]

[DEFENDANT ADDRESS]

[CITY, STATE ZIP]

By the following method:

☐ Certified Mail, Return Receipt Requested

☐ Regular and Certified Mail

☐ Personal Service by Process Server

☐ [OTHER METHOD PERMITTED BY COURT RULE]

________________________________

[PLAINTIFF SIGNATURE]

[DATE]

FILING INSTRUCTIONS

FORMATTING REQUIREMENT (N.J.R. 1:4-9):

Every document filed with a New Jersey court must carry a 3-inch (3") blank

top margin on the first page to accommodate the court's filing stamp. All

subsequent pages require a minimum 1-inch top margin. Verify margins before

filing.

Where to File

File this Complaint with the Superior Court of New Jersey, Chancery Division, Family Part in the county where you or your spouse resides.

Filing Fee: Approximately $300 (check with the specific county for current fee)

Payment Methods: Cash, money order, certified check, or credit card (varies by county)

Required Documents to File

1. Original Complaint for Divorce (this document)
2. Certification of Insurance Coverage
3. Certification of Non-Collusion
4. Case Information Statement (CIS) — REQUIRED in all contested matters
5. Filing fee payment
6. [IF CHILDREN] Confidential Litigant Information Sheet
7. [IF CHILDREN] Parent Education Program registration

After Filing

1. The Court will assign a docket number
2. You must serve the Defendant with a copy of the Complaint
3. Defendant has 35 days to file an Answer
4. If Defendant does not answer, you may request entry of default
5. The Court will schedule a Case Management Conference

Resources

• NJ Courts Self-Help: njcourts.gov/selfhelp
• NJ State Bar Lawyer Referral: njsbar.com
• Legal Services of NJ: lsnjlaw.org | 1-888-576-5529

Jurisdiction-correct document templates. Not legal advice.

Document Version: NJ-DIV-2026-01

Last Updated: March 2026