COMPLAINT FOR DIVORCE (UNCONTESTED - NO MINOR CHILDREN)

Pennsylvania

IN THE COURT OF COMMON PLEAS

[County] County, Pennsylvania

DIVISION: DOMESTIC RELATIONS

Docket No.: _____________

Plaintiff: _________________________________

v.

Defendant: _________________________________

COMPLAINT IN DIVORCE

Plaintiff, by their attorney, _____________, Esq., whose office is located at _________________________________, complains and says:

I. THE PARTIES

1.1 Plaintiff is an individual who resides at _________________________________, [City], Pennsylvania [ZIP], and has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately preceding the filing of this Complaint.

1.2 Defendant is an individual who resides at _________________________________, [City], [State] [ZIP].

II. MARRIAGE

2.1 The parties were married on _____________, 20___, in [City], [State].

2.2 The parties last resided together as husband and wife in [County] County, Pennsylvania.

III. CHILDREN

3.1 There were [no children / ___ children] born of this marriage.

3.2 [If no children: There are no minor children born of this marriage, and the Wife is not now pregnant.]

[If children: The names and birthdates of the minor children are:]

IV. SEPARATION

4.1 The parties separated on _____________, 20___.

4.2 The parties have lived separate and apart from each other since the date of separation.

4.3 The marriage is irretrievably broken.

V. GROUNDS FOR DIVORCE

5.1 MUTUAL CONSENT

Pursuant to 23 Pa.C.S. § 3301(c), the parties mutually consent to the divorce. Both parties have:

• Signed affidavits of consent
• Acknowledged that the marriage is irretrievably broken
• Waived the 90-day waiting period by mutual consent

5.2 IRRETRIEVABLE BREAKDOWN

In the alternative, pursuant to 23 Pa.C.S. § 3301(d), the marriage is irretrievably broken, and:

• The parties have lived separate and apart for a period of at least one (1) year
• There is no reasonable prospect of reconciliation

VI. JURISDICTION AND VENUE

6.1 This Court has jurisdiction over this matter pursuant to 23 Pa.C.S. § 3104.

6.2 Venue is proper in this County because the parties last resided together as husband and wife in this County [or: the Defendant resides in this County].

VII. MARITAL SETTLEMENT AGREEMENT

7.1 The parties have entered into a written Marital Settlement Agreement resolving all issues arising from the marriage, including but not limited to:

• Equitable division of marital property pursuant to 23 Pa.C.S. § 3502
• Allocation of marital debts
• (If applicable) Custody, partial custody, and child support

7.2 A copy of the Marital Settlement Agreement is attached hereto as Exhibit A.

7.3 The parties request that the Court incorporate the Agreement into any Decree of Divorce.

VIII. NO OTHER ACTIONS PENDING

8.1 There are no other actions for divorce or annulment pending in any court.

IX. PRAYER FOR RELIEF

WHEREFORE, Plaintiff requests that this Court:

(a) Adjudge a divorce dissolving the bonds of matrimony between the parties on the grounds of mutual consent pursuant to 23 Pa.C.S. § 3301(c), or in the alternative, irretrievable breakdown pursuant to 23 Pa.C.S. § 3301(d);

(b) Approve and incorporate the Marital Settlement Agreement into the Decree of Divorce;

(c) Grant such other and further relief as the Court deems just and proper.

_______________________________

[Attorney Signature]

Attorney for Plaintiff

PA Attorney ID No.: _____________

Plaintiff's Address:

_______________________________

_______________________________

VERIFICATION

**Commonwealth of Pennsylvania }

**County of _________________ }

I, _________________________________, being duly sworn according to law, depose and say:

1. I am the Plaintiff in this action.
2. I have read the foregoing Complaint and know the contents thereof.
3. The facts alleged therein are true to my own knowledge, except as to those matters alleged upon information and belief, and as to those matters, I believe them to be true.
4. This complaint is not presented to the Court for any improper purpose.

_______________________________

Signature: _________________________________

Date: _________________

Sworn and subscribed before me this ____ day of _______________, 20___.

_______________________________

Notary Public Signature

Notary Seal

My Commission Expires: _________________

AFFIDAVIT OF CONSENT PURSUANT TO 23 Pa.C.S. § 3301(c)

**Commonwealth of Pennsylvania }

**County of _________________ }

I, _________________________________, being duly sworn according to law, depose and say:

1. I am the [Plaintiff/Defendant] in the within action.
2. I consent to the entry of a divorce decree.
3. I acknowledge that the marriage is irretrievably broken.
4. I have signed a Marital Settlement Agreement.
5. I understand that I may waive the 90-day waiting period by mutual consent.

_______________________________

Signature: _________________________________

Printed Name: _________________________________

Date: _________________

Sworn and subscribed before me this ____ day of _______________, 20___.

_______________________________

Notary Public Signature

Notary Seal

My Commission Expires: _________________

CERTIFICATE OF SERVICE

I hereby certify that on this ____ day of _______________, 20___, I served a copy of the within Complaint for Divorce, attached Marital Settlement Agreement, and Affidavits of Consent upon:

_______________________________

Defendant Name

_______________________________

Address

_______________________________

City, State ZIP

by [certified mail, return receipt requested / personal service / regular mail with consent].

_______________________________

Signature: _________________________________

Date: _________________

FILING INSTRUCTIONS

FORMATTING REQUIREMENT (Pa.R.C.P. No. 204.1):

Every document filed with a Pennsylvania court must have a 3-inch (3") blank

top margin on the first page. Subsequent pages require a minimum 1-inch top

margin. Verify margins before filing.

CONFIDENTIAL INFORMATION FORM (Pa.R.C.P. No. 207.1 — Effective Jan. 1, 2022):

Do NOT include in this or any public court document:

• Social Security Numbers — use last 4 digits only, or submit separately on

AOPC Form 3 (Confidential Information Form)

• Financial account numbers — last 4 digits only

• Driver's license numbers — submit on AOPC Form 3

• Minor children's full dates of birth — submit on AOPC Form 3

File completed AOPC Form 3 with the Prothonotary/Clerk separately from this

filing. Download at: www.pacourts.us/forms/for-the-public

Where to File

File this Complaint with the Prothonotary or Clerk of the Court of Common Pleas in the county where:

• The parties last resided together as spouses, OR
• The Defendant currently resides

Filing Fee

Contact the Prothonotary's Office for current filing fees. Fees typically range from $100-$250.

Required Documents

1. Complaint in Divorce (this document)
2. Marital Settlement Agreement (signed by both parties)
3. Verification (signed before notary)
4. Affidavits of Consent (both parties, signed before notary)
5. Notice to Defend and Claim Rights (required by PA Rules)
6. Cover Sheet (required by local court rules)

Service of Process

• The Defendant must be served with the Summons and Complaint
• Service may be made by:
• Certified mail (return receipt requested)
• Personal service by sheriff or private process server
• Acceptance of service (if Defendant signs acknowledgment)

Waiting Periods

Mutual Consent Divorce (23 Pa.C.S. § 3301(c)):

• 90-day waiting period from service of Complaint before decree can be entered
• Parties may waive this period by mutual written consent
• Affidavits of Consent must be filed

Irretrievable Breakdown (23 Pa.C.S. § 3301(d)):

• 1-year separation required before filing
• No additional waiting period after filing

Residency Requirement

• At least one party must have been a bona fide resident of Pennsylvania for 6 monthsJurisdiction-correct document templates. Not legal advice.Document Prepared By:

Jurist-Diction

The law, precisely spoken.

Date: March 23, 2026