RESPONSE TO PETITION FOR DISSOLUTION OF MARRIAGE
IN THE [COURT NAME] COURT OF [COUNTY] COUNTY, [STATE]
IN RE THE MARRIAGE OF:
[PETITIONER'S FULL LEGAL NAME],
Petitioner,
and
[RESPONDENT'S FULL LEGAL NAME],
Respondent.
CASE NO.: [CASE NUMBER]
RESPONSE TO PETITION FOR DISSOLUTION OF MARRIAGE
COMES NOW the Respondent, [RESPONDENT'S FULL LEGAL NAME], by and through the undersigned counsel (or "pro se" if self-represented), and hereby files this Response to the Petition for Dissolution of Marriage filed by Petitioner, and states as follows:
I. RESPONDENT'S PERSONAL INFORMATION
- Respondent's full legal name is [RESPONDENT'S FULL LEGAL NAME].
- Respondent's current residential address is [STREET ADDRESS, CITY, STATE, ZIP CODE].
- Respondent's telephone number is [PHONE NUMBER].
- Respondent's email address is [EMAIL ADDRESS].
- Respondent's date of birth is [DATE OF BIRTH].
- Respondent has been a resident of [STATE] for [NUMBER] years and [NUMBER] months, and a resident of [COUNTY] County for [NUMBER] years and [NUMBER] months.
- Respondent □ is □ is not currently on active duty in the United States military.
II. VERIFICATION OF PETITIONER'S INFORMATION
- Respondent □ admits □ denies □ lacks sufficient knowledge to admit or deny the accuracy of Petitioner's personal information as stated in the Petition for Dissolution of Marriage.
- Corrections to Petitioner's information, if any: [SPECIFY ANY CORRECTIONS TO PETITIONER'S INFORMATION].
III. CASE INFORMATION
- Respondent acknowledges that this case has been assigned Case Number [CASE NUMBER] in the [COURT NAME] Court of [COUNTY] County, [STATE].
- Respondent □ admits □ denies that the court identified in the Petition has proper jurisdiction over this matter.
- Respondent was served with the Petition for Dissolution of Marriage on [DATE OF SERVICE].
- This Response is being filed within the time period required by law.
IV. MARRIAGE INFORMATION
- Respondent □ admits □ denies that the parties were married on [DATE OF MARRIAGE] in [CITY, STATE/COUNTRY].
- If denied, Respondent states that the correct date and place of marriage is: [CORRECT DATE AND PLACE].
- Respondent □ admits □ denies that the date of separation was [DATE OF SEPARATION] as stated in the Petition.
- If denied, Respondent states that the correct date of separation is: [CORRECT DATE OF SEPARATION].
- Respondent □ admits □ denies that the marriage is irretrievably broken with no reasonable prospect of reconciliation.
V. JURISDICTIONAL REQUIREMENTS
- Respondent □ admits □ denies that the jurisdictional residency requirements have been met as stated in the Petition.
- If denied, Respondent states: [EXPLANATION OF WHY JURISDICTIONAL REQUIREMENTS HAVE NOT BEEN MET].
- Respondent □ admits □ denies the legal grounds for dissolution claimed in the Petition.
- If denied, Respondent states: [EXPLANATION OF POSITION ON LEGAL GROUNDS].
VI. PARAGRAPH-BY-PARAGRAPH RESPONSE
Respondent responds to each numbered paragraph of the Petition for Dissolution of Marriage as follows:
[NOTE: This section should respond to each numbered paragraph in the original petition with "Admitted," "Denied," or "Respondent lacks sufficient knowledge to admit or deny." For paragraphs that are partially admitted and partially denied, specify which portions are admitted and which are denied.]
VII. AFFIRMATIVE DEFENSES
- Respondent asserts the following affirmative defenses to claims made in the Petition:
a. [AFFIRMATIVE DEFENSE #1]
b. [AFFIRMATIVE DEFENSE #2]
c. [ADDITIONAL AFFIRMATIVE DEFENSES AS APPLICABLE]
VIII. CHILDREN OF THE MARRIAGE
- Respondent □ admits □ denies that the information regarding minor children of the marriage as stated in the Petition is accurate and complete.
- The following are the minor children born of or adopted during this marriage, or children born to the parties before the marriage:
| Child's Full Name | Date of Birth | Age | Currently Residing With |
|---|
| [CHILD 1 NAME] | [DOB] | [AGE] | □ Petitioner □ Respondent □ Other: [SPECIFY] |
| [CHILD 2 NAME] | [DOB] | [AGE] | □ Petitioner □ Respondent □ Other: [SPECIFY] |
| [ADDITIONAL CHILDREN AS APPLICABLE] | | | |
- Respondent □ admits □ denies that either spouse is currently pregnant.
- If admitted, the expected date of delivery is: [DUE DATE].
IX. CHILD CUSTODY AND PARENTING TIME
-
Respondent requests the following legal custody arrangement:
□ Joint legal custody between Petitioner and Respondent
□ Sole legal custody to Respondent
□ Sole legal custody to Petitioner
□ Other: [SPECIFY]
-
Respondent requests the following physical custody arrangement:
□ Joint physical custody between Petitioner and Respondent
□ Primary physical custody to Respondent with parenting time to Petitioner
□ Primary physical custody to Petitioner with parenting time to Respondent
□ Other: [SPECIFY]
-
Respondent proposes the following parenting time/visitation schedule:
a. Regular Parenting Time Schedule:
[DETAILED DESCRIPTION OF PROPOSED REGULAR PARENTING TIME SCHEDULE]
b. Holiday Parenting Time Schedule:
[DETAILED DESCRIPTION OF PROPOSED HOLIDAY PARENTING TIME SCHEDULE]
c. Summer/School Break Parenting Time Schedule:
[DETAILED DESCRIPTION OF PROPOSED SUMMER/SCHOOL BREAK PARENTING TIME SCHEDULE]
d. Transportation Arrangements:
[DETAILED DESCRIPTION OF PROPOSED TRANSPORTATION ARRANGEMENTS]
e. Communication During Parenting Time:
[DETAILED DESCRIPTION OF PROPOSED COMMUNICATION ARRANGEMENTS]
- Respondent believes this proposed parenting plan is in the best interests of the minor children because:
[DETAILED EXPLANATION OF WHY THE PROPOSED PLAN IS IN THE CHILDREN'S BEST INTERESTS]
X. CHILD SUPPORT
-
Respondent's position regarding child support is as follows:
□ Child support should be established according to the state child support guidelines
□ Deviation from the state child support guidelines is appropriate for the following reasons:
[DETAILED EXPLANATION OF REASONS FOR DEVIATION]
-
Respondent's current gross monthly income is $[AMOUNT].
-
To the best of Respondent's knowledge, Petitioner's current gross monthly income is $[AMOUNT].
-
The minor children have the following special needs or extraordinary expenses that should be considered in determining child support:
[DETAILED DESCRIPTION OF ANY SPECIAL NEEDS OR EXTRAORDINARY EXPENSES]
-
Respondent requests the following regarding health insurance coverage for the minor children:
[DETAILED DESCRIPTION OF PROPOSED HEALTH INSURANCE ARRANGEMENTS]
-
Respondent requests the following regarding allocation of uninsured medical expenses for the minor children:
[DETAILED DESCRIPTION OF PROPOSED ALLOCATION OF UNINSURED MEDICAL EXPENSES]
-
Respondent requests the following regarding allocation of childcare expenses:
[DETAILED DESCRIPTION OF PROPOSED ALLOCATION OF CHILDCARE EXPENSES]
-
Respondent requests the following regarding allocation of educational expenses:
[DETAILED DESCRIPTION OF PROPOSED ALLOCATION OF EDUCATIONAL EXPENSES]
XI. SPOUSAL SUPPORT/ALIMONY
-
Respondent's position regarding spousal support/alimony is as follows:
□ No spousal support/alimony should be awarded to either party
□ Respondent should be awarded spousal support/alimony from Petitioner
□ Respondent agrees to pay spousal support/alimony to Petitioner
□ Other: [SPECIFY]
-
If Respondent is requesting spousal support/alimony, the requested amount is $[AMOUNT] per month for a duration of [DURATION].
-
The basis for this request is:
[DETAILED EXPLANATION OF BASIS FOR SPOUSAL SUPPORT REQUEST, INCLUDING FACTORS SUCH AS LENGTH OF MARRIAGE, STANDARD OF LIVING DURING MARRIAGE, AGE, HEALTH, EDUCATION, EMPLOYMENT HISTORY, EARNING CAPACITY, CONTRIBUTIONS TO THE MARRIAGE, ETC.]
XII. TEMPORARY SUPPORT
-
Respondent □ does □ does not request temporary support during the pendency of these proceedings.
-
If temporary support is requested, Respondent requests:
a. Temporary child support in the amount of $[AMOUNT] per month
b. Temporary spousal support in the amount of $[AMOUNT] per month
c. Temporary exclusive possession of the marital residence
d. Temporary possession of the following property: [SPECIFY]
e. Other temporary relief: [SPECIFY]
XIII. PROPERTY DIVISION - MARITAL/COMMUNITY PROPERTY
- Respondent identifies the following assets as marital/community property subject to division:
A. Real Estate
| Property Address | Approximate Value | Mortgage Balance | Proposed Allocation |
|---|
| [ADDRESS 1] | $[VALUE] | $[BALANCE] | □ Petitioner □ Respondent □ Sell and divide proceeds |
| [ADDRESS 2] | $[VALUE] | $[BALANCE] | □ Petitioner □ Respondent □ Sell and divide proceeds |
| [ADDITIONAL PROPERTIES AS APPLICABLE] | | | |
B. Vehicles
| Year/Make/Model | VIN | Approximate Value | Loan Balance | Proposed Allocation |
|---|
| [VEHICLE 1] | [VIN] | $[VALUE] | $[BALANCE] | □ Petitioner □ Respondent |
| [VEHICLE 2] | [VIN] | $[VALUE] | $[BALANCE] | □ Petitioner □ Respondent |
| [ADDITIONAL VEHICLES AS APPLICABLE] | | | | |
C. Bank Accounts and Cash
| Financial Institution | Account Type | Account Number (last 4 digits) | Approximate Balance | Proposed Allocation |
|---|
| [INSTITUTION 1] | [TYPE] | [####] | $[BALANCE] | □ Petitioner □ Respondent □ Split |
| [INSTITUTION 2] | [TYPE] | [####] | $[BALANCE] | □ Petitioner □ Respondent □ Split |
| [ADDITIONAL ACCOUNTS AS APPLICABLE] | | | | |
D. Retirement Accounts and Pensions
| Institution | Account Type | Account Number (last 4 digits) | Approximate Value | Proposed Allocation |
|---|
| [INSTITUTION 1] | [TYPE] | [####] | $[VALUE] | □ Petitioner □ Respondent □ Split via QDRO |
| [INSTITUTION 2] | [TYPE] | [####] | $[VALUE] | □ Petitioner □ Respondent □ Split via QDRO |
| [ADDITIONAL ACCOUNTS AS APPLICABLE] | | | | |
E. Investment Accounts
| Institution | Account Type | Account Number (last 4 digits) | Approximate Value | Proposed Allocation |
|---|
| [INSTITUTION 1] | [TYPE] | [####] | $[VALUE] | □ Petitioner □ Respondent □ Split |
| [INSTITUTION 2] | [TYPE] | [####] | $[VALUE] | □ Petitioner □ Respondent □ Split |
| [ADDITIONAL ACCOUNTS AS APPLICABLE] | | | | |
F. Business Interests
| Business Name | Ownership Percentage | Entity Type | Approximate Value | Proposed Allocation |
|---|
| [BUSINESS 1] | [PERCENTAGE]% | [TYPE] | $[VALUE] | □ Petitioner □ Respondent □ Split |
| [BUSINESS 2] | [PERCENTAGE]% | [TYPE] | $[VALUE] | □ Petitioner □ Respondent □ Split |
| [ADDITIONAL BUSINESSES AS APPLICABLE] | | | | |
G. Personal Property of Significant Value
| Item Description | Approximate Value | Current Possession | Proposed Allocation |
|---|
| [ITEM 1] | $[VALUE] | □ Petitioner □ Respondent | □ Petitioner □ Respondent |
| [ITEM 2] | $[VALUE] | □ Petitioner □ Respondent | □ Petitioner □ Respondent |
| [ADDITIONAL ITEMS AS APPLICABLE] | | | |
- Respondent proposes the following general division of household items, furniture, and personal effects not specifically listed above:
[DETAILED DESCRIPTION OF PROPOSED DIVISION OF REMAINING PERSONAL PROPERTY]
XIV. PROPERTY DIVISION - SEPARATE PROPERTY
- Respondent claims the following assets as separate property not subject to division:
| Asset Description | Basis for Separate Property Claim | Approximate Value | Current Possession |
|---|
| [ASSET 1] | [BASIS - e.g., owned prior to marriage, gift, inheritance] | $[VALUE] | □ Petitioner □ Respondent |
| [ASSET 2] | [BASIS - e.g., owned prior to marriage, gift, inheritance] | $[VALUE] | □ Petitioner □ Respondent |
| [ADDITIONAL ASSETS AS APPLICABLE] | | | |
-
Respondent □ admits □ denies Petitioner's separate property claims as stated in the Petition.
-
If denied, Respondent's position regarding Petitioner's separate property claims is:
[DETAILED EXPLANATION OF POSITION ON PETITIONER'S SEPARATE PROPERTY CLAIMS]
XV. DEBT DIVISION - MARITAL DEBTS
- Respondent identifies the following debts as marital debts subject to division:
A. Mortgage and Real Estate Loans
| Creditor | Property Address | Account Number (last 4 digits) | Current Balance | Monthly Payment | Proposed Allocation |
|---|
| [CREDITOR 1] | [ADDRESS] | [####] | $[BALANCE] | $[PAYMENT] | □ Petitioner □ Respondent |
| [CREDITOR 2] | [ADDRESS] | [####] | $[BALANCE] | $[PAYMENT] | □ Petitioner □ Respondent |
| [ADDITIONAL MORTGAGES AS APPLICABLE] | | | | | |
B. Vehicle Loans
| Creditor | Vehicle Description | Account Number (last 4 digits) | Current Balance | Monthly Payment | Proposed Allocation |
|---|
| [CREDITOR 1] | [VEHICLE] | [####] | $[BALANCE] | $[PAYMENT] | □ Petitioner □ Respondent |
| [CREDITOR 2] | [VEHICLE] | [####] | $[BALANCE] | $[PAYMENT] | □ Petitioner □ Respondent |
| [ADDITIONAL VEHICLE LOANS AS APPLICABLE] | | | | | |
C. Credit Card Debt
| Creditor | Account Number (last 4 digits) | Current Balance | Monthly Payment | Proposed Allocation |
|---|
| [CREDITOR 1] | [####] | $[BALANCE] | $[PAYMENT] | □ Petitioner □ Respondent |
| [CREDITOR 2] | [####] | $[BALANCE] | $[PAYMENT] | □ Petitioner □ Respondent |
| [ADDITIONAL CREDIT CARDS AS APPLICABLE] | | | | |
D. Other Debts
| Creditor | Type of Debt | Account Number (last 4 digits) | Current Balance | Monthly Payment | Proposed Allocation |
|---|
| [CREDITOR 1] | [TYPE] | [####] | $[BALANCE] | $[PAYMENT] | □ Petitioner □ Respondent |
| [CREDITOR 2] | [TYPE] | [####] | $[BALANCE] | $[PAYMENT] | □ Petitioner □ Respondent |
| [ADDITIONAL DEBTS AS APPLICABLE] | | | | | |
E. Tax Liabilities
| Tax Year | Type of Tax | Amount Owed | Status | Proposed Allocation |
|---|
| [YEAR] | [TYPE] | $[AMOUNT] | [STATUS] | □ Petitioner □ Respondent □ Split |
| [YEAR] | [TYPE] | $[AMOUNT] | [STATUS] | □ Petitioner □ Respondent □ Split |
| [ADDITIONAL TAX LIABILITIES AS APPLICABLE] | | | | |
XVI. DEBT DIVISION - SEPARATE DEBTS
- Respondent claims the following debts as separate debts that should be the sole responsibility of the indicated party:
| Creditor | Type of Debt | Account Number (last 4 digits) | Current Balance | Basis for Separate Debt Claim | Responsible Party |
|---|
| [CREDITOR 1] | [TYPE] | [####] | $[BALANCE] | [BASIS] | □ Petitioner □ Respondent |
| [CREDITOR 2] | [TYPE] | [####] | $[BALANCE] | [BASIS] | □ Petitioner □ Respondent |
| [ADDITIONAL SEPARATE DEBTS AS APPLICABLE] | | | | | |
-
Respondent □ admits □ denies Petitioner's separate debt claims as stated in the Petition.
-
If denied, Respondent's position regarding Petitioner's separate debt claims is:
[DETAILED EXPLANATION OF POSITION ON PETITIONER'S SEPARATE DEBT CLAIMS]
XVII. INSURANCE AND HEALTHCARE
-
Respondent's position regarding health insurance coverage during and after the divorce is as follows:
a. For the minor children:
[DETAILED DESCRIPTION OF PROPOSED HEALTH INSURANCE ARRANGEMENTS FOR CHILDREN]
b. For Respondent:
[DETAILED DESCRIPTION OF PROPOSED HEALTH INSURANCE ARRANGEMENTS FOR RESPONDENT]
c. For Petitioner:
[DETAILED DESCRIPTION OF PROPOSED HEALTH INSURANCE ARRANGEMENTS FOR PETITIONER]
-
Regarding life insurance policies:
| Insurance Company | Policy Number (last 4 digits) | Face Value | Current Beneficiary | Proposed Disposition |
|---|
| [COMPANY 1] | [####] | $[VALUE] | [BENEFICIARY] | [DISPOSITION] |
| [COMPANY 2] | [####] | $[VALUE] | [BENEFICIARY] | [DISPOSITION] |
| [ADDITIONAL POLICIES AS APPLICABLE] | | | | |
- Respondent requests the following regarding life insurance coverage for the benefit of the minor children:
[DETAILED DESCRIPTION OF PROPOSED LIFE INSURANCE ARRANGEMENTS FOR BENEFIT OF CHILDREN]
XVIII. NAME CHANGE
-
Respondent □ does □ does not request restoration of a former name.
-
If a name change is requested, Respondent requests to be known by the following name: [FORMER NAME].
XIX. ATTORNEY FEES AND COSTS
-
Respondent's position regarding attorney fees and costs is as follows:
□ Each party should be responsible for their own attorney fees and costs
□ Petitioner should be ordered to pay all or a portion of Respondent's attorney fees and costs
□ Respondent agrees to pay all or a portion of Petitioner's attorney fees and costs
□ Other: [SPECIFY]
-
If Respondent is requesting that Petitioner pay attorney fees and costs, the basis for this request is:
[DETAILED EXPLANATION OF BASIS FOR ATTORNEY FEE REQUEST]
XX. DOMESTIC VIOLENCE
-
Respondent □ admits □ denies any allegations of domestic violence made in the Petition.
-
If denied, Respondent's position is:
[DETAILED EXPLANATION OF POSITION ON DOMESTIC VIOLENCE ALLEGATIONS]
-
Respondent □ does □ does not allege that Petitioner has committed acts of domestic violence against Respondent or the minor children.
-
If alleged, Respondent states:
[DETAILED DESCRIPTION OF ALLEGED DOMESTIC VIOLENCE]
XXI. ADDITIONAL RELIEF REQUESTED
- Respondent requests the following additional relief not addressed in the Petition:
a. [ADDITIONAL RELIEF #1]
b. [ADDITIONAL RELIEF #2]
c. [ADDITIONAL RELIEF AS APPLICABLE]
XXII. COUNTERCLAIMS
-
Respondent □ does □ does not assert counterclaims against Petitioner.
-
If counterclaims are asserted, they are as follows:
a. [COUNTERCLAIM #1]
b. [COUNTERCLAIM #2]
c. [ADDITIONAL COUNTERCLAIMS AS APPLICABLE]
XXIII. MANDATORY DISCLOSURE COMPLIANCE
-
Respondent □ has □ has not provided the mandatory financial disclosures required by the court.
-
If provided, the date of provision was: [DATE].
-
If not yet provided, Respondent will provide the mandatory financial disclosures by: [DATE].
XXIV. PRAYER FOR RELIEF
WHEREFORE, Respondent respectfully requests that this Honorable Court:
-
Grant a Decree of Dissolution of Marriage;
-
Award legal and physical custody of the minor children as requested herein;
-
Establish a parenting time schedule as requested herein;
-
Order child support as requested herein;
-
Order spousal support/alimony as requested herein;
-
Equitably divide the marital property and debts as requested herein;
-
Confirm the separate property and debts of the parties as requested herein;
-
Order the health insurance and life insurance provisions as requested herein;
-
Restore Respondent's former name if requested herein;
-
Order the payment of attorney fees and costs as requested herein;
-
Enter appropriate orders regarding any domestic violence allegations;
-
Grant the additional relief requested herein;
-
Grant such other and further relief as the Court deems just and proper.
Respectfully submitted this [DAY] day of [MONTH], [YEAR].
[RESPONDENT'S FULL LEGAL NAME], Respondent
[or if represented by counsel:]
[ATTORNEY NAME], Esq.
[BAR NUMBER]
[LAW FIRM NAME]
[ADDRESS]
[PHONE NUMBER]
[EMAIL ADDRESS]
Attorney for Respondent
VERIFICATION
I, [RESPONDENT'S FULL LEGAL NAME], being first duly sworn upon oath, state that I am the Respondent in the above-entitled action; that I have read the foregoing Response to Petition for Dissolution of Marriage and know the contents thereof; and that the statements contained therein are true and correct to the best of my knowledge, information, and belief.
[RESPONDENT'S FULL LEGAL NAME]
Subscribed and sworn to before me this [DAY] day of [MONTH], [YEAR].
Notary Public
My Commission Expires: [EXPIRATION DATE]
CERTIFICATE OF SERVICE
I hereby certify that on this [DAY] day of [MONTH], [YEAR], a true and correct copy of the foregoing Response to Petition for Dissolution of Marriage was served upon:
[PETITIONER'S ATTORNEY NAME] (or Petitioner if self-represented)
[ADDRESS]
[CITY, STATE ZIP]
by the following method(s):
□ U.S. Mail, postage prepaid
□ Hand Delivery
□ Email: [EMAIL ADDRESS]
□ Facsimile: [FAX NUMBER]
□ Electronic Court Filing System
□ Other: [SPECIFY]
[RESPONDENT'S FULL LEGAL NAME] or [ATTORNEY NAME]
