SAMPLE Divorce Complaint – Irreconcilable Differences

Attorney At Law
700 E Palisade Ave #101
Englewood Cliffs, NJ 07632
Tel: (201) 585-7444
Fax: (201) 541-6674
Attorney for Plaintiff








Civil Action


The Plaintiff, (Plaintiff’s name), residing at (Plaintiff’s address) County of (Plaintiff’s County), State of New Jersey, by way of Complaint against the Defendant says:

First Count
  1. He/She was lawfully married to (defendant’s name), the defendant herein, on (date of marriage) in a (civil or religious) ceremony in (Municipality of Marriage), (County of Marriage), (State of Marriage).
  2. Plaintiff was a bona fide resident of (plaintiff’s county of residence when the cause of action arose), State of New Jersey when this cause of action arose and for more than one year next proceeding the commencement of this action has been a bona fide resident of (plaintiff’s county of residence when the cause of action arose), New Jersey.
  3. The Defendant, (defendant’s name) resides at (defendant’s address) State of New Jersey.
  4. The parties have irreconcilable differences which have caused the breakdown of the marriage for a period of six consecutive months.
  5. The marital breakdown has continued to the time of the filing of the complaint for divorce.
  6. The differences are of such an extent and nature that it reasonably appears that the marriage should be dissolved.
  7. There is no reasonable prospect of reconciliation between the parties.
  8. There are no children born of the marriage. Nor are there any adopted children or expected children.
  9. There have been no previous proceedings between the parties respecting the marriage or its dissolution or respecting the maintenance of either party:
    WHEREFORE, Plaintiff demands judgment:
  1. Dissolving the marriage between the parties pursuant to N.J.S.A. 2A:34-2(i);
  2. For such other and further relief as the Court may deem equitable and just.



Certification Pursuant to R. 4:5-1

I hereby certify to the best of my knowledge, information, and belief that the matter in controversy is not the subject of any other action pending in any court, or of a pending arbitration proceeding, that no other action or arbitration proceeding is contemplated, and I am not aware of any other person who should be joined in this matter.



Trial Counsel Designation Pursuant to R. 4:5-1(c)

Brian D. Iton, Esq., is hereby designated trial counsel in this matter.

Certification of Verification and Non-Collusion Pursuant to R. 5:4-2(c)

I, (PLAINTIFF’S NAME), being of full age, hereby certify:

I am the Plaintiff in the foregoing Complaint. The allegations in the Complaint are true to the best of my knowledge, information and belief, and the said Complaint is made in truth and good faith and without collusion for the causes set forth therein. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment.


Client Reviews
Divorce can be a nasty and trying time in someone’s life. Thank God for Brian Iton who showed compassion and quickly answered all my questions and concerns. His rates were reasonable and Mr. Iton made the process as painless as possible. I was very impressed with the professionalism and attention to every detail. I highly recommend Brian Iton, Esq. J. H, Sr
Just a note to thank you for your professionalism, competence and passion for what you do. I appreciate you taking out the time to always explain the steps surrounding my divorce. It helps greatly to understand where I’m going. You were truly a blessing in this difficult time in my life S.D.
In my search for legal representation, I had consultations with several law firms in New Jersey and was taken aback by their lengthy, expensive and complex retainer agreements. Luckily, I stumbled onto Iton Law and can truly say that Brian delivered to my utmost satisfaction. N.S.
The Iton Law Firm made a traumatic life event an easier one! From the moment I reached out to Brian at the law firm, I was handled with kid gloves. Brian not only listened but was empathetic and caring ... the time and patience he showed during this hardship was unbelievable. T.F.
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