IN THE SUPERIOR COURT OF CLAYTON COUNTY

STATE OF GEORGIA

*
BARBARA CLARK-JENKINS, *
Plaintiff, *
* CIVIL ACTION FILE NO.
v. *
*
FRANKLIN DELANO JENKINS, *
Defendant. *
*

COMPLAINT FOR DIVORCE

COMES NOW the Plaintiff in the above-styled action and submits this complaint for Divorce

and states the following:

1.

Plaintiff, BARBARA CLARK-JENKINS is a resident of the State of Georgia, and resident

of Clayton County at 962 Forest Glen, Jonesboro, GA 30238 for more than six (6) months prior to

the filing of this action and the Defendant, FRANKLIN DELANO JENKINS, is a resident of the

State of Georgia and a resident of Clayton County at 962 Forest Glen, Jonesboro, GA 30238.

2.

Jurisdiction and venue are proper in ths Court. The Defendant has consented to the

Jurisdiction of this Court and has acknowledged service of process and jurisdiction of this Court.

3.

The parties were married in Jonesboro, Clayton County, Georgia on September 21, 2013.

4.

The parties separated on November 21, 2016, and have remained in a bona fide state of

separation since that date. There are no minor children of this marriage.
 5.

The parties shall divide any and all marital property as outlined in the settlement agreement

to be filed in this case.

6.

This divorce is filed on the basis that the marriage between the parties is irretrievably broken

without any prospect of reconciliation within the contemplation of the Official Code of Georgia

Annotated, § 19-5-3(13) and that the parties hereto are entitled to a total divorce, that is to say, a

divorce a vinculo matrimonii.

WHEREFORE Plaintiff petitions this honorable Court for the following:

1. That the Plaintiff be granted a divorce and vinculo matrimonii from the Defendant;

2. That the Plaintiff is awarded any further equitable relief as this Court deems just and

proper.

This day of , 20___.

Lee A. Frison, Jr.

Attorney for Plaintiff
GA Bar No. 278036
1230 Peachtree Street
Suite 1900, Promenade II
Atlanta, GA 30309
404-942-4330
lee@frisonlaw.com
 IN THE SUPERIOR COURT OF CLAYTON COUNTY
STATE OF GEORGIA

*
BARBARA CLARK-JENKINS, *
Plaintiff, *
* CIVIL ACTION FILE NO.
v. *
*
FRANKLIN DELANO JENKINS, *
Defendant. *
*

VERIFICATION

Personally appeared before me, the undersigned officer duly authorized to administer oaths,

BARBARA CLARK-JENKINS, Plaintiff, who after being duly sworn, deposes and states that the

facts contained in the foregoing Complaint for Divorce are true and correct to the best of my

knowledge, information and belief.

BARBARA CLARK-JENKINS, Plaintiff

Sworn to and subscribed
before me this
day of , 20___

NOTARY PUBLIC