IN THE CHANCERY COURT OF PEARL RIVER COUNTYSTATE OF MISSISSIPPI

IN THE MATTER OF THE DISSOLUTION OF MARRIAGE OF

))))

SHELLY LIN MCGEHEE ))

AND ) CASE NO.       )

MICHEAL EDMOND MCGEHEE JR ))

BY JOINT COMPLAINT )

JOINT COMPLAINT FOR DIVORCE

COMES NOW, SHELLY LIN MCGEHEE and MICHAEL EDMOND MCGEHEE

JR , Husband and Wife, and file this Joint Complaint for Divorce and in support hereof would

show unto the Court the following, to-wit:

1. This Court has jurisdiction of the parties and subject matter pursuant to the laws of

the State of Mississippi.

2. The Parties are actual and bona fide adult resident citizens of PEARL RIVER

County, Mississippi, and have been for more than six (6) months next preceding the filing of this

Joint Complaint.

3. The Parties were married on the 15 th day of September , 2007 , and

separated in PEARL RIVER County,

Mississippi, on 13th day of MARCH , 2015 .

4. Since the date of said separation, the 13TH day of MARCH , 2015 , the

Parties have not cohabited as husband and wife.

5. The present address of the Parties are as follows: SHELLY LIN MCGEHEE 73

PEA RIDGE ROAD, PICAYUNE, MS 39466

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MICHAEL EDMOND MCGEHEE JR 130 ALAN ROAD CARRIERE, MS 39426

6. The Parties allege that they are entitled to a Divorce on the grounds of irreconcilable

differences.

7. There is no reasonable expectation that the parties will reconcile.

8. There are ONE minor child(ren) of the marriage; namely,

DESTYNE JEAN D. MCGEHEE , born 5th day of MAY , 2008 ,

      , born       day of       , 20      ,

      , born       day of       , 20      ,

      , born       day of       , 20      .

9. Neither party has participated, as a party, witness, or in any other capacity, in any

other litigation concerning the custody of the parties' minor children in Mississippi or any other state.

10. Neither party has any knowledge of any custody proceeding concerning the parties'

minor children pending in a court of Mississippi or any other state.

11. Neither party knows of a person not a party to this proceeding who has physical

custody of the parties' minor children or who claims to have custody or visitation rights with respect

to the parties' minor children.

12. All matters involving custody and support of the above named children have been

resolved and the terms agreed to in the Separation and Property Settlement Agreement attached

herein as Exhibit “A”.

13. All matters involving property of the marriage, both real and personal, have been

resolved and the terms agreed to in the Separation and Property Settlement Agreement. All debts

have likewise been resolved by the parties in the Separation and Property Settlement Agreement

attached herein as Exhibit “A”.

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14. Party       , requests that her former name of

      be restored unto her. This request is not made for any illegal or

fraudulent reason.

15. The Parties further state the following:

We do not know of any other cases in the State of Mississippi or any other state or

territory involving the same claim or subject matter as this case.

OR

We know of the following related cases concerning the same claim or subject matter

as this case.

WHEREFORE, PREMISES CONSIDERED, SHELLY LIN MCGEHEE and

MICHAEL EDMOND MCGEHEE JR pray that:

(A) The Court grant the parties a Divorce on the grounds of irreconcilable differences;

(B) That the terms of the Separation and Property Settlement Agreement in which all

issues of custody and support of the children of the marriage are resolved and which disposes of all

jointly owned property and settling all jointly owed debts and rights and liabilities of the parties, a

copy of which is attached hereto as Exhibit “A”, be incorporated into the final judgement of divorce:

(C) For judgment and relief as set forth in this Complaint.

(D) For such other relief and judgment as is just and equitable in the premises

Respectfully submitted,

Husband’s Printed Name MICHAEL EDMOND MCGEHEE JR Husband’s Signature

Wife’s Printed Name SHELLY LIN MCGEHEE Wife’s Signature

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STATE OF MISSISSIPPI

COUNTY OF PEARL RIVER

PERSONALLY appeared before me, the undersigned authority in and for the

county and state aforesaid, the within named,       , one of the

Co-Plaintiffs, who, being by me first duly sworn, stated on oath that the matters, facts and

averments set forth, contained and alleged in the above and foregoing Joint Complaint for

Divorce are true and correct as therein stated.

Signature:

Print Name:      

SWORN TO AND SUBSCRIBED this the       day of       , 20      .

____________________________________NOTARY PUBLIC

MY COMMISSION EXPIRES:      

STATE OF MISSISSIPPI

COUNTY OF      

PERSONALLY appeared before me, the undersigned authority in and for the

county and state aforesaid, the within named,       , one of the

Co-Plaintiffs, who, being by me first duly sworn, stated on oath that the matters, facts and

averments set forth, contained and alleged in the above and foregoing Joint Complaint for

Divorce are true and correct as therein stated.

Signature:

Print Name:      

SWORN TO AND SUBSCRIBED this the       day of       , 20      .

____________________________________NOTARY PUBLIC

MY COMMISSION EXPIRES:      

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