1. Terry Evers
Family Law
Fall 2015
1
IN THE CIRCUIT COURT OF BENTON COUNTY, ARKANSAS
DOMESTIC DIVISION
WENDY JACKSON Plaintiff
VS. CASE NO. DR- 2015 -85 – 4
MICHAEL JACKSON Defendant
COMPLAINT FOR DIVORCE
Comes now the Plaintiff, Wendy Jackson,and for her Complaint for Divorce filed herein, does state and
allege as follows:
1. Plaintiff is a resident of Bentonville, Benton, County, Arkansas, and has been for at least 60 days.
2. The Court has jurisdiction of the parties, and subject matter herein, thus venue is proper.
3. The parties have lived together as husband and wife in Benton County since their marriage June
15, 1989.
4. The parties have lived separate and apart since on or about June 23, 2015 without cohabitation.
5. During the marriage, the Defendant has treated the Plaintiff with such indignities, in such a
manner, and, fashion in life as to render Plaintiff’s life intolerable, all pursued over the entire
course of the parties’ marriage past.
6. The parties are the parents of two minor children, Emily, age eleven years,and Maxwell, age three
years.
7. The Plaintiff is the fit and proper party to have the temporary and permanent custody of the minor
children, subject to the Defendant’s right of reasonable, liberal visitation.
8. The Defendant should be ordered to pay a reasonable amount of child support and alimony
commensurate with his ability to pay.
9. The parties’ marital property and debts should be adjudicated by the court, in the event the parties
are unable to reach an agreement.

2. Terry Evers
Family Law
Fall 2015
2
10. The mattershould be set for a temporary hearing to determine the issues of child custody, alimony,
visitation, and, child support during the pendency of this action.
WHEREFORE,the plaintiff, Wendy Jackson, prays that she be granted a decree of absolute divorce from
Defendant herein; that she be awarded the temporary and permanent care and custody of the parties’ minor
children, Emily and Maxwell, subject to the Defendant’s right of reasonable, liberal visitation; that the
Defendant be ordered to pay a reasonable amount of child support based upon his ability to pay; that the
Defendant be ordered to pay a reasonable amount of alimony commensurate with his present income; that
the Court adjudicate the parties’ marital property and debts, in the event they are unable to reach an
agreement; that she be awarded her costs, attorney’s fees, and, for all other relief to which she may show
herself to be entitled.
WENDY JACKSON, Plaintiff
By her Attorney:
_____________________________
Stephen Hawks, Bar # XXXXX
123 North Last Street
Bentonville, AR 72717
479 – 709- XXXX