First of all, the first part
1. Title: "Civil Complaint of Divorce".
2. Party column: the woman's name, age, nationality, native place, occupation or position, unit or address.
3. The cause of action, the cause of responding to the lawsuit and the time of receiving the copy of the complaint.
Second, the defense arguments and arguments
Express opinions on whether the facts and reasons stated in the man's claim are in line with the actual situation. All the facts claimed cannot be established, and all of them are denied. Some can't be established, and some are denied.
1, whether to agree to the defense of divorce, and briefly explain the reasons;
2. Respond to the problem of child support and briefly explain the reasons;
3, the list of property and the division of defense reasons, briefly explain the reasons;
4. Respond to the problem of fault compensation and briefly explain the reasons.
Cite relevant laws, put forward facts that are in line with the objective truth to prove and demonstrate the facts, and emphatically list negative evidence to prove that the facts stated in the plaintiff's complaint cannot be established, requiring the disproof to be true and sufficient, and not to deny the things stated in the man's complaint out of thin air.
Third, the tail
1, the time for writing the defense.
2. A woman's signature.
Attachment: sample of divorce defense
Defendant: Zhang, female, Han nationality. Born on _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
In the case of _ _ _ _ v. the respondent's divorce dispute, the respondent made the following defense:
1. The statement that the respondent _ _ _ _ _ _ _ _ _ claimed that the relationship between husband and wife broke down in the civil complaint was not valid. In fact, the respondent and the respondent have a good relationship.
(1) The respondent and the respondent have a solid marriage foundation. What the defendant said is not true. In fact, it was after the respondent and the respondent had known each other for nearly three years and fully understood each other that they were very satisfied with their personality, education, work and life before registering for marriage.
(2) The respondent and the respondent have a harmonious relationship after marriage. What the defendant said is not true. In fact, the respondent and the respondent are loving and caring, and the defendant tried his best to take care of the plaintiff when he was sick. Especially after having a son, the three of us are happy and enjoy family happiness.
(3) The real reason for the defendant's divorce is that he has changed his mind and has another love. (4) The "_ _ _ _ _ _ _ _ _ _" stated by the respondent in the civil complaint is untrue.
In fact, the Respondent and the Respondent have been living in the _ _ _ _ _ _ _ _ unit.
2. The "_ _ _ _ _ _ _ _ _" stated by the Respondent in the civil complaint is not true, and the Respondent resolutely disagrees with the divorce. The "_ _ _ _ _ _ _ _ _" stated by the respondent in the civil complaint is not true.
Third, the opposite is true. The son has been taken care of by the respondents since he was born, and the respondents basically don't take care of the children. Even if the child is hospitalized with a fever, the respondent will ignore it. To sum up, the defendant strongly disagreed with the divorce.
Four, our hospital implores the people's court to comprehensively consider the facts of the case, combined with the legal provisions, the judgment is not allowed to divorce the defendant.
Verb (abbreviation of verb) 1. The current situation of the relationship between the respondent and the respondent in this case is that although there are minor contradictions, it is a normal quarrel between husband and wife, which is far from the complete breakdown of the relationship between husband and wife.
2. The respondent in this case has both the desire and the possibility of reconciliation.
From this point of view, the divorce between the defendant and the defendant in this case is only an episode in the symphony of normal husband and wife life, and it is a "threshold" that almost every couple may encounter. The respondent believes that as long as the collegial panel can combine the facts of the case and the legal provisions, supplemented by patient and meticulous persuasion, the "stumbling" between the respondent and the respondent can be resolved. To sum up, the respondent has no factual basis for the respondent's claim, requests the people's court to protect the respondent's legitimate rights and interests, rejects the respondent's claim against the respondent, and decides that the respondent is not allowed to divorce the respondent.
I am here to convey
_ _ _ _ _ _ _ _ _ People's Court
Defendant _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _