Legal Forms for Answer and Counterclaim

							                 COMMONWEALTH OF MASSACHUSETTS
                         TRIAL COURT
NORFOLK DIVISION         PROBATE & FAMILY COURT
                         90D 0000


DAVID SMITH,
Plaintiff

v.

MARIE SMITH,
Defendant

              DEFENDANT'S ANSWER AND COUNTERCLAIM FOR DIVORCE



Now comes the Defendant, Marie Smith, and ANSWERS as follows:

      1.     She admits the allegations in paragraphs 1 through 4.

      2.     She denies the allegation in paragraph 5.



Further, by way of COUNTERCLAIM, Marie Smith, the Counterclaim Plaintiff says:


      1. Counterclaim Plaintiff, who resides at 62 Jump Street, Anytown, Norfolk County,
         Massachusetts, is lawfully married to the Counterclaim Defendant, who now resides at
         97 Hop Street, Brighton, Suffolk County, Massachusetts.

      2. The parties were married at Pittsville, Middlesex County, Massachusetts, on January
         14, 1969 and last lived together in Anytown, Norfolk County, Massachusetts on or
         about July, 1990.

      4. There is a child of the marriage, Aaron Smith, born December 26, 1983.


      5. On or about July, 1990, at Brookline, Norfolk County, Massachusetts there came to be
      and continues to be an irretrievable breakdown of the marriage of the parties.

      6. Wherefore, the Counterclaim Plaintiff requests that the court:


           a) grant her a divorce on the grounds of irretrievable breakdown of the marriage
                pursuant to Massachusetts General Laws, Chapter 208, section 1B.
          b) order a suitable amount of alimony and an equitable division of the marital property
             pursuant to Massachusetts General Laws, Chapter 208 section 34.

          c) order a suitable amount for support and health insurance for the child.

          d) order the Counterclaim Defendant to provide health insurance coverage for her.

           e) order such further relief as is fair and just.




               Marie Smith,

               April 10, 1992



                                     CERTIFICATE OF SERVICE


              I, Marie Smith, certify that I have this 13th day of April, 1992, served the within
Defendant's Answer and Counterclaim for Divorce on the Plaintiff by mailing a copy thereof to his
attorney, Tommy Lee Jones, 000 State Street, suite 000, Boston, MA 00000.

Signed under penalties of perjury,