IN THE CHANCERY COURT OF COOK COUNTY, MISSISSIPPI

MEGAN HALLAM PLAINTIFF

VS. CAUSE NO__________

CURTIS HALLAM. DEFENDANT

COMPLAINT FOR DIVORCE

NOW COMES, the Plainti , MEGAN HALLAM, and les her Complaint for Divorce against Defendant,

CURTIS HALLAM, and would respectfully show unto this Honorable Court as follows:

1.

Plainti , MEGAN HALLAM, is an adult resident citizen of Cook County, Mississippi, and had been for

more than six months next preceding the ling of this suit.

2.

Defendant, CURTIS HALLAM, is also an adult resident of Cook County, Mississippi who may be served

with process at 752 Cox Avenue, Strickland, Mississippi 38822 or wherever he may be found.

3.

That the Plainti and the Defendant were lawfully married on the 23rd day of February, 1988 in Jones

County Mississippi. The parties have been separated on or about August 1, 2023.

4.

That two (2) children were born, during the marriage, namely Jade Hallam and Jesus Hallam, fraternal

twins born July 26, 2004. Jade Hallam and Jesus Hallam are nineteen (19) years of age. That the Plainti is a t

and proper person to have the permanent and temporary legal and physical custody, care and control of the

parties’ minor child, and would ask that she be awarded same, with visitation rights reserved unto the Defendant.

Wife is not pregnant and no more children are expected and the parties have not adopted any children.

5.

That the Plainti at all times during the marriage has been true and faithful to the marital vows and has

done all things to make the Defendant good and dutiful Husband and to discharge fully and properly all obligations

imposed by the marital relationship. Notwithstanding the e orts of the Plainti , the Defendant has breached the
marital obligations. Further, the Plainti charges the Defendant with ________________________________

_____________________________________________________________________________________________

______________________________________________________________________________________________

______________________________________________________________________________________________

Therefore, the Plainti is entitled to a divorce absolute of and from the Defendant upon the statutory ground of

Plainti is entitled to a divorce absolute of and from the Defendant upon the statutory ground of ______________?

6.

In the alternative, Plainti would show unto the Court that she is entitled to a full and complete divorce of

and from the Defendant pursuant to Sec. 93-5-1 of the Mississippi Code of 1972, as amended, upon the ground of

Irreconcilable Di erences, if the parties can agree in writing. To a divorce on said ground, and after the expiration

of sixty (60) days from the service of process of this complaint upon the Defendant.

7.

Defendant is an able-bodied man and has a substantial income. Plainti owns a successful business that

she operates out of her home. With the loss of his income as a successful diesel mechanic she no longer has the

support and funds in which to maintain herself and their children in the style to which they are accustomed. The

Defendant should be required to provide Plainti alimony in any and lil various forms, both on a temporary and

permanent basis.

8.

Plainti is without su cient funds to provide medical and dental coverage for herself and their children. The

Defendant should be required currently and in the future to maintain medical and dental insurance for the bene t

of the Plainti and also required to maintain medical and dental insurance on their children to the age of twenty-six

(26). Also, for the bene t of the Plainti and their children the Defendant is to pay all insurance premiums on said

insurance. Plainti would further show that Defendant should pay all current and future medical; drug, clinic,

hospital, optometric, and dental charges incurred for the bene t of the Plainti which are not covered by the

Plainti ’s current insurance policy.

9.

That the parties are owners of real property located at 301 East Penny Road, Stricklin, Mississippi 38822, in
 Cook County, Mississippi. Plainti should be awarded permanent and exclusive use of said real property with all

furniture, appliances and immediate possession of said real property. That the Defendant should be order to pay

the monthly mortgage payments on any real property, pay all ad valorem taxed and other taxes on the property,

maintain, and pay hazard insurance on said dwelling and property for the bene t of the Plainti .

10.

That the Plainti should be awarded any automobile in her possession including the 2014 Toyota

Highlander and Defendant should be required to pay any tag or insurance and all necessary repairs on said

automobile. Defendant should be ordered to take such action as may be necessary to transfer title of said

automobile to Plainti .

11.

During the marriage, the Defendant acquired in his name certain retirement accounts and/or 401k which

accounts are marital property. The Plainti requests that the Court equitably divide any such retirement accounts

in conformity with the laws of the State of Mississippi.

12.

The Plainti should be awarded the full use, title, and possession of any and all retirement accounts in her

name.

13.

The Plainti would show unto the Court that the following a divorce in the matter, she should be granted an

equitable division in all marital assets, including but not limited to, real estate, businesses, household goods and

furnishings, personal property, automobiles, yard and/or farm equipment, motor homes, stocks, bonds, savings, and

checking accounts, mutual funds, liquid currency, and any and all assets which may be classi ed “marital assets” which

have been accumulated by the parties.