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Sample New York Supreme Court Matrimonial Verified Answer (FOR EDUCATIONAL PURPOSE ONLY …NOT TO BE USED IN LITIGATION)  


County of Suffolk




– against-


Defendant.                                                                                VERIFIED ANSWER


Index No.:


Defendant, _____________., appears, answering the complaint herein,

respectfully alleges as follows:

1. Defendant neither admits nor denies the allegations contained in paragraphs

“_________” of the Plaintiff’s Verified Complaint.


2. The parties are over the age of 18 years.

3. The Plaintiff has resided in New York State for a continuous period in excess of one

year immediately preceding the commencement  of this action and the cause of action occurred in

New York State and both Plaintiff and Defendant were residents thereof at the time of the

commencement of this action.

4. The Plaintiff and the Defendant were married on _________, in the _____________. The marriage was performed by a clergyman, minister or by a leader of the Society for Ethical Culture. The Plaintiff will take prior to the entry of final judgment all steps solely within his power to remove any barrier to the Defendant’s remarriage.

5. There are ________ unemancipated children of the marriage, to wit;




6. The Plaintiff resides at ____________________ and her Social

Security No. is ___________. The Defendant resides at __________________ and his Social Security No. is ______________.

7. The grounds for divorce that are alleged as follows: Irretrievable Breakdown (DRL

Sec. 170(7»: For a period of more than six (6) months immediately prior to the commencement of

this action, the marital relationship between the Plaintiff and Defendant has irretrievably broken


8. There is no judgment in any court for a divorce and no other matrimonial action

between the parties pending in this court or in any other court of competent jurisdiction.

WHEREFORE, the Defendant respectfully requests the following relief:

(a) Awarding a judgment of absolute divorce forever dissolving the bonds of matrimony

heretofore existing between the parties;

(b) An award of custody of the infant issue of the marriage to the Defendant;

(c) An award of a reasonable sum as and for the support of the infant issue to the


(d) Awarding Defendant a reasonable sum as and for Defendant’s support and


(e) Awarding Defendant title to the marital abode;

(t) Awarding Defendant an equitable distribution of real and personal property;

(g) Awarding Defendant a reasonable sum as and for counsel fees;

(h) Awarding Defendant insurance on the Plaintiff’s life with the infant minor as

irrevocable beneficiary;

(i) Awarding Defendant a distributive award;

G) Awarding Defendant title to Defendant’s separate property;

(k) A warding Defendant title to furniture and personal property in the marital abode;

(1) Awarding Defendant a declaration of marital property;

(m) Awarding Defendant a declaration of separate property;

(n) Directing the Plaintiff to pay all outstanding obligations of the marriage;

(0) Awarding Defendant and infant minor health insurance;

(P) Awarding Defendant such other, further and different relief as this Court deems just,

proper and equitable.

Dated: __________

_______, New York

TO: _________________

Yours, etc.


Attorneys for Defendant





___________________ being duly sworn, deposes and says: I am the

Defendant in the within action; I have read the foregoing VERIFIED ANSWER WITH

COUNTERCLAIM and know the contents thereof; the same is true to my own knowledge, except

as to the matters therein stated to be alleged on information and belief, and as to those matters I

believe it to be true.


Notary _________________






Sample New York Supreme Court Matrimonial Verified Answer (FOR EDUCATIONAL PURPOSE ONLY …NOT TO BE USED IN LITIGATION)  

ATTORNEY ADVERTISING: Information herein and is not intended to be, legal advice. This sample legal document is provided as part of a free public educational service by Zachary Irtaza Riyaz, Esq., attorney at law in the State of New York (Westhampton – Tel. 516-234-0348), for reference only. IT IS NOT INTENDED TO GIVE LEGAL ADVICE ABOUT A SPECIFIC LEGAL PROBLEM, NOR DOES IT CREATE AN ATTORNEY-CLIENT RELATIONSHIP. Due to the importance of the individual facts of every case, the generalizations I make may not necessarily be applicable to any particular case. Statutes and codes such as Domestic Relations Law (DRL)are frequently amended and may affect the validity of the above legal document and no representation is made that the above sample is going to be enforceable in the future. Changes in the law could at any time make parts of this web site content obsolete.  Updated statutes and codes may be available at the New York State Legislature Website. No statute or sample legal document should be relied on without understanding controlling case law which may further interpret it. THIS INFORMATION IS PROVIDED WITH THE UNDERSTANDING THAT IF LEGAL ADVICE IS REQUIRED THE SERVICES OF A COMPETENT ATTORNEY SHOULD BE CONSULTED.