IN THE CIRCUIT COURT OF ________________ COUNTY
COMMONWEALTH OF VIRGINIA

________________	)		Plaintiff
	)
	)
	)
v.	)	Case No. ____________
	)
_________________	)		Defendant		
	)
	)

DEPOSITIONS IN SUPPORT OF DIVORCE
FROM THE BOND OF MATRIMONY

The depositions of ________________ (Plaintiff) and ________________ (Witness), were taken before me, the undersigned Notary Public, at  __________________________________ (Address, City, State, Zip), on __________, to be read as evidence on behalf of ________________ (Plaintiff) in support of his/her Complaint for a divorce from the bond of matrimony.

Those in attendance at the taking of these depositions:

________________	Plaintiff
________________	Witness
________________	Examiner/Attorney
________________	Notary Public

The plaintiff, ________________, being duly sworn, did depose and state as follows:

EXAMINATION by ________________.

Q.	Please state your name and address?

A.	My name is ________________ and I reside at ________________, ________________, Virginia, which is in the City of ________________, Virginia.

Q.	Are you the plaintiff in a certain divorce case styled ________________v. ________________, currently pending in the Circuit Court of the County of ________________, Virginia?

A.	Yes, I am.

Q.	What is your social security number?

A.	____________.

Q.	What is your spouse’s social security number?

A.	______________.

Q.	When and where were you and the defendant married?

A.	We were married in ________________, Virginia, on ____________.

Q.	Are there any minor children born of this marriage or adopted?

A.	_____.

Q.	What is the child’s name and date of birth?

A.	_________________, born __________________
	_________________, born __________________
	_________________, born __________________.

Q.	Are any children expected?

A.	No.

Q.	Have you been domiciled in and bona fide resident of Virginia for more than six months preceding the commencement of this suit?

A.	Yes.

Q.	Are you and the defendant over the age of eighteen years?

A.	Yes.

Q.	Are either of you in the Armed Forces of the United States of America?

A.	_____.  If yes, who? ________________

Q.	Where did you and the defendant last cohabit together as man and wife?

A.	We last lived together in the City of ________________, Virginia.

Q.	When did you separate?

A.	We separated on _____________.

Q.	When you separated did you intend to make the separation a permanent one?

A.	Yes.

Q.	Have you lived separate and apart, without any cohabitation and without interruption since that date?

A.	Yes.

Q.	Have you and your spouse settled all matters relating to property?

A.	Yes, we have.

Q.	Did you and your spouse enter into a property settlement agreement?

A.	Yes.

Q.	Mr./Mrs. ________________, I show you this document and ask if this is the agreement which you entered into with your spouse?

A.	Yes, it is.

[The property settlement agreement, dated ____________, was marked for identification as "Exhibit 1.]

Q.	If applicable, who has physical custody of your child(ren)? 

A.	_________________

Q.	Mr./Mrs. ________________, is reconciliation with your wife/husband probable or possible?

A.	No, it is not.

[The right of cross-examination of the witness by counsel for the defendant is reserved].

AND FURTHER THE DEPONENT SAYETH NOT

_____________________________
Plaintiff

The witness, ________________, being duly sworn, did depose and state as follows:

Q.	Please state your name and address?

A.	My name is ________________ and I live at ___________________.

Q.	What is the nature of your relationship with the plaintiff, ________________?

A.	I am his/her ________.

Q.	When and where were the parties married?

A.	They were married in ________________, Virginia, on ___________.

Q.	Are there any minor children born of this marriage or adopted?

A.	_____.

Q.	If yes, what is the child’s name and date of birth?

A.	_________________, born __________________
	_________________, born __________________
	_________________, born __________________.

Q.	Are any children expected?

A.	No.

Q.	Has the plaintiff been domiciled in and a bona fide resident of Virginia for more than six months preceding the institution of this suit?

A.	Yes.

Q.	Are the plaintiff and the defendant both over the age of eighteen years?

A.	Yes.

Q.	Are either of the parties in the Armed Forces of the United States of America?

A.	______.  If yes, who?  ________________

Q.	Where did the plaintiff and the defendant last live together as man and wife?

A.	In the City of ________________, Virginia.

Q.	When did they separate?

A.	They separated on ___________.

Q.	Did the parties intend to make the separation a permanent one?

A.	Yes.

Q.	Since that date have they lived separate and apart without interruption and without cohabitation?

A.	Yes, they have.

Q.	To your knowledge is reconciliation between the parties probable or possible?

A.	No.

[The right of cross‑examination of the witness by counsel for the defendant is reserved].

AND FURTHER THE DEPONENT SAYETH NOT.

_____________________________
Witness

COMMONWEALTH OF VIRGINIA;

COUNTY OF ________________; To-Wit:

	I, the undersigned Notary Public, do certify that I am a Notary Public for the Commonwealth of Virginia, at large; that ________________ and ________________, deponents above, appeared before me on the ______ day of ______________, 20___, and after being duly sworn, answered the questions above listed with the answers noted and each signed in my presence after being duly sworn. This is a true and accurate record of the proceedings herein.

_____________________________
Notary Public

My commission expires: __________________