与客户就起诉状进行沟通（包括起诉书样本）
VIA REGULAR INTERNATIONAL MAIL
May 18, 2004
Mrs. Grace M. Wang
123 Oak Street
Hometown, Virginia 30012
U.S.A.
Re: Mrs. Wang vs. Mr. Wang
Haidian District People’s Court Docket No. 111
Dear Mrs. Wang:
Following up on your request, enclosed for your careful review please find a draft of
the proposed Complaint (with English translation) in the above referenced matter.
Although I have tried to draft the Complaint from the information and documents you
have provided, I must ultimately rely on your personal knowledge of these facts to
make sure the Complaint is accurate and complete.
This is an important legal document, and before it is filed we must try to make sure
that there are no misstatements or exaggerations. With this in mind, please review it
carefully and make any suggested corrections, changes, or additions either directly on
this draft or in a separate memo directly from you to me (to preserve the
attorney-client privilege), or both. These being done, please return the document(s)
to me as soon as possible so that I can continue to move forward on this matter.
As always, if you have any problems, comments, or concerns, please let me know.
Sincerely,
Wang, Zhang & Lee
_________________
Deguang Zhang, Esq.
Enclosure
BEIJING HAIDIAN DISTRICT PEOPLE’S COURT
Mrs. Grace M. Wang, Plaintiff vs. Mr. Bai Wang, Defendant.

Case No. 11111
COMPLAINT FOR ABSOLUTE DIVORCE
1. The court’s jurisdiction is based on P.R.China Civil Procedure Code Section 3,
Article 101.
2. Plaintiff, Mrs. Grace M. Wang, is a naturalized citizen of the United States and a
resident of the State of Virginia, currently residing at 123 Oak Street, Hometown,
Virginia 30012.
3. Defendant, Mr. Bai Wang, is an adult citizen of the People’s Republic of China and
a permanent resident of the Beijing Municipality for 41 years, actually residing at
Yingchun Beili 5-13-2-408, Haidian District, Beijing 100013.
4. The parties were lawfully married on April 1, 1990, in Handian District of Beijing
Municipality, at which time both were citizens of the People’s Republic of China
and permanent residents of Beijing Municipality.
5. There were two children born of said marriage, namely, Jacky Wang, born June
12, 1994, and Melissa Wang, born April 1, 1997, both of whom currently residing
with Plaintiff in the State of Virginia of the United States of America.
6. That the Plaintiff is a fit and proper mother to have custody of said minor
children.
7. That on numerous occasions and over the past several years the Defendant did
and continues to commit adultery; said adultery has been committed by
defendant with an individual by the name of Ms. Second Mistress, whose
address is currently unknown to Plaintiff; the Plaintiff has neither forgiven nor
condoned said conduct; and there is no reasonable hope or expectation of a
reconciliation between the parties.
8. That although conduct of the Plaintiff has been that of a faithful, kind and chaste
wife, yet the Defendant has persistently engaged in cruelty of treatment of the
Plaintiff, and has engaged in excessively vicious conduct, endangering Plaintiff’s
safety, health, and happiness, and has assaulted Plaintiff on a number of
occasions, causing her bodily injury, and has harassed and humiliated her in the
presence of her family including their minor children and friends, and rendering
the marital relationship impossible if Plaintiff is to preserve her health, safety
and self-respect.
9. The Plaintiff and Defendant are joint owners of the real property located at
Yingchun Beili 5-13-2-408, said real property being an apartment by the size of
approximately 150 square meters.
10. That the parties hereto had jointly purchased said property on or about May 13,
1998, as Tenants by the Entireties, since they were duly married then.
11. That since the purchase of said property in 1998 the Plaintiff has continued most,
if not all, of the mortgage payments including principal and interest, as well as
the homeowner’s insurance; that all of the aforesaid payments have been made
with very meager capital contribution on the part of the Defendant.
12. That currently there exists certain other marital property owned by either or

both of the parties, including but not limited to bank accounts, stocks and
securities, pension and profit-sharing accounts, furniture and furnishings and
two automobiles.
WHEREFORE, the above premises considered, Plaintiff prays:
1. That Plaintiff be awarded an absolute divorce from the Defendant on the
grounds of adultery and/or cruelty.
2. That the Defendant be enjoined and restrained from harming, molesting,
harassing, threatening or otherwise interfering with the Plaintiff.
3. That the Plaintiff be awarded temporary and permanent custody of the minor
children of the parties.
4. That the Defendant be ordered to pay Plaintiff a reasonable sum for the
temporary and permanent child support.
5. That the Court determine the ownership and value of all personal property
regardless how titled.
6. That upon the final hearing of the action the Court order a sale in lieu of
partition of the real property located at Yingchun Beili 5-13-2-408, Beijing, and a
division of the proceeds of sale between the parties based upon their respective
interest in the property, and further requiring contribution from the Defendant
for the mortgage payments, homeowner’s insurance, and necessary repairs and
maintenance paid by the Plaintiff.
7. That Defendant be ordered to pay to Plaintiff suit money and court costs,
including a reasonable contribution toward Plaintiff’s attorney’s fees in
connection with legal services for the benefit of said children.
8. And such further relief as the Court may deem proper and just.
_______________________
Grace M. Wang, Plaintiff
To the Honorable Court: ss
Grace M. Wang, being first duly sworn on oath, deposes and states that the
forgoing “Complaint for Absolute Divorce” has been subscribed and read by her and
that the things contained therein are true to the best of her knowledge, information
and belief.
____________________________
Grace M. Wang
Subscribed and sworn to before me this ______ day of _______, 20____.
______________________________

Notary Public
Respectfully submitted,
_________________________
Deguang Zhang, Bar # 12345
Zhang, Wang & Lee, L.L.P.
Attorney for Plaintiff
666 East Chang’an Boulevard
Beijing 100001, China
010-1234-5678