The model text of the divorce indictment for one spouse's infidelity is as follows: plaintiff: defendant: claim
 1、 Divorce the plaintiff and the defendant;
 2、 The legitimate son/daughter is supported by the plaintiff, and the defendant pays a one-time alimony of yuan to the plaintiff (/the defendant pays alimony every month until the son/daughter is 18 years old);
 3、 The joint property of husband and wife is divided equally according to law (/____ is judged to belong to the plaintiff);
 4、 The defendant paid the plaintiff a lump sum of damages of ____ yuan, stating the specific time of marriage and the birth of children, stating the basis of the claim, and especially pointing out the legal divorce situation: the defendant committed domestic violence or maltreated or abandoned family members. It shows that the relationship between husband and wife has broken down and there is no possibility of reconciliation. The reasons and basis for the child's upbringing, maintenance fees, visiting methods, property conditions, reasons and basis for division shall be listed in detail. Sincerely, XX People's Court Plaintiff: MM/DD/YYYY
 The legal basis is: Article 121 of the Civil Procedure Law shall state the following items in the bill of complaint:
 （1） The name, sex, age, nationality, occupation, work unit, address and contact information of the plaintiff, the name and address of the legal person or other organization, and the name, position and contact information of the legal representative or principal person in charge;
 （2） Information such as the name, gender, work unit and address of the defendant, and information such as the name and address of the legal person or other organization;
 （3） The claim and the facts and reasons on which it is based;
 （4） Evidence and source of evidence, name and address of witness.