Wording the grounds for divorce - UB

After spending hours on this immensely helpful site I feel a lot more courageous to kick off with my divorce.

After reading through the posts on the unreasonable behaviour reasons I have come up with my list. I do have a lot of doubts regarding this list and the wording though.

First I thought I would just keep it nice to please my husband and make my life easier. But then I am not sure I am comfortable with him spending time with our daughter on their own just yet. She has gone through a lot of drama because of his violent character and he has had pretty much no interest in her so far, but you never know with him - he might change his mind now just to hurt me through her. He has done so before.

So then I changed my mind ref the reasons for divorce and decided to include the ones that he is bound to not like.

I would appreciate your advice though. Should I change or leave out anything?
Should I include more details, dates etc?
Where do I mention that since February 2012 I no longer live in a matrimonial house? (I and my daughter has lived at my brother''s place for the past 5 months).

Here is what I have come up with so far:

Since 2010 the Respondent has shown no affection or interest of an intimate nature towards the Petitioner. He has indicated by his manner and behaviour that he has no wish to spend any time or communicate with her affecting the Petitioner‘s self esteem as this made her feel unattractive and lonely.
Since 2010 the Respondent has spent most of his time off work drinking alcohol either on his own or with friends leading no social life with his family. His alcohol addiction has been getting worse, and for the past year he has had a few sober days a month, leaving the Petitioner feel burdened with all the responsibilities of the household and childcare.
Since 2010 the Respondent has been habitually excessively critical, rude and verbally abusive towards the Petitioner. Most of the time at home he ignores the Petitioner, and when he addresses her it is in the accusing, aggresive or threatening manner causing the Petitioner to feel belittled and humiliated.
A few times since July 2011 the Respondent threatened to hurt the Petitioner if she tells anyone of the way he has been treating her at home.
The Respondend has been physically violent towards the Petitioner on a number of occasions; he attacks with a clenched fist, pretends to hit and swears at the Petitioner telling her that he can effotlessly make her unconscious. The most recent incident of this kind happened in January 2012. In September 2011 the Respondent pushed the Petitioner against the table causing her bruises. The constant fear for her own and daughter‘s safety has resulted in deterioration of the Petitioner‘s health.

The Respondent has behaved in such a way that the Petitioner cannot reasonably be expected to live with the Respondent.
The said marriage has broken down irretrievably.

Looks pretty good. Only changes I would make are:
- Remove the "Since 2010"s, these are not really needed and it may be suggested that you lived with it for too long. So I would simply remove these words from your first 3 points.
- Remove the September 2011 incident from the end. It''s not needed.
- Add a final point at the bottom, "the Petitioner moved out of the marital home in February 2012 due to these incidents and has not returned since"

I would be slightly cautious of putting actual physical assaults in the Petition. Your husband is unlikely to agree that he was physically abusive and he could defend the Petition adding significantly to costs and time. Instead of stating that he was physically abusive you could state that you feared for your safety.
Abusive men rarely become reasonable during the divorce process and despite their own solicitors advising them not to defend some will. Sadly by stbx (or should I say not so soon to be)is one of them.

Respondents can defend some or all of the allegations made against them but still consent to the divorce in the AoS. Defending an/all allegation(s) is not the same as defending the divorce action, for which there is only one true legal ground in that the marriage has not ended and is still on-going.

I disagree about removing an actual assault, it is a clear indication that you can not be reasonably expected to remain in the marriage with that kind of behaviour occurring. However, a specific incidence does need to be within the last 6 months or so of you having lived together as husband and wife, which in your situation the September incident would be within that timeframe.

Hi - regarding OP''s situation, sorry, can''t seem to scroll back to find your name - new on here and this is my first post apart from my introduction, so forgive me if I am in wrong place, but on same theme re UB wording....!

Been struggling myself with the wording in so far as which tense to use: since I left Oct 2010, I can''t really use the present continuous. I did read on this very helpful site though, that one is recommended to use both the worst and the last incident.

I have a relatively simple question to ask all you lovely helpful Wikis out there - can I also cite incidents of UB AFTER my leaving the MH: have found out from my octogenarian parents he has been phoning them up in the intervening time, despite his promising me to leave them alone at the time of seperation, a promise he has obviously reneged on. Obviously, calls are of an abusive nature. Last incident of this was only in Feb this year - would I be able to cite this - the fact he reneged on his promise not to contact my elderly parents ever again - as the last example of UB, even though we had already been seperated for well over a year by then?

My other question - sorry about this! - but due to the amount of time between my physically leaving the marital home and submitting D8, would it be advisable to state this fact BEFORE listing my examples of UB, rather than AFTER, so that judge realises I am talking in the retrospect, though I suppose that will be self-evident when I cite my examples in the past tense, so sort of answered my own question really! Sorry, got a touch of ''divorce-fever'', I think!!!!LOL! Just been sat on here for days and days now, as a silent ''lurker'' just trying to learn all I can, and what a helpful site it is!!!! Thanks.

Final question, re seamless cohabitation to marriage. Where and how to make the judge aware that it was a 9 year relationship? ( lived together 7 years, married less than 4 months before the final act of domestic violence that necessitated I leave the MH) I don''t know how to make judge aware of this fact, or does that come later on the Chronology. I suppose the length of the ''marriage'' only is of importance re AR proceedings, which I do intend to apply for on Form A. For now, I just need to word the D8 well-enough not to get it struck out, and cost me 90 squids to resubmit! Just want to get the ball rolling after all these months of pontification!
Sorry, didn''t mean to hijack your thread, original poster - I am new on here, not sure of the etiquette, but sounds like we are both at the same stage, and you might have found something I said of some use!

Many thanks for what is a terrific site, Wiki.

Dear RubyTuesday - you have just answered one of the questions I had in your reply to the OP, many thanks. I also agree with your opinion that incidence of physical violence even where police were not involved and no record of it anywhere, ought to be submitted: good enough reason for any Judge, surely, to see the marriage has irretrivably broken down and that P can''t be reasonably exected to live with him/ her any longer!!!! In my case, not only domestic violence, but verbal abuse for many years. I shall just cite examples of both verbal abuse and domestic violence and make clear on my D8 that after the final incident of the latter, I had no choice but to leave the MH, he really hurt me that time, and feared for my safety..... not much fun this, is it, reliving the nightmare! I just feel sorry for any other person reading this still stuck in an abusive marriage. I''ve been putting off my divorce out of fear of him all this time, but now he has made himself unemployed by choice and decimating marital assets, I really do have to get my head out of the sand and crack on with this. Looked at Freezing Injunctions, but after all this time, no idea where he has put the money from him taking early retirement, so no idea how I am going to get Discloure from him.... This is the sort of man who even lies about still being at his work when really he''d retired... Roll on form E time, that should be fun - will be having a lot of questions for him on the questionnaire! But once the - OUR - money has gone, and he has sold our marital assets, not much I can do about it, so time to get a move on, I think! Once I have submitted my D8, I will feel so much happier - it will be court-timetabled and am also very relieved to know a judge will decide the AR. I think this one will go all the way to a FDR, you see. I just look forward to seeing what open offers he makes me!

I was on a roll there - wrote another few paragraphs about how duplicitous a bullying handy with his fists ***** this man was/is, but deleted it - am fearful that I could be identified with volunteering too much info. You can bet the first thing he''ll do is look for free advice when he gets my D8.... boy, that felt good though, very cathartic!

Sorry, totally hijacked OP''s thread here.... I wish you best of luck, OP, with your own submission of the D8.
Thanks all Wikis who may be reading this!

cookie2, thank you so much for the suggestions. I have made the changes you suggested.
As for the last bit, I intend to return home in August. Could my last point read as follows:

Due to these incidents the Petitioner moved out of the marital home in February 2012. She returned in August 2012 to commence the divorce proceedings.