Divorce in NY is Painful and Costly and Lawyers Love It - Gothamist: New York City News, Food, Arts & Events:
"Forty-nine states in the Union permit residents to pursue no-fault divorces, but not the Empire State. New York doesn't accept 'irreconcilable differences' as grounds for ending marriage, and so one spouse must prove in court that the other is guilty of adultery, cruel and inhuman treatment, or withholding sex for a year"
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