(TMZ) TMZ has learned ... Katie Holmes says her marriage to Tom Cruise was "irretrievably" broken at least 6 months prior to her filing for divorce ... this according to divorce documents filed in New York.Sources connected to Tom tell TMZ ... Katie's contention is baffling, because he had "no idea" she was about to file for divorce. As the sources told us last week, Tom was "blindsided" by the filing.
We've also learned ... Katie claims in her divorce documents that both she and Tom have been residents of New York for "at least 2 years." Katie, who filed in NYC, must establish legal residency in NY in order for the court to have jurisdiction -- something she wants because New York courts are more likely to grant sole custody of Suri -- something she desperately wants.
No doubt ... Tom -- who shared a home with Katie in Beverly Hills for years -- will fight the residency claim tooth and nail. more on this story