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CIRCUIT COURT FOR , MARYLAND COUNTER-COMPLAINT FOR ABSOLUTE (Maryland Judiciary)

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Page 1 of 5
COUNTER-COMPLAINT FOR ABSOLUTE DIVORCE
I, , representing myself, file Counter-Complaint against
the plaintiff/counter-defendant and in support state that:
1.
CC-DR-094 (Rev. 10/2018)
Name
The plaintiff/counter-defendant and I were married on
in in a civil religious ceremony.
2.
Check all that apply:
4. Children (check one):
We have no children together (skip paragraphs 6 through 11) or
My spouse and I are the parents of the following child(ren):
Name
Date of Birth
Name
Date of Birth
Name Date of Birth
Name
Date of Birth
Name
Date of Birth
Name
Date of Birth
Month Day Year
City/County/State where Married
Telephone
Plaintiff Defendant
( )( )
City State Area
Code
Telephone City State Zip Code Area
Code
vs.
Name
Street Address
Zip Code
Name
Street Address
Apt # Apt #
CIRCUIT COURT FOR , MARYLAND
Case No.
City/County
Court Address
Located at
I have lived in Maryland since:
My spouse has lived in Maryland since:
The grounds for divorce occurred in Maryland.
The grounds for divorce occurred outside of Maryland and I or my spouse have been a resident
of Maryland for at least six (6) months prior to the date of the filing of this Counter-Complaint.
3.
Check all that apply: (see paragraph 15)
Month/Year
Month/Year
5. I know of the following related cases concerning the child(ren) or parties (such as domestic
violence/protective order, paternity, divorce, custody, visitation (child access), CINA, delinquency,
termination of parental rights, adoption or other cases):
Court Case No. Kind of Case
Year Filed
_______________________
Results or Status (if you know)
Page 2 of 5
7. I know of the following people, not parties to this case, who have physical custody of, or claim
rights of legal custody, physical custody, or visitation with the child(ren):
Name
Name
Name
Current Address
Current Address
Current Address
8. The child(ren) currently live(s) at:
.
Address
with
Name
9. The child(ren) have lived in Maryland for at least six (6) months ( yes no), and in the
following places, with the persons indicated during the last five (5) years:
Time Period Place
Name(s)/Current Address of Person(s) with whom the Child(ren) Lived
10. It is in the best interest of the child(ren) that I have (check all that apply):
joint primary physical custody of
joint sole legal custody (decision-making) of
.
.
.
Name of Child(ren)
Name of Child(ren)
Name of Child(ren)
CC-DR-094 (Rev. 10/2018)
visitation (child access or parenting time) with
11. Child support (check one):
I am seeking to establish child support and/or health insurance for the child(ren). You must file
either a Child Support (short form) Financial Statement (Form CC-DR-030) or General
(long form) Financial Statement (Form CC-DR-031).
Child support has already been established for the child(ren) separate from this Counter-Complaint:
in a separate court case, Case No. .
in the Office of Child Support, Case No. .
I am not requesting to establish child support and/or health insurance for the child(ren) at this
time because
.
State
Attach the most recent court order for the above-referenced court cases.
I have been a party, witness, or otherwise involved in the following cases about custody, CINA,
guardianship, or visitation (child access) of the child(ren):
6.
Court Case No. Date of Child Custody or Guardianship Determination
12. Alimony: I am am not seeking alimony because
13. Marital property: (You do not have to complete paragraph 13 if you are not asking the court
to make decisions about your property, however, if you choose not to the court may be barred
from making decisions about certain property and debts after a divorce has been granted.)
Page 3 of 5
House(s)
Pension(s)/Retirement Account(s)
Motor Vehicle(s)
Debts (attach list)
Furniture
Bank account(s) and investment(s)
Family Use Personal Property
Other:
.
If you are seeking alimony you must file a General Financial Statement (Form CC-DR-031)
with this Counter-Complaint.
My spouse and/or I have the following property and debts that need to be divided (check all that apply):
You must file a General Financial Statement (Form CC-DR-031) with this Counter-Complaint.
I'm requesting to have use and possession of the home and/or other property for the benefit of the
children.
My spouse and I have already reached agreement about our marital property and debts AND alimony
(you must attach a copy of your signed written agreement to this Counter-Complaint).
My spouse and I have no marital property or debts that need to be decided by the court.
14. I am requesting to be restored to my former name
Print Former Full Name
CC-DR-094 (Rev. 10/2018)
(If you do not request to be restored to your former name at this time, you may do so by a separate
request within (but no longer than) 18 months after the date the clerk enters a decree (judgment) of
absolute divorce.)
Actual Desertion - On or about , my spouse deliberately, without just cause or
15. My grounds for an absolute divorce are: (you may check more than one)
separate and apart from each other in separate residences, without interruption, and without sexual
intercourse, for a period of 12 months or more before the date of filing of this Counter-Complaint.
Adultery - My spouse committed adultery.
reason, abandoned and deserted me, with the intention of ending our marriage. This desertion has
continued without interruption for a period of 12 months or more before the date of filing of this
Counter-Complaint and there is no reasonable expectation that we will reconcile (get back together).
Constructive Desertion - I left my spouse because his/her persistent conduct or cruel and vicious
treatment towards me made the continuation of our marriage impossible, in order to preserve my health,
safety or self-respect. This conduct was the final and deliberate act of my spouse and our separation has
continued without interruption for a period of 12 months or more before the date of filing of this
Counter-Complaint, and there is no reasonable expectation that we will reconcile (get back together).
was sentenced to serve at least three (3) years or an indeterminate sentence in a penal institution and
has served at least 12 months of the sentence before the date of filing of this Counter-Complaint.
Cruelty/Excessively Vicious Conduct Against Me or my Minor Child(ren) - My spouse's cruel
and excessively vicious conduct toward me and/or my minor child(ren) has made the continuation of
the marital relationship impossible, and there is no reasonable expectation that we will reconcile
(get back together).
Month/Day/Year
Month/Day/Year
12-Month Separation - From on or about , my spouse and I have lived, and remained,
Criminal Conviction of a Felony or Misdemeanor - On or about , my spouse
Month/Day/Year
Page 4 of 5
hospital, or other similar institution and has been confined for a period of at least three (3) years
before the date of filing of this Complaint. Two (2) doctors competent in psychiatry will testify
that the insanity is incurable and there is no hope of recovery. My spouse or I have been a
resident of Maryland for at least two (2) years before the filing of this Complaint.
Month/Day/Year
Insanity - On or about , my spouse was confined to a mental institution,
Mutual Consent - My spouse and I have a written settlement agreement resolving all issues related to:
l alimony;
l property; and
l the care, custody, access, and support of minor or dependent child(ren).
Attach a copy of your written and signed agreement to this Counter-Complaint. If the settlement
agreement provides for the payment of child support, also attach a copy of the completed Child
Support Guidelines Worksheet (Form CC-DR-030 OR CC-DR-031) to this Counter-Complaint.
CC-DR-094 (Rev. 10/2018)
Alimony (file Form CC-DR-031).
Any other appropriate relief.
x
FOR THESE REASONS, I request (check all that apply):
An Absolute Divorce.
A change back to my former name:
Joint Primary physical custody of the minor child(ren).
Joint Sole legal custody (decision-making) of the minor child(ren).
Visitation (child access or parenting time) with the minor child(ren).
Full Former Name
Use and possession of the family home for up to three (3) years from the date of the divorce.
x
Use and possession of the family use personal property for up to three (3) years from the date
of the divorce.
Child support (file Form CC-DR-030 OR CC-DR-031).
Health insurance for the child(ren).
Property (check all that apply): (The following requests regarding property require Form CC-DR-033
Joint Statement to be filed no later than 10 days before the final trial date)
My share of the property or its value.
Transfer of family use personal property.
Transfer of real property jointly owned by the parties located at:
Authorize
A monetary award (money) based on marital property.
from to
to purchase from
an interest in real property located at
Name of Party
Name of Party
Dismiss plaintiff's Complaint for Absolute Divorce.
I, , solemnly affirm under the penalties of perjury,
that the contents of the foregoing paper are true to the best of my knowledge, information, and belief.
Name
Date Signature
Address
E-mail Telephone
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this day of , , a copy of this
Date Signature
Plaintiff's or His/Her Attorney's Address Including City/State/Zip
Plaintiff or His/Her Attorney
Month YearDate
Counter-Complaint and any attached documents, were mailed, postage prepaid, OR hand delivered
to:
Page 5 of 5
CC-DR-094 (Rev. 10/2018)
Address
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CIRCUIT COURT FOR , MARYLAND COUNTER-COMPLAINT FOR ABSOLUTE (Maryland Judiciary)

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Completed 13 January 2021

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