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Complaint for Absolute Divorce — Uncontested

IN THE CIRCUIT COURT FOR [1. County] COUNTY, MARYLAND

Case No: [2. Case Number]

[3. Plaintiff Full Name], Plaintiff, vs. [4. Defendant Full Name], Defendant.

Comes now the Plaintiff, [3. Plaintiff Full Name], and files this Complaint for Absolute Divorce against the Defendant, [4. Defendant Full Name], and in support thereof respectfully states:

Jurisdiction and Residency

Plaintiff has been a resident of the State of Maryland for at least six (6) months immediately preceding the filing of this Complaint, in accordance with Md. Code, Fam. Law § 7-101. This Court has jurisdiction over the parties and the subject matter of this action.

Marriage Information

The parties were lawfully married on [5. Date of Marriage] in [6. City and State of Marriage], and separated on [7. Date of Separation]. There are no minor children born of or adopted during this marriage.

Grounds for Divorce

The parties consent to the dissolution of the marriage, in accordance with Md. Code, Fam. Law § 7-103. The marriage should be dissolved.

Property and Debt Division

The parties have reached a full and complete agreement regarding the division of all marital property, assets, and debts. The terms of this division are as follows: [8. Property and Debt Division Terms]

Spousal Support

The parties have agreed that spousal support, also known as alimony, shall be as follows: [9. Spousal Support Terms]

Request for Relief

WHEREFORE, Plaintiff respectfully requests that this Court:

(a) grant an Absolute Divorce dissolving the marriage of the parties;
(b) approve the parties' agreement regarding property, debts, and spousal support;
(c) restore Plaintiff's former name of [10. Former Name], if requested; and
(d) grant such other and further relief as the Court deems just and proper.

Dated: [11. Date of Signing]

Verification

I, [3. Plaintiff Full Name], declare under penalty of perjury that the foregoing statements are true and correct to the best of my knowledge, information, and belief.

Executed this [12. Execution Date] day of [13. Execution Month, Year], at [14. City and State of Execution].

Complaint for Absolute Divorce — Contested

IN THE CIRCUIT COURT FOR [1. County] COUNTY, MARYLAND

Case No: [2. Case Number]

[3. Plaintiff Full Name], Plaintiff, vs. [4. Defendant Full Name], Defendant.

Comes now the Plaintiff, [3. Plaintiff Full Name], and files this Complaint for Absolute Divorce against the Defendant, [4. Defendant Full Name], and in support thereof respectfully states:

Jurisdiction and Residency

Plaintiff has been a resident of the State of Maryland for at least six (6) months immediately preceding the filing of this Complaint, in accordance with Md. Code, Fam. Law § 7-101. This Court has jurisdiction over the parties and the subject matter of this action.

Marriage Information

The parties were lawfully married on [5. Date of Marriage] in [6. City and State of Marriage], and separated on [7. Date of Separation]. There are no minor children born of or adopted during this marriage.

Grounds for Divorce

The parties have lived separate and apart without cohabitation and without interruption for a continuous period of at least six (6) months, in accordance with Md. Code, Fam. Law § 7-103. The marriage should be dissolved.

Property and Debt Division

The parties are unable to agree on the division of their marital property, assets, and debts. Plaintiff requests that this Court make a monetary award and divide the parties' marital property equitably. The relevant marital assets and liabilities include: [8. Property and Debt Description]

Spousal Support

The parties are unable to agree on spousal support. Plaintiff requests that the Court award spousal support in an amount and for a duration that is equitable, considering the factors set forth in Md. Code, Fam. Law § 11-106. Relevant facts include: [9. Spousal Support Facts]

Request for Relief

WHEREFORE, Plaintiff respectfully requests that this Court:

(a) grant an Absolute Divorce dissolving the marriage of the parties;
(b) make a monetary award and equitably divide the parties' marital property;
(c) award spousal support as the Court deems equitable;
(d) restore Plaintiff's former name of [10. Former Name], if requested; and
(e) grant such other and further relief as the Court deems just and proper.

Dated: [11. Date of Signing]

Verification

I, [3. Plaintiff Full Name], declare under penalty of perjury that the foregoing statements are true and correct to the best of my knowledge, information, and belief.

Executed this [12. Execution Date] day of [13. Execution Month, Year], at [14. City and State of Execution].

Complaint for Absolute Divorce — Uncontested with Children

IN THE CIRCUIT COURT FOR [1. County] COUNTY, MARYLAND

Case No: [2. Case Number]

[3. Plaintiff Full Name], Plaintiff, vs. [4. Defendant Full Name], Defendant.

Comes now the Plaintiff, [3. Plaintiff Full Name], and files this Complaint for Absolute Divorce against the Defendant, [4. Defendant Full Name], and in support thereof respectfully states:

Jurisdiction and Residency

Plaintiff has been a resident of the State of Maryland for at least six (6) months immediately preceding the filing of this Complaint, in accordance with Md. Code, Fam. Law § 7-101. This Court has jurisdiction over the parties and the subject matter of this action.

Marriage Information

The parties were lawfully married on [5. Date of Marriage] in [6. City and State of Marriage], and separated on [7. Date of Separation].

There are [8. Number of Children] minor child(ren) born of or adopted during this marriage: [9. Children Names and Birthdates].

Grounds for Divorce

The parties consent to the dissolution of the marriage, in accordance with Md. Code, Fam. Law § 7-103. The marriage should be dissolved.

Custody and Parenting Plan

The parties have reached a full agreement regarding legal and physical custody of the minor child(ren), in accordance with the best interests of the child(ren) under Md. Code, Fam. Law § 9-101. The agreed parenting plan is as follows: [10. Parenting Plan Terms]

Child Support

The parties have reached an agreement on child support consistent with the Maryland Child Support Guidelines (Md. Code, Fam. Law § 12-201). The agreed monthly child support amount is [11. Child Support Amount], payable by [12. Paying Parent] to [13. Receiving Parent]. Additional terms: [14. Child Support Additional Terms]

Medical and Childcare Expenses

Unreimbursed medical, dental, vision, and childcare expenses for the minor child(ren) shall be shared as follows: [15. Medical and Childcare Terms]

Property and Debt Division

The parties have reached a full and complete agreement regarding the division of all marital property, assets, and debts. The terms of this division are as follows: [16. Property and Debt Division Terms]

Spousal Support

The parties have agreed that spousal support shall be as follows: [17. Spousal Support Terms]

Request for Relief

WHEREFORE, Plaintiff respectfully requests that this Court:

(a) grant an Absolute Divorce dissolving the marriage of the parties;
(b) approve the parties' Parenting Plan regarding custody;
(c) order child support in accordance with the parties' agreement and the Maryland Child Support Guidelines;
(d) approve the parties' property and debt division;
(e) restore Plaintiff's former name of [18. Former Name], if requested; and
(f) grant such other and further relief as the Court deems just and proper.

Dated: [19. Date of Signing]

Verification

I, [3. Plaintiff Full Name], declare under penalty of perjury that the foregoing statements are true and correct to the best of my knowledge, information, and belief.

Executed this [20. Execution Date] day of [21. Execution Month, Year], at [22. City and State of Execution].

Complaint for Absolute Divorce — Contested with Children

IN THE CIRCUIT COURT FOR [1. County] COUNTY, MARYLAND

Case No: [2. Case Number]

[3. Plaintiff Full Name], Plaintiff, vs. [4. Defendant Full Name], Defendant.

Comes now the Plaintiff, [3. Plaintiff Full Name], and files this Complaint for Absolute Divorce against the Defendant, [4. Defendant Full Name], and in support thereof respectfully states:

Jurisdiction and Residency

Plaintiff has been a resident of the State of Maryland for at least six (6) months immediately preceding the filing of this Complaint, in accordance with Md. Code, Fam. Law § 7-101. This Court has jurisdiction over the parties and the subject matter of this action.

Marriage Information

The parties were lawfully married on [5. Date of Marriage] in [6. City and State of Marriage], and separated on [7. Date of Separation].

There are [8. Number of Children] minor child(ren) born of or adopted during this marriage: [9. Children Names and Birthdates].

Grounds for Divorce

The parties have lived separate and apart without cohabitation and without interruption for a continuous period of at least six (6) months, in accordance with Md. Code, Fam. Law § 7-103. The marriage should be dissolved.

Custody and Parenting Time

The parties are unable to agree on legal or physical custody of the minor child(ren). Plaintiff requests that the Court award custody and establish a parenting plan in accordance with the best interests of the child(ren) under Md. Code, Fam. Law § 9-101. Relevant facts include: [10. Custody Dispute Facts]

Child Support

The parties are unable to agree on child support. Plaintiff requests that the Court order child support in accordance with the Maryland Child Support Guidelines (Md. Code, Fam. Law § 12-201). Relevant facts include: [11. Child Support Facts]

Medical, Dental, and Childcare Expenses

Unreimbursed medical, dental, vision, and childcare expenses for the minor child(ren) shall be allocated as follows, or as the Court determines equitable: [12. Medical and Childcare Terms]

Property and Debt Division

The parties are unable to agree on the division of their marital property, assets, and debts. Plaintiff requests that the Court make a monetary award and equitably divide the parties' marital property. The relevant marital assets and liabilities include: [13. Property and Debt Description]

Spousal Support

The parties are unable to agree on spousal support. Plaintiff requests that the Court award spousal support as the Court deems equitable. Relevant facts include: [14. Spousal Support Facts]

Request for Relief

WHEREFORE, Plaintiff respectfully requests that this Court:

(a) grant an Absolute Divorce dissolving the marriage of the parties;
(b) determine legal and physical custody and establish a parenting plan in the best interests of the minor child(ren);
(c) order child support in accordance with the Maryland Child Support Guidelines;
(d) make a monetary award and equitably divide the parties' marital property;
(e) award spousal support as the Court deems equitable;
(f) restore Plaintiff's former name of [15. Former Name], if requested; and
(g) grant such other and further relief as the Court deems just and proper.

Dated: [16. Date of Signing]

Verification

I, [3. Plaintiff Full Name], declare under penalty of perjury that the foregoing statements are true and correct to the best of my knowledge, information, and belief.

Executed this [17. Execution Date] day of [18. Execution Month, Year], at [19. City and State of Execution].