Counter-Complaint For Absolute Divorce Page 3
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412.
My grounds for an absolute divorce are: (Check all that apply)
Twelve (12) Month Separation - From on or about
, my spouse and I have lived
Month/Day/Year
separate and apart from each other in separate residences, without interruptions, without sexual
intercourse, for more than 12 months.
Adultery - My spouse committed adultery.
Actual Desertion - On or about
, my spouse, without just cause or reason,
Month/Day/Year
abandoned and deserted me, with the intention of ending our marriage. This abandonment has
continued without interruption for more than 12 months and there is no reasonable expectation
that we will reconcile.
Constructive Desertion - My spouse's actions have terminated the husband and wife relationship
and made it impossible for me to continue the marriage and preserve my health, safety or self-
respect, and since these actions occurred, I have not had sexual intercourse with my spouse. This
conduct was the final and deliberate act of my spouse and it has continued without interruption
for more than 12 months and there is no reasonable expectation that we will reconcile.
Criminal Conviction of a Felony or Misdemeanor - On or about
, my spouse
Month/Day/Year
was sentenced to serve at least three years or an indeterminate sentence in a penal institution and
has served 12 or more months of the sentence.
Cruelty/Excessively Vicious Conduct Against Me or my minor child - My spouse has
persistently treated me or my minor child cruelly and has engaged in excessively vicious
conduct rendering continuation of the marital relationship impossible if I am to preserve my
health, safety, and self-respect, and there is no reasonable expectation that we will reconcile.
Insanity - On or about
, my spouse was confirmed to a mental institution,
Month/Day/Year
hospital, or other similar institution and has been confined for 3 or more years. Two 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 years before the
filing of this complaint.
Mutual Consent - My spouse and I do not have minor children in common. My spouse and I
have a written settlement agreement resolving all issues related to alimony and property.
FOR THESE REASONS, I request (check all that apply):
x
An Absolute Divorce.
A change back to my former name:
Full Former Name
Sole
Joint physical custody of the minor child(ren) and reasonable child support.
Sole
Joint legal custody of the minor child(ren) and reasonable child support.
Visitation with the minor child(ren).
Use and possession of the family home for up to three years from the date of the divorce.
Use and possession of the family use personal property for up to three years from the date of
the divorce.
Child support (Attach Form DR 30 or DR 31).
Health insurance for the child(ren).
Health insurance for me.
CC-DR 94 (Rev. 10/2015)
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