IN THE CIRCUIT COURT FOR PRINCE GEORGE’S COUNTY, MARYLAND

DOMESTIC RELATIONS/CIVIL DIVISION

Patricia Walker *
ADDRESS *
ADDRESS *
*
Plaintiff, *
*
v. * CASE NO. __________

*
Malcolm Walker *
ADDRESS *
ADDRESS *
*
Defendant. *

PLAINTIFF’S COMPLAINT FOR ABSOLUTE DIVORCE

NOW COMES, PLAINITFF, Patricia Walker, by and through her Counsel of Record,

Angela D. Minor and MINOR & WILLCOX, LLC, files this Complaint for Absolute Divorce and

respectfully represents unto this Honorable Court the following:

1. That the Plaintiff is an adult citizen of the United States and has been resident of

Prince George’s County, Maryland for more than one (1) year preceding the filing of this

Complaint for an Absolute Divorce.

2. That the Parties were married on May 5, 2001 in a civil ceremony in Baltimore

City.

3. That two (2) children were born of the marriage:

4. That the Plaintiff believes that she being the fit and proper custodial parent due to

Defendant’s history of adultery and mental abuse and that custody of the Parties’ minor children

should continue to reside with her.

Parties have been living in separate residences since January 12, 2017.

6. That the Plaintiff has not participated as a party, witness, or in any other capacity

in any other litigation concerning the custody of either child in this or any other State; the Plaintiff

has no other information of any custody proceeding concerning either child pending in a Court of

this or any other State; the Plaintiff knows of no other person not a party to the proceedings who

has physical custody of either child or claims to have custody or visitation rights with respect to

either child.

7. That the Plaintiff has always behaved in a kind loving manner towards the

Defendant, however, Defendant has treated the Plaintiff in a humiliating manner, by engaging in

adulterous act(s) which endangered the personal, physical and mental health of Plaintiff, and

seriously impaired the marital relationship.

8. That the Defendant committed acts of cruelty and abuse during the marriage and

on/ or about DATE, the Plaintiff was granted a Final Protective Order from the Defendant in the

District Court for Prince George’s County.

9. That the Plaintiff was granted use and possession of the marital home and custody

of their son, who is still a minor, Joshua Walker, August 8, 2006. REDACTED.

10. At all times since the Parties separation, the Parties’ sons have resided with the

Plaintiff in the marital home.

CUSTODY AND VISITATION

11. Plaintiff hereby incorporates the allegations contained in Paragraphs 1 through 10

of this Complaint.
 12. That the Parties’ have reached a Consent Agreement regarding custody of the minor

child and child support during the Pendente Lite hearing held on January 12, 2018, and the Plaintiff

desires that the Consent Order remains in full, force and effect.

13. That minor children have adjusted to the family home, school and current

environment with Plaintiff, such that it is in the “best interest” of the parties’ youngest son who is

still a minor to reside with Plaintiff.

14. That the Plaintiff has provided a continuous nurturing and stable environment for

the Parties’ minor children.

15. That the Plaintiff is currently employed at Panera bread earning approximately,

$41,000.00 a year.

16. That the Defendant has the means to provide child support to the Plaintiff for their

minor child as he earns approximately $130,000.00. Defendant earns sufficient monies to

contribute to the needs of their minor children.

PROPERTY

17. Plaintiff hereby incorporates the allegations contained in Paragraph 11 through 16

of this Complaint.

18. That the Parties’ purchased a martial home during the marriage located at

ADDRESS.

19. That the Parties’ principal residence has already been divided among them and is

now in foreclosure.

ALIMONY
 20. Plaintiff hereby incorporates the allegations contained in Paragraphs 17 through

19 of this Complaint.

21. That the Plaintiff seeks to maintain the standard of living that the parties

established during their marriage.

22. That the duration of the marriage consists of fourteen (14) years.

23. That the Plaintiff’s contributions to the marriage were significant both monetary

and non-monetary.

24. That the circumstances that contributed to the estrangement of the marriage are

the Defendant’s acts of adultery and cruelty.

25. That the Defendant has the ability and financial means to pay the alimony sought

to meet the Plaintiff’s needs, pendente lite, rehabilitative and/or permanent and requests.

FORMER NAME CLAUSE

26. Plaintiff hereby incorporates the allegations contained in Paragraphs 20 through 25

of this Complaint.

27. That the Plaintiff, Patricia Walker, seeks restoration of her former name, Dotson,

and she does not seek said restoration for any fraudulent purpose or to evade criminal prosecution

nor tax evasion.

ATTORNEY’S FEES AND COURT COSTS

28. Plaintiff hereby incorporates the allegations contained in Paragraphs 26 through 27

of this Complaint.
 29. That the Plaintiff has incurred a reasonable sum of Attorney’s fees.

30.

31. That this Court award the Plaintiff Court costs and suit money both pendent lite and

permanently.

32. That this Court pass an Order reducing to judgment any costs and suit money

awarded to the Plaintiff.

33. That the Defendant has financial means to contribute to the Plaintiff’s attorney’s

fees and court costs.

WHEREFORE, the Plaintiff respectfully requests that this Honorable Court grant her the

following relief:

A. That an Order be entered granting Plaintiff an Absolute Divorce based on the

grounds of Twelve (12) Month Separation;

B. That an Order be entered granting Plaintiff her requests that the Parties’ Consent

Order regarding Custody and Child Support remain in full, force and effect.

C. That an Order be entered granting Plaintiff a reasonable sum of monies for alimony,

both pendente lite, rehabilitative and/or permanent alimony and said alimony be paid to the

Plaintiff, Rhona Harper, by wage lien;

D. That the Court pass a use and possession Order permitting the Plaintiff and the

minor children of the parties to have the continued use and possession of the martial home to the

date of this Absolute Divorce;

E. That this Court grant an Order to the Plaintiff use and possession, both pendente

lite and for the maximum time permitted under the Family Law Article of the Annotated Code of

Maryland, of the principal family residence, and order the Defendant to contribute to the
maintenance of the family home, including, but not limited to, principal, interest, taxes, insurance,

utilities, maintenance and repairs.

F. That the Court determines the value of the marital property of the parties and grant

the Plaintiff her marital share of the Defendant’s retirement accounts and the value of the marital

home;

G. That the Defendant be ordered to pay the Plaintiff’s reasonable counsel fees and the

cost of these proceeding or at least the of $700.00 awarded to her by this court on April 4, 2018;

H. That any such order for counsel fees be reduced to judgment in favor of the

Plaintiff’s counsel and on behalf of the Plaintiff;

I. That the Plaintiff be awarded such other and further relief as the nature of her cause

may require.
 I, HEREBY CERTIFY THAT UNDER THE PENALTIES OF PERJURY THAT THE
CONTENTS OF THE FOREGOING PLAINTIFF’S COMPLAINT FOR ABSOLUTE
DIVORCE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE,
INFORMATION AND BELIEF.

_________________________
NAME

Respectfully Submitted,

MINOR & WILLCOX, LLC

By: _________________________

Angela D. Minor, Esq.

Attorney and Counselor at Law

Post Office Box

Largo, Maryland 20792-

(202) 756-7300 Direct

(202) 390-0200 Cellular

Counsel for Plaintiff, Patricia Walker