IN THE CIRCUIT COURT FOR WASHINGTON COUNTY, MARYLAND KATRINA N. BAKER 24 Chips Court Smithsburg, Maryland 21783 Plainsitt v. Case No. TERRY LEE BAKER c/o Bruce Poole, Esquire 29 W. Franklin Street Hagerstown, MD 21740 Defendant COMPLAINT FOR ABSOLUTE DIVORCE OR IN THE ALTERNATIVE. FOR LIMITED DIVORCE ‘The Plaintiff, KATRINA N. BAKER, by and through her attomeys, Mary M. Drawbaugh, Chelsea Kadish and Haspel, McLeod & Drawbaugh, P.C., respectfully files this Complaint for Absolute Divorce or in the Alternative, for Limited Divorce and, in support thereof, states as follows 1, Plaintiff is a resident of the State of Maryland and has been for more than six months prior to the filing of this Complaint. 2. Defendant is a resident of the State of Maryland and has been for more than six months prior to the filing of this Complaint. 3. The parties were lawfully married on July 21, 1992 in the State of Kentucky. 4. No children were born to the parties during their marriage. 5. There is certain real and personal property which has been accumulated by the parties during their marriage to each other and is “marital property,” the same not having beenacquired by inheritance or gift from a third party, and not excluded by a valid agreement, nor directly traceable to any of these sources. Plaintiff is the owner of assets, including real and personal property which are her non-marital assets and/or which are directly traceable to non-marital assets. 7. During the course of the marriage, Plaintiff expended substantial effort in acquiring marital and non-marital property and made substantial contributions, both monetary and non-monetary, to the well-being of the family. 8. Plaintiff is unemployed and is unable to support hereself without contribution from the Defendant. 9. Defendant is employed and has a substantial income and is able to contribute to the support and maintenance of Plaintiff, both pendente lite and indefinitely (or for a rehabilitative period). 10. The Defendant has at various times and places, committed the act of adultery. The Defendant's adultery has not been forgiven or condoned by the Plaintiff. There is no reasonable hope or expectation of reconciliation between the parties. 11. During the marriage the Defendant engaged in a persistent pattern of financial and ‘emotional abuse towards the Plaintiff as well as controlling and dominating behavior toward the Plaintiff. Defendant’s conduct constituted constructive desertion, Defendant's financial and ‘emotional abuse and his controlling and dominating conduct was such that the Plaintiff could no longer continue to live with the Defendant if she was to preserve her health, safety and self respect. 12, The foregoing conduct of the Defendant, all of which constitutes cruelty of treatment and excessively vicious conduct, is intolerable and has endangered the Plaintiff'shealth, safety and self-respect and has caused her to reasonably fear that her health and well- being are in jeopardy. The Plaintiff is unable to continue the marital relationship or preserve her health, safety and self-respect. 13. On or about July 24, 2018, Plaintiff filed a petition seeking an Protective Order against the Defendant based on her fear that the Defendant would harm her. That petition was ‘granted an temporary order was put in place. 14, _ Prior toa hearing on the Final Protective Order, the Plaintiff agreed to dismiss the Petition in exchange for the parties entering into a Consent Separation Agreement that Plaintiff felt would protect her physically, as well as emotionally and financially. To date, Defendant has refused to sign a written form of that agreement and has brazenly violated the spirit and the terms of that agreement. 15. Said constructive desertion was Defendant's final and deliberate act and has continued without interruption through the filing of this Complaint. There is no reasonable hope or expectation of reconciliation between the parties. 16. Inthe alternative, on or about July 24, 2018, the parties voluntarily separated due to Defendant's actions. Since that date the parties have separate and apart, without interruption and without cohabitation. There is no reasonable hope or expectation of reconciliation between the parties. WHEREFORE, Plaintiff respectfully requests: A. That Plaintiff's Complaint for Absolute Divorce or in the Alternative, for Limited Divorce be granted. B, _Thatall relief requested by Plaintiff in Plaintiff’s Complaint for Absolute Divorce or in the Alternative, for Limited Divorce be granted.