IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND. MARILYN J. MOSBY clo Law Office of Chantal M. Joseph, LLC 6305 Ivy Lane, Suite 270 Greenbelt, MD 20770 Plaincitt CASE NO. 24D- 2400233] NICHOLAS J. MOSBY 2104 Bolton Street Baltimore, MD 21217 Defendant COMPLAINT FOR LIMITED DIVORCE, CUSTODY AND OTHER RELIEF. COMES NOW, the Plaintiff, MARILYN MOSBY, by and through her attorney, Chantal M. Joseph, Esq. and LAW OFFICE OF CHANTAL M. JOSEPH, LLC hereby files this Complaint for Limited Divorce and Child Custody, and respectfully represents unto this Honorable Court as follows: 1. The Plaintiff, Marilyn J. Mosby, is an edult resident of Maryland, and has been for more than one (1) year preceding the filing of this Complaint 2. The Defendant, Nicholas J. Mosby, is an adult resident of Baltimore City, Maryland and has been a resident of the State of Maryland for more than one (1) year preceding the filing of this Complaint. ‘That the parties were married in a religious ceremony on October 8, 2005, in Boston, MA. 4. ‘Two (2) children were born to them as a result of their marriage; namely, 2G, 0 AS TS 5c SY hereinafter referred to as “Minor Children”. 5. From the date of the minor children’s birth and up to the date of the filingof Voluntary Separation as set forth herein above; and 2. Grant the parties joint physical and joint legal custody of the parties’ minor children; and 3. Order the Defendant to continue to provide health insurance for the Plaintiff and the minor children, both pendente lite and for the maximum time permitted by law; and 4. Order the Defendant to contribute to the extraordinary medical expenses and/or school and transportation expenses of the minor children as required by Fam, Law Art, 12-204(h-i) and defined by Fam, Law Art, 12-201(g), both pendente lite and throughout the children’s minority; 5. Grant such further relief as this Court deems just and proper. 1 DO SOLEMNLY DECLARE AND AFFIRM UNDER THE PENALTIES OF PERJURY THAT THE MATTERS AND FACTS CONTAINED HEREIN ABOVE QRRECT TO THE BEST OF MY INFORMATION,‘CHANTAL M. JOSEPH, ESQ. CPFID: easy Law Office of Chantal M. Joseph, LLC 6305 Ivy Lane, Suite 270 Greenbelt, MD 20770 301-200-9455 (Maia) 301-302-0884 (Fax) xy for PlaintiffIN THE CIRCUIT COURT FORBaltimore City. (Giy/Countyy CIVIL - DOMESTIC CASE INFORMATION REPORT. DIRECTIONS Plaintiff: This Information Report must be completed and attached to the complaint filed with the Clerk of Court unless your case is exempted from the requirement by the Chief Justice of the Supreme Court of Maryland pursuant to Rule 2-111(2). Defendant: You must file an Information Report as required by Rule 2-323(h). THIS INFORMATION REPORT CANNOT BE ACCEPTED AS A PLEADING FORM FILED BY: @ PLAINTIFF O DEFENDANT CASE NUMBER. Cakehay — CASE NAM MARILYN J. MOSBY a NicuoLas }MosEy” en tea PARTY'S NAME,___"MARILYNJ. MOSBY_ PHONE: PARTY'S ADDRESS:______C/O LAW OFFICE OF CHANTAL M, JOSEPH, LEC PARTY'S E-MATL: Ifrepresented by an attorney: PARRY'S ATTORNEY'S NEM: CHANTALM.,JOSEPH,ESQ. — puofif? 201-200-0455 PARTY'S ATTORNEY'S ADDRESS: 6305 IVY LANE, SUITE 270, GREENBELT, MD=20770- | PARTY'S ATTORNEY'S EMAL; | Glam not represented by an attorney ay RELATED CASE PENDING? OI Yes 58 No Ifyes, Case #3) if known: PLEADING TYPE. =o — New Case: Original Existing Case: Post-Judgment_ C Amendment Uf filing i an existing case, skip Case Category! Subcategory section - go to Issues section ‘SPECIAL REQUIREMENTS Ti Spoken Language Toterpreer~ Attach form CC-DC-041 Gi I yourequire an accommodation fora disability under the Americans with Disabilities Act - Attach form CC-DC-049 "ALTERNATIVE DISPUTE RESOLUTION INFORMATION Ts this case appropriate for referral to an ADR process under Md. Rule 17-101? (Check all that apply) mM wD ‘A Mediation Yes C1No C. Settlement Conference © Yes O No B, Arbitration 0 Yes 68 No D. Neutral Evaluation Yes C No Ino, explain why: ___ MUTUAL CONSENT _ If NEW CASE: CASE CATEGORY/SUBCATBGORY (Check one box) Domestic Family C AlimonyiSpousal Support Ageney/IV-D Change of Name Independent Proceedings Annulment Child Support Change oFName Cl Amend Bish Certificate Breach G Patemity/Parentage Adult Change of Sex Child Support Private Outrsa OD Minor Oi Corect Death Certificate 1D Custody C Declare Deceased i Divorce Adoption Dispose Body Emancipation i Adoption - Independent Cl Amend Marriage Certificate Enforce Foreign Onder 1 Adoption - Private Agency Family LegaliMedical 1 PaternityParentage Guardianship Recognition as Legal Child C2 Guacdianship of Adult Person andlor Property Visitation 1 Guactianship of Minar Person andlor Property ‘CC-DCM.-001 (Rev. 12/2022) Page | of 2IF NEW OR EXISTING CASE: ISSUES (Check All that Apply) Adoption Change of Name C) Esrnings Withholding Cl Pension Distribuiion i Alimony/Spousal Support Gadut Emancipation Property Distbution Ci Permanent O Minor Enforcement i Protective Order Rehabilitative Change ofSex CO Exceptions Ci Register Foreign Order Amend Bit Certifeate -CAChild Support Family LegelMedical 0 Restore Former Name GAmend Death Certificate Oh Contempt CO Génshp of Adult. CD Termination of Génshp Amend Marriage Cerificate C1Court Costs/Fees CO Person O Transaction Review Gi Annulment 18 Custody Property Use and Possession Oi Asset Determini Declare Deceased C Gdnshp of Minor Visitation Oi Change of Name Dispose Body Person CAdult Divorce Absolute O Property CO Minor © Divorce -Limited_C) Paterity/Pareniage ESTIMATED LENGTH OF HEARING (Case will be tracked accordingly.) Time estimate for a Merits Hearing —3_Hours —__Days Time estimate for hearing other than Merits Hearing: Hours Days OTHER MATTERS 18 THIS CASE CONTESTED? ® Yes C) No If yes, which issues appear to be contested? @ Ground for divorce Oi Child Custody O Visitation Oi Child Support 1D Alimony Permanent —_C) Rehabilitative Oi Use and possession of family home and property C Marital property issues involving: 1 Valuation of business) Pensions C Bank accounvIRA's C1 Real Property Other: Paternity 1 Adoption/termination of parental rights Tok i ener ‘Request is made for: 2 Initial Order O) Modification C) Contemp? CO Absolute Divorce 68 Limited Divorce For non-castody/visitation issues, do you intend to request: O Court-appointed expert (name field) ® Initial conference withthe court C Mediation by a court-sponsored settlement program _& Other._PETITION TO SHIELD HRG For custody/ visitation issues, do you intend to request: Mediation by a private mediator ClAppointment of counsel fo represent child 1 Evaluation by mental health professionel (not just to waive psychiatric privilege) Other Evaluation CVA conference with the court Is there an allegation of physical or sexual abuse of party prehild? DL Yes ON 1 07/21/2023 \~——ws7170122, a oe a roe ‘aie of Counsar Pay ‘Atomey Number 6305 Ivy Lane, Suite 270 _ “____Chantal M. Joseph, Es “ ‘aires ? Printed Name Greenbelt MD___ 20770 CC-DEM-001 (Rev. 12/2022) Page 2 of 2 Reset