Page 1of 2 T COURT FOR CHARLES COUNTY

Sharon L. Hancock rk of the Circuit Court

200 Charles Street P.O. Box 970

La Plata, MD 20646 (888) -932-2 72, TTY for Deaf: (800) -201-7165

Civil(301)932-3215 Support(3 1)932-3245 Criminal(301)932-3220 Juv(301)932-3230

W R I T 0 F S U M M 0 N S Case Number: 08-C-12-001142

C I V I L

Marlynn Dickson vs

STATE OF MARYLAND-, CHARLES TY, TO WIT:

To: Pierre D Dickson

3027 wildflower Dril e La Plata, MD 20646

1 You are hereby summone~ to file a written response by pleading or motion, within 30 days after ser ice of this summons upon you, in this Court, to the attached Complaint filed by:

Marlynn Dickson 3027 Wildflower Drive

La Plata, MD 20646-

WITNESS the Honorable Chie Maryland.

Date Issued: 05/01/12

To the person summoned:

FAILURE TO FILE A RESPONSE WITHIN THE TIME ALLOWED MAY RESULT IN A JUDGMENT BY DEFAULT TO THE GRANTING OF THE RELIEF SOUGHT AGAINST YOU.

Personal attendance in count on the day named is NOT required.

INTHECIRC

MARL YNN DICKSON 3027 Wildflower Drive La Plata, Maryland 20646

COURTFORCHARLESCOUNTY,MARYLAND

*

* Fl LED Plaintiff *

vs. * Case No.

MAY 0 1 2012

CIRCUIT COURT FOR CHARLES CO., MD.

PIERRE D. DICKSON 3027 Wildflower Drive La Plata, Maryland 20646

Defendant

* * * * * *

*

* * * * * * * COMPLAINT FO ABSOLUTE DIVORCE OR IN THE ALTERNATIVE,

COMPLAINT FORILIMITED DIVORCE, CUSTODY, AND OTHER RELIEF I

TO THE HONORABLE, THE nrGE OF SAID COURT:

* *

Marlynn Dickson, Plainti£1f, by and through her attorneys, Cameron A. Methner, and Andrews,

Bongar, Gormley and Clagett, P.1·· respectfully represents unto Your Honor:

1. That both parties are over 18 and have been residents of the State of Maryland for more than

one ( 1) year prior to the filing of tL s Complaint.

2. That the parties werl e married ~n the 26th day of April, 1986 in the District of Columbia, by a

religious ceremony.

3. That two children were born as a result of said marriage; namely Imani Dickson, born

October 20, 1992, who has emancfpated by virtue of his age, and Khari Dickson, born February 9, 1995,

who is in the care and custody of tihe Plaintiff. The Plaintiff is a fit and proper person to have custody of

said minor child. I

4. That on or about September 13, 2011, the Defendant did, without just cause or reason,

abandon and desert the Plaintiff 1 th the intention of ending the marriage, that said abandonment was the

Defendant's final and deliberate al t and has continued uninterruptedly up to and including the date of the

filing of this Complaint; and that t\here is no reasonable hope or expectation of a reconciliation between the

parties.

5. That, in the altern ive, the Defendant did commit adultery; the Plaintiff has neither forgiven I

Page 1 of 5

nor condoned said conduct; and there is no reasonable hope or expectation of a reconciliation between the

parties.

6. That, in the alterna ive, on September 13, 2011, the Plaintiff and Defendant did separate and

begin to live apart from one another in separate abodes with the express purpose and intent of ending their

marriage, and that said voluntary jgreement was the deliberate and final act of both parties.

7. That since the aforlsaid date, the parties have lived separate and apart, uninterruptedly,

without any cohabitation, in separlte abodes prior to the filing of this Complaint, and that there is no

reasonable hope or expectation of Ia reconciliation between the parties.

8. That the Plaintiff Jd the minor child of the parties are residing in a home which was

acquired by the parties during thel marriage and is titled in the Defendant's name solely, was used as the

principal residence of the parties kd their children immediately preceding their separation, is their family

home, and that the child has a neef to reside therein.

9. That the family hofe is currently going through a foreclosure action and the Plaintiff and

minor child are being forced to m<i>ve to the Plaintiffs mother's home as the Defendant has not paid the

mortgage on the family home. Thtl family ho~e will be or has been auctioned off at the end of March 2012.

10. That the parties ha e substantial tangible personal property which was acquired during their

marriage and used primarily for f "ly purposes, including household furnishings and appliances, and

automobiles which the Defendant left at the family home when he left.

11. That the Plaintiff Just remove the tangible personal property from the family home when

she vacates the family home due t the impending foreclosure action.

12. That the following property has been accumulated by the parties during their marriage to

each other and is "marital prope ' the same not having been acquired by an inheritance or gift from a third

party, and is not excluded by a v id agreement nor is it directly traceable to any of these sources.

A. The family /home at 3027 Wildflower Drive, La Plata, Maryland 20646, which is

currently the subject of a forecloske action, which IS titled m the sole name of the Defendant.

B. A Chrysler Pacifica in the Defendant's possession and titled in his name, a

Mitsubishi Endeavor in the Defe t' s possession and titled in the Plaintiffs name, a 2007 Mercury Milan

Page 2 of 5

in the Plaintiff's possession and titled in the Defendant's name, and a 2002 Lincoln Continental that was

purchased since the date of separ+on in the possession of the Defendant and titled in his name.

C. Multiple professional grade bicycles purchased by the Defendant during the marriage

in his possebsion and all with a value above approximately $1,000.00.

D. Various i4s of household furniture acquired by the parties during their marriage

would be marital property within the meaning of the Annotated Code of Maryland FL 8-201, located within

the family home that need to be reboved f~r the pending foreclosure action.

. E. That the ,endant is receiving retirement from his former employer, Prince

George's County Police Department. ,

13. That there exists ern other "marital property" owned by either or both of the parties.

14. That the Plaintiff has made substantial contributions, both monetary and non monetary, to

the well-being of the family.

15. Although Plaintiff is presently employed at a salary of approximately thirty-eight thousand

($38,000.00) dollars gross per ye1 and is currently maintaining a part time job tutoring at $34.00 per hour

for two (2) hours every day, endinf. in June 2012, she makes substantially less than the Defendant.

16. That the Defendant· s a monetary contributor and his income is approximately $57.4 7 per

hour at his full time employment, aking over one hundred and nineteen thousand ($119 ,000.00) dollars

per year. He is also receiving app ~ximatelr $2,784.95, a month for his pension from the Prince George's

Police Department who was his prvious eljllployer.

17. That the Defendant is able to aid Plaintiff in the support of the child and spousal support.

18. That the Defendanl has not made any substantial contributions towards the support of the

minor child to the Plaintiff. That the Plaintiff is currently paying the private school tuition of the minor !

child on her own. 1

I

19. That the Defendan · is proviqing health insurance for the entire family, including Plaintiff, at I

no cost to him through his previo s employer.

WHEREFORE, th Plaintiff prays as follows:

Page 3 of 5

A. That Plaintiff be alarded an absolute divorce or in the alternative that the Plaintiff be

awarded a limited divorce from th Defendant.

B. That Plaintiff be af arded sole legal and physical custody of the minor child of the parties.

C. That the Defendan~ be ordered to pay to the Plaintiff pendente lite and permanent alimony,

Court costs.

D. be ordered to pay to the Plaintiff a reasonable sum for temporary and

permanent child support.

E. be ordered to pay to the Plaintiff suit money and court costs, including a

reasonable contribution toward Plaintiff's attorney's fees in connection with legal services for the benefit of

said child and attorney's fees for t e Plaintiff.

F. That the furniture r d furnishings in said the La Plata residence and the 2007 Mercury Milan

car be declared family use person property.

G. That the Plaintiff b granted a use and possession order of said family use personal property

pendente lite.

H. That the Defendant be enjoined from disposing of or otherwise encumbering any of the

property herein alleged to be mari al property or property acquired during separation.

I. That the court dete mine the ownership of all personal property and real property regardless

of how titled.

J. That the Court ord r a sale in lieu of partition of all real and personal property determined to

be jointly owned and not determined to be family home or family use personal property and not included in

a use and possession order, and dir de the proceeds equally.

K. That the Court determine the value of all marital property of the parties.

L.

equities in the marital property.

a monetary award to the Plaintiff after adjusting the parties' rights and

I

M. That such monet award in favor of the Plaintiff be reduced to a judgement together with

interest in Plaintiff's favor. I

N. That the Court ent ! an Order as justice may require both pendente lite and permanent

Page 4 of 5

r pursuant to Code FL-8-208.

0. That the Defendant be ordered to pay Plaintiff's reasonable counsel fees, and the costs of

these proceedings.

reqWe.~DOS::~::re:=::::::~::::E:::·::ay THE MATTERS AND FACTS c9NTAINED IN TillS COMPLAINT FOR ABSOLUTE DIVORCE OR IN THE ALTERNATIVE, COMPLAINT FOR LIMITED DIVORCE, CUSTODY, AND OTHER RELIEF ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. '!t?r @ffik&tu Marlynn15kDI1

v .I

ANDRE~S, BONGAR GO ~.A

{:J.~1U'{ t!' e -Cameron A. Methner 11705 Berry Rd., Suite 202 Waldorf, Maryland 20603 301-645-4100/301-843-1950 Attorney for Plaintiff

Page 5 of 5

CIRCUJ IT COURT FOR CHARLES COUNTY Sharon L. Hancock

C erk of the Circuit Court 200 Charles Street

P.O. Box 970 La Plata, MD 20646

(888)-932- 072, TTY for Deaf: (800)-201-7165 Civil(301)932-3215 Support(301)932-3245 Criminal(301)932-3220 Juv(301)932-3230

Case Number: 08-C-12-001142 DA

Cameron A Methner Esq Andrews, Bongar, StarMey & Clagett PA 11705 Berry Road Suite 202 Waldorf, MD 20603

bg FOLD HERE

DA~~~lb~Jo~7~~son vs Pierrj D Dickson

P L E A S E S E E M E S S A G E BE L 0 W

Costs not enclosed. All costs must be paid in advance. Amount Due: $ . Appearance Fee/Dismissal

Signature missing (Jleading/check) . No case number provided.

No certification of mailing /service (MR 1-323)

MR 2-506(a) requires signatures of all parties/attorneys.

Submit to newspaper j for publishing.

Since service copie were not provided, you must attach same to the summons before ,ervice.

Effective July 1, 1991, we no longer file Discovery Material pursuant to MR 2-40~. Please file required Notice.

Once we receive the !Request to Issue the Writ of Possession, Instructions to She~iff and appropriate fees, we will issue the Writ.

Effective June 1, 2do4 there is a $25.00 civil surcharge due.

Page 2 of 2 * * * * s

CIRCUIT

Case Number: 08-C-12-001142

H r R I F F' S R E T U R N * * * *

CO[ RT FOR CHARLES COUNTY, MARYLAND

Marlynn Dickson vs Pierre D D~ckson

I certify that I delivered a ~opy of Writ of Summons and:

To : Pierre D Dickson

Personally at:

On this _______________ Day of

By ID No Sheriff

Instructions to Returned To l lttorney:

1. This summons is effective for service only if served within 60 days after the date it is issued.

2. Proof of service shall seb out the name of the person served, date and the particular place and 11anner of service. If service is not made, Please state the reasons .

3. Return of served or unserved process shall be made promptly.

Circuit Court for Charles Q:ounty -------r ~ --~------------~C~icy-o-rC~o-~-cy-------------------------------------

CI'\['IL- DOMESTIC CASE INFORMATION REPORT

DIRECTIONS: n}c Plaintiff: This in

1

ormation Report must be completed and attached to the complaint filed with the Clerk of Court unless your case is 1xemptedjrom the requirement by the Chief Judge of the Court of Appeals pursuant to Rule 2-111. A copy must be t cludedfor each defendant to be served.

Defendant: YouN ustjile an Information Report as required by Rule 2-323(h). THIS INFORMATIO

1 REPORT CANNOT BE ACCEPTED AS AN ANSWER OR RESPONSE

FORM FILED BY: !&] PLI INTIFF D DEFENDANT CASE NUMBER {!_/;:2-// f/..:2---' Clerk to insert

CASE NAME: Marlynn Dicl{son vs. Pierre D. Dickson

I Plaintiff Defendant

PARTY'S NAME:Marlynn Ij)ickson PHONE: ( 240 ) 882 - 1924

ADDRESS: 3027 Wildflowe~ Drive, La Plata, MD 20646

Day Time Phone

PARTY'S ATTORNEY'S Nk: Cameron A. Methner PHONE: ( 301 ) 645 - 4100

ATTORNEY'S ADDRESS: 11705 Berry Rd, Ste. 202, Waldorf, MD 20603

D I am not represent~d 5 an attorney RELATED CASE PENDIN<JJ? Yes I&J No

I If yes, Court and case #(s) if known:

Special Requirements? D ~nterpreter/communication impairment Which language (Attach Form 1-332 if AccoT modation or Interpreter Needed) Which dialect

D ADA accommodation:

ALTERNATIVE DISPUTE RESOLUTION INFORMATION Is this oase appro prime fo< ~erral to on ADR prooess unde< Md. Ru 1o l 7- l 0 I ? (Check all thm tty)

A. Mediation Yes D No C. Settlement Conference I&J Yes No B. Arbitration Yes D No D. Neutral Evaluation D Yes D No

IS THlS CASE CONTESTEb? 0 Yes 0 No If yes, which issues appear to be contested?

0 Ground fo< divore1 !KI Child Custody 1&1 Visitation I&] Child Support 1&1 Alimony D Permanent I&J Rehabilitative !&] Use and possessiory offamily home and property IKJ MaritatJroperty issues involving:

D Real Property Valuatiod of business !KI Pensions I&J Bank accounts/IRA's D Other: I

DPatemity J

D Adoption/termination of parental rights D Other:

Request is made for: D Ini~ial order D Modification D Contempt IKI Absolute Divorce 1&1 Limited Divorce

For non-custody/visitation iskues, do you intend to request: D Court-appointed expertl (name field) D Mediation by a Court-sponsored settlement program D Initial conference with ~he court D Other:

For custody/visitation issues~ do you intend to request: D Appointment of counsel to represent child (not just to D Mediation by a privat~ mediator

DEvaluation by mental ~ealth professional waive psychiatric privilege) D Other Evaluation 0 A conference with the Court

I Is there an allegation ofphy~ical or sexual abuse of party or child? DYes IKI No

CC/DCM 001 (Rev. 3/2009) Page 1 of2

CASE NAME Marlynn DicJson vs. Pierre D. Dickson Plaintiff Defendant

CASE NUMBER: ____ -! (Clerk to Insert)

TIME ESTIMATE FOR A IMERITS HEARING: 2 hours 0 days

TIME ESTIMATES FOR HEARING OTHER THAN A MERITS HEARING:_1 ___ hours _0 ___ day

I COMPLEX SCIENCE MEDICAL CASE MANAGEMENT PROGRAM (ASTAR)

FOR PURPOSES OF POSSIBLE SPECIAL ASSIGNMENT TO AN ASTAR RESOURCE JUDGE under Md. Rule I6-202. Please cheJk the applicable box below and attach a duplicate copy of your complaint.

~ E<poditod- Td>l r ithin 7 month• of filing D Stmd"d- Tri•l within" month• of filing

Prin~Name

11705 Berry Rd, Ste. 202 I Waldorf, MD 20603

Street iAddress

City/State/Zip

CC/DCM 001 (Rev. 3/2009) Page 2 of2

IN THE CIRCUI COURT FOR CHARLES COUNTY, MARYLAND

MARL YNN DICKSON

Plaintiff

vs.

PIERRE D. DICKSON

Defendant

* * * * *

*

* *

* *

*

* * * *

CaseNo.:C/2- //V2-

F' LED MAY 0 1 2012

CIRCUIT COURT FE>R CHARLES GQ., MD.* * *

ENTRY OF APPEARANCE

TO THE HONORABLE CLERK OF COURT:

Please enter my appearance

Cameron A. Methner, Esq. Andrews, Bongar, Gormley & Clagett, P.A. 11705 Berry Rd., Suite 202 Waldorf, MD 20603 301-645-4100

*

I HEREBY CERTIFY that on this day of April, 2012, a copy of the foregoing Entry of Appearance was mailed, postage pri paid to: Pierre D. Dickson, 1/k/a, 3027 Wildflower Drive, La Plata, MD 20646; Pierre D. Dickson, 8800 eenbelt Road, Mailstop # 700, Bldg #25 S128, NASA TransPo FHA, Greenbelt, MD 20771

CIRCUIT COURT FOR CHARLES COUNTY COURTHOUSE P.O.BOX970

LA PLATA, MARYLAND 20646

<CIVIL STATEMENT OF COSTS

DATE: ~()/-/~ CASENUMBER C/c;;2~ / lf/'c2_ I INVOICE NUMBER

~_L-e;{;so.rJ ~--

I vs.

rJ)I;_k So~ V 1101 Clerk's Fee 7 1500 Appearance Fee ~ 1265 Civil Surcharge

1168 Req. for Foreclosr e Mediation __ 1108 Foreign Decree

1111 Foreign Judgmenf 1113 Recorded Judgm~nt . I 1116 Judgment Rene"'fal 1117 Judgment Satis:D1ction 1119 Civil Lien 1122 Federal Lien · 1126 Miscellaneous 1128 Petition to ModifY 1130 Contempt!Modifiication 1131 Certificates!Rghtt of Redemption 1510 Special Admissio,1n 113 7 Writ/Civil Case 1139 Writ of Garnishrrient 1151 Court of Special ~ppeals 1161 Clerk/Appeal Fee

__ 1206 Overage 1157 Clerk/ND --

__ 1203 Copy- Non Case 1169 HCF Mediation Fund --

--1208 Recording Fee 1209 Ret. Check Fee --1105 Dismissal Fee --

--11 07 Fiduciary Acct

-- 2000 Interest Bearing Account

101 Circuit Court ---- 102 Bail Bond Acct.

103 State Roads Acct --

TOTAL ; ..... ~.· . _,., . ( ',_·! ~

Cash

CIRCU]T COURT FOR CHARLES COUNTY ClJrk of the Circuit Court,

Sharon L. Hancock 200 Charles Street

P.O. Box 970 La Plata, MD 20646

Phone: ( 888)- 932-2072

Received From: Cameron A Me ,hner Address:

I 11705 Berry oad Suite 202 Waldorf, MD 20603

08-C-12-001142 DA Marlynn Dickson vs Pierre D Dickson

Clerk Fee- Civil Filing F 1 e CK 7707 MARYLAND LEGAL SERVICE CK 7707 Clerk Fee - Appearance Fee CK 7707 Sub Total

----MOP-------------AMOUNT----

Receipt #201200002916 Cashier: LE CCCHREG1 05/01/12 1:41pm

CK

TOTA TENDERED CASH RECEIVED CASH DUE

CHANGE

$145.00

$145.00 $0.00 $0.00

$0.00

$80.00 $55.00 $10.00

$145.00

CIRCUIT COURT FOR.CHARLES COUNTY Sharon L. Hancock

Clerk of the Circuit Court 200 Charles Street

P.O. Box 970 La Plata, MD 20646-

(888) -932-2072, TTY for Deaf: (800) -201-7165 Civil(301)932-3215 Support(301)932-3245 Criminal(301)932-3220 Juv(301)932-3230

05/01/12 Case Number: 08-C-12-001142 DA Date Filed: 05/01/2012 Status: Open/Active Judge Assigned: To Be Assignedr Location : CTS Start : 05/01/12 Target : 05/01/13

Marlynn Dickson vs Pierre D Dickson

C A S E H I S T 0 R Y

INVOLVED PARTIES

Type Num Name(Last,First,Mid,Title)

PLT 001 Dickson, Marlynn

Mail: 3027 Wildflower Drive

La Plata, MD 20646

Attorney: 0816052 Methner, Cameron A Andrews, Bongar, Starkey & Clagett PA 11705 Berry Road Suite 202 Waldorf, MD 20603 (301)645-4100

DEF 001 Dickson, Pierre D

Addr Str/End

05/01/12

Appear: 05/01/2012

Party ID: 0363116

Mail: 3027 Wildflower Drive 05/01/12

La Plata, MD 20646

Pty. Disp. Addr Add/Upd

05/01/12 BG

05/01/12 BG

08-C-12-001142 Date: 05/01/12 Time: 13:50

JUDGE HISTORY

JUDGE ASSIGNED Type Assign Date Removal RSN

TBA To Be Assigned, J 05/01/12

DOCUMENT TRACKING

Num/Seq Description Filed Party Jdg Ruling

00001000 Attorney Appearance Filed for Plaintiff 05/01/12 PLT001 TBA

00002000 Complaint for Absolute Divorce, or in 05/01/12 PLT001 TBA the Alternative, Complaint for Limited Divorce, Custody, and Other Relief with Case Information Report.

00003000 Writ of Summons - Civil Issued 05/01/12 DEF001 TBA

00004000 **Custody or Visitation Issues** 05/01/12 PLT001 TBA

SERVICE

Page: 2

User ID Closed Entered

BG 05/01/12 05/01/12

BG

05/01/12

BG 05/01/12 05/01/12

BG 05/01/12

-F&~-Name-----------------------------------Lissss~u~e~dL__JR~e~sponse Served Returned Agency

Writ of Summons 05/01/12 Returned To Attorne DEF001 Dickson, Pierre

TICKLE

Code Tickle Name Status Expires #Days AutoExpire GoAhead From Type Num Seq

-------------------- ------ -------- ---------- -------CTOS Create Tickle On Ser OPEN 05/01/12 0 no no 0 000

NCDT Notice Of Contemplat OPEN 08/29/12 120 no no CTOS T 0 000

08-C-12-001142 Date: 05/01/12 Time: 13:50 Page: 3

ACCOUNTING SUMMARY

NON-INVOICED OBLIGATIONS AND PAYMENTS

Date Rcpt!Ini t i a 1 s Acct Desc Oblig Payment Total MOP Balance ----- ------- ---- ---- ------------ --------- --------- --------- --- ----------

05/01/12 201200002916/LE 1500 CF-App Fee .00 10.00 -10.00 CK -10.00 05/01/12 201200002916/LE 1265 MLSC .00 55.00 -55.00 CK -65.00 05/01/12 201200002916/LE 1101 CF-Civil Fil .00 80.00 -80.00 CK -145 .00 05/01112 1101 CF-Civil Fil 80.00 .00 80.00 -65.00 05/01/12 1265 MLSC 55.00 .00 55.00 -10.00 05/01112 1500 CF-App Fee 10.00 .00 10.00 .00