Xiv. [§ 10.35] Interference with Parent-Child Relations

• Jurisdiction: Maryland

XIV. [§ 10.35] INTERFERENCE WITH PARENT-CHILD RELATIONS

Jane Smith and John Smith are divorced parents of two minor children, Mark and Madeline Smith. Under the terms of their divorce, the parties have joint legal custody of the children, Jane has primary physical custody, and John has regular visitation with the children. John asked Jane's permission to take the children to visit relatives in Florida for the week of spring break. Jane consented, provided the children returned to Maryland the Monday following spring break; John agreed to the arrangement. Instead of returning the children to Maryland, John put the children on a flight from Miami to Venezuela, where he and the children now reside with John Smith's relatives. Jane Smith has not seen her children since.

VERIFIED COMPLAINT FOR INTERFERENCE WITH PARENT-CHILD RELATIONS

Jane Smith (hereafter "Plaintiff"), by her attorneys, Alexander P. Nilsen and Nilsen & Nilsen, P.A., sues John Smith (hereafter "Defendant"), for tortious interference with parent-child relations, and states as follows:
1. Plaintiff is a resident of Baltimore County, Maryland.
2. Defendant is Plaintiff's former husband, now residing in Venezuela.
3. The Parties were divorced on July 5, 2020.
4. Pursuant to the Judgment of Divorce entered in this Court, Plaintiff was granted primary physical custody of the Parties' minor children, Mark and Madeline Smith. Defendant was granted visitation rights with the minor children.
5. Defendant sought Plaintiff's consent to take the minor children to Florida on or about March 24, 2022. Plaintiff consented provided Defendant agreed to return the children to Maryland before March 31, 2022. Defendant agreed.
6. Instead of returning the children as promised, Defendant abducted the children and

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