Kallia K. Butterworth

She completed a judicial clerkship with the Honorable Stephen M. Waldron of the Circuit Court for Harford County before joining Karas & Bradford in 1993.  She is a member of the Maryland State Bar Association and the Harford County Bar Association.   She has focused her practice in the area of family law for the past ten years.

Kallia is a lifelong resident of Harford County, Maryland and currently resides with her family in Bel Air.

Mr. Bradford has concentrated his practice in the areas of Real Estate, Business law and Estate Planning for over twenty-five years.

In addition to the practice of law, he is a member of the Harford County Bar Association, where he serves on the Courthouse committee.  He also serves as a Director of the Wilson Center.

Mr. Bradford lives in Darlington with his wife, Ellen and their three daughters, Kathryn, Rachael and Allison.

Following law school, Mr. Karas worked with the law firm of Tanner, Livezey and Cobb, which later became known as Tanner, Livezey and Karas and thereafter Tanner, Livezey, Karas & Bradford.  In 1989 Mr. Karas left the firm with his current partner, Charles E. Bradford, Jr. and formed the law offices of Karas & Bradford with an initial office in Aberdeen, Maryland, expanding the practice to his second office in Bel Air, Maryland.  Mr. Karas has had a concentration in family law since 1985.

John and his wife, Belinda reside in Have de Grace and have three children.  John is Chairman of the Board of Harford Bank, Vice-Chair of the Board of Trustees for the John Carroll School; a trustee for the Darlington United Methodist Church and a director of the Cal Ripken Senior Foundation.  In addition, John is a member of the Aberdeen Rotary Club, the Harford County Bar Association and the Maryland State Bar Association.

Following law school, Mr. Donlick worked briefly for the Lockheed Martin Company before becoming an associate with Karas & Bradford in 2004.  Concentrating in Family Law, Mr. Donlick has found years of enjoyment working clients though a difficult time.

Dan and his wife Jeanne reside in Bel Air with their three children.   Dan is a member of the Aberdeen Rotary Club, the Harford County Bar, The Harford County Bar Association, and is on the board of directors of the Harford County Bar foundation.

Association of Family and Conciliation Courts Professionals dedicated to improving the lives of children and families through the resolution of family conflict. www.afccnet.org

This could be in the form of a Complaint for Divorce that seeks a custody determination if you are both married, a Complaint for Custody, or a Complaint for Visitation.  The other party will have thirty days to file an answer after service upon them, if the other parent resides in the State of Maryland, and up to sixty days to respond if he or she resides outside of the State of Maryland.

Following the other parties’ answer to your complaint, he or she then may request an initial custody conference of the court.  The process to get an initial custody conference may take one to two months.

An initial custody conference is an opportunity for parties and counsel to inform a Master of the Court what the current custodial situation is, and what schedule he or she is seeking pending ultimate resolution by the Court, perhaps a trial.

Please note, that it is the usual practice that an initial custody conference provide 15 minutes or less to each party to present his or her case.  However, often times parties are afforded the ability to bring an “essential” witness that may provide the Master of the Court with significant and relevant information relating to a custody determination.

The Master will, following the hearing, make what is called a Pendente Lite (pending litigation) recommendation as to custody.  Please note, it is the Court’s interest at this point in stabilizing the situation for the children’s benefit – not to make a final determination.

If either party disagrees with the Master’s Recommendation, he or she may file what is called Exceptions (or an appeal) to the Master’s Recommendation.  Within the Exceptions, that party would need to state with particularity, the areas of the Master’s findings in which he erred.  An Exceptions hearing, largely a legal argument would then be scheduled – again within one to two months.

Should it be that neither party files Exceptions the Order will be signed at the expiration of a ten day waiting period by a Judge of the Circuit Court for Harford County.

It is also highly likely that at the time of the initial custody conference, both parties will be referred to the Office of Family Court Services for a Custody Evaluation.  A Custody Evaluation is a process whereby a social worker is assigned to meet with both parties and the child or children involved in an attempt to reach an agreement as to custody.  That social worker will also speak to collateral contacts, perhaps teachers, counselors, coaches, and the like during their evaluation.

While the purpose of the evaluation is for parties to reach an agreement as to a custody and visitation schedule, should the parties not reach an agreement, the social worker then comes back to court at a hearing to review their findings and a recommendation as to what the custodial schedule should be.  The hearing to receive the Evaluator’s Report is scheduled at the time of the initial custody conference and typically is one and a half to two and a half months later.

Please note, it is unlikely, unless the social worker notes an emergent situation that the Master at the time of the Evaluator’s Report will make significant changes in the custodial schedule.  Should both parties be unable to reach agreement following the Evaluator’s Report and Recommendation, the custody matter will be set for trial.  It is very likely that trial will be schedule six months or more later.  It is also likely that your first trial date will get “bumped” or postponed due to an older court case filed before yours.  Should it be the case that divorce and property also need to be litigated, and should those items have long drawn-out discovery issues, your entire case may not be heard for up to one and a half to two years.

It is sometimes the case that the issues of substance abuse and/or psychological impairments cause one or both parties to be unable to reach an agreement.  Should this be the case, either party is able to request of the court drug and alcohol testing, a substance abuse evaluation, and/or a psychological evaluation.   Please note, that there is significant cost to each one of these measures.  It is likely that if any of the aforementioned tests are ordered, that both parties will participate in the evaluation.

I would stress that of utmost importance is the need, when possible, for parties to reach an agreement as to custody.  Parties reaching an agreement not only alleviate the emotional stress and strife surrounding the uncertainty of their lives and that of their children, but also have the satisfaction that they were both successful in reaching an agreement together and taking the first steps at co-parenting while apart – something that will need to take place throughout the life of your child or children.  I would also point out that not so unimportant is the fact that reaching an agreement in a custody case is a significant cost savings to both parties.

Lastly, I would point out that when custody and visitation are primary issues in a separating family, emotions and tensions run high.  I strongly suggest that both parties not take any actions to increase tensions at a tense time, but rather to do whatever may be necessary, and possibly bend from time to time, to reach an amicable solution.  My preferred colloquialism with regard to this attitude is “be like the duck”.

In reaching an agreement as to property disposition, once again each party is provided the opportunity of dividing property such that not necessarily they are completely satisfied, but that each can live with the result.  Similarly, in not litigating disposition of property, each party has once again demonstrated the ability to communicate and cooperate, but also has save a tremendous amount of money.  At the end of the day, particularly in custody situations, each party will need to be able to co-parent and cooperate in raising of a child.  It is hopeful that when your child or children graduate from high school, that when they come off the stage they will not have to make a decision as to which parent to go to, because both parents will be sitting together to celebrate that important day together.

Contained within the materials provided are some statistics with regard to children raised in separated families that were contentious vs. children raised in separated families that were less contentious.

The roadmap below will be one for a divorce that includes pending litigation (Pendente Lite) alimony, custody, child support, disposition of marital property, and divorce.

Whether it be to commence an action for financial relieve, custody of minor children, or simply to attain a divorce, one party will file a Complaint for Divorce in the appropriate Circuit Court.  Often, the Complaint will be filed post-separation.  The Complaint for Divorce filed will allege that both the parties married are over the age of eighteen, a resident of the State of Maryland for at least one year proceeding the filing of their Complaint, that the other party is not a member of the United States Military nor any of its allies; the fact that you have a child or children, where the child or children have lived within the prior years, an allegation that financial support is needed in order to meet basic living standards, an allegation that there is significant real or personal property that needs to be either divided or sold and divided, an allegation as to the ground for divorce; and also a request of the Court to grant relief consistent with the above allegations.  Once a Complaint is filed in the appropriate Circuit Court, a summons is issued, and the other party served he or she will have thirty (30) days from service (if they reside within the State of Maryland, sixty (60) days if they reside outside of the State of Maryland, and ninety (90) days if they reside outside of the United States) in order to file an Answer to your Complaint.  Very often the Answer will be a denial of the allegations contained therein to the extent that you are requesting financial relief and custody.  Once the Answer is filed with the Circuit Court, you than have the ability to request of the Circuit Court (1) an initial conference to establish an interim schedule for custody, and (2) a separate hearing on financial issues

With regard to the initial conference to establish an interim custody schedule, this is an opportunity for parties and counsel and perhaps some witnesses, to explain to a Master of the Court what the current custodial situation has been throughout the course of the marriage and what schedule each party is seeking pending the outcome of the case.  The Master will hear from both sides and make a recommendation as to interim custody.  Please note, the Court’s first concern at this stage is, even though one or both parties might be unhappy with a custodial schedule, to provide some level of consistency to the children involved in your separation and/or divorce.  It may be the case that both parties arrive at this initial conference and are able to work out an agreement on their own.  If so a Consent Order can be entered at this time.  It may also be the case that one or both parties are so dissatisfied with the Master’s Recommendation that they file Exceptions (an appeal) to the Master’s Recommendation.  If the latter is the case the Exceptions will be set before a Judge who will in fact set some custodial schedule.

Also at this initial custody conference, it is likely that the parties will be referred to the Office of Family Court Services for a Custody Evaluation.  During a Custody Evaluation, both parties are assigned to a Social Worker that will speak with each party, the children, collateral sources (such as teachers, relatives, or any other individual with pertinent information) in order to assess the past custodial situation, and what would be best for the child or children involved going forward.  Throughout the sections that you will have with the Social Worker, the Social Worker will attempt to have you and the other parent reach an agreement as to custody and/or visitation.  If the Social Worker is unsuccessful, or rather the parties are unsuccessful in reaching an agreement, the Social Worker then returns to Court on a later date and so that the Court can receive the report of the Social Worker as well a recommendation as to custody.  If both parties are unable to reach an agreement at that point, then the custody is set for trial.

With regard to financial support, it is hopeful, but not guarantied that a Support Hearing could be scheduled within two to three months of the request (please note the request comes following the other parties having filed their Answer).  Prior to a Support Hearing both parties will likely provide Discovery, or a request for information in the form of documents or questions upon the other party.  In particular, prior to a financials hearing, financial documentation as to a parties’ expenses and income is relevant.  Should your financial hearing be pertained to Pendente Lite alimony, the test for that type of support is your need vs. the other parties’ ability to pay.  In analyzing your need, a Master of the Court will review your current financial obligations and weight them against your current income.  Should it be that in analyzing your finances, you’re in a deficit position at the end of each month, than you will have satisfied the first part of the test.  Next, through testimony and evidence, the Master will be a position of analyzing the financial circumstances of your spouse.  In much the same way the Master will be examining your spouse’s current expenses vs. his income.  Please note that if your spouse is unable to meet their financial responsibilities, than you will not have satisfied the second part of the test-the ability of your spouse to pay.  If however, your spouse has extra money the Master may, but is not required, to award you some level of support to assist you in meeting your needs.

Also at that financial hearing you will have the ability to present evidence and testimony for the Master to compile Child Support Guidelines.  Maryland Child Support Guidelines are largely a product of income and overnights.  If you are yourself a W2 wage earner and your spouse is a W2 wage earner, than establishing income is relatively easy.  Difficulty arises when one party or the other or both are self-employed with a cash business.  The latter is a much more difficulty case if one party or the other is less than candid with their income.  Once income is established the Master plugs in that income (before tax income) to the Maryland Child Support Guidelines.  The Master, likely using the Court’s Order as to custody, will than include the number of overnights that each party has.  Other items the Master will consider would be alimony that is paid from one party to the other, health insurance, extraordinary expenses, daycare expenses, or other child support obligation of you or your spouse.  Once this information is available to the Master, a computation is done which determines the amount of child support according to Maryland Child Support Guidelines.  Please note, child support is an absolute obligation and does not analyze one’s expenses whatsoever.  It does not matter if one party or the other has five big screens that they are paying on inside their Cadillac Escalade, in their $500,000 house, they will still pay child support according to their gross income.

Following Support Hearing, the Master will make a recommendation as to what if any alimony is to be paid and what amount of child support will be paid.  Should either party disagree with the amount of support awarded, that party may file Exceptions (or an appeal) to the Master’s Recommendation.  If there is a dire need for support, the Master may have recommended an immediate Order.  In that case, the Master’s Recommendation would be reviewed based on the standard of emergent need within two weeks of the Master’s Report being issued (please note the Master’s Report may come several months following the hearing).  If the Master recommended support for you and you are able to convince the Judge that there is an emergent situation, than the Judge will sign the immediate Order.  The immediate Order does not divest the other party of the ability to file their Exceptions.  Should Exceptions be filed a hearing will be set in due course for a Judge to review it once again.  Either prior to your hearing or following, it is likely that you will have at least a few Pre-Trial Settlement Conferences.  A Pre-Trial Settlement Conference is an opportunity for counsel and the parties to come to court to attempt to reach resolution of the case in total.  In all likelihood, counsel for the parties will speak together in an attempt to find some common ground.  They will than return to their clients to gain their client’s position on the offers being made.  At some point during the Pre-Trial Settlement Conference, counsel themselves will speak with the administrative Judge of the Circuit Court.  The Administrative Judge may have suggestions that they wish the counsel to take back to their clients in a further effort to settle the case.  If an agreement ultimately is reached at the time of the Pre-trial Settlement Conference, counsel for the parties will place this agreement on the record in open court and the parties will be asked whether or not they agree with the agreement.  Provided they do agree, that agreement can be reduced to writing and will be signed by a Judge.  If it is the case that the Pre-Trial Settlement Conference is reached a year after your separation, it maybe possible to also put divorce testimony on the record at the time of the Pre-Trial Settlement Conference.  If this is the case divorce testimony will be taken as well and the entire agreement plus a granting of the divorce will be granted and signed by the Judge.  If after opportunity for Pre-Trial Settlement Conference, or conferences, the parties are still unable to reach and agreement on any remaining issues present in their case, the case will go to trial.  At the time of the trial the parties will present evidence as to what is in the best interest of the minor children for custody, what type of financial relief they need themselves, the property and each parties allegation as to the value of any property, and the grounds for divorce.  Following trial the Judge will render any opinion.  That opinion will be a final ruling one or both parties note an appeal to that decision.  Please note that an appeal to a custody decision will not suspend the implementation of the Judge’s ruling on custody.

• counseling clients in all aspects of separation and divorce
• negotiation and preparation of separation agreements
• representation of clients in court proceedings involving divorce, custody disputes, child support, spousal support, division of property
• providing advice and counseling to clients involved in mediation
• advising and representing clients in domestic violence cases
• adoption
• change of name
• Child in Need of Assistance (CINA) proceedings
• representation of clients in appeal of Department of Social Services finding

	COMPROMISE In any separating situation in which a family is breaking apart, tensions are particularly high.  It is of utmost importance wherever possible for each party to attempt to negotiate a reasonable compromise to this difficult situation. Read more…
	SEPARATION & DIVORCE There are a number of ways in which an actual separation of married parties comes about.  Without addressing each of the causes, this cursory roadmap will serve as something for you to refer to should you be curious as to where in your divorce proceedings you may be. Read more…
	CUSTODY PROCEEDINGS If you and the other parent of your child or children are unable to reach an agreement as to a custody and/or visitation schedule, then either one of you, or both of you, will file the appropriate pleadings in court. Read more…

Our practice includes:

• representing clients in the purchase, financing and sale of real estate
• preparation of real estate contracts, deeds, and mortgage documents
• handling settlements
• preparation of leases
• landlord/tenant matters
• foreclosures
• preparation of contracts
• formation of businesses, including incorporation