The recent unreported case of Ziegler v. Ziegler decided by the Maryland Court of Special Appeals discusses several divorce issues. In Zeigler, the trial court granted a divorce on grounds of 12 month separation. The trial court did this despite the fact that the period of a protective order was included in the calculation of the separation period. While the Court of Special Appeals concluded that this calculation was erroneous, it also concluded that the granting of the divorce did not prejudice the party seeking the appeal. Perhaps more significantly, the court indicated that a corroborating witness need not have knowledge of the entire period of separation and reinforced the notion that corroboration only needs to be slight.
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