Document for Sara J Porter v. Casey J Porter

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                                Filed in Otoe District Court
                                                                                     ** EFILED    **
                                                                           Case Number: D11C1240000047
                                                                             Transaction ID: 0021242158
                                                                     Filing Date: 02/29/2024 04:36:48 PM CST




       IN THE DISTRICT COURT OF OTOE COUNTY, NEBRASKA

SARA PORTER,                                     CASE NO:      CI 24-
                   Plaintiff,
                                                      COMPLAINT FOR
vs.                                              DISSOLUTION OF MARRIAGE

CASEY PORTER
          Defendant.

          COMES NOW Sara Porter, the Plaintiff herein and for her cause of action
states and alleges as follows:
        1       That Plaintiff is a resident of Muscatine County, Iowa and is
represented by Thomas D. Prickett, of Reinsch, Slattery, Bear, Minaban &
Prickett, P.C., L.L.O., 545 Main Street, Plattsmouth, Nebraska 68048. The exact
address of the Plaintiff is being withheld as she has been the victim of intimate
domestic partner abuse.
       2          The Defendant’s current address 2115 Central Avenue, Nebraska
City, Otoe County, Nebraska 68410. The Defendant has resided in Otoe County
Nebraska for at least one year prior to the filing of this action.
       3. The parties were martied on February 10, 2020, in Alliance, Box Butte
County, Nebraska.
       4. No minor children have been born to the marriage.
       5. Plaintiff is not now a party to any other pending action for divorce,
dissolution, or legal separation,
           6. Neither Plaintiff nor the Defendant are members of the United States
Armed Forces nor has either party been ordered for induction into the same.
           7. There are no existing Restraining Orders, Protection Orders,
criminal No-Contact Orders regarding either party.
        8. That during the martiage the parties have incurred certain debts and
other obligations and that an equitable division thereof should be made.
        9. There has been a breakdown in the marriage of the parties to the extent
that the legitimate objects of matrimony have been destroyed, that the attempts at
reconciliation have been unsuccessful, that thé marriage is irretrievably broken
and should be dissolved.
10.      That the Plaintiff is requesting reimbursement of attorney’s fees
and costs if the Defendant is unreasonable throughout this process, proceeds in
bad faith, or causes unnecessary litigation.
         11.    That the parties may have premarital or non-marital assets which
should be considered setoffs to the marital estate.
        12. That this matter should be heard by a District Court Judge.

         WHEREFORE, Plaintiff prays that the parties be granted a dissolution of
marriage and for the following relief:
       a) An equitable division of marital property
      b) An equitable division of the debts and obligations of the parties;
      c) An award of attorneys fees to the Plaintiff; and
      d) Any other and further relief the Court deems fair and equitable.

                                 Respectfully Submitted
                                 Sara Porter,
                                 Plai   ff.
                             7
                                              P=
                       By
                                 Thomas         ickett, #24516
                                 Reinsch, Slattery, Bear, Minahan & Prickett, PC,
                                 LLO
                                 545 Main Street/P.O. Box 489
                                 Plattsmouth, NE 68048
                                 (402) 296-6996
                                 tdp@rsbmlaw.com
STATE OF IOWA                     )
                                    )ss.
  COUNTY OF MUSCATINE )

         Sara Porter, being first duly sworn on oath deposes and states that the
  undersigned is the Plaintiff herein, that the undersigned has read the foregoing
  instrument, knows the contents thereof and that the allegations therein conta“Ss


                                                  Inge
  are true as she verily believes



                                                 Sara Porter

          SUBSCRIBED and sworn to before me this          8 ° day of
Ferny                 2024.

                                                      Cin            iat 0)
1AEoy
              Diego
       Commission Number 842491
fowh         TSS                                Notary PuBLic