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24CV007608-910
STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE
COUNTY OF WAKE SUPERIOR COURT DIVISION
KEITH MARINE,
Plaintiff, COMPLAINT
v (JURY TRIAL DEMANDED)
WES BLANKENBECLER,
Defendant.
NOW COMES THE PLAINTIFF, complaining of the Defendant and alleges the following:
'COUNT 1 -
ALIENATION OF AFFECTION
1. Plaintiff is a citizen and resident of Wake County, North Carolina and has been
for six (6) months preceding the initiation of this action.
2. Defendant is a citizen and resident of Wake County, North Carolina and has been
for six (6) months preceding the initiation of this action. :
3. Plaintiff married Heather Marine on May 13, 2017. Plaintiff and Heather Marine
separated on or around July 19, 2023.
4, At all times from the date of the marriage until the occurrences set forth in this
Complaint, the Plaintiff lived with his spouse and was a faithful and dutiful spouse.
5. Prior to the actions and interference of the Defendant as set forth hereinafter, :
Plaintiff and Heather Marine were happily married, and genuine love and affection existed
between them.
6. Beginning approximately November 15, 2022, Defendant, by persuasion and with
the actual knowledge of the marital relationship existing between the Plaintiff and his spouse,
has willfully and deliberately seduced, enticed and alienated the affections of the said Heather
Marine, thereby destroying the love and affection which previously existed between Plaintiff and
El
ectroni
cal
lyFi
led Date:3/6/2024 3:56 PM W ake CountyCl
erkofSuperi
orCourt
1
his wife and to wrongfully and maliciously injuring the Plaintiff and depriving him of the
company, consortium, society, assistance, and services of his wife.
7. The actions of the Defendant resulted in Heather Marine withdrawing her
affection from the Plaintiff, moving into a separate bedroom in May 2023, and ultimately
separating from the Plaintiff in July of 2023.
8. The Defendant's willful and deliberate efforts to alienate the affections of the
Plaintiffs wife from the Plaintiff, include but are not limited to, the following acts:
a. The Defendant, upon information and belief, has committed acts of illicit sexual
behavior with Heather Marine in the state of North Carolina as defined by N.C.
Gen. Stat. § 50-16.1A(8)(a);
b. The Defendant and Heather Marine, upon information and belief, have spent the
night together and engaged in afternoon encounters on a regular basis in North
Carolina and other locations; and
C. Various acts at other times and other places to be shown through discovery and
proven at trial.
9. All of the aforementioned actions occurred after the date of the parties' marriage
and prior to their separation, occurred prior to the expiration of the applicable statute of
limitations period, and were not condoned by the Plaintiff or otherwise justified.
10. As a result of the aforementioned actions by the Defendant, Plaintiff has lost,
among other things, his wife's affections, society, companionship, assistance, and services, and
has suffered a loss of support, injury to his physical and mental health, feelings, and reputation.
He and his wife are estranged, and their marital relationship has been destroyed. Moreover, the
Plaintiff has suffered great mental and emotional anguish and distress, and has been greatly
embarrassed and humiliated.
11. By reason of the above injuries, the Plaintiff has been damaged in an amount in
excess of Twenty-Five Thousand and no/100 Dollars ($25,000.00).
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COUNT II CRIMINAL CONVERSATION
-
12. Plaintiff incorporates herein by reference, as if fully set forth, the allegations set
forth in Paragraphs 1 -9 above.
13. Upon information and belief, Defendant and Heather Marine have had numerous
sexual encounters since December 1, 2022, occurring on a regular basis and continuing until the :
and at other times
separation of the Plaintiff and Heather Marine in July 2023, in North Carolina,
and other places to be shown through discovery and proven at trial.
14. Upon information and belief, Defendant and Heather Marine have engaged in a
sexual relationship wherein they had sexual intercourse with each other, and/or have committed
other acts of illicit sexual behavior in the state of North Carolina as defined by N.C. Gen. Stat. §
50-16.1A.(3)(a).
15. During the time referred to in paragraphs 12 and 13 above, Plaintiff and Heather
Marine were not divorced, nor legally separated, and the acts occurred within the statute of
limitations.
16. Atno time were the acts in questions condoned by Plaintiff; in fact, Plaintiff had
no knowledge of the acts in question until after they were committed.
17. The exclusive rights and privileges of the Plaintiffs marriage were invaded and
ended, and the Plaintiff suffered shame and embarrassment, all caused by the loss of his spouse's
affection and the disgrace which the acts described herein have caused.
18. The marriage bed was dishonored, domestic comfort was destroyed, and the right
of Plaintiff to his wife's company, cooperation, and aid in every conjugal relation was
substantially and actually damaged and lost.
19. Plaintiff's mental anguish, humiliation, oppression, loss of consortium,
embarrassment, emotional turmoil and injury, and loss of assistance has continued unabated and
will continue, all to the Plaintiffs continuing damage and injury.
20. The actions of Defendant give Plaintiff a cause of action for criminal
conversation. On account of Defendant's actions, Plaintiff has been greatly embarrassed, and
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humiliated, and has suffered emotionally, Plaintiff is entitled to recover damages in excess of
Twenty-Five Thousand and no/100 Dollars ($25,000.00).
WHEREFORE, based upon the foregoing, Plaintiff requests the following relief:
For alienation of affections, compensatory damages in excess of Twenty-Five
:
1. :
Thousand and no/100 Dollars ($25,000.00).
2. For criminal conversation, compensatory damages in excess of Twenty-Five
Thousand and no/100 Dollars ($25,000.00).
3. The costs of this action, including attorney's fees to the extent allowed by law.
4. That the Court grant such other and further relief as it deems just and proper.
5. A jury trial is demanded.
This the 29" day of February, 2024.
GANTT FAMILY LAW
Richard Gantt
N.C. Bar # 44150
4917 Waters Edge Drive, Suite 235
Raleigh, NC 27606
Office: 919-809-8860
richard@ganttfamilylaw.com
Attorney for Plaintiff
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VERIFICATION
L,Keith Marine, being first duly sworn, depose and say that I am the Plaintiff in the above
entitled action; that JI am over the age of eighteen (18) and am competent to give this
Verification; and that I have read the foregoing Complaint and know the contents thereof; that :
the same are true to my own knowledge, except as to those matters stated upon information and
belief, and as to those matters, I believe them to be true.
:
ith Marine
Sworn to and subscribed before me this 29" day of February, 2024.
EOC,
Natalie Rouse :
WOTARy
Wale County :
NOTARY PUBLIC
1
"ay ON corse"
My Commission Expires: 0 20 20 28
5
Preview
24CV007608-910 STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE COUNTY OF WAKE SUPERIOR COURT DIVISION KEITH MARINE, Plaintiff, COMPLAINT v (JURY TRIAL DEMANDED) WES BLANKENBECLER, Defendant. NOW COMES THE PLAINTIFF, complaining of the Defendant and alleges the following: 'COUNT 1 - ALIENATION OF AFFECTION 1. Plaintiff is a citizen and resident of Wake County, North Carolina and has been for six (6) months preceding the initiation of this action. 2. Defendant is a citizen and resident of Wake County, North Carolina and has been for six (6) months preceding the initiation of this action. : 3. Plaintiff married Heather Marine on May 13, 2017. Plaintiff and Heather Marine separated on or around July 19, 2023. 4, At all times from the date of the marriage until the occurrences set forth in this Complaint, the Plaintiff lived with his spouse and was a faithful and dutiful spouse. 5. Prior to the actions and interference of the Defendant as set forth hereinafter, : Plaintiff and Heather Marine were happily married, and genuine love and affection existed between them. 6. Beginning approximately November 15, 2022, Defendant, by persuasion and with the actual knowledge of the marital relationship existing between the Plaintiff and his spouse, has willfully and deliberately seduced, enticed and alienated the affections of the said Heather Marine, thereby destroying the love and affection which previously existed between Plaintiff and El ectroni cal lyFi led Date:3/6/2024 3:56 PM W ake CountyCl erkofSuperi orCourt 1 his wife and to wrongfully and maliciously injuring the Plaintiff and depriving him of the company, consortium, society, assistance, and services of his wife. 7. The actions of the Defendant resulted in Heather Marine withdrawing her affection from the Plaintiff, moving into a separate bedroom in May 2023, and ultimately separating from the Plaintiff in July of 2023. 8. The Defendant's willful and deliberate efforts to alienate the affections of the Plaintiffs wife from the Plaintiff, include but are not limited to, the following acts: a. The Defendant, upon information and belief, has committed acts of illicit sexual behavior with Heather Marine in the state of North Carolina as defined by N.C. Gen. Stat. § 50-16.1A(8)(a); b. The Defendant and Heather Marine, upon information and belief, have spent the night together and engaged in afternoon encounters on a regular basis in North Carolina and other locations; and C. Various acts at other times and other places to be shown through discovery and proven at trial. 9. All of the aforementioned actions occurred after the date of the parties' marriage and prior to their separation, occurred prior to the expiration of the applicable statute of limitations period, and were not condoned by the Plaintiff or otherwise justified. 10. As a result of the aforementioned actions by the Defendant, Plaintiff has lost, among other things, his wife's affections, society, companionship, assistance, and services, and has suffered a loss of support, injury to his physical and mental health, feelings, and reputation. He and his wife are estranged, and their marital relationship has been destroyed. Moreover, the Plaintiff has suffered great mental and emotional anguish and distress, and has been greatly embarrassed and humiliated. 11. By reason of the above injuries, the Plaintiff has been damaged in an amount in excess of Twenty-Five Thousand and no/100 Dollars ($25,000.00). 2 COUNT II CRIMINAL CONVERSATION - 12. Plaintiff incorporates herein by reference, as if fully set forth, the allegations set forth in Paragraphs 1 -9 above. 13. Upon information and belief, Defendant and Heather Marine have had numerous sexual encounters since December 1, 2022, occurring on a regular basis and continuing until the : and at other times separation of the Plaintiff and Heather Marine in July 2023, in North Carolina, and other places to be shown through discovery and proven at trial. 14. Upon information and belief, Defendant and Heather Marine have engaged in a sexual relationship wherein they had sexual intercourse with each other, and/or have committed other acts of illicit sexual behavior in the state of North Carolina as defined by N.C. Gen. Stat. § 50-16.1A.(3)(a). 15. During the time referred to in paragraphs 12 and 13 above, Plaintiff and Heather Marine were not divorced, nor legally separated, and the acts occurred within the statute of limitations. 16. Atno time were the acts in questions condoned by Plaintiff; in fact, Plaintiff had no knowledge of the acts in question until after they were committed. 17. The exclusive rights and privileges of the Plaintiffs marriage were invaded and ended, and the Plaintiff suffered shame and embarrassment, all caused by the loss of his spouse's affection and the disgrace which the acts described herein have caused. 18. The marriage bed was dishonored, domestic comfort was destroyed, and the right of Plaintiff to his wife's company, cooperation, and aid in every conjugal relation was substantially and actually damaged and lost. 19. Plaintiff's mental anguish, humiliation, oppression, loss of consortium, embarrassment, emotional turmoil and injury, and loss of assistance has continued unabated and will continue, all to the Plaintiffs continuing damage and injury. 20. The actions of Defendant give Plaintiff a cause of action for criminal conversation. On account of Defendant's actions, Plaintiff has been greatly embarrassed, and 3 humiliated, and has suffered emotionally, Plaintiff is entitled to recover damages in excess of Twenty-Five Thousand and no/100 Dollars ($25,000.00). WHEREFORE, based upon the foregoing, Plaintiff requests the following relief: For alienation of affections, compensatory damages in excess of Twenty-Five : 1. : Thousand and no/100 Dollars ($25,000.00). 2. For criminal conversation, compensatory damages in excess of Twenty-Five Thousand and no/100 Dollars ($25,000.00). 3. The costs of this action, including attorney's fees to the extent allowed by law. 4. That the Court grant such other and further relief as it deems just and proper. 5. A jury trial is demanded. This the 29" day of February, 2024. GANTT FAMILY LAW Richard Gantt N.C. Bar # 44150 4917 Waters Edge Drive, Suite 235 Raleigh, NC 27606 Office: 919-809-8860 richard@ganttfamilylaw.com Attorney for Plaintiff 4 VERIFICATION L,Keith Marine, being first duly sworn, depose and say that I am the Plaintiff in the above entitled action; that JI am over the age of eighteen (18) and am competent to give this Verification; and that I have read the foregoing Complaint and know the contents thereof; that : the same are true to my own knowledge, except as to those matters stated upon information and belief, and as to those matters, I believe them to be true. : ith Marine Sworn to and subscribed before me this 29" day of February, 2024. EOC, Natalie Rouse : WOTARy Wale County : NOTARY PUBLIC 1 "ay ON corse" My Commission Expires: 0 20 20 28 5