Document for State of Nebraska v. Landon J Medina

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                                Filed in Thurston District Court
                                                                      *** EFILED ***
                                                           Case Number: D55CI240000009
                                                              Transaction ID: 0021282063
                                                      Filing Date: 03/08/2024 03:52:58 PM CST



 IN THE DISTRICT COURT OF THURSTON COUNTY, NEBRASKA


State of Nebraska On Behalf Of
Carson Tyce Saunsoci,                  Case No.: CI 24
Heidi Jae Medina,
Carlee Ann Medina,
Crimson John Medina,
            Minor Children,           COMPLAINT TO ESTABLISH
            Plaintiff,
                                             SUPPORT
vs.

Landon John Medina,
          Defendant.


       COMES NOW the Plaintiff, the State of Nebraska and for its
cause of action against Defendant, Landon John Medina, states and
alleges as follows:
       1. That the State of Nebraska is authorized to bring this action
           pursuant to Neb. Rev. Stat. §43-512 through §43-512.18.
       2. That Cammie Hevewah is the mother of the following minor
           children presently in her physical possession:
           Carson Tyce Saunsoci born September, 2010
           Heidi Jae Medina born September, 2011
           Carlee Ann Medina born April, 2015
           Crimson John Medina born January, 2023
       3. That Cammie Heveway and said minor children are
           residents of Thurston County, Nebraska.
       4. That Landon John Medina is a resident of the State of
           Nebraska and is subject to the personal jurisdiction of this
           Court.
       5. That Landon John Medina is the father of said minor
           children as follows:
          Carson Tyce Saunsoci born September, 2010, by having
          signed a notarized acknowledgment;
          Heidi Jae Medina born September, 2011, by having signed a
          notarized acknowledgment;
          Carlee Ann Medina born April, 2015, by having signed a
          notarized acknowledgment;
          Crimson John Medina born January, 2023, by having signed
          a notarized acknowledgment.
      6. That said minor children do not reside with Landon John
          Medina, Defendant, and are in need of financial support
          from the Defendant.
      7. That the State of Nebraska, Department of Health and
          Human Services:
           a. Is subrogated to the rights of Cammie Chrea Hevewah
               following her application for medical assistance benefits,
               and/or
           b. Has an automatic assignment of rights following
               application for medical assistance benefits, and/or
           c. Has an assignment by operation of law of any right for
               child support following an assignment.
      8. That Landon John Medina has a duty to:
          a. Pay monthly child support obligation to support said
               minor children commencing with the date of filing this
               complaint;
          b. Provide ongoing health insurance coverage or pay cash
               medical support for said minor children;
      WHEREFORE, Plaintiff, prays for an order of the Court
determining that:
      1. Landon John Medina is the father of the minor children
          named herein;
      2. Landon John Medina, Defendant, has a duty to pay support
          for said minor children;




                                                          CSE0099
       CC ID/DSS COMPLAINT TO ESTABLISH SUPPORT #: CC4CD4DXHK9XY
3. Current support of said minor children shall commence from
   the date of filing this complaint in accordance with the
   Nebraska Child Support Guidelines;
4. Landon John Medina shall provide health insurance
   coverage for said minor children if insurance is available at
   a reasonable cost or in the alternative Defendant shall pay
   cash medical support;
5. Landon John Medina shall pay the costs of this action and
   such other relief as the Court may allow; and/or
6. Other relief as may be just in these proceedings.

                         STATE OF NEBRASKA
                         PLAINTIFF




                         By:Tammy Maul-Bodlak
                         TAMMY MAUL-BODLAK, #21976
                         COUNTY ATTORNEY
                         COUNTY.ATTORNEY@THURSTONC
                         OUNTYNE.GOV
                         106 S 5TH ST
                         PO BOX 490
                         PENDER NE 68047
                         (402) 385-3416




                                                   CSE0099
CC ID/DSS COMPLAINT TO ESTABLISH SUPPORT #: CC4CD4DXHK9XY