Document for Dana L Kunes v. Jason J Kunes

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                                Filed in Buffalo District Court
                                                                                   we EFILED    **
                                                                         Case Number: D09C1240000025
                                                                           Transaction ID: 0021047178
                                                                   Filing Date: 01/19/2024 12:38:06 PM CST



              IN THE DISTRICT COURT OF BUFFALO COUNTY, NEBRASKA

     DANA KUNES,                                       Case No. CI 24-

                         Plaintiff,
                                                COMPLAINT FOR DISSOLUTION
        vs.                                            OF MARRIAGE

     JASON KUNES,

                         Defendant.
              COMES   NOW     Plaintiff, and   for her Complaint    herein,   states and
     alleges as follows:
             1       Plaintiff resides at 6102 R Avenue, Kearney, Buffalo County,
     Nebraska.    Defendant resides at 3032 224 Street, Columbus, Platte County,
     Nebraska. That both Plaintiff and Defendant have had actual residence in the
     State of Nebraska with a bona fide intent of making this state their permanent
     home for more than one year prior to the filing of the Complaint.
              2.     Plaintiff and Defendant were married in Columbus, Platte
     County, Nebraska on July 9, 2021.
              3      The parties have no minor children who will be affected by
     these proceedings; Plaintiff is not now pregnant.
             4      Neither Plaintiff nor Defendant is a member of the Armed
     Forces of the United States of America.
             5      Plaintiff has made every reasonable effort to effect
     reconciliation without success, and that the marriage of the parties is
     irretrievably broken.
             6.     The parties are the owners of various property and the Court
     should make a fair and equitable division of such property.
              7.      The parties have incurred various debts and the Court should
     make a fair and equitable determination as to the payment of the debts.
              8       Defendant is able-bodied, capable of earning a significant
     income and capable of providing support to Plaintiff as well as contribution to
     Plaintiff's costs and attorney’s fees herein.




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9      Plaintiff is fearful that unless       restrained   from   doing   so,
Defendant may try to hide, sell, conceal, dispose of or hypothecate property of
the parties during the pendency of this action.
        10.    Plaintiff is fearful that unless restrained from doing so,
Defendant may harass, molest or disturb his peace.
        11.    Plaintiff requests that the Defendant be excluded from the
marital property of the parties.
        12.    Plaintiff requests this matter be heard by a District Judge.
       Plaintiff prays that upon filing of the Complaint for Dissolution of
Marriage herein, he be granted ex parte restraining orders regarding person
and property herein.
        Plaintiff prays that upon notice to Defendant and temporary hearing,
she be granted temporary spousal support, attorney’s fees and suit money
herein and that any restraining orders regarding person and property be
continued during the pendency of this case, or if not entered, be issued at
such time.
        Plaintiff prays that upon final hearing the marriage of the parties be
dissolved; that the Court make a fair and equitable division of the property of
the parties; that the Court make a fair and equitable determination as to the
payment of the debts of the parties; that Plaintiff be awarded alimony and
attorney’s fees, and for such other and further relief as may be just and
equitable.

                                           DANA KUNES, Plaintiff,

                                           BY//. Heather Swanson-Murray
                                           Heather Swanson-Murray, NSBA
                                           # 21340
                                           Of Swanson Murray Law, LLC
                                           2029 Central Avenue
                                           P.O. Box 2042
                                           Kearney, NE 68848-2042
                                           Phone: (308) 234-1966
                                           Fax:      (308) 234-1482
                                           Her attorney
STATE OF NEBRASKA                              )
                                               )ss:
COUNTY OF BUFFALO,                             )
        DANA KUNES, being first duly sworn upon her oath, deposes and
says that she is the Plaintiff in this action; that she has read the foregoing
Complaint for Dissolution of Marriage and knows and understands the
contents thereof, and, that the same are true as she verily believes.


                                                          Dang J—
                                                          DANA KUNES, Plaintiff


        Subscribed           and       sworn          to before me   this   19 th   day   of   January,
2024.


                SONJA K. LOEFFLER


                                                                                          bee
          ‘State of Nebraska-Gen eral Notary
              My Commission Expires
                September 01, 2025                           Chore. Xho
                                                         Notary Pub!