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Filed in Phelps District Court
** EFILED **
Case Number: D37C1240000017
Transaction ID: 0021190847
Filing Date: 02/20/2024 11:45:55 AM CST
IN THE DISTRICT COURT OF PHELPS COUNTY, NEBRASKA
BRENT MATTHEW BERTRAND, ) CASE NO.: CI24-
)
Plaintiff, ) COMPLAINT FOR
Vv ) DISSOLUTION OF
MARRIAGE
SARAH EVELINA BERTRAND, )
)
Defendant. )
Plaintiff, Brent Matthew Bertrand, for cause of action against
Defendant, Sarah Evelina Bertrand, states and alleges as follows:
1. Plaintiff is a resident of Phelps County, Nebraska, and has
been a resident of Nebraska for more than one year prior to filing this
Complaint.
2. The current addresses of the parties are:
Brent M. Bertrand Sarah E. Bertrand
722 Logan St. 112 West Detroit St.
Holdrege, NE 68949 Wilcox, NE 68982
3. Plaintiff is represented by Jonathan R. Brandt, of the law
firm Anderson, Klein, Brewster & Brandt, 417 East Avenue, P.O. Box
183, Holdrege, NE 68949-0133.
4. The parties were lawfully married on September 19, 2009, in
Kearney, Buffalo County, Nebraska.
5. Two (2) children were born as issue of this marriage. The
name, month and year of birth of each child whose custody or welfare
may be affected by this proceeding is as follows:
Name Month & Year of Birth
Emmett A. Bertrand August of 2013
Joselyn E. Bertrand September of 2014
6. Aparenting plan is not yet developed. Child custody,
parenting time, visitation, other access and child support may be
contested issues.
7. The following information is provided in accordance with the
requirements of the Uniform Child Custody Jurisdiction and
Enforcement Act:
A The dates, address and names and current address for the
children and person(s) with whom the children have lived
in the past five years is as follows:
DATES: ADDRESS: NAMES & CURRENT
Birth — 8/27/23 722 Logan St. ADDRESS
Holdrege, NE 68949 Brent M. Bertrand’
722 Logan St.
Holdrege, NE 68949
Sarah E. Bertrand
112 W Detroit St.
Wilcox, NE 68982
8/27/23 - Present 112 W Detroit St. Sarah E. Bertrand
Wilcox, NE 68982 112 W Detroit St.
Wilcox, NE 68982
Plaintiff has not been a party or a witness in any other
proceeding concerning the custody of or visitation of the
children.
Plaintiff is not aware of any other actions or proceedings
that could affect this action. This includes actions or
proceedings about domestic violence, protection orders,
termination of parental rights, and adoptions.
Plaintiff is not aware of the names and addresses of any
persons other than Defendant or Plaintiff who have
physical custody of the children or claim to have custody
or visitation rights with the children.
8. Plaintiff is a fit and proper person to have legal and physical
care, custody and control of the minor children of the parties.
9. Defendant should be ordered to provide support for the
children of the parties and share in all work-related childcare expenses
and all unreimbursed medical expenses incurred by the minor
children.
10. Plaintiff and Defendant should be ordered to provide health
insurance for the minor children if it is reasonably available through
his or her employer, and both Plaintiff and Defendant should be
ordered to contribute towards the provision of the available health
insurance.
12. The marriage of the parties is irretrievably broken.
13. Plaintiff is not a party to any other pending action for
divorce, separation, or dissolution of marriage.
14. Neither party is in the military service of the United States
or its allies within the meaning of the Servicemember’s Civil Relief
Act.
15. During the marriage, the parties acquired interests in
property and an equitable division of such property should be made.
Further, the parties incurred certain debts prior to the separation
which should be equitably divided.
16. Plaintiff is unaware of any existing restraining orders,
protection orders, or criminal no-contact orders regarding either party.
17. Plaintiff acknowledges receipt of the Nebraska Parenting
Act Information Brochure.
18. Plaintiff requests this matter be held before a District
Judge.
WHEREFORE, Plaintiff respectfully requests that upon final hearing,
Plaintiff be awarded the following relief:
A. A dissolution of the marriage of the parties;
B Legal and physical custody awarded in the best interests of the
children and implementation of a parenting plan;
Both parties share in the work-related daycare costs and
unreimbursed medical and dental expenses incurred by the minor
children of the parties;
An equitable division of the assets and debts between the parties
including spousal support if applicable;
An award of child support and order of health insurance premium and
reimbursement costs according to the provisions Nebraska Child
Support Guidelines;
Any award of child support effective the first of the month after
service;
Any such other and further relief as to this Court deems just and
equitable.
BRENT MATTHEW BERTRAND, Plaintiff
By__/s/Jonathan R. Brandt
Jonathan R. Brandt #23627
jonbrandt@kleinbrewster.com
Anderson, Klein, Brewster & Brandt
3423 2n¢ Ave., Suite 7, P.O. Box 521
Kearney, NE 68848-0521
Ph: (308) 237-5545 F: (308) 646-2676
STATE OF NEBRASKA )
) ss.
COUNTY OF Keayney )
Brent Matthew Bertrand deposes and says that he is the Plaintiff in the
above and foregoing Complaint for Dissolution of Marriage, and that the facts and
allegations contained therein are true as he verily believes.
Q
Bre
t
mn t Matthew Bertrand
Subscribed in my presence and sworn to before me this 14% day of
February, 2024.
Lites Q-N\eboty
GENERAL NOTARY - State of Nebraska Notary Public
TERESA A. NELSON
‘My Comm. Exp. October 7, 2024
Preview
Filed in Phelps District Court ** EFILED ** Case Number: D37C1240000017 Transaction ID: 0021190847 Filing Date: 02/20/2024 11:45:55 AM CST IN THE DISTRICT COURT OF PHELPS COUNTY, NEBRASKA BRENT MATTHEW BERTRAND, ) CASE NO.: CI24- ) Plaintiff, ) COMPLAINT FOR Vv ) DISSOLUTION OF MARRIAGE SARAH EVELINA BERTRAND, ) ) Defendant. ) Plaintiff, Brent Matthew Bertrand, for cause of action against Defendant, Sarah Evelina Bertrand, states and alleges as follows: 1. Plaintiff is a resident of Phelps County, Nebraska, and has been a resident of Nebraska for more than one year prior to filing this Complaint. 2. The current addresses of the parties are: Brent M. Bertrand Sarah E. Bertrand 722 Logan St. 112 West Detroit St. Holdrege, NE 68949 Wilcox, NE 68982 3. Plaintiff is represented by Jonathan R. Brandt, of the law firm Anderson, Klein, Brewster & Brandt, 417 East Avenue, P.O. Box 183, Holdrege, NE 68949-0133. 4. The parties were lawfully married on September 19, 2009, in Kearney, Buffalo County, Nebraska. 5. Two (2) children were born as issue of this marriage. The name, month and year of birth of each child whose custody or welfare may be affected by this proceeding is as follows: Name Month & Year of Birth Emmett A. Bertrand August of 2013 Joselyn E. Bertrand September of 2014 6. Aparenting plan is not yet developed. Child custody, parenting time, visitation, other access and child support may be contested issues. 7. The following information is provided in accordance with the requirements of the Uniform Child Custody Jurisdiction and Enforcement Act: A The dates, address and names and current address for the children and person(s) with whom the children have lived in the past five years is as follows: DATES: ADDRESS: NAMES & CURRENT Birth — 8/27/23 722 Logan St. ADDRESS Holdrege, NE 68949 Brent M. Bertrand’ 722 Logan St. Holdrege, NE 68949 Sarah E. Bertrand 112 W Detroit St. Wilcox, NE 68982 8/27/23 - Present 112 W Detroit St. Sarah E. Bertrand Wilcox, NE 68982 112 W Detroit St. Wilcox, NE 68982 Plaintiff has not been a party or a witness in any other proceeding concerning the custody of or visitation of the children. Plaintiff is not aware of any other actions or proceedings that could affect this action. This includes actions or proceedings about domestic violence, protection orders, termination of parental rights, and adoptions. Plaintiff is not aware of the names and addresses of any persons other than Defendant or Plaintiff who have physical custody of the children or claim to have custody or visitation rights with the children. 8. Plaintiff is a fit and proper person to have legal and physical care, custody and control of the minor children of the parties. 9. Defendant should be ordered to provide support for the children of the parties and share in all work-related childcare expenses and all unreimbursed medical expenses incurred by the minor children. 10. Plaintiff and Defendant should be ordered to provide health insurance for the minor children if it is reasonably available through his or her employer, and both Plaintiff and Defendant should be ordered to contribute towards the provision of the available health insurance. 12. The marriage of the parties is irretrievably broken. 13. Plaintiff is not a party to any other pending action for divorce, separation, or dissolution of marriage. 14. Neither party is in the military service of the United States or its allies within the meaning of the Servicemember’s Civil Relief Act. 15. During the marriage, the parties acquired interests in property and an equitable division of such property should be made. Further, the parties incurred certain debts prior to the separation which should be equitably divided. 16. Plaintiff is unaware of any existing restraining orders, protection orders, or criminal no-contact orders regarding either party. 17. Plaintiff acknowledges receipt of the Nebraska Parenting Act Information Brochure. 18. Plaintiff requests this matter be held before a District Judge. WHEREFORE, Plaintiff respectfully requests that upon final hearing, Plaintiff be awarded the following relief: A. A dissolution of the marriage of the parties; B Legal and physical custody awarded in the best interests of the children and implementation of a parenting plan; Both parties share in the work-related daycare costs and unreimbursed medical and dental expenses incurred by the minor children of the parties; An equitable division of the assets and debts between the parties including spousal support if applicable; An award of child support and order of health insurance premium and reimbursement costs according to the provisions Nebraska Child Support Guidelines; Any award of child support effective the first of the month after service; Any such other and further relief as to this Court deems just and equitable. BRENT MATTHEW BERTRAND, Plaintiff By__/s/Jonathan R. Brandt Jonathan R. Brandt #23627 jonbrandt@kleinbrewster.com Anderson, Klein, Brewster & Brandt 3423 2n¢ Ave., Suite 7, P.O. Box 521 Kearney, NE 68848-0521 Ph: (308) 237-5545 F: (308) 646-2676 STATE OF NEBRASKA ) ) ss. COUNTY OF Keayney ) Brent Matthew Bertrand deposes and says that he is the Plaintiff in the above and foregoing Complaint for Dissolution of Marriage, and that the facts and allegations contained therein are true as he verily believes. Q Bre t mn t Matthew Bertrand Subscribed in my presence and sworn to before me this 14% day of February, 2024. Lites Q-N\eboty GENERAL NOTARY - State of Nebraska Notary Public TERESA A. NELSON ‘My Comm. Exp. October 7, 2024