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Filed in Richardson District Court
*** EFILED ***
Case Number: D19CI240000013
Transaction ID: 0021109566
Filing Date: 02/01/2024 01:48:27 PM CST
IN THE DISTRICT COURT OF RICHARDSON COUNTY, NEBRASKA
TERRA FRANK, )
Plaintiff, ) MOTION FOR
vs. ) TEMPORARY ORDERS &
) NOTICE OF HEARING
FRANKLYN RIST, )
Defendant. )
COMES NOW, the Plaintiff and moves the Court to enter an Order granting her
the following temporary relief:
1. For an Order granting temporary legal and physical custody of the parties’
minor child, namely: McKaley G. Rist (DOB: 09/2022), to the Plaintiff/Mother, on a
primary and sole basis, subject to reasonable parenting time with Defendant.
2. That the temporary parenting time schedule involving the parties minor
children be determined, including a temporary holiday schedule;
3. For an Order compelling the Defendant/Father to pay, for the use and benefit of
the Plaintiff, temporary child support pursuant to the Nebraska Child Support Guidelines;
4. For an Order compelling the Defendant to pay an equitable share of out-of-
pocket medical expenses, if any, for the minor child during the pendency of these
proceedings;
5. For an Order enjoining and restraining the Defendant from threatening,
assaulting, molesting, attacking, or otherwise disturbing the peace of the Plaintiff;
6. For such other and further relief as the Court deems just and equitable.
WHEREFORE, Plaintiff prays that the Court enter an Order granting temporary
legal and physical custody of the parties’ minor child, McKaley G. Rist, to the
Plaintiff/Mother on a primary and sole basis subject to reasonable parenting time with
Defendant; For an Order setting forth the regular and holiday parenting times for the
parties during the pendency of these proceedings; for an Order requiring the
Defendant/Father to pay, for the use and benefit of the Plaintiff/Mother, temporary child
support; for an Order equitably dividing out of pocket medical expenses for the minor
child during the pendency of the proceedings; For an Order enjoining and restraining the
Defendant from threatening, assaulting, molesting, attacking or otherwise disturbing the
peace of the Plaintiff; and for such other and further relief as the court deems just and
equitable.
Terra Frank, Plaintiff
Dated: February 1, 2024. By: /s/ Morgan T. Ritchie_____
Morgan T. Ritchie (27653)
Ligouri Law Office
1118 15th Street
P.O. Box 99
Auburn, Nebraska 68305
Telephone: (402) 274-5484
Morganritchie41@gmail.com
Attorneys for Plaintiff
NOTICE OF HEARING
TO: Defendant, Franklyn Rist at 63239 712 Rd., Humboldt, NE 68376, and his
attorney if any:
Please take notice that the above and foregoing Motion for Temporaries will come on for
hearing before the Honorable Judge Julie D. Smith, at the Richardson County Courthouse,
District Courtroom, on the 20th day of February 2024 at 1:15 a.m., or as soon thereafter as the
Court may hear the same.
/s/ Morgan T. Ritchie____
Morgan T. Ritchie (27653)
CERTIFICATE
The undersigned hereby certifies that on the 1st day of February 2024, a true, correct, and
complete copy of the above and Motion for Temporary Orders was sent to the Richardson
County, Nebraska, Sheriff’s Office to be personally served upon the Defendant, Franklyn Rist, at
the following address: 63239 712 Rd., Humboldt, NE 68376.
/s/ Morgan T. Ritchie
Morgan T. Ritchie
2
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Filed in Richardson District Court *** EFILED *** Case Number: D19CI240000013 Transaction ID: 0021109566 Filing Date: 02/01/2024 01:48:27 PM CST IN THE DISTRICT COURT OF RICHARDSON COUNTY, NEBRASKA TERRA FRANK, ) Plaintiff, ) MOTION FOR vs. ) TEMPORARY ORDERS & ) NOTICE OF HEARING FRANKLYN RIST, ) Defendant. ) COMES NOW, the Plaintiff and moves the Court to enter an Order granting her the following temporary relief: 1. For an Order granting temporary legal and physical custody of the parties’ minor child, namely: McKaley G. Rist (DOB: 09/2022), to the Plaintiff/Mother, on a primary and sole basis, subject to reasonable parenting time with Defendant. 2. That the temporary parenting time schedule involving the parties minor children be determined, including a temporary holiday schedule; 3. For an Order compelling the Defendant/Father to pay, for the use and benefit of the Plaintiff, temporary child support pursuant to the Nebraska Child Support Guidelines; 4. For an Order compelling the Defendant to pay an equitable share of out-of- pocket medical expenses, if any, for the minor child during the pendency of these proceedings; 5. For an Order enjoining and restraining the Defendant from threatening, assaulting, molesting, attacking, or otherwise disturbing the peace of the Plaintiff; 6. For such other and further relief as the Court deems just and equitable. WHEREFORE, Plaintiff prays that the Court enter an Order granting temporary legal and physical custody of the parties’ minor child, McKaley G. Rist, to the Plaintiff/Mother on a primary and sole basis subject to reasonable parenting time with Defendant; For an Order setting forth the regular and holiday parenting times for the parties during the pendency of these proceedings; for an Order requiring the Defendant/Father to pay, for the use and benefit of the Plaintiff/Mother, temporary child support; for an Order equitably dividing out of pocket medical expenses for the minor child during the pendency of the proceedings; For an Order enjoining and restraining the Defendant from threatening, assaulting, molesting, attacking or otherwise disturbing the peace of the Plaintiff; and for such other and further relief as the court deems just and equitable. Terra Frank, Plaintiff Dated: February 1, 2024. By: /s/ Morgan T. Ritchie_____ Morgan T. Ritchie (27653) Ligouri Law Office 1118 15th Street P.O. Box 99 Auburn, Nebraska 68305 Telephone: (402) 274-5484 Morganritchie41@gmail.com Attorneys for Plaintiff NOTICE OF HEARING TO: Defendant, Franklyn Rist at 63239 712 Rd., Humboldt, NE 68376, and his attorney if any: Please take notice that the above and foregoing Motion for Temporaries will come on for hearing before the Honorable Judge Julie D. Smith, at the Richardson County Courthouse, District Courtroom, on the 20th day of February 2024 at 1:15 a.m., or as soon thereafter as the Court may hear the same. /s/ Morgan T. Ritchie____ Morgan T. Ritchie (27653) CERTIFICATE The undersigned hereby certifies that on the 1st day of February 2024, a true, correct, and complete copy of the above and Motion for Temporary Orders was sent to the Richardson County, Nebraska, Sheriff’s Office to be personally served upon the Defendant, Franklyn Rist, at the following address: 63239 712 Rd., Humboldt, NE 68376. /s/ Morgan T. Ritchie Morgan T. Ritchie 2