Family Matters: Travis N Hale Jr v. Desirae N Hale

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                                Filed in Phelps District Court
                                                                               *** EFILED ***
                                                                     Case Number: D37CI240000027
                                                                       Transaction ID: 0021404172
                                                                Filing Date: 04/04/2024 09:42:55 AM CDT



       IN THE DISTRICT COURT OF PHELPS COUNTY, NEBRASKA

TRAVIS NATHAN HALE JR.,                )                   Case No. CI 24 -
                                       )
                       Plaintiff,      )
                                       )                COMPLAINT FOR
       v.                              )                DISSOLUTION OF
                                       )                   MARRIAGE
DESIRAE NICOLE HALE,                   )
                                       )
                       Defendant.      )



       COMES NOW the plaintiff, by and through his attorney, Collin A.D.
Preece, and hereby states and alleges as follows:
    1. The plaintiff is a resident of Phelps County, Nebraska, and has been a
resident of the State of Nebraska for at least one year prior to the filing of this
Complaint.
    2. The plaintiff and the defendant were married in Adams County, Hastings,
Nebraska, on October 30, 2020.
    3. There is 1 minor child of the parties affected by these proceedings:

       Alizay Khalia Hale, born July 2021;

    4. The plaintiff is fit and proper to have legal custody of the minor child. It
would be in the best interests of said child that joint legal custody be granted to
plaintiff.
    5. The plaintiff is a fit and proper person to have the physical care, custody
and control of the minor child of the parties, and it would be in the best interest of
said child that joint physical custody be granted to plaintiff.
    6. The plaintiff has not participated as a party, witness, or in any other
capacity, in any litigation concerning the custody of the minor child. Further, the
plaintiff has no information of any custody proceeding concerning the minor child
pending in a Court of this or any other state and does not know of any person not
a party to these proceedings who has physical custody of the minor child or
claims to have custody or visitation rights with respect to the minor child.
   7. The plaintiff is not now a party to any other pending action for divorce,
separation or dissolution of marriage.
   8. Neither party is a member of the Armed Forces of the United States of
America.
   9. The names and addresses of the parties are as follows:
               Plaintiff:     Travis Nathan Hale, Jr.
                              908 Garfield St., Apt B
                              Holdrege, NE 68949

               Defendant:      Desirae Nicole Hale (Formerly Ness)
                               608 6th Ave. Apt 1
                               Holdrege, NE 68949

    10. The name and address of the attorneys for the plaintiff is Collin A.D.
Preece, Bruner Frank, P.O. Box 2230, Kearney, Nebraska 68848-2230.
    11. The plaintiff has made every reasonable effort to effect reconciliation,
without success and the marriage of the parties is irretrievably broken.
    12. The parties are the owners of various real and personal property, and
plaintiff is entitled to a fair and equitable division of the property of the parties.
    13. The parties have incurred certain debts and obligations during their
marriage and liability for payment of these debts and obligations should be
equitably divided by the parties.
    14. The defendant is well able to provide for the support, care and
maintenance of the minor child of the parties.
    15. The plaintiff requests that this matter be heard by a District Judge.
    16. A parenting plan has not been developed. The plaintiff prays that the
Court grant temporary and permanent joint legal and joint physical custody of the
parties’ minor child to the plaintiff and order support for said minor children
according to the law.
        WHEREFORE that upon final hearing in this matter, the marriage
between the parties be dissolved; that the Court make a fair and equitable division
of the property of the parties; that the Court make a determination as to the
payment of the debts of the parties; that the plaintiff be granted permanent joint
custody of the parties’ minor child; and that the plaintiff be granted such other,
further and different relief as to the Court deems just and equitable.
        DATED this 4th day of April, 2024.
TRAVIS NATHAN HALE JR., Defendant

By: /s/ Collin A.D. Preece
Collin A.D. Preece, NSBA # 27913
of Bruner Frank
5804 1st Avenue
P.O. Box 2230
Kearney, NE 68848-2230
Phone: (308) 455-1046
cpreece@nebraskalawfirm.net
Attorneys for Defendant