Document for Susan M Wohlford v. Justin L Wohlford

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                                Filed in Sarpy District Court
                                                                                 ** EFILED#*
                                                                      Case Number: D59C1240000825
                                                                        Transaction ID: 0021590027
                                                                 Filing Date:   05/14/2024   12:43:23 PM   CDT
              IN THE DISTRICT COURT OF SARPY COUNTY, NEBRASKA

SUSAN MARIE WOHLFORD,                            Case. No. 24-

                      Plaintiff,
                                                      COMPLAINT FOR
       vs.                                       DISSOLUTION OF MARRIAGE

JUSTIN LEVI WOHLFORD,

                      Defendant.

       COMES    NOW     the Plaintiff, Susan Marie Wohlford, and for her cause of action

against the Defendant herein, states and alleges as follows:

                                            I

       That the Plaintiff is a resident of Sarpy County and presently resides at 716

Grenoble Drive, Bellevue, NE 68123.       That the Plaintiff has resided in the State of

Nebraska for more than one (1) year with a bona fide intention of making this state her

permanent home.     That the Plaintiff is represented in this action by Justin A. Roberts

of ROBERTS     LAW, L.L.C., 5010 Dodge Street, Ondha, NE 68132.

                                            II

      That the Defendant is a resident of Bellevue, Sarpy County,               Nebraska and

presently resides at 716 Grenoble Drive, Bellevue, NE 68123.        That the Plaintiff and

the Defendant were united in marriage on March 22"4, 2002 in North Platte, Lincoln

County, Nebraska.

                                           Ill

      That two children were born to the parties; however, only one minor child shall

be affected by these proceedings, to wit: Caitlyn Marie Wohlford, born 2006. Plaintiffis
a fit and proper person to be awarded legal and physical custody of the minor child.

                                           IV

       That the Plaintiff is not a party to any other pending action for divorce, legal

separation, or dissolution of the marriage in this State or any other State.

                                            Vv

      That there has been a breakdown in the marriage relationship to the extent that

the marriage is irretrievably broken and there remains no reasonable likelihood that

the marriage can be preserved.

                                           VI

      There are no existing restraining orders, protection orders, or criminal no-

contact orders regarding any part of the proceedings.

                                          VII

      That neither of the parties hereto is a member of the Armed Forces of the United
                                                                                 .
States of America.

                                          VII

      That there is no adequate remedy at law.

                                           Ix

      That a financial statement has not been filed with this Complaint; however, in

the event a temporary hearing is necessary, the Plaintiff shall file the same.

                                           x

      That the relief sought by the Plaintiff, is a dissolution of the marriage; an order

granting her; an equitable division of the real and personal property and the debts of
the parties; child support pursuant to the guidelines; attorney fees and court costs.

                                               XI

       That the Plaintiff requests this matter be heard before a District Court Judge.

       WHEREFORE,           Plaintiff prays that the marriage be dissolved, and further prays

for the following relief:

       (a)    An equitable division of the real and personal property and the debts of
              the parties;

       (b)    an award of legal and physical custody of the minor child;

       (©)    child support pursuant to the Nebraska Child Support Guidelines;

       (a)    an award of attorney fees and court costs;

       (e)    that this matter be heard before a District Court        Judge; and

       @      such other and further relief as the Court may deem just and equitable in
              the premises.




                                             SUSAN MARIE WOHLFORD,
                                             Plaintiff

                                             By: /s/ Justin A. Roberts
                                             Justin A. Roberts - #24188
                                             ROBERTS LAW, L.L.C.
                                             5010 Dodge Street
                                             Omaha, NE 68132
                                             (402) 346-1920
                                             justin@roberts-attorneys.com
                                             Attorney for Plaintiff