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InN
IN THE DISTRICT COURT FOR DOUGLAS COUNTY, NEBRASKA
Case No. Cl 24 - Hy} 34
VANESSA FLORES-BUSTAMANTE,
PLAINTIFF, COMPLAINT FOR
PATERNITY, CUSTODY,
vs.
AND ALLOWANCES
ARMANDO SANTANA ALONZO
DEFENDANT. ~~ ~
COMES NOW, Vanessa Flores-Bustamante, by and through her
attorney, Elaine D’ Amato of Legal Aid of Nebraska, and files her
Complaint for Paternity, Custody, and Allowances. In support thereof,
Plaintiff presents the following information to the Court:
1 Plaintiff lives at 1713 Holmes Street in Douglas County, Omaha,
Nebraska 68107.
The Defendant lives at 2832 South 39th Street in Douglas County,
Omaha, Nebraska 68105.
The Parties were never married. However, during the time of
conception of the minor children, the parties were involved in an
intimate relationship and the Plaintiff became pregnant and gave
birth to the minor children, to-wit: Elayna Santana Bustamante,
bom 2017, and Adilene Santana Bustamante, born in 2018.
The minor children of the parties have lived in the State of
Nebraska for at least five years.
Neither the Plaintiff nor the Defendant is a member of the Armed
Forces of the United States or its allies.
Paternity of the above-named minor children has not been
established.
The Plaintiff is the fit and proper person to have the care, custody,
and control of the minor children, subject to the reasonable
supervised visitation by the Defendant.
The following information is provided in compliance with the
requirements of the Uniform Child Custody Jurisdiction and #7
Enforcement Act:
DOUGLAS COUNTY, NEBR
ASKA
JUN 0 6 2024
CLERK DISTRICT CouRT
a) For the last five years, the children’s addresscs and persons they
have lived with are:
DATES ADDRESS WITH WHOM
01/2024 1713 Holmes Street Plaintiff
- Present Omaha, NE 68107
12/2021- 2832 S. 39" Street Plaintiff and
01/2024 Omaha, NE 68105 Defendant
06/2020- 1713 Holmes Street Plaintiff
12/2021 Omaha, NE 68107
12/2017- 907 Castelar Street Plaintiff and
05/2020 Omaha NE, 68108 Defendant
b) Plaintiff knows of no 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.
c) Plaintiff does not know the names and addresses of any persons
other than the Defendant and Plaintiff who have a claim of right to
physical custody of the children or a claim to parenting time with
the children.
Defendant is capable of providing support for the children and
child support should be calculated in accordance with the current
Nebraska Child Support Guidelines.
10. Defendant is capable of providing medical coverage for the minor
children, and the Court should order such coverage as deemed
appropriate.
Il Defendant is capable of paying unreimbursed medical expenses of
the minor children, and the Court should determine and order such
expenses to be paid as deemed appropriate.
12 Defendant is capable of paying child care expenses of the parties’
minor children, and the Court should determine and order such
expenses to be paid as deemed appropriate.
13. Plaintiff requests this proceeding be heard by a district court judge.
14. There are no existing restraining orders, protection orders, or
criminal no-contact orders regarding the other party.
15 A Parenting Plan has not been developed.
16 Child custody, parenting time, visitation or other access, and child
support are contested.
WHEREFORE, The Plaintiff respectfully requests that
this Court finds that the Defendant is the natural father of the
minor children and thereby enters an Order Establishing Paternity;
awards Plaintiff sole legal and sole physical custody of the children
of the parties; award child support in accordance with the,
Nebraska Child Support Guidelines and grant any further relief
that Court deems relevant in the premises.
Dated this 4_ day of ie _, 2024.
By: Elaine D’ Amato #20974
Legal Aid of Nebraska
209 S. 19" Street, Ste. 200
Omaha, NE 68102
(402 )938-5070
edamato@legalaidofnebraska.org
Attomey for Plainitff
Vanessa Flores-Bustamante, being on oath first duly swom,
deposes and says that she/he is the Plaintiff in this action; she/he
knows the contents of the foregoing Complaint, and the statements
therein contained are true.
‘Vanessa Flores-Bustamante
SUBSCRIBED and sworn to before me this lp th day of
Sune, 2024.
on
Lae
Notary Public
GENERAL NOTARY - State of Nebraske
‘SUSAN M. WILLIS
hy Comm. Exp. April 9, 2028
Preview
InN IN THE DISTRICT COURT FOR DOUGLAS COUNTY, NEBRASKA Case No. Cl 24 - Hy} 34 VANESSA FLORES-BUSTAMANTE, PLAINTIFF, COMPLAINT FOR PATERNITY, CUSTODY, vs. AND ALLOWANCES ARMANDO SANTANA ALONZO DEFENDANT. ~~ ~ COMES NOW, Vanessa Flores-Bustamante, by and through her attorney, Elaine D’ Amato of Legal Aid of Nebraska, and files her Complaint for Paternity, Custody, and Allowances. In support thereof, Plaintiff presents the following information to the Court: 1 Plaintiff lives at 1713 Holmes Street in Douglas County, Omaha, Nebraska 68107. The Defendant lives at 2832 South 39th Street in Douglas County, Omaha, Nebraska 68105. The Parties were never married. However, during the time of conception of the minor children, the parties were involved in an intimate relationship and the Plaintiff became pregnant and gave birth to the minor children, to-wit: Elayna Santana Bustamante, bom 2017, and Adilene Santana Bustamante, born in 2018. The minor children of the parties have lived in the State of Nebraska for at least five years. Neither the Plaintiff nor the Defendant is a member of the Armed Forces of the United States or its allies. Paternity of the above-named minor children has not been established. The Plaintiff is the fit and proper person to have the care, custody, and control of the minor children, subject to the reasonable supervised visitation by the Defendant. The following information is provided in compliance with the requirements of the Uniform Child Custody Jurisdiction and #7 Enforcement Act: DOUGLAS COUNTY, NEBR ASKA JUN 0 6 2024 CLERK DISTRICT CouRT a) For the last five years, the children’s addresscs and persons they have lived with are: DATES ADDRESS WITH WHOM 01/2024 1713 Holmes Street Plaintiff - Present Omaha, NE 68107 12/2021- 2832 S. 39" Street Plaintiff and 01/2024 Omaha, NE 68105 Defendant 06/2020- 1713 Holmes Street Plaintiff 12/2021 Omaha, NE 68107 12/2017- 907 Castelar Street Plaintiff and 05/2020 Omaha NE, 68108 Defendant b) Plaintiff knows of no 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. c) Plaintiff does not know the names and addresses of any persons other than the Defendant and Plaintiff who have a claim of right to physical custody of the children or a claim to parenting time with the children. Defendant is capable of providing support for the children and child support should be calculated in accordance with the current Nebraska Child Support Guidelines. 10. Defendant is capable of providing medical coverage for the minor children, and the Court should order such coverage as deemed appropriate. Il Defendant is capable of paying unreimbursed medical expenses of the minor children, and the Court should determine and order such expenses to be paid as deemed appropriate. 12 Defendant is capable of paying child care expenses of the parties’ minor children, and the Court should determine and order such expenses to be paid as deemed appropriate. 13. Plaintiff requests this proceeding be heard by a district court judge. 14. There are no existing restraining orders, protection orders, or criminal no-contact orders regarding the other party. 15 A Parenting Plan has not been developed. 16 Child custody, parenting time, visitation or other access, and child support are contested. WHEREFORE, The Plaintiff respectfully requests that this Court finds that the Defendant is the natural father of the minor children and thereby enters an Order Establishing Paternity; awards Plaintiff sole legal and sole physical custody of the children of the parties; award child support in accordance with the, Nebraska Child Support Guidelines and grant any further relief that Court deems relevant in the premises. Dated this 4_ day of ie _, 2024. By: Elaine D’ Amato #20974 Legal Aid of Nebraska 209 S. 19" Street, Ste. 200 Omaha, NE 68102 (402 )938-5070 edamato@legalaidofnebraska.org Attomey for Plainitff Vanessa Flores-Bustamante, being on oath first duly swom, deposes and says that she/he is the Plaintiff in this action; she/he knows the contents of the foregoing Complaint, and the statements therein contained are true. ‘Vanessa Flores-Bustamante SUBSCRIBED and sworn to before me this lp th day of Sune, 2024. on Lae Notary Public GENERAL NOTARY - State of Nebraske ‘SUSAN M. WILLIS hy Comm. Exp. April 9, 2028