Soxeu aun een 1 rn 12 13 14 15 16 7 18 19 20 2 22 23 24 25 26 27 28 Silverman Kettelman ‘Springgate, Chi (773) 322-3223 Pax (79) 322.3649 FILED Electronically DV19-00417 Jacqueline Bryant| Clerk of the Court Code: Gary R. Silverman (NSB# 409) Michael V, Kattelman (NSB#6703) Transsation'# 7168072; ‘John P. Springgate (NSB# 1350) Alexander C. Morey (NSBA#:1236) ‘Tamatha Schteinert (NSBe10438) Kenton C. Karrach (NSB#13515) Benjamin K Albers (NSB#in85; Silverman Kattelman Speinggate, Ch {500 Damonte Ranch Pavlova, Suite 675 Reno, Nevada 89521 ‘Telephone 776)32 Facsimile: T7932 ‘Atlorneys for Wendy Marie Carry IN THE FAMILY DIVISION OF THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA| IN AND FOR THE COUNTY OF WASHOE WENDY MARIE CARRY, Plaintiff, Case No. vs. Dept. DENNIS BRYAN CARRY, and CARLA BALDWIN CARRY, and DOES 1-X, inclusive, Defendants, / ED COMPLAINT FOR DIVORCE (WITHOUT MINOR CHILDREN) AND OTHER CLAIMS COMES NOW, WENDY CARRY, by and through counsel and avers as follows: FIRST CAUSE OF ACTION (DIVORCE) 1, JURISDICTION OF THE COURT. Wendy Carry (“Wife”) and Deni Carry (“Husband”) are residents of the State of Nevada. For a period of more than si VERIF. weeks before commencement of this action, Husband and Wife have resided in the Stat of Nevada, and now reside and are domiciled here. During all of the period of resideney| Wife had, and still has, the intent to make the State of Nevada her home, residence, an domicile for an indefinite period of time. Page 1 0f 7 2019-03-15 02:07:40 PM jiloria28 Silverman Katetman Springgate, Cid (73) 302.3223, Fax (775) 322-3689 Carla Baldwin Carry is a resident of the State of Nevada. Ms. Carry owns rei property with Husband in joint tenancy, such property being a s ibject of thes proceedings, and is named as a Defendant in this action for the purpose of preserving th estate(s) of Husband and Wife. Carla Baldwin Carry appears to be holding, possessing, or claiming an interest in property in which Husband and Wife have a financial interest. 2, DOE DEFENDANTS. ‘The true names and capacities of the Doe Defendant: are unknown to Plaintiff at this time, Plaintiff is informed and believes that each of th Doe Defendants is or has been the officer, director, partner, trustee, agent, servant, employee, principal or alter ego of one or more of the other Defendants, or was a person, firm or corporation which did, or participated in the acts or omissions hereinafter described; or otherwise own, hold, or have possession of property and income of th community, and at such time as their true names and capacities become known to Plaintiff, Plaintiff will seek to amend the Complaint to insert the true names and capacities of the Doe Defendants. The Doe Defendants are herewith served in all such] capa ities as well as individually. MARRIAGE. Husband and Wife were married in South Lake Tahoe} California on November 30, 1996. 4. PURPORTED MARRIAGE OF CARLA BALDWIN CARRY AND DENNIS BRYAN CARRY. Carla Baldwin Carry and Dennis Bryan Carry entered int ceremony purportedly to marry on May 24, 2018 in California, while Wendy Marie Carr; and Dennis Bryan Carry continued to be married. Wendy Marie Carry and Dennis Bryan] Carry continue to be married and were never divorced. The purported marriage betweer Carla Baldwin Carry and Dennis Bryan Carty is not a valid marriage. On March 1, 2019, Carla Baldwin Carry and Dennis Bryan Carry filed a Join Petition for Annulment in Case No, DV19-00347 in the Second Judicial District Court of the State of Nevada, Plaintifi-Wife, Wendy Marie Carry, neither signed a joint petition for divorce with Husband, nor participated in prior divorce proceedings with Husband, and it appears Husband created documents referenced as “Case No. DV18-00651” in al Page 2 0f 7Cer aun en 10 uM 12 13 14 15 16 17 18 19 20 24 22 23 24 25 26 27 28 Silverman Kattan ‘Springgnie, Cid (715) 32-3225, Fax (775) 322-3649 fraudulent manner to convince Carla Baldwin Carry and others that he was divorced from Wendy Marie Carry, although Husband remains married to Plaintiff: Wite. 5. COMMUNITY PROPERTY AND DEBTS. Community property and| debts exist and should be awarded and assigned pursuant to law. 6. 1675 VERDI VISTA COURT, RENO, NEVADA 89523. Carla Baldwin Carry and Dennis Bryan Carry purchased real property located at 1675 Verdi Vista Court, Reno, Nevada 89523. Dennis Bryan Carry purchased this property during his marriage |to Wendy Marie Carry, and Wendy Marie Carry has a community interest in the property} located at 1675 Verdi Vista Court, Reno, Nevada 89523. 7 SEPARATE PROPERTY AND DEBTS. Separate property and debts may exist, They should be awarded and assigned pursuant to law. 8. GROUNDS FOR DIVORCE. The parties are incompatible in marriage. 9. SPOUSAL SUPPORT. Wife may require spousal support, including spousal support from such date this Court deems just, in a reasonable amount and for a reasonable duration according to law. 10, LITIGATION FEES AND COSTS. Litigation fees and costs should awarded pursuant to Nevada law. u. NAME, Wendy Maric Carry wishes to be restored to her former name Wendy Marie Blevins. 12, RESERVATION OF CLAIMS. If upon further discovery Wife learns of facts showing Husband wasted community assets, unjustly enriched himself, or has acted in a way causing economic harm to the community estate or Wife's separate estate, Wife reserves her right to assert such claims. SECOND CAUSE OF ACTION (BREACH OF FIDUCIARY DUTY) 13. Wife realleges and restates each and every allegation in paragraphs 1-13 a4 though fully set forth at this point. Page 3 of 7