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Silverman Kuttelnan ‘Springaste, Ch (773) 30-3023 Fax (78) 322-3649 FILED Electronically Dv19-00417 2019-03-15 02:07:40 Jacqueline Bryant cose Clerk of the Court Gary 8. Stverman (NSBs 409) Michal ¥, Kattlian (NSB#6709) Transaction #7108072 tha P Springate (NSDeIg50) Alexandr C Movey (NSBe11216) rama Sehreinest (NSBev0496) Kenton C. Karasch (NSBAI9515) Benjamin & Albers (NSBeN695) Siverman Kattlman Springgte, Chi 500 Damonte Raich Park, Sule 675 Reno, Nevada 89521 Telephone: 775/322-9223, Foca Tysfsae 3649 atime for Wendy Mae 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. ef VERIFIED 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 Dennis, Carry (“Husband”) are residents of the State of Nevada. For a period of more than si ‘weeks before commencement of this action, Husband and Wife have resided in the Stat. lof Nevada, and now reside and are domiciled here. During all of the period of residency, 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 10f7 M pitoria 28 Silverman Kalman ‘Springgate, Ch. (778) 322.3223, Pax (775) 3223649 Carla Baldwin Carry is a resident of the State of Nevada, Ms. Carty owns real property with Husband in joint tenancy, such property being a subject of thesq proceedings, and is named as a Defendant in this action for the purpose of preserving the 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 Defendants are unknown to Plaintiff at this time. Plaintiff is informed and believes that each of the Doe Defendants is or has been the officer, director, partner, trusts » agent, servant, employee, principal or alter ego of one or more of the other Defendants, or was a pers: mn} 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 t Plaintiff, Plaintiff will seek to amend the Complaint to insert the true names andl capacities of the Doe Defendants. The Doe Defendants are herewith served in all such} capacities as well as individually. 3 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 into a ceremony purportedly to marry on May 24, 2018 in California, while Wendy Marie Carrs 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 between Carla Baldwin Carry and Dennis Bryan Carry 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 o the State of Nevada. Plaintiff-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 a Page 2 0f 7 Cer aneon 10 iL 12 13 14 15 16 7 18 19 20 2 22 23 24 25 26 27 28 Silverman Kattan Springzats, Ch (773) 372-3023 Fax (175) 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-Wife. 5. COMMUNITY PROPERTY AND DEBTS. Community property and debts exist and should be awarded and assigned pursuant to law. 6. SS wed WBS RENO, NEVADA 89523. Carla Baldwin} Carry and Dennis Bryan Carry purchased real property located at agjgy Gah TABLE Reno, Nevada 89523. Dennis Bryan Carty purchased this property during his marriage to Wendy Marie Carry, and Wendy Marie Carry has a community interest in the property| located atdiy WP WEB WEB Reno, Nevada 89523. 7. SEPARATE PROPERTY AND DEBTS. Separate property and debt 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 reasonable duration according to law. 10. LITIGATION FEES AND COSTS. Litigation fees and costs should bx awarded pursuant to Nevada law. 1, NAME, Wendy Marie Carry wishes to be restored to her former name o Wendy Marie Blevins. 12, RESERVATION OF CLAIMS. If upon further discovery Wife learns lof 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 ay ‘though fully set forth at this point. Page 3 of 7

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