Fred J. Pettid - Page 5




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                  On April 20, 1992, Ms. Wagner filed a petition against              
             petitioner in the district court.  Ms. Wagner's petition                 
             alleges in pertinent part as follows:                                    

                       3.  During the years 1981 and 1982, Pettid                     
                  dated and courted Bartling [viz, Wagner].                           
                       4.  During the courtship, Bartling was a                       
                  single person, having been legally divorced from                    
                  a previous marriage.                                                
                       5.  At all times during the courtship,                         
                  Pettid represented himself to Bartling as a                         
                  single person, who had been divorced pursuant                       
                  to a dissolution of a previous marriage.                            
                       6.  During the courtship, Pettid estab-                        
                  lished himself in a position of trust and                           
                  confidence with Bartling which resulted from                        
                  the courtship relationship.                                         
                       7.   In or around August, 1981, Pettid                         
                  asked Bartling to marry him, promising to marry                     
                  her and cohabitate as husband and wife.                             
                       8.   Bartling accepted the good faith of                       
                  Pettid and relied upon his representation to her                    
                  that he was legally capable of entering into an                     
                  agreement to marry her.  Bartling, therefore                        
                  having reasonably and justifiably given Pettid                      
                  her trust and confidence, and accepting his good                    
                  faith, agreed to marry Pettid pursuant to his                       
                  proposal.                                                           
                       9.   In anticipation of her planned marriage                   
                  to Pettid, and with Pettid's knowledge and                          
                  encouragement, Bartling resigned her employment                     
                  in the Fall of 1981.                                                
                       10. In anticipation of her planned marriage                    
                  to Pettid, and with Pettid's knowledge and                          
                  agreement, Bartling sold her residence in the                       
                  Fall of 1981 and moved into her parents' house,                     
                  planning to remain a resident there until the                       
                  marriage was solemnized.                                            





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