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Soe aaueoen W 12 3 14 15 16 7 18 19 20 ai 24 25 26 Kuz JUN 13.208 EG L. ALLISON Kei Groenke Chere of District Law Office of Kai Groenke, P.C. By 239 2" Street West Olerds P.O. Box 3098 . Kalispell, MT 59903-3098 Telephone: (406) 890-2999 kai@ Attomey for Petitioner MONTANA ELEVENTH JUDICIAL DISTRICT COURT, FLATHEAD COUNTY. IN RE THE MARRIAGE OF: Cause No, DR-18-474 NINA KOUPRIIANOVA, Petitioner, | 4 FRIDAVIT OF N.K. IN SUPPORT OF and EX PARTE MOTION RICHARD B. SPENCER Respondent. NK., deposes and says: 1. Lam the Petitioner in this matter, Respondent R.S. and I are parents to two (2) minor children, C.N.S. (age 3) and M.A.S. (age 7 mos.). 2. RS. and I have been married since August 31, 2010 and living separately since July 1, 2017. 3. RS. has been verbally, physically, and emotionally abusive towards me throughout our marriage, Our children have been repeatedly exposed to this abuse. 4, Attached hereto as Exhibit 1 is an approximately 66-page summary of physical violence and emotional, verbal, and financial abuse of me by R.S. and negligent Page 1 ee a awe 10 ra 12 13 4 15 16 17 18 19 20 21 22 23 24 25 26 behavior by him that I believe creates a risk of emotional, mental, and physical harm to our children. 1 prepared this summary in anticipation of divorce litigation. Included in the summary are various documents labeled as sub-exhibits and referenced in the summary statement. ‘To summarize Exhil 1, RS. has engaged in physical violence toward me, including, ut not limited to: a. January 2011 —he dragged me out of bed and down the stairs by my legs, arms, and hair, and threw me on the couch, resulting in bruises. See sub- exhibit 20, emails between R.S. and me documenting the incident, b. July 2014 — he attacked me when I was four months pregnant with our first child, where he held me down with his body weight and held me by my neck and lower jaw, causing bruising. See sub-exhibit 21, emails between R'S. and me where he acknowledges hurting me and states, “I feel terrible.” See also sub-exhibit 22, photos of the bruising on my chest and leg taken at Teast a week after the incident. ©. October 2017 — R.S. entered my residence to visit our daughter, became irate, and attempted to punch me in the face, which made me back into the kitchen stove, so as to avoid him. This occurred when I was nine months pregnant with our second child. See sub-exhibit 24, a transcript of a recording I made of the incident. See also sub-exhibit 25, my efforts to report the violence to the National Domestic Abuse Hotline chat and seek a safety plan because I was going into the hospital for a c-section for the birth Page2 Cow aw ew DH 10 ul 12 1B 14 15 16 7 18 19 20 21 22 23 24 25 26 of our second child and I did not know if R.S. would become violent. In fact, much of my second pregnancy was extremely stressful. See sub-exhibit 27, a note from my OBGYN stating that I expressed concern for my safety ‘on numerous occasions during doctor's visits. d. February 2018 — after attending mediation with Randy Schwickert, R.S. grabbed, pulled and held me by my hair in the car in the parking lot of my residence. He entered the apartment without asking, tried to attack me again, and physically attacked his mother by shoving her into the wall, She was babysitting our children. R.S. and his mother took my phone away when I tried to record the incident for my own safety. R.S. and his mother then left the residence with our three-year-old daughter and our dog, handing back my phone on the way out, I sent text messages to some of the people closest to me to document the violence out of fear that something bad would happen to me in the near future, See sub-exhibit 26, text messages to fiiend and confidant to document the abuse, ©. One of RS.’s favorite statements to me was, “The only language women understand is violence.” RS. has engaged in behavior intended to intimidate me and break me down emotionally and mentally, including, but not limited to: a. He repeatedly woke me up in the middle of the night or prevent me from going to sleep. This usually occurred between the hours of 12:30 am and 3:00 am. On these occasions, R.S. interrogated me, as he blocked the Page 3