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Home My WebLink About09-3775 SALINA L. GILLIS Plaintiff VS. ALEXANDER F. GILLIS, III Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. o 9 - 3 71 s ?uwl CIVIL ACTION -LAW CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Salina L. Gillis, residing at 643 Cedar Ridge Lane, Mechanicsburg, PA 17055. 2. The defendant is Alexander F. Gillis, III, residing at 322 Shuey Road, New Cumberland, PA 17070. 3. Plaintiff seeks custody of Chase A. Gillis, born November 6, 2001. 4. The child was born out of wedlock. The parties currently share physical custody of the child on a week on week off basis. 5. For the past five years, the child has resided with the following persons at the following addresses: Custodian Salina L. Gillis Salina L. Gillis Alexander F. Gillis, III Address 643 Cedar Ridge Lane Mechanicsburg, PA 17055 322 Shuey Road Harrisburg, PA Dates 10/08 - present 05/04 -10/08 6. The mother of the child is Salina L. Gillis who currently resides at 643 Cedar Ridge Lane, Mechanicsburg, Pennsylvania. She is currently married to defendant. 7. The father of the child is Alexander F. Gillis, III, currently residing at 322 Shuey Road, New Cumberland, Pennsylvania. He is currently married to plaintiff. 8. The plaintiff currently resides with her boyfriend, Todd Harris, his two children, Dylon and Rylie Harris, and Chase A. Gillis. 9. It is believed that the defendant currently resides his girlfriend, Jessica Sears, and her two children, Caleb and Chloe. 10. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 11. The plaintiff has no information of a custody proceeding concerning the child pending in a court in this Commonwealth or in any other court. 12. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 13. The best interest and permanent welfare of the child will be served by granting primary physical custody of the children to mother. 14. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, plaintiff requests this Court to award her primary physical custody of Chase A. Gillis. Respectfully submitted, J,Zh a H. Rehkamp, Esquire k4er and O'Connell North Front Street Harrisburg, PA 17110 (717) 232-4551 SALINA L. GILLIS IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. ALEXANDER F. GILLIS, III CIVIL ACTION -LAW Defendant CUSTODY Verification I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 19 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Date: )09 RLED-OFFICE OF THE PROTHONOTARY 2009 JUN -S PM 1: 13 P- I lp /1?/ ?t I $S. 6o P 0 ATrY RTI a ac.36.1 SALINA L. GILLIS PLAINTIFF V. ALEXANDER F. GILLIS, III DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-3775 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, June 11, 2009 , upon consideration of the attacl it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, E at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, July 09, 2009 for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the i if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enti order. Failure to appear at the conference may provide grounds for entry of a temporary or permai The court hereby directs the parties to furnish any and all existing Protection from A Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled heal FOR. THE COURT. By: /s/ ac ueline M. Verne Es .6r- Custody Conciliator I Complaint, ?. , the conciliator, at 9:30 AM aes in dispute; or into a temporary 1t order. ng. orders, The Court of Common Pleas of Cumberland County is required by law to comply ith the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must at end the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF Y U DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OF ICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ZQ04 JUN I ! PM 2: 25 ryi J?A 0. Y SALINA L. GILLIS, Plaintiff V. ALEXANDER F. GILLIS, III, Defendant, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.: 2009-3775 Civil Term CIVIL ACTION - LAW IN CUSTODY TO THE PROTHONOTARY OF CUMBERLAND COUNTY: ENTRY OF APPEARANCE Please enter my appearance on behalf of the Defendant, Alexander F. Gillis, III, in the above captioned custody case. Respectfully submitted, Law Office of Joseph L. Hitchings T seph L. itchings, 1? e Attorney ID # 65551 5000 Ritter Road, Suite 202 Mechanicsburg, Pennsylvania 17055 (717) 458-8123 (717) 790-6019 Fax Attorney for Defendant w SALINA L. GILLIS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No.: 2009-3775 Civil Term ALEXANDER F. GILLIS, III, CIVIL ACTION -LAW Defendant, IN CUSTODY CERTIFICATE OF SERVICE I, Joseph L. Hitchings, Esquire, hereby certify that the following service has been completed in compliance with the Pennsylvania Rules of Civil Procedure: Via first class US mail postage pre-paid Johanna H. Rehkamp, Esquire Turner And O'Connell 4701 North Front Street Harrisburg, PA. 17110 Jacqueline M. Verney, Esquire 44 S. Hanover Street Carlisle, PA 17013 Respectfully submitted, Law Office of Joseph L. Hitchings seph L. itchings, squire Attorney ID # 65551 5000 Ritter Road, Suite 202 Mechanicsburg, Pennsylvania 17055 (717) 458-8123 (717) 790-6019 Fax Attorney for Defendant PILED-dr rlt'."E OF THE Ppo-? 2009 JUN 26 PM I , 02 PENNSYLVANIA