HomeMy WebLinkAbout09-7126
JUSTIN M.. GALLO,
Plaintiff
vs.
AMANDA TRITT,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: No. 09. ?/.Z4 Civil Term
IN CUSTODY
CUSTODY COMPLAINT
1. Plaintiff is Justin M. Gallo, (hereinafter referred to as "Father"), who currently
resides at 175 Witmer Road, Shippensburg, Cumberland County, Pennsylvania, 17257.
He is twenty-three (23) years old.
2. Defendant is Amanda Tritt, (hereinafter referred to as "Mother"), who currently
resides at 473 King Street, Shippensburg, Cumberland County, Pennsylvania, 17257.
She is twenty-three (23) years old.
3. Plaintiff is the Father of the following child and seeks a custody Order
regarding the following child:
NAME DOB/AGE ADDRESS
Trinity Larae Gallo 10/2/04 473 King St., Shippensburg, Pa. 17257
Mother currently has primary physical custody of the child.
During the past five years, the child has resided with the following persons and at
the following addresses:
NAME ADDRESSES DATES
Amanda Tritt 473 King St. 2006 - 2009
Josh Weaver Shippensburg, Pa. 17257
Jesse Straitifs (Cumberland County)
Amanda Tritt 512 Meadow Dr. 2004 - 2006
Shippensburg, Pa. 17257
(Franklin County)
The mother of the child is Amanda Tritt. She currently resides at 473 King
Street, Shippensburg, Cumberland County, Pennsylvania, 17257. She is not married.
The father of the child is Justin Gallo. He currently lives at 175 Witmer Road,
Shippensburg, Cumberland County, Pennsylvania, 17257. He is not married.
4. The relationship of plaintiff to the child is that of Father. The plaintiff currently
resides with his mother, Lori Witmer.
5. The relationship of the defendant to the child is that of Mother. The defendant
currently lives with the child.
6. 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 other than as
follows: There was a prior complaint and court Order issued in Franklin County, under
docket no. FR 2006 - 3561 on April 26, 2006. Neither party now lives in Franklin
County, and Father is requesting this case proceed in Cumberland County
Other than as provided herein, Plaintiff has no information of a custody
proceeding concerning the child pending in a court of this Commonwealth or any other
state.
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.
7. The best interest and permanent welfare of the child will be served by granting
the relief requested because: The prior court Order provided minimal physical custody for
Father. The child is now older, and Father is more mature and more stable. Father is also
extremely concerned about Mother's living situation and the many roommates she has had
in her home over the past few years. Father is requesting primary custody of the child as
he believes this would be in the best interest of the child at this time.
8. Each parent whose parental rights to the child have not been terminated and
the person who has physical custody of the child has been named as parties to this
action.
WHEREFORE, Plaintiff requests the court to enter a custody Order regarding the
child.
Date:
c?
Respectfully submitted,
d"a a Adams, Esquire
I. V. No. 79465
W. South St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
VERIFICATION
I verify that the statements made in this Petition are true and correct.
I understand that false statements herein are made subject to the penalties of 18
Pa.C.S. §4904 relating to unsworn falsification to authorities.
Date: A0 A G
Ju n M. Gallo, P aintiff
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JUSTIN M. GALLO IN THE COURT OF COMMON PLEAS OF
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
V.
AMANDA TRITT
DEFENDANT
2009-7126 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, October 27, 2009 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, December 03, 2009 at 10:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custodv orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: /s/ Hubert X. Gilroy, Es q. ,CA
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with 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 attend the scheduled
conference or hearing.
YOU SHOULD TAKE. THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE 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
OF THE ITH, ' 7ARY
2009 OCT 27 Pty 2., 4 I
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