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HomeMy WebLinkAbout09-7676JILL RETTIG, THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CHRISTOPHER JENKS, CIVIL ACTION LAW - LAW Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, Jill Rettig, Pro Se, and makes the following Complaint for Custody: The Plaintiff is Jill Rettig, an adult individual residing at 1020 Hemlock Lane, Enola, Cumberland County, Pennsylvania, 17025. 2. The Defendant is Christopher Jenks, an adult individual, who currently resides at 118 Kim Acres Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. The Plaintiff and Defendant were never married and one (1) child was born out of wedlock as a result of this relationship, who is the subject of this action, namely: 1 Kyliegh Anne Rettig-Jenks, Date Of Birth- 04/06/2000 4. Plaintiff seeks physical and legal custody of the minor child, Kyliegh Anne Rettig-Jenks. 5. The minor child is presently in shared custody. 6. During the past five (5) years, the minor child has resided with the following persons at the following addresses: Jill Rettig 1090 Pleasant Grove Road, York Haven, PA, 17370 April 2006-June 2008 Christopher Jenks Matthew Jenks Jill Rettig 6 Pocono Drive, Mechanicsburg, PA, 17055 June 2008-February 2008 Christopher Jenks Matthew Jenks Virginia Jenks John Jenks Jill Rettig 118 Kim Acres Dr, Mechanicsburg, PA, 17055 Febuary 2008-October 2009 Christopher Jenks Matthew Jenks 7. The natural mother of the minor child is the Plaintiff. 8. The natural father of the minor child is the Defendant. 9. The Plaintiff has not participated as a party or in any other way in any litigation concerning the custody of the minor child in this or any other court, except for this instant custody action. 10. The Plaintiff has no information of a custody proceeding concerning the minor child pending in a court of this or any other jurisdiction. 11. Plaintiff knows of no other person not a party to this action already who has physical custody of or claims to have custody or visitation with the said minor child. 12. Plaintiff believes that the best interest of the minor child would be served if sole physical and legal custody is awarded to mother, the Plaintiff and Dependant herein. 13. Each parent whose parental rights to the child have not been terminated and the person who has the physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff, Jill Rettig requests this Honorable Court to award sole physical and legal custody of the minor child, Kyliegh Rettig-Jenks. Respectfully submitted, Date: 't-- L9 -0 By ill Rettig, o Se VERIFICATION I, Jill Rettig, hereby verify that the statements of fact made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: --? - ?? Do i-i Jill ettig JILL RETTIG, IIN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. CHRISTOPHER JENKS, CIVIL ACTION LAW - LAW Defendant IIN CUSTODY CERTIFICATE OF SERVICE I, Jill Rettig, Pro Se, hereby certify that a true and correct copy of the foregoing Complaint was sent by United States mail, postage prepaid, certified mail, return receipt requested, to the following: Christopher Jenks 118 Kim Acres Drive Mechanicsburg, PA 17055-5533 Christopher Jenks c/o PowersAuto Repair 53 Springer Lane New Cumberland, PA 17070-2456 C'*'?? k?e'? Jill ttig, Pro Se Date: t `, ly --C)C1 FILE C r 2009 NOv -6 PH I : r ?ics.sv7d I?L?? JILL RETTIG IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER JENKS DEFENDANT 2009-7676 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, November 19, 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 Tuesday, December 15, 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 ofa temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Hubert X. Gilroy, Es q. 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 infonnation 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 RLED-Offrifulc OF THS PRMHONOTARY" 2009 NOV 19 PM 12: 19 PENNSYLVANIA