The URL can be used to link to this page

Home My WebLink About06-6123 vs. : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. ()(,.... '1:1-3 Civil Term JUSTIN M. GALLO, Plaintiff AMANDA TRITT, : ACTION IN CUSTODY Defendant CUSTODY COMPLAINT 1. Plaintiff is Justin M. Gallo, who currently resides at 175 Whitmer Road, Shippensburg, Cumberland County, Pennsylvania, 17257. 2. Defendant is Amanda Tritt, who currently resides at 512 Meadow Drive, Shippensburg, Cumberland County, Pennsylvania, 17257. 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 1012104 (2) 512 Meadow Drive Shippensburg, Pa. 17257 Mother and Father were never married. Mother currently has primary physical custody of the child. During the past five years, the children have resided with the following persons and at the following addresses: NAME ADDRESSES DATES Amanda Tritt Justin M. Gallo 175 Whitmer Drive Shippensburg, Pa. 17257 10/2/2004 to 2/05. Amanda Tritt Justin M. Gallo 512 Meadow Drive Shippensburg,Pa.17257 2/05 to 8/05 Amanda Tritt And boyfriend Jesse half-sibling born 6/06. 512 Meadow Drive Shippensburg,Pa.17257 8/05 to present. . The mother of the child is Amanda Tritt. She currently resides at 512 Meadow Road, Shippensburg, Pa., 17257. She is not married. The father of the child is Justin Gallo. He currently resides at 175 Whitmer Road, Shippensburg, Pa., 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 Gallo. 5. The relationship of defendant to the child is that of Mother. The persons that the Defendant currently resides with are: her boyfriend. and her other 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. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a party to the proceedings who has physical custody of the child or anyone who 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 parties separated in August. 2005. Mother has not permitted Father to have contact with the child since March 6. 2006. Father is requesting a custody Order that would ensure that he would have liberal periods of partial custody with the child. It would be in the best interest of the child for Father to maintain contact with his daughter. 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. Respectfully submitted, Date: IlJ!q /be VERIFICATION I verify that the statements made in this Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: /0-//-0 ro A%~ # f;t1-/4 Ju~ M. Gallo, Plaintif ~ ~ ~. ~. ...... ~ ~t9 ~ ~ ~ "-J ~ \~ , . ~ ~~ f)':J &~ ~'fj .~ . ~ (") r-= l:1~ !TItr.? '"7'L ~~..fL (/) ,i ~- ~.~~i' z ~ ,.." ~ ~ g i! --l mi _ -0 \.0 ;Q U ,-~ ..,., ::-:: .,.., ::::&:: c> :::D 20 _ Om . . ---t ~ ~ ~ JUSTIN M. GALLO PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-6123 CIVIL ACTION LAW AMANDA TRITT DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, October 31, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, December 08, 2006 , the conciliator, at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort wilI 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. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or penn anent 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 hearinl!. FOR THE COURT. By: /s/ Hubert X Gilroy. Esq. 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 A TTORNEY AT ONCE. IF YOU DO NOT HA VE 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 _ ~ ~'#--: ~ '41 ~;k t ~ ~ -nl jp 1- ~~-p;; 9(J'}e'11 11~ Ie-II 1rJ'~/1 --- :.-C'Mn." ",. \1 ~ It...) fJ ~ :21 Hd 12 .I, n'I'l oriU Pl',' 1 JUvu NOV 29 2006 JUSTIN M. GALLO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW AMANDA TRITT, Defendant NO. 2006-6123 IN CUSTODY COURT ORDER .ct AND NOW, thisd f"" day of November, 2006, the Conciliator being advised the Plaintiff will be withdrawing the Complaint, the Conciliator relinquishes jurisdiction. VINVi\lASNN3d 1 !Nnn'~1 'O';.r",,':;qW{'v', tv... ',_ ',' , " ""(,f ~l hJ 9t :z ~Id 1- 3309GOl AtlV10NOrl108d 3111 .:IO 3Ol:!=\0-0318 JUSTIN M. GALLO, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 06 - 6123 Civil Term AMANDA TRITT, : CUSTODY Defendant PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: AND NOW, this cF- day of ~ bv ,2006, please mark the above-captioned case Discontinued. Respectfully Submitted, Date: / d,!Lf /0 ~ a e Adams, Esquire 6 S. Pitt St. arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF (') c -" .......,~ -ace ~""'f1 'r'{'; 'z.e~,.-, -7) f.nY =<;." \:..;:1: ~~t: ~Z _..l / -, ~ ~ o (""'1"1 c-> \ - ..... ""0 ::1C ~ :i!'"1"I f\"~ :B\;J QIQ, :C-n (") -(") -;7 rn o -\ ~ ~ o tv