ComplaintChild Custody

In the General Court of Justice

District Court Division
File NO. 1234

North Carolina
Gaston County

_________ _______

Jill A. Adams
Plaintiff
vs.
Jack B. Adams
Defendant
COMPLAINT

The Plaintiff, complaining of the Defendant, alleges and says,

1. That the Plaintiff is a citizen and resident of 987 S. Ridell Avenue, Gastonia, Gaston County, North Carolina and
the Defendant is a citizen and resident of Gaston County, North Carolina. That the Plaintiff [or, Defendant] has been
a resident of the State of North Carolina for at least six months next preceding the filing of this action.
2. That the Plaintiff and Defendant were married on the first day of January, 1998, in Gastonia NC, and lived
together as husband and wife until on or about the first day of September, 2014, when they separated.
3. That since September 1, 2014, the Plaintiff and Defendant have lived continuously separate and apart from each
other and have at no time resumed the marital relationship which formerly existed between them.
4. That two children were born of said marriage, to-wit:
1.Lincoln C. Adams 14, born on 12/03/2001
2. Anna D. Adams 9, born on 10/18/2006
5.This is a claim for custody of the minor child(ren) named above. Attached hereto and incorporated herein is a
completed Affidavit as to Status of Minor Child (AOC-CV-609) for each child set forth above.
6. Children named above have been living with the Plaintiff since separation on September 1, 2014.
7. The District Court of Gaston County, North Carolina has personal jurisdiction over the parties and subject matter
jurisdiction (including jurisdiction under the Uniform Child Custody Jurisdiction and Enforcement Act) to decide the
claims and render a custody determination in this action.
8. Venue of this action is proper in Gaston County, North Carolina

Custody Claim

9. The Plaintiff is a fit and proper person to have custody of the minor child(ren) named above, and an
award of custody to the Plaintiff would be in the best interests and welfare of the named child(ren).

Prayer For Relief

1.
case;

Accept this verified Complaint as the Plaintiffs affidavit upon which the Court may base all of its Orders in this

2. Wherefore, the Plaintiff agrees that the defendant is a good father, but Plaintiff is requesting sole
physical and legal custody of the children. The Plaintiff agrees that the defendant can have reasonable
visitation.
06/26/2016
Jill A. Adams
987 S. Ridell Avenue,
Gastonia NC 28000
704-657-3409

Paul Mitchell
Attorneys for Plaintiff
190 E Walter Ave
Gastonia, NC 28056
704-789-0987

STATE OF NORTH CAROLINA

)
)

VERIFICATION

COUNTY OF GASTON

I, Jill A. Adams, being first duly sworn, deposes and

says that he/she is the Plaintiff in this matter, that he/she has read and understood this
COMPLAINT and knows the contents to be true of his/her own personal knowledge, except for those
matters and things set forth upon information and belief, and as to those matters and things, he/she
believes them to be true.

Jill A. Adams
(Sign in the Presence of the Notary Public)

Sworn to and subscribed before me this 26th day of , June, 2016.

Keri Washington_
Notary Publi