STATE OF NORTH CAROLINA

COUNTY OF GASTON

IN THE GENERAL COURT OF JUSTICE

DISTRICT COURT DIVISION
File No. ______________

)
JILL A. ADAMS
)
PLAINTIFF
)
)
CHILD CUSTODY COMPLAINT
vs.
)
)
)
JACK B. ADAMS
)
DEFENDANT,
)
______________________________________________________________________________
The Plaintiff, complaining of the Defendant, alleges and says as follows:
1. That the Plaintiff is a citizen and resident of Gaston County, State of North Carolina for
the past 12 years.
2. That the Defendant is a citizen and resident of Gaston County, State of North Carolina for
the past 10 years.
3. The Plaintiff and the Defendant were married on January 1, 1998.
4. The Plaintiff and the Defendant have two children: Lincoln C. Adams, born December 3,
2001, and Anna D. Adams born October 18, 2006. The children have been living with the
Plaintiff since the separation.
5. The Plaintiff and the Defendant separated on September 1, 2014.
WHEREFORE, the Plaintiff respectfully prays the Court as follows:
1. That she gets sole physical and legal custody of the children. The Plaintiff agrees that the
Defendant can have reasonable visitation.
2. That the Plaintiff be awarded a trial by jury.
3. That the costs of this action, including a reasonable attorneys fee, be taxed by the Court
against the Defendant.

4. For such and further relief as to the Court may seem just and proper.
This the 26th day of June 2016
_______________________
Christie Mackin
Evans and Associates, LLP
108 S. York Rd
Gastonia, NC 28052
Attorney for Plaintiff
N.C.S.B. #78-45124785
Telephone: (704)-654-8974

STATE OF NORTH CAROLINA )

COUNTY OF GASTON

VERIFICATION

I, Jill A. Adams being first duly sworn, deposes and says that she is the Plaintiff in this matter,
that she has read and understood this CHILD CUSTODY COMPLAINT and knows the contents
to be true of her own personal knowledge, except for those matters and things set forth upon
information and belief, and as to those matters and things, she believes them to be true.
_______________________________
Rachel Mackin-Evans, Notary Public

Sworn to and subscribed before me this 24th day of June, 2016

__________________________________
Notary Public