No.: D-15-515847-R

PET
WARM SPRINGS LAW GROUP
ELLIOTT D. YUG, ESQ.
Nevada Bar #5172
1489 W. Warm Springs Rd. Ste. 110
Henderson NV 89014
(702) 966-8270 Telephone
(702) 534-4974 Facsimile
[email protected]
Attorney for Petitioner
Mindy Leigh Gilkerson
DISTRICT COURT
CLARK COUNTY, NEVADA
Case No.: D-15-515847-R
Dept. No.: Q
In the matter of the parental rights as to
JONAH LEE GILKERSON, a minor
PETITION TO TERMINATE
PARENTAL RIGHTS
COMES NOW, Petitioner Mindy Leigh Gilkerson by and through her Attorney of
Record, Elliot D. Yug, Esq., of the Law Firm, WARM SPRINGS LAW GROUP, and
states as follows:
1. Petitioner Mindy Leigh Gilkerson, hereinafter Ms. Gilkerson, is the mother of
Jonah Lee Gilkerson, born August 12, 2009 in the County of Bernalillo, State
of New Mexico.
2. David Edward Lofties is the father of Jonah Lee Gilkerson.
3. David Edward Lofties has had no communication with or paid Ms. Gilkerson
any child support for Jonah Lee Gilkerson.
4. Jonah Lee Gilkerson lives with Ms. Gilkerson the County of Clark, State of Nevada.
5. They have lived in Nevada for over 1 year.
6. David Edward Lofties has abandoned Jonah Lee Gilkerson per NRS
128.012(2) in that he has never paid any child support for Jonah and he has
not communicated with Ms. Gilkerson for Jonah for over 1 year.
7. Jonah has no memory of David Edward Lofties.
8. Jonah has never met any of David Edward Lofties’ family.
9. It would be in Jonah’s best interest if the parental rights of David Edward Lofties were terminated because 1) he will be psychologically damaged when he
learns that the person who has been held out as his father wants no relationship with
him; 2) Ms. Gilkerson’s ability to register Jonah for school will be complicated as
the school may require information on Jonah’s father for registration and other
purposes; 3) Ms. Gilkerson’s ability to obtain a passport and travel with Jonah out
of the country will be restricted as Mr. Lofties is the parent and she will need his
consent and/or cooperation to do these things; 4) in the event that Ms. Gilkerson
remarries any adoption will be more difficult; and 5) in the event that Ms. Gilkerson
were to pass before Jonah reaches the age of majority, Jonah will be placed with
Mr. Lofties instead of the family that he has already build up a relationship with.
10. Therefore, Petitioner Mindy Leigh Gilkerson asks this Court to terminate the
parental rights of David Edward Lofties as to Jonah Lee Gilkerson.
11. Petitioner Mindy Leigh Gilkerson asks this Court for an Order requiring the
birth certificate of Jonah Lee Gilkerson be amended to remove the name of
David Edward Lofties as the father of Jonah Lee Gilkerson.
12. Further your Petitioner sayeth naught.
Respectfully submitted this 1st day of June, 2015
/s/ Elliott D. Yug
Elliott D. Yug, Esq.
Nevada Bar #:5172
VERIFICATION
Comes now, MINDY LEIGH GILKERSON and declares, under penalties of
perjury, that I have read the PETITION TO TERMINATE PARENTAL RIGHTS
and know the contents thereof; and that the same is true of my own knowledge, except
those matters therein contained stated upon information and belief and as to those
matters, I believe them to be true and correct.
Dated this 1 day of June, 2015.
/s/ Mindy Gilkerson
Mindy L. Gilkerson
HCS Pub. July 31, August 7, 14, 21, 2015

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