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HomeMy WebLinkAbout07-1036 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HELEN YATES, Guardian for Minor Child, CORY PORTER. Plaintiff No. 2007 - I D~ v CIVIL ACTION - LAW THERESA MARTIN, Guardian for Minor Child, JESSICA MARTIN Defendant CUSTODY COMPLAINT to ESTABLISH PA TERNITV and for GENETIC TESTING 1. The Plaintiff is Helen Yates, as Guardian for her minor son, Cory Porter, who is an adult individual currently residing at 336 E Street, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Theresa Martin, as Guardian for her minor daughter, Jessica Martin, who is an adult individual currently residing at 152 West North Street, Carlisle, Cumberland County, Pennsylvania. 3. Minor Defendant, Jessica Martin, is the natural mother and Minor Plaintiff, Cory Porter, believes that he may be the natural father of the following child: Jordan Porter DOB: 04/2006 4. The above named child resides at the following address with the following individuals: 152 West North Street, Theresa Martin Carlisle, PA Jessica Martin Grandmother Mother 5. Minor Defendant, Jessica Martin, was not married at the time the child was conceived or born. 6. Minor Defendant, Jessica Martin, is not now married. 7. There is not a custody, support, or other action involving the paternity of the above-named child now pending in any jurisdiction. A support action was filed, then withdrawn by the Minor Defendant, Jessica Martin, on the day the paternity test was scheduled to be conducted. 8. There has not been a determination by any court as to the paternity of the child in any prior support, custody, divorce, or any other action. 9. Plaintiff agrees to pay all costs associated with genetic testing directly to the testing facility in accordance with the procedures established by that facility. WHEREFORE, Plaintiff respectfully requests this Honorable Court Order the minor Defendant, Jessica Martin, to submit to genetic testing and to make the child available for genetic testing. Respectfully submitted, Spencer Abel Law Office u an e Spen r Abel, Esq. Att y 10 #202443 22 East Street, #6 Mt Holly Springs, PA 17065 (717) 323-0046 spencer _ abeL esq@fastmail.fm Counsel for Plaintiff, Helen Yates, as Guardian for her Minor Child, Cory Porter Page 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HELEN YATES, Guardian for Minor Child, CORY PORTER. Plaintiff No. 2007 - v CIVIL ACTION - LAW THERESA MARTIN, Guardian for Minor Child, JESSICA MARTIN Defendant CUSTODY VERIFICA liON I VERIFY that I have personal knowledge of all facts not of record set forth in the foregoing pleading, and that such statements are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 94904 relating to unsworn falsification to authorities. Date: 1.1 d--"':> I () I 11-$ .. / Helen Yates IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HELEN YATES, Guardian for Minor Child, CORY PORTER. Plaintiff No. 2007 - v THERESA MARTIN, Guardian for Minor Child, JESSICA MARTIN Defendant CIVIL ACTION - LAW CUSTODY CERTIFICATE OF SERVICE I certify that, concurrent with filing the foregoing Complaint to Establish Paternity, I am this day serving a copy of same by Regular First Class U.S. Mail, and by Certified, Return Receipt Requests, First Class U.S. Mail, to the following: Theresa Martin, Guardian for Jessica Martin 152 West North Street Carlisle, PA 17013 Date: Su an 22 Street, #6 Mt. Holly Springs, PA 17065 (717) 323-0046 spencer _abeL esq@fastmail.fm ~ "'" = ~ '&. = --I ~ -n :i! 0 ~ fTi l" OJ mf!J :ft: '" N -om :~JO -(}) w f:) i CP ~O '::.,--{ (:l ..s:> -0 )::n ~ In :x ,:) (") tp \) w Om It.> 0 -'4 :>- 1" ~ =1 -.l -<. --. HELEN YATES, Guardian for Minor Child, CORY PORTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V, CIVIL ACTION - LAW THERESA MARTIN, Guardian for Minor Child, JESSICA MARTIN, Defendant CUSTODY NO. 07-1036 CIVIL ORDER OF COURT AND NOW, this 2nd day of March, 2007, after examination of the record and the Court having determined that there is no valid support or custody case pending before this court and further determining that the Petitioner lacks standing to bring the instant complaint to establish paternity and for genetic testing, IT IS HEREBY ORDERED AND DIRECTED that this matter is DISMISSED. By the Court, 't J. M, L. Ebert, Jr" Suzanne Spencer Abel, Esquire Attorney for Plaintiff Theresa Martin ~,~ 3vtJ~{J7 ~ 9 I :j I WV S- ~v~~ LOOl . 8' In ,,', " . ., '. I -'Hl .:10 ^ '1'1 . ,,\., 'I'" i' i...-, .... If, \"';l',\." 1..L........L.,'- .... 30!:J:lQ-{J3l!.:J