The URL can be used to link to this page

Home My WebLink About08-2099Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 Attorneys for Plaintiff 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 ROBERT C. NICKEY, Plaintiff V. JESSICA R. DELANEY, Defendant NO. V F= dG 9 9 CIVIL TERM CIVIL ACTION - LAW COMPLAINT TO ESTABLISH PATERNITY AND FOR GENETIC TESTING Plaintiff, Robert C. Nickey, requests genetic testing to establish paternity pursuant to 23 Pa. C. S. § 4343, and in support of that requests that: 1. Plaintiff is an adult individual who resides at 4182 Elk Court, Apartment 115, Mechanicsburg, Pennsylvania 17050. 2. Defendant is an adult individual who resides at 197 College Hill Road, Enola, Pennsylvania 17025. 3. Defendant is the natural mother and Plaintiff believes that he may be the natural father of the following child: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Liam C. Delaney, born October 12, 2007. 4. The above-named child resides at the following address, with the following individuals: Address Household Members / Relationshi 197 College Hill Road, Jessica R. Delaney / Mother/Plaintiff Enola, Pennsylvania Penelope Bernheisel / Maternal Grandmother Boaz Berneisel / Uncle Wyatt Delaney / Uncle 5. Defendant was not married at the time the child was conceived or born. 6. Defendant is not now married. 7. There is not a custody action involving the paternity of the above-named child now pending in any jurisdiction. 8. The Defendant filed a support complaint on October 17, 2007, docketed to number 867-S-2007, PACSES Case No. 718109540, in the Domestic Relations Section of the Court of Common Pleas of Cumberland County, Pennsylvania,. 9. By Judge Bayley's Order of December 6, 2007, the Defendant's complaint for support was dismissed without prejudice due to her failure to appear for genetic testing. 10. There has not been a determination by any Court as to the paternity of the child and any prior support, custody, divorce or any other action. 11. Plaintiff in the instant matter appeared for genetic testing on the date designated by the Court, December 4, 2007, and submitted himself for genetic testing at that time. 12. 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 requests that the Court order Defendant to submit to genetic testing and to make the child available for genetic testing. :JO HzSON, DUF E, STEWART & WEIDNER r Melissa Peel Greevy 320269 M VERIFICATION I, Robert C. Nickey, verify that the statements made in this Complaint to Establish Paternity and for Genetic Testing are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A §4904, relating to unsworn falsification to authorities. Date: C, QL&e Robert C. Nick L n o ^f 00 G J ? - 0 2?y? Johnson, D ffie, Stewart & Weidner (APR 0 7 r By: Melissa P el Greevy I.D. No. 7795 Attorneys for Plaintiff 301 Market St eet P. O. Box 109 Lemoyne, Pe sylvania 17043-0109 (717) 761-454 ROBERT C. ICKEY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. d K, ,xZ 4 q CIVIL TERM V. CIVIL ACTION - LAW JESSICA R. D LANEY, Defendant NOTICE OF HEARING AND ORDER YOU H VE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the followin papers, you must appear at the hearing scheduled below. If you fail to do so, the case may roceed against you, and the final Order may be entered against you granting the relief req este the Plaintiff. Plaintiff and Defendant are directed to appear on the AVL" day of h's , 2008, at A '-0D . m., at Courtroom _ 1 for a hearing an Plaintiff' re uest for genetic testing. If you fail to a pear as ordere th rt may enter an Order in your a sence, requiring you and your child to submit t neti s B THE C J. Americans With Disabilities Act The Co rt of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable acc mmodations available to disabled individuals having business before the court, please contact ur office. All arrangements must be made at least 72 hours prior to any hearing or business bef re the court. You must attend the scheduled conference or hearing. S OULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT YOU HAVE A LA ER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN ROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFF RD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORM TION ABOUT AGENCIES THAT OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR AT NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 ?y w ,,,7 ?`' Q --? r-- ?-- ? `?? ? ? ? ? v,- .Q -?? ? ? ?? ? ? Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 ROBERT C. NICKEY, Plaintiff V. JESSICA R. DELANEY, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2099 CIVIL ACTION - LAW AND NOW, this 1 , day of April, 2008, the undersigned does hereby certify that on April 15, 2008, the Compl int filed April 2, 2008 in the above captioned action was served upon on Defendant, Jessica R. Delaney via certified mail return receipt requested addressed to 197 College Hill Road, Enola, PA 17025, the residence of Ms. Delaney. The Return Receipt evidencing service upon Defendant is attached hereto as Exhibit A. JOHNSON, DUPFIE, STJWVART & WEIDNER Melissa Peel Greevy I.D. No. 77950 Johnson, Duffle, Stewart & Weidner 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorneys for Plaintiff .- CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing Return of Service upon all parties or counsel of record by depositing a copy of same in the United States Mail at Lemoyne, Pennsylvania, with first-class postage prepaid on the ?day of April, 2008, addressed to the following: Jessica R. Delaney 197 College Hill Road Enola, PA 17025 JOHNSON,.DQFFIE, STEWART & WEIDNER Peel Greevy :329929 ti;+ A- ki (Domestic Mail Only; No Insurance Coverage Provided) F d li i f- ati i it b i a or e very n orm o n v s our we s te at www .usps.cornq, ? da A f - $ 0, Postage A PrI 17 0 1 ` P ru C3 I Certified Fee 41 A 9 10 Atrnark %D C3 Return Receipt Fee (Endorsement Required) z r?lere CO C3 Restricted Delivery Fee (Endorsement Required) S e & Fees Total Posta $ V C3 g r%- a Sent To ?t?ssl - !?? J7e.la O [`- .....-----------------. -t--reet----- --N---o---- , Apt. S or PO Box No. - ---------------------------- City, State, 4 r f?a25 ---------------- PS Form :3800, August .. See R everse for Instructions ¦ Complete items 1, 2, and 3. Also complete Item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. A. by (Pri?rted Name) 0 Agent LUWdressee ate of Delivery D. Is delivery address different fr6m Item 1? es ?? cC\2 If YES, enter delivery address below ( 3. Service Type $ z i, A Certified Mall 0 Express Mail 0 Registered 0 Return Receipt for Merchandise 0 Insured Mail 0 C.O.D. ?4. Restricted Dellvwy? (Extra roe) Yes 2. Article Numbeir (Tiar?sfersle? from m service label) 7007 0710 0002 9649 1768 PS Form 3811, February 2004 Domestic Return Receipt 1025s5-024+15go'. 1. Article Addressed to: J??s?c? ? .??czney ?q?. Coke e ? 1`i ?'uo I ?iiwlc? 1 ? D2S C^? ?''V ?"? r:_ ? ,_ ..r. ?? ?? ?? ??`?? ? ! j 1e,? ', /'?.) r? ;. `xj "'ti ROBERT C. NICKEY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW JESSICA R. DELANEY, Defendant NO. 08-2099 CIVIL TERM ORDER OF COURT AND NOW, this 28th day of April, 2008, this matter having been called this date on a complaint filed by Robert C. Nickey to compel genetic testing to determine paternity, and Jessica R. Delaney agreeing to said testing, it is ordered that Jessica R. Delaney, herself, shall appear and bring Liam C. Delaney, born October 12, 2007, for genetic testing pursuant to proper and ordinary procedures ? Melissa Peel Greevy, Esquire /For Plaintiff ? Jessica R. Delaney, pro se 197 College Hill Road Enola, PA 17025 prs 0- I la rna I LPL. Alta q /D$ "*?M 4 1 L4 CID =- ;rte ) C--j