HomeMy WebLinkAbout04-3392J Scott Gardner
Plaintiff
No. (]Lf - 3qz L .?u?l EiL?
v
Wendy Kirk
Defendant
COMPLAINT TO ESTABLISH PATERNITY AND FOR GENETIC TESTING
NOW COMES, PLAINTIFF, J SCOTT GARDNER, by and through his
attorneys, James A Miller, Esquire and Miller Lipsitt LLC, and respectfully
requests genetic testing to establish paternity pursuant to 23 Pa. C.S. section
4343 and in support thereof states:
1. Plaintiff is J Scott Gardner, an adult individual residing at 2712 Lisburn
Road, #304, Camp Hill PA 17011
2. Defendant is Wendy Kirk, an adult individual residing at 3D Roundridge
Road, Mechanicsburg PA 17055
3. Defendant is the natural mother and Plaintiff believes that he may be the
natural father of the following child(ren):
Chase Alexandra Gardner born April 15, 2004
4. The above named child(ren) reside at the following address with the
following individuals:
Wendy Kirk, 3D Roundridge Road, Mechanicsburg PA 17055
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, support or other action involving the paternity of
the above named child now pending in any jurisdiction.
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 the
facility.
WHEREFORE, Plaintiff requests that the court order Defendant to submit to
genetic testing and to make the child available for genetic testing.
Respectfully submitted,
Miller Lipsitt LLC
BY: J s A. Miller, Esquire
2157 Market Street
Camp Hill, PA 17011
(717) 737-6400
VERIFICATION
I verify that the statements made in the attached divorce complaint are
true and correct. I understand that false statements herein are made subject to
the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
Date: Jam( I ( I b q
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MILLER LIPSI77 LLC
21.57 Market Street
717-7x7-6400
Fa.x: 717-737-:?S5
Fri+?.pa ttla.W.corn
IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY
PENNSYLVANIA
J Scott Gardner
Plaintiff 0 y- 33 51.
No. 043392 of 04
v
Wendy Kirk
Defendant
ORDER
AND NOW, this - S day of T U ( : 2004. Upon
review and consideration of Plaintiffs Complaint to establish paternity and
genetic testing, it is hereby;
"& A 4d
ORDERED that a hearing on this ma hall be held on the-,,
- ay of
2004, at -3o a.m p.m. in Courtoom number
Cumberland County ourlhouse, 'I Courthouse Square,
Carlisle, Pennsylvania 17013.
BY THE COURT:
We-46[C Ut r, Tv t J
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J. SCOTT GARDNER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
WENDY KIRK,
Defendant NO. 04-3392 CIVIL TERM
ORDER OF COURT
AND NOW, this 4`h day of August, 2004, upon consideration of the attached
communication from James A. Miller, Esq., attorney for Plaintiff, the hearing scheduled
for August 23, 2004, is cancelled, and Plaintiffs Complaint To Establish Paternity and
for Genetic Testing is deemed moot.
,,,.Kames A. Miller, Esq.
2157 Market Street
Camp Hill, PA 17011
Attorney for Plaintiff
,W'endy Kirk
3D Roundridge Road
Mechanicsburg, PA 17055
Defendant, pro se
7
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BY THE COURT,
11 r?*r r,`rlnn
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BILLER LiPSITr LL[
r° 2157 Market Street
Cnin.p Hill, PA 1.7011
717 737-6400
F&K: 717-737 :FASS
trowwcpaatlaw.mrn
PLEASE REPLY TO A130VE ADDRESS:
F'.®CSIMILE COVER S]EIEET
To:. Ruth
Falu 2406462
From., James A Miller
Pages: 3
Phoned
Re; Gardner y Kirk Order
Re:
J SCOtt Gardner
Plaintiff
V
Wendy Kirk
Defendant
Date:
C'C:
No. 043392 of 04
August 3, 2004
Ruth - Wendy Kirk has agreed to testing voluntarily without a court hearing. Do ynii
have instructions for us as to when/where with regard to Cumberland County testing? If
so, please advise.
This will allow us to terminate the August 23 10:30 am hearing. If there's an standard
order (similar to DRO), I can prepare it for Judgc Olcr.
I appreciate your attention.
James A Miller
_x ORIGINAL CORRESPONDENCE WILT.
FORWARDED BY MAIL.
cmai : amns n aatlaw.com
toll free: 866.440.6400; fax - 866.737.5355
Harrisburg numbers: 717.236.5161; fax - 717.236.8747
Philadelphia address: 1620 Locust Street, Philadelphia, PA 1.9103
NOT BE
gene K. Simpson
Deputy Prothonotary
Curtis R. Long
Prothonotary
3p1:1Dtb(3'R1Dta.1rv
? fftce of. h
(Cumberlanlb CO"ty
John F Slike
Solicitor
CIVIL TERM
INATION OF COST CASES
ORDER OF TE
07 AFTER MAILING NOTICE OF
ER 20 THC ??H PA
Tx DAN OF NOVENIB O RESP AON SE - CCORD
VINO N
AND NOW THIS 5 gECEI IN
WITH PRENDICE
EED INATED M AND
INTENTION TO PROER
CASE IS HEREBY T
RCP230.2-
By THE COURT,
CURTIS R. LONG
PROTHONOTARY
Square 'Carlisle, Pennsylvania 11013 (717) 240-6195 0 Fax (717) 240-6573