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Home My WebLink About11-3381CF T Apy HE P°OTHO T 2011 MAR 31 PM 12,' 33 KAYLA GRIMM, IN THE COURT OF COMMON ISU SQKND COUNTY CUMBERLAND COUNTY, PENNSI? EWOLVANIA Plaintiff V. : No. //- 3 3 f I Civil Term. JEREMI ANDREW KANNEG, SR., CIVIL ACTION - PATERNITY COMPLAINT TO ESTABLISH PATERNITY AND NOW, comes Kayla Grimm, by and through her Attorney, Jane Adams, Esquire, and in support of the complaint respectfully represents as follows: 1. Petitioner is Kayla Grimm (hereinafter referred to as "Petitioner") and she currently lives at 514 3rd Street, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Petitioner's date of birth is April 26, 1990. 3. Petitioner is the natural mother of Margaret Jane Kanneg, born August 10, 2010. A copy of the child's birth certificate is attached as Exhibit A. 4. When Petitioner completed the form to obtain her child's birth certificate, Petitioner listed the name as Margaret Jane Kanneg. At that time, she believed that Jeremi Andrew Kanneg, Sr., was the natural father of the child. 5. In November 2010, a paternity test was completed, which determined that Teddy Caufman was the natural father of the child. 6. Vital statistics will not change the child's last name without a court order. 7. Petitioner is requesting that the child's name be changed to Margaret Jane Caufman and that Teddy Caufman be listed as the child's father. 8. Teddy Caufman, Natural Father, joins in this petition, and agrees with the request to change the child's name. He lives with Petitioner. a4 ? 5-7 y!? ?? a S73ao 9. There is currently no custody, support or other action involving paternity regarding the above-named child now pending in any jurisdiction. 10. A petition for a name change for the child to Margaret Jane Caufman was filed on March 10, 2011 in Cumberland County. 11. The hearing is currently scheduled for April 14'h, 2011 at 9:15 a.m. before Judge Hess. 12. In the interest of judicial expediency and conservation of legal fees and costs for Petitioner, who is of modest means, Petitioner is requesting that a hearing regarding Paternity be scheduled on April 14, 2011 at 9:15 a.m. before Judge Hess, the same time and place as the name change hearing. 13. Petitioner believes it would be in the best interest of the child to change her last name to that of her natural father and list the correct father on the birth certificate. 14. Correcting the birth certificate would also assist in domestic relations matters. WHEREFORE, Petitioner requests that this Honorable Court Order enter a court Order adjudicating Teddy Caufman as the child's father. Respectfully submitted, Date: 5 V r `/ 4 *e Adams, Esquire . No. 79465 17 West South St. St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PETITIONER t 0 0 0 O N 0 N ti t? O N A N O 7 +?+ OA 00 7 O V] A W wz Aw Acn a W E6 V 0 " ??? l ' T 1 0 l l ---111 W z W H ?W1 A O w u0 j ?R 8 dD c? J En m ?m dG a? g of N C o> 0 G O A 3L a a7 8? 0p6 er' U U N o Nm N C o? H 0 I I i IW I CC IW r t.n U) 0 C314 0 la t? L ? CL cz a: z § I ® ;? ¢a?? m . co w W ¢ O <¢IW 3a ' O I? W z I _ Z >1z` W 2: IN L F, 0.1 =I 0 a FI-? A' W? aQ N i z alcc UJ iars.? 4- M l W a 01-111 70 N Z 4- L Z Z I 0 z ?I O I I? o I L U- o a I? > > W 0 ij _O = I I E?cm13Irt?Df VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: 3 ?3(A Kayla Grimm, Retitioner Date: ?? 3o? 1 Teddy C fman, Na ural Fat r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KAYLA GRIMM, Plaintiff V. JEREMI ANDREW KANNEG, SR., Cl) o ? z?.. -vrn { X° ? 5;4= nj v No. /(- 3 35;11 Civil Term. CIVIL ACTION - PATERNITY ORDER AND NOW, this / + day of ^. / , 2011, upon consideration of the attached Complaint to Establish Paternity, filed under the above- docketed number, a hearing is set for the 14th day of April, 2011, in Courtroom No. 4 at 9:15 a.m. in the Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT: i M. Jane Adams, Esquire, for Plaintiff Family Law Clinic, for Defendant d Kayla Grimm, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW 3 PATERNITY rn 'n Jeremi Andrew Kanneg, Sr., w rn i rn xt ? rn- Defendant. : NO. 11-3381 CIVIL TERM (,r- -<D r- = C) ---4c:) : MOTION FOR CONTINUANCE =c X 2F Defendant, Jeremi Andrew Kanneg, Sr., by and through his attorneys, the Family Law Clinic, represents the following: 1. On March 10, 2011, Plaintiff filed a Petition for Name Change, Docket No. 11-2956. The Order of Court, dated March 16, 2011, scheduled a hearing for Thursday, April 14, 2011, at 9:15 A.M. before the Honorable Kevin A. Hess. 2. On March 31, 2011, Plaintiff filed a Motion to Waive Advertising, in the above- captioned Name Change Docket. The Order of Court, dated April 1, 2011, excused Plaintiff from advertising notice of the hearing. 3. On March 31, 2011, Plaintiff filed a Complaint to Establish Paternity, Docket No. 11- 3381. The Order of Court, dated April 1, 2011, scheduled a hearing for Thursday, April 14, 2011, at 9:15 A.M. before the Honorable Kevin A. Hess. 4. On April 5, 2011, Plaintiff served Defendant's attorneys with these documents via certified mail. Prior to April 5, 2011, Defendant did not receive any of these documents from Plaintiff. 5. Pursuant to C.C.R.P. 5, upon the filing of petition for name change, notice must be given to any non-petitioning parent of a child whose name may be affected by the proceedings at least ten days prior to the hearing. Defendant signed the acknowledgement of paternity for the child whose name may be affected by the above-captioned name change proceeding. Plaintiff's counsel first accomplished service of these documents to Defendant's counsel nine days before the hearing date. 6. Defendant's counsel is unable to attend the hearing scheduled for April 14, 2011. 7. Pursuant to C.C.R.P. 208.2(d), Defendant's attorneys sought concurrence of opposing counsel, Jane Adams, for this Motion for Continuance. On April 11, 2011, opposing counsel stated that she would not oppose this request. 8. Pursuant to Pa.R.C.P. 216(A)(1) and for the aforementioned reasons, Defendant requests a continuance of the April 14, 2011 hearing. Date: April 11, 2011 Respectfully Submitted, r Ashley Nichols Certified Legal Intern fi/?w "a MEG RIESMEYER ANNE MACDONALD-FOX THOMAS M. PLACE ROBERT E. RAINS Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 Fax: (717) 243-3639 Kayla Grimm, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA , c V. : CIVIL ACTION - LAW -cry :PATERNITY M -Orn Jeremi Andrew Kanneg, Sr., i o Defendant. : NO. 11-3381 CIVIL TERM > ?.x s ° -+o =o c-n C -5 n ORDER OF COURT AND NOW, this day of , 2011, upon consideration of the attached Motion for Continuance, the motion is granted. A hearing on this matter is scheduled for the ad m day of , 2011. a,,6 9 Q Q , .01 7 . BY THE COURT: i Date CC: Jane Adams, for Plaintiff Family Law Clinic, for Defendant J. e` Q Kayla Grimm, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW PATERNITY Jeremi Andrew Kanneg, Sr., Defendant. : NO. 11-3381 CIVIL TERM ORDER AND NOW, this z to 0 day of May, 2011, after hearing and upon consideration of Complaint, it is hereby ORDERED and DECREED as follows: 1. Margaret Jane Kanneg shall be hereafter known as Margaret Jane Caufman. 2. Teddy Lee Caufman is the natural Father of Margaret Jane Caufman. 3. Vital Statisitics shall remove Jeremi Andrew Kanneg, Sr. from the birth certificate and shall list Teddy Lee Caufman as the Father. 4. Plaintiff's challenge to Defendant's paternity is upheld and Defendant's prior Acknowledgment of Paternity shall be rescinded based on material mistake of fact. BY THE COURT: -WA?, cc: ? Jane Adams, Esquire, for mother Family Law Clinic, for father Cep; es g ven ??rsoKUl? y O y J. ? 1 A n o ? h Z