HomeMy WebLinkAbout11-4750I
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
THOMAS LEE THOMAS,
Plaintiff
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V. No l - `? SU Civil Term
CHERIESE N. THOMAS, CIVIL ACTION - PATERNITY
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
set forth in the following papers, you must appear at the hearing scheduled below. If
you fail to do so, the case may proceed against you and a final Order may be entered
against you granting the relief requested by the Plaintiff.
2011 at 1P!,6'0 a.m./*a%_in Courtroom No. a-
Plaintiff and Defendant are directed to appear on the 8 ? day of
of the Cumberland County Courthouse, Carlisle, Pennsylvania, for a hearing on
Plaintiffs request for genetic testing: If you fail to appear as ordered, the court may
enter an order in your absence requiring you and your children to submit to genetic
tests.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE, THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford St.
Carlisle, Pa. 17013
(717) 249-3166
The Court 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 accommodations
available to disabled individuals having business before the court, please contact our office. All
arrangements must be made at least 72 hours prior to any hearing or business before the court. You
must attend the scheduled conference or hearing.
BY THE COURT:
cc: Jane Adams, Esquire, for Plaintiff
Family Law Clinic, for Defendant oco
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
THOMAS LEE THOMAS,
Plaintiff
vs.
CHERIESE N. THOMAS,
Defendant
CIVIL ACTION - LAW
No. 11 - 4750 Civil Term
ACTION IN PATERNITY
MOTION FOR CONTINUANCE
AND NOW comes the Plaintiff/Petitioner Thomas Lee Thomas, by and through
his Attorney, Jane Adams, and respectfully represents the following:
1. Petitioner is Thomas Lee Thomas, (hereinafter referred to as "Petitioner"),
who currently resides at 1361 Zimmerman Road, Carlisle, Cumberland County,
Pennsylvania, 17013.
2. Respondent is Cheriese Thomas, (hereinafter referred to as "Mother"), who
is currently represented by the Family Law Clinic.
3. On June 3, 2011, Petitioner filed a Complaint to Establish Paternity and for
Genetic Testing under the above-captioned matter.
4. The hearing on this matter is scheduled for Thursday, September 8, 2011
before this Honorable Court.
5. Counsel for the parties have discussed undertaking voluntary genetic testing
and it is anticipated that the parties may be able to enter into an agreement to that
effect.
6. Petitioner is asking for a continuance to allow time to complete the stipulation
and details of the arrangement for voluntary genetic testing and that the next date be
scheduled no less than four weeks from today's date, in order that the test results could
be returned before any further proceedings.
7. Such request would conserve time and resources for the court, counsel, and
the parties.
8. Attorney Megan Riesmeyer at the Family Law Clinic was contacted regarding
Petitioner's request on Friday, September 2nd and she indicated she was in agreement
with the request for the continuance.
9. This matter was previously assigned to Judge Ebert.
WHEREFORE, Petitioner, Thomas Lee Thomas, respectfully requests that this
Honorable Court continue the hearing previously scheduled in this matter.
Date.
Respectfully submitted,
ne Adams, Esquire
D. No. 79465
17 W. South St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PETITIONER
THOMAS LEE THOMAS
CERTIFICATE OF SERVICE
AND NOW, this September 4, 2011, I, Jane Adams, Attorney for Petitioner,
Thomas Lee Thomas, hereby certify that a copy of Father's Petition for a continuance
has been duly served upon the Mother by placing such in the custody of the United
States Postal Service, via certified mail, postage pre-paid addressed to:
Family Law Clinic
45 N. Pitt St.
Carlisle, Pa. 17013
FOR DEFENDANT
Ja Adams, Esquire
I. No. 79465
7 South Street
C rlisle, Pa. 17013
17) 245-8508
ATTORNEY FOR PETITIONER
THOMAS LEE THOMAS
j? .
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
THOMAS LEE THOMAS,
Plaintiff
vs.
CHERIESE N. THOMAS,
Defendant
CIVIL ACTION - LAW
No. 11 - 4750 Civil Term
ACTION IN PATERNITY
ORDER OF COURT
AND NOW, this 4e? day of , 2011, it is
hereby ORDERED AND DECREED that the hearing scheduled in the above-captioned
matter shall be rescheduled for 4-00 a.m.
fir , on the ? Dgy ot;?
2011, in Courtroom No. 2 of the Cumberland Co mom'
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Courthouse, Carlisle, Pa. 17013. C?
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By the Court:
cc: ? Jane Adams, Esquire, for Plaintiff
Family Law Clinic, for Defendant
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
CHERIESE N. THOMAS
vs. Plaintiff/Petitioner
THOMAS LEE THOMAS
Defendant/Respondent
) Docket Number: 00286 S 2009
) PACSES Case Number:
) Other State ID Number
STIPULATION OF FACTS
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Petitioner CHERISSE THOMAS and Respondent THOMAS LEE THOMAS, by their respective attorneys,
enter into the following stipulation with respect to the above-captioned Support action now pending before
the Court:
1. Petitioner and Respondent, agree that child, Tamia Thomas, was born on July 14, 2010.
2. Though not divorced, Petitioner and Respondent have been living separate and apart since March
2009.
3. Petitioner and Respondent, submit that Respondent is not the biological father of Tamia Thomas.
4. Petitioner and Respondent, submit that Timothy Terrell Keys is the biological father of Tamia Thomas.
5. Respondent is willing to submit to paternity testing but cannot afford to pay for the same.
01
C r se Thomas (V\ Thom L. Tho
tiff/Petitioner Defenda p ndent -?
cry _ -?..
Gregory Marcelin gielAtdams, Esq.
12A 17
Certified Legal Intern
Carlisle, PA 17013
MEGA RIESMEYER
MARTIN J. D'URSO
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax (717) 243-3639
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
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THOMAS LEE THOMAS, :CIVIL ACTION -LAW ? ?-
Plaintiff 2? _< -o,-t-,
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CHERIESE N. THOMAS, ACTION IN PATERNITY
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Defendant
STIPULATION OF THE PARTIES
WHEREAS, Plaintiff filed an action in Paternity under the above -caption on June
3, 2011, the parties agree as follows:
1. The parties, Thomas Lee Thomas and Cheriese N. Thomas, as well as the
child, Tamia M. Thomas, born July 14, 2010, shall submit to genetic testing at the time
and place requested by Plaintiff.
2. Plaintiff shall be responsible for all costs associated with the testing.
3. The parties agree that further proceedings shall be continued pending the
result of the genetic tests.
4. This stipulation may be entered as an Order of Court for enforcement
purposes if necessary.
Thorns Lee as, PlaiW
Date: /';? l? 1
Witness Cheriese N. Thomas, De ant
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Date:
WITNESSETH:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
THOMAS LEE THOMAS,
Plaintiff
CIVIL ACTION - LAW
vs.
CHERIESE N. THOMAS,
Defendant
yr-
No. 11 - 4750 Civil Term
ACTION IN PATERNITY
MOTION FOR CONTINUANCE
WHEREAS, Plaintiff filed an action in Paternity under the above-captioned
number on June 3, 2011, hereby avers as follows in support of his request for
Continuance.
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1. On November 1, 2011, a stipulation was filed pursuant to an agreement of the
parties.
2. The stipulation provided that the parties, Thomas Lee Thomas and Cheriese
N. Thomas, as well as the child, Tamia M. Thomas, born July 14, 2010, shall submit to
genetic testing at the time and place requested by Plaintiff.
3. In Order to save judicial time and resources, it is requested that this matter be
continued to allow the parties more time to obtain a genetic test. Once the test is
obtained, the parties can attend the hearing and stipulate to an Order indicating the
natural Father of the child.
4. This matter was previously assigned to Judge Ebert.
5. Family Law Clinic, who represents the Defendant, is in agreement with this
request.
Ily submitted
Date: / (- 3 - l/
,kr Adams, Esquire
I. V. No. 79465
W. South Street
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
r
THOMAS LEE THOMAS,
Plaintiff/ Petitioner
V.
CHERIESE N. THOMAS,
Defendant/ Respondent
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
7
No. 11 - 4750 CIVIL TERM
ACTION IN PATERNITY
ORDER OF COURT -,
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AND NOW, this 3 day of ON , 2011, upon consideration of the attached Stipulation
of Facts, it is hereby Ordered as follows:
1. The parties, Thomas Lee Thomas and Cheriese N. Thomas, as well as the child, Tamia
M. Thomas, born July 14, 2010, shall submit to genetic testing.
2. The Plaintiff, Thomas-Lee Thomas shall be responsible for all costs associated with the
testing.
BY THE 'U
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