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Home My WebLink About11-7321 STEVEN MICAHEL FRY Plaintiff V. REBECCA MCKINLEY FRY Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA N0: 11- r7 ' ( ?vi1 Txm : IN RE: PATERNITY r? ? a3 cTnT1 m.•/?? I T1 -- = _V PETITION AND AFFIDAVIT FOR LEAVE TO PROCEED i?r N IN FORMA PAUPERIS PURSUANT TO P.A. R.C.P. 24O.??o .? "c-a ? c_J I, Steven Michael Fry, hereby verify that I have'no current income, assets or means to pay the cost and fees of the above at captioned. I have attached a affidavit of income. g-. -i Z -,Z rn --i G cD -a-i c? ?s I, Steven Michael Fry, respectfully request this Honor- able Court to allow to move In Forma Pauperis pursuant to P.A. R.C.P. 240. Date: 09/20/11 Steven Michael Fry G Integrated Offender Case Management System 9/1/20118:31:40 AM Monthly Account Statement From Date: 07/31/2011 To Date: 09/01/2011 Institution: GRN - Greene BatchAt Date Tran. Code Transaction Obscription Transaction Amount Balance after Transaction 0000 04/14/2011 86 Re-open Account - 0.00 0.00 0558 04/14/2011 88 Credit - 27 - MisclOther 15.00 15.00 0000 04/14/2011 86 Transfer Out - 0.00 15.00 0000 04/14/2011 86 Transfer In - 0.00 .15.00 New balance as of this Transaction 15,00 A STEVEN MICHAEL FRY : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V . NO: (1- ?3a1 ?ivi REBECCA MCKINLEY FRY U) rv Defendant IN RE: PATERNITY ?. tv C C-) f iV C. ) . COMPLAINT TO ESTABLISH PATERNITY AND FOR GENETIC TATLNG -'` Plaintiff, Steven Michael Fry, Pro Se, respectfully request to Establish Paternity pursuant to 23 Pa C.S.A. § 4343 and in support thereof avers the following: 1. Plaintiff is an adult individual who resides at 175 Progress Drive, Waynesburg, Pennsylvania 15370. 2. Defendant is an adult individual who resides at 22 Regency Woods North, Carlisle, Pennsylvania. 3. The above at captioned parties were married on March 12, 2009, in Palatkia, Florida. 4. The above at captioned parties seperated on April 2, 2011. (See Exibit A; Support Complaint) 5. The Defendant has advised the Plaintiff that a child was conceived and alleges that child to be the Plaintiff's. 6. During the relevant period which the unborn child was conceived Plaintiff had no access to the Defendant for the Plaintiff was in a State Correctional Community Center. (See Exibit B: Verification letter dated August 1, 2011) 7. The Defendant has made little to no attempt to pro- vide the Plaintiff information concerning the unborn child de- spite alleging Plaintiff as the Father. 8. There is no family unit to protect or preserve for it has been destroyed by seperation. 9. To the best of the Plaintiff's knowledge the unborn child is due on or around October 31, 2011. 10. The Plaintiff is currently incarcerated in a State Correctional Institution. 11. The Plaintiff agrees to pay all cost associated to Genetic Testing directly to the testing facility in accordance with the procedures established by the facility. 12. I verify that the foregoing is true and correct to the best of my knowledge and or belief and that a false statement is subject to pentality under 18 Pa C.S.A. § 4904, False state- ments to authorities. WHEREFORE, Plaintiff respectfully request this Honor- able Court to order the Defendant to submitt to Genetic Testing and to make the unborn child available for Genetic Testing at the time of birth. Respectfully submitted, Date: 09/20/11 2 ? Steven M. Fry In the Court of Common Pleas of CUMBERLAND County, Pennsylvania / DOMESTIC RELATIONS SECTION REBECCA M. FRY ) Docket Number: 01087 S 2009 vs. Plaintiff ) )PACSES Case Number. 592111361 STEVEN M. FRY ) Defendant ) Other State ID Number. t do Complaint for Sifor Support 4 New Complaint 0 Amended Complaint 1. Plaintiff resides at 22 REGENCY WOODS N, CARLISLE, PA. 17015-9059-22 CUMBERLAND County. Plaintiffs date of birth is 07113183 2. Defendant resides at C/O KEYSTONE, 7201 ALLENTOWN BLVD, HARRISBURG, PA. 17112-3646-99 DAUPHIN County. c Defendant's date of birth is 05/20171 ?Nr 3. (a) Plaintiff and Defendant were married on MARCH 12, 2009 o z -' at PALAKA, FLORIDA o rr D (b) Plaintiff and Defendant were separated on APRIL 2, 2011 z b?' (c) Plaintiff and Defendant were divorced on c; at (d) Address of last marital domicile: 22 REGENCY WOODS NORTH CARLISLE PA 17015 4. Plaintiff and Defendant are the parents of or stand in loco parentis to the following children: Name Birth Date AM Bom of the Marriage Y = Yes, N = No DEVON M. FRY 06/09/09 1 Y Residence: W/PLNT Residence: Form IN-005 Service Type M Worker 10 21502 I[NC I7201 Allentown Blvd. I Harrisburg, PA 117112 1 Phone (717) 651-0340 1 Fax (717) 651-0265 --b?' August 1, 2011 To whom it may concern: The purpose of this letter is to verify that Stephen Fry was a resident of Keystone Correctional Services, Inc. from December 10th 2010- April 12th 2011. Our address is 7201 Allentown Blvd., Harrisburg, PA 17112. If you need further information please call (717) 651-0344 and ask to speak with the duty supervisor. Thank you in advance for your time and attention to this matter. Sincerely, Casey ell Counselor Keystone Correctional Facility, Inc.