The URL can be used to link to this page

Home My WebLink About11-8999 STEVEN MICAHEL FRY Plaintiff V. REBECCA MCKINLEY FRY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • NO: II- BQgq alvil Icrm IN RE: PATERNITY rn c --r zm Fn M r r<T Cn a+ i PETITION AND AFFIDAVIT FOR LEAVE TO PROCEk IN FORMA PAUPERIS PURSUANT TO P.A. R.C.P. n CD ?. 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. 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: 11/09/11 Steven Michael Fry PM? Integrated Offender Case Management System 1111/2011 8:46:42 AM Monthly Account Statement From Date: 10/01/2011 To Date: 11/01/2011 Institution: GRN - Greene cation Case ID Offender Name Current Balance Escrow Balanc :N-K-A-2034-01 GX4964 FRY,STEVEN 2.32 n n 2N-012801 10/31/2011 37-Postage . 0.20 -2.32 2N-012736 10/25/2011 37 - Postage -0.44 -2.12 2N-012723 10/24/2011 37 - Postage -0.44 -1.68 RN-012723 10/24/2011 37 - Postage -0.44 -1.24 RN-012723 10/24/2011 37 - Postage -0.44 -0.80 RN-012687 10/20/2011 37 - Postage -1.68 -0.36 2N-012687 10/20/2011 37 - Postage -1.68 1.321 RN-012687 10/20/2011 37 - Postage -0.44 3.00 2N-012674 10/19/2011 36 - Library Copies -0.20 344 2N-012625 10/14/2011 32 - Commissary GRN COMMISSARY FOR 10/14/2011 -10.77 3.64 2N-012578 10/11/2011 37 - Postage -0.44 14.41 RN-012559 10/07/2011 10 - Maintenance Payroll GRP 1 -1st - End of Month +15.12 14.85 2N-012497 10/0412011 37 - Postage -0.44 -0.27 Page 1402 of 1734 STEVEN MICHAEL FRY Plaintiff V. REBECCA MCKINLEY FRY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: IN RE: PATERNITY CERTIFICATE OF SERVICE I verify that the foregoing motion was served to the following parties listed below by First Clas United States Mail: Rebecca McKinley Fry 22 Regency Woods North Carlilse, Pa 17015 Date: 11/09/11 Steven Michael Fry I STEVEN MICHAEL FRY Plaintiff V. REBECCA MCKINLEY FRY Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO: 11- 89g q elvd7em IN RE: PATERNITY COMPLAINT TO ESTABLISH PATERNITY AND FOR GENETIC TESTING 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 17015. 3. Defendant is the natural mother and Plaintiff be- leives that he may not be the natural father of the fe)llMi children: (= C= ?m m 71r- Child's name D.O.B. u' 'ut t:D'= .? ?C = T CD-r Jenna Lee Fry Foose 10/30/11 xc , rv 4 c..n 4. The above named child resides at 22 Regency Woods m' North, Carlisle, Pennsylvania, 17015, with the Defendant who is the natural mother of the child. 5. Defendant was married at the time the child was conceived. 6. Defendant is currently married to the Pla&-miff' 7. There is not a custody support or other action in- volving the paternity of the above named child or any other pending in this jurisdiction. 8. There has not been a determination by any Court as to the paternity of the child in any prior support, custody, or divorce or any other action. 9. The Plaintiff and Defendant seperated on April 2, 2011, and have been seperated since. (See Exibit A; Support Complaint 10. During the relevant period Plaintiff had no access to the Defendant 1fortPlaintifwas conceived in a State Correctional tff was housed Community Center. (See Exibit B; Verifi- cation letter dated August 1, 2011) 11. There is no family unit to protect or perserve for it has been destoryed by seperation. 12. Plaintiff is currently incarcerated in a State Correc- tional Institution. 13. 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. 14. I verify that the foregoing is true and correct to the best of my knowledge and or belief and that false statements are subject to pentalitY under 18 Pa C.S.A. § 4904, False State- ments to Authorities. WHEREFORE, Plaintiff respectfully request this Honorable Court to order the Defendant to submit to Genetic Testing and to make the child available for Genetic Testing. Respectfully Submitted, Date: 11 /09/11 c-- Steven Michael Frv In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION REBECCA M. FRY Plaintiff )Docket Numbsr. 01087 S 2009 VS. ) STEVEN M. FRY PACSES Case Number. 592111361 ) DtNendar>t do )Other State ID Number J tM Comniaint for Smart O New Complaint O Amended Complaint 1. Plaintiff resides at 22 REGENCY WOODS N, CARLISLE, PA. 17015-9059-22 CUMBERLAND County. Plaintiffs date of birth is 07113/83 2. Defendant resides at C/O KEYSTONE, 7201 ALLENTOWN BLVD, HARRISBURG, PA. 17112-3646-99 DAUPHIN County. n 03 O Def'endant's date of birth is 05/20/71 amr. r N r. + ? 37 3. (a) Plaintiff and Defendant were married on MARCH 12, 2009 0C"3 - at PALAKA, FLORIDA ^?= D (b) Plaintiff and Defendant were separated on APRIL 2 2011 Cz . , (c) Plaintiff and Defendant were divorced on w (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 DEVON M. FRY Birth Date Age 06/09/09 1 Born of the Marriage Y = Yes, N = No Y Residence: W/PLNT Residence: Form I N-005 Service Type M Worker ID 21502 K INC 7201 Allentown Blvd. Harrisburg, PA 117112 1 Phone (717) 651-0340 1 Fax (717) 651-0265 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 10`h 2010- April 12`h 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, V` Casey ell ) Counselor Keystone Correctional Facility, Inc. STEVEN MICHAEL FRY Plaintiff V. REBECCA MCKINLEY FRY Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO: IN RE: PATERNITY MOTION FOR TESTIMONY BY ELECTRONIC MEANS PURSUANT TO PA R.C.P. RULE 1930.3 Plaintiff, Steven Michael Fry, Pro Se, respectfully files the following MOTION FOR TESTIMONY BY ELECTRONIC MEANS and in support thereof avers the following: 1. Plaintiff has filed to Establish Paternity and for Genetic Testing. 2. Plaintiff is currently incarcerated in a State Correctional Institution. 3. The county of Cumberland will likely not GRANT Plaintiff a Writ of Habeus Corpus to attend any hearing to this procedure. 4. I verify that the foregoing is true and correct to the best of my knowledge and belief and that a false statement is subject to pentalty under 18 PA C.S.A § 4904, False Statement to Authority. WHEREFORE, Plaintiff respectfully request this Honorable Court allow any testimony needed for this procedure to be done by Electronic means pursuant to PA R.C.P. Rule 1930.3. Respectfully Submitted, Date:11/09/11 S Steven Michael Fry STEVEN M. FRY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. REBECCA NICKINLEY FRY, NO. 2011 - 8999 CIVIL Defendant IN RE : IN FORMA PAUPERIS r c c7 ORDER OF COURT AND NOW, this 18TH day of JANUARY, 2012, based on the attached petition to proceed IN FORMA PAUPERIS, Plaintiff's Motion Is GRANTED. By they` t, Edward E. Guido, J. Steven iichael Fry GX-4964 175 Progress Drive Waynesburg, Pa. 15370 : s l d (> YYII . Y i? ! .? ?i