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Home My WebLink About12-2038JAMIE SMITH, IN THE COURT OF COMMON PLEAS .. Plaintiff , COUNTY OF CUMBERLAND, PENNSaVaIA V NO. /a - 01038 CIVIL TERM . . CAITLYN KEEPER, CIVIL ACTION - LAW Defendant -v ; --; PETITION TO ESTABLISH PATERNITY AND FOR GENETIC TESTING PURSUANT TO 23 PA C.S.A. §4343 Plaintiff, Jamie Smith, by and through his counsel, Marylou Matas, Esquire, requests genetic testing to establish paternity pursuant to 23 Pa. C. S. § 4343 and in support of that request states the following: 1. Plaintiff is an adult individual who resides at 270 Spanglers Mill Road, New Cumberland, Cumberland County, Pennsylvania, 17070. 2. Defendant is an adult individual whose last known address is 15 Robert Paul Drive, Etters, Pennsylvania, 17319. 3. Defendant is the natural mother and Plaintiff believes that he may be the natural father of the following child: Kaia Keffer January 3, 2012 4. The above named child resides at the following address with the following individuals: Plaintiff is currently unaware as to who the child is residing with. Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 5. Defendant was not married at the time the child was conceived or born. 6. Defendant is not now married. 7. Plaintiff and Defendant were in a relationship and lived together for approximately two (2) years until August 2011, at which time the parties separated. 8. Plaintiff and Defendant are not married to each other and have not ever been. 9. There is not a custody, support or other action involving the paternity of the above-named child not pending in any jurisdiction. -$1o3. 75 PO Airy a#3a.S53 a#d 73/(05" 10. 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. 11. In the event Plaintiff is determined by a 99% or greater probability that he is the father of the child, Plaintiff agrees to pay all costs associated with genetic testing directly to the testing facility in accordance with the procedures established by that facility. 12. A copy of this Petition has been forwarded to the Defendant. 13. No prior Judge has been assigned to any matter involving Plaintiff and Defendant. Wherefore, Plaintiff requests that the court order Defendant to submit to genetic testing and to make the child available for genetic testing. Respectfully submitted, SAIDIS, SULLIVAN & ROGERS Hannah White-Gibson; Esquire Attorney ID. 311679 26 West High Street Carlisle, PA 17013 Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 VERIFICATION to I verify that the statements made in this complaint are true and correct to the best of my edge, information and belief. I understand that false statements herein are made subject penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. mie Smith, Plaintiff Law Offices of & Rog rq 26 West High ree Carlisle, PA 1 13 JAMIE SMITH, Plaintiff V. CAITLYN KEFFER, Defendant IN THE COURT OF COMMON PLEAS COUNTY OF CUMBERLAND, PENNSYLVANIA NO. CIVIL TERM CIVIL ACTION - LAW CERTIFICATE OF SERVICE This is to certify that in this case, complete copies of all papers contained in the attached document have been served upon the following persons by the following means and on the dates stated: Name & Address Caitlyn Keefer 15 Robert Paul Drive Etters, PA 17319 Means of Service Regular Mail, First Class Date of Service 3//12 Date: 3/,Zq//2 Hannah White-Gibson, squire Attorney ID 311679 Attorney for Plaintiff 26 West High Street Carlisle, Pennsylvania 17013 (717) 243-6222 Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 JAMIE SMITH, Plaintiff V. IN THE COURT OF COMMON PLEAS THE NINTH JUDICIAL COURT CIVIL ACTION - LAW CAITLYN KEFFER Defendant CIVIL ACTION NO: 2012-2038 IN RE: PETITION TO ESTABLISH PATERNITY AND FOR GENETIC TESTING PURSUANT TO 23 PA C.S.A. §4343 ORDER OF COURT AND NOW, this 10th day of April 2012 upon consideration of the "Petition to Establish Paternity and for Genetic Testing Pursuant to 23 PA C.S.A. § 4343" it is hereby directed that a hearing will be held on 24 May 2012 at 1:30 p.m. in Courtroom No. 6 of the Cumberland County Courthouse, Carlisle, Pennsylvania. Distribution List: Hannah White-Gibson, Esq. 26 West High Street Carlisle, PA 17013 Counsel for Plaintiff Caitlyn Keffer 15 Robert Paul Drive Etters, PA 17319 Cvpe,S ma.IeW 4I11 j1 a mh a4- BY the Co"It Thomas A. Placey C.P.J. t?J r L\ r e ?J n a, t? ?i tk 1? k N j JAMIE SMITH, Plaintiff V. CAITLYN KEFFER, Defendant IN THE COURT OF COMMON PLEAS COUNTY OF CUMBERLAND, PENNSYLVANIA NO. /O 'L- a2p38 CIVIL TERM CIVIL ACTION - LAW 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 yo granting the relief requested by the plaintiff. ?L G? 4Plaintiff and Defendant are directed to appear the? day of 2012 at : * M. in courtroom for a hearing on Plauest for genetic testing. If you fail to ap ear as ordered, the court may enter an order in your absence requiring you and your child to submit to genetic tests. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 Americans with Disabilities Act of 1990 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. SAIDIS, SULLIVAN & ROGERS Hannah White-Gibson, Esquire Attorney Id. 311679 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 JAMIE SMITH, Plaintiff v CAITLYN KEFFER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NINTH JUDICIAL DISTRICT CIVIL ACTION - LAW NO. 2012-2038 CIVIL TERM IN RE: PETITION TO ESTABLISH PATERNITY -? N AND FOR GENETIC TESTING ORDER OF COURT c. AND NOW, this 24th day of May, 2012, pri&r 5_ e? hearing, both parties consenting to testing, it is ordered and directed that both parties submit to genetic testing. The parties are directed to schedule an appointment with the Domestic Relations Office at the next available testing time. The parties are further directed to contact the Domestic Relations Office within 5 days of today's date to schedule that next available time. By the Thomas A. lacey C.P.J. /Hannah White-Gibson, Esquire 26 West High Street Carlisle, PA 17013 For Plaintiff Caitlyn Keffer 15 Robert Paul Drive Etters, PA 17319 Defendant, pro se mae de ies IuCCc ?Pd S` ?/?/. Rg .6-