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HomeMy WebLinkAbout12-2876IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA c CHARLES P. WEEMS, Plaintiff V. AMANDA L. RODRIGUEZ, Defendant C7 X M Zm z:0 c,nr- No. fog- d,8 76 Civil Fri CIVIL ACTION - PATE RNITN'' COMPLAINT TO ESTABLISH PATERNITY AND FOR GENETIC TESTING AND NOW, comes Charles P. Weems, by and through his Attorney, Jane Adams, Esquire, and requests genetic testing to establish paternity pursuant to 23 Pa.C.S. §4343 and in support of that request states that: v -0 Fri 1. Petitioner Charles P. Weems, is an adult individual, (hereinafter referred to as "Plaintiff'), who currently lives at 126 Martel Circle, Dillsburg, York County, Pennsylvania, 17019. 2. Defendant, Amanda L. Rodriguez, is an adult individual (hereinafter referred to as "Mother"), who lives at 111 East Main Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Defendant is the Natural Mother and Plaintiff believes that he may be the natural father of the following child: Emma Grace Rodriquez born April 18 2012 4. The above-named child resides at the following address with the following individuals: 111 East Main Street. Mechanicsburg Pennsylvania 17055, with Amanda L. Rodriguez, Mother. 5. Plaintiff and Defendant were not married at the time the child was conceived. 6. Defendant is not married. 7. There is no custody, support, or other action involving the paternity of the above-named child now pending in any jurisdiction. 8. There has not been a determination by any court as to the paternity of the child in any prior support, custody, divorce, or other action. 10.75?449? C# /0 7y 9. Plaintiff agrees to pay all costs associated with genetic testing directly to the testing facility in accordance with the procedures established by that facility. 10. Plaintiff desires to utilize the services of Cumberland County Domestic Relations, to perform testing in this matter, as their procedure is convenient and cost- effective. WHEREFORE, Plaintiff requests that the court order Defendant to submit to genetic testing and to make the child available for genetic testing. Respectfully submitted, Date Adams, Esquire 1. . No. 79465 West South St. St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PETITIONER VERIFICATION I verify that the statements made in this COMPLAINT FOR PATERNITY 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: !'--- - - - / Z Charles P. Weems, Petitioner U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHARLES P. WEEMS, Plaintiff V. AMANDA L. RODRIGUEZ, Defendant No. /.2 - A87,6 Civil Term CIVIL ACTION - PATERNITY NOTICE OF HEARING AND ORDER AND NOW, this Z..l day of 2012, upon consideration of the attached Complaint to Establish aternity, fi ed under he above- docketed number, a hearing is set for the day of , 2012, in Courtroom No. 0 at b •? a.m.4pox in the Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT: I cc: / Jane Adams, Esquire, for Plaintiff Amanda L. Rodriguez, Defendant ,t/G'I Piacey j. mas A. h o T audge Pleas Common -; -73 N cr> ? N y n ?c _ 7-1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHARLES P. WEEMS, Plaintiff V. AMANDA L. RODRIGUEZ, Defendant M? z? No. 1A_ 98 7Z Civil Frfi X CI CIVIL ACTION - PATE RN IT)W'W; COMPLAINT TO ESTABLISH PATERNITYAND FOR GENETIC TESTING AND NOW, comes Charles P. Weems, by and through his Attorney, Jane Adams, Esquire, and requests genetic testing to establish paternity pursuant to 23 Pa.C.S. §4343 and in support of that request states that: rv cm. rv E -J ca rJ 1. Petitioner Charles P. Weems, is an adult individual, (hereinafter referred to as "Plaintiff'), who currently lives at 126 Martel Circle, Dillsburg, York County, Pennsylvania, 17019. 2. Defendant, Amanda L. Rodriguez, is an adult individual (hereinafter referred to as "Mother"), who lives at 111 East Main Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Defendant is the Natural Mother and Plaintiff believes that he may be the natural father of the following child: Emma Grace Rodriguez, born April 18, 2012. 4. The above-named child resides at the following address with the following individuals: 111 East Main Street Mechanicsburg. Pennsylvania, 17055, with Amanda L. Rodriguez, Mother. 5. Plaintiff and Defendant were not married at the time the child was conceived. 6. Defendant is not married. 7. There is no custody, support, or other action involving the paternity of the above-named child now pending in any jurisdiction. 8. There has not been a determination by any court as to the paternity of the child in any prior support, custody, divorce, or other action. ,4 ios. ?spde? C# io 7y 9. Plaintiff agrees to pay all costs associated with genetic testing directly to the testing facility in accordance with the procedures established by that facility. 10. Plaintiff desires to utilize the services of Cumberland County Domestic Relations, to perform testing in this matter, as their procedure is convenient and cost- effective. WHEREFORE, Plaintiff requests that the court order Defendant to submit to genetic testing and to make the child available for genetic testing. Respectfully submitted, Date: P6 Adams, Esquire I. No. 79465 West South St. St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PETITIONER VERIFICATION I verify that the statements made in this COMPLAINT FOR PATERNITY 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: S- '-> -/Z Charles P. Weems, Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHARLES P. WEEMS, Plaintiff V. No. 12 -,2R 74 Civil Ter . -fir r AMANDA L. RODRIGUEZ, CIVIL ACTION - PATERNITY?;s- ?- Defendant - MOTION TO CONTINUE AND NOW, comes Charles P. Weems, by and through his Attorney, Jane Adams, Esquire, and requests genetic testing to establish paternity pursuant to 23 Pa.C.S. §4343 and in support of that request states that: 1. Petitioner Charles P. Weems, is an adult individual, (hereinafter referred to as "Plaintiff'), who currently lives at 126 Martel Circle, Dillsburg, York County, Pennsylvania, 17019. 2. Defendant, Amanda L. Rodriguez, is an adult individual (hereinafter referred to as "Mother"), who lives at 111 East Main Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Defendant is the Natural Mother and Plaintiff believes that he may be the natural father of the following child: Emma Grace Weems, born April 18, 2012. 4. Defendant filed a support action against Plaintiff. 5. A paternity test is now scheduled for June 26, 2012 at Domestic Relations. 6. A hearing regarding the paternity petition in this matter is scheduled for June 28, 2012. 7. Plaintiff is asking for a continuance of this matter, until the paternity test results are returned. 8. Plaintiff is asking for a continuance of three to four weeks; upon return of the paternity test, he will present such results before this Honorable Court, and ask for a court Order confirming the paternity of the child. 9. Plaintiffs counsel contacted Defendant on June 18, 2012, and she does not oppose the request for a continuance. 10. This matter was previously assigned to Judge Placey. WHEREFORE, Plaintiff requests for a continuance of this matter. Respectfully submitted, Date: Jar( Adams, Esquire . No. 79465 West South St. St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHARLES P. WEEMS, Plaintiff v. No. 12.-.29'7 (o Civil Term AMANDA L. RODRIGUEZ, CIVIL ACTION - PATERNITY Defendant NOTICE OF HEARING AND ORDER AND NOW, this li4b day of J uwcr , 2012, upon consideration of the attached Motion to Continue, filed under the above-docketed number, the hearing is now set for the day of Jua, 2012, in Courtroom No. -L at 1;3a on./p.m. in the Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT: cc: &/Jane Adams, Esquire, for Plaintiff ? Amanda L. Rodriguez, Defendant 4'es ".'Jed J. Thomas A. Placey -? Common Pleas Judge <? _. ca, Aet CHARLES P. WEEMS, Plaintiff v AMANDA L. RODRIGUEZ, Defendant IN RE: COMPLAINT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - PATERNITY NO. 12-2876 CIVIL TERM TO ESTABLISH PATERNITY ORDER OF COURT AND NOW, this 16th day of July, 2012, acting the compliant to establish paternity in genetic testing, upon review of the results of the genetic testing (Exhibit 3), Plaintiff is found to be the natural biological father of Emma Grace Weems born April 18, 2012. Father may seek to have his name added to the birth certificate. By the Court, Thomas A. Placey C.P.J. Jane Adams, Esquire 17 West South Street Carlisle, PA 17013 For Petitioner ? Amanda L. Rodriguez 111 East Main Street Mechanicsburg, PA 17055 Defendant :mae C-) n? Fri.- L _ ._.; -t> ... C4 _--I cry CHARLES P. WEEMS IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 12-2876 AMANDA L. RODRIGUEZ CIVIL ACTION - LAW C-3 Defendant IN CUSTODY -mz rn cn CA) WITHDRAWAL AND ENTRY OF APPEARANCE ° >w n -Q TO THE PROTHONOTARY OF SAID COURT: ?? PLEASE withdraw my appearance as attorney of record for the Plaintiff, CI A- R-tES j WEEMS, at the above-captioned docket. submitted by: Dated: 747 ?7Vest South Street Aisle, PA 17013 Phone: (717) 245-8508 PLEASE enter my appearance as attorney of record for the Plaintiff, CHARLES WEEMS, at the above-captioned docket. By: / Dated: -7 Z ?- -? Thomas M. Clark, Esquire Attorney ID # 85211 130 West Church Street Suite 100 Dillsburg, PA 17019 Phone: (717) 502-5000 Fax: (717) 502-5050 ?a o -`„ ?rn