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HomeMy WebLinkAbout12-7014IN THE COURT OF COMMON PLEAS OF ~ CUMBERLAND COUNTY, PENNSYLVANIA -~~ ^~ CHARLES K. MESSICK, Plaintiff v. ALLISON FORBES. Defendant ~m o ~ ~ -c ~ - ..< A to ~~ No. l~ ~ CIO / ~ Civi~rmc, CIVIL ACTION - PATERNITY- COMPLAINT TO ESTABLISH PATERNITY AND FOR GENETIC TESTING AND NOW, comes Charles K. Messick, 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: .~.., _f .T.j ~ ^- o [~ -r ~, ..~; 1. Petitioner Charles K. Messick, is an adult individual, (hereinafter referred to as "Plaintiff"), who currently lives at 1104 Woodlot Road, Manheim, Lancaster County, Pennsylvania, 17545. 2. Defendant, Allison Forbes, is an adult individual (hereinafter referred to as "Mother"), who lives at 16780 Cumberland Highway, Newburg, Cumberland County, Pennsylvania, 17240. 3. Defendant is the Natural Mother and Plaintiff believes that he may be the natural father of thE. following child: Austin Wyatt Forbes. born October 5. 2012. 4. The above-named child resides at the following address with the following individuals: 16780 Cumberland Highway. Newburg. Cumberland County Pennsylvania with Daniel Redcav. 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. C~ ~/8d~ 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: (~ ~ ~ ~ Z- Ja Adams, Esquire . 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: ~~ r/c1 4 /~ E~r~~1°~ Charles K. Messick, Petitioner CHARLES K. MESSICK, of It --love 0 0 MT Plaintiff � � >�I V. IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT 2012-07014 CIVIL_ TERM ALEXANDREA STAHL, Defendant CIVIL ACTION — PATERNITY IN RE: COMPLAINT TO ESTABLISH PATERNITY ORDER OF COURT AND NOW, this 25th day of March 2013, upon information received by the court that the paternity test has been completed and the result made known to the parties, a brief status conference is scheduled for 1 April 2013 at 10:30 a.m. in Courtroom No. 6 of the Cumberland County Courthouse, Carlisle, Pennsylvania, solely to determine the parties need for the court in their next steps. If the parties can agree on an order based on the result, which is unknown to the court, the court will issue that order to expedite this process. BY THE COURT, Thomas Placey C.P.J. Distribution: Jane E. Adams, Esq. Alexandrea Stahl, pro se - cN- r =-` r -p M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHARLES K. MESSICK, Plaintiff V. No. 2012 - 7014 Civil Term ALEXANDREA STAHL, CIVIL ACTION - PATERNITY Defendant MOTION TO ENTER ORDER REGARDING PATERNITY AND NOW, comes Charles K. Messick, by and through his Attorney, Jane Adams, Esquire, and files the following Motion to Enter an Order regarding Paternity, and in support of that request states that: 1. Petitioner, Charles K. Messick, is an adult individual, (hereinafter referred to as "Plaintiff"), who currently lives at 1104 Woodlot Road, Manheim, York County, Pennsylvania, 17545. 2. Defendant, Allison Forbes, is an adult individual (hereinafter referred to as "Mother"), who lives at 16780 Cumberland Highway, Newburg, Cumberland County, Pennsylvania, 17240. 3. The parties are the natural parents of Austin Wyatt Forbes, born October 5, 2012. 4. Pursuant to this Paternity action, the parties participated in DNA testing. The results of the test are attached to this Petition as Exhibit A. 5. After receipt of the testing results, the parties executed a stipulation regarding paternity of the child, which is attached as Exhibit B. 6. Petitioner, Charles K. Messick, is requesting that the attached proposed Order be entered as final Order of court regarding Paternity. 7. The parties are in agreement regarding this request. 8. This matter was assigned to Judge Thomas A. Placey. WHEREFORE, Plaintiff requests that the court enter the attached Order regarding Paternity. Respectfully submitted, Date: � a / � ' J Adams, Esquire No. 79465 7 West South St. St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PETITIONER DNA Test DNA Diagnostics Center Report COPY Cumberland County Domestic Relations PA 0D,305 DDC is accreditcd/certified by AABB,CAP,ACLASS-International,ISO/11 c 17025,CLIA,NYSDOH&ASCL.D/LAB-International. ' Case 1274036 MOTHER CHILD Alleged FATHER Name Alexandrea Stahl Austin Stahl Charles Messick Race Caucasian Caucasian Date Collected 3/5/2013 3/5/2013 3/5/2013 Test No. 1274036-10 1274036-20 1274036-30 Interpretation: RN.666390 Combined Paternity Index: 18,279,691 Probability of Paternitv_ 99.99999% The alleged father is not excluded as the biological father of the tested child. Based on testing results obtained from analyses of the DNA loci listed.the probability of paternity is 99.99999%. This probability of paternity is calculated by comparing to an untested,unrelated,random individual of the Caucasian population (assumes prior probability equals 0.50). Subscribed and sworn,heM3ttliuv f)n March 11 I.the undersigned L.aboratory Director,cerif\ that the %`PRA AL cSS interpretation of the results is cornet as reported on 3:11,'2013. 0 Edward Harris S, Q Nlichael L.Baird.Ph.D. l homas M.Reid,Ph.D. Notary Public,St Ex ��,��,.� Marco Scarpetta.Ph.D. Richard Chmelo.Ph.D. i�9y Commission EstSfru 1t}ti��,2013 Tricia 1).Frye.Ph.D. John W.Peterson,Ph.D. Debra I..Davis.Ph.D. .toy Johnson,Ph.D. 1.513.881.7800 One DDC Way Fairfield, OH 45014 U.S.A. www.DNAcenter.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHARLES K. MESSICK, Plaintiff : V. No. 2012 - 7014 Civil Term ALEXANDREA STAHL, CIVIL ACTION - PATERNITY Defendant STIPULATION OF THE PARTIES AND NOW COME, the parties to this action, Charles K. Messick, (hereinafter "Father"), and Alexandrea Stahl (hereinafter "Mother"), and stipulate as follows: 1. The parties participated in paternity testing which showed that Charles K. Messick is the natural Father of Austin Wyatt Stahl. 2. The parties consent to an Order confirming that Charles K. Messick is the natural Father of Austin Wyatt Stahl. 3. The parties consent to the addition of Charles K. Messick as Father on the birth certificate of Austin Wyatt Stahl. WITNESSETH: rO&dl )"z fitness 7 Alexandrea Stahl, Mother * Date: � , f l NZ, � 3 fitness Charles K. Messick, Father ., • . Date: r R - a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHARLES K. MESSICK, Plaintiff V. No. 2012 - 7014 Civil Term ALEXANDREA STAHL, CIVIL ACTION - PATERNITY Defendant n ORDER OF COURT AND NOW, THIS day of 4110j , 2013, pursuant to the petition filed in this matter, the motion and exhibits, and the stipulation of the parties, it is hereby ORDERED AND DECREED as follows: 1. Charles K. Messick is the father of Austin Wyatt Stahl, born October 5, 2012. 2. Charles K. Messick shall be added and listed as the Father on the birth certificate of Austin Wyatt Stahl. BY -1 : Thomas A. Placey, C.P.J. cc: /Jane Adams, Esquire, for Plaintiff ZAlexandrea Stahl, Defendant ' 'VINVAIASNN3d • AINnaa awogwna �,�