HomeMy WebLinkAbout12-7014IN THE COURT OF COMMON PLEAS OF ~
CUMBERLAND COUNTY, PENNSYLVANIA -~~ ^~
CHARLES K. MESSICK,
Plaintiff
v.
ALLISON FORBES.
Defendant
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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:
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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.
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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 /~
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Charles K. Messick, Petitioner
CHARLES K. MESSICK, of It --love 0 0 MT
Plaintiff � �
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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 =-`
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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:
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fitness 7 Alexandrea Stahl, Mother
* Date: � , f l
NZ, � 3
fitness Charles K. Messick, Father
., • . Date: r
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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
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