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Home My WebLink About14-3474v Sheri D. Coover, Esquire Attorney ID 93285 Carrucoli and Associates 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 THE PROT HONO1Ai-\\; JUN 10 PM !c: 53 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TANNER J. DUGAN, Plaintiff : CASE NO. /., 3y7 L/ Cf,'v. 1 v. l AMBER R. BOOSE, : PATERNITY ACTION Defendant COMPLAINT TO ESTABLISH PATERNITY AND FOR GENETIC TESTING PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 1930.6 AND NOW, comes Plaintiff, Tanner J. Dugan, by and through his counsel, Sheri D. Coover, Esquire and the law firm of Carrucoli and Associates, and files the following COMPLAINT TO ESTABLISH PATERNITY AND FOR GENETIC TESTING PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 1930.6 and in support thereof avers as follows: 1. Plaintiff is an adult individual who resides at 106 Deerview Drive, Newville, Pennsylvania 17241 and who is hereinafter referred to as "Father". 2. Defendant is an adult individual who resides at 5 McDermond Road, Newville, PA 17241 and who is hereinafter referred to as "Mother". 3. Defendant is the biological mother and Plaintiff believes he may be the biological father of Alaura M. Dugan whose date of birth was January 15, 2014 (hereinafter referred to as the "Minor Child"). 4. The Minor Child resides at 5 McDermond Road, Newville, Pennsylvania with Mother, Ray and Michelle Boose (maternal grandparents), Barbara Neidigh (maternal great- grandmother), and sibling of Mother. 5. Mother was not married at the time that the child was conceived or born. 6. Mother is currently unmarried. 7. Father is unaware of any other custody, support or other action concerning the Minor Child pending in this Court or any other jurisdiction. 8. There has not been a determination by any Court as to the paternity of the Minor Child in any prior support, custody, divorce or other action. 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. WHEREFORE, Father requests that the Court Order Mother to submit to genetic testing and to make the Minor Child available for genetic testing over, Esquire orney ID 93285 Carrucoli and Associates 44 S. Hanover Street Carlisle, PA 17013 1703. i 104 f 3 3 Y5' /2—A3c)-747k Sheri D. Coover, Esquire Attorney ID 93285 Carrucoli and Associates 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TANNER J. DUGAN, Plaintiff v. AMBER R. BOOSE, Defendant : CASE NO. : PATERNITY ACTION VERIFICATION I, Sheri D. Coover, Esquire, hereby verify that I reviewed the statements made in the COMPLAINT TO ESTABLISH PATERNITY AND FOR GENETIC TESTING PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 1930.6 with Tanner J. Dugan and that he expressed to me that they are true and correct to the best of his knowledge, information and belief. I understand that I can be subject to the penalties of perjury pursuant to 18 Pa.C.S. § 4904 for any false statements contained therein. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TANNER J. DUGAN, • Plaintiff • �-7�/ / CASE NO. /y- 3y / / L:'�': I ' �� v. AMBER R. BOOSE, : PATERNITY ACTION Defendant 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 you granting the relief requested by the Plaintiff. .2""41,130 p.M Plaintiff and Defendant are directed to appear on the 36 day of 41 2014, in Courtroom# 3 for a hearing on Plaintiff's request for genetic testing. If you fail to appear as Ordered, the Court may issue an Order in your absence requiring you and the Minor Child to appear for genetic testing. 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 OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717)249-3166 ,, 4)Y cn r- t 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. BY (0(4?'// Date n2.ai.t , 11-4..c C Oa u est- a L ett_ 1.1,2/,y TANNER J. DUGAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 14-3474 CIVIL TERM AMBER R. BOOSE, Defendant PATERNITY ACTION ORDER OF COURT AND NOW, this 30th day of June, 2014, it appearing to the Court that the parties agree that Plaintiff is the father of the minor child, Alaura Mae Dugan, born January 15, 2014, and it further appearing that, Defendant has filed a support action, the Request for Paternity Testing is DENIED. By the Court, Edward E. Guido, J. " Sheri D. Coover, Esquire Carrucoli and Associates A.torney for Plaintiff Amber R. Boose 5 McDermond Road Newville, PA 17241 SYS 0-Tr'es fi2eU- 7/0.1/iif r-- N