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Home My WebLink About14-4041Sheri D. Coover, Esquire Attorney ID 93285 Carrucoli and Associates 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 CUMBERLAND CUU! 1 PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAVEY W. BANKERT, Plaintiff v. : CASE NO. /9— 7 ° y� et RUEHET JACOBS, : PATERNITY ACTION Defendant COMPLAINT TO ESTABLISH PATERNITY AND FOR GENETIC TESTING PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 1930.6 AND NOW, comes Plaintiff, Davey W. Bankert, 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 115 Woodview Drive, Mt. Holly Springs, Pennsylvania 17065 and who is hereinafter referred to as "Father". 2. Defendant is an individual who is seventeen (17) years of age who resides at 1408 Walnut Bottom Road, Carlisle, PA 17013 and who is hereinafter referred to as "Mother". 4/03.75 ?cmt C# 3e#0/ ,eft 30831 v 3. Defendant is the biological mother and Plaintiff believes he may be the biological father of Rhett Jacobs whose date of birth was May 14, 2014 (hereinafter referred to as the "Minor Child"). 4. The Minor Child resides at 1407 Walnut Bottom Road, Carlisle, Pennsylvania with Mother, Stephanus and Marie Jacobs (maternal grandparents), Devillers (age 18, maternal uncle) and D.J. (age 24, maternal uncle). 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. submitted, ri D. Coover, Esquire ttorney ID 93285 Carrucoli and Associates 44 S. Hanover Street Carlisle, PA 17013 heri D. Coover. Esquire Attorney ID 93285 Carrucoli and Associates 44 S. Hanover Street Carlisle, PA 17013 .17)960-0075 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA OAVEY W. BANKERT, Plaintiff : CASE NO. RUEHET JACOBS, : PATERNITY ACTION Defendant VERIFICATION I, Davey W. Bankert, hereby verify that the statements made in the COMPLAINT TO ESTABLISH PATERNITY AND FOR GENETIC ILSTING PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 1930.6 are true and correct to the best of my 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. Davey W. Bankert Date IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAVEY W. BANKERT, Plaintiff v. • • CASE NO. /7. 7 c / / 0! L �/ RUEHET JACOBS, : 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. Plaintiff and Defendant are directed to appear on the 5 -Nay of y +tiP.�cr' , at - 2014, in Courtroom # o)- for a hearing on Plaintiff's request for genetic testing. If you fail a,; 0 VIN., 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 TI 'APER 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 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. *ht.\ Date e DUCy. £t .e•tvd-- Taco As, L'9pi esw - id 711e1/v BY THE COURT: C) CO rn 7-3 -< C) f Sheri D. Coover, Esquire Attorney ID 93285 Carrucoli and Associates, P.C. 44 S. Hanover Street Carlisle, PA 17013 (717) 243-9190 LLB-OFFICEM , i_ IHE PROTHONO tr��i 2011+ JUL 28 PM 3: 25 CUMBERSYLVAM COUNTY TY DAVEY W. BANKERT, Plaintiff v. RUEHET JACOBS, : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : CASE NO. 14-4041 CIVIL Defendant : PATERNITY ACTION AFFIDAVIT OF SERVICE I, Sheri D. Coover, Esquire hereby certify that I did serve a true and correct copy of the PLAINTIFF'S COMPLAINT TO ESTABLISH PATERNITY AND FOR GENETIC TESTING PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE RULE 1930.6 to be served upon Defendant by depositing or causing to be deposited in the U.S. mail certified, restricted delivery, postage prepaid to Ruehet Jacobs addressed as follows: Ruehet Jacobs 1408 Walnut Bottom Road Carlisle, PA 17013 Return card acknowledging receipt on July 14, 2014 is attached as "Exhibit A." O- ` - cxfully s bmitted, hen P . Coover, Esquire Attorney ID 93285 Carrucoli and Associates 44 S. Hanover Street Carlisle, PA 17013 (717) 243-9190 Sheri D. Coover, Esquire Attorney ID 93285 Carrucoli and Associates, P.C. 44 S. Hanover Street Carlisle, PA 17013 (717) 243-9190 DAVEY W. BANKERT, Plaintiff v. RUEHET JACOBS, : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : CASE NO. 14-4041 CIVIL Defendant : PATERNITY ACTION CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certify that on the 28th day of July, 2014, I caused the foregoing AFFIDAVIT OF SERVICE to be served upon Defendant by United States first class mail addressed as follows: Ruehet Jacobs 1408 Walnut Bottom Road Carlisle, PA 17013 tfully submitted, heri D. Coover, Esquire Attorney ID 93285 Carrucoli and Associates 44 S. Hanover Street Carlisle, PA 17013 (717) 243-9190 I. SENDERRCOMPLETETHMSECTI 111 Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. • Print your name and address on the reverse so that we can return the card to you. ▪ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Ru..e.r)e+ ‘cobs NO2 woonLer ‘3otNyo Co -\e PA 1-7 0 )3 A. Signature • e/ ,/,orprf; 0 Agent 0 Addressee C. Date of Delivery ' B. Receive by (Prin c i Name) ehet 7-14-(ei D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No 3. Service Type 121*6ertifled Mail® 0 Pridity Mail Express" 0 Registered 0 Return Receipt for Merchandise 0 Insured Mail 0 Collect on Delivery 4. Restricted Delivery? (Extra Fee) 4a.feS 2. Article Number (rransfer from service 7010 PS Form $811, July 2013 670 0001 6157 2459 Domestic Return Receipt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAVEY W. BANKERT, Plaintiff v. : CASE NO. /I—a9/ c--/v.L. RUEHET JACOBS, : PATERNITY ACTION CORDER AND NOW, this day of S t+Q} • , 2014, after consideration of PLAINTIFF'S COMPLAINT TO ESTABLISH PATERNITY AND FOR GENETIC TESTING PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 1930.6, the Plaintiff's request is GRANTED and Plaintiff, Defendant and the Minor Child, Rhett Jacobs, are Ordered to submit to genetic testing at a date and time as directed by the Cumberland County Domestic Relations Office. Defendant Distribution List: Aheri D. Coover, Esquire (on behalf of Plaintiff) Carrucoli and Associates, 44 S. Hanover Street, Carlisle, PA 17013 /Ruehet Jacobs (pro se') 1408 Walnut Bottom Road, Carlisle, PA 17013 Adti