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Home My WebLink About07-0622KOPE ~ ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA IN RE: M.R.K. NO. a'C -- ~~,.~ ~ ~v ~~,~ . ~~ :CIVIL ACTION PETITION FOR NAME CHANGE 1. Petitioner is John Darcy, III, the guardian, primary custodian and natural father of Megan R. Knob, an eleven year old minor who was bom on April 7, 1995. 2. Petitioner desires to change his child's name from Megan R. Knob to Megan R. Darcy. 3. There are no judgments or decrees of record or any other matter of like character against the child. 4. Petitioner's reasons for desiring this change of name of his child are as follows: a. Petitioner is not married to the child's natural mother and Petitioner has the surname of Darcy; b. Petitioner has had primary custody of the child and the child would benefit from sharing Petitioner's surname; r c. The child is of the age where she attends school and Petitioner desires to protect his child from the psychological and emotional confusion which may result from the child and parent having two different surnames; and d. The child's natural mother, Marie Smiley, nee Knob, is in agreement with this petition to change the surname of the child. 5. From August of 2006 up to the present, the subject of this Petition has lived with her natural father, the Petitioner, at 2138 Yale Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. 6. From approximately August of 2004 until August of 2006, the subject of this Petition lived with her natural mother at 215 North Hartley Street, York, York County, Pennsylvania 17401. 7. From 2002 until approximately August of 2004, the subject of this Petition lived with her natural mother at 100 River Road, Columbia, Lancaster County, Pennsylvania 17512. WHEREFORE, Petitioner respectfully requests that this Honorable Court: a. Fix a hearing on this petition; and b. Direct that notice be given of the filing of this petition and the hearing to the non-petitioning parent. WHEREFORE, Petitioner further requests that this Court waive the requirement for official searches of the proper offices of the county wherein Petitioner resides on the grounds that the subject of this petition is a minor and Petitioner avers .. that there are no judgments or decrees of record or any other matter of like character against the child. WHEREFORE, per 54 Pa.C.S.A. § 701(a.1)(3)(iii), Petitioner further requests that this Court waive the requirement for publication of the notice in two newspapers of general circulation on the grounds that the subject of this petition is a minor, and Petitioner does not wish for predators or the like to have access to the child's name and address. Respectfully Submitted, KOPE 8~ ASSOCIATES, LLC By: ~~. esley m, sq. Dated: ~ ~ ~ ~ ~ r VERIFICATION I, John Darcy, III, the Petitioner in this matter, have read the foregoing Petition for Name Change. I verify that my averments in this Petition are true and correct and based upon my personal knowledge. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsifications to authorities. ~..--~ s,..~~~ Dated: o~ G ~, ohn arcy If °~ ~.... 4;; .5 v • ... _ _~ 1 ~ /`'~` / _ ~ !"" ~~~? v ~ - ~ 'rill IN RE: M.R.K. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW N0.07-622 CIVIL TERM ORDER OF COURT AND NOW, this 8th day of February, 2005, upon consideration of the attached Petition for Change of Name, a hearing is scheduled for Monday, April 30, 2007, at 11:00 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. IT IS FURTHER ORDERED that notice of the filing of said Petition and the aforesaid date, time and place of the hearing be published once in the Cumberland Law Journal and a newspaper of general circulation in the County at least 10 days prior to the hearing; in addition, Petitioner shall comply with all other requirements of C.C.R.P. 5, and the Act of December 16, 1982, P.L. 1309, §6 (see 54 Pa. C.S. §701 [Historical and Statutory Notes] [Main Volume]), and 54 Pa. C.S. §§701 et seq. IN ADDITION, notice of the petition and hearing time and place shall be provided to the child's natural mother at least 20 days prior to the hearing by regular mail and by certified mail. BY THE COURT, l J. ~/esley Oler, J"r., J. esley J. Beam, Esq. 4660 Trindle Road Suite 201 Camp Hill, PA 17011 ~ Attorney for Petitioner :rc ~ s : ~ ~ ~ z ~ ~~~ caoz /~1~vJ~ i.~.~~~ 3!-i~. ~0 3~71~M'.~'11~ r KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA IN RE: M.R.K. NO. 07-622 CIVIL ACTION AFFIDAVIT AND RETURN OF SERVICE AND NOW comes Kope & Associates, LLC by LESLEY J. BEAM, attorney for John Darcy, natural father of M.R.K., and states that service of the Petition for Name Change and Order of Court scheduling the hearing in this matter was made by him upon Marie Smiley, natural mother of M.R.K., by posting the same in the U.S. Mail, postage prepaid, at Camp Hill, PA by Certified Mail No. 7004 2510 0007 6450 2438, Return Receipt Requested on February 15, 2007, to her mailing address, at 608 West Princess Street, York, PA 17401, which mail was received by Marie Smiley on February 20, 2007, all in accordance with PA. R.C.P. 412 and 403. The mailing receipt and the return receipt or true copies thereof are attached hereto and made part hereof, together with the cover letter mailed to Defendant. LES J. EAM, Esq. Atto ev for Petitioner ~ '' N O ' m ~- ru a ,~ ~_ ~ E ~ Q N ~ ~ ..~ ~ ~ N ~~ z~ m s rd~ CV 2i r{ ~i i o N a 'i W to ~$ ~~ . bo ~~~ ~~~~~ ns M 4~ • ~ ~ ., QE+~2 OSfi9 L~dO O'CS2 +~~OL ,~ '"""'~ M K O P E ASSOCIATES LAW OFFICES LLC VIA CERTIFIED MAIL and FIRST CLASS MAIL Marie Smiley 608 West Princess Street York, PA 17401 Re: In Re: M.R.K. 07-622 Dear Ms. Smiley, February 15, 2007 I represent John Darcy, III, in the above captioned matter. Enclosed and served upon you is the Petition for Name Change, filed with the Cumberland County Court of Common Pleas, and Order of Court scheduling the Hearing. 1 am sending these papers to you directly because I have no information that you are represented by an attorney. Please be aware that the Hearing has been scheduled for Monday, Apri130, 2007 at 11:00 am at the Cumberland County Courthouse, Courtroom No. 1. This will be your official notice of that Hearing and you must attend if you wish to voice any objections to the change of surname. If you have any questions, please feel free to contact me. But, please be aware that I cannot give you legal advice because I represent Mr. Darcy. Thank you for your kind attention to this matter. Sincerely, Kope ~ Associates, LLC Esquire Enclosures 466o Trindle Road ^ Suit P 7i7.76i.7573 ^ F Smart Representation aoi ^ Camp Hill, PA i7oii 7i7.76i.7572 ^ kopelaw.com r~ ~ -- rt ~~ ` ,; _~,- , t .t l (4. '~ ( 1 ~ t . '"'t> r~7 t "7 ~ {'t1 IN RE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA M.R.K. CIVIL ACTION - LAW 07-622 CIVIL TERM IN RE: CHANGE OF NAME ORDER OF COURT AND NOW, this 30th day of April, 2007, upon consideration of the Petition for Name Change in the above-captioned case filed by John Darcy, II:I, on behalf of Megan Renee Knob (date of birth, April 7, 1995), and following a hearing, at which testimony was received indicating that the natural mother of the child has no objection to this name change, the petition is granted, and hereafter Megan Renee Knob shall assume the name of, and be known as, Megan Renee Darcy. esley J. Beam, Esquire 4660 Trindle Road, Suit Camp Hill, PA 17011 For Petitioner :mae By the Court, ;.,~ --"- - .~ _ ~ ~_ tis ~'=' ~ C? C=;; " ~ r'' r~ _ } '-- r"_ '~ ~ v , IN RE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT'', PENNSYLVANIA M.R.K. CIVIL ACTION - LAW 07-622 CIVIL TERM IN RE: LIEN AND JUDGEMENT SEARCH REQUIREMENT WAIVED ORDER OF COURT AND NOW, this 30th day of April, 2007, in view of the age of the child involved in this name change case, the requirements for a lien and judgment search are waived. By the Court, C./ J, esley 0 Jr., J. esley J 4660 Tri Camp Hil For Peti :mae . Beam, Esquire 'ndle Road, Suite 2C 1, PA 17011 J 'boner ;'~ ~' _ ; ~;~; ~. _,_ ~~ c -: ~ ~ ` - , ,~ a:.- -y F r-- :.~ ~ Q N