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HomeMy WebLinkAbout03-3533IN RE: CHAiqGE OF NAME OF DANIEL SOLOMON CHIRKOFF : CUMBERLAND COUNTY, : NO. C g-. £23 : CIVIL ACTION - LAW : O.i?,.¢Jd, g~' COLrRT DIVISION IN THE COURT OF COMMON PLEAS PENNSYLVANIA PETITION FOR CHANGE OF NAME This is the Petition of Sergei Chirkoff and Victoriya Abramova, by and through their attorneys, Friedman & King, P.C., and who do hereby aver as follows: 1. The Petitioners are the natural parents of their lawful son, Daniel Solomon Chirkoff, who is six (6) years of age and who was born on July 1, 1997. 2. The Petitioners do desire and hereby seek to change the name of their lawful natural son. 3. The Petitioners' son, Daniel Solomon Chirkoff, primarily resides with his natural mother, Petitioner, Victoriya Abramova, and the Petitioners are desirous of having the minor child's last name be the same as his natural mother with whom he primarily resides. 4. In the Russian-American community of which the parties are members, the proper masculine form of Petitioner Victoriya Abramova's last name is Abramov. 5. Petitioner, Victoriya Abramova, and her son, Daniel Solomon Chirkoff, have resided at 31 Nathan Drive, Enola, Cumberland County, Pennsylvania for approximately the past three (3) years. 6. There are no judgments or decrees of like character of record against the Petitioners' son, Daniel Solomon Chirkoff. WHEREFORE, Petitioners request the Court, pursuant to the Act of December 16, 1982, PL 1309, 295, Section 2, 54 Pa. C.S.A. § 702, to: A. Fix a hearing on this Petition; B. Direct that notice be given of this Petition and hearing by publication; and C. Enter a Decree chan9ing the Petitioners' son's name from Daniel Solomon Chirkoff to Daniel Solomon Abramov. Date: Respectfully submitted, FRIEDM3%I~ & KING, P.C. , John F. King, E~ire ~6g'0 N. Second S~]~eet ~enthouse Suite P. O. Box 984 Harrisburg, PA 17108 (717) 236-8000 f/p:domestic~abramova.pet VERIFICATION We, Sergei Chirkoff and Victoriya Abramova, hereby acknowledge that we are the Petitioners in the foregoing action; that we have read the foregoing Petition for Change of Name; and the facts stated therein are true and correct to the best of our knowledge, information and belief. We understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Serge± Ch±rkof~ Victoriya ~ramova Dated: IN RE: CHANGE OF NAME OF DANIEL SOLOMON CHIRKOFF : CUMBERLAND COUNTY, : CIVIL ACTION - :~JLBW~W~' COURT DIVISION IN THE COURT OF COMMON PLEAS PENNSYLVANIA AND NOW, to wit this ~ ~ , day of  ' 2003, Petition of Sergei Chirkoff upon and Victoriya Abramova, it is ORDERED and DECREED that the within Petition be heard on the ~"~ day of 0~ , 2003, at /,~ o'clock~ .m., in court room ~'~ , and that notice of the filing of the within Petition and of the aforesaid date of hearing, be published by the Petitioners as required by statute. IN RE: CHANGE OF NAME OF DANIEL SOLOMON CHIRKOFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVAMIA : NO. 03-3533 civil Term : CIVIL ACTION - LAW MOTION FOR CONTINUANCE This is the Motion of Sergei Chirkoff and Victoriya Abramova, by and through their attorney, John F. King, Esquire, and who do hereby aver as follows: 1. The Movants are the natural parents of their lawful son, Daniel Solomon Chirkoff, who is six (6) years of age, and who was born on July 1, 1997. 2. The Movants filed a Petition for Change of Name of their son on or about July 25, 2003. A copy of the Petition is attached as Exhibit "A". 3. The Honorable Judge Edward E. Guido issued an Order dated July 30, 2003 for Hearing and Publication, which did Order and Decree that the Petition be heard on tile 2nd day of October, 2003 at 1:00 p.m. in Court Room No. 5. A copy of the Order is attached as Exhibit "B". 4. Petitioner, Victoriya Abramova, and the child in question, Daniel Solomon Chirkoff, will be traveling out of the country on the date of hearing as ordered by Judge Guido, and will not return until Tuesday, October 7, 2003. WHEREFORE, it is respectfully requested that the hearing scheduled for October 2, 2003 at 1:00 p.m. in Court Room No. 5 be continued, and it is further requested that the Court, pursuant to the Act of December 16, 1982, PL 1309, 295, Section 2, 54 Pa. C.S.A. § 702: A. Fix a new hearing date after October 7, 2003 on this Petition; and B. Direct that notice be given of this Petition and hearing by publication. Date: Respectfully submitted, ~00/N. Second tie. ~t house Suite P.~O. Box 984 Harrisburg, PA 17108 (717) 23 ~-8000 f/p:domestic~abramova.mot VERIFICATION I, John F. King, Esquire, hereby acknowledge that I am the attorney for the Petitioners/Movants in the foregoing action; that I have read the foregoing Motion for Continuance; and the facts stated therein are true and correct tc the best of my knowledge, information and belief. The Petitioners are currently out of the jurisdiction of the Court. I have reviewed the contents of this Motion with them. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to author~ ~o~n ~. King, Esq,%re Att~ey for Petit~ovants Dated: ~/I IN RE: CHANGE OF NAME OF DANIEL SOLOMON CHIRKOFF : IN THE C~JRT OF COMMON PLEAS : CUMBERLANqD COI/NTY, PENNSYLVANIA : NO. : CIVIL ACTION - LAW : ORPHANS' COURT DIVISION PETITION FOR CHANGE OF NAME This is the Petition of Sergei Chirkoff and Victoriya Abramova, by and through their attorneys, Friedman & King, P.C., and who do hereby aver as follows: 1. The Petitioners are the natural parents of their lawful son, Daniel Solomon Chirkoff, who is six (6) years of age and who was born on July 1, 1997. 2. The Petitioners do desire and hereby seek to change the name of their lawful natural son. 3. The Petitioners' son, Daniel Solomon Chirkoff, primarily resides with his naturai mother, Petitioner, Victoriya Abramova, and the Petitioners are desirous of having the minor child's last name be the same as his natural mother with whom he primarily resides. 4. In the Russian-American community of which the parties are members, the proper masculine form of Petitioner Victoriya Abramova's last name is Abramov. 5o Solomon Chirkoff, Cumberland County, (3) years. Petitioner, Victoriya Abramova, and her son, Daniel have resided at 31 Nathan Drive, Enola, Pennsylvania for approximately the past three 6. There are no judgments or decrees of like character of record against the Petitioners' son, Daniel Solomon Chirkoff. WHEREFORE, Petitioners request the Court, pursuant to the Act of December 16, 1982, PL 1309, 295, Section 2, 54 Pa. C.S.A. § 702, to: A. Fix a hearing on this Petition; B. Direct that notice be given of this Petition and hearing by publication; and C. Enter a Decree changing the Petitioners' son's name from Daniel Solomon Chirkoff to Daniel Solomon Abramov. Date: Respectfully submitted, FRIEDMAn! & KING, P.C. John F. King, EsqUire ~6Q0 N. Second Sk~eet 'l~ent house Suite P. O. Box 984 Harrisburg, PA 17108 (717) 236-8000 f/p:domestic~abramova.pet VERIFICATION We, Sergei Chirkoff and Victoriya Abramova, hereby acknowledge that we are the Petitioners in the foregoing action; that we have read the foregoing Petition for Change of Name; and the facts stated therein are true and correct to the best of our knowledge, information and belief. We understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: Sergei Chirkof f Vict oriya Abramova JUL ~ ~ 2002 IN RE: CHANGE OF NAME OF DANIEL SOLOMON CHIRKOFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAw : ~R4~, COURT DIVISION ORDER FOR HEARING AND PUBLI~Z_ATION AND NOW, to wit, this __30+~ _ day of ~ I~j~ _, 2003, upon Petition of Sergei Chirkoff an toriya Abramova, it is ORDERED and DECREED that the within Petition be heard on the _ 2~--c~ day of ~-~%~ , 2003, at ]~0~ o'clock .m., in Court room _, _, and that notice of the filing of the within Petition and of the aforesaid date of hearin!3, be published by the Petitioners as required by statute. BY THE COURT: IN RE: CHANGE OF NAME OF DANIEL SOLOMON CHIRKOFF · IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-3533 Civil Term : CIVIL ACTION - LAW ORDER FOR CONTINUANCE AND NEW HEARING DATE AND PUBLICATION AND NOW, to wit, this ~ ~ day of ~ , 2003, upon Motion of Sergei Chirkoff and Victoriya Abramova requesting a continuance of the hearing previously scheduled, it is ORDERED and DECREED that the hearing scheduled for October 2, 2003 is hereby continued. It is further ORDERED and DECREED that the Petition For Change of Name filed on July 25, 2003, be heard on the ; ~ ~ day of ~~ , 2003, at /.'~;~ o'cl6ck ~.m., in court room ~'~, and that notice of the filing of the Petition for Change of Name and of the aforesaid new date of hearing, be published by the Petitioners as required by statute. IN RE: CHANGE OF NAME OF DANIEL SOLOMON CHIRKOFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-3533 Civil Term CIVIL ACTION - LAW DECREE FOR CHANGE OF NAME AND NOW, this /~ day of ~)~ , 2003, upon hearing of the Petition, and upon motion of John F. King, Esquire, attorney for Petitioners, and upon presentation of proof of publication of notice as required by law, together with proof that there are no judgments or decrees of record or any other matter of like effect against the above-named, and it appearing that there is no legal objection to the granting of the prayer of the Petition, it is ORDERED and DECREED that the name of the above-referenced Daniel Solomon Chirkoff be, and is hereby changed to, Daniel Solomon Abramov.