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Home My WebLink About07-3447KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hili, PA 17011 (717) 761-7573 (beam@kopelaw.com Attorney for Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA IN RE: C.M.F. NO. 07 -~ 3Sl~'~ (_.: t cs i,(,~~c/Z.1-r-~ CIVIL ACTION PETITION FOR NAME CHANGE 1. Petitioner is Courtney Mae Yost, the guardian, primary custodian and natural mother of Cerenity Mae Fish, a four year old minor who was born on October 14, 2002 (hereinafter the "child"). 2. Petitioner desires to change her child's name from Cerenity Mae Fish to Cerenity Mae Yost. 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 her child are as follows: a. Petitioner is not married to the child's natural father and Petitioner has the surname of Yost; b. Petitioner has had primary custody of the child and the child would benefit from sharing Petitioner's surname; c. The child is of the age where she attends pre-school and Petitioner desires to protect her child from the psychological and emotional confusion which may result from the child and parent having two different surnames; d. The child has expressed desire to have the same surname as her mother, the Petitioner; e. The child's natural father, Andrew W. Fish, has not seen the child for over three (3) years, specifically, since she was 1 '/Z years old; the child will be 5 years old in October. In fact, the child's natural father has not made any efforts to contact the child or her mother during this time, and has relocated without informing Petitioner of his new address; f. The child's natural father has repeatedly failed to contribute to the child's financial support; and g. The natural father's engagement in notorious conduct has already served to alienate the child. 5. For over a year preceding the filing of this Petition and currently, the subject of this Petition has lived with her natural mother, the Petitioner, at 1714 Market Street, Apartment A, Camp Hill, Cumberland County, PA 17011. 6. From the subject's birth until the year preceding the filing of this Petition, the subject of this Petition has lived with her natural mother, the Petitioner, at 707 Pear Street, Apartment 5, Lemoyne, Cumberland County, PA 17043. 7. The subject of this petition is a minor, and as such, Petitioner requests that this Court waive the requirement for publication of the notice in two newspapers of general circulation on the grounds that Petitioner does not wish for predators or the like to have access to the child's name and address. 8. The subject of this petition is a 4 year old minor, and as such, has not entered into any contracts, been charged with any criminal conduct, or received any judgments of the court. As such, Petitioner requests that this Court waive the requirement for official searches of the proper offices of the county. 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 & ASSACIATES, LLC sy: / ~...,,.,, ~ ~.,r,,., ~~,.,. Dated: (o g /~ VERIFICATION I, Courtney Mae Yost, 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. ,_.~ Dated. ~1T ~ ~ ~~ ~---_ _~ ti __ ~~~. Courtney Mae Yost `- !~ %~ ~ ''~ ~ ~~ V _^ 1,- 4 F±-~' ^~~ N !~ G'~ ~d.y ..ice.: L.2 cn tt7 ~TT J' ~_ ~i ~t i "~ U t 7 JUN 13 2007,E KOPE 8~ 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: C.M.F. NO. 07 -- ~?~/~7 ~t(~i(.,~~Ly/L CIVIL ACTION ORDER OF COURT CHANGING NAME AND NOW, this day of , 2007, upon consideration of the attached petition and after hearing, it is found as a fact that the requirements of 54 Pa.C.S. § 701 have been satisfied and the name of the minor child is hereby changed from Cerenity Mae Fish to Cerenity Mae Yost. BY THE COURT, By: J. KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 (beam@kopelaw.com Attorney for Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 07 - 3~~7 ~~~~L~~. IN RE: C.M.F. CIVIL ACTION ORDER OF COURT FIXING HEARING AND NOW, this ~~_ day of , 2007, upon consideration of the attached Petition for Name Change filed by the etitioner: 1. A hearing on the Petition of Courtney Mae Yost, for change of name is fixed for ~ ~ ~°~~ 2007, at 1 J , o~ o'clock gym, at ~- Lk.-Y-~-f'~t ~ • ~ ~~ ~ ~ 5 2. The Petitioner is not directed to give notice of the hearing by publication in two newspapers of general circulation in Cumberland County, Pennsylvania, one of which publications may be the official paper for the publication of legal notices in that county. 3. The Court hereby waives the requirement for official searches of the proper offices of the county. 4. Petitioner is directed to give notice of the hearing to any nonpetitioning parent of the child whose name is affected by the proceedings. BY THE COURT, By: J. ,.,- ,.,_. ~iRi,~ j 1,~ °zi "~, J ~~ ~~ ~_~~ 61 ~'j?!~ lu~Z ~~, _ .~ JUN 1 ~ 2007,~~ 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: C.M.F. NO. 07 -- ~~~7 ~tviC,~~L CIVIL ACTION ORDER OF COURT CHANGING NAME AND NOW, this ~1 ~~ day of ~~, 2007, upon consideration of the attached petition and after hearing, it is found as a fact that the requirements of 54 Pa.C.S. § 701 have been satisfied and the name of the minor child is hereby changed from Cerenity Mae Fish to Cerenity Mae Yost. BY THE COURT, Y~~~ 1 ~1~ 1~~*~ t /,dam ~~ ~ ~ ~~~~ ~ t ~~/a '`~^.~~ a~ ~~ ~,.. _ . KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 (beam@kopelaw.com Attorney for Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA IN RE: C.M.F. NO. 07-3447 CIVIL ACTION AFFIDAVIT AND RETURN OF SERVICE AND NOW comes Kope & Associates, LLC by LESLEY J. BEAM, attorney for the natural mother, Courtney Yost, of C.M.F., and states that service of the Petition for Name Change and Order of Court scheduling a hearing in this matter was made by her upon the natural father, Andrew Fish, of C.M.F., by posting the same in the U.S. Mail, postage prepaid, at Camp Hill, PA by Certified Mail No. 7004 2510 0007 6450 1493, Return Receipt Requested on August 13, 2007, to his current place of residence at Potter County Prison, 102 E. Second Street, Coudersport, PA 16915 which mail was received by Andrew Fish on August 15, 2007, all in accordance with PA.R.C.P. 412 and 403. The mailing receipt and the return receipt or true copies thereof of the acceptance of service bearing the signature of Andrew Fish are attached hereto and made part hereof, together with the cover letter mailed to Andrew Fish. SLEY,~/. ~AM, Esq. orne or ourtney Yost ~, 11~ • s '; E '` ~ ' i s~ `_. ~~ , ~`~~ ~`E ~' ~- ,,t. r ~ ~ ~ ~ ~ ~S ~~ ~ 1 E6fi -:. Zfl~fl ~~~ ~ ~• ~~~(~~~- _. ~~ K O P E ASSOCIATES LAbV OFFICES LLC August 13, 2007 VIA CERTIFIED MAIL Andrew W. Fish Potter County Prison 102 E. Second Street Coudersport, PA 16915 Re: In Re: C.M.F. 07-3447 Dear Mr. Fish, I represent Courtney Yost 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. I 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, August 20, 2007 at 11:00 am at the Cumberland County Courthouse. This will be your official notice of that Hearing. 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 Ms. Yost. Thank-you for your kind attention to this matter. Sincerely, Kope & ssociat ,LLC r esley J. am Esquire Enclosures Smart Representation 466o Trindle Road ^ Suite 2oi ^ Camp Hill, PA i~oii P 717.76i•7573 ^ F 717.76.75'72 ^ kopelaw.com r`~r ~ .._~ c: ' , -- :~w y ~,'1 .. ,-~ a, J ,.,~ -~` ~ ~' ,~ _ ~'~ a st '~, .~ ,~, -,~. j l:, 3 ~ __-------~ ~-~ ~ t , ~~. ~ ~..~ ~ ~ A ~- M T ' iT ~... ~ i .,-,~. r. -- . r ~~ Kr cw~- `~ ti ~ i .~ ~~ ,,~- ~ ~ ~~ ~t- ~ ~ ~ i+~~Y~ , €~ `! ~ ~ . _ .. ~~ ~~ .~ t' ~' ,~} ~ . ~.e.' ,, ,, o a~ era r ~~~~ ~ ~ '~ ~ ~'`~ ~~~ ~ ~ ~~`~° _ _ ~- w ~~ __.~ ~_ -: .~_--" ____ --------'-'`~^~-^I-- ` ~ ~. ' . ~tA t' ,.. t` y~ ~ s ~ 4 ~ t ~ ~ _--- `~ s~' . , a t *,__. ;'~" ~ 1 eA st~ d r~-'~ ~ ~.w .~ r '1 IN RE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CMF NO. 07-3447 CIVIL ORDER OF COURT AND NOW, this 29~' day of August, 2007, the Court having just received a Motion for Continuance filed by Andrew Fish in the above captioned matter, and the Court noting that the hearing in question took place on August 20, 2007, that Mr. Fish did have notice of the hearing, and Mr. Fish's Motion was not filed with the Prothonotary until 2:00 p.m. on August 27, 2007, IT IS HEREBY ORDERED AND DIRECTED that Mr. Fish's Motion is DENIED as being untimely. By the Court, 'y~~ M. L. Ebert, Jr., J. Lesley Beam, Esquire Attorney for Petitioner Andrew Fish -~t k,~;,~,,,,",, 0'! 't/1 ~ ~~ ~I11~ ~.QDl n~l.~Jt~it,ii"_1,~,i~;:c.! ~71,t, a~ [~ E3 N ~ ----~, N ,Z ~ ..: ~ ~ /' ~~ +.. ~,"~~ .~~~.w.. 4 .~.,~~ 4 4. ~~.°LW ~~ ~+v'r iw .-- ~ ~- ~; 1 _- _,_~~_ ~.. -.y--- ~ ' :x gat ~- , ~~~-- ~ t ~~-. - . _ _--------~-~;i~~ ~ ~ -_----- - - - 1 - ~T ~, ~~ ~~ ~ ~~' ' r --- -- ------------ ---~? d~~F'~(-_ -~-~: ~ t! vM ,.~ ,~' ~_. M ~ _~ ~ ~ ~ '~ ~ V --- ~< Q p ` K~ i ~' 1 ~ 1 7 V -- r ~~a~ ~ ~ - ~/ ~ ~ ~~ ~~~ IN RE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CMF N0.07-3447 CIVIL ORDER OF COURT AND NOW, this 29~' day of August, 2007, the Court having just received a Motion for Continuance filed by Andrew Fish in the above captioned matter, and the Court noting that the hearing in question took place on August 20, 2007, that Mr. Fish did have notice of the hearing, and Mr. Fish's Motion was not filed with the Prothonotary until 2:00 p.m. on August 27, 2007, IT IS HEREBY ORDERED AND DIRECTED that Mr. Fish's Motion is DENIED as bei~ untimely. By the Court, ~1.. M. l.. EbeA..k.. J. Lesley ~. Esq~re Attorney for Petitioner M. L. BERT, .1R. ~ UDGE ~ E COURTHOUSE SQUARE RLISLE. PA 17013-3387 :, d7-3~Iy~ C~vv ~~~~ 4 ~~ ` . wwEs 0004631598 SUG30~00 MAILED FROM Z~'CO~ 1 701 i~TC' ~~Y,,N Andrew Fish 102 East 2nd Street ~ ~ Coudersport, PA 16915 RETURN TO SENDER Ti07 DEL,Z'li6Ftl4®LE A~ ADDRESSED U1*lA®4E TO F R'1JA1i'D i£~z3'l~i"?'~~ L:.~:3~3~ ~t-,lil,-s.lll~s„~~ll~~ll,l,~l,i i a ~~5 ~~~