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HomeMy WebLinkAbout01-6204 :IN THE COURT OF COMMON PLEAS OF IN RE: SHAWN MATTHEW :CUMBERLAND COUNTY, PENNSYLVANIA JEAN BOWEN CIVIL ACTION - LAW NAME CHANGE NO. ~)] '~0~/ CIVIL TERM PETITION FOR NAME CHANGE PURSUANT TO 54 Pa. C. S. §701 The Petitioner, Rena M. Bowen, by her attomeys, the Family Law Clinic, hereby petitions this Honorable Court to enter a decree changing her minor son's name from Shawn Matthew Jean Bowen to Shawn Matthew Jean Kams, and respectfully represents that: I. The Petitioner is Rena M. Bowen, who lives at 132 South Bedford Street, Carlisle, Cumberland County, Pennsylvania. 2. Petitioner is the biological mother of Shawn Matthew Jean Bowen (hereafter "Shawn'), who was bom on October 20, 1998, in Charnbersburg, Franklin County, Pennsylvania. A tree copy of Shawn's birth certificate is attached as Exhibit "A' and is incorporated herein by reference. 3. Shawn's social security number is 179-78-2255. 4. Shawn's father is John C. Bowen ("father"), whose last known address is P.O. Box 188, 13500 Fleetwood Drive, Nokesville, Virginia 20182-0188. 5. Rena Bowen and John C. Bowen were married on November 29, 1997. 6. Rena Bowen and John C. Bowen were separated on July 15, 1998, six months prior to Shawn's birth. 7. Rena Bowen and John C. Bowen were divorced on November 1, 2000. 8. Petitioner avers that it is in the best interest of Shawn Matthew Jean Bowen to have his name changed to Shawn Matthew Jean Karns, because:~ a) Mother has been divorced from the father and plans to retake her maiden name of Rena M. Karns, contingent upon her son's name being changed to Shawn Matthew Jean Karns. b) Father has had no contact with Shawn since his birth in October 1998. c) Father did not show up the one time arrangements were made for him to see his son, on Sunday, December 28, 1998 at 2:00 p.m.. d) Father owes child support for Shawn, but is in arrears in the amount of $8970.41. e) Petitioner is estranged from the Bowen family, and Shawn has had no contact with the Bowen family. 9. Since the child's birth, Petitioner and Shawn have lived at their current address, 132 South Bedford Street, Carlisle, Cumberland County, Pennsylvania, and Father is aware of this address. 10. There are no judgments, liens, decrees or the like against Shawn Matthew Jean Bowen or Shawn Matthew Jean Karns. WHEREFORE Petitioner prays that the Court: a) Set a time and place for a hearing on the above-captioned matter; b) Direct Petitioner to serve this Petition and the attached Order on John C~ Bowen, the biological father of the child, via United States mail, certified, restricted delivery, return receipt requested, postage prepaid and by regular first class mail; c) Direct that notice in the form set forth in Exhibit "B", attached hereto, be published of the filing of this petition and of any hearing once in the Carlisle Sentinel and the Cumberland Law Journal; d) After said hearing, enter an Order changing the name of Shawn Matthew Jean Bowen to Shawn Matthew Jean Karns; and e) Grant such other relief as may be just. Date: ,o KarenJL. Kurts // Certified Legal Intern ~HTO~AS M. PL,~CE ROBERT E. RAINS TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 VERIFICATION I hereby verify that the statements made in the foregoing Petition for Name Change are true and correct, to the best of my knowledge, information and belief. I understand making a false statement would subject me to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: Rena M. Bowen DATE OF 10-20-1998 FJLE 3896150-1998 10391595 &,~¼;b;-F_. "A" IN RE: SHAWN MATTHEW JEAN BOWEN :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :NAME CHANGE : NO. CIVIL TERM Name Change Notice NOTICE IS HEREBY GIVEN that a heating on the Petition of Rena M. Bowen, on behalf of her minor son, Shawn Matthew Jean Bowen to change his name to Shawn Matthew Jean Kams will be held on at .m. in Courtroom number __, Cumberland County Courthouse, Carlisle, Pennsylvania. Any and all interested parties may appear and show cause, if any, why the request of the Petitioner should not be granted. FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 SHAWN MATTHEW : JEAN BOWEN : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6204 CIVIL TERM Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 Attorneys for Petitioner ORDER OF COURT AND NOW, this 6th day of November, 2001, upon consideration of the attached Petition for Name Change Pursuant To 54 Pa. C.S. §701, a hearing is scheduled for Monday, February 11, 2002, at 2:30 p.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. BY THE COURT, J(]Hesley Ole~ ~& - :rc o ZOOt y' IN RE: SHAWN MATTHEW JEAN BOWEN :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NAME CHANGE NO.O/'~~Ot/ CIVIL TERM To the Prothonotary: PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Rena M. Bowen, Petitioner, to proceed in forma pauperis. I, Karen L. Kurts, of the Family Law Clinic, Certified Legal Intern, for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party. Date: Certified Legal Intern ROBERT E. RAINS TERI L. HENNING Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Attorneys for Plaintiff IN RE: SHAWN MATTHEW JEAN BOWEN :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW NAME CHANGE : NO. 01-6204 CIVIL TERM PRAECIPE TO REINSTATE TItE PETITION To the Prothonotary: Please reinstate the attached Petition for Name Change in the above-captioned case. Dated: February 6, 2002 Cettilied Legal Intern T~ASAS M~'. PLA~E~ ROBERT E. RAINS TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 SHAWN MATTHEW JEAN BOWEN :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO 01 - 6204 CIVIL TERM PETITION FOR A CONTINUANCE The Petitioner, Rena M. Bowen, by her attorneys, the Family Law Clinic, hereby petitions this Honorable Court to grant a continuance of the heating in this matter, currently scheduled for February 11, 2002 at 2:30 p.m., in Courtroom No. 1. In support of her petition, Petitioner represents the following: The Petitioner is Rena M. Bowen. On November 6, 2001, Rena M. Bowen, by her attorneys, the Family Law Clinic, petitioned the Court to enter a decree changing her minor son's name from Shawn Matthew Jean Bowen to Shawn Matthew Jean Karns. The Court scheduled a hearing on the Petition for Name Change Pursuant To 54 Pa. C.S §701 for February 11, 2002 at 2:30 p.m. The Family Law Clinic has made numerous attempts to serve John C. Bowen with notice of Petitioner's Petition for a Name Change, but has been unsuccessful in f'mding a good address for Mr. Bowen. The Family Law Clinic has attempted to mail the petition to last known addresses for Mr. Bowen. The Clinic has also contacted Mr. Bowen's parents in an effort to find him. On November 19, 2001, the Family Law Clinic attempted to serve the Petition for Name Change on John C. Bowen via United States mail, certified, restricted delivery, return receipt requested, postage prepaid, and regular first class mail to P.O. Box 188, 13500 Fleetwood Drive, Nokesville, Virginia, 20182-0188. On November 26, 2001, the Petition was retumed to the Family Law Clinic because the mail had remained unclaimed, and the forwarding address was unknown. On December 6, 2001, the Family Law Clinic attempted to serve the Petition for Name Change on John C. Bowen via United States mail, certified, restricted delivery, return receipt requested, postage prepaid, and regular first class mail to 610 Acacia Drive, Marysville, Ohio, 43040-8669. On January 4, 2002, the Petition was returned to the Family Law Clinic because the mail had remained unclaimed, and the forwarding address was unknown. The Family Law Clinic contacted the Domestic Relations Office in a further attempt to locate John C. Bowen. Upon information and belief, the Domestic Relations Office attempted to locate Mr. Bowen through the use of data entry in the National and State new hire system, subpoena to the U.S. Department of Education, and parent locators through CSNet. The Domestic Relations Office has been unable to locate Mr. Bowen. Because the Family Law Clinic has been unable to locate Mr. Bowen to serve him personally, Petitioner intends to file a Petition for Service by Publication. Petitioner asks that this Court reschedule the heating in this matter in order to allow additional time to file the Petition for Service by Publication and serve the Petition for Name Change on John C. Bowen in a manner acceptable to the Court. WHEREFORE, Petitioner respectfully requests that this Court grant a continuance in this matter to allow time for John C. Bowen to be served. Date: February 6, 2002 Respectfully ~submitted~ THOMAS M. PLACE TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 FEB 0 6 2002 IN RE: SHAWN MATTHEW JEAN BOWEN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. 01 - 6204 CIVIL TERM ORDER OF COURT AND NOW, this ~ day of February, 2002, upon consideration of Petitioner's Petition for a Continuance, it is ordered and directed that the hearing in this matter scheduled for February 11, 2002 at 2:30 p.m. shall be continued until BY THE COURT, IN RE: SHAWN MATTHEW JEAN BOWEN I~AR 0 : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NAME CHANGE : NO. 01-6204 CIVIL TERM ORI)ER OF COURT AND NOW, this [I ~day of ~_, 2002, upon consideration of the within petition, it is hereby ordered that Petitioner Rena Bowen shall serve Notice of the hearing in this matter and the Petition for Name Change on John C. Bowen, as follows: a) by mailing the Petition and Notice to Mr. Bowen's parents' last known address at 2212 Youngs Drive, Haymarket, VA 20169, by certified and regular mail; and b) by publishing the Notice in the form s.et ~Xh in Exhibit i'A".to the Petitiqn, once in ~ and once in the Cumberland Law Journal. Said service shall satisfy the requirements for service of original process under the Pennsylvania Rules of Civil Procedure. IN RE: SHAWN MATTHEW JEAN BOWEN :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NAME CHANGE : NO. 01-6204 CIVIL TERM CERTIFICATE OF SERVICE I, Georgina A. Howells, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Petition for Name Change on John C. Bowen, c/o Clifford Bowen, residing at 2212 Youngs Drive, Haymarket, Virginia, 20169, by regular and certified U.S. mail. Gepr~gi ~ta A(l~wells -~ Ce 'f/~_~ Leg'ar Intern Dated: March 18, 2002 Z 338 765 252 US Posta~ Service Receipt for CLa~fft~l Mail NO Insurance Coverage Provided. THOM~. PLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 :IN THE COURT OF COMMON PLEAS OF IN RE: SHAWN MATTHEW :CUMBERLAND COUNTY, PENNSYLVANIA JEAN BOWEN CIVIL ACTION - LAW NAME CHANGE : NO. 01-6204 CIVIL TERM PROOF OF PUBLICATION I, Georgina A. Howells, Cextified Legal Intern, Family Law Clinic, hereby certify that I served Legal Notice of the Heating and Petition for Name Change on John C. Bowen by having the Notice published once in the Cumberland Law Journal on March 22, 2002. Ge~r~ina A(.~Wells ~ Celled Legal Intern Dated: March 22, 2002 THOMA~<~[. P/LACE ROBERT E. RAINS LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L. 1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly swom, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz MARCH 22, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are SWORN TO AND SUBSCRIBED before me this 22 day of MARCH 2002 LOIS E. 8NYI}ER, Nobr/I~l~io I CUMBERLkND LAW JOURNAL LEGAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania No. 01-6204 Civil Term IN RE: NAME CHANGE OF SI-lAWN MATI'HEW JEAN BOWEN, A MINOR CHILD NO'HCE OF HEARING TO CHANGE NAME OF SHAWN MArl'HEW JEAN BOWEN TO SPAWN MATTHEW JEAN KARNS TO: JOHN CLIFFORD BOWEN, fa- ther of SPAWN MATTHEW JEAN BOWEN, bom 10/20/98 to RENA M. BOWEN in Cumberland Coun- ty, Pennsylvania. The Petitioner, Rena M. Bowen, by her attorneys, the Family Law Clinic, has filed a Petition to change Shawn Matthew Jean Bowen's name to Shawn Matthew Jean Karns. The Court has set a hearing to consider the Petition. That hearing will be held on April 3, 2002, at 9:30 a.m. in the Cumberland County Courthouse, Carlisle, Pennsylvania in Courtroom l, Fourth Floor. If you wish to object to this name change, you must enter a written appearance personally or by attorney and file your defenses or objections in writ- ing with the court. You are warned that ff you fail to do so, the ease may proceed without you, a~d the Court may enter an order changing Shaven Matthew Jean Bowen's name to Shawn Matthew Jean Kams. YOU SHOULD TAKE THIS NO TICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT PAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Mar. 22 IN RE: SHAWN MATTHEW JEAN BOWEN :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NAME CHANGE NO. 01-6204 CIVIL TERM PROOF OF PUBLICATION I, Georgina A. Howells, Certified Legal Intern, Family Law Clinic, hereby certify that I served Legal Notice of the Hearing and Petition for Name Change on John C. Bowen by having the Notice published once in the Carlisle Sentinel on March 20, 2002. Dated: March 20, 2002 LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland. Lori Saylor, Classified Advertising Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Notice of Publication March 19, 2002 Affiant further deposes that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Mamh 20, 2002 Sworn to and subscribed before me this 20th day of March ., 2002. Notary Public My commission expires: SHIRLEY O. DURNIN, Notary Public Carlisle Boro., Cumberland County I~ Commission Expires Aug. 9, 2003