HomeMy WebLinkAbout08-2477KOPE & 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: E.M.J. NO. J - 2 V 7-1
CIVIL ACTION
PETITION FOR NAME CHANGE
1. Petitioner is Deborah Nissley, the guardian, primary custodian and natural
mother of Emily Marie Jenkins, a seven-year-old minor who was born on November 3,
2000 (hereinafter the "child").
2. Petitioner desires to change her child's name from Emily Marie Jenkins to
Emily Marie Nissley.
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
had the married name of Nissley since 2004;
b. Petitioner has had primary custody of the child and the child would
benefit from sharing Petitioner's surname;
c. Petitioner and the child share their residence with Petitioner's husband
and the child's half-sister, both of whom have the surname of Nissley;
d. The child is of the age where she attends first grade 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;
e. The child has expressed desire to have the same surname as her
mother, the Petitioner. Indeed, the child refers to herself with the surname
of Nissley and represents to her peers that her last name is Nissley;
f. The child's natural father, Kenneth Jenkins, has not seen the child for
over two (2) years. The child's natural father relocated to Alabama three
years ago, in 2003, and has made only nominal effort, if that, to maintain
any relationship with the child;
g. The child's natural father only speaks to the child approximately two
times per year. During Petitioner's last contact with the child's natural
father in January of 2008, he did not ask to speak with the child; and
h. The child's natural father has repeatedly failed to contribute to the
child's financial support, and is, at the time of this filing, approximately
$7,500.00 in arrears.
5. Currently, the child lives with her natural mother, the Petitioner, at 418 Orrs
Bridge Road, Camp Hill, Cumberland County, PA 17011. The child and Petitioner also
reside with Petitioner's husband, David Nissley, and the natural offspring of Petitioner
and her husband, Alexandria Nissley, who is three years old.
6. For two years prior, the child lived with the aforementioned persons at 1324
Sand Hill Road, Hummelstown, PA 17036.
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 child predators or
the like to have access to the child's name and address.
8. The subject of this petition is a 7-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 child predators or the like to have access to the child's
name and address.
Respectfully Submitted,
KOPE & ASSOCIATES, LLC
By: 11 ?,-J- // C______
?I LesI?J. Beam, Esq.
Dated: ?,/?? w-6
VERIFICATION
I, Deborah Nissley, 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:
Deborah Nissley
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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: E.M.J. NO. Dg_ ay77 Civil T?r-0%
CIVIL ACTION
ORDER OF COURT FIXING HEARING
3
AND NOW, this q 14, day of 4vi-_, 2008, upon consideration of the
attached Petition for Name Change filed by the Petitioner:
1. A hearing on the Petition of Deborah Nissley, for change of name is fixed for
2008, at 3 y o'clock km, at?
2. The Petitioner is not directed to give notice of the hearing by publication in two Cos."
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 within days to any non-petitioning
parent of the child whose name is affected by
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IN RE: E.M.J.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. p8''2y77 Clul -le- rA
CIVIL ACTION
ORDER OF COURT CHANGING NAME
AND NOW, this 11day o ?''? , 2008, 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 Emily Marie Jenkins to
Emily Marie Nissley.
BY34gE COURT,
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