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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 'r? r? ?'r) f-'1 Q jG O r, r a i APR 17 20D6r 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 By: J. 1:'37'????? . 81?t//,, zz am t Q ?? tt 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, By: J. -7 s? 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