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HomeMy WebLinkAbout04-1604IN RE: EMMA MAY EDWARDS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-IN LAW PETITION FOR CHANGE OF NAME AND NOW comes Petitioner Karen Rhinehart, by and through her counsel REAGER & ADLER, PC and respectfully represents the following: 1. Petitioner, Karen Rhinehart, is the natural mother and custodial parent of Emma May Edwards, born on February 18, 1999. 2. Petitioner Karen Rhinehart and the minor child Emma May Edwards reside at 1618 Chatham Road, Camp Hill, Cumberland County, Pennsylvania 17011. The minor child Emma May Edwards has been a resident of Cumberland County since birth. 4. At birth, the minor child was named Emma May Edwards; Edwards was the surname of minor child's natural mother, Karen Rhinehart, formerly Karen Edwards. 5. Petitioner Karen Edwards married Charles Paul Rhinehart, Jr. on the 30th day of August, 2003, and took her husband's surname and is now known as Karen Rhinehart. 6. Emma May Edwards is a minor child and has never been convicted of any crime. 7. Emma May Edwards is a minor child aged four (4) and she has never filed for bankruptcy under 11 U.S.C. §101 et seq. 8. There are no judgements or liens of record and no actions pending against Emma May Edwards in any Court of this State or of the United States or of any government subdivisions. 9. The minor child Emma May Edwards has not at any time made assignment through the benefit of creditors. 10. There are no claims, demands, liabilities, or obligations of any kind on any written instrument or otherwise against the minor child Emma May Edwards under the name sought to be changed or any other name. 11. The minor child has no creditors who may be adversely effected or prejudiced by the proposed change of name. 12. Petitioner Karen Rhinehart, the natural mother of the minor child Emma May Edwards, desires to change her daughter's name from Emma May Edwards to Emma May Rhinehart for the following reasons: a. Petitioner Karen Rhinehart was married on 30th day of August, 2003. b. Edwards was Petitioner Karen Rhinehart's maiden name. She desires to have her daughter's last name changed from Edwards to Rhinehart so she and her daughter will continue to have the same last name. c. Petitioner would like to have Emma's name changed prior to herbeginning kindergarten in the Fall of 2004. WHEREFORE, Petitioner respectfully requests this Court to grant this Petition and direct the minor child's name be changed from Emma May Edwards to Emma May Rhinehart. Respectfully sub~pitte3t~ Debr nis (C t Attorney ID No..' 66378 2331 Market Street Camp Hill, PA 17011 (717) 763-1383 VERIFICATION I, Karen Rhinehart, hereby verify and state that the facts set forth in the foregoing pleading are tree and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. DATE:Jo~q, ~, pooq .~0~. ~-b~.~ }no waren Rh~nehart ~DWA~DS EMMA MAY DB 50xsoG8 1133s5 #ng012 12: 08; 37 20040119-12~15 CERTIFICATE OF SERVICE I hereby certify that on the date set forth below a tree and correct copy of the foregoing Petition for Change of Name was served on the following individuals via United States First Class Mail, postage prepaid as follows: Wesley L. Cook c/o Brenda Cook 14 E. Keller Street Mechanicsburg, PA 17055 Dated: Debr~/Denisot~-C antoT, Esquire /(d~6r~ey ID.]>~o, 66378 - 2331 Market Street Camp Hill, PA 17011 (717)763-1383 Attorney for Karen Rhinehart IN RE: EMMA MAY EDWARDS CIVIL ACTION-IN LAW ORDE~R /'7_ AND NOW this h,,~) day of ,/'-7/? ,2004, it is hereby ORDERED that a hearing on the Petition to Change Name filed in the above-captioned case shall be held on the Ot~rqv'~t dayof 9~,_.~ _ ,,.004, at a.~_m./p.m. in Courtroom # __M_~, Cumberland County Courthouse, One Courthouse Square, Ca?lisle, PA. IT IS FURTHER ORDERED that Notice of the following said Petition and the heating date shall be published in two (2) newspapers of general circulation in Cumberland County and one (1) legal journal, one (1) of which is to be the Cumberland ,County Reporter, once a week for three consecutive weeks, and that three (3) proofs of publication thereof to be appended to the Petition at the time of the hearing. BY THECOURT IN RE: EMMA MAY EDWARDS IN THE COURT ,OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA AND NOW, this for Name Change, proof of publication, and Lien Search, and a]2er heating, it is hereby ORDERED that Emma May Edwards shall be now known as Emma May Rhinehart. NO.: 04-1604 CiVIL ACTION-IN LAW day of,~_._ 2004, upon review of the Petition BY THE COURT