HomeMy WebLinkAbout08-7009LAW OFFICES OF PETER J. RUSSO, P.C.
BY: ELIZABETH J. SAYLOR, ESQUIRE
PA Supreme Court ID: 200139
5006 E. Trindle Road, Suite 100
Mechanicsburg, PA 17050
(717) 591-1755
IN THE MATTER OF PETITION FOR
CHANGE OF NAME OF MINOR
SKYE ELIZABETH LANDAVERDE
Attorneys for Petitioner
: COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. d8 - '7007
PETITION FOR CHANGE OF NAME
The petitioner, Christy Marie Jennings, Biological Mother, on behalf of Skye
Elizabeth Landaverde, minor child, through her counsel, Elizabeth J. Saylor, Esquire of
the Law Offices of Peter J. Russo, P.C., requests that this Court order a change of name
on behalf of the minor child pursuant to 54 Pa. C.S. § 701 et seq., and in support thereof
represents as follows:
1. Petitioner, Christy Marie Jennings, is the biological Mother of Skye Elizabeth
Landaverde, who was born in York, Pennsylvania on February 22, 2005. A true and
correct copy of the Birth Certificate of Skye Elizabeth Landaverde is attached hereto as
Exhibit A and incorporated herein.
2. Biological father of Skye Elizabeth Landaverde is Michael Lynn Landaverde. A
true and correct copy of the Acknowledgement of Paternity is attached hereto as Exhibit
B and incorporated herein.
3. Petitioner, Christy Marie Jennings along with Skye Elizabeth Landaverde
currently reside at 1425 Apple Drive, Apt. 137, Mechanicsburg, Cumberland County,
Pennsylvania 17055, where they have resided since March of 2007.
4. Petitioner, Christy Marie Jennings along with Skye Elizabeth Landaverde have
resided at the following additional residences in the past five years:
a. 59 Fawn Avenue, New Oxford, PA 17350 from June of 2006 until March
of 2007;
b. 605 Y2 Baltimore Street, 1St Floor, Hanover, PA 17331 from March of
until June of 2006;
c. 5280A Carlisle Pike, New Oxford, PA 17350 from February of 2005 until
March of 2006; and
d. 59 Fawn Avenue, New Oxford, PA 17350 from prior to October 2003
until February of 2005.
5. Skye Elizabeth Landaverde is a minor child who has attained her third (3rd) year
on February 22, 2008.
6. Petitioner wishes to change the minor's surname so that she shall forever be
known as Skye Elizabeth Jennings.
7. The reasons for the requested name change are as follows:
a. The minor child's last name is that of her Biological Father, who has not
been a part of minor child's life since on or about June of 2006.
b. Petitioner desires that she and the minor child have the same last name.
c. Petitioner desires that said change of name is in effect prior to the child's
admission into kindergarten.
8. The petitioner does not request the Court proceed under 54 Pa. C.S. § 701
(a)(3)(iii).
9. There are no judgments or decrees of like character of record against the minor
child.
WHEREFORE, Petitioner requests that this Court enter a decree changing the
minor child's name from Skye Elizabeth Landaverde to Skye Elizabeth Jennings.
2
Respectfully submitted,
LAW OFFICES OF PETER J. RUSSO, P.C.
Peter J. Russo, Esquire
Attorney I.D. No. 72897
Elizabeth J. Saylor, Esquire
Attorney I.D. No. 200139
Attorneys for Petitioners
5006 E. Trindle Road, Suite 100
Mechanicsburg, PA 17050
Telephone: (717) 591-1755
Facsimile: (717) 591-1756
Counsel for Petitioner
EXHIBIT A
- ___-_-_______-_________-_-_______-_-______s_-__-_____-___-_-_-_-_-_-_-_____-_-
DATE OF
FILE 02-22-2005 N0166990-2005
,?FREED 02-24-2005
COUNTY OF DATE
BIRTH YORK MWED 41- 6- 2 0 0 5
NAME
SKYE ELIZAB TH` 'ANDAVERDE "r
FATHERS NAME" -
MICHAEL LYNNiLANDAVERDE
MOTHERS MAIDEN NAME, pmnry.,,y
CHRISTY "MARIE JENNINGS OF
,?,??,
c
This is to oertily that this is a true copy of the record which is on file in the Pennsylvania Department of Health, d a
In accordance with Act 66, P.L 304, approved by the General Assembly, June 29, 1953.
C 44,1
Calvin B. Johnson, M.D., M.P.H. H1e5.105.1 (Rev.e104) Charles Hardeater
Secretary of Health State Registrar
Esc 3830916
SKYE ELIZABETH LANDAVERDE
C/O 5280 A CARLISLE PIKE
NEW OXFORD PA 17350
EXHIBIT B
ACHE ITy
:..
TF,tP.{CKING NUMBER- FOR OFFICIAL
USE ONLY
This is important #n#orm Ion for 6 g_ ' • .i ity of your child.
For help or translation of the.forn1j1please call'
the Bureau of Child Support Enforcement at 1-800-932-0211.
:8:MAMh4 iA akin n:oiull 1011 PdOIN m wlpiu r?}a?l+uprin nrmtfipmq[fttec
yraoeimrenmmoiabmalmnigtggmj&uqo (sureou of child supp«rt Esto es-informacibn importante para establecer la patemidadde su hijo.
uzcan el formulario, [lame al
Enforce wx) t 0-e 1-800-932-0211. Si necesita ayuda o necesija qua le tr-a
Departamento de Curriplirrierito de la anutenci6n de los Hijos
it1A--:F*MiMBk:fO c c f 7 i>ft9aio EI (Bureau of Child Support L5riforcemerrt) al 1-800-932-0211.
R)jA§r M(081-800-932-021t )ILilt) >gh+k
17 . 3997mr16ngtinyoantrpagA*,Cthkc ptfnhhu} f?l ngp 8rcnuconemc'uaglfy',4.
M1& u d*c tro &p*y phk a 4 ch n? wi*' , xin gpi vi n plio ng $oreaa of Cb Bd Support
90OW,'catAW" WM ycT°*mnm^ muosc»n. Euw-e0-µ Enforcement3bd*na"I1-8w-932421t-
Wf*t ri`no-UP- NM fl WOWA eio?owCi` VO*K,; ;?aFStrs a r»4pw'
G"WAeW*K no 1=8W.;932-0211.
r10 ankmNWo
www.childsupport.state ?pa.us
Pennsylvania law provides that the father of a child born to an uDmarrlgg woman may file an Acknowledgment of
Paternity form with,tlie Department of Public Welfare (DRVf/). (23 Pa:;C.S h,*l?Cnow#edgment of Paternity
form shall include the consent and signature of the birth mother, supported by her *14*0d statement, and signature
of the father and is considered conclusive evidence of paternity that does not require approval by the court.
1. I understand that the acknowledgment of paternity is completely voluntary and may be cancelled by either party
by submitting ,signed written statement to the DPW Paterni* eooMinator at: P:O Sex 80.18, Harrisburg, PA 17105-
8018. The Written statement must be submitted within 60 days after the Acknowle4! "1411 df Paternity form is signed
or the date of a court proceeding relating to the child `(whichever is sooner). Afar` a expires, the acknOwl-
edgment of paternity may be challenged in court only on the basis of #raud, duress or nlatei1' mistake of fact, which
must be estatilis'hed"by the chaNengerthrough clear and convincit'h4evldence. Ari order for support shall not be
suspended during the period of challenge, except for good cause.
2. I understand that by signing this Acknowledgment of Paternity form the father shall have atl the. rights and duties
regarding the child as if he had been married to the mother at the time of the child's birth. The child shall have all
the samerights and,duties as to the father which the child would have had if the father had been married to the
mother at the time of birth.
3. 1 Understand that by signing, .th+s Acknowledgment of Paternity form, the parents are rqw d to provide child support
and, healthcare coverage until ft child reaches- at least 18 years of age or graduates hrgh school, whichever occurs
later, unless otherwise ordered-by the court.
4. 1 understand that if both parents sign the Acknowledgment of Paternity form, the father's name shall be listed:on the
Birth Certificate.
5. 1 understand that if the birth mother fails or refuses to sign the Acknowledgment of Paternity form, the putative father
may sign, the form. By signing the Acknowledgment without the mothers consent, he has the right to receive notice
of any proceeding to terminate any parental rights involving the child.
6. 1 understand that if I have any doubt, I may request blood or genetic testing to determine paternity. If 1 sign this
Acknowledgment of Paternity form, I give up the right to blood or genetic testing to determine paternity, unless
cancel the Acknowledgment within 60 days.
7. I understand that if I have any doubt that I am the father of the child, I have the right to speak with an attorney for
legal advice, at my own expense.
5SIGNATURE OF FATHER DATE
DATE OF 9TH z..2. t
CHILD'S NAME *- J l L+ )(
sSIGNATURE OF MOTI ER i + '! LA l tF _, PAT.E_ "L
PA/CS 611 7/04
MOTHER'S COPY
COMMONWEALTH OF PENNSYLVANIA •' DEPARTMENT QB-.PUBIIC WELFARE
BUREAU D,F' GHIt:D SURPOF+NbtIEIVMST
P.O.'BOX 801`8, HARR16BUR4 5A 17105=8048
e r TRACKING NUMBER FOR OFFICIAL
USE ONLY
ER 4, ff Y
'K[ OMMOM l' "Q T _
AC
For a Child' Born to an UrIamed Woman, pursuant toAct-No. 1093-62 and Act No. 1997-58.'
7JF I
1 OF, CO. it STATE
WAS THEI,RILD YES TF'NO, VITHATCOUNTRY? .
BORN IN THE
UNITED STATES? Q NO
FOR OFFICIAL USE ONLY HBU OR CAO CODE
Perl'nsylvariia law provides that the father of a child born to an unmarried woman may file arv Acknowledgment of
Paternity form with.the Department of Public Welfare (DPW). (23 Pa. C.S.A. §5103) The# k=vv1edgrnec ,Patemity
form'shall include the consent and signat4e, of the birth mother and signature of the father.
9'I;36 OY CO 4rpt ,1,,F* aEkn erl pateF%?ijy tFrat-
.I x ?, w
PR1N7 l? (? . ) { E) ([AST) (JR°:ff,lll,IV)
I(MIDQLE> {s the, father of my-0ild na "a ?.,qpd, further- state that I was
;•unmarded at the tithe of tidr5 X14 . 1 understand that false
(?sn statements made herein ais St} tai the penalties of 18 Pa. C.S.
§4904 (relating to unSworn fa1sl Ik n 1d t thorities).
SECURITY NUMBER DATE OF BIRTN(MM/DDlYYW) !4 '
t g{ 4>trht DATE SIGNED (MM/DD )
l i '
- -x
M(PTHER'5 (If elude Street, city State and bp Code)
ADDRESS fr'':Ir° ?•. ( :, ?, ,7 ?? 1„yI 1'? :#." .:-r'"??
WITNESS IS'THE PERSON -VYITNESSED 2 SIGNATURE OF WITNESS (CANNOT BE IRTH MOTHeR-d A R)
l(4STWA[CHTHEBIRT BY ,. t
HER SIGN i}i1S-FORM. } ', { ?i. ?+
r..
( .. , yl
, e father of the child
n'
1 r eiy a `?? .-
1 ? narx)ed above. I u, rstand"tPiat iaents made herein are
(M(DDLE) subject to the penalties of 1$ Pa. C,S. 44904 (relating to unswom
falsification to authorities).
(LAS T)
? ...
S0614?EdURhTYNUMBER DATE OF BIRTH(MMYDDlYYYY) =w'
F of , qT6 sl NE, MnMfyyr
t. ? 01, 1, ,I v'.
I.J
FI?THER 5 Include Street, City, State and Zfd Code)
ADDRESS S i ' i1. _ _ _
,W OF WITNESS ( , T I ?f R R 0 FATHER)
SHE WITNESS & THE PERSON SI ATURE
WHO MUST WATCH THE BIRTH WITNESSEDL'
,FATHER SIGN THIS FORM. BY
FOR THIS FORM TO BE VALID YOU MUST DO THE FOLLOWING:
1) 7'Hij:RE-Ml1ST BE SIGNATURES IN THE FOUR, AREAS DESIQNA7'BQ 8Y?sr, L1 Al 1 a ' k !N'I
2) ,7ti1 RE-MUST BEA SOCIAL SECURITY.NUMBER IF'AVAILAB?'E 0 TI=/9 MOTI ' f itflER'S SECTIONS.
3) ALL SECTI,ONS'MUST BE COMPLETE. IF INFORMATIONDOES'NOT ARRLY W, It" T '
4) THE ACKNOWLEDGMENT OF PATERNITY FORM MUST BE ACCOMPANIbb-'&YA SIGAhED "' j ? , ONSl81LIFIES
AND OBLIGATIONS" FORM.
PA ICS 611 7/04
MOTNER'S COPY
VERIFICATION
I, Christy M. Jennings, hereby swear and affirm that the facts in the forgoing Petition
for Change of Name are true and correct to the best of my knowledge, information, and
belief and are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
Date: C
Christy M. J pings
6
_a
Io:b
CcC 0 2 200
IN THE MATTER OF PETITION FOR COURT OF COMMON PLEAS OF
CHANGE OF NAME OF MINOR CUMBERLAND COUNTY, PENNSYLVANIA
SKYE ELIZABETH LANDAVERDE
. NO.
ORDER FOR HEARING AND PUBLICATION OF PROPOSED NAME CHANGE
AND NOW, this_day of 200 on the motion of
petitioner, on behalf of her minor child, it is ORDERED that a hearing on the Petition for
Change of Name is fixed for them ay of 200_ &'00
P m., in Room 5 of the Cumberland County Court House, One Courthouse
Square, Carlisle, Pennsylvania 17013.
The petitioner is herein directed to give notice of the filing of the petition for the
change of name and of the date set for hearing on the petition by publication in two
newspapers of general circulation in this County where the petitioner resides, one of
which may be the official paper for the publication of legal notices in the county.
By the Court:
J.
Distribution list
? Elizabeth J. Saylor, Esquire
Law Office of Peter J. Russo, P.C.
5006 E. Trindle Road, Suite 100
Mechanicsburg, PA 17050
Attorneys for Petitioner
rn 3 c C£??
(2o r
I
"T l
CC a ca 0'-
IN THE MATTER OF PETITION FOR : COURT OF COMMON PLEAS OF
CHANGE OF NAME OF MINOR : CUMBERLAND COUNTY, PENNSYLVANIA
SKYE ELIZABETH LANDAVERDE
NO. 08-7009 CIVIL TERM
AFFIDAVIT OF SERVICE
I, T. V-te1rjc R-1 - j 12 , being duly sworn according to law, certify that I am over 18 years
of age and not a party to the above-captioned action, served and made known to
M',?t) =- i as ?t i? Dt on the iZL day of j Pi ,v 0 e y , 2009 at
11*j?-_ irdp.m. at 15 0 NuNi? tor)L ???? tlfl ?'???r (?i? t ?'? 31
a Petition for Change of Name issued in the above entitled case in the manner described below:
[ ] Personally delivered them into the hands of the person to be served
[X] Adult family member with whom that person resides. Relationship is W I f
[ ] Agent or person in charge of person's office or usual place of business
[ ] Other. $ff vi c e ry-1'.0r cue 1 La n clc. v r r cl e Lo\?j 1 ea v l .4 w?%
Description of Recipient
Sex: F Skin Color: wm o% E Hair Color: e31Lo-,/
Facial Hair: Np Height (approx.): Weight (approx.): b v
Age: ?
Signature:
Title Badge/ID # (if any)
Address: ' 1 r w N-i ?? ?T ST I
Phone Number: ?, - l y 3 5 13
;.1
(Landaverde Service) - No.08-7009
om before me on 16 1 day o ,
the a iant who is known :t
me.
.A
Y
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
M. Michelle Guyton, Notary Public
Carlisle Boro, Cumberlanc County
M MY Expires July 1, 2012
Memblf, OMI'llIV VAmin Aq%ociation of Notaries
C'J
.%
?:.?.5 = 1
g
-- ' 1. C..._.
;a.a:? _.? "'T"1
.....
,•„_ V
E -.c
i
_:
t* Z
??? y
0
0
IN THE MATTER OF PETITION FOR : COURT OF COMMON PLEAS OF
CHANGE OF NAME OF MINOR : CUMBERLAND COUNTY, PENNSYLVANIA
SKYE ELIZABETH LANDAVERDE
: NO. 08-7009 CIVIL TERM
AFFIDAVIT OF SERVICE
JR. , being duly sworn according to law, certify that I am over 18 years
of age and not a party to the `above-captioned action, served and made known to
00W on the ( Oi1 day of 2009 at
( ,i5=a-.tn/p.m.at (S? NvNic??AL EO -ttjrwV? f F? l? 331
an Order for Hearing and Publication of Proposed Name Change issued in the above entitled
case in the manner described below:
[ ] Personally delivered them into the hands of the person to be served
W Adult family member with whom that person resides. Relationship is \A/ i r i=
[ ] Agent or person in charge of person's office or usual place of business
? L-2f? Z V t C C12 ? leG v i it
[ ] +.- - M ` C?1 a t
Other. f:) e c e- %--v a
Description of Recipient
Sex: r Skin Color: w01 Hair Color: 6fl-0
Facial Hair: A.1
Age: 5
i
Signature: rLx
{
Title Badge/ID # (if any)
Address: 9S w N+ r it ST .1
C.CA jIo13
Height (approx.): ? ' y" Weight (approx.): 16 6
0
Phone Number: J S•;t 10 `?', 113
(Landaverde Service) - No. 08-7009
Subscribed wom t e o me on tL_day of ?? u
?q the cant o is personally own me.
NO PUBLIC
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
M. Michelle Guyton, Notary Public
Carlisle Boro, Cumberland County
M QQmmiston Expires July 1, 2012
817108f, PWRIVIN4019 A§ Otligri of Netaries
c n
c.n
IN THE MATTER OF PETITION FOR : COURT OF COMMON PLEAS OF
CHANGE OF NAME OF MINOR : CUMBERLAND COUNTY, PENNSYLVANIA
SKYE ELIZABETH LANDAVERDE
NO. 08-7009 CIVIL TERM
ORDER
AND NOW, this l am day of P' kflr , 2009 in consideration of the
Petition for Change of Name filed on behalf of Skye Elizabeth Landaverde, and upon
presentation of proof of publication of notice as required by law, together with proof that
there are no judgments or decrees of record or any other matter of like character
against the minor child given her age, and it appearing that there is no lawful objection
to the request of the petitioner after a hearing thereon, it is hereby ORDERED that the
name of petitioner Skye Elizabeth Landaverde is changed to Skye Elizabeth Jennings.
BY THE COURT:
UA \ I J.
Distribution list:
Elizabeth J. Saylor, Esquire laWW .3/i91oy'
Law Office of Peter J. Russo, P.C.
5006 E. Trindle Road, Suite 100
Mechanicsburg, PA 17050
Attorneys for Petitioner
Michael L. Landaverde
150 Municipal Road
Hanover, PA 17331
Pro se Defendant
??
--n sue:
F ?4 ? ?,
? ??
?
.
??
^yy
`
?, '? `td
?` }
.
?3
? ???- ? ?.
^- (y„