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HomeMy WebLinkAbout04-1810IN RE: BRADFORD R. SCOTT EXUM : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO.: : : CIVIL ACTION PETITION FOR CHANGE OF NAME AND NOW comes Petitioner Linda Schaufert, by and through her counsel REAGER & ADLER, PC and respectfully represent the following: 1. Petitioner Linda Schaufert is the natural mother and custodial parent of Bradford R. Scott Exum, date-of-birth January 6, 1991. 2. Petitioner and the minor child reside at 497 Crepe Myrtle Drive, Boiling Springs, Pennsylvania, 17007. 3. At birth, the minor child was named Bradford R. Scott Exum. Exum was the surname of the minor child's natural father, William Jordan Exum. The last known address of William Jordan Exum is 909-A Leesville, Lynchburg, Virginia. 5. Petitioner and the natural father were divomed on February 25, 1991. Petitioner was granted sole custody of the child at that time. 6. Petitioner and the child relocated to Pennsylvania on January 20, 2000. 7. Petitioner married Eric Schaufert on April 2, 1994, at which time Petitioner took Husband's surname. Eric Schaufert was killed in an accident on April 25, 2003. 8. The last contact the minor child had with his natural father was in the fall of 1992/early winter 1993. 9. Since that time, the only contact between the child and his natural father has been through the payment of support through the Division of Child Support Enforcement, in Lynchburg, VA. An attempt to obtain Mr. Exum's current address from this agency was made, and the agency declined to release the information. Bradford R. Scott Exum is a minor child and has never been convicted of any 10. crimes. 11. Bradford R. Scott Exum is a minor child and has never filed for bankruptcy under 11 U.S.C. §101, et. Seq. 12. There are no judgments or liens of record and no actions pending against Bradford R. Scott Exum in any Court of this state or of the United States or of any government subdivisions. 13. The minor child Bradford R. Scott Exum has not at any time made assignments through the benefit of creditors. 14. There are no claims, demands, liabilities, or obligations of any kind on any written instrument or otherwise against the minor child Bradford R. Scott Exum under the name sought to be changed or any other name. 15. The minor child has no creditors who may be adversely affected or prejudiced by the proposed change of name. 16. Petitioner, Linda Schaufert, the natural mother of the minor child Bradford R. Scott Exum desires to change her son's name from Bradford R. Scott Exum to Bradford R. Scott Schaufert for the following reasons: a. The child has had no contact with his natural father in approximately 11 b. Eric Schaufert was the only father that the child has ever known. c. The child's half-brother and natural mother maintain the last name of Schaufert and Petitioner desires for all of her children to have the same last name. d. It is unknown whether or not the natural father, William Jordan Exum, will object to this Petition. WHEREFORE, Petitioner respectfully requests this Co~rrt to grant this Petition and direct the minor child's name be changed Bradford R. Scott Exum to Bradford R. Scott Schaufert. Date: Respectfully submitted, Reager & Adler, PiE D[~a ~'h2s6n Cantor, Esquire Attorney ID No.: 66378 2331 Market Street Camp Hill, PA 17011 (717) 763-1383 Attorneys for Petitioner Linda Schaufert VERIFICATION I, Linda Schaufert, verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsification to authorities. Date: LINDA SCHAUFERT IN RE: BRADFORD R. SCOTT EXUM IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 0q-I~10 ~c[~,-,~ CIVIL ACTION SCHEDULING ORDER AND NOW this }~a~- day of ~¢[J,'k~- ,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 gq gt~ day of (~ ,2004 at l(; q~'- a.m./pm, in Courtroom #t,¢~ , Cumberland County Courthouse, One Courthouse Square, Carlisle, PA. The Petitioner is hereby directed to provide notice of the filing of this Petition and of the day set for the Hearing thereon in the Cumberland County Law Joumal and the Carlisle Sentinel. 1N RE: BRADFORD R. SCOTT EXUM IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 04-1810 CW1L ACTION PETITION TO SERVICE NOTICE VIA PUBLICATION AND NOW comes Petitioner Linda Schaufert by and through her counsel Reager & Adler, PC and requests this Honorable Court for permission to serve by publication as follows: 1. Petitioner is the natural mother of Bradford R. Scott Exum. 2. The natural father of the minor child is William Jordan Exum, with a last known address of 909-A Leesville Road, Lynchburg, VA. 3. The Petition in this matter was filed on April 26, 2004. Prior to that time, counsel attempted to contact William Jordan Exum at his last known address, and the mail was returned. In addition, counsel attempted to obtain a current address from the Department of Social Services, Division of Child Support, Lynchburg District Office,, 2127 Lakeside Drive, Lynchburg, VA. Attached hereto as Exhibit "A" is a copy of the refusal to release this information to our office. Counsel is unable to locate William Jordan Exum for service. 4. No address could be obtained from the Internet. 5. Since Petitioner is unable to locate William Jordan Exum's last known address in Lynchburg VA, counsel for Petitioner requests permission to serve notice of the hearing on William Jordan Exum by publication in the Lynchburg News and Advance WHEREFORE, since Petitioner is unable to locate William Jordan Exum's last known address in Lynchburg VA, counsel for Petitioner requests permission to serve notice of the hearing on William Jordan Exum by publication in the Lynchburg News and Advance. Respectfully submitted, Reager & Adler, PC Date: ._~/..~¢/~) ¢ D~"l~nison/C~or,'~squire 32ttom~y ID # ~/.6~78 ~ 2331 Market Stree~Y~-''~ Camp Hill, PA 17011 (717) 763-][383 Exhibit A 'Nar ES 04 04:32p L~nohbur~ Child Support ~343850860 Department of Social Services Division of Child Support Enforcement Lynchburg District Office 2127 Lakeside Drive, Lynchburg, VA. 24501 FACSiMiLE TRANSMZ$$ION Telephone: 1-800-962-3492 Facsimile: (434) 385-0860 To: Fax Number: You should receive I page(s) including the cover sheet. If you do not receive all pages, please call 800-962-3492. CO1VIMENTS: .~a~ -m__ u_.a~ or __c~_~.___~m___~.o_.v..,.~__~..~o~__. .............. = .................. ~'~ L/au, . ....... ............................. ........................................ This information is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivering the message to the recipient, you are hereby notified that any dissemination, distribution or copying of this communication is stricti~ prohibited. If you have received this communication in error, please notify us by telephone and return by regular mail. IN RE: BRADFORD R. SCOTT EXUM : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 04-1810 CIVIL TERM ORDER OF COURT AND NOW, this q~-~f~-~day of June,, 2004, the hearing currently scheduled for June 28, 2004, is cancelled and rescheduled for Thursday, July 29, 2004, at 9:00 a.m., in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania. ,-~ebra Denison Cantor, Esquire For Petitioner ~ :sal By the Court, ~ .//.~/' Edgar'l~ay~'ey, j.,/ /~ IN RE: BRADFORD R. SCOTT EXUM AND NOW this that William Jordan Exum shall be served and notified of this Order via publication in the Lynchburg News and Advance. Proof of publication shall be provided to the Court. 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 04-1810 CiVIL ACTION -'~,~ day of . ~ t~'~ 2004 it is hereby ORDERED BY THE b'RT Z Judge Ed~"~ B. Bayl~f (_../-"~ '~' / IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA IN RE: BRADFORD R. SCOTT EXUM NO.: 04-1810 CWIL ACTION AFFIDAVIT OF LINDA SCItAUFERT I, Linda Schaufert, mother of Jayson Brent Exum hereby attest that William Jordan Exum's mother is deceased; the whereabouts of Mr. Exum's father is unknown, as is the last name and whereabouts of Mr. Exum's sister. I am aware of two relatives of Mr. Exum's, Tony Mayhew, a cousin, and Linda Mayhew, an aunt. I have not had contact with either person in the last ten years and do not know their whereabouts. I know of no additional family members. Datei~/~¢~,~ c/W~?~ o~Oz// Li fcrt COMMONWEALTH OF PENNSYLVANIA: :SS. COUNTY OF ~_~.~'~d~ ( ~4 : ~"~'~aday of June 2004, before me, a Notary. PubliC :irka~d for the Commonwealth of On the Pennsylvania, the undersigned officer, personally appeared,*C .nru *-~ ~3~~l)3tC4kn tb':~.~c~. Ii, is factory proven) to be one of the parties executing the foregoing instrument, and he or she acknowledges the foregoing instrument to be his or her free act and deed. 1N WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and year first above written. CA NO'fAR AL SEAL ~ $$ANDRA T. ROSENBAUM, Notary Public ~ Camp Hill Boro, Cumberland County ~ ~..My Commission Expires December 4, 20044 Notary Public My Commission Expires: I, Daria Baransky, employee of Reager & Adler, PC, inserted the names of Anthony (Tony) Mayhew and Linda Mayhew in an Internet search engine and came up with the following names and numbers. I contacted each individual at these numbers and either received no reply or was informed that they were not related to William Jordan Anthony L. Mayhew (540) 436-9444 Anthony Mayhew Anthony Mayhew Anthony Mayhew Tony L. Mayhew Tony W. Mayhew L.C. Mayhew L.D. Mayhew L.D. Mayhew (804) 883-7196 (757) 345-0931 (757) 345-0961 (540) 586-4720 (434) 342-9449 (703) 549-0461 (434) 237-5706 (540) 942-5531 Date: Dada Baransky (// COMMONWEALTH OF PENNSYLVANIA: COUNTY OF ~'h~t~L4~4~9~/r t 4U4t<~ : : SS. On the ~ day of June 2004, before me, a Notary Pnblic in and for,4~e~.~r~ ~Co~0n~. I, Commonwealth of Pennsylvania, the undersigned officer, personally appeared;U~o~vn to me ~ (or satisfactory proven) to be one of the parties executing the foregoing instrument, and he or she acknowledges the foregoing instrument to be his or her free: act and deed. 1N WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and year first above written. NOTARIAL SEAL CASSANDRA T. ROSENBAUM, Notary Public~ Camp Hill Boro, Cumberland County MY C°m-?~s-?~" ?P!re~ ?e~-e?ber 4' 2004 Notary Public ~ My Commission Expires:/ IN RE: JAYSON BRENT EXUM ~4/- /gl/ & IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 0¥- /O3 CiVIL ACTION ORDER ANDNOWthis '~"~ dayof ~)~/.~,,~ ,2004, afteraheadng . - 5 ~ l lO~n the Court bein full having been held in the matter, and based upon the attacned Pet't' , , g Y advised, finds the statements made in the Petition are true, and the desire to change name is proper and not detrimental to the interest of any person, and therefore it is hereby ORDERED that the name of the Petitioner shall be changed from Jayson Brent Exum to Jayson Brent Schaufert. IN RE: BRADFORD R. SCOTT EX1JM IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION ORDER~ a~er'~, ~d ~fe 2004, after a hearing having beaten hNel~ iWn ~1~ m ~ lo~i the Court, being fully advised, finds the statements made in the Petition are true, and the desire to change name is proper and not detrimental to the interest of any person, and therefore it is hereby ORDERED that the name of the Petitioner shall be changed from Bradford R. Scott Exum to Bradford R. Scott Schaufert.