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HomeMy WebLinkAbout09-2128IN RE: NOAH CORNETT ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION NO. 2009 - ;t 1-2 P CIVIL TERM PETITION FOR CHANGE OF NAME NOW COMES Petitioner, Brandi Stum, by and through her attorney, Neuharth Law Offices who petitions this Honorable Court to change her minor child's name from Noah Cornett to Noah Stum, and in support of her petition to change his name pursuant to 541Pa.C.S.A. §701 et seq., represents as follows: 1. Petitioner Brandi Stum, "Mother," is an adult individual who resides at 132 West Orange Street, Shippensburg, Cumberland County, Pennsylvania 17257. 2. The child was born Noah Cornett on November 9, 2006. 3. Since birth the child has lived at the following addresses: a. From birth to December 2006, Mother and the child resided at 462 Arborshade Drive, Inwood, West Virginia 25428. b. From December 2006 to present, Mother, the child and Mother's husband have resided at 132 West Orange Street, Shippensburg, Cumberland County, Pennsylvania 17257. 4. Mother has never been convicted of a felony and is not requesting the name change for a fraudulent purpose or to avoid creditors. Furthermore, the child is about two d one half years old, has no credit history and has never been subject to any criminal activity. i 5. Mother believes changing the child's name serves the child's best interest because: a. Mother's maiden name is Brandi Cornett. At the time Mothe gave birth to the child, she was not married, and she gave the child her maidenj name, "Cornett." b. On May 10, 2008, Mother married Brent Stum and took his laGst name. Mother and her husband had a child together subsequently; this child'Is surname is "Stum." Mother seeks to have the child share her married surname, "Stum." d. Mother believes it serves the child's best interest that the child share the same surname as Mother, Mother's husband and the child's baby si8ter. e. Mother believes a change in the child's surname will strengthOn the child's family unit and family identity. f. Mother believes that a change in the child's surname will alleviate any confusion or unease that may arise if the child retains his current surname. Such confusion or unease could arise once the child enrolls in school and grows older. g. In approximately early 2006, Mother conceived the child. At the time of conception, Mother was attending a crowded party in which alcohol was served. Mother has no recollection of conceiving the child, and she does not know the identity of the child's father. h. Mother's husband is the child's father figure and the only father the child has ever known. 6. For the reasons stated in Paragraph 5, Mother believes it serves the best interest of Noah Cornett to change his name legally to Noah Stum. 7. Petitioner is the child's natural mother. Mother does not know the idehitity of the child's natural father. Mother's husband, Brent Stum, is the only father figure the child has ever known. 8. ?I Other than the child's unknown father, Mother does not know of any ther party who have a claim of right to custody or who would have an interest in these proce dings. . , , , 9. The child is not subject to the requirements of 54 Pa.C.S.A. §702 regarding fingerprinting and forwarding the information to the Pennsylvania State Police. WHEREFORE, Petitioner Brandi Stum respectfully requests this Honorable Court to: a. fix a date, time and place for a hearing on this matter; and b. direct that notice of the filing of this petition and of the hearing be published one time in a newspaper of general circulation in Cumberland County, Pennsylvania and one time in the Cumberland Law Journal; and c. after a hearing, enter a decree changing the name of Noah Cornett to Noah Stum. Respectfully Submitted,' NEUHARTH LAW OFFICES Paul M. Fergusorf Supreme Ct. No.: 203293 Attorney for Petitioner P.O. Box 359 232 Lincoln Way East Chambersburg, PA 17201 (717) 264-2939 VERIFICATION I verify that the statements made in this petition are true and correct 0 the best of my knowledge, information and belief. I understand that any false statements herein are made subject to the penalties of perjury contained in 18 Pa.C.S.A §4904 relating to unsworn falsifications to authorities. Date randi Stum AIEU- CE OF THE P TH }TARY 2009 APR -6 AM 10: 13 I' AILD COUNTY PENS SYWANIA $gg.50 PD A-rr\f Cluj` 1369 eta` U244 1w y I ' APR 07 2U1,N (9 J IN RE: NOAH CORNETT AND NOW, this consideration of the within P Ail 2009 at of the Cumberland County C u1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION NO. 2009 - oll aS CIVIL TERM ORDER OF COURT day of Q*a; , 2009 upon presentation and k, a hearing thereon is scheduled for the t5b* day of 10, of) o'clock, I in. in Courtroom number S Notice of the filing of the Petition and of the time and place of the hearing thereon shall be published one (1) time ea4h in a newspaper of general circulation in Cumberland County, Pennsylvania and the Law Journal. BY THE COURT, 0 0 s :ZI tad £ I ddv 60oz AbvlCytiorilio?d 3A ?o 90WO-CTY IN RE: NOAH CORNETT ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION NO. 2009 - 2128 CIVIL TERM ORDER OF COURT NOW, this S T day of 2009, upon consideration of the Petition for Change of Name and after a hearing on the above-captioned matter, it is found that the requirements of 54 Pa.C.S. §701 have been satisfied and the name of Noah Cornett is changed to Noah Stum. d de[iv?e ??- Co e* Pow' ,?,?09 D? BY THE COURT, tL ?? 2009 J?:L - I AM 10: 10