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Home My WebLink About09-3263Pamela L. Purdy Attorney ID No. 85783 308 N. Second Street, Suite 200 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Petitioners IN RE PETITION FOR NAME CHANGE BY CLIFFORD & LINDA HANNER ON BEHALF OF THEIR MINOR GRANDSON, CADEN MAXWELL CUPP IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. Oy_ 3-G3 Ccu-i T7 VIMN PETITION FOR NAME CHANGE 1. Petitioners are Clifford and Linda Hanner, the guardians and natural grandparents of Caden Maxwell Cupp, a seven year old minor who was born on January 13, 2002. 2. Petitioners and the child currently reside at 6203 Whitehill Drive, Mechanicsburg, PA 17050. 3. The Petitioners desire to change the child's name from Caden Maxwell Cupp to Caden Maxwell Hanner. 4. The Petitioners' reasons for desiring this change of name of the child are that: (a) The Petitioners have had custody of the child since November 2005, are the legal guardians of the child since August 2007 and would like him to have their last name. (b) The child does have regular contact with his natural mother, Brenda Hanner. (c) The Petitioners desire to protect the child from the psychological and emotional confusion which may result from the child and grandparents, as well as mother, having two different surnames. (d) The child's natural father, Steven Cupp, has not initiated visitation rights with the child in at least four years and his current address is unknown. (e) The child has requested that his name be changed to match his mother and grandparent's last name. 5. The child has lived at the following addresses in the last five years: Address Dates 70 Ashford Court Enola, PA May 2003 to November 2005 6203 Whitehill Drive Mechanicsburg, PA 6. Petitioners request this Court: November 2005 to present (a) to fix a hearing on this petition; and, (b) to direct that notice be given of the filing of this petition and the hearing. 7. Petitioners further request this Court to waive the requirement for official searches of the proper offices of the county wherein Petitioners reside on the grounds that the subject of this petition is a minor and avers that there are no judgments or decrees of record or any other matter of like character against him. Respectfully submitted, Pamela L. Purdy Attorney for Petitioners Dated: 14 1 &' 200) ,?/ VERIFICATION I 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 are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Cliffo anner Dated: ?J? f - CERTIFICATE OF SERVICE The undersigned certifies that on this 1a, day of May, 2009> a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Brenda E. Hanner 516 Berkshire Lane Mechanicsburg, PA 17050 Steven H. Cupp 3709 Wheaton Drive Bedford, TX 76021 . P" I.-V P?_?/ Pamela L.Purdy r *18 .50 PO ATTY CC* 130 We MAYS 2 6 ZouC,, IN RE PETITION FOR NAME IN THE COURT OF COMMON PLEAS CHANGE BY CLIFFORD & LINDA CUMBERLAND COUNTY, PA HANNER ON BEHALF OF THEIR : 3a(o3 C?v?lT?M1 MINOR GRANDSON, CADEN NO. MAXWELL CUPP DECREE OF COURT FIXING HEARING 1. A hearing on the petition of Clifford & Linda Hanner on behalf of their minor grandson, Caden Maxwell Cupp, for change of name is fixed for at •00 dL' M. T at Courtroom , Cumberland County Courthouse, Carlisle, Pennsylvania. 2. The petitioners are directed to give notice of the hearing by publication in two 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. BY T CO RT- J. Date: '7'?'c z'Tta q ?,ew ?Jv Pamela L. Purdy, Esquire Attorney ID No. 85783 308 N. 2"d Street, Suite 200 Harrisburg, PA 17108 (717) 221-8303 tel (717) 221-8403 fax plpurdy@verizon.net Attorney for Petitioner IN RE PETITION FOR NAME CHANGE BY CLIFFORD AND LINDA HANNER ON BEHALF OF THEIR MINOR GRANDSON, CADEN MAXWELL CUPP IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO.09-3263 CIVIL ACTION - LAW MOTION FOR CONTINUANCE Petitioners Clifford and Linda Hanner, by and through their attorney Pamela L. Purdy, Esquire, hereby moves this Honorable Court for a continuance and avers as follows: 1. This Court scheduled a hearing on Petitioner's Petition for Name Change for July 24, 2009 at 11:00 A.M. 2. Petitioner's counsel is attached to York County's custody trial week, as well as a Custody hearing in Perry County at 9:00 a.m. on that date. 2. The Honorable Edward E. Guido entered the scheduling order in this matter. 3. There are no opposing parties in this matter. WHEREFORE, counsel for the Plaintiff requests that this Honorable Court grant a continuance to the next available date. Respectfully submitted, ?7" ?' p- Pamela L. Purdy Counsel for Petitioners Dated J un. 3, 20&1 2 I lb CERTIFICATE OF SERVICE, / The undersigned hereby certifies that on theI °- day of June, 2009, a true and correct copy of the foregoing document was served by regular mail upon the following: Brenda E. Hanner 516 Berkshire Lane Mechanicsburg, PA 17050 Steven H. Cupp 3709 Wheaton Drive Bedford, TX 76021 poij t 1 Pamela L. Purdy R t`i iCE OF THE PROTHONOTAFW 2009 JUN -5 Phi 3: 53 CuM6b?ILtgNu (IJUNTI Y f'EP NSMAWIA. JUN 0 0 20096 IN RE PETITION FOR NAME IN THE COURT OF COMMON PLEAS CHANGE BY CLIFFORD AND CUMBERLAND COUNTY, PA LINDA HANNER ON BEHALF OF THEIR MINOR GRANDSON, NO.09-3263 CADEN MAXWELL CUPP CIVIL ACTION - LAW ORDER AND NOW, this day of June, 2009, upon consideration of Ow lV04,41 lo let lq -fX,:S A -m& - EQu .vo Lorr `o uA n/ . J"s n in nia, one tices n /? kt `oun.S Ll r lew L;7;&/y AV 46 /-Y.r6in fl s 17A .-m toW.. ?Y R2 y C t ?' W-9