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HomeMy WebLinkAbout04-2833Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market S~'eet P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Petitioner Dana Lynn Askey In the Petition of Dana Lynn Askey for the change of name of Thomas James Askey- Wilkinson to Thomas Askey James IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C~RPt IAN~ ~t~KT B~I~ION PETITION FOR NAME CHANGE PURSUANT TO ~ Pa.C.S.A. 6 701. et s~. TO: THE HONORABLE JUDGE OF SAID COURT: AND NOW, Dana Lynn Askey through her attorneys Johnson, Duffle, Stewart & Weidner, respectfully represents the following: 1. Petitioner is Dana Lynn Askey of 400 Seventh Street, Apt. 1, New Cumberland, PA 17070. 2. The Petitioner desires to change her name from Dana Lynn Askey to Dayna Lynn Askey James pursuant to 54 Pa. C.S.A. § 701 and desires to change the name of her minor child from Thomas James Askey-Wilkinson to Thomas Askey James pursuant to 54 Pa.C.S.A, § 703. 3. Petitioner has concurrently filed a separate petition seeking to change her name and, if granted, Title 24 provides that the new surname of mother shall be borne likewise by the child unless otherwise ordered by the Court, 54 PA. C. S. A. § 703, 4, The Petitioner's reason for desiring the change of the child's name are: (a) The Petitioner is the adoptive child of Charles and Sharon Askey, and the Petitioner's only known blood relative is her son, Thomas James Askey-Wilkinson, born February 4, 1999. As such, Petitioner Askey believes that it is in the best interests of her son and herself to have the same surname in order to honor their blood relation and status as a family. (b) The biological father, Jason A. Wilkinson, has no relationship with the child and has had no contact with him whatsoever for a period in excess of five years. (c) The change is in the child's best interest because he will be starting school in the fall and the Petitioner desires to prevent confusion and avoid embarrassment caused by having the surname of a non-participant Father and a dissimilar surname from that of his Mother. (d) The change of the child's surname will not impair the relationship with Father because none exists. (e) Dana Lynn Askey is and always has been the sole custodial parent to the child and he has lived with her continuously throughout his life in Cumberland County. (f) No confusion will result for the child because he understands his name to be "Thomas James" and does not know his current surname. 4. Petitioner requests this Court: (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. 5. Petitioner requests this Court that her child not be subject to the requirement of fingerprinting or notification of the State Police Department on his behalf pursuant to 54 Pa.C.S.A. § 702(b) (5) (iii). 6. Petitioner requests this Court to waive the requirement for official searches of the proper offices of the county where the child resides on the grounds that the subject of this petition is a minor, 5 years of age and avers that there are not judgments or decrees of record or any other matter of like character against him. I, Dana Lynn Askey, verify that the statements made in this Petition are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A. {}4904, relating to unsworn falsification to authorities. Date: (_~//'-~ t 0~ By: Dana Lynn Askey (~ Date: JOHNSON~3~"PI)E, STEWART & WEIDNER k~ssa eel reevy :230793 IN THE PETITION OF : DANA LYNN ASKEY : FOR THE CHANGE OF : NAME OF THOMAS : JAMES ASKEY- : WILKINSON TO : THOMAS ASKEY : JAMES : AND NOW, this IN THE COURT OF COMMON PLEAS OF CUMBERLAND COLD4TY, PENNSYLVANIA CIVIL ACTION - LAW 04-2833 CIVIL TERM ORDER OF COURT 13th day of July, 2004, upon consideration of the attached Petition for Name Change Pursuant To 54 Pa. C.S.A. §701, et seq., a hearing is scheduled for Thursday, September 23, 2004, at 2:30 p.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. IT IS FURTHER ORDERED that notice of the filing of said Petition and the aforesaid date, time and place of the hearing be published once in the Cumberland Law Journal and a newspaper of general circulation in the Coun]Iy at least 10 days prior to the hearing; in addition, Petitioner shall comply with all other requirements of C.C.R.P. 5, and the Act of December 16, 1982, P.L. 1309, §6 (see 54 Pa. C.S. §701 [Historical and Statutory Notes] [Main Volume]), and 54 Pa. C.S. §§701 et seq. BY THE COURT, J.~Vesley Oler, Jr., J. -- Melissa Peel Greevy, Esq. P.O. Box 109 Lemoyne, PA 17043 Attorney for Petitioner :rc IN THE PETITION OF DANA LYNN ASKEY FOR THE CHANGE OF NAME OF THOMAS JAMES ASKEY- WILKINSON TO THOMAS ASKEY JAMES IN TIHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2833 CIVIL ACTION - LAW RETURN OF SERVICE The undersigned makes the following return of service: The Petition for Name Change and Order of Court were mailed to the Defendant, Jason A. Wilkinson, on September 1, 2004 and September 8, 2004, respectively, at 5 Laughlin Circle, Altoona, PA 16602: X Copies of the signed return receipts indicating service was completed for the Petition and Order on September '10, 2004 are attached hereto. The mail, refused and returned, is attached. A copy mailed to the Defendant at the same address by ordinary mail with the return address of the sender appearing thereon has riot been returned within fifteen days after mailing. I, Melissa Peel Greevy, certify that I am a competent adult not a party to the action. I verify that the statements made in this affidavit and return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: September 20, 2004 JOHNSON, D~I~EWART & WEIDNER Melissa Peel Greevy Attorney I.D. No. 77950 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telepho~e (717) 761-4540 Attorneys for Petitioner :235618 2-' " IN THE PETITION OF DANA LYNN ASKE¥ FOR THE CHANGE OF NAME OF THOMAS JAMES ASKEY- WILKINSON TO THOMAS ASKEY JAMES IN THF_ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2833 CIVIL ACTION - LAW PROOF OF PUBLICATION Attached hereto is Proof of Publication in the Cumberland Law Journal on August 6, 2004 noticing the hearing of September 23, 2004 at 2:30 p.m. in this matter. This Publication was made pursuant to C.C.R.P. 5, and the Act of December 16, 1982, P.L. 1309, § 6 (see 54 Pa. C.S. §701 [Historical and StatutoP./Notes] [Main Volume]), and 54 Pa. C. S. §§ 701 et seq. Date: September 21, 2004 JOHNSON, DUFFLE, STEWART & WEIDNER -Melissa Peel Greevy ~ Attorney I.D. No. 77950 301 Market Street P.O. Box 1{;)9 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Petitioner :235761-3 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L. 1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland ]Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local couxts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz AUGUST 6, 2004 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. SWORN TO AND SUBSCRIBED before me this 6 day of A_____U_UGUST 2004 LOIS E, SNYDER, Notary Public Carlisle Boro, Cumberland Count,/ My Commissio~ E~:pires March 5, 2005 CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas Cumberland County, Pennsylvania No. 04-2833 Ci~l IN THE PETITION OF DANA LYNN ASKEY FOR THE CHANGE OF NAME OF THOMAS JAMES ASKEY- WILKINSON TO THOMAS ASKEY JAMES NOTICE NOTICE IS HEREBY GIVEN that on June 21, 2004, the Petition of Dana Lynn Askey was filed in the above-named Court, requesting an order to change the name of her son Thomas James Wilkinson to Thom- as Askey James. The Court has fixed the day of September 23, 2004 at 2:30 p.m., in Courtroom No, I of the Cumber- land County Courthouse, One Court- house Square, Carlisle, PA 17013, as the time and place for the hear- ing on said Petition, when and where ail interested parties may appear and show cause, if any, why the requests of the Petitioner should not be granted. MELISSA PEEL GREEVY, ESQUIRE JOHNSON, DUFFIE, STEWART & WE1DNER 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 July 27, 2004 Aug, 6 4 IN THE PETITION OF DANA LYNN ASKEY FOR THE CHANGE OF NAME OF THOMAS JAMES ASKEY- WILKINSON TO THOMAS ASKEY JAMES IN THE COURT OF COMMON PLEAS 'OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2833 CIVIL ACTION - LAW COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SS: AFFIDAVlT OF TAMMY L. KITNER I, Tammy L. Kitner, being employed by Johnson, Duffle, Stewart & Weidner in a capacity for which I routinely check judgment indexes of several local counties represent the following: As required by § 54 Pa. C. S. 701, I have performed a search on Dana Askey and hereby certify that on September 21, 2004 there were no pending court suits or actions or outstanding, unsatisfied judgments or decrees of record in the Dauphin County Court of Common Pleas for the Commonwealth of Pennsylvania. I verify that the statements in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Sworn and subscribed to before me this ,,,~! ~-~ay of~2004. - Notary Public Nota~a~Seal ~ K, Myel~s, No~ Public MY Commission Expires Dec. 2, 2006 :235702-2 IN THE PETITION OF DANA LYNN ASKEY FOR THE CHANGE OF NAME OF THOMAS JAMES ASKEY- WILKINSON TO THOMAS ASKEY JAMES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2833 CIVIL ACTION - LAW COMMONWEALTH OF PENNSYLVANIA: : COUNTY OF CUMBERLAND SS: AFFIDAVlT OF TAMMY L. KITNER I, Tammy L. Kitner, being employed by Johnson, Duffle, Stewart & Weidner in a capacity for which I routinely check judgment indexes of several local counties represent the following: As required by § 54 Pa. C. S. 701, I have performed a search on Dana Askey and hereby certify that on September 21, 2004 there were nc, pending court suits or actions or outstanding, unsatisfied judgments or decrees of record in the Cumberland County Court of Common Pleas for the Commonwealth of Pennsylvania. I verify that the statements in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Sworn and subscribed to before me this ~/Mday of~ 2004. Notary Public :235702 IN THE PETITION OF DANA LYNN : ASKEY FOR THE CHANGE OF NAME : OF THOMAS JAMES ASKEY- : WILKINSON TO THOMAS ASKEY : JAMES : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-2833 CIVIL TERM IN RE: LIEN SEARCH REQUIREMENT WAIVED ORDER OF COURT AND NOW, this 23rd day of September, requirement that petitioner at No. 2004, a lien search be conducted for the minor 04-2833 Civil Term is waived. By the Court, the Melissa Peel Greevy, Esquire 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 For the Petitioners :mae IN THE PETITION OF DANA LYNN : ASKEY FOR THE CHANGE OF NAME : OF THOMAS jAMES ASKEY- : WILKINSON TO THOMAS ASKEY : JAMES : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-2833 CIVIL TERM IN RE: PETITION FOR CHANGE OF NAME ORDER OF COURT AND NOW, this 23rd day of September, 2004, upon consideration of the attached petition and after hearing, it is found that the requirements of 54 Pa.C.S.A. Sections 701 and 703 have been satisfied and it is in the best interests of the child that the name of Thomas James Askey-Wilkinson is changed to Thomas Askey James. By the Court, Jyesley 01~, Jr., J. Melissa Peel Greevy, Esquire 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 For the Petitioners :mae