HomeMy WebLinkAbout01-7133IN RE: HILARIE HUME,
Parent and Guardian of
SHANE E. GRAMM,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
PETITION FOR NAME CHANGE
Petitioner, by and through her attorney, The Law Office of Darrell C. Dethlefs, files the
above captioned Petition for a name change and avers as follows:
1. Petitioner is the natural mother of Shane E. Gramm, who is a minor child born on
September 19, 1996 hereinafter "child".
2. Petitioner and Shane E. Gramm have resided at the following addresses:
A. 115 North 31st Street, Camp Hill, Pennsylvania from February of
1998 to the present;
B. 1702 Letchworth Road, Camp Hill, Pennsylvania, from November
1996 to February 1998;
C. 13th Street, Harrisburg, Pennsylvania, from September 19, 1996
until November 1996 with father Lee Gramm.
3. No judgments or decrees of like character of record against Shane E. Gramm.
4. It is in the best interests of Shane E. Gramm to have his name changed to Shane
David Hume since Petitioner, his natural mother's surname is Hume and Shane
has had no contact with his father Lee Gramm since December 1999, with
random contact prior to December 1999. Additionally, for school purposes it is in
Shane's best interest to Shane the same surname as Petitioner.
5. Father, Lee E. Gramm, is the natural father of Shane E. Gramm.
WHEREFORE, Petitioner requests the Court to change the name of Shane E. Gramm to
Shane David Hume.
Date:
Respectfully Submitted,
LAW OFFICE OF DARRELL C~ ~JETHLEFS:/
Michael J. Pyko~h, Esquire
Attorney Identification No. 58851
3805 Market Street
Camp Hill, PA 17011
(717) 975-9446
I hereby verify that the statements of fact made in the foregoing Petition are true and
correct to the best of my knowledge, information and belief. I understand that any false
statements therein are subject to the criminal penalties contained in 18 Pa C. S. Section 4904,
relating to unsworn falsification to authorities..~..~/~/~,~. , _
Date: - - - Hilarie A. Hume
PA
5 ~o~
BLANK
ADDITIONAL INFORMATION
P 4-124 (3-96) PENNsYLVANiA STATE POLICE
IN RE: HILARIE HUME,
Parent and Guardian of
SHANE E. GRAMM,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
AND NOW, thisbe)/~' day of ~ 20(~pon Motion of
Pet~.er, it is
hearing on the Petition for a name change is fixed for the ~
Ordered
that
a
~ 20Q/~at ~: OC) o'clock~in court room number ..~ ofthe
Cumberland County Courthouse.
Petitioner is directed to give notice of the filing of the Petition and the date and time of the
hearing by publication in two newspapers of general circulation in this county, one of which may
be the official newspaper for publication of legal notices in this county. The Petitioner is further
directed to give notice of filing of the Petition and the date of the hearing to any non-participating
parent of the child, whose name will be affected by certified mail return receipt requested.
L
IN RE: HILARIE HUME,
Parent and Guardian of
SHANE E. GRAMM,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 01-7133
:
CERTIFICATE OF SERVICE
I hereby certlflj that a true and correct copy of the Petition for a name change and Order of
Court were served upon Lee E. Gramm on February 26, 2002 p.m. by U.S. Mail, Certified Retum
Receipt. The green card is attached hereto and labeled Exhibit 'A". ,~
/ /
5Attorney Identifica io 1
3805 ManY, et Street
Camp Hill, PA 17011
(717) 975-9446
i lENDER: I also wish to receive the
· Complete items 1 and/or 2 for addlitonal servk~s, following ssrvices (for an
· ~l~tt~O ~is~On~ tO the fro~t of the mailplece, or on the back If space does not 1. r'-I Addmssee's Address
rmit. · 2 [] Restricted Delivery
~ ~iveRr~n Receipt will st~:~ ,o ,,,~h o m the art ~'1* was delivered and the date Consult postmaster for fee.
3. A~ticle Addressed to: 1 4a. Article Number
~ ' ~ _ __ 14b. Service Typa
~I~,~-W~J.T- ~.- I[] Express Mall [] Insured
B,t.tA4~_[~,QJ ~,1;> ~.. ~D/~ t'~lt~/._~ [;~aet~mReceiptf°raerchandise [] COD
.a pS Form ~11, December 1994
1(]~5~5-ge-B-~229 ~tic Return Receipt
IN RE: HILARIE HUME,
Parent and Guardian of
SHANE E. GRAMM,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 01-7133
:
PRAECIPE
To the Prothonotary:
Please file this Praecipe and attached advertisements from the Cumberland Law Journal
and the Carlisle Sentinel in the record of the above captioned matter.
3805 Market Street
Camp Hill, PA 17011
(717) 975-9446
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.
Roger M. Morgenthal, 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 courts 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
MARCH 8, 2002
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
SWORN TO AND SUBSCRIBED before me this
8 day of MARCH 2002
CO~ E. Sth'DER, Not~ Pubic /
CUMBERLAND LAW JOURNAL
NOTICE
In the Court of Common Pleas
Cumberland County. Pennsylvania
No. 01-7133 Civil Term
IN RE: HILARIE HUME.
Parent and Guardian of
SHANE E. GRAMM,
NOTICE
NOTICE IS HEREBY GIVEN that
on January 31, 2002, the Petition of
Hilarie Hume. parent and guardian
of Shane E. Gramm, was filed in
the Court of Common Pleas of Cum
berland County, Pennsylvania re-
questing the change of name of
Shane E, Gramm to Shane David
Hume.
The Court has fixed March 2 l.
2002. at 3 o'clock p.m. in court room
number (5) five of the Cumberland
Cotmty Courthouse located at One
Courthouse Square, Carlisle, Penn-
sylvania at the time and place for a
hearing on sa/d Petition, when and
where all interested parties may
appear to show cause, ff any. why
the request of Petitioner should not
be granted.
MICHAEL J, PYKOSH.
ESQUIRE
3805 Market Street
Camp Hill, PA 17011
(717) 975-9446
2
PROOF OF.PUBLICATION
State of Pennsylvania,
County of Cumberland.
Lori Saylor, Classified Advertising Manager
of THE SENTINEL,
of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of
general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th,
1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice
or publication attached hereto is exactly the same as was printed and published in the regular editions and
issues of THE SENTINEL on the following dates, viz
Copy of Notice of Publication
M~rr.h 4:2~3~2
Affiant further deposes that he is not interested in
the subject matter of the aforesaid notice or
advertisement, and that all allegations in the
foregoing statement as to time, place and character
of publication are true.
March 6, 2002
Sworn to and subscribed before me this 6th
day of March ,2002.
Notary Public
My commission expires:
NOTARIAL SEAL J
SHIRLEY O. DURNIN, Notary Public
Cadisle Bore., Cumberland County
M~ Commission Expires Audi. 9. 2003
IN RE: HILARIE HUME,
Parent and Guardian of
SHANE E. GRAMM,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
ANO NOW, this~:~/~'7~', ofda~ ~ 20(~pon Motion of Petitio it is
Ordered that a hearing on the Petition ~ra name change is fixed ~r the~
~ 20~t ~: ~0 o'clock~in cou~ room number ~ ofthe
Cumberland County Cou~house.
Petitioner is directed to give notice of the filing of the Petition and the date and time of the
hearing by publication in two newspapers of general circulation in this county, one of which may
be the official newspaper for publication of legal notices in this county. The Petitioner is further
directed to give notice of filing of the Petition and the date of the hearing to any non*participating
parent of the child, whose name will be affected by certified mail return receipt requested.
FREDERICK L. CORNMAN,
Plaintiff
VS.
DIANNA K. CORNMAN,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA
NO. 01-7233 CIVIL TERM
CIVIL ACTION-LAW
TO THE HONORABLE JUDGES OF SAID COURT:
PETITION FOR LEAVE TO AMEND DIVORCE COMPLAINT
/k
AND NOW, this g~] - day of April, 2002, comes the plaintiff, Frederick L. Comman,
by and through his attorney, Jason P. Kutulakis, Esquire, of ABOM & KUTULAKIS, L.L.P. and files
this Petition for Leave to Amend, pursuant to Pa.R.C.P. 1033 as follows:
1. Plaintiff is Frederick L. Comman who currently resides at 614 North Middle
Road, Newville, Cumberland County, Pennsylvania 17241.
2. Defendant is Dianna K. Comman, who currently resides at 302 Meadow Drive,
Shippensburg, Cumberland County, Pennsylvania.
3. Plaintiff filed the original Divorce Complaint in this case on December 28, 2001.
4. On April 17, 2002, a Support Hearing was held before Support Master, Michael
R. Rundle. At this hearing, Defendant testified to having adulterous relations with another man
during her marriage to the Plaintiff. The Defendant also admitted that these adulterous relations
have continued since the Defendant's separation from the Plaintiff.
5. At the Support Hearing on April 17, 2002, the Defendant served the Plaintiff with
a Counterclaim to the Plaintiffs Divorce Complaint. Within that Counterclaim, the Defendant
requests Child Support, Alimony Pendente Lite and Alimony.
6. The Plaintiff's original Divorce Complaint does not contain any averments as to
the adulterous relations of the Defendant due to this information not being discovered until after
the filing of that pleading.
WHEREFORE, the Plaintiff respectfully requests that this Petition for Leave to Amend
be granted in order to allow the original Divorce Complaint to reflect the evidence that has been
newly discovered.
Date:
Respectfully submitted,
Abom& KutulaMs, L.L.P.
JasoCP. Kutulakis, Esquire
Attotmey I.D. No. 80411
Suite 204
8 South Hanover Street
Carlisle, PA 17013
(717) 249-0900
Attorney for Plaintiff
FREDERICK L. CORNMAN,
Plaintiff
VS.
DIANNA K. CORNMAN,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA
NO. 01-7233 CIVIL TERM
CIVIL ACTION-LAW
CERTIFICATE OF SERVICE
AND NOW, this 'd-~ "day of April, 2002, I, Jason P. Kutulakis, Esquire, of Abom&
Kutulakis, L.L.P., hereby certify that I did serve a true and correct copy of the foregoing Petition
for Leave to Amend upon Jerry A. Weigle, Esquire, Attorney for Defendant, by mail at the
following:
WEIGLE & ASSOCIATES, P.C.
Jerry A. Weigle, Esquire
126 East King Street
Shippensburg, PA 17257
Respectfully submitted,
Abom& Kutulakis, L.L.P.
tulakis, Esquire
.No. 80411
Suite 204
8 South Hanover Street
Carlisle, PA 17013
(717) 249-0900
Attorney for Plaintiff