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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