HomeMy WebLinkAbout11-1560IN THE COURT OF COMMON PLEAS OF a
CUMBERLAND COUNTY, PENNSYLVANIA C-) ?°. -4
IN RE
MADDISON CORRIN
:
GLASS No. JZL for 2011
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NAME CHANGE 'V
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PETITION FOR CHANGE OF NAME
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AND NOW
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ruary, 2011, come Petitioners, Alan J. Ken dall and Julia ne
M. Kendall, on behalf of their minor child, Maddison Corrin Glass, and file the following Petition,
and in support thereof, avers the following:
1. Petitioners, Alan J. Kendall and Juliane M. Kendall, husband and wife, are adult
individuals residing at 42 Church Road, Newville, Cumberland County, Pennsylvania. Petitioners
reside with the minor child, Maddison Corrin Glass (hereinafter "Maddison").
2. Petitioners are the natural parents of Maddison, whose date of birth is August 19,
2004.
3. Maddison was born during the marriage of Juliane Marie Kendall and Christopher
Shawn Glass.
4. At the time of Maddison's birth, Juliane Marie Kendall was married to Christopher
Shawn Glass but separated. Maddison was given the surname of Glass when she was born.
5. In addition to Maddison's present address, since birth, she has resided at the following
addresses:
a. From birth to March 4, 2006 at 4 West Main Street, Walnut Bottom,
Pennsylvania; and
b. From March 4, 2006 to present at 42 Church Road, Newville, Pennsylvania.
6. Maddison was born out of wedlock and was born as Maddison Corrin Glass.
7. The Petitioners and Maddison have resided in Cumberland County, Pennsylvania,
since before Maddison's birth.
8. Petitioners desire and feel it would be in the best interest of Maddison that her
surname be changed to conform to her parents' surname of Kendall.
9. Petitioners do not wish to change Maddison's name for any illegal purpose, to avoid
payment of taxes or other debts, or to avoid any obligation.
10. Petitioners' counsel, Sean M. Shultz, Esquire, has searched the index in the
Prothonotary's Office in the Court of Common Pleas of Cumberland County and there are no
judgments or decrees of like character of record against Maddison Corrin Glass.
WHEREFORE, the Petitioners request this Honorable Court enter a decree changing the
name of Maddison Corrin Glass to Maddison Corrin Kendall.
Respectfully submitted,
LAW OFFICE OF SEAN M. SHJJLTZ, P.C.
Yean M. Shultz, Esquire
Attorney ID No. 90946
4 Irvine Row
Carlisle, Pennsylvania 17013
(717) 701-8412
Attorney for Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN RIB: MADDISON CORRIN GLASS No. for 2010
NAME CHANGE
VERIFICATION
We VERIFY that the statements set forth in the attached Petition are true and correct to the
hest of our knowledge, information and belief. We understand that false statements herein arc rriade
subject to the penalties oI'18 Pa. C.S. 5 4904 relati
Date: Z11
Alan J
r.. r
M o unsworg fit(sific?rflon to authorities.
dune M. Kendall -
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: MADDISON CORRIN GLASS No. 1 S&0for 2011 rte -+o o ,...
Z °
NAME CHANGE
PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS
AND NOW this ? day of February, 2011, come Petitioners, Alan J. Kendall and Juliane
M. Kendall, by their attorney, Sean M. Shultz, Esquire, and represent as follows:
1. Petitioners, Alan J. Kendall and Juliane M. Kendall, husband and wife, are adult
individuals sui juri, who reside at 42 Church Road, Newville, Cumberland County, Pennsylvania.
2. Petitioners are filing a Petition for Change of Name of the minor child, Maddison
Corrin Glass, and due to financial circumstances are unable to pay any of the costs or expenses of
same. See Petitioners' Financial Affidavit attached hereto as Exhibit "A".
3. Petitioners have qualified for pro bono legal services through the Cumberland County
Bar Association.
WHEREFORE Petitioners request that an Order be entered granting leave to proceed in this
matter in forma pauperis without the payment of costs.
Respectfully submitted,
LAW OFFICE OF SEAN M. SHULTZ, P.C.
Sean M. Shultz, Esquire
Attorney ID No. 90946
4 Irvine Row
Carlisle, Pennsylvania 17013
(717) 701-8412
Attorney for Petitioners
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: MADDISON CORRIN GLASS No. for 2011
NAME: CHANGE
AFFIDAVIT
1. We are the Petitioners in the above matter and because of our financial condition are
unable to pay the fees and costs of the above captioned action or proceeding.
2. We are unable to obtain funds from anyone, including our family and associates, to
pay the costs of litigation.
;. We represent that the information below relating to our ability to pay the fees and
costs is true and correct:
(a) Names: Alan J. Kendall and Juliane M. Kendall
Address: 42 Church Road, Newville, PA 17241
Social Security Numbers: 209-58-5648 and 211-62-9761
(b) Employment for Alan J. Kendall: n/a
If you are presently employed, state
Employer:
Address:
Salary or wages per month:
Type of work:
If you are presently unemployed, state
Date of last employment: December 2005
Salary or wages per month: minimum wage
Type of work:
(c) Other income within the past twelve months
Business or profession: n/a
Other self-employment: Alan recycles and does odd jobs on cars
Interest: n/a
Dividends: n/a
Pension and annuities: n/a
Social security benefits: Maddison receives $674.00/month SSI
Support payments: $1048.(X)/month
Disability payments: n/a
Unemployment compensatio n and supplemental
Benefits: n/a
Workman's Compensation:
Welfare Food stamps and medical assistance
Other: n/a
(d) Other contributions to household support
Wife's Name: Juliane M. Kendall
If your wife is employed, stat e n/a
Employer:
Salary or wages per month:
Type of work:
Contributions from children: n/a
Contributions from parents: n/a
Other contributions: n/a
(e) Property Owned
Cash:
Checking account:
Savings account:
Certificates of deposit:
Real estate (including home):
Motor Vehicle: Make
$50.(X)
$200.0( )
n/a
n/a
Present value $154,000.00
Amount Owed: $159,0(x).00
1997 Ford Expedition
1990 Ford F350
Cost , Amount Owed: $0.00
Stocks; bonds: n/a
Other: n/a
(f) Debt and obligations
Mortgage: $1323.10/month
Rent: n/a
Loans: n/a
Electric $300.00/month
Oil/Gas/Heat $400.(Ornonth
Food food stamps
Child Support n/a
Transportation $ 100.(X)/'week gas
Insurance $140.(x) twice a year
Telephone $20.00/month
Cable $30.00/month
Clothing $5(x).(X)/year
Child Care n/a
Medical Expenses n/a
Credit Card Payments $20.00/month
Other: n/ a
(g) Persons dependent upon you for support
Wife: Juliane M. Kendall
r
Children, if any:
Names: Courtnie Glass
Alyssa Glass
Makayla Glass
Maddison Glass
Alexzander Kendall
Other persons: n/a
Name:
Relationship:
4. We understand that we have a continuing obligation to inform the court of
improvement in our financial circumstances which would permit us to pay the costs incurred herein.
5. We verify that the statements made in this affidavit are true and correct. We
understand that false statements herein are made subject to theknaytiXof 18 Pa. C.S. §4904,
relating to unsworn falsification to authorities.
Date: 1
Alan J. ?I
(2, 1 A/Z
liane M. Kendall
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ss.
On this, the 2- day of January, 2011, before me, the undersigned officer, personally
appeared. Alan J. Kendall and Juliane M. Kendall, his wife, known to me or satisfactorily proven to
be the persons whose names are subscribed to the within instrument, and acknowledged that they
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
? (SEAL)
QOMMONWE&TH O PENNSYLVANIA
Notarial Seal
Jennifer Gum, Notary Public
Lower M fflin TWp., Cumberland County
my commission Expires Oct. 14, 2013
Member, Pennsylvania Association of Notaries
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: MADDISON CORRIN GLASS No. 15(tD for 2010 -rcn cc; -n
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NAME CHANGE
5:F
ORDER OF COURT E ,
AND NOW, this I I day of February, 2011, upon consideration of Petitioners' Petition
for Change of Name, it is ORDERED that a hearing on Petitioners' request be held on
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I Y M,ti a -?, at 11 yU , in Courtroom No. J` , Cumberland County Courthouse,
Carlisle, Pennsylvania.
IT IS FURTHER ORDERED that the notice of the filing of said Petition and the aforesaid
date, time and place of the hearing be published once in the Cumberland County Law Journal and a
newspaper of general circulation in the County at least ten (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, Section 6, and 54 Pa. C.S. Section 701 et seq. (1995 Supp.).
BY THE COURT:
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nti1. Shultz ?'gp POLL,
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA C :
C o 7.?
IN RE: MADDISON CORRIN GLASS No. ) for 2011 Z ? w
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NAME CHANGE
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ORDER J?
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AND
NOW, this day of February, 2011 , upon consideration of the within Petition
and Exhibit, the Court being satisfied of the truth of the averments therein, and the Court further
being satisfied that Petitioners are unable to pay any of the costs of these proceedings, it is therefore
Ordered and Decreed that the Petitioners may, pursuant to Pa. R.C.P. 1920.62, proceed with a name
change action in forma pauperis without payment of costs. Petitioners shall promptly notify the
Court of any material change in income or financial condition during the pendency of this action.
S
?S? M. gh u(tz &PY R)Op led
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: MADDISON CORRIN GLASS
No. 1560 for 2011
NAME CHANGE
PRAECIPE
To Prothonotary:
C?
Pursuant to the Order of Court dated March 29, 2011, attached please find copies of the
Proofs of Publication of the publication of the Notice of Hearing in the above-captioned matter. The
Notice was published in the Cumberland Law Journal on June 3, 2011, and in The Valley Times-Star
on June 1, 2011.
Respectfully submitted,
LAW OFFICE OF SEAN M. SHULTZ, P.C.
Date: June 9, 2011 `
Sean M. Shultz, Esquire
Attorney ID No. 90946
4 Irvine Row
Carlisle, Pennsylvania 17013
(717) 701-8412
Attorney for Petitioners
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH 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 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
June 3, 2011
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.
Marie Coyne, Edi
SWORN TO AND SUBSCRIBED before me this
3 day of June 2011
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
CUMBERLAND LAW JOURNAL
NOTICE
NOTICE IS HEREBY GIVEN that
on February 9, 2011, the Petition
of Alan J. Kendall and Juliane M.
Kendall was filed in the Court of Com-
mon Pleas of Cumberland County,
Pennsylvania, praying for a decree to
change their daughter's name from
Maddison Corrin Glass to Maddison
Corrin Kendall.
The Court has affixed June 21,
2011 at 8:45 a.m. in Courtroom No.
5 of the Cumberland County Court-
house as the time and place for the
hearing of said Petition, when and
where all persons interested may
appear and show cause, if any they
have, why the prayer of said Petition
should not be granted.
SEAN M. SCHULTZ, ESQUIRE
LAW OFFICE OF
SEAN M. SCHULTZ, P.C.
Attorneys for Petitioners
4 Irvine Row
Carlisle, PA 17013
(717) 701-8412
June 3
Proof of Publication of Notice in
THE VALLEY TIMES-STAR
COUNTY OF CUMBERLAND
SEAN M. SHULTZ/LEGAL NOTICE
COMMONWEALTH OF PENNSYLVANIA
John Zimmerman, being duly sworn according to law, deposes and says that he is the General Manager
of "The Valley Times-Star" which is a weekly newspaper of general circulation published in
Shippensburg Township, Cumberland County, Pennsylvania, by Latrobe Printing and Publishing
Company, a corporation duly organized and existing under the laws of the Commonwealth of
Pennsylvania having its principal place of business at 22 East King Street (P.O. Box 100),
Shippensburg, Pennsylvania; that he is authorized to and does make this affidavit on its behalf;
that the printed notice, advertisement of publication attached hereto is the same as was printed
in the regular editions and issues of "The Valley Times-Star" on the following date(s):
June 1. 2011
Affiant further deposes that neither he nor "The
Valley Times-Star" and The Latrobe Printing and
Publishing Company have any interest in the subject
matters of the aforesaid notice or advertisement, and
that the facts set forth in the foregoing affidavit is
true and correct.
`-Sworn and cri d before me this
-_Day of ,2011
COMMONVVEALTH OF PENNSYLVANIA
Notarial Seal
Lisa Dawn Shankle, Notary Public
Bedford Boro, Bedford County
My Commission Expires Feb. 21, 2012
Member, Pennsylvania Association of Notaries
7?
, too-
Notary Public
To: "The Valley Times-Star"
Shippensburg, PA 17257
For publishing the notice attached hereto:
Copy of Notice of Publication
;PV8LIC NOTICE
NOTICE IS HIE ICY GIVEN that on the 9th day of
February, 2011, the Petition of Alan J. Kendall and
Juliane M. Kendall was filed in the Court of Common
Pleas of Cumberland County, Pennsylvania, praying
for a decree to change their daughter's name from
Maddisori Corrin Gla's's to Maddison Corrin Kendall.
The Court has affixed the 21st day of June, 2011, at
8:45 a.m. in Courtroom No. 5 of the Cumberland'
County Courthouse as the time and place for the
hearing o ,said Petition, when and where all persons
nterestg"ay appear and show cause, if add" `iKe"y
have, why `IK*, pi"ayer 6f said Petition should not be
granted.
Sean M. Shultz, Esquire
LAWtOFfICE OF SEAN M. SHULTZ, P. C.
4 Irvine Row
Carlisle, Pennsylvania 17013
(717) 701-8412
Attorney for Petitionq?ys
ADV VTS JUNE 1, 2011
On the stated date(s) ..............$ 36.00
Affidavit .......................... $ 5.00
Total $ 41.00
i
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.?O//
IN RE: MADDISON CORRIN GLASS No. for 243
NAME CHANGE
ORDER OF COURT
AND NOW, this f r
day of y\#- , 2011, upon consideration of Petitioner's
Petition for Name Change, and following a hearing, IT IS HEREBY ORDERED that Maddison
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Corrin Glass's name be changed from Maddison Corrin Glass to Maddison Corrin Ke 11N°
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BY THE COURT:
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