HomeMy WebLinkAbout11-2956IN THE COURT OF COMMON PLEAS OF
CUMBE RLAND COUNTY, PENNSYLVANIA
In Re:
NO 11- ?' Civil TEErm r:' ^
Margaret Jane Kanneg -+
Born: 8/10/10 CIVIL ACTION - LAW m -? ?,r--
NAME CHANGEa
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FOR NAME CHANGE
AND NOW, comes Kay la Grim, by and through her Attorney, Jane Adams`; ...
Esquire, and respectfully requ ests this Honorable Court to change the name of her child
to Margaret Jane Caufman.
1. Petitioner is Kayla rim (hereinafter referred to as "Petitioner") and she
currently lives at 514 3rd Streei , Carlisle, Cumberland County, Pennsylvania, 17013 .
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, 1990.
3. Petitioner is the natural mother of Margaret Jane Kanneg, born August 10,
2010. A copy of the child's bi h certificate is attached as Exhibit A.
4. When Petitioner completed the form to obtain her child's birth certificate,
Petitioner listed the name as Margaret Jane Kanneg. At that time, she believed that
Jeremy Kanneg was the natur I father of the child.
5. In November 2010, paternity test was completed, which determined that
Teddy Caufman was the naturol father of the child.
6. Vital statistics will not change the child's last name without a court order.
7. Petitioner is requesting that the child's name be changed to Margaret Jane
Caufman.
8. Teddy Caufman, Natural Father, joins in this petition, and agrees with the
request to change the child's n me. He lives with Petitioner.
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9. Since the child is on y seven months old, there are no financial obligations
that could be avoided by the ange of name.
10. Petitioner believes it would be in the best interest of the child to change her
last name to that of her natural father.
WHEREFORE, Petitio er requests that this Honorable Court Order that her
child's name be changed to: argaret Jane Caufman.
Date:3
Respectfully submitted,
ne Adams, Esquire
.D. No. 79465
5
17 West South St. St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PETITIONER
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VERIFICATION
I verify that the state
understand that false stateme
Pa.C.S. §4904, relating to un
made in this petition are true and correct. I
herein are made subject to the penalties of 18
falsification to authorities.
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Date: Kayla 6, Petitioner
Date: ' ? C
Teddy C ufman, N ural Father
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
In Re:
NO //- ,Ze Civil Term
Margaret Jane Kanneg
Born: 8/10/10 CIVIL ACTION - LAW
NAME CHANGE
ORDER
AND NOW, this /6 M day of 2011, upon
consideration of the Petition for Name Change, filed under the above-docketed number,
a hearing is set for the day of 6LvA 2011, in
Courtroom No. _ at q 1 / S a.m.1". , in the Cumberland County
Courthouse, Carlisle, Pennsylvania.
BY THE COURT:
cc: Jane Adams, Esquire
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
In Re:
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NO Civil
Margaret Jane Kanneg rn n
Born: 8/10/10 CIVIL ACTION - LAW =rn
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NAME CHANGE
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MOTION TO WAIVE ADVERTISING '
AND NOW, comes Kayla Grimm, by and through her Attorney, Jane Adam s
Esquire, and respectfully represents as follows: ,
1. Petitioner is Kayla Grimm (hereinafter referred to as "Petitioner") and she
currently lives at 514 3' Street, Carlisle, Cumberland County, Pennsylvania, 17013.
2. Petitioner's date of birth is April 26, 1990. She is twenty-years old.
3. Petitioner is the natural mother of Margaret Jane Kanneg, born August 10,
2010. A copy of the child's birth certificate is attached as Exhibit A. She also has a
two and a half year old son, Jeremi A. Kanneg, Jr., born 8/2/08.
4. When Petitioner completed the form to obtain her child's birth certificate,
Petitioner listed the name as Margaret Jane Kanneg. At that time, she believed that
Jeremi A. Kanneg, Sr. was the natural father of the child.
5. In November 2010, a paternity test was completed, which determined that
Teddy Caufman was the natural father of the child.
6. A petition for a name change was filed on March 10, 2011 under the above-
captioned docket number. A hearing is scheduled for April 14th, 2011 at 9:15 a.m.
7. Advertising notice of the hearing in the newspaper is directed by the statute
regarding name changes.
8. Natural Father is in agreement with the name change.
9. Petitioner works at Walmart as a cashier. Her income is extremely modest
and she has two small children.
10. Natural Father is a bakery production operator.
11. The child will be only eight months old at the time of the name change
hearing, and therefore, she does not have any tax debt or creditors which might need to
be notified of the name change by publication.
12. The only other person who may be interested in this matter is Jeremi
Kanneg, Sr., who is listed as the father on the child's birth certificate. He is represented
by Family Law Clinic. Petitioner's attorney will send notice of the petition and hearing
date to the Family Law Clinic via certified mail.
13. Petitioner knows of no other third parties which may be interested in, or
affected by the name change.
14. Petitioner is requesting that the requirement of advertising be waived by this
Honorable Court for the reasons listed above.
15. This matter was previously assigned to Judge Hess.
16. Natural Father, Teddy Caufman, is in agreement with the relief requested.
WHEREFORE, Petitioner requests that this Honorable Court Order that the
requirement of advertising be waived.
Respectfully submitted,
Date: 3
Ja Adams, Esquire
No. 79465
7211lisle, West South St.
Pa. 17013
(717) 245-8508
ATTORNEY FOR PETITIONER
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VERIFICATION
I verify that the statements made in this Motion 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.
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Date: f l i t Kayla imm, Pet i ner
Date: Teddy Cau an, Natural Father
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
In Re:
NO ?k--%ez 1 SS
Margaret Jane Kanneg
Born: 8/10/10 CIVIL ACTION - LAW
NAME CHANGE
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Civil Term
ORDER
AND NOW, this day of +. */ 2011, upon
consideration of the attached Motion, Petitioner is excused from advertising notice of
the hearing scheduled in the above-captioned matter.
BY THE COURT:
cc: YJane Adams Esquire
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In Re: : IN THE COURT OF COMMON PLEAS OF Cl -'
Margaret Jane Kanneg : CUMBERLAND COUNTY, PENNSYLVA s,. =-n
Born: 08/10/2010 -um
CIVIL ACTION - LAW ND -' off'
NAME CHANGE
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NO. 11-2956 CIVIL TERM
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MOTION FOR CONTINUANCE
Defendant, Jeremi Andrew Kanneg, Sr., by and through his attorneys, the Family Law
Clinic, represents the following:
1. On March 10, 2011, Plaintiff filed a Petition for Name Change, Docket No. 11-2956.
The Order of Court, dated March 16, 2011, scheduled a hearing for Thursday, April 14, 2011, at
9:15 A.M. before the Honorable Kevin A. Hess.
2. On March 31, 2011, Plaintiff filed a Motion to Waive Advertising, in the above-
captioned Name Change Docket. The Order of Court, dated April 1, 2011, excused Plaintiff
from advertising notice of the hearing.
3. On March 31, 2011, Plaintiff filed a Complaint to Establish Paternity, Docket No. 1I-
3381. The Order of Court, dated April 1, 2011, scheduled a hearing for Thursday, April 14,
2011, at 9:15 A.M. before the Honorable Kevin A. Hess.
4. On April 5, 2011, Plaintiff served Defendant's attorneys with these documents via
certified mail. Prior to April 5, 2011, Defendant did not receive any of these documents from
Plaintiff.
5. Pursuant to C.C.R.P. 5, upon the filing of petition for name change, notice must be
given to any non-petitioning parent of a child whose name may be affected by the proceedings at
least ten days prior to the hearing. Defendant signed the acknowledgement of paternity for the
child whose name may be affected by the above-captioned name change proceeding. Plaintiff's
counsel first accomplished service of these documents to Defendant's counsel nine days before
the hearing date.
6. Defendant's counsel is unable to attend the hearing scheduled for April 14, 2011.
7. Pursuant to C.C.R.P. 208.2(d), Defendant's attorneys sought concurrence of opposing
counsel, Jane Adams, for this Motion for Continuance. On April 11, 2011, opposing counsel
stated that she would not oppose this request.
7. Pursuant to Pa.R.C.P. 216(A)(1) and for the aforementioned reasons, Defendant
requests a continuance of the April 14, 2011 hearing.
Date: April 11, 2011
Respectfully Submitted,
zit4 Ll
Ashley Nichols
Certified Legal Intern
MEG RIESMEYER
ANNE MACDONALD-FOX
THOMAS M. PLACE
ROBERT E. RAINS
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717)243-2968
Fax: (717) 243-3639
In Re: : IN THE COURT OF COMMON PLEAS OF
Margaret Jane Kanneg : CUMBERLAND COUNTY, PENNSYLVANIA
Born: 08/10/2010
CIVIL ACTION - LAW
NAME CHANGE
:NO. 11-2956 CIVIL TERM -a
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ORDER OF COURT r c s w
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AND NOW, this 49
da of
Y , 2011, upon consideration of theme; c?
attached Motion for Continuance, the motion is granted. A hearing on this matter is scheduled
for the 640-?day of 2011 ?% ' ?? •?? '
BY THE COURT:
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Date
CC: Jane Adams, for Plaintiff
Family Law Clinic, for Defendant
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FILED-OFFICE
OF THE PROTHONOTAR
2011 MAY 26 AM 9= 40
CUMBERLAND COUNTY
IN THE COURTp???OI?AMNAPLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
In Re:
Margaret Jane Kanneg
Born: 8/10/10
AND NOW, this' Z`• day of ^ Ay
NO. 11 - 2956 Civil Term
CIVIL ACTION - LAW
NAME CHANGE
ORDER
, 2011, after hearing
and upon consideration of the Petition for Name Change, filed under the above-
docketed number, Margaret Jane Kanneg shall hereafter known as:
Margaret Jane Caufman.
cc: /Jane Adams, Esquire, for mother
P," Family Law Clinic, for father
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BY THE COURT: