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HomeMy WebLinkAbout01-2623 AND NOW comes D~ ~ B~cI~' by and through her attorney, Thomas D. Gould, and requests this Honorable Court, pursuant to 54 P.S. Section 701, to issue a Decree changing the name of her biological daughter, ~&C~I~ JO~ 1~' to ~%C~1~ J~ B~C~, based on the following: 1. Debra Jean Becker, hereinafter referred to as Mother, is an adult citizen who resides at an undisclosed location in Cur~berland county and receives mail at her parentS, Jack & Joan Becket, 329 Somerset Drive, shiremanstown, Cumberland County, Pennsylvania 17011. 2. Mother is the biological mother of Jaclyn Joan Kennerly, born July 13, 1998, hereinafter referred to as Child. 3. Sean Christopher GrosS, hereinafter referred to as Father, is the biological father of Child. 4. Father is not listed on the Child's birth certificate, but has acknowledged paternity through DRO. 5. Father and Mother were never married. 6. Mother had been married to Mark Andrew Kennerly and had taken his surname. 7. Mother divorced Mr. Kennerly on July 9, 1996. 8. Following the birth of the Child, pursuant to 54 p.C.S. Section 704 Mother resumed her maiden name of Becket. 9. Mother has Legal Custody of the child. 10. Father has no contact with the Child. ll. The child doeS not carry Father'S surname. 12. The best interests of child will be served by changing her last name to Mother'S because: a. Child lives in Mother'S household. b. All the members of Mother'S household will have the last name of Becket. c. Mother'S name is well respected in the community. 13. Mother fearS for her safety and therefore has not contacted Father regarding her desire to change the Child'S surname. 14. Child has no judgments or decrees of record or any other matter pending of like character against her in this or any other jurisdiction. WHEREFORE, Debra Jean Beck respectfully requests this Honorable Court to set this matter for hearing and enter an Order directing Petitioner to give Legal Notice as required by statute to Father and all other interested parties of the filing of this action and the date and time set for Hearing, which shall not be less than one month or more than three months after the filing of this Petition. After the Hearing it is respectfully requested that this Honorable Court issue a Decree changing the name of Jaclyn Joan Kennerly to Jaclyn Joan Becker. Respectfully submitted, Thomas D. Gould, Esqui=e Attorney For Petitioner I.D. # 36508 2 East Main Street shiremanstOwn, PA 17011 (717) 731-1461 THOMAS D. GOULD MA,. s~.~E~ · SH.REMANSTOW". P^ ''O'' MAY 0 8 20~ ~C',,. VERIF] CATION I verify that the statements made in this Petiticm q'¢, Change Name are true and correct. I Llhd~t'st,~lad thai: ~a]$e statements made herein a~e subject to the penalties ,:)~ 18 P.S. SectLor, 4904, Lelating to unsworn falsification to authorities. E~,~_ Jean Bec'kef ~.- IN RE: JACLYN : IN THE COURT OF COMMON PLEAS OF JOAN KENNERLY : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 01-2623 CIVIL TERM ORDER OF COURT AND NOW, this 2nd day of May, 2001, upon consideration of the attached Petition To Change Name, a hearing is scheduled for Thursday, June 21, 2001, 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 County 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] [lVlain Volume]), ,an.d 54 Pa' O'S' §§701 et seq' , · ,- ¢.,s~.O> ~[~"~ BY THE COURT. ~)~sl'~ Oler, J~ J. ' Thomas D. Gould, Esq. 2 East Main Street Street Shiremanstown, PA 17011 Attorney for petitioner OB- 0 ~t. :re VINVA'IXSNN=Id )J.N,qOo 2t) ti- ?ROOF OF PUBLICATION State of Pennsylvania. County of Cumberland. ana er of THE SEHTINEL, 'fiord Classified Ad M g . - t' THE sENTINEL, s ne~.spaper of Shem/Ch _ ~ ~ ........ M~ and says tha ........ ~*h ~ aid being du,y s waS estebhshee . County and State aforas , un and State aforasa,d, . _ tinted not,ce of the . .L_ ,,_..u,~h of Carlisle, Co ty ...... :a roun~, and that the p oeneral circulation in me ,~,,_-_...~_...,~. ,... n ularly iasue~ m ~,- .... · ;881, since which date THE S~HH--=~- ""' bee rog was printed and published In the regular editions and or publication attached hereto Is sxaatly the same as issues of THE SENTINEL on the following dates, viz Copy of Notice of Publication June 6, 2001 kEGAL NO1111~E interested in 'l~em will be a heroin ~,~.~,~,~.~=, Affiant further deposes that he is not ~1,~M1 M ~:eo p~n. ln ~o~ No. ~, the subject mat~er of the a~oreseid notice or ¢~(M~,,d~ ement, and that ail sllegatJons in the ~o~.,~,M,. adverti.s ~,./~d.~,k~ ~oregomg statement as to time, place and character nem$ ot ,h doln Jea~ Beaker. of publication are true. ~une~6, 2001 6th Sworn to and subscribed before me this day of June .20~.1. Nu[a~f Pub..c My commission expires: NOTARIAL SEAL ' .=u~?.k =..~m~ Aua 9, 2003 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA :: ss. COUNTY OF CUMBERLAND ]oumai, of the County Roger M. Morgenthal, Esquire, Editor of the Cumberland Law · law. deposes and says that the Cumberland __:a h ine dui sworn, accord, ing..to k _r ~o.lisle in the CountY and State and State afore~,~,.-e ..-,._~ _,,~,lished in tl~e ~omugn o' '~'" Law Journal, a legal pcnOotCm aforesaid, was established lanuary 2, 1952, and designated by the local courts as the official legal periodical for the publication of ail 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 printed in the regular editions and issues of the said Cumberland Law as was Journal on the following dates, -- · ' o veri this statement by the .Cumberl .and ant further deposes that he IS .aut. hon,_z~...d..I' ,nd ~at he is not interested re. the subject Affi · · ~:~1 of oeneral Cll-CUlZttto~,, --- foregoing Law Journal, a legal penou,,.,~ ~, matter of the aforesaid notice or advertisement, and that all allegations in the statements as to time, place and character of publication are sWORN TO AND SUBSCRIBED before me this cuMBERLAND tAW jOURNAL ~ NOTICE IS H--~BY G~ t~at- on May 2, 2~1, a ~on ~ ~ d~- ~ j~ ~ly w~ ~ed m ~e ~u~ of Co--On ~eas of C~' I~d CounW, ~l~a, No. 01- ..... ~e~. ~questi~ ~ or- 2623 ~w~ - r to change ~e n~e of Jacl~ de -~1~ J~ ~ker. By o~er ~ the Ho~mble J. Wes- 1~ O1~, Jr., ~e Co~ ~ ~ June 21, 2~1, at 2:~ P.M. ~ co~°m of the Cumberland counW No. 1 ~lva- Cou~OU~ In C~BSle, nia as the time ~d place for the he~ on the ~on, when ~d wh~ ~ ~te~sted ~es ~Y ap- ~ ~d show caul, tf ~Y. why ~e ~uest shoed not ~ ~ted. THO~ D. GOULD. 2 ~st ~n S~t Shi~m~st~, PA 17011 {717} 731-1~1 June 8 ~FFIDAVIT OF sERVICE I, ThomaS D. Gould, attorney for Petitioner, in the above captioned action for name change, hereby certify that a copy of the court order setting this matter for hearing waS served upon the father, Sean C. GroSS, in person by constable Russell S. Moody, Jr., at his place of employment on June 1, 2001 as evidenced by the attached return of service. ThomaS D-. Gould ID # 36508 Attorney At Law 2 East Main Street shiremanstown, PA 17011 (717) 731-1461 The undersigned certifies that he performed a diligent search of the records found in the Cumberland County Prothonotary's office and Recorder of Deeds and does hereby represent to the court that there are no judgments of decrees of like character of record against Jaclyn Joan Kennerly. Thomas D. Gould, Esquire Attorney For Petitioner I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 The undersigned on behalf of the Cumberland County Prothonotary confirms that there are no judgments or decrees of like character of record against Jaclyn Joan Kennerly. ~/umb~e~r~a~d~oun~n~Pr ot honot a r y, BY · Print Name Date