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HomeMy WebLinkAbout01-3289 § IN THE COURT OF COMMON PLEAS § CUMBERLAND COUNTY, PENNSYLVANIA IN RE § GEORGE STANLEY BROWN § NO. ol- 3 ~ g q $ 2001 § CIVIL ACTION § CHANGE OF NAME PETITION TO CHANGE NAMF~ AND NOW, comes George Stanley Brown, by and through his attorney Roger R. Laguna, Jr., and requests this Honorable Court, pursuant to 54 P.S. Section 701, to issue a Decree changing his name from George Stanley Brown to Jorge Luis Quinnonez, based on the following: 1. George Stanley Brown, hereinafter referred to as "Petitioner", is an adult citizen who resides at 517 Highland Court, Cumberland County, Carlisle, Pennsylvania 17013. 2. This Petition was initially misfiled in the Dauphin County Court of Common Pleas at Docket No. 3587 S 2000. A hearing on said Petition was held on May 23, 2001 before The Honorable Judge John F. Cherry and, because Petitioner's current residence is in Cumberland County, the Petition was dismissed by the Court for lack of venue. 3. Prior to the hearing held at the Dauphin County Court of Common Pleas, Petitioner's fingerprint cards were submitted to the Pennsylvania State Police and, thereafter, a notice and criminal history record were submitted to the Court (originals attached hereto as "Exhibit A"). 4. Petitioner was born in Dauphin County, Pennsylvania on June 30, 1967. 5. The Petitioner's birth certificate indicates that his father was Stanley Joseph Brown (deceased: 1969). However, Petitioner avers that Stanley Joseph Brown, was not really his biological father. 6. In support of this averment, Petitioner states that his biological mother, Yolanda Quinnones, recently advised her son that he was conceived when she was forcibly raped at the age of(14) fourteen years old, by a perpetrator who had been staying with her family. The alleged perpetrator absconded after the incident. He was known only as "Miguel Perez"; no date of birth, social security number, address, etc., was ever learned. 7. After conception, but prior to Petitioner's birth, Stanley Joseph Brown (deceased: 1969), graciously married Petitioner's mother with the intention of sparing the mother and child the stigma which they believed would be associated with these events. As such, at the time of Petitioner's birth, the husband, Mr. Brown, was presumed to be the Petitioner's biological father and was listed as such on Petitioner's birth certificate. Unfortunately, Mr. Brown died approximately 2 years after Petitioner's birth. 8. Having recently learned of this saga. Petitioner now wishes to assume his biological mother's maiden name in order to re-establish that connection with his true bioodline. 9. The whereabouts and identity of Petitioner's biological father remain unknown. WHEREFORE, Petitioner respectfully requests this Honorable Court to set this matter for hearing and enter an Order directing him to give notice of the filing of this action and the date and time set for the hearing. After the hearing, it is respectfully requested that this Honorable Court issue a Decree changing the name of George Stanley Brown to Jorge Luis Quinnonez. i Respectful ired, ~ Roger R. Laguna, Jr., Esquire Supreme Court I.D. No. 75900 Attorney foM~titioner LAGUNA REYES MALONEY LLP i 5 North Front Street, Suite 203 Steelton, PA 17113 (717) 939-4429 PENNSYLVANIA STATE POLICE CENTRAL REPOSITORY 1800 ELMERTON AVENUE HARRISBURG, PA 17110 717-783-3762 PROTHONOTARY DATE: February 5, 2001 DAUPHIN COUNTY COURT HOUSE FRONT AND MARKET STREETS RE: $1D: 185-00-17-5 HARRISBURG PA 17101 NAME: Brown, George Stanley SOC: 196-48-1325 ,. COURT DOCKET ~ 3587-S-00 ' Dear Sir: In accordance with the Name Change ACt of 1998, the flngerpmint cards of the above named individual, who has applied for a name change, has been searched in the files of the Pennsylvania State Police, Criminal Records and Ide~tifloation Division Cenb-al Repository, and; ( ) This person .is not subject to 18 Pa.C.S. Chapter 91, and the fingerprints ha~e been dastmyed. ( )' This person is subject to 18 Pa.C.S. Chapter 91, and the name change has been noted on the person's criminal history record, information. (X) A criminal record was revealed containing felony convictions. IN ACCORDANCE WITH THE NAME CHANGE ACT, lille COURT BHALL NOTIFY THE PENNSYLVANIA.STATE POLICE WHEN A NAME CHANGE FOR A PERSON CONVICTED OF A FELONY HAS BEEN ORDERED. The Pennsylvania State Police, upon receipt of this notice, shall include the change of name information in the Central Repository as provided for in 18 Pa.C.S., Chaptar 91 (rela0ng to criminal history record information). Reference No. 082053 ( ) This person has been convicted of felony violation(s) for which the court may not order a change of name. ( ) A criminal record was revealed that might prohibit a name change. Because the subsection(s) of the affected conviction(s) has not been provided to us, we are unable to determine whether a hame change can or cannot be marie. Please provide the subsection(s) of the following crime(s): if available. You are also advised that the above response is based on comparison of fingerprints and associated requaster-fumished information against a name inriex and fingerprints contained in the files of the Pennsylvania State Police Central Repository - only - and does not preclude Ih~ existence of other' criminal records which may be contained in the repositories of other local, state, or federal criminal justice agencies. If we may be of further assistance to you concerning this matter, please contact us at the above address or telephone number. Sincerely, Director, Criminal Records and Identification Division EXHIBIT SP4-!37B PENNSYLVANIA STATE POLICE CENTRAL REPOSITORY 1800 ELMERTON AVENUE HARRISBURG, PENNSYLVANIA 17110 ~ .. (717) 787-9092 COMPILED: 02/09/2001 PAGE: LAST OF 1 USE OF THE FOLLOWING CRIMINAL HISTORY RECORD FOR *** SID/185-00-17-5 *** REGULATED BY ACT 47, AS AMENDED. DOB: 06/30/1967 SEX: M RAC: B SOC: 196-48-1325 FBI: NAME: BROWN,GEORGE STANLEY OTN: C151303-5 ARRESTED: 03/10/1989 PA0220900 SWATARA TWP PD OCA: 89075 DISPOSITION DATE: 08/10/1989 COMMON PLEAS DOCKET: 84489 02/08/1989 CC0903 CRIMINAL CONSPIRACY - F FOUND GUILTY STATE CORRECTION 01YR - 02 YRS COSTS 02/08/1989 CS13A30 VIO CS/DRUG/DEV & COSMETIC ACT FOUND GUILTY - F STATE CORRECTION 01YR - 02 YRS COSTS +++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++ F = FELONY, M = MISDEMEANOR, S = SUMMARY AND THE NUMERIC = THE DEGREE. ARREST(S) SUPPORTED BY FINGERPRINT CARD(S) ON FILE. RESPONSE BASED ON COMPARISON OF REQUESTER FURNISHED INFORMATION AND/OR FINGERPRINTS AGAINST A N~/~E INDEX AND/OR FINGERPRINTS CONTAINED IN THE FILES OF THE PENNSYLVANIA STATE POLICE CENTRAL REPOSITORY ONLY, AND DOES NOT PRECLUDE THE EXISTENCE OF OTHER CRIMINAL RECORDS WHICH MAY BE CONTAINED IN THE REPOSITORIES OF OTHER LOCAL, STATE OR FEDERAL CRIMINAL JUSTICE AGENCIES. VERIFICATION I verify that the statements made in the foregoing pleading are tr~e and correct to the best of my knowledge, information and belier: I understand that false statements made herein may subject me to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. § IN THE COURT OF COMMON PLEAS § CUMBERLAND COUNTY, PENNSYLVANIA IN RE § GEORGE STANLEY BROWN § NO. ~ § CIVIL ACTION § CHANGE OF NAME ORDER AND NOW, this day of~, 2001, it is hereby ordered that a hearing in the above-captioned name ch~ge matter be scheduled for the ,~n~d day of /")~,~,~.z.~.-t: ,2001at ~:57.) a.m./t:.m.,inCourtRoomNo, tT/ , Cumberland ~ounty Courthouse, I Courthouse Square, Carlisle, Pennsylvania. It is further ordered that an official search of thc proper offices in any county where the petitioner resided in within the past five years shall be conducted. Proper certification from the Prothonotary's Office verifying that there are no judgments, decrees of record or any other of like character against the petitioner shall be submitted at the hearing. It is further ordered that a notice of the filing of the petition for name change and of the date set for the hearing thereon shall be published in two newspapers of general circulation in Cumberland County, one of which publications may be in the Cumberland Law Journal. Notice of the filing ofthe said petition and hearing shall also be given to the Cumberland County District Attorney's Office by certified mail, return receipt requested. Said publication and notice shall take place at least ten ( 1 O) days prior to the hearing. Proof of publication and notice shall be submitted prior to or at the hearing. ~ !~N~ BY THE COURT: § IN THE COURT OF COMMON PLEAS § DAUPHIN COUNTY, PENNSYLVANIA IN RE § GEORGE STANLEY BROWN § NO. 3587 S 2000 § CIVIL ACTION § CHANGE OF NAME CERTIrlCATION Or NO JUDGMENTS rOUND 1, ~'~,_37~Q~XC~ ~ .~/~C~_. ,ProthonotaryoftheCourtofCommon Pleas in and for Dauphin County, do hereby certify that after diligent search by me made, I find no judgments, decrees of record or any other of like character against George Stanley Brown within the past five years. IN WITNESS WHEREOF, I have hereunto set my hand and caused the seal of the said court to be affixed at Harrisburg, Pennsylvania, this _.Q"~/'day of 2001. Prothonotary U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER ~-~l~c~. i~f~ Iqll~ ~.~,~') ,~ '.'" One piece of or{iinew mail addmlied to: · Complete items 1, 2, and 3. Also complete A. Received by (P/ease Fg~nt C/mm'y) B. Date of Delivew item 4 if Restricted Delivery is desired. so I~at we can tatum the card to you. C. Signature · Attach this cen:l to the back of the mallpiece, X '~'J-~'..~c';'~. '~ - /'"~- - -j [] Agent or on the front if space permits. .~r....~ ~ [] Adclm~ee 5 C~I:s le / )P~ IqOI.3 O I~ ..I, aC.O.D. 4. Re~b'lcte~l Delivery? ~.t/ra F~e) [] Yes PS Form 3811, July lg99 Domestic Retum Recept 1o2sms.a0-M.aes; THE PAXTON HERALD East Shore FAX 657-3523 Office & Plan; - (P 0 Box 6310) :01 Lrncoln Street {717} 545-9540 ~arr,sou g. =~, I;'3 ~2 (7171 545'8762 PROOF OF PUBLICATION ~A1T O[ I~Sl/I,V.LaU C01~.,YI¥ 0l~ 0AbT~ Before me. the subscriber, a Notary Public in and for said County.. personally came "~,.,.~,~a~'%, who, being duly sworn, doth .L ~M)TI~.E 18 HEREBy GIVEN depose and say that he/she is CLERK of THE PAXTON HERALD. a ..ma~ - Pofltk)n to Change terumo of Oeorge 8tonley newspaper or' general circulation published in Han~sburg, ?ennsylvania:meed ~memov~. That TH~ PAXTON HERALD was established on the 25"' day ol".lune. =reetoelmneethe nameof George e~_n~. Brown to ]960, and h. been. published continuously since that datel that the ~tij ,.ute uu,n,lon~.The advertisement, or' which a copy is attached hereto, was published in the advertising columns of 'rilE p RALD in all respects as ~~__~n..~t.ml~m~ ordered in the issue(s) o~ Affiant thrther deposes *at he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that the allegations in the ~atl foregoing statement as to the time, place and character of publication ate true. ~ S,~mre Sworn and subscribed before me this day of 0 7 tOOl Noarv Public ~ n~.HI I. KIMMEL, NotaP/Public i · ~ L:rn, erPaxtnn Twp. Dau hnCo ,1 . . . P ut1, '1 MY CO m-"t1.'s ~ ..... ~-. I, fl 7*. ' . ....... · ..y ~, 20~ · Cop:,' of Pubhshed N~cc ° Proof of Notice of Publication in Dauphin County Reporter 213 North Front Street, Harrisburg, PA 17101 Under Acts approved May 16, 1929, P. L. 1784 and April 24. 1931. P. L. 67.45 P. S. I et seq. State of Pennsylvania County of Dauphin I ss: Donald Morgan, agent of the Publisher of the Dauphin County Reporter, of the County and State aforesaid, being duly sworn, deposes and says that the Dauphin County Reporter. a legal periodical published in the City of Harrisburg, County and State aforesaid, was established January 1.1898, and designated the Legal Periodical for Dauphin County, on February 5. 1919, since which date the Dauphin County Reporter has been regularly issued in said County, and that the printed notice of publication at*ached hereto is exactly the same as was printed and published in the regular editions and issues of the Dauphin County Reporter on the following dates, viz: May 4, 2001 Affiant further deposes that he is the Agent of the Publisher of the Dauphin County Reporter. a legal Periodical of general circulation, to verify the foregoing statement under oath, and that neither the affiant nor the Dauphin County Reporter is interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in place and character of publication are tree.  Copy of Notice of Publication Sworn to and subr~dbed balfo~ me this 4th iN TH~ COUR'F OF COMMON PI'F'AS ! Statement Advertising Costs: Name Chanae: George Stantey Brown to Jorge Luis Quinnonez To DAUPHIN COUNTY REPORTER, Dr. For publishing the notice or publication at~ached hereto on the above stated dates ............. Probating same ................. $ 4. .0~ Total .................... $ 6S.00 Publbber's Receipt for Advertising Costs The Dauphin County Reporter, a legal periodical, hereby acknowledges receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. 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 : Roger M. Morgunthal, 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 ofall 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 $oumal on the following dates, Viz JULY 20, 2001 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 Rogei~--''~ SWORN TO AND SUBSCRIBED before me this 20 day of~ I I CUMBERLAND LAW JOURNAL In the Court of Common Pl~as Cumberland County. Pennsylvania No. 01-3289 Civil NOTICE IS HEREBY GIVEN thai a Pe~ltion ~o Chnnge Name of George Stanley Brown, was filed in the above-named court requesling a decree to change the name of George Stanley Browa to Jorge Luis Ouln- nonez. The Court hn~ fixed August 2, 2001 at 9:00 a.m. in Com't R~om No. 4. Cumberland Coun~ Court House, I Courthouse Square, Cra-- lisle, Pennsylvania. as the time nnd place for the hem-tag on said Peri- 0on, when and where nil interested i~rtles may appear and show cause, If any. why the request of the peri- tioner should not be granted. July 20 3 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, In the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of ~ and The ~d~ newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 11th day(s) of July 2001. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed end adopted severally by the stockholders and board of directors (~f the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said Countyto~ D~uphin in Miscellaneous Book "M", Volume 14, Page 317. /All PUBLICATION .................... ~~..'...~...:...: .................................. COPY ~worn to and s~bscribed ,,bef~.re..J~. this 16th da/of JulyS01 A.D. ~ My Commisaio~ E~ims June 6. 2no2 / NOTARY PUBLIC - MOlllb~, Pem'.sy~vama Associalioa ct Notariekly commission expires June 6, 2002 · '.' {~lt~'Nallle ' LAGUNA REYES MALONEY, LLP IN 'TNI COURT OF COMMQN PLIEAIS L~W OFFICES ~.a.mea,4~ 15 NORTH FRONT STREET, SUITE 203 ~s~'~':~'~,'~,.~ Statement of Advertising Costa a.m. llt ¢em-I ROOm Ne. 4, cum~.l~te ceu~- To THE PATRIOT-NEWS CO., Dr. ~,,.~,,=,,o, m ~h* fl.~ o.e ~ ~ ~ For publishing the notice or publication attached ~'~.~,~t~=~,,~~. hereto on the above stated dates $ 66.24 Probating same Notary Fee(s) $ 1.50 Bold Print $ 3.00 Total $ 70.74 Publisher's Receipt for Advertising Coat The Patriot News Co., publisher of ~and un P tri - w , newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. § IN THE COURT OF COMMON PLEAS § CUMBERLAND COUNTY, PENNSYLVANIA IN RE § GEORGE STANLEY BROWN § NO. 01 - 3289 § CIVIL ACTION § CHANGE OF NAME ORDER AND NOW, this Z~ day of ~,f.~..w- ,2001. after a hearing on the above-captioned matter, it is hereby ORDERED and DECREED that George Stanley Brown's Petition to Change his Name to Jorge Luis Quinnonez, is GRANTED and from this day forward George Stanley Brown is to be legally known as Jorge Luis Quinnonez. BY THE COURT: