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HomeMy WebLinkAbout11-8501IN RE: CHRISTINA M. ENGLAND Ti'sfwn -T061an eetr&t(p C I'111drI J-Urle 0a(ru°ro IN FORMA PAUPERIS : IN THE COURT OF COMMON PLEAS OF : CUMBERLANDCOUNTY, PENNSYLVANIA CIVIL ACTION --;7 NO. C) CHANGE OF NAME OF MIN( C) X;o 'C -urn c PETITON FOR CHANGE OF NAME OF MINOR C') ? D c r CD AND NOW, comes Petitioner, Christina M. England, by and through her -n attorney, Drew F. Deyo, Esquire, and in support of her Petition for Change of Name of Minor, makes the following declaration: 1. Birth Date and Place: The minor children, Tristan Tobias Carrero, born June 12, 2007, and Lillian June Carrero, born September 15, 2003, were born in Dauphin County and Berks County, respectively. Certified copies of the minors' birth certificates and fingerprints are attached to this Petition. 2. Birth Name: 'The minors were named Tristan Tobias Carrero and Lillian June Carrero at birth, and as of the date of this Petition, the minors have always been known by that name, with the following exceptions, if any: N/A 3. Residence: The minors reside with Petitioner at 500 Third Street, Carlisle, Cumberland County, Pennsylvania 17013. 4. Minor's Parents: The mother of the minor child is Christina M. England, Petitioner, and she resides at 500 Third Street, Carlisle, Cumberland County, Pennsylvania 17013. Mother enjoys sole legal and sole physical custody of the minor children. The father of the minor children is Manuel Carrero Jr., who is currently incarcerated at the Berks County Prison, and awaiting trial on charges of murder in the IFID first degree. Pursuant to an Order of Court, Father does not enjoy and legal or physical custody. 5. Reason for Name Change: Petitioner seeks to change said minors' last name to England as opposed to Carrero, and offers the following reason for seeking to do so: the minor children originally took Father's name at birth, but as previously stated, Father is awaiting trial for murder in the first degree involving a case where he allegedly beat an eighty-three year old woman to death with a hammer. Petitioner, therefore, does not want her children to share Father's last name. 6. Legal and Creditor Status: The minor children do not have any outstanding judgments, and have never been convicted of a crime. 7. Additional Declarations: Petitioner requests that she not have to comply with the local rule of Court mandating that she publish notice of the name change hearing in the newspaper, and makes said request because she does not want to shed light upon Father's horrible crimes in front of the community; nor does she want to subject the children to any unneeded attention resulting from Father's crimes. In addition, Petitioner notes that she is filing this Petition under In Forma Pauperis status. WHEREFORE, Petitioner respectfully requests that this Honorable Court order the minors' names be changed as follows: Tristan Tobias Carrero to Tristan Tobias England, and Lillian June Carrero to Lillian June England. Dated: Respectfully submitted, ROMINGER & ASSOCIATES (Z2. Drew F. Deyo, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 308857 Attorney for Petitioner IN RE: CHRISTINA M. ENGLAND --j'r-jS?c?e7 -o6igs 00fr'ero GillIdl? func° ew;l&ro IN FORMA PAUPERIS : IN THE COURT OF COMMON PLEAS OF : CUMBERLANDCOUNTY, PENNSYLVANIA CIVIL ACTION : NO. : CHANGE OF NAME OF MINOR CERTIFICATE OF SERVICE I, Drew F. Deyo, Esquire, attorney for Petitioner, do hereby certify that I this day served a copy of the within Petition for Change of Name of Minor upon the following via first class mail, postage prepaid, at the following address: Manuel Carrero Jr. BCP 2011-0912 Block 0-219 Berks County Prison 1287 County Welfare Road Leesport, Pennsylvania 19533 Date: November 62011 Respectfully submitted, Rominger & Associates /;Z::z . Drew F. Deyo, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court I.D. # 308857 Attorney for Petitioner VERIFICATION I verify that I am the Plaintiff and that the statements made in the foregoing Petition 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. Date: a?Q?, Christina M. gland, Plam ---------------------------------- DATE OF BIRTH 09-:L5-2003 IMO DAY, YEAR) COUNTY OF BIRTH B E R K S NAME LILLIAN JUNE CARRERO FATHERS NAME MANUEL CARRERO JR MOTHERS MAIDEN NAME CHRISTINA MARIE ENGLAND FILE NO 0980700-2003 DATE FILED IMo9DAY. YEAR) -2003 DATE ISSUED IMO9DA1 YEAR) 2 0 0 3 SEX FEMALE 1Tb h to oorlily tlt t thb b (nM SPY Of IM rxM wI b Or1 fib In IM Ponropv?nb Dwrtment of H"Ith, In rroeorOrarr with AC M, P.L 3W. opOrowd by 1M Wrwal Mtambly, Jum 2Y, 71Ri1 cl" //I CHAALSS HAMSTER STATE R 8106.106.1(01.90) Esc 2933146 S? N om m m FH v m <o m a ?m ?c 'aF m ? mm m ?m 1° A >a m . s a x _D r Ln r w 171. ??(, 5?y ,, ,; ; ? ; - -??.. . - ?? ?, _.------ 3 I r { 1:. /" ? W F ??? ? . i -?- - ?Ar - '?"=' .. ?.I ?: J i Ank 4 ahi re C x •, IN RE: CHRISTINA M. ENGLAND ris?an ob,as C'a?ier o ox 6y L I ,'ll,an Tv,ne C?rrero Rff? DeyO .5 ecief? l IN FORMA PAUPERIS : IN THE COURT OF COMMON PLEAS OF : CUMBERLANDCOUNTY, PENNSYLVANIA CIVIL ACTION NO. I- g5-0 ('t?IZ 1-w CHANGE OF NAME OF MINORn x -ax rn := PRAECIPE TO PROCEED IN FORMA PAUPERIS =MW To the Prothonotary: v' xo -t Kindly allow Christina M. England, Plaintiff, to proceed in forma au eris. I, Drew F. Deyo, attorney for the party proceeding in forma ap uperi s, certify that I N CJ Q •c 0 -o r Z; believe the party is unable to pay the costs and that I am providing free legal services to the party. Dated: Respectfully submitted, ROMINGER & ASSOCIATES Drew F. Deyo, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 308857 Attorney for Petitioner CD 4C) a? _„ ire, 3%' 70 -G IN RE: IN THE COURT OF COMMON PLEAS OF CHRISTINA M. ENGLAND CUMBERLAND COUNTY, PENNSYLVANIA LILLIAN JUNE CARRERO CIVIL ACTION - LAW IN FORMA PAUPERIS NO. 11-8501 CIVIL TERM IN RE: PETITION FOR CHANGE OF NAME ORDER OF COURT AND NOW, this 29th day of December, 2011, after hearing, the within petition for change of name is granted, and the child, Lillian June Carrero, shall hereafter be known as Lillian June England. By the Court, Robert A. Kulling, Esquire For the Petitioner bg ?o = c ` 3 --s =? rn Z-q - -'D-n ? o M C7, DC °M --I _ . A -< ?. IN RE: IN THE COURT OF COMMON PLEAS OF CHRISTINA M. ENGLAND CUMBERLAND COUNTY, PENNSYLVANIA TRISTAN TOBIAS CARRERO : CIVIL ACTION - LAW IN FORMA PAUPERIS NO. 11-8501 CIVIL TERM IN RE: PETITION FOR CHANGE OF NAME ORDER OF COURT AND NOW, this 29th day of December, 2011, after hearing, the within petition for change of name is granted, and the child, Tristan Tobias Carrero, shall hereafter be known as Tristan Tobias England. By the Court, A At- Kevin . Hess, P.J. ? Robert A. Kulling, Esquire For the Petitioner :bg CoPle S /19, -W,/I( '0a c az, 2:;u r-- CZ 'a m D c- a C)-n y, G ca ' ?` 1> :=