HomeMy WebLinkAbout11-8501IN RE: CHRISTINA M. ENGLAND
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IN FORMA PAUPERIS
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLANDCOUNTY, PENNSYLVANIA
CIVIL ACTION
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NO. C)
CHANGE OF NAME OF MIN( C)
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PETITON FOR CHANGE OF NAME OF MINOR C') ?
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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
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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
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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
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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
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STATE R 8106.106.1(01.90)
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IN RE: CHRISTINA M. ENGLAND
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IN FORMA PAUPERIS
: IN THE COURT OF COMMON PLEAS OF
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CIVIL ACTION
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CHANGE OF NAME OF MINORn
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PRAECIPE TO PROCEED IN FORMA PAUPERIS =MW
To the Prothonotary:
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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
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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
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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
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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,
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Kevin . Hess, P.J.
? Robert A. Kulling, Esquire
For the Petitioner
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