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Home My WebLink About12-3594 hd r _7D ; IN THE COURT OF COMMON PLEAS OF = - `' - CUMBERLAND COUNTY, PENNSYLVANIA In Re: RAUL I. VARGAS, born 9/15/2007 NO. la- 359y Civil Term Civil Action - Law PETITION FOR NAME CHANGE AND NOW, comes Leslie Ann Vargas-Otero, natural mother of Raul I. Vargas, by and through her attorney, Jane Adams, Esquire and files her petition to change her child's name, and support thereof avers as follows: 1. Petitioner, Leslie Ann Vargas-Otero, currently lives at 326 Farmington Drive, Shippensburg, Cumberland County, Pennsylvania, 17013. 2. Petitioner is the natural mother of three children, namely Arianna Deleon, born January 1, 2002, Kenneth Rivera, born December 28, 2004, and Raul I. Vargas, born September 15, 2007. 3. Petitioner/Natural Mother is seeking to change the name of Raul I. Vargas, born September 15, 2007. 4. The natural Father of Raul I. Vargas, whose name is also Raul Vargas, has an extensive criminal record, and has been charged with Indecent Assault, Unlawful restraint, indecent exposure, rape of a child, and involuntary deviate sexual intercourse with a child as well as other serious offenses. 5. Petitioner has a PFA Order in place against the Father, Raul Vargas. 6. In deference to the Child's future and the safety and well-being of the victim, and the family, it is requested that the child's name be changed. Mother will testify in more detail about the effect of the child having Father's name, upon her family and other children at the hearing. 7. The child is commonly called by his middle name, Isaiah. 8. The child is under eighteen (18) years old and has no outstanding credit debt that could be avoided through a name change. 9. The child has no outstanding federal or state tax debt that could be avoided through a name change. 10. Petitioner is requesting that the child's name be changed to: Isaiah Enrique Ramos. WHEREFORE, Petitioner requests that this Honorable Court Order change the child's name. Respectfully submitted, Date: gNeAdams, Esquire o. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PETITIONER VERIFICATION I verify that the statements made in this 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. 1,7 Date: r ?'L. Leslie Ann Vargas-Otera, Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA In Re: RAUL I. VARGAS, born 9/15/2007 Civil Action - Law NO. Id - 35911 PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Civil Term Kindly allow Petitioner, Leslie Vargas-Otero, to proceed in forma au eris. This case was referred by the Pro Bono Program of the Cumberland County Bar Association. I, Jane Adams, attorney for the party proceeding in forma paugeris, certify that believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. Respectfully submitted, Date: ?Z 0 0Ca44A,0_ ne Adams, Esquire .D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA In Re: Civil Action - Law RAUL I. VARGAS, born 9/15/2007 NO. Civil Term AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. 1 am the Petitioner in the above matter and because of my financial condition I am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. 1 am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. 1 represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: Leslie Vargas-Otero Address: 326 Farmington Drive Shippensburg, Pa. 17257. (b) Social Security Number: not provided in this document due to privacy concerns. 4. 1 am presently unemployed. 5. 1 am on public assistance and receive $498.00 per month. 6. 1 have no other source of income. I am in school. 7. 1 do not receive child support from the Father of the subject child of this action, as he- is believed to be in jail. 8. My monthly rent expenses are $318.00 per month. 9. 1 have no other property or resources from which I could withdraw funds to pay for the filing and legal fees of this matter. 10. The persons who are dependent on me for support are: Arianna Deleon, daughter, born 1/1/2002; Kenneth Rivera, son, born 12/28/2004; and Raul I. Vargas, born 9/15/2007. 11. 1 understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. VERIFICATION I verify that the statements made in this affidavit 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: ?P l 71 Leslie Vargas-Otero, Petitioner IN RE: RAUL I. VARGAS born 9/15/2007 a" of* 'OR ty 00 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 2012-3594 CIVIL TERM IN RE: PETITION TO CHANGE NAME OF MINOR CHILD ORDER OF COURT AND NOW, this jBth day of June, 2012, upon consideration of the attached Petition for Change of Name, filed by Leslie Ann Vargas-Otero on behalf of her minor child, Raul I. Vargas, a hearing on the petition is scheduled for Wa a , Ul 2012, at in Courtroom Number Cumberland County, Carlisle, Pennsylvania. PETITIONER will obtain certifications of actions filed of record from the Prothonotary no more than two days prior to hearing. 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] [Main Volume]), and 54 Pa. C.S. §§701 et. seq. IN ADDITION, notice of the petition and time and place of the hearing shall be provided to the child's other parent by Petitioner at least 10 days prior to the hearing by regular mail and by certified mail to his last known address. Proof of such service shall be filed of record prior to the hearing. By the Court, Aii- ." a1 ? '.N 7i r Thomas Al Placey C.P.J. Distribution List: ? Jane Adams, Esq. 17 W. South St. Carlisle , PA 17013 Counsel for Petitioner, on behalf of minor child COPY tRa. ('- c./ 6// VIA) "--I- 6 s THE PRO T i+0'?1.1 2012 JUL -9 PH 2: 39 CUd"!iERLAN0 COU14TY PENNSYLVA NIA. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA In Re: RAUL I. VARGAS, born 9/15/2007 NAME CHANGE NO. 2012 - 3594 Civil Term Civil Action - Law AFFIDAVIT OF PUBLICATION I, Jane Adams, Esquire, do hereby certify that on June 27, 2012, 1 caused of the hearing scheduled in the above-captioned matter to be published in the Cumberland Law Journal. A copy of the Proof of Publication of Notice is attached hereto. Date.?y Cj /-? Respectfully Submitted: ? e Adams, Esquire . No. 79465 7 West South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Jackie Cox, Sales Director, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed. and published in the regular editions and issues of THE SENTINEL on the following day(s): June 27, 2012 COPY OF NOTICE OF PUBLICATION M &a Coact caamon Pt Pte, fio. 201 Tspe?av) f:'Yarpas.7g Paraml?ia6arssyd: patlttan rras Nladd On Ain* S. 2012, by LeNk "W'" of Raid 1. VWWO to Walsh EMW, rx a mtrwr. pfd 1W ar 0("W C )Wt 16tad the ttth tlay of ,luly. 2012, a1>i,`3?- _? ofMw ?1lmbarlMwd C004r Gowthawe. hasr ft, when sad n the` tY +Nb "M for a parsodl?roytf?ov cease, wiry sa?d 'nsma stwatd not be ch*X*: Jams Adams, EsgL*o t7 VV" tai m $traat CarNsle, PA 17013 717-245-OW Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are tr , i ? Swofn to and sub ibed before me this . '2 J-14 dd 10 1 )- Notary Public My commission expires: NOTARIAL SE,`,L BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY My Commission Expires ,Jan 27, 2014 --LLU'Cr'? :. F HiE P UTHON 2012 JUL -9 PM 2: 319' CUMBERLAND COU TN IN THE COURT OF COMMON PLEA?gNSYLVANIA CUMBERLAND COUNTY, PENNSYLVANIA In Re: RAUL I. VARGAS, born 9/15/2007 NAME CHANGE NO. 2012 - 3594 Civil Term Civil Action - Law AFFIDAVIT OF PUBLICATION I, Jane Adams, Esquire, do hereby certify that on June 29, 2012, 1 caused noti of the hearing scheduled in the above-captioned matter to be published in the Cumberland Law Journal. A copy of the Proof of Publication of Notice is attached hereto. Respectfully Submitted: Date J e Adam L-?i'?--?-- r s, Esquire No. 79465 17 West South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County an( State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland LaN Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesa was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularli 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 Journal on the following dates, Viz June 29, 2012 a Marie Coyne, itor SWORN TO AND SUBSCRIBED before me this 29 day of June, 2012 Notary 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 subjec matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL LEGAL NOTICE OF CHANGE OF NAME In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2012-3594 Civil Term In re: Raul I. Vargas To all persons interested: NOTICE IS HEREBY GIVEN that a petition was filed on June 8, 2012, by Leslie Ann-Vargas-Otero, to change the name of Raul I. Vargas to Isaiah Enrique Ramos, a minor. Notice is hereby given that an Order of said Court fixed July 11, 2012, at 1:30 p.m. in Courtroom No. 6 of the Cum- berland County Courthouse, Carlisle, Pennsylvania, as the time and place for a hearing, when and where all persons may show cause, why said name should not be changed. JANE ADAMS, ESQUIRE 17 West South St. Carlisle, PA 17013 (717) 245-8508 June 29 IN THE COURT OF COMMON PLEAS OF #i- U-t1 Fi: CUMBERLAND COUNTY, PENNSYLVANIA THE PROTHO 010"`' In Re: NAME CHANGE 2012 JUL `9 PM 2 3?1 CU ANQ COUNT) " RAUL I. VARGAS, born 9/15/2007 NO. 2012 - 3594 ? IftrVANIA i Civil Action - Law AFFIDAVIT OF SERVICE I, Jane Adams, Esquire, do hereby certify that on June 26, 2012, 1 mailed a col of the name change petition filed under the above-captioned docket number, to Raul I Vargas, the parent of the child who is the subject of the petition, via CERTIFIED MAIL RETURN RECEIPT REQUESTED, at the address below, which is his last known verified address. A copy of the receipt is attached hereto. Raul I. Vargas Perry County Prison South Carlisle St. New Bloomfield, Pa. 17068 ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: tNLT V s V41Tlc? PA X? ? Agent Addressee ved by ( nWgan) C. Date of Delivery D. Is delivery address diTiftFit from', Item 1? ? Yes If YES, enter delivery address below: ? No 3. Service Type A&Owtifbd Mail ? Exp=e Mail ? Registered ? Return Oecelpt for Merchandise ? irmssd mou ? C.O.D. 4. Restricted Delivery? (Exhs Feel ? Yes 2. Article Number 7 011 1150 0000 1089 1472 (J}arrsfer from seMcelsbeq PS Fort 3811, February 2004 Domestic Return Receipt Respectfully Submittedr Date: - 1 / J ne Adams, Esquire D. No. 79465 17 West South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF 102595-02-M-1540 IN THE COURT OF COMMON PLEAS OF c 7 r" -„ CUMBERLAND COUNTY, PENNSYLVANIA N In Re: NAME CHANGE cn r- ? r*-? RAUL I. VARGAS, born 9/15/2007 NO. 2012 - 3594 Civim? t-D Civil Action Law c r'J AFFIDAVIT OF SERVICE -...r' :c, I, Jane Adams, Esquire, do hereby certify that on June 26, 2012. 1 mailed a cl of the name change petition filed under the above-captioned docket number, to Raul Vargas, the parent of the child who is the subject of the petition, via FIRST CLASS MAIL, at the address below, which is his last known verified address. A copy of the receipt is attached hereto. Raul I. Vargas Perry County Prison South Carlisle St. New Bloomfield, Pa. 17068 UMTWSMUES PCA3MSEWIM® Certificate Of Mailin This Cerbficote of Mailing provides 3Iidence that mail has been presented to USPS®form dir This form maybe usod fqr& mestir and int-atioral mall PS Form 3817, April 2007 PSN 7530-02-000-9065 Date: Respectfully Submitted: O O O GF--. gCJI JaAe Adams, Esquire No. 79465 17 West South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF 'c N Z P `- 0 N ^C A 00 ..{J I_ rl~ C 3aI2.' . 3[ =?N C71V?? CIJ1C.'? ? \1 Ci D v7, m i}- 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA In Re: NAME CHANGE RAUL I. VARGAS, born 9/15/2007 NO. 2012 - 3594 Civil Term Civil Action - Law ORDER AND NOW, this day of July, 2012, after hearing, and upon consideration of the Petition to Change Name and the exhibits filed, it is hereby and directed that Raul I. Vargas, who was born on September 15, 2007, 104 be known as: Isaiah Enrique Ramos. By the Court:, i ovA C A PUA ? cFci cc: Jane Adams, Esquire _ 'IT 1 e s P-.,eiv Raul I. Vargas, natural father jc ? Perry County Prison New Bloomfield, Pa. 17068 IV ^- ? `d ? N