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HomeMy WebLinkAbout12-7503 3F- THE PROTHONOTaw." 2013 MAR 20 PM 4: 06 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA In Re: No. 12 - 7503 Civil Term Chance MacKenzie Evelhoch BORN: 8129101 Civil Action - Law NAME CHANGE MOTION TO WAIVE ADVERTISING AND NOW, comes Jesse Kelley, by and through his Attorney, Jane Adams, Esquire, and respectfully represents as follows: 1. Petitioner is Jesse Kelley, (hereinafter referred to as "Petitioner') and he currently lives at 531 Willow Grove Road, Carlisle, Pa. 17015. 2. Petitioner is the Natural Father of Chance MacKenzie Evelhoch, born August 29, 2001. 3. A petition for a name change for Chance MacKenzie Evelhoch was filed on December 14, 2012 under the above-captioned docket number. The hearing is scheduled for April 18, 2013 at 10:30 a.m. before this Honorable Court. 4. Advertising notice of the hearing in the newspaper is directed by the statute regarding name changes but can be waived by court Order. 5. Natural Mother has been notified of the petition via certified mail and she has indicated via a telephone call to Petitioner's counsel that she is in agreement with the name change. A certificate of service is being filed contemporaneously with this Motion. 7. The child will be only eleven years old at the time of the name change hearing, and therefore, he does not have any tax debt or creditors which might need to be notified of the name change by publication. 8. The only other person who may be interested in this matter is Natural Mother, who has indicated she consents to the proposed name change. 9. Petitioner knows of no other third parties which may be interested in, or affected by the name change. r r 10. Petitioner's income is modest, and the funds used for advertising would be better utilized to support the child. 11. Petitioner is requesting that the requirement of advertising be waived by this Honorable Court for the reasons listed above. 12. This matter was previously assigned to Judge Ebert. 13. Petitioner does not know of any reason Mother would object to the request to waive advertising. WHEREFORE, Petitioner requests that this Honorable Court Order that the requirement of advertising be waived. Respectfully submitted, Date: �3 : / �r . /� Ja Adams, Esquire I . No. 79465 West South St. arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PETITIONER i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA F ILED-OPF IOL" THE PROTHONOTrA( In Re: No. 12 - 7503 CtvhT?W 20 PM 4: 06 Chance MacKenzie Evelhoch BORN: 8/29/01 Civil Action - Law GUMBERLANO C0UNU NAME CHANGE PENNSYLVANIA CERTIFICATE OF SERVICE I, Jane Adams, Esquire, do hereby certify that on December 29, 2012, I served a true and correct copy of the NAME CHANGE PETITION AND HEARING NOTICE in the above-captioned matter upon the following individual(s) by certified mail, restricted, return receipt requested, addressed as follows: Belinda Brwon c/o Janel Evelhoch 385 Crossroad School Rd. Y Newville, Pa. 1741 J a + �. 0.is soar ce ► l c . MAN080 a 1069 1609 =_ Oifok No Respectfully Submitted: Date: n Adams, Esquire .D No. 79465 1 West South St. arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF laneAdams ATTORNEY AT LAW 17 WEST SOUTH STREET CARLISLE,PA.17013 (717)245-8508 voice (717)241-2456 fax esgadams @gmail.com December 28, 2012 BeLinda Brown 385 Crossroad School Road Newille, Pa. 17241 Re: Name Change Petition Dear BeLinda: Enclosed please find a Petition for a Name Change which I filed for Jesse Kelley regarding your son Chance. A hearing is set for April 18'', 2013. It is my understanding that you are in agreement regarding Chance's change of name. You may attend the hearing but you are not required to. If you would be willing to sign a consent, confirming you are in agreement with the name change, please contact me at the number listed above. Thank you for your attention to this matter. i Very truly yours, J�A4u"l Jane Adams, Esquire cc: Jesse Kelley OF THE �°'ROTFf�'F4u 2013 MAR 22 PM 12: 10 CUMBERLAND COUNT" PENNSYLVANIA, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA In Re: No. 12 - 7503 Civil Term Chance MacKenzie Evelhoch BORN: 8/29/01 Civil Action - Law NAME CHANGE ORDER k� AND NOW, this day of M Wr 2013, upon consideration of the attached Motion, Petitioner is excused from advertising notice of the hearing scheduled in the above-captioned matter. BY THE COURT: J. i cc: ✓Jane Adams, Esquire 4y ma,led, ���/�