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.
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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
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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
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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.
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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
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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.
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cc: ✓Jane Adams, Esquire
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