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Home My WebLink About04-5868NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PETITIONER IN RE: PETITION FOR CHANGE OF NAME OF DESEREA ELIZABETH ANN RILEY : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :NO: PETITION FOR CHANGE OF NAME Petitioner, Diane Elizabeth Dayton, mother, on behalf of Deserea Elizabeth Ann Rile~ by and through her attorney, Nathan C. Wolf, Esquire, hereby presents this petition requesting that this Court order a change of Deserea Elizabeth Ann Riley's name, pursuant to 54 Pa. C.S. $ 701 et seq., and in support thereof makes the following averments: 1. Petitioner Diane Elizabeth Dayton, is the mother of one minor child, namelyDeserea Elizabeth Ann Riley, the subject of the instant petition. 2. Petitioner has been a resident of Cumberland County continuously since November 2000. 3. Deserea Elizabeth Ann Riley was bom on March 30, 2000. 4. During the five years preceding the filing of this petition down to the and including the date thereof, Deserea Elizabeth Ann Riley has resided continuously at the following locations: (a) 1556 Main Street, Lisburn, Apt. A., Mechanicsbmg, Pennsylvania - November, 2000, to Present; (b) 1128 I-fighland Drive, Mechanicsburg, Pennsylvania - April, 2000, to November, 2000; and, 10. (c) 3 Limekiln Pike, Apt. C., Glenside, Pennsylvania - September, 1998, to - April, 2000. Petitioner was never married to the child's natural father, Ronald Riley. Became Petitioner wishes that the child's name match her own, as the child's father has effectively abandoned the child and has failed to act as a parent to the child since immediately following the child's birth. Petitioner seeks the relief requested herein to allow the child to have the same name as her mother when she begins school in 2005. Petitioner fears that the child will suffer embarrassment and confusion as to why her name and her mother's name are not the same, when her father is not involved in her life whatsoever. Petitioner desires Deserea Elizabeth Ann Rileyto be known as Deserea Elizabeth Dayton. Since the child's father has had no involvement with the child's life or welfare, the child's best interests would be served by allowing her name to be the same as Petitioner's so that the child may be spared the awkwardness of having a family name associated with someone who she does not know. Became the child is only four years old, she is not old enough to appreciate the significance of the name change at this point, and doing so now would allow her to grow up knowing only one family name. Petitioner requests that the child's name be changed from Deserea Elizabeth Ann Riley to Deserea Elizabeth Dayton. The reason for the requested change of name is the following: (a) The natural father has had no contact with the child or the Petitioner for a period in excess of 18 months and his agreement to the name change was sought through the undersigned counsel in February, 2003, and no response was ever received and the letter sent by counsel was never returned through the mail. WHEREFORE, Petitioner, Diane Elizabeth Dayton, respectfully prays that this Honorable Court enter an order fixing a time for a hearing on the instant petition before this Court, no Jess than one month, nor more than three months from the filing of the instant petition, and that after hearing, that this Honorable Court issue an Order authorizing the change of the child's name to Deserea Elizabeth Dayton. Dated: November ~_~_, 2004 ..~..~qitted, uite ~ 37 .~ou~4ffanover Street Su; et~201 Carlisle, PA 17013 Supreme Court I.D. No. 87380 (717) 241-4436 Attorney for Plaintiff VERIFICATION I, Diane Elizabeth Dayton, hereby verify that I am the Petitioner in this action and the facts stated in the above petition are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. $4904, relating to unswom falsification to authorities. ne Elizabq~Daytoff'"'- ~/ NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) ~41-4436 ATTORNEY FOR PETITIONER IN RE: PETITION FOR CHANGE OF NAME OF DESEREA ELIZABETH ANN RILEY : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO: 04-5868 Civil Term PETITION FOR LEAVE TO SERVE NOTICE BY PUBLICATION AND NOW comes the Petitioner, Diane Elizabeth Dayton, by her attomey, Nathan C. Wolf, Esquire, and presents the following Petition, representing as follows: 1. The Petitioner is Diane Elizabeth Dayton, an adult individual residing at 1556 Main Street, Lisbum, Apt. A., Mechanicsburg, Pennsylvania, Cumberland County, Pennsylvania. 2. The non-petitioning parent is Ronald Riley, an adult individual whose last known mailing address was 221 Keystone Drive, Apartment 5, Richmond, Kentucky 40475. 3. The parties are the natural parents of one minor child, namel3e Name Present Residence Deserea Elizabeth Ann Riley 1556 Main Street, Lisbum, Apt. A., Mechanicsburg, Pennsylvania 4 D.O.B. 03/30/2000 4. The child is presently the subject of a Petition for Change of Name filed November 22, 2004. 5. Petitioner has sero a certified copy of the Petition for Change of Name to the non- petitioning parent at his last known address in Richmond, Kentucky, by regular and certified mail. The Court has also mailed a copy of the Order, setting forth a Hearing on the Petition for Change of Name Name of February 1, 2005, at 9:00 a.m. in Courtroom 2 of the Cumberland County Courthouse, to Mr. Riley at the same address. 6. All mailings were returned to sender, not deliverable and unable to forward. Copies of the envelopes are attached as Exhibits A, B, and C. 7. Petitioner has used this address successfully in the past, and she has no information as to the present whereabouts of Mr. Riley. WHEREFORE, Petitioner asks this Honorable Court to grant leave to the Petitioner to provide notice by publication in a newspaper of general circulation in Madison County, Commonwealth of Kentucky, the county of Father's last known address. Dated: December /~ , 2004 Respectfully submitted, 37 S/~th~over Street Suitg-g0l Carlisle, PA 17013 Supreme Court I.D. No. 87380 (717) 241-4436 Attorney for Petitioner .1:.', 0 .i:.', .q 0 Exhibit A i-'-~ 0 0 m = I-h .I) 0 ~ I...'- ~ 0 0 0 I.~ m 0 · ~ -..J ri' · 0 ill'! 0 Exhibit B Exhibit C o o VERIFICATION I, Nathan C. Wolf, Esquir~,~depose.and say that I am the. a_ttg_rney for Petitioner, and do hereby verify that the facts set forth in this petition are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unswom falsification to authorities. December /t)7 ,2004 C~etitione~' INRE: PETITION FOR CHANGE OF NAME OF DESEREA ELIZABETH ANN RILEY : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW : NO: 2004-5868 AND NOW,'" I II- "'yof ~,200S' "po",~kko;oo of'" ~ petition of Diane Elizabeth Dayton for change of name, and upon presentation of proof of publication of notice as required by law, and it appearing that there is no lawful objection to the request of the Petitioner, it is hereby ORDERED that the name of Deserea Elizabeth Ann Riley is changed to Deserea Elizabeth Dayton. I B~'h' cic:f/ '\ { ~M J. N~ tJ~ 6J; I~t~ tdL~ :; \ dZ~ .7..;//,-1 ~ !~ !"".) C~:.) t:;;:::I <:,;;.1.... -C\ g \ - ~".o (.J"'