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HomeMy WebLinkAbout13-4220 IN RE: IN THE COURT OF COMMON PLEAS OF Cam* CUMBERLAND COUNTY, PENNSYLV�IA-� MCD JASLEEN SIDHU 13-gV c) CIVIL ACTION LAW PRIOR JUDGE: M. L. EBERT, JR. CD PETITION FOR CHANGE OF NAME AND NOW, comes Petitioner, Rupinder Mann, by and through her counsel of record;' Bradley L. Griffie, Esquire, and the law firm of Griffie & Associates, P.C. and petitions the Court as follows: 1. Your Petitioner is Rupinder Mann, an adult individual currently residing at 637 Brisbain Lane, Enola, Cumberland County, Pennsylvania. 2. Your Respondent is Gurpartap Singh Sidhu, an adult individual whose last known address is 4649 Millati Lane, LaCrosse, Wisconsin, 54601. 3. The parties are the natural parents of one minor child, namely, Jasleen Sidhu, born December 16, 2004. 4. The parties are subject to an Order of Court dated January 17, 2008 relative to the custody of the child, said Order being attached hereto and incorporated herein by reference as Exhibit"A." 5. Although the Order of January 17, 2008 provides for Respondent to have supervised visits with the child, Respondent has not had any contact with the child for in excess of three (3) years. 6. Prior to contact Respondent had with the child once in February 2010, he had not had contact with the child for at least eight (8) months prior to that. J1,3 P 7 co- a 7. Respondent has returned to Cumberland County, Pennsylvania on multiple occasions over the past three (3) years and has made no efforts to visit with the child. 8. The Respondent has only had very few visits with the child and has not otherwise had contact with the child through any other means since the child's birth. 9. In prior testimony before your Honorable Court, Respondent was unable to give any reasonable explanation for his failure to have contact with the child. 10. Through collateral proceedings in the parties' divorce case, Respondent has indicated his intent to pursue his education outside of the continental United States, suggesting less likelihood of him having contact with the child. 11. Since the parties were before your Honorable Court in April 2013, no additional efforts of any nature whatsoever have been exerted by Respondent to maintain contact with the child. 12. There is no reason to anticipate that Respondent will maintain any involvement in the child's life or maintain any contact with the child based upon his past history. 13. During the past four (4) years, Respondent has had one (1) one-hour supervised visit with the child at the YWCA in Harrisburg, Pennsylvania, which visit occurred in February 2010. 14. Other than the one hour supervised visit in February 2010, Respondent has maintained no contact of any nature whatsoever in person, by telephone, in writing, by email, by text message, or through any other source or means for well over four(4)years. 3 15. Petitioner is a naturalized United States citizen who has.maintained her residency in the United States of America for in excess of fourteen (14) years. 16. Petitioner maintains gainful employment in Cumberland County, Pennsylvania where she has resided and been employed since 2004. 17. The child has attended school in Cumberland County, Pennsylvania in the East Pennsboro School District since her education began. 18. The child is entering the third grade for the 2013-2014 school year. 19. The child has been questioning your Petitioner, her mother, as to why her mother's name is different than her name, and why she has the last name of "Sidhu,"rather than"Mann." .20. In the past school year, the child has become insistent with her teacher that she be permitted to go by the last name of "Mann," which is your Petitioner's (her mother's)name, and has on occasion refused to write the last name of"Sidhu." 21. The concept that the child has a different last name than her mother under circumstances where she has no relationship of any nature whatsoever, and has not had any relationship with her father, the Respondent, for many years, creates tremendous confusion for the child. 22. In the past there have been conflicts between the parties relative to the use of the child's Passport such that the child's Passport was placed in escrow with the Cumberland County Prothonotary's office. 23. On various occasions over the past several years, Petitioner has been obligated by Court Order to post a $75,000.00 bond before she was permitted to secure the child's Passport and travel with the child to India. 24. In a hearing before the court on April 19, 2013, at Petitioner's request, the. Court authorized the Passport to be released, and no longer requires the Passport to be held by the Prothonotary's office, which has allowed Petitioner and the child to travel to India for a three week trip and return, as Petitioner promised and testified would occur to the court. 25. The Petitioner and the child are going to maintain their residence in Cumberland County, Pennsylvania for the foreseeable future. 26. Respondent has not been engaged in any aspect of the child's life, including contact or visits with the child, involvement with the child's healthcare, involvement with the child's education, involvement with the child's religion or in Any other aspects of the child's life, essentially since her birth. 27. The child does not have any estate of her own. 28. In related custody proceedings, Respondent was last represented by Timothy L. Czekaj, Esquire who is not known to represent the Respondent currently. 29. Contemporaneously with the filing of this Petition, a copy has been forwarded to the last known address of the Respondent and to his prior counsel notifying them that this Petition is being filed and, further, notifying them that a true and attested copy of the Order of Court and Rule to Show Cause to be entered upon this Petition will be forwarded to them upon receipt. 30. It is known that Respondent does not concur in this request. WHEREFORE, Petitioner requests your Honorable Court to enter an Order of Court and Rule upon Respondent, Gurpartap Singh Sidhu, to show cause, if any he has, as to why the child, Jasleen Sidhu, should not be permitted to change her. name to. Jasleen Mann for all future purposes. Respectfully Submitted, B e iff e, Esquire for Petitioner Supreme Court ID No. 34349 GRIFFIE &ASSOCIATES, P.C. 200 North Hanover Street Carlisle, PA 17013 (717),243-5551 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE:_ '711T RUPIN R NIANN, Petitioner IN RE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JASLEEN SIDHU CIVIL ACTION LAW PRIOR JUDGE: M. L. EBERT, JR. CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire, hereby certify that I did, the day of July, 2013, cause a copy of Petitioner's Petition for Name Change to be served upon Respondent by serving him, as well as his last known attorney of record, Timothy L. Czekaj, Esquire, by first-class mail, postage prepaid at the following address: Gurpartap Singh Sidhu 4649 Millatti Lane LaCrosse, WI 54601 Timothy L. Czekaj, Esquire 315 North Front Street Harrisburg, PA 17101 i DATE: 13 iffie, Esquire r for Petitioner Supreme Court ID No. 34349 GRIFFIE &ASSOCIATES, P.C. 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 IN RE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JASLEEN SIDHU CIVIL ACTION LAW PRIOR JUDGE: M. L. EBERT, JR. ORDER OF COURT AND RULE TO SHOW CAUSE AND NOW, this day of _V 0-ot, _, .2013, upon presentation and VA consideration of the within Petition, a Rule is hereby issued upon the Respondent,,Gurpartap Singh Sidhu,to show cause, if any he has, as to why the name of the child, Jasleen Sidhu, should not be changed to Jasleen Mann. rt7�— Rule returnable at a hearing to be held on the 10 day of 2013, at ,'Wo'clock +_.m. in Courtroom No. of the Cumberland County Courthouse. Service to be made by regular first class mail,postage prepaid upon the Respondent at his last known address. Service also to be provided by publication in the Cumberland Law Journal and in the Carlisle Sentinel on one occasion. By the Court, cr) LL_j C:) ce) M. L. Ebert,Jr.,Judge cow C-j IN RE: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA JASLEEN SIDHU : NO. 2013-4220 CIVIL ACTION LAW ORDER OF COURT AND NOW, this 25th day of October, 2013, upon presentation and consideration of the Petition for Change of Name, as well as the hearing held on Friday, October 25, 2013, it is hereby ORDERED and DIRECTED that the name of the child Jasleen Sidhu, born December 16, 2004, shall be legally changed for all purposes whatsoever from Jasleen Sidhu, to Jasleen Mann from this day forward. By the Court, t M. L. Ebert, Jr., Judge Cc: Bradley L. Griffie, Esquire V Attorney for Petitioner m r c a CD!. w CD IN RE: : IN THE COURT OF COMMON PLE S Off, ==; : CUMBERLAND COUNTY, PENNSY VIA- JASLEEN SIDHU : NO. 2013-4220 CIVIL ACTION '' .. {,- PETITION TO MAKE RULE ABSOLUTE AND NOW comes Petitioner, Rupinder Mann, by and through her counsel, Bradley L. Griffie,Esquire and law firm of Griffie and Associates,P.C. and petitions the court as follows: 1. Your Petitioner is Rupinder Mann, an adult individual currently residing at 637 Brisbain Lane,Enola, Cumberland County,Pennsylvania. 2. Petitioner filed a Petition, a copy of which is attached hereto and incorporated herein by reference as Exhibit `B," to authorize execution of the Passport and Visa application and related documents for her minor child, Jasleen Mann, on October 29, 2013. 3. Your Honorable Court issued an Order dated November 4, 2013, a copy of which is attached hereto and incorporated herein by reference as Exhibit "A," which included the issuance of a Rule upon the Respondent, Gurpartap Singh Sidhu, to show cause, if any he had, as to why the relief requested should not be granted. 4. The Rule is returnable thirty (30) days after service by first-class mail, postage prepaid upon the Respondent at his last known address. 5. By correspondence of November 6, 2013, a copy of which is attached hereto and incorporated herein by reference as Exhibit "C," a true and attested copy of the Petition and resulting Order of Court was served by first-class mail, postage prepaid upon Gurpartap Singh Sidhu at his last known address of 4649 Millati Lane, LaCrosse, Wisconsin, 54601. 6. More than thirty-six (36) days have passed since the time of service of the Petition upon the Respondent. 7. Your Honorable Court's Order of November 4, 2013 specifically provided that a hearing will be held on Thursday, December 19, 2013 at 9:30 a.m. in Courtroom Number 2 of the Cumberland County Courthouse, Carlisle, Pennsylvania "in the event an Answer is timely filed by the Respondent." 8. No Answer has been filed in this matter and the time for filing the Answer has passed. 9. On October 25, 2013 an Order was issued changing the name of the child at issue herein from Jasleen Sidhu to Jasleen Mann, with a copy of said Order being attached hereto and incorporated herein by reference as Exhibit"D." WHEREFORE, Petitioner requests your Honorable Court to enter an Order in the form attached authorizing Petitioner to execute any and all necessary documents related to the renewal or updating of the Passport or Visa, or related documents for the child, Jasleen Mann, without the need to secure the signature of the child's father, Gurpartap Singh Sidhu. Respectfully Submitted, adOEsquire q tad .� Petitione r Susreme Court ID No. 34349 GRIFFIE &ASSOCIATES,P.C. 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904,relating to unsworn falsifications to authorities. DATE: 1 11 3 /l . GRIFFIE,Attorney for Petitioner IN RE: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA JASLEEN SIDHU : NO. 2013-4220 CIVIL ACTION LAW • CERTIFICATE OF SERVICE rT1/ I, Bradley L. Griffie, Esquire, hereby certify that I did, the ( 3 day of December, 2013, cause a copy of Petitioner's Petition to Make Rule Absolute to be served upon Respondent, Gurpartap Singh Sidhu, by serving him by first-class mail, postage prepaid at the following address: Gurpartap Singh Sidhu 4649 Millati Lane LaCrosse, WI 54601 DATE: P-1( jiierre, 1 S '�/ riffle, Esquire i rney for Petitioner GRIFFIE &ASSOCIATES,P.C. 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 r IN RE: Hit ' Tr't 0,' ()T;,,,,J7 `{ IN THE COURT OF COMMON PLEAS OF t 13 ?IE P 9 Pt'1 ^• 27 CUMBERLAND COUNTY, PENNSYLVANIA JASLEEN SI?-UPNBERLAND COUNTY NO. 2013-4220 CIVIL ACTION LAW JUDGE: M. L. EBERT, JR. ORDER OF COURT AND NOW this day of D 2.CCr►1 b ftf , 20 �.3 , upon presentation and consideration of the within Petition to Make Rule Absolute, it is hereby ORDERED and DIRECTED that from this time forward, Rupinder Mann, natural mother of the child, Jasleen Mann, formerly known as Jasleen Sidhu, shall have all rights and authority to execute any and all documents relative to the renewal of the child's Passport, Visa, or related documentation without the need to secure the signature of the child's father, Gurpartap Singh Sidhu. Due to the lack of father's involvement in any legal or physical custodial rights to the child, the inability to secure a response from the father to the within pending petition, and the unlikelihood of being able to secure contact with, or approval from, the father relative to the renewal applications and related documentation to maintain the child's Passport and Visa in active status, Mother Rupinder Mann, alone and individually, may execute all such documentation and have it processed without securing the signature of Gurpartap Singh Sidhu. By the Court, M. L. E RT, JR., JUDGE Cc: /Bradley --L.. Griffie, Esquire �f��l C, �r