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Home My WebLink About05-1056 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA InRe: Alexander Joseph Strawcutter Date of Birth: 5/3/01 NO. ~-/O~1o e()~Cl-~ CIVIL ACTION - LAW PETITION FOR NAME CHANGE. AND NOW, comes Robert J. Smith, by and through his Attorney, Jane Adams, Esquire, and respectfully represents the following: 1. Petitioner, Robert J. Smith, (hereinafter referred to as "Father") is the natural father of Alexander 1. Strawcutter (hereinafter referred to as "Child"). 2. Petitioner lives at 521 Liggett Road, Carlisle, Cumberland County, Pennsylvania, 17013. 3. The Child's Natural mother is Verna Strawcutter (hereinafter referred to as "Mother"). 4. Mother is currently believed to reside at 10 33rd St. South, Texas City, Texas, 77590. 5. Father has had primary physical custody of the child since November 2004. 6. Father has had legal and primary physical custody of the child pursuant to an Order of Court entered January 12, 2005 by this Honorable Court. (Please see Exhibit A). 7. The child's date of birth is May 3,2001. 8. For two months prior to Father obtaining custody ofthe child, the child lived with his cousins in Punxsutawney, Pennsylvania upon the recommendation of Jefferson County Children and Youth. 9. Prior to the child living with his cousins, the child lived with Mother at 502 Sycamore St., Apt B28, Punxsutawney, Jefferson County, Pennsylvania. 10. Mother has not requested a visit with the child since approximately November 27, 2004. 11. Father believes that having the child use the last name of Smith would avoid confusion regarding school and medical records. 12. The child is only three years old and has no outstanding credit debt that could be avoided through a name change. WHEREFORE, Petitioner requests that this Honorable Court Order that Alexander Joseph Strawcutter's name be changed to Alexander Joseph Smith. Respectfully submitted, Date: ~l ~t 16s- e &\dams, EsqUIre LD o. 79465 S. Pitt 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. 94904, relating to unsworn falsification to authorities. Date:) \~<6\6S- 12rI-c:* ~!~L Robert 1. Smith, Petitioner p -It;. 1f- \ V( ~ - - U( \' If) D - ~ -J '}..l ~ ?- ---....c: J- o (~. (i;'~\\ (J'c';~. J . '\:_.:C~ \,~ " '::i7 ("} 2c> '"72:- -z. .::\ .-<. ....' $ "-" -;:;;. "P': ~ \ t-l '. Q. ~~ -i~~) ~ ;~.':;1 :D ,..,. t)(~ ~ ;e-;,<' ..- S.\ ,.- 'T,'. ;.:, ":"2 .r;:- IN RE: ALEXANDER JOSEPH STRA WCUTTER: IN THE COURT OF COMMON CUMBERLAND COUNTY, PE CIVIL ACTION - LAW NO. 05-1056 CIVIL TERM ORDER OF COURT LEAS OF SYLVANIA AND NOW, this 5th day of April, 2005, upon considera ion of the attached Petition for Narne Change, a hearing is scheduled for Thursday, . une 9, 2005, at 9:30 a.m., in Courtroorn No.1, Curnberland County Courthouse, Carlisle, Pennsylvania. IT IS FURTHER ORDERED that notice of the filing of aid Petition and the aforesaid date, tirne and place of the hearing be published once in he Cumberland Law Journal and a newspaper of general circulation in the County at leas 10 days prior to the hearing; in addition, Petitioner shall cornply with all other require ents of C.C.R.P. 5, and the Act of December 16, 1982, P.L. 1309, 96 (see 54 Pa. C.S. 9701 [Historical and Statutory Notes] [Main Volurne]), and 54 Pa. C.S. S9701 et seq. IT IS FURTHER ORDERED and directed that the na ural rnother, Verna Strawcutter, be served with a copy of the above petition and hearing otice. BY THE COURT, Jane Adams, Esq. 64 S. Pitt Street Carlisle, PA 17013 Attorney for Petitioner - It .!J (t ~/J /\\A~ . r / 4- {p ()C) )s' Verna Strawcutter 10 33rd Street South Texas City, TX 77590 :rc V]N\;:'\l'\SNr'~,~jd 'L' '(Y"~' '''''1' "'~""I'I" ^ l\l, l~)'" <,\',' :;'~'i'li"l .J I ~ :8 Hd S- ~dV SOOl AtNiOi\;Uh.LOdd 3Hl :10 :;"'.!.in-O"li:l .,'-)t,__'....~ ",:J '_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA InRe: Alexander Joseph Strawcutter Date of Birth: 5/3/0 I NO. 05 - 1056 CIVIL ACTION - LAW MOTION FOR SERVICE BY ADVERTISEMENT AND NOW COMES, Robert Smith, Petitioner, by and through his attorney, lane Adams, Esquire, and hereby avers the following in support of his Motion for Advertisement: 1. Petitioner is Robert Smith, (hereinafter referred to as "Petitioner"), who currently lives at 521 Liggett Road, Carlisle, Pennsylvania. 2. Petitioner is the natural father of Alex Strawcutter, and has primary custody of Alex Strawcutter. 3. The natural mother of the child is Verna Strawcutter, whose last known address was 10 33'd St. South, Texas City, Texas, 77590. 4. On March 2,2005, Petitioner filed a Petition to change the name of his son, Alex Strawcutter, to Alex Smith. 5. A letter sent to Mother at her last known address containing notice of the hearing date was returned labeled "moved left no address". (Please see Exhibit A). 6. Petitioner's counsel has attempted to contact Mother at the telephone number she provided when she lived at 10 33'd St. South, Texas City, Texas; upon calling repeatedly on five different days, from approximately April 22, 2005, through May 3, 2005, and a busy signal or "all circuits are busy" message was received. 7. Petitioner's counsel attempted to contact Mother at the telephone number she provided when she lived at her previous address at 502 Sycamore St., Apt B28, Punxsutawney, Pennsylvania, 15762; upon calling, a message was played indicating that the telephone number was disconnected. 8. Petitioner's counsel attempted to find an address for Mother on Superpages.com, upon a search, no address was found for Mother in Texas City, Texas. (Please see Exhibit B). 9. Petitioner has attempted to contact Mother's relatives in Punxsutawney, Pennsylvania, but has been able to obtain no information regarding mother's whereabouts. 10. Petitioner's income and resources are limited; Plaintiff would not be able to afford the cost of an extensive investigation by a private investigator or other professional. WHEREFORE, Plaintiff requests that this Honorable Court grant his request to serve Defendant via advertisement. (' Date: J 3.{)~~ /'" Jane V1cdams, Esquire I.D o. 79465 South Pitt St. Carlisle, Pa. 170 I 3 (717) 245-8508 ~ ~ ~ ~ \ I ~ '\ .-'l -< J ..... ~ ~ 0 " ., VJ 8 V> \~ r" n 0- '!\ ~. (/Jet; ,\J Q; .. .... .-'l rJ1 % r, 0 () fI ~ %- a " ?J, ~ " -l ;f -l .\ V> J'1', . 'D .,r, 0 , ~ '~ .' r ~ j .. :. ~ ... n"'io' ~ ,i:;;..? ::=-: t/l ('i) V> 'b. 'i>:9. -:... . p- '"d ell a ~ :~ V> ..... -l o ..... VJ , ....\ "~i m it! ;/;;I ..-r it!' .'iJ.! :t. :'t.":" ,t' ..... 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For example, check "Include nearby areas" when searching in a City, or try a Nationwide search (leave City empty). Please keep in mind: . People with unlisted numbers will not appear. . People who moved recently may not appear. First Name: Last Name: (required) !;tra~-;;tte;- Use People Pages to: . Search for people nationwide . Update your listing . Save listings to your personal address book . Get Maps and Driving Directions . Find neighbors j- Exact matches only City: jtexas city State: ITexas ._.~l Include nearby areas Find I Search Tips Reverse Lookup Plus much more! Home I My.pirE!ctory I Yellow Pages I People Pilges I City Pages I ConSlJn Eniglish I Espanol Advertise With Us I About Us / Help I Add / Change Listing I Privacy Policy I Feedback CQRyright / Wei:lSite UseAgreement I Site Index I Verizon Products / Servi<::E SuperPages t XH-fB /'{ B http://directory.superpages.comlwp/results.jsp?SRC=&PS= 15&PI= I &STYPE=WS& WF=... 4/22/2005 SuperPages.com: People Pages Search Page 2 of2 Copyright 1996 . 2005 (e) Verizon All rights resErved. http://directory.superpages.com/wp/results.jsp?SRC=&PS= I 5&PI= I &STYPE= WS& WF=... 4/22/2005 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. S4904, relating to unsworn ifalsification to authorities. iDate: 1- ~16' 0:;- ll-t- ,g ~tl R6bert J. Smith, Petitioner "tl rn -,. Z (f) -' r;:t ~?; ~~ )>~ ~ ", - ~ "y RECEIVED MAY 0 5 2005 ::Yj " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA In Re: Alexander Joseph Strawcutter Date of Birth: 5/3/01 NO. 05 - 1056 CIVIL ACTION - LAW ORDER AND NOW this b !l day of (/1.17) , 2005, it is hereby ORDERED and DECREED that Plaintiff may serve Natural Mother, Verna Strawcutter, notice ofthe hearing in the above-captioned matter by advertisement, specifically, by publishing Notice of the Hearing set by the AprilS, 2005, Court Order in a newspaper of general circulation in Texas City, Texas. W~K~ cc: ~e Adams, Esquire ~D0 O~,O c'" c-: ...:r (-.~) -!:: .) ,- C~ <..0 I .- "";'- LI":"! '. c::::::; ~:) C7.:> <..... U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA InRe: Alexander Joseph Strawcutter Date of Birth: 5/3/0 I NO. 05 - 1056 CIVIL ACTION - LA W ORDER AND NOW, this 9ili day of June, 2005, after hearing, and upon consideratio~ of the Petition to Change Name and the exhibits filed, it is hereby ordered an~ directed th~ Alexander Joseph Strawcutter shall hereafter be known as: Alexander ~oseph Smithl I J. cc: VIN'v'/\l.ASi\tnd ).lNnC)"l n"-"'~U~ii"~nCJ 9 t; :OII~l\1 6 - Nnr SOUZ AtftllOi\iOHlOCid 3Hl 30 38f:1:1o-G311.:J ------- IN RE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. ALEXANDER JOSEPH STRAWCUTTER Date of Birth: 5/3/01 CIVIL ACTION - LAW NO. 05-1056 ORDER OF COURT AND NOW, this 9th day of June, 2005, Petitioner's Exhibit 1 (Proof of Publication), Petitioner's Exhibit No.2 (Proof of Publication), Petitioner's Exhibit 3 (Custody Order), and Petitioner's Exhibit 4 (lien search), are admitted. Any other requirements as to Publication of Notice are waived. By the Court, ~Adams, Esquire South Pitt Street Carlisle, PA 17013 For the Petitioner tl/c- J esley 01 pcb ~ Wf~ o Ali<,T . .. 'i,nJ IS :6 Hd 02: llni' gun NJVJ.Oi<OHJ.OHd 3Hl :iO 38\:HO-<l3lI:J