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STACY B.WOLF,ESQUIRE 'F 1H E* P R 0 1 T H 0 T,14 0 I A t';Y
ATTORNEY ID NO.88732
10 WEST HIGH STREET 2014 FEB -4 PM 4: [ I
CARLISLE PA 17013
41-4436
ATTORNEY ICUMg£RLAND COUNT
ATTORNEY FOR PETITIONER v ���N c�r 1 J�u'!A
IN RE: : IN THE COURT OF COMMON PLEAS OF
PETITION FOR : CUMBERLAND COUNTY, PENNSYLVANIA
CHANGE OF NAME OF
COLIN A. TALBOT and : CIVIL ACTION-LAW
KATELYN R. TALBOT
NO: 2014-
PETITION FOR CHANGE OF NAME
Petitioner,Andrea L. McClure, mother, on behalf of Colin A. Talbot and Katelyn R. Talbot,by
and through her attorney, Stacy B. Wolf, Esquire, hereby presents this petition requesting that this Court
order a change of Colin A. Talbot and Katelyn R. Talbot's names,pursuant to 54 Pa. C.S. § 701 et seq.,
and in support thereof makes the following averments:
1. Petitioner,Andrea L. McClure,is the mother of two minor children,namely Colin A.
Talbot and Katelyn R. Talbot, the subject of the instant petition.
2. Petitioner has been a resident of Cumberland County continuously for the past year.
3. Colin A. Talbot was born on August 18, 2002 and Katelyn R. Talbot was born May 27,
2008.
4. During the five years preceding the filing of this petition down to and including the date
thereof, Colin A. Talbot and Katelyn R. Talbot have resided continuously at the following
location:
(a) 210 Adams Road, Carlisle, Pennsylvania—January 2008 to Present.
5. Petitioner was never married to Michael L. Talbot, the children's father, and he is not
named as father on the children's Birth Certificate.
A 1L
6. By Order of Court dated August 29, 2013, Mother has sole legal and sole physical custody
of the children.
7. Mr. Talbot has sent one recent letter and one card to Colin and one card to Katelyn but
otherwise has had no contact with the children since his incarceration in SCI Camp Hill,
SCI Pine Grove, and SCI Waymart in March, 2012.
8. Mr. Talbot has had little contact with the children due to his periods of incarceration as
follows:
a. March 7, 2002 for 7 days in Cumberland County Prison;
b. July 25, 2003 through December, 2003 in Cumberland County Prison;
c. March 28, 2004 through August 23, 2004 in Cumberland County Prison;
d. October 27,2005 for 8 days in Cumberland County Prison;
e. January 14, 2006 through June 13, 2006 in Cumberland County Prison;
f. May 29, 2008 through August 2008 in Bucks County Prison;
g. January 31,2009 through December 16, 2010 in SCI Camp Hill and SCI
Laurel Highlands;
h. December 16, 2011 through January 2012-in Cumberland County Prison;
and
i. March, 2012 through present-in SCI Camp Hill, SCI Pine Grove, and SCI
Waymart.
9. The children have no relationship with Michael L. Talbot.
10. Petitioner desires Colin A. Talbot to be known as Colin A. McClure and Katelyn R.
Talbot to be known as Katelyn R. McClure.
11. The granting of the instant relief is in the best interests of the children.
12. The granting of the instant relief would enable the children to avoid the social stigma and
unnecessary embarrassment associated with having the same name as Michael L.Talbot
who has a long history of drug usage, criminal activity, and incarceration.
13. Colin A. Talbot, age 11, desires his own name to match that of his Mother, the petitioner.
Katelyn does not understand the significance of the change because she is only 5 years
old.
14. Petitioner requests that the children's names be changed from Colin A.Talbot to Colin
A. McClure and Katelyn R. Talbot to Katelyn R. McClure.
15. The reasons for the requested change of name is the following:
(a) To provide stability, consistency, and structure to the children's lives;
(b) Michael L. Talbot sent one recent letter and one card to Colin and one card to
Katelyn but otherwise has had no contact with the children since his current
incarceration and little contact throughout the children's lives due to his repeated
periods of incarceration;
(c) This change will not effect the natural bonds between the children and Michael
Talbot; and
(d) This change would enable the children to avoid the social stigma and unnecessary
embarrassment associated with having the same name as Michael L. Talbot who has a
long history of drug usage, criminal activity, and incarceration.
WHEREFORE, Petitioner,Andrea L. McClure,respectfully prays that this Honorable Court
enter an order fixing a time for a hearing on the instant petition before this Court, no less 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 children's names to Colin A. McClure
and Katelyn R. McClure along with any additional relief that the Court may deem appropriate and just.
Respectfully submitted,
WOLF &WOLF,Attorneys at Law
Dated: —312014 BY: �
Stacy B. f, Esquire
10 West High Street
Carlisle, PA 17013
Supreme Court I.D. No. 88732
(717) 241-4436
Attorney for Plaintiff
VERIFICATION
I,Andrea L. McClure,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
unsworn falsification to authorities.
2014
And a L. Mc re
IN RE: PETITION FOR CHANGE OF
NAME OF COLIN A. TALBOT �,
and KATELYN R. TALBOT
GUMP of cumberfaub
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_Z C)z IN THE COURT OF COMMON PLEAS
�- OF THE NINTH JUDICIAL DISTRICT
2014-00672 CIVIL ACTION
ri IN RE: PETITION FOR CHANGE OF NAME
ORDER OF COURT
AND NOW, this 10th day of February 2014, upon consideration of the Petition for
Change of Name, a HEARING shall be held on 17 April 2014 at 10:30 a.m. in
Courtroom Number Six of the Cumberland County Courthouse, One Courthouse
Square, Carlisle, Pennsylvania.
At least TEN (10) DAYS prior to the hearing, NOTICE of the filing of the petition
and of the date, time, and place of the above-scheduled hearing shall be given to
Michael L. Talbot, the non-petitioning parent, and shall be published in two newspapers
of general circulation in Cumberland County or an adjoining county, one of which may
be the Cumberland County Law Journal, in accordance with 54 Pa.C.S. § 701 and
C.C.R.P. 5. Proof of publication and service to the non-petitioning parent must be filed
with the Cumberland County Prothonotary prior to the above-scheduled hearing.
BY THE CO
Thomas A. Placey C.P.J.
istribution:
Stacy B. Wolf,, Esq.
`!�l LL
�_ M
STACY B.WOLF,ESQUIRE r 1 L'C D-1 f H U k`
ATTORNEY ID NO.88732 hp T HF PRO IHONO_1Ai Y
10 WEST HIGH STREET
CARLISLE(717)2414436 17013 201' FEB 24 PM 2. 25
ATTORNEY FOR PETITIONER
ciiMBF RLAHO COUNTY
IN RE: PENNSAtitittkouRT OF COMMON PLEAS OF
PETITION FOR : CUMBERLAND COUNTY,PENNSYLVANIA
CHANGE OF NAME OF
COLIN A.TALBOT and : CIVIL ACTION—LAW
KATELYN R.TALBOT .
:NO: 2014-00672
CERTIFICATE OF SERVICE
I, Stacy B. Wolf,hereby certify that I served notice of the hearing on the petition for name
change in the above-captioned matter on the date indicated,upon the following individuals,by
United States First Class mail:
Michael L. Talbot
Inmate # HZ1728
SCI-Waymart
P.O. Box 256,Rt#6
Waymart, PA 18472
(Children's father)
(Served February 24, 2014)
WOLF %WOLF,Attorneys at _ ,w
f i
Dated: „ , 2014 By: , . _ - [,
Stacy B.Wolf, squire
Counsel for ' 'timer I
STACY B. WOLF, ESQUIRE
ATTORNEY ID NO. 88732
10 WEST HIGH STREET
CARLISLE PA 17013
(717) 241-4436
ATTORNEY FOR PETITIONER
IN RE:
PETITION FOR
CHANGE OF NAME
COLIN A. TALBOT and
KATELYN R. TALBOT
TO THE PROTHONOTARY:
: IN THE COURT OF COMMON PLEAS OF (-)
: CUMBERLAND COUNTY, PENNSYLVANIA„:.: —k
rn ,
Cr) CD
<CD -0
Cf? I
: CIVIL ACTION - LAW
: NO. 2014-00672
PRAECIPE
Kindly file the attached Proof of Publications in the above-captioned matter.
Dated: Apri
2014
By:
Respectfully submitted,
WOLF & WOLF
acy B. Esquire
10 West Hi Street
Carlisle, PA 17013
(717) 241-4436
Supreme Court I.D. No. 88732
Attorney for Petitioner
j
PROOF OF PUBLICATION
State of Pennsylvania, County of Cumberland
Patrick Doane, Production Director, of The Sentinel, of the County and State aforesaid,
being duly sworn, deposes and says that THE SENTINEL, a newspaper of general
circulation in the Borough of Carlisle, County and State aforesaid, was established
December 13th, 1881, since which date THE SENTINEL has been regularly issued in said
County, and that the printed notice or publication attached hereto is exactly the same as
was printed and published in the regular editions and issues of
THE SENTINEL on the following day(s):
March 19, 2014.
COPY OF NOTICE OF PUBLICATION
NOTICE OF NAME CHANGE
IN RE: COLIN A. TALBOT AND KATELYN R. TALBOT
Andrea L. McClure has filed a Petition to change the names of her son, Cohn
A. Talbot, to Colin A. McClure and her daughter. Katelyn R. Talbot, to
Katelyn R. McClure. The Court will hear the Petition on April 17, 2014, at
10:30 a,m., in Courtroom 6 of the Cumberland County Courthouse on
Carlisle, Pennsylvania. All interested parties may appear and show cause,
any, why the request of the Petitioner should not be granted.
Affiant further deposes that he /she is not
interested in the subject matter of the
aforesaid notice or advertisement, and that
all allegations in the foregoing statement as
to time, place and character of publication
are true..._
Sworn to and subscribed before me this
alp cayt-Alla.rth 9,04
1
tary Public
My commission expires:
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Bethany M. Holtry, Notary Public
Carlisle Boro, Cumberland County
My Commission Expires Sept. 26, 2015
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND.
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
Viz
March 28, 2014
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
sa Marie Coyne, E. for
TO AND SUBSCRIBED before me this
28 day of March, 2014
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
IONINEINIMIONOW
CUMBERLAND LAW JOURNAL
NOTICE OF NAME CHANGE
IN RE: COLIN A. TALBOT AND
KATELYN R. TALBOT
Andrea L. McClure has filed a Peti-
tion to change the names of her son,
Colin A. Talbot to Colin A. McClure
and her daughter Katelyn R. Talbot
to Katelyn R. McClure. The Court will
hear the Petition on April 17, 2014
at 10:30 a.m., in Courtroom 6 of the
Cumberland County Courthouse in
Carlisle, Pennsylvania. All interested
parties may appear and show cause,
if any, why the request of the Peti-
tioner should not be granted.
Mar. 28
6
IN RE: : IN THE COURT OF COMMON PLEAS OF
PETITION FOR : CUMBERLAND COUNTY, PENNSYLVANIA
CHANGE OF NAME OF
COLIN A. TALBOT and : CIVIL ACTION — LAW
KATELYN R. TALBOT
: NO: 2014 -00672
AND NOW, this I * day of
ORDER
v't
, 2014, upon consideration of the attached
petition of Andrea L. McClure for change of name, after hearing, 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 Colin A. Talbot is changed to Colin A.
McClure and the name of Katelyn R. Talbot is changed to Katelyn R. McClure.
By tht C urt:
tes d e(ve/
070
(9 (
Thomas A. Placey,