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Home My WebLink About14-0987 Pamela L. Purdy Attorney ID No. 85783 Allison C. Gossett Attorney ID No. 314900 Law Office of Pamela L. Purdy, LLC 1820 Linglestown Road Harrisburg, PA 17110 (717) 221-8303 (717) 221-8403 facsimile plpurdy @verizon.net Attorney for Petitioner IN RE PETITION FOR NAME CHANGE IN THE COURT OF COMMON PLEAS BY DANIELLE MARIE PANIKIEWSKY CUMBERLAND COUNTY PENNSYLVANIA ON BEHALF OF HER MINOR Q DAUGHTER, ADDISON MARIE AYALA NO. �� CIVIL ACTION-LAW PETITION FOR NAME CHANGE 1. Petitioner is Danielle M. Panikiewsky, the natural mother of Addison Marie Ayala, a four year old minor who was born on March 1, 2009. 2. The natural father of the child is Robert Ayala, Jr., whose last known residence or mailing address is unknown. 3. Petitioner currently resides at 345 Timber Road, New Cumberland, Cumberland County, Pennsylvania, 17070. 5. The Petitioner desires to change her child's name from Addison Marie Ayala to Addison Marie Panikiewsky. p, 6. The Petitioner's reasons for desiring this change of name of her child are that: (a) Petitioner has at all times since the child's birth been the child's sole caregiver and provider; (b) Respondent has not seen or contacted the child for two years, and in the past, visited the child infrequently and was prone to long periods of absence; (c) The minor child believes that her name is Addison Marie Panikiewsky; and (d) The minor child's relationship with Respondent is almost non- existent, while the child shares a close relationship with Petitioner. 5. The child has lived at the following addresses in the last five years: Address Dates 2010 Bayhead Drive Birth — May 2010 Parlin, NJ 08859 6803 Clubhouse Drive, Apt. K May 2010-July 2011 Harrisburg, PA 17111 345 Timber Road July 2011-Present New Cumberland, PA 17070 6. Petitioner requests this Court: (a) to fix a hearing on this petition; and, (b) to direct that notice be given of the filing of this petition and the hearing. 7. Petitioner further requests this Court to waive the requirement for official searches of the proper offices of the county wherein Petitioner resides on the grounds that the subject of this petition is a minor and avers that there are no judgments or decrees of record or any other matter of like character against her. Respectfully submitted, A44 A ij J -�2 - OCS I PI,*,Vr Pamela L. Purdy Attorney for Petitioner Dated: /N VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. fib P'O ak'idl I 'Danielle M. Panikiewsky Dated: d I i I i I I A CERTIFICATE OF SERVICE The undersigned certifies that on this 19th day of February, 2014, a true and correct copy of the foregoing Petition for Name Change shall be served by publication, upon approval by the Court, upon the following: Robert Ayala, Jr. (DOB: 09/20/1978) Heat er J. Auten alegal Law Office of Parreln. Purdy, LLC T! fD PENN'S YINACNU141TY /A Pamela L. Purdy Attorney ID No. 85783 Allison C. Gossett Attorney ID No. 314900 Law Office of Pamela L. Purdy, LLC 1820 Linglestown Road Harrisburg, PA 17110 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Petitioner IN RE PETITION FOR NAME CHANGE IN THE COURT OF COMMON PLEAS BY DANIELLE MARIE PANIKIEWSKY CUMBERLAND COUNTY, P NNSYLVANIA ON BEHALF OF HER MINOR tj_,.I DAUGHTER, ADDISON MARIE AYALA NO. CIVIL ACTION-LAW PETITION FOR LEAVE TO SERVE BY PUBLICATION PURSUANT TO PA.R.C.P. 430 AND NOW, comes Petitioner, Danielle Marie Panikiewsky, by and through her counsel, the Law Office of Pamela L. Purdy, LLC, and files this Petition for Leave to Serve by Publication Pursuant to Pa.R.C.P. 430, and in support thereof avers the following: 1. Petitioner is Danielle Marie Panikiewsky, an adult individual who currently resides at 345 Timber Road, New Cumberland, Cumberland County, Pennsylvania, 17070. 2. Respondent is Robert Ayala, Jr., who currently resides at an unknown location. 3. Petitioner is filing simultaneous with the filing of this Petition, a Petition for Name Change, on behalf of her minor daughter, Addison Marie Ayala. 4. 54 Pa.C.S.A. § 701(a.1)(3)(ii) requires that notice of a petition for name change be given to any non-petitioning parent whose minor child will be affected by the name change. 5. Petitioner has not seen our spoken to Respondent in more than two years, and does not have a current address or telephone number for Respondent. 6. Further, Petitioner's address and place of employment, where Respondent would customarily reach her, have not changed in the last two years. 6. After reasonable investigation Petitioner is unable to locate a functioning telephone number or residence for Respondent. A true and correct copy of Petitioner's Affidavit setting forth the good faith effort she has made to locate Respondent is attached hereto, made a part hereof, and marked as Exhibit "A". 7. Pa. R.C.P. 430 states that, "If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service." 8. This matter has not previously been assigned to a Judge. 9. As Petitioner cannot locate Respondent, it is unknown whether he concurs in Petitioner's request. WHEREFORE, Petitioner, Danielle Marie Panikiewsky, respectfully requests this Honorable Court grant her leave to serve her Petition for Name Change, and all subsequent Orders and Notices issued by the Court, upon Respondent via publication. Respectfully submitted, Date: a amela L. Purdy, Cou 6 for Petitioner i VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Danielle M. Panikiewsky Dated; I I i I I I I I I i I i IN RE PETITION FOR NAME CHANGE IN THE COURT OF COMMON PLEAS BY DANIELLE MARIE PANIKIEWSKY CUMBERLAND COUNTY, PENNSYLVANIA ON BEHALF OF HER MINOR DAUGHTER, ADDISON MARIE AYALA NO. CIVIL ACTION-LAW .AFFIDAVIT OF PETITIONER,, DAN*LLE PANIKIEWSKY I I, Danielle Marie Panikiewsky, hereby certify that I have made the following unsuccessful inquiries, through my counsel, in an effort to locate Respondent, Robert Ayala, Jr.: 1. Sent a request for Respondent's last known address or forwarding address, pursuant to the Freedom of Information Act, to the United States Postal Service at 1425 Crooked Hill Road, Harrisburg, PA, 17107; 2. Searched the White Pages for a valid telephone number or address for Respondent; 3. Searched for Respondent in the Pennsylvania Voter Records; and 4. Searched for criminal, traffic, and non-traffic records regarding Respondent in the Pennsylvania Unified Judicial System database and the New Jersey Department of Corrections database. /t 6Wb Q� Date: ( I Danielle Marie Panikiewsky j 345 Timber Road New Cumberland, PA 17070 i i i E HIBIT II s CERTIFICATE OF SERVICE The undersigned certifies that on this 19th day of February, 2014, a true and correct copy of the foregoing Petition for Leave to Serve by Publication Pursuant to PA.R.C.P. 430 shall be served by publication, upon approval by the Court, upon the following: Robert Ayala, Jr. (DOB: 09/20/1978) (ORR. Heather J. Auten, aralega Law Office of P e a L. Purdy, LLC IN RE: PETITION FOR NAME CHANGE BY DANIELLE r ` MARIE PANIKIEWSKY ON BEHALF OF HER MINOR DAUGHTER;"ADDIS;ONMARIE AYALA ¢onnt <ot�um6erlana IN THE COURT OF,COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT 14'--0087 CIVI'L-ACTION IN RE: PETITION FOR NAME CHANGE ORDER OF COURT t 4 AND NOW, this 26th day of February,2013, upon consideration of the Petition for t� Change of Name, a HEARING shall be held on 17 April 2014 at 11:30 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 Robert Ayala, Jr.,, 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 must be filed with the Cumberland County Prothonotary prior to the above-scheduled hearing. BY THE COURT, VINVAIXSSNN34 X11103 m838WR Thomas A. lacey C.P.J. Distribution: Pamela L. Purdy, E@$ :C Wd 9Z 83J 118Z Robert Ayala, Jr. p, t iO(?GNOH id 3H.I. �l t X31-1,-0-03ii IN RE PETITION FOR NAME IN THE,COURT OF COMMON PLEAS CHANGE BY DANIELLE MARIE CUMBERLAND COUNTY PENNSYLVANIA .. PANIKIEWSKY ON BEHALF OF HER MINOR DAUGHTER, NO. ryLI �� C( V l ADDISON MARIE AYALA CIVIL ACTION-LAW DECRE1UF COURT FIXING HEARING 1. A hearing on the petition of Danielle Marie Panikiewsky on behalf of her. minor daughter, Addison Marie Ayala,.for change of name is fixed for at m. at Courtroom , Cumberland County Courthouse, Carlisle, Pennsylvania. 2. The petitioner is directed to give notice of the hearing by publication in two newspapers of general circulation in Cumberland County, Pennsylvania, one of which publications should be the official paper for the publication of legal notices in that county. BY THE COURT: J. Date: Distribution: Pamela L. Purdy, Esq., 1820 Linglestown Road, Harrisburg, PA 17110 Robert Ayala, Jr., via publication IN RE: PETITION FOR NAME CHANGE BY DANIELLE MARIE PANIKIEWSKY ON ♦'� �� BEHALF OF HER MINOR DAUGHTER, ADDISON MARIE AYALA QCouutp of Cum@erfana IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT 14-0987 CIVIL ACTION IN RE: PETITION FOR LEAVE TO SERVE BY PUBLICATION PURSUANT TO PA.R.C.P. 430 ORDER OF COURT AND NOW, this 2�day of February 2013, upon consideration of the Petitioner's Petition for Leave to Serve By Publication Pursuant to Pa.R.C.P. 430, the Petition is GRANTED. Pursuant to Pa.R.C.P. 430(a), following Petitioner's described efforts to locate and serve the Respondent, Petitioner is permitted to effectuate service upon Respondent by publication. Petitioner SHALL advertise a notice of the action once in the legal publication of the county in which Respondent was last known to reside and once in a newspaper of general circulation within said county. The publication shall contain the caption of the action and names of the parties, state the nature of the action, and include a notice to defend as prescribed in Pa.R.C.P. 430(b)(1). Bi€-GOB , VINVA IASNN3d 1l1N13D3 0N.Vi83.eWfl3 Thomas A. Placey C.P.J. Distribution: I S' ,£ ��d �� Pamela L. Purdy, Esq. 1`.�;t`10t40 i0dd 31-1! _I;� Law Office of Pamela. L. Purdy, LLC Pamela L. Purdy Attorney ID No. 85783 Allison C. Gossett Attorney ID No. 314900 1820 Linglestown Rd., Harrisburg, PA 17110 Tel. (717) 221 -8303; Fax (717) 221 -8403 plpurdy @purdylawoffice.com allison @pu rdylawoffice. com Attorney for Petitioner IN RE PETITION FOR NAME CHANGE : BY DANIELLE MARIE PANIKIEWSKY : ON BEHALF OF HER MINOR DAUGHTER, ADDISON MARIE AYALA : Ua.1 APR —I AM 10 :47 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 14 -987 PRAECIPE TO FILE PROOF OF NOTICE OF PUBLICATION IN DAUPHIN COUNTY REPORTER TO THE PROTHONOTARY: Please file the enclosed Proof of Notice of Publication in Dauphin County Reporter in the above - captioned matter. Date: 31.2111y Respectfully submitted, Pamela L. Purdy Counsel for Defendant Proof of Notice of Publication in Dauphin County Reporter 213 North Front Street, Harrisburg, PA 17101 Under Acts approved May 16, 1929, P.L. 1784 and April 24, 1931, P.L. 67, 45 P.S. 1 et seq. State of Pennsylvania County of Dauphin ss: Elizabeth G. Simcox, agent of the Publisher of the Dauphin County Reporter, of the County and State aforesaid, being duly sworn, deposes and says that the Dauphin County Reporter, a legal periodical published in the City of Harrisburg, County and State aforesaid, was established January 1, 1898, and designated the Legal Periodical for Dauphin County, on February 5,1919, since which date the Dauphin County Reporter has been regularly issued in said County, and that the printed notice of publication attached hereto is exactly the same as was printed and published in the regular editions and issues of the Dauphin County Reporter on the following dates, viz: March 28, 2014 Affiant further deposes that she is the Agent of the Publisher of the Dauphin County Reporter, a legal Periodical of general circulation, to verify the foregoing statement under oath, and that neither the affiant nor the Dauphin County Reporter is 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. Co,5 Sworn to and subscribed before me this 28th day of March, 2014 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Joyce A. Tambolas, Notary Public City of Harrisburg, Dauphin County My Commission Expires Oct. 5, 2016 Statement of Advertising Costs: Name Change: Addison Marie Ayala to Addison Marie Panikiewsky For publishing the notice or publication attached hereto on the above stated dates Probating Same Total $ 117.50 $ 5.00 $ 122.50 Publisher's Receipt for Advertising Costs The Dauphin County Reporter, a legal periodical, hereby acknowledges receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid DAUPHIN COUNTY REPORTER, BY: ORIGINAL Copy of Notice of Publication COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: PETITION FOR NAME CHANGE BY DANIELLE MARIE PANIKIEWSKY ON BEHALF OF HER MINOR DAUGHTER, ADDISON MARIE AYALA NOTICE IS HEREBY GIVEN that on February 20, 2014, the Petition of DANIELLE PANIKIEWSKY on behalf of her minor daughter, Addison Marie Ayala, was filed in the above -named court, requesting a decree to change her name from Addison Marie Ayala to Addison Marie Panikiewsky, The Court has fixed April 17, 2014 at 11:30 a.m. in Courtroom #6, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA as the time and place for the hearing on said Petition, when and where all persons interested may appear and show cause if any they have, why the prayer of the said Petition should not be granted. NOTICE If you wish to defend, you must enter a written appearance personally or by attorney and file your defenses or objections in writing with the court. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you without further notice for the relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717 - 249 -3166 m28 Law Office of Pamela L. Purdy, LLC Pamela L. Purdy Attorney ID No. 85783 Allison C. Gossett Attorney ID No. 314900 1820 Linglestown Rd., Harrisburg, PA 17110 Tel. (717) 221-8303; Fax (717) 221-8403 plpurdy@purdylawoffice.com allison@purdylawoffice.com Attorney for Petitioner IN RE PETITION FOR NAME CHANGE BY DANIELLE MARIE PANIKIEWSKY ON BEHALF OF HER MINOR DAUGHTER, ADDISON MARIE AYALA fiFFIC;E 113N 0 TA ; 2011; -8 4111: 14 9 CUMBERLAND COUNTY PENNSYLVANIA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-987 PRAECIPE TO FILE PROOF OF NOTICE OF PUBLICATION IN THE PAXTON HERALD TO THE PROTHONOTARY: Please file the enclosed Proof of Notice of Publication in the Paxton Herald in the above-captioned matter. Date: Respectfully submitted, amela L. Purdy Counsel for Defendant 4- ' • THE PAXTON HERALD Fax (717) 657 -3523 STATE OF PENNSYLVANIA COUNTY OF DAUPHIN 1M Po91on 149m141• 4910 Eof 0riw,1100191909, M17112. 0434/540 Office & Plant - (PO Box 6310) 101 Lincoln Street Harrisburg, PA 17112 PROOF OF PUBLICATION Before me, the subscriber, a Notary Public in and for the said County, personally came Lisa M. Carnes who, being duly sworn, doth depose and say that she is CLERK of THE PAXTON HERALD, a newspaper of general circulation published in Harrisburg, Pennsylvania; That THE PAXTON HERALD was established on the 28th day of June, 1960, and has been published continuously since that date; That the advertisement, of which a copy is attached hereto, was published in the advertising columns of THE PAXTON HERALD in all respects as ordered in the issue(s) of 3- Affiant further deposes that she is not interested in the subject matter of the aforesaid notice or advertisement, and that the allegations in the foregoing statement as to the time, place and character of publication are true. Sworn and subscribed before me this day of otary Pub c A.D. O OF PENNSYLVANIA_ NOTARIAL SEAL DAVID M. GOLDSTEIN, Notary Public City of Harrisburg, Dauphin County My Commission Expires May 26, 2014 East Shore (717) 545 -9540 (717) 545 -8762 NOTICE OF PETITION FOR NAME CHANGE ' Court of Common Pleas of Cumberland County, Pennsylvania IN RE: PE I I i ION FOR NAME CHANGE BY DANIELLE MARIE PANIKIEWSKY ON BEHALF OF HER MINOR DAUGHTER, ADDISON MARIE AYALA NOTICE IS HEREBY GIVEN that on February 20, 2014, the Petition of Danielle Panikiewsky on behalf of her minor daughter, Addison Marie Ayala, was filed in the above -named court, request- ing a decree to change her name from Addison Marie Ayala to Addison Marie Panikiewsky. The Court has fixed April 17, 2014'at 11:30 a.m. in Court- room #6, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA as the time and place for the hearin on said Petition, when an where all persons interested may appear and show cause if ' any they have, why the prayer of the said Petition should not be granted. NOTICE If you wish to defend, you must enter a written appear- ance personalty or by attorney and file your defenses or ob- jections in writing with the court. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you without further notice for the relief requested by the plaintiff. You may lose money or property or other rights im SHOULD you. TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELE- PHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH IN- FORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717 - 249 -3166 3-26 IN RE PETITION FOR NAME CHANGE BY DANIELLE MARIE PANIKIEWSKY ON BEHALF OF HER MINOR DAUGHTER, ADDISON MARIE AYALA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 14 -. 00, CIVIL ACTION -LAW ORDER OF COURT CHANGING NAME Upon consideration of the attached petition and after hearing, it is found as a fact that the requirements of 54 Pa.C.S. § 701 have been satisfied and the name of Addison Marie Ayala is changed to Addison Marie Panikiewsky. Date: Distribution: Pamela L. Purdy, Esq., 1820 Linglestown Road, Harrisburg, PA 17110 ` Qziixr Wild Robert Ayala, Jr. via publication