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HomeMy WebLinkAbout05-1953 INRE: LACY MAY JEAN GRUMBIANIN : IN THE COURT OF COMMON PLEAS F : CUMBERLAND COUNTY, PENNSYL NIA : CIVIL ACTION - LAW : NAME CHANGE : ()5/- /153 : NO. CIVIL TERM PETITION FOR NAME CHANGE PURSUANT TO 54 Pa. C. S. !l701 The Petitioner, Penny J. Geedy, by her attorneys, the Family Law Clinic, hereby p titions the Court to enter a decree changing her minor daughter's name from Lacy May Jean Grumbianin to Lacy May Jean Geedy, and respectfully represents that: 1. The Petitioner is Penny J. Geedy, who resides at 4420 Gettysburg Road, Apt. 2 Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Petitioner is the biological mother of Lacy May Jean Grumbianin (hereafter "ch Id"), born on April 29, 2000, in Harrisburg, Dauphin County, Pennsylvania. A true copy ofthe child's birth certificatl" is attached as Exhibit "A" and is incorporated herein by reference. 3. The child's Social Security number is 206-78-8646. 4. The child's father is Thomas Baughman ("father"), who resides at 503 Pisgah R ad, Shermans Dale, Perry County, P A, 17090. 5. Petitioner was never married to the child's father. 8. Petitioner avers that it is in the best interest ofthe child to have her name change Lacy May Jean Geedy, because: a) Mother named the child Lacy May Jean Grumbianin due to her relationship with Richard Grumbianin; however, Mr. Richard Grumbianin is not the child's biological father. b) Mr. Richard Grumbianin has no legal or biological relationship to this child. c) The child's parents agreed upon a custody arrangement, entered as an Order 0 Court, dated November 12, 2004. A copy of the Order is attached as Exhibit "B." d) Petitioner has sole legal custody and primary physical custody of the child p uant to an Order of Court. e) The child will reach school age shortly and the Petitioner desires to protect the child from the psychological and emotional confusion which may result from the child and par nt having two different surnames, and having a surname of a person with whom she has no biological relationship. f) Father has rarely contributed to the child's financial support. g) Petitioner and the child's father have never been married. h) Since the child's birth, Petitioner and the child have lived at their current addres , 4420 Gettysburg Road, Apt. 2, Camp Hill, Pennsylvania. i) The child has never resided with father. j) Father has consented to the change the child's name from Lacy May Jean Grum ianin to Lacy May Jean Geedy. Father's consent is attached hereto. 9. There are no judgments, liens, decrees or the like against Lacy May Jean Grumb anin or Lacy May Jean Geedy. WHEREFORE Petitioner prays that the Court: a) Set a time and place for a hearing on the above-captioned matter; b) Direct Petitioner to serve this Petition and the attached Order on Mr. Tho as Baughman, the biological father of the child, via United States mail, certified, restricted deli ery, return receipt requested, postage prepaid and by regular first class mail; and on Mr. Richard Grumbianin via United States mail, certified, restricted delivery, return rece c) Direct that notice in the form set forth in Exhibit "C", attached hereto, e requested, postage prepaid and by regular first class mail. published of the filing of this petition and of any hearing once in the Carlisle Sentinel and once in the Cumberland Law Journal; d) After said hearing, enter an Order changing the name of Lacy May Je Grumbianin to Lacy May Jean Geedy; and e) Grant such other relief as may be just. Date:~ -'v(~f <----- CHARLE . A . VILlNA Certified Legal Intern 1/ ~f2zdL- THOMAS . PLACE ANNE MACDONALD-FOX ROBERT E. RAINS LUCY JOHNSTON-WALSH Supervising Attorneys F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 VERIFICATION I hereby verify that the statements made in the foregoing Petition for Name Chang are true and correct, to the best of my knowledge, information and belief. I understand that m mg a false statement would subject me to the penalties of 18 Pa.C.S. Section 4904, relating to un worn falsification to authorities. Penny 1. Geedy Date: ~ - L\ - 0 5 INRE: LACY MAY JEAN GRUMBIANIN : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V NIA : CIVIL ACTION - LAW : NAME CHANGE : NO. CIVIL TERM CONSENT TO NAME CHANGE I, Thomas Baughman, do hereby state the following: I. I am the father of Lacy May Jean Grumbianin. 2. I understand that Penny J. Geedy wishes to change our daughter's n me from Lacy May Jean Grumbianin to Lacy May Jean Geedy. 3. I consent to the name change of Lacy May Jean Grumbianin to Lac May Jean Geedy. 4. I verify that I have been advised that if! have any questions, I shoul consult my own attorney. 5. I verify that the statements made herein are true and correct to the be t of my knowledge. 6. I understand that false statements herein are made subject to the pen lties Date: ;1. -;1, 5- 0 ( ~~ of 18 Pa.C.S. S 4904, relating to unsworn falsification to authorities. Thomas Baughman ~ DATE OF 04- Hl -2 0 00 BIRTH 0~-19-2000 COUNTY OF BIRTH ;; , , DAUPHIN NAME LACY MAY .(<" FATHERS NAME tNfORMAT;J:QN 1'-', MOTHERS MAl J~~ii~Al'lE PENNY JEAN lWEYl1.N'li / . ',,"-. "",.~ "<,~,l.,> ..,'\ '~ ~1,,:'~' '" 'I l ~~ 'i', , '\ ,R', ,~,:" '1 ;:.~{~'~:~-,-,,::'-~> ,,,,~},,!"):~_.! ';,.l"",..,,~ ",." ", ' ,t'< '",..>-"~,r- '~ ,', .<;-:- ~,~ _'\,i! This is to iJermy lhat this is. 3 true oopy on~e record whicl1i.t~n'liie in lhePIiMsylvil.iiiaDe~rtf(1ertof l1e.ilth, l in accOrdance with AcI 66, P.l304, approved by the General Assembly June 29, i953 ~, ~ ~~\ Cal'llnB, John$or1,M.D" MP.H. Secn~tary afHealth , ..... EXHIBIT I A ~\IO\l I q 7\\0/( E S . Of PENNY J, GEEDY, Plaintiff v. THOMAS BAUGHMAN, Defendant NOli l 0 IDOl; IN THE COURT OF COMMON PLE S OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY NO, 04- 51e~1 CIVIL TERM ORDER AND NOW, this 11th day of November, 2004, the attached Custody Agreement is approved and entered as an Order of Court, EXHIBIT 'I B :8 s BY THE COURT, /sJJ -j, Cold ([1,,), J, . . . PENNY 1. GEEDY, Plaintiff IN THE COURT OF COMMON PLEA OF CUMBERLAND COUNTY, PENNSYLVANIA v, THOMAS BAUGHMAN, Defendant CIVIL ACTION - LAW IN CUSTODY NO. 04- CIVIL TERM CUSTODY AGREEMENT THE FOLLOWING AGREEMENT, made this <6~~ day of November, 20 between Plaintiff, Penny J. Geedy (Mother), and Defendant, Thomas Baughman (Fat er), concerns the custody of their child, Lacy May Jean Grumbianin (Child), born April 2 , 2000, Mother and Father agree to the following: 1. Mother shall have sole legal custody of the Child, 2, Mother shall have primary physical custody of the Child. 3, Father shall have periods of partial physical custody of the Child as determined by the mutual agreement of the parties. 4, In the event of an emergency, both parties shall allow reasonable telephone communicaiion with the child during the other parent's custodial visits. Such phone c lis shall not be excessive and shall only be out of necessity, 5, Mother shall keep Father informed of the Child's dietary and medical need. 6, Neither parent shall do anything which may estrange the Child from the ot r party, or injure the opinion of the child as to the other parent, or which may hamper th free and natural development of the child's love and respect for the other parent. 7, Mother and Father desire to make this agreement a Court Order. C) -" r-.) en l,.C) .. ;' - . 8, The Father understands that the Family Law Clinic represents only the Mother's interest in this matter and he may seek the advice oflegal counsel ifhe so desires. "4 \\-Id-ol{ Date %~07 , //- Date CfuJ~~. ~~ CHARLEN 1, A . lUNA Certified Legal Intern ,) ?:11.)-C LU JO STON- WALSH RO RT E, RAINS THOMAS M. PLACE ANNE MACDONALD-FOX Supervising Staff Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 Counsel for Plaintiff NAME CHANGE NOTICE NOTICE IS HEREBY GIVEN that a Petition for Name Change pursuant to 54 Pa.C S. S701 et seq. has been filed on behalf of Lacy May Jean Grumbianin and a hearing on the Pe ition of Lacy May Jean Grumbianin to change her name to Lacy May Jean Geedy will be held 0 at ,m, in Courtroom number _, Cumberland Co ty Courthouse, Carlisle, Pennsylvania. Any and all interested parties may appear and show ca se, if any, why the request of the Petitioner should not be granted, FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PAl 70 I 3 (717) 243-2968 EXHIBIT j ~ ~\ '1t ~ o C) C' '" C'_~ c:...> C,..., o -n ::;:-.1 i:;~l ;I: -;-"In, :,;CJ L; - '. ........"" ;:-"'t -,,~> CJ 7'""" .c- -6~- PENNY j, GEEDY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW : NAME CHANGE THOMAS BAUGHMAN, Defendant : NO, (Il,_ /qc:::..? CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Penny J. Geedy, Plaintiff, to proceed in forma pauperis. I, Charlene J, Aquilina, of the Family Law Clinic, Certified Legal Intern, for party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs a that I am providing free legal service to the party. , Date:~ {'I \~J7\,C\' ,.,\t\;'Ij\,.:~'v CHARLE J, UILINA Certified Legal Intern ~~~ Ie ".(L- THOM . PLACE .. LUCY JOHNSTON-WALSH ROBERT E, RAINS ANNE MACDONALD-FOX Supervising Attorneys THE F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Attorneys for Plaintiff ...., ~:-;:) D~ ~.:~ o -,-j ---< :~;j is] ;_~Sl~; ',;~() :-~'-~ f9, :~g' .,<.:: ;::~} co u; IN RE: LACY MAY JEAN GRUMBIANIN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 05-1953 CIVIL TERM ORDER OF COURT AND NOW, this 22nd day of April, 2005, upon consideration of the attached Petition for Name Change Pursuant to 54 Pa. C.S. 9701, a hearing is scheduled for Wednesday, June 22, 2005, at 1:30 p.rn" in Courtroorn No, I, Cumberland County Courthouse, Carlisle, Pennsylvania. IT IS FURTHER ORDERED that notice of the filing of said Petition and the aforesaid date, tirne and place of the hearing be published once in the Cumberland Law Journal and a newspaper of general circulation in the County at least 10 days prior to the hearing; in addition, Petitioner shall cornpIy with all other requirernents of C.C.R.P. 5, and the Act of Decernber 16,1982, P.L. 1309,96 (see 54 Pa. C.S, 9701 [Historical and Statutory Notes] [Main Volume)), and 54 Pa. C.S. 99701 et seq. PLAINTIFF IS directed to serve this order and attached petition on Mr. Thomas Baughman and Mr. Richard Grumbianin via United States Mail, certified, restricted delivery, return receipt requested, postage prepaid and by regular first class rnail. BY THE COURT, Thomas M. Place, Esq. Anne MacDonald-Fox, Esq. Robert E. Rains, Esq. Lucy Johnston-Walsh, Esq. Charlene J, Aquilina, Certified Legal Intern Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 Attorneys for Petitioner ! ~f : II! !'~ S~~ (:dr) SG;JZ IN RE: LACY MAY JEANGRUMBIANIN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO, 05-1953 CIVIL TERM ORDER OF COURT AND NOW, this 22nd day of April, 2005, upon consideration of the attached Petition for Narne Change Pursuant to 54 Pa. C.S. 9701, a hearing is scheduled for Wednesday, June 22, 2005, at 1:30 p.m" in Courtroorn No.1, Cumberland County Courthouse, Carlisle, Pennsylvania. IT IS FURTHER ORDERED that notice of the filing of said Petition and the aforesaid date, time and place of the hearing be published once in the Cumberland Law Journal and a newspaper of general circulation in the County at least 10 days prior to the hearing; in addition, Petitioner shall comply with all other requirernents 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 Volume]), and 54 Pa. C.S. 99701 et seq. PLAINTIFF IS directed to serve this order and attached petition on Mr. Thornas Baughman and Mr. Richard Grumbianin via United States Mail, certified, restricted delivery, return receipt requested, postage prepaid and by regular first class mail. BY THE COURT, Thornas M. Place, Esq. Anne MacDonald-Fox, Esq. Robert E. Rains, Esq. Lucy Johnston-Walsh, Esq. Charlene J. Aquilina, Certified Legal Intern Farnily Law Clinic 45 North Pitt Street Carlisle, P A 170 I 3 Attorneys for Petitioner ~/~fle,- ~ . , ~V"L .~Ii -~..----.J ~ tVd..4-/ ~~ ;t-LCl;h f':'< tt:J f!rf...,. ! II . 1 ! ~ 1',' ~. . J :' 'i 1"\ ) \ f ".1 " ~. . :~ -' }' d, ~'; "-1" -v '~'.J.' ..0t& .:-JJ INRE: LACY MAY JEAN GRUMBIANIN : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NAME CHANGE : NO, 05-1953 CIVIL TERM VERIFICATION OF SERVICE I, Jeffrey G. Stovall, hereby verify that I am a competent adult and that I served a true and correct copy ofthe above captioned Petition for Change of Name Pursuant to 54 Pa. C.S. 9 701 et seq. and an accompanying Order of Court on Richard Grumbianin, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid and by regular first class mail, on the 20th Day of May, 2005 addressed as follows: Richard Grumbianin 4420 Gettysburg Road Apt. I Camp Hill, PA 17011 Sender's receipt no, 7005 03900003 26324983 is attached hereto and incorporated by reference. On the 24th day of May, 2005, return receipt number 7005 03900003 26324983 was delivered to the Family Law Clinic, bearing the signature of Richard Grumbianin and showing a date of service of May 21, 2005. Return receipt number 7005 039000032632 4983 is attached hereto and incorporated by reference. I understand that making any false statement would subject the Family Law Clinic to penalties under 18 Pa. C.S. 94904 (relating to uns orn falsification to authorities). -' Dated: \ )LM' ILf; ~5 - FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, P A 17013 717-243-2968 (~ ,..., 0 .~ => ,. t~ 'Tl c.n '- ..... :I: f;; n1:D .- -.,m .c- C:Jcr S'.~C) -0 {5~~ =-c: w c3rn --I t.) :~5 -< "AoaoMdI>l'(-~ D."~____1? IIY1i111,_~_boIOw: J i" ~,~' ~\., ,~~ noli --1W>o 'II CeIlIIIod _ [J I!lcp-. _ o R4IIA\...,.d "II Retuin Receipt for Merchandise [J _ _ [J C.O.D. 4. __ Doll-Y/ (EJdnJ Foe) l:!rYes 2. __ 7~ P39.o ~0<>3 ~4.3-j;>.. 4<?8'3 ~from__1IlbeI) PS Fonn 3811, FOIbI'IMry 201M _ _.... .-.'''''... """'.'. INRE: LACY MAY JEAN GRUMBIANIN : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NAME CHANGE : NO. 05-1953 CIVIL TERM VERIFICATlON OF SERVICE I, Jeffrey G, Stovall, hereby verifY that I am a competent adult and that I served a true and correct copy of the above captioned Petition for Change of Name Pursuant to 54 Pa, C.S. S 701 et seq. and an accompanying Order of Court on Thomas Baughman, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid and by regular first class mail, on the 20th Day of May, 2005 addressed as follows: Thomas Baughman 503 Pisgah Road Shermans Dale, P A 17090 Sender's receipt no. 7005 0390000326324990 is attached hereto and incorporated by reference. On the 31 st day of May, 2005, return receipt number 7005 0390 0003 2632 4990 was delivered to the Family Law Clinic, bearing the signature of Thomas Baughman and showing a date of service of May 26, 2005, Return receipt number 7005 0390 00032632 4990 is attached hereto and incorporated by reference. I understand that making any false statement would subject the Family Law Clinic to penalties under 18 Pa, C.S. S4904 (relating to unsworn falsification to authorities). ~ - III Dated: J-"" / loz,S- FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 i /" ..1. riN _; . CoinpIoee 1lemI1. W Item 4W .... k*d DIIivlIIY fa dIIInId. . Prtnl \IOlH' _ _1IddI-. on the__ 80 __ can NIum the C8Id to you. . Attach thIa C8Id to the beck of the ,,18IlPIeCe, or on.the front W lIPlIl* ~ 1,__10: 7!'tn??4.s. ~~ 5<!:13 1&-~rJu I?.-d. SIuwn"'-'~11""'/70~ 3._""" <<0eftIlIId MIll 0 expr.a MIll o ~Isl"od 17-.m ~ for _I.. 0__ CC,O.D. 4, R8I1r1c1ed DoIlv8ry7 (CxtnIFeeJ ~~....- ~f1~ .;, J&V.. 2. ArtlcleNu_ ?oo.,s- 0390 0003 (7Iansfer from._1ol>oIJ PSFonn3811.~_ ~--- 102595-02-M-1540 : """"~~ ~,,<::~-,,,"' ...., ~ = c..-:::'l CJ' (..... --l c: :C.,., -...,,, nip L"~^_ -om ,$:"' ;!:JC? , ,:_~:3C) , {~~~ --0 ::L C:? 81 (.) ?J.; 0 .< IN RE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT", PENNSYLVANIA CIVIL ACTION - Ll',W NO. 05-1953 CIVIL TERM LACY MAY JEAN GRUMBIANIN ORDER OF COURT AND NOW, this 22nd day of June, 2005, upon consideration of the Petition for Name Change Pursuant to 54 Pa. C.S. Section 701 in the matter of Lacy May ~Tean Grumbianin, and following a hearing at which evidence was presented in support of the position of the Petitioner, Penny J. Geedy, and at which no person offered objection to the request of t:he petition, the Petition for Name Change is granted, and hereafter Lacy May Jean Grumbianin shall be known by the name of Lacy May Jean Geedy. By the Court, ~ J. Jeffrey G. Stovall, Certified gal Intern ~y Johnston-Walsh, Supervising Attorney ~~mily Law Clinic 45 North Pitt Street Carlisle, PA 17013 For the Petitio er pcb \iil\)\/,\l/,S;\)j' {Jd ,,-LNt~r(} ":Y'Jn8 'J fit I lid 8- lnnnOl AUVIOI\!O:-UOUd 3HldO 3810:10-0311:1 ,. , , IN RE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - L!\W NO. 05-1953 CIVIL TERM LACY MAY JEAN GRUMBIANIN ORDER OF COURT AND NOW, this 22nd day of June, 2005, upon consideration of the various exhibits evidencing notice of the hearing in this matter (Petitioner's Exhibits 2, 3, 4, and 5), any further requirements as to notice are hereby waived. By the Court, J. Jeffrey G. Stovall, Certified egal Intern ~~ Johnston-Walsh, Supervising Attorney ~m~ly Law Clinic 45 North pitt Street Carlisle, PA 17013 For the Petitioner pcb >: a.. <( ;.;: UJ-/ Qc, U:~E' C6) c.) f' ~a: 2LLI u-FS '6 ..::t ..:l' :c c... >- j-_. :;:7. ~l~ ::::. ~;o-. <j~l 0:> I _I :::> -, u-:> = = ....... ~I:t '~', :"":.1- ":;.. 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