HomeMy WebLinkAbout05-2156IN RE: HARRY LEE WILLIAMS and IN THE COURT OF COMMON PLEAS
KATHY LYNN WILLIAMS, CUMBERLAND COUNTY, PENNSYLVANIA
Parents and Guardians of
GIANNA LYNN SHANDRA,
NO. L.J? IS"6
PETITION FOR NAME CHANGE
Petitioner, by and through their attorney, The Law Office of Darrell C. Dethlefs, file the
captioned Petition for a name change and aver as follows:
Petitioner Harry Lee Williams is the natural father of Gianna Lynn Shandra born
December 17, 1999, hereinafter the "child".
2. Petitioner is the natural mother of Gianna Lynn Shandra, who is a minor child born
December 17, 1999 hereinafter "child".
3. Petitioners and Gianna Lynn Shandra have resided together as a family at 760
Street, Lemoyne, Pennsylvania 17043.
4. Petitioners Harry Lee Williams and Kathy Lynn Williams were married to each othgr on
May 5, 2003.
5. Petitioners Harry Lee Williams and Kathy Lynn Williams do not have a religious
6. No judgments or decrees of like character of record against Gianna Lynn Shand
7. It is in the best interests of Gianna Lynn Shandra to have her name changed to
Lynn Williams
WHEREFORE, Petitioner requests the Court to change the name of Gianna Lynn Shandr4 to
Gianna Lynn Williams.
Respectfully Submitted,
LAW OFFICE OF DARRELL C.
Date-3/14 la--5
Attorney Identification No. 58851
3805 Market Street
Camp Hill, PA 17011
(717) 975-9446
IN RE: HARRY LEE WILLIAMS and : IN THE COURT OF COMMON PLEAS
KATHY LYNN WILLIAMS, : CUMBERLAND COUNTY, PENNSYLV
Parents and Guardians of
GIANNA LYNN SHANDRA,
NO.
VERIFICATION
We hereby verify that the statements of fact made in the foregoing document are true and
t to the
best of our knowledge, information, and belief. We understand that any false statements therein are
subject to the criminal penalties contained in 18 Pa.C.S.A. §4904, relating to unsworn falsification to
authorities.
Harry Lee
Kathy
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RE: HARRY LEE WILLIAMS and
LTHY LYNN WILLIAMS,
rents and Guardians of
4NNA LYNN SHANDRA,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ORDER
AND NOW, this egJ1 day of 2005, upon Motion of Petitioner, it is Ordered
that a hearing on the Petition for a name change is fixed for the day of ___,2005
at o'clock a.m./p.m. in court room number of the Cumberland County Courthouse.
Petitioner is directed to give notice of the filing of the Petition and the date and time of the hearing by
publication in two newspapers of general circulation in this county, one of which may be the official
newspaper for publication of legal notices in this
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IN RE: HARRY LEE WILLIAMS and
KATHY LYNN WILLIAMS,
Parents and Guardians of
GIANNA LYNN SHANDRA,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. QS - oZ Sb
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ORDER
AND NOW, this Z1 day of -LV%A -, 2005 upon consideration of the Motion filed in
this matter and the proof of publication of notice and after a hearing in this matter and appearing that there
is no lawful objection to the Petition, it is here
changed be changed to Gianna Lynn Williams.
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MEGAN M. GRABIEC, : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION -LAW
JOSEPH O. GRABIEC, NO. 2006-2156 CIVIL TERM
Defendant : IN CUSTODY
HONORABLE M. L. EBERT, JR.
ANSWER TO NEW MATTER AND COUNTERCLAIM
11. Admitted. By way of further answer, it is believed that defendant/respondenfs father
suffers with Parkinson's Disease.
12. Plaintiff/petitioner is without knowledge sufficient to form a belief as to the averments of
paragraph 12.
13. Plaintiff/petitioner is without knowledge sufficient to form a belief as to the averments of
paragraph 13.
14. Plaintiff/petitioner is without knowledge sufficient to form a belief as to the averments of
paragraph 14; however, plaintiff/petitioner believes that defendant/respondenfs father drools while eating
and requires the use of adult diapers.
15. Admitted. By way of further answer, defendant/respondenfs mother, a former registered
nurse, requires the assistance of another medical professional at least twice a week to care for her husband
and the children. Plaintiff/petitioner believes that the LPN bathes the children because the grandmother is
unable to do so.
16. Denied for the reasons set forth in paragraph 15.
17. No responsive pleading is required.
18. Denied. Plaintiff/petitioner has used only the assistance of her mother.
Plaintiff/petitioner was released from custody three hours after her arrest . During her in-patient treatment
for post-traumatic stress disorder at Roxbury, plaintiff/petitioner's mother did provide sole care for the
children because defendant/respondent was deployed. No exchanges were required during those time
periods.
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19. Admitted.
20. Admitted. By way of further answer, plaintiff/petitioner was abiding the court order of
October 10, 2008.
21. Admitted. By way of further answer, the change in exchange location was for the benefit
of both parties because defendant/respondent moved to Carlisle.
22. Admitted. By way of further answer, the change in exchange location was for the benefit
of both parties because defendant/respondent moved to Carlisle.
23. Admitted. By way of further answer, the agreement was based on misrepresentations by
defendant/respondent concerning his work schedule.
24. Admitted.
25. Admitted. By way of further answer, the agreement was based on misrepresentations by
defendant/respondent concerning his work schedule.
26. Admitted. By way of further answer, the agreement was based on misrepresentations by
defendant/respondent concerning his work schedule.
WHEREFORE, plaintiff/petitioner requests your Honorable Court to dismiss the new matter and
counterclaim of defendant/respondent.
Respectfully submitted,
aT nnaH. Rehkamp, Esquire
er & O'Connell
N. Front Street
sburg, PA 17110
(717) 232-4551
Attorney for Petitioner
Verification
I verify that the statements made in the foregoing are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa. C.S.A.
Section 4904 relating to unworn falsification to authorities.
Date: ?16?
Certificate of Service
I, Stacey A. Fogle, secretary in the law firm of Turner and O'Connell, hereby
certify that I served a true and correct copy of the foregoing by depositing same in the
U.S. mail, first class postage prepaid, addressed as follows:
Bradley Griffie, Esquire
200 North Hanover Street
Carlisle, PA 17013
Date: 12/11/2009 tacey A. Fogle
RlFD-?)F rE
OF THE' PR:Or nNO?'ARY
2009 DEC 14 PM 2: (0
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