HomeMy WebLinkAbout05-3765
Thomas J. Williams, Esquire
J.D. 17512
Hillary A. Dean, Esquire
J.D. 92878
MARTS ON DEARDORFF WILLIAMS & OTTO
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Petitioners
IN THE MATTER OF PETITION FOR
CHANGE OF NAME OF
ASHLEY L YNN SWARTZ
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05- 31 (p,5' CIVIL ACTION - LAW
CHANGE OF NAME
PETITION FOR CHANGE OF NAME
Petitioners, JOHN A. BOBB and ANGELA S. BOBB, by their undersigned attorney, request
that the Court order a change of name pursuant to 54 Pa. Cons. Stat. 9 701 et seq. and in support
thereof make the following averments:
I. Petitioners are John A. Bobb, the natural father of Ashley Lynn Swartz, and Angela
S. Bobb, his wife, having been married on September 30, 1995.
2. The Petitioners reside at 568 Mountain Road, Boiling Springs, Pennsylvania 17007.
3. Ashley Lynn Swartz, born December 29, 1991, has continuously resided with
Petitioners since June of 2000.
4. The mother of the Ashley Lynn Swartz is Eugina Swartz alkJa Eugina Grimes whose
last known address is P.O. Box 491, Webster, Florida 33597.
5. The mother and father of Ashley Lynn Swartz were never married.
6. Since June of2000, the mother of Ashley Lynn Swartz has had irregular visitation
with her, perhaps averaging every six months. Since her natural mother moved to Florida on
November 28,2004, there has been no visitation whatsoever.
7. Petitioners desire to change the name of Ashley Lynn Swartz to Ashley Lynn Bobb,
being the surname of her natural father, the Petitioner herein. Ashley Lynn Swartz has begun to refer
to herself as "Bobb," often using the name "Bobb" when she signs her name. Also, the presence of
siblings named "Bobb" in the same household has created confusion. There is no family connection
with the name "Swartz." "Swartz" was the name of the step-father of Ashley Lynn Swartz's natural
mother who adopted it as her surname for exactly the same reasons Petitioners and Ashley Lynn
Swartz desire to adopt the surname "Bobb."
8. Ashley Lynn Swartz has not had a normal parent/child relationship with her natural
mother for at least two years and, given her young age, identifies herself integrally as part of her
present family.
9. The Petitioners believe Ashley Lynn Swartz's best interest unquestionably supports
the change of her surname to "Bobb."
1 O. There are no judgments, decrees or like character of record against the Ashley Lynn
Swartz.
WHEREFORE, Petitioners request Your Honorable Court to enter a decree changing the
name of Ashley Lynn Swartz to Ashley Lynn Bobb.
MARTS ON DEARDORFF WILLIAMS & OTTO
tt
homas J. Willi
I.D.17512
Hillary A. Dean, Esquire
I.D. 92878
10 East High Street
Carlisle, P A 17013
(717) 243-3341
Date: July 25, 2005
Attorneys for Petitioners
Thomas J. Williams, Esquire
!.D. 17512
Hillary A. Dean, Esquire
!.D. 92878
MARTSON DEARDORFF WILLIAMS & OTTO
10 East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Petitioners
IN THE MATTER OF PETITION FOR
CHANGE OF NAME OF
ASHLEY LYNN SWARTZ
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
NO. 05-
CIVIL ACTION - LAW
CHANGE OF NAME
CERTIFICATION OF LIEN SEARCH
Martson Deardorff Williams & Otto, a professional corporation organized under the laws of
the Commonwealth of Pennsylvania, hereby certifies that it has caused to be conducted a lien search
of the public records of the County of Cumberland for a five year period prior to July 7, 2005, in the
name of Ashley Lynn Swartz. Martson Deardorff Williams & Otto hereby certifies that no
outstanding judgments or decrees of record or any other matter oflike character were indexed against
Ashley Lynn Swartz during the applicable time period.
MARTS ON DEARDORFF WILLIAMS & OTTO
ri&ld!iQJJeWJ
J.D. 17512
Hillary A. Dean, Esquire
J.D. 92878
10 East High Street
Carlisle, P A 17013
(717) 243-3341
Date: July 25 , 2005
Attorneys for Petitioners
VERIFICATION
The foregoing Petition is based upon information which has been gathered by our counsel
in the preparation of the lawsuit. The language ofthe document is that of counsel and not our own.
We have read the document and to the extent that it is based upon information which we have given
to counsel, it is true and correct to the best of our knowledge, information and belief. To the extent
that the content of the document is that of counsel, we have relied upon counsel in making this
verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if we make knowingly false
averments, we may be subject to criminal penalties.
. Qb~^ ~~
Angela S.Bobb
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Created: 9/20/04 0:06PM
Revised: 7/14/05 1:44PM
Thomas 1. Williams, Esquire
J.D. 17512
Hillary A. Dean, Esquire
J.D. 92878
MARTS ON DEARDORFF WILLIAMS & OTTO
10 East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Petitioners
IN THE MATTER OF PETITION FOR
CHANGE OF NAME OF
ASHLEY L YNN SWARTZ
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05- 31r,s CIVIL ACTION - LAW
CHANGE OF NAME
DECREE
AND NOW, this _ day of
, 2005, upon consideration of the attached
Petition of John A. Bobb and Angela S. Bobb, for the change of name of Petitioner John A. Bobb's
minor daughter, and it appearing that there is no lawful objection to the request of Petitioners, it is
hereby ordered that the name of the minor, Ashley Lynn Swartz, is changed to Ashley Lynn Bobb.
BY THE COURT,
, J.
Thomas J. Williams, Esquire
I.D.17512
Hillary A. Dean, Esquire
I.D. 92878
MARTSON DEARDORFF WILLIAMS & OTTO
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Petitioners
IN THE MATTER OF PETITION FOR
CHANGE OF NAME OF
ASHLEY L YNN SWARTZ
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
,.-
NO. 05- 37f.e:> CIVIL ACTION - LAW
CHANGE OF NAME
ORDER OF COURT
AND NOW, this _ day of
, 2005, upon Motion of Petitioners, it is
ordered that a hearing on the Petition for Change is fixed for
,2005,
at
Carlisle, Pennsylvania.
The Petitioners are directed to give notice of the filing of the Petition and of the date of the
. m. in Courtroom No.
of the Cumberland County Courthouse,
hearing by publication one time in the Sentinel and one time in the Cumberland Law Journal. The
Petitioners are further directed to give notice of the filing of the Petition and the date of the hearing
to Eugina Swartz, alk/a Eugina Grimes, the natural mother, by certified mail, restricted delivery
requested.
BY THE COURT,
, J.
IN THE MATTER OF
PETITION FOR CHANGE
OF NAME OF ASHLEY
LYNN SWARTZ
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
NO. 05-3765 CIVIL TERM
ORDER OF COURT
AND NOW, this 5th day of July, 2005, upon consideration of the attached Petition
for Change of Name, a hearing is scheduled for Wednesday, September 21,2005, at 1 :30
p.rn" in Courtroom 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 requirements of C.C.R.P. 5,
and the Act of December 16, 1982, P.L. 1309, S6 (see 54 Pa. C.S. S701 [Historical and
Statutory Notes] [Main Volume]), and 54 Pa. C.S. SS701 et seq.
IN ADDITION, notice of the petition and hearing shall be provided to the child's
natural mother at least 10 days prior to the hearing by regular mail and by certified mail.
Thomas J. Williams, Esq.
vH!Ilary A. Dean, Esq.
10 East High Street )
Carlisle, PA 17013
Attorney for Petitioners
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BY THE COURT,
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IN THE MATTER OF
PETITION FOR CHANGE
OF NAME OF ASHLEY
LYNN SWARTZ
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
NO. 05-3765 CIVIL TERM
AMENDED ORDER OF COURT
AND NOW, this 16th day of August, 2005, the prior order of court in the above
matter dated July 5, 2005, and filed August 5, 2005, is hereby amended to reflect the
correct date of the order as August 5, 2005. In all other respects the prior order shall
remain in full force and effect.
BY THE COURT,
~as J, Williams, Esq,
Hillary A. Dean, Esq.
10 East High Street
Carlisle, PA 17013
Attorneys for Petitioners
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Created: 9/20/04 0:06PM
Revised: 7/14/05 1:44PM
}ECEIVED AUG 032005
Thomas J. Williams, Esquire
J.D. 17512
Hillary A. Dean, Esquire
J.D. 92878
MARTS ON DEARDORFF WILLIAMS & OTTO
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Petitioners
IN THE MATTER OF PETITION FOR
CHANGE OF NAME OF
ASHLEY L YNN SWARTZ
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
NO. 05- :<7(,,:) CIVIL ACTION - LAW
CHANGE OF NAME
DECREE
AND NOW, this -z.. \ day Of~ ?()()<; , upon consideration of the attached
Petition of John A. Bobb and Angela S. Bobb, for the change of name of Petitioner John A. Bobb's
minor daughter, and it appearing that there is no lawful objection to the request of Petitioners, it is
hereby ordered that the name of the minor, Ashley Lynn Swartz, is changed to Ashley Lynn Bobb.
BY T~URT,
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