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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 ~ ~ Lj "\:) A (l ~~ ~ """- 1 Cr, '- ~ ~ '-. ~l ~ ()' t ~ ~ ~ 'V t ,t. ~, ("} c~ C) c' ~ -1'1 :-;} -'-,..-" :b ' "'e r'-,' ::i c:; -'fJ C1 r;. ~:7 --, '-..c.) F:\FILES\DA T AFILE\GeneraIICl.lrrent\ I J 596. J . namechangepetition,als 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 :rc BY THE COURT, },jN~ r>n ,',' . I'" ~,_, '.J '0 . ('fI'" ..',\JUv , ' Y ,-. 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 dft J. :rc ~lj; \()\ ViNv'/\l,,\S\ii'~.id II 'In ",,r, ,0-" "'. ~"','I"n."'\ 1\.1..1\! ,1,;",1 ",' _ -~':'!, I h..l BIJ :2 \J,d L I ;JfW SGOl 'Cf<,fl'Y' ,-',' "0" 'd 3H1 .'0 ^UIi, UI\JUrd, 'C" ;J 301:!~(}-Q31I:J F: \FILES\DA T AFlLE\GeneraJICurrent\ I J 596.1 ,namechangepetition,als 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, ,< ) (') ~ -;-."", ""t)t-C' 'i"r:" ;~"; " ~ $ </> ro -0 rv - ;~l\~ <">, , 5o'e: ~ "'0 ::II: ~ l,:J:\ -O~~ -0 ~, :t~ :g Go /-r\1 "3 ~ - 0:..;> 0"