HomeMy WebLinkAbout05-4939
INRE:
: IN THE COURT OF COMMON P~EAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
MITCHELL CARY HIGGINS
: NO. tI5~q?f CIVIL TERM
PETITION FOR CHANGE OF NAME
AND NOW, comes Petitioner, Jennifer 1. Hansen, by and through her counsel of
record, Bradley 1. Griffie, Esquire, and the law firm of Griffie & Associates, and
petitions the Court as follows:
I. Your Petitioner is Jennifer 1. Hansen, an adult individual currently residing at
627 Highland Avenue, Carlisle, Cumberland County, Pennsylvania.
2. Your Petitioner is the natural parent of two children, namely, Brianna Rose
Higgins, born February 6, 1993, and Mitchell Cary Higgins, born December
19, 1994.
3. The natural father of the children is Brian Samuel Higgins, whose address is
unknown.
4. Petitioner has legal and physical custody of the children pursuant to the
parties' Marital Settlement Agreement dated July 28, 1999, a copy of said
Marital Settlement Agreement being attached hereto and incorporated herein
by reference as Exhibit "A."
5. The child, Mitchell Cary Higgins, was born on December 19, 1994, in the
State of California. A copy of the child's birth certificate being attached
hereto and incorporated herein by reference as Exhibit "B."
6. Petitioner is married to Jacob Bernard Hansen, having married Mr. Hansen on
September 28, 2003.
7. Mr. Hansen has resided with Petitioner and her children since approximately
July 2003.
8. Since the time Petitioner and her husband began residing together, Mitchell
promptly began using the last name of Hansen as he had no relationship with,
nor did he identify with his father, Brian Samuel Higgins.
9. Your Petitioner, and her former husband, Brian Samuel Higgins, separated in
February 1999, which is the last time that Brian Samuel Higgins had any
contact of any nature whatsoever with the child at issue herein.
10. At the time of Petitioner's separation from Brian Samuel Higgins, the parties
were residing at 8 Golders Green Way, Glenhaven, New South Wales,
Australia, and Brian Samuel Higgins separated himself from Petitioner and
the parties' children.
11. The said Brian Samuel Higgins (hereinafter referred to as "Higgins") is
believed to have moved to Singapore in February 1999 when he separated
himself from the family.
12. Since February 1999, Petitioner has not had a mailing address, a telephone
number, an email address, or other means of contacting Higgins.
13. Pursuant to the parties' Marital Settlement Agreement dated July 28, 1999,
which is attached hereto, Higgins has a responsibility to pay child support to
Petitioner which he did, at least in partial fashion, until August 27,2004.
14. When Petitioner would receive support payments to her prior address in
Australia, the payments would be by wire from a bank in Singapore, a copy of
said wiring notification being attached hereto and incorporated herein by
reference as Exhibit "C."
15. The wiring notification, and any other means of receiving support from
Higgins by Petitioner, never provided any specific mailing address for
Higgins.
16. No support payments have been received by Petitioner from Higgins since
August 27, 2004.
17. Petitioner believes upon information received that Higgins may be residing
somewhere in Thailand.
18. Brianna has not received any type of personal contact, telephone contact,
email contact, or written contact of any nature whatsoever from Higgins since
February 1999.
19. Petitioner's husband, Jacob Hansen, is a Colonel, and is active United States
Army presently serving as a commander in the conflict in Iraq.
20. Brianna has identified herself with the last name Hansen since even prior to
Petitioner's marriage to Mr. Hansen in September 2003.
21. Higgins' mother, the child's paternal grandmother, identifies the child as
Brianna Hansen.
22. The child has been identified as Brianna Hansen in her school since moving to
the County of Cumberland in the Commonwealth of Pennsylvania in July
2003.
23. While respective teachers in the child's classrooms use the name Hansen, the
child's official records at school list her last name as Higgins.
24. The child is aware of the fact that her given name was Higgins, but she refuses
to use that last name, looks to Jacob Hansen as her father, and prefers the use
of the last name Hansen for all purposes.
25. The child does not have any estate of her own.
NOW THEREFORE, it is in the best interest and permanent welfare of the child
to have the child's last name changed from Brianna Rose Higgins to Brianna Rose
Hansen.
Respectfully submitted,
1'(.2-1 10J
Date
. G' Ie, Esquire
rney Petitioner
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unsworn falsifications to authorities.
DATE:
1/;)/05
,
ft1I~.
!J ifeI. Hansen
STATE OF ILLINOIS
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
STEPHENSON COUNTY
In Re the Marriage of
JENNIFER HIGGINS,
Plaintiff,
and
BRIAN HIGGINS,
Defendant.
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1FJlL6~ 75)
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NO. 99 D 93 v.p [] 1999
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C!.t:nK OP''!"I''!l:: em
St8phenac:n CoU"I~,clu'II'r COi./i';1'
~. no/:
MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT made and entered into this? 8 day of :;) vt/V , 1999,
I
between JENNIFER HIGGINS (hereinafter referred to as the "Wife"), and BRIAN
HIGGINS, (hereinafter referred to as the "Husband");
RECITALS
A. Certain irreconcilable and unfortunate differences have arisen between the
parties which have rendered impossible a continuation of the marital relationship existing
between them.
B. Plaintiff has filed a Petition for Dissolution of Marriage in the Circuit Court of
the Judicial Circuit, Stephenson County, Illinois, in Cause No. 99 D 93, and said cause of
action remains pending and undetermined.
C. Wife has engaged Dan G. Fishburn of the firm of Snow, Hunter, Whiton &
Fishburn, Ltd., as her attorney, and the Husband has engaged Richard Hauser of the firm
Exhibit "A"
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of Mahoney & Hauser. Ltd., as his attorney, and each party has had the benefit of coun.
sel. Both parties acknowledge that they are fully informed of their respective rights and
obligations under Illinois law and pursuant to the terms and provisions of this Agreement.
Accordingly, each party represents and warrants that:
1. He or she has made a full and complete disclosure of his or her financial
condition and that he or she is fully informed of the wealth, property, estate, assets and
liabilities and income of the other.
2. He or she has carefully reviewed the terms and provisions of this Agreement
and has a full and complete understanding of the legal consequences thereof.
3, He or she has entered into this Agreement freely and voluntarily, without
imposition of force, duress, coercion or undue influence from any source.
4. The other party has made no representations or warranties as an inducement to
enter into this Agreement, other than as set forth in writing within the terms and
provisions of this Agreement.
5. The terms and provisions of this Agreement are fair and equitable to each of the
parties in light of the respective and collective circumstances of the parties.
D. Two children were born to the parties as a result of the marriage, namely,
Brianna Rose Higgins, born February 6, 1993, and Mitchell Cary Higgins, born December
19,1994. No other children were born to or adopted by the parties and Wife
acknowledges that she is not pregnant.
E. Each party considers it to be in his or her best interest to settle all issues that
could be raised by either of them in the pending proceedings, and forever, finally, and
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fully to settle and adjust all rights that either party may have against the other, whether by
virtue of the marriage or any other relationship or occurrence between or involving the
parties, or either of them, including personal, physical or emotional injury, as well as any
other rights that either of them now has or may hereafter claim against the other, without
reservation of any kind, nature, or description, and specifically including a resolution by
agreement of all rights and claims in and to any property of the other, whether marital or
non-marital, whether now owned or hereafter acquired, and further including all rights or
claims in and to the estate of the other.
F. The Recitals are an integral part of this Agreement and are enforceable as such,
AGREEMENT
NOW, THEREFORE, in consideration of the mutual and several promises and
undertaking herein contained, and for other good and valuable consideration, the receipt
and suffiCiency of which is hereby mutually acknowledged, the parties do hereby freely
and voluntarily agree to each and term and provision hereinafter set forth in this Marital
Settlement Agreement.
ARTICLE I
STATEMENT OF INTENTION
1.1 Integrity of the Marriage. This Agreement is not intended to undermine the
integrity of marriage or the family relationship.
1.2 Amicable Settlement of Disputes. By this Agreement, the parties intend to
effect an amicable resolution of their disputes, to mitigate the potential harm to the
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spouses and their children caused by the dissolution of marriage, and to make reasonable
provision for the parties and their children aher the dissolution of the marriage.
1.3 Reservation of Rights. In the event the Court shall find this Agreement to be
unconscionable, each party reserves the right to prosecute or defend any action now
pending or that may hereaher be brought for relief under the Illinois Marriage and
Dissolution of Marriage Act.
ARTICLE II
CUSTODY AND VISITATION
2.1 Sole Custody. The sole care, custody, control and education of the minor
children of the parties shall be with the Wife, subject to reasonable visitation rights in the
Husband. That the parties shall adhere to the following rules with respect to the custody
of and visitation with the minor child:
1. Each parent shall refrain from discussing the conduct of the other parent in the
presence of the child except in a laudatory or complimentary way;
2. Under no circumstances shall the question of child support either as to amount,
manner, or transmission of payment, be raised in the presence of the chi Idren;
3. Visitation with the minor children shall not be withheld because of the
nonpayment of child support. The payment of child support shall not be withheld
because of the refusal of the Custodial-Parent to grant visitation to the Non-Custodial-
Parent;
4. The Custodial-Parent shall not threaten to withhold visitation from the Non-
Custodial-Parent. The Non-Custodial-Parent shall not threaten to prevent or delay the
return of the child to the Custodial-Parent after a period of visitation;
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5. The Custodial.Parent shall prepare the child both physicaliy and mentally for
visitation with the Non-Custodial-Parent. The child shall be available at the time
mutually agreed upon between the parties for the beginning of visitation;
6. The Non-Custodial-Parent shall advise the Custodial-Parent as soon as possible
if the Non-Custodial-Parent is unable to keep a planned visitation with the child;
7. Both parents shall not unreasonably question the children regarding the
activities of the other parent;
8. Neither parent shall expose the children to any immoral condud between the
parent and any member of the opposite sex;
9. Neither parent shall drink to excess in the presence of the children and the
Non-Custodial-Parent shall not visit the children if the Non-Custodial-Parent has, shortly
before said visitation, been drinking alcoholic beverages;
10. The Non-Custodial-Parent shall not visit the children at unreasonable hours;
11, The Non-Custodial-Parent shall work with the Custodial-Parent to arrange
visitation schedules which shall take into account the children's educational, athletic and
social activities. The Non-Custodial-Parent may take the children to appropriately
planned activities;
12, In the event the Non-Custodial-Parent takes the children for an extended
period to a place other than the Non-Custodial-Parent's residence, the Non-Custodial-
Parent shail inform the Custodial-Parent of the children's whereabouts;
13. If visitation does not occur, through no fault of the Non-Custodial-Parent,
compensatory visitation shall be arranged;
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14. Both parents shall, at all times, conduct themselves in a manner which
promotes the beneficial effect on the minor child of visitation with the Non-Custodial-
Parent.
ARTICLE "'
CHILD SUPPORT
3.1 Child Support.
A. The Husband shall pay to Wife, as and for support of the minor child, the sum
of $1,625.00 per month in U.S. dollars, payable monthly commencing August 1, 1999.
The parties acknowledge that due to their temporary residence outside of the United
States, it would be impractical to require payments to be made through the Clerk of the
Circuit Court. Therefore, the parties agree that Husband shall make child support
payments directly to Wife. The amount of child support as set forth in this Paragraph is
based upon Husband's current income of $65,000.00 per year in U.S. dollars, said
income is not presently subject to the payment of income taxes.
B. Duration of Payments. The Husband's obligation under Paragraph 3.1 shall
continue until the emancipation, as defined hereinafter, of the minor child.
C. Emancipation Defined. For purposes of this Agreement, the term
"emancipation" shall be defined as the occurrence of the first of the following events:
1. The child's death;
2. The child attaining the age of 18 years or completion of a high school
education, whichever later occurs, but in no event beyond the child's 19th birthday;
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3, The child's maintaining a full-time residence outside the home of the parent
having primary care of that child, exclusive of a residence at a secondary boarding
school, camp, or similar facility;
4. The child's obtaining full-time employment, exclusive of employment during
school vacation periods;
5. The child's induction into the armed services of the United States or the
National Guard; or
6. The child's marriage.
3.2 Children's Medical Expenses.
A. Wife shall maintain medical insurance for both of the children of the parties.
Application for each independent incident of treatment for medical, dental (including
orthodontic), optical or any other health care shall be made first to the available
insurance. Wife shall pay all uninsured medical, dental, optical and health care expenses
with the exception of orthodontic treatment, which shall be divided equally between the
parties.
B. Duration of Obligations. The parties' respective obligations under this
Paragraph 3.2., shall commence on the effective date of this Agreement and shall
continue, as to the child in question, until the child's emancipation, as hereinabove
defined, provided that if the child pursues a college, university, or vocational school
education, then the obligations of the parties as set forth in Paragraph 3.2. shall continue
until that child's completion or discontinuance of the educational pursuit, but in no event
shali these obligations continue beyond the child's 23rd birthday.
-8-
3.3 Dependency Exemptions.
A. Entitlement. Wife shall be entitled to claim the minor children as dependents
for income tax purposes.
3.4 Life Insurance for Children.
A. Each of the parties shall maintain life insurance policies with the minor
children or a Trustee for the minor children named as the beneficiary, in the minimum
amount of $500,000.00, until such time as the youngest child attains the age of 21.
There shall be no loans against the policies. Both parties may request proof of said
insurance coverage by written request to the other party, once per calendar year.
ARTICLE IV
MAINTENANCE
4.1 Waiver of Maintenance. Each party hereby waives and releases any and all
claims against the other for maintenance, alimony and spousal support, whether past,
present or future and each party is barred hereafter from claiming maintenance from the
other party.
ARTICLE V
PROPERTY SETTLEMENT
5.1 Tangible Personal Property. Except as otherwise provided in this Agreement,
each of the parties covenants and agrees that each party shall have an retain sole and
exclusive right, title and interest in all of the tangible personal property in his or her
respective name or possession or under his or her respective control upon the effective
date of this Agreement. The parties presently have tangible personal property in storage
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at O'Mara's Moving and Storage in Freeport, Illinois. The parties acknowledge that said
property shall be divided by mutual agreement subsequent to the Judgment for
Dissolution of Marriage. In the event there is any dispute regarding the division of said
property, the parties may return to Court and request the Court to equitably divide the
property which is in storage.
5.2 Vehicles, The parties have no vehicles which they own, Wife has a company
car in which she has no ownership interest.
5,3 Life Insurance. Except as otherwise provided in Paragraph 3.4 above, each of
the parties hereby releases and/or waives any interest, beneficial or otherwise, which he
or she may have acquired in or to life insurance policies owned by the other party.
5.4 Checking and Deposit Accounts. Except as otherwise herein set forth,
Husband shall have as his sole property any checking, savings or deposit account
presently in his name and Wife shall have as her sole property any checking, savings or
deposit account presently in her name.
5.5 Retirement Accounts. Wife shall have as her sole property her 401 (k) with
Fidelity Investments, which has an approximate value of $9,000.00. Any other IRA's,
pensions, profit-sharing plans or retirement accounts shall be the sole property of the
party whose name is on said account.
ARTICLE VI
DEBTS AND LIABILITIES
6,1 Husband's Obligations. Husband shall pay all of his student loans and his
debt to Dell Computer and all credit card accounts in his name. Husband shall
indemnify and hoid Wife harmless on said debts.
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6.2 Wife's Obligations. Wife shall pay the outstanding debt to David Jones
Department Store for appliances of approximately $7,000.00 and shall pay all credit card
accounts in her name, Wife shall indemnify and hold Husband harmless on said debts.
6.3 Respective Obligations, Except as otherwise set forth in this Agreement, each
party warrants that he or she has not incurred any debts or liabilities with third parties for
which the other party would be liable, except for those debts and liabilities incurred in
the ordinary course of living, which shall be paid by the party who incurred such debt or
liability. Each party agrees with the other party that he or she will not at any time
hereafter contract any debt or liability whatsoever with third parties for which the other,
or his or her legal heirs, representatives and assigns, shall become liable. Each party
agrees to keep the other party, his or her heirs, personal representatives and assigns, free,
harmless and indemnified from any claims, debts, charges or liabilities hereafter
contracted by himself or herself with third parties.
6.4 Income Tax Liability. The parties have filed joint federal income tax returns
during the marriage with the exception of the year 1998 when they filed "married filing
separate." In the event there are any additional taxes, penalties or interest arising from
the fll ing of federal or state income tax returns, the liability for said taxes, penalties or
interest shall be as follows: Both parties shall be solely responsible for any tax liabiiity
resulting from the filing of their 1998 tax returns which were filed on a "married filing
separate" basis. In the event there are any taxes, penalties or interest due for 1997 and
prior years arising from jointly filed tax returns, the taxes, penalties and interest shall be
the responsibility of the party who earned the income frorn which the additional taxes,
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penalties or interest arose and said party shall pay the liability and hold the other party
harmless, In the event a tax liabiiity arises from a jointly filed return that is not related to
the income of either party (such as itemized deductions, investment income, etc.), any
additional taxes, penalties or interest shall be divided equally between the parties.
ARTICLE VII
ATIORNEY'S FEES AND COSTS
7.1 Each of the parties shall pay their own attorney's fees and costs incurred
herein.
ARTICLE VIII
GENERAL PROVISIONS
8.1 This Agreement may only be amended or modified by mutual agreement of
the parties. Any such amendment or modification shall be reduced to writing, dated and
signed by both of the parties, and shall specifically provide that it is intended to alter or
amend this Agreement. No oral agreement shali be effective to in any manner modify or
waive any terms or conditions of this Agreement.
8.2 Any and all property acquired by either party subsequent to the date of this
Agreement shall be the separate property of the party acquiring the same if all other terms
of this Agreement become effectuated.
8.3 Both parties will promptly execute any and all documents of any kind or
character which may be necessary or proper to carry out the terms of this Agreement. If
either party hereto shall for any reason fail or refuse to make, execute, acknowledge or
-12-
deliver any such documents, then this Agreement is hereby declared to constitute a full
and present transfer, assignment and conveyance of all rights hereinabove designated to
be transferred, assigned and conveyed, and a waiver of all rights hereinabove designated
to be reiinquished and waived. If either party, after written request, fails for a period of
more than 30 days after said written request to make, execute, acknowledge or deliver
any necessary documents or instruments that are reasonably required to implement the
terms of this Agreement, a Judge of the Circuit Court of Stephenson County, Illinois, is
hereby authorized to make, execute, acknowledge and deliver such documents and
instruments at the request of either party, This authorization includes, but shall not be
limited to, any and all documents and instrument pertaining to the transfer or conveyance
of real and personal property and beneficial interest in land trusts.
8.4 The provisions of this Agreement contain the entire understanding of the
parties. No representations, warranties, promises, covenants, or undertakings, other than
those expressly set forth herein, have been made by either party to the other.
8.5 This Agreement shall be construed under the generai laws of the State of
Illinois, irrespective of the later domicile or residence of the Husband or Wife.
8.6 This Agreement shall be binding upon, and inure to the benefit of, the parties
hereto and their heirs, personal representatives and assigns.
8.7 In the event a Judgment of Dissolution of Marriage is granted to the Parties at
any ti me hereafter, this Agreement and all of its provisions shall be set forth and
incorporated in any such Judgment, but in no event shall this Agreement be effective or
of any validity unless and until a Judgment of Dissolution of Marriage is entered. The
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Court, upon entry of the Judgment of Dissolution of Marriage, shall retain the right and
power to enforce the provisions and terms of the Agreement, including, but not limited
to, the use of contempt procedures. Upon entry of such Judgment, this Agreement shall
also be subject to enforcement by either party as in the case of any other contract or
agreement.
IN WITNESS WHEREOF, the Husband and Wife have hereunto set their respective
hands and seals the day and year first above written.
,
V'7 (SEAl)
(SEAL)
Brian Higgins
STATE OF ILLINOIS )
) SS
COUNTY OF STEPHENSON )
Before me, a Notary public, in and for the County and State aforesaid, personally
appeared Jennifer Higgins, personally known to me and known to me to be the same
person who executed the foregoing instrument, and she acknowledged that she executed
and del ivered said instrument as her free and vol untary act and deed, for the uses and
purposes herei n set forth.
Given under my hand and notarial seal this -Z'1? day of (\d ,~I
V
,1999.
OFFICIAL SEAL
DAN G, FISHBURN
NOTARY PUBLIC, STATE OF ILLINOIS 1
MY COMMISSION EXPIRES 1-7,2002 1
'~i.,(t
Notary Public
)
) SS
)
-14-
"
Before me, a Notary public, in /.h.t?~~ ./J'?J.-..s..Lv L!~~.~
personally appeared Brian Higgins, personally known to me and known to me to be the
same person who executed the foregoing instrument, and he acknowledged that he
executed and delivered said instrument as his free and voluntary act and deed, for the
uses and purposes herein set forth.
Given under my hand and notarial seal this G day of,!2t/~~ , 1999.
APPROVED:
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1'1. orney Richard J, H(y er
Attorney for Defendaffii
Snow, Hunter, Whiton & Fishburn, Ltd.
Attorneys for Defendant
11 East Exchange Street
Freeport, IL 61032
(815) 235-2511
[DIVIHIGGtNS.02]
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Notary Public 'J
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CERTIFICATE OF LIVE BIRTH
STATE OF CALIFORNIA
USE BLA.CK INK ONLY
LOCAL REGISTRATION DISTRICT AND CERTIFICATE NUMBER
THIS
CHilD
PLACE
OF
BIRTH
FATHER
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MOTHER
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8. O"'TE OF arRTH
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9'\, NAME OF MOHlER
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,138 LICENSE NUMBER
: G-65656
RELAllONSUlP TO CWLD II2C. OATE SIGNED
: 12/30/94
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113C. OATE SIGNED
: 12/30/94
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IIA. TYPED NAME "''10 TITLE OF CERTIFIER IF O'"ER TllAN ATTENDIIN'
: BARBARA ORLINA,M.R.C.
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MOTHER
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IJD. TYPED N"'ME, TITl.E "'ND ",....,UNG ADDRESS OR AnENOANT
JOEL M BERCHIN,MD,8851 CENTER DR,LA MESA
t Cfll'Ir'f H'A' THl (:ltILOWIIS eOllN ALIVI!;
A' lI'l a.'l. HOUII AND P''''<;II: .'A'I!;O
IS.... DATE OF DEATH
'58. STATE I'll END.
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16. LOCAL m:GlSrn..."
.
17. DATE ACCEPTED FOR REClIS'RAHON
o 1 / 0 9 11995
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.
COUNTY OF SAN DIEGO, DEPT. OF HEALTH SERVICES 3851 ROSECRANS ST.
THIS IS TO CERTIFY THAT, IF BEARING THE OFFICIAL SEAL OF THE
SAN DIEGO DEPARTMENT OF HEALTH SERVICES, TH IS A TRUE COPY OF
THE ORIGINAL DOCUMENT FILED.
REQUIRED FEE PAID
DATE ISSUED: August 10, 1995 REGISTRAR OF VITAL STATISTICS
\
Exhibit "B"
'1lestpac Banking Corporation
ABN 33 00745714'1
First Bank in Australia
MRS J HIGGINS
MRS J L HIGGINS
B GOLDERS GREEN WAY
GLENHAVEN 2156
LOCKED BAG 5100
PARRAMATTA NSW 2124
Telephone No 131032
Fax No 02 9806 4100
5th January 2001
CREDIT ADVICE CONFIRMATION
We have +OrlAY recAived AUD 1500.00 and credited account
number 732091 516531 at our CHATSWOOD Branch with
AUD 1500.00.
Beneficiary's Details, JENNIFER L HIGGINS
B GOLDERS GREEN WAY
GLENHAVEN NSW 2054 AUST
612 BB50 1684
Remitting Bank and Branch, DBS BANK LTD (DEVELOPMENT BANK OF S
SINGAPORE
By Order of, HIGGINS BRIAN SAMUEL , BLK 12
Should You have any query regarding this transaction, please call or
write quoting our reference number 2IPITTI 714217 in all correspondence.
Exhibit "e"
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j RECEIVED S::P 2320051.,\
INRE:
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
; NO, {)b- <-(Cf-3tjCIVIL TERM
MITCHELL CARY HIGGINS
ORDER OF COURT
AND NOW, this /~ day of&e/-a.1u/L...-
, 2005, upon
presentation and consideration of the within Petition, a Rule is hereby issued upon the
Respondent, Brian Samuel Higgins, to show cause, if any he has, as to why the name of
the child, Mitchell Cary Higgins, should not be changed to Mitchell Cary Hansen.
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Rule returnable and hearing to be held on .,j"/u / d 1 ' the ~ day of
111}(un.kNt./ , 2005, at q: Cf7) !L.m. in Courtroom No. ~ of the
Cumberland County Courthouse.
Service to be made by certified mail, restricted delivery upon the Respondent at
his last known address.
Service also to be provided by publication in the Cumberland Law Journal and in
the Carlisle Sentinel on one occasion.
By the Court,
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INRE:
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
MITCHELL CARY HIGGINS
: NO. 05-4939 CIVIL TERM
ORDER OF COURT
And now, this ---.!.L day of
N".....,w-
, 2005, following hearing in this
matter, IT IS HEREBY ORDERED AND DECREED that from this day forward
Mitchell Cary Higgins shall be known as Mitchell Cary Hansen.
BY THE COURT,
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