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HomeMy WebLinkAbout06-1058 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: CHANGE OF NAME OF MHORIGANN INANNA DANU CARTER, a minor, to MORRIGAN ELIZABETH SULLIVAN, No.2006-/C,51' CIVIL TERM PETITION FOR CHANGE OF NAME TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, this J lJTh day of ~, 2006, comes the Petitioner, Kevin P. Sullivan, on behalf of his daughteT, Mhorigann Inanna Danu Carter, by and through his attorneys, Knight & Associates, P.C., and represents the following: 1. The Petitioner Kevin P. Sullivan resides with the minor child, Mhorigann Inanna Danu Carter (hereinafter "Mhorigann") at 267 Lincoln Street, Carlisle, Cumberland County, Pennsylvania. 2, The Petitioner is the natural father of Mho rig ann, a minor, whose date of birth is June 3,2002. 3, The natural mother of Mhorigann is Sarah A. CarteT, whose last known address is 2219 Jennings Street, Sioux City, Iowa 51104, 4, The child was born out of wedlock and Petitioner is estranged from Ms. Carter and is married to Lynn Sullivan. 5. PetitioneT was granted sole legal and primary physical custody of Mho rig ann by Order of this Court dated December 12, 2005 docketed to Civil Action No. 05-5459. A copy of the said Court OTder is attached hereto as Exhibit "A" and made a part hereof. , 6, In addition to Mhorigann's present address, since birth, she has resided at the following addresses: a. From birth to July 10,2005 with her natural mother, Sarah A. Carter and her friends and family at various addresses and homeless shelters in Missouri and Iowa and occasionally at Ms. Carter's grandmother's residence at 310 5th Avenue, Hornick, Iowa; and b. From July 10, 2005 to September 1, 2005, with Petitioner, Petitioner's wife, Lynn Sullivan, and her parents, Tieu and Dennis Arashiro at 2181 Makanani Drive, Honolulu, Hawaii. 7, Mhorigann was born out of wedlock and was born as Mhorigann Inanna Danu Carter. 8, The Petitioner and Mhorigann have resided in Cumberland County, Pennsylvania, since September I, 2005, 9. Petitioner desires and feels it would be in the best interest of Mho rig ann that her first name be changed to Morrigan, that her middle name be changed to her maternal grandmotheT' s name of Elizabeth and that her surname conform to his surname, Sullivan, 10. Petitioner does not wish to change Mhorigann' s name for any illegal purpose, to avoid payment of taxes or other debts, or to avoid any obligation, II. Petitioner's counsel, Sean M, Shultz, Esquire, has searched the index in the Prothonotary's Office in the Court of Common Pleas of Cumberland County and there are no judgments or decTees oflike character of record against Mhorigann Inanna Danu Carter. , WHEREFORE, the Petitioner requests this Honorable Court enter a decree changing the name of Mhorigann Inannu Danu Carter to Morrigan Elizabeth Sullivan, Respectfully submitted, M. Shultz, Esqui Attorney ill No. 90946 II Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorneys for Petitioner VERIFICATION Kevin p, Sullivan hereby verifies that the facts set forth in the foregoing Petition are true and correct to the best of his knowledge, information and belief, and understand that false statements herein are made subject to the penalties of 18 Pa, C.S, g4904 relating to unsworn falsifications, ~ ;J Jo ... Kevin p, Sullivan Date: ~Y,('I.In-J' b, 2006 , '. Exhibit "A" . , DEe 0 7 l005 /)/ J~ KEVIN p, SULLIVAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Ys. : NO. 05-5459 CIVIL ACTION - LAW SARAH A. CARTER, Defendanl IN CUSTODY ORDER OF COURT AND NOW, this /:<. th day of December, 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Kevin P. Sullivan, shall enjoy sole legal custody and primary physical custody of Mhorigann Inanna Danu Carter, born June 3, 2002. 2. The Mother, Sarah A. Carter, shall enjoy periods of visitation with the minor child at such times and under such circumstances as agreed to by the parties. 3. In the event Mother is not satisfied with the amount of visitation afforded to her by the Father, or Mother otherwise desires to modify this Order, Mother may petition to have the case again scheduled with the Custody Conciliator for a conference. BY THE COURT, Cc: Sean M. Shultz, Esquire Ms. Sarah A. Carter 7CJ \+- - ~ ~ -..:t ()~ ~ ~ tn .t:: C>- ~~ ~ -L" ;".) c; -f"1 ~ ;-. .,~., ~:-(', : . Q -~,\ 0.' r0 - ;'1\ .. I') C . 1,. RECEIVED FEB 23 ZaJ6 (il'V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: CHANGE OF NAME OF MHORIGANN INANNA DANU CARTER, a minor, to MORRIGAN ELIZABETH SULLrv AN, No. 2006- I()~ CIVIL TERM ORDER OF COURT AND NOW, this ol'lit day of ~, 2006, upon consideration of Petitioners' Petition for Name Change, it is ORDERED that a hearing on Petitioner's request be held on ~7"11 , 2006 at .2:I:J illY!, in Courtroom No, -1-, Cumberland County . Courthouse, Carlisle, Pennsylvania. IT IS FURTHER ORDERED that the 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 ten (1 0) days prior to the hearing; in addition, Petitioner shall comply with all other requirements ofC,C.R.P. 5, and the Act of December 16, 1982, P.L. 1309, Section 6, and 54 Pa, C.S, Section 701 ~t seq, (1995 Supp,).. H. . U . ~\ L'Z..I'l~r (0 d.71$ l701((~ S~.2[! lc.. ~I"c.h t, c.. c..,L,'L ~ ~ ~ ~rl C.Htcl' ~Jfr>i:,{,J-' ~e..l\jI~1... ~L> <.. li\1 <> 1(.,0' I 1"2. { t . r _ I BY THE COURT f'<tS-el',\t!d z.t L 1iIc:.2JI'(} J. ~: C"J ,.-.., C":' (::> :;:-',J r=-= l' e,-) - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: CHANGE OF NAME OF MHORIGANN INANNA DANU CARTER, a minor, to MORRIGAN ELIZABETH SULLIVAN, No. 2006- 1058 CIVIL TERM CERTIFICATE OF SERVICE AND NOW, thist. ~-t"'- day of March, 2006, I, Sean M. Shultz, Esquire, hereby certify that the following peTson was served with a True and Correct copy of the Petition for Change of Name and Order of Court dated February 24,2006, scheduling a Hearing for April17, 2006, at 2:15 p.m. filed in the above-referenced matter. The documents were mailed on March 7, 2006, but actual service took place on March 17, 2006, by Sarah A. Carter signing for a copy ofthe documents which were mailed in the United States Mail, Certified Mail--Return Receipt Requested, Restricted Delivery, Postage Prepaid, addressed as follows: Sarah A. Carter 310 5th Avenue Hornick, lowa 51026 A copy of the signed Domestic Retwn Receipt is attached hereto as Exhibit "A" and by reference incorporated herein and made a part hereof. Respectfully submitted, F,IUser Folder\Firrn Docs\Gel]do,s2006\3884.~ertservi\:ewpd ean M, Shultz, EsqUl Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorneys for Petitioner - SENDER: COMPLETE THIS SECTION . Complete items 1. 2, and 3. Also complete Item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: S a,rali;1, CCV+u 3JO ~ AVt/1ue, ~r(l ~u'( r To wa. 5102w 2. Artit ITra, COMPLETE THIS SECTION ON DELIVERY te of Oe\iV8l"j -.:3, ?C) ~~ D. Is delivery address different from item 17 0 Yes If YES, enter delivery a.ddress below: 0 No 3. !le~Type ~Certjfied Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise DC.a.D. 4. Restricted Delivery? (Extra Fee) es 7005 1160 0002 1108 9339 102S9S-02-M-1540 PS Form 3811 , February 2004 Domestic Return Receipt c; ~" E~ ;:.''-' ~, l".) -1 (:;~ 'n ~~E': --<,~) -> ::<;.' " - ::~~. ~:~; "::/\ --/'-" ~i:: --" r:-? c..J G-) ----- F:ECEIVED FE8 Q ~ ~r'1f') r/z, ..... - L~;. r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: CHANGE OF NAME OF MHORIGANN INANNA DANU CARTER, a minor, to MORRIGAN ELIZABETH SULLIVAN, No, 2006- Jofi> CIVIL TERM ORDER OF COURT AND NOW, this d\ay of /A f " ~ l , 2006, upon consideration of Petitioner's Petition for Name Change, and following a Hearing, IT IS HEREBY ORDERED that Mhorigann Inanna Danu Carter's name be changed from Mhorigann Inanna Danu Carter to Morrigan Elizabeth Sullivan. BY THE COURT J. ~~ o \:,~' -- ~"~:;. o I": '1-:( .....,...,i . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: CHANGE OF NAME OF MHORIGANN INANNA DANU CARTER, a minor, to MORRIGAN ELIZABETH SULLN AN, No, 2006- 1058 CNIL TERM PRAECIPE To Prothonotary: Pursuant to the Order of Court dated February 24,2006, attached please find copies of the Proofs of Publication ofthe publication of the Notice of Hearing in the above-captioned matter. The Notice of Hearing was published in the Cumberland Law Journal on April 7, 2006, and in The Sentinel on March 30, 2006, Respectfully submitted, Date: April 12, 2006 A;:cL n ,Shultz, Esquire Attorney ill No, 90946 II Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorneys for Petitioner F\User Folder\Firrn Docs\Gendocs2006\3884.2praecipe,wpd PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tammv Shoemaker, Classified Advertising Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said Cotmty, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s) March 30, 2006 COPY OF NOTICE OF PUBLICATION NOTICE NOTICE IS HEREBY GIVEN that on the 28th day of . February, 2006, the Petition of KEVIN P. SULLIVAN was flied in the Court of Common Pleas of ... Cumberland County, Pennsylvania, praying for a decree to change his daughter's name from Mhorigann lnanna Oanu Carter to Morrigan Elizabeth SulliVan. The Court has affixed the 17th day of April, 2006, at 2:15 p.m. in Courtroom No.1 of the Cumberland County Courthouse as the time and place for the hearing of said Petition, when and where a\l persons interested may appear and show cause, if any they have, why the prayer of said Petition should not be granted. Sean M. Shultz, Esquire KNIGHTS & ASSOCIATES, P .C. 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717)249-5373 Attorney for Petitioner Affianl further deposes that he / she is not interested in lhe subject matter of the aforesaid notice or advertisement, and that all allegations in the foreg;oing statement as to time, place and character of .J::~~ Sworn to and subscribed before me this 31". day of March2006. C'-IuiM1iCL 'A. W Notar~lic My commission expires: q I t IOf COMMONWEALTH OF PENNSYLVANIA Notarial Seal Cl1nstina L Wolfe, Noiary Public Carlisle 80m, Cumberland CounIy My CommiSSlOn Expi~ Sept 1 , 2008 Member. Penn~vlvarll:? A!lSOc18tlOn Of Notaries AD r. . L. """ 1 :: L ;M' . ~ ~ ) A ~o,3336 CUMBERLAND LAW JOURNAL NOTICE NonCE IS HEREBY GIVEN that on February 28, 2006, the Petition of Kevin P. Sullivan was filed in the Court of Common Pleas of CUmber- land County, Pennsylvania, praylrlg for a decree to change hiS daugh- ter's name from Mhor1gann Jnanna Danu carter to Morrlgan Eli2abeth Sullivan, Tlle Court has affixed Apr1l 17. 2006. at 2: 15 p.m. In Courtroom No, 1 of the Cumberland County Court- house as the time and place for the hearlIlg of sald Petition, when and where all persons interested may appear and show cause, If any they have, why the pr~J: of said Peti- tion should not be granted, SEAN M. SHULTZ, ESQUIRE KNIGIIT & ASSOClA1'ES, P,C. Attorneys for Petitioner 11 Roadway Dr1ve Suite B Carlisle, PA 17013 (717) :0<49-5373 Apr. 7 4 D --: (.-.