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HomeMy WebLinkAbout07-0106 KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY 1.0. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA IN RE: J.L.S. NO. D'[- 16h eLu~l '----t~ CIVIL ACTION PETITION FOR NAME CHANGE 1. Petitioner is Lori L. Scandle, the guardian and natural mother of Janee' L. Salmond, a seven year old minor who was born on August 17,1999. 2. Petitioner desires to change her child's name from Janee' L. Salmond to Janee' L. Scandle. 3. There are no judgments or decrees of record or any other matter of like character against the child. 4. Petitioner's reasons for desiring this change of name of her child are as follows: a. Petitioner is not married to the child's natural father and Petitioner is using her maiden name of Scandle; b. The child is of the age where she attends school and Petitioner desires to protect her child from the psychological and emotional -~ confusion which may result from the child and parent having two different surnames; c. The child's natural father, Darrell K. Salmond, has chosen to waive both legal and physical custody rights with the child; d. The child's natural father has repeatedly failed to contribute to her financial support; and e. The child's natural father is currently incarcerated for failure to pay child supportlarrearages for more than one of his natural offspring. The natural father's engagement in notorious conduct has already served to alienate the child. 5. During the three years preceding the filing of this Petition, the subject of this Petition has lived with her natural mother, the Petitioner, at 7043 Carlisle Pike #321, Carlisle, Cumberland County, PA 17015. 6. From the subject's birth until three years preceding the filing of this Petition, the subject of this Petition has lived with her natural mother, the Petitioner, at 251 Marlette Drive, Mechanicsburg, Cumberland County, PA 17050. WHEREFORE, Petitioner respectfully requests that this Honorable Court: a. Fix a hearing on this petition; and b. Direct that notice be given of the filing of this petition and the hearing. WHEREFORE, Petitioner further requests that this Court waive the requirement for official searches of the proper offices of the county wherein Petitioner resides on the grounds that the subject of this petition is a minor and Petitioner avers that there are no judgments or decrees of record or any other matter of like character against the child. WHEREFORE, per 54 Pa.C.S.A. 9 701 (a.1 )(3)(iii), Petitioner further requests that this Court waive the requirement for publication of the notice in two newspapers of general circulation on the grounds that the subject of this petition is a minor, and Petitioner does not wish for predators or the like to have access to the child's name and address. Respectfully Submitted, By: Dated: \ ('3 {/)1 J~-3-2007 12:17 FROM:SMITHRAD 7177747529 ~1/~3/20a7 12:12 717-751-7572 TO: 7617572 KlFE g ASSOCA TES P:1/1 PAGE: 85185 VERIFICATION I. Lori L. Scandle. the Petitioner in this matter, have read the foregoing Petition for Name Change. I verify that my averments in this Petition are true and correct and based upon my personal knowledge. f understand that any false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unswom falsificatiOns to authorities, Dated: 1- 3 -Or Lori~~~ 1st Rv ~ ~ \) """'- ~ ~ tV r () c: Q)~f ~~;~ ~ ~i:~'~j ,> ,,".c =;;~; ~ -4 ,....." ~ ~ --' ~ :r"'i z :~ .j, i'3 -0 =? "T' 3: ~~~ N ~ ~ ~ - . , . !J JAN 08 200?f KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY 1.0. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA IN RE: J.L.S. NO. 07 - Ic::io CIVIL ACTION Ctc,)~L'-r ~ ORDER OF COURT FIXING HEARING AND NOW, this r day of r~(J:2007, upon consideration of the attached Petition for Name Change filed by the Petitioner: 1. A hearing on the Petition of Lori L. Scandle for change of name is fixed for ... ft.~ >,2007,at3.'3ao'clockAm,at ~j f~. 2. The Petitioner is not directed to give notice of the hearing by publication in two newspapers of general circulation in Cumberland County, Pennsylvania, one of which publications may be the official paper for the publication of legal notices in that county. 3. Petitioner is directed to give notice of the hearing to any non petitioning parent of the child whose name is affected by the proceedings. By: J. '-iJ\~'l":f !\;\,:.sN\~;1d nr _~ ,".," J"" ;~r""'\I"\(\1"\ ,\ It-\ '.' \' . ,~\::. \.,.-~,,"."\ Iv f')..r~\ ,.,.'" ',' .;, ' -- g~ ~t. \\d 6- \-\~r lU~'l. ~ui;j\O\~O'r\l.O'dd 3rU. jO . - 3~)\j:\b-Gj\\:\ KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA IN RE: J.L.S. NO. 07-106 CIVIL ACTION CERTIFICATE OF SERVICE I, Lesley J. Beam, Esquire do hereby certify that on this 11th day of January, I served a true and correct copy of the foregoing Petition for Name Change and Order of Court scheduling hearing via certified mail, postage prepaid, addressed as follows: Darrell K. Salmond Dauphin County Work Release Center 919 Gibson Blvd Steelton, PA 17113 ROPE & ASSOCIATES LAW () F F ICE S L I.C January 11, 2007 VIA CERTIFIED MAIL Darrell K. Salmond Dauphin County Work Release Center 917/919 Gibson Road Harrisburg, PA 17113 Re: In Re: J.L.S. 07-106 Dear Mr. Salmond, I represent Lori Scandle in the above captioned matter. Enclosed and served upon you is the Petition for Name Change, filed with the Cumberland County Court of Common Pleas, and Order of Court scheduling the Hearing. I am sending these papers to you directly because I have no information that you are represented by an attorney. Please be aware that the Hearing has been scheduled for Monday, March 5, 2007 at 9:30 am at the Cumberland County Courthouse. This will be your official notice of that Hearing and you are required to attend. If you have any questions, please feel free to contact me. But, please be aware that I cannot give you legal advice because I represent Ms. Scandle. Thank-you for your kind attention to this matter. Sincerely, K~;i~S~~ ~SIe0i ~~e Enclosures Smart Representation 4660 Trindle Road. Suite 201 . Camp Hill, PA 17011 P 717.761.7573. F 717.761.7572. kopelaw.com ..---............-.. j JAN 0 8 2007 fr^ KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY 1.0. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA IN RE: J.L.S. NO. 0'7 - /6b CIVIL ACTION Cll->~LT ~ ORDER OF COURT FIXING HEARING AND NOW, this ~ day of ~007, upon consideration of the attached Petition for Name Change filed by the Petitioner: 1. A hearing on the Petition of Lori L. Scandle for change of name is fixed for ... '1\ ~- fj' '" " .- .. r / ~ .... it-' ,vi~\ ;; ,2007, at ~. .~O o'clock A m, at . 'J ~~. ; . 2. The Petitioner is not directed to give notice of the hearing by publication in two newspapers of general circulation in Cumberland County, Pennsylvania, one of which publications may be the official paper for the publication of legal notices in that county. 3. Petitioner is directed to give notice of the hearing to any non petitioning parent of the child whose name is affected by the proceedings. J. By: KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY 1.0.91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA IN RE: J.L.S. NO. 07 - JOe.- ~uL'-r~ CIVIL ACTION PETITION FOR NAME CHANGE 1. Petitioner is Lori L. Scandle, the guardian and natural mother of Janee' L. Salmond, a seven year old minor who was born on August 17, 1999. 2. Petitioner desires to change her child's name from Janee' L. Salmond to Janee' L. Scandle. (') ~ c.: = s: -.I 3. There are no judgments or decrees of record or any other matt~~f lik~ L.. '.,.. , character against the child. ~? ~,: U1 ~~') ~ 4. Petitioner's reasons for desiring this change of name of her chilif ate N --,.. , .::.... =< Ul \.0 as follows: a. Petitioner is not married to the child's natural father and Petitioner is using her maiden name of Scandle; b. The child is of the age where she attends school and Petitioner desires to protect her child from the psychological and emotional ~ ~ n,:D r- -om 256 ---l, I:Il 0(") am ~ -< confusion which may result from the child and parent having two different surnames; c. The child's natural father, Darrell K. Salmond, has chosen to waive both legal and physical custody rights with the child; d. The child's natural father has repeatedly failed to contribute to her financial support; and e. The child's natural father is currently incarcerated for failure to pay child supportlarrearages for more than one of his natural offspring. The natural father's engagement in notorious conduct has already served to alienate the child. 5. During the three years preceding the filing of this Petition, the subject of this Petition has lived with her natural mother, the Petitioner, at 7043 Carlisle Pike #321, Carlisle, Cumberland County, PA 17015. 6. From the subject's birth until three years preceding the filing of this Petition, the subject of this Petition has lived with her natural mother, the Petitioner, at 251 Marlette Drive, Mechanicsburg, Cumberland County, PA 17050. WHEREFORE, Petitioner respectfully requests that this Honorable Court: a. Fix a hearing on this petition; and b. Direct that notice be given of the filing of this petition and the hearing. WHEREFORE, Petitioner further requests that this Court waive the requirement for official searches of the proper offices of the county wherein Petitioner resides on the grounds that the subject of this petition is a minor and Petitioner avers that there are no judgments or decrees of record or any other matter of like character against the child. WHEREFORE, per 54 Pa.C.S.A. ~ 701 (a.1 )(3)(iii), Petitioner further requests that this Court waive the requirement for publication of the notice in two newspapers of general circulation on the grounds that the subject of this petition is a minor, and Petitioner does not wish for predators or the like to have access to the child's name and address. Respectfully Submitted, By: j Dated: \ ('3 {D1 . JAN-3-2007 12: 17 FROM: SMITHRAD 7177747529 ~1/a~/20e7 12:12 717-761-7572 TO: 7617572 KCFE & ASSOCA TES P: 1/1 PAG€: B5/135 VERIFICA TJON I, Lori l. Scandre, the P~itioner in this matter, have read the foregoing Petition for Name Change. I verify that my averments in this Petition are true and correct and based upon my personal knowledge. I understand that any false statements herein are made subject to 'the penalties of 18 Pa. C.S. 4904 relating to unswom farsifications to authorities. Dated: 1- 3 -Ot Lori~jQ~ '-0 ~ = = ......., <- :t:... --~ --- o ..., 5! n1;!:! -ry fT1 &~ Cjr'r'! 0:,-1 55 -< Ol -0 -= - .r;;- .. KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY 1.0. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Petitioner IN RE: J.L.S. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA NO. 07-106 CIVIL ACTION AFFIDAVIT AND RETURN OF SERVICE AND NOW comes Kope & Associates, LLC by LESLEY J. BEAM, attorney for Lori Scandle, natural mother of J.L.S., and states that service of the Petition for Name Change and Order of Court scheduling the hearing in this matter was made by her upon Darrell K. Salmond, natural father of J.L.S., by posting the same in the U.S. Mail, postage prepaid, at Camp Hill, PA by Certified Mail No. 7004 2510 0007 6450 0922, Return Receipt Requested on January 29, 2007, to his mailing address, at 3620 Brookridge Terrace, Harrisburg, PA 17109, which mail was received by Darrell K. Salmond on February 8,2007, all in accordance with PA.R.C.P. 412 and 403. The mailing receipt and the return receipt or true copies thereof are attached hereto and made part hereof, together with the cover letter mailed to Defendant. /-~ ,/" /' ,// // (-;I" ,] ..-..~ , it .I .~ I ~ . \ i'O~""-&lO ~ ~ '0 .)" z I 0 00 '" 0 ~ , ~ 0 ~..< a i ~ il ru \ :t:]-u l~ ~ ru Q)' ~ ~ ! <t>.l-} i~ .l p- o ~ ~) I ~ ~ ~ () i 000 . 0 . ~U' ~ "* _i U1 {-!I:iQ :r iil 'a ~ JI i~~~~ l~l~ ~ f" 11 I r'-' 'it~i_7.) 0 9- 1 ~t~~ ~ l~' 0 i aD! 0 i IX: .!l == ~ . " c::i /" t? ~ 0 i ~ ~ U1 ru 1 l~ :s- o 0 <r- r'-' ~ 1= >-Q) "1 \J .... g c:2=ai -r r- <.!!! 010:: (f) ~ t'i~i ~E ',> ..... 'tl~-cQ).8! . Y rr- I ~ i~i=Q)8 ~ 0 ~ cS N 'tl E= ~ ~. ~ I' ~ _"ii::loC... rot or ,!..rn S IU~n11~ ~ u. . or- gi .... co ~~~,j;~ lAc J it (l) c.. 'Ot g. 10 € c: J! q E ~E~=~~ ~ ~ '~ ~& ~ 0.. g C( 0 11(\ ~ (/) . .. ..;. 0.. S' ~ " ~ 8 :;) <Ii ct :t I- 'll ~ a.. ~ ~ - Co> ;: UJ "'0 co U<..l ~ UJ?j~ a: ~ ~ :5 :3 -1~:: CJ --00 U <( 0 '; .- <: 2: 2 ~Q CJoe ro Cf) 0 E - UJ:-:::: ~ ro - Cl'J C +-' Ll.. ~ .- fJ)_u ~ o I-'~ .~ c-a:'ll1) u)w~'C '" 0 ~_ ::> \..; '.- \ Ii '..1 7<t~ <J ~ .- ~ o 'i .. (I) '.~IUIUJ ~ 11111) j ., . I J ~ 2260 OS~9 LOOO O~S2 .._._~ .. , ~ ~. fr0. i \::::::./ \~:::~'/ K 0 P E & ASSOCIATES LAW OFf'ICES LLC January 29, 2007 VIA CERTIFIED MAIL Darrell K Salmond 3620 Brookridge Terrace Harrisburg, PA 17109 Re: In Re: J.L.S. 07-106 Dear Mr. Salmond, I represent Lori Scandle in the above captioned matter. Enclosed and served upon you is the Petition for Name Change, filed with the Cumberland County Court of Common.Pleas, and Order of Court scheduling the Hearing. I am sending these papers to you directly because I have no information that you are represented by an attorney. . Please be aware that the Hearing has>beenschedu1edior Monday, March 5, 2007 at 9:30 am at the Cumberland County Courthouse.. . This' will be your official notice of that Hearing and you are , required to attend. H you have any questions, ple~efeel.f1'eetoc()ntactJl1ie.. But; please be aware that I cannot give you legal advice because I tepresent.~.Scan.dle.'I'l1a.rik-youfor your kindia~tion to this ' .. matter. . . Sincerely, Enclosures Smart Representation 4660 Trindle Road _ Suite201 _ Camp Hill,PA 17011 P 717.761.7573 - F 717.7fJl.7572 - kopelaw.com (') <;; -04_" ~-v\ ~, . ~q z(; __ f~C ..::.~- ~~ ~ c.3 ...,., ~ r-:> CP ? ~ ~e i1J :'f;t( C~")~i "2-~ S -"", ~ ~ :$ - - <...J -J . , .. KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY 1.0.91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA IN RE: J.L.S. NO. 6"l - !CIc C.,,:L T~ CIVIL ACTION ORDER OF COURT CHANGING NAME AND NOW, this ~ day of M~ ,2007, upon consideration of the attached petition and after hearing, it is found as a fact that the requirements of 54 Pa.C.S. ~ 701 have been satisfied and the name of the minor child is changed to Janee' L. Scandle. J. ~i < ~ l' v I \ C) '-l ' if ~ r ~ B I : II HV s- ~Vt~ LUfJZ AtIvlO:\;Ci-LL~)~d 3Hl :10 3~;I:;:!;O--03llj