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HomeMy WebLinkAbout95-04299 . '" . ' if:: ~ M r- ,. l.T.~.: .( . II' ~':, , ; 1\ r;;;7'" I';.. (:JUo!_ 1_,.1:,_-) , ~_.) , I ., ," "". ',j' ~ "':',:, ,'.:.01 lo. ~, .,j t~' ~ " McNEES, WAl.l.ACE 80 NURICK 100 PlNI 8T'UIT p, O. .Olt II UI HA""I'BU:"Q, PA 17108 . . , . - ~ WIlJCID,~n ~",IQV""QN JII lMC",pOII~ M)Mltl',""CHIII"" ~,.t;..nNIJII QoWIQ.. (JIll'll\' _",AU A OOC'''CMi luv.Itl'H.. OOU~U'" HNNlY'''UOCN'''1M) ""'UI.,,'MI ,IIINCII. HAM, "" w.JI"~J"NCVNLAIJ WK:H~L I), JAA...fo.N ~\IID M, tlU'ItINOlR ....,.0,. LJ.IIUl!iIl[&, J" DlVI'IOJlf,L.,ANTI ( ( McNEES, WALLACE & NURICK ATTORNEYS At l.AW "'(I'I>J1l)'lll,~-l"UI O"'~IDl Ll~''''''''' 'L,o!:w""'NIHII ,,,,,/jIl~IN '" ""'LUlI,..I1t F1QPUHfl, ""LI.lI &IlPt<lI'j,A MoolIE MlII"P"" Nullu,:" ",eMN6 OlLiff 11"'01"'J ,,"6'l" ~,"",,'''1I' [CW,&llOW HO,~.h1"N 0"1'1" .'tv[kl M:..OIJYO IIOIU" D. &11:1& 111(...,.,.0* 'n....n...ON CIfl,Nlt.l TOIlJo.H!iIloY 01'\110'"' WAllS,"," lOll PINt..: 6' m:r, r p,o UOX 1100 t.n...u..j\lllltj........H:t. NU'LI5 ....u.1 NUll"''''''' ......,Il V.,.,.'H tiC I: II .".,(Cl'lI 11Jl.1Iyf llN,.QiIol'llll WllL.III"'h1 ',,"lJhQ",II H"FH1t60URG, PA 17100.1I0t) rHlPtlCld 17171 jl:3Z'~OOO F.....1711l2l7'l)lOO C' CC')IJNflL nOUJIII ,.,~,,&....O\.o f>Ahlut:\.,. 6(:t,"lOJH(l,\U&T, ",II, [llleN ,.,..tV O"''''ON D",..tR .I0NAl~I",N c, IItlUf" .""", 0 0......11 .I"''''U,.O......N~llt:l "''''hlU P OOl/OtIIIU" IlAH.~UN" OIJNat ROII~ln J o.oOUTO August 28, 1995 Valeri I7.railievich Dubrovitsky c/o Izrail Grigorievich 208 Senate Avenue, Apt. 615 Camp Hill, PA 170ll. Dear Mr, Dubrovitsky: &(0" '" OOIJ~D " tlICf<Ot....e (,\1J,."I'll~f<nLl ,1COU"0 ....v.a tlAlolH' J"'C~H OONol~O II lVo-lJ,,....H hlIC,'olnAI'[U[" PPUH" ""I[Tl ","'hlt6W l'UU C'-'MILLtc;.,..",flION IH",IlQN" "M'ON CHIJONr)...,'..."',.. JON""H"'~j '"'. RVOO "IIVer",.,..CI" ColROl.A,IUINOIJR C..t...tPlNr (, w...~ll,.. C~lIlm;1l P Wl..u......1ON Enclosed ~nd served upon you is a Petition for Change of Name of Pavel Shirokov, Also served upon you is a signed Order of Court setting a hearing date before the Court on this petition for Change of Name on October 2, 1995 at 8145 a.m, in Courtroom No, II, cumberland County Courthouse, High and Hanover Streets, Carlisle, Pennsylvania 17013, united States of America. Also enclosed is a copy of the Notice of Petition and Hearing For Change of Name which will appear in the Cumberland Law Journal and The Sentinal, the newspaper of general circulation in Cumberland County, Pennsylvania, Very truly yours, &tLfj 91, /A; Betsy A, Ruth Litigation paralegal Enclosures - EXHIBIT 'C" - liA :i t: , , ~, wf " if: ,_. ;..1 u."., U:"r: , m .~~ 0.:' , " ~:i I.lJ,~ " N '.,/, ,I ,~ , ~ ., ,. " ~ , ., , ":':'1 , , , , " McNEES, WALLACE Be NURICK '00 PINE fl1RElEY 1'. O. .011I II ,. HA""II.UAa. ", 17108 '{I '\ .\ , '\"' <,,1 > !Y" I" ') , ,;'S-v tJ '1 "",'" .~~} I ) -: IV I) \ \. IV "- ~f~ ,I' V'" \'!~ >)1' vvJ , , ~ ~ . :.or.: u_ o Ul \'? ~ &:~ ..u:( .... '~\ ; "- , 'I, ,:J ..,.,; ..' ,J ..,.., ~-6 "'l-- ~ ~~ '-j n~--) -- '~ \~ .., ..., ~ ?"- m ~ 1\"') <'\') .... I<j ....... 'I' ~...... ~~~ ~ .~ , ' McNEES, WALLACE a NURICI< 100 'INI a1,u:r.T " O. Ii<l.l.' I" HA",.I..UIU" PI. '7101 AUS 16 msi> ~ . . . 5. While in Russia, she married Valeri Izrailievich Dubrovitsky. Petitioner Maria Smith's maiden name was Maria Vsevolodovna shirokova. She and Mr. Dubrovitsky were divorced in 1985 in Moscow, Russia, After her divorce from Mr. Dubrovitsky, she resumed her maiden name, Also, petitioner chose to have her son nssume the last name of Shirokov which was an option available tu her under Russian law. Petitioner Maria Smith's visa and green card are in the name of "Maria Shirokov", 6. petitioner Pavel Shirokov is the son of petitioner Maria Vsevolod Smith and Valeri Izrailievich Dubrovitsky. He was born on April 29, 1982 in Moscow, Russia, At birth, his name was Pavel Valerievich Dubrovitsky, When his mother and father divorced, his name was changed to Pavel Valerievich Shirokov, On his green card and social security card hiD name is Pavel Shirokov. 7, After the divorce and until November 1989, when Petitioners left Russia, Pavel Shirokov had very little contact with his father. 8, Since Petitioner, Pavel Shirokov, left Russia in November 1989, he has had no contact whatsoever with his father. 9. Since November 1989, Pavel's father has made no contribution whatsoever to his support or maintenance, 10. As of today, neither Pavel Shirokov nor. Maria Smith are U.S. citizens. However, they intend to become U,S. citizens in the near future. - 2 - d. petitioner has not had any contact with his natural father since sometime prior to November 1989; e. Petitioner has used the first name "Paul" on an informal basis for three years. He has used the surname of "Smith" on an informal basis since his mother married Dean Smith. f, His green card and social security card do not list a middle name or initial, He wishes to adopt a middle name and believes "Jonathan" is the appropriate middle name for him; g, The change of name will best meet petitioner's social and occupational needs as a resident and anticipated future citizen of the united States of America and the Commonwealth of pennsylvania, 13, Petitioner, Maria vsevolod Smith has under appropriate laws validly adopted her current name, However, Petitioner requests the court to confirm her present name as her lawful name to clarify and remove any issues that may arise with respect to her legal name. 14. There are no judgments or decrees of record in cumberland County or Dauphin County against either of your Petitioners, 15, This Petition is not presented for the purpose of avoiding payment of taxes or other debts, but solely for the purposes set forth above, - 4 - 16. Petitioners do /lot know the pres~nt address of Valeri Izrailievich Dubrovitsky other than he resides in Russia. He refuses to give his address to the Petitioners because he is afraid that a suit would be filed against him for child support. However, Mr, Dubrovitsky's parents live at 208 Senate Avenue, Apt, 615, Camp Hill, PA 17011, His father's name is Izrail Grigorievich. Also, Mr. Dubrovitsky receives faKes at 011-7- 095923-3858, Petitioner will provide notice of the filing of the petition and the scheduled hearing to Mr. Dubrovitsky in care of Izrail Grigorievich and by fax to the above number, 17, Your Petitioners request the court to authorize and direct the publication of the notice of this petition in the Cumberland County Reporter and The Sentinel, Carlisle, Pennsylvania, WHEREFORE, your petitioners request the court to enter an order scheduling a hearing on the petition for a date at least thirty days after the date of the order and directing (a) the publication of the notice of such hearing in the Cumberland County Reporter and The Sentinel; and (b) service of notice of the hearing and the filing of this Petition on Valeri Izrailievich Dubrovitsky by first class and certified mail in care of Izrail Grigorievich, 208 Senate Avenue, Apt, 615, Camp Hill, PA 17011, and by faK directed to Mr, Dubrovitsky at 011-7- 095-923-3858, Upon such hearing, the court is requested to grant your Petitioners' petition and to order that: - 5 -