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HomeMy WebLinkAbout02-16-07 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ANDREW F. KING, a minor over 14 years of age, : NO. Petitioner : ORPHANS' COURT DIVISION C) '" roo' = :-=0 ~ -.:;~ -,., ;J- Q f;] g~ :: \.... ~ AND NOW comes the Petitioner, Andrew F. King, a minor over ~ ~ars of@e, w Co PETITION and petitions this Honorable Court as follows: 1. The Petitioner is Andrew F. King, who currently resides at 487 W oodcrest Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050, and whose date of birth is March 31, 1991. 2. The Petitioner's natural mother is Karen L. King, who resides at 3236 Trinity Road, Harrisburg, Dauphin County, Pennsylvania 17109. 3. The identity ofthe natural father of the Petitioner has never been established, nor is there any available information regarding the identity or location of said natural father. 4. The Petitioner resides with his maternal uncle, John F. King, Esquire, his aunt, Gail L. King, and his cousin, John F. King, III, in said uncle's residence at 487 Woodcrest Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 5. The Petitioner's natural mother, Karen L. King, consents to this instant Petition, and by such consent does aver that the relief sought in this instant Petition is in the best interests of the minor child Petitioner. v 6. The necessity for the appointment of a Guardian for the Petitioner is averred as follows: A. The Petitioner has been raised by his natural mother in an only child, single parent home since the date of his birth. B. The Petitioner's natural mother, Karen L. King, is a hearing officer for the United States Department of Agriculture, and does work out of her home in that capacity. C. The Petitioner's natural mother has initiated the relocation of her residence and offices from her current residence to Cumberland County. D. The Petitioner's natural mother is currently unable to provide the necessary emotional support and disciplinary oversight to the Petitioner, which would otherwise be required for the Petitioner to thrive in his school and social settings. E. The Petitioner has recently moved in with his uncle, aunt and cousin in their residence in Hampden Township, Cumberland County, Pennsylvania, which residence is of sufficient size and quality to provide an appropriate, safe residence for the Petitioner. F. Petitioner's uncle is able to provide the necessary emotional support and disciplinary oversight to the Petitioner, which is required for the Petitioner to thrive in his school and social settings. 7. The proposed Guardian, John F. King, Esquire, is the maternal uncle ofthe Petitioner, and does reside at 487 Woodcrest Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050, along with his wife and son, and has resided there for approximately two (2) y~ars, and has further resided in Hampden Township, Cumberland County, for approximately thirteen (13) years. 8. The proposed Guardian does not have any interest adverse to that ofthe minor. 9. The religious persuasion ofthe mother and the proposed Guardian ofthe Petitioner is Methodist. 10. The Petitioner is not entitled to receive any money, nor is he a party to any action or proceeding, in any Court. 11. The Petitioner is not the child of a Veteran. WHEREFORE, Petitioner respectfully requests this Honorable Court appoint John F. King, Esquire as the Guardian of the person of the Petitioner/minor. Date~>1.l..lll~ (7; d::i17 drew F. King 487 Woodcrest Drive Mechanicsburg, P A 17050 (717) 761-8144 Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ANDREW F. KING, a minor over 14 years of age, : NO. Petitioner : ORPHANS' COURT DIVISION CONSENT I, John F. King, Esquire, hereby consent to being appointed as Guardian of Date:~~~L~~, v Andrew F. King. COMMONWEALTH OF PENNSYLVANIA : SS: COUNTY OF DAUPHIN On this, the/'JU day of ~PY'l1n~..L1L, 2007, before me a Notary Public, the undersigned officer, personally appearedJ~~.~g, Esquire, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. '--f)fl/I1~f~ N.)i BARBARA E. City of H3rris"',,,tg, My Comrnis~,:~."i::~:f:~:e:.. COMMDNW: .\{Tl'4 ,-""'-' .., : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ANDREW F. KING, a minor over 14 years of age, : NO. Petitioner : ORPHANS' COURT DIVISION CONSENT I, Karen L. King, am the natural mother of the Petitioner, Andrew F. King, and I hereby consent to John F. King, Esquire being appointed as Guardian of my son, Andrew F. King. I further do swear and attest that there is no available information relating to the identity or location of the natural father of the Petitioner, nor has said paternity ever been established. Date:]&Y1l4 L S- ;?'i\i I ~!!4 41 Kare L. King COMMONWEALTH OF PENNSYLVANIA : SS: COUNTY OF DAUPHIN On this, the I~ay of '-11'~ 2007, before me a Notary Public, the undersigned officer, personally app~ared ~en L. King, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. --Bf1A~ ..p~~ l\;i.) ~. i\ ~~~"j ~\ L : BARBARf\L P('!;,i:'F:, r'i(jti~ry Public City of 1'!;m:::,\J'!(,0;:Da~1?hi~ County My Commii;',\,;1I FX,~n~'; ',""'1 23, 2009 ~-<.".,;.;.:"~.:;;:;;:.::;;:~:.,:::,:;:-~:;:;;:.:;;-,, - ,;.:".,...,~,... ~r1~ : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ANDREW F. KING, a minor over 14 years of age, : NO. Petitioner : ORPHANS' COURT DIVISION STATEMENT OF PROPOSED GUARDIAN, PURSUANT TO LOCAL RULE 12.5-2 1. The proposed Guardian, John F. King, Esquire, is a citizen of the United States and is able to speak, read and write the English language. 2. It is not the intention of the proposed Guardian, John F. King, Esquire, to apply for an allowance for the support or education of the minor during minority. 3. The proposed Guardian, John F. King, Esquire, is not the Fiduciary or an officer or employee of a corporate Fiduciary of an estate in which the minor has an interest, nor is he the surety or an officer or an employee of the corporate surety of such a Fiduciary, and the proposed Guardian, John F. King, Esquire, has no interest adverse to the minor. --. 7 I , Date:*~ 1->: axn