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HomeMy WebLinkAbout95-00455 \" , '.0 ; , ;',.~~~td'~;{ " "flt ,-.:';,,:.~i/!ri!J J'\.{;:~~~ " BCKERT SEAMANS CHmUN '" MELi.arr P.o.BOXIUI " HARIU51IUllll. PA 1"01 : C717)217- .. -. ", ,'" 2 \995~ " .' .H~R ','" . ~,' ....y, 'C PENNSYLVANIA A MINOR ORPHANS' COURT DIVISION NO. OF 1995 PETITION UNDER ORPHANS' COURT RULE 12.5 FOR APPOPINTMENT OF GUARDIAN FOR MINOR'S PROPERTY AND NOW, comes petitioner, Sue Ellen Abi-Nader, by and through her attorneys, Eckert Seamans Cherin & Mellott, who respectfully request that petitioner be appointed guardian of the property of Zeina Abi-Nader, a minor, pursuant to Orphans' Court Rule 12.5, and in support thereof represent as follows: 1. Sue Ellen Abi-Nader (the "Petitioner") resides at 605 Green Spring Road, Newville, Cumberland County, Pennsylvania 17241. 2. Petitioner is the natural mother of Zeina Abi-Nader, a minor (the "Minor"). 3. Minor is under the age of fourteen, having been born on March 29, 1989. 4. Minor resides with Petitioner at 605 Green Spring Road, Newville, Cumberland County, Pennsylvania 17241. 5. Jihad Abi-Nader, the natural father of Minor, is deceased, having died on July 4, 1992, as the result of an automobile accident. 6. As a result of the automobile accident, a lawsuit was commenced on behalf of Jihad Abi-Nader and/or Minor in the State of New Jersey. 7. As a result of the lawsuit, Minor was awarded certain monetary damages (the "Monetary Damages"). 8. Minor's Monetary Damages are currently being held on her behalf by the Middlesex City Surrogate's Office of the State of New Jersey in an interest bearing deposit account. 9. As of November I, 1994, Minor's Monetary Damages, together with accrued interest, are in an amount equal to $39,220.19. "" ....;. IN RE: PROPERTY OF ZElNA ABI-NADER, A MINOR . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV ANlA ORPHANS' COURT DIVISION NO. OF 1995 CONSENT OF GUARDIAN Sue Ellen Abi-Nader hereby consents to her appointment as Guardian of the property of Zeina Abl-Nader, a minor. :2u f"- Iq9~ Date ~"I ///~_ /.J,L..-7/rtd..... Sue Ellen Abl-Nader ~lI.48fi',.."..~,;;,:~,f~ji"'f.\IlnM~,n~_i'!_':""""~';:" L':,.~;c.;;"~','U"'-i''f:_'-t'''i;,-,...-;~_",,,,,,,,:;e'~''''N"..~jt._,;,;;j);~""'_"__. -" .. IN RE: PROPERTY OF ZEINA ABI-NADER, A MINOR IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. OF 1995 VERIFICATION I do hereby .verify that the facts set forth in the foregoing document are true and correct to the best of my knowledge, information, and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. fi4904, relating to unsworn falsification to authorities. DATED: .;2& 9,-. 1'l"S- Su' ?//.... /l/~'-~1"LI Sue Ellen Abl-Nader IN RE: PROPERTY OF ZElNA ABI-NADER, A MINOR IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV ANIA ORPHANS' COURT DIVISION NO. OF 1995 AND NOW, this _ day of , 1995, after consideration of the within Petition, pursuant to Orphans' Court Rule 12.5, this Court hereby (i) appoints Sue Ellen Abi- Nader as Guardian of the property of Zeina Abi-Nader, a minor, to serve without bond, and (ii) directs the Middlesex City Surrogate's Office of the State of New Jersey to transfer any and all funds held on behalf of Zelna Abi-Nader to this jurisdiction to be held on behalf of Zcina Abi-Nader by said Guardian. ", pRDER President Judge In Orphans' Court Division .--- <~lp()..5~ W!.(!\.J-t.t. ()..pproff\a..h \ or O-L"'- ()..W\.tI- ~-h~_ ()..:bl:.o..ckt..PL- C.19 (~" . '-f\r\o-U- .~av- ;~:,~~;'i'!'f'~!y",~,*,6~'i':~,~~~_~_~tlw~t;II>k ,'. , ,y.J..,"OY'- (\./' '~ \..~ ~ CJ-""'I$. u...O v-- CR.\ ~rf'"\ ~~~ ~ " , \ i , , . CV \ t.o..c;.e. \ , , \ ',' ,-{ \;- , , "-~--. BCKERT SHAMANS CHBIUN '" MELLOI'I" , P.o._'1UI " IWlRISlIUIlO, PA 11101 C717l Z17.- ' - .BAR 'i~~11 "j)$+~ ,'f: ... 'f."" '.,.( CUMBERLAND PENNSYLVANIA ORPHANS' COURT DIVISION NO. OF 1995 PETITION UNDER ORPHANS' COURT RULE 12.5 FOR APPOPINTMENT OF GUARDIAN FOR MINOR'S PROPERTY AND NOW, comes petitioner, Sue Ellen Abi-Nader, by and through her attorneys, Eckert Seamans Cherin & Mellott, who respectfully request that petitioner be appointed guardian of the property of Zeina Abi-Nader, a minor, pursuant to Orphans' Court Rule 12.5, and in support thereof represent as follows: 1. Sue Ellen Abi-Nader (the "Petitioner") resides at 605 Green Spring Road, Newville, Cumberland County, Pennsylvania 17241. 2. Petitioner is the natural mother of Zeina Abi-Nader, a minor (the "Minor"). 3. Minor is under the age of fourteen, having been born on March 29, 1989. 4. Minor resides with Petitioner at 605 Green Spring Road, Newville, Cumberland County, Pennsylvania 17241. 5. Jihad Abi-Nader, the natural father of Minor, is deceased, having died on July 4, 1992, as the result of an automobile accident. 6. As a result of the automobile accident, a lawsuit was commenced on behalf of Jihad Abi-Nader and/or Minor in the State of New Jersey. 7. As a result of the lawsuit, Minor was awarded certain monetary damages (the "Monetary Damages"). 8. Minor's Monetary Damages are currently being held on her behalf by the Middlesex City Surrogate's Office of the State of New Jersey in an interest bearing deposit account. 9. As of November I, 1994, Minor's Monetary Damages, together with accrued interest, are in an amount equal to $39,220.19. IN RE: PROPERTY OF ZElNA ABI-NADER, A MINOR IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA ORPHANS' COURT DIVISION NO. OF 1995 CONSENT OF GUARDIAN Sue Ellen Abl-Nader hereby consents to her appointment as Guardian of the property of Zelna Abi.Nader, a minor. ;lId f~L- Iq9~ Date "-.,.0.1 f//-.. 4./~'.-~1" ,/~~ Sue Ellen Abl-Nader IN RE: PROPERTY OF ZBlNA ABI-NADER, A MINOR IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. OF 1995 VERIFICATION I do hereby verify that the facts set forth in the foregoing document are true and correct to the best of my knowledge, Information, and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. e.s. fi4Si04, relating to unsworn falsification to authorities. DATED: ~u t<>-. I'I'IS ':-...1 I//,_~ Alri"-1/,.rJ., Sue Ellen Abl-Nader ':7 J"""14h.~~$~~,,I~--"'..~ '~""f"~-";'-f;,;~;;"~'. '~ , COMMONWEALTH OF PENNSYLVANIA COURTHOU5E 1 counntOUBE SQUl-flE CA"U6lt. PA. 17013.3307 17171 240-e211O HAROLD E. 5HEEL Y PRElWOENT JUDGE March 24, 1995 ""7 j "' (; " J I -" Robin L. Barber, Esquire 213 Market st. P.O. Box 1248 Harrisburg, Pa. 17108-1248 Dear Ms. Barber: 20 P.S. 5112 (3) prohibits the court from appointing a parent as guardian of the estate of a minor. I would have no objection to an order authorizing the proceeds being payable to you as counsel for the parties and the money then being deposited under your direction in a restricted account of same type. This would eliminate the necessity for a guardian and without the expense. Vile truly You~s I \2 tl..., - . ,,--.--.- H rold ~. Shee y,' P.J. HES/sld IN RE: PROPERTY OF ZEINA ABI-NADER, A MINOR IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV ANIA ORPHANS' COURT DIVISION NO. II S-..;- OF 1995 ORDER t 'I J AND NOW, this ~ day of '.LL.,~"-, 1995, after consideration of the within Petition, this Court hereby directs that: (1) The Middlesex City Surrogate's Office of the State of New Jersey shall transfer any and all funds held on behalf of Zeina Abi-Nader to this jurisdiction by making a check payable In the appropriate amount to Eckert Seamans Cherin & Mellott; and (2) Eckert Seamans Cherin & Mellott shall deposit said funds in a restricted account established with Members 1st Federal Credit Union, having offices located at 5275 East Trindle Road, Mechanicsburg, Pennsylvania 17055, which account shall be maintained In the form of a twelve-year certificate of deposit, subject to the following restriction: until Zeina Abi-Nader reaches the age of majority, any and all withdrawals from the restricted account shall be made pursuant to Order of the Court. /\l. Ll.t~~1 ( C, S, President Judge In Orphans' Court Division 10111.2 '. 9. As of November I, 1994, Minor's Monetary Damages, together with accrued Interest, are In an amount equal to $39,220.19. 10. Minor is entitled to receive her Monetary Damages, together with aecrued Interest, and desires to have the same transferred to this jurisdiction where Minor currently resides. II. In order to transfer the Monetary Damages and accrued interest, and to protect and preserve Minor's legal rights therein, it Is necessary to establish a restricted deposit account on Minor's behalf (the "Restricted Account"). 12. The Restricted Account shall be established with Members 1st Federal Credit Union, having offices located at 5275 East Trindle Road, Mechanicsburg, Pennsylvania 17055 (the "Bank"), and shall be maintained In the form of a twelve-year certificate of deposit subject to the following restriction: until Minor reaches the age of majority, any and all withdrawals from the Restricted Account shall be made pursuant to Order of the Court. 13. The Monetary Damages, together with accrued interest, shall be transferred to this jurisdiction by having the Middlesex City Surrogate's Office of the State of New Jersey make a check payable in the appropriate amount to Eckert Seamans Cherin & Mellott, who will then deposit the funds into the Restricted Account on Minor's behalf. WHEREFORE, Petitioner requests this Court to issue an order directing the Middlesex City Surrogate's Office of the State of New Jersey to transfer any and all funds held on behalf of Zeina Abi-Nader to this jurisdiction to be held in the Restricted Account with Bank subject to the terms and conditions set forth above. Respectfully Submitted, Q0f.L- S ~ \ ):/ /J '1LH'/1,." , ;;( &~/?.J Christopher M. Cicconi, Esquire Attorney I.D. No. 19331 Robin L. Barber, Esquire Attorney I.D. No. 67899 Eckert Seamans Cherin & Mellott 213 Market Street P. O. Box 1248 Harrisburg, PA 17108-1248 ,1995 Attorneys for Petitioner -2- --.. " . IN RE: PROPERTY OF ZElNA ABI-NADER, A MINOR IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. OF 1995 VERIFICATION I do hereby verify that the facts set forth in the foregoing document are true and correct to the best of my knowledge, information, and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. 04904, relating to unsworn falsification to authorities. DATED: :lS"" /l'J'j 19'15" 5", ~,/t'- . /lL'-?F/<-t Sue Ellen Abi-Nader