The URL can be used to link to this page

Home My WebLink About96-01049 . ;0. ':"i':Z ,.: ">t:"." ~ .'>'"," ~:~~1~t~~:~,7 ": -. ~1l'" , Jk?l(::: .' ;t~..!; '_ ,-" ~"",,,,,, .' iI,.'''.,.., . W!t~~, ~\.., ~,..",..," ,t.., ~ . .... 0 G) ... c ... '" LLI IN RE: GUARDIANSHIP OF MICHAEL LEE ARMOUR, a minor IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ~/ -'1(". - /ol/"t, AND NOW, this ~ d.yOR:~ -Or<-- , 1996, Defendant is hereby directed to show cause why petitioner's Motion for Appointment of Guardian should not be granted. held on ~Uid~. tf1w /JIhf- :)7 1996, at ij ~ cumberland county courthouse, courtroom No. ~ Hearing to be /1)_ n) /rM. in , BY THE COURT: IN RE: GUARDIANSHIP OF MICHAEL LEE ARMOUR, a minor IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. PETITION FOR APPOINTMENT OF GUARDIAN AND NOW, comes Petitioner, Brady J. Freeman, by and through his Attorney, Karl R. Hildabrand, Esquire of Metzger, wickersham, Knauss & Erb, and hereby files this Petition for Appointment of Guardian and in support thereof avers the following: 1. Petitioner and Bonnie M. Freeman are husband and wife, having been married on December 15, 1984 in Hampden Township, Cumberland County, Pennsylvania. 2. Petitioner and Mrs. Freeman are the natural parents of three children, John B. Freeman (DOB:12/15/84), Christopher Ray Freeman (DOB:07/28/87) and Sarah Nicole Freeman (DOB:01/23/90). 3. Mrs. Freeman is the natural mother of Michael Lee Armour (DOB: 01/08/83), and Petitioner is the stepfather of said child child. 4. Michael has lived continuously with Petitioner and Mrs. Freeman for 16 years, since the date of marriage of Petitioner and Mrs. Freeman. 5. The child's natural father, Ernest Markley, Jr., has had no contact with the child, 6. Petitioner has actively participated in the raising and nurturing of said child for the past 16 years. 7. Mrs. Freeman has recently left the marital residence to live elsewhere, and has left all four minor children in Petitioner's care and custody, including Michael. a, Petitioner and Mrs. Freeman have agreed that it is in Michael's best interest that he reside with his stepfather, the Petitioner, in the marital home, with his step-siblings. 9. It is Petitioner's and Mrs. Freeman's intention that Michael will continue to attend school in his current school district, and Petitioner is in need of a guardianship order so the child can continue to attend his regular school, and so that Petitioner is able to make the daily decisions necessary for the proper care and raising of the child. 10. Mrs. Freeman initially agreed to stipulate to the appointment of Petitioner as Michael's guardian. A true and correct copy of the Agreement is attached hereto as Exhibit "A." 11. Subsequently, Mrs. Freeman informed Petitioner that she is no longer in agreement with said Guardianship Agreement. WHEREFORE, Petitioner, Brady J. Freeman, hereby requests that This Honorable Court grant his Petition and enter an Order appointing him as guardian of Michael Lee Armour, a minor" METZGER, WICKERSHAM, KNAUSS & ERB Date: December 10, 1996 , "--fI . ,1 1/ , (, I . J\ {C;,(, ..(~~,~,,-- ',_ C,:'~._-":f' 'lJ~" Karl R. Hildabrand, Esquire Attorney 1.0. 30102 3211 North Front Street P. O. Box 5300 Harrisburg, PA 17110-0300 Attorneys for petitioner ( If) "-lA, 111.)~:1.. -2- Exhibit A ,..<-_.----~ -- ,.., -.-.-- BRADY J. FREEMAN, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO, BONNIE M. FREEMAN, Defendant CIVIL ACTION AGREEMENT FOR APPOINTMENT OF GUARDIAN WHEREAS, Bonnie M. Freeman, hereinafter referred to as MOTHER, and Ernest Markley, Jr., hereinafter referred to as FATHER, are the natural parents of one (1) minor child: Michael Lee Armour (d.o.b. 01/08/83); and WHEREAS, plaintiff Brady J. Freeman, hereinafter referred to as STEPFATHER, is the husband of Bonnie M. Freeman and the STEPFATHER of Michael Lee Armour; and i , WHEREAS, plaintiff and Defendant have recently separated; and WHEREAS, FATHER has maintained no contact with the child; and WHEREAS, STEPFATHER has actively participated in the raising and nurturing of said child; and WHEREAS, MOTHER, FATHER and STEPFATHER desire to make arrangements for the guardianship of the person and property of said child; and WHEREAS, all parties hereto have been advised by counselor have had the opportunity to so be advised by counsel; and WHEREAS, the parties intend to submit this Agreement to the Court of appropriate jurisdiction for merger into a court Order approving said Agreement; - NOW, THEREFORE, it is hereby stipulated and agreed as follows: 1. STEPFATHER is hereby appointed and designated legal guardian of the person and property of Michael Lee Armour (d.o.b. 01/08/83). This designation recognizes the close love, affection, and personal relationship between STEPFATHER and the child and MOTHER AND FATHER hereby express their belief that said designation is in, and for, the best interest of the child and his emotional and physical well-being. 2. This Agreement shall be effective immediately upon signature by each of the parties hereto and its validity is not contingent upon court approval. Date: lkc..., "7 I 9 fliP ~.;tt;,,~-~. BRADY J. EMAN Date: Die. 7. J qq(;. ~ /f). %J/YJLtVJt- BONNIE M. FREEMAN Date: ERNEST MARKLEY, JR. -2- , '" ,'; 0 i~ ~.'.. CI -. '.r -, N" n. ~ .. 0.:; ... \0 9" ." : CJ N.' )'Z~ '.. - No ., .J,. .,,- -j" -',. . .' ',\.' . . I(:;p. . ~;; ~' :')' ~(;,;';;;~~,~,," ..., in , ;.~ .'f":':i " m' ',' , , '>}i~,~,tt,~;~~ ~. ""''''"'''''''ij\ 'g::. <,:: :,~',,<;di!.~Jt~~ ' &4 .-. t'J' I' ~~";<.i~~i~.rr en 0 :1' o. /""\;l:<,r~ . ':"'-"':,;';''''4tf'.-of;~ U) t' 0 "':'-':{-"';~:,l,,'~~J~-:r,,iV_ ; k! "e-i"'"''.',.i''';''' ~ i.-;: '.,~~'~"~:;.~ lie: :5 III 8 ~ ,\" ",.,~. i:)'; ~'~;, i <.>~!:{~~~f:~t~~3" X II ~ .' ~_-_:,_"...,,;.,..nJ..~l't" &II: ti:'~:o '~' ;~:i;~,:~~;r~~~;}}_"H a: !j% III "z, '" ,,:,,~~:;,~~,:> ... -. cl w . ",,'..'" ~" ~ g: ..0.<'/ .i-....t~~th.:~~'::::-<~; u'r:;: a:'f ~';\;".':'P{~':'~Q.');~ l < ~ 0 '1.\~:"~'?:~,~)Ii s q 1-. " L~ ~. ": .,,::~j)g~l1 ,. ',.,. ",'. . J,.; _ ~ :, , ',_" ~ ,". ,~ .' '- :,' ~:, '1-': .r .,~' ,- ".' , . - IL-LI-30 U3:LDftM r;.~ ~vA LAI VIIllt II) l'il'ILmm [00\:002 /0.i:s;7. / . " . . Countess. Gilbert · AndreWs lirw Ojfrcrs ,.' . jMC.CounlfU GlryMG_ I'ttt, 1_ AndlfW1 ~ftft'l\CtV.Youtl' MlC'htwllwilnd SIIlronLMytn ~,ldhny Tho.... D. 01l>c1 John D fllnc1lbJ\I&h fnnk H. Coufllnl J-ph r. c...... U SU1A..Auilir! Knth I. SSlItuM Date: I;; /;'1/ 'It,. I .. PETITIONER'S . I EXr'BIT Number of pages (including cover sheet): ~ Iib.,M]- Deliver to: 't/, ~ ;.jjd~...A/, &; 'I/? l~jll- 9'17 f . company: Fax No.: From: Countess Gilbert AftdrOWD 29 North Duke Street York, PA 17401 Fax #: 717-843-9039 ~Q/)V V. ~ subject: If you do not receive all of the pages sent or have questions, please call (717) 848-4900 as soon as possible, Thank you, ~'IJ-,~~~ ~~_~/~~.~' A~ ('L1J_rMrj..- ~ -ft,v ~ .ffi1~ ' U ~/:-L Comments: ******......*..............*.....**..........**..**.**...,....... The inform.cion concained in chi. facaimile meDD~ge io .ccorney privileged and confidenCial informacion incended only for .he individual or .ncicy named above. tf the reader of thiD m....g. i. not che intended recipient. you are hereby notifi.d that any dissemLnacion, dL.cribution or copy of thi. communication i_ atrictly prohibited. If you have received thl~ communication in errcr, pleaae immqdiat.ly notify u. by cel.phone and return the orLgin>l meGDago co u. at the aboye address via the U.s. pODt.l Servic.. Thank you. ..............".........-.......,.....................,.".....- / Original will will not tollow by mail A Pro/..ioMJ Cor,otrJli" 2'1 NoM OIl.. SUM . Yorl<, p<nnr,1"n~ 17101-11l12 ' Tdq>hon<, 717/BoW49ill . fAX 71718lyWl9 Ado>lJOfUl oIf..ln f>lt Il<rlin. PA "