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Home My WebLink About01-06979 ~, I fU"O/.I(pfi79 eWZi f__ POWER OF ATTORNEY KNOW ALL PERSONS BY THESE PRESENTS, that BLAZER CONSUMER DISCOUNT COMPANY, d/b/a WASHINGTON MUTUAL FINANCE a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, constitutes and appoints RUSSELL W, DUNKLE i,ts true and lawful attorney.in~fact for it, and in its name, place and stead to appear in the office of the Recorder of Deeds or the Prothonotary's office for CUMBERLAND County in the Commonwealth of PeAnsylvania, and to file mortgages, bailment leases and other legal documents with power, right and authgrization to Elxecute and record, whether in person or by mail, any and all releases, satisfaction pieces, to satisfy mortgages and/or judgment notes entered of record in the offices of the Recorder of Deeds or the Prothonotary's office, to record judgment notes and to postpone the lien of judgment thereon with the said Recorder of Deeds or the Prothonotary's office belonging to or held by said corporation, hereby giving and granting to its attorney, full power to do any additional act necessary to be done in connection with the powers granted, as fully as it might or could do if personally present, hereby ratifying and confirming all its attorney shall lawfully do or cause to be done by virtue of this appointment. IN WITNESS WHEREOF, said BLAZER CONSUMER DISCOUNT COMPANY d/b/a WASHINGTON MUTUAL FINANCE has caused this instrument to be executed for it and its name, and its corporate seal affixed bYt Jerry T. Burditt, its Vice President, and attested by Beverly L. Thurston, its Assistant Secretary, this 30 h day of November, 2001. ATTEST: BLAZER CONSUMER DISCOUNT COMPANY d/b/a WASHINGTON MUTU ANCE .~/. r:JA.u~ Beverly L. ;ft;"urston ,1,ssistant Secretary By: Je rdiU Vice President State of Florida County of Hillsborough This 30th day of November, 2001, personally came before me, Sylvia C, Hall, a notary public, Beverly L. Thurston, who, being by me duly sworn, says that she knows the common seal of BLAZER CONSUMER DISCOUNT COMPANY d/b/a WASHINGTON MUTUAL FINANCE a corporation of the Commonwealth of Pennsylvania, and is acquainted with Jerry T, Burditt, who is the Vice President of said corporation, and that she, the said Beverly L. Thurston, is the Assistant Secretary of the said corporation, and saw the said Vice President sign the foregoing or annexed instrument, and saw the said Common Seal of said corporation affixed to said instrument by said Vice President of said corporation, as and for the act and deed of the said corporation for the uses and purposes therein mentioned, and that she, the said Beverly L. Thurston, signed her name in attestation of the execution of said instrument in the presence of said Vice President of said corporation, I certify that I am not a party to the attached instrument. WITNESS my hand and notarial seal, this 30th day of November, 2001, SEAL ~~~ C, cUcJt Notary Public TO RECORDER OF DEEDS: Please return to: Jerry T, Burditt, Attorney Washington Mutual Finance 8900 Grand Oak Circle Tampa, FL 33637~1050 Jo$":~Iiif;;, SYLVIAC. HALL i !-(Ji.' ,"1 MY COMMISSION # CC 754239 ~~'1'! EX~IRES: Ju~ 13, 2002 "P.r.,ft;~: BondedThru Notary Public Undetwriters H:\Depts\LEGAL\SCP\Pennsylvania\Dunkle POA PA 027.doc -.";~"llWl'.~~~,,, r'l1U: , " ~ " ~._~~."~--. ~, "'"'',,''*'''''''.C'i''''' "~.~ ~ "~-~, ',"",-.,o~-;- '-""'~--;'rb-""i'1";flilnIifilJlr'- HiT""r:rilrtr:""'3~ f ~ ? 0 C) ~ f c G 5:: i::::'f ..... "- W .. ~. "ooe :'1 I ~ rrlr":-' , , '" "'" 0\ :Z::: ::r; " ~ ~ ..... <> 6~~ )~- p...) .0 <:-.. '-' g -~~ . ~ "'" .J i~3 2:;~: ~ '" 0 ~ t \..0 ~, L:" ~ =< C -" ~ r - !iiiii1llillBlii~~~lifII,.,~'m!, .. . ,;l,"f~1'RI1'iffl',?!H~.g-4~",~<'~'f"1-'w:-,nr:'f"'f~"ftle;(".i,~~,]fJ"~~&!Rl~#rrrf.'~~.W-ili:-'''f{''B'!im-$U~I~'kl -'=",rl_ _ H'_'.<,,,,,", A I . I ROSE E, ECKENRODE and LAURA E, SMITH : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, ANDREA SAY and MARK SAY : NO, 2001~6879 CIVIL ORDER OF COURT AND NOW, this 19TH day of DECEMBER, 2001, this matter is to be referred to the custody conciliation and plaintiffs are directed to provide service of all pleadillgs and notice of all hearings to Jessica Annol! and Cumberland COUllty Childrell & Youth Services, Karl E, Rominger, Esquire For the Plaintiffs Edward E. Guido, J. '\~ .~ l~~ [~(} & Mark and Andrea Say 17 East Penn Street Carlisle, Pa, 17013 :sld :;:;- ---, ",-" ., '" --'-~' ";'7,,:~_-, ",,", ~. :.- iC,,!,,-. .,. ; '. '"1'-' -~"'-_ . c 1:__ !-",-- -~. - ,~"-~':'- '~-":' .!:,,;',~,.,,~~ijf.W~J!j;jjlll'W1ifl,~~=;u..~~i _~~~~'<f~i;!;,;;:g-*=_w~~'~it~/- "~;;:"'":~<b~~-~'.;,,,:,,J'_,' LJJ,,~.l!.j i . Tlm!llllIl ".O', .__.O', ,., ,. _ ,"_~_ "_-.,-"'~,.._"> _~ _' """~_'~_'_ ~_ _" _.,L "_ ~O" 'Mill.i ,"....P, ",..,..,.C"..,..'., ".... .."...."..,.. (/,:' , ',I 01 1'9 ,'" .r' i" j j .~.' L~ 0 cu/i:ii~::::~,~_. i:~~ '-C, t- ct~'(j~_:.'Yj lj!", '} " I_,/-."!\,,,..\ , Jill Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. DI- kP'lC( Ct~~C:--'/~ ROSE E, ECKENRODE/ LAURA E, SMITH, v, ANDREA SAY/ MARK SAY, Defendants : IN CUSTODY ORDER OF COURT AND NOW, this day of , 2001, a hearing is scheduled in Courtroom _, at _ o'clock _m. on the _, day of , 20_, for purposes of deciding Petitioners request for special relief. BY THE COURT: J, Distribution: Karl E. Rominger, Esquire Mark and Andrea Say i.'if~'1S~;!~,__"_,__I\'ill!,~ , , ~_. )!"' -- ~ "II"-l\l~ ;,m. ROSE E, ECKENRODE/ LAURA E, SMITH, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. ANDREA SAY/ MARK SAY, : NO. D~- I..P79 (?t""ul:( 'T~ Defendants : IN CUSTODY PETITION FOR EMERGENCY RELIEF AND NOW, cornes the Petitioners, Rose E, Eckenrode, and Laura E, Srnith, by and through their attorney, Karl E, Rominger, Esquire, and avers the following in support of this Petition for Emergency Relief: 1, The Petitioner, Rose E, Eckenrode, is an adult illdividual who currently resides at 644 Peach Glen-Idaville Road, Gardners, Pennsylvania 17324 and Laura E, Smith, currently residing at 612 Pine Road, Carlisle, Pennsylvania, 2, The Respondents, Andrea and Mark Say are adult individuals who currently reside at 171 East Penn Street, Carlisle, Pel1llsylvania. 3, There is one dependent child of the parties, namely Megan Say, DOB: 7/2001 4, Petitioners seek primary of the following child: Name Present Residence Age Megan Say 5 months The child was not born out of wedlock The child is presently in the custody of Jessica Annolt, who currently resides at. Unknown --'-"'_Mf'A'f_~~~ ~_~,1'W,1_1.~....,_ "Iillifl.-L ~~""'I- ~~""~-,,-.-- l/P-;J~ '~' The mother of the child is Respondent, Andrea Say, currently residing at 171 East Penn Street, Carlisle, PA, The father of the child is Respondent, Mark Say, currently residing at 171 East Penn Street, Carlisle, P A, 5. The relationship of the Petitioners to the child is that of maternal grandmother and maternal great grandmother. The Petitioner, Rose E, Eckenrode, currently resides with no one and Petitioner, Laura E, Smith currently resides with her husband, Raymond Smith, The relationship of the Respondent, Andrea Say to the child is that of natural mother and the relationship of Respondent, Mark Say to the child is that of natural father. To Petitioner's knowledge, Mother and Father currently reside with one another, 6, There is currently no Custody Order. 7, Petitioner does know of a person not a party to the proceedings who has physical custody of any of the child or claims to have physical custody or visitation rights with respect to th,e child, namely Jessica ArmoIt, She has the child pending a Children and Youth Services investigation, 8, The best interests and permanent welfare of the child will be served by granting the relief requested because: (a) Petitioners are the natural grandmother and great grandmother of the child; (b) Petitioners have established a relationship with the child; (c) Petitioners desire to continue exercising parental duties and enjoys the love and affection of the children; (d) It is believed and therefore averred that the child was left alone at least twice, once by each of the natural parents with no parental supervision while less than five months of age, ~':~i":'W<1~ <---' ,-~. ~~ 1. - '~;l ~. ~!. - ',. (e) It is believed and therefore averred that the father shook the child in an inappropriate manner, (f) Plaintiffs have come to learn that the child may also have suffered burns, 9, Each parent whose parental rights to the child have not been terminated have been named as parties to this action. PETITION FOR EMERGENCY RELIEF - REOUEST FOR ORDER FOR TEMPORARY PRIMARY PHYSICAL CUSTODY 10. Special relief is warranted, as the child has been removed from the custody offamily members because of interactions between Cumberland County Children and Youth Services and the Defendants, 11, Since the Defendants are unable to carry out their parental duties, Plaintiffs have a right under the law to exercise custody and have the standing necessary, 12. Having the child in the home of a stranger who is not a blood relation to thll child is not in the child's best interest where the grandmother and great grandmother stand ready, willing and able to exercise physical and legal custody, WHEREFORE, Petitioners respectfully request this Honorable Court grant spec:ial relief and place the child in the custody and care of the great grandmother and grandmother pending conciliation in this matter, Dated: /,2 /~t/ I ' Respectfully submitted ~---- Karl E. Rominger, Esquire Attorney for Plaintiffs 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ill No, 81924 ~ '--"~~OO'fJn: H. ,_ ~. " - , ~,rr'"" ~" , ~ --~ -~ ^'!''''''-~~ ROSE E, ECKENRODE! LAURA E, SMITH, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plailltiffs v, ANDREA SAY! MARK SAY, :NO, Defendants : IN CUSTODY CERTIFICATE OF SERVICE I, Karl E, Rominger, Esquire, attorney for Plaintiffs, do hereby certify that I this day served a copy of the Petition for Special Reliefupon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Mark and Andrea Say 171 East Penn Street Carlisle, P A 17013 ~ -- Karl E, Rominger, Esquire Attorney for Plaintiffs Dated: "rl~r!'''", . u '0 ,~ , 1 ~~" ~ 0 - ,'of ~,'~ __ Date: ,'"L$lH ~""_ ~~ p_,W__ VERIFICATION We, Rose M, Eckenrode and Laura E, Smith, hereby verify that the statements made in the foregoing Petition are true and correct to the best of their knowledge, information, and belief, We understand that false statements herein are made subject to the penalties of 18 Pa, C,S. Section 4904, relating to unsworn falsification to authorities, Dee ~ 206! ~.e/J~ "- Rose M. Eckenrode ~JLAA - ~ k/~ Laura E, Smith " "',~. , "," 11 ~~ ,"""'-!' ,"""'~'"YT'''~ ,,-~~,- '.- ~, '4'_1 -4'_",,'~' ,,"'- ~.,,-"'. ;;;'f;:"';-;.""a;;:"'~"- -U ~ ,~" -~4:\~_0N"';t'U;'h1fJr]n'TI'jITf~lil~W(,-,,:,.;,'t\"if~li"'tf\'1 0 0 0 L_ -n ""(1 ~~~., C'J ,,~ '''" ll)~~:; -'1 ,'"' - 21 Zf'/ I .}fn ~eL .J:..~ --:'rC7 i9 ""t) -,~(~) ~~2 ~'-. ~'~-;"~ :.~l~l C) r.:- 'oj rn Z ~---=: =< .,...J .2J "< t . ." ., , ~~_ _" r.> _~_.' ~"~"__I-~"""""""";~'''~- '"'''''''''~''''!!>E!~~~ . ~ 'F~~~~~-!'>f.1!'):,,--;yfl1~'fi'i7~Wij!--""~l'H "'1;r:"--,,,,',";q'''~;'em'lf'WJ:.~i!i~0~'"l\-'';';;''f~'';"-H~,;;;,JJ;;R~~~~~lW'-l!~$\'