HomeMy WebLinkAbout07-10-07
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717) 774-1445
INRE:
GUARDIANSHIP OF
ARIY ANNA L. McNEAL and
AVERY M. McNEAL
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: ORPHANS' COURT DIVISION
: NO. ~ \ 0'1 D\t)~B
PETITION FOR APPOINTMENT OF GUARDIANS
OF MINORS' PERSONS AND ESTATES
AND NOW COME Petitioners, Janet L. McNeal and Michael F. McNeal, through their
attorney, Barbara Sumple-Sullivan, Esquire and requests the Court appoint them. as guardians of
the persons and estates of Ariyanna L. McNeal and Avery M. McNeal.
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Petitioners, Janet L. McNeal, age 50, and Michael F. McNeal, a~jO~e
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husband and wife. The Petitioners are adult individuals who residt? i 1050 9
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Hemlock Lane, Enola, Cumberland County, Pennsylvania 17025.
2. Petitioners are the maternal grandparents of the above named minors, Ariyanna
L. McNeal and Avery M. McNeal.
3. The above named minors are six (6) years of age, having been born on July 23,
2000, at Harrisburg Hospital, Harrisburg, County of Dauphin, Commonwealth
of Pennsylvania.
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4. The above named minors reside with Petitioners and the children's uncle,
Stephen P. McNeal, at the above referenced address.
5. During the past five years, the children have resided with the following persons
at the following addresses:
DATES
ADDRESSES
4/01-3/03
3205 N. 6th Street, Apt. 3
Harrisburg, P A
3/03-3/04
2144 S. Second Street
Steelton, P A
3/04-9/04
1050 Hemlock Lane
Enola, P A
10/04-11/06
4517 D. Florence Ave
Mechanicsburg,PA
l1/06-present
1050 Hemlock Lane
Enola, PA
NAMES OF PERSONS
IN HOUSEHOLD
Colleen E. McNeal
and children
Colleen E. McNeal
and children
Colleen E. McNeal,
children, Petitioners and
Stephen P. McNeal
Colleen E. McNeal,
and children
Colleen E. McNeal (until
her death on 4/2/07),
children, Petitioners and
Stephen P. McNeal
6. Colleen E. McNeal, the minor children's mother and daughter of the
Petitioners, is deceased, having died on April 2, 2007. The Petitioners have
stood in loco parentis for the children and an award of guardianship is
necessary to effectuate the continuation of the children's current education,
health care, stability of household and family.
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7. Brandon Cruz, the minor children's father, is living and resides at 500 Geneva
Drive G4, Mechanicsburg, Cumberland County, Pennsylvania 17055. Brandon
Cruz has had no contact with the children since birth, is unknown by the
children and has neglected to provide for them.
8. Petitioners have significant concerns about natural father's fitness.
9. Brandon Cruz, the above named minor children's father has been given notice
of the filing and has not responded as to whether or not he consents to this
petition.
10. The above named minors have now no general or testamentary guardian
appointed by will to the knowledge or belief of Petitioners.
11. The religious persuasion of the biological father is unknown. The deceased
Mother of the minor children was of the religious persuasion of Protestant.
The Petitioners are of the religious persuasion of Protestant.
12. Petitioners are fit and proper persons to be appointed guardians of the persons
and estates of the minor children.
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WHEREFORE, Petitioners request that a decree be issued appointing Janet L.
McNeal and Michael F.McNeal, Petitioners, the guardians of the persons and estates of
the above named minor children, and for such other relief and future relief as the court
may deem proper.
Dated: July 10, 2007
Barbara Sumple-Sullivan,.- Esquire
Attorney for Petitioner
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court J.D. No. 32317
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Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717) 774-1445
INRE:
GUARDIANSIDP OF
ARIY ANNA L. McNEAL and
AVERY M. McNEAL
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: ORPHANS' COURT DIVISION
: NO. b~ D\o~8
CONSENT
I, Ianet L. McNeal, being duly sworn, depose and say:
I hereby voluntarily and unconditionally consent to my appointment as guardian of the
above named minor children, Ariyanna L. McNeal and Avery M. McNeal, both born Iuly 23,
2000.
I, Ianet L. McNeal, hereby certify that the facts set forth in the foregoing Consent are true
and correct to the best of my knowledge, information and belief I understand that any false
statements made herein are subject to penalties of 18 Pa. C.S.A Section 4904 relating to
unsworn falsification to authorities.
I have read and understand the above, and I am signing it as a free and voluntary act.
DATE: ~ \ ')I( , 2007
7
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(711) 774-1445
INRE:
GUARDIANSHIP OF
ARIY ANNA L. McNEAL and
AVERYM. McNEAL
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: ORPHANS' COURT DIVISION
: NO. ~ \ 0"1 DtDtfB
CONSENT
I, Michael F. McNeal, being duly sworn, depose and say:
I hereby voluntarily and unconditionally consent to my appointment as guardian of the
above named minor children, Ariyanna L. McNeal and Avery M. McNeal, both born July 23,
2000.
I, Michael F. McNeal, hereby certify that the facts set forth in the foregoing Consent are
true and correct to the best of my knowledge, information and belief I understand that any false
statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to
unsworn falsification to authorities.
I have read and understand the above, and I am signing it as a free and voluntary act.
DATE: 4-/ Z5" . 2007
8
BaIbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717) 774-1445
INRE:
GUARDIANSIllP OF
ARIY ANNA L. McNEAL and
AVERYM.McNEAL
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: ORPHANS' COURT DMSION
: NO. ~\ 0'- D~~8
STATEMENT OF THE GUARDIAN
I, Janet L. McNeal, being duly sworn, depose and say:
1. I am a citizen of the United States of America, and am able to speak, read and
write the English language;
2. I reside with the minor children in the same household and it is not my
intention to apply for an allowance for the support of education of the minor children during
minority;
3. I am not the Fiduciary or an officer or employee of a corporate Fiduciary of an
estate in which the ~or children have an interest nor the surety or an officer or an employee of
the corporate surety of such a Fiduciary, and that I have no interest adverse to the minor children.
4. I, Janet L. McNeal, hereby certify that the facts set forth in the foregoing Statement are
true and correct to the best of my knowledge, information and belief I understand that any false
statements made herein are subject to penalties of 18 Pa. C.S.A Section 4904 relating to
unsworn falsification to authorities.
DATE: ~ 2007
J
L. McNEAL
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Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717) 774-1445
INRE:
GUARDIANSHIP OF
ARIY ANNA L. McNEAL and
AVERYM. McNEAL
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: ORPHANS' COURT DMSION
: NO. ~\ Ol D~~8
STATEMENT OF THE GUARDIAN
L Michael F. McNeal, being duly sworn, depose and say:
1. I am a citizen of the United States of America, and am able to speak:, read and
write the English language;
2. I reside with the minor children in the same household and it' is not my
intention to apply for an allowance for the support of education of the minor children during
minority;
3. I am not the Fiduciary or an officer or employee of a corporate Fiduciary of an
estate in which the minor children have an interest nor the surety or an officer or an employee of
the corporate surety of such a Fiduciary, and that I have no interest adverse to the minor children.
4. L Michael F. McNeal, hereby certify that the facts set forth in the foregoing Statement
are true and correct to the best of my knowledge, information and belief. I understand that any
false statements made herein are subject to penalties of 18 Pa. C.S.A Section 4904 relating to
unsworn falsification to authorities.
DATE: C, / z 5" . 2007
I
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BaIbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland. P A 17070
(717) 774-1445
INRE:
GUARDIANSIDP OF
ARIY ANNA L. McNEAL and
AVERY M. McNEAL
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: ORPHANS' COURT DMSION
: NO. ~ \ O't t>,",l.\~
VERmCATION
We, Janet L. McNeal and Michael F. McNeal, hereby certify that the facts set forth in the
foregoing PETITION are true and correct to the best of our knowledge, information and belief
We understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A.
Section 4904 relating to unsworn falsification to authorities.
Date: 6/25/07
~~7.1tt(~
MIC L F. McNEAL
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LAW OFFICES
BARBARA SUMPLE-SULLIVAN
549 BRIDGE STREET
NEW CUMBERLAND. PENNSYLVANIA 17070-1931
PHONE (717) 774-1445
FAX (717) 774-7059
July 10, 2007
Clerk of Orphan's Court
Cumberland County Courthouse
1 Courthouse Square
Carlisle, P A 17013
In Re:Guardianship of Ariyanna L. McNeal and Avery M. McNeal
Dear Sir/Madam:
Enclosed please find an original and one copy of the following documents for
filing in the above captioned matter:
(1) Petition for Appointment of Guardians of Minor' Persons and Estates;
(2) Order for Hearing; and
(3) Final Order for Guardianship.
Please process the enclosed and advise as to when a hearing will be scheduled. I
also enclose a check of $50.00 for the filing fee. Thank you.
If you should have any questions, please do not he' e to contact my office.
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Barbara Sumple-Sullivan
BSS/lh
Enclosures
cc: Mr. and Mrs. Michael F. McNeal