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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. '" c::::> c::::> --' 1. o ~~ E -.J\J,......... ..- -1 I'- " I _ . j ').0> (:;, ,-- '-:/'" 0 Petitioners, Janet L. McNeal, age 50, and Michael F. McNeal, a~jO~e '00 :r:- ". C) -01 :X husband and wife. The Petitioners are adult individuals who residt? i 1050 9 .::'.:J c..> .V \.D 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. 1 'n m C) ,---- --' :.D CJ -:, 'cj c::> --n -n ("") en ~\ 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. 2 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. 3 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 4 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 5 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 6 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 9 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. i I / / { Barbara Sumple-Sullivan BSS/lh Enclosures cc: Mr. and Mrs. Michael F. McNeal