HomeMy WebLinkAbout10-23-07
o
LAW OFFICES OF PETER J. RUSSO, P.C.
By: Peter J. Russo, Esquire
P A Supreme Court ID # 72897
3800 Market Street
Camp Hill, P A 17011
Ph: (717) 591-1755
F: (717) 591-1756
Drusso(tV,Dirlaw.com
Counsel for Petitioner
()
C='; 0
<~ ::::J:J
: --n
~\ ~"f~ ()
. ~~~ ~:.S
:-::::.
f-.-'
c::l
c::-.;;;
-J
,..,
c. ~.....,.
. '
-.
f'.,..)
w
IN THE MATTER OF THE PERSON
OF:
'f2
IN THE COURT OF COMMoK::pLEAS :'J
CUMBERLAND COUNTY, PENNSYL VANIA
NO. 2007- 09~
P:
GUARDIANSHIP OF
NICOLE QUILES
A MINOR CIDLD
ORPHANS' COURT DIVISION
GUARDIANSIDP
PETmON FOR THE APPOINTMENT OF A GUARDIAN
FOR A MINOR PLAINTIFF, NICOLE QIDLES
AND NOW, COMES the Petitioner, PATRICIA FORRY and respectfully represents the
following:
1. The subject minor child is named NICOLE QUILES.
2. NICOLE QUILES is a minor of the age of sixteen years old (16). Born on August 26,
1991.
3. NICOLE QUILES resides at 905 Chester Road, Enola, PA 17025.
4. KATHY STEVENS, NICOLE QUILES'S natural mother resides at 151 Regency
Woods North, Carlisle, PA 17015.
5. NICOLE QUILES'S natural father is unknown.
6. The Petitioner, PATRICIA FORRY, is a family friend of NICOLE QUILES and
KATHY STEVENS.
7. The Petitioner, PATRICIA FORRY, reside at 905 Chester Road, Enola, PA 17025.
8. KATHY STEVENS, NICOLE QUILES'S natural mother, consents to this Petition.
9. KATHY STEVENS, NICOLE QUILES'S natural mother, executed a consent to the
appointment of a guardian which is attached hereto as Exhibit A and the original has
been filed with the Court of Common Pleas of Cumberland County, Orphans' Court
Division. A true and correct copy of the same is attached hereto.
10. As NICOLE QUILES'S natural father is unknown, the Petitioner cannot represent the
natural father's position relative to the appointment of a guardian.
11. The appointment of a Guardian is required as KATHY STEVENS, NICOLE
QUILES'S natural mother, believes it is in the best interest of the minor child,
NICOLE QUILES to reside with PATRICIA FORRY.
12. The proposed Guardian is the Petitioner, PATRICIA FORRY, age 47.
13. The proposed Guardian, PATRICIA FORRY, resides at 905 Chester Road, Enola, PA
17025.
14. The proposed Guardian, PATRICIA FORRY, is a family friend of KATHY
STEVENS and NICOLE QUILES.
15. The proposed Guardian, PATRICIA FORRY, has no interests which are adverse to
NICOLE QUILES.
16. The proposed Guardian, PATRICIA FORRY, is Catholic.
17. NICOLE QUILES has not been baptized but is considered Protestant.
18. NICOLE QUILES does not have an estate that requires an itemization.
19. Petitioner is not aware of any entitlement NICOLE QUILES may have as party to any
action.
20. NICOLE QUILES is not the child of a veteran, therefore notice of this petition to the
United States Veterans' Administration or its successors is not required.
21. The proposed Guardian, PATRICIA FORRY, has consented to her appointment as
Guardian as evidenced by the attached consent.
WHEREFORE, Petitioner's respectfully requests that this Honorable Court grant
PATRICIA FORRY guardianship of the person of NICOLE QUILES.
Respectfully submitted,
~~
Peter J. Russo
Date: to l2--Z-1 0"/
IN THE MATTER OF THE PERSON
OF:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
GUARDIANSHIP OF
NO. 2007 -
NICOLE QUILES
A MINOR CHILD
ORPHANS' COURT DMSION
GUARDIANSmp
CONSENT TO APPOINTMENT OF GUARDIAN
I, the undersigned, reviewed the Petition for Guardianship and I consent to the
appointment of guardianship for NICOLE QffiLES. I fully understand the ramifications of my
decision and I fully believe that the appointment of PATRICIA FORRY as the guardian for my
daughter is in her best interest.
~e.@i~
WITNES .OR KA STEVENS
~~
IN THE MATTER OF THE PERSON
OF:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
GUARDIANSIDP OF
NO. 2007 -
NICOLE QUILES
A MINOR CHILD
ORPHANS' COURT DMSION
GUARDIANSIDP
CONSENT TO APPOINTMENT OF GUARDIAN
I, the undersigned, reviewed the Petition for Guardianship and I consent to the
appointment of guardianship for NICOLE QUILES. I fully understand the ramifications of my
decision and I fully believe that my appointment as the guardian for NICOLE QUILES is in her
best interest.
~ ~~ -
WIlNES~R P~FORRY
~~7'
IN THE MATTER OF THE PERSON
OF:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
GUARDIANSHIP OF
NO. 2007 -
NICOLE QUILES
A MINOR CHILD
ORPHANS' COURT DIVISION
GUARDIANSmp
VERIFICATION
I, PATRICIA FORRY, verify that the statements made in the foregoing document are true
and correct. I understand that false statements made herein are subject to the penalties of 18
PaC.S. ~4904 relating to unsworn falsification to authorities.
Date: / tJ - z z. -07
r:~ ~/