The URL can be used to link to this page

Home My WebLink About11-13-07 IN THE MATTER OF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : ORPHANS COURT DIVISION : NO. ~ \ 0\ \~olP : GUARDIANSHIP-MINOR NICHOLAS R. PRICE, A MINOR ~--) r, PETITION FOR ApPOINTMENT OF TEMPORARY GUARDIAN c<) !-~. ) NOW come petitioners, by their attorney, Harold S. Irwin, III, Esquire, and present this petition for appointment of temporary co-guardians of the person and estate of Nicholas R. Moore, a minor, representing as follows: 1. Petitioners are BRIAN K. MOORE and VANESSA K. MOORE, adult individuals residing at 2626 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17015. Petitioners are the aunt and uncle of the subject minor child. Nicholas R. Price. 2. The minor child, NICHOLAS R. PRICE, was born on May 3, 1995, the son of Joseph R. Nastelli and Kelly A. Sentz, who were unmarried at the time of the child's birth. A copy of the child's birth certificate and social security card are attached hereto as Exhibit "A". He has resided with petitioners in Cumberland County, Pennsylvania for more than six months. 3. The father, Joseph R. Nastelli, has consented to the guardianship of Nicholas R. Price by the petitioners. A copy of his consent is attached hereto as Exhibit "B". 4. The mother, Kelly A. Sentz, abandoned the child to the care of the petitioners in or around April, 2007, and relocated to Florida. In August, 2007, the mother executed a handwritten document in which she gave all her rights to the child to petitioner, Brian K. Moore. A copy of this document is attached hereto as Exhibit "C". 5. Petitioners have had only sporadic telephone contact with the mother, who has refused to advise them of her whereabouts or to provide any address at which she can be contacted. 6. The child has no income and no assets. 7. The child's next of kin are his parents, referred to above, and two half brothers: Paul Lawyer, a college student in Williamsport, Pennsylvania, and Zachary Sentz, a minor, who resides with his father, Joseph A. Sentz, in Gettysburg, Pennsylvania. 8. Petitioners have no knowledge of any other Court within this Commonwealth which has appointed a guardian for the minor. 9. The minor is incapable of caring for his own personal finances and physical needs and requires the appointment of a guardian to do so. In addition, the petitioners require this appointment for the inclusion of the child on their medical insurance coverage and to have the authority to make medical, educational and other decisions on behalf of the child. 10. Petitioners have no interests adverse to the minor and have agreed to act as co- guardians if this Honorable Court shall so appoint. The consent of the proposed guardians is incorporated herein by reference and attached hereto as Exhibit "0". 11. If appointed as co-guardians, petitioners will act in compliance with regulations promulgated under Court Order in Pennsylvania Bulletin 931, et seq., April 19, 1975. WHEREFORE, petitioners respectfully request this Honorable Court set a hearing at which the averments of this petition may be documented and the appointment of petitioners as temporary co-guardians for the person and estate of the child may be considered, with notice thereof to be given to such persons as this Court may direct. Finally, due to any emergency and immediate needs of the child, petitioner requests that they be appointed temporary co-guardian pending a final hearing on this matter. HAROLD S. IRWIN, II Attorney for petition rs November 6, 2007 VERIFICATION We do hereby depose and state that the facts contained in the foregoing petition are true and correct to the best of our knowledge, information and belief. We understand that false statements made herein are subject to the penalties of 18 Pa.C.S.A. Section 4094, relating to unsworn falsification to authorities. November 6, 2007 ~ VAN '" fo\- Sf (' & .. C>"~.,.. ...~L.1> nO"t7o~7f:i!.5'~ . &-,........ . ...j', ."'" .... ....~ . -. . TH IS.NU ~~ER~A~BEi~ E$iA'~'t,.sH E~ F~A .". -'._.'.",.:.'.:_i':"'- -..- '"".': NICHOL~ ROPERT PRICE" . .' "~7/ \l~Htl,\~Q' ..... 1\IISTRt'- SIGNATU RE . COMMONWEALTH OF PENNSYL VANIA. DEPARTMENT OF HEALTH' VITAL RECORDS e:aJ({rrtification of riirtb~ "" IN THE MATTER OF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : ORPHANS COURT DIVISION NICHOLAS R. PRICE, A MINOR : NO. : GUARDIANSHIP-MINOR CONSENT OF NEXT OF KIN I, JOSEPH R. NASTELLI, do hereby certify that I am the father of the minor child, NICHOLAS R. PRICE, and I consent to the appointment of BRIAN K. MOORE and VANESSA K. MOORE as temporary co-guardians of his person and estate. The facts and opinions contained herein are true and correct to the best of my knowledge, information and belief. -A b~ ~~ SE~ R. NASTELLI Sworn to and subscribed before me thisc;..^l.V) day of November, 2007. (Ol~ - Notary Public EXHIBIT "B" ..- f - j I<ELL y A -Sl;~<- =t::'-.s 7 ' L/ r'f\ r ~ t l My 'K: <:; ~+ .r +-0 '5 KJ f\"J k: ---g6~ KD f\v\ o() K-E 0< ~ :;) (: LV A.ll\Juf-- FbR. rv i c. f-tOLf\S KOLSe~+ f?,cc._ Sc)c<.4( 'Sec~;-k{ Mll 170 - 76- 7638 C I'\rU:JI.E pA. I/o/S- ~ Sworn & Subscribed To Before Me This ~ DaYof!kJ ~(Y7 . 1 / I // / .~ F Fr:2 ci cvLc ()V-\-~ o 'PJ /<:> J :J.OO( . O. ~ pf;NNSYLVANIA NWtALrr~ . r , _ COMMe NOTARiAL SEAL Public - NEIL Notary ty DARCIe: A:. !. Cum>)er!and Coun Boro of ~ar.lis,e,!x ires' Nov. 24, 2009 M ,"'ommlsslO11 r. P Y\..'~H_ ~-...--. I~E: LL 'I A 'S, ~ 4-\ · D'I<.:~t0 K. fV\uoKv2 ~/~ IN THE MATTER OF : IN THE COURT OF COMMON PLEAS OF : PERRY COUNTY, PENNSYLVANIA : ORPHANS COURT DIVISION DUSTYN MICHAEL SONNY MUMMA, A MINOR : NO. : GUARDIANSHIP-MINOR CONSENT OF PROPOSED GUARDIAN I, BRIAN K. MOORE and VANESSA K. MOORE, do hereby certify that we are willing to act as the temporary co-guardians of the person and estate of NICHOLAS R. PRICE, if the Court shall so appoint us. Further, we do hereby certify that we are not a fiduciary of any estate in which the minor has an interest, nor have we any interest adverse to the minor. The facts and opinions contained herein are true and correct to the best of my knowledge, information and belief. ?' / ~" /',./ / ~', ,':> , / d'J'<-.J, _ ?Z // ~57e'>-::;: t/. L:~........ ...--...- VANE Sworn to and subscribed before me this (-,"'1'l- day of ovember,2007. COMMONWEALTH OF PENN:) Y,V \NI,\ r- N' I 'TA'I?1 "[ 'P",-;----' : ,U ,..~. ~U\L "i H I' S' ' ," E N'" ,"," 'I ; arod ',: :r\VI~!I' ''1" 0:3,\ ,1'1>[1110 I ("ni',;e, (urnberland C 'Jll~tY : ~/ly CO~im!sS!on ci,p;.es February 06, 20llj EXHIBIT "D"