HomeMy WebLinkAbout11-13-07
BRANDON C. HOwe, a minor
: IN THI! COURT OF COMMON PLI!A8 OF
: CUMBI!RLAND COUNTY, PI!NN8YLVANIA
: ORPHAN8 COURT DIVI810N
:NO.21-07.~
: GUARDIAN8HIP-MINOR
~EDIION FJ~"R~Ap'9l~~6fINLOF.
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IN THI! MATTI!R OF
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NOW come petitioners, CHARLES H. HOWE and DOLLIE D. HOWE, by their attorney, H~Qld
S. Irwin, III, Esquire, and present this petition for appointment of temporary co-gu~rdians of:the
person and estate of BRANDON C. HOWE, a minor, representing as follows: ('.)
1. Petitioners are CHARLES H. HOWE and DOLLIE D. HOWE, adult individuals residing at
1047 Centerville Road, Newville, Cumberland County, Pennsylvania 17241.
2. Petitioners are the paternal grandparents of BRANDON C. HOWE, a minor child, born
on May 5, 1997. A copy of the child's birth certificate is attached hereto as Exhibit "A".
3. The minor child's father, Robert C. Howe, died on January 19, 2004, as the result of
injuries sustained in a motor vehicle accident in Cumberland County, Pennsylvania.
4. The minor child's mother, Anna Long, was residing with the petitioners at the time of
Brandon's birth, but left their home and the child approximately three weeks after the child's
birth. She has never had any contact with the child since that time and petitioners, while
believing her to be residing somewhere in Puerto Rico, have had no knowledge of her
whereabouts or her mailing address at any time since her departure from their home.
5. The minor child has continued to reside with the petitioners since his birth, both before
and after the death of his father, Robert C. Howe.
6. The minor child's father, Robert C. Howe, had no assets at the time of his death and the
child received no inheritance or life insurance proceeds from the estate of his father. The child
is the recipient of approximately $475 per month in social security proceeds which your
petitioners have been using tor the child's care since the death of his father.
7. Other than the petitioners, paternal grandparents, the minor's only next-ot-kin is his
mother, Anna Long, whose whereabouts are unknown to petitioners.
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 ot caring tor his own personal finances and physical needs. He
has no assets and no income other than the social security proceeds referred to above.
10. Petitioners have no interest 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 "B~.
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 person or persons as this Court may direct. Petitioners further request that a
guardian ad litem be appointed to act for the alleged minor regarding any necessary hearings.
Finally, due to any emergency and immediate needs of the child, petitioners request that they
be appointed temporary co-guardians pending a final hearing on this matter.
September 26, 2007
HAROLD S. IRWIN, III
Attorney for petitioners
VERIFICA TION
We, Charles H. Howe and Dollie D. Howe, petitioners in this matter, 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.
September 26, 2007
{()aJd/J ' L-
C RLES G. HOWE
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DOLLIE D. HOW
IN THE MATTER OF
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: ORPHANS COURT DIVISION
: NO. 21 - 07 -
: GUARDIANSHIP-MINOR
BRANDON C. HOWE, a minor
CONSENT OF PROPOSED GUARDIAN
We, Charles H. Howe and Dollie D. Howe, do hereby certify that we are willing to act as the
temporary co-guardians of the person and estate of Brandon C. Howe, 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 our knowledge,
information and belief.
&~J!~
CHARLES H. HOWE
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DOLLIE D. HOWE
Sworn to and subscribed
before me this 26TH
day of eptember,2007.
o
Notary Public
COMMONWEALTH OF PENNSYLVANIA
NOT ARlAL SEAL
I Harold S. Irwin Iii, Esq, Notary Public
\ Carlisle, Cumberland County
My commission expires Februa 06,2011