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HomeMy WebLinkAbout02-10-09IN THE COURT OF COMMON PLEAS OF, CUMBERLAND COUNITY, PENNSYLVANIA In re: :ORPHAN'S COURT DIIVISION H.C. .NO. a~-~~- U~~ ~ n - ~ - _~ ~ - :GUARDIANSHIP -MINORS - ~,~ r?'rz ~- ! ' ~ r-- ~_,~ ~ , ; ~ _, J 'j; , -~ i PETITION FOR GUARDIAN OF MIIN~~ ~_ N NOW comes the petitioners, Haley Claman, by her attorney, Karl E. Rominger, Esquire, and files this Petition for Guardian of Minors representing as follows: 1. The proposed Guardian is Tara Karper, an adult individual, residing at 70 VVest South Street, Apt. 7, Carlisle, Pennsylvani~i 17013. 2. Your Petitioner is Haley Calaman, hereinalFter H.C. a minor child, age 17 years, who currently resides at 70 West South Street, p,pt. 7, Carlisle, Pennsylvania 17013. 3. Petitioner is the paternal cousin of the proposed Guardian, Tara Karper. 4. Petitioner has no knowledge of any Court within this Commonwealth which has appointed a guardian for them. 5. The proposed Guardian has no interest aclverse to the minor child, and has agreed to act as guardian of the child if this Honorable Court shall so appoint. 6. Pursuant to the Cumberland County Rule:> of Orphans Court 12.5-2, attached is a Consent form and statement of the proposed guardian. 7. The appointment of a guardian is necess2~ry as the child's mother, Theresa Peterson is recently deceased, and the father, Gregoiry Calaman is recently deceased and the Social Security Administration requires the appointment of a Guardian. WHEREFORE, petitioner respectfully request this Honorable Court set a hearing at which the averments of this petition may be documented and the appointment of Tara Karper as guardian for the minor child, H.C:. may be considered, with notice thereof to be given to such persons as this Court may direct. Date:~~(;1<"' ~ Respectfully submitted, ROMINGER 8~ ASSO(:IATES Karl . Rominger, Esquire Attorney for Petitiorners 155 South Hanover ~itreet Carlisle, PA 17013 717-241-6070 Supreme Court ID No. VERIFICATION Karl E. Rominger, Esquire, states that he is the attorney 'For Petitioner, K.R. and R.R., in this action; that he makes this affidavit as attorney bec~iuse he has sufficient knowledge or information and belief, based upon his investigati~~n of the matters averred or denied in the foregoing document; and that this statE~ment is made subject to the penalties of 18 Pa. C.S. Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: ~br'UG.1'~ ~ ~ ~~ t ,/`-) ~-__ Karl E. ominger, Esquire Attorney far Petitioners IN THE COURT OF C~DMMON PLEAS OF, CUMBERLAND COUNITY, PENNSYLVANIA In re: :ORPHAN'S COURT DIVISION H.C. . NO. GUARDIANSHIP - MIINORS CONSENT OF PROPOSED CO-GUARD/AN I, Tara Karper certify that I am the natural CO (J S /~I of the alleged minor child/Petitioner and that I am willing to act as her guardian, if the Court shall so appoint me. In conformity with the Cumberland County Local Rule of Orphan Court 12.5-2, I aver as follows: 1. Your Proposed Guardian is a citizen of the Unitecl States and is able to read, write and speak the English language. 2. Your proposed Guardian is not a fiduciary or an officer or employee of the corporate fiduciary of an estate in which the minors have are interest nor the surety of such a fiduciary. 3. Your Proposed Guardian has no interest that is adverse to the minor childrenlPetitioners. 4. Your Proposed Guardian will not be seeking an allowance for the support of the children while the children are still minors. The facts and opinions contained herein are true and correct to the best of my kno dge information and belief. Ciaw - \~ Tara Karper Sworn to and subscribed before me this- day of % ~ ~ < <~~~, 2009 ~;~ C(7h9lVl~NWlnAL7"Fi Gz- PEN~SYLV/iNIA Nat2rstz! Seal 7ammie l.. ~-'(~rs, ~fotary Public Gaslisie l3c~re. ~s~,bertarxi Ccunty ~~.~ ca-rmsr{«r~,r f ,wni.a~ Sre~t ~, 20'''! ivl~mf7rwr, F'enn~~,t. ~ ~!„'~~ ~xiaticn of v~:~farie~ Notary Public