Loading...
HomeMy WebLinkAbout04-24-09IN RE: : IN THE COURT OF COMMON PLEAS OF E.R.W. :CUMBERLAND COUNTY, PENNSYLVANIA :ORPHAN'S COURT DIVISION q 9 ~ NO. 2009- ~ ~ ~ . ~ ~-D a' GUARDIANSHIP-MINOR ~~~ ~ J e~7 ~;-',' ~ 'A ~ ~ ~n0 = V C PETITION FOR GUARDIAN OF MINOR o~-" _ :? ~ ~` n _ NOW, comes the Petitioner, Emandalee Rebecka Whitcomb, by her attome~ `"' `. Jacqueline M. Verney, Esquire, and files this Petition for Guardian of Minor representing as follows: 2. 3. 4. 5. 6. 7 The proposed Guardians are Benjamin Markham and Teresa Markham, adult individuals residing at 19 McAllister Church Road, Carlisle, Cumberland County, Pennsylvania. Your Petitioner is Emandalee Rebecka Whitcomb, a minor child, age 15 years, who currently resides at 19 McAllister Church Road, Carlisle, Cumberland County, Pennsylvania. Petitioner is the former foster child of the proposed Guardians. Petitioner was placed with the proposed Guardians through Dauphin County Children & Youth Services from May 2005 to 2007, approximately 1 '/: years. Petitioner was returned to the care and custody of her Mother in 2007 and dependency was terminated by Dauphin County Court. Petitioner continued to visit with the proposed Guardians even after she retumed to the care and custody of her mother. Petitioner's mother died on April 16, 2009. The location of Petitioner's father is unknown and he has never had any contact with the child. 9. The Petitioner has three maternal aunts and ahalf-brother, none of whom are interested in assuming Guardianship of Petitioner. 10. Petitioner has no knowledge of any Court within this Commonwealth which has appointed a Guardian for her. 11. The proposed Guardians have no interest adverse to the minor child and have agreed to act as Guardians of the child if this Honorable Court shall so appoint. 12. Pursuant to the Cumberland County Rules of Orphan's Court 12.5-2, attached is a Consent form and statement of the proposed Guardians. 13. The appointment of a Guardian is necessary because the school district will not enroll the child in school unless a Guardian is appointed. WHEREFORE, Petitioner respectfully requests this Honorable Court set a hearing at which the averments of this petition may be documented and the appointment of Benjamin Markham and Teresa Markham as Guardians for the minor child, E.R.W. may be considered, with notice thereof to be given to such persons as this Court may direct. Respectfully submitted, Date a line M. Verney, Esquire #231 44 South Hanover Street Carlisle, PA 17013 (717)243-9190 Attorney for Petitioner ATTORNEY VERIFICATION I verify that the facts included in the within document are true and correct based on information known to me or received from reliable sources. I understand that false statements herein aze made subject to the penalties of 18 Pa. C. S.A. § 4904 relating to unsworn falsification to authorities. Dated: ~/-~ y-~ 9 (dacgfi~line M. Vemey, Esquire #¢3167 44 S. Hanover Street Cazlisle, PA 17013 717 243-9190 Attorney for Petitioner ewTHf i1-29-1993 _. IMO, onr, rEr,Ri COelAiil°F~ DAUPHIN / NAME ,i EMANDALEE R r ` 'FJ FATHERS NAME INFORMATI ~O -ECO `/i MOTHERS MAIDE~A ,E 1~ CYNTHIA JEAPt1 tEnrTmFn io 1602570-1993 ~ FILED 02-01-.1994 \ IMO. Mr. YE.ePI In eccotreirc wll~ Aq~BB, P L 90% iDprweE M iM OenereilAel pmplY. Juna Zp~tY+J°eperlmenl of Xeel(q / I CXAREES MARGESiER $iAlE RfGIGiMP XIlI6.IG61REV. 6~I~B61 9161286