Loading...
HomeMy WebLinkAbout08-17-09IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. ~' J - U 9 - ~/'7~ ESTATE OF MADELINE ROSE OWENS, MINOR 0 0 w a chi v PETITION FOR APPOINTMENT OF GUARDIAN OF A FOR RECEIPT OF INSURANCE PROCEEDS OF A DEC 2 r r r; ,-~r- ~i '_c',' ri; c+i ~.. '.: The Petition of Dennis T. Owens and Amanda Martin Owens to be appointed as Guazdians for their minor daughter, Madeline Rose Owens, respectfully represents that: 1. 2. 3 4. 5. 6. 7 Petitioners are 47 and 34 yeazs of age, respectively, and reside at 508 Partridge Court, Hampden Township (Mechanicsburg), Cumberland County, Pennsylvania, 17050. Petitioners aze husband and wife, and aze the natural pazents of Madeline Rose Owens, a minor, age 2, born on October 6, 2006. . Petitioner, Dennis T. Owens, is a surviving brother of Michael Thomas Owens, who died on May ICJ , 2008, a resident of Philadelphia County, Pennsylvania. The Decedent, Michael Thomas Owens, did not have a Will. The minor, Madeline Rose Owens, is the named beneficiary of life insurance proceeds from The Hartford Life & Accident Insurance Company, Policy No. ADD-10900, in the amount of Fifty Thousand Dollars ($50,000.00). The minor has no other assets. In order to receive the proceeds of the aforementioned life insurance policy, The Hartford Life & Accident Insurance Company requires that Guardians be appointed for the minor. The proposed Guardians have no interest adverse to the minor. 8. Petitioners have individually executed Consents to Serve as Guazdian of the Estate, which Consents are attached to this Petition, and they further consent to the appointment of a Co-Guardian, as required by 20 Pa.C.S.A. §5112(3), in the person of the undersigned. WHEREFORE, Petitioners respectfully request that this Honorable Court appoint Dennis T. Owens and Amanda Martin Owens as Guazdians of the Estate of Madeline Rose Owens, a minor. Date: August ~-, 2009 Respectfully submitted: By: H orky Goldstei , # 07182 Attorney for Petitioners 59 Central Blvd. Camp Hill, PA 17011 (717)236-6491 COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~/a(,~~E/~~/ SS DENNIS T. OWENS and AMANDA MARTIN OWENS, being duly sworn according to law depose and say that they aze the Petitioners in the foregoing Petition and the facts set forth therein aze true and correct to the best of their knowledge, inform ion and belief. DE S T. OWENR-, TIN Sworn to & subscribed before me This ~ day of August, 2009. Not lia ~' ` -° ~~~~nNMeMEwp,C'upM"~ ~mD«. vm 1017 #768619-v1 50056-0001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. OBI ~~~~ ESTATE OF MADELINE ROSE OWENS, MINOR CONSENT TO APPOINTMENT OF CO-GUARDIAN OF THE ESTATE I, AMANDA MARTIN OWENS, Natural Mother of the Minor, Madeline Rose Owens, do hereby consent to the appointment of Herbert Corky Goldstein, Esquire to serve with me as Co-Guazdian of the Estate of my daughter, Madeline Rose Owens. AMANDA MARTIN O NS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION No. Oq -11 D ESTATE OF MADELINE ROSE OWENS, MINOR CONSENT TO APPOINTMENT OF CO-GUARDIAN OF THE ESTATE I, DENNIS T. OWENS, Natural Father of the Minor, Madeline Rose Owens, do hereby consent to the appointment of Herbert Corky Goldstein, Esquire to serve with me as Co- Guazdian of the Estate of my daughter, Madeline Rose Owens. I 9 D IS T. OWENS #768651-v1 50056-0001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. ~~ - -l7 O ESTATE OF MADELINE ROSE OWENS, MINOR CONSENT TO SERVE AS GUARDIAN OF THE ESTATE I, AMANDA MARTIN OWENS, do hereby consent to serve as the Guardian of the Estate of my daughter, Madeline Rose Owens. I am 34 years old and am a homemaker and part time media producer. I am a citizen of the United States and reside at 508 Partridge Court, Hampden Township (Mechanicsburg), Cumberland County, Pennsylvania 17050. I can read, write and speak the English language. I have no interest adverse to Madeline Rose Owens. A TIN OW NS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. ~ 1 -~~~ ESTATE OF MADELINE ROSE OWENS, MINOR CONSENT TO SERVE AS GUARDIAN OF THE ESTATE I, DENNIS T. OWENS, do hereby consent to serve as the Guardian of the Estate of my daughter, Madeline Rose Owens. I am 47 years old and am employed as a News Anchor. I am a citizen of the United States and reside at 508 Partridge Court, Hampden Township (Mechanicsburg), Cumberland County, Pennsylvania 17050. I can read, write and speak the English language. I have no interest adverse to Madeline Rose Owens. n n DENNIS T. OWENS #768655-v1 50056-0001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO.~- l l~ ESTATE OF MADELINE ROSE OWENS, MINOR CONSENT TO SERVE AS CO-GUARDIAN OF THE ESTATE I, HERBERT CORKY GOLDSTEIN, ESQUIRE, do hereby consent to serve as Co- Guardian of the Estate of Madeline Rose Owens, a minor. I am 68 years old and am employed as an attorney. I am a citizen of the United States and reside at 2900 Pazkside Lane, Harrisburg, Dauphin County, Pennsylvania 17110. I can read, write and speak the English language. I have no interest adverse to Madeline Rose Owens. #768660-v1 50056-0001