HomeMy WebLinkAbout06-14-11IN THE COURT OF COMMON PLEAS, ORPHAN'S COURT DIVISION,
CUMBERLAND, PENNSYLVANIA
IN RE: JOHN STANLEY PAUKOVITS
(a minor child)
:NO: 21-2011-0318
:GUARDIANSHIP „U
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AMENDED PETITION FOR CO-GUARDIANSHIP/ ~
APPOINTMENT OF CO-CONSERVATORS ~'
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AND NOW come Katie Paukovits, Keith Paukovits and Aimee Paukovits, by and
through counsel, Lawrence J. Rosen. Esquire, and offers the following averments in support of
their Petition for Co-Guardianship/Appointment of Conservator of the minor child, John Stanley
Paukovits:
Petitioners, Katie Paukovits and Keith Paukovits who reside at 906 Acri Road,
Mechanicsburg, Cumberland County, Pennsylvania and Aimee Paukovits, who
resides at 213 C Enola Street, Enola, Cumberland County, Pennsylvania are
seeking to be named co-guardians/conservators of the person and estate of the
minor child, John Stanley Paukovits (DOB 01/15/2005)
Z. Petitioners, Katie and Keith Paukovits are the parents of the minor child.
Petitioner. Aimee L. Paukovits is the paternal aunt of the minor child.
3. The minor child resides with Petitioners, Katie and Keith Paukovits, at 906 Acri
Road. Mechanicsburg, Cumberland County. Pennsylvania.
4. The parents of the minor child are Katie Paukovits and Keith Paukovits who
reside at 906 Acri Road, Mechanicsburg, Cumberland County, Pennsylvania.
They agree that it is in the best interests of the minor child that the subject Petition
be granted and that they act as co-guardians/conservators of the person and estate
of the minor child with Aimee L. Paukovits. (See Exhibit A)
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5. The appointment of a co-guardian/conservator for the minor child is necessary as
the deceased grandfather of the minor child left a sum of monies through an
annuity naming the minor child as beneficiary. The subject company is requiring
a Court Order naming his guardian/conservator of the estate of the minor child
before it will release the funds due and owing to the minor child. (See Exhibit B)
6. There has never been an appointed guardian/conservator for the person or estate of
the minor child prior to this Petition.
7. Petitioners do not have any interest which may be described as adverse to the
minor child.
8. Petitioners and the minor child are of the same religious background.
9. Petitioners have executed consents agreeing (as parents of the minor child and as
paternal aunt of the minor child) to this action and to act as co-
guardians/conservator of the estate and person of the minor child. (See Exhibit C)
WE [EREFORE, Petitioners ask that Your Honorable Court grant the instant Petition and
name Katie Paukovits, Keith Paukovits and Aimee Paukovits as co-guardians/conservators of the
person and estate of the minor child, .lohn Stanley Paukovits.
Respectfully submitted:
KREVSKY ~ ROSF,N, P.C.
Lawrence J. Rosen, Esquire
1101 North Front Street
Harrisburg. PA 17102
lU# 10625
(717)234-4583
IN THE COURT OF COMMON PLEAS, ORPHAN'S COURT DIVISION,
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE:.IOHN STANLEY PAUKOVITS
(a minor child) : NO: 21-201 I-0318
GUARDIANSHIP
CONSENT
We. Katie Paukovits and Keith Paukovits , do hereby assert that we are the natural parents of the
minor child.. and I, Aimee Paukovits, do hereby assert that I am the paternal aunt of the minor
child. John Stanley Paukovits (DOB 1/15/05). By our signatures affixed hereto, it is our intention
to consent to our being named as co-guardians/conservators of the person and the estate of John
Stanley Paukovits. Our consent is given freely and with full understanding of the legal
implications attendant thereto. We believe that it is in the best interests of John Stanley Paukovits
that we he named as his co-guardians/executors and ask that Your Honorable Court grant the
subject Petition.
SIGNED: DATED:
P ~~ SIdN~II
Katie Paukovits
Keith aukovits
I
nnewits
IN THE COURT OF COMMON PLEAS, ORPHAN'S COURT DIVISION,
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE:.IOHN STANLEY PAUKOVI"I S
(a minor child)
:NO: 21-201 1-0318
:GUARDIANSHIP
CONSENT
We, Katie Paukovits, Keith Paukovits and Aimee Paukovits do hereby agree and consent to
become co-guardians/conservators of the person and estate of John Stanley Paukovits. We
are executing this consent voluntarily and with full knowledge of the legal implications
attendant hereto. We assure the Court that we will make all efforts to provide John Stanley
Paukovits, with the love, stability and nurturing that he requires to mature into a
responsible and productive adult and to protect and manage his assets in his best interests.
SIGNED: DATED:
-Ll~~ I C~o~ ~tlt.r,+s.a..~ S Z y~l.f~_
Katie Paukovits -
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Keith Paukovits
Aimee Paukovits
WESTERN J NATIONAL
March 14, 2011
Life Insurance C o m p a n y
P.O. Box 871
Amarillo, Texas 79105-0871
1.800.424.4990
KATIE A PAUKOVITS
FBO: JOHN STANLEY PAUKOVITS
906 ACRI RD
MECHANICSBURG PA 17050
RE: Deceased: Stanley Chimock
Contract #: VP224988
Beneficiary: John Stanley Paukovits
Deaz Mrs Paukovits:
We have received the request to defer receipt of the claims proceeds up to the fifth anniversary of the death of
Stanley Chimock or the eighteenth birthday of the minor beneficiary, John Stanley Paukovits. The funds must be
withdrawn no later than 06/02/2015. The proceeds will continue to earn interest as provided in the original contract.
Please keep this letter with your records for future reference.
When a beneficiary chooses the Open Claim Option, which defers payout up to five years, the following conditions
apply:
1. The contract remains in the deceased's name. You may not withdraw any of the proceeds until John Stanley
Paukovits obtains the age of majority (18) and completes the required forms or until we aze provided with a
court document listing the legal guazdian for the minor beneficiary along with the required forms.
2. Please be advised that once John Stanley Paukovits obtains age eighteen, he will be required to complete an
Annuity Claimant Statement to claim the proceeds. We will establish an American General Annuity Bridge
Account if the amount payable is $10,000 or more. Please see the enclosed brochure.
3. Internal Revenue Service requires that the beneficiary must take receipt of the proceeds within five years of
the death of the Owner.
4. In the event of death of the beneficiary prior to payout the remaining claims proceeds will be payable to
beneficiary's estate.
It is very important that you advise American General Annuity of any change in address. This will allow us to keep
in touch with you, notify you yearly of policy value and advise you of any interest rate changes that would affect the
policy.
If you should have any questions, please call 1-800-424-4990, and speak with a customer service representative.
Sincerely,
~~ 1
Patrick Bailey, Annuity laims Examiner
Annuity Claims Department
Enclosures