HomeMy WebLinkAbout10-03-11IN THE MATTER OF
NICHOLAS R. PRICE,
A Minor
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
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NO. 21-07-1036 ORPHANS' COUP
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MOTION TO TERMINATE TEMPORARY GURADIANSHIP .~-_~~_~ ~?
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NOW comes petitioner, Kelly Sentz, through her attorneys, MidPenn Legal Services, and
presents this motion to terminate the temporary guardianship of the minor child Nicholas R.
Price, representing as follows:
1. Petitioner is Kelly Sentz, an adult individual residing at 329 A Greason Road,
Carlisle, Pennsylvania, 17015. Petitioner is the mother of the minor child Nicholas R. Price.
2. The minor child was born on May 3, 1995, and is 16 years old. The child is the
son of Kelly Sentz and Joseph Nestelli, who were unmarried at the time of the child's birth.
3. On December 11, 2007, the Honorable Judge Oler granted temporary
guardianship of the child to Vanessa Moore, the child's aunt, and Brian Moore, the child's uncle.
See Order of Court, attached as Exhibit A.
4. At the time this Court ordered temporary guardianship to Vanessa Moore and
Brian Moore, petitioner was incarcerated.
5. Petitioner was released from incarceration on July 4, 2010.
6. From July 2010 to June 2011, Petitioner had custody of the child every other
weekend.
7. Since July 2011, child has resided with Petitioner.
8. Petitioner is able and willing to resume her parental responsibilities to the child.
9. Co-guardian, Vanessa Moore, consents to terminating the temporary
guardianship. See Consent to Terminate Guardianship, attached as exhibit B.
10. Co-guardian, Brian Moore, consents to terminating the temporary guardianship.
See Consent to Terminate Guardianship, attached as exhibit C.
11. Minor child Nicholas R. Price consents to the temporary guardianship being
terminated. See Consent to Terminate Guardianship, attached as exhibit D.
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12. Child's father, Joseph Nestelli, consent to terminate this guardianship has not
been obtained.
WHEREFORE, Petitioner respectfully requests this Honorable Court release Vanessa
Moore and Brian Moore as temporary co-guardians of minor child Nicholas R. Price.
Respectfully Submitted,
MIDPENN LEGAL SERVICES
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ate Amv H' is
Attoryfev for Petitioner
Atty zp/1Vo. 310094
401 East Louther Street, Suite 103
Carlisle, PA 17013
717-243-9400
VERIFICATION
The above-named Petitioner, Kelly sentz, verifies that the
statements made in the above Motion are true and correct.
Plaintiff understands that false statements herein are made
subject to the penalties of 18 Pa. C.S. §4904, relating to
unsworn falsifica ion to authorities.
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ATTORNEY ID NO. Z~ZO
64 SOUTH PITT STREET
CARLISLE PA 17013
(719) ?at3~0Y0
ATTORNEY FOR PETtT10NERS
IN TII~lE MATTER OF : IN TIFf2 COURT OF COMM~DN PLEAB OF
:CUMBERLAND COUNTY, PENNBYLVANf1A
NICHOLA8 R. PRICE, : ORPHANB COURT DIVI810N
A MINOR : NO, a\ b-1 1v3~O
tiUARD1AN8HIP-MINOR
ORDER OF COURT
MOW, this ~~ day of ~e~-- , 2007, on motion of Harold S. Irwin, III, Esquire, upon
consideration of the attached petition and after a hearing held following due notice, BRIAN K.
MOORE and VANESSA K. MOORE are appointed temporary co-guardians of the p~;rson and
of the estate of NICHOLAS R. PRICE. No bond shall be required of petitioners.
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By the L"ourt,
f'~I THE MATTER OF
I~ilCHOLAS R. PRICE,
A Minor
II~1 TEIE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
NO. 2I-07-1036 ORPHANS' COURT'
CONSENT TO TERMINATE TEMPORARY GUARDIANSHIP
I. Vanessa K. Moore, certify that I am the temporary co-guardian of the minor child Nicholas R.
Price.
I consent to this Court terminating my temporary guardshlp o~t the minor child.
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Vanessa K. Moore
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TiV THE ?u1ATTER OF : IN THE COURT Oh COMMON PLEAS OF
NICHOLAS R. PRICE, :CUMBERLAND COUNTY PE r
NNSYLVANIA
A Minor :ORPHANS' COURT DIVIcION
NO. 21-07-1036 ORPI-TANS' COIJRri'
CONSENT TO TERMINATE TEMPORARY UUARD[ANSHIP
I, Brian K. Moore, ceirtify that I am the temporary co-guardian of the minor child Nicholas R.
Price.
I consent to this Court terminating my temporary guardianship of the minor child.
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Date
Brian K. Moore
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1N THE MATTER OF : IN THE COURT OF COMMON PLEAS OF
NICHOLAS R. PRICE, :CUMBERLAND COUNTY, PENNSYLVANIA
A Minor :ORPHANS' COURT DIVISION
NO. 21-07-1036 ORPHANS' COURT
CONSENT TO TERMINATE TEMPORARY GUARDIANSHIP
I, Nicholas Price, consent to this Court terminating the temporary guardianship that Vanessa
Moore and Brian Moore have on my behalf. I also consent to my mother, Kelly Sentz, resuming
her role as my legal guardian.
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Date Nicholas Price