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IN RE: DYLAN X. JOHN~~`~
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A MINOR Cll.`,"~~~.. r ~! i ; :` 'p~,
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CUMBERLAND COUNTY
COURT OF COMMON PLEAS
ORPHANS' COURT DIVISION
PETITION FOR APPOINTMENT OF
CO-GUARDIANS OF THE ESTATE OF
A MINOR
PETITION FOR APPOINTMENT OF CO-GUARDIANS OF
THE ESTATE OF A MINOR
TO THE HONORABLE, THE JUDGES OF SAID COURT:
The Petition of Melissa Bobincheck and Robert Bobincheck ("Petitioners") respectfully
represents as follows:
1. This Petition is filed under and pursuant to Section 5111 of the Pennsylvania
Probate, Estates and Fiduciaries Code, 20 Pa. C.S. §5111, and Rule 12.5 of this Court.
2. Petitioner Melissa Bobincheck, age 28, is the mother of Dylan X. Johnson.
3. Petitioner Melissa Bobincheck resides at 1518 Tussey Court, Mechanicsburg, PA
17050.
4. Petitioner Robert Bobincheck is Melissa Bobincheck's father.
5. Petitioner Robert Bobincheck resides at 433 Sample Bridge Road, Enola, PA
17025.
6. The minor Dylan X. Johnson was born on October 25, 2009.
7. Dylan resides with Melissa at 1518 Tussey Court, Mechanicsburg, PA 17050.
8. Paul Johnson, the father of Dylan, died as the result of a shooting on June 15,
2011.
9. Paul Johnson died intestate. Dylan is the sole heir of Paul Johnson's estate, and
Petitioners anticipate he will receive at least $200,000 from the estate. He is also the beneficiary
of a $70,000 life insurance policy on Paul Johnson's life. Finally, Dylan is likely to receive
additional funds on account of claims arising from his father's death against the estate of the
shooter, Robert Liddick, who killed himself following the murder of Paul Johnson and another
individual.
10. Dylan has no general or testamentary guardian appointed by Will, deed, or
otherwise, to the knowledge or belief of Petitioners. No guardian of the estate or person has ever
been appointed for Dylan.
12. Dylan is not a child of a veteran and receives no benefits from the Veterans'
Administration or similar agency.
13. Petitioners Melissa Bobincheck and Robert Bobincheck seek to be appointed co-
guardians of the Estate of Dylan X. Johnson. The Consent of Petitioner Melissa Bobincheck is
attached hereto as Exhibit "A". The Consent of petitioner Robert Bobincheck is attached hereto
as Exhibit "B".
14. Petitioners do not have an interest adverse to Dylan X. Johnson.
15. Petitioners request that a bond requirement be waived.
2
WHEREFORE, Petitioners request that a decree be issued appointing Melissa
Bobincheck and Robert Bobincheck, the Petitioners, as Co-Guardians of the Estates of Dylan X.
Johnson.
1
Thomas P. Gacki, Esquire
ECKERT SEAMANS CHERIN & MELLOTT, LLC
213 Market Street, 8th Floor
Hamsburg, PA 17101
Attorneys for Petitioners
3
VERIFICATION
I, Melissa Bobincheck, hereby verify that all of the averments of fact contained in the
foregoing petition are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904,
relating to unsworn falsification to authorities.
Melissa Bobin eck
4
EXHIBIT A
CONSENT TO APPOINTMENT AS CO-GUARDIAN OF THE ESTATE
I, Melissa Bobincheck, natural guardian, consent to my appointment as Co-Guardian of
the Estate of Dylan X. Johnson, a minor.
WITNESS the execution hereof this ~ day of dv ~w , 2011.
WITNESS:
•~-
Melissa Bobinche
EXHIBIT B
CONSENT TO APPOINTMENT AS CO-GUARDIAN OF THE ESTATE
I, Robert Bobincheck, consent to my appointment as Co-Guardian of the Estate of
Dylan X. Johnson, a minor.
WITNESS the execution hereof this ~ day of _~'].~t, 2011.
WITNESS:
~ ~? 1
Robert Bobincheck
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CQMMONWEAL7H OF PENNSYLVANIA
Notarial seal
Tracy L. M. Horetsky, Notary Public
City of Harrisburg, Dauphin County
My Commission Expires April 26, 2014
Member, Pennsviv?~~' nggry~i.3~i~r of Notaries
IN RE: DYLAN X. JOHNSON,
A MINOR
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
ORPHANS' COURT DIVISION
NO.
PETITION FOR APPOINTMENT OF
CO-GUARDIANS OF THE ESTATE OF
: A MINOR
STATEMENT OF GUARDIANS PURSUANT TO CUMBERLAND COUNTY
ORPHANS' COURT RULE 12.5-2
1. We are citizens of the United States of America, and are able to speak, read and
write the English language.
2. It is not our intention to apply for an allowance for the support or education of the
minor during minority.
3. We are not a Fiduciary or an officer or employee of a corporate Fiduciary of an
estate in which the minor has an interest nor the surety or an officer or an employee of the
corporate surety of such a Fiduciary, and we have no interest adverse to the minor.
Melissa Bobi eck
Robert Bobincheck