HomeMy WebLinkAbout02-07-12.. A~
IN COURT OF COMMON PLEAS OF CUMBERLAND COUN~~,~ ~~11Y,SYI,iA~~1
ORPHAN S COURT ,,~~'' kL 1 ~~' U
IN RE: Gibson, Memphis G.W. : No. CLERK CF
A MINOR ~ - 1 ~ °61 U? `~ ~IORPF~t~N'S ~(~n!Rr
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PETITION FOR APPOINTMENT OF A GUARDIAN OF THE PERSON OF A MINOR
TO THE HONORABLE, THE JUDGES OF SAID COURT:
AND NOW comes Petitioners, Billy Joe Gibson and Karen Gibson, by their attorney Jessica
E. Guise, ESQUIRE, and respectfully request they be granted guardianship of Memphis G.W.
Gibson, a minor. The petitioners represent that:
1. Memphis is 2 years old and was born on September 28, 2009.
2. He currently resides at 6017 Robert Drive, Mechanicsburg, Pennsylvania, with the
proposed guardians.
3. Memphis is the child of Amanda Gibson, daughter of the petitioners, who is also residing
in Mechanicsburg, Pennsylvania. The identity, location and address of his father are unknown.
4. Memphis' mother consent to the Petition as evidenced by her consent attached hereto as
"Exhibit A" and incorporated herein by reference. Petitioners are unable to obtain the consent of
Memphis' father, as his identity is unknown and he cannot be located.
5. Petitioners believes therefore avers that they should be appointed as the guardian of
Memphis' person because he has resided from birth with Petitioners and will continue to reside
with Petitioners. Petitioners provide all daily care and support of Memphis, including seeking
health care on his behalf.
6. The proposed guardian, Karen Gibson is 46 years of age, is the maternal grandmother of
Memphis and resides at Mechanicsburg, Pennsylvania.
7. The proposed guardian, Billy Joe Gibson is 48 years of age, is the maternal grandfather
of Memphis and resides at Mechanicsburg, Pennsylvania.
8. The proposed guardians are married to each other. They are the parents of one child, who
is an adult and no longer resides in their home. They reside in awell-appointed home with
accommodations suitable for the minor subject of these proceedings.
9. The proposed guardians have no interest adverse to Petitioner.
10. The natural mother is a member of the Baptist faith. The proposed guardians are also
members of the Baptist faith. They will continue to raise Memphis within the Baptist religious
tradition.
11. The proposed guardians consent to said appointment, such consent being attached hereto
as "Exhibit B" and "Exhibit C" incorporated herein.
WHEREFORE, Petitioners Billy Joe Gibson and Karen Gibson, request that the Court
appoint them as guardian of the person of Memphis G.W. Gibson.
;motto ey for the Petitioners
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I swear that the facts related above are true to the best of my kn ledge and belief.
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Affidavit
EXHIBIT A
IN COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ORPHAN'S COURT DIVISION
IN RE: Gibson, Memphis G.W. : No.
A MINOR
CONSET OF NATURAL PARENT
I ACCEPT notice of the foregoing Petition for the Appointment of Karen Gibson and
Billy Joe Gibson as guardians of the person of my minor child Memphis G.W. Gibson and
consent thereof.
Amanda Gibson, Mother
EXHIBIT B
IN COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ORPHAN'S COURT DIVISION
IN RE: Gibson, Memphis G.W.
A MINOR
No.
CONSET OF PROPOSED GUARDIANS
I CERTIFY that my domicile is 6017 Robert Drive, Mechanicsburg, Pennsylvania;
That I am 46 years of age and a citizen of the United States;
That I am the maternal grandmother of the minor;
That I have no interests adverse to the minor;
I agree to accept the appointment as guardian of the person of Memphis G.W. Gibson a
minor.
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Kare Gibson, Guardian
EXHIBIT C
IN COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ORPHAN'S COURT DIVISION
IN RE: Gibson, Memphis G.W. : No.
A MINOR
CONSET OF PROPOSED GUARDIANS
I CERTIFY that my domicile is 6017 Robert Drive, Mechanicsburg, Pennsylvania;
That I am 48 years of age and a citizen of the United States;
That I am the maternal grandfather of the minor;
That I have no interests adverse to the minor;
I agree to accept the appointment as guardian of the person of Memphis G.W. Gibson a
minor.
C
Bil y Joe Gibson, Guardian