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HomeMy WebLinkAbout08-09-12r BREANNA COOK and : IN THE COURT OF COMMON PLEAS OF MATTHEW COOK, Husband and Wife :CUMBERLAND COUNTY, PENNSYLVANIA Petitioners ORPHANS' COURT DIVISION CQ ~~ ~., -~; ~ x~• ~ ~~ C ~._, G7 r ~ { r 1 r _ ~ ~ ~ PETITION FOR APPOINTMENT OF GUARDIANS _ ~~' ~ -~ `~~~ `~-_ OF A PERSON OF A MINOR CHILD °' ` ~'~ ~"~~ ~ ~ =' = ~ ~ £: ~r ~ ~ 4n p --n c.^~ AND NOW come the Petitioners, Breanna Cook and Matthew Cook, husban d and wife, and petition this Honorable Court as follows: 1. The Petitioners are Breanna and Matthew Cook, husband and wife, who currently reside at 228 Cumberland Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The subject minor child is Zackariah Little. 8 years of age, date of birth is November 20, 2003. 3. The subject minor child's natural mother is Christine Little McMillen, who is currently without permanent residence. 4. The natural father of the subject minor child is Joseph Auston. 5. The natural father of the child, Joseph Auston, has never exercised custody or visitation of the child, nor has he ever sought custody or visitation of the child. 6. The natural father of the child, Joseph Auston, does not financially support the child. 7. The natural father of the child, Joseph Auston's, current residence is unknown. 8. The subject minor child resides with his maternal aunt, Petitioner, Breanna. Cook, her husband, Petitioner, Matthew Cook, and Mazen Cook, the 1 1 /2 year old child of the Petitioners, in the Petitioners' residence at 228 Cumberland Road, Camp Hill, PA 1.7011. 9. The subject minor child's natural mother, Christine Little McMillen, consents to this instant Petition, and by such consent does aver that the relief sought in this instant Petition is in the best interest of the subject minor child. 10. The necessity for the appointment of a Guardian for the subject minor child is averred as follows: A. The subject child, Zackariah Little is 8 years of age, and is currently residing in the home of the Petitioners. B. The subject child's natural mother, Christine Little McMillen, is currently without a permanent residence, and is unable to provide the necessary emotional support and disciplinary oversight to the subject child, which would otherwise be required for the subject child to thrive in his school and social settings. C. The subject child is without a home base in order to allow for the enrollment and attendance at school in the upcoming 2012/2013 school year. D. The subject child has recently moved in with his aunt, uncle and cousin, in their residence at 228 Cumberland Road, Camp Hill, Cumberland County, PA 1701 1, which residence is of sufficient size and quality to provide an appropriate safe residence for the subject child. E. The subject child's aunt and her husband are able to provide the necessary emotional support and disciplinary oversight to the subject child, which is required for the subject child to thrive in his school and social settings. 11. The proposed Guardian, Breanna Cook, is the maternal aunt of the subject minor child, and does reside at 228 Cumberland Road, Camp Hill, Cumberland County, along with her husband, Petitioner, Matthew Cook, and the Petitioners' daughter, Mazen Cook, and have resided there for approximately two (2) years. 12. The proposed Guardians do not have any interest adverse to that of the minor child. 13. The religious persuasion of the Petitioner, Matthew Cook, is Christian, and the religious persuasion of the Petitioner, Breanna Cook and the natural mother of the child, is unaffiliated. The religious persuasion of the natural father is unknown. 14. The Petitioners are not entitled to receive any money, nor are they a party to any action or proceeding, in any Court. 15. The subject minor child is not the child of a Veteran. WHEREFORE, Petitioners respectfully request this Honorable Court appoint Breanna Cook and Matthew Cook, husband and wife, as the Guardians of the person of the subject minor child, Zackariah Little. Date: ~02-- Respectfully submitted, JOHN F. KING LAW, P.C. ~~- J F. King, Esquire 4076 Market Street Camp Hill, PA 17011 (717)695-2222 (717) 695-2207 FAX BREANNA COOK and 1N THE COURT OF COMMON PLEAS OF MATTHEW COOK, Husband and Wife :CUMBERLAND COUNTY, PENNSYLVANIA Petitioners NO. ORPHANS' COURT DIVISION CONSENT We, Breanna Cook and Matthew Cook, hereby consent to being appointed as Guardians of Zackariah Little. Date: ~ ~ .~ ~ ~ Z ~~ Date: t~~ ~3 ~ I z- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this, the ~ day of ~~ 2012, before me a Notary Public, the undersigned officer, personally appeared Breanna Coo -known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that sloe executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. i1W 11 >IHi1------~-~. ~~ MLL y ~ E~~ C01 otary Public COMMONWEALTH ANIA COUNTY OF CUMBERLAND On this, the ~ day of~ S ~ .2012, before me a Notary Public, the undersigned officer, personally appeared Matthew Cook known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that lie executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ,. ; i K ~""" otary Public =MAIg1Y . ~bry ~~ ~ Comnyi~:~' Alyd ap1~, E~t'hM~. tOt~ BREANNA COOK and : IN THE COURT OF COMMON PLEAS OF MATTHEW COOK, Husband and Wife :CUMBERLAND COUNTY, PENNSYLVANIA Petitioners NO. ORPHANS' COURT DIVISION CONSENT I, Christine Little McMillen, am the natural mother of the subject minor child, Zackariah Little, and I hereby consent to Breanna Cook and Matthew Cook being appointed as Guardians of my son, Zackariah Little. I further do swear and attest that there is no available information relating to the location of the natural father of the subject minor child, which natural father has never exercised nor sought custody of visitation of the subject minor child. Date: ~~ ~'~ ~ 12- Christine Little McMillen mcti~Q,Q~ COMMONWEALTH/STATE OF ~~ COUNTY OF ~ 1~- ~{Z~:Gt-~~-~. On this, the ~~ day of ~ , 2012, before me a Notary Public. the undersigned officer, personally appeared ~ hristine Little McMillen known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Rj - --.~~~ NOtAR1AL8EAL otary Public SHABBY D =EMNK Nary CAMP INLL SOltOUBH, Ctl i000N1Y My Cominbsion Ex~ BREANNA COOK and MATTHEW COOK, Husband and Wife Petitioners IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION STATEMENT OF PROPOSED GUARDIANS, PURSUANT TO LOCAL RULE 12.5-2 The proposed Guardians, Breanna Cook and Matthew Cook, are citizens of the United States and are able to speak, read and write the English language. 2. It is not the intention of the proposed Guardians, Breanna Cook and Matthew Cook, to apply for an allowance for the support or education of the subject minor child during minority. The proposed Guardians, Breanna Cook and Matthew Cook, are not the Fiduciary or an officer or employee of a corporate Fiduciary of an estate in which the minor has an interest, nor are they the surety or an officer or an employee of the corporate surety of such a Fiduciary, and the proposed Guardians, Breanna Cook and Matthew Cook, have no interest adverse to the subject minor child. llate: ~S ~ / Z-- Date: ~/ ~ f ~ ~- Breanna Cook f Matthe ~ ook