HomeMy WebLinkAbout08-21-12BREANNA COOK and
MATTHEW COOK, Husband and Wife
Petitioners
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 21-12-872
ORPHANS' COURT DIVIS
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PETITION TO AMEND CAPTION
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AND NOW come the Petitioners, Breanna Cook and Matthew Coo>~husband did -"
wife, by and through their attorney, John F. King, Esq., 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, and no longer in this Court's jurisdiction.
4. The parties in the guardianship action have previously executed and filed
with the Clerk of Orphan's Court, a Petition and Consents requesting the Court to award
guardianship of Zackariah Little to Breanna and Matthew Cook.
5. The child is of school age, and the child cannot be registered at school
without an Order of guardianship from this court.
6. After the filing of the original Petition and Consents in this matter, it was
brought to the attention of John F. King, Esq., that the Court requires that the child's name be
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included in the caption.
7. The natural Mother, Christine Little McMillen, is no longer in t:he
jurisdiction and "somewhere in Iowa", and the parties would be unable to obtain a new consent
from natural Mother in a timely fashion.
8. The Petitioners hereby request that the caption above be amended as
follows:
BREANNA COOK and
MATTHEW COOK, Husband and Wife
Petitioners
In re: Guardianship of Zackariah Little,
A Minor Child
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 21-12-872
ORPHANS' COURT DIVISION
9. The Petitioners would request that Court entertain all documents filed under
the original caption, as if filed under the amended caption.
WHEREFORE, Petitioners respectfully request this Honorable Court to amend the
caption herein, and to entertain all documents filed under the original caption, as if filed under the
amended caption.
Respectfully submitted,
JOHN F. KING LAW, P.C.
Date: ~ ~U I~
J F. King, Esquire
4076 Market Street
Camp Hill, PA 17011
(717) 695-2222
(717) 695-2207 FAX
VERIFICATION
We, Breanna Cook and Matthew Cook, hereby acknowledge that we are the
Petitioners in the foregoing action; that we have read the foregoing Petition to Amend Caption;
and the facts stated therein are true and correct to the best of our knowledge, information and
belief.
We understand that any false statements herein are made subject to penalties of 18
Pa. C.S. Section 4904, relating to unsworn falsification to authorities.
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Breanna Cook
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Dated: ~~' ~ Z' ``