HomeMy WebLinkAbout01-14-13
IN RE: APPLICATION FOR MARRIAGE IN THE COURT OF COMMON PLEAS OF
LICENSE OF CARL W. BELL, JR., AND CUMBERLAND COUNTY,
MARY L. BALTIMORE COMMONWEALTH OF PENNSYLVANIA
ORPHANS' COURT DIVISION
NO. ,MARRIAGE LICENSE; =201: d
jVj
U _ t a
p rPETITION FOR APPLICATION FOR MARRIAGE LICENSE' M
UNDER 23 Pa. C.S. 1306
r
To the Honorable, the Judge of the Said Court:
The Petition of CARL W. BELL, JR., and MARY L. BALTIMORE under 23
Pa. C. S. § 1306, regarding oral examinations for application of marriage license
Petitioners respectfully represent:
1. Petitioners are both adult individuals residing in Cumberland County.
2. Petitioner BALTIMORE resides at 232 West Ridge, Carlisle, PA 17013.
Petitioner BELL, JR., resides at Manor Care Health Services, 940 Walnut
Bottom Road, Carlisle, PA 17015.
3. The Petitioners are desirous of entering into marriage and therefore they
are required to undergo an oral examination to be conducted by the
Cumberland County Register of Wills pursuant to 23 Pa. C. S. § 1306.
4. Petitioners desire that the Cumberland County Register of Wills conduct
an oral examination for application of marriage license.
5. Petitioner BELL, JR., is a disabled individual and as such he is confined
to reside at Manor Care Health Services, 940 Walnut Bottom Road, Carlisle,
PA 17015, Room 135, for an indefinite period of time.
t
6. During the indefinite period of confinement, Petitioner BELL, JR., is
unable to leave the facility in order to attend the oral examination at the office
of the Cumberland County Register of Wills. (See Exhibit A.)
7. It is the desire of the Petitioners that the relationship of husband and wife
be established, and in order to do so an application for marriage license must
be completed, including the oral examination.
WHEREFORE, the Petitioners, believing and alleging that the right to marriage
will be promoted by the completion of the application, including the conducting of the
oral examination at the place of Petitioner's confinement, prays your Honorable Court to
either Order the Cumberland County Register of Wills to conduct the oral examination as
requested, or in the alternative, schedule a Hearing on the matter.
ADAM R. DELUCA, ESQ.
Attorney for Petitioners
61 West Louther Street
Carlisle, PA 17013
717-249-1177
Supreme Court Attorney I.D. # 311738
.
VERIFICATION
CARL W. BELL, JR., and MARY L. BALTIMORE, being duly sworn
according to law, deposes and says that they are the Petitioners in the foregoing matter,
and that the facts set forth in the foregoing Petition are true and correct to the best of their
knowledge, information and belief. This statement is made subject to the penalties of 18
Pa. C.S. § 4904 relating to unsworn falsification to authorities.
e
Petitioner
~j
Petitioner
~-3
Dated.
ManorCare
940 Walnut Bottom Road
Carlisle, PA 17015
717-249-0085 717-249-0647 Fax ManorCcUCV
ArN
Health Services
01/03/13
To whom it may concern:
Mr. Carl Bell has been a patient at ManorCare of Carlisle since 10/10/12. He is not
physically able at this time to leave the center, unless by a stretcher, due to his current
physical condition.
If you should have any further questions you can call me at 717-249-0085 ext. 254
Respectfully,
Mary C. Kane BSW
Social Services
ManorCare of Carlisle
X