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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
IN THE MATTER OF
KARA N. HARTMOYER
A Minor Person
ORPHANS' COURT DMSION
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No. .;21'0~ - 00 q 3
)
Petition for Avvointment for Limited Guarcllan
Of Minor'. Estate
Pursuant to 15 Pa. C.S. ~5511 et al., and Ru1e 12.5 of the Orphan Court
Ru1es, Kristyn A. Hartmoyer, ("Petitioner") presents this Petition'.' for
Appointment for Limited Guardian of Minor's Estate for consideration and
respectfu1ly request that this honorable Court order that Robert D. Bowen
("Proposed Linnted Guardian") be appointed Limited Guardian for Petitioner's
daughter, Kara N. Hartmoyer, a minor person under the age of 14.
1. Petitioner resides at 143 Ewe Road, Mechanicsburg, Cumberland County,
Pennsylvania, 17055.
2. Petitioner is the mother of Kara N. Hartmoyer, a minor.
3. The above-named minor is under 14 years of age, having been born on
September 6, 1996, in the City of Harrisburg, County of Dauphin,
Commonwealth of Pennsylvania.
4. The above-named minor resides with her mother, the Petitioner, and her
Grandfather, the Proposed Limited Guardian, at 143 Ewe Road,
Mechanicsburg, Cumberland County, Pennsylvania.
5. Kenneth K. Hartmoyer II, the father of the above-named minor, is dead,
having died in a vehicle accident on Interstate 81 near mile post 133.0, on
September 1, 2004.
6. Kristyn A. Hartmoyer, the above-named minor's mother and Petitioner
hereby consents to this petition.
7. The above-named minor is entitled to certain property and estate, and to
protect and preserve the legal rights of such minor, it is necessary that some
proper person be duly appointed the Limited Guardian of her estate to receive
and deposit funds now being held in minor's name by Jefferson Pilot Financial
of Omaha, Nebraska. According to policy and procedures of Jefferson Pilot
Financial they will not release the mmor's funds to her or to minor's parent.
Jefferson Pilot Financial will only release the funds of the minor to a Guardian
appointed by a Court.
.)..
.,
8. The above-named minor has now no general or testamentary ~ardian
appointed by will, deed, or otherwise, to the knowledge or belief of Petitioner.
9. The above-named minor is entitled to the following certain property and
estate:
a. Insurance proceeds in the approximate amount of $10,800.00, as minor
was the beneficiary of an insurance policy her recently deceased father had
contracted for with Jefferson Pilot Financial.
"
10. The personal property above-mentioned is described as follows: Life
insurance funds being held by Jefferson Pilot Financial of Omaha, Nebraska.
The interest of said minor therein is as follows: 100% primary beneficiary of
policy number CL-0000091233.
11. No notice is required to be given to the United States Veteran's'
Administration or its successor.
12. Robert D. Bowen, minor's maternal yrandfather, is a fit and proper
person to be appointed Limited Guardian 0 the estate of the above-named
minor, as he is competent to administer the funds and properly invest them for
use for the minor's education, health or physical or mental needs. In addition,
Petitioner does not know of any adverse reason that the Proposed Limited
Guardian would have to minor's estate. The Proposed Limited Guardian is well
educated, healthy and has the requisite knowledge to oversee the proper
management of the minor' funds.
Wherefore, Petitioner requests that a decree issue appointing Robert D.
Bowen the Limited Guardian of the estate property mentioned above for the
benefit of the above-named minor and for such other relief as the court may
deem proper.
HJIJD~ A. J-I{}~
Kristyn A. Hartmoyer, Petitioner
&4-/ ji;:;J
Duane P. Stone
Attorney No.: 85715
Law Offices of Duane P. Stone, P.C.
P.O. Box 696
Dillsburg, PA 17019
717 -432-2089
U1
JEFFERSON PilOT FINANCIAL
P.O. BOx 2649
OMAHA, NE 68103-2649
Bus: 1-877-843-3948
www.jpfinancial.com
JEfFERSON PILOT
FINANCIAL
December 14,2004
KRISTYN HARTMOYER
143 EWE ROAD
MECHANlCSBURG P A 17055
RE: Deceased: Kenneth K. Hartmoyer II
Policy Nmnber: CL - 0000091233
Claim Nmnber: 1040131680
Dear Ms. Hartmoyer:
Jefferson Pilot Financial has purchased the U.S. group business of Canada Life Assurance
Company. As a result, Jefferson Pilot Financial is now processing the death claim referenced
above.
On November 10, 2004, we sent a letter to you requesting information on the death claim
submitted for Kenneth K. Hartmoyer II. As of this date, we have not received these docmnents.
This is our second request for the following information.
Before benefits can be considered, the following docmnentation must be forwarded to our office:
1) Guardianship Paperwork Over The Financial Estate OfKara N. Hartmoyer
Please forward the docmnentation requested above to our office within the next 30 days.
If you should have any questions, please contact our office at 877-843-3948.
Ainanda Prochaska
Life Benefit Specialist
Employee Care Center
Jefferson Pilot Financial Insurance Company
Administrator for Canada Life Assurance Company
"
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
IN THE MATTER OF
KARA N. HARTMOYER
A Minor Person
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.
ORPHANS' COURT DIVISION
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.
No.
CONSENT OF PROPOSED LIMITED GUARDIAN
Robert D. Bowen does hereby certify that he is willing to act as Guardian
of Kara N. Hartmoyer, a minor person, in the limited capacity of authority
relating to certain property of such minor effective immediately ("Guardian"), if
the Court shall so appoint. Said personal property is of the value of
approximately $10,800.00 and are the proceeds from her deceased father's life
insurance policy that named Kara N. Hartmoyer the primary beneficiary. The
personal property is being held by Jefferson Pilot Financial of Omaha,
Nebraska, as their Life Insurance Policy requires that a Guardian be appointed
for minors receiving funds as a beneficiary. As a Limited Guardian, Robert D.
Bowen, understands that he has certain fiduciary duties related to the minor's
personal property and he must exercise control of said property for her benefit,
including transferring personal property to an appropriate account, utilizing
funds for the minor's education, health and welfare, until the minor reaches
the age of twenty-one; at which time, any and all remaining property shall be
immediately distributed to Kara N. Hartmoyer.
Further, Robert D. Bowen hereby certifies that he is not a fiduciary of
any estate in which Kara N. Hartmoyer has an interest, nor has he any interest
currently adverse to Kara N. Hartmoyer.
Dated:
tin! 0 '1
(LLf D. f1.---
Robert D. Bowen
9 ~!j;/;:;)
Duane P. Stone
Attorney No.: 85715
Law Offices of Duane P. Stone, P.C.
P.O. Box 696
Dillsburg, PA 17019
717-432-2089
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
IN THE MATTER OF
KARA N. HARTMOYER
A Minor Person
.
.
ORPHANS' COURT DMSION
.
.
.
.
No.
VERIFICATION
The undersigned hereby verifies that the statements of fact in the
foregoing document are true and correct to the best of my knowledge,
information and belief. I understand that any false statements therein are
subject to the penalties contained in 18 Pa. C. S. ~ 4904, relating to unsworn
falsification to authorities.
Dated:
J / a. 7 IDS
)1n~ HDA~
. styn A. Hoyer
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
IN THE MATTER OF
KARA N. HARTMOYER
A Minor Person
ORPHANS' COURT DIVISION
No.
VERIFICATION
The undersigned hereby verifies that the statements of fact in the
foregoing document are true and correct to the best of my knowledge,
information and belief. I understand that any false statements therein are
subject to the penalties contained in 18 Pa. C. S. ~ 4904, relating to unsworn
falsification to authorities.
Dated:
JJ/17/{)'S
.
~ a ftJ.. ftr.J'f'~;y ~ /1
Kara N. Hartmoy
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
IN THE MATTER OF
KARA N. HARTMOYER
A Minor Person
ORPHANS' COURT DIVISION
.
.
No.
VERIFICATION
The undersigned hereby verifies that the statements of fact in the
foregoing document are true and correct to the best of my knowledge,
information and belief. I understand that any false statements therein are
subject to the penalties contained in 18 Pa. C. S. ~ 4904, relating to unsworn
falsification to authorities.
Dated:
0.7/6~
~ .
(U..,J j), tJ-v--
Robert D. Bowen