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HomeMy WebLinkAbout10-18-05 \ f IN RE: Guardianship of : IN THE COURT OF COMMON PLEAS OF JOSHUA LEE ANDERSON : CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS COURT DIVISION 2''''os- ~~d-~ PETITION FOR APPOINTMENT OF GUARDIAN FOR A MINOR AND now, comes Petitioner, Gloria A. Anderson, by and through her counsel of record, Bradley L. Griffie, Esquire and the law firm of Griffie & Associates, and petition~ ~~ _):'1;~ -; -/ c-h the Court as follows: ',t' ~t ! "1- 1. Your Petitioner is Gloria A. Anderson, an adult individual currently residingaJ i 810 Greenspring Road, Newville, Cumberland County, Pennsylvania. , r'...) i 2. The minor at issue is Joshua Lee Anderson, of 810 Greenspring Road, NewviUef Cumberland County, Pennsylvania, age 11, born November 26, 1993. 3. The natural parents of the minor, Joshua Lee Anderson, are Gloria A. Anderson~ your Petitioner, and David L. Anderson of 810 Greenspring Road, Newville~ Cumberland County, Pennsylvania. 4. The minor at issue in this proceeding is the natural son of Gloria A. Andersoq and David L. Anderson. 5. The minor's parents consent to this Petition in that the minor's natural mother, Gloria A. Anderson, is the Petitioner and the minor's father, David L. Anderson, has executed a Consent, which is attached hereto and incorporated herein by! reference as Exhibit '"A" and will take part in these proceedings. 6. The necessity or reason for appointment of Guardian in this matter has arisen due: to the fact that the minor is a named beneficiary on certain life insurance policiesl , with Prudential Financial on the named insured, Victor S. Russell, deceased. ~ . J \ I 7. The said Victor S. Russell passed away on May 5, 2005 as the insured under three life insurance policies with Prudential Financial, as evidenced by the enclosed correspondence dated May 11, 2005 to your Petitioner. I 8. The minor at issue has not had a guardian appointed for him in any other proceedings. , 9. The proposed Guardian, your Petitioner, is Gloria A. Anderson, of 8H~ Greenspring Road, Newville, Cumberland County, Pennsylvania, 37 years of age, born January 4, 1968. She is the minor's natural mother. 10. Your Petitioner and proposed Guardian has no interest adverse to that of th~ minor at issue. 11. The minor has no assets of any nature beyond those assets to be received upo~ the disbursement of the death benefit proceeds from the Prudential Financiallif~ I I insurance policies on the life of the late Victor S. Russell as referenced above. 12. From the limited information that Petitioner and her counsel have been able to secure from Prudential Financial, the exact amount of the life insurance deatl\ benefits are unknown at this time. 13. The minor at issue is not involved in any litigation which will result in thd payment for disbursement of funds. 14. As the parents of the minor are not now, nor have they been, in the military service with the United States Government, there is no obligation to give notice! to the United States Veterans Administration or its successor. WHEREFORE, Petitioner requests your Honorable Court to enter an Order naming her as Guardian of the estate of her son, the minor at issue herein, Joshua Lee Anderson. Respectfully submitted, . Griffie, Esquire ey for Petitioner 2 North Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 1 , I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATE: to~t/-OS ~ 8,L1rv~ GLOIDAA.ANDERSON \ , . , IN RE: Guardianship of : IN THE COURT OF COMMON PLEAS OF JOSHUA LEE ANDERSON : CUMBERLAND COUNTY, PENNSYLVANIA : ORPHANS COURT DIVISION CONSENT OF NATURAL FATHER I hereby confirm that I am the natural father of Joshua Lee Anderson and, as suc~ have reviewed the foregoing Petition and consent to the entry of an Order naming my I wife and Joshua's mother, Gloria A. Anderson, as the Guardian of his estate. I verify that the statements made in the foregoing document are true and correct. l understand that false statements herein are made subject to the penalties of 18 Pa.C.S\ Section 4904, relating to unsworn falsification to authorities. - DATE: /0 -4 " Cl_S f)~:;;:L ~ DAVID L. ANDERSON EXHIBIT "A"