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Home My WebLink About10-27-05 IN THE MATTER OF THE RE: APPOINTMENT OF A GUARDIAN OF THE PERSON AND ESTATE OF BRAE DON ARTHUR ROBERT FUNK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. OS- -CjL{ 1 I I ' PETITION FOR APPOINTMENT OF GUARDIANS FOR THE PERSON AND ESTATE OF BRAE DON ARTHUR ROBERT FUNK ~... '. .-' AND NOW, come the Petitioners and proposed Guardians, Nevin W. Funk, and Janice K. Funk, by and through their attorneys, Jones & Henninger, P.C. and aver as follows: 1. The minor is Braedon Arthur Robert Funk, born September 28, 2005, who currently resides at 6300 Auburn Drive, Mechanicsburg, Cumberland County, Pennsylvania, with his mother, also a minor, Cara Funk and his maternal grandparents, your Petitioners, Nevin W. Funk and Janice K. Funk. 2. The father of the minor child, Robert John Mossman, an adult individual born August 19,1986, currently resides at 1416 Fresno Road, Wilmington, Delaware, 19803. 3. Your Petitioners are Nevin W. Funk and Janice K. Funk, maternal grandparents of the minor child, who currently reside at 6300 Auburn Drive, Mechanicsburg, Cumberland County, Pennsylvania. 4. Your minor's parents, Robert John Mossman, an adult individual born I' August 19, 1986 and Cara Funk, a minor born December 7, 1987, consent to this Petition. The father, Robert John Mossman's Consent is attached hereto, marked Exhibit "A", and made a part hereof by reference thereto. The consent of the mothe~, Cara Funk, is attached hereto, marked Exhibit "B", and made a part hereof by reference thereto. 5. It is necessary for a guardian of the Person and Estate of Braedon Arthur Robert Funk be appointed by this Court since it is the position of the father, , Robert John Mossman, who currently resides in Delaware, that he is unable at this tUne to provide for his son and due to the fact that the minor child's mother, Cara Funk is a minor who is still attending high school, and although she is residing with your Petitioner's and with her son, she is incapable of providing care, support and more specifically medical insurance for her son, your minor, Braedon Arthur Robert Funk. 6. It is also vitally important and necessary to appoint Temporary Guardians of the Person of Braedon Arthur Robert Funk due to the fact that his health insuranca coverage expires this Friday, October 28,2005 due to a thirty (30) day rule and the proposed Guardians policy will pick him up so long as they are appointed. Furthermore, your minor has certain medical conditions that need addressed immediately and cant1lot wait until after a hearing in this matter. 7. The proposed Guardians of the Person and Estate of Braedon Arthur Robert Funk are his maternal grandparents, Nevin W. Funk, an adult individual born August 9, 1955 and Janice K. Funk, an adult individual born July 16, 1958. 8. Neither of your proposed guardians have any interest adverse to that of II the minor, including, inter alia, any estate in which the minor is interested in which the proposed guardians are a fiduciary or surety, or employee of a fiduciary or surety therein. 9. The parents of the minor child, and your proposed guardians are all of the Protestant persuasian. 10. At the present time there are no assets in the estate of your minor. 11. To the best of their knowledge, information and belief, your Petitioners aver that the minor is not entitled to receive any money as a party of any action or proceeding in any Court. 12. Your minor is not a child of a veteran and no insurance your other gratuity is payable to him by the United States Veteran's Administration or it's successors. 13. The proposed Guardians' written consents to the appointment are attached hereto as Exhibits "C" and "0". WHEREFORE, your Petitioners respectfully pray upon the Court to appoint them Temporary Guardians of the Person and Estate of Braedon Arthur Robert Funk, a minor, and schedule a prompt hearing to determine if they can be appointed Guardians of the Person and Estate of Braedon. By: Peter R. He 1.0.# 44873 Jones & Henninger, P.C. 905 West Governor Road, Ste 330 Hershey, PA 17033 (717) 533-7116 doc.FUNK.consent&statementofguardian. 00587.10.24.05 11 IN THE MATTER OF THE RE: APPOINTMENT OF A GUARDIAN OF THE PERSON AND ESTATE OF BRAEDON ARTHUR ROBERT FUNK IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYlVA~IA ORPHANS' COURT DIVISION I :NO. CONSENT OF FATHER I, Robert John Mossman, an adult individual born August 19, 1986, the fathe~ of I the minor, accept Notice of the foregoing Petition and consent to the appointment o~ Nevin W. Funk and Janice K. Funk of Hampden Township, Cumberland County, Pennsylvania, as Guardians of the Person and Estate of Braedon Arthur Robert Furlk, a minor. t:1J 1,L4f~ Robert John Mossman ~ EXHIBIT II All II IN THE MA TIER OF THE RE: APPOINTMENT OF A GUARDIAN OF THE PERSON AND ESTATE OF BRAEDON ARTHUR ROBERT FUNK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA! ORPHANS' COURT DIVISION NO. CONSENT AND STATEMENT OF MOTHER I, Cara Funk, a minor individual born December 7, 1987, the mother of the mihor, accept notice of the foregoing Petition and consent to the appointment of my parent~, , Nevin W. Funk and Janice K. Funk of Hampden Township, Cumberland County, Pennsylvania, as guardians of the person and estate of Braedon Arthur Robert Fun~, a minor, my son born September db ,2005. IN WITNESS WHEREOF, I set my hand and seal this October, 2005. 21PI day of ~'-,' f <<--f. Cara Funk doc. FUNK.consent&statementofguardian.mother.00587.1 0.24.05 EXHIBIT 11811 I' IN THE MA TIER OF THE RE: APPOINTMENT OF A GUARDIAN OF THE PERSON AND ESTATE OF BRAEDON ARTHUR ROBERT FUNK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA! ORPHANS' COURT DIVISION NO. CONSENT AND STATEMENT OF GUARDIAN I, Nevin W. Funk, hereby consent to my appointment as Co-Guardian of the person and estate of Braedon Arthur Robert Funk, a minor, and in support thereof I make the following statement: (1) that I am a citizen of the United States of America and am able to speak, read and write the English language; (2) that Braedon Arthur Robert Funk resides in my household and that it is not my intention to apply for an allowance for the support or education of Braedon Arthur Robert Funk during his minority; (3) that I am not a fiduciary, officer or employee of a corporate fiduciary of ejm estate in which the minor has an interest nor the surety, officer, or employee of a corporate surety of such a fiduciary, and that I have no interest adverse to Braedon Arthur Robert Funk, a minor. IN WITNESS WHEREOF, I set my hand and seal this 25771 day of October, 2005. doc. FUNK.consent&statementofguardian.00587.1 0.24.05 EXHIBIT lie II I' IN THE MATTER OF THE RE: APPOINTMENT OF A GUARDIAN OF THE PERSON AND ESTATE OF BRAEDON ARTHUR ROBERT FUNK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIAI ORPHANS' COURT DIVISION NO. CONSENT AND STATEMENT OF GUARDIAN I, Janice K. Funk, hereby consent to my appointment as Co-Guardian of the person and estate of Braedon Arthur Robert Funk, a minor. and in support thereof I make the following statement: (1) that I am a citizen of the United States of America and am able to speak, read and write the English language; (2) that Braedon Arthur Robert Funk resides in my household and that it is not my intention to apply for an allowance for the support or education of Braedon Arthur Robert Funk during his minority; (3) that I am not a fiduciary, officer or employee of a corporate fiduciary of an estate in which the minor has an interest nor the surety, officer, or employee of a corporate surety of such a fiduciary, and that I have no interest adverse to Braedon Arthur Robert Funk, a minor. IN WITNESS WHEREOF, I set my hand and seal this :::ft; M day of October, 2005. - --. ~~u'tc -I!:fti-i( Jani~ K. Funk doc. FUN K.consent&statementofguardian.janice. 00587.10.24.05 EXHIBIT 110" I' VERIFICATION I, Janice K. Funk, verify that the statements made in the foregoing Petitio~ are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. ~ 4904, relating to unsworn falsification to authorities. Date: /O/Jf!l{{ff ( ! /-i". // /) d <..-.:- t1./,u_ /1. ,/'J.vA" '" ~ "" I j,anice K. Funk doc. FUNK. verification.janice. 00587.10.24. 05.doc VERIFICATION I' I, Nevin W. Funk, verify that the statements made in the foregoing Petitio~ I I are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. Date: lo~ 25- oS doc. FUNK. verification. nevin. 00587.10.24. 05.doc