VERIFIED PETITION FOR APPOINTMENT

OF GUARDIAN OF PERSON AND ESTATE

STATE OF INDIANA

SS:

COUNTY OF KOSCIUSKO

IN THE MATTER OF THE GUARDIANSHIP OF:

DANIEL KREIS, Minor

IN THE KOSCIUSKO SUPERIOR COURT

CAUSE NO. 43001-2011-GU-000047

    COMES NOW Petitioner, John Mills, by counsel, David C. Van Gilder and petitions the Court for an order appointing him guardian of the person and estate of Daniel Kreis, a minor child. In support thereof, Petitioner shows as follows:

    1. That the alleged incapacitated person is Daniel Kreis, born April 6, 2016, who is 4 years of age. Daniel currently resides with foster parents.

    2. That Daniel Kreis is incapacitated by virtue of his age.

    3. That  Daniel  Kreis  does  not  have  any  property,  real  or  personal,  other  than personal effects.

4.    That there is no guardian appointed or acting for the person and estate of Daniel Kreis in Indiana or any other state.

    5. That Petitioner John Mills is Daniel's maternal grandfather.

    6. That Daniel's biological mother is Sarah Kreis, who is currently homeless.

    7. That  Daniel's  biological  father  is  Dyrell  Kreis, currently  incarcerated  in  the Kosciusko County Jail.

    8. That Petitioner does not serve as court-appointed guardian over any other person in Indiana or any other state.

    9. That Petitioner does not seek to limit the guardianship of the person and estate of Daniel Kreis in any way.

    10.  That the Department of Child Services has not filed a petition or made an informal adjustment regarding the minor child, Daniel Kreis as of the time of this filing.

    That the names and addresses of the persons most closely related by blood or marriage to Daniel Kreis are as follows:

    Sarah Kreis, Mother

    Address unknown

    Dyrell Kreis, Father

    Kosciusko County Jail

    221 W Main St.

    Warsaw, IN 46580

    11. That the attorney for the guardianship is David C. Van Gilder of Fletcher Van Gilder, LLP, 436 East Wayne Street, Fort Wayne, IN 46802.

    WHEREFORE,  Petitioner, John Mills, respectfully prays the Court to enter an Order as follows:

    A. That a hearing be scheduled on this Petition for Appointment of Guardian of the Person and Estate, consistent with the preservation of the rights of the alleged incapacitated person;

    B. Requiring that all necessary parties and persons who have not consented to the guardianship and waived notice be given adequate notice of these proceedings;

    C. Finding that Daniel Kreis is incapacitated and that a guardianship over his person and estate is necessary to protect his interests;

    D. Finding  that  Petitioner,  John  Mills,  is  a  suitable  person  to  be  appointed  as guardian of the person and estate of Daniel Kreis;

E.     Finding that Daniel Kreis is under the age of twenty-one (21) years; F.    Finding that Daniel Kreis is unmarried;

    G. Appointing John Mills as guardian of the person and estate of Daniel Kreis, to serve without bond, and setting out the duties and powers of the guardian; and

    H. For all other just and proper relief in the premises.

    I affirm under the penalties for perjury that the above and foregoing are true and correct to the best of my knowledge and belief.

John Mills

STATE OF INDIANA

SS:

COUNTY OF ALLEN

    Subscribed  and  sworn  before  me,  a Notary  Public  in and  for  said  County  and  State, personally appeared the Petitioner, John Mills, this  6 day of November, 2020.

Estella M. Rodriguez, Notary Public

Prepared by:

David C. Van Gilder, #15290-02

Fletcher Van Gilder, LLP

436 E. Wayne St.

Fort Wayne, IN 46802

Phone:  (260) 425-9777

Email: vangilder@fvglaw.com

Attorneys for Petitioner

11-13,20,27 hspaxlp