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Brief Example - 1YOUR NAME 2Address 1 3Address 2 4Phone...

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YOUR NAME Address 1 Address 2 Phone Number Email SUPERIOR COURT OF PENNSYLVANIA County of Philadelphia ___________________________________ ) ) Estelle Roberts, ) ) ) v. ) ) PHEAA ) ___________________________________ ) No. 101 Brief in Support /Opposition (depending on which side you are on) of Petitioners’ Motion for Relief From Debt 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 28 29 30 31 32 33 34 35 36 37 38 39
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STATEMENT OF FACTS Factual History. Baby E. is the genetic child of Jose and Mary Ocosta. Res. Gen. Tests 3 (Feb. 14, 2007). He is genetically part of a big family with strong ethnic ties. Eval. 3-4. (Feb. 9, 2007). He has an older sister, grandparents, twelve aunts and uncles and numerous cousins, all of whom live near the Ocostas. Id. He is also part of the Puerto Rican ethnicity. Id. The Ocostas’ shared Puerto Rican culture and family is critical to them and they hope to unite their entire family. Id ; Depo. Mary Ocosta 8:19 (Feb. 2, 2007). Baby E. now lives with the Gladsteins who obtained him through an in vitro fertilization (IVF) mix up when Dina Gladstein was accidentally implanted with the Ocostas’ embryos that were intended only for the their use. Use of Embryos (Nov. 20, 2004); Depo. Dina Gladstein 13:15-19 (Feb. 13, 2007). The Ocostas were married in 1996 and live together in Pennsylvania. Eval. 3 (Feb. 9, 2007); Depo. Jose Ocosta 1:2-5 (Feb. 2, 2007). There, Mr. Ocosta works as a Sales Manager for Wachovia and Mrs. Ocosta works as an art teacher. Depo. J. Ocosta 2:15-17; Depo. M. Ocosta 7:15. The Ocostas’ moved back to the East Coast to be closer to their families. Eval. at 3. As both Mr. and Mrs. Ocosta are from big families, each having five siblings, having kids together has been of paramount importance to them and a focal point of their relationship since they first met. Id. When the Ocostas had trouble getting pregnant, they were willing to put themselves into $20,000 in debt in order to have two IVF procedures. Id; Depo. M. Ocosta 6:14. Mrs. Ocosta withstood the pain and the frequent sickness of the egg-harvesting procedure, as well as the difficulties of labor, all to be a mother. Id. at 6:23, 6:5-6. Mrs. Ocosta was thrilled when she had her first daughter Isabel through IVF and went back to the Center for Reproductive Health (Center) for a second procedure three years later. Id. at 7:6-7. The Ocostas went back to the Center for the second round of IVF on September 2, 2004. Use of Embryos (Nov. 20, 2004). On November 15, 2004, the Ocostas completed egg harvesting and produced fourteen embryos of their own genetic material. Id. Four of those embryos where implanted into Mrs. Ocosta, but she did not become pregnant. Id ; Depo. J. Ocosta 4:20-21. In early 2005, Mrs. Ocosta was diagnosed with diabetes and discouraged by her doctor from undergoing additional IVF procedures. Depo. M. Ocosta 9:10-13. The Ocostas completed and signed the Center’s Use of Embryos Form on November 20, 2004, indicating that their
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Brief Example - 1YOUR NAME 2Address 1 3Address 2 4Phone...

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