HomeMy WebLinkAbout02-08-07
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NATHAN C. WOLF, ESQUIRE
ATTORNEY ID NO. 87380
10 WEST HIGH STREET
CARLISLE PA 17013
(717) 241-4436
ATTORNEY FOR RESPONDENT
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: IN THE COURT OF COMMON P~~F sg
: CUMBERLAND COUNTY, PENNSyiW~IA I
: ORPHAN'S COURT DIVISION ,J; ~< C::>
INRE:
BENJAMIN RITTER
Born 9/13/1996
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: NO. 21-06-1022 ORPHAN'S ::CJ::
: GUARDIANSHIP - INCAPACITAm:lY"PERS6l-ir
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An alleged incapacitated person
MOTIONFOR CO"N.llNUANCE
AND NOW comes the respondent, Lany Ritter, by and through his counsel Nathan C.
Wolf, Esquire, and in support of his motion avers as follows:
1. The above-captioned matter is scheduled for a plenary guardianship hearing concerning
the above-referenced incapacitated person, Benjamin Ritter. Said hearing is scheduled to take place
on the 12th clay of February, 2007, at 1:00 o'clock p.rn., before the Honorable Edward E. Guido.
2. The moving party for said proceeding is the respondent, Lany Ritter, the natural father of
the alleged incapacitated person, Benjamin Ritter, represented by Nathan C. Wolf, Esquire.
3. Joining in the instant motion is Candi Yinger, the temporary plenary guardian for the
alleged incapacitated person represented by JohnJ. Mangan, Esquire and Mathew S. Crosby,
Esquire, Court-Appointed counsel for the alleged incapacitated person.
5. This proceeding has been previously continued once, from January 11, 2007 until
February 12,2007.
6. A continuance is requested because the parties, after an extended meeting held this date
believe that this matter may reach a resolution which would eliminate the need for a hearing and
because all counsel involved need additional time to meet with and secure the testimony of the
medical providers for the alleged incapacitated person.
7. As stated previously, all parties agree and therefore aver that they need additional time to
prepare and obtain records which cannot be accomplished prior to the February 12, 2007 hearing.
8. The parties specifically request a continuance of not less than two months.
WHEREFORE, Respondent Larry R Ritter, respectfully prays that this Honorable Court grant the
foregoing motion and reschedule this matter to a date no sooner that April 12, 2007 along with any
additional relief that the Court may deem appropriate and just.
Dated: February 8, 2007
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Respec~{~bmitted,
WOLF & woy
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NathanJ?)V6if, Esquire
10 Weu.High Street
Carlisle, PA 17013
Supreme Court LD. No. 87380
(717) 241-4436
Attorney for Respondent
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NATHAN C. WOLF, ESQUIRE
A'ITORNEY ID NO. 87380
10 WEST HIGH STREET
CARLISLE PA 17013
(717) 241-4436
A'ITORNEY FOR RESPONDENT
INRE:
BENJAMIN RITTER
Born 9/13/1996
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: ORPHAN'S COURT DIVISION
An alleged incapacitate person
: NO. 21-06-1022 ORPHAN'S
: GUARDIANSHIP - INCAPACITATED PERSON
CERTIFICATE OF SERVICE
I hereby certify this day that I served a copy of the Motion for Continuance of Hearing upon
the following by United States mail, postage prepaid, addressed as follows:
John J. Mangan, Esquire
BAYLEY & MANGAN
57 West Pomfret Street
Carlisle, PA 17013
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February ~ , 2007
Matthew S. Crosby, Esquire
HANDLER HENNING AND ROSENBERG, LLP
1300 Linglestown Road '7
Harrisburg, P A ~7110 // / .
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By: b/' /'--
/ . ..' NATHANC. WOLF
Attom~for Respondent, Larry Ritter
10 West High Street
Carlisle, PA 17013
717-241-4436
Supreme Court ID No. 87380