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Home My WebLink About97-06045 "1 , I I 1 "- I .Q .. ~ ~ I i) , I i ~ , I ) . . 1 . ! i , ". ! i ! . I . ... ~ " \I} ) f i\. .' It !! 11 .. r ~ ! -t--I i . .. I ~ I ~I I "" . 0 ..., ~ i )0 0 ~ fYI 0Q ~ IV) .1.0 - . ~1\ ~ (S) ~ ~~ ~ v ~ ~. ' ~ ~ <::Ill) ~ ::::t-- ~ Ql ~~ - ~ !i lloE-o H"" .j.l ::t Ul lil:::: ~ III :;!\H ns 00 .o:.j.l ~ iii j~ ~~ Z ..0 l:: ~ ::E Orill:l'.-j Ql i~~ ~rnUl '" ..... -c ~- UH p::ril:><.... Ql E-o ::; U -:;! U ril~p::1l. 0 Z .... . ~ '1''> r..H< _Il. .0: H ~ . '< :il:il OOH p:: Z :s ; .Ji E-o~~ 00 '~ , - r:::r::: Hrill:l > p:: ~ ... H -- p:: > ZE-o Il. 0 0 310 CC OlIl~ ril.o:~ H 0 III ~~ OE-o UlE-o E-o Z U 0 i:x\i: g) ~~ U"'Ul HH~ ril ril'>l~ 'U~ rn u:: u -! al .0: ..1 ~ ... lIllIlril ~6~ p:: 0 E-oE-oIl. ~ ~ zr..r.. Z:><ril HOO Halll. SHERIFF'S RETURN - REGULAR CASE NOI 1991-0604~ P !t--~ COftftONWEALTH OF PENNSYLVANIA I COUNTY OF CUftBERLAND SENIOR ALftA B ET AL VS. SENIOR ELftER WESLEY COOK CUftBERLAND County, Penn.ylvania, who to law, .ay., the within COftPLAINT - upon SENIOR ELftER defendant, at 1834100 HOURS, on the ~ day of Novemb.r 19i1 at 140~ LDUTHER ROAD CAftP HILL. PA 11011 County, Penn.ylvania, by handing to ELftER SENIOR a true and att..t.d copy of the COftPLAINT - EQUITY togeth.r with NOTICE and at the .... time directing His .ttention to the cont.nt. th.r.of. . Shariff or Deputy Sheriff of being duly .worn according EIiIUITY "all .erved the . .CUftBERLAND . . . Sheriff'. CO.t.1 Dock.ting Service Affidavit Surch.rg. 18.00 8.68 .00 2,00 So an.w.r~:"'r? / (ff 1'- ...~"...c..c:< ~ H. Tho... Kl1ne, ~n.r eZ8.bB WILLIAft R. BUNT 11/06/1991 , /. /) ./ by //~'f",",/'" iff .,. ~ . .... a.pu1:.y 5her1%% Sworn and .ub.cribed to b.for. .. f."'- thi. day o~ -/t(n'~ ~L~ ,r~_ j 19 '17 A.D, \.J- (' ~' 0- ~, ;;.!.~ (.L.- UrJi.- I ., flro ono~.fy , , ALMA B, SENIOR. AN IN THE COURT OF COMMON PLEAS INCAPACITATED PERSON OF THE NINTH JUDICIAL DISTRICT BY WILLIAM G, REESE, PERMANENT: OF PENNSYLVANIA PLENARY GUARDIAN, Plaintiff : ACTION IN EaUITY v, ELMER SENIOR, Defendant NO, q7- 60LfS~-r~ NOTICE You have been sued in court, If you wish to defend the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a witten appearance personally or by attorney and filing with the court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff, You may lose money or property or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, Pennsylvania 17013 717-240-6200 Dated: October) 6, 1997 By: IF WILLI~. BUNT, ESaUIRE 109 S, Carlisle Street P. O. Box 336 New Bloomfield, Pennsylvania 17068 717-582-8195 Attorney for Plaintiff LAW OFFICE OF WILLIAM R BUNT WILLIAM R, BUNT CHIlYSTAl L PRO!l5ER ArrOTINEYS AT LAW 109 5 CortiN Street New BkJomtlekt Po 1106& Tel (717) 582-8195 FAX (717) 582-7521 ALMA B, SENIOR, IN THE COURT OF COMMON PLEAS AN INCAPACITATED PERSON, OF THE 9TH JUDICIAL DISTRICT BY WILLIAM G, REESE, PERMANENT: OF PENNSYLVANIA PLENARY GUARDIAN, Plaintiff v, ACTION IN EQUITY Defendant NO, Q7- ~otf5' ~ T~ ELMER SENIOR, COMPLAINl AND NOW COMES, Plaintiff, ALMA B, SENIOR, an Incapacitated Person, by WILLIAM G, REESE, Permanent Plenary Guardian, by and through her attorney, WILLIAM R. BUNT, ESQUIRE, and respectfully represents as follows: 1, That Plaintiff is Alma B, Senior v.t1ose permanent residence is Claremont Nursing and Rehabilitation Center of Cumberland County located at 375 Claremont Drive, Carlisle, Cumberland County, Pennsylvania, 2, That William G, Reese Vd/b/a w.G, Reese Financial Guardian Services, (hereinafter referred to as Plaintiff's Guardian) was appointed permanent plenary glJardian of the Estate of Alma B. Senior, an incapacitated person, by Order of Court dated November 22, 1996, A copy of said Order is marked "Exhibit A', attached hereto and LAW OffiCE OF WILLIAM R BUNT incorporated herein by reference thereto, WILLIAM R, BUNT CHRYSTAl L. PROSSER AnORNEVS AT LAW 3, That Plaintiff's Guardian has his place of business at 138 North Second Street, NeVvport, Perry County, Pennsylvania. 109 s. CQfllM Sir..' New 8kJomt\e1d. Po 17068 4, That Defendant is Elmer Senior, Ihtlose address is 1405 Louther Road, Camp rei (711) 5&2.8195 FAX (717)5112.1521 Hill, Pennsylvania 17011, 5, That Defendant is the husband of the said Alma 8, Senior, an incapacitated adult. 6, That Defendant and the said Alma B. Senior hold property and resources individually and jointly as tenants by the entireties, 7, That an application was made by Plaintiff's Guardian to the Cumberland County Assistance Office to enroll the said Alma B, Senior for medical assistance to cover the cost of her nursing home care, 6, That the Cumberland County Office of Public Assistance determined that the amount of !he said Alma B, Senior's share of resources held jointly with Defendant is Fifty- Five Thousand, Seventy-Four ($55,074,00) Dollars as of March 20, 1997, A copy of the "Re9ult of Resource Assessmenr prepared by the Cumberland County Assistance Office is marked Exhibit B, attached hereto and incorporated herein by reference thereto, 9, That the following assets, valued as of November 27, 1996, are included as a part of the amount referenced in Paragraph 6 above: a, First National Bank of Nev.port Certificate of Deposit, account number 2205505160, in the amount of Eighty Thousand ($60,000,00) Dollars held by Defendant and Alma B, Senior jointly, LAW OffiCE Of WILLIAM R BUNT b, PNC Bank Checking Account, # 5060387497, in the amount of WILLIAM R. BUNT CHRYSTAL L, PROSSER ATTOIlNEYS AT LAW Thirteen Thousand, Seven Hundred and Ten Dollars and Seventy-Two Cents ($13,710,72), in the name of the said Alma B, Senior. 109 5 Cont1i. Street New 9IoomtJeltj. Po 17068 Page 2 of 6 rei (117) 5llH 195 FA)( (117) 5112,7521 of Cumberland County Is owed approximately Twenty-One Thousand, Three Hundred Twelve ($21,312,00) Dollars for the care and maintenance of the said Alma 8, Senior. 14, That since the entry of the March 20, 1997 Order of Court, said Certificate of Deposit has continued to produce income in the form of interest payments, 15, That Plaintiff's Guardian has requested Defendant to surrender Plaintiff's portion of said Certificate of Deposit or Thirty-One Thousand, Five Hundred ($31,500,00) Dollars as well as the interest payments earned thereon, 16. That Defendant has failed to surrender Plaintiff's portion of said Certificate of Deposit to Plain1iff's Guardian for the care and main1enance of the said Alma 8, Senior, 17, ThaI Defendant has failed to surrender any portion of said in1erest payments to Plaintiff's Guardian for the care and maintenance of the said Alma 8, Senior, WHEREFORE, Plaintiff prays Your Honorable Court to enter judgment in favor of Plaintiff and Order Defendant to surrender Plaintiffs portion of jointly held assets, COUNT I - PARTITION 18, That Paragraphs 1 through 17 above are incorporated herein by reference thereto, LAW OFFICE OF WILLIAM R, BUNT 19, That Defendant has deprived Plaintiff of her right to a portion of the Certificate of Deposit and other jointly held assets by refusing to provide her with her WILLIAM R, BUNT CHRYSTAL L. PROSSER ATTORNEYS AT LAW portion of the same, 20, That Defendant has interfered with attempts by Plaintiff's Guardian to gain 109 5_ COlllSle 5"98f New 8Ioomfleld. Po 17008 Page 4 of6 Tel (71/) ~2-eI95 FAX (/17) 582-7521 possession or control of said Certificate of Deposit and other jointly held assets, 21, That Defendant remains in possession of the Certificate of Deposit and othar jointly held assets in which the said Alma Senior has a right. 22, That the said Alma Senior has not consented to Defendant withholding access to said property, 23, That there exists no lawful justification for Defendant to withhold said Alma Senior's interest in the property, 24, That said interference is inconsistent with the rights of Alma Senior in said property, 25, That Defendant has appropriated property held by the entireties for his oVvf1 use, 26, That said appropriation is to the exclusion of the said Alma B, Senior, 27, That said appropriation operates to convert the oVvf1ership in said property from tenants by the entireties to tenants in common, 28, That Plairtiffs Guardian desires to dispose of the said Alma B, Senior's right, title and interest in 1he property but has been unable to arrive at a satisfactory arrangement with Defendant for the amicable disposition of the property, 29, That the necessity of seeking a remedy through Your Honorable Court LAW OFFICE OF WILLIAM R, BUNT increases the costs and fees to be incurred by Plaintiff, thereby diminishing the amount of WILLIAM R BUNT CHRYSTAL L. PROSSER AnORNEVS AT LAW funds available for her care and maintenance, 30, That said diminishment in the availability of funds, significantly impacts on 109 S. CQrllsle StUJet N.... 8Ioomneld. Po 1706a Page 5 of 6 Tol (717)581-8195 FAX (717) 582-7521 VERIFICATION " I hereby verify that the information set forth in 1he foregoing is true and correct to the best of my knCl'Nledge, Informa1ion and belief. I understand that any false statements contained herein are subject to the penalties of 18 Pa, e.s. 4904, relating to unsworn falsification to authorities. Dated: t?ci . df. / 99 7 ( r~ Jb.I)~ William G. Reese, Permenant Plenary Guardian of the Estate of Alma B. Senior, an incapacitated person IN THE MATTER OF TilE PERSON AND ESTATE OF: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION ALMA B. SENIOR, an alleged incapacitated person No, 21-96-890 ORDER OF COURT AND NOW, this 22nd day of November, 1996, upon consideration of the Petition for Appointment of permanent Plenary Guardian of the Person and Estate, and following a hearing, Alma B, Senior is adjudicated an incapacitated person. The Area Agency on Aging in and for Cumberland county, Pennsylvania, is appointed plenary guardian of the person of Alma B. Senior. william G, Reese (W.G, Reese Financial Guardian services), F.O. Box 351, Newport, Pennsylvania, is appointed plenary guardian of the estate of Alma B, Senior, conditioned upon his filing bond as security for the proper performance of his duties in the amount of $50,000.00, The guardians are directed to file reports in accordance with the provisions of 20 Pa. C.S. Section 5521(C). No bond shall be required of the Area Agency on Aging. Notice is hereby provided to Alma B. Senior through her court-Appointed counsel, Susan J. otto, Esquire, and through service of this order of her right to appeal, and to petition to modify or terminate the guardianships created herein. EXHIBIT "A" '~ ,~ .........,,";"""... -""" ,..........,............ DI'AIHMINT 0' 'UILIC WIL,AR' CUMBERLAND COUNTY ASSISTANCE OFFICE 33 Wcstmlnstcr Drivc P.O, Box 599 CarlbIc. PCDnsy1vanla 17013-0599 if 1 ~ 'I YJ ' TlL',HOHI NUMIIIl "IOO.UI.017J C71J1 140-2700 Dear yYW' l '\.01..' L"l. . RESULTS OP lE~uURCE ASSESSMENT Date YJ1J.,\ (11, dO , ICY/7 The oepartmrnt of Public Welfare has completed the Resource Assessment received on J, l'?/CI 7 . Based on the information you prOVided. the tdta value of the countable resources owned by you and your sPRuse as of the date of your admission to the nursing facility is~ rIll 14\(,... . A copy of the Resource Assessment Porm is enclosed. , The purpose of the assessment was to determine what portion of the total resources owned by you and your spouse may be protected for the spouse at home. This portion is called the "protected spousal share" and is not considered available to pay for nursing facility care. This protected spousal shar~ is generally one-half of your joint resources, up to a maximum, set by federal law (currently 879.020) and not less than a minimum (curp nj~y S15.804.1 Based on that formula, your protected spousal share is ~ ,)()7t(~,) - , Except as described below, you should apply for Medical Assistance when the total countable resources of you and your spouse are reduced to an amount approximately equal to the protected spousal share (above) plus S2,400. In some cases, more re~ources may be protected for the spouse at home. In order to be able to protect more resources, you must apply for Medicaid sooner and request a hearing. Information describing when you are permitted to protect more resources for your spouse at home was included in Part 3 of the .'dmissions Notice Packet you received from the nursinq facility when YOII were admitted. You should refer to this information if the income of the spouse at home is less than 81976 per month. If you need another copy of Part 3. contact the admissions office of your nursing facility, It is important for you to calculate the monthly i~come allowance and actual monthly income needs of the spouse at home in order to appropriately protect resour~es and provlde income to your spouse at home as pp,rmitted by federal law. The enclosed worksheet will help you in making this determlOation. Once you have applled for Medicaid benefits, either you or your spouse may request a fair hearing it you are dissatisfied with the Department's determination of the community spouse's share of resources or monthly income allowance, or to establish that your spouse shonld receive a higher inCOMe or resource allowance, It you hav~ ant questions about this letter. you may contact llIe by telephone at r;. ,( U ,,-:). 7 V~' or by writing to the address above, / - h]7)- ,.).(..,c, - () / 7 j C c . { Jpt,,(.r/ ~ /;V' ;{UL.C" " C (' AJ ~I 0, c/ ? IJ..__ Sincerely, ~l. Grit.1~L{ EXHIBIT "B" !NCOMP. A33P.33!1P.tIT.., WO~K:lI!EI~ You. the spouse livinq at home. are entitled to a minimum protected monthly income level. currently, that level is Sl,295 plus shelter costs over S389, up to no morc than a total of S1976. The following chart will enable you to compute your own protected monthly income level and your · actual monthly income. The allowances for utility costS are based on a set standard, not on your actual costs. If you pay scparately (tor example, not included in rent) for heatinq and/or cooling and tor other utilities you should enter 52711 in the appropriate space in the chart below. If you do not pay for heating or cooling, but pay tor other utilities (besides telephone service), you should enter~. If you do not have any utility costs, but pay only for telephone service, you should enter 523. For all other shelter items, compute and enter your actual monthly cost, even it you pay on another time basis (tor example, quarterly or annuallyl, If you do not make payments for a specific item, leave that item blank, Honthly Expenditures (1) Utilities (5278, S153, or S23) (l) (2) Rent (2) (3) Hortqage (Principal & Interest) (3) (4) Real Esute Taxes (4) (5) Homeowner's Insurance (5) (6) Condominium Fees (6)+ (7) SUB-TOTAL (add lines 1-6) 17I (8) LESS 5389 (8)- (9) "YOUR SHELTER COSTO" (subtract line 8 from 7) (9) (10) CURRENT FEDERAL BAaE LEVEL (10) 1.295 (11) PLUO "YOUR SHELTER COSTa" AHOUNT (enter amount from line 9)(12) TOTAL - HONTHLY (add line 10 and 11) (11)+ INCOHE ALLOWANCE (12) This total is the minimum monthly lncome amount which you are entitled to as a community spouse, under Federal Medicaid law, If your total is qreater than Sl,976, the Department of Public Welfare will use the figure of Sl,976 because that is tbe maximum allowance under federal law, -2- To determine your actual monthly Income. use the following procedure: Monthlv Income of 3Douse at Home (13) social Security (13) (14) Pension (14) (15) Other (15) (16) Interest or Dividends from protected share of resources ltrom the "Resul ts of Resource Assessment") (16) (17) TOTAL MONTIILY INCOME (17) *Actual rate of return QL reasonable rate of return on a i year C.D" whicbever is larger, Example: if a I-year C.D. currently earns 5\/yr, and you have your standard spousal share of resources invested at a rate of only 3,5\, the Department of Public Welfare will use 5\ as the rate of return or interesr, If the total on line 17 (your income) is less than the total on line 12 (your monthly income allowance) you are permitted to have more monthly income, you may seek additional income of: 51.976 -51.200 5 776 For Ex~mple. if your protected monthly income level (line 12) is: and your total monthly income (line 17) is: If you want to protect additional resources for the purpose of producing this income, your spouse should apply for Medicaid now and request a hearing to establish that you need a greater share of the resources in order to brinq your income up to the protected level. In the alternative, your spouse in the some of his or her income each month, Your for Medicaid or have a hearing to do this. total of your combined incomes is enouQh to allowance. nursing facility can give you spouse does not have to apply You should make sure that the provide the monthly income If you and your spouse choose to supplement your income through a monthly income contribution from your spouse in the nursing facility instead of protecting a greater share of your resources, tben your spouse does not have to apply for Medicaid until the total resources are reduced to approximately your protected sbare (indicated on the Results of Resource Assessment) plus 52,400, REMINDER: The maximum protected amounts for both resources and income for the spouse at home are revised annually. . " . ,., , ' '. -I PAGE ONE OF TWO -.. jlESO'JRCE ASSESSMENT COMPUTATION SHEET I , ..' ;:- Completed By, .', - ;~ ; CODE 01 >ot 02 " -~. ...;-.-,; " \;f - 03 ~;.i'm >;::\~ ':~~1 ,.........,. >".,.,.,-, InstnutJonuzed Spouse. Count) bat~ of Admission. TYPE Cesh on Hand Savino I Account Savinos Account Savinns Account Checklna Account Checklna Account Checklna Account Checklno Account 04 ChrlllmesNacallan Clut >i'\V: ChrlstmallVacallon Cliii' .' ..,,," , .,,~~f. 05 ,~.;~~ ':~:G;j~! :,:t; 06 ~~:):t~ 07 \13~ ~'~,:~~>~;f~ 08 :......:'c 09 r;;i'"rn ""~I~"" <~,.-~ :,.\~ ..~...:t:1:7i :~!I 10 .:~';4l;j 11 ?i~~ ,'~J';;1 12 ,,,:,"';:~-;~!j "<;'i.", ; ---..'-,,' -;,""'<-l',: 13 >;;~~ StackllBonds StockllBonds StoclcllBonds SlockllBandl SlackllBands Trust Fund Trull Fund Burlal R..arve Auria' R..erve Burlal Plols Burlal Plols Ufa tnluranca Ufe Inlurance Ute Inlurance Ut. Inlurance Uf. Inlurance Non-R.sldent PllIn..... Motor Vehicle Motor Vehicle Other VehiCle I Other Vehlcl. I Other Vehicle I N.,;;\tJ ,:,.."...;.~ <;-'-"';c ~_;~:1tJ ::t':~;V Cert. of Denosit Cert. of Deoolit Cert. of Deoaslt Cert. of Denosit Cert. of Deoolit Cert. of DeDollt '..:, . '.' ,;,~ JJ l;.rv#) ~ l m~tM 1{_,~~ Glrr~<J.ffi J f/7:>1 /10 A(l/lI'l' t [111/1 f:~;,,~:~ 11)' If - 31'/1 Counteble Vilified? Amount Ves No S S S S LOCATION OF RESOURCE - COMMENTS - f.'NlI.;U l,^,'PorTlJ.. "U~).p. 'leOI ^ .. - rni """- ....,-n YIl ~ 1 .J(J ;;;;. . r. '"".~ -f. lit i{."",,, I), lJ~h/t-511 /'Y'''' y t' N l 1\<vJ-.. -'I.. ~ :}I' .. oJ Y \! Y ~~, SUII/: .... SJ~f.., S 7iJflJYF L.- S....JJ-J/J,_ S S S S S S S S S IIlTlM1cabl.? VES NO S IIlTlM1cabla? VES NO S I exemnt? VES NO S I exemol? YES NO S . . 1,}-\/11'#o., r rv F.ce S I Ii ' " Face S Face S F.ce S F.ce S Calh S.J.~W'. S II ,.,/ Cash S S , Calh S S I Calh S S , Calh S S I S I / ..... V '71\10 S J I L-- I ves NO S i . c, . "lOa 1I,\('/ \IV "'TI!'..",ol? -rei'emnl? ., '('1/" '" j I"", /' .. I MtCl ";lldt:rll'-,1r)O~ 1 I;) I ~ 0 I iO"':UUU ....... -- .",., " ..,- " SUB TOTAl... VERIFIED COUNTABLE RESOURCES -> IS .~ //U.f'f'- 'I ^/I'" N~.' ".... .. ... PAGE TWO OF TWO TYPE nuilies Mnuitles nuillas oeATION OF RESOURCE - COMMENTS Countable Verified' Amounl Yas No 15 Savtn a Bonda Savtn a BondI Savin Bonds Savtn a Bonds Savin Bonds ;, Savtn s BondI 16 Mutual Funda Mutual Funda Mutual Funds Mutual Funds 17 ole Pro letorahl ": Joint Partnershi 18 U e Interest "~','" ';:. 19 Other ".;1 Other " Other ,.;..., " Other ", . ,''t, '-~-",; ~!i,r~":",,~,,...~;;;_'>:~~,i . : ,~.:~x~r~'>~;::\.2L:: .:. "'. . . " """ " l C ., > SU"TOTAI "-:"i' :;",,,:':n"..', "", .... ft - ,~d' > ' t!l' ~...' 1~ .-....." " ,~... .,. ....., 't;j '1A,t:fJt..,t t,'J;tot.w"'-~' t~,.< ..~~ ~g(t!;,~,!.,i:'",ht:;.?, bf,: SUB-TOT "J" ..>ol:'>1_:..-~.,.!1...'-~ "f4' . ,',. f 't. ~ <1'1,10....,;(,]:(,.41,' .,,_~, ::"<v ;.";'"~rtt:':-(~'~''!..t.'~\4 ~.l .,IJI' ~"'r,.:.;t :...f'n,.r~".(~ .y:..~ < . ~ '><-'.w~~t...il.' "'~'1'~'~f;{ y .$' .,,~. . ..... "',."'''-~~~'''''f:'''Uoe '>:""f.~'j+ """< l" ,,"!.,. : ~'.:;~rr-" '\~i.<,;~-: ,.1"-':-..~ ,~,~':~":'" '-..;.>H VERIFIED COUNTABLE RESOURCES . two s ..,;;.!}'....,4'" ,,4" ..,.... 1".,"'.L~.f_;.' .... 'I' s VERIFIED COUNTABLE RESOURCES r L . on. ...c-. .!,;, .,,' .._j ,;... ,.;.,~':'"", v'~r;'./'~~~""" ,"<~'/ .''';;< > ,'" : -., "'~. TOTAL COUNTABLE RESOURCES -> S L ." .., '.'. \t~,.:'~~~~'~:r':'~;,\,;~',;,:' .; ; ,G.,...; :x,:...~'};u.'_"'; DIVIDE BY 2 . SPOUSAl. SHARE -> S L .~ . --,. ~, '. ",' ..f".....~. . ':H!.-Ql~ ;~;:~i\~'~_;c~S'fl~'-.-, ~~fJj.;1},:'~_< ;t:{~~;:-::i, ",,,",'" - ,~.h., ',' ,.,.' .'w"', :;;.r~.,f'" /i,.",,'f<:>.......~-':;.-!. ,,,:,,,,,:~: I s~~:~~:J"";:r;A~' , , .. ~r::::~<~ -1t-:~)/ ..:~\:~#:.:: ~'/-'. - '. ':'~~;., J; .;: -,~., ';"" ;;~);:~~,..:::\;~: . .' ., ~ . :'..,>:;'t-:" ...... ~~;...:;-.-,:;i~,:~,.: .~~.~,:-g.."c. ' ':'l~~r::~:; .,._<c'" '-"~" . . -,. - , V.rlf1caUonlDocum.nlatlon Needed' .' ('~ F.~L~Q-'?!~r-:';1.,}iNi~ 97-6045 r~ ",'....,. 'r',' ,'\.J o. vr ...................,.... It If' qa 1~"'.O I',\ \:~'.,..,lma B. Senior, an I .' ,.Jncapacitated person by ""," , U:,;,;IWilliam G. Reese, Permanent Cv,.,,:,:c,:::,";,' '. JllenaJ:Y, Guardwn" , . . . . , . . . . rc.1oi ,Jtl.' 1 ..,. ,... .. .... ." .~l~~AliHI.... VI, , Elmer Senior .... .... . ... .. ./................ Defendant ................................. ................................ 'J Praecipe for ................... I . .. .. . Flied ..........,.,'"..,.. t 9. . , , ................................ Attorney for Plaintiff , " ~- -~--:;..~- ,'- -, J-"_ ;.. . WILLIAM R. BUNT ATTORNEY AT LAW P. O. Box 338 1011 SOUTH CARLISLE STRUT NEW BLOOMFIELD. PA 17018 TEL \717) 5U.8195 FAX 717) nZ-7U1 WILUAM R. BuNT, Eao. CHRYITAL L. PRDIIIR, Ela. January 5, 199B Mr, Lawrence E. Welker, Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 RE: Senior v, Senior Action in Equity No. 97-6045 Equity Dear Mr. Welker: Enclosed herein please find a Praecipe asking that you withdraw the above captioned action. Very truly yours, tr William R. Bunt WRS/ams Ene. CC: Mr. William Reese Robert G. Radebach, Esquire .. >- ". r-. Cr' C": L. .' ,'. i'. .. '..,- UJ~'-~ - (.) ~.-~ ~_?(~ ;:c u .:::. '1....-- "- ~ ~~ ~L , \D .: ./J L ~' I .J _. Uj" iLZ ~t~. -- ._J'LJ M' .S.:.. ,- -, I: CO :3 (.; C1' U