HomeMy WebLinkAbout96-00352
LAW OFFICES
JOHNSON. DUFFIE, STEWART & WEIDNER
TeI~rhono (.17) 16t-4540
Telocopler (7171 16t.]015
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P. 0, Box t09
Lemoyno, ronnoytvanla 17043.0109
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
NO. 96 :35:t ORPHANS' COURT
ESTATE OF EVELYN M. MILLER
PETITION PURSUANT TO SECTION 5511 OF THE PROBATE, ESTATES AND
FIDUCIARY CODE TO ADJUDICATE EVELYN M. MILLER TO BE INCAPACITATED
AND TO APPOINT A GUARDIAN FOR HER PERSON AND HER ESTATE
PRELIMINARY DECREE
AND NOW. this 1',1 day of I ' ,/ . ; . 1996, upDn consideratiDn of thB
Bnnexed PBtition. IT IS ORDERED AND DECREED th~t a hearing on this mattBr is set for thB <' ( day
of ' , , ,1996, in Court RODm No. " Bt ',; .'i o'clock I. .M. and that
a CitatiDn be issued to Evelyn M. Miller commanding her to show cause why she cBnnot appeBr Bt the
BforementiDned hBaring pursuant to the Petition of Kathryn E. Zink tD hBve Evelyn M, Miller adjudicatBd
an incBpacitBted person and to have plenary guardians BPpointed for her persDn Bnd hBr Bstate. NDtice
of the hearing shall be given to Evelyn M. Miller by counsel for the Petitioner in accordance with 20 P.S.
~ 5511(a) nDt less than twenty (20) days prior to the hBaring.
BY THE COURT: /
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099999-OOO341Aprilll. 1996IRIIWIPARl520n
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
NO. 96 ORPHANS'COURT
ESTATE OF EVELYN M. MILLER
PETITION PURSUANT TO SECTION 5511 OF THE PROBATE, ESTATES AND
FIDUCIARY CODE TO ADJUDICATE EVELYN M. MILLER TO BE INCAPACITATED
AND TO APPOINT A GUARDIAN FOR HER PERSON AND HER ESTATE
TO THE HONORABLE, THE JUDGES OF SAID COURT:
The Petition of Kathryn E. Zink respectfully represents thBt:
1. Your PetitiDner, KBthryn E. Zink. is an adult individual WhOSB address is 406 Herman
Avenue, LemDynB, Pennsylvania, 17043.
2. Evelyn M. Miller is an eighty-five (85) year old incapacitated female, born on June 1, 1910.
3. Evelyn M. Miller resides at The MeadDws Living Center, 4837 EBSt Trindle RDBd,
Mechanicsburg, Pennsylvania, 17055. Prior to her April 9, 1996 entrance tD ThB MBadows Living CentBr,
ShB resided at 2164 Market StreBt, Camp Hill, CumberlBnd County, Pennsylvania.
4. Evelyn M. Miller suffers frDm progressive deterioration Df her mental and physical
capabilities. Her mental stBte has deteriorated to the point where her heBlth and safety Bre endangered.
ShB is una biB tD prBpare fODd for hBrself, attBnd to hBr personal hygiene, manage her Dwn financial affairs
Dr to make decisions concBrning her person. ShB has periDds Df confusion and a short term mBmDry
deficit. Her mental state continues to detBriorate.
099999-OOO34/Aprilll, 19961RHW/PARlS2023
5. Evelyn M. Miller hBS diabetes mellitus, She CBn draw up end inject her own insulin, but she
cannDt mBnBge hBr Dral medication dosages.
6. JDhn M. Sullivan, M.D., Evelyn M, Miller's treating physiclBn. has Bdvised that she is
suffering from the effBcts of senility Bnd cannot manage her own Bffairs Bnd has advised thBt she reside
in a setting with around-the-clock supervision for her safety and welfare.
7. At her most recent evaluatiDn by Dr. Sullivan, on February 27, 1996, EVBlyn M. Miller was
nDt oriented to time or place.
8. Evelyn M. Miller is an incapacitated adult person whose ability to receive and evaluate
informatiDn effectively Bnd cDmmunicate decisions abDut her care Bnd needs is impaired to such a
significant extent that she is totally unable to manage her financial reSDurces or meet essential
requirements for her physical health and safety.
9. To bBtter provide for her safety, Evelyn M. Miller recently entered The MBadDws Living
Center.
10. Evelyn M. Miller is widDwed. She has threB (3) living childrBn; Kathryn E. Zink, residing Bt
406 Herman AvenuB, LemDyne, Pennsylvania. 17043; CharlBs W. Miller, residing at 2164 MBrket Street,
Camp Hill, PennsylvBnia. 17011; Bnd Richard F. Miller. residing at 106 Rollo CDurt. Mechanicsburg,
Pennsylvania, 17055. A SDn. James R. Miller, is deceased. Evelyn M. Miller has five (5) living siblings:
Mrs. CBrol Rose. 42 Half Mile Drive, Gardners. Pennsylvania. 17324; Mrs. Helen HBller. 1149 Myerstown
Road. GardnBrs. PennsylvBnia, 17324; Mr. AlbBrt RDse. 527 West PhilBdelphiB Street. YDrk. PBnnsylvania,
17404; Mrs. GIBdys MDlyan. 1532 Kemble Street. Utica. New YDrk. 13501; and Mrs. Dorothy Cline, 142
North Stratton StreBt. GBttysburg. Pennsylvania. 17325.
11. Evelyn M. Miller has executed a Will. dated August 11. 1980. directing thBt all Df her estate,
in equal shares. be distributed to Charles W. Miller. Richard F. Miller and Kathryn E. Zink. Bnd the issue
of James R. Miller.
,
099999-OOO34/ApriI26. 19961RIIW/PARl52023
12. Your PetltlDner, Kathryn E. Zink, has nD interast adverse to Evelyn M. Miller.
13. EVBlyn M. MiIIBr's SDurce of income is $692.00 per mDnth SDcial Security Bnd BpprDximBtely
$110.00 per mDnth from Interest and dividends frDm variDus Investments. It is beliBvBd that Evelyn M.
MiIIBr has Bssets of apprDximately $240,000.00, including her real BstatB at 2164 Bnd 2166 Market
StrBet, CBmp Hill, PennsylvBnia.
14. EVBlyn M. Miller becBuse of mental inCBPBCity, is unable to mBnBge her property, is liable
to disslpBte it Dr. bBcDme the victim of designing persDns, and lacks sufflclBnt capacity to makB or
communicBte rBspDnsible decisiDns concerning her persDn, and to Bdequately Bttend to her own safBty
Bnd welfare.
15. The prDposed guardian of the person and estate of Evelyn M, Miller Is KBthryn E. Zink.
Attached hereto BS Exhibit "A" is an Bffidavit by Kathryn E. Zink showing her willingness to BCt BS
guardian of the estate Df the namBd IncDmpBtent. AttachBd hBreto as Exhibit "B" is an affidavit by
Charles W. MiIIBr and Richard F. Miller, consenting tD the appointmBnt of Kathryn E. Zink as guardian Df
thB person and estBte of Evelyn M. Miller.
WHEREFORE. your PetitiDnBr prBYS that B citBtiDn bB issued to Kathryn E. Zlnk to ShDW CBuse why
Evelyn M. MiIIBr ShDUld nDt be adjudged to be IncapacitBted and a plenary guardian of hBr estate Bnd her
person bB Bppolnted.
JOHNSON. DUFFIE. STEWART & WEIDNER
Date:
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By:
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Attorney 1.0. ND, 56113
Mark C. Duffie
Attorney I,D. ND. 75906
301 MarkBt Street
P. O. Box 109
LBmoyne, PA 17043-0109
(717) 761-4540
Attorney for Kathryn E. Zink
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099999.ooo341Aprilll. I\l96IRHW/PARl52023
YERIFICATION
I, KATHRYN E. ZINK, verify that the statemBnts madB In the fDregDing are true and CDrrect to the
best of my knowledge. infDrmation and beliBf. I understand that false stetemBnts hBrBin are made subject
to the penBltles of 18 Pa. C.S. t 4904 relating tD unSWDrn falsification to authorities.
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K THRYN E. INK
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LN RE:
I N Till:: COUll'I' OF COMMON PI.EI\S OF
CUMBI,;RI.I\ND COUNTY. PI':NNSYI,v/\NI/\
ES'l'/\TE OF EVELYN M. MIl.I.lm
/\N I\LLEGED INC/\P/\CLT/\TED
PERSON
ORI'II/\NS' COURT III V L S lON
NO. 352 ORPII/\NS' 1996
C L'I'/\'1'I0N
WE COMMI\ND. you that laying aside all business and excuses
whatsoever. you be and appear in your proper person before the lion-
orable Judges of the Common Pleas Court. Orphans' Court Division
at a session of the said Court there to be held. for the County of
Cumberland to show cause why she cannot appear at the aforementioned
hearing pursuant to the Petition of Kathryn E. Zink to have EVelyn
M. Miller adjudicated an incapacitated person and to have plenary
guardians appointed for her person and her estate. Notice of the
hearing shall be given to Evelyn M. Miller by counsel for the Peti-
tioner in accordance with 20 P.S.S 551l (a) not less than twenty (20)
days prior to the hearing.
witness my hand and official seal of office at Carlisle. Penns.
ylvania. this 2nd day of May. 1996.
"
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IN RE:
ESTATE OF
EVELYN M, MILLER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
96-352 ORPHANS' COURT
ORDER OF COURT
AND NOW, this 28th day of May, 1996, Rebecca R. Hughes, Esquire, Is
appointed to represent Evelyn M, Miller.
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By the Cotjrt,
.w. <I.:
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Edgar B, BaYle~ J,
Ralph H, Wright, Jr., Esquire
Rebecca R. Hughes, Esquire
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LA \V OFFICI'S
.JOHNSON, DUFFIE, STEWART & WEIDNER
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L<moyn., r.nlllylv.nl. 170U.oI09
Tdcphonc (717) 761-4540
Td",'pl,r (717) 761.)015
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IN RE:
ESTATE OF EVELYN M. MILLER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96.$ ORPHANS' COURT
.......1.
IMPORTANT NOTICE
CITATION WITH NOTICE
A petitiDn has been filed with this Court to have you declared an Incapacitated Person. If the Court
finds you to be an Incapacitated Person. YDur rights will be affected, including our right to manage money
and property and to make decisions. A copy Df the petitiDn which has bBen filed by Kathryn E, Zink, is
attached.
You are hereby Drdered to appear at a hearing to be held in Court Room ND, 2, Cumberland County
Courthouse, Carlisle, Pennsylvania, on June 3, 1996, at 3:30 P,M. to tell the Court why it should nDt find
you to be an Incapacitated Person and appoint a Guardian to act on your behalf.
To be an Incapacitated Person means that YDU are not Bble tD recBive and effectively
evaluate Information and communicate decisions and that you are unable to manBge your
mDney and/or other property, Dr to make necessary decisions about where you will live,
what medical care you will get, or how your money will be spent.
At the hearing, you have the right to appear, to be represented by an BttDrney, and
to requBst a jury trial. If you do not have an attornBY, you have the right to requBst the
Court to appoint an attorney to represent you and to have the attorney's fees paid for you
if you cannot afford to pay them yourself. You alsD have the right tD request that the Court
DrdBr that an independent evaluation be conducted as to your alleged incapacity,
If the Court decides that you are an Incapacitated PersDn, the Court may appDint a
Guardian for you, based on the nature of any condition or disability and your capacity to
make and communicate decisions, The GUBrdian will be of your persDn and/Dr your mDney
and Dther propBrty and will have either limited or full pDwers to act for you,
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1I0l<ACL A IOIlN'ON
IrKI< Y I< Dllml
I<ICIIAI<D W. 'lI.WAI<1
C I<OY WIIDNLI<, IR
WMIIND G ~\),LR'
JOHNSON, DUFFIE, STEWART & WEIDNER
30t MARKET STREET
p, O. BOX t09
LEMOYNE, PENNSYLVANIA t7043.0109
IAML' A IOIlN'ON
DAVID W. DrI.IICI
I<All'lI II WI<IGIH, II<
DAVID I LANZA
IO'U'1I \. IIIICIIIN'"
MARK C Dun II.
TELEI'II0NE 717.76t,4S40
FACSIMILE 717.761.JOI5
MBY 24, 1996
The HDnorable Edgar B. BByley
CumberlBnd CDunty CourthDuse
One CourthDuse Square
CBrlisle, PA 17013-3387
Re: Estate of Evelyn M. Miller
No. 96-352 Orphans' Court
Dear Judge Bayley:
We filed a Petition on bBhalf of Kathryn E. Zink tD adjudicate the abDvB-nBmBd person
an incapBcitBted persDn and to appoint guardians for her estate Bnd her person.
YDU have scheduled a hearing for June 3, 1996, at 2:30 P.M.. in CDurt RDom ND. 2,
in this matter, Pursuant to the requirements of thB Guardianship Act, as rBvised in 1992,
please be advised that to my knowledge no CDunsBI has been retained by, or on bBhalf Df, the
Blleged incBpacitated person. 20 Pa.C.S. ~ 5511 la).
Very truly yours,
JOHNSON, DUFFIE, STEWART & WEIDNER
~d
Ralph H. Wright, Jr.
RHW:par:53497
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IN RE: ESTATE OF EVELYN
M. MILLER
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
: NO. 96-352
ORPHANS' COURT DIVISION
DEPOSITION OF: JOHN M. SULLIVAN, M.D.
TAKEN BY: PETITIONER
BEFORE: TAMMY J. BAKER, REPORTER
NOTARY PUBLIC
DATE: MAY 29, 1996, 2:37 P.M.
PLACE: 1001 SOUTH MARKET STREET
MECHANICSBURG, PENNSYLVANIA
APPEARANCES:
JOHNSON, DUFFIE, STEWART & WEIDNER
BY: RALPH H. WRIGHT, JR., ESQUIRE
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ORIGINAL
Hughes, 7nErighf, 'Foltz &-' JVatde :Reporting Se~iu, {lnc.
115 PINE STREET' HARRISBURG, PA 17'0'
H,,"sburg 717.232,5644 Fa, 717,232,9637 laneaS!or 717,393.5101
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NAME
JOHN M. SULLIVAN, M.D.
BY: MR. WRIGHT
WITNESSES
DIRECT CROSS REDIRECT RECROSS
J
EXHIBITS
SULLIVAN DEPOSITION EXHIBIT NO.
1. LETTER DATED JANUARY 22, 1996
PRODUCED AND MARKED
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STIPULATION
It is hereby stipulated by and between counsel for
the respective parties that reading, signing, sealing,
certification and filing are hereby waived.
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JOHN M. SULLIVAN, M.D., called as a witness, being
duly sworn, testified as follows:
DIRECT EXAMINATION
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BY MR. WRIGHT:
Q For the record my name is a Ralph H. Wright,
Junior, and I represent Kathryn E. zink, the daughter of
Evelyn M. Miller.
We have petitioned the court on behalf of Kathryn
E. zink to have her appointed guardian of the estate and
person of Evelyn M. Miller.
I'm going to ask you some questions which are
being taken under oath and will be placed in a transcript
which will be submitted to the court at a hearing on June
Jrd, 1996, before judge Bayley.
Could you state your name for the record?
A John M. SUllivan.
Q And you're a licensed physician in Pennsylvania?
A Yes.
Q How long have you been licensed in pennsylvania
to practice medicine?
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A 18 years.
Q Do you have a specialty or a concentration?
A We do family practice and we also do allergy and
environmental medicine.
Q okay. Is your practice concentrated to any
degree in the area of geriatrics?
A I wouldn't say concentrated, but we do have a
fair share.
Q Okay. Could you give me an approximate
percentage of geriatric patients in your practice?
A Can I ask how you define the word geriatric?
Q Let's say age 65 or over?
A okay. That constitutes about 35 percent of my
practice, maybe 30.
Q Okay. And Evelyn M. Miller has been a patient of
yours, has she not?
A Yes.
Q How long to your recollection has she been your
patient?
A I think that I got her as a patient somewhere
around 1993.
Q And could you give us a brief synopsis of her
medical history, anything remarkable or anything of note
which you recall about her?
A I do know that she was suffering from several
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conditions, one of which was diabetes, another was high
blood pressure and a third was poor circulation.
Q During the time that Evelyn Miller has been under
your care, how frequently have you seen her for exam or
evaluation?
A I can give you an exact answer when I get the
other half of her chart.
Q Okay.
A My recollection is it was about every two months
or so.
Q Okay. We can return to that.
Have you been Mrs. Miller's primary care
physician?
A Yes.
Q How would you compare Mrs. Miller's status the
last time that you saw her with her status the preceding
year?
A My recollection is that her physical complaints
had been under fairly good control, but her mental
capabilities were deteriorating.
Q Okay. I guess the dates for her last visit
probably are going to be contained in the other part of the
record that they're locating?
A Yes.
Q Do you recall when Mrs. Miller was last seen by
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yourself?
A Not off the top of my head, but I could look it
up in the computer if you need that, the date of the last
visit.
;.
I'll keep a list of anything else you want me to
look up.
Q Okay. It occurs to me that her records are --
probably her most recent records were forwarded, I believe,
to The Meadows?
A That may be.
(Discussion held off the record.)
THE WITNESS: Yes, the records were forwarded to
Dr. Torchia.
BY MR. WRIGHT:
Q Dr. Torchia is the physician who will be
following Mrs. Miller at The MeadowS, is that correct?
A At the nursing home, yes.
Her last visit was 2/27/96.
Q What was Mrs. Miller's mental status at her last
visit?
A I have a note here that she is in the moderate
stages of senility, although physically she was okay.
Q Was she oriented at that visit?
A No.
Q How did Mrs. Miller respond to verbal
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communication directed to her?
A By recollection her responses were exceedingly
limited. Sometimes she just answered with a grunt.
sometimes she had an answer that was a very superficial
answer.
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On several occasions over the last times I have
made notes about she is becoming more forgetful, she's not
taking her medications. She's been found incontinent of
urine and stool.
Her overall hygiene was deteriorating because she
was just not in a capacity to take care of herself anymore,
a mental capacity.
Q Okay. Would you please mark that for
identification.
(Letter dated January 22, 1996 produced and
marked Sullivan Exhibit No.1.)
BY MR. WRIGHT:
Q Dr. sullivan, I'm handing you what has been
marked as Exhibit 1. Do you recognize this document?
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Yes.
And that is your signature at the bottom
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right-hand corner?
A Yes, it is.
Q Can you briefly state why you prepared that
particular document and explain to me what it is?
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A This was a letter dictated at the request of the
daughter in her seeking custodial care over the person and
the finances of Evelyn Miller.
Q Okay. And the daughter was Kathryn Zink?
A Yes. She called and asked me to prepare such a
letter.
Q You make a statement in that letter that Mrs.
Miller has shown progressive deterioration of both physical
and mental capabilities and the deterioration has reached
the point where she's no longer capable of living by herself
safely and of taking care of her own affairs.
A That's correct.
Q Okay. And you did recommend that she be provided
with a power of attorney?
A Yes.
Q And the rational for that, if you would perhaps
elaborate?
A Well, I don't think that she was in a position to
be making significant decisions on her own.
Q I see. Dr. Sullivan, I'm going to hand you a
copy of Section 5501 of Title 20 of the Pennsylvania
Consolidated Statutes which is Pennsylvania's statutory
definition of an incapacitated person and I'll ask you to
review that if you would?
A Okay.
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Q Based on your professional judgment and your
examination and familiarity with her, do you believe that to
a reasonable degree of medical certainty Evelyn M. Miller is
an incapacitated person within the meaning of the definition
you've just read?
A Yes, I would.
Q In the letter which was marked Exhibit 1, if one
of the requirements for Mrs. Miller to give a valid power of
attorney were that she would need to fully comprehend the
nature of what she was doing and the scope of authority that
she were to give someone, do you, in your opinion, believe
that Mrs. Miller could give a valid power of attorney?
A She would not comprehend what she was doing.
Q Okay. In your opinion is there any plausible
alternative to guardianship for a person in Mrs. Miller's
mental and physical condition?
A No, because even if she went into total placement
somewhere, they would still want the establishment to become
power of attorney. Right now it's a question of whether
it's going to be a family member to be the power of
attorney.
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Eventually someone is going to have to receive
power of attorney. Whether that's a family member or the
establishment that she might go to, I don't see an
alternative to that.
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I hereby certify that the proceedings and evidence
are contained fully and accurately in the notes taken by me
on the within proceedings, and that this copy is a correct
transcript of the same.
NOTARIAL SEAL
TAMMY J, spans, Nl1.ry f'1;bhc
L...r Swaim lop, Oauphin Clun!y, P..
My Co~missi," ~'p"'s No.. 9, 1995
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Tammy J. Bake I Reporter
Notary Public
Date: 5/30/96
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JOHN M. SULLIVAN. M.D.
BoUTIU-OINT P"OrE8"IONAI~ OrncEN
1001 SoUTUltlAHKET STREET
MECIJANICSnURO. PA 170G5
1717. 697,50110
January 22. 1996
To \\ban It May Concern:
RE: EVELYN MILLER
Evelyn Miller has been a patient of mine since 1991. Since that time
she has shown progressive deterioration of both physical and mental
capabilities. It has reached the point where she is no longer capable
of living by herself safely and of taking care of her own affairs. It
is recommended that she be provided with a power of attorney.
Thank you very llUch.
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~ EXHIBIT
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LAW OHICE5
JOHNSON, DUFFIE, STEWART fI WEIDNER
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30t Market Street
p:o, 801109
Lemoyne. Penn.yl..nl. 17043.0109
Telephone (713) 76t .4.':40
Telecopl" (717) 761.3015
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
NO. 96.352 ORPHANS' COURT
ESTATE OF EVELYN M. MILLER
PETITION PURSUANT TO SECTION 5511 OF THE PROBATE. ESTATES AND
FIDUCIARIES CODE TO ADJUDICATE EVELYN M. MILLER TO BE INCAPACITATED
AND TO APPOINT CO.GUARDIANS FOR HER PERSON AND HER ESTATE
FINAL DECREE
AND NOW. this 1/ day of O~/.:J , 1997, upon consideration of the
Petition of CHARLES W. MillER and RICHARD F. MillER, and following a hearing, IT IS ORDERED
AND DECREED that Evelyn M, Miller is adjudicated an incapacitated person and Charles W, Miller and
Richard F, Miller are hereby appointed plenary co-guardians of Evelyn M, Miller's estate, Charles W,
Miller and Richard F, Miller are authorized to make future payments of both income and principal for her
care and maintenance as may be necessary; Charles W, Miller and Richard F, Miller are hereby permitted
to sell, convey. lease or transfer any real property which Evelyn M, Miller may own, including that
located at 2164 Market Street and 2166 Market Street, Camp Hill, Cumberland County, Pennsylvania,
and any other personal or real property that Evelyn M, Miller may own as may be necessary for her
future care and maintenance, however, the proceeds from the sale of such real property shall only be
used for her future care and maintenance alter all other principal and income from the estate has first
been exhausted; and no bond shall be required; and Charles W, Miller and Richard F. Miller are hereby
appointed co-guardians of Evelyn M, Miller's person and are hereby authorized to make decisions on
behalf of Evelyn M. Miller concerning her medical care treatment, including admission to nursing homes
and hospitals and other health care facilities as well as to consent to medical treatment.
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099999-000J4fSopfombor 23, 1997fRHWfPAflll01171
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
NO. 96-352 ORPHANS' COURT
ESTATE OF EVELYN M. MILLER
PETITION PURSUANT TO SECTION 5511 OF THE PROBATE, ESTATES AND
FIDUCIARIES CODE TO ADJUDICATE EVELYN M. MILLER TO BE INCAPACITATED
AND TO APPOINT CO-GUARDIANS FOR HER PERSON AND HER ESTATE
TO THE HONORABLE. THE JUDGES OF SAID COURT:
The Petition of Charles W. Miller and Richard F, Miller respectfully represents that:
1. Your Petitioner. Charles W. Miller, is an adult individual whose address is 2164 Market
Street. Camp Hill. Pennsylvania, 17011,
2. Your Petitioner, Richard F. Miller, is an adult individual whose address is 106 Rollo Court,
Mechanicsburg, Pennsylvania, 17055,
3. Kathryn E. Zink, an adult individual who resided at 406 Herman Avenue, LemDyne,
Pennsylvania, 17043, being the daughter of Evelyn M, Miller, filed on April 26, 1996, a PetitiDn
Pursuant to SectiDn 5511 of the Probate, Estates and Fiduciaries Code to Adjudicate Evelyn M. Miller to
be Incapacitated and to Appoint a Guardian for her Person and her Estate.
09999g OD034IS."fnmhur 23. 1997/flItWiI'AllIl01171
4, Your Honorable Court, by Preliminary Decree, dated May 1, 1996, ordered that a hearing
Dn the matter of the Petitien Dr Kathryn E, Zink te have Evelyn M, Miller adjudicated an incapacitated
person and te have plenary guardians appointed for her person and her estate be set for June 3, 1996,
in Court Room No, 2, at 3:30 P,M,
5. Kathryn E. Zink died suddenly Wednesday, May 29, 1996, and a general continuance
was requested regarding the aforementioned Petition to have Evelyn M, Miler adjudicated an
incapacitated person and to have plenary guardians appoinled for her person and her estate, until
another individual willing to serve as such guardian was identified, and an appropriate Petition was filed.
6. Your PetitiDners, Charles W, Miller and Richard F. Miller, desire to serve jointly as Co-
Guardians for Evelyn M. Miller's Estate and person in the place of their deceased sister, Kathryn E. Zink.
7. Evelyn M. Miller is an eighty-seven (871 year old incapacitated female, born on June 1,
1910.
8, Evelyn M. Miller resides at the Church of God Home, Inc., 801 North Hanover Street,
Carlisle, Pennsylvania, 17013, She was admitted to the Church Df GDd Home, Inc, on December 16,
1996 from Manor Care. She was admitted to Manor Care in October, 1996, following her discharge
frDm the Renova Center, 4950 Wilson Lane, Mechanicsburg, Pennsylvania, where she was admitted
briefly following a hospitalization at Holy Spirit Hospital, Camp Hill, Pennsylvania, for removal of a
gangrenous toe. Prior to her admission to Holy Spirit Hospital, Evelyn M, Miller resided at the Meadows
Living Center, 4837 East Trindle Road, Mechanicsburg (Hampden Township), Pennsylvania, to which
she was initially admitted on April 9, 1996. Mrs, Miller's stay at the Meadows Living Center was
interrupted by an admission to Polyclinic Medical Center.
9, Evelyn M, Miller suffers from progressive deterioratiDn of her mental and physical
capabilities, Her mental state has deteriDrated to the pDint where her health and safety are endangered.
She is unable to prepare food for herself, attend to her personal hygiene, manage her own financial
affairs or to make decisions concerning her person, She has periods Df confusion and short-term
-2-
09999000034/50111001"'" 23, 1997/R1IW/PAR/101171
momory doficit. She occasionally fails to rccognize her son, Charlos W, Miller, by name and does nDt
rocognizc othcr individuals by name, She is not oriented to place or time, Hcr mcntal state continues to
detcriDratc,
10, Evelyn M, Miller has insulin dependent diabctes mellitus and diabetes-related neuropathy.
11. John M, Sullivan, M.D" then Evelyn M, Miller's treating physician advised in a deposition
taken May 29, 1996, that at her most recent cvaluation by him on February 27, 1996, Evelyn M, Miller
was not oriented to time or place, that she was suffering from the effects of senility and could not
manage her own affairs and further advised that she reside in a setting with around-the-clock
supervision fDr her safety and welfare.
12. H. Robert Davis, M,D, Evelyn M, Miller's current attending physician has advised that she
is quite confused and that senile dementia is one of her current diagnDses.
13. Evelyn Miller was found unresponsive at the Church of God Home on June 18, 1997, and
was admitted tD Carlisle Hospital for evaluatiDn. She was discharged from Carlisle HDspital, June 23,
1997, with a discharge diagnosis of organic brain syndrDme,
14, Evelyn M. Miller is an incapacitated adult person whose ability to receive and evaluate
information effectively and communicate decisions about her care and needs is impaired to such a
significant extent that she is totally unable to manage her financial resources or meet essential
requirements for her physical health and safety,
15. Evelyn M, Miller is widowed, She has two (2) living children; Charles W. Miller, residing at
2164 Market Street, Camp Hill, Pennsylvania, 17011; and Richard F. Miller, residing at 106 Rollo Court,
Mechanicsburg, Pennsylvania, 17055. A son, James R, Miller and a daughter, Kathryn E, Zink are
deceased. James R. Miller is survived by two (2) children; Evelyn L. Maze, 285 Bishop Drive, Gainsville,
Florida, 32607, and Susan E. Miller, 535-C, Northeast 21st Lane, Gainsville, Florida, 32609, Kathryn E,
Zink is survived by two (2) sons; Craig A, Turner, RR 1, BDX 193, Elliottsburg, Pennsylvania, 17204,
-3-
.' , ...
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ODDD9DOOOJ4fSlIlIIlIInl..r 23. lD91fRlIWfPARflOl111
and RDnald E. Turner, 7 Rockaway Drive, Camp Hill, Pennsylvania, 17011, Evelyn M. Miller has five (5)
living siblings; Mr, Cnrol Rose, 42 Half Mile Drive, Gardners, Pennsylvania, 17324; Mrs, Helen Heller,
1149 Myerstown Road, Gardners, Pennsylvania, 17324; Mr, Albert Rose, 527 West Philadelphia Street,
York, Pennsylvania, 17404; Mrs, Gladys Molyan, 1532 Kemble Street, Utica, New YDrk, 13501; and
Mrs, Dorothy Cline, 142 North Stratton Street, Gettysburg, Pennsylvania, 17325,
16, Evelyn M. Miller has executed a Will, dated August 11, 1980, directing that all of her
estate, in equal shares, be distributed to Charles W, Miller, Richard F. Miller and Kathryn E, Zink (now
deceased), and the issue of James R, Miller.
17. Your Petitioners, Charles W. Miller and Richard F. Miller, have nD interest adverse to
Evelyn M. Miller.
18, Evelyn M, Miller's source of income is $692.00 per month Social Security and
approximately $110.00 per month from interest and dividends from various investments. It Is believed
that Evelyn M. Miller has assets of approximately $215,000.00, including her real estate at 2164 and
2166 Market Street, Camp Hill, Pennsylvania.
19, Evelyn M. Miller because of mental incapacity, is unable to manage her property, is liable
to dissipate it or, become the victim of designing persons, and lacks sufficient capacity to make Dr
cDmmunlcate responsible decisions concerning her person, and to adequately attend to her own safety
and welfare.
20, The proposed co-guardians of the person and estate of Evelyn M. Miller are Charles W.
Miller and Richard F, Miller. Attached hereto as Exhibit "A" is an affidavit by Charles W. Miller and
Richard F, Miller showing their willingness to act as co-guardians of the estate of the named
incompetent,
-4-
OS9S90.D0034/Soplombor 23, 19971RHW/PAR1101171
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
NO. 96.362 ORPHANS' COURT
ESTATE OF EVELYN M. MILLER
We, CHARLES W. MILLER and RICHARD F. MILLER, hereby agree to accept the appDlntment of
plenary co'guardians of the person and the estate of Evelyn M, Miller, an alleged incapacitated person.
We hereby certify that we have no interest adverse tD the alleged incapacitated person,
~~~.~
CHARLES W. MILLER
~~:(~
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ss.
On this the ~l/4.J.day of !.1tlntr'~lcL-,-,: , 1997, before me the undersigned
officer, personally appeared, CHARLES W. MILLER, known to me lor satisfactorily proven to be) the
perSDn whDse name is subscribed tD the within instrument and acknowledged that he executed the
same fDr the purpDses therein contained.
IN WITNESS WHEREOF, I have hereuntD set my hand and Dfficial seal.
L-}/( ~C1C<J--- ,-I. '''8,(/l'ctuL
NDtary Public
My CommissiDn Expires:
(SEAL)
-7-
I Nolallal SUI
I Hancy L. Blslllne. Nollly Public
I Lamoyne BOil), Cumberland County
, My COIOO1lulon Expllll Nov. 23. 1918
"fW"""- ~"l" Ab(\Claf'on of Notnt
ORIGINAL
~
IN RE: ESTATE OF EVELYN
M. MILLER
IN THE COURT OF COMMON
PLEAS, CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 96-0352
ORPHANS' COURT
DEPOSITION OF: H. ROBERT DAVIS, M.D.
TAKEN BY: PETITIONERS CHARLES AND
RICHARD MILLER
BEFORE: DONNA E. RICHARDS, RPR
NOTARY PUBLIC
DATE: OCTOBER 21, 1997, 8:53 A.M.
PLACE:
CHURCH OF GOD HOME
801 NORTH HANOVER STREET
CARLISLE, PENNSYLVANIA
')
i" "
APPEARANCES:
JOHNSON, DUFFIE, STEWART & WEIDNER
BY: RALPH H. WRIGHT, JR., ESQUIRE
FOR _ PETITIONERS CHARLES AND RICHARD MILLER
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115 PINE STREET' HARRISBURG, PA 17101
HBlllsburg 717,232,5644 FB,717,232,9637 lancBslor 717,393,5101
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WITNESS
NAME
H. ROBERT DAVIS, M.D.
BY MR. WRIGHT
DIRECT
CROSS
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EXHIBITS
DAVIS DEPOSITION EXHIBIT NO. PRODUCED AND MARKED
1. MEANING OF INCAPACITATED PERSON
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STIPULATION
It is hereby stipulated by and between counsel
for the respective parties that reading, signing, sealing,
certification and filing are hereby waived.
H. ROBERT DAVIS, M,D., called as a witness,
being duly sworn, testified as follows:
DIRECT EXAMINATION
BY MR. WRIGHT:
Q Okay. For the record, my name is Ralph H.
Wright, Jr. And I represent Charles W. Miller and Richard
F. Miller, the sons of Evelyn M. Miller.
We've petitioned the court on behalf of Charles
and Richard Miller to have them appointed co-guardians for
the estate and person of Evelyn M. Miller.
I'm going to ask you some questions which will
be taken under oath and will be placed in a transcript,
which will be submitted to the court at a hearing on
October 31st, 1997 before Judge Bailey.
Could you first state your name for the record?
A Yes, it's H. Robert Davis. Do you need my
address? Or what would you like?
Q That might be helpful, if you would be willing
to furnish that.
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A
I practice in Mount Holly Springs, Three
2 Springs Family Practice. The address there is 303 North
3 Baltimore Avenue, Mount Holly Springs, Pennsylvania,
4 17065.
5 And I've practice medicine since 1955, so that
6 I'm going on my 42nd or 43rd year of medicine.
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Q
And Dr. Davis, you are a licensed physician in
8 Pennsylvania?
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A
I'm a licensed physician, and I was board
10 certified up until 1990 in Family Practice.
11
Q
Okay. And do you currently have a specialty or
12 a concentration?
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A
Pardon?
14
Q
Do you currently have a specialty or
15 concentration?
16
A
Family practice, yes.
17
Q
Is your practice concentrated to some degree in
18 the area of geriatrics?
19
A
Yes, it's always been, you know, nursing homes,
20 The Church of God Home I think I've come to for the last
21 35 or 40 years and looked after many of the patients here.
22 And perhaps before that I went to most all of
23 the nursing homes in Carlisle, my partners and I. I have
24 partners now so that we sort of divide up the various
25 nursing homes. And I still come here to The Church of God
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Home as my primary base of geriatric practice.
Q Could you give an approximate percentage of
your practice that is devoted to geriatrics?
A Well, I would say it's probably about 50
percent. Both in the office and then, you know, in
nursing homes,
Q Okay. Evelyn M. Miller has been a patient of
yours, has she not?
A Yes, that's true.
Q Are you Mrs. Miller's primary care physician?
A Yes, I am.
Q How long, to your recollection, has Mrs. Miller
been under your care?
A Well, she was admitted to this home, to The
Church of God Home, 12/16/96. And so that at this point
in time I would say it's about ten months that I've been
her primary care physician.
Q Okay. Could you give us a brief synopsis of
Mrs. Miller's medical history and anything remarkable or
anything of note which you would recall about her?
A Well, when she first was admitted we noted in
our admission note, that was 12/17/96, that she was an 86
year old white female admitted from Manor Home in
Harrisburg.
She was very confused, was in a wheelchair, had
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diabetes mellitus, which was insulin dependant; peripheral
vascular disease, which was concentrated mostly in her leg
areas; and was a thin, pleasant lady, but very confused.
At that particular time, we didnlt note this,
but I'm certain that she didn't even know where she really
was.
Q Okay. What is Mrs. Miller's mental status?
A Well, she continues to be confused. In fact,
since the time she's been admitted here she's been in the
Carlisle Hospital two times, one with a mild stroke,
cerebral vascular accident, and has had multiple problems
with her legs with vascular ulcers, stasis ulcers, and had
a large inclusion cyst on her skull that was removed back
in June of '97.
And she did well with that, but she still
exhibits some weakness in her extremities from her stroke.
Q Is there a diagnosis that's pertinent to Mrs.
Miller's mental status?
A Yeah, when she came in she had a diagnosis of
organic brain disease, and we continued that diagnosis.
But one of the older terms, probably even an organic brain
disease, was senile dementia, which she also exhibits
strongly.
And not knowing her before, one might even
consider Alzheimer's Disease with Mrs. Miller, although
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she has had some cerebral vascular problems and perhaps an
organic brain syndrome. And senile dementia might explain
her mental condition the best.
Q What would the prognosis be for those
diagnoses?
A Well, very poor. she's certainly not going to
improve with that diagnoses. She's only going to get more
confused and more mentally incompetent, if that's
possible. Because she certainly is that right now at the
present.
Q During the time Mrs. Miller's been under your
care, how frequently have you seen her for examination or
evaluation?
A Well, it's a requirement of -- of the state,
and I believe of also Medicare, that you see her at least
once a month. But we've seen her more often than that
because of her adm~ssions to the hospital and her other
problems which have come up, such as this cyst on her head
and her open areas on her legs. So that we've seen her
more than one time a month usually.
Q Have you noted any change in her mental status
over the time that she's been under your care?
A I can't say she's anymore confused than she
was, but she was so confused when she came in that, you
know, it's pretty difficult to say that she's more
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confused. Because she was very confused when she came in.
Q When did you last see Mrs. Miller?
A Well, I should look here in my notes. And our
last note was about a week ago. We saw her 10/14/97. And
at that time I made a note, has been very confused, which
is sort of a redundant saying because we've said that
almost every note.
She has also become somewhat combative. When
the nurses try to take care of her, she'll strike at them
and so forth, which doesn't make it too easy sometimes for
them to look after her.
But one thing that was improved were her feet
and her leg sores. We have asked a special nurse from a
hospital to look at her legs for us to help us with
healing them, and they are somewhat improved.
Q Does Mrs. Miller typically respond to
17 communication directed to her?
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A Well, that's difficult really to say. I think
she notices when someone talks to her. She doesn't
understand, I don't believe. But she does notice when you
talk directly to her.
Q Does she communicate with her care givers or
with anyone else that you've observed?
A Well, that's again difficult for you to say.
She does talk, but I don't believe the -- the reality is
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there for Mrs. Miller. And so that it'S very difficult to
say that she understands what you've asked her except that
she knows that you've said something to her, and she may
respond. But it's not too appropriate.
Q Dr. Davis, I'm going to hand you a copy of
section 5501 of Title 20 of pennsylvania consolidated
statutes, which is pennsylvania's statutory definition of
an incapacitated person. And I'll ask you to review that.
And the language is highlighted there.
A Thank you, um-hum. Oh, I certainly would agree
with this statement, that she is so impaired mentally that
she's unable to manage her financial resources or to meet
essential requirements for her physical health and safety.
I certainly would agree with that statement.
Q Then based on your professional judgement and
your examination and your familiarity with Mrs. Miller,
you would believe to a reasonable degree of medical
certainty that she is an incapacitated person within the
meaning of the definition you've just read?
A I would.
Q Based on your experience with Mrs. Miller, can
you suggest any plausible alternative to a guardianship of
her person and her estate?
A Oh, I think the guardian, especially her son,
is the most appropriate way to go. I couldn't think of
10
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2 attorney. But I would believe if they're guardians, they
3 would become her power of attorney also. Is that true?
4 Q At this point a power of attorney wouldn't even
5 be an option.
6 A Okay.
7 Q Because of what we already suspect is her
8 limited capacity.
9 A Okay. All right. So no, I would say that a
10 guardian would be the only way then that I could even
11 think that Mrs. Miller could be handled well, safely and
12 for her own, you know, well being.
13 MR. WRIGHT: And that would conclude all the
14 questions that I would have for you. And I thank you for
15 your time.
16 THE WITNESS: Thank you.
17 (Meaning of an incapacitated person was
18 produced and marked as Davis Deposition Exhibit No.1.)
19 (Whereupon, the deposition was concluded at
20 9:08 a.m.)
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1 COUNTY OF DAUPHIN
SS
2 COMMONWEALTH OF PENNSY1,VANIA
3 I, Donna E. Richards, a Notary Public,
4 authorized to administer oaths within and for the
5 Commonwealth of Pennsylvania, do hereby certify that the
6 foregoing is the testimony of H. Robert Davis, M.D.
7 I further certify that before the taking of
8 said deposition, the witness was duly sworn; that the
9 questions and answers were taken down stenographically by
10 the said Reporter-Notary Public, and afterwards reduced to
11 typewriting under the direction of the said Reporter.
12 I further certify that the said deposition
13 was taken at the time and place specified in the caption
14 sheet hereof.
15 I further certify that I am not a relative
16 or employee or attorney or counsel to any of the parties,
17 or a relative or employee of such attorney or counsel, or
18 financially interested directly or indirectly in this
19 action.
I further certify that the said deposition
20
constitutes a true record of the testimony given by the
21
said witness.
22
IN WITNESS WHEREOF, I have hereunto set my
23
hand this 23rd day of
October, 1997.
. \ ~.,
/>'1'" ( " 1./ '/o! 'r":!
Donna E. Richards, RPR
Notary Public
24
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8:53111 M:9 tV'"
1:11 degree 121 4:17 9:17 familiarity II) 9:10
Carlisle III 1:14
4:23 6:10 dementia 121 6:22 Family III 4:~ 4:11I
-9- cerebral 12) 7:2 4:16
96-0352 (I) 6:11 dependuntlll 6:1 feet 111
1:4 7:1 X:12
9:08(11 11I:20 certain (II 6:5 deposition 111 1:6 female (II 5:23
certainly 1'1 ~:II 10:IN 11I:19 filing(ll 3:4
7:6 II:S 11:12 11:19
-A- 7:9 9:10 9:14 dcvoted (II 5:3 financial III 9:12
a.m121 1:11 11I:20 certainty (II 9:IS diabetes (II Id financially (II II:IS
accident (II 6:11 certification 111 3:4 diagnoses 121 7" first 121 3:~1 5:21
action 111 11:19 certified III 4:10 7;7 follows (II 3:7
address 1213:23 4" certify 1'1 11:5 11:7 diagnosis PI 1>:17 foregoing (II II:n
administer (II 11:4 11:12 11:15 11:1'1 6:19 h:10 forth III X:IO
admission II) 5:22 change III 7:21 difficult 1'1 7:25 frequently I'I 7:1~
admissions (II 7:17 Charles 1'1 1:7 S:IS H:2-l ~:I furnish III 3:25
admitted I') I:IX 3:1~ 3:14 DIRECT[21 2:2
5:14 Church 1'1 1:12 4:20 3:9
5:21 5:23 6:9 -G-
afterwards III 4:25 5:15 directed (II X:17
11:10 co-guardians 111 3:15 geriatric (II 5:1
HUGHES, ALBRIGHT, FOLTZ & NATALE
717-540-0220\717-393-5101
Index I':age I
Multi-I'lIge '"
geriatrics - rcmarkablc
II ROBERT DA VIS M D
,
geriutrics 121 4'IS ~-'~~ ---------.---.. - 'Mrsllll ~,IO ~:1:! perhups III 4:22
5:3 -K- ~: I'J h7 6:17 7:1
given 111 11:20 h;:!~ 7.11 x., peripherllllll 1>:1
knowinglll (1,1.' ,.
givers 111 H:'" S,II> '>.I 1):16
knowslIl 9:3 1),11 1011 person 161 2: 12 ll/,
God 1'1 1:1~ 4:20 multiple 111 tJ.x ~:IX 1):23
4:25 5:15 --- 10:11 111:17
guardian 121 9:24 -1.- pertinent 111 n:17
HUll ladYll1 6:.' -N- petitioned 111 3: 14
guardians 111 )0:2 languuge 111 9.1) namepl 2:.2 III l'ETITIONERSI2II:7
guardianship 111 9:22 large 111 n.D 3:21 I :IX
last 1'1 4:20 t\.... need 111 J.22 physical 111 9:13
-11- SA North 121 I:D 4:~ physician 141 4:7
Hili 1:1, 1:17 leust 111 7:15 Notaryl2ll:lll II:J: .t:9 5:10 5:17
2:3 3:6 3:11 legl21 n" S:D note 161 5:~O 5:22 place 121 1:12 11:13
3:22 11:6 legs 1'1 6:12 7:1'1 10:4 S:4 H:5 placed 111 3:IX
hand 121 '1:5 11:23 H:14 X:7 plausible 11 I 9:22
handled 111 10:11 licensed 121 4:7 noted 121 5:21 7:~1 I'LEASIIII:2
HANOVER 111 I:D 4:9 notcslIl X:3 pleasant 111 6:3
Harrisburglll 5:24 limited III 10:S notice 111 H:2ll point 121 5:15 10:4
head II) 7:IS look 1'1 S:3 X:II nOlices 111 X:19 pOOf) II 7:6
S:14
healing III M:15 now 121 4:24 7:~ possible 111 7:9
health 111 '1:13 looked 11 I 4:21 nurselll S:13 power PI 10:1 10:3
heuringll13:19 nurses II I X:9 10:4
helplIl S:14 -M- nursing 1'14: 19 4:23 practice '81 4:1
helpfuhl13:24 MI41 1:2 3:1J 4:25 5:6 4:2 4:5 4:10
hereby III 3:~ 3:16 5:7 4:16 4:17 5:1
3:4 M.DI'I 1:11 2:3 -0- 5:3
11:5
hereof III 11:14 3:6 11:6 oath 111 3:IS present 1117:10
hereunto III manage 1119:12 oaths 111 11:4 pretty 111 7:25
11:22 M anof) II 5:23 primary PI 5:1
highlighted 11 I 9:9 marked 1212:11 HI:IS observed I'I S:23 5:10 5:17
historyllJ 5:19 may 111 9;3 October PI 1:11 problems III 6:11
Holly 121 4:1 4:3 3:2ll 11:~3 7:1 7:IX
home 161 1:1~ 4:20 meaning PI 2:12 office III 5:5 produced 121
9:1'1 10:17 2:11
5:1 5:14 5:15 medical 121 often 111 7:16 HI:IX
5:23 5:19 oldlll 5:23 professional 11 I
'1:17 9:15
homes 1'1 4:1'1 4:23 Medicare 111 olderlll 6:21 prognosis II I 7:4
4:25 5:6 7:15
hospital PI medicine 121 4:5 once 111 7:16 l'ubliepl 1:10 11:3
6:10
7:17 H:14 4:6 onel'l 6:10 6:21 11:10
meet 111 9:12 6:24 7:2ll S:12
-I- mellitus 111 6:1 open 111 7:19 -Q-
impaired III mentull'l 6:7 I>:IS option 111 10:5 questions PI 3:17
9:11 7:3 7:21 organic I'l n:20 6:21 10:14 11:9
improve 111 7:7 mentally 121 7:X 7"
improved 121 S:12 <):11 ORI'IIANS' III 1:5 -R-
H:15 mighll'l 3:24 6:24 own II) 10:12
incapacitated 1'1 2:12 7:2 RalphI'I 1:17 3:11
9:X 9:18 10:17 mild II) 6:lll -p- REIII 1:1
inclusion II) 6:13 Millerll1l U I:X I'ardon 1114:13 read 111 9:19
incompetent 111 7:H 1:1 X 3:12 3:13 particular III reading 1113:3
indirectly 111 II:IX 3:13 ll5 3:16 6:4 reality III M:25
insulin III 6:1 5:7 5:12 6:25 parties 121 3:3 11:16 reallYI'I 6:5 8:18
interestcd 11 I 1I:IX X:2 S:III 9:1 partners 121 4:23 reasonable III 9:17
'I: 16 9:21 10:11 4:24
Miller's 1'1 5:10 patient III 5:7 recollection III 5:12
-J- 5: 19 10:7 6:18 patients III 4:21 record III 3:11 3:21
JOHNSON III 7:11 11:~ll
1:16 month 121 I'cnnsylvania 111 1:3 reduced 11 I 11:10
Jfl21 1:17 3:12 7:16 7:.211 1:14 4:3 4:S
Judge III 3~ll monlhsll15:16 9;6 11:2 II :5 redundant 111 S:6
judgemenl II I 9:15 mostl21 4:22 9:2~ I'ennsylvaniu's 1119:7 relative 121 11:15
mostly 111 6:2 11:17
June II) 6:14 percent II) 5:5 remarkablelll 5:19
Mount 121 4: I 4:3 percentage 111 5"
HUGHES, ALBRIGIIT, FOLTZ & NATALE
717-540-0220\717-393-5101
I ndel( Page 2
Multi-I'uge 1\1
rcmoved - ycurs
II. ROBERT 1M VIS, M D
.
removed III 11:13 SIIII121 4:25 (1:15 walvetllll 34
Reporterlll 11:11 stipulaled III 3:2 weakness 111 tdll
Reporter-Notary 111 STII'ULATION 1113:1 week 111 S:4
11:1ll STREET III 1:1.1 WEIDNER III 1.11,
represent II) 3:12 strike 111 M,9 wheelchair III 5:25
requirement 111 7:14 stroke 121 h:1O (o:Ih WIIEREOFIII II :22
requirements III 9:13 strongly II) ();23 whitelll 5:23
resources II) 9:12 submitted III 3:1<J willing 1113:~4
respective III 3:3 such 121 7:IM 11:17 withinl21 9:IM II :4
respond III M:16 suggest 1119:2~ witness 161 2:1
9:4 suspect 111111:7 3:h 10: 16 II:M
review III 9:M SWOml21 3:7 II:M II :21 11:22
Richard 1'1 I:M syndrome III 7:2 Wrightl>II:17 2:4
I:IM 3:12 3:15 3:10 3:12 IO:IJ
Richards III 1:9 synopsis III 5:IM
11:3 11'25 -y-
right 121 7:9 10:9 ..'..-
year (21 4:6 5:23
Robert 1'1 1:6 2:3 tukinglll 11:7 years III 4:21
3:6 3:22 11:6 talks III M:I<J
RI'R121 1:9 11:25 tenlll 5:11>
terms III 6:21
-S- testified II) 3:7
safely III 10:11 testimony 121 11:6
safety III 9:13 11:20
SaWII) 8:4 thank III 9:10 1ll:14
sealing III 3:3 1ll:16
Section 1119:6 thinlll 6:3
see 121 7:15 8.' Thrcclll 4:1
senile 121 6:22 7:2 times III 6:10
set III 11:22 Title III 9:6
sheet III 11:14 tOOl21 8:10 9:4
signing 1113:3 transeriptlll 3:IM
skull II) 6:13 truell) 5:9 10:3
11:20
somconelll 8:19 try 111 M:9
sometimes III 8:10 tWOlll 6:10
somewhat 121 M:8 typewriting III II :11
8:15 typically II I S:16
son II) 9:24
sons II) 3:13 -u-
sores III 8:)3
SOrtl21 4:24 M:6 ulcers 121 6:12 6:12
speeialtl18:13 urn-hum 11) 9:10
specialty (2) 4:11 unable 111 9:12
4:14 undeq'l 3:18 5:13
specified II) 11:13 7:11 7:22 11:11
Springs III 4:1 understand III 8:20
4:2 4:3 understands I'I 9"
,.
SSII) 11:1 unless III W:I
stasis III 6:12 UPI11 4:10 4:~4
state 121 3:21 7:14 7;IM
statement (2) 9:11 usually 1117:211
9:14
status III 6:7 6:18 -V-
7:21 various 1'/4:24
Statutes III 9:7 vaseularl'l 6:2
statutory III 9:7 6:11 6:12 7:1
stenographically III
11:9 -w-
STEWART II) 1:16 Will 3:12
v
IIUGHES, ALBRIGIIT, FOLTZ & NATALE
717-540-0220\717-393-5101
I ndex Page 3
20 I'n.C.S.A. ~ 5,111i
IlECEIlE:'\TS, ESTATES, ETC,
1II.lnrlcllllln<l Stlltnlnr)' Nnll's
^~l 1'1'1:. '\rlll 1", 1'1. Ill!', :-O,l :.1. If,.
~uh'lIluled "lnCJluciiJICd I'cr~,"\" (,If "'nwm.
1~ICI\I\" In the (hJr!.'! hCJd101l
SUIlCIIAI'n:H A, (;E~f:HAI. I'HO\'ISIO~S
Sl'l'tilln
r,501. ~tl'aninlo: of llil'apal'itntt'd pl'r:'lln.
lif,O:!, Purpo~(! of chaptt'r.
lIi.tnricullln<l Stlltutnl')' :'\otcs
Act I'N!. ,\ptll Ifl, 1'.1.. lO.'t, t-:\l 24. I (',
~uh\lilU1Cd "General l'w\i\lOm" fll! "~h:.,"in~
of Inwmpch:nt" in the lulxhaplcr head mg.
Cross References
Menial Ik.lllh I'hlo:cdurl'\ Act, ~c: ~II f1 S
o 71111 cl \cq
Law Hc\'iew nnd Journnl Commentaries
Capae;l)' or incapacit}? Th.11 i~ the quc\li\m
Jud~c Anne E. I.Oll.lrY\' 55 flhi]a,Ll'.lo. :-1 (FJll
19')..).
GUJrdlamhip Il\~nmrclcn~) \tJndJrJ (19i6)
U.J'.j,L.Rc\',IO.:S.
WESTl.AW meetronlc Hcscarch
See WESTLAW Electronic Rc~.mh Guide
ColllMins th~ rtdace.
~ 5501. Meaning of incapacitated person
"Incapacitated person" means an adult whose ability to receive and evaluate inronna.
tlon effective1)' and communicate decisions in any way is impaired to such a !>ignlficnnt
ex~nt that he Is lJartially or totally unable to manage his financial re~ources or to meet
essential requirements for his ph~'5ical health and saret~..
Amend,,11992. Al'rillG, P.L, 10S. No, 2~.! 6. effecli"e in 60 doy"
Official Comment-1974
Thh It'ctlon Ii Imended to enlarge the ml'anlng or incompetenl:)', thrreb;,' rrdut'ir.jt the
luppost>tlltllfJl\3 Ittached to the dulgnation and abo to include thOfc who arc mentall)'
. ,"ounc! but ne\'l,.rthl'll'~~ lack capacit). to take Ute of their 'It'I'SOn. re~ardl(,H of the fl'aJon.
llistorlcal arid StotutOI'). Notes
i'l:UII"l:Itlol1
The 1992 amendment re....role the: ~c:ction.
SCClions 20 and 21 of Act 199~, ,\ptil Ifl, r.l..
IOS. No. 2~, pra.ide::
"Section 20. The prO\'isions uf Ihis act arc
~erable. If any proo.'ision of this act or it\
application to any peMn or citcumsf,mce is held
in\'alill, the innliJit}. shall not affect other provi.
siom or applications of this act Vlhich can be
gi\'en effcct Vlithout the in\'alid prO\'ision or ap.
plication,
"Seetion 21. Except for Ihe addition of ~O
Pol.C.S. 01. 5':, the amcndment of ~o PJ.C.S,
shall appl)' to all guarlliamhip proceedings in
Vlhich petitions fot Ihe appointment of a guard.
ian arc flied su~qucnt to the effecti\e datc of
Ihis scction. Where a petition has been (ilell
prior to Ihc effccti\e d.ltc c( thi\ sc"ion but
....here a guardian h.lS not )Cl bec:n appoinlcll, the
proccdures of the amendment uf :0 l'a.C.S,.
e\cept (or Ihe addition of ~O Pa.C.S, 01. 5':. shall
apply. E.\isting guarJianship m.l)' be modified b)'
thc routt in accordJnce Vlith the amendment of
20 Pa.C.S., e"cpt for the addition of 20 Pa.C.S.
en. 5~, upon pctition of an> intcrested pJrt>'."
66
nt;CEDENTS, EST}
La"
~hndalOrY appointmenl 01
\Ini.l guardilnlohip proctedir.
lNe\' 97.
CoatlnlttlOD uet Ipplltltloc
~hnt.lI11Dtn 1
I. CODstnlCllolI Ind Ippllcl
Trial coun did not apply
delermining ..hether mentall
ln~ompctcnt In proceedina In
cr and bther each filed P'
dccl:ued incompetent and ,
Su.udians; court luumed Id
.nd ....cnt on to decide ..h.
i1pptopriate custody arranr
I bcmch, 609 A.2d 1384,
Supc:r.I992.
E\'idcnce ....as lnsufficlcn
mentally retarded Idult wa
,tence presented It uial lara-
er adult ....ould do best living
her father, rlther thin ..helh
tent under st81utOry defl
Uaemch, 6f11 A.2d 1384,
SUflcr.I992.
"Incompeten'" is person y
tcrion of being unable to mr
bl:inll unable to manage hls
\'. 5\no. 59~ A.2d 307, 406
pct.i991. appeal denied 600
1>12,
E\'idencc in support of S
VIas insufficient 10 e$llbllsh
rnidcnt VIas incompetent ..i
~'tion; Ilthough resident',
Iy i:npaired. she was aWlre II
ing her U\C15 and hid cor.
that she ....anled to entrust
tither thin pelitioner', wife,
mter\;ie....cd rnident condu(
of choosing financial repre!
Ute of Wood, S33 A.2d 772
Sllper.19S7.
Conclusion that petitlone
old and throughout his Iif~
sr.ull sums of money, eould I
age about $150.000 In cash I
less of' how ....ell.intentione
such conclusion was., waJ r.
I 5502. purpose of.
Recognizing thot ever
purpose of this ehapter
SYSlem which pennlta I
decision. which arcee!
rt'quirements for thelr
their financial resoun:e:
extenl possible and whi
rcstriCt!\.c B1~mBtivei
nccc~satj', it is Importl
willing lo .e",e as guanl
1992, April 16, P,L. lOS,
00228M,OOlIO/Ocluhcr 20, 1997IJUlW/I'A)UI02243
ESTATE OF EVELYN M. MILLER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-352 ORPHANS' COURT
NOTICE OF HEARING
TO: CRAIG A. TURNER
RR 1, Box 193
Ellioltsburg, PA 17204
AND NOW, this 20'" day of October, 1997, you are hereby notified that a hearing pursuant to the
Petition of Charles W, Miller and Richard F. Miller to adjudicate Evelyn M. Miller to be incapacilated and to
appoint a guardian for her person and her estate has been scheduled by the Cumberland County Court for
Friday, October 31, 1997, In Court Room No.2, Cumberland County Courthouse, Carlisle, Pennsylvania, at
8:45 A.M., before Judge Edgar B. Bayley.
JOHNSON, DUFFIE, STEWART & WEIDNER
B~~C~~ -.
Allorney 1.0. No. 53113
301 Market Street
P. 0, Box 109
Lemoyne, PA 17043-0109
(717) 761-4540
Allorney for Charles W. Miller and
Richard F. Miller
"
0/
I
~
002288.ooo10/Oclohc' 20. 199711111W/I'MU1Il2H3
ESTATE OF EVELYN M. MILLER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-352 ORPHANS' COURT
TO: RONALD E, TURNER
7 Rockaway Drive
Camp Hill, PA 17011
AND NOW, this 20th day of October. 1997, you are hereby notified that a hearing pursuant to the
Pelition of Charles W. Miller and Richard F. Miller to adjudicate Evelyn M. Miller to be Incapacitated and to
appoint a guardian for her person and her estate has been scheduled by the Cumberland County Court for
Friday, October 31, 1997, in Court Room No.2, Cumberland County Courthouse. Carlisle, Pennsylvania, at
8.45 A,M., before Judge Edgar B. Bayley.
JOHNSON, DUFFIE, STEWART & WEIDNER
BY:~/~~ .
/~ffi. Wright, Jr. ",
Attorney 1.0. No. 53113 '
301 Market Street
P. O. Box 109
Lernoyne, PA 17043-0109
(717) 761-4540
Attorney for Charles W. Miller and
Richard F. Miller
,.
0021MK,lXXlIOI0c1IlhC:120, 19'J711U1WII'AJlIIlI12013
ESTATE OF EVELYN M. MILLER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-352 ORPHANS' COURT
NOTICE OF HEARING
TO: SUSAN E. MILLER
535-C Northeast 21st Lane
Gainesville, FL 32609
AND NOW, this 20lh day of Oclober, 1997, you are hereby notified that a hearing pursuant to the
Petition of Charles W, Miller and Richard F. Miller to adjudicate Evelyn M. Miller to be incapacitated and to
appoint a guardian for her person and her estate has been scheduled by the Cumberland County Court for
Friday, October 31, 1997, in Court Room No.2, Cumberland County Courthouse, Carlisle, Pennsylvania, at
8:45 A.M., before Judge Edgar B. Bayley.
JOHNSON, DUFFIE, STEWART & WEIDNER
BY:~/#~:"
, R ph H. Wright, Jr.
Attorney 1.0. No. 53113
301 Market Street
P. O. Box 109
Lemoyne, PA 17043-0109
(717) 761-4540
Attorney for Charles W. Miller and
Richard F. Miller
002288'(]()()\0/OcIOhc,20, 1997/RIIW/I'ARlI02243
ESTATE OF EVELYN M. MILLER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96.352 ORPHANS' COURT
NJJI1CE OF HEARING
TO: GLADYS MOLY AN
1532 Kemble Street
Utica, NY 13501
AND NOW, this 20'" day of October, 1997, you are hereby notified that a hearing pursuant to the
Petition of Charles W. Miller and Richard F. Miller to adjudicate Evelyn M. Miller to be Incapacitated and to
appoint a guardian for her person and her estate has been scheduled by the Cumberland County Court for
Friday, October 31, 1997, In Court Room No.2, Cumberland County Courthouse, Carlisle, Pennsylvania, 01
8:45 A.M., before Judge Edgar B. Bayley.
JOHNSON, DUFFIE, STEWART & WEIDNER
B"~~rP
'" alph H, Wrlg I, Jr. .
Attorney 1.0. No, 53113
301 Market Stroot
P.O. Box 100
Lemoyno, PA 17043.0100
(717) 761-4540
Attorney for Charles W, Mlllor and
Richard F. Miller
002288,OOOI0/lXlohc:r 20, 1997IRIlWIPAIUI022013
ESTATE OF EVELYN M. MILLER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-352 ORPHANS' COURT
NQTICE Of HEARING
TO: HELEN HELLER
1149 Myerstown Road
Gardners, PA 17324
AND NOW, this 20th day of October, 1997, you are hereby notified that a hearing pursuant to Ihe
Petition of Charles W. Miller and Richard F. Miller to adjudicate Evelyn M. Miller 10 be Incapacllated and to
appoint a guardian for her person and her estate has been scheduled by the Cumberland County Court for
Friday, October 31, 1997, In Court Room No.2, Cumberland County Courthouse, Carlisle, Pennsylvania, at
8:45 A.M., before Judge Edgar B. Bayley.
JOHNSON, DUFFIE, STEWART & WEIDNER
B'~~4rh
, alph H. Wrlghl, J .
Allorney 1.0. No. 53113
301 Market Slreet
P. O. Box 109
Lemoyno, PA 17043-0109
(717) 761.4540
AIlorney lor Charlos W. Miller and
Richard F, Miller
002288'()()()IO/Oclohcr 20, 199711UlWII'^IUI02243
ESTATE OF EVELYN M. MILLER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96.352 ORPHANS' COURT
NfJIICE Of HEARING
TO: ADMINISTRATOR, CHURCH OF GOD HOME
801 North Hanover Street
Carlisle, PA 17013
AND NOW, this 20th day of October, 1997, you are hereby notified that a hearing pursuant to the
Petition of Charles W. Miller and Richard F. Miller to adjudicate Evelyn M. Miller to be Incapacitated and to
appoint a guardian for her person and her estate has been scheduled by the Cumberland County Court for
Friday, October 31, 1997, in Court Room No.2, Cumberland County Courthouse, Carlisle, Pennsylvania, at
8:45 A.M., before Judge Edgar B. Bayley.
JOHNSON, DUFFIE, STEWART & WEIDNER
. ,.
By:~P/4 --
, R ph H. Wright, Jr.
Attorney 1.0. No. 53113
301 Market Street
P. O. Box 109
Lemoyne, PA 17043-0109
(717) 761-4540
Attorney for Charles W. Miller and
Richard F. Miller
October 31, 1997
David W. DeLuce, Esquire
301 Market Street
P.O. Box 109
Lemoyne, PA 17043
Harold S. Irwin, III, Esquire
36 South Pitt Street
Carlisle, PA 17013
RE: Estate of Evelyn M. Miller
96-0352 Orphans' Court
Dear Counsel:
Upon reflection I signed the final decree in the above matter without the
requirement of posting bond.
Very truly yours,
Edgar B. Bayley
EBB:saa
I
I
,
I
I
,
!
t
I
,
j
i
i
t.
,
I
r
t
IN RE:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
NO. 9J .352 ORPHANS' COURT
EV"LYN M. MILLER
IMPORTANT NOTICE
CITATION WITH NOTICE
A petition has been filed with this Court to have you declared an Incapacitated Person. If the Court
finds you to be an Incapacitated Person. your rights will be affected. including our right to manage money
and property and to make decisions. A copy of the petition which has been filed by
__-RALPH H_ WRTGHT..TR. ESO. is attached.
You are hereby ordered to appear at a hearing to be held in Court Room No.2. Cumberland
County Courthouse. Carlisle. Pennsylvania. on OCT. 31 . 1997 . at 8: 4 5 ~.M. to
tell tho Court why it should not find you to be an Incapacitated Person and appoint a Guardian to act on
your behalf.
To be an Incapacitated Person means that you are not able to receive and effectively
evaluate information and communicate decisions and that you are unable to manage your
money and/or other property, or to make necessary decisions about where you will live.
what medical care you will get. or how your rnoney will be spent.
At the hearing, you have the right to appear, to be represented by an attorney, and
to request a jury trial. 11 you do not have an attorney. you have the right to request the
Court to appoint an attorney to represent you and to have the attorney's fees paid for you
if you cannot afford to pay them yourself. You also have the right to request that the Court
order that an independent evaluation be conducted as to your alleged incapacity.
If the Court decides that you are on Incapacitated Person. the Court may appoint a
Guardian for you. based on the nature of any condition or disability and your capacity to
IN RE:
IN 'l'HE COUR'r OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
c
EVELYN M. MILLER
ORPHANS' COURT DIVISION
NO. 21-96-352
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on the 31st day of
December, 1997, a copy of the petition to the Orphans' court to
Approve and confirm Sale of Real Property, Order, Rule and
proposed order approving and confirming the sale was served on
the following:
VIA REGULAR, FIRST CLASS, U.S. POSTAGE PREPAID MAIL:
William V. Freeman, president
Pennsylvania State Bank
2148 Market street
P.O. Box 487
Camp Hill, PA 17001-0487
Richard F. Miller
106 Rolo court
Mechanicsburg, PA 17055
Charles W. Miller
c/o Church of God Horne Inc.
801 N. Hanover street
Carlisle, PA 17013
VIA CERTIFIED, RETURN RECEIPT REQUESTED AND REGULAR, FIRST CLASS,
U.S. POSTAGE PREPAID MAIL:
craig Turner
1l Rockaway Drive
Camp Hill, PA 17011
Ronald Turner
1437 Apple Circle, Apt. 188
Mechanicsburg, PA 17055
Evelyn Maze
285 Bishop Drive
Gainsville, FL 32607
Susan Lacheney
5730 county Road U926
Nevada, TX 75173
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By:., j~;. d/r- ~ to '{
Thomas M. Devlin, Esquire
r.D. 1134993
1802 Market street
Camp Hill, PA l7011
(717) 730-9878
:~ ,
flEe is 1 1998
IN TilE: COURT OF COMMON PLE:AS OF CUMBE:RLAND COUNTY
NO. 96-352 ORPHANS' COURT
E:STATE: OF E:VELYN M. MILLER
ORDER
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AND NOW, this
">\
day of
upon consideration of the foregoing petition, it is hereby
ordered that:
(1) A rule is issued upon all parties to the petition and
all persons served with the petition and proposed order to show
cause why the petitioners are not entitled to the relief
requested;
(2) Anyone wishing to object shall file an answer or
objection to the petition on or before
1999;
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(3) If no answers or objections are filed, the Court may
proceed to grant the petition in a final order; and
(4) Notice of the entry of this order shall be provided to
all parties by regular mail and to the prospective heirs listed
in the petition by certified mail to their last known address,
service being completed upon mailing.
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BY THE COURT:
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. TtloMAll M. OEVUN
1802 MARKET STREET
CAMP HILL. PI. 17011
(71n 730-9878
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IN THE COURT Ot" COMMON PI,EAS OF CUMBERLAND COUNTY
NO. 96-352 ORPHANS' COURT
ESTATE OF EVELYN M. MILLER
PETITION TO THE ORPHANS' COURT TO APPROVE
AND CONFIRM SALE OF REAL PROPERTY
TO THE HONORABLE JUDGE EDGAR B. BAYLEY:
AND NOW, come the co-guardians, Charles W. Miller and
Richard F. Miller, for the Estate of Evelyn M. Miller as Sellers
and jointly with pennsylvania State Bank as Buyer and request
this Court's approval and confirmation of a sale of the
incapacitated person's real property as follows:
1. Charles W. Miller and Richard F. Miller were appointed
co-guardians of the Estate of Evelyn M. Miller under this Court's
final decree of October 31, 1997, adjudicating her as an
incapacitated person. A copy of said final decree is herein
attached and marked as Exhibit "A" and incorporated by reference
as if fully set forth herein.
2. This Court's final decree granted the co-guardians the
authority to sell, convey, lease or transfer any real property
including that located at 2164 and 2166 Market street, Camp Hill,
cumberland County, Pennsylvania.
3. The personal property of the Estate of Evelyn M. Miller
having dwindled due to its use for the purposes of her care and
nursing home care and maintenance, the co-guardians deem it
appropriate and in her best interest to sell the above-referenced
real property.
4. Accordingly, the co-guardians have entered into an
Agreement for the Sale of Real Estate with Pennsylvania State
Bank for the purchase of the said real property in the amount of
$160,000.00 on the terms and conditions of the Agreement and its
Addendum herein attached as Exhibit "13" which are herein
incorporated by reference as if fully set forth herein.
5. The proposed purchaser is Pennsylvania State Bank, a
Pennsylvania banking corporation, whose headquarters are located
at 2148 Market street, P.O. Box 487, Camp Hill, PA l7001-0487.
6. The property to be sold is 2164 and 2166 Market street,
Camp Hill, PA l70ll, more fully described in the legal
description herein attached as Exhibit "C."
7. A title abstract of the property has indicated that
there are no pending liens or encumbrances other than utility
encumbrances of record and the usual deed restrictions against
the property and other than the taxes or other charges prorated
at the time of closing.
8. It is believed by Sellers and Buyer that the $160,000.00
purchase price is better than could be obtained on a public or
auction sale of the property, because the purchase price takes
into consideration that had the property been listed for sale by
a commercial Realtor at the market appraisal price, there would
have been substantial costs and expenses of approximately 10%
(estimated $19,000.00) and that the Buyer is also paying the 2%
transfer tax (estimated $3,200.00) and other closing costs
including the cost of this petition and therefore believes that
the contract sale price is reasonable and fair.
9. The co-guardians had obtained an independent appraisal
of the property which listed an estimated market value of
$190,000.00 without request for minimum valuation, a specific
valuation, or the approval of a loan. (See attached copy of
relevant opinion portions of appraisal marked as Exhibit "D.")
10. Pursuant to Orphans' Court Rule 14.4 (proceedings
related to real estate), the above appraisal conforms as far as
practical to the requirements for the rules pertaining to
personal representatives or guardians of a minor in transactions
of a similar type, including but not limited to the requirements
under Orphans' Court Rule 12.9 and l2.10 and in place of two
affidavits that the proposed consideration is more than could be
obtained at public sale.
11. There are no other known creditors who would have
interest in the real property, and it is believed that the
proceeds of the sale would be more than sufficient to pay any
incidental creditors who might exist presently.
12. The co-guardians are themselves prospective heirs and
other potential heirs under the incapacitated person's Will are
relatives, nieces and nephews: Susan Lacheney, Evelyn Maze,
Ronald Turner and Craig Turner. Those potential heirs will be
notified by providing them with service by way of certified or
regular mail or an acceptance of service form and a copy of the
rule to show cause, the petition and proposed order.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
NO, 96-352 ORPHANS' COURT
ESTATE OF EVELYN M. MILLER
PETITION PURSUANT TO SECTION 5511 OF THE PROBATE, ESTATES AND
FIDUCIARIES CODE TO ADJUDICATE EVELYN M. MILLER TO BE INCAPACITATED
AND TO APPOINT CO-GUARDIANS FOR HER PERSON AND HER ESTATE
FINAL DECREE
AND NDW, this 1/ day of O~ ,1997. Upon consideration of the
Petition of CHARLES W. MILLER and RICHARD F. MILLER, and followin9 a hearing, /T IS ORDERED
AND DECREED that Evelyn M. Miller is adjudicated an incapacitated person and Charles W. Miller and
Richard F. Miller are hereby appointed plenary co-guardians of Evelyn M. Miller's estate. Charles W.
Miller and Richard F. Miller are authorized to make future payments of both income and principal for her
care and maintenance as may be necessary; Charles W. Miller and Richard F. Miller are hereby permitted
to sell, convey, lease or transfer any real property which Evelyn M. Miller may own, including that
located at 2164 Market Street and 2166 Market Street. Camp Hill. Cumberland County, Pennsylvania,
and any other personal or real property that Evelyn M, Miller may own as may be necessary for her
future care and maintenance, however, the proceeds from the sale of such real property shall only be
used for her future care and maintenance after all other principal and income from the estate has first
been exhausted; and no bond shall be required; and Charles W. Miller and Richard F. Miller are hereby
appointed co-guardians of Evelyn M. Miller's person and are hereby authorized to make decisions on
behalf of Evelyn M. Miller concerning her medical care treatment. including admission to nursing homes
and hospitals and other health care facilities as well as to consent to medic.,:!1 treatment.
A TRI'l: CO?Y FFlO~,1Ricom :' ,
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Clmk of tho 0 ;>h!:O:l ~t:(t
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Exhibit
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t6li~iirrrmrnt, owIe thll.,., ." d' ,18 th day of ,
\. llelTocca Chdrl,"~,H"i'I,il.leran<l, Illeh.ud ~'. Mil l"r,
co-o;:u lrd i ,]nsold Evel yn~.rHi Ie,':" ii"f.ii'i:.a"t~,
~"nnsy 1 van~:ii:::s.,~~t,e",Jl,"n~", .tipenll!,yl~:a~lill,~;~n,~jIl9
P? C.~!I~.U.f.' r.
plen'!ry,
A,D,19 98
..K~alIlfll'r"6tJrclUl
. .. . . herelnaftcr called SeDer, and
eOr:po~!l,t:i,()n, "dd'd'
d. . "d".d.d. . . ,... ,. ...d.. ..,." . , ' ......, ..d'.' . hcrelnaltc, called Buy.,.
1'lill!'Htn'
2.WlTh'ESSETH: Sell., hereby Ig,cc,lo sell I.d con'.y '0 Buyer, who hereby Igm,'o pUlChlse: ALL TIlAT CERTAIN \0' or plea: of
pound with buildings and improvements thereon erecled. if an)'. lnO~lI as ur deKribcd u follow.:
21 ~ ,1 dnd 2166., Ma!:,~c,t,$t;rl'et'd,Ci;l!11PdlijJdk'ddc,\Iml:m,l"n<l,.CQ,\IlltY" .1'./\, ,ffiore....f,l!lly,dddd"",
.:ic l;C r.ibed., ,J.n. dthe",lell a!.. ,de H CJ: ip t i Qn",CO n tain odd. ,in., .the d. de ed. d to" Ar.thu!:." ,F,... ,Mil 1 OJ: ..,,,, .
'od "Yel ynfMb.M\Uer "C. recorded instil" C.\I!11h5~r t,nctcountbl th...,. ,llor,OIl9h..""" . of
Heeorder 0 cods Of, "".. Jjook '12 , I'age .,0
Tr~l~'P Jllll "d.'.'...,...., nUll'1 . cumber lund . .. ... , Sla'. of .Pcnnsylvania'........
),Tof/O<Ib< '"In of Ono ,hundred sixty th()us~nd ($160,000.00) -.-.------.....-..-...-...
---------------~------------------------------------_.-_._--------_._---~~
abltb lb.U k paid IQ the Sellct by lbe Buyer .. fullowl:
tbl Cuh ur ebcd. II li,nin, tbis ~'Icrmcnl: S.
(c) c.,burcbcd. lobc paid on or bcfolc: at cloning 19 S
Cd) I
(t) Cub or m1iPic.J (hee" al time of wUJcmrnl: . S
TOTAL I
160.000
19
..,. 1998
00
to Wrillcn IPl'fo....1 of Seller 10 be on 01 before:
(cJ Sctllcmcnl to be made on or before: December 31,
thl Con\'C')lncc hom Selin will be by ,he .implc deed of lop<<oia.l~UM1.tL Guardaans uS f iduc i a r les
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APPRAISAL OF A
MIXED USE 1'ltol'Elrr....
LOCATED AT
2164-2166 MARKET STREET
CAMP HILL BOROUGH
CUMBERLAND COUNTY,PA 17011
FOR
MS. PEGGY MILLER
106 ROLO COURT
MECIlANICSBURG, PA 17055
DATE OF REPORT
NOVEMBER 20, 1998
PREPARED BY
RSR APPRAISERS & ANALYSTS
355 N. 21ST STREET, SUITE 102
CAMP HILL, PENNSYLVANIA 17011
(717) 763-1212
Exhibit "0"
RSR ~Pl1liSerS
analyst.s
Novcmbcr :!O, 1998
Ms. Peggy Miller
106 Rolo Court
Mechanicsburg, PA 17055
Dear Ms, Miller:
At your requesl, RSR Appraisers & Analysts has complelcd a limited summary
appruisill on lhe property known as:
2164.2166 Market Street
Camp Hili, I'A 17011
Our File # 98.72G
The purpose of lhis appraisal is 10 estimate lhe markel value of the subjecl property
as of the effective dale of lhis report. The report lhal follows provides a summary
description of lhe property and lhe basis for the estimated value. Based on our inspeclion of
lhe subjecl properly, Ihe invesligalion and analysis undel1aken, and subjecl to lhe
"Undcllying Assumption~ and Limiling Conditions" noted in thc addenda to this relXlrt, il is
our ol'lIlion lhal the cstimalcd markel valueof lhe fce simple inlerc~l in the subject property
as of O~lOber 29. 1998 is:
ONE IIUNDRED NINETY THOUSAND DOLLARS
($190,000)
This appraisal has been devclopcdas if lhe property were free and clear of any liens
or encumbrances. We assume lhere are no hazardous malcrials on sileo The discovery of
such malerials will necessitale re-evaluation; and lhis appraisal may be void.
This report has been prepared in aecordance with the Unifonn Standards of
Professional Appraisal PnlClicc of lhe Appmisal Foundalion, and Ihe Code of Elhics and
Standards of professional Pruclicc of lhe Appmisal Inslitule. This appraisal W,L~ nol
requesled wilh a minimum valualion,a specific valualion,or lhe approval of a loan.
Our compensalion is nol contingenl on the valueeslimale and we will be available to
discuss the findings of lhe report al your requesl and convenience.
Respeclfull y submillcd,
W. ~~
W, Greg Rolhman. CCIM
GA-OOI455.L
:z
P.O. Box 188' Camp Hill, PA 17001-0188' Phone (717) 763-1212' Fax (717) 763-1656
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IN RE:
IN '1'111:: COURT OF COMMON PLI::/\S OF'
CUMBEIU,AND COUNTY, PENNSYLV/\NI/\
EVELYN M. MILLER
ORPHANS' COUIn DIVISION
NO. 21-96-352
MOTION FOR AN ORDER APPROVING AND CONFIRMING THE SALE OF
INCAPACITATED PERSON'S REAL ESTATE
TO THE HONORABLE JUDGE EDGAR B. BAYLEY:
AND NOW, come the co-guardians for the above-referenced
Estate and Pennsylvania state Bank and motion this Court for a
final Order as follows:
l. On December 31, 1998, this Court issued an order for a
Rule.
2. That Rule was issued upon all the parties to the
proposed transaction of the incapacitated person's real property
on a Petition to Approve and Confirm a private sale to
Pennsylvania state Bank.
3. Additionally, all the current prospective heirs under
the incapacitated person's Will were noticed in accordance with
the Rule.
4. The Rule was issued pursuant to a Petition to the
Orphans' Court to Approve and Confirm Sale of Real Property of
2164 and 2166 Market street, Camp Hill, Cumberland County,
pennsylvania.
5. Objections or answers were to be filed on or before
January 15, 1999.
6. No answers or objections have been filed.
WHEREFORE, movants respectfully request that this court
enter the Order requested with the Petition which the attached
Order Approving and Confirming the Sale of Incapacitated Person's
Real Estate, thereby making that Order final.
Dated:
/'11/11
RespectfullY submitted,
/2-:~-//( JI!~L
Thomas M. Devlin, Esquire
I. D. 1134993
1802 Market Street
Camp Hill, PA l70ll
(717) 730-9878
IN RE:
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
EVELYN M. MILLER
ORPHANS' COURT DIVISION
NO. 2l-96-352
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on the
/9(6
day of
January, 1999, a copy of the Motion for an Order Approving and
Confirming the Sale of Incapacitated Person's Real Estate was
served on the following by first class, U.S. postage prepaid
mail:
William V. Freeman, President
Pennsylvania State Bank
2148 Market street
P.O. Box 487
Camp Hill, PA 17001-0487
Richard F. Miller
106 Rolo Court
Mechanicsburg, PA 17055
Charles W. Miller
c/o Church of God Home Inc.
801 N. Hanover street
Carlisle, PA 17013
Craig Turner
11 Rockaway Drive
Camp Hill, PA l7011
Ronald Turner
1437 Apple Circle, Apt. 188
Mechanicsburg, PA 17055
Evelyn Maze
285 Bishop Drive
Gainsville, FL 32607
Susan Lacheney
5730 County Road >>926
Nevada, TX 75173
~ -/" /' /'//
By: ' /~__-<'''''' ((If.. tI
Thom~s M. Devlin, Esquire
I.D. 1134993
1802 Market Street
Camp Hill, PA l70ll
(717) 730-9878