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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
ORPHANS' COURT DIVISION
In re: Amanda McKee,
An Alleged Incapacitated Person
21-05-463
PETITION FOR COURT ORDER TO RELEASE FILES TO GUARDIAN
AND NOW, this o?G.fl..-day of April, 2007, comes the Petitioner, Elizabeth
Reinecker, guardian of Amanda McKee, by her attorney, Wendy Weikal-Beauchat,
Esquire, and states the following:
1. Petitioner is Elizabeth Reinecker, 9 Mayfield Road, Mechanicsburg,
Pennsylvania 17055-3333.
2. This Court appointed Petitioner as plenary guardian of the person and
plenary guardian of the estate of her mother Amanda McKee by Order dated June 20, 2005.
A copy of the Order of Court is attached hereto and incorporated herein by reference as
exhibit A.
3. Since the time of her appointment, Petitioner has been organizing her
mother's affairs and corralling her mother's property.
4. Petitioner believes her mother used the services of William D. Schrack, III,
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Esq. for estate planning and long term care planning. ~;-g::r::
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5. Petitioner believes Mr. Schrack's file contains information regarding her
mother's property that is essential to her ability to serve as plenary guardian of the estate of
her mother.
6. Further, Petitioner believes Mr. Schrack's file contains estate planning
documents such as a will that are essential to her ability to serve as plenary guardian of the
person of her mother.
7. Petitioner contacted Mr. Schrack and requested that he release the files of
her mother and late father to her.
8. Mr. Schrack requested Petitioner seek an order from this Court ordering him
to release said files. A copy of Mr. Schrack's fax request is attached hereto and
incorporated herein by reference as exhibit B.
9. To better serve her mother, Petitioner seeks an order from this Court
requiring Mr. Schrack to release the files of her mother and late father to her.
WHEREFORE, Petitioner requests that this Court enter an Order requiring Mr.
Schrack to release any and all files related to Amanda McKee, Petitioner's mother, and
Milford McKee, Petitioner's father, to Petitioner.
Respectfully submitted,
BEAUCHAT& BEAUCHAT
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Wen4y Weikal-Beauchat, Esquire
Attorney for Petitioner
63 West High Street
Gettysburg, P A 17325
ID #71930
717.334.4515
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: AMANDA MCKEE,
AN ALLEGED INCAPACITATED
PERSON
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: 21-05-463
ORDER OF COURT
AND NOW, this ~
day of June, 2005, finding that Amanda
McKee is an incapacitated person, IT IS ORDERED that Elizabeth Reinecker'is
appointed plerlary guardian of the person a~d plenary guardian of the ~state of her
mother Amanda McKee. The guardian shall serve without bond.
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Jane Adams, Esquire
For Amanda McKee
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Wendy Weikal-Beauchat, Esquire
For Petitioner
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EXHIBIT
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~PR-04-2007 12:34PM FROM-iCHRACK & LINSENBACH Law Offi~'1
7174321053
1-077 P.001/001 F-'~
LAW OFFICES
124 W. HARRISBURG ST.
P.O. BoX 310
DILLSBURO, PA 17019~0310
PHONE (717) 432-9733
FAX (711) 432,:,1053
AltOrtfeyfi
WM. D. SCIIRACKm
BRIAN C. LINSENBACH
TO:
FAX NO:
FROM:
DATE:
H;.
WODdy Weikal-Be..ehat, Esquire
71700337-2009
W. D Sehrack m
4/4107
The Affain of AmaDda " MUronl McKee
PAGES:
L-J INCLUDING THIS COVERLETIER'
D1'ID8rg_. PL8AU CAlLAS ~..~ _ co NJ'AlNEDUlf
'I'IDIPU ~~.rr.lIJ1 --y
1l'O. TIIB o~~, THE or _ II IN'DNDD
-,'Y ..n1rco~l1ON1Jlt J&~ 0I'JlL:~~
COLLECT JJ' NECal.UtY, AND D MISSA YOU.
MESSAGE: Wendy:
Acknow1eclgc receipt of your req1,JCSt of March 29, 2007 relative the noted. I returned to the
office 00 Mon~, April 2, and reque*d the fax trtnmiission of a copy of the Court Order which
appoints Eliubeth her mother's aUardian. .. . .
Althou~ a packet is prepated and ~ for the mail, I ~~ a copy of that order os a
coudition ofma11ing. I do not queslion that the appointment is m place, nor impusn your credibility,
but do need to cover the file. :
EXHIBIT
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VERIFICATION
I, the undersigned, hereby verify that I have read the foregoing Petition for Court Order to
Release Files to Guardian and that the Petition for Court Order to Release Files to Guatdian
is true and correct to the best of my knowledge, information and belief. I understand that
any false statements herein are made subject to the penalties of 18 Pa.C.S.A. ~ 4904
relating to unsworn falsifications to authorities.
Date: l( /bJP7
~~d1..d~
Eliza Reinecker
Guardian of Amanda McKee .
Petitioner