HomeMy WebLinkAbout08-17-07
MARK F. BAYLEY, ESQUIRE
BAYLEY & MANGAN
17 WEST SOUTH STREET
CARLISLE P A 17013
(717) 241-2446
ATTORNEY ill NO. 87663
ATTORNEY FOR HOWARD & VIRGINIA TAYLOR
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHAN'S COURT DIVISION
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INRE: HOWARDJ. TAYLOR
AN INCAPACITATED PERSON
NO. 21-06-0436
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IN RE: VIRGINIA M. TAYLOR
AN INCAPACITATED PERSON
NO. 21-06-0435
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THE T A YLORS' RESPONSE TO THE RULE TO SHOW CAUSE
ISSUED JULY 31. 2007
AND NOW, come Howard J. Taylor and Virginia M. Taylor, by and through their court-
appointed counsel, Mark F. Bayley, Esquire, and in response to the rule to show cause issued
July 31,2007, respond as follows:
1. The Taylors' current guardian, Cheryl E. Watson, has requested to be relieved of her
duties by petitio!). filed July 30, 2007.
2. Said petition requests that Keystone Guardianship Services be appointed as guardian at
this time.
3. Judge Ebert issued a rule upon the Taylors dated July 31, 2007 to show cause why said
petition should not be granted
4. Undersigned counsel recently met with the Taylors who indicate that they would prefer
former neighbors, Alfred and Bernadette Burch, to assume guardianship duties rather
than a professional service.
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5. Mr. and Mrs. Burch have been friends with the Taylors for approximately 30 years and
have kept close contact to date.
6. Undersigned counsel spoke with Mrs. Burch who indicated that she and her husband
are willing and able to assume guardianship duties.
7. Undersigned counsel believes that a hearing will be necessary for the Court to determine
which proposed guardian would best serve the Taylor's interest.
WHEREFORE, The Taylors respectfully request that a hearing with regard to the
selection of a new guardian be scheduled.
Respectfully submitted,
BAYLEY & MANGAN
Date: <2'~ l1- Or
Mark F. Bayley, Es
17 West South Street
Carlisle, PA 17013
(717) 241-2446
Supreme Court ID # 87663
Attorney for Howard & Virginia Taylor
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
ORPHAN'S COURT DIVISION
IN RE: HOWARD J. TAYLOR
AN INCAPACITATED PERSON
NO. 21-06-0436
IN RE: VIRGINIA M. TAYLOR
AN INCAPACITATED PERSON
NO. 21-06-0435
VERIFICATION
MARK F. BAYLEY, ESQUIRE, states that he is the attorney for Howard & Virginia
Taylor, in this action; that he makes this affidavit as attorney because he has sufficient
knowledge or information and belief, based upon his investigation of the matters averred or
denied in the foregoing document; and that this statement is made subject to the penalties of 18
Pa. C.S. Pa.C.S. ~4904, relating to unsworn falsification to authorities.
Date:
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Mark F. Bayley, Esquire
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
ORPHAN'S COURT DIVISION
IN RE: HOWARD J. TAYLOR
AN INCAPACITATED PERSON
NO. 21-06-0436
IN RE: VIRGINIA M. TAYLOR
AN INCAPACITATED PERSON
NO. 21-06-0435
CERTIFICATE OF SERVICE
I, MarkF. Bayley, Esquire, attorney for Howard & Virginia Taylor, do hereby certify that
I this day served a copy of the within document upon the following by depositing same in the
United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows:
Glenn Davis, Esquire
1700 Bent Creek Blvd., Suite 140
Mechanicsburg, P A 17050
Dated:
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