HomeMy WebLinkAbout08-21-07
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,
PENNSYL VANIA
INRE:
ORPHANS' COURT DIVISION
DONNA L. NEAD
No. 21-07-0682
AN ALLEGED
INCAPACITATED PERSON.
Motion for Continuance
Filed on Behalf of Petitioner:
SHIPPENSBURG HEALTH CARE CENTER
Our Matter No. 875-07
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Counsel of Record for Petitioner:
CAPOZZI AND ASSOCIATES, P.C.
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Douglas A. Snyder, Esquire
Attorney ill No. 204384
2933 North Front Street
Harrisburg, PAl 711 0
(717) 233- 4101 (phone)
(717) 233- 4103 (fax)
Attorneys for Petitioner
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,
PENNSYL VANIA
INRE:
) ORPHANS' COURT DIVISION
)
)
) No. 21-07-0682
)
) PETITION FOR THE APPOINTMENT
) OF A PERMANENT GUARDIAN
) OF THE PERSON
)
DONNA L. NEAD
AN ALLEGED
INCAPACITATED PERSON.
MOTION FOR CONTINUANCE
AND NOW comes Petitioner, Shippensburg Health Care Center through their attorney,
Douglas A. Snyder, Esquire and states:
1. Donna Nead is an alleged incapacitated person residing at Shippensburg Health Care
Center.
2. Shippensburg Health Care Center has filed a petition with this Honorable Court to
have Donna Nead declared incapacitated and have a permanent plenary guardian of
her estate and person appointed.
3. The hearing date for the appointment of a permanent plenary guardian is scheduled
for August 30, 2007 at 11:00 a.m. in Court Room # 3.
4. Petitioner is requesting the hearing be rescheduled to the first available hearing date
not less than twenty-five (25) days after the date that this motion is decided.
5. To the best of Petitioner's knowledge, the current guardianship proceeding, scheduled
for August 30, 2007 is uncontested.
6. In the original Guardianship Petition filed with this Court, Petitioner stated that the
only interested parties and next of kin are:
Brian Nead (son)
1318 Wilson Ave.
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Chambersburg, P A 17201
Pastor Dannie Keen (Power of Attorney)
P.O. Box 85
S1. Thomas, P A 17852
7. Petitioner has subsequently learned that Donna Nead has a daughter, Sandra
Durham with a last known address of 198 Black Gap Road, Trailer 144,
Fayetteville, P A 17222.
8. Because of Donna Nead's alleged incapacity, Petitioner was unable to learn this
information prior to filing the Petition.
9. The current hearing date precludes Petitioner from providing Sandra Durham, an
interested party, with the statutory minimum twenty (20) days notice.
WHEREFORE Petitioner respectfully requests this Honorable Court:
1. Grant this Motion to Continue without having had this Motion to Continue
presented formally to the Court;
2. Issue a new Preliminary Order rescheduling the hearing for the first available
date not less than twenty-five (25) days after the date that this motion is decided
so Petitioner can provide all interested parties with proper notice.
Respectfully submitted,
CAPOZZI AND ASSOCIATES, P.C.
Date:
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Douglas A. Snyder, Esquire
Attorney ID No.: 204384
2933 North Front Street
Harrisburg, P A 17110
(717) 233- 4101
Attorney for Petitioner
VERIFICATION
I, Douglas A. Snyder, Esquire, hereby verify that the statements in the foregoing
Motion are true and correct to the best of my knowledge, information and belief. I
understand that false statements contained herein are made subject to the penalties of 18
Pa. C.S.A Section 4904 relative to unsworn falsification to authorities.
Date:
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Douglas A. Snyder, Esquire
Attorney ID No.: 204384
2933 North Front Street
Harrisburg, PAl 711 0
(717) 233- 4101
Attorney for Petitioner