HomeMy WebLinkAbout09-20-07
IN THE MATTER OF
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
BETTY M. PETTY, an alleged
incapacitated person
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: GUARDIANSHIP-INCAPACITATED PERSON
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AMENDED PETITION FOR
ApPOINTMENT OF GUARDIAN
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NOW come petitioners, CHARLES Y. PETTY, JR and LISA M. CHRISTOPHER, by
their attorney, Harold S. Irwin, III, Esquire, and present this amended petition for
appointment of guardians over Betty M. Petty, an alleged incapacitated person,
representing as follows:
1. Petitioners are CHARLES Y. PETTY, JR., an adult individual and son of the
alleged incapacitated person, residing at 209 West North Street, Carlisle, PA 17013,
and LISA M. CHRISTOPHER, an adult individual and daughter of the alleged
incapacitated person residing at 430 South Pitt Street, Carlisle, PA 17013. Petitioners'
consent to this guardianship was attached to the original petition at Exhibit "A".
2. The alleged incompetent is BETTY M. PETTY, born May 26,1926 (age 81
years), whose permanent residence address is 136 "B" Street, Carlisle, PA 17013. (This
paragraph amends paragraph two of the original petition which incorrectly identified the
alleged incompetent and her permanent residence address.)
3. The alleged incapacitated person became incapacitated and has been unable to
handle her own affairs since at least 2005.
4. The alleged incapacitated person has five children who are her next-of-kin.
Those individuals are Charlotte Brock, Charles Y. Petty, Jr. (one of the petitioners),
Ernest L. Petty, Lisa M. Christopher (one of the petitioners), and Judith A. Smallwood.
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5. Petitioners have no knowledge of any other Court within this Commonwealth,
which has appointed a guardian for the alleged incapacitated person.
6. Prior to the onset of the alleged incapacity, the alleged incapacitated person had
no income except social security and pension funds from her late husband.
7. The alleged incapacitated person is incapable of handling her financial affairs for
the reasons set forth in a competency affidavit, prepared by her treating physician,
Darryl Guiswite, M.D., which statement was attached to the original petition as Exhibit
"8".
8. Petitioners, having no interest adverse to the alleged incapacitated person, have
agreed to act as co-guardians if this Honorable Court shall so appoint.
9. The alleged incapacitated person owns no assets in her own name except her
home.
WHEREFORE, petitioners respectfully request this Honorable Court issue a rule upon
Betty M. Petty, the alleged incapacitated person, with notice thereof to be given to her
next-of-kin, and to such other persons as this Court may direct, to show cause why she
should not be adjudged an incapacitated person and petitioners be appointed co-
guardians of her person and estate.
September 20, 2007
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VERIFICATION
I, Harold S. Irwin, III, Esquire, attorney for the petitioners in this matter, do hereby
depose and state that the facts contained in the foregoing petition are true and correct
to the best of my knowledge, information and belief. I understand that false statements
made herein are subject to the penalties of 18 Pa.C.S.A. Section 4094, relating to
unsworn falsification to authorities.
September 20, 2007
HAROLD S. IRWI
Petitioners