HomeMy WebLinkAbout10-23-07
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IN THE MA TIER OF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS COURT DIVISION
BETTY M. PETTY, an alleged
incapacitated person
NO. 21-07-0854
GUARDIANSHIP-INCAPACITATED PERSON
MOTION FOR CONTINUANCE
AND NOW comes Betty M. Petty, by and through her attorney, Lorin Andrew
Snyder, Esquire, and avers the following:
1. Betty M. Petty is the alleged incapacitated person in the above-captioned
matter.
2. A hearing on the Petition for Guardianship filed on behalf of Charles Y.
Petty, Jr., and Lisa M. Christopher is scheduled for October 31, 2007.
3. This continuance is requested in order to allow the necessary time for
discovery and deposition in regard to financial matters, medical history and the new
party that has entered an appearance in this action.
4. Petitioner is in no personal or financial peril in her household and will not
be harmed by the requested continuance.
5. The Honorable J. Wesley Oler, Jr., has been assigned to this matter.
6. Nathan C. Wolf, Esquire, attorney for Charlotte Brock, and Harold S. Irwin,
III, Esquire, attorney for Charles Y. Petty, Jr., and Lisa M. Christopher, were contacted
and concur in this motion.
WHEREFORE, Petitioner respectfully requests this Honorable Court to grant a
continuance in the above-captioned matter for a reasonable time in order to complete
adEf~tlate discovery in this increasingly complex matter.
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Respectfully submitted,
TURO LA OFFICES
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Carlisle, PA 17013
717 -245-9688
Attorney for Petitioner
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CERTIFICATE OF SERVICE
I hereby certify that I served a true and correct copy of the Motion for
Continuance upon Harold S. Irwin, III, Esquire, and Nathan C. Wolf, Esquire, by
depositing the same in the United States Mail, first class, postage pre-paid on the
twenty-third day of October, 2007, from Carlisle, Pennsylvania, addressed as follows:
Harold S. Irwin, III, Esquire
64 South Pitt Street
Carlisle, PA 17013
Nathan C. Wolf, Esquire
Wolf & Wolf
10 West High Street
Carlisle, PA 17013
Lori
28 South P'
Carlisle, P
(717) 245-9688
Attorney for Petitioner