HomeMy WebLinkAbout10-25-07
BETTY M. PETTY, an alleged
incapacitated person
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS COURT DIVISION
NO. 21-07-0854
GUARDIANSHIP-INCAPACITATED PERSON
IN THE MATTER OF
PETITION FOR SHERIFF'S SERVICE AND PAYMENT ASSISTANCE
AND NOW comes Betty M. Petty, by and through her atto/l1ey, Lorir'f1\ndrew
(- _J
Snyder, Esquire, and avers the following: ~;S
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1. Petitioner is represented by court-appointed counselirf~~ a~e-
captioned matter.
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2. Discovery is necessary regarding the handling of Petit~er's f~ds by
Jamison Christopher, the caretaker of Petitioner's finances. ~,
3. Petitioner intends to depose Mr. Christopher on November 1,2007.
4. Sending a subpoena for Mr. Christopher's attendance at said deposition
via first class mail, certified return receipt, would not produce certification of receipt for
weeks.
5. It is for the benefit for all parties involved that this matter moves forward as
quickly as possible.
6. Sheriffs service will ensure that Mr. Christopher receives the subpoena
and that receipt is confirmed simultaneously.
7. The Honorable J. Wesley Oler, Jr., has been assigned to this matter.
8. Nathan C. Wolf, Esquire, attorney for Charlotte Brock, was contacted and
concurs in this motion.
9. Harold S. Irwin, III, Esquire, attorney for Charles Y. Petty Jr., and Lisa M.
Christopher, could not be reached for his concurrence in this motion.
WHEREFORE, Petitioner respectfully requests this Honorable Court to allow
service of the subpoena on Jamison Christopher by the Cumberland County Sheriffs
Office, the costs of Sheriff's service of said subpoena to be paid by the Cumberland
County Court System.
Respectfully submitted,
1 O/j 5/; 7
Date
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CERTIFICATE OF SERVICE
I hereby certify that I served a true and correct copy of the Petition for Sheriff's
Service and Payment Assistance upon Harold S. Irwin, III, Esquire, and Nathan C. Wolf,
Esquire, by d~positing the same in the United States Mail, first class, postage pre-paid
on the ? ~ 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