HomeMy WebLinkAbout11-08-07
COURT OF COMMON PLEAS OF CUMBERLAND CO
PENNSYL VANIA
ORPHANS' COURT DIVISION
NO. 2\ -C>( -lOt~
ESTATE OF JEAN A. WOLFE,
AN ALLEGED INCAPACITATED PERSON
Social Security Number
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PETITION FOR ADJUDICATION OF INCAPACITY D
APPOINTMENT OF PLENARY GUARDIAN
OF THE ESTATE AND PERSON
IN ACCORDANCE WITH 20 P A. C.S.A. ~ 5511
TO THE HONORABLE, THE JUDGES OF THE SAID COURT:
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Petitioner, Glenn C. Thompson, respectfully submits this petition to th~ Court for
the appointment of plenary guardians of the person and estate of Jean A. W Olf~, an
The alleged incapacitated person, Jean A. Wolfe, who was born pn
January 4, 1924, is an 83 year old widowed woman and is dOmi~iled in
Pennsylvania, residing at the Church of God Nursing Home, 801 I North
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alleged incapacitated person, and in support thereof avers the following:
Jurisdiction and Venue
1.
Hanover, Carlisle, Cumberland County, Pennsylvania.
2.
Pursuant to 20 Pa. C.S.A. ~5512(b) and (2), this Court has jurisdi tion
over and is the proper venue for the appointment of a guardian 0 the
person and estate of the alleged incapacitated person.
3. No other court has ever assumed jurisdiction in any proceeding to
determine the capacity of the alleged incapacitated person and no dian
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has ever been appointed for the estate or person of the allege
incapacitated person.
Interested Parties
4. Jean A. Wolfe is widowed and has no Surviving children.
5. Petitioner is Jean A. Wolfe's nephew and is the named execut r in her
Last Will and Testament.
6. To the best of Petitioner's knowledge, information and belief, the alleged
incapacitated person's only living adult next-of-kin are as foIl ws:
Nephews:
Glenn C. Thompson
9 Morari Drive
Dillsburg, PA 17019
James A. Wentz
290 North Old Stonehouse Road
Carlisle, P A 17013
David L. Lockard
30 Ann Street
Middletown, P A 17057
Paul L. Wentz
1631 Potato Valley Road
Harrisburg, P A 17112
Richard E. Thornton, Jr.
1902 Antelope Trail
Harker Heights, TX 76548
Nieces:
Victoria E. Lockard
30 Ann Street
Middletown, P A 17057
Patricia Stake
P. O. Box 66
Newville, PA 17241
Bonnidine Zielonis
785 Bremer Road
Dover, PA 17315
Patricia Martin
220 East Locust Street
Mechanicsburg, PA 17055
7. Paul Wentz, the alleged incapacitated person's brother, was th
in-fact under the alleged incapacitated person's previously val d durable
general power of attorney, but Paul Wentz died on May 9, 200 .
8. To the best of Petitioner's knowledge, information and belief, e alleged
incapacitated person had no advance directive, including a he
advance directive, other than her previously executed durable neral
power of attorney which is now invalid, and has never nominat d any
individual or other entity to serve as her guardian in the event 0 her
incapacity.
9.
The alleged incapacitated person was never a member of the
ed
services of the United States and is not receiving benefits from e United
States Veterans' Administration.
Proposed Plenary Guardian
10. Petitioner, the alleged incapacitated person's nephew, who is fi -seven
(57) years of age and a resident of Dillsburg, York County, Pe sylvania,
seeks to be appointed guardian of the estate of the alleged incapa itated
person. Petitioner is a college graduate and is currently employe as a
Police Officer with the Upper Allen Township Police Dep
Mechanicsburg, Pennsylvania. Petitioner's consent to serve guardian of
the person and guardian of the estate of the alleged incapacit ted person is
attached hereto as Exhibit "A".
11. The proposed guardian has no interest adverse to the alleged' capacitated
person.
Factual Back2l'ound/Limitations of Alleged Incapacitated Person
12. The alleged incapacitated person has resided in the Mechanics urg area
her entire adult life.
13. The alleged incapacitated person is suffering from dementia, d is not
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able to care for herself, including feeding, dressing and person I hygiene.
Her ability to receive and evaluate information effectively and
14.
communicate decisions in any way is impaired to such a significant extent
that she is totally unable to manage her financial resources or 1 meet the
essential requirements for her physical health and safety. I
Because oCher age and mental health, the alleged incapacitated rerson.s
condition is not expected to improve.
15.
By letter dated October 25,2007, a copy of which is attached h
Exhibit "B" and incorporated herein by reference, Herbert E. M ers,
M.D., a Psychiatrist who has been treating the alleged incapacit ed
person for many months, has concluded that the alleged incapaci ted
person is unable because of her health and mental condition to h dIe her
financial matters or make decisions about her person.
No Less Restrictive Alternative
16. The following support Petitioner's position that there is no I ss restrictive
alternative to the appointment of a plenary guardian of the p rson and the
estate of the alleged incapacitated person:
a. She has dementia of the Alzheimer type which contin es to
progress and is in the advanced stages; and i
b. She is unaware of where she is, not oriented as to lim1' and is not
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able to make her own health care decisions.
Assets and Income
17. As of this time, the alleged incapacitated person's assets, to th~ extent
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known by Petitioner, are as follows: $247,911.37 maintained rith PNC
Investments, account #5004876061.
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18. To the best of Petitioner's knowledge, information and belief, ~e alleged
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incapacitated person's annual income is approximately $20,001.00 which
she receives in the form of investment income and social securi~y benefit.
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Plenary Guardianship Reauested
19.
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Due to the severity of the alleged incapacitated person's mental I condition,
the lack of viable, less restrictive alternatives necessitate the a,ointment
of a plenary guardian of the alleged incapacitated person's estat~ to
collect, manage and administer all matters concerning her finanfal affairs,
including but not limited to:
her cash, checks and any bank accounts;
her other individually owned property;
payment of medical and other bills incurred t provide her
with proper medical care, insurance and maintenance of her
lifestyle;
handling claims made on behalf of or against er;
execution of documents and entering into con
social security benefits and any other governm tal or non-
governmental benefits;
applying for insurance and/or Medicare or Me icaid
benefits;
20. The severity of the alleged incapacitated person's mental cond tion and the
lack of viable, less restrictive alternatives necessitate the appoi tment of a
plenary guardian of her person to handle all issues relating to h r person,
including but not limited to:
authorizing or withholding consent to medical tr atment or
medication and psychiatric care;
deciding where the alleged incapacitated person ill live,
giving consideration to her lifestyle and her preferences, if known;
arranging for nurses, aides or other personnel for the
alleged incapacitated person's care, as well as for physic and
other therapy;
making decisions about social, recreational and 0 er
personal care matters;
WHEREFORE, Petitioner respectfully requests that this Court aw d a citation
directed to Jean A. Wolfe, the alleged incapacitated person, and to such oth r persons as
this Court may direct, to show cause why Jean A. Wolfe should not be adju goo a fully
incapacitated person, and Glenn C. Thompson appointed plenary guardian fher estate
and plenary guardian of her person.
Respectfully submitted,
R. Mark Thomas, Esqui e
Attorney I.D. No. 41301
101 South Market Street
Mechanicsburg, P A 170 5
Telephone: 717-796-21 0
Attorney for Petitioner
COURT OF COMMON PLEAS OF CUMBERLAND COUNIY'
PENNSYL VANIA
ORPHANS' COURT DIVISION
NO.
ESTATE OF JEAN A. WOLFE,
AN ALLEGED INCAPACITATED PERSON
Social Security Number
CONSENT OF GUARDIAN OF ESTATE
I hereby consent to act as plenary guardian of the estate of Jean A. W lfe,an
Dated:
November 7, 2007
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alleged incapacitated person.
I reside at 9 Morari Dr, Dillsburg, P~ and am aPolice Offic
17019
Upper Allen Police De~ Mechanicsburg , Pennsylvania.
I am a citizen of the United States and can speak, read and write the En !ish
language.
Glerm c. Thanpson
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PE SYL VANIA
ORPHANS' COURT DIVISION
NO.
ESTATE OF JEAN A. WOLFE,
AN ALLEGED INCAPACITATED PERSON
Social Security Number
CONSENT OF GUARDIAN OF PERSON
I hereby consent to act as plenary guardian of the person of Jean A. WolD, an alleged
incapacitated person.
I reside at 9 Morari Dr., Dillsbuflibtd am a Police Officer at
PA 17019
Police Dept. of Mechanicsburg , Pennsylvania.
I am a citizen of the United States and can speak, read and write the Engli h language.
Dated: November 7, 2007
Glenn C. Thanpson
ilhaven
October 25,2007
R. Mark Thomas
Attorney at Law
101 South Market Street
Mechanicsburg, PA 17055-3851
Re: Jean A Wolfe
Church of God Home
Date of Birth: January 4, 1924
Dear Attorney Thomas:
I am responding to your inquiry regarding Jean Wolfe of the Church of God H me. I
have been seeing her for some time as a psychiatric consultant. I understand t t her
brother who was her Power of Attorney is deceased and there is no one else to andle her
affairs.
The above person is not capable of handling her own affairs. She has dementia fthe
Alzheimer type. In May of 2006,s he only managed to score 15 out of30 points n the
MiniMental State Examination. Her dementia has continued to progress so that he is in
the more advanced stages. She is unable to care for herself needing assistance 'th the
activities of daily living. She is unaware of where she is nor is she oriented to ti e. She
could not manage financial affairs nor can she make decisions in regards to her ealth
care. She should clearly have a guardian appointed.
If you have further questions or need further information, please, feel free to con t me.
Sincerely,
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Senior Psychiatrist
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283 South Butler Road. P.O. Box 550. Mr. Grema, PA 17064 . Telephone: 717-273-8871 . Fax: 717-270-2 52 . www.philhaven.org
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VERIFICATION
I, Glenn C. Thanpson , verify that I am the Petitioner in th
petition and that the facts set forth therein are true and correct to the
knowledge, information and belief; and that this verification is subje t to the
penalties of 18 Pa. C.S. g 4904 relative to unsworn falsification to au
Dated:
November 7, 2007