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HomeMy WebLinkAbout03-23-01 (3) .. . . -" " .~ . · zjJOl ~l~RC:~ i3, IN RE: APPOINTMENT OF A GUARDIAN OF THE ESTATE OF MILDRED J. GERBER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 21-01-92 FINDINGS (1) Mildred J. Gerber, born November 9,1914, suffers from dementia that impairs her capacity to make and communicate decisions. (2) Her ability to receive and evaluate information effectively and communicate decisions is impaired to such a significant extent that she is totally unable to manage her financial resources. (3) The estrangement between one of her daughters and her other daughter and son, and the substantial assets in her estate, requires the appointment of a corporate guardian. (4) A plenary guardian of the estate is necessary because her incapacity is permanent. (5) The guardianship must be for an unlimited period. ORDER OF COURT AND NOW, this 22nd day of March, 2001, PNC Bank is appointed plenary guardian of the estate of Mildred J. Gerber. By tl)e Court, / (~ ~, ""- Edgar B. Bayley, J. I MR~-Z1-20¢l 17:42 FROM 5. Marilyn Gerber's subpoena was not served upon Sgt. Brown "reasonably in advance of the date upon which attendance is required" as required by Pa.R.C.P: No.234.3(a). 6. Sgt. Brown has mandatory police training scheduled for the morning of March 22, 2001 in Harrisburg, PA which makes his attendance at the scheduled hearing impossible. 7. The extreme last minute notice of this hearing, due to a current shortage of police officer, puts the City of Harrisburg in the position of not having enough officers scheduled on duty to adequately protect the life and ensure the safety of its residents and property ifSgt. Brown were required to attend this hearing. 8. Due to the last minute notice of this hearing Sgt. Brown has been unable to review his files for notes and reports as requested in the subpoena. 9. Marilyn Gerber's subpoena failed to contain the $5.00 witness fee as mandated by 42 Pa.C.S.A. § 5903(b) or the required mileage. 10. Due to the last minute notice of this hearing, this office has not had an opportunity to discuss this matter with Sgt. Brown. Upon such discussions with Sgt. Brown and other individuals within the Bureau of Public Safety, the City may wish to amend this pleading to assert further grounds upon which to quash this subpoena. WHEREFORE, in view of the foregoing, the CITY respectfully requests that Marilyn Gerber's Subpoena to Attend and Testify issued to City of Harrisburg Sgt. Ralph C. Brown be quashed. Respectfully submitted, Steven R. Dade Deputy City Solicitor Attorney I.D. # 76736 City of Harrisburg Law Bureau - Suite 402 City Government Center 10 North Second Street Harrisburg, PA 1710 ! - 1681 (717) 255-3065 Dated: March 21, 2001 at Harrisburg, Pennsylvania .. .' ~ . . Richard C. Rupp, Esquire For Petitioner Jacqueline M. Verney, Esquire For Mildred J. Gerber Marilyn Gerber, Pro se 42 Drexel Place New Cumberland, PA 17070 :saa VERIFICATION 1, CHARLES KELLAR, Police Chief for the City of Harrisburg, verify that the statements made in the foregoing Motion to Quash Subpoena are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. By: Charles Kellar Date: TOTAL P.07