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COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
IN RE:
APPOINTMENT OF A GUARDIAN
OF THE ESTATE OF MILDRED J. GERBER,
an alleged incapacitated person
No. 21.01-92
HEARING MEMORANDUM
INDEX
Pages
LAW
MOTION BY MARILYN J. GERBER
1
PORTfONS OF LAW RE: APPOINTMENT
OF GUARDIAN
1 - 3
WITNESSES FOR PETITIONER
4 - 6
COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
IN RE:
APPOINTMENT OF A GUARDIAN
OF THE ESTATE OF MILDRED J. GERBER,
an alleged incapacitated person
No. 21-01-92
HEARING MEMORANDUM - LAW
I. Opposition to Motion for Continuance. etc.
a. The requirement for twenty days notice applies only to
alleged incapacitated person. 20 Pa. C.S.A. 95511
Marilyn J. Gerber received proper notice - Sheriff
sent notice Certified Mail, Return Receipt Requested,
when unable to serve personally.
Reason for continuance - subpoena fifty witnesses - is
absurd and bizarre.
b. Expert will testify that the alleged incapacitated person
needs a Guardian of the Estate
Emergency Guardianship of the Estate expires
February 24, which would leave the alleged
incapacitated person without a Guardian.
,
c. Marilyn J. Gerber can petition for a review hearing
under 20 Pa. C.S.A. 95512.2.
d. Jacqueline M. Verney, Esquire, counsel for the alleged
incapacitated person concurs with the Petitioner in
opposing the Continuance.
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V.
VI.
II.
20 Pa. C.S.A. ~5511 -
Exhibit A
a.
b.
Clear and convincing evidence
Appointment of guardian
Par. (a)
Par. (f)
III.
20 Pa. C.S.A. ~5512. 1 -
Exhibit B
a. Determination of incapacity
Specific findings of fact
(1) Nature of condition or disability
(2) Extent of capacity to make and
communicate decisions
(3) Need for guardianship services -
availability of family, friends, etc.
(4) Plenary or limited guardian needed
based on nature of condition or
disability and capacity to make and
communicate decisions
(5) Duration of guardianship
(6) Court shall prefer limited guardianship
IV. 20 Pa. C.S.A. ~5518 -
Exhibit C
a. Evidence of incapacity
(1) Nature and extent of alleged incapacities and
disabilities
(2) Mental, emotional and physical condition
(3) Adaptive behavior and social skills
(4) Type of assistance required and why no less
restrictive alternatives would be appropriate
(5) Probability that the person's incapacity may
significantly lessen or change
20 Pa. C.S.A. ~5518.1
Exhibit D
a. Testi~ony of capacity of alleged incapacitated person
subject to cross exam by counsel for alleged incapacitated
person
20 Pa. C.S.A. ~5516 -Guardian's Bonds
Exhibit E
2
VII. Cumberland County Orphans' Court Rules
a.
Rule 14.2- 1 - except for cause shown, relatives of
incompetent shall not be appointed as Guardians
Rule 14.2-2 - statement required to be attached to
Petition under c.C.O.C.R. 12.5-2
Rule 14.2-3 - proofs at Hearing
Rule 14.3- 1 - proof of service of Notice and Petition
b.
c.
d.
e.
Rule 12.5-2 - Statement of Guardian
3
Exhibit G
/I II
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II II
Exhibit H
COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
IN RE:
APPOINTMENT OF A GUARDIAN
OF THE ESTATE OF MILDRED J. GERBER,
an alleged incapacitated person
No. 21-01-92
HEARING MEMORANDUM - WITNESSES FOR PETITIONER
I. David Sabo. Ph.D.
a. Qualification as expert witness
b. Mildred J. Gerber, incapacitated by reason of infirmities of old
age (86 years)
c. Experiences fear caused by daughter, Marilyn
d. Cannot resist pressures by Marilyn
e. Wants to please Marilyn
f. Likely to become victim of designing persons
II Jennifer Conway - PNC Assistant Branch Manager, New Cumberland
Branch, New Cumberland, PA
a. Mildred's bank accounts at PNC Bank
b. Marilyn's actions and demeanor towards Mildred
c. Pressure on Mildred by Marilyn to withdraw monies from
Mildred's PNC Bank accounts
,
d. Attempt by Marilyn to revoke Fred E. Gerber, II, as Mildred's
Power of Attorney (Agent)
e. Badgering of Mildred by Marilyn
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III. Frederick E. Gerber. II
a. MBNA credit card
Balances prior to Marilyn's visit to Mildred's residence
Charges and balances after visit
b. PNC bank accounts
Withdrawals by Marilyn and/or Mildred for Marilyn's
benefit
c. Charles Schwab brokerage account
Attempt by Marilyn to revoke Petitioner as Trustee of
Mildred's Living Trust, the assets of which are invested with
Charles Schwab
d. Personal property
Removal of personal property from Mildred's home by
Marilyn
e. Susceptibility of Mildred to become a victim of designing persons
and need for a Guardian of Mildred's Estate
f. Judicial Notice
Mildred J. Gerber, Plaintiff v. Marilyn Jo Gerber,Defendant
No. 98-4120 Equity, Cumberland County
, Commonwealth v. Marilyn Jo Gerber
No. 98- 1438, Cumberland County
g. Need for Guardian
Previous measures unsuccessful
5
h. Qualifications of Petitioner to be Guardian of the Estate of
Mildred
Colonel in the United States Army
Director of Health Care Services in the office of the U. S.
Surgeon General
Testified many times before Congressional Committees on
health care matters
Is Executor of his father's Will; Trustee of his father's Trust;
named Executor in Mildred's Will; Trustee of Mildred's
living Trust; named Agent in Mildred's Power of Attorney;
named Agent in Mildred's Health Care Power of Attorney.
I. In reo Sylvester 409 Pa. Super. 439 (1991)
20 Pa. C.S.A. ~5604(c)(2) provides that a principal
executing a power of attorney may nominate the Guardian
of his Estate and that the court "shall" appoint the person
so nominated as Guardian of the Estate except for "good
cause or disqualification."
Copy of Mildred's Power of Attorney attached -
Exhibit F
6
~ 5511. Petition and hearing; indepnndent evaluation
(a) Resident.-The court. upon petition and hearing and .upon the presentation of
clear and convincing evidence, may find a person domiciled in the Commonwealth to be
incapacitated and appoint a guardian or guardians of his person or estate. The
petitioner may be any person interested in the alleged incapacitated person's welfare.
The court may dismiss a proceeding where it determines that the proceeding has not
been instituted to aid or benefit the alleged incapacitated person or that the petition is
incomplete or fails to provide sufficient facts to proceed. Written notice of the petition
and hearing shall be given in large type and in simple language to the alleged
incapacitated person. The notice shall indicate the purpose and seriousness of the
proceeding and the rights that can be lost as a result of the proceeding. It shall include
the date. time and place of the hearing and an explanation of all rights, including the
right to request the appointment of counsel and to have counsel appointed if the court
deems it appropriate and the right to have such counsel paid for if it cannot be afforded.
The Supreme Court shall establish a uniform citation for this purpose. A copy of the
petition shall be attached. Personal service shall be made on the alleged incapacitated
person. and the contents and terms of the petition shall be explained to the maximum
extent possible in langnage and tenns the individual is most likely to understand.
Service shall be no less than 20 days in advance of the hearing. In addition, notice of
the petition and hearing shall be given in such manner as the court shall direct to all
persons residing ,vithin the Commonwealth who are sui juris and would be entitled to
share in the estate of the alleged incapacitated person if he died intestate at that time. to
the person or institution providing residential services to the alleged incapacitated
person and to such other parties as the court may direct. including other ser.-ice
providers. The hearing may be closed to the public and without a jury unless the
alleged incapacitated person or his counsel objects. The hearing shall be closed and
with or without a jury if the person alleged to be incapacitated or his counsel so
requests. The hearing may be held at the residence of the alleged incapacitated person.
The alleged incapacitated person shall be present at the hearing unless:
(1) the court is satisfied. upon the deposition or testimony of or sworn statement
by a ph:-'sician or licensed psychologist. that his physical or meiU.al condition would
be harmed by his presence; or
(2) it is impossible for him to be present because of his absence from the
Commonwealth. It shall not be necessary for the alleged incapacitated person to be
represented by a guardian ad litem in the proceeding.
Petitioner shall be required to notify the court at least seven days prior w the hearing if
counsel has not been retained by or on behalf of the alleged incapacitated person. In
appropriate cases, counsel shall be appointed to represent the :illeged incapacitated
person in any matter for which counsel has not been retained by or on behalf of that
individual.
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(b) Nonresident.-The court may find a person not domiciled in the Commonwealth,
having property in the ~ommonwealth, to be incapacitated and may appoint a guardian
of his estate. The appomtment may be made after petition, hearing and notice, as in the
case of a person domiciled in the Commonwealth, or upon the submission of an
exemplified copy of a decree establishing his incapacity in another jurisdiction. The
court shall give preference in its appointment to the foreign guardian of the nonresident
incapacitated person, unless it fmds that such appointment will not be for the best
interests of the incapacitated person.
(c) Payment of certain costs.-If the alleged incapacitated person is unable to pav
for counselor for the evaluation, the court shall order the county to pay these cos~.
These costs shall be reimbursed by the Commonwealth in the following fiscal year.
(d) Independent evaluation.-The court, upon its own motion or upon petition by the
alleged incapacitated person for cause shown, shall order an independent evaluation
which shall meet the requirements of section 5518 (relating to evidence of incapacity).
The court shall give due consideration to ~he appointment of an evaluator nominated by
the alleged incapacitated pe~on.
(e) Petition contents.-The petition, which shall be in plain language. shall include
the name, age, residence and post office address of the alleged incapacitated person, the
names and addresses of the spouse. parents and presumptive adult heirs of the alleged
incapacitated person,. the name and address of the person or institution providing
residential services to the alleged incapacitated person, the names and addresses of
other service providers, the name and address of the person or entity whom petitioner
asks to be appointed guardian, an averment that the proposed guardian has no interest
adverse to the alleged incapacitated person, the reasons why guardianship is sought. a
description of the functional limitations and physical and mental condition of the alleged
incapacitated person, the steps taken to find less restrictive alternatives. the specific
areas of incapacity over which it is requested that the guardian be assigned powers and
the qualifications of the proposed guardian. If a limited or plenary guardian of the
estate is sought, the petition shall also include the gross value of the estate and net
income from all sources to the extent known. .
(0 Who may be appointed guardian.- The court may appoint as guardian any
qualified individual, a corporate fiduciary, a nonprofit corporation. a guardianship
support agency under Subchapter F (relating to guardianship support) or a county
. agency. In t~e case of residents of State facilities, the court may also appoint. only as
guardian of the estate, the guardian office at the appropriate State facility. The court
shall not appoint a person or entity providing residential services for a fee to the
incapacitated person or any other person whose interests conflict with those of the
incapacitated person except where it is clearly demonstrated that no guardianship
support agency or other alternative exists. Any family relationship to such individual
shaH not, by itself. be consider.ed as an interest adverse to the alleged incapacitated
person. If appropriate, the court shall give preference to a nominee of the incapacitated
person.
Amended 1992. Apri116, P.L. 108, No. 24, g 8, effective in 60 days.
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~ 5512.1. Determination of incapacity and appointment of guardian
(a) Determination of incapacity.-In all cases, the court shall consider and make
specific findings of fact concerning:
(1) The nature of any condition or disability which impairs the individual's capacity
to make and communicate decisions.
(2) The extent of the individual's capacity to make and communicate decisions.
(3) The need for guardianship sen;ces, if any, in light of such factors as the
availability of family, friends and other supports to assist the individual in making
decisions and in light of the existence, if any, of advance directives such as durable
powers of attorney or tnlsts. .
(4) The type of guardian. limited or plenary, of the person or estate needed based
on the nature of any condition or disability and the capacity to make and communicate
decisions.
(5) The duration of the guardianship.
(6) The court shall prefer limited guardianship.
. (b) Limited guardian of the person.-Upon a fmding that the person is partially
incapacitated and in need of guardianship services, the court shall enter an order
appointing a limited guardian of the person with powers consistent with the court's
findings of limitations, which may include:
(1) General care, maintenance and custody of the incapacitated person.
(2) Designating the place for the incapacitated person to live.
(3) Assuring that the incapacitated person receives such training, education. medi-
cal and psychological services and social and vocational opportunities. as appropriate.
as well as assisting the incapacitated person in the development of maximum self-
reliance and independence.
(4) Providing required consents or approvals on behalf of the incapacitated person.
(c> Plenary guardian of the person.- The court may appoint a plenary guardian of
the person only upon a fmding that the person is totally incapacitated and in need of
plenary guardianship services.
(d) Limited guardian of the estate.-Upon a finding that the person is partially
incapaCitated and in need of guardianship services. the court shall enter an order
appointing a limited guardian of the estate with powers consistent with the court's
finding of limitations. which shall specify the portion of assets or income over which the
guardian of the estate is assigned powers and duties.
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(e) Plenary guardian of the estate.-A court may appoint a plenary guardian of the
es~te only upon a finding that the person is totally incapacitated and in need of plenary
guardianship services.
(0 No presumption.-No presumption of incapacity shall be raised from the alleged
incapaci~ted person!s institutionalization.
(g) Legal rights retained.-Except in those areas designated by court order as areas
over which the limited guardian has power, a partially incapaciUlted person shall retain
all legal rights.
(h) Information as to rights.-At the conclusion of a proceeding in which the person
has been adjudicated incapaciUlted~ the court shall assure that the person is informed of
his right to appeal and to petition to modify or terminate the guardianship.
1992. April 16, P.L. 108, ~o. 24, ~ 9, effective in 60 days.
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~ 5518. Evidence of incapacity
To establish incapacity, the petitioner must present testimony, in person or by
deposition from individuals qualified by training and experience in evaluating individuals
with incapacities of the type alleged by the petitioner, which establishes the nature and
extent of the alleged incapacities and disabilities and the person's mental. emotional and
physical condition, adaptive behavior and social skills. The petition must also present
evidence regarding the services being utilized to meet essential requirements for the
alleged incapacitated person's physical health and safety, to manage- the person's
financial resources or to develop or regain the person's abilities; evidence regarding the
types of assistance required by the person and as to why no less restrictive alternatives
\vould be appropriate; and evidence regarding the probability that the extent of the
person! s incapacities may significantly lessen or change.
Amended 1992, April 16, P.L. 108, No. 24, g 10, effective in 60 days.
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~ 5518.1. Cross-examination of witnesses
Testimony as to the capacity of the alleged incapacitated person shall be subject to
cross-examination by counsel for the alleged incapacitated person.
1992, April 16, P.L. 108, No. 24, g 11. effective in 60 days.
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~ 5516. Fiduciary estate
The court. in its discretion, upon the application of any party in interest, in addition to
any bond required for the incapacitated person's individual estate, may require a
separate bond in the name of the Commonwealth, with sufficient surety, in such amount
as the court shall consider necessary for the protection of the parties in interest in an
estate of which the incapacitated person is serving in the capacity as a fiduciary and
conditioned in the following fonn.:.
(1) When one guardian.- The condition of this obligation is that, if the said
guardian shall well and trnly account for property held by the incapacitated person as
fiduciary according to law, this obligation shall be void; but otherwise it shall remain
in force.
(2) When two or more guardians.-The condition of this obligation is that, if the
said guardians or any of them shall well and trnly account for property held by the
incapacitated person as fiduciary according to law, this obligation shall be void as to
the guardian or guardians who shall so account; but otherwise it shall remain in force.
Amended 1992, April 16, P.L. 108, No. 24, 9 10, effective in 60 days.
t>iHIGn E
DURABLE POWER OF ATTORNEY
NOTICE
THE PURPOSE OF THIS POWER OF ATTORNEY IS TO GIVE THE PERSON YOU
DESIGNATE (YOUR "AGENT") BROAD POWERS TO HANDLE YOUR PROPERTY,
WHICH MAY INCLUDE POWERS TO SELL OR OTHERWISE DISPOSE OF ANY REAL OR
PERSONAL PROPERTY WITHOUT ADVANCE NOTICE TO YOU OR APPROVAL BY
YOU.
THIS POWER OF ATTORNEY DOES NOT IMPOSE A DUTY ON YOUR AGENT TO
EXERCISE GRANTED POWERS, BUT WHEN POWERS ARE EXERCISED, YOUR AGENT
MUST USE DUE CARE TO ACT FOR YOUR BENEFIT AND IN ACCORDANCE WITH THIS
POWER OF ATTORNEY.
YOUR AGENT MAY EXERCISE THE POWERS GIVEN HERE THROUGHOUT
YOUR LIFETIME, EVEN AFTER YOU BECOME INCAP ACIT A TED, UNLESS YOU
EXPRESSL Y LIMIT THE DURATION OF THESE POWERS OR YOU REVOKE THESE
POWERS OR A COURT ACTING ON YOUR BEHALF TERMINATES YOUR AGENT'S
AUTHORITY.
YOUR AGENT MUST KEEP YOUR FUNDS SEPARATE FROM YOUR AGENT'S
FUNDS.
A COURT CAN TAKE A WAY THE POWERS OF YOUR AGENT IF IT FINDS YOUR
AGENT IS NOT ACTING PROPERLY.
THE POWERS AND DUTIES OF ANY AGENT UNDER A POWER OF ATTORNEY
ARE EXPLAINED MORE FULLY IN 20 Pa. C.S. Ch. 56.
IF THERE IS ANYTHING ABOUT THIS FORM THA T YOU DOD NOT
UNDERSTAND, YOU SHOULD ASK A LAWYER OF YOUR OWN CHOOSING TO
EXPLAIN IT TO YOU.
I HAVE READ OR HAD EXPLAINED TO ME THIS NOTICE AND I UNDERSTAND
ITS CONTENTS.
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P CIP AL
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DA"bE
I, MILDRED J. GERBER of 623 Hilltop Drive, New Cumberland. CLUnberland County,
Pennsylvania hereby appoint my son, Frederick E. Gerber, II, (hereinafter referred to as "agent")
my agent for me and in my name and place. I direct my agent to transact all my business and to
manage all my property and affairs as completely as I myself might do if personally present,
including but not limited to, exercising the following powers.
1. EXECUTION OF CONTRACTS. To enter into. perform. modify, extend,
cancel, compromise, enforce, or otherwise act with respect to any contract of any sort whatsoever
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including but not limited to, leases and mortgages; and to pay any money or to transfer title and
possession to any real or personal property that may be required to be paid or transferred by any
contract or in the performance of any obligation entered into or incurred by me or on my behalf.
2. INVESTMENTS. To invest in all forms of real and personal property without
any restriction whatsoever as to the kind of investments, including, but not limited to, United States
Treasury Bonds which are redeemable at par in payment of federal estate taxes.
3. REGISTRATION OF PROPERTY.
the name of a nominee.
To hold property unregistered or In
4. PERSONAL PROPERTY. To buy or sell at public or private sale for cash or
credit or partly for each, exchange, pledge, lease, give or acquire options for sales or exchanges or
leases, or by any other means whatsoever to acquire, dispose of, repair. alter or manage tangible or
intangible personal property or any in.t~rest therein; and, without limitation, with respect to any
securities, to comply with any securities laws or regulations, to execute indemnity agreements, to
purchase insurance and to pay commissions or discounts required by any underwriting.
5. REAL PROPERTY. To buy or sell at public or private sale for cash or credit or
partly for each, exchange, mortgage, encumber, lease for any period of time. give or acquire options
for sales, purchases, exchanges or leases, dedicate, or by any other means whatsoever; to acquire or
dispose of real property or any interest therein; to partition and subdivide real property; to manage
real property; to repair, alter, erect, or tear down any structure of part thereof: and to file such plans,
applications, or other documents in connection therewith and do such other acts as may be
requested by any government or other authority having or purporting to have jurisdiction.
6. SECURITIES. To vote in person or by proxy at ;my meeting. to join in any
merger. reorganization, voting-trust plan or other concerted action of security holders, to make
payments in connection therewith, and in general to exercise all rights of a s~curity holder.
7. INSURANCE. To procure, alter, extend or cancel insurance against any and
all risks affecting property and persons, and against liability, damage or claim of ;my sort.
8. LOANS. To borrow money in such amounts for such periods and upon such
terms as my attorney shall deem proper and to secure any loan by the mortgage or pledge of any
property, and I specifically autl).orize my attorney to borrow money and pledge property as collateral
for the purpose of purchasing United States Treasury Bonds which are redeemable at par in
payment of federal estate taxes.
9. BANK ACCOUNTS. To sign checks, drafts and other instruments or otherwise
make withdrawals from any checking, savings, transaction or other deposit account in my name,
and to endorse checks payable to me and receive the proceeds thereof in cash or otherwise; to open
and close checking, savings, transaction or other deposit accounts in my name: to purchase and
redeem savings certificates, certificates of deposit or similar instruments in my name: to execute
and deliver receipts for any funds withdrawn or savings certificate. certiticate of deposit or similar
instrument which I now have or may hereafter acquire, the same as I could do if personally present.
Any financial institution may continue to rely on this power of attorney until it receives written
notice from me that this power of attorney is revoked or actual notice of my death and shall be
indemnified and or loss, including lawyers' fees, costs of suit and claims of third parties, which
might incur by relying on this power after termination or revocation but before it receives such
notice, or at any time because of wrongful acts, omissions or representations of my attorney with
respect to transactions covered by this power of attorney. My agent shall be subject to whatever
bank rules and regulations I would be subject to.
10. INDIVIDUAL RETIREMENT ACCOUNT. To request and receive
distributions from any of my Individual Retirement Accounts; to give instructions for the purchase
and sale of securities in those accounts; to execute on my behalf any powers of attorney or other
instruments needed for those purposes; and to endorse notes, checks, drafts and bills of exchange,
and to make contributions to those accounts.
11. SAFE DEPOSIT BOXES. To have access to and control over the contents of
any safe deposit box rented by me, to rent safe deposit boxes in my name, to close out and execute
safe deposit boxes in my name, to close out and execute and deliver receipts for safe deposit boxes
in my name, and to do all acts regarding any safe deposit boxes in my name, which I now have or
may hereafter acquire, the same as I could do if personally present; provided that my agent shall not
deposit or keep in any such safe deposit box any property in which my agent has a personal interest.
Any financial institution may continue to rely on this power of anomey until it receives written
notice from me that this power of attorney is revoked or actual notice of my death and shall be
indemnified and held harmless by me and my estate, personal representatives and heirs against any
liability or loss, including lawyers' fees, costs of suit and claims or third parties. which it might
incur by relying on this power after termination or revocation but before it receives such notice, or
at any time because of wrongful acts, omissions or representations of my agent with respect to
transactions covered by this power of attorney. My agent shall be subject to whatever bank rules
and regulations I would be subject.
12. RECEIPTS AND APPROVAL OF ACCOUNTS. To receive a payment of any
. kind, including a bequest, devise, gift or other transfer of real or personal property to me in my own
right or as a fiduciary for another, and to give full receipt and acquinance therefor. or a refunding
bond therefor, to approve accounts of any business, estate, trust, partnership or other transaction
whatsoever in which I may have any interest of any nature whatsoever. and to enter into any
compromise and release in regard thereto.
13. COMPROMISE AND ARBITRATION OF CLAIMS. To compromise or
arbitrate any claim in which I may be in any manner interested, and for that purpose to enter into
agreements to compromise or arbitrate, and either through counselor otherwise to carry on such
compromises or arbitration and perform or enforce any award entered in arbitration.
14. INSTITUTION AND DEFENSE OF CLAIMS. To institute. prosecute,
defend, compromise, or otherwise dispose of, and to appear for me in. any proceedings at law or in
equity or otherwise before any tribunal for the enforcement or for the defense of any claim, either
alone or in conjunction with other persons, relating to me or to any property of mine or any other
person (including the authority to sue if this power of attorney is not honored), and to retain,
r:2,
discharge and substitute counsel and authorize appearance of such counsel to be entered for me
in any such action of proceedings.
15. TAXES. To prepare, execute and file in my name and on my behalf any
return, report, protest, application for correction of assessed valuation of real or other property,
appeal, brief, claim for refund, or petition, including petition to the United States Tax Court, in
connection with any tax imposed or purported to be imposed by any government, authority or
agency, or claimed, levied or assessed by any government, authority or agency and to pay any such
tax and to obtain any extension of time for any of the foregoing; to execute waivers of restrictions
on the assessment and collection of deficiency in any tax; to execute closing agreements and all
other documents, instruments and papers relating to any tax liability of mine of any sort; to institute
and carry on either through counselor otherwise any proceeding in connection with contesting any
such tax or to recover any tax paid, or to resist any claim for additional tax or any proposed
assessment or levy thereof, and to enter into any agreements of stipulations for compromise of other
adjustment or disposition of any tax.
16. DISCLAIMER. To execute, deliver and file or record disclaimers of any part
or all of any property, power or interest passing to or for me under any will. deed of trust or
otherwise.
17. EMPLOYMENT OF OTHERS. To employ accountants. attorneys-at-law,
investment counsel, custodians, agents, servants, and others. and to delegate to them, to remove
them, and to pay them such remuneration as my attorney shall deem proper.
18. REVOCABLE TRUST TO BE CREATED. To execute any revocable
deed of trust on my behalf under the terms of which (i) my agent or anyone or more other persons
or corporations with fiduciary powers selected by my agent is named as the trustee or trustees, (ii)
during my lifetime the entire net income and as much principal as 1. my agent or my trustee thinks
is desirable shall be paid to me or for my benefit (including those I am legally obligated to support),
and (iii) upon my death the principal and any undistributed income shall be payable to the executor
or administrator of my estate; and to transfer property to the trustee or trustees thereunder.
19. REVOCABLE TRUSTS PREVIOUSLY CREATE D. To add any property to
any revocable deed or trust executed by me for my benetit even through the trust may not be
payable upon my death to my estate and to revoke in whole or in part any such trust.
20. GUARDIAN 'OF THE PERSON AND ESTATE. For the purpose of recording
my wishes in convenient place, I record here that if it is necessary to appoint a guardian of my
person or a guardian of my estate it is my desire that my agent be appointed.
21. GIFTS. To make gifts which do not exceed mv annual federal gift tax
exclusion or other tax exempt gift.
22. GENERAL. To do all things which my agent shall deem proper in order to carry
out any of the foregoing enumerated powers, which shall be construed in the broadest possible
manner. In no event shall my agent take any action concerning a policy of insurance on my agent's
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life. The descriptive headings of this general power of attorney are inserted for convenience only
and shall not be deemed to affect the meaning or construction of any of the provisions hereof or to
limit in any way the construction thereof in the broadest possible manner.
23. SUBSTITUTION. My agent shall have the full power of substitution and
revocation, and such substitution or revocation may relate to, or be limited to, anyone or more or
all foregoing acts or powers, or be limited as to time or in such other respect as my agent shall deem
proper.
24. RA TIFICA TION. I hereby ratify and confirm all that my agent or the substitute
or substitutes therefor shall lawfully do or cause to be done by virtue hereof.
25. RELIANCE BY OTHERS. This power of attorney shall continue in force and
may be accepted and relied upon by anyone to whom it is presented despite my purported
revocation of this power, the age of this power, the issuance of a court decree declaring my
incompetency or my death, until written notice of such event is received by such person.
26. EFFECT OF MY DISABILITY. This power of attorney shall not be affected
by my disability or incapacity and shall specifically continue after such disability and incapacity.
27. GOVERNING LAW. This power of attorney shall be governed by and
interpreted in accordance with Pennsylvania law.
Dated i Cl (Ja'UUL'I..(f ,2001.
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Witnesses: Jc<-""'"
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MILDRED J. GE~ER
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COMMONWEAL TH OF PENNSYLVANIA
SS.
COUNTY OF CUMBERLAND :
. On this i1 d day of ~~ ' 200 I, before me the undersigned
officer, personally appeared Mildred J. erber, kno to me (or satIstactory proven) to be the
person whose name is subscribed to the foregoing instrument, and acknO\vledged that she executed
it for the purpose therein contained.
Witness my hand and official seal the day and year aforesaid.
'-1{t*t~dJ
N tary Public
NOTAR'ALSEAL
KATHlEEN K. SHAUlIS, Notat~ PUblic
Carlisle Bora. Cumberland COunty
My Commission Expires Dec. 22. 2003
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STATEMENT OF GUARDIAN
Rule 12.5-2.
The petition shall have attached thereto, in addition
to consent of the guardian, a statement of the guard-
ian with respect to the following matters:
(1) that the proposed guardian, if an individual, is a
citizen of the United States of America, and is able to
speak, read and write the English language;
(2) if the proposed guardian is an individual and if
the proposed guardian. and the minor reside in the
same household, that it is not the intention of the
guardian to apply for an allowance for the support or
education of the minor during minority;
(3) that the proposed guardian is not the Fiduciary
or an officer or employee of a corporate Fiduciary of
an estate in which the minor has an interest nor the
surety or an officer or an employee of the corporate
surety of such a Fiduciary, and that the proposed
guardian has no interest adverse to the minor.
Note: See PEF Code ~~5111 to 5113, inclusive.
Adopted May 15, 1990, effective July 1, 1990.
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