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HomeMy WebLinkAbout01-1112 ~ I I ... f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INRE: OLIVER BUNTING : NO. 21-2001-1112 ORDER AND NOW, this ~ day of January, 2002, after hearing, and upon consideration of Marilyn Chubb's and Susan B. Bianchi's Petition for Adjudication of Incapacity and Appointment of Plenary Guardian of the Estate and Person of Oliver Bunting, the Court finds that Oliver Bunting, who suffers from senile dementia, hypertension and advanced Parkinson's disease, is unable to make, communicate or participate in any decision relating to his estate or person; that he is totally incapacitated; and that there is no less restrictive alternative to provide for his care than to appoint a plenary guardian of his estate and person. Accordingly, his daughters, Marilyn Chubb and Susan B. Bianchi, are appointed plenary guardians of the person and the estate of Oliver Bunting. Marilyn Chubb and Susan B. Bianchi, as Guardians, shall have full authority and responsibility to manage and use Oliver Bunting's property for his benefit, and to make all necessary decisions concerning his medical care. Each may act independently on Mr. Bunting's behalf. Marilyn Chubb and Susan B. Bianchi are relieved of their obligation to file a bond with the Court pursuant to 20 Pa.C.S.A. S 5122(d). Oliver Bunting, an incapacitated person, has the right to appeal this order of court by filing exceptions within ten (10) days of this date or to petition this court for a review hearing to modify or terminate the guardianship herein established. Oliver Bunting may .. I be represented by counsel in connection with any such appeal or review, and counsel will be appointed for him upon request if he is indigent and unable to afford counsel. BY THE COURT: J. ':f - f:-,.. .~ (i Dte 0 6 2001 ~f) i~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: OLIVER BUNTING : NO. 21- 0' - " I 2. PRELIMINARY DECREE FOR GUARDIAN ~ AND NOW, this ~ day of ~ tf!I# ,20 tJ t, to judicially resolve Petitioners' request for the appointment of a guardian, the Court does hereby ORDER AND DECREE the following: 1. The Court hearing on the attached Petition is scheduled for the r ~ay of ~ ~O{):t-- , at 3. uVo'clock -fJm. The hearing will be held before Judge /futy to JJf~ Courtroom No. J , located in the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. The Court directs the issuance of an appropriate Citation with Rule to Show Cause why the above-captioned individual should not be adjudged an incapacitated person and why the Court should not appoint an appropriate guardian(s). 3. Petitioners shall cause to be served by personal service the Citation and Petition with attached important notice upon the alleged incapacitated person at least twenty (20) days prior to the Court hearing. The contents and terms of the Petition and the Notice shall be explained to the maximum extent possible in language and terms the alleged incapacitated person is most likely to understand. An affidavit of service shall be filed before the hearing or offered as an exhibit at the beginning of the Court hearing. ..... I .J . I . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA IN RE: OLNER BUNTING : NO. 2.1 - 0 I -I J I 2- PETITION FOR ADJUDICATION OF INCAPACITY AND APPOINTMENT OF PLENARY GUARDIANS OF THE ESTATE AND PERSON OF OLIVER BUNTING IN ACCORDANCE WITH 20 Pa.C.S. ~ 5511 AND NOW comes the Petitioners, Marilyn M. Chubb and Susan B. Bianchi ("Petitioners"), who, by and through their attorneys, Charles O. Beckley, IT, Esquire, Thomas S. Beckley, Esquire, and Beckley & Madden, of Counsel, file this Petition for Adjudication of Incapacity and Appointment of Plenary Guardians of the Estate and Person of Oliver Bunting in Accordance with 20 Pa.C.S. 9 5511, and in support thereof aver as follows: 1. Petitioners are Marilyn M. Chubb and Susan B. Bianchi, daughters of Oliver Bunting, the alleged incapacitated person. 2. Oliver Bunting was born on October 17, 1915, is 86 years of age, is married to Florence R. Bunting, and resides at Claremont Nursing and Rehabilitation Center, 375 Claremont Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. The following persons are, to the best of Petitioners' knowledge, information and belief, the only living next-of-kin of Oliver Bunting: Florence R. Bunting (wife) Messiah Village .. /' '1 # I 100 Mount Allen Drive Mechanicsburg, Pennsylvania 17055 Marilyn M. Chubb (daughter) 1017 Meadowview Court Harrisburg, Pennsylvania 1 7111 Susan B. Bianchi (daughter) 147 Somerset Drive Hershey, Pennsylvania 17033 Bruce K. Bunting (son) 31176 Gordon Drive Exeter, California 93221 4. The name and address of the institution providing the care of and residential services for Oliver Bunting is the following: Claremont Nursing and Rehabilitative Center 375 Claremont Drive Carlisle, Pennsylvania 17013 5. To the extent known by Petitioners, the assets of Oliver Bunting are valued at approximately $9,000.00, which is the amount remaining in a trust established by his father who is deceased. 6. Petitioners estimate Oliver Bunting's monthly income to be approximately $1,574.23, which includes $1,437.00 in social security benefits, $36.23 from an insurance policy, and $101.00 from a VA pension account. All of this income goes directly to the Claremont Nursing and Rehabilitation Center to pay for Mr. Bunting's care. In addition, Florence Bunting, Oliver Bunting's wife, receives a monthly payment from Mr. Bunting's pension in the amount of$515.93. This pension comes in the name of Oliver Bunting. 2 . J . I 7. Oliver Bunting has suffered from Alzheimer's and Parkinson's disease for the past nine years and is unable to care for himself in any capacity. He has been a resident of Claremont Nursing and Rehabilitation Center for approximately nine years. 8. Because of his condition, Oliver Bunting is totally unable to manage his financial affairs, property and business and to make responsible decisions relating thereto, and he lacks the ability to communicate his need for assistance in these areas. 9. Oliver Bunting granted a power of attorney to his wife, Florence R. Bunting, on October 29,1992. A true and correct copy of this power of attorney is attached hereto as Exhibit A. 10. Upon information and belief, Florence Bunting will renounce the power of attorney given to her by Oliver Bunting upon the appointment of Marilyn Chubb and Susan Bianchi as guardians for Oliver Bunting's estate and person. 11. To Petitioners' knowledge, a plenary guardianship is the only remaining alternative to care for Oliver Bunting and his estate. 12. The severity of Oliver Bunting's condition and the lack of viable, less restrictive alternatives necessitate that a plenary guardian of his estate be appointed to manage and handle all aspects of Oliver Bunting's estate, specifically including, but not limited to: all issues relating to his cash, checks, and any bank or savings account held in his name, his stocks and bonds, his personal property, his real estate, his life and other insurance of which he is a beneficiary, his entitlement to any governmental and non-governmental benefit plans, federal, state, and local taxes, claims made or to be made on behalf of him or against him, the execution of documents, entry into contracts 3 ~. affecting him, and the payment of reasonable compensation or costs to provide services to him. 13. The severity of the Oliver Bunting's condition and the lack of viable, less restrictive alternatives necessitate that a plenary guardian of his person be appointed to handle all issues relating to Oliver Bunting's person, specifically including, but not limited to: his living arrangements, his medical and psychiatric care, the administration of medication to him, and the employment and discharge of physicians, psychiatrists, dentists, nurses, therapists and other professionals for his physical and mental treatment and care. 14. The proposed plenary guardians of the person and the estate of Oliver Bunting are Marilyn Chubb, a daughter of Oliver and Florence Bunting, who resides at 1017 Meadowview Court, Harrisburg, Pennsylvania 17111, and Susan B. Bianchi, also a daughter of Oliver and Florence Bunting, who resides at 147 Somerset Drive, Hershey, Pennsylvania 17033 15. The proposed plenary guardians have no interests adverse to Oliver Bunting. 16. The consents of Marilyn M. Chubb and Susan B. Bianchi are incorporated herein, made a part hereof, and attached hereto as Exhibit B. 17. No other court has ever assumed jurisdiction in any proceeding to determine the capacity of Oliver Bunting. 18. No other guardian has been appointed for the estate or person of Oliver Bunting. 4 ~ 19. Marilyn Chubb and Susan Bianchi are willing and able to serve as guardians of the person and estate of Oliver Bunting. True and correct copies of their resumes are incorporated herein and attached hereto as Exhibit C. WHEREFORE, Petitioners, Marilyn M. Chubb and Susan B. Bianchi, respectfully request that this Court award a citation directed to Oliver Bunting, the alleged incapacitated person, and to such other persons as this Court may direct, to show cause why Oliver Bunting should not be adjudged a fully incapacitated person, and Marilyn M. Chubb and Susan B. Bianchi appointed plenary guardians of his person and estate. DATED: December 4,2001 Respectfully submitted, Of Counsel ..... BECKLEY & MADDEN 212 North Third Street Post Office Box 11998 Harrisburg, Pennsylvania 17108-1998 (717) 233-7691 <7 ~-<-f~ Thomas S. Beckley, Esquire Attorneys for Petitioners Marilyn M. Chubb and Susan B. Bianchi 5 ;..: VERIFICATION I, Marilyn M. Chubb, hereby state that I am an adult individual, that I have read the foregoing document, and that the facts set forth in the foregoing document are true to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. ~tu ~i iW aJer Marilyn M. ctbb '- , . , , .J,.'. 1. . #' j . I.: EXHIBIT A LAW OFFICES OF STEPHEN J. HOGG 401 E. lOUTHER STREET CARLISLE. PA 17013 .. I .. POWER OF ATTORNEY I, OLIVER BUNTING, of 100 stoner Drive, Mechanicsburg, Cumberland County, Pennsylvania, currently a patient in the Mechanicsburg Rehab Hospital, Mechanicsburg, Cumberland County, Pennsylvania, do hereby nominate, constitute and appoint, my wife, FLORENCE R. BUNTING, of 100 stoner Drive, Mechanicsburg, Cumberland County, Pennsylvania, as my true and lawful Attorney-In-Fact, to act in my name, place and stead to do and perform any act that I myself might perform if I were personally present in regard to the following: To endorse checks, notes, drafts and any other commercial papers ~n my name and to withdraw money from any bank accounts that I may have for my benefit, and to sign orders or receipts therefore in my name; To enter into any safe deposit box I may have in my own name or jointly with another person to inventory the contents of such box or to do or perform any act with respect to the contents that I might legally perform if I were personally present. To grant, bargain, sell and convey my real property or any part thereof for such price and on such terms and conditions as he shall deem proper, with or without the taking back of a purchase money mortgage or deed of trust and to collect and receive the proceeds from any sale; To enter into any contract or contracts for the sale of the premises, or any part thereof with such persons and on such terms as she shall in her discretion elect and to execute, acknowledge and deliver in my name such deeds or conveyances, with such covenants and conditions as she may deem proper, that may be required for the transfer of said property or any part thereof or of any interest therein: To execute a mortgage or deed of trust on my real property in such amount and on such terms and conditions as she may deem necessary and proper and to sign, execute and deliver, in my name or otherwise, such instruments as may be required in connection with obtaining the mortgage or deed of trust, and to do any other acts as I might or could do in obtaining the mortgage or deed of trust on the property; To sell and enter into a contract or contracts for the sale of all or any party of my personal property, effects and belongings of every kind and nature wherever situated for my benefit with full power to deliver possession of said personal property and to execute in LAW OFFICES OF lTEPHEN J. HOGG m1 E. LOUTHER STREET CARLISLE, PA 17013 l my name any documents necessary to transfer title to said personal property, including bills of sale or other documents of title, and to take any security interest for any unpaid balance which my Attorney-In-Fact in her discretion may deem necessary and proper; To borrow money from such sources and on such terms as my Attorney may deem fit and proper, and to execute in conjunction with any loan of money a security agreement covering any of my real or personal property and to execute, sign, acknowledge and deliver in any form that instrument that may be required in conjunction with the transaction; To authorize my admission to medical, nursing, residential or similar facility and to enter into agreements for my care. This power is to be construed and implemented in accordance with the provisions of Chapter 56 of Title 20, Consolidated Pennsylvania statutes in effect on the date of execution of this Power of Attorney; To authorize medical and surgical procedures. This power is to be construed and implemented in accordance with the provisions of Chapter 56 of Title 20, Consolidated Pennsylvania statutes in effect on the date of execution of this Power of Attorney. I direct that this Power of Attorney shall be a durable Power of Attorney and shall become effective immediately upon execution by the grantor above. Date: /0 -:2-'1 r r;~ ~VE~ING _~s~ ~L_ witness LAW OFFICES OF STEPHEN J. HOGG 401 E. lOUTHER STREET CARLISLE, PA 17013 Commonwealth of Pennsylvania ss County of Cumberland On the ~9 day of &L';fJ1A_) , 1992, before me, the undersigned officer, personally appeared OLIVER BUNTING, known to me or satisfactorily proven to be the person whose name is subscribed to the attached Power of Attorney, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission expires: ~1i~",-Q ,00-'---0 Nr~.~~liC ... '~~.'.:~. \. \ t." . - -. . . .... Pl. I I" "J ',j,~ ~/_-=-~_~_~'- .'-~ .-.:.::.....:: '..- l4. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INRE: OLIVER BUNTING : NO. CONSENT OF GUARDIAN OF THE ESTATE AND PERSON I, Marilyn M. Chubb, hereby consent to act as the Guardian of the Estate and Person of Oliver Bunting. I reside at 1017 Meadowview Court, Harrisburg, Pennsylvania 17111. I am a citizen of the United States of America and can speak, read and write the English language. Oliver Bunting is my father, and I have no interest adverse to him. ~~~,~ Marilyn . ubb Sworn and subscribed to befo71me this /~-dayof . Nove ber,2001 Notarial Seal Craig A. Etter, Notary Public Lower Swatara Twp., Dauphin County My COmmission Expires Oct. 8. 2002 Member, PenngylVania AssocIation ot Notaries ~.~ , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INRE: OLNER BUNTING : NO. CONSENT OF GUARDIAN OF THE ESTATE AND PERSON I, Susan B. Bianchi, hereby consent to act as the Guardian of the Estate and Person of Oliver Bunting. I reside at 147 Somerset Drive, Hershey, Pennsylvania 17033. I am a citizen of the United States of America and can speak, read and write the English language. Oliver Bunting is my father, and I have no interest adverse to him. j~~ 8. ~~Mr~ Susan B. Bianchi Sworn and subscribed to before me this ...~t" day of November, 2001 (SEAI,) I NOTARIAL SEAL JOYCE A CARROll. Notary Public City of Harrisburg, Dauphin County ~ Commission Expires Dec. 27, 2001 l. I I .(lei I '-'" . I . .. 1II \ EXHIBIT C CAREER OBJECTIVE EDUCATION April 1990 June 1982 1981 1979 1976 EXPERIENCE September 1991 - Present May 1991 - August 1991 April 1989 - May 1991 July 1986 - April 1989 December 1985 - July 1986 August 1985 - December 1985 It/ MARILYN M. CHUBB 1017 Meadowview Court Harrisburg, Pa. 17111 (717) 939-8521 Responsibility for merchandising and/or marketing in a growth environment, with potential for advancement. totes, Inc. Manager Training Program Pomeroy's Executive Training Program B.A. in History, Millersville State College A.A. in Retailing, Harrisburg Area Community College Graduated - Mechanicsburg Area High School (Maternity Leave) totes. Outlet Division. (Rockv.le Sau.re). Lancaster Pa. Store Manager Full responsibility for opening a new selling unit (IE - ordering of inventory, office supplies and sundries, merchandising and setting Floor plan for entire store, organization of stock room, initial programming of computerized check-out terminals, hiring staff of ten). Also same as below, but with ultimate responsibility for sales quota. tote.. Outlet Division. (Centeryllle Road). Lancaster. Pa. Assistant Manager; Store Manager-in-Training Managed, scheduled, hired and reviewed staff of five sales and stock associates. Communicated weekly with central buying office as to inventory needs and problems. In charge of preparation and adual stock count of yearly inventory. Responsible for all Floor displays, merchandising and Fixturing. Attended yearly corporate sales meetings. . Pomeroy's DeDarlment SIore. Harrlsbura. Pa. Buyer of 0-24 months RTW, Giftware, and Bedding. Responsible for a volume of $1,500,OOO.~ for all twelve stores. Balance monthly open-to-buy budget. Reconcile purchase journals monthly and inventory twice-yearly. Coordinate with Advertising Department on all promotions and special events. Supervised conversion from manual to computerized point- of-sale data collection system. Experienced with Wang and IBM distributed systems for sales reporting. Pomerov's DeDarlment SIore. Harrlsbura Pa. Assistant Buyer of Newborn-Toddler RTW, Infants Furniture and Accessories. Managed and scheduled staff, merchandised selling floor, coordinated semi- annual inventory, wrote returns-to-vendor, charge-backs and purchase orders. Responsible for accuracy of monthly vendor and classification on order. Pomeroy's DeDarlmenl Store. Harrlsbura. Pa. Assistant Buyer of Girls 4-14 and Accessories. (Similar duties to above position.) .'1 ~.. I May 1983 - August 1985 Pomeroy's D.partment Store. CamD Hili Pa. Area Sales Manager of the 'Clubhouse' and 'Petites Place' departments. Managed a staff of eight sales associates; including monthly scheduling and personnel reviews. Prepared for and supervised a twice-yearly inventory. Responsible for preparation of a monthly merchandise review and actual merchandising of an approximately $100,000 inventory on the selling floor. Processed and supervised all departmental price changes. January 1982 - May 1983 Pomeroy's OeDartment Store. Harrlsbura. Pa. Assistant Buyer of Budget Lingerie and Accessories. Managed, scheduled and reviewed a staff of four sales associates. Responsible for writing purchase orders for customer special orders from five branch stores. Responsible for maintaining accuracy of monthly computerized inventory. Responsible for monthly accounting of orders outstanding. Responsibie for ordering promotional signs for branch stores. Responsible for return to vendors of all damaged or misdirected merchandise for all five branch stores. September 1981 -January 1982 Pomeroy'. DeDartment Store Camp Hili. Pa. Area Sales Manager of the Children's Department. (Same duties as above position with a staff of twelve sales associates.) August 1976 - June 1981 Pomeroy's OeDartment Store. CamD Hili Pa. Sales Associate, starting with a WorklCo-Op program from Harrisburg Area Community College. Sales experience in the Junior, Ladies Sportswear. Budget, Mens' Hosiery and 'Lifestyle' departments. Responsible for waiting on customers and operating cash register. Helped with merchandise inventory and presentation. OCT. 29.2001. 5: 27Pt'1 1'10 . 2'30 I' ,-, lie.. . , ,. ~ -. . .. . susAN BUNTING BIANCHI 147 Somerset Drive Hershey PA 17033 Phone: 717-533-9897 or 717-561-7664 Fax: 717-533-4552 Emml: susan.bianc~i~~ranscore,ccrn orsubianchi@a~:.com Education: CDP ~ Certification in Data Processing. Jeep, 1981 M.S., Library & Information Science, Drexel University, 1974 B.A., Biology, Wilson College~ 1972 Summary: MIS Manager / Senior Systems Analyst - 27 years working with the identification, organization, analysis and dissemination of information. Experience with transaction logging systems design, proposal writing, customer service software support, customer reporting, budgeting, configuration management) writing detailed design specifications, writing procedure manualst joint applications developmentt software testing, data warehouse design & construction, requirements definition. Professional Experience: Senior Systems Analyst TransCore I PA Turnpike Commission, Toll Host, 2001- Administer project problem tracking software - TeamTrack™. Worked closely with the vendor to customize this software for our use. Coordinate issue tracking for the project team and the customer. Facilitate requirements gathering meetings to define Phase 4 of the Toli Host Upgrade. Document decisions and Action Items. Participate in designing data storage and system architecture. Help produce technical documentation. Serve a.s backup test manager. Serve as administrative point of contact for the work group. Senior Systems Analyst TransCore I P A Turnpilte Commission. E-ZPass, 1998 - 2000 Facilitated joint development of operational requirements for a Customer Service Center (incorporating a Violations Processing Center) to support Electronic ToU Collection (E..ZPass) on the P A Turnpike. Managed requirements documentation. Developed and documented the decision process and the design specifications. Worked with the customer to interpret systems structures and functions to dleir management. Developed user acceptance test plans & successfully carried them out. Wrote procedure manuals for the CustOl1.l.er Service Center. OutRes200 I.doc OCT.29.2001. 5:27PM rKi . 290 F'. .3 ., 'I ,. .. . ... . SUSAM BUNTING BIANCHI Professional Experience: Senior Documentation Specialist SAle I CSX Railroads, 1997-98 Led the documentation support team for a Y2K post-remediation testing project covering all major systems at a rail freight camer. Defined Configuration Management processes & files. Wrote & maintained Test Planning Guidelines. Developed Access database for project support. Systems Engineer SAle I State of Indiana Family & Social Service Administration, 1997 Analyzed human services legacy systems to locate, identify and define data to meet Federal Welfare Refonn reporting requirements. Assisted in the design and implementation of a data warehouse. Assisted with Configuration Management. As a result of this project, Indiana was one of fewer than 10 states to submit acceptable data to DHI-iS on the first required reporting date in 1997 I Director, Information Systems The Precertification Center, 1985..1997 Had nlajor input to product developn1ent, marketing, customer service and provider relations decisions in addition to full responsibility for Information Systems. Supervised MIS support and account reporting. Supervised and evaluated hardware purchase, installation and maintenance. Supervised and evaluated quality assurance and product performance reporting using Focus and SAS. Prepared proposals in response to major RFPs. Responsible for design, development and maintenance of the on-line precertification and disability software systems in CIeS. These systenls support call center encounter logging and medical necessity detennination for medicalt surgical, diagnostic~ psychiatric and rehabilitation procedures. Responsible for an annual $250,000. departmental budget with signature authority to $10,000. Prepared the 53,000,000. annual corporate budget over a period of more than 10 years. Senior Project Analyst Pennsylvania Blue Shield, 1984..85 Developed Second Surgical Opinion Referral Center procedures, reports, forms and databases. Responsible for management reporting, staff traini11.g and system design. Supervised system start..up for the precertification product. Evaluated program perfonnance at one year for publication in Business and Health. 2 OutRes200 I.doc OCT. 29.2001 . 5: 28Pt1 N~.290 F'.4 .'1 --..- . ..'" SUsAN BUNTING BIANCHI Professional Experience: Manager, Corporate Research Pennsylvania Blue Shield, 1981-83 Supervised 10 to 15 analysts using a data warehouse plus other resources to provide decision support to corporate management through payout studiest account reporting & studies of proposed changes in benefits. Maintained the corporate data warehouse containing l.lp to ten years of health care utilization infonnation. Implemented a departmental project tracking system. Consulted on statistical analysis software & 4GLs, including SAS & SPSS, Senior Research Analyst Pennsylvania Blue Shield, 1980.81 Created multivariate models for longitudinal analyses of physicians' fees. Provided database & statistical computing support for cross-sectional anal)rses of physician pricing practices & patterns of \\tilization, Designed a model to test a series of alternative physician reimbursement systems. Consulted on research analysis. Senior Technical Ana1)1st Hershey Medical Center, 1917-79 Supervised data entry and analysis at the Sleep Research and Treatment Center. Collected data from clinical drug trials of sedativelhypnotic pharmaceuticals. Designed, constructed & maintained an integrated database for 10 years of case records. Analyzed research data from studies of nonnal & disturbed sleep using SPSSt SAS and BMDP, Information Specialist Lederle Laboratories, 1974.76 Compiled computerized indexes to worldwide data on pharmaceutical products. Produced bibliographies of drug literature. Identified & assembled drug safety &. efficacy data for submission to foreign & US regulatory agencies. 3 OutRes200 I.doc OCT.29.2001 · 5:29PM ~iO . 2'30 P.5 .. · 1 ......' .. -_ . .. susAN BUNTING BIANCHI Computer Proficiency: TeamTrack™, Focus, SAS, MS Wor~ Excel, PowerPoint, Access, Outlook, Visio, \VordPerfect~ Harvard Graphics, MacWritePro, Excel (Mac version), MacLink Plus, JeL, CICS screen design. Professional. Associations: DPMA President Central P A Chapter 1990 Special Chapter Service Award 1987 Association Outstanding Newslettel' Award 1986 Newsletter Editor 1984-88 Publications: TransCore Travelogues; Cruising J ournal- Part 2, The Bridge (TransCore's Intranet Newsletter), Vol. 2, Issue 4, August/September 2001. TransCore Travelogues; Cruising the Rideau Waterway, The Bridge (TransCore's Intranet Newsletter), Vol. 2, Issue 3, June/July 2001. PenDsylvania Turnpike Commission E-ZPass Customer Service Center. General Procedures & Reference Guide. TransCore Document 70000016, Version 1.Ot October 2000. Pennsylvania Turnpike Commission Electronic Toll Collection System. CSC Commissioning Test Plan. TransCore Docwnent 70000017, Version 1.1, August 2000. Penllsylvania Turnpike Commission. Detailed Design Document. ETC CSC &. VPC System. TransCore Document 700D0003 , Version 1.1, April 2000. Pennsylvania Turnpike Commission. Customer Service Center. Operations Requirements. VESNPC System. TransCore Document 700D0002, Version 1.2, April 1999 . Pennsylvania Turnpike Commission. Customer Service Center. Operations Requirements. ETC System. TransCore Docl.Unent ?OODOOO 1 , Version 1.7, October 1998. Hobbies: Photography & Scrapbooks, Baking, Reading, Singing. 4 OutRes200 1.doc IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: OLIVER BUNTING : NO. 21-2001-1112 AFFIDA VlT OF SERVICE OF PETITION UPON OLIVER BUNTING I, Thomas S. Beckley, Esquire, verify that I made personal service of a copy of the within Citation With Notice, the Preliminary Decree, and the Petition, copies of which are annexed hereto, upon Oliver Bunting, by causing to be read the Citation and explaining the same to and leaving a copy thereof with Oliver Bunting on Thursday, December 20, 2001, at the Clairemont Nursing and Rehabilitative Center, Carlisle, Pennsylvania. The above statements are made subject to the penalties of 18 Pa.C.S.A. ~ 4904 relating to unsworn falsification to authorities. DATED: December 20,2001 ~~~/ Thomas S. Beckley Sworn and subscribed to before rne this 20th day of Dteember, 2001. . .1 nc; - --. ..- ('tI 3 ~" C,T ",l (,) d - ::0 :O(tr (l: 0 ':c:', () i:,' ,;;;: o C"':J N - (SEAL) ~--_. NOTARIAL SEAL . ELIZABETH S. BECKLEY, Ndary PubIc Harrisburg, De.uphin County, PA t!~~g,?!"lmlssion Expires MardI 12. Z)06 U Lv -.....J IN RE: OLIVER BUNTING IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION : NO. 21-2001-1112 IMPORTANT NOTICE CITATION WITH NOTICE A petition has been filed with the Court to have you declared an Incapacitated Person. If the Court finds you to be an Incapacitated Person, your rights will be affected, including our right to manage money and property and to make decisions. A copy of the petition which has been filed by MARILYN CHUBB AND SUSAN B. BIANCHI is attached. You are hereby ordered to appear at a hearing to be held in Court Room No. 3 JUDGE GEORGE E. HOFFER, Cumberland County Courthouse, Carlisle, Pennsylvania, on JANUARY 9 ,2002, at 3:00 p.m. _M. to tell the Court why is should not find you to be an incapacitated Person and appoint a Guardian to act on your behalf. To be an incapacitated Person means that you are not able to receive and effectively evaluate information and communicate decisions and that you are unable to manage your money and/or other property, or to make necessary decisions aboufwhere you will live, what medical care you will get, or how your money will be spent. At the hearing, you have the right to appear, to be represented by an attorney, and to request a jury trial. If you do not have an attorney, you have the right to request the Court to appoint an attorney to represent you and to have the attorney's fees paid for you if you cannot afford to pay them yourself. You also have the right to request that the Court order that an independent evaluation as to your alleged incapacity. If the Court decides that you are an Incapacitated person, the Court may appoint a Guardian for you, based on the nature of any condition or disability and your capacity to make and communicate decisions. The Guardian will be of your person and/or your money and other property and will have either limited of full powers to act for you. If the court finds you are totally incapacitated, your legal rights will be affected and you will not be able to make a contract or gift of your money to other property. If the court finds that you are partially incapacitated, your legal rights will also be limited as directed by the Court. If you do not appear at the hearing (either in person or by an attorney representing you) the court will still hold the hearing in your absence and may ap~poi~t the Guardian requested. Jv-' ___., ,-,', , ,'\ r'\ I '\ ~ : " ':. I. .,' I: "I ^ \ By: n (it Lt l / ..\\-.-V(,l,GI :z,ll, In f}v(), ULDp I Clerk, 0 hans Court DIvision / Cumberland County, Carlisle, P A My Commission Expires 1st Monday, January, 2002 -- &I'~ ~ DEe 0 6 2001~P L /' . ,~ /-~ I I ~-J - ;~ ~..RE. ~ < 0 I ~ g g . OLNER BUNTING .co.. 0 U5 o E ai C\I'10-\ () a:: "(;3 f- -~ '" o ~ i: r.:- ,_t: ia ~ ~'"J ,m ~! e- >:: W 0 v," I I () ;v a: . ~ ~- 0'-.oJ I -...,/ I ~::) ~ ~ ("J ~ -->1 ~ E O 0 t:'~o ~~ ::J '- :J .... 0:2 I::; ok- ~huU lJ.. -- co) .:C> ---: I ~ ~ 6:15~'~~c3 ~ ~ o OJ C:? . "0 ~ (J -f.: '0 ',~ ,-.> AND NOW, this day of , 20 f) I, to J.udicially resolve w>- - g f ~.; :..." 'Petitioners' request for the appointment of a guardian, the Court does hereby ORDER q: ;;:; .:; -- f -:J, -- ~ -g -.) ---AND DECREE the following: co ' ~ ....J c .c~--J - 1-;- -.. ,) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 21-01-"/2.. PRELIMINARY DECREE FOR GUARDIAN 1. The Court hearing on the attached Petition is scheduled for the tj ~ay of ~ 200 J--. at 3. .vo'clock -IJm. The hearing will be held before Judge ~y tJ . Courtroom No. J , located in the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. The Court directs the issuance of an appropriate Citation with Rule to Show Cause why the above-captioned individual should not be adjudged an incapacitated person and why the Court should not appoint an appropriate guardian(s). 3. Petitioners shall cause to be served by personal service the Citation and Petition with attached important notice upon the alleged incapacitated person at least twenty (20) days prior to the Court hearing. The contents and terms of the Petition and the Notice shall be explained to the maximum extent possible in language and terms the aneged incapacitated person is most likely to understand. An affidavit of service shall be filed before the hearing or offered as an exhibit at the beginning of the Court hearing. .. . -~ /--": ~ - - '!!!!!!!! iiii - I 4. At least fifteen (15) days notice of the petition and hearing shall be given by personal service or certified mail to all persons who would be entitled to share in the estate of the alleged incapacitated person's estate if he died intestate. 5. Petitioners shall notify the Court, in writing, at least seven (7) days pri~ to the Court hearing if counsel has NOT been retained by or on behalf of the alleged incapacitated person. 6. The alleged incapacitated person shall be present at the Court hearing unless it is established that his physical or mental condition would be harmed by his presence, or it is impossible for him to be present because of his absence from the Commonwealth. BY THE COURT: J. - . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV~ IN RE: OLIVER BUNTING : NO. 1 J - 0 I -I J J L . PETITION FOR ADJUDICATION OF INCAPACITY AND APPOINTMENT OF PLENARY GUARDIANS OF THE EST ATE AND PERSON OF OLIVER BUNTING IN ACCORDANCE WITH 20 Pa.C.S. ~ 5511 . AND NOW comes the Petitioners, Marilyn M. Chubb and Susan B. Bianchi ("Petitioners"), who, by and through their attorneys, Charles O. Beckley, II, Esquire, Thomas S. Beckley, Esquire, and Beckley & Madden, of Counsel, file this Petition for Adjudication of Incapacity and Appointment of Plenary Guardians of the Estate and Person of Oliver Bunting in Accordance with 20 Pa.C.S. 9 5511, and in support thereof aver as follows: 1. Petitioners are Marilyn M. Chubb and Susan B. Bianchi, daughters of Oliver Bunting, the alleged incapacitated person. 2. Oliver Bunting was born on October 17, 1915, is 86 years of age, is married to Florence R. Bunting, and resides at Claremont Nursing and Rehabilitation Center, 375 Claremont Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. The following persons are, to the best of Petitioners' knowledge, information and belief, the only living next-of-kin of Oliver Bunting: Florence R. Bunting (wife) Messiah Village -.. .-. . _.__. - - -.==...-_..~,~;:;,:..",;-~ ~'~'oC.'tz;::.:: ---"~~Rji~~':...~d;jlJthrrli - ...~'.tA~~~~~:~: 'il,~~~:].1 zji_t1'..L.i ..:----~. lJ .~. -.:', ~,~:,';;"~..lL" ~,~~~tk 100 Mount Allen Drive Mechanicsburg, Pennsylvania 17055 Marilyn M. Chubb (daughter) 1017 Meadowview Court Harrisburg, Pennsylvania 1 7111 . . Susan B. Bianchi (daughter) 147 Somerset Drive Hershey, Pennsylvania 17033 Bruce K. Bunting (son) 31176 Gordon Drive Exeter, California 93221 4. The name and address of the institution providing the care of and residential services for Oliver Bunting is the following: Claremont Nursing and Rehabilitative Center 375 Claremont Drive Carlisle, Pennsylvania 17013 5. To the extent known by Petitioners, the assets of Oliver Bunting are valued at approximately $9,000.00, which is the amount remaining in a trust established by his father who is deceased. 6. Petitioners estimate Oliver Bunting's monthly income to be approximately $1,574.23, which includes $1,437.00 in social security benefits, $36.23 from an insurance policy, and $101.00 from a VA pension account. All of this income goes directly to the Claremont Nursing and Rehabilitation Center to pay for Mr. Bunting's care. In addition, Florence Bunting, Oliver Bunting's wife, receives a monthly payment from Mr. Bunting's pension in the amount of$515.93. This pension comes in the name of Oliver Bunting. 2 _______ ...___ ~ - '.. -0. ..... _ - --"-~,-"'l. ~._';.2,:~,~gii7~::r;.1;~ ,;.Jt~.....:.....:~ 't%rL.J !i:8:,.J. -u f"-........."~.~"'--~........_~'..,.....lIfoad........ .- ~ '-", ~-'-';;'~.....,. '... <. ~. ~."- 7. Oliver Bunting has suffered from Alzheimer's and Parkinson's disease for the past nine years and is unable to care for himself in any capacity. He has been a resident of Claremont Nursing and Rehabilitation Center for approximately nine years. 8. Because of his condition, Oliver Bunting is totally unable to manage his financial affairs, property and business and to make responsible decisions relating thereto, and he lacks the ability to communicate his need for assistance in these areas. . 9. Oliver Bunting granted a power of attorney to his wife, Florence R. Bunting, on October 29, 1992. A true and correct copy of this power of attorney is attached hereto as Exhibit A. 10. Upon information and belief, Florence Bunting will renounce the power of attorney given to her by Oliver Bunting upon the appointment of Marilyn Chubb and Susan Bianchi as guardians for Oliver Bunting's estate and person. 11. To Petitioners' knowledge, a plenary guardianship is the only remaining alternative to care for Oliver Bunting and his estate. 12. The severity of Oliver Bunting's condition and the lack of viable, less restrictive alternatives necessitate that a plenary guardian of his estate be appointed to manage and handle all aspects of Oliver Bunting's estate, specifically including, but not limited to: all issues relating to his cash, checks, and any bank or savings account held in his name, his stocks and bonds, his personal property, his real estate, his life and other insurance of which he is a beneficiary, his entitlement to any governmental and non-governmental benefit plans, federal, state, and local taxes, claims made or to be made on behalf of him or against him, the execution of documents, entry into contracts 3 - "._-......:.......... . ._~...;;.:;.- ..--", . -;:.:.-....'"- '" ;.'~r1~1::1tti!;g'C.'.. .-.. J,,;,; ~\-l~lT~.~f:!Jrq~1f.~ -- ~-"""~"'-~",~~"",,<...~,<,, affecting him, and the payment of reasonable compensation or costs to provide services to him. 13. The severity of the Oliver Bunting's condition and the lack of viable, less . restrictive alternatives necessitate that a plenary guardian of his person be appointed to handle all issues relating to Oliver Bunting's person, specifically including, but not limited to: his living arrangements, his medical and psychiatric care, the administration of medication to him, and the employment and discharge of physicians, psychiatrists, dentists, nurses, therapists and other professionals for his physical and mental treatment and care. 14. The proposed plenary guardians of the person and the estate of Oliver Bunting are Marilyn Chubb, a daughter of Oliver and Florence Bunting, who resides at 1 0 17 Meadowview Court, Harrisburg, Pennsylvania 17111, and Susan B. Bianchi, also a daughter of Oliver and Florence Bunting, who resides at 147 Somerset Drive, Hershey, Pennsylvania 17033 15. The proposed plenary guardians have no interests adverse to Oliver Bunting. 16. The consents of Marilyn M. Chubb and Susan B. Bianchi are incorporated herein, made a part hereof, and attached hereto as Exhibit B. 17. No other court has ever assumed jurisdiction in any proceeding to determine the capacity of Oliver Bunting. ~ 18. No other guardian has been appointed for the estate or person of Oliver Bunting. ---, 4 --- ----.---..--....-~---"-......,...,,.."':,.'__...;c,__.- -. '--~~~c--'---'-'=F7'!,~'~,,~~a~'it.._~ 'Ill~ji~~;'..;j~ ....~.--..t ... or ~ ~. 'l;- ;.... . '_.' ~ ~ . 't'1~1-' .t.tn~.ii-n t1/li"='''.... 19. Marilyn Chubb and Susan Bianchi are willing and able to serve as guardians of the person and estate of Oliver Booting. True and correct copies of their resu!TIes are incorporated herein and attached hereto as Exhibit C. . WHEREFORE, Petitioners, Marilyn M. Chubb and Susan B. Bianchi, respectfully request that this Court award a citation directed to Oliver Bunting, the alleged incapacitated person, and to such other persons as this Court may direct, to show cause - ;. why Oliver Bunting should not be adjudged a fully incapacitated person, and Marilyn M. Chubb and Susan B. Bianchi appointed plenary guardians of his person and estate. ! i DA TED: December 4, 2001 Respectfully submitted, Of Counsel ... BECKLEY & MADDEN 212 North Third Street Post Office Box 11998 Harrisburg, Pennsylvania 17108-1998 (717) 233-7691 ~ ~4'7~~ Thomas S. Beckley, Esquire Attorneys for Petitioners Marilyn M. Chubb and Susan B. Bianchi 5 ,..' -,...~- ......... ......:'~!J".w..~~...."' ';"~'~~'.i'lf'f~:~.?W~~~..tllt"I' "';'I~"I.ftl""_l' ~ &~ · :""Mt-', l '.l . .,' · , ".,,"',".' .~ ~.. ',,- - " '.' .- '-'~-- ~ - ~'." r~,1:.b" ;;..J-'J.l....1i- _ _ - . ,,)'< - - ;...~r ::..... tltt~"'); ".dJ,.;f'<:<<:<' VERIFICATION I, Marilyn M. Chubb, hereby state that I am an adult individual, that I have read the foregoing document, and that the facts set forth in the foregoing document are tn~ to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. . Qu4tau~ Marilyn M. C ubb ... . LAW OFFICES OF STEPHEN J. HOGG 401 E. LOUTHER STREET CARLISLE. PA 17013 . !;:if, ~'.. .' o.;!", ,! .'~ ~::-:;.;~!.-!-';' '. " ,:01. ~:...~ ."'. POWER OF ATTORNEY I, OLIVER BUNTING, of 100 Stoner Drive, Mechanicsburg, cumberland County, Pennsylvania, . currently a patient in the Mechanicsburg Rehab Hospital, Mechanicsburg, cumberland County, Pennsylvania, do hereby nominate, constitute and appoint, my wife~ PLORENCE R. BUNTXNG, of 100 stoner Drive, Mechanicsburg, cumberland County, Pennsylvania, as my true and lawful Attorney-In-Fact, to act in my name, place and stead to do and perform any act that I myself might perform if I were personally present in regard to the following: To endorse checks, notes, drafts and any other commercial papers in my name and to withdraw money from any bank accounts that I may have for my benefit, and to sign orders or receipts therefore in my name; To enter into any safe deposit box I may have in my own name or jointly with another person to inventory the contents of such box or to do or perform any act with respect to the contents that I might legally perform if I were personally present. To grant, bargain, sell and convey my real property or any part thereof for such price and on such terms and conditions as he shall deem proper, with or without the taking back of a purchase money mortgage or deed of trust and to collect and receive the proceeds from any sale; To enter into any contract or contracts for the sale of the premises, or any part thereof with such persons and on such terms as she shall in her discretion elect and to execute, acknowledge and deliver in my name such deeds or conveyances, with such covenants and conditions as she may deem proper, that may be required for the transfer of said property or any part thereof or of any interest therein: To execute a mortgage or deed of trust on my real property in such amount and on such terms and conditions as she may deem necessary and proper and to sign, execute and deliver, in my name or otherwise, such instruments as may be required in connection with obtaining the mortgage or deed of trust, and to do any other acts as I might or could do in obtaining the mortgage or deed of trust on the property; To sell and enter into a contract or contracts for the sale of all or any party of my personal property, effects and belongings of every kind and nature wherever situated for my benefit with full power to deliver possession of said personal property and to execute in ......_..;.,'..r;~ my name any documents necessary to transfer title to said personal property, including bills of sale or other documents of title, and to take any security interest for any unpaid balance which my Attorney-In-Fact in her discretion may deem necessary and proper; To borrow money from such sources and on such terms as my Attorney may deem fit and proper, and to e4ecute in conjunction with any loan of money a security agreement covering any of my real or personal property and to execute, sign, acknowledge and deliver in any form that instrument that may be required in conjunction with the transaction: ... To authorize my admission to medical, nursing, residential or similar facilitv and to enter into agreements for my care. This power is to be construed and implemented in accordance with the provisions of Chapter 56 of Title 20, Consolidated Pennsylvania statutes in effect on the date of execution of this Power of Attorney; To authorize medical and surgical procedures. This power is to be construed and implemented in accordance with the provisions of Chapter 56 of Title 20, Consolidated Pennsylvania statutes in effect on the date of execution of this Power of Attorney. I direct that this Power of Attorney shall be a durable Power of Attorney and shall become effective immediately upon execution by the grantor above. Date: /0 . :2-'1 ,. f/ ~, ~VE~rNG ~)rud r3uwJL. witness LAW OFFICES OF STEPHEN). HOGG 401 E. LOUTHER STREET CARLISLE. PA 17013 --.--- _._----~---~".... ..~.._.- .( - LAW OFFICES OF STEPHEN J. HOGG 401 E. lOUTHER STREET CARLISLE. PA 17013 Commonwealth of Pennsylvania ss county of Cumberland . On the ~9 day of &L;nfA_) , 1992, before me, the undersigned officer, personally appeared OLIVER BUNTING, known to me or satisfactorily proven to be the person whose name is subscribed to the attached Power of Attorney, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission expires: ~1J~A-Q.~{.; Notary Public.. __--, f-.- ----..: -, - ,'.';,. \ .' . . - . ~ - . . .~ .- n.~. i ..~r. - ..--- , . _; .1_...:.... 1714 I :',' .' .-" - . .-- ~1~OJ ___-- . - '..... --;;,;~;~, l,'....:-;.;~~_;"":.-,.i C;-'" ~._ '.:'.;"~:'--;-~~~~.- -~-- '-'" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: OLIVER BUNTING : NO. ~ CONSENT OF GUARDIAN OF THE ESTATE AND PERSON I, Marilyn M. Chubb, hereby consent to act as the Guardian of the Estate and Person of Oliver Bunting. I reside at 101 7 Meadowview Court, Harrisburg, Pennsylvania 1 7111. I am a citizen of the United States of America and can speak, read and write the English language. Oliver Bunting is my father, and I have no interest adverse to him. ~~~~ Marilyn . ubb Notarial Seal Craig A. Etter, Notary Public Lower Swatara Twp., Dauphin CountY My Commission Expires Oct. 8, 2002 Member, Penrl9Ylvania Association ot Notaries - ~------------------ ----._-~~----------------~----~---~--- ---------~~------- ~------------ --------~---- J-:i:".,..,....,.x;..:"'.,-"j". " . ~~_:~t .~<r ~...--; 1.;.~)ri:t.~_N~ ':" -""~.~..:.,i...,._,:.. '~~"--.:~ _~~~j ,;..; ~-- ,_;.~ J. .. ~ ..~ + ..., ...' . ..... - .. ..~. ... ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: OLIVER BUNTING NO. ~ CONSENT OF GUARDIAN OF THE EST A TE AND PERSON . I, Susan B. Bianchi, hereby consent to act as the Guardian of the Estate and Person of Oliver Bunting. I reside at 147 Somerset Drive, Hershey, Pennsylvania 17033. I am a citizen of the United States of America and can speak, read and write the English language. Oliver Bunting is my father, and I have no interest adverse to him. jl\~ 8. f1~Mr~ Susan B. Bianchi Sworn and subscribed to before me this ,,~th day of November, 2001 (SEA~) NOTARIAL SEAL JOYCE k CARROLL, Notary Public City of Harrisburg, Dauphin County M Commission Expires Dec. 27. 2001 .....,- _T"T,~-r-~"" ;'f~", ,....,..'r.~: CAREER OBJECTIVE EDUCATION - . ~ April 1990 June 1982 1981 1979 1976 EXPERIENCE September 1991 - Present May 1991 - August 1991 April 1989 - May 1991 July 1986 - April 1989 December 1985 - July 1986 August 1985 - December 1985 MARILYN M. CHUBB 1017 Meadowview Coun Harrisburg. Pa. 17111 (717) 939-8521 Responsibility for merchandising and/or marketing in a growth environment. with potential for advancement. ~ totes. Inc. Manager Training Program Pomeroy's Executive Training Program B.A. in History. MilIersville State College A.A. in Retailing. Harrisburg Area Community College Graduated - Mechanicsburg Area High School (Maternity Leave) totes. Outlet Division. (Rockvale Sauare}. lancaster. Pa. Store Manager Full responsibility for opening a new selling unit (IE - ordering of inventory, office supplies and sundries. merchandising and setting Floor plan for entire store, organization of stock room. initial programming of computerized check-out terminals, hiring staff of ten). Also same as below. but with ultimate responsibility for sales quota. totes. Outlet Division. ICentervllle Road}. Lancaster. Pa. Assistant Manager; Store Manager-in- Training Managed, scheduled. hired and reviewed staff of five sales and stock associates. Communicated weekly with central buying office as to inventory needs and problems. In charge of preparation and adual stock count of yearly inventory. Responsible for all Floor displays. merchandising and Fixturing. Attended yearly corporate sales meetings. Pomeroy's DeDartment Store. HarrisburG. Pa. Buyer of 0-24 months RlW. Giftware. and Bedding. Responsible for a volume of $1.500.000.im for all twelve stores. Balance monthly open-to-buy budget. Reconcile purchase journals monthly and inventory twice-yearly. Coordinate with Advertising Department on all promotions and special events. Supervised conversion from manual to computerized point- of-sale data collection system. Experienced with Wang and IBM distributed systems for sales reporting. PomeroY's DeDartment Store. Harrlsbura. Pa. Assistant Buyer of Newborn-Toddler RlW. Infants Furniture and Accessories. Managed and scheduled staff. merchandised selling floor, coordinated semi- annual inventory, wrote returns-to-vendor. charge-backs and purchase orders. Responsible for accuracy of monthly vendor and classification on order. Pomeroy's DeDartm.nt Star.. Harrlsbura. Pa. Assistant Buyer of Girls 4-14 and Accessories. (Similar duties to above position.) >>.t. .; I ..i,..... ::it--~-_-:. :;. .t.":;-i,,:~-xii~;,-~...H.-~ir.i.:......l..~~l.lii..>'" ........:~. _ May 1983 - August 1985 Pomeroy'. DeD."me"t Store C.""D HIli P. Area Sales Manager of the 'Clubhouse' and 'Petites Place' departments. Managed a staff of eight sales associates; including monthly scheduling and personnel reviews. Prepared for and supervised a twice-yearly inventory. Responsible for preparation of a monthly merchandise review and actual merchandising of an approximately $100,000 inventory on the selling floor. Processed and supervised all departmental price changes. January 1982 - May 1983 Pomeroy's OeDartment Store. Harrlsbura Pa. Assistant Buyer of Budget Lingerie and Accessories. . Managed, scheduled and reviewed a staff of four sales associates. Responsible for writing purchase orders for customer special orders from five branch stores. Responsible for maintaining accuracy of monthly computerized inventory. Responsible for monthly accounting of orders outstanding. Responsibie for ordering promotional signs for branch stores. Responsible for return to vendors of all damaged or misdirected merchandise for all five branch stores. . September 1981 - January 1982 Pomeroy's DeDartment Stora CamD Hili. Pa. Area Sales Manager of the Children's Department. (Same duties as above position with a staff of twelve sales associates.) August 1976 - June 1981 Pomeroy'. DeDartmant Store. CamD Hili. Pa. Sales Associate, starting with a WorklCo-op program from Harrisburg Area Community College. Sales experience in the Junior, Ladies Sportswear. Budget, Mens' Hosiery and 'Lifestyle' departments. Responsible for waiting on customers and operating cash register. Helped with merchandise inventory and presentation. ~~~~~_if~~~. 147 Onl Hershey PA 17033 Phone: 717-533-9897 or 717-561-7664 Fax: 717-533-4552 Etn~l: susan.bianc~i~~ransCQre.ccrn orsub~anchi~a~:.com ~tc _, Education: CDP, Certification in Data Processing, ICep, 1981 M.S., Library &. Information Science, Drexel University: 1974 B.A., Biology, Wilson College! 1972 Summary: MIS Manager I Senior Systems Analyst - 27 years working with the identification, organization, analysis and dissemination of information. Experience with transaction logging systems design, proposal writing, customer service software support, customer reporting, budgeting, configuration management, writing detailed design specifications, writing procedure manuals, joint applications development, software testing, data warehouse design & construction, requirements definition. Professional Experience: Senior Systems Anal)'st TransCore I P A Turnpike Commission, Toll Host, 2001 - Administer project problem tracking software - TeamTrackD4. Worked closely with the vendor to customize this software for our use. Coordinate issue tracking for the project team and the customer. Facilitate requirements gathering meetings to define Phase 4 of the Toli Host Upgrade. Document decisions and Action Items. Participate in designing data storage and system architecture. Help produce technical documentation. Serve as backup test manager. Serve as administrative point of contact for the work group. Senior Systems Analyst TransCore I P A Turnpike Commission. E-ZPass, 1998 - 2000 Facilitated joint development of operational requirements for a Customer Service Center (in(~orporating a Violations Processing Center) to support Electronic Toll Collection (E-ZPass) on the P A Turnpike. Managed requirements documentation. Developed and documented the decision process and the design specifications. Worked with the customer to interpret systems structures and functions to their management. Developed user acceptance test plans & successfully carried them out. Wrote procedure manuals for the Custonler Service Center. OutRes200 I.doc Professional Experience: Senior Documentation Specialist SAlC I CSX Railroads, 1997-98 Led the documentation support team for a Y2K post-remediation testing project covering all major systems at a rail freight carrier. Defined Configuration Management processes & files. Wrote & maintained Test Planning Guidelines. Developed Access database for project suppon. Systems Eneineer sAle I State of Indiana Family & Social Service Administration, 1997 ,.. ~ Analyzed human services legacy systems to locate, identify and define data to meet Federal Welfare Reform reporting requirements. Assisted in the design and implementation of a data warehouse. Assisted with Configuration Management. As a result of this project, Indiana was one of fewer than 10 states to submit acceptable data to DHHS on the first required reporting date in 1997. Director, Informstion Systems The Precertification Center, 1985.1997 - I Had major input to product development, marketing, customer service and provider relations decisions in addition to full responsibility for Information Systems. Supervised MIS suppon and acCOWlt reporting. Supervised and evaluated hard\\rare purchase, installation and maintenance. Supervised and evaluated quality assurance and product performance reponing using Focus and SAS. Prepared proposals in response to major RFPs. Responsible for design, development and maintenance of the on-line precertification and disability software systems in CICS. These systems support call center enco1U1ter logging and medical necessity determination for medical, surgical, diagnostic~ psychiatric and rehabilitation procedures. Responsible for an annual $250,000. departmental budget with signature authority to S10,OOO. Prepared the S3,OOO,OOO. annual corporate budget over a period of more than 10 years. Senior Project Analyst Pennsylvania Blue Sbield, 1984..85 Developed Second Surgicat Opinion Referral Center procedures, reports, forms and databases. Responsible for management reporting, staff training and system design. Supervised system start-up for the precertification product. Evaluated program performance at one year for publication in Business and Health. 2 OutRes200 I.doc --.~ -----~-~--- Professionsl Experience: Manager t Corporate Research Pennsylvania Blue Shield, 1981-83 Supervised 10 to 15 analysts using a data warehouse plus other resources to provide decision support to corporate management through payout studies. account reponing ~ studies of proposed changes in benefits. Maintained the corporate data warehouse containing up to ten years of health care utilization information. Implemented a departmental project tracking system. Consulted on statistical analysis software & 4GLs, including SAS &. SPSS. Senior Research Analyst Pennsylvania Blue Shield, 1980..81 . Created multivariate models for longitudinal analyses of physicians' fees. Provided database & statistical computing support for cross-sectional anal)pses of physician pricing practices & patterns of utilization. Designed a model. to test a series of alternative physician reimbursement systems. Consulted on research analysis. Senior Technical Analyst Hershey Medical Center, 1977-79 Supervised data entry and analysis at the Sleep Research and Treatment Center. Collected data from clinical drug trials of sedativelbypnotic pharmaceuticals. Designed~ constructed & maintained an integrated database for 10 years of case records. Analyzed research data from studies of nonnal & disturbed sleep using SPSS. SAS and BMDP. Information Specialist Lederle Laboratories, 1974-76 Compiled computerized indexes to world\Vide data on phannaeeutical products. Produced bibliographies of drug literatW'e. Identified & assembled drug safety &. efficacy data for submission to foreign & US regulatory agencies. 3 OutRes200 I.doc ~.-lId" '-4 ,,' ... '" ~~.. .D.., "4....' :t .,i.'j.... 4-~.......'"&. . T Computer Proficiency: TeamTrackN, Focus, SAS, MS Word, Excel, PowerPoint, Access, Outlook, Visio, \VordPerfect~ Harvard Graphics, MacWritePro, Excel (Mac version), MacLinlc Plus, JCL, CICS screen design. Professional. Associations: .. DPMA President Central P A Chapter 1990 Special Chapter Service A ",,-ani 1987 Association Outstanding Newsletter Award 1986 Newsletter Editor 1984-88 Publications: TransCore Travelogues; Cruising Journal - Part 2, The Bridge (TransCore's Intranet Newsletter), Vol. 2, Issue 4, August/September 2001. TransCore Travelogues; Cruising the Rideau Watenvay, The Bridge (TransCore's Intranet Newsletter), Vol. 2, Issue 3, June/July 2001. Pennsylvania Turnpike Commission E-ZPass Customer Service Center. General Procedures & Reference Guide. TransCore Docwnent 700D0016, Version 1.0, October 2000. Pennsylvania Turnpike Commission Electronic Toll Collection Syst~m. CSC Commissioning Test Plan. TransCore Document 70000017, Version 1.1, August 2000. Pennsylvania Turnpike Commission. Detailed Design Document. ETC CSC &, VPC System. TransCore Document 700D0003, Version 1.1, April 2000. Pennsylvania Turnpike Commission. Customer Service Center. Operations Requirements. VESNPC System. TransCore Document 700D0002, Version 1.2, April 1999 . Pennsylvania Turnpike Commission. Customer Service Center. Operations Requirements. ETC System. TransCore Document 700DOOO 1 , Version 1.7, October 1998. Hobbies: Photography & Scrapbooks, Baking, Reading, Singing. 4 OutRes200 I.doc '... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INRE: OLIVER BUNTING : NO. 21-2001-1112 AFFIDAVIT OF SERVICE OF PETITION UPON BRUCE BUNTING, FLORENCE R. BUNTING AND CLAREMONT NURSING AND REHABILITATION CENTER I, Thomas S. Beckley, Esquire, verify that I made personal service of a copy of the Citation With Notice, the Preliminary Decree, and the Petition, upon Bruce Bunting by certified mail at his home address, and upon Florence R. Bunting by handing a true and correct copy to her, and upon Claremont Nursing and Rehabilitation Center by handing a copy to the person in charge. Service was made upon each party mentioned on December 20, 2001. The above statements are made subject to the penalties of 18 Pa.C.S.A. S 4904 relating to unsworn falsification to authorities. DA TED: January 9, 2002 /7 ~~ Thomas S. Beckley Sworn and subscribed to before me this 9th day of January, 2002. L~J..J~9' J,,,~ 'Notary Public / NOTARIAL SEAL Geraklne J. ScrbaQic, Notary PublIc CIty of Harrtsburg, Oe.uphtn County _~ ~.!"tssIon expires Nov. 18, 2002 :J(") - ..".. =w :j ~. S:r ~ ~ (SEAL) C- :J;::> z I \,Q v I'.J o co :JJ ro II'j~lt I.... () ~~:"! () .~:) -., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COUNTY, PENNSYL VANIA INRE: OLNER BUNTING No. 21-2001-1112 AFFIDA VIT OF DAVID R. WENNER, D.O. I, David R. Wenner, D.O., am a licensed physician in the C0111monwealth of Pennsylvania. I do hereby swear or affirm within a reasonable degree of medical certainty to the following: 1. I am currently the primary care physician for Oliver Bunting. Mr. Bunting has been in my care since January, 2001. Mr. Bunting is residing at the Claremont Nursing and Rehabilitation Center in Carlisle, Pennsylvania. 2. Mr. Bunting is 86 years old. He suffers from senile dementia, hypertension and quite advanced Parkinson's disease. 3. Due to Mr. Bunting's illnesses, he is unable to communicate verbally or participate physically in any of the activities that occur at the Claremont facility. His daily activities are extrelnely limited. He is unable to an1bulate amI must be transport~J in a wheelchair and lift. 4. Mr. Bunting is currently in stable condition, however, I do not expect his condition to improve. To the contrary, in my opinion, Mr. Bunting's condition will worsen over time. P€t ifldlV €.R 's EXHmIT #/ ,.CJ(}:J. I'r' 71; ~ 5. In my professional medical OpInIOn, Mr. Bunting's ability to receIve and evaluate information effectively and communicate decisions in any way is impaired to such a significant extent that he is totally unable to meet the essential requirements for his physical health and safety. 6. In my professional medical opInIon, Mr. Bunting's ability to receIve and evaluate information effectively and communicate decisions in any way is impaired to such a significant extent that he is totally unable to manage his financial resources. 7. I believe that Oliver Bunting should not attend the court hearing in the Cumberland County Courthouse because, in my professional medical opinion, his mental condition would be harmed by the transportation to the courtroom and by his attendance at the court hearing. Furthermore, I do not feel that Mr. Bunting would be able to communicate in any substantive manner with the Court during the hearing, or understand the nature of it. ~ &-U...~ lC' \ .0/tJ v~ J .U..^ ~ David R. Wenner, D.O. . Sworn and subscribed to before me this-.:.;"".c(- day of ,:\,.-.....:.. __, 20 i~.J..... L' .J .--....... ~c.-_.i-=-~c_r_ C-{ J").").....~.[_ Notary Public (SEAL) Notarial Seal Patricia A. Meek, Notary Public Middlesex Twp, Cumberland County My Commission Expires Nov. 8, 200S Member, p~ Association Of Notaries ~ ~ "'. IN RE: OLIVER BUNTING IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. 21-2001-1112 IMPORTANT NOTICE CITATION WITH NOTICE A petition has been filed with the Court to have you declared an Incapacitated Person. If the Court finds you to be an Incapacitated Person, your rights will be affected, including our right to manage money and property and to make decisions. A copy of the petition which has been filed by MARILYN CHUBB AND SUSAN B. BIANCHI is attached. You are hereby ordered to appear at a hearing to be held in Court Room No. 3 JUDGE GEORGE E. HOFFER, Cumberland County Courthouse, Carlisle, Pennsylvania, on JANUARY 9 ,2002, at 3:00 p.m. _M. to tell the Court why is should not find you to be an incapacitated Person and appoint a Guardian to act on your behalf. To be an incapacitated Person means that you are not able to receive and effectively evaluate information and communicate decisions and that you are unable to manage your money and/or other property, or to make necessary decisions about where you will live, what medical care you will get, or how your money will be spent. At the hearing, you have the right to appear, to be represented by an attorney, and to request a jury trial. If you do not have an attorney, you have the right to request the Court to appoint an attorney to represent you and to have the attorney's fees paid for you if you cannot afford to pay them yourself. You also have the right to request that the Court order that an independent evaluation as to your alleged incapacity. If the Court decides that you are an Incapacitated person, the Court may appoint a Guardian for you, based on the nature of any condition or disability and your capacity to .. ~ make and communicate decisions. The Guardian will be of your person and/or your money and other property and will have either limited of full powers to act for you. If the court finds you are totally incapacitated, your legal rights will be affected and you will not be able to make a contract or gift of your money to other property. If the court finds that you are partially incapacitated, your legal rights will also be limited as directed by the Court. If you do not appear at the hearing (either in person or by an attorney representing you) the court will still hold the hearing in your absence and may ap 'nt the Guardian requested. By: CI Cumb and County, Carlisle, P A My Commission Expires 1 st Monday, January, 2002 BECKLEY & MADDEN ATTORNEYS AT LAW CRANBERRY CoURT 212 NORTH THnm STREET POST OFFICE BOX 11998 HARRISBURG. PENNSYLVANIA 17108-1998 AREA CODE 717 TELEPHONE 23.'i-7691 FAX NO. (717) 233-3740 FILE NO. 40841 December 27,2001 The Honorable George E. Hoffer Cumberland County Courthouse One Courthouse Square Carlisle, Pennsylvania 17013 RE: In re: Oliver Bunting - Docket No. 21-2001-1112 Guardianship Petition Dear Judge Hoffer: This office represents Marilyn Chubb and Susan Bianchi. On December 6, 2001, we filed a Petition for Adjudication of Incapacity and Appointment of Plenary Guardian of the Estate and Person of Oliver Bunting in accordance with 20 Pa.C.S.A. S 5511. Oliver Bunting suffers from senile dementia, hypertension and advanced Parkinson's disease, so we are attempting to have the Court appoint Marilyn Chubb and Susan Bianchi, his daughters, guardian of his estate and person. The Court has scheduled a hearing in this matter for January 9,2001. On December 11, 2001, the Court entered a Preliminary Decree which instructed us to notify the Court if Mr. Bunting had not retained an attorney. Accordingly, we are writing to you to let you know that Mr. Bunting has not retained an attorney, nor do we believe he will retain an attorney. We also do not believe that Mr. Bunting will attend the hearing because his treating physician, Dr. David Wenner, believes it would be harmful to his condition if he had to attend the hearing. If you have any questions, or if you need anything further from our office, please do not hesitate to contact me. c U\ ~ N 0- <:( u_ Very truly yours, - ~ ., U ,:,1 ~~.~ c::3 ~.~ . ~:: '. .8 cc: ~ ~aril)6Chuii ~ a:: . 0U BECKLEY & MADDEN ~ Thomas S. Beckley', ... COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE BUREAU OF INDIVIDUAL TAXES DEPT. 280601 HARRISBURG, PA 17128-0601 REV-1162 EX(11-96) RECEIVED FROM: PENNSYLVANIA INHERITANCE AND ESTATE TAX OFFICIAL RECEIPT STEGOSSI LAURA E BLANK ROME, LLP ONE LOGAN SQUARE PHILADELPHIA, PA 19103 -------- fold ESTATE INFORMATION: SSN: 203-01-1112 FILE NUMBER: 2105-0203 DECEDENT NAME: HALL HELEN R DATE OF PAYMENT: 05/16/2005 POSTMARK DATE: 05/13/2005 COUNTY: CUMBERLAND DATE OF DEATH: 02/17/2005 NO. CD 005321 ACN ASSESSMENT CONTROL NUMBER AMOUNT 101 I $64,339.00 I I I I I I I I TOTAL AMOUNT PAID: REMARKS: CHECK#107 SEAL INITIALS: JA RECEIVED BY: REGISTER OF WILLS $64,339.00 GLENDA FARNER STRASBAUGH REGISTER OF WILLS -,~ ~~~.