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HomeMy WebLinkAbout02-19-08 IN THE COURT OF COMMON PLEAS - CUMBERLAND COUNTY ORPHANS' COURT DIVISION IN RE: BERTHA STONE, An Alleged Incapacitated Person O.C. No..21-0~..OI76 PETITION UNDER & 5511 OF THE PROBATE, ESTATES AND FIDUCIARIES CODE TO ADJUDGE BERTHA STONE TO BE TOTALLY INCAP ACIT A TED AND APPOINT A PERMANENT PLENARY GUARDIAN FOR HER PERSON AND EST A TE AND NOW, COMES, Petitioner, Church of God Home, Inc. ("Petitioner"), by and through its attorneys, SCHU1]ER BOGAR LLC, and hereby petitions for adjudication of incapacity and appointment of a permanent plenary guardian of the estate and person of Bertha Stone and, in support thereof, represents as follows: 1. The name of the alleged incapacitated person is Bertha Stone. 2. Bertha Stone, the alleged incapacitated person, is a 101-year old widowed individual who currently resides at Petitioner's skilled nursing facility located at 801 ,...." North Hanover Street, Carlisle, Pennsylvania 17103. ~o ~ :c'.... :n .." ,,"0 -0 rrJ Petitioner, a domestic corporation, is a residential and skille~~ng~re ; C7 :n \.Q :':'."""1 ~.......-, ~oc -0 '.)04'1 :J: c.) =:0 :o-l po 3. provider. - .. en CT\ ORIGINAL ~ 4. Because the alleged incapacitated person resides in Cumberland County, this Court has Jurisdiction pursuant to Sections 5512(a) and 711(10) of the Probate, Estates and Fiduciary Code. 5. On or about October 21, 2002, Bertha Stone became a resident of Petitioner's skilled nursing facility. See Admission and Care Agreement, attached as Exhibit" A." 6. Upon information and belief, and to the extent of Petitioner's knowledge, the alleged incapacitated person has the following living heir or next of kin who is sui Juns: Edith Eckart (daughter) 5270 South West Street Carlisle, PA 17013 Mary Gross (granddaughter) 917 Park Place Mechanicsburg, P A 17055 7. Petitioner is unaware of the value of the alleged incapacitated person's estate, if any. 8. An application for the receipt of Medical Assistance benefits was filed with the Cumberland County Assistance Office ("CAD"), but the CAD denied that application on March 7, 2007, as evidenced by the Notice to Applicant ("P A-162") attached as Exhibit "B." 9. To the extent of Petitioner's knowledge and upon information and belief, the alleged incapacitated person receives monthly income consisting of Social Security and a Lear pension, but Petitioner is not aware of the value of that monthly income. 2 10. The alleged incapacitated person's treating physician is: William Kaufmann, M.D. 1921 Spring Road Carlisle, PA 17013 11. Bertha Stone, the alleged incapacitated person, has been diagnosed by Dr. Kaufmann as suffering from dementia. That condition has caused her incapacity and requires that she receive 24-hour-a-day care. 12. Because of the condition set forth in paragraph 10, Bertha Stone, the alleged incapacitated person, is unable to manage or even appreciate the significance of her personal and/ or financial affairs and to make and communicate any decisions relating thereto, including the ability to communicate her need for assistance in these areas. See January 21, 2008 letter from Dr. William Kaufmann to counsel for the Petitioner, attached as Exhibit "C." 13. To the extent of Petitioner's knowledge, Mary Gross is the agent-in-fact for Bertha Stone, but Petitioner does not have a copy of the Power of Attorney. 14. However, presently, upon information and belief and to the extent of Petitioner's knowledge, the alleged incapacitated person does not have a capable and willing agent, guardian, and/ or available next of kin who are sui juris to manage her personal and/or financial affairs and to obtain the documents needed to qualify the alleged incapacitated person for the receipt of Medical Assistance benefits. 15. There are no less restrictive alternatives to the appointment of a permanent plenary guardian of the person and estate of the alleged incapacitated person. 3 16. The proposed guardian of the alleged incapacitated person is Good News Consulting, Inc., located at 140 Roosevelt Avenue, Suite 206, York, Pennsylvania 1740l. Good News Consulting, Inc. does not have any adverse interest to the alleged incapacitated person and an acceptance to serve as guardian of the person and estate is attached hereto as Exhibit "D." 17. Good News Consulting, Inc. has been suggested as guardian of the person and estate of Bertha Stone because of its vast experience in dealing with incapacitated persons such as her. 18. No Court within this Commonwealth, of which Petitioner has knowledge, has appointed a guardian for Bertha Stone. 19. Upon information and belief and to the extent of Petitioner's knowledge, Bertha Stone was not a member of the Armed Service of the United States and, therefore, is not receiving any benefits from the United States Veterans' Administration. WHEREFORE, your Petitioner prays that a citation be issued to Bertha Stone, to show cause, if any there be, why she should not be declared an incapacitated person and Good News Consulting, Inc., appointed permanent plenary guardian of her person and estate. 4 Respectfully submitted, SCHUTJER BOGAR LLC Dated: 'J11l1 t.008 By: ~~~ Bradley A. Schutjer Attorney J.D. No. 75954 (717) 909-5921 Maria G. Macus-Bryan Attorney J.D. No. 90947 (717) 909-8640 417 Walnut Street, 4th Floor Harrisburg, P A 17101 Fax No.: (717) 909-5925 Attorneys for Petitioner 5 VERIFICATION The undersigned hereby verifies that the statements of fact in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the penalties contained in 18 Pa. C. s. 9 4904, relating to unsworn falsification to authorities. Dated:~ of II r ~ J/ /Mr'~ Signature Co.,. J () I' c;:.. R~ +1: 'J e Print Name J ~.I')"~..A- ( c &;) Position Church of God Home, Inc. EXHIBIT II A" CHURCH OF GOD HOMEr INC. JI.DMISSION AND c.~,RE AGREE.J.'1ENT THIS AGREEMENT is made on this oil day of 1J;i/Jj1 ,~Cl, by and between The Church of God Homer Inc., called the "Facility, 11 a pennsylvania non-profit corporation located at 801 North Hanover Street, C;hrisle, CUmb~eriand County, Pennsylvania, . ~A r 11 tI and 'I( c. 'lA... called "Resident" and It, dZl16 (C(fGif called "Responsible Party". The Resident and the Responsible Party reaffirm that the information provided in the Pre-Admission Questionnaire is true and correct and understand that the submission of false information may constitute grounds to terminate this Agreement -' The Resident has applied for admission to the Facility and the Facility has approved the. Application for Admission. Therefore, the Facility, The Resident and Responsible Party agree to the following terms': ~ . PROVISION OF SERVICES _ The Facility will provide' .- Resident with: (a) Skilled nursing care, i.e_ professionally supervised nursing care and related health services under a pl~ of services regularly provided under a plan of care' supervised by licensed personnel and, as required by the Resident's medical condition, assistance with activities of daily living. (b) Accommodations consistent with the .level of care provided to the Resident including heat, air conditioning, electricity and hot and cold water. (c) Bed, bedding, blankets and laundered bed linens, towels and wash cloths. (d) Three meals each day, except as otherwise medically indicated. (e) Activity programs and social services. 2 . RECURRING CHARGES. In exchange for the above services, the Resident shall pay the following recurring charges~ (a) For skilled nursing care: $ (I{ g O(J' dollars .per day. Acimission and Care Agreement - c:om:inued - 3-. NON-RECURRING CID..RGES. The Resident shall pay the following non-recurring charges: (a) A security deposit in the amount of thirty-one (3l) times the current daily rate for the level of care requ~y the resident, will be b~lled after adrnis' day. The amount of the security deposit is $ .. No interest will be paid on the security depos. t. A security deposit will not be charged to residents who are receiving benefits for room and board provided by Medicare r until the Medicare benefit concludes. An applicant who is.covered by Medicaid is not required to pay a security deposit. (b) The cost for enrollment in the community ~~ce and ALS (Advance Life Support) Unit is $~. This fee must be paid prior to admission and will be billed annually to the Resident. 4 - MISCELLANEOUS CHARGES AND OUTSIDE SERVICES. Resident is responsible to pay for other services provided by the. 'Facility which are not covered by the daily rate/charge. . A. list of such services/charges is attached to this Agreement on the llChart of Costs. II The services of a licensed physician and dentist I a registered pharmacist and licensed pharmacy for the provision of pharmaceutical supplies, a licensed hospital, and. diagnostic services, will be made available at the Resident's expense. THE RESIDENT HAS THE RIGHT TO SELECT HIS/HER OWN PHYSICIAN OR ANY OTHER SERVICE PROVIDER SO LONG AS THE PHYSI CIAN OR OTHER SERVICE PROVIDER IS PROPERLY LICENSED OR REGISTERED UNDER THE LAW, AND THAT ALL APPLICABLE GOVERNMENT RULES AND POLICIES OF THE. FACILITY ARE MET. In addition to the Facility'S charges, the Reside~t is responsible to pay 'all fees and costs . for goods or services furnished to or for the Resident by anyone other than the Facility under this Agreement. The responsibility of the Resident to pay applies to all fees for costs of services provided for the Resident by any physician, dentist, optometrist, therapist, diagnostic or testing laboratory, pharmacist, pharmacy, hospital, or any other person, facility or entity providing services or goods to or for the Res ident , and f or all lLrugs't medicines, medications, pharmaceutical supplies, corrective eye lenses,. hearing aids, dentures, hair care, and other personal items or se~ices for the Resident. SUCH FEES AND COSTS Jl..RE NOT INCLUDED IN THE HOME'S DAILY P~2\.TE/CHJI..RGE. '. ltdmission and Care Agreement - continued 5. J..nMISSION. The Resident \.,ill ~ ad.mit:ted, or a bed will be reserved for Resident, beginning on f j(i{() IX I J~_;;< /. ]1._11 pre-admission charges will be bilJ.ed after admission, and recurring charges will begin to accrue as of the above date. The Resident may reserve an available bed by paying the daily rate for the bed reserved. The daily rate for the reserved bed will continue to accrue and be payable until the reservation is terminated, even if the Resident does not enter the Rome for what:ever reason, including illness, injury, incapacity or death. 6. PERIODIC BILLINGS AND PAYMENT DUE DATE. (al On the first of each month~ Resident will be billed the current daily rate for Resident's current level of care times the number of days in the month. The bill is due and payable'upon receipt. (bl Miscellaneous charges (refer to "Chart:. of Costsll attached to this Agreement) such as hair care, personal laundry., incontinency , supplies, etc. J are, additional charges,{'a:bove . the daily rate. These miscellaneous charges:"'~ill be added to, and included with, your monthly bill. . , ' ' (c) Pharmacy charges will be billed as a separate part of the Facility's monthly bill, and will require a separate ch~ck. (dl outside pro~ders,will bill directly and separately. 7. CHANGES IN CHARGES. From time to time, the Facility may change the amount of its charges. In addition, from time to time, t.he Facility may change how and when its charges are computed, billed or become due. The Facility reserves the right to make any such changes at any time. Written notice of any such changes will be given to the' Resi.dent thirty (30) days in advance of implementation, unless" the change is required earlier under any, federal or state law or assistance program. 8. PARTICIPATION 'IN "MEDICARE/MEDID..IDn PROGRAl-1S. The Facility participates i.n the Medicare program administered pursuant to Title XVIII of the Federal Social Security J.kt and the Pennsyl vania Medical Assistance Program ("Medicaid") administered pursuant to the Pennsylvania state plan and Title XIX of the Federal social security Act. However, the Facility reserves the right to withdraw from the MedicarejMedicaidprograrns at anytime in accordance with the law. ' ' Acim;Lssion and Care Ag:;:-eement - cont:inued. - 9--. OBLIGItTIONS OF RESPONSIBLE PARTY. The Responsible Party is responsible for services and supplies that are billed through the Facility or billed directly to the Resident or Responsible Party by any other provider. The Responsible Party is responsible' to pay all fees and costs from Resident's resources. lO. P~MISSION - BED HOLD POLICY. If the Resident leaves the Facility for a period of hospitalization, therapeutic leave, or any other reason, other than the Rel?ident' s deat.h, and if the Resident is not eligible for, or receiving medical assistanc~, the Resident's bed will be reserved and charges for the reserved bed will continue to accrue, unless the Resident or Responsible Party _otherwise directs in writing. If the Resident or Responsible Party elects not to reserve a bed, then the Resident will be eligible for readmission upon the availability of the first bed suitable fpr the Resident's level of care. If the Resident -=L'S receiving medical assistance benefits and the Resident leaves .the Facility for a period of hospitalization or therapeutic leave, the Resident's bed will be reserVed for the applicable maximum number of days paid for the reserved bed under the Pennsylvania.Medical Assistance. Program. The current' bed reservation period is fifteen (lS) days for hospitalization, regardless of level of care, fifteen (lS) days for therapeutic leave for residents receiving skilled nursing care,.. and thirty (30) -days for therapeutic leave for res.idents receiving intermediate care. The bed reservation period may be subject to change in accordance with any changes in the. Medical Assistance Program. If the period of hospitalization or therapeutic leave ends within the reservation period under the Medical Assistance Program, the Resident may return to the Facility. If the period of hospitalization or therapeutic leave exceeds the maximum time for reservation of a bed under the. Pennsylvania Medical Assistance Program, the Resident must wait until a suitable bed becomes available for readmission. The Resident is entitled to the first available bed suitable for the Resident's level of care if 1 at the time of readmission, the Resident . requires the services provided by the Home. ll. REFUNDS, The .8ecuri ty q.eposit for private pay residents, after deductions for the payment of any outstanding bills oweq to the Facility, will be refunded within thirty (30) days after the Resident's discharge from the Facility or death. Those Nursing Residents on Medical Assistance will receive their refund, if any due, within ninety (90) days. .There will.be no other refunds, in the absence of an overpayment, under this Agreement. l2.. PERSONAL FINANCES. The Resident has the right to manage his /her personal funds. The Resident is and will be responsible to provide his/her personal funds. If the Resident elects, the Resident may designate, in writing, that the Facility hold and manage the Resident's personal funds. If the Resident Admission and Care Agreemen~ - con~irrueci designates someone other than the Facility to manage his/her personal funds, the Resident or Responsible Party shall notify the Facili ty promptly. The Resident is not required to make any designation, and -is _responsible for his/her own personal funds unless such designation is made. The Resident may revoke, at any time, the designation or the Facility as the manager of his/her personal funds by providing the Facility a ~r.ritten notice signed and dated by tbe Resident or Responsible Party. If the Resident transfers to the Home, responsibility to _manage the Resident's personal !unds, the Facility will do so-in accordance with the "Rights of Nursing Facility Residents", a copy of which is. provided at the time of your admission, and the Facility's personal funds management policy. The Facility may deduct, at any time, charges due to the Facility under. this agreement from the Resident's personal funds managed by the Facility. . 13. TERMINATION, TRANSFER OR DISCHARGE. (a) BY the Resident.: - The Resident may tenninate this Agreement upon thirty (30) days written notice to the Facility. If the Resident leaves the-Facility for any reason other than a medical emergency' or his/her death, the Resident must give written notice to the. Facility at .least thirty (30). days in advancecif the departure/ . transfer/discharge or termination of the Agreement. If advance written notice is not given to the Facility, .there will be due to the Facility its daily.and other . charges then in effect for the Resident's current level of care for the required thirty. (3D) day notice period. The charge applies whether or not the Resident remains at the Facility during the thirty (30) day period. By the Facility: The Facility may terminate the Resident I s stay and transfer or discharge the Resident if: (I) the transfer or discharge is necessary to meet the Resident's welfare which cannot be met by the Facility; (b) (II) the Resident's health or condition has improved sufficiently that.the Resident no longer needs the services provided by the Facility; (III) . the safety or health of individuals in the Facility is or otherwise would be endangered; ~~ssion and ~are Agreement - con~inued (IV) The charges or other amounts due to the Facility \L~der this Agreement have not been paid to the Facility or treated .as paid to the Facility on the Resident's behalf by Medical Assistance' under the Pennsylvania Medical Assistanc~ Program or by Federal Medicare benefits under Title XVIII of the Federal Social Security Act i OR (V) The Facility ceases to operate. The Facility generally will not.ify the Resident and Responsible Party or if none, a family member or legal representative of the Resident/if known to the Facility, at least thirty (30) days in aqvance of such a transfer or discharge. However, in any case, described in subparagraph (I), (II) or (III) above/ or if the Resident has not resided at the Facility for at least thirty (30) days, the Facility will give such notice berore transfer or discharge as is practicable under the circumstances. l4. TIURD PARTY PADmNTS. The Resident may be or may become eligible, to receive financial assistance, reimbursement or other benefits' Tram " third-parties, such as through private insurance, employee benefit plans, medical assistance under the Pennsylvania Medical Assistance Program,' Medicare benefits, supplementary medical 'or other. health insurance, supplemental securi.ty income insurance,' or old-age survivors' or disability insurance under or pursuant to the Federal Social Security Act or Program. If the Resident becomes eligible to receive payments from any third-parties for the stay 'and care of the Resident, the Res ident and Responsible Party shall/ at all ,times, cooperate fully wi th the Facility and each third-party' payments. . Cooperation includes / If/hen requested, providing information, signing and delivering documents, and having the Facility designated by the Social Security' Administration as the Resident / s representative payee for receipt of Federal Social Security benefits or any other governmental assistance, reimbursement or benefits to the extent of all charges due the Facility. The ResidenL irrevocably authorizes the Facility to make claims and to take such other actions as may be necessary for the" Facility/s receipt of third-party payments. To the fullest. extent permitted by la\'l, the Resident hereby assigns to the Facility, the Resident's rights to any third-party payments now or hereafter paYable to the. extent of all charges due to. the Facility. The Resident and Responsible Party promptly shall endorse and turn over to the Facility any payments received from third-parties to the extent necessa-ry to satisfy the charges 'under thi s Agreement. . . AcirnissioD and Care A~e.ement - cOIl::.iDuea _1.5. PERSONAL PROPERTY. The Resident is and will be responsible To furnish and maintain his or her own clot.hing, jewelry, personal possessions and ot.her items of property. The Facility may limit the amount or type of property that the Resident may keep at the Facility if there is insufficient space, or if medically indicated or necessary.to protect the rights or welfare of others. The Facility will not be liable for damage to or loss of any personal property of the Resident unless the property is deposited with the Facility for safekeeping. The Facility will Drovide written receipt for any items of the Resident's property deposited with the Facility. 16. RESPONSIBILITIES OF RESIDENT. The Resident s:t,all comply - fully with all governmental laws and regulations, the provisions of this Agreement and the Facility's existing policies, rules and regulations which may, from' time to time, be altered or amended. 17. MISCELLANEOUS PROVISIONS. (a) The Resident and Resuonsible Party acknowledge that they are adult individ~a1s and hqve read and understand the terms of this Agreement. . (b) The provisions of this Agreement shall be governed by the laws of the' Commonwealth of .Pennsylvania and shall be binding upon and inure to the.~benefit of each of the undersigned parties and thefr respective heirs;, personal representatives, successors and assigns. (c) The various provisions of this Agreement shall be severable one from another. If any provision of this Agreement is IDund by competent legal authority to be invalid, the other provisions. .shall remain in full force and effect as if the invalid provision had not been a part of this Agreement. (d) The Facility reserves the right to modify unilaterally the terms of this Agreement to conform to subsequent changes. in the law or regulation' and changes in charges. Resident will be .provided thirty (30) days notice of changes 'in charges and, if practicable, reasonable notice of any modifications required by law. {' r, __~I I -c;-; I,.J. . /, .-,.-_ f.-.. '..-"- (/ ....... Date EXHIBIT ~~B" 1liIlEi-1~1: ''-~:I_ur.. Dnegulation<;s- (,b. GJ. 1.!:I.l I Reason Code DY L . '!y;7ha ~~ \Al:~ fot."1:IILT Oh1J..AA.- {a- 101,\ tr.Y\ ((-'u"'i-d~<;;\Sh-\CQ.. ~(;_~ fu {c.I\o..ui-)( \IQ:~(\((,",,<Yl. !.t;(LS t)c1 P,i;'.j .elL'tl: . la:'tp .).001 lib- fll.,)<;L0<\ q.1r.>.> \:lC':~u... L~"J LLllllJi_d j'~ ~:r~<-kl Lout h rU:v1H.:'J S~~i~ill. fbc a.,U 'a.l..,t. Mc.cl,',k t-c '-\.....J ~ f-ylu- \a.\~\\Ou. '(:XJ.(\"c; , /:!:;P'-\ of 1I..u. ~l;\ ClLr..l.Jil'\L.,'-.'rc..:\,,,,,, LI."(:I '5'1v<'~),' c.l.<'<-'::<-'u\l- .s~f'''''llli\h -fi:r a.l\. aS~illl}I6..(.'-.,h.... ~lor'l \j~./\tid-kr. oc::. (ill a.nJ../'II-s ClD'.....llllf) T\u.. r:lS~ ~"I(,'"3., V~f ,fu.ll..:h~ cf ~ 'x.'-fu;.s at ~ ,lJ.;.poJ!. cnLI.JHI-fi. \.:...d 0.'1 1-h"6~ '-:',,~r1 I ,tk, ..k,kr.l 1111101 \1". lIv:-\r {'Inf.,.k",.., f,YL,,-.d...t.- /JJ\ MA.~\ t1FItI \f\" ~'!i~"'.f ~. Name ~~~J Name ~~~"'.W&~J rill/II/. v 1/ l77i '(11111// GROSS MONTl1L Y UNEARNED INCOME '/~ljll II 1///I/7l, /(//1/// ~f~~~Wil~\~~\iJ:~~(~~~~~ l-BO'l-269.0173 717-240.2700 DEPARTMENT OF PUBUc WELFARE CUMBERLAND COUNTY ASSISTANCE OFFICE 33 WEsn.VNSTER DRIVE P. O. BOX 599 CARLISLE. FA 1701J.0599 OfNEFiT UASSISTANCE CHECK ~- ~;~~I~.{;-NCE El:G18lf ::t~:e~u: F~::D'~.(' ! . I 1 "~---" AII~i (ht~ I;f"~i rJ1eo wf'lich m;)y te i! ~:peci"'l ;:!l'N)unl ",'OU .\1';1 f~cer/? S __ o h-.>ce:t P..\c.rilh o Once a Mwm o In:ileM;\)1 o Mill! Buflh o YOl; ,.a'/E a D.illienl pay 1.41b,lr., cf S ~ P~iod beg1fV'lil'\g You ~\'111 f.z:cel~C 5 a,.11 E(!<jol1g o EII~J'lve Dale OF000 STAMPS :0 !o; the mJ,ilnlsl 01 __ mer. )OU \Ylt' ~c'!""e 1000 Slal'Tlps in lhe amo'.;tll C'. S o In l~~ Matl 0 At the Barn.. "' mOnTh IT.~m I;;} f4URSING HOME CARE o ~V~~ES 0 ~~, THE FOLLOWING PERSONS ARE IHCLUOEO L1'JE HO x Lf"lf'1 01 coup. iouIhori4e-o you Jre EJPeclM to pay 5 1 month lO'l'llaro ,.OUf call: ~t2i< I J~~s MEO. ASS. sac SERVICE UNE NO. NAME I tJf~K FOOD STAMPS "AME 0\ IA.-.r\-h~ c:..\r-.tlL- S :5 $ Name II//I/. 11///1 GROSS I.4ONTlil Y UNEARNED INCOME S 11// , S I/I///, $ Name TOTAL GROSS MONTHLY INCOME GROSS MONTHLY DEPENDENT CARE COSTS GROSS MEDICAL COSTS S $ :{. TOTAL GROSS MONTHLY INCOME GROSS MONTHLY OEPENDENT CARE COSTS 1:5 Is Telephone Electric Waler/Se>J'mge GatbageIT ,ash o MEDICAL ASSISTANCE Name - ...... ---.-- "- -- '-'EO ASST SQC SERVICE S $ $ $ $ $ Ulillly In51"lIallOO Olher ---- _._-~- GROSS UTILITY COSTS/UTIliTY STANOARO' $ REHT/MORTGAGE $ .------.-\--- S S -----~-~--=---~~--=----=~- Number 01 PersD05 ~ I GROSS fIKlNl HL Y EARNED INCOME /// ///. .////I./~/. ,.:7;'.'17/ , .':"." '/!. GR'JSS IJOtlll-ll. Y IJIJE~'lltIEO Jt'lCOtAE Y'!/u:;. II,.. './':'i:'"" V r. /." ','. I 1/' I ." ~. . ' ,I /. ~-'i':'" Gas 011 TAXES INSURANCE COST ON HOME 1////11 '7/1/1/ 11//// Name TOTAL SHELTER COST f------- TOT AL GROSS MONTHL V INCOME NET MONTHLY INCOME/NET SEMI. ANNUAL INCOME "The householO may switch l1e/ween tile aC/lIal uJility costs and the sfandard utitity allowance at the tIme 01 reapplication and iJne "ddifional lime during each twetve-month penod INCOME liMn RECOROHUMBER CAr ~ i\\;~,', \Nor~('I.':. S.",raIUlO? "\"l ~\)1 ole r I LEGAL HELP IS AVAILABLE AT fl.L..ih t ( \<'Cto- \- ~;.tl 0 See.lh \..,--' ,\ ':.i' (t;;\t.t;"\ ilei-?) lIL":'I<\ I'D (, lv.:'-_Il "'6 C. ,d LEGAL SERVICES. INC. a IRVINE ROW CARLISLE. PA 11013-3019 717-243-9400 717-766--8475 L fD) ~ @ ~ 0 \TI ~ wi lUU MAR 0 t, ZOOl ~ CUfNT C.~\f'Y ;) So S $ S S s :;; S 1\"1. .)'-I\)~_ Tr'lcphone '-)1 Imber I ___J EXHIBIT "c" l\X UllLt:/...t: ~I\" ,O-IIUUll\'r.U) u6:II'1 01/23/0B OB: 3~ AH medentvia V5I-FAX Fax# (717)-2~3-B57B r. U UII Page 2 of 2 #37177 ~h O.~.'.......~...... ~ A-' \QI \Spring Road FAMILY PRACTICE JasonA Ramirez.MD 1921 SprmgR.oad .CarlJsle.PA ~ 17013. Phone:tll7) 243-5444. Fa {m) 243-8518 · www.sprlngRoadFP.com DowE.~MD WillIam S. kauf(ma:rl,MD Bryan Retd..MD January21,2008 Maria Macus-Bryan Shug,art and Bogart Fax 909-5925 Re: Bertha E Sterle (DOB: 11/17/1906) To Whom ft May Cerlcem: Bertha Sterle is a greater than 1 OO-year-oId female resident of Church of God Nursing Home who r have known for many years. Althoug, she is pleasant and has no behavior problems, she does suffer from dementia and is not able to take care of her 0\Nl'1 affairs, financial or otherwise. Please Cerltact me if there are any questierls regardng the affairs of this very pleasant lady. William S. Kauffman, M.D. WSKmw EXHIBIT liD" .. ACCEPTANCE OF PROPOSED PERMANENT PLENARY GUARDIAN Good News Consulting, Inc. the guardian of the person and estate proposed in the foregoing petition for appointment of a permanent plenary guardian of Bertha Stone, the alleged incapacitated person, agrees to accept the appointment as permanent plenary guardian and avers that: 1. The proposed guardian is Good News Consulting, Inc., which is currently handling numerous guardianship matters similar to Bertha Stone. 2. Good News Consulting, Inc. is not a fiduciary of an estate in which the alleged incapacitated person has an interest, and the proposed permanent guardian of Bertha Stone has no interests adverse to her. Dated: 1/31/0 3' rz:: -~ Tina Hess, BS, CMC, RG-N6f' CGC Vice President of Operations of Good News Consulting, Inc.