HomeMy WebLinkAbout02-28-08
LAW OFFICES OF
STEPHEN J. HOGG
19 S. HANOVER STREET
SUITE 10\
CARLISLE, PA \7013
IN RE: ROY G. KENNEDY
ALLEGED INCAPACITATED
PERSON
: COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY
: PENNSYLVANIA
: ORPHAN COURT DIVISION
: NO.: ~\- \)~ ~ i01-.~o--
PETITION FOR PLENARY GUARDIANSHIP
The undersigned brings this Petition through his Attorney,
Stephen J. Hogg, Esquire, seeking appointment for Plenary
Guardianship of Roy G. Kennedy alleging the following:
1. The Petitioner is Stephen Pompeo, friend of the alleged
incapacitated person, residing at 613 B Geneva Drive, #37,
Mechanicsburg, Pennsylvania 17055. Petitioner has no interest
adverse to the alleged incapacitated person and seeks
appointment as Plenary Guardian to ensure the alleged
incapacitated person's continued physical and mental health
treatment.
2. The Petitioner has served ably as medical POA and partial
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financial POA for the alleged incapacitated person since }uly ..
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2007.
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LAW OFFICES OF
STEPHEN J. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
3. The alleged incapacitated person is Roy G. Kennedy born
October 25, 1920 and whose last known address is 100 East
Butler Street, Mt. Holly, PA 17065.
4. The alleged incapacitated person is not married and has a
daughter:
Rosemary Barnard
24174 Meadows Avenue
Flat Rock, Michigan 48134
(734) 795-6932
5. Rosemary Barnard, daughter of the alleged incapacitated
person does not wish to be appointed guardian herself and
approves the appointment of Petitioner as attached hereto as
Exhibit 1 .
6. The alleged incapacitated person is currently being treated by
Dr. David Dell of Forest Park Nursing Home and Dr. Christopher
Royer of PRISM Psychology.
7. The alleged incapacitated person was diagnosed by a
psychiatrist from Philhaven in October 2007 and then by Dr.
Royer in November 2007 as having vascular dementia with
behavioral disturbances.
8. The Petitioner alleges that the alleged incapacitated person has
shown he is unable to adequately care for his own needs and
would likely not pursue any physical or mental health treatment
as prescribed by Dr. Christopher Royer.
2
LAW OfFICES OF
fEPHEN J. HOGG
9 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
9, The Petitioner requests that he be appointed Plenary Guardian
of the alleged incapacitated person to assure continued needed
physical and mental health treatment and over the estate of the
alleged incapacitated person to ensure that the alleged
incapacitated person does not waste or squander his estate.
10. The Petitioner alleges that he is the most qualified individual to
be appointed Plenary Guardian of the alleged incapacitated
person having his best interests in mind.
11. The Petitioner seeks appointment as Plenary Guardian of the
alleged incapacitated person only so long as the alleged
incapacitated person is determined by his treating doctor, Dr.
Royer, to be unable to take care of his own needs.
12. The Petitioner estimates that the gross value of the alleged
incapacitated person's estate is $388,347.41.
13. The Petitioner alleges there may be unknown assets in a safe
deposit box.
14. Petitioner seeks appointment as Plenary Guardian of the
alleged incapacitated person's estate and of his person.
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VERIFICATION
I verify that the statements made in this Petition For Plenary
Guardianship to the Court of Common Pleas of Cumberland County,
Pennsylvania, are true and correct. I understand that false statements
herein are made subject to the penalties of 18 Pa. Section 4904,
relating to unsworn falsifications to authorities.
Date: ,;J- ;- () ?
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S E N POMPEO I
LAW OFFICES OF
fEPHEN J. HOGG
9 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
IN RE: ROY G. KENNEDY
ALLEGED INCAPACITATED
PERSON
: COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY
: PENNSYLVANIA
: ORPHAN COURT DIVISION
: NO.:
WAIVER OF GUARDIAN APPOINTMENT
1, Rosemary Barnard, daughter of the alleged incapacitated
person, do not wish to become his guardian. I waive any right to be
involved in his care and maintenance as his guardian. I agree with the
appointment of Stephen Pompeo as the guardian of Roy G. Kennedy.
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Rosemary Barn' d
Date: 'L- J.., SOb