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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
IN RE: GUARDIANSHIP OF
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WARREN DIAMOND
c. ::t
File No. ;}./-{)f -0351'
An Incapacitated Person
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PETITION TO ACCEPT TRANSFER OF PLENARY GUARDIAN c.)
AND NOW, this ZJ~day of~, 2008, comes Petitioner, Harry Stoner, by and
through his attorneys, Knight & Associates, P.c., and files the following Petition for Appointment
of Plenary Guardian, and in support thereof avers as follows:
1. Petitioner's mailing address is 701 Hummel Avenue, Lemoyne, Pennsylvania 17043.
2. Petitioner is the life-long friend of Warren Diamond, the incapacitated person.
3. Mr. Diamond suffers from Alzheimer's Disease.
4. Due to Mr. Diamond's illness he is unable to effectively evaluate information and
communicate decisions, and is unable to manage his money or to make necessary decisions about
where he will live, what medical care he will get, and how his money will be spent.
5. Mr. Diamond has been found totally incapacitated by the 17th Judicial Circuit in and
for Broward County, Florida, by Order of Court entered January 9, 2007. A true and correct copy
of the Broward County, Florida January 9,2007 Order is attached hereto and incorporated herein.
6. The 17th Judicial Circuit in and for Broward County, Florida, appointed South Florida
Guardianship Program, Inc., as plenary guardian of the person and property of Warren Diamond on
January 9, 2007.
7. Mr. Diamond has no living next of kin.
8. Petitioner has been a close friend of Warren Diamond for over forty years, and is the
closest relation Mr. Diamond has to family.
9. Warren Diamond is the godfather of Petitioner's twenty-two year old son.
10. Mr. Diamond has one asset, which is a condominium in Deerfield, Florida; an
attorney in Florida is already retained to pursue Mr. Diamond's interest in the condominium and
Petitioner will continue to pursue that interest; Mr. Diamond's interest in the condominium has an
approximate value of $20,000.00.
11. Mr. Diamond's only income is from Social Security in the approximate amount of
$1,270.00 per month.
12. The 17th Judicial Circuit in and for Broward County, Florida, has directed a change
of residence for Mr. Diamond to Cumberland County, Pennsylvania, so that Petitioner may be
appointed Guardian in this county. A copy of the Broward County, Florida Order of Court dated
January 16, 2008, is attached hereto and incorporated herein.
13. In order to ensure that Mr. Diamond gets the personal care assistance that he needs
when he arrives in Pennsylvania, Petitioner must be appointed guardian in this jurisdiction.
14. By the Broward County, Florida Order dated January 16, 2008, South Florida
Guardianship Program, Inc. will remain the guardian of Mr. Diamond until guardianship is
established in Pennsylvania.
15. It is Petitioner's desire to care for Mr. Diamond in the time he has before Mr.
Diamond succumbs to his illness.
WHEREFORE, Petitioner respectfully requests that this Court accept the transfer of
jurisdiction from Broward County, Florida, to Cumberland County, Pennsylvania, and appoint him
as the plenary guardian of the person and estate of Warren Diamond.
Respectfully submitted,
KNIGHT & ASSOCIATES, P.C.
ean M. Shultz, Esquire
Attorney ID No. 90946
11 Roadway Drive, Suite B
Carlisle, Pennsylvania 17015
(717) 249-5373
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in the foregoing Petition are true and correct 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. Section 4904, relating to unsworn falsification to authorities.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: GUARDIANSHIP OF
WARREN DIAMOND
File No.
An Incapacitated Person
CERTIFICATE OF SERVICE
AND NOW, this 2JJf day oEMarch, 2008, I, Sean M. Shultz, Esquire, hereby certifY that
I have this day served the following with a copy of the foregoing Petition by first class, United States
Mail, Certified, Return Receipt Requested, Restricted Delivery, postage pre-paid, addressed as
follows:
South Florida Guardianship Program, Inc.
Station 262
PO Box 130130
Sunrise, Florida 33313
Respectfully submitted,
KNIGHT & ASSOCIATES, P.c.
Sean M. Shultz, Esquir
Attorney I.D. No. 90946
11 Roadway Drive, Suite B
Carlisle, Pennsylvania 17015
(717) 249-5373
Attorney for Petitioner