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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
NO. 2...\ ()~ 6L{-DD ORPHANS' COURT
ESTATE OF ROBERT WAYNE MAXWELL
PETITION PURSUANT TO SECTION 5511 OF THE PROBATE, ESTATES
AND FIDUCIARY CODE TO ADJUDICATE ROBERT WAYNE MAXWELL TO BE INCAPACITATED
AND TO APPOINT A PLENARY GUARDIAN
The Petition of Holy Spirit Hospital respectfully represents that
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TO THE HONORABLE, THE JUDGES OF SAID COURT:
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1. Your Petitioner, William Donald Maxwell is an adult individual resi~.~t at 13~san~...Q~Qar
Drive, Panama City Beach, FL 32408. William Donald Maxwell is also the brother, and only ~Iing, ot'the
alleged incapacitated person, Robert Wayne Maxwell.
2. The alleged incapacitated person is Robert Wayne Maxwell, a divorced man, age 53, who
last resided in an apartment at 8714 Beacontree, Apt. 4, Richmond, VA 23294-4006.
3. On March 18, 2008, he was admitted to the Emergency Room at Holy Spirit Hospital of the
Sister's of Christian Charity "Holy Spirit Hospital" in Camp Hill, Cumberland County, Pennsylvania for a
cardiac condition.
4. Robert Wayne Maxwell was in the Harrisburg area on a job to remodel local CVS pharmacy
stores for his employer RGIS.
5. The alleged incapacitated person underwent surgery on March 18, 2008 and is now in the
Cardiac Intensive Care Unit at Holy Spirit Hospital where he is non-responsive, on a ventilator, and an EEG
showed little signs of brain activity.
6. Robert Wayne Maxwell's current diagnosis is: coronary artery disease and cardio myopathy.
His prognosis has been described by his treating cardiologist Dr. Sang Kim as poor.
7. The known relatives of the alleged incapacitated person are:
A. William Donald Maxwell, his brother and petitioner herein; and
B. Samuel and Louise Maxwell, his mother and father who reside at 119 Fairway
Blvd. Panama City Beach, FL 32407.
8. The alleged incapacitated person has been estranged from his parents for many years,
however, they have come to visit him in the hospital and do not object to the appointment of their son,
William Donald Maxwell, to be appointed as plenary guardian.
9. The alleged incapacitated person is divorced and his ex-wife currently resides in his home
located at 5 West Bel-Air Blvd., Clarksville, TN 37042.
10. The alleged incapacitated person entered into a forbearance agreement with the mortgage
company, Citi Residential Lending, regarding his Tennessee home and it is believed that this agreement is
or will soon be in default and that a foreclosure proceeding will be filed or has already been filed.
11. The alleged incapacitated person currently resides with a roommate, Dawn Eckstein, in an
apartment located at 8714 Beacontree, Apt. 4, Richmond, VA 23294-4006.
12. The alleged incapacitated person opened a joint account, believed to be at Wachovia Bank,
with Ms. Eckstein where his paycheck from RGIS is directly deposited.
13. Ms. Eckstein has refused to give the alleged incapacitated's family access to this account to
pay his necessary bills such as rent and the monthly mortgage payment as outlined in the forbearance
agreement.
14. The approximate value of the alleged incapacitated person's estate is unknown at this time as
the family has been unable to access his financial information.
15. Robert Wayne Maxwell is an incapacitated adult person within the meaning of 20 Pa.C.A.
Chapter 55 who needs a court appointed guardian for his person and his estate.
16. It is believed and therefore averred that Robert Wayne Maxwell does not have a Power of
Attorney or Living Will.
17. A guardian is necessary to facilitate Robert Wayne Maxwell's needed medical care and
treatment and to protect and preserve his assets.
18. It is believed that no other court has assumed jurisdiction in any proceedings to determine the
capacity of Robert Wayne Maxwell.
19. William Donald Maxwell, the alleged incapacitated person's brother, is willing to accept the
appointment of guardian of the person of Robert Wayne Maxwell and has no interest adverse to his brother.
20. Robert Wayne Maxwell will not be able to attend the hearing and his treating physician will
testify that his attendance must be excused as it would adversely affect his recovery and treatment in the
Cardiac Intensive Care Unit.
WHEREFORE, your Petitioner prays that a Citation be issued to Robert Wayne Maxwell to show
cause why he should not be adjudged to be incapacitated and a plenary guardian for his person and his
estate be appointed, and that the Court schedule a hearing on this Petition.
JOHNSON, DUFFIE, STEWART & WEIDNER
Date: April 8, 2008
By:
David W eLuce
Attorne .0. #41687
Elizabeth D. Snover
Attorney 1.0. #200997
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
Telephone (717) 761-4540
Attorneys for Petitioner
:328633
VERIFICA TION
I, William Donald Maxwell, 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.A. 94904 relating to unsworn falsification to authorities.
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W. Donald Maxwell
Dated: L/-L/~. Og
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
NO. ORPHANS' COURT
ESTATE OF ROBERT WAYNE MAXWELL
PETITION PURSUANT TO SECTION 5511 OF THE PROBATE, ESTATES
AND FIDUCIARY CODE TO ADJUDICATE ROBERT WAYNE MAXWELL TO BE INCAPACITATED
AND TO APPOINT A PLENARY GUARDIAN
ACCEPTANCE OF PROPOSED PLENARY GUARDIAN
William Donald Maxwell of 137 Sandollar Drive, Panama City Beach, FL 32408 hereby agrees to
accept the appointment as plenary guardian of the person and estate of his brother Robert Wayne Maxwell,
if he is adjudged to be an incapacitated person by the Cumberland County Orphans' Court.
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W. Donald Maxwell
Dated: 1./ -4-0f)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
NO. ORPHANS' COURT
ESTATE OF ROBERT WAYNE MAXWELL
PETITION PURSUANT TO SECTION 5511 OF THE PROBATE, ESTATES
AND FIDUCIARY CODE TO ADJUDICATE ROBERT WAYNE MAXWELL TO BE INCAPACITATED
AND TO APPOINT A PLENARY GUARDIAN
PRELIMINARY DECREE
AND NOW, this day of , 2008, upon consideration of the
annexed Petition, it is ORDERED AND DECREED that a hearing on this matter is set for the day of
, 2008, in Courtroom No. , at o'clock _.M. at the
Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, and that a Citation be
issued to Robert Wayne Maxwell commanding him to show cause why he cannot appear at the
aforementioned hearing pursuant to the Petition of William Donald Maxwell to have Robert Wayne Maxwell
adjudicated an incapacitated person and to have William Donald Maxwell appointed as the plenary guardian
appointed for his person and estate. Notice of the hearing shall be given to Robert Wayne Maxwell in
accordance with 20 P.S. S 5511 (a) not less than twenty (20) days prior to the hearing.
BY THE COURT:
J.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
NO. ORPHANS' COURT
ESTATE OF ROBERT WAYNE MAXWELL
PETITION PURSUANT TO SECTION 5511 OF THE PROBATE, ESTATES
AND FIDUCIARY CODE TO ADJUDICATE ROBERT WAYNE MAXWELL TO BE INCAPACITATED
AND TO APPOINT A PLENARY GUARDIAN
FINAL ORDER OF COURT APPOINTING PLENARY GUARDIAN
AND NOW, this
day of April, 2008, a hearing in this case having been held on
, 2008, and it appearing to the Court that Robert Wayne Maxwell was
properly served with a Citation and Notice of this hearing, and properly excused based on the testimony of
his treating physician, the Court finds from the testimony presented at the hearing:
1. That Robert Wayne Maxwell suffers from severe medical conditions which totally impairs his
capacity to receive and evaluate information effectively and to make and communicate
decisions concerning management of financial affairs or to meet the essential requirements
for his physical health and safety.
2. That there exists no other less restrictive alternative mechanism for decision making.
3. That based on the total incapacity of Robert Wayne Maxwell to receive and evaluate
information and to make or communicate decisions, a plenary guardian of the person and a
plenary guardian of the estate are required on a permanent basis.
NOW, THEREFORE, based on the clear and convincing evidence supporting the foregoing findings it
is ORDERED, ADJUDGED and DECREED that Robert Wayne Maxwell be and is hereby adjudged an
incapacitated person and William Donald Maxwell is hereby appointed Plenary Guardian of the Person and
the Estate of Robert Wayne Maxwell.
A Report by the Plenary Guardian shall be filed on an annual basis with the Court.
No bond shall be required of the Plenary Guardian named herein.
The Plenary Guardian is hereby authorized to make decisions on Robert Wayne Maxwell's behalf
concerning his medical care and treatment including his admission to nursing homes, personal care
facilities, hospitals and other healthcare providers, as well as to consent to and authorize medical treatment;
and the Plenary Guardian herein appointed is further authorized to take possession and secure all of the
assets of his Estate including the principal and interest, and to conduct his business affairs on his behalf,
including the sale or transfer of any of his assets including all real estate owned by him, payment of his bills
and expenses, access to his bank accounts, investment of assets and all matters related thereto.
BY THE COURT:
J.