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HomeMy WebLinkAbout05-30-08 INRE: PAUL SHEARER KONHAUS, III I ..---) ~ IN THE COURT OF cOMMa. CUMBERLAND COUNTY, -r--,. / ORPHANS' COURT DIVISION : NO: 21-08-0514 MOTION TO DISCONTINUE ACTION ,....) C~ .c;::..:::, c:.o Q -::~ :1:- -< G.) <::) TO THE HONORABLE EDGAR B. BAYLEY, PRESIDENT JUDGFjt~? ~ ::8 N;. AND NOW, come Paul S. Konhaus, Jr., and Melissa J. KonhaustPetitionerfin the above .:::- captioned matter, by their attorneys, Snelbaker & Brenneman, P .C., and respectfully represent as follows: 1. On May 8, 2008, Petitioners filed their Petition for adjudication of incapacity of their son, Paul Shearer Konhaus, III, and for the appointment of a plenary guardian of his person and estate. 2. On May 9, 2008, President Judge Bayley entered an Order directing the issuance of a Citation upon the alleged incapacitated person and Marlin R. McCaleb, Esquire his attorney. 3. On May 16,2008, Marlin R. McCaleb, Esquire, entered his appearance in this action on behalf of Paul Shearer Konhaus, III. 4. Subsequent to the events recited in the foregoing paragraphs, Paul Shearer Konhaus, III, made a remarkable recovery of his mental faculties and is making progress in his physical recovery, thereby rendering him able to make intelligent decisions LAW OFFICES SNELBAKER Be BRENNEMAN. P.C. concerning his personal and business affairs. 5. The need for adjudication has been rendered moot, thus obviating the need for hearing and further proceedings. 6. Marlin R. McCaleb concurs with the relief sought in this Motion (See Concurrence of Counsel or Paul Shearer Konhaus, III, attached hereto). ::E~~=: 'chard C. Snelbaker, Esquire Snelbaker & Brenneman, P.C. 44 West Main Street Mechanicsburg, P A 17055 (717) 697-8528 Attorney for Petitioners -2- LAW OFFICES SNELBAKER & BRENNEMAN, P.C. LAW OFFICES SNELBAKER & BRENNEMAN, P.C. VERIFICATION We, Paul S. Konhaus, Jr., and Melissa J. Konhaus, the Petitioners, in the within action, hereby verify and certify that the facts set forth in the foregoing Motion for Discontinuance of Action are true and correct to the best of our knowledge, information and belief. We understand that any false statements made herein are subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. r) rc~5' ~oJ\~ . 1,- Paul S. Konhaus, II. Dated: !I4&y '2.fj ,2008 LAW OFFICES SNELBAKER & BRENNEMAN. P.C. INRE: PAUL SHEARER KONHAUS, III Dated: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION : NO: 21-08-0514 CONCURRENCE OF COUNSEL FOR PAUL SHEARER KONHAUS. III I hereby concur with the relief sought in the foregoing Motion to Discontinue Action. May 29,2008 ~~4P Mar n . McCaleb, Esquire Attorney for Paul Shearer Konhaus, III