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HomeMy WebLinkAbout98-0515II\l THE MATTER OF IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA BEULAH E. JUMPER an adjudicated incapacitated person :ORPHANS' COURT DIVISION ~? ~ - "~ ~-, ~, NO. 98-515 ~' ~ `f' ,~. -w _ ._._ r r N - -= ~: , N - ~> PETITION FOR APPOINTMENT OF CO-GUARDIAN ' ~~ ;,~ -~ _ PURSUANT TO 20 Pa.C.S.A. ~ 5514 ~ 3 r . __., : ~" .~ _ AND NOW, come Petitioners, Glenn J. Jumper and Sherry L. Jumper, by and through. tr~eir attorneys, GERBER & ASSOCIATES, and request that Sherry L. Jumper be added as a co- guardian to the plenary guardianship of Beulah E. Jumper, currently managed solely by Glenn J. Jumper, guardian, and, in support thereof, set forth the following: 1. Glenn J. Jumper is an adult individual residing at 90 Fox Hollow Road, Shern~ans Dale, Pennsylvania 17090. 2. Sherry L. Jumper is an adult individual residing at 90 Fox Hollow Road, Shermans Dale, Pennsylvania 17090. 3. Glenn J. Jumper and Sherry L. Jumper are husband and wife, respectively. 4. Beulah E. Jumper is an adult individual living in an adult group home at 8 South F:oad, Mechanicsburg, Pennsylvania 17050. 5. Beulah E. Jumper and Glenn J. Jumper are biological siblings. 6. On or about the 22°a day of July, 1998, this Court adjudicated Beulah E. Jumper wholly incapacitated as a result of her mental retardation and as a result of her having an intelligence quotient of ten (10) and appointed Glenn J. Jumper her plenary guardian. A copy of :>aid Order is attached hereto and incorporated herein and marked as Exhibit "A". 7. Since July 22"d, 1998, Glenn J. Jumper has acted as the plenary guardian of ]Beulah E. Jumper. 8. Glenn J. Jumper has, for the past ten (10) years, worked third shift, from 9:30 p.m. through b:30 a.m. and has often slept during the workday. 9. Sherry L. Jumper is a homemaker and has, for the past ten (10) years, performed most of the guardianship duties of her husband. 10. Recently, Glenn J. Jumper was diagnosed with lung cancer. 11. Glenn J. Jumper's health problems and work schedule have made it difficult for iVlr. Jumper to manage Beulah's affairs alone. 12. Because Sherry L. Jumper has been performing the duties of guardian for the past decade, Petitioners feel strongly that the appointment of Sherry L. Jumper as co-guardian would ease the burden on Glenn J. Jumper while not disturbing the guardianship. 13. Beulah E. Jumper has a second sibling, Esther Jumper, an adult individual residing at 22 Lightner Road, Landisburg, Pennsylvania 17040. 14. Esther Jumper has not and does not maintain any contact with Beulah E. Jumper. 15. Beulah E. Jumper has no other siblings. 1 b. Beulah E. Jumper has no children or grandchildren. 17. Beulah E. Jumper's parents are both deceased. 18. Beulah E. Jumper receives services through Cumberland County's Mental Health Mental Retardation program. 19. Cumberland County MHMR is well aware that Sherry L. Jumper has been pe;rforming most of the guardianship duties for Glenn J. Jumper. A letter of recommendation and support is attached hereto and incorporated herein and marked as Exhibit "B". 20. Beulah E. Jumper receives support services through Keystone Human Services. 21. Keystone Human Services is well-aware that Sherry is an integral part of Beulah's life and they support Sherry being named co-guardian. A letter of recommendation and support is attached hereto and incorporated herein and marked as Exhibit "C". 22. Beulah E. Jumper receives program services through United Cerebral Palsy Alternatives. 23. UPC Central PA is well-aware that Sherry has been an exceptional advocate for Beulah. A letter of recommendation and support is attached hereto and incorporated herein and marked as Exhibit "D". 24. Beulah E. Jumper receives regular medical care by Dr. Kathleen L. Sempeles. 25. Dr. Sempeles found that the plenary guardianship continues to be necessary for the maintenance and support of Beulah E. Jumper. A letter of recommendation and support is attached hereto and incorporated herein and marked as Exhibit "E". 26. The proposed co-guardian, Sherry L. Jumper, has no interest adverse to the interest of Beulah E. Jumper. 27. Besides Glenn J. Jumper, no other guardian has been appointed by any court. 28. The consent of the proposed co-guardian is attached hereto. WHEREFORE, the Petitioners respectfully request that this Court award a citation directed to Beulah E. Jumper, Esther Jumper and such other persons or entities as the Court may direct, to show cause why the proposed co-guardian should not be appointed. Respectfully submitted, GERBER & ASSOCIA Robert J. Dailey, I.D. 203418 46 East Main Street Palmyra, PA 17078 (717) 838-5411 IN THE MATTER OF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BEULAH E. JUMPER an adjudicated incapacitated person :ORPHANS' COURT DNISION NO. 98-515 VERIFICATION We, Gleml J. Jumper and Sherry L. Jumper, hereby acknowledge that we have read the ~:oregoing Petition for Appointment of Co-Guardian and verify that the facts stated therein are true and correct to the best of our knowledge, information and belief. We understand that false statements made herein are subject to penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Late: ~// ,r-- Date: `ti ~ I Q~ ~~~ ~ ~ Glc~fin J~7um~_ ~. ,* ~"" ~, p '~~ ~ :Z:. •,- _~ iN THE MATTER OF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BEULAH E. JUMPER, :ORPHANS' COURT DIVISION An Alleged Incapacitated Person N0. 98-51 ~ : INCAPACITATED PERSON IN RE: PETITION FOR APPOINTMENT OF A GUARDIAN OPINION AND ORDER OF COURT BEFORE HOPPER, P.J. The present case is before the Court on the Petition of Glenn J. Jumper, It is requested that Beulah E. Jumper be adjudicated an incapacitated person, and that a guardian be appointed. Following a hearing, the following Findings of Fact and Order of Court are made and entered: FINDINGS OF FACT 1. The Beulah E. Jumper suffers from mental retardation, having an tQ of approximately 10, which is in the profound mental retardation range. This condition ir-npairs the individual's capacity to make and communicate decisions. 2. Ms. Jumper also has additional diagnoses of pervasive developmental disorder and obsessive compulsive disorder. 3. Notwithstanding that, Ms. Jumper has a very supportive family and enjoys thE~ support of the agency here involved. Testimony from Greg Knox, the county MR director, supports, the finding that the goals of both the state and the county support the involvement of family members in the residential placement and selection of services. . :I. tN :i,",. 4. The type of guardian required is a plenary guardian of the person. 5. The duration of the guardianship involved would be indefinite pending further Order of Court. The guardian shall exercise the following duties. A. Arrange for the care, maintenance and custody of the incapacitated person. This shalt include medical and psychological services. B. Designation of the place for the incapacitated person to live. C. Arrange for the provision of all available services to maximize her self reliance and independence. D. To arrange for other matters relating to the care and welfare of the incapacitated person. 6. The Court recognizes that community placement may be an option for Ms. Jumper and encourages the guardian to maintain an open mind ~n reference to the same and to explore that option as requested by the county agency from time to time. 7. The proposed guardian, Glenn J. Jumper; has no interest adverse to that of Beulah E. Jumper. As a consequence of the foregoing Findings of Fact, the following Order of Court will be entered. ORDER OF COURT AND NOW, thisL Z day of July, 1998, .based upon the Petition To Adjudicate Incapacity And Appoint A Guardian Of The Person ,and following a hearing, the Court finds that the allegedly incapacitated person, Beulah E. Jumper, is an incapacitated person in that, because of menial retardation, she is unab{e to receive and evaluate information effectivety and communicate decisions sufficiently, and to such a degree that she is unable to meet the essential requirements for her physical health and safety. She is, therefore, adjudicated an incapacitated person, and Glenn J. Jumper is appointed plenary guardian of her person. The guardian shall exercise the following duties: A. Arrange for the care, mainkenance and custody of the incapacitated person. This shall include medical and psychological services B. Designation of the place for the incapacitated person to live. C. Arrange for the provision of all available services to maximize her self reliance and independence: D. To arrange for other matters relating to the care and welfare of the incapacitated person. This Order shall continue pending further Order of Court. BY THE CaURT, GEORGE E. HOB ER, P.J. ROE3E=RT L. 4'BRIEN, ESQUIRE Solicitor for CumberfandlPerry MH/MR Cumberland & Perry Counties' Mental Health and Mental Retardation Program Empowering and supporting individuals in the community with Mental Health & Mental Retardation needs Date: 7!22/2008 To: Mr. Robert Dailey From: Keli Whitney, Support Coordinator Subject: Petition for co-guardianship Mr. Dailey, On behalf of Cumberland Perry MH/MR, I would like to offer my support of Sherry Jumper in her effort to become a co-guardian for Beulah Jumper. Sherry is Beulah's sister-in-law and spouse of Glenn 3umper (current legal guardian). Working with Beulah for the past several years, I have observed Sherry's involvement and sincere desire to work on behalf of Beulah's best interests. Sherry performs most duties related to guardianship in the absence of other involved family members. She participates in the development of Beulah's annual support plan, monitors her services and plays a key role in advocating for Beulah. Due to Mr. Jumper's poor health, and in order to continue family involvement on Beulah's behalf, I have no hesitation in recommending her appointment as legal co- guardian of Beulah Jumper. Please feel free to contact our office with any further questions at 240-6325. Respectfully, Keli Whitne y Support Coordinator cc: file Suite 301, 16 W High St, Carlisle PA 17013-2963 Carlisle: 717.240.6320 • All Other Cumberland Areas: 888.697.0371 Ext. 6320 Perry County: 866.240.6320 Fax: 717.240.6415 • E-Mail: MHMRCc~CCPA.NET Nancy Hoke, Program Specialist }~ R:eystone Residence R 940 East Park Drive Harrisburg, PA Robert Daily, Esq 0~'Brien, Baric and Scherer 19 West South Street Carlisle, PA 17013 5f;ptember 2, 2008 Dear Robert Daily: EYSTON E E S I D E N C E `Advancing the Human Sj~irit" I gun writing as a reference for Sherry Jumper, who is applying for co-guardianship on behalf of Bf;ulah Jumper. I have worked with Beulah for eight years as a Program Specialist, with the role of helping the Interdisciplinary Team develop goals and supports for Beulah in her home, supported by Keystone Residence. Sherry and Glenn have been a constant and solid support for Beulah as family, guardian and representative payee for her whole life and especially in transitioning from institutional living to a residential setting. During the last eight years, Sherry has attended every planning meeting for Beulah, advocates for the supports that will meet Beulah's needs, and helps her through difficult moments such as surgical procedures. Sherry and Glenn are the only family that have a relationship with Beulah, and assure that she has spending money for her community life as well as personal needs. They celebrate her birthday, holidays and other events with Beulah, who enjoys this important relationship. Adding Sherry to the guardianship will also help Beulah in expediting the processes that require signatures whf;n Glenn is not immediately available. This is especially critical in regards to Beulah's medical • care. Thank you for your consideration. to a Sincerely, 7 , ~~ Nancy Hoke Program Specialist SCANNED ,940 EAST PARK DRIVE > HARRISBURG, PA 17111-2800 > T: 717.541.8322 > F: 717.541.4354 170 MILL ROAD > CHAMBERSBURG, PA 17201-8609 > T: 717.267.OA42 ~ F: 717.264.9574 WWW.KEYSTONEHUMANSERVICES.ORG An r+beuq' of Kerstotrc Honorer Swrices "A copy of tfie ofJtcia( regi.rnzuiotr curd /iaanc&d inJinwurNOtr for tieTStane Hennuu .Seruices nun' be oLtaAeed from tl~e Pet+nsplrcutirt Depurcmeul ofSCUte UT crc!ling toll free, toithix Petues7•/Naniu. IB00.7j?-O)99. Hegisn~cllion does no( in+p/P eltdw SeniCUL" ,~ UCP Understanding Disabilities Creating Opportunities Central PA www. ucpcentralpa.org 925 Linda Lane Camp Hill, PA 17011 717-737-3477 voice 717-737-0158 tty 717-975-3333 fax mainoffice @ ucpcentralpa.org To whom it may concern i`~y Warne is Diane Rohis~n and I am the program manager for UCP Alternatives C,arnp I-Dili, C:.i`i liSii, aliCi 1~vCliGi?Ii,Sb:rg: ~ h«~'e ~': Gr~~Pd fOr t11e agency and with Miss Beulah Jumper since 1999. Over this period of time it has been my responsibility to attend many monthly, quarterly and annual meetings regarding Beulah .These meetings involve members of her "team", people from her group home ,day program and her family. Always present at these meetings is her sister in law ,Mrs Sherry Jumper .Mrs Jumper always listens intently at these meetings and takes notes where applicable. She usually arrives with lists of answers from the previous meetings and concerns that she may wish to discus at the current meeting. Mrs Jumper also has attended many medical appo;fitments with Beulah ,this is very helpful in two ways ,Beulah becomes quite anxious on appointments and having a family member around helps calm her and also it is good to have a family member present to answer questions for the doctors. Mrs. Jumper is also a strong and vocal advocate for Beulah. She would be a wonderful choice to be Beulah's legal guardian. Sincerely, Diane Robison Program Manager UCP Alternative Camp Hill, Carlisle ,Mechanicsburg is SCANNED ~-. ` ' Yy .. LEAVE A I_EGACY'° Please remember LICP Cenb~al PA ire yoto~ firtur~e financial plans A United Way Agency Thy a//ie~- I - .L'i~m ~ufun rmd /inun~ ~ / -n/urmolion /m- (iCP Cewun/ l~l niu~ Ge obtained hvur do %il Uepnnmurt uJ S~utr br ~-aping Col/ jree ~i id~in Priu~n haruu. b'0a-7i?-a99J. R~gievratiu~i dnea our imply u~dur.v~•meN. PENNSTATE i ne ivituon ~. nersney lvieatcal Lenter The College of Medicine Penn State College of Medicine Tel: (717) 69]-1212 The Milton S. Hershey Medical Center Fax: (7]7) 691-5354 University Physician Group Silver Spring Family Practice 3 Flowers Drive Mechanicsburg, PA 17050 Augusil 1, 2008 Name: JUMPER, BEULAH E HMC Number: 1314752 DOB: 01 /27!1957 Date of Service: 07/29/2008 Attorney Robert J. Dailey 19 West South Street Carlisle., PA 17013 Dear Mr. Dailey: I understand that Beulah Jumper's sister-in-law is petitioning the court for co-guardianship for Beulah. Beulah is 51 years old and has profound developmental disability, which includes profound mental retardation, severe vision limitations (legally blind), perceptual speech disorder and autistic behavior. She needs constant supervision. She is well situated in her current group home where she seems content and is well taken care off. I see her in the office approximately every 2 months and have observed the kind of detailed care she receives. She will continue to need this level of care indefinitely, She will also require a guardian for the rest of her life. f hope this information helps with Glenn and Sherry Jumper's petition for this co-guardianship as their role in this capacity wilt be needed lifelong. SIrlCerely, n ~ ~. Sempeles, Kathleen L, MD ~~. `7 ~ 1l(lQ IN THE MATTER OF BEULAH E. JUMPER an adjudicated incapacitated person IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. 98-515 CONSENT OF INDIVIDUAL TO APPOINTMENT AS CO-GUARDIAN I, Sherry L. 3umper, hereby consent to my appointment as co-guardian of the person and estate of Beulah E. Jumper, an adjudicated incapacitated person and certify the following: I am 18 years of age or older; 2. I reside at 90 Fox Hollow Road, Shermans Dale, Pennsylvania 17090; I am a homemaker and have been for most of my life; 4. I speak, read and write the English language; 5. I am a citizen of the United States; 6. I do not have any interest adverse to the interests of Beulah E. Jumper; and 7. I am not a fiduciary, or an officer or employee of a corporate fiduciary, of an estate in which Beulah E. Jumper has an interest, or a surety, or an officer or employee of a corporate surety, of such a fiduciary. 1~ G' Date: ~__._ Sherry Lt'Ju per f ~ LC~' ~~'' SClaN1~6~~D C~' LAW OFFICE OF (serberTanner & ASSOCIATES Daryl ). Gerber Megan E. Ryland-Tanner Shawn J. Jayman 46 East Main Street Palmyra, PA 17078 e 717-838-5411 r 717-838-3047 www.gerberlawoffice.com Curberland County Register of Wills & Orphans' Court 1 Courthouse Square Carlisle, PA 17013 September 19, 2008 RE: Beulah E. Jumper, Co-Guardian Appointment; Case No. 98-515 In the Matter of Beulah E. Jumper, an adjudicated incapacitated person Dear Sir or Madam: Enclosed please find the following documents regarding the above captioned matter, pertaining to the appointment of a co-guardian of Beulah E. Jumper: 1. 1 Original Set containing Preliminary Decree, Final Decree, Important Citation with Notice, Related Matters, Petition for Appointment of Co-Guardian, Verification, Exhibit's A-F. 2. 9 Copies of the Set of documents listed above to send in the S.A.S.E. 3. Self Address Stamped Envelopes for the following: Beulah Jumper, Glenn & Sherry Jumper, Esther Jumper, Cumberland Counties Mental Health & Mental Retardation Program, Keystone Residence to the Attention of Nancy Hoke, Program Specialist, Understanding Disabilities Creating Opportunities, Dr. Kathleen L. Sempeles and to my office, The Law Office of Gerber & Associates. 4. Check made out to Cumberland County Register of Wills for $15.00. If you would please send my office a time stamped copy. R1D/rsp Enclosures: Preliminary Decree Final Decree Important Citation with Notice Related Matters Petition for Appointment of Co-Guardian Verification Exhibits A-F Self Addressed Stamped Envelopes $15.00 Check Very truly yours, GERBER & ASSOCIATES - v ~, .. Robert J. Dailey, Esq C7 -_~ "17 ~~ t= ':; r-~-~ - _, --a ,~i;_. .._ `_) 1 (_ ~ -il ,, r ,- :~ :.177 --1 -:-~ na cc~ c~ c:s~ C/3 f *"1 - -p ' ` ~ N N -,. ___ Z3 _ ~ :~: .~ SEP 'L 3 2008 (~ ~ I IN THE MATTER OF IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA BEULAH E. JUMPER an adjudicated incapacitated person :ORPHANS' COURT DIVISION NO. 98-515 c? , -' Tl [V _ PRELIMINARY DECREE `~~ =~` _ , ~, . _: xp AND NOW, this day of , 2008, it is here order .. and decreed that: _:-~ ~ 1. A hearing on the attached Petition for Appointment of Co-Guardian is scheduled for ~~ ~~2 ,the /~~day of , 2008, at 1Q:~5 p~. in Courtroom No. ~ of the Cumberland County Courthouse, Carlisle, Pennsylvania; 2. Petitioners shall serve this Petition along with the Citation at least twenty (20) days prior to the hearing upon Beulah Jumper, Glenn Jumper, Sherry Jumper, Esther Jumper, Cumberland County MHMR, the residential home provider and all such other persons as this Court shall require and shall file proof of service with this Court prior to the hearing; 3. At ]east twenty (20) days prior to the hearing, notice of the hearing shall be given to Beulah Jumper, Glenn Jumper, Sherry Jumper, Esther Jumper, Cumberland County MHMR, the residential home provider and all such other persons as this Court shall require; 4. Cumberland County MHMR shall obtain representation for the incapacitated person and shall notify this Court in writing at least seven (7) days prior to the hearing that it has secured counsel for Ms. Jumper; and S. Beulah E. Jumper shall be present at the hearing unless (i) the Court is satisfied, upon representation of a physician or licensed psychologist or psychiatrist, that her physical, ~ti J~ mental, emotional or psychological condition would be harmed by her presence, (ii) it is impossible for her to be present because of her absence from the Commonwealth or (iii) the Court is satisfied, upon representation by the incapacitated person's counsel, that her presence is unnecessary and would be counterproductive. ~~~~~~ BY THE COURT, ORPHANS' COURT DIVISION COURT OF COMMON PLEAS OF CUMBERLAND COUNTY In Re: BEULAH E JUMPER pENNSYLVANIA NO. 21-98-0515 CERTIFICATE OF SERVICE OF ORDER ORDER DATE: 09-23-08 JUDGE'S INITIALS: JWO TIME STAMP DATE: 09-25-08 ~ ~: PRELIMINARY DECREE SERVICE TO: ESTHER JUMPER LAW OFFICES OF GERBER AND ASSOC BEULAH JUMPE CLIMB O RED DCEONLCE IKATIHLEEN L SEMPLE~LES GLENN J & SHERRY L JUMPER M KE UNDERSTANDING DISABILITIES CREATING OPPORTUNITIES METHOD OF MAILING: ® LISPS RRR ^ HAND DELIVERED ^ OTHER MAILED:C~~ -~ SERVICE TO: METHOD OF MAILING: ^ LISPS ^ RRR ^ HAND DELIVERED ^ OTHER MAILED: ENVELOPES PROVIDED BY: ® PETITIONER ^ JUDGE ^ CLERK OF ORPHANS COURT ENVELOPES PROVIDED BY: ^ PETITIONER ^ JUDGE ^ CLERK OF ORPHANS COURT Deput Clerk o rphans' Court f IN RE: BEULAH E. JUMPER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. 21-98-0515 r,.~ ~:~ IMPORTANT NOTICE `~ o ,- CITATION WITH NOTICE '~ --~ '---~' - ~s` 1, A petition has been filed with the Court to have you declared an Incapacitated Perk ii. If tie - l~. -;'=:~ Court finds you to be an Incapacitated Person, your rights will be affected, including yoig~t toT~ .-~ ~ - manage money and property and to make decisions. A copy of the petition which has lien filed b~nthe petitioners Glenn J. Jumper, Sherry L. Jumper by and through their attorneys Gerber & Associates is attached. You are hereby ordered to appear at a hearing to be held in Court Room No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania, on December 15 , 2008, at 10:45 A.M. to tell the Court why it should not find you to be an incapacitated Person and appoint a Guardian to act on your behalf. To be an incapacitated Person means that you are not able to receive and effectively evaluate information and communicate decisions and that you are unable to manage your money and/or other property, or to make necessary decisions about where you will live, what medical care you will get, or how your money will be spent. At the hearing, you have the right to appear, to be represented by an attorney, and to request a jury trial. If you do not have an attorney, you have the right to request the Court to appoint an attorney to represent you and to have the attorney's fees paid for you if you cannot afford to pay them yourself. You also have the right to request that the Court order that an independent evaluation as to your alleged incapacity. If the Court decides that you are an Incapacitated person, the Court may appoint a Guardian for you, based on the nature of any condition or disability and your capacity to make and communicate decisions. The Guardian will be of your person and/or your money and other property and will have either limited or full powers to act for you. If the court finds you are totally incapacitated, your legal rights will be affected and you will not be able to make a contract or gift of your money or other property. If the court finds that you are partially incapacitated, your legal rights will also be limited as directed by the Court. If you do not appear at the hearing (either in person or by an attorney representing you) the court will still hold the hearing in your absence an may appo' t the Guardian requested. Date:09/25/08 By: Clerk, Orphans' Court Division Cumberland County, Carlisle, PA My Commission Expires 1St Monday, January, 2010 ORPHANS' COURT DIVISION COURT OF COMMON PLEAS OF In Re: BEULAH E JUMPER CUMBERLAND COUNTY PENNSYLVANIA NO. 21-98-0515 CERTIFICATE OF SERVICE OF ORDER ORDER DATE: 09-23-08 JUDGE'S INITIALS: JWO TIME STAMP DATE: IN RE: CITATION SERVICE TO: ESTHER JUMPER LAW OFFICES OF GERBER AND ASSOC BEULAH JUMPER CUMBERLAND COUNTIES MENTAL HEALTH & MENTAL RETARDATION PROGRAM KEYSTON RESIDENCE, KATHLEEN L SEMPLELES GLENN J & SHERRY L JUMPER UNDERSTANDING DISABILITIES CREATING OPPORTUNITIES METHOD OF MAILING: ® USPS ^ RRR ^ HAND DELIVERED ^ OTHER MAILED:~-3C~ -~~$ ENVELOPES PROVIDED BY: ® PETITIONER ^ JUDGE ^ CLERK OF ORPHANS COURT SERVICE TO: METHOD OF MAILING: ^ USPS ^ RRR ^ HAND DELIVERED ^ OTHER MAILED: ENVELOPES PROVIDED BY: ^ PETITIONER ^ JUDGE ^ CLERK OF ORPHANS COURT ~pc~ De u Cle of Orphans' Court IN THE MATTER OF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BEULAH E. JUMPER an adjudicated incapacitated person :ORPHANS' COURT DIVISION NO. 98-515 CERTIFICATE OF SERVICE I hereby certify that on or about October 3, 2008, I, Robert J. Dailey, Esquire, of GERBER & ASSOCIATES, did contact the Orphans' Court and verify that it received my envelopes for the Petition and my envelopes for the Citation and that it did send out copies of the tome-stamped Petition for Appointment of Co-Guardian, as well as the signed Citation and Preliminary Decree by first class U.S. mail, postage prepaid, to the interested individuals listed below, as follows: ]3eulah Jumper Glenn Jumper '3 South Road 90 Fox Hollow Road Mechanicsburg, PA 17050 Shermans Dale, PA 17090 Cumberland County MHMR Keystone Residence 16 W. High St., Suite 301 90 East Park Drive Carlisle, PA 17013 Harrisburg, PA 17111 Kathleen Sempeles, M.D. Esther Jumper 3 Flowers Drive 22 Lightner Road Mechanicsburg, PA 17050 Landisburg, PA 17040 dd '~G~ ~~d~~:i~zlVtitn~ ~dn~~ s,~~ao 4Z ;Zf ~~ ~- ~©~ BGOZ ~~ ~>- ~,. .. . ,, _ ~ _. Sherry Jumper 90 Fox Hollow Road Shermans Dale, PA 17090 Central PA UCP 925 Linda Lane Camp Hill, PA 17011 •~ ., ~.-' r~ ~`" Robert J. Dailey, esquire Attorney for Petitioners IN THE MATTER OF IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUN'I'y,PENNSYLVANIA BELULAH E. JUMPER an adjucated incapacitated person ORPHANS' COURT DIVISION N . ~ ~ ~- _,~ a-~ T, • NO. 98-515 C. -a rn ~, ~~ .: `: _~ r c~ ~~ ;~. m r, ,- ---. = " -t-~ c,3~-, ~ pp : ; - ; . , c-r t7r,~ MOTION TO AMEND PRELIMINARY DECREE `~ " - " -p ` ~ _~,.i `~' -i-• ~t 7C.7 ~ _ t AND NOW, come Petitioners, Glenn J. Jumper and Sherry L. Jumper, by and throw their . `' attorney, Robert J. Dailey of GERBER & ASSOCIATES, and request that this honorable Court amend the Preliminary Decree of September 23, 2008 and, in support thereof, set forth the following: 1. On or about September 22, 2008, Petitioners filed with this Court a Petition for Appointment of Co-guardian pursuant to 20 Pa.C.S.A. Section 5514. 2. On or about September 23, 2008, this honorable Court issued a Preliminary Decree which is attached hereto, incorporated herein, and marked as Exhibit "A". 3. After discussion with Cumberland County MHMR, Petitioners' counsel came to realize that is it normally the duty of the Court, not MHMR, to appoint an attorney for incapacitated persons. 4. After a brief discussion with this Court on Wednesday, November 26, 2008, this Court informed Petitioners' Counsel that due to the nature of this case and the ongoing permanent mental retardation of the adjudicated incapacitated person, Beulah E. Jumper, the appointment of an attorney would not be necessary for this simple Petition to add a co-guardian. 5. This Court has requested that Petitioners make arrangements for the adjudicated incapacitated person, Beulah E. Jumper, to be present at the hearing scheduled for December 15, 2008 at 10:45 AM in courtroom #1 of the Cumberland County Courthouse, Carlisle, Pennsylvania. WHEREFORE, Petitioners respectfully request that paragraphs 4 and 5 of the Preliminary Decree be amended to require only that the adjudicated incapacitated person, Beulah E. Jumper, be individually present at the hearing and that she be afforded at least 7 days notice. Respectfully submitted, GERBER & ASSOCIA' Robert J. Dailey, squire Attorney ID No. 2 3418 46 East Main Street Palmyra, PA 17078 rdailey(a~ ~erberlawoffice. com Phone: 717-838-5411 Fax: 717-838-3047 Attorney for Petitioners IN THE MATTER OF BELULAH E. JUMPER an adjucated incapacitated person IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA ORPHANS' COURT DIVISION NO. 98-515 VERIFICATION I, Robert J. Dailey, Esquire, verify that I am the attorney for Glenn and Sherry Jumper, and as such I am authorized to give this verification on behalf of them. Accordingly, I verify that the facts set forth in the foregoing Motion to Amend Preliminary Decree are true and correct to the best of my knowledge information and belief. Dated: ~ ~ ~ ~ ~l.U IN THE MATTER OF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'I'y,PENNSYLVANIA BELULAH E. JUMPER an adjucated incapacitated person ORPHANS' COURT DIVISION NO. 98-515 CERTIFICATE OF SERVICE Robert J. Dailey, Esquire, of the Law Office of Gerber & Associates, both deposes and says that he caused to be mailed by U.S. Mail, First Class, a copy of Petitioners' Motion to Amend Preliminary Decree on the above captioned matter on November 26, 2008 to the following interested individuals: Beulah E. Jumper 8 South Road Mechanicsburg, PA 17050 Cumberland County MHMR 16 West High Street, Suite 301 Carlisle, PA 17013 Glenn Jumper 90 Fox Hollow Road Shermans Dale, PA 17090 Keystone Residence 90 East Park Drive Harrisburg, PA 17111 Sherry Jumper 90 Fox Hollow Road Shermans Dale, PA 17090 Central PA UCP 925 Linda Lane Camp Hill, PA 17011 Kathleen Sempeles, M.D. 3 Flowers Drive Mechanicsburg, PA 17050 RdKert J. Dailey,' Attorney I.D. No. Esther Jumper 22 Lightner Road Landisburg, PA 17040 ~; C/ I Dated: t ~ / 02 ~' a 0 ~g QED 0 9 2C'~3 6, IN THE MATTER OF BELULAH E. JUMPER an adjucated incapacitated person IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA ORPHANS' COURT DIVISION NO. 98-515 AMENDED PRELIMINARY DECREE AND NOW, this ! G~~day of Tom- t L ,2008 it is hereby ordered and decreed that the Preliminary Decree issued by this Court on September 23, 2008 is amended with respect to paragraphs 4 and 5 of that decree to simply require that the adjudicated incapacitated person, Beulah E. Jumper, be individually present at the hearing and that she be afforded at least 7 days notice thereof. n o -~ O -~ m o , >`7 r n -'(T ~'~~ O . V i.~~' a (_),'_ ~ -T! _ D y .~. .. 4 CJ1 Q1 - -} ~_ '' T; l „i V V BY THE COURT, ORPHANS' COURT DIVISION COURT OF COMMON PLEAS OF In Re: BEULAH E JUMPER CUMBERLAND COUNTY PENNSYLVANIA NO. 98-515 CERTIFICATE OF SERVICE OF ORDER ORDER DATE: JUDGE'S INITIALS: TIME STAMP DATE: IN RE: AMENDED PRELIMINARY DECREE SERVICE TO: BEULAH JUMPER CENTRAL PA UCP ESTHER JUMPER GLENN JUMPER KEYSTONE RESIDENCE KATHLEEN SEMPELES SHERRY JUMPER CC MHMR METHOD OF MAILING: ENVELOPES PROVIDED BY: ® USPS ^ RRR ^ HAND DELIVERED ^ OTHER MAILED: 12/10/08 ® PETITIONER ^ JUDGE ^ CLERK OF ORPHANS COURT SERVICE TO: METHOD OF MAILING: ^ USPS ^ RRR ^ HAND DELIVERED ^ OTHER MAILED: ENVELOPES PROVIDED BY: ^ PETITIONER ^ JUDGE ^ CLERK OF ORPHANS COURT u Clerk of Orphans' Court IN THE MATTER OF IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA BEULAH E. JUMPER an adjudicated incapacitated person :ORPHANS' COURT DIVISION NO. 98-515 FINAL DECREE AND NOW, this _~~day of ~~[., , 2008, upon consideration of the Petition for Co-Guardian and upon a hearing on the matter, it is hereby ORDERED that Sherry L. Jumper is appointed co-guardian of the person and estate of Beulah E. Jumper, an incapacitated person; and it is FURTHER ORDERED that Glenn J. Jumper shall continue to act as guardian of the person and estate of Beulah E. Jumper, an incapacitated person; and it is FURTHER ORDERED that this Order shall continue pending further Order of Court. b~ ~;.. ~`-~ ~b,~~~ ddO ~~ ~ ~~~d S/ ,? 1! t; fn ,! ~~..~ 1 nr~- ~: ~, .~;: BY THE COURT, In Re: BEULAH E. JUMPER ORPHANS' COURT DIVISION COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO.21-98-0515 CERTIFICATE OF SERVICE OF ORDER ORDER DATE: 12/15/08 JUDGE'S INITIALS: JWO TIME STAMP DATE: 12/15/08 IN RE: FINAL DECREE SERVICE TO: CENTRAL PA UCP ESTHER JUMPER KATHLEEN SEMPELES MD, BEULAH JUMPER, GLENN JUMPER SHERRY JUMPER CUMBERLAND COUNTY MHMR, KEYSTONE RESIDENCE METHOD OF MAILING: ENVELOPES PROVIDED BY: ® USPS ®PETITIONER ^ RRR ^ JUDGE ^ HAND DELIVERED ^ CLERK OF ORPHANS COURT ^ OTHER MAILED: 12-17-08 ci~uvrrTr 'r'n• METHOD OF MAILING: ^ USPS ^ RRR ^ HAND DELIVERED ^ OTHER MAILED: ENVELOPES PROVIDED BY: ^ PETITIONER ^ JUDGE ^ CLERK OF ORPHANS COURT Depu Clerk of Orphans' Court IN THE MATTER OF IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY~PENNSY~VANIA BEULAH E. JUMPER r - -~ ~~ti:~ an adjudicated incapacitated person :ORPHANS' COURT DIVI ~~ ~ ~ ~ ~ `~ ~_ __ _ ,. -.~ ., . , NO. 98-51 S ~ ~ ~~`' . ` f ~~ „; ., „.~ PETITION FOR APPOINTMENT OF CO-GUARDIAN PURSUANT TO 20 Pa.C.S.A. § 5514 r- ~; .. AND NOW, comes Petitioner, Sherry L. Jumper, by and through her attorney, Robert L. O'Brien, Esquire, also the solicitor for the County MH/IDD program, and requests that Misty M. Jumper be added as a co-guardian to the plenary guardianship of Beulah E. Jumper, currently managed solely by Sherry L. Jumper, surviving guardian, and, in support thereof, set forth the following: 1. Glenn J. Jumper had been serving as a co-guardian of Beulah E. Jumper until his death. 2. Sherry L. Jumper, his widow, is an adult individual residing at 90 Fox Hollow Road, Shermans Dale, Pennsylvania 17090. 3. Sherry L. Jumper had been appointed guardian in an application and Order in 2008. 4. Beulah E. Jumper is an adult individual living in an adult group home at 8 South Road, Mechanicsburg, Pennsylvania 17050. 5. Misty M. Jumper is the daughter of Sherry L. Jumper and the niece of Beulah E. Jumper. 6. On or about the 22°d day of July, 1998, this Court adjudicated Beulah E. Jumper wholly incapacitated as a result of her mental retardation and appointed Glenn J. Jumper her plenary guardian. h~ 7. Sherry L. Jumper and her late husband have been performing the duties of guardian for the past fourteen years, Petitioner feels that the appointment of Misty M. Jumper as co-guardian would guarantee continuity in the care of Beulah in the event Sherry becomes unable to perform her duties. 8. Beulah E. Jumper has a second sibling, Esther Jumper. Esther Jumper has not and does not maintain any contact with Beulah E. Jumper. 9. Beulah E. Jumper has no other siblings. 10. Beulah E. Jumper has no children or grandchildren. 11. Beulah E. Jumper's parents are both deceased. 12. Beulah E. Jumper receives services through Cumberland County's Mental Health IDD program. 13. Cumberland County MH/IDD is well aware that Sherry L. Jumper has been performing the guardianship duties for Beulah E. Jumper. 14. The proposed co-guardian, Misty M. Jumper, has no interest adverse to the interest of Beulah E. Jumper. 15. 50 Pa. C.S.A. Section 5514, provides that the Court may appoint a co-guardian without the requirement of a hearing. 16. Petitioner requests the appointment of Misty M. Jumper as co-guardian. 17. The consent of the proposed co-guardian is attached hereto. WHEREFORE, the Petitioner respectfully requests that this Court appoint Misty M. Jumper as co-guardian Respectfully submitted, Robert L. O'Brien ~_ Robert L. O'Brien, Esquire I.D. 28351 19 West South Street Carlisle, PA 17013 (717) 249-6873 IN THE MATTER OF BEULAH E. JUMPER an adjudicated incapacitated person IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. 98-515 VERIFICATION I, Sherry L. Jumper, hereby acknowledge that I have read the foregoing Petition for Appointment of Co-Guardian and verify that the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Dace: / IN THE MATTER OF IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA BEULAH E. JUMPER an adjudicated incapacitated person :ORPHANS' COURT DIVISION NO. 98-515 CONSENT OF INDIVIDUAL TO APPOINTMENT AS CO-GUARDIAN I, Misty M. Jumper, hereby consent to my appointment as co-guardian of the person and estate of Beulah E. Jumper, an adjudicated incapacitated person and certify the following: 1. I am 18 years of age or older; 2. I reside at 90 Fox Hollow Road, Shermans Dale, Pennsylvania 17090; 3. I am a intake office support associate; 4. I speak, read and write the English language; 5. I am a citizen of the United States; 6. I don not have any interest adverse to the interests of Beulah E. Jumper; and 7. I am not a fiduciary, or an officer or employee of a corporate fiduciary, of an estate in which Beulah F. Jumper has an interest, or a surety, or ~n officer or employee of a corporate surety, of such a fiduciary. Date: f ,~ /, .''~. 4~ isty M. J er~ ~~ IN RE: BEULAH E. JUMPER, An Adjudicated Incapacitated Person oF~~~ IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT ORPHANS' COURT DIVISION N O. 21-98-0515 IN RE: PETITION FOR APPOINTMENT OF CO-GUARDIAN PURSUANT TO 20 Pa. C.S.A. § 5514 ORDER OF COURT AND NOW, this 19th day of February 2013, upon consideration of the Petition for Appointment of Co-Guardian Pursuant to 20 Pa. C.S.A. § 5514, a CITATION is issued upon all interested parties to show cause why the relief requested should not be granted. PETITIONER shall effectuate service of this Citation upon all interested parties. CITATION RETURNABLE within 20 days from the date of service. ~ ...~~ _:-, Thomas ~y `~-'C.I~Jrn m ~ ~ Distribution List: ~ ~ ~ ~ ~~ ~ ~ ,~v?~ ~ ~ ~~ Robert L. O'Brien ° ~ ,~ -~, ~ ~ 19 West South Street ~ c ; `~ --~ „ ~ -~, Carlisle, PA 17013 :~ .y' jv ~ ~~ 6~ ORPHANS' COURT DIVISION COURT OF COMMON PLEAS OF In Re: BEULAH E JUMPER CUMBERLAND COUNTY PENNSYLVANIA NO.21-98-0515 CERTIFICATE OF SERVICE OF ORDER ORDER DATE: 2/ 19/ 13 JUDGE'S INITIALS: TAP TIME STAMP DATE: 2/19/13 IN RE: ORDER SERVICE TO: ROBERT L O'BRIEN 19 W SOUTH ST CARLISLE PA 17013 METHOD OF MAILING: ® USPS ^ RRR ^ HAND DELIVERED ^ OTHER MAILED: 2/ 19/ 13 SERVICE TO: ENVELOPES PROVIDED BY: ® PETITIONER ^ JUDGE ^ CLERK OF ORPHANS COURT METHOD OF MAILING: ^ USPS ^ RRR ^ HAND DELIVERED ^ OTHER MAILED: ENVELOPES PROVIDED BY: ^ PETITIONER ^ JUDGE ^ CLERK OF ORPHANS COURT -, P h' rk of Orphans' Court