HomeMy WebLinkAbout02-17-09 (2)
IN THE MATTER OF THE IN THE COURT OF COMMON PLEAS
PERSON and ESTATE OF OF CUMBERLAND COUNTY,
KATHLEEN S. GURY, PENNSYLVANIA
AN ALLEGED INCAPACITATED
PERSON ORPHAN'S COURT DIVISION
NO. 2009- ~...~
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PETITION FOR THE APPOINTMENT OF i ~
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PERMANENT PLENARY GUARDIAN OF THE PERSON ANI~ `~''
ESTATE IN ACCORDANCE WITH 20 P.S.§5513 _ ~o`--~-
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AND NOW COMES THE PETITIONER, Melissa D. Reed, niece oche
alleged incapacitated person, Kathleen S. Gury, by her attorney, George F. Douglas, III,
represents and avers as follows:
1. The Petitioner, Melissa D. Reed, resides at 2796 Leitersburg Road,
Waynesboro, Franklin County, Pennsylvania.
2. The alleged incapacitated person, Kathleen S. Gury, age 88, is of 630
Brenton Street, Shippensburg, Cumberland County, Pennsylvania and has resided there
for a period of three (3) months prior to the filing of this Petition.
3. Kathleen S. Gury is currently a patient at the Hershey Medical Center,
P.O. Box 850, Hershey, Dauphin County, Pennsylvania.
4. Kathleen S. Gury exhibits symptoms of being in a coma-like state.
5. Kathleen S. Gury's mental incapacity prevents her from managing and
caring for the affairs of her person and estate.
6. Kathleen S. Gury is being treated by Dr. Darren P. Bryant at the Hershey
Medical Center.
7. The permanent guardianship of the person is necessary for the following
reasons:
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a) Kathleen S. Gury is an elderly woman who lacks the capacity to live
independently. Her current home at 630 Brenton Street, Shippensburg,
Pennsylvania is in a deplorable condition characterized by extreme
disorganization, uncontrolled filth and generally unhealthy conditions.
b) At this time, there is no other reasonable alternative to affect the proper
care of Ms. Gury besides the appointment of a guardian of the person.
g) Melissa D. Reed is willing to accept appointment as Permanent Guardian
of her aunt, Ms. Gury.
h) Without the appointment of a guardian, Kathleen S. Gury will be unable to
receive the care necessary for her wellbeing.
WHEREFORE, the Petitioner respectfully request that:
1. The Court appoint Melissa D. Reed as Permanent Plenary Guardian of the
person and estate of Kathleen S. Gury.
Respectfully submitted,
Date: '2, '~ b~
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George F. Douglas, III, Esquire
Salzmann Hughes, P.C.
354 Alexander Spring Rd. Suite 1
Carlisle, PA 17015
Supreme Court No. 61886
VERIFICATION
I hereby verify that the facts and information set forth in the foregoing Petition for the
appointment of Emergency Plenary Guardian of the Person and Estate in accordance with 20
P.S.§5513 of Kathleen S. Gury are true and correct to the best of my knowledge, information
and belief. I understand that any false statements contained herein are subject to the penalties
of 18 Pa.C.S.Section 4904, relating to unsworn falsification to authorities.
Date: ~. ~ ~ 1'(7 Cf
Mel' sa D. Reed