HomeMy WebLinkAbout06-12-09IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISI ON
No. ,~ ~}~ of 2009
EMERGENCY PETITION FOR ADJUDICATION OF INCAPACITY AND
ANT
APPOINTMENT PLENARY GUARDIAN OF THE ESTATE AND PERSON PURSU
TO 20 PA.C.S. §5511 E
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TO THE HONORABLE JUDGE OF SAID COURT: ~ ~ < <
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Petitioner is the TY AARON BERRIOS of HUSBAND (the "alleged ~,
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Incapacitated person"). ~ `~`~'~,,
2. The alleged incapacitated person was born on 10-15-1981, is MARRIED, and resides
at 52 WINDSOR WAY, CAMP HILL, PENNSYLVANIA ).
3. The following persons, to the best of Petitioner's knowledge, information and belief,
are the living next-of-kin of the alleged incapacitated person:
Alicia Boodoo- SISTER
13111 Millhaven Place
Germantown, MD 20874
4. The name and address of the person providing residential services person is/are:
Alicia Boodoo
13111 Millhaven Place
Germantown, MD 20874
5. To the extent known by Petitioner, the assets of the alleged incapacitated person are
valued at approximately $3000.00, comprised of the following holdings:
M & T Bank Account #9830431426
6. Petitioner estimates the alleged incapacitated person's annual income to be
$75,000.00.
7. The alleged incapacitated person was not a member of the armed services of the
United States and is/is not receiving benefits from the United States Veterans'
Administration.
8. The alleged incapacitated person suffers from Paranoid Schizophrenia.
9. Because of his mental and/or physical condition, the alleged incapacitated person is
totally unable to manage his/her financial affairs, property and business and to make
and communicate responsible decisions relating thereto, including the ability to
communicate his/her need for assistance in these areas.
10. Because of his/her impaired mental and/or physical condition, the alleged
incapacitated person lacks the capacity to make or communicate responsible decisions
concerning her person and is unable to pay household bills, and mortgage.
11. The severity of the alleged incapacitated person's mental and/or physical condition
and the lack of viable, less restrictive alternatives necessitate that a plenary guardian of
his/her estate be appointed to manage and handle all aspects of the alleged
incapacitated persons estate, specifically, but not limited to: all issues relating to cash,
checks, bank savings, stocks, bonds, personal property, real property, insurance
policies, government entitlements, taxes, execution of documents, entry in contracts
and the payment of reasonable compensation for services provided to the person.
12. The severity of the alleged incapacitated person's mental and/or physical condition
and the lack of viable, less restrictive alternatives necessitate that a plenary guardian of
her person be appointed to handle all issues relating to the person of the alleged
incapacitated person, specifically, but not limited to: living arrangements, medical and
psychiatric care, employment and discharge of physicians, and other medical decisions
as may be required.
13. Petitioner is not aware that the alleged incapacitated person signed any powers of
attorney or advance health directives or in any other way designated anyone to serve as
his/her agent over any of his/her personal or financial affairs or as her surrogate over
her medical care, or that he/she designated in writing his/her wishes with regard to
health care, including the use or refusal of life sustaining treatment.
14. The proposed plenary guardian of the person and estate is TYAARON BERRIOS,
HUSBAND.
15. The proposed plenary guardians have no interest adverse to the alleged
incapacitated person.
16. No other court has ever assumed jurisdiction in any proceeding to determine the
capacity of the alleged incapacitated person.
17. No other guardian has been appointed for the estate or person of the alleged
incapacitated person.
18. MR. BERRIOS HAS ALL HIS PERSONAL FUNDS IN THE ACCOUNT OF
LUCINDA K. BERRIOS. AND IS UNABLE TO ACCESS ANY FUNDS TO PAY
HOUSEHOLD BILLS, AND FOR MEDICATIONS FOR HIS WIFE.
WHEREFORE, Petitioner respectfully requests that this Court issue a Citation, directed
to the alleged incapacitated person, with notice thereof to be given to her next of kin and
to such other persons as this Court may direct, to show cause why LUCINDA K.
(ZAMIR) BERRIOS, should not be adjudged fully incapacitated and TY AARON
BERRIOS should not be appointed plenary guardian of her estate and his/her person.
Respectfully submitted,
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TY AARON BERRIOS
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MARRIAGE CERTIFICATE
License Number: Z-15-440
1, REVEREND DR JOHN FORDON
hereby certify that
on June 10, 2006 at CAMP HILL PA
TYAARONBERRIOS and LUCINDA KHATIJA ZAMIR
were by me united in marriage, in accordance with license issued by the Clerk of the
Orphans' Court Division of the Court of Common Pleas of Dauphin County, Pennsylvania.
Certified from the record
June IS. 2006
j/1 G~if Q. ~ . p F'~
Clerk of the Orphans' Court Division
REVEREND DR JOHN FORDON
Officiant
~Triang~e Refrigeration Co. ~ Earnings Statement
P.O. Box 487
3200 Oregon Pike Check Date: June O5, zoo9
Leola, PA 17540 Period Beginning: May 16, 2009
Period Ending: May 29, 2009
Ty A Berrios Employee Number 228
Earnings Rate Hours Amount YTD Hrs YTD Amt
Reg 21.00 58.17 1221.57 130.92 2749.32
O"C _ _. 31.50 1.00 31.50 3.83 120.65
Total Gross Pay 59.17 1253.07 134.75 2869.97
Batch Type Hourly Voucher Number 6886
Dept 004 Net Pay 1,089.72
Check Amount
Taxes Status Taxable Amount YTD Amt
Medicaze 1253.07 18.16 41.61
OASDI 1253.07 77.69 177.94
PA SUI - EE 1253.07 0.75 1.72
Manheim T. (Lancaste 1253.07 12.53 28.70
Manheim T.(Lancaster 1253.07 2.00 4.00
Pennsylvania SITW 1253.07 38.47 88.1 ]
Federal Income Tax M/4 1253.07 8.58 59.29
Total Taa Withholding 158.18 401.37
Deductions Amount YTD Amt
Account Receivable 5.17 5.17
Total Deductions s.17 5.17
Direct Deposits Account Amount
xxxxx2955 xxxxxx1426 1089.72
Total Direct Deposits los9.7z
i3enei-t~ Hours Amount YTDHrs YTD Amt
Accruals Dollars
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PAY TO THE
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I~~! I:03~3029551: 983043~426~~'0789 ~.
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Susan L. Thornsley MD
Adolescent & Adult Psychiatry
INVOICE ,
Name: ~~~~~~ j~Date: ~~~~
Address:
Diagnostic Code: ~ ~~
Service Provided: ~~ ~,"v
Fee: ~ ~ U~
Previous Balance:
Total Amount Due: ~-~~'
Paid: ~-~~
Current Balance:
Next Appointment
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Susan L. Thorn y M.D.
License # MD-03
NPI # 184-122-2650
2448 Walnut Street Harrisburg, PA 17103
Telephone (717) 233-7499 Fax (717) 233-7498
Employer Identification Number 03-0442279
FORM 040592 R/03/OB ITEM 8101