HomeMy WebLinkAbout09-28-09IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
IN THE MATTER OF THE PERSON :ORPHANS' COURT DIVISION
AND ESTATE OF SUSAN H. HUME,
AN ALLEGED INCAPACITATED NO. a ~ - Oq - Oq O$
PERSON
PETITION FOR APPOINTMENT OF PERMANENT
PLENARY GUARDIAN OF THE PERSON AND ESTATE
AND NOW comes the Petitioner, David G. Hume, who represents and avers
as follows:
1. The Petitioner is David G. Hume, an adult individual residing at 115 North s,st
Street, Camp Hill, Cumberland County, Pennsylvania.
2. The alleged incapacitated person is Susan H,. Hume, 65 years of age, who for
the 11 years prior to her hospitalization resided at 115 North 31st Street, Camp
Hill, Cumberland County, Pennsylvania.
3. Susan H. Hume is married to David G. Hume.
4. Susan H. Hume is the parent of two (2) known children namely:
David Alan Hume who resides at 8650 Haslynn Avenue, Harrisburg , Pa.
Hilarie Ann Hume who resides at 115 North 31st Street, Camp Hill, Pa.
5. Susan H. Hume is not veteran of the armed services of the
United States of America, nor is she receiving any benefits from the
Administration of Veterans Affairs of the United States of America.
6. Susan H. Hume has, for at least two (2) months, been incapable of managing
and caring for herself.
r
7. Presently the said Susan H. Hume is a resident patient at SC Specialty Hospital,
Camp Hill, Cumberland County, Pennsylvania, for post operative rehabilitation
from brain surgery.
8. Susan H. Hume exhibits symptoms of postoperative effects of emergency
surgery for repair of ruptured arterio venous malformations from which she has
not yet recovered so that she suffers from mental incapacity, and diminished
reasoning ability.
9. Susan H. Hume's mental incapacity prevents her from managing and caring for
the affairs of her person to such an extent that she is incapable of making
responsible decisions concerning her personal and financial affairs.
10. The physical condition of Susan H. Hume is now such that the hospital will not
release her to return home.
11. The approximate gross value of the separate estate of Susan H. Hume is in
excess of $136,000.00, and her monthly income is consists of social security
benefits will be of $1,800.00 per month commencing October, 2009, and
Pennsylvania School Employees Retirement Benefits of $2,400.00, which is
presently in pay status..
12. The Petitioner is willing to accept the appointment of Permanent Plenary
Guardian of the Person and Estate of Susan H. Hume.
13. The Petitioner has no interest adverse to the alleged incapacitated person.
14. No previous application, to the knowledge of Petitioner, has been made for the
Order herein requested.
15. No order Court has ever assumed jurisdiction in any proceeding to determine the
capacity or incapacity of Susan H. Hume.
16. The failure to appoint the Petitioner as Permanent Plenary Guarding of the
Person and Estate of Susan H. Hume will result in irreparable harm to the person
and estate of Susan H. Hume.
17. Petitioner believes and therefore avers that the relief sought is the least
restrictive alternative available.
18. The David G. Hume is qualified to be the Permanent Plenary Guardian of the
person of Susan H. Hume.
WHEREFORE, Petitioner prays that this Honorable Court appoint
Petitioner to the be Permanent Plenary Guardian of the person of Susan H. Hume, and
Permanent Plenary Guardian of the estate of Susan H. Hume.
Robert G~adebach, Esquire
912 North River Road
Halifax, PA 17032
(717) 896-2666
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
IN THE MATTER OF THE PERSON
AND ESTATE OF SUSAN H. HUME
AN ALLEGED INCAPACITATED
PERSON
ORPHANS' COURT DIVISION
No.
VERIFICATION
I hereby verify that the facts and information set forth in the foregoing Petition
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.
Dated: 0~
David G. Hume
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
IN THE MATTER OF THE PERSON ORPHANS' COURT DIVISION
AND ESTATE OF SUSAN H. HUME
AN ALLEGED INCAPACITATED No.
PERSON
Consent of Proposed Guardian
I, David G. Hume, of 115 North 31st Street, Camp Hill, Pennsylvania, do hereby certify
that I am willing to act as Guardian of the Person and Estate of Susan H. Hume, an
alleged incapacitated parson, if the Court shall so appoint.
Further, I do hereby certify that I am not a fiduciary of any estate in which the
alleged incapacitated person has an interest, nor have I any interest adverse to the
alleged incapacitated person.
The facts and opinions contained herein are true and correct to the best of my
knowledg information and belief.
Dated: ~ .~
David G. Hu e