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• STATE OF ARI,ENE E. DELL :IN THE COUIRDT PENNSYLVANIA AS
IN RE. E
AN ALLEGED INCAPACITATED pgMpBgAN~SACOURT DIVISION
PERSON a -~:,
3 ~
G+ }
~ ~ : ,
R ADJUDICATION OF INCAPACITY ~ ~~
PETITION FO IAN cn =a c':3
AND APPOINTMENT OF PLENARY GUARD .~ 4F.~..
OF THE ESTATE AND PERSON IN ACCORDANCE ~ ~, 3 ~~-~
N t.~ Ca
WITH 20 PA Cons Stat Ann & 5511 :~ ~
,~
TO THE HONORABLE, THE JUDGES OF SAID COURT:
etitioner is Craig W •Keefauver, nephew of Arlene E. Dell (the "alleged incapacitated
1. P
person")
2
The alleged incapacitated person was born on October
widowed, and resides at Manor Care Nursing Home,
11, 1925, is 84 years of age and
whose address is 1700 Market Street, Camp
Hill, PA 17011.
e following persons are to the best of Petitioner's knowledge, information and belief
3. Th
ivin next-of--kin or the alleged incapacitated person: Henry Keefauver, l 12 Wesley Drive,
the only 1 g
219 Fox
Mechanicsburg, PA 17050, brother ofthe alleged incapacitated person; Bruce A. Keefauver,
chanicsburg, PA 17050, nephew of the alleged incapacitated person; and Craig W.
Drive, Me
045 Country Club Road, Camp Hill, PA 17011, nephew of the alleged incapacitated
Keefauver, 1
person and Petitioner herein.
erson are
4. To the extent known by Petitioner, the assets of the alleged incapacitate p
a roximately $135,310.27 comprising the following: an undetermined balance in a
valued at pp
account at PNC Bank; a personal residence at 301 N. Second Street, Wormleysburg,
checking
is valued at $114,370.00; intestate succession rights to her deceased son, Raymond T.
Pennsylvan
ass Mutual Financial Group 403 (b) Plan valued at $159.30 and American Funds Plan
Dell's M
4.83 and an American Funds check payable to Raymond Dell, in the amount of
valued at $16,17
$4,606.14.
titioner estimates the alleged incapacitated person's annual income to be $23,765.52,
5. Pe
ent monthly Social Security benefits of $410.00 and current monthly Office of
including curr
Personnel Management Pension benefits of $1,570.06.
lle ed incapacitated person was not a member of the armed services of the United
6. The a g
tates and is not receiving benefits from the United States Veterans' Administration.
S
The alle ed incapacitated person has been deemed unable to make decisions by Manor
7. g
Care Nursing Home.
Because of her impaired mental and physical condition, the alleged incapacitated person
8.
able to manage her financial affairs, property and business and to communicate
is totally un
decisions relating thereto, including the ability to communicate her need for assistance
responsible
in these areas.
Because of her impaired mental and physical condition, the alleged incapacitated person
9.
to be served with a Complaint in a mortgage foreclosure action. Appointment of a
was attempted
guardian is necessary to defend the foreclosure action.
ro osed guardian of the estate and person of the alleged incapacitated person is
10. Thep p
Craig W• Keefauver, nephew of the alleged incapacitated person.
e ro osed guardian of the estate and person of the alleged incapacitated person has
11. Th p p
no interest adverse to the alleged incapacitated person.
other Court has ever assumed jurisdiction in any proceeding to determine the
12. No
competency of the alleged incapacitated person.
0 other uardian has been appointed for the estate or person of the alleged incapacitated
l3. N g
person.
HEREFORE, Petitioner respectfully requests that this Court award a citation directed to
W
. Dell the alleged incapacitated person, and to such other persons as this Court may direct,
Arlene E ,
e wh Arlene E. Dell should not be adjudged a fully incapacitated person, and Craig W.
to show caus y
Keefauver appointed plenary guardian of her estate and her person.
NAUMAN, SMITH, SHISSLER & HALL, LLP
~t
c
By' y uire
Suza a S. Frida , Esq
Supreme Court ID# 201873
200 North Third Street, P. O. Box 840
Harrisburg, PA 17108-0840
Telephone: (717) 236-3010
Counsel for Petitioner, Craig W •Keefauver
Date: March 1, 2010
VERIFICATION
' W. Keefauver, the undersigned do hereby state that the statements set forth in the
I, Craig
etition for Adjudication of Incapacity and Appointment of Guardian of the Estate
foregoing P
e and correct to the best of my knowledge, information and belief. I understand
and Person are ~
ements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to
that false stat
unsworn falsification to authorities.
~tJ
. Keefauv ,Petitioner
Date:
CONSENT OF GUARDIAN OF THE ESTATE AND PERSON
Keefauver, hereby consent to act as the Guardian of the Estate and Person of
I, Craig w•
Arlene E. Dell. ~ ~ ~~
reside at 1045 Country Club Road, Camp Hill, PA 17011 and am a ~ ~
I
n of the United States of America and can speak, read and write the English
I am a crtize
language.
I have no interest adverse to Arlene E. Dell, the alleged incapacitated person.
0 osed Guardi