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HomeMy WebLinkAbout04-26-10IN RE: LORRAINE B. GOBER :COURT OF COMMON PLEAS OF An Alleged Incapacitated Person :CUMBERLAND COUNTY, PENNSYLVANIA NINTH JUDICIAL DISTRICT ORPHANS' COURT DIVISION r-~-> -. o ~ `,_~~~ ~ -~-'-rn N PETITION OF GOLDEN LIVINGCENTER -CAMP HILL...: ~ `~~ ~-', ~'` FOR ADJUDICATION OF INCAPACITY AND APPOINTMEI~'~> ~ -c} OF A GUARDIAN OVER THE PERSON AND ESTATE OF LORRAINE%» GOBR '~,-•i .. ~' N W AND NOW, comes the Petitioner, Golden LivingCenter -Camp Hill ("GLC -Camp Hill"), by and through its counsel, Thomas, Thomas & Hafer, LLP, and respectfully petitions this Honorable Court pursuant to 20 Pa. C.S. § 5511 for an Order adjudicating Lorraine B. Gober to he an incapacitated person and appointing a guardian over her Person and Estate and, in support thereof, avers as follows: 1. Petitioner, GLC -Camp Hill, is licensed as a long-term care nursing facility in Pennsylvania. 2. GLC -Camp Hill is a long-term care nursing facility located at 46 Erford Road, Camp Hill, Pennsylvania 17011. 3. Lorraine B. Gober is 73 years of age with a date of birth of February 27, 1937. 4. Lorraine B. Gober was admitted to GLC -Camp Hill on October 27, 2006, and is currently a resident at that facility. The essential requirements for Ms. Gober's health and safety are provided at GLC -Camp Hill. 5. Residential services are currently being provided to Ms. Gober by GLC -Camp Hill. 6. As the residential care provider for Ms. Gober, GLC -Camp Hill has an interest in her welfare given her status as an alleged incapacitated person. ~~ ,-.,, ~ 7. Lorraine B. Gober suffers from dementia, depressive disorder and Alzheimer's Disease which impair her ability to make decisions regarding her physical condition, health, well-being, or finances. (See Affidavit of James Harty, M.D., attending physician, attached hereto as Exhibit "A") 8. According to her attending physician, James Harty, M.D., Ms. Gober is incapable of making competent decisions regarding her medical or psychiatric care and treatment or financial decisions. (See Exhibit "A") 9. It is believed that Lorraine B. Gober's mental condition is not curable or reversible. However, her mental status can be managed if she is provided proper psychiatric care and treatment (See Exhibit "A") 10. Lorraine B. Gober is currently unable to competently manage or take care of matters pertaining to her own health and well-being and finances without the existence of another individual who will act as her guardian. (See Exhibit "A") 11. Upon Petitioner's information and belief, Lorraine B. Gober executed a Power of Attorney on March 19, 2004 appointing her daughter, Mary Murphy, and late husband, Frank J. Gober as Attornies-in-Fact. Lorraine B. Gober also executed a Living Will on March 25, 2004, naming Mary Murphy and Frank J. Gober as her Proxies. (See a copy of Power of Attorney and Living Wi11, attached hereto as Exhibit "B"). 12. Upon Petitioner's information and belief, Lorraine B. Gober receives Social Security Income in the amount of $1,040.20 per month. (See Affidavit of Susan Bertolette attached hereto as Exhibit "C"). 2 13. Upon information and belief, Lorraine B. Gober receives an annual pension of $6,037.68 from WRS Retirement Services. (See Affidavit of Susan Bertolette attached hereto as Exhibit "C"). 14. Upon Petitioner's information and belief, Lorraine B. Gober maintains checking and savings accounts with Wachovia Bank, the balance of which is unknown at this time. (See Affidavit of Susan Bertolette attached hereto as Exhibit "C") 15. Upon information and belief, Lorraine Gober does not own real property. (See Affidavit of Susan Bertolette attached hereto as Exhibit "C"). 16. Upon information and belief, Lorraine B. Gober does not own an automobile, is not insured under a life insurance policy, and does not own a burial plot. (See Affidavit of Susan Bertolette attached hereto as Exhibit "C"). 17. Upon Petitioner's information and belief, no other guardian over the Person and Estate of Lorraine B. Gober has been appointed, and no other Court has assumed jurisdiction in any proceedings to determine the capacity of Lorraine B. Gober. 18. Upon Petitioner's information and belief, Lorraine B. Gober has a niece, Georgine Gober, who resides at 722 East Mahanon Avenue, Mahanoy City, PA 17948; (570) 773-2855. 19. Upon Petitioner's information and belief, Georgine Gober does not oppose the appointment of Ronald Byer, as guardian over Lorraine B. Gober's Person and Estate. (See Exhibit "D") 20. Upon Petitioner's information and belief, Lorraine B. Gober has a niece, Mary Ellen Bane, 61 North Spencer Street, Frackville, PA 17931; (570) 874-0357. 3 21. Upon Petitioner's information and belief, Mary Ellen Bane does not oppose the appointment of Ronald Byer, as guardian over Lorraine B. Gober's Person and Estate. (See Exhibit "D") 22. Upon Petitioner's information and belief, Lorraine B. Gober has a nephew, John Byer, 27 High Road, Mahanoy City, PA 17948; (570) 773-0827. 23. Upon Petitioner's information and belief, John Byer does not oppose the appointment of Ronald Byer, as guardian over Lorraine B. Gober's Person and Estate. (See Exhibit "D") 24. Upon Petitioner's information and belief, Lorraine B. Gober has a niece, Karen Chilinskas, R.R. #2, Barnesville, PA 18214; (570) 467-0986. 25. Upon Petitioner's information and belief, Karen Chilinskas does not appose the appointment of Ronald Byer, as guardian over Lorraine B. Gober's Person and Estate. (See Exhibit "D"). 26. Upon Petitioner's information and belief, Lorraine B. Gober has a nephew, John. Cavanaugh, 36 East Spruce Street, Mahanoy City, PA 18214; (570) 773-1636. 27. Upon Petitioner's information and belief, John Cavanaugh does not appose the appointment of Ronald Byer, as guardian over Lorraine B. Gober's Person and Estate. (See Exhibit "D"). 28. Upon Petitioner's information and belief, Lorraine B. Gober has a niece, Cathy Evans, 323 East Pine Street, Frackville, PA 17931; (570) 874-1133. 29. Upon Petitioner's information and belief, Cathy Evans does not appose the appointment of Ronald Byer, as guardian over Lorraine B. Gober's Person and Estate. (See Exhibit "D") 4 30. Upon information and belief, Lorraine B. Gober has one living child. Mary Murphy, who has recently become estranged from Ms. Gober, has not visited or contacted Petitioner regarding Lorraine B. Gober despite numerous requests to do so, and has not been involved with Ms. Gober's care or treatment since moving to Arizona. 31. As of the filing of this Petition, neither GLC -Camp Hill, nor undersigned counsel, has been able to contact Ms. Murphy regarding Petitioner's care and treatment of Lorraine B. Gober or this Petition. (See Exhibit "D") 32. Upon information and belief, Lorraine B. Gober was not a member of the United States Armed Forces. 33. Upon Petitioner's information and belief, Lorraine B. Gober is not a fiduciary in any capacity. 34. A guardian over Lorraine B. Gober's Person and Estate is required to provide consent for psychiatric evaluation and treatment and/or medical care and treatment, and to ensure that Ms. Gober's continued personal, financial and medical needs are satisfied. 35. Petitioner believes there are no less restrictive alternatives to seeking a guardianship over the Person and Estate of Lorraine B. Gober. 36. The failure to appoint a guardian over the Person and Estate of Lorraine B. Gober may result in irreparable harm in that Lorraine B. Gober will be at significant risk for her deteriorating psychiatric condition, physical harm and/or financial harm. 37. The proposed guardian over Lorraine B. Gober is her nephew, Ronald Byer, RR 1 Box 2524, 524 Haystack Drive, Zion Grove, PA 17985; (570) 384-3530. 38. Ronald Byer has agreed to serve as guardian over Lorraine B. Gober's Person and Estate. (See Consent of Proposed Guardian attached hereto as Exhibit "E"). 5 39. Upon information and belief, the proposed guardian has no interest adverse to the alleged incapacitated person. 40. Petitioner respectfully requests that the proposed guardian be given powers over the Person and Estate of Lorraine B. Gober. 41. Lorraine B. Gober's mental and physical condition mandate that a guardian be appointed to make decisions concerning her Person and Estate, including, but not limited to her living arrangements, her medical and psychiatric care, the administration of medications, surgical interventions, the employment and discharge of physicians, dentists, nurses, etc.. for her physical care, and to manage her financial affairs. WHEREFORE, Petitioner, Golden LivingCenter -Camp Hill, respectfully requests that this Honorable Court declare Lorraine B. Gober to be an incapacitated person, and appoint Ronald Byer as guardian over her Person and Estate. Respectfully submitted: THOMAS, THOMAS & HAFER, LLP Date: y~~ ~..,1 J Malrc A. Mo r, Esquire Attorney I. . No. 76434 305 Nort rout Street, 6th Floor P.O. Bo 999 Harrisburg, PA 17108 717-441-3960 mmoyer@tthlaw. com Counsel for Petitioner Golden LivingCenter -Camp Hill :79581.1 6 EXHIBIT A AFFIDAVIT OF JAMES HARTY M.D. I, James Harty, M.D., do hereby state that the following is true and correct based upon my personal knowledge, information and belief: I am a physician licensed in good standing to practice medicine in the Commonwealth of Pennsylvania. 2. I am the attending physician for Lorraine B. Gober. I attend to Lorraine B. Gober on a regular basis at Golden LivingCenter -Camp Hill located at 46 Erford Road, Mechanicsburg, Pennsylvania, 17011 where Lorraine B. Gober has resided since October 27, 2006. Lorraine B. Gober is 73 years of age, with a date of birth of February 27, 1937. 4. Ms. Gober suffers from Dementia, Depressive Disorder, Alzheimer's Disease and various other illnesses and psychiatric conditions. 5. Ms. Gober's psychiatric disorders are not curable or reversible. However, her mental status can be managed in the event she is properly evaluated and provided appropriate psychiatric care and treatment. 6. Ms. Gober received a psychiatric consultation on September 17, 2009, by Senior Psychiatrist Herbert Myers, M.D. affiliated with Philhaven, 283 S. Butler Road, Mt. Gretna. PA 17064. 7. I have determined to a reasonable degree of medical certainty that Lorraine B. Gober is unable to receive and evaluate information effectively and communicate decisions, and that her abilities are impaired to such a degree as to render her totally unable to meet the requirements for her physical health and safety and financial matters without the assistance of another individual/organization who will act as a guardian over her Person and Estate. 8. It is my opinion that Ms. Gober is unable to resist fraud or undue influence without the assistance of a guardian to make decisions regarding her health care and financial matters. It is my opinion that the failure to appoint a guardian with authority to provide consent for Ms. Gober to receive appropriate psychiatric care and treatment will result in irreparable harm to her Person. I declare that the above statements are true subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. ~~Z© -/o Date ~. ~tco James Harty M.D. 797704.1 2 Pc~wf.rz c~F A~rr(~IZNr~~ NOT1CE ~I~III~: PURPUSI~: (~I~ ~rfllS POWI~.R OI~ A~I~~1~ORNI~:I' IS ~I~O C;IVI:~. ~I~IIE PERSON lOl! UI~:S(GNi~~l~l~: (YOUR "AGI~,N~I~") BROAD Pt~WI~:RS ~I~O IfANDLI YOUR I'R(~PI~:f~~fY. Vb'1(ICII [viAY INCLUUI~: POWERS ~I~O SI~:L[. OR O~I~I II~.RWISE DISPOSE ~I~ ,1NY RI~.;\I_. OR PI~:RSONAI, PROPI~.fZ~I~Y Wl~i~l 10l ~~I~ ADVANCE NO~fICE "l'O 1~~(~(' ~ ~fl APPI:OVAI. BY YC)I I. ~I'IIIS POWER OF ATTORNEY DOES NO'T' IMPOSE A DUTY ON YOUR !~(~I~.N~f~ ~I~O I;XC:RCISE GRANCED POWI~RS. BU"I~ WIZEN POWERS ARE I;XI:RC[SI~;D. YOUR AGENT MUST USE DUE CARE "I'O AC"f I~OR YOUR BENEFIT iWU IN ACCORDANCE WITI I TI I[S POWER OF A"I'~['ORNEY. YOUR AGENT M~~1Y I:XERCISI~: ~[~IIE POWERS GIVEN HERE ~I~I lR(~UGI f0[!~h YOUR LI}~I=."DIME, [~:VI;N AI~~fI:R YOl` BECOME INC'nP;~~'I~I~n'I~I-;D. UNLESS YOU I~;XPRI:SSLY LIMIT ~I~1IE DURA~fION OF THESE Pt>~~~'I~:RS OIZ YOU REVOKE ~I~IIESI~. POWF,RS OIZ A COURT ACTING ON YOUR 131~.I I,~V.1~ "i'I~:RNIINA~I~I:~.S YOItR AGC~:N"I~'S AI ~"I~f IORI"I~Y. YOUR A(~E;N~[~ N1US'I~ KE[~P YOUR FUNDS SI~PARA"fE FROM YOUR \(;I~;Nf~'S FUNDS. A LOUR"h CAN 'CAKE AWAY "~I Il; POW'I~,RS OI~ YOUR ADEN"T [F IT FINDS Yt )UIZ A(;EN"I~ IS N07~ AC"LING PROPERLY. ~I~IIf~. POWERS AND DU"PIES OF AN AGf~.N~f UNDER A POWER OF ,11~"I~(>RNI:Y ,1RI~: I:XPLAINEU MOR1~: [~ULLY IN ~0 PA. C'.S.A. CI IAPTER ~6. II~ ~I~1 II~;RI~: IS ANY"I~I-ZING ABOI1~[~ ~1~1 [(S i~ORivl ~I~l IA"h YOU DO NOT t INDI~:RS~I~AND. YOU Sf IOULD ASK A LAWYER OF YOUR OWN CI LOOSING ~f0 I~:API.;~IN I~I~ ~I~O YOU. 1 I fAVI: RL:AD OR I lAU L~:XPI.AINI~:U ~I~O lull: ~I~f [(S NOI~(CE. AND [ f'NDI~:IZS~I~AND ITS CON~I~I~.NI~S. L()R12,11~vF_, f3. (;()l3ER I )~~~~: :~l~ir~h 19 . ~OO~ i~UwERUF;~~rT~UR~~~E~~ KNU~V ALL ;~~IEN l3Y THESE PRESENTS. that (. LORRAtNE Q. COE3ER ~"i'rinci~,;-I"). ~~I~ ?O~ west S}~rUee Strcet_ ~~lahan-~~~ City. 1'em~svivania. have made. ~~~~n~(i~uled and a~~~~~~inted, and h~~ these ~~resents d~~ make. c~~nstitute and aE~pc~int m~~ Vi-i;i,,incL F R;~NK .1. CURER. ~~i~ ?U~ ~~-est S~~ruce Street. ~~~lahan~w Cite. ['cnns~~lvania. ~~nd n-~ ~I,-u~~hlcr. w1ARY M[1Rt'Hti'. ~ 17 f.~-I~~~~c~ie f )ri~~e. Nc~~~ Cumberland. !'~~•nn~:~ I~ ~inia. fir either ~~f them. ~-ctin~~ ~-I~,n~_ but itl~~rr~~l l~~ I-~rein.-I~ter. ~in~~l~~ ~~r J~~intl~~. as n-v l!"Ue anC~ ~11~~~Ill~ l~llUt"ne~~-In-l~acl (~I' ,~~elnl (~~.~~~Cnl~~~. lOt' Il1C and In m~' Hanle. ~7~aee and ;-~•ac(. t~~ ~~erl~~~rm anv Mme ~~r all ~~I~ the li~ll~~~~~in~ ~-cts. ati ~letinc~l in ~0 Pa. C.S.A. ~~etir~n ~(~(1 ~: (~-) ~I~~~ make limited ~~ifts; ~ h) (~~~ create a trust f ~~r my hcnel it: Ir) i~~~ nu-kc adcfiti~ms t<~ an c~istin~_ trus( liar m~~ hcneliL (d) ~I~~~ Maim an elective share ~~Flhc {~ata[e ~~i~n~~. deceased sEx~usc: (e) ~I~~~ cfisc:laim am~ interest in ~~r~~~~crt~~_ (I) ~I~~~ rcn~~uncc liduciarv ~~c~sili~ms; (<~ I f~~ ~~ ithdra~~~ and recei~~c the inc~~me ~~r c~~r~uis ~~I~ a (rust: ~h) I~~~ auth~~riic m~ admissi~~n to a medical. nursin~~. residciltial ~~r similar I~,i~ili~~ and t~~ enter int~~ .-~~rccmcnts liar in~~ c~-rc: (i) ~I ~~ auth~>rirc medical and ~ur~_ical ~~r~~eedures: (,I 1 ~I~~~ en~~a~~c in real ~~r~~Eiert~ [ransarti~~ns: (k! ~f~u cn~~a~ec in tan~~ih(e E~ers~~nal ~~r~~~~ert~ transucti~,ns: 1 I) ~I ~~ cn~~a~~e in st-~ck. h~>n~L and ~~tllcr .~eruritie~ tr~-nsacti~,ns: (m) I~~~ en~~a~~c in c~-n~n~~~dit~ and ~>~~tiun trantiaeti~~ns: (n) ~ ~~ en~?a~~C Iil h~lilkln~~ ~Ilid ~InallCia~ U'~IntiaCU(1nS: ~ ~,1 I u burru~~ mone~~: I hJ l~c~ enter salt clehosit boxes: (yj ~fu c:n~~a~~c in in~w•~-ncr tr~-n~c-~tic~its: (r) ~I~o ~n~~.-~~c in rctircmc-~t hlau tr~u~s~-ctic~n~: (s) ~fo handle interests in estates anti trusts: (~) ~fo hursuc claims anti liti~~ation: (u) ~fo receive ~~c~~~crnt»ent benefits; (~) I~o hursuc tax matters: and (~~) 1 u nuke an anatomical gilt ofall or any hart ul~m~ hods. GIVING AND GRANTING unto my said ~1~~cnt full hu~~~cr and authority to do and herlin•m all anti every act, decd, nutter and thin.; whatsoever in and about my estate. hrc,hrrty ,u-d af~lairs as I•ully and cffcctually to all intents and hurhoscs as l might or could cl<, in n~~ o~~n h-•ohcr person if• hcrsonally hresent. `~ivin`~ to m~ said /1`~cnt lower to make ~u~d substitute under it an ~~1~~cnt or n~~cnts liar all the hurhoscs herein described. the above specially enumerated lowers hein~~ in aid and cxcmhlifiration cif the Il-ll, complete and ~~encr<-I po~~~cr herein ~erantcd, and not in limitation ur clclinition thereat; and hereby ratil:~in~~ all that my said ngcnt or substitute i~~~cnt shall I~-«~I•ully do or cause to be done by ~irtuc c,flhcsc presents. ,end I herch~~ decl~u~e that any act or thine I~n~~fully done hereunder h~~ m}~ said /1~ent ~;I-,ill (~~ hindin~~ on m~~scll: and n~~~ heirs. lc~~al and hersc,nal rehresentati~~cs. and assi~~-ls. Il-i; hu~~er ut atturne~~ shall continue in force dcshite n~v incomhetencv. n~cntal ur hl-> ~i~,il incapacity. and may he aceehted and relied uhun h~ anyone to ~~ hone it is hresentcd cl~'~I~i~e i>>~ hunc~n~trd revocation ul~ it c,r n~~ death. until actual ~~~ritten nc~ticc ol• such c~~ent i~ ree~~i~ ccl h~ ~ueh person. In the e~ ent ol~ n-~ ineon~hetenc~ . from ~~ hates cr cause. this f,c,~~ er of attorney Tall nut thereh~ be re~~uked but Tall thereuf~un become irrcvocahle• and n~~i~ be accchted and relied upon h~~ an~~unc to ~~hom it is hrescntcd dcshitc such in~~„nipe~enc~~. subject only to it hceon~in~~ ~~uid and ol~no further el~l~ct only upon rccciht by ~u~~l- ~~~rsc,n either ul~ (I) written c~idenee of the uhhoinU»cnt of a ~~uarcli~-n (ur similar I i~t~i~i,ir~ ~ ~,I~ i>>~ rsl~il~ f~~~ll~~«in~~ ~i~lju~iic~iti~,n uf~ inrun~~~~~t~n~•~ . ~~r (~) ~~ ri(icn n~~ticc ~~~~ m~ I~' ~~'ITNESS ~VFIERCO~. I h~~~~c h~reunt~~ ~r( m~ hand an~i seal this 19th cfa~~ ~~I~.Al~u~ch. ~UO-~. - - -- - -- ~ ~~~~ (SEAL ) ('O;~~l~~lON11%E;~LTt~( ()F PI;NNSI'LV;~ti~l<<~ ~. (~Ot',~~Tl~ OF tiC'l1UY'LKILL ON "1'H IS. the 19th clay oI~ Marrh. ?UU-[. hcli~rc mc. a Notar~~ Public in and f~~r ~~ii~l C~omn~on~~u-Ith anc) C'ount~. {~ersonall~ a~~[~earcd LORRAINC l3. GOQER. hno~wn to n-c (ur satislactoril~~ [proven) to be the ~~crson whose name is subscribed to the within Power ~~I~ ;1t(orne~~. and acl:nowled~cd that she c~ccutcc[ tic same I~~r the [~u-poses therein c~~ntaincd. IN WITNESS WHEREOF. f hereunto set n~~~ hand and of~[icial seal. ~~~~ Notary Public TN~R~SA RR P~R~ . ~'~! of pott~vi~s, Sdnry~ ~~ 1rh~~xnn>~on ~ ~~ ~CKNOYVLEDGitiI ENT ~~~c. f' R:~NK J. CO[3ER and ,MARY' NIURPHY_ h<<~e rcacl the .~ttachcc! ['~~~~er ~~f \tt~~rn~~ anal are the hers~~ns iclentilie~l as the ~~~~~ntti liar LOIZRAINE F3. COBER, the I'riiirilr,~l. ~~~~ hcreh~~ ~~rhn~~~~lcci~~r lh~tt in the ~ih~rnc~ ~~f ,i ~hc~ilic hr~~~ isi~~n t~~ the c~~ntrar~ iii ll~c I'~~~~er ~~f~i~tt~~rnc~~ ~n- in ~O ['~~. ~'.~.~~. ~~~hcn ~~e art ati /~~~cnts: ~~~e shall e.~ercitic the Ix~~~~crti fi~t• the hcnclit ~,I~the I'rincihal. ~~~~e ;hall I:ceh the assct~ ~~I~the I'rinrihal se~~u~atc f~r~~m ~~ur a~~cts. We shall ezrrritic rea~~~nahle cauti~~n anal hru~lcnrc. ~'~%~• shall I:eeh a fli(l and ~ieeur~itc rec~~rcl ~~f all aetiun~. receihtti and ~lisbursement5 ~m h~hall ~~l~the I'rincihal. ~~ FRANK .l. G013ER (SEAL) ,~~-- ~ , ~~ ~~ ~ w ~ ''~`--'' ~ (SEAL) ~1 A R Y l lk; P Fl Y ,_/ NREAiti~Il3L[ TO L.I~'ING ~-VILE Our.ludro-~'hri~lian I~~rit~-~~r 1-~~Icls tlt~it lily i~ ll~r ~~il~t ul~,i I~~~~in~~ (~-~tl. 1 undcrtitancl. ,~I~(~ a~ ,- ~•~-thulic. that I nw~~ ne~~cr choosy to cause -»~ death. 1~hcrclorc. I hclie~~e that ~uthanasi,- and suicide constitute an un~~~arranted dctiU•uction ol• human life and arr.' not n~orall~ hern~issihlr. I uu(Icrstand shat I ha~~c tllc ri~~h( try n~al:r ~l~cisiun~ ahr,ut -»~~ health care. ~hhere ma~~ c~,-nc a tin~r ~~hrn I any unable. due (o I,h~~siral or n~cntal incal,arit~~. to c~hress m~~ o~a~n hralti care decisions. In these circuntstanrr,~. iho~c carin~~ I~~r n~c ~~ ill n~~d dircctir~n cunccrnin~ m~~ care and ~~~ill turn tc~ ~r~n~c(~nc ~~~hr~ hnr~~~~~ ni~~ ~~alucs and health care wishes. I any. thcrclorc. si`~nin~ the attached LIVING ~'II.I.. ~~~hich is m~ advance directive f-or health care, to hrrn~idc the ~~uidance and autl~orit~~ needed to implement my decisions. DECLARATION OF LIVING W1LL I direct that those responsible for n~~~ care seep to nud:c health care decisions in ~iccordancc ~~~ith ~~~hat the}' kno~~~ ol• my stated w~ishcs. 1 hereby declare and make known n~~ insirurtions and «ishcs for my li-turc health care. I his I.1VIN(~ V~'ILI.. which is m~ a(I~ancc dirccti~c lo-' health Care, shall take effect in the e~cnt I any determined h~~ the attrndin~~ hh~~tiician ~r~ I~icl: sul•licicnt capacity to make ~~r cunun-u-irate decisions ghoul nt~ health rare. I he attending physician muss also determine that I: ha~'C an incurable and irr~~rr~ihle me(lical condition in an acl~~anred statC ~~~iich ~~~ill result in death rC~~ru-dless of~ the continued application of~ lile-sustaining trcaln~cnt. 'I~hc dctcrmination ol• my medical er~n(lition u-ust he ronlirmed h~~ a second ph~~sician ~~ith appropriate e.~pcrtisC. ~I~o inli~rm those resionsihlC I~>r m~ care ol~ m~~ spccilic ~~~ishcs. 1 direct that the I~~II~~~~ in~~ hcallh care (lecisions he implcnnnted. I ~-~I: (h,-t il~ I fall tertninall~ ill. I he (~~Id ~~(~ this so that ~I n~i,~lli lrelarc nl~~sclf~ f~~r ~I~~iiii. i i~ i ,-n~ unahic t~~ n~al:e dccisi~~n.~ (i~r n~~ ~eIC. I dircc( flat n~~~ sliri~u~tl needs he taken ~.u~~~ ~>I~ - that I he attcndccl h~ ~- C~athulic lriest anti recei~c the Sacraments of i:cc:~nciliation and the /~nointin~ ofthc Sic{: and Viaticum. I believe that C am not hound in conscience to use cthical(~~ e~traordina-~~ or di.;ir~~lor~ionaic n~cdical treatments (gin- sustainin~~ life. that iti. means that arc exccssivcl~~ hurdcnson~c or do not off-cr ~-n~~ reasonable hole ol~ beneli~. I direct that. re~Tardless ~~f m~~ ~h~ ~ic.-I ~,r mental c~~ndition_ all ordinary medical c.u~e necessary (~~ rclic~~c lain and nu-kc nor con~li>rlahlc (~~~hich includes mcdicall~~ assisted nuh~ilion and h~~dration) he provided so I~~n~~ ~-s the lr~~ccdurc fir nutriti~~n anti h~~drati~~n d~>cs n~~t lrc5cnt a ~~ra~c, intolerable or unbearable burden anti of~lers a reasonable hope of~ benefit. 1 also direct that I not receive clhicall~~ c~traordinar`~ treatments. unless m~~ lrox~~ allointcd herein iud~~es. or, if I did not clc~i~~nalc ~- lro.~~~. then those closest to me ju~l~~~e that at that tin~c there arc slecial and ~i~~nilican( rcations ~~~hv I should receive them. DES[CNATION OF PROXY I hereh~ clcsi~~natc: :11)I)IZI~,SS ~'U~ ~~'est S~iruec Street (~ITY i~~lahano~~ C'it~~ STATC I'n 17~)-~X ~L~ Illy I)ro\~~ 1(1 11111IeillCnt I11~' heallll Cal"e dCCltilons. I t~ll'CCl nl~~ lr(1XV' to II11p~C111en1 my death care decisions as stated in this document. In the e~~cnt my ~~~ishes arc not clear. or a ~~ilu~lti~ul ~-ris~s I cli(I nOt anticil7atc. my hrl)~v is auth(u'ir.cci tO mal:c dccisi~~lls based upon ~~ Il~ll Ili ~u~ ~h~ I:n~~~~ s ul~ n)\ \\ ishcs. V~.A~till: nNl) ~~I)I)IZI~:SS OI~ til~[3S~I~I~I~I!"I~l~: I'IZO\Y (II~ I'IZOXY I)ESIC~Nn~1~EU \I~~ >V'I~ I~ (`N~~lil.f~: ~I~O SI~.IZVI~.) '~ ,<~ 1\~1 E 1\~ 1 ~1 R 1' M I ~ R f' ADDRESS 317 Laf~a\ette ('1~,1~ N~v~ C'unlhcrland STATE Ian I ~~»~~ I hav~c Cliscussccl the terms ol~ this dctii~~nali(~n v~~ith nlv• }~rOx~~ alld h~ (lr she has ~~illin~~ly~ ~-~~recd tO ~-ccc}~t the respol7sihility~ I~~r a~tin~~ on nw' hchall~. 1 direct that this document become 17art of my 17ermanent medical records. I understand that 1 have the right to revoke this Livinti Will. 13v~ vv~riting this LIVING WILL. I direct those vv~ho nuly' heconle entrusted with my 11:'[11111 (;al'C lc> Illl}llClllelll nl\' \\'Itiheti. f ha\'L ChsctltitiCC} the lCl'ills O1 1f115 deslgnatloll \V11}7 171)' hrl)x~ (if an~~) and is or she has vvillin~~l~~ a~~rccd to acccl7t the res}x)nsihility for acting on I11\' hclla}I In acCO1'dal1CC \\'Ilh tf11S CI11'CC11\'e. } Ulldl'1'sland 1I1C }7u1'}lose alld ef~~L'Ct OI 1h1S d~lcunlent and si~.:n it l:novvin~aly. volunta-'ily~ and after careful drlihcralioll. ~i~~nr(I this 25th dav' ol~March. ?UU~. LORRr11NE 13. COf3ER .~UI)IZESS ~(1~ W'~st S~7rucc Sll'ccl CITY ~~lahanov~ ('itv~ STATE 1'n } 79-~~ I ~I~~lar~ that thr ~~crs~m ~~~h~~ si~~nc~l this ~I~+cumcnt. ~~r an~~(hcr ~ih~~ ~~as askccl t~~ ~i;!il iill~ ~i~r~UlilCit On hl~ (11' IlC1' ~l~hall. C~I(~ till IIl Illy ~ll'~sl'nCl'. Thal ~l~ (~1' s~l~ is ~~l'I'tiOna~~\ ~;n~,~~ n <<, n~~. an~f that hr ur shy I:n~~«in~~l~ an~i ~~~~lunt~u~il~ si~~n~cl this ~~ritin~~ h~~ Si~~naturr ~~r i>>arl: in n~~ ~~r~s~nc~ and a~i~,~ars to he ~~I~suun~l n~in~l. 1. ~~'IT`'F:ti~_ JOHN B. LIEBERMAN, III, ESQUIRE 1I)1)REti~ 111 East Market Street, P.O. Box 238 ttsv STATE PA 17901-0238 ~rrl.rl~FlO!vE 57o-6z2-19s8 ~I(:~~AT~~rzE ~'.~~ L DATE March 25 2004 ~. ~-~'I~TNE~S JAMES E. CROSSEN, III, ES ;~l)I)IZE~~ 111 East Market Street, P.O. Box 238 ('I~Tl' Pottsville TELEI'FIONE ~I(;N;~TI'1ZE 5~70---622-1988 11 C~ 1),-~~T'E March 25, 2004 STATE PA 17901-0238 (~O;~l~lON!~'E;~LTH OF PE~VNSYLV:~NI~~ ~ti. (()l~~N"f 1~ OF tiC'FII!ti'LKILL t)i1 THIS. the 19th clay ~+I~M.II'CII. SOU-;;. h~lcn'c m~. a N~~tat~ I'uhlic in and tur ~;ii~l ~'~nnnnm~~ralth and (_'ounh. persc~nall~ appcarccf LOIZRAINE Q. GOBER. known to n~~ (ur satisfactorily proven) to he the person whose name is suhscrihecl to the within Power ul~ ~1tt~~rnry. and acknowlccl~cd that she c~ccutcd the same liar the purposes therein ~unt,iin~cl. IN WITNESS WHEREOF. l hcrcunto sct my hand anti ol•ficial scal. ~~'~ --~ ~~ Notate Public .....•+^ 'fNEREBA R P~R~ NAY P.r~ ~~ sa-~ ;~cKNOwLEnCiv1ENT \~~~. 1' R:~NK .I. CORER anal ,MARY ~VIURf'HY. have read the attached I'~~~~cr ~~f \tt~~rn~~ ,Intl ~ir~ the hers~,ns idcntilied <« the \`_ents I~~,r LORRAINE R. GORER. the I'rin~il~al. 1~~'r hereh~~ ;trl:n~,~~l~ci~~c that in the ~th~~nc~ ul~ ,i ~h~cilic hr~,~isi~~n t~~ the ~~,ntrar~ in the I'~n~er ~,f~~\tt~n-ne~~ ~,r itt ~(1 I'a. C'.ti.r~. ~~hei~ ~~e act <« n~ents: \~ e shall e~c:reitic the ~~,~~ers fi,r the benefit uf•the I'rincihal. \~ ~ sha11 {;ecp the assets c,l~the I'rin~ihal tierarate I•r~,m c,ur assets. ~Ve shall ~~crcisc reas~~nahle cautic,n and hrudencc. ~\'~~ shall {:eeh a I~ull and accurate rece,rd ul~all aetiunti. reeeihts and disbursements c,n h~hall•~,I•the I'rincihal. (SEAL) FRANK J. COE3ER i\ ~~ w ~ ~-~- (SEAL) ~1ARY' t iCj; PHY J I )at~_d: March 19 . ?(H)~ __ - EXI~IBIT C AFFIDAVIT OF SUSAN BERTOLETTE, BUSINESS OFFICE COORDINATOR, GOLDEN LIVINGCENTER-CAMP HILL I, Susan Bertolette, do hereby state under penalty of perjury that the following is true and correct based upon my personal knowledge: I am the Business Office Coordinator for Golden LivingCenter -Camp Hill which provides skilled nursing and rehabilitation services at 46 Erford Road, Camp Hill, Pennsylvania 17011. 2. Lorraine B. Gober is currently a resident of Golden LivingCenter -Camp Hill and has been a resident since her admission on October 27, 2006. 3. To the best of my knowledge, Lorraine B. Gober has executed a living will and power of attorney, naming her late husband and daughter, Mary Murphy, Attorney-in-Fact and Proxy. 4. Upon information and belief, Lorraine B. Gober maintains a checking and savings account with Wachovia Bank, the balance of which is unknown. Upon information and belief, Lorraine B. Gober does not own real property or an automobile, is not insured under a life insurance policy, and does not own a burial plot. 6. Upon information and belief, Lorraine B. Gober receives approximately $1,040.20 in Social Security Income per month. 7. Upon information and belief, Lorraine B. Gober receives an annual pension of $6,037.68 from WRS Retirement Services. 8. Upon information and belief, Lorraine B. Gober was not a member of the United States Armed Forces. 9. Upon Petitioner's information and belief, Lorraine B. Gober has a daughter, Mary Murphy, who currently resides at 2014 West Western Drive, Chandler, AZ 85224, (480) 584-1406. 10. Upon Petitioner's information and belief, Lorraine B. Gober has a niece, Georgine Gober, who currently resides at 722 East Mahanon Avenue, Mahanoy City, PA 17948, (570) 773-2855. 11. Upon Petitioner's information and belief, Lorraine B. Gober has a niece, Mary Ellen Bane, who currently resides at 61 North Spencer Street, Frackville, PA 17931, (570) 874-0357. 12. Upon Petitioner's information and belief, Lorraine B. Gober has a nephew, John Byer, who currently resides at 27 High Road, Mahanoy City, PA 17948, (570) 773-0827. 13. Upon Petitioner's information and belief, Lorraine B. Gober has a niece, Karen Chilinskas, who currently resides at RR #2, Barnesville, PA 18214, (570) 467- 0986. 14. Upon Petitioner's information and belief, Lorraine B. Gober has a nephew, John Cavanaugh, who currently resides at 36 East Spruce Street, Mahanoy City, PA 17948, (570) 773-1636. 15. Upon Petitioner's information and belief, Lorraine B. Gober has a niece, Cathy Evans, who currently resides at 323 East Pine Street, Frackville, PA 17931, (570) 874-1133. 2 16. Upon Petitioner's information and belief, Lorraine B. Gober has a nephew, Ronald Byer, who currently resides at RR1 Box 2524, 524 Haystack Drive, Zion Grove, PA 17985, (570) 384- 3530. I declare that the above statements are true subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date :797685.1 ,~ ~ ~ ~ ~ ~ ,r Susan Bertolette Business Office Coordinator Golden LivingCenter -Camp Hill Street Address: 30~ Nort1~ Front Street. Harrisbur_. PA 17]01 Mailins Address: P-O. Box 994_ Harrisburg. P.A 17108 Phrn~e~ 717237J100 Fax- 7172,Z710~ Mark A. Mover ('1 ?l 4-11-3960 mmo>>eria'.tthla~~. com April 5. X010 VIA CERTIFIED MAIL/REGULAR MAIL 7008 3230 0000 3420 8428 Mary Ellen Bane 61 North Spencer Street Frackville, PA 17931 Dear Ms. Bane: It was a pleasure speaking with you several days ago regarding your aunt. Lorraine Gober. who is currently a resident at Golden LivingCenter -Camp Hill. As we discussed, we anticipate filing a Petition to appoint Ronald Byer guardian over Ms. Gober's Person and Estate for the purpose of providing Mr. Byer the authority to make all medical and financial decisions on Lorraine Gober's behalf. This letter is simply intended to confirm the substance of our telephone conversation in which you indicated that you do not oppose Ronald Byer being appointed as guardian over Lorraine Gober's Person and Estate. To that end, I kindly ask that you contact me irrunediatel~~ if my understanding of our telephone conversation is incorrect in any way. As we discussed, we will receive notice from the Court as to the date, time. and place of the hearing to appoint Ronald Byer as guardian over Ms. Gober's Person and Estate in the future. and will provide you with that information as soon as it is received by our office. Once again, thank you for your attention to this matter. As always, please do not hesitate to contact me if you have any questions or concerns. Very truly yours, MAM/j1d:79692~. ~ arc A. over .=P~3St8~ ~.~v~fVC-. TM ~T~F~~~ ~-n~n r.. R~~~~G ;,(~vmestic MaflDnly; Alo<tnsurance Lbarerai ~ Fnr~ellas'scY iritortrtation visit DUrwet-si#e.at~nrww ~ I lJ ~ i ~ JJ t ? Fostage ~ S ~ ~~~1 ~~ n ~ Certified Fee ~ I ~ Retum Receipt Fee ~ POStmarF; ~ (Endorsement Required] ~ I Hare Restricted Delivery Fee ~ , ~ (Endorsemenf Required? ~ f n s L Total Pcstaga & Fees i ~ i n Q ~ Sent To ~ ! ~ ~ ~~~ r~r,/le i ~ I Street. sl{iP tJc.: ~ --'-- ~-- --- T ~ -"~'-a:--- "~ ~ I or PD Box Nc. d - ~~ Crty; State, ZIP+a ~ ! ~ ~! j --------------°°----" t f1e ~ ~ :ee ee. _ I, 2, and 3. Also complete :d Delivery is desired. ind address on the reverse turn the card to you. o the back of the mailpiece, space permits. r. ~~ 1 `~~~ pJ t ~~~ ,I A. S~nature ~ .-- ^ Agent ~/ !-"~1",.~ ~j` % Addressee B. Received by (Printed Name) ~ C.11 D/ate{\of~Delivery '" f~ L 1~\ h 1 1 ~'~ D. Is delivery address different from item t? ~ ^ Yes If YES, enter delivery address below: ^ No 3. SQrvice Type ~I-Certified Mail ^ Express Mail ^ Registered Return Receipt for Merchandise ^ Insured Mail C.O.D. 4. Restricted Delivery? (Extra Fee) ^ Yes ;e la 7028 2222 2222 3422 $428 ~ruary 2004 Domestic Return Receipt 102595-02-M-1540 Street Address: 30~ North Front Street. Harrisbure_ PA 1710) Mailing .Address: P.O. Box 999. Harrisburg. I'A 17105 Phone: ?17237.7100 Fax: 717237.710 Mark A. Mover (~1') =1~1-3960 mmoverrtitthla~~. cony April 5. ~ 010 i~1,A CERTIFIED MAIL/REGULAR MAIL 7008 3230 0000 3420 8435 John Byer 27 High Road Mahanoy Cite, PA 17948 Dear Mr. Byer: It was a pleasure speaking with you several days ago regarding your aunt. Lorraine Gober, who is currently a resident at Golden LivingCenter -Camp Hill. As we discussed, we anticipate filing a Petition to appoint Ronald Byer guardian over Ms. Gober's Person and Estate for the purpose of providing Mr. Byer the authority to make all medical and financial decisions on Lorraine Gober's behalf. This letter is simply intended to confirm the substance of our telephone conversation in which you indicated that you do not oppose Ronald Byer being appointed as guardian over Lorraine Gober's Person and Estate. To that end, I kindly ask that you contact me immediately if my understanding of our telephone conversation is incorrect in any way. As we discussed, we will receive notice from the Court as to the date, time. and place of the hearing to appoint Ronald Byer as guardian over Ms. Gober's Person and Estate in the future, and will provide you with that information as soon as it is received by our office. Once again, thank you for your attention to this matter. As always. please do not hesitate to contact me if you have any questions or concerns. MAM/j1d:796924. ~ Very truly yours, arc oyer 11.x. Pos tal Ser vic~,r, ,,`, CE Rfi1 FIE D 11 11A1L Th; RE1/ EIPT (Do-n estic Msil .Dnly No Ins urance C overage Provided) ~d eliuery irrfa rmatio n visit o ur website ~ t www.usps.aom~; PosYace ~ ~ j ~'~! ~~ Certified Fee ~ Pastmark Return Receipt Fee I Here {Endorsement Required) ~ Restricted Deliwn~ Fee i (Endorsement Required) ~ 1 Tatal Postage & Fees ~ ~ v S°ntTo ~} v~-~`/ .._ . Street, Apt. No.: ~. or PO Box Nc. __z - -~7--~- -~~--- ---~~- - ----------t------- --- ! Clay Siaie, ziP+~ - ~ ~ 1 ~G~ ~~ .,, ... 2, and 3. Also complete d Delivery is desired. nd address on the reverse turn the card to you. ~ the back of the mailpiece, ;pace permits. r K ~[- y Ci~y,~A ~~ ^ Agent L/,Y.7 C Addressee B, ceived by (Printed N e) C D ~e ¢f Delivery D. Is delivery address different from item 1?/ u Ye: If YES, enter delivery address below: ^ No 3. S rvice Type rtified Mail L~ Express Mail ^ Registered Return Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Feej ^ Yes :~ 7~~8 3230 0200 3420 8435 >ruep"14, Domestic Return Receipt 102595-02-M-1540 Street Address: 30~ North f=ront street_ Harrisburg. PA 17101 Mailing Address: P.O. Boz 999. Harrisburg. PA 17108 Phone: 71 ;?37.? 100 Fay: 71 ;?3 i J 10~ Mark .9. Mover (~I;~ 441-3960 namover~tr~tthlal~ . com April ~_ ?010 VLA CERTIFIED MAIL/REGIILAR MAIL 7008 3230 0000 3420 8442 Karen Clulinskas R.R. #2 Barnesville, PA 18? 14 Dear Ms. Chilinskas: It was a pleasure speaking with you several days ago regarding your aunt. Lorraine Gober, who is currently a resident at Golden LivingCenter -Camp Hill. As we discussed. we anticipate filing a Petition to appoint Ronald Byer guardian over Ms. Gober's Person and Estate for the purpose of providing Mr. Byer the authority to make all medical and financial decisions on Lorraine Gober" s behalf. This letter is simply intended to confirm the substance of our telephone conversation in which you indicated that you do not oppose Ronald Byer being appointed as guardian over Lorraine Gober's Person and Estate. To that end, I kindly ask that you contact me irmnediately if my understanding of our telephone conversation is incorrect in any way. As we discussed, we will receive notice from the Court as to the date, time, and place of the hearing to appoint Ronald Byer as guardian over Ms. Gober's Person and Estate in the future, and will provide you with that information as soon as it is received by our office. Once again, thank you for your attention to this matter. As always, please do not hesitate to contact me if you have any questions or concerns. MAM/j1d:796928. ~ Very truly yours, Marc A. o er °o `° ~ >; ~ ~' ' • p - - - ' n~ ~ 1--'USSagP.. i ~ ____ / ~J,1 ~ ~ m ~ 7 `' p Certified Fee i p p Return Receipt Fee (Endorsement Required)) i ~ Postmark ~ Here O O Restricted Delivery Fee (Endorsement Required) m ~- ~ Total Postage & Fees m ~ p p ~ Senf To ----'--------- - --~,--1{~ Street. Apt. No.; -- - -~---------- ~- - or PO Box Na. ~- ~ '~ ~ ~ ~ _ 1 1. -~~ ------ i ------------~~ ----- --- `-•----- --•-----r Crty, State. _.P+4 . r•l I - ------ --°-°---, -----°--..-----°---- r.- :16 /1. 1, 2, and 3. Also complete :ted Delivery is desired. and address on the reverse return the card to you, I to the back of the mailpiece, f space permits. A. Signature X ^ Agent ^ Addressee to: ~~'i 1 IQ, .~ / ~~ D. Is delivery address different from item 1? Yes If YES, enter delivery address below: ^ No 3. Service Type ertified Mail ^ Express Mail ^ Registered Return Receipt for Merchandise ^ Insured Mail C.O.D. 4. Restricted Delivery? (Extra Fee) ^ Yes 7~~8 323 ~~00 342 8442 vice la~- ~ebruary 2004 Domestic Return Receipt 102595-02-M-1540 Street Address: 30~ North Front Street. Harrisburg. PA 17101 Mailin<_~ Address: P.U. Bos 999. Harrisburg PA 17108 Phone: 717237J100 Fax 71?.'_'37.710~ Mark A. Alover (?I ~) 4d 1-3960 mmover~~.tthlatir. coma April ~, 2010 VIA CERTIFIED MAIL/REGULAR MAIL 7008 3230 0000 3420 8459 John Cavanaugh 36 East Spruce Street Mahanoy Cit<~. PA 17948 Dear Mr. Cavanaugh: It was a pleasure speaking with you several days ago regarding your aunt. Lorraine Gober. who is currently a resident at Golden LivingCenter -Camp Hill. As we discussed. we anticipate filing a Petition to appoint Ronald Byer guardian over Ms. Gober's Person and Estate for the purpose of providing Mr. Byer the authority to make all medical and financial decisions on Lorraine Gober's behalf. This letter is simply intended to confirm the substance of our telephone conversation in which you indicated that you do not oppose Ronald Byer being appointed as guardian over Lorraine Gober's Person and Estate. To that end, I kindly ask that you contact me immediately if my understanding of our telephone conversation is incorrect in any way. As we discussed, we will receive notice from the Court as to the date, time, and place of the hearing to appoint Ronald Byer as guardian over Ms. Gober's Person and Estate in the future, and will provide you with that information as soon as it is received by our office. Once again, thank you for your attention to this matter. As always, please do not hesitate to contact me if you have any questions or conceals. MAM/jld:~96929. ~ Very truly yours, arc A. oyer 1, 2, and 3. Also complete ted Delivery is desired. and address on the reverse return the card to you. to the back of the mailpiece, f space permits. to: urn ~ ~~? A. r B. Received by (Printed Name) C,p~etC~ of Deli - y-~-/~ D. Is delivery address different from item 1? ^ Yes If YES, enter delivery address below: ^ No 3. 5 rv~ce type - Certified Mail ^ Express Mail " Registered ~eturn Receipt for Merchandise ^ Insured Mail ^ C.O.D. a. Restricted Delivery? (Extra Fee) ^ Yes ,ice. 708 323 3022 3420 8459 :bruary 2004 Domestic Return Receipt 102595-02-M-7540 Street Address- 30~ North Front Street. Harrisburg. PA 17101 Mailin<_~ Address: P.O. Box 999_ Harrisburg. PA 1710 Phone: 71?.~37J100 Fax ?1?.~3;.710~ A4ark A. 1~9over• (^l.,l =x=11-3960 mmove~•i~a~.tthla~ . com April ~, 2010 i~h4 CERTIFIED MAIL/REGULAR MAIL 7008 3230 0000 3420 8466 Cath} Evans 323 East Pine Street Frackville, PA 17931 Dear Ms. Evans: It was a pleasure speaking with you several days ago regarding your aunt, Lorraine Gober, who is currently a resident at Golden LivingCenter -Camp Hill. As we discussed. we anticipate filing a Petition to appoint Ronald Byer guardian over Ms. Gober's Person and Estate for the purpose of providing Mr. Byer the authority to make all medical and financial decisions on Lorraine Gober's behalf. This letter is simply intended to confirm the substance of our telephone conversation in which you indicated that you do not oppose Ronald Byer being appointed as guardian over Lorraine Gober's Person and Estate. To that end, I kindly ask that you contact me immediately if my understanding of our telephone conversation is incorrect in any way. As we discussed, we will receive notice from the Court as to the date. time, and place of the hearing to appoint Ronald Byer as guardian over Ms. Gober's Person. and Estate in the future, and will provide you with that information as soon as it is received by our office. Once again, thank you for your attention to this matter. As always, please do not hesitate to contact me if you have any questions or conceals. Very truly yours, MAM/j1d:79~932.~ ~ e. • , r ~ _ ~ ~{ i u ( r ~ ~ r Postage $ j ~~ ~ ~ ~' n Certified Fee ~ ~ Retum Receipt Fee ~ Postmark Here ~ (Endorsement Required; ~ f- RPStricted DeliverT Fee ~ (Endorsement Requiredi ~ n i L1 Tota{ Pos;age & Fees ,~ I n ~ ~ ~ ~ r ~ Sent To ~ ~- ~------ ----------------------------- --- Street. Apt. No.. -- i --- -- ------------- --- - i or PO Box Nc. City, State. Zlp+ l ~~ t' :a~ e~ / I is 1, 2, and 3. Also complete I I X SlgnatuL~~~~'t"~ cted Delivery is desired. ie and address on the reverse "~ I return the card to you. I B. Received by (Printed Name) 'd to the back of the mailpiece, if space permits. d ta: ~~~ ~ ~~~- ~~~ ,5~ ~ ^ Agent C. D. Is delivery address different from ftem 1? ^ Y~: If YES, enter delivery address below: ^ No 4. Restricted Delivery? (Extra Fee) ~-yam ~. Service Type rtifted Mail O ~resa Mall Registen3d Retum Receipt for Merchandise ^ Insured Mall C.O.D. -+- 7DD8 323D DDDD 3420 8466 -vrce ~~ =ebruary 2004 Domestic Return Receipt ~o25s5-o2-nn-t5au Street Address: 30~ North Front Street_ Harrisburg. PA 17101 Mailim~ Address: P.O. Boa 999. Harrisburg. YA 17108 Phone- 71 1.237.7100 Fay: 717?37.710> Mark A. Mover (' 1 'l 441-3960 ~nmoverititthla~~~. cof~z April ~, 2010 VLA CERTIFIED MAIL/REGULAR MAIL 7008 3230 0000 3420 8411 Georgine Gober 722 East Mahanon Avenue Mahanoy City, PA 17948 Dear Ms. Gober: It was a pleasure speaking with you several days ago regarding your aunt. Lorraine Gober, who is currently a resident at Golden LivingCenter -Camp Hill. As we discussed, we anticipate filing a Petition to appoint Ronald Byer guardian over Ms. Gober's Person and Estate for the purpose of providing Mr. Byer the authority to make all medical and financial decisions on Lorraine Gober's behalf. This letter is simply intended to confirm the substance of our telephone conversation in v~~hich you indicated that you do not oppose Ronald Byer being appointed as guardian over Lorraine Gober's Person and Estate. To that end, I kindly ask that you contact me immediately if my understanding of our telephone conversation is incorrect in any way. As we discussed, we will receive notice from the Court as to the date, time, and place of the hearing to appoint Ronald Byer as guardian over Ms. Gober's Person and Estate in the future, and will provide you with that information as soon as it is received by our office. Once again, thank you for your attention to this matter. As always, please do not hesitate to contact me if you have any questions or concerns. MAM/j1d:796~60. ~ Very truly yours, arc oyer Th7 . ~CEf~~Fl~fl 'A~I~-1LT~ RECEIPT (Domesfic.Mail Duly, No Insurance Coverage Prouided) _~ ' ~rdelhrery tnfarn[ation visit our ~nrebsitP at ww~.., ~e.,~ .....,. _ O f1J ~ Postage m Certitisd Fee ~ ~ ~ Retum Receipt Fee i (Endorsement Reouiredt O Restricted Delivery Fee 0 (Endorsement Required] m r-- ~l,4-i Pa,tmark Here rl_I Total Postage 8 Fees m ~ I Sent to ,~ ~ ~Sfreet,slpi`. ~-4']~~_~~~/Vj~J~(-~+-&~(~~/_`\/„~~~~,!/L~J~~-• -- ---------------° ~ or P4 ©ox No. ._/____\r_----!__t I: t~iL_.~~i ~ ~ . _ ~ t City; State, Zta:4 --- -- - - -~------- • ------°'-1 •:~a ~e. 1, 2, and 3. Also complete 'ed Delivery is desired. and address on the reverse eturn the card to you. to the back of the mailpiece, space permits. A. Signature B. Received by (Primed Name) D. Is d~4ivery address different from item If YES, enter delivery address below: ^ Agent ate of Delivery -~ - ~(,~ D Y-----_ ^ No to: ~ f 1~ ~ lS~ ,~~.~~ .b~~~~~~~~~ ~~ u. ce lype ------~ Certified Mail F„~ress Mail Registered alum Receipt for fJierohandise ^ Insured Mail C.O.D. v. Restricted Dalivann ic,...,. ~__, _ ,----_ . _ , u Yctc ro08 3232 0002 3422 8411 ~ruary 2004 Domestic Return Receipt 102595-02-M-1540 Street Address: 30~ North Front street. Harrisburg. PA 1710] Mailing Address: P.O Box 999. Harrisbure. PA 1710b Phone: 717237.7100 Fax: 717 237.710 Mark A. Moyer ~'1'i 4=11-3960 ~ninnrer;2alhlatr. cony April ~. 2010 VIA CERTIFIED MAIL/REGULAR MAIL 7008 3230 0000 3420 8473 Mary Murphy 2014 West Western Drive Chandler. AZ 8224 Dear Ms. Murphy: I am writing to you at this time in ].fight of my inability to contact you by telephone on several occasions. Please note that we anticipate filing a Petition to appoint Ronald Byer as guardian over the Person and Estate of your mother, Lorraine Gober, for the purpose of providing Mr. Byer the authority to make all medical and financial decisions on your mother's behalf. To the extent your mother has appointed you her Attorney-in-Fact and Living Will Proxy pursuant to a March 19. 2004 Power of Attorney and March 25, 2004 Living Will, we will be asking the Court tc rescind the Power of Attorney and Living Wi11 Proxy so as to provide Ronald Byer the exclusive ability to render medical and financial decisions on your mother's behalf. Please feel free to contact me upon your receipt of this correspondence if you would like to discuss this matter further, or if you have any questions. Thank you for your attention to this matter. MAM/i1d:7973~i.1 Very truly yours, arc yer f.EIEI~ MAIL TM REC EIPT ~Mait Dnly ; ~vo Jns ur~nce C averege Provided) -- --, i i _,~. °ostage j a ~ ~rtitied Fes ( I ~'ostmark ecsipt Fee ~_ Ftsquued~ ~ i Here elivery Fee ~-~ . Rsquirsd ~.__.~ a' ~ Fees , '" i --- -- - ie.: -- ~ ~ t `.F--- ---- - ~-~F- ---------------- IP+4 ~r. - - EXHIBIT E CONSENT OF PROPOSED GUARDIAN I, Ronald Byer, reside at 524 Haystack Drive, Zion Grove. PA 17985. 2. I am the nephew of Lorraine B. Gober who currently resides at Golden LivingCenter -Camp Hill, 46 Erford Road, Camp Hill, PA 17011. 3. I am aware of Lorraine B. Gober's medical and psychiatric conditions and hereby consent to act as Guardian over the Person and Estate of Lorraine B. Gober, the alleged incapacitated person. /~ :~G/d e ,~ .u ~. Ronald Byer 797681.1