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HomeMy WebLinkAbout03-10-11IN THE COURT OF COMMON PLE AS OF CUMBERLAND COUNTY PENNSY n^, ~`~ , LVANIA ORPHANS' COURT DIVISION -<.. ezr - '~' -""' a r.. ~~~ = O.C. N0.2011-0239 ~~ ~ ~, C3~70 ESTATE OF DOROTHY E. WERNER ~J~~- ~ - , AN ALLEGED INCAPACITATED PERSON n ~•' `'•' ~ c_ MOTION FOR CONTINUANCE OF HEARING HCR ManorCare Camp Hill ("ManorCare"), by and through its attorneys, Kennedy, PC Law Offices, files this Motion for Continuance of Hearing and avers the following in support: 1 • A guardianship hearing is scheduled for the above-captioned matter on March 24, 2011 at 3:00 p.m. 2. Petitioner's counsel was informed by the proposed guardian, Tina Hess on behalf of Good News Consulting, Inc., that a representative of Good News Consulting, Inc. will not be available to attend the scheduled March 24`~ hearing due to a previously scheduled monitoring visit from the York County Area Agency on Aging. 3 the next available date in order for a representative of Good News Consulting, Inc. to be available to testify. 4• Petitioner's counsel spoke with Court-appointed counsel, Kathleen Shaulis, Esquire, regarding this Motion and Attorney Shaulis indicated she did not object to the request because she would like to take the testimony of the proposed guardian as well. Petitioner is respectfully requesting the guardianship hearing be rescheduled for rn ~, :~ c:~ <:• _ u _.,,.. _r_, _:_ ; .~ ~- ~`~~ c~ p -t, WHEREFORE, HCR ManorCare Camp Hill respectfully requests the d• hearing scheduled for March 24, 2011 in the above-captioned matter be rescheduled or~p available date m order for a representative of Good News Consulting, Inc. to be available a next testify. to Respectfully Submitted, Date: .~ qy By: ~ ~~ ~ edy, Esqu' A y I.D. No.: 682 8 Benjamin J. Glatfelter Attorney I.D. No.: 203935 )KENNEDY, PC Law Offices P.O. Box 5100 H~sbm'g, PA 1 71 1 0-0 1 00 (717) 233-7100 Attorneys for HCR ManorCare Camp Hill