HomeMy WebLinkAbout06-02-11Jeffrey B. Engle, Esquire
SHAFFER & ENGLE LAW OFFICES
SI2 Market Street
Millersburg, PA 17061
717-692-2345 *phone
717-692-3554 *fax
Jeff~7shafferengle. com
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IN THE MATTER OF THE PERSON OF
SEAN A. AVENI,
AN ADULT INDIVIDUAL
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
N0.21-09-0795
MOTION FOR CONTINUANCE
AND NOW, this ls` day of June, 2011, comes the Petitioner, Mark R. Aveni, by and
through his counsel, Shaffer & Engle Law Offices, more specifically Jeffrey B. Engle, Esquire,
and respectfully requests a continuance in the above-captioned matter, and in support thereof,
avers as follows:
1. Petitioner, Mark R. Aveni, filed a Petition for Modification of Guardianship and Request
for Entry of an Emergency Order on or about May 23, 2011.
2. Petitioner, Mark R. Aveni, is represented by Jeffrey B. Engle, Esquire, of Shaffer &
Engle Law Offices, LLC, 512 Market Street, Millersburg, PA 17061.
3. The undersigned counsel is unaware if Respondent, Anita Aveni, is currently represented
by her prior counsel, John M. Kerr, Esquire.
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4. By Order dated October 24, 2011, the Court appointed Michael Whare, Esquire, as
guardian ad litem for the Incapacitated Person, Sean A. Aveni.
5. By Order dated May 24, 2011, the Respondent is prohibited from relocating the subject
incapacitated person outside the jurisdiction of Cumberland County.
6. Also, by Order dated May 24, 2011, a hearing was scheduled in this matter for June 10,
2011 at 1:00 p.m.
7. The undersigned counsel will be out of town from June 9-13, 2011.
8. The undersigned counsel is, therefore, respectfully requesting a continuance in this
matter.
9. It is believed and therefore averred, that delay will not substantially prejudice the parties
to this matter.
10. Opposing counsel, John Kerr, Esquire, has been contacted; however, there has been no
response whether Attorney Kerr opposes this motion.
11. Michael Whare, Esquire, court appointed guardian ad litem for the incapacitated person
has also been contact; however, there has been no reply as to whether Attorney Whare
oppose this motion.
WHEREFORE, the undersigned counsel respectfully requests that this Honorable Court
grant Petitioner's Motion for Continuance.
Dated: l t l
Respectfully submitted,
Jeffrey~S. ~i~fe,~s i
I.D. 0.76644
SHAFFER & EN
512 Market Street
Millersburg, PA 17061
(717) 692-2345
Attorney for Petitioner
W OFFICES
IN THE MATTER OF THE PERSON OF
SEAN A. AVENI,
AN ADULT INDIVIDUAL
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
N0.21-09-0795
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Motion for Continuance was
sent First Class U.S. Mail to the following:
John M. Kerr, Esquire
5020 Ritter Road, Ste. 109
Mechanicsburg, PA 17055
Attorney for Petitioner
Michael Whare, Esq.
37 E. Pomfret Street
Carlisle, PA 17013
Attorney for Sean A. Aveni
Daniel R. Lovett, Esq.
360 Stonycreek Street
Johnstown, PA 15901
Anita M. Aveni
51 Kensington Drive
Camp Hill, PA 17011
Date: ~- l ` ~ 1
v V V.J~
Melissa Wise, Paralegal to
Jeffrey B. Engle, Esquire
SHAFFER & ENGLE LAW OFFICES
512 Market Street
Millersburg, PA 17061
(717) 692-2345