HomeMy WebLinkAbout11-07-11 (2)IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS COURT DIVISION
In Re:
JONATHAN KINZLER,
An alleged incapacitated person
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NOTICE THAT RESPONDENT HAS NO LEGAL COUNSEL
Petitioners, David R. Kinzler and Kay D. Kinzler, by and through their
attorney, Paul D. Daggs, Esquire, respectfully state the following:
1. Petitioners are the individuals seeking to be appointed Plenary
Guardians of the Person and Estate of Respondent, Jonathan Kinzler.
2. Petitioners are the parents of Respondent.
3. Respondent lives with the Petitioners and Petitioners are the primary
caretakers of Respondent.
4. Respondent has no assets and only receives $449.34 of Social Security
benefits per month.
5. Respondent suffers from severe, permanent brain damage, and lacks
the capacity to understand the nature of these proceedings or assist the court or any
counsel regarding these proceedings.
6. Respondent has no legal counsel and is financially unable to retain
counsel.
7. It would be an undue burden on Petitioners to retain counsel for
Respondent. Petitioner, David R. Kinzler, is employed as a part-time custodian at
Oak Flat Elementary School in Big Springs, PA. Petitioner, Kay D. Kinzler, is
employed as a rural carrier for the U.S. Postal Service.
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8. Petitioners intend to bring Respondent to any hearings related to their
Petition seeking Plenary Guardianship. Therefore, the Court will be able to observe
firsthand the incapacities of the Respondent.
Respectfully submitted,
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Paul D. Daggs, Esquire
Attorney for Petitioners
Attorney ID No. 64688
DAGGS LAW, Li.c
130 W. Church Street, #100
Dillsburg, PA 17019
(717) 884-4963