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Home My WebLink About12-02-11IN RE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ADA GRACE COCKLIN, :ORPHANS' COURT DIVISION An alleged incapacitated person PETITION FOR THE APPOINTMENT OF PERMANENT PLENARY GUARDIAN OF THE PERSON AND ESTATE PURSUANT TO 20 P.S. &5511 AND NOW COMES THE PETITIONER, the Cumberland County Aging & Community Services, in and for Cumberland County, Pennsylvania, by its solicitor, Anthony L. DeLuca, Esquire, who represents and avers as follows: 1. The Petitioner is Cumberland County Aging & Community Services, in and for Cumberland County, Pennsylvania, with its office located at 1100 Claremont Road, Carlisle, Cumberland County, Pennsylvania. 2. The alleged incapacitated person is Ada Grace Cocklin, age 93, who currently resides at Claremont Nursing & Rehabilitation Center, 1000 Claremont Road, Carlisle, Cumberland County, Pennsylvania. 3. The known relatives of the alleged incapacitated person are c-~ a. Mary Ann Wise -niece .~ _~-? ; -^' 1839 Ridgeview Drive ~'; ~~` `_- ~~ _-- Carlisle, PA 17013 _h ~ r,'; y ~ _ b. Barbara -last name unknown -niece ~~=~ ~ -. California ~ ~' `':= . __ _., -= 4. The Petitioner is not related to Ada Grace Cocklin. 5. The Petitioner's interest is that of a welfare agency concerned with her welfare and is familiar with her case. 6. Ada Grace Cocklin, has, for at least three (3) months, been incapable of managing and caring for herself and her financial affairs. 7. On September 9, 2411, a psychological evaluation was performed by Lisa Eaton, PsyD. who concluded that Ada Grace Cocklin exhibits symptoms of mental incapacity, including but not limited to: A. A pattern of memory and language deficits suggestive of cortical dementia (senile dementia, alzheimer's type) with delusional/psychotic features; B. Auditory hallucinations; C. Functional memory impairment; and D. Moderately impaired recall. 8. Lisa Eaton, PsyD. further concluded that the nature and severity of cognitive and affective disturbance make Ada Grace Cocklin incapable of individual and independent descision making. A copy of Dr. Eaton's report is attached hereto, marked as Exhibit "A", and incorporated herein by reference. 9. Investigation by Petitioner's authorized representative has determined that Ada Grace Cocklin is totally bed bound and is diagnosed with ambulation dysfunction deep vein thrombosis, chronic obstructive pulmonary disease, muscular degeneration, hyptotension, osteoarthritis, depression, Hx GI Blood, hypothyroidism, GERD, visual hallucinations, and edema. 10. Ada Grace Cocklin's mental incapacity prevents her from managing and caring for the affairs of her person and estate. 11. On or about June 21, 2011, Ada Grace Cocklin moved to Claremont Nursing & Rehabiltation Center to ensure she was safe and that her needs would be met. 12. The Petitioner believes and, therefore, avers that Ada Grace Cocklin's monthly income is $1,164.00, consisting of Social Security and a Pension, and that she is the owner of real estate situated at 802 Fairfield Street, Mechanicsburg, Cumberland County, Pennsylvania. 13. Petitioner requests that Keystone Guardianship Services be appointed Permanent Plenary Guardian of the Person and Estate of Ada Grace Cocklin and Keystone Guardianship Services agrees to be the appointed Guardian. 14. The proposed Guardian has no interest which is adverse to the interest of Ada Grace Cocklin. 15. Petitioner believes, and therefore avers, that Ada Grace Cocklin does not already have a Guardian. 16. Petitioner asserts that Ada Grace Cocklin is incapacitated as defended in Chapter 55 of the Probate Estates and Fiduciaries Code. 17. Because of her impaired mental and physical condition, Ada Grace Cocklin lacks the capacity to provide for her own personal care and maintenance. 18. Because of her mental and physical condition, Ada Grace Cocklin is unable to mange her financial affairs, property and business and is unable to make and communicate decisions relating thereon. 19. Ada Grace Cocklin does not have an existing power of attorney which would be a less restrictive alternative than Guardianship. 20. The failure to appoint Keystone Guardianship Services as Permanent Plenary Guardian of her Person and Estate will result in irreparable harm to the person and estate of Ada Grace Cocklin. 21. To Petitioner's knowledge, no previous application has been made for the Order herein requested or for a similar order. 22. No other Court has ever assumed jurisdiction in any proceeding to determine the incapacity of Ada Grace Cocklin. 23. Petitioner believes and, therefore, avers that Ada Grace Cocklin may have sufficient assets to pay for the services of Keystone Guardianship Services. A copy of Keystone Guardianship Services fee schedule is attached hereto, marked as Exhibit "B", and incorporated herein by reference. WHEREFORE, the Petitioner respectfully requests that: 1 . The Court appoint Keystone Guardinship Services as Permanent Plenary Guardian of the Person and Estate of Ada Grace Cocklin; and 2. The Court authorize Keystone Guardianship Services to charge a guardianship fee as set forth in the fee schedule mentioned herein. Respectfully Submitted, Anthony L. uca, Esquire 113 Front Street P.O. Box 358 Boiling Springs, Pennsylvania 17007 (717) 258-6844 VERIFICATION I hereby verify that the facts and information set forth in the foregoing Petition for the appointment of Permanent Plenary Guardian of the Person and Estate of Ada Grace Cocklin pursuant to 20 P.S. §5511 are true and correct to the best of my knowledge, information, and belief. I understand that any false statements contained herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: ~L`,V ~.~ ~,E~f' '~~, a-o ~ 1 ~~ Janet Paull 11 09.59 FFOM-Cumberland Co A ~ CS 7179605529 T-77~ PuU~~i~~~~ r-~r~ i. REPORT ~1F CONSULTATION LastNeme Fir Mtdtlte Room N^ G ~ .L/1 ~9/1~ ~ ~~GIG ~ Record Na From: Attending PF,y5lcian 7a: Consulting P-ystdan Dale a ~ ~! Qr Fin~ge~ (~ /L /l_~'S~._...~.:! ~ ...~./c~ ~~ Ccu vQ ~ C yP~•- ~ Q c~'~ g ~ -~-~~~I d x r~-~a~~la ~~ ~o~~~~ ~-~.~~ ~--~~• a -~c~. ~~ -~ T---. ~"` ~r,~ 11/~T~{/1/L f L.~~G I ~ ~ll~-,~~ ~'~~M~h- ~ ~'.'1 ~-r I~t~ G' ldLlx"~ r f" ~ ~ ~i!~¢' ~S~ ~ / t-~~ f~ ~ 1/~t'}'Y~O ,('tl./C~ ,~:-A,..l~ f , /~.i{..d.t ~~ ~ /j^~p -~.LS~.-t.~ l U~~!~1.~ ~ ~- ~ mot.. r ~r ~ cr l' h L~~~ ./L~ >o~fitf7 ~. p-~ ~' _ ~.E7~'-T?i `~'J..P . e/''~ Gi~~~ - 1.~~ fi'D !' Phi p u~ /ti -- / ' (/ /,•e~./lc~~(~2 C +~ Y~v~ k- ~~L~f~ ~Gc c. Qn ~- f- r~-~1t _l`.ow~icQ j~ovc ~C mot-1•- ~ . c ~ ~ ~~r~~ ~/6 ~ c~ ,~ ~ 1 ~ i ~ e~~ ~ ~ -f s ~- ~d~~~ ~ - ~-te~ t~ ~ ~ D~~ ~ ~ ~~- ~ `~ ~-~" ' fL~ ~~ /~ ~ ~ A.f i l ~ L ~1lJQQ ~ r ~?~ /Q D~`!1 'f "7 a ~ ~ ~~ P..~ Go,~ i u d G yv~ ~ -~ -t ~K cfz.o~ cv ,%~.~ f-t. o+.-C~ ( ti~-e ~-,! ~ ~/ J Or n Q f C ; . ytrc o on»vKr. o . _~,..,_..T._-_.._.. atpn~aure q+ oonaWant ~ ~ f ~ Z- v r- i r. .~ Fe.,nt~si ee~ooADar.~v~w.awMetrwot~•~~w,.,•••.e~cwc~v.~ r~Crvr~1 yr a.vnaa~~,~R~rvn ~,y aa+rtra tiv ua ti • EXHIBIT "R" ~~~ 2 ~ 11 09:59 FPOM-Cumberland Co ~ & CS ?1"r 9605529 r'~ REPORT OF CONSULTATION T-?? D P6003I0003 r-~S'l5 Last Name Flr Middle Room No. Reonra No. From: Attending Phy"sje~~an TD; Consul Pnysicien T ~ ~~ ~l/lt ! ~ 6~ Z~ Dalo ~ ~ / ~ Findings ~,G .. _`~ / /t D14.,.P'~ Ctrl f Siy ~j~ ~Z"s ~.r o~ ~I ~~ ~ f , ~LCi-~a ~ ~~..~ ~ ~ ,.,,,,UGC a I , ~ ~~.~..~s-~= ;r~'~.~~ f l~~ 6r-r1~cc1J G 11- ~,l s ... '~ ~ ,. _ ~~'~ , k -- -~-• - ' ~~ .~•~, dee...~_• Pin ha ~~i e ~'3' ~n~~ r1~,~ r~ ,~2,_1'~,,~L _.r. !~ v ~~ /~ !ice ~.Q l _Y.1_.~._/.Lr~l~[1~~L1(' ~ ~~O ~~xt'~/t~7 ha 11 ~.G1~..~_ ~ • ~? X ~/ d Q. y !9 lar~ !'~ v a ~ .. 1_ U : ~ y~-~ ,.~ ~ !'sue, ~/ Oloyn~tl8~ ~` ~ ~ rM! ~ O ~ ~~ L.G 1/tJ /rid. Q t ~ LLD C ~~ Q T'^'isr e.~' ~ l' J .~ -F" /~-Gc-s1,~- -'F-' ~ t /L.i~ ~ ca f {~ 41 yS-tryl ic. ~.+Q~ ~c_~~es I~~ r~~i .tee a e~ ~.e 1~.~-~C. ~ - R~„ade r~s~. ~~ ~ Pt y c ~ fi ~ - ~y.,-h,r/e -±- ~ ~~ ~i fy o l_.oa/~ ~ f1~~ +-- .4~ec eve ~ ~ yftii hum ~ ~k~.e ~~. ~clG l~ _ a /t C a t~ 9 1 o r-e ~~ ~~ ~ /~ r /~ Gl~.~ ct ~ J t n-Cg.e.~--o~~~. ~- d.e. r ~ C~ u .~ ~~~fi~~Q~7v` L ~ ~G~Pr G /L~,L G~-~ .~-c.~ Q~ ~ ~ ~G ~ Date of Consultadon; Qr. ~~ ~y°t` Q ~ SlgnsWro 01 Conavlrent ' ~ ~ Foln. eel a tlHleCtly Oar utlrw~ u X09 ~WOI Ra>.2~11 ww~vA~loav(bo.wm YAP •flWTCV IM V.On `rl d ~~ ~ l ~I ~ r] '7 i ~/[~ r/L REPORT OF CONSULTATION ~'~, -~ ~/ S KEYSTONE GUARDIANSHIP SERVICES Fee Schedule July 201 1 GUARDIANSHIP Appointment Fee (one time fee) Hourly Fee Minimum Monthly Maintenance Fee Supplemental Security Income Recipients Fee Costs as incurred (Mileage, postage, telephone calls, etc.) POWER OF ATTORNEY Appointment Fee (one time fee) Hourly Fee Monthly Maintenance Fee Supplemental Security Income Recipients Fee Costs as incurred (Mileage, postage, telephone calls, etc.) AGENT FOR ABSENTEE FAMILY 500.00 75.00 200.00 100.00 500.00 75.00 200.00 100.00 Set Up Fee (one time fee) $ 200.00 Monthly Maintenance Fee 100.00 Costs as incurred (Mileage, postage, telephone calls, etc.) NOTE: Hourly fees assessed for excessive time spent on account, this will be established and understood prior to entering into the service EXHIBIT "B"