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HomeMy WebLinkAbout10-04-12IN THE MATTER OF THE PERSON : IN THE COURT OF COMMON PLEAS AND ESTATE OF: :CUMBERLAND COUNTY, PENNSYLVANIA KATHLEEN M. KNISELY, :ORPHANS' COURT DIVISION An alleged incapaciated person : NO. 21-12-946 PETITION FOR APPOINTMENT OF PERMANENT PLENARY GUARDIANS OF THE PERSON AND ESTATE AND NOW COMES THE PETITIONER, James G. Knisley, by his attorney, Anthony L. DeLuca, Esquire, and represents and avers as follows: 1. The Petitioner is James G. Knisely, an adult individual, who resides at 3822 Pamay Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 and is a son of Kathleen M. Knisely. 2. The alleged incapacitated person is Kathleen M. Knisely, widow, 79 years of age, who resides at, 23 West Lawn Circle, Wormleysburg, Cumberland County, Pennsylvania 17043 since approximately 1962. 3. Ms. Knisely is the mother of five (5) children who are identified as follows: a. Samuel Scott Knisely -son 135 Harmon Avenue -Unit 3705 Las Vegas, Nevada 89109 b. Lee Ann Knisely -daughter n ~~ 485 Front Street ~ ~? _,.~ ~ ~ ~` Louisville, Colorado 80027 W ~' n , ` ~ ~? v < ~ ~ ~ 3 ~J ~> r- <= . s l c. Barbara L nn Knisel M.D. - dau hter Y Y~ g ~"' ~'` v ~ ~ i a t~ -~ -~- 3501 Sunset Drive n~-~~ ~ , v._ -~-, Madison, Wisconsin 53705 o ~ ~ - ~ ;a ~=' c a + 4 ~n _~ c ., , r r ~ ~ d. James Grant Knisely -son 3822 Pamay Drive Mechanicsburg, PA 17050 e. Kathleen L. Knisely -daughter f. 9008 Avis Court g. Vienna, Virginia 22182 4. On or about August 30, 2012 the Petitioner filed an Emergency Petition to Adjudicate Incapaciated and Appoint Temporary Guardian of the Person and Estate. 5. On or about August 31, 2012 an Emergency Guardianship Hearing was held, resulting in an Order of Court which stated that, after hearing, the Court could not find by clear and convincing evidence that an Emergency Guazdian need be appointed, and the request was denied. A hearing on the Petiton for the appointment of a guardian of Kathleen M. Knisely, an alledged incapaciated person, was scheduled for Friday, October 26, 2012, at 9:30 a.m. by Order of Court. A copy of the Emergency Petition and Orders of Court are attached hereto, incorporated herein by reference and mazked as Exhibit «A„ 6. Kathleen M. Knisely has, for at least four (4) months, been incapable of caring for herself. 7 Kathleen M. Knisely exhibits symptoms of mental incapacity. ~ i ~ ~ 8. Kathleen M. Knisely's mental incapacity prevents her from managing and caring for the affairs of her person and estate. 9. On or about July 27, 2012, Kathleen M. Knisely was seen by Walter Watkin, Jr., M.D. who listed a number of medical problems confronting Kathleen M. Knisely, one of which was dementia and also listed the medications being taken, two (2) of which were Namenda Titration Pak 5 and Namenda 10 mg oral tablets for memory. 10. On or about August 30, 2012, Kathleen M. Knisely, accompanied by her son, Samuel Scott Knisely, was seen by Esther Oh, M.D. at Johns Hopkins Bay Views Medical Center. 11. The report of Dr. Esther Oh reflects the following: a. That Mrs. Knisely's son, Samuel Knisely, was identified as a neurologist; b. That Mrs. Knisely was at Johns Hopkins for an evaluation of her memory problems for the past year; c. That, according to her son, Samuel Knisely, his mother had been having problems with short term recall and appears to be frequently confused; d. That, according to her son, Samuel Knisely, his mother, in September, 2011, was having sleep disturbance and some delusions; and e. That Samuel Knisely also notices increased anxiety and absentmindedness. 12. The report of Dr. Esther Oh also stated that: a. The patient also acknowledges that she has been having some memory problems but thought that the medication Namenda 10 mg which she takes twice daily was for sadness or depression. 13. The Mini-Mental State Exam was 25/30, missed 1 on orientation to time, missed 3 on orientation to place, missed 1 from serial 7, 1 from language. 14. 'The assessment of Dr. Oh reflects a cognitive disorder, NOS and a more in-depth neuropsychological testing was recommended. A copy of Dr. Esther Oh's report is attached hereto, marked as Exhibit "B", and incorporated herein by reference 15. Samuel Scott Knisely was a licensed physician who medical licence was revoked for, amongst other reasons, submitting fraudulent documents before the North Cazolina Medical Board. 16. Petitioner believes and, therefore avers, that Samuel Scott Knisely also suffers from certain mental infirmities and is now preying upon his mother and exercising undue influnce over her. 17. Petitioner believes and, therefore avers, that Samuel Scott Knisely arrived in Harrisburg on or about August 27, 2012 from Las Vegas, Nevada, made an unannounced . i r t visit to his mother, which visit was not known by any of the other children and discussed the possibility of taking their mother to Baltimore for a medical exam at Johns Hopkins. 18. On or about Tuesday, August 28, 2012, Samuel Scott Knisely removed his mother from her home and registered her with him at a Mariott Hotel in Mechanicsburg, PA. 19. On or about Tuesday, August 28, 2012, Kathleen Knisely spoke to her sister, Mary Lawrence, who resides in Old Tappan, New Jersey and told her that Scott had appeared at the house on Monday, August 27~`, had somehow gotten in and was due to return that morning (Tuesday) at 11:00 A.M. to take her to Baltimore. 20. Mary Lawrence contacted Caroline Knisely, wife of James, and relayed this information to her and also expressed her concern about Kathleen Knisely getting into a car with Scott; also stating that her sister was going to get into the car with him until she talked her out of it. 21. The Petitioner, at the request of his mother, was at her house at 10:30 A.M. on Tuesday, August 28th, to mow her lawn but the door was locked; he drove around the corner for a few minutes and, when he returned, he observed his mother in a car with Scott Knisely leaving her home. t i t i ~ 22. Information developed by Petitioner reflects that Scott Knisely with his mother appeared at the law office of Mette Evans and Woodside on Wednesday, August 29~', and demanded all legal documents relating to her affairs such as her Will. 23. While at the law office of Mette Evans and Woodside, a call was made by a member of that office to Kathleen Knisely Grim who is her mother's Power of Attorney and, when her daughter asked to speak to her mother, the request was denied and they promptly left the law office. 24. Information developed by Petitioner further reflects that Scott was in contact with his mother's brokerage firm, Morgan Stanley, on August 29~ and attempted to transfer funds in her brokerage account. 25. Petitioner believes and, therefore, avers that his brother, Samuel Scott Knisely, has exercised undue influence over their mother and is seeking to take control of her very substantial assets to the detriment of their mother. 26. Kathleen M. Knisely's mental incapacity prevents her from managing and caring for the affairs of her person and estate. 27. Petitioner requests that he be appointed Permanent Plenary Guardian of the Person of his mother. ~ 1 ~ 1 1 ~ 28. Petitioner requests that Kathleen Knisely Grim' her power of attorney and Wilmington Trust, a subsidiary of M&T Bank, be appointed Co-Guardians of the Estate of Kathleen M. Knisely. 29. The proposed Guazdians have no interest which is adverse to the interest of Kathleen M. Knisely. 30. Petitioner believes and, therefore, avers that Kathleen M. Knisely does not already have a Guardian. 31. Petitioner asserts that Kathleen M. Knisely is incapacitated as defended in Chapter 55 of the Probate Estates and Fiduciaries Code. 32. Because of her impaired mental and physical condition, Kathleen M. Knisely lacks the capacity to provide for her own personal Gaze and maintenance. 33. Because of her mental and physical condition, Kathleen M. Knisely is unable to manage her financial affairs, property and business and is unable to make and communicate decisions relating thereon. ' ~ 34. The failure to appoint Petitioner as Permanent Plenary Guazdian of her Person and Kathleen Knisely Crrim, her power of attorney, and Wilmington Trust, a subsidiary of M&T Bank as Permanent Plenary Guazdians of her Estate will result in irrepazable harm to the person and estate of Kathleen M. Knisely. 35. To Petitioner's knowledge, no previous application has been made for the order herein requested or for a similar order. 36. No other Court has ever assumed jurisdiction in any proceeding to determine the incapacity of Kathleen M. Knisely. WHEREFORE, the Petitioner respectfully requests that: 1 . The Court appoint Petitioner as Permanent Plenary Guazdian of the Person of Kathleen M. Knisely and Kathleen Knisely Grim, her power of attorney, and Wilmington Trust, a subsidiary of M&T Bank as Permanent Plenary Guardians of her Estate Respectfully Submitted, Anthony L. De Esquire 113 Front Street P.O. Box 358 Boiling Springs, Pennsylvania 17007 (717) 258-6844 #18067 VERIFICATION I hereby verify that the facts and information set forth in the foregoing Petition for the appointment of Permanent Plenary Guardians of the Person and Estate pursuant to 20 P.S. §5511 of 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: ~ IN RE: KATHLEEN M. KNISELY, ~n ~N THE COURT OF COMMON PLEAS OF Alleged Incapacitated Person CUMBERLAND COUNTY, P~`NNSY~VANIA ON THE PETITION OF ORPHANS' COURT DIVISION JAMES G. KNISELY N0. 21-2012-946 ORDER OF COURT AND NOW, this 31st day of August, 2012, a hearing on the Petition for Appointment of a Guardian for Kathleen M. Knisely, an Alleged Incapacitated Person, is scheduled for Friday, October 26, 2012, at 9:30 a.m. By the Court, .%~ Edward E. Guido, J. Gregory A. Kogut, Jr., Esquire James, Smith, Dietterick & Connelly P.0. Box 650 Hershey, PA 17033 Attorneys for Petitioner John E. Slike, Esquire Saidis, Sullivan & Rogers 635 North 12th Street, Suite 400 Lemoyne, PA 17043-1247 srs cn ~w ~Q ~ :~, . ~~ .~ ~ ~ ,-; `- ~' PY FROM RECORD CO c~\c: o ~_ = -° ~ -. .. ~~. ~ ~~ A TRUE to Testimony ~ hand ~~ ~ '' w .. -_ ~• '~" ' T' `~ ~uK ffi , PA ~ ~ ~~ ~; t • ~dy clsAc ot~ ~ y EXHIBIT "A" /71~ IN RE: KATHLEEN M. KNISELY, an,: IN, THE COURT OF COMMON PLEAS OF ' Alleged Incapacitated Person CUMBERLAND COUNTY, PENNSYLVANIA ON THE PETITION OF ORPHANS' COURT DIVISION JAMES G. KNISELY NO. 21-2012-946 ORDER OF COURT AND NOW, this 31st day of August, 2012, after hearing, we cannot find by clear and convincing evidence that an emergency guardian need be appointed, and the request is DENIED. By the Court, Edward E. Guido, J. Gregory A. Kogut, Jr., Esquire James, Smith, Dietterick & Connelly P.O. Box 650 Hershey, PA 17033 Attorneys for Petitioner John E. Slike, Esquire Saidis, Sullivan & Rogers 635 North 12th Street, Suite 400 Lemoyne, PA 17043-1247 srs A TRUE COPY FROM RECORD In Testimony +n-herof, I hereunto aet my hand and the ~~ of ~aidcCcurt at isle, Pq T day of CNAc of ifte Cumber c s--~ , T. ~ C') ~ ra ^'f f -x? ~-r-~ ~C ~ ~' ~~' Q ~' j : ~~ ~ ~~l t 0 ~ ~ L . ~ --r~ A 0 ~~ ~ ~~ Neil Wamer Yahn, Esquire Attorney I.D. No. 82278 James Smith Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 Attorneys for Petitioner IN RE: KATHLEEN M. KNISELY , an Alleged Incapacitated Person ON THE PETITION OF JAMES G KNISELY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION No. OCR J - 2012 - ~ ~ (~ ORDER FOR EMERGENCY GUARDIANSHIP HEARING AND NOW, this ,~ day of ~ , 2012, it is hereby ORDERED, ADJUDGED and DECREED that//f~an Emergency Guardianship Hearing for KATHLEEN M. KNISELY, is scheduled for f~ t~•-~'~ ~ ~ , 2012 at ~~ 3~ a.m.,~A. in Courtroom ~ in the Cumberland County Courthouse 1 Courthouse Square Carlisle Pennsylvania 17013 /~~ ~ ~ T BY TH -{~ .... ~, J. c~ ~' ~,-., A TRUE COPY FROM RECORD W~} c m e In Testimony wherof, I hereunto m ~-, ,~!, r _ : C': set my hand end the seal ~ ~• `~. w ~:~r=~ of said Court a . PA ~• % o ~ ~ r? y~ Q ~-. r , L-,; This ~r C? CG ~ ` ' _n `-' ~ ;-- G ~7 "D -i f"- CIsAc ofC~O~ erns Gwtt 9 ~ `~ p Cotmty Distribution List: Neil Warner Yahn, Esquire, James Smith Dietterick & Connelly, LLP, P.O. Box 65D, Hershey, PA 17033; Attorneys for Petitioner Scott Knisely, 370 Hughes Center Drive, Las Vegas, Nevada 27235 LeeAnn Knisely-Cast, 485 Front Street, Louisville, Colorado 80027 Dr. Barbara Knisely, 3501 Sunset Drive, Madison, Wisconsin 53705 Kathleen L. Knisely, 9008 Avis Court, Vienna, Virginia 22132 Neil Warner Yahn, Esquire Attorney I.D. No. 82278 James Smith Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 Attorneys for Petitioner IN RE: KATHLEEN M. KNISELY , an ) Alleged Incapacitated Person ) ON THE PETITION OF JAMES G. ) KNISELY ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION No. OC 2012 EMERGENCY ORDER OF COURT APPOINTING TEMPORARY GUARDIAN AND NOW, this day of , 2012, consistent with 20 PA C.S.A 5513, based on the clear and convincing evidence supporting the foregoing findings it is ORDERED, ADJUDGED and DECREED that KATHLEEN M. KNISELY, be and is hereby adjudged as an incapacitated person and her son, JAMES G. KNISELY, is appointed as Temporary Guardian of the Person and of the Estate for a limited duration of seventy two (72) hours. If said emergency continues, this Order may be extended, upon request, for an additional twenty (20) day time period. Within thirty (30) days of the date of this Order, Petitioner shall advance a Petition for a full guardianship proceeding consistent with 20 PA C.S.A 5511. BY THE COURT: J. Distribution List: Neil Warner Yahn, Esquire, James Smith Dietterick & Connelly, LLP, P.O. Box 650, Hershey, PA 17033; Attorneys for Petitioner Scott Knisely, 370 Hughes Center Drive, Las Vegas, Nevada 2 7235 LeeAnn Knisely-Cast, 485 Front Street, Louisville, Colorado 80027 Dr. Barbara Knisely, 3501 Sunset Drive, Madison, Wisconsin 53705 Kathleen L. Knisely, 9008 Avis Court, Vienna, Virginia 22132 Neil Warner Yahn, Esquire Attorney I.D. No. 82278 James Smith Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 Attorneys for Petitioner IN RE: KATHLEEN M. KNISELY , an Alleged Incapacitated Person ON THE PETITION OF JAMES G KNISELY r,,a O r;~ C J ~., ~1 ~ ~ z~ ~ cr G7 ~> C j ~ r ' {~~ _ f i G~ ~-i ~r7 .~ v3 =;~ ~ o ~~ ~_ J -, ':' r- --... T1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION No. OC 2012 EMERGENCY PETITION TO ADJUDICATE INCAPACITATED AND APPOINT TEMPORARY GUARDIAN OF THE PERSON AND ESTATE TO THE HONORABLE JUDGE OF SAID COURT: 1. Petitioner, James G. Knisely (herein "Petitioner"), is an adult individual residing at 3822 Pamay Drive, Mechanicsburg Pennsylvania 17050 and a son of Kay. 2. Kathleen M. Knisely (herein "%ay"), the alleged incapacitated person, resides at 23 West Lawn Circle, Wormlesyburg, Cumberland County, Pennsylvania 17043 and is currently at a Marriott Courtyard Hotel being held under questionable circumstances by her son, namely Samuel Scott Knisely (herein "Scott"). 3. Kay is seventy nine (79) years old and was born on February 11, 1933. 4. It is believed that Kay is incapacitated as a result of the extensive onset of dementia and episodes of significant confusion. 5. Kay was evaluated at Watkin, Nipple Associates by Dr. Walter Watkin, Jr., M.D. as evidenced by the Medical Summary set forth as Exhibit "A" (herein the "Medical ReporP') which provides in relevant part that Kay is suffering from the onset of dementia (Petitioner intends to provide a full Medical Evaluation prior to the plenary hearing). 6. Scott was a licensed physician whose license was revoked as further reflected in the attached document set forth as Exhibit "B" for amongst other reasons submitting fraudulent documents before the North Carolina Medical Board. 7. Scott currently resides at 370 Hughes Center Drive in Las Vegas, Nevada. 8. It is believed that Scott also suffers from certain mental infirmities and is now preying upon Kay and her impuissance. 9. It is believed that on or about Monday, August 27, 2012, Scott arrived in Harrisburg from Las Vegas, Nevada and visited Kay unannounced and unbeknownst to Kay's other children (as hereinafter defined). 10. On Tuesday, August 28, 2012, Scott involuntarily removed Kay from her primary residence to a Marriot Hotel on Old Gettysburg Road in Mechanicsburg. 11. Prior to Scott removing Kay from the house, Kay called her sister, namely Mary Lawrence of Old Tappan, New Jersey (on or about the same day) and expressed her concern about being relocated by Scott. 12. Upon being confronted by your Petitioner herewith to return Kay to her house, Scott relocated Kay to another Marriot Courtyard Hotel situated on Eisenhower Boulevard, in Swatara Township under a fictitious name. 13. Contemporaneous with the relocation of Kay, Scott has been advancing certain documents in an effort to transfer a substantial portion of her assets estimated in 2 access of several million dollars from Janney Montgomery Scott to Morgan Stanley Smith Barney as further reflected in the attached Exhibit ""C". 14. In past, Kay granted Scott the power to act as her agent pursuant to a certain Power of Attorney of which said power was revoked after it is believed Scott commingled Kay's assets with that of his own. 15. Petitioner believes and therefore alleges that Scott has returned from Las Vegas to transfer Kay's assets to himself thereby preying upon Kay's weakened intellect. 16. Petitioner believes and therefore avers that Kay's lucidity maybe compromised and that she does not have the requisite capacity to thwart Scott's attempts of self dealing. 17. Kay now requires in home care and a guardian. 18. The names and addresses of the those persons other than the Petitioner herewith who .would be potential intestate heirs of Kay are her four (4) other children, namely: a. Scott Knisely - 370 Hughes Center Drive, Las Vegas, Nevada 27235; b. LeeAnn Knisely-Cast - 485 Front Street, Louisville, Colorado 80027; c. Dr. Barbara Knisely- 3501 Sunset Drive, Madison, Wisconsin 53705; and d. Kathleen L. Knisely - 9008 Avis Court, Vienna, Virginia 22132. 19. Petitioner has no interests which are adverse to Kay's interests and as of the date hereof, the remaining aforementioned children. are not able to serve as guardian. 3 20. 21. 22. 23 Petitioner believes this matter is ripe for this Honorable Court to intervene as Kay is unable to make decisions for herself. Petitioner avers that Kay does not currently have a plenary guardian of her person and estate. Petitioner respectfully requests that an emergency hearing beheld -and that Petitioner be granted emergency powers to act for Kay in all matters of her person and estate until a full and plenary hearing can be established. Petitioner will comply with filing a full Plenary Guardianship of the person and estate consistent with 20 PA C.S.A 5511 within thirty (30) days of the emergency order and therefore requests that this Honorable Court grant the emergency guazdianship for such period until a full hearing for permanent guazdianship can be heard. Date: 3J ~~ Respectfully submitted, JAMES, SMITH, DIETTERICK & (C.ONI~LLY, LLP By. ~; - Neil W. S hn, Esquire A~.torney I. . No. 82278 1 ~4 Sipe enue H own, PA 17036 (717) 533-3280 Attorneys for Petitioner 4 Neil Warner Yahn, Esquire Attorney I.D. No. 82278 James Smith Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 Attorneys for Petitioner IN RE: KATHLEEN M. KNISELY , an Alleged Incapacitated Person ON THE PETITION OF JAMES G: KNISELY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA } ORPHANS' COURT DIVISION No. OC 2012 VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. §4904, relating to unsworn falsification to authorities. Dated: ~ ~~ 1 ~ _ Jam s G. Knisely Neil Warner Yahn, Esquire Attorney I.D. No. 82278 James Smith Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 Attorneys for Petitioner IN RE: KATHLEEN M. KNISELY , an Alleged Incapacitated Person ON THE PETITION OF JAMES G. KNISELY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISTON No. OC 2012 CON5ENT TO APPOINTMENT AS GUARDIAN 1. The name of the proposed guardian is James G. Knisely. 2. The proposed guardian resides at 3822 Pamay Drive, Mechanicsburg Pennsylvania 17050. 3. The proposed guardian is employed as a landscaper. 4. The proposed guardian speaks, reads and writes the English language. 5. The proposed guardian does not have an interest adverse to the alleged incapacitated person. 6. The proposed guardian is not a fiduciary, or an officer or employee of a corporate fiduciary, of an estate in which the alleged incapacitated person has an interest; and is not the surety, or an officer or employee of a corporate surety of such fiduciary. 7. The proposed guardian consents to act as guardian for Kathleen M. Knisely. Dated: ~ ~ ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS. On this, theday of , 2012, before me, the undersigned officer, personally appeared JAMES G. KNISELY, Petitioner, who, being duly sworn according to law, does depose and say that the facts set forth in the foregoing Petition are true and correct to the best of his knowledge, information and belief. IN WITNESS WHEREOF, I hereunder set y hand and official seal. J s G. Knisely SWORN to and subscribed before me this day of ~, 2012. N Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal JuUe K. Stambaugh, Notary Public Oerry 7wp., Dauphin CauMy My Cortwnl9slon June 27, 2015 verarsnv~xt~ assoa~norr of Norms EXHIBIT A P I ~ tiAC L E ~-~ !:_:~ i.~T~ I~1 ~ncount.er. .1ix1 27 2012 10:30AM Watkin, Nipple Associates Medical Summary No Reason for Referral was iven. 1 mo f u t needs med consul aer HMG Acrnm Hied b :The anent comes in toda with her dau hter. No HPI available. .. - • Generalized Anxiety Disorder Last Assessed: 07/27/2012 11:37:29 AM (300.02); (Active) Dementia Last Assessed: 07/27/2012 11:37:40 AM (294.8); (Active) • Hyperlipidemia (272.4); (Active) • Anemia (285.9); (Active) • Joint Pain Fingers (719.44); (Active) • Hearing Loss (389.9); (Active) • Intercostal Myositis p29.1); (Active) • Lymphadenopathy (785.6); (Active) • Insomnia (780.52); (Active) • Fatigue (780.79); (Active) Recent Weight Loss (_ Lbs) (783.21); (Active) • Osteoporosis (733.00); (Active) • Blood Chemistry Screening Tests As Part Of Pre-Operative Exam (V72.63); (Active) Lump Or Mass In BreastRight; (611.72); (Active) • Normal Routine History And Physical Senior Citizen (65-80) (V70.0); (Active) • Osteoarthritis (715.90); (Active) • Lum In On The Skin 782.2 • Active - . .~ . + Refresh Dry Eye Therapy 1-1 % Ophthalmic Solution; Instill 1 drop in each eye 4 times daily; Start Date: 05/02/2011 (Active} • Aspirin 81 MG Oral Tablet; TAKE 1 TABLET DAILY.; Start Date: 05/02/2011 (Active) • Alendronate Sodium 70 MG Oral Tablet; TAKE 1 TABLET ONCE WEEKLY; Start Date: 01/03/2012; End Date: 01/01/1900 (Active) • Namenda Titration Pak 5 (28)-10 (Zl) MG Oral Tablet; TAKE AS DIRECTED..; .Start Date: 07/05/2012 (Active) • Sertraline HCI 50 MG Oral Tablet; TAKE 1/2 TABLET DAILY.; Start Date: 06/01/2012; End Date: 01/01/1900 (Active) + Namenda 10 MG Oral Tablet; TAKE 1 TABLET TWICE DAILY FOR MEMORY.; Start Date: 07/27/2012; End Date: 0101 1900 Active -- ~~~ • Sulfites (Active) • Grass (Active) 1 of 3 7/27/12 11:43:31 AM ~} Pl ~ NBC LE f-~ L:-~ LT ~~-I ~, ; Encounter: Ju6 27 ?01.2 10:30AM • Other (Active) • Nuts Active -. • History of Destruction Of Flat Warts By Cryosurgery Comments: 07/26/2006 (Resolved) • History of Removal Of Lesion Comments: 06/05/2002-left elbow, left hand by cryosurgery (Resolved) • History of Spinal Anesthesia Epidural Lumbar, Single Comments: 06/18/2004 (Resolved) • History of Diarrhea (Symptom) (787.91); (Resolved) • History of Otitis Media (382.9); (Resolved) • History of Otitis Media In Both Ears (382.9); (Resolved) • History of Hypotension (458.9); (Resolved) • History of Chest Pain (786.50);-(Resolved) • History of Allergies (V15.09); (Resolved) • History of Cough (786.2); (Resolved) • History of Rhinitis (472..0); (Resolved) • History of Upper Respiratory Infection (465.9); (Resolved) • History of Abrasion Of Fingers (915.0); (Resolved) • History of Abdominal Pain (789.00); (Resolved) • History of Nausea (Symptom) (787.02); (Resolved) • History of Urinary Tract Infection (V13.02); (Resolved) • History of Measles (Rubeola) (055.9); (Resolved) • History of Varicella (052.9); (Resolved) • History of Pertussis (033.9); (Resolved) • History of Pneumonia (V12.61); (Resolved) • History of Arthritis (V13.4); (Resolved) • Histo of Hemorrhoids 455.6 • Resolved Procedure Procedure Date Date CompFeted - ~ _ ~~ . • ~ Status ..1. ., Resolved Cesarean SecCDn ,' ,`" w "' ,Resolved`_ Tonsillectamv' .,1 .._....F~~cW~.~ i.£1:~*~ ?.~~~ ... ~;i ,.,~,..:,~_;::.~,~.. ~ ~ . .4.., _ -- • Influenza -Administered on: 09/24/2010 • Pneumo (Pneumovax) -Administered on: 02/05/2002 • Influenza Lot #: UH486AE -Administered on: i2 29 2011 • Paternal history of Father Deceased At Age Comments: 45 (Active) • Patemal history of Coronary Artery Thrombosis (Active) • Family history of Family Health .Status Sister 1 Comments: skin cancer, ear infections (Active) • Maternal history of Ischemic Stroke (V17.1); (Active) • Matemal history of Heart Disease (V17.49); (Active) • Patemal history of Heart Disease (V17.49); (Active) • FamA histo of Famii Health Status S ouse Comments: deceased -heart disease Active F. • Marital History -Widowed (Active) • Sexual Orientation Heterosexual (Active) • Occupation: Retired (Active) • Living Independently Alone (Active) • Alcohol Use Comments: social (Active) • No History of Drug Use (Denied) • Former Smoker Comments: smoked in colle a V15.82 Active Date Description Test Result 2 of 3 7127/12 l 1:43:31 AIv1 `,'it,._ _. E ' Encounter: Jul ?7 2012 ]0:30AM 27 Jul 2012 10:41.AM recorded by: Rebuck, Ann Wel9h1 122,25 ib Body Mass Index Caiculated 20:12 Body Surface Area Calculated 1.61 Heart Rate 80 /min BP Systolic 138 mm[Hg]' BP Diastolic 7D mm[~9 • Follow-up visit in 1 month 07/Z7/2012 Routine • Tobacco Assessment Follow Up 07/27/2012 2 years • Mammogram Screening Bilateral 07/27/2012 1 year - . ~. _ ~ ~~. - s,,.. f° een Knish _ , ~,~ - ~ ~~ P-ersonal: ~ Kathl, ° ~ ly .: °Worrnleysburg, PA 17043-1142 k : ~.~; d t .- (717)~6~683~(Home phone) " SIIMM'I41RiZA~QN .UFI~PISODE 7+lOTE''~ "- Encounter au1 ;zr, Line lu::~u+uuuu Y~ rp 65 ~ .Site W~atK-n!~`N' le}Assaciates From Ente rise EHR 11.200 X288 ~Om , _. , N.rPP Sir'Thomas.Court Har~sburgj~PA 17109 .~ _ 6791 (1Na~k~phone) (~ F 38 }?° Gr;rated `July 27,..201~Z l.l,:a3-04D0 By Walter Watkin Jr 3 of 3 7127/12 11:43:3 ]. AM EXHIBIT B BEFORE' THE ' , NORTH CAROLINA MEDICAL BOARD In re: } Samuel Scott Knisely, M.D., } NOTICE OF CHARGES AND ALLEGATIONS Respondent. ) The North Carolina Medical Board (hereafter Board) has preferred and does hereUy prefer the following charges and allegations: 1. The Board is a body duly organized under the laws of North Carolina and is the proper party to bring this proceeding under the authority granted it in Axticle 1 of Chapter 90 of the North Carolina General Statutes. 2. Samuel Scott Knisely, M.D., (hereafter Dr. Knisely) is a physician licensed by the Board on July 31, 3993, license number 93-00190. 3. During the times relevant herein, Dr. Knisely practiced neurology in the Greensboro, North Carolina, area. FIRST CHARGE FAILURE TO COMPLY WITH A BOARD ORDER 4. Paragraphs one through three are re-alleged and incorporated herein. 5. On February 9, 2001, the Board issued to Dr. Knisely an Order for Examination (hereafter Order), a copy of which is attached hereto. 6. Dr. Knisely received tl~ie OrEler in June 2001. , 7. As of the date hereof, Dr. Knisely has failed to comply with the Order. B. The foregoing action constitutes the failure to respond, within a reasonable period of time and in a reasonable manner as determined by the Board, to inquiries from the Board concerning any matter affecting the license to practice medicine within the meaning of N.C. Gea. Sta t. ~ 90-14{a)(14), and grounds exist under that section of the North Carolina General Statutes for the Board to aan.ul, suspead, revoke, or limit Dr. Knisely's license to practice medicine and surgery issued by the Board. SECOND CHARGE CONDUCT CONTRARY TO HONESTY, JUSTICE, OR GOOD MORALS 9. Paragraphs one through three are re-alleged and incorporated herein. 10. On September 10, 2001, Dr, Knisely, through his attorney, faxed a hand-written note to the Board, a copy of which is attached. The note reads: "Dr. Sam Rnisely is a patient here. Unit number 39195234." The note is written on the letterhead of Jerrold F. Rosenbaum, M.D., Interim Chief of •Psychiatry, Massachusetts General Hospital and Professor df Psychiatry, Harvard Medical School (hereafter Dr. Rosenbaum). 11. Upon information and belief, Dr. Knisely has never been one of Dr. Rosenbaum's patients and has never, during the times relevant herein, bean admitted to Massachusetts General Hospital. 12. Upon information and belief, Dr. Knisely, or someone on his behalf, surreptitiously obtained Dr. Rosenbaum's letterhead, hand-wrote the note described above, and caused this note to be sent to the Board in an attempt to mislead the Board regarding his compliance with the Order for Examination. 13. The foregoing action constitutes unprofessional conduct, including, but not limited to, the committing of any act contrary to honesty, justice, or good morals within the meaning of N.C. Gen. Stat. § 94-14(a)(6), and grounds exist under that section of the North Carolina General Statutes for the Soard to annul, suspend, revoke, or limit Dr. Knisely's license to practice medicine and surgery issued by the Board. NOTICE TO DR. KNISELY • You may, if you desire, file written answers to the charges and allegations preferred against you within 34 days after the service of this notice. 3 • 'You will be given an opportunity to be heard concerning the above charges and allegations at a place and time to be hereafter designated by the Board, at which place and time you may appear, either personally or through counsel, and may cross-examine witnesses and present evidence in your own behalf , This the ~~ day of October, 2001. NORTH CAROL INA MED I CAI. BOARD ~.-..~ By : .`, Eli eth P. Ranof, M.D. President ATTEST: Andrew Watry Executive Director 4 . ~ BEFORE THE. NORTH CAROLINA MEDICAL BOARD ' In re: ) . . Respondent. ) This matter is before the North Carolina Medical Board (hereinafter Board), upon its own motion, regarding Samuel Scott Knisely, M.D., (hereinafter Dr. Knisely}. N.C. Gen. Stat. § 90-14(a)(5) empowers the Board, "to require a physician licensed by it to submit to a mental or physical examination by physicians designated by the Board ." Finding grounds exist to order such an examination concerning Dr. Knisely, the Board ORDERS, pnrsnant to this authority, that within thirty days of service of this order, Dr. Knisely shall submit to a complete physical and psychiatric assessment at one o£ the following locations: Elmhurst Memorial Healthcare Professionals at Risk Program, Elmhurst, Illinois (630-758-5110}; PaJ.metto Addiction Recovery Center, Rayville, Louisiana (800-203-6612); Professional Renewal Center, Lawrence, Kansas (877-978-4772); or Rush Behavioral Health - DuPage Multidisciplinary Assessment Program, Downers Grove, Illinois (.630-969-7300}. Dr. Knisely shall cooperate fully with this assessment. Dr. Knisely shall authorize those conducting the assessment to send the Board ,reports of this evaluation to: the following address: Director of Investigations, North Carolina Medical Board, PO Box 20007, Raleigh, NC 27619. This the ~:] day of February, 2001. NORTH CAROLINA MEDICAL BOARD ...~ ~. By: E1iz ~eth P. Kanof, M.D. President ATTEST: Andrew Watry Executive Director (Order for Examination - Samuel Scott Knisely, M.D.y NLAS:'~A,C~USETTS G,EN~RAL HOSS'XT~- 15 Y3rlcmut Stmt, l4AC R12 [ip~tori. VtassMt+uprtta 03114.3117 Tn1: (,17.72Gai82, Fax: b17.i26.2bdt! t• mall: IiOSarbatun-yp.~ K, .era.nvS ~ ~ . SA -~ ~ P~~~ ~~~ . k'IARV ARD ~. = ~ Mg~~CAL SC~'lCaOL .~%.'a ~~;~ K~ ; s e ~- r i s jetrold F. Rvseribxum, bi.L`. ('hNf of Pay~'tt~rrv ((ltftfgRr JNni~77f~rYSC!!< %rnrrr.: Flx;it1~ f+rytjo;,ty qF P.+y~hmrrt/ Aarard J~lea'i:al $,rvo! ..~.. i04~ ' ~' ~ HRH 4Tt'L 9ZL LS S~. It ~ ~ Tu -l: f{t -.. ~Ltil. 9~1. LZ9 BEFORE THE NORTH CAROLINA MEDICAL BOARD In re: ) FINDINGS OF FACT, CONCLUSIONS Samuel Scott Rnisely, M.D., ) OF LAW, AND ORDER OF DISCIPLINE Respondent. ) This matter was heard by the North Carolina Medical Board (hereafter, "BoardA) on August 21, 2003. Marcus Jamison represented the Board, and Edwar3 E. Hollowell and Donna Turner Eyster represented Respondent, Samuel Scott Rnisely, M.D. Based upon the evidence presented and the arguments of counsel, the Hoard enters the following: FINDINGS OF FACT 1. The Board is a body duly organized under the laws of North Carolis~.a and is the proper party to bring this proceeding under the authority granted it in Article 1 of Chapter 90 of the North Carolina General Statutes. 2. Samuel Scott Rnisely, I.D., {hereafter, °Dr. Rriisely") is a physician licensed by the Board oa July 31, 1993, license number 93-00190. 3. During the times relevant herein, Dr. Knisely practiced neurology in the Greensboro, North Carolina, area. 4. On February 9, 2001, the Board issued to Dr. Kaisely an Order for Examination (hereafter, "Order"} The Order required that Dr. Knisely submit himself to a complete physical and psychiatric assessment at one of four specified health care facilities. 5. Dr. Knisely received actual notice of the Order on or about June 2001 and hired an attorney to represent him in regard to the Board's Order. 6. Dr. Knisely failed to comply with the Order, and admitted at the hearing, that he never received an assessment from one of the four designated health care facilities listed in the Board's Order. 7. In or about September 2001, Dr. Knisely traveled to Boston, Massachusetts. There he attempted to obtain an evaluation to submit to the Board, ostensibly to demonstrate an effort to comply with the Board's Order. 8. On September 10, 2001. Dr. Kaisely faxed to his attorney, and his attorney faxed to this Board, a hand-written note. The note reads: "Dr. Sam Rnisely is a patient here. IInit number 39195234." The note is written on the letterhead of Jerrold F. Rosenbaum, M.D., Interim Chief of Psychiatry, 2 Massachusetts General Hospital and Prafessar of Psychiatry, Harvard Medical School (hereafter, "Dr. Rosenbaum°}. 9. At the hearing on this matter, Dr. Knisely admitted that the handwriting that appears on Dr. Rosenbaum's letterhead is his owa. Dr. Knisely also admitted at hearing that he was never a patient of Dr. Rosenbaum's. Dr. Knisely did cot have permission or authorization from Dr. Rosenbaum to use his letterhead. 10. By surreptitiously obtaining a copy of Dr. Rosenbaum's letterhead and by authoring a not a giving an impression that he was one of Dr. Rosenbaum's patients, Dr. Kniaely attempted to mislead the Hoard that he was being evaluated by Dr. Rosenbaum £ar purposes of complying with the Board's Order. Based upon the foregoiag Findings of Fact, the Baard enters the Following: CONCLUSIONS OF LAW 1. The Baard has jurisdic tiara over Dr. Knisely and the subject matter. 2. By nat submitting himself tv a complete physical and psychiatric assessment at one of the four designated health care facilities pursuant to the Board's Order for Examination, Dr. 3 ~Knisely failed to respond, within a reasonable period of'time'and in a reasonable manner as determined by the Board, to inquiries from the Board concerning any matter affecting the license to practice medicine within the meaning of N.C. Gen. Stet. § 9fl- 14(a}(14), and grounds exist under that section of the North Carolina General Statutes for the Board to annul, suspend, revoke, or limit Dr. Knisely's license to practice medicine and surgery issued by the Board. 3. By writing a note on Dr_ Rasenbaum's letterhead, without Dr. Rosenbaum's permission, so as to create an impression that he was Dr. Rosenbaum~s patient, when in fact he was not, and by submitting that note to his attorney, who then conveyed it to the Board, Dr. Kaisely attempted to mislead this Board that he was attempting to comply with this Board's Order for Examination, and such conduct constitutes unprofessional conduct, including, but not limited to, the coaanittin+g of any act contrary to honesty, justice, yr good morals within the meaning of N.C. Gen. Stet. ~ 90-14(a)(6), and grounds exist under that section of the North Carolina General Statutes far the Board to annul, suspend, 4 revoke, or limit Dr. Knisel 's license to Y practice medicine and surgery issued by the Beard. ORDER 1. The North Carolina medical license of Samuel Scott Knisaly, M.D. be and hereby is REVOKED. Thi s the ~ 3 .'. day o f C~'ti 2 0 4 3. IJORTH CAROL INl~ MEDICAL BOARD $y ~ ~ _ _ ~- Charles.L. Garrett, Jr., M.D. President 5 BEFORE ~ T8E NORTH CAROLINA MEDICAL BOARD ~ ' In re: } ORDER OF SUMMARY Samuel Scott Knisely, M.D., } SUSPENSION OF LICENSE ) Respondent. ) This matter is before the North Carolina Medical Board (hereafter Board) upon information that Samuel Scott Knisely, M.D. (hereafter Dr. Knisely), has failed to respond, within a reasonable period of time and in a reasonable manner as determined by the Board, to inquiries frost the Board concerning any matter affecting the license to practice medicine within the meaning of N.C. Gen. StRt. § 90-14(a)(14) and has engaged in unprofessional conduct, including, but not limited to, the committing of any act contrary to honesty, justice, or good morals within the meaning of N.C. Gen. Stet. § 90-14(x)(6). The Board finds that the public health, safety or welfare requires emergency action. The Board therefore ORDERS, pursuant to N.C. Gen. Stet. § 150E-3(c), that Dr. Kmisely's license to practice be SUSPENDED effective on service of the certified copy of this Order to him personally or at his last known address. This the ~_ day of October, 2001. NORTH CAROLINA MEDICAL BOARD By: Elizabeth P. Ranof, MD rest en ~1TTE~T r Andrew Watry Executive Director Page two of two - Order of Summary Suspension of License regarding Samuel Scott Knisely, M.D. ~le~s~ 5e~d r~ !/ ~~~our~ Y l~J~~I~-vUl~"~~1~ ~ ~-o ttie F°Il~"~~~G FP ~ N~`'M h~ ~ I~H~tilee ~ w~. 1~~~5P ~r ~'~~ }~ vt. ~' ~ ~ r Z ° J oZ Neil Warner Yahn, Esquire Attorney I.D. No. 82278 James Smith Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 Attorneys for Petitioner IN RE: KATHLEEN M. KNISELY , an Alleged Incapacitated Person ON THE PETITION OF JAMES G KNISELY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION No. OC 2012 CERTIFICATE OF SERVICE I, NEIL WARNER YARN, Esquire, do hereby certify that I served a true and correct copy of the foregoing EMERGENCY PETITION TO ADJUDICATE INCAPACITATED AND APPOINT TEMPORARY GUARDIAN OF THE PERSON AND ESTATE upon the following below-named individua b ~ .S. Mail, first class postage prepaid, at Hershey, Pennsylvania this 3~ day of , 2012. SERVED UPON: Scott Knisely 370 Hughes Center Drive Las Vegas, Nevada 27235 LeeAnn Knisely-Cast 485 Front Street Louisville, .Colorado 80027 Dr. Barbara Knisely 3501 Sunset Drive Madison, Wisconsin 53705 Kathleen L. Knisely 9008 Avis Court Vienna, Virginia 22132 NEIL`WA NER YARN, ESQUIRE Att rn .D. #82278 Sep. Zl. ZU~1 Z: ?3rM JOHNSHOPKINS ,,~o~~.. Johns Hopkins ~ayvicw Mcdical No. I SOU r. Z ,. G7iiric Nate Manor: KNseh-, KmMsen History: t7008~2 Address: 8Y7 Creek Tral Vlslt tats: Otll90/2012 > NC 27377 r Prwrw: (336j'2b i-1038 LocattOn: $E/1Gi 008: OTI11h833 Rac®: YVhim Gender: Female Prlrnpry P/oYldar: Oh.Eatt~sr Other Provider: Document Na 27380900090 lteasen fiw Visit: Evalus0on for cogrdlive pr+obiarns History of Praasnt Ignesa: The patient m a 7lt+~ysar~old wenran who ores by her son, tiAr. Samuel KNsey wha is a neurologist. She is hero for evaluaiNoti of hor memory pro for the pact ybar. Aocordmo b Tarr son, Mr. Knisely, hts mother hoe been having ~lq-itus~tarra andappear9 b be hequently oorifuaed. ~Heiteted that In September 20tt, acre was hsring dk~iurbsnoo Borne deNaslona. He alto radioed iigesaed Y and absentm~dr-ess as was. He noted tfist the pagerrt had CT scan In 201 t, but that R did not show ar>1rih6~g slgnlfhslnt. In terms of Tirncsort, the soh staled bst orre of brothers who Mres Herr the pe~ieM.in Fennsylvanla probably knows of bar fis>c0are1 ~neel.belter.. The{ralier~. currarrly resi~ng >n P/1. but tevently IlMad..wkh her daughter in Wisconsin. He staiect that there wars sonic issues among the dWdnsn, but ~d not wish to 81aDorate. The patbnt also acluwwletigec 1hat.she has bean he~tg m®dicatron Namenda t0 rag which she takes twice de9y ~ Is very good and is siaepirrg very well. She has not had a modaYges such e= MRI. The son also wardored wheU~er PET scan at (his tune. Aq other ROS negative. Medications: Namenda -10 mg twice daNy. Atlerpkts: No known drug aNergias. Past tuledical HlstorY as above Pest Surglcal,HlstOry: Cataract surgery. Femlly Hlslory: tVo ttlsbry ofidert~tge. Soaal History: She Is widowed, tree 5 c~fUdren. She lifeguard and at en olkc:e. Major Findings; KnlsetY, Kslhksn ln~ all'+ii~lED EXHIIBIT "B" orris mdrwry problems, but she thought that the rotor sadness ordepression. She rtobd Prat bar appetite V woAarp In terns of bkrod test or a0fer knaging 1e should have an in depth neuopsychokxJkal testing or ~ b soAtionwne year In cottage. She worked as a PrM1~d: oel21/s0u Pagc I of 2 Sep. Z!. ZUIL !: I~rM •~ Physical txarrK Terriperaia~e 97.6, blood prbpurs 14QII rata 16. Ganerak Not in earls dslroas. Apprvpriaae dne motions Intact. Pupils eQuel. towel. and readMe b tilt rhythm. Clear b a<readteson braletfely. Abibrm pelpeaon. Lower Exbetrritiss: No edema. Cranial never maneuvaFantad. Vlsegl iltekb InLad. petxaased senss6 her hearirp alds at home). Sbseglh 5~ upper 8rrd lower plnP-Ic1c and sett loud,- NepatNe Romberg. t~roprboepll Mini-Mental State Exam 25130. m~ged tan orbnfation to 7'.1 from language. Recai was trltld. There were na ~ Assessments; ~ pio.lUtiU r. 3 ~~ . a. pulse 67, weight wa's 125 pounds. pubs 87, respirAb-Y sad for tfie weaUwr. Speech fluent. ItEEM': Extraocular ~ndbc ExarrK S7. S2. too 33. S4. Raguter rate and t: FIeL Bowri sowrds irlact. Saq, aonpsnder upon II-XXIt trgact. No iironte~i release aipna Fingerr to-nose n b larger rubs b~iersKl-. (The pef[ent stabd 0tat she left r4rbrtibss 6ialeral and pY t is intact to n b intact NapsilWS Babirrsi3. (dad Intact. ime, nriued 3 on orbntatbn to place. missed 1 hom serial t or Mnsping studies aveaade to me. t..opnitive disorder NO3. At Ills time. firs etiobgy o(her which is in the tower arrdE of eonttal rs,-rge for het ape and problem b wrcbar. Sire scored 21,130 pe MMSE, Due b Uds borderline adore t would recommend a more neuropeydlgiogic~ C9C, CMP. TSN. vitarriirr 8t2, and fobls. THs was a , yrq~ also reoatrrtrend ~ taARl and bb ~ such as t+rlef vlatt as the patlsnt vr• not ba able b oonth t receive care hers due to brsrrrarrce masons and vrpl most ins~tutan near her home wllhhr her Medica-o Adv ua o ikeiy need b Weals a tonnal evaluation at another The son sfaled that he wle look ~ a ply~n ~ PA. Problems/blapnoses: as above Procedures and Irranunixalions: none Plans: es above Madicstion Changes: none pictsted By: OH, E3THER, M.D. JMEDQ p,0121H 0.5:42:27 SIGNED BY: t7Fl, ESTI{ER THIS dOCUMENT F1At3 SEEM ELECTRONICALLY DATE AND 71ME SIQNIEO: 09H2201211~8 AM Notc Tais ads rote porw,s uilo„nri.,, amp airp to N. ~ti Icnr•.iy. wthiMn tt~oosatt MaM~sir. R mw awflp ineeiat IWlorri. fn the Me~tai Prrnr.e: osn+no~2 Page 2 of 2