HomeMy WebLinkAbout01-04-13
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
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ORPHAN'S COURT DIVISION
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IN RE: L. GALE HORSTICK NO:
An Incapacitated Person -3
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PLENARY GUARDIAN OF T14
ESTATE AND THE PERSON c , ~
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EMERGENCY PETITION FOR THE ADJUDICATION OF INCAPACITY AND
APPOINTMENT OF A GUARDIANSHIP OF AN INCAPACITATED PERSON
AND NOW COMES Petitioner, Judith Gale White, by and through her counsel, Kathy
M. Shughart, and respectfully requests that this Honorable Court declares L. Gale Horstick an
Incapacitated Person and appoint her as Plenary Guardian of the Estate and Person of L. Gale
Horstick for the following reasons:
1. The Incapacitated Person is L. Gale Horstick, an adult individual born March 1, 1925,
currently a patient at Holy Spirit Hospital, 4th Floor, 503 North 21st Street, Camp Hill,
Pennsylvania, and who resided at 1107 Apple Drive, Mechanicsburg, Pennsylvania until
December 15, 2012.
2. The Petitioner is Judith Gale White, an adult individual born March 28, 1966 and residing
at 1149 Thunderhill Road, Lincoln University, Pennsylvania.
3. The Incapacitated Person did not prepare an Advanced Directive for Health Care prior to
her incapacity.
4. The Incapacitated Person attempted and intended to execute a Durable Power of Attorney
prior to her incapacity as evidenced by the General Power of Attorney, a true and correct copy of
which is incorporated by reference herein and attached hereto as Exhibit "A".
5. On December 20, 2012, while a patient at Holy Spirit Hospital and in anticipation of her
possible imminent incapacitation, the Incapacitated Person executed the General Power of
Attorney attached hereto as Exhibit "A", which was notarized by the Hospital notary.
6. As a result of the lack of legal counsel at the time, the General Power of Attorney,
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attached hereto as Exhibit "A," is incomplete and defective in that it does not include the
required Notice signed by the maker of the power of attorney or the Acknowledgement of Agent
signed by the person appointed as agent.
7. On or about May 2012, the Incapacitated Person was diagnosed with vulvar cancer for
which she received surgery and radiation treatments.
8. On or about November 2012, the Incapacitated Person was diagnosed with metastatic
cancer involving tumors in her pelvis and chest.
9. On or about December 14, 2012, the Incapacitated Person received her first
chemotherapy treatment for the metastatic cancer.
10. On or about December 15, 2012, the Incapacitated Person became so weak from diarrhea
and extensive pain and weakness in her left leg that she was admitted to Holy Spirit Hospital for
treatment.
11. The Incapacitated Person's medical condition worsened with dehydration, slowed speech
and decreased urine output but she remained oriented as to person, place and events until
December 22, 2012.
12. On or about December 22, 2012, the Incapacitated Person became non-verbal and
increasingly non-responsive.
13. The Petitioner was advised that the medical condition of the Incapacitated Person is grave
and likely imminently fatal.
14. On or about December 30, 2012, the Incapacitated Person was moved to the inpatient
Hospice unit on the fourth floor of the Hospital for an initial period of five days.
15. It is unclear at this time whether the Incapacitated Person will remain in the Hospice unit
of the Hospital or whether she will be transferred to a Hospice facility.
16. Since December 22, 2012, the Incapacitated Person has been unable to communicate.
17. Since December 22, 2012, the Incapacitated Person has been unresponsive.
18. Since December 22, 2012, the Incapacitated Person has been unable to feed herself.
Unsuccessful attempts were made to insert a feeding tube, but she is now receiving only
intravenous fluids.
19. It is not anticipated that the medical condition of the Incapacitated Person will improve
and she will require long-term custodial, skilled nursing care at an appropriate facility.
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20. At this time, the Incapacitated Person is wholly unable to care for her physical or
financial needs.
21. As of this time, the Incapacitated Person's attending physician, Mujtaba Ali, M.D.
believes that her condition is unlikely to improve. A true and correct copy of the Deposition of
Individual Qualified to Render Opinion as to Incapacitation is incorporated by reference herein
and attached hereto as Exhibit "B".
22. As of this time, the Incapacitated Person requires 24 hour care and is totally unable to
manage her finances and totally unable to meet essential requirements for her physical health and
safety.
23. At this time, decisions regarding medical issues are being made by the Petitioner, who is
the niece of the Incapacitated Person, in accordance with the defective General Power of
Attorney, (Exhibit "A".)
24. The Incapacitated Person is unmarried and has no children.
25. The Incapacitated Person's next of kin and sole beneficiary in the event of her death is
her brother, Jack A. Horstick, born January 28, 1931, and residing at 513 Nimitz Road, Dover,
Delaware.
26. Jack A. Horstick does not desire to be appointed Guardian due to his age and residence
in Delaware, but prefers that the Petitioner, his daughter, be appointed Guardian.
27. Jack A. Horstick is aware of the filing of this Petition and has no objection to the relief
sought herein.
28. At this time, there is no person who is legally able to manage the Incapacitated Person's
financial, legal, medical and other affairs.
29. Due to the incapacity of L. Gale Horstick, decisions regarding the management of her
physical and financial affairs cannot be made in a timely fashion; accordingly the failure to
appoint an Emergency Guardian of the Estate and Person of the Incapacitated Person can result
in immediate irreparable harm to the Estate and Person of L. Gale Horstick since finances cannot
be properly managed, bills cannot be paid and income cannot be properly credited to her
account.
30. Because the Incapacitated Person is wholly unable to attend to her physical and financial
needs, and does not have in place a proper Durable Power of Attorney, there is no less restrictive
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alternative means to attend to the Incapacitated Person's physical and financial needs other than
a Plenary Guardianship of the Person and Estate.
31. The Petitioner, Judith Gale White, requests that this Honorable Court appoint her as
Plenary Guardian of the Person and Estate of L. Gale Horstick so that the appropriate healthcare
and financial decisions can be made on Ms. Horstick's behalf.
32. The Petitioner is the niece of the Incapacitated Person and has no interest adverse to the
Incapacitated Person.
33. The Petitioner has had a lifelong relationship with the Incapacitated Person and is
familiar with her physical and financial needs and desires.
34. The Petitioner is a licensed registered nurse in Delaware and is employed by Christiana
Care in Dover, Delaware in the Emergency/Trauma Department and is therefore familiar with
the medical issues which confront the Incapacitated Person.
35. The Petitioner has attempted to determine the size of the Incapacitated Person's estate but
has been unsuccessful since no one other than the Incapacitated Person is permitted to access her
financial records, reports or accounts.
36. The Incapacitated Person resides in a rental unit which must be either maintained or
terminated.
37. It is believed the Incapacitated Person receives income from social security and some
form of retirement or annuity.
38. Representatives of Wells Fargo, the institution at which the Incapacitated Person is
believed to have her accounts, will not reveal to any family member the balances in any accounts
held by Incapacitated Person.
39. The Petitioner is unable to ascertain the insurance benefits of the Incapacitated Person or
to communicate with any insurance company, Medicare or Medicaid.
40. The failure to be able to obtain substantive information about the state of the finances of
the Incapacitated Person's estate prevents the proper management of the Incapacitated Person's
financial affairs.
41. The failure to be able to obtain substantive information about the insurance benefits and
state of the finances of the Incapacitated Person's estate will adversely impact the proper
management of the Incapacitated Person's healthcare affairs in the event she must be transferred
from the Hospital to a Hospice or long-term care facility.
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42. It is necessary for Judith Gale White to receive Plenary Guardian of the Estate and Person
of L. Gale Horstick so that she can have the authority to take the necessary and appropriate steps
to protect the Estate and Person of L. Gale Horstick during her time of incapacity.
43. The Petitioner, Judith Gale White, consents to her appointment as Plenary Guardian of
the Estate and Person of L. Gale Horstick. A true and correct copy of her Written Consent is
incorporated herein and attached hereto as Exhibit "C".
44. Prior to, and in anticipation of her possible incapacity, the Incapacitated Person attempted
and intended to appoint the Petitioner, Judith Gale White, as her Power of Attorney, but said
execution was defective due to the lack of the required Notice page.
45. It is believed and therefore averred that the Incapacitated Person would agree with the
appointment of Judith Gale White as Plenary Guardian of the Estate and Person of L. Gale
Horstick.
46. Petitioner intends to file a Petition for Guardianship pursuant to 20 Pa.C.S.A. §5511
within five days.
WHEREFORE, it is respectfully requested that this Honorable Court appoint Judith Gale
White as Plenary Guardian of the Estate and Person of L. Gale Horstick.
Respectf lly submitted,
L~
M. Shu ha
Kathy g
Attorney for Plaintiff
P.O. Box 6315
27 South Arlene Street
Harrisburg, PA 17112-0315
(717) 540-8511
Supreme Court 439779
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VERIFICATION
I verify that the statements made in the attached Petition are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4904 relating to unsworn falsification to authorities.
0, ao'-V
J dith Gale White, Petitioner
CHR ER OBS CORE D Fax Dec 31 2012 07:21am P004/009
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GENERAL POWER OF ATTORNEY
KNOW ALL MEAT BY THESE PRESENTS, that I, e
of lAf-C k-&h f C S Y Pennsylvania, hereby revoke y g ial pow of attorney that
I have heretofore given to OR'Y person and do hereby appoint
(hereinafter "my Agent") my true and lawful :agent for me a-ad on my ehalf to perform all such
acts as my agent in my Agent's absolute discretion may deem advisa e, as fully as I could do if
personally present.
This Power of Attorney shall not be affected by my subs eque~ disability or incapacity.
My Agent is hereby given the fullest possible powers to a on my behalf: to transact
business, make execute and acknowledge all agreements, contra , s, orders, deeds, writings,
assurances and instruments for any matter, with the same powers I' d for all purposes with the
same validity as I could, if personally present.
Without limiting the general powers hereby already conferred, my Attorney shall have
the following specific powers which are included in the foregoing general powers:
1. Banking and Financial Iustitutions- General Financial Pbv~rs_
(a) To deposit any funds received for me in my ac looms in such bank or trust
company or other depository as my Attorney may select, either in y name or in my Attorney's
Ski ze..as attozx~ey- n.fact-
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(b) To withdraw from and to any check or other d agaixist any moneys held
for me at any bank, saving fund or other place of deposit, whetheriuuch account was created by
me or by my Attorney.
(c) To endorse notes, checks and other instr= is which may require my
endorsement.
(d) To pay all debts now or hereafter incurred by mel
(e) To borrow money and to mortgage or pledge property, real or personal, now
or bereafter owned by me as security therefore and to satisfy „~f record any indentures of
mortgage now or hereafter standing in my name or acquired for rnyl[ccount.
{ To have access to any safe deposit box star( in my name or in my
Attorney's name for me, and to add to or remove the contents of filch box; provided, however,
my Attorney shall not use such box as a place W which to keep !ny personal property of my
Attorney.
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(g) Generally, to transact any and all business f r me with any bank, trust
company or other depository. ii
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EXHIBIT A
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CHR ER OBS CORE D Fax Dec 31 2012 07:21am P005/008
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2. Stocks Bonds Securities and Investments.
(a) To sell, exchange, pledge, assign, transfer and cefiver to any person, at my
Attorney's discretion, all or any part of any stocks, bonds, no s, mortgages, interests in
partnerships or other securities, and any aind all personal property standing in my name or
belonging to me, or over which I may have any power'oz control. Tp make, execute and deliver
on my behalf all necessary deeds, assignments or transfers. i
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(b) To register any or all of my securities in airy Attbrney's name as attorney-in-
fact for me.
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(e) To vote my securities in person or by proxy.
(d) To transact all business in relation to any stockq,~, bonds, securities, or other
property in the nature thereof; to deposit the same under agreement of deposit; to participate in
any plan of lease, mortgage, merger, consolidation, exchange, reoanization,. recapitalization,
liquidation, receiver-ship, or foreclosure with respect. thereto; to exerIIcise any nights to subscribe
new issues thereof; and generally to exercise all rights of mananent and ownership with
respect thereto. III,
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(e) To invest in any form of property, all funds and s'' ties held or received for
my account, keeping such cash reserves as., in my Attorney's "seretion, are necessary or
desirable to meet. conditiops. as they, may exist from time to time. the exercise of this power,
my Attorney may invest in any variety of real and personal pt: perry- as. in my . Attorney's
discretion appears to be prudent investments, and my Attorney shah not be liable to me for any
error of judgment in the making or continuing of any investment. I .
3. Real Estate.
(a) To sell, exchange, pledge, assign,, transfer, and ideliver to any person, at my
Attorney's discretion, all or any part of my. real property, standing in my name or belonging to
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mc, oz over which I have any power or control.
(b) To make, execute and deliver on my behalf all necessary deeds, assignments
or transfers.
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(c) To operate zeal property, separately or jointly Zvi others-
(d) To lease for any terns any zeal property and to ~ the terms, including rent
payable, of any lease.
(e) To alter, repair, improve, mortgage, divide, exclaarige, join in the partition of,
or give options with respect to, zeal property.
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CHR ER OBS CORE D Fax Dec 31 2012 01:21am P006/008
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(f) To buy in at judicial sale any property on which 14od a mortgage.
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(g) Generally to transact all business and to exercis 1 all rights of management
and ownership relating to real property. ~i
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4. Claims Law Suits Compromise and Miscellaneous Power.
(a) To demand, sue for, levy, collect, and give pro ter receipts for all sums of
money or property now or which may hereafter become due me pm any source whatsoever,
including all estates or trusts, proceeds of insurance policies or~ther property of any kind
whatsoever. i
(b) To join with other parties in the compromise or se dement of any claims,
(c) To make, negotiate, sign and perform any and Al agreements and contracts
now in course of negotiation, execution and settlement by me, or ~ 1 hich may hereafter in the
opinion of my Attorney be to my interest or advantage; to effect, pr cure and continue insurance
of any and every kind and description; and with Ul power and authority to manage any real and
personal property and conduct my affairs generally.
(d) To employ attorneys at law and such 4er agents, employees or
reprpsentatives -as-my-,A.ttomey.:may thinly proper, and to pay any cl ims, fees, expenses, wages,
demands or obligations for which Z may now be or may hereafter-be ' bme Uable.,_
5. Tax Matters.
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(a) To prepare, execute and file on my behalf and in day name any and all income
tax declarations and returns, and any other tax returns and reports (ucluding, but not limited to,
protests, claims, elections,. consents, closing agreements, waivers 6f. statutes of.limitations and
extensions), and to represent me before the Internal Revenue Ser~lice'or Treasury Department
and any state or local taxing authority with respect to any claim or ceeding having to do with
my tax liabilities, federal, state or local., for any and all years-J,,ro
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6, Power to Delegate-
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To substitute one or more attorney or attorneys under my Attorney, to carry out
any of the general or specific powers hereby granted. ~j
7. Specific Authority to Purchase "Flower" Bonds.
To purchase United States Treasury "flower" bonds orz my behalf and to borrow
money as provided above for the purchase of such bonds.
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CHR ER OBS CORE D Fax Dec 31 2012 07:22am P007/008
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8. Specific Financial Powers Defined by Statute.
The following powers are granted pursuant to Chap {er 56 of the Pemsylvania
Probate Estates and Fiduciaries Code as further defined therein:
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(a) To make lin-Ated gifts: My Attorney may :makq!'gifts on my behalf to any
donees and in such amounts as my Attorney may decide subject to th(' following'
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(i) The class of permissible donees shall cons~st solely of my spouse, my
children, my grandchildren and my great-grandchildren (including tly Attorney if my Attorney
is a member of such class). j
(ii) During each calendar year, the gins to 9ach donee pursuant to this
power shall have an, aggregate value not in , excess of Ten Thous an%~ .Dollars or such lesser (or
greater) amount as, and shall be made in such manner as, to qual'fy in their entirety for my
annual exclusion from the Federal gift tax as provided in section 250 .(b) of the Internal Revenue
Code of 1986, as amended, without regard to section 2513(a) thereof', (vr any successor provision
allowing gifts to be split with a spouse).
(b) To create a trust for my benefit. I'
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(c) To make additions to an existing trust for my benefit.
(d . To claim.an el Qtjve..sbage of the estate of my dec, aced spouse.
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(e) To disclaim any interest in property. i
(f) To renounce fiduciary positions.
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(g) To withdraw and receive the income or corpus of4 trust.
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9. Specific Personal and Medical Powers Defined b Statute[;
If
The following general powers are granted purslill ~lnt to Chapter 56 of the
Pemisylvania Probate, Estates and Fiduciaries Code, as further defitAld therein:
Pin, residential or similar
(a) To authorize nay admission to a medical, nu
facility and to enter into agreements for ixiy care. Ij.
(b) To authorize medical and surgical procedures- i.
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This Power of Attorney shall not expire by reason of lapse oItime.
Z hereby ratify and confirm all that each Agent acting here>~nder shall do or cause to be
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CHR ER OBS CORE D Fax Dec 31 2012 07:22am P008/008
done under this General Power of ,Attorney. I specifically direct diet such Agent shall not be
subject to any liability by reason of any of such .Agent's decisions, acts or failures to act, all of
which shall be conclusive and binding upon me, my personal represitatives, heirs and assigns.
Furffiermore, except in the case of malfeasance of office, I agree to ~ndemnify such Agent, and
hold such Agent harmless, from all claims. that may be made against lsuch Agent as a result of
such Agent's service hereunder and I agree to reimburse such A t in the amount of any
damages, costs and expenses that may be incurred as a result of any 's 'ch claim.
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IN WITNESS WHEREOF, and intending to be legally boupd, I have hereunto set my
hand and seal this . day of UP C , 24J 2•
Signed, sealed and delivered in the presence of
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C4 (SEAL).
z~au~e)
Witness (type or F'It
COMMONWEALTH OF PENNSYLVANIA : i
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COUNTY OF PHILADELPHIA.
On this, the day of i 2012? before me, the
undersigned officer, personally appeared known to me or
satisfactorily proven, to be the person whose name is subscribed to ~ foregoing instrument, and
acknowledged that he executed the same for the purposes therreixa con jained.
IN WITNESS WHEREOF, I have set ivy hand and official s '-I.
*OTARK
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JAN/04/2013/FRI 09:21 AM FAX No. P. 001
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL'V'ANIA
ORPHAN'S COURT DI'V'ISION
IN RE: L. GALE HORSTICK NO:
An Incapacitated Person
PLENARY GUARDIANSHIP OF THE
ESTATE AND TIDE PERSON
DEPOSITION OF INDIVDUAL
QUALIFIED TO RENDER OPINION AS TO INCAPACITATION
This written deposition of a witness
in. this matter is taken on the 3"4d day of January, 2013, at Holy Spirit Hospital, 4"' Floor,
503 North 21" Street, Camp Hill, Pennsylvania-
1. Please state your name and your pfrroferslsi n 1 addres*/]sp:
s~ o~ls~ SF~ Camp 1 Kr11,0
2. Please describe your education, training and background with particulax emphasis on
your expertise in evaluation of individuals with incapacities OR attach your curriculum vitae to
this written deposition.
.L( C~.an. ctu b r.. ° cLtir2 b . Sarre ~F T ~u~~ r~:f
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3. In your professional capacity, have you had the opportunity to meet with, examine, speak
with or otherwise become acquainted with L. Gale Horstick?
ya -
EXHIBIT B
JAN/04/2013/FRI 09:21 AM FAX No. P. 002
If yes, please state the following:
1 first became acquainted with L. Crate Plorstick on when she was
brought to my attention by my becoming the patient's attending hospital physician. I have since
examined her on a daily basis.
4. Please evaluate the present condition of this patient with respect to ineapacities or the
type alleged in the Petition for Adjudication of Incapacity.
In particular, please comment on the nature and extent of the alleged ineapacities and disabilities
and also, insofar as you axe able, her mental, emoticanal and physical condition, adaptive behavior,
and social skills,
Based upon my education, training and experience, as well as my acquaintance with this patient, it
is my opinion, to a reasonable degree of medical certainty, that her ineapacities are as follows:
Mental condition: S Ojtaw U. 1k
Emotional condition:
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Physical condition,
'0 ~ 57`rx 7-~ ~Lct~ / Ste? ~ i_°l~ ~Q
Adaptive behavior:
Social Skills: Liu twb
2
JAM/04/2013/FRI 09;21 AM FAY No. F. 003
5. Based upon your education, training and experience, and your contacts with this patient,
do you have an opinion, to a reasonable degree of medical certainty, whether she is impaired in
her ability to effectively receive and evaluate information and to male and communicate decisions
in any way?
If yes, please explain your opinion./ I n 1
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6. If you are of the opinion that she is impaired in her ability to effectively receive and
evaluate information and make and communicate decisions in any way, does such impairinent
render her either partially or totally unable to manage her financial resources?
If yes, check whether such impairment renders her:
Partially unable to manage her own finances.
Totally unable to manage her own finances.
Please explain your opinion. / / /
Sites mUL[tC~~ ' Uu L~~t,'tUu ~✓8k,.N1~c/I 4 sTrn~,~ +c~L~,
(,f ~~t.~ ~ 'YV~t~e~ a.c~c. el~c.l~ . (ofc~ rn ~P~~t~~•
JAN/04/2013/FRI 09.21 AM FA'X No. P. 004
7. If you are of the opinion she is impaired in her ability to effectively receive and evaluate
information and snake and communicate decisions in any way, does such impairment render her
either partially or totally unable to meet the essential requirements for her physical health and
safety?
If yes, check whether such impairment renders her:
Partially unable to meet essential requirements for her physical health and safety.
Totally unable to meet essential requirements for her physical health and safety.
Please explain your opinion.
S~ e ri h 21i(. ~1 C(,Wd~t c T t`t~/~ l~l-L.~Lt1J Jam' °'~LU91J ~~GfLL(-U~3 V
8. Please provide an assessment of the severity of any impairment of this patient.
Impairment (Circle one)
a) P Mild Moderate ever
b) WtA.W eQ~ u Mild Moderate Severe
c) W eQh^'O_d Mild Moderate e er
d) Mild Moderate Severe
e) Mild Moderate Severe
4
JAN/04/2013/FRI 09;21 AM FAX No, P. 005
fl Mild Moderate Severe
g) Mild Moderate Severe
h) Mild Moderate Severe
9. Is the condition of this patient such that, because of her condition, she would be
susceptible to undue influence by unscrupulous or designing persons?
If so, what services or assistance would you recommend as necessary to appropriate management
of this patient's finances?
10. What services or assistance would you recommend as necessary to meeting the health
and safety needs of this patient? be- s,
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JAN/04/2013/FRI 09:21 AM FAX No. P. 006
11- Are the services or assistance recommended the least restrictive alternative?
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Does the patient need the services of the guardian to make decisions regarding the patient's
healthcare, safety and financial resources? In other words, could the patient evaluate,
communicate and make decisions regarding her healthcare, safety and financial resources in
important matters without the guardian?
L ~ fi , ` r~ ev e lQ c deIf^fe jjj Mt 0 6_k e.. M,6~,M .
If not, please explain why less restrictive alternatives are inappropriate.
12. Based upon your education, training, experience, and familiarity with this patient, what is
your opinion as to the likelihood that the degree of incapacitation will significantly change?
Trgf1aU2 JVLAAA C~+2dt ~,~o
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1AN/04/2013/FRI 09:21 AM FAX No. P. 007
13, Would the physical or mental condition of this patient be harmed by her presence in open
court? NOTE: Pennsylvania lacy, 20 Pa.C.S. §5511(a)(1), requires that the alleged incapacitated
person be present at the hearing unless a physician or licensed psychologist provides by
deposition, testimony or sworn statement, an opinion that her physical or mental condition would
be harmed by her presence in court. If yes, please explain.
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JAN/04/2013/FRI 09:21 AM FAX No, P. 008
VERIFICATION
T, vw'%I. ba _ ~z O 7YI f~_ verify that the statements made in the
foregoing deposition are true and correct to the best of my Imowledge, information and belie' I
understand that false statements herein are made subject to the penalties of 18 Pa_C.S, Section
4904 relating to uns'worn falsification to authorities,
Signature of Depone
Dated: 3 .
s
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHAN'S COURT DIVISION
IN RE: L. GALE HORSTICK NO:
An Incapacitated Person
PLENARY GUARDIANSHIP OF THE
ESTATE AND THE PERSON
WRITTEN CONSENT TO APPOINTMENT AS
PLENARY GUARDIAN OF THE ESTATE AND PERSON OF L. GALE HORSTICK
1. My name is Judith Gale White, born March 28, 1966, and I reside at 1149 Thunderhill
Road, Lincoln University, Pennsylvania.
2. I am employed as a registered nurse in the Emergency/Trauma department at Christiana
Care in Dover, Delaware.
3. I am able to speak, read and write the English language with proficiency.
4. I do not have any interest with is adverse to the Incapacitated Person.
5. I am not a fiduciary or officer or employee of a corporate fiduciary or an estate in which
the Incapacitated Person has an interest.
6. I am not a surety of an officer or employee of a corporate surety or fiduciary.
7. It is my desire to become the Plenary Guardian of the Estate and Person of L. Gale
Horstick.
EXHIBIT C
8. I hereby consent to my appointment as Plenary Guardian of the Estate and Person of L.
Gale Horstick.
Date: d ! ,t
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Ju 'th Gale White