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HomeMy WebLinkAbout02-01-13IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA r= , ~ © ~ - `~' `~ Orphans' Court Divisic~iY ~ ~ ~ ~ No. 21-12-1300 ter' ~ --~ x c `;:Y~.t 1~~- RENA G. BURK Honorable Thomas A. a~y~ ~ ~.~~ ~ °~ ~ MOTION FOR EXPEDITED HEARING . °-~ ~, ~, ~~~ ~~., AND NOW COME, Movants, Barbara B. Schorr and Kathy L. Hughes, by and through their undersigned counsel, moving this Court for an expedited hearing based on the following: 1. Movants filed a Petition for Determination of Incapacity and Appointment of Guardian for Rena G. Burk on or about December 3, 2012. 2. An Order of Court was docketed on or about December 28, 2012, setting a hearing for March 25, 2013, to determine whether Rena G. Burk should be adjudicated an incapacitated person and have a guardian appointed for her person and estate. 3. The Power of Attorney for Rena G. Burk at the time of the filing of this Petition for Determination of Incapacity and Appointment of Guardian was Ernest E. Bolton. 4. On January 22, 2013, Ernest E. Bolton passed away leaving no alternate or successor party to act as Power of Attorney for Rena G. Burk. 5. With Ernest E. Bolton expiring, Rena G. Burk has no party or individual to assist her in a legal capacity to make decisions and/or address financial issues until the hearing date on March 25, 2013. 6. Movants' request is in the alleged incapacitated person's best interests as it would provide a guardian for her without having to wait two (2) months. 7. Movants also request that the Executor/Executrix for Ernest E. Bolton's estate provide an accounting of Rena G. Burk's funds from the inception date of the Power of Attorney to the current date as they are aware of unpaid invoices despite their belief that sufficient funds exist to pay them. 8. Lisa M. Coyne, Esquire, has been appointed to represent the alleged incapacitated person in these proceedings and she has provided her oral consent to the requested relief. WHEREFORE, Movants respectfully request that an expedited hearing be scheduled in this proceeding and to compel an accounting of the alleged incapacitated person's estate. Respectfully submitted, LAW OFFICES OF CRAIG A. DIEHL Date: ,~ " By: ~ (~„ Craig A. iehl, Esquire Attorney I.D. No. 52801 3464 Trindle Road Camp Hill, PA 17011 Tel: (717) 763-7613 Fax: (717) 763-8293 Attorney for Movants CERTIFICATE OF SERVICE AND NOW, the 1St day of February, 2013, the undersigned hereby certifies that a true and correct copy of the foregoing Motion for Expedited Hearing was served upon the opposing parties by way of United States first class mail, postage prepaid, addressed as follows: Lisa M. Coyne, Esquire 3901 Market Street Camp Hill, PA 17011 Rena G. Burk Country Meadows -Room 224 4837 East Trindle Road Mechanicsburg, PA 17055 Estate of Ernest E. Bolton 40 North Enola Drive Enola, PA 17025 D bra A. Fike, Legal Secretary