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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL ,
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ORPHANS' COURT DIVISION G 6' ° -
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IN RE: ;,o r ro
TAMMY LYNN RANEY, No. a -13 -0a 13 C) w
an adjudicated incapacitated person
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PETITION FOR APPOINTMENT OF SUCCEEDING GUARDIANS W
PURSUANT TO 20 Pa.C.S.A. & 5514
AND NOW, come Petitioners, Melissa A. Dixon and Jason M. Dixon, by and through
their attorney, Bret P. Shaffer, Esq. of Baric Scherer LLC, and request that Melissa A. Dixon and
Jason M. Dixon be appointed limited Guardians of Tammy Lynn Raney, and, in support thereof,
set forth the following:
1. The first Petitioner is Melissa A. Dixon, an adult individual, who resides at 105
Park Place, Camp Hill, Cumberland County, Pennsylvania, and is the sister of Tammy Lynn
Raney.
2. The second Petitioner is Jason M. Dixon, an adult individual, who resides at 105
Park Place, Camp Hill, Cumberland County, Pennsylvania, and is the husband of Melissa A.
Dixon and the brother-in-law of Tammy Lynn Raney.
3. The Orphans' Court Division of the Court of Common Pleas of Clearfield
County, Pennsylvania, by an Order dated July 24, 1992 (attached as Exhibit A), adjudged
Tammy Lynn Raney a partially Incapacitated Person in need of a Limited Guardian with the
following powers:
(a) To handle the general care and maintenance and retain physical custody of
Tammy Lynn Raney.
(b) To designate the residence of Tammy Lynn Raney.
(c) To supervise and secure appropriate training, educational, medical and
psychological services and social and vocational opportunities.
(d) To determine and secure, when necessary at the discretion of the Guardian,
appropriate medical care and treatment and to execute any necessary consents
or authorizations required therefore.
(e) To determine and provide, when appropriate, at the discretion of the Guardian
any consents or approvals needed by Tammy Lynn Raney.
(f) To handle all financial matters involving Tammy Lynn Raney.
4. In the Court's July 24, 1992 Order, Luanne M. Preece was appointed Guardian of
the person and Estate of Tammy Lynn Raney for an unlimited term and directed to file an annual
report as required by law.
5. Luanne M. Preece, mother of Tammy Lynn Raney and Petitioner Melissa A.
Dixon, passed away on April 16, 2012.
6. Luanne M. Preece was intestate.
7. Since the death of Luanne M. Preece, Tammy Lynn Raney has resided with the
Petitioners at 105 Park Place, Camp Hill, Cumberland County, Pennsylvania.
8. The only other party in interest in the guardianship of Tammy Lynn Raney is
Ronnie G. Raney, her father, an adult individual residing at 1335 County Road, 1175 East,
Carmi, Illinois.
9. Ronnie G. Raney has been given notice of the present Petition and has signed an
affidavit consenting to the appointment of Melissa A. Dixon and Jason M. Dixon as Guardians of
the Person and the Estate of Tammy Lynn Raney (attached as Exhibit B). -
10. The heart condition that led to Luanne M. Preece's passing was known to both
Ms. Preece and Melissa A. Dixon for years, and it was always the family's intention that, should
Ms. Preece pass away, her daughter Melissa A. Dixon would care and provide for her other
daughter, Tammy Lynn Raney.
11. The appointment of Jason M. Dixon as a second guardian will offer stability,
given that the Petitioners reside together with Tammy Lynn Raney, and will also be a safeguard
in the event of emergency.
12. It is out of love and affection that Melissa A. Dixon and Jason M. Dixon wish to
serve as guardians of Tammy Lynn Raney, and Petitioners believe they have no interest adverse
to the interest of Tammy Lynn Raney.
13. The failure to appoint Melissa A. Dixon and Jason M. Dixon as guardians will
result in irreparable harm to the person and estate of Tammy Lynn Raney.
14. Tammy Lynn Raney receives approximately $823.00 per month in the form of a
Social Security payment because she has been determined to be a dependent adult child.
15. Melissa A. Dixon is the representative payee of Tammy Lynn Raney's monthly
Social Security payment.
16. Petitioners assert, upon information and belief, that a comparable living
arrangement for Tammy Lynn Raney, at the Cumberland Vista assisted living center, would cost
about $1,643.30 per month, $1,143.30 of which can be covered by Supplemental Security
Income (SSI) or Social Security benefits, with an additional $500.00 per month made up from
private funding sources.
17. With this in mind, it would be both reasonable and appropriate to allow
Petitioners to be compensated any remainder of Tammy Lynn Raney's monthly Social Security
payment once her expenses are met.
18. Extraordinary expenses incurred for the care of Tammy Lynn Raney can be
covered by the approximately $24,000.00 available in the Raney Family Special Needs Trust, of
which Melissa A. Dixon is trustee.
19. To the extent that the remainder of Tammy Lynn Raney's Social Security
payment, after her reasonable expenses, is less than $200.00 per month, the Petitioners request
that they would be compensated, beyond reimbursement for their expenses, that amount from the
Raney Family Special Needs Trust, or such other trust as may be established for the benefit of
Tammy Lynn Raney.
20. Petitioners previously filed a Petition to Transfer Venue in the Orphans' Court
Division of the Court of Common Pleas of Clearfield County, Pennsylvania, in order to bring the
present Petition in the Orphans' Court Division of the Court of Common Pleas of Cumberland
County, Pennsylvania, which Petition has been granted.
WHEREFORE, the Petitioners respectfully request that:
1. The Court appoint Melissa A. Dixon and Jason M. Dixon as successor
guardians to Luanne M. Preece;
2. The Court authorize Petitioners to be compensated $200.00 per month for their
care of Tammy Lynn Raney, in addition to their reimbursement of expenses incurred, and
which will be paid primarily out of any monthly remainder of Social Security payments
to Tammy Lynn Raney, and secondarily out of any trust established now or in the future -
for the benefit of Tammy Lynn Raney;
3. The Successor Guardian(s) file annual guardianship reports as guardians of the
person and estate.
Respectfully submitted,
BARIC SCHERER LLC
Date:
Bret P. Shaffer, Esquire
I.D.# 309180
19 West South Street
Carlisle, PA 17013
(717) 249-6873
Fax: (717) 249-5755
Attorney for Petitioners
VERIFICATION
We verify that the statements made in the foregoing Petition for Appointment of
Succeeding Guardians Pursuant to 20 Pa.C.S.A. § 5514 are true and correct. We understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to
unsworn falsification to authorities.
1
Meliss A. Dixon
i-
r _ "Y\
Jas M. Dixon
DATE:
-,0 /;0/2312 14: _ 5531175553°9 P,EGISTEP. P.ECOPDEP,P9D PAGE J2/03
IN THE COURT OF L'b1 ON PLEAS OF CLEARFIELD COMITY, PENNSx'LV
ANIA - -
ORPHANS' COURT DIVIsloN
ZN R"8,' TAMMY LY'NN' R"EY, an -
alleged incapacitated • Na. 32-269
person
NO6J, THIS day of July, 1992, fob lowin Hearing
the above ca tioned matter. on jut 9 g in
P Y r 1992 and in accordance with,
Findings of Fact of even date herewith, it is harsh -
Decreed that Y Ordered and
Tammy Lynn Raney is Ad ud
..d a partially
incapacitated Person in need of a Limited Cu&rdjan Of her person
and Estate with the fo7.lo~rin Guardian of her person
5 ,powers,
(a) To handle the general care and
maintenance and retain physical custody of
Tammy Lynn Raney.
(b) To designate the residence of Tammy Lynn
Raney.
(c) To supervise and secure approprixtm
training, educational, medical and
Psychological services and social and
vocational opportunities.
(d) To determine and secure, when necessary
at the discretion of the Guardian,
appropriate medical care and treatment and to
execute any necessary consents or
authorizations required therefore,
0MC dF rliF, c I. '.IC (1p
OR04P j' CCr,in r r,'
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t<ARERL, ST~RC
0 12 14:2, 03101471-56009 REGISTER. RECORDERNID PAGE 73i J3
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(e) To determine and provide, when
appropriate, at the discretion of the - -
r Guardian an _
y consents or approvals needed by
Tammy Lynn Raney.
M To handle
all financial matters
involving Tammy Lynn Raney.
Luanne M. Preece is hereby appointed as the Guardian of
the person and Estate Of 'hammy Lynn Raney.
The Guardian shall serve for an unlimited term.
The Guardian is directed to file an annul report as
required by law.
The Guardian shall not be required to post a Bond.
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By/ Th.; a r
< John
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IN THE COURT OF COMMON PLEAS OF CLEARFIELD COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
IN RE:
TAMMY LYNN RANEY, No. 92-269
an adjudicated incapacitated person :
AFFIDAVIT OF CONSENT
I, RONNIE G. RANEY, hereby consent to the appointment of MELISSA A. DIXON and
JASON M. DIXON as Guardians of the Person and of the Estate of TAMMY LYNN RANEY,
an adjudicated incapacitated person.
Ronnie G. Raney
DATED: -Z I - l z-