HomeMy WebLinkAbout06-28-13 IN RE: ) IN THE COURT OF COMMON PLEAS
) OF CUMBERLAND COUNTY �:=.\. -.< �'
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JOAN SCHRADER ) ORPHANS' COURT DIV�I�T � ;-`,' �'
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) NO. 2013-168 ''" -�- `�' ^
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JOINT MOTION FOR LEAVE TO FILE STIPULA'��'• %°�� C� �
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PROPOSED FINDINGS OF FACT AND CONCLUS lI�1l.T� � �
OF LAW UNDER SEAL �'' � '—A •
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NOW COME, Petitioner Fredrick A. Schrader ("Petitioner"), by anc�'through h�counsel,
Rhoads and Sinon LLP, and Joan Schrader ("Ms. Schrader"), an alleged incapacitated person, by
and through her counsel, Martson Law Offices, and jointly file the within Joint 1Vlotion For
Leave to File Stipulated Proposed Findings of Fact and Conclusions of Law Under Seal.
1. Petitioner is an adult individual that currently resides at 2715 Carter Farm Court,
Alexandria, Virginia 22306.
2. Ms. Schrader is an adult individual that currently resides at 508 Conklin Street,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. This matter is before the Court on an Emergency Petition to Adjudicate Joan
Schrader Incapacitated and appoint a Plenary Guardian of her Estate (the "Petition").
4. On February 27, 2013, this Court entered an Order appointing Attorney Ivo Otto
as counsel for Joan Schrader, and continued the hearing on the Petition to afford the parties time
to engage in settlement discussions.
5. The parties have engaged in settlement discussions and by separate Motion, are
requesting that the Court approve a Stipulated Limited Guardianship Order, and enter it as an
Order of Court.
6. The parties have prepared Stipulated Proposed Findings of Fact and Conclusions
of Law, with exhibits, including some of Ms. Schrader's healthcare records to be submitted on
the record in support of the Stipulated Limited Guardianship Order.
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7. The parties have prepared Stipulated Proposed Findings of Fact and Conclusions
of Law, with exhibits, including some of Ms. Schrader's healthcare records to be submitted on
the record in support of the Stipulated Limited Guardianship Order.
8. The Stipulated Proposed Findings of Fact and Conclusions of Law contain
personal healthcare and other mental health information that should not be filed of public record.
The parties jointly request that leave be granted to file the Stipulated Proposed Findings of Fact
and Conclusions of Law, together with exhibits, under seal.
WHEREFORE, the parties jointly move this Honorable Court grant leave to file the joint
Stipulated Proposed Findings of Fact and Conclusions of Law under seal.
Respectfully Submitted,
RHOADS & SINON LLP
By:—,��� L�--
Thomas A. French, Esquire
Attorney I.D. No. 39305
Jillian M. Golden, Esquire
Attorney I.D. No. 206510
One South Market Square
P. O. Box 1146
Harrisburg, PA 17108-1146
(717) 233-5731
Attorneys for Petitioner Frederick Schrader
MARTSON LAW OFFICES
By:
Ivo V. Otto III, Esquire
10 East High Street
Carlisle, PA 17103
(717) 243-3341
Attorneys for Joan Schrader
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CERTIFICATE (JF SERVICE
I, Tricia D. Eckenraad, an autharized agent for lYlartsan Deardorff Wiitiams Otta Gilroy&
Faller,hereby certify that a copy afthe foregoing Joint Motion far Leave to File Stipulated Findings
of Fact and Conclusians of Law Under Seal was served this date by depositin� same in the Post
t�ffice at Cariis�e, PA, first class mai1, postage prepaid, addressed as follows:
Tharnas P. Gacki, Esquire
ECKERT SEAMANS CHERIN & MELLOTT, LLC
213 Market Street, 8`"Floor
Harrisburg, PA 17101
MARTSON LAW OFFICES
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ricia D. ckenroad
Ten East �igh Street
Car�isle, PA 170�l 3
(717) 243-3341
Dated: June 28, 2013
F-IFILESIC]ientsll S l21 Sehraderll 5121.l certificate af sarvice_wpd