HomeMy WebLinkAbout06-28-13 (2) IN RE: ) iN THE COURT OF COMMON PLEAS
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JOAN SCHRADER ) ORPHANS' COURT DIV1�I(�*1 �_ �,;'; �
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JOINT MOTION FOR APPROVAL OF STIPULATED O��1rON--� �� ��,
GUARDIANSffiP PETITION ,�� c: , �' . . 4
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NOW COME, Petitioner Fredrick A. Schrader ("Petitioner"), by arrt�t�irough l�s corxr�s�1�
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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 Motion for
Approval of Stipulated Order on Guardianship Petition.
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 13, 2013, this Court entered a Preliminary Order of Court, inter alia,
freezing the assets of Joan Schrader, pending further order of Court.
5. Thereafter on February 19, 2013, this Court ordered the parties to confer and
agree upon independent counsel for Joan Schrader and engage in settlement discussions.
6. 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.
890212.1
7. This Court further modified its prior orders, and ordered that if the parties could
not reach a settlement by May 15, 2013 either party may request scheduling of a hearing on the
Petition.
8. The parties have engaged in settlement discussions and request that the Court
approve a Stipulated Limited Guardianship Order, in the form of order attached hereto, and to
enter it as an Order of Court.
9. The parties have prepared Stipulated Proposed Findings of Fact and Conclusions
of Law, with exhibits, including some of Ms. Schrader's healthcare records which have been
submitted on the record in support of the Stipulated Limited Guardianship Order.
10. The parties request that the Court adopt the Proposed Findings of Fact and
Conclusions of Law as the Court's findings and conclusions in this matter.
WHEREFORE, the parties jointly move this Honorable Court approve the Stipulated
Limited Guardianship Order, and enter it as an Order of Court.
Respectfully Submitted,
RHOADS & SINON LLP
By: ��`��1'� �
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
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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 OF SERVICE
I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams Otto Gilroy&
Faller,hereby certify that a copy of the foregoing Joint Motion for Approval of Stipulated Order on
Guardianship Petition was served this date by depositing same in the Post Office at Carlisle,PA,first
class mail, postage prepaid, addressed as follows:
Thomas P. Gacki, Esquire
ECKERT SEAMANS CHERIN & MELLOTT, LLC
213 Market Street, 8`"Floor
Harrisburg, PA 17101
MARTSON LAW OFFICES
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Tricia . Eckenroad
Ten EQ st High Street
Carlisle, PA 17013
(717) 243-3341
Dated: June 28, 2013