HomeMy WebLinkAbout08-01-13 OF-NCE Cr
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Keith O.Brenneman,Esquire CUYBEFc00i") 00- S'#�
44 West Main Street
Mechanicsburg,PA 17055
(717)697-8528
Attorney ID#47077
Assistant Cumberland County Solicitor
For Cumberland County Aging and Community Services
IN RE: : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
REBECCA WELCH-KOHL,
An alleged incapacitated person
ORPHANS' COURT DIVISION
NO. 21-13-797
SUPPLEMENTAL MOTION TO RESCHEDULE HEARING ON
PETITION FOR APPOINTMENT OF EMERGENCY GUARDIANS
Cumberland County Aging and Community Services,by its attorney,Assistant
Cumberland County Solicitor Keith O. Brenneman, submits this Supplemental Motion to
Reschedule Hearing on the Petition For Appointment of Emergency Guardians and in support
thereof states the following:
1. On July 22, 20.13 Petitioner Cumberland County Aging and Community Services
filed a Petition For Appointment of Emergency Guardians of the Person and Estate (the
"Petition")with respect to this matter.
2. By Order dated July 23, 2013 the Court scheduled a hearing on the Petition to take
place at 10:00 o'clock a.m. on July 31,2013.
LAW OFFICES
SNELBAKER&
BRENNEMAN, P.G.
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3. Early in the morning of July 31, 2013 the attorney for the Petitioner learned that a
key witness in this matter from Cumberland County Aging and Community Services was unable
to attend the hearing due to illness.
4. On July 31, 2013 Petition filed a Motion to reschedule the hearing in this matter due
to the unavailability of the witness to testify in this case.
5. Counsel for Petitioner requests this Court to reschedule the hearing on the Petition to
a later date to ensure the availability of the witness that is testifying on behalf of the Petitioner.
6. Petitioner waives any time limits applicable to the holding of a hearing due to the
emergency nature of the Petition and consents to a hearing being held on August 23, 2013 at 9:00
o'clock A.M.
7. Brian Williams, Esquire, the Court-appointed attorney for the alleged incapacitated
person, Rebecca Welch-Kohl, had earlier consented to the July 31, 2013 hearing being
rescheduled.
WHEREFORE, Petitioner requests this Court to reschedule the hearing on the Petition
for the reasons set forth above.
Keith O. Brenneman, Esquire
Assistant Cumberland County Solicitor
For Cumberland County Aging and
Community Services
Date: August 1, 2013
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SNELBAKER& -
BRENNEMAN, P.C.
VERIFICATION
I verify that the statements made in the foregoing Motion 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 unworn falsification to authorities.
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Keith O. Brenneman
Assistant Cumberland County Solicitor
Date: August 1, 2013
LAW OFFICES
SNELBAKER&
BRENNEMAN, P.C.
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CERTIFICATE OF SERVICE
I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date,
caused a true and correct copy of the foregoing Motion to be served upon the person and in the
manner indicated below:
FIRST CLASS MAIL, POSTAGE PREPAID ADDRESSED AS FOLLOWS:
Brian Williams, Esquire
17 West South Street
Carlisle, PA 17013
SNELBAKER& BRENNEMAN, P.C.
By:
Keith O. Brenneman, Esquire
44 W. Main Street
P. O. Box 318
Mechanicsburg, PA 17055
(717)697-8528
Date: August 1, 2013 Assistant Cumberland County Solicitor
LAW O CES
SNELBAKER&
BRENNEMAN, P.C.
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