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HomeMy WebLinkAbout08-06-13 0 Paula J. McDermott, Esquire Attorney LD. # 46664 Post & Schell, P.C. 17 North Second Street, 12th Floor Harrisburg, PA 17101-1601 (717) 612-6012 (phone) (717) 731-1985 (fax) c� =, = � -,:� E-mail: PMcdermott@postschell.com � � `"' r�:��= �.; c.� : ��� °'' �::> (rl - - ��-�, C.�f � � ::i:k �) " ., . IN RE: : IN THE ORPHANS�Qf;J�ZT' D�ISLON x IN THE MATTER OF : CUMBERLAND CC�IJ�i'T�, P�, � �^� : _ � N. CARL VANDLING, : : AN ALLEGED iNCAPACITATED : _ : � . ;:� ., PERSON : � r,� :.:: �:, : N0. 21-13-0754 `� '' PETITION TO APPOINT LIMITED GUARDIAN OF THE ESTATE OF N. CARL VANDLING AND NOW COMES PETITIONER, Michael N. Vandling, by and through his attorneys, Post & Schell, P.C., and avers as follows to the Court: 1. Petitioner, Michael N. Vandling, is an adult individual with an address of One Abbey Lane, Camp Hill, PA 17011 and is the son of the alleged incapacitated person, N. Carl Vandling. 2. Alleged incapacitated person, N. Carl Vandling, is an adult individual with a date of birth of September 15, 1934 and is 79 years of age. 3. N. Carl Vandling resides at 133 West Locust Street, Apartment 108, Mechanicsi�urg, PA 17055. 4. Alleged incapacitated person, N. Carl Vandling is married to Charlotte Vandling whose adc�r:;ss is 133 West Locust Street, Apartment 107, Mechanicsburg, PA 17055. 5. N. Carl Vandling is not a resident of a hospital. 6. The next of kin of the alleged incapacitated person are: Michael N. Vandling, 1 Abbey La.ne, Camp Hill, PA 17011, son, Carol Vandling, 398 A. Gurtner Road, New Cumberlarid, PA 17070, Daughter; and Diane Brubaker, 190 Konhaus Road, Mechanicsburg, PA 17055, Daughter. 7. The gross value of the alleged incapacitated person's estate is unknown. 8. Currently, N. Carl Vandling receives $900.00 a month from a trust account as well as a small income from warking part time at Rite-Aid. 9. He also receives approximately $1,216.00 a month in social security payments. 10. N. Carl Vandling suffers from Alzheimer's/dementia which renders him unable to manage his finances. 1 l. N. Carl Vandling has been a member of the armed services in the United States and has so7ne limited medical benefits from the Veterans Administration. 12. N. Carl Vandling has been the victim of ongoing elder abuse and fraud perpetrateci by his granddaughter, Brandi Neff. 13. Brandi Neff is an adult individual who resides at 398 B. Gurtner Road, New Cumberland, PA 17070. 14. Neff, who is chronically unemployed and has no money of her own, has been deceiving I�er grandfather, N. Carl Vandling, into paying all of her bills out of his meager income. 15. Brandi Neff deceived her grandfather into paying all of her bills, including, but not limitec; to, dental, medical, auto insurance, student loan payments, cell phone, cable and numerous �:iher expenses. 16. Brandi Neff has deceived her grandfather into co-signing on numerous student loans as well as other loans from M&T Bank. 2 17. The $900.00 a month which Carl Vandling receives from his trust account will stop within less than a year because, thanks to the depredations of Neff, it will be totally exhausted. 18. Brandi Neff has never contributed any funds to the accounts which she jointly owns with her grandfather, the alleged incapacitated person, N. Carl Vandling, nor has she ever made any payments on the loans which she took out jointly with her grandfather, N. Carl Vandling. 19. This Honorable Court held an emergency hearing on Wednesday, July 17, 2013. 20. At that time, this Honorable Court appointed Michael N. Vandling limited emergency guardian of the estate of N. Carl Vandling. 21. Since that time, Petitioner Michael N. Vandling has attempted to organize the finances oi his father, N. Carl Vandling. This effort is ongoing. 22. The medical deposition of Dr. Sean Oser, which will be entered into the record at the hearin�; in this matter, indicates that N. Carl Vandling is unable to manage his finances and needs assistance. 23. Dr. Oser's expert opinion is that N. Carl Vandling is incapable of managing his finances. 24. The name and address of the proposed permanent guardian is Michael N. Vandling, 1 Abbey Lane, Camp Hill, PA 17011. 25. Michael N. Vandling has no interest adverse to N. Carl Vandling. 26. No other Court has ever assumed jurisdiction in any proceeding to determine the competency of N. Carl Vandling. 27. The alleged incapacitated person has no guardian already appointed other than by this Hono�able Court. 3 28. Michael N. Vandling's consent to serve as limited guardian of the estate of N. Carl Vandling is attached hereto as Exhibit A. 29. The alleged incapacitated person's wife, Charlotte Vandling, and daughters Diane Brubaker and Carol Vandling concur in this Petition and the relief requested. WI�EREFORE, Petitioner Michael N. Vandling respectfully prays this Court to grant a citation directed to N. Carl Vandling with notice thereof to his next of kin and such other persons as the Cou��t may direct to show cause why he should not be judged an incapacitated person and a limited guia•dian of his estate appointed. Respectfully Submitted, POST & SCHELL, P.C. BY: �c Paula J. cDermott, Esquire Attorney ID #46664 17 North 2°d Street, 12t" Floor Harrisburg, PA 17101 Telephone: (717) 731-1970 Facsimile: 717-731-1985 Email: pmcdermott(c�postschell.com Dated: Azkgust 6, 2013 �o9sss9s�� 4 EXHIBIT ��A" CONSENT OF GUARDIAN OF THE ESTATE I Michael N. Vandling, hereby consent to my appointment as limited guardian of the estate of my father,N. Carl Vandling. Michael N. V dling 10988903v1 M VERIFICATION I, Michael N. Vandling, hereby affirm that the facts and matters set forth in the faregaing document are true and carrect to the best of my knawledge, information, and belief. The undersigned�nderstands that the statements rnade#herein are made subject to the genalties�af 18 Pa. C.S. §4904 relating to unsworn falsificatian to autharities. MICHAE N. VAN LING Date: August 2,2Q 13