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Keith O. Brenneman,Esquire ° '° '
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: : 1N THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
REBECCA WELCH-KOHL, :
An alleged incapacitated person .
: ORPHANS' COURT DIVISION
: N0. 21-13-797
PETITION FOR APPOINTMENT OF ROBERT S. KOHL, II AS PERMANENT
PLENARY GUARDIANS OF THE PERSON AND
ESTATE IN ACCORDANCE WITH 20 Pa.C.S.A. 5511
Petitioner Cumberland County Aging and Community Services, by its attorney, Assistant
Cumberland County Solicitor Keith O. Brenneman, submits this Petition and in support thereof
states the following:
1. Petitioner is Cumberland County Aging and Community Services, having an
office located at 1100 Claremont Road, Carlisle, Pennsylvania.
2. On July 22, 2013 Petitioner filed a Petition For Appointment of Emergency
Guardians of the Person and Estate with respect to Rebecca Welch-Kohl.
3. On August 23, 2013 this Court issued an Order appointing Petitioner as
emergency plenary guardians of the person and estate of Rebecca Welch-Kohl for an initial
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period of seventy-two (72) hours, which period was extended for an additional twenty (20) days.
4. Since the issuance of the Court's Order of August 23, 2013, Ms. Welch-Kohl has
been residing at Green Ridge Village at 210 Big Spring Road in Nevwille, Pennsylvania, in a
nursing-home facility. Ms. Welch-Kohl has adjusted well to her new surroundings.
5. In the process of handling Ms. Welch-Kohl's affairs, Petitioner located an
envelope mailed to Ms. Welch-Kohl by an individual identified as the son of Rebecca Welch-
Kohl, which mail was sent in 2008.
6. Petitioner has been able to locate and speak to Robert S. Kohl, II, son of Rebecca
Welch-Kohl, and confirmed through a representative of Petitioner as well as Assistant Solicitor
for Petitioner that Robert S. Kohl, II is willing to serve a guardian of the person and estate of his
mother, Rebecca Welch-Kohl.
7. Rebecca Welch-Kohl is 83 years of age, not married and her parents are believed
to be deceased. Her former husband resides in a nursing home. The presumptive adult heirs of
Rebecca Welch-Kohl are Robert S. Kohl, II, who lives at 501 Mohn Street, Apartment 404,
Steelton, PA 17113-2055, a daughter who also resides in Steelton, a daughter who lives in
Arizona and son who lives in South Carolina.
8. Robert S. Kohl, II has indicated that his other siblings identified in Paragraph 7,
above are and have been estranged from their mother and would not want to serve as her
guardian.
9. As noted in the previous petition filed with the Court, and as further evidenced by
the testimony in the hearing on August 23, 2013, Rebecca Welch-Kohl is in need of a guardian
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and the failure to make an appointment will result in irreparable harm to her person and estate.
10. Neither Petitioner nor Robert S. Kohl, II, it is believed, has any interest adverse to
that of Rebecca Welch-Kohl.
11. Testimony of Dr. Christopher Royer presented to the Court at the hearing on
August 23, 2013 confirmed that Rebecca Welch-Kohl is totally incapacitated with respect to her
ability to receive and evaluate information effectively, is totally incapacitated with respect to her
ability to communicate decisions and is totally incapacitated with respect to her ability to manage
her financial resources and affairs.
12. Petitioner avers that Rebecca Welch-Kohl is incapacitated as defined in Chapter
55 of the Probate, Estates and Fiduciaries Code.
13. Rebecca Welch-Kohl's last known sources of income consist of a$676 monthly
Social Security benefit and a monthly sum of$243 deposited directly into her bank account. In
addition, Rebecca Welch-Kohl has approximately $2,000 in a savings account and $350 in a
checking account, both being maintained at M&T Bank. Rebecca Welch-Kohl further has a
savings account at Citizens Bank containing approximately $355.
14. This Court has previously assumed jurisdiction in this proceeding to determine
the incapacity of Rebecca Welch-Kohl on an emergency basis.
15. Petitioner is not aware that Rebecca Welch-Kohl has ever executed a Power of
Attorney or in any other way designated anyone to serve as her agent with respect to any matter
pertaining to her.
16. This matter was previously assigned to Judge Ebert, who issued the Order made
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reference to in Paragraph 3, above.
Wherefore, Petitioner Cumberland County Aging and Community Services requests this
Court to:
A. Schedule a final hearing in this matter;
B. Appoint Robert S. Kohl, II as Permanent Plenary Guardian of the person and estate
of Rebecca Welch-Kohl;
C. Grant such other and further relief as this Court deems just and appropriate.
Respectfully submitted,
�
Keith O. Brenneman, Esquire
Cumberland County Assistant Solicitor for
Cumberland County Aging and Community Services
Attorney ID No. 47077
(717) 697-8528
Date: September 12, 2013
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VERIFICATION
I verify that the statements made in the foregoing Petition 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 unsworn falsification to authorities.
����
Janet Paull, Cumberland County Aging and
Community Services
Date: September 12, 2013
CERTIFICATE OF SERVICE
I, I�EITH O. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date,
caused a true and correct copy of the foregoing Petition ta be served upon the persan and in the
manner indicated below:
FIRST CLASS MAIL PC3STAGE PREPAID ADDRESSED AS FULLOt�VS:
Brian Williams, Esquire
1� West South Street
Carlisle, PA 17013
SNELBAKER 8c BRENNEMAN,P.C.
By: �� "'"" �
I�eith(3. Brenneman, Esquire
44 W. Main Street
P. (J. Box 318
Mechanicsburg, PA 17055
(717)697-8528
Llate: September 12, 2013 Assistant Cumberland County Solicitoz