HomeMy WebLinkAbout09-20-13 IN RE: : IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,PENNSYLVANIA
JAMES STOVER,
An Alleged Incapacitated Person : NO. - l j - lU V
: ORPHANS' COURT DIVISION
EMERGENCY PETITION FOR APPOIN IENT OF GUARDIAN
AND NOW,comes Mary Stover, by and through her attorney, Mark A. Mateya, and
respectfully represents:
1. James Stover is and adult individual, age 71 (DOB 10/26/41), and is presently a
patient at Carlisle Regional Medical Center, 361 Alexander Spring Road, Carlisle, Cumberland
County, Pennsylvania.
2. Mary Stover, is the wife of James Stover and is an adult individual, age 59 (DOB
5/25/54), and is presently residing at 1638 Williams Grove Road, Dillsburg, Cumberland County,
Pennsylvania 17019.
3. James Stover, is the father of 2 children:
a. Sonya Seely, residing in Wellsville, PA; and
b. Jamie Lebo, residing in Bresslet, PA.
r
4. James Stover and Mary Stover have been married to each other for the previous 29
years.
5. James Stover was admitted to the Carlisle Regional Medical Center suffering from
complications from pneumonia, on or about Monday, September 16, 2013,. and has been on life
support since being admitted to the hospital.
6. James Stover is unable to communicate in any fashion with anyone and it is not
anticipated that James Stover's medical condition will improve to the point where he can be
removed from life support devices.
7. James Stover has a checking account with M&T Bank which is held in his name
alone.
8. Mary Stover is not a signatory on any bank accounts which James Stover holds at
M&T Bank or any other financial institutions.
9. Mary Stover needs to obtain funds from the accounts held by James Stover in order
to pay outstanding bills for which she and James Stover are responsible for.
10. It is in the best interest of James Stover to have this Honorable Court appoint a
Guardian for him.
11. There have been no other legal proceedings brought in this or any other court
concerning the competency of James Stover.
12. James Stover presently has no guardian appointed to handle his affairs.
13. Mary Stover requests that this Honorable Court appoint her as Guardian to handle
the day to day decisions concerning James Stover's financial well being as well as his personal day
to day living decisions.
WHEREFORE, Mary Stover respectfully requests that this Honorable Court issue an
Order adjudging James Stover incompetent and appoint Mary Stover as guardian to act on his
behalf.
Respectfully submitted,
W- fVU
Mark A. Mateya, quire
Attorney ID No. 78931
55 W. Church Avenue
Carlisle PA 17013
(717)241-6500
(717) 241-3099 - Fax
Attorney for Mary Stover
Dated: 2j
VERIFICATION
ICAT_ION
I, Mary Stover, verify that the facts set forth in the foregoing document are true and correct
to the best of my knowledge,information,and belief. I understand that false statements herein are
subject to the penalties of 18 Pa. C.S. §4904, relating to unworn falsification to authorities.
,, Mary Sto r
DATED: _ `1