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Home My WebLink About11-13-13 � IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.�f�13�I ZD 7 ORPHANS' COURT ESTATE OF SAMIR KHALIL PETITION PURSUANT TO SECTION 5511 OF THE PROBATE, ESTATES AND FIDUCIARY CODE TO ADJUDICATE SAMIR KHALIL TO BE INCAPACITATED AND TO APPOINT A PLENARY GUARDIAN TO THE HONORABLE, THE JUDGES OF SAID COURT: The Petition of Holy Spirit Hospital respectfully represents that: 1. Your Petitioner, HOLY SPIRIT HOSPfTAL OF THE SISTERS OF CHRISTIAN CHARITY, ("HSH�) is an acute care hospital located at 503 North 21 st Street, Camp Hill, Cumberland County, Pennsylvania, where Samir Khalil, the alleged incapacitated person is currently a patient. 2. The alleged incapacitated person is Samir Khalil (73 years old, date of birth April 17, 1939, Social Security Number XXX-XX-�UCX} who formerly resided at 609A Geneva Drive, Apt. 22, Mechanicsburg, Cumberland County, PA 17055. 3. Mr. Khalil suffers from various medical issues, including progressive, Alzheimer's-type - dementia with psychosis. � c " r�Dn � c� � � � � � � 4. Initially, Mr. Khalil was an inpatient in the behavioral health unit at��f�om l�agu��01� � � rn in th � Q.ntial through August 29, 2012; he was admitted for treatment of severe behavioral iss�s�r�r�d g �c�, � � � � �a � � � danger of hurting himself or others. � � "'' `'� �s i �v +-�' �.�`"",,,, m � � ° � "'� � 5. Mr. Khalil was transferred from the behavioral health unit to the acute floor for medicai management from August 29, 2012 through September 7, 2012. Mr. Khalil was transferred back to the behavioral health unit for a finrelve-day period befinreen September 7 and September 19, 2012 for Alzheimer's dementia, vascular dementia combined with delirium, delusions and behavioral disturbances. 6. Mr. Khalil was re-admitted to HSH on January 30, 2013. He had been left alone at the Mall by his son and was found wandering and incoherent; police took him to the HSH Emergency Department. He has not left the hospital since that date. 7. Mr. Khalil's Alzheimer's is progressive and incurable. His condition requires that he be under specialized, 24-hour supervision at all times. 8. Mr. Khalil's son cannot care for him, and has refused to do so. 9. Mr. Khalil's treating doctors have opined that he cannot be safely discharged to his home, nor can he be properly cared for at HSH, an acute care hospital. 10. Mr. Khalil is in need of permanent placement in an appropriate long term care facility. 11. The total assets of the alleged incapacitated person are unknown at this tirne. Upon investigation, HSH was unable to locate any assets of Mr. Khalil. 12. Mr. Khalil needs a court-appointed guardian for his person and his estate. 13. A court appointed guardian is necessary to facilitate Mr. Khalil's needed medical care, treatment and placement. 14. It is believed that no other court has assumed jurisdiction in any proceedings to determine the capacity of Samir Khalil. 15. Brian D. Brooks, d/b/a The Pennsylvania Guardianship Agency, is willing to be appointed as Plenary Guardian of the person and the property of Mr. Khalil and has no adverse interest to Mr. Khalil. WHEREFORE, your Petitioner prays that a Citation be issued to Samir Khalil to show cause why he should not be adjudged to be incapacitated, and a Plenary Guardian for his person and his estate be appointed, and that the Court schedule a hearing on this Petition. JOHNSON, DUFFIE, STEWART&WEIDNER Date: `� 13 13 Y: David . D c Attorney I.D. #41687 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Petitioner :588855 � � 1/FRIFIC�4TI�N � I� Joseph A Tor�hia, MD, MM�I, Chief Medic�l Officer of Holy Spirit Hea!#h Systam, verify that the statements made ir� th� foregang Petitian are ttue ancf correct to the best of my knowledge, informetion and be{ief. 1 undecstand th�t false statements herein are made subje�t to� the penalties uf 18 Pa.C.S.A. §4904 rela#ing to unsworn fais�fcation to authorit�'es, : ?�� ,�a Name: J eph . Torchia, M.D., MMM Title: C �ef Medi�al O�fficer, Holy Spit'it Health System qated: !l I z l3 . � .... . . �L:.''�'.': .'F;::��y:��'7'r .R:'.ti,r� �•i:�:.�....�•.SI:...• '.i��i. !!.•T �4�i17_':::" :�`lr.::a:t:.. � . .+'^�j::i. _ _ ...:..i..�.'ci.�.: .:...^.' ", .:T.�;yi ' ;-t..::r.:.•:L� ' . ..�. " .... '� . • . •'.t.GC::ts:_... �.v:.::.i::.�.'+ ._ _ .. . . ... �. .i.i. � ��':i�t" :'T;�'sti::;'� �73• .:8i�'f^.Y.. '•iP. � ' ' : a.-�.��:5�� _ r• . 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