HomeMy WebLinkAbout01-08-14 IN THE COURT OF COMMON PLEASOF
CUMBERLAND COUNTY, PENNSYLVANIXECORDED OFFICE OF
O.C. NO. 21-13-1181 REGISTER OF kyiLLS
11 25
ESTATE OF VIRGINIA A. BROWN, +14 "PIN 9 Aft
AN ALLEGED INCAPACITATED PERSON CLERK OF
ORPHANS- COURT
MOTION FOR CONTINUANCE CUMBERLAND CO., pA
AND NOW, comes the Movant, Virginia A. Brown, by and through her attorney, Lorin
A. Snyder, Esquire, and requests a continuance in this matter as follows
1. Movant is Virginia A. Brown (hereinafter, "Ms. Brown"), an adult individual who
resides at Manor Care Health Services, 1700 Market Street, Camp Hill, Cumberland County,
Pennsylvania 17011.
2. No November 7, 2013, a Petition was filed by Manor Care Health Services
under §5511 of the Probate, Estates and Fiduciaries Code, alleging Ms. Brown to be totally
incapacitated and requesting appointment of a guardian for her estate and her person.
3. As a result of said petition, a hearing has been scheduled for Tuesday,
January 14, 2014, at 10:30 a.m.
4. Ms. Brown intends to call as a vital witness her daughter, Jennifer Hattan, who
is Ms. Brown's acting Power of Attorney and Health Care Agent to give testimony.
5. Jennifer Hattan is unable to attend the hearing scheduled for January 14,
2014.
6. Jennifer Hattan's testimony is indispensible to this case.
7. Ms. Brown and Jennifer Hattan intend to resolve the matter which gave rise to the
filing petition without the need for further litigation.
8. Benjamin J. Glatfelter, Esquire, counsel for Manor Care, was contacted and
did not concur with this motion.
9. The Honorable M. L. Ebert, Jr., is assigned to this case.
WHEREFORE, for the foregoing reasons, Movant respectfully requests this
Honorable Court to continue the hearing to a date certain, to provide Movant and Jennifer
Hattan the opportunity to resolve this matter without the needfor further litigation, and, if a
hearing should prove necessary, to allow Movant to call Jennifer Hattan, her Power of
Attorney and Health Care Agent, as an indispensible witness
Respectfully submitted,
TURO ROBINSON
(3110,9111
Date Lorin.. d r, Esquire
%6D No. 203 99
9 South Pitt treet
arlisle, PA 013
17-245- 8
Attorney for Virginia A. Brown
CERTIFICATE OF SERVICE
I hereby certify that I served a true and correct copy of the Motion for Continuance upon
Benjamin J. Glatfelter, Esquire, by facsimile at 717-233-7050,and by depositing the same in the
United States Mail,first class, postage pre-paid on the Ninth dayof January, 2014,from Carlisle,
Pennsylvania, addressed as follows:
Benjamin L. Glatfelter, Esquire
Kennedy, PC Law Offices
P.O. Box 5100
Harrisburg, PA 17110-0100
Attorney for Manor Care Health Services
TURD R_ O61AJSON
Lorin . Snyder, E quire
129 outh Pitt Str et
Ca isle, PA 1701
( 17) 245-966P
Atulley-fer' irginiaA. Brown