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HomeMy WebLinkAbout02-26-14 IN RE: Estate of Virginia A. Brown, IN THE COURT OF COMMON PLEAS OF An alleged incapacitated person CUMBERLAND COUNTY, PENNSYLVANIA ORPHAN'S COURT DIVISION c, 1' x-, NO. 21-13-1181 _:. MOTION FOR CONTINUANCE �a o�-_ w AND NOW, comes court-appointed counsel for Virginia A. Brown, Mark'`""F. Bayley;�nd .© in support of the within motion avers as follows: I. The within matter is assigned to the Honorable M. L. Ebert,Jr. 2. A hearing is scheduled for March 3, 2014. 3. Undersigned counsel was recently appointed and is still in the process of investigating the matter. 4. Ms. Brown appointed her daughter,Jennifer R. Hatton, as her agent by a power of attorney document executed on May 5, 2011. 5. Ms. Hatton may currently be taking action to remove Ms. Brown from her current residence at Manor Care Health Services in Camp Hill. 6. In the event that Ms. Brown is deemed to be an incapacitated person it has not yet been determined that Ms. Hatton is a suitable guardian/agent or that Ms. Brown's removal from her current residence is appropriate. 7. Based on the circumstances it is appropriate for the Court to prohibit Ms. Brown's removal from her current residence pending further Order or agreement between the parties. 8. Benjamin J. Gladfelter, Esquire, was contacted and concurs with the within motion on f� behalf of the Petitioner. WHEREFORE, entry of the attached order is requested. Respectfully submitted, BAYLEY& MANGAN Mark F. Bayley, Esquire 17 West South Street Carlisle,PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 IN RE: Estate of Virginia A. Brown, IN THE COURT OF COMMON PLEAS OF An alleged incapacitated person CUMBERLAND COUNTY, PENNSYLVANIA ORPHAN'S COURT DIVISION NO. 21-13-1181 VERIFICATION Mark F. Bayley, states that he is the attorney in relation to the within matter; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. Mark F. Bayley, Esquire IN RE: Estate of Virginia A. Brown, : IN THE COURT OF COMMON PLEAS OF An alleged incapacitated person : CUMBERLAND COUNTY, PENNSYLVANIA ORPHAN'S COURT DIVISION NO. 21-13-1181 CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, do hereby certify that I this day served a copy of the forgoing document upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Benjamin J. Glatfelter, Esquire Kennedy, PC Law Office P. O. Box 5100 Harrisburg, PA 17011-0100 Z -- Z� ( '--I Z' V Mark F. Bayley, Esquire