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IN RE: : IN THE COURT OF COMMC�1 P�EASN � Q
SANYA M. WAGNER, : CUMBERLAND COUNTY,PENNSYLVt�TIA '� �
an alleged incapacitated person : ORPHANS' COURT DIVISION �
: DOCKET NO. `1-I -I�I - ���I
PETITION TO APPOINT EMERGENCY GUARDIANS FOR
AN ALLEGED INCAPACITATED PERSON
AND NOW,come Douglas K.Wagner and Paula M.Wagner(hereinafter"Petitioners"),by
and through their undersigned counsel, and make the following petition:
1. Petitioners are husband and wife residing at 601 Wayne Drive,Mechanicsburg(Upper
Allen Township), Cumberland County, Pennsylvania 17055.
2. Petitioners are the natural parents of the alleged incapacitated person, Sanya M.
W agner.
3. Sanya M. Wagner was born on October 17, 1984, and is now 29 years of age.
4. Sanya M. Wagner has never been married.
5. Sanya M. Wagner is a lifelong resident of Cumberland County,Pennsylvania,but at
the time of the accident described below, she was temporarily living at 612 Range End Road,
Dillsburg, York County, Pennsylvania 17019.
6. Sanya M. Wagner suffered traumatic injuries in a motor vehicle accident on March
20,2014,and she has been a patient in the intensive care unit at Penn State Hershey Medical Center
since that time.
7. Sanya M. Wagner suffered diffuse axonal brain injury which has left her in a
persistent vegetative state with no indication of her regaining consciousness in the near future.
8. In addition to her traumatic brain injury, Sanya M. Wagner suffered broken ribs, a
broken pelvis, and a bulged disk in her neck.
9. Sanya M.Wagner is currently on a respirator and receiving intravenous nutrition and
hydration.
10. Attached hereto as Exhibit"A"and incorporated herein by reference is a letter from
Ariel Santos, MD, of Penn State Hershey Medical Center, stating that Sanya M. Wagner is unable
to make medical decisions or handle her legal or financial affairs.
1 l. Sanya M. Wagner(a) is unable to receive and evaluate information effectively and
communicate meaningful decisions,(b)is unable to manage her financial resources and(c)is unable
to meet essential requirements for her physical health and safety.
12. Sanya M. Wagner has not signed a power of attorney.
13. Sanya M. Wagner has not created a trust to manage her financial resources.
14. Sanya M. Wagner's assets consist of the following:
a. A checking account at PNC Bank with an approximate balance of$1,000.00;
b. Miscellaneous personal effects;
c. A Chevrolet Cavalier which was deemed a total loss after the accident.
I5. Sanya M. Wagner was employed by Merry Maids with an approximate income of
$22,000.00 per year.
2
16. Penn State Hershey Medical Center requested that Petitioners obtain emergency
guardianship for Sanya M.Wagner so that someone has immediate legal authority to make medical
and financial decisions for her.
17. Petitioners propose to serve as emergency guardians of the estate and person of Sanya
M. Wagner with authority to act jointly or individually. Petitioners' consents to serve are attached
hereto as Exhibit"B" and incorporated herein by reference.
18. Petitioner pouglas K. Wagner is not employed due to medical disability.
19. Petitioner Paula M. Wagner is employed by National Flood Services in data entry.
20. Petitioners have no interest adverse to the interests of Sanya M. Wagner.
21. No other court has assumed jurisdiction in any proceeding to determine the incapacity
of Sanya M. Wagner.
22. In addition to her parents (the Petitioners), Sanya M. Wagner has the following
immediate family:
a. Tanya M. Wagner(sister), 601 Wayne Drive, Mechanicsburg PA 17055;
b. Douglas K. Wagner Jr. (brother), 1117 Diamond Ct., Harrisburg PA 17111;
c. Jacob D. Myers (son, age 4), 612 Range End Road, Dillsburg PA 17019.
23. Tanya M. Wagner and Douglas K. Wagner Jr. have consented in writing to the
appointment of Petitioners as plenary guardians of the estate and person of Sanya M.Wagner. Their
Consents are attached hereto as Exhibit"C" and incorporated herein by reference.
3
24. If appointed as emergency guardians, Petitioners intend to move Sanya M. Wagner
to an appropriate medical facility closer to their home when possible.
25. Petitioners intend to petition this Court to appoint them plenary guardians of the
estate and person of Sanya M. Wagner.
WHEREFORE, Petitioners respectfully request that the Court enter an order appointing
them to serve jointly or individually as emergency guardians of the estate and person of Sanya M.
Wagner for the maximum period allowed by law, to serve without bond.
HALBRUNER, HATCH & GUISE, LLP
BY: �� ,
Mark E. Halbruner, Esquire
Supreme Court LD.No. 66737
2109 Market Street
Camp Hill PA 17011
(717) 731-9600
(Attorneys for Petitioners)
Date: � 2 �
4
EXHIBIT "A"
Mar. 31. 2014 8:46PM 711-531-0321 No, 7303 P, 1/1
PENNSTATE: H�:1�SHFY
M�lto�i S. Hcrsl�cy
�Medical Ccntci' Dlvlstou of'17'�uma,Aco1c C'Hrc Sur�;ery
and C.'riEicql C.`Hre.
Milton S.IIcrslicy Mcdical Ccntcr
500 Univcrsiry Ur.,MC H07S
Hcrshcy,PA 17033-OR50
'felcphunc'717-S71-7161
1�„x: 717•531•0321
Date: March 28,Z�14
To Attorney Mark Halbruner
Fax; 717-731-9627
Re: Sanya M Wagner DOB 10/17/1984
Ms.Sanya M.Wagner is a patient 1n the Penn State Nershey Medlcal Center. She suffered traumatic
injuries due to a motorvehiele crash on 03/20/2014 ancl she has bee►i a patient in the iritensive care
unit since that tirne. Due to the severity of her injury she is unable to make medicai declsions or handle
any of her legal or��anciai affairs. •
Sincerely,
lrl'��
� Santo�INID
�rauma/Acute Care Surgery
`�:
An Eausl Onoorlunih�lhii�r.ni1Y
EXHIBIT "B"
COMMONWEALTH OF PENNSYLVANIA .
. SS:
COUNTY OF CUMBERLAND .
DOUGLAS K. WAGNER, being duly sworn according to law, deposes and says that the
facts set forth in the foregoing petition are true and correct to the best of her knowledge,information
and belie£ I further attest as follows:
1. I hereby consent to act with my spouse, Paula M. Wagner, as emergency guardians
of the estate and person of our daughter, Sanya M. Wagner.
2. I now reside at 601 Wayne Drive, Mechanicsburg PA 17055.
3. I am not employed due to medical disability.
4. I am a citizen of the United States of America, and I can speak, read and write the
English language.
5. I have no interest adverse to my daughter,Sanya M.Wagner,the alleged incapacitated
person.
r
�,��� y/1n�.�
UGLAS K. WA NER
Sworn to and subscri ed
before e this�day
of , 2014.
G�lil�/
Notary Pu li
C�R�N�CfA�E/�LT�!OF PENNSYWANIA
nlotarial Seat
Trad L.Sepkovic,NoWry Public
t.emoYne Boro,Cumberland County
M CAmmisslon Expires March 27,2016
MlMBER�,QRI�N+��v�N��A�ON OF N07ARIES
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COMMONWEALTH OF PENNSYLVANIA .
. SS:
COUNTY OF CUMBERLAND :
PAULA M.WAGNER,being duly sworn according to law,deposes and says that the facts
set forth in the foregoing petition are true and correct to the best of her knowledge, information and
belief. I further attest as follows:
1. I hereby consent to act with my spouse,Douglas K.Wagner,as emergency guardians
of the estate and person of our daughter, Sanya M. Wagner.
2. I now reside at 601 Wayne Drive, Mechanicsburg PA 17055.
3. I am employed by National Flood Services in data entry.
4. I am a citizen of the United States of America, and I can speak, read and write the
English language.
5. I have no interest adverse to my daughter,Sanya M.Wagner,the alleged incapacitated
person.
� W .
P ULA M. WAGNE
Sworn to and subscr�bed
before me this ��� day
of , 2014.
. ,/ (�tiG✓
,��`
Notary Public
C�MMONWEALTH OF PENNSYLVANIA
NoWrial Seal
Traci L.Sepkovic,Notary Public
Lemoyne Boro,Cumberland County
My Commission Expires March 27,2016
MEMBER,PENNSYLVANIA ASSOCIA170N OF NOTARIES
^Y,.oti.+ti�a,.art�a9id��/.
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EXHIBIT `�C"
CONSENT TO APPOINTMENT OF
EMERGENCY AND PLENARY GUARDIANS
I, TANYA M. WAGNER, being the natural sister of Sanya M. Wagner, and having been
notified of the petition to adjudicate her an incapacitated person and to appoint emergency and
plenary guardians of her estate and person,hereby consent to the appointment of Douglas K.Wagner
and Paula M. Wagner to serve jointly or individually as emergency and plenary guardians of the
estate and person of Sanya M. Wagner, to serve without bond.
_� . G�� �
� �
TANYA . WAGNER
COMMONWEALTH OF PENNSYLVANIA :
. SS:
COUNTY OF CUMBERLAND .
On this,the�nv�'day of /�1 � ,2014,before me,a Notary Public,the
undersigned officer,personally appeare TANYA M. WAGNER, known to me(or satisfactorily
proven)to be the person whose name is subscribed to the within instrument,and acknowledged that
she executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
� 1C.1/!i! c.
No ry Public
G�MMONWEq�-I'H OF PENNSYLVANIA
hlotadal Sea!
Tracf L Sepkovk,Notary PUbIIC
Lertroyne Bo%Cumberland County
My Commfsslpn Fxpires March 27,2016
MEMBER,PENNSYLVANIA A$$p�pTlON OF NOTqItIE$
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CONSENT TO APPOINTMENT OF
EMERGENCY AND PLENARY GUARDIANS
I,DOUGLAS K.WAGNER JR.,being the natural brother of Sanya M.Wagner,and having
been notified of the petition to adjudicate her an incapacitated person and to appoint emergency and
plenary guardians of her estate and person,hereby consent to the appointment of Douglas K.Wagner
and Paula M. Wagner to serve jointly or individually as emergency and plenary guardians of the
estate and person of Sanya M. Wagner, to serve without bond.
/ :��
D AS . W GNER JR.
COMMONWEALTH OF PENNSYLVANIA :
� ���� . SS:
COUNTY OF � .
On this,the�day of _,2014,before me,a Notary Public,the
undersigned officer, personally appe ed DOUGLAS K. WAGNER JR., known to me (or
satisfactorily proven) to be the person whose name is subscribed to the within instrument, and
acknowledged that he executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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Notary Public
C'�MMONWEA TH OF PENNSYLVANIA
Notertal Seal
Trad L.Sepkovic,Notary Public
Lemoyne Boro,CUmberland County
M Commisslon Expires March 27,2016
MEMBER,PENNSI'WANU ASSOQATtON OF NOTARIES
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