HomeMy WebLinkAbout04-08-13 I
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Keith O. Brenneman, Esquire � � �'`3 r' t�n
44 West Main Street � � F.,., � O
Mechanicsburg, PA 17055 Cs7 �
(717)697-8528
Attorney ID#47077
Assistant Cumberland County Solicitor
For Cumberland County Aging and Community Services
IN RE: : 1N THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
JOAN S. GROVE, : ORPHANS' COURT DIVISION
an alleged incapacitated person : n
: NO. 21-14-,��.i�--
PETITION FOR APPOINTMENT OF PLENARY GUARDIANS
OF THE PERSON AND ESTATE
IN ACCORDANCE WITH 20 Pa.C.S.A. § 5511
Petitioner Cumberland County Aging and Community Services, by its attorney, Assistant
Cumberland County Solicitor Keith O. Brenneman, submits this Petition and in support thereof
states the following:
1. Petitioner is Cumberland County Aging and Community Services, having an office
located at 1100 Claremont Road, Carlisle, Pennsylvania.
2. The alleged incapacitated person is Joan S. Grove, who is unmarried, 85 years of
age and who presently resides at the Claremont Nursing And Rehabilitation Center, 1000
Claremont Drive, Carlisle, Cumberland County, Pennsylvania.
3. The alleged incapacitated person is a resident of the dementia unit at Claremont
Nursing and Rehabilitation Center and has resided in the dementia unit since February 8, 2012.
4. Petitioner understands that the Ms. Grove has never married, has no surviving
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parents and has no children or family. Accordingly, Ms. Grove has no presumptive adult heirs.
5. The alleged incapacitated person has been under the care and treatment of
physicians and has undergone a psychological examination. As a result of her medical treatment
and psychological examination, Joan S. Grove has the following diagnoses and
recommendations for her continued care:
a. She has primary progressive dementia, Alzheimer's type;
b. She has severe cognitive short-term and long-term memory and language
dysfunction;
c. She has dementia with psychosis;
d. She has depression, hypertension and osteoarthritis;
e. She has Gerd, narcolepsy, hypothyroid and dysphagia;
£ She is not capable of independent decision making;
g. She requires extensive assistance with transfers and ambulation;
h. She requires 24/7 care and supervision.
6. Petitioner avers that Joan S. Grove is incapacitated as defined under Chapter 55 of the
Probate, Estates and Fiduciaries Code.
7. The alleged incapacitated person lacks capacity, is in need of a guardian and the
failure to make such an appointment will result in irreparable harm to the person and/or estate of
Joan S. Grove.
8. Petitioner requests that it be appointed plenary guardians of the person and estate of
Joan S. Grove.
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10. Petitioner, if appointed, will be able to assist in handling the financial affairs of the
alleged incapacitated person and to make medical decisions for her including hospitalizations
and end of life decisions that may need to be made on her behalf.
11. Previous individual or individuals that were Ms. Grove's agents under a Power of
Attorney dated December 19, 2008 have passed away or are otherwise unavailable.
12. Joan S. Grove's only known source of income is a monthly Social Security check
in the amount of$1,005.00 which is received and utilized for her benefit at the Claremont
Nursing and Rehabilitation Center. Ms. Grove is on medical assistance and her burial
arrangements have been made.
13. Petitioner is unaware of any other person serving as or appointed to serve as
guardian of either the alleged incapacitated person or estate.
14. Petitioner believes that no previous application has been made to any court to
declare Joan S. Grove incapacitated and no court has assumed jurisdiction in any proceeding to
determine the incapacity of Joan S. Grove.
WHEREFORE, Petitioner Cumberland County Aging and Community Services requests
this Court to issue an Order scheduling a hearing in this matter on a date that allows Petitioner to
provide service upon the alleged incapacitated person at least 20 days prior to the hearing in
accordance with 20 Pa.C.S.A.§5511(a), appointing counsel for the alleged incapacitated person
and appointing Petitioner plenary guardians of the person and estate of Joan S. Grove.
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Keith O. Brenneman, Esquire
44 W. Main Street
Mechanicsburg, PA 17055
(717) 697-8528
Date: ��it r j �G, �v/� Cumberland County Assistant Solicitor for
Cumberland County Aging and Community Services
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VERIFICATION
I verify that the statements made in the foregoing Petition are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4904 relating to unsworn falsification to authorities.
l.�:r,i' ��[� LL���/Yj'LS7��'CJ
Priscilla Whitman, Cumberland County Aging
and Community Services
Date: �i��/�l�/