HomeMy WebLinkAbout05-08-14 IN RE: : IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,PENNSYLVANIA
JOAN ANN RENZO,
An Alleged Incapacitated Person : NO.O
: ORPHANS' COURT DIVISION
PETITION FOR ADJUDICATION OF
INCAPACITY AND APPOINTMENT OF GUARDIAN
AND NOW,comes Lauren A. Renzo, by and through her Counsel, Mateya Law Firm,
P.C., Mark A. Mateya, Esq., and respectfully represents:
1. Joan Ann Renzo is and adult individual, age 79, DOB 7/26 /1934, and is presently
residing at 6 Cedar Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055-6201.
2. Lauren A. Renzo is the daughter of Joan Ann Renzo and is an adult individual, age
49, DOB 11/24/1964, and is presently residing at 107C, South Chestnut Street, Mechanicsburg,
Cumberland County, Pennsylvania 17055.
3. Joan Ann Renzo has four surviving adult children: c s
rn
3 C-�
a. Lauren A. Renzo
b. Joel F. Renzo �-, M Co 322 Chenango Street _,a °
Binghamton,NY 13901
C. Johnathan E. Renzo o =
6 Cedar Road t —�+ c`' ;— rn
Mechanicsburg, PA 17055-6201
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d. Frank B. Renzo
128 Cabot Alley
Mechanicsburg, PA 17050
4. Joan Ann Renzo was married to Frank Renzo; Frank Renzo died on February 15,
2013. See attached Exhibit A.
5. Joan Ann Renzo has a good relationship with all of her surviving children.
Page 1 of 8
6. Joan Ann Renzo is under the medical care of Dr. Christopher Royer, Clinical
Neuropsychologist, of Mechanicsburg, PA 17055. His business address is 1150 Lancaster Blvd.,
Suite 101, Mechanicsburg, PA 17055.
7. Dr.Royer will testify to Joan Ann Renzo's mental capacity; it is not anticipated that
Mrs. Renzo's medical condition will improve to the point where she can care for herself.
8. Joan Ann Renzo is unable to handle decisions concerning her own financial
matters. It is believed that the income of Joan Ann Renzo is approximately $1,800.00 per month;
her net worth is nominal. She owns the house where she is currently residing.
9. Joan Ann Renzo is mentally unable to comprehend the costs of day to day living
expenses including food, shelter, healthcare, etc.
10. It is in the best interest of Joan Ann Renzo to have a plenary Guardian to care for
her everyday needs, both as to her person and to her financial estate.
11. There have been no other legal proceedings brought in this or any other court
concerning the competency of Joan Ann Renzo.
12. Joan Ann Renzo presently has no attorney in fact or guardian appointed to handle
her affairs.
13. Joan Ann Renzo served in the U.S. Marines Reserves.
14. Lauren A. Renzo consents to serving as plenary Guardian for her mother,Joan Ann
Renzo.
15. Lauren A. Renzo has no interest which would adversely affect the guardianship of
Joan Ann Renzo.
16. It is believed that all of Lauren A. Renzo's siblings support her being named the
plenary guardian for Joan Ann Renzo: All of Joan Ann Renzo's children were served a copy of this
Page 2 of 8
pleading.
WHEREFORE, Lauren A. Renzo respectfully requests that this Honorable Court issue a
Rule to Show Cause why Joan Ann Renzo should not be adjudged an incompetent person and a
guardian appointed to act on her behalf.
Respectfully submitted,
UJ - M
Mark A. Mate , Esquire
Attorney ID No. 78931
55 W. Church Avenue
Carlisle PA 17013
(717) 241-6500
(717) 241-3099 - Fax
Attorney for Mary Stover
Dated:
Page 3 of 8
VERIFICATION
I, Lauren A. Renzo, verify that the facts set forth in the foregoing document are true and
correct to the best of my knowledge, information, and belief. I understand that false statements
herein are subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to
authorities.
Lauren A. Renzo
DATED: 49 - 076 020
Page 4 of 8
IN RE: : IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,PENNSYLVANIA
JOAN ANN RENZO,
An Alleged Incapacitated Person : NO.
: ORPHANS' COURT DIVISION
ACCEPTANCE OF PROPOSED GUARDIAN
OF THE PERSON AND ESTATE OF JOAN ANN RENZO
Lauren A. Renzo, the proposed guardian named in the Petition for Adjudication of
Incapacity and Appointment of Guardian of the person and estate of Joan Ann Renzo, the alleged
incapacitated person, agrees to accept the appointment as guardian of the person and estate and
avers that:
1. The proposed guardian, Lauren A. Renzo, is the daughter of Joan Ann Renzo and
resides at 107C, South Chestnut Street,Mechanicsburg, Cumberland County, Pennsylvania
17055.
2. Lauren A. Renzo is the fiduciary of the estate of Frank Renzo in which the alleged
incapacitated person may have an interest; the proposed guardian of the person and
estate, Lauren A. Renzo, has no interests adverse to Joan Ann Renzo, the alleged
incapacitated person.
Date: D S•y�� ;)p/'f
Lauren A. Renzo
Renzo Estate Administration/Ajudicate Petition 9
Page 8 of 8
CERTIFICATE OF SERVICE
I, Mark A. Mateya, Esquire, hereby certify that I have served a copy of the foregoing
document on the following person(s) by depositing a true and correct copy of the same in the
United States Mail, by way of United States Mail, first class, postage prepaid, at Carlisle,
Cumberland County, Pennsylvania addressed to:
Lauren A. Renzo
107 C south Chestnut Street
Mechanicsburg PA 17055
Joan Ann Renzo
6 Cedar Road
Mechanicsburg PA 17055
Joel F. Renzo
322 Chenango Street
Binghamton NY 13901
Johnathan E Renzo
6 Cedar Road
Mechanicsburg PA 17055
Frank B Renzo
128 Cabot Alley
Mechanicsburg PA 17050 h {�
Mark A. Mateya, squire
55 W. Church Avenue
Carlisle, PA 17013
(717) 241-6500
(717) 241-3099 Fax
Dated: `J � �y