HomeMy WebLinkAbout05-09-14 ,...��., �� ,�.,.,��.��..,..�,�,.� �<.��� .,�,r�,.���,����� _�, _ _
IN THE COURT OF COMMON PLE�S ,_,,,
CUMBERLAND COUNTY, PENNSYL�ANIA ° rn �
ORPHANS' COURT DIVISIOIVG o � e> �
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IN RE: VIRGINIA BROWN, . a �, ��, �° : �i
An Alleged Incapacitated Person . No. 21�3�I8'1 � :.� c�
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MOTION TO WITHDRAW PETITION FOR GUARDIANSHIP
ManorCare Health Services Camp Hill ("ManorCare"),by and through its attorneys,
Kennedy, PC Law Offices, hereby files this Motion to Withdraw Petition for Guardianship
("Guardianship Petition") and, in support thereof, represents as follows:
1. A guardianship hearing is scheduled for the above-captioned matter on June 5,
at 9:00 a.m.
2. ManorCare filed the Guardianship Petition on November 7, 2013 in order to
appoint a guardian to handle Virginia Brown's financial affairs and to complete the Medical
Assistance("MA") application filed on Virginia Brown's behalf.
3. After service of the Guardianship Petition on Virginia Brown's intestate heirs,
Virginia Brown's daughter and agent acting under a power of attorney, Jennifer Hattan, provided
the necessary financial verifications to qualify Virginia Brown to receive MA benefits.
4. Given the foregoing, ManorCare now desires to withdraw its Guardianship
Petition without prejudice.
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WHEREFORE, ManorCare Health Services Camp Hill requests the Court withdraw its
Petition to Adjudge Virginia Brown to Be Totally Incapacitated and To Appoint a Permanent,
Plenary Guardian of Her Person and Her Estate without prejudice and cancel the hearing for this
matter scheduled on June 5, 2014 at 9:00 a.m.
Respectfully Submitted,
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Date: � By: `
Be � i . Glatfelter squ e
Atto I.D. No.: 2 935
N. Kennedy, squire
Attorney I.D. No.: 68278
KENNEDY, PC
Law Offices
P.O. Box 5100
Harrisburg, PA 17110-0100
(717) 233-7100
Attorneys for ManorCare
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that Kennedy, PC Law Offices served a copy of
the foregoing Motion to Withdraw Petition for Guardianship to Edmund G. Myers, Esq.
and by sending it to the alleged incapacitated person's attorney, Mark Bayley, Esq. via
U.S. Mail to the following address:
Edmund G. Myers, Esquire Mark Bayley, Esquire
Johnson, Duffie, Stewart &Weidner Bayley&Mangan
301 Market Street 17 West South Street
P.O. Box 109 Carlisle, PA 17013
Lemoyne, PA 17043-0109
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Date. 5/6/2014 By. �
i . Glatfelter, quire
LD. No.: 20 35
John N. Kennedy, E uire
Attorney I.D. No.: 68278
KENNEDY,PC LAW OFFICES
P.O. Box 5100
Harrisburg, PA 17110-0100
(717) 233-7100
Attorneys for ManorCare