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HomeMy WebLinkAbout06-13-14 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION IN RE: JAY H. LOUCKS, An Alleged Incapacitated Person No. 21-14-0406 MOTION FOR CONTINUANCE OF HEARING HCR ManorCare Carlisle ("ManorCare"), by and through its attorneys, Kennedy, PC Law Offices, files this Motion for Continuance of Hearing and avers the following in support: 1. A guardianship hearing is scheduled for the above-captioned matter on June 23, 2014 at 10:30 a.m. 2. Since the scheduling of the hearing, a personal scheduling conflict has arisen for the undersigned which cannot be rescheduled. 3. Additionally, due to the timing of the personal scheduling conflict, adequate notice was not possible to serve the alleged incapacitated person, Jay H. Loucks. 4. Petitioner's counsel consulted with Jay H. Louck' court-appointed attorney, Austin F. Grogan, Esquire, regarding the instant continuance request and he has no objection. M rn o co C O r C T co ::7 CJ Q za �J N F" rn CO O 00 WHEREFORE, HCR ManorCare Carlisle respectfully requests the guardianship hearing scheduled for June 23, 2014 at 10:30 a.m. in the above-captioned matter be continued for thirty (30) days or until such time as the Court is available. Respectfully Submitted, Date: ( � I I By: Robert A. Evarts, Esquire Attorney I.D. No.: 75767 John N. Kennedy, Esquire Attorney I.D. No.: 68278 KENNEDY,PC Law Offices 351 West James Street, Suite 207 Lancaster, PA 17603 (717) 233-7100 Attorneys for ManorCare IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION IN RE: JAY H. LOUCKS , An Alleged Incapacitated Person No. 21-14-0406 CERTIFICATE OF SERVICE I,the undersigned, hereby certify that Kennedy, PC Law Offices served a copy of the foregoing Motion for Continuance of Hearing by sending it to the alleged incapacitated person's attorney, Austin F. Grogan, Esq. via U.S. Mail to the following address: Austin F. Grogan, Esquire LAW OFFICES OF COYNE & COYNE, P.C. 3901 Market Street Camp Hill PA 1 701 1-4227 Date: 6/11/2014 By: ' obert A. Evarts, Esquire Attorney I.D. No.: 75767 John N. Kennedy, Esquire Attorney I.D. No.: 68278 KENNEDY,PC Law Offices 351 West James Street, Suite 207 Lancaster, PA 17603 (717) 233-7100 Attorneys for ManorCare