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HomeMy WebLinkAbout10-09-14 IN RE: MARTHA JEAN MCCURDY IN THE COURT OF COMMON PLEAS an Alleged Incapacitated Person OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION No. 21-2014-0815 UNCONTESTED MOTION FOR TELEPHONE TESTIMONY BY EXPERT WITNESS NOW COMES, Robert McCurdy, by and through his attorneys, the law firm of Saidis, Sullivan & Rogers, and files the within Motion, and in support thereof, avers the following: 1. On September 11, 2014, Robert McCurdy filed a Petition for Plenary Guardianship of Martha Jean McCurdy. 2. Attached to the Petition was the written deposition of Dr. Roger B. Gustayson, Martha Jean McCurdy's treating physician. 3. Dr. Gustayson offered his written deposition to provide his opinion on the incapacitation of Martha Jean McCurdy. U- :7- 4. Dr. Gustayson is unable to appear and offer his medical opinion in person © ! t tie hearing scheduled on October 15, 2014, at 11:00 a.m. Lo .j cn J CD 0-5. .D Gustayson will be able to provide his testimony to the court via telep3wne� rte-' C�7 LU m c] Z. L cl. Co l for Martha Jean McCurdy, Robert Kline, does not oppose Dr. w(Kstison proMing his expert testimony via telephone. � N WHEREFORE Petitioner, Robert McCurdy, respectfully requests the Court to grant his Motion to present expert witness testimony via telephone. Respectfully submitted, SAIDIS, SULLIVAN & ROGERS DATE: October , 2014 By: _ uv,,0A'F 1 Anna Borro Hays, Esq ire PA Identification No. 70375 635 North 12th Street, Suite 400 Lemoyne, PA 17043 717-612-5800 IN RE: MARTHA JEAN MCCURDY IN THE COURT OF COMMON PLEAS an Alleged Incapacitated Person OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION No. 21-2014-0815 CERTIFICATE OF SERVICE I, Anna Borro Hays, of Saidis, Sullivan & Rogers hereby certify that I this day served a copy of this UNCONTESTED MOTION FOR TELEPHONE TESTIMONY BY EXPERT WITNESS upon the person listed below by United States Certified Mail, return receipt requested, at Camp Hill, Pennsylvania and addressed as follows: Robert P. Kline, Esquire 714 Bridge Street P.O. Box 461 New Cumberland, PA 17070 SAIDIS, SULLIVAN & ROGERS Date: October , 2014 By: Anna Borro Hays, Esq ire Identification No. 70375 635 North 12th Street, Suite 400 Lemoyne, PA 17043 717-612-5801 Attorney for the Petitioner