HomeMy WebLinkAbout10-20-14 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: ORPHANS' COURT DIVISION
PATRICIA L. SHARBAUGH, No. 21-2014-846
An Alleged Incapacitated Person
MOTION TO CONTINUE HEARING
Filed on behalf of:
BEVERLY FRY, SENIOR EXECUTIVE
DIRECTOR, GOLDEN LIVING CENTER
WEST SHORE, Petitioner
Counsel of Record for this
Party:
Christopher E. Fisher, Esquire
Pa.I.D. #201395
Tucker Arensberg, P.C.
2 Lemoyne Drive, Suite 200
Lemoyne, PA 17043
(717) 234-4121
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: ORPHANS' COURT DIVISION
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PATRICIA L. SHARBAUGH, No. 21-2014-846 ,
An Alleged Incapacitated Person c C,3 C;
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MOTION TO CONTINUE HEARING v rL' cam '
AND NOW, comes the Petitioner, Beverly Fry, Senior Executive Director QT
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Golden Living Center -West Shore ("Golden Living Center"), by and through its
counsel, Tucker Arensberg, P.C. , and respectfully requests this Honorable Court to
continue the hearing listed for October 15, 2014, at 3:30 p.m., and in support thereof
represents as follows:
1. On September 10, 2014, the Petitioner filed a Petition for Appointment of
Permanent Plenary Guardian of Person and Estate, seeking the appointment of a
permanent plenary guardian of the person and estate of Patricia L. Sharbaugh ("Ms.
Sharbaugh") and that a Citation be issued and directed to the Ms. Sharbaugh to show
cause why she should not be adjudged incapacitated and why a permanent plenary
guardian of her person and estate should not be appointed.
2. On September 15, 2014, the Preliminary Order of Court ordered a Citation
to be directed to Ms. Sharbaugh and set October 15, 2014, at 3:30 p.m. as the time for
a hearing on the Petition.
3. On September 18, 2014, the Citation was issued by the Clerk of Orphans'
Court.
4. On September 24, 2014, a corrected Citation was issued, correcting the
date of the hearing from October 14, 2014 in the first Citation, to October 15, 2014, the
date provided in the Preliminary Order.
5. On October 14, 2014, Mark Bayley, Esquire was appointed as counsel for
Ms. Sharbaugh by Order of Court.
6. The undersigned counsel and Attorney Bayley had the opportunity to
discuss the matter on October 14th and agreed that the October 15, 2014 hearing
should be continued to provide Attorney Bayley with some time to review the matter and
for the deposition of the medical witness.
7. Attorney Bayley concurs in this request to Continue the October 15, 2014
hearing.
WHEREFORE, Golden Living Center respectfully requests that the
October 15, 2014 hearing be continued to the next available date in order to allow the
parties to properly prepare the matter for disposition.
TUCKER ARENSBERG, P.C.
By
Cbn- o her E. fs , Esquire
#20 95
Tucker Arensberg, P.C.
2 Lemoyne Drive, Suite 200
Lemoyne, PA 17043
Dated: /U 1117 / (717) 234-4121
HBGDB:146842 0261A-165635
CERTIFICATE OF SERVICE
AND NOW, this 17 day of October, 2014, I, Christopher E. Fisher,
attorney for the within Petitioner, hereby certify that I have this date served a copy of the
within Motion to Continue Hearing by depositing a copy of the same in the United States
Mail, postage prepaid, addressed as follows:
Mark F. Bayley, Esquire
Bayley & Mangan
17 West South Street
Carlisle, PA 17013
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