HomeMy WebLinkAbout11-18-14 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: ORPHANS' COURT DIVISION
JESSIE CARTER, No. 21-2014-849 ,�,
An Alleged Incapacitated Person G �,
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MOTION TO CONTINUE HEARING �:? ?, �-' r7;
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AND NOW, comes the Petitioner, Beverly Fry, Senior Executive Director:
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 November 18, 2014, at 3930 a.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, seeking the appointment of a permanent
plenary guardian of the person of Jessie Carter ("Mr. Carter") and that a Citation be
issued and directed to Mr. Carter to show cause why he should not be adjudged
incapacitated and why a permanent plenary guardian of his person should not be
appointed.
2. On September 15, 2014, an Order of Court appointed Lisa M. Coyne,
Esquire as Guardian ad litem for Mr. Carter and directed a Citation to be issued to Mr.
Carter and set November 18, 2014, at 9:30 a.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. The Petitioner's counsel recently learned that he is also scheduled to be in
Court in Philadelphia at 9:30 a.m. on November 18, 2014.
5. The undersigned counsel and Attorney Coyne had the opportunity to
discuss the matter on November 14th and agreed that the November 18, 2014 hearing
should be continued to provide for additional to to investigate potential military service
history of Mr. Carter, the status of the relationship with a previous power of attorney and
to accommodate the conflict in Petitioner's counsel's schedule.
6. Attorney Coyne concurs in this request to continue the November 18,
2014 hearing.
WHEREFORE, Golden Living Center respectfully requests that the
November 18, 2014 hearing be continued to the next available date in order to allow the
parties to properly prepare the matter for disposition.
Respectfully Submitted,
TUCKER ARENSBERG, P.C.
By: / -
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Chrir opfier fisher, Esquire
l/ ia"k 6 #A 1395
Tucker Arensberg, P.C.
2 Lemoyne Drive, Suite 200
Lemoyne, PA 17043
Dated: /G /7 / (717) 234-4121
HBGDB:147414102 35-165636
CERTIFICATE OF SERVICE
AND NOW, this 17 day of November, 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 e-mail and by depositing a copy of the same in the
United States Mail, postage prepaid, addressed as follows:
Lisa M. Coyne, Esquire
Coyne & Coyne, P.C.
3901 Market Street
Camp Hill, PA 17011-4227
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