HomeMy WebLinkAbout01-09-15 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
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IN RE: ORPHANS' COURT DIl`��I � G� Q
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JESSIE CARTER, No. 21-2014-849 '� � � � ' � ��
An Alleged Incapacitated Person � � ;-�, --o �;; -:-,
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MOTION TO CONTINUE HEARING � G' `r' "
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AND NOW, comes the Petitioner, Beverly Fry, Senior Executive Director of
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 January 7, 2015, at 1:30 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, 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. On November 17, 2014, the Petitioner filed a Motion to Continue this
hearing do to a scheduling conflict that could not be accommodated, and with the
concurrence of Attorney Coyne, by Order dated November 20, 2014, this Honorable
granted a continuance to January 7, 2015, at 1:30 p.m.
5. The undersigned counsel and Attorney Coyne have had the opportunity to
discuss this matter further and have agreed that the January 7, 2015 hearing should be
continued to provide for additional time to further investigate potential military service
history of Mr. Carter and the status of the relationship with a previous power of attorney.
6. Attorney Coyne concurs in this request to continue the January 7, 2015
hearing, as these issues are relevant to allow full consideration of the best interests of
Mr. Carter.
WHEREFORE, Golden Living Center respectfully requests that the
January 7, 2015 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.
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By:
�C� ;"�;#:�pher� i� �r, Esquire
1".D. #20 395
�Tucker Arensber , P.C.
9
2 Lemoyne Drive, Suite 200
Lemoyne, PA 17043
Dated: �/ �� iS' (717) 234-4121
HBGDB:147414 026 5-165636
CERTIFICATE OF SERVICE
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AND NOW, this � day of January, 2015, 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 1 701 1-4227
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