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Home My WebLink About02-25-15 n s. � m c o ^ - � � � _ r-i 0 w � c� ro � i � u� � � l 'v r� _ �� u� -;i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION O.C. NO. 2I- 15 "C�2� 2 F.STATE OF MARGARET L. WILKEMEYER, AN ALLEGED INCAPACITATED PERSON PETITION UNDER §SSl l OF THE PROBATE, ESTATES AND FIDUCIARIES CODE TO ADJUDGE MARGARET L. WILKEMEYER TO BE TOTALLY INCAPACITATED AND TO APPOINT A GUARDIAN FOR HER ESTATE AND HER PERSON TO THE HONORABLF. JUDGES OF SAID COURT: ManorCare Health Services—Carlisle ("Petitioner'� respectfully cepresents that 1. Petitioner is a skilled nursing faciliry wherein resides Mazgaret L. Wilkemeyer ("Ms. Wilkemeycr'�, an alleged incapacitated pecson. 2. Ms. Wilkemeyer was bom on February 23, 1935 and is currently 80 years of age. 3. Ms. Wiikemeyec resides in a pcivate nursing faciliTy in Cumberland County, whose address is: ManorCare Health Services—Cadisle 940 Walnut Bottom Road Cazlislq PA ]7015 4. Because Ms. Wilkemeyer resides in Cumberland County, this Courl has jurisdictio�pursuant to § 711 (10) of the Probate, Estates and Fiduciary Code and § 5512(a). � 5. To the extent of Petitioner's knowledge, Ms. Wilkemeyer has the following livi�g relatives: Name: Address: Rclationshin: Karen Lyons 213 Glenwood Drive Daughter Dillsburg PA 17019 Patricia Pufiey 1117 Cocklin Street Daughter Mechanicsburg, PA 17055 6. Ms. Wilkemeyer may own an interest in ceal proper[y located at ll 17 Cockli� Street, Mechanicsbu�g, Pcnnsylvania 17055. 7. According to paperwock completed on Ms. Wilkemeyec's behaif a[[he time of her admission to ManorCare Health Services—Cadisle in February 2014, Ms. Wilkemeyer's assets include tw�o accounts at M&T Bank with balances of approxima[ety $52,000.00 and $25,000.00. 8. To Pe[i[ioner's knowledge, Ms. Wilkemeyer receives total monthly income of approximately $1,900.00 from the Social Security Administration and from a pension; however, Petitioner is without knowlcdge of the respective amounts of each income source. 9. To Petitione�'s knowledge, Ms. Wilkemcycr was not a member of the Armed Services of the United States and therefore is not receiving any benefits &om[he United States Veterans' Administration. 10. Petilioner was informed Ms. Wilkemeyec appoin[ed her daughter, Pat�icia Putney, to act on her behalf as her agent unde�power of attorney; however, Petitioner has not received a copy of the power of attomey document. I 1. "Po Petitioner's lmowledge, a guardian has not pceviously been appointed for Ms. Wilkemeyer. 12. Ms. Wilkemeyer's treating physician is: Dr. Darryl Guistwite, D.O. 56 Ashton Sheet Cazlisle, PA 17015 (717) 609-2052 13. Dr. Guistwite diagnosed Ms. Wilkemeyer as suffering from demen[ia, a condi[ion which causes incapacity and requires that she receive 24-houo-a-day care. 14. Becausc of the lack of a representaUve willing and/or able to act on Ms. Wilkemeyer's behalt, aod due to the onset oY Ms. Wilkemeyer's dementia, there may be no ]ess restrictive altematives to the appointment of a Uuardian of thc estate and person of Ms. Wilkemeyer. 15. Because of Ms. Wilkemeyer's dementia,she is totally unable to manage or even appreciate the significance of her financial affairs, property and busi�ess and[o make and commu�icate any decisio�s relati�g thereto, including the abiliry m communieate her need for assistanec in these azeas. 16. Because of Ms. Wilkemeyer's dementia, she lacks the capacity to malce or communicate any responsible decisions conceming her person and is unable to attend [o her pecsonal hygiene or to keep herself properly nourished and hydrated or communicate to others her need for assistanee in these areas. 17. Because of the severity of Ms. Wilkemeyer's dementia, the assistance of other persons or services would not enable Ms. V✓ilkemeyer to participate in the making of any decisions conceming her estate or person. 18. The severity of Ms. Wilkcmeyer's dementia requires that a plenary guacdian be appointed to manage her estate. Said guardian should be appointed to manage and handle all aspects of her estate, specifically including but not limited to: all iss�es relati�g to cash, checks in any bunk or savings account, stocks and bonds, personal property, real estate, life and othe� insurancc of which she is a beneficiary,her entitlement to any govemment or non-govemment bene6t plans, federal, state, local t�es, trust aceounts of which she is the beneficiary, claims made or to bc made on her behalf or agaius[her,the executio�of documents, the entry into contracts aF1'ecting her and the paymeut of masonable eompensation or costs to provide services for her. 19. The severiry of Ms. Wilkemeyer's dementia mandates that a plenary guardian of her person be appointed to handle all issues relating to the person of Ms. Wilkemeyer, specifieally including but�ot limited[o: her living arrangements, medical and psyehiatrie eare, the adminislration of inedication to hcr and the employment a�d discharge of physicians, psychiatrists, dentists, nurses, therapists, and other professionals for her physical and mental treatmen[ and care. 20. The proposed guardian of the person and estate of Ms. Wilkemeyer is: Good News Consulting Inc. 140 Roosevelt Avenue York, PA 17401 (717) 843-1504 21. 'I�he proposed guardian, Good News Consulting, Inc., does not have any adverse intcrests to the person or estate of Ms.Wilkemeyer, and an acceptance to serve as guardian of[he person and estate is attached hereto as Exhibit A. 22. Good News Consulting, Inc. has been suggested as guardian of the pecson and estate of Ms. W ilkemeyer because they have extensive experience in handli¢g such matters. 23. Petitioner is wilhout lmowledge of whether Ms. Wilkemeyer executed an advance directive for healthcaze decisions. 24. To Petitioner's knowledge, no other Court has ever assumed jurisdiction in any pcoceeding to determine the capacity of Ms. Wilkemeyer. WHEREFORE, Petitionec pcays that a Citation be issued directed to Margazet L. Wilkemeyer to show cause why she should not be judged a totally incapacitated person and Good News Consulting, Inc. be appointed permanent plenary guardian of her person and her estate,with notice by personal service to Margare[ L. Wilkemeyer. Respectfully Submitted, Date: � ��/ /S By: CS� 6� � �enja in latfelter, quire % — .D. No.: 203 35 KF.NNF.DV�PCLAW OFFICF,S P.O. Box5100 Harrisburg, PA 17110-0100 (717) 233J I 00 Attomeys for MauoiCazc Hcalth Scrviccs—Cazlisle Sd33-IS V ERIFICATION The undersigned hereby verifies the statements oCCac[ in the foregoing document are true and correc[to[he best of his or her knowledge, informatiun and bclicE Hc or she und¢rstands any false s[a[emen[s[herein are subject to the penalties contained in 18 Pa. G S. § 4904, relating to unsworn falsification to aulhorilies. Dated:_�� v L /9�r1f/"( Sign ure Printed Name:�!//Of/ J�///IIL.0 P��cea �oe T�ue: Bi/S��S D�i�o/��iy�v ManorCare Health Services—Carlisle sa3a-is CONSENT OF PROPOSED GUARDIAN Good News Consulting, Inc. does hereby certify they are willing to act as permanen[plenary guardian of the person and estate of Margaret E. W ilkemeyer, an alleged incapacitated person, if the Court shall so appoin[. Further, Good News Consulting Inc. hereby certifies they are not a fiduciary of any es[a[e in which Margare[ E. W ilkemeyer has an interest nor do they have any other interests currenNy adverse to Margaret E. W ilkemeyer's person or estate. � �ated: c� 3 /5 ?�> �'SCmC n/LC Signature PrintedName: / �� f�c'S� Prin[ed Job Title: J�tS�Cfenf �� U Good News Consul[ing, Inc.