HomeMy WebLinkAbout05-07-15 Name Relationship Address
Hilda Arnold Mother 1100 S Cameron Street
Harrisburg, PA 17104-2547
5. The following persons or institutions provide the listed services to the
Incapacitated Person:
Name Address Service
Golden Living Center 770 Poplar Church Road Residential Skilled
Camp Hill, PA 17011 Nursing Services
Thomas Kunkle 550 Brandt Avenue Attending physician
New Cumberland, PA 17070
AlixaRX 1041 Washington Pike Ste 100 Prescriptions
Bridgeville, PA 15017
6. The Incapacitated Person's physicians have diagnosed her physical and
mental condition as including Methicillin Resistant Pneumonia Due to Staphylococcus Aureus,
Post Traumatic Stress Disorder, Epilepsy, and Chronic Depressive Personality Disorder. These
physicians have opined that the Alleged Incapacitated Person's functional limitations include an
inability, without the care, supervision and the continued assistance of others, to satisfy
requirements for nourishment, personal and medical care, shelter, self-protection and safety,
and the management of financial resources, and that the treatment rendered to date has been
unsuccessful in significantly improving the aforementioned conditions and functional limitations.
7. Golden Living Center has been advised and believes that the
Incapacitated Person's ability to receive and evaluate information effectively and to
communicate responsible decisions is significantly impaired and currently preclude the
Incapacitated Person from independently attending to issues of medical treatment, residential
care and all matters concerning personal affairs and also the management of any financial
affairs.
8. On or about September 9, 2014, Golden Living Center, by and through
counsel, requested the appointment of a guardian due to medical and psychiatric information
received (as set forth above), which information contributed to Golden Living Center's belief that
the Incapacitated Person is totally incapacitated within the meaning of 20 Pa.C.S. §§ 5501, et
seq. with regard to matters concerning the Alleged Person's person. A copy of the Petition for
Appointment of Guardian is attached hereto as Exhibit "A".
9. Keystone Guardianship Services, with an address of P.O. Box 804,
Elizabethville, PA 17023, was identified in that Petition as a potential Guardian of the person.
10. On November 6, 2014, following a hearing on the same date, an Order
was issued, appointing Keystone Guardianship Services as "plenary, permanent guardian of the
person." A copy of the Order is attached hereto as Exhibit "B."
11. While the language of the Order and the request of Golden Living Center
was only to appoint Keystone Guardianship Services as guardian of theep rson of the
Incapacitated Person, the title of the Order purported to appoint Keystone Guardianship
Services as "Permanent Plenary Guardian of the Person and Estate." See Exhibit B, title
(emphasis added).
12. To the knowledge of Keystone Guardianship Services, the Incapacitated
Person has no gross estate and her income is limited to Social Security benefits of $679.00 per
month for which Social Security may appoint a representative payee.
13. Due to the Incapacitated Person's general medical conditions, it is
believed that the Incapacitated Person's treating physicians would likely find that her presence
in court would be harmful and detrimental to her physical or mental condition.
14. To the best of Keystone Guardianship Services knowledge, information
and belief, there has never been a prior guardian of the person or the estate who has been
appointed for the Incapacitated Person.
15. As the Court that issued the Order appointing Keystone Guardianship
Services as guardian, this Court has jurisdiction over this matter.
16. Therefore, to avoid any further confusion and ambiguity regarding the
intentions of the parties and the Court, Keystone Guardianship Services requests that this Court
enter an Order in the attached form, appointing Keystone Guardianship Services as Permanent
Plenary Guardian of the Person only.
WHEREFORE, Keystone respectfully requests this Honorable Court enter an
Order in the attached form, amending the Order of November 6, 2014, and appointing Keystone
Guardianship Services as Permanent Plenary Guardian of the Person only.
TUCKER ARENSBERG, P.C.
BY 44—AftJ—�
Ke In all, Esquire
Pa. I.D. No. 311826
Tucker Arensberg, P.C.
2 Lemoyne Drive, Suite 200
515115 Lemoyne, PA 17043
Dated: (717) 234-4121
BANK FIN:508402-1 026135-163738
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VERIFICATION
The undersigned representative for Keystone Guardianship Services hereby states that
the facts contained in the foregoing Petition are true and accurate to the best of my knowledge,
information and belief. This verification is made subject to the penalties of 18 Pa. C.S. §4904
relating to unsworn falsification to authorities.
onstance E. Stoneroad
President
Date:
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the above
document was provided on this date to the following via first class mail, postage pre-
paid:
Mark F. Bayley, Esquire
Bayley & Manga
17 West South Street
Carlisle, PA 17013
Hilda Arnold
1100 S. Cameron Street
Harrisburg, PA 17104
Carmen Arce
770 Poplar Church Road
Camp Hill, PA 17011
Keystone Guardianship Services
Constance Stoneroad
P. O. Box 804
Elizabethville, PA 17023
TUCKER ARENSBERG, P.C.
By �x aw
Kevin L. Hall, Esquire
Pa. I.D. No. 311826
Tucker Arensberg, P.C.
2 Lemoyne Drive, Suite 200
Lemoyne, PA 17043
Dated: s 5 �� (717) 234-4121
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