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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
IN THE MATTER OF :
SARAH QUIMBY, :
An Alleged Incapacitated Person : No. 21-14-"�27
MOTION FOR AMENDED FINAL DECRF E
AND NOW, COMES the Movant herein, Messiah Lifeways, by and through its
attorneys, Latsha Davis & McKenna, P.C., and files this Motion for Amended Final Decree, and
in support thereof, states the following:
l. Movant, Messiah Lifeways, filed a Petition for Adjudication and Appointment of
Guardian on September 26, 2014.
2. By Order of Court dated October 6, ?014, this Honorable Court scheduled a
hearing on the matter for November 26, 2014.
3. After that hearing, this Honorable Court issued a temporary Order appointing
Keystone Guardianship Services ("KGS") as temporary guardian of the person and Estate of
Sarah Quimby, which also directed KGS to investigate certain outstanding matters.
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4. After KGS completed its investigation into the outstanding matters and Petitioner
reported back to the Court, a Final Decree was entered on April 21, 2015.
5. Subsequent to the entering of the Final Decree, KGS has become aware of life
insurance proceeds which were paid to Ms. Quimby and need to be dealt with in order to
maintain Ms. Quimby's eligibility for Medical Assistance.
6. Additionally, the Final Decree did not provide for appropriate payment for the
services of KGS.
7. Accordingly, Petitioner requests that this Honorable Court issue an Amended
Final Decree providing for the appropriate spend-down of the life insurance proceeds, as well as
appropriate payment to KGS.
8. The Court appointed attorney for Sarah Quimby, Robert Kline, Esquire, concurs
in this Motion and in the language of the Amended Final Decree filed herewith.
WHEREFORE, Movant, Messiah Lifeways, respectfully requests that this Honorable
Court issue the Amended Final Decree attached hereto.
Respectfully submitted,
LATSHA DAVIS & MCKE , .C.
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Date: July 7, 2015 gy; �� �.`-�
Steven M. Montresor
Attorney I.D. No.: PA 74244
Andrew P. Dollinan, Esquire
Attorney I.D. No. PA 209466
1700 Bent Creek Boulevard, Suite 140
� Mechanicsburg, PA 17050
Tele: (717 j 620-2424
Fax: (7 1 71 620-2444
Attorneys for Movant, Messiah Lifeways
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CERTIFICATE OF SERVICE
I, Angela D. Enos, hereby certify that on this 7th day of July, 2015, a true and correct
copy of the foregoing Petition for Amended Final Decree was served via U.S. First Class Mail,
upon the following:
Robert P. Kline, Esquire
Kline Law Office
714 Bridge Street
P.O. Box 461
New Cumberland, PA 17070-0461
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Dated: July 7, 2015 : � ' ,��,�
Angel D. nos �/
584562v1