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Home My WebLink About08-06-15 I IIII' 1 I�I■ I f'�J Jennifer B. Hipp, Esquire � Q � � � 1 West Main Street cza .� � � � Shiremanstown, PA 17011 � � � �---� �+ (717) 737-8761 -- ,'��' � �' �-�' > > Attorney ID No. 86556 = ' � .� ' �`� Assistant Cumberland County Solicitor � , _" =� -r `� For Cumberland County Aging and Community Services cs� P== rn �,. -.._; r-- � �- cn ca . � 'n IN RE: : IN THE CO[1RT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ANN JENKINS, : An alleged incapacitated person : ORPHANS' COURT DNISION : NO. 21-15- 0834 PETITION FOR APPOINTMENT OF PLENARY GUARDIAN OF THE PERSON AND ESTATE IN ACCORDANCF WI"1'H 20 Pa.C.S.A. § 5511 Petitioner Cumberland County Aging and Community Services, by its attorney, Cumberland County Assistant Solicitor Jennifer B. Hipp, subtnits this Petition and in support thereof states the following: 1. Petitioner is Cumberland County Aging and Community Services, having an office located at 1100 Claremont Road, Carlisle, Pennsylvania. 2. The alleged incapacitated person is Ann Jenkins, wlzo is unmarried, age 73, with a last known permanent address of B'Nai B'Rith Apartments, 130 S. Third Street, Harrisburg, Dauphin County, Pennsylvania 17101. 3. Petitioner filed an Emergency Petition for Appointment of Plenary Guardians of the Person and Estate in Accordance with 20 Pa.C.S.A. § 5513, which was granted by this 1 � � IIIIII 1 I�I■ I Honorable Court on July 31, 2015, appointing Keystone Guardianship Services as Ms. Jenkins' temporary guardian. 4. Ms. Jenkins is presently residing at Golden LivingCenter - West Shore, 770 Poplar Church Road, Camp Hill, Cumberland County, Pennsylvania 1701 l. 5. On or about July 11, 2015, Gregory B. Sullivan, M.D. of Psychiatry, Behavioral Health Services, Holy Spirit Hospital, evaluated Ms. Jenkins. 6. As a result of the psychological evaluation conducted by Dr. Sullivan, Dr. Sullivan concluded the following about Ann Jenkins: a. She suffers from neurocognitive impair�ncnt which most likely represents a mixed dementia of moderate severity; and b. She is unable to exercise adequate decision-inaking due to her cognitive limitations. 7. In addition to the findings made as a result of the evaluation by Dr. Sullivan, Ann Jenkin's medical diagnoses include hypertension, anxiety, depression, GERD, dementia, cognitive deficits, chronic low back pain, aortic insufficiency, ischemic heart disease, left breast surgery (cancer) and sarcoidosis. 8. Based upon Ann Jenkin's physical condition and the findings of Dr. Sullivan, the alleged incapacitated person lacks capacity and is in need of a plenary guardian. 9. Keystone Guardian Services of 34 S. Market Stre-et, Suite B, Elizabethville, PA 17023, has agreed to serve as plenary guardian of Ms. Jenkins' person and estate. 10. Petitioner and Keystone Guardian Services have no interests that are adverse to those of Ann Jenkins. 2 I IIII'. 1 I�I■ � 11. Petitioner believes that Ann Jenkins does not �lready have a permanent, plenary guardian. 12. Petitioner avers that Ann Jenkins is incapacitatcd as defined in Chapter 55 of the Probate, Estates and Fiduciaries Code. 13. Based upon statement made by Ann Jenkins to PEtitioner, Petitioner believes that Ms. Jenkins's income is less $1,000.00 per month, although Petitioner has not been able to verify the precise amount and source(s) of the monthly income. 14. Despite its best efforts, Petitioner has been able to identify and verify any other assets of Ann Jenkins. 15. Other than Petitioner's Petition Emergency Petition for Appointment of Plenary Guardians of the Person and Estate, Petitioner believes that no previous application has been made to any court to declare Ann Jenkins incapacitated and no Court has assumed jurisdiction in any proceeding to determine the incapacity of Ann Jenkins. 16. Petitioner is not aware that Ann Jenkins has ever executed a power of attorney or in any other way designated anyone to serve as her agent with respect to any matter pertaining to her. 17. The names and addresses of Ann Jenkin's knowil relatives are as follows: a. One adult daughter: Natasha Cobb, 721 S. Mountain Road, Apt. 308, Dillsburg, PA 17019; b. Sister: Maggie Black, 1612 Naudain Street, Harrisburg, PA 17014; and c. Sister: Petitioner believes that Ms. Jenkins has another sister, although Petitioner, despite its best efforts, has been unable to verify the sister's name or place of residence. 3 II1111 1 I�I■ 1 18. Priscilla M. Whitman, Protective Services Investigator and Guardianship Caseworker, Petitioner, has determined that Ms. Jenkin's daughter, Natasha Cobb, would be inappropriate as Ms. Jenkin's Guardian. 19. Ms. Whitman has determined that Maggie Black is unable to provide assistance to Ms. Jenkins. 20. Petitioner has determined that Keystone Guardianship Services of 34 S. Market Street, Suite B, Elizabethville, PA 17023, should be appointecl to serve as Ms. Jenkins' plenary guardian of the person and estate. WHEREFORE, Petitioner Cumberland County Aging and Community Services respectfully requests that this Court appoint Keystone Guardianship Services as the Permanent Plenary Guardian of the Person and Estate of Ann Jenkins to serve without bond and to receive compensation for its services as plenary guardians in the amount of$100 per month or ten percent (10%) of Ann Jenkins' gross monthly income, whichever is less. �,,, I�� Date: August�, 2015 �'�� ` � Jennifer . i � , squire 1 West ain Street Shiremanstown, PA 17011 Cumberland C�unty Assistant Solicitor For Cumberland County Aging and Community Services 4 ni � i�i■ � VERIFICATION I verify that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to tlle penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: August�, 2015 �,�,(,Q,�:(�ct. 1 �'� _ L�-�.t�.��:��'U' Priscilla M. Whitman, Protective Services Investigator and Guardianship Caseworker Cumberland County Aging and Community Services 5 CERTIFICATE OF SERVICE I, Jennifer B. Hipp, Esquire, hereby certify that I am this day serving the foregoing Petition for Appointment of Plenary Guardian of the Person and Estate of Ann Jenkins upon the following named individual this day by depositing same in the United States Mail, First Class, postage prepaid, at Shiremanstown, Pennsylvania, addressed as follows: John McCullough, Esq. Halbruner, Hatch & Uuise, LLP 2109 Market Street Camp Hill, PA 17011 Attorney for Ann Jenkins Natasha Cobb 721 S. Mountain Road, Apt. 308 Dillsburg, PA 17019 Maggie Black 1612 Naudain Street Harrisburg, PA 17104 `-`::> ��11 Date: August � , 2015 �- "`�%�'�_ J ennife B. �ipp, Esquire 1 West ain Street Shiremanstowil, PA 17011 Cumberland County Assistant Solicitor For Cumberland County Aging and Community Services 6