HomeMy WebLinkAbout08-18-15 �v
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Jennifer B. Hipp, Esquire 3: � .s, r� r-,
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1 West Main Street � ,:? ,`.� � U; �
Shiremanstown, PA 17011 ,-' y ' � � ' �-'
(717) 737-8761 � � � "-�
Attorney ID No. 86556 � a `-`;
Assistant Cumberland County Solicitor : —3 -- �`�'
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For Cumberland County Aging and Community Services � � ` n�-',
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IN RE: : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
ANN JENKINS, :
An alleged incapacitated person : ORPHANS' COURT DNISION
: NO. 21-15- 0834
REQUEST FOR ORDER EXTENDING THE APPOINTMENT OF EMERGENCY PLENARY
GUARDIANS OF THE PERSON AND ESTATE OF ANN JENKINS
Petitioner Cumberland County Aging and Community Services, by its attorney,
Cumberland County Assistant Solicitor Jennifer B. Hipp, submits this Request and in support
thereof states the following:
l. 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, who is unmarried, age 73, with a last
known permanent address of B'Nai B'Rith Apartments, 130 S. Third Street, Harrisburg, Dauphin
County, Pennsylvania.
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3. Petitioner filed an Emergency Petition for Appointment of Plenary Guardians of the
Person and Estate of Ann Jenkins in Accordance with 20 Pa.C.S.A. § 5513 with this Honorable
Court on July 31, 2015.
4. On July 31, 2015, this Honorable Court granted Petitioner's Emergency Petition and
appointed Keystone Guardian Services of 34 S. Market Street, Suite B, Elizabethville,
Pennsylvania as Plenary Guardians of the Person and Estate of Ann Jenkins for a minimum
period of seventy-two (72) hours, to be extended for a period of twenty (20) days.
5. The appointment of Keystone Guardian Services as the Emergency Plenary Guardian
of the Person and Estate of Ann Jenkins expires on August 23, 2015.
6. Petitioner filed a Petition for Appointment of Plenary Guardian of the Person and
Estate of Ann Jenkins in Accordance with 20 Pa.C.S.A. § 5511 on August 6, 2015, for which this
Honorable Court scheduled a hearing on September 9, 2015 at 10:30 a.m.
7. Petitioner respectfully requests that this Honorable Court extend its emergency
appointment of Keystone Guardian Services as the Plenary Guardians of the Person and Estate of
Ann Jenkins until September 9, 2015 at 10:30 a.m. in order to prevent a gap in care for Ms.
Jenkins.
8. John McCullough, Esquire, attorney for Ann Jenkins, supports this Request for Order
Extending the Appointment of Emergency Plenary Guardians of the Person and Estate of Ann
Jenkins.
9. Mr. McCullough and the Cumberland County Office of Aging and Community
Service are amenable to meeting with this Honorable Court via teleconference in lieu of a
hearing to review resolution of this matter or for this Honorable Court to approve this Request
without further evidentiary proceedings.
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WHEREFORE, Petitioner Cumberland County Aging and Community Services
respectfully requests that this Honorable Court issue an Order extending its appointment as the
emergency plenary guardians of the person and estate of Ann Jenkins until September 9, 2015 at
10:30 a.m..
Date: August`�P , 2015 � �' 1
Jennife B. ipp, Esquire
1 West ain Street
Shiremanstown, PA 17011
Cumberland County Assistant Solicitor
For Cumberland County Aging and Community
Services
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CERTIFICATE OF SERVICE
I, Jennifer B. Hipp, Esquire, hereby certify that I am this day serving the faregoing
Request for Order Extending the Appointment of Emergency Plenary Guardians of the Person
and Estate of Ann Jenkins upon the following named individuals 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 & Guise, 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
Date: August�, 2015 �
Jenn er . Hipp, Esquire
1 We Main Street
Shiremanstown, PA 17011
Cumberland County Assistant Solicitor
For Cumberland County Aging and Community
Services
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