HomeMy WebLinkAbout08-28-15 c� �
Susan J. Hartman, Esquire � o � .� �
Attorney ID #65184 ,.-,�'-a � � `;; �
Duncan& Hartman, P.C. ' � r=' �' �% =�J
1 Irvine Row � ." cv^'-- i C��
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Carlisle, Pennsylvania 17013 Attorney for Petitioner ._�, ,:� ,�=�'
Telephone: (717-249-7780) Sarah F. Byers � '' :'�
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IN RE: : IN THE COURT OF COMMON PLEAS OF
KENDRA BERLYNN HUNTER : CUMBERLAND COUNTY, PENNSYLVANIA
: ORPHANS' COURT DIVISION
: No: �i-�-�9.��
PETITION FOR APPOINTMENT OF GUARDIAN
TO THE HONORABLE, THE JUDGES OF SAID COURT:
Petitioner, 'through her undersigned attorney, petitions Your Honorable Court for her
appointment as PLENARY GUARDIAN of KENDRA BERLYNN HLTNTER, and in support
thereof respectfully requests:
1. Petitioner, Sarah F. Byers, of 285 Regal Drive, Carlisle, Cumberland County,
Pennsylvania, 17013, a sui juris adult, is the natural mother of KENDRA BERLYNN HLJNTER.
2. KENDRA BERLYNN HLTNTER is a 44 year old single adult female whose birthday
is September 11, 1970.
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3. KE�IDRA BERLYNN HLTNTER, resides at Fox Subacutue Facility,
120 S. Filbert Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 and receives
residential services.
4. KENDRA BERLYNN HLTNTER,is an alleged mental incompetent as is evidenced
by a letter from Erik I. Soiferman, DO, MBA, CMD, FACOI, FACP, who indicate that KENDRA
BERLYNN HUNTER has severe physical disabilities,including anoxic encepalopathy and chronic
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ventilator dependent respiratory failure and she is unable to communicate with her environment in
any meaningful way. Said letter is incorporated by reference and attached at Exhibit "A".
5. The proposed Guardian has no interest that is adverse to those of KENDRA
BERLYNN HUNTER.
6. The Petitioner is willing to serve as Guardian of KENDRA BERLYNN HLTNTER,
an alleged mental incompetent,and she has signed a consent letter which is attached as Exhibit"B".
7. It is the position of the Petitioner that Guardianship is necessary in order to secure
medical and social services on behalf of KENDRA BERLYNN HLJNTER.
8. KENDRA BERLYNN HLTNTER, is unable to manage her property, or is liable to
dissipate it or become the victim of designing persons and lacks sufficient capacity to make or
communicate responsible decisions concerning her person.
9. The Petitioner is the mother of KENDRA BERLYNN HUNTER.
10. The Petitioner believes that there exists no less restrictive alternative in view of the
mental and physical disabilities of KENDRA BERLYNN HLINTER.
11. No other petition has been filed for the appointment of a Guardian for the alleged
incompetent. ,
WHEREFORE, Petitioner respectfully requests that she be appointed Plenary Guardian of
her daughter, KENDRA BERLYNN HLINTER, both of her person and of her property.
Duncan& Hartman, P.C.
By:
� Sus'an J. Hartma ire
��� a�, ���� Attorney for Petitio er
VERIFICATION
I verify that the statements made in the foregoing Petition for Appointment of Guardian
Complaint are true and correct. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
Date: - a�7 S � �l �� "
" Sarah F. Byers
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