HomeMy WebLinkAbout09-08-15 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: ORPHANS' COURT DIVISION
JESSIE CARTER, No. 21-2014-0849
An Alleged Incapacitated Person
MOTION FOR STATUS CONFERENCE
Filed on behalf of:
JOHN HOLLY, EXECUTIVE DIRECTOR,
GGNSC CAMP HILL WEST SHORE LP
d/b/a GOLDEN LIVING CENTER-WEST
SHORE, Petitioner
Counsel of Record for this
Party:
Danielle L. Dietrich, Esquire
Pa. I.D. #200767
Kevin Hall, Esquire
Pa I.D. #311826
Tucker Arensberg, P.C.
2 Lemoyne Drive
Suite 200
Lemoyne, PA 17043
(717) 234-4121
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: ORPHANS' COURT DIVISION
JESSIE CARTER, No. 21-2014-0849
An Alleged Incapacitated Person
MOTION FOR STATUS CONFERENCE
AND NOW, comes Petitioner, John Holly, Executive Director, GGNSC CAMP
HILL WEST SHORE, LP d/b/a GOLDEN LIVING CENTER - WEST SHOD , PetW6nef,,3, r
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by and through counsel, Tucker Arensberg, P.C., and hereby files this �, of 0--for S§atug r; co rrFT1
Conference and in support thereof, avers as follows: w = _.!D c�
1. In or about September 2014, Petitioner filed a Petition for Appointment of
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Guardian over the Person of Jessie Carter. o ''?
2. On or about February 24, 2015, following a scheduled hearing for the
appointment of a guardian over the person of Jessie Carter, a request to amend the
Petition to include the appointment of a guardian over the person and estate was
granted.
3. Per the Order of Court of February 24, 2015, the Petitioner was to file an
Amended Petition for Appoint of Guardian of the Person and Estate, at which time a
new hearing would be scheduled.
4. In addition, upon information and belief, at that hearing, a number of
concerns were raised by the guardian ad litem with counsel for Petitioner regarding the
following: 1. The veteran/military status of the alleged incapacitated person; 2. The
current residence of the alleged incapacitated person in comparison to the location of
his prior residence.
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5. In the interim, Petitioner has undertaken an investigation regarding both
concerns and hereby requests a Status Conference with the Court and the guardian ad
litem to both review the findings of such investigation and discuss the filing of an
Amended Petition for Appointment of Guardian of Person and Estate.
6. Notice of Petitioner's intent to file this request for status conference was
provided to the guardian ad litem via correspondence dated August 27, 2015. A copy of
the correspondence is attached as Exhibit "A."
7. The Honorable Judge Thomas A. Placey has previously ruled on matter
relating to this guardianship proceeding.
WHEREFORE, Petitioner hereby requests that this Honorable Court grant the
request for status conference and provide such other relief as the Court should deem
just and proper.
Respectfully submitted,
TUCKER ARENSBERG, P.C.
By
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Danielle L'. etrich, Esquire
Pa. I.D. #200767
Kevin Hall, Esquire
Pa. I.D. #311826
2 Lemoyne Drive
Suite 200
Lemoyne, PA 17043
717-234-4121
khat l(a-tuckerlaw.com
Date: -3 /S
H BG DB:152732-1 026135-165636
Hall, Kevin
From: Hall, Kevin
Sent: Thursday, August 27, 2015 2:15 PM
To: 'Lisa Coyne'
Cc: Smith, Jennifer
Subject: In Re: Guardianship Petition of Jessie Carter
Dear Ms. Coyne:
Please allow this note to inform you of our intention to request a status conference with the Court to discuss the
matters you raised in our telephone conversation of last week.
Please let us know if you have any questions.Thank you.
Kevin L. Hall, Esq.
2 Lemoyne Drive, Suite 200 1 Lemoyne, PA 17043
Office: 717.221.7951 1 Cell: 717.991.8793
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VIA E-MAIL:tapc@tuckerlaw.com
VIA TELEPHONE:412-566-1212
1
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and accurate copy of the foregoing document was
served upon the parties listed below this day via first class mail postage pre-paid, addressed as
follows:
Lisa M. Coyne, Esq.
Coyne and Coyne, P.C.
3901 Market St
Camp Hill, PA 17011
Guardian ad litem
BY 1
Danielle L. Dietrich, Esquire
Pa. I.D. #200767
Kevin Hall, Esquire
Pa. I.D. #311826
2 Lemoyne Drive
Suite 200
Lemoyne, PA 17043
717-234-4121
khall(abtuckerlaw.com
Date: C), I