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HomeMy WebLinkAbout05-09-05 LAW OFFICES OF TEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 IN RE: LILLIAN V. FLANNERY ALLEGED INCAPACITATED PERSON : COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : ORPHAN COURT DIVISION : NO.::JI-()5fiL/d.c::, . - ~ ~ ) PETITION FOR PLENARY GUARDIAN c...: The undersigned brings this Petition through her Attorney, Stephen J. Hogg, Esquire, seeking appointment for Plenary Guardian of Lillian V. Flannery alleging the following: 1. The Petitioner is Kathleen Flannery, daughter of the alleged incapacitated person, residing at 925 Greenbriar Drive, Mechanicsburg, Pennsylvania 17050. The Petitioner has no interest adverse to the alleged incapacitated person and seeks appointment as Plenary Guardian to ensure the alleged incapacitated person's continued physical and mental health treatment. 2. The alleged incapacitated person is Lillian V. Flannery born March 5, 1924 and whose last known address is Claremont Nursing Home. 3. The alleged incapacitated person is widowed and has two children: LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 Kathleen Flannery 925 Greenbriar Drive Mechanicsburg, PA 17050 Michael P. Flannery 45 Moyer Lane Shermans Dale, PA 17090 4. The alleged incapacitated person is currently being treated by Dr. Ernest Josef, 1830 Good Hope Road, Enola, Pennsylvania 17025. 5. The alleged incapacitated person has been diagnosed by Dr. Ernest Josef as having Dementia. 6. The Petitioner alleges that the alleged incapacitated person has shown herself to be unable to adequately care for her own needs and would likely not pursue any physical or mental health treatment as prescribed by Dr. Ernest Josef. 7. The Petitioner requests that she be appointed Plenary Guardian of the alleged incapacitated person to assure continued needed physical and mental health treatment and over the estate of the alleged incapacitated person to ensure that the alleged incapacitated person does not waste or squander her estate. 8. The Petitioner alleges that she is the most qualified individual to be appointed Plenary Guardian of the alleged incapacitated person having her best interests in mind. 9. The Petitioner seeks appointment as Plenary Guardian of the alleged incapacitated person only so long as the alleged LAW OFFICES OF ;TEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 incapacitated person is determined by her treating doctor, Dr Ernest Josef, to be unable to take care of her own needs. 10. The Petitioner estimates that the gross value of the alleged incapacitated person's estate is $250.000.00. 11. Petitioner seeks appointment as Plenary Guardian of the Date: alleged incapacitated person's estate and of her person. Respectfully Submitted, v. .... Stbphen J. H6 , Esquire Attorney for Petitioner i~lc;;; 5~ i (