HomeMy WebLinkAbout09-08-15 Tucker Arensberg, P.C.
Kevin L. Hall, Esq.
Pa. ID No. 311826
2 Lemoyne Drive, Suite 200
Lemoyne, PA 17043 ,.,^,
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717-231-4121 Attorney for Petitioner �= `; :=r, E�' n
1N RE: COURT OF COMMON PI���S,�,�_r -n �,�
CUMBERLAND COUNT�; ;': - � ��
PENNSYLVANIA `�'
HAYWOOD WILKERSON, :
An Alleged Incapacitated Person � ; � ., ,
ORPHAN'S COURT DIVISION �
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MOTION FOR CONTINUANCE OF HEARING
AND NOW, comes Petitioner, John Holly, Executive Director of Golden Living Center -
West Short (Petitioner), by and through his counsel, Tucker Arensberg, P.C., and hereby files
this Motion for Continuance of Hearing and in support thereof avers as follows:
1. On or about May 18, 2015, Petitioner filed a Petition for Appointment of Guardian for
the appointment of a Permanent Plenary Guardian of the Person and Estate of an alleged
incapacitated person, Haywood Wilkerson(Petition).
2. The Petition alleged that the alleged incapacitated person's physician had diagnosed the
alleged incapacitated person's physical and mental condition as including, but not limited to,
Depressive Disorder and Dementia with behavioral disturbances.
3. The Petition also alleged that due to the alleged incapacitated person's general medical
conditions, it is believed that the alleged incapacitated person's treating physician would likely
find that his presence in court would be harmful and detrimental to his physical or mental
condition.
4. On or about May 29, 2015, this Honorable Court issued an Order setting a hearing in this
matter for August 19, 2015.
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5. On or about July 28, 2015, this Honorable Court issued an Order re-scheduling a hearing
in this matter to take place on September 10, 2015.
6. The primary care physician who previously provided the above diagnosis was Dr.
Edward Lamarque, M.D.
7. In or about the beginning of August 2015, the alleged incapacitated person began treating
with a new primary care physician, Dr. Thomas Kunkle, D.O.
8. In the interim, there has been insufficient opportunity for Dr. Kunkle to properly evaluate
the alleged incapacitated person so as to provide testimony regarding the previous diagnoses.
9. Therefore, Petitioner requests that this Honorable Court continue a hearing to provide a
sufficient opportunity for the new primary care physician for the alleged incapacitated person to
evaluate the present diagnoses.
10. The Honorable Judge Thomas A. Placey has previously ruled on matters relating to the
above captioned case.
WHEREFORE, Petitioner respectfully requests that this Honorable Court continue the
hearing scheduled for September 10, 2015.
Respectfully submitted,
TUCKER ARENSBERG, P.C.
� '�
By
Kevin L. a , Esquire
Pa.I.D. #311826
Tucker Arensberg, P.C.
2 Lemoyne Drive, Suite 200
� � � Lemoyne, PA 17043
Dated: � �� (717) 234-4121
CERTIFICATE OF SERVICE
The undersigned counsel hereby certifies that the foregoing document was this day
served upon the parties listed below by first class mail, postage pre-paid, addressed as
follows:
Lisa Coyne, Esq.
Coyne & Coyne, P.C.
3901 Market Street
Camp Hill, PA 17011-4227
Guardian ad litem
TUC R AR S G, P.C.
By
Kevin . , squire
Pa.I.D. #311826
Tucker Arensberg, P.C.
2 Lemoyne Drive, Suite 200
� Lemoyne, PA 17043
Dated: � � I � (717) 234-4121
HBGDB:152823-1 026135-167624