HomeMy WebLinkAbout09-08-15 � - a
co �n � m
i � J rt� �
cn � �T '� o
_.� __ �. -a �i ��
.... .., , . .. ¢�
Jennifcr B. Hipg Esquirc � _ a � �-'
1 West Main Strect � . -i
Shiremanstowq PA 17011 =
(717) 737-8761 `v .-- T
Attorney [D No. 86556 y " �
Assista�t Cmnberland County Solicitor
Por Cumbedand County Aging and Community Services
IN KE: : IN �fHE COURT OF COMMON PLEAS OF
: CUMBERI.AND COUNTY, PENNSYI.VAKIA
MARCELLA GOOSE, .
An alleged Incapacitated Pe�son : ORPHANS' COOR"f DNISION
: N0. 21-15-792
RFOUGST POR ORDER LX7'rNDING THF APPOINTMHNT OF "PLMPORARY Pi,F.NARY
UUARDIANS OF THE PERSON AND ES"I�A�PE OF MARCF.LLA GOUSE
Petitioner, Cumberland Counry Aging and Communiry Services, by its attorney,
Cumbedand County Assistnnt Solicitor Jennifer B. Hipp, submits this Request and in support
thcreof sta[es the following:
I. Petitimier is Cumbexland Counry Aging and Community Services, having an oCfice
located at I100 Cluemont Road, Cadisle, Pennsylvania.
2. The alLeged incapaeitated person is Marcella Gouse, who is widowed, age 87, and
resided at 808 Opland Street, Mech¢nicsbu�g, Lower Allen Township, Ycnnsylvania 17055 until
Febmary 19.2015 when her home was condemned by Lowec Allen 7�ownship.
3. On vtarch 2,2015, she became a residen[of the Episeopal Home, 206 E. Bu�d Street,
Shippensburg, Pennsylvania.
1
�
4. Petitioner filed an Cmergency Pctition for Appointment of Plenary Guardians of the
Pcrson and l;statc i� accordancc wi[h 20 Pa.C.S.A. § 5513, which w�s granted by this Honorablc
Court on Mamh 13, 2015, appointing Petitioner as the temporary plenary guardian of the pe�son
and estate oCMrs Gouse.
5. Petitioner's appointment as the temporary ple�ary gua�dian of ihe person and estate of
Mrs. Gouse will cxpire on September 13, 2015.
6. Petitioner filed a Pctitio� tor Appointment of Plenary Uua�dian of the Person and
Estate of Marcella Gouse i�Aeeo�dance with 20 Pa.C.S.A. § SS l 1 on August 27, 2015, fo�
which this Honorable Court s-cheduled a hearing on September 24, ZO15 at 930 a.m.
7. Petitioner respectfully requcsts that this Honorable Cou�t extend its emcrgency
appointment as the Plenary Guardian of ihe Person and Estate of Maroclla Go�se until
September 24, 2015 at 930 a.m.in order �o prevent a gap in ca�e for Mrs. Gouse.
8. Robert P. Kline, I�:squice, attorney Coc Marcella Gouse, supports this Request Cor Order
Extcndi�g the Appointment oCEmergency Ylenary Guardians of the Perso� and Estatc of
Marcclla Gousc.
2 Mr. Kline and Ihe Cumberland County Office of Aging and Commonity Service are
amenable m meeting with this I[onorable Court via teleconference in lieu of a hcaring to review
resolution of this matter or fo� this Honorable Court to approve this Requcst without further
evidentiary proceedings.
2
WHGREFORE, Ye[itioner Cumbcrland County Aging and Community Scrviccs
ccspcc[fuity requests Ihat this Honorable Coun issue a� Order extcnding its appoin[ment as [he
emergency plcnary guardians of the perso� and estatc of Ma�cella Gouse until September 24,
2015 at 930 a.m..
Date: Septcmber 3 2015 � �7
Jcnnifer . pp, Gsquiw
1 West Main Strcet
Sliiremanstown, PA 17011
Cumbeda�d County Assistant Solicimr
For Cuntbedand County Aging arid Community
Services
3
CF.RTIFICATE OF SERVIC�E
I, Jennifer R. Hipp, F.squire, hereby certify that I am this day scrving the foregoing
fiequest Cor O�der Hxtending the Appointment of Emergency Ple�azy Guardians of the Person
and Estatc of Mareella Gouse upon thc following named individual this day by dcpositing same
in the Uni[ed Statcs �Iail, First Class, postage prepaid, at Shiremanstowq Pennsylvania,
addressed as follows:
Robe�t R Kline, Esquire
Attorncy for Maroella Gouse
714 Bridge Strcct
Ncw Cumberland, PA 17070
F7oyd Gouse, Jr.
3223 Louisa Lane
Mcchanicsburg, PA 17050
L'piscopal Home
Attn: Mary Grace Sheurer
206li. Burd Street
Shippensburg, PA 17257
Dntc: Scptcmbci �J1' , 2015 �
Jennifer . ipp, Lsquire
1 West Main Strcct
Shiremanstown, PA 17011
Cumbcrlhnd County Assistant Solicitor
For Cumbedand County Agi�g and
Commimity Scrviccs
4