HomeMy WebLinkAbout09-21-15 Tucker Arensberg, P.C.
Kevin L. Hall, Esq.
Pa. ID No. 311826
2 Lemoyne Drive, Suite 200
Lemoyne, PA 17043 c)
khall a,tuckerlaw.comc� sx M C-)717-231-4121 Attorney for Petitioner ED -a `=t,
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANi-A
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IN RE: ORPHANS' COURT DIVISION
LEONARD CARPENTER, No. 21-15-0866
An Alleged Incapacitated Person
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 August 10, 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, Leonard Carpenter (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, Alzheimer, Hypertension and Heart Disease with behavioral disturbances.
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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 August 12, 2015, this Honorable Court issued an Order setting a
hearing in this matter for September 24, 2015.
5. The primary care physician who previously provided the above diagnosis was Dr.
Edward Lamarque, M.D.
6. 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.
7. 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.
8. Dr. Kunkle has expressed that he is unavailable for the hearing scheduled on
September 24, 2015.
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 M.L. Ebert, Jr. has previously ruled on matters relating to
the above captioned case.
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WHEREFORE, Petitioner respectfully requests that this Honorable Court continue the
hearing scheduled for September 24, 2015.
Respectfully submitted,
TUCKER ARENSBERG, P.C.
By
Kevin 1, Esquire
Pa.I.D. #311826
Tucker Arensberg, P.C.
2 Lemoyne Drive, Suite 200
Lemoyne, PA 17043
Dated: September 18, 2015 (717) 234-4121
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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:
Mark F. Bayley, Esquire
Bayley & Mangan
17 West South Street
Carlisle, PA 17013
Guardian ad litem
Thomaisina Reynolds
4570 Larch Drive, Apt. 182
Harrisburg, PA 17109
Interested Party
Kim CaT enter
67 N. 171 Street
Harrisburg, PA 17103
Interested Party
Kevin Carpenter
1222 Capital Street
Harrisburg, PA 17102
Interested Party
TUCKER ARENSBERG, P.C.
By
Kevin L. aTl, squire
Pa.I.D. #311826
Tucker Arensberg, P.C.
2 Lemoyne Drive, Suite 200
Lemoyne, PA 17043
Dated: September 18, 2015 (717) 234-4121
HBGDB:153083-1 026135-168983
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