HomeMy WebLinkAbout08-30-05
7IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA
INRE:
) ORPHANS' COURT DIVISION
)
) No. 21-05-147
)
)
)
)
WILLIAM JUMPER
AN ALLEGED
INCAPACITATED PERSON.
MOTION FOR THE APPOINTMENT OF PERMANENT GUARDIANS OF THE
PERSON AND EST ATE OF WILLIAM JUMPER
NOW COMES the Petitioner, Beverly HealthCare - Camp Hill, Petitioner, by it's Attorney
Michael B. V olk of Capozzi & Associates, P .C., respectfully represents as follows:
1. Petititioner operates a long-term care facility located at 46 Erford Road, Camp Hill,
Cumberland County, Pennsylvania 17011.
2. Mr. William Jumper, a man age 86, having been born March 9, 1918, the subject of this
action, is a resident at Petitioner's facility and has been determined to be incapable of
handling his own affairs by this Court on April 15, 2005.
3. Since that time, Alfred D. Sloan, as the Principal and Founder of Faith, Hope and Love
Guardianship Services, Inc. has served as guardian of the person of William Jumper.
4. Petitioner respectfully requests this court to appoint Patricia Maisano, as Principal and
Founder of Ikor, Inc. as permanent plenary Guardian of the Estate of William JUlllper. A ".-;
--
Consent document executed by Ikor, Inc. is attached as Exhibit "1" and is hereby
incorporated by reference.
5. Information regarding the proposed guardian of the estate of William Jumper, Ik?f;;Inc. m~y
be found at HTTP://WWW.IKORUSA.COM
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6. Petitioner requests that the court grant the Guardian of the Estate full authority to
conduct financial transactions for William Jumper without exception.
7. Petitioner further requests that the Court appoint Alfred D. Sloan, as the Principal and
Founder of Faith, Hope and Love Guardianship Services, Inc. is appointed as permanent
plenary guardian of the person of William Jumper.
8. Petitioner requests that the Court grant the guardian of the person full authority over the
person of William Jumper, with the ability to consent to the general care, maintenance and
custody of William Jumper without exception.
9. It is believed and therefore averred that the Permanent Guardians of Person and Estate
shall work together to insure proper coverage of the affairs of the person and estate of
William Jumper.
10. Petitioner requests that reasonable payment in the amount of a one-time set-up fee of
$500.00 for the Guardians of the Person and Estate and $75.00 per hour for performing
guardianship services, shall be made to Ikor, Inc. and to Faith, Hope and Love Guardianship
Services, Inc. from the resident's income and/or estate.
11. Mr. James D. Flowers, Esq., Attorney for William Jumper has consented to the appointment
ofIkor, Inc. as guardian of the estate of William Jumper.
. /
Re~ctfllilY S~b~
.~/[l___
Capozzi & Associates, P.C.
Michael B. V olk, Esq.
Attorney J.D. No.: 88553
2933 North Front Street
Harrisburg, PAl 711 0
Tel: (717) 233-4101
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA
WILLIAM JUMPER
) ORPHANS' COURT DIVISION
)
) No. 21-05-147
)
)
)
)
INRE:
AN ALLEGED
INCAP ACIT A TED PERSON.
CERTIFICATE OF SERVICE
I hereby certify that on this day I served the foregoing attached materials on the person(s)
and in the manner indicated below, which service satisfies the requirements ofPa. R.C.P. 440:
James D. Flowers, Esq.
26 West High Street
Carlisle, PAl 70 13
Court-appointed attorney for
William Jumper
Helen Kocher
1057 A Allendale Road
Mechanicsburg, P A 17055
Andrea Metzger
206 North Division Street
Apartment 5
Ocean City, MD 21842
William Jumper
C/o Beverly Health Care
Camp Hill
46 Erford Road
Camp Hill, P A 17011
Faith, Hope and Love
Guardianship Services, Inc.
ATTN: Rev. Alfred D. Sloan
123 North 13th Street
Harrisburg, PAl 70 13
Ikor, Inc.
A TTN: Mrs. Patricia Maisano
696 Unionville Road
Kennett Square, P A 19348
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3 0 ()J..~fl ~-,., u
/fv.~A (----
Capozzi & Associates, P.C.
Michael B. Volk, Esq.
Attorney J.D. No.: 88553
2933 North Front Street
Harrisburg, PAl 711 0
Tel: (717) 233-4101
08-18-2005 02:03PM FROM-CAPOZZI AND ASSOCIATES
+717-233-4103
T-243 P.002/002 F-050
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSVL V ANI <\
INRE:
) ORPHANS' COURT DIVISION
)
) No. 21-05-147
)
)
)
)
WILLIAM JUMPER
AN ALLEGED
INCAPACITATED PERSON.
CONSENT TO SERVE AS PERMANENT GUARDIAN OF THE
EST ATE OF WILLIAM JUMPER
1, Patricia Maisano, am an authorized representative of Ikor. Inc., and do hereby certify
that we are willing to act as the Permanent Guardian ofthe estate of William Jumper, if the COlltt
shall so appoint us.
Further, I do hereby certify that 1 am not a fiduciary of any estate in which tlle alleged
incapacitated person has an interest, nor have I any interest adverse to the alleged incapacitated
person.
The facts and opinions contained herein are troe and correct to the best of my knowledg.:,
infonnation and belief. ~ .
~I ~ c.A ~-.
Date: I~ 05 Patricia Maisano
Sworn to and subscribed before me this lli. day of ~, 2005
Q~-J~
My Commission Expires:
tv\Ck.rc~ 301 2009
NONW. SEAL
JENNIFER L. AC~
Notarv PublIc
EAST MMt.8OROUGH lWP.CHERER COUNIV
My CommIIIIon expires Mol 30. 2009
EXHIBIT
I 1/
...
.
Exhibit" A"
STATEMENT OF RIGHTS
AN ORDER HAS BEEN ENTERED WHEREBY YOU HAVE BEEN
ADJUDICATED AN INCAPACITATED PERSON AND UNABLE TO CARE FOR
YOURSELF AND/OR MANAGE YOUR PERSONAL AFFAIRS. YOU HAVE THE
RIGHT TO FILE EXCEPTIONS TO THE COURT'S DECISION WITHIN TWENTY
(20) DAYS OF THE COURT'S ORDER OR YOU HAVE THE RIGHT TO APPEAL
THE COURT'S DECISION WITHIN THIRTY (30) DAYS OF THE COURT'S
ORDER.
YOUR MAY PETITION THE COURT AT ANY FURTHER TIME TO
MODIFY OR TO TERMINATE THE GUARDIANSHIP IF THERE IS A CHANGE IN
YOUR CAPACITY OR IF YOUR GUARDIAN FAILS TO PERFORM HIS/HER
DUTIES IN ACCORDANCE WITH THE COURT'S ORDER.
IF YOU WISH TO APPEAL THE COURT'S ORDER OR PETITION THE
COURT TO MODIFY OR TERMINATE THE GUARDIANSHIP, YOU ARE
ENTITLED TO BE REPRESENTED BY AN ATTORNEY.