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HomeMy WebLinkAbout10-14-05 IN THE ORPHAN'S COURT OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: KEVIN EARL HUTCHISON, Alleged Incompetent Person NO. c? I - 05 - oq J d- ('""'\ '-'''I r) EMERGENCY PETITION UNDER SECTION 5511 OF THE PROBA~E. ESTATES AND FIDUCIARY CODE TO ADJUDICATE A PERSON INCOMPETENT AND TO APPOINT A GUARDIAN OF HIS ESTATE Petitioners, Dawn E. Strock, Constance M. Hutchison and Norman Hutchison, by and through their attorney, Fiona K. Line, file this Emergency Petition to Adjudicate a Person Incompetent and to Appoint a Guardian of his Estate and in support thereof, state the following: 1. Petitioner, Dawn E. Strock, is an adult individual who resides at 47 Walnut Street, Carlisle, PA 17013; 2. Petitioner, Dawn E. Strock, is the girlfriend, of 15 years of Kevin Earl Hutchison, the alleged incompetent person, and the Mother of their two sons, Kevin E. Hutchison, Jr. ,age 10 and Jeremy R. Hutchison, age 9; 3. Petitioner, Constance M. Hutchison, is an adult individual who resides at 644 Baltimore Pike, Gardners, PA 17324; 4. Petitioner, Constance M. Hutchison, is the Mother of Kevin Earl Hutchison, the alleged incompetent person; 5. Petitioner, Norman E. Hutchison, is an adult individual who resides at 644 Baltimore Pike, Gardners, PA 17324; 6. Petitioner, Norman E. Hutchison, is the Father of Kevin Earl Hutchison, the alleged incompetent person; 7. Kevin Earl Hutchison is a 39 year-old single male who currently resides at the Holy Spirit Hospital located at 503 North 21st Street, Camp Hill, PA 17011; 1 r 8. Kevin Earl Hutchison, prior to his admittance to the Hershey Medical Center on August 15, 2005, lived with Petitioner, Dawn E. Strock at 47 Walnut Street, Carlisle, PA 17013; 9. Kevin Earl Hutchison was diagnosed with Guillian Barre Syndrome on August 16, 2005 by the physicians at Penn State Hershey Medical Center; 10.Kevin Earl Hutchison was place in an induced coma on August 16, 2005 and place on a ventilator at Penn State Hershey Medical Center; 11.Kevin Earl Hutchison was transferred to the Holy Spirit Hospital located at 503 North 21st Street, Camp Hill, PA 17011 on September 15, 2005; 12.Kevin Early Hutchison may be transferred to John Hopkins University Hospital in the near future; 13.The names and addresses of the next of kin of the alleged incompetent are as follows: a) Constance M. Hutchison - Mother 644 Baltimore Pike, Gardners, PA 17324 b) Norman E. Hutchison - Father 644 Baltimore Pike, Gardners, PA 17324 c) Edwina Rodriguez - Sister 644 Baltimore Pike, Gardners, PA 17324 d) Dori Bloser - Sister 206 North Enola Dr., Enola, PA 17025 e) Kevin E. Hutchison - Son 47 Walnut Street, Carlisle, PA 17013 f) Jeremy R. Hutchison - Son 47 Walnut Street, Carlisle, PA 17013 14.The alleged incompetent was not and is not a member of the Armed Services of the United States; 15.Petitioners state that the alleged incompetent, Kevin E. Hutchison is unable to receive and effectively evaluate information and communicate decisions and that he is unable to manage his money and/or other property, or make necessary 1 ' .. decisions about where he will live, what medical care he will receive and how his money will be spent; 16.The proposed guardian is Dawn E. Strock, is the alleged incompetent's girlfriend of 15 years and the mother of the alleged incompetent's two sons. Dawn E. Strock and Kevin E. Hutchison have cohabitated with each other for fifteen (15) years; 17.The proposed guardian, Dawn E. Strock has no interest adverse to the alleged incompetent; 18.No court has ever assumed jurisdiction in any proceeding to determine the competency of the alleged incompetent; 19.The alleged incompetent does not have a guardian already appointed; 20.Petitioners respectfully request a citation, directed to the alleged incompetent, with notice thereof to his next of kin and to such other persons as the court may direct, to show cause why he should not be adjudged an incompetent and a guardian of his estate appointed. (/ ,4/ ~~ ,/'--'-/~~, .. :...<... Fiona Kimberly Line Attorney for Petitioners Attorney ID #65283 184 Virginia Ave. Carlisle, PA 17013 (717) 991-1382 IN THE ORPHAN'S COURT OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: KEVIN EARL HUTCHISON, Alleged Incompetent Person NO. PROPOSED GUARDIAN'S WRITEN CONSENT TO THE APPOINTMENT I, Dawn E. Strock, consent to the appointment of Guardian of alleged incompetent person, Kevin Earl Hutchison and of his estate. ~(\ ~ \ \ '~'., "\<(x-.G'J"E~/ \ Dawn E. Strock IN THE ORPHAN'S COURT OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: Kevin Hutchison, an alleged incapacitated person NO. VERIFICATION We verify that the statements made in the foregoing Emergency Petition to Appoint a Guardian are true and correct to the best of our knowledge, information and belief. This Verification is made only as to the factual averments contained herein, and not to legal conclusions. We understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. i ~"J ~v ~'N~ ' J'-^.,~ '---" ~" I Dawn Strock - C~~ Connie Hutchison, Mother f~~ Edward Hutchison, Father I-~