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Home My WebLink About10-26-05 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION ,-.> --J IN RE: ESTATE OF WILLIAM JUMPER, AN INCAPACITATED PERSON No.21-05-147 ~".,' l ~'1 " ._1. MOTION TO INVADE PRINCIPAL TO THE HONORABLE, THE JUDGES OF SAID COURT The Petition ofIKOR, INC., duly appointed Guardian ofthe Estate of WILLIAM JUMPER, an incapacitated person, by it's Attorneys CAPOZZI & ASSOCIATES, P.c., respectfully represents as follows: 1. By Decree of the Honorable Judge J. Wesley Oler, Jr., dated September 8, 2005, IKOR, Inc. was appointed Guardian of the Estate of William Jumper, an incapacitated person. 2. WILLIAM JUMPER ("the incapacitated person") resides at Beverly HealthCare - Camp Hill, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Petitioner is in the process of preparing and filing the inventory of the incapacitated person's estate in accordance with the provisions of 210 Pa. C.S.A. ~ 552l(a)(i), which will reflect principal assets in an amount~n excess of $200,000.00. 4.Petitioner has secured approximately $176,000.00 of assets belonging ~o William Jumper which consists primarily of cash and certificates bf deposit. 2 --) , \ 5.The total annual income which Petitioner estimates will be received on behalf of the incapacitated person, including Social Security payments is currently unknown as Petitioner continues to gather financial information which had not been previously provided. 6. Petitioner currently knows that William Jumper receives $1.600.00 per month in Social Security income and there is an existing annunity 7.It is estimated that the care and comfortable maintenance of the incapacitated person will require annual expenditures of at least $60,000.00 8. Petitioner anticipates that the annual income available from all sources will be insufficient to maintain the incapacitated person and an annual invasion of principal will be necessary. 9. Petitioner has received a bill in the amount of$46,427.18 from Beverly Health Care Camp Hill for nursing home services provided to Mr. Jumper prior to, during and following the guardianship proceedings that must be paid immediately or Mr. Jumper is subject to being discharged for non~ payment on October 28, 2005. A copy of the bill is attached as Exhibit "A." 10. Petitioner has received a bill in the amount of $2,960.00 from Pharmerica for pharmaceutical supplies and services provided to Mr. Jumper during his stay at Beverly Health Care Camp Hill. A copy of the bill is attached as Exhibit "B." 3 11. Petitioner has also received a bill in the amount of $1,189.00 from James Flowers, Esquire, for services rendered to the incapacitated person during the emergency and plenary guardianship proceedings, which bill Petitioner wishes to pay from principal. A copy of Mr. Flowers' statement is attached hereto as Exhibit "C." 12. Petitioner is aware of the following services performed by James Flowers, Esquire, which were beneficial to the incapacitated person: a. Conferring with counsel for Beverly Health Care and the courts during these proceedings. b. Appearing at the emergency hearing at which Faith, Hope and Love Guardianship Services, Inc., was appointed Emergency Guardian of the Person of William Jumper. c. Appearing at the plenary hearing wherein Petitioner was appointed plenary guardian of the incapacitated person's estate and Faith, Hope and Love Guardianship Services, Inc., was appointed plenary guardian of the person. d. Serving as counsel to the incapacitated person. e. Investigating emergency and ongoing needs of incapacitated person. f. Conferring by telephone with the incapacitated person's physicians to confirm his need for various emergency and non- emergency medical services and making decisions on his behalf. 4 g. Visitation to the incapacitated person. 13. Petitioner has received a bill in the amount of $500.00 from Faith, Hope and Love Guardianship Services, Inc., duly appointed Emergency Guardian of the Person of William Jumper for the set up fee f6r emergency guardianship services and $300.00 for emergency guardianship services provided between February and April 2005. A copy of the bill ts attached as Exhibit "D." 14. Petitioner is aware of the following services performed by Failjij, Hope and Love Guardianship Services, Inc. which were beneficial to the incapacitated person during the emergency guardianship: a. Contact with doctors, surgeons, medical personnel, facility staff and Mr. Jumper's family concerning hospitalizatiobJ, surgery, and recovery. b. Visits to hospital and nursing home to check on him, ensure hiS comfort, arrange room change, and request specific care fot him as needed (ie., X-rays after fall, etc...) c. Making medical and care decisions on his behalf. 15. Petitioner has received a bill in the amount of $1,200.00 from Faith, Hope and Love Guardianship Services, Inc. duly appointed Plenary Guardian of the Person of William Jumper which consist of the set up fee of $500.00 and provision of guardianship services at $100.00 per month between May and October 2005. A copy of the bill is included at Exhibit, "D." 5 [' 16. Petitioner is aware of the following services performed by Faith, Hope and Love Guardianship Services, Inc., which were beneficial to the incapacitated person: a. Visiting Mr. Jumper at the nursing home and checking on his care, nutrition, and health. b. Contact with facility personnel. c. Contact with the family members and Mr. Jumper's girlfriend. d. Contact with medical personnel regarding proposed treatments. e. Contact with apartment personnel regarding the existing lease. f. Contact with IKOR, Inc. to arrange to inventory Mr. Jumper's assets. 17. Petitioner has received a bill from the Lebanon Veterans Administration Medical Center for $46.77 for prescribed medications. A copy ofthe bill is attached as Exhibit "E." 18. Petitioner's set up fee that has been approved by This Honorable Court is $500.00. 19. Attorney for Petitioner has contacted Mr. James Flowers, Attorney: for Mr. Jumper, concerning the filing of this motion and he concurs witni in the filing of this motion WHEREFORE, your Petitioner respectfully requests that this Honorable Court authorize IKOR, Inc., as Plenary Guardian of the Estate of William Jumper, to spend principal to the extent named herein for the care and comfortable maintenance of said incapacitated person; and further requests that this Honorable Court authorize 6 payment from the principal of the incapacitated person's estate to Beverly Health Care Camp Hill for nursing home services; Pharmerica for pharmaceutical supplies provided; the Lebanon VA Medical Center for medical services provided; Faith, Hope and Love Guardianship Services, Inc., for Emergency and Plenary Guardianship services provided; James Flowers, Esquire, for legal services he rendered aforesaid; Capozzi and Associate$, P.C. for the payment of the attorney's fees and costs related to filing this Motion; and IKOR, Inc., for guardianship set up fee. Respectfully submitted, ~6 rre/ taC CAPOZZI & ASSOCIA S, P.C. i/ /k,L. BY .I Michael B. V olk, Esquire Attorney for Petitioner Attorney LD. No. 88553 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 7 [' ~ ~ ~c ~~c ~rl~ ~ r-It~ r F=> r i e:>>~~ ACCOUNT NUMBER 91852 STATEMENT DATE 09/15/05 BEVERLY HEALTHCARE- Camp Hill 1500 Ard_ Blvd PITTsburg" PA Ul221 41Z-871-10g0 41Z 871 10<<) - - I NAME IACCOUNT NUMBE STATEMENT DATE William Jumper 191852 (] 9/15/05 DATE/PERIOD COVERED DESCRIPTION QTYIDAYS AMOUN 01/20f05 01/26/05 Room and Care charges 7 1. 020.67 01/27/05 01/31/05 Bed hold 5 570.00 02101/05 02/24/05 Bed hold 24 2,1736.00 02/25/05 02/28/05 Room and Care charges 4 781.29 03/01/05 03/31/05 Room and Care charges 31 5,193.25 04/01/05 04/30/05 Room and Care charges 30 5 051.10 " 05/01/05 05/31/05 Room and Care charges 31 ~. 39.05 06/01/05 06/30/05 Room and Care charges 30 ~. 20.72 07/01/05 07/31/05 Room and Care charaes 31 5i. 16.36 08/01/05 08/31/05 Room and Care charaes 31 51. 12.74 09/01/05 09/30/05 Room and Care charges 30 4 92.00 . 10/01/05 10/31/05 Room and Care charges 31 4, 92.00 , , , . , , ..........._. ..__. L-_..__ __. _ _,"...._.._____._.__._. PAYMENT DUE UPON RECEIPT i TOTAL AMT 46,4 27.18 .. . ...... .._...._-------_....._.~,.__..........._- i EXHIBIT i A [' CUSTOMER: WILLIAM T, JUMPER DATE: 08/31/05 FACILITY: BEVERL Y- CAMP HaL CARE CENTE ACCOUNT: 5702-01-1841 J PHARMERICA c:-... 491.A BLuE E.\GUi: AVE 'If' tlARlUSBt..1l.G,I'A 17112 PAGE: 1 ofl PREVIOUS $2764.01 PAYMENTS CREDITS: NEW $196.80 BALANCE $2960.81 BALANCE: RECEIVED: CHARGES: DUE:I DATE RX NUMBER DESCRIPTION QTY BlLLED DUE FROM I INSURANCE CHARGES/ AMT INSURANCE ADJUST CREDITS Balance Forward: 2764.01. OB/03/05 1227965.02 POTASSIUM CHLORIDE 10% LI 480.000 8.90 8.90 08/08/05 1253776.00 nIOVAN 80 MG TABLET 30.000 60.85 60.85 08/1.2/05 11.99405.03 TRAZODONE 50 MG TABLET 30.000 17.25 1.7.25 08/12/05 1227965.03 POTASSlrn~ CHLORIDE 10% LI 480.000 8.90 8.90 08/26/05 1227965.04 POTASSIUM CHLORIDE 10% LI 480.000 8.90 8.90 08/29/05 1185825.03 NOVOLIN R 100 UNITS/ML VI 10.000 34.60 34.60 08/31./05 1200979.01 LORAZEPAM 0.5 MG TABLET 30.000 22.80 22.80 08/31/05 1273004.00 NOVOLIN N 100 UNITS/ML VI 10.000 34.60 34.60 Amount Due: 2960.81 BILLING QUESTIONS: 08:30 AM - 05:00 PM PHONE: 800-352-9161 MEDICATION QUESTIONS: 09:00 AM - 04:00 PM PHONE: 717-651-9996 PAYMENT ~DRESS: P.O. BOX 6413 CAROL sTR.E.AM, a 60197-6413 1111111 Wlmlll I IIlII I 1111. II IIIIUI III 111101 PHARMEIDCA c;t PHARMERICA 491-A BLUE EAGLE AVE HARRISBURG. PA 17112 n Ple.... check box If address is Incorrect or insurance LJ InformetiDn has cheng8d, end indlcatll changll(sl on reverse side. 09/30/05 $2960.81 o AWERICAN !!l<Pf'lESS /ofT ru In IT" .,... ru c::I 0- .,... C C Ln 0:. LIJ 1TI Q ..... C ... 31111-UB17 II" I'AYlNQ lIY MASTERCARD. DISCoveR, VISA OR AMeRICAN EXPRI; S, FlU. OUT BI!:LOW. C:HFCK CABO USING FOR PI\YMI;Nl _ @""F.nwc _ ~COVER ::=. ~A CAMUN ':J~ RETURN SERVICE REQUESTED t;1::;NAluRL: CUSTOMER NAME: WILLIAM T. JUMPER DUE DATE PAY THIS AMOUNT ACCT. ... 111"111,..1,,"1111,,".1,111"1"11111,,"1"1111"1""1.1111.1"11,"1 WILLIAM T, JUMPER HOPE FAITH & LOVE GUARDIANSHIP P.O. BOX 2027 ATTN PAST. SLOAN HARRIBURG, PA 17105-2027 1.11..11""11111.1..1,"1111 11.1,,1,"11,,11"111111111.111111 PHARMERICA P.O. BOX 6413 CAROL STREAM, IL 60197-6413 31111-U8t7.1LROQVOV6006B35 , LROWX4EN: 1 . 1 5702010108040101002960810 EXHIBIT j ~ I' JOtl:\' E. SI.IKE ROBERT C. SAID/S GEOFFREY S. SU urr JAMES D. FLOWER. JR. CAROL]. LINDSAY BRIAN C. CAFFREY GEORGE P. DOUGLAS III MATTHEW J. ESHELMAN t THOMAS E. foLOWF.R jACLYN M. SMiTH SAlOIS, SHUFF, FLOWER & LINDSAY A PROFESSIONAL CORPORATION 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 243-6222 FACSIMILE: (7j 7) 243-6486 EMAIL: attorney@ssfl-law.com www.ssfl-Iaw.com CAMP HILL OFFICE; 2109 MARKE1' STREET CAMP HILL. PA 17011 TELl!PHONE: (71'7) 737.3405 FM:sIMIUl: (717) 737-3407 tlloanl Cc-rdnc'(\ Creditors' Righll'l Rt:pl"\.<tiCOntat.i\1l1 REPLY TO CARLISLE May 31,2005 Faith Hope and Love Guardian Services, Inc., 123 N. 13th Street Harrisburg, PA 17103 Our file# 7127 lnvoice# 23065 051109 EIN: 25-1694606 RE: William Jumper Balance forward as of invoice dated April 30,2005 Payments received since last invoice Accounts receivable balance carried forward $1,092.00 $0.00 $1,092.00 PROFESSIONAL SERVICES OS/27/2005 Return calls to Mr. Volk, call from Mr. Volk; telephone conference with Judge TOTAL FEES $97.50 ~EKEEPERFEERECAP Lawver Hours Amount Flower Jr, James D. 0.50 $97.50 EXHIBIT i_C 051109 Jumper, William lnvoice# 23065 Page 2 Billing Summary Total professional services Total of new charges for this invoice Plus net balance forward Total balance now due $97.50 $97.50 $1,092.00 $1,189.50 PRIVACY POLICY; During this rums representation of you, we may receive nonpublic, personal information from you or from sourccs about you. It is our policy tlIld practice that our attorneys and staff do not at any time reveal informatiolti relating to our rcpresentation of you unless you consent after consultation, except for disclosures that are impliedly authorized to carry out the representation. and except for disclosures required or authorized by the Pennsylvania Rules of Professional Conduct. Interest at 1 1/2% per month on unpaid balance after 30 days. I' FAITH, HOPE AND LOVE GUARDIAN SHIP SERVICES, Inc. 123 North Thirteenth Street Harrisburg, Pennsylvania 17103 (717) 233-5698 October 25, 2005 IKOR, Inc. Guardian of the Estate of William Jumper Re: William Jumper Invoice for Services to date Set up fee for serving as Emergency Guardian $500.00 Covers all pre-hearing activities including opening Emergency Guardianship file; interviews and contacts with attorneys, facility staff, physicians, surgeons, nursing personnel, apartment personnel, and family members and interested party; handling mail, making necessary personal and medical decisions; attendance at hearing, and visits to hospital and nursing home; reviewing medical records and legal documents; 24 hour per day availability; obtaining insurance and three months of guardianship services. $100.00 per month fee for serving as Emergency Guardian $300.00 (Feb - April 2005) Covers all contacts with physicians, surgeons, hospital personnel, facility personnel, hospice personnel; making necessary medical decisions; visits to Mr. Jumper at the hospital and Beverly Health Care; review of medical records, and discussions with family members. Set up fee for serving as Plenary Guardian of the Person $500.00 Covers all pre-hearing activities; opening permanent Guardian of Person file; review, revision and execution of legal documents. $100.00 Monthly fee for Serving as Plenary Guardian of the Person $700.00 (May - October 2005) Covers all post-hearing activities; interviews and contacts with attorneys, facility staff, physicians, medical staff, apartment personnel, family members, interested parties and IKOR; making necessary personal and medical decisions; and visits to nursing home; reviewing medical records and 24 hour per day availability. TOTAL $2,000.00 EXHIBIT I 0 FAITH, HOPE AND LOVE GUARDIAN SHIP SERVICES, Inc. 123 North Thirteenth Street Harrisburg, Pennsylvania 17103 (717) 233-5698 October 25, 2005 IKOR, Inc. Guardian of the Estate of William Jumper Re: William Jumper Invoice for Services to date Set up fee for serving as Emergency Guardian $500.00 Covers all pre-hearing activities including opening Emergency Guardianship file; interviews and contacts with attorneys, facility staff, physicians, surgeons, nursing personnel, apartment personnel, and family members and interested party; handling mail, making necessary personal and medical decisions; attendance at hearing, and visits to hospital and nursing home; reviewing medical records and legal documents; 24 hour per day availability; obtaining insurance and three months of guardianship services. $100.00 per month fee for serving as Emergency Guardian $300.00 (Feb - April 2005) Covers all contacts with physicians, surgeons, hospital personnel, facility personnel, hospice personnel; making necessary medical decisions; visits to Mr. Jumper at the hospital and Beverly Health Care; review of medical records, and discussions with family members. Set up fee for serving as Plenary Guardian of the Person $500.00 Covers all pre-hearing activities; opening permanent Guardian of Person file; review, revision and execution of legal documents. $100.00 Monthly fee for Serving as Plenary Guardian of the Person $700.00 (May - October 2005) Covers all post-hearing activities; interviews and contacts with attorneys, facility staff, physicians, medical staff, apartment personnel, family members, interested parties and IKOR; making necessary personal and medical decisions; and visits to nursing home; reviewing medical records and 24 hour per day availability. TOTAL $2,000.00 I' FAITH, HOPE AND LOVE GUARDIAN SHIP SERVICES, Inc. 123 North Thirteenth Street Harrisburg, Pennsylvania 17103 (717) 233-5698 October 25, 2005 IKOR, Inc. Guardian of the Estate of William Jumper Re: William Jumper Invoice for Services to date Set up fee for serving as Emergency Guardian $500.00 Covers all pre-hearing activities including opening Emergency Guardianship file; interviews and contacts with attorneys, facility staff, physicians, surgeons, nursing personnel, apartment personnel, and family members and interested party; handling mail, making necessary personal and medical decisions; attendance at hearing, and visits to hospital and nursing home; reviewing medical records and legal documents; 24 hour per day availability; obtaining insurance and three months of guardianship services. $100.00 per month fee for serving as Emergency Guardian $300.00 (Feb - April 2005) Covers all contacts with physicians, surgeons, hospital personnel, facility personnel, hospice personnel; making necessary medical decisions; visits to Mr. Jumper at the hospital and Beverly Health Care; review of medical records, and discussions with family members. Set up fee for serving as Plenary Guardian ofthe Person $500.00 Covers all pre-hearing activities; opening permanent Guardian of Person file; review, revision and execution of legal documents. $100.00 Monthly fee for Serving as Plenary Guardian of the Person $700.00 (May - October 2005) Covers all post-hearing activities; interviews and contacts with attorneys, facility staff, physicians, medical staff, apartment personnel, family members, interested parties and IKOR; making necessary personal and medical decisions; and visits to nursing home; reviewing medical records and 24 hour per day availability. TOTAL $2,000.00 FAITH, HOPE AND LOVE GUARDIAN SHIP SERVICES, Inc. 123 North Thirteenth Street Harrisburg, Pennsylvania 17103 (717) 233-5698 October 25, 2005 IKOR, Inc. Guardian of the Estate of William Jumper Re: William Jumper Invoice for Services to date Set up fee for serving as Emergency Guardian $500.00 Covers all pre-hearing activities including opening Emergency Guardianship file; interviews and contacts with attorneys, facility staff, physicians, surgeons, nursing personnel, apartment personnel, and family members and interested party; handling mail, making necessary personal and medical decisions; attendance at hearing, and visits to hospital and nursing home; reviewing medical records and legal documents; 24 hour per day availability; obtaining insurance and three months of guardianship services. $100.00 per month fee for serving as Emergency Guardian $300.00 (Feb - April 2005) Covers all contacts with physicians, surgeons, hospital personnel, facility personnel, hospice personnel; making necessary medical decisions; visits to Mr. Jumper at the hospital and Beverly Health Care; review of medical records, and discussions with family members. Set up fee for serving as Plenary Guardian of the Person $500.00 Covers all pre-hearing activities; opening permanent Guardian of Person file; review, revision and execution of legal documents. $100.00 Monthly fee for Serving as Plenary Guardian ofthe Person $700.00 (May - October 2005) Covers all post-hearing activities; interviews and contacts with attorneys, facility staff, physicians, medical staff, apartment personnel, family members, interested parties and IKOR; making necessary personal and medical decisions; and visits to nursing home; reviewing medical records and 24 hour per day availability. TOTAL $2,000.00 I' II 1700 S LINCOLN AVE LEBANON PA 17042-7597 ~ Department of Veterans Affairs Call Center 1-888-777-1383 STATEMENT OF MEDICAL CARE COST RECOVERY ACCOUNT ACTIVITY NAME OF FACILITY LEBANON VA MEDICAL CENTER (585) FOR QUESTIONS ABOUT YOUR ACCOUNT. PLEASE PHONE THE BELOW NO. 1-888-777-1363 For written Inqulr ell concerning your accRunt pease sen them to the MCCR. or Revenue uffice atl.the. tacilitG a dress above. or. infarmation rsgar'dlng ypur rights ana ob IgatJons 0 c arges owel2 the Unltcl2 5tates Government. please refer to paragraptlls) on l'everse oftfiis statement. - - !!! E 1...11111.111......1111111..1.1..11.11.....11..1..1.11....1.11 000164 051605 WILLIAM THOMAS ~UMPER BEVERLY HEALTHCARE ROON #213 (2ND FLOOR) 46 ERFORD RD ~AMP HILL PA 17011-2303 - ~ 5 Payments r-ece1ved after- 05/12/200!S wi 11 be on your- next statement. == i!Il!ii!; - - iiii - NEW PHONE NUMBER FOR QUESTIONS IS 1-866-777-1363 ::J:~]~I~f~f~~~~;~~}~~i~~~f!~]R1~f;~r~~~~;~~jJ1~ {~8~i~tfi; INTEREST/ADM. CHARGE (Int:O.04 Adm:1.55 Dther:O.OO Please refer to previous statement of rights. 1.59 EXHIBIT i E SUMMARY OF ~f.19~.@',Ili:~~:: ::!!:!ii~;:::g~I~I~[:l!~AAIR;.i. '::~~~;::~~~~~i;:~:~il jl:~:'~~~iiiil~~~:;::" ................... ,. MONTHLY ACTIVITY 4& . 18 .00 1 .59 48. 77 .. ........".......P.lEASE...DET.Al:I:t..lliIS..COOP.!lN...BELD.W..AMI...RE1U8llI...WJJI:t..P.l\YMENI......DD...N.aI..lNCLUDE..ANY... CORBESP.ONOENCE...WJJH..P.l\YMENIIi ................................ ~ ACCOUNT NUMBER STAT'ElMENT DATE ~ ~ 5e5-00000oo0-13580-~UMPE OSI 8/2005 tNAME OF CREDIT ARD ] ~E:~~~N 0 ~SciER 0 DISCOVER D VISA 5 9 5 * * 5 9 5 0 0 0 0 0 0 0 0 13 5 a 0 J U M P E * * * 000 000 (j] 0 0 Lf b 7 7 7 -SIGNATURE Remit To: ~DUNT DUE CUE DATE *AMOUNT OF PAYMENT DUE UPON $ 46.77 RECEIPT $ WILLIAM THOMAS ~UMPER BEVERLY HEALTHCARE ROOM #213 (2ND FLOOR) 48 ERFORD RD CAMP HILL PA 17011-2303 FORM . 2002 0246 1..11.11.....11..1.111.11.11.....1.1.11..1.1...11. .1.1...11111 DEPARTMENT OF VETERANS AFFAI~ PO BOX 530289 ATLANTA GA 30393-0289 I paying by check or money order please make payable to III "VA" and send include accoul'lt number on check. . '. . i CCPI CERTIFICATE OF SERVICE .I ..J;/'/ ..., ~ ryff AND NOW, this 'J.-.6 day of .. ,2005, I hereby certify that I have served the foregoing Motion to Invade Principal of the Estate of William Jumper a trUe and correct copy of same in the United States mail, postage prepaid, addressed to: James D. Flowers, Esq., 26 West High Street Carlisle, P A 17013 Helen Kocher, 57 A Allenda1e Road Mechanicsburg, P A 17055 Andrea Metzger 206 North Division Street Apartment 5 Ocean City, MD 21842 Toni Blair, Executive Director 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, Guardian of William Jumper 123 North 13th Street Harrisburg, P A 17103 IKOR, Inc. A TTN: Mrs. Patricia Maisano 696 Unionville Road Kennett Square, P A 19348 ,/b (ht't if Date: October )8; 2005 "jt 1 I I L~ Vl/\'"\ ,_ L/ . 8