HomeMy WebLinkAbout11-22-05
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL VANIA
IN RE: MARY DUGAN,
An Alleged Incapacitated Person
ORPHANS COURT DMSION
NO. 21 - 05 - 380
RESPONSE TO PETITION TO CHANGE PERMANENT PLENARY
GUARDIAN OF ESTATE
AND NOW comes Mary Dugan, by and through her court-appointed counsel, James I.
Nelson, Esquire, and submits the following response to the petition submitted bhthe Area ~
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1. Admitted. C) .....~
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2. Admitted. (~ ""'D
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3. Admitted. (..:> II"
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4. Admitted.
5. Admitted.
6. Admitted.
7. Admitted.
8. Admitted.
WHEREFORE, your Respondent agrees that the Court should revoke the appointment
of Pennsylvania Guardianship Association as Permanent Plenary Guardian of the Estate of
Mary Dugan and appoint Keystone Guardianship Services as Permanent Plenary Guardian of
the Estate of Mary Dugan.
elson, Esquire
.D. No. 91144
ROMINGER, BAYLEY & WHARE
155 South Hanover Street
Carlisle, PA 17013
Tel: (717) 241-6070
Fax: (717) 241-6878
v 7:,:
VERIFICATION
James 1. Nelson, Esquire, states that he is the attorney for Mary Dugan in the instant
matter; that he makes this affidavit as attorney because he has sufficient knowledge or
information and belief, based upon his investigation of the matters averred or denied in the
foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S.
Pa.C.S. ~4904, relating to unsworn falsification to authorities.
Date: 11/2212005
CERTIFICATE OF SERVICE
AND NOW, this 22nd day of November, 2005, I, James I .Ne1son, Esquire, hereby
certify that I have this day served the following person with copies of the foregoing Response via
USPS First Class Mail and, also, facsimile:
Anthony L. Deluca, Esquire
113 Front Street
Boiling Springs, P A 17007
(717) 258-3902
Mark E. Halbrunner, Esquire
10 13 Mumma Road, Suite 100
Lemoyne, PA 17043 -1144
(717) 731-9627
, BAYLEY & WHARE
ames 1. 1son, Esquire
mey ID No. 91144
155 South HanoverStreet
Carlisle, PA 17013
(717) 241-6070