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HomeMy WebLinkAbout03-15-06 In re: DAVIDF.HECKENDORN An alleged incapacitated person : IN THE COURT OF COMMON PLEAS OF : OF CUMBERLAND COUNTY, PENNSYL VANIA : ORPHAN'S COURT DIVISION : NO. 21-06-0155 : GUARDIANSHIP- INCAPACITATED PERSON MOTION FOR CONTINUANCE AND NOW, comes David F. Heckendorn, by and through his attorney, Leslie A. Tomeo, Esquire, and in support of this Motion avers as follows: 1. The above-captioned case was listed for a hearing for appointment of permanent guardian on March 22, 2006. 2. Attorney Nathan Wolf and the undersigned counsel have agreed that additional matters, including but not limited to, the independent evaluation has not yet taken place and Defendant's medical records are not currently available for review by Dr. Hume, must be addressed prior to the hearing. 3. This case has not been previously continued. Wherefore, Defendant respectfully requests that the above-captioned case be continued for thirty (30) days. Respectfully submitted, L"{~~ Rominger, Bayley & Whare 155 South Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court ill # 200198 I 0 : f II,JV c: t ~'::u "'","., -.I \,.j t rJ )u!Jt In re: DAVlDF.HECKENDORN An alleged incapacitated person : IN THE COURT OF COMMON PLEAS OF : OF CUMBERLAND COUNTY, PENNSYLVANIA : ORPHAN'S COURT DIVISION : NO. 21-06-0155 : GUARDIANSHIP- INCAPACITATED PERSON CERTIFICA TE OF SERVICE I, Leslie A. Tomeo, Esquire, attorney for Defendant, do hereby certify that I this day served a copy of the Motion For Continuance upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Nathan Wolf, Esquire Wolf& Wolf 10 W. High Street Carlisle, P A 17013 Dated: 3/1 r/ (J (; Le~~ Attorney for Defendant In re: DAVID F. HECKENDORN An alleged incapacitated person : IN TIIE COURT OF COMMON PLEAS OF : OF CUMBERLAND COUNTY, PENNSYL VANIA : ORPHAN'S COURT DIVISION : NO. 21-06-0155 : GUARDIANSHIP- INCAPACITATED PERSON VERIFICATION LESLIE A. TOMEO, ESQUIRE, states that she is the attorney for Defendant, David F. Heckendorn, in this action; that she makes this affidavit as attorney because she has sufficient knowledge or information and belief, based upon her 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: g/,>!q I