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Home My WebLink About05-01-06 .. IN RE: CONSTANCE M. MEREDITH : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYL VANIA : ORPHANS' COURT DIVISION An alleged incapacitated person : NO. 06-0294 On the Petition of WILLIAM J. MEREDITH MOTION FOR CONTINUANCE AND NOW, comes Marielle F. Hazen, Esquire, of the Law Office of Marielle F. Hazen, to request this Honorable Court to reschedule the hearing in the above matter currently set for May 15,2006 at 1:00 p.m., to the next available date on the Court's calendar. Respectfully submitted, ~00 Date B{: t!Jl~q. Attorney for Petitioner PA J.D. #68003 2000 Linglestown Road, Suite 202 Harrisburg, P A 17109 (717) 540-4332 "0 ,-'~I ~ ..., I! 1 \ - ,1,\J',.1 SOUl Q ',' 'c]. . . ..I .{, v, :,: I,: , ; ,...,~ ,_ i "n-' i .1J.....I. , ''', u-! ,I,.;, ,I i-1tj :J \JJiJ j,",~VV J - C-' MAY-10-2006 02:36 PM MARIELLE_HAZEN.ATTORNEY 717 540 4313 P.0 IN RE: CONSTANCE M. MEREDITH : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : ORPHANS' COURT DIVISION An alleged incapacitated person : NO. 06-0294 On the Petition of WILLIAM J. MEREDITH MOTION FOR CONTINUANCE AND NOW comes Petitioner, William J. Meredith, by and through his counsel, Madelle F. Hazen, Esquire, and requests a continuance of the hearing in the above matter currently set for May 15,2006 at 1:00 p.m. and in support hereof, avers as follows: I. A Petition for Appointment of Guardian of the Person and Estate of an Alleged Incapacitated Person was filed on April 3, 2006 under File No_ 06-0294. 2. By Order of Court dated April 7,2006, a hearing datc was scheduled for May 15, 2006 at 1:00 p.m. 3. Constance M. Meredith, the alleged incapacitated person, is a patient at the Danvillc State Hospital, 200 Statc Hospital Drive, Danville, Pennsylvania 17821. The guardianship is necessary to access Constance M. Meredith's assets to be used to pay for her care at the Danville State Hospital. Constance M. Meredith cannot qualify f()r public benefits to pay for her care until her resources have been depleted. 4. Until recently, Constance M. Mcrcdith'~ primary treating psychiatrist at the Danville State Hospital was Conrada Ola, M.D. Dr. Ola had agreed to provide testimony for the guardianship proceeding. 5. In April 2006, attorney tor Petition!"", Mnrielle F. Hazen, Esquire, attt.."IIlpted to ~AY-10-2006 02:37 PM MARIELLE_HAZEN,ATTORNEY 717 540 4313 P.04 contact Dr. 01a to schedule her deposition in preparation for the hearing in this matter. Attorney Hazen was infonned that Dr. 01a is no longer employed by the Danville State Hospital. Constance M. Meredith's new treating psychiatrist is Wieslawa Kaccanowska. M.D. 6. After several attempts to reach Dr. Kaccanowska, Attorney Hazen's office was advised that Dr. Kaccanowska was not able to provide testimony prior to the May 15, 2006 hearing date because she had not yet reviewed Constance M. Meredith's records and had not had an opportunity to evaluate Mrs. Meredith'~ mental capacity. 7. Dr. Kaccanowska's testimony regarding mental capacity is necessary for this proceeding. 8. Petitioner requests that the hearing in this matter be continued to allow time tor Dr. Kaccanowska to evaluate Constance M. Meredith and provide medical testimony for the court proceeding. Constance M. Meredith must receive twenty days advance notice of the hearing date, so Petitioner requests that the new date allow time fOT the Order of Court to be served not less than twenty days before the hearing date. WHEREFORE, Petitioner requests this Honorable Court to enter an Order continuing the hearing in this matter to allow Dr. Kaccanowska the opportunity to evaluate Constance M. Meredith and to provide medical testimony regarding her capacity. Respectfully submitted, S -- I ~ -- tJ & Date B't/'l )~ Marfelle F. zen, sq. Attorney for Petitioner PA LD. #68003 2000 Linglestown Road, Suite 202 Hl1rrisburg, PAl 71 09 (717) 540-4332 -' . .~.~ ~ "'-L-L-<::'_MRLI::.N, ATTORNEY 717 540 4313 P.0 IN RE: CONSTANCE M. MEREDITH : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : ORPHANS' COURT DIVISION An alleged intapacitated penon : NO. 06-0294 On the Petition of WILLIAM J. MEREDITH VERIFICATION I verify that the statements made in this Motion are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA.e.S. ~ 4904, relating to unsworn falsification to authorities. .,~~/~ WTLT.1AM.I_ MF.TU~n'T" MAY-10-2006 02:35 PM MARIELLE_HAZEN.ATTORNEY 717 540 4313 P.01 2000 L1nglestown Road, Suite 202 Harrisburg, PA 17110 (717) 540-4332 (717) 540-4313 FAX Law Office of Marielle F. Hazen Fax To~ Attn:$andy Hon. Edward e. Guido From: Cathy Semon, for Marielle F. Hazen, Esq. FIUG 717-240-6462 D.te~ May 10, 1006 Phone: 717-240-6290 Paglts: 5, Including Cover Sheet ReI Guardianship of Constance Meredith cc: File No. 06-0294 . Ulpint . 'or Revl.-w . PI.... Comment + P"'_ Reply . .......~.. .Commenb: Following is Mr. Meredith's Motion for Continuance re the hearing scheduled for 1 :00 p.m. May 15,2006. Hard copy to follow this date via U.S. Mail. Thank you for your time and assistance in this matter. If you have any questions, please do not hesitate to contact our office. Cathy Semon Paralegal CONFIDENTIALITY NOTICE: This facsimile contain.. confidential information which is legally privileged. This facsimile is intended only flIT the use of du! addressee(s) named abow!. q you are not the addre..f.fee, or the per.flln responsible fllr delivering it to the addre.,see, you aN hereby notlfl<<J that any dissemination or copying of this facsimile, or tire taking of any action In reliance on the content.. 0/ this facsimile b' sttictly prohihited. If you have received this facsimHe in el'l'O', plellSt immediately notify the .fentkr by telephone to arrange/or retU"H (ifthla/tlCSimilt! 10 us. Thankyou.