The URL can be used to link to this page

Home My WebLink About05-11-06 IN THE COURT OF COMMON PLEAS - CUMBERLAND COUNTY ORPHANS' COURT DIVISION IN RE: JOSEPH M. FELDISH, SR. An Alleged Incapacitated Person O.C. No. ;J 1-()(o-OLf\\ Phllll0N UNDER ~ 5511 OF THE PROBATE, ESTATES AND FIDUCIARIES CODE TO ADWDGE JOSEPH M. FELDISH, SR. TO BE TOTALLY INCAPACITATED AND APPOINT A PERMANENT PLENARY GUARDIAN FOR HIS PERSON AND ESTATE AND NOW, COMES, Petitioner, Country Meadows Associates d/b/ a Country Meadows of West Shore, by and through its attorneys, SCHUTJER BOGAR LLC, and hereby petitions for adjudication of incapacity and appointment of a permanent plenary guardian of the person and estate of Joseph M. Feldish, Sr., and, in support thereof, represents as follows: 1. The name of the alleged incapacitated person is Joseph M. Feldish, Sr. 2. Joseph M. Feldish, Sr. is a 76 year old widower who currently resides at Country Meadows Associates d/b/ a Country Meadows of West Shore, a personal care facility located at 4837 East Trindle Road, Mechanicsburg, P A 17050. 3. V]Pelj.tjoner, a Pelll1sylvania corporation, is a licensed personal care home. - /; IV 6 S : I Ud 11 ! \-', ! on'!., ht~"t)UU~ c ~; I ...;, ro{,,:~~} ~/.'l(J ~!~ /.....i..li---I' ',,...,.....\_.,, -'v j'Ji...J.J',j UJ !.~:; i' ;"'-1 - .-.....J--.J......'\.J_.. 4. Because the alleged incapacitated person resides in Cumberland County, this Court has Jurisdiction pursuant to S 711(10) of the Probate, Estates and Fiduciary Code and S 5512(a). 5. Upon information and belief, Joseph M. Feldish, Sr. has one living heir who is sui juris. His name and address are: Joseph M. Feldish, Jr. 212 Market Street Halifax, PA 17032 6. Petitioner is unaware of the value of the alleged incapacitated person's estate. 7. The estimated monthly income of the alleged incapacitated person is unknown to Petitioner. 8. The alleged incapacitated person's treating physician is: Dr. Supriyo Ghosh Burick & Azizkhan Internal Medicine Associates 888 Poplar Church Road Camp Hill, P A 17011 (717) 724-2126 9. Joseph M. Feldish, Sr., the alleged incapacitated person, has been diagnosed by Dr. Ghosh as suffering from dementia and Parkinson's. Said mental conditions have caused his incapacity and requires that he receive 24-hour-a-day care. 10. Because of the mental conditions set forth in paragraph 9, Joseph M. Feldish, Sr., the alleged incapacitated person, is totally unable to manage or even 2 appreciate the significance of his personal and financial affairs and to make and communicate any decisions relating thereto, including the ability to communicate his need for assistance in these areas. 11. Presently, Joseph M. Feldish, Sr., does not have an agent, guardian, or willing next of kin to appropriately manage his personal or financial affairs. 12. There are no less restrictive alternatives to the appointment of a permanent plenary guardian of the person and estate of the alleged incapacitated person. 13. The proposed guardian of the alleged incapacitated person is Good News Consulting, Inc., located at 783 Priority Road, York, Pennsylvania 17404. Good News Consulting, Inc. does not have any adverse interest to the alleged incapacitated person and an acceptance to serve as guardian of the person and estate is attached hereto as Exhibit II A." 14. Good News Consulting, Inc. has been suggested as guardian of the person and estate of Joseph M. Feldish, Sr. because of its vast experience in dealing with incapacitated persons such as him. 15. No Court within this Commonwealth, of which Petitioner has knowledge, has appointed a guardian for Joseph M. Feldish, Sr. 16. Upon information and belief, Joseph M. Feldish, Sr. was not a member of the Armed Service of the United States and, therefore, is not receiving any benefits from the United States Veterans' Administration. 3 WHEREFORE, your Petitioner prays that a citation be issued to Joseph M. Feldish, Sr., to show cause, if any there be, why he should not be declared an incapacitated person and Good News Consulting, Inc. appointed permanent plenary guardian of his person and estate. Respectfully submitted, SCHUTJER BOGAR LLC Dated: i./ &{ /4 b By: Ql.. J. cJ, ~ r Chadwick O. Bogar ~ Attorney 1.0. No. 83755 Kirk S. Sohonage Attorney 1.0. No. 77851 305 N. Front Street, Suite 401 Harrisburg, PA 17101 (717) 909-8160 Attorneys for Petitioner 4 5- 4-06; 4:45PM;Count~y Meadows MAY-02-2006{TUE) 16:42 ;7179752118 # 7/ 8 P. 006/007 VERIFICATION The undersigned hereby verifies that the statements of fact in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the penalties contained in 18 Pa. C. S. S 4904, relating to unsworn falsification to authorities. Dated: 5H--Of ~cu-l, /Ie ~rez;;hr .05/08/2006 10:24 7178463878 MFI.:t-1)2-~OI)b( iUU I~;,~ GOOD NEWS CONSULTING PAGE 02 1 , VVY' .I"~' A.CCEPT ANCE OF PROPOSID PDMANENT PLENARY GUARDIAN Cood News Consultir1g, JI'I(. the gl1udian of the person and "tate proposed in the foregoing petition for appointment of a permanE nt plenary guardian ot Joseph M. Feldish, Sr., the aUeged incapacitated pe1"SO", agree! to accept the appointment ., permanent plenary guardian and aVer& that: 1. The proposed gua:rdian is Good NeW! Consulting, Inc., which iI currently handling numerous guardIanship matters similar to Joseph M. Feld.ish, Sr. 2. Good News Coneulting, Inc. is not a f :dud.iuy of an estate in which the alleged inc:apacitabld person has an interest, a.nd. tile proposed permanent guardian Df Joseph M. Feldish, Sr. ha:~ no int.,CPts adverse to him. Dated~ 5)~JCCp , rJ;1f!-~~ Tina Hess, IS, CMC, RG.NGF V i~ e President of Operations of ec!od News Consultiftg. Inc.