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HomeMy WebLinkAbout05-19-06 LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 IN RE: HOWARD J. TAYLOR ALLEGED INCAPACITATED PERSON : COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA ~ ORPHAN COURT DIVISION : NO.: (t1- 4Jfc. PETITION FOR EMERGENCY PLENARY GUARDIANSHIP The undersigned brings this Petition through their Attorney, J Stephen J. Hogg, Esquire, seeking appointment for Plenary j Guardianship of Howard J. Taylor alleging the following: 1. The Petitioner's are Cheryl E. Watson, niece of the afleged (.II I 1 incapacitated person, residing at 6203 Catherine Street, Harrisburg, Pennsylvania 17112 and the alternate Petitioner is Sandra L. Nye, niece of the alleged incapacitated person, residing in Red Cliff, Colorado. Petitioner and alternate Petitioner have no interest adverse to the alleged incapacitated person and seeks appointment as Plenary Guardian and alternate Plenary Guardian to ensure the alleged incapacitated person's continued physical and mental health treatment. 2. The alleged incapacitated person is Howard J. Taylor born August 3, 1926 and whose last known address is 510 Appalachian Avenue, Mechanicsburg, PA 17055. \ ~~ ,/'\ LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 3. The alleged incapacitated person is married and has an adopted son: Virginia M. Taylor, wife (incapacitated) 510 Appalachian Avenue Mechanicsburg, PA 17055 James Taylor, son Address/location unknown No contact 4. The alleged incapacitated person is currently being treated by Dr. Dukkipatti, 975-8585. 5. The alleged incapacitated person has been diagnosed by Dr. Dukkipatti as having Alzheimer's. 6. The Petitioner and alternate Petitioner allege that the alleged incapacitated person has shown himself to be unable to adequately care for his own needs and would likely not pursue any physical or mental health treatment as prescribed by Dr. Dukkipattii. 7. The Petitioner and alternate Petitioner request that they be appointed Plenary Guardian and alternate Plenary Guardian of the alleged incapacitated person to assure continued needed physical and mental health treatment and over the estate of the alleged incapacitated person to ensure that the alleged incapacitated person does not waste or squander his estate. 8. The Petitioner and alternate Petitioner allege that they are the most qualified individuals to be appointed Plenary Guardian and LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 alternate Plenary Guardian of the alleged incapacitated person having his best interests in mind. 9. The Petitioner and alternate Petitioner seek appointment as Plenary Guardian and alternate Plenary Guardian of the alleged incapacitated person only so long as the alleged incapacitated person is determined by his treating doctor, Dr Dukkipatti, to be unable to take care of his own needs. 10. The Petitioner and alternate Petitioner estimate that the gross value of the alleged incapacitated person's estate is $270.000.00. 11 . Petitioner and alternate Petitioner seek appointment as Plenary Guardian and alternate Plenary Guardian of the alleged incapacitated person's estate and of his person. Respectfully Submitted, Stephen J. Ho squire Attorney for P . oner and Alternate Petit" ner Date: $ VERIFICATION I verify that the statements made in this Petition for Plenary Guardian to the Court of Common Pleas of Cumberland County, Pennsylvania, are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Section 4904, relating to unsworn falsifications to authorities. Date: ~l J'/.; tlM(P C~t~~ VERIFICATION I verify that the statements made in this Petition for Plenary Guardian to the Court of Common Pleas of Cumberland County, Pennsylvania, are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Section 4904, relating to unsworn falsifications to authorities. Date: --(1;1 /7 ~o& S=~ ------- Sandra L. Nye 7ERST Fax: 7177632"7.91 " May 17 2006 13:39 P.14 'j~l/ ,.. r" ;1. ' I M 79 Text Results MS8W / 840 01 CAR Pt#: 27655232 u Isol: s Mr#: ~84477 I I CONSULT DATE/TIME 05/10/06 11:40 STATUS: F I i ,i, ,I ADM. DATE: 04/29/2006 SS #: 171-20-9176 I I I OR CONSULTATION: Confusion. -~~~~-------~--------~~~---------~------~-~--------~~---------~-~--- OF PRESENT ILLNESS: The patient is a 79 year-old man who was to the hospital on 04/29/06 with volume depletion, congestive ilure, and acute:renal insufficiency. During the course of the ization, the patient has been noted to be confused. No 108s of aneae or convulsive 'activity has been reported. The patient denied headaches, vision loss, focal weakness, or paresthesias. lCAL HISTORY: Congestive heart failure, coronary artery disease, artery bypass surgery, atrial fibrillation, reD placement, benign c hypertrophy, and hyperlipidemia. ONS: Noted and reviewed in the chart. s: None known. ISTORY: The patient is retired and is married. He does not smoke ISTORY: Noncontributory. F SYSTEMS: Noted and reviewed in the chart. EXAMINATION: 9ns: Noted and reviewed in the nursing record. The patient is observed to be in no acute distress. He appears his stated age. Ie: The patient is awake, alert, and oriented x person, place, and year... He is somewhat slow to respond at. times 1 i. e. dec reased spontaneity. Speech is fluent. Attention is fair.. Memory is, fair. Pupils are equally. reactive. Extraocular movements are full without nystagmus. visual fields are ful 1 to confrontation. Funduscopy is not performed. Facial. sensation is normal. Facial symmetry is preserved. Tests of hearing are grossly normal. Gag and palate elevation are 8ym~etric. Tongue protrusion is midline. Motor examination reveals 5-/5 strength throughout with normal tone and bulk~ There is po drift or tremor noted. Deep tendon responses ar ! , I. I ~ 3757 13:15 05/17/06 FROM @OOG,ZRPRTGF2 I I I ! ~ I ! ' , : I 7EAST Fax: 71776327.91 'I May 17 2006 13:39 P.15 Results D J I ANDREAS U 29/06 IA Text Results . MS8W I 840 01 CAR 79 M pt#: 27655232 Mr#: 284477 Isol: S CONSULT DATE/TIME 05/10/06 11:40 STATUS: F ;, I I I I MPRE S I I 1. !P 2. is 3. Ie 4. fA I 5. iH I I ! e 1+, symmetric, with down~going plantars bilaterally. Gait is not tested. Coordination is good. No neck bruits are heard. ON: obable mild cognitive impairment. perimposed encephalopathy secondary to cardiac and renal issues. ronary artery disease. rial fibrillation. erlipidemia. is a 79 year-old man with likely cognitive impairment/early well as superimposed metabolic encephalopathy. A CT of the obtained. An EEG will be obtained. B12, folate, -and TSH lab 1 be obtained. He will likely be placed on Aricept. Social is involved in terms of discharge disposition and home care ents. u again for the consultation. Signed RAVI DUKKIPATI, MD 05/11/2006 15:0 9 RD/c DOC D: 0 T: 0 0000 cc: RAVI DUKKIPATI, MD 644295 6/2006 0/2006 11:40 A 90 VI DUKKIPATI I 'MD REAS U. WALI I MD 3757 13:15 05/17/0S FROM @OOGrZRPRTGF2 I' i ' ! I, I : 1 :' 'I I :! , :11' '\ ;1 : " illl 7EAST Fax: 71776327.9111 ~ May 17 2006 13:39 P.16 f . .. l Results J I ANDREAS U 29/06 IA Text Results MS8W / 840 01 CAR 79 M pt# :' 27655232 1801: S Mr#: 284477 ~~~-----------~~-------------------------~~-~------------~-~~------- DATE/TIME 05/08/06 19:27 STATUS: F By: e Diagnosis: Tracing: x Dr.wali Confusion er: f Tracing: Electrode: on: Routine 22 disc, 1 EKG, Tl and T2 PS only None The patient is a 79 -year-old man with history of confusion. consisted of awake and sleep portions. The awake background d of a fairly well-developed 6-7 Hertz medium amplitude activity seen symmetrically in both posterior head regions. This d was rhythmical and-reactive to eye movements. Beta activity in the frontal chains symmetrically 6 Stage I sleep was recorded wing of the underlying background noted. No epileptiform es were seen. Hyperventilation was' not performed 6 Photic ion failed to produce any significant changes in the EEG. ON: Abnormal (awake and sleep). This BEG suggests a mild diffuse opathy. No epileptiform discharges are seen. Clinical correlation ed. il :11 2:51 P 7:27 P IPATI, MD 05/11/2006 15:09 IPATIJ MD 'I ,j 1 ~I 1/ i 315B 13:15 05/17/06 FROM @OOG,ZRPRTGF2 7EAST Fax: 7177632791 '. Ma~ 17 2006 13:40 P.l? ~ . ~ . Results J I ANDREAS U 29/06 IA M 79 Text Results MS8W, / 840 01 CAR Isol: S pt#: 27655232 Mr#: 284477 ----~-~-------------------------~~---~~------------------------~--~- CT BRN WOCON DA.TE/TIME 05/06/06 13:51 - 05/06/2006 STATUS: F CT BRAIN WO CTRS 70450 Exam: Unenhanced cranial CT Altered mental status, confusion Routine unenhanced images were obtained from the skull base to ex. bilateral physiologic basal ganglia calcification. There is prominence of the ventricles with moderate periventricular white ypoattenuation consistent with chronic small vessel ischemia. moderate cortical atrophy. ed is a small area of left occipital hypoattenuation consistent or infarct. , , I ~ of subdural, epidural, or intracerebral hematoma or one windows, the visualized paranasal sinuses are clear. There is opriate atherosclerotic change at the base of the brain. There is nee of skull fraoture. Impression: are age~appropriate senescent changes. There is also moderate ricular white matter hypoattenuation4 evidence of a small area of prior left occipital infarct. no evide~ce of acute hemorrhage or midline shift. BY:RICHARD MOSER M.D. / PSC EXAM: 05/06/2006 759 13:15 05/17/06 FROM @OOGtZRPRTGF2 .1 I '11 ~\I\,. .1 :il ; ,I illl