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F\FlLES\DA T AFILE\General\CuITent\ 12096.I.mot 1
Created: 9/20/04 0:06PM
Revised: 5/22/06 11: 13AM
120961
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George B. Faller, Jr., Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
J.D. No. 49813
10 East High Street
Carlisle, PAl 70 13
(717) 243-3341
Attorneys for Virginia M. Taylor
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INRE: VIRGINIAM. TAYLOR
ALLEGED INCAP ACIT A TED PERSON
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 435 of2006
ORPHAN COURT DIVISION
MOTION TO OBTAIN MEDICAL RECORDS
1. The undersigned counsel has been appointed to represent Virginia M. Taylor, an allegedly
incapacitated person.
2. A hearing has been set for Tuesday, May 23,2006, at 9:30 a.m., before the Honorable
Merle Ebert.
3. In order to evaluate the validity of the Petition, counsel will need to review Mrs. Taylor's
medical records.
4. The easiest way to obtain these records is for the Court to Order their production.
5. Dr. Julienne Fahnestock was Mrs. Taylor' s (date ofbirth July 10, 1930) family physician.
6. Stephen J. Hogg, Esquire, counsel for the Petitioners, concurs in the request.
WHEREFORE, counsel requests that the court order Dr. Fahnestock's records custodian to
appear at the hearing on May 23, 2006, at 9:30 a.m., in courtroom number 5. In the alternative, Dr.
Fahnestock's records custodian may fax a certified copy of the medical records to counsel by4:00p.m.,
on May 22, 2006.
Date: May 22, 2006
By
George Baller, Jr.,
J.D. No. 49813
10 East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Virginia M. Taylor
CERTIFICATE OF SERVICE
I, Melissa A. Scholly, an authorized agent for Martson Deardorff Williams & Otto, hereby certify
that a copy of the foregoing Motion to Obtain Medical Records was served this date by depositing same
in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows:
Stephen J. Hogg, Esquire
LAW OFFICES OF STEPHEN J. HOGG
19 South Hanover Street
Suite 101
Carlisle, P A 17013
MARTSON DEARDORFF WILLIAMS & OTTO
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Melissa A. Scholly
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Dated: May 22, 2006
George B. Faller, Jr., Esquire
MARTSON DEARDORFF \VILLIAMS & OTTO
J.D. No. 49813
10 East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Virginia M. Taylor
INRE: VIRGINIAM. TAYLOR
ALLEGED INCAPACITATED PERSON
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 435 of2006
ORPHAN COURT DIVISION
ORDER
AND NOW this 22nd day of May, 2006, Dr. Julienne Fahnestock is ordered to have a records
custodian appear on Tuesday, May 23,2006, at 9: 30 a.m., in courtroom number 5, in the Cumberland
County Courthouse. In the alternative, a certified copy ofthe records can be faxed to Attorney George
B. Faller, Jr., at 717-243-1807, by May 22, 2006, at 4:00 p.m.
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Judge M.L. Ebert, Jr.
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