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Home My WebLink About10-02-06 .... , IN THE COURT OF COMMON PLEAS - CUMBERLAND COUNTY ORPHANS' COURT DIVISION IN RE: ROSA L. THOMPSON, An Alleged Incapacitated Person O.C.No. Dl9- ()~~ PETITION UNDER & 5511 OF THE PROBATE, ESTATES AND FIDUCIARIES CODE TO ADJUDGE ROSA L. THOMPSON TO BE TOTALLY INCAPACITATED AND APPOINT A PERMANENT PLENARY GUARDIAN FOR HER PERSON AND ESTATE AND NOW, COMES, Petitioner, Manor Healthcare Corp. d/b/a ManorCare Health Services - Camp Hill ("Petitioner"), 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 Rosa L. Thompson, and, in support thereof, represents as follows: 1. The name of the alleged incapacitated person is Rosa L. Thompson. 2. Rosa L. Thompson is a 58 year old divorced woman who currently resides ~.,' (2 ;:; at Petitioner's skilled nursing facility located at 1700 Market Street, CamffJml, PA ~ '--?p ~ 17011.:; :-", I _ ,;., N ~=:J 3. ---) Q ':J Petitioner, a Pennsylvania corporation, is a licensed skilled,~~"fiomg .~ ::-_~ r:~ -r"" "~T Because the alleged incapacitated person resides in Cumberland Co~y, 4. this Court has Jurisdiction pursuant to 9 711(10) of the Probate, Estates and Fiduciary Code and 95512(a). ORIGINAL . , 5. Upon information and belief, Rosa L. Thompson has two living heirs who are sui juris. Their names and addresses are: Gaylord Thompson, Son 2600 Wilson Parkway Harrisburg, P A 17103 T errenze Thompson, Son 2600 Wilson Parkway Harrisburg, P A 17103 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 approximately $2,200.00. 8. The alleged incapacitated person's treating physician is: Dr. James R. Harty 207 House Avenue, Suite 101 Camp Hill, P A 17011 (717) 761-8331 9. Rosa L. Thompson, the alleged incapacitated person, has been diagnosed by Dr. Harty as suffering from, inter alia, dementia and senility. Said mental conditions have caused her incapacity and require that she receive 24-hour-a-day care. 10. Because of the mental conditions set forth in paragraph 9, Rosa L. Thompson, the alleged incapacitated person, is totally unable to manage or even appreciate the significance of her personal and financial affairs and to make and communicate any decisions relating thereto, including the ability to communicate her need for assistance in these areas. 2 .. , 11. Upon information and belief, Rosa L. Thompson presently does not have a responsible agent, guardian, or capable next of kin to appropriately manage her 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 /I A." 14. Good News Consulting, Inc. has been suggested as guardian of the person and estate of Rosa L. Thompson because of its vast experience in dealing with incapacitated persons such as her. 15. No Court within this Commonwealth, of which Petitioner has knowledge, has appointed a guardian for Rosa L. Thompson. 16. Upon information and belief, Rosa L. Thompson 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 Rosa L. Thompson, to show cause, if any there be, why she should not be declared an incapacitated person and Good News Consulting, Inc. appointed permanent plenary guardian of her person and estate. Respectfully submitted, ~'1~v Dated: l\" 1~' 0 \.,P By: Chadwick O. Bogar Attorney I.D. No. 83755 (717) 909-7002 Kirk S. Sohonage Attorney J.D. No. 77851 (717) 909-8160 305 N. Front Street, Suite 401 Harrisburg, P A 17101 Attorneys for Petitioner 4 , S~P-21-2006(THU) 13:40 P.006/006 It ~ VERIFJCA TION 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. ~ 4904, relating to unsworn falsification to authorities. Dated: 4;1 Jf 0 f.t; :;EP-1>2C10!)lHC) lS:I~:=: .' ~ P, 007/C107 ACCEPTANCE OF PROPOSED PERl\.1ANENT PLENARY GUARDIAN Good News ConsultingJ Tnc, the gtlardian of the person and este1te propotted in the for.egoing petition for appointment of a permanent plenary guardian of Rosa 1... Thompson, the alleged incapacitated per~onJ agrees to accept the appointment as pcmluncnt plenary gu~rdian and avers that: 1. The proposed guardian is Good News Consultin~ Inc., which is currently handling numerous guardianship matters shnilar to Rosn 1. Thompson. 2. Good News Consulting, Inc. is not a fiduciary of an estate in which the alleged incapacitated person has an interest, and the proposed pennancnt guardian of Rosa L. TIlompson has no interests adverse to her. Dated: 9 j; 'I /0 <p ~~ Tina Hess, 85, CMC, RG-NGF Vice President of Operations of Good News Consulting} Inc.