HomeMy WebLinkAbout10-17-06 (2)
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NATHAN C. WOLF, ESQUIRE
A'ITORNEY ID NO. 87380
10 WEST HIGH STREET
CARLISLE PA 17013
(717) 241-4436
A'ITORNEY FOR PETITIONER
IN THE MATTER OF THE PERSON
AND ESTATE OF:
: IN THE COURT OF COMMO~ PLEAS~F OJ)
: CUMBERLAND COUNTY, P~SYL~L\~~, :-'=;
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: ORPHAN'S COURT DIVISIONJ '7";: (;::, 'f~,~
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: NO. 21-06-890 ~:;~ c:)
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RAYMOND B. CUMMINGS,
AN ALLEGED INCAPACITATED
PERSON
32
PETITION FOR APPOINTMENT OF AN EXPERT
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AND NOW comes the Petitioner Raymond B. Gunmings by and through his attorney, Nathan C
Wolf, Esquire, and in support of this Petition avers as follows:
1. Petitioner is the subject of a petition by the Gnnberland County Area Agency on Aging for
appointment of a guardian of Petitioner's person and estate in which a hearing to appoint a permanent
plenary guardian has been set for Friday, November 3, 2006, at 9:00 a.m.
2. Petitioner seeks to have an independent medical evaluation conducted and requests the
Court to appoint John Burne, MD., who is an expert in the field of psychiatry.
3. Pursuant to 20 Pa.CS. 5511(d.) the Court shall order an independent evaluation of an alleged
incapacitated person upon petition.
4. Petitioner requests that Dr. Burne be court-appointed to render an expert independent
evaluation of Petitioner.
5. Dr. Burne has agreed to evaluate Petitioner at his rate of $150.00 per hour.
6. Dr. Burne estimates that he will need approximately six (6) hours of evaluation and review
time to properly evaluate Petitioner and to testify on his behalf, if necessary.
7. Petitioner needs Dr. Burne's evaluation to accurately present his current mental condition.
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8. Petitioner requests that the Court authorize up to $1,000.00 to pay Dr. Hume for services
perlormed on his behalf, said funds to be release upon submission of an invoice for services perlormed to
the Court through counsel for petitioner.
9. Counsel for the Cumberland County Area Agency on Aging, Anthony L. DeLuca, Esquire,
consents to the court appointment of Dr. Hume, but does not concur to payment for Dr. Hume's
evaluation by the Cumberland County Area Agency on Aging.
WHEREFORE, Petitioner respectfully requests that the Court appoint Dr. John Hume at his rate of
$150 per hour, to review necessary records and evaluate Petitioner regarding his mental state, and to
authorize payment of up to $1,000.00 in said fees upon submission of invoices to the Court for services
rendered on behalf of the petitioner, along with any additional relief that the Court may deem appropriate.
October -1L- , 2006
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ner, Raymond B. Cummings
VERIFICATION
I do hereby verify that the facts set forth in this petition are true and correct to the best of my
infonnationt knowledge and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa.CS. Section 4904t relating to unsworn falsific . n to authorities.
October 11, 2006
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etitioner, Raymond B. Cummings
NATHAN C. WOLF, ESQUIRE
ATIORNEY ID NO. 87380
10 WEST HIGH STREET
CARUSLE PA 17013
(717) 241-4436
ATIORNEY FOR PETITIONER
IN THE MATTER OF THE PERSON : IN THE COURT OF COMMON PLEAS OF
AND ESTATE OF: : CUMBERLAND COUNTY, PENNSYLVANIA
RAYMOND B. CUMMINGS,
AN ALLEGED INCAPACITATED
PERSON
: ORPHAN'S COURT DIVISION
: NO. 21-06-890
CERTIFICATE OF SERVICE
I hereby certify this day that I served a copy of the Petition for Appoinunent of an Expert upon the
following by United States mail, postage prepaid, addressed as follows:
Anthony L. Deluca, Esquire
113 Front Stree
Boiling Springs,
October D, 2006
C. OLF
fo etitioner, Raymond B. Cummings
10 W t igh Street
Carlisle~.~4/17013
717-241' .I-Pi 3(,
Supreme Court ID No. 87380