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Home My WebLink About10-17-06 (3) o NATHAN C. WOLF, ESQUIRE ATI'ORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATI'ORNEY FOR PETITIONER IN THE MATTER OF THE PERSON : IN THE COURT OF COMMO~ PLEAS~F .::0 AND ESTATE OF: : CUMBERLAND COUNTY PENNSYLV4'NT A-::-::; :J' , -::lJ ' . t:':t -.&.<'t: . - ") : . _.:;o~ =.~ () ~ .~~ S-r3 : ORPHAN'S COURT DIVISIO~ :t; i~ ~ .:, ~~ - - <'- ___D -.I '" c:J : NO. 21-06-890 ' ci5 7~'- - c~ (:? c=' -0 -n (j '''::J: -n C e''') :D r:-:> in ,.J --i (-) > c..> '-''1'-1 PETITION FOR APPOINTMENT OF AN EXPERT U) RAYMOND B. CUMMINGS, AN ALLEGED INCAPACITATED PERSON AND NOW comes the Petitioner Raymond B. Cummings 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 Gunberland O>unty Area Agency on Aging for appointment of a guardian of Petitioner's person and estate in which a hearing to appoint a pennanent plenary guardian has been set for Friday, November 3, 2006, at 9:00 a.In. 2. Petitioner seeks to have an independent medical evaluation conducted and requests the O>urt to appoint John Hume, MD., who is an expert in the field of psychiatry. 3. Pursuant to 20 Pa.C.S. 5511(d) the O>urt shall order an independent evaluation of an alleged incapacitated person upon petition. 4. Petitioner requests that Dr. Hume be court-appointed to render an expert independent evaluation of Petitioner. 5. Dr. Hume has agreed to evaluate Petitioner at his rate of $150.00 per hour. 6. Dr. Hume 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. Hume's evaluation to accurately present his current mental condition. v- 8. Petitioner requests that the Court authorize up to $1,000.00 to pay Dr. Hume for services perlonned on his behaJf, said funds to be release upon submission of an invoice for services perlonned to the Court through counsel for petitioner. 9. Counsel for the Gunberland County Area Agency on Aging, Anthony 1. DeLuca, Esquire, consents to the court appointment of Dr. Burne, but does not concur to payment for Dr. Burne's evaluation by the Gunberland 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 behaJf of the petitioner, along with any additional relief that the Court may deem appropriate. {)ctober~,2006 T Attom for P ner, Raymond B. Cummings 10 West High treet Carlisle" .fAt 17013 717-291''1'13~ Supreme Court ID No. 87380 VERIFICATION I do hereby verify that the facts set forth in this petition are true and correct to the best of my infonnation, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.CS. Section 4904, relating to unsworn falsific . n to authorities. olf etitioner, Raymond B. Cummings October J1, 2006 , t NATHAN C. WOLF, ESQUIRE ATrORNEYID NO. 87380 10 WEST IDGH STREET CARUSLE PA 17013 (717) 241-4436 ATrORNEY 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 Appointment 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 /1, 2006 C. OLF fo etitioner, Raymond B. C1Jrnrnings 10 W t igh Street Carlisle~.~4/17013 717-241 ~ ;.j13~ Supreme Court ID No. 87380 v In Re: RAYMOND B. CUMMINGS ORPHANS' COURT DIVISION COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA NO. 21-06-0890 CERTIFICATE OF SERVICE OF ORDER ORDER DATE: 10/19/06 JUDGE'S INITIALS: EEG TIME STAMP DATE: 10/20/06 IN RE: ORDER """""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" SERVICE TO: NATHAN C. WOLF ESO ANTHONY L. DELUCA ESO METHOD OF MAILING: ENVELOPES PROVIDED BY: , [gI USPS DRRR D HAND DELIVERED D OTHER_ [gI PETITIONER D JUDGE D CLERK OF ORPHANS COURT MAILED: 10-20-06 """""""""""""""""""""""""""""""""""""""""""""""""""""""""""""" SERVICE TO: METHOD OF MAILING: ENVELOPES PROVIDED BY: D USPS DRRR D HAND DELIVERED D OTHER_ D PETITIONER D JUDGE D CLERK OF ORPHANS COURT MAILED: ~~~ Deputy . Clerk of Orphans' Court