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HomeMy WebLinkAbout10-27-06 (2) NATIIAN C. WOLF, ESQUIRE ATtORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATtORNEY 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 .TJ II' C'J C) -I] c.-.:-; If 1 1.:-':; ~2 ". ~ ,.~ '.~1 AND NOW comes Petitioner Raymond B. Gunmings, by and through hisatfuJlley, N"iihan~g ~ .','.J ---I .. ::/) Wolf, Esquire, and presents this motion for a continuance of the November 3, 2006> hearing ctm, f~ r--.:> = = c..;""'\ MOTION TO CONTINUE HEARING, o C:J --l f'j -.J representing as follows: 1. On October 12, 2006, a hearing was held regarding the necessity of emergency plenary guardians of the person and estate of the above alleged incapacitated. 2. A hearing is presently scheduled on November 3, 2006, at 9:00 a.ffi. for appointment of permanent plenary guardians of the person and estate of the above alleged incapacitated person. 3. Petitioner seeks to postpone the hearing date because of the unavailability of the Court- appointed expert, Dr. HumeJand the Office of Aging expert on the date of the hearing. 5. Counsel for the Ounberland CoWlty Area Agency on Aging, Anthony L. DeLuca, Esquire, was contacted by Petitioner's counsel and does not oppose petitioner's motion to continue the hearing. >-.. WHEREFORE, the petitioner, Raymond B. Gunmings, respectfully requests this Honorable Court continue the hearing to a date and time convenient for all parties. October ~ , 2006 AT C. Attorney for Pe tioner, Raymond B. Cl1mmings 10 West High Street Carlisle, P A 17013 717-241-4436 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 information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to WlSwom falsification to authorities. Octobe) 7,2006 tioner, Raymond B. Cummings " . NATIIAN 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 : 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 Motion for Continuance of :Hearing upon the following by United States mail, postage prepaid, addressed as follows: Anthony L. Deluca, Esquire 113 Front Street Boiling Springs, P A 17007 October~~,2006 NAT C OLF Attome fi Petitioner, Raymond B. Cummings 10 Wes igh Street Carlisle, P A 17013 717-241-4436 Supreme Court ID No. 87380