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Home My WebLink About02-27-07 Marjorie A. Wevodau First Deputy One Courthouse Square Carlisle, P A 17013 Glenda Farner Strasbaugh Register of Wills & Clerk of Orphans' Court Kirk S. Sohonage, Esq. Solicitor Phone: (717) 240-6345 Fax: (717)240-7797 OFFICES OF Register of Wills and Clerk of the Orphans' Court County of Cumberland FACSIMILE TRANSMITTAL SHEET TO: Lisa Watson FROM: Margie Wevodau COMPANY: Barley Snyder LLC PHONE: 717-240-7766 FAX NUMBER: 717-291-4660 DATE: February 27, 2007 RE: TOTAL NO. OF PAGES INCLUDING COVER: o URGENT o FOR REVIEW 0 PLEASE COMMENT 0 PLEASE REPLY o PLEASE RECYCLE AS PER OUR CONVERSATION THIS MORNING, HERE IS CUMBERLAND COUNTY'S AFFIDAVIT. IN THE COURT OF COMMON PLEAS OF LANCASTER COUNTY, PENNSYLVAN[A CIVIL DIVISlqN MICHAEL A. and BETH 1. BLANCHFIELD V. No. CI-0I-02023 County ofLancaster,et al . \ AFFIDAVIT OF GLENDA FARNER STRASBAUGH I, Glenda Farner Strasbaugh, being duly sworn according to law, state: 1. I am elected as the Clerk of Orphans' Court of the County of Cumberland, Commonwealth of Pennsylvania 2. As Clerk of the Orphans' Court of Cumberland County, I am familiar with and have first hand knowledge of our County's Adoption Counseling Fund (provided for and established pursuant to 23 Pa. C.S.A. ~ 2505) (hereinafter the "Fund") beginning with my first commission in office - January 2004. Prior to that time, Mary C. Lewis and Donna Otto would have served as Register of Wills and Clerk of Orphans' Court in Cumberland County. 3. Upon taking office in January of 2004 this office had collected $50,400.00 from January 1994 through December 2003 in the Fund. 4. . As of December 2005: a The total amount collected and paid into the Fund since its inception was $56,775.00. b. The balance in the Fund at the end of December 2005, was $56,775.00 c. The total amount which was disbursed from the Fund to provide adoption counseling was $600. Date: F ebruarv 26. 2007 Glenda Farner Strasbaugh Cumberland County Register of Wills of Orphans' Court o c;;o <j~!~ )C)O ~-)9 -n '~.-=) =0 ~-..; r--.:l c:::> c:::l --.J -T"1 I""T1 O:J N -J -0 ::J:: r:-? ~ :T) r; (-"'-1 ;~ C.J Sworn to and subscribed Before me this ::JlJi-V- day of~007 fl. ~. .. ~~:ffo I.L/ .. o. Public I . . NOTARIAL SEAL MaIjorie A. Wevodau, Notary Public Carlisle Boro., Cumberland County My commission expires Apri~5, 201~. (f?, ~:u (-) ;'T'l \._/ -' .' ., BARLEY SNYDER LLC James R. Adams, Esquire Court 1.0. No. 02501 . .126 East King Street Lancaster, PA 17602-2893 (717) 299-5201 Attorneys for Plaintiffs MICHAEL A. and BETH J. BLANCHFIELD, et aI., COURT OF COMMON PLEAS LANCASTER COUNTY, PENNSYLVANIA Plaintiffs, No. CI-01-02023 v. COUNTY OF LANCASTER, et aI., CIVIL ACTION - LAW Defendants. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Glenda Farner Strasbaugh, Register of Wills Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 (JC) l__) O-n r.....:> = c:;::I -...J -" /"T1 co N -.J -0 ::ll: o Co :c~13 ..; ;;r: 0 ::" J.-'> r- ':;7 In C 1:> 5\? ___;1...-- : ::0 :u-l .J:> N .+:- o Within twenty (20) days of the service of this subpoena, you are ordered by the Court to. produce the following documents or things: all documents which show the following information with regard to the $75.00 fees paid into your County's Adoption Counseling Fund (hereinafter "The Fund"), as provided by 23 Pa. C. S. A. 9 2505 (e), from its creation, which would be in 1992 or thereafter, including: 1. Total amount paid into The Fund as of December 31, 1999; 2. Balance remaining in The Fund as of December 31, 1999; 3. Total amount paid into The Fund as of December 31,2005; 1705577 .1 Cumberland County ; , ,# 4. Balance remaining in The Fund as of December 31, 2005., at Barley Snyder LLC, 126 East King Street, Lancaster, PA 17602-2893. You may deliver or mail legible copies of the documents or produced things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. This subpoena was issued at the request of the following person: BARLEY SNYDER LLC James R. Adams, Esquire Attorney for Plaintiffs 126 East King Street Lancaster, PA 17602-2893 Court 1.0. No. 02501 (717) 299-5201 BY THE COURT: Seal of the Court Date: Jf) l~ /2tJP(L By: I / 1705577 .1 Cumberland County .... BARLEY SNYDER LLC James R. Adams, Esquire Court 1.0. No. 02501 126 East King Street Lancaster, PA 17602-2893 (717) 299-5201 ~(Q)~ Attorneys for Plaintiffs MICHAEL A. and BETH J. BLANCHFIELD, et aI., COURT OF COMMON PLEAS LANCASTER COUNTY, PENNSYLVAiIAo o 0'\ r- -. 0 ,.,., ~6 ~ ~ 02: I'T1 )>0 ::0 c.n-i (..) ~ -t)>c 0 ,.,.,::0 90 ::0 -< ~ -r'I .. v3 r= -00 N rn ~-n - 0 -n CA) oN rn Plaintiffs, No. CI-01-02023 v. COUNTY OF LANCASTER, etal., CIVIL ACTION - LAW Defendants. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ,...." c::;) <::::I --.I .." m 00 N -.! TO: Howard L. Kelin, Esquire Kegel Kelin Almy and Grimm 24 North Lime Street Lancaster, PA 17602 o S2 rB~o ;-i>r- '7rn c/5~ ~3(~ ::':J ----I -0 ~ -- N ~ o As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Plaintiffs certify that: (1) a notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty. (20) days prior to the date on which the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, 1725540-1 ::c; -cJ jt! ~jj.8 ; "-7') .:TJ - ;----J !'; ('or, .~:j C~J C) n,l -n c) n, C) .1"1 ~, (3) no objection to the subpoena has been received, and all parties have agreed to waive the 20 day notice of intent to serve a subpoena, and (4) the subpoena to be served is identical to the subpoena attached to the notice of intent to serve the subpoena. BARLEY SNYDER LLC Dated: 1~/~'1l1 By: 126 East King Street Lancaster, PA 17602-2893 Court 1.0. No. 02501 (717) 299-5201 1725540-1 BARLEY SNYDER LLC James R. Adams, Esquire Court 1.0. No. 02501 126 East King Street Lancaster, PA 17602-2893 (717) 299-5201 Attorneys for Plaintiffs MICHAEL A. and BETH J. BLANCHFIELD, et aI., COURT OF COMMON PLEAS LANCASTER COUNTY, PENNSYLVANIA Plaintiffs, No. CI-01-02023 v. COUNTY OF LANCASTER, et aI., CIVIL ACTION - LAW Defendants. NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO.RULE 4009.21 TO: Howard L. Kelin, Esquire Kegel Kelin Almy and Grimm 24 North Lime Street Lancaster, PA 17602 Plaintiffs intend to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and. serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. 1705577.1 Cumberland County . , Dated: ID 11.1 IS(,;I 1705577.1 Cumberland County BARLEY SNYDER LLC By: 126 East King Street Lancaster, PA 17602-2893 Court 1.0. No. 02501 (717) 299-5201 BARLEY SNYDER LLC James R. Adams, Esquire Court 1.0. No. 02501 126 East King Street Lancaster, PA 17602-2893 (717) 299-5201 Attorneys for Plaintiffs MICHAEL A. and BETH J. BLANCHFIELD, et aI., COURT OF COMMON PLEAS LANCASTER COUNTY, PENNSYLVANIA Plaintiffs, No. CI-01-02023 v. COUNTY OF LANCASTER, et aI., CIVIL ACTION - LAW Defendants. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Glenda Farner Strasbaugh, Register of Wills Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Within twenty (20) days of the service of this subpoena, you are ordered by the Court to produce the following documents or things: all documents which show the following information with regard to the $75.00 fees paid into your County's Adoption Counseling Fund (hereinafter liThe Fund"), as provided by 23 Pa. C. S. A. ~ 2505 (e), from its creation, which would be in 1992 or thereafter, including: 1. Total amount paid into The.Fund as of December 31,1999; 2. Balance remaining in The Fund as of December 31,1999; 3. Total amount paid into The Fund as of December 31, 2005; 1705577.1 Cumberland County 4. Balance remaining in The Fund as of December 31, 2005., at Barley Snyder LLC, 126 East King Street, Lancaster, PA 17602-2893. You may deliver or mail legible copies of the documents or produced things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. This subpoena was issued at the request of the following person: BARLEY SNYDER LLC James R. Adams, Esquire Attorney for Plaintiffs 126 East King Street Lancaster, PA 17602-2893 Court 1.0. No. 02501 (717) 299-5201 BY THE COURT: Date: By: Prothonotary Seal of the Court 1705577.1 Cumberland County CERTIFICATE OF SERVICE [Blanchfield. et at v. County of Lancaster, et al.) I HEREBY CERTIFY that a true and correct copy of the foregoing Notice of Intent to Serve a Subpoena was served this ) \ day of October, 2006, by first class mail, postage prepaid, upon the following: Howard L. Kelin, Esquire Kegel Kelin Almy and Grimm 24 North Lime Street Lancaster, PA 17602 ~ams. Esquire Attorney for Plaintiffs 126 East King Street Lancaster P A 17602 Court I.D. 02501 1705577.1 Cumberland County CERTIFICATE OF SERVICE [Blanchfield, et al. v. County of Lancaster, et al.) I HEREBY CERTIFY that a true and correct copy of the foregoing Certificate Prerequisite to Service of a Subpoena was served this 13J4- day of October, 2006, by first class mail, postage prepaid, upon the following: Howard L. Kelin, Esquire Kegel Kelin Almy and Grimm 24 North Lime Street Lancaster, PA 17602 e . Adams, Esquire rney for Plaintiffs 126 East King Street Lancaster, PA 17602-2893 Court I.D. No. 02501 (717) 299-5201 1725540-1 126 East King Street Lancaster, PA 17602-2893 Tel717.299.S201 Fax 717.291.4660 www.barley.com James R. Adams, Esquire Direct Dial Number: 717.399.1510 E-mail: jadams@barley.com October 19,2006 Glenda Farner Strasbaugh, Register of Wills Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Re: Blanchfield v. County of Lancaster, et aI. Dear Ms. Farner Strasbaugh: This firm represents the Plaintiffs in the above Class Action challenging the constitutionality of a Pennsylvania statute which created Adoption Counseling Funds in each County. On the basis of information from an earlier survey, we believe that the Funds are sitting unused, because of the way the law was written. With Court approval, we are serving the enclosed Subpoena on you to collect information about the status of the Fund in your County. We are seeking to identify the balances paid into and remaining with the funds as of the ends of 1999 and 2005. If you would prefer, instead of providing the documentation stated, you may just give us the needed dollar figures by completing and returning the enclosed Affidavit. The Affidavit would need to be notarized. Thank you for your anticipated cooperation. Please note that your response is due W!hin twenty (20) days. Please forward your response and questions to our paral~~ Lisa ~ Watson (717-299-5201 x3223), at the same address. :-';:0 ...." -' \.."7 rr1 :: ~.r: 0 00 ., ~ :=;::; N (/3 ~;: -.J 8~~~ ~ '- - =0 '-n ---j ~,..t...... -",,;:.;-. 21;' N +"" o James R. Adams JRA/lam: 1732677_1. DOC Enclosures Lancaster' York' Harrisburg · Reading · Berwyn · Hanover · Chambersburg