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Louis Michelsen, Esquire � o `� ,.'.�'� m
Attorney ID #90582 �' � -�v �? a
Ira Weinstock, P.C. � a � �' � �
800 N. Second Street � �, f'� v~i r� �'
Harrisburg, Pa. 17102 � ' ''` {., c,
(717)238-1657 � a -°n � �"' -�''ri
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��� : iN THE COURT OF COMMON PLE „'
: CUMBERLAND COUNTY, PENNA.
ESTATE OF CHARLOTTE STONE, : ORPHANS' COURT DIVISION
DECEASED : No. 21-13-88
Joint Motion for In-Camera Review of Records from Cumberland Countv A�ing and
Communit,y Services
NOW comes Joy Nargi, daughter of the Decedent, Tammy Duncan, daughter of the
Decedent, Angela Book, daughter of the Decedent, and Debbie Ulsh, daughter of the Decedent,
as well as Respondent (Bruce Stone) herein after "Petitioners," submits this Joint Motion for In-
Camera Review of Records from Cumberland County Aging and Community Services.
1. On or about August 22, 2013, Petitioners filed a Citation for Appeal from Probate
in the Orphans' Court of Cumberland County, Pennsylvania. Petitioners alleged that undue
influence resulted in the writing of the February 1 l, 2009 Last Will and Testament of Decedent
Charlotte Stone.
2. In particular, Petitioners alleged at paragraph j. of the Citation the following: "In
October or November 2011, the Department of Aging of Cumberland County investigated Bruce
Stone for alleged abuse of Decedent."
3. The parties are in the discovery phase of litigation.
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4. On or about January 6, 2014, a subpoena was served upon Cumberland County
Aging and Community Services seeking to produce records regarding Decedent from January 1,
2010 to January 12, 2013. The subpoena was signed by the Cumberland County Register of
Wills/Clerk of Courts of the Orphans' Court on December 2, 2013. Respondent, Bruce Stone,
signed a waiver agreeing to the release of these records.
5. Cumberland County Aging and Community Services asserted that all such
material subject to the subpoena are by law confidential.
6. By order dated March 12, 2014, the Honorable Thomas Placey sealed records
relating to Decedent from January 1, 2010 to January 13, 2013 after receipt of those documents
from Keith O. Breneman, Esquire.
7. In that order, Judge Placey noted that the information in the sealed envelope may
be germane to the instant matter and that the sealed order protects those recards for future use as
deemed appropriate with a proper court order.
8. Petitioners (which include Respondent Bruce Stone) request an order permitted an
in-camera review of those records.
WHEREFORE, Petitioners request that this Court issue an order permitting Petitioners
(including Respondent Bruce Stone) and in-camera review of the sealed documents.
Respectfully Submitted,
IRA H. WEINSTOCK,P.C.
800 North Second Street
Harrisburg, PA 17102
Phone: 717-238-1657
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LO J. MICHELSEN
CERTIFICATE OF SERVICE
AND NOW, this 14th day of April, 2014, I, Louis J. Michelsen, Esquire, attorney for
Petitioners, hereby certify that I served the within Joint Motion for In-Camera Review of
Records from Cumberland County Aging and Community Services this day by depositing
the same in the United States mail, postage prepaid, in the post office at Harrisburg,
Pennsylvania, addressed to:
By First Class Mail:
The Honorable Thomas A. Placey
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
Keith O. Brenneman,Esquire
44 West Main Street
Mechanicsburg, PA 17055
Wayne F. Shade, Esquire
53 West Pomfret Street
Carlisle, PA 17013
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LOUIS . MICHELSEN