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In the Coinmonwealth of Pennsylvania
Court of Coinmon P1eas
Of the Ninth Judicial District
: Orphan's Court Division
In Re: Estate of Charlotte Stone, Deceased : 21-2013-0088
In Re: Motion to Quash Petitioner's Subpoena
AND NOW, comes Pennsylvania Department of Aging, through their counsel, Cynthia
Haines, and respectfully request that the court reconsider the above captioned Motion to Quash
based upon the following:
1. Petitioners attempted to secure Protective Services records in discovery and requested an in
camera review with the Cumberland County Court.
2. Mrs. Stone has passed away and her children wish to see if there�was documented abuse
which could have led to her passing.
3. The Department of Aging's local partner, initially objected to the review under Title 6 Pa.
Code § 15.101 as confidential and Judge Thomas Placey denied the review.
4. Since the Department of Aging's initial objection, the defendant, Bruce Stone,joined the
request for the records to be reviewed in camera.
5. Title 6 Pa Code § 15.105(5)pennits such a review if the Department determines that the
release will not be detrimental to tlle safety of the person. Further, the policy is designed to
protect all witnesses and reporters. All relevant parties have consented to the review.
6. As a result of the foregoing, the Department determines that the zn came�•a review by both
parties will not be detrimental.
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Wherefore, the Department of Aging wishes to withdraw all objections to the in camera
review of the aforementioned records.
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Cindy Haines, Counsel
Department of Agin�,
Office of General Counsel
555 Walnut St., Sth Floor
Harrisburg PA 17101
In the Cominonwealth of Pennsylvania
Court of Common Pleas
Of the Ninth Judicial District
: Orphan's Court Division
In Re: Estate of Charlotte Stone, Deceased : 21-2013-0088
CERTIFICATE OF SERVICE
I, Cynthia A. Haines, hereby certify that on this date, I served a true and correct copy of
the foregoing by first class mail on the person indicated below, addressed as follows:
Louis Michelson, Esq.
Ira Weinstock, P.C.
800 N. 2"d Street
Harrisburg PA17102
Keith Brenneinan, Esquire
44 West Main Street
Mechanicsburg, PA 17055
Wayne F. Shade, Esquire
53 West Pomfret Street
Carlisle PA 17013
Respectfully submitted,
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Date: �� " ���� Cynt ia Haines
Assistant Counsel
Attorney I.D. No. 71821
Pennsylvania Department of Aging
555 Walnut Street, St�' Floor
Harrisburg, PA 17101
(717) 783-0509