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Home My WebLink About03-09-15 IN RE: . IN THE COURT OF COMMON PLEAS . CUMBERLAND WUNTY, PENNA. . NINTHJUDICIALDISTRICT ESTATE OF CHARLOTT F. STONE, . Deceased. . No. 21-13-0088 AFFIDAVIT OF SERVICE On January 8, ?A15, my office served the December 23, 7A14 Order re Motion ro Quash Subpoe�a to Jeunifer B. Hipq Esqui�e, and Wayne F. Shade, Esquire via email. Ou January 22, 2015, my office served the Decembec 23, 7A14 Order re Motion to Quash Subpoen on Cindy Haines, Esquire via email. The December 23, 2014 Order ec Motion to Quash Subpoena was served and accepted as outlined in the emails attached hereto as Exhibit "A". I make these statemen[s pursuant to 18 Pa. Co�s. StaL § 4904 �elating to unsworu Palsification to authorities xnd understxnd that false statements may subject me ro criminal penalties unde� that statute. r By: Log s J. Michclscq Esquire 1RA H. WEINSTOCK, P.C. 800 North Second Stceet Harrisburg, PA 17102 Phone: 717-238-]657 � -, - .� �: _ n : c� —� c� ,._ _.., �,. .1 ,.:� ;; c� � _�� ..� r i � � .� Louis Michelsen From: Jennifer Hipp <jhipp@bogarlaw.com> Sent: Wednesday,January 07, 2015 3:35 PM To; Wayne F. Shade;solicitor@ccpa.net Cc: Louis Mi<helsen Subject: RE: Estate of Charlotte F.Stone, No. 21-13-88 Wayne: i am agreeable to service via email. 1 will review this matter with my dient and be in touch. Thank you, Jenniter B. Hipp, Esq. James D. Bogar Law Ottices One West Main Street Shiremanstowq PA 17011 Phone: Q17) 737-8761 Fax p17) 737-2086 www booarandhioolaw.com ihipp�600arlaw.com From: Wayne F. Shade [mailto•wavnefshadeColcomcastnetl �� Sent: Monday, ]anuary O5, 2015 1:29 PM To: lennifer Hipp; solicitorCdccoa net Ca Louis]. Michelsen Subject: Estate of Charlotte F. Stone, No. 21-13-88 Jennifer: Thank you very much for service of your appeazance in the above matter. We attach copies of the Department of Aging consent to in camera review served December 18, 2014, and Judge Placey's Order of December 23, 2014. The judge's Order is a bit difficul[ to understand in view of the fact that it seems to be acknowledged by all concemed [hat there is no dispute tha[[he records in question, which are already in the hands of the Clerk of the Orphans' Court, may be reviewed by the parties tn camera. Nevertheless, from the [ertns of the O�der, we will not be able to move focwazd un[il the Office of Aging as [he Respondent, responds wi[h a proposed order. [[ would be sugges[ed tha[the response simply be that everyone concemed is in agreemen[ wi[h the in cnmera review and tha[ the proposed order would request[he scheduling of a date therefor. By copy of this email to Lo�is Michelsen, we will be askiug him [o serve the orde� �**�media[elv if he has not already done so. i EXHIHIT "A" Louis Michelsen From: Jill Foster Sent: Thursday,January OB, 2015 3:15 PM To: Jhipp@bogarlaw.com;waynefshade@comast.net ��; Lo�is Michelsen Subjec[ Estate of Charlotte Stone Attachments: 12-23-14 Order re Motion to Quash Su6poena.pdf Dearlenniferand Wayne, Per your request for service via email,attached please f nd the December 23,2014 Order of Judge Thomas A. Placey, in response to the Motion to Quash Peti[ionels Subpoena. Kindly respond to[his email as proof of receip[. Thankyou lill Foster Ira A. Weinstock, P.C. 800 N. Second 5[ree[ Harrisburg, PA 17102 717-238-1657 This email is for the use of the intended recipient�s)only. If you have received this email in error, please notify the sender immediately and then delete it. If you are not the intended recipient,you must not keep, use, disclose, copy or distribute this email without the author's prior permission.We have taken precautions to minimize the risk of transmitting software viruses, bu[we advise you to carry out your own virus checks on any attachmen[to this message. We cannot accept liability for any loss or damage caused by sokware viruses.The information contained in this communication may be confidential and may be subject to the attomey-dient privilege. Ifyou are the intended recipient and you do not wish to receive similar electronic messages from us in future[hen please respond to[he sender to this effect. 1 Louis Michelsen from: liil Foster Sent: Tuesday,lanuary 13, 2015 11:31 AM To: Louis Michelsen Subject: FW: Estate of Charlotte Stone Wayne has received. .__.._ ._ ___ . _._._ ._.__ _.... .. . Prom. Wayne P. Shade [mailto•wavnefshadeC�comcast netl Sent:Tuesday, January 13, 2015 11:30 AM To: Jill Foster Subject: RE: Estate of Charlotte Stone Received. Thank you very much. Waync F. Shade Wavnc E Snadc,Esy��irc Annmcya�.l�w 9l Wcxl VunrtmtSvuc� Ca9[Je.P.4 111113 Tcicl�honu: )V-'_li-U220 Fuv: 91'1-^i9-0019 &Mnil: �(�M1'J�@ Wehdic wnYnushaJclnw_wm CONFIDHNTIALITY NOTF� TNE.IFFORMATION CONT1INF.D IN THIS ELECI'ROV IC MNL iRAN5bI15S10�IS LEGdILY PRIVILFGED AVD CO4fiDF,NTi.\L WFORMA'1'ION INT[NDF.�OVLY FOR THE USF.OFTHF I�DIVIDCa\LOR ENTITY N,\MF.D ABOVF. IFTHE READEROFTHIS f.1FS510E IS NOT TIIF.M"i'ENDED RECIPIF,�T,}'OU ARF HF:REBY NOTIFIFD'f1i4T ANY�ISSEMINATION,�ISTRI9UTION OR W PYMC OF THIS ELE(:TNONIC M1IAII.W ESSACF.IS STRICTLY PROIIIRITF.O. IF VOU HAV E RF.CEIV ED TVIIS FLECTRONIC\L41L M ERROR,PLE,\SF.ACCEIT OUR APOLOCIES A�U LM�AEDIA'ITLY�LLLTL ff.AS WELL A3 NOTIFYING US OF TIIE ERROR 61'REPLY'ING'1'O TFlIS ELGCTRONIC MAIL OR CALL US A9'N(%�'_1J-02:0. . ..._ ...__ . __._. . . __._ ._... ... . ._. _._.__ From. Jill Foster [mailto�ifosterCalweinstocklaborlaw com] Sent:Tuesday, January 13, 2015 10:36 AM To: wavnefshadeCdcomcast ne[ Subject: FVJ: Estate of Charlotte Stone Dearlenniferand Wayne, Per your request for service via email, attached please find the December 23,2014 Order of Judge Thomas A. Placey, in response to the Motion to Quash Petitioner'S Subpoena. Kindly respond to this email as proof of receipt. Thankyou Jill Foster Ire A.Weinsrock, P.C. 800 N. Second Street Harrisburg, PA 17102 717-238-1657 This email is for the use of the intended recipient(s)only. If you have received this email in error, please notify the sender immediately and then delete it. If you are not the intended recipient,you must not keep,use,disclose,copy or 1 Louis Michelsen From: lill Foster SenY. Thursday,January 22, 2015 11:45 AM Ta. Louis Michelsen Subject FW: Estate of Charlotte Stone ...__. . .___'_ . _—..__ —_—._ .—_____. _—_._. ._—.. From Hames, Cindy [madto�cihaines(aoa aovl Sent:Thursday,]anuary 22, 2015 11:39 AM 70:lill Foster Sub�ec[: RE: Estate of Charlotte Stone I have received the document and accep[ receip[. Cindy Haines � Attorney at Law Department of Aging, Offlce of General Counsel 555 Walnu[ St., 5th Floor � Harrisburg PA ll101 Phone: 717J63.0509 � Fax:717.772.3382 Website: aaino oa aov The Pennsylvania Department of Aging - Proudly Serving Pennsylvanians for over 35 years! There is No Excuse for Elder Abuse - Anyone who believes that an older adult is being abused, neglected, euploited or abandoned should call the Department of Aging's confidential elder abuse hotline a[ 1-800- 490-8505 PRIVILEGED AND CONFIDENTIAL COMMUNICATION The information transmitted is intended only for the person or entity to whom it is addressed and may contain confidential and/or privileged material. Any use of this informa[ion other[han by the intended recipient is prohibited. tf you rereive this message in error, please send a repty e-mail to the sender and delere the material from any and all computers. Unintended transmissions shall not constitute waiver of the attomey-dient or any other privilege. .._ . __ .___.. . _ _ __ _ From: LII Foster f mailto 'fos[e Cdweinstocklaborlaw mml Sent:Thursday,lanuary 22, 2015 11:36 AM To: Haines. Cindy Subject: FW: Estate of Charlotte Stone Dear Cindy, Attached please find the Otder regarding the Motion m Quash Su6poena for Ihe above-referenced matter. Please respond to this email as acceptance of this Order. Thankyou Jill Foster Ira A. Weinstock, P.C. 800 N.Second Street Harrisburg, PA ll102 717-238-1657 1 Louis Michelsen From: Wayne E Shade <waynehhade@comcast.neU Sent: Friday,January 30, 2015 1:32 PM Ta. 7ennifer Hipp';solicifor@ccpa.net �� Louis Michelsen Subject: RE: Estate of Charlotte F. Stone, No.21-13-88 Jennifer: You may recall our email of Januazy 5, 2015, with respect to the above. Are you able to give us an idea as [o when you expec[ ro be able to respond ro that email. Wayne Please confirm thut you have received [his email. W u}nr P.SM1adc.Gsiryim .VlomuY-��.law 51 W xt PumRel tiVut CadLwIe.PA 1]1113 'fcicOhene: "I19d11-03'_0 Pvx: �1]d.19.W I"! gA1ai1: actnc� W{�ilc y '1'd lvw�. m roNFIDFhTIALITY NOTF.: '11iE INFORMAfION CONTAIhF.D IN TIi15 ELECI'RONIC MAILTRANS1IISSION IS LF.GALLY PRI�II.FCF,D AN� CONf1UENIL\L INfORMAI'IOF INIEND[DONLY POR 1'lIE USGOP'f11E IYUIVIDUALOR CMtiTY NAb1EDABOVE. IFTHER64DEROPT1115 AtGSSAGL IS 6ti f THG INTE\OED N[CIPIENT,Y00�VtL HERLdY NOTIPIED'CHAT ANY UISSLW W A'fION,UISTRIDUTION OR COVY I�G OF'fl{�S APOfAGIES(�\KDIMSIEDI\TEI.YDFLETEITASWF.LLDSNOTIFI'INGGS)FTNEF.RftORHtRPLY1NGTOTNISF.f�FO.([TROMCh1V�NrC�R CS,AT NW-;J)�V_�p0. __ _ _- __.... ._.. From: Jenmfer�Hipp [mail[o�ihiooCa�boaarlaw coml Sent: Wednesday,January 07, 2015 3:35 PM To:Wayne F. Shade; � IicitorCalccoa net Cc: Louis J. Michelsen Subject: RE: Estate of Charlotte F. Stone, No. 21-13-BB Wayne: I am agreeable to service via emaii. I will review chis ma[ter with my dient and 6e in touch. Thank you, Jennifer B. Hipp, Esq. James D. Bogar Law Offices One West Main Street Shiremanstown, PA 17011 Phane: (717) 737-8761 Fax: (717)737-2086 n oarandhipplaw com _.__ - 1 Louis Michelsen From: lennifer Hipp <jhipp@bogadaw.mm> Sent: Friday, February 13, 2015 3:32 PM To: Jill Poster,Wayne F. Shade (waynefshade@comcast.net); Louis Michelsen SubjecC Estate of Charlotte Stone Ms. Fos[er, Mr.Shade and Mr. Michelson: I have reviewed this matter with my client,Cumberland County Aging&Communiry Services("A&CS"�. A&CS has determined that it will no longer oppose the desired in camera review of its records regarding Mrs.Charlotte Stone. A&CS has not returned the Rule issued by the Court of Common Pleas to show cause why the requested in camera relief should not be gran[ed. We believe that A&CS's decision not to file a return to the Rule signals to the Court that we no longer oppose the in camera request. As we read the Court's December 23,2014 Order,A&CS's requirement to include a proposed Order applies only if A&CS made a filing as to why the in camera review should not be granted. Should your clients wish to proceed with the in camera review,A&CS is prepared to review a proposed Order seeking the Court to schedule the in camera review. Presuming that A&CS is agreeable to the proposed Order,we would conseM[o language in thefiling noting our consen[to requesting that the Court schedule the in camere review. Please advise if you have any questions regarding this ma[ter. Thank you, Jen Hipp Cc: Cum6erland County Aging&Community Services Jennifer B. Hipp, Esq. James D. Bogar Law Offices One West Main Street Shiremanstown, PA 17071 Phone: (717) 737-8761 Fax: (717) 737-2086 www.boaarandh ioolaw.com ihipoC�boaarlaw.com i