OOR Brief Filed 6 28 13

7/28/2019 OOR Brief Filed 6 28 13

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IN THE COMMONWEALTH COURT OF PENNSYLVANIA

No. 174 C.D. 2013

BOROUGH OF WEST EASTON,

Appellant,

v.

TRICIA J. MEZZACAPPA,

Appellee.

Brief of Amicus Cur iae Office of Open Records

APPEAL FROM THE JANUARY 9, 2013 ORDER OF THE NORTHAMPTON

COUNTY COURT OF COMMON PLEAS AT NO. C-48-CV-2012-7973,

AFFIRMING THE JULY 11, 2012 FINAL ORDER OF THE OFFICE OF OPEN

R ECORDS AT OOR DKT. AP 2012-0992

Dena Lefkowitz, Chief Counsel

Supreme Court ID# 52912

J. Chadwick Schnee, Assistant Chief Counsel


Audrey Buglione, Esquire


The Office of Open Records

Commonwealth Keystone Bldg.

400 North Street, Plaza Level

Harrisburg, PA 17120-0225Telephone: (717) 346-9903

Facsimile: (717) 425-5343Counsel for the Office of Open Records

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TABLE OF CONTENTS

TABLE OF CONTENTS ................................................................................. i

TABLE OF AUTHORITIES .......................................................................... ii

I. INTEREST OF AMICUS CURIAE ........................................................ 1

II. COUNTER-STATEMENT OF STANDARD AND SCOPE OFREVIEW................................................................................................ 2

III. COUNTER-STATEMENT OF THE CASE .......................................... 3

IV. SUMMARY OF ARGUMENT ............................................................. 6

V. ARGUMENT ......................................................................................... 9

A. A second request for a record does not constitute “repeated requests”

pursuant to Section 506(a) of the RTKL ............................................. 10

B. An agency must provide evidence that responding to repeated requests

is unreasonably burdensome ............................................................... 13

VI. CONCLUSION ................................................................................... 17

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TABLE OF AUTHORITIES

Cases

Allegheny County Department of Administrative Services v. A Second

Chance, Inc., 13 A.3d 1025 (Pa. Commw. Ct. 2011) ............................ 2, 12

Borough of West Easton v. Tricia J. Mezzacappa, No. C-48-CV-2012-7973

(Northampton Com. Pl. Jan. 9, 2013) ............................................... 4, 5, 15

Bowling v. Office of Open Records, 15 A.3d 427 (Pa. 2011) .......................... 2

Carey v. Pa. Dep't of Corr., 61 A.3d 367, 376 (Pa. Commw. Ct. 2013) ....... 15

Cohen v. Pa. Dept. of Labor and Industry, OOR Dkt. AP 2009-0333,

2009 PA O.O.R.D. LEXIS 169 .................................................................... 9

Dep’t of Envtl. Prot. v. Legere, 50 A.3d 260, 265

(Pa. Commw. Ct. 2012) ............................................................................ 13

Dougher v. Scranton Schl. District , OOR Dkt. AP 2009-0798,2009 PA O.O.R.D. LEXIS 318 .................................................................... 9

Dreyer v. Department of Environmental Protection, OOR Dkt. AP2009-0453, 2009 PA O.O.R.D. LEXIS 207 .......................................... 9, 12

Kaplin v. Lower Merion Twp., 19 A.3d 1209, 1213 n.6

(Pa. Commw. Ct. 2011) ............................................................................... 2

Laigle v. City of Pittsburgh, OOR Dkt. AP 2010-0955, 2010 PA

O.O.R.D. LEXIS 909 .................................................................................. 9

Levy v. Senate of Pa., No. 44 MAP 2012, 2013 Pa. LEXIS 788(Pa. Apr. 24, 2013) ............................................................................... 11, 12

Lutz v. City of Philadelphia, 6 A.3d 669, 676 (Pa. Commw.Ct. 2010) .............................................................................................. 14, 15

Makanvand v. Borough of Loganville, OOR Dkt. AP 2012-0337,

2012 PA O.O.R.D. LEXIS 269 .................................................................. 10

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Mezzacappa v. West Easton Borough, OOR Dkt. AP 2012-0992,

2012 PA O.O.R.D. LEXIS 967 .......................................................... 3, 4, 12

Office of the Governor v. Bari, 20 A.3d 634 (Pa. Commw. Ct. 2011) ... passim

Pa. State Police v. Zloczower , No. 2082 C.D. 2010, 2011 Pa. Commw.Unpub. LEXIS 822 (Pa. Commw. Ct. 2011) ............................................. 14

Rabjohn v. City of Philadelphia, OOR Dkt. AP 2011-0174,2011 PA O.O.R.D. 90 ............................................................................ 9, 12

Schneller v. City of Philadelphia, OOR Dkt. AP 2011-0852,

2011 PA O.O.R.D. 559 .......................................................................... 9, 12

Slate v. Pa. Dept. of Environmental Protection, OOR Dkt. AP2009-1143, 2009 PA O.O.R.D. LEXIS 97 .................................................. 9

Stein v. Plymouth Twp., 994 A.2d 1179 (Pa. Commw. Ct. 2010) ................... 2

SWB Yankees LLC v. Wintermantel , 45 A.3d 1029, 1037 (Pa. 2012) ............. 2

Thompson v. Dickinson Township, OOR Dkt. AP 2009-0302,2009 PA O.O.R.D. LEXIS 162 .................................................................. 13

Yakim v. Municipality of Monroeville, OOR Dkt. AP 2012-0317,

2012 PA O.O.R.D. LEXIS 267 .................................................................. 10

Zloczower v. Luzerne County Correctional Facility, OOR Dkt.

AP 2010-0754; 2010 PA O.O.R.D. LEXIS 737 .......................................... 9

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Statutes

1 Pa.C.S. § 1921(a) ........................................................................................11

1 Pa.C.S. § 1921(b) ........................................................................................11

1 Pa.C.S. § 1921(c) ........................................................................................11

65 P.S. § 67.1101(a) ........................................................................................ 4

65 P.S. § 67.1302 ............................................................................................ 5

65 P.S. § 67.1308 .......................................................................................... 13

65 P.S. § 67.506(a) ........................................................................ 3, 10, 11, 14

65 P.S. §§ 67.101 et seq. ........................................................................... 1, 12

65 P.S. §§ 67.1101, 67.1301(a) ....................................................................... 1

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I. INTEREST OF AMICUS CURIAE

Your amicus curiae, the Pennsylvania Office of Open Records

(“OOR”), is an independent, quasi-judicial tribunal charged with, among

other duties, implementation of the Pennsylvania Right-to-Know Law, 65

P.S. §§ 67.101 et seq., (“RTKL”), including issuing final orders of appeals

within its jurisdiction and conducting training on the RTKL. See 65 P.S. §§

67.1101, 67.1301(a).

Since 2009, the OOR has handled over 7,000 appeals, participated in

or monitored over 300 cases in the Supreme Court, Commonwealth Court

and courts of common pleas, conducted around 700 trainings, fielded about

45,000 e-mail and telephone inquiries from citizens, public officials and the

media, and has conducted hearings.

Your amicus curiae participates in this case in an effort to aid the

Court in clarifying an agency’s obligation to respond to repeated requests for

the same record(s) where the request is repeated only once and there is

insufficient evidence that the second request places an unreasonable burden

on the agency.

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II. COUNTER-STATEMENT OF STANDARD AND SCOPE OF

REVIEW

“The framework governing appellate review in matters arising under

the Right-to-Know Law is presently under consideration” by the

Pennsylvania Supreme Court. SWB Yankees LLC v. Wintermantel , 45 A.3d

1029, 1037 (Pa. 2012) (citing Bowling v. Office of Open Records, 15 A.3d

427 (Pa. 2011) (per curiam)).

The Commonwealth Court has held that its standard of review for

lower court decisions under the RTKL is “limited to determining whether

findings of fact are supported by competent evidence or whether the trial

court committed an error of law, or an abuse of discretion in reaching its

decision.” Kaplin v. Lower Merion Twp., 19 A.3d 1209, 1213 n.6 (Pa.

Commw. Ct. 2011) (quoting Allegheny County Department of Administrative

Services v. A Second Chance, Inc., 13 A.3d 1025, 1029 n.3 (Pa. Commw. Ct.

2011)). “The scope of review for a question of law under the [RTKL] is

plenary.” Stein v. Plymouth Twp., 994 A.2d 1179, 1181 n.4 (Pa. Commw. Ct.

2010).

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III. COUNTER-STATEMENT OF THE CASE

Appellee Tricia Mezzacappa (“Requester”) filed a RTKL request with

Appellant Borough of West Easton (“Borough”) on May 8, 2012 that sought

1) 1099s issued to the law firm McFall, Layman and Jordan from 2000 to

date; 2) year to date check register for 2011; 3) minutes of November 14,

2011 council meeting; and 4) statements of financial interest for Kelly Gross

and Tom Nodoline for each year served on Borough council (“Request”).

Reproduced Record (“R.”) at 2a. The Borough issued a response denying

the Request as disruptive under Section 506(a) of the RTKL, 65 P.S. §

67.506(a), and stating that the Request sought the same records previously

requested for inspection in separate requests made in February of 2012. R.

at 4a. The February requests for inspection indicated that Requester sought

inspection between 9:00 a.m. and 11:00 a.m. due to her work schedule. R. at

12a. The Requester withdrew the February requests for inspection after the

Borough provided access only between 1:00 p.m. and 5:00 p.m. R. at 4a.

The Borough responded to the notice of withdrawal by advising the

Requester to notify the Borough (through a new Right-to-Know request)

asking which requests for inspection the Requester desired to convert to

requests for copies. See generally Mezzacappa v. West Easton Borough,

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OOR Dkt. AP 2012-0992, 2012 PA O.O.R.D. LEXIS 967 at *1-5; Borough

of West Easton v. Tricia J. Mezzacappa, No. C-48-CV-2012-7973

(Northampton Com. Pl. Jan. 9, 2013).

Subsequently, the Requester filed the instant Request for copies of

records. See Mezzacappa v. West Easton Borough, OOR Dkt. AP 2012-

0992, 2012 PA O.O.R.D. LEXIS 967. The Borough responded to the

Request advising that it previously granted access to inspect the records

sought in Items 1, 2 and 4, but that Requester chose not to inspect the

records because the inspection time offered interfered with her work

schedule. Id . The Borough stated that responding a second time would

impose a significant burden and denied the Request as disruptive. R. at 4a.

The Requester appealed to the OOR pursuant to 65 P.S. § 67.1101(a)

and the OOR invited both parties to supplement the record with relevant

legal arguments and evidence. See Mezzacappa v. West Easton Borough,

OOR Dkt. AP 2012-0992, 2012 PA O.O.R.D. LEXIS 967. The OOR issued

a final order holding that Items 1,1 2 and 4 were not “repeated requests”

because the Requester made only a second request, and not “repeated

requests,” for those records. Id . The Borough’s denial of Item 3 was upheld

1The OOR ultimately determined that 1099s are not public records and denied the appeal

as to Item 1. Item 1 is not the subject of the instant matter before this Court.

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as disruptive because the record had been granted on multiple occasions and

the Borough devoted resources to litigating the prior requests for Item 3. Id .

The Borough appealed the OOR’s final order to the Northampton

County Court of Common Pleas pursuant to 65 P.S. § 67.1302. R. at 1a.

Judge Stephen Baratta issued an order affirming the OOR’s final order,

holding that a second request is not “repeated” and, alternatively, found that

the Borough failed to show evidence of an unreasonable burden. Borough of

West Easton v. Tricia J. Mezzacappa, No. C-48-CV-2012-7973

(Northampton Com. Pl. Jan. 9, 2013). The Borough filed the instant appeal

to this Court.

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IV. SUMMARY OF ARGUMENT

This case presents a matter of first impression before this Court

regarding what constitutes a “disruptive request” under the state’s Right to

Know Law. The law was designed to “empower citizens” to gain access to

their government records. Merely filing a second request for a government

record does not constitute a disruptive request under the Right to Know Law

which requires that two elements be present for a request to be considered

disruptive.

Section 506(a) of the RTKL permits an agency to deny a request as

disruptive if 1) the requester has made repeated requests for the same record

and 2) the agency provides sufficient evidence that responding places an

“unreasonable burden” upon the agency. This Court has previously held that

an agency must demonstrate both elements set forth in Section 506(a) of the

RTKL in order to properly deny a request as disruptive. The Borough

asserts that the trial court erred in failing to follow Office of the Governor v.

Bari, 20 A.3d 634 (Pa. Commw. Ct. 2011), but, that case is markedly

different than the case at bar. In Bari, neither party challenged whether the

second r equest was “repeated” and this Court limited its analysis to whether

the second request placed an unreasonable burden on the agency. Therefore,

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the determination as to when a requester has made “repeated requests” is a

matter of first impression before this Court.

A second request for the same record cannot constitute “repeated

requests.” If the General Assembly intended for a second request to be

disruptive, it would have been expressly stated. Silence does not equal

ambiguity. The plain language of Section 506(a) defines a disruptive request

as “repeated requests” – using the plural form of the word – rather than “a”

repeated “request.” Evidence of one prior request does not satisfy the plain

language in the first paragraph of Section 506(a), particularly, as here, where

a request for inspection was followed by a request for copies. Permitting

requesters access to inspect records prior to determining which, if any, they

wish to pay for fulfills the General Assembly’s goal of enhancing access to

governmental records.

An agency must provide evidence that responding places an

unreasonable burden upon it in order to satisfy the second paragraph of

Section 506(a), which, as this Court has held, is a high evidentiary threshold.

Here, the Borough generally states that it is a small agency with limited

resources and argues that, as such, responding to a second request for access

is per se unreasonable, but this Court has rejected mere assertions that

limited staffing or budgetary resources makes responding to RTKL requests

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unreasonably burdensome. Office of the Governor , 20 A.3d at 645. An

agency must provide actual evidence of the burden imposed. Here, the trial

court properly held that the Borough failed to meet its burden of proof,

affirming the OOR’s Final Determination.

The OOR respectfully asks this Court to hold that 1) more than two

requests are required for a request to be “repeated requests” under the RTKL

and 2) that merely responding to “repeated requests” does not, in itself,

place an “unreasonable burden” on a responding agency.

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V. ARGUMENT

Since 2009, the OOR has issued fifty-two (52) final orders assessing

whether a repeated request causes an unreasonable burden. Agencies have

successfully proven unreasonable burden by offering evidence such as: 1)

the agency previously granted access to copies of the record; 2 2) the agency

spent resources litigating the prior request;3 3) the request was previously

denied and the requester failed to appeal that decision;4 4) the request is

voluminous and requires an extensive re-review of records;5 or 5) the second

request was filed during the thirty day extension period taken by the agency

in response to the first request.6

2 See Schneller v. City of Philadelphia, OOR Dkt. AP 2011-0852, 2011 PA O.O.R.D. 559;

Rabjohn v. City of Philadelphia, OOR Dkt. AP 2011-0174, 2011 PA O.O.R.D. 90; Dreyer v. Department of Environmental Protection, OOR Dkt. AP 2009-0453, 2009 PA O.O.R.D.

LEXIS 207.3 Zloczower v. Luzerne County Correctional Facility, OOR Dkt. AP 2010-0754; 2010 PA

O.O.R.D. LEXIS 737; Cohen v. Pa. Dept. of Labor and Industry, OOR Dkt. AP 2009-0333, 2009 PA O.O.R.D. LEXIS 169.4 Laigle v. City of Pittsburgh, OOR Dkt. AP 2010-0955, 2010 PA O.O.R.D. LEXIS 909.

5 Slate v. Pa. Dept. of Environmental Protection, OOR Dkt. AP 2009-1143, 2009 PA

O.O.R.D. LEXIS 97 (noting that responding would require more than 400 hours of work

and reproduction of 2,500 pages).6 Dougher v. Scranton Schl. District , OOR Dkt. AP 2009-0798, 2009 PA O.O.R.D.

LEXIS 318.

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A. A second request for a record does not constitute

“repeated requests” pursuant to Section 506(a) of the

RTKL

Section 506(a)(1) of the RTKL permits an agency to deny a request

for records as “disruptive” if two elements are met: 1) “the requester has

made repeated requests for that same record and 2) the repeated requests

have placed an unreasonable burden on the agency.” 65 P.S. § 67.506(a) .

This Court has held that an agency must “demonstrate” the unreasonable

burden caused by the repeated requests. Office of the Governor , 20 A.3d at

645. The trial court correctly found that the Borough had not demonstrated

evidence that the request was repeated or unduly burdensome.

The Borough first asserts that the trial court erred in failing to follow

this Honorable Court’s decision in Office of the Governor . However, Office

of the Governor is distinguishable from this case because there was no

dispute by the parties as to whether the second request was repeated and this

Court limited its analysis to whether responding to a second request placed

an unreasonable burden on the agency.7 Id . Therefore, the interpretation of

7Similarly, in the OOR Final orders relied upon by the Borough, Yakim v. Municipality of

Monroeville, OOR Dkt. AP 2012-0317, 2012 PA O.O.R.D. LEXIS 267 and Makanvand v.

Borough of Loganville, OOR Dkt. AP 2012-0337, 2012 PA O.O.R.D. LEXIS 269, theOOR did not determine that a second request qualified as “repeated requests.” Rather,

the OOR merely noted that the request had been made twice and constrained its analysis

solely to whether the agency had demonstrated an unreasonable burden.

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the first prong of Section 506(a) is a matter of first impression before this

Court.

The plain language of Section 506(a) expressly states that a disruptive

request is one where the requester has made “repeated requests ” for a

particular record, not “a” repeated request. 65 P.S. § 67.506(a) (emphasis

added).

The Pennsylvania Supreme Court recently stated:

As with any question of statutory interpretation, our object is to“ascertain and effectuate the intention of the GeneralAssembly” and “if possible, to give effect to all [a statute’s]

provisions.” 1 Pa.C.S. § 1921(a). “When the words of a statute

are clear and free from all ambiguity, the letter of it is not to bedisregarded under the pretext of pursuing its spirit.” 1 Pa.C.S. §

1921(b). When the statutory language is ambiguous, however,we may ascertain the intention of the General Assembly by

considering such things as “[t]he occasion and necessity for the

statute,” “[t]he mischief to be remedied,” “[t]he object to be

attained,” and “[t]he consequences of a particular interpretation.” 1 Pa.C.S. § 1921(c).

Levy v. Senate of Pa., No. 44 MAP 2012, 2013 Pa. LEXIS 788 (Pa. Apr. 24,

2013). The General Assembly clearly did not intend a single duplicative

request for the same record to be sufficient to meet the first prong of Section

506(a). The express language in Section 506(a) only considers “repeated

requests” to be disruptive, if they are also unreasonably burdensome, 65 P.S.

§ 67.506(a). The plain language supports the trial court’s conclusion that a

single repeated request does not constitute “repeated requests.” See also

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Levy, supra at *55 (“The Commonwealth Court has aptly recognized that

courts should liberally construe the RTKL to effectuate its purpose of

promoting ‘access to official government information in order to prohibit

secrets, scrutinize actions of public officials, and make public officials

accountable for their actions’”) (quoting Allegheny County Dept. of Admin.

Services v. A Second Chance, Inc., 13 A.3d 1025 (Pa. Commw. Ct. 2011)).

The Borough argues that the trial court failed to differentiate between

the instant Request (which followed a grant of access) and cases involving

second requests where the first one was denied, citing Dreyer. However, in

Dreyer , the agency submitted evidence that it granted the prior requests and

also provided copies of the requested records in response to numerous

requests.8 Id . Here, the Borough previously granted access to inspect the

records, but the limited inspection time offered by the Borough conflicted

with the Requester’s work schedule. See R. at 8a; R. at 15a-19a. The

Requester then relied upon and followed the Borough’s own guidance and

submitted a second request, this time seeking copies. See Mezzacappa v.

West Easton Borough, OOR Dkt. AP 2012-0992, 2012 PA O.O.R.D. LEXIS

967.

8The Borough also cites to Rabjohn, supra and Schneller, supra to support its argument

that the OOR has held that a second request following a prior grant is per se disruptive.

However, like in Dreyer, the requests at issue in Rabjohn and Schneller were each, at the

very least, the third (rather than the second) requests following a grant of access. The

OOR made no determination that a second request is per se disruptive.

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In a case similar to this one, a requester sought to review documents,

and, after reviewing them, submitted a second request to obtain copies. See

Thompson v. Dickinson Township, OOR Dkt. AP 2009-0302, 2009 PA

O.O.R.D. LEXIS 162. The OOR rejected the argument that this second

request was disruptive, finding that the request for copies was not a repeated

request because the first request sought inspection, rather than duplication.

Id . The instant matter is identical to Thompson, except that, here, the

Requester withdrew the request for inspection because she was unable to

inspect records during the time frame offered by the Borough. Therefore,

even if Office of the Governor stands for the proposition that a second

request for copies of records is “repeated,” the trial court properly held that

the Requester’s request for copies, followed by a request for inspection, are

not “repeated requests” under Section 506(a).

B. An agency must provide evidence that responding to

repeated requests is unreasonably burdensome

The trial court properly refused to find that it is per se unreasonable

for a small agency to respond to a second request for records. Agencies may

not limit access to records based solely upon the burden of responding. See,

e.g ., 65 P.S. § 67.1308 (prohibiting agencies from developing a policy

limiting the number of records which may be requested); Dep’t of Envtl.

Prot. v. Legere, 50 A.3d 260, 265 (Pa. Commw. Ct. 2012); see also Pa. State

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Police v. Zloczower , No. 2082 C.D. 2010, 2011 Pa. Commw. Unpub. LEXIS

822 (Pa. Commw. Ct. 2011). However, as set forth in Section 506(a) of the

RTKL, the General Assembly did not ignore the fact that responding to

“repeated requests” for records could place an unreasonable burden on an

agency. Notably, the General Assembly did not make it a per se rule that

“repeated requests” may be denied simply because an agency lacks

resources to respond. Instead, the plain language of Section 506(a) requires

that an agency prove that responding creates a burden that is “unreasonable.”

See 65 P.S. § 67.506(a).

As with any ground for denial of access to records, an agency is

required to provide evidence to support its position. See, e.g., Lutz v. City of

Philadelphia, 6 A.3d 669, 676 (Pa. Commw. Ct. 2010) (“More than mere

conjecture is needed” to support withholding records based upon the

personal security exemption in Section 708(b)(1) of the RTKL). This Court

has previously held that the “unreasonable burden” prong is a high

evidentiary threshold. See Office of the Governor, 20 A.3d at 645. There,

this Court considered an agency’s evidence of burden and found it

insufficient to demonstrate an “unreasonable” burden. Id .

In Office of the Governor , the Office asserted it was burdened

because it had to “1) expend duplicative staff and attorney time for

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responding at length to a request that … was duplicative; 2) in a time of

significant budgetary and staffing constraints; and 3) having to devote

attorney and staff time to … a request that has been asked and answered.”

20 A.3d at 645. This Court noted that if it were to find that responding to

duplicative requests, alone, equated to an unreasonable burden, “Section

506(a) of the RTKL’s ‘unreasonable burden’ requirement would be rendered

meaningless.” Id . In requiring that an agency “explain what efforts it

undertook in responding to [the] repetitive request,” this Court followed the

established precedent that an agency must provide sufficient evidence to

support grounds for denial. Id .; see, e.g., Carey v. Pa. Dep't of Corr., 61

A.3d 367, 376 (Pa. Commw. Ct. 2013) (“[S]peculation and conclusory

statements in an affidavit do not show a reasonable likelihood of a threat to

security”); Lutz, supra.

The Borough argues that it has a small, part-time staff with

responsibilities to attend to other than responding to Right-to-Know

requests. R. at 10a. In rejecting the Borough’s assertions, the trial court

noted that the Borough, as a “governmental agency in a constitutionally

established repr esentative democracy, is in the business of public service.” .

Borough of West Easton v. Tricia J. Mezzacappa, No. C-48-CV-2012-7973,

slip op. at 10 (Northampton Com. Pl. Jan. 9, 2013). Because the trial court

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considered the Borough’s evidence of burden as required by Office of the

Governor , and rejected it as insufficient to prove an unreasonable burden,

the trial court properly held that the Borough did not establish that the

Request was “disruptive.”

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VI. CONCLUSION

The OOR, as a quasi-judicial tribunal, does not offer any input as to

the underlying merits of the final order issued by the OOR or the opinion of

the lower court. The OOR does, however, respectfully ask this Court to hold

1) that more than two requests are required for a request to be “repeated

requests” under the RTKL and 2) that merely responding to “repeated

requests” does not, in itself, place an “unreasonable burden” on a responding

agency.

Respectfully submitted,

By:

Dena Lefkowitz, Chief Counsel

Supreme Court I.D. Number 52912

J. Chadwick Schnee, Assistant Chief Counsel


Audrey Buglione, Esquire


Commonwealth Keystone Building

400 North Street, Plaza Level

Harrisburg, PA 17120-0225T: (717) 346-9903; F: (717) 425-5343

For the Office of Open Records, Amicus curiae

DATE: June 28, 2013

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