Pursuant to Rule 24 (j), R. Utah S. Ct., defendant LDS Social Services hereby submits the following supplemental authority for Point III of its Respondents' Brief, pertaining specifically to the validity of the presumption of abandonment in U.C.A. § 78-30- 4(3)(c).
Public record document (some rights may be reserved).
Legal Brief, Swayne v. L.D.S. Social Services, No. 880384 (Utah Supreme Court, 1988).