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1 IN THE SUPREME COURT OF OHIO CINCINNATI BAR ASSOCIATION, Case No Relator, V. ROBERT F. ALSFELDER Respondent. RESPONDENT'S MEMORANDUM IN OPPOSITION TO RELATOR'S MOTION TO HOLD RESPONDENT IN CONTEMPT Robert F. Alsfelder 3700 Center Street Cincinnati, OH (513) voice Respondent 11 AR 0, 5 :'j e2 CLERK ^F MI IRT SUPREMELtfUr;; = uh60y ED MAR 0 5 Zo1z CI_ti2H aal f;ourt ^ StfpRLiViE COURI OF HIO Michael P. Foley ( ) 1 W. 4th Street, Suite 900 Cincinnati, OH (513) voice (513) fax s.com Counsel for Relator Stephen M. Nechemias ( ) 425 Walnut Street, Suite 1800 Cincinnati, OH (513) voice (513) fax Riechemias taft[aw.corn Co-Counsel for Relator James J. Condit ( ) PO Box Cincinnati, OH (513) voice (513) fax..c fuse.net Co-Counset for Relator

2 IN THE SUPREME.COURT OF OHIO CINCINNATI BAR ASSOCIATION, Case No Relator, v.. MEMORANDUM IN OPPOSITION TO RELATOR'S MOTION FOR ROBERT F. ALSFELDER CONTEMPT Respondent. Respondent should not be held in contempt related to the allegations that he failed to file two Notices of Disqualification and Withdrawal with the courts. Attached hereto in support of Respondent's position is Respondent's Affidavit (see Exhibit A). Attached to Respondent's Affidavit is a file stamped Notice of Disqualification and Withdrawal in the Hamilton County Juvenile Court case In re: Heidi McCollum dated December 5, 2011 (see Exhibit A, Exhibit 1). This document was refiled on March 2, 2012 out of an abundance of caution. Also attached to Respondent's Affidavit is a file stamped copy of Respondent's Notice of Disqualification and Withdrawal dated March 2, 2012 in the Warren County Domestic Relations case, Lay v. Lay, which was handfiled out of an abundance of caution (see Exhibit A, Exhibit 2). Therefore, any technical non-compliance with this Court's Order, regardless of who may have been responsible for the mistake(s), has been cured. Respondent was under the good faith belief that in both of these cases, Respondent's Notices of Disqualification and Withdrawal were of record. (see Affidavit, Exhibit A). The basis for Respondent's belief In the McCollum case is that Respondent has a time-stamped Notice of Disqualification and VVithdrawal (See Exhibit A, Exhibit 1).

3 In the Lay case, the court and/or the court's personnel acknowledged to counsel that it had received notice of Respondent's disqualification. (see Affidavit, Exhibit C). This is consistent with Respondent's Affidavit (see Affidavit, Exhibit A). There also appears to be some misunderstanding, which Respondent would like to address. In the McCollum case, the certified record shows that new counsel appeared on behalf of Respondent's former clients on August 12, 2011 and filed the Objections to Report of Magistrate's Decision (see Exhibit E attached to Relator's Motion). This occurred after Respondent's participation in that case had ended and which was prior to Respondent's suspension. After August 12, 2011, Respondent did not receive any further notices from the court in this matter nor participate further in any proceedings. In light of the fact that Respondent was not involved in the McCollum case after August 12, 2011, it was only out of an abundance of caution that the Notice of Disqualification and Withdrawal was filed. In the Lay case, new counsel took over for Respondent's former client as described in counsel's affidavit (see Affidavit, Exhibit C). In addition, additional counsel appeared as reflected in counsel's affidavit (see Affidavit, Exhibit B). As the record reflects, Respondent did not make an appearance for his former client after his suspension began. The affidavits of counsel also address some additional apparent misunderstandings regarding factual recollections as well as problems in the Warren County Clerk's office with filings being misplaced and/or misfiled (see Affidavits, Exhibit B and C). Warren County's own certified record clearly reflects a misfiled document in the Lay case (see entry on January 13, 2012 titled "Answer of Defendant ABF Freight System Inc" in Exhibit C attached to Relator's Motion). This document was obviously

4 misfiled by the Clerk's office when filed in the Lay case as it was completely unrelated to the Lay case. The court's own personnel indicated to counsel that they had been experiencing problems in filing documents and pleadings in the proper places and cases (see Affidavit, Exhibit B). In fact, a Motion for Contempt filed on behalf of Tammy Lay was either lost, misplaced and/or misfiled and could not be heard (see Affidavit, Exhibit B). Perhaps the explanation for Respondent's Notice of Disqualification and Withdrawal not appearing in the Lay file is that it too was misplaced or misfiled. Respondent attempted to fully comply with this Court's Order, and in good faith believed he had. Any technical deficiency in the same, regardless of the cause, has been corrected. For all the foregoing reasons, Respondent respecffully requests that Relator's Motion for Contempt be denied. ewectfully submitted, obert F. Alsfelder 3700 Center Street Cincinnati, OH Telephone: Facsimile: ralsfelderccr^fuse.net

5 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been served upon the following by ordinary U.S. Mail on this 3rd day of March, Michael P. Foley, Esq. Rendigs, Fry, Kiely & Dennis 1 W 4th St, Ste 900 Cincinnati, OH 45202

6 AFFIDAVIT OF ROBERT F. ALSFELDER, JR. Comes now the Affiant, and after being duly sworn testifies as follows: 1. I have personal knowledge of the facts in this affidavit. 2. I went to the Hamilton County Clerk of Court's office on December 5, 2011 and filed a Notice of Disqualification and Withdrawal in the case of In Re: Heidi McCollum, Hamilton County Juvenile Court Case No. F I had previously served said notice on all counsel of record and my former clients. Out of an abundance of caution, I refiled on March 2, 2012 a copy of the same same notice. A file stamped copy is attached as Exhibit On March 2, 2012, and out of an abundance of caution, I personally filed with the Warren County Common Pleas, Domestic Relations Division, a copy of my Notice of Disqualification and Withdrawal in Case Number 05DR 29723, Tammy R. Lay v. Randy W. Lay. I had previously served all counsel of record and my former client with a copy of this notice. A file stamped copy is attached as Exhibit 2. To the best of my recollection, I mailed a copy of my Notice of Disqualification and Withdrawal to the Warren County Clerk of Courts for filing in this matter prior to November 17, Prior to receiving the instant motion, I was of the belief that in both the McCollum and Lay cases, my Notices of Disqualificatiqq and Withdrawal were of record. Further, Affiant sayeth naught.,obert F. Alsfelder, Jr. Sworn to before me and subscribed in my presence this 2nd day of March, Notary Public DE9ORABAKER Notary Public, Stete of Ohio My Commission Expires 02-16r2014

7 HAMILTON COUNTY JUVENILE COURT IN RE: HEIDI MCCOLLUM CASE NO. F NOTICE OF DISQUALIFICATION AND WITHDRAWAL The undersigned hereby gives notice of his disqualification to act as attorney for Respondents and withdrawal as counsel in this matter for Respondents due to the suspension of his law license by Order of the Ohio Supreme Court dated September 22, The undersigned may be contacted at the address be!$^v. Robert F. Alsfelder, Jr Center Street Cincinnati, OH (513) CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing was filed with the Court and served by certified mail, return receipt requested this 28th day of November, 2011 upon: Donald L. Weber, Esq., Counsel for Petitioner Weber, Dickey & Bellman 1726 Young Street Cincinnati, OH Stephen R. King, Esq., Co-Counsel for Respondents King, Koligian & Associates 9370 Main St., Al Montgomery, OH Bradford C. Weber, Esq., Co-Counsel for Respondents Benjamin, Yocum & Heather, LLC 300 Pike St. Ste. 500 Cincinnati, OH Russell McCollum and Ramona Lohr 3814 Simpson Ave. Cincinnati, OH 45227

8 COURT OF COMMON PLEAS DIVISION OF DOMESTIC RELATIONS WARREN COUNTY, OHIO TAMMY R. LAY V. RANDY W. LAY Case No. 05 DR NOTICE OF DISQUALIFICATION AND WITHDRAWAL The undersigned hereby gives notice of his disqualification to act as attorney for Tammy R. Lay and withdrawal as counsel in this matter for Plaintiff due to the suspension of his law license by Order of the Ohio Supreme Court d** September 22, The undersigned may be contacted at the address below. Robert F. Aisfelder, Jr Center Street Cincinnati, OH (513) CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing was filed with the Court and served by certified mail, return receipt requested this 28th day of November, 2011 upon: John Mulvey, Esq Park Ave Cincinnati, OH Deborah T. Alsfelder, Esq Center St Cincinnati, OH Tammy R. Lay 3050 N Palm Aire Dr, No 708N Pompano Beach, FL , Robert F. Aisfelder,Jr. ^

9 AFFIDAVIT OF BRADFORD C. WEBER, ESQ. Comes now the Affiant, and after being duly sworn testifies as follows: 1. I have personal knowledge of the facts in this affidavit. 2. I am counsel for Tammy R. Lay in Warren County Common Pleas, Domestic Relations Division, Case Number 05DR29723 styled Tammy R. Lay v. Randy W. Lay. 3. After speaking with the Court on January 11, 2012, I sent for filing, that day, by facsimile and regular mail, a Notice of Appearance, Motion for Continuance and Entry Granting Continuance. File stamped copies of these documents, including a signed order granting same, along with a file copy of my related transmittal correspondence and facsimile confirmation, are attached hereto as collective Exhibit I sent for filing, by regular mail, a motion for contempt on February 1, A file stamped copy and copy from my file of the related transmittal correspondence is attached hereto as collective Exhibit At hearing on February 3, 2012, I was informed by the Court that I could not proceed with my Motion for Contempt in the case due to the fact that the Court could not locate my filed Motion. Further, I was told at that time that there were filings in the Lay v. Lay case file that were from another, unrelated case and that these filings did not belong in Lay v. Lay case. 6. In a subsequent phone conversation with the Clerk of Court's office following the February 3, 2012 hearing in Lay v. Lay, I was told that the Court had found my Motion for Contempt in another case file. I was also told at that time by the Clerk's office that they had been experiencing numerous incidents where documents and pleadings had been misfiled by their office. 7. Further, Affiant sayeth naught. Bradford C. Weber, Esq. Sworn to before me and subscribed in m,moer&e this 2nd day of March, CHARLES F. HOLLIS, III Attorney at Law Notary Public, State of Ohio My Commission Has No Expiration Date. Section O.R.C.

10 BYH ATTORNEYS AT LAW TNomASR.YocuM TIMOTHY P. HEATHER ANTNONYJ.IACIOFANO0 L1SA M. BITTER BRADFORD C. WEBER t CHARLES F. HOLLIS, III }@ BENJAMIN, YOCUM & HEAT AMERICAN BOOK BUILDING 300 PIKE STREET SUITE 500 CINCINNATI, OHIO (513) FAX: (513) WEB SITE: byhlaw.corn info@byhlaw.com JULIE A. NEUROTH, OF COUNSEL # PATRICK M. O'NEILL, OF COUNSEL JOSE PEDRO SANTOS, SR. PARALEGAL ' ALSOADMITTED IN KENTUCKY AND FLORIDA } ALSO ADMITIED IN KENTUCKY AND INDIANA 0 ALSO ADMITTEDIN LL.M. INTERNATIONAL LAW # ADMITTEDIN KENTUCKY ONLY AMERICAN ALLIANCE CERTIFIED PARALEGAL & OSBA CERTIFIED PARALEGAL JOHN A. BENJAMIN (1914-2U99) VIA FACSIMILE (513) and U.S. FIRST-CLASS MAIL Warren County Court of Common Pleas Assignment Commissioner Attn: Pam Jackson 500 Justice Drive Lebanon, Ohio RE: Tammy R. Lay v. Randy W. Lay; Case No. 05DR29723 Dear Ms. Jackson: Please find attached my Notice of Appearance, a Motion for Continuance and an Entry Granting Continuance for the convenience of the Court. I am sending this to you pursuant to the phone scheduling conference with Magistrate Iverson and opposing counsel, John Mulvey that we had today. Mr. Mulvey is in agreement with the request for continuance. Please file my appearance and present the Motion to Continuance and Entry to Magistrate Iverson. You may contact me or my secretary in my absence, Donna Devine, to schedule a new hearing date. Please contact me if you have any questions or require anything further of me. As always I remain, - Very truly yours, BENJAMIN, YOCUM & HEATHER, LLC Bradford C. Weber BCW/dmd Enclosures Cc: John Mulvey (via with encls.)

11 c^. - ^ ^ti^, THE COURT OF COMMON PLEAS, WARREN COUNTY DOMESTIC RELATIONS DI^LStIQAF., i 3 A^ 9' t^ C gr,;^tt1 ^C CUURSS TAMMY R. LAY Plaintiff V. CASE NO.: 05DR29723 NOTICE OF APPEARANCE OF COUNSEL RANDY W. LAY Defendant. COMES NOW, Bradford C. Weber, and gives notice of his appearance as counsel for Tammy R. Lay. The contact information for Bradford C. Weber is below. Respectfully submitted, BENJAMIN, YOCUM & HEATHER, LLC Bradford C. Weber ( ) BENJAMIN, YOCUM & HEATHER, LLC 300 Pike Street, Ste. 500 Cincinnati, OH Telephone: Facsimile: bcweber@byhlaw.com Attorney for Plaintiff, Tammy R. Lay 1

12 CERTIFICATE OF SERVICE I hereby certify a copy of the foregoing Notice of Appearance of Counsel was served via facsimile and ordinary U.S. mail this 11th day of January, 2012, upon the following: John Mulvey ( ) Attorney for Plaintiff 2306 Park Avenue Cincinnati, Ohio (513) FAX: (513) Bradford C. Weber( ) 2

13 THE COURT OF COMMON PLEAS, WARREN COUNTY DOMESTIC RELATIONS DIVISION 20I2 JAN 3 AM 9.41 TAMMY R. LAY Plaintiff V. RANDY W. LAY Defendant. CASE NO.: 05DR29723 MOTION TO CONTINUE CLERK u,co(,'rts COMES NOW, Bradford C. Weber, new counsel for Tammy R. Lay, and respectfully moves this Court to continue the trial of this matter that is currently set for Monday, January 23, As grounds for this motion the undersigned counsel states that he has only recently been retained in the case. Furthermore, the undersigned has been scheduled to be on vacation and will be on vacation out of state the entire week of the scheduled hearing. Counsel for Randy W. Lay, John Mulvey, Esq., is in favor of the continuance. WHEREFORE, the undersigned requests a continuance of said hearing after February 1, This Motion is not being made for purposes of delay. Respectfully submitted, BENJAMIN, YOCUM & HEATHER, LLC Bradford C. Weber ( ) BENJAMIN, YOCUM & HEATHER, LLC 300 Pike Street, Ste. 500 Cincinnati, OH Telephone: Facsimile: bcweber e,byhlaw.com Attorney for Plaihtiff, Tammy R. Lay 1

14 CERTIFICATE OF SERVICE I hereby certify a copy of the foregoing Notice of Appearance of Counsel was served via facsimile and ordinary U.S. mail this 11th day of January, 2012, upon the following: John Mulvey ( ) Attorney for Plaintiff 2306 Park Avenue Cincinnati, Ohio (513) FAX: (513) Bradford C. Weber ( ) 2

15 THE COURT OF COMMON PLEAS, WARREN COUNTY DOMESTIC RELATIONS DIVISION J (' l12 JAN 13 AM T. 4 I TAMMY R. LAY Plaintiff V. CASE NO.: 05DR29723 QR,DE-R L{ CLERK G^ C^^i^TS EXTRZT"RANTING MOTION FOR CONTINUANCE RANDY W. LAY Defendant. Upon Motion of counsel Bradford C. Weber to continue the trial currently scheduled for January 23, 2012, opposing counsel's agreement and the court being sufficiently advised, it is hereby ordered, decreed and adjudged that the trial currently scheduled for January 23, 2012 be rescheduled until /'(/^ SO ORDERED. Distributed to: Bradford C. Weber t ) John Mulvey ( ) BENJAMIN, YOCUM & HEATHER, LLC 2306 Park Avenue 300 Pike Street, Ste. 500 Cincinnati, Ohio Cincinnati, Ohio Prepared by: Bradford C. Weber (# ), BENJAMIN, YOCUM & HEATHER, LLC, 300 Pike Street, Suite 500,Cincinnat4 OH Tel: (513) Fax: (513)

16 ACTIVITY REPORT TIME : 01/11/ :30 NAME. FAX TEL SER.# : BROF8J NO. DATE TIME FAX N0./NAME DURATION PAGE(S) RESULT COMMENT 01/04 01: OK RX ECM 01/04 13: OK RX ECM 01/04 13: OK RX ECM 01/04 14: :11 05 OK RX ECM 01/04 20: OK RX ECM 01/05 01: OK RX ECM 01/05 09: OK RX ECM 01/05 20: :12 06 OK RX ECM 01/06 01: OK RX ECM 01/06 09: NG RX ECM 01/06 13: OK RX ECM #424 01/06 14: :14 09 OK TX ECM #425 01/06 16: OK TX ECM 01/07 01: :01 01 OK RX ECM 01/07 16:01 01:59 05 OK RX ECM 01/09 11: OK RX ECM 01/09 12:11 01:09 05 OK RX ECM 01/09 12: OK RX ECM #426 01/09 13: BUSY TX #427 01/09 13: BUSY TX #428 01/09 13: BUSY TX #429 01/09 15: :13 05 OK TX ECM 01/09 20: OK RX 01/09 21:25 01:17 01 OK RX 01/10 01: :02 01 OK RX ECM 01/10 09:57 01:02 07 OK RX ECM #431 01/10 10: OK TX ECM 01/10 10: NG RX 01/10 10: NG RX ECM 01/10 11:13 01:34 11 OK RX ECM 01/10 11:36 02:14 10 OK RX ECM 01/10 12: OK RX ECM 01/10 13: :18 08 OK RX ECM 01/10 16: OK RX ECM 01/10 16:58 01:09 02 OK RX 01/11 01: OK RX ECM 01/11 10: NG RX ECM #432 01/11 10: OK TX ECM BUSY: BUSY/NO RESPONSE NG : POOR LINE CONDITION / OUT OF MEMORY CV : COVERPAGE POL : POLLING RET : RETRIEVAL PC : PC-FAX

17 BYH ATTORNEYS AT taw THoMAsRYocuM- TIMOTHYP.HEATHER ANTHONYJ.IACIOFANOO LISA M. BITTER BRADFORD C. WEBER t CHARLES F. HouJS, III f@ BENJAMIN, YOCUIYI & HEATHER, LLC AMERICAN BOOK BUILDING 300 PIKE STREET SUITE 500 CINCINNATI, OHIO (513) FAX: (513) WEB SITE: byhlaw.com info@byhlaw.com JULIEA.NEUROTH,OF COUNSEL# PATRICK M. O'NEILL, OF COUNSEL JOSE PEDRO SANTOS, SR. PARALEGAL ' ALSO ADMITTED IN KENTOCKYAND FLORIDA t ALSO ADMITTED IN KENTUCKY AND INDIANA 0 ALSO ADMITTED IN LL.M. INTERNATIONAL LAW 4 ADMITTED IN KENTUCKY ONLY AMERICANALLIANCE CERTIFIED PARALEGAL & OSBA CERTIFIED PARALEGAL February 1, 2012 JOHN A. BENJAMIN ( ) Warren County Court of Common Pleas Clerk 500 Justice Drive Lebanon, Ohio RE: Tammy R. Lay v. Randy W. Lay; Case No. 05DR29723 To Whom It May Concern: Enclosed please find a Motion for Contempt on behalf of Plaintiff, Tammy R. Lay. Please file same and return a time-stamped copy in the self-addressed, stamped envelope provided. Please contact me if you have any questions or require anything further of me. As always I remain, Very truly yours, BENJAMIN, YOCUM & HEATHER, LLC Donna M. Devine, Legal Secretary to Bradfor C. Weber DMD/i Enclosure Cc: John Mulvey (via and reg. mail with encls.)

18 THE COURT OF COMMON PLEAS, WARREN CO DOMESTIC RELATIONS DIVISION 20I2 FEB -3 PM 4: 0 4, TAMMY R. LAY Plaintiff V. CASE NO.: 05DR2972 "'^'" ^ ( ' '1 tlerk QF COURTS MOTION FOR CONTEMPT RANDY W. LAY Defendant. COMES NOW, Plaintiff, Tanuny R. Lay (hereinafter "Wife"), by and through counsel and respectfally moves this Court for an Order finding Defendant Randy W. Lay (hereinafter "Husband") in contempt The grounds for contempt are Husband's non-payment of spousal support, pursuant to decree. This Motion is supported by the pleadings and attached Memorandum. Respectfully submitted, BENJAMIN, YOCUM & HEATHER, LLC Bradford C. Weber ( ) BENJAMIN, YOCUM & HEATHER, LLC 300 Pike Street, Ste. 500 Cincinnati, OH Telephone: Facsimile: bcweber@.byhlaw.com Attorney for Plaintiff, Tammy R. Lay 1

19 MEMORANDUM Counsel for Wife has been advised by Wife that Husband, Randy W. Lay remains in arrears as to his monthly spousal support obligation. Pursuant to the Judgment Entry and Decree of Divorce entered on June 29, 2006: 2.01 Beginning on June 1, 2006, and continuing for a period of eight (8) years, Husband shall pay Spousal Support to Wife in the amount of $ per month. Wherefore, Tammy R. Lay prays for a finding that Randy W. Lay is in contempt of Judgment Entry and Decree of Divorce, for an order requiring Randy W. Lay to pay all spousal support due, in an amount to be established at trial, and for all other relief to which Tammy R. Lay may be entitled. Respectfully submitted, BENJAMIN, YOCUM & HEATHER, LLC Bradford C. Weber ( ) BENJAMIN, YOCUM & HEATHER, LLC 300 Pike Street, Ste. 500 Cincinnati, OH Telephone: Facsimile: bcweber@byhlaw.com Attomey for Plaintiff, Tammy R_ Lay 2

20 CERTIFICATE OF SERVICE I hereby certify a copy of the foregoing Motion was served by and ordinary U.S. mail this Ist day of February, 2012, upon the following: John Mulvey ( ) 2306 Park Avenue Cincinnati, Ohio Bradford C. Weber( ) 3

21 AFFIDAVIT OF DEBORAH ALSFELDER, ESQ. Comes now the Affiant, and after being duly sworn testifies as follows: 1. I have personal knowledge of the facts in this affidavit. 2. I represent Tammy R. Lay, who is a party in Warren County Common Pleas, Domestic Relations Division, Case Number 05DR29723 styled Tammy R. Lay v. Randy W. Lay. 3. On November 17, 2011, I attended a telephone conference with the Court on behalf of Tammy Lay and in place of Robert Alsfelder who had been suspended from the practice of law by Order of The Supreme Court of Ohio. Prior to this phone ^c s; n. 0.^'^^"f myrvss} 'onox conference, I had spoken with the Court^n^d c^nrmed t^iat they had received notice of Robert Alsfelder's suspension from the practice of law. At that time, I also informed the Court that I would be taking over the case. 4. I again participated in a telephone conference with the Court on behalf of my client on December 28, At that time, my elderly grandfather's medical condition had seriously deteriorated and I was in the process of moving him to hospice care while at the same time caring for my grandmother. I am attaching as Exhibit 1 an transmission that I had sent to Mr. Lay's counsel, John Mulvey, the day prior to the scheduled telephone conference in that regard. In this phone conference, I also told the Court that I was going to need the assistance of attorney Bradford Weber with this case, because of my commitments to my grandmother and now gravely ill grandfather. 5. At hearing on February 3, 2012, I was informed by the Court that the Court could not proceed with our client's Motion for Contempt due to the fact that the Court could not locate said Motion in its file. 6. Further, Affiant sayeth naught. Deborah Alsfelder, Esq. Sworn to before me and subscribed in my presence this 2Dd day of March, MICHELLE R. SH ENAAKER Notary Public, State of 0hio My Commission EtOres February

22 From: Subject: Re: Lay v Lay Date: December 28, :51:37 PM EST To: "Deborah Alsfelder" <dalsfelder@gmail.com> Dear Debbi, I am just now reading your and I am sorry to hear of what you are going through. I got home at 11:30 last night and picked up Magistrate Iverson's conference call on the way into the office this morning. If there is anything I can do, either by handing the matter over to the new attorney or otherwise, please let me know. John Mulvey... Sent from my I-IP TutxhPad On Dec 27, :33 PM, Deborah Alsfelder <dalsfelder@gmail.com> wrote: John, I believe we have a conference call with the Magistrate scheduled for tomorrow morning. I am right now in the process of moving my grandfather from a nursing home to Hospice care. Tomorrow morning could not be a worse time for me under these circumstances. I'm having to deal with my ill 89- year old grandfather and my 94-year old grandmother. Do you think we could postpone this for a week for two? Thank you. Debbi Alsfelder

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