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Mentor Municipal Court – 1/6/99
Summons (Rules 4 and 9)
Case Number: CRB 9900019
The State of Ohio, City of Mentor vs. Smith, Loretta D.

A Complaint, a copy of which is attached hereto, has been filed in the above named court charging you with the following: 131.04 ASSAULT. You are hereby summoned and ordered to appear in this Court at 10:00 AM within three days after receipt of this summons. –Clerk of the Court

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EXHIBIT A

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Juvenile Division, Lake County, Ohio
Complaint of Contempt of Visitation Order
Case Number 97 CV 0314
Judge William W. Weaver
Plaintiff: John Doe, Mentor, Ohio
Defendant: Loretta D. Smith, Avon Lake, Ohio

1. I, John Doe, am the natural and legal father of Little Doe who was born on xx/xx/xx.

2. Paternity of my child was established by administrative order pursuant to R.C. Sections 3111.20 to 3111.29, as provided by R.C. Section 3111.02. A copy of my paternity order is contained in the case file.

3. The defendant, Loretta D. Smith, is the mother and custodial parent of my child, Little Doe.

4. On December 10, 1997, a visitation order was entered into judgment provided by R.C. Section 3108.051.

5. In May of 1998, an amended visitation schedule was drafted by the defendant and agreed upon by both parties. (a copy which is contained in the case file.)

6. On December 8, 1998, a complaint of contempt was filed and is pending in the Lake County Juvenile Court.

7. On December 27, 1998, by telephone conversation, Ms. Smith said she would pick up the child a day early on Monday at my residence. She told me that she was not going to allow her daughter to be in the presence of my "Pregnant, junk yard dog, of a girlfriend," any longer than necessary, and that her lawyer was going to drag my girlfriend’s name through the mud, and I’d be lucky to have a supervised visitation when they’re done with me. I made it clear to Ms. Smith that under no circumstances was she to come to my home that day, and that she may come at the agreed day and time, which was Tuesday, December 29, 1998 at 5:30 PM.

8. On Monday, December 28, 1998, I returned home from work, got cleaned up and went to a doctor’s appointment, leaving my daughter in the care of my pregnant fiancé, Jane Doe, who also has a small child. Ms. Smith showed up at my home. Jane took the children into the bedroom and turned on the television for them. Ms. Smith continued to ring the doorbell and bang on the door and windows of the home, upsetting the dog and children. Jane answered the door and asked Ms. Smith to please stop and to leave. Ms. Smith asked where I was and when Jane said I wasn’t home Ms. Smith said she was there to get Little Doe. Jane told Ms. Smith that she was not going to hand the child over and that Ms. Smith should go to the Mentor Police Department, if she needed to.

At that point Ms. Smith grabbed the glass storm door, which was closed, and opened it forcing her way into the house. Jane went to grab the handle of the door and Ms. Smith punched Jane in the nose cutting it open at the top. Ms. Smith was then in the house screaming obscenities and Jane tried pushing her out the door asking her to get out of the house. Ms. Smith hit Jane again in the mouth breaking her bottom lip open. Jane was able at that point to push Ms. Smith out the door and close it. Ms. Smith continued her assault on the doorbell and banging on the windows. Jane called the police and informed Ms. Smith they were on their way. At that, Ms. Smith got in her car and fled. An assault charge was filed. (A copy of the report is attached to complaint.)

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