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IN THE DISTRICT COURT IN AND FOR OKMULGEE COUNTY

STATE OF OKLAHOMA
Xxxxxxxxxxxxxxx , )
Plaintiff, )
-vs- ) No. PO-xxxxxxxxxxx
xxxxxxxxxxxxxxx )
Defendant. )

MOTION TO VACATE PROTECTIVE ORDER & REQUEST FOR


EMERGENCY HEARING

COMES NOW the above-named Defendant, xxxxxxxxx, by and through


his attorney, Bruce Edge, and moves this Honorable Court to vacate the
above referenced protective order and grant an emergency hearing on the
matter, on the grounds and for the reasons that:
1. The order was entered in violation of xxxxxxxx right to due process.
Specifically
service was never perfected on xxxxxxxx and he had no notice of
the hearing.
2. The protective order was served on xxxxxxxxxxxxxxxBroken Arrow
Oklahoma 74012. This is not effective service pursuant to 22
O.S. § 60.4 and 12 O.S. § 2004
3. An emergency hearing is needed due to the fact that this is a crucial
issue in a trial
set for July 8th, 2002 in Tulsa County District Court.

THEREFORE this Defendant prays this honorable court grant an emergency


hearing on this motion to vacate the above referenced Protective order.

Respectfully submitted,

___________________________
Bruce Edge # 18697
717 S. Houston, Suite 500
Tulsa, OK 74127
918-582-6333
Attorney for Defendant
CERTIFICATE OF DELIVERY

This is to certify that on this 20th day of June, 2002, a true and correct

copy of the above and foregoing Motion to Vacate and request for emergency

hearing was delivered to the Tulsa County Sheriff’s office within and for Tulsa

County, State of Oklahoma.

______________________________
Bruce Edge # 18697
Attorney for Defendant
IN THE DISTRICT COURT IN AND FOR OKMULGEE COUNTY
STATE OF OKLAHOMA

CLARINDA ELIZABETH REICHMANN, )


Plaintiff, )
-vs- ) No. PO-2001-192
RICHARD B. MOUCHANTAF )
Defendant. )

ORDER

IT IS HEREBY ORDERED THAT said Motion for Okmulgee County, Okmulgee,

Oklahoma, for a vacating of the above referenced Protective Order _____ day of

_________, 20____, be hereby granted on the _____ day of ____________, 20___, at the hour of

___:___ __.m.

DATED this _____ day of _________, 20___.

_________________________________________
JUDGE OF THE DISTRICT COURT
IN THE DISTRICT COURT IN AND FOR OKMULGEE COUNTY
STATE OF OKLAHOMA

CLARINDA ELIZABETH REICHMANN, )


Plaintiff, )
-vs- ) No. PO-2001-192
RICHARD B. MOUCHANTAF )
Defendant. )

ORDER

IT IS HEREBY ORDERED THAT said request for Emergency hearing filed in the

District Court Clerk's Office, Okmulgee County, Okmulgee, Oklahoma, on the _____ day of

_________, 20____, be hereby set for hearing on the _____ day of ____________, 20___, at the

hour of ___:___ __.m.

DATED this _____ day of _________, 20___.

_________________________________________
JUDGE OF THE DISTRICT COURT
VERIFICATION

STATE OF OKLAHOMA )
) ss.
COUNTY OF OKMULGEE )

Richard Mouchantaf, of lawful age, after first having been duly sworn upon oath, deposes
and states: That he is the above named defendant; that he has read the above and foregoing
motion to vacate and request for emergency hearing; and that the contents contained therein are
true and correct to the best of his knowledge.

______________________________
Richard Mouchantaf

Subscribed and sworn to before me this ___________ day of _________, 2002

______________________________
Notary Public

My commission expires:

________________________