STATE OF MINNESOTA DISTRICT COURT

COUNTY OF DAKOTA FIRST JUDICIAL DISTRICT

Case Type: Harassment

David Rucki, Samantha Rucki and Court File No.: 19AV-CV-17-1950

and o/b/o Minor Children Judicial Officer: Phillip Kanning

Petitioners,

v. PETITIONERS’ NOTICE OF MOTION TO EXTEND

HARASSMENT RESTRAINING ORDER

Deirdre Elise Evavold

Respondent

TO: Deirdre Elise Evavold, Respondent above named, and her attorney, Paul
Godfread, Esq., Larkin Hoffman Daly & Lindgren, LTD, 8300 Norman Center
Drive, #1000, Minneapolis, MN 55437:

PLEASE TAKE NOTICE, at on a date and time to be determined or in the

alternative, taken under administrative review, before the Honorable Phillip Kanning, Judge

of District Court, located at the Dakota County District Court, Apple Valley, Minnesota,

Petitioners herein will move the Court for an Order as follows:

1. Ordering the current Harassment Restraining Order, set to expire on July 28,

2019, be continued for a period of 50 years, pursuant to Minn. Stat. § 609.748, Subd. 5(3);

2. Finding that there are reasonable grounds that the Respondent has engaged

in harassment and will continue to do so if not granted;

3. Finding that the Respondent above named has had two or more of violations

of the Harassment Restraining Order since it was was entered on July 28, 2017;

4. Finding that Respondent above named was found in contempt of this Court

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relating to the violations;

5. Finding that Respondent above named was taken into custody on March 18,

2018 and remained in custody until March 21, 2018, due to her ongoing violations of the

HRO and this Court’s March 1, 2018 Order;

6. For such other and further relief as is just and equitable.

Said motion will be made to the Court based upon the Declarations of David V.

Rucki, Samantha Rucki, and Gianna Rucki, arguments of counsel, and all pleadings,

records and files herein.

Dated: July 19, 2019 ELLIOTT LAW OFFICES, P.A.

By: /s/Lisa M. Elliott________

Lisa M. Elliott, #201923
Attorneys for Petitioners
2409 West 66th Street
Minneapolis, Minnesota 55423
(612) 466-7190
lisa@eHiottlaw.net

ACKNOWLEDGMENT

The undersigned hereby acknowledges that costs, disbursements, and

reasonable attorney and witness fees may be awarded pursuant to Minn. Stat. §
549.21, Subd. 2, to the party or parties against whom the allegations in this pleading
are asserted.

Dated: July 19, 2019

By: /s/Lisa M. Elliott_________
Lisa M. Elliott, #201923