MEMORANDUM OF LAW

SUPREME COURT OF THE STATE OF NEW YORK APPELLATE DIVISION: SECOND JUDICIAL DEPARTMENT
In the Matter of Winona P. (Anonymous). Appellate
Suffolk County Department of Social Services, Div. No.
Petitioner-Respondent; Winona P.(Anonymous),
Appellant; Paul P. (Anonymous), nonparty-Respondent 2010-06768
2010-06769
(Fam. Ct. Docket No. NN-16863-09)
APPELLANT'S MEMORANDUM OF LAW
Gina M. Scelta, Esq. Attorney for Appellant P.O. Box 407 Centerport,NY 11721


TABLE OF CONTENTS
TABLE OF CASES AND AUTHORITIES i
PRELIMINARY STATEMENT 1
ISSUES ON APPEAL 2
HISTORY OF THE CASE 3
ARGUMENTS 11
I Did the lower Court, err when it issued its
June 23, 2010 Order of Protection? 11
II Did the Court, in its June 23 Order, finding
Appellant to be neglectful by a preponderance of the evidence? 12
CONCLUSION 20
STATEMENT UNDER CPLR 5531 ii
CERTIFICATE OF COMPLIANCE PURSUANT
TO 22 NYCRR § 670.10.3(f) iv.
APPENDIX
NOTICE OF APPEAL (2) a-1
ORDER a-2
SUBPOENA a-3
CERTIFICATION OF APPENDIX b-1