VIRGINIA:

IN THE CIRCUIT COURT FOR THE CITY OF ALEXANDRIA

NATALIA DALTON

Petitioner,

v.
Case Nos. CJ 14001064
and CJ 14001065
JULIO LACAYO,

Respondent.

In Re: Ethan Lacayo-Dalton

Date of Birth: February 11, 2008

MOTION FOR CLARIFICATION AND MODIFICATION OF ORDER

COMES NOW the Petitioner, Natalia Dalton, by counsel, and hereby respectfully

requests that the Court clarify and modify the court's verbal explanation announced at a hearing

on June 15, 2018, and order the Alexandria Detention Center to immediately release Natalia

Dalton from custody, and for her grounds states as follows:

1) The Court by the Honorable Lisa Kemler announced its reasoning and conclusion

on pending issues before the Court in a hearing held for delivering the Court's order on June 15,

2018, which was very extensive and took approximately 30-40 minutes to read into the record

before a Court Reporter.

2) Although in counsel's view the statement read sounded finished and sufficiently

polished to be published as a memorandum opinion of the Court's decision, and seemed to be

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exhaustively detailed to serve as a full explanation, the Court did not yet release the statement of

reasons as an opinion or order or other statement for officially supporting the Court's orders in

these matters.

3) However, the Bailiff and Sheriff's Office took Natalia Dalton into custody to serve

a 5 day term of punishment for contempt of court.

4) However, there is no order from the Court at this time.

5) Judge Kemler directed Donne Colton, attorney for Julio Lacayo, to draft an order.

6) From discussions with the court reporting company, Casamo & Associates, as of

Saturday the transcript of Judge Kemler's verbal explanation of her decision had not yet been

ordered, when counsel for Natalia Dalton asked for an estimate of the transcript.

7) Drafting written versions of orders through counsel in this case and other cases in

this Court have often taken as long as 2 months to go through the process of being drafted and

agreed upon and signed by this Court.

8) Since no written order has been drafted, signed, and entered sentencing Natalia

Dalton to five days in jail, it was error for Natalia Dalton to be taken into custody.

9) But perhaps worse there is also no order instructing the Alexandria Detention

Center when to release Natalia Dalton.

10) While five days in jail is a significant injury legally and practically, it is too short a

time starting from a Friday to file a habeas corpus proceeding.

11) However, in the absence of a written order, counsel is informed that there is

continuing confusion about when Natalia Dalton will be released. She is being told different

things day by day about when she can expect to be released, met with transportation, etc.

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 WHEREFORE, Natalia Dalton, by counsel, requests that the Court clearly order the

Alexandria Detention Center as to when she is to be released.

RESPECTFULLY SUBMITTED,
NATALIA DALTON, By Counsel

Virginia State Bar #41058

3823 Wagon Wheel Lane
Woodbridge, Virginia 22192
Telephone: (703) 656-1230
Fax: (703) 783-0449

CERTIFICATE OF SERVICE

I hereby certify that the foregoing Motion was emailed by first-class mail, postage

prepaid, to:

Donne Colton, Esq.

510 King Street, Suite 400
Alexandria, Virginia 22314
Telephone: (703) 549-9703
Facsimile: (703) 836-4385
Email: Colton@lawDMC.com
Counsel for Julio Lacayo

Debra S. Bray, Esquire

Amole & Bray, PC
437 N. Lee Street
Alexandria, Virginia 22314
Guardian Ad Litem for Minor Child Ethan