Gilbert v. Sherman

Syllabus

1. When a plaintiff in an order of protection proceeding amends her petition before a contested hearing, is it error if the court does not compel the defendant to either request a continuance or take a recess? 2. Where a plaintiff has made two prior applications for an order of protection, which were both addressed in merits hearings, did the doctrine of issue preclusion prevent her from raising evidence addressed in those prior hearings during the hearing on her third application?