The indictment sufficiently charged first-degree contempt under Penal Law § 215.51 (c), which involves violation of a certain kind of order of protection, committed by a person with a prior conviction of a similar crime. Defendant argues that his indictment was jurisdictionally defective because the special information that was filed to elevate each count of second-degree contempt to first-degree contempt did not explicitly allege either that the prior second-degree...
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