In People v. Casey (95 NY2d 354 [2000].), the defendant was charged with criminal contempt for violating an order of protection and the People never filed the certified copy of the order of protection. On appeal, the defense counsel argued that without the order of protection, the information was jurisdictionally defective under CPL 100.40 (1) (c) because the People failed to assert nonhearsay statements alleging that: (1) the order of protection was outstanding and in effect, and (2) the defendant had knowledge of the order. The Court stated that the accusatory instrument charging criminal contempt should: (1) give the defendant sufficient notice to prepare a defense, (2) be adequately detailed to prevent the defendant from being tried twice for the same offense, and (3) demonstrate firsthand knowledge that the order was granted, was in effect and was violated by the defendant. (Casey, supra at 357.) In Casey, the record reflected that the complainant showed a certified copy of the order containing defendant's signature and acknowledgment of receipt of service to the detective. The defendant also admitted to the detective in their initial telephone conversation that he was served with the order. The Court found that the defendant's admission coupled with the detective's firsthand knowledge of the order and receipt of service thereof sufficiently demonstrated the defendant was aware of an effective order of protection. The Court of Appeals held that the first-party allegations of the complainant and detective regarding the issuance, terms and service of the order of protection4 were sufficient to establish criminal contempt in the second degree (Casey, 95 NY2d at 359-360). There, the complainant had signed a supporting deposition attesting that an order of protection had been issued against the defendant, prohibiting him from harassing her (id. at 360). The complainant also swore that she personally had observed the defendant engage in conduct proscribed by the order (id.). The Court noted that "the fair implication of these averments established [the complainant's] firsthand knowledge that the order had been granted, was in effect and was violated by defendant's harassing or criminal conduct on the date of the offense" (id.). The Court ruled that although the "far better practice" would have been to annex the underlying order of protection, the failure to do so "did not require reversal under the particular circumstances of this case" (id.). In Casey, the detective alleged in the information that " 'the defendant was advised and served a copy of the Order of Protection in court' " (Casey, 95 NY2d at 361). The detective did not state the basis for his belief, which could have come from information provided to him by the complainant rather than personal knowledge, and therefore would have constituted hearsay (id. at 361). Because the defendant did not raise this objection, the Court deemed that he had waived it (id. at 362). In any event, the Court noted that any hearsay defect could have been cured by filing the certified copy of the order of protection containing the defendant's acknowledgment of receipt or by alleging the defendant's admission that he was served with the order (id. at 361-362). The Court of Appeals considered how hearsay in a misdemeanor information affected the trial court's jurisdiction. The Court reiterated that " Whether the allegation of an element of an offense is hearsay, rendering the information defective, is to be determined on a facial reading of the accusatory instrument ." (Casey at 361.) The Court specifically held that a "hearsay pleading violation of CPL 100.40 (1) (c)" is not a "jurisdictional and non-waivable" defect robbing the trial court of jurisdiction over the matter. (Casey at 362.)