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COLEMAN, BERNHOLZ, DICKERSON, <br /> BERNHOLZ, GLEDHILL & HARGRAVE 014 <br /> ATTORNEYS AT LAW <br /> 110 CR-ORTON STREET <br /> IILLISBOROUGEf,N.C.27278 <br /> 919-732-2196 <br /> 919-942-8000 <br /> CHAPEL RILL OFFICE <br /> 1.)11"E 20.FRANKLIN BUILDING <br /> 137 E.FRANKLIN STREET <br /> CHAPEL HILL,N.C.27514 September .1 , 1985 <br /> 919-928-7m <br /> ALONZO B.COLEMAN,JR. <br /> STEVEN A.BERNHOLZ <br /> DONALD R.DICKERSON <br /> ROGER B.BERNHOLZ <br /> GEOFFREY E.GLEDHILL <br /> DOUGLAS HARGRAVE <br /> MARTIN J.BEFINHOLZ <br /> RICHARD tr.SNIDER,JR. Donald Willhoit, Chair <br /> JANE G.do LISSOVOY <br /> G.NICHOLAS HERMAN Moses Carey <br /> LYNN A.ANDREWS Ben Lloyd <br /> Of Counsei ' Shirl Marshall <br /> BONNER D.SAWYER Norman Walker <br /> 0902-19m <br /> Orange County Board of Commissioners <br /> 106 E. Margaret Lane <br /> Hillsborough, North Carolina 27278 <br /> Re: Massage Ordinance <br /> Dear Board Members: <br /> During the public hearing on the ordinance under <br /> consideration by the Board which would establish <br /> licensing requirements for massage therapists, several <br /> questions were posed by the Board. Mr. Thompson and I <br /> have been attempting to address those questions. At <br /> this time we have determined the following: <br /> Question: Can the licensing requirements of the <br /> ordinance be limited to establishments employing one or <br /> more massage practitioners? <br /> It is our view that such a limitation on the <br /> licensing requirements has the potential to create a <br /> "loophole" in the licensing provisions of the ordinance <br /> through which any establishment could slip through. <br /> This is so because the legal entity which is the <br /> establishment can be divided into any number of <br /> separate legal entities in a manner which would exempt <br /> all from the licensing requirement. <br /> Question: How long a period must a person have a <br /> "clean" record before being disqualified from being <br /> licensed? <br /> There is no legal limit. It is therefore a policy <br /> decision whether to require a totally "clean" record or <br /> one without convictions for the prohibited offenses for <br /> some period of time prior to the date of application. <br /> Po"— <br />