Clerk stamps date here when form is filed. COURT CAUCOPHA COUNTY OF O OF ft•NOE LAW“ v 6 KIM,'cENTER MAR 0 4 2022 AVIg H. 'IWASAKI, CIe* d CS* BY: • LIORF1110 ,C1PUTY FILED Case Number: 22V000515 Fill In court name and street address: Superior Court of California, County of ORANGE COUNTY SUPERIOR COURT FAMILY LAW COURT OPERATIONS 341 THE CITY DRIVE POST OFFICE BOX 14170 ORANGE, CA 92863-1570 Court tills In case number when form is tiled. THIS CASE IS ASSIGNED FOR ALL PURPOSES TO COMMISSIONER WILLIAM G. WATSON (G 3 Request for Domestic DV-100 Violence Restraining Order Instructions: To ask for a domestic violence restraining order, you will need to complete this form and other forms. After you complete this form, see next steps on page 12. 0 Person Asking for Protection a. Your name: Lucie Colomb b. Your age: 30 Address where you can receive court papers (This address will be used by the court and by the person in ® to send you official court dates, orders, and papers. For privacy, you may use another address like a post office box or another person's address, if you have their permission and can get your mail regularly. If you have a lawyer, give their information.) Address: 501 W. Broadway City: San Diego State: CA Zip: 92101 Your contact information (optional) (The court could use this information to contact you. If you don't want the person in® to have this information, leave it blank or provide a safe phone number or email address. If you have a lawyer, give their information.) Telephone: 760-884-7508 Fax: Email Address: elizabethgthegglawfirm.com e. Your lawyer's information (if you have one) Name: Elizabeth Grumet Firm Name: The Grumet Gonzalez Law Firm State Bar No.: 276029 O Person You Want Protection From a. Full Name: Laith Abdallah Algaz b. Age (give estimate if you do not know exact age): 33 c. Date of Birth (if known): 10/09/1988 d. Gender: EM OF q Nonbinary e. Race: Middle Eastern American This is not a Court Order. jliCECI8 d 1, 1 Canellat Cannta. VNAW CaWia gaV Request for Domestic Violence Restraining Order Ravlsa January 2022, Mandatary ram Family Ca Palo at ma (Domestic Violence Prevention) DV-100, Page 1 of 12 Case Number: 2 V 0 0 0 5 1 5 0 Your Relationship to the Person in (If you do not have one of these relationships with the person in 0, you are not eligible for this type of restraining order. You may be eligible for another type of restraining order. Learn more at www.coraise.htin.) IZI1 Check all that apply a. El We have a child or children together (names of children): Arabella Bint Laith Algaz b. 0 We are married or registered domestic partners. c. 0 We used to be married or registered domestic partners. d. 0 We are dating or used to date. e. ID We are or used to be engaged to be married. (1. D We are related. The person in ® is my (check all that apply): q Parent, stepparent, or parent-in-law 0 Brother, sister, sibling, or sibling-in-law 0 Child, stepchild, or legally adopted child 0 Grandparent or grandparent-in-law D Child's spouse 0 Grandchild or grandchild-in-law g. 0 We live together or used to live together. (If eheeke4, answer question below): Have you lived together with the person in as a family or household (more than just roommates)? 0 Yes 0 No (If no, you do not qualify for this kind of restraining order unless you checked one of the other relationships listed above.) 0 Other Restraining Orders and Court Cases a. Are there any restraining orders currently in place or that have expired in the last six months (examples: Did the police give you a restraining order that lasts a few days? Do you have one from the criminal court?) 0 No 0 Yes (If yes, give information below and attach a copy if you have one.) (1) (date of order): (date it expires): (2) (date of order): (date it expires): b. Are you involved in any other court case with the person in (9? 2 No 0 Yes (If you lotow, list where the case was filed (city, state, or tribe), the year it was filed and case number.) El Custody El Divorce 0 Juvenile Court q Criminal 0 Other (what kind of case?): This is not as Court Order. Rafted January 1.2022 Request for Domestic Violence Restraining Order (Domestic Violence Prevention) DV - 100, Page 2 of 12 Case Number. 0 0 0 5 15 Describe Abuse In this section, explain how the person in 0 has been abusive. The judge will use this information to decide your request. Here are some examples of what "abuse" means under the law (not a complete list): • harassed you • hit, kicked, pushed, or bit you • made repeated unwanted contact with you • injured you or tried to • tracked, controlled, or blocked your movements • threatened to hurt or kill you • kept you from getting food or basic needs • sexually abused you • isolated you from friends, family, or other support • abused a pet or animal • made threats based on actual or suspected immigration status • destroyed your property • made you do something by force, threat, or intimidation • choked or strangled you • stopped you from accessing or earning money • abused your children O Most recent abuse a. Date of abuse (give an estimate ifyou don't know the exact date): 2/23/2022 b. Did anyone else hear or see what happened on this day? El I don't know 0 No 0 Yes (If yes, give names): Anais Colomb c. Did the person in 02 use or threaten to use a gun or other weapon? 2 No ID Yes (7f yes, describe gun or weapon): d. Did the person in 0 cause you any emotional or physical harm? 0 No 2 Yes (If yes, describe harm): He caused me to fear for my safety and that of my baby daughter. He caused me to have exhume anxiety and to cry because he verbally abused me and kicked me and our daughter out of the house. SEE DECL ATTACHED e. Did the police come? 0 I don't know 0 No 0 Yes (If the police gave you a restraining order, list it in 9.) f. Give more details about how the person in 0 was abusive on this day. Details can include what was said, done, or sent to you (examples: text messages, emails, or pictures), how often something happened, etc. SEE DECLARATION ATTACHED g. How often has the person in abused you like this? q Just this once 0 2-5 times q Weekly 0 Other: Every day Give dates or estimates of when it happened, if known: SEE DECLARATION ATTACHED This is not a Court Order. Revd January 1, 2022 Request for Domestic Violence Restraining Order DV-100, Page 3 of 12 (Domestic Violence Prevention) Case Nu n V 0 0 0 5 5 ® Has the person in Q 2 abused you In a different way from the abuse you described in CD? If yes, describe below. a. Date of abuse (give an estimate if you don't know the exact date): SEE DECLARATION ATTACHED b. Did anyone else hear or see what happened on this day? I don't know 0 No D Yes (If yes, give names): SEE DECLARATION ATTACHED c. Did the person in 0 use or threaten to use a gun or other weapon? 2 No D Yes (If yes, describe gun or weapon): d. Did the person in ® cause you any emotional or physical harm? D No 2 Yes (If yes, describe harm): SEE DECLARATION ATTACHED e. Did the police come? 0 I don't know 0 No 0 Yes (If the police gave you a restraining order, list it in®.) f. Give more details about how the person in ® was abusive on this day. Details can include what was said,done, or sent to you (examples: text messages, emails, or pictures), how often something happened, etc. SEE DECLARATION ATTACHED g. How often has the person in 0 abused you like this? D Just this once 0 2-5 times 0 Weekly Other: Every day Give dates or estimates of when it happened, if known: SEE DECLARATION ATTACHED This is not a Court Order. Rafted January 1, 2022 Request for Domestic Violence Restraining Order DV-I00, Page 4 0112 (Domestic Violence Prevention) Case Number: 22V0005 15 0 Is there other abuse by the person in 0 that you want the Judge to know about? If yes, describe below. a. Date of abuse (give an estimate if you don't know the root doh.): b. Did anyone else hear or see what happened on this day? q I don't know q No q Yes (If yes, give names): c. Did the person in ® use or threaten to use a gun or other weapon? q No q Yes (If yes, describe gun or weapon): d. Did the person in 0 cause you any emotional or physical harm? q No q Yes (Iyes, describe harm). e. Did the police come? q I don't know q No q Yes at the police gave you a restraining order, list it in T) f. Give more details about how the person in was abusive on this day. Details can include what was said,done, or sent to you (examples: text messages, emails, or pictures), how often something happened, etc. g. Flow often has the person in 0 abused you like this? q Just this once q 2-5 times q Weekly q Other: Give dates or estimates of when it happened, if known: q Check this box if you need more space to describe the abuse. You can use form DV-101, Description of Abuse and turn it in with this form. You can also use a separate sheet of paper, write "Describe Abuse" abuse at the top, and turn it in with this form. This is not a Court Order. Revd January 1, 2022 Request for Domestic Violence Restraining Order DV-100, Page 5 of 12 (Domestic Violence Prevention) Case Nu n n V 0 0 0 5 15 0 Other Protected People Do you want the restraining order to protect your children, family, or someone you live with? a. 0 No b. 0 Yes (If yes, complete the section below): (1) full name Arabella Bint Laith Algaz Age Relationship to you Lives with you? 7 mos daughter 2 Yes 17] No q Yes q No q Yes n No El Yes q No 0 Check this box if you need to list more people. Use a separate piece of paper and write "DV-100, Other Protected People" at the top. Turn it in with this form. (2) Why do these people need protection? SEE DECLARATION ATTACHED ® Does Person in Have Firearms (Guns) or Ammunition? a. q I don't know b.0 No c. 0 Yes (If you have information, complete the section below.) (1) Describe firearms or ammunition (examples: long, short, black silver, handgun, nide. semiautomatic): (2) Number of firearms or ammunition, if known: (3) Where they are located or stored, if known: This is not a Court Order. Revised January 1, 2022 Request for Domestic Violence Restraining Order DV-1 100, Page 6 of 12 (Domestic Violence Prevention) Case N in fl! 0 0 0 5 15 Choose the Orders That You Want a Judge to Make In this section, you will choose the orders you want a judge to make now. Every situation is different. Choose the orders that fit your situation. 2 Check all the orders that you want a judge to make (order). ® 2 Order to Not Abuse I ask the judge to order the person in® to not do the following things to me or anyone listed in®: Harass, attack, strike, threaten, assault (sexually or otherwise), hit, follow, stalk, molest, destroy personal property, keep under surveillance, impersonate (on the intemet, electronically, or otherwise), block movements, annoy by phone or other electronic means (including repeatedly contact), or disturb the peace. Disturbing the peace includes, but is not limited to: • Isolating you from friends, relatives, or other support; keeping you from food or basic needs; controlling or keeping track of you, including your movements, contacts, actions, money, or access to services; and making you do something by force, threat, or intimidation, including threats related to actual or suspected immigration status. • Destroying your mental or emotional well-being. This can be done directly or indirectly, such as through someone else. This can also be done in any way, including by phone, text, or online. 0 Z No-Contact Order I ask the judge to order the person in ® to not contact me or anyone listed in ®. 12 LI Stay-Away Order a. I ask the judge to order the person in ®to stay away from: Er Check all that apply 111 Me. Z My vehicle. Z My home. E My school. I] My job or workplace. 111 Each person in O. E My children's school or childcare. Z Other (please explain): Our daughter Arabella b. How far do you want the person to stay away from all the places you checked above? El 100 yards (300 feet) 111 Other (give distance in yards): This isliOt a Court Order. Revised January 1, 2022 Request for Domestic Violence Restraining Order DV - 100, Page 7 of 12 (Domestic Violence Prevention) case Number: V 0 0 0 5 15 12 Stay-Away Order (continued) c. Do you and the person in C) live together or live close to each other? 0 No ID Yes (If yes, check one): q Live together (If you live together, you can ask that the person in move out in (9 .) q Live in the same building, but not in the same home q Live in the same neighborhood l Other (please explain): We lived together, but I moved out on 2/23/2022. d. Do you and the person in U have the same workplace or go to the same school? 111 No El Yes (If yes, check all that apply): Z Work together at (name of company): We worked together on projects from home. 111 Go to the same school (name of school): ['Other (please explain): 0 0 Order to Move Out a. I ask the judge to order the person in 0 to move out of the home, located at: (Give address): b. I have a right to live at this address because: Q Check all that apply E I own the home. O My name is on the lease. O I live at this address with my child(ren). 111 I have lived at this address for years, 0 I pay for some or all the rent or mortgage. q Other (please explain): months. 0 q Other Orders (Describe any additional orders you want the judge to make to keep you, your children, or the people in safe.): ® El Child Custody and Visitation Check this box if you have a child with the person in 0 and want the court to make or change a child custody/ visitation order. You must also fill out form DV-105, Request for Child Custody and Visitation Orders, and attach This is not a Court Order. Revised January 1. 2022 Request for Domestic Violence Restraining Order DV-100, Page 8 of 12 (Domestic Violence Prevention) case Nu ler 2 V 0 0 0 5 1 5 0 Protect Animals a. (You may ask the court to protect your animals, your children's animals, or the person in O's animals.) Name (or other way to ID animal) Type of animal Breed (if brown) Color (1) Theeb Dog German Shepherd Black (2) Nimr Cat Tabby Orange (3) (4) b. I ask the judge to protect the animals listed above by ordering the person in ® to: Check all that apply (1) 0 Stay away from the animals by at least: E 100 yards (300 feet) D Other (give distance in yards): (2) DI Not take, sell, hide, molest, attack, strike, threaten, harm, get rid of, transfer, or borrow against the animals. (3) E Give me sole possession, care, and control of the animals because (check all that apply): 0 Person in ® abuses the animals. 0 I take care of these animals 0 I purchased these animals. El Other (please explain): 0 q Control of Property a. I ask the judge to give only me temporary use, possession, and control of the property listed here (describe): b. Explain why you want control of the property you listed: 0 n Health and Other Insurance I ask the judge to order the person in Q 2 to not make any changes to any insurance or other coverage for me, the person in ®, or our children, including not being allowed to cancel, cash, borrow against, transfer, dispose of, or change the beneficiaries for the insurance. 19 D Record Communications I ask the judge to allow me to record calls or communications the person in 0 makes to me, when those calls or communications violate this restraining order. This is not a Court Order. Revised January 1, 2022 Request for Domestic Violence Restraining Order DV-100, Page 9 of 12 (Domestic Violence Prevention) Case Number. 11] Property Restraint (only if you are married or a registered domestic partner with the person in (D.) I ask the judge to order the person in ® not to borrow against, sell, hide, or get rid of or destroy any possessions or property, except in the usual course of business or for necessities of life. I also ask the judge to order the person in ® to notify me of any new or big expenses and to explain them to the court. Extend My Deadline to Give Notice to Person in (Usually, the judge will give you about two weeks to give notice, or to "serve" the person in ® of your request. If you need more time to serve, the judge may be able to give you a few extra days.) I ask the judge to give me more time to serve the person in CD because (explain why you need more time): 111 Pay Debts (Bills) Owed for Property (If you want the person in ® to pay any debts owed for property, list them and explain why. The amount can be for the entire bill or only a portion. Some examples include rent, mortgage, car payment, etc.) a. I ask the judge to order the person in CD to make these payments while the restraining order is in effect: (1) Pay to: For: Amount: $ Due date: (2) Pay to: For: Amount: $ Due date: (3) Pay to: For: Amount: $ Due date: Explain why you want the person in 0 to pay the debts listed above: b. Special decision (finding) by the judge if you did not agree to the debt (optional) (If you did not agree to the debt or debts listed above, you can ask the judge to decide (find) that one or more debts was made without your permission and resulted from the person in (D's abuse. This may help you defend against the debt if you are sued in another case.) Do you want the judge to make this special decision (finding)? 111 No El Yes (If yes, answer the questions below.) (1) Which of the debts listed above resulted from the abuse? (check all that apply): q 41) q a(2) D a(3) (2) Do you know how the person in ® made the debt or debts? q No q Yes (If ye.s, explain how the person in ® made the debt or debts): This is not a Court Order. Revised January 1.2022 Request for Domestic Violence Restraining Order DV-1011, Page 10 of 12 (Domestic Violence Prevention) 20 21 22 Case Num 2e2 V000515 Orders That You Want a Judge to Make at Your Court Date Below is a list of orders that a judge cannot make right away but can make at your court date in a few weeks. The person in 0 must be notified of your court date before the judge can consider making any of the orders listed below. Check all the orders that you want the judge to make at your court date. 0 q Pay Expenses Caused by the Abuse I ask the judge to order the person in 0 to pay for things caused directly by the person in 0 (damaged property, medical care, counseling, temporary housing, etc.). Bring proof of these amounts to your court date. Amount: $ Amount: $ Amount $ o Child Support (this only applies tfyou have a minor child with the person in(j) Er Check all that apply a. ID I do not have a child support order and I want one. D I have a child support order and I want it changed (attach a copy if you have one). c. q I now receive or have applied for TANF, Welfare, or CalWORKS. CI Spousal Support (this only applies if you are married or a registered domestic partner with person in CI) I ask the judge to order the person in 0 2 to give me financial assistance. q Lawyer's Fees and Costs I ask that the person in a pay for some or all of my lawyer's fees and costs. q Batterer Intervention Program I ask the judge to order the person listed in Q to go to a 52-week barterer intervention program. (The goal of a batterer's intervention program is to stop abuse. There are weekly classes to teach accountability, abuse effects, and gender roles. If ordered to complete this program, the person in ® would have to show proof to the judge that they enrolled and completed the program.) 0 El Transfer of Wireless Phone Account (If the person in C) holds the rights to your cell phone account, you can ask the judge to transfer your number or your child's number to you. This means you will be financially responsible for these accounts. If you want to have control over a mobile device, like a cell phone, make this request at Q .) I ask the judge to order the wireless service provider to transfer the billing responsibility and rights to the wireless phone numbers listed below to me because the account currently belongs to the person in C): a. El My number El Number of child in my care (including area code): b. El My number El Number of child in my care (including area code). This is not a Court Order. Revised January 1, 2022 Request for Domestic Violence Restraining Order DV - 100, Page 11 of 12 (Domestic Violence Prevention) Pay to: Pay to: Pay to: For: For: For: 24 25 26 27 c Cale "unr2 V 0 0 5 1 5 Automatic Orders That a Judge Can Make Right Away 0 No Guns, Other Firearms, or Ammunition If the judge grants you a restraining order, the person in 0 must sell or turn in any firearms that they have or control. The person in ®would also be prohibited from buying firearms and ammunition. 0 Cannot Look for Protected People If the judge grants you a restraining order, the person in ® will not be allowed to look for the address or location of any person protected by the restraining order, unless the court finds good cause not to make this order. 31 Additional pages If you used additional paper or forms, enter the number of extra pages attached to this form: 32 Your signature I declare under penalty of perjury under the laws of the State of California that the information above is true and correct. Date: 3/3/2022 Lucie Colomb Type or print your name 33 Your lawyers signature (Vyou have one) Date: 3/3/2022 Elizabeth Grumet Lawyer's name Lawyer's signature Your Next Steps al You must complete at least three additional forms: • Form DV-I10 Temporary Restraining Order (only items I, 2 and 3) • Form DV-109, Notice of Court Hearing (only items I and 2) • Form CLETS-001, Confidential CLETS Information ® if you are asking for child custody and visitation, you must complete form DV-105, Request for Child Custody and Visitation Orders and form DV-I40, Child Custody and Visitation Order. O Turn in your completed forms to the court. Find out when your forms will be ready for pick up. • Once you get your forms back from the court, have someone "serve" a copy of all forms on the person in ® . The sheriff or marshal can do this for free. Learn more about how to "serve" your papers and prepare for your court date: h selthel .courts.ca. ov/sheriff-serves- our-r r min rder If you are asking for child support, spousal support, or lawyer's fees, you must also complete form FL-150, Income and Expense Declaration. If you are only asking for child support (item 23), you may be eligible to fill out a simpler form, FL-155. Read form DV-570 to see if you are eligible. Turn in your completed form to the court before your court date. You must also have someone mail or personally deliver a copy to the person in ®. This is not a Court Order. Revised January 1, 2110 Request for Domestic Violence Restraining Order DV - 100, Page 12 of 12 (Domestic Violence Prevention) • Request for Child Custody and Visitation Orders caseNu rn0 0 0 5 15 DV-105 This form is attached to (check one): 0 form DV-100 q form DV-120 O O O q Dad 0 Other* Your name: Lucie Colomb Other parent's name: Laith Abdallah Algaz *If Other, specify relationship to child: El Child Custody I ask the court for custody as follows: Child's Name Date of Birth a. Arabella Bint Laith Algaz 08/03/2021 b. c. d. O Mom O Mom Legal Custody to (Person who makes decisions about health, education, and welfare): O Dad 0 Other* Physical Custody to (Person you want the child to live with): Mom Dad Other g 0 0 O 0 El ID 0 0 ID 0 0 Mom Dad Other 0 0 0 0 0 Check here if you need more space. Attach a sheet of paper and write "DV-105, Child Custody" for a title. ® ID Change Current Court Order I want to change a current child custody or visitation court order. Case Number (f you have it): County: Explain your current order and why you want a change: 0 Check here if you need more space. Attach a sheet of paper and write "DV-105, Change Current Court Order" for a title. ® Child's Address Where has the child in Oa lived for the last five years? List each city and state the child has lived in unless it is unknown to the other parent and you want to keep it confidential because of domestic violence or child abuse. Start with where the child lives now and work backwards in time. If the current address is confidential, check the box below and just provide the current state. Child ®a addresses (city and state): Child (Da lived with: Dates lived there: Mom Dad Other VConfidential g q 0 From 02/23/2022 to present 'Irvine, CA 0 0 q From 08/03/2021 to 02/23/2022 0 q 0 From to 0 0 0 From to D Check here if you need more space. Attach a sheet of paper and write "DV-105, Child's Address" for a title. This is not a Court Order. Judi Camel of California. beneametesegov Rev. arceeey 1,2022, MandatorY Ran Family Code, §3063 Request for Child Custody and Visitation Orders (Domestic Violence Prevention) DV-105, Page 1 of 3 case art V 0 0 0 5 15 0 Other Children's Addresses 0 Check here if the other child's (or children's) address information is the same as listed in ®, O If it is different, check here. Attach a sheet of paper and write "DV-105, Other Children's Addresses" for a title. List other children's address information, including dates, and name of person(s) children lived with. Other Custody Case Were you involved in, or do you know of, any other custody case for any child listed in this form? g No CI Yes af yes, fill out below and attach a copy of any custody or visitation orders if you have them): a. Name of each child in other case. b. Type of case: 0 Parentage (Paternity) 0 Domestic Violence El Child Support O Juvenile/Dependency 0 Guardianship 0 Other (sPeci .fr): O Divorce c. I was a 0 party d. Court (name): El witness CI Other (specify): Address: County: State: e. Date of court order f. Case number (f you have it): O Other People With or Claiming to Have Custody or Visitation Rights Do you know of anyone who is not involved in this case who has or claims to have custody or visitation rights with any child listed on this form? 0 No D Yes (If yes, fill out below.) That person (give name and address): ELI has custody DI claims custody rights CI claims visitation rights for these children (name of each child): O El Visitation I ask the court to order that the person in have the following temporary visitation rights: Check all that apply a. g No visitation until the hearing b. El No visitation after the heating c. 0 The following visitation D until the hearing El after the hearing (1) El Weekends (starting): (The 1st weekend of the month is the 1st weekend with a Saturday.) q 1st 0 2nd 0 3rd 0 4th 0 5th weekend of month from at D am. EI p.m. to at 0 am. El p.m. (day of week) (tinie) (day of week) (time) (2) q Weekdays (starting): from at 0 a.m. 0 p.m. to at 0 a.m. 0 p.m. (day of week) (flake) (day of week) (time) This is not a Court Order. Rev. January,, 2022 Request for Child Custody and Visitation Orders DV-105, Page 2 of 3 (Domestic Violence Prevention) Case N T7 r: V 0 0 0 5 1 5 O Other Visitation I ask the court to make other visitation orders, like summer vacation, birthdays, and holidays. (List the orders you want on a separate sheet of paper. Write "DV-105, Other Visitation" for a title and attach it to this form.) q Responsibility for Transportation (The parent will take or pick up the child or make arrangements for someone else to do so.) I ask the court to order that: a. q Mom q Dad 0 Other (name): take children to the visits. b. 0 Mom 0 Dad q Other (name): pick up children from the visits. c. q Drop-off / pick-up of children will be at (address): d. q Check here if other arrangement. Attach a sheet of paper and write "DV-105, Responsibility for Transportation" for a title. D Supervised Visitation a. I ask that the visitation in be supervised by: q a professional supervisor q a nonprofessional supervisor 0 Other (Name and telephone number, liknown:) b. I ask that the visitation in 0 be supervised by: 111 a professional supervisor 111 a nonprofessional supervisor El Other: (Name and telephone number, if known): c. I ask that any costs for supervision be paid by: Mom % Dad % Other (name): O Travel With Children I ask the court to order that: El Mom q Dad q Other (name): must have written permission from the other parent, or a court order, to take the children outside of: a. q California b. 0 County of (list): c. 0 Other place(s) gist): 0 0 Child Abduction Risk q I believe that there is a risk the other parent will take our child out of California and hide the child from me. (If you check this box you must fill out and attach form DV-108, Request for Order: No Travel with Children.) Important Instructions • You must tell the court if you Snd out any other information about a custody case in any court for the children listed on this form. • If the court makes a temporary custody order, the parent receiving custody must not take the child out of California without a noticed hearing. (See Family Code, § 3063.) This is not a Court Order. Rev. Jemimy 1,1072 Request for Child Custody and Visitation Orders DV-105, Page 3 of 3 (Domestic Violence Prevention) 10 11 12 13 22 V000 5 15 CASE NAME: Lucie Colomb v. Laith Abdallah Algaz CASE NUMBER: DECLARATION OF LUCIE COLOMB I, Lucie Colomb, Petitioner in this action and if called upon, could and would testify from my personal knowledge to the following: SUMMARY: 1. I respectfully request the Court to grant me the protection of the restraining order. a. Petitioner shall be granted an Order of Protection, protecting me and my baby daughter protection from Respondent. b. Petitioner shall have primary/sole custody of our daughter. c. Our dog and cat, who remain in the apartment with Respondent, shall be removed from the home for their safety. BACKGROUND HISTORY: Respondent and I were married on March 4, 2020 and separated on February 23, 2022. However, we have been together for three and a half (3 & 1/2) years. We have a baby daughter together- Arabella Bint Laith Algaz. Arabella was born on August 3, 2021. During our relationship, Respondent has abused alcohol and drugs, and has been extremely verbally and emotionally abusive towards me and our daughter, and physically threatening towards me. In or around November 2020, when I became pregnant, Respondent's abusive behavior dramatically escalated. He has alienated me from all my friends. refusing to allow me to leave our apartment. The few times I left the home, he required I ask him for permission. He has stated in person and multiple text messages that he wants nothing to do with "the daughter", "your daughter" (our child), and that he resents her because she reminds him of me. He has become physically violent, especially when he drinks, wherein he will throw items, aggressively, near me, when he is angry. He has kicked me out multiple times, but I was too afraid to leave. Finally, on February 23, 2022, after he became angry again and indicated he was 1 DECLARATION OF LUCIE COLOMB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 going to be drinking heavily, I took our baby daughter out of the apartment because I was terrified of his abuse. Most recently, on March 1, 2022, Respondent texted me, threatening, "murder bitch". DV: 100- RECENT ABUSE: My husband has a history of alcohol abuse and domestic violence. He was imprisoned for felony domestic abuse (against a former girlfriend) in the past. On March 1, 2022, Respondent texted me, "murder bitch", after I left our apartment on February 23, 2022 with our baby daughter, due to his verbal abuse and explosive temper. On February 22, 2022, Respondent's abusive behavior came to a head, when he exploded in anger because he could not find milk in the refrigerator at 5:00 a.m. My younger sister Anais Colomb was visiting me from France at the time and was staying with me in the apartment I share with Respondent and our baby. Only because my sister was visiting, Respondent did not verbally scream at me, and instead, began sending me abusive text messages. Respondent was furious that the two cartons of milk he was searching for were placed in the back of the refrigerator, rather than in the front. He accused me (via text) of hiding his milk, texting me, "FUCKING IDIOT...YOU THINK I CANT SEE IT...I TOLD YOU 50 fucking times. ITS NOT A GOD DAMN JOKE. YOU WERE SUPPOSED TO RE ORGANIZE THE FRIDGE... WHAT THE FUCK IS WRONG WITH YOU. THIS IS MY HOUSE...YOU ARE BEING A FUCKING BITCH AS USUAL...CARELESS...I COMPLAINED...INSANNNNNE...All you French fucks are insane. I don't know how you can tolerate each other...Dumb bitch. Keep your mouth quiet next time." Please see all text messages referenced in this declaration, attached as Exhibit 1. Also on February 23rd, Respondent texted me, calling me a "bitch", "dumb bitch", "fucking bitch", repeatedly. He texted, "You should have lived to serve me instead of feeling sorry for yourself 24/7", and, "do you think my wife treats me like a boss? Am I a boss in my 2 DECLARATION OF LUCIE COLOMB 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 own apartment? No." He also texted me, "My biggest regret is speaking well of you behind your back in ways you didn't deserve...Your selfishness is unparalleled." Respondent also berated me for crying in front of my sister Anais, who was with me in the apartment, stating, "crying in front of your sister for gods sake. What a traitor...You could have gone into the room like any responsible adult would that didn't want attention and drama. But your selfish soul led you to this again." Exhibit 1. After our daughter Arabella was born in August 2021, Respondent frequently said that he wanted a son, and that our daughter would not be able to "carry his lion"- meaning, she would never be able to carry his last name. He frequently said, "Now I am stuck with you because we have a daughter and I wanted a son." Respondent has a lot of hatred for people of different races and ethnicities. Because I was with an Armenian boyfriend many years before I met Respondent, he called me a "whore" and said he did not want our daughter to turn out like me. On February 25, 2022, Respondent texted me, "I am totally unwilling to be involved in the raising of a girl who well end up sleeping with Armenians as a teenager, like you did. This will humiliate me and burn my soul as an Arab man, so I will have nothing to do with her life after the kidnapping (unless you return her, soon, and have zero custody yourself)." Exhibit 1. Respondent has repeatedly expressed disdain for our baby daughter. On February 23, 2022, Respondent texted me, "I end up hating you and the daughter...I can't give a shit now about either of you because I spent months imagining she dislikes me and I'm a bad father and I associated her with you. Such a bitch move.". On the same day, he texted me, "I am happy with the way I treated you and believe you deserve much worse treatment...You deserve much worse. MUCH." Also, on this day, he texted, "If you act like a bitch, I believe calling you a bitch is 100% honorable and within my ethical code." Exhibit 1. When I left the house on February 23, 2022, he sent me texts characterizing our 7-month- old daughter Arabella as "your daughter", and said he wanted nothing to do with her, since I left. 3 DECLARATION OF LUCIE COLOMB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 On February 24, 2022, he texted me, "You caused your daughter to lose a father...human scum...I won't take this kid back, so there's no way in hell it will ever happen to me again...I do not wish to see her again. I told you if you kidnap my child she is not my child again...I will not co- parent...She is not my daughter." Exhibit 1. I fear for the safety of my daughter Arabella. I became a citizen in January 2021. After I left the apartment on February 23rd, Respondent threatened multiple times that he would contact immigration services to have me deported. He continues to make these threats to try to intimidate me. In the last week since I left the apartment with our baby, Respondent has tried to convince me in messages and calls that I should not trust my closest friends nor my own sister. He says that they are all brainwashing me, they are losers, and that I should no longer speak with them. On a phone call after I left, he stated that while he regretted some of his actions, I was at fault for "kidnapping" our baby and leaving our apartment. He told me that I should return, but before I did so, I must apologize to him and demonstrate I was sorry for leaving. He also said he wanted the names of each friend I spoke with about us when I left, so he could contact them. He texted two of my closest friends on March 3rd, trying to get them to call him He continues to call me, causing me anxiety and confusion. Just today, he again threatened to have me deported, told me I had "kidnapped" our daughter, and he must be granted access to her. DV: 100- PRIOR ABUSE: During our marriage, I have suffered extreme emotional and verbal abuse by the actions of Respondent. In or around April/May 2020, Respondent began drinking, after years of sobriety. He also began smoking weed. He frequently would order alcohol to be delivered to our apartment. After I became pregnant in November of 2020, Respondent became extremely controlling and angry. He frequently complained that I was selfish, lazy, and giving him less attention than he deserved. Respondent would frequently degrade me, calling me, "lazy", and said that I did not do 4 DECLARATION OF LUCIE COLOMB 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 a good enough job in my work with him. I helped him start a YouTube channel in January 2020, because I have a strong marketing background. Respondent expected me to manage my pregnancy alone, while carrying the business we created. When I needed to tend to my needs because I was pregnant, he called me "selfish", stating I was "mistreating" him He constantly complained that I was not "doing enough" for him. If I didn't anticipate his every whim and ask him if he needed anything, he degraded me, saying I was a "stupid bitch", "lazy", "selfish". During my pregnancy, Respondent alienated me from my friends. I have a small circle of very close friends who are my only family in the US (because I am from France). He told me repeatedly that it was selfish if I spent any time with them. On the rare occasions I tried to make plans with my closest friends, Respondent would become very angry, saying we had work to do, that I was selfish, and that I had to remain at home. Therefore, despite my close friendships, I almost never saw any friends after I became pregnant. On one occasion, I had to sneak out of the apartment when Respondent was not home, so I could see one of my closest friends and she could meet our baby. I did not tell Respondent, because I feared he would become angry. During Christmastime in 2021. I tried to visit a couple of my close friends, with our baby, for just the day. My dear friend Sarah had invited me to share a Christmas meal with her. I also had a friend visiting from France, who wanted to see me. I was so concerned about Respondent being angry about me leaving, even for a short time, that I asked his permission to leave. He was passed out from being drunk the night before when I asked him, and he said it was fine. I returned that night to find Respondent passed out again. The next morning, after hearing our daughter cry, he became very angry, yelling at me for leaving the day before. He said that I had "kidnapped" our baby and that I had no right to leave. Respondent yelled that if he did not give me permission, I had no right to leave our apartment. 5 DECLARATION OF LUCIE COLOMB