Professional Documents
Culture Documents
‘ ‚ _
r 00 Req UeSt fO%OmeSt|C - Clerk stamps date here when form is filed.
. 4 l.
' Violence Res_training Order
You must also comfnlete Form CLETS-001, Condential CLETS Information, S" .
and give it t0 the c erk when youle this Request. perm’ Court ofc .
Counw “llforma
‘JUL M‘ r „ = Anoeies
of Persion Asking for Protection:
® Name
Agezsm? r Z019
Your lawyer in this case (zfyou have one)." ShemR- Carier, nxccumc u "‚ „n . .
Name: Susannah Braffman Amen State Bar No.2 2Q2 1 68 BY 'er" °TCou r
. . . G . 1 HE May. 2 ‚ Depu; ‚
Firm Name: Elkins Kalt Wemnanb Renhm Salazar 5
Address (Ifyou have a lawyerfor this casaafgive your lawyer ’s
information. Ifyou d0 not have a lawyer an want t0 keäp your home Fil/ in coun name and street address;
address private, give a different mailing address instea . You d0 not s . C n fc H . C f
have t0 give your telephone, fax, or e-mail.): Lupen“ o" ° a ' orma’ °unty °
_ os Anäeles
' Address: 111 N. 111 Street
E] Move-Out Order p
(Ifthe person in ® lives with you andyou want that person t0 stay awayrom your home, you musz askfor
this move-out order.)
‚B?! ' .
I ask the court t0 order the person m@to move out from and not return to (address):
@ Q Debt Payment
I ask the court to order the person in ® to make these payments while the order is in effect:
Ü Check here zfyou need more space. Attach a sheet ofpaper and write “D V-100, Debt Payment ”for a title.
ff Pay to: LFor: ______________ Amount: S _.__.___________Due date: __________..___
Q Property Restraint A
I am married to or have a registered domestic partnership with the person in ® . I ask thejudge to order
that the person in ® not 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.
@ Q spousal Support
I am married t0 or have a registered domestic partnership with the person in ® and no spousal Support order
exists. I ask the court to order the person in ® to pay spousal Support. (You must c0mplete‚ le, and serve Form
FL-150‚ Income and Expense Declaration be ore ourhearin . I"
Ü Check here ifyou need more space. Altach a sheet ofpaper and write “D V-1 00, Other Orders ”f0r a title.
Court Hearing
The court will schedule a hearing on your request. Ifthe judge does not make the orders effective right away
("temporary restraining orders")‚ thejudge may still make the orders after the hearing. lfthejudge does not make
the orders effective right away, you can ask the court to cancel the hearing. Read form DV-1 l2, Waiver ofHearing
an Denied Requestfor Temporary Restraining Order, for more information.
@ Describe Abuse
Describe how the person in ® abused you. Abuse means to intentionally or recklessly cause or attempt to cause
bodily injury to you; or to place you or another person in reasonable fear of imminent serious bodily injury; or to
harass, attack‚ strike‚ threaten, assault (sexually or otherwise), hit‚ follow, stalk, molest, keep you under
surveillance, impersonate (on the Internet, electronically or otherwise)‚ batter, telephone, or contact you; or to
disturb your peace; or to destroy your personal property. (For a complete denition, see Fam. Code, Q5 6203, 6320.)
a. Date of most recent abuse:
1. Who was there?
2. Describe how the person in C2) abused you or your child(ren):
S l 1 I: l . E l E
m Check here ifyou need more space. Allach a sheet ofpaper and write “D V-1 00, Recent Abuse ”for a title.
3. Did the person in ® use or threaten to use a gun or any other weapon? ®NO E] Yes (Ifyes, describe):
93:; 5. Did the pollce come? E] No Ü Yes (I went to the police to le a report).
If yes, did they give you or the person in® an Emergency Protective Order? m Yes C] N0 E] l don’t know
Altach a copy ifyou have one.
The order protects m you or ü the person in ®
Has the person in ® abused you (or your child(ren)) other times?
b. Date of abuse:
1. Who was there?
2. Describe how the person in @ abused you or your child(ren):
mCheck here zfyou need more space. Altach a sheet ofpaper and write “D V-I 00, Recent Abuse ”for a
title.
3. Did the person in ® use or threaten to use a gun or any other weapon? KINO Ü Yes (Ifyes, describe):
äfädeclare under penalty of perjury under the laws ofthe State of California that the information above is true and correct.
gägate:
This form is attached to DV-l O0, Requeslfor Domestic Violence Restraining Order.
Check the orders you want IZI .
G) E] Child Custody
' I ask the Court for Custody as follows: Legal Custody to: (Person Physical Custody to:
who makes decisions about (Person you a t th
‚ health, education, and welfare) child t0 live Sitz) e
Child's Name . Datf ofBirth Mom Dad Other Mom Dad Other
a. 0-_ZLE0EL‘L_ E] c1 1:: c:
b. 000W‘ P0006 ‘0/ * Z005 EI EI c1 C:
e. 005m0 W6 ‘V 0 200 5a E] E] a D EI
01.0 0 C! EI C] C] CI CI
C] Check here you need more space. Attach a sheet 0 paper and write “D V-J 05, Child Custod‚V ” or a title.
Ü Check here zfyou need more space. Altach a sheet ofpaper and write “D V—105‚ Other People With or
Claiming Custody or Visitation ”for a title.
G) [X] Visitation
I ask the court to order that the person in ® have the following temporary Visitation rights:
(Check all that apply)
a. IX] N0 Visitation until the hearing (or Professionally monitored)
b. ü] No Visitation after the hearing
c. C] The following Visitation Ü until the hearing E] after the hearing
(1) Ü Weekends (startingße (The Ist weekend ofthe month is the Ist weekend with a Saturday.)
Ü 1st Ü 2nd E] 3rd Ü 4th Ü 5th weekend of month
fromeat e D a.m. Ü p.m. to Lat LÜ a.m. Ü p.m.
(day ofweek) (time) A (day ofweek) (time)
(2) Ü Weekdays (starting):____._:__
from____at e. Ü a.m. Ü p.m. to im ja a.m. Ü p.m.
(day ofweek) _ time 4 _ ‚ _ _ ‚ da I o week) (time)
R°“Ja"“°’“-’°‘2 Re uest for Child Custod and Visitation Orders °V'1°5' Page 2 °f3
ggähgif! q (Domestic Violenyce Prevention) 9
v ‘ BD 639 740
c1 Other Visitation
Attach a sheet ofpaper with other visitation days and times‚ like summer vacation, holidays, and birthdays.
List dates and times. Write “D V-1 05, Visitation ”for a title.
® E] Supervised Visitation
a. I ask that the Visitation in @ be supervised by
m A professional supervisor DA non-professional supervisor Ü Other
Name and telephone number, ifknown:
b. I ask that the Visitation in be supervised by
Ü A professional supervisor DA non-professional supervisor C] Other
Name and telephone number, zfknown:
c. I ask that any costs for Supervision be paid by:
Mom _% Dad LO_O_% Other (name) ______ %
lmportant Instructions
You must tell the court if you nd 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 Q3063.)
5 personal knowledge of the facts set forth herein, and if called as a witness, I could and
6 would competently testify to the matters stated herein. I submit this Declaration in
' 9 BACKGROUND
m l0 2. John is my former husband. John andI have three minor chi1dren‚ Daniel
ä 11 Pierce (age 15), Jordan Pierce (age 14 on August 1, 2019), and Joshua Pierce (age 11).
5 e.
ä 55 g 12 Our Judgment of Dissolution ("Judgment") was entered on October 27, 2016. A true
L9 g‘ ä
ä ä E ä 13 and correct copy of our Judgment of Dissolution is attached hereto as Exhibit "1".
a a es
‘g L-L 14 3. Concurrently with the execution of the Judgment‚ John and I (together
ä ' u; 8
ä ä f}; 15 „with . our attorneys of record) executed a First Further Judgment ("First Further
2 = K.
ä ‘g ä g 16 Judgment"), Which was 9g; filed with the Court for privacy reasons. The First Further
ä 18 provisions. The Judgment states that the First Further Judgment cannot be filed with
19 the Court, except for enforcement purposes, and that certain notice requirements must
20 be met before filing it. This Request for Domestic Violence Restraining Orders is not
21 an enforcement issue, and I am making this application without notice to John; thus,
23 upon the Court's request, I will lodge a copy of the First Further Judgment.
24 4. John had a history of abusing alcohol and drugs, including cocaine, during
25 our marriage. He also had a history of anger management issues. He is a former army
26 captain; he has owned a gun and a cross-bow in the past and may own them now. I
27 obtained a DV-TRO against him in 2016 during our Dissolution case, and he
28 relinquished a gun in connection with the 2016 DV-TRO. A true and correct copy of
' 1 my 2016 DV-TRO application, the 2016 DV-TRO, and the 2016 Order on Request to
3 5. Pursuant to the First Further Judgment, I have sole legal and physical
4 custody of our children. At or about the time we entered into the First Further
6 after sending me emails stating that he was going to kill himself. While John was
7 being treated at UCLA, someone from the hospital called me to issue a Tarasoff
8 warning, stating that John was expressing an intense desire to kill me. Further details
9 relating to this incident are set forth in my August 15, 2016 Declaration, which is
g 13 Hospital. It further provided that upon his discharge from UCLA Psychiatrie Hospital,
ä g 14 he would have four (4) hours per week of supervised Visitation with the children for a
' ä 15 period of nine (9) months. It further stated that following this nine (9) month period of
E g ä 16 supervised Visitation, John and I would meet and confer regarding his Visitation
g 17 schedule. Since John's nine (9) months of monitored Visitation ended, he and I have
w ä 18 not formally entered into a different custody arrangement. We have been generally
19 cooperative with each other in informally determining Visitation times for John on an
20 ad hoc basis, although our younger children, Jordan and Joshua, have declined to see l
21 him in recent months. i
22
23 7. The most recent incident of abuse occurred on July 27, 2019. By way of
24 background, our son, Daniel ("Danny"), is a soccer player and was scheduled to attend
25 a residential soccer camp at UC Davis next week. John and I had previously agreed
26 that John would drive Danny t0 Davis for drop-off at camp. On July 27, 2019 at
27 approximately 11:27 a.m.‚ John sent me a text message stating that he had to go on a
28 business trip, which meant that he could not take Danny to camp. John copied his
O C
. In Re the Marriae of Pierce L.A.S.C. Case No. BD 639 740
1 personal assistant, Lauren Green‚ and another person‚ Troy Queenl, on this text
2 thread (I do not know why). I am unable to take Danny to Davis myself because of my '
3 work schedule‚ so I sent John a text at 12:20 p.m. that day, stating that we could cancel
4 camp, and that it was not a big deal. John responded with a text that stated, "U don’t
6 8. For the next hour and a half, John texted me over sixty (60) times. His
7 texts were threatening, insulting, full of expletives, and largely non-sensical. For
9 I am Jewish and John is not, and though I cannot remember a time that I discussed
g l0 Israel or Judaism with John in years‚ a large number of his above-referenced texts
ä 13 continued texting me, over and over. The following is a sampling of the text messages
ä 14 John sent me on July 27, 2019 during the period from 12:20 p.m._through 1:55 p.m.:
E ‘a: i» 16 b. "He is the best freshman that ever lived. Puts u anrl me to shame.
ä 17 That is for God damn sure. Dont fuck with me right now. I will bur u
20 d.’ "BITCH"
22 f. "Fuck u foreVer"
23 g. "I will fuck u and ur kind u. U have no idea" (Emphasis
24 added) V
25 h. "U have no idea what’s comin ur wa. Time is tickin.
27
1 i. "iiarmageddon"
2 j. "Slut"
3 k. "I fucking warned u"
6 (Emphasis added) i
7 n. "Bitch" L
8 o. "Watch Jack Bauer on 24 if ur curious what I’m capable of."
9 p. "Va11ey cunt"
ä 11 better than u. But no, I spend my life protecting the innocent and
19 (Emphasis added)
25 Cunt."
26 w. "I cant hear u!!!!????? Cunt"
6 9. The following morning, John sent a text message on the same thread,
7 stating, "Sorry about all that. Had a bad day yesterday. All good now. Didnt mean any
8 of that." A true and correct copy of the complete‚ unedited transcript of the above-
9 referenced text thread, including the messages from July 27, 2019 through July 28,
8 10 2019, is attached hereto as Exhibiti"3" and incorporated herein by this reference. This
ä 11 transcript came from data that was extracted directly from my cell phone with the
ä ä 13 Lockwood). In Exhibit "3", John's messages are printed in gray and are identified
ä g 14 with the name "John Pierce Final" (which is the way his contact information is saved
ä 15 in my cell phone), and my-texts to him are printed in green and are identified as
' E. g ä 16 "Mommy". The relevant text messages begin in themiddle of page 3, but I have
u ä 18 10. Upon receiving these texts from John, I was extremely scared for my
19 safety and the safety of my children. I believe John's text stating, "I will fuck u and
20 ur kind u" (emphasis added) was a threat to harm both me and our children. His
21 text stating, "I will be at Armaeddon with y children fihtin aainst u"
22 (emphasis added) also causes me to fear for my safety and the safety of our children.
23 There were multiple other texts messages that directly threatened me. Thus, on July '
24 27, 2019, I filed a police report at the Van Nuys Police Department, and I received an
25 Emergency Protective Order ("EPO") that day. A true and correct copy of the EPO is
26 attached hereto as Exhibit "49 and incorporated herein by this reference. The EPO
' 27 expires on August 2, 2019 at 4:00 p.m. I caused John to be served with the EPO on
28
. _ 5
DECLARATION OF ALYZE PIERCE
l '
J . O .
A
1 Juiy 28, 2019. A true and. correcl; cqpy pf the Proof of Service is attached hereto as
2.. Exhibit "5".
3 11. Icontinuezto be scaredfor my’ safigty -and our childres safety. I have not
4 slept weil in days, and I've been constantly worried. I d0 not know what caused John
5 t0 react to a benign text with auch rage. I db not know if he is usi-ng. drugs again. Izdo
6 ‚not know if he is» having psychiatric issues again. He4 has military ‘training and has
7 owned gur-xs in the passt; he may own a gunnow. John knows that our children are the
8 most "important. thing in the world to 1ne-,_ andI feax- that hexmay harm’ them in a rageful
9. ‚Staate äsa means, of hurting me.
g I0 12. I request that the Court "issue an- Order th at Respondent have n0 visitation
ä ILI with the minor children, or that Aqany visitation "be monitoredby zrprofessional monitcir,
ä’ x ä 12 idcclare under penalty of perjury under the‘ iawlsoffhe‘ Statc of CaIitbnlia thait thc
ä ä 13 forcgoizxg is tme and cornzct.
äs-äg 15 x-<‚«z*_..—-——
ä 17 ALYZE ‘RCE
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4 of the facts set forth herein, and if called as a witness, I could and would competently
9 Braffman Amen, I met with Petitioner, who gave her cell phone and cell phone
g 10 password to me. With Petitioner's permission, I attached her cell phone to my ofce
ä 11 Computer, and using a program called iExp1orer‚ I exported all data on her cell phone,
ä U ä 12 thereby creating a back up copy of her cell phone's contents. The data I exported from
ä ä 13 Petitioner's phone included all text messages on the phone. From this data, I printed
ä g 14 a transcript of the entire text thread between Petitioner and 213-500-7 339 (identied
2 g ä 16 Petitioner's phone as John Pierce Final), and 310-484-4514 (not identied by name).
ä 17 A true and correct copy of this transcript is attached hereto as Exhibit "3" and
19 4. The top of the rst page of Exhibit "3" contains the details of the above-
20 referenced export and the phone numbers of the participants on this text thread.
21 I declare under penalty of perjury under the laws of the State of California
25
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EXHIBIT 11
FL-1 80
‘ ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, 3mm Bar number, and addrass): FOR couRT usE omy
GARY FISHBEIN (SBN 93765)
BUTER ‚ BUZARD, FI SHBE IN & ROYCE LLP
11611 San Vicente Boulevard, Suite 82 0
Los Angeles, CA 90049- 6508
TELEPHONE m0.; 310 — 820- 6700 FAXNO. (Optional): 3 l0 — 207-4612
EMAIL ADDRESS (Optional): f i shbe in@bbf rl aw . com E’???
ATTORNEY FoR (Name): Petitioner ‚ Alyze L . Pierce
SUPERIOR coum’ 0F CALIFORNIAQOUNTY OF Los Ange" es °}9-;‘?-‘v'-“3‘"’T‘/ 1&3?‘
. STREETADDRESS: 11l Nort Hill Street * "r- o - ‚ , "
MAILING ADDRESS: Same f
CITYAND zu= cooaLOS Angeles ‚ CA 90 0 12
BRANCH NAME: Central District . Gang, lgßä-Qgggnujgk? mnger/Cark
MARRIAGE OR PARTNERSHIP OF v. Martin 600559.:; pggmy
PETlTloNERzALYzE L . PIERCE '
REsPoNoENTzJoHN M. PIERCE
JUDGMENT CASE NUMBER:
ü DISSOLUTION E] LEGAL SEPARATION E] NULLITY BD 63 9740
E] Status onIy
Ü Reserving jurlsdlction over termination of marita! or domestic
_ partnership status
Ü Judgment on reserved Issues
Date marltal or domestlc partnership status ends:
1. Ü Thlsjudgment Ü contains personal conduct restraining orders Ü modifies existlng restrainlng orders.
The’ restralning orders are contained on page(s) of the attachment. They expire on (date):
2. This proceedlng was heard as follows: [2 Default or uncontested Ü By declaration under Family Code section 2336 -
Ü Contested Ü Agreement in court _
a. Date: Dept; Room:
b. Judlcial ofcer (name): Ü Temporary judge
c. Ü Petltioner present in court Ü Attorney present in court (name):
d. Ü Respondent present in court D Attorney present in court (name):
e. C] Claimant present in court (name): ’ E] Attorney present in coun (name):
f. Ü Other (specify name): '
n. m Attorney fees and costs are ordered as set fonh In the attached
(1) Ü Settlemenl agreement, stipulation for judgment, or other written agreement.
(2) E] Aftomey Fass and Costs Order (form FL-346).
(3) Ü Other (specify): As set f orth in the First Further Judgment .
o. E Olher (specify): All other orders as set forth in Pages 1 through 3 of the
attached hereto.
Each attachment to this judgment ls lncorporated into this judgment. and the parties are ordered to comply with each attachmenfs
provlslons. Jurisdiction ls raserved to make other orders necessary to carry oul this judgment.
Data: _
_ - ' JUDICIAL OFFICER
5. Number of pages attached: 3_________ m SIGNATURE FOLLOWS LASTATFACHMENT
NOTICE
Dissolulion or legal Separation may automatlcally cancel the rights of a spouse or domestic panner under the other spouse’s or
domestic partnes will, trust, retirement plan, power of attorney, pay-on-dealh bank account. transfer-on-death vehicle registratlon,
survivorship rights to any property owned in joint tenancy, and any other simllar property interest. lt does not automatically cancel the
rights ofa spouse or domestic partner as beneciary of the other spouse's or domestic partner's life insurance policy. You should
' E review lhese matters. as well as any credlt cards‚ other credlt accounts, lnsurance policies, retirement plans, and credll reports. to
determine whelher they should be changed or whethar you should take any other actions. * ’ ' ' - -
‘ A debt or obligation may be assigned (o one party as part of thedissolution of property and debts, but if that pariy does not pay the
debt or obligatlon, the creditor may be able to collect from the other pany. . .. . . . _ . _ '
An earnlngs assignment may be issued without additional proof if chlld, family, partner, or spousal Support is ordered. ''
- Any party requlred to pay support must pay inlerest on overdue amounts at the "legal rate," which is currently 10 percent.
s FL-180[Rev.July1‚ 2012) JUDGMENT Page 2 of2
. ‘
M-S;
nr Balkan‘
‘Famm’ "3"" PIERCE , ALYZE L.
. NOTICE OF RIGHTS AND RESPONSIBILITIES . ‘M92
Health-Care Costs and Reimbursement Procedures
IF YOU HAVE A CHILD SUPPORT ORDER THAT INCLUDES A PROVISION FOR THE
REIMBURSEMENT 0F A PORTION OF THE CHILD'S OR CHlLDREN'S HEALTH-CARE COSTS
AND THOSE COSTS ARE NOT PAlD BY INSURANCE, THE LAW SAYS:
1. Notice. You must give the other parent an itemized 7. Preferred health providers. lfthe court-ordered coverage
Statement ofthe charges that have been billed for any health- designales a preferred health-care provider, that provider
care costs not paid by insurance. You must give thls must be used at all limes consistent with the terms ofthe
Statement to the other parent within a reasonable tlme, but no health insurance policy. When any party uses a health-care
more than 3D days after those costs were given to you. provider other than the preferred provider, any health-care
2. Proof of full payment. lf you have already paid all of the w“? the? Would haye been paid by the preferred heanh
uninsured costs, you must (1) give the other parent proof that pwvldetlthat Provider häd beep used must be the Sole
you paid them and (2) ask for relmbursernent for the other responslbmty of the pay mcumng those Costs“
parenfs court—ordered share of those costs. -
' FL-192(Rev. Januaryl. 20151 NOTICE OF RIGHTS AND RESPONSIBILITIES Page 2ol2
’ ‚xlmllumnrs ___ Health-Care Costs and Reimbursement Procedures - - - *
v; ESSENTlAl FURMS“ PIERCE, ALYZE L .
' r 7 O O
2 1 STATISTICAL INFORMATION
3 The COURT FINDS that the following information has been set forth by the parties:
4 1.1 This Judgment is made by and between Petitioner, Aiyze Pierce (hereinafter
7 1.3 The parties have three minor child from their marriage: Daniel Pierce, born
8 February 2, 2004, age 12; Jordan Pierce, born August 1, 2005, age 11; and Joshua Pierce,
5 9 born April 16, 2008, age 8 (hereinafter collectiveiy referred to as the "minor chiIdren").
z 10 1.4 Petitionerand Respondent were residents of the County of Los Angeles, State
ä ä?‘ 11 of California, at the time this action was filed and resided continuously in this state and
ä 12 county for a period in excess of six months prior to the filing of the action for dissoiution of
_z_ ä 13 marriage.
‘ä 14 1.5 Irreooncilabie differences have arisen between the parties which have led to
ä 15 the irremediable breakdown of the marriage. making it impossible for the parties to Iive
2% 16 together as husband and wife and the‚y have agreed to separate and live perman ently apart.
5 ä 53% 17 The parties’ date of Separation is May 28, 2012. Petitioner filed a Petition for Dissolution of
äg 18 Marriage on ApriI 25, 2016 in the Superior Court of California, County of Los Angeles, case
in?’ 19 number BD 639740. Respondent filed a Response to said Petition on June 24, 2016.
E 20 2 EXECUTION AND ENTRY OF FIRST FURTHER JUDGMENT _
ä 21 2.1 The Court finds that the parties and her/his respective counsel acknowledge
22 thattheynave, concurrentlywith their execution ofthis Judgment‚ executed two (2) duplicate _ _
23 origin als of a First Further Judgment on Reserved Issues (collectively referred to as the “First
'
24 Further Judgment") pursuant to which the parties have settled all of the remaining issues in
25 these proceedings. The Petitioner shaII retain one duplicate-original of the First Further
26 Judgment and Respondent shaII retain one duplioate original ofthe First Further Judgment.
27 The parties agree and the Court further finds th at the First Further Judgment has not been --
_
7 28 submitted to the Court for execution and the parties intend and agree that the First Further
Judgment shall not be entered by the Court, except if a party seeks to enforce the terms of
2 the First Further Judgment as described herein. The parties agree and the Court orders that
3 the Court retainsjurisdiction over the parties to enforce this Judgment and the First Further
4 Judgment until performance in fuII of the terms of this Judgment and the First Further
l 5 Judgment.
6 2.2 If eith er party determines she or he needs or desires to enforce any of the
7 terms set forth in the First Further Judgment, either Petitioner or Respondent may cause the
8 originai executed copy of the First Further Judgment in her or his possession to be filed with
j 9 the Court in this matter, subject to the notice provisions set forth in paragraph 2.3 herein.
J 10 Upon such request by either of the parties, the Courtshall enterthe First Further Judgment.
ä äg 11 2.3 Notwithstanding theforegoing‚ the First FurtherJudgment shall not be filed with
g 13 2.3.1 The party seeking to enforce the First Further Judgment or alleging a
‘ä 14 breach thereon, notifies the other party in writing of the alleged breach.
ä 15 2.3.2 The breaching party is given ten (10) business days between written
2E 16 notification of the breach and entry ofithe First Further Judgment, to rectify the breach and
E: ä 17 comply with the terms of the First Further Judgment; and
gä 18 2.3.3 The breach has not been cured within the ten (10) business day period.
E? F 19 2.4 The party seekingto have the First Further Judgment entered, after providing
E 20 notice and an opportunity to cure pursuant to Paragraph 2.3 herein, shall request that the
ä 21 Court seal the First Further Judgment prior to ling Same with the Court. If sealing is not
' 22 permitted by the Court, then said party shall seek to file the First Further Judgment in the .
23 most confidential manner possible at the time of said filing.
24 2.5 lf the First Further Judgment is not entered by the Court at the request of one
25 of the parties, for any reason, Petitioner and Respondent shali-each be‘ entitled to have the
26 First Further Judgment entered pursuant to the terms of California Code of Civil Procedure
27 section 664.6. Petitioner and Respondent each waive Notice of Motion to enter the First‘ "
28 Further Judgment pursuant to C.C.P. section 664.6and agree that said entry of the First
— 5 consent‚ and agree, that the Court shall enter the First Further Judgment pursuant to the
6 terms of the settlement set forth in writing in the First Further Judgment executed by the
7 Petitioner and Respondent outside the presence of the Court as part of the settlement of this
8 matter. The parties further approve, agree‚ consent‚ and direct the Court to retain
E; 9 jurisdiction overthe parties t0 enforcethe terms and provisions oftheJudgment and the First
_I
u, 10 Further Judgment untii performance in fuil of all terms and provisions has been
o
S äo 11 accomplished. 4
F N
27
i Dated: am 2 7 01a ‚ 2016 PATFPC“ A- “THCART. r
_ 28 JUDGE ÖF iFiE SUPER ÖUi .
PATRICK A. CATHCART
IN RE THE MARRIAGE OF PIERCE - CASE NO. so 639740
2 _
3 JUDGMENT
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- DV-116 Order on Request to Continue Hearing am stampsdale here when form is n/ed.
Complete items ® ‚ @ ‚ and CD .
Superior Court of California 3
® protected Party: County ofLos A.n;_y‚c!s.:<
. x an M‘ ä ‘ "
5E? / LÜIG
® Restrained Party: Shem R‘ °““"*w—--»-——-n- „zggr/‘cmk
Bv.._‚z.‘&zv; x r, . ä
_ _ Martin Godgtggn“ . “m”
6) Party Seekmg Contmuance
I am the m Protected Party Ü Restrained Party Fill in court name and streer address:
Your Lawyer (ifyou have onefor this case): Superior Court of Callfornia, County of
_. Los Angeles
.2 . 2
Name State Bar N0 111 North H11 1 Street:
Firm Name: Same
Your Address (Ifyou have 'a lawyer, give yaur lawyer ‘s Information. If goitigeää: €152‘: 900 1 2
ydu do n0! have a Iawyer and want t0 keep your home address private, e a‘
you may give a dierent mailing address instead You d0 not have to Fill in case number:
4 give telephone, fax, or e-mail.) - Case Number:
Address:
' ‘ U BD 63 97 4 0
City: StateAjZip: i0_0_4._9____
Telephone: Fax: -Mail Address:
i
The court will complete the rest ofthisform.
G1) Order on Request for Continuance
a. The hearing in this matter is currently scheduled for (date): .
b. Ü The request for a continuance is DENIED for the reasons set forth EI below C] on Attachment 4b.
i
r
E
The hearing shall be held as currently scheduled above. The Temporary Restraining Order (Form DV-110) [
issued on (date) .' #312 remains in full force and effect until the hearing date.
QÄTHB request for a continuance is GRANTED as set forth below. ‘
emaew 9- i
. ' ‘7
‘ Case Number:
BD 6 3 9 74 O
b. C] The court nds good cause and orders acontinuance in its discretion.
e. Other (specijja):
G) Service of Order .
a. Ü N0 further Service of this order is required because both parties were present at the hearing when the new
heng date was ordered.
b. he court granted the protected party’s reqyest to Continue the hearing date. A copy of this order must be
serv o'n the restrained party at least _‚_S_ days before the hearing in ® .
(1) All other documents requesting domestic violence restraining orders as shown in Form DV-l09‚ Notice I
ofCourt Hearing (at item 65)) must also be personally served on the restrained party.
(2) Ü The Temporary Restraining Order (Form DV-110) has been modied and must be personally served
on the restrained party.
_ (-3) Ü A copy of the Temporary Restraining Order must NOT be served because the order was terminated in
7d. ' u
c. ÜThe court granted the restrained party’s request to Continue the hearing date. A copy of this order must be
served on the protected party at least ______ days before the hearing in A copy of the Temporary
Restraining Order (Form DV-l 10) must be served if it was modied by the court in item ® .
e. C] Other (specüy):
No Fee to Serve ‘
If the Sheriff or marshal’ serves this Order, he or she will do it for free. -
@ CLETS Entry —
If the hearing is continued, the court or its designee will transmit this form within on usiness day to law
enforcement personnel for entry into the Califomia Restraining and Protective O _ e CARPOS) via the
California Law Enforcement Telecommunications System (CLETS). ' ' ' "4 > i
Data: _ - .
"w Judicial Oicer - " T
. PATRICK A. CATHCAHT
Request for Accommodatnons
services
Assistive listcning Systems, Computer-assisted real-time captioning, or sign language interpreter
are available if you ask at least fwe days before the hearing. Contact the clerk’s ofce or go to
www.courts.ca. ov/ormshtm for RequestforAccommodations by Persons With Disabilities and
Response (fonn MC-410). (Civ. Code, ä 54,8.) _
H (Clerk willll au! this parL) ‘ "
„..«-w-=uu.„_ —Clerk’s Certificate-
‚f‘. ‚öq, I- eejrtify that this Order On Request to Continue Hearing (Temporary Restraining
' _.v_ f; a. '”-.‚@"'prder)(CLETS—TRO) is a true and correct copy of the Original on le in the coun.
I am m6: m Party Seeking protecon" Fill in court name and street address:
Ü Restramed Party" Superior Court of California‚ County of
Your Lawyer (ifyau have onefor this case): ägsäaäill Street
Name: State Bar No.2 33165€ Same
'
Fm" Name
: L°S A“ 9199s’ CA 90012
Centra? DlStrlCt
b. Your Address (Ifyou have a Iawyer, give yaur lawyer ’s iräformation. If
you d0 not have a lawyer and want to keep your home ad ress private,
you Im?) give a dierent mailing address instead. You do not have to FiI/ in case number:
give te ephone, fax, or e-mail.) Gase Number: ‘
Address: lexard, S111 12a B2!) BD 639740
City: State: CL____Zip:3D.0.4.9__.__
Telephone: Fax:
E-Mail Address:
® Other Party l
Full Name:
5 I l I 1 J l E i l l .J 1 . ‚ J ‚
::;::‚::::':;-:::i‚:::';f°::::‚:"
Essenal - A (TemporarvRestrawvnsordew
(Domestnc Vlolence Preventnon) PIERCE I »
ALYZE L .
gjForms- * v
' o o ä
‘ Case Number:
BD 63 974 o g
'
Pcirä’
E] Check here zfthere are additionalprotectedpersons. List them an an atrached sheet ofpaper und write,
ggf "DV-IJO, Additional ProtectedPersons " as a titIe. ' -
' ‚ 771e cow-f M11 complete the rest ofthisform. '
’ v Court Hearing ‘ .
h T7113" order expires at the end ofthe hearing stated below: .
. ' „
Hearing Data: 44 '
55l Time: . ‚- 1 A -
. Q This is a Court
.
Order. ' .
.
äääääwäas°ääwä}n”üa°°' Temporary Restraining ‘Order ‘
DV-110, Page 1 of6
9
.
imggügoo sl saq.
(CLETS—TRO)
59-53mm’ _ (Domestic VioIencePrevention) PIERCE , ALYZE L.
E] Form:
= =< . „ .. - _ _ ______ Gase Number; __ _
"w" n 75***»: = ' ‘wem "M ‘ '-- - --- 13D’ "53-9-740. m -— 5- ;: -" -- » ä
. hNo information has been provided to the judge about a criminal proteptive order. 4
The court has granted the temporary orders checked below. lf you do not obey these orders‚ you
can be arreste.d and charged with a crime. You may be sent_to jail for up to one year, pay a fine of
up to 51,000, or both. "
® Personal Conduct Orders üNot requested > ÜDenied unü] the hearing ‘üGranted follows:
/
a. You mustnot do the following things to the person in® and Qpersons in ®: ' _ ‘
Harass, attack, strike, threaten, assault (sexually or otherwise), hit, follow,’ stalk, molest, destroy personal
property, dvismrb the peace, keep under surveillance, impersonaie (an the Internet, electronically or
othemise), or blQck movements
Confacf, either directly or indirectly, in any way, including but not iimitedto, by telephoncmail, e-mail _
or other elccüonic means '
Take any acüon, directly or through others, to obtain the addresses or Iocations of the persons i116) and
l
(‚Tfthis item i: not checked the courthqsfound good cause not to ma/ce this Order.) A
b. Peaceful wtitten contact through a lawyer or process Server or another person for Service of Form DV- 120 ’
(Response to Requestfor Damesric Violence Restraining Order) or other legal papers related to a comt case is
allowed and does not violate this order. "
c. C] Exceptions: Brief and peaoell contact with the person in ® ‚ and peacexl contact with children in @ , as
required for court-ordered visitation of childrem is allowed unless a criJninal protäctive order says othenvise.
® Stay-Away Order E] Not requested C] Denied until the hgäring ‚KGranted as folllows: l
a. You must stay at least (specißl): Ä yards away öm (check all that apply): '
2 The person in G) ' School ofperson in@ l
S Home of person in ® ‘ EIThe persons in ® _ ‘ Q
ä The job or workplace of person in (D T116 child(ren)’s school or child care ' \
[Z] Vehicle of erson in® Ü Other (speciß2):
I b. C] Exceptions: Brief and pcaceful nonfact With the person i116), and peaceftzl contact with children in@, as"
required for court-ordered visitation o'f childyen, is allowed unless a cdminal protective order says
otherwise. '
Move-Out Order Not requested Ü Denied until the hearing Ü Granted as follows:
You must take only personal clothing and belongings needed until the hearing and move out immediately from
(address): ä ____ ._ _. .____ ____ _ ‘ _ '
%
Case Number: .
g
ä
u Sell to‚'or store with, a Licensed gun dealer, or tum in to a law enforcement agency, any guns or ofher rearms
within you: immediate possession or control. Do so within 24 hours of being sen/ed with this Ärder.
o Withixx 48 hours of receiving this Order, le with the oourt a receipt that braves guns hzwe been tunied in, '
gstored, or sold. (You may use Form DV—800‚ ProofofFirearnw Turned In, Sold, or Stored, for the receipt.)
Bring a court led cbpy t0 the heaxing. .
°v ‚EI T
Record Unlawful Communications ''
Ü Not requested Ü Denied unl the hearing" M Granted as follows: „ _
"Ihe. person in ® can record commuqicafions made by you that violate the judge’s ofders. _ .
® Care of Animäls Not requested [j Denied until the hearing Ü Granted asfollows: ‘
'I'he person in (D is given the Sole possession, care, and control of the animals listed below. The person in ®must
stay at least yaxds away om and not take, sell, transfer, encumber, conceal, molest; attack, strike,
threaten, harm, or qtherwise dispose of the following animals: .
.
@ Child Custody and Visifation" l:|Not requested DDeuied unl the heäring qGranted as follows:
Chjld custody and visitation are ordered on the aa er or
(specijja otherform): ______________. The parent with temporary custody of the child must not renjove
the child from California unläss the court allows it aftcr a noticed hearing CFam. Code, 5 3063). '
®Child Support . . _ '
' Not ordered now but may be ordered aftcr a noticed hearing. _
Property Control ‚äNot requested C] Denied unl the hearing Granted as follows: '
- Unül the höaring, only the person in ®can use, control, and possess thci following property: '
.
G9 Debt Payment {äqot requested Ü Denied unl the hearing Ü Granted 2s follows:
The person in ® must makc these payments until this order ends: - A
Pay to: ________ For: ______.__ Amount: S _________ Due date: ______‚__
f Pay to: __________._ For: _________ Amount: S ____.? Due date: ________
Property Restraint äNot requested E] Denied ntil the hearing C] Gfanted as follows:
If the people in ® and ® am manied to nach other or are registerad domestic parlilers, Üthe pefson in ® .
[j "the person in ® must not transfcr, boow againät, sell, hide, or get rid of or destroy any propexty,
including animals, except in the usual couxse of business or for necessities of life. In addition, each person must b
notify the other of any new or’ big expenses and explajn them to the court. (Yheperson in ® cannot contact the
person in ® ifthe court has made a ”no contac!” Order.) .
to a
' Peaceful written contact through a läwyer or a process server oxjother person for Service of legal papers relatcd
court case is allowed and does not Violatc this ordär.‘
Gaspousal Support » . l
Not ordered now but may be ordered after a noticed hearing. ' H
[3 Check here Ifthere are additional orders. List them an an aached sheet ofpaper and write "DV-I 10, Other
Orders” a: a title. _ . '
No Fee to Serve (Notify) Restrained Person
i!“ Ifthc Sheriff serves this Order, he or she will do so for ee. (
lf You Do Not Obey This Order, YouCan Be Arrested And Charged With a Crime. 4
- Ifyou do not obey thjs order‚ you can go to jail or prison and/er pay a ne.
- It is a felouy to take or hide a child irrviolation öf this order.
- Lf you tmvel t0 another state or to tribal lands or make the protected person do so, with the intention of disobeying this
Order, you cm be Charged with a federal Crime. ‚ — _
shown
This order is effective when made. It is enforceable by any law enforcement ageney that has received the order, is
copy of the order, or has veried ifs exjstenee on the California Law Enforcement Telecommunications System
restrained . _
QECLETS). Ifthe law enforcement agency has not received proof of Service on the restrajned person, and the
gerson was not present at the court hearing, the agency shall advise the restrained person of the terms of the order and „
0 shall enforceit. Violaons of this Order are subject to criminal penalties. _ .
. Even i.f the protected person invites or consents to contaet with the restrained person, the orders remain in effect and must
The
be enforoed. The protected person cannot be arrested for inviting or consenting t0 contact With the resfrained person.
orders can be changed only by another court Order. (Pan. Code, 13710(b).) A ' E
l
"a. I certify that this Tempormy Restraining 0rd r a e and correct copy of the '
95i" '
" “n -' 77"- ‘(9 ‘s Original on le in the couxt. ' I’ ‘ü
Ä I ‘
. ' . f v
2511-"?!
BSEHUÄL HIRMS"
ä-
4 (‘
‘ . 7 ' i:
. ‚ \ .
D Other Orders
as a title. '
Check here and attach any other orders ta thisform. Write "DV-1 40, Other Orders"
Jurisdiction _ _ ' '
Uniform Child Custody Jurisdiction
Thß court has jurisdiction to make child custody orders in this case under the
and Enforcement Act (part 3 of the Califomia Family Code Starting with ä 3400).
E] Move-Out Order
(Ifthe person in ® lives with you andyou want thatperson to stay awayfrom your home‚ you must askfor
this move-out Order.)
53:49 I ask the court to Order the person in® to move out from and not retum to (address):
ägägm“ Request for Domestic Violence Rgstraining Order DV-100, Page 2 of6
E51’ (Domestlc Vlolence Preventnon) PIERCE, ALYZE L _ 9
, ' ' _ Case Num er:
BD 6 3 9 7 4 0
® E] Debt Payment
I ask the court to order the person in ® to make these paymentswhiletheorder is in effect: '
D Check here i You need more sP ace. Attach a sheet o PaP er and write "D V—1 00, Debt Pa)’ment" or a title.
Pay to: ____„____For: _____________ Amount: S ______Due date: _________
a Property Restraint
' I am married to or have a re stered domestic artnership with the person in . I ask the judge to order
a" P
that the pörson in ® not 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
W me of any new or big expenses and to explain them to the court.
@ EI Spousal Support .
I am manied to or have a registered domestic partnership with the person in ® and no spousal Support order
exists. I ask the court to order the P erson in to Pay spousal su PPort. (You must complete, le, and serve Form
FL-I50, Income and Expense Declaratio u be ore our hearin .
This is not a Court Order. ‘
‚ “°"“"““""’°’° Request for Domestic Violence Restraining Order DV-100, P a re
l 5828W“ (Domestic Vlolence Prevention) age o 9
53-9511? . PIERCE‚ ALYZE L.
Gase Num - er:
BD 6 3 9 74 O
E] ‘Check here zfyou need more space. Altach a sheet ofpaper and write "D V—J00‚ Other Orders "for a tirIe.
a Check here ifyou need more space. Attach a sheet ofpaper ana’ write "D V-I 00, RecentAbuse ”for a title.
3. Did the person in @ use or threaten to use a gun or any other weapon? E] No E] Yes (Ifyes, describe):
.
E] Check here ifyou need more space. Attach a sheet ofpaper and write “D V-1 00, RecentAbuse "for a
title.
3. Did the person in ® use or threaten to use a gun or any other weapon7 E] N0 E] Yes (Ifyes, describe):
I declare under penalty of perjury under the laws of the State of Califomia that the information above is true and correct.
Date: _
Myze E; arge b See attached sinature
Type or print your name Sign your name
Date:
D Check her: ifyau rxeed more space. Altach a shee: ofpaper und write "D V- I 00. Recem Abuse "for a
title.
3. Did thc person in ® usc or threaten to usc a gun or any other weapon? E] N0 E] Yes (lfyes. describe):
Date : —————— E’ .
‚____________.
5 this Declaration in support of my'Request for Temporary Restraining Order led herewith.
6 . STATISTICAL INFORMATION I
7 1. Respondent and I have three children from our marriage, DANIEL (age 12),
8 JORDAN (age11)‚and JOSHUA (age 8). I led a Petition for Dissolution of Marriage on April
S 9 25, 2016 and Respondent executed a Notice and Acknowledgment of Receipt o_n May 24,
I 10 2016. .
ä ä” 11 FACTS RELATING T0 CURRENT ABUSE
ä äää 12 2. On August 13, 2016, at 10:45 a.m., I received an email from Respondent,
E 13 stating: "I had to check into UCLA. I am suicidal. I put 40K in joint account. My dad and
ä 14 Iawyers and Steve will have to Iiquidate retirement funds there is Iike 700K you can have it
ä 15 all to pay 2014 taxes and there wiII be some Ieft over. My parents wiII help with the kids. I
u". ä ä 16 Iove my children. I will sign whatever power of attorney or legal documents anyone wants.
g 17 I cannot handle Iife or society anymore." A copy of this email is attached hereto‚ marked
E 20 doctor a_t UCLA, informing me that Respondent had been admitted to the Hospital and that
ä 21 Respondent was expressing an intense desire to kiIl me. The ER doctor toId me he was
22 calling to issue a Tarasoffwarning and that the phone caIl was being documented in the
23 UCLA Iog. I was toId that Respondent was placed on a mandatory 3-day hold and that the
24 poIice were caIIed. I was in shock, and was unable to request details from the employee,
25 such as which police station was contacted, the name of the employee I was speaking to,
26 etc.
' 27 4. I spoke with Respondent’s nurse at 10:00 a.m. on Monday, August 15, 2016.
28 She connned that my conversation with the ER doctor was kept in the UCLA log, and that
5 He informed me that Respondentwould be Ieaving the hospital soon, and that all he wanted
6 was to see our children. When I told Respondenfs father that I was glad Respondent was
7 feeling better, he told me that this was aII my fault, and this would not have occurred if I had
5 9 6. Between August 11, 2016 and August 13, 2016, I noticed Respondent
.1
m 10 exercising increasingly erratic and aggressive behavior. In those three days, he called,
o
ä 22 11 texted, or emailed me no Iess than 30 times. I answered the phone three times, and each
c a» g .
ä 12 time I answered, he screamed atme, shouting obscenities and threats. He toId me that he
O U) G)
z ä z‘, ä 13 couId not handle Iife anymore, that I was to blame and that if his Iife was destroyed‚ he would
— Q 5 o: o
ä ä; 3E 14 make sure to destroy the Iives of me and our children. He told me that he has nothing, there
I n: = ‘- c‘,
<3 ää g 15 is no place for him to go, and that society has thrown him away. Examples of the emails I
“.25 16 received are attached hereto, marked Exhibit 2, and incorporated herein by this reference.
D e3g"
5 3, 17 7. In May 2016, Respondent lost his job. at K&L Gates for physicaIIy assaulting
E G! c:
g 5?; 18 another employee. Respondent detached his retina during the altercation. lt was believed
m. 2 3 19 that the altercation was a result of Respondent’s drug and aIcohoI abuse, and so
o:
I“ 20 arrangements were made for Respondent to check-in to rehab at Promises Facili .
.
F.
24 Respondent's behavior during his most recent visits with the children, I am concerned that
‘i’? 25 he is too unstable and erratic at this time to be abIe to care for the children.
14:?
26 9. Respondent has not seen our children since July 16, 2016. On that date, the
27 visit Iasted approximately 3 hours. Between January and July 2016, he saw them once
28 every 3-4 weeks, for 4-5 hours at a time. He had one overnight with the children in January
3 10. During their most recent visits, Respondent sIept for most of the time and left
4 the children unattended. His house was unkempt, with alcohol bottles and cans of tobacco
5 Iying about. Respondent complained of being tired throughout the visits and did not chänge
» 6 his clothes. The children told me that they are scared to be with Respondent.
A 7 11. In May 2016, the children and I had to Ieave our house in ShermanOaks
8 because oftoxic; mold. Respondent was working in San Francisco, and offered to Iet us use
Ü 9 his home while we Iooked for a new place. I led the Petition for Dissolution Iaterthat month,
Z 10 and when Respondent received it, he called me to teII me thatthe children and I needed to
i; ägm 11 vacate the home by midnight, or he would caII the sheriff and have us thrown out. I put all
S 12 of our belongings in garbage bags and moved them to my mothes house that afternoon.
5 äxj 13 12. I do not know when Respondent is Ieaving the hospital. I am concerned for our
ä 14 safety, and a restraining order is necessary to ensure that Respondent does not harm me
15 or ourchildren. ’
u". ä ä 16 I decIare under penalty of perjury under the laws of the State of California that the
E 2o . ' .
ä 21 See attached signature
22 ALYZE L. PIERCE
' 26
27
28 ’
5 ä; g 13 ‚ 12. ldo not knowwhen Respondent is leaving the hospitat. I am concemed for our
=°s i . » .
i: w z 2 s 14 2 safety‚ and a restrainlng order 1s necessary to ensure that Respondent does not harm me
I E "5 E (9 c
bg g 15 g or our chiidren.
2% 16 l declare under penalty of perjury under the laws of the State of California that the
‘n. ä I
x
19 2
Executed on August 15, 201e, at Los Angeles, California.
. m 20|
"' i;
::
m 21
. i’ f . .»————
24». _
26i
w f
' 27
2a
_ I iN RE THE MARRlAGE 0F PIERCE OASE N0. B0 839740
i ggmmgg 5.1. ,1 ‚ __EAQE.Q
’ - DECLARATION OF ALYZE L. MERCE
_ . ‚ . . .. _
' Ali Fishbein
From: Ali Fishbein <ashbein@bbfrlaw.com>
Sent: Monday, August 15, 2016 10:33 AM
To: ashbein@bbfrlaw.com
Subject: FW:
I had to check into UCLA. I am suicidal. I put 40K in joint account. My dad and lawyers and
Steve will have to liquidate retirement mds there is like 700K you ca.n have it all to pay 2014
taxes and there will be some le over. My parents will help with kids. _I love my children. I will
sign whatevcr power of attomey or legal documents anyone wants. l1 cannot handle Iife or
society anymore.
Q?’
1
Ali Fishbein
we have to talk asap my whole life has collapsed we have t0 work collaboratively _
to minimize harm to kids in the long run. i may have to move away. i am sorry
for everything i never intended to harm anyone i just never grew up. i have
always loved u more than u can imagine. i just want t0 sleep
P4i?
12i.
1
1 ‚ „ _ Q O
Ali Fishbein
I have to go to hospital my emotions are out of control. I will have lawyer and Steve statt getting
things ready to take care of 2014 taxes to make sure you are o" hook. Please make sure the
children know how very much I love and adore 01cm.
1. Contact Joe and have him do 1 year lease on Chats worth propeny: get it to at least cover
. mortgage and other related expenses plus cost of property management company. Have
property management company handle everyxing. So lease price should cover all mortgage,
maintenance costs and property management company costs
3. Setup meeting with Lacher. This is crucial. Give him every detail of every nancial debt,
asset, hide nothing. Come up with way (work with IRS, etc) to pay remainder of 2014 taxes and
your 2015 and 2016 taxes (I paid my own 2015 and 2016 separately and used Steve)
4. Move back to Erie: get your life gured out_. Your parents can take care of you. All you have
to focus on is getting well and nding a job! It is not too late for you but sitting around feeling
hopeless won't get you anywhere ,.
Sent om my iPhone
2 l V 1
Ali Fishbein
Alyze I am in extreme distress. U are spending my money and I am handling the debt. Forget
the Iras but the Latham is mine anyways as separate property. Pls call me it is emergency
53%?
1
‘m.
g?
ätit”
R244?
EXHIBIT 3
Chat with Lauren Schaefer Green, John Pierce 8L +1 310-484-4514
6/22/2019 6:11:09 AM — 7/28/2019 9:21:20 AM
Export Details:
Device Phone Number +1 (310) 883-5690
Device ID 00008020-000230513EO6002E
iOS 12.3.1
Participants:
+1 310-484-4514
Troy can u pIs work with Jim and whoever in rm and insurer 5 ‘I’ “W
to get this done ASAP thx
John Pserce Fmal
https://www.Iinkedin.com/feed/update/ e 11 AM
urn:Ii:activity:6548183511919140864
Mommy‘
Meaning, Lauren: I knovv this i5 ‚Jinfsjola. I can send the receipts 6 f4’Äi‘\\‚1
again but I need t0 get reimbursed
Page 1 3
l
l - a‘
' C O
’ John Pverce Frnal
+1 310-484—4514
|'Il shake everything loose and update on Monday 5 25 ‘W
Nlommy
+1 3vo_4s4-4514
You as weII 5 35 A“
John Pverce Final
Alyzee what is kid status are they all at camp tika 6 “l3 A“
John Pxerce Final
Page 2
' Lauer Scnaefer Greer
Hi! Can you pls make sure to laring l2 plain bagels (from grocery ; 9g W
store) and also a pack of 48 waters to Stanford. Also give Danny
S50 for night pizza and snacks
Lauer Scnaeier Green
John- resent you all the info last night. Iet me know you got
it. and if Troy is still staying there with you, maybe he can 35 A“
print the Stanford agenda packet (4pgs).
Saturday July 2T 2019
JON‘ Dzerce Fsnal
Alyze, I have to go to the East Coast Tuesday nite for some < _
mission critical Iaw firm stuff in NY and Boston. Likely back " 3’ All‘
early the following week. So wont be able to do any soccer
stuff for Danny boy during that time range
NlCITTWy
Or I can have my parents or Lon come out and take him ‘3 '3 m"
40°." P>er:e Final
Page 3
' 352m” Pserte Final
It's not a big deal. He doesn't even Want to go. It's Iike S200 m 2': m"
Jcnn Pierce Fmai
U cancel that u can work on the street for the rest of ur Iife ‚2 25 DM
Iike u should. Or beg me for money the way u already do.
Ion." Pierce Final
Page4
' O O
' ‚:*" 3973s Flraa
NAME IT ‘i 3‘ "l
„r“ 13-925 Pha:
BITCH ‘3 i’ 3“”
4C"? Qlece F ‚"3;
#armageddon ‘Z 35 3“”
„cf“ I3 5te 3mal
Slut ‘I 45 3“
.2” P-erce Pnal
I fucking warned u ‘3 35 S“
m"? Perce F nal
Or go work out for 12 hours. Fucking ungrateful skank ‘*3 3" 3"‘
‚cm P erce Fmaä
Page 5
l
Ruin my fucking Iife. Ya, we'll see how that works out for u “3 “"3 3"“
4;“ 3 eice —: bei
U Iike AOC??? Say it. Dont be shy. Be a Iibtard. Say it. Anti-
semite whore. Fuck u. I will fuck ur kind up. She is going to ‘I: d; w
talk about concentration camps?? Fuck u. I was in the US
Army. We Iiberated the concentration camps. Fuck u
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Page 6
I. WILL. FUCK. U. UP. VALLEY. GIRL. WANNABE. HLS. POSER. ‚L- 5; zu
BITCH.
People Iike u hate the USA. Guess what bitch, we ain't goin
anywhere. Ever. Go to hell where u belong. America belongs *3 57 5“"
to US and God.
Anti-semite skank ‘ 3‘ m”
5:?” 3 arte F "a:
Answer for urself slut. Name one thing u have done for „ : ; ;„.
Israel. ONE. MOTHER. FUCKING. THING.
One thing. ‘ W
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Page 7
Say it ' M 9“’
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2:5 I ' M *
w Do u even know what Armageddon is??? Fucking ‚_ 36 W
uneducated moron clueless anti—semite bitch.
Page 8
John Pierce Final
vs evil.
lt is good vs
It is evil. I am good.
I are eviI.
good. U are evil. God is on my
is on my side.
side. I
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will hunt
will u down and fuck
hunt u u up.
fuck u up.
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I gEpoxjoj ONEuc-‘ppy In 45mm. an‘ wo Iuvatnoa pmon. aus copy Io q4
- EI stay awaxrjat Ieast‘: vards from 1 ' |3 move out immediately from .
{addmss}: ' . _ I - - - ‚Z7
d. YOU MUST NOT own, ppsses‚s_‚i'pur_chase‚’ receive. or attempt t_o purqhase or receive any rearrn or ammunition. II you have
any rearms. you mustß turn {Harn In .to a Iaw enforcement agencybr seII them" to. or store them with, a IIcensed gundealer.
e. YOU MUST NOT take any action, dbirgctly or through others. Io obtain thenaddresses or Iocatlons of any person named In Item 1. 7
4, E] (Name): 2 - ’ " ' V D _ ' g I; given teinporary care and control of the following ‘4
minor chIIdrenof the. parIies (nah1”9s_ qnd eges): '" A . .
7. _ Reasonable grounds for the issuahnce of thIs Order exivst, and an erlnergvency protective order Isqneoessary to prevent the occurrence
or recungnce of domestIc vIoIence‚ chIId abuse, chIId abduction. elder or dependent adult abuse. orstalking. . v
i 8- JudIciabI ofcer (name): 5%) W granIecI this Order on (date): 412-: I ä v . et (time): I 2 7.5 ' '
9'. „A"Th’e.event"'sf"thA'_aI 'ca‘used the "pbrqtqcfed pänson tdfeäriminedlae and presqnt danger of domeStIc vIoIence, child abuse, child
abduction, elder or depe ent adyltabuse (e pt spIeIy nanäal abuse), or stalki s are (give factspnd dateä; specify we ans):
‚-911 '44 n > ' L " V- ’ ’ ‘V ‚i, z. q ' v ‚H114 „I, D
_____
10. D Fifeäfms wäre: D" observgd V D Ipdrfed" '“ D searched for D selbzed " _4 N
11_ [j The person to be protecIed Iives with the person to be restrained and requests an order that the restraIned person move ouI - A
I Immedlatelyfrom the address in item 3c. - . . -.
12. (E, The person to be protected has minor chIIdren In common wiIh the person to be restralned. and a temporary custody order is . '
requested because of the facts alleged in item 9. A custody order Q does sn exIsI. '-
' A9°"°V= „i! _„ „ „ „ „ .IN„___I „‚„ n T°'°P"°"° "°" O._' __s„‚_ f». 03W ”°-= 5g! I
ä 13. Person served (name): - A ' . -
I 14. I personaIIy delivergd copileciäfölfrihIs Order to ‚the person served es foIIows: Datei Timei
I ‘A517’ Address: _ . -
l 15. At the tIme of geirvice. I was at least 18 years of age and not a party to thIs cause. D I am a CaIIfornia Iaw enforcement ofcer. -
i 16. My name, address. "and telephone number are (this does not have Io be servefs home telephone number or address):
I declare under penalty ofnperjury under the laws of the State of CaIIfornIa that the foregoIng is Irue and correct. _ ' .
V Oate: b -
CASESCREENINGFACT°R<S> cmwumnnnlsrs i
E] PRINTS on OTHER EVIDENCE NOT PRESENT
E] M0 NOT ousrmcr
M pgopgafy L955 L555 “(AN 35mm
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ADDRESS
R‘ 4600 P00 AV Woodland Hllll CI
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91364
5“ 11° 44 M” 5/1975
M0 nr Lgugjgm, us-r umoue ACTIONS. n= sugmjqm, nescmne suspecrs ACTIONS IN ums: PHRASES, INCLUDING WEAPON ussn. oo NOT azpen ABOVE INFO nur cumn
nsponr A8 NECESSARY. n: ANY or m: MISSING nsns ARE POTENTIALLY IDENUFIABLE. mm2: AND oescmne ALL neue M|88ING IN 1ms INCIDENT IN m: NARRATNE.
Sus (exhuahand wlth 3 minor children in common) text Vict threntenlng mesn g es "I'm will fuck ou u erconally". Vict in ln
T0 REPORT ADDITIONAL INFORMATION: If you have specic facts to provide which might assist in the investigation of your case, please
contnct the detective Monday through Friday, between 8:00 A.M. and 9:30 A.M., or between 2:30 P.M. and 4:00 P.M. at telephone number
. If the detective is not available when you call, plcase leave a message and include the telephone number where you
can be reached.
COPY 0F REPORT: If you wiah to purchase a copy of the complete report, phone (213) 486-8130 to obtain the purchase price. Send a
check or money order payable t0 the Los Angeles Police Department to Records and Identication Division, Box 30158, Los Angeles, CA
90030. Include a copy of thia report or thc following information with your request: l) Name and address of victims; 2) Type of report and
DR number (if listed above); 3) Date and location of occurrence. NOTE: Requests not accompanied by proper payment will not bo processed.
DR NUMBER: 1f not entered on this form, the DR number may b: obtainod by writing to Records and Identication Division and giving the
information needed to obtain a copy of the report (see above paragraph). Specify that you only want the DR numbcr. lt will be forwarded
without delay. There is no charge for this service.
CREDIT CARDS/CHECKS: Immedialely notify concemed credit corporation or banks to avoid possibility cf being liable for someone else
using your stolen or lost credit card or check. .
-
l O DEPARTAMENTO DE POLICIA
O e
.‚ ‘ . DE LOS ANGELES
MEMÖRANDUM DE REPORTE PARA VICTIMAS
Su caso serä asignado a un detective para continuar Ia investigaciön basandose enfactores espectcos obtenldos durante la
investigaciön inicial. Estudios han demonstrado que Ia presencia de estosfactores pueden predecir si una investigaciön datallada
podria resultar en el arresto y prosecuciön deI responsable o la recuperaciön de Ia propiedad, de una manera que es menos coslosa para
ud, e! contribuyente. Disminuciones sigmcantes de personal han hecho imposible a los detectives discutir personalmente cada caso
con tadas las victimas de crimenes. EI detective na I0 contactara rutinarlamente a menos que requiera irgformaciön adicional. »
PARA REPORTAR INFORMACIÖN ADICIONAL: Si tiene datos especicos que proveer que puedieran asistir en la investigaciön de su
caso, favor de comunieärse con el detective de Lunes a Viemes, entre las 8:00 y 9:30 de la maana o entre las 2:30 y 4:00 de 1a tarde al
telefono . Si el detective no se encuentra disponible cuando usted Ilame, favor de dejar un mensaje incluyendo un nümero
de telefono donde se pueda comunicar con usted.
COPIA DE REPORTE: Si desea comprar una copia del reporte completo, llame al (213) 486-8133 para obtener el precio actual. Remita un
cheque o giro postal a Los Angeles Police Department Records and Identification Division, Box 30158, Los Angeles, Califomia 90030.
Incluya con su peticion una copia de este reporte o la siguiente infonnaciön: l) Nombre y domicilio de la victima(s); 2) Tipo de reporte, y
numero de DR, (si estä listado en esta forma); 3) Fecha y lugar de los hechos. NOTA: Peticiones no adjuntas al pago apropiado no seien
procesadas.
NUMERO DR: Si no aparece en esta forma, el nümero DR se puede obtener escribiendo a Records and Identication Division dändoles 1a
informaciön necesaria para obtener una copia del reporte (vea el pärrafo anterior). Especique que usted quiere el nümero DR. Serä mandado
sin tardanzas. No hay cargos por este servicio.
TARJETA DE CREDITO/CHEQUES: Notique imediatamente a su compaia de credito o banco para evitar la posibilidad de hacerse
sujeto a que alguien use sus cheques o tarjeta perdida o robada.
5CÖMO PUEDE AYUDAR EN LA INVESTIGACIÖN DE SU CASO?
Si usted pago los gastos de un entierro/meral de una victima de un delito violento, puede ser reembolsado haste 57,500 por los gastos. E1
Estado no reembolsarä por daflos o ni perdidas de propiedad. La ley [Seceiön l3959(a-c) y las subsiguientes secciones del Cödigo
Gubemamental] requiere que reporte el crimen y que coopere con la ley para recibir el reembolso. Usted tiene tres aos, a partir de 1a fecha
del delito. para hacer su reclamo (este limite se puede extender si hay una causa que lo justique).
Para recibir asisteneia de Compensacion para Victimas se puede comunicar con las siguientes: La Ocina del Procurador de 1a Ciudad de Los
Angeles (213) 978-4537 or Visite su sitio web wwwhelplacrimevicitimsorg or 1a ocida del Fiscal del Condado de Los Angeles
(800) 380-3811.
‚w‘
T}... » CALIFORNIA VICTIM COMPENSATION B0ARD= If you are a victim of a violent crime and are injured as a result of the crime, you may ' '
» be eligible for reimbursement for medical expenses, mental health expenses, relocation, loss of wages, support loss, or job rehabilitation. If -
‚ injury or death was the result of an auto accident, you and survivoring victims may also qualify if the driver at fault was charged with one of the
3 gfä following: driving under the inuence of alcohol or drugs; hit and run; using the vehicle as a weapon; or eeing the scene of a violent crime.
If you paid the funeral/burial expenses for someone who was a victim of a violent crime, you may be eligible for reimbursement for up to '
37,500 for funeral/burial expenses. Property loss o: demage will not be repaid by the Stare. The law [Califomia Govemment Code Section '
13959 (a-c)] requires that a Victim report the crime, and must cooperate with law enforcement in order to be found eligible for
reimbursement. You have three years from the date of the crime to le a claim (may be extended for good cause).
To receive assistance with the Victim Compensation application, you may call one of these agencies: Los Angeles City Attomey Victim _
Assistance Program (213) 978-4537 or visit their Website at: wwwhelplacrimevictimsorg, or Los Angeles Distriet Attomey's Office,
Bureau‘ of VictimServices (800) 380-381 l. '
GUARDE ESTE MEMORANDUM PARA REFERENCIA E‘ E -
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2. REsTRAlNED PERSON (name): Eye ootorgg 4;. R°°°‘ Jdhf. AWH} D“ °‘ "m"
Sex; MM Üp m4‘ o MJTIOHair oolorzüg‘ l Gvö .
* 3. ‘ro m5 RESTRAINED ERSON: sexually or 0016W“). hr1. follow, stalk. molest, destroy any
- P . „wen. 3653““ 0g . or block the movements of each person named in it er" 1 -
a. gpvou musr NOT harass. attack. stnka * „de, surveillan . m t l. n d‘ b _
Personal propeny of. disturb the m8: fräecy‘ b‘! am means.i!1°'“d'“9 "° ‘m. e ° Y ‘°'°Ph°n6. mall. e-mail or
_b. . B YQUJMILIJSTMOI «- - A am
t . ‚Eher 95:9. .1. - in nem‚1.
am“ „samme- dä; ‚man named mm „d, person named in .nem 1. _
°' Ü you "W7 E3613)’ EWG! 81'885‘! yards from u [j move out immediately from ‘
E] stay away a1 least: ____...— y - y
(3407088)! l t rchase or receive any rearm or ammunition. lf you have
d- 2321x287 NOT own. possess_ purohase, reoem» gejßä Ü: sAelI them to. or store them with. a lioensed gun dealer,
e. YOYU „U332: 2:31 turn them in.to a Iaw 0mm go obtain the addresses or locatlons of any person named in itern 1. 0
4_ D (Nmm; e m’ °°‘_‘°“» ‘3"."'°"V °r is given temporary Gare and eonlro! of the following ’
min“ dmdm" Of lhe parties („Mies am ages):
|7 V00 9010 qourt 1o request restraining orders, take your copy of this form with you. If a juvenile petmon is pendmg. ie in that oourt.
7. Reasonable grounds for_the issuanee o: m13 order exist. and an emergency protective order is neoessary 1o prevem the occurrence
or recurrenoe of domestac vimenoe. child
abuse. mild abduction. e|der or dependent adult abuse. or stalking. ‘l
8- 400W?‘ 01'509? (me)! (i) S granteq this Order on (date): 2 all’ l 3 at (time): l5 ' g
' . _ . . ._ . f
9. T“ °V°m3 m3‘ 080390."!!! Drotected person to ar immediate ad present danger o1 domestic violenee, ehild abuse. child j
abductlon. elder or depe - ent adult abuse (e . pt sole|y nancial abuse), or stalkin are (give facts and daleä; specify we : n n s): '._
L.—.—1|.L2. n H}! ' L l ’ r ‚f f ‚ '.IL D
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