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Jasleen Ahuja Shantey Mirzakhayan Katrina Novak 3050 Wilshire Blvd. Los Angeles, CA 90010 (213) 738-6700 Attorneys for Plaintiff, PAULA SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGGELES

PAULA, Plaintiff, vs. DOUG, Defendant

) Case No.: ) ) [PROPOSED] ORDER ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

I, PAULA, declare:

1. I am a private investigator hired by the plaintiff in this action and make this declaration in support of plaintiff's application for a temporary restraining order and order to show cause re preliminary injunction.

- 1 COMPLAINT FOR TEMPORARY RESTRAINTING ORDER

One person. another person Ralph. email. the persons committing or performing the act(s) and the relationship of these persons to defendant. shot himself in the head. Facebook. 2) film the event for posterity so that their lives would have some meaning. showing over 50 calls within one week period prior to each suicide victim’s death. Angela is a friend of Doug who is encouraging Angela to commit suicide while Doug watches via web cam. I viewed both filmed suicides on Doug’s website on October 29th. 3.2 COMPLAINT FOR TEMPORARY RESTRAINTING ORDER . Doug told me that he encouraged both individuals to 1) end their miserable lives and. Each telephone number belonged to one of the victims. Doug has told me on several past occasions that he has watched two people commit suicide. This statement is also on Doug’s Facebook page and Doug’s website. Doug should be restrained from communicating with Angela including but not limited by telephone. Sue. Sue and Ralph illustrating Doug’s continuous communication immediately preceding the victims’ . Exhibit A attached to and made a part of this application is Doug’s telephone statements. and in person. Doug represents on his Facebook page that he is an internet “death muse’ who encourages despondent individuals to commit suicide while Doug watches via web cam. in Iowa.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 2. [Describe act(s) sought to be restrained. jumped out of the window of her 57thth story apartment in Chicago. and facts showing that the act(s) are without right or are wrongful].

the extensiveness of their communications on a daily basis. Angela became very secretive about her relationship with Doug although initially she was upfront with Paula about Doug. as in Paragraph 3]. On average. and Facebook. Angela “friended” Doug. Angela tried to commit suicide twice. is a withdrawn young woman with a strong fascination with death. Given the fact that Doug represents on his Facebook page that he is an internet “death muse” who encourages despondent individuals to commit suicide while he watches. they spend several hours a day communicating with each other. once when she was 13 and later when she was 15. identifying and describing the significance of each. email. ___________________[Continue with references to and support for exhibits attached to the declaration. Since that time Angela and Doug have communicated regularly by telephone. and her .3 COMPLAINT FOR TEMPORARY RESTRAINTING ORDER .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 suicides. According to her mother Paula. Three weeks ago. Angela has changed all the passwords to her computer and no longer allows Paula access to her Facebook page. particularly her own. About a week ago. and Exhibit A is a fair and accurate representation of the records. I personally observed the telephone records. a minor. Angela’s history with suicide. Angela. (identify matter depicted and describe its significance). on Facebook. 4. About one month ago. 5. Angela has stopped seeing her therapist.

] 8. (and a number of times since then.4 COMPLAINT FOR TEMPORARY RESTRAINTING ORDER . Doug’s acts can lead Angela to attempt to commit suicide again.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 recent covertness regarding her relationship with Doug. to refrain from their (threatened) conduct. DATED: November 13. [Describe the effect of the act(s) on plaintiff that establish the ground(s) for pendente lite injunctive relief]. Defendants have refused. irreparable injury will result to Angela and Paula as Angela will attempt to commit suicide with the aid of Doug that will be sustained and cannot be compensated for in money. 2011 . 6. while Doug watches via web cam. and still refuse.) ___________________ (I or plaintiff) demanded that defendants stop their wrongful (threatened) conduct described above. The above facts are within my personal knowledge and I am competent to testify to their truth if called as a witness. On ___________________ (date). Unless a temporary restraining order is granted. [7.

5 COMPLAINT FOR TEMPORARY RESTRAINTING ORDER .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 Your signature Jasleen Ahuja Shantey Mirzhakyan Katrina Novak .