Professional Documents
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Restraining Order Request Sam Lutfi 2020
Restraining Order Request Sam Lutfi 2020
b. Are there now any protective or restmining orders in effect relating to you or any of the persons in @ nnd the
person in? N0 D Yes (Ifyes, attach a copy ifyau have one.)
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Description of Harassment
F}: Harassment means violence or threats of violence against you, or a course of conduct that seriously alarmed,
E}; annoyed, or harassed you and caused you substantial emotional distress. A course of conduct is morc than onc act.
m a. Tell the court about the last time the person in harassed you.
(I) When did it happen? mrovide date or estimated dare): ongoing
(2) Who else was there?
nöitÄiaV-"Couh Order.“
“m” "m" “m” Request for Civil Harassment Restraining Orders °"-1°°- P399 2 0' 6
(Civil Harassment Prevention) ‘Ö
‘
(4) Did the person in use or threnten to use a gun or any other weapon?
D Yes E N0 (Ifyes, explain below):
Ü Check here ifthere is not enough spacefcnr your answer. Put yaur complete answer on the attached
sheet ofpaper orform MC-025 und write "Attachment 7a(4)=-Use of Weapons "for a title.
The person in ® will be ordered no! !o !ake any action !o ge! the addresses ar Iocations ofany protected persan
unless the caurlnds good cause n0! to make the Order.
(«D E] Stay-Away Orders
a. I ask the court to order the person in ® to stay a! least 100 yards away from (check all Ihn! apply):
(l) E Me. (8) E My vehicle‚
(2) E The other persons Iisted in _ (9) Other (speczfjr):
(3) E My home. Petitioner re uests that the sta -awa distance be reduced
(4) E M), Job m, workplace. to allow Resndent access to Resndem s resldence.
(5) E] My school.
(6) E My children's school.
(7) E My children's place of child care.
b. If‘ the court orders the person in @ to stay away om all the places listed above, will he or she still be able
to get (o his or her home, school‚ or job? Ü Yes Ü N0 (Ifn0. explain below):
Ü Check here ifthere Es no! enough spacearyour answer: Put your complete answer an the utlached slzee! of
paper orform MC-025 and write "Atlachmen! 9b—S!ay-Away Orders, "far a title.
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ä Guns or Other Firearms and Ammunitlon
Does the person in ® own or possess any guns or other renrms‘? E Yes E No E I don't know
Iflltejudge gratus a protective order, the person in ® will be prohibiled-orpx owning, possessing, purchasing,
receiving. or attempling t0 purchase or receive a gun, otherrearm, and ammunition while the proteclive order
is in eect. The person in ® will also be ordered !o mm in !a law enforcement. or sell Ia or slore witl: a
licensed gut: dealer. any guns orreanns within his or her immediate possession or contral.
“°""°" “m” ‘- 2°“ Request for Civil Harassment Restraining Orders CH-100. Page 4 or6
(Clvll Harassment Preventlon) ->
‘
Thiä is "hat a
I requcst sole possession of the animals because (specir good causejbr granting order):
Ü Check here zftlzere is not enough spaceforyour answer. Put your complele amwer on the altached
sheet ofpaper orform M0025 und write "Attachment [Sa-Possession afAnimaIs "for a tille.
b. E] That the person in @must stay at least yards away from, and not take, sell, transfer, encumber,
conceal, molest, attack, slrike, threaten, harm, or otherwise dispose of, the animals listed above.
D Check here ifzere is n0: enough spacefor your answer. Put your complete answer an the attached shee! of
paper arform MC-025 und write "Attachment I 6-14dditional Orders Requested, "for a title.
YURY GALPERIN
141W??? 'S "am? (Van?) a ' signature
I declare under penalty of perjury under the laws of the State of Califomia that the information above and on all
g; attznchments is true und con-ect.
fhas‘ isvhot;fäjii‘fe{c>yu
“M” ‘- 3°’ M l Q V Reuest fr Cil Hasmn esrining rde ll » kA r
(Civil Harassment Prevention)
1 LIEBER & GALPERIN, LLP
' 2 Yuxy Galperin, CSB #232305
1801 Cenmry Park Bast, 24th Floor
3 Los Angeles, CA 90067
Telephone: (424) 325-6388
4 Facsimile: (424) 389-7082
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35 2. The facts stated below are known by me to be true of my own personal knowledge
26 and if called upon to testify as to the truth ofthe matters set forth hereinaer, l could and would
l 2 4. I have served as president of the HOA board at our complex since 2013.
i 5. Since 2018, Respondent, angry about some decisions made by the HOA, began to
6
7 RECENT HARASSMENT
8 6. Within the last 2 weeks, Respondent impersonated me on the interner by creating a
9 fraudulent prole on an app called Whisper which is an anonymous social media app apparently
1o utilized to arrange meetings for casual sex. A true and correct Screenshot of the fraudulent prole
13 to and including the date of the instant ling) many explicit and disturbing text messages to my
14 personal phone at all hours of the night. This has caused me signicant emotional distress.
15
1° mm2 HARASSMENT
17 8. Since 2018, Respondent has undertaken a campaign of harassment
18 against me and my family, including my two small children, who are listed on my Request as
20 9. When respondent sees us in or around our building, he constantly yells and curses at
W us, usually making sexually suggestive comments about me, and accusing my husband of
24 l0. When he believes no one is watching, Respondent regularly vandalizes our property
25 by throwing trash at our front door. We are in possession of security footage showing
25 this behavior. True and correct copies of photographs of trash thrown at our door by Respondent
2e l1. Respondent has also been incessantly sending text messages to my husband, despite
2 Tme and correct copies of selected text messages sent by Respondent are attached hereto as
s l2. Respondent has also threatened our safety via text message by texting Statements such
6 as “an eye for an eye” - I understand this to be a physical threat. A true and correct copy of the
7 threatening text message sent by Respondent is attached hereto as Exhibit “D” and incorporated
8 by reference herein. lt is clear that Respondent blames me for some of the HOA's actions and
9 wants revenge. ‚
1o 13. I previously led a Request for Civil Harassment Restraining Order on er about
11 October l0, 2019 - case number I9STRO07 1 52. The TRO was denied in that matter because I
12 was unable to provide evidence that Respondent is responsible for the online harassment 1 have
13 experienced as described above. As part of that matter I was able, via subpoena, to obtain
14 infonnation regarding multiple IP addresses that had accessed and used the fake Whisper prole
15 used to harass me. I was able to trace those IP addresses to Los Angeles but was awaiting results
17 subpoenas were pending, - case number l9STRO07l52 was dismissed by the Court because I
18 did not serve Respondent. ‘Therefore, I was unable t0 obtain documents in connection with the
19 second set of subpoenas. Those subpoenas will be reissued immediately upon obtaining a case
2o number for the instant ling. I was, and remain‚ afraid to serve him until I am able to obtain a
ü TRO against him - I believe that based on his prior actions, Respondent will escalate his
g; 23 harassment of me and my family. I am afraid for my safety, as well as the safety of my young
2 4 children.
m 25 l4. Respondent has a history of harassment and has been a Respondent in other
25 Restraining Order matters. Respondent had a Restraining Order issued against him in favor of
27 Britney Spears as a result of behavior that is substantially similar to his actions as described
2a herein. l am informed and believe, and thereupon allege that other neighbors have
5 impersonated me on the internct. Respondent’s harassment has escalated over time, and has left
6 mc afraid for my safety as well as the safety of my family. I respectfully request the Court’s
9 ldeclare under penalty of perjury under the laws of Califomia that the foregoing is true
1o and correct, and that this declaration was executed on January l0, 20g
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