California, United States of America
The following excerpt is from Cindy M. v. Johnson, A156075 (Cal. App. 2020):
The DVPA "permits the trial court to issue a protective order 'to restrain any person for the purpose' of preventing a recurrence of domestic violence and ensuring a period of separation of the persons involved; the petitioner must present 'reasonable proof of a past act or acts of abuse.' " (Rodriguez v. Menjivar (2015) 243 Cal.App.4th 816, 820.)
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