Rowan

BACKGROUND

In early 2020, Rowan filed a request for civil harassment restraining order against Kirkpatrick. Rowan alleged Kirkpatrick posted threatening and defamatory comments about her on social media and engaged in other

Undesignated statutory references are to the Code of Civil Procedure.

1 threatening behavior. Kirkpatrick, acting in propria persona, filed a request for a restraining order against Rowan. Rowan filed a response. The court consolidated the restraining order requests. Kirkpatrick refused to stipulate to a commissioner hearing the matters and the parties agreed to continue the hearing to February 24, 2020. Kirkpatrick, however, failed to appear on that date. The trial court held an evidentiary hearing in her absence and granted Rowan’s request for a restraining order (§ 527.6). It dismissed Kirkpatrick’s restraining order request without prejudice due to her failure to appear. Two days after the hearing, Kirkpatrick filed a “Supplemental Evidentiary Submission” supporting her restraining order request. Rowan moved to strike the submission. Later, at Rowan’s request, the court declared Kirkpatrick a vexatious litigant (§ 391).2 Two months later, Kirkpatrick…