Frutiger

I.

FACTUAL AND PROCEDURAL BACKGROUND

This appeal arises in the context of a fraught relationship between (now- ex) spouses that, over time, has spawned multiple orders against Paul

for the protection of Paola and (most recently) the child.1 Included among such orders is the one that is the subject of this appeal: the DVRO. A. The Application for a DVRO and the Evidentiary Hearing In August 2022, Paola completed and filed a form DV-100 request for DVRO. In response to item 5 on the DV-100 (and item 3 on the accompanying form DV-101), inquiring about the “most recent abuse,” Paola described a pair of encounters in a courthouse the previous day in which Paul had behaved toward her in a manner that, in her telling, was aggressive. Where the forms inquired into other incidents of abuse directed at oneself or one’s child, she described an occasion in 2018 in which “Paul tried to strangle me” and noted a report she had made to Child Protective Services based on an incident that the child had reported to her earlier the same week. (We shall refer to these three matters, each of which we discuss post, as: the courthouse incident, the alleged strangling incident, and the alleged child…