Based on Mrs. Joaquin’s affidavit, she requested an emergency hearing to address the safety and welfare of the children. In the restraining order, Mrs. Joaquin requested that the court immediately:
- Issue an order allowing the children to remain in the sole possession of their mother until a hearing can be held on the matter.
- Issue an order excluding Mr. Altenberg from possession of or access to the children until a hearing can be held.
Furthermore, Mrs. Altenberg requested the court to dispense with the necessity of a bond, and also requested that Mr. Altenberg be temporarily restrained immediately, without hearing, and after notice and hearing be temporarily enjoined, pending further order of the court from:
- Intentionally communicating with Mrs. Altenberg in person or in any other manner, including by telephone or another electronic voice transmission, video chat, in writing, or electronic messaging, by use of vulgar, profane, obscene, or indecent language or in a course or offensive manner, with intent to annoy or alarm Mrs. Altenberg.
- Threatening Mrs. Altenberg in person or in any other manner, including by telephone or another electronic voice transmission, video chat, in writing, or electronic messing, to take unlawful action against any person, intending by this action to annoy or alarm Mrs. Altenberg.
- Placing a telephone call anonymously, at any unreasonable hour, in an offensive and repetitious manner, or without a legitimate purpose of communication with the intent to annoy or alarm Mrs. Altenberg.
- Intentionally, knowingly, or recklessly causing bodily injury to Mrs. Altenberg or to a child of either party.
- Threatening Mrs. Alterberg or a child of either party with imminent bodily injury.
*Many more requests were made, but they are far too extensive to list for the purposes of this article.
