In 2008, the superior court issued a three-year restraining order against defendant/appellant. At the end of the three years, the plaintiff/respondent requested a renewal of the restraining order, and defendant/appellant opposed the request. In 2011, the court renewed the order, this time until 2016. The appellate court affirmed the order of the trial court, noting that under Ritchie v. Conrad (2004) 115 Cal.App.4th 1275, [10 Cal.Rptr.3d 387], facts supporting an initial order “often will be enough in themselves to provide the necessary proof” to renew the protective order. But the appellate court also noted that in this case, defendant/appellant had violated the initial order in 2011, four days prior to the request to renew, concluding the trial court acted within its discretion in renewing the restraining order. Lister v. Bowen (Cal.App. First Dist., Div. 2; April 11, 2013) (Case No. A134290).
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