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XXXX XXXX Ventura, CA 93001 (805) XXX-XXXX In Pro Per

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF VENTURA XXXX, ) Case No.: 56-2010-0XXXXXXXX-CU-HR-VTA ) ) ATTACHMENT 3d - REASONS TO RENEW ) ORDER - ADDENDUM ) ) Judge: Hon. Rocky Baio ) Dept.: 36 ) Date: August 28, 2013 ) Time: 8:30 am ) ) ) ) ) )

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Petitioner, vs.

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MARSHA WEBER, !
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Respondent.

The purpose of the Request to Renew Order hearing is to

discuss Leonard Weber and Marsha Webers multiple violations of the existing Restraining Orders and the continuing threat the Webers pose to the XXXX family. However, the Webers Responses

to the Requests do not address their recent Restraining Order violations, but rather focus on irrelevant issues that have, in some instances, already been litigated several times in this Court. For reasons of judicial economy, the XXXX familys

original Requests to Renew do not address disputes that occurred prior to issuance of the original Restraining Orders. However,

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the Webers Responses to said Requests contain blatant misstatements of fact that, although irrelevant to the issue at hand, we feel require illumination.

MARSHA AND LEONARD WEBER HAVE CONTINUED TO ANNOY AND HARASS THE XXXX FAMILY IN VIOLATION OF THEIR EXISTING RESTRAINING ORDERS

1.!

Marsha Weber most recently violated her Restraining On August 20, 2013, Mrs. Weber wrote

Order just three days ago.

and mailed a letter to XXXX to request a meeting. See Letter attached hereto as Exhibit A. Mrs. Weber is prohibited from

contacting XXXX, either directly, indirectly, or by mail, by the terms of her Restraining Order. By willfully engaging in such

conduct, Marsha Weber has violated California Penal Code Section 166 and is again in contempt of this Court.! ! 2.! Mr. Weber most recently violated his Restraining Order On or about July 17, 2013, Mr. Weber

less than one month ago.

followed XXXX in his car from Target, to a pet store, and then toward his new home. On July 20, 2013, Mr. Weber followed XXXX in his car from Von's, to the post office, and then followed him all the way to his new home which is located on a dead end street. Mr. Weber parked his car in front of the XXXX familys home for approximately 10 minutes waiting for XXXX to come out. XXXX walked outside and Mr. Weber put his fingers in the shape of a gun, pretended to shoot XXXX, and then sped off. See

Picture of Mr. Weber In Front of XXXX Family Home; Police Report #13-8216 attached hereto as Exhibit B. Mr. Weber brazenly

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admits to following XXXX around town and to his home in his Response to this Request. Mr. Weber is prohibited from

following, stalking, or harassing XXXX by the terms of his Restraining Order. By willfully engaging in such conduct,

Leonard Weber has violated California Penal Code Section 166 and is again in contempt of this Court. ! 3.! Mr. Weber violated his Restraining Order by On July 23, Mr.

approaching and harassing XXXX without provocation.

2012, XXXX was talking to neighbors on the XXXXs street.

Weber drove up, parked, got out of his car, and proceeded to walk toward XXXX while yelling obscenities at him. XXXX

retreated to his house without responding. See Video Frame Capture and Video dated 06/23/2012 attached hereto as Exhibit C. Mr. Weber is prohibited from harassing, yelling at, or coming within 10 yards of XXXX by the terms of his Restraining Order. By willfully engaging in such conduct, Leonard Weber has violated California Penal Code Section 166 and is again in contempt of this Court. ! 4.! Mr. Weber was arrested, cited and released by the

Ventura Police Department for assaulting XXXX and again violating his Restraining Order. On June 22, 2012, Mr. Weber

was driving on XXXXs street, saw him outside, flipped XXXX the bird while revving his engine, lost control of his car, and crashed into the XXXX familys retaining wall causing considerable damage. Mr. Weber went to his own house, returned

with a camera, and stood in the middle of the XXXXs property taking pictures of the damage. XXXX instructed Mr. Weber to

leave his property, stood between Mr. Weber and the damaged

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wall, and advised him to take pictures from the public sidewalk just a few feet away. Mr. Weber shoved XXXX out of the way and

continued to take pictures while standing in the XXXXs driveway. XXXX, a Draganchuk security guard for the Ventura

Keys community, witnessed Mr. Weber shove XXXX while standing in the XXXXs driveway. Mr. XXXX approached the scene and escorted The Police were summoned

Mr. Weber off of the XXXXs property.

and determined that Mr. Weber was in violation of the Restraining Order. Mr. Weber was arrested, cited and released

for said violations. See Arrest Report #12-7260 attached hereto as Exhibit D. Mr. Weber is prohibited from entering the

property located 1091 Dolphin Court and from harassing, making contact with, or coming within 10 yards of XXXX by the terms of his Restraining Order. By willfully engaging in such conduct,

Leonard Weber has violated California Penal Code Section 166 and is again in contempt of this Court. ! 5.! Mrs. Weber again violated her Restraining Order by

yelling obscenities at and harassing the XXXX family without provocation. On March 13. 2011, Mrs. Weber painted a sign on

her broom that read "LOATHESOME" and again began pounding on the XXXXs border fence, yelling obscenities and waving her sign above the fence toward the XXXX familys breakfast nook approximately 6 feet away. After approximately 10 minutes of

waving, pounding, and yelling obscenities, Mrs. Weber fastened her "LOATHESOME" sign to the border fence facing the XXXX family home and left it there. Mrs. Weber again began to yell

obscenities at the XXXXs while repeatedly opening and slamming her garage side door that is located approximately 6 feet from

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the XXXXs living room.

The police were summoned to calm Mrs.

Weber down and document her violation of the Restraining Order. Approximately 15 minutes later, while VPD Officer Alexander was at the XXXXs residence, Mrs. Weber again started yelling obscenities over the fence and repeatedly opened and slammed her garage side door, unaware that a Police Officer was present and observing her conduct. Thereafter, Officer Alexander

interviewed Mrs. Weber regarding her conduct, during which Ms. Weber admitted that she had in fact been violating the Restraining Order by waiving the sign at issue and yelling obscenities over the fence. Officer Alexander proceeded to

interview the neighbors as to what they witnessed, when Mrs. Weber again came out of her residence and began repeatedly yelling You fucking liar! at XXXX. XXXX did not respond to

Mrs. Webers attempts to provoke him. See Picture of Mrs. Webers sign and Police Report #11-2782 attached hereto as Exhibit E. Mrs. Weber is prohibited from contacting, either

directly or indirectly, and harassing (specifically defined in her Restraining Order as the restrained party shall not yell at the protected person) the XXXX family by the terms of her Restraining Order. By willfully engaging in such conduct,

Marsha Weber has violated California Penal Code Section 166 and is again in contempt of this Court. ! 6.! Mrs. Weber again violated her Restraining Order by

yelling obscenities at and harassing XXXX without provocation. On March 3, 2011, XXXX was on Seaview Ave. talking with a group of neighbors that included children. Mrs. Weber drove by,

swerved her car toward XXXX, rolled down her window, displayed

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the middle finger at XXXX and yelled, "Fuck you, you fucking bastard lawyer." See Police Report #11-2782 attached hereto as Exhibit E. Mrs. Weber is prohibited from contacting, either

directly or indirectly, and harassing (specifically defined in the Restraining Order as the restrained party shall not yell at the protected person) XXXX by the terms of her Restraining Order. By willfully engaging in such conduct, Marsha Weber has

violated California Penal Code Section 166 and is again in contempt of this Court.

MARSHA AND LEONARD WEBERS RESPONSES TO THE REQUESTS TO RENEW CONTAIN MISSTATEMENTS OF FACT

I. Misstatements of Fact Relevant To The Requests To Renew Orders

7.!

The Webers Response claims that they are friendly This is not true. The true facts are that XXXX and

with XXXX.

the XXXX children are very afraid of Leonard Weber and his wife. In fact, when questioned under oath regarding her fear of the Webers, Ms. XXXX stated, Im scared for my children. I have a

baby thats in daycare in Newbury Park because Im scared of them to be outside around them. See Transcript of Original

Restraining Order Hearing; Text Messages Between XXXX and XXXX dated August 22, 2013 attached hereto as Exhibit F. In fact,

XXXX would never let the XXXX children anywhere near Leonard Weber, a known pervert, who attempted to take pictures of the XXXXs oldest daughter in her underwear through the XXXXs

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living room window.

See Transcript of Original Restraining

Order Hearing attached hereto as Exhibit F; Image of Leonard Weber Peeping and Taking Pictures of XXXX Child attached hereto as Exhibit G. ! In addition, Ms. XXXX has been made aware of the Webers

current allegations, she disputes the Webers statements, and has again asked the Webers to leave her alone. After reading

the Webers Response to this Request, Ms. XXXX wrote, I am upset that my name is in this garbage that they wrote. See Text Messages dated August 22, 2013 between hereto as Exhibit F. ! 8.! With regard to the incident in which Mr. Weber crashed XXXX, again XXXX and XXXX attached

into the XXXXs retaining wall and assaulted

violating his Restraining Order, the Webers Response claims, Our insurance paid $500 to fix it after the incident. probably got someone to do it for $200. the issue at hand, this is another lie. Although irrelevant to The true facts are that

the XXXXs hired Rose Masonry & Concrete to fix the wall Mr. Weber drove through and paid $500 to have the work done. See Contractor Invoice attached hereto as Exhibit H.

II. Misstatements of Fact Relating To Issues Already Litigated

The Webers Responses fail to address the issues at hand

and instead seek to rehash disputes that have already been litigated, Restraining Orders issued, and Judgments entered. Although such attempts to distract this Court from the Webers

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continuing harassment of the XXXX family is irrelevant to these proceedings, we feel that such blatant misstatements of fact need to be addressed. ! 8.! The Webers Responses claim, once again, that Mrs.

Weber did not intentionally vandalize the XXXXs home on June 24, 2010. This dispute was litigated, a Judgement was entered

against Mrs. Weber, and it survived Mrs. Webers attempt to have the verdict overturned by accusing the Judge of impropriety. See Letters To and From Judge McGee attached hereto as Exhibit I. The true facts are that Mrs. Weber vandalized the XXXXs

home by intentionally training a garden hose into the XXXXs open bedroom window, affixing said hose to the XXXXs fence, turning the water on full, and walking away, thus causing substantial water damage to the XXXXs guest bedroom. Video of Mrs. Webers conduct was captured by the XXXXs home security cameras. See Video Stills of Marsha Weber Vandalizing the XXXXs Home attached hereto as Exhibit J. In addition, the Webers XXXX stole

Responses to this Request present a new claim that

the money for himself that Mrs. Weber was ordered to pay and that XXXX received nothing. not true. The Webers allegation is, again,

The true facts are that Mrs. Weber paid the Court,

the Court issued a check to XXXX, and that check was deposited into XXXX account. See Ventura County Case Report Summary attached hereto as Exhibit K. ! 9.! The Webers Responses also claim that, prior to

issuance of the original Restraining Orders at issue, XXXX snooped over our walls to see the arbor they built without a permit. This, again, is not true. The true facts are that the

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Webers also had a dispute with the neighbor living on the other side of their property, Mrs. XXXX. The Webers called Ventura

Code Enforcement when Mrs. XXXX attempted to repair the dilapidated fence dividing their properties. The arbor referred

to by the Webers was attached to Mrs. XXXX fence, it was not on the XXXXs side of the Webers property. During the Webers

dispute with Mrs. XXXX, Mr. Webers violent temper again erupted. Mrs. XXXX stated under oath, having become frightened

by Mr. Webers constant verbal threats, actions and threatening mannerisms, I asked my ex husband to stay at my home for protection while the fence was being replaced. This resulted in

Leonard Weber standing on his front lawn maniacally screaming threats at me. I truly feared that he was going to hurt me.

See Declaration of XXXX attached hereto as Exhibit L.

Conclusion

The Webers actions as described herein have been willful,

egregious, and in violation of the Restraining Orders imposed to prevent such conduct. On several occasions, this Court has

instructed the Webers to leave the XXXX family alone, the Ventura Police Department has instructed the Webers to leave the XXXX family alone, and even the Webers own attorneys have instructed them to leave the XXXX family alone. See Letter from Bamieh & Erickson attached hereto as Exhibit M. However, with

flagrant disregard for the law, the Webers violent and destructive harassment of the XXXX family persists without

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consequence.

Therefore, the XXXX family hereby implores this

Court to issue the requested Renewals, to force the Webers to cease their hostile activities, and to issue sanctions in an amount sufficient to deter future violations.

Dated: August 23, 2013!

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