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Jasleen Ahuja Shantey Mirzakhayan Katrina Novak 3050 Wilshire Blvd. Los Angeles, CA 90010 (213) 738-6700 Attorneys for Plaintiff, PAULA SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGGELES

PAULA, Plaintiff, vs. DOUG, Defendant

) Case No.: ) ) [PROPOSED] ORDER ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

I, PAULA, declare:

1. I am a private investigator hired by the plaintiff in this action and make this declaration in support of plaintiff's application for a temporary restraining order and order to show cause re preliminary injunction.

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2. Doug should be restrained from communicating with Angela including but not limited by telephone, email, Facebook, and in person. Angela is a friend of Doug who is encouraging Angela to commit suicide while Doug watches via web cam. Doug represents on his Facebook page that he is an internet death muse who encourages despondent individuals to commit suicide while Doug watches via web cam. Doug has told me on several past occasions that he has watched two people commit suicide. One person, Sue, jumped out of the window of her 57thth story apartment in Chicago; another person Ralph, in Iowa, shot himself in the head. I viewed both filmed suicides on Dougs website on October 29th. Doug told me that he encouraged both individuals to 1) end their miserable lives and; 2) film the event for posterity so that their lives would have some meaning. This statement is also on Dougs Facebook page and Dougs website. [Describe act(s) sought to be restrained, the persons committing or performing the act(s) and the relationship of these persons to defendant, and facts showing that the act(s) are without right or are wrongful].

3. Exhibit A attached to and made a part of this application is Dougs telephone statements, showing over 50 calls within one week period prior to each suicide victims death. Each telephone number belonged to one of the victims, Sue and Ralph illustrating Dougs continuous communication immediately preceding the victims
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suicides. (identify matter depicted and describe its significance). I personally observed the telephone records, and Exhibit A is a fair and accurate representation of the records.

4. ___________________[Continue with references to and support for exhibits attached to the declaration, identifying and describing the significance of each, as in Paragraph 3].

5. Angela, a minor, is a withdrawn young woman with a strong fascination with death, particularly her own. According to her mother Paula, Angela tried to commit suicide twice, once when she was 13 and later when she was 15. Three weeks ago, Angela has stopped seeing her therapist. About one month ago, Angela friended Doug, on Facebook. Since that time Angela and Doug have communicated regularly by telephone, email, and Facebook. On average, they spend several hours a day communicating with each other. About a week ago, Angela became very secretive about her relationship with Doug although initially she was upfront with Paula about Doug. Angela has changed all the passwords to her computer and no longer allows Paula access to her Facebook page. Given the fact that Doug represents on his Facebook page that he is an internet death muse who encourages despondent individuals to commit suicide while he watches, Angelas history with suicide, the extensiveness of their communications on a daily basis, and her
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recent covertness regarding her relationship with Doug, Dougs acts can lead Angela to attempt to commit suicide again, while Doug watches via web cam. [Describe the effect of the act(s) on plaintiff that establish the ground(s) for pendente lite injunctive relief].

6. Unless a temporary restraining order is granted, irreparable injury will result to Angela and Paula as Angela will attempt to commit suicide with the aid of Doug that will be sustained and cannot be compensated for in money.

[7. On ___________________ (date), (and a number of times since then,) ___________________ (I or plaintiff) demanded that defendants stop their wrongful (threatened) conduct described above. Defendants have refused, and still refuse, to refrain from their (threatened) conduct.]

8. The above facts are within my personal knowledge and I am competent to testify to their truth if called as a witness.

DATED: November 13, 2011

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Your signature Jasleen Ahuja Shantey Mirzhakyan Katrina Novak

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