D.M.R. VS. M.K.G. (FV-01-1206-20, ATLANTIC COUNTY AND STATEWIDE) (RECORD IMPOUNDED) (A-4085-19)
Defendant appealed from a final restraining order (FRO) entered against her pursuant to the Prevention of Domestic Violence Act, N.J.S.A. 2C:25-17 to -35, based on a predicate act of harassment, N.J.S.A. 2C:33-4(a). This court reversed because the trial court did not conduct the required legal analysis necessary to enter the FRO under Silver v. Silver, 387 N.J. Super. 112 (App. Div. 2006) and the record did not demonstrate plaintiff needed future protection. Further, our review of the record also disclosed defendant was deprived of due process due to numerous trial irregularities in the remote proceeding, including that defendant had insufficient notice and opportunity to prepare a defense in her case, plaintiff's witness was not sequestered, plaintiff testified in the witness's presence with witness coaching plaintiff, and the trial court engaged in inappropriate questioning of defendant.
