I. INTRODU AND RELIEF REQUESTED

This a arises out of a years-long intimate relationship between the parties， which hurts Respo deeply due to Petitioner’s lies and abusive treatment. For more than six years， Respo was misled by Petitioo believe that she was dating a single man and was building up a itted relationship. It turns out only retly that Petitioner had iionally hidden， and tinually lied about， the fact that he was a married man and had at least one child from his marriage. After his lies were exposed， Petitioner fessed to Respo and aowledged the severe harm he had doo Respo， he also promised Respohat he would provide solutions and listen to her demands for damages.

But things ged dramatically afterwards: Petitioner reported Respoo poliay 1， 2023， and then filed this petition on May 16， 2023 for a prote ainst Respo. Depig Respo as a“occasional acquaintangaged in a limited number of casual sexual enters”， see the Petition，§7， at 2， Petitioner accused Respo of making harassing tacts， exposing his personal information， and threating his and his family members’ safety. See Id.， at§§16- 17， at 9- 10.

The facts， however， are quite different. Among other details， the following critical facts were distorted or omitted iioner’s May 16， 2023 petition:

1. Petitioner had initiated， maintained， and dominated in a six-strong year-long datiionship with Respo， and had initiated tacts to Respo for sex and other

intimate activities;

2. Petitioner had tinually assured Respo about his care and love to her， and denied he was a married man， leading Respoo i her time， money， energy， aion into him and the relationship;

3. To satisfy his personal desire in dating Respo， Petitioner had violated work ethid probably employment policies as an Amazon employee;

4. Petitioner had fessed to Respo for his lies， and invited Respo her requests and demand;

5. When Respo attempted tact for his response， Petitioner iionally kept silent， and had never given clear notice of not wanting further tact;

6. Petitioner has been actively engaging social media and seeking public attention and has voluntarily disclosed enormous amount of personal information; and

7. Before filing his petitioioner knew clearly that Respo was not the cause of the alleged“leak” or“exposure” of his personal (including employment) information.

When it became clear that Petitioner had lied to her， manipulated her， and misled her into a years-long intoxicated relationship， Respo did the following:

1. She wrote doublish her love story， hiding parties’ names and personal information， for self-healing and farewell，

2. For the same purposes， she quietly and briefly visited a place that she believed to be associated with her pain in her relationship with Petitioner;

3. She fronted Petitioner and demanded for apologies and damages， and had only started to tact Petitioner for respoer Petitioner disappeared and remained silent to her demands;

4. When attacked and insulted online， she defended herself by rep Petitioo

third parties that she believed had the authority to duvestigation and reveal the truth.

5. Once learned about the nature of the temporary prote order， she made her best effort， including submitting herself to the police， to ply with the order.

Respo has not unlawfully harassed Petitioner， she has not invaded Petitioner’s privaor has she ever had“the io coerce， intimidate， or humiliate Petitioner.” See RCW 7.105.900(3). What she did are reasonable and justified reas towards Petitioner’s lies， his hypocrisy， and his threats and insults when things were exposed: to protect herself， to seek justice， and to reveal the truth.

Now， though Respo has determio pursue legal as against Petitioner she will undoubtedly avoid any future tact with Petitioner in her life forever. Respo’s has itted no unlawful harassment at Petitiohere is no need and no basis for a civil prote order to restrain her.

II. FACTS

Respo is currently an iional student attending school ile.

Respo met Petitioner Mr. Kang Dai iember 2016， when she was traveling ile was offered a to stay iioner’s apartment before she left the city. Id.?7 & Ex. 1. The two had sex before Respo left Seattle. Id.?8. This experiearted a datiionship betweewo for more than six years， with a few intervals of interruption. Id.?4.

Petitioner had domihis relationship. He was the one initiating tacts to Respoo show his care and love， sending invitations for holidays’ meeting together， and requesting sex and other initiate activities with Respo. Id.??9-14 & Ex. 2-3. No doubt， the joy aement in sex was etitioner was after: he took photos during sex with Respo without her knowledge or sent， Id.??12-13; he requested Respoo take medication to delay period (so he could have sex without any wait)， Id.?14; he insisted on having sex despite Respo was having period， Id.?21; and used violence during sex despite Respo’s reluce. Id.

But Petitioner also vowed， for many times， for his care and love to Respo beyond sex. Id.??9， 15-16，20， Ex. 6. Most importantly， he kept assuring Respohat he was a single man so the two， as long as tinuing the datiionship， would have the opportunity to be fully together ultimately. Id.?6 & Ex. 4. Petitioner wahe relationship with Respo; he also mao maintaiimate relationship with Respo by taking advantage of her love and trust in him. Id.??5， 16.

After Respo moved to Seattle for her school， Petitioner spent more time physically with Respo， treating her more and more like a life partner. Id.??17-20 & Ex. 5. Petitioook Respo in tours and for meals， showed her his workplad took her into his office， and visited Respo’s apartment for intimate activities. Id.

By March 2023， Respo was still expeg to build a long-term， serious relationship with Petitioner– including marriage. But her suspi oioner’s hoy and faithfulness started to groidly sie February， when she discovered evidence showing that Petitioner was a married man and already had a child from his marriage. Id.?22. When fronted， Petitioner dehat he was married and told Respohat he wao tinue his relationship with Respo. Id.?23. The suspi， however， intensified in late March 2023， wheioner even denied his ese o be the one Respo had long believed and used. Id.?25. The fusion， doubts， and insecurity caused serious emotional distress on Respo. Id.?23 & Ex. 8. In early April 2023， Respo could no longer bear it aermihat she must end this relationship. Id.?26.

To say farewell to this seven-year-loionship， Respo did three things.

First， she wrote down her love story and posted it on the social media website“Little Red Book”(in ese Xiao Hong Shu) on April 23， 2023. The story tained no name or any identifier information， Id.?27& Ex. 9， but it was re-posted on other ese websites without Respo’s knowledge. Id.?30 & Ex. 11. Sed， on May 1， 2023， she made another post on Little Red Book titled“Move on”， expressing her personal feelings of pain and shock， and her decision to end her relationship with Petitioner. Id.?49 & Ex. 20. Third， also on May 1， 2023， apanied by a church friend， Respo paid a visit to， and stayed about ten minutes in， the neighborhood where she assumed Petitioner was residing. She took two pictures of the neighborhood as she found the view was beautiful and posted them on her social media at. Id.?47-48; The photos were posted in Respo’s May 1， 2023“Move on” post， but the photo-taking location， shown in the post， was not the same location of the neighborhood. See the Petition，§Evidence， Appendix 5 (showing“Swedish Issaquah Ca…”);.??48-49. By paying the visit， Respo did not io stalk Petitioner or visit Petitioner’s residence. In fact， at the time， she did not even know for sure if Petitioner really lived in that neighborhood， and she actually thought Petitioner was still in a. See Respo Decl.??47-48;

On or about May 1， 2023， Petitioner reported to the police， acg Respo’s post and the disclosed information therein， including the posted neighborhood pictures， as a threat. The police report for this case showed that information was sidered to be“publiformation” and had no threat to Petitioner.?50 & Ex. 21.

After Respo posted her story on Little Red Book， Petitioner’s real name was identified by unknown i users. Id.?31 & Ex. 12. Respo ignored or rejected these i users’ suggestions that she should expose Petitioner online， but she could not stop Petitioner’s personal information from being disclosed and circulated online. Id.??28-29 & Ex. 10， 13. Petitioner himself made all of the disclosure possible and easy: he is a social media influencer and has shared with the public a lot of personal information， including photos of his family members a dog. Id.?33 & Ex. 14. It was from the disclosed information， circulated online or supplied by unknown i users， that Respo learned about Petitioner’s marital status， marital property， and employment information. Id.?? 31-32 & Ex. 12.

On April 24， 2023， starting from 2:43 a.m.， Petitioner called Respo 13 times via eaking for 219 minutes a Respo about 50 WeChat messages. In these unications， Petitioner repeatedly insulted， harassed， and threatened Respo. For instance， Petitioner yelled at Respo in his calls， threatening with his death， and his wife’s revenge. Id.??34-35. Petitioner also made death threats multiple times to Respo and also threateo release email correspondences taining intimate tent to the public. Id.??34-35， 40 & Ex. 17. Respo was exhausted and scared by Petitioner’s calls and threats. Id.?36.

Petitioner also khat Respo had nothing to do with the circulation of her love story and the exposure of his personal information. Id.?37 & Ex.15.

During the unication via etitioner also attempted to secure another personal meeting with Respo ile in May 2023. Respo expressly rejected it， and clearly informed Petitiohat she wao stay away from him due to Petitioner’s threats. Id.?38.

In the evening of April 24， 2023， Petitioner tacted Respo again o

to fess his lies about his marital status. Id.?39 & Ex. 16. Petitioold Respo

that she could bring up her any demands and he would tinuously listen to Respo’s plaints and demands. Id.?39 & Ex. 16.

During the late night of April 24， 2023， Respo made her demands to Petitioner

via WeChat， but she received no response from Petitioner. Id.?41 & Ex. 18.

At the same time， Respo started to find anonymous posts oag and insulting her with slanders and defamation. Respo replied some of the attag posts on the website 1point3acres. to defend herself. Id.?42-43 & Ex. 19.

On April 27， 2023， finding herself not receiving any response from Petitioner and trying to protect her creditability aation from the oack， Respo sent emails to individuals that she believed to be Petitioner’s supervisors at work to report Petitioner. Id.?44. Respo was hoping to prompt an iigation made by a ral third party that had authority over Petitioo reveal the truth and prove what she was plaining about. Id.?45. Amazon Inc. replied to Respo’s email a day later， and also invited Respoo attend a meeting with its iigator on May 2， 2023. Id.?46.

In order to seek Petitioner’s respoo her demands April 24， 2023， Respo started to send messages to Petitioner and call Petitioner via WeChat to repeat her demands for apologies， pensation， and resolutions. From May 10， 2023 through May 13， 2023， Respo sent a few messages o. None of the messages， however， was responded by Petitioner. Id.?51. In the following three or four days， Resporied different ways to tact Petitioo see if her messages were received by Petitioner and to prompt Petitioner’s response， including making telephone calls to Petitioners， sending emails， and sending messages o and Chime. Id.?52.

Respo’s last attempt to tact Petitioner was made through her social medium at at 2:59 p.m. of May 18， 2023. Id.?53.

Petitioner remained silent throughout the eime from May 10， 2023 through May 18， 2023. Before filing the Petition and even before Respo was actually served the full package of the temporary order， Petitioner had not provided any clear notice to Respohat he did not want further tact. Id.??54-56.

The full tent of the temporary order issued on May 16， 2023 was only served upon Respo ie afternoon of May 18， 2023. Id.??58-59. Before she was served， Respo made a post expressing her fusion， shock， and pain. Id.?60. After she fully

uood the meaning of the temporary order， she voluntarily submitted herself to the police to ensure full pliance. She had plied the order. Id.?61.

During the ewo months of April and May， Respo had ried to meet Petitioner in-person， nor had she stalked， or attempted to stalk， Petitioner or any of his family members. All of Respo’s attempt of tag Petitioner in the month of May 2023 were caused by Petitioner’s failure to fulfill his promise to listen to Respo’s plaint and his iional silence. Even though， Respo has never inteo coerce， intimidate， or humiliate Petitioner， her goals were simple: to protect herself， to seek justice， and to reveal the truth.

On May 23， 2023， Respo filed her petition for civil prote ainst

Petitioner. Id.?62.

Respo has suffered from severe emotional distress from this intoxicated

relationship with Petitioner， from Petitioner’s lies， insult， and threats， as well as

Petitioner’s abusive litigation. Id.?63 & Ex. 23.

III. AUTHORITY AND ARGUMENT

A. Legal Standard for Issuing Anti-Harassment Prote Order

“A petition [may be filed] for an antiharassment prote order， which must allege the existence of unlawful harassment itted against the petitioner or petitioners by the respo.” RCW 7.105.100(1)(f). For the purpose of antiharassment prote order，“unlawful harassment” means:“(a) A knowing and willful course of duct directed at a specific person that seriously alarms， annoys， harasses， or is detrimental to such person， and that serves imate or lawful purpose. The course of duct must be such as would cause a reasonable person to suffer substantial emotional distress， and must actually cause substantial emotional distress to the petitioner; or (b) A si of violence or threat of violence directed at a specific person that seriously alarms， annoys， harasses， or is detrimental to such person， and that serves imate or lawful purpose， which would cause a reasonable person to suffer substantial emotional distress， and must actually cause substantial emotional distress to the petitioner. A sihreat of violence must include:(i) A malicious and iional threat as described in RCW 9A.36.080(1)(c);1 or (ii) the presence of a firearm or other on.” RCW 7.105.100(36).“Course of duct”， then，“means a pattern of duposed of a series of acts over a period of time…evideng a tinuity of purpose.” RCW 7.105.101(6)(a)(emphasis added). However， stitutionally protected speech is carved out from the definition of“course of duct”. See RCW 7.105.100(6)(a). Further，“[i]ermining whether the course of duct serves aimate or lawful purpose， a court should sider whether:(i) Any current tact between the parties was initiated by the respo only or was initiated by both parties;(ii) The respo has been given clear notice that all further tact with the petitioner is unwanted;

(iii) The respo's course of duct appears desigo alarm， annoy， or harass the petitioner;(iv) The respo is ag pursuant to any statutory authority including， but not limited to， acts which are reasonably necessary to:(A) Protect property or liberty is;(B) Enforce the law; or (C) Meet specific statutory duties or requirements;(v) The respo'scourse of duct has the purpose or effect of unreasonably interfering with the petitioner's privacy or the purpose or effect of creating an intimidating， hostile， or offensive living enviro for the petitioner; or (vi) tact by the respo with the petitioner or the petitioner's family has been limited in any manner by any previous court order.” RCW 7.105.100(6)(b). Lastly， an antiharassment prote order shall be issued if the court“finds

by a preponderance of the evidehat the petitioner has been subjected to unlawful harassment by the respo. RCW 7.105.225(1)(f). 1 RCW 9A.36.080(1)(c) provides that“[a] person is guilty of a hate crime offense if he or she maliciously and iionally

its one of the following acts because of his or her perception of the victim's race， colion， ary， national in， gender， sexual orientation， gender expression or identity， or mental， physical， or sensory disability specific persroup of persons and places that person， or members of the specific group of persons， in reasonable fear of harm to person or property. The fear must be a fear that a reasonable person would have under all the circumstances. For purposes of this se， a “reasonable person“ is a reasonable person who is a member of the victim's race， colion， ary， national in， gender， or sexual orientation， or who has the same gender expression or identity， or the same mental， physical， or sensory disability as the victim. Words alone do not stitute a hate crime offense uhe text or circumstances surrounding the words indicate the words are a threat person does not have the ability to carry out the threat.”(emphasis added). Threatening words do not stitute a hate crime offense if it is apparent to the victim that the person does not have the ability to carry out the threat.”(emphasis added)

B. Online Posts， ducts， and Disclosure of Information Accused iition Were NOT Made， or Directed to Be Made， by Respo.

It is important to point out that many online posts and disclosure of information that are accused iition were not even made， or directed to be made， by Respo. See Respo Decl.?99. For instance， Petitioner provide no evideo prove that Respo had any involvement in the following posts or disclosure of information:

? Appendix 6 attached to the Petition (an online post made by an i user“1x409686m0817”).

? Appendix 7 attached to the Petition (including four sets of online posts made by i users including“Anna007_” and“momo”).2

? Petitioner’s evidence provided by Petitioner’s sel on May 31， 2023， attached here to as Exhibit A.

? Petitioner’s evidence provided by Petitioner’s sel on May 31， 2023， attached here to as Exhibit B.