You tell me how to pronounce it. It's Quiller, like Peter Quill from Guardians of the Galaxy. I don't know that reference, but I got the... I don't either. Okay. Well, a quill is like a pen, so Quiller. Quiller. Maybe one of my ancestors made pens. I'm not sure. Good afternoon. May it please the court. Cringeworthy and socially awkward is what happened in a course of conduct over several years where Mr. Krauss abused his position as superintendent to harass, stalk, and threaten three ladies for which I am representing, Sandra, Xenia, and Arueri. In an unprecedented four days of trial testimony, because usually restraining orders last for a few hours, four days, the court, by clear and convincing evidence, found that there was this course of conduct over time that warranted the imposition of a restraining order. There is ample evidence that there is going to be future harm based on the past conduct. In addition, there was a separation agreement that occurred in spring 2024, which was put in place to help separate Mr. Krauss from the three ladies. Pushing that aside, he said, Well, I'm going to run for office anyway, and came back. And so then fast forward to this restraining order. It was filed in October 2025 and granted on a temporary basis— sorry, that was 2024. In the face of that, then at the January 2025 board meeting, not in response to a legitimate question from a concerned member of the public, just voluntarily gets up, knowing full well that the three executive assistants were going to be present, because at the court hearing, the court made Mr. Krauss appear remotely because the women were going to be there, and then he started saying that the restraining order was false and he was being falsely accused, directly to the women who were present by Zoom. There is clear and convincing evidence of that past course of conduct and the future harm. There is the text messages, the stalking, going to the husband's house, going to one of the women's house at night and taking a picture through the window. What about Mr. Briggs's argument that at a certain point in time, I guess after the separation agreement, there was no further contact with these women, other than the one board meeting you're talking about, I guess? Yes and no. So yes in the sense that there was no direct contact, no in the sense that the purpose of the separation agreement was to separate these parties because he was harassing them. And so in spite of that, he ran for the board office, which would directly put him in contact with these ladies. During his campaign, outside of the jurisdiction for the seat for which he was running, was placing signs in front of their houses, and then after the restraining order was put in place in October 2024, took it upon himself to basically indirectly address the ladies in an open public forum at the January 2025 meeting. Moving on to the waiver issue, I think that the court's question for the supplemental briefing was right on point. First and foremost, these three ladies were not signatories to the agreement. 527.8. The employer has the right to bring a restraining order on behalf of the three ladies. So the three ladies are actually the real party in interest in this case right here. It's just that the district procured my services on their behalf, whereas the settlement separation agreement from the year prior was between Mr. Krauss and the district. And then with the court supplemental question, Civil Code Section 3513, and then also in our respondent's brief, 1668, makes it clear that you're not allowed to waive statutes for public policy. And I think we can all agree the legislative history is clear and uncontradicted that 527.8 was enacted to mirror 527.6, so that employers like Adelanto School District have an additional tool in their belt to prevent the serial stalking, harassment, cringeworthy course of conduct that we have seen in this case. And then finally, I would just like to ask the court to affirm the lower court's ruling in all respects. Before you sit down, though, could you address the overbreadth argument and the fact that the order prohibits Mr. Krauss from speaking even about the CHRO during board meetings for which he is an elected board member? Yes. He's elected— well, I think we can all agree that sexual harassment is never within the course and scope of employment, neither is sexual assault, okay? So this restraining order has to do with sexual harassment. He was not elected to be a board member to sexually harass anybody. So there is zero reason for him to talk about this restraining order during a board meeting. Now, given my colleague's hypothetical, yes, if there was a situation where a member of the public asked him about it, that's something different. But we haven't seen that. The evidence before us is one case where as soon as he got the opportunity, while he was already under a restraining order, right? And this goes to the likelihood of future conduct, because he didn't care about the restraining order. He knew about it. He knew that the ladies were on Zoom, and he just voluntarily started talking about how the women were falsely accusing him for no reason. So there was no legitimate purpose for that. The purpose of being a board member is to promote the educational interests of the children. And there was testimony, if I recall correctly, from the three women that those comments made them feel further harassed. Is that right? Oh, absolutely. I mean, again, he knew that they were there, and there was no question posed to him about any of this. He just automatically was like, I'm being falsely accused and vilified of sexual harassment. There was no purpose for that. So in terms of the breadth, he can talk about the case off the dais, outside of the board meeting. Theoretically, if a member of the public wants to ask him about it, not during open session, the restraining order doesn't mention that. What it does do is that the three EAs, or the three victims, are present at the meeting. So is Krauss. The restraining order itself—I mean, we're talking about prior restraint—the Judicial Council form WV-100, 109, and 110 has for you to check the box: direct or indirect communication with the restrained party. If I am voluntarily talking about these ladies during that meeting, that's an indirect communication with those ladies knowing that he was there, and that's appropriate. So, go ahead. So why isn't that sufficient in order to protect, as you referred to here, the three ladies? Well, it should have been, but we saw that it was not, because in October 2025— October 2024, there was a temporary restraining order, which says no indirect contact. And then four months later, under the thumb of that restraining order, he went ahead and indirect contact with them anyway by voluntarily discussing this stuff during the board meeting when he knew that the three ladies were going to be there. Can I ask a follow-up question on an unrelated topic? Unless you have— Go ahead. This issue about that the restraining order would be against public policy, you raised that in response for the first time, is that correct? And then supplemental briefing was requested? Not that I'm aware of. In my respondents brief, we cited 1668, which talks about not having anything in a contract that is against public policy. My question is, was this issue litigated below, or are we being asked to decide this for the first time on appeal? I don't believe that it was raised at the trial court level. I think that the issue of the separation agreement was discussed by the appellant in terms of waiving the rights. It was also mentioned by us, but we, I don't think either party talked about the public policy issue, and we didn't submit any briefs, and I don't think the trial court asked us about it either. So then the follow-up question is, litigated issue on appeal? Was it waived if it wasn't reached at the trial court level? I would say theoretically yes, but at the same time, in all fairness, the interpretation— there are statutory issues here. This is de novo, and I admit I'm not an appellate specialist. So on the one hand, it is probably waived. On the other hand, I think it goes directly to some of the issues that were raised in the court of appeal brief, and you guys did ask us for supplemental briefing. But I think that without getting to that jurisdictional issue, the substantive answer is so obvious that this separation agreement could not have possibly waived these ladies' rights to a restraining order for this cringeworthy course of conduct. Thank you. Justice Buchanan, anything further? Could you just comment real quickly on the duration of the order? It seems like the statute says it has to be only three years. Yeah, absolutely. That's a great question. I'm no mind reader, and the duration did not come up at the trial court level, and it's not addressed in the order. But here's what I can say. Workplace Violence Restraining Order Form 109 specifically says that the court has jurisdiction to award a restraining order for a period of five years, which seems to contradict 527.8, if you look at it in isolation, which is your question. 527.8 does have a duration of three years, right? And so how do you reconcile that with the actual Judicial Council form WV109 that says five years? And so to do that, and we put this in our respondents brief, you look at the statutory scheme as a whole, which starts with 527.6, right? 527.6 allows for the five years. 527.8 was enacted after the fact because of this rise in workplace violence, cringeworthy behavior, course of conduct. And then later, I believe it was 1998, 527.6 was actually amended to mirror 527.8. So there is nothing that precludes that trial judge from exercising his or her discretion to do the five years for 527.6. It's also worth noting that in the trial court, there are restraining orders heard in front of that judge under 527.6 and 527.8, because the statutes are interchangeable. And then finally, the practical reason for this is, keep in mind, Mr. Cross was elected for a four-year term. It would defeat the entire purpose if this was only for three years, because it would leave the ladies that last year subject to a continued course of conduct, which we know is not restrained by the restraining order, because in October 2024 there was a restraining order, which was willfully denied and disobeyed. But you acknowledge that 527.8 limits to three years? I do, absolutely. And so if the court— like I said, there is an inherent inconsistency with the actual Judicial Council form that says five years and 527.8, which says three years, and the form is based on 527.8, so there is an inconsistency. However, if the court were to modify the restraining order down to three years, that would be at your discretion, but what's most important to me and my clients is that the course of conduct and cringeworthy behavior stop for as long as possible. So the substance should stay in place, and if the court addresses that inconsistency between WV109, 527.8, and its mirror cousin of 527.6, that's up to your discretion. All right. Thank you, Mr. Quiller. Thank you. Mr. Greats, you have five minutes? Justice Toviji, I have five minutes? Yes. Thank you. So a couple things. Justice Castillo, yes, this is an issue that was raised for the first time on appeal, and we think it's inappropriate to address that issue. Did you— are you waiver in your respondents brief? I think we put it in the reply brief. I don't think it was addressed in the supplement. I'm not sure which place. I just, I don't recall as I stand here. The evidence of continuing harassment, there has to also be no legitimate purpose. I'm not here arguing that there is ever a legitimate purpose to harassment, but the harm that the women claim that they will experience is some sort of emotional harm because they have to hear and see my client at public meetings as part of an office to which he was elected. There is a legitimate purpose served by my client showing up and fulfilling his obligation to his constituents. To suggest that there's no legitimate purpose in an elected official going to the public meeting is a problem. I don't think that that's what I heard Mr. Quiller to be arguing. He's saying there's no legitimate purpose within the scope of his elected duties to be commenting on the WVRO proceedings. But there could be. I understand. It just, I don't think that Mr. Quiller argued what you just stated. To not be allowed to talk about a lawsuit is a gag order. That is a violation of the First Amendment. The women claim that they will suffer some sort of emotional distress, emotional harm from having to hear him talk about this lawsuit. Here is the testimony that was given at the trial. The women— sorry. I'm quoting from page 10 of the reply brief, which has a citation to the record. My client was, quote, basically telling the board that they needed to do away with our legal counsel because it's spending a lot of money. That is the evidence of the comment that was made at the public meeting. Wasn't there also a video that was played for the court of the whole meeting? There is a video that was played for the court. There's no transcript of what is on it. I don't know. I wasn't at the meeting, so I can't tell you exactly what was said. But it was consistent with what was described here. It was about money. Furthermore, the evidence in the record is that my client appeared by Zoom. He could only see the board members and the superintendent on the screen. He doesn't know who's at the meeting. And the evidence is that the women were in a separate room. They weren't even in the main room. So a lot of things are being cobbled together to make things look bad. But under the Scripps-Health case, there's got to be reasonable certainty of this harm continuing in the future, and it can't have a legitimate purpose. And the only harm is hearing my client talk about this case if it comes up. That's what the restraining order says he can't do. The— let's see, other comments. I think— I appreciate that my colleague acknowledged that the statute is limited to three years. He's been a pleasure to work with throughout this case. But I think that that actually shows what's really going on here. To suggest that there's discretion to make it longer and that my... Punishment. Because my client decided to run for office. The suggestion that he somehow waived the right to run for office by severing his employment—that's not an argument that's been made. That's today for the first time. But he can't be said under that agreement to have waived his right to run for elected office and to fully serve out his term and serve his constituents. But that's what this restraining order prevents him from doing. Thank you, your Honors. All right. Thank you, Mr. Briggs. Thank you, counsel. Matter is submitted. We're going to take a recess for a panel change.