Does a temporary restraining order need to be issued as a result of an offer of proof?

Appellant attaches great emphasis to the trial court's initial issuance of a temporary restraining order on the day she filed her petition. According to appellant, the court issued the temporary restraining order because the court found she had documented a credible threat of violence by respondent. The record does not support appellant. A temporary restraining order issues from what amounts to an offer of proof, not adjudicated findings. As the court in Thomas v. Quintero (2005) 126 Cal.App.4th 635 explained, "the procedure for obtaining a TRO [is not] akin to an adjudication of a disputed claim. So informal is the TRO proceeding that it does not even have to afford due process protections to the person against whom the TRO is directed. For example, no notice must be given to the person sought to be restrained before the TRO is issued.

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