If a DVPA order has expired, can the DVPA be obtained by P.J.L. in a personal injury case?

Here, the request for a DVPA order, and, we presume, an accompanying declaration and evidence, was not provided to this court by Peck. It is impossible for this court to determine what documents the trial court relied upon that were submitted by P.J.L., and whether P.J.L. presented sufficient evidence to support the trial court's order. We understand that Peck is representing himself, but "[p]ro. per. litigants are held to the same standards as attorneys." (Kobayashi v. Superior Court (2009) 175 Cal.App.4th 536, 543.) As such, even if the DVPA order had not expired prior to the resolution of this

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appeal, defendant failed to meet his burden of showing reversible error by an adequate record.⁴