Kehlani K. v. Tripp T (AC-25-P-960, October 22, 2026)

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25-P-960

Appeals Court

KEHLANI K. vs. TRIPP T.1

No. 25-P-960.

Norfolk. May 5, 2026. – October 22, 2026.

Present: Massing, Ditkoff, & Hand, JJ.

Abuse Prevention. Protective Order. Statute, Construction. Due Process of Law, Abuse prevention.

Complaint for protection from abuse filed in the Dedham Division of the District Court Department on October 23, 2024.

The case was heard by Paul J. McCallum, J.

Syrie D. Fried for the defendant. Joana L. Stathi (Andraya Ferraro also present) for the plaintiff.

HAND, J. "Chapter 209A, the Abuse Prevention Act, was enacted to provide 'a statutory mechanism by which victims of family or household abuse can enlist the aid of the State to prevent further abuse.'" Commonwealth v. Carino, 496 Mass. 783,

1 The parties' names are pseudonyms. 786 (2025), quoting MacDonald v. Caruso, 467 Mass. 382, 385 (2014). In June 2024, the Legislature expanded the definition of "[a]buse" included in G. L. c. 209A, § 1, to add "coercive control." See St. 2024, c. 118, § 4 (effective Sept. 18, 2024). This case presents the question whether the evidence before a District Court judge at a c. 209A hearing after notice was adequate to prove that the plaintiff suffered from abuse under the new definition. We conclude that it was. For that reason and because the defendant has failed to persuade us that the judge denied him a meaningful opportunity to be heard, we affirm the judge's order extending the ex parte abuse prevention order.

1. Procedural background. In October 2024, the plaintiff filed a complaint against her husband, the defendant, in the District Court, seeking protection from abuse. See G. L. c. 209A, § 3. A judge issued an ex parte abuse prevention order2 and scheduled a hearing with notice to be provided to the defendant. See G. L. c. 209A, §§ 3, 4.

On the day of the hearing after notice, the plaintiff represented herself and the defendant was represented by counsel. Both parties testified, and at the conclusion of the hearing the judge ruled that the plaintiff had "met her burden

2 The ex parte order required that the defendant not abuse the plaintiff. It also required that he not contact the plaintiff and that he stay away from her and her home. of proof" and extended the abuse prevention order for one year. This appeal followed.

2. Facts. We summarize the facts as the judge could have found them, reserving certain details for later discussion.3 See G.B. v. C.A., 94 Mass. App. Ct. 389, 389 (2018). At the time of the hearing after notice in October 2024, the plaintiff and the defendant had been married for seventeen years; in recent years, however, they had been embroiled in divorce proceedings initiated by the plaintiff. The plaintiff was "emotionally done" but the defendant was "not letting go" of the marriage. The defendant had told the parties' children that, unlike him, the plaintiff wanted a divorce and did not "want a family"; had told the plaintiff that he was "never, ever leaving"; and — two days before the initial hearing after notice — had "begged [the plaintiff] to call off the divorce."4

A judge of the Probate and Family Court (probate judge) had, in March 2024, granted the plaintiff sole and exclusive use

3 The judge did not make detailed factual findings, but it is apparent from the transcript that he credited the plaintiff's evidence and, where the defendant's testimony differed from the plaintiff's account, did not credit the defendant. Cf. Iamele v. Asselin, 444 Mass. 734, 741 (2005) (appellate court unable to discern whether and how judge credited plaintiff's testimony).

4 This last communication took place after the defendant had been served with the ex parte abuse prevention order, which included a no-contact provision. and occupancy of the marital home (plaintiff's home). Although the defendant had moved out of the plaintiff's home and eventually into an apartment, he continued to appear at the plaintiff's home without the plaintiff's permission and against her wishes. He came into her driveway "on a near daily basis," sometimes blocking her car in, and the plaintiff's doorbell camera captured images of the defendant "circling" around the house on foot. In addition, the defendant repeatedly entered the house when the plaintiff was not present, even after the plaintiff had changed the locks. He admitted to the plaintiff that, on one occasion, he came into the house through an unlocked window. Another time, the defendant entered the house without the plaintiff's permission and took photographs of a calendar that provided details of the plaintiff's whereabouts "at all times." The plaintiff was not present, but one of the children was in the house and photographed the defendant as he viewed the plaintiff's calendar. That photograph was admitted in evidence.

In addition to making unauthorized appearances in and around the plaintiff's home, the defendant sought the plaintiff out in other locations. For example, in late September 2024, the defendant saw the plaintiff at a soccer game and "continued to harass" her about plans the plaintiff had made for herself and the children; the plaintiff was so distressed by the interaction that she left the game. On another occasion, shortly after the plaintiff had obtained the ex parte order, she arrived at one of the children's schools to pick up the child and found the defendant waiting there.5 The defendant made so many unexpected appearances that the plaintiff became afraid that he was "tracking" her. When the plaintiff took the children to New York, she arrived at a movie theater to find the defendant waiting outside on a bench. Other examples included the plaintiff's finding the defendant in the backyard of her vacation rental and in a hotel she was staying in "that he wasn't supposed to gain access to." The plaintiff testified that these unexplained appearances occurred "for months and months," and, in substance, that the defendant's ongoing course of conduct made her concerned for her safety and left her acutely vigilant.6

5 Although the defendant had by that time been served with the ex parte order, which directed him to stay at least 100 yards away from the plaintiff, the defendant did not immediately leave the classroom area after the plaintiff arrived there. When he did leave the room, he remained in his car in the school's parking lot. The plaintiff introduced photographs of the defendant inside the school and outside in the parking lot.

6 At the hearing, the plaintiff explained to the judge, "I'm here for my safety and for my space and my peace of mind and my health and my stress. So when the [doorbell camera] chime goes off, I don't jump or I don't run to the window to see if it's his car, and nine times out of ten, it is." 3. Adequacy of evidence of abuse. a. Standard of review. We review the issuance of an abuse prevention order under G. L. c. 209A for an abuse of discretion or other error of law. See Noelle N. v. Frasier F., 97 Mass. App. Ct. 660, 664 (2020). See also Constance C. v. Raymond R., 101 Mass. App. Ct. 390, 394 (2022) (defining abuse of discretion). In conducting our review, we "scrutinize without deference the propriety of the legal criteria employed by the trial judge and the manner in which those criteria were applied to the facts." Iamele v. Asselin, 444 Mass. 734, 741 (2005), quoting C.O. v. M.M., 442 Mass. 648, 655 (2004).

b. Statutory language and purpose. "A plaintiff who seeks a restraining order under G. L. c. 209A, whether the initial, ex parte order, or its extension, carries the burden of proving by a preponderance of the evidence that she is suffering from abuse." Noelle N., 97 Mass. App. Ct. at 664. The 2024 amendments to the definition of abuse in G. L. c. 209A, § 1, modified the introductory language7 and, pertinently, added "coercive control" as subsection (d). See G. L. c. 209A, § 1,

7 The introductory language for the definition of abuse was modified by replacing the phrase "one or more of the following acts" (emphasis added), G. L. c. 209A, § 1, as amended through St. 1996, c. 450, § 232, with "any of the following acts" (emphasis added). G. L. c. 209A, § 1, as amended by St. 2024, c. 118, § 4. as amended by St. 2024, c. 118, § 4. General Laws c. 209A, § 1, now defines abuse as follows: "the occurrence of any of the following acts between family or household members:

"(a) attempting to cause or causing physical harm;

"(b) placing another in fear of imminent serious physical harm;

"(c) causing another to engage involuntarily in sexual relations by force, threat or duress;

"(d) coercive control."

As relevant here, the 2024 amendment also added the following definition of "coercive control": "(a) a pattern of behavior intended to threaten, intimidate, harass, isolate, control, coerce or compel compliance of a family or household member that causes that family or household member to reasonably fear physical harm or have a reduced sense of physical safety or autonomy, including, but not limited to:

"(i) isolating the family or household member from friends, relatives or other sources of support;

"(ii) depriving the family or household member of basic needs;

"(iii) controlling, regulating or monitoring the family or household member's activities, communications, movements, finances, economic resources or access to services, including through technological means;

"(iv) compelling a family or household member to abstain from or engage in a specific behavior or activity, including engaging in criminal activity;

"(v) threatening to harm a child or relative of the family or household member; "(vi) threatening to commit cruelty or abuse to an animal connected to the family or household member;

"(vii) intentionally damaging property belonging to the family or household member;

"(viii) threatening to publish sensitive personal information relating to the family or household member, including sexually explicit images; or

"(ix) using repeated court actions found by a court not to be warranted by existing law or good faith argument; . . . ."

G. L. c. 209A, § 1 (subsection [a] of definition of "coercive control). In this case, we interpret and apply this statutory language for the first time.

c. Application to this case. The judge found that the plaintiff met her burden of proving that she was suffering from abuse in the form of the defendant's coercive control. Although the judge did not provide any detailed findings explaining his reasoning,8 we can discern from his ruling and comments during the hearing a reasonable basis for his decision. Thus, the lack of detail does not limit our ability to conduct our review. See G.B., 94 Mass. App. Ct. at 396-397. As set forth below, we conclude that the evidence before the judge supported a finding of coercive control based on (i) "a pattern of behavior" by the

8 The plaintiff has consistently limited her allegations of abuse to abuse by coercive control. She did not argue at the hearing after notice that she was suffering from any other form of abuse and does not do so on appeal. See G. L. c. 209A, § 1 (definition of "[a]buse"). defendant, where (ii) the nature of the behavior consisted of "regulating or monitoring [the plaintiff's] activities, communications, [and] movements," and was "intended to . . . coerce or compel [the plaintiff's] compliance,"9 and (iii) the behavior caused the plaintiff to "have a reduced sense of physical safety or autonomy."10 G. L. c. 209A, § 1 (subsection [a] [iii] of definition of "coercive control").

i. Pattern of behavior. Because "pattern" is not defined in G. L. c. 209A, we rely on the plain meaning of the word, see Commonwealth v. Meta Platforms, Inc., 497 Mass. 384, 397 (2026), and interpret it to mean "[a] mode of behavior or series of acts that are recognizably consistent." Black's Law Dictionary 1359 (12th ed. 2024).11 The plaintiff's testimony, which we infer

9 The plaintiff meets the statutory definition of a "family or household member[]." G. L. c. 209A, § 1 ("Family or household members" include "persons who . . . are or were married to one another"). The defendant does not argue otherwise.

10 Because we discern a reasonable basis for the abuse prevention order under this definition of coercive control, we need not consider the defendant's challenges to the plaintiff's showing of coercive control under any of the other examples provided in the statutory definition, specifically, control of "finances" or "economic resources." G. L. c. 209A, § 1 (subsection [a] [iii] of definition of "coercive control").

11 "[P]attern" also appears in G. L. c. 209A, § 3 (d) ("evidence that a pattern or serious incident of abuse, as defined in section 31A of chapter 208, toward a parent or child has occurred" bears on standard under which judge can award plaintiff temporary custody of minor child [emphasis added]). See Hovagimian v. Concert Blue Hill, LLC, 488 Mass. 237, 246 that the judge credited, about the defendant's repeated intrusions into her home and activities amply supports a finding of a "pattern" of behavior here.12

ii. Nature of behavior. We next consider the nature of the behavior that comprised the pattern and whether the defendant intended that behavior to "coerce or compel" the plaintiff's compliance. G. L. c. 209A, § 1 (subsection [a] of definition of "coercive control"). We infer that the judge credited the plaintiff's descriptions of the defendant's repeated efforts to track her whereabouts and activities, including the defendant's maintaining a presence in and around the plaintiff's home at "all hours of the day" and, on at least one occasion, taking photographs of her daily calendar. This

(2021), quoting Beeler v. Downey, 387 Mass. 609, 617 (1982) ("where words are used in one part of a statute in a definite sense, they should be given the same meaning in another part of the statute"). Chapter 208 also does not define "pattern"; however, cases concerning G. L. c. 208, § 31A, appear to apply the plain meaning of the word. See, e.g., K.A. v. T.R., 86 Mass. App. Ct. 554, 557, 560-561 (2014).

12 The defendant does not specifically challenge the adequacy of the plaintiff's showing of a "pattern" and has not briefed that issue. We therefore leave for another day the question whether, in the absence of some more specific requirement from the Legislature, proof of a "pattern" requires the plaintiff to prove some minimum number of acts. See, e.g., Commonwealth v. Welch, 444 Mass. 80, 89 (2005) (in context of criminal harassment statute, G. L. c. 265, § 43A, "pattern of conduct or series of acts" requires proof of "three or more incidents of harassment"). Cf. G. L. c. 258E, § 1 (defining "[h]arassment" as "3 or more acts" of qualifying conduct). evidence was adequate to establish that the defendant was "monitoring [the plaintiff's] activities" and "movements."13 G. L. c. 209A, § 1 (subsection [a] [iii] of definition of "coercive control").

The evidence also supported an inference that the defendant specifically intended his pattern of behavior — his monitoring of the plaintiff's activities and movements — to "coerce or compel compliance" with his insistence that she discontinue the pending divorce proceedings. G. L. c. 209A, § 1 (subsection [a] of definition of "coercive control"). See G.B., 94 Mass. App. Ct. at 396 (whether defendant's actions constituted abuse is "based on the totality of the circumstances"). From the evidence at the hearing, the judge could have concluded, as we infer that he did, that the defendant used information about the plaintiff's plans and locations — which he obtained by

13 At the hearing, the defendant denied that he went to the plaintiff's home for reasons other than seeing the children; testified that he went into the house when no one was there only twice, to pick up belongings he had left behind when he moved out; and confirmed that he "d[id] not make a habit of" breaking into the house. He provided alternative explanations for at least some of this conduct, including that he appeared at plaintiff's home and at the tutoring session because his child or children had asked him to do so and that he was checking the plaintiff's calendar (while present in the house without the plaintiff's permission) because it included information about the children's schedule of activities. The judge was not required to credit the defendant's explanations, and we infer that he did not do so. monitoring the plaintiff — to create opportunities to insert himself into the plaintiff's family life and press his demands that the plaintiff "drop the probate case," "call off the divorce," and work out the marriage with him.14 The fact that there was no direct evidence of the defendant's intent is of no moment; the judge could reasonably have inferred that intent from the defendant's conduct. See J.C. v. J.H., 92 Mass. App. Ct. 224, 228 (2017) (defendant's subjective intent to cause plaintiff fear and intimidation was reasonably inferred from his angry texts and repeated harassment of her).

iii. Plaintiff's reduced sense of physical safety or autonomy.15 The evidence was adequate to show that the

14 The defendant's reliance on and argument about the holding in Counterman v. Colorado, 600 U.S. 66 (2023), is misplaced. Our analysis focuses on the defendant's conduct and does not rely on the defendant's having made threatening communications to the plaintiff. See id. at 69. How the analysis would differ for an abuse prevention order sought based solely on a defendant's speech must await another case.

We are aware that in a pending case the Supreme Judicial Court has solicited amicus briefs regarding, inter alia, "[w]hether the 'coercive control' provision is vague and overbroad in violation of the First and Fifth Amendments to the United States Constitution and cognate provisions of the Massachusetts Constitution." See G.P. vs. S.P., Supreme Judicial Ct., No. SJC-13947 (May 19, 2026). The defendant does not challenge the constitutionality of the statute on its face or as applied in the circumstances of this case.

15 Subsection (a) of the definition of "coercive control" requires proof that the defendant's pattern of behavior caused the plaintiff "to reasonably fear physical harm or have a reduced sense of physical safety or autonomy" (emphasis added). defendant's pattern of coercive behavior caused the plaintiff to have "a reduced sense of physical safety or autonomy" (emphasis added). G. L. c. 209A, § 1 (subsection [a] of definition of "coercive control"). In reaching our conclusion, we consider the effect on the plaintiff of the "entire course" of abuse, analogizing to precedent interpreting the harassment prevention statute, G. L. c. 258E. O'Brien v. Borowski, 461 Mass. 415, 426 n.8 (2012) (interpreting intent and result requirements of G. L. c. 258E).

As to the plaintiff's "reduced sense of physical safety," G. L. c. 209A, § 1 (subsection [a] of definition of "coercive control"), there was evidence at the hearing that the defendant had broken into the plaintiff's house through a window, circled her home on foot, blocked her car into the driveway, and appeared to "track" her movements and that the plaintiff feared the defendant, at least in part, for those reasons.16 That was

G. L. c. 209A, § 1. Because, as we will explain, we conclude that the evidence was adequate to prove that the plaintiff reasonably experienced "a reduced sense of physical safety or autonomy," we need not and do not reach the question whether the evidence also supported a finding that the defendant's pattern of coercive conduct caused the plaintiff "to reasonably fear physical harm." Id.

16 The fact that, at a different point in the hearing, the plaintiff testified that she also experienced "fear and intimidation" based on the defendant's attempts "to threaten that he will lose his job, will lose the home, will lose our health insurance" if she did not "drop" the abuse prevention order does not change our view. The plaintiff's testimony is enough to satisfy the first of the two disjunctive alternatives in subsection (a) of the definition of "coercive control" in G. L. c. 209A, § 1.

Alternatively, there was adequate evidence at the hearing to support a finding that the defendant's pattern of behavior caused the plaintiff to have a "reduced sense of . . . autonomy." G. L. c. 209A, § 1 (subsection [a] of definition of "coercive control").17 The plain meaning of "autonomy" includes

reasonably interpreted as including two different kinds of fear: fear for her physical safety and fear for her financial stability.

17 To the extent that the word "physical" (as appearing in the phrase "have a reduced sense of physical safety or autonomy" [emphasis added]) could be read as modifying both "safety" and "autonomy," G. L. c. 209A, § 1 (section [a] [iii] of definition of "coercive control") — a construction that we do not suggest was intended by the Legislature — the defendant did not argue in the trial court or in his brief that we should interpret the phrase to require the plaintiff to show a reduced sense of physical autonomy. We assume without deciding that the reduced sense of autonomy contemplated by the definition need not be physical. Our assumption is supportable, given both the protective purpose of c. 209A, see MacDonald, 467 Mass. at 385- 386, and the nonexclusive list of examples of qualifying behavior included in the statutory definition of "coercive control," which includes conduct that would not necessarily affect a family or household member's physical autonomy, but would readily affect such a person's autonomy in a more general sense, including for example, "controlling" the person's "access to services," threatening to harm the person's child or pet, damaging the person's property, "threatening to publish sensitive personal information relating to" the person, or "using repeated court actions found . . . not to be warranted by existing law or good faith argument." G. L. c. 209A, § 1 (subsections [a] [iii] and [a] [v]-[ix] of definition of "coercive control"). "[a]n individual's capacity for self-determination," Black's Law Dictionary 165 (12th ed. 2024), and an individual's "independence." See American Heritage Dictionary of the English Language 122 (5th ed. 2018). In the context of assessing the evidence of coercive control under G. L. c. 209A, § 1, we interpret "autonomy" to mean an individual's ability to make significant decisions unfettered by concerns that doing so will expose that person to abuse.18 The plaintiff's testimony, which we infer that the judge credited, supported a finding that the

18 Our interpretation is consistent with the definitions of "coercive control" included in several other States' abuse protection statutes. See Cal. Fam. Code § 6320 (authorizing issuance of protective orders prohibiting "coercive control, which is a pattern of behavior that in purpose or effect unreasonably interferes with a person's free will and personal liberty" and includes "[c]ontrolling, regulating, or monitoring the other party's movements, communications, daily behavior, finances, economic resources, or access to services"); Conn. Gen. Stat. § 46b-1(b) (defining "domestic violence" to include "coercive control," "which is a pattern of behavior that in purpose or effect unreasonably interferes with a person's free will and personal liberty"); Haw. Rev. Stat. § 586-1 (defining "[c]oercive control," for purposes of statute authorizing issuance of abuse prevention orders, to include "a pattern of behavior that seeks to take away the individual's liberty or freedom and strip away the individual's sense of self, including bodily integrity and human rights," where it is "designed to make an individual dependent by isolating them from support, exploiting them, depriving them of independence, and regulating their everyday behavior"); Wash. Rev. Code § 7.105.010(4) (similar). See also Ark. Code Ann. § 9-15-219 (authorizing issuance of protective orders prohibiting "course of control or disturbing the peace" and defining "course of control" as "a pattern of behavior that in purpose or effect unreasonably interferes with the free will and personal liberty of a person"). defendant's pattern of monitoring the plaintiff's activities left the plaintiff "look[ing] over [her] shoulder" at all times and reduced her sense of personal freedom, integrity, and independence, even when she was in her own home. This evidence was adequate to prove that the plaintiff had experienced "a reduced sense of . . . autonomy." G. L. c. 209A, § 1 (subsection [a] of definition of "coercive control").

Finally, we conclude that the word "reasonably" (as it appears in the phrase "causes [the plaintiff] to reasonably fear physical harm or have a reduced sense of physical safety or autonomy" [emphasis added]) serves as a modifier for both "fear physical harm" and "have a reduced sense of physical safety or autonomy." G. L. c. 209A, § 1 (subsection [a] of definition of "coercive control"). The plaintiff, therefore, was required to prove that her perception of the reduction in her sense of physical safety or autonomy was reasonable. Indeed, in Iamele, 444 Mass. at 737, the Supreme Judicial Court read a similar reasonableness requirement into the definition of abuse by "fear of imminent serious physical harm" despite the fact that the Legislature had not explicitly included a reasonableness requirement in that definitional section as it did in defining coercive control. See G. L. c. 209A, § 1, as amended through St. 1996, c. 450, § 232 (subsection [b] of definition of "[a]buse").19

When assessing whether the plaintiff established the reasonableness of her reduced sense of physical safety or autonomy, the judge could consider evidence that demonstrated the defendant's disregard of the probate judge's order granting the plaintiff sole use and occupancy of the marital home and the defendant's unwillingness to comply with the no-contact provision in the ex parte abuse prevention order. See Commonwealth v. Gordon, 407 Mass. 340, 350 (1990) (fact that husband violated order to remain away from house was relevant to reasonableness of wife's fear that husband might abuse her). See also Commonwealth v. Kendrick, 446 Mass. 72, 76 (2006) ("A 'no contact' order . . . obligates a person to leave the area if a protected party appears"). The judge could also take into account the virtual certainty that, as parents with three school-aged children in common, the parties would continue to have contact with one another. See Iamele, supra at 740 (in

19 At the time of the Supreme Judicial Court's decision in Iamele, 444 Mass. at 736-737, the statute defined "[a]buse" as "the occurrence of one or more of the following acts between family or household members: (a) attempting to cause or causing physical harm; (b) placing another in fear of imminent serious physical harm; (c) causing another to engage involuntarily in sexual relations by force, threat or duress." G. L. c. 209A, § 1, as amended through St. 1996, c. 450, § 232. evaluating risk of future abuse, "a judge must consider the totality of the circumstances of the parties' relationship," including "the likelihood that the parties will encounter one another in the course of their usual activities"). Given these facts, we are satisfied that the evidence was adequate to show the reasonableness of the plaintiff's sense of either reduced physical safety or reduced autonomy. See G.B., 94 Mass. App. Ct. at 396 (plaintiff's statement confirming that she feared defendant was sufficient, considered as part of totality of circumstances, to prove that her subjective fear was objectively reasonable); Ginsberg v. Blacker, 67 Mass. App. Ct. 139, 148 (2006), quoting Pike v. Maguire, 47 Mass. App. Ct. 929, 930 (1999) (judge "'was entitled to credit the testimony of the plaintiff' regarding her fear in the attendant circumstances and 'to accept the reasonableness of her perception of that fear as a potential prelude to physical harm'").

For all of these reasons, we are satisfied that the evidence presented at the hearing was adequate to prove that the plaintiff was suffering from abuse under the "coercive control" definition set out in subsection (a) (iii) of the definition of that term.

4. Defendant's opportunity to be heard. On appeal, the defendant contends that he was denied the opportunity to be heard because the judge (1) limited defense counsel's ability to ask follow up questions of the defendant after the judge questioned the defendant directly and (2) concluded the hearing without allowing defense counsel to question the plaintiff about photographs that the plaintiff introduced for the first time during her final summation. The defendant argues that this case parallels Idris I. v. Hazel H., 100 Mass. App. Ct. 784, 787 (2022). Assuming that these claims are not waived,20 they are unavailing.

The portion of the defendant's brief dedicated to these challenges does not include any record citations. See Mass. R. A. P. 16 (a) (9), as appearing in 481 Mass. 1628 (2019) ("The argument shall contain . . . citations to the authorities and

20 As we discuss below, the defendant has failed to adequately identify which questions he now argues that the judge wrongly prevented defense counsel from asking him. It follows that the defendant has also failed to adequately establish that he preserved an objection to the judge's rulings. See Ciccarelli v. School Dep't of Lowell, 70 Mass. App. Ct. 787, 799 (2007) ("In order to raise an issue on appeal, a party must lodge a specific objection on the record").

We are also unable to identify any objection that preserved the defendant's challenge to the judge's decision to not allow defense counsel to cross-examine the plaintiff about the photographs that the plaintiff introduced during her summation. Defense counsel objected that she "didn't get a chance . . . to examine or cross-examine [the plaintiff] on any of the factual allegations that she made in her summation" and contended that the plaintiff's summation included "new, additional facts that were not testified to during the course of the hearing when the Court was hearing evidence." Defense counsel did not object to the introduction of the photographs on any ground. parts of the record on which the appellant relies"). Without that support, the defendant's argument the judge abused his discretion by preventing defense counsel from asking the defendant follow up questions amounts to no more than a "bald assertion[] of error." Zora v. State Ethics Comm'n, 415 Mass. 640, 642 n.3 (1993). We decline to address that argument. See Lynn v. Thompson, 435 Mass. 54, 56 n.4 (2001), cert. denied, 534 U.S. 1131 (2002) ("The requirement that a party provide 'an appropriate and accurate record reference' for each and every fact set forth in the brief is not an idle technical requirement" [citation omitted]).

Although we could, on the same grounds, reject the defendant's argument that he was wrongly denied an opportunity to cross-examine the plaintiff about the photographs she introduced when making her closing argument, we elect to address the issue because we can readily identify the part of the record to which this challenge relates. Although it would have been better practice for the self-represented plaintiff to have offered the photographs in evidence during her testimony, after careful examination of the record, we are not persuaded by the defendant's argument. "A judge has broad discretion in circumscribing the proper scope of cross-examination." Commonwealth v. Garcia, 470 Mass. 24, 35 (2014). Moreover, in c. 209A proceedings "the rules of evidence need not be followed, provided that there is fairness in what evidence is admitted and relied on." Frizado v. Frizado, 420 Mass. 592, 597-598 (1995). The photographs that the plaintiff referred to during her summation included pictures captioned "Home," depicting the defendant inside the house on five different dates and on one of those dates, also depicting the defendant's car stopped or braking on the street outside the house; pictures taken on several different dates, including some apparently taken by the plaintiff's doorbell camera, depicting the defendant standing on the plaintiff's porch, parked in her driveway, walking in the yard and standing on the street in front of the plaintiff's house; pictures of the defendant sitting, standing, walking, or cycling within feet of the photographer (presumably, the plaintiff) in other locations, including in Bermuda and on Nantucket; and pictures of the defendant talking to a child in a gym, taking photographs of swimmers at a Nantucket beach, and looking from a sidewalk toward a car from which a photograph was being taken. Some of the photographs were captioned with a month, day, and time.21 These photographs merely illustrated the plaintiff's testimony about the defendant's unwelcome appearances "at the house, at the beach," "in [her] car, on

21 There was no indication that any of the captioned photos were taken after the judge issued the ex parte abuse prevention order. vacation," and "in close proximity to [her]." Where defense counsel had extensively cross-examined the plaintiff on these issues earlier in the hearing, we discern no abuse of discretion in the judge's decision not to invite defense counsel to revisit them. See Clark v. Clark, 47 Mass. App. Ct. 737, 746 (1999) (noting judge's ability to limit cross-examination to eliminate "repetitious and irrelevant inquiries").

Finally, the defendant's reliance on Idris I., 100 Mass. App. Ct. at 787, is misplaced. Here, unlike the appellant in Idris I., the defendant had the opportunity to present his evidence and challenge that of the plaintiff. Cf. id. at 790, quoting S.T. v. E.M., 80 Mass. App. Ct. 423, 430-431 (2011) ("While a judge surely may exclude irrelevant or inadmissible evidence, or even interrupt an argument or a witness examination that has become repetitious, [the judge] should not terminate a hearing without ensuring that [the judge] has heard all the relevant and admissible evidence once"). We are not persuaded that the judge's limitations on the defendant's ability to cross-examine the plaintiff about the photographs deprived the defendant of a meaningful opportunity to challenge the plaintiff's evidence. Idris I., supra at 788 ("A meaningful opportunity to be heard includes an opportunity to address the material and determinative allegations at the core of a party's claim or defense and to present evidence on the contested facts"). See Guidelines for Judicial Practice: Abuse Prevention Proceedings § 1:02 (Oct. 2025).

5. Conclusion. The order entered on October 31, 2024, extending the ex parte abuse prevention order, is affirmed.

So ordered.