Wording about tech abuse for restraining orders

If you are seeking a restraining order

A woman who fears for her safety and that of her children because of tech abuse may be able to get a restraining order (see Lawrence v. Bassett, 2015 ONSC 3707 and A.T. v. V.S., 2020 ONSC 4198).

She will need to show the court that she has “reasonable grounds” to fear. Reasonable grounds means that any other person in her situation would be fearful. The fear can be for psychological and emotional safety as well as physical safety.

Wording in a court order could be:

[name of ex-partner] be prohibited and restrained from communicating, disseminating, posting on the internet, distributing or publishing in any manner whatsoever, whether directly or indirectly, any statements, depictions, descriptions or commentary that reference by name or innuendo anything related to [name of mother and children].

[name of ex-partner] shall delete any social media posts
(i) that refer to the issues in this litigation, or
(ii) that denigrate the mother, or
(iii) that refer to the [name of mother and children]. This [list specific posts], shall be deleted;

[name of ex-partner] shall refrain from creating any new social media posts
(i) that refer to the issues in this litigation, or
(ii) that denigrate the mother, or
(iii) that refer to [name of mother and children].