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"I then walked back to the apartment and quietly opened the front door so I could grab my purse and keys, which I had dropped by the door when respondent attacked me. I had no money or credit cards in my purse because respondent had taken these a couple of days before. I rode around in my car until it was time to get my daughter from school. I came back to the apartment about four hours later, expecting that he had cooled down by this time and that his brother would be there to help."

After talking to his brother, Sureldie said, Jamal apologized. "Respondent rather coldly said he was sorry. His brother took our daughter to McDonald's while the two of us talked, and then he stayed with us for several hours. I was very sore where respondent had punched me and from being pushed down the stairs. I had swellings on my legs and lower back. Respondent is 6´3´´ and weighs about 350 pounds. He is very muscular and strong. He was contrite that evening about having hurt me and promised he would never hit me again."

But, Sureldie claimed, her ordeal was just beginning.

On Saturday, March 2, an argument began. "He called his mother and asked me to talk to his mother. While I was talking to her, he grabbed our daughter and said, 'We're leaving.' I put the phone down and told him that he should not be taking her away. She was holding tightly onto me and was frightened because the respondent was obviously very angry and out of control.

"At that point I hung up on the call with his mother and called 911. The police came to our apartment and talked to us. I told the police that I just wanted to get away for a while. The respondent said that I could not take our rental car, but the police verified that my name was on the rental agreement, and they told him to give me the keys."

After that, Sureldie said, she and her daughter moved in with a friend for a few days. Then on March 8 Jamal called with an offer of reconciliation. It involved a shopping trip, which quickly turned disastrous. "After our daughter was taken to preschool, respondent suggested that we go together and buy new wedding rings, which I understood to mean that he wanted to make a fresh start. We went to three places and after some time selected rings we wanted to purchase.

"Before the sale was finalized, however, he told me he had spent [all] of the money from a very large bonus we had been expecting and had wired his mother $82,000 from what he had received to pay off her home mortgage. We do not have a savings account, have some major bills, and we did not even have the means to pay for the rings we were about to order. I was extremely shocked by his actions, and he became very defensive about what he had done.

"While we were driving home, he pulled the truck over to the side of the road and told me to get out. I refused, and he then proceeded to drive home. When we got home, he pulled in behind my car so that I could not remove my car from the garage. Earlier that day, he had taken my cell phone, and he refused to give it back to me. He was verbally abusive, was very angry, and seemed to be getting out of control.

"I became very frightened. I called 911 and asked for someone to come out so I could leave before he became violent again. As soon as I got off the phone, he left the house, and I felt certain that he was going to get our daughter from her school. I was very concerned about respondent picking her up while he was in such a state, particularly since he had previously threatened to take her to his mother's home in Kentucky. I called the school and asked them not to release her to him, and they agreed.

"The police arrived at our apartment and took a report. After the officer spoke to a judge by phone, he provided me with an emergency protective order that will expire on Friday, March 15. In the meantime, respondent had gone to the school and told a teacher that he was leaving with Joy to 'go on a vacation' and that they would be gone 'for about a month.' They refused to release her to him, and while he was arguing with them, the police came and took him into custody.

"Even though I have the emergency protective order, I felt very unsafe, and I asked my father to come out from Texas to stay with me. He arrived that night, and he, Joy, and I checked into a hotel because I was still afraid that he would come to our apartment despite the protective order. I believe that respondent is mentally unstable. He has been given prescriptions for mood stabilizers, but he has refused to take them."

Saying she could no longer deal with the threats to her physical safety from Jamal, Sureldie and her daughter flew from San Diego to stay in the couple's Texas estate, but, according to a declaration dated April 18, 2002, she soon discovered that Jamal had "changed the security code to our home, and he also changed the emergency contact numbers to that of his mother and his brother." Jamal, she added, "also changed the code on our voice mail and he disconnected the long-distance service and had the cable turned off. He had all the locks changed and completed a change of address with the post, sending our mail to his mother's address."

"On March 27, around three o'clock in the morning, I received several phone calls on my cell phone. The caller did not speak, but I believe it was the respondent on the other end. I could hear someone breathing into the phone, but he would not respond.

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