Under the Domestic Violence Prevention Act (Family Code 6300 et seq.) a spouse may be restrained from committing violence on the other spouse.  Section 6305 requires special findings if the court issues a mutual restraining order.  Following n Melissa G. v. Raymond M. (2018) 27 Cal.App.5th 360 and disagreeing with Conness v. Satram (2004) 122 Cal.App.4th 197, this decision holds that whether dueling DVPA petitions are heard jointly with a single resulting order or are heard at different times with different orders addressing only one spouse, if the net result is a restraining order against each spouse, section 6305 applies requiring the special findings that each spouse was a primary aggressor.  The decision also holds that section 6305 applies even when the dueling petitions relate to different episodes.