California, United States of America
The following excerpt is from Kaiser Found. Hosps. v. Letherblaire, C085987 (Cal. App. 2020):
It appears that Letherblaire further claims that her e-mails were created in the context of constitutionally-protected probate litigation activity. Section 527.8 does not permit a court to issue an order prohibiting speech or other activities that are constitutionally protected or otherwise protected by any provision of law. ( 527.8, subd. (c).) But threatening violence is not constitutionally protected and Letherblaire does not cite any authority holding otherwise. (See City of San Jose, supra, 190 Cal.App.4th at p. 537; see Brekke v. Wills (2005) 125 Cal.App.4th 1400, 1403-1404 [speech used to annoy, ridicule and threaten mother of respondent's girlfriend was not entitled to constitutional protection].)
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