The following excerpt is from Malott v. Placer Cnty., No. 2:14-CV-1040 KJM EFB (E.D. Cal. 2016):
Cal. Civ. Code 52.1(j); see also Martin v. County of San Diego, 650 F. Supp. 2d 1094, 1108 (S.D. Cal. 2009) ("although the language of 52.1(a) does not mention 'violence,' 52.1(j) explicitly provides that violence is a required element where the 'threat, intimidation or coercion' is based purely upon a defendant's statements.").
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