California, United States of America
The following excerpt is from Cathy B. v. Christopher B., B277144 (Cal. App. 2018):
"'"[D]isturbing the peace of the other party" in section 6320 may be properly understood as conduct that destroys the mental or emotional calm of the other party.'" (Burquet v. Brumbaugh (2014) 223 Cal.App.4th 1140, 1146.)
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