In a Decision – A.B. v. D.M.O., (an "Unreported Decision") >> the Court Held:
The Appellate Division reversed the Trial Court decision that defendant's
motivation to harm plaintiff's business established a predicate act of
Domestic Violence in the form of causing emotional distress
On appeal, the court reversed the entry of a FRO and remanded for further proceedings. The court found that defendant's harassment of plaintiff was not sufficiently egregious to warrant the entry of a FRO. Here the offense of harassment was not itself sufficiently egregious.