Under Family Code 6320(c), a domestic violence restraining order may issue against a defendant who “disturbs the peace of the other party by conduct that, based on the totality of the circumstances, destroys the mental or emotional calm of the other party.  This decision holds that unlike other portions of the DVRO statute that expressly refer to “reasonable” fear of violence, for example, this provision contains no express or implied requirement that the plaintiff’s mental or emotional distress be a reasonable reaction to the defendant’s conduct.