In order to be guilty of criminal contempt in the first degree, a defendant must intentionally place or attempt to place a person for whose protection an order of protection was issued "in reasonable fear of physical injury, serious physical injury or death" (Penal Law § 215.51 [b] [iii]). Where "reasonable fear" is an element of a crime, the fear must be objectively reasonable (see Donnino, Practice Commentaries, McKinney's Cons Laws of NY, Book 39, Penal Law...
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