In In re Marriage of Nadkarni (2009) 173 Cal.App.4th 1483, a former wife alleged that her ex-husband had accessed her private e-mail account while she was away on a business trip, then attached copies of the e-mails to documents filed in proceedings regarding custody of their teenaged children. (173 Cal.App.4th at pp. 1487-1488.) She sought a permanent restraining order, but the trial court denied it without a hearing after finding that the DVPA did not cover situations in which there was no physical harm alleged. The appellate court reversed and remanded the matter to the trial court for a hearing. It held that the definition of abuse under the DVPA is not limited to the infliction of physical injury or assault. (173 Cal.App.4th at pp. 1498, 1501.)