In People v. Bonitto, 4 Misc 3d 386 (Crim Ct NY County 2004) a jail inmate sent two letters to a stranger. In the first, he asked her for permission to call her. In the second, sent one month later, defendant observed that if he could not get the complainant's attention, he would resort to resort to "Plan B." The court held that even "the reference to Plan B' was, at most, vague and ambiguous and seems to be explained by the final sentence of the letter, which advises that the defendant, in the absence of a response, will call the complainant." Id.