Ritchie v. Konrad (2004) 115 Cal.App.4th 1275, addressed the issue of weighing the burdens a DVRO imposes against the risk of future abuse in the context of a request for renewal of a domestic violence protective order under section 6345. (Ritchie, supra, 115 Cal.App.4th at pp. 1283, 1292.) In that context, it stated, "The burdens the restrained party suffers from a renewed--and especially a permanent--protective order may become relevant, however, where the existing order focuses not on the threat of physical violence, but lesser forms of abuse--unwanted telephone calls or mail, for example. Where the worst 'danger' the protected party must fear is a few unwanted calls or letters or e-mail messages, the court may have to weigh the seriousness as well as the degree of the risk against the significance of the burdens the restrained party will experience if subjected to a continuing protective order." (Ibid.) In Ritchie, the court concluded that the firearm restriction in section 6389 is mandatory when a court imposes or renews any of the protective orders defined in section 6218. (Ritchie, supra, 115 Cal.App.4th at pp. 1294-1295.) Ritchie stated, "a firearms restriction becomes mandatory even when a trial court imposes a protective order based solely on the restrained party placing annoying telephone calls, or sending unwanted e-mails, letters, or the like." (Id. at p. 1299.) In short, the respondent sought an extension of a protective order under Family Code section 6345. (Ritchie, supra, 115 Cal.App.4th at p. 1280.) This statute provides that an order may be renewed upon request "either for five years or permanently, without a showing of any further abuse since the issuance of the original order . . . ." (Fam. Code, 6345.) The trial court interpreted the statutory language as entitling the protected party to an extension of the protective order upon request. (Ritchie, at p. 1281.) The appellate court reversed, and held that "the trial court should grant a requested extension unless the request is contested and the judge determines the protected party does not entertain a 'reasonable apprehension' of future abusive conduct." (Ritchie, at p. 1279.)