The following excerpt is from El-Dehdan v. El-Dehdan, 19 N.Y.S.3d 475, 2015 N.Y. Slip Op. 07579, 26 N.Y.3d 19, 41 N.E.3d 340 (N.Y. 2015):
King v. Barnes, 113 N.Y. 476, 21 N.E. 182 [1889]). This Court then stated that the element which serves to elevate a contempt from civil to criminal is the level of willfulness with which the conduct is carried out (id.).
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