I don't know enough about the law in Liz's state to say whether this would qualify for any type of protective order. Many states have different types of protective orders, depending on what behavior has been going on. Lexie has far more experience with this stuff than me, and I'm sure she will chime in when she's able.
I do know that over the years, Liz's XAH and my STBXAH have shared a lot of qualities--one of those qualities is the ability to talk a BIG game with little to no follow-through. At the very least, however, it is worth a call to the lawyer and taking steps to document this behavior, because even if THIS doesn't warrant a protective order, it may ultimately warrant one if combined with other behavior in the future.