Holly Madison is accusing Crystal Hefner of “legal bullying” after Hugh Hefner‘s widow threatened to sue her over comments on her podcast … TMZ has learned.

In an exclusive clip from the “Girls Next Level” Patreon, Holly and co-host Bridget Marquardt confirm they — as well as Marston Hefner — received written warnings from Crystal’s lawyer … which they deem a gross overreaction.

As TMZ previously reported … Crystal’s lawyer accused the podcast hosts and Marston of suggesting CH kept Hugh “doped up” in order to take advantage of him financially — warning the trio to avoid making further comments in the future or they would be facing legal action.

Yet, as Holly and Bridget put it, they never made such an implication … with Holly stating they were “obnoxiously careful” not to say anything defamatory.

Holly does say Marston suggested medical professionals might have overprescribed Hugh toward the end … but insists they never linked Crystal to this situation.

Without naming Crystal directly, Holly further defends their podcast interview … claiming Crystal is just trying to intimidate them.

She adds … “I’m not backing down — there’s a thing I like to call ‘legal bullying,’ when people who think they’re richer than everybody else pay their attorneys to send cease and desists to people to shut them up.”

Holly says it’s more common than you may think … noting everyday people are too scared to go head-to-head against wealthy celebs.

Though Bridget doesn’t say much in the segment, she appears to back Holly’s stance, offering up a simple, “Yeah.”