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iii) The Defendant's correspondence includes:

a) two suggestions that an ABC Councillor should commit suicide;

b) numerous examples of personally offensive comments about appearance, weight, intelligence and capability;

c) unfounded accusations of criminal conduct including allegations of misfeasance in public office, perverting the course of justice, perjury and conducting restricted legal activities without lawful authority to do so;

d) unfounded allegations of professional misconduct;

e) frequent hollow threats of reporting an individual to CILEX or some other regulator;

f) frequent hollow threats of judicial review or other legal proceedings;

g) requests that ABC Councillors or employees should resign or should be dismissed.

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