That said, RK’s criminal convictions alone are insufficient to form a legitimate basis for JK’s subjective fears: Noriega v. Litke, 2020 ONSC 2970. While I accept that JK took RK’s threat seriously, that she was scared, and that it was the main factor prompting her to leave the relationship, I also note that the threat was made some 18 months ago, and that there have been no further criminal convictions since.
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