31th August 2022

Urgent and Confidential

Not for Publication

Ms Kieran O’Rourke
16 Barnabas Crescent
CHRISITE DOWNS SA 5164

12th Aug 2022

Mr George Dixon
16 Barnabas Crescent
CHRISTIE DOWNS SA 5164

Email: jean@chesterslegal.com.au

This document, including any attachments, may contain privileged and confidential information intended only for the addressee named
above. If you are not the intended recipient, please notify me. Any unauthorised use, distribution, or reproduction of the content of
this document is expressly forbidden

Dear Sir,Madam

Re: Defamation of MSR Kieran O’Rourke – Concerns Notice. “Without prejudice”

This letter is a Concerns Notice pursuant to section 14 (2) of the Defamation Act 2005 (SA)

I am writingwrite to you regarding your email dated: 9th July 2022 Regarding Cease and Desist. A
third3rd Party who identifiedthat identified the original post has brought to my attention about Mr
Dixon’s publication on Facebook which has still not been removed.

Defamation of Msr O’Rourke

Mr Dixon’s defamatory thread on Facebook

Comment posted on or around the 15th Sept 2021 by Mr Dixon via Facebook.

“You have abused and controlled my life, silenced my voice, alienated my family and friends, sunk
your claws into everything, attempted to destroy my business, reported false accusations, come at
me with work cover, changed the locks and denied entry to my own home, hold my stuff for
ransom, destroying my belongings and endless threats. I will not give up fighting. Karma is a
bitch.”

Imputations of Concern

In their natural and ordinary meaning, the Publication contains the following injurious and grossly
defamatory imputations concerning me
 1. Mr O’Rourke has abused, controlled, and silenced Mr Dixon
2. Mr O’Rourke alienated Family members and friends
3. Attempted to destroy Mr Dixon’s Business
4. Mr O’Rourke reported false accusations
5. Mr O’Rourke come at Mr Dixon with Work Cover
6. Mr O’Rourke denied entry to Mr Dixon’s own home.

The allegations your client has published are entirely without foundation. They are defamatory of
myself and constitute a malicious falsehood in relation to me. They are published without regard to
the facts and with no proper evidence made to me as to their fairness or accuracy.

Having attacked me regarding my Personal Character, Mr Dixon has chosen to publish material
which is unfounded, unfair and which would breach all the standards to which you refer when
attacking me.

I have evidence to prove that the comments made by Mr Dixon via Facebook contain serious,
untrue, and highly defamatory comments towards myself, some of which contain malicious
falsehood. In doing so, defamatory comments are being communicated to hundreds of people
throughout the community, posing a serious threat to my reputation.

The allegations your client has published are entirely without foundation. They are defamatory of
myself and constitute a malicious falsehood in relation to me. They are published without regard to
the facts and with no proper evidence made to me as to their fairness or accuracy.

Having attacked me regarding my Personal Character, Mr Dixon has chosen to publish material
which is unfounded, unfair and which would breach all the standards when attacking me.

I have evidence to prove that the comments made by Mr Dixon via Facebook contain serious,
untrue, and highly defamatory comments towards myself, some of which contain malicious
falsehood. In doing so, defamatory comments are being communicated to hundreds of people
throughout the community, posing a serious threat to the reputation of myself.

The defamatory thread are as follows

Comment posted on or around the 15 th Sept 2021 by Mr Dixon via Facebook.

“You have abused and controlled my life, silenced my voice, alienated my family and friends, sunk
your claws into everything, attempted to destroy my business, reported false accusations, come at
me with work cover, changed the locks and denied entry to my own home, hold my stuff for ransom,
destroying my belongings and endless threats. I will not give up fighting. Karma is a bitch.”
Imputations of Concern

In their natural and ordinary meaning, the Publications contain at least the following injurious and
grossly defamatory imputations of and concerning me

7. Mr O’Rourke has abused, controlled, and silenced Mr Dixon

8. Mr O’Rourke alienated Family members and friends
9. Attempted to destroy Mr Dixon’s Business
10. Mr O’Rourke reported false accusations
11. Mr O’Rourke come at Mr Dixon with Work Cover
12. Mr O’Rourke denied entry to Mr Dixon’s own home.

These grave allegations and imputations are strenuously denied. They have caused me significant
humiliation, hurt and distress. The publications also have the capacity to cause significant economic
loss to myself. The Publications are baseless and cannot be tolerated. They appear to be part of a
deliberate campaign by Mr Dixon to wilfully discredit and damage myself. They represent a very
personal attack, which is completely unwarranted and must now stop.

Urgent Steps must be taken to minimise the damage which has been and continues to be caused
by Mr Dixon’s publication of the Facebook post and comments made. I seek the following.

1. The immediate removal of the article and comments from publication on Mr Dixon’s
Facebook Page.
2. Your written undertaking that Mr Dixon will not republish any of the allegations in the
Facebook Post or comments or any other false, misleading, or defamatory material
regarding Msr O’Rourke
3. A full and unqualified written apology for and retraction of the allegations in the comments
in the form to be approved by myself.
4. The posting of the apology in a prominent position on the homepage of his profile on
facebook which must be visible to the public.
5. A submission to Myself withinwith in 14 Days of the date of this letter that action has been
taken by your client Mr Dixon that removal has takenas taken place.
6. I seek an Offer to Make Amends by Financial Compensation pursuant to the Act.

This offer is subject to the parties entering into a Deed of Settlement and release on terms to be
agreed.

Your client will have significant hurdles to face in successfully defending such claim.

Legal Proceedings & Cost

If you do not make and offer to make amends in line with the above and otherwise fail to comply
with the matters above.

If I am forced to issue legal proceedings, I will seek the following orders.

1. Order that you desist from the above-referred conduct

2. Compensation for economical and non-economicnon-economical loss in relation to Mr
Dixons Conduct
3. Legal costs against Mr Dixon, on an indemnity basis.
In the event this is not forthcoming from you within the time referred to above, I will commence
proceedings for defamation without further notice to you under Section 18 of the Defamation Act
2005 (SA).

I request a response no later than close of Business Friday 2nd September 2022

Kind Regards

Kieran O’Rourke