Nor is there any evidence that Plaintiff has engaged in similar abuse after the Court's warning. ECF No. 62; see Harry v. Lagomarsine, No. 18-cv-1822, 2019 WL 1177718, at *2 (E.D.N.Y. March 13, 2019) (noting dismissals after warning). Under these circumstances, I cannot make a finding by clear and convincing evidence that Plaintiff so willfully or intentionally abused the litigation process that I should go so far as dismissing the case.

Courts have not hesitated to dismiss a pro se Plaintiff's claims with prejudice based on such serious threats, which have no place in a civilized society, to say nothing of a federal court. See, e.g., Harry v. Lagomarsine, 2019 WL 1177718, at *1 (E.D.N.Y. Mar. 13, 2019) (threats to sexually assault and kill defense counsel); Phelan v. Karandy, 2012 WL 2235125, at *3 (N.D.N.Y. June 15, 2012) (threats against judge); Nelson v. Eaves, 140 F.Supp.2d 319, 319-320 (S.D.N.Y. 2001) (Chin, J.) (threatening and sexually graphic letters to defense counsel).

Harassing and intimidating counsel so that they withdraw from litigating a case is beyond cavil; it is an unfair and inappropriate litigation strategy that strikes at the core of our system. See Harry v. Lagomarsine , Docket No. 18-CV-1822 (BMC) (LB), 2019 WL 1177718, *3 (E.D.N.Y. March 13, 2019) (explaining how threats to opposing counsel "effected a permanent change in [the] defendants’ representation"); Kalwasinski v. Ryan , supra, 2007 WL 2743434, at *3 ("[b]y deliberately and intentionally participating in making threats of physical harm against parties and witnesses in his case, he has engaged in conduct that he should have known would threaten a fair decision in this matter"). We recognize that there is a place for strong advocacy in litigation, but language evoking threats of physical harm is not tolerable.