Where kidnapping, extortion and assault charges arise from the same course of conduct, cumulation of approximately 31 per cent on extortion and 25 per cent on assault (approximately 69-75 per cent concurrency) may be appropriate. The existence of aggravating factors common across multiple offences does not preclude ordering cumulation to reflect the seriousness of each offence, provided the sentencing judge identifies the differentiating characteristics of each charge.
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