HomeMy WebLinkAboutP-2007-0665.Antoncic.09-01-06 Decision
Public Service Commission des
Grievance Board griefs de la fonction
publique
Bureau 600
Suite 600
180, rue Dundas Ouest
180 Dundas St. West
Toronto (Ontario) M5G 1Z8
Toronto, Ontario M5G 1Z8
Tél. : (416) 326-1388
Tel. (416) 326-1388
Téléc. : (416) 326-1396
Fax (416) 326-1396
P-2007-0665
IN THE MATTER OF AN ARBITRATION
Under
THE PUBLIC SERVICE ACT
Before
THE PUBLIC SERVICE GRIEVANCE BOARD
BETWEEN
AntoncicGrievor
- and -
The Crown in Right of Ontario
(Ministry of Community Safety and Correctional Services)
Employer
BEFOREKathleen O?Neil Vice-Chair
FOR THE GRIEVOR
Marc A. Munro
Counsel
Graydon Sheppard B.A. LL.B.
FOR THE EMPLOYERPaul Meier
Counsel
Ministry of Government Services
HEARINGNovember 17, 2008.
2
Decision
[1]This decision deals with the question of whether the grievor, Nicholas Antoncic, has
breached the terms of a Memorandum of Settlement, dated July 20, 2007, which settled
his grievance concerning his dismissal for cause. The employer claims that the grievor
has breached that agreement in a number of ways, notably by launching a civil action
against two civil servants for conspiracy and defamation. A preliminary decision giving
my reasons for finding that I had jurisdiction over the dispute was issued on October 10,
2008. A hearing was then convened to hear the main issue. At that time, the parties
agreed to deal only with the question of whether the minutes of settlement had been
breached and to leave the dispute as to what remedy should follow, if a breach were
found, to a later time.
[2]The evidence necessary to this decision was introduced mostly by way of filing
documents on consent. Two letters from the grievor to the Minister of Corrections and
the Attorney General dated October 27 and 30, 2007, respectively, were admitted over
the objection of counsel for the grievor as arguably relevant to the meaning of the
grievor?s suit against his former colleagues. There is little dispute about the facts
necessary to this decision; it is the question of whether they constitute a breach of the
settlement which divides the parties.
[3]Prior to his dismissal on September 25, 2006, the grievor was employed as a Staff
Relations Manager with the Ministry. The dismissal followed an investigation into a
number of allegations, including that Mr. Antoncic had improperly released a Staff
Relations Officer, a probationary employee.This employee alleged that his release was a
reprisal for the fact that the Staff Relations Officer was involved in a personal
3
relationship with a woman, also a Ministry employee, with whom the grievor had earlier
been similarly involved. It is this couple that Mr. Antoncic has sued for defamation and
conspiracy. Prior to signing the minutes of settlement here in dispute the grievor had
asserted , in correspondence to the employer on various occasions, and/or in the
grievance filed with this Board, that some of the information relied on by the investigator,
including from the couple, was fabricated, tailored, incorrect, incomplete and/or
deliberately misrepresentative. As well, according to notes prepared by Mr. Antoncic?s
former counsel for a meeting with the employer on February 8, 2007, the grievor had
received the complaint made about him by the released Staff Relations Officer by August
31, 2006 when Mr. Antoncic was suspended from employment pending the completion of
the employer?s investigation. When he agreed to the Minutes of Settlement at a
mediation session at the Board, Mr. Antoncic was represented by his former counsel.
[4]In the statement of claim dated December 20, 2007, Mr. Antoncic asserts that the
defendants conspired to advance false allegations to discredit him and undermine his
employment, and that they communicated false statements to the employer and the
investigator, injuring his reputation and causing him distress and embarrassment, and
leading to his termination.
[5]In his letter to the Minister of Community Safety and Correctional Services, Rick
Bartolucci, dated October 27, 2008 Mr. Antoncic wrote: ?As a direct consequence of my
dismissal, I commenced a civil action for defamation against two (2) Ministry
employees?, and that since then, government officials had ?engaged in a concerted,
sustained and improper effort to thwart the advancement of my claim or damages against
the defendants? in order ?to suppress the release of information regarding?systemic
4
financial mismanagement, abuse of the public trust?and other irregularities which will
become part of the public record during the course of my civil action.? He further
indicated he would be cooperating with members of the press interested in his case. His
letter to Attorney General, Chris Bentley, dated October 30, 2008 makes similar
statements.
[6]The portions of the confidential agreement between the grievor and the Ministry most
pertinent to this decision are the following:
WHEREAS theGrievor has filed a grievance under the Public Service
Act with the PSGB dated May 28, 2007, and whereas this grievance bears the file
# 2007-0665;
AND WHEREAS the Parties wish to resolve the aforementioned matter
and any and all outstanding matters relating to the Grievor?s employment on a
without prejudice and precedent basis and without any admission of liability or
wrongdoing on either Party?s part;
NOW THEREFORE the parties agree to the following terms and
conditions as full and final resolution of the above captioned grievance and all
other outstanding individual grievances, complaints, claims and matters regarding
the Grievor?s past employment:
1.The Grievor agrees that the above captioned grievance, and any and all
outstanding grievances pertaining to the Grievor?s employment, is hereby
withdrawn. The Grievor further agrees to inform the Public Service Grievance
Board (?PSGB?) of their withdrawal;
2. [The employer agreed to pay the grievor a sum of money.]
3.The parties agree that as consideration for the payment in paragraph 2 above, the
Grievor shall have no additional claim for payments of salary, benefits, severance,
termination pay or benefits of any other kind arising from his employment with
the Employer;
?
6. The Parties agree to keep the terms and conditions of this agreement
confidential except as otherwise required by law and for the purposes of
implementation of this settlement;
7. The Grievor further agrees to keep confidential any and all matters and
information obtained, discovered or learned of, directly or indirectly, during the
course of his employment with the Employer. Such confidentiality shall be
5
protected by the Grievor and considered a vital term and condition of this
agreement;
8. The Grievor further acknowledges his post-employment duties and obligations
flowing from his Oath of Office and Secrecy as set out in the Public Service Act
and its regulations, and any future enactment and the regulations promulgated
thereunder. Such duties and obligations are not exhaustive and would include any
additional duties and obligations at common law;
9. The Parties further agree that neither shall make disparaging remarks regarding
the conduct of the other;
10. The Grievor agrees to irrevocably instruct his Counsel to return any and all
materials disclosed by the Employer through its Counsel, and in particular the
disclosures made under covering letters dated December 8, 2007 and December
21, 2007. Such irrevocable instruction shall be made upon the signing of this
agreement. ?
[Note: the parties agreed at the hearing that the letters mentioned in this
paragraph were actually dated in 2006 rather than 2007. Nothing turns on the typing error in the
date in any event.]
?
12. The Grievor hereby agrees to release and forever discharge the Employer and
the Crown in Right of Ontario from any and all grievances, claims, complaints,
actions or causes of action respecting the Grievor?s employment and cessation of
employment, including under the Employment Standards Act, Human Rights
Code and any related statutes. In addition, the Parties agree and acknowledge that
payment of the sum identified in paragraph 2 is inclusive of and exhaustive of all
possible entitlements, statutory or otherwise, to severance pay on termination or
pay in lieu of reasonable notice or damages whether pursuant to the Public Service
Act, to any heads of damage under the Ontario Human Rights Act, and under any
other Statute or common law;
?
14.The parties agree that this memorandum of settlement constitutes the entire
agreement between the parties and supersedes all oral or written agreements
arrangements, representations or understandings between the parties;
15. The Grievor agrees that he is fully informed of and understands the
;
consequences of this settlement and, accordingly, he enters into it voluntarily
16. The parties agree that Vice-Chair K. O?Neil shall remain seized of the matter
for the sole purpose of overseeing the effective implementation or resolving any
breach of the terms and conditions of this settlement.
[7]The thrust of the employer?s position is that the Minutes of Settlement amount to an
agreement that all disputes related to the grievor?s employment were settled, and that the
6
grievor?s lawsuit is an attempt to resurrect a dispute which was central to the settled
grievance, in contravention of the Minutes of Settlement. Employer counsel asks for a
declaration that the grievor has breached paragraphs 7, 9, 10 and 12 of the Minutes of
Settlement. The following case law is relied on in support:
McIntyre v. Connolly, [2008]
O.J. No. 1097 (O.S.J.), Toronto District School Board v. Ontario Secondary School
Teachers? Federation (re McIntyre), unreported decision dated April 5, 2007, (Arbitrator
London Drugs Ltd. v. Kuehne & Nagel International Ltd., [1992] 3 S.C.R. 299,
Shime),
cited to 1992 CanLII 41 (S.C.C.), OPSEU (Clarke) and Ministry of Natural Resources,
(March 11, 2003) GSB # 0260/98, etc., (Brown), A Co. v. Naster, [2001] O.J. No. 4997,
Disher v. Kowal, [2001] O.J. No. 4184 (O.S.J.) ?2001 CanLII 28010 (ON S.C.) and
OPSEU (Young) and The Crown in Right of Ontario (Ministry of the Attorney General),
(January 23, 2004), GSB # 2001-0660, (Abramsky) .
[8]By contrast, the grievor?s position is centered on the fact that the defendants in the
lawsuit were not parties to the settlement and not covered in the release clause. It is
asserted that the grievor accepted the agreed compensation in lieu of reasonable notice,
and executed the settlement because it was expressly limited in scope to the employer and
the Crown. As a result, it is argued that the lawsuit does not breach the settlement.
Counsel for the grievor maintained that the employer is asking that wording be implied
into the release clause which it failed to negotiate. As in Gabriel v. Hamilton Tiger- Cat
Football Club Ltd. (1975) 8 O.R. (2d) 285, counsel invites a finding that the wording of
the contract is unambiguous and should be applied as negotiated. Referring to Eli Lilly &
Co. v. Novopharm Ltd., [1998] 2 S.C.R. 129, counsel submits that, in the absence of
ambiguous language, extrinsic evidence, such as of one party?s intention, or the
surrounding circumstances, cannot be relied upon. Moreover, it is the grievor?s position
7
that the lack of privity of contract with the defendants in the civil suit prevents them from
benefiting from the Minutes of Settlement.
[9]Referring to excerpts from the textThe Law of Releases in Canadaby Fred D. Cass,
counsel for the grievor submits that the release of the Crown and the employer does not
release the individual defendants in the civil suit, and refers to
Morgan v. Saskatchewan,
Consolidated Mining and Smelting Co.
(1985) 43 Sask. R. 129 in support. Referring to
of Canada v. Murdoch [1929] SCR 141, (S.C.C.) counsel invites a finding that the
employer is complaining about behaviour that is analogous to an accident in the
employer?s parking lot, or a fight in the hall, not something that arose in the course of
employment, in that defamation cannot be part of the grievor?s job description.
[10]As to the employer?s allegation concerning the breach of the confidentiality provisions in
paragraph 7 of the Minutes of Settlement, grievor?s counsel argues that it is overbroad,
and should be considered void for vagueness.If interpreted literally, and together with
the non-disparagement language in the way the employer argues, he submits, the
grievor?s right to free speech would be infringed, and he would never be able to engage
in political discourse.
[11]Both counsel spent considerable time on whether or not the information disclosed to the
grievor prior to the settlement was subject to a deemed undertaking, and whether that in
itself should indicate that the settlement was breached. This included the argument on
behalf of the grievor that the employer?s specific invocation of the deemed undertaking in
its covering letters forwarding disclosure had not been adopted by counsel for the grievor,
and was superseded by the language of the Minutes of Settlement providing that its terms
8
were the ?entire agreement?. Further, counsel for the grievor argued that third parties
such as the defendants in the law suit should not be given the benefit of the deemed
Temeliniv.Canada Permanent Trust Co (2005) 21 C.P..
undertaking rule, relying on
th
(6
) 179.. Although I accept that, as set out in A Co. v. Naster, cited above, the deemed
undertaking rule applies in proceedings before administrative tribunals, I do not find it
necessary to deal with this dispute in that context, as the wording of the Memorandum of
Settlement is sufficient to determine the question before me. Further, any question
concerning what benefit the defendants may derive from the deemed undertaking rule in
the civil suit is a matter of the interpretation of the rule for the Court.
[12]Further, counsel for the grievor submitted that, given that the jurisdiction of the Public
Service Board is limited to the wrongful dismissal claim, the grievor?s claim in tort
against the defendants could not be remedied by this Board by damages for defamation
and conspiracy in any event. In this respect, he argued that the claim for damages in the
law suit was not a claim for double recovery as argued by the employer, since damages
for wrongful dismissal are distinct, intended to compensate for lack of notice, and not
aimed at remedying the damage to reputation on which the tort claim is based.
***
[13]The central question to be determined is whether Mr. Antoncic has breached the Minutes
of Settlement by launching an action for defamation against his former colleagues. I
have considered all the detailed arguments made, orally and in writing, as well as all the
material filed, including the extensive case law. In the view I take of this matter, the
issue can be resolved in a straightforward manner, and does not require an extensive
analysis of the authorities. The issue before me depends on the interpretation of the
Minutes of Settlement in their entirety, including, but not limited to, the release portion of
9
the document, found in the first sentence of paragraph 12. When read in its entirety, the
language of the settlement document clearly communicates that the parties were settling
?all outstanding matters relating to the Grievor?s employment?. It was not just a
resolution of the grievance that he had been wrongfully dismissed; it was also a ?full and
final resolution of ? all other outstanding individual grievances, complaints, claims and
matters regarding the Grievor?s past employment.? As a result, the basic question to be
answered is whether the civil suit is a claim or matter ?regarding the grievor?s past
employment?. In my view, it is very clear that it is. The thrust of the statement of claim
is that the defendants made false statements about the grievor?s conduct during his past
employment as a staff relations manager. The employment context permeates the
grievor?s pleading, and it is specifically alleged in the civil suit that the defendants?
conspiracy and disparaging remarks lead to the investigation of Mr. Antoncic?s alleged
improper conduct and his discharge from his employment. Further, it specifically claims
damages for economic loss as a result of his termination. In all these aspects, it is both a
claim and a matter regarding the grievor?s past employment.
[14] In this regard, it was argued on behalf of the grievor that the employer did not insist on
the inclusion in the settlement of what counsel referred to as ?the other issues swirling
around? at the time of Mr. Antoncic?s discharge. As well, he submitted that what he
referred to as a ?a standard release clause? reciting a release of all employees and
servants would have been necessary to achieve the result for which the employer argues.
[15]Further, counsel referred to the jurisprudence flowing from Weberv.Ontario Hydro
[1995] 2 S.C.R. 929 to support his argument that defamation and conspiracy are not part
of the jurisdiction of the Board, and that the employer would have objected if the grievor
10
had tried to claim compensation for defamation as part of his grievance. Looking at the
enabling statute, and to the grievance to determine the nature of the dispute, counsel
argues that, since the Board?s jurisdiction and the grievance were limited to unjust
dismissal, the wording ?any and all matters related to the grievor?s employment? should
be interpreted to be limited to unjust dismissal. I do not find this persuasive in light of
both the broad language of the third unnumbered paragraph of the Minutes of settlement,
as well as the second sentence of paragraph 12, which refers to the exhaustion of ?all
possible entitlements? including damages at common law. This is expressed as ?in
addition? to the first sentence which contains the releases of the employer. As noted in
the
Cass text relied upon by grievor?s counsel, it is not at all unusual, or unenforceable,
for parties to a settlement to include issues going beyond the specific dispute which
would have been litigated if the settlement had not occurred. It is not necessary to decide
what would have been the outcome if the grievor had tried to include compensation for
defamation in his claims at a hearing before the Board. It is only necessary to emphasize
that the grievor settled more than the claim for wrongful dismissal that he made in the
grievance filed. See, in a similar vein, the GSB?s decision in Clarke, cited above. This is
not a matter of implying language into the settlement document; it is a matter of giving
effect to the plain meaning of the words ?any and all matters relating to the grievor?s past
employment? and ?exhaustive of all possible entitlements?.
[16]In sum, given the broad language of the Minutes of Settlement, I find the civil suit to be a
breach of the Minutes of Settlement, as it treats matters relating to the grievor?s past
employment as unresolved, and deserving of further damages, when the settlement, on its
face, was a full and final resolution of all matters relating to the grievor?s past
11
employment. Simply put, continuing to litigate issues related to his previous employment
with the Ministry is not compatible with the Minutes of Settlement the grievor signed.
[17]Further, the lawsuit relates to matters which were outstanding at the time of Mr.
Antoncic?s termination and the Minutes of Settlement, and known to the grievor, as
evidenced by his communications to the employer and the Board prior to his signing of
the settlement . Although written after the signing of the Minutes of settlement, the
grievor?s October 27, 2008 letter to Minister Bartolucci, makes this even more
abundantly clear in the grievor?s own words:
As a direct consequence of my dismissal, I commenced a civil action for
defamation against two (2) Ministry employees (Court File No. 07-35577)
in the Ontario Superior Court of Justice (Hamilton) filed on December 20,
2007.
During my employment and in the capacity of managing the Employee
Relations Unit, I had direct, ?first person? and detailed knowledge of the
Ministry?s behaviour in respect of the various matters which ultimately led
to my termination and which caused me to bring the civil action.
[18]The above is a sufficient basis on which to issue the declaration requested by the
employer that the grievor has breached the Minutes of Settlement. However, in
deference to some of the other arguments made, I will address a number of them.
Although not determinative, given the broad wording of the recitals in the Minutes of
Settlement, it is important to underline that there is no lack of privity of contract or
consideration before me, as the party seeking a remedy for the breach is the employer in
its own right, not as a representative for the defendants to the lawsuit. The employer
argues on its own behalf that it bought and paid for a full settlement of all issues related
to the grievor?s employment. The terms of paragraphs 3 and 12 read together make it
clear that the monetary consideration given was to extinguish all possible entitlement
flowing from Mr. Antoncic?s employment. Further, as noted by Madam Justice Swinton
12
inDisher v. Kowal, cited above, although in the context of a claim of a breach of the rule
as to implied undertakings, the effects of lawsuits against employees who provide
information to employers are not limited to the specific outcome for those individuals in
Court. Other results for the employer include a potential chilling effect among
employees flowing from the use of such information as a basis to sue, leading to
difficulty in conducting effective workplace investigations, as well as disruption to the
employer?s operations flowing from the inevitable involvement of employees in the
lawsuit, as many aspects of the grievor?s employment would be re-examined. In the
matter before me and the employment context of this Ministry, it is clear that these
effects are of serious concern.
[19]Further, I note that the Morgandecision, cited above, relied on by grievor?s counsel
concerning the release clause, is distinguishable, in that the decision does not indicate a
context of such broad language concerning what was settled as appears in the Minutes of
Settlement in issue before me. Nor did it include a sentence such as the second sentence
of paragraph 12 of the Minutes of Settlement to the effect that the monetary payment
accepted by the grievor was in lieu of any head of damages under statute or common law.
The release language in the Minutes of Settlement before me is an integral part of the
document; it is not a separate document, and this second sentence of paragraph 12 is not
restricted to damages claimed against the Crown or the Ministry specifically. In this
respect, the ordinary, clear meaning of the words ?in addition? is something more than
what went before, i.e. the specific release of the employer and the Crown. As well, a
reading of the Minutes of Settlement in Morgan lead the trial judge to assume that the
plaintiff had been wrongfully dismissed, an interpretation not available on the wording of
13
the settlement signed by Mr. Antoncic, given its explicit expression of being without
prejudice and including no admission of liability on either side.
[20]In regards to the specific paragraphs of the Minutes of Settlement alleged to be breached,
I find that the evidence supports the employer?s allegations, with the exception of the
allegation of a breach of paragraph 10, relating to the return of the materials disclosed to
counsel. I agree with grievor?s counsel that the evidence does not establish that no
instruction was given, or that the materials were not returned as detailed therein.
Nonetheless, there remains a question which the parties agreed to defer until the remedial
phase of this matter, if necessary, as to the manner in which the grievor obtained access
to notes of the workplace investigator and whether his retention and use of such
information should attract a specific remedy.
[21]Concerning paragraph 7, agreed by its terms to be a ?vital term and condition? of the
settlement, the evidence supports a finding that it was breached by the launching of the
civil suit. Grievor?s counsel argued that the information necessary to the lawsuit should
not be considered to be obtained during the course of his employment, as defamation was
not part of his job. I am unpersuaded by this argument, when it is clear that the facts of
which Mr. Antoncic complains came to him as a result of his job as staff relations
manager, including his participation in the procedures flowing from the complaint lodged
against him by the released employee. In his own letter of October 27, 2008, the grievor
acknowledges that he obtained the information leading to the lawsuit ?in the capacity of
managing the Employee Relations Unit?. In this regard, I do not find the situation
analogous to the facts in Consolidated Mining, cited above, relied on by grievor?s
counsel, where two workmen were found not to be in the course of their employment
14
when they caused damage by letting a cooking fire escape, when they had not been
employed to set cooking fires. More generally, whether or not the allegations against him
were true or false, (and therefore capable at law of being considered defamatory), or
sufficient to justify the grievor?s discharge, were issues that would have been at the heart
of the litigation of the grievance, which both parties chose to avoid by executing the
Minutes of Settlement.
[22]The other argument relating to paragraph 7 advanced on behalf of the grievor was that its
wording was overbroad, and should not be interpreted to mean every piece of information
that was obtained during a time period coincident with his former employment. There
may be matters, for example information exchanged among employees unrelated to
Ministry business, which ought not to be included in the scope of the information the
grievor is required to keep confidential by the Minutes of Settlement. However, it would
be a serious undermining of the parties? agreement to say that paragraph 7 does not
include information such as the central facts at issue in the grievance itself, many of
which are pleaded in the Statement of Claim. In this regard, perhaps it bears specifying
that the information concerning possible conflicts of interest or personal animus for an
action within the grievor?s job such as releasing a probationary employee are very much
related to the course of his employment and thus included in what is covered by
paragraph 7.
[23]As to paragraph 9, the mutual non-disparagement portion of the settlement, grievor?s
counsel submits that the portion of the statement of claim which states that the grievor
was wrongfully dismissed cannot be considered disparagement, as it is just a legal
conclusion. Counsel submits that because Mr. Antoncic was dismissed without notice,
15
and there is no acknowledgment of any wrongdoing on either party?s part, he is free to
continue to maintain that he was dismissed without cause. Further, relying on Razzell v.
Edmonton Mint Ltd.[1981] 4 W.W.R. 5, counsel argues that there is absolute privilege
for statements made in pleadings, such that the statements should not be considered
disparaging, which counsel asserts means defamatory. In
Razzell, the court found that a
statement of claim alleging publication of defamatory material in another statement of
claim, as well as in an examination for discovery, disclosed no cause of action as the
context of the publication constituted an occasion of absolute privilege. Employer
counsel replied to this argument, emphasizing the mutual promises of non-disparagement,
as well as the statements in Mr. Antoncic?s letters to the Minister and the Attorney-
General making it clear that he intended to criticize and embarrass the employer in the
information he would elicit in the lawsuit.
[24]In my view, the ordinary meaning of the word disparagement does not require that a
statement meet the legal test for defamation. Further, the Ministry is not claiming that
the statements made in the Statement of Claim constitute the actionable tort of
defamation. Rather it is claimed that the allegations in the Statement of Claim, for
instance, paragraph 14?s statement that the Ministry relied on an erroneous investigation
report in order to wrongfully terminate Mr. Antoncic, are disparaging in the sense of
critical or disapproving, and thus breaches paragraph 12 of the Minutes of Settlement. In
these circumstances, I do not see this as a situation to which the discussion of privilege in
the context of suits for defamation discussed in Razzell applies. Moreover, and more
germane to this decision, the decision in Razzelldoes not stand for the proposition that,
having agreed by contract, for consideration, not to disparage the employer, Mr. Antoncic
may do so with impunity, so long as he does so in statements of claim. Further, I find
16
the statement in paragraph 14 to be disparaging of the employer in the ordinary, rather
than tortious, sense of the word. Moreover, I am not persuaded that the language, to
which Mr. Antoncic voluntarily agreed, is so broad as to constitute an improper limit on
his freedom of speech.
[25]As to paragraph 12, I also find it to have been breached in that the statement of claim is
incompatible with the second sentence which, as noted above, acknowledges that the
consideration provided is exhaustive of all possible entitlements, including common law
damages. In this regard, I note that the Cass text relied on by the grievor, supports the
interpretation of the document as a whole, in light of the purpose recited therein. In this
respect, the second sentence, about which more has been said above, reflects the recital
that the specific terms represent ?full and final resolution of all claims and matters
regarding the Grievor?s past employment.?. In this context, it is not necessary to have
any particular release language to make the lawsuit against the employees a breach of the
settlement with the employer.
***
[26]To summarize, for the reasons set out above, the employer?s request for a declaration that
the grievor has breached the Minutes of Settlement is hereby granted. I remain seized to
deal with the remedial aspects of the matter if the parties are unable to resolve them on
their own. Either party may request dates of the Registrar to reconvene the matter when
so advised.
th
Dated at Toronto this 6 day of January 2009.
Kathleen O?Neil, Vice-Chair