THE QUEEN'S BENCH Winnipeg Centre. MARLENE BILES and SHAWNA PAULSEN, - and - AMENDED STATEMENT OF CLAIM
|
|
- Erik Peters
- 6 years ago
- Views:
Transcription
1 File No. CI THE QUEEN'S BENCH Winnipeg Centre BETWEEN: MARLENE BILES and SHAWNA PAULSEN, plaintiffs, - and - MUNICIPALITY OF OAKLAND-WAWANESA, defendant. AMENDED STATEMENT OF CLAIM TAYLOR McCAFFREY LLP Barristers and Solicitors 9th Floor St. Mary Avenue Winnipeg, Manitoba R3C 4K5 JEFFREY J. PALAMAR. Tel Fax jpalamar@tmlawyers.com Client File No
2 THE QUEEN'S BENCH Winnipeg Centre BETWEEN: MARLENE BILES and SHAWNA PAULSEN, plaintiffs, - and - MUNICIPALITY OF OAKLAND-WAWANESA, defendant. AMENDED STATEMENT OF CLAIM TO THE DEFENDANT A LEGAL PROCEEDING HAS BEEN COMMENCED AGAINST YOU by the plaintiffs. The claim made against you is set out in the following pages. IF YOU WISH TO DEFEND THIS PROCEEDING, you or a Manitoba lawyer acting for you must prepare a statement of defence in Form 18A prescribed by the Queen's Bench Rules, serve it on the plaintiffs' lawyer or, where the plaintiffs do not have a lawyer, serve it on the plaintiffs, and file it in this court office, WITHIN 20 DAYS after this statement of claim is served on you, if you are served in Manitoba. If you are served in another province or territory of Canada or in the United States of America, the period for serving and filing your statement of defence is 40 days. If you are served outside Canada and the United States of America, the period is 60 days.
3 2 IF YOU FAIL TO DEFEND THIS PROCEEDING, JUDGMENT MAY BE GIVEN AGAINST YOU IN YOUR ABSENCE AND WITHOUT FURTHER NOTICE TO YOU. IF YOU PAY THE PLAINTIFFS' CLAIM, and $750 for costs, within the time for serving and filing your statement of defence, you may move to have this proceeding dismissed by the court. If you believe the amount claimed for costs is excessive, you may pay the plaintiffs' claim and $750 for costs and have the costs assessed by the court. July 13, ( Signed by L.C I C Deputy Registrar 100C York Avenue Winnipeg, Manitoba R3C OP9 TO: Municipality of Oakland-Wawanesa, c/o Greg Tramley McCandless Tramley 668 Corydon Avenue Winnipeg, MB, R3M 0X7 Solicitors for Municipality of Oakland-Wawanesa rt- 1-.) - J. LONSDALE DEPUTY REGISTRAR COURT OF QUIN'S BENCH FOR MAN1TOBA
4 3 CLAIM 1. (a) (b) (c) (d) (e) (f) (g) (h) The plaintiffs claim against the defendant, the following: a declaration that they have been wrongfully dismissed; general damages for the wrongful dismissal of the plaintiff Shawna Paulsen ("Paulsen") and general damages for infliction of mental distress, loss of reputation and loss or damage to career and employment opportunities in respect of both plaintiffs; special damages to be quantified at the trial of this action, including expenses incurred in mitigation; punitive, aggravated and/or exemplary damages; pre-judgment interest; post-judgment interest; solicitor and client costs; and such further and other relief as this Honourable Court may deem just. 2. The plaintiff Marlene Biles ("Biles") is an administrator and resides in the Municipality of Oakland-Wawanesa, Manitoba. 3. The plaintiff Shawna Paulsen ("Paulsen") Paulsen is an administrator and resides in the Municipality of Grasslands, Manitoba. 4. The defendant is a municipality pursuant to the laws of Manitoba. 5. At all material times, Morley Dennis Rome ("Rome") has been and remains an elected municipal council member of the defendant and his actions were either actually on behalf of the defendant, or would reasonably be seen as being on behalf of the defendant. 6. of Rome. At all material times the defendant was legally responsible for the actions 7. In or about June 1999, and pursuant to an agreement with the defendant, made orally, by the actions of the parties, in writing and through implication of law (the "CAO Employment Contract") Biles commenced employment with it as its Chief Administrative Officer. It was an express or implied term of the CAO Employment Contract, and in the contemplation of the parties at the time the CAO Employment Contract was entered, that inter alia: (a) (b) (c) the CAO Employment Contract would be for an indefinite duration; at all times the defendant would provide a safe and respectful workplace, and ensure that Biles was free from workplace violence, harassment and bullying; the defendant could only terminate Biles' employment:
5 4 (d) (e) (f) i) for just cause; or ii) with reasonable notice or pay in lieu; as of June 2014, reasonable notice became defined as follows: Council of the Municipality may terminate the employment of the CAO at any time before January 1, 2019 without just cause by providing the CAO with 5 months' written notice of termination of this agreement ("additional notice/pay") together with 1 month's written notice for each year of employment, or payment of 5 months' base salary together with 1 month's base salary for each year of employment in lieu of such notice. The CAO shall also be entitled to receive the Municipality's portion of any municipal pension benefit and Health Care Spending Account contributions that would have been contributed by the Municipality in respect of this period and the retirement severance to be paid to retiring employees as set out in and calculated in accordance with section 8 of the non-unionized staff agreement. After January 1, 2019, the CAO will not be entitled to the additional notice/pay; if the defendant terminated the CAO Employment Contract in a manner not in accordance with these conditions, or otherwise did not act in good faith with respect to Biles, her employment and/or its termination, the defendant would compensate Biles for all damages suffered, including inter alia mental distress, loss of reputation and lost or damaged career and employment opportunities suffered by Biles; and Biles would be paid as compensation for her work an annual salary (which as of January 1, 2016 was $73,732.55) and also enjoyed coverage in a group insurance plan and pension offered by the defendant. 8. In or about May 2012 and pursuant to an agreement with the defendant, made orally, by the actions of the parties and through implication of law (the "ACAO Employment Contract") Paulsen commenced employment with it as its Assistant Chief Administrative Officer. It was an express or implied term of the ACAO Employment Contract, and in the contemplation of the parties at the time the Employment Contract was entered, that inter alia: (a) (b) (c) (d) the ACAO Employment Contract would be for an indefinite duration; at all times the defendant would provide a safe and respectful workplace, and ensure that Paulsen was free from workplace violence, harassment and bullying; the defendant could only terminate Paulsen's employment: i) for just cause; or ii) with reasonable notice or pay in lieu; if the defendant terminated the ACAO Employment Contract in a manner not in accordance with these conditions, or otherwise did not act in good
6 -5 (e) faith with respect to Paulsen, her employment and/or its termination, the defendant would compensate Paulsen for all damages suffered, including inter alia mental distress, loss of reputation and lost or damaged career and employment opportunities suffered by Paulsen; and Paulsen would be paid as compensation for her work an annual salary (which as of January 1, 2016 was $52,012.50) and also enjoyed coverage in a group insurance plan and pension offered by the defendant. 9. Further, or in the alternative, the defendant as an employer owed a duty to Biles and Paulsen as its employees, independent of the contractual relations: (a) (b) (c) (d) to take reasonable care not to act in a manner which could cause Biles or Paulsen to suffer mental distress, loss of reputation, and loss or damage to career and employment opportunities; not to willingly or recklessly, with disregard as to whether or not damage would ensue, act so as to cause Biles or Paulsen harm, including mental distress, loss of reputation and loss or damage to career and employment opportunities; to at all times provide a safe and respectful workplace, and ensure that Biles and Paulsen were free from workplace violence, harassment and bullying; and to act in good faith with respect to Biles and Paulsen, their employment and/or its termination. 10. The defendant owed further duties to Biles and Paulsen pursuant to a Council Code of Conduct policy dated on or about February 11, 2015, which stated in part that: In carrying out the duties, members of the Council of the Municipality of Oakland-Wawanesa are expected to conduct themselves in such a way as to promote public trust and public confidence in the Council and the municipality... Every member of Council is expected to conduct himself or herself in public, and in respect to the public, in such a way as to reflect the decorum and dignity of the office that he or she holds. No member of Council shall intimidate or threaten his or her colleagues, members of the public, or employees or volunteers of the municipality. 11. Throughout the course of their employment, Biles and Paulsen proved themselves to be valuable and reliable employees, and performed their duties faithfully, diligently and in a highly competent manner.
7 6 12. Starting in or about April of 2015 and continuing thereafter, Rome engaged in a course of conduct that either was intended or if unintended would reasonably be expected to have the result of causing the plaintiffs harm and driving them out of the workforce. This conduct included inter alia a series of public, inappropriate and defamatory communications to and/or about the plaintiffs, which have been humiliating and embarrassing to the plaintiffs, damaged the plaintiffs' sense of self-worth and selfesteem and poisoned the work environment. 13. In recognition of such wrongdoing, in or about August 2015 the defendant passed a resolution (the "Resolution") which stated as follows: WHEREAS Council of the Municipality of Oakland-Wawanesa adopted a Council Code of Conduct policy on February 11, 2015; AND WHEREAS Council values and respects their employees and volunteers, and the work that they do; AND WHEREAS Council values the working relationships and respect of the suppliers and contractors of the Corporation; AND WHEREAS Council has received complaints from employees and volunteers of the corporation in respect to the conduct, comments and actions of Councillor Morley Dennis Rome towards these individuals; AND WHEREAS Council has concerns regarding the conduct and interactions with suppliers and contractors of the corporation by Councillor Morley Dennis Rome; THEREFORE BE IT RESOLVED that Councillor Morley Dennis Rome is hereby prohibited from: 1. Personal contact (phone or in person), including the sending of s and text messages to employees and volunteers of the Municipality of Oakland- Wawanesa; 2. Personal contact (phone or in person), including the sending of s and text messages to suppliers and contractors of the Municipality of Oakland-Wawanesa; and 3. Posting municipal related topics on social media sites (ebrandon, Twitter, Facebook, etc.). AND FURTHER BE IT RESOLVED that Councillor Morley Dennis Rome is hereby required to direct all comments, concerns and requests for municipal information, in writing, to Head of Council David B. Inkster, which will then be brought forward to the next regular meeting of council and dealt with by the entire council. 14. Despite and in breach of the Resolution, and despite the repeated efforts of the plaintiffs both to have Rome cease and desist and the defendant to cause Rome to cease and desist, Rome has continued his actions and the defendant has failed to cause Rome to cease and desist. The plaintiffs state that accordingly, the defendant has breached the obligations and duties owed to them as set out in this Claim, and is liable both for such breach and also as a result of the consequent constructive dismissal.
8 7 15. In or about January, 2017 the defendant provided payment to or on behalf of Biles of those moneys required to be paid to her as pay in lieu of reasonable notice as required by the CAO Employment Contract. Accordingly, while Biles was wrongfully dismissed the defendant has subsequently compensated Biles for failing to provide reasonable notice or pay in lieu and Biles no longer has a claim for that As a result of the defendant's conduct and breach of contract, the plaintiffs have suffered and continue to suffer damages in respect of loss of income, loss of reputation, lost or damaged career and employment opportunities and mental distress. Further, the plaintiffs have been injured in their credit, character and reputation. 17. As a result of the defendant's conduct and breach of contract, Paulsen has suffered and continues to suffer damages in respect of loss of income As a further result of the defendant's conduct and breach of contract, the plaintiffs have incurred and will continue to incur various out-of-pocket expenses in attempts to mitigate damages. July 13, 2016 TAYLOR McCAFFREY LLP Barristers and Solicitors, 9th Floor St. Mary Ave., Winnipeg, Manitoba R3C 4K5 JEFFREY J. PALAMAR Tel
THE QUEEN S BENCH Winnipeg Centre. - and - HEATHER BUSH and GEORGE BUSH STATEMENT OF CLAIM. MARTIN GREEN 147 West Gate Winnipeg, Manitoba R3C 2E2
QB File No. THE QUEEN S BENCH Winnipeg Centre BETWEEN: MARTIN GREEN, plaintiff, - and - HEATHER BUSH and GEORGE BUSH defendants. STATEMENT OF CLAIM MARTIN GREEN 147 West Gate Winnipeg, Manitoba R3C 2E2
More informationONTARIO SUPERIOR COURT OF JUSTICE. and
B E T W E E N: ONTARIO SUPERIOR COURT OF JUSTICE Court File No. TSI INTERNATIONAL CANADA INC. Plaintiff and THE CORPORATION OF THE TOWN OF MILTON, GORDON KRANTZ, WILLIAM F. MANN aka BILL MANN, and BARBARA
More informationIN THE COURT OF APPEAL
File No: CI 12-01-77146 IN THE COURT OF APPEAL BETWEEN: An intended appeal of the Plaintiffs from the decision of the Honourable Justice R. Dewar of the Manitoba Court of Queen s Bench dated December 31,
More informationONTARIO SUPERIOR COURT OF JUSTICE CHRIS AVENIR. and RYERSON UNIVERSITY STATEMENT OF CLAIM
ONTARIO SUPERIOR COURT OF JUSTICE Court File No. BETWEEN: (Court Seal) CHRIS AVENIR Plaintiff and RYERSON UNIVERSITY Defendant Proceedings under the Class Proceedings Act, 1992 TO THE DEFENDANT(S) STATEMENT
More informationContract and Tort Law for Engineers
Contract and Tort Law for Engineers Christian S. Tacit Tel: 613-599-5345 Email: ctacit@tacitlaw.com Canadian Systems of Law There are two systems of law that operate in Canada Common Law and Civil Law
More informationCanadian Systems of Law Contract and Tort Law for Professionals There are two systems of law that operate in Canada: Common Law and Civil Law.
Canadian Systems of Law Contract and Tort Law for Professionals There are two systems of law that operate in Canada: Common Law and Civil Law. Common Law operates in all Canadian Provinces and territories
More informationcv 1S~'S~V I&~ Court File No.
cv 1S~'S~V I&~ Court File No. ONTARIO SUPERIOR COURT OF JUSTICE BETWEEN: (Court seal) METROPOLITAN TORONTO CONDOMINIUM CORPORATION NO. 933 Plaintiff - and- ICC PROPERTY MANAGEMENT LTD., and MASSIMO MUSSO
More informationIN THE SUPREME COURT OF BRITISH COLUMBIA
File no: Victoria Registry IN THE SUPREME COURT OF BRITISH COLUMBIA BETWEEN: JANE RENAUD Plaintiff AND HSBC INVESTMENTS (CANADA) LIMITED Defendant Brought pursuant to the Class Proceedings Act (R.S.B.C.,
More informationIN THE COURT OF QUEEN S BENCH OF ALBERTA JUDICIAL DISTRICT OF CALGARY PLAINTIFFNAME. - and - DEFCONTRACTORNAME. And DEFENDANTOWNERNAME
Action No: BETWEEN: IN THE COURT OF QUEEN S BENCH OF ALBERTA JUDICIAL DISTRICT OF CALGARY PLAINTIFFNAME Plaintiff - and - DEFCONTRACTORNAME And DEFENDANTOWNERNAME Defendants STATEMENT OF CLAIM 1. PLAINTIFFNAME,
More informationPOLICY MANUAL PART ONE INTRODUCTION AND INTERPRETATION OF POLICY. The interpretation of the Code of Conduct will be at the discretion of the Council.
POLICY MANUAL Legal References: Municipal Government Act Freedom of Information and Protection of Privacy Act Local Authorities Election Act Cross References: Procedural Bylaw 3001 Policy department: Council
More informationEXPROPRIATION ACT RULES OF PROCEDURE AND PRACTICE
Province of Alberta EXPROPRIATION ACT EXPROPRIATION ACT RULES OF PROCEDURE AND PRACTICE Alberta Regulation 187/2001 With amendments up to and including Alberta Regulation 181/2015 Office Consolidation
More informationTHE QUEEN'S BENCH WINNIPEG CENTRE. APPLICATION UNDER Queens Bench Rule 14.05(2)(c)(iv) WESTERN CANADA WILDERNESS COMMITTEE, - and -
File No. CI 11-01-72733 THE QUEEN'S BENCH WINNIPEG CENTRE APPLICATION UNDER Queens Bench Rule 14.05(2)(c)(iv) BETWEEN: WESTERN CANADA WILDERNESS COMMITTEE, Applicant, - and - THE GOVERNMENT OF MANITOBA,
More informationC-451 Workplace Psychological Harassment Prevention Act
Proposed Canadian National Law C-451 Workplace Psychological Harassment Prevention Act Second Session, Thirty-seventh Parliament, 51-52 Elizabeth II, 2002-2003 An Act to prevent psychological harassment
More informationJ)NTAR/0 YEGALROSEN. -and- BMO NESBITT BURNS INC. FRESH AS AMENDED STATEMENT OF CLAIM
PURSUANT TO CONFORM~MENT A J)NTAR/0 UPERIEURE D~OR COURT OF JUSTICE FFI A LOCAL Court File No. CV-10-39668500CP YEGALROSEN Plaintiff -and- BMO NESBITT BURNS INC. Defendant Proceeding under the Class Proceedings
More informationdays. If you are served outside Canada and the United States of America, the period is sixty days.
Court File No. SUPERIOR COURT OF JUSTICE DARA FRESCO Plaintiff -and - CANADIAN IMPERIAL BANK OF COMMERCE Defendant PROCEEDING UNDER THE CLASS PROCEEDINGS ACT, 1992 TO THE DEFENDANT STATEMENT OF CLAIM A
More informationTORT LAW. By Helen Jordan, Elaine Martinez, and Jim Ponce
TORT LAW By Helen Jordan, Elaine Martinez, and Jim Ponce INTRO TO TORT LAW: WHY? What is a tort? A tort is a violation of a person s protected interests (personal safety or property) Civil, not criminal
More informationPRACTICE REVIEW OF TEACHERS REGULATION
Province of Alberta SCHOOL ACT PRACTICE REVIEW OF TEACHERS REGULATION Alberta Regulation 11/2010 Extract Published by Alberta Queen s Printer Alberta Queen s Printer 7 th Floor, Park Plaza 10611-98 Avenue
More informationCOURT OF QUEEN S BENCH OF MANITOBA
Date: 20181121 Docket: CI 16-01-04438 (Winnipeg Centre) Indexed as: Shirritt-Beaumont v. Frontier School Division Cited as: 2018 MBQB 177 COURT OF QUEEN S BENCH OF MANITOBA BETWEEN: ) APPEARANCES: ) RAYMOND
More informationSUPERIOR COURT OF JUSTICE STATEMENT OF CLAIM
B E T W E E N: SUPERIOR COURT OF JUSTICE Court File No.: HENVEY INLET FIRST NATION as represented by its duly elected Chief and Council - and - STACY MCQUABBIE and JACKIE PEARCE Plaintiff Defendants STATEMENT
More informationIN THE QUEEN'S BENCH JUDICIAL CENTRE OF REGINA. -and-
..,. ~ I CANADA ) PROVINCE OF SASKATCHEWAN ) } ()7 Q.B.G. No. ------'-'------- IN THE QUEEN'S BENCH JUDICIAL CENTRE OF REGINA Between: NICOLE BRITTIN -and- PLAINTIFF THE MINSTER OF HUMAN RESOURCES AND
More informationPRECIS OF THE REPORT INTO THE DISMISSAL OF DEPUTY HEADMASTER, ROHAN BROWN
PRECIS OF THE REPORT INTO THE DISMISSAL OF DEPUTY HEADMASTER, ROHAN BROWN This precis summarises the principal parts of the report submitted by Mr Ray Finkelstein AO QC and Ms Renee Enbom. For a number
More informationPROTECTION FOR PERSONS IN CARE ACT
Province of Alberta Statutes of Alberta, Current as of February 20, 2015 Office Consolidation Published by Alberta Queen s Printer Queen s Printer Bookstore Suite 700, Park Plaza 10611-98 Avenue Edmonton,
More informationAccountancy Scheme Sanctions Guidance
Guidance Financial Reporting Council April 2018 Accountancy Scheme Sanctions Guidance The FRC s mission is to promote transparency and integrity in business. The FRC sets the UK Corporate Governance and
More informationCONSENT. DATED at the of, in the Province of (City or Town) (name of City/Town) Saskatchewan, this day of, 20. Signature of Solicitor {
CONSENT I,, of acknowledge (Name) (Name of Law Firm) and consent to the Assessment of my attached account dated in the amount of, by the Local Registrar of the Court of Queen s Bench, Judicial Centre of,
More informationREAL ESTATE. Complaints and Investigation Procedures COVERING:
REAL ESTATE Complaints and Investigation Procedures COVERING: Residential Homes Rural Real Estate Condominiums New Home Sales Commercial Real Estate Property Management REAL ESTATE The Manitoba Securities
More informationIngles v. The Corporation of the City of Toronto Decision of the Supreme Court of Canada dated March 2, 2000
Ingles v. The Corporation of the City of Toronto Decision of the Supreme Court of Canada dated March 2, 2000 (City Council at its regular meeting held on October 3, 4 and 5, 2000, and its Special Meetings
More informationForm 5-6. (Subrule 5-6(1)) COURT FILE NUMBER JUDICIAL CENTRE PLAINTIFF(S) DEFENDANT(S) AFFIDAVIT OF DOCUMENTS. Affidavit of Documents of
Form 5-6 (Subrule 5-6(1)) COURT FILE NUMBER COURT OF QUEEN S BENCH FOR SASKATCHEWAN JUDICIAL CENTRE PLAINTIFF(S) DEFENDANT(S) AFFIDAVIT OF DOCUMENTS Affidavit of Documents of (name and status) Sworn (or
More informationONTARIO SUPERIOR COURT OF JUSTICE DAVID CARMICHAEL. -and-
(1fl ~ I CJ~!fl%'1( Court File No. ONTARIO SUPERIOR COURT OF JUSTICE DAVID CARMICHAEL -and- Plaintiff VIA RAIL CANADA INC., CANADIAN NATIONAL RAILWAY COMPANY, and CANADIAN PACIFIC RAILWAY COMPANY Defendants
More informationPublic Guardian and Trustee of Manitoba COMMITTEESHIP. A Guidebook for Court Appointed Committees
Public Guardian and Trustee of Manitoba COMMITTEESHIP A Guidebook for Court Appointed Committees Prepared by: The Public Guardian and Trustee of Manitoba 155 Carlton Street - Suite 500 Winnipeg MB R3C
More informationONTARIO SUPERIOR COURT OF JUSTICE COMMERCIAL LIST. IN THE MATTER OF THE COMPANIES CREDITORS ARRANGEMENT ACT, R.S.C. 1985, c.
Court File No. CV-12-9545-00CL ONTARIO SUPERIOR COURT OF JUSTICE COMMERCIAL LIST IN THE MATTER OF THE COMPANIES CREDITORS ARRANGEMENT ACT, R.S.C. 1985, c. C-36, AS AMENDED AND IN THE MATTER OF A PLAN OF
More informationSTATEMENT OF DEFENCE
ONTARIO SUPERIOR COURT OF JUSTICE Court File No.: CV-17-578059-00CP B E T W E E N: ROBIN CIRILLO Plaintiff - and - HER MAJESTY THE QUEEN IN RIGHT OF THE PROVINCE OF ONTARIO Defendant Proceedings under
More informationREGISTRAR, LOBBYISTS ACT OFFICE OF THE ETHICS COMMISSIONER PROVINCE OF ALBERTA
REGISTRAR, LOBBYISTS ACT OFFICE OF THE ETHICS COMMISSIONER PROVINCE OF ALBERTA February 1, 2008 TABLE OF CONTENTS INTRODUCTION... 1 TYPES OF LOBBYISTS... 1 1. Organization Lobbyist... 1 2. Consultant Lobbyist...
More informationBEFORE THE COMMISSION ON JUDICIAL CONDUCT OF THE STATE OF WASHINGTON
BEFORE THE COMMISSION ON JUDICIAL CONDUCT OF THE STATE OF WASHINGTON In Re the Matter of: The Honorable Douglass A. North Judge of the King County Superior Court CJCNo. 8583-F-174 STIPULATION, AGREEMENT
More informationPLAINTIFF S ORIGINAL PETITION
FILED 2/4/2019 9:59 AM Mary Angie Garcia Bexar County District Clerk Accepted By: Victoria Angeles 2019CI02190 CAUSE NO.: DEREK ROTHSCHILD IN THE DISTRICT COURT as Next Friend of D.R. v. BEXAR COUNTY,
More informationCase3:05-cv WHA Document1 Filed02/14/05 Page1 of 5
Case:0-cv-00-WHA Document Filed0//0 Page of Wayne Johnson, SBN: Law Offices of Wayne Johnson P.O. Box 0 Oakland, CA 0 (0) - Attorney for Plaintiffs 0 LYNART COLLINS, UNITED STATES DISTRICT COURT NORTHERN
More informationIN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO
IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO ) MARY ADDI ) CASE NO. 11040 Indian Hollow Road ) Elyria, Ohio 44035, ) JUDGE In Pro Se ) ) Plaintiff, ) ) COMPLAINT vs. ) ) HORIZON SCIENCE ACADEMY )
More informationFILED: KINGS COUNTY CLERK 09/03/ :48 PM INDEX NO /2014 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/04/2014
FILED: KINGS COUNTY CLERK 09/03/2014 09:48 PM INDEX NO. 508086/2014 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/04/2014 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS MICHAEL KRAMER, Plaintiff, -against-
More informationAPPLICATION FOR ADMISSION AS A CANADIAN LEGAL ADVISOR
App5 THE LAW SOCIETY OF MANITOBA APPLICATION FOR ADMISSION AS A CANADIAN LEGAL ADVISOR In order to initiate the process of admission to The Law Society of Manitoba as a Canadian Legal Advisor on the basis
More informationONTARIO SUPERIOR COURT OF JUSTICE
Court File No.: ONTARIO SUPERIOR COURT OF JUSTICE BETWEEN: PHOENIX HOSPITALITY (BANANAS) INC., PHOENIX HOSPITALITY (COPA) INC., PHOENIX HOSPITALITY (DARD) INC. and BANANAS BEACH BAR INC. - and - Plaintiffs
More informationIN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT KANSAS CITY PETITION
JANE DOE, v. IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT KANSAS CITY Plaintiff, YAHKHAHNAHN AMMI, Serve at: 9821 E 60th Street #7 Kansas City, MO 64133 Defendant. PETITION Case No. Division JURY
More informationEXPROPRIATION ACT FORMS REGULATION
Province of Alberta EXPROPRIATION ACT EXPROPRIATION ACT FORMS REGULATION Alberta Regulation 188/2001 With amendments up to and including Alberta Regulation 177/2017 Office Consolidation Published by Alberta
More information- 4 - APPLICABILITY OF ARBITRATIONS ACT, 1991
www.barryfisher.ca - 2 - INTRODUCTION Up until very recently it was assumed that the only way in which a non-unionized employee could have his or her employment dispute adjudicated upon was either before
More informationSUPREME COURT OF VICTORIA. CREESE v HAMILTON-BYRNE (S CI ) IMPORTANT NOTICE GROUP PROCEEDING REGARDING ANNE
SUPREME COURT OF VICTORIA CREESE v HAMILTON-BYRNE (S CI 2017 03007) IMPORTANT NOTICE GROUP PROCEEDING REGARDING ANNE HAMILTON-BYRNE On 1 August 2017, Leeanne Joy Creese (the plaintiff) commenced this group
More informationAdapted Bylaws pursuant to the Prevention of Sexual Harassment Law,
Adapted Bylaws pursuant to the Prevention of Sexual Harassment Law, 5758-1998 Sexual harassment and intimidation against a sexual background violate a person s dignity, liberty, privacy and equality between
More informationTHE GENERAL ASSEMBLY OF PENNSYLVANIA HOUSE BILL
PRINTER'S NO. 1 THE GENERAL ASSEMBLY OF PENNSYLVANIA HOUSE BILL No. Session of 01 INTRODUCED BY COHEN, BISHOP, V. BROWN, CALTAGIRONE, P. DALEY, HARKINS, KORTZ, MAHONEY, MOLCHANY, O'BRIEN AND THOMAS, APRIL
More informationONTARIO SUPERIOR COURT OF JUSTICE. - and -
Court File No./N du dossier du greffe: CV-18-00603521-0000 Court File No. Electronically issued Délivré par voie électronique : 17-Aug-2018 Toronto B E T W E E N: ONTARIO SUPERIOR COURT OF JUSTICE MARC
More informationLISTING PROCEDURE FOR SUMMARY CRIMINAL TRIALS
Local Court of New South Wales PRACTICE NOTE NO. 7 of 2007 ISSUED: 9 November 2007 LISTING PROCEDURE F SUMMARY CRIMINAL TRIALS This Practice Note applies where a plea of not guilty is entered in respect
More informationAPR/05/2012/THU 05:29PM DIGI FAX No P. 002
APR/05/2012/THU 05:29PM DIGI FAX No. 416-628-5051 P. 002 ONTARIO c_ v~ l ~- 45
More informationFAMILY SUPPORT FOR CHILDREN WITH DISABILITIES ACT
Province of Alberta Statutes of Alberta, 2003 Current as of December 9, 2016 Office Consolidation Published by Alberta Queen s Printer Alberta Queen s Printer 7 th Floor, Park Plaza 10611-98 Avenue Edmonton,
More informationFEES AND EXPENSES FOR WITNESSES AND INTERPRETERS REGULATION
Province of Alberta COURT OF APPEAL ACT COURT OF QUEEN S BENCH ACT PROVINCIAL COURT ACT FEES AND EXPENSES FOR WITNESSES AND INTERPRETERS REGULATION Alberta Regulation 123/1984 With amendments up to and
More informationIN THE SUPERIOR COURT OF DISTRICT OF COLUMBIA CIVIL DIVISION * * * * * * * * * * * * * * * * * * * * * * *
IN THE SUPERIOR COURT OF DISTRICT OF COLUMBIA CIVIL DIVISION SOLEIL BONNIN 5901 Montrose Road, Apt. C802 Rockville, MD 20852 v. Plaintiff, FEDERAL NATIONAL MORTGAGE ASSOCIATION 3900 Wisconsin Avenue, NW
More informationUNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA SANDRA DILAURA and : Civil Action No. 03-2200 JEFFREY DILAURA, w/h, and : THE UNITED STATES EQUAL : EMPLOYMENT OPPORTUNITY : COMMISSION,
More informationSanctions Policy (Audit Enforcement Procedure)
Policy Financial Reporting Council April 2018 Sanctions Policy (Audit Enforcement Procedure) The FRC s mission is to promote transparency and integrity in business. The FRC sets the UK Corporate Governance
More informationDistrict of Columbia Model Severance Agreement
District of Columbia Model Severance Agreement This is for educational purposes only and is not intended as legal advice. For a legal opinion on your settlement you guessed it consult with a lawyer. THIS
More informationProvince of Alberta ATB FINANCIAL ACT. Revised Statutes of Alberta 2000 Chapter A Current as of December 15, Office Consolidation
Province of Alberta Revised Statutes of Alberta 2000 Current as of December 15, 2017 Office Consolidation Published by Alberta Queen s Printer Alberta Queen s Printer Suite 700, Park Plaza 10611-98 Avenue
More information3RD SESSION, 41ST LEGISLATURE, ONTARIO 67 ELIZABETH II, Bill 14. An Act with respect to the custody, use and disclosure of personal information
3RD SESSION, 41ST LEGISLATURE, ONTARIO 67 ELIZABETH II, 2018 Bill 14 An Act with respect to the custody, use and disclosure of personal information Mr. H. Takhar Private Member s Bill 1st Reading March
More informationCHAPTER 6 RELATIONSHIP TO STUDENTS, EMPLOYEES AND OTHERS
CHAPTER 6 RELATIONSHIP TO STUDENTS, EMPLOYEES AND OTHERS 6.1 SUPERVISION Direct Supervision Required 6.1-1 A lawyer has complete professional responsibility for all business entrusted to him or her and
More informationONTARIO SUPERIOR COURT OF JUSTICE EXCALIBUR SPECIAL OPPORTUNITIES LP. - and - SCHWARTZ LEVITSKY FELDMAN LLP
Court File No. CV-12-466694-00CP ONTARIO SUPERIOR COURT OF JUSTICE B E T W E E N: EXCALIBUR SPECIAL OPPORTUNITIES LP Plaintiff - and - SCHWARTZ LEVITSKY FELDMAN LLP Defendant Proceeding Under the Class
More informationDJAS FILED. eelveo PLAINTIFFS COMPLAINT FOR DAMAGES. Case 1:18-cv RP Document 1 Filed 02/20/18 Page 1 of 18. Case No.
eelveo FEB 2 0 018 DJAS Case 1:18-cv-00150-RP Document 1 Filed 02/20/18 Page 1 of 18 FILED FEB 202018 CLERK tj.. UNITED STATES DISTRICT COURT ci.ix, U.S DISTRICT COURT WESTERN DISTRICT OF TEXAS FARRAH
More informationNOTICE OF CERTIFICATION and PROPOSED SETTLEMENT OF CLASS PROCEEDING
1 NOTICE OF CERTIFICATION and PROPOSED SETTLEMENT OF CLASS PROCEEDING Re: Charlotte Perrenoud and Rajesh Bedi v. ehealth Ontario and Her Majesty The Queen In Right of Ontario as represented by the Minister
More informationPERSONAL INFORMATION PROTECTION ACT
Province of Alberta Statutes of Alberta, Current as of December 17, 2014 Office Consolidation Published by Alberta Queen s Printer Alberta Queen s Printer Suite 700, Park Plaza 10611-98 Avenue Edmonton,
More informationAGRICULTURAL SERVICE BOARD ACT
Province of Alberta AGRICULTURAL SERVICE BOARD ACT Revised Statutes of Alberta 2000 Chapter A-10 Current as of November 1, 2010 Office Consolidation Published by Alberta Queen s Printer Alberta Queen s
More informationANNE ELIZABETH HARDY NOVEMBER 1, 2011 Law Society of Saskatchewan v. Anne Elizabeth Hardy, 2011 LSS 6
ANNE ELIZABETH HARDY NOVEMBER 1, 2011 Law Society of Saskatchewan v. Anne Elizabeth Hardy, 2011 LSS 6 C A N A D A ) PROVINCE OF SASKATCHEWAN ) T O W I T ) IN THE MATTER OF THE LEGAL PROFESSION ACT, 1990
More informationONTARIO SUPERIOR COURT OF JUSTICE COMMERCIAL LIST. IN THE MATTER OF THE COMPANIES CREDITORS ARRANGEMENT ACT, R.S.C. 1985, c.
ONTARIO SUPERIOR COURT OF JUSTICE COMMERCIAL LIST Court File No. CV-12-9545-00CL IN THE MATTER OF THE COMPANIES CREDITORS ARRANGEMENT ACT, R.S.C. 1985, c.c-36, AS AMENDED AND IN THE MATTER OF A PLAN OF
More informationNOTARIES AND COMMISSIONERS ACT
Province of Alberta Statutes of Alberta, Current as of December 9, 2016 Office Consolidation Published by Alberta Queen s Printer Alberta Queen s Printer 7 th Floor, Park Plaza 10611-98 Avenue Edmonton,
More informationH 7024 S T A T E O F R H O D E I S L A N D
LC000 01 -- H 0 S T A T E O F R H O D E I S L A N D IN GENERAL ASSEMBLY JANUARY SESSION, A.D. 01 A N A C T RELATING TO LABOR AND LABOR RELATIONS -- HEALTHY WORKPLACE Introduced By: Representatives O'Brien,
More informationDANGEROUS GOODS TRANSPORTATION AND HANDLING REGULATION
Province = of Alberta DANGEROUS GOODS TRANSPORTATION AND HANDLING ACT DANGEROUS GOODS TRANSPORTATION AND HANDLING REGULATION Alberta Regulation 157/1997 With amendments up to and including Alberta Regulation
More informationCAUSE NO CV ANNA DRAKER IN THE DISTRICT COURT OF VS. MEDINA COUNTY, TEXAS
CAUSE NO. 06-08-17998-CV ANNA DRAKER IN THE DISTRICT COURT OF VS. MEDINA COUNTY, TEXAS BENJAMIN SCHREIBER, a minor, LISA SCHREIBER, RYAN TODD, a minor, LISA TODD, and STEVE TODD 38TH JUDICIAL DISTRICT
More informationCANADIAN COUNCIL OF MINISTERS OF THE ENVIRONMENT INC. (CCME)
CANADIAN COUNCIL OF MINISTERS OF THE ENVIRONMENT INC. (CCME) PROFESSIONAL SERVICES CONTRACT THIS AGREEMENT made in duplicate as of the xx th day of Month, 2016; BETWEEN: Name of Contractor Address City,
More information2014 Bill 8. Third Session, 28th Legislature, 63 Elizabeth II THE LEGISLATIVE ASSEMBLY OF ALBERTA BILL 8 JUSTICE STATUTES AMENDMENT ACT, 2014
2014 Bill 8 Third Session, 28th Legislature, 63 Elizabeth II THE LEGISLATIVE ASSEMBLY OF ALBERTA BILL 8 JUSTICE STATUTES AMENDMENT ACT, 2014 MS KENNEDY-GLANS First Reading.......................................................
More informationKATESTONE CONSULTING SERVICES AGREEMENT
KATESTONE CONSULTING SERVICES AGREEMENT DATE [insert date] AGREEMENT NO. [insert agreement #] PARTIES Katestone Environmental Pty Ltd ACN 097 270 276 16 Marie Street Milton QLD 4064 Fax No.: (07) 3369
More informationDANGEROUS GOODS TRANSPORTATION AND HANDLING REGULATION
Province of Alberta DANGEROUS GOODS TRANSPORTATION AND HANDLING ACT DANGEROUS GOODS TRANSPORTATION AND HANDLING REGULATION Alberta Regulation 157/1997 With amendments up to and including Alberta Regulation
More informationSECURITY SERVICES AND INVESTIGATORS ACT
Province of Alberta Statutes of Alberta, Current as of January 1, 2017 Office Consolidation Published by Alberta Queen s Printer Alberta Queen s Printer 7 th Floor, Park Plaza 10611-98 Avenue Edmonton,
More informationFILED: KINGS COUNTY CLERK 09/02/ :36 PM INDEX NO /2014 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/02/2014
FILED: KINGS COUNTY CLERK 09/02/2014 01:36 PM INDEX NO. 508016/2014 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/02/2014 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS DAE HYUN CHUNG, Plaintiff, -against-
More information11/9/2017 9:48 AM 17CV48960 IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF DESCHUTES. Case No.
11/9/2017 9:48 AM 17CV48960 1 2 3 4 5 6 7 IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF DESCHUTES 8 MELISSA GOTTLIEB, an individual, and A.G., a minor, by and through his natural 9 parent
More informationTHE PUBLIC INTEREST DISCLOSURE (WHISTLEBLOWER PROTECTION) ACT
THE PUBLIC INTEREST DISCLOSURE (WHISTLEBLOWER PROTECTION) ACT Provision PART 1 PURPOSE AND DEFINITIONS Purpose of this Act 1 The purpose of this Act is (a) to facilitate the disclosure and investigation
More informationThe Advocate for Children and Youth Act
1 The Advocate for Children and Youth Act being Chapter A-5.4* of the Statutes of Saskatchewan, 2012 (effective September 1, 2012), as amended by the Statutes of Saskatchewan, 2014, c.e-13.1; 2015, c.16;
More informationONTARIO SUPERIOR COURT OF JUSTICE COMMERCIAL LIST
File No. 09-CL-7950 ONTARIO SUPERIOR COURT OF JUSTICE COMMERCIAL LIST THE HONOURABLE MR. JUSTICE ) TUESDAY, THE 19TH DAY MORAWETZ OF NOVEMBER, 2013 IN THE MATTER OF THE COMPANIES' CREDITORS ARRANGEMENT
More informationTHE LONDON BAR ARBITRATION SCHEME. Administered by The London Common Law and Commercial Bar Association
THE LONDON BAR ARBITRATION SCHEME Administered by The London Common Law and Commercial Bar Association 2004 EDITION Correspondence to be addressed to Melissa Wood Administrator, LCLCBA Hardwicke Hardwicke
More informationINCOME AND EMPLOYMENT SUPPORTS ACT
Province of Alberta Statutes of Alberta, Current as of December 9, 2016 Office Consolidation Published by Alberta Queen s Printer Alberta Queen s Printer Suite 700, Park Plaza 10611-98 Avenue Edmonton,
More informationONTARIO SUPERIOR COURT OF JUSTICE
Court File No. 29762 ONTARIO SUPERIOR COURT OF JUSTICE THE HONOURABLE ) MR. JUSTICE WARREN K. WINKLER ) ) FRIDAY, THE 15 TH DAY OF DECEMBER, 2006 BETWEEN: MARLENE C. CLOUD, GERALDINE ROBERTSON, RON DELEARY,
More informationCase Law Update Councillors Behaving Badly, The Sequel. May 4, 2018
Case Law Update Councillors Behaving Badly, The Sequel May 4, 2018 Quinto M. Annibale, Partner The information presented is for general discussion purposes only and does not constitute legal advice for
More informationSTANDARDS OF PROFESSIONALISM
STATEMENT OF PRINCIPLES 1. Principle: A lawyer should revere the law, the judicial system and the legal profession and should, at all times in the lawyer s professional and private lives, uphold the dignity
More informationSTATEMENT OF CLAIM. (Court File No. ) FEDERAL COURT. BETWEEN: DAN PELLETIER Plaintiff. and. HER MAJESTY THE QUEEN Defendant.
STATEMENT OF CLAIM (Court File No. ) FEDERAL COURT BETWEEN: DAN PELLETIER Plaintiff and HER MAJESTY THE QUEEN Defendant (Court seal) STATEMENT OF CLAIM TO THE DEFENDANT PROPOSED CLASS PROCEEDING A LEGAL
More informationFILED: NEW YORK COUNTY CLERK 05/15/ :39 PM INDEX NO /2015 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/15/2015
FILED: NEW YORK COUNTY CLERK 05/15/2015 04:39 PM INDEX NO. 155631/2015 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/15/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ---------------------------------------------------------------------x
More informationQUICKPOLE.CA TERMS OF SERVICE. Last Modified On: July 12 th, 2018
1. PRELIMINARY PROVISIONS: QUICKPOLE.CA TERMS OF SERVICE Last Modified On: July 12 th, 2018 1.1 Introduction. Welcome to our website's Terms and Conditions ("Agreement"). The provisions of this Agreement
More informationFILED: NEW YORK COUNTY CLERK 12/15/ :02 PM INDEX NO /2017 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/15/2017 INDEX NO. Plaintiff, SUMMONS
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK PAUL HAGGIS, INDEX NO. v. Plaintiff, SUMMONS HALEIGH BREEST, Defendant. TO THE ABOVE-NAMED DEFENDANT: YOU ARE HEREBY SUMMONED and required to answer
More informationONTARIO SUPERIOR COURT OF JUSTICE ONTARIO LIMITED. -and- GREG KELLY, JOAN KELLY, ONTARIO INC. and TRADESMAN HOME INSPECTIONS
ONTARIO SUPERIOR COURT OF JUSTICE Court File No.: CV-12-466870 B E T W E E N: 2180511 ONTARIO LIMITED Plaintiff -and- GREG KELLY, JOAN KELLY, 1159387 ONTARIO INC. and TRADESMAN HOME INSPECTIONS STATEMENT
More informationCase 3:08-cv CRW-CFB Document 1 Filed 11/07/2008 Page 1 of 12
Case 3:08-cv-00141-CRW-CFB Document 1 Filed 11/07/2008 Page 1 of 12 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF IOWA-DAVENPORT DIVISION MELISSA ROSE WALDING MILLIGAN, Plaintiff, No.
More informationPRACTICE DIRECTIVES FOR CONTESTED APPLICATIONS IN THE PROVINCIAL COURT OF MANITOBA
PRACTICE DIRECTIVES FOR CONTESTED APPLICATIONS IN THE PROVINCIAL COURT OF MANITOBA November 4, 2013 TABLE OF CONTENTS PREAMBLE TO PRACTICE DIRECTIVES FOR CONTESTED APPLICATIONS IN THE PROVINCIAL COURT
More informationONTARIO SUPERIOR COURT OF JUSTICE NOTICE OF ACTION
C V-1 1-5 0 i ':1'13-occP ONTARIO SUPERIOR COURT OF JUSTICE Court File No. BETWEEN: (Court Seal) JACK ROMBOUTS Plaintiffs and FCA CANADA INC., FIAT CHRYSLER AUTOMOBILES N.V. and FCA US LLC Defendants Proceeding
More informationIN THE SUPREME COURT OF BRITISH COLUMBIA. NICOLA MONACO and TAMMY MARIE JOSEPH NOTICE OF CIVIL CLAIM. (Amended pursuant to order issued June 20, 2013)
SUPREME COURT OF BRITISH COLUMBIA VANCOUVER REGISTRY =-.=:~:; AUG 2 7 2013. ~ w ;;~;-.: ~~~( i~ :~::-~--~~ ~-~~~--- No. S-083289 VANCOUVER REGISTRY IN THE SUPREME COURT OF BRITISH COLUMBIA BETWEEN: AND:
More informationPROVINCIAL COURT ACT
Province of Alberta PROVINCIAL COURT ACT Revised Statutes of Alberta 2000 Current as of February 1, 2018 Office Consolidation Published by Alberta Queen s Printer Alberta Queen s Printer Suite 700, Park
More informationPedestal Search Terms and Conditions of Service:
Suite 300-100 Broadview Ave, Toronto, ON, M4M 3H3 (416) 545-1467 Pedestal Search Terms and Conditions of Service: WHEREAS these terms and conditions govern Pedestal s services and agreements between Pedestal
More informationCOURT OF QUEEN S BENCH ACT
Province of Alberta COURT OF QUEEN S BENCH ACT Revised Statutes of Alberta 2000 Current as of March 30, 2015 Office Consolidation Published by Alberta Queen s Printer Alberta Queen s Printer Suite 700,
More informationONTARIO SUPERIOR COURT OF JUSTICE NOTICE OF ACTION
Court File No./N du dossier du greffe: CV-18-00605906-00CP Court File No. Electronically issued Délivré par voie électronique B E T W E E : N: 26-Sep-2018 Toronto ONTARIO SUPERIOR COURT OF JUSTICE STACEY
More informationCOPY 1AR ) Dept.: P52 ) 2. INTENTIONAL INFLICTION COUNTY OF RIVERSIDE 17 ) 4. PRELIMINARY INJUNCTION 19 )
1 Alvin B. Sherron, Esq. (State Bar No. 106598) LAW OFFICES OF ALVIN B. SHERRON 2 COPY D 1055 Wilshire Boulevard, Suite 1702i jrnia Los Angeles, California 90017 Tel: (213) 482-3236 1AR 09 2017 4 Fax:
More informationThe Proceedings against the Crown Act
1 PROCEEDINGS AGAINST THE CROWN c. P-27 The Proceedings against the Crown Act being Chapter P-27 of The Revised Statutes of Saskatchewan, 1978 (effective February 26, 1979) as amended by the Statutes of
More informationAPPLICATION FOR PERMIT TO ACT AS A FOREIGN LEGAL CONSULTANT (Regulation 6.5)
EDUCATION & CREDENTIALS APPLICATION FOR PERMIT TO ACT AS A FOREIGN LEGAL CONSULTANT (Regulation 6.5) This application must be completed legibly. All questions must be answered fully and precisely and the
More informationCITY OF HAMILTON BY-LAW NO Council Code of Conduct:
CITY OF HAMILTON BY-LAW NO. 16-290 Council Code of Conduct Authority: Item 6, General Issues Committee 16-024 (LS16022) CM: October 26, 2016 Bill No. 290 WHEREAS sections 8, 9 and 10 of the Municipal Act,
More information