2022-03-29 +Cooper+Nanaimo+Demand Letter_Redacted.pdf -

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https://www.gofundme.com/manage/help-defend-workers-who-need-to-enforce-rules/edit/story WITHOUT PREJUDICE https://gofund.me/ff922e9d 29 March 2022 Regional District of Nanaimo 6300 Hammond Bay Road Nanaimo, BC V9T 6N2 Attention: Darren Marshall, Manager, Transit Operations Greetings: Re: Jason Cooper; Dismissal without cause and discrimination on the basis of political belief; Our File No. 04-0001.1204 1. Introduction 1.1 We are legal counsel representing Jason Cooper (“Jason”) in this matter, as such, are authorized to deliver this correspondence on his behalf. 1.1 Jason commenced employment with the Regional District of Nanaimo (“RDN” or the “Employer”) on 5 March 2017. On 11 May 2021, after more than four years of continuous service, RDN summarily terminated Jason’s employment for alleged cause. In our view, RDN’s termination of Jason’s employment constitutes unlawful discrimination on the basis of political belief, contrary to the Human Rights Code. 1 Furthermore, our opinion is that RDN has failed to fulfill its obligations under the Workers Compensation Act. 2 1.2 Unless this matter can be resolved quickly and amicably, we will seek instructions to commence litigation. Nevertheless, we are hopeful that the Employer can avoid both the high-costs of legal fees associated with litigation and the resulting adverse publicity it will likely attract. 1 Human Rights Code, RSBC 1996, c-210 [the “Code”]. 2 Workers Compensation Act, Error! Main Document Only.RSBC 2019, c 1 [the “WCA”]. S. ANDERSON PROFESSIONAL 1 604 475 0041 | 1 877 708 8350 LAW CORP. Facsimile 1 877 700 8879 #206, 3007 Glen Drive, Coquitlam, BC V3B 0L8 [email protected] | www.LabourRightsLaw.com Labour Rights Law Page 2 Jason Cooper –and– Regional District of Nanaimo 29 March 2022 2. Background 2.1 Our client, Jason was hired by RDN on or about 5 March 2017 as a Transit Operator. As a Transit Operator, Jason drove RDN busses through the RDN transit system which serves the region from Cedar, in the southern part of the RDN, to Electoral Area H, in the north, including the City of Nanaimo, District of Lantzville, City of Parksville, Town of Qualicum Beach, and surrounding rural areas. 2.2 Throughout Jason’s long career with RDN, he was a valuable employee who built and maintained client relations for the Employer. He was well-liked and respected by both his peers and supervisors. 2.3 Jason was an extremely capable Transit Operator. He loved his work and he endeavored to provide each passenger with a safe and positive experience. Prior to driving busses for RDN, Jason was an advanced driving instructor. He trained people to handle adverse conditions on the road in classroom settings, using simulators and obstacle courses. Jason is trained in the regulation and enforcement of the Traffic Safety Act, and he obtained his qualifications to examine collisions and make assessments. Jason has further experience driving long-haul trucks, short-haul trucks, taxis, and limousines. Above all, Jason enjoyed driving busses and his skills and abilities are perfectly suited to this type of work. 2.4 On or about 13 March 2020, the Province of BC declared a state of emergency due to the global pandemic, i.e., COVID-19. 2.5 Shortly thereafter, the Provincial Health Officer made a series of orders, pursuant to the Public Health Act, and the Ministry of Health imposed special public health guidelines to manage the state of emergency created by COVID-19. WorkSafeBC mandated businesses to create and enforce COVID-19 safety plans. 2.6 With respect to face coverings, the Provincial Health Officer has expressly stated: Properly worn, face coverings are one measure that has been shown to suppress the transmission of the SARS-CoV-2 virus and to reduce the risk of contracting COVID-19 in both the vaccinated and the unvaccinated. The non-wearing of masks by people gathering indoors, some of whom might be infected and some of whom might be susceptible to infection, interferes with the suppression of the SARS-CoV-2 virus. 2.7 The Provincial Health Officer went on to explain that she has reason to believe and does believe that, “the presence of the public, operators, workers … in indoor settings where they intermingle with each other without wearing a face covering constitutes a health hazard under the Public Health Act.” 2.8 With limited exception, face coverings were required in indoor public spaces. 2.9 BC Transit advises that safety is its “first priority”. BC Transit created policies to comply with its occupational health and safety obligations, and the public health orders intended to reduce the transmission of COVID-19. This included imposing a policy regarding mandatory face coverings on all BC Transit busses and at bus stops. Labour Rights Law Page 3 Jason Cooper –and– Regional District of Nanaimo 29 March 2022 2.10 On the RDN website under the heading, “Regional Transit”, the first sentence in bold lettering states clearly: Face coverings are mandatory on all RDN Transit vehicles. 3 2.11 On the BC Transit website, the Employer provides that “COVID Bus Etiquette” ensures the Employer’s top priority of safety of passengers and operators is maintained. The website states that, “BC Transit has implemented safety measures in response to COVID-19 to help you get to your destination safely and efficiently. These safety measures allow BC Transit to follow the guidance of the Provincial Health Officer and WorkSafeBC, and incorporate current best practices of the transit industry worldwide. It is important we all work together to create a comfortable and respectful environment on board for everyone.” 4 2.12 It goes on to provide that, “the use of face coverings is once again mandatory on all BC Transit buses and at bus stops, effective August 25.” 2.13 The policy regarding face coverings uses the word, “mandatory”, i.e., required by law or rules; compulsory. Similarly, passengers must be wearing footwear to board a BC Transit bus. Shoes are mandatory and without shoes, the passenger will be denied entry. This rule is enforceable. The BC Transit website provides that, “For safety reasons, shirts and footwear must be worn to board the bus or the driver will refuse service.” 2.14 For safety reasons, face coverings must also be worn on BC Transit buses. However, management informed its drivers of its policy for drivers to “educate not enforce” some of the rules that apply to passengers. Of course, some safety rules require enforcement, such as, not allowing passengers to board who are intoxicated. However, rules surrounding passenger fares and COVID-19 mask mandates were not to be enforced by drivers. 2.15 Incongruously, the Employer asked drivers to enforce the rule, which disallowed passengers from boarding the bus with a bag of recyclable materials and the rule that wearing shoes is mandatory. Evidently, the Employer expected drivers to enforce some rules, however, only inform about others. Which rules were enforceable, remains undetermined. 2.16 On 29 September 2020, the Employer provided a letter to Jason, seeking an incident report for an incident on 26 September 2020, in which Jason stated to a customer that the Employer had a policy regarding face coverings. Jason did not enforce the policy or ask the customer to exit the bus, he stated as a fact that there is a policy. In other words, Jason educated the passenger about the face covering policy. 2.17 On 27 October 2020, the Employer provided a letter to Jason, seeking an incident report for an incident on 23 October 2020, regarding “an altercation over the “Face Covering Policy” that resulted in denied service due to no mask.” 3 https://www.rdn.bc.ca/regional-transit. 4 https://www.bctransit.com/covid-19/bus-etiquette. Labour Rights Law Page 4 Jason Cooper –and– Regional District of Nanaimo 29 March 2022 2.18 Jason advised the Employer that he did not deny service to any passenger. On 23 October 2020, Jason informed passengers that BC Transit has a face covering policy, however, he did not advise any passenger that they could not board the bus. 2.19 On 9 November 2020, Jason attended a meeting with the Employer, wherein it conducted an investigation into three incidences in which Jason informed passengers of the face mask policy. In each of the incidences, Jason did not ask any passenger to leave the bus. He simply stated that there exists a face mask policy, however, he did not enforce it. At no time did Jason refuse entry to a passenger. 2.20 During this meeting, Jason advised the Employer that he has maintained compliance with its policy to “educate not enforce” certain rules such as those which set the appropriate fare and the rule regarding mandatory face coverings. 2.21 Jason expressly advised the Employer that encouraging passengers to board the bus without a face covering caused Jason serious concern for his health and safety, and for that of the other passengers. 2.22 At the Employer’s request, Jason agreed to inform passengers of the mandatory face mask policy going forward, as follows: Masks are mandatory on BC Transit. Please ensure that the next time you are wearing your mask. Please take a seat. 2.23 On or about 10 November 2020, the Employer provided a letter of suspension to Jason related to the above incidents in which Jason informed passengers of the face covering policy which states that face coverings are mandatory on BC Transit. 2.24 In this letter, the Employer explains its justification for discipline of Jason in part because he “told a customer, who did not have a face mask that wearing a mask was mandatory to ride the RDN bus.” The Employer further agreed that Jason did not ask the passenger to leave or deny the passenger service, however, the passenger left the bus on their own. 2.25 The Employer’s face covering policy is clear in that wearing a face covering is mandatory to ride an RDN bus. 5 2.26 On 23 April 2021, the Employer provided a letter to Jason seeking an incident report for an incident on 15 April 2021, in which Jason did not notice a passenger who wanted to exit the bus out of the back door at a stop along Jason’s route. The passenger was then required to exit the bus using the front door and filed a complaint about Jason. 2.27 Jason filed an incident report regarding this matter and made clear that he did not notice that a passenger made a stop-request for the Country Club Exchange. 5 https://www.rdn.bc.ca/regional-transit. Labour Rights Law Page 5 Jason Cooper –and– Regional District of Nanaimo 29 March 2022 2.28 On 29 April 2021, the Employer held a follow up meeting with Jason and his union representative, Tina Lapensee, regarding the 15 April 2021 incident. Jason advised that he was confused by the Employer’s investigation as he did not recall any incident with any of the passengers. With respect to the passenger exiting the bus from the front-door, Jason explained that he did not hear or notice a stop-request at the time for the back door of the bus. 2.29 Jason explained that the passenger hoped to exit at a stop called the Country Club Exchange, a stop which Jason and other bus drivers frequently drive past as it is not a heavily trafficked stop. 2.30 Jason explained that he did not notice anyone who wanted to exit the bus at the Country Club, and he did not receive a stop-request. With late notice, Jason realized that a passenger wanted to exit and Jason stopped the bus. Jason then opened the front door for the passenger to exit. 2.31 During the meeting, Jason advised that his invariable practice is to open only the front door when passengers are embarking on the bus. In circumstances where no one is getting off the bus, he will not open the back door. This is common practice among many Transit Operators as it prevents clients from embarking the bus through the back door. Because of COVID-19, Jason explained that maintaining the flow of passengers from front to back is an important safety measure. 2.32 The Employer inquired about Jason having clapped. Jason explained that he did not clap at any passenger in a mocking or intimidating manner. He advised that COVID-19 has proved an extremely difficult time for himself and others. He understands that his passengers arrive on the bus with a host of backgrounds and personal experiences, which he knows nothing about, and he endeavors to provide each passenger with a positive experience while on RDN transit. Jason explained to the Employer that during times of frustration, he has a practice of clapping to himself as a reminder that each person is doing their best. He advised that it was a meditative process which assists him to maintain a clear and positive attitude. 2.33 During this meeting, Jason was unequivocal that he had no intention to “teach anyone a lesson”. He was clear that failing to open the back-door was the result of there being no stop-request and Jason did not see any passenger waiting at the back door. Jason explained that it appeared to be a misunderstanding. He offered that perhaps the passenger did not understand the correct procedure to make a stop-request. The Employer advised that it would investigate further and provide Jason with a response. 2.34 On 11 May 2021, RDN provided Jason with a letter of termination (the “Termination Letter”). The Termination Letter provides the reasons for termination as related to the 15 April 2021 incident, i.e., a passenger was required to exit the bus using the front door. 2.35 On 14 June 2021, the Employer stated in a meeting that the termination of Jason’s employment was a culmination of three separate incidences, resulting in three suspensions. Each of these instances were related to the RDN’s mandatory face covering policy and Jason having informed passengers of the policy. At no time did Jason take steps to enforce the policy, or refuse entry to any passenger not in compliance with the policy. Labour Rights Law Page 6 Jason Cooper –and– Regional District of Nanaimo 29 March 2022 2.36 Jason made clear to the Employer his concerns regarding the non-compliance with the face covering policy and the increased risk of transmission of COVID-19 as a result of the failure to enforce appropriate COVID-19 safety protocols. At no time did RDN require passengers to show proof of their vaccination status, and during the height of the pandemic, face coverings were the only protective measure against the health hazards presented by COVID-19. 2.37 On or about 10 March 2022, the Provincial Health Officer announced that COVID-19 restrictions would be easing as a result of lower hospitalization rates and reduced transmission rate of the virus. The BC Government announced that it would be lifting the restriction of mandatory masks in public places effective first thing Friday, 11 March 2022. 2.38 On or about 10 March 2022, the Employer made an announcement that, “ As of 12:01 a.m. on Friday, March 11, 2022, masks are no longer mandatory in all RDN facilities including Ravensong Aquatic Centre in Qualicum Beach and Oceanside Place Arena in Parksville or on RDN Transit buses.” 2.39 While the face covering policy will no longer be mandatory, throughout the pandemic during the relevant periods prior to 10 March 2022, face coverings were mandatory on RDN Transit buses. 3. Discrimination on the basis of political belief 3.1 In BC, people are protected from discrimination on the basis of political belief in the areas of employment and membership in unions and associations. 6 3.2 The ground of political belief is to be liberally interpreted. 7 The Tribunal’s early attempts to define “political” drew from the dictionary definition: political a. 1. of or affecting the State or its government; of public affairs; of politics. 2. (Of person) engaged in civil administration. 3. Having an organized form of society or government. 4. belonging to, or taking, a side in politics; relating to a person's or organization's status or influence… 8 3.3 This definition is grounded in the form and function of government, and a person’s participation in partisan politics. Its scope reflects those areas where the Tribunal has comfortably acknowledged political belief: participation in partisan politics and beliefs that are “core to a person’s concept of social cooperation. 9 3.4 The Tribunal expanded the ground of political belief beyond partisan politics in Jamieson v Victoria Native Friendship Centre. Mr. Jamison was a member of the Mohawk First Nation and part of the Mohawk Warrior Society. He alleged that the Victoria Native Friendship Centre refused to re-hire him 6 Human Rights Code, RSBC 1996, c-210 [the “Code”], ss 13 & 14. 7 Bratzer v Victoria Police Department, 2016 BCHRT 50; Kjajic v Vancouver (City), 2014 BCHRT 258. 8 Jamieson v Victoria Native Friendship Centre, [1994] BCCHRD No. 42. 9 Croxall v West Fraser Timber, 2009 BCHRT 436, at ¶22. Labour Rights Law Page 7 Jason Cooper –and– Regional District of Nanaimo 29 March 2022 once it learned of his beliefs. Those beliefs, which the Tribunal accepted as political, included beliefs regarding culture, economics, and social well-being of the community. 3.5 Applying a broad and purposive interpretation to “political belief”, the Tribunal expressed satisfaction that many of Mr. Jamieson’s articulated beliefs were political in nature. This is because they “concern the way First Nations communities are organized and governed and how these communities relate to each other and to other levels of government”. It held that, “political beliefs are not limited to beliefs about or involvement in recognized or registered political parties…beliefs about the organization and governance of First Nations communities are political”. This case led the Tribunal to identify systems of “social cooperation” as political. 10 3.6 In Wali v Jace Holdings Ltd. (c.o.b. Thrifty Foods), 11 the Tribunal once again applied the ground of political belief to somewhat novel circumstances. Mr. Wali was a pharmacist who had been outspoken about his opposition to a bylaw proposed by the College of Pharmacists to expand the role of pharmacy technicians. His position was in opposition to that of his employer, Thrifty Foods, and he was terminated. 3.7 The Tribunal was satisfied that Mr. Wali’s belief was political. The Tribunal described Mr. Wali’s belief as related to social cooperation because it related to “the social contract between the government, the College and the public regarding the safe destruction of pharmaceutical medication”. 12 3.8 In another successful case before the Tribunal of Bratzer v Victoria Police Department, 13 Mr. Bratzer was a constable with the Victoria Police Department. He was also an active member of Law Enforcement against Prohibition (“LEAP”), an organization that advocates for the legalization and regulation of all illicit drugs. In his personal time, he made frequent public appearances and statements advocating for fundamental reform to Canada’s drug laws. In his capacity as a police officer, the evidence was unanimous that he was an excellent officer and that his views on drug laws posed no impediment to his ability to enforce those laws on the street. The Tribunal ultimately concluded that the Police Department had discriminated against Mr. Bratzer on the basis of his political beliefs when it attempted to, and on two occasions did, restrict Mr. Bratzer’s ability to speak publically on the issue of drug policy under threat of discipline. The Police Department conceded that Mr. Bratzer’s beliefs about drug laws were political. The Tribunal said that this was a proper concession: …I find that, regardless of what the limits of "political belief" may be, advocacy for changes to the drug laws or engagement in the level or cost of policing in a municipality may both be classified as "political beliefs". In both cases, they involve public discourse on matters of public issue which involve or would require action at a governmental level, be it the federal government, as with drug laws, or a municipal council with policing issues… 14 10 Jamieson v Victoria Native Friendship Centre, [1994] BCCHRD No. 42, at ¶15-16. 11 Wali v Jace Holdings Ltd. (c.o.b. Thrifty Foods), 2012 BCHRT 389. 12 Wali v Jace Holdings Ltd. (c.o.b. Thrifty Foods), 2012 BCHRT 389, at ¶117-118. 13 Bratzer v Victoria Police Department, 2016 BCHRT 50. 14 Bratzer v Victoria Police Department, 2016 BCHRT 50, at ¶271. Labour Rights Law Page 8 Jason Cooper –and– Regional District of Nanaimo 29 March 2022 3.9 The Tribunal found that the Police Department had discriminated against Mr. Bratzer and awarded him $20,000 for injury to dignity, feelings and self-respect. 3.10 It is without dispute that COVID-19 health and safety measures have reached a high level of politicisation across BC, and elsewhere in North America. This includes measures, such as COVID-19 vaccinations, mask wearing, and maintaining social distancing. 3.11 Multiple studies have shown - and a greater number of public polls suggest - that attitudes about facemasks during the COVID-19 pandemic fall across political ideologies. Beliefs that masks are ineffective in preventing COVID-19 and psychological reactance have proven to be aligned with certain political affiliations. Equally, mask adherence is closely tied to political association and matters of public policy and governance. 3.12 Jason’s belief engages the employer and the provincial government on a matter of public interest and social cooperation: public health mandates regarding COVID-19 and the provincial state of emergency. Jason’s belief falls squarely within the medical-political complex British Columbians face. 3.13 Furthermore, the Tribunal has made clear that the Code protects employees’ “beliefs about modes of social cooperation.” In our view, there is a strong inference to be made that Jason’s political beliefs played a factor in the Employer’s decisions to impose discipline and ultimately terminate Jason’s employment. 3.14 We note that for the Tribunal’s purpose, the facts alleged must be capable of supporting a reasonable inference that the adverse treatment alleged is related, in whole or in part, to a prohibited ground of discrimination. Direct evidence of discrimination or evidence of intent to discriminate is not necessary for the complainant to meet the burden of proof. 15 3.15 Discrimination can be established as long as the employee is able to establish that his political belief was one of the factors that influenced the employer’s actions. 16 3.16 The complainant is not required to produce direct evidence of discrimination. Discrimination will more often be proven by circumstantial evidence and inference, because it is understood that seldom will discrimination be proven by direct evidence. 17 3.17 Considering all of the foregoing, we allege that RDN’s decision to terminate Jason’s employment was a direct result of or influenced by Jason’s political beliefs, and consequently, RDN has discriminated against Jason, contrary to the provisions of the Code. 3.18 Should this matter proceed before the Tribunal, we have instructions to seek reinstatement or, in the alternative, damages for future loss of wages and benefits. For the purposes of negotiating a fair settlement, we are seeking a sum of $15,000 for RDN’s contravention of the Code and the damage it 15 Québec (Commission des droits de la personne et des droits de la jeunesse) c Bombardier Inc, 2015 SCC 39 (SCC) [Bombardier]. 16 Benton v Richmond Plastics, 2020 BCHRT 82. 17 Error! Main Document Only. Bombardier, supra. Labour Rights Law Page 9 Jason Cooper –and– Regional District of Nanaimo 29 March 2022 has caused to Jason’s dignity, feelings, and self-respect. In our view, this sum represents an entirely reasonable offer. 4. Conduct contrary to the Workers Compensation Act 4.1 Sections 47 and 48 of the WCA prohibit an employer from taking “discriminatory action” against an employee by retaliating against a worker for engaging in health and safety matters under the jurisdiction of WorkSafeBC. 4.2 As you are aware, COVID-19 safety protocols fall under the jurisdiction of WorkSafeBC as a matter of occupational health and safety and the Employer’s obligations under the WCA to provide its employees with a healthy and safe workplace. 18 4.3 As you may know, the preliminary issue to be decided in prohibited action complaints is whether there has been a prohibited action by the employer, as set out in Section 47 of the WCA. The WorkSafeBC Appeal Division has held that this is not a difficult burden to meet. Showing that there was a suspension, dismissal, discipline or elimination of a job is generally a “straightforward factual question.” The complainant becomes entitled to an inquiry by the Board pursuant to [Section 49], simply by providing some evidence that the complainant was dismissed for one of the reasons in [Section 48]. Furthermore, Section 49(4) of the WCA, as amended, provides where a complaint is made to the Board, “burden of proving that there has been no such contravention is on the employer.” 4.4 On several occasions, Jason reported to the Employer that he felt unsafe by the Employer’s direction of encouraging passengers to board the bus without a face covering, which was mandatory under the Employer’s COVID-19 safety plan. Jason reported that passengers who were not wearing a face covering posed a serious risk to himself and to the other passengers. 4.5 As a result of Jason informing passengers about the BC Transit face covering policy, the Employer suspended Jason’s employment and, finally, terminated it. 4.6 In our view, there is a clear causal connection between the negative employment consequence Jason experienced and a protected safety activity. We contend that, contrary to Sections 47(2)(a), 48(a), and 48(c)(i – iii) of the WCA, the Employer’s decision to terminate Jason’s employment was, at least in part, related to his concerns regarding the Employer’s failure to enforce its own health and safety policies. 4.7 Section 22(1)(a) of the WCA imposes a general duty on a worker to take reasonable care to protect the worker’s own health and safety and to comply with occupational health and safety provisions and the Regulation. 4.8 Section 3.10 of the Occupational Health and Safety Regulation states in summary that whenever a person observes what appears to be an unsafe or harmful condition or act, the person must report it as soon as possible to a supervisor or the employer. 18 Error! Main Document Only.WCA, s 21. Labour Rights Law Page 10 Jason Cooper –and– Regional District of Nanaimo 29 March 2022 4.9 During the COVID-19 pandemic, Jason maintained compliance with public health guidelines to limit exposure and transmission of SARS-CoV-2, the virus that causes COVID-19. He wore a respirator while operating RDN Transit busses in order to protect himself and members of the public from transmitting the virus. 4.10 Jason often observed others who disregarded the public health orders and the Employer’s own policies regarding face coverings. On multiple occasions, Jason informed the Employer that encouraging entry on the bus to passengers who were not in compliance with COVID-19 safety measures, posed a serious risk. 4.11 Jason experienced and observed unsafe/harmful conditions, and, in compliance with the OH&S Regulation, he reported it to the Employer. 4.12 We are confident that WorkSafeBC will find that Jason was coerced and intimidated, and ultimately dismissed by the Employer for raising concerns about mandatory face mask rules that were in place in order to protect the health and safety of himself and others in the workplace and in light of the COVID- 19 global pandemic. The Employer’s actions, in our view, fall within the parameters of a prohibited action contemplated by the WCA. 4.13 WorkSafeBC found a prohibited action took place in its prohibited action decision CD2021119, in which a worker complained about the employer’s failure to enforce proper COVID-19 protocols and failure to provide appropriate face masks and other personal protective equipment. Shortly thereafter, her employment was terminated and she filed a successful prohibited action complaint. 4.14 In the very likely event that a complaint filed on this basis is upheld, Jason would be entitled to damages including compensation for his loss of wages. 5. Wage Loss 5.1 6. Summary Labour Rights Law Page 11 Jason Cooper –and– Regional District of Nanaimo 29 March 2022 6.1 To recap, our client, Jason, is advancing a claim in this case calculated as follows and to be paid in accordance with his lawful instructions: HEAD OF DAMAGE QUANTUM Damages for injury to dignity, feelings and self-respect $15,000.00 Wage loss $40,000.00 NET TOTAL $55,000.00 7. Conclusion 7.1 We submit that the above claim for compensation is fair and reasonable. In this letter, we have endeavoured to break this claim down to its constituent elements and to provide you with a rational basis for considering the reasonableness of each element. 7.2 Under the circumstances, we would request that you review this correspondence with your legal advisors and have them contact us in order to ascertain whether more satisfactory compensation in lieu of reasonable notice may be agreed upon and paid to Jason. We ask that Jason’s compensation package include a positive reference letter and that all future communication by RDN relating to Jason be consistent with this positive reference letter. 7.3 Please note that in the event we do not hear from you, or in the event that satisfactory arrangements cannot be made prior to 8 April 2022, we will seek instructions to commence legal proceedings against RDN without any further notice to you. Please govern yourselves accordingly. Thank you for your prompt attention to this matter. Yours truly, LABOUR RIGHTS LAW* per: Madeline Harden, Barrister & Solicitor She/her/hers * Sebastien Anderson Prof. Law Corporation Cc Client - via email