Alberta Take Five July 2013

604-879-4280 | [email protected]

July 2013

ALBERTA EDITION

Grievances; Discrimination; Arbitration; Wage Employees

Oil & Gas; Competition; Fuel Hauling Services, With Counsel Comments

Business; Fraud; Unlawful Conduct Conspiracy; Director’s Duties

Minors; Trust; Public Trustee; Advance Costs

Municipal Law; Validity of Bylaw; Limitation Period

Featured Cases:

P2

P4

P8

P10

P12

op

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In 2008, Jamie Graham was a

temporary employee working for the Alberta Department of Employment, Immigration and Industry under a cooperative education program offered through his university. Due to Mr. Graham’s cerebral palsy, he required the use of a wheelchair and voice recognition software during his employment. A few months into his employment, Mr. Graham was terminated due to his “inability to perform the duties and requirements of [the] position”. As a member of the Alberta Union of Public Employees (“AUPE”), Mr. Graham grieved his termination through AUPE under its collective agreement with the Alberta Government (the “Employer”). The only

grievance procedure available under the collective agreement to a wage employee, as Mr. Graham was, provided the grievance to be submitted in writing to a Designated Officer. Other forms of dealing with a grievance, such as arbitration, were expressly not available to wage employees. The Designated Officer dismissed the complaint noting that it was final and binding under the collective agreement. Mr. Graham did not challenge the impartiality of the Designated Officer, who was in fact an employee of the Employer, nor did he apply for judicial review of the decision. Instead, several months later, AUPE sought to advance the matter to arbitration on the basis that his termination amounted to discrimination under the Alberta Human Rights Act, R.S.A. 2000, c. A-25.5 based on his physical disability and the failure of the Employer to make reasonable accommodation. The arbitrator concluded that he did not have jurisdiction to hear the matter on the grounds that neither the collective agreement nor s. 135 of the Labour Relations Code, R.S.A. 2000, c. L-1 (the “Code”) required arbitration, and the collective agreement specifically excluded it for wage employees. Further, the arbitrator did not find the recent decision of the Supreme Court of Canada in Parry Sound (District) Social Services Administration Board v. OPSEU, Local 324, 2003 SCC 42 (“Parry Sound”) to require arbitration in this case alleging discrimination. On judicial review of the arbitrator’s decision, the reviewing judge held the applicable standard of review of an arbitrator’s decision on their jurisdiction was one of reasonableness, and that the arbitrator’s decision had met that standard. AUPE appealed.

AUPE v Alberta, 2013 ABCA 212Areas of Law: Grievances; Discrimination; Arbitration; Wage Employees

~Discrimination grievances of wage employees in Alberta do not necessarily require arbitration~

BACKGROUNDCLICK HERE TO ACCESS

THE JUDGEMENT

http://www.canlii.org/en/ab/abca/doc/2013/2013abca212/2013abca212.pdf


July 2013


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APPELLATE DECISION

AUPE v Alberta, (cont.)

The main thrust of AUPE’s argument

on appeal was that Parry Sound required grievances based on an alleged breach of human rights legislation to be resolved by arbitration and that s. 135 of the Code should be interpreted to require arbitration accordingly. In that case, the grievor was a probationary employee who was dismissed due to her pregnancy. The relevant collective agreement in that case stated that probationary employees did not have access to grievance procedures contained in the agreement. However,

the Ontario arbitration board found that they still had jurisdiction as the complaint was one of discrimination under a different piece of legislation, namely Ontario’s Human Rights Code, R.S.O. 1990, c. H. 19. The arbitrator’s jurisdiction was eventually upheld by the Supreme Court of Canada. However, a significant difference exists between Parry Sound and the case at bar. Unlike Alberta’s Code, the Ontario Labour Relations Act, 1995 S.O. 1995, c. 1, Sch. A requires all disputes under a collective agreement to be resolved by arbitration without provision for the parties to agree to a lesser means for dispute resolution. Further, the Supreme Court’s decision did not go so far as to require arbitration for settling discrimination-based disputes nor did it consider whether such disputes must be heard by someone other than an employee of one of the parties. In this case, the parties had agreed to resolve their matter through a Designated Officer in compliance with s. 135 of Alberta’s Code and there was nothing in Parry Sound to suggest that discrimination grievances in Alberta needed to be treated in any other way.

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The appellants, Husky Oil Operations

Ltd. (“Husky”) and ExxonMobil Canada Ltd. (“Exxon”), jointly owned several oil and gas properties in the Rainbow Lake area, north of Edmonton. After years of an uncooperative relationship, the two companies sought to improve their relations on a more collaborative and strategic basis. As part of this endeavour, Husky and Exxon began looking together into methods to improve their operations to reduce their costs associated with their jointly owned properties. One strategy they considered was to use a single fuel

hauling company rather than the two they used at present, Kolt and Cardusty Trucking (“Cardusty”). Husky and Exxon advised Kolt and Cardusty of their intended strategy and engaged in an extensive and lengthy evaluation process with both companies to determine which would provide the best efficiencies in the field. Cardusty was ultimately chosen to provide the fuel hauling services and Husky and Exxon subsequently terminated the services of Kolt in compliance with their contracts. As a result of this significant loss of business to Kolt, less than a year later it ceased operations and sold off its assets. Under s. 36 of the Competition Act, R.S.C. 1985, c. C-34 (the “Act”), Kolt sued Husky and Exxon on the allegation that their conduct was anti-competitive. The trial judge held in favour of Kolt, finding Husky and Exxon liable for the torts of conspiracy and interference with business relations in that their agreement unduly limited or lessened competition. He awarded damages “at large” in the amount of $5 million, punitive damages of $500,000 against each defendant, and investigation costs in the amount of $75,000.

BACKGROUND

321665 Alberta Ltd. v. Husky Oil Operations Ltd., 2013 ABCA 221Areas of Law: Oil & Gas; Competition; Fuel Hauling Services

~Applicants for hearing and for review and variance of decisions of Energy Resources Conservation Board required to provide sufficient evidence at “preliminary question” stage~

CLICK HERE TO ACCESS THE JUDGEMENT



July 2013


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321665 Alberta Ltd. v. Husky Oil Operations Ltd., (cont.)

Husky and Exxon’s appeal was

granted. The Act does not preclude a business from restructuring their operations, particularly to increase efficiencies and reduce unnecessary costs. The purpose of the Act is to provide businesses with a fair opportunity to compete for business. The term “unduly” is used in s. 45 of the Act to differentiate between the ordinary lessening of competition from

the fluctuations in a free market economy from the artificial lessening of competition due to conduct that “unduly” prevents or reduces competition. The trial judge had failed to consider that Husky and Exxon provided Kolt with a fair and equal opportunity to become their exclusive fuel hauling service provider. Further, co-owners of assets must be able to jointly agree on how to manage their operations and, as in this case, reduce their costs. Kolt also argued that, during the evaluation process, it had felt pressured to disclose its profit margins. However, no evidence suggested that Husky and Exxon attempted to use such information to reduce suppliers’ profit margins, their prices or the volume of work provided. The Court of Appeal concluded that Husky and Exxon were not liable to Kolt and held that, even if they had been, they would have reduced the damages award and not awarded punitive damages or the investigation costs in this case.

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APPELLATE DECISION

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“The decision is one of a very few cases to consider the application of the criminal conspiracy provision of the Competition Act (the “Act”) to a collaboration for the procurement (versus the supply) of goods or services. Its precedential value on

this point is likely limited to any legacy cases. The 2010 amendments to the Act specified that the criminal provision applies only to agreements among competitors to fix prices, limit supply or allocate markets in the supply of a product. The decision is, however, of interest for a number of the points made by the Court on the application of the old s.45 and related matters. The conclusions that are of interest to us as counsel for Husky include:

1. The Court was satisfied the conduct of Husky/Mobil was not the type that should engage the former s.45. The Court of Appeal did not undertake a detailed PANSI analysis, arguably because they did not see the agreement to use a single supplier as being an agreement to lessen or prevent competition at all, and therefore did not embark on further analysis to determine if there was an “undue” lessening of competition flowing from the agreement. The Court noted that the Trial Judge focussed on the consequences to Kolt rather than the conduct of Husky/Mobil and its impact upon competition. This is a critical distinction and a potential pitfall for those unfamiliar with the objective of competition law and policy, which is to protect competition and not an individual competitor.

2. The Court found that businesses like oil and gas companies which often jointly own assets (and share the costs of operating those assets) with competitors by necessity

I R v. Nova Scotia Pharmaceutical Society, [1992] 2 SCR 606 (“PANS”) is generally regarded as the leading authority on the test for an undue lessening of competition under the former s.45.

COUNSEL COMMENTS

Comments provided by Jerry Patterson, Barry Zalmanowitz, Q.C., and Ryan Quinlan, Counsel for the Appellant (Respondent by Cross-Appeal), Husky Oil Operations Ltd.

Ryan Quinlan

321665 Alberta Ltd. v. Husky Oil Operations Ltd.

Jerry Patterson Barry Zalmanowitz, Q.C.

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must and generally should be permitted to make joint decisions on how to properly manage the operations, including decisions to reduce costs and increase efficiencies.

3. The Court declined to decide whether the single economic entity defence which has developed in U.S. antitrust law in relation to section 1 of the Sherman Act is applicable to s.45 of the Act. The Court clearly stated that where the parties intended to, and did, remain separate legal entitles, their collaboration on the jointly-owned properties did not insulate them from the application of the Act.

4. The Court’s assessment of compensatory damages, while technically obiter dicta given its finding on liability, is of interest in a couple of respects.

First, the Court noted that: an award of damages at large is not a valid substitute for a proper assessment of damages arising from a tortfeasor’s conduct; a plaintiff must still prove damages; the outcome of an award must still reasonably approximate actual or foreseeable loss; and an award of damages at large arises where the nature of the tort has made it impossible for the plaintiff to prove damages with precision. This is an important series of statements as we are unaware of any prior case which provided such clear direction on when and how an award of damages at large can be made.Second, the Court indicated that the preferable approach to quantifying damages in cases where the alleged tort has caused a business to cease operations is to assess the value of the business as a going concern, versus attempting to calculate a number representing a loss of future profits. The latter approach, the Court noted, invites too much speculation. In adopting the business valuation approach, the decision is consistent with a line of Ontario cases.

5. The Court’s handling of the punitive damage award is also notable. The decision affirms the concept that conduct which is directed toward a corporation’s goal of generating profit for its shareholders is, without more, insufficient to warrant an award of punitive damages. To attract punitive damages, the conduct must be “harsh, vindictive, reprehensible and malicious”. The Court found no evidence of any such malicious intent in Husky/Mobil attempting to increase the efficiency of their operations.

6. The Court also provided some guidance on “investigation” costs that may be recoverable in damage claims under s.36 of the Act. The Trial Judge had awarded $75,000.00 without any specific proof of costs incurred. The Court said that investigation costs require specific proof and mere participation by the Plaintiff in the litigation is not compensable as “investigation costs”.”

COUNSEL COMMENTS



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HSBC Bank Canada v. Fuss, 2013 ABCA 235Areas of Law: Business; Fraud; Unlawful Conduct Conspiracy; Director’s Duties

~Conspiracy found based on overall agreement between parties to prevent bank from realising debt without knowledge of one party’s details of that fraud~

BACKGROUND

In 2001, the respondent bank provided an

operating line of credit to 828326 Alberta Ltd. (“828”) secured by a general security agreement which provided that any money collected or received by 828 was subject to a trust in favour of the respondent. 828 operated as a wholesale and retail distributor of electronic equipment with Cameron Kendrick (“Kendrick”) as its sole director and shareholder. The appellants, David Fuss (“Fuss”) and Rhonda Thuna (“Thuna”), were the sole directors of several other small companies that dealt with 828. In 2003, a new company, EWE, was incorporated in which

Thuna became the director. During that year and into 2004, 828 often exceeded the limit of its line of credit with the respondent and eventually the respondent began dishonouring all of 828’s cheques. Kendrick and Fuss opened an account with TD Canada Trust (“TD”) under EWE’s name and began depositing all of 828’s receivables and proceeds from the sale of its inventory into that account. The respondent was advised of the account but not that 828’s business was operating under EWE or that EWE had owned the TD account. Although over $1.2 million was received in the TD account by May 2004, 828 did not make any payments to the respondent. That month, the respondent made a demand for payment with no response. A month later, a new corporation, 1100, was incorporated to take over 828’s business operations with Fuss and Kendrick’s fathers acting as the directors. In June 2004 the respondent appointed a receiver and manager over 828 and a month later petitioned it into bankruptcy with negligible recovery. Further, 828’s electronic records had been destroyed. The respondent successfully sued Kendrick, Fuss, Thuna and their companies for unlawful conduct conspiracy aimed at preventing the respondent from recovering the debt owed by 828.




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HSBC Bank Canada v. Fuss, (cont.)

APPELLATE DECISION

Kendrick did not appeal, and the appeals

of Fuss and Thuna were dismissed. The trial judge had correctly stated and applied the test for unlawful conduct conspiracy, which required five key elements: 1) the parties had acted in combination; 2) their conduct was unlawful; 3) their conduct was directed towards the plaintiff; 4) they had knowledge that injury to the plaintiff would result; and 5) their conduct had caused injury to the

plaintiff. He also correctly found that they had breached their statutory fiduciary duties owed to their companies as directors through authorizations of transactions they knew had no legitimate business purpose. The main ground of appeal argued by Fuss and Thuna was that because the trial judge had found they were not aware of Kendrick’s fraud, he erred in finding a conspiracy. However, even though Fuss and Thuna may not have been aware of the details of Kendrick’s plan, they were aware of his overall intentions to deprive the respondent from its ability to realise 828’s debt and, cooperating by agreement to achieve this goal was sufficient to constitute a conspiracy of this nature.

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1985 Sawridge Trust v Alberta (Public Trustee), 2013 ABCA 226Areas of Law: Minors; Trust; Public Trustee; Advance Costs

~Strict criteria set by Supreme Court of Canada in Little Sisters for awarding advance costs not rigidly applied to all cases~

In response to anticipated changes

to the Indian Act, R.S.C. 1985, c. I-5 that would have returned membership to native women previously lost through marriage, in 1985 the Sawridge First Nation set up a trust to hold properties (with a current value of $70,000,000) for the benefit of all Sawridge members who would have qualified on April 15, 1982 (the “Trust”). The

trustees of the Trust, intending to distribute the assets of the Trust, identified that the existing distinction of “beneficiaries” was potentially discriminatory and sought to change that definition on the advice and direction of the court. The chambers judge noted that such a change would affect certain children and ordered that the Public Trustee be notified to represent these children who would not otherwise be represented by counsel. The Public Trustee applied to be appointed their litigation representative. In granting that application, the judge also awarded advanced costs to the Public Trustee on a solicitor and his own client basis and exempted the Public Trustee from liability for any other costs that may arise during the litigation. The trustees appealed the order only as it related to advance costs and exemption from liability for costs.

BACKGROUNDCLICK HERE TO ACCESS

THE JUDGEMENT

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The trustees argued that the chambers judge had

erred in ruling that the strict criteria of “impecuniosity, a meritorious case and special circumstances”, established by the Supreme Court of Canada in Little Sisters Book and Art Emporium v. Canada (Commissioner of Customs and Revenue), 2007 SCC 2 (“Little Sisters”) for awarding advance costs, did not apply to these proceedings. However, these criteria were not intended to apply to all awards of advance funding. Such criteria were intended to apply in adversarial situations where an impecunious private party wishes to sue another private party or public institution and requests to have their costs paid in advance. In this case, the Public Trustee

was not appointed to act on behalf of the minors to sue another party. The role of the Public Trustee was merely to ensure that their interests are taken into account during the trustees’ application for advice and direction regarding the Trust. Cases have held that in circumstances where trustees ask the court for guidance on the construction or administration of a trust, “the costs of all parties necessarily incurred for the benefit of the estate will be paid from the fund”. The Public Trustee Act, S.A. 2004, c. P-44.1 and Rule 2.21 of the Rules of Court provide the court with a large discretion on awarding costs, including advance costs. Further, the chambers judge has inherent jurisdiction under the parens patriae doctrine to award advance costs in the best interests of the child when legislation is silent on the matter. As such, the trial judge did not err in awarding advance costs to secure the independent representation of the Public Trustee to protect the interests of those children affected in this proceeding.

APPELLATE DECISION

1985 Sawridge Trust v Alberta (Public Trustee), (cont.)



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Okotoks (Town) v. Foothills (Municipal District No. 31), 2013 ABCA 222Areas of Law: Municipal Law; Validity of Bylaw; Limitation Period

~Six-month limitation period in Rule 3.15(2) applies to applications for declaration of validity of bylaw~

BACKGROUND

The Town Okotoks and the Municipal District

of Foothills own adjacent land subject to plans that conflict with respect to residential density, namely, Bylaw 15/2010, which adopts an area structure plan (the “Bylaw”), and the earlier adopted inter-municipal development plan. The Bylaw was passed on August 11, 2010. In the summer of 2011, pursuant to s. 536 of the Municipal Government Act, R.S.A. 2000, c. M-26 (the “MGA”), the Town of Okotoks brought an originating application to declare the Bylaw invalid and void on the grounds that it conflicted with the inter-

municipal development plan. The chambers judge refused to grant the application on the basis that it had not been brought within the requisite six-month period after the Bylaw was passed. Even though s. 536 of the MGA does not prescribe a limitation period, the judge held that the six-month limitation period found in Rule 3.15(2) of the Rules of Court, which applies to “an originating application for judicial review to set aside a decision or act of a person or body”, applied in these circumstances. The Town of Okotoks appealed, arguing that the six-month limitation period set out in Rule 3.15(2) did not apply to their application on several grounds. Firstly, they alleged that a bylaw does not constitute a “decision or act” of a body as stipulated in the Rule. Further, they argued that the Rule only applies to judicial remedies and not to the statutory remedy in which they seek, and lastly, that Rule 3.15(2) conflicts with the MGA and therefore the MGA trumps the Rule.




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The appeal by the Town of Okotoks was

dismissed. A municipal council can only act by resolution or bylaw and, as such, a bylaw is considered a “decision or act” of a body as set out in Rule 3.15(2), and therefore applies accordingly. In answer to the statutory remedy argument, s. 536 of the MGA mandates that a bylaw must be challenged by way of an application to the Court of Queen’s Bench for a declaration and is thus governed by the Rules. Under principles of statutory interpretation, use of the same word in different pieces of legislation addressing the same subject matter, i.e. use of the term “declaration” in the MGA and the Rules regarding originating applications

for a declaration, are assumed to have a consistent meaning. Therefore, it was well within the intent of the Legislature that the judicial review rules, including Rule 3.15(2), applied to challenges of bylaws in addition to traditional judicial review remedies. The Town of Okotoks argued further that since there is a 60-day limitation period in s. 537 of the MGA for enumerated instances where one can challenge the validity of a bylaw, and yet no limitation period provided in s. 538 for other specific circumstances to challenge a bylaw, the Legislature intended there to be no limitation on an application pursuant to s. 536 as no limitation period was provided in that section either. However, had the Legislature intended there to be no limitation period, it could have added the words “at any time” in s. 536 as it had done so in s. 538 to indicate that no limitation period applied. Rule 3.15(2), on the other hand, supplements s. 536 of the MGA with respect to the practice and procedure required to apply to an application for a declaration regarding the validity of a bylaw.

APPELLATE DECISION

Okotoks (Town) v. Foothills (Municipal District No. 31), (cont.)

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OnPoint Legal Research L.C. has been researching and preparing memoranda and facta for other lawyers for over 14 years. In the

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Ellen Vandergrift, OnPoint Legal Research- Ellen clerked at the Court of Appeal of Alberta before articling and practicing at Fraser Milner Casgrain. She subsequently spent several years as legal counsel to the Queen’s Bench and has now been with OnPoint for over eight years. She is well-suited to appellate work and particularly enjoys researching and analyzing complex legal issues and preparing facta.

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Chair: Sarah Picciotto, Founder of OnPoint Legal Research- As a clerk to the B.C.S.C. in 1998, Sarah learned the importance of sound legal research. She gained practical experience as a litigator with Edwards Kenny & Bray before leaving practice to establish OnPoint in 2000. Sarah is committed to providing OnPoint’s clients with a competitive edge. She is dedicated to ensuring that OnPoint produces nothing less than exceptional work and offers outstanding service.

Monika Gehlen, Davis LLP- Monika is a partner with Davis LLP, where she specializes in written advocacy, appellate practice, legal opinions, and strategic advice. As a member of the firm's Legal Research and Litigation Practice Groups, Monika has extensive experience in the research and analysis of complex legal issues.

Do-Ellen Hansen, Borden Ladner Gervais- As a partner at Borden Ladner Gervais, Do-Ellen provides complex research analysis and advice on diverse legal issues to private and Crown corporations, banks, and insurers. In the course of her practice, she regularly prepares legal opinions and analyses, litigation briefs, and legal arguments for trials, appeals, and arbitrations.

Michelle Maniago, Borden Ladner Gervais-Michelle Maniago practises in the area of civil litigation and arbitration at Borden Ladner Gervais, with an emphasis on commercial and corporate disputes. She also practises as a legal research lawyer and works with both solicitors and litigators to prepare legal opinions. Prior to joining the firm, Michelle had the opportunity to hone her legal research skills as a clerk with the B.C.C.A.


Meghan Maddigan, Legal Community Liason, Courthouse Libraries BC- Meghan is the point person for training at the library and is committed to helping lawyers succeed in their practice through outreach. Prior to joining Courthouse Libraries BC in 2010, Meghan practiced law for five years with a small firm where she gained first-hand experience learning what is required to conduct successful legal research in private practice.

Eric Sherbine, Dentons Canada LLP- Eric Sherbine is a Research Specialist with Dentons Canada LLP, where he provides legal and business research services. He has substantial legal research experience in both Canada and the United States. Prior to immigrating to Canada, he practiced as an employment and labour lawyer in the US.

Agenda- Legal Research: From Issues to Solutions 2013

8:30- 9:00 Registration and Pastries and Coffee

9:00- 9:15 Welcome from Sarah Picciotto, Founder of OnPoint

9:15- 10:00 Ellen Vandergrift- “Starting Out on the Expedition and Staying on the Right Course”

- The importance of paper and online secondary materials in legal research (texts, digests, encyclopedias and course materials) - Tips on the best secondary sources to use and how to make the most of them - Making good research choices- when to stop, when to take a different path, when to check back with the client or supervising lawyer

10:00-10:45 Do-Ellen Hansen, Michelle Maniago and Ellen Vandergrift- "Navigating the Electronic Terrain, Part One: The General"

- Insider tips from research lawyers who perform computer research every day - Tips on how to construct effective searches and manage search results - Noting up as an essential research tool

10:30- 10:45 Coffee break

10:45- 12:00 Do-Ellen Hansen, Michelle Maniago and Ellen Vandergrift- "Navigating the Electronic Terrain, Part Two: The Specific"

- Pointers on when to use which resource for what task - Cost-efficient uses of electronic resources - Important resources for keeping current

12:00- 1:00 Lunch (on your own, but save room for Full Afternoon Tea Service at 2:30)

1:00- 2:00 Meghan Maddigan- "Tackling Legislative Research Like a Pro”

- Making it modern: How to ensure you are looking at the most current, in-force laws - So many sources, so little time: Where to start and finish when looking at legislation - Working backwards: How to trace specific provisions through time - Who said what: Finding judicial consideration of legislation

2:00- 2:30 Eric Sherbine, "Handling American Research Sources" - Available resources for specific tasks - Free vs. paid sources - What can you reasonably expect to research without U.S. training - Answers to lawyers' commonly asked questions about conducting U.S. research 2:30- 2:45 Break- Prepare for Full Afternoon High Tea Service during next presentation

2:45-3:15 Monika Gehlen , "Presenting Your Work- Writing to Win" - Tips for better written advocacy - Factum writing 3:15- 4:15 Group Panel- “Time to Take the Plunge: A Sample Research Issue, Step By Step”

Agenda (cont.)

Research to a

T

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Who is OnPoint Legal Research?

Who We Are: Our research lawyers are well versed with both traditional research sources and the latest in research technology. They are academics -- all have completed a clerkship in B.C. or Alberta. In addition, they have all had the benefit of obtaining essential practice experience as lawyers with major downtown law firms.

What We Do:Our research lawyers possess diverse legal backgrounds, enabling us to handle projects of any size on any issue. We work closely with our clients to ensure that we have a thorough understanding of the scope of the project, the specific issues involved, and the perimeters of the desired end product. We complete a variety of projects for our clients, from case summaries to complex memoranda and facta.

How to Contact Us:

t. 1.888.894.4280e. [email protected]. www.onpointlaw.com

“Our litigation firm does not have the resources to do quick or extensive research, especially in the middle of a proceeding. We find the services of OnPoint Legal Research to be responsive, effective and good value and we have no hesitation in recommending them.”

Hugh S. McLellan, McLellan Herbert

“OnPoint is a trusted associate for research on specialty points of law and document review assistance in large cases for my busy sole practice. Sarah and her team never let me down.

On time, on budget …On Point.”

Morag MacLeod, Morag MacLeod LC

Sarah Picciotto, B.A., LL.B. Founder

Alberta Take Five July 2013

Documents

Transcript of Alberta Take Five July 2013