GSB# 2023-02560, 2023-02561
UNION# 2023-0271-0004, 2023-0271-0005
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union (Cormier)
Union
- and -
The Crown in Right of Ontario (Ministry of the Attorney General)
Employer
BEFORE
Heather Ann McConnell
Arbitrator
FOR THE UNION
James Sommerville Ontario Public Service Employees Union Grievance Officer
FOR THE EMPLOYER
Chris Tikkanen Treasury Board Secretariat Employee Relations & Negotiations Employee Relations Advisor
HEARING
March 3, 2025
Decision
Introduction
1The Grievor is employed by the Ministry of the Attorney General, Court Services Division, as a Flexible Part-Time Court Services Officer (FPT CSO 1096 Hours). She has been employed in that capacity since March of 2013. Originally the Grievor was assigned to the Brampton Courthouse, but she took a temporary position at the Milton Courthouse in 2016.
2Before the Board are two grievances. The first is a conversion grievance, filed on December 5, 2024, alleging that the Employer breached the collective agreement, including the management rights clause, when the Employer failed to convert the Grievor to a permanent FPT CSO 1096 Hours position at the Milton Courthouse. The second is a recall/temporary assignment grievance, filed on the same day, alleging that the Employer violated the collective agreement, including the management rights clause, when the Employer recalled the Grievor from the Milton to the Brampton Courthouse.
3The Employer raises two interconnected preliminary issues in respect of the Board’s jurisdiction to hear the grievances. First, the Employer argues that the particulars provided by the Union expand the grievances beyond their original scope. As a result, the Employer requests that the Board strike several paragraphs in the particulars letter. Second, based on the stripped-down particulars, the Employer takes the position that the grievances should be dismissed as failing to make out a prima facie case of a violation of the collective agreement.
4The Employer agrees that its second preliminary motion is dependent upon a finding in respect of the first. In other words, the Board can only conclude that there is no prima facie case, if the portions of the particulars letter identified by the Employer are struck.
5The Union disagrees that it inappropriately expanded the scope of the grievances. It is the Union’s position that the facts outlined in its particulars letter are inherent to the grievances, were known to the Employer, were discussed during the grievance process, and make out a prima facie case of a violation of the collective agreement.
6In the alternative, and to the extent that any of the particulars are found to be beyond the original scope of the grievances, it is the Union’s position, that any expansion should be permitted because there is no prejudice to the Employer, the Employer was well aware of the underlying facts that the Union wants to rely on, no additional witnesses or evidence would be required, and it would not prolong the hearing process.
7The Union requests that the grievances be heard on their merits and that the Board dismiss the Employer’s preliminary motions.
8Article 22.16 of the collective agreement applies to this case and confirms that decisions that fall under that provision will not have precedential value. Those decisions are also expected to be succinct and issued in short order.
9This decision addresses only the preliminary motions of the Employer and not the merits of the case.
10For the reasons that follow, the Employer’s preliminary motions are dismissed.
Background
11The Union’s particulars are appended to this decision for ease of reference and are not reproduced in full in the body of the decision. However, some background on the Grievor’s work history is helpful to understand the nature of the dispute. While the Board did not hear evidence regarding the Grievor’s work history and the Board is not making a finding of fact in this respect, it is helpful to understand the facts as the Parties asserted them in their respective arguments. Many of these facts appear not to be in dispute.
12The Grievor worked at the Brampton Courthouse from March 2013 to November or December of 2016. At that time, the Grievor was successful in obtaining a temporary position at the Milton Courthouse. The position had the same title, classification, function, duties, and hours. The only meaningful difference between the two positions was the work location.
13The Grievor and the Employer signed 5 consecutive Temporary Assignment Agreements (TAA) in respect of the assignment to the Milton Courthouse. They covered the period between November 21, 2016, and July 4, 2020. The TAAs each confirm that the Grievor’s permanent or home position is the Brampton Courthouse, and that the temporary assignment position is in Milton. There are provisions in each of the agreements that confirm that the temporary work arrangement can be extended by the mutual agreement of the signatories, that it can be terminated early with two weeks’ notice and that upon termination or expiry, the Grievor will return to her home position at the Brampton Courthouse.
14A key dispute between the Parties is what happened after July 4, 2020, and the expiry of the last signed TAA. There is no TAA for the period from July 2020 to July 2021. It is the Employer’s position that this was an oversight due to the pandemic. The Employer produced an unsigned TAA for the period between July 2021 and July 2022 but could not confirm it was sent to or received by either the Grievor or the Union. It does not appear that there was a TAA thereafter, signed or unsigned.
15The Employer argues that notwithstanding the absence of a signed TAA from July 4, 2020 onwards, the TAA terms continued to apply to the Milton position, the Grievor’s home assignment continued to be at the Brampton Courthouse, and the Employer maintained its right to end the temporary assignment with two weeks’ notice, which it says it did when operational requirements changed and the Grievor was needed in Brampton. It is the Employer’s position that it took no steps to permanently assign the Grievor to the Milton Courthouse and that it is within its sole discretion to make that determination.
16The Union, on the other hand, takes the position that no further TAA was signed because the Grievor was permanently reassigned to the Milton Courthouse in or around February of 2020, when the permanent position she was backfilling became vacant. The Union says the employee who the Grievor was temporarily replacing, took a permanent position at the Brampton Courthouse and thus the Milton position became available to her on a permanent basis.
17The Union argues that, at that time, the Employer exercised its discretion under Article 8.6.3 to directly assign the Grievor to the position permanently (as she had held the position for 18 months or longer). The Union acknowledges the permanency was not formally conveyed to the Union or the Grievor. However, the Union asserts that the Employer’s actions thereafter are consistent with the Grievor having been permanently assigned to Milton and that they only changed after the Grievor took a sick leave which she attributed to mold in the Milton Courthouse.
18The Employer objects to the facts relied upon by the Union, as outlined in its particulars letter, as they relate to the other employee’s employment location and status, which the Employer says are irrelevant to the Grievor. In addition, the Employer takes the position that there is no basis for the Union’s claim that it exercised its discretion under Article 8.6.3 and it disagrees that its decision to move the Grievor was connected to her sick leave or had anything to do with health and safety concerns raised. It is the Employer’s position that the decision was entirely operational and that it retained the discretion to do so.
19In any event, the Grievor was recalled to the Brampton Courthouse effective October 23, 2023. At the time of the recall, the Grievor was off on sick leave and remained on sick leave as of the date of the hearing.
Impermissible expansion of the scope of the grievances
20There is no disagreement between the Parties that the starting point for the Board is a review of the grievance forms and the grievance context including the discussions between the Parties during the grievance process. They agree that the Board is to take a liberal view of the grievances, that grievances should not be won or lost on a technicality, but that the Employer is entitled to reasonably understand what issues are to be addressed and should not be surprised at the hearing with entirely new allegations.
21While the Parties agree on the state of the law, they disagree on how it should be applied to the circumstances at hand and what the Board should draw from the cases relied upon. In respect of its expansion of the scope argument the Employer relied upon OPSEU (Jones et al.) and Ministry of Labour, GSB No. 2006-1204 (2010) (Abramsky). The Employer also relied upon OPSEU (Martin et al.) and Ministry of Community and Social Services, GSB No. 2013-3579 (2015) (Anderson), in respect of its prima facie argument.
22The Union, for its part, relied on the following: OPSEU (Couture et al.) and Ontario (Ministry of Government Services), GSB No. 2008-3329 (2011) (Dissanayake); OPSEU (Martin et al.) and Ontario (Ministry of Community and Social Services), GSB No. 2013-3579 (2015) (Anderson); OPSEU (Bernard et al.) and Ontario (Ministry of Natural Resources and Forestry), GSB No. 2022-0985 et al. (2024) (Herlich); Blouin Drywall Contractors Ltd. and United Brotherhood of Carpenters and Joiners of America, Local 2486, CanLII 707 (1975); Perry Sound (District) Social Services Administration Board v. OPSEU, Local 324, 2003 SCC 42; St. Lawrence Lodge, Brockville and Canadian Union of Public Employees, Local 2107 (2013) (Luborsky); Ronkai and Ontario (Ministry of Community Safety and Correctional Services, PGSB No. 2013-1964 (O’Neil); Re Horizon Operations (Canada) Ltd. and Communications, Energy & Paperworkers Union, Local 2000 (2000) (Coleman); Ontario Secondary School Teachers’ Federation, District 12 (Lazar) v Toronto District School Board (2015) (Howe); OPSEU (Union) and Ontario (Ministry of the Solicitor General), GSB#2019-0719 et al. (2022) (Petryshen).
23In its particulars letter at paragraphs 34 and 35 the Union outlined its position on what the grievances are about. It reads as follows:
That the Employer violated Articles 2 and 8.6.3 in having not permanently assigned the Grievor to the Milton Courthouse after eighteen months of continuous service in that position;
Notwithstanding that the Grievor maintains that they ought to be a permanently assigned employee of the Milton Courthouse, that the Employer, when they recalled the Grievor back to the Brampton Courthouse in October of 2023, reprised against the Grievor for having spoken up about their ill health in the workplace and thus violated Article 3 of the collective agreement.
24It is the Employer’s position that based on a plain reading of the grievances, they allege only a violation of the management rights clause. Article 8.6.3, the conversion clause, is not specifically referenced, and, in any event, it is entirely within the discretion of the Employer as to whether it exercises that right and it says it did not. There is also nothing on the face of the grievances confirming that the Union was alleging that the Employer engaged in a reprisal or discriminated against the Grievor for taking a sick leave or raising health concerns in the workplace. It is the Employer’s position that these issues were not raised during the grievance process, identified before a mediation held between the Parties, and were only provided to the Employer just prior to the commencement of the hearing.
25Given that the starting point is a review of the grievances, it is helpful to reproduce them here. The statement of the conversion grievance is as follows:
I grieve a violation of the collective agreement including, but not limited to Article 2 when the Employer did not convert me to CSO FPT 1097 permanent and flexible part-time position at Milton Courthouse and the Union reserves the right to rely upon any other applicable article or legislation.
The remedy requested is as follows:
Full redress, full disclosure, to assigned to FPT CSO 109[6] permanent and flexible part time position at Milton Courthouse including any lost monies, time or credits and any other remedy deemed appropriate by an arbitrator.
The statement of the recall/temporary assignment grievance is as follows:
I grieve a violation of the collective agreement including but not limited to Article 2 when the Employer recalled me to Brampton rather than staying at Milton and the Union reserves the right to rely upon any other applicable article or legislation.
The remedy requested is as follows:
Full redress, full disclosure, to remain in my assignment at the Milton Courthouse including any lost monies, time or credits and any other remedy deemed appropriate by an arbitrator.
26Based on the grievance forms, the Board finds that Article 8.6.3 is incorporated by reference into both grievances. The conversion grievance explicitly uses the term “conversion” which is language taken directly from Article 8.6.3. This fact was acknowledged by the Employer. In the recall/temporary assignment grievance the basis of the Grievor’s allegation is that she was not permitted to stay in Milton, which she says is a violation of the collective agreement because that was her position. She specifically asks, by way of remedy, that she be permitted to “remain in [her] assignment.” An assignment she believed she had pursuant to Article 8.6.3.
27The inclusion of Article 8.6.3 in the grievances is confirmed in the notes of the grievance meeting. According to those notes, which both the Employer and the Union agree are an accurate reflection of the discussion, the Grievor says repeatedly that she believed she had been made permanent at the Milton Courthouse. While the Grievor did not specifically reference the article number, she did confirm that the “CA had some provision” for conversion although she was “not sure which one”. She also asserted that she wasn’t recalled to Brampton at other times when it would have been reasonable to do so, that she was paid travel time when she went to Brampton, and that she had been repeatedly asked by management at Brampton if she would agree to return which she elected not to do. It is the Grievor’s position that if she was not permanently assigned to Milton, management at the Brampton Courthouse would not have asked her if she wanted to return because they would have had the ability to recall her.
28The issue of the Grievor’s work status (where she was assigned and whether she was assigned on a permanent or temporary basis) is one that must be determined in a hearing on the merits in the whole of its context. This is particularly so given the absence of a signed TAA or a formal notice of conversion and where both the Employer and the Union’s theory of the case is dependent upon their view of the Grievor’s status. While the Employer may be correct that the Board does not have jurisdiction to force the Employer to exercise its discretion if it has not done so freely, an issue the Board need not determine at this time, a factual finding regarding whether it did exercise that discretion is something that can and should be decided. Determining the Grievor’s employment status in 2020 and thereafter is necessary to establish what collective agreement rights, protections and actions can follow.
29Paragraphs 4-5, 10-11, and 13-20 of the Union’s February 21, 2025, particulars letter are relevant to determining the Grievor’s work status. If the Board takes them to be true and provable, as it must do on a prima facie motion, they are capable of supporting a potential violation of the collective agreement. If the Grievor had been made permanent in 2020 or thereafter pursuant to Article 8.6.3, then the Union may be correct that the Employer could not recall her to Brampton in the manner that it did. However, if the particulars are disputed at hearing and it is established that she continued to be temporarily assigned to Milton, it may be that the Employer had the discretion to move her in the manner that it did. In any event, this determination cannot be made on a preliminary basis.
30Having regard to the above, the Board is satisfied and hereby finds that the grievances reference both Article 2 and Article 8.6.3 and establish a prima facie case of a violation of the collective agreement.
31Notwithstanding this conclusion, the Board must also address the Employer’s argument that the Union is attempting to raise, for the first time, allegations of reprisal and discrimination and that it ought not be permitted to do so. It is the Employer’s position that the grievances allege that it has acted improperly or unreasonably but it argues that allegations of discrimination or reprisal are an improper change in grounds. The Employer requests that the Board strike those particulars which identify the factual matters that the Union says the Employer improperly took into consideration in making its decision to move the Grievor back to Brampton.
32The Union acknowledges that assertions of reprisal and discrimination were not specifically addressed on the face of the grievances nor were they raised at the grievance meeting. The Union argues, however, that the grievances were clearly about what was happening when the Employer made its decision to move the Grievor from Milton to Brampton and the Employer’s motivation is clearly relevant to whether it exercised its management rights in an appropriate manner or not.
33The grievance forms allege that management did not act appropriately, and it is the Union’s position that such allegation necessarily requires a finding of discrimination and/or bad faith on the part of the Employer. The Union points out that both grievances allege a violation of the management rights clause, both ask for full disclosure in its remedy, and the Union Representative put the Employer on notice during the grievance meeting that it would require the Employer to explain why it recalled the Grievor when it did. It is the Union’s position, that although it has not received particulars from the Employer outlining why it took the actions that it did, at the time that it did, the Union nonetheless provided particulars on its view of what was motivating the Employer at the time.
34The grievances raise a number of essential questions. They include why the Grievor was moved when she was, whether the Employer had the right to move her when it did, and if so, whether that right was exercised in a manner that was consistent with its management rights. Given the particular circumstances of this case and what was discussed at the grievance meetings, the Board is not prepared to strike paragraphs 21-23 and 25-31 as an improper expansion of the grievances. Those paragraphs, and the facts alleged therein, may be relevant to answering why the Employer moved the Grievor when it did and whether it did so in an appropriate and reasonable manner (allegations that the Employer accepts form part of the grievances).
35While it may be that the Union is raising for the first time allegations of reprisal and discrimination, the Board does not find that those allegations are so foreign to the issues outlined in the grievances to amount to an improper change in grounds. In this case, the allegations that the Employer acted in an inappropriate and unreasonable matter can connote or encompass a claim that the Employer was motivated in whole or in part by the Grievor’s statements in the workplace related to mold and health and safety issues and/or by her taking a sick leave. In this case, the Board finds that the Union’s particulars were a legitimate clarification of its position and there is no real surprise or prejudice to the Employer. The Union is also not raising new factual allegations or things that happened after the events, but those that occurred at the time that the Employer’s decision to move the Grievor was made.
36In any event, even if the scope of the grievances has been expanded by the Union in asserting these particulars, that expansion is warranted where the Union put the Employer on notice that the Employer’s reason for moving the Grievor to Brampton was being challenged, there is no prejudice to the Employer in its ability to respond to that allegation, the expansion will not require additional facts or witnesses be called, and it will not prolong the hearing process.
37For the reasons outlined above, the Employer’s motions are denied.
Dated at Toronto, Ontario this 15^th^ day of April 2025.
Appendix
Re: OPSEU Grievance #2023-0271-0003/0004 (Cormier, Dianne) and OPS Ministry of Attorney General
Please see below with respect to particulars and production on the above-noted matter.
These particulars are provided without prejudice to any position the Union may take in relation to the material facts underlying the grievance. The Union explicitly reserves the right to add or amend these particulars as necessary. The Union relies on statements made by the Grievor regarding this incident.
Facts
The Grievor is employed as a Flexible Part-Time Court Services Officer 1096 Hours (FPT CSO 1096 Hours).
They have been under the employ of the Ministry of the Attorney General, Court Service Division since March 18, 2013. The Grievor’s original headquarters, at that time, was Brampton Courthouse.
On December 5, 2016, after a successful job competition process for a position as temporary (9 months) FPT CSO 1096 Hours at the Milton Courthouse, the Grievor is assigned to work at the Milton Courthouse at 491 Steeles Avenue East.
Prior to December 5, 2016, another Milton Courthouse employee, Phyllis R., whose permanent position was also an FPT CSO 1096 Hours, had taken a temporary position at Brampton Courthouse as a Court and Client Representative (CCR).
At this time, the Grievor believed that their temporary assignment with Milton Courthouse served as a backfill for Phyllis R. The Grievor maintains this perception for the entirety of her employment with Milton Courthouse and into the present day.
The Grievor, operating under the assumptions of (5) above, signed Temporary Assignment Agreements (TAA) covering the following periods of time:
November 21, 2016 to December 31, 2016
November 21, 2016 to March 31, 2017 (the same start date as the first TAA is believed to be an error caused either by using the previous document as a template but neglecting to revise the start date, or the date parameters of the original TAA were recorded incorrectly)
March 31, 2017 to July 16, 2017
July 17, 2017 to January 27, 2018
January 27, 2018 to July 16, 2018
July 16, 2018 to July 13, 2019
July 12, 2019 to July 4, 2020
Those TAAs listed in (6) above indicate that the Grievor’s home position was 00046050, Court Services Officer, 00036H – Usher and Messenger, CSD MCO Brampton Crt Ops 6, Court Services Division, Ministry of the Attorney General.
Those TAAs indicate also that the Grievor’s temporary assignment position was 00048308, Court Services Officer, CSD MCO Halton Crt Op2, Court Services Division, Ministry of the Attorney General. Her hours of work are specified as being 21 hours per week, equivalent to the 1096 hours per year expected for a FPT CSO 1096 Hours contract.
In February 2020, a permanent FPT CSO position was vacated by Phyllis R. This member becomes at that time a permanent, regular Court and Client Representative at the Brampton Courthouse.
Because the Grievor was not asked to sign an additional TAA upon the departure of Phyllis R., and because the Grievor understood that she had been backfilling that member, the Grievor concludes that the Employer had exercised its right pursuant to Article 8.6.3 to directly assign an employee who has held a position for 18 months or longer, and that they were now assigned to a permanent position as FPT CSO 1096 Hours at the Milton Courthouse.
In this same time period, from March 2020 onward, due to the COVID-19 pandemic, the Milton Courthouse experienced workplace disruptions such as a transition to virtual hearings. During this time, the Grievor did not perform the full extent of their duties as an FPT CSO, Court Services Officers not being needed as prior. This alteration of duties, in conjunction with the perceptions of (10) above, further contributed to the Grievor’s belief that they had been provided with a permanent role at Milton Courthouse.
An additional TAA was allegedly produced in 2021, covering the dates of July 12, 2021 to July 10, 2022. However, the Grievor had no knowledge of this form. It was not presented to the Grievor and does not bear her signature.
In June 2021, Milton Courthouse workers were temporarily relocated to Burlington to allow for mold and asbestos remediation at the Milton Courthouse. The Grievor is not recalled to Brampton but instead attends work in Burlington.
From June 2021 until November 2021, the Grievor worked as a Records Clerk in Burlington. During this period, the Grievor also assisted with limited in-person matters in Orangeville and Guelph. After each assignment, the Grievor returned to their position at Burlington and claimed meals and travel allowances consistent with being assigned to Burlington as their home position.
From September 2021 to November 2021, although working primarily from the Burlington Courthouse, the Grievor at this time also assisted with in person proceedings at the Brampton Courthouse, serving there as a Court Service Officer. Ray A., a Supervisor at this courthouse, joked with the Grievor about luring her back to Brampton permanently and commented that the Grievor, traveling from Burlington, represented an expensive budget item.
From the above, it was further confirmed in the Grievor’s estimation that they were in fact a permanent employee of the Milton/Burlington Courthouse.
During this period assisting Brampton Courthouse, Ray A., repeatedly asked the Grievor to return to Brampton. The Grievor declined. No direction was provided to the Grievor to return to Brampton permanently, nor was it represented to the Grievor that the Employer understood that Brampton was the Grievor’s assigned headquarters.
On the contrary, in November 2021, the Grievor was directed back to a temporary Milton Courthouse located at an Oakville hotel ballroom to serve as Court Service Officer.
In March 2022, the Milton Courthouse fully reopens to OPS staff. The Grievor is directed to report to that location.
During this time, the Grievor worked regularly and often for the Milton Courthouse. For example, from the weeks of April 17 2023 to June 12 2023, the Grievor was scheduled thirty-six days in court.
On Monday, September 11, 2023, the Grievor emailed Supervisor Harvey N. advising him of ill health, describing her symptoms. The Grievor left work early that day.
On September 12, 2023, the Grievor again called in sick. In an email to Harvey N., the Grievor described their breathing issues in great detail and related them directly to the mold issue.
On or about September 12, 2023, for roughly a two-week period, the entire judiciary of Milton Courthouse withdrew their labour because of the continued presence of mold/asbestos and the still ongoing remediation performed by Pinchin Ltd., environmental consultants. No clients or persons beyond OPS staff were permitted on site.
On September 13-14, 2023, the Grievor worked in the office. Due to the withdrawal of the judiciary, there was no live court that day.
During an all-staff meeting held on September 14, 2023, senior management (Debbie Dunn) and local management (Joe D. and Harvey N.) advised staff that no cases of ill health had been reported in the Milton courthouse. The Grievor, at this moment, spoke up, describing in detail about feeling unwell whenever in the building. They asked whether the OPS would approve her sick leave. The Grievor was informed that their medical condition should not be discussed, that they ought to take their sick leave and speak with their supervisor. The Grievor perceived that management grew angry with them at this point, speaking over her.
Shortly following this meeting, Harvey N called the Grievor into his office and completed a WCB report on their behalf on his computer (WSIB Employer’s Report of Injury/Disease Form 7).
On September 15, 2023, the Grievor was away from work on pre-approved vacation.
On September 18, 2023, the Grievor begins an extended absence from the workplace due to illness.
On October 4, 2023, during this period of sick leave, Supervisor Ray A. made a telephone call to the Grievor. During this call, the Grievor was advised that they would be returning to Brampton on October 23, 2023.
The Grievor, genuinely believing that they had been permanently assigned to the Milton Courthouse, was in shock.
When asked whether this relocation was a result of Brampton’s or Milton’s request, Ray A. responded “A bit of both.”
On December 5, 2023, the union, on behalf of the Grievor, files two grievances alleging a violation of Article 2, seeking to have their position at the Milton Courthouse recognized as permanent and to recover any and all lost monies, time, or credits.
The Grievor, to date, continues to be on an approved sick leave.
Union position
That the Employer violated Articles 2 and 8.6.3 in having not permanently assigned the Grievor to the Milton Courthouse after eighteen months of continuous service in that position;
Notwithstanding that the Grievor maintains that they ought to be a permanently assigned employee of the Milton Courthouse, that the Employer, when they recalled the Grievor back to the Brampton Courthouse in October of 2023, reprised against the Grievor for having spoken up about their ill health in the workplace and thus violated Article 3 of the collective agreement.
Remedy
That the Grievor be recognized as a permanent employee of the Milton Courthouse
That the Grievor be reimbursed for any and all lost wages, credits, and pension contributions.
Production
Reserving its right to request further and better production, the Union requests pre-hearing production of documentation and a fulsome set of particulars that the employer intends to rely on, as well as all particularized preliminary objections. Please provide this documentation as soon as reasonably possible. The Union also requests that the Employer provide copies of any and all arguably relevant documents in any format or medium, including, but not limited to the following:
Any and all arguably relevant documents, including internal correspondence, related to the Grievor’s transfer from Brampton to Milton Courthouse.
Any and all arguably relevant documents, including internal correspondence, related to the decision to direct the Grievor to return to the Brampton Courthouse.
Any and all WEAR forms and employment contracts from 2016 until the date of grievance, December 5, 2023.
Any and all other arguably relevant documents.
Please do not hesitate to contact me if you have any questions.
Sincerely
James Sommerville

