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Posts tagged: employment law

Terminating Senior Executives: The Nickels and Dimes Can Really Add Up

By , March 6, 2018 8:50 am

News Flash: An employer who does not specify in an employment contract how much an executive is entitled to receive when terminated can pay much more termination pay than expected.

The Case

UBS Securities Canada Inc. found out the hard way how the nickels and dimes can add up when it terminated the employment of David Bain who was the Managing Director and Head of Canadian Mergers & Acquisition.

The Nickels & Dimes

The Ontario Court of Appeal recently considered four issues that were decided by the trial judge in this case, namely:

  1. Was Mr. Bain owed a deferred bonus by way of notional shares that vested after the expiry of an agreed upon 18 month notice period? This part of the bonus was worth $ 1,200,000.
  2. Was vacation pay owing calculated on base salary or salary and bonus? The difference was $ 81,772.
  3. Should prejudgment interest be based on the “lump sum” approach or the “instalment” approach? The difference was $44,585.81.
  4. Should legal costs be determined using the partial indemnity “grid” rates set out in the preamble to Rule 57, “Information for the Profession”, or by using 60% of the actual rates charged by the employee’s counsel? UBS was seeking a reduction of approximately $70,000 in the costs of the action.

The Decision

The trial judge and the Ontario Court of Appeal sided with the employee on all four issues.

Lessons to Be Learned

  1. A well drafted employment contract and well drafted variable compensation plans can eliminate legal uncertainty and save employers A LOT of money – especially for senior executives.
  2. Variable compensation plans including bonus plans can be drafted to clearly state how much compensation a terminated employee is owed and it can be significantly less than the person’s common law entitlement.
  3. Bonus plans can be drafted so that employees are not entitled to earn vacation pay on bonus income.
  4. Termination clauses can be drafted so it is more likely that pre-judgment interest damages will be awarded using the less expensive installment method.
  5. Litigating a wrongful dismissal case can be very expensive. UBS paid its own legal fees plus 60% of Mr. Bain’s fees or $225 000. If UBS’ legal fees were the same as Mr. Bain’s then UBS’ legal costs to go to trial were about $ 600 000.

For over 30 years, Doug MacLeod of the MacLeod Law Firm has been advising employers on all aspects of the employment relationship. If you have any questions, you can contact him directly at 416 317-9894 or at [email protected]

The material and information in this blog and this website are for general information only. They should not be relied on as legal advice or opinion. The authors make no claims, promises, or guarantees about the accuracy, completeness, or adequacy of any information referred to in this blog or its links. No person should act or refrain from acting in reliance on any information found on this website or blog. Readers should obtain appropriate professional advice from a lawyer duly licensed in the relevant jurisdiction. These materials do not create a lawyer-client relationship between you and any of the authors or the MacLeod Law Firm.

 

The Latest on the Legality of Random Drug & Alcohol Testing

By , February 20, 2018 9:18 am

In 2013, the issue of whether an employer can unilaterally implement random drug testing was addressed by the Supreme Court of CanadaBottom line: there are very few instances when random drug testing will be permitted.

This blog summarizes a recent arbitration award where a union challenged an employer’s random drug testing policy at a coal mine.

The Facts

The arbitrator found that anyone working in mine operations, the mine maintenance department, and in the coal plant was involved in a safety-sensitive job.

Further, he found  that the work and surroundings involved in all three of these operations required employees to maintain a continuing alertness so that they did not cause an accident that might injure themselves and/or another employee, or were not injured by someone else’s carelessness.

In 2012, the employer unilaterally implemented random drug and alcohol testing that required employees to, among other things,  provide breath or urine samples. If there was a positive result then the employee was required to meet with an additional specialist and disclose personal health information.

The Issue

The issue in random drug and alcohol cases is how to resolve the conflict between an employer’s interest in making their workplaces safe, and an employee’s interest in protecting their privacy.

The Test

  1. Have employees’ privacy rights been infringed and, if so, to what degree;
  2. If so, is there sufficient or adequate cause to justify the search and seizure and resulting privacy intrusions represented by random testing; and, if so,
  3. Is random testing a proportionate response to that “demonstrable workplace problem”?

The Decision

After a 39 day hearing, the arbitrator concluded:

  1. Random drug and/or alcohol testing is a prima facie privacy violation
  2. The fact that an employer’s workplace is dangerous does not, in and by itself, establish a legitimate need for random drug and alcohol testing. There was no evidence of a “demonstrated workplace problem” or “a general problem with substance abuse in the workplace.” In this regard, in the five years leading up to the random testing, the number of positive tests were relatively low for post-accident testing, averaging between one and two positive post-incident drug tests per year.
  3. Neither a positive breathalyzer test at .02% BAC nor a positive urinalysis test for the presence of cannabis or cocaine metabolites establishes that an employee was under the influence of, or impaired by, any of those substances.  Such positive tests only establish that the employee has used those substances in the past, not that he was impaired at the time of the test.

The arbitrator also noted that no evidence was led on whether or not there were any less intrusive means of measuring impairment that would be equally as effective such as “computer-assisted employee performance testing” which is more commonly known as “impairment testing.”

Lessons to Be Learned

  1. It is possible but extraordinarily difficult to justify a random drug and alcohol policy.
  2. Unionized employees will almost certainly grieve the policy under the applicable collective agreement, and non-unionized employees can file an application under human rights legislation.
  3. The onus is on the employer to justify the need for the policy.
  4. The employer must demonstrate an actual problem with substance abuse in the workplace; not a theoretical problem.
  5. The employer’s testing protocol needs to prove impairment; not use.

For over 30 years, Doug MacLeod of the MacLeod Law Firm has been advising employers on all aspects of the employment relationship. If you have any questions, you can contact him directly at 416 317-9894 or at [email protected]

Patrick Brown: Could the Alleged Sexual Harassment/Assaults Have Been Prevented?

By , January 25, 2018 5:04 pm

Yesterday, CTV reported that two women alleged Ontario Progressive Conservative leader Patrick Brown sexually harassed and/or sexually assaulted them. Shortly after the story broke Mr. Brown resigned as party leader.

I don’t think Mr. Brown will deny he met either women. Instead I think he will claim that whatever happened was consensual.  In other words, classic “he said, she said” situations. If criminal charges are laid against Mr. Brown then the Crown will need prove the charges beyond a reasonable doubt. The same burden of proof as in the Jian Ghomeshi case.

This blog considers whether either situation could have been avoided from an employment law perspective.

If the federal government had addressed sexual harassment and sexual assault in the federal civil service and the House of Commons prior to 2013, then I think the 2013 incident could have been prevented. The Prime Minister could have stood up in the House of Commons and said the federal government is going to take a leadership role on this issue and take proactive steps to redress this societal problem. First, by saying it won’t be tolerated; second, by requiring all employees and MPs to comply with a sexual harassment policy; and third, by introducing a complaint procedure and encouraging employees to use it. This would have put MPs on notice of the cultural change the government was committed to leading and would have made all MPs think twice about sexually harassing staff. It would also communicate a very strong message to staff that the employer wanted people to bring forward sexual harassment complaints. In this climate, I think Mr. Brown would have thought twice before allegedly bringing a staff member back to his home or into his bedroom.

I don’t think the incident that took place over 10 years ago could have been prevented through workplace policies. According to the CTV report, the 17 year old female high school student did not appear to have any connection to Mr. Brown’s workplace and they do not appear to have met at a workplace event.

Given the societal change that has taken place in connection with sexual harassment and sexual assault over the last 5 years I do not believe nearly as many employees or politicians will put themselves in compromising situations in the future. The adverse consequences associated with sexual harassment and sexual assault allegations in 2018 is staggering.  Without these allegations, polls show Mr. Brown would have been premier of Canada’s largest province in June.

For over 30 years, Doug MacLeod of the MacLeod Law Firm has been advising employers on all aspects of the employment relationship. If you have any questions, you can contact him directly at 416 317-9894 or at [email protected]

The material and information in this blog and this website are for general information only. They should not be relied on as legal advice or opinion. The authors make no claims, promises, or guarantees about the accuracy, completeness, or adequacy of any information referred to in this blog or its links. No person should act or refrain from acting in reliance on any information found on this website or blog. Readers should obtain appropriate professional advice from a lawyer duly licensed in the relevant jurisdiction. These materials do not create a lawyer-client relationship between you and any of the authors or the MacLeod Law Firm.

 

Wal-Mart Employee Awarded $250,000 in Moral Damages and $500,000 in Punitive Damages

By , January 23, 2018 9:00 am

When deciding whether to settle a case, a lawyer assesses the risks and uncertainties inherent in the litigation process including the quantum of damages that a judge will likely order for each head of damages claimed. I call this litigation risk.  

As I have written beforeemployees seldom claim only wrongful dismissal damages in an employee termination case. Additional heads of damages include human rights damages, moral damages, punitive damages, and damages for the intentional infliction of mental stress. This results in more litigation risk but despite this increased risk more than 90% of cases still settle.

Every once in a while a case goes to court and the decision increases the litigation risk for all subsequent cases. This is one of those cases. Based on the reported facts in this caseI would never have predicted that Wal-Mart would have been ordered to pay the employee $ 250 000 in moral damages and $ 500 000 in punitive damages.

Until this case is appealed or followed/considered/distinguished by other trial judges, I will need to consider this decision when assessing the chances a judge will order moral damages and punitive damages in my cases. And in the meantime, litigation risk has increased for employers in employee termination cases.

The Facts

In September 2002, Gail Galea started working at Wal-Mart and about 8 years later her employment was terminated without just cause. About 10 months before her employment was terminated, her position was eliminated because of a re-organization. During her last 10 months of employment, Wal-Mart tried to find her another position within the organization and sent her to Harvard for an 8-week executive management program. When Wal-Mart couldn’t find her a suitable position she was terminated without cause. Instead of paying her the two years pay she was owed, Wal-Mart continued her benefits and the equivalent of her salary for 11.5 months.

Trial Decision

The judge concluded that an agreement between Ms Galea and Wal-Mart obliged Wal-Mart to pay her damages equal to the compensation and benefits she would have earned during the two year period after her termination.

As far as paying Ms. Galea damages for variable compensation during the 2 year period after her termination was concerned, Wal-Mart took the position it owed her no monies under a Management Incentive (Bonus) Program, Deferred Profit Sharing Plan, Executive Retirement Plan and a Long Term Incentive Plan. The trial judge disagreed except for damages claimed under the Long Term Incentive Plan.

Ms. Galea claimed moral damages because of the manner of her termination. The trial judge awarded her $200,000 for the treatment she received from Wal-Mart during the last 10 months of her employment including the 2 months she spent at Harvard. “She was made to suffer repeated humiliation, starting with the announcement of her re-assignment from Vice President, General Merchandising to that of a roving vice president of little substance.”

Ms. Galea claimed damages for the way Wal-Mart acted after her termination. The judge awarded her an additional    $50,000 damages for the following behavior. “I consider Wal-Mart’s decision to stop the continued payment of her base salary and the health and dental coverage to her and her family (after 11.5 months) to be unduly insensitive, and to have caused her mental distress. I consider Wal-Mart’s delay in answering its undertakings until the eve of trial, and the torrent of productions made in the course of the trial,… capable of causing Ms. Galea  prolonged anguish about the case.”

Ms. Galea provided no medical evidence that these actions caused her mental distress.

Ms. Galea claimed punitive damages. The trial judge awarded her $ 500 000 punitive damages for the following behaviour: “ All of Wal-Mart’s conduct that justifies an award of punitive damages occurred between January 29, 2010 and November 19, 2010 when Wal-Mart would make representations to Ms. Galea about her career prospects while making decisions that detracted from, or even defeated that purpose. It is not that Wal-Mart set Ms. Galea up to fail; it is that Wal-Mart built her up, only to let her down that much more. That corporate behaviour was not just unduly insensitive, it was mean.”

Lessons to be Learned

  1. Wal-Mart’s decision to stop termination payments after 11.5 months instead of continuing the payments for the contractually prescribed 24 months was a reason the judge ordered Wal-Mart to pay Ms. Galea moral damages. Accordingly, in this case, damages flowing from the breach of contract was more than would normally be awarded in a case like this which is the difference between the 11.5 months and the 24 months.
  2. If an employer does not want an employee to receive damages for the variable compensation that she would have earned had she received notice of termination then the variable compensation plan must clearly say so. For earlier blogs on this issue, click here
  3. If an employer implements a re-organization and does not immediately offer a new job to a person whose position has been eliminated then the employer should provide a reasonable road map to the displaced employee on how her continued employment will be handled and act consistently with this plan. In this case, the judge stated: “Conduct that can trigger moral damages includes an employer’s conduct that is untruthful, misleading or unduly insensitive, and a failure to be candid, reasonable, honest and forthright with the employee.” He found that Wal-Mart breached this duty as it was trying to find a new position for Ms. Galea. I don’t know if this case will turn out to be an outlier but in the meantime employers should be very careful when dealing with an employee who is between jobs within the organization.

For over 30 years, Doug MacLeod of the MacLeod Law Firm has been advising employers on all aspects of the employment relationship. If you have any questions, you can contact him directly at 416 317-9894 or at [email protected]

The material and information in this blog and this website are for general information only. They should not be relied on as legal advice or opinion. The authors make no claims, promises, or guarantees about the accuracy, completeness, or adequacy of any information referred to in this blog or its links. No person should act or refrain from acting in reliance on any information found on this website or blog. Readers should obtain appropriate professional advice from a lawyer duly licensed in the relevant jurisdiction. These materials do not create a lawyer-client relationship between you and any of the authors or the MacLeod Law Firm.

 

Bill 148 – Summary of Changes to the Employment Standards Act and When Each Change is Implemented

By , December 4, 2017 2:24 pm

On November 22, 2017, the Ontario legislature passed the final version of Bill 148- the Fair Workplaces, Better Jobs Act. Below is a summary of some of the provisions of the Act , their dates of implementation and their impact on employers and employees throughout Ontario. We offer a fixed fee service for employers who need help complying with these changes. 

 

Provision Amendment Effective Date
Minimum wage General minimum wage will increase to $14 per hour on January 1, 2018 and $15 per hour on January 1, 2019. There will also be a proportional increase to special minimum wage rates. January 1, 2018: $14/h

January 1, 2019: $15/h

Minimum wage will increase every year going forward subject to an annual inflation adjustment on October 1 of every year starting in 2019

Misclassification of workers An employer who wrongfully classifies a worker as a non-employee (i.e. an independent contractor, or other nonemployee) will now be in contravention of the ESA and subject to penalties.
Note: The burden of proof lies on the employer to show that the person is not an employee.
 November 27, 2017
Equal Pay for Equal Work – No difference in pay rate because of employment status Employers will be prohibited from paying employees at different rates depending on whether they are full-time, part-time, seasonal, etc. unless an exemption applies.

An employee may request a review of their rate of pay from the employer, to which the employer must respond if it disagrees with the employee’s belief that this section has been breached.

Note: The reprisal provisions have been amended to protect employees who avail themselves of this change.

The rule will not apply when the difference in pay rate is made on the basis of: (a) a seniority system; (b) a merit system; (c) a system that measures earnings by quality of production; or, any other factor other than sex or employment status.Unionized employers: if a collective agreement (“CA”) that is in effect on April 1, 2018 contains a provision that permits differences in pay based on employment status, and there is a conflict between the provision of the CA and this rule, the provision of the CA prevails until the earlier of the date the CA expires and January 1, 2020.

 April 1, 2018
Equal pay for equal work for assignment employees This new change mandates equal pay for temporary help agency employees:

• equal pay for jobs that are substantially the same but not necessarily identical to   regular employees;

• where performance requires substantially the same skill, effort and responsibility; and,

• when work is performed under similar working conditions.

There are however  exceptions: namely, when the difference in the rate of pay is made on the basis of any other factor other than sex, employment status or assignment employee status.
Unionized employers: if a collective agreement (“CA”) that is in effect on April 1, 2018 contains a provision that permits differences in pay between employees of a client and an assignment employee, and there is a conflict between the provision of the CA and this rule, the provision of the CA prevails until the earlier of the date the CA expires and January 1, 2020.

 April 1, 2018
Holiday Pay Holiday pay will be calculated as the average daily wages earned in the pay period leading up to the holiday instead of the current law which is calculated as wages and vacation pay earned in the four work weeks prior to the week in which the holiday falls, divided by 20.

If the employee was not employed during the pay period immediately preceding a public holiday, the employee’s public holiday pay for the public holiday shall be equal to the amount of regular wages earned in the pay period that includes the public holiday divided by the number of days the employee worked in that period.

January 1, 2018
Substitute holidays The rule on substituted holidays remains but with the new imposition of written requirements for documenting substitutions.
Under the new law, the employer must provide the employee with a written statement outlining: a) the public holiday (on which the employee will work); b) the substitution date; and, c) the date the written statement was provided to the employee. 
 January 1, 2018
Vacation entitlement, pay and timing   A minimum 3 week vacation entitlement to employees whose period of employment is five years or more.

 

There is also a requirement that an employee must pay vacation pay equal to at least, (a) 4 per cent of the wages if the employee’s period of employment is less than five years; or (b) 6 per cent of the wages if the employee’s period of employment is five years or more.

 

Vacation Timing: (i) The vacation must be completed no later than 10 months after the end of the vacation entitlement year for which it is given. (ii) If the employee’s period of employment is less than five years, the vacation must be a two-week period or two periods of one week each, unless the employee requests in writing that the vacation be taken in shorter periods and the employer agrees to that request. (iii) If the employee’s period of employment is five years or more, the vacation must be a three-week period or a two-week period and a one-week period or three periods of one week each, unless the employee requests in writing that the vacation be taken in shorter periods and the employer agrees to that request.

 January 1, 2018
Paid Personal Emergency Leave All employees will be entitled to 10 days off for personal emergencies, the first two of which must be paid.
[Note: Currently, employees who work for employers with less than 50 employees are not entitled to this leave. Also employees are not currently entitled to any paid personal emergency leave.]
Employers retain the right to require evidence of entitlement to these days but are not permitted to require a certificate from a qualified health practitioner.
Qualifying period: The employee must have worked for the employer for at least one week before reaching entitlement for the two paid days. Regardless of overtime pay or shift premiums, the employee will be paid regular wages.
 January 1, 2018
Cancellation Pay – Guaranteed Three Paid Hours Employees are entitled to a minimum of three hours’ pay at their regular rate (i) for being on call (even if they are not called into work) or (ii) if an employer cancels the employee’s shift within 48 hours of the start of that shift.
This amendment includes exemptions in circumstances:

• Beyond the employer’s control – such extreme weather, power failure, etc.

• Where the work is weather dependent and the employer cannot provide work for weather dependent reasons.

• Where the employer requires the employee to be on call for the purposes of ensuring the continued delivery of essential public services.

Unionized employers:

if a collective agreement (“CA”) that is in effect on January 1, 2019 contains a provision that addresses payment when the employer cancels the employee’s scheduled work or on-call period, and there is a conflict between the provision of the CA and this rule, the provision of the CA prevails until the earlier of the date the CA expires and January 1, 2020.

 January 1, 2019
Employees Who Regularly Works Three Hours are Guaranteed Three Paid Hours: Employees who regularly work more than three hours each day must be paid three hours at their regular pay rate if they are required to work and work for less than three hours despite being available to work longer.

Exception: the rule does not apply if the employer is unable to provide work for the employee because of weather, fire, or other similar causes beyond the employer’s control

 January 1, 2019
On-Call Employees – Guaranteed Three Paid Hours: If “on call” employees are not called into work, or are called in but work less than three hours despite being available to work longer, then they must be paid three hours at their regular pay rate, and this is required for each 24-hour on-call period.

Note: Currently an employee who is called into work is entitled to the greater of their wages earned and three hours at the minimum wage.

Exceptions: the rule does not apply if the employer is unable to provide work for the employee because of weather, fire, or other similar causes beyond the employer’s control.

The three-hour rule also does not apply if the employer required the employee to be on call for the purposes of ensuring the continued delivery of essential public services.

January 1, 2019
Right to Refuse – 96 Hour Rule: An employee is now entitled to refuse without repercussion an employer’s request to work or to be on call if the request is made less than 96 hours prior to the commencement of the shift.

Exception: Where the work is to: a) deal with an emergency; b) to remedy or reduce a threat to public safety; c) ensure the continued delivery of essential public services; or d) for such other reasons as may be prescribed.

Note: An “emergency” is this section would refer to a situation or an impending situation that constitutes a danger of major proportions that could result in serious harm to persons or substantial damage to property and that is caused by the forces of nature, a disease or other health risk, an accident or an act whether intentional or otherwise, or  a situation in which a search and rescue operation takes place.

Unionized employers: if a collective agreement (“CA”) that is in effect on January 1, 2019 contains a provision that addresses an employee’s ability to refuse the employer’s request or demand to perform work or be on call on a day the employee is not scheduled to work or be on-call, and there is a conflict between the provision of the CA and this rule, the provision of the CA prevails until the earlier of the date the CA expires and January 1, 2020.

January 1, 2019
Overtime pay when employee has two or more rates of pay If an employee has two or more regular rates for work performed for the same employer in a work week, the employee is entitled to be paid overtime pay for each hour of work performed in the week after the total number of hours performed for the employer reaches the overtime threshold.

Additionally, the overtime pay for each hour is one and a half times the regular rate that applies to the work performed in that hour

January 1, 2018
Right to request changes to schedule or work location Employees with at least three months’ tenure with their employer can request changes to their schedule or work location. Employers who receive these requests must discuss them with the employee and either grant them or provide reasons for their denial. January 1, 2019
Domestic or sexual violence leave An employee, who has been employed by an employer for at least 13 consecutive weeks, is entitled to take a leave of absence if the employee or their child experiences sexual or domestic violence.
The leave can be up to 10 days (taken individually), and up to 15 weeks (intermittently) to a maximum of 17 weeks total. The leave may be taken: to seek medical attention; to obtain services from a victim services organization; to obtain counselling; to relocate; or, to seek legal or law enforcement assistance.
The first 5 days of the leave must be paid
January 1, 2018
Critical-Illness of an Adult Family Member An employee may take leave to provide care and support to any critically ill family member for up to 17 weeks
A qualified health practitioner must issue a certificate that, (a) states that the adult is a critically ill adult who requires the care or support of one or more family members; and (b) sets out the period during which the adult requires the care or support.
December 3, 2017
Pregnancy and parental leave Pregnant employees with at least 13 weeks service will be entitled to 18 months pregnancy and parental leave
Amendments will extend the leave for employees who suffer a stillbirth or miscarriage from 6 to 12 weeks.
The length of parental leave is extended from 35 to 61 weeks if the employee took a pregnancy leave and from 37 to 63 weeks for employees who did not. An employee may commence parental leave no later than 78 weeks (previously 52) after the day the child is born or comes into the employee’s care or custody for the first time.
December 3, 2017

 

January 1, 2018

 

 

December 3, 2017

 

 

 

 

Family medical leave Increased leave from 8 to up to 28 weeks of leave. Expansion of the definition of “qualified health practitioner” to now include certain registered nurses or individuals with equivalent qualifications, and, in some circumstances a member of a prescribed class of health practitioners January 1, 2018
Termination of temporary agency assignment employees Temporary help agencies must now provide an assignment employee with one week’s written notice or pay in lieu, if an assignment that was estimated to last for three months or more, is terminated before the end of its estimated term, unless another assignment lasting at least one week is offered to the employee. January 1, 2018
Record Keeping A larger list of recordkeeping requirements has been imposed, which will be coming into force on varying dates:

– Dates and hours worked.

– Where an employee has two or more regular rates of pay, the dates and times that the employee worked in excess of the overtime threshold at each rate of pay.

– Records of substitute holidays (mentioned above).

– Retention of documents for all leaves. – Record-keeping of vacation pay and vacation time.

– Record retention for 5 years instead of 3

January 1, 2018
Record Keeping Requirements for Employers with On-Call Employees Employers with on-call employees:

– Dates and times of work and on-call schedules, and any changes made to oncall scheduling

-Dates and times of cancellations of a scheduled day of work or scheduled on-call period.

January 1, 2019
Record Keeping Requirements for Temporary Help Agencies. Temporary help agencies must:

– record the number of hours worked by each assignment employee for each client of the agency in each day and each week; and
-retain a copy of any written notice provided to the employee upon termination of an assignment.

January 1, 2018
Footwear with elevated heel under the Occupational Health and Safety Act (“OHSA”). A new section is added to the OHSA stating that an employer shall not require a worker to wear footwear with an elevated heel unless it is required for the worker to perform his or her work safely. An exception to this prohibition is made for employers or performers in the entertainment and advertising industry. November 27, 2017


The material and information in this blog and this website are for general information only. They should not be relied on as legal advice or opinion. The authors make no claims, promises, or guarantees about the accuracy, completeness, or adequacy of any information referred to in this blog or its links. No person should act or refrain from acting in reliance on any information found on this website or blog. Readers should obtain appropriate professional advice from a lawyer duly licensed in the relevant jurisdiction. These materials do not create a lawyer-client relationship between you and any of the authors or the MacLeod Law Firm.

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