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File No. 

November 14, 2016
BY EMAIL

The Honourable Kelly Regan

Minister of Labour and Advanced Education
6th Floor, 5151 Terminal Road

PO. Box 697

Halifax, NS 83.1 2T8

Dear Minister:

RE: Urgent request pursuant to section 36 of the Trade Union Act

We act as counsel for the Halifax Typographical Union, Local 30130 ("Union"), which
represents employees of The Halifax Herald Ltd. ("Employer").

We write to request that pursuant to section 36 of the Trade Union Act the
attached Complaint be referred forthwith to the Nova Scotia Labour Board for
determination.

The Union alleges that the Employer is in violation of section 35 of the Act in that the
Employer is bargaining in a manner designed to end union representation of its
employees and/or prevent a collective agreement from being concluded.

The Union alleges among other things that despite the fact that it has agreed to all of
the Employer's major demands for monetary concessions concessions that will save
the Employer and take from bargaining unit employees millions of dollars over the life of
the collective agreement, the Employer nevertheless continues to bargain to impasse
proposed changes to the Union's jurisdiction and scope and proposed changes to
employee's job security rights.

CAVALLUZZO SHILTON MCINTYRE CORNISH LLP BARRISTERS SOLICITORS
474 Bathurst Street. Suite 300. Toronto. Ontario M5T 286 T. 416.964.1 1 15 F. 416.964.5895 cavalluzzo.com


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These proposals, if accepted by the Union, would give the Employer the right to decide
what work and what employee is in the bargaining unit and what work and what
employee is out of the bargaining unit, and to lay off senior employee ahead of new
hires in the same job. These preposals, if accepted by the Union, would completely
undermine the integrity and viability of the bargaining unit and the Union's bargaining
rights, and were tailor-made to be rejected and prevent a collective agreement from
being reached.

We respectfully request that this matter be given urgent attention in light of the fact that
the members of this bargaining unit have been on strike since January 23, 2016, and
they and the Union have done everything in their power to conclude a collective
agreement.

Please do not hesitate to contact me if further information is required or I can be of
assistance in any way.

A copy of this letter and attached "Complaint" are being emailed to G. Grant Machum.
counsel to the Employer, at the same time as they are being emailed to the Minister.

Yours truly,

CAVALLUZZO SHILTON MCINTYRE CORNISH LLP

em

Sean FitzPatrick

Enc.

cc; G. Grant Machum, Stewart McKelvey
J. Baboushkin, Conciliation and Mediation Services
I. Bulmer, HTU L. 30130
D. Wilson, CWA-SCA Canada

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