180304542
COURT FILE NUMBER

COURT COURT OF BENCH OE ALBERTA
JUDICIAL CENTRE EDMONTON
JANE DOE JANE DOE JANE DOE

JANE DOE #4

HER MAJESTY THE QUEEN IN RIGHT OF
CANADA, OF CANADIAN
CORRECTIONAL 

 

DOCUMENT STATEMENT Gt: CLAW

ADDRESS FOR AND

CONTACT INFORMATION OF Combs Kent

PARTY FILING THIS DOCUMENT Barristers Solicitors
10614 124 Street
Edmonton AB
T5N 183
P: 780 425?4666
F: 780 4254233
Attention: Jeffrey P. O?Brien

TO DEFENDANNS)
You are being sued. You are a defendant.

Go to the end of this document to see what you can do and when you must do it.

Note: State below only facts and not evidence (Rule 13.6)

Statement at facts reiied on:
PARTEES
The Plaintiffs
The Plaintiffs, Jane Doe #1 (Andrea), Jane Doe #2 (Samantha), Jane Doe #3 (Jessica)

and Jane Doe #4 (Sarah) were each employed by Correctional Service Canada



(alternatively referred to as the ?Employer? and ?Corrections?) at the federal prison
referred to as Edmonton Institution (hereinafter, at various times in various

capacities.

2. The Plaintiffs have been identified using Does due to the confidential and secretive
nature of law enforcement work, especially that within Corrections. Management

personnel and other employees have also been identified using pseudonyms.

Andrea commenced employment with Cerrectional Service Canada in August of 2009
and resides in Edmonton, Alberta with her two children. She is Serbian?born, having fled
turmoil in the region with her family in her youth. She experienced significant prejudice
through the course of her employment due to her ethnic origin, gender, reiigion, and

family status.

Samantha commenced employment with Correctional Service Canada in 1999 and

resides in Edmonton, Alberta with her same-sex partner.

Jessica commenced employment with Correctional Service Canada in May of 2007 and

is a residentof Alberta.

Sarah commenced employment with Correctional Service Canada in December of 2009

and resides in Fort Saskatchewan, Alberta, with her daughter and husband.

The Defendants

The Crown is named as a party to this action because the Plaintiffs are or were
employees Correctional Service Canada, which is a body of the federal government.
Within this claim, the employer will alternatively be referred to as the Employer, CSC,

and Corrections.

The Defendant, Union of Canadian Correctional Officers (hereinafter or the
?Union?) is the exclusive bargaining agent in respect of the Plaintiff?s employment with
CSC.

CVERVEEW

10.

The Plaintiffs are all dedicated, hardworking, high?performing, long-term employees to
CSC. They were nevertheless harassed and discriminated against by CSC
management, by colleagues, and by Union officials on the basis of ethnic origin, age,
gender, family status, and sexual orientation and such other grounds as may be proven

at trtai.

El is a workplace rife with discrimination, harassment, bullying, abuse of authority, and
sexual assault. Management, the Union and employees in leadership positions support
this atmosphere throughout the institution, without any adherence to respectful

workplace norms. This tone and approach has been dictated from the top and adopted

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throughout the organization. Many employees gain upward mobility and career success
by participating in this misconduct. Discriminatory behaviour has become the norm

which has a protoundty negative ettect on vulnerable employees.

Neither the Union nor management will acknowledge the inappropriateness of this
conduct. They are unwilling or unable to take steps to protect the Plaintiffs and other
employees or to prevent these behaviours. The Plaintitts? attempts to grieve their
treatment have been met with derision, threats of reprisals, and further harm. The

Ptaintitts have no internal means to prevent this abuse.

12. This institutionaltzed conduct spans decades; each and every Ptaintift was treated this
way upon commencement of their employment. They have alt sustained stress, anxiety,
depression, embarrassment, and loss of income and opportunities.

seesaw.
andrea?s Backgreund

18. Andrea worked for Corrections for 8 years and served as the local Union?s secretary.
She is well-educated, currently pursing a master?s degree in which she
originatly hoped to put to use with further employment with CSC. She is the mother of
two young children.

?i4. She is a Canadian oi Serbian descent. She came to Canada with her
parents and siblings as refugees to escape war in her native region.

15. Andrea was discriminated against by CSC and by the Union for her gender, her ethnicity
as well as her family status, and wrongfully terminated.

Andrea?s Werking Environment
16. Andrea received numercus harassing comments from various CSC emptoyees when

she began her emptoyment. These included but were not limited to:
a. ?You should be home in the kitchen cooking?.

b. ?You have no place in a prison because this is a man?s job?.



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c. ?Women want to be treated equatly but they do not want to do equatly as much work
for example females do not perform urine samples or frisk searches on male

offender?s and as a result Male Officers have to work harder than femates?.

d. ?Females take advantage of the system by getting pregnant, being accommodated

and taking maternity teave?.

e. ?Go clean the toilet because you are a woman and that is what women should be

doing?.

f. ?Women flirt with offenders and are convict lovers? this was a reaction to her acting in

a non-aggressive manner.

9. ?Females who are employed at Edmonton institution are misbehaved because they

are all promiscuous.?
h. ?Mothers should not be working.?
i. ?You filt a man?s role?.

These are just a sampting of the abuse she sustained. The reality is that Andrea and the

other Plaintiffs were harassed daity. Andrea was often referred to as a ?fucking Serb.?

Her chief tormentor was John Doe When she commenced her employment, he was
the local Union?s vice president. He pressured her into taking on the role of Union
secretary. l\/lr. Doe then persuaded her to switch crews on the job so that the
secretary could be working with the president and VP. Though Andrea eventually
accepted with the hope that the position would grant her valuable work and educational

experience these actions appear to have been part of a ptoy to have more access to her.

Before Andrea?s training for the secretary role, Mr. Doe #1 goaded her and another 080
employee into the home of homosexual female Corrections employee with the stated
purpose of looking for sex toys to take pictures for other 080 employees to laugh at.
Before and after this episode, lVlr. Doe #1 made vulgar jokes about female sexuality and

the employee?s same~sex marriage.

Soon after, Mr. Doe #1 convinced Andrea to have a meeting with him outside of work,
ostensibly to discuss Union matters. Andrea later determined that Mr. Doe had

arranged to have the then?Union president drive by them during this meeting in order to

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strengthen the rumour he had started that he and Andrea were having an inappropriate

relationship.

At a secbnd meeting outside of work, Andrea communicated very clearly to Mr. [Joe #1
that she was not interested in a romantic relationship with him. Mr. Doe #t woutd not
take to for an answer; his inappropriate contact to her increased after this. Situations

included:
a. Constantiy pressuring her into meeting outside of work.

b. Pressuring her in front of other staft and offenders into going on outside escorts with
him in order to be atone with her. Their communicating was typicaliy via email or
SMS, but on one occasion she refused and he came to her Unit to pressure her in

person.

c. Threatihg to come into the sub~controt she was posted to through the tunes! and

make sexual advances towards me.
d. Trying to force himself on her and invade her personal space.
e. Toid her to erase all her emails from him.

t. Handcuffed her to a chair using her own restraints and threatened to sexually assault

her.

g. Catled her excessively and at inappropriate times which she clearly expressed was
inappropriate and non?Union related which he replied to ?You are the secretary of the

Union and you witl answer the phone whee call you, otherwise you?re fired.?

h. Repeatedly critiquing her relationship with her husband and tried to convince her that

the relationship is not going anywhere.

i. At a Union meeting at a board room in a hotei in St. Albert he sat across from her at
the table and sent text messages which she refused to answer. He then asked her to
step outside for conversation. Mortified and embarrassed she was reluctant to go but
complied because she did not want to make the situation more embarrassing. Once
out ot the room, he pushed her into the washroom in order to intimidate her and

asked ?Have you ordered told him that his behavior is inappropriate.

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This was part of a conceited effort to make it appear to observers that they had an

intimate relationship.

Andrea later determined that Mr. Doe had told multiple 080 employees that they

were in a sexual relationship.

As he was doing these things, lVlr. Doe would often claim that he was acting out due
to his own marital problems. He elicited pity rather than feeling remorseful for his own

wrongdoing.
Andrea?s First Pregnancy

Andrea became pregnant with her first child in September of 2010. She first reported this
to a female Manager. Andrea assumed this would remain confidential. However, not
long after she became aware that Mr. Doe #3 had told several staff members and

inmates that she was pregnant with his child; this despite her marriage to a third party.

lVlr. Doe #1 is not the father of either of Andrea?s children, nor has he ever had a sexual

relationship with her. She does not know how he became aware of her pregnancy.

There is a strong culture within El against reporting fellow officers. So doing is
derogatorily referred to as ratting someone out. Andrea did not previously report the
behaviour described herein for fear of being labeled a rat and consequent reprisal,

However, she finally reported l\/lr. Doe #1 for sexual harassment.

Andrea?s complaint was assigned to a manager, John Doe despite the conflict of

interest given his close personal friendship with Mr. Doe 

Mr. Doe #2?s summary of Andrea?s complaint was ?a relationship gone bad.? When
meeting with the parties to the complaint, he asked her what she wanted out of her
complaint. She responded that she wanted to be left alone. lVlr. Doe #1 agreed to do so.
Andrea was satisfied and left the meeting. She later determined that after she left, lVlr.
Doe #1 showed lVlr. Doe #2 a picture of a woman?s genitalia and falsely claimed it was
Andrea: The then Union president, was also present. The men laughed about the
incident and no remedial action was taken beyond Mr. Doe #t?s agreement to leave her

alone.

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Mr. Doe did not leave her atone. He showed the said picture to multiple other (380
employees, including Jessica, and identified it as Andrea. The following week
management provided him with her scheduling information, in breach of privacy and
contidentiatity. He continued his habits of inappropriately contacting her, and was able to

do so more ettectiveiy with her scheduling intormation.

Around this time, Andrea tried to discuss her probtems with Mrsaid that Andrea was unworthy of humane treatment because she is Serbian
and, according to Mr. Doe alt Serbians are bad due to their actions in the Yugoslav
War. Andrea tried to explain that she had fled the war when she was young and that she

had sympathy for all victims.

Mr. Doe #1 was then assigned to manage Andrea?s accommodation for her pregnancy.
This was clearly inappropriate, and Andrea requested a no?oontact order from the Union,

which was granted. Sheeventually went on maternity teave.
Andrea?s Return to Work

Andrea returned to work in September of 2012. The Union steward John Doe #3 refused
to allow any accommodation, accusing her of trying to scam him by asking for a

chiidcare accommodation.

During this time, Mr. Doe #1 constantly harassed her, suggesting that she transfer to his
unit. This was a direct violation of the above-mentioned no?contact order, but the
Defendant was unwilling or unable to enforce their own regulations. He would also
pressure her to come visit him at his unit during working hours, and would chastise her
for not responding to his phone calls or text messages. This was despite her deleting
him on ail social media. Any time he spoke to her in the hallway he would high?five

nearby male employees to suggest she was some conquest of his.

Dealing with the stress of this harassment was a daiiy problem for Andrea, yet no
remedial action was taken. in tact, male employees were enabling this by encouraging
Mr. Doe 

That winter Andrea requested leave for Orthodox Christmas. She ridicuted by a male
manager in front of several 080 employees for celebrating a holiday that he deemed

non?Canadian.

 

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AndrealsSecond Pregnancy

Andrea became pregnant in January of 2014. The member in charge of her
accommodation was once again Mr. Doe despite her repeated complaints about him

and despite how obviously inappropriate this was.

She was accommodated by working in the administration building. During this period l\/ir.
Doe #1 would often come to the admin building, something he seldom or never did
before or after her accommodation, to have inappropriate conversations with her. He
would try to rationalize her pending divorce and tail her that she should be in a

relationship with him instead.
Andrea?s Return to Work

When Andrea returned in September of 2016, her trials at the workplace forced her to
take antidepressants. By this time she was accustomed to daily abuse by Mr. Doe 
but she come to realize that management at 080 was entirely compliant with his
treatment of her and multiple other temale employees. They knew what was happening,

but they had no interest in preventing these actions.

in the first three and a half months, Andrea was not given a paycheck, though she did
receive one emergency cheque for 33300. As a mother of two young children attending
graduate schooi, she was unable to afford chiidcare in this time and experienced severe

financiai hardship and family stress as a result.

She put in a request to return to 12?hour shifts because otherwise she could not afford
childcare. The acting RTW Manager, John Doe #4 put the change off for over a month
without valid excuse, despite having previously made similar changes for other

employees on a much quicker turnaround.

Around this time, Andrea?s grandfather passed away in Serbia and she requested
grievance leave to be with family. She made the request to Mr. Doe #4 via telephone.
She was clearty on speakerphone, but he retused to telt her who else was present in the
room. He asked her several inappropriate and questions, including where
she would be staying and how she would be spending her days off. He implied to her
that she had no right to grievance leave because her grandfather was not Canadian, and

that she was not entitled to leave it she was not going to Serbia.

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Andrea is Wrongfuity Terminated

By switching to 12-hour shift, Andrea was required to work nights, despite this not being
a part of her employment contract. it was a further implied term of the contract that 080
would provide her with reasonable notice of the termination of her employment and the
termination would be carried outwith good faith and fair dealing and in a manner to

preserve her dignity. it was a further implied term of the employment contract that:

a. The Defendant would were her in clear and unequivocat terms if his job
was in jeopardy and the reasons therefore, along with the goals and objectives to

be met; and

b. She would be treated fairly and in the same fashion as other employees
with regards to carrying out the terms of his employment and with regards to
discipline, and would be provided with fair opportunity to be heard in the event of

an incident requiring review.

On or about March 16, 2017, Andrea was dismissed from employ without just
cause and without any notice, and in breach of the implied terms set out about. The
circumstances of the termination inciuded an allegation of misconduct for which there

was no merit.

Further, or in the alternative, Andrea was not provided with clear direction or was
provided with conflicting direction for her job requirements or unreasonable requirements

were imposed in breach of the employmeht agreement.

Further, Andrea was not provided with an opportunity or any real opportunity to state her

side of the case.
The Union declined to grieve her termination.

Her shift began at 11:00pm, which was 30 minutes later than the start of the

regutar shift. She would typically arrive 15?30 minutes early, yet every night she was

verbally abused by the officers she was intended to relieve, because she was not

reliving them at 10:30. She complained about this to two managers and asked that either
she not be posted to shifts where the officers needed to be relived at 10:30, or that the
officers she was set to relieve be informed that they would not be retieved until 11:00.

Her requests were ignored, and the abuse carried on for severat months.

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One evening, Andrea arrived at 10:40, but the otficer she was relievtng was so angry
about not being relieved on time that he stemmed the door, screamed at her, kicked the
unit television down the stairs, and?removed the batteries out of the portable heater,
which was the main heat source in the unit. Andrea had to continue working overnight in

the Edmonton winter without heat.

On February 24, 2017 Andrea arrived at 10:45 and was posted to a suicide watch. She
reminded the manager that her training for that post was expired. The manger shouted
at her that the unit was short staffed and there was no one else to do it. Andrea was not
comfortable taking this post and wouid have preferred not to. However, by this time she
had sustained considerable bullying whenever she had raised anything resembling a
compliant. Knowing that a compliant would not be effective, she did not speak up for fear

of further reprisal, and took the post.

Her assignment was to watch a sleeping inmate from 11:00pm to 7:00am. She had to
wear a parka because although the inmate she was supervising had a heater, she was
not provided one. She was provided with chairs that were not built for being sat in for
such a period, and she was not given any accommodation for her wetl?
documented severe temporomandibular joint These factors caused her
significant discomfort. She eventualty took a blanket from the office because it was so

cold.

Suicidexwatch required Andrea to keep the inmate in her sight. The cell was not

equipped for viewing the inmate, and Andrea had to slouch to see him.

At one time during the evening, it became apparent that the inmate seifwharmed beneath
his blanket. Andrea immediately took all appropriate steps: contacted manger, calied for

back up, calted ambulance, and applied tirst aid. 

Two officers did hourly walks around the unit, and Andrea spoke with them each time.

She was posted to suicide watch for the same inmate on February 27,
The following week on her day off, Andrea was put on paid leave, but not informed why.

On or around March 14, 2017, she received an email stating that she ?was found to be
negligent while on suicide watch with inmate [name redacted by the Plaintiffs? counsei]

on February 24 and on 27.? it further required her to attend a disciptinary meeting on

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March 18th in which ?the Warden was to decide whether a disciplinary action was

warranted.? The details at the alleged negligence were not stated.

Andrea attended the meeting on March 16, 2017. Mr. Doe #1 insisted on attending and

was ailowed to. Mr. Doe #t claimed to have brokered a deal that would save her job.

in the meeting, the acting Warden asked her whether she had fallen asleep during her
shift on those two dates. She said she had not, and mentioned the conversations with

the hourly patrols. iVlr. Doe #1 did not provide the promised support.

Andrea had a further meeting with the acting warden on April 18, 2017, wherein he gave
her a letter of termination which alleged she had been sleeping during her shift on
February 24. There is no merit for this allegation, The acting warden did not
acknowtedge that Andrea was obviousty uncomfortable, and had multiple conversations
with other officers during these shifts. Nor did he acknowiedge the above~mentioned

remedial steps she took when the inmate self~harmed

The conctusion that she was sleeping is apparently based on a review of surveiltance
camera footage, despite the El?s policy of not using surveillance footage tor employee
discipline. It was further alleged that Andrea do not out appropriate documentation
regarding the suicide watch. There is no merit to this allegation as she did in fact fill out
the correct forms. The form was later lost by (380 due to an internal failure of El?s

administrative policies.

On May 1, 2017, Standing Orders were changed so that no of?cer will be posted on

suicide watch for more than 2 hours.

Andrea?s termination has no merit. It and the Union?s faiture to grieve is cumulation of
discriminatory behaviour and cronyism. As a welt~educated, outspoken, young woman
with a foreign-sounding name who does not tolerate abuse, she was singled out for

abuse and harassment.
tmpact on Andrea

Andrea has not been compensated for the heretnumentioned period where she did not
receive a pay cheque. Her family continues to feel the financial hardship ot her lack of

payment and wrongfut dismissat. Having lost her benefits, she cannot obtain treatment

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for her chronic nor counseting for PTSD related to the inmate suicide attempt and

the harm she sustained at the from male coworkers.

These incidents have caused significant turmoil within her famity; she and her husband

nearly divorced multiple times.

She continues to work towards her master?s degree. She had planned to utilize it over a
long career in Corrections, hoping that she could overcome the mistreatment from
within. Now, unfortunately she has determined that it is impossible, and she has wasted
a large portion of her career and educational efforts towards an organizatton that refuses

to support her.

SAMANTHA

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Samantha?s Background

Samantha has been working as a Corrections officer for approximatety 20 years.
Throughout that time she has been openly gay, and has been married to another woman
for the majority of her service. She herself has no problem with being homosexuat and
does not care who knows. Unfortunatety, this attitude has made her a target of buflying,

harassment, discrimination, and reprtsals from fellow Corrections workers.
Samantha?s Environment

When Samantha commenced her employment she noticed that the atmosphere was
hostile to homosexuals. She was often subject to ridicule. lt was commonptace for mate
corrections officers to make sexualty expticit comments about other female officers, and
then ask Samantha tnappropriate questions about her willingness to copulate with the

woman in question.

It appears to the Plaintiffs that male Corrections employees would often have

conversations amongst themselves about vufgar subjects. There seems to have been
some attempt to soften this when female officers were in earshot. However, due to her
age and her sexual orientation, Samantha was not granted that courtesy. Some of the

remarks she was subject to:
a. ?Who?s your husband??

b. ?it?s OK. l?m a lesbian too.?

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0, Being calied an oitensive nickname despite her objections.

Samantha often complained about these remarks, but no action was taken. Her
complaints were typically dismissed with the expression ?boys wiil be boys.? Samantha
has well?deveioped sense of humour and is not opposed to hearing an off-colour joke
from timewto?time. She was exposed to vuigar comments lacking in wit on a daily basis,
which were far beyond what anyone could consider reasonable humour. This blaise
attitude towards such remarks contributed to the overali toxic culture of the El that

prevented wrongs from being redressed.

Although Samantha was uncomfortable with the negative attitude towards homosexuals,
she was new to Corrections and was keen to contribute and demonstrate her abilities.
She consciously decided to overlook the prejudice with a view to undermining it with her

own actions.

Discrimination

Despite Samantha?s dedication to working at Corrections and her positive demeanor
when it came to inappropriate comments regarding her sexuality, she was constantly
discriminated against. Given her long tenure with the organization she shouid have been
high on the iist to receive overtime. For reasons never explained to her, she was often
passed over for overtime; the shifts were given to male officers with less experience than
her. She filed a grievance regarding this and 21 other instances of statutory holiday pay,

but none of this was taken seriously by the Union or CSC.

When a Corrections officer is sick, it is standard practice to send an officer from a less
pepuiated unit as a substitute. Any time a manager sent Samantha to and Block
under these conditions, Mr. Doe who had de facto control over these Blocks, would

tell her to leave because they did not want to work with her.

In March of 2012, Samantha slipped and feil on the premises, sustaining a broken
right wrist, rendering treatment necessary, This was a result of the negligence of the
Defendant in their faiiure to properly sand and shovel the walkway. She received first aid
on site, but was told that she required an xmray. Mr. Doe #4 told her that if she wanted to
go to a hospital, she would have to drive herself, knowing full well there was a

snowstorm that day. Not adequately treating injuries and forcing empioyees to drive

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themselves to a medical facility was common practice, as it had happened to Samantha

at least one time before.
Samantha ts Peepers-Serayed

There was a single-toilet bathroom in the General Outside building of El that Samantha
would use every day before her shift began. Others seldom used it because it is in a low
traffic area. It was common knowledge that this was her habit. In March of 2015 on one
shift Samantha entered that bathroom at her usual time. Upon sitting on the toilet, she
sustained severe chemical burns to her buttocks and upper legs consistent with the

burns caused by pepper spray that was standard issue at El.

She spent the following week laying her stomach. When she returned to work she

learned that numerous employees were iaughing at her over this incident.

Though this incident was reported to the Union and the manager, it was not thoroughly
investigated. She was told that she had an adverse reaction to a cleaning product, even
though CSC never investigated her burns and no other person sustained injuries from
the alteged cleaning product. Furthermore, pepper spray was often used in so-oalled
practical jokes by bullies at El on other employees, especially in bathrooms. Other

incidents include:

a. Leaving pepper spray on a coworker?s keyboard;

b. Leaving pepper spray on toilet paper; and

c. Spraying pepper spray underneath the door while someone is in a bathroom stail.
?the Recerding

in August of 2016, two anonymous Corrections officers were recorded making vulgar
remarks about Samantha. She has made numerous requests for a transcript, all of which
have been denied. Redacted versions of the transcript have been made available, and
below is what portions of the conversation are known to the Plaintiffs:

Speaker 2: I don?t know. Oh, ah, did you want to do the would-ya now the doubts
header would?ya??

Speaker Yeah let?s do a quick one.

Speaker 2: Okay a quick one. Okay.

Speaker 1: Yeah.

Speaker 2: Now yesterday we were talking and, you know, [redacted], and you know,
[redacted] exposed, you know, his disclosure from 12 years ago. How does [redacted]
save an email from 12 years ago?? Anyway, so here?s the deal: Now behind door number
2 is young [redacted].

Speaker Yeah.

Speaker 2: Hair down, lights down, tanned skin, tan lines. Black heels on, black bra on,
no panties. She?s bent over, she?s got an O?Henry bar sticking out of her ass. Okay,
behind door number 1 though, is [he used the offensive nickname for Samantha
referenced above], same thing 

Speaker 1: Who?

Speaker 2: [Samantha],

Speaker 1: Oh, Okay.

Speaker 2: minus the lingerie, same O?Henry bar, same place. TO get to [redacted]?s
O?Henry bar in her ass by the way, she smells realty good, nice perfume 
Speaker1:?aughs]

Speaker 2: you?ve got to go in there and take you?ve got the one you?and bite the one out of Sue?s ass first. What do you do [redacted]? All
showered up. There?s nothing disgusting about [the offensive nickname] or nothing.
She?s just buck naked with an O?Henty bar sticking out of her ass. What do you do?
Speaker 1: To get to [redacted]?

Speaker 2: exactly.

Speaker 1: I guess t?m going in.

Speaker 2: Yes [redacted]! You?re going to bite the butlet. You?re going to eat down fast.
Close your eyes and pretend it?s [redacted] ass or something.

Speaker 1: Yeah.

Speaker 2: [Redacted] So, you got to go down, bite and i mean the part, the chocolate
thatget that part out, right, and eat that too. And then and then
it?s [redacted] and that O?Henry bar. You can spend all day. The treat is you could spend
all fucking day eating that chocolate bar. i mean, there?s no race against the clock. Oh,
maybe we?ll give you like two hours, So, you can around reading a book and
because you know at our age it needs a iittle break right? But no 

Speaker 1: Take a fucking nap.

Speaker 2: But yeah, okay, so you would, eh?

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Speaker 1: Definitely, to get there?
Speaker 2: Yeah, yeah, exactly.
Speaker 1: l?d be happy.

Speaker 2: Okay, yeah of for sure.
Speaker Would you?

Speaker 2: [laughs]

Samantha was only informed about this recording in October of 2016 because the acting
warden was forced to tell her by regional command. ln a meeting, he described the
recording to her, but laughed about it. He said that he did not tell her sooner because he
was unsure what to do and did nothing in hope that it would go away. He refused to take
any corrective action, but said ?it won?t happen again.? He was still laughing when he

said that, and he made no efforts to prevent such things from happening again.

Samantha soon found out that the recording was common knowledge within El, and that
it was gossiped about by several male officers. She tried to fife a formal grievance, but

the Union President laughed at the conversation and described it as ?locker room talk.?

Samantha has attempted to grieve the matter herself but received little Union support.
The matter was initially dismissed by CSC, but she appeaied it. The appeal was also
dismissed. A Union Representative had represented to Samantha that a further appeal
would be made, but no action was taken, despite Samantha expressing a desire to
continue the appeal. 

The Impact on Samantha

Samantha is currently on stress leave. The recording incident was the final straw in her
workplace stress, but her condition is a result of a conceited effort by the Defendants to
create a workplace rife with bullying and harassment and the resultant years of abuse
she sustained. The failure to prevent or in any way address the Samantha?s
mistreatment has resulted in irreparable harm to her reputation and career in the small
Corrections community. Her career has been irretrievably ruined by the toxic work
environment and whisper campaign that routinely follows whistleblowing. Yet the
Defendants are still attempting to sweep this under the rug by minimizing the findings in
Samantha?s case and discouraging others from standing in sotidarity with her and
coming forward with their own stories.

 

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Samantha?s marriage has sustained severe pressure because of the effect of the abuse
on her, and also because the nature of he;r sexuality has been constantly undermined for
so many years. The stress on their family caused Samantha?s wife to toss lucrative
employment, further straining the family. The abuse has caused them to nearly divorce
several times.

Samantha suffers from panic attacks, low mood, depression, insomnia, and of

PTSD. She manages this through weekly care of a 

JESSICA

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Jessica?s Background

Jessica commenced employment as a corrections officer with CSC in May of 2007.
During this time she sustained emotional, and physical abuse at the
hands of superior officers. This was institutionalized abuse, ingrained in the culture.
Jessica lived in constant fear of reprisal so she never spoke out. Taking this matter to

the Union was not an option, because her abusers had positions within the Union.

Jessica joined Corrections when she was 22 years old as a starting point for her lifelong
dream of being a police officer. After devoting her adult life to Corrections and receiving
no other training, she is not qualified to work in any fiefd other than law enforcement.

However, due to the abuse she sustained she is incapable of being anywhere offenders

or institutions.
Jessica?s Introduction to Corrections

Jessica was inadequately trained for her role as a corrections officer, but was
nevertheless deemed fit for duty and began work at the Edmonton institution in May of
2007, when she was 22 years old. She soon met Mr. Doe Her rank was Correctional
Officer 1 and Mr. Doe was CX2, one rank ahead of her. He acted in a paternal
fashion towards her, telling her that he would protect her from inmates and any internal
issues. He specificaliy told her that no one would survive without someone they could
trust, and presented himseff as that person to her. He made similar representations to

her father.

in May Mr. Doe #1 told Jessica that there were rumours she had had an affair with an

instructor. This was untrue; Jessica never met this instructor and he was not an

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instructor for any training that Jessica had received. Severat months later Mr. Doe #1
informed Jessica that the instructor had denied having coitus with her, but claimed that
she performed fellatio on him. Jessica had still never met this man, but she was afraid of
these rumours damaging her reputation, and Mr. Doe #1 acted as though he could
protect her. if these rumours were not started by Mr. Doe he at least used them to

increase Jessica?s dependence on him.

Jessica felt woefully underquaiified to deal with inmates due to her lack of training, and
she constantly lived in fear of the inmates due to her small stature, weighing
approximately 110 at the time. Mr. Doe #1 assured her that he would protect her
from violence. He made similar claims to Jessica?s father. Mr. Doe #1 presented himself
as a mentor, a protector and a confidant. As a CX2 and a military veteran he was trained
to handle all kinds of inmate issues, and he is a physically imposing man, weighing
approximately 265 lbs. He also called himself Jessica?s best friend, often enough that
other staff and eventually Jessica repeated it. Over the years he would do many things
to make her rely on him. There are many examples of horrible things that Mr. Doe #1
has done, but it is important to note that he is witty and charming, able to make people
trust him and very adept at reading people. He uses this to manipulate people. His
former partner quit Corrections because of stress and depression caused by Mr. Doe

#1 ?s manipulation.

in Jessica?s first week, an officer made many inappropriate advances on her, then
started calling her personal phone and emailing her personal account Main
Communications and Control Post had given him her contact information without her
consent. After some months, Mr. Doe #1 told Jessica that he had an argument with that
officer. Jessica does not know what was said, but the officer left her alone after this. Mr.

Doe #1 later ended similar inappropriate advances from a different officer.

in July of 2007 there was an inmate riot, which required Jessica to use a firearm on
inmates, despite not having been adequately trained in riot suppression. This
dramaticalty increased her fears of working at the institution and forced her to rely on

individuals such as Mr. Doe #1 even more.

Beginning in late 2007, Jessica dated a Corrections Officer. Mr. Doe #1 often ridiculed

their relationship; it ended after six months later and for years after, Mr. Doe #1 wouid

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ridicule her for choosing her boyfriend over him. He made it a habit to use this and other

things to embarrass her in front their colleagues.

She later found out that the officer she dated had shown intimate pictures of her to the

Emergency Respense Team without her consent.
Ongoing Harassment

For nearly ten years, Jessica was sexually harassed daily. Mr. Doe #1 made a habit of
stirring her and other female officers? unattended drinks with his penis and not telling
them until after they had drunk from it, then laughing. A Programs Officer once saw her
through a glass window and, with several inmates watching, threw himself against the
glass, gyrated his pelvis, and made sexual noises as he ticked the glass. On other
occasions he would ask her and other femaie officers to close their eyes and hold out a
finger. He would then suck on the finger. Jessica formally complained about this, but

nothing was done.

Mr. Doe #1 would often pull his genitalia out of his pants and parade himseif around the
office, causing Jessica to run out of the room. He would chase after her with his penis in
his hand. Mr. Doe #1 would urinate into rubber gloves, tie them off and threaten to throw
them at Jessica. On two occasions, he did. He would keep several hidden in the office

for months at a time as a grim reminder of the consequences for disobeying him.

On another instance, a manager entered the crowded office and toid Jessica that he
would like her to come to his house wearing nothing but a trench coat. He totd her that
his country house was in a secluded area and said, ?i will fuck you so hard and no one
wiil be able to hear you scream.? The male officers in the room iaughed at this. Jessica
was not able to stand up for herself so she took this abuse, and it increased her reliance
on Mr. Doe He would participate in this abuse body shaming her, shaming her
sexuaiity, saying she was not marriage material, and saying that she could not survive
without him but wouid come back and apologize later. He wouid catl her his kid and
that he wouid never do anything to hurt her. He would often reassure her that he ?had
her back? and would ask her to confirm that she had his back. Jessica said ?lnitiallyl
found his humour crass, obnoxious yet stiil funny and almost addicting at times. He

could make me taugh so hard, then crush my ego at the next moment.? After

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approximateiy six months Jessica was mirroring Mr. Doe #1?s behavior. She spoke and

walked the way he did.

Mr. Doe #1 deliberately undermined Jessica?s relationship with female officers. He would
tell female officers that Jessica hated them, and say that she had insulted the female
officer. He would then tell Jessica that the femaie officer had claimed to hate her. Later
Jessica determined that she and several female officers had been hostile to each other
for no reason other than Mr. Doe #t?s meddling. When pressed, he said that he did it for

his own amusement.
Jessica Seeks Support

in 2009, there was a change in mobilization of corrections officers. While Jessica and
the other CX1s had been responsible for patrols, they now had to work the ilving units.
Jessica had no training to do this. Since 2007 she had been rotating between the and
units and others, and this did not change. unit was populated by gang members.
Though it was iabelied the more violent of the units, the inmates policed themselves and
never attacked femaie officers. Jessica was more fearful of working in unit, which
housed sex offenders and did not have the self?policing features of unit. She relied on
Mr. Doe #1 to prevent herfrom being assaulted. in 2013, Mr. Doe #1 tirelessiy coerced

her into working and at all times, which furthered her reliance on him.

Mr. Doe #1 was often candid with Jessica about his own demons. He was confident that
because of their relationship she would not share his secrets, and she did not. This was
a manipulation tactic; it convinced her to share secrets with him. Unfortunately Mr. Doe
#1 did not did not protect her personal secret the way she did his. He would use this

information to humiliate her in front of her peers.

He had a simiiar relationship with his partner. lVlr. Doe #1 knew his intimate secrets and
would occasionally release them for his advantage. Eventually, in 2014, he took it too
far. To protect the partner?s confidentiality, the particuiars of this will not be specified.
Suffice to say, over the course of one week Mr. Doe #t often and loudly proclaimed very
private information about his partner to anyone in the who wouid listen, without
any apparent motive. After this incident, the partner quit. The partner had often worked

with Mr. Doe #1 and participated in his misfeasance. Jessica wouid humourously refer to

them as ?my creepy uncles,? but the partner was the more restrained of the two, often

acting as a voice of reason.

99. Without his partner holding him back, Mr. Doe #1?s treatment of Jessica worsened. The
verbal abuse and breach of trust became more common and brutal, though he would still
occasionaily use gentie words and humour to pacify her. Jessica now says that she felt

like his hostage because she relied on him but the abuse was traumatizing her.

100. Mr. Doe #1?s new partner was CX2 John Doe She dearly missed her relationship
with the former partner and Mr. Doe #6 filled that void. She described her retationship
with Mr. Doe #6 thusly:

[John] was very attentive to me. He teased me like a little sister, and he
listened to what I had to say. He protected me, gave me great advice,
and we were able to laugh and joke like old friends would. I felt accepted.
I felt cared for and shifted the level of trust I had built with [redacted] over
7 years of working together all onto [John]. This transition happened
almost immediately. The helplessness a woman feels inside those walls
is palpable. And finding a proverbial protector means higher likelihood of
emotional survival. He took on the role that I needed him to be. Protector,
adviser, platonic friend. I relied on him more and more for emotional
support. And he relied on me for the same. We initially had- what I thought
was a genuine friendship and partnership. Then he started buying me gifts
that made me uncomfortable over time. I had shared so much with him, I
didn ?t want to hurt his feelings by not accepting them. This was a massive
error. The gifts went from food and snacks, to books, to jewelry, eventually
to sex toys. We had talked too much about sex. And if other OX are willing
to admit? basically everyone does in there does. It always turns to sex

talk over time.

[John] grew more protective as the years went on, and I embarrassingly

allowed it. I felt neglected by my husband due to opposite schedules. The

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stress of my hatred for work consumed me. I hated everyone. I didn't
trust anyone. I was miserable at home as well. I turned to [John] and cried,
and divulged every last drop of my thoughts onto him. He was extremely

supportive.
Mr. Doe #6 Turns on Jessica

Jessica?s marriage suffered because of her trauma at work, and also because she and
her husband worked opposite scheduies. She sought Mr. Doe #6?8 comfort, which sadly
drove her and her husband further apart. At this time Mr. Doe #6?5 behaviour became
less supportive and more abusive, beyond just the inapprOpriate gifts. He scoured her
social media accounts. After she left her husband in May 2015 she stayed with a friend.
She and the friend went to visit the friend?s parents in Entwistfe. Jessica posted a picture
on Facebook of their bonfire. The following day Mr. Doe #6 posted a photo of himself in
his car in Entwistle with the caption ?just out for a Sunday drive.? He drove around the

area trying to find her.

After this incident Jessica deleted her social media accounts. Mr. Doe #6 did not ease
oft, however. He would constantly text message her friends, especially the one with

whom she was staying, asking where Jessica was.

The stalking escalated. He would text her and colieagues asking when she was working.
Mr. Bee #6 always refused to work overtime, yet during this period he would often drive
to the institution on his days off to see if Jessica?s car was in the parking lot. He woutd

sometimes leave sex toys in her car. Jessica had to purchase a new car to avoid him.

To many staff members he accused her of manipulating him to purchase gifts for her,
when in fact ail the gifts he had bought were unwanted. He also accused her of faking an

injury she sustained on a vacation, but the injury was legitimate.

Mr. Doe #6 would often inappropriately touch Jessica during shift. On two different
occasions he grabbed her between the legs and smiied at her in a predatory manner.
They often wrestled with each other. At first she had gone along with it as it was in fun,
but it later turned sexes! and she tried to avoid it. The sexual escalation was around the
time he began statking her. One evening while she was in the bathroom he tried to kick
down the door, and laughed at her terror. The wrestling stopped in November 2015. She

avoided him every time he tried to initiate it. in retaliation, one evening he grabbed her

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and forced her to bend over a desk while she struggled to get away. He put his hand I
down her pants and pulled up her underwear, took her handcuffs and cuffed her through
her own underwear. He tater told her that he had spent the previous night planning this

attack.
The Relationship Sours

By December 2015 her relationship with Messrs. Doe #1 and Doe #6 had soured; they
continued to abuse her, but they ceased pretending to be her friend. The incident that
sticks out the most occurred that month. Jessica?s desk faced the door to a single-toilet
bathroom. Mr. Doe #1 went into the bathroom but did not close the door, and stared at
her while he defecated. Jessica knew there was nothing she coutd say or do make him
stop, so she tried to ignore him. Not getting the response they were hoping for, Mr. Doe
#6 grabbed Jessica and dragged her into the bathroom while Mr. Doe #1 was stilt on the
toilet. He had not ?ushed. He lifted one side of his buttocks and Mr. Doe #6 shoved her
face into the gap between Mr. Doe #1?s buttocks and the water. Both men taughed while

she screamed and struggled.

After this Jessica was subjected to verbal abuse and/or sexual violence every day at

work, on a target scale than before. Some other incidents includedwaterboarding her and iaughing about it;
b. Both of them would often put her in choke holds;

(3. Mr. Doe #1 would throw her against the wait and choke her;

Mt?. Doe #1 made a habit of grabbing her by the hair and slamming her face into hard
surfaces; and

e. her to chairs. On one such incident, she was found by the Deputy

Warden, who laughed about it and took no remedial or disciplinary steps.
Further Mistreatment

Jessica sustained additional trauma as a result of negligence by the institution?s
negligent management and Union officials. In December 2012 when a high-ranking gang
member was released to a halfway house. This individual had previously threatened to

murder Jessica and her family. Shortly after arriving in the halfway house, he escaped

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and was at large for six months. Jessica had to fear for her and her family?s safety this
entire time. 080 took no protective measures. Mr. Doe #1 had such influence within

(380 that mistreatment of Jessica was promulgated.

in the felt of 2015, several inmates made a plan to gang rape and murder Jessica.
Management was aware of this plan; they even knew the date and time that the inmates
were planning to execute it. Jessica was not tofd of the plan, however, and went to work
that day none the wiser. Perhaps by providence, she was warned of the scheme fess

than an hour before it was ptanned to occur. She left the unit immediately.

in January of 2016 Jessica was assaulted by an inmate who had long posed a threat to
her. She had complained to management, but nothing was put in place to protect her. In
April of 2015 this inmate, who had been convicted of raping and murdering several
women, was transferred to unit from a special handting unit in Quebec known as
Super Max. He would often make advances and threats, and took obvious pleasure in
seeing Jessica?s fear of him. This inmate?s job within the prison was to clean offices that
Jessica worked in. That job is one of high trust and supposedly reserved for well-
behaved inmates. Jessica made her concerns about this inmate known to her superiors
and protested giving him that job, but they did not heed her. They laughed at her for
bringing concerns with this man cteaning her office. The January incident was as follows:
Jessica was in the office on the phone, unaware that the inmate was in there cleaning.
He crawled under her desk, leered at her, and rubbed himself against her thigh. She
jumped up and screamed. She then looked at Mr. Doe who was also in the room. He
smiled as if he found the assault amusing, and shrugged his shoulders. He had been
aware of the inmate?s presence the entire time, but did nothing to protect his partner.
The experience of being targeted by a convicted rapist and murderer was traumatizing.

That Jessica had asked her superiors to protect her from that compounded this.

By January of 2016, Jessica was suicidal. After this incident, whenever she was at work
Jessica would hope that an inmate would stab her to end her ordeal. She stopped
wearing her body armour, but no one in the system did anything to prevent this obvious
safety hazard. Also, every day until she moved to British Columbia, as she drove to the
she would contemplate driving her car off the Terwillger Bridge. She hoped for
detiverance in something that looked like an accident because she feared humiliating her

family by committing suicide.

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All of this caused severe problems in Jessica?s personal life. In May 2015 her marriage
broke down. She lost her home and her pets in the divorce. She transferred to the
Pacific institution near Abbotsford, British Columbia (often calied Matsqui for the
community nearby) in September, hoping for a fresh start. This was a much safer facility,
but once she began there she incurred similar treatment. On her first day, the security
maintenance officer, a high-ranking CX2, asked her why she had been transferred. She
told him the truth, but he asked her repeatedly what the real reason was and told her ?it?ll
take me a matter of minutes to find out what you're really about.? His intimidation made
her feel as though she had something to hide and forced her to withdraw within herself.

After this, she had an anxiety attack every time she saw him.

The abuse did not stop at Matsqui. in October a mate repeatedly yelled at her ?do

you want to fuck?? in front of several people.

By January of 2017 Jessica was unabie to cope with being in a prison. She would
experience panic attacks with many of the described above. it was at this

time she was diagnosed with PTSD.

After the 2014 death threat she had sought medical care, but her trauma left incapable
cf articulating all that had happened to her prior to the death threat. The doctor could not
diagnose her with PTSD based on one traumatic experience; the diagnostic criteria
require multiple. Finally, in 2017 she was able to describe these events to a 
who diagnosed the diagnosis was confirmed by an MD and another 
speciafizirig in trauma counselling. These professionals described her PTSD as the
result of a slow drip of events, not one breaking point that caused PTSD, but ongoing

physical and emotional abuse.

She still has great difficulty facing this situation. She has been iiving in British Columbia,
but when she returned to Alberta in March 2017 for the PTSD diagnosis she described
the experience of landing at the Edmonton Airport as ?like walking into the gates of hell.?

She nearly attempted suicide the following day.

Jessica?s issues are a result of the abuse and trauma she sustained while working at
Corrections. The failure to properly train her, and the refusal to respond to any of her

legitimate complaints. The Union provided no support for her. Her abusers all had

prominent positions in the Union, and for the most part still do. Mr. Doe #1 was the

Union?s vice president.

118. Certain individuals have been singled out for their specific misdeeds against Jessica, but
this is part a systematic problem that allowed these men to abuse Jessica and many

other female officers.
impact on Jessica

119. Jessica is in hiding because she still lives in fear of reprisal from her abusers and from

080 maeagement. She deleted all sociat media and lost touch with most of her friends.
120. She experiences many challenges, including but not limited to:

a. Post Traumatic Stress Disorder

b. Claustrophobia

0. Panic attacks

d. Flashbacks

e. Anger issues

f. Trust issues

g. Parental alienation

h. Social isolation with an inability to bond with people

i. Social anxiety

j. Nightmares

k. Dissociation

1. Lost focus

m. Hysteria

n. Seizures

o. Nausea

p. Panic attacks which induce crying fits, vomiting, hematochezia and many of the other

physical listed here.
q. Scotophobia
r. Androphobia
s. Agoraphobia
t. Loss of enjoyment of life
U. Paranoia
v. Hair loss
w. Suicidal urges
x. Foniasophobia
y. Hypophagia and resultant weightless
z. Generalized anxiety
aa. Fear of showering
bb. Excessive Drinking
cc. Marijuana abuse
dd. Self-harm
ee. Aggravation of Crohn?s disease 

121. Jessica was proud to join 080. She enthusiastically gave her entire adult life to the
organization with a view to having along career in law enforcement. She is diligentiy
mitigating her damages, but the abuses she suffered have ruined her career and ieft her

incapable of living her life.

SARAH

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Sarah commenced employment with Corrections in December of 2009. She is well?
educated with a law enforcement diploma and Bachelor of Education degree. She was a

licensed teacher, having formerly been employed by an Edmonton school board.

Though many Corrections officers joined CSC as a means of obtaining skills and
education that would be useful in a permanent career, Sarah relinquished a stable,
lucrative career in education to work as a Corrections officer. She joined Corrections
intending to enrich the organization with her hard work and skills over a long career. She
hoped to make a difference in the lives of offenders. She graduated at the top of her
class in training, informally voted as the most likely to be a warden someday. She was
very active within El, using her education background as a staff trainer/mentor for new

recruits, and was very proud of the integrity she tried to inspire in them.

Despite her commitment to Corrections and her potential, CSC created an environment
that was hostile to a woman of Sarah?s and skills. She has been a dedicated,
loyal, and committed employee of an organization that is extremely demanding of its

employees but repays loyalty in deliberate manipulation and harm.

Sarah was formerly very proud of her work with Corrections, but can no longer take pride

in or respect an organization that does not respect her.
Sarah?s Working Environment

At the beginning of her career, after she was offered a spot in the Correctional Otficer
Training Program, her interviewer told her because she was a young, pretty girl she
would have more problems with her male co?workers than inmates once she started
work at El. On training, Sarah was warned by multiple instructors that El often
mistreated female employees, both sexually and by limiting advancement. El was stated
to be a ?black cloud? and the worst prison to work at in Canada. Sarah noted this, but
was confident in her ability to handle herself in inappropriate situations and that her skills
would overcome any sexist treatment. One instructor told her ?she?d be a calming

presence in a sea of chaos at El.?

Sarah received numerous harassing comments from various CSC employees over her

employment. These included but were not limited to:

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a. ?Women want to be seen as equals here but do not comptete the same duties such

as a man, like strip searches.?

b. ?Females scam the system by starting here, becoming pregnant, being

accommodated and taking maternity leave.?
c. ?Go clean the shitters?

of. ?Women flirt and smile at convicts and are convict lovers? because we try to deal with
them humanely and build rapport. Affects females ability and confidence to do their

job.
e. ?Women are just felt here for male officers? and as such distract mate officers
f. ?El is no place for mothers to be working? shortly before she became pregnant

g. ?What kind of woman wants to work in a male prison. The ones with something to
prove to men?

On training Sarah was flirted with behind closed doors with different instructors. The

attention was constant and very uncomfortable.

During a tour of the prison after training was complete, an officer working on a living unit,
who has since quit, shouted at her ?if you have a fucking brain in your head, you witl go
do anything else you can than work in this fucking shit hole.? Sarah was shocked. No

one else reacted besides to laugh and roll their eyes.

In her first month of emptoyment at El, a senior officer was upset he was chastised by
management for relieving Sarah late on a post, so submitted false reports to the Union
and management without Sarah?s knowledge. She was humiliated when she was
approached by her on the job trainer about remedial training. She knew how important it
was to cement a solid reputation as a new femaie officer. Sarah was outraged and told
the Union and the trainer he had lied. These people believed her but shrugged their
shoulders and said ?that?s [name redacted by Plaintiff?s counsel], you can?t realty trust
him.? Nothing was done to support her. Sarah was so shaken up by the outrageous
tarnishing of her repotation, she was finally forced to confront him in the parking lot one
morning before work. He admitted he had lied and said already have a harassment

complaint against me by a woman and was going to get you before you got me?. This

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rnate officer was also notorious for saying women had no business there and were in the

end ?only tail? for the male officers.

Shortly after she started working at El, she was approached by Mr. Doe who seemed
to be trying to cultivate a relationship with her that was similar to his relationship with
other femafe officers as described herein. Sarah was able to resist this, though on one

occasion he grabbed her buttocks without any warning and without her consent.

Her resistance of Mr. Doe #1 was characteristic of her work there. She was constantiy
exposed to the toxic masculinity and rampant misogyny of the Corrections culture. The
fear and paranoia were so great, she chose to stay within the perceived safety of her
own crew, then take a 12 hr position which she had been waitlisted on for over 6 years.
Taking the coveted position would have meant she was more exposed to Mr. Doe #1
and his crew which she was terrified of. Her personal life would have been greatly
improved with this schedule change. Corrections black bailed her, stifled her

professional development and refused to support her.

Sarah was humitiated in front of members of the public and multiple staff members at
visitor security where she was working, when an officer walked by and yelled ?my God,
you?re beautifui?. Silence fell in the entire area, people stared and she was too

embarrassed to say anything.

Sarah fett uncomfortable and like her safety was in jeopardy when male co?workers
would say things like ?080 says a guard is a guard, hey?! Let?s see a femate use a
shield on an offender or maybe we won?t show up in the next physical altercation and

let?s see the girls gain control of the offender on their own.?

Upon returning to work from more than a year off from uniform due to maternity leave,
Sarah entered the main gate for her first day of work. Already intimidated for the above
stated reasons as well as being gone for a significant length of time, she was met with
the foltowing greeting ?if this isn?t the most sorry sack of shit to see returning to work I?ve

ever by a male officer.
Sarah?s Pregnancy and Return to Work

Sarah became pregnant with her first child in 2015 and went on maternity teave some

time after. She suffered from anxiety and depression during her leave and was often

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kept up at night worrying about returning to such a toxic workplace as a new mother and

also with medical complications resulting from pregnancy.

She returned to work on March 14, 2017'. However, she began her efforts to return to
work at the end of January knowing she would need a medical disability accommodation
supported by doctor?s note. She was not fit physically or mentally to be a correctional
officer at the time. As the RTW manager, Mr. Doe #4 was evasive with her from January
right up until the day before she was slated to return to work. He asked why she was
asking for accommodation so early, sounding suspicious as to her motives. Sarah was
being professional and giving her employer ample notice. He took weeks to get back to
her phone calls, said he would see what ?acting Deputy Warden was willing to do for
her.? This uncertainty created such anxiety Sarah was unable to enjoy the last 2.5
months of her maternity leave with her new daughter. The day before the return to work,
Mr. Doe #4 finally told her to just come to his office the next day and he would figure it
out. This treatment did not allow Sarah to secure proper child care. Thus, her mother

had to care for her daughter to allow her to work.

Management put her in an inappropriate accommodation as a full time clerk which
has a heavy workload and Sarah was working only 3 days per week. As the work tell
behind, Sarah was hearing comments about her work performance which caused her
stress and anxiety. She wrote an email acknowledged her complaint and said they would move her or get the supports in place

to help her. She never heard from him again.

Sarah had to walk by Mr. Doe #4?s desk to get to her own office. He used this to
continually bully and harass her. In May 2017 he told her she would have to be back in
uniform by July, completely ignoring her doctor?s orders, or Mr. Doe #7 says ?we will
have to look at getting you out of your correctional officer position.? Many male officers

have been on accommodation for years.

Sarah complained about this to her Union rep, John Doe who physically dismissed
the complaint with a wave of his hand, and refused to listen to the substance of the
complaint, constantly interrupting her. He laughed at her patronizingly and said ?wow,
you?re really upset.? Despite Sarah?s disability, Mr. Doe #3 asked various inappropriate
questions about her personal life, another bullying tactic. When she tried to explain the

bullying and intimidation, he said ?Wally knows he can?t do that. forget about

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him.? When Sarah requested the Union make a harassment complaint, Mr. Doe #3 said
?that?s a tong drawn out process which most likely won?t go anywhere.? He later added ?l

don?t know how to file those. You?ll have to talk to [the Union President].?

Sarah emailed the Union President and Mr. Doe #8 about this complaint, but no action

was taken.

Several days later, Mr. Doe #4 abruptly dropped Sarah from his caseioad looking like

Mr. Doe #3 may have broke confidence and told him Sarah mentioned harassment.

A culture of bullying is manifest within the El. Any sort of complaint is met first with
dismissive comments. When an individual such as Sarah tries to push a complaint, they

are met with hostility and intimidation in an attempt to preserve the status quo.

In July Mr. Doe #4 stopped Sarah in the haliway as she walked by his office, this time
saying ?so you?re going back into uniform next week. We are going to put you at the
main gate.? This was contrary to her doctor?s orders and wouid put her in a post where

bullying was rampant because it was viewed as ?good post steaiing.?

Sarah was in shock. She sent a email to Mr. Doe the Union, and Mr. Doe #7
regarding this pattern of buliying, harassment and job threatening since January 2017.

No one ever responded by email, visit or phone call.

Several RTW meetings were strangely scheduied on Sarah?s days off. She oniy became
aware of these meetings when she would receive a phone call from current manager

about the missed meetings.

in October 2017 this intimidation continued during a RTW meeting in the acting deputy
warden?s office. The office climate was somber and very cold. Mr. Doe #7 had received
Sarah?s multiple complaints but as already mentioned, ignored them all. Union rep
John Doe #3 marched in without a glance at Sarah. Directly after the short meeting,
before Sarah could exit the officestarted laughing and
shaking each other?s hands and being very gregarious, a direct contrast to the climate
minutes earlier. They closed the officer door behind Sarah to taik amongst themselves

making Sarah feel anxious and isolated.

148.

149.

150.

The Fentanyl incident

On July 13, 2017 at approximately 12 noon, a suspicious piece of mail was received at
the visits and correspondence area of El. The piece of maii was similar to multiple
incoming letters containing fentanyl received in June 2017. The piece of mail was
brought to the Security intelligence Office where Sarah was accommodated as a clerk.
Jane Doe an clerk, took the piece of mail to be ion scanned at visitor security
where it hit as being laced with meth and fentanyi. Sarah only learned this
information days later through other SlOs. The mail was brought back to the office and
acting warden and Ms. Doe #5 were behind closed doors with it. The acting warden
soon exited. Ms. Doe #5 burst out of the office at approximately 2:20pm and ran by
Sarah without saying a word, leaving the door to her area open. The fentanyl laced letter
sat on a desk approximately 8 ft from Sarah?s desk. As a clerk, she routinely gathers up
paperwork, files and mail to be placed in proper places. Ms. Doe #5 over dosed in health
care and had to be revived with Narcan and medical intervention. Visitor security was
quarantined, and all staff and visitors were processed through the sally port. Three times
the acting correctional manager entered the SIG office asking Sarah if she was okay, but
rushed out each time without actually telling her what had happened. He mentioned
there were staff on the way to hospital, but left in an agitated state before she couid ask
further questions. She was never toid fentanyi was the cause of the danger or even that

it was possibly in her work space. No one investigated where the danger was.

Though Sarah was blissfully unaware of her danger, Ms. Doe management and
health care were aware it was present in the institution, most likely where Ms. Doe #5
had been working. Despite the risk, not a single person could be troubled to inform
Sarah that she was sitting or possibly sitting right next to a hazardous substance in the
open. All relevant parties were aware that Sarah is a young mother who had to pick up

her daughter at day care immediately after work.

Sarah?s shift ended at 4pm. At approximately 4:00, she was preparing to ieave for the
day when the acting correctional manager entered the office for the third time and said
?can you do me a favour and leave? I should have asked you to leave when ali this
happened?. Still unaware as to what even happened due to his poor communication,
Sarah compiled as she was done for the day anyways. inmate caused incidents are very

common at El so she did not think much of it. She closed the inner office door which was

151.

152.

153.

154.

155.

approximatety 1-2 feet from the piece of mail which sat exposed to the air all night on the

desk. A hazmat team supposed to clear the mail that evening missed it.

Miraculously, so far as the Plaintiffs are aware, no one was harmed by fentanyl exposure
besides Ms. Doe who did not follow any of woefully outdated and inadequate
fentanyl handling protocols. There was no separate mail processing room or any safety
measures in ptace for safe handling, even though El was proud of seizing 13,000 dollars
worth of fentanyl just weeks eartier. Ms. Doe #5 opened it carelessly in a working office
space not only endangering herself, but her co workers and the public. Had fentanyl
been on Sarah?s clothes, she could have exposed fentanyl to any of the children at the

daycare, particularly her own daughter when she physically picked her up.

The Defendants showed wanton disregard for the safety of Sarah and of the public at
large. This is of larger issues within 080. Policies are ineffective, but that is
moot given that policies are not followed. The Defendants had no interest in protecting

employees, especially not female employees who do not toe the company line.

As of this writing, not so much as an incident report has been tilted out regarding the
fentanyl episode. 0808 policy regarding hazardous substances was not followed. The

envelope was not actualty removed from the area for several days.

Aftermath

On or around August 9, 2017, Sarah emaited Mr. Doe #9 the then Occupational Health
and Safety committee member regarding the fentanyl incident. They spoke on the phone
that evening. Mr. Doe #9 expressed shock at management?s mishandling of the
situation. However, when Sarah mentioned a grievance, he became cautious, saying ?for
every action you take in this place there is a reaction. I want your eyes to be wide open
before you go down this road.? She responded that the reaction would be worth it. He

advised her to inform the Union President to initiate the complaint process.

Neither the President nor Mr. Doe #8 would bring Sarah?s complaint forward, despite
receiving emails from her outlining the complaint on or around August 10 and 15, 2017.
She left her personal phone numbers for them to be make sure they could get hold of

her when they came on shift.

156.

157.

158.

159.

160.

161.

162.

Sarah tried to escalate her complaint by contacting Don Head, the CSC Commissioner.
She was very concerned there were no or reports on the incident. Mr. Head was
also concerned there were no cempieted and promised to meet with her the next

week when he was at El. He never met with her.

At 3:00 pm on August 15, 2017, the acting warden requested a meeting the next
morning with Sarah to discuss the matter. She was initialiy agreeable, but cancelled
when her Union reps did not respond to her email of that date, not wanting to attend a

meeting with the deputy warden without Union representation.

On cr around August 21, 2017, the acting warden again requested a meeting with
Sarah, this time giving only one hour?s notice. She did not attend because she could not
obtain Union representation. She contacted Mr. Doe #9 regarding lack of Union

response.

That afternoon, iVlr. Doe #8 visited Sarah at 4:00pm, knowing this was the end of her
shift and she had to pick up her daughter, using this as a means of avoiding having
substance to the meeting. He did not ask any questions regarding the fentanyl incident.
in a response to her allegations of bullying and harassment, he simply said he ?is
abrasive.? Sarah tried to persuade him to file a complaint, he emphasized he ?is abrasive
to everyone, so don?t think you?re special.? He had a confrontationai demeanour. He left,
saying ?we haven?t forgotten you.? No plan to deal with Sarah?s issues was made not
her accommodation, the bullying, or the fentanyl and she has had no further

communication from the Union.

The Union has taken no corrective action. The Union works with the employer, not to
represent its members, but to enrich a select few at significant expense to vulnerabie

members such as the Plaintiffs.
impact on Sarah

Sarah continues to work in her reduced capacity which is tantamount to constructive

dismissal. She struggles to come to work daily.

Sarah made significant sacrifices vis-a?vls her career and family to work at Corrections,
and it has cost her dearly. Her high blood pressure condition which she has been

accommodated for has been exacerbated by all this hardship and stress. She has lost

163.

164.

165.

166.

167.

168.

169.

her health, having gained 90 pounds since her employment commenced. She has
sought counselling and alternative therapies where her weight gain has

been attributed to depression and trying to protect herself from her environment.

She was still interested in furthering her career with 080 up until August 2017 when she
half completed the application to become a parole officer, but stress and depression kept
her from completing it. She had informed management of her intent to become a parole

officer.

She has had to use all her vacation, sick time and FRL for stress related to all of these

incidents and toxic environment. She is now ?46 sick time for the first time in her career.

She has had to undergo financial hardship from mentally being unable to work at El

more than three days per week and take days off with leave with no pay.
Her marriage is under strain due to stress, anxiety and depression.

She has had trouble maintaining her household and dealing with her 2 year old daughter
due to this strain. This has negatively impacted the first two years of her daughter?s life.
Precious time and bonding she can never get back. She has had to rely heavily on the

support and help of her mother and sister.
Wearing the CSC uniform cost Sarah her dignity.

The clinical therapist El recently hired, told Sarah in his opinion ?it seems El has taken a
piece of who you are away from you and you need to find it again for yourself before you

can even think of being fully successful in another career.?

THE WRONGFUL CONDUCT AND ON THE 

170.

Forms of Wrongful Conduct

The Piaintiffs, and other 080 employees, have experienced discrimination, harassment,

bullying and abuse of authority in various forms, including but not limited to the foliowing:

a. Discrimination, including in relation to gender, race, ethnicity, sexual orientation,

religion, age;

b. Name calling, insults and put?downs, and personal attacks about their private lives or

personal attributes, as well as spreading rumours;

Withholding information or responsibilities;

Withholding training, education, and employment opportunities;
Sabotaging another?s work, and otherwise interfering with their work;
Setting unrealistic goats;

Punitive transfers and other punitive work assignments;

improper, unwarranted and disproportionate criticism or discipline, and trivial fault?

finding;

Acts designed to humiliate, embarrass, exclude, isolate, or denigrate;
Exclusion or siagiing out for unusual treatment;

Assigning menial tasks below the Plaintiffs? abilities or outside their job tasks;
Undermining the Piaintiffs? performance, career, and career opportunities;

. Acts meant to affect working conditions or career development;

Acts intended to cause emotional stress, anxiety, and harm;
Inappropriate questions regarding the Plaintiffs? personal lives;

inappropriate use or disclosure of confidential information about the Plaintiffs;

Threats and reprisals for questioning, complaining, grieving, or seeking assistance to

deal with discrimination, harassment, abuse of authority and builying;
Sexuai assault;

Wrongful and bad faith use of internal administrative and discipiine processes and

managerial discretion; and
Such other and further wrongful acts as may be proven at trial.

The above is collectiveiy referred to as the ?Wrongful Acts.?

171.

Defendants? Failures

The discrimination, harassment, bullying and abuse of authority suffered by the Plaintiffs

has been made worse by the Defendants? failures, including:

a. Maintaining and permitting an organizational culture which fosters harassment,

bullying and abuse of authority;
b. Refusing to recognize Wrengful Acts as wrongful, or complaints as valid;

c, Wrongiy asserting that misconduct was a reasonable exercise in managerial

discretion;

d. Failing to properly supervise the workforce, including in particular members of

management and Union officials, to prevent or minimize Wrongful Acts;
e. ignoring complaints;

f. Failing or choosing not to recognize problems, even where the circumstances

warrant investigation, such as where:

i. Multipie complaints within a working group and/o:r against an individual

authority figure is made;

ii. Many employees are ill and/or seek to be transferred from a working

environment;

Poo:r morale, poor performance and/or increased tensions within a working

group; or
iv. High absenteeism within a working group.

g. Failing to properly investigate complaints in a timely way, properly, impartially, or at

alt;

h. Failing to hold accountable those individuals found to be in breach of applicable

legislation, policies, procedures, and guidelines;

i. Engaging in or permitting retaliation for raising discrimination, harassment, bullying

and abuse of authority concerns;

172.

173.

i. Failing to act and/or failing to perform an adequate or any investigation or review,
particularly when undertaking to do so, and/or failing to act when wrongful conduct is

disclosed;

k. Failing to maintain or enforce proper procedures to prevent or minimalize the risk of
Wrongful Acts;

l. Failing to adjudicate complaints fairly, or at all;
m. Shunning complaints and complainants;

n. Penalizing complainants and/or rewarding those engaged in discrimination,
harassment, bullying and/or abuse of authority by, tor example, promoting the
wrongdoer, removing the complainant from the workplace, permitting the harasser to
remain in the workplace, often including in physical proximity to the complainant
and/or in a position of authority over the person(s) harassed, and ostracizing

complainants;

o. Protecting of deferring to employees who are more senior in the organizational

structure;
p. Failing to act honestiy, impartially-and responsibly;

q. Failing to carry out appropriate or any remedial action in relation to discrimination,

harassment, bullying and abuse of authority; and
r. Such other and further failures as may be proven at trial.
The above are collectively referred to as ?Defendants? Failures.?

The Defendants perpetuated a culture of discrimination, harassment, abuse of authority,
and buliying by its enabling behaviour, by its inaction and by its denial. They provided
leadership to the workforce showing that the wrongful conduct is acceptable and that

compiainants wilt be silenced.
Harms Suffered by Plaintiffs

The Wrongful Acts and Defendants? Failures have caused the Plaintiffs and other

employees to suffer:

a. Loss of reputation;

13. Loss of income and income opportunities, including but not limited to overtime,

pensions compensation, and promotions;
c. Anger, cynicism, depression, fear and humiliation;
d. Loss of morale, social isolation and maladjustment;

e. Feelings of incompetence, powerlessness, illness, fear of returning to

work;

Temporary or permanent incapacity requiring medical attention;

g. Stress, including post-traumatic stress;

h. Problems with interpersonal relationships;

i. Loss of confidence in self and others;

i. Rage, feeiings of 

k. Depression;

I. Work disruption;

m. Loss of self?esteem;

n. Feelings of degradation and discomfort;

0. afflictions; and

p. Such other and further harms as may be proven at triai.
The above are referred to as ?Emptoyee Harms.?



174. The Defendants are directly and vicariously liable for the Employee Harms arising from
the Wrongful Acts and Defendants? Failures carried out by Corrections directly and/or

through its agents and Union representatives.

175.

Duties

At all material times, the Defendants owed the Plaintiffs a duty to ensure that they could
work in a safe environment, free of discrimination, harassment, assault, bullying and

abuse of authority. Such duties include the obligations to:

a. Ensure a safe, discrimination-free work environment, promote health, safety and

weli~being and ensure adequate humane, financial, and material resources;

b. Uphold the values enshrined in the Canadian Charter of Rights and Freedoms (the
?Charter?) and protect Charter rights and rights contained within the Canadian
Human Rights Act, including equal treatment regardless of gender, race, religion,

sexual orientation, ethnicity, or age;

0. Establish, maintain, and follow adequate internal processes, guidelines and

regulations respecting discrimination, harassment, abuse of authority and bultying;

d. Educate, supervise and appropriately monitor and discipline 080 employees on

matters relating to discrimination, harassment, abuse of authority and bullying;
e. Use reasonable care to ensure the health and safety of the Plaintiffs;
f. Devetop, provide and maintain a safe work environment for employees;

g. investigate discrimination, harassment, abuse of authority and bullying when

complaints or made or circumstances warrant;

h. Address circumstances of discrimination, harassment, abuse of authority and
bullying, including by providing assistance and redress to the Ptaintiffs and

transparent and appropriate discipline to perpetrators;

i. Take all reasonable steps to prevent Wrongfui Acts, Defendants? Failures and

Employee Harms; and
j. Such other and further duties as may be proven at trial.

The above are referred to collectively as ?Defendants? Duties.?

176.

177.

178.

179.

180.

181.

Harassment

The conduct of the Defendants, and those within their respective organizations for whom
they are liable, was outrageous. It was intended to, and did, cause the Ptaintiffs
emotionai stress or was carried out with a recklessdisregard for whether it would cause
the employees to suffer from emotional stress. Each of the Plaintiffs did suffer severe or
extreme emotional distress, the proximate cause of which was the Wrongful Acts and
Defendants? Failures, for which the Defendants are directly and vicariously liable, jointiy

and severally.
Neg?gence

At all material times, the Defendants owed the Piaintiffs a duty of care to carry out those
obligation identified as Defendants? Duties. The Defendants breached their duty of care
by permitting the Plaintiffs to suffer the Wrongful Acts through the Defendants? Failures.
These breaches have resuited in the Employee Harms.

The Defendants and their management, representatives, and agents knew, or ought to
have known, that the Wrongfui Acts and Defendants? Failures described above were
occurring and were of a nature that would cause the Employee Hatms to the Plaintiffs

and others. The Plaintiffs are entitled to damages from the Defendants as a result.
Breach of the Charter

The Charter provides that every individual is equal before and under the law and has the
right to equal protection and equal benefit of the law without discrimination and, in
particular, without discrimination based on race, national or ethnic origin, colour, religion,

sex, age or mental or physical disability.

The Plaintiffs state that some or all of the Wrongful Acts perpetrated against them and
the Defendants? Failures were discriminatory, contrary to the protections outlined the
Charter, and constitute breaches of the Charter. The Plaintiffs state that these breaches

caused the Employee Harms. The Plaintiffs are entitled to damages as a result.
Vicarious Liability

The Defendants are directly and/or vicariously liable for the Wrongfui Acts committed by

employees and members of their respective organization against the Plaintiffs, and the

Defendants Failures, and are thUS liabie to pay damages for the Employee Harms that

have followed.

DAMAQES

182.

188.

184.

185.

The Plaintiffs have suffered at the hands of the Defendants, and they are entitled to
damages, including pecuniary and non~pecuniary general damages, special damages

and aggravated, exempiary and punitive damages.

As a consequence of the breaches set out above, the Plaintiffs have sustained and wiil
continue to sustain injuries as set out in the Empioyee Harms. in addition, the Plaintiffs
have lost wages, including overtime opportunities, promotional opportunities and future
income, and the corresponding pension income. They have also incurred medical, travel

and other health care costs. The Plaintiffs seek recovery of all these damages.
@reunds fer Punitive, Aggravated and Exempiary Damages

The Defendants knowingly failed the Plaintiffs. They had knowledge of widespread
discrimination, harassment, bullying sexual assault, and abuse of authority within, and it
faiied and refused to act in a timely way, or at all, to acknowledge the misconduct, forbid
or seek to limit or eradicate the misconduct, or take appropriate steps to relieve the

burden on the Plaintiffs and other victimized empioyees.

Despite their knowledge, the Defendants continued to permit the wrongful conduct and
took no steps, or in the alternative no reasonabie steps, to protect the Plaintiffs from
these abuses and harms. in the circumstances, the failure to ?act on that knowledge
amounts to a wilfui wanton and reckless disregard for the well?being of the Piaintiffs, and

renders punitive and aggravated damages both appropriate and necessary.

Remedy sought:

186.

187'.

188.

189.

 

A declaration that (380 owed and breached contractual, constitutional, statutory, and

common law duties to the Plaintiffs.
A declaration the CSC breached the Plaintiffs? Charter rights.
A declaration that (380 is iiable for its breaches of the said duties.

A declaration that 080 is vicariously liable for the torts of its employees.

     

 

190. A declaration that UCCO owed and breached contractual, statutory, and common law

duties to the Plaintiffs.
191. A declaration that UCCO is liable for its breaches of the said duties.
192. A declaration that UCCO is vicariously tiable for the torts of its members.
193. A declaration that the Defendants are jointlyand severally liable.

194. Non~pecuniary general damages for breaches of the duties described herein in the
amount of $25,000,000.

t95. Pecuniary damages for toss of income, promotional opportunities, promotions, overtime,
holiday and stat pay, educational opportunities, training opportunities, benefits, and

pension value in the amount of $12,000,000.
196. Damages for pain and suffering in the amount of $1,400,000.

197. Aggravated, exemplary, punitive damages, as well as damages arising from 324(1) of
the Charter, in the amount of $5,000,000.

198. Special damages including future and anticipated medicat, therapeutic, and out of pocket

expenses in an amount to be determined at trial.

199. An order that damages be paid by the Defendants into a common fund and distributed to

the Plaintiffs in a manner directed by the Court.
200. Prejudgment and post?judgment interest.
201. Any applicable taxes.
202. Costs of this action on a full-indemnity basis.
203. Such other and further relief as this Honourable Court deems just and appropriate.
VENUE
204. The Plaintiffs propose that this action be tried in Edmonton, Alberta.

APPLECABLE LEGESLATEGN

205. The Plaintiffs plead and rely upon the provisions of the following:

   

a. Crown Liability and Proceedings Act, R80 1985, (3-50;
b. Canadian Charter of Rights and Freedoms, R80 1985, 0 
0. Canadian Human Rights Act, R80 1985, and

Corrections and Conditional Release Act SC 1992, 20.

9-

CONCLUSION

206. 080 was established to contribute to the maintenance of a just, peacequ and safe
society. invoking this mandate, it has given itsetf a veii of secrecy, which managers,
senior employees and the Union have used to harass and intimidate employees, thus far
with immunity. Under this veit, the Plaintiffs have been harmed, with disastrous, life-

aitering consequences, and the Defendants utterly failed them.

 

NOTICE TO THE DEFENDANHS)

You only have a short time to do something to defend yourself against this claim:
20 days if you are served in Alberta

1 month if you are served outside Aibeita but in Canada

2 months it you are served outside Canada.

You can respond by filing a statement of defence or a demand for notice in the office of the clerk of the Court of
Queen?s Bench at Edmonton, Aiberta, AND serving your statement of defence or a demand for notice on the
plaintiff?s(s?) address for service,

WARNING

If you do not fiie and serve a statement of defence or a demand for notice within your time period, you risk tosing
the law suit automatically. if you do not file, or do not serve, or are late in doing either of these things, a court
may give a judgment to the piaintiff(s) against you.