HE NUWAVUT COURT OF JUSTICE. BETWEEN: PM?!th SUWA Plain?ff - and- THE GOVERNMENT OF as represented by the DEPMTMENT OF Defendant NOTICE TO DE F. You are hereby noti?ed that the Plaintiff [or Plaintiffs) may enicrjudgment against you in accordance with the attached Statement of Claim, or such judgment as may be granted wider the Rule-.- ofthe Nmm?u: Cour! ofJuSIice, without no?cc to you Lmless within days a?or service of Slate-mom of Claim on you, unless you cause to be ?led in the oi?ee of the Clerk of the Nunavut Court of Justice either A Statement of Defence, or b. An Appearance 2. The mmehed Statement of Claim is to be sewed within 12 months from the day on which it is issued. .5. Every defendant should consult his or her lawyaur, or refer to the Rules ofrhe Nunavut Court afJu?ice, to deiem?ne his or her rights. The attached Statement of Claim is hereby issued out of the of?ce of the Clerk of the Nunavut ?a Court ofJustIee at 5h I H, Nunavut, on ?ame. 2mg .E??ggt In. I i ?H/a'i'img/ In?lerk of?a'c c" . I IN THE NUNAWT COURT OF JUSTICE PADMA SURAMAJA Plaintiff . and. THE 0F NUWAWT as rcpt: Seated by the DEPARTMENT OF JUSTICE Defendant STATEMENT OF CLAIM The Parties 1. The Plaintiff has, at all material times, been resident of the City of Iqaluit, in the 'l'cr?tory of Nunavut. 2. The: Defendant is the Employer, Employing the Department of Justice, Governth of Nummt. The Claim 3- The Phtin?clff, Fatima Summln, claims: a. A declaration that sht: Was wrongfully d?x?sscd 17mm hm- employment as Chief Comm: with the Depmcut ofjus?cc, Government of Nunavut on or about Ap?l 25, 2018; b. A dalmatian that the merit: which Defendant. suspended and terminated the Plaintist employment was in breach of that: duty of good. faith and fair dealing; 1?5. decimation that the Defendant bzeachcd the Plaintist cantact by: i. Failing tn comply with legislation, policies and rules; Intentionally in?icting mental suffc?ng on the Plaintiff; Conspin'ng and mongfu?y imetfcxing in the work of the Plaintiff prior to her termination. d. Damages f0: wrongqu pr: tennim?on conduct of in ?at: ant-tun: of $200,000 arising from harassment and intimation, the conspiracy and The Fags i1:te:fe:enee at" her work, neg?gmee negligent misrepresentation and the intentional or negligent infliction of mental suffering; e. Genexal and aggravated damages for the Plaintiffs and breach of duty of care and ?air dealings in the summit ef$400,300 representing 24 months' notice of the Plaineff?s employment-related compensation during ?nal] eerie-d plus aggsavateti damages; f. Damages for der?amalieu ami intentional M?icuon of mental in the sun: of g. Punitive audio: aggravated damages in the amount of 31503100; Special damages in an amount to be determined at trial; 1. Pee-judgment and post?judgment interest on thcs: amounts in accordaBCe with the j. Costs of this ac?on en a substantial indemnity basis, together with the applicable GET thereon; and Such further and other relief as counsel may advise and this Honourable Com deems just. The Plainuff enrezed into a contract of employment with the Defendant, Govemment of Nunavut, commencing on or around November 15, 2005. The Plaiuu'ff was 42 years old :11. this Lime She initially worked for the Government of Nunavut as :1 registczed for the Deparuneut of Hc?th Social Services in Cnmb?dge Bay, Nunavut. [n 2007, the Plain?ff was liansfeued by the Defendant to the Qikiqtani General Hospital in Iqaluit, NIL-user as. a. full?time indeterminate nurse. In 2003, in addition to he: duties as a Nurse at the Q?-Lith?i General Hospital, the le'ntiffwas also appointed as a Comma: by the Defendant. A5 11 coroner, he: clun'es were required on an sis-needed basis and she was paid fees for sen'ices rendered rather than a salary. In 2010, the Plaieri IT was approached by the Deputy ivlieiste: of the Deparuuent of Justice. Ms. Slaughter. and was asked to assume the duties of the Chief Coroner on an aetieg basis while rhe existing Chief Coroner recovered {rum illness. The Plaieljff agreed and was hired as a casual employee in the role oEAeliug Chief Coroner. In March 2011, the Plaintiff was hired as Chief Coroner on aunt-yea: term basis as the existing Chief Coroner was still on sick leave. This term was extended twice and in 2014 the Plaintiff 1teas appointed as the Chief Coroner for the Territory of Nunavut on a full? Iime; indeceunieate basis. ll. 12. 13. 14. The position of Chief Coroner is created by" statute, namely the R.S.N.W.T. 1933,c.C 20. The powers and duties of the Chief Coroner are set out in Section 5 of the CmsemAr: with the primary responsibility of the Chief Coroner being the administration of the its regulations. . the Chief Coroner reports to the Director of Com Bertie-es, who, in turn, reports to the Deputy Minister of the Department ofjustice. As set out in Section 2 of the Comrmx?in?, the Act is binding on the Gaitemmenr of Nunavut and its agents. The position of Chief Coroner requires a high degree of independence in order for tire Clonal-Coroner to ?ll?ll he: obligations under 7hr: The ACT itself does not esplicirly identify the scope of the independence of the Chief Coroner, but the/?rms a whole speaks to the neccssiry of the Chief Coroner?s role in identifying public safety issues and informing the public of those issues. Further, the Chief Coroner?s often target speci?c Government of Nunavut sntides and agencies to address these public safety issues. In respect, 3 high degree of independence and neutrality?r is required to maintain public con?dence that the actions of tile Cl?ef COmucr are not by virtue of being an employee of the Govcmmeot of Nunavut The Plaintiff through the course ofhcr employment with the Employer diligently,l followed the administrative direcan provided by the Deputy Minister ofjumicc and the Director of Court Sen-ices. The Plaintiff faithfully performed her duties on behalf of the and throughout her employment with the Defendant the Plaintiff proved herself to be a valuable and reliable employee. . The Defende exceeded its administrative authority and began to unduly in?uence and interfere with Lite smmrory responsibilities of the Cldef Coroner as early as 2015. As a direct result of this interference, the Plaintiff could nor suf?ciently perform her duties as Chief Coroner. . Injune 2011, there was a murder! suicide in Iqaluit, Nunavut 'L'hsr event dramatically illustrated the prevalence and seriousness of domestic violence in Nazism: and prompted Plaintiff as Chief Coroner to conduct a general review on the issue of domestic violence in Nunavut The Plaintiff arranged for the assistance oF the Of?ce of the Chief Coroner of Ontario to conduct the review and produce the report. As a product of that review, the Plaintiff prepared :1 public report pmsunul to Section of the Comm-rs An? that identi?ed ?fteen risk factors for intimate partner homicide-suicide. The report also made several recommendations to enhance risk assessment, safety planning and possibie prevention of Future deaths related to domesdc violence. 15. The Defendant, namely the Deputy Minktet William McKay, expressly 19prohibited the Chief Coroner from releasing the report Rather, he insisted that die Plaintiff only teleasc a benign emtdl statement that the Chief Coroner. was working with the Oemzio Coronet Service to prevent sheila: ddis in the Fume, while offering no speci?cs or recouunendaliotts that Would inform rhe public. Suhsequent he: dismissirl, .1 MLA tabled the report in the Nunavut Legislature, quesrions from orhe: legislators as to why the report was not released by the Chief Cetonet. The Plaintiff was unable to defend her position not did the Department oFJuslice deadly to the legislature that it was the Depuq' Ministe: ofjuseice who had pxohibited the release of the tepott. Similetly. in 2016 the Plaintiff conducted an inquest regarding the death of a young child who had been receiving medical treatment from the Department of Health. An issue. waged upon the announCmnent of the inquest as the child?s family sought an inquest to determine wrongdoing on part of the Depazmtent of Hme and the Chief Coronet was PIOllilJlIc-Ll by legislation, speci?cally &etinn of U1: Comma-34?, Ecru doing so. The resulting inquest and issues surrounding it peompted the Plaintiff to collaborate with the Chief Coroner of Ontario to audit Nunavut coroner?s of?ce and its operations to determine hes: practices. The Deputy Minister ofjustiee, William McKay, audios-ind the nudiL but rejected the ?ndings. in correspondence to the Plaintiff, Mr. McKay dismissed the audit report as being ?full of complaints". 'll-iis prevented the Plaintiff as Chief Coroner to adopt best practices that would have allowed her to perfonn her duties in a more ?lls-omit manner. The Deputy Miriam: ofjustice, Tirtlliain McKay, comm:th the Plaintiffupon receipt of the report and dismissed it, stating that ltwas jus: a series of complaints. At no time bemcen the production of the report and the dismissal of the Plaintiff were any,r of the issues raised in the report addressed by the. Defendant. In March 2017 there was a police-involved shooting death in Pond Inlet, Nunmrut. The Ottawa Police were assignod by the RCMP to investigate. Pursuant to Section the C?ef Coronet was obliged to Investigate the dead: was activer from attending the death scene by the Ottawa Police team- When the Phlintiffpezsistcd in her to ful?ll her duties as Chief Corouu to ('?nduct: an investigttion, the Grants. Police escalated the matte: and infomied the Depuejr Minute: ofjuslice William McKay of their objections to the Chief Coroner?s involvement. . Upon being informed of the situation, the Deputy Minisuet of_ ustiee, William McKay, took active steps in support of the Ottawa Police rad-let than support the Chief Coronet. This compromised the Plaintiff as Chief Coronet in her dealings with the Ottawa Police who prevented he: f:on1 informing the family of the deceased about the cause of death after the completion of the autopsy. 26. 29. 31. 32. 33. The Plaintiff, as Chief Coroner, had addressed this issue with the Defendant and the RCINTP in 2016 when legal counsel for the Chief Coroner, Sheldon. Toner, wrote Deputy Minister of justice William Eddie; and the Commanding Of?cer. of the RCMP and speci?cally requested that the};' not interfere with the Coroner?s death investigations involving police of?cers as doing so constituted an obstruction of the duties of the Chief Coroner as set out in Secrion of the CemnmAd. . In Dori-Julie: 20] the Plaintiff prepared a Coroner?s report pursuant to Section 19 of the Chitinch Ar! regarding the death of an employee of the Government of Nunavut. The Plaintiff the death and concluded that die individual committed suicide while on suspension from employment. The Plaintiff-produced 2 Hard Coroner?s Roportwith recommendations to the Department of Health and sent a copy of the report to the Deputy Ministet of justice, William McKay. 1 Upon receipt of the Coroner?s Report, Deputy Minister of Justice, William McKay expressed his opinion to the Plaintiff that the cause of death was accidental and he did not accept the Chief Coroner's ?nding that the cause of death was suicide. In the summer of 2017 the Plsin'dffinfonned Deputy Writer of Justice. William McKay, that she would be producing an annual report for the year 2012. The report had been delayed in its producan pending the completion of all dontll investigations from that year and the subsequent calculation ofdeath satis?es. The Plaintiff ?JIfher informed the Deputy h?rister that she wished to table the annual report for the May? Jurtc 2013 sitting of the . The Deputy l?nisler of Justice, William McKay, wrote the Plaintiff as Chief Coroner and oopicd several other: high ranking members of the Department of Health. He openly questioned the Plaintiffs decision to produce the report despite her express author-it}? to do so pursuant to Section of the Carmen/1d. The Plaintiff attempted to address the issue of continuing interference by the Deputy lt?nistcr of?lustioc by commissioning an audit of tin! Of?ce of the Chief Coroner. On Febniery 15. 201? the Plaintiff Sent :1 proposed agenda for a review of the functions of lire Of?ce of the Chief Coronet. The: preposal for the audit submitted by the Plaintiff was reviewed and approved by the Minister of jusu'ce, William McKay. Mr. Kent Stewart, a retired Chief Coroner from Saskatchewan, was commissioned to conduct fee audit. On Sept-unbri- 15, 201?, a report was submitted to the Deputy Minister William McKay, entitled ?5 Region Concerning the Nunavut Of?ce of the Chief Coroner". Authored by Mr. Kent Stewart the report noted as follows: a. Although the Sconce usually ?ts into an existing organizational structure with respeer ro administrative matters, senior managers and politicians should not unduly influence the coroner?s ?ndings including recorornendadoris as ourlinod in the Act; b. A sigm'?c?nt issue that is apparent is access to medical records. In most cases that the coroner invesrigites, this is critical information. 2'15 torch1 there should be eminent}r in the Commrr?n? to access and copy docummts without warren; c. {l?he Chief Coroner) is on call every day unless she em arrange coverage {administrative staff) and remarkably, she is the ?rst point of contact for nearly ail deaths that occur in Nunavut. Additionally, she takes coroner calls in iqnluit {average E20 to I40 each year} and also completes signi?cant numbers or" documents and reporn: that normally should he Completed by eommuni eoroners. This is an unusual feature given that roost jurisdictions maintain a network of coroner's ro assist the Chief Coroner. Thin practice has resulted in a very heavy and unsusuinahle workload for Ms. Suremala. 34. The second issue identi?ed in the report, merely the issue of access to medical records, 35. 37. 33. had been a source of ongoing tension between the Of?ce of the Chief Coroner, 1the Deputy Minister nit-justice and the of Health. The Plaintiff as Chief Coroner had tried to address the issue widt the Deputy Minister ofjustice by suggesting changes to pertinent legislation The audit itselfwas also an attempt by the Plaintiff to have the issue examined by a third party expert. its Chief Coroner, the Plaintiff was often involved in the inian stages of death investigations. By necessity, the investigative steps at that stage are very time sensitive the autopsy of the deceased moot he conducted soon after death. One of the necessary steps prior to conducting the autopsy is to: the Coroner to obtain a copy of the deceased's medical records. . The Depammt anenlth had informed the Chief Coroner that the Chief Coroner :nust foliow the Department of Health?s protocol that. imisted on the production of a warrant from ejustice of the Peace before the Chief Coroner could access the deceased?s edical records. The Plaintiff had sought it:ng advice from legal counsel to the Of?ce of the Chief Coronet, Sheldon Toner. Mt. Toner reviewltd the CommnAd and noted that while the Language did not fully capture the issue, the existing language supported the position of the Chief Coroner the: she ditl nor requir: a warrant from the Justice of the Peace to access a cop},r of the medical records. Dnjenuatj: ?12, ENE, Mr. Tom-J; on behalf-of the Chief Coroner, communicated this interpretation to the Deputy liim?ster ofjurtice. William McKay, and the. Deputy Minister of the Department of Health, Colleen 39. The Depot-mom ofj'nsnice and the Department of Health continued to disagree with the Chief Coroner?s interpretation and application of the Cement/dc: on this issue. On February 6, 2013, upon the direction of the Plaintiff, Mr. Toner propoend to meet with represenmtives From lite Department ofjusliee and the Department oFHenith to resolve the outstanding lasuen regarding access to medical. records. 40. Onjsnimry 3D, 2018, the PlaintifFes Chief Coroner issued a Coroner?s Authorization, without a concomitant men: from 2 Justine of the Pea cc, to the Nurse-in-Charge at the Health Centre in Qikiqtrnusq, Nunavut for the release of 2. copy of medical information of an individual who had died suddenly in that community. The Chief Coroner requested the information on the reasonable and prolmble grounds that she would need :1 copy of malical documentation of nursing and physician notes of Ike deceased's illness visits and, in gardculer, any hifonnatlon relating to blood work and EKG results, to assist her in the linker denomination of the circumstances surround the death and to determine the risk factors associated in the death investigation. 41. With respect to the dais-d issue raised in Mr. Stewart's report. the Defendant had long been aware of the unsustainable nature of the Plaintiffs won; responsibilities and the. effects it was lmving on her health. 4-2. 0:1 or about August 20, 2011, the Plaintiff investigated a crash of a First Air aircraft in Resolute, Nunavut . The crash had resulted in multiple casualties and the. Plaintiff was responsible for the grisly task of collec?ng hurl}- pans [mm Lhe crash site and idmti?-ing the deceased at the autopsy. 43. As a result of the: experience, the Plaintiff was ?isgnosed with Post 'l'rauroatic Stress Disorder. The Defendant was made aware of the diagnosis and approved for the Plaintiff to take 39 clays' special leave. 44. Desgire the diagnosis and Defendant's axmmess thereof, the Plaintist work responsibilities were never adjusted by the Defendant and she continued to perfonn all of her duties throughnur her employment with the Defendant. 45. ?thn rlu: Plaintiff made efforts to this issue by seeking the, appointment of a Deputy Coroner, the Defmdant, namely Depot}r Minister ofjusn'ee William McKay, deliberately rescinded the Plaintiff from the hin'ng procws, contrary to he: express powers as Chief Coroner as set out in Section of the (Imam-Arr. 46. On February 5, 2013 the Plaintiff received a letter from Mr. Elicia? entitled ?Re: Suspension Pending Investigation?. The letter informed the Plaintiff the: she was being placed on suspension with Pay pending investigation into the allegations of mismnducf. No particulars were Provided in the letter Concerning the nature of the allegations. Despite the clear allegation of n?seonduct, Mr. McKay went on to 'W'I'lt'c that the suspension was in nature". After receiving the suspension loner, the Plaintiff retained legal counsel to assist her in her response to suspension. Counsel for the Plaintiff, Ms. Gillian Bourke. wrote 10 Deguqr Minister, William McKay, on February 9, 231.3 and requesred an overview of the allegations, including any supPorting documentation. 4'8. 49. 51. 52. On February 13, 2018, the Plaintiff received an email from Debbie Kamino, Employee Relations Consultant. and Governman of Nunavut. She stated that had received a copy of the correspondence from M5. Bowl-to. Ms. Knmino expressly stated that the suspension process was and that he: of?cc does not engage with legal counsel during the investigation. She went furt?am to state that the process docs not allow for the: attendance of legal counsel at the ?Fact Finding? meeting. Ms. correspondence on February 13, 2013 was the ?rs: instance where the Defendant Provided. the Plaintiff with particulars of her alleged misconduct. The}; consisted of two issues: Payments to the Plaintiff from outside employment with $3 YWCA. Agvvik Society in Iqaluit, Nunavut; and b. That Plaintiff?s of?ce was obtaining hospital records without a. warrant. With res-pcct to tho ?rst allegation, the Plaintiff had consistently disclosed to the Defendant her Lm'olvemmt with the YWCA Agvvilt Society and moznittcd the rcquisitc authorization [onus to he: administrative supervisors throughout hm: involvement. \?'hilc the Plaintiff was on suspension, the Defendant raised allegations of misconduct surrounding the imnngement of the Coroners and their respective computation. Deputy Minister of Jugticc, William McKay, misled these allegations with the supervisor, the Director of Court Services, who responded with an explanation that clearly indicated that the Plaintiff was no: at fault. At no time pcior to the termination was the Plaintiff made aware of allegations no: nos 5hr: gin-n an opportuan to realmnd to them On rel}ch 14, EDIE, Silk, DireCtor, Legal and Constitutional Law wrote to Me. Bourkc informing her. that the Plaintiff did nor 11:11": ?ne tight to be accompanied by legal counsel when being intendewcti and that Employee Relations would deal directly with the Plaintiff, dcspite Ms. Bouckc?s request to have the matth dcalt with through counsel. She stated further that ?we do not on notice role for legal counsel at this stage?. . Noti?cation of the Plain?ffs suspension was copied to several executives within the of Nunavut, including the Director who should not have been privy to that informmion. . During the. Plain?ff's suspension, the denied hot access to he: Government of N1111th email account. This Prevented the Plaintiff from attessing that would allow her to resound to the allegations. UI Ln 58. . The Defendant enlisted legal counsel to the ?Fact Ending? investigaer The was denied my representation, despite the fact that the allegations of misconduct were of suf?cient senousness as to support 1 decision to tenninnte he: C?lyl?fl'l'l??t. . Fur-diet. the Plaintiff was denied an opportunity to provide a fulsome response to the allegations during the ?Fact Finding? investigation, partimdzuly with respeet to the Defendant?s: denial of he: access to documents would the supported her position. . On April 25, 2013, the Defendant tenninated the Plainst employment. In :1 letter to :11: Plaintiff from ?lm: Power. the Associate Deputy Minister of l-luman Resources. the Defendant ill-a?eld the termination upon its diet the. Plaintiff had breached the Govemrneat of Nunavut?s poliq' regarding outside activity and that she as Chief Coroner had not followed the. direction of he: "supmrisors? :egatdlug the obedniog of a wamnt to access copies of medical records. The Defendant failed to afford the Plaintiff due process pursuant to the Government of Nunavut?s disciplinary policy {as oudlnedin Section 3'01 and 803 of the Human Resume: Manual}, including but not limited to the following a. The manager, namely Deputy Minister William did not infon?n the. Plaintiff prior to her rumination that she was not meeting the reindede of general and/01: particular conduct as Chief Coronet; b. The Deputy h?nistei: of justice, William McKay, did not meet with the Plaintiff palm: to her tenninarinn to i. Ensure the Pleimiffwas aware of the problem; ii. Pee-quit the Plaintiff a cop}r of the intcmel invesligadon report; Give the l?lajnti?': an opportunity to eitpluin the. circumstances surrounding the unsatisfactory or breach of conduu; Deteu'nine if the Plaintiffs anions were tuneful},r the result of misunderstanding direclions, or if the employee will?illy broke the rules of conduct; and v. Explain to the Plaintiff that the alleged offence may result in dismissal. iv. The Depuqr h?nister did not consider the Plaintiff's length of service,I p331: record, Senousness of the offence and all Other pertinent facts before recommending her dismissal; d. The Defendant did not apply any progressive discipline prior to the Plaintist dismissal; 10 c. 'llic Defundant, namely the Assoriatr Drputy Minister of Human Resources. terminated the Plaintiff's employment ?dd-taut providing the Plaintiff a written notice ofthc for and an tor the Plaintiff to make a written submission on her behalf be considered in the: ?nal analysis; and f. Th3 Defendant denied the Plaintiff legal representation throughout the process despite the fact Lhat the Defendant was intending to terminate the Plainl'i?'s employment. 59. 315 a result of the Defendants wrongful conduct, the. Plaintiff has expc?ertced severe mat}; depression, social isolation, insomnia, humiliation, Erma-adore, aggravation, the erosion of her self?catccm and con?dmice. Her normal and comfort DIP ht: family life and friendships at: severely impaired. This has msulted in medical care which was triggmd as a direct 1:51:11 of the Stress from the arr-awful conduct Ufth: Defendant. 60. All of the abet: damages rcpment losses that the Defendant 1mer or ought to have known would ?ow from its cmduct and the conduct of its duployecs and agents as plead in this herein Claim. The. Plaintiff states that that: existed a. special relationship, proximate, such as to give. $156. to a reasonable duty of cart: on behalf of th: Defendant not to adversely harm this. Plaintiff, both throughout and following the employment relationship. 61. The Defendant terminath the Plaintiff?s Etnployment in branch of their duty ofgood Faith and fair darling. 62. Th: Defendant Further breachad their duty of :3ch as the employer of the Plaintij in the circumstances set out in this Claim. 63. Thu: Plaintiff further claims that the egregious, wrongful conduct of du?ng the Course of the Flamti?ls employment and at the. lime of he: Lcnnina?ot'. durum-es an award for punitive damages. The Defendant?s conducr as set Dutiu this of Claim was unfair, malitious, unlawEuL arbitrary and callous. 64. The Plaintiff states that in the course of seekhtg she has incurred expenses, the full particulars of which the Plaintiff undertakes to previdc the Defendant prior to trial. 65? The Plaintiff proposes that this scum: be tried the Hung-mt Court ijus?ce in Iqaluit, Nunasut. DATED at the City of Vicron'a, in the Province of B??sh Colombia [his 13th dag; ofjune, 2018 and DELIVERED by Michael H. Penna-1 Barrister and Solicimr, 2-175 Kaila St., PO Bea: 1 I052 Iqaluit, Nunavut, solicitor for the whose address for Service is in cm: of her said Solicitor, B?chael H. PEG?ner- Micggd H. ?cnner Solicitor for he Plaimiff of the ef?ee of the Clerk of the Nunavut Count ofjusdcc at the City of Iqaluit, Nunavut, on hits 2018. r" (251' - acu- i {?g-I1 5/319,? ?ff 3? 3; A Whit-:1; of the NImavut 3? i TO: Clerk of Nunavut Court ofjusdoAdrienne 311K, Legal Launsd For the Government of humvut $31; - I, r. ?95 013-1 gt a? c?i: P1112018 IN THE NLNAVIJI COURT OF JUSTICE "Plainti IT -and.. THE GOVERWENT OF NUNAVUT as represented by the OF Defandant NOTICE TO and STATENIENT OF CLAIM Michael H. Barrister 3: Solicitor PO Box 11032, 2475 Kaila St? Iqaluit, Nunavut XUA Telephone: 383-979-5777 Fax: Law Sncim?y ofNunnvm. Mamba: #2002022