Public Representative (Employees)
Judge, Vice President
Public Representative (Employers)
[1] A special contract for the plaintiff's employment dated January 17, 1990 was attached as Appendix A to the statement of defense.
[2] Paragraph 11 of the plaintiff's supplementary main testimony affidavit.
[3] Paragraph 19 of the plaintiff's summaries.
[4] See Appendix B to the statement of defense.
[5] The plaintiff's application was attached as Appendix 6A to the supplementary affidavit on her behalf (p. 1).
[6] The plaintiff's application was attached as Appendix 6A to the supplementary affidavit on her behalf (p. 2).
[7] Paragraph 28 of the affidavit of Dr. Rosen's main testimony.
[8] Section 31(c) of the statement of claim.
[9] An email correspondence from 2014 regarding the plaintiff's departure for an "environmental alert" course was attached as Appendix 6D to the plaintiff's supplementary affidavit.
[10] Paragraphs 58-59 of the plaintiff's supplementary affidavit.
[11] Paragraph 12 of Dr. Rosen's supplementary affidavit.
[12] Appendix 8 to the supplementary affidavit on behalf of the plaintiff.
[13] Appendix 8 to the supplementary affidavit on behalf of the plaintiff.
[14] Section 31(e) of the statement of claim. It should be noted that in the plaintiff's summaries, she no longer claims retroactive entitlement to the degree of stay, but rather that the defendant did not present to her the reasons for the retroactive entitlement to the degree of stay, and that only at a management meeting that took place in 2017 did it be claimed before her that the rank was given beyond the letter of the law, at personal risk to the chairman of the association (see paragraphs 135-142 of the plaintiff's summaries).
[15] Section 81 of the statement of defense, paragraph 106 of Dr. Rosen's affidavit of January 10, 2021.
[16] Paragraph 68 of the plaintiff's supplementary testimony affidavit.
[17] Appendix 9(b) to the supplementary affidavit on behalf of the plaintiff.