The document is a final case book summarizing Shawn Brightly's termination grievance case. It includes a grievance letter, management response, timeline of events, witness list, agreed statement of facts, relevant law, and arguments. Shawn was terminated for fraud and dishonesty for claiming paid sick leave while participating in a curling tournament. The union grieved the termination. Key evidence shows Shawn participating in the tournament during his claimed sick period.

1. Final Case Book
Shawn Brightly Termination Case
HRMT 5190 A50: Labour and Employee Relations
Submitted By:
Marjorie Favor
Marina Ferreira
Nisha Thompson
Carla Stumpf
Submitted to:
Mr. Ian Kato
July 4, 2023

2. 2
Table of Contents
Marking Guide 3
Grievance Letter 4
Grievance Reply – Management Response 5
Theory Of The Case 7
Timeline Of Events 9
Evidence Documents 10
Witness List 13
Agreed Statement Of Facts 15
Law 17
Argument 27
Remedy 32
Bamos 32
Appendix 33

3. 3
Marking Guide

4. 4
Grievance Letter
June 2, 2023
Re: Grievance of Shawn Brightly
We grieve on behalf of Shawn #112385 who was terminated on November 09 for
being dishonest with Associated Warehouse (AW) with immediate effect. Shawn has
almost 28 years of seniority with the company and has a clean work record with no
discipline in the past. He has been Chief Shop Steward for many years.
According to Wm. Scott & Co. Ltd. there is no just cause for the imposed discipline
and the penalty is highly excessive. There is no solid evidence which proves that
Shawn was dishonest with the company. Shawn is a hardworking employee who has
been working for a long time with the company. There is no cause in this case. We
demand that there should be no discipline against Shawn, and he must receive a full
reinstatement with back pay.
We look forward to your early response to this important matter.
Sincerely,
Union Shop Steward

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Grievance Reply – Management Response
June 4, 2023
Re: Grievance of Shawn Brightly | Grievance File No. 444-2023
Dear Ms. Kaur,
I am writing in reply to your grievance on June 2, 2023. Unfortunately, after careful
consideration, we have decided to dismiss this grievance and firmly stand by our
decision to terminate his employment.
The decision to terminate Shawn's employment was made after careful consideration
of the evidence, which suggested fraudulent behaviour and dishonesty on Shawn's
part. The principles of the Wm. Scott case law is applicable as we deem the decision
to be just, reasonable, and appropriate in this situation.
The following are the key points impacting our decision:
• It was discovered that Shawn claimed sick leave for a week in October, during
which he was reportedly incapacitated due to a back injury, however
subsequent information from public social media confirmed that Shawn had
participated in a curling bonspiel in Alberta during the same period.
• We conducted a thorough investigation into the matter, during which Shawn
denied any involvement in curling activities and maintained that his back injury
prevented him from performing his duties.

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We carefully considered the nature of the allegations, the evidence, and the potential
impact on the employees and the organization. We concluded that Shawn made
misrepresentations and committed fraud by claiming sick leave pay under false
pretenses.
We firmly believe that honesty is a fundamental attribute expected of all employees,
especially one who has been the Chief Union Delegate for several years. Shawn's
actions indicate a breach of trust and a serious violation of company policies and
have been treated accordingly.
Sincerely,
General Manager
Associated Warehouses (AW)

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Theory of the Case
Type of Case
This case is disciplinary in nature and was brought about because it was alleged that
Shawn defrauded the company by receiving paid sick benefits for a period that he was
not sick. The situation was further compounded by the fact that his managers had
strong reason to believe that he lied about the real cause of his absence. Shawn was
therefore terminated for allowing himself to be paid sick leave when he was not actually
sick (fraud) and lying about the situation when being confronted twice (dishonesty
leading to a loss of trust).
Case Overview
Shawn’s tenure is almost 28 years with a clean record, and he was Chief Shop Steward
for several years. His job is highly physical in nature. He only identified vacation dates
for 2 of the 5 weeks that he is entitled to. Shawn’s vacation leave application for
October 26 - 30 was denied and he was paid sick leave for the same week. This is
coincidentally the same week of the tournament in Alberta. His managers confirmed his
participation in the event through the sport website and he lied when asked directly if he
had been curling. He was terminated effective immediately for fraud and dishonesty.
Argument and Ideal Outcome
In response to the denial of vacation, Shawn acted with fraud and dishonesty,
simulating muscle injury to obtain a paid sick leave and participate in the sporting event
without prejudice to his remuneration. The employee had the opportunity to confess that

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he participated in the Curling tournament. However, he chose to insist on dishonesty,
making it impossible to maintain the employment due to loss of trust.
The decision to terminate should stand because Shawn defrauded the system by
getting a doctor’s note because his vacation leave application was denied. This also
means that he misled his doctor about the true condition of his health, otherwise, he
would not have been granted the time to “rest his back”. The fact that the doctor said he
should try to do some walking further confirms this fact. Also, leniency in the matter can
no longer be considered because he lied when approached two times by his superiors.
This outcome must be maintained for precedence to be set. The ideal outcome is for the
grievance to be dismissed.
Law
The Wm. Scott case law is applicable in this situation because it is disciplinary in nature.
It creates guidelines that can be used when it comes to discipline and termination by
posing 3 questions. These questions help us decide if the disciplinary action is justified
– 1) Has the employee given just and reasonable cause for some form of discipline by
the employer? 2) If the answer is yes, was the employer's decision to dismiss the
employee an excessive response in all the circumstances of the case? 3) if the
arbitrator does consider discharge excessive, what alternative measure should be
substituted as just and equitable?
Remedy
We request that you should deny Shawn Brightly’s grievance.

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Timeline of Events

10. 10
Evidence Documents
The Evidence Documents are located and can be found on the Appendix page.
Timeline of Events and Evidence List
Date: Event: Evidence: Exhibit:
January 4, 2022 Shawn selected the last two
weeks of August as his
vacation date.
August 8, 2022 Shawn requested vacation
for the week of October
26th–30th, but it was
denied. At that time, Shawn
already had the Western
Canada curling event
schedule published in May.
October 24, 2022 Shaw visited the doctor,
explaining that he injured his
back while taking out the
garbage. The doctor
determined he was unable
to work and issued a note
advising him to stay home.
October 26-30, 2022 Shawn took paid sick leave
during the same period as
the tournament.
October 30, 2022 The event organizing
company posted an
Instagram photo of the
winners, clearly showing
Shawn holding the trophy.
Plus, social media post on
the association’s official
Instagram page.
Instagram Post of
the Winners from
Western Canada
Curling Events
Official Instagram
Account
Exhibit C
October 31, 2022 A newspaper article was
published featuring a photo
of Shawn playing in the lead
Newspaper Article
about Shawn
Brightly and his
curling team winning
Exhibit B

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shot position in the curling
bonspiel.
in the curling
tournament
November 2, 2022 Shawn returns to work and
informs his supervisor that
his back is now fine.
November 6, 2022 HR Manager Jasmine Brar
received an anonymous
letter with a printout of the
tournament website listing
Shawn Brightly Foursome
among the winners.
Jasmine verified Shawn's
name on the official event
website and questioned him
about his involvement, to
which Shawn denied any
participation. Jasmine
discussed the matter with
General Manager Rachel
Smith.
Official Website of
Western Canada
Curling Events
Team Winners for
2022 Tournament.
Associated
Warehouses
Communication Log
Exhibit A
Exhibit E
November 7, 2022 Rachel talks to Shawn
directly and informs him that
someone reported him for
curling when he should have
been injured. Shawn denies
it once again. Rachel and
Jasmine decide to gather
more evidence.
Associated
Warehouses
Communication Log
Exhibit E
November 8, 2022 Rachel and Jasmine review
the situation and analyze all
the evidence, including a
review of the employee
illness log and company
records such as company
ID. They also consider the
details of Jasmine's
conversation with Shawn's
friend, a curling teammate,
who participated in the
same tournament. As part of
the investigation, a
Shawn Brightly
Work ID
Employee Illness
Log
Affidavit of Kevin
Roberts (Shawn’s
Teammate)
Affidavit of license
Medical Sport
Exhibit D
Exhibit H
Exhibit F

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conversation from
doctor/Sport Specialist
about the correlation
between back pain and
curling.
Affidavit of Doctor
Rebecca Turner
Exhibit G
November 9, 2022 Shawn was called to a
disciplinary meeting and
asked to bring a shop
steward. Rachel informed
Shawn that he was
terminated immediately for
fraud and dishonesty. Later
that day, the union filed a
complaint on Shawn's
behalf.
Code of Conduct
Addendum to the
Collective
Bargaining
Agreement Articles
25-27
Exhibit I
Exhibit J
November 19, 2022 The field investigator
communicated with the
Tournament Organizer of
Western Canada Curling
events. The tournament
organizer confirmed
Shawn’s participation in the
curling tournament, sent the
website link and the prizes
section detailing tournament
winners from the last three
years, with Shawn being the
MVP in those years. and
provided details about
Shawn’s agreement with the
curling tournament.
Email conversation
of the field
investigator and
Tournament
Organizer
Affidavit of the
Tournament
Organizer
Curling Website
Winners in 2020
and 2021.
Curling Tournament
Participation
Contract
Exhibit K
Exhibit L
Exhibit M
Exhibit N
June 2, 2023 Grievance Letter from the
Union
June 4, 2023 Grievance Reply from the
Management
June 6, 2023 Grievance Meeting was held
between the Union and
Management

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Witness List
Witness 1: Kevin Roberts
Position: Teammate of Shawn Brightly in Shawn Brightly Foursome
Contact Info: kevinroberts@gmail.com; (778) 962-6745
Role in the matter: To testify that Shawn participated in the curling tournament and
was his teammate.
Questions:
1. Can you confirm that you were Shawn Brightly's teammate in the curling
tournament?
2. How long have you known Shawn and how would you describe his dedication to
curling?
3. Did Shawn mention anything about his back injury or pain during the
tournament?
4. Can you provide any evidence or additional witnesses who can support Shawn's
participation in the tournament?
Witness 2: Rebecca Turner
Position: Medical Sports Doctor
Contact Info: drrebeccaturner@surreyhospital.ca; (604) 872-6287
Role in the matter: To affirm that participating in curling while experiencing significant
back pain is not advisable.
Questions:
1. As a medical sports doctor, can you explain the physical demands of curling and
how they may impact someone with a back injury?
2. In your professional opinion, would it be feasible for someone with significant
back pain to actively participate in a curling tournament?

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3. Are there any precautions or restrictions you typically recommend for individuals
with back injuries when it comes to physical activities like curling?
4. Is there any evidence or medical records that can confirm Shawn's back injury
during the specified period?
Witness 3: Nicole Davidson
Position: Curling Tournament Organizer
Contact Info: nicole.davidson@westerncanadacurling.ca; (403) 268-2489
Role in the matter: To confirm Shawn’s attendance in the curling tournaments from
2020, 2021 and 2022; and to testify about Shawn’s long-time relationship and
association with the Western Canada Curling tournament.
Questions:
1. Can you confirm that Shawn participated in the curling tournaments in 2020,
2021, and 2022?
2. Are there any records or documents that can support Shawn's consistent
participation in these tournaments?
3. Did you have any direct interactions with Shawn during these tournaments that
could shed light on his dedication and commitment?
4. Can you explain the association between Shawn and the Western Canada
Curling tournament and provide any additional information that might be relevant
to the case?

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Agreed Statement of Facts
• Shawn has been a long-term employee for 28 years and a Chief Shop Steward
with his union for several years.
• He is a Lift Truck Driver.
• His performance appraisals note that “Shawn is a reliable and efficient worker
who is well-liked by the customers and co-workers”.
• Shawn requested a vacation leave for the week of October 26 – 30 but was
denied.
• In the last five years, Shawn has had 16 sick leave claims. None of these was for
a serious illness or injury and were all fewer than 3 days in duration. Usually
described as “cold” or “flu.”
• Shawn received paid sick leave from the company for October 26 – 30.
• Shawn is entitled to 5 weeks of vacation as a long-service employee.
• The propane tank weighs about 25 kilograms and Shawn must lift the empty one-
off and load the full one on.
• On Nov 2, Shawn returned to work and resumed his normal duties stating that
his back was okay now.
• Shawn is a serious curler.
• On November 6 the HR Manager Jasmine Brar found an unsigned letter shoved
under her door that stated that Shawn had not been sick the previous week but
instead have been playing in a curling bonspiel in Alberta.
• The company gave Shawn the opportunity to say if he had participated in a
curling tournament from October 26-30, but he denied participation in the curling
tournament twice.
• On November 9, Shawn was terminated effective immediately for fraud and
dishonesty.

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• Later that day the shop steward submitted a grievance on behalf of Shawn
saying there was no cause and further that if there was “some measure of cause”
then the penalty was excessive.
Management Team Signatures:
Marjorie Favor
Marina Ferreira
Nisha Thompson
Carla Stumpf
Union Team Signatures:
Jasmeen Kaur
Inderpreet Kaur
Harjap Kaur
Kamalpreet Singh

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Law
Collective Bargaining Agreement
Between
Associated Warehouses
And
Warehouse Union Members Association (WUMA
Addendum to the Collective Bargaining Agreement Article 25-27
This article, hereby incorporated into the collective bargaining agreement between the
Warehouse Union Members Association (WUMA) (hereinafter referred to as the
"Union") and Associated Warehouses (AW) (hereinafter referred to as the
"Company"), addresses the issues of fraud, dishonesty, and willful abuse of sick leave
privileges. Both parties recognize the importance of maintaining a workplace
environment based on trust, integrity, and accountability.
Article 25 Fraud and Dishonesty
Section 1. Fraud and dishonesty in any form, including but not limited to dishonesty,
fraud, theft, misappropriation of funds, embezzlement, falsification of records, or any
other deceptive practices, are strictly prohibited within the Company.
Section 2. Any employee found to have engaged in fraudulent or dishonest activities
shall be subject to disciplinary action, up to and including immediate termination, as
per the Company's policies and procedures.
Article 26 Willful Abuse of Sick Leave Privileges
Section 1. Sick leave is a benefit provided to employees for genuine illness or injury,
as well as for medical appointments and related reasons.

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Section 2. Willful abuse of sick leave privileges, such as falsely claiming illness,
forging medical documentation, or engaging in activities inconsistent with the claimed
illness, is strictly prohibited.
Section 3. Any employee found to have willfully abused sick leave privileges may face
disciplinary action, up to and including termination, as per the Company's policies and
procedures.
Section 4. The employer reserves the right to discharge any employee, without notice,
for any of the following causes: 1) dishonesty or fraud, 2) willful abuse of sick leave
privileges”. It is clear under this Collective Bargaining Agreement, dishonesty and
abuse of sick leave privileges have been designated as disciplinable offences that if
proven, will allow the employer to terminate the employee immediately without notice.
Article 27 Chief Shop Steward Position
Section 1. The Chief Shop Steward is a position of high responsibility within the
Union, entrusted with representing and advocating for the rights and interests of the
union members.
Section 2. The Chief Shop Steward, by virtue of their position, is expected to uphold
the highest standards of honesty, integrity, and ethical conduct in the workplace.
Section 3. The Chief Shop Steward cannot claim ignorance of the significance of
honest behaviour in the workplace, as they hold a position that emphasizes the
importance of such behaviour.
Section 4. Holding the esteemed position of Chief Shop Steward confers a significant
amount of authority and responsibility, requiring the individual to serve as a role
model for other employees.

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Case Law
Wm. Scott & Company Ltd., Employer, and
Canadian Food and Allied Workers Union, Local P-162, Union
[1976] B.C.L.R.B.D. No. 98
BCLRB Decision No. 46/76
British Columbia Labour Relations Board
P.C. Weiler, Chair, C.J. Alcott and A. Macdonald, Members
Heard: June 11, 1976.
Decision: July 26, 1976.
The historical case of Wm. Scott & Co. Ltd. represents a milestone in Canadian law,
specifically addressing disciplinary and termination issues in unionized workplaces.
The case arose from a request for reconsideration filed by the Canadian Food &
Allied Workers Union involving the dismissal of Margaret Martelli from a chicken
processing plant in Coquitlam, British Columbia. The arbitrator initially upheld the
termination, prompting the union to seek reconsideration from the newly created
Labor Relations Board. Notably, the decision introduced a simplified test comprising
three essential questions for referees to assess in discipline and dismissal cases.
According to Section 13 Page 9, it states that “Instead, arbitrators should pose three
distinct questions in the typical discharge grievance”.
First, has the employee given just and reasonable cause for some form of
discipline by the employer?
If so, was the employer's decision to dismiss the employee an excessive
response in all of the circumstances of the case?
Finally, if the arbitrator does consider discharge excessive, what alternative
measure should be substituted as just and equitable?

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Case Citations
The full copies of the cases are found in separate PDFs in the attachments.
Case No. 1
2006 CarswellBC 3331
British Columbia Arbitration
Agrifoods International Cooperative Ltd. v. Teamsters, Local 464
2006 CarswellBC 3331, [2006] B.C.C.A.A.A. No. 144, [2007] B.C.W.L.D. 2032, [2007]
B.C.W.L.D. 2033, [2007] B.C.W.L.D. 2034, 154 L.A.C. (4th) 77, 87 C.L.A.S. 136
In the Matter of an Arbitration between Agrifoods International Cooperative Ltd.,
("the Employer") and Teamsters Local Union No. 464, ("the Union")
J.P. Sanderson Member
Heard: June 5-26, 2006
Judgment: August 10, 2006
Docket: X-014/06(a)
Counsel: V.R. (Sam) Black, for Union
Bruce M. Greyell, for Employer
Subject: Occupational Health and Safety; Labour; Public
Mr. Chair, I would like to draw your attention to this leading case which is disciplinary
in nature. The grievor is a Farm Pick-up Driver with almost 18 years tenure and no
previous disciplinary issues, was terminated on the grounds of dishonesty. The
grievor claims to have suffered a strain to his left shoulder because of work activities
and not racing and working on his car. The grievor did not want to explain what he
was doing with respect to his racing activities because he knew it would adversely
affect his claim and his right to receive benefits. The employer alleges that the grievor
was dishonest and misled both the Workers’ compensation Board and the employer.
The grievor was chief shop steward and a member of the negotiating committee.

21. 21
Decision: The arbitrator decided to dismiss the case because the grievor was guilty
of dishonest and deceitful behaviour as alleged by the employer. It was further found
that discharge was not an excessive disciplinary response in the circumstances.
Explain the Law: I would like to highlight the following paragraphs in the Agrifoods
International Cooperative Ltd. v. Teamsters, Local 464 case:
• Para 47 in the Weyerhaeuser Canada Co. case (supra), Arbitrator Chertkow
stated at para 93 "it is trite law to say that honesty in deals between an
employee and an employer forms the underpinning of a viable
employment relationship".
• Para 47 section 94, in a case cited by counsel for the company, Simon Fraser
University and Canadian Union of Public Employees, Local 3338 (Diane Fraser
Grievance) dated May 28th, 1992 (unreported) Arbitrator Donald R. Munroe,
Q.C. commented at pages 21 and 22; the arbitrator stated that “an employee
who deliberately makes a false claim is guilty of a serious breach of trust
— not only as against the employer but also as against her working
colleagues. It is impractical to suggest that employers ought to be tightly
policing and second-guessing the applications by their employees for
sick leave or LTD benefits.” Moreover, any such suggestion would be
inconsistent with the aims and underpinnings of the modern employment
relationship. “What is required by everyone concerned is a reasonable and
appropriate level of mutual trust, and an attitude of voluntary
compliance.”
• Para 48 In the Canada Safeway Ltd. case (supra) the arbitrator stated at
paragraph 34 "In my view, a measure of trust between employers and their
employees is an essential lubricant that is required to enable

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employment machinery in any workplace to function properly for their
mutual benefit".
• Para 49 … at paragraphs 98 and 99, Arbitrator Chertkow said as follows, in
those circumstances, arbitrators are guided by the principles enunciated by the
late Mr. Justice O'Halloran of the British Columbia Court of Appeal in his oft-
quoted decision in Faryna v. Chorny, [1951] 2 D.L.R. 354 at page 357 where
he said; “The credibility of interested witnesses, particularly in cases of
conflict of evidence, cannot be gauged solely by the test of whether the
personal demeanour of the particular witness carried conviction of the
truth. The test must reasonably subject his story to an examination of its
consistency with the probabilities that surround the currently existing
conditions.
• Para 50 The arbitrator further stated "with reference to your activities
while off work... and with reference to your injury and your inability to
work. It is my conclusion the evidence of the grievor is not to be believed
and his story is not in harmony with the preponderance of the
probabilities which a practical and informed person would readily
recognize as reasonable in that place and in those conditions".
In this case the arbitrator used case law to emphasize the importance of mutual trust
and willing compliance to policies and procedures. She highlights the impracticality of
employers strictly monitoring sick leave and other benefits to ensure employee
compliance.
Similarities: Mr. Chair, this case is like ours in the following ways. Both occurred in
the same province (British Columbia). The grievor was a chief shop steward for a long
time, with a clean record and seniority in employment. He fraudulently simulated
painful symptoms and obtained WCB benefits while participating in racing events.

23. 23
Grievor had several opportunities to confess the fact during the investigation process
but did not and the evidence published in social media. Then the reason this case is
important to our case is that the grievor had a clean record, has more than 18
seniority and has been chief shop steward for long time like the Shawn Brightly case.
Grievor used the same premeditated strategy as in Shawn’s case, that is, using
fraudulent symptoms to obtain a medical license to participate in sports activities (a
hobby). The fact was confirmed by social media, the same type of evidence in the
Shawn Brightly case. Grievor in a similar case was also given the opportunity to own
up to the lie, or show regret, but on two occasions he too refused to do so. The same
applies, as Shawn also lied, showed no remorse, and made no apology. The
arbitrator's reasoning is the same thesis presented by the employer that the breach of
trust and malicious dishonesty are serious causes that justify the termination of the
employment relationship, even if it occurred only once.
Principle: Mr. Chair, the reason this case is important is that arbitrator used case law
to emphasize the importance of mutual trust and willing compliance to policies and
procedures. She highlighted the impracticality of employers strictly monitoring sick
leave and other benefits to ensure employee compliance. It highlights the severity of
dishonesty as an employment offence. The case demonstrates that acts of dishonesty
and it stands for the principle that even when committed by long-term employees with
no prior disciplinary actions, can result in termination.

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Case No. 2
2021 CarswellBC 1079
British Columbia Arbitration
Insurance Corp. of British Columbia and Moveup (COPE, Local 378) (Mundy),
Re
2021 CarswellBC 1079, [2021] B.C.C.A.A.A. No. 57, 148 C.L.A.S. 152
IN THE MATTER OF: A grievance filed on behalf of Rhianna Mundy dated
September 3, 2020 alleging unjust termination, contrary to the collective
agreement, and in the Matter of an arbitration under the Labour Relations Code
INSURANCE CORPORATION OF BRITISH COLUMBIA (Employer) and MOVEUP
(CANADIAN OFFICE AND PROFESSIONAL EMPLOYEES' UNION LOCAL 378)
(Union)
Arne Peltz Member
Heard: January 18, 2021; January 19, 2021
Judgment: April 7, 2021
Docket: None given
Counsel: Chris Leenheer, Ellen Ferguson, for Employer
Cathy Hirani, for Union
Subject: Public; Labour
Mr. Chair, the first case we would like to introduce is the case of Rhianna Mundy and
the Insurance Corporation of British Columbia (ICBC), a discipline case which
involves the termination of an employee due to dishonesty in claiming sick leave.
Rhianna Mundy was a Customer Service Adjuster employed by the Insurance
Corporation of British Columbia (ICBC) in Surrey, B.C. She was fired due to
dishonesty in claiming sick leave and lying during the subsequent investigation.
Mundy's husband went to a resort in Penticton for a long weekend in August after she
failed in an attempt to book a day off for a scheduled workday. She called, saying she
had a headache, but a social media sweep found an Instagram post showing her

25. 25
celebrating at the lakeside resort. The employer considered this sick leave abuse and
concluded that the necessary trust for a viable employment relationship was
irreparably damaged.
Decision: The grievance was DENIED. The arbitrator decided that “Considering all
the factors, on balance, the penalty of termination was not excessive. There are
insufficient mitigating factors to justify a finding that the employment relationship can
be restored” (at para. 130, page 48).
Explain the Law: I would like to draw attention to the relevant paragraphs In the
Insurance Corporation of British Columbia and Moveup (Canadian Office and
Professional Employees’ Union Local 378) case:
• Para. 117, page 43, the arbitrator recognized that fraud involving sick day
justifies termination, in his words: “I accept the Employer’s submission that
sick leave abuse is a serious form of dishonesty and justifies termination
in the absence of significant mitigating circumstances.” Despite the
grievor belief that taking the day off the way she did was a minor issue; it was
determined to be a significant case of employment misconduct.
• Para 120, page 44, to reinforce the gravity of insisting on dishonesty, the
arbitrator in the cited case highlighted that “the grievor’s conduct has been
characterized by deceit and denial from start to finish. There has been no
acknowledgement of wrongdoing, no apology, and no evidence of
remorse”. In the concluding part of the initial interview, the grievor was asked
if she would change her actions in a similar situation. However, considering
that she had been caught hiding her trip to Penticton, she displayed hesitation
and ambiguity in her response.
• Para 124-125, page 47: about the clear record, the arbitrator highlighted that
the action was premeditated, which is an aggravating factor. “The grievor's

26. 26
work record was apparently favourable, and she had no previous
discipline.” Mr. Chair, the arbitrator's reasoning aligns with the employer's
argument, emphasizing that breach of trust and premeditated dishonesty are
serious grounds for termination, even if it is an isolated incident.
Similarities: The significance of this case lies in its similarities to the present
situation. Just like in our case, the case is in British Columbia. The employee in
question had a clean record and resorted to premeditated fraudulent tactics after their
time off request was denied. Social media evidence played a role in confirming the
dishonesty. Furthermore, similar to our case, the employee had two opportunities to
confess or express remorse but chose not to do so, indicating a lack of regret.
Principle: Mr. Chair, the reason this case is important is because it highlights the
significance of honesty and integrity in the workplace. It stands for the principle that
the behaviour or misconduct involves a breach of the trust relationship with the
employer which makes the employment relationship extremely difficult to maintain
and cannot be restored.

27. 27
Argument
Case Overview
This is a disciplinary case centred around allegations that Shawn committed fraudulent
acts by unjustly receiving paid sick benefits while not genuinely being sick. As a result,
Shawn's termination was deemed necessary as he allowed himself to be compensated
for sick leave when he was not genuinely ill, which constitutes fraud. Moreover, he
exhibited dishonesty by lying when confronted about the situation on two separate
occasions, resulting in a significant loss of trust. We will argue under the Wm. Scott &
Co. Ltd law that the management had just cause to terminate based on the grievor’s
actions and the penalty is not too excessive in response to the circumstances.
Shawn had an extensive tenure of nearly 28 years with a clean record, during which he
held the position of Chief Shop Steward for several years. However, it is important to
consider that he had only specified vacation dates for two out of the five weeks he was
entitled to. Although his application for vacation leave from October 26 to 30 was
denied, he received sick leave payment for that week, which coincidentally aligned with
a curling tournament in Alberta. The HR and General managers were able to confirm his
participation through a sports website, and when directly questioned about his
involvement, Shawn dishonestly denied it. Consequently, due to the combined offences
of fraud and dishonesty, Shawn's termination was immediate and necessary to maintain
integrity and trust within the company.
Core Arguments:
1. Fraudulent sick leave: We highlight the fact that Shawn took paid sick leave
from October 26th to 30th while participating in the curling tournament.
Emphasizing that the following evidence demonstrates Shawn's fraudulent
actions of receiving sick leave benefits while not genuinely being ill.

28. 28
Evidence that supports this argument:
• Exhibit B: The newspaper article published on October 31st, features a photo of
Shawn playing in the tournament.
• Exhibit C: The social media post on the association's official Instagram page on
October 30th, showing Shawn holding the trophy.
• Exhibit A: Official Website of Western Canada Curling Events Team Winners for
2022 Tournament.
• Exhibit D: Shawn Brightly Work ID confirms his identity and has similar photos.
2. Lack of Medical Justification and History: We establish that Shawn's sick
leave during the curling tournament was not medically justified.
Evidence that supports this argument:
Exhibit G: The affidavit of Doctor Rebecca Turner, a licensed medical doctor,
affirms that participating in curling while experiencing significant back pain is not
advisable as it is a physically demanding activity that includes bending and
twisting which is not possible for anyone who has a back injury/pain.
Exhibit H: A record of the employee Illness Log for the past five years showing
that Shawn has only used 16 sick leaves for common ailments, with a maximum
of two days. He has no doctor's note for chronic medical diagnoses or ongoing
medication. Despite his work responsibilities, he has no history of serious
conditions like diabetes, bone fracture, or back injury.
3. Denial and dishonesty: We point out that when questioned about his
involvement in the tournament, Shawn repeatedly denied any participation. This
highlights Shawn's dishonesty and further strengthens the case against him.

29. 29
Evidence that supports this argument:
• Exhibit E: The communication log with Jasmine and Rachel, specifically the
conversation on November 6th
and 7th
when Shawn denied his participation
twice, despite the evidence already suggesting otherwise.
4. Tournament participation evidence: We highlight the various pieces of
evidence that support Shawn's participation in the curling tournament.
Evidence that supports this argument:
Exhibit F: The affidavit from his teammate confirming his involvement in the
tournament.
Exhibit K and L: The affidavit and email conversation from the tournament
organizer that contains details of the winners of the curling tournament from the
past three years, with Shawn being the MVP.
Exhibit N: The tournament contract between Shawn and the Western Canada
Curling Events Association.
Exhibit M: Western Canada Curling Website Winners in 2020 and 2021.
5. Violation of company policies and collective bargaining agreement: We
claim that Shawn's actions, specifically his fraudulent sick leave and dishonesty,
are in direct violation of the policies established by the company and the
provisions outlined in the collective bargaining agreement.
Evidence that supports this argument:
Exhibit I: The company's Code of Conduct page document, specifically the
section on fraud and dishonesty leading to immediate termination, which was
signed by Shawn.

30. 30
Exhibit J: The Collective Bargaining Agreement article that addresses
termination, dishonesty, fraud, and abuse of sick leave.
Reference Case:
To support our argument for denying Shawn Brightly's grievance, we refer to two
reference cases: the Farm Pick-up Driver case and the Rhianna Mundy case.
In the Farm Pick-up Driver case, the grievor, who had almost 18 years of seniority as a
Farm Pick-up Driver, was terminated for engaging in auto racing while off work. The
grievor's job duties involved physical maneuvers, similar to Shawn Brightly's duties. The
grievor's termination was based on dishonesty and misleading behaviour, as he claimed
inability to work due to a shoulder injury while participating in races. The arbitrator in this
case decided to dismiss the grievance, stating that the grievor's misrepresentation of
activities and inconsistent claims justified the termination.
The Rhianna Mundy case involves discipline and termination based on grounds of
dishonesty. Rhianna Mundy, a customer service adjuster, had 8 years of seniority and a
clean disciplinary record. She requested a vacation day, which was denied by the
employer, but she took the day off as a sick day and went on her planned vacation. The
employer discovered this through a social media post and terminated her employment,
considering it a planned and serious offence. The grievance was ultimately dismissed,
and the arbitrator stated that Mundy's actions constituted sick leave abuse and fraud
against the employer.
These cases are similar to Shawn Brightly's case in various ways. In all three cases, the
employees had clean disciplinary records and a significant number of years of seniority.
The termination in each case was based on dishonesty and the abuse of sick leave
privileges. Evidence, such as race results or social media posts, was used to prove the
employees' misconduct. In all cases, the termination was deemed appropriate and not
excessive given the circumstances.

31. 31
Union’s Argument
The union may argue that the severity of Shawn Brightly's offence is not comparable
and there was no cause for termination. Further to this, they may point out that if there
was “some measure of cause” then the penalty was excessive.
To counter this argument, we emphasize the similarities between the cases and
highlight the underlying principles that remain consistent.
Here are some counterpoints:
1. Clean discipline record: In both the referenced cases and Shawn Brightly's
case, the employees had clean disciplinary records. This demonstrates that the
employees had a history of good conduct and reinforces the severity of their
offences.
2. Dishonesty and abuse of sick leave: In all cases, including Shawn Brightly's,
the employees were terminated for dishonesty and willful abuse of sick leave
privileges. This common ground establishes a clear breach of trust and integrity,
regardless of the specific details of the offences.
3. Planned and intentional acts: In both the referenced cases and Shawn
Brightly's case, the employees' misconduct was not a result of a momentary
lapse but rather a planned and intentional act. This factor contributes to the
seriousness of the offenses and further highlights the breach of trust.
4. Lack of remorse or acknowledgement: The referenced cases and Shawn
Brightly's case share the element of the employees failing to acknowledge their
misconduct or show remorse. This absence of remorse underscores the severity
of their actions and the difficulty of restoring the employment relationship.
We argue against Shawn Brightly's grievance claims that these reference cases
highlight the severity of dishonesty as an employment offence and emphasize the
importance of honesty and integrity in the workplace. The acts of dishonesty and breach

32. 32
of trust, even by long-term employees with clean disciplinary records, can lead to
termination. Therefore, we submit that Shawn Brightly's grievance should be denied
based on these precedents.
Remedy
Mr. Chair, we say that these two cases strongly support our argument that termination
was an appropriate punishment in this case since the employee betrayed the mutual
trust between himself and the employer. This mutual trust is an important element that
is required to fuel a harmonious employment agreement that is mutually beneficial to
both parties.
In conclusion, we would like to emphasize that these cases uphold the principle and the
precedence that has been set by case law for honouring honest and forthright conduct
in employment relations and appropriately sanctions any deviations from the same.
Because of this, Mr. Chair, we submit that you should rule in favour of the
employer and dismiss the grievance.
BAMOS
a) Shawn will be offered a settlement equivalent to 6 months’ salary and the termination
upheld.
b) Shawn will be offered a settlement equivalent to 12 months’ salary and the
termination upheld.
c) A reduced penalty of 1 year of suspension as an alternative to the termination.

33. 33
Appendix

34. EXHIBIT A

35. EXHIBIT B

36. EXHIBIT C

37. EXHIBIT D

38. EXHIBIT E

39. EXHIBIT F
Affidavit
November 8, 2022
Province of British Columbia
City of Surrey
I, Kevin Roberts, of legal age, a Canadian citizen, residing at 617-14672 88 Ave., Surrey, BC, V4U
8D7, do solemnly affirm that the following statements made in this affidavit are true and correct to the
best of my knowledge and belief. I make this affidavit in testifying about Shawn Brightly's participation
in the curling tournament held at the Western Canada Curling Arena in Edmonton, Alberta from
October 26-30, 2022.
1. I participated as a teammate alongside Shawn Brightly in the aforementioned curling
tournament.
2. Shawn Brightly demonstrated exceptional skills and sportsmanship throughout the tournament.
3. Shawn Brightly's performance earned him the well-deserved Most Valuable Player (MVP) title.
4. Our team Shawn Brightly Foursome, led by Shawn Brightly, achieved a commendable 3rd
place finish in the tournament.
5. I affirm that the statements made in this affidavit are true and correct to the best of my
knowledge and belief.
Signed,
Kevin Roberts
Kevin Roberts
November 8, 2022
Sworn before me at the City of Surrey, in the Province of British
Columbia, this 8th day of November 2022.
Sarah F. Johnson
Barrister, Solicitor, Notary Public and a Commissioner for Taking Oaths
in and for the Province of British Columbia
Surrey, British Columbia, V3F 8H4

40. EXHIBIT G
Affidavit
November 8, 2022
Province of British Columbia
City of Surrey
I, Dr. Rebecca Turner, of legal age, a Canadian citizen, residing at 14033 92 Ave, Surrey, BC V3V
0B7, do solemnly affirm that the following statements made in this affidavit are true and correct to the
best of my knowledge and belief.
1. I am a qualified and licensed medical sports doctor in the Province of British Columbia,
currently practicing at Surrey Memorial Hospital, with 20 years of experience in the field of
orthopedics particularly in the musculoskeletal system, which includes bones, muscles and
joints.
2. I have evaluated numerous cases of individuals with back pain and have extensive experience
in assessing the impact of such pain on physical activities.
3. Based on my professional expertise and evaluation, I affirm that participating in curling while
experiencing significant back pain is not advisable.
4. The physical demands involved in curling, including repetitive bending, twisting, and sweeping
motions, can exacerbate existing back pain and potentially lead to further injury.
5. Curling requires a level of flexibility, stability, and strength that can be compromised by back
pain, increasing the risk of complications.
6. Engaging in curling activities while experiencing back pain can impede the healing process
and increase the risk of long-term complications.
7. It is my professional opinion that individuals with back pain should refrain from participating in
curling activities until the pain has significantly improved or until they have received
appropriate medical evaluation and treatment.
8. Therefore, any injury requires recovery time, and it is not advisable to practice physical activity,
especially a sport like curling until there is a complete rehabilitation of the muscle, which varies
from person to person.
I affirm that the statements made in this affidavit are true and correct to the best of my knowledge and
belief.
Signed,
Rebecca Turner
Dr. Rebecca Turner
Orthopedic Sports Doctor
Licensed No. 637852
November 8, 2022
Sworn before me at the City of Surrey, in the Province of British
Columbia, this 8th day of November 2022.
Sarah F. Johnson
Barrister, Solicitor, Notary Public and a Commissioner for Taking Oaths
in and for the Province of British Columbia
Surrey, British Columbia, V3F 8H4

41. EXHIBIT H

42. EXHIBIT I
Associated Warehouses
Code of Conduct
Fraud, Dishonesty, and Abuse of Sick Leave Policy
At Associate Warehouses, we are commi1ed to maintaining a culture of honesty, integrity, and respect in all
aspects of our business opera:ons. We expect our employees, contractors, and associates to uphold these
values and act with the utmost professionalism. As part of our commitment to ethical conduct, we have
implemented policies addressing fraud, dishonesty, and the abuse of sick leave privileges.
Fraud and Dishonesty
Associated Warehouses has a zero-tolerance policy for fraud, dishonesty, and any other unethical behaviour.
This includes but is not limited to lying, misinterpreta:on of documents, forgery, bribery, and any act that
compromises the integrity of our organiza:on. Any individual found to be engaging in such conduct will face
immediate termina:on without no:ce, regardless of their posi:on or length of service.
Abuse of Sick Leave
Associated Warehouses recognizes that employees may occasionally require sick leave due to illness or injury.
We respect the need for employees to take :me off to recover and priori:ze their well-being. However, we
strictly prohibit the abuse of sick leave privileges.
Policy Statement
Employees are expected to use sick leave in good faith and only when genuinely unable to perform their job
du:es due to a legi:mate medical condi:on. Any employee found to be willfully abusing sick leave privileges,
including falsely repor:ng illnesses or injuries, misrepresen:ng the need for leave, or engaging in ac:vi:es
inconsistent with their claimed condi:on, will be subject to immediate termina:on without no:ce.
Consequences of Dishonesty and Abuse of Sick Leave
The use of sick leave rights fraudulently and dishonestly results in a breach of trust, nega:vely impact team
morale and disrupt business opera:ons. Associated Warehouses takes these viola:ons seriously and will
thoroughly inves:gate any reported incidents. Individuals found to violate this policy may face immediate
termina:on. The degree of discipline taken must correlate to the seriousness of the offence and the
employee’s record. Major and serious situa:ons include fraud, dishonesty and abuse of using sick leave
privileges.
Shawn Brightly
By signing above, I acknowledge that I have read, understood, and will comply with the Associated
Warehouses Code of Conduct, specifically the Fraud, Dishonesty, and Abuse of Sick Leave Policy. I understand
that any viola:on of this policy may result in disciplinary ac:on, up to and including immediate termina:on of
my employment.
Shawn Brightly
Date: January 3, 2022
Posi:on: LiW Truck Driver
Employee ID: 321-456-9870

43. EXHIBIT J
Addendum to the Collec.ve Bargaining Agreement Ar.cle 25-27
This ar(cle, hereby incorporated into the collec(ve bargaining agreement between the Warehouse Union
Members Associa(on (WUMA) (hereina?er referred to as the "Union") and Associated Warehouses (AW)
(hereina?er referred to as the "Company"), addresses the issues of fraud, dishonesty, and willful abuse of sick
leave privileges. Both par(es recognize the importance of maintaining a workplace environment based on
trust, integrity, and accountability.
Ar+cle 25 Fraud and Dishonesty
Sec(on 1. Fraud and dishonesty in any form, including but not limited to dishonesty, fraud, the?,
misappropria(on of funds, embezzlement, falsifica(on of records, or any other decep(ve prac(ces, are strictly
prohibited within the Company.
Sec(on 2. Any employee found to have engaged in fraudulent or dishonest ac(vi(es shall be subject to
disciplinary ac(on, up to and including immediate termina(on, as per the Company's policies and procedures.
Ar+cle 26 Willful Abuse of Sick Leave Privileges
Sec(on 1. Sick leave is a benefit provided to employees for genuine illness or injury, as well as for medical
appointments and related reasons.
Sec(on 2. Willful abuse of sick leave privileges, such as falsely claiming illness, forging medical documenta(on,
or engaging in ac(vi(es inconsistent with the claimed illness, is strictly prohibited.
Sec(on 3. Any employee found to have willfully abused sick leave privileges may face disciplinary ac(on, up to
and including termina(on, as per the Company's policies and procedures.
Sec(on 4. The employer reserves the right to discharge any employee, without no(ce, for any of the following
causes: 1) dishonesty or fraud, 2) willful abuse of sick leave privileges”. It is clear under this Collec(ve
Bargaining Agreement, dishonesty and abuse of sick leave privileges have been designated as disciplinable
offences that if proven, will allow the employer to terminate the employee immediately without no(ce.
Ar+cle 27 Chief Shop Steward Posi+on
Sec(on 1. The Chief Shop Steward is a posi(on of high responsibility within the Union, entrusted with
represen(ng and advoca(ng for the rights and interests of the union members.
Sec(on 2. The Chief Shop Steward, by virtue of their posi(on, is expected to uphold the highest standards of
honesty, integrity, and ethical conduct in the workplace.
Sec(on 3. The Chief Shop Steward cannot claim ignorance of the significance of honest behaviour in the
workplace, as they hold a posi(on that emphasizes the importance of such behaviour.
Sec(on 4. Holding the esteemed posi(on of Chief Shop Steward confers a significant amount of authority and
responsibility, requiring the individual to serve as a role model for other employees.
Signatures: Shawn Brightly
For the Union: Warehouse Union Members
Associa(on (WUMA)
Shawn Brightly
Li? Truck Driver and Chief Shop Steward
Date: January 4, 2022
Signature: RachelSm*h
For the Company: Associated Warehouses (AW)
Rachel Smith
General Manager
Date: January 4, 2022

44. EXHIBIT K
Email Conversa4on
From: John Stevens john.stevens@inves3gator.ca (Field Inves3gator)
To: Nicole Davidson nicole.davidson@westerncanadacurling.ca (Tournament Organizer)
Date: November 17, 2022; 9:00 am
Subject: Inquiry about Shawn Brightly's Par3cipa3on in the Curling Tournament
Dear Nicole Davidson,
I hope this email finds you well. My name is John Stevens, and I have been hired as a field
inves3gator to conduct an inquiry regarding Shawn Brightly's par3cipa3on in the curling
tournament held at the Western Canada Curling Arena in Edmonton, Alberta, from October 26-
30, 2022.
As part of my inves3ga3on, I am reaching out to you to gather informa3on and confirm whether
Shawn Brightly indeed played and a[ended the tournament during the specified dates.
Addi3onally, I would appreciate any details, evidence, or documenta3on you can provide to
support his par3cipa3on, such as photographs, video recordings, or tes3monials from
witnesses.
Please also inform me if there is a website or any other plaorm where I can access further
informa3on about the tournament and any records of the awards and achievements bestowed
upon the par3cipants, including Shawn Brightly.
Your prompt response and coopera3on in this ma[er are greatly appreciated. Should you
require any further clarifica3on or have any ques3ons, please do not hesitate to reach out to
me.
Thank you for your assistance.
Best regards,
John Stevens
Field Inves3gator

45. From: Nicole Davidson nicole.davidson@westerncanadacurling.ca (Tournament Organizer)
To: John Stevens john.stevens@inves3gator.ca (Field Inves3gator)
Date: November 18, 2022; 10:30 am
Subject: Re: Inquiry about Shawn Brightly's Par3cipa3on in the Curling Tournament
Dear Mr. Stevens,
Thank you for your email. This is to confirm Shawn Brightly's par3cipa3on in the curling
tournament held at the Western Canada Curling Arena in Edmonton, Alberta, from October 26-
30, 2022.
I can confirm that Shawn Brightly did par3cipate in the tournament as an ac3ve player during
the specified dates. He was a valuable member of the Shawn Brightly Foursome and made
notable contribu3ons to their performance throughout the event.
To provide you with the necessary informa3on, I have a[ached an agreed contract that contains
detailed records of the tournament, including the schedule, teams, and agreement between
Shawn Brightly and Western Canada Curling Events. Furthermore, I would like to direct your
a[en3on to our tournament's website at westerncanadacurlingevents.ca where you will find a
dedicated sec3on showcasing the awards and achievements of the par3cipants.
In the awards sec3on, you will find that Shawn Brightly has been consistently recognized as the
Most Valuable Player (MVP) for the past three years. This is a testament to his excep3onal skills,
sportsmanship, and impact on the tournament. The website provides addi3onal informa3on to
support his par3cipa3on.
If there are any specific records or details you require, please let me know, and I will do my best
to assist you. I understand the importance of your inves3ga3on and will provide any necessary
coopera3on to establish the accuracy of Shawn Brightly's par3cipa3on in the tournament.
Thank you for your diligence in this ma[er, and I look forward to your findings. Should you have
any further ques3ons or require addi3onal assistance, please feel free to reach out to me.
Best regards,
Nicole Davidson
Tournament Organizer
Western Canada Curling Events
Edmonton, Alberta

46. EXHIBIT L
Affidavit
November 19, 2022
Province of Alberta
City of Edmonton
I, Nicole Davidson, of legal age, a Canadian citizen, residing at 10863 82 Ave, Edmonton, AB T6F
2J2, do solemnly affirm that the following statements made in this affidavit are true and correct to the
best of my knowledge and belief. I make this affidavit in testifying of Shawn Brightly's participation in
the curling tournament held at the Western Canada Curling Arena in Edmonton, Alberta from October
26-30, 2022.
1. I am the head organizer of the curling tournament at the Western Canada Curling Arena.
2. On August 9, 2022, Shawn Brightly informed and assured me of his commitment to play curling
at the Western Canada Curling Arena from October 26-30, 2022.
3. Shawn Brightly not only expressed his verbal commitment but also signed a contract to
formalize his agreement to participate in the tournament. The contract outlined the terms and
conditions of participation, including the dates, venue, and expectations regarding Shawn
Brightly's involvement.
4. His signature on the contract served as confirmation of his understanding and agreement to be
present and participate in the tournament as planned.
5. I hereby confirm that his absence will lead to his team, the Shawn Brightly Foursome, being
disqualified from the competition. The team consists of four members and an alternate
member, and as the alternate member, James Dylan has not been able to register for the
curling tournament. Therefore, Shawn Brightly's presence is crucial for the team to maintain its
eligibility and compete in the tournament.
Signed,
NicoleDavids-
Nicole Davidson
Curling Tournament Head Organizer, Western Canada Curling Events
November 19, 2022
Sworn before me at the City of Edmonton, in the Province of Alberta, this
19th day of November 2022.
Arthur M. Anderson
Barrister, Solicitor, Notary Public and a Commissioner for Taking Oaths in
and for the Province of Alberta
Edmonton, Alberta, T6G 1S4

47. EXHIBIT M

48. EXHIBIT N
Curling Tournament Par6cipa6on Contract
This agreement (hereina.er referred to as the "Contract") is entered into between the management of
Western Canada Curling Events (hereina.er referred to as the "Management") and Shawn Brightly (hereina.er
referred to as the "Player") as follows:
1. Tournament Details:
a) Tournament Name: Western Canada Curling Tournament
b) Date of the Event: October 26-30, 2023
c) Venue: Western Canada Curling Arena, Edmonton, Alberta
d) Organizing Body: Western Canada Curling Events
2. Player's Obliga6ons:
a) The Player, as a member of the Shawn Brightly Foursome team, acknowledges their commitment to fully
parRcipate in the curling tournament menRoned above.
b) The Player agrees to comply with all rules, regulaRons, and policies set forth by the Management.
c) The Player shall exhibit good sportsmanship and conduct themselves in a professional manner throughout
the tournament.
d) The Player understands that non-parRcipaRon or failure to fulfill their obligaRons without a valid reason will
not be allowed and may result in consequences as outlined in this Contract.
3. Management's Obliga6ons:
a) The Management agrees to provide the necessary faciliRes and equipment for the tournament.
b) The Management will organize and schedule all games, ensuring a fair and compeRRve environment.
c) The Management will provide adequate security and medical assistance during the tournament.
d) The Management will award prizes and recogniRon to outstanding performers, as per the tournament
guidelines.
4. Terms of Par6cipa6on:
a) The Player acknowledges that parRcipaRon in the tournament is voluntary and at their own risk.
b) The Player agrees to indemnify and hold harmless the Management from any liability arising from personal
injury or property damage incurred during the tournament.
c) The Player grants the Management the right to use their name, likeness, and photographs for any purposes
related to the tournament.

49. 5. Teammates:
The Player will be part of the Shawn Brightly Foursome
team, consisRng of the following members:
• Alex Thompson
• Nixon Collins
• Kevin Roberts
• Shawn Brightly
• James Dylan (Unregistered)
6. Fulfillment of Agreement:
The Player acknowledges that this Contract represents a commitment to fulfill their obligaRons and acRvely
parRcipate in the curling tournament. Non-parRcipaRon or failure to fulfill the agreed-upon obligaRons
without a valid reason may result in consequences, including disqualificaRon, loss of prizes, or other acRons
deemed appropriate by the Management.
This contract confirms that The Player’s absence will lead to his team, the Shawn Brightly Foursome, being
disqualified from the compeRRon. The team consists of four members and an alternate member, and as the
alternate member, James Dylan has not been able to register for the curling tournament. Therefore, The
Player, Shawn Brightly's presence is crucial for the team to maintain its eligibility and compete in the
tournament.
7. En6re Agreement:
This Contract consRtutes the enRre agreement between the Management and the Player, superseding any
prior discussions or agreements, whether wri_en or oral, relaRng to the subject ma_er herein.
8. Signatures:
By signing below, both parRes acknowledge their understanding and acceptance of the terms and condiRons
outlined in this Contract.
NicoleDavids-
Nicole Davidson
Head Tournament Organizer
Western Canada Curling Events
Date: August 9, 2022
Shawn Brightly
Shawn Brightly
Player of Shawn Brightly Foursome
Date: August 9, 2022