Leslie Moodley VBeenleigh Sports Club Inc.
[2012] FWA 10206
•27 DECEMBER 2012
[2012] FWA 10206 |
|
DECISION |
Fair Work Act 2009
s.394—Unfair dismissal
Leslie Moodley
V
Beenleigh Sports Club Inc.(U2012/8635)
COMMISSIONER SIMPSON | BRISBANE, 27 DECEMBER 2012 |
Application for unfair dismissal remedy - application dismissed.
[1] This matter concerns an application for unfair dismissal remedy filed by Leslie Moodley (the Applicant) against Beenleigh Sport Club Inc (the Respondent). The application was filed on 1 June 2012. A conciliation conference was conducted on 21 June 2012 which was unsuccessful.
[2] The matter was then listed for Hearing for 10am 21 November 2012. The Applicant represented himself and the Respondent was represented by Mr Wally Lee from the Registered and Licensed Clubs Association of Queensland, Union of Employers (T/A Clubs Queensland).
[3] The Applicant was the only witness to give evidence in his case. The Respondent called Mr Peter John Harrison-Kyte who is the incumbent President of the Beenleigh Sports Club Inc, Mr Gregory Krieger a former Club President, and Mr Perran Sonnex, the current General Manager of the Beenleigh Sports Club Inc.
BACKGROUND
[4] The Respondent operates a licensed club from premises at the Dauth Park Complex. The Applicant was engaged on 7 November 2011 under a three year contract as Local Sport and Recreation Coordinator employed by the Respondent through a grant from the Queensland Government through the Department of Communities, Sport and Recreation Services. 1He was terminated at a meeting on 18 May 2012 with one weeks’ notice.
[5] Although the Respondent was his employer, the grant from the State Government provided the funding for the role the Applicant fulfilled as a project to provide assistance to a cluster of Beenleigh sporting organisations, including;
● Beenleigh-Logan Cricket Association
● Beenleigh Junior Rugby league Football Club,
● Beenleigh Australian Rules Football Club,
● Beenleigh Netball Association,
● Beenleigh Tennis Association,
● Beenleigh Sports Club (the Respondent).
[6] The evidence indicates the Respondent acted as a sponsor body for the respective sporting associations, and because of its size and management structure was best suited to be the employer, albeit the Applicant through the project funding was to provide services not just to the Respondent but was to spread his time across all of the named sporting bodies. The purpose of the role is set out in great detail in the Local Jobs Plan Application Form 2.
CONSIDERATION
[7] Perran Sonnex the General Manager of the Respondent at the time of the Applicant’s employment and his termination said that at the time of his commencement he was provided a staff handbook, and a copy of the Local Sport and Recreation Co-Ordinator Jobs Plan and Grant Application to use as reference material for his role. 3
[8] Mr Sonnex said the Applicant reported directly to the Beenleigh Sports and Recreation Coordination Committee via the General Manager of the Club and Chair of the Committee who was the President of the Respondent Les Kreiger before Peter Harrison-Kyte became President of the Respondent and took over that role. 4
[9] The Applicants says he received an email from Perran Sonnex at 12.50pm on 17 May 2012 requesting he attend an urgent meeting of the Board of the Respondent on Friday 18 May 2012 at 6.30pm to discuss an agreement entered into between Bartercard and the Respondent, and informing him that he may bring an independent witness which he ultimately did. 5 The Applicant responded by email at 7.30pm requesting the specifics of the allegations and for advice as to whether his employment was in jeopardy.
[10] An interview was conducted with the Applicant on the evening of 18 May 2012 where the Applicant attended with his support person, Mr Harrison-Kyte as President of the Club also attended along with a number of other members of the Respondents Board.
[11] The following allegations were put to the Applicant for his response at the commencement of the meeting.
(a) That Les Moodley knowingly entered into a financial agreement with Bartercard.
(b) Les Moodley signed an application for credit on behalf of the Beenleigh Sports Club on 19 January 2012.
(c) That Les Moodley misrepresented himself as a board member/director of the Board of the Beenleigh Sports Club in order to complete the said application.
(d) Les Moodley was advised that all sponsorship was to be signed by the sport and recreation committee chairperson for group deals or by a sport and recreation representative from the relevant sporting body.
(e) That (i),(ii), (iii) were done independently and without prior knowledge of the Beenleigh Sports Club Board or the Sport and Recreation Coordination Committee (the Committee).
[12] Perren Sonnex gave evidence that according to the Bartercard statements the Applicant made his first transaction on 19 January 2012 for a Mini Motorbike from a vendor in Bendigo. 6
[13] Mr Sonnex said that a number of items were obtained for use within the Club for promotional activities and the Applicant had indicated to him and the Promotions Manager Stephanie Elsworth that these items were “goodwill” gestures obtained using his existing relationship with Bartercard and there was no financial impact on the Licensed Club. 7
[14] Mr Sonnex said the proposal for access to $20,000 trade dollars in Bartercard Sponsorship was first introduced on 6 February 2012 8 at a Sports and Recreation Coordinating Committee meeting where the Applicant explained its benefit to the other clubs and the Respondent.9 Mr Sonnex said at a Board meeting of the Respondent on 15 February the concept was discussed at length and it was decided the other sporting bodies could make their own decision but that the Respondent would not be involved in any arrangement with Bartercard.10 On 22 February the Applicant emailed a formal proposal to all members of the Sports and Recreation Coordinating Committee including the Respondent.
[15] Mr Sonnex said on 3 March a venue specific sponsorship arrangement was signed on behalf of Bartercard and emailed to the Sports and Recreation Coordinating Committee. This proposal he said was presented to the meeting of Sports and Recreation Coordinating Committee on 5 March at which Peter Harrison-Kyte made it clear the Respondent would not be involved. The Sports and Recreation Coordinating Committee approved the Bartercard proposal subject to a response from Jeff Scott at the Beenleigh Tennis Association. 11
[16] On a separate matter Mr Sonnex claimed that sponsorship with Bendigo Bank was discussed and the Applicant was advised by Mr Harrison-Kyte that only Directors of the Respondent could sign the sponsorship arrangement with Bendigo Bank. 12 At a meeting of 2 April 2012 final approval for sponsorship deals was given.13
[17] Mr Sonnex said after the Respondent received invoices from Bartercard it decided to conduct an investigation into the Applicants involvement with Bartercard. 14 Mr Sonnex said on 16 May 2012 the Applicant produced to him a signed copy of the Agreement made with Bartercard on 19 January 2012. 15
[18] In a written submission the Applicant later adopted as his statement 16 he claimed he advised the Respondent that prior to entering the arrangement with Bartercard he had received prior authorisation from former President of the Respondent Greg Kreiger, who was also chair of the Sports and Recreation Committee.17
[19] He gave evidence that the Sports and Recreation Coordinating Committee met in December 2011 and gave him the task, as a matter of urgency, to raise sponsorship dollars. He claimed he meet with Mr Kreiger in January 2012 and discussed four proposals, and Mr Kreiger said to him “as a matter of urgency the clubs do need the money, can you go away and sign sponsorships on behalf of the club.” 18
[20] When pressed again on the words said the Applicant said as follows;
PN60
MR LEE: Can you say again, what exactly did Mr Krieger say when he gave you that authorisation?---Well, Mr Krieger basically said to me, you know, what I mean, “Go out and get the sponsorship deals done because the clubs are in urgent need of cash.”
PN61
When you were - in response to your last you question you actually said, “He told me to go out and sign”?---Yes, yes.
PN62
Is that what he said?---The exact words he said to me was to, “Go out and get the sponsorship deals done and signed.”
PN63
In those circumstances the materials that were circulated in relation to this matter, what’s your reaction to the statutory declaration that Mr Krieger has now put forward?---Look, you know, that’s what Greg is saying; and this is what I’m saying. You know, I produced an email at my termination meeting with the committee from Maria Robins, which is the president of the Beenleigh Netball Association that basically stated that in December, and I quote - I quote - this is an email from Maria Robins to me, “Hi Les, I’ve been through my notes and minutes and Bartercard (indistinct) of last year and although Greg said members of the board were not Bartercard fans he would explain it would be used for signage and raffle prizes, et cetera. It was then reported back to our local sports committee that he would handle everything. As always nothing was confirmed in writing. What was reported back verbally through Greg was that it was okay and he and you would handle the dealings with them. Again, no written confirmation, we took him on his word.” Would you like a copy of that email?
[21] The Applicant also relied on a Statutory Declaration from Trevor Capps a Bartercard Membership Consultant. Mr Capps did not appear at the hearing to give evidence. His statutory declaration said that he had three meetings with the Applicant prior to signing the Bartercard membership documents and that the President had approved the membership agreement.
[22] Mr Gregory Kreiger as the former President of the Beenleigh Sports Club provided a Statutory Declaration dated 15 June 2012 which said as follows;
“I had been contacted by Les Moodley, Sports and Recreation Coordinator regarding the Bartercard application from earlier this year. As you know, a number of Committee members expressed concern at a possible Bartercard deal, in that they were unaware of its financial impact on the Sports Club.
I would like to make it very clear, that I, in my then role as Club President, did not give Mr Moodley permission to enter into or sign any documents with Bartercard on behalf of the Beenleigh Sports Club Incorporated.” 19
[23] This statutory declaration was consistent with an email sent by Mr Kreiger to Darryl Fagan the Secretary of the Club on Friday 18 May 2012 at 7.59am 20 prior to the meeting that evening where the Club took the decision to terminate the Applicant.
[24] Mr Kreiger gave evidence that the grant, which was for $52,000 a year for three years, was to pay a sports development officer to help the clubs to get better management, to try and help to fundraise and get sponsorship. 21
[25] The Applicant sought to attack the credibility of Mr Kreiger as a witness on the basis that he had resigned as President of the Respondent after the Board of the Respondent had raised a matter with him of having made an arrangement for sponsorship of the Beenleigh Junior Rugby League Club for $4,000 without agreement of the Board. Mr Kreiger said he accepted the request to resign and did so.
[26] The Applicant’s argument was that had Mr Kreiger passed onto the Board of the Respondent the nature of discussions he had with Mr Kreiger concerning Bartercard he would not have got into the predicament he was in. 22
[27] Mr Kreiger said the Applicant was in charge of trying to get sponsorship for the sporting bodies represented on the committee and that was part of his brief, and Mr Kreiger agreed the Applicant was authorised to do that but to not to sign anything on behalf of the Respondent which he was never authorised to do, and that was the difference. 23
[28] The Applicant said the arrangement was an unusual situation in that there were six different clubs involved. 24
[29] Peter Harrison-Kyte gave evidence that on the evening of Wednesday 15 February 2012 he was elected as President of the Club, following the resignation of President Greg Kreiger and at the same management committee meeting he assumed the chair of the Sports and Recreation Coordinating Committee. 25
[30] The Applicant said he commenced his role in November 2011 and the Committee met for the first time in December 2011. He said the discussion at the meeting was the window of opportunity for sponsorship between January to March before seasons start and he said the decision was “Les go out and get some sponsorship because we need the funds.” 26
[31] A copy of a Job Description of the Applicants role was attached to the Minutes of the March Committee meeting. When asked if he reported making the arrangement with Bartercard to the Respondent the Applicant claimed he mentioned it was ready to go at the February Sports and Recreation Committee Meeting. 27
[32] It was put to the Applicant that when the General Manager asked the Applicant about the source of the items for the raffles that he told Mr Sorren they were goodwill or donated goods. The Applicant said his response was that they were from Bartercard and it was a goodwill gesture by Bartercard in the initial stages. The Applicant indicated Bartercard gave the prizes as a goodwill gesture in good faith, on the basis a sponsorship agreement made with Bartercard. 28
[33] The difficulty with the position as put by the Applicant even if it were true is that it did not properly describe the arrangement the Applicant had entered with Bartercard. In truth the arrangement with Bartercard was not a gift. The arrangement entered into under the Bartercard scheme was that the Respondent would eventually have to make payments which the Respondent only first became aware of when it began to receive invoices from Bartercard.
[34] The Applicant said he had explained to the Respondent that the arrangement that had been struck with Bartercard was not a credit arrangement but was in fact a sponsorship arrangement whereby Bartercard had agreed to make available for the use of the Respondent $20,000 in sponsorship funds in the form of trade dollars. The Applicant confirmed he signed a membership form to join Bartercard on 20 January, 2012.
[35] Mr Harrison-Kyte said he was presented with a copy of this signed application for credit from Bartercard after he had instructed the General Manager Mr Sonnex to investigate how the Applicant was gaining access to merchandise that the Beenleigh Sports Club was receiving accounts for. 29
[36] Mr Harrison-Kyte said that on Monday 9 May 2012 at the monthly meeting of the Sports and Recreation Coordinator Committee the Applicant advised the Committee it would now be necessary to retain 10% of all sponsorship money raised as a result of the Bartercard merchandise raffles for additional fees imposed by Bartercard. Mr Harrison-Kyte said these fees had not been previously disclosed to the Committee by the Applicant. 30
[37] The Applicant claimed the $20,000 was like credit to purchase promotional items. 31 The Applicant claimed the first time he was advised that he was not allowed to sign any future group sponsorship agreements without authority of the Board or the Committee was at a Committee meeting in March when new Club President Mr Peter Harrison-Kyte advised him of this.32
[38] The Applicant claimed the March committee meeting was the first time anyone had told him he couldn’t sign sponsorship arrangements and Peter Harrison-Kyte referred to future arrangements. 33 The Applicant maintained he had authority to sign arrangements before than as it was a major part of his role. 34
[39] The Applicant claimed that as at 20 January 2012 the Club had no written policy or procedure for entering into sponsorship arrangements, and the Respondent has accepted the benefit of the arrangements he made. The Applicant argued that if there was no specific authority to make the arrangement he was unaware of that, and as there was no policy or procedure to make him aware. 35
[40] The Applicant said he did not represent himself to be a Board member of Director of the Respondent, 36 and this is evidenced by his signing the application itself as the Local Sport and Recreation Co-ordinator.
[41] Mr Harrison Kyte said that on 16 May 2012 as a result of an investigation of the Executive members of the Beenleigh Sports Club Management Committee the board was informed of the matters involving the Applicants arrangement with Bartercard and a decision was taken of the full board to convene a Special Committee Meeting at 6.30pm on Friday 18 May 2012.
[42] Mr Harrison-Kyte said the Applicant was told to attend the meeting to explain his action in relation to Bartercard and was offered the opportunity to have a witness present. The meeting occurred at 6.30pm on Friday 18 May 2012. Darryl Wright attended the meeting as support person which was recorded, and a recording of the interview was provided as evidence. Mr Harrison-Kyte said after an investigation the Club had come to conclusion it wanted the Applicant to answer the allegations concerning Bartercard.
[43] There is no question that the Applicant knowingly entered into a financial agreement with Bartercard on 20 January. He also named the applicant for the agreement as the Respondent. On the form the Applicant ticked the section for Company, and filled out the form in the section under the heading Company Directors/Partners/Proprietors. It should have been clear to the Applicant he did not fall into any of these categories however regardless decided to complete the form despite that on behalf of the Respondent. He described this action as an oversight on his part.
[44] The Applicant argues he did not do this with the intention of trying to be deceptive; there was no personal gain in doing it for himself. However it should have been apparent to him he was not entitled to complete this form and enter such an arrangement on behalf of the Respondent.
[45] To compound this error it was clearly noted in the Minutes of the March 2012 Beenleigh Sports and Recreation Committee meeting that Mr Harrison-Kyte said the Respondent made it clear it did not wish to have any part of an arrangement involving Bartercard 37 The Applicant was in attendance at the meeting. If he was not already aware that he had taken an action that he was not authorised to take, from that time it was very clear the President of the Respondent did not support a relationship with Bartercard.
[46] This should logically have triggered a response from the Applicant declaring the nature of the arrangement entered into back on 20 January but it did not.
[47] The Applicant claimed the first time he was made aware that all sponsorship arrangements had to go to the Board of the Respondent was when Mr Harrison-Kyte became President. He also claimed he had made requests for a policy to clarify what the powers of the Sports and Recreation Coordinating Committee actually were.
[48] Mr Sonnex accepted in cross examination he had discussions with the Applicant about Bartercard in January 2012 and actually was a supporter of the concept but says he never authorised the Applicant entering any arrangements. He accepted he agreed with the proposal for a wrap to be put on the Respondents bus subject to sponsorship from Bendigo Bank however he said he was never authorised to finalise the matter without Board approval. 38
CONCLUSION
[49] In considering whether it is satisfied that a dismissal was harsh, unjust or unreasonable, FWA must take into account a range of factors. The Applicants case rests heavily on the claims that Mr Kreiger authorised him to make the arrangement and the process governing his role were ill defined.
(a) whether there was a valid reason for the dismissal related to the person’s capacity or conduct (including its effect on the safety and welfare of other employees);
[50] The Applicant was provided a letter of appointment on commencement. The Local Sport and Recreation Jobs Plan 39 which was provided with the employee handbook to the Applicant at the time of his commencement during induction 40 made clear it was intended the role reported directly to and was supervised by the General Manager of the Respondent Perren Sonnex, and the role was overseen by the Sport and Recreation Coordinating Committee comprising representatives of the five sporting bodies and the Respondent. Mr Sonnex gave evidence that a position description was an appendix to the Jobs Plan provided to the Applicant on commencement. 41 The Applicant ticked a form titled “Orientation Checklist’ that indicated he did receive a position description on 7 November 2011.42
The Applicant was also given a copy of the Staff Handbook which included under the heading disciplinary procedures that providing of false information on any documentation was regarded as misconduct. 43
[51] The Applicant described the reporting requirements as firstly to Perren Sonnex as General Manager of the Club, and that Perren Sonnex then reported to the Board of the Club. 44
The Applicant accepted he was given a copy of the Local Sports and Recreation Jobs Plan with the grant application. 45
[52] The Applicant claims to have had authority to have entered the arrangement with Bartercard in January 2012 from the former Respondents Club President Mr Kreiger who was also Chair of the Sport and Recreation Coordinating Committee however Mr Kreiger has provided a statutory declaration refuting this, and also given oral evidence refuting this claim.
[53] Mr Kreiger did however indicate he believed the Applicant was authorised to attempt to gain sponsorship for the sporting bodies represented on the Sport and Recreation Coordinating Committee as opposed to the Respondent, the Beenleigh Sports Club Inc, a licensed club, and that is the distinction. It may well be that a misunderstanding existed between the Applicant and Mr Kreiger in that the Applicant believed he had been given authority to act on behalf of the Respondent whereas Mr Kreiger maintains he was never given that authority.
[54] Even if that were so and the Applicant should be shown latitiude on that basis, it still does not explain the Applicant not bringing the sponsorship arrangement to the attention of his supervisor Perren Sonnex earlier, signing the Bartercard documents which clearly on their face were not intended to be signed by an employee at the level within the entity making the arrangement that the Applicant was, and also failing to make clear at and following the meeting on 5 March 2012 that an arrangement had already been entered into between the Respondent and Bartercard, once the Applicant had been made aware in the clearest terms by Mr Harrison-Kyte on behalf of the Respondent that the Respondent had no intention of being involved in any arrangement with Bartercard.
[55] The evidence of Mr Sonnex was the Respondent started to receive invoices from Bartercard 46 in a form similar to credit card statements before the March committee meeting. Keeping in mind that the Applicant had only been employed with the Respondent for just over two months when the arrangements were made with Bartercard, and the entity he was engaged with had a General Manager who directly supervised him, and an Executive and governing board it is difficult to see how the Applicant could have believed he would be authorised to make the arrangement he did as the formal representative of the Respondent.
[56] The Applicants failures to take the steps outlined above satisfy me that in the circumstances the Respondent did have a valid reason for dismissal, even though it is equally possible that at the time of making the arrangement the Applicant believed he was doing so with the authority of President Mr Kreiger at the time.
[57] I understand the Applicant has sought to argue that the discussions at the Sport and Recreation Coordinating Committee in February, March and April did not pertain to the arrangement made in January 2012. However it also strikes me as odd that a Bartercard proposal was raised at the committee meetings in February 2012 and March 2012, documentation referred to an arrangement between the Respondent and Bartercard and the Applicant did not seek to make clear at those meetings that another arrangement between the Respondent and Bartercard had already been entered into in January 2012 to distinguish it from the proposal now being put forward which the Applicant maintained was a different and separate arrangement. If the Applicant maintains that was his understanding, his failure to make that explicitly clear, particularly in light of Mr Harrison-Kites’ statements at the 5 March meeting, especially in the context that the document circulated at the 5 March 2012 related specifically to the Respondents venue, goes to the Applicants competence if not his motivation.
[58] This failure to be clear is compounded at the April 2012 meeting when the other sporting bodies approved an arrangement with Bartercard, and the Respondents attitude to such an arrangement remained consistent. Despite this the Applicant still said nothing at the April meeting about the arrangement made in January 2012 between the Respondent and Bartercard.
(b) whether the person was notified of that reason;
[59] The Applicant was advised of the reasons in a show cause process which included the meeting of 18 May 2012.
(c) whether the person was given an opportunity to respond to any reason related to the capacity or conduct of the person;
[60] The Applicant claimed he had not been given an adequate opportunity to respond to the allegations, and his responses were ignored. 47 I am satisfied that the Applicant was given an opportunity to respond to each of the matters raised in the course of the meeting on 18 May and his responses were considered by the meeting before a decision taken to terminate him.
(d) any unreasonable refusal by the employer to allow the person to have a support person present to assist at any discussions relating to dismissal;
[61] The Applicant was offered the opportunity to have a support person, and a support person attended the meeting of 18 May with him.
(e) if the dismissal related to unsatisfactory performance by the person—whether the person had been warned about that unsatisfactory performance before the dismissal; and
[62] The termination related to misconduct not unsatisfactory performance.
(f) the degree to which the size of the employer’s enterprise would be likely to impact on the procedures followed in effecting the dismissal; and
[63] The Respondent advised it is not a small business employer. It is a member of Clubs Queensland and took advice during the process from that organisation.
(g) the degree to which the absence of dedicated human resource management specialists or expertise in the enterprise would be likely to impact on the procedures followed in effecting the dismissal; and
[64] The Respondent did not seek to rely upon section 387(g) and therefore I have not considered it as a factor.
[65] There are no other matters that I consider relevant for the purposes of this application. On the basis of my views expressed above I am not satisfied that the termination was harsh unjust or unreasonable and therefore the Application must be dismissed.
COMMISSIONER
Appearances:
Mr Moodley for the Applicant
Mr Lee for the Respondent
Hearing details:
2012
November 21
1 Exhibit 9 Statement of Kieran Sonnex dated 22 October 2012 paragraph 2
2 Exhibit 9 Statement of Kieran Sonnex dated 22 October 2012 attachment PS 2 Page 9
3 Exhibit 9 Statement of Kieran Sonnex dated 22 October 2012 paragraph 4
4 Exhibit 9 Statement of Kieran Sonnex dated 22 October 2012 paragraph 6
5 Exhibit 1 Statement of Leslie Moodley paragraph d
6 Exhibit 9 Statement of Kieran Sonnex dated 22 October 2012 paragraph 8
7 Exhibit 9 Statement of Kieran Sonnex dated 22 October 2012 paragraph 8
8 Exhibit 9 Statement of Kieran Sonnex dated 22 October 2012 attachment PS 4
9 Exhibit 9 Statement of Kieran Sonnex dated 22 October 2012 paragraph 10
10 Exhibit 9 Statement of Kieran Sonnex dated 22 October 2012 paragraph 11
11 Exhibit 9 Statement of Kieran Sonnex dated 22 October 2012 paragraph 14
12 Exhibit 9 Statement of Kieran Sonnex dated 22 October 2012 paragraph 15
13 Exhibit 9 Statement of Kieran Sonnex dated 22 October 2012 paragraph 16
14 Exhibit 9 Statement of Kieran Sonnex dated 22 October 2012 paragraph 18
15 Exhibit 9 Statement of Kieran Sonnex dated 22 October 2012 paragraph 20
16 Exhibit 1 Statement of Leslie Moodley
17 Exhibit 1 Statement of Leslie Moodley paragraph i
18 Transcript PN 59
19 Exhibit 8 Statutory Declaration
20 Exhibit 7 Email to Darrell Fagon from Greg Kreiger dated 18 May 2012.
21 Transcript PN 319
22 Transcript PN 279
23 Transcript PN 287
24 Transcript PN 88
25 Exhibit 2 Statement of Peter John Harrison-Kyte dated 8 October 2012
26 Transcript PN 107
27 Transcript PN 96
28 Transcript PN 101
29 Exhibit 2 Statement of Peter John Harrison-Kyte dated 8 October 2012 paragrpah 7
30 Exhibit 2 Statement of Peter John Harrison-Kyte dated 8 October 2012 paragraph 8
31 Transcript PN 69
32 Exhibit 1 Statement of Leslie Moodley paragraph K
33 Transcript PN 73
34 Transcript PN 74
35 Exhibit 1 Statement of Leslie Moodley paragraph R
36 Exhibit 1 Statement of Leslie Moodley paragraph S
37 Transcript PN 178
38 Transcript PN 386 to 388
39 Exhibit 11 Local Sport and Recreation Job Plan
40 Transcript PN 335
41 Transcript PN 372
42 Exhibit 18 Extract of Staff handbook
43 Exhibit 18 Extract of Staff handbook
44 Transcript PN 91
45 Transcript PN 104
46 Exhibit 12 Tax Invoice Statements from Bartercard
47 Exhibit 1 Statement of Leslie Moodley paragraph X
Printed by authority of the Commonwealth Government Printer
<Price code {C}, PR531971 >
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