Ms Breanda Nesbitt v Super Cheap Auto Pty Ltd
[2012] FWA 4994
•2 JULY 2012
[2012] FWA 4994 |
|
DECISION AND REASONS FOR DECISION |
Fair Work Act 2009
s.394 - Application for unfair dismissal remedy
Ms Breanda Nesbitt
v
Super Cheap Auto Pty Ltd
(U2011/1731)
COMMISSIONER CLOGHAN | PERTH, 2 JULY 2012 |
Unfair dismissal.
[1] On 24 August 2011, Ms Breanda Nesbitt (“the Applicant”) made application to Fair Work Australia (FWA) seeking a remedy for alleged unfair dismissal from her employment with Super Cheap Auto Pty Ltd trading as Super Cheap Auto (“the Employer”).
[2] Ms Nesbitt’s application is made pursuant to s.394 of the Fair Work Act 2009 (“the FW Act”).
[3] The application was unable to be resolved at conciliation and was referred to me for arbitration on 27 September 2011.
[4] The Employer’s response to Ms Nesbitt’s application is contained in a Form F3 dated 20 September 2011. Shortly put, the Employer alleges that:
● Ms Nesbitt’s employment was not terminated at the initiative of the Employer; and
● Ms Nesbitt did not resign because she was forced to do so because of conduct, or a course of conduct, engaged in by the Employer.
[5] Simply put, the Employer alleges that the Applicant resigned of her own accord after receiving a written warning.
[6] On 3 October 2011, I issued procedural directions for a hearing on 5 December 2011. The Employer, to the extent possible, complied with the procedural directions. The Applicant was unable to comply with the procedural directions. On 23 November 2011, the Applicant’s legal representative sought and was granted an adjournment of the scheduled hearing on 5 December 2011.
[7] Further procedural directions were issued on 7 March 2012 for a hearing on 3 April 2012. Following continued non compliance with the procedural directions, I forwarded correspondence to the Applicant on 16 March 2012. On 27 March 2012, the Tribunal received correspondence in which the Applicant sought and was granted an adjournment of the hearing on 3 April 2012.
[8] On 28 March 2012, I issued an Advice To Parties.
[9] On 30 March 2012, I issued amended procedural directions for a hearing on 6 June 2012 in Albany, Western Australia. The Applicant did not comply with the procedural directions.
[10] At the hearing on 6 June 2012, Ms Nesbitt was represented by Mr Guy Wroth and gave evidence on her own behalf. The Employer was represented by Ms Corrina Dowling, Employment Law Division, National Retail Association and evidence was given by:
● Mr Christopher Morton, Area Manager;
● Ms Shannon Suttle, People Relations Manager
● Ms Shirley Correia, People Relations Coach (WA); and
● Mr Daniel Ruffo, Albany Store Manager and formerly Assistant Store Manager.
[11] The Employer provided documentation to the Tribunal on 21 October 2011 which was relied upon and incorporated into proceedings. The Applicant relied upon her originating application. Having received this documentation, heard oral evidence and submissions, I reserved my decision. This is my decision and reasons for decision.
RELEVANT FACTS
[12] Ms Nesbitt commenced employment with the Employer on 26 March 2007.
[13] On 30 May 2010, Ms Nesbitt was appointed Manager of the Super Cheap Auto store in Albany.
[14] On 7 and 8 April 2011, Mr Morton, Area Manager, visited the store in Albany. Ms Nesbitt was not present during the visit as she had taken time off in lieu.
[15] During the visit, Mr Morton was made aware of staff concerns regarding Ms Nesbitt’s conduct as Store Manager.
[16] On 11 April 2011, Mr Morton telephoned Ms Nesbitt to advise her that he would be visiting the store to discuss with her the issues that had been raised by staff during his visit on 7 and 8 April 2011.
[17] On 21 April 2011, Mr Morton and Ms Correia, People Relations Coach (WA) met with Ms Nesbitt at the Albany store. The meeting was variously described as “coaching” or “mediation”. In my view the descriptor of the meeting is not to point; what matters is that the meeting was to discuss issues raised by staff during Mr Morton’s visit to Albany on 7 and 8 April 2011.
[18] On 10 May 2011, Mr Morton again visited the Albany store. During the visit, Mr Morton gave evidence that he was to provide notes to Ms Nesbitt on strategies to address issues raised by staff during his visit on 7 and 8 April 2011. The eventual date these notes were given to the Applicant is in dispute.
[19] On 13 and 14 June 2011, Mr Morton again attended the Albany store. During his visit he received unsolicited feedback on Ms Nesbitt’s improved approach in managing staff and was informed that the store was benefitting from such improvement 1.
[20] It is asserted by Mr Morton, but disputed by the Applicant, that sometime between January and March 2011 and on 9 or 10 May 2011, Ms Nesbitt was instructed not to re-employ a person to whom I will refer to as “Mr Man”. 2
[21] On 4 July 2011, Mr Man was re-employed.
[22] While the facts surrounding Mr Man’s re-employment are the subject of much dispute, there is no dispute that on 22 June 2011, Ms Nesbitt sent to the Employer’s People Services, an email with the subject heading, “Go Ahead Table - Mr Man - Casual - Albany Store”. The relevant parts of the email is as follows:
“Daniel [Mr Ruffo] put the wrong month for Mr Man’s start date.
It’s the 04/07/2011” 3
[23] Mr Morton became aware that Mr Man had been re-employed.
[24] On 27 June 2011, Mr Morton spoke to both Ms Nesbitt and Mr Ruffo and advised both of them that they would be required to attend a formal disciplinary meeting on 28 June 2011 concerning the re-employment of Mr Man.
[25] At the disciplinary meeting on 28 June 2011, both Ms Nesbitt and Mr Ruffo were issued with a “1st warning”.
[26] After receiving the “1st warning”, Ms Nesbitt did not return to work and provided medical certificates from 28 June 2011 to 13 August 2011.
[27] On 29 July 2011, Ms Nesbitt provided to the Employer the following letter of resignation:
“To whom it may concern,
It is with great regret that I have to inform you that I can no longer continue as the Store Manager of Supercheap Auto Albany.
Given the actions of the Area Manager, Mr Chris Morton, my position as the manager of the Albany store has become untenable and accordingly, I hereby give 2 week’s notice as from the date of this letter.
I am very disappointed to leave the company as I had a passion for my job and the company as a whole, but unfortunately I believe that I have been forced to resign from Supercheap Auto due to Mr Morton’s conduct.”
EMPLOYER’S CASE
[28] The Employer’s primary position is that Ms Nesbitt was not dismissed at the initiative of the Employer. Ms Nesbitt resigned from her employment on 29 July 2011.
[29] In her letter of resignation of employment, Ms Nesbitt states that her employment became untenable given the actions of her Area Manager, Mr Morton.
[30] The Employer highlights the fact that following a disciplinary meeting on 28 June 2011, in which Ms Nesbitt was given a “1st warning”, she did not return to work and was on personal leave up to and beyond the date of formally tendering her resignation.
[31] The “1st warning” given to the Applicant on 28 June 2011 was for not following a lawful and reasonable direction. Further, the Employer asserts that the meeting on 21 April 2011 referred to in paragraph [17] was not a disciplinary meeting but a coaching/mediation discussion which did not and would not constitute conduct or a course of conduct that would force a person to resign.
[32] Put shortly, the Employer contends that Ms Nesbitt resigned of her own accord on 29 July 2011 after receiving a written first warning. Accordingly, as a matter of law, the Applicant was not dismissed in accordance with subsection 386(1) of the FW Act and consequently, is not protected by the unfair dismissal provisions of the FW Act.
APPLICANT’S CASE
[33] Ms Nesbitt advised the Tribunal that she relied upon her originating application 4.
[34] In her originating application, Ms Nesbitt asserts:
“On or about 29 July 2011 I forwarded a letter of resignation to Super Cheap on the basis that my position as the manager of the Albany Super Cheap store had become untenable due to the actions of the Area Manager Mr Chris Morton”.
[35] Ms Nesbitt states that:
● on 11 April 2011, Mr Morton telephoned her and advised that he would be visiting the Albany store on 13 April 2011 to discuss, “accusations about me which he needed to action immediately”;
● on requesting details of the accusations, Mr Morton advised that he would “rather tell me face to face”;
● after a postponement of the scheduled meeting on 13 April 2011, Mr Morton attended the Albany store with Ms Correia on 21 April 2011. The meeting was described by Mr Morton as “mediation” and with the purpose of getting “to the bottom of all the issues that had been raised by other staff”;
● Mr Morton did not provide specifics of the allegations and only described them in general terms on 21 April 2011;
● she was given little opportunity to respond to the accusations;
● she received a verbal warning and that Mr Morton stated that if the issues did not cease, she would receive a written warning;
● Mr Morton would be “checking” with her staff regarding her performance;
● as a result of the decision by Mr Morton to discipline the Applicant and his assertion that he would check with her subordinate staff, “I believe my position as store manager became untenable”;
● she believed Mr Morton no longer trusted her and that, “I was answerable to my subordinate staff rather than be able to run the store”; and
● “due to the stress induced by Mr Morton’s actions and because my position with Super Cheap had become untenable, the only option I had was to resign from my position”.
RELEVANT STATUTORY FRAMEWORK
[36] Section 382 of the FW Act provides:
● 382 When a person is protected from unfair dismissal
A person is protected from unfair dismissal at a time if, at that time:
(a) the person is an employee who has completed a period of employment with his or her employer of at least the minimum employment period; and
(b) one or more of the following apply:
(i) a modern award covers the person;
(ii) an enterprise agreement applies to the person in relation to the employment;
(iii) the sum of the person’s annual rate of earnings, and such other amounts (if any) worked out in relation to the person in accordance with the regulations, is less than the high income threshold.
Note: High income threshold indexed to $118,100 from 1 July 2011
[37] As there is no dispute that Ms Nesbitt has met he provisions of s.382 of the FW Act, it is necessary to determine whether she has met the definition of “dismissed” in s.386 of the FW Act. The definition is as follows:
● 386 Meaning of dismissed
(1) A person has been dismissed if:
(a) the person’s employment with his or her employer has been terminated on the employer’s initiative; or
(b) the person has resigned from his or her employment, but was forced to do so because of conduct, or a course of conduct, engaged in by his or her employer.
(2) …
(3) …
CONSIDERATION
[38] Ms Nesbitt does not assert that her employment was terminated on the Employer’s initiative in accordance with paragraph 386(1)(a) of the FW Act.
[39] Further, there is no ambiguity in Ms Nesbitt’s letter of resignation that she resigned because of the “actions” and/or “conduct” of Mr Morton.
[40] The reason for Ms Nesbitt’s resignation is supported in her originating application which states that “as a result of the decision by Mr Morton to discipline me [on 21 April 2011] and his assertion that he would be checking with my subordinate staff regarding my performance, that my position as store manager became untenable” and “I felt that I could not return to the position as store manager as I believe that Mr Morton no longer trusted me” and finally, “due to the stress induced by Mr Morton’s actions...the only option I had was to resign from my position” (my emphasis).
[41] Notwithstanding this common ground between the letter of resignation and originating application, Ms Nesbitt, in cross examination, gave the following evidence:
“Okay, so it was purely the April meeting, was it [why she resigned]?---No, it was everything that happened from the beginning of April right through until I resigned.” 5
[42] In the first instance, it is necessary to consider whether Ms Nesbitt was forced to resign as a result of the conduct or course of conduct of Mr Morton. In doing so, it is necessary to assess all the evidence given to the Tribunal and determine, objectively, whether it is reasonable for the Applicant to be considered affected in the way she claims, and forced to resign.
[43] Mr Morton has been employed by the Employer since September 2003. Mr Morton interviewed and employed Ms Nesbitt in March 2007. There was no evidence given to the Tribunal of any adverse interaction between Ms Nesbitt and Mr Morton until April 2011.
[44] Mr Morton gave evidence that he visited the Albany store approximately once per month.
[45] During his visit on 7 and 8 April 2011, Mr Morton was advised of various complaints by staff concerning: Ms Nesbitt’s conduct in relation to her level of work during “load days”; the manner in which she spoke to staff and customers; changing staff rosters; and, particularly, the way Ms Taura was dealt with during sickness at work on the previous weekend.
[46] While Mr Morton gave evidence that he did not think Ms Nesbitt had done anything “wrong”, he considered it appropriate to raise with her the circumstances surrounding Ms Taura’s sickness and the overall perception of staff towards Ms Nesbitt 6. I am satisfied from the evidence that Mr Morton did not solicit the complaints and that his actions in raising the issues with Ms Nesbitt were appropriate.
[47] I note from Ms Nesbitt’s evidence that she was aware that Ms Taura had informed her and Mr Ruffo in writing, prior to Mr Morton’s visit, that they “had not handled her sickness in an appropriate or a compassionate manner” 7. Accordingly, the fact that this issue was raised with Mr Morton would not have come as a surprise to Ms Nesbitt.
[48] Mr Morton gave evidence that he contacted Ms Nesbitt by telephone on 11 April 2011 to let her know that he would be visiting the store to discuss the issues raised by staff on 7 and 8 April 2011. Mr Morton concedes that he did not particularise the issues and preferred to set them out to Ms Nesbitt in person 8.
[49] While Ms Nesbitt raises this lack of particularity as a ground for the dismissal being “harsh, unjust and unreasonable” in her originating application, I find that, in the circumstances, it was a reasonable course of action open to Mr Morton. In reaching this conclusion, I have borne in mind that the Applicant’s performance to that time was satisfactory and she had not been warned about any alleged performance defects or unsatisfactory performance. Further, the Employer had not received any formal complaints from staff on the issues raised during Mr Morton’s visit on 7 and 8 April 2011. Mr Morton, in his evidence, stated that he was concerned that these issues may be staff having a “whinge” about Ms Nesbitt without cause 9.
[50] Ms Nesbitt conceded in her evidence that giving staff feedback on their performance is normal and she had done so with her staff 10. Ms Nesbitt believed that she had a good relationship with her staff and when told of the issues raised by staff, was upset, hurt and considered herself worthless, especially after being advised by Mr Morton that he was going to “check on the progress of how I was going” following the meeting11.
[51] In the meeting, Ms Nesbitt gave evidence that, “I basically chose not to answer anything; or say anything” 12. This evidence by Ms Nesbitt has to be seen in the context that the meeting lasted approximately two (2) hours.
[52] Unlike other business fads, management ideas or quick fixes, the performance of those who manage or lead is always under scrutiny from work colleagues both above and below. Mr Morton could not, and did not, ignore the complaints he received from staff about Ms Nesbitt at the Albany store. In my view, he was right, in the circumstances, to be cautious with the complaints and put them to Ms Nesbitt in a face-to-face meeting and give her the opportunity to respond.
[53] Being told of criticisms of you by your staff is not a pleasant part of management. However, your response becomes critical. It is clear, in her own words, that Ms Nesbitt was hurt by such criticisms and adopted a defensive attitude of not engaging with Mr Morton during the discussion on 21 April 2011.
[54] I consider the criticisms by Ms Nesbitt of Mr Morton unreasonable. As Area Manager, he had a responsibility to raise the staff criticism with Ms Nesbitt. Mr Morton was right to seek Ms Nesbitt’s responses and provide, at the time, and subsequently, strategies to deal with the issues raised by staff. Further, it was appropriate for Mr Morton to check with staff, in the future, to see if those issues were still a problem, or alternatively, the discussion had succeeded in positive improvement in staff/manager relationships.
[55] It is important to note that subsequent to the discussion on 21 April 2011, Ms Nesbitt gave evidence that Mr Morton informed her that unsolicited feedback to him from staff, was that her relationship with staff had “greatly improved and the store was seeing the benefits of that” 13.
[56] Finally, in relation to the 21 April 2011 meeting, I find that it was not part of a disciplinary process and the Applicant received no documentation to indicate it was a disciplinary meeting. The Applicant gave evidence of this fact 14.
[57] In her application, the Applicant’s reasons why she was forced to resign are solely related to the 21 April 2011 meeting with Mr Morton.
[58] In summary and in response to those reasons, I find Mr Morton’s conduct leading up to and at the meeting to be appropriate and within the bounds of reasonableness in managing staff criticism of the Store Manager; I do not find his behaviour was sufficient conduct to force Ms Nesbitt to resign.
[59] Ms Nesbitt claims:
“As a result of the decision by Mr Morton to discipline me and his assertion that he would be checking on me with my subordinate staff regarding my performance, I believe my position as store manager became untenable.”
[60] I do not need to repeat what I have stated regarding whether it was a discipline procedure and “checking” with staff, but if the assertions that her position as Store Manager was untenable were acceptable, she should have resigned shortly after 21 April 2011 and not on 29 July 2011 while on sick leave following a first written warning on 28 June 2011.
[61] In view of the evidence that Ms Nesbitt claims that she was forced to resign because of “everything that happened from the beginning of April right through until I resigned” 15, it is necessary to consider those matters post the meeting with Mr Morton on 21 April 2011. In doing so, I shall commence with her evidence in cross examination as follows:
“...So as a result of that coaching session in April where no disciplinary action was taken against you; there was positive feedback after that meeting; you raised no further issues until you received a warning in June for conduct that you suggest you weren't involved in, and perhaps you think that it was unfair for you to have received the warning; you then resigned your employment. Are you suggesting that there was no other option for you but to resign your employment?---Yes.” 16
[62] From the evidence given to the Tribunal, with the exception of Mr Morton checking with Ms Nesbitt’s subordinates concerning her performance and the positive feedback given to the Applicant on her improvement, no further issues arose between Mr Morton and Ms Nesbitt until 27 June 2011.
[63] On 27 June 2011, Mr Morton telephoned Ms Nesbitt and Mr Ruffo concerning the re-employment of Mr Man. A disciplinary meeting was scheduled for 28 June 2011.
[64] Both Ms Nesbitt and Mr Ruffo knew the purpose of the meeting. Both knew it was part of a formal disciplinary process. Both were also aware that they could have a support person present. Both staff members were given the opportunity to respond to the allegations which were that they had failed to follow a lawful and reasonable direction of the Employer.
[65] Ms Nesbitt’s evidence is conflicting in relation to the re-employment of Mr Man.
[66] Firstly, the “Record of Disciplinary Meeting” sets out the key issue for discussion is, “in the period of January to March 2011 you [Ms Nesbitt] inquired into the process to re-hire a previous employee [Mr Man]. At the time you were advised by your Area Manager that the team member in question was not to be re-employed by SCA due to...On June 21st, steps were taken by your Assistant Store Manager to facilitate the re-employment of the team member. You were aware, at this time, that this would result in a breach of the directive given by your Area Manager. In failing to halt, or further enquire into the re-employment of the team member [Mr Man] by your ASM, you have failed to comply with a reasonable directive from your manager.” 17
[67] Ms Nesbitt signed the Record of Disciplinary Meeting and the issuance of a first warning.
[68] A similar allegation, record and disciplinary penalty was also given to Mr Ruffo.
[69] In contract to the Record of Disciplinary Meeting, Ms Nesbitt gave evidence that Mr Morton had never told her not to employ Mr Man directly and that she “had nothing to do with launching the position or approving his application or communicating with him to call him in [for] an interview or anything like that” 18.
[70] Mr Ruffo gave evidence that on 21 June 2011, “Ms Nesbitt and I met with [Mr Man] to discuss his return to work at the Albany store” 19. This evidence was tested and not disturbed in cross-examination. Further, Mr Ruffo gave evidence that this interview with Mr Man was preceded by a discussion between Mr Ruffo and Ms Nesbitt concerning Mr Man’s re-employment.
[71] I am satisfied on the evidence that Ms Nesbitt actively took part in the re-employment of Mr Man both prior to and during the recruitment process as documented by her email of 22 June 2011 (which clarified Mr Man’s commencement date of employment). Further, I am satisfied, on the evidence, that this was contrary to the direction of her Area Manager.
[72] In conclusion, it is necessary to express the view that the reasons why the Employer did not want Mr Man re-employed are not at issue. Nor is it an issue whether he is still employed and performing successfully. What is at issue is that Mr Morton gave a direction that Mr Man was not to be employed and Ms Nesbitt actively participated in his re-employment.
[73] Ms Nesbitt’s evidence in allowing Mr Man to be re-employed was to state that she “cave[d] in” to her second and third in charge and “gave them exactly what they wanted, which was Mr Man back in the store” 20. Unfortunately while supportive of her immediate subordinates, it inevitably led to the subsequent disciplinary process. Doing the right thing by your subordinates does not always align with doing the right thing by your immediate manager.
[74] Within hours of receiving the first written warning as part of the disciplinary process, Ms Nesbitt saw a medical practitioner and remained on sick leave until she tendered her resignation on 27 July 2011.
[75] Between 28 June and 27 July 2011, Ms Nesbitt had one contact with her Employer concerning her pay. Also during that period, Mr Morton attempted to contact Ms Nesbitt by telephone. Mr Morton’s telephone calls were to the effect of enquiring how she was and what was happening with her employment; Ms Nesbitt did not return the telephone calls.
[76] Ms Nesbitt resigned on 27 July 2011.
CONCLUSION
[77] In considering this application, I have adopted the principles in Ross Davidson v The Commonwealth of Australia[2011] FWAFB 6265 in which the Full Bench affirmed Commissioner Deagan’s reference, in the first instance, to extracts from P O’Meara v Stanley Work Pty Ltd (2006) PR973462 at paragraph [23] which reads:
“In our view the full statement of reasons in Mohazab which we have set out together with the further explanation by Moore J in Rheinberger and the decisions of Full Benches of this commission in Pawel and ABB Engineering require that there to be some action on the part of the employer which is either intended to bring the employment to an end or has the probable result of bringing the employment relationship to an end. It is not simply a question of whether “the act of the employer [resulted] directly or consequentially in the termination of the employment”. Decisions which adopt the shorter formulation of the reasons for decision should be treated with some caution as they may not give full weight to the decision in Mohazab. In determining whether a termination was at the initiative of the employer an objective analysis of the employer’s conduct is required to determine whether it was of such a nature that resignation was the probable result or that the appellant had no effective or real choice but to resign.”
[78] In my view, what is required is an objective analysis of the employer’s conduct in relation to the employee and not just the subjective view of the complaining party.
[79] To substantiate the claim that an employee was forced to resign because of conduct or course of conduct engaged in by the employer, it is necessary, in my view, for the employee to demonstrate that the employer’s conduct is such that an impartial observer would state that the behaviour is unreasonable and inconsistent with maintaining an employment relationship. It is insufficient, in my view, for an employee to state “this happened” and I resigned, therefore whatever happened forced me to resign; such a circular argument would lead to employees self defining the meaning of being forced to resign.
[80] Applying the test in Mohazab v Dick Smith Electronics Pty Ltd [No 2] (1995) 62 IR 200, I am unable to discern, on an objective analysis that the conduct of Mr Morton led the Applicant to have no choice but to resign. Simply put, Mr Morton’s actions leading up to, and at the meeting on 21 April 2011, were reasonable and appropriate in addressing the Albany store staff complaints. Whatever shortcomings the Applicant perceived in the process, they did not undermine the overall approach of the Employer to set out the complaints and seek a response from Ms Nesbitt. It is notable that the process resulted in an improvement in manager/staff relationships which was relayed back to the Applicant.
[81] Finally, while many organisations have different disciplinary processes, the Employer’s disciplinary process is to improve performance and behaviour and is constructed in a graduated form of disciplinary action.
[82] A formal “1st Warning” is the second least form of disciplinary action.
[83] It is notable that the Employer’s disciplinary process includes, within the definition of “serious misconduct”, refusal to carry out lawful and reasonable instructions. Such conduct may result in termination without warning or notice. Notwithstanding, the Employer adopted, and in my view appropriately, the lesser penalty of a “1st Warning”.
[84] For the reasons I have set out above, I am unable to agree with the Applicant that the Employer’s actions intended to bring the employment relationship to an end or had the probable result of bringing it to an end. There can be no argument that an employer is legally entitled to evaluate the performance of its employees, having done so on this occasion, it found Ms Nesbitt wanting but it was at the lower end of unacceptable performance and not fatal to her ongoing employment.
[85] I find that Ms Nesbitt, after almost no contact with the Employer for nearly one month, came to the decision to resign. The decision to resign was not forced upon her but one of her own choice. As a consequence of her employment not being terminated at the initiative of the Employer, the Applicant is not protected by the unfair dismissal provisions of the FW Act. Accordingly, the application must be, and is, dismissed for failing to meet the statutory requirements of s.385(a) of the FW Act An order will issue to this effect.
COMMISSIONER
Appearances:
Ms B Nesbitt, the Applicant.
Ms C Dowling, on behalf of the Respondent.
Hearing details:
2012:
Albany, Western Australia
6 June.
1 PN 243
2 Exhibit R4 and PN 296
3 Exhibit R4
4 PN 329 and PN 344
5 PN 322
6 Exhibit R4
7 PN 216
8 Exhibit R4
9 Exhibit R4
10 PN 234
11 PN 242
12 PN 252
13 PN 243
14 PN 282
15 PN 322
16 PN 312
17 Exhibit R4
18 PN 299
19 Exhibit R5
20 PN 300
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