Human Rights Complaints: Smoking, hardwood floors, pets and - - PowerPoint PPT Presentation

Human Rights Complaints:

Smoking, hardwood floors, pets and…

Presented by: Elaine T. McCormack- Wilson McCormack Law Group

• G. Stephen Hamilton – Hammerberg Lawyers

Sat Harwood – Lesperance Mendes Lawyers Moderator: Jamie Bleay – Access Law Group

Disclaimer

• The legal work performed with respect to this seminar is for

general education purposes only and does not constitute legal advice in relation to any specific matter, circumstances or fact pattern to anyone, including those who take the

• seminar. Should anyone want legal advice pertaining to any

specific matter, circumstance or fact pattern then such party must enter into a solicitor/client relationship with a lawyer for such purpose.

Agenda

• Smoking and the Human Rights Tribunal and the Civil

Resolution Tribunal Presented by Elaine T. McCormack

• Accessibility and flooring issues and the Human Rights

Tribunal Presented by Sat Harwood

• Break (approximately 10:45 a.m.)
• Pets and the Human Rights Tribunal

Presented by G. Stephen Hamilton

Introduction

• Human Rights legislation, in one form or another, has been in

existence in British Columbia for many, many years. One of the earliest examples of the application of Human Rights legislation to condominiums in British Columbia occurred in 1994 (453048 British Columbia Ltd. v. Strata Plan KAS 1079, 43 R.P.R. (2d) 293 (B.C.S.C.)). This case involved a bylaw that prohibited any person under the age of 50 from occupying a strata lot for more than 21 days in any calendar year.

Introduction

• Since that case was heard by the tribunal in 1994 there have been

hundreds of human rights complaints filed with the B.C. Human Rights Tribunal involving complaints filed by various individuals against strata corporations, strata councils and individual strata council members,

• wners, tenants, employees and strata managers.
• Some of these complaints have involved tenancy and age restriction
• bylaws. Others have involved discrimination involving accommodation

based on physical or medical disabilities with fact patterns including complaints about cigarette smoking, therapy pets, cigarette smoking and family status.

Introduction

• For the most part complaints filed under the Human Rights

Code of B.C. (the “Code”) against strata corporations generally fall into two categories: – Discrimination involving accommodation, service and facility under section 8 of the Code; – Discrimination in tenancy premises under section 10.

Introduction

• Owners and tenants alike who feel that their strata council/strata

corporation has not responded to their complaints of discrimination can approach the Tribunal for a remedy.

• Complaints that are accepted by the Tribunal can, if not settled at

some point in time, end up at a hearing where witnesses are examined and evidence is considered by a Tribunal member.

• Today’s presentation will look at some of the different types of

complaints and the importance of the duty to accommodate persons who have, often unintentionally, been discriminated against.

SMOKING IN A STRATA

The Interaction of Laws, Bylaws, the Human Rights Tribunal, the Courts and the CRT Presented by Elaine T. McCormack

Law Governing Smoking in BC Strata Corporations

• Human Rights Code
• Common Law of Nuisance
• Tobacco and Vapour Products Control Act (as
• f September 1, 2016)
• Schedule of Standard Bylaws, Strata Property

Act

Human Rights Code

• Mental and physical disability
• Vast majority of smoking cases against strata corporations

involve non-smokers alleging physical disability affected by second hand smoke

• Fewer cases involve smoker alleging physical or mental

disability as a result of being highly addicted to nicotine, or disability requiring medical marijuana

• Courts, Tribunal and Arbitrators have broad and liberal

interpretation of disability

• Nicotine-addiction recognized as mental and physical

disability

• Cominco Ltd. v. United Steelworkers of America Local 9705

Human Rights Code

• Relevant Provisions for Strata Corporations:

Section 8: Discrimination in accommodation, service and facility Section 9: Discrimination in purchase of property Section 10: Discrimination in tenancy

Human Rights Code

• Teodora Leary v. Strata Plan VR 1001

September 21, 2016

• Blueprint for accommodation

Human Rights Code

• Teodora Leary v. Strata Plan VR 1001
• Section 8 second hand smoke case
• Many varying complaints about neighbours,

demanding and difficult owner

• Letters from doctor – trouble breathing,

inhaler, raspy speech, shortness of breath

• Complaints about upstairs and downstairs

neighbours smoking

Human Rights Code

• Teodora Leary v. Strata Plan VR 1001
• Findings

– Prima Facie case found – proven disability and adverse impact in relation to the provision of services – Claims exaggerated – Strata took minimal steps to address complaints – Once smoking confirmed by witness no further investigation to determine extent of problems and how they could be solved

Human Rights Code

• Teodora Leary v. Strata Plan VR 1001
• Frequent complaint letters
• Council often ignored complaints
• Council sent letter to smoker, hoped dryer vent

cleaning would help

• Witness offered but no consequences communicated

to Leary for not contacting witness

• Witness did attend January 2015 – smoke smell
• bvious
• Council sent out bulletin
• HVAC experts could not provide service sought
• Non-smoking bylaws failed

Human Rights Code

• Teodora Leary v. Strata Plan VR 1001
• Relief Granted

–Failure to accommodate –30 days to engage air quality specialist –Parties must work together to find solution –Pay $7,500.00 injury to dignity, feelings self respect –Post-judgment interest

Human Rights Code

• Teodora Leary v. Strata Plan VR 1001
• General Directions – Individual Must

–Advise council of disability –Provide sufficient medical information –Discuss possible solutions –Co-operate with professionals or other parties involved to explore accommodation solutions

Human Rights Code

• Teodora Leary v. Strata Plan VR 1001
• General Directions – Council Must

– Address requests for accommodation promptly, take them seriously – Gather info required to understand the nature and extent of need for accommodation – Keep medical information confidential – Obtain expert advice when needed

Human Rights Code

• Teodora Leary v. Strata Plan VR 1001
• General Directions – Council Must

– Take lead role in investigating solutions – Assess whether strata can implement solution – consider financial costs and needs of those with competing disabilities – Cannot contract out of Human Rights Code – can’t rely on vote of owners to deny accommodation – Council members working on process must be able to approach the issue with an attitude of respect – those who can’t may need to be removed from the process

Common Law of Nuisance

• Unreasonable interference with the use and

enjoyment of property

• Reconciles competing uses of land
• Court can grant injunction

Tobacco and Vapour Products Control Act

• Section 2.3 prohibits smoking or holding

lighted tobacco or using or holding an e- cigarette in a public building or structure or within 6 metres of a doorway, window or air intake

• Some municipalities have bylaws

Tobacco and Vapour Products Control Act

• Covers the common areas of condominiums

and apartment buildings

• Managers, owners, lessees and employers

liable for contraventions, except for any portion of the 6 metre area they are not in control over, and reasonable care and diligence to prevent a contravention is a defence

Tobacco and Vapour Products Control Act

Progressive Enforcement »Education, awareness, verbal warning, letter warning, ticketing, administrative hearing

Bylaws

• Section 3 of Standard Bylaws:

3 (1) An owner, tenant, occupant or visitor must not use a strata lot, the common property or common assets in a way that (a) causes a nuisance or hazard to another person, (b) causes unreasonable noise, (c) unreasonably interferes with the rights of other persons to use and enjoy the common property, common assets or another strata lot, (d) is illegal, or (e) is contrary to a purpose for which the strata lot or common property is intended as shown expressly or by necessary implication on or by the strata plan. …

• In some ways, more expansive than Tobacco and

Vapour Products Control Act

Bylaws

• Legal designation of area (e.g. common

property, limited common property, strata lot) is not as important as the actual layout of the strata complex.

• Entails a balancing of interests

Bylaws

• Kinds of smoking bylaws:

–Smoking prohibition bylaw –Smoking limitation bylaw

Bylaws

• Must comply with all legislation:

–Strata Property Act –Residential Tenancy Act –Human Rights Code

Bylaws

• Section 128: Amendment procedures

–¾ vote resolution at AGM or SGM –Mixed use developments

Rules

• Section 125
• Govern use, safety, and condition of common

property and common assets

• Rules can be used to prohibit smoking on

common property and/or common assets, but not in strata lots

• Eg. Smoking is prohibited while in common

property garden

Rules

• A rule ceases to have effect at first AGM held

after it is made unless it is ratified by a resolution passed by majority vote at or before that AGM

Grandfathering

• Bylaw / Rule
• New vs. existing strata corporations
• No bylaw at time of purchase
• Section 123, Strata Property Act
• Strata Plan NW 243 v. Hansen

Bylaw Enforcement

• Section 135 of the Strata Property Act outlines

mandatory bylaw enforcement procedures

• Important to ensure that all procedures are

followed before seeking remedy from Court or CRT

Bylaw Enforcement

• Once section 135 procedures have been

followed, and council decides bylaw has been contravened, council can: –Fine –Remedy the contravention –Deny access to recreational facility –Order to vacate (final resort)

Bylaw Enforcement

• Fines
• Section 130 of the Strata Property Act governs

fines

• Section 7.1 of Strata Property Regulation

identifies maximum frequency that strata corporation can impose a fine

• Smoking not a continuing contravention

Bylaw Enforcement

• Remedying the Contravention
• Section 133 of the Strata Property Act governs

Strata Corporation’s ability to require person to remedy the contravention –E.g. requiring owner to cover cost of cleaning up discarded cigarettes on common property, or aerating strata lot damaged by tobacco smoke

Bylaw Enforcement

• Denying Access to Recreational Facility
• Council can deny access to recreational facility

if owner, tenant, occupant or visitor breached bylaw or rule relating to recreational facility. –E.g. smoking in the entertainment room

Bylaw Enforcement

• Strata Corporation can go to:

(a) Small Claims to collect fines (b) Supreme Court of BC to collect fines, seek injunctive relief and for an Order to Vacate (c) Civil Resolutions Tribunal to collect fines and seek injunctive relief

Bylaw Enforcement

• Order to Vacate
• Final resort
• Sections 137 and 138, Strata Property Act
• Section 47, Residential Tenancy Act

Court

• Petition or Notice of Civil Claim can be commenced by various

parties

• Common law rights and provisions of the Strata Property Act
• Raith v. Coles 1984 BCJ No. 772 injunction granted ordering
• Mr. Cole to stop smoking cigars below Mr. and Mrs. Raith, an

elderly couple on the basis of the common law of nuisance

• The Owners, Strata Plan NW 1815 v. Aradi, 2016 BCSC 105 –

Order that owner stop smoking in his strata lot

• Order to Vacate if resident keeps breaching a reasonable and

significant bylaw and is in contempt of court

Civil Resolutions Tribunal

• Strata corporation must be a party
• The Owners, Strata Plan LMS 2900 v. Hardy

2016 CRTBC1- Owner prohibited from smoking tobacco or marijuana on any strata property, including the strata common asset, limited common property or common property,

• utdoors or indoors

Challenging Smoking Bylaws

Section 121, Strata Property Act

Unenforceable bylaws 121 (1) A bylaw is not enforceable to the extent that it (a) contravenes this Act, the regulations, the Human Rights Code or any other enactment or law, (b) destroys or modifies an easement created under section 69, or (c) prohibits or restricts the right of an owner of a strata lot to freely sell, lease, mortgage or otherwise dispose of the strata lot or an interest in the strata lot. (2) Subsection (1) (c) does not apply to (a) a bylaw under section 141 that prohibits or limits rentals, (b) a bylaw under section 122 relating to the sale of a strata lot, or (c) a bylaw restricting the age of persons who may reside in a strata lot.

Bylaw

ELEMENTS OF NON-SMOKING BYLAW (1)Define: (a) What is being prohibited; (b) Where is it being prohibited; and (c) Acknowledge need to consider accommodating smokers, particularly if smoking is being prohibited in strata lots.

Conclusion

• When a second hand smoker alleges disability,

council must deal with bylaw enforcement and accommodation pursuant to blueprint in Leary

• In cases of smoker alleging disability, council

must deal with bylaw enforcement and accommodation

QUESTIONS AND COMMENTS?

DISIABILITIES IN A STRATA Accessibility, flooring issues and the Human Rights Tribunal

Presented by Sat Harwood

Disability: Introduction

• Strata corporations have a duty not to discriminate

regarding the services they provide to persons with disabilities.

• This includes a duty to take all reasonable steps to avoid

negative treatment based on a personal characteristic.

• This is known as the duty to “accommodate”

Disability: Introduction

• In a successful disability complaint, strata corporations

may be ordered to accommodate (permit an owner to do something, undertake alterations) and to pay damages (compensation) for losses and suffering

• Typical disability examples include:

– Access to strata lots and buildings – Environmental conditions – Medical conditions or disabilities

Disability: The Test

• In a complaint under s. 8 of the Code, the initial burden is on

the complainant to establish, on a balance of probabilities:

– that the respondents discriminated against the complainant with respect to accommodation, services or facilities customarily available to the public because of the grounds alleged in the complaint.

Disability: The Test

• In the context of disabilities, the initial burden may be met if

the complainant establishes that: – The complainant suffers from a disability – The complainant received differential treatment with respect to accommodation, service or facility customarily available to public – The complainant’s disability was a factor in differential treatment

• If the complainant can establish these factors, the onus shifts

to the respondents to establish, on the balance of probabilities, that their conduct was justified

Disability – Types

• A disability is a physical conditions that affects or

is seen as affecting a person’s abilities.

• Disabilities may include:

– Addiction, amputation, asthma, acne, diabetes – Cancer, epilepsy, high blood pressure, obesity – Impairments to hearing, speech, vision and mobility.

• Does not include short-lived conditions (a cold)

Disability – Differential Treatment

• The fact that a complainant was treated the same way as all
• ther owners does not mean that he has failed to establish

differential or adverse treatment.

• Turnbull v. Famous Players Inc., [2001] O.H.R.B.I.D. No. 20:
• Claim involved wheelchair access to movie theatres

– "equal treatment based on disability means that persons with disabilities have a right to the provision of services and facilities in as dignified and full a way as able-bodied individuals".

Disability: Justification

• British Columbia (Superintendent of Motor Vehicles) v.

British Columbia

• In order to establish justification, respondent must prove that:

– it adopted the standard for a purpose or goal that is rationally connected to the function being performed – it adopted the standard in good faith, in the belief that it is necessary to the fulfilment of the purpose or goal – the standard is reasonably necessary to accomplish its purpose or goals, in the sense that the respondent cannot accommodate the complainant and others adversely affected by the standard without incurring undue hardship

Disability - Flooring

• Konieczna v. Strata Plan NW 2489
• Ms. Konieczna suffered from allergies and asthma
• Latex, mould and dust in carpeting aggravated her asthma
• At purchase, hardwood permitted with written permission
• Konieczna granted permission to install hardwood
• Installation delayed due to external wall repairs
• Strata passed bylaw to only permit wall-to-wall carpet
• Strata refused to grant her an exemption

Disability - Flooring

• Tribunal:
• Konieczna allowed to install hardwood at her expense
• SL had to be restored once she no longer resided at building
• $3,500 fine for injury to dignity, feelings and self-respect
• Tip: Draft bylaws with a view to accommodation of HR issues
• Tip: When administering bylaws, consider how bylaws affect

persons with disabilities

Disability: Intercom

• Williams v. Strata Plan LMS 768
• Ms. Williams was physically disabled
• Strata concerned about security issues with the building
• Strata modified the intercom so that from 8pm to 8am,
• wners could not buzz people into the building
• Owners needed to go to front door to let people in
• Williams concerned that if she needed medical attention at

night, she would be unable to buzz paramedics into building

Disability: Intercom

• Williams cont…
• Tribunal:
• Human Rights Code applied
• Accommodation would not create unacceptable security risk
• Strata ordered to return intercom to 24 hour a day use
• $1,500.00 to for injury to dignity, feelings and self respect
• Tip: Discrimination may arise from operational decisions

Disability: Parking

• Ganser v. Rosewood Estate Condominium Corp. (No. 1)
• Alberta Human Rights decision
• Ms. Ganser was 87 years old and suffered from blindness and

limited ability to walk or stand

• Originally assigned indoor parking stall which provided easy

access to door and elevator

• Did not own car, but stall regularly used by granddaughter and

caretakers who took her to appointments etc...

Disability: Parking

• Ganser Cont…
• Bylaws amended to introduce eligibility conditions for indoor

parking stalls

• Eligibility became conditional on:

– holding valid drivers license – owning vehicle – having insurance – driving vehicle regularly

Disability: Parking

• Ganser Cont…
• Panel:
• Panel had jurisdiction because any member of the public

could potentially be a resident owner

• Parking stall assignment bylaw was discriminatory on basis of

disability

• Provide suitable indoor parking stall
• $5,000 in damages for pain and suffering

Disability: Access Ramp

• Mahoney obo Holowaychuk v. Strata Plan NW332
• Ms. Holowaychuk was 91 years old
• Decreased mobility due to various medical issues
• Accessed her upper floor unit via elevator
• Elevator located up a short flight of stairs
• Strata refused to install an access ramp

Disability: Access Ramp

• Holowaychuk cont…
• Hearing:
• Was exiting via parkade ramp acceptable?
• Where could alterations be made?

– Lobby, fire door, new elevator from guest parking

• Who pays for alterations to lobby?

– $63,000 for automated door and ramp

Disability: Access Ramp

• Holowaychuk cont…
• Tribunal:
• Access via parkade ramp not reasonable accommodation
• Strata had not established undue hardship because cost of

alterations and amount of levy or CRF withdrawal unclear

• Strata to obtain plans, seek City approval and tender work
• Strata to undertake alterations on unit entitlement basis

provided costs are less than or equal to hearing estimate

• If no approval from City or costs exceed estimate, further

mediation and hearings before Tribunal

Disability: Sun Shades

• Shannon v. The Owners, Strata Plan KAS 1613
• Manufactured home strata located in Osoyoos, BC
• Mr. Shannon suffered from Obstructive pulmonary disease
• Conditions exacerbated by air conditioning
• Installed a solar screen on interior front window
• Solar screen was contrary to Strata bylaws
• Strata ordered that solar shade be removed

Disability: Sun Shades

Shannon cont.. Issues: Strata was never open to possibility of allowing sun shade Sun shade did not represent radical departure from Sun shade was not unsightly Strata failed to establish that there were reasonable alternatives Strata did not consider alternative prior to ordering sun shade removal

Disability: Sun Shades

Shannon v. The Owners, Strata Plan KAS 1613 Allowed to reinstall sun shade Compensation for cost of medical report Legal costs for improper conduct to be neogitated by parties but

• curt szied if matter not resllved

$2,500 for injury to dignity, feelings and self respect

Disability – Converting Living Space

• Calderoni v. Strata Council Plan No. K6
• Ms. Calderon requested permission to convert

carport into a second bedroom

• She maintained she was not able to climb

stairs due to a physical disability

• Strata denied her request on basis that:

– Concern modification could impact structure – Concern room could be used for illegal rental

Disability – Converting Living Space

• Ground floor had two existing rooms
• Kitchen would still be located upstairs
• Other units had internal stairway lifts
• Request not accompanied by any plans
• Tribunal dismissed claim – no prospect of success

Disability – Converting Living Space

• Tribunal:
• No explanation for:

– Why she could not convert downstairs rooms – Why she could not install an internal stairwell lift

• No compelling medical evidence
• Requiring applicant to follow bylaws is not per se

discriminatory

• Tip: Burden of accommodation belong to strata

but complainant’s must be open to alternatives

Disability – Building Repairs

• Menzies v. Strata Plan NW 2924
• Four building strata with 51 strata lots
• Ms. Menzies owned basement apartment
• Menzies claimed to:

– Suffer from chronic pain related to scoliosis and degenerative spinal problems – Have difficulty dealing with stress and suffers from depression and anxiety

Disability – Building Repairs

• Strata approved building envelope repairs
• Repairs involved replacement of aluminum

windows with low-E vinyl windows

• Menzies opposed to repairs and windows

from the start – did not mention disability

• Strata installed new windows

Disability – Building Repairs

• Strata received letter from Menzies lawyer
• Letter advised of disability

– New windows result in loss of light – No medical evidence provided

• Strata requested medical evidence
• Menzies refused unless Strata lawyer promised not to provide

medical info to strata council or committee

• Tribunal dismissed claim

Disability – Building Repairs

• No evidence that strata knew about disabilities before

windows installed

• Remainder of complaint was premature
• Refusal to provide requested information had hindered

Strata’s ability to determine whether to what extent accommodation necessary

• Tip: No duty to accommodate where respondent is not aware
• f a disability, and no accommodation is requested.

Disability: Autism

• Stacey and Mark Vogl
• Son autistic and has overgrowth condition
• Son is 3 years old and weighs 70 pounds
• Neighbours complaining about son jumping
• Strata issued letters threatening fines
• Complaint filed against owners and strata
• No decision issued
• Tip: Understanding of what constitutes a disability is evolving
• Tip: Be open to considering new types of ailments

Disability: Building Code

• Since at least 1998, the building code has included

provisions dealing with barrier free access to buildings

• The requirements include:

– Ramps to at least one main building entrance – Minimum dimensions for landings – Graspable door handles and handrails – Restrictions on changes in height of interior passageways – Minimum door clearances – Maximum heights for intercoms

• Older buildings may still be grandfathered

Disability: Questions

• Questions to Consider:
• Is the request an exclusive need of the owner, tenant
• r occupant?
• Are there medical conditions?
• Are there issues with access?
• Does the request fall under one of the recognized

categories of discrimination?

• How can the strata accommodate the owner, tenant, or
• ccupant?

Disabilities: Practice Points

• Like treatment is not equal treatment
• Be open to considering new or novel claims
• Seek reasonable solutions where possible
• If in doubt:

– Seek legal advice – Contact your strata insurance provider – Confirm your strata insurance covers Human Rights Claims

QUESTIONS AND COMMENTS?

Pets and the Human Rights Tribunal

Presented by G. Stephen Hamilton

Pets: Bylaw

• Standard bylaw 3(4) states:

An owner, tenant or occupant must not keep any pets on a strata lot other than one or more of the following: (a) a reasonable number of fish or other small aquarium animals; (b) a reasonable number of small caged mammals; (c) up to 2 caged birds; (d) one dog or one cat.

• However, a strata corporation may prohibit pets by bylaw:
• Types of pets
• Size of pets
• Breed of pet

Pets: Bylaw

• Standard bylaw 3(4) states:

An owner, tenant or occupant must not keep any pets on a strata lot other than one or more of the following: (a) a reasonable number of fish or other small aquarium animals; (b) a reasonable number of small caged mammals; (c) up to 2 caged birds; (d) one dog or one cat.

• However, a strata corporation may prohibit pets by bylaw:
• Types of pets
• Size of pets
• Breed of pet

Pets: Bylaw

Exceptions

• Section 123(1) of Strata Property Act – A bylaw that

prohibits pets does not apply to a pet living with an owner, tenant, or occupant at the time the bylaw is passed

• Section 123(1.01) of Strata Property Act – a bylaw that

prohibits a pet does not apply to a guide dog or service dog

• r a dog that is a member of a retired guide or service dog

team

• Human Rights Code

Pets: Human Rights Code

• Ordinarily the protected ground in issue will be

physical or mental disability

• Must be a causal link between a disability and the

adverse treatment

• The expression “causal link” does not import

intent by the respondent who has allegedly acted in a discriminatory manner

• Section 2 of the Code states “Discrimination in

contravention of this Code does not require an intention to contravene this Code.”

Pets: Human Rights Code

Judd v. Strata Plan LMS 737

• Mrs. Judd claimed that she suffered from anxiety and

depression and Mr. Judd stated that he suffered from hypertension, heart disease and arthritis.

• The Judds provided a letter from a doctor indicating that they

would benefit from having a pet and that the pet would provide stress relief and make the Judds happier and more content allowing them to live longer healthier lives with less need for medical intervention.

• The Strata Corporation denied the Judds’ request.

Pets: Human Rights Code

Judd v. Strata Plan LMS 737

• The Tribunal found that because the Judds had

not proven a link between the medical information respecting the beneficial impact of dog ownership and the adverse impact of being deprived the benefits of the dog.

• A pet must be shown to be medically necessary

and not merely generally beneficial.

• The Human Rights Tribunal dismissed the

complaint.

Pets: Human Rights Code

• Jones v. The Owners Strata Plan 1571 and others
• Bylaw prohibited pets, but allowed companion

pets of up to 15 lbs.

• Mr. Jones was legally blind and had a dog that

provided him assistance but was not a registered guide dog.

• Mr. Jones’ dog weighed more than 15 lbs.
• The Tribunal concluded that the Strata

Corporation had contravened s. 9 of the Code - Discrimination in purchase of property

Pets: Human Rights Code

• BH on behalf of CH v. Creekside Estates Strata Corp.

KAS 1707 and Robert Shaw – application dismissed as dog was not certified in Canada and there was a lack of evidence to show why an oversized dog was needed, rather than one in compliance with the bylaws

• Companion cats – Ontario Human Rights Code
• Accommodation
• Undue hardship
• Allergens
• Nuisance
• Burden of proof is on Strata Corporation

QUESTIONS AND COMMENTS?