6FKHGXOH$

Nature of the Complaint / Statement of Material Facts

The Complainant, Service Employees International Union Local 2, Brewery, General and
ProIessional Workers` Union ('SEIU Local 2 or 'the Union), relies on the Iollowing material
facts in support of the present complaint:

The Parties

1) SEIU Local 2 is a trade union within the meaning of that term in the Trade Union Act ('the
Act).

2) The Respondent, JustUS! Coffee Roasters Co-op ('JustUS or 'the Employer), is a
company engaged in the operation of coffee shops at several locations in Nova Scotia,
including a location on Spring Garden Road in downtown Halifax.

Summary

3) The present unfair labour practice complaint concerns violations of the Act committed by the
Respondent, which occurred when it summarily dismissed two employees, known to be
supporters of SEIU Local 2, at its location at 5896 Spring Garden Road, in the midst of an
organizing drive.

Background

4) SEIU Local 2 commenced an organizing drive with respect to employees of JustUS working
at 5896 Spring Garden Road ('Spring Garden location) in Halifax at the end of December
2012.

5) Throughout the course oI January and February 2013, the Union`s organizer, Mr. Jason
Edwards, held a series of meetings and had numerous discussions with employees at the
Spring Garden location. During that period of time, a number of employees signed
membership cards with SEIU Local 2.

6) On March 10, 2013, as part of the continuing organizing drive, the vast majority of staff at
the Spring Garden location, along with Mr. Edwards, met with a representative of the
Canadian Labour Congress, to discuss unionization and the benefits of unionization, among
other things.

7) The following day, Ms. Alison XXXXX, the Team Lead (Store Manager) at the Spring
Garden location, along with Ms. Holly XXXXX, a Team Lead at another location, spoke
with most, if not all, employees at that location, including two employees that were the
Union`s key inside organizers, who would be terminated from employment shortly thereafter.
Ms. XXXXX explicitly asked employees if they were discussing unionization. Ms. XXXXX
also suggested that she had received a phone call 'Irom a concerned parent about the
Union`s organizing drive.

8) The Union`s organizing drive had been discussed openly among the workforce at the Spring
Garden location. Two employees, Shay XXXXX and Elijah XXXXX, were known by the
vast majority of staff to have been key inside organizers for the Union. In addition, both of
these individuals has signed union cards in front of other workers and openly discussed
unionization with SEIU Local 2 with other staff. The Respondent was well aware that these
individuals were internal leaders in the Union`s organizing drive.

9) On March 27, 2013, both Shay XXXXX and Elijah XXXXX were terminated from their
employment. At the time of the terminations, both individuals had been employed with the
Respondent for over a year, with Shay XXXXX being employed for more than 18 months.
Despite this, the Employer`s reasons Ior terminating Shay XXXXX were indicated as being
'not a right Iit Ior the company and 'not committed to the co-op. As Ior Elijah XXXXX,
the Employer gave multiple and completely improper reasons for the termination, such as
'physicality, 'tendonitis, 'Iuture plans, and 'personal stress. It was clear that the
Employer had no rational or defensible basis for the terminations and therefore provided the
reasons set out above.

10) The work location at issue is a small operation, employing 12 non-managerial employees
(until the recent terminations). In light oI this Iact, the eIIect oI the Employer`s actions is
magnified and creates a clear chill among the workforce, in terms of any continued viable
organizing eIIorts. The Employer`s actions were calculated and imposed specifically to send
a message to employees that they would be putting their employment in jeopardy if they
chose to support SEIU Local 2.

Submissions

11) In light of the foregoing, SEIU Local 2 submits that it is clear that the Respondent`s actions,
in terminating the Union`s two key internal organizers, were aimed at creating a chilling
eIIect that would, in eIIect, bring an end to the Union`s organizing drive. This action has
resulted in multiple violations of the Act, as set out on the attached Form 16.

12) As a result, the remedies requested in Schedule 'B are necessary in order to redress the
harm occasioned by the Respondent`s actions.


ALL OF WHI CH I S RESPECTFULLY SUBMI TTED





6FKHGXOH%

The Complainant, Service Employees International Union Local 2, Brewery, General &
ProIessional Workers` Union Local 2 ('SEIU Local 2), respectfully requests the following
remedies:

1) A declaration that the Respondent, JustUS! Coffee Roasters Co-op ('JustUS), has violated
ss. 53(1)(a), and/or 3(a)(i), and/or 3(b), and/or 3(e) of the Trade Union Act ('the Act).

2) An Order that JustUs cease and desist from violating the Act.

3) An Order that JustUs reinstate Shay XXXXX and Elijah XXXXX to their employment at
JustUS` Spring Garden location, with no loss of service, along with an Order that for
compensation Ior all losses incurred as a result oI the Respondent`s actions.

4) An Order that SEIU Local 2 be provided with an opportunity to meet with all non-managerial
employees for a period of thirty minutes on a date of its choosing, during regular working
hours, in a location that is near to, or within, the Respondent`s location.

5) An Order that the final decision in this matter be posted in a conspicuous location at the
workplace and remain posted for a period of thirty (30) days.

6) An Order that JustUS be required to post a notice in a conspicuous location at the workplace,
where it will come to the attention of all employees, signed by a senior official of JustUS,
acknowledging that it violated the Act, describing the manner in which it violated the Act,
and further advising that all employees have the right to freely choose their bargaining agent,
without restraint or interference.

7) Such other relief as the Complainant may request and the Board deems just.

6FKHGXOH$
Nature of the Complaint / Statement of Material Facts

The Complainant, Service Employees International Union Local 2, Brewery, General and
ProIessional Workers` Union ('SEIU Local 2 or 'the Union), relies on the Iollowing material
facts in support of the present complaint:

The Parties

1) SEIU Local 2 is a trade union within the meaning of that term in the Trade Union Act ('the
Act).

2) The Respondent, JustUS! Coffee Roasters Co-op ('JustUS or 'the Employer), is a
company engaged in the operation of coffee shops at several locations in Nova Scotia,
including a location on Spring Garden Road in downtown Halifax.

Summary

3) The present unfair labour practice complaint concerns violations of the Act committed by the
Respondent, which occurred when it summarily dismissed two employees, known to be
supporters of SEIU Local 2, at its location at 5896 Spring Garden Road, in the midst of an
organizing drive.

Background

4) SEIU Local 2 commenced an organizing drive with respect to employees of JustUS working
at 5896 Spring Garden Road ('Spring Garden location) in Halifax at the end of December
2012.

5) Throughout the course oI January and February 2013, the Union`s organizer, Mr. Jason
Edwards, held a series of meetings and had numerous discussions with employees at the
Spring Garden location. During that period of time, a number of employees signed
membership cards with SEIU Local 2.

6) On March 10, 2013, as part of the continuing organizing drive, the vast majority of staff at
the Spring Garden location, along with Mr. Edwards, met with a representative of the
Canadian Labour Congress, to discuss unionization and the benefits of unionization, among
other things.

7) The following day, Ms. Alison XXXXX, the Team Lead (Store Manager) at the Spring
Garden location, along with Ms. Holly XXXXX, a Team Lead at another location, spoke
with most, if not all, employees at that location, including two employees that were the
Union`s key inside organizers, who would be terminated from employment shortly thereafter.
Ms. XXXXX explicitly asked employees if they were discussing unionization. Ms. XXXXX
also suggested that she had received a phone call 'Irom a concerned parent about the
Union`s organizing drive.

8) The Union`s organizing drive had been discussed openly among the workforce at the Spring
Garden location. Two employees, Shay XXXXX and Elijah XXXXX, were known by the
vast majority of staff to have been key inside organizers for the Union. In addition, both of
these individuals has signed union cards in front of other workers and openly discussed
unionization with SEIU Local 2 with other staff. The Respondent was well aware that these
individuals were internal leaders in the Union`s organizing drive.

9) On March 27, 2013, both Shay XXXXX and Elijah XXXXX were terminated from their
employment. At the time of the terminations, both individuals had been employed with the
Respondent for over a year, with Shay XXXXX being employed for more than 18 months.
Despite this, the Employer`s reasons Ior terminating Shay XXXXX were indicated as being
'not a right Iit Ior the company and 'not committed to the co-op. As Ior Elijah XXXXX,
the Employer gave multiple and completely improper reasons for the termination, such as
'physicality, 'tendonitis, 'Iuture plans, and 'personal stress. It was clear that the
Employer had no rational or defensible basis for the terminations and therefore provided the
reasons set out above.

10) The work location at issue is a small operation, employing 12 non-managerial employees
(until the recent terminations). In light oI this Iact, the eIIect oI the Employer`s actions is
magnified and creates a clear chill among the workforce, in terms of any continued viable
organizing eIIorts. The Employer`s actions were calculated and imposed specifically to send
a message to employees that they would be putting their employment in jeopardy if they
chose to support SEIU Local 2.

Submissions

11) In light of the foregoing, SEIU Local 2 submits that it is clear that the Respondent`s actions,
in terminating the Union`s two key internal organizers, were aimed at creating a chilling
eIIect that would, in eIIect, bring an end to the Union`s organizing drive. This action has
resulted in multiple violations of the Act, as set out on the attached Form 16.

12) As a result, the remedies requested in Schedule 'B are necessary in order to redress the
harm occasioned by the Respondent`s actions.


ALL OF WHI CH I S RESPECTFULLY SUBMI TTED





6FKHGXOH%

The Complainant, Service Employees International Union Local 2, Brewery, General &
ProIessional Workers` Union Local 2 ('SEIU Local 2), respectfully requests the following
remedies:

1) A declaration that the Respondent, JustUS! Coffee Roasters Co-op ('JustUS), has violated
ss. 53(1)(a), and/or 3(a)(i), and/or 3(b), and/or 3(e) of the Trade Union Act ('the Act).

2) An Order that JustUs cease and desist from violating the Act.

3) An Order that JustUs reinstate Shay XXXXX and Elijah XXXXX to their employment at
JustUS` Spring Garden location, with no loss of service, along with an Order that for
compensation Ior all losses incurred as a result oI the Respondent`s actions.

4) An Order that SEIU Local 2 be provided with an opportunity to meet with all non-managerial
employees for a period of thirty minutes on a date of its choosing, during regular working
hours, in a location that is near to, or within, the Respondent`s location.

5) An Order that the final decision in this matter be posted in a conspicuous location at the
workplace and remain posted for a period of thirty (30) days.

6) An Order that JustUS be required to post a notice in a conspicuous location at the workplace,
where it will come to the attention of all employees, signed by a senior official of JustUS,
acknowledging that it violated the Act, describing the manner in which it violated the Act,
and further advising that all employees have the right to freely choose their bargaining agent,
without restraint or interference.

7) Such other relief as the Complainant may request and the Board deems just.