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April 12, 2013 Via facsimile (902) 424-1744 Ms. Mary-Lou Stewart Chief Executive Officer Nova Scotia Labour Relations Board 5151 Terminal Road, 7th Floor PO Box 697 Halifax, Nova Scotia B3J 2T8 Dear Ms. Stewart and Ms. Crowe: Re: Service Employees International Union Local 2, Brewery, General & Professional Workers Union (the Applicant) and JustUS! Coffee Roasters Co-op (the Respondent) Unfair Labour Practice Complaint LB-0356 As you know, I am legal counsel to the Service Employees International Union Local 2, Brewery, General and Professional Workers Union (the Union or SEIU Local 2). The above-noted complaint was filed with the Board on March 28, 2013. Subsequent to the filing of the complaint, SEIU Local 2 has become aware of a further violation of the Act on the part of the Respondent. As a result, the Applicant seeks to amend its complaint to include the following particulars: 1. On Sunday, April 7, 2013, Charlie Huntley, an employee of the Respondent at the Spring Garden location, was scheduled to work a shift that involved closing the cafe at 5 pm. Another employee had been scheduled to work the same closing shift as well, but ultimately did not work that shift. While at least two other employees had volunteered to work the closing shift, Ms. Larsen, the store manager, decided that she would work the closing shift herself. Ms. Larsen had also opened the cafe earlier that day. It was atypical for the same employee to both open and close the cafe. 2. Charlie Huntley was known to be a supporter of SEIU Local 2, having previously been quoted in the Unions literature. Accordingly, the Union asserts that Ms. Larsens decision to work the closing shift on April 7th was motivated by a desire to communicate
2600 Skymark Ave. Bldg 2, Suite 200 Mississauga, ON L4W 5B2 1-800-663-6841 905-602-7477 Fax 905-602-7476 572 Arthur St. W. P.O. Box 32001 Thunder Bay, ON P7E 0A1 1-888-887-5343 807-473-9651 Fax 807-473-3632 331 Cooper St. Suite 503 Ottawa, ON K2P 0G5 613-567-3528 Fax 613-567-0924 7820 Edmonds St. Suite 301 Burnaby, BC V3N 1B8 604-540-7774 Fax 604-540-7779 163 Wyse Road, Lower Level Dartmouth, NS B3A 1M5 902-455-1095 Fax 902-455-1855

Ms. Heather Crowe Program Officer Nova Scotia Labour Relations Board 5151 Terminal Road, 7th Floor PO Box 697 Halifax, Nova Scotia B3J 2T8

www.seiulocal2.ca Representing Canadian workers since 1902

directly with Charlie about the Union and its organizing drive, in order to disparage the Union and discourage Charlie from supporting SEIU Local 2. 3. At or around 5:15 pm, once all of the customers had exited the cafe, Ms. Larsen engaged Charlie in a lengthy conversation about the Union and its organizing drive, in what was often an aggressive and argumentative tone. She made critical statements about the Unions motivation and interest(s) in organizing the cafe, including the suggestion that the Unions organizing efforts were based on a desire for monetary gain on the part of the Union. At or around 5:30 p.m., Ms. Larsen clearly articulated to Charlie that if the employees at the Spring Garden cafe unionized, there would be consequences to doing so, including the fact that employees would lose their annual profit sharing payments. 4. The statement of Ms. Larsen made it clear that employees would be penalized monetarily for having exercised rights under the Act. This contravenes the unfair practices provisions of the Act. I trust the foregoing is satisfactory. Should you have any questions or concerns, please feel free to contact me directly at (905) 602-7477 x. 209, by fax to (905) 602-7476, or by email at bprice@seiulocal2.ca. Yours truly,

Bruce Price Legal Counsel

2600 Skymark Ave. Bldg 2, Suite 200 Mississauga, ON L4W 5B2 1-800-663-6841 905-602-7477 Fax 905-602-7476

572 Arthur St. W. P.O. Box 32001 Thunder Bay, ON P7E 0A1 1-888-887-5343 807-473-9651 Fax 807-473-3632

331 Cooper St. Suite 503 Ottawa, ON K2P 0G5 613-567-3528 Fax 613-567-0924

7820 Edmonds St. Suite 301 Burnaby, BC V3N 1B8 604-540-7774 Fax 604-540-7779

163 Wyse Road, Lower Level Dartmouth, NS B3A 1M5 902-455-1095 Fax 902-455-1855