Docket: T-1510-17
Citation: 2018 FC 223
[ENGLISH TRANSLATION]
Ottawa, Ontario, February 28, 2018
Present: The Honourable Mr. Justice Martineau
| BETWEEN:
|
| MICHEL THIBODEAU
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| Applicant
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| and
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| HALIFAX INTERNATIONAL AIRPORT AUTHORITY
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| Respondent
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ORDER AND REASONS
[1] On October 5, 2017, the applicant, Michel Thibodeau, filed an application with this Court under section 77 of the Official Languages Act, RSC 1985, c. 31 (4th Supp.) [OLA], which reproaches the respondent, the Halifax International Airport Authority [HIAA], for past and current non-compliance as a federal institution with the quasi-constitutional obligations set forth in Part IV of the OLA (Communications with and Services to the Public). This involves determining whether the Court must strike certain paragraphs of the affidavit that was cited in support of the application in question on the ground that they are not relevant and either contain inadmissible hearsay or are identified by settlement privilege.
Background
[2] The applicant complained to the Commissioner of Official Languages [the Commissioner] that the HIAA did not comply with the language obligations set forth in section 23 of the OLA to ensure that services to travellers at the Halifax Stanfield International Airport [the Airport] are in both official languages. In fact, on July 26, 2016, the applicant and his spouse were not served in French at an information counter at the airport when a display clearly indicated that the service was available in both official languages [the incident]. Those last facts were not denied by the federal institution.
[3] In fact, information services at airport counters were offered and continue to be offered to the travelling public by a team of volunteers who are recruited and trained by the HIAA. In its final report in August 2017, the Acting Commissioner found that the shortage of services in French was flagrant and systemic. In fact, the investigation revealed that the total number of volunteers at airport counters was 96 and of that number, only two were identified as being bilingual. However, the HIAA acknowledged that the volunteers who were present at the information counter where the applicant and his spouse had arrived were all unilingual Anglophone, meaning that they were unable to serve them or other travellers in French.
[4] Finding that the applicant’s complaint had merit and that the HIAA had not complied with the obligations set forth in Part IV (including the spirit of the OLA), the Acting Commissioner recommended that the HIAA create and implement an action plan as soon as possible and no later than six months after receiving the final report for recruiting volunteers who can offer service in French at the airport’s information counters and continue to give monthly reminders of the importance of compliance with the OLA to volunteers who serve the public.
Application for relief from the Court
[5] The applicant is now seeking a statement from the Court such that the respondent did not meet its language obligations. He also seeks an order forcing the respondent to change its operating processes, such that in the future, the service provided to travellers at the airport’s information counters is a service of equal quality in both official languages. Furthermore, the applicant is seeking the payment of the sum of $1,500 in damages, along with a letter of apology and any other remedy that the Court deems appropriate and just in light of the circumstances.
[6] In support of his application for relief, the applicant promptly served the respondent with an affidavit from himself, dated November 16, 2017, which details the facts surrounding the incident, the investigation conducted by the Acting Commissioner, the findings and recommendations from that investigation, the communications that the applicant has since had with the respondent, and also cites excerpts from reports and newspaper articles that detail a flagrant and systemic problem in the lack of services in French at the airport’s information counters.
[7] The respondent, who is opposed to the request, has not yet served its affidavits on the applicant. Instead, on December 20, 2017, it filed this motion with the Court to strike certain paragraphs from the applicant’s affidavit—and exclude some documentary evidence—on the ground that they are not relevant and contain either communications that are subject to the settlement privilege or are inadmissible hearsay. At the same time, since the deadline for serving its affidavits is now passed, the respondent also asks the Court to extend the deadline for serving its affidavits and documentary evidence.
[8] This motion to strike is dismissed.
Applicable principles for striking allegations from an affidavit
[9] We must begin by remembering that the Federal Court has the authority to hear the applicant’s remedy and, if it finds that the respondent did not comply with the OLA, may grant such remedy as it considers appropriate and just in the circumstances (subsections 77(1) and (4) of the OLA). In the meantime, before the matter is determined by the trial judge, it is the provisions found in Part 5 – Applications of the Federal Courts Rules, SOR/98-106 [the Rules] that govern the procedure. It is also evidence: unless this application becomes an action (which is not the case here), the Court must rule on the remedy as soon as possible and according to a summary procedure. In that last case, the Court does not hear witnesses. All the evidence is submitted through affidavits.
[10] By analogy, in the context of an application for judicial review, a judge who is hearing motions must only resort to his or her discretionary authority to strike all or part of an affidavit in exceptional circumstances (see Gravel v Telus Communications Inc., 2011 FCA 14 at para 5 [Gravel]). To repeat the words of Létourneau J.: “The reason is quite simple: applications for judicial review must quickly proceed on the merits, and the procedural impacts of the nature of a motion to strike are to delay unduly and, more often than not, needlessly, a decision on the merits”
(Gravel at para 5). Such an authority can in particular be exercised when the allegations in question are abusive or clearly irrelevant, when they contain opinion, argument or legal conclusions or where the Court is convinced that admissibility would be better resolved at an early stage so as to allow the hearing to proceed in a timely and orderly fashion (see Canada (Attorney General) v Quadrini, 2010 FCA 47 at para 18).
[11] In addition, when striking paragraphs of an affidavit and certain supporting items because they contain inadmissible hearsay, such a motion should only be brought where the hearsay goes to a controversial issue, where the hearsay can be clearly shown and where prejudice by leaving the matter for disposition at trial can be demonstrated (see Canadian Tire Corp. Ltd. v. P.S. Partsource Inc., 2001 FCA 8 at para 18 [Partsource]). Similarly, allegations and items containing communications that are protected by settlement privilege can also be struck (for example, see Remo Imports Ltd. v Jaguar Cars Ltd., 2005 FC 870 at paras 18–19). Overall, during a motion to strike, the judge should only use his or her discretionary authority in the most evident cases (for example, see Partsource at para 17). But such is not the case here.
Hearsay evidence
[12] The respondent submits that exhibits 8 and 10 from the applicant’s affidavit from November 16, 2017—articles taken from Radio-Canada’s Web site and paragraphs 23 and 25 that refer to it—should be struck because they constitute inadmissible hearsay. The paragraphs in question read as follows:
[TRANSLATION]
23. The problem of a lack of French service at the Halifax international airport was also documented in the news. For an example, see this Radio-Canada article from January 22, 2019 in Exhibit 8 of this affidavit titled “Halifax fait piètre figure”, in which we can read:
“The international airport in Halifax, Nova Scotia is recognized worldwide for the quality of its passenger services, but it is among the worst in Canada for offering services in French,” according to a new report from the Commission of Official Languages, Graham Fraser.
25. A few years later, on August 10, 2012, in another Radio-Canada article, in exhibit 10 of this affidavit, we can see that volunteers at the Halifax international airport are unable to serve people in French:
“Volunteers, for example, cannot answer people in French, but they must offer them an alternative solution,” explained the airport’s communications manager, Jennifer Delorey Lyon.
[13] According to the respondent, those articles are hearsay and the applicant is clearly trying to admit them as evidence from their content. They do not meet the necessary criteria of reliability and necessity to make an exception to prohibiting hearsay evidence.
[14] The applicant retorted that the articles are relevant and should be admitted as evidence. Firstly, they show that the respondent was already having difficulty with offering the service in French in 2010 and in 2012. However, being able to show the existence of a problem that has persisted over time is important for the Court to be able to award a full, effective and meaningful remedy. What is more, the articles give comments from the respondent’s own senior executives: it is free to examine its senior executives and submit countary evidence in its affidavits. If the articles are in fact hearsay, the applicant first submits that they fulfill the criteria of reliability and necessity. Whatever the case may be, they may also be admissible due to section 79 of the OLA, which allows for the admission into evidence of information regarding similar complaints for the same federal institution and thus prevail over the other rules of evidence (see Thibodeau v Air Canada, 2005 FC 1156 at para 83, aff. by 2007 FCA 115 [Thibodeau FC 2005]).
[15] I agree with the applicant. The procedural approach advocated by the respondent has no place here. I would also recall the remarks of Décary J. in Canada (Commissioner of Official Languages) v Air Canada, 88 ACWS (3rd) 995 at paras 16–17, [1999] FCJ no. 738 at paras 16–17 (QL)(FCA):
[16] The Act itself provides that a particular complaint may serve as the gateway into a federal institution’s system as a whole. This was Parliament’s intention, as a means of giving more teeth to an enactment, the Official Languages Act, which serves as a special tool for the recognition, affirmation and extension of the linguistic rights recognized by the Canadian Charter of Rights and Freedoms.
[17] In other words, this is an area in which an overly litigious approach is particularly inappropriate. The Act itself invites one to go beyond the particular case to the general, and a federal institution against which not one but several complaints are brought can hardly feign surprise or cry injustice if the Commissioner, in an investigation, in his report, in his findings, or in the context of a court proceeding, was quick to transform the argument on a particular case into a general argument.
[16] But there is more to the subject. We must return to the definition of hearsay evidence. Hearsay includes out-of-court statements from a third party introduced as evidence by a third party or an exhibit for which the purpose is to prove the veracity of their contents, that is, the veracity of the facts that are reported in it, since it is impossible to cross-examine the declarant (for examples, see R v Khelawon, 2006 SCC 57 at para 35 [Khelawon]; R v Starr, 2000 SCC 40 at paras 159–161 [Starr]). On the contrary, the statement is not hearsay if it is filed simply to prove that it was done (see in particular R v O’Brien (1977), [1978] 1 S.C.R. 591 at p 593, 76 DLR (3rd) 513). Therefore, the first step of the analysis consists of finding the purpose for which the out-of-court statement is tendered (see Khelawon at para 36; see also Express File Inc. v HRB Royalty Inc., 2003 FC 924 at para 8, citing Starr at paras 162 and 165, aff. by 2004 FCA 341).
[17] Therefore, I must ask myself whether, as a judge hearing motions, it is appropriate at this stage of proceedings to exercise the Court’s discretion in the manner desired by the respondent, that being to strike the allegations in question and to purely and simply exclude the articles in question from the evidence on record. In my view, I do not believe that this is the case, since it is not clear that the allegations and articles in question constitute inadmissible hearsay. In fact, they do not appear to have been filed to prove their content, but instead to reveal a repeated breach over time by the by the respondent of the language requirements of Part IV of the OLA. In my view, this is exactly the type of generic evidence that Parliament wants to see admitted as evidence in this type of public law remedy involving a federal institution in its relations with the public.
[18] Therefore, this allows the complainants to present the tribunal with the complete context of the linguistic situation in the federal institution against which they are complaining, and to establish the existence of a systemic problem that has already persisted for some time (see Canada (Commissioner of Official Languages) v Air Canada, 77 ACWS (3rd) 1166 at paras 17–22, [1997] FCJ No. 1834 (QL)(FCTD) [Air Canada 1997 FC with referrals to the ACWS]; Lavigne v Canada Post Corporation, 2009 FC 756 at para 32; Thibodeau 2005 FC at para 53). Otherwise, Parliament would not have enacted section 79 of the OLA, which reads as follows:
| In proceedings under this Part relating to a complaint against a federal institution, the Court may admit as evidence information relating to any similar complaint under this Act in respect of the same federal institution.
|
Sont recevables en preuve dans les recours les renseignements portant sur des plaintes de même nature concernant une même institution fédérale.
|
[19] In addition, section 79 of the OLA is a unique provision, showing Parliament’s intention to make an exception in the traditional rules of evidence in order to allow the tribunal to offer the most complete and appropriate remedy (see Thibodeau 2005 FC at paras 82–83). In fact, in the context of an application under the OLA, the complainant can report on a general or even systemic situation, surpassing the facts that he or she personally knows. In this case, it is services that must be offered in both official languages to the travelling public as a whole. This highlights the importance and quality of services in French that are in fact offered by the federal institution: a context that extends over several years, during which, according to the applicant, the respondent did not comply with its obligations under Part IV of the Act.
[20] For example, if we take the statement by communications manager Jennifer Delorey Lyon found in paragraph 25 of the applicant’s affidavit, the purpose is not to prove that in fact in 2012, the volunteers had to offer an alternative service, but rather than in 2012, the respondent was already concerned about the linguistic issue. In the same way, with respect to the remarks of the Commissioner of Official Languages in paragraph 23 of the affidavit and in exhibit 8, this is not to prove the veracity of his remarks, but instead the simple fact that he had already considered the situation of the respondent’s respect for language rights at the time.
[21] In my view, there is ground to admit exhibits 8 and 10 as evidence. That evidence may prove useful for demonstrating that, already in 2010 and 2012, the media and the respondent’s representatives were concerned about the linguistic issue, and with it, support the applicant’s general allegation in which there were public denunciations of the repeated breaches of Part IV obligations in the OLA. It is up to the judge presiding at the hearing on the merits of the motion to assess the probative force of the articles in question in light of all of the evidence on record (see Air Canada 1997 FC at para 19).
[22] I would also mention in passing that exhibits 8 and 10 contain several statements from the respondent’s own representatives. Even if this were in fact hearsay, those statements can constitute out-of-court statements (see in particular R v Evans, [1993] 3 S.C.R. 653 at page 664, 108 DLR (4th) 32). It must also be remembered that the rule prohibiting hearsay is based on the difficulty of verifying the declarant’s statement, given that it is impossible to cross-examine him or her (see Khelawon at para 35). It is difficult to imagine how the respondent can claim to be unable to cross-examine its own representatives. As the applicant highlights, it is free to file affidavits that respond to the allegations, which, it must be remembered, it did not do by the deadlines assigned to it. In this case, it is not a flagrant case that would warrant that I exercise discretion to once again strike an inappropriate allegation from an affidavit. Quite the contrary, the articles in question are exactly the type of admissible evidence to verify compliance with Part IV obligations in the OLA, those being to ensure the equality of service in English and French and to ensure the fullest protection of those quasi-constitutional guarantees.
Settlement privilege
[23] Now aiming to have paragraph 15 struck from the affidavit of November 16, 2017, the respondent cites Rules 422, which we find in Part 11 – Costs. Paragraph 15 reads as follows:
[TRANSLATION]
15. On November 1, 2017, counsel for the HIAA sent me an offer to settle, which I declined. I cannot attach a copy of this settlement offer to this affidavit because according to counsel for the HIAA, the contents of the offer “cannot be disclosed or used before any forum whatsoever.”
[24] Rule 422 specifies that no communication respecting an offer to settle shall be made to the Court until all questions of liability and the relief to be granted, other than costs, have been determined. The respondent submits that Rule 422 goes as far as protecting the disclosure of the very existence of an offer to settle. However, contrary to what the respondent claims, neither Rule 422 nor the settlement privilege appear to prevent the disclosure of the existence of an offer to settle. The privilege instead prevents the disclosure of the contents of such an offer (see Union Carbide v Bombardier Inc, 2014 SCC 35 at para 31 [Union Carbide]).
[25] In this case, there is no need strike paragraph 15, which does not reveal any offer to settle.
[26] Second, this is determining whether paragraph 13 (including the email attached in exhibit 3) of the affidavit from November 16, 2017 contains communications that are subject to settlement privilege as the respondent claims, which is challenged by the applicant.
[27] Paragraph 13 of the affidavit of November 16, 2017 reads as follows:
[TRANSLATION]
13. On September 27, [2017], I received an email from Ms. Valerie Seager from the HIAA declining the out-of-court settlement and at the same time saying that “We deeply regret that services in French were not made available to you at our volunteer counter on July 26, 2016.” The same email also says that the HIAA is not able to have bilingual volunteers in place at all times. A copy of the email is in Exhibit 3 of this affidavit.
[28] Although the excerpts from paragraph 13 of the affidavit from November 16, 2017 do not strictly reveal the contents of any offer to settle made by the respondent—which declined an out-of-court settlement—counsel for the respondent nevertheless invites the Court to read the entire email from September 27, 2017, which reads as follows:
[translation]
Thank you for having contacted me. I am grateful to you for having informed me in advance of your intentions regarding your recent complaint about your experience at Halifax Stanfield International Airport.
We deeply regret that services in French were not available to you at our volunteer counter on July 26, 2016. We take our obligations under the Official Languages Act very seriously and we regret not being able to answer your request for assistance in the language of your choice. We would like to thank you for bringing this situation to our attention. Although we are not able to have bilingual volunteers in place at all times, we provide our volunteers with training and some tools to help them provide service in French to our passengers. We are sorry that our volunteer did not use those tools in your case.
After receiving your complaint, we reminded our volunteers of their obligation to provide travellers with service in the official language of their choice and we reviewed with them the tools that are available to help them do so. We have also redoubled our efforts to draw bilingual volunteers.
We are proud to offer our passengers exceptional customer service and we regret not being able to do so on this occasion.
Although we recognize that you are entitled to service in the official language of your choice, we do not think that damages of $1,500 are warranted under these particular circumstances. However, we greatly appreciate that you took the time to bring this issue to our attention and we took advantage of this occasion to remind all our service providers of their official languages obligations. Please accept my most sincere apologies for this incident.
[29] In this case, what stood out from Valerie Seager’s affidavit from December 13, 2017 and the applicant’s affidavit from January 26, 2016, which were filed by the respondent and applicant respectively in support of the claims regarding the motion to strike, is that the parties do not agree on the legal description to give to the contents of the alleged communications in paragraph 13 of the affidavit from November 16, 2017, particularly what is written by the respondent’s representative in the email from September 27, 2017.
[30] According to the respondent, this last email fits within the framework of a group of discussions regarding a potential settlement. In fact, the email followed a telephone call from the applicant in which he proposed to settle the dispute out of court, without which he threatened the respondent with bringing his case before the Federal Court. According to the respondent’s understanding, the intention of the parties was clear that all those exchanges had to remain confidential. The failure to include a specific mention in that regard in the email constitutes an involuntary omission on its part. Such concessions on the part of the respondent would never have been made outside of a settlement context. Thus, the conditions in case law that lead to the protection of communications that are part of a settlement are met: litigation was clearly planned, in light of the applicant’s threat; the intention of the parties was clear in that the communications had to remain confidential and the absence of a label was not determinative, and lastly, the applicant himself admitted that he had proposed to the respondent that they settle out of court. The email from September 27, 2017, is the reply to that offer.
[31] The applicant is focusing his claims on the absence of a common intention between the parties as to the confidentiality of communications, at least those that were revealed in the alleged email in paragraph 13. The email from September 27, 2017, does not indicate anywhere that its existence or its contents had to remain confidential. That question was never discussed by the parties as part of their exchanges and he never consented to it either explicitly or implicitly. On the contrary, he also says that he was surprised to see the ‘confidential’ label on the offer to settle that was made after the email from September 27, 2017, by counsel for the respondent, which was on November 1, 2017, and which was filed on record or summarized in paragraph 15 of the affidavit from November 16, 2017. According to him, the conditions in case law that would lead to the protection of communications that were part of a settlement are therefore not met in this case.
[32] The respondent’s objection is not founded.
[33] Settlement privilege is a common law rule of evidence that protects communications exchanged by parties as they try to settle a dispute (see Union Carbide at para 31). It applies to all communications that are part of discussions aimed at a settlement and not only the contents of a possible agreement. The Supreme Court has repeatedly confirmed the importance of that privilege, which aims to encourage settlements and thus contribute to improving access to justice (see Globe and Mail v Canada (Attorney General), 2010 SCC 41 at paras 78 and 81 [Globe and Mail]; Sable Offshore Energy Inc v Ameron International Corp, 2013 SCC 37 at para 11 [Sable Offshore]; Union Carbide at para 1). In fact, that privilege stems from the principle that parties would hesitate to commit themselves in open negotiations if they fear that the concessions made could be used against them in later litigation (see Globe and Mail at para 80; Sable Offshore at para 13; Union Carbide at para 31).
[34] According to the case law and doctrine consulted by the Court (Mohawks of the Bay of Quinte v Canada (Indian and Northern Affairs), 2013 FC 669 at para 34; see also Sidney N Lederman, Alan W Bryant and Michelle K Fuerst, Sopinka, Lederman & Bryant: The Law of Evidence in Canada, 4th ed, Markham, Lexis Nexis, 2014 at p 1039 [Lederman]), the conditions that are necessary for the existence of settlement privilege are as follows:
a)A litigious dispute must be in existence or within contemplation;
b)The communication must be made with the express or implied intention that it would not be disclosed to the court in the event negotiations failed; and
c)The purpose of the communication must be to attempt to effect a settlement.
[35] That said, although it may serve to indicate the intent of the parties, the presence of the label “without prejudice”
is not required to invoke the privilege (see Sable Offshore at para 14; see also Lederman at p 1039). It is in fact the intent of the parties to settle the action that will be determinative (see Sable Offshore at para 14).
[36] The email from September 27, 2017, is not protected by settlement privilege. Indeed, it is undeniable that litigation between the parties was foreseen. The applicant himself mentioned in paragraph 9 of his affidavit from January 26, 2018 that he had contacted that respondent for the purpose of avoiding litigation at the Federal Court. On the applicant’s side, the intent of that appeal was clearly to settle the dispute (see the affidavit from January 26, 2018, at paragraph 9). However, I am not satisfied that such was the intent of the respondent in its email from September 27, 2017 (exhibit 3). In fact, the email does not show any intent whatsoever to settle: Valerie Seager only declines the applicant’s offer without offering anything in exchange or trying to begin any sort of settlement discussion. It must be remembered that settlement privilege aims to encourage the parties to disclose information and make concessions. Here, the information given by Ms. Seager regarding the bilingualism-related situation does not appear to me to be used as a negotiation argument. Instead, the email has the appearance of a courtesy letter that attempts to end the exchange with the applicant. In that measure, I do not find that this shows the respondent’s intention to settle, which is the 3rd test of applying the privilege.
[37] I also agree with the applicant that the intent to keep those communications confidential is also not evident. Let us recall the context: the respondent, the HIAA, a significant federal institution, communicates directly with an individual through its Vice President, Legal & Regulatory Affairs, clearly showing an imbalance in the level of legal knowledge between the parties. Ms. Seager could not thus presume that the applicant would quite naturally expect that their exchanges would remain confidential. If such was the respondent’s intention, it seems to me that a brief conversation or mention to that effect would have been appropriate. However, the question of confidentiality was never discussed by the parties, at least when the email was sent. The Vice President was therefore well aware of the issue of confidentiality, yet claims that the failure to include any mention in the email was involuntary. I do not agree with this argument after the fact from the respondent. Added to that is the fact that counsel for the respondent made the effort to include the label “without prejudice”
in their subsequent offer on November 1, 2017.
[38] In summary, the three criteria for invoking settlement privilege are not completely met. Therefore, there is no need to exercise this Court’s discretionary authority to summarily strike paragraph 13 of the applicant’s affidavit from November 16, 2017.
Costs
[39] The parties agree that the costs should be awarded by the Court at the motion to strike stage, rather than wait for the decision on merits, based on the outcome of the case.
[40] Given that this motion was dismissed, the applicant will be entitled to costs.
[41] Although as a general rule, a self-represented party is only entitled to payment of its disbursements and its fees, given the absence of counsel, the justices of this Court are increasingly open to allowing some compensation for time spent preparing the case (see Air Canada v Thibodeau, 2007 FCA 115 at para 24 [Thibodeau 2007 FCA]; Sherman v Canada (Minister of National Revenue), 2004 FCA 29 at paras 10–11; Stevens v Canada (Attorney General), 2007 FC 847 at paras 17–19; see also the trial decision in Thibodeau 2005 FC at paras 31 et seq.).
[42] In Thibodeau 2007 FCA, Létourneau J. stated the following:
However, given the three-fold objective of costs, i.e. providing compensation, promoting settlement and deterring abusive behaviour, case law has acknowledged that it is appropriate to award some form of compensation to self-represented parties, particularly when that party is required to be present at a hearing and foregoes income because of that: see Sherman v. Minister of National Revenue, [2003] 4 FCA 865. However, the compensation awarded may at best be equal to what the party could have obtained under the Tariff if it had been represented by a lawyer: see Sherman, supra, 2004 FCA 29 (CanLII), at paragraph 11 [...]
[43] In my view, such an approach fits within the spirit of the OLA, for which subsection 81(2) also allows the awarding of costs in favour of the unsuccessful party, due to the public interest of the remedy under that legislative scheme. Although that subsection does not apply in this case, it certainly shows a legislative intent to compensate the parties that spend time and money to settle a case that raises significant issues for Canadian society (for example, see Norton v Via Rail Canada, 2009 FC 704 at para 130).
[44] In addition, beyond its costs of $250, the applicant claims compensation for the approximately 50 hours of work that were necessary for preparing his reply to the respondent’s motion. Here, it is suitable to award the applicant an overall sum as compensation for his hours worked. A total sum of $1,250, including disbursements claims by the applicant, seem appropriate to me in the circumstances.
Extension of the deadline for serving respondent’s affidavits
[45] Lastly, given that that deadlines to serve the respondent’s affidavits have passed, the Court allows an extension until March 16, 2018 for the respondent’s affidavits to be served.
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