Citation: 2008TCC49
Date: 20080128
Docket: 2004-4624(GST)G
BETWEEN:
MERCHANT LAW GROUP,
Appellant,
and
HER MAJESTY THE QUEEN,
Respondent.
REASONS FOR ORDER
(Edited from Reasons for
Order delivered orally
by telephone conference
call
on January 9, 2008 at Ottawa, Canada)
Rossiter, J.
BACKGROUND:
[1] The Appellant has filed
a Motion in writing relating to an Examination for Discovery asking that the
Respondent answer Undertakings given during the Examination for Discovery.
[2] The Appellant
appeals a GST assessment relating to 2000, 2001, 2002 and January 1st through
to April 30th, 2003 assessment periods. The main issue in the appeal is whether
certain legal disbursements are taxable supplies pursuant to the Excise Tax
Act (the “Act”). The appeal was initiated on December 1st, 2004.
FACTS:
[3] The following are
some relevant activities in relation to this motion:
1. On July 24,
2007, the Appellant conducted an Examination for Discovery of a representative
of the Minister and during the Examination for Discovery a number of
Undertakings were given by the Respondent.
2. On August 2,
2007, the Appellant filed a Motion seeking that the Respondent provide
answers to all Undertakings indicated at the Examination for Discovery and
that the trial, then scheduled for November 5, 6, and 7, 2007, be
adjourned.
3. On August 31,
2007, the Respondent, by letter, attempted to provide answers to 28 Undertakings
given at the Examination for Discovery.
4. On September
14, 2007, the Respondent, by letter, advised that the Minister opposed the
trial being adjourned.
5. On September
28, 2007, the Appellant, by letter, further argued that the Respondent
was obliged to provide answers to the Undertakings left at issue.
6. In early
October 2007, it came to the Court’s attention that the Appellant had
been reassessed twice on July 28, 2004 and once on March 8, 2005 and as a
result of this new information, the Respondent later agreed that the
trial would be adjourned.
7. On October 3,
2007, the Appellant by letter informed the Court that the Respondent now
agreed to the adjournment of the trial and the Appellant further sought
to file a new appeal since there was an additional reassessment.
8. On October 10,
2007, the Motion for adjournment was heard by the Court by conference call.
A new timetable was set out and the hearing had been rescheduled with
agreement of counsel.
ISSUES:
[4] The issue left to
be decided from this motion was whether the Respondent satisfied the Undertakings
given during the Examination for Discovery. Certain Undertakings had been dealt
with during the conference call hearing and are now moot.
[5] There is also the
issue as to whether or not the Appellant files an Amended Notice of Appeal or a
new Notice of Appeal given the additional assessment.
RELEVANT LAW
[6] In dealing with the
motion, several procedural rules must be considered. In particular, reference
should be made to the Tax Court of Canada Rules (General Procedure)
(Rule 95) - Scope of Examination.
Reference should also be
made to Rule 116 of the Tax Court of Canada Rules (General Procedure) –
Failure to Answer - which deals specifically with Examination for Discovery by
written questions and might be of help to understand the overall meaning of an
Undertaking and the consequences of failing to respect it.
Failure to Answer
116.(1) Where the examining party is not
satisfied with an answer or where an answer suggests a new line of questioning,
the examining party may, within fifteen days after receiving the answer, serve
a further list of written questions which shall be answered within thirty days
after service.
(2) Where the person being examined
refuses or fails to answer a proper question or where the answer to a question
is insufficient, the Court may direct the person to answer or give a further
answer to the question or to answer any other question either by affidavit or
on oral examination.
(3) Where the Court is satisfied, on
reading all the answers to the written questions, that some or all of them are
evasive, unresponsive or otherwise unsatisfactory, the Court may direct the
person examined to submit to oral examination on such terms respecting costs
and other matters as are just.
(4) Where a person refuses or fails to
answer a proper question on a written examination or to produce a document
which that person is required to produce, the Court may, in addition to
imposing the sanctions provided in subsections (2) and (3),
(a) if the person is a party or a person
examined on behalf of or in place of a party, dismiss the appeal or allow the
appeal as the case may be,
(b) strike out all or part of the
person's evidence, and
(c) give such other direction as
is just.
[7] There is no
specific Rule for Undertakings in the Tax Court of Canada Rules (General
Procedure) and as such it is necessary to look to the local rules of Civil
Procedure to see how Undertakings are handled. The Appellant referred to Rule
231 of the Queen’s Bench Rules and the Saskatchewan Civil Procedure
Rules which state as follows:
Refusal or Neglect to
answer:
Penalties
231
Anyone refusing or neglecting to attend at the time and place appointed for his
examination or refusing to be sworn or to answer any lawful question put to him
by any party entitled to do so or his counsel or solicitor or having undertaken
at the examination to answer at a later date any lawful question put to him
fails to do so within a reasonable time after the examination shall be deemed
guilty of a contempt of court and proceedings may be taken forthwith to commit
him for contempt. He shall be liable if a plaintiff to have his action
dismissed, and if a defendant to have his defence, if any, struck out and to be
placed in the same position as if he had not defended. If the party so
neglecting to refusing is an officer or servant of a corporation, the corporation
itself shall be liable if a plaintiff to have its action dismissed, and if a defendant
to have its defence, if any, struck out and to be placed in the same position
as if it had not defended; and in either case the party examining may apply to
the court to that effect and an order may be made accordingly.
[8] The Ontario
Rules of Civil Procedure mention the following regarding Undertakings given
by a party, and I refer specifically to Rule 31.07(1), 31.07(2) and 31.07(3):
31.07(1) Where a party, or a person examined
for discovery on behalf of or in place of a party, has refused to answer a
proper question or to answer a question on the ground of privilege, and has
failed to furnish the information in writing not later than 60 days before the
trial begins, the party may not introduce the information at trial except with
leave of the trial judge.
Effect of Failure to
Answer in accordance with undertaking
(2) Where a party, or person examined for
discovery on behalf of or in place of a party, has undertaken to answer a
question but has failed to furnish the information in writing not later than 60
days before the trial begins, the party may not introduce the information at
trial except with leave of the trial judge.
Additional Sanction
(3) The sanction provided by subrule (1) and
(2) is in addition to the sanctions provided by Rule 34.15 (sanctions for
default in examination).
[9] These Rules give a
fairly strict approach to Undertakings given and when those Rules apply, a
party that has given Undertakings at an Examination for Discovery cannot later
change its mind and will be bound by its original promise. A refusal to give
answers to an Undertaking can have detrimental consequences for the party at
fault.
[10] It is necessary to
examine how the case law has dealt with Undertaking issues especially relating
to proceedings at the Tax Court of Canada level.
[11] The Tax Court of
Canada has been confronted with questions relating to Undertakings on many occasions.
Procedural rules in provincial Courts, have been used as a comparison. In Union
Industries Inc. v. Beckett Packaging Ltd., [1988] O.J. No. 115, Master
Donkin of the Ontario Superior Court of Justice defined an Undertaking as
follows:
It seems to me that an undertaking
is a form of contract. It is a promise to produce certain information, and the consideration
may well be the fact that no further questions are asked about the document at
the time of the examination. At any rate it is a promise which the courts have
always enforced.
[12] Furthermore, in Towne
et al. v. Miller et al., [2001] O.J. No. 4241, the Ontario Superior Court
of Justice explains that:
… An undertaking is an
acknowledgment that the question is proper and that the subject-matter of the undertaking
is relevant. Put crudely, should counsel be permitted to renege on a
production-undertaking when he or she subsequently comes to the belief that a
document or part thereof is not relevant in the action? This question invades the
sanctity of a solicitor’s undertaking.
An undertaking is an
unequivocal promise to perform a certain act. I do not see any material
difference between, for example, an undertaking given in the context of a real
estate transaction (when lawyers undertake to do, or obtain, something
necessary to complete the transaction) and an undertaking given on an
examination for discovery. Each involves a promise. In an examination for
discovery, the undertaking may be given by the litigant been examined or it may
come from his or her counsel. Both are equally binding.
And even if the undertaking
is couched in language such as, “On behalf of my client I will obtain such and
such” (which here is not the case), it, nonetheless, is a personal
responsibility of the lawyer: see Ontario Rules of Professional Conduct, Rule
14, commentary 6. An undertaking given by a lawyer renders the lawyer
personally liable even where the consent of the client to the undertaking is
lacking (again, not the case here).
Undertakings
given by lawyers are matters of the utmost good faith and must receive
scrupulous attention.
An undertaking which may be
beyond the ability of the lawyer to fulfill should be given as a “best efforts”
undertaking, thereby transforming it into a qualified promise.
[13] This approach has
been followed within the Tax Court of Canada, by Mr. Justice Bowie in Bathurst
Machine Shop Ltd. v. R., [2006] 5 C.T.C. 2167 at paragraph 1. In that case,
counsel for the Respondent had given certain Undertakings but later took the
position that the questions were irrelevant to the issue of the Appeal and
therefore the Minister refused to fulfill the Undertakings originally given. To
that effect, Justice Bowie explained that:
… once an unqualified undertaking
has been given, it is too late to refuse to provide an answer on grounds of
relevance: …
[14] While the approach
in Bathurst Machine Shop Ltd. v. R., supra, dictates a fairly
strict approach, some case law seems to indicate that relevancy of the Undertaking
remains important and has to be taken into consideration. It should be noted,
that the Examination for Discovery does not occur in a vacuum; it is part of
the entire appeal process and its purpose is to gather information that helps
solving the entire appeal. In Cimolai v. R., [2005] 2 C.T.C. 2026,
Justice Hershfield in paragraph 16 indicated the purpose of the Discoveries is:
… to gather information
related in a relevant way to the issues under appeal. …
In that case the Court was
dealing specifically with Examinations for Discovery by way of written
questions, notwithstanding the same, the general principle is nonetheless
applicable here.
[15] One criteria to
consider in the Undertaking is whether the issue is relevant to the
determination of the appeal. It would be illogical and it would unduly prolong
the process if a party was required to provide an answer to the Undertaking that
is of no relevance to the issue in the appeal. In Fortunato v. Toronto Sun, [2001] O.J. No. 3383,
Master Birnbaum stated in paragraph 9 that if an Undertaking is no longer
relevant it does not have to be answered. He further states:
11 … Clearly to require the production of
material that is no longer relevant to an action creates an unnecessary cost to
both the plaintiff and the defendants and this is to be avoided.
[16] It is important to
examine the language used by the party who has given the Undertaking. Was the
Undertaking unconditional or was the Undertaking subject to certain conditions
or restrictions? In Patex Snowmobiles Ltd. v. Bombardier Ltd. et al.,
(1986) 10 C.P.R. (3d) 424, Justice Strayer of the Federal Court of Canada
considered the wording used with regards to the Undertakings given by the party
being examined. In that case, the Appellant did not contest the relevancy of the
questions; he rather denied that an Undertaking had been given. Justice Strayer
made a variety of comments at paragraphs 1 to 4. At paragraph 3, he stated:
… He cited to me several cases in which
it has been said that undertakings given by solicitors, to be enforceable, must
be clear and unequivocal.
While I accept that as a general
principle, one must look at the particular context of an examination for discovery
and try to see what counsel should reasonably understand as to whether undertakings
have been given. In such examinations, it is very common practice for counsel
to put questions to the examinee and, where the examinee is unable to answer
the question, to ask him or his counsel to see if the answer can be provided.
In reviewing the portions of the examination for discovery in question, it
appears to me that that is generally what happened in this case. While it may
not be necessary for counsel to make a specific objection to a question in
order to be able to argue later before a judge that such a question is not
relevant or is otherwise objectionable (a matter which I need not and do not
decide here), it appears to me that it is legitimate for examining counsel to
assume that an answer will be sought and if possible provided by the examinee,
where so requested, unless there is a specific refusal to do so.
Based on this approach, I am taking all
the answers which counsel for the defendants (appellants) characterized as
equivalent to “we’ll consider it” or “we’ll look into that” as being commitments
to look and see if an answer can be found. As such, I have no difficulty in
finding these to be undertakings to provide some kind of a response to the
questions in issue …
This of course does not mean the defendants
must give answers where no answers are possible. The undertakings must be read
in the form in which the question was put, as further qualified by the
discussion which ensued. In many cases a proper response would simply involve a
search for the information and a report to counsel for the plaintiff as to
whether the information is available or not and if so what it is. [Emphasis
added]
The Determination whether an undertaking
has been answerable will have to pass a two step test. First, it has to be
determined whether an unconditional undertaking has been given by a party, or
whether the undertaking is conditional. At this stage one needs to look at the
wording used during the examination for discovery. Secondly, if an undertaking
has been given, the Court has to determine whether or not it is relevant to the
determination of the Appeal. Based upon the foregoing, one can deal with each undertaking,
will have to be decided.
ANALYSIS:
Given the background facts and the
relevant law, I will now deal with the Undertakings in dispute in this
particular matter.
[17] The following
Undertakings were originally given by the Respondent during the course of the
Examination for Discovery.
Undertaking One. Provide the date that
the audit of Merchant Law Group began.
This Undertaking has
been satisfied.
Undertaking Two. Provide a copy of the
GST returns for May 2000, March 2001, January 2001, and April 2001.
The Respondent argues
that this Undertaking has been answered. More precisely, the Minister affirms
that the GST returns are no longer available and further mentions that a copy
of the posted data could be provided to the Appellant. The Appellant is not
satisfied with the answer provided by the Respondent and seems to suggest that
the Respondent has not diligently searched for the set of documents. The
Appellant seeks further explanation from the Respondent regarding this
Undertaking and wants some sort of reassurance that the Respondent has actually
searched for the asked documents. The Appellant argues that the answer provided
by the Respondent does not indicate whether the Minister searched for the documents
or not. It is somewhat difficult to follow this argument. The Minister stated the
documents are no longer available and it seems logical that the Minister had to
search for the documents to determine they are no longer available, or else he could
not say otherwise. Since the documents are no longer available it becomes
impossible for the Minister to produce them and therefore the Respondent has
fulfilled its obligations for this particular Undertaking.
Undertaking Three. If possible, itemize
each of the disbursements in the working papers. For example, advise what
amounts, or if a marriage contract is to be discovered or a doctor’s reports, et
cetera.
This Undertaking was
initially refused but was later given as Undertaking Twenty-Eight. I will not
refer to the specific wording of the Undertaking at the Discovery, or the
relevancy of the Undertaking as it has been dealt with in the telephone
conference call in this matter where Counsel for the Respondent indicated that
the Minister will be able to produce the documents. Furthermore, in the
Respondent’s written answer to this motion he confirmed that the Minister will
produce this material provided he is allowed six days to do so. Given a
timeline, with respect to how this matter has progressed, and the fact that the
trial in this matter is scheduled for April 2008, the Minister will be allowed
30 days from January 9, 2008 to fulfill this Undertaking.
Undertaking Four. Advise why two
assessments were done in July 28, 2004 and March 8, 2005. This Undertaking has
been addressed in the letter from the Respondent dated October 13, 2007 and has
also been further explained by the Respondent during the teleconference and as
a result there is no need for it to be considered any further and that the
Undertaking has been fulfilled by the Respondent.
Undertaking Five to
Eleven and Thirteen to Twenty-One. The Appellant asked advice regarding the
applicability of the GST on some specific legal disbursements. For example, the
Appellant asked if bank charges, bills of cost, civil claim fees accepted are
subject to GST. The Minister has given general answers to those questions and
rightfully argues that it is difficult to provide more specific answers
although unless there is a clear factual background. These Undertakings have
been answered by the Respondent.
Undertaking Twenty-Two. Advise if fees for
Tax Certificates for the city are subject to GST.
It appears from the
transcripts, that no Undertaking was given by the Respondent in respect to the
above-mentioned question. The Minister is under no obligation to provide an
answer to this question.
Undertaking Twenty-Three. Advise if the Court
transfer fees are subject to GST. The same answer for Undertaking Twenty-Two
applies here, that the Minister did not give an Undertaking and the question
need not be answered.
Undertaking Twenty-Five. If possible, provide
a copy of the Reciprocal Taxation Agreement and refer to the relevant
provisions, rule out the portions.
The Respondent has
provided the Appellant with the relevant documentation but has not referred to
the relevant portions. The Undertaking was given conditionally, that is “if
possible”. The relevant portions applicable might vary depending on the
circumstances and it might at this time simply not be possible for the Minister
to refer to the relevant portions. The purpose of the Undertaking is not for
the Appellant to received legal advice but simply provide him with the relevant
Reciprocal Taxation Agreement.
Undertaking Twenty-Six. If possible provide
a copy of the Agreements in place in Saskatchewan between the provincial and federal
governments that the province will not charge tax with respect to legal
matters.
The Respondent has
indicated that “no such agreement was found”. Additionally, the Undertaking
uses the words “if possible”. Furthermore, during examination, Counsel for the
Respondent said regarding this Undertaking:
Yes, no, we can undertake to
try to obtain and research to see if they exist.
It seems clear that the
Respondent only undertook to try to search for the document. He could not find
an answer, consequently, the Minister’s answer does not say whether or not the
subject document exists. The Minister’s response should indicate whether or not
the documents exist within 30 days of January 9, 2008.
Undertaking Twenty-Seven.
If
possible, provide a copy of the Agreements in place in all provinces and
territories of Canada between provincial and federal governments, that the
provinces/territories will not charge tax with respect to legal matters. The
same answer as provided in Undertaking Twenty-Six is applicable to this Undertaking.
Undertaking Twenty-Eight. Attempt to provide a
detailed account summary with respect to the amounts in issue. This is the same
Undertaking as Undertaking Three and has already been dealt with.
[18] On the issue of
costs, it should be noted, that the results on this motion were somewhat mixed
to say the least. I should also note, that when the teleconference initially
occurred in this matter, directions were given by the Court and agreed to by
both counsel, with respect to timelines for the parties to give submissions on the
issue of costs. The Appellant was directed and ordered by the Court to file its
submissions on costs by October 18, 2007. The letter, enclosed over their
submissions on costs was dated October 26, 2007, sent by courier November 5,
2007 and received by the Court, on November 5, 2007 without any explanation as
to it having been outside the timeline agreed to and ordered by the Court and without
any motion to the Court to extend the deadline. The Court will not comment on
the dating of the letter, the date it was couriered or the date it was
received, suffice it to say, the dating of the correspondence is totally
irrelevant. The date sent by courier is totally irrelevant. It is the day it is
received by the Court that is important. It was received some 18 days after it
was supposed to be filed without an explanation. The rules of Court are there
for a purpose and that is to provide for the administration and flow of
litigation. When parties agree to particular timelines and agree to an Order on
these timelines and then do not comply with the timelines without providing a
satisfactory explanation, it shows disrespect for opposing counsel, the Court
and either ignorance of the purpose of Rules of Court or arrogance with respect
to their application. Counsel for the Appellant is an experienced counsel and
is familiar with the Tax Court of Canada. Counsel ignored the Order and the rules
of Court and put his client at risk on costs and he should know better. I will
not tolerate such disrespect for the Court. If you do not agree with the timelines
when given, say it. It looks like correspondence was somewhat conveniently
dated and later couriered to make it look like it was not as late as it really
was. We have already set the schedule for this litigation and trial, and those
dates are not and will not be delayed or altered by these tactics. The trial is
scheduled for April and it will proceed in April.
[19] There is another
issue to be dealt with and that is, that there is an additional assessment. The
Appellant claims that it should be allowed to file a new Notice of
Appeal as opposed to an Amended Notice of Appeal because the reassessment has
been sent out while an appeal was pending and ongoing in the same matter. This,
in my view, contradicts section 302 of the Excise Tax Act. That
section specifically was drafted for instances like the present situation and
indicates that the proper form in which to proceed is by Amended Notice of
Appeal. Additionally, the Appellant had previously agreed to file an Amended
Notice of Appeal in this Court and made an Order accordingly. Rule 55 of the Tax
Court of Canada Rules (General Procedure) is applicable and the Appellant
must comply with it.
[20] The Appellant filed
its Notice of Appeal on November 19, 2007 and shortly thereafter the Respondent
forwarded correspondence to the Court in which the Minister states that the Notice
of Appeal fails to comply with the procedural rules which require that amendments
be underlined so as to distinguish the amended wording from the original.
Whether or not the Appellant is correct to file a new Notice of Appeal and not
an Amended Notice of Appeal, the re-draft of the Amended Notice of Appeal is
not in proper form and does not comply with Rule 55. The Appellant takes the
position that it is not an Amended Notice of Appeal but a new Notice of Appeal,
but nonetheless the Appellant submitted an Amended Notice of Appeal, filed on
November 26, 2007. This Amended Notice of Appeal is not even in compliance with
Rule 55.
[21] The crux of the
Appellant’s argument is that Rule 55 of the Tax Court of Canada Rules
(General Procedure) is not applicable because this is a new appeal
resulting in a new assessment. Rule 54 and 55 respectively of the Tax Court
of Canada Rules (General Procedure) reads as follows:
54. A plea may be amended by the party
filing it, at any time before the close of pleadings, and thereafter either on
filing the consent of all other parties, or with leave of the Court, and the
Court in granting leave may impose such terms as are just.
55. (1) An amendment to a pleading shall
be made by filing a fresh copy of the original pleading as amended, bearing the
date of the amendment and of the original pleading, and the title of the
pleading, proceeded by the word “amended”.
(2) An amendment to a pleading shall be
underlined so as to distinguish the amended wording from the original.
[22] The real question
remains as to whether or not the Appellant is entitled to file a new Notice of
Appeal or whether it shall file an Amended Notice of Appeal.
[23] By correspondence
dated October 3, 2007 in relation to the motion concerning the Undertakings,
the Appellant also sought additional relief, namely to file a new Notice of
Appeal. During the teleconference of October 10, 2007, a particular issue was
raised and discussed with the parties and in the transcript it is clearly noted
that the Appellant unequivocally agreed to file an Amended Notice of Appeal. As
a result, therefore this Court ordered the Appellant to file an Amended Notice
of Appeal pursuant to Tax Court of Canada Rules (General Procedure)
on or before November 19, 2007. Now for some strange reason, the Appellant
later claims that it should be considered as a new Notice of Appeal.
[24] Section 306 of the Act
sets out the requirement to file an appeal to the Tax Court of Canada and this
section applies to cases where the Minister has confirmed the assessment. In
this case, however, the Appellant was allowed additional courtesy by way of a
Notice of Reassessment dated March 8, 2005 and since it is not a Notice of
Confirmation but Notice of Reassessment, section 302 of the Act becomes
applicable and not section 306. Section 302 states:
Where a person files a
notice of objection to an assessment and the Minister sends to the person the
Notice of a reassessment or an additional assessment, in respect of any matter
dealt with in the notice of objection, the person may, within ninety days after
the day the notice of reassessment or additional assessment was sent by the
Minister,
(a) appeal therefrom to the Tax Court; or
(b) where an appeal has already been
instituted in respect of the matter, amend the appeal by joining thereto an
appeal in respect of the reassessment or additional assessment in such manner
and on such terms as the Tax Court directs. [Emphasis
added]
[25] This section, in my
view, resolves the issue. It clearly deals with cases where a reassessment or
additional assessment is sent to a person where an objection is outstanding.
There is no doubt that it is applicable, in the case at bar and it is
appropriate for the Appellant to file an Amended Notice of Appeal. Author David
Sherman in his analysis of section 302 of the Act sums it up quite properly:
Section 306 is the normal
route for appeals to the Tax Court, when the Minister confirms an assessment to
which an objection has been filed.
Section 302 deals with the unusual
case where a reassessment or additional assessment is sent to a person while
an objection is outstanding. This may happen, for example, if separate
assessments have been issued by different
offices at CCRA. (This is more common in income tax reassessments than under
the GST, where there is rarely more than one audit group examining a particular
person’s affairs for all years that are open for an assessment.)
[26] Also, section 302 of
the Act gives the Court its discretionary powers and this Court has
clearly directed the Appellant to file an Amended Notice of Appeal by an Order
dated October 17, 2007. Unless the Court otherwise orders, Rule 55 of the Tax
Court of Canada Rules (General Procedure) becomes applicable and the
Appellant ought to comply with this Rule on a timely basis.
[27] This Court also uses
its discretionary power to dispense the compliance of certain rules that it
deems in the interest of justice. To this effect, I refer to Rule 9 of the Tax
Court of Canada Rules (General Procedure). The Court will not be exercising
its discretionary power, and will not be giving any additional directions,
otherwise than to state quite clearly that the Appellant has to file an Amended
Notice of Appeal. It is a continuation to the proceeding initially started by
the original Notice of Appeal. The Appellant is ordered to file an Amended
Notice of Appeal, within five (5) working days of January 9, 2008 and the
Respondent is to file an Amended Reply, if any, within five (5) working days of
the receipt of the Amended Notice of Appeal.
[28] The Respondent shall
have their costs in these applications, fixed in the amount of $1,500 payable
forthwith, which means payable by 5:00 p.m., Ottawa time, on January 11, 2008.
Signed at Ottawa, Canada, this 28th day of January, 2008.
"E. P. Rossiter"
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