News

Farewell LPAT, we hardly knew ye.

On June 1, 2021, select changes from Ontario’s omnibus Bill 245, the Accelerating Access to Justice Act,  took effect. Among these changes is the amalgamation of the Local Planning Appeal Tribunal (“LPAT”), the Board of Negotiation, the Conservation Review Board, the Environmental Review Tribunal and the Mining and Lands Tribunal, into a single new body, the “Ontario Lands Tribunal” (“OLT”), pursuant to the Ontario Land Tribunal Act, 2021.

The Province first announced this decision and circulated a draft set of Rules of Practice and Procedure (the “Rules”) in January 2021. After receiving public submissions, the Rules that will govern the amalgamated Tribunal have been finalized. Notable changes to the procedures include:

New Focus on Cost Effectiveness and Efficiency

The OLT was introduced to eliminate overlap between cases, streamline the hearing process and to find efficiencies in tribunals’ specialized areas of adjudication and mediation expertise. The Rules build on these principles immediately by stating in Rule 1.3 that they are to be liberally interpreted to offer the best opportunity for a fair, just, expeditious, and (now) cost effective resolution of the merits of the proceedings.

To this extent, multiple time-saving processes have been introduced by the Rules into the OLT’s procedure. Among these are Rule 2.2, which introduces an Alternate Chair, who may perform the duties of the Chair and has all powers of the Chair in cases where the Chair is unable to act. Rule 5.1 removes the requirement to provide applications, appeals or referrals in hard-copy, instead calling for submission in electronic format, unless directed by the Tribunal otherwise. This likely goes hand in hand with the OLT’s new online document submission platform. Further, while new practices for electronic hearings have already been introduced, the Rules’ continued focus on these procedures suggest that these will also be used post-COVID.

Rule 19.2 mandates parties to present a draft procedural order prior to a case management conference (“CMC”). While this was already standard practice of the LPAT in many cases, this practice is now explicitly codified within the Rules, thus further expediting the hearing process, and streamlining the CMC process.

Renewed Focus on Mediation

Both the former Ontario Municipal Board and LPAT have been criticized for not having a procedure or framework for non-Tribunal members to conduct public mediations. This has led to significant time and cost delays as the timing of mediations depended on the Member’s scheduling, and often led parties to seek private mediation thereby increasing their legal costs.

The Rules have changed this process by allowing Tribunal-led mediations to be conducted by an approved external mediation service. Mediation assessments may also be conducted by external mediators approved by both the Chair and the Ministry of the Attorney General. Thus, the pool of public mediators available to OLT participants has been expanded. While the OLT Rules do not go as far as Rule 24.1 of the Rules of Civil Procedure (which mandates mediations in certain regions before a hearing can even occur), this change supports the promotion and facilitation of the mediation process.

Blurring of Notice Period Requirements

Rule 6.4, which set out different notice periods per type of planning appeal, has been removed, and new Rule 6.1 simply states the notice period will be directed by the Tribunal. While this change gives the Tribunal flexibility to set notice periods appropriate to the circumstances, it provides less certainty for municipalities, appellants, and the public to understand in advance how much notice they will be required to give, or will receive, prior to a hearing event.

Impartiality of Expert Witnesses

Another notable change in the Rules is an express provision in Rule 7.5 regarding the impartiality and professionality of expert witnesses. Expert witnesses that are giving oral evidence in examination in chief, under cross examination or while in reply, cannot seek or receive assistance or communication, except technical support, from third parties. This express Rule attempts to ensure that expert witnesses (and third parties) understand their professional duties when an expert is testifying in front of the Tribunal. This recognition was introduced into the Acknowledgement of Experts Duty forms when the LPAT went virtual post-COVID and is now codified in the new Rules.

The team at Davies Howe LLP will continue to monitor legislative and regulatory changes as they relate to land use planning and development.

As an update to our post from March 11, 2021 titled Parking Up the Right Tree: A Review of Parking Requirements for New Development, the City of Toronto is on track with the Parking Review timelines and will be hosting a number of public consultation meetings at the beginning of June. Three meetings will be held on June 1 (7-9 pm), June 2 (3-5 pm), and June 3 (1-3 pm). The feedback from these meetings will help inform recommendations for revised parking standards. Registration is available here for June 1, here for June 2 and here for June 3.

A second series of public meetings will take place in September where staff will present draft proposals to amend the zoning by-law. More information on the Parking Review can be found here.

The City of Toronto Moves Ahead with Modernizing the Toronto Building Division

The City of Toronto (the “City”) continues its modernization process and now proposes reforms to the Toronto Building Division (“Toronto Building”). Toronto Building’s role is to ensure that the City’s built environment is safe, healthy and accessible through controlling the issuance of building permits and performing building inspections. As the City’s building priorities adapt and change, there is a push to modernize Toronto Building’s operating model so that it reflects these changes.

On May 20, 2021 , the Planning and Housing Committee (the “PHC”) commenced the modernization process by adopting the recommendations set forth in Item 23.15 during its committee meeting. These recommendations direct the Chief Building Official and the Executive Director of Toronto Building to report back to the PHC in the second quarter of 2022 to provide an update on the implementation of the following recommendations:

1. Strengthening the existing processes related to demolition approvals, in collaboration with Heritage Preservation Services so that local City Councillors are notified of demolition applications for commercial buildings in their ward;
2. Implementing clear and accessible web-based tools to provide the public with current information on the status of Toronto Building investigation and enforcement activity, including complaints received through 311 Toronto; and
3. Developing a strategy, in consultation with the General Managers of Transportation Services and Municipal Licensing and Standards, to minimize the adverse impacts on the public as a result of large construction projects occurring within close proximity to one another.

The recommendations build on a Report published in May 2021 by KPMG, which provides a review of the Toronto Building Program, as well as on Toronto Building’s desire to become a client-centric regulator. The recommendations look to provide a more flexible and adaptive approach for different development types and to respond to ongoing issues faced by the City.

Recommendation 1 will likely work to prevent wholesale destruction of heritage buildings, in response to the recent media attention that demolition approvals have received. This recommendation may result in greater awareness of demolition applications on behalf of local councillors, to ensure that council is notified in a timely matter in case they wish to designate buildings under Section 27 of the Ontario Heritage Act.

Meanwhile, Recommendation 3 is likely a response to situations where multiple developments occur in close proximity to each other and, among other things, the future intensive construction along the rail corridor in Riverside. A fourth rail for expanded GO service is being proposed in the same area as the construction of the Ontario Line (cross section here). While impact studies have been done for both projects individually, neither project has considered the impact of the other in its reports. Recommendation 3 would result in more onerous requirements to consider the cumulative impacts of both projects.

This modernization will attempt to align Toronto Building with other transformation initiatives throughout the City such as the Concept to Keys program which, as we previously discussed here, is similarly reforming the development review process. For Toronto Building, a new permit application process will streamline simple projects by allowing the Division to work directly with applicants, either through face to face or virtual meetings, to address any outstanding deficiencies. Staff, services, and other resources will provide their services city-wide, rather than per district. A new service delivery model will also create new “back office” functions to enhance communication between City divisions, reduce costs through improved efficiency, and improve client satisfaction.

The PHC Item will proceed to Toronto City Council at its June 8/9 meetings for final consideration. If approved, Toronto Building will commence its modernization process.

The City of Toronto’s (the “City”) Infrastructure and Environment Committee (the “Committee”) adopted amendments to the existing Policy for Accepting Potentially Contaminated Lands to be Conveyed to the City under the Planning Act (the “Policy”), and recommended that they be approved by City Council at the May 5, 2021 Council Meeting.  However, rather than considering the proposed amendment (the “Updated Policy”), City Council referred the item to the Engineering and Construction Services (“ECS”) Chief Engineer for further consideration. While we patiently await the ECS comments, we can look at the Updated Policy as detailed in the City’s Staff Report and presented in Attachment 1.

Background

The Policy was first adopted by City Council on February 10, 2015.  The purpose of the Policy is to ensure that the City does not accept lands from applicants that present elevated risks to the environment, worker safety or public health.  The Policy contained environmental requirements which exceed Provincial laws and regulations, to protect the City from acquiring lands that have unacceptable liabilities associated with known or suspected environmental contamination. The Policy created a peer review process conducted by third-party qualified persons (“QPs”) as defined by O.Reg. 153/04 established under the Environmental Protection Act, and selected by the City.  The applicant bears the cost of this review process.

In November 2019, due to stakeholder criticism regarding the Policy’s lack of clarity, City Council requested that staff review potential amendments to the Policy and report back in Q4 of 2020.

The Updated Policy

The Updated Policy seeks to provide more certainty and clarity; expedite the peer review process; minimize the City’s liabilities related to accepting land; and continue to safeguard public health and the environment. However, the overarching objectives of the peer review process remain unchanged.

First, the Policy will be renamed the “Policy for Accepting Potentially Contaminated Lands to be Conveyed to the City as a Condition of a Development Application Approval”, to emphasize that the City may be authorized to require conveyance conditions under legislation other than the Planning Act, including the City of Toronto Act, 2006 and the Condominium Act, 1998.

The Updated Policy is proposed to include:

• Clarification of terminology and definitions, including 24 new definitions;

• Alignment of the stratified site condition standards with the Provincial legislation – these standards will apply to soil below a depth of 1.5m (subsurface soil), and are less stringent than the standards for surface soils;

• A risk assessment process – this will allow assessments for properties where it is not physically or economically feasible to remove all the contamination to determine whether the site-specific soil and groundwater standards can be developed to ensure the safety of the intended users;

• Strengthened procedural and notification requirements – the applicant and QPs will have elevated responsibilities to provide information to the City as it pertains to the conveyance of lands, as well as notifying City staff where it is likely that contamination has migrated onto adjacent City lands and poses a possible adverse effect; and

• Clarification of exemptions from the peer review process including:

1. Small parcel exemption – where the intended use is not changing to a more sensitive use. For example, residential land to be used as parkland or former industrial land to be used for road widening. The applicant will have to submit a rationale as to why they meet this exemption.

2. Dedication of small sized parks – where the lands were formally used for residential, institutional or park purposes; the areas are less than or equal to 100m²; or the areas are greater than 100m² but less than 1m in width. This was also an exemption in the former Policy.

3. Corner roundings exemption – where the lands conveyed for the purposes of a Right-of-Way corner rounding have an area less than or equal to 12.5m², provided they are not subject to a Record of Site Condition or a Certificate of Property Use.

This is a much-anticipated Policy update, and we hope that it will add more certainty and clarity to the City’s expectations and requirements for accepting potentially contaminated lands.

The Davies Howe LLP team would be happy to discuss the Updated Policy with you further.

In response to concerns regarding direct communications between Toronto Local Appeal Body (“TLAB”) Members and those involved in the TLAB hearing event, at the Q2 TLAB Public Business Meeting, the TLAB adopted Sub-Rule 2.6 to the TLAB’s Rules of Practice and Procedure.

Sub-Rule 2.6 requires that all communications with the TLAB concerning TLAB hearing events, excluding those that are strictly administrative in nature, must be made in the presence of, or copied to, all other parties to the hearing event. The effect of this rule is to ensure transparency in communications between all parties. The Members emphasized that the purpose of adopting this rule is to “reinforce the norm” to the public that, throughout the hearing process, all parties have a right to be privy to communications with TLAB Members.

After grappling with the question of how to increase the efficiency of the hearing process, at its May 7 Public Business Meeting, the Toronto Local Appeal Body (“TLAB”) decided it will move forward with a pilot project requiring Pre-Hearing Conferences (“PHC”) for all hearings anticipated to take longer than the typical duration.

Among several issues discussed, Item 31.5 proposed a new Practice Direction for Hearing Extensions (the “Proposed Direction”). The Proposed Direction was an attempt to address public feedback which characterized the current TLAB process as cumbersome and inefficient. It would require ‘variance-only’ hearings to be scheduled for no more than 2 hearing days and for ‘consent and variances’ hearings to be scheduled for no more than 4 hearing days. If the assigned Member believes a hearing may require additional days, the Member would hold a PHC where they could hear from all Parties on scheduling and determine the appropriate number of days required for the hearing. This proposal was intended to increase the efficiency of the TLAB process by establishing firm commitments from the Parties and representatives involved concerning the amount of time required throughout each step of the hearing process.

Throughout the discussion, several TLAB Members expressed concern that placing limitations on hearing days could hurt the current process. The Members believe that setting a limitation on the number of days for a hearing may lead to some Parties not having an adequate amount of time to defend their positions. While the Members of the TLAB acknowledged the importance of increasing the efficiency of the current process, the Members were more concerned with ensuring that those who participate in the TLAB process feel that they have been given a fair hearing with sufficient time to be heard.

As such, the Members were not in favour of the Proposed Direction. However, a pilot project for PHCs will move forward, in which certain matters will have a PHC scheduled and heard by the Vice-Chair of the TLAB. In PHCs, the Parties would be encouraged to settle or resolve the issues raised. If a TLAB hearing is still required, the Vice-Chair would establish a limit on the number of hearing days. The Board will reconsider this Item at a later date following feedback from the pilot project.

In a May 6, 2021  Council decision, the City of Toronto (the “City”) adopted the recommendations set forth in item PH22.7, which directs City Planning to conduct a study regarding potential changes to the Committee of Adjustment (“CoA”), including but not limited to:

• Alternatives to the CoA process for minor variances and severances;
• Changes to notice options;
• Resident concerns with the current process;
• Education and training of Members on both procedures and substance of the CoA mandate; and
• Revisions to committee processes, based on tribunal best practices.

What do the potential changes mean?

It is unclear what possible alternatives exist for the passage of minor variances and severances. Section 44 of the Planning Act (the “Act”) states that a municipality may by by-law constitute and appoint a CoA, while subsections 45(1) and 53(1) authorize a CoA to grant minor variances or consents. In theory, this means that the City could choose to administer minor variances and consents without a CoA; however, given thousands of matters are dealt with at committee every year, it is unlikely that the City’s reappropriation of these powers would lead to a more efficient or expeditious planning process.

In the City’s deliberations, concerns were also raised that Notices of Public Hearings were not being delivered in time to residents, thus preventing residents from speaking before the committee, or simply giving inadequate time for them to prepare remarks. Section 3 of Ontario Regulation 200/96 Minor Variance Applications (the “Regulation”) requires a Notice Period of at least 10 days before a hearing to be given to every landowner within 60 metres of the application area. The City’s internal process is to mail notice 20 days ahead of a hearing. As of the onset of virtual CoA hearings on May 28, 2020, the City has extended this notice to 22-24 days. It is uncertain if a further extension would have a significant impact on resident participation.

Lastly, during its meeting council proposed studying changes in respect of:

• Access to the CoA
• The transparency of the hearing process
• The grounds upon which the CoA makes their decisions.

These proposals were brought forth largely in response to comments received from certain resident groups to address perceived unfairness within both the CoA’s process and its planning decisions. These considerations will ultimately be part of City Planning’s review of the CoA and inform its eventual recommendations to Council.

While this review is in its early stages, we will continue to monitor potential changes to the CoA and outline any future impacts to matters before the body in a future blog post.

The City of Toronto (the “City”) is moving ahead with transforming its development review process through the implementation of the Concept 2 Keys (“C2K”) program, which we last reported on in October, 2020. C2K is the City’s response to its development review process report entitled End to End Review released in August 2019 (the “Report”). The Report aims to reimagine organizational structures, processes and technology to provide for a more seamless and collaborative approach to development review. In the age of virtual work environments, the need to foster collaboration between staff, applicants and the public has only increased.

What are the changes?

On a technical level, C2K’s changes to the review process include the launch of a new online application submission tool with new user-friendly forms and templates, and the expansion of the online intake portal. A new commenting mark-up tool will enable City staff and commenting partners to review planning applications, provide comments and collaboratively revise planning drawings. These changes are proposed to foster a more collaborative and iterative approach to development review, while simultaneously shortening review turnaround times.

Changes to the review process itself involve the creation of dedicated application review teams made up of members from various City divisions and overseen by new application managers and coordinators. Upon receipt of an application, teams will work to identify preliminary issues and communicate the City’s requirements and expectations. The hope is to provide a coordinated approach to development review that avoids conflicting instructions from different divisions. Should there be competing or conflicting priorities between divisions, a new Issues Resolution Table (“IRT”) has been created where new relationships and issues coordinators will facilitate internal discussion and resolve (or escalate) issues within ten business days, while updating the applicant on an ongoing basis.

Applicants can also bring issues to the IRT through a new relationship and issues management function on the review portal, which provides a single place to go to resolve file specific issues. Touch points with applicants and the City will also be increased, including through pre-application meetings, to avoid the need for the IRT to be used in all circumstances.

How is the program being implemented?

Currently, C2K is being piloted on affordable housing development applications and long-term care applications which meet the affordability criteria outlined in the City’s HousingTO 2020-2030 Acton Plan. Thirteen applications are currently participating in the C2K process (click here).  Plans to gradually expand the process to non-affordable housing in a “Phase 2” have not yet been given a firm date.

The prioritization of affordable housing projects within C2K is consistent with the City’s goal of constructing 40,000 new affordable rental homes by 2030 and is sensible within the affordable housing context, where construction of projects are increasingly being spearheaded by the City itself. However, it remains to be seen whether this increased efficiency will be preferable for private applicants over filing an LPAT appeal for failure of Council to reach a decision within the prescribed statutory periods.

It has been over one year since Ontario declared a state of emergency in response to the COVID-19 pandemic. Since then, COVID has had profound impacts on employees in Ontario and across Canada. They have been faced with temporary layoffs, reductions in the scope of their duties, and in some cases, termination. Where an employee has been terminated, they will be entitled to reasonable notice at common law, subject to the terms of their employment contract.

The purpose of reasonable notice (or pay in lieu of notice) is to provide the employee with an opportunity to seek alternative employment. Calculating the reasonable notice period is a highly fact-specific exercise and Courts will typically consider the following factors: 1) the employee’s age; 2) the length of service; 3) the character of the employment; and 4) the availability of similar employment. With that in mind, Courts in Ontario have now been asked to consider whether the impact of COVID on the job market should extend reasonable notice periods for terminated employees. Although Courts have suggested that COVID may extend reasonable notice periods, they have thus far declined award lengthier notice periods in response to COVID.

Recent Case Law

The case of Yee v. Hudson’s Bay Company, 2021 ONSC 387, a recent decision of the Ontario Superior Court of Justice, involved a 62-year-old plaintiff  who was terminated by the defendant employer after more than 11 years of service. The plaintiff’s employment was terminated in August of 2019 – just over six months before the beginning of the COVID pandemic. The plaintiff argued that, in determining the appropriate reasonable notice period, the Court should consider the COVID pandemic and the associated challenges in obtaining comparable employment. There was evidence that the plaintiff had submitted approximately 90 employment applications without success.

The Court distinguished between terminations occurring before and after the beginning of the COVID pandemic. Specifically, the Court held that pre-pandemic terminations should not attract the same consideration as post-pandemic terminations in terms of the pandemic’s negative effect on finding comparable employment. The Court’s holding appeared to suggest that terminations occurring after the beginning of the pandemic could result in longer periods of reasonable notice.

However, in Iriotakis v. Peninsula Employment Services Limited, 2021 ONSC 998, the Ontario Superior Court of Justice refused to extend the reasonable notice period for a termination that occurred after the pandemic was declared. In that case, the plaintiff was employed as a business development manager with the defendant employer for just under two and a half years. The plaintiff’s employment was terminated one week after Ontario declared a state of emergency due to the pandemic.

Although the Court acknowledged that the pandemic had some influence on the plaintiff’s job search, the Court stated that the impact of the pandemic on the job market was “highly speculative and uncertain both as to degree and to duration” at the time the plaintiff’s employment was terminated. The Court also warned about the dangers of applying hindsight when calculating the appropriate period of reasonable notice. The plaintiff was ultimately awarded three months’ notice.

Takeaways

The case law dealing with post-pandemic terminations is currently limited. Courts have not yet considered a case where an employee was terminated at the height of the pandemic. Although there are existing criteria which Courts apply to determine reasonable notice periods, it remains to be seen whether Courts will place additional weight on the COVID pandemic when considering the availability of similar employment for post-pandemic terminations. For now, Courts appear to be taking a conservative approach, but we will continue to monitor this issue for further developments.

Questions? Contact David Cherepacha or Ava Kanner

With warmer weather and sunnier days approaching, outdoor dining on one of the City’s many patios could again become one of the most popular pandemic activities, subject to Provincial government regulations permitting restaurants the ability to provide outdoor dining. The pandemic forced everyone to adapt to the “new normal” rather quickly and outdoor patios were not an exception. Since the onset of the pandemic, the City has introduced two by-laws as well as an initiative to give more restaurant and food establishments the opportunity to create and expand their outdoor patio spaces during these times. Below is an overview of the temporary use by-laws and the CafeTO program that are making these expansions more feasible.

Minister’s Zoning Order and Temporary Use By-laws

In July 2020, the Province issued Ontario Regulations 345/20 and 358/20 (collectively, the “Regulations”). O. Reg. 345/20 authorized City Council to adopt a by-law that authorized the temporary use of land for a restaurant or bar patio without the need to hold a statutory public meeting and without being appealable to the Local Planning Appeal Tribunal (LPAT). O. Reg. 358/20, which was also a Ministerial Zoning Order (“MZO”), expanded zoning permissions for outdoor patios in the City, expiring on November 16, 2020. These permissions were required to achieve the following objectives requested by City Council:

• Permit surface outdoor patios in certain zones which ordinarily permit eating establishments, but not outdoor patios;
• Remove restrictions in the Employment Industrial Zones of Zoning By-law 569-2013, which limit the amount of front yard an outdoor patio may occupy and require a setback from the front lot line;
• Allow an outdoor patio to occupy space that would otherwise be required for parking; and
• Increase the permitted maximum area of surface outdoor patios ancillary to eating establishments, take-out establishments, and recreation uses.

Pursuant to the Regulations, City Council adopted two temporary use by-laws on October 27, 2020 which replaced the expiring MZO. The two temporary use by-laws intended to continue to ease restrictions for patios during the winter months (the “By-laws”). The By-laws allowed an increase to the maximum size of outdoor patios and removed restrictions that prevented locating an outdoor patio in front of buildings. The By-laws are set to expire on May 25, 2021.

The By-laws grant the following permissions:

• Permit surface outdoor patios in Local Commercial Zones (CL) in Zoning by-law 569-2013 and similar zones in the former municipal zoning by-laws which ordinarily permit restaurants but not outdoor patios;
• Remove restrictions in the Employment Industrial Zones of Zoning By-law 569-2013 which limit the amount of front yard an outdoor patio may occupy and require a setback from the front lot line;
• Allow an outdoor patio to occupy the area of non-residential parking spaces; and
• Increase the permitted maximum area of surface outdoor patios to the greater of 50 square metres or 50% of the establishment’s interior floor area.

On March 10, 2021, City Council adopted two new temporary use by-laws which are identical to and replace the By-laws that are expiring on May 25, 2021. The new temporary use by-laws are set to expire on April 14, 2022.

CafeTO Program

Since its adoption on June 29, 2020, the CafeTO program has made it feasible for numerous restaurants and food establishments across the city to continue their operations throughout the warmer months. CafeTO provides an opportunity for restaurants and bars to expand their outdoor eating spaces into the public right-of-way, mostly on sidewalks and curb lanes.

In 2020, the program was approved to run from July 1, 2020 until April 14, 2021, and was further extended to run until November 10, 2021. The program is proposed to end on April 14, 2022 in conjunction with the By-laws.

To participate in the CafeTO program to install or expand a café, you must register with the City. Following registration, City staff review your proposal for compliance with applicable guidelines, policies and by-laws. Upon receiving a positive confirmation from the City, you may operate new and expanded sidewalk cafes as soon as outdoor dining is permitted under provincial regulations in Toronto. Further information on CaféTO and associated guidelines can be found here. While the first registration window for curb lane cafes closed on March 26, 2021, a second round of registrations opened on March 27, 2021 and will close in May 2021 (exact date to be determined).

While most outdoor café expansions require CafeTO registration, the following two instances do not require registration and can operate as-is:

• Small Sidewalk Frontage Café: single line of seating directly in front of the business not exceeding an area of 0.8 m x 5.5 m; and
• Existing Permanent Café Licences: permanent, licensed sidewalk cafes who held a permit before March 2020 and do not wish to expand on the sidewalk or the curb lane.

Additionally, patios that are located entirely on private property, comply with the applicable City-wide zoning by-laws and do not incorporate any structures that require a building permit do not require permission from the City prior to installation. Guidelines for outdoor patios located on private property can be found here.

For situations where an outdoor patio that complies with City-wide zoning regulations is not feasible on the subject site or where a patio under the CafeTO program is not feasible,  City Council requested at its March 10, 2021 meeting, that staff bring forward City-initiated site-specific temporary use by-laws to provide site-specific zoning relief for outdoor patios located on private property.

If you are looking to install or expand a patio on public or private property and have additional questions, do not hesitate to reach out and one of our lawyers will be happy to help you navigate through the process.