CUPW grieves that on or about July 13, 2009 and ongoing in Halifax, the Corporation interfered in the representation of employees by CUPW and violated the provisions of clauses 3.01, 3.02, 3.04, 5.01, and others of the Collective Agreement and the provisions of the Canada Labour Code in denying the President of the Nova Local, Lori Stacey, access to the Halifax Metro Postal Plant.
In addition, the interference by the Corporation in the representation of employees is also in violation of previous and binding arbitral awards between the parties.
Corrective Steps Requested
The Union is hereby applying for a cease and desist order under clause 9.87 of the Collective Agreement and requests the issuance of an interlocutory order that the Corporation cease and desist from denying or interfering with access to the Halifax Metro Postal Plant and any other postal installation in the Atlantic Region by the President of the Nova Local of CUPW or by any other CUPW representatives.
And on the merits of the grievance, the Union requests a declaration that the Corporation is violating the provisions of the collective agreement and of the Canada Labour Code. The Union also requests that the Corporation be ordered to cease and desist from interfering in the representation of employees by CUPW and to cease and desist from denying CUPW representatives access to postal installations.
The Union further requests that compensatory and punitive damages be awarded to CUPW and such other relief as CUPW may advise.