E.F. v. Correctional Service of Canada

E.F. v. Correctional Service of Canada Collection Canadian Human Rights Tribunal Date 2025-05-23 Neutral citation 2025 CHRT 56 File number(s) HR-DP-2856-22 Decision-maker(s) Hadjis, Athanasios Decision type Ruling Grounds Gender identity or expression Decision Content Canadian Human Rights Tribunal Tribunal canadien des droits de la personne Citation: 2025 CHRT 56 Date: May 23, 2025 File No(s).: HR-DP-2856-22 Between: E.F. Complainant - and - Canadian Human Rights Commission Commission - and - Correctional Service of Canada Respondent Ruling Member: Athanasios Hadjis I. OVERVIEW [1] The Respondent, Correctional Service Canada (CSC), has made a motion to strike certain paragraphs in the Statement of Particulars (SOP) filed by the Complainant, E.F. The Complainant and the Canadian Human Rights Commission (CHRC) object to the motion. II. DECISION [2] For the following reasons, I grant the request in part. III. ISSUE [3] Is there a sufficient connection or nexus between the complaint’s allegations and the paragraphs CSC seeks to have struck? IV. BACKGROUND [4] In her complaint, signed on June 26, 2019, E.F. states that she is an Indigenous transgender woman in CSC’s custody and that her complaint concerns a gender-dysphoria assessment conducted and prepared by Dr. Stephen Hucker, a CSC-contracted psychiatrist. Dr. Hucker interviewed her on July 6, 2018, and issued a report on August 3, 2018. [5] E.F. claims that, after interviewing her, Dr. Hucker disclosed personal information about her gender identity and expression to third parties in her home community, effectively outing her, all without her consent. Dr. Hucker also spoke to and sought input from E.F.’s estranged wife. [6] As I noted in an earlier ruling regarding a request to add Dr. Hucker to this case (2023 CHRT 31), the complaint focuses almost entirely on Dr. Hucker’s actions. E.F. contends that Dr. Hucker relied on her estranged wife’s views and on the fact that E.F. had not come out earlier to conclude that she was not a transgendered woman. She adds that Dr. Hucker deliberately misgendered her numerous times in his report. He ultimately recommended that she not be offered feminizing hormones and that she abandon her “strategy” regarding sex transformation. [7] E.F. alleges in her complaint that Dr. Hucker’s conduct towards her amounted to willful and reckless discrimination and harassment on the grounds of gender identity and expression. She specifies that he outed her to persons in her small community, denied her right to self-determine her gender identity, and accused her of falsifying her gender identity based on stereotypical and discriminatory assumptions. [8] The complaint is three pages long. E.F.’s allegations about CSC’s responsibility in this matter are set out in the last paragraph of the two-page portion of the complaint entitled “Summary and details of discrimination at issue”. E.F. states that CSC controls her access to health care and submits that CSC has an obligation to ensure the professionals it hires abide by CSC policies and uphold CSC’s human rights obligations. Since CSC contracted Dr. Hucker’s services, it is liable for his discriminatory conduct and for compounding the discrimination by defending his report and refusing to pay for a new assessment. The last page of E.F.’s complaint form details the impact of the alleged discrimination on her and the steps she took to address it by filing an inmate grievance, which the institution’s warden denied. [9] In accordance with Rules 18 to 20 of the Canadian Human Rights Tribunal Rules of Procedure, 2021, SOR/2021-137, the parties filed their SOPs setting out their positions on the facts on which the complaint is based and the issues raised. [10] CSC claims in its motion that E.F. included in her SOP broader allegations of systemic discrimination that introduce substantially new complaints, which circumvent the CHRC’s gatekeeping function. [11] CSC lists a series of paragraphs (the “impugned paragraphs”) that it submits should be struck as they relate to allegations that are not connected to the complaint and therefore not within the Tribunal’s jurisdiction. CSC also requests that the witness statements of several persons in E.F.’s list of witnesses be struck as they refer to information and allegations outside the scope of the complaint. V. ANALYSIS [12] The Tribunal’s jurisdiction to conduct inquiries into complaints is derived from s. 49 of the Canadian Human Rights Act, R.S.C., 1985, c. H-6 (the “Act”), according to which the Tribunal Chairperson must institute an inquiry into a complaint upon receipt of a request from the CHRC (s. 49(2)). The scope of Tribunal inquiries is thus limited to the matters arising from the complaints accompanying such requests (see Kowalski v. Ryder Integrated Logistics, 2009 CHRT 22 at para 7). [13] When the Tribunal receives a motion to narrow the scope of the complaint or to strike certain items, it is guided by the principles that the Tribunal has developed to determine the scope of a complaint (see Levasseur v. Canada Post Corporation, 2021 CHRT 32 at para 7 [Levasseur]). The Tribunal must determine the substance and the scope of the complaint and decide whether there is a sufficient connection or nexus between the allegations in the SOP and the original complaint (Levasseur at paras 15–16). [14] To determine whether an SOP’s allegations have exceeded the scope of the original complaint, the Tribunal may consult not only the original complaint but also the CHRC’s investigation report and the letters sent by the CHRC to the Chairperson and the parties and any administrative forms (Levasseur at para 17). [15] I have decided to break down the SOP paragraphs that CSC is challenging into six categories for the purposes of my analysis: Allegations that clearly relate to matters alleged in the complaint Allegations dealing with facts arising after the complaint was filed Broad allegations of systemic discrimination Allegations relating to remedies E.F.’s summaries of her witnesses’ anticipated testimony Harassment allegations A. Allegations that clearly relate to matters alleged in the complaint [16] In its list of impugned paragraphs, CSC has included several paragraphs that in my view are clearly related to matters alleged in the complaint. [17] At the bottom of page 2 of the complaint, E.F. states that CSC has total control over her access to health care. She cannot simply choose to see a different doctor or psychiatrist as a patient in the community could. Accordingly, she alleges that CSC has an obligation to ensure such professionals abide by CSC policies and uphold CSC’s human rights obligations. E.F. adds that because Dr. Hucker was under contract with CSC as a psychiatrist, CSC is liable for his allegedly discriminatory conduct. [18] Several of the impugned paragraphs relate to these allegations. Paragraphs 4, 5, 85, and 187, make similar allegations and set out Dr. Hucker’s actions for which E.F. claims CSC should be held liable. These actions are also detailed in the complaint. Paragraph 175 makes a generic allegation about CSC’s obligation to provide health care to persons like E.F. All these paragraphs are therefore not struck. [19] A series of the impugned paragraphs continue on the theme that CSC should be held liable for contracting with Dr. Hucker and failing to monitor and address concerns about him. These passages are found at subparagraphs 188(2) (minus one clause to be discussed later), 188(3), 188(4), 188(5), and 188(6). These are not struck either. [20] The complaint also alleges at page 2 of the complaint that Dr. Hucker applied stereotypical and discriminatory assumptions, which E.F. then elaborates on. Similar allegations are found at paragraph 65 of the impugned paragraphs. It is therefore not struck. [21] E.F. refers at the end of her complaint to CSC’s denial of her grievance regarding Dr. Hucker’s report. The CSC decision included a finding that Dr. Hucker’s assessment complied with approved practices and a suggestion that she get another psychiatric assessment at her own cost. E.F. describes CSC’s position in her complaint as “digging in and doubling down” on Dr. Hucker’s discriminatory conduct. [22] These allegations are all basically reiterated in the impugned paragraphs at subparagraphs 188 (7), (8), (9), and (10). They are therefore not struck. [23] E.F. also mentions at page 3 of her complaint that Dr. Hucker’s “discriminatory report” is now a permanent part of her medical and correctional files, which prevents her from being able to “access gender-confirming health care”. This alleged availability of Dr. Hucker’s report is alluded to in subparagraphs 188(11) and (12), which allege a failure by CSC to keep the report confidential (in a “lock-box”). These provisions are also not struck. B. Allegations dealing with facts arising after the complaint was filed [24] CSC contends that several of the impugned paragraphs deal with allegations relating to incidents occurring after the complaint was filed on June 27, 2019. The first page of the complaint form itself states, under the heading “Start date”, July 6, 2018, and, under the heading “Last date”, May 19, 2019. According to E.F.’s SOP, on this latter date, CSC issued its Initial Level Grievance Response regarding her grievance about Dr. Hucker’s report. [25] CSC argues that if E.F. wanted to bring up facts arising after this date, she should have filed new complaints with the CHRC and followed the appropriate procedures thereafter. CSC claims that the inclusion of these new allegations prejudices it by having to address broad and potentially meritless allegations and to fulfill “enormous” disclosure obligations at the Tribunal stage that would otherwise have been excluded at the CHRC’s gatekeeping process. [26] E.F. contends that the issues relating to the impact of Dr. Hucker’s report were still ongoing when she filed her complaint but points out that the CHRC’s complaint form requires that a date be entered in the “Last date” box in a “dd/mm/yyyy” format. So, the date of CSC’s grievance denial was written in to comply with the form’s directions. E.F. points out that the cover page of the complaint form entitled “Summary of Complaint” gives as the date of the alleged discrimination, “Jul-2018 and ongoing”. I understand that this summary was prepared by the CHRC after it received the complaint, but it was included with the complaint form that was referred to the Tribunal for inquiry. [27] CSC takes issue with the fact that E.F. filed an affidavit with her submissions signed by the Interim Executive Director of Prisoners’ legal Services/West Coast Prison Justice Society explaining the technicalities about filling out the CHRC complaint form. CSC argues that the affidavit is based on hearsay, offends the rule against counsel providing evidence in their own case, and constitutes legal argument. [28] I find the question about the affidavit to be a distraction. Irrespective of the affidavit, the complaint form itself makes it obvious that a person would feel compelled to put some date there. [29] More importantly, the allegations in the complaint itself refer to the potential ongoing impact of Dr. Hucker’s report. At the second paragraph of page 3, E.F. complains about how the report is now part of her permanent medical and correctional files and about how she has been branded a “fraud”, which in turn is preventing her from being able to access gender-confirming health care. As mentioned previously, E.F. also alleged in the complaint that CSC defended Dr. Hucker’s findings and refused to pay for a new assessment. In other words, she is referring to the ongoing impact of Dr. Hucker’s allegedly discriminatory report. [30] Consequently, I find that there is a nexus or, as described in Levasseur at paragraph 43, a continuum between the complaint and any of the impugned paragraphs that refer to the ongoing impact of Dr. Hucker’s report on E.F. even if that impact occurred after the complaint. This includes E.F.’s efforts at redressing that impact by seeking alternative assessments. As I explain later in this decision, my finding does not extend to any allegations that are unrelated to this specific impact of Dr. Hucker’s report on E.F. [31] Impugned paragraphs 10, 114, 118, 119, 121, 123, 124, 125, 126, 127, 128, 129, 130, 131, 132, 133, 134, 135, and 136, all relate to this impact on E.F. [32] I do not find that CSC would be prejudiced irreparably if these impugned paragraphs were retained. The hearing process is still in the early stages. Hearing dates have not been set, and CSC has already had an opportunity to address all of the impugned paragraphs in its SOP. It is not evident that dealing with the ongoing impact of Dr. Hucker’s report on E.F. will lead to excessive delay or costs. The evidence will still relate to E.F. [33] The above-noted impugned paragraphs are therefore not struck. C. Broad allegations of systemic discrimination against E.F. and all gender-diverse persons in CSC custody [34] CSC claims that several of the impugned paragraphs include a broad allegation of systemic discrimination by CSC against her and all gender diverse inmates for failing to provide timely gender-affirming care. CSC contends that E.F. did not raise this broad allegation of systemic discrimination in her complaint and that this introduces substantially new complaints that should not be considered by the Tribunal in the current inquiry. I agree. [35] The impugned paragraphs in question allege that CSC systemically neglected and deprioritized gender-affirming care by, for instance: failing to ensure gender-diverse patients at all CSC institutions have access to primary care providers with appropriate cultural sensitivity and expertise, failing to engage with and fund local community service providers and telemedicine clinics that could provide gender-affirming services, referring gender-diverse patients to backlogged clinics, and failing to be transparent with gender-diverse patients. [36] With respect to E.F. in particular, these impugned paragraphs allege that she has been denied gender-affirming care for years and that there remains no plan for her to receive the gender-affirming surgery that has been recommended for her. The passages do not refer to Dr. Hucker’s alleged discriminatory report. [37] In contrast, the complaint makes no mention of any of these claims. The term or notion of systemic discrimination is not expressed anywhere in the complaint. [38] E.F. alleges that the issue is referred to implicitly. She points to the paragraph at the bottom of page 2 of her complaint, which states that CSC has total control over her access to healthcare and that she cannot simply choose to see a different doctor. CSC must therefore ensure that such professionals abide by CSC policies and uphold CSC’s human rights obligations. The paragraph ends with the allegation that CSC is liable for compounding Dr. Hucker’s discriminatory practice by defending his report as being “approved” and a “common practice”. [39] I do not find that these passages give rise to any nexus with the impugned paragraphs at issue. The complaint clearly relates to CSC’s decision to select Dr. Hucker for her assessment and CSC’s endorsement of his assessment methods. The passages are not related to the broader allegations of gender-affirming care found in the impugned paragraphs at issue. [40] E.F. referred me to the Report for Decision prepared on March 25, 2022, by the CHRC’s human rights officer (HRO). The HRO was mandated to prepare the report to help the CHRC commissioners decide how or whether to deal with the complaint. [41] E.F. points to several references to systemic issues in the Report for Decision. In the first page of the report, the HRO summarizes the complaint and states that E.F. “also alleges that [CSC] pursues a discriminatory policy or practice, specifically failing to apply a human-rights perspective to the delivery of health care services to transgender individuals in its care”. The summary’s next paragraph also mentions that E.F. alleges CSC’s policy regarding disclosure of personal health information and of professional duties and ethics in a doctor-patient relationship is discriminatory. [42] Elsewhere in the Report for Decision, the HRO refers to CSC’s offender grievance process as being incapable of remedying complaints that raise “complex systemic issues”. In the analysis portion of the Report for Decision, the HRO sets out E.F.’s submissions which include statements such as the assertion that CSC must ensure that proper gender-affirming care is available to transgender prisoners and that the health care professionals it contracts with adhere to CSC policies and respect inmates’ human rights. [43] In the Report for Decision’s conclusions, the HRO states that the complaint “raises complex and systemic questions about the respondent’s health policies and practices as they relate to the assessment or gender-affirming medical care”, with implications that could leave transgender inmates vulnerable to discrimination. As a recommendation to the CHRC, the HRO concludes that the complaint has allegations about CSC’s gender dysphoria assessment process, which may have been conducted in breach of CSC policies. The HRO also finds that the complaint raises “broader questions” about CSC’s assessment process through which transgender inmates access gender-affirming care. [44] The CHRC’s subsequent decision of June 15, 2022, to refer the complaint to the Tribunal for inquiry states that, before rendering its decision, the CHRC reviewed the complaint form, the Report for Decision, and the submissions of the parties filed in response to the Report for Decision. [45] E.F. claims these passages point to the types of broader systemic issues in the impugned paragraphs to which CSC objects. [46] Although, as noted in Levasseur, in determining the scope of a complaint, I may consult the investigation report (i.e., the Report for Decision), I am not necessarily bound by any comments or “recommendations” that the HRO may state, even if the CHRC states in its decision that it reviewed it prior to making its decision to refer the complaint for further inquiry. The CHRC referred the complaint without making any specific change or amendment to it. Any interpretation or conclusions that the HRO may have made about the nature of the complaint, even after receiving submissions from the parties, are irrelevant if the allegations in the SOP’s impugned paragraphs at issue have no nexus to the complaint. [47] I do not find any such nexus between the broad allegations at issue and the complaint, which is focused on Dr. Hucker’s assessment. This is not to say that policy or systemic issues may not emerge from the evidence about Dr. Hucker’s actions. But as noted in Richards v. Correctional Service Canada, 2025 CHRT 5 at para 27, the Tribunal’s process is not intended to be an ever-expanding generalized inquiry into allegations about a respondent. Merely because, through the investigation process, the CHRC learns of other matters that it feels would be important to have the Tribunal address does not mean that they should be tethered onto an existing complaint that is far more focused in nature. The amendment of complaints or the filing of additional complaints to address other new issues can amply occur at the CHRC stage, before referral to the Tribunal for inquiry. But once a complaint is referred for inquiry, the Tribunal can only deal with the issues raised in the complaint or that have a nexus to it. [48] E.F. referred to the decisions in Richards v. Correctional Service Canada, 2020 CHRT 27 and Last v. Correctional Service Canada, 2024 CHRT 112, where the Tribunal denied CSC’s requests to strike allegations in SOPs as being outside the scope of the complaints. However, in both cases, the complaints’ allegations contained elements of the matters upon which the broader SOP allegations were made. The same cannot be said here. The complaint is entirely focused on the alleged discriminatory conduct by Dr. Hucker. [49] E.F. points out that CSC, in its response to the Report for Decision, took issue with the document’s references to systemic discrimination. The CHRC nonetheless decided to refer the complaint to the Tribunal for inquiry, and CSC did not seek judicial review of that decision. This does not mean that CSC is precluded from arguing before the Tribunal that allegations in E.F.’s SOP are outside the scope of the complaint before the Tribunal. If a complainant’s SOP allegations do not relate to their complaint, the Tribunal is without jurisdiction to deal with them, irrespective of whether the responding party chose to review the CHRC’s referral decision. [50] For these reasons, the following impugned paragraphs are struck: 1, 2, 14, 15, 17, 68, 69, 137, 138, 139, 140, 141, 142, 143, 144, 145, 146, 147, 148, 149, 150, 151, 152, 153, 154, 155, 156, 157, 158, 188(1), 188(2) (only the clause “and all gender-diverse prisoners in the Ontario Region”), 188(13), 188(14), and 189. D. Allegations relating to remedies [51] CSC submits that E.F.’s requested remedies, as reflected in the impugned paragraphs, should also be struck because they are predicated on the same broad systemic allegations that fall outside the scope of the complaint and therefore beyond the Tribunal’s jurisdiction. Although s. 53(2)(a) of the Act states that the Tribunal may order a remedy designed to redress a discriminatory practice or prevent the same or similar discriminatory practice from occurring in the future, CSC contends that such a remedy is “generally recognized as being oriented towards addressing systemic discrimination” and that systemic remedies can only be imposed when systemic discrimination has been alleged in the complaint. [52] However, as the CHRC correctly points out in its submissions, the Tribunal has a broad and remedial discretion to order appropriate remedies for any discrimination it may find after considering the evidence in a full inquiry, including appropriate systemic remedies pursuant to s. 53(2)(a) (see Hughes v. Elections Canada, 2010 CHRT 4 at paras 49–51). This broad remedial discretion is intended to prevent the same or similar forms of discrimination from occurring, even where the complaint involves a finding of discrimination experienced by one person. The Tribunal considers whether a requested remedy is appropriate after hearing all the evidence rather than as a preliminary matter. Nothing prevents CSC from objecting to a request for public interest remedies at the end of the hearing if it is not appropriate, based on the evidence (Richards v. Correctional Service Canada, 2020 CHRT 27 at para 112). [53] CSC claimed, as it did with respect to allegations of ongoing discrimination, that it would be prejudiced with the inclusion of these remedial claims at this stage and that they will unduly prolong the case. However, it is common for complaints, when they are filed, to provide only basic information about the remedies being sought. One of the purposes of SOPs is to provide greater detail about the remedial claims. The fact that a remedial claim is mentioned for the first time in the SOP does not mean that it falls outside the scope of the case (Liu v. Public Safety Canada, 2024 CHRT 104 at para 29). Any time devoted to dealing with remedies is a necessary part of the hearing process and cannot be avoided. [54] I note that CSC highlighted in its motion E.F.’s request that the Tribunal order the removal of Dr. Hucker from his position, arguing that this would contravene s. 54(a) of the Act. That provision states that no Tribunal order may require the removal of an individual from a position in which they accepted employment in good faith. Although the application of s. 54(a) would certainly need to be explored in addressing this remedial request, it is premature at this time for the Tribunal to assess if the request falls squarely within this limitation or, for that matter, whether the Tribunal has any authority to otherwise order Dr. Hucker’s removal. [55] For these reasons, CSC’s request to strike impugned paragraphs 191, 201, and 202 is denied. E. E.F.’s summaries of her witnesses’ anticipated testimony [56] CSC asked that any will-say statements of E.F.’s proposed witnesses, included in her SOP, that refer to allegations outside the scope of the complaint also be struck. This is unnecessary. The scope of the complaint has been defined with this ruling. Parties will be prevented from introducing any evidence that is outside the complaint’s scope. That said, in my order below, I afford the parties the opportunity to amend their SOPs and replies to take into account my findings and render the pleadings more comprehensible, including the summaries of their witnesses’ anticipated testimony. F. Harassment allegations [57] CSC contends that, in her SOP, E.F. also sought to add a claim that Dr. Hucker’s conduct amounted to harassment, which was not included in the complaint and which the CHRC had not investigated. The complaint does not explicitly mention s. 14 of the Act, the provision relating to the discriminatory practice of harassment. CSC maintains E.F. should have done so if she intended to bring a harassment complaint. [58] Similarly, the “Complaint Information” cover page of the HRO’s Report for Decision only refers to s. 5 of the Act (i.e., the denial of good, service, facility, or accommodation on discriminatory grounds) and its first paragraph states that E.F. alleges discrimination in the provision of services, contrary to s. 5. There is no mention of s. 14. CSC therefore argues that a harassment complaint was not referred to the Tribunal for inquiry since the CHRC never investigated such a claim in the Report for Decision nor did the CHRC specifically indicate that a harassment complaint was being referred. CSC submits that the parties and the Tribunal should not be left guessing as to what was referred to the Tribunal. [59] CSC did not specify in its motion which of the impugned paragraphs contains a claim of harassment and should be struck. By my review, only one of the impugned paragraphs refers to harassment or any variation of the term—subparagraph 188(6)(iv). It alleges that Dr. Hucker revealed intimate information about E.F.’s gender identity and expression, outing her to her family and others without her consent, and did so in a way that subjected her to derision and stigma, which “amounts to discrimination and/or harassment”. [60] I already ruled that subparagraph 188(6)(iv) should not be struck as the paragraph as a whole relates to allegations that are clearly set out in the complaint. However, for the following reasons, I find that the clause referring to harassment should not be struck in any event. [61] The complaint unquestionably refers to the notion of harassment. In the portion of the complaint describing the impact of Dr. Hucker’s actions, E.F. says that “this harassment” was a serious violation of her privacy rights that will have long-term consequences for her life. Paragraph 5 on page 1 of the complaint states explicitly that Dr. Hucker’s conduct towards E.F. “amounts to wilful and/or reckless discrimination and harassment on the grounds of gender identity and expression”. [62] Thus, the allegation of harassment is clearly discussed in the complaint, and consequently there is a nexus with subparagraph 186(6)(iv). The fact that s. 14 was not mentioned in the complaint and in the Report for Decision does not preclude E.F. from alleging and arguing the discriminatory practice of harassment before the Tribunal. For that matter, s. 5 was not mentioned in the complaint either. Indeed, no provision of the Act is mentioned in the complaint form that E.F. filled out. It is only the cover page and the Report for Decision, both of which were prepared by the CHRC, that refer to a specific provision of the Act (s. 5). Notwithstanding what the CHRC or the HRO may have focused on, it is the complaint that the Tribunal must inquire into, not the cover page or the Report for Decision. [63] E.F. may be using the opportunity given by this motion to clarify at this stage of the hearing process that she intends to argue that she was the victim of harassment. This does not prejudice CSC. The facts in support of the harassment allegation appear to essentially be the same as those relating to the claim of discrimination in the provision of a service. The only variation will likely present itself in final submissions when the parties will argue if the case’s facts give rise to either or both types of discriminatory practices. [64] For all these reasons, CSC’s request is granted in part. To keep the pleadings workable, E.F. must amend and refile her SOP with the struck portions removed. [65] E.F. contends that CSC has not responded in its SOP to the impugned paragraphs and has not disclosed all arguably relevant documents in relation to those paragraphs. [66] CSC should revisit its SOP and disclosure documents and provide any additional information and material that should be included in light of my findings. E.F. and the CHRC may in turn file amended replies to the CSC’s SOP to address any changes. VI. ORDER [67] CSC’s request to strike certain paragraphs from E.F.’s SOP is granted in part. [68] The following paragraphs from E.F.’s SOP are struck: 1, 2, 14, 15, 17, 68, 69,137, 138,139, 140, 141, 142, 143, 144, 145, 146, 147, 148, 149, 150, 151, 152, 153, 154, 155, 156, 157, 158, 188(1), 188(2) (only the clause “and all gender-diverse prisoners in the Ontario Region”), 188(13), 188(14), and 189. [69] E.F. must file an amended version of her SOP with the struck paragraphs removed by June 6, 2025. [70] CSC may amend its SOP, list of documents, and list of anticipated witnesses by June 20, 2025. [71] E.F. and the CHRC may file amended replies by June 27, 2025. Signed by Athanasios Hadjis Tribunal Member Ottawa, Ontario May 23, 2025 Canadian Human Rights Tribunal Parties of Record Tribunal File: HR-DP-2856-22 Style of Cause: E.F. v. Correctional Service of Canada Ruling of the Tribunal Dated: May 23, 2025 Motion dealt with in writing without appearance of parties Written representations by: Paul Quick , for the Complainant Laure Prévost, for the Canadian Human Rights Commission David Aaron and Aman Owais , for the Respondent