APPENDIX 1

Complainant: Dr. Emily Carasco

Complaint: (1) Discrimination against Dr. Emily Carasco on the basis of race and sex, by the University of Windsor, University of Windsor Faculty of Law and Professor Richard Moon, contrary to section 5 of the Ontario Human Rights Code.

(2) Systemic discrimination on the basis of race and sex by the University of Windsor and University of Windsor Faculty of La,!" contrary to section 5 of the Ontario HUman Rights Code.

A. Complaint of Individual Discrimination on the Basis of Race and Sex

1. Overview

1. I applied for the position of Dean of the Faculty of Law, University of Windsor, in

November 2009, and as of February 2010 was oneaf the final two candidates on the

short-list. Individual respondent Professor Richard Moon made untrue allegations of

plagiarism against me on the eve of my final interview by the Decanal Search

Committee, when it was becoming clear that I had a serious chanoe of being chosen

over the other candidate. The Chair of the Search Committee, Dr. McCrone, committed

serious violations of my rights in dealing with these allegations.

2. Under Dr. McCrone's leadership the Committee also violated the rules

established by Senate By-law 10 for the conduct of a search. By-law 10 requires that

following a search, the Committee shall propose a name to Faculty Council. The

Committee failed to do so.

3. I was fully qualified for the position of Dean of the Faculty of law, and was the

only one of the two short-listed candidates to be so . I believe that the appointment was

denied to me because of discrimination on the basis of race and sex, on the part of the

Faculty of Law and the University of Windsor (responsible for creating the Search

Committee and for its actions) and Professor Moon. Put quite simply, the Faculty of Law

and the University of Windsor, in spite of the lip service paid to equity and social justice,

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did not want a visible minority woman as Dean of the Faculty of Law, no matter how well

qualified. Moreover, my decades of advocacy on behalf of equity at the University, an

integral part of my identity as a visible minority woman, had left them in no doubt that in

my Deanship I would do more than pay lip service to equity, and this prospect was

unwelcome. Professor Moon's allegations of plagiarism provided a pretext to justify

resistance to my candidacy for the Dean's position. Rather than investigating and

dispelling them, Dr. McCrone and the Search Committee left them to linger to serve as.

a pretext for not recommending me although I met every requirement for the pOSition.

4. I also allege that the University and Faculty of Law have committed systemic

discrimination on the basis of race and sex, by purporting to accept the goal of

employment equity but doing little or nothing over many years to realize that goal, even

when bound by law to do so and even though numerous internal reports and

commissioned studies have urged it to do so. The University and Faculty of Law

leadership remain in the hands of white males; the discrepancy between formal and real

commitment to equality and equity has perpetuated a culture of privilege which white

men expect to have continue, and will defend with impunity. My treatment in the Dean

search is an aspect of that discrimination. That Professor Moon was able to sabotage

my candidacy for the Deanship through defamatory allegations based only on hearsay,

with no accountability for his behaviour, illustrates that the University and the Faculty 01

Law have, through their systemic discrimination on the basis of race and sex, created

an environment of impunity for individual acts of discrimination.

2. Career Track at University of Windsor

5. I was born in Bombay (Mumbai), India. My parents are Goan from India; I and

my family are Roman Catholic. We moved to Kampala, Uganda shortly after my birth.

was a Ugandan citizen until 1972 when General Idi Amin expelled Ugandans of Asian

origin from Uganda. I became a Canadian crtizen in February, 1983.

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6. I received my LL.B. in 1971 from Makerere University in Kampala, Uganda

and in 1972 my family and I were required 10 leave Uganda on extremely short notice

as refugees from the Amin government's persecution of persons of Indian ethnicity.

7. From 1972 to 1979, I attended the Harvard Law School, Harvard Universrty.

received my LL.M. in 1974, and my S.J.D. in 1979.

8. In 1979, I served as Research Assistant to the Official Guardian of Ontario, in

what is now called the Children's Lawyer's Office.

9. In 1980, I secured a one-year teaching contract at the Faculty of Law,

University of Windsor. The Dean at the time was Ron Ianni. My starting salary of

$20,132.00 was below the floor in the CollecUve Agreement for such pOSitions, and was

adjusted upwards, but only to the floor, after I was hired. Apart from Dr. Ianni , the Dean,

I was the only member of the Faculty of Law at that time to have a doctorate in law.

10. In 1981 , I secured a tenure-track position in the Faculty of Law at the Assistant

Professor level , and in 1984, I was promoted to Associate Professor, with tenure. I did

not have any difficulty securing tenure and promotion to Associate Professor.

11 . I served as a member of the Status of Women Committee of the University of

Windsor Faculty Association (WUFA) from 1983-88 , on the EXecutive ofWUFA in 1985-

86, and as Vice-President, External ofWUFA in 1987-88.

12. When I became President ofWUFA in July 1988, I became aware of the details

of an agreement signed between the University and the Faculty of Law in the spring of

1988, for the distribution of an Anomalies Fund created by Article C 12 of the Collective

Agreement to provide salary adjustments to members of the Faculty of Law. Professor

Jeffrey Berryman was one of the two negotiators of the agreement on behalf of the

Faculty of Law. The other was Professor Robert Kerr, since deceased.

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13. In October 1988, WUFA filed ~ grievance on my behalf alleging arbitrary and

discriminatory distribution of the Anomalies Fund at the Faculty of Law. At that time, my

salary was the most anomalous within the Faculty. I was being paid less than the two

other persons hired the same year as I was, even though they both had three years

less post-LL.B education than I did. The distribution scheme negotiated by Professors

Berryman and Kerr, which included a cap on the overall recovery possible from the

Fund, left me as anomalous as I had been in relation to these individuals, and still left

me in the situation of having the most anomalous salary within the Faculty.

14. In March 1990, arbitrator Gail Brent found that WUFA had "proven, on balance,

a prima facie case of systemic discrimination on the basis of sex .. . both in the

establishment of the grievor's hiring salary and in the distribution of the anomaly fund".

The Arbitration Award contains a detailed account of the salary discrimination against

me.

15. The arbitrator found that the appropriate remedy was that the University should

redo the distribution of the fund which had been done improperly the year before (a

remedy which WUFA had not requested), and that she did not have the jurisdiction to

order the remedy requested by WUFA which was to order the University to award the

me the sum of money I would have received if a cap had not been put on the amount

received. After many discussions and negotiations with University President Ron lanni,

he appointed an internal University committee which decided unanimously in January

1991 that I (and all the female faculty members) should be compensated appropriately,

retroactive to July 1, 1988. A year after negotiating the distribution of the anomalies

fund, Jeffrey Berryman became Dean of the Faculty of Law, commencing his term in

July 1990.

16. In the spring of 1990, I applied, unsuccessfully, for the position of Associate

Dean . A white colleague, Professor Donna·Marie Eansor, was appointed. Professors

Jeffrey Berryman and Maureen Irish were the faculty members on the search

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committee. Professor Eansor, while a very competent young colleague, had neither

the academic qualifications nor the experience that I had at that time.

17. In academic years 1989-90 and 1990-91 , I was a member of the University

President's Advisory Committee on Women's Issues, and in 1990-91 , a member ofthe

University's Planning Committee on Race Relations, and of the Employment and

Educational Equity Advisory Committee at the University. In 1991-92, I was a member·

of the President's Commission on Prejudice and Discrimination.

18. Having served as the Chair of the Employment Equity Committee of the Ontario

Confederation of University Faculty Associations (OCUFA) (1990), and on the OCUFA

executive, I became OCUFA Vice-President in 1993. I served as President of OCUFA in

1994 for a one-year tenn.

19. From 1996 to 1999, I served at the request of the President of the University,

Dr. Ianni, as the first Commissioner of Human Rights at the University of Windsor. I set

up the University's Human Rights Office, hiring support staff and organizing an Office

that would receive and investigate complaints as well as carry out educational initiatives

regarding human rights. Working with apprOXimately seven unions on campus, leaders

ofthe various student groups, non-unionized staff and the University Counsel, I

developed a comprehensive Human Rights Policy for the University. The policy

encompassed substantive obligations as well as a process for investigation and

resolution of complaints.

20. The Human Rights Policy which I developed stated on its face that it should be

reviewed within five years of its adoption, but the University has not done that. The

Human Rights Office which I set up has been slated for over a year to be converted into

a Human Rights, Equity and Accessibility Office but the UniverSity has not done this yet,

and the original Human Rights Office operates in the interim under a temporary director.

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21 . In academic year 1998-1999, I applied for promotion to full Professor. A

promotions oommittee at the Faculty of Law, oomprised of Professors Moon, Bill Conklin

and Marcia Valiante and chaired by Dean Westmoreland-Traore rejected the application

although both of the external reviewers had recommended promotion.,

22. I appealed to the University Committee on Appointments, Promotion and

Tenure (UCAPT), which draws its membership from the University as a whole, and

UCAPT unanimously overturned the decision of the Faculty of Law.

23. I have been a full Professor at the Faculty of Law since 1999. I teach, write and

research in the areas of International Law, Family Law, Immigration Law and Human

Rights.

24. I have served on a number of law school Committees, including Admissions,

Discipline, AppOintments, Equity, MBNLLB, Promotion Tenure and Renewal, and Law

Foundation. In addition to my human rights and equity work at the University level, I

have served on the University Senate, as a member of UCAPT, as Chair of the Campus

Safety Audit Committee, and as Chair of the Senate Strategic Renewal Committee. In

2008, I was the Chief Negotiator for the University of Windsor Faculty Association,

successfully leading WUFA in negotiations for a new collective agreement between the'

University and its faculty and librarians.

25. In addition to my keen interest in mentoring students on an informal basis, I

have for twenty years been the coach of the Faculty of Law team for the Jessup Moot,

one of the premier national and international mooting competitions. I have worked with

law students to establish Justice at Work, a highly successful annual event where

students' who are interested in careers in social justice are able to meet and learn from

lawyers already established in the field in Ontario and elsewhere. I have initiated and

done the fund-raising for two scholarships at the University, including one where the

money was raised solely from Windsor law alumni.

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26. My service to the Windsor community includes being a member of the Board of

Directors of the United Way of Windsor, a member of the Big Sisters Association of

Windsor, the Windsor Committee of the National Organization for Visible Minorities, the

Mayor's Committee on Children's Services of Windsor, and the Board of Directors of the

South Asian Centre of Windsor: I have also served as the President of the Board of

Directors of the Roman Catholic Children's Aid Society of Windsor. These activities, and

others I have undertaken in the community, have involved fund-raising along with other

responsibilities.

27. My activities in the legal profession include being a member of the Gender

Issues Committee of the Canadian Bar Association - Ontario, and serving as a member

of the Board of Editors of the Canadian Journal of Women and the Law (1984-91) and

the Review of International Business Law (1985-89). In 1992, I served as the Chair of

the Ontario Judicial Appointments Advisory Committee. I also served as a member of

that Committee in 1995-1996. Currently, I am a member of the Advisory Committee of

the African-Canadian Women's Human Rights Project, a collaboration among

academics and activists in Canada, Ghana, Malawi and Kenya to advance women's

rights that is entirely supported 'by fund raising in Canada and internationally.

28. I was named Windsor Woman of the Year in 1993, and in 1994 was honoured

with the deSignation Honorary Big Sister by the Big Sisters Association of Windsor. In

2006, I received an Honourary LL.D. from the Law Society of Upper Canada, and the

Feminist Legal Analysis Section of the Ontario Bar Association gave me its

Commitment to Equality Award in 2009. In 2010, I received from the University of

Windsor Faculty Association the Mary Lou Dietz Award for Equity Leadership.

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35. During our work to enhance opportunities for women and members of visible

minorrties at the Universrty, I and other activists have followed three principal strategies.

One is to put in place decision-making processes which are transparent and fair; it has

always been thought that if the process itself is transparent, it will produce objective

decisions not tainted with bias. The second strategy has been to strive for

improvements in employment equity, so that more women and persons of colour could

move into teaching, professional and leadership roles on campus. The third has been to

work for improvement of the climate on campus, by addressing systemic human rights

abuses, workplace bullying and power imbalances; by making space for a variety of

religious beliefs, and making evident the entrenched privilege of white male faculty and

University leadership .

36. My recent activities within the Faculty of Law are consistent with these

strategies. I believe they have been seen as threatening.

37. In December 2007, I moved a motion at Faculty Council in the Faculty of Law

to end the practice of cancelling classes on the Jewish High Holidays. The students at

the Faculty of Law observe a variety of religious holidays, for almost all of which classes

are not cancelled . My motion was aimed at treating in the same way most student

absences for purposes of religious observance: classes would not be cancelled and

class notes or recordings would be made available to students taking time for religious

duties. Although I could do nothing about the statutory preference for Christian

holidays, when the University is closed , I wanted to place other religions on an even

footing .

38. The motion generated considerable discussion and debate at the law school.

Professor Moon confronted me in the presence of a support staff person and asked me

if I had clearly thought about the implications of my motion and proceeded to inform me

that it was a very bad idea. I politely disagreed. Professor Moon opposed the motion

strenuously at Faculty Council. The motion nevertheless succeeded with a clear

majority.

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39. The notice of motion, and the actual motion that was passed, provide as

follows:

In light of the ever-increasing religious and cultural holidays that are now an everyday part of life in Canada, I believe that it is time for us to set out a clear statement about our policy on the subject. I am therefore giving notice of motion Regarding the following resolution that I would like to place before Faculty Council:

Recognizing the tremendous religious, ethnic and cultural diversity amongst our student body, faculty and staff, and in the spirit of the Canadian Charter and Human Rights legislation, be it resolved that henceforth the Faculty of Law, University of Windsor will no longer cancel classes for any specific religious observance, but will provide reasonable accommodation for all students, staff and faculty who are unable to carry out their responsibilities due to a desire to observe religiouS/cultural practices.

40. In the past two years, I have twice taken a position in favour of adhering to

the University's hiring procedures in connection with the appointment of junior faculty at

the Faculty of Law. In both cases, strict adherence to such procedures might have

rendered uncertain (but by no meanS have precluded) a particular result desired by the

Dean and a group of senior members of the faculty. The University's hiring procedures·

were not adhered to in either of these cases, and my advocacy for compliance with

them was seen by proponents of these particular hires as threatening and

confrontational. I have leamed over the course of my advocacy for employment equrty

that in the long run equity and fairness are best served by openly following established

procedures and not by quietly bending or ignoring the rules to achieve a desired result

in a particular case.

4. Decanal Search

(a) Rules for Dean Search

41 . The rules and procedures for a Dean search are established by By-law 10 of

the Senate By-laws.

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42. By-law 10 provides that the Dean of a Faculty is the leader of his or her

Facu~y and shall possess the appropriate qualifications therefore.

43. Article 2.2.1 of By-law 10 requires the establishment of a Search Committee,

composed of the Provost and Vice-President Academic as chair, -three to six faculty

members elected from and by the regular faculty, an Employment Equity Procedures

assessor, student members and up to two staff, professional or community

representatives determined by the Search Committee.

44. Article 2.3.2 of By-law 10 requires that the search process shall be initiated

normally fifteen months prior to the expiration of the term of the incumbent Dean. Article

2.3.4 requires that at least one calendar year prior to the expected date of appointment

the Search Committee shall report to the Faculty Council and the President setting out

its proposed agenda, including its mode of operation , schedules for the search

procedure and schedules for the submission of periodic reports to the Faculty Council

and the President.

45. Article 2.3.6 of By-law 10 requires that the Search Committee prepare a

short-list of candidates (one to three) and obtain views and comments in an appropriate

manner from members of the Faculty Council. The short-list shall normally be

announced to the Faculty Council six months prior to the expected date of appointment.

46. Article 2.3.8 of By-law 10 states that following a search, the Search

Committee shalf propose the name of a single candidate in writing with appropriate

supporting material to the Faculty Council. This provision requires that the Committee

submit the name of one of the two (or three) short-listed candidates to Faculty Council if

the search has progressed to the point of having such a short-list. At a meeting called

on five calendar days written notice, the Faculty Council shall consider the

recommendation of the Committee. Voting at the Faculty Council shall be by secret

ballot, and a simple majortty of the votes cast is required to endorse the named

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candidate. Article 2.3.9 requires that the name of the candidate endorsed by the Faculty

Council shall be submitted to the President.

47. If the Candidate recommended by the Search Committee is not endorsed by

the Faculty Council, Article 2.3.10 of By-law 10 requires that the search Committee

shall reconsider its recommendation. If the second candidate recommended by the

Search Committee is not endorsed by the Faculty Council, then the Search Committee

can be reconstituted.

48. If the candidate endorsed by the Faculty Council is not accepted by the

President, Article 2.3.11 of By-law 10 requires that the Search Committee reconsider ~s

recommendation. If the Search Committee's second recommendation is not accepted

by the President, the Search Committee is required to be reconstituted.

49. Article 2.3.12 of By-law 10 outlines what the Chair of the Search Committee

can do if the search is not progressing. If the Chair of the Search Committee declares

that a lack of Committee progress requires it, he or she may request that the Faculty

Council decide among the following alternatives: that the Search .committee agenda be

altered , that an acting appointment be made or that the Search Committee be

reconstituted.

50. If the reconstituted Search committee is unable to make a recommendation,

or if their recommendation is not endorsed by the FacuHy Councilor the President,

Article 2.3.13 of By-law 10 provides that the President may recommend a candidate to

the Board of Governors.

fbi My Candidacy for Position of Dean

51. Dean Bruce Elman being scheduled to complete his second term on June 30,

2010, a Search Committee for the position of Dean of the Faculty of Law was struck in

the spring of 2009. The Chair was originally Provost Neil Gold ; when he received a one-

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year appointment as Vice-President, International of the University, he waS succeeded

as Chair by Kate McCrone, then acting Provost and Vice-President Academic.

Membership on the Search Committee included the following members of the full-time

faculty at the Faculty of Law: Larry Wilson, Donna Eansor, Moira McCarney, Laverne

Jacobs, Chris Waters (Associate Dean) and Jeffrey Berryman. Other members of the

Search Committee were Judge Mary Jo Nolan, Michelle Pilutti of the staff at the Faculty,

and the President and Vice-President of the Student Law Society, Arun Krishnamurti

and Omar Raza. The Equity Assessor was Clinton Beckford , Associate Dean of the

Faculty of Education . The search firm of Odgers Berndtston , Toronto, was retained to

assist in the search.

52 . The advertisement for the position of Dean was published in October 2009. It

described as follows the attributes being sought:

A distinguished academic, the new Dean will continue to expand on the Faculty's themes of Access to Justice and Transnational Law, while providing professional direction and collegial leadership. A member of the University's senior management team, the Dean of Law will have experience in academic administration, will be a visible and vocal champion of the institution and the Faculty, and will be active in raising their profile and increasing support for their· continued expansion. .

53. The advertisement also stated that the University of Windsor is committed to

equity in its academic policies, practices, and programs; supports diversity in its

teaching, learning and work environments; and ensures that applications from members

of.traditionally marginalized groups are seriously considered under its employment

equity policy. Among those identified as likely to contribute to the further diversification

of the Faculty and its scholarship were women and 'members of visible minorities.

54 . The description of the Faculty of Law appended to the advertisement

described the key themes of the Faculty as Access to Justice and Transnational Law,

which run through research, teaching and learning. It emphasized that the school's

admissions policy ensures a diverse and dynamic student body.

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55. The material accompanying the advertisement also identified the following

attributes and proposed activities of the new Dean:

• As a member of the University's senior management team, the Dean will seek to enhance relationships with local, national, and international governments, the profession, donors, alumni, and community leaders, so as to raise the profile and influence of the Faculty and the University. .

• Building on the Faculty's existing reputation and its recognized strengths in the fields of transnational law and social justice, the new Dean will find ways to enhance the profile of the Faculty overall . This is an overarching priority ...

• Thus, an immediate priority for the new Dean will be to continue and expand this effort to attract and retain first-class teaching and research talent, from within Canada and around the wo~d .

. • The new Dean will be expected to engage the Canadian university community on an academic level , including attending and encouraging attendance at conferences.

• Building on the University's commitment to renewal and innovation, it will be incumbent upon the new Dean to explore Canada's legal education landscape in search of topical, vibrant, and innovative communities of scholars with which Windsor Law may wish to connect.

• The position of Dean, Faculty of Law is emphatically an opportunity to help make good on those promises regarding the role Windsor will play in the renewal of the Windsor-Essex community, particularly given prevailing economic and attendant social conditions in the Region.

• At the heart of the Windsor Law educational experience there is support for making the concepts of transnational law and Access to Justice pervasive. The new Dean will review the way the concepts of transnational law and Access to Justice are integrated into the curriculum.

• If Windsor Law is to continue to champion the advancement of social justice and transnational law, ij will be a priority for the new Dean to build a comprehensive support network to assist graduates in finding work in related areas. The new Dean will work creatively with students, faculty, and professional groups to explore alternative careers in the legal profession and to define Windsor Law as an institution that actively supports its students in finding new ways to put their skills into service - while at the same time ensuring that they have the uriderstanding and skills necessary for the more traditional practice of law.

• That being said, increasing the diversity of the program remains an internal priority, and one that enjoys support at all levels of the UniverSity community. This also means enacting initiatives to support students with disabilities and being sensitive to the needs of visible and other minorities.

• To be successful in this endeavour, the new Dean must be someone who genuinely enjoys the external aspect of his/her role, as well as someone who considers the fundraising pursuits of Deanship to be a worthy responsibility.

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56. In any selection process at the University of Windsor, each candidate is

assessed against the qualifications outlined in the advertisement; an evaluation grid is

created to evaluate each candidate systematically, and scores are assigned to the

candidate for each qualification on the grid. This evaluation produces the short-list and '

ensures that each candidate on the short-list meets the advertised requirements. Short­

listed candidates are then assessed by way of an evaluation grid, to measure their

performance in the interview with the Selection Committee. The assessment of short­

listed candidates will also measure their performanoe in other activities taking place

after the short list is announced .

57. I submitted my application for the position of Dean by letter dated November

26, 2009. In the first week of February 2010, Professor McCrone advised me that I was

one of four candidates who would be participating in a preliminary round of interviews. I

was interviewed on February 15, 2010, for two hours. Dr. McCrone advised me by

telephone on February 21 that I was on a short-list of two individuals. On February 27,

2010, I was asked to provide a list of nine referees, which I forwarded to Odgers

Berndtston.

58. Subsequently, I learned from some of the referees whose names I provided

that they had been interviewed in quite a cursory manner by someone telephoning from

South Africa , on a bad telephone connection, on behalf of the search firm. I also believe

that letters of reference from other supporters were not placed in their entirety before

the Search Committee.

59. The week of March 22, 2010 was established for the interviews of the two

short-listed candidates and other activities requiring the participation of both of us.

Among the activities I took part in that week on the initiative of the Search Committee

were a meeting of the Windsor Bench and Bar hosted by Judge Nolan (March 23),

meetings with other Deans and the University President (March 24), a Town Hall

meeting at the Facufty of Law (March 24), a meeting with Dean E;lman of the Faculty of

Law (March 25) and a two-hour interview with the Search Committee (March 25) . On

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March 26, I flew to Toronto to meet with alumni of the Law Faculty, and had a further

meeting with an alumnus on March 27. As far as I am aware, the other short-listed

candidate took part in most of the same activities. As these meetings progressed, I was

receiving positive feedback from my colleagues and others, and it was becoming

evident that my candidacy had a strong chance of success.

60. On March 24, 2010 the day before my crucial final interview with the Search

Committee, Professor Moon surfaced with spurious allegations that I had committed

plagiarism during my co-authorship of an immigration and refugee law casebook

between 2003 and 2006. Professor Moon forwarded to Dr. McCrone on March 24, an e­

mail in which he made allegations of a ''very serious" problem of plagiarism, which

"when discovered required that the chapters prepared by Emily be recalled from the

publisher and repaired/rewritten by the other editors". He acknowledged in his e-mail

that his knowledge of this issue was second-hand, and acquired almost two years

before from Professor Audrey Macklin, one of my co-authors, whom he had married

subsequent to our collaboration on the book. He suggested that Dr. McCrone might

wish to contact the co-authors of the book, who "have copies of the chapters Emily

originally submitted and the sources that were not properly referenced". Professor

Moon made these allegations to me and to Professor McCrone bye-mail and he also

discussed them with other members of the Faculty of Law.

61 . Professor Moon's reasons for making these spurious allegations at the

eleventh hour are highly suspicious. Had he seriously been concemed that an academic

offence had been committed, he had ample opportunity to raise the issue through the

proper processes at any time after he allegedly learned of them, which was almost two

years before the search. He did not ever do this. Rather, he raised them at a time and in

a manner that would do maximum damage to my reputation and candidacy, without

subjecting his allegations to the testing or scrutiny of a hearing where I had standing

and an opportunity to respond .

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62. As I sought to explain to the Committee, from 2003 to 2006 I collaborated with

three other scholars to prepare'a casebook on Immigration and Refugee Law. I was

primarily responsible for chapter 1, a history of Canada's immigration policy. The

manuscript was circulated amongst the co-authors tor two years before being submitted

to the publisher; some of the co-authors taught from it. It was part of a blind peer­

reviewed process early in 2006. I was not advised of any issue with respect to my

chapter until after the galley proofs were prepared. When one of the co-authors, Don

Galloway, was reviewing the galley proofs supplied in 2006 by the publisher, he told me

bye-mail that he had found instances where I had not given sufficient attribution to one

particular source. He did not identify for me in this e-mail , or at any time since, the

specific problems in attribution which he claimed to have found. Nor did he give me the

opportunity to insert the attributions myself. Rather, he secured approval from the co­

authors to do the work himself, and I agreed because I was in England dealing wrth a

family emergency. Professor Galloway made substantial alterations to the galley prOOfs

of my chapter, removing my material outlining the history of racism in Canada's

immigration policy. He had not discussed with me beforehand his intention to make

such extensive revisions, nor had he secured my permission to do so, My review of the

original chapter in 2010 disclosed no problems in attribution justifying this re-write. I did

find that I had made voluminous attributions to the author identified by Professor

Galloway. At no time in his dealings with me about the alleged shortcomings in

attribution had Professor Galloway alleged plagiarism, as Professor Moon later did. Nor

did my co-authors ever make that allegation, either when the matter first came up or in

2010.

63. In reviewing the whole Galloway incident at the time of the Dean search in

March 2010, I concluded that I should have resisted more sturdily Professor Galloway's

comments about my chapter. I came to see his focus on the attribution issue as a way

of providing himself with an opportunity to remove material on racism which he believed

should not have been included. I was the only person of colour on the four-person

writing group ..

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64. In handling Professor Moon's allegations of plagiarism, Dr. McCrone

committed several serious violations of my rights. She did not provide me wtth a copy of

the Moon e-mail of March 24 until March 30, even though she had previously raised

these allegations with the Search Committee, and indeed raised them with me in the

presence of the Search Committee at the end of my final interview by the Committee on

March 25 before I had seen Moon's e-mail to her.

65. She told me that the Search Committee had considered Moon's allegation to

be of sufficient seriousness to request that she contact my co-authors, and she did

contact them. They all emphasized the urgency of showing the Committee my original

chapter and the source mentioned by Professor Galloway, so that the Committee could

make up its own mind on the basis of the facts. At her request, I provided to Dr.

McCrone a copy of chapter 1 and the book by Valerie Knowles I had used as a source.

She told me in an e-mail sent March 28 at 11 :37 a.m. that she wanted to provide this

material to the Committee so that they could "see the material in question for

themselves". In a letter to me of April 6, Dr. McCrone stated that "given that the Dean is

the highest academic officer of a faculty, the Search Committee has a responsibility to

ensure that the issue that has arisen is clarified".

66. Despite all of these assurances, Dr. McCrone did not provide chapter 1 to the

Committee so that it could make up its own mind, a fact I learned only on the morning of

April 7, the day I was to have a final meeting with the Committee, so that I could

address these accusations.

67. Dr. McCrone did not tell me who made the decision that the Committee would

not review the chapter and the source, or why that decision had been made. I was

surprised and disappointed that the Search Committee was not given this material,

especially in light of Dr. McCrone's assertions that the Committee has a responsibility t9

clarify the issues. I nonetheless attended the meeting of the committee on April 7 and

made a detailed statement rebutting the allegations. The Committed posed no

questions, and no discussion with the Committee ensued. Neither the Committee nor

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Dr. McCrone ever made a statement dealing with Moon's allegations even though I had

specifically stated in a letter to Dr. McCrone of March 31 that in the circumstances I was

entitled to a "clear statement from you negating the very damaging allegations made

against me". The allegations were left hanging over me to blight not only the Dean

Search but also my future. They create a poisoned environment at the law SChool, and

the academy generally.

68. On March 31 , 2010 at 11 :43 a.m. one of my colleagues sent Dr. McCrone by

e-mail a detailed analysis of the so-called plagiarism, and evidence of computer

searches totally invalidating the allegations. Dr. McCrone refused to put it before the

Committee, writing in an e-mail at 10:21 a.m. on April 7: "your ... communication dated

March 31 with respect to 'plagiarism', with attachments, provides your personal analysis

of the matter. It is the search Committee's responsibility to determine whether or not

they wish to undertake such an analysis themselves. As such it would be inappropriate

to provide it with your communication ... I will not be distributing it to the Committee".

However, Dr. McCrone had already put before the Committee Moon's allegations, which

were not backed up with any evidence or analysis. I believe that Dr. McCrone gave the

Committee a copy of Moon's accusatory e-mail of March 24, as she provided it to me,

and told me in her April 2 e-mail that "everything provided to the Committee will be

provided to you". It is also surprising to me that Dr. McCrone told my colleague on April

7 that "it is the Search Committee's responsibility to determine whether or not they wish

to undertake such an analysis themselves" (emphasis supplied) when she had already

assured me that they would do so, and requested material from me to facilitate that

analysis.

69. Dr. McCrone never advised me of the role Professor Moon's overblown ,

hearsay-based, allegations of plagiarism had played in the Committee's decision

making, even though I asked her to do so on at least two occasions. The response of

Professor McCrone and the Committee to the Moon allegations did not give me a fair

opportunity to counter and dispel them. Although they received submissions from me in

writing on March 31 and in writing and orally on May 7, they never examined the original

- 20 -

documents, as the co-authors had urged, and thus did not give me an opportunity to

address any concerns they had on the basis of that review.

70. I believe that the behaviour of Professor Moon in bringing these allegations

forward , and the serious irregularities in the way Professor McCrone and the Search

Committee dealt with them, would not have occurred had the Faculty of Law not been

on the brink of choosing a woman of colour as its Dean. The allegations of so-<:alled

plagiarism presented a convenient pretext for the denying me the position. The actions

of Professor Moon and the Committee (including its Chair) amount to discrimination

against me on the basis of race and sex.

71 . In addition to the failure to deal appropriately with the Moon allegations, the

Committee committed serous breaches of By-law 10. Article 2.3.8 of By-law 10 imposes

a mandatory requirement that following a search , "the search committee shall propose

the name of a single candidate in writing with appropriate supporting material to the

members of the .. . Faculty Council." To fulfil this requirement, the Search Committee

must actually choose between the two short-listed candidates.

72. Dr. McCrone did not require or permit the Search Committee to choose, by

vote, between me and the other short-listed candidate. Rather, she presided over a vote

which included the option of choosing neither candidate. This approach is

unprecedented in searches at the University of WindsDr. As Chair, Dr. McCrone should

have required the Committee to choose one candidate or the other.

73. The Committee voted in favour of chOOSing neither candidate and thus never

weighed or discussed the merits of the two short-listed candidates as required by the

By-law. These irregularities were brought to President Wildeman's attention on April 9,

2010 and he indicated his support for this procedure. Dr. McCrone reported to the

Faculty Council at the Faculty of Law on April 14 that the Committee had voted to

recommend neither candidate, thus depriving the Faculty Council of its assigned

responsibility of considering the Committee's recommendation. This approach runs

- 21 -

counter to the requirements of By-law 10. If the Committee had been deadlocked after .

going through the proper evaluation and discussion, and proper voting procedures, By­

law 10 spells out what is to follow. Nowhere does By-law 10 provide for the procedure

followed by Professor McCrone.

74. At the Faculty Council meeting on April 14, Dr. McCrone advised that the

Search Committee had voted to recommend neither candidate. She told the Faculty

Council that neither candidate met the requirements for the position. Dr. McCrone did

not give reasons for this conclusion . Nor has she ever advised me personally why the

Committee decided I did not meet the requirements of the posrtion.

75. The Faculty Council voted to strike a new search Committee and do another

search. This procedure does not comply with Article 2.3.12. A new Search Committee

was struck on April 28, 2010. Dean Bruce Elman has been appointed Acting Dean for.

the year 201 0-2011. The appointment of Dean Elman as acting Dean would not stand in

the way of my appointment as Dean, should the Tribunal make such an order. However,

appointment of a Dean after the conclusion of this second search may do so, and I will

be pursuing interim relief to halt the search process and prevent the appointment of a

new Dean under By-law 10 until this complaint is finally resolved. The Universrty has

refused my request to suspend voluntarily the search process to permit my complaint to

be heard.

76. I believe that the violations of By-law 10 committed after April 7, 2010 reflect

the Search Committee's indecent haste to dispose .of my candidacy, and constrtute

discrimination against me on the basis of race and sex.

77 . I meet all of the required criteria for the position of Dean of the Faculty of Law,

and believe that I am the only one of the two short-listed candidates to do so. The

appointment was denied to me because of discrimination on the basis of race and sex,

on the part of the Faculty of Law and the University of Windsor (responsible for creating

the Search Committee and for its actions) and Professor Moon. Put quite simply, the

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Faculty of Law and the University of Windsor, in spite of the lip service paid to equity .

and social justice, did not want a visible minortty woman as Dean of the Faculty of Law,

no matter how well qualified. Moreover, my decades of advocacy on behaW of equity at

the University, an integral part of my identity as a visible minority woman, had left them

in nO doubt that in my Deanship I would do more than pay lip service to equity, and this

prospect was unwelcome. Professor Moon's allegations of plagiarism provided a

pretext to justify resistance to my candidacy for the Dean's position. Rather than

investigating and dispelling them, Dr. McCrone and the Search Committee left them to

linger to serve as a pretext for not recommending me although I met every requirement

for the position. That Professor Moon was able to sabotage my candidacy for the

Deanship through defamatory allegations based only on hearsay, with no accountability

for his behaviour, illustrates that the University and the Faculty of Law have, through

their systemic discrimination on the basis of race and sex, created an environment of

impunity for individual acts of discrimination.

B. Complaint of Systemic Discrimination on the Basis of Race·and Sex

78. Like the Faculty of Law, the University of Windsor has now, and has always

had, a leadership almost exclusively comprised of white males.

79. Since 1980, when I first came to the Universtty, ali the Presidents have been

white males. Since 1980, ali of the Vice-Presidents Academic have been white males,

with the exception of Dr. McCrone, who was acting Provost and Vice-President from

July 2009 to April 2010 , the period comprising the Dean Search. A new position of Vice­

President Teaching and Learning, created in 2007, has a white male as its first

incumbent. The Vice-Provost, Students and Registrar has been a white male since the

position was created in 2005. Similarly, the only two incumbents of the position of

Associate Vice-President Academic Affairs, created in 1999, have been white males.

White males have occupied the position of Vice-President Finance '(Iater Finance and

Administration) since 1981 .

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88. A Review Committee on Employment Equity (RCEE) was formed in 1987,

pursuant to Article 30 in the Collective Agreement, dealing with employment equity.

The RCEE, comprised of representatives from the administration and the faculty, was to

investigate and report on whether serious gender imbalances existed in the composition

of academic units at the University, recommend hiring goals to address such

imbalances, review the University's actions to achieve the hiring goals recommended,

and report its findings and recommendations annually to the Senate, the Universrty and

the Faculty Association.

89. The RCEE made its first report in 1988, and reported a·nnually until 1995. In

that year, it submitted rts Sixth Report, urging implementation of th~ recommendations

of past reports. Of particular concern was the failure of the University to set goals and

timetables for hiring visible minorities, Aboriginal peoples and persons with disabilities to

parallel the eXisting goals and timetables for women. When the University took no

action on these recommendations for two consecutive years, the RCEE stopped

meeting, and did not resume until it was reconstituted in 2007.

90. The lack of meaningful progress on equrty from 1993 led to the creation of the

President's Working Group on Equity Review (WGER) in 2004. Its 2005 Report, which

was approved by the Senate that year, found that there had been a considerable gap

between the original policies arid procedures for implementing employment equity

adopted by Senate and their implementation . It found that overall implementation of

employment equity had weakened gradually over the years to the point that many of the

important details of the original program, such as having goals and. timetables for hiring

members of the four groups designated by the Federal Contractors Program, had been

lost.

91 . The WGER observed that the Senate had not acted on two requests from the

Review Committee on Employment Equity to establish goals for the designated groups

of visible minorities, Aboriginal peoples and persons with a disability. After 2000, when

the initial timetables for reaching the equity goals of hiring women faculty had expired,

- 26 -

no new goals were established . With the expiry of the initial goals for women's hiring,

the University was thus, as of 2000, without goals or timetables for 'any of the

designated groups. This left the RCEE, whose mandate was to monitor implementation

of goals and timetables, with nothing to do.

92. WGER recommended in 2005 that Senate set goals and timelines for

representation of women and visible minorities. It also recommended that Senate

establish a separate task force for each of Aboriginal peoples and persons with a

disability to bring back recommendations on specific programmes to encourage the

identification, recruitment and hiring of well-qualified candidates from these areas. The

University administration failed .to implement any of these recommendations.

93. Pursuant to a recommendation in the WGER report that an external expert

with significant expertise in employment equity issues in the University setting be

retained , Dr. Rebecca Coulter of the University of Western Ontario was retained to

advise Senate, and in April 2006 she submitted her report, Making it Real.

94. Among her recommendations was that specific goals and timetables for

meeting equity objectives be set, monitored and evaluated by means of a reconstituted

Review Committee on Employment Equity. This has not been done. The University of

Windsor does not now have goals or timetables with respect to any of the four

designated groups.

95. Among the other recommendations of Dr. Coulter which have not been

implemented are that:

• a system emphasizing rewards and incentives for achieving equity goals should be introduced although it must be balanced with an ability to impose sanctions when necessary

• a culture of equity must be built on the campus through educational programming and practices, the provision of resources to new and emerging programs, and on-going support for members of the designated groups

• strong, informed, consistent and timely leadership must be offered in support of equity, and

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filing of the report on the RCEE's first year of operation which was required to be filed by

May 2008. This impasse brought to a halt the work of the reconstituted RCEE.

99. During 2007-2008, the RCEE had prepared a memorandum of its planned

equity strategy, and submitted it to the· President and the Provost for their endorsement.

This approach was adopted because of Dr. Coulter's advice that "If equity culture is to

become a reality at the University of Windsor, it must begin with strong, consistent and

on-going leadership". The memorandum was discussed with the President and Provost

and redrafted to take into account their comments and concerns. Outgoing University

President Ross Paul gave the report a strong endorsement and undertook to endorse

the RCEE proposal to Dr. Alan Wildeman, who had been chosen to succeed him.

Provost Neil Gold (formerly Dean of the Faculty of Law) was not willing to provide a

written endorsement of the revised RCEE proposals, though he said he had a personal

commitment to principles of equity. The Union appointees to the RCEE concluded,

'Without the formal , written endorsement from the Provost for the RCEE

recommendations, there is nothing more to be done by the RCEE at this time".

100. In a report on the RCEE's work in 2007-2008 prepared by Professors Emily

Carasco and Pamela Milne, WUFA appointees to the Committee, it is concluded:

The senior Administration of the University of Windsor has chosen to continue its empty commitment to the principles of equity without any substantive mechanism to move the institution toward real equity. Little progress has been possible in the past without this commitment and the RCEE does not think meaningful progress can be made in the future without it.

The University of Windsor's current equity efforts are, and .have been for the past 12 years, in failure mode. As the Coulter report indicated , "making it real" depends on the emergence of equity leadership within senior Administration. Such leadership is not yet evident. Senate can adopt and approve documents and recommendations such as contained in WGER and Coulter but if those recommendations are not implemented by the Administration, then no progress toward equity is ever to be realized at the University of Windsor. The work of the reconstituted RCEE is also at a standstill because senior Administration has failed yet again to agree to implement the strategy developed by the committee. More time, more work and still no product.

- 29-

101. President Wildeman and the new Provost Dr. Leo Groarke have not made

any commitment in writing to the employment equity strategy proposed by RCEE since

taking office. Nor have they made any other form of concrete ccmmitment to the

achievement of employment equity.

102. President Wildeman has not complied with Art. 30.01 (b) of the 2008

Collective Agreement, which provides that:

Within one hundred and eighty (180) days from the signing of this collective agreement, in the context of the President's plans for a comprehensive campus­wide approach to employment equity, the President will publish a detailed plan and timetable with respect to implementation of the recommendations of the Coulter Report.

103. In May 2009, President Wildeman announced in his President's Update (#3) a

plan to create an Office of Human Rights and Equity which was to be established in July

2010. This Office has not yet been established. There is no mention in this Update or

any other since, of the Coulter Report or of a detailed timetable for the implementation

of the recommendations in the Couner Report.

104. Significantly no President or Vice President Academic has set goals or

timetables for hiring women or visible minorities in senior administration positions .

105. In March 2007, President Paul received a Report to the President on Matters

of Racism and Discrimination at the University of Windsor, prepared by Campbell

Aliens Consultants Inc. The report was ccmmissioned by Dr. Paul as a response to

student ccmplaints about discriminatory ccnduct on the part of the management of the

student pub. The consultants were asked to look into concerns ofracism and

discrimination on campus and to make proposals to overcome these problems. This

Report made a number of findings and observations.

106. In reporting on visible minority students' perceptions, the Report noted that

over and over again, the "whiteness" of the University was cited as a contributor to the

- 30-

students' feeling of not belonging. It continued , "It cannot be refuted that, with one

exception, the Senior Management Group of the University is white and mostly male.

Despite the fact that the Federal Contractors Program continues to find the University of

Windsor's equity program to be in compliance, and despite some progress in this

regard, the University's own employment equity report shows that the Faculty is

overwhelmingly white as well , with the exception of certain faculties wherein visible

minorities are clustered. In general, visible minorities have little, and aboriginal people

almost no presence in supervisory or staff positions across the University".

107. The Report observed further that students have the perception that those in

power positions do not understand the stress associated with seldom being able to deal

with authority figures that "look like them". Those who have never encountered this

have trouble understanding it. Even though the University administration and faculty

"understand" equity issues, students report that they perceive a feeling of "us v. them"

when issues arise such as the Pub dress code, or more recently the controversy over

the Sports Weekend activities on campus. On the one hand, administrators say they

are engaging in consultation, but the students perceive tokenism at play. With regard to

Sports Weekend, the students involved in the negotiations allege the existence of a

double standard when comparing the Sports Weekend to other similar campus events

involving a predominately white student base. Administrators proudly cite the existence

of policies relating to human rights, equity and anti-racism while students and others

point to the gaps in the practice of those goals.

108. As a further example of what they see as a disconnect .between policy and .

practice, the students cited the President's State of the University address on January

26, 2007. In it, the President did speak to his belief that "we have a tremendous

richness of diversity on our campus and we absolutely must do more to ensure that all

of our students, faculty and staff take advantage of it. We must learn to do more ... as

must all universities in the 21 st century" . Because the President did not directly refer to

either the University's commitment to social justice or the actions being undertaken in

that regard, the omission was deemed' to be an indication that the Administration does

- 31 -

not take the issue seriously. Further, it gives strength to the students' fear that the

"commitment" is dubious and this inquiry is merely "window-dressing" that will not result

in any meaningful changes related to the students' experiences and perceptions of

racism, racial profiling and discrimination against racialized and other marginalized

students.

109. The Campbell Aliens study alluded to the poor reception accorded the Coulter

Report. It observed that Dr. Coulter's recommendations, specifically those relating to

setting timetables and goals for implementation, have not been acted upon as yet:

The 2005/2006 Action Plan listed Employment Equity as one of the top ten goals, and the WUF A Collective Agreement is clearly in support of equity measures (See Article 30). The Report on Key Performance Indicators, which helps to assess how well the University is meeting the goals it has set in a wide range of endeavours, lists Equity and Diversity and as an indicator but that it will only be reported on triennially. Thus, it is not available in current reporting, and there is no mention of it in the Plan for 2006/2007.

A more recent report, Forly years later, how are university women doing? by Janice Drakich and Penni Stewart published in Academic Matters, February 2007, provides evidence that women are making strides in both faculty and administrative hirings, but even then it appears that "women continue to be clustered both as students and faculty in feminized disciplines; women faculty are not appointed to the rank of full professor at the same rate or speed as men; and women continue to be under-represented in senior administrative positions". Sub has Ramcharan's work in 2005 made similar observations, and pointed to the dismal failure of the University to include Aboriginal people in any occup<,tional category save food and services.

This plus the lack of progress on other equity initiatives leaves racialized students and faculty feeling that their issues, and those of Aboriginal people, persons with disabilities and other marginalized groups, are not being respected. They and those who support equity feel inferior and demoralized. Perhaps the powers that be are simply "slow to act", but in any event, the lack of communication about the action plan relating to equity hiring programs contributes to the belief that the issue is not on the administration's radar screen. There is a fear that if equity hiring plans are not implemented, the University will not capitalize on the opportunities presented by the pending retirements of those taken on during the hiring boom of the late 1960's and early 1970's.

- 32-

114. University of Windsor president Alan Wildeman would not comment on any

specific anecdotes in the report, but he noted that campuses are cross-sections of

society. "It is not surprising that things are happening on our university campuses that

are also happening across our society in general." Wildeman pointed to the University's

creation of a human rights, equity and accessibility office (which has not yet been

accomplished although the deadline for doing so was July 2010). "We always

encourage people who have concerns of this type to bring them forward , so that we can

look into them - and if there have been wrongs committed, do all we can to correct

those wrongs."

115. President Wildeman's reference was to case-by-case investigation of

complaints. He made no reference to the absence from University of Windsor of an

effective strategy to address systemic discrimination.

116. The University of Windsor has a long record of paying lip service to the goal

of equity, while doing little or nothing to advance that goal. Its inaction has left intact the

structure of white privilege within senior ranks at the University, and fostered

expectations that such privilege will continue undisturbed. In such an environment,

resistance to the initiatives of visible minority scholars to get through the glass ceiling

into senior professorial ranks and administration is normalized, and occurs with

impunity.

C. Effect on the Complainant

117. This University's handling of the Dean Search is the most difficult thing I have

had to deal with in my entire career. It may well be naive but I did really believe that my.

candidacy would be assessed on the basis of merit. I now realize that as far as some

people are concerned , I am not entitled to the treatment that they take very much for

granted. This is a hard thing to accept - that in 2010 in Canada, a woman of colour, no

matter how well qualified , is still not treated in the workplace the way members of the

dominant group in Canada are treated. I feel betrayed both by some of my colleagues

and by those in power within the system who permit this kind of behaviour to go

- 34-

unchallenged. II is particularly hard 10 swallow in a conlext where I am surrounded by

individuals who claim Ihallhey undersland and live by Ihe values Ihal underlie human

righls law.

118. I don'l know if I can describe Ihe slress and Ihe shock I experienced during

Ihe last two weeks of Ihe decanal search process. Professor's Moon personal attack on

me was very painful and Dr. McCrone's inexplicable handling of illefl me

psychologically bruised and wilh a sense of hopelessness in relalion 10 Ihe damage

done 10 my credibility and repulalion. Over Ihe lasl few weeks I have been asked

dozens of limes by fanner sludenls, people in Ihe communily and beyond , 10 explain

why I did nol gellhe posilion. I have been unable 10 do so. I have carried Ihe weighl of

Ihis evenl with me every single 'day since il occurred . I don'l know Ihall will ever be Ihe

same - nol so much because I did nol gellhe job - bul because of how il happened

and how many people permitted ilia happen.

D. Remedy

1. Wilh Respect 10 Professor Moon:

1. Public relraction of his allegalions of plagiarism

2. Damages for injury 10 dignily iri Ihe amounl of $15,000

2. Wilh Respecllo Ihe Faculty of Law and Universily of Windsor discriminalion againsl me:

1. Appoinlmenl of Dr. Carasco as Dean of Law by Presidenl Wildeman, for a full

five-year lerm wilh Ihe opportunity for renewal ;

2. Damages for injury 10 dignity in Ihe amounl of $60,000

3. An inlerim order slaying Ihe Dean search by Ihe Committee appoinled April 28,

2010, and requiring Ihal an Actin\l-Dean be in place until the final disposition of this

complaint.

- 35-

3. With Respect to Systemic Discrimination:

1. Establishment by the University within six months of the. date of the Order of a

data base, goals and timetables for the four groups of women, members of visible

minorities, Aboriginal people, and persons with a disability, in accordance with the

recommendations of the Coulter Report and the RCEE proposals of 2008.

2. Establishment of an employment equity program in accordance with the Coulter

Report within a period of two years of the date of the Order.

3. An order requiring the University to report back to the Human Rights Tribunal

within 6 months to establish its compliance with the order in paragraph 1 hereof

and within 2 years to establish compliance with the Order in paragraph 2 hereof.

4. Comprehensive equity and human rights training for all senior administration at

the University, from the level of Dean to President, and training of Equity

Assessors as recommended by Professor Coulter.

5. Within one year of this Order, complete and report on a Consultation with

University of Windsor students about means to promote and support student

diversity, and implementation of the recommendations of those consultations within

two years of the date of the Order. A report to be produced by the University at the

end of the second year from the date of this Order outlining its progress on

implementing the recommendations of the Report, and distributed widely through

the University and the student community.

- 36-

· .