January 6, 2019 Email from Stella Reddy to HRTO

HRTO- File Numbers  2018-32808-I, 2018-32809-I, 2018-32810-I, 2018-32811-I.

Issues with the Reply Form #3 Info

I have some serious issues with the Reply submitted by the applicants. There are some serious issues in here over telling me how I should have done my job once again at the LTB hearing, repeating himself so many times, sentences not finished and these papers are full of new information that they have not included in their original application.

As you will see in this Reply the applicants did not follow the rules of procedures where it states they could not add any other facts or issues that was not raised in the application.

In this Reply, they have invaded the social media of my family members, as evidenced by the photos they took of my niece and her family. I have had issues with this information being used since they first sent it. This action goes to show the how uncaring the applicant is of others and their privacy as long as it gets them the reaction they wish.

The applicants have included so much information here that was not part of the original application, this application should be dismissed just on this as the applicants have proven that they do not wish to follow what is asked of them, but will do as they see fit. This action is proof of my allegations in my Response that the applicants do not follow the rules and regulations of any agency, or of any property management company, that they do not agree with and will follow their own direction and do what they see fit, even if it goes against the rules they should be following. They have continually done what they wanted and ignored the rules, as they do here.

Rules of Procedure

Applications under the Human Rights Code, Part IV, R.S.O. 1990, c.H.19 as amended 
Disponible en français

RULE 9REPLY
9.1An Applicant who intends to prove a version of the facts different from those set out in a Response must deliver and file a Reply in Form 3 setting out the different version, unless it is already contained in the Application. An Applicant may also reply to any other matter raised in the Response.
       9.2The Reply must deal only with new matters that are raised in the Response.
9.3The Applicant must deliver a copy of the Reply to the other parties and any trade union or occupational or professional organization and other person or organization identified as an affected person in the Application or Response and file it with the Tribunal not later than 21 days after the Response was sent to the Applicant.
5.7Where a party seeks to present evidence or make submissions with respect to a fact or issue that was not raised in the Application, Response, Reply, or in the materials filed under Rule 16 or 17, the Tribunal may refuse to allow the party to present evidence or make submissions about the fact or issue unless satisfied that there would be no substantial prejudice and no undue delay to the proceedings.

This Reply also contains more suppositions from the applicants and even suggestions on how I should have done my job and once again is filled with sentences beginning with “it appears” followed by the applicant’s personal opinions.

This Reply was to respond to any new matters that were raised by me in my Response, as per the Rules of Procedures. I see in these papers that they didn’t even talk of the website they did, nor of the Facebook postings, except in general terms, and there was no proof given of any such alleged prior meeting they claim we had where they state I said so much either. As this alleged meeting is the basis of all their allegations against me, and later the property owners, I find it really strange that there is no mention of it in this Reply. As for the applicants claims that their alleged issues with me was not the basis of all the applications and issues they complain about, I believe I have shown with their own paperwork that this is true. There were no allegations of racism until we had issues with entry to complete repairs and they alleged in that letter they sent in Oct 2016 where they made general claims of racism against me. The applicants had issue with how I did my job and this was their way of retaliating and getting back at me for doing that. Since it has started in July 2016 their resentment and hatred for me has grown and is very prevalent in these papers and in all the papers sent as this is a personal vendetta for them now. As I read these papers I can feel the hatred they have towards me.

 “It should be noted that the Divisional Court appeal only involves Allison Read and none of the other members of the family. The appeal filed with Divisional Court was filed only on behalf of Allison Read and she is the only individual named by the 3 Respondents on any of the N5 for the September 26, 2017 LTB hearing. The facts of the appeal are based on the many bias and serious errors of law made by the Social Justice Tribunals Ontario Member Kevin Lundy against Allison Read and none of the other family members.

Based on these grounds, there can be no issue relating to the 3 remaining family members as legally they are not part of the appeal in Divisional Court, nor were they legally part of the LTB hearing on September 26, 2017 in any legal capacity.”

In the very beginning, the applicants are contradicting themselves as throughout this application, throughout all applications and paperwork received from them over the past 2 ½ years, has been about “the applicant and her family” and what they claim my alleged actions have caused. Mr. Read represented his wife and family at the LTB hearing on Sept 26, 2017, maybe not as a legal person but as you know you are not required to be one for these tribunals, and he has completed all following letters, emails, and applications for Divisional Court and for HRTO so he is directly involved in all the applications and issues. To try to now claim not to be involved is ridiculous and totally unreasonable. 

I have included some info on credibility of a witness to show that the applicants have to meet. They have not proven with absolute certainty that I made any racist comments to them at some restaurant before I moved into the building to work here that they claim was the basis for their application, nor have they shown that I was prejudiced or reprising against them. I was doing my job in looking after the property. They have been reaching and using their own personal opinions to attack me. As the applicants don’t like what I did in my job as building staff, especially the eviction proceeding that was granted for consistent refusal of access,  they twist the facts and ignore what won’t help them in their case, as evidenced by the lack of mention over the website they did and the Facebook posts.

Credibility

[7]           While some of the facts of this case are not contested and/or are supported by documentary evidence, other facts require me to choose between the applicant and the respondents’ conflicting testimonial evidence. In evaluating the evidence in this case, I have given consideration to the following analyses frequently cited in decisions of this Tribunal, see Marne v. Aptco Capital Corporation, 2014 HRTO 1756 (CanLII), at para. 11:

1.  “When one is concerned with a witness’s veracity, one speaks of the witness’s credibility. When one is concerned with the accuracy of a witness’s testimony, one speaks of the reliability of that testimony.” Reliability is influenced by a witness’s ability to “accurately observe, recall and recount” events. Credibility goes to the propensity to tell the truth or the “sincerity” of the witness. See R. v. Morrissey (1995), 1995 CanLII 3498 (ON CA), 97 C.C.C. (3d) 193 (ON C.A.) at p.205

2.  Credibility can be determined by evaluating whether the story provided by the witness is consistent with the “preponderance of the probabilities which a practical and informed person would readily recognize as reasonable in that place and in those conditions:” see Faryna v. Chorny, 1951 CanLII 252 (BC CA), [1952] 2 D.L.R. 354 (B.C.C.A.)

3.  In evaluating the credibility or reliability of evidence, one looks to a number of interrelated factors such as its probability, logical connection with other findings and support from independent evidence. In evaluating the credibility of a witness, one looks to such factors as the ability to “perceive and recall,” level of candour (or evasiveness) and “attitude towards the parties.” See Visic v. Elia Associates Professional Corporation2011 HRTO 1230 (CanLII) at para. 54

4.  “A finding of lack of credibility or reliability with respect to one aspect of a witness’s testimony does not automatically render the entirety of the witness’s evidence as incredible or unreliable.” See Visic, above.

I also take exception to the label the applicants have given me, “now alleged former Alto Properties Inc. Property Manager Stella Reddy”. Once again the applicants are going on their own agenda and giving me a label that would fit with their version than the actual facts. By giving me this label, they are giving me more administrative powers than what I actually had in order to show their version that I was the alleged “ringleader” of the “ racist, prejudice and reprisal manner” shown to them.

“This also means that the now alleged former Alto Properties Inc. Property Manager Stella Reddy filed her own HRTO complaint against the Applicants, 10 days after they initially filed their HRTO complaints against her on June 04, 2018.

It appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy filed her own HRTO complaint against the Applicants as a way to retaliate against them for filing against her.”

The applicants also include an application I filed with this office June 14 but they did not mention my original one I filed in August 24 2017 that was mistakenly dismissed that I didn’t know about. Why bring up an application that was dismissed and not one that was accepted before but include here a letter I sent for that application? So no, this was not in retaliation as I submitted an application in August 24, 2017, almost a year before they did. Yes, I used most of the paperwork they sent as it contains what I needed to show that it didn’t happen the way they say it did. I used their own paperwork against them, as I was able to do, as the truth is hiding there if you read it all, not just focus on what the applicants try to make you see.

As I stated previously, I will not discuss anything about any other tenants as it is not these applicants concern over how the business is run. They have no right to dictate to the property owners how to run their business over parking, rental rates, nor anything else in the property. As I also stated a Tenant Service Request Form that they have in these papers where they put in for temp parking is also not the proper Parking Request Form that I gave them previously. It is a completely different form than the Service Request one. As for parking supposedly being free, if they look at their paperwork, it states that if you later require parking you will be required to rent one. If they had a vehicle when they first moved in, yes the parking would have been free, but they did not. They asked for a parking spot 2 yrs later and it was no longer free.

“The now alleged former Alto Properties Inc. Property Manager Stella Reddy has deliberately made absolutely no arguments, quoted or presented any legal grounds in her written response to this issue.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has chosen to forfeit her right to have any place at the table to argue any issues relating to her own request for a deferral and/or dismissal, as she has deliberately not presented any documents or argument to collaborate and justify her request for a deferral and/or dismissal that she has requested.

It is the Applicants position that Alto Properties Inc. Property Manager Stella Reddy has taken it upon herself to not present the required documents to collaborate or justify her request for deferral and/or dismissal.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy willfully and without any threats of reprisal, violence, repercussions or intimidation decided that she was not going to address the issue of deferral and/or dismissal that was requested by her in her response.

It appears that the now alleged former Alto Properties Inc. Property Manager Stella Reddy thinks that it is the HRTO responsibility and obligation to make her positions fully known, to create an argument on her behalf and to present documents that help justify her own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that the now alleged former Alto Properties Inc. Property Manager Stella Reddy should not have placed these inappropriate expectations upon HRTO, as it is solely HER responsibility to present, validate and defend her own request for deferral and/or dismissal.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have chosen to forfeit their right to have any place at the table to argue this issues relating to their own request for a deferral and/or dismissal, as they have deliberately not provide a physical copy or digital copy of their authorities, present explanations about their authorities that are so vaguely explained or in some cases lack any type of explanation at all to justify their request for a deferral and/or dismissal that they had requested.

It is the Applicants position that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have taken it upon themselves to deliberately not present the required documents to collaborate or justify their request for deferral and/or dismissal.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio willfully and without any threats of reprisal, violence, repercussions or intimidation decided that they were not going to address some issue raised in their request for deferral and/or dismissal that was requested by them in their response.

It appears that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio think that it is the HRTO responsibility and obligation to make their positions fully known, or to create an argument on their behalf and to present documents that help justify their own request for a deferral and/or dismissal.

It is Applicants position that this is not the case, and that Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio should not have placed these inappropriate expectations upon HRTO, as it is solely THEIR responsibility to present, validate and defend their own request for deferral and/or dismissal.

The paragraphs above are constantly repeated throughout this Reply numerous times. Why?

As the LTB hearing, that is self-explanatory and has been talked about numerous times. The applicants were evicted for consistent refusal of access to the apartment for repairs needed that they admitted to doing, even before I worked here. It is in the transcript they provided. The applicants seem to think that the adjudicator should have forced us to either adjourn the hearing till Oct 31, 2017 or proceed that day without being prepared. You have to understand, we received their application that SAME DAY, as their Certificate of Service will show they served us with their application made for Oct 31, 2017 on that day of the hearing Sept 26, 2017. We were not obligated to adjourn and that is why it was not enforced. The applicants could have went ahead on Oct 31, 2017, we were all at the LTB for the hearing and were prepared but they withdrew of their own choice at that time. They cannot now all of a sudden cry “wolf” because they feel they got shafted in giving their case against me. It was their decision. Their documents and alleged allegations of racism wouldn’t have made any changes to the eviction order as the landlord has a right to gain entry to complete repairs and they always refused entry when it wasn’t on their terms. The adjudicator even made the statement that he felt it would not matter even if he ordered them to allow entry, as they were so adamant in not allowing it, no matter whom it was for.

The Applicants at that time had no idea that the Divisional Court could not hear the case that was presented to the LTB. That the Divisional Court could only hear about issue of error in law. So their request for a new hearing in front of the Divisional Court was a request that cannot be fulfilled as the documents itself is not in dispute. It is the conduct and bias of the Social Justice Tribunals Ontario Member Kevin Lundy.

Under reasonability, it can be assumed that since the Divisional Court can’t hear the applicant’s complaints against me, they decided to go trough this tribunal as their original intention in Divisional Court was to get back at me, as you can see from what I copied and pasted below from the website www.859kennedyroad.com that is still online and was posted throughout Facebook. If this was not the original intention why make a website about it for the world to see and keep it there?

So it appears that it is okay for people like Luigi Liscio, his son Anthony Liscio who are the owners of Alto Properties Inc. To hire

proven racist, who say racist things in front of Judicators like Kevin Lundy from the Landlord Tenant Board during a hearing because

when it is all said and done.

Cheap Justice wins in the end.

So now we had to Appeal the Kevin Lundy eviction order to the Appeals in Divisional Court. Where I will finally I get my chance to

present my case in full, and I will finally get too Stella Reddy with the numerous amount of questions I have for her.

Now as my Appeal is in the early stages, I would love to show you all the documents at this time. But showing you the documents

without explanation would be pointless. Obviously I don’t want to expose my hand any sooner to the other side than I have to. But

trust me I cannot wait to get in front of the Appeals Court and show how this Kevin Lundy had a clear bias against us, and that Alto

Properties Inc. and Stella Reddy had and have alternative motives behind what they are trying to do to our family.

Please check in every couple of weeks, and I hope to offer more documentation and explanations as this all plays out.”

They have made various statements in this website that have not yet been proven as true, such as “To hire proven racist”. This whole website was a way to harass me, embarrass me, and they also promoted other to do the same b y sharing it on Facebook.

It is also interesting as once again the applicant feels justified in telling me how I should have done my job, as they have tried to since I started working here and is a perfect example of what I have had to deal with.

“This finding certainly applies to now alleged former Alto Properties Inc. Property Manager Stella Reddy as her racially charged language, prejudice slurs and her own racially motivated actions in a public forum at the LTB hearing on September 26, 2017 had nothing to do with the 3 Respondents filing for Refusal of Entry.

There was absolutely no reason for now alleged former Alto Properties Inc. Property Manager Stella Reddy to try and justify her racist beliefs as legal the only issue before the LTB was did the Applicants refuse her entry, YES OR NO?

The now alleged former Alto Properties Inc. Property Manager Stella Reddy may have wanted to discuss the conversation that transpired between the Applicants. But in actuality all she had to do was state

I gave proper Notice and I was refused.. Done…

The Act is very clear about that. There was absolutely no reason for her to bring up what happened or what was said. It had absolutely nothing to do with…

DID THE APPLICANTS ALLOW YOU IN YES OR NO?

Again there was no need for now alleged former Alto Properties Inc. Property Manager Stella Reddy to utter the slur “ Newfie ” numerous times in front of the Applicants, arbitrator and public. The now alleged former Alto Properties Inc. Property Manager Stella Reddy may have wanted to discuss this topic, but in actuality all she had to do was state

I gave proper Notice and I was refused.. Done…

The excerpt I copied and pasted below is very interesting to me. I am a born and raised Newfie and yet the applicants feels that because he don’t like the term it should be considered a slur and therefore not proper? Does the applicant have the right to say how I self-identify? Is this not discrimination? Accusing me of a slur over my own heritage?

The Applicants found the now alleged former Alto Properties Inc. Property Manager Stella Reddy prejudice slurs offensive about New Foundlanders and to be unwanted harassment, despite it not being directly towards them.

The Applicants position is that a person does not have to possess a certain characteristic themselves for it to be considered unwanted harassment.

Again there was no need for the now alleged former Alto Properties Inc. Property Manager Stella Reddy to say the racially charged “ Mullato ” statement towards and in the presence of their children again.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy may have wanted to discuss this topic, but in actuality all she had to do was state

Where is it stated that I said these words? I do not see it in these papers, nor any papers, where I said those words to anyone. So this is not accurate.

I gave proper Notice and I was refused.. Done…

The now alleged former Alto Properties Inc. Property Manager Stella Reddy statement was insensitive and shameful and it is classified as harassment.

Again the racially motivated conduct the now alleged former Alto Properties Inc. Property Manager Stella Reddy was unwanted and not needed in a public LTB hearing.

This was the 2nd time the now alleged former Alto Properties Inc. Property Manager Stella Reddy had referred to the Applicants children as “ Mullato ” in their presence and in a public area.

The Applicants wants to remind the HRTO the racial charged slur “ Mulatto ” is a considered a derogatory term by society, because came into use during slavery when referring to the bi-racial offspring of African slaves and most often their white European slave masters.

The now alleged former Alto Properties Inc. Property Manager Stella Reddy also stated my “ I have very beautiful great nephews and nieces who are half black, and my nephew is as black as you can get. He’s even darker than she is. ”” while point at the Applicant, embarrassing and shaming her about her complexion. This is their inference, not mine. Once again the applicants seem confused as I state “my nephew, not great nephew”. They are confusing the issue as if it is my nephew, it don’t fit what they want you to see. These pictures should not have been included and was not in the original application.

Again all the now alleged former Alto Properties Inc. Property Manager Stella Reddy may have wanted to discuss this topic, but in actuality all she had to do was state

I gave proper Notice and I was refused.. Done…

But instead the now alleged former Alto Properties Inc. Property Manager Stella Reddy wanted to either imply to Applicant that despite her great “ nephew ” being even “ darker than she is ” that he is still beautiful.

So one has to wonder if her great nephew had a lighter complexion than the Applicant, would she still think he is as beautiful?

Did the now alleged former Alto Properties Inc. Property Manager Stella Reddy also mean to imply to the Applicant    Not finished

The real irony of this whole racially charged language and actions “ He’s even darker than she is. ” that were made by the now alleged former Alto Properties Inc. Property Manager Stella Reddy in perjury at the LTB hearing. Is that her great nephew has a far lighter complexion than the Applicant herself.”  This is a DIRECT LIE as he has GREAT NEPHEW in this sentence. It goes to show how the applicants twist things to make it appear as what they want people to see.

The whole section on Reprisal is suppositions and personal opinions of the applicants and has no substance in fact. They sent this letter in October 2016 where they alleged this previous meeting but had no real details and did not even request an investigation or a meeting. They just assumed that they could make allegations and it would be accepted just by their word. Under reasonableness, if an investigated is requested then there should have been a formal request with as much detail of the incident as possible to follow, but there was not. As these allegations just came out in Oct and I was here since June 29, 2016 why was it not brought up before in the initial meeting with me? It took 4 ½ months for them to reference a alleged incident they claim they are basing their accusations on?

What is all the quoted statements below if not harassment against myself? There is a lot of it in these papers. As for my health issues, I have no reason to advertise them while I do my job. I only added them to my response to show the HRTO that I had health issues before moving in to work here that were made worse by the stress of the applicants false allegations and accusations. The stress of working in an apartment building dealing with tenants and perspective tenants, contractors and other public figures with the website online with their lies and the Facebook posts about me was difficult and that’s is not including the harassment I had to deal with from the applicants with their tenant association and rumours spread among the other tenants by these people. I explained all this in my response. These statements below are suppositions made by the applicants is harassment.

”The Applicants have changed their position in regards to the behaviour of the now alleged former Alto Properties Inc. Property Manager Stella Reddy. At first the Applicants believed that it was a Obsessive Compulsive Behaviour or OCD.

But after doing this reply, it has become in their opinion that now alleged former Alto Properties Inc. Property Manager Stella Reddy is just a Narcissist

Some of the most common traits of a Narcissist are…

1. They exaggerate – They will overplay or even lie about events. They share their achievements over and over, they actually become a reality to the person. They believe all the things that they share with others.

2. They are masters manipulators – The narcissist will utilize your weakness to ensure that they get what they want. They will degrade you, using your weaknesses to add more power to their personality.

3. They don’t recognize or accept your feelings – The only thing that counts is how they feel. The narcissist will be sure to bulldoze your emotions to make they feel worthy. A narcissist is only concerned with how they feel. Emotions are driven by their needs and desires.

4. They are arrogant – The narcissist is never wrong. They believe they are entitled to everything. They will brag and step over anything or anyone along their path to get the things they want. Being a narcissist doesn’t allow for the person to have a rational moral compass. They aren’t sensitive to anyone’s feelings.

5. The require constant admiration and adoration – The narcissist needs to be the center of attention. When the attention is no longer available, they will move onto another person. They cannot keep relationships for long because no one can keep them on a golden pedestal. They have difficulties keeping jobs and focusing on school as well because they lose interest quickly.

6. They take advantage of others – The narcissist will take advantage of anything and anyone to suit their needs. This means stepping over anything to reach their level of twisted goals. The narcissist appears to have self-confidence and high self-esteem, but it’s a facade. They are lacking self-worth but compensate it by using others to their best interest.

7. They are envious of others – The narcissist cannot accept anyone better than themselves; therefore, when the attention is on someone else, they get angry. They suffer from severe depression and frustration. They become enraged. They are envious of anything that doesn’t come to them and their attention.

8. They believe they are superior – They believe they are above anyone. Their grandiose attitude is overwhelming. They do no wrong. When something doesn’t go their way, it’s because of someone else who messed up. There is no way to rationalize with their behavior.

In the Applicants opinion there is no shortage of these mentioned traits by the now the alleged former Alto Properties Inc. Property Manager Stella Reddy throughout this reply.

This Narcissist behaviour now sudden shines a whole new light on everything she has done in regards to her own racially motivated actions of harassment, discriminating and acting in a reprisal manner against the Applicants.

It explains away any remaining questions as to why she would use such racially charged language, prejudice slurs in a public forum without fear.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony have allowed and enabled the now alleged former Alto Properties Inc. Property Manager Stella Reddy to retaliate against the Applicants in a racist and discriminatory manner despite it being brought to their attention on different occasions by the Applicants.

Everyone is a bit of a Narcissist in their own little ways, but the problem with people like the now alleged former Alto Properties Inc. Property Manager Stella Reddy. Is that when they do something wrong and they are not corrected or they are encouraged to continue, they take it to a level that a normal behaviour is no longer considered.

There is no doubt that the now alleged former Alto Properties Inc. Property Manager Stella Reddy is aware of her behaviour.

 She joyfully takes responsible for getting the Applicants evicted.

 She gladly admits that she made racially charge comments.

 She enjoys scolding and lectures the Applicants about her knowledge of the system.

 She eagerly continues to lie to the HRTO about the same things even after being caught.

 She proudly can’t wait to get in front of the HRTO to justify her actions.

 She happily inconvenience the Applicants every chance she could.

Another example of her narcissist behaviour is when the now alleged former Alto Properties Inc. Property Manager Stella Reddy thought everything was going her way between June 2016 to July 2018.

During this time not once did the now alleged former Alto Properties Inc. Property Manager Stella Reddy complain about her many health issues.

She did not have health issues when …

she was made the pattern of her making the Applicants sit around, waiting 3 times for her, and she never bothered to show up without warning.

She did not have health issues when …

when she was building the 3 Respondents provoked case to have the evicted.

She did not have health issues when…

she was throwing away the key to their unit to justify her illegal N5 to get them evicted.

She did not have health issues when…

she was in front of Social Justice Tribunal Member Kevin Lundy of September 26, 2017, lying.

She did not have health issues when…

she refused the Applicants parking at the building, but at the same time gave the all-white 306 tenant that same privilege she refused the interracial Applicants.

But as soon as the Applicants file their HRTO complaints against her and she reads the basis of it. Suddenly the now alleged former Alto Properties Inc. Property Manager Stella Reddy has become plagued by so many health issues it is hard to keep up.

It appears to the Applicants that there might be a connecting to these sudden health issues and the filing of their Application on June 04, 2018 against the now alleged former Alto Properties Inc. Property Manager Stella Reddy?

If this connection is true, it would again be another classic symptom of a Narcissist doing what they do best, and that is try and manipulate the situation.

By what it appears again to be the now alleged former Alto Properties Inc. Property Manager Stella Reddy trying to gain some form of sympathy from the HRTO.

The Applicants also take the position that the now alleged former Alto Properties Inc. Property Manager Stella Reddy alleged medical issues are not relevant to their HRTO complaints against her.

Based on the facts that at the time of her racially motivated actions of harassment, discriminating and acting in a reprisal manner. She was of solid mind and good health, and what happened after the fact is not relevant to her behaviour pre-HRTO complaints.

Her health issues that appeared only after the pre-HRTO complaints no matter how fake, or serious they are. Are irrelevant as a defence for the now alleged former Alto Properties Inc. Property Manager Stella Reddy.

It appears to the Applicants that the now alleged former Alto Properties Inc. Property Manager Stella Reddy is planning to try and use her medical issues as some way to rationalize all of her pre-HRTO complants, racially motivated actions of harassment, discriminating and acting in a reprisal manner.

Again it is the opinion of the Applicants, as they are not doctors they cannot say with certainty about her being a Narcissist, but as the old saying goes.

If it walks like a duck, sounds like a duck, acts like a duck and looks like a duck… it’s probably a duck.

In regards to Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio who have heard and seen the racially charged language and actions of that they’re now alleged former Alto Properties Inc. Property Manager Stella Reddy in person at the LTB hearing.

They have continue to rally behind her, united in their fight in the HRTO and Divisional Court to have the Applicants removed from the building.

They have read all the documents provided by the Applicants, they have seen the huge amount of outright lies that their now alleged former Alto Properties Inc. Property Manager Stella Reddy has been telling to the HRTO and probably themselves.

And still they continue to sit on their hands, ignore the facts in their joint effort to fight and spend more money in the HRTO and Divisional Court to have the Applicants removed from the building. Because Alto Properties Inc. owner Luigi Liscio is upset that the Applicants called them out for their behaviour and for enforced their rights to appeal in Divisional Court that it “ affected ” him and “ you hit my business ” and they “ should known better ”.

There can be no other determination other than Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio have acted in a reprisal manner against the Applicants.

By Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio getting the Applicants evicted or to move out. They stand to gain a 63% profit in rent from their unit. $1106 verses $1750

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio retaliated because the “ Black ” called them out for their lack of actions and concerns about by the now alleged former Alto Properties Inc. Property Manager Stella Reddy racially motivated actions of harassment, discriminating and acting in a reprisal manner.

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio retaliated because the Applicants enforced their rights under the law to appeal the illegal eviction order made by the Social Justice Tribunals Ontario Member Kevin Lundy

Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio retaliated because the Applicants called them out to the HRTO for their participation with now alleged former Alto Properties Inc. Property Manager Stella Reddy in the continuous harassment and inconveniencing of them.

The list at this point is almost endless, and at some point the Applicants have to stop addressing these endless amounts of misquotes facts, lies and obvious illegal actions of the 3 Respondents.

There as so many inconsistences that could be addressed that it would take the Applicants months just to sit down and cross reference, rebuke and show every lie and misquoted fact and questionable actions on the behalf of the 3 Respondents. It just is not realistic nor is it logical to think that they need or can do it at this time.

The Applicant would challenge any of the 3 Respondents to prove with where the Applicants have lied or mislead the HRTO?

To continue down this long written road of going through their current paper work and that of the remaining paper work the Applicants have. It would only continue to confirm that when the 3 Respondents were called out on it by the Applicants in their letters, the 3 Respondents decided to retaliate against the “ Black ”Applicant and her family by using their positions with Alto Properties Inc. to achieve it. The whole time encouraging and enabling each other and trying to build a case against them so they could have them removed for multiple benefits.

There really is no need at this time for the Applicants to continue addressing the 3 Respondents behaviour. The HRTO has the 3 Respondents own;

 Words

 Documents

 Videos

 behaviour

to help them make a finding against them.

The Applicants have made it very obvious to the HRTO and anyone who reads this file. That despite of all the

 Documents

 Emails

 Videos

 Pictures

 Obvious Lies

 Racially Charged Language

 Prejudice Slurs

 October 25, 2017 Conversation

 Harassment

 Racist Motivated Behaviour

 Discrimination

 Intentional Inconveniencing

 Illegal N5’s

The now alleged former Alto Properties Inc. Property Manager Stella Reddy was their – GO TO PERSON for Alto Properties Inc. owner Luigi Liscio and Alto Properties Inc. owner Anthony Liscio.

The Applicants reply, without any doubt shows that despite any words or lack of words the 3 Respondents try and use, to try explain away their prejudice and discriminatory behaviour towards the Applicants.

The reality of this situation for them is that they have provided no visual case law, presented no acceptable arguments or explanations to justify why everyone was in NOT in cahoots in their attempts to have the applicants removed from the building.

It is pretty clear and pretty obvious that the now alleged former Alto Properties Inc. Property Manager Stella Reddy is far from being “ obvious ” or “ Naive ” as it has been claimed.

She freely makes narcissist statements like “ I could have said worse, ”

She has NEVER shown a touch remorse for her behaviour or even hinted at a apologizing,

She brags how “ no will give a shit ” racially charged language, prejudice slurs and her own racially motivated actions

She makes false claims “ I see people as people. To me it don’t matter what they look like, ” yet they has open compared, referred to and insulted the Applicant and her own nephew based on their complexion.

She continues to lie to the HRTO, despite being unquestionable caught.

The HRTO needs to dismiss the 3 Respondents request for deferral and/or dismissal.

Thank you.

Kory, Allison, Kniighetti and Eexii – Read

The Applicants wish to enforce their rights to add to this Reply as needed or requested.”

Among the factors that Tribunals should consider when awarding general damages are humiliation; hurt feelings; the loss of self-respect, dignity and confidence by the complainant; the experience of victimization; the vulnerability of the complainant; and the seriousness of the offensive treatment.

[51]        There is no fixed formula for the Tribunal to follow to assess a monetary compensation award. In Arunachalam v. Best Buy Canada, 2010 HRTO 1880 (CanLII) (“Arunachalam”), the Tribunal stated at paras. 51-54:

Cases with equivalent facts should lead to an equivalent range of compensation, recognizing, of course, that each set of circumstances is unique. Uniform principles must be applied to determine which types of cases are more or less serious…

…The Tribunal’s jurisprudence over the two years since the new damages provision took effect has primarily applied two criteria in making the global evaluation of the appropriate damages for injury to dignity, feelings and self-respect: the objective seriousness of the conduct and the effect on the particular applicant who experienced discrimination…

The first criterion recognizes that injury to dignity, feelings, and self- respect is generally more serious depending, objectively, upon what occurred. …

…The second criterion recognizes the applicant’s particular experience in response to the discrimination. Damages will be generally at the high end of the relevant range when the applicant has experienced particular emotional difficulties as a result of the event, and when his or her particular circumstances make the effects particularly serious

In Strudwick v. Applied Consumer & Clinical Evaluations Inc., 2016 ONCA 520 (CanLII) (“Strudwick”) at paragraphs 52-77, the Court of Appeal reviewed the principles set out by the Tribunal in Arunachalam, above.

[52]        In Strudwick, at paragraph 62, the Court of Appeal identified the following factors as particularly relevant:

           the immediate impact of the discrimination and/or harassment on the complainant’s emotional and/or physical health;

           the ongoing impact of the discrimination and/or harassment on the complainant’s emotional and/or physical health;

           the complainant’s vulnerability;

           objections to the offensive conduct;

           the respondent’s knowledge that the conduct was not only unwelcome but viewed as harassment or discrimination;

           the degree of anxiety the conduct caused; and

           the frequency and intensity of the conduct.

Please, do not allow this farce to continue and dismiss this application. As copied and pasted above from https://www.canlii.org/en/on/onhrt/doc/2017/2017hrto208/2017hrto208.html?searchUrlHash=AAAAAQAKaGFyYXNzbWVudAAAAAAB&resultIndex=7  you will see that I included my health issues to show how this harassment has affected me to the point where I could no longer function and went into psychosis and developed severe depression and anxiety that made me quit my position here. The impact of harassment by another has been proven many times over various issues and even though the applicants seem to believe it is “fake” it is not and due to their actions my life will never be the same again as I will never be able to work in any stress. That website they put online is a major factor in this as well as their continual lies over an alleged meeting.

The applicants have not proven that their allegations are true and have supplied no proof of it. I was doing my job and as per the transcript, they were evicted for consistent refusal of access for repairs, as they admitted at the hearing in their own words, even before I worked here. This is why they will be evicted from the apartment as there was no errors in law. They made up the allegations of some meeting at some restaurant as retaliation for the issues of entry we were having as there was nothing mentioned before this happened. The applicants seem to pick and choose what to discuss as long as it works in their favour but will ignore answering to what is not helpful to them.

Thank you for your time.

Stella Reddy

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