Watch Dale Frank explain the context, audience, and purpose for her demand letter to the City of Eden's General Counsel.
Can you do me a favour? Read my demand letter and let me know:
  1. Did I give enough context?
  2. Does the letter deliver my message to the City’s General Counsel with the right level of detail, tone, and language?
  3. Does my letter give the City’s General Counsel clear choices?

Let me know what I did well and what I can strengthen in the feedback boxes.

McRae and Associates

Paris – London – Toronto – New York - Ottawa

Without Prejudice

April 3, 2013
Anna Gabor
City Hall
12 Forsythe Avenue
Eden, Ontario L8L 2Z0

Dear Ms. Gabor,

I represent Alice and Charles Barton and their six children, whose equality rights are violated by the City of Eden’s new bylaw 456A that limits curbside garbage pick-up to one plastic garbage bag a week. My clients have instructed me to challenge this discriminatory bylaw in a class action lawsuit. My clients will settle this matter out of court if the City grants them an immediate exemption.

The by-law exempts families with seven or more children, but does not consider any other hardship factors. My clients have six children under the age of twelve. They do not have a car. The by-law forces them to travel to a landfill and pay extra to dispose of two additional bags of garbage every week.

The by-law discriminates on the basis of family status by imposing a significant financial burden on the Bartons because they have six rather than seven children. The courts recognize family status as a ground of discrimination. If we are forced to file a class action lawsuit, the Bartons will represent large families like themselves, as well as persons with disabilities who are also adversely affected by the by-law’s requirement to bring excess garbage to a distant landfill site.

I would like to schedule a meeting with you, the Bartons, and a representative from ACTNow, a disability support organization, to discuss bylaw changes that do not create hardship for large families, disabled persons, and persons with limited resources. In the interim, please instruct the city garbage collectors to collect all the garbage bags from the Barton’s home at 125 Cherry Lane beginning on the next regular pick-up date. If the city does not begin full garbage pick-up, I will promptly file a class action lawsuit in Superior Court.

I will take the liberty of calling your office this Friday to schedule the meeting. The Bartons look forward to an amicable settlement of this matter that is in keeping with the City’s image as a family-oriented and accessible place to live.

Dale Frank


Senior Lawyer's Feedback on Dale Frank's Demand Letter

Transcript (.pdf. 76 kb)