December 31, 2018 – January 2, 2019 – Received 27 emails from Toxic Adult Bullie that include his extensive Exhibits and 184 pages in written submission for his Reply as per HRTO policy. Right at the beginning, Toxic Adult Bullie is trying to backtrack, claiming HRTO is for just him and the children, and not his wife anymore in case of conflict. Therefore at a minimum, the HRTO complaints filed by father, daughter and son can move forward freely as there are no issues of conflicts under the Human Rights Code. Both parents at this time would like to withdraw their consents for the HRTO request to consolidate all 4 complaints against the 3 Respondents. They started to see they were losing, became more irate, so set out to create more false allegations against me, as there are quite a few in this document.
Toxic Adult Bullie spend the first 12 pages writing about my own personal applications with HRTO that I filed for and was dismissed. It is in this document where I sensed Toxic Adult Bullie focus changed from attacking me on a professional level to personal. It is around this time in the process, when he had no choice than try and convince HRTO of his claims that he had no evidence for, not even a link to show it was possible to have occurred as he claimed. I changed from Alleged employee to Alleged Property Manager.
- Pages 13-22 write about other Tenants parking spots and show Pictures of other Tenants vehicles. Kory Read clearly shows evidence that other Tenants are like just like them and don’t want to follow the rules.
- Just like pages 23 – 29 discuss Tenants balconies and BBQ’s. By then, some Tenants had bought electric BBQ’s and also like them, there was a couple of tenants who refused to remove it.
- Pages 30-41 he writes about how I stated I was “I am rule driven” It seems like a bit of hypocrisy of the behalf of the now alleged former Alto Properties Inc. Property Manager Stella Reddy to be lecturing and scolding the Applicants about lying when she, herself has been caught without debate so many times lying to the HRTO in her attempts to portray the Applicants in an unfavorable light.
- Pages 41- 44 Toxic Adult Bullie once again shares the page he made with pictures of his family and compares their skin tones to that of my family member, specifically my Nieces 4 young children. It is pretty clear and pretty obvious that the now alleged Stella Reddy has not only lied to the HTRO, but has also lied to the LTB about the complexion of her own nephew in hopes of trying sway and influence the LTB in her favor. It is also pretty obvious that the now alleged former Alto Properties Inc. Property Manager Stella Reddy never considered the idea that the Applicants would be able to find anything on social media of her nieces and nephews, eventually exposing her lie.
- Pages 44-49 discuss Defer and/or Dismiss and this texts at the beginning are repeated numerous times within these 184 pages. 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 any 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.
- Pages 50-61 – Other Ongoing Legal proceedings. It is the position of the Applicants that due to the inadequate responses by the 3 Respondents, it is clear that they are relying solely upon the fact that there are two legal proceedings ongoing to justify having the complaints by the Applicants to be deferred and/or dismissed. The rest is copies of other proceedings in the past.
- Pages 62-76 “Before Me” It is mind boggling to think, that she thinks these irrelevant issues can possible have any relevance or role in her defence to help justify her own request for a deferral and/or dismissal. It appears the now alleged former Alto Properties Inc. employee Stella Reddy is doing as she has previous done with others, and that is trying to play like she is the victim and that she has been dealt such a rough hand in life.
- Pages 77-84 Overlapping documents. This section is about the HRTO will see that Social Justice Tribunals Ontario Member Kevin Lundy denied the Applicants their right to present a full defence against the 3 Respondents. The appeal is strictly about the many bias and serious errors of law made by the Social Justice Tribunals Ontario Member Kevin Lundy against the Applicant. It also appears that the Social Justice Tribunals Ontario Member Kevin Lundy found no importance it the racially charged language and prejudice slurs and actions made by the now alleged former Alto Properties Inc. Property Manager Stella Reddy during the hearing in front of him. The Social Justice Tribunals Ontario Member Kevin Lundy allow her to repeatedly say staggering things and then he consciously wrote it off as her being “oblivious” to her own ignorance to justify his illegal eviction order. The Applicants take the position that the now alleged former Alto Properties Inc. Property Manager Stella Reddy was not “oblivious ” to her racially charged language, prejudice slurs and racially motivated actions. The position of the Applicants is that the now alleged former Alto Properties Inc. Property Manager Stella Reddy JUST DID NOT CARE, AND DID IT WITHOUT FEAR!
- Pages 85-101 – It is pretty straight forward and obvious that the Divisional Court will be dealing with only issue of bias and serious errors of law made by ONLY the Social Justice Tribunals Ontario Member Kevin Lundy. Upon reading the Applicants Notice of Appeal and Appellants Factum filed with the Divisional Court. It should be pretty clear and obvious the proceedings in Divisional Court will not be addressing any of the allegations raised in the HRTO complaints filed by the Applicants against the 3 Respondents in regards to their harassment, discriminating and acting in a reprisal manner against them. When Social Justice Tribunals Ontario Member Kevin Lundy created his order – it was an intentional and premeditated attempt to deny and block the Applicant to her rights to be heard and have equal justice. The Divisional Court will not be making any findings in regards to any of the her racially charged language, prejudice slurs, racially motivated actions of harassment, discriminating and acting in a reprisal manner complaints filed with the HRTO against the 3 Respondents
- Pages 102- 107 Remedies LTB hearing – October 31, 2017 – Initiated by the Applicants, but never proceeded forward as they withdrew the complaint on the date of hearing without prejudice, as the outcome of this hearing would have played no factor is in the illegal evection notice by the Social Justice Tribunals Ontario Member Kevin Lundy dated October 3, 2017. The Applicants basically withdrew the complaint and essentially freeing them up to proceed to the HRTO. At the time of filing the Applicants were working with a very tight deadline to file with Divisional Court and had no idea how the Appeal Process worked.. It is the conduct and bias of the Social Justice Tribunals Ontario Member Kevin Lundy. The Applicants are asking the Divisional Court to ONLY deal with the eviction order and NOT the racially motivated actions of harassment, discriminating and acting in a reprisal manner against the Applicants by the 3 Respondents. The Applicant is seeking no remedies from the Human Rights Code for their racially motivated actions of harassment, discriminating and acting in a reprisal manner against the Applicants by the 3 Respondents, nor do they intend to in Divisional Court.
- Pages 108- 113- 1 year limitation. –As the 3 Respondents have decided to deliberately not elaborate on this issue, the Applicants are very puzzled as to their grounds and what time frame they think they are working with. A quick review of the document provided by the Applicants, the harassing, discriminating and acting in a reprisal behaviour against the Applicants by 3 Respondents has been ongoing since the obvious meeting in June 2016, August 2016, October 2016, August 2017, September 2017, October 2017, March 2018 and June 2018. Just by reviewing the Applicants 107 Statement of Facts provided, it is pretty obvious the 3 Respondents have been harassing, discriminating and acting in a reprisal manner against the Applicants since the now alleged Property Manager Stella Reddy meeting in June 2016. Given the obvious illegal N5’s given to the Applicants, the denying the Applicants parking privilege despite giving other tenants the same parking privileges, there deliberately actions to inconvenience the Applicants, alter documents to justify an illegal N5 and the numerous amounts of lies over and over that have been proven that cannot be disputed Even the Social Justice Tribunals Ontario Member Kevin Lundy noticed the behaviour of the now alleged former Alto Properties Inc. employee Stella Reddy through her own words and actions. There can be no more doubt that the 3 Respondents were harassing, discriminating and acting in a reprisal manner continuously since 2016.
- Pages 114- 134-Absolute Privilege– Pure speculation and conjecture over my motives over words I had said. No matter how times the Applicants read Stella Reddy 16 page response given to the HRTO. They can make absolutely no connection between above irrelevant issues and the HRTO complaints against her, and absolute privilege. Upon reading the documents supplied by the Applicants to the Divisional Court. It is clear and obvious that the entire appeal is based on the conduct of the Social Justice Tribunals Ontario Member Kevin Lundy. The 3 Respondents are now so irrelevant to the appeal that they will not even have to speak in regards to their harassing, discriminating and acting in a reprisal manner against the Applicants. The now alleged Property Manager Stella Reddy does not hold any legal standing with the Law Society of Ontario or anywhere in Canada and therefore cannot practice law, and therefore she cannot be considered counsel for Alto Properties Inc. Reviewing the transcripts and listening to the recording from the LTB hearing on September 26, 2018. There can be no arguments that it was in fact Stella Reddy using all racially charged language, prejudice slurs and racially motivated actions at the LTB hearing. But amazingly Alto Properties Inc. are trying to claim/piggy back their absolute privilege on the behalf of the their alleged former Alto Properties Inc. Property Manager Stella Reddy. The HRTO complaints could proceed as two different hearings on two different days. It is Applicants position that the racially charged language and prejudice slurs and actions by Stella Reddy are not to be considered absolute privilege as they are NOT THE BASIS of the complaints filed against the 3 Respondents.. It is clear that the Applicants are not relaying on the now alleged former Alto Properties Inc. Property Manager Stella Reddy racially charged language and prejudice slurs as the foundation/basis of their complaints against the 3 Respondents and their harassing, discriminating and acting in reprisal behaviour. The Applicants are only wishing to use the obvious racially charged language and prejudice slurs to support their claims against the 3 Respondents.
There was absolutely no reason for 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?
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… 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 Stella Reddy to utter the slur “ Newfie ” numerous times in front of the Applicants, arbitrator and public. 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 Applicants found 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 Stella Reddy to say the racially charged “ Mullato ” statement towards and in the presence of their children again. 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…
Stella Reddy statement was insensitive and shameful and it is classified as harassment. Again the racially motivated conduct Stella Reddy was unwanted and not needed in a public LTB hearing. This was the 2nd time 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.
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. 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 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?
The real irony of this whole racially charged language and actions “ He’s even darker than she is. ” that were made by Stella Reddy in perjury at the LTB hearing. Is that her great nephew has a far lighter complexion than the Applicant herself. So now that it has been confirmed that her great nephew has a lighter complexion than the Applicant. Does she really still think he is more beautiful than when he was untruthfully darker?
So what was the motive Stella Reddy making this racially charged deliberately misleadingly derogatory statement? Does Stella Reddy believe that by committing perjury, using racially charged language and prejudice slurs and actions in a public forum proves that she is not a racist? How does her nieces and nephews having children with individuals that have a different skin complexion make her not a racist? It is the position on the Applicant that any perjury that is committed in the act of a legal proceeding is not covered by absolute privilege because it is uttered with malice and intent to deceive the system. The topic that Stella Reddy lied and committed perjury about was not a topic relating to the Entry of Refusal.
The questions here is what was real reason behind Stella Reddy sudden mysterious use of all this racially charged language and prejudice slurs and actions in a public forum at the LTB hearing? What was real reason behind Stella Reddy filing all the letters from the Applicants where they called her out about her racist behaviour from a year earlier?
It almost appears that Stella Reddy was coached, maybe by some familiar with the law to come into the LTB hearing and to file these irrelevant letters, use irrelevant racially charged language and irrelevant prejudice slurs as to try and provoke a response from the “ BLACK ” Applicant and her husband? Afterwards Stella Reddy would use the Applicants provoked frustration to justify the harassment and racist motivated behaviour towards them in small claims court which she intend to file. Was she thinking that her racially charged language and prejudice slurs and actions could not be used against her, because she was coached, maybe by some familiar with the law into believing that it would qualify as absolute privilege? It would have been a win, win, win and win for Stella Reddy in her mind. ( win #1 ) She could provoke a negative response from the Applicants, ( win #2 ) use it against them in the LTB hearing, (win #3) and in Small Claims Court, and ( win #4 ) there is nothing the Applicants could do about it, as she believed it would be covered by absolute privilege. So Stella Reddy think that she deserves some praise or some form of congratulations for resisting the urge to be even more racist than she already was? It is the Applicants position Stella Reddy has not been living under a rock or in a cave her entire life. That despite their being a large population of whites in New Foundland vs. visible non – whites. There is absolutely no way a 52 year old, born Canadian, white woman with a “diverse” family is “naive” that what she said and did in a public forum wasn’t offensive, inappropriate and racist. With the above facts, the Applicants take the position that Stella Reddy racially charged language and prejudice slurs and actions were not need and uncalled for in the LTB hearing, and in fact may have been said and done as a way to protect herself from any future litigation .
- Pages 135-136 The Social Justice Tribunals Ontario Member Kevin Lundy basically conned the Applicants into giving the 3 Respondents a free preview/heads up into the Applicants case against them for October 31, 2018 on September 26, 2017. It is pretty clear and obvious that the LTB and the Divisional Court have not and will not be dealing with the substance of the HRTO complaints against the 3 Respondents. The substance of the LTB hearing was that of the 3 Respondents filed for eviction order for a Refusal of Entry. The substance of the Divisional Court is the behaviour and bias of the Social Justice Tribunals Ontario Member Kevin Lundy. The substance of the HRTO is to address the harassing, discriminating and acting in a reprisal manner by Stella Reddy where she used her position with Alto Properties Inc. against the Applicants for calling her out. The substance of the HRTO is to address the harassing, discriminating and acting in a reprisal manner by Alto Properties Inc. owner where they used their position with Alto Properties Inc. against the Applicants to support Stella Reddy and because they enforced their rights under the law.
- Pages 137-164– Reprisal –This is a long list of Past Behaviours they claim I had where they speculate on my words and actions to such a degree, trying to convince you they know me and what my motives were. It is clear that Alto Properties Inc. had as much of a hand in the racially motivated discrimination and reprisal against the Applicants as Stella Reddy did. It is clear by reading the Applicants 107 pages of Statement of Facts that the 3 Respondents did not and would not have made the mistake of making any ought right threats to the Applicants by leaving any kind of paper trail. Instead the 3 Respondents used illegal N5’s, which they knew were illegal and threats of eviction to try intimated the Applicants into compliance. Their constant attempts to deliberate inconvenience and harassment the Applicants and their endless attempts to put finical and emotional stress upon the entire family. Of course the 3 Respondents are smart enough to understand that implied ( read between the lines ) threats are far harder to prove then outright threats. It is the position of the Applicants that all the harassing, discriminating and acting in a reprisal manner by Stella Reddy against the Applicants had to be given the okay/thumbs up and embraced by Alto Properties Inc. owner. Alto Properties Inc. owner are as guilty of the same behaviour Stella Reddy as they stood by intentionally passive while giving Stella Reddy the green light to do their bidding in retaliation for their letters.
- Pages 165-168 Abuse of Process –. This only confirms why they hired Stella Reddy back in June 2016. This explains why they have hidden behind the curtain as the puppet masters while encouraging Stella Reddy to do their bidding. They both have the exact same mentality. The moment you stand up for yourself and enforce you rights under the law. They consider you to be challenging them and you are abusing the system and the process. The HRTO has to realize that practically every email Stella Reddy has ever sent to the Applicants, she has chastised them for their actions in regards to the legal system. She has constantly told them that they have zero chance in Divisional Court and with the HRTO. Why? Because of people like the Social Justice Tribunals Ontario Member Kevin Lundy who allowed her to get away with her behaviour, lies and words and never dealt with it! It is plain and simple! Because of people like Alto Properties Inc. owner allowed her to lie in the LTB hearing, used racially charged language, heard her use prejudice slurs, watched her own racially motivated actions of harassment, discriminating and acting in a reprisal manner, participated alongside with her, and did nothing about it. It is that plain and simple! It appears to be the 3 Respondents that have continuously acted in bad faith It is pretty clear by this time to the HRTO that this hearing is needed and that the documents and 3 Respondents statements prove it.
Any undue prejudice to the 3 Respondents will have been brought upon themselves through their own words, actions, documents and the Applicants have no control of that. As the remedies requested in the LTB and the Divisional are not the same as the HRTO, It is obvious that they are trying to defeat the ends of justice. As this has absolutely nothing to do with the Divisional Court and the Applicants have not asked for the Divisional Court to stay the proceedings until after the HRTO findings. It is pretty clear that there is no intended to delay on the behalf of the Applicants. The Applicants position is the more the merrier.
- Pages 169-171- No Reasonable Prospect of Success – Now this argument is probably the most fascinating and far reaching requested of them all. The Applicants and the 3 Respondents know that proving discrimination is a very hard case to prove, that it leans in favor of the 3 Respondents. But if this case was not at least justifiable to be heard, one can only imagine what the threshold must be? Just with the Applicants original complaint filing on June 04, 2018. The Applicants supplied the HRTO with 148 exhibits. Of the 148 exhibits, 75 exhibits/50% are the 3 Respondents very own paper work. (emails, letters, NOE, ect.) One would have to be hard pressed to believe that there is NO REASONABLE PROSPECT OF SUCCESS.
- Let us remember the outright lines to the HRTO that have been told…
- Example 1 – The Applicants being the only tenants to have a BBQ in the building.
- Example 2 – NO Tenants are allowed to park in visitor parking,
- Example 3 – Applicants did not return the required parking forms
- Example 4 – Her nephew’s complexion
- Pages 173-175 -Double Recovery – So it seems pretty obvious that the Applicants do not need to address this issue. Despite Alto Properties Inc. owner placing it in their response.
- Pages 176-180 Summery – The Applicants have changed their position in regards to the behaviour of 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 Stella Reddy is just a Narcissist 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. Alto Properties Inc. owner have allowed and enabled 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. There is no doubt that 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 Stella Reddy thought everything was going her way between June 2016 to July 2018.
- During this time not once did 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 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 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 Stella Reddy trying to gain some form of sympathy from the HRTO. The Applicants also take the position that 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 Stella Reddy. It appears to the Applicants that 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 who have heard and seen the racially charged language and actions of that 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 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 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 have acted in a reprisal manner against the Applicants. Alto Properties Inc. retaliated because the “Black” called them out for their lack of actions and concerns about Stella Reddy racially motivated actions of harassment, discriminating and acting in a reprisal manner. Alto Properties Inc. owner 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 retaliated because the Applicants called them out to the HRTO for their participation with Stella Reddy in the continuous harassment and inconveniencing of them. 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. Stella Reddy was their – GO TO PERSON for Alto Properties Inc. owners. 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 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. The Applicants wish to enforce their rights to add to this Reply as needed or requested.