LTD The Year in Review...LTD The Year in Review Steve Rastin McCarthy Bergeron Rastin Clifford LLP Box 398 16984 Hwy 12 Midland ON L4R 4L1 Tel 705 528 7088 Fax 705 528 7067 OTLA 2005

LTD The Year in Review

Steve Rastin

McCarthy Bergeron Rastin Clifford LLP

Box 398 16984 Hwy 12

Midland ON L4R 4L1

Tel 705 528 7088

Fax 705 528 7067

OTLA 2005 FALL CONFERENCE

LTD THE YEAR IN REVIEW

TEN THINGS YOU OUGHT TO KNOW

By Steve Rastin and Lee Ann FournierMCCARTHY BERGERON RASTIN CLIFFORD LLP

As the Ontario workforce ages there is a significant likelihood that the number of

workers finding themselves disabled and claiming LTD benefits will increase

Recent proposals to raise or eliminate the mandatory retirement age may also

contribute to this trend Plaintiffs lawyers will likely encounter more disgruntled

workers complaining of being wrongfully denied long term disability benefits Its

simple mathematics More claims will lead to more disputes In an era when

legislative changes increasingly impair the ability of motor vehicle accident

victims to obtain full compensation lawyers may find that LTD litigation naturally

becomes a larger part of their practice

LTD litigation remains dynamic Ten years ago jury notices were barred in LTD

actions in Ontario now they are common1

The doctrine of bad faith has taken

root in LTD litigation Insurers are constantly developing new and innovative

arguments which have the potential to defeat a Claimants action for benefits

Tactics and strategy are essential weapons for the Claimant and his her lawyer

as they cross blades with some of the largest insurers in Canada in these

disputes

IM Steven Rastin Judge or Jury Where to Turn for Insurance Claims 1998 OTLA Spring Conference

Day II Tab 2 and Ramm v Sun Life Assurance Company ofCanada 1999 43 O R P 652 Gen Div

RASTIN FOURNIER MBRC LLP

LTD TEN THINGS YOU OUGHT TO KNOW

1

With this in mind we have set out a few recent developments that Plaintiffs

lawyers might find useful as they litigate in this area

Procedural Issues

The Impact of the Pre Claim medicalexamination

Pursuant to the Rule 33 01 of the Rules of Civil Procedure and s 105 of the

Courts of Justice Act a defendant is entitled as of right to compel the plaintiff to

submit to a medical examination However what is the impact of medical

examinations conducted prior to the issuance of the Statementof Claim It is not

uncommon for insurers to require regular medical examinations while a person is

on claim When a claim is denied insurers have generally placed the onus for

gathering additional medical information on the claimant at his her expense

A common exception to this practice seems to occur after the insurer becomes

aware that the claimant has retained counsel and is considering litigation It is

our common practice to write a letter asking for the file before suing This allows

us to evaluate the file and to determine if there is any evidence of improper

conduct that should be specifically pleaded in the Statement of Claim In some

cases however LTD insurers have responded to a request to produce the file by

sending the Claimant to another round of medical examinations If the

examinations support disability benefits are reinstated and the insurer avoids

litigation


LTD TEN THINGS You OUGHT To KNOW

2

If benefits are not reinstated LTD insurers will routinely schedule another round

of medical examinations Be advised however that Zinchuk v Unum

Providentof Canada2

stands for the proposition that a second round of medical

examinations should not be granted In this case Zinchuks mental health was in

question In this case Unum conducted three psychiatric examinations in 1996

1999 and 2002 Benefits were terminated shortly after the last examination and

the Statement of Claim was issued in 2003 Unum relied on Tsegay v McGuire3

which allowed a fresh examination after a tort action was started notwithstanding

that the defendant had conducted two examinations prior to issuance of the

claim However Master Egan preferred to follow a line of cases flowing from

Binns v Skinner Estate4 where Justice MacDonald refused to allow the same

insurer to have separate examinations for accident benefits and statutory third

party purposes MacDonald J stated

I am of the view therefore that a prior medical examinationunder one

statute or its regulation is relevant to the question of whether a

medical examination properly may be ordered under the other statute

or its regulation 5

Masters and Judges seem wary of allowing insurers to bolster their case when

they have already had the benefit of choosing to send a Claimant to the doctor of

their choice and to make a decision regarding payment of benefits based on that

2 February 2 2005 Master J Egan Court File No 03 CV 251214CM CanLII 2327 Ont S C3

2000 1 C P C 5th 311 Ont S C J4

2000 O J No 3739 S C J5

at para 14 See also St Pierre v Liberty Mutual Insurance Group 2001 O J No 5973 affirmed on

appeal at 2002 O J No 5356 S C J and Ebrani v Citadel General Assurance 1998 O J No 6279

Gen Div



3

examination While the Zinchuk decision is clearly beneficial to claimants this

matter is far from decided

The Choice of who to Examine of Behalfof the Insurer

This is a critical decision Many LTD insurers have professional witnesses who

travel the country appearing as the representative of the defendant at

Examinations for Discovery These witnesses will have no direct experience with

the file or your client Generally speaking examining these witnesses is of

limited value If you have a legitimate bad faith case examinations of this sort

are a complete waste of time

My practice is to require a sworn Affidavit of Documents with Schedule A

productions BEFORE I advise the insurer of the person I want to examine LTD

insurers are usually good about providing you with internal correspondence We

try to identify the lowest decision maker on a file that had a significant role in the

decision to terminate benefits Examination of the decision maker may give you

first hand information that you would never obtain by examining the insurers

professional witness For example a couple of years ago after reviewing the

production documents we determined that the decision maker on a file was a

claims representative based out of Florida I required that she be produced in

Canada and under examination she admitted that she had a grade 12 education

no medical training no training manual no understanding of Canadian law no

knowledge of what CPP disability was had never met my client and did not



4

bother to even schedule a medical before terminating benefits because we dont

do that down in Florida

Asking the insurer to produce the decision maker may also assist you in

determining whether the LTD insurer has farmed out the file to a claims handling

company This practice which has only recently come to light involves

situations in which large Canadian insurers have contracted with independent

companies usually American to assist and or take over claim handling of some

files Clients have complained that the claims handling practices in some of

these cases have been very aggressive A warning bell should sound if you are

told that the decision maker is not an employee of the insurance company

Claims handling is a high turn over industry and the adjuster may have left

however the adjuster may NEVER have worked for the LTD insurer in the first

place You need to determine if that is indeed the fact If necessary find out

the identity of the independent claims handling company and add it as a party to

your action

OTLA member John Johnson has more experience with this phenomenon than

most and Plaintiff lawyers that are interested in this area should contact John or

see some of the papers he has delivered at recent Bad Faith Section

Conferences



5

The Option to Bring an LTD Action in Simplified Rules

One of the ongoing barriers to LTD litigation is that the quantum of the claim is

often not significant by the date of trial Assuming you are retained shortly after

benefits are terminated and you move the action forward quickly total arrears by

the date of trial might be very modest We have personally seen cases where

there has been a CPP overpayment and the total arrears at the eve of trial has

been less than 15 000 While the value of future benefits may be significant

that is only relevantfor the purpose of settlement discussions A Court can only

order payment of arrears From a cost benefit analysis perspective it can be a

challenge for lawyers and clients

One possible solution flows out of the recent decision of Keddy v Clarica Life

Insurance Company 6In this case the Plaintiff sued for benefits from the date

of termination to the date of trial plus damages for breach of contract mental

distress and or aggravated damages The twist is that she sued in Simplified

Rules Clarica brought a motion to amend its pleadings and claim that the action

was not within the jurisdiction of Rule 76 and ought to be transferred to ordinary

procedure Clarica wanted inter alia an Examination for Discovery Clarica

noted the claim was for more than 50 000 and complained that the strategy

adopted by the Plaintiff would likely lead to multiple proceedings Mrs Keddy

responded by abandoning the amount of her claim exceeding 50 000 Justice

Browne refused to move the claim out of Simplified Procedure He found that

6November 13 2002 Justice E R Browne Court File No 38656 CanLII 10004 Ont S C


LTD TEN THINGS You OUGHT TO KNOW

6

any future litigation about future benefits would be based on evidence that would

come into being at a later date and should not bar the current matter from

proceeding in its current format

There are some significant advantages in some cases to being able to get a case

to Court quickly without having to go through the expense of Examinations for

Discovery This strategy is probably not the best however in cases where the

Claimant feels that he she has a legitimate bad faith or poor claims handling

argument In those cases Plaintiffs lawyers will need the opportunity to examine

the insurer in order to build the case

Collateral Deduction Disputes

Long Term Disability contracts are always written by the insurer and the insured

has usually never seen a copy of the contract This is especially true where the

LTD policy is part of a workplace group benefits policy It is not surprising that

these contracts tend to contain very favourable terms for the insurer Care

should be taken when interpreting the collateral deductions clause of the

contract Generally the insurer takes the position that it is entitled to any income

paid to the worker from any source including but not limited to C P P disability

benefits wages severance packages other insurance policies etc


LTD TEN THINGS YOU OUGHT To KNOW

7

It is worth noting that some insurers based outside of Ontario have often taken

the position that they are entitled to deduct payments made to MVA victims for

income replacement benefits paid pursuant to accident benefits provisions of

policies In the alternative the insurer will write the victim a letter demanding that

he she advance a subrogated claim for repayment of those benefits from the

accident benefits or tort insurer Claims of this nature arise from a

misunderstanding of the Ontario Insurance Act In these cases our practice is to

send them a copy of Section 267 8 which clearly sets out Ontario law which

requires the LTD insurer to pay first It is the motor vehicle insurer which gets the

benefit of LTD insurance and not the other way around

WSIB Benefits

LTD insurers will also try to get the benefit of WSIB coverage As a general rule

a person opts for either WSIB benefits or LTD benefits Even if entitlement to

LTD benefits survived the election for WSIB payments the WSIB quantum would

likely wipe out any obligation on the LTD insurer to pay An important case

dealing with the interaction between WSIB money and LTD payments is

Abdulrahim v Manufacturers Life Insurance Company 8Here the Plaintiff

was seriously injured with a cutter and sustained injuries to his arm and leg He

originally opted to receive WSIB benefits and he also applied for LTD benefits

through his Group Policy ManuLife took the position that it was entitled to an off

7R S 0 1990 1 8

82003 65 O R 3d 543 2003 CanLII 48161 Ont S C



8

set for any WSIB money paid The Plaintiffs solicitors then wrote to the parties

advising everyonethat they had decided to de elect WSIB benefits and wanted

to proceed with a tort action against the German based manufacturer of the

cutter that injured Abdulrahim WSIB demanded full repayment by certified

cheque and discontinued payments in the interim Manulife strongly objected to

the Plaintiffs decision and argued that the Policy obligated Abdulrahim to apply

for benefits to which he was entitled including WSIB and his decision to de elect

was improper Manulife attempted to deduct the money that would have been

paid by WSIB and relied on a section of the policy which stated

If an Employee does not apply for a benefit for which he is eligible the

amount of such benefit will be estimated by Manulife Financial andassumed to be paid 9

The central issue at the motion was the proper interpretation of the phrase

receives or is entitled to receive in the Policy Justice Himel applied the

principles of interpretation relating to insurance contracts as set out by Mr

Justice Sopinka in Brissette v Westbury Life Insurance Company 10These

principles include the idea that ambiguities should be construed against the

insurer After a lengthy analysis he concluded that the contract was not clear

and should be interpreted in favour of the insured He found that since the

Plaintiff elected to proceed in tort the WSIB benefit was not availableto him

9Para 17 of decision clause g ofBenefit Calculation Rules

11992 CanLII 32 S C C 1992 3 S C R 87 at 92 93



9

Deducting Severance Payments from LTD Payments

Most LTD contracts stipulate that they are entitled to deduct money paid by the 410employer to the employee by way of severance Employers on the other hand

have tried to claim a set off for LTD payments when paying out severance

packages It is very common for employers to terminate workers that have been

off for an extended period of time with or without a severance Plaintiffs lawyers

running LTD actions will almost certainly be asked to provide advice on the inter

action between LTD payments and severance packages

Employers have been trying to deduct LTD payments from severance package

for a considerable period of time The Supreme Court of Canada seemed to

support their position in Sylvester v British Columbia when the Supremes

allowed the employer to take credit for disability payments and deduct those

payments from damages for wrongful dismissal Justice Major found that since

the disability policy was entirely funded by the employer there was no

expectation that the employee could receive both benefits

I

There was significant criticism to Sylvester as many felt that the Courts were

making it all too easy for employers to terminate ill employees at reduced cost

The potential harm caused by Sylvester was greatly limited by the Ontario Court

1997 146 D L R 4th 207 S C C

IIRASTIN FOURNIER MBRC LLP


10

of Appeal in Sills v Childrens Aid Society of Belleville12 Simmons J A

relying on an earlierdecision of the Supreme Court13 concluded

Absent an express provision precluding double recovery in my view

the principles in Cunningham assist in determining whether an

intention that there would be double recovery in the event of a

wrongful dismissal can be inferred I consider it reasonable to assume

that an employee would not willingly negotiate and pay for a benefit

that would allow her employer to avoid responsibility for a wrongfulact I consider it reasonable to infer that parties would agree that an

employee would retain disability benefits in addition to damages for

wrongful dismissal where the employee has effectively paid for the

benefits in question 14

The key here is to note that benefits can be paid for directly OR INDIRECTLY

Since most employees can argue that they take less to have their group benefits

paid for by the employer it can be said to be an indirect benefit These principles

have been followed repeatedly in Ontario See for example the recent decision

of Dowling v TNTLogistics North America 15

What about the reverse LTD insurers claim they are entitled to severance

packages Their contracts often state this specially However recent authority

suggests that they may not be on solid ground Consider for example the

closing statement of Speigel J in Dowling

There is nothing in the employment contract that would indicate that

Dowling cannot receive both employment benefits and LTD benefits

Further the provisions of the Plan are contractual provisions with the

insurer not with TNT There are the usual provisions that state that

an employee on LTD has his or her benefits reduced if an employee is

122001 53 O R 3d 577 C A

13 Cunningham v Wheeler 1994 CanLII 120 1994 1 S C R 35914

At para 4515 May 24 2004 Justice G Speigel 2005 CanLII 18293 Ont S C

RASTIN FOURNIER MBRC Lty


11

earning money elsewhere I do not interpret these provisions toapply to an employee receiving damages for wrongful dismissalan insurer under an LTD policy would be hard pressed to deductthese damages 16

Until recently the question of how to treat severance packages was rare

because most employers use the doctrine of frustration to terminate contracts

without paying severance However employers should be aware of the recent

Ontario Court of Appeal decision of 0 N A v Mount Sinai Hospital17 which

holds that notwithstanding the exemptions set out in the Ontario Employment

Standards Act an employer MUST pay severance to an employee even if the

contract is frustrated

Entitlement Issues

Denial basedon Failure to Mitigate

Winning in LTD litigation is about more than proving your client is disabled

according to the terms of the policy LTD litigation seems simpler than motor

vehicle cases because you dont need to worry about liability questions There

are a host of arguments however that an insurer can raise to deny liability It is

necessary to anticipate and counter these arguments as early as possible in the

litigation process

16Para 13 emphasis mine

172005 O J No 1739 C A



12

Some concerns are common to all personal injury litigation For instance in

Deyonge v Liberty Mutual Insurance Company 18 the trial judge found that the

plaintiff was someone who was quite sick however he also found that she had

failed to seek sufficient medical treatment He concluded on the evidence that

she would have recovered earlier if she had sought psychiatric assistance as per

her doctors recommendation He reduced the allowable period of her disability

accordingly When mitigation arguments are in play it is essential that you be

able to argue with supporting medical evidence that 1 the proposed treatment is

unrealistic or doctors think it is a bad idea 2 that your client has tried a form of

the treatment without success already 3 that the treatment will not cause

improvement in any event and or 4 that your client has taken all reasonable

steps to assist with his her own recovery Failure to cover off mitigation may

result in a claim being dismissed even when the Court finds the client is disabled

Denial basedon Misrepresentation

Another area of particular concern in LTD contracts is misrepresentation

Insurers have relied upon failure to disclose and misrepresentation to deny

numerous claims Consider the leading Court of Appeal decision of Gregory V

Jolley Aetna Life Insurance et al19

In the case Gregory asserted a claim for

disability benefits and was successful after a 19 day trial notwithstanding that the

trial judge found he had misrepresented material facts relating to his medical

182003 25 C C E L 3rd 27 2003 CanLII 42935 Ont S C affirmed at 2004 CanLII 30220 Ont C A

192001 54 O R 3d 481 201 D L R 4th 729 147 O A C 336 Ont C A



13

condition and income The trial judges decision was based on his conclusion

that there was no evidence of fraud and therefore the incontestability clause

applied This clause which is common to most policies holds that an insurer

cannot void a policy for misrepresentations after two years from the application

for insurance in the absence of fraud The decision was overturned by the

Ontario Court of Appeal which found that Gregory had misled the insurer with

respect to his medical conditions and had grossly overstatedhis income He was

in fact losing money not making the six digit income he claimed The Court found

that the misrepresentations were sufficiently reckless as to be considered

fraudulent in the civil sense The result of the insureds failure to disclose

material facts or act in good faith therefore made the policy voidable and Aetna

was not obliged to pay any benefits even though Gregory was clearly profoundly

disabled

Material misrepresentation is routinely pleaded by insurers In cases where

clients have filled out an application for insurance which will likely not happen in

group policy situations counsel should get a copy of the application early in the

process and go over the form with the client line by line to look for any possible

inaccuracies Remember that innocent mistakes are treated differently at law

than fraudulent misrepresentations


LTD TEN THINGS YOU OUGHT To KNOW

14

Limitationand Qualifvina PeriodIssues

Often LTD insurers will provide a relative short appeal window when they set out

a denial letter Many letters typically give claimants 60 or 90 days to appeal

failing which the insurer will close its file We have had several instances where

claimants for whatever reason dont take action within this appeal window and

then conclude that they have missed the opportunity to appeal the decision to

deny benefits In some cases claimants will wait months if not years before

consultinga lawyer

If you are consulted by a claimant it is important to actually see a copy of the

denial letter The stated appeal window on the letter is not determinative but

unless you have evidence to the contrary you should assume that you are

governed by the standard one year limitation period

It is important to get a hold of the termination letter because some policies have

extended notice periods We have encountered one large insurer that regularly

incorporates a two year appeal period 20

Even if a client has missed the limitation period Morgan v Dominion21 is the

root case in a long line of authority that stands for the proposition that benefits

cannot be denied until they become due and claimants therefore have a rolling

20The Great West Life Assurance Companyof Canada21

1980 31 O R 2d

285 H C J

RASTIN FOURNIER MBRC uy


15

limitation period in which to claim benefits If a potential client comes into your

office after the expiry of a limitation period it is important to immediately issue a

Notice of Action to preserve the claim to as much of the arrears as possible

In situations where the client has improved over time however Morgan v

Dominion may not be able to help you In order for a client to qualify for benefits

it is necessary to prove that he she was disabled during what is commonly

referred to in policies as the qualifying period It is not enough to prove that

your client is disabled as for the date of trial you must also prove that he she

was disabled as of the end of the qualifying period Consider for example

Lyons v Canada Life Assurance Company22 where the jury awarded the

Plaintiff six months worth of disability benefits covering a six month period in

1995 even though the claim was not commenced until November 1998 The

Court of Appeal overturned the award primarily on the basis that an award for

benefits for this time period was barred by the limitation period in the policy 23

Plaintiffs counsel attempted to defend the decision using the discoverability

principle but that argument was doomed to failure because the trial judge did not

reference discoverability in his charge to the jury

222002 22 C C E L 3d 217 2002 166 O A C 299 CanLII 18089

23The Court also overturned the award of 235 000 aggravatedand 25 000 punitive damages



16

A better example of the qualifying period piffall at work is Martin v

Manufacturers Life Insurance Company 24Martin injured herself in a ski

accident in April 1998 She did not submit a claim until October 2001 and it was

denied in January 2002 due to late filing In June 2003 she commenced an

action Justice Bouck conducted a detailed analysis of the policy and concluded

that Martin was obligated to file a claim within a specified period of time after the

injury Further to succeed she needed to prove that she was totally disabled

from working within the qualifying period In Martins case the evidence showed

that she was not disabled during the qualifying period but only became disabled

later when she ceased working in order to undergo surgical treatment However

this later period of disability was found irrelevant Because there was insufficient

proof that Martin was disabled during the qualifying period the claim was

dismissed

The risk of being found to have become disabled after the end of a qualifying

period is significant especially in cases where individuals are suffering from

degenerative problems have been terminated from their employment and do not

seek legal advice for an extended period of time after benefits are denied

24 August 2004 Bouck J 2005 BCSC 528 CANLII



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lniunctive Relief

Perhaps the most intriguing case to come out of LTD litigation in recent years is

the motions decision of Traynor V Unum Life insurance Company of

America25

After developing chronic fatigue syndrome Andrew Traynor applied

to Unum for disability benefits but he was denied Traynor not only launched a

Statement of Claim but also brought an immediate motion for an interlocutory

mandatory injunction to require Unum to pay monthly disability benefits pending

trial Significant evidence was led concerning bad faith claims handling practices

by Unum The motion was granted at first instance but overturned on appeal to

the divisional court in a sharply divided decision

Justices Cunningham and Matlow issued a terse four page decision allowing the

appeal The majority was clearly concerned with the floodgate argument noting

that mandatory interlocutory injunctions are exceptional relief granted only in

exceptional circumstances and that if this were such a case similar results

might be held to constitute irreparable harm in a broad variety of breach of

contract cases even outside of insurance policies a result which is not

supportable by the present state of the law The majority also concluded that it

could not be said that Traynor would suffer irreparable harm if the injunction was

not granted Finally the majority found the ruling would wrongfully deprive Unum

252003 65 O R 3d 7 2003 CanLII 40149 and 17998 Divisional Court



18

of the right to require sufficient proof in order to continue payments as entitlement

to future payments without proof was not a benefit conferred by the policy

Justice Kurisko wrote a spirited dissent supporting the ruling of the motions

judge He found ample evidence of irreparable harm and further found that

Unums conduct was so blameworthy that the insurer could not be said to be

coming to Court with clean hands and its own actions should disentitle it to relief

Kurisko J relief in part on the ruling of Keenan J who even though he granted

leave to appeal ordered continuation of disability payments pending the appeal

He said

I have concluded however that it would be manifestly unfair to Mr

Traynor to permit Unum to withhold payments under the insurance

policy pending the outcome of this matter At this point there appearsto be responsible medical evidence that he suffers form chronic

fatigue syndrome Without the payments under the policy Mr

Traynor would be reduced to a level below the level of poverty His

circumstances would be such that he would not even be able to afford

food for himself and his family because of all the other obligations that

he confronts each month 26

Justice Kuriskos decision is extensive and supported by considerable authority

While the decision of the majority is clearly a significant obstacle the dissent at

least leaves open the possibility that the law will evolve in this direction in the

future

26Dissent ofKurisko J paragraph46 quoting Keenan J



19

The Growth of Bad Faith in LTD Litigation

Considerable attention has been given to the development of the bad faith

doctrine in fire loss and accident benefits cases but a good argument can be

made that bad faith and aggravated damages claims will likely be more

successful in LTD litigation than anywhere else In house lawyers at the large

disability insurance companies are very aware of recent bad faith decisions

Further there is increasing evidence that Canadian insurers are being influenced

by American claims handling practices which have historically been highly

aggressive Some Canadian companies have farmed out difficult claims to

American Claims Handling companies Mergers and competitive business

practices have put increasing pressure on claims handlers In the United States

questionable claims handling practices have resulted in large damage awards

and significant fines27

Lawyers for LTD insurers seem prepared to accept that aggravated and bad faith

damages are appropriate in some cases provided supporting evidence is

tendered and they will settle cases on that basis28

27Consider the precedent setting fine of 1 million US imposed against Unum Provident as a result of the

Georgia Insurance Commissioners investigationof its practices28

For judicial confirmation of same see Bryan v Crown Life Insurance 2004 CanLII 22955 Ont S C

As part ofa previous settlement Crown Life paid the plaintiff 59 000 lump sum for her difficulties

during the times when her payments were held up para 9



20

It is important however that steps be taken BEFORE the claim is drafted to

identify specific instances and occurrences that might support a claim for bad

faith and or aggravated damages Kennedy v Manulife29 is authority for the

proposition that a claim that contains allegations without any factual backing of

bad faith conduct runs the risk of being struck out The best course of action is

to do your homework before the claim is drafted plead specific allegations that

can be supported and refrain from making the bad faith argument in the absence

of compelling evidence

Conclusion

LTD litigation is likely to be an expanding area of the law in Ontario Claimants

are clearly disadvantaged by the fact that the LTD insurers write and interpret the

Policies However there are many weapons that an innovative advocate can

use to advance the rights of claimants that have wrongly been denied benefits

Thank you

292003 CanLII 32544 Ont S C



21