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October 2, 2026

WITHOUT PREJUDICE
DELIVERED VIA EMAIL

To: Director of Human Resources
Lakeshore Distribution Ltd.

RE: Termination of Employment – Sarah Mitchell

Dear Director of Human Resources,

I am writing to formally respond to the termination of my employment with Lakeshore Distribution Ltd. effective September 30, 2026, and to the severance package of 8 weeks’ salary outlined in your letter of September 28, 2026. While I understand the company’s restructuring decision, the offer as presented does not reflect my legal entitlements, and I cannot accept it.

I joined Lakeshore Distribution as a Sales Representative on June 8, 2015, and was promoted to Regional Sales Manager in 2019, a role I held until my termination. Over more than 11 years of continuous service, I grew my territory’s revenue by over 40%, received consistently positive performance reviews, and was never subject to discipline of any kind. I am 52 years old and earned a base salary of $95,000, plus participation in the company’s health and dental benefits plan and annual bonus program.

Your offer of 8 weeks’ salary ($14,615.38) does not even satisfy my minimum statutory entitlements under the Ontario Employment Standards Act, 2000. With over 11 years of service, I am entitled to 8 weeks’ termination pay plus 11 weeks’ severance pay — 19 weeks in total, or approximately $34,711.54. The offer falls short of this floor by more than half.

Beyond the statutory minimums, my entitlements are governed by the common law. I did not sign an employment agreement containing an enforceable termination clause, and no such clause was ever presented to me. Applying the Bardal factors — my age of 52, my 11 years of loyal service, my senior managerial position, and the realities of the current job market for sales leadership roles — a reasonable notice period of 13 months is appropriate. This is consistent with how Ontario courts have treated comparable long-service managerial employees.

My total compensation during that notice period — base salary plus the value of my benefits and bonus participation, confirmed as compensable by the Supreme Court of Canada in Matthews v. Ocean Nutrition Canada Ltd., 2020 SCC 26 — amounts to $108,062.50.

Against that entitlement, the company’s offer of $14,615.38 leaves a shortfall of $93,447.12. I am therefore requesting a full and final settlement of $108,062.50, less statutory deductions and less any amounts already paid, to resolve all claims arising from the termination of my employment.

I have valued my 11 years at Lakeshore Distribution and would strongly prefer to resolve this matter professionally and without litigation. Please respond with your position within 14 days of the date of this letter.

Legal precedents relied upon:

• - Bardal v. Globe & Mail Ltd., (1960), 24 D.L.R. (2d) 140 (Ont. H.C.)
• - Matthews v. Ocean Nutrition Canada Ltd., 2020 SCC 26
• - Machtinger v. HOJ Industries Ltd., [1992] 1 S.C.R. 986

I look forward to your prompt response.

Sincerely,

Sarah Mitchell