R. v. Chouhan with Cate Martell and Janani Shanmuganathan

Join Jean-Simon Schoenholz of Norton Rose Fulbright Canada LLP as he speaks to Cate Martell (@catemartell) and Janani Shanmuganathan (@_JananiS) about R. v. Chouhan, a recent appeal regarding the constitutionality of abolishing peremptory challenges in jury selection heard by the Supreme Court Canada.

Cate Martell (www.martelldefence.com) acted as co-counsel with Jill Presser to intervene on behalf of The Advocates’ Society, and Janani Shanmuganathan, partner at Goddard & Shanmuganathan (www.gsllp.ca), intervened on behalf of the South Asian Bar Association of Toronto.

For more information about The Advocates' Society intervention in R. v. Chouhan go to https://www.advocates.ca/TAS/Advocacy_Pages/Advocacy_Pages/Select_Interventions.aspx 

Transcript

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In this episode of Friends Who Argue, we welcome Norton Rose Fulbright litigator, Jean-Simon Schoenholz, who discusses Chouhan, a Supreme Court of Canada appeal about the constitutionality of abolishing peremptory challenges in jury selection with two talented criminal law advocates who represented interveners. Cate Martell acted as co-counsel with Jill Presser to intervene on behalf of The Advocates' Society and Janani Shanmuganathan, partner at Goddard& Shanmuganathan represented the South Asian Bar Association of Toronto, or SABA, as intervener.

Jean-Simon Schoenholz: 1:05

Today, we're joined by, uh, two fantastic guests to discuss the Chouhan case, uh, which was heard by the Supreme Court of Canada in October, 2020. Uh, so first we have Cate Martell, uh, a criminal lawyer working as a sole practitioner in Toronto. Her practice focuses mainly on appeals. She worked alongside Jill Presser, uh, to intervene with the, uh, before the Supreme Court on behalf of The Advocates' Society. And our second guest is, uh, Janani Shanmuganathan, uh, a criminal lawyer in Toronto. She does criminal trials and appeals, as well as professional regulatory work. She was notably co-counsel in Nur, where the Supreme Court struck down mandatory minimums for gun possession, uh, and in Chouhan she intervened on behalf of the South Asian Bar Association of Toronto. Uh, thank you both for, uh, for joining us today. So, uh, I'd like to start, um, if you could just both tell us a little bit about yourselves and, uh, what's, what's brought you to, to this intervention before the Supreme Court, in this case.

Cate Martell: 2:19

Uh, I can go first. Um, I'm a sole practitioner with an exclusively criminal defense practice that I, uh, started up about five years ago. Um, I have a mostly appellate focus practice. I do some trial work as well, and also sometimes I'm retained by trialers to do parts of trials to argue motions or make submissions on particular issues. I got involved with Chouhan after the Supreme Court granted leave on the appeal and cross appeal. The Advocates' Society asked Jill Preser to represent it. Uh, she and I do a lot of appeal work together and she brought me on board as co-counsel.

Jean-Simon Schoenholz: 2:56

And was it your, your first, uh, intervention at the, at the Supreme Court that you were working on?

Cate Martell: 3:02

Uh, no. A few years ago. I, uh, co-counselled with, uh, Erica Chozik for the, the Criminal Lawyers' Association in Wong, uh, which dealt with when you can set aside, uh, a guilty plea, um, because of not knowing about immigration consequences, that flowed from conviction.

Jean-Simon Schoenholz: 3:18

Awesome. Cool. How about you Janani?

Janani Shanmuganathan: 3:22

So I'm also a criminal lawyer in Toronto, and I do both trials and appeals. I also do some regulatory work, which includes representing lawyers at the Law Society. And I became involved in the Chouhan appeal because I'm a board member of the South Asian Bar Association. And one of my goals when I joined SABA was to help SABA intervene for the first time at the Supreme Court of Canada, because it was something they hadn't yet done. And so when Chouhan came along, I knew that this was the perfect opportunity for SABA to intervene for the first time at the Supreme Court, because a lot of what Chouhan was about was something that resonated with a lot of the members of SABA.

Jean-Simon Schoenholz: 4:02

And, and what was that like, I guess, working with a client who was intervening for the first, for the first time, because that's, that must have been an interesting experience for you.

Janani Shanmuganathan: 4:12

It was a lot of pressure to make sure we actually got leave to intervene, but, um, it worked out well and, um, it helped that there were, or other, uh, racialized groups that were intervening and SABA was, was one of them. So that certainly helped get us at intervention.

Jean-Simon Schoenholz: 4:28

Janani, um, for those who haven't heard about this case, um, can you maybe give us a brief, you know, bird's eye view of the factual background that's relevant for the listeners today?

Janani Shanmuganathan: 4:40

Sure. So this was an appeal that had to do with the abolition of peremptory challenges and what peremptory challenges are was, um, prior to, to a piece of legislation, bill C-75, accused people, as well as the Crown had the ability to peremptory challenge certain jurors. So this meant that accused people and the Crown could each challenge a juror without providing any reason for why they were challenging them. But then bill C-75 came along and abolished these challenges, which meant that, uh, an accused person could no longer challenge a juror without providing a reason. And a juror can now only be removed or challenged pursuant to a challenge for cause. So if an accused person or a Crown is able to show that the juror was impartial in some way, or where a trial judge exercises their discretion to remove a juror in order to maintain public confidence in the administration of justice. So what this meant is that now it's essentially up to the trial judge to decide whether a juror should be removed. Whereas prior to bill C-75, an accused person had that choice themselves.

Jean-Simon Schoenholz: 5:49

And, and Cate, maybe you can, you can, uh, add to that. And that was a great factual kind of overview. Uh, what's what kind of brings us here in terms of the factual background for the, the legislation in question?

Cate Martell: 6:04

So the appeal dealt with this package of changes to the jury selection procedures, uh, in criminal trials, that was part of bill, uh, C-75. And the impetus for those changes, uh, was the trial of Saskatchewan farm owner Gerald Stanley, who, uh, in 2008 shot and killed a young Indigenous man. He was charged with second-degree murder and ultimately acquitted by an all white jury. After several Indigenous people were excluded from the jury during, uh, jury selection. After the verdict, uh, there was public outcry at the discriminatory exclusion of Indigenous people from the jury. And ultimately that was what led to the repeal of peremptory challenges as part of this package of changes to the criminal code.

Jean-Simon Schoenholz: 6:47

Fantastic. Thank you. Um, so Cate, maybe you can start by giving us, uh, you intervened on behalf of the, The Advocates' Society, um, you know, maybe go into why did The Advocates' Society think it was important to intervene on this case and, and what was your position?

Cate Martell: 7:07

So The Advocates' Society intervened on the constitutional challenge to the abolition of peremptory challenges. And the Society's concern was that, although the goal of this, uh, change to the jury selection procedures was intended to prevent the discriminatory exclusion of minority groups during jury selection, that it would actually have the effect of decreasing jury diversity, uh, because peremptory challenges were a tool often used by racialized accused persons to increase the diversity and representativeness of the jury panel. So The Advocates', The Advocates' Society, we argued that the repeal challenges violates section 11(f) of the Charter, uh, which guarantees the right to trial by jury for accused persons facing a sentence of five years or more. And we argued the peremptory challenges are essential to ensure the jury is impartial and representative of the community, which the Supreme Court is previously held or are sort of the core characteristics of the jury. We argued they're essential to impartiality, uh, cause peremptory challenges grant accused the ability to exclude a certain number of jurors whom they feel cannot decide the case fairly. And they're essential to representativeness because peremptory challenges are a tool that can be used to increase jury diversity. And without that tool, uh, random selection alone is not likely to produce juries that are representative of the community because there are, um, our segments of the community that are tend to underrepresented on the jury rolls, which is the database from which jurors are randomly selected.

Jean-Simon Schoenholz: 8:46

And so the position here taken by, by The Advocates' Society, and I understand a number of, of the interveners was, um, that even though this, uh, this bill had been brought to place to, to avoid circumstances where a jury would be, uh, less representative because of preemptory challenges that actually had these, uh, these, uh, harmful impacts on representativeness.

Cate Martell: 9:14

Exactly. It was the issue of, of whether in trying to prevent discrimination, uh, against Indigenous and racialized jurors. The government exacerbated a disadvantage face by accused persons from those same groups, which is that they're underrepresented on jury rolls. So the legislation, uh, risks exacerbating the very problem that it sought to address, which is, you know, a lack of diversity and representativeness on jury panels.

Jean-Simon Schoenholz: 9:40

Janani, uh, in the South Asian Bar Association's, um, factum, one thing that struck me, uh, is that you argued that in the Supreme Court's leading case on the right to representativeness, um, um, in the Kokopenace case, um, you argue that, um, jury representativeness extends to the mailbox and not to the courtroom and that this definition of representativeness demands a sad, bare minimum. Can you explain what you meant and how that fit more broadly into, um, into the Association's submissions?

Janani Shanmuganathan: 10:23

Sure. So, um, I never know how to pronounce this case, but I call it Kokopenace, was, um, was a case that argued, um, that the Charter requires that a jury roll, be representative of an accused person's community. So that was a case where, um, it was an Indigenous man and he was living in Kenora. And at the time of his trial between 21 and 31% of the adult population in Kenora was Indigenous. Um, but only constituted 4.1% of Kenora's jury roll. And what the Supreme Court said was, you know, under the charter, all representatives requires is that the government provide a fair opportunity for broad cross-section of society to participate in the jury process. In other words, to essentially just mail out forms for jury duty, to as many people as they can, but they can't control who actually decides to show up for jury duty. So as a result of that, and, you know, as you can see in the case of Kokopenace, um, many of the people who actually showed up for jury duty weren't Indigenous, they were white. And so this fit into my submissions on behalf of SABA, because if we can't ensure that who is going to show up for jury duty is reflective of society at large, or reflective of the accused person's background. We should arm an accused person with the ability of some choice in who actually makes their way onto the jury. And one thing that we need to kind of realize is, um, the way that peremptory challenges had been used by some trial lawyers was if you see, um, a number of jurors who are not racialized on the jury, you can sort of try and use a peremptory challenge on the next white person that shows up in the hopes of the next person that's gonna show up is going to be racialized. And so it's not a perfect solution, but it was one way to sort of try and create a more diverse jury. But with the abolition of it, that was a power that was taken away.

Cate Martell: 12:23

Right. It was kind of a way to get deeper into the bench so that you could have a larger number of jurors potentially to pick from, I guess, which gave you a better shot at a diverse jury.

Jean-Simon Schoenholz: 12:33

One of those scenarios where it's it's the, the solution that was in place was not, was not ideal. Uh, but it's now that's, you know, removing it is problematic because it was better than nothing, uh, in terms of enhancing representativeness of, of juries.

Janani Shanmuganathan: 12:51

And the way that it kind of works. Now, it's the first 12 people who show up for jury duty may make their way onto the jury, but given that representativeness is not required on the jury roll, first 12 people may be white and the accused may not be, so how does this achieve diversity?

Jean-Simon Schoenholz: 13:11

And, and maybe it's important to kind of, uh, explain for, for anyone who's listening, who's maybe not as familiar with, with criminal law. Um, what are, what are your other options in terms of, you know, your faced with these first 12 people? What are your other options, um, to, to have those people removed? Are there any other basis to, to remove somebody kind of for, for bias or something like that?

Janani Shanmuganathan: 13:39

So you can, you can bring a challenge for cause, but you have to try and show some evidence, um, or you have to try and make the argument that the juror is impartial in some way. But part of the argument that a lot of the intervener groups were making at the Supreme Court is that it's really hard to articulate why somebody is impartial or someone is biased. Um, you can't really put into words why someone, you may think someone is biased against you. So the challenge for cause is not a perfect solution to the abolition of peremptory challenges.

Jean-Simon Schoenholz: 14:14

Interesting. So then I, again, this, this, this, uh, peremptory challenge being a way that, you know, again, although it wasn't a perfect solution, uh, it, it was a solution that was easily accessible to attempt to enhance that representativeness in, in kind of looking at the background of this case. And, and, um, and trying to, to, to piece this together for myself, it just seemed like there was kind of something, um, dissonant between, you know, the objective of, of government in the context of, you know, why they, they abolish these peremptory challenges in the context of the, the Colten Boushie case. Um, but then hear that we have a number of interveners coming forward saying, no, this actually undermines representativeness and, and makes it more difficult for racialized accused. Um, how, how did that kind of, um, dissonance maybe, um, how do we reconcile those things, but then also, how did that come up in, in the hearing and, and, you know, in, in the way that the judges addressed, um, address these issues?

Janani Shanmuganathan: 15:28

So I think one thing that we should bear in mind when we're thinking about the Colton Boushie case is that, um, the way that peremptory challenges were used in that case was, was atypical from the perspective of many trial lawyers, because that was a case where the accused was white and defense counsel was using the peremptory challenges in a way to remove diversity from the jury to reflect the accused person's background, which is white. And so I can understand why the government, you know, there was a superficial appeal to doing that because it looked like racism and they want to get rid of racism in some way. But the reality is, is the way that peremptory challenges were more commonly used is on behalf of accused people where trial lawyers are trying to use the peremptory challenges to get at least one person that looked like the accused on the jury. And so that's really where the dissonance between, um, the reason why government did and why so many intervener groups were opposed to it is because, you know, government was focused on this atypical situation and creating a law that was gonna have vast implications for all of the accused people, when really the majority of the accused people were gonna be harmed in some way as a result of that.

Cate Martell: 16:48

So one of the things that, uh, we argue for The Advocates' Society was that the, uh, parliament should have calibrated its approach a little bit more. I mean, what they were concerned about was not peremptory challenges broadly, but the discriminatory use of peremptory challenges. And so what they should have done instead of what they could have done instead of abolishing peremptory challenges entirely and removing that option for all accused person, was to create process by, by which the trial judge can step in and prevent the abusive peremptory challenges, uh, similar to what's known in, in the US as the Batson Challenge after their Supreme Court case of, uh, Batson versus Kentucky. Um, but I, I think I have to acknowledge that that option is not without its challenges and that the US experiences with the Batson procedure have demonstrated that it is challenging to create a process that's effective in eliminating racial discrimination in, uh, in jury selection. Cause it's hard to prove discriminatory exclusion, um, all you have to do to defeat the challenges is to come up with some race neutral reason, uh, for the exclusion. So I think it was a difficult problem. And I think that's reflected in the fact that there were, you know, intervener groups, um, on both on both sides, you know, some in support of the legislation and some arguing that it was unconstitutional.

Jean-Simon Schoenholz: 18:10

And, and were there other, um, like what maybe, what other, um, alternatives maybe could, could have been, or could be considered by, um, by, by parliament, uh, going forward that that would, you know, maybe be, uh, be, um, allow for juries to be more representative and even peremptory challenge would, would allow.

Cate Martell: 18:39

I'm not sure that I know the answer either. I mean, one of the problems the court identified in Kokopenace was that, you know, the problem starts right at the beginning of the process, which is just sending out, um, jury, uh, app forms and getting them back from as wide a cross-section of society as possible. That's kind of where the challenge begins and begins with the, with the lists, from which those, um, from which those, those addresses and names are, are gathered, um, which is, often you know, from property lists, which, so it doesn't capture people who are, uh, who are renters. And, um, Janani's factum for, for SABA, uh, addressed this as well that the, this, the problem starts with just capturing, you know, a broad cross section of society in the first place. So it's a difficult problem, and I'm not quite sure what the solution is. I think it'll be interesting to see how this experiment with abolishing peremtory challenges, uh, shakes out, you know, do we end up with your, with juries that are more diverse or, or more homogenous, there were certainly people who argued for both sides.

Janani Shanmuganathan: 19:48

Yeah, it would be really interesting to see. I mean, as Cate just said, the, the problem with jury representativeness is, is that like the back end in terms of the mailboxes and all these people who are getting and responding to those, um, jury forms, and it's almost too late in the process, try to fix it at the jury selection process because you really need a solution that figures it out at the beginning, not at the end. Um, but yes, I am curious to see what the court writes in Chouhan to see if they, they explain how we could potentially address jury diversity, even, um, in the absence of peremptory challenges and how trial judges should use our discretionary power and when's appropriate, what's not appropriate. Uh, so yeah, it'll be, it'll be interesting. And it'll almost like an empirical study that we can do about let's look at juries before peremptory challenges or when they existed. And now let's look at it after and see, these are a difference. Maybe it will make a difference. I don't know.

Jean-Simon Schoenholz: 20:48

And, and as, as you're alluding to, uh, the court upheld the constitutionality of, of this bill and, and the abolition of peremptory challenges and, and decided that from the bench with reasons to follow, as I understand, is there, and you kind of already alluded to it as, uh, Janani, but is there, is there anything either of you and maybe Cate, you can start that you're, you're kind of hoping to see in those reasons,

Cate Martell: 21:18

Uh, I hope to see the court address, The Advocates' Society's argument that 11(f) the, the right to trial by jury should be given, uh, a broader, more generous interpretation than 11(d), which is the, the right to, uh, an independent and impartial tribunal. Um, and to provide a little bit more guidance on what is the content of the right to trial by jury. There isn't a lot of, uh, jurisprudent from the Supreme Court on that, um, what the scope of that right is, and that it would be really helpful to see,

Janani Shanmuganathan: 21:49

I'm hoping to see, I guess, some sort of like validation on behalf of all of the racialized intravenous groups that appeared and all of the people that were making submissions on the importance of diversity on the jury. Um, you know, it felt, I think it's fair to say that it was kind of disappointing and a bit like hurtful that all these people appeared and made these submissions, and it was a full day of argument. And then out of nowhere, I don't think anyone was expecting it, the court came back and just decided it from the bench that almost felt like a bit of a waste of time. And so I'm really hoping that there is some acknowledgement that diversity is important, even if it's not maybe a constitutional right, but that we should all be as society seeking more diverse representations on the jury and perhaps some guidance on how to achieve that in the absence of preemptory challenges.

Jean-Simon Schoenholz: 22:45

And, and that's certainly something that I got out of watching the submissions was that there was a number of racialized lawyers making some really, you know, important, uh, oral submissions that were brought, you know, I, I thought a really strong perspective to the table. Um, notably, uh, I noticed on, on Twitter during your submissions, Janani, that, uh, you know, there, there was a lot of, of, uh, of people commenting on, on your very strong, uh, submissions that you, that you made and that focused on, you know, uh, almost empathizing with the perspective of the racialized accused. Um, you said, uh, you know, it's an experience that most white judges have not lived. Um, this podcast is about, you know, friends who argue and, and, you know, advocates and, uh, what did it feel like to make those submissions and, and what went into kind of making, making that choice?

Janani Shanmuganathan: 23:49

So I actually, um, didn't write my submissions, um, before the day of the appeal, I wanted to listen to the arguments that were made on behalf of the appellant, um, just to hear what the court was interested and are not interested in. And, um, I just, I knew I had five minutes, it wasn't gonna be a lot of time anyway. And so I wanted to make my five minutes count. And so, as I was listening to the exchange between council and the court, it became obvious to me that, um, you know, some of the members on, on the bench, uh, didn't seem to really get the point of why peremptory challenges mattered so much to accuse people, or why diversity matters so much to accuse people in terms of their, the jury. And so I thought it was important to spend my five minutes trying to explain as best I could, what it feels like to be the only racialized person in a courtroom and why a racialized accused would want somebody that resembles them on the jury. Because I knew that, you know, I mean, the reality is, is we have an all white Supreme Court of Canada. Um, they're not racialized. They may not know what it feels like to walk into a courtroom and have everybody else in the courtroom not look like them. And so I wanted to spend those five minutes trying to explain that and convey that message.

Jean-Simon Schoenholz: 25:14

And I think it was a, a really impactful moment, um, which I, I encourage anybody listening to go to go look at. Cate from the kind of other, uh, other perspective of, of written submissions. Um, you know, and this will probably be the case for a number of our listeners at some point where you're kind of intervening on these significant cases. Um, there's a number of interveners participating in, and the, the perspectives being brought forward might be kind of similar. Um, how do you make, you know, in your case, The Advocates' Society stand out, do you have any, any tips for, uh, people who might be intervening for the first time in terms of making strong written submissions,

Cate Martell: 26:00

Although what the courts below, um, so Chouhan had argued that, uh, the repeal of peremptory challenges was institutional under both 11(d), which is the right to an independent and impartial tribunal and 11(f) the, the right to trial by jury. Um, he had focused on 11(d) and the courts below had, had essentially treated 11(d) and 11(f) as co-extensive. So their analysis of 11(f) uh, was quite brief, and that kind of stuck out to us in the Court of Appeals decision, uh, cause in Kokopenace, which, uh, Janani's always also, already spoken about. And, um, which was also a case that The Advocates' Society intervened in, uh, the Supreme Court found, although there's overlap between the rights under 11(d) and 11(f). 11(f) is broader, uh, has serves this sort of broader function of making sure that, uh, the juries, uh, are act as the conscience of the community and that, uh, serves the purpose in, um, ensuring the public perceives the verdict as legitimate. So this seemed to leave the door open to an argument in this case that even in peremptory challenges are not essential, uh, to an impartial tribunal that they're essential to the right to trial by jury guaranteed by 11(f). So that's what our factum and submissions focused on. And, uh, you know, we knew that out of the other interveners and parties, uh, nobody else was planning to focus specifically on 11(f) all the action was going to be around the guarantee of impartiality under 11(d). So we thought by focusing on 11(f) we could build on the submissions of the appellant, um, and also offer something different and something that would be helpful to the court.

Janani Shanmuganathan: 27:46

And just one thing I would add to that is, um, it's always difficult trying to carve out something unique to say when there's a lot of interveners intervening on a particular appeal. And, um, you know, a lot of the interveners are kind of saying the same thing, and you're trying to say the same thing in a different way to, to make it sound unique. And so, um, I would just recommend people don't just consider like the sexy arguments, like look for the boring ones too, because they do prove kind of useful to the court. And so what angle, one angle I took in the written submissions, um, was to look at like a comparative analysis of let's see what other countries are doing, and the fact that peremptory challenges have been abolished in other countries try to see, is there any distinctions that we can make in terms of why they abolished it there and why it may be okay there, but not here? Uh, it's not the sexiest argument, but I think it's useful, especially when it comes to, um, the, the, the judges writing the judgement. I know that they often look to see what other countries are doing in order to justify the reasons for why they're doing what they're doing.

Jean-Simon Schoenholz: 28:51

Yeah. Thinking outside the box, being creative and, and helping the court to kind of cover all its bases in a, in a way, and to have the, all the information that might be relevant to it be put forward. So obviously this is, you know, a really significant case when it comes to, um, the right to a jury and the right to representativeness, um, within a jury. Where do you see this going next? Where do you see, um, the development of, of, you know, the right to jury representativeness go next and, and, you know, where do you see also, you know, opportunities for, uh, for further challenges, um, specifically in, in terms of, you know, racial justice and, um, and, and, and everything that, that comes around that?

Janani Shanmuganathan: 29:47

Um, I'm not sure. I think, um, you know, I'd be curious to see, especially sort of as talking about this, this empirical study of, well, let's see what juries look like following the abolition of peremptory challenges. I don't think this is the end of the road for challenging the representatives of juries. I do think there's going to be a day where there's gonna be some acknowledgement that we need to do more than just mail out jury notices to people. I think, especially in light of just, you know, this, this discussion among, um, you know, this move in, in the legal system about trying to create more diversity among the judiciary, right? Like we wanna see, um, more women, more racialized people on the bench. And so why do we want that? Why do we want diversity in the judiciary? Shouldn't that same desire, then move to the jury. If both of these are triers of facts, shouldn't we want diversity among both of them? So I don't think this is gonna be the end of the road for jury representativeness. And I think there's gonna be another challenge coming, but we'll have to first see what the court says in Chouhan first.

Cate Martell: 30:59

Yeah. Yeah. I, I agree. I think there, there is for representativeness arguments and, you know, the court, um, did in Kokopenace, uh, articulate quite a, a narrow role for representativeness. Um, but I don't think that sort of conclusively answers the, the question of, of what, you know, the scope of the right to a representative jury. Kokopenace was focused very narrowly on one stage of the process, you know, how the, how, um, the state gathers the list of jurors, it sends out questionnaires. And it kind of assumed an adequate in court selection process. And so didn't comment on that process. So I, I think, you know, there is still lots of room for challenges to that process. Um, if you know, something, uh, in those procedures, either impedes, uh, the creation of a diverse jury panel, or, um, or, you know, in this, this case, we argue that a tool was taken away that could increase diversity. And I, I think there is still scope for other similar arguments, depending on what happens next and then how, you know, the new legislation shakes out.

Jean-Simon Schoenholz: 32:11

Well, thank you so much, um, that that's, it's, it's been really interesting, um, chatting with you both about this, uh, really important case and, and really, uh, significant issues. And, um, we'll stay tuned to see, uh, you know, what the court's reasons look like. Um, I imagine in the near future, but, uh, thank you both so much for, for your contribution. It's been great speaking with you and, um, yeah, I look forward to see, uh, your, your future interventions.<laugh>.

Janani Shanmuganathan: 32:45

Great. Thanks a lot.

Cate Martell: 32:45

Thanks a lot.

Web Haile: 32:48

Thank you to Jean-Simon Schoenholz, Cate Martell, and Janani Shanmuganathan for a thoughtful discussion. Thank you also to my co-editors Chris Horkins and Chloe Snider. Our production leads Ian Breneman, Natalia Rodriguez, Laura Gurr, Matthew Huys, and Jean-Simon Schoenholz. To Danielle Baglivo of Dentons, our technical sponsor for her editing assistance, and to The Advocates' Society team for their support. This is Web Haile, co-editor Friends Who Argue, signing off.

Speaker 1: 33:19

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: 33:25

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Speaker 1: 33:31

Friends Who Argue is brought to you by The Advocates' Society, an association of advocates with over 6,000 members from all areas of practice across Canada. For more information about The Advocates' Society, go to www.advocates.ca or follow us on Twitter at,@Advocates_Soc.

Speaker 2: 33:52

Until next time we are friends who argue

Speaker 7: 34:01

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