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CHAPTER 6 LEGAL CITATIONS E 93 In their work, lawyers deal with problems and situations governed by principles of common law or statute law, and

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CHAPTER 6 LEGAL CITATIONS E 93 In their work, lawyers deal with problems and situations governed by principles of common law or statute law, and the ability of lawyers, law clerks/paralegals, and legal administrative assistants to accurately cite the law is an essential part of legal advocacy. Common law is based on unwritten custom and long-established practices. Much of this law is based on court decisions made by judges; this is referred to as case law or precedent. The decision of a judge in a matter must be followed by all lOWer court judges dealing with similar matters, until the decision is changed by a higher court. Statute law is based on the legislation passed by Parliament or provincial leg- islatures in the form of acts. This form of law has put into writing many common law principles and is sometimes referred to as written law. When referring to a source of law, the lawyer is said to cite it, and the actual ref erence is called a citation. The citation provides a way to accurately locate the law (whether case or statute) that is being relied on in the legal situation being reviewed. S17Tlff LINUV The federal Constitution Act sets out the divisions of legislative power between the federal government and the provinces; this division was originally set out in 1867 in the British North America Act. Each province, in turn, may grant power to its municipalities (for example, to a city) to pass by-laws and ordinances. Statutes Legislation passed by the federal government or a provincial legislature is knowu as an act; all acts in effect in a province and in Canada are known as statutes. Each year, Canada and each province publish volumes containing all new acts passed during the previous legislative year, as well as amendments to existing acts, and these are identified by year (for example, Statutes of Ontario 2007}. These statutes are referred to by the following abbreviations: Name of Statutes Abbreviation Statutes of Canada S.C. Statutes of Alberta S.A. Statutes of British Columbia S.B.C. Statutes of Manitoba S.M. Statutes of New Brunswick S.N.B. Statutes of Newfoundland and Labrador S.N. Statutes of Nova Scotia S.N.S. Statutes of the Northwest Territories S.N.W.T. Statutes of Nunavut S.Nu. Statutes of Ontario 5.0. Statutes of Prince Edward Island S.P.E.l. Statutes of Quebec SQ. Statutes of Saskatchewan 8.5. Statutes of Yukon NEL a.______._.__.__.-_.._.___.,_ 96 I PART 1 GENERAL LEGAL OFFICE PROCEDURES AND DOCUMENTATION Although government websites may be considered reliable, remember to review any disclaimer on the website stating how comprehensive and current the site is. This should always be taken into consideration when conducting and relying on Internet research. References to Acts When any reference, or citation, to a statute is made, it must contain the following information: 1. the name of the act (in italics or underlined) 2. the abbreviation for the statute or revised statutes and year 3. the chapter number (including the alpha letter if applicable) 4. the sectionlsubsections (if applicable) Each part of the citation is separated by a comma. See the following examples: Chapter Section/Subsections Canada Business Corporations Act, R.S.C. 1985, c. C44, s. 1(d)(iii) Alberta Health Care insurance Act, R.S.A. 2000, c. A-20 It the act has not yet been consolidated, the year in which the act was passed is shown as part of the name of the act, in addition to the statute reference. For example: Name of Act Chapter SectionISubsectlons Ammunition Regulation Act, 1994, REGULATIONS The acts of a province or of Canada stipulate the law on a particular topic; regulations are published to indicate how the law is to be carried out or administered. For example, the Courts oflustt'ce Act, R.S.O. 1990, c. C43, sets out the structure and juris- diction of courts in Ontario. The Rules of Civil Procedure contain the regulations pro- viding how the provisions of this act are to be carried out covering such matters as how a legal proceeding is commenced in the courts, the form of required documents, where proceedings are to be heard, and how orders of the court are to be enforced. Periodically, all existing regulations are consolidated in volumes known as the revised or consolidated regulations, identified by the year of consolidation; for example, for Canada, consolidated regulations are identified as Consolidated Regulations of Canada, or C.R.C.; for Ontario, they are identified as Revised Regulations of Ontario, or R.R.0., with the appropriate year. in consolidations, the regulations are arranged in alphabetical order and are identified by consecu- tive chapter numbers. NEL 104 1 PART I GENERAL LEGAL OFFICE PROCEDURES AND DOCUMENTATION Name of Case Year Volume Number (if any) Page (Style of Cause) Abbreviated Name Number of Law Report Series (if any) Re Hart Holding Ltd. and Stone, [2006] 1 S.C.R. The following is an explanation of each element of this second example: Name of Case - in this proceeding, one of the parties is a corporation, so the full name of the corporation is shown, along with just the last name of the second party, who is an individual. 0 Note that the "Re" is included in the name of the case and denotes that it is an application proceeding with the names separated by and instead of v. Year 0 The year still denotes when the judgment was handed down by the court. - The year, however, is now also "essential" because in this report series, the volume is designated first by year and then by volume within the year; that is, a new sequence of volume numbers begins each year. 0 Square brackets are used to denote that the series is organized by year, and the comma now appears before the year following the style of cause. Volume, Law Report, Series 0 1 S.C.R. denotes that this case may be found in the lst volume of the Supreme Court Reports for 2006. Page Number - 46 denotes that this case is reported beginning on page 46 of the applicable volume of the report. Name of the Court - The name of the court is not included as it is obvious from the name of the report. Pinpoint References If a certain page or paragraph of the law report is being quoted or merits special attention, a pinpoint reference may be made to this section of the law report. If the reference is to a certain paragraph (which is becoming more common with elec- tronic documents), the abbreviations \"para." or \"paras." should be used, followed NEL 94 E' PART I GENERAL LEGAL. OFFICE PROCEDURES AND DOCUMENTATION Revised Statutes At certain intervals, which vary provincially and federally, all existing acts of Canada and the provinces and territories are published, including all amend- ments made to them since the last publication, and are referred to as revised statutes. These are identified by the year of consolidation (for example, Revised Statutes of Canada 1985). The revised statutes are referred to by the following abbreviations: Name of Statutes Abbreviation Revised Statutes of Canada R.S.C. Revised Statutes of Alberta R.S.A. Revised Statutes of British Columbia R.S.B.C. Revised Statutes of Manitoba R.S.M. Revised Statutes of New Brunswick R.S.N.B. Revised Statutes of Newfoundland and Labrador R.S.N. Revised Statutes of Nova Scotia R.S.N.S. Revised Statutes of the Northwest Territories R.S.N.W.T. Revised Statutes of Nunavut R.S.Nu. Revised Statutes of Ontario R.S.O. Revised Statutes of Prince Edward island R.S.P.E.I. Revised Statutes of Quebec R.S.Q. Revised Statutes of Saskatchewan R.S.S. Revised Statutes of Yukon Order of Acts in Statutes In publications of both statutes and revised statutes, the acts appear in alphabet- ical order; each act is a numbered chapter. Several provinces, such as British Columbia, follow a straight numerical sequence, for example, Chapter 1, Chapter 2. Federal statutes and those of many other provinces, including Ontario, follow an alphanumeric sequence, for example, Chapter (3-2 (federal) or Chapter C.2 (Ontario). Names of Acts When an act is passed, it is given a name that clearly identifies its main purpose; for example, the Age of Majority Act establishes the age at which an individual is deemed to be an adult and may vote in provincial and federal elections. The article \"the\" is part of the proper name of an act in the provinces of Manitoba and Saskatchewan, for example, The Manitoba Hydro Act. For all other provinces, terri- tories, and federal acts, \"the" is not part of the proper name of the act, for example, the Trustee Act. NEL I02 I PART 'I GENERAL. LEGAL OFFICE PROCEDURES AND DOCUMENTATION Table 6.2 Guide to Abbreviations for Some English Law Reports REPORT ABBREVIATION All England Reports, 1936 All E.R. All England Law Reports, 1999 All E.R. Law Reports, Appeal Case A.C. Law Reports, Chancery Division Ch. Law Reports, King's Bench Division KB. Queen's Bench Reports QB. Law Reports, Probate, Divorce, and P. Admiralty Division NOTE: The year is not an essential part of any English case having a date prior to 1891. Preparing Citations of Law Reports A keyed reference to a law report has the following elements: 1. Name of the case (referred to as the style of cause or title of proceeding) in italics or underscored 2. Year in square or round brackets depending on whether the year is \"essential" or \"non-essential\" in order to locate the law report 3. Volume number (it any). abbreviated name of law report, series (if any) 4. Page number at which the case starts 5. Name of the court (in brackets) that decided the case if not obvious from the name of the report series The ONLY comma is between the case name and the beginning of the refer- ence to its location. Name of Case Year Volume Number (if any) Page Name of (Style of Cause) Abbreviated Name Number Court of Law Report (if required) Series [if any) Hart v.5tone (2001), ' 7s O.R. (3d) (C.A.) HEL 106 I PART 1 GENERAL LEGAL OFFICE PROCEDURES AND DOCUMENTATION ELECTRONIC RESOURCE CITA'IJONS Before the introduction of electronic technology, the only way to ascertain the cases related to a particular fact pattern was to determine the key word or phrases that described the legal situation, such as CONTRACTS: Implied terms - Discretion. The topical index of reported cases under that key word or phrase was searched, and the applicable cases were read to determine which best supported the current fact pat- tern. This method was slow and time-consuming. Although it is still necessary to read the applicable cases when they have been determined, electronic technology now permits the quick retrieval of a list of cases to be reviewed on a particular topic using much the same methodology but by using the electronic search engines of legal databases. Traditionally, a law student or junior lawyer searched the law reports for the appropriate decided cases; however, legal assistants are now sometimes responsible for initiating computer retrieval searches and providing the necessary list or hard copies of appropriate cases or statutes to be reviewed. Subscription services such as LexisNexis Quicklaw'm (http:Hglobal.lexisnexiscornica) or WestlaweCARSWELL (http:waw.westlawecarswell.com/home) or the open access database CanLll (httpzliwwwcanliiorg), managed by the Federation of Law Societies of Canada, pro- vide searchable electronic databases of both statute and case law. In citing these resources, keep the following points in mind: 1. Always cite a printed report first, if possible, in addition to the electronic reference 2. Include the style of cause (in italics) as in a traditional citation. followed by any citations from print reporters, and then key in the reference to the electronic database, which is usually shown at the top of the first page of the case. For example: Hebb v. Hebb (1991), 103 N.S.R. (2d) 147, CanLIl 2523 (NS CA.) 3. The URL address is not usually shown (as this may change) and is only used if citing an unreported case that is not available anywhere else. However, this is usually unnecessary as electronic databases have a case identifier or docket number that may be used, as shown in the following examples: Bovingdon v. Hergott, 2006 CanLll 312.02 (ON S.C.) R. v. Shawon, [1995.] S.C.J. No. 9 (QL) The \"S.C.J." abbreviation here refers to Supreme Court Judgments; the abbrevia- tion is also used for each of the provincial and territorial judgment databases. For example, O.C.J. would refer to Ontario Court Judgments, and B.C.J. would refer to British Columbia Judgments. The court identification is then followed by \"No.\" and the identifying number in the Quicklaw database. NEL CHAPTER 6 LEGAL CITATIONS I 95 Locating Acts Although most law firms will maintain a copy of any statutes (including updates) that are applicable to the areas of law in which they practise, most federal and provincial statutes may also now be accessed electronically through government- sponsored websites, as well as the electronic databases discussed later in this chapter. Below is a list of applicable government websites: Jurisdiction Provider URL Canada Department of Justice, Canada http://laws.justice.gc.ca/ Alberta Alberta's Queen's Printer http://www.qp.gov.ab.ca/ index.cfm British Columbia British Columbia http://www.qp.gov.bc.ca/statreg/ Queen's Printer Manitoba Queen's Printer for Manitoba http://www.gov.mb.ca/chc/ statpub/ New Brunswick Queen's Printer for http://www.gov.mb.ca/chc/ New Brunswick statpub/ Newfoundland House of Assembly http://www.hoa.gov.nl.ca/ and Labrador hoa/sr/ Nova Scotia Nova Scotia Legislative Counsel http://www.gov.ns.ca/ legislature/legc/ Northwest Department of Justice http://www.justice.gov.nt.ca/ Territories Nunavut Department of Justice http://www.justice.gov.nu.ca/ Ontario Ministry of Government http://www.justice.gov.nu.ca/ Services Prince Edward Legislative Counsel Office http://www.gov.pe.ca/law/ Island Quebec Publications Quebec http://www.publications duquebec.gouv.qc.ca Saskatchewan Queen's Printer http://www.qp.gov.sk.ca/ Yukon Department of Justice http://www.justice.gov.yk.ca/ NEL95 '3 PART I GENERAL LEGAL OFFICE PROCEDURES AND DOCUMENTATION case LAW When a court decision is made that is thought to be of great interest to lawyers, it is reported in a law report, which is a published account of a legal proceeding. The report outlines the facts of the case, the arguments put forth by all parties involved, the iudgment given by the court, and the reasons for that judgment. Lawyers are very interested in such decisions since the judgment arrived at in one case must be followed in another case where the facts are the same, until a higher court changes the decision. In acting for a client, the lawyer frequently wishes to know the deci- sion of the courts in similar situations and will refer to previously decided cases. LAW REPORTS There are many published law reports. Lawyers subscribe to the series of reports published for the province in which they practise, as well as to the reports of cases decided in the Supreme Court of Canada. Many series are published weekly or monthly in booklet form or may be subscribed to electronically. At regular intervals (often after 10 booklets have been published), the booklets are sent out to be bound into a hardcover volume. Abbreviations for Law Reports Abbreviations for the more frequently encountered Canadian law reports are shown in Table 6.1. Not all series are still being published, but reference is still made to cases they reported. References may also be made to English reports, some of which are listed in Table 6.2 (p. 102). When in doubt about the correct abbreviation for a law report not shown in Table 6.1 or 6.2, refer to the Canadian Guide to Uniform Legai Citation, 6th Edition (Thomson Carswell), a copy of which is usually available in the law office library. Identication of Bound Volumes of Law Reports Each series of law reports is contained in bound volumes, identified by the abbrevi ation for the law report and either by year or by consecutive volume number. Frequently, when a law report is identified by year, there are several published vol- umes of that law report in the year. it is necessary to indicate which volume for that year is being referred to; for example, including a 2 or a 3 indicates that it is the second or third volume in the year. Some law reports have been identified by volume alone at one time and by year at other times. Table 6.1 provides a guide for determining whether a Canadian case is cited by year or by volume. When square brackets appear before the abbreviation for the law report, the report is cited by year. NEL CHAPTER 6 LEGAL CITATIONS E 105 by the applicable paragraph number or numbers. if the reference is to a certain page or pages, it is not preceded by the word \"page\" or "pages\"; just the actual page number or numbers are keyed in. These references are always preceded by the word at, as shown in the following examples: Britt's}.l Columbia v. Tanner (1985), 28 B.C.L.R. (2d) 241 at para. 41 R. 1/. Paid (1983), 3 W.W.R. 673 at 675-676 More than One Report Cited Many decided cases are reported in more than one law report; these are referred to as parallel citations. When citing such cases, the name of the case is set out, fol- lowed by each law report in which it may be found. Note that the year of the deci- sion does not need to be repeated with each report and that each parallel citation is separated with the comma. For example: Fagan v. Emery investments Ltd. (1986), 54 OR. (2d) 615, 27 D.L.R. (4th) 257, 3 C.P.C. (2d) 10] NEUTRAL CITATIONS Since 1999, some Canadian courts have started to assign a neutral citation to their judgments, most notably the Supreme Court of Canada. If the case being reported has a neutral citation, the neutral citation is cited first, followed by any print report citations. The print citation is still required as the neutral citation is only a case identifier and does not identify where the printed report of the case can be found. A neutral citation consists of three parts, as shown in the following example: Year of Decision Ordinal Number The following example shows parallel citations of a case including the neutral citation: R. v. Sharpe, 2001 scc 2, [2001] 1 S.C.R. 45, 194 D.L.R. (4th) 1 This citation is of a criminal case that was appealed. The Supreme Court of Canada handed down its decision in 2001, which has the neutral citation of SCC 2, which means that it was the 2nd case decided in 2001. This is followed by the print cita- tion, which was reported in Volume 1 of the Supreme Court Reports of 2001 begin- ning on page 45, and the parallel citation is in Volume 194 of the 4th series of the Dominion Law Reports beginning on page 1. NEL .-.....__....._ CHAPTER 6 LEGAL CITATIONS 97 Subsequent to the publication of the consolidated revised regulations, new reg- ulations are published in the appropriate gazette, discussed below, and are usually identified by a regulations number, commencing at 1 for each calendar year, and the year it was passed. Note that some provinces show all four digits for the year; others use only two. For example: O. Reg. 48/06: refers to the 48th consecutive regulation passed in Ontario in 2006 N.S. Reg. 83/2007: refers to the 83rd consecutive regulation passed in Nova Scotia in 2007 For Canada, regulations are identified by Statutory Orders and Regulations numbers commencing at 1 for each calendar year. For example: SOR/2006-347 GAZETTES The provinces and territories, as well as Canada, issue official publications entitled "gazettes" at regular intervals to provide information on statutory notices, royal assent to new acts, appointments, new regulations, etc. The following is a list of the gazettes that are available free to the general public in full-text versions online: Name of Publication Website Canada Gazette http://canadagazette.gc.ca/ Alberta Gazette http://www.qp.gov.ab.ca/display_gazette.cfm Ontario Gazette http://www.ontariogazette.gov.on.ca/ Royal Gazette http://www.gov.pe.ca/royalgazette/ (Prince Edward Island) Royal Gazette http://www.gnb.ca/0062/gazette/index-e.asp (New Brunswick) Newfoundland and http://www.gs.gov.nl.ca/gs/oqp/gazette/ Labrador Gazette Nunavut Gazette http://www.justice.gov.nu.ca/english/gazette/ Yukon Gazette http://gazette.gov.yk.ca/home.html Alternatively, copies of all provincial, territorial and federal gazettes may be subscribed to for a fee either electronically or in hard copy and may also be found in the law office or public library. These "gazettes" are important because once an act or regulation is published in a gazette, it is considered publicly and officially published. NEL8 1 of 20 6 CHAPTER Legal Citations OBJECTIVES: Distinguish between statute law and case law and explain the significance of each Define and describe the various legal publications, such as acts, regulations, gazettes, and law reports, and how they may be located Prepare memoranda of law and letters incorporating citations 92 NELCHAPTER 6 LEGAL CITATIONS !. 103 The following is an explanation of each element of Example 1: Name of Case 0 Hart v. Stone is the name of the case, which is also referred to sometimes as the "style of cause\" and denotes that this is a lawsuit in which Hart is suing Stone. Only the last names of the first mentioned party on each side are shown; that is, er of. or and others is not included if there are additional par- ties on either side. . The \"v.\" is an abbreviation for versus. The names of the parties and the \"v.\" are italicized or may be underlined (but not both). - Note that a style of cause of R. v. Stone would be a reference to a criminal case against Stone. The "R" refers to the Latin word for queenreginain legal citations. 0 Note that a style of cause of Re Hart and Stone would indicate a case that was an application to the court for its determination. Year - The year denotes when the judgment was handed by the court in this case, which is also the year in which it was published. if the decision and the publi- cation date are different, then both may be shown, but this is not the usual practice. 0 If the year is not required to locate the law report, then any reference to a year is said to be \"non-essential\" and appears in round brackets followed by a comma, as shown in this example. This is how most law reports are now organized, with the notable exception of the Supreme Court Reports, dis- cussed below. Voiume, Law Report, Series 0 75 OR. (3d) denotes that this case may be found in the 75th volume of the 3rd series of the Ontario Reports. 0 Frequently, law reports identified by volume number have several series, each commencing with Volume 1 and continuing indefinitely until a new series is started. It is then necessary to indicate which series the volume is part of by including a (2d), (3d), or (N.S.) following the name of the law report to indicate the second, third, or new series of that report. 0 10] denotes that this case is reported beginning on page 101 of the applicable volume of the report. Page Number ' I Note that the word "page\" is not included. I Name of Court - (CA) refers to the Court of Appeal. 0 This reference is included because the assumption might otherwise be made that this was a decision of a lower court. NEL CHAPTER 6 LEGAL CITATIONS _ 101 Table 6.1 Guide to Citing Canadian Law Reports (continued) LAW REPORT PERIOD ABBREVIATION Ontario Law Reports 1901-1931 O.L.R. Ontario Practice Reports 1850-1901 O.P.R. Ontario Reports 1882-1900 O.R. 1931-1973 [ ] O.R. 1973-1990 O.R. (2d) 1991- O.R. (3d) Ontario Weekly Notes 1909-1932 O.W.N. 1933-1962 [ ] O.W.N. Real Property Reports 1977-1988 R.P.R. 1988-1996 R.P.R. (2d) 1996- R.P.R. (3d) Reports of Family Law 1971-1978 R.F.L. 1978-1986 R.F.L. (2d) 1986-1994 R.F.L. (3d) 1994-2000 R.F.L. (4th) 2000- R.F.L. (5th) Reports of Family Law 1824-1970 R.F.L. Rep. (Reprint Series) Saskatchewan Law Reports 1907-1931 Sask. L.R. Saskatchewan Reports 1980- S.R. Canada Law Reports: 1923-1969 [ ] S.C.R. Supreme Court of Canada Canada Supreme Court Reports 1877-1922 S.C.R. 1970- [ ] S.C.R. Western Law Reporter 1905-1917 W.L.R. Western Weekly Reports 1911-1916 W.W.R. 1917-1950 [ ] W.W.R. 1951-1970 W.W.R. (N.S.) 1971- [ ] W.W.R. NELCHAPTER 6 LEGAL CITATIONS E 99 Table 6.1 Guide to Citing Canadian Law Reports LAW REPORT PERIOD ABBREVIATION Alberta Law Reports 1908-1933 Alta. L.R. 1976-1992 Alta. L.R. (2d) 1992- Alta. L.R. (3d) Alberta Reports 1976- A.R. All Canada Weekly Summaries 1970-1979 [ ] A.C. W.S. 1980-1986 A.C.W.S. (2d) 1986- A.C.W.S. (3d) Atlantic Provinces Report 1975- A.P.R. British Columbia Reports 1867-1947 B.C.R. British Columbia Law Reports 1977-1986 B.C.L.R. 1986-1995 B.C.L.R. (2d) 1995- B.C.L.R. (3d) Business Law Reports 1977-1990 B.L.R. 1991-1999 B.L.R. (2d) 2000- B.L.R. (3d) Canadian Bankruptcy Reports 1920-1960 C.B.R. 60-1990 C.B.R. (N.S.) 1991-1998 C.B.R. (3d) 1998- C.B.R. (4th) Canadian Cases on the Law 1976-1990 C.C.L.T. of Torts 1990-2000 C.C.L.T. (2d) 2000- C.C.L.T. (3d) Canadian Intellectual 1984-1990 C.I.P.R. Property Reports Canadian Patent Reporter 1941-1971 C.P.R. 1971-1984 C.P.R. (2d) 1985-1999 C.P.R. (3d) 1999- C.P.R. (4th) Carswell's Practice Cases 1976-1985 C.P.C. 1985-1992 C.P.C. (2d) 1992-1997 C.P.C. (3d) 1997-2000 C.P.C. (4th) 2001-2005 C.P.C. (5th) 2006- C.P.C. (6th) NELCHAPTER 6 LEGAL CITATIONS E MEMOMNDA. 9" HTML Reference may be made to decided cases in legal correspondence, but the most fre- quent use is in a special type of memorandum, a memorandum of law, that is pre- pared most frequently for the use of lawyers who practise in the area of civil litigation. When a lawyer is retained to act for a client in a matter that may lead to court proceedings, the lawyer looks for previously decided cases (also called authorities) that support the client's position. The individual reading the law finds the names of cases dealing with a problem similar to that of the new client and then reads the cases in the law reports and prepares a memorandum setting out the infor- mation learned from the cases. An example of a memorandum of law is shown in Precedent 6.1. The memorandum is usually double spaced, many pages in length, and contains citations of and quotations from the decided cases that have been reviewed. A guide for typing quotations is provided in Chapter 2. Reference to Judges The memorandum of law usually indicates the last name of the judge or judges who gave the decision from which material is being quoted, followed by an abbreviation indicating the position of that judge or those judges. The following table lists the accepted abbreviations to be used, including some archaic references that may be encountered in older case law reports: Abbreviation Reference C.J.C. ChiefJustice of Canada C.J.A. Chief Justice of Appeal C]. Chief Justice, Chief Judge J.A. Justice of Appeal, Judge of Appeals Court JJ. . Justices of Appeal, Judges of Appeals Court J. Justice, Judge JJ. Justices, Judges Mag. Magistrate Co.Ct.J. Judge, County Court D.C.J. Judge, District Court _ Surr.Ct.J. Judge, Surrogate Court C.J.H.C. Chief Justice, High Court The abbreviation is keyed directly after the name or names of the judge or judges, and there is no comma inserted'between the name of the judge and the office. For example: " Austin]. Callaghan C.J. . . Blair, Morden, and Tarnopolsky JJ.A. \"El 107 100 PART 1 GENERAL LEGAL OFFICE PROCEDURES AND DOCUMENTATION Table 6.1 Guide to Citing Canadian Law Reports (continued) LAW REPORT PERIOD ABBREVIATION Dominion Law Reports 1912-1922 D.L.R. 1923-1955 [ ] D.L.R. 1956-1968 D.L.R. (2d) 1969-1984 D.L.R. (3d) 1984- .L.R. (4th) Eastern Law Reporter 1906-1915 E.L.R. Estates & Trusts Reports 1977-1994 E.T.R. 1994- E.T.R. (2d) Federal Court Reports 1971- [ ] F.C. Labour Arbitration Cases 1948-1972 L.A.C. 1973-1981 L.A.C. (2d) 1982-1989 L.A.C. (3d) 1989- L.A.C. (4th) Manitoba Reports 1883-1961 Man. R. 1979- Man. R. (2d) Maritime Provinces Reports 1929-1968 M.P.R. Motor Vehicle Reports 1979-1988 M.V.R. 1988-1994 M.V.R. (2d) 1994-2000 M.V.R. (3d) 2000- M.V.R. (4th) National Reporter 1973- N.R. New Brunswick Reports 1825-1928 N.B.R. 1969- N.B.R. (2d) Newfoundland & Prince 1971- Nfld. & P.E.I.R. Edward Island Reports Northwest Territories Reports 1983-1998 [ ] N.W.T.R. Nova Scotia Reports 1834-1929 N.S.R. 1965-1969 N.S.R. 1969- N.S.R. (2d) Ontario Appeal Reports 1876-1900 O.A.R. NEL

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