defending economic loss claims in uncertain times · to be blunt, an economic loss claim asserted...

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Defending Economic Loss Claims in Uncertain Times

Presented by: Robert Zochodne Zochodne Law Office

Oshawa

January 22, 2010 Tricks of the Trade 2010

The Carlu College Park

Toronto

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Introduction

While virtually all claims arising from personal injury include a claim for economic loss, this paper is limited to the considerations for defence counsel when responding to significant economic loss claims in today’s economy.

The premise is that if you are prepared, if you understand the case you have to meet

and the potential value of the claim examined against the backdrop of a challenging economy, there is no logical reason you should not be able to settle economic loss claims, perhaps even more so today.

Our current economic difficulty, unlike earlier recessions, evidenced by high

unemployment, inflation and rising interest rates, does not include any inflationary pressures or rising interest rates. To the contrary, the cost of living has not risen appreciably and interest rates are as close to zero as they will ever reach.

Commencing in 2008 and beyond, we have experienced a global downturn

characterized by systemic failures in financial institutions, fluctuating currencies, a vast decline in manufacturing production, particularly in automobiles and their suppliers and falling commodity prices. The most obvious indicator of this has been the dramatic fall in stock market indices across the world.

It is not always an easy matter to predict, or to react to claims that are affected by

economic factors. However, I will examine certain categories of economic loss claims to illustrate where negative economic forces will influence how a case is to be viewed.

While the following list is not intended to be exhaustive, here are some examples of

economic loss claims that might be influenced by a decline in economic activity: 1. A self employed plaintiff who alleges that his business has suffered since the accident as a

result of injuries sustained.

These are principally causation cases. Assuming that plaintiff’s counsel asserts a claim that is merely mathematical (a loss based on the reduction from a previous year, on a dollar for dollar basis), defence counsel must develop an alternate basis for calculation in order to respond to the claim.

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For example, if the plaintiff is involved in a 2007 accident, and alleges a reduced

capacity to work in the business and the sales of his business declined by 30% in 2008 and 2009, the plaintiff is likely to assert that these losses are as a result of the accident and assert claims based upon a straight line calculation.

In this example, the defence will be called upon to prove that, as a matter of

causation, it was economic forces that led to the decline of the business, and not the plaintiff’s reduced capacity. This is not simply a matter of making the assertion and refusing to pay the claim. Rather, this can be proven by economic evidence, secured in ways set out below, to demonstrate two things. First, that the economy generally is in decline, and second that the particular sector of the economy in which the plaintiff is involved is also suffering.

This could also include a temporal component, either specific to the plaintiff and

his business, or generally by economic sector. One can be more specific in instances where the plaintiff’s business is of long standing.

The simple example would be a case where the plaintiff is a real estate broker.

The business would decline in productivity in circumstances where the transaction value of real estate has fallen. One could chart the profitability of the plaintiff’s business as against that economic indicator to determine correlations. Showing this to plaintiff’s counsel at mediation or pre-trial conference might be sufficiently persuasive to settle the case.

For example:

Sales Performance

0

20

40

60

80

2005 2006 2007 2008

Year

Do

llars

Company sales ($1,000's)

Total residential realestate sales in Ontario($10,000,000's)

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2. An employed plaintiff who alleges an inability to continue working due to injuries sustained

in an accident. However, she is employed in the manufacturing sector, which is suffering economically.

One method to respond to such claims involves the application of a percentage reduction from an economic loss claim called a “contingency”.

This is described by the Ontario Court of Appeal in Graham v. Rourke (1990), 74 D.L.R. (4th) 1:

A plaintiff who establishes a real and substantial risk of future

pecuniary loss is not necessarily entitled to the full measure of

that potential loss. Compensation for future loss is not an all-

or-nothing proposition. Entitlement to compensation will depend

in part on the degree of risk established. The greater the risk

of loss, the greater will be the compensation. The measure of

compensation for future economic loss will also depend on the

possibility, if any, that a plaintiff would have suffered some or

all of those projected losses even if the wrong done to her had

not occurred. The greater this possibility, the lower the award

for future pecuniary loss: Personal Injury Damages in Canada, op.

cit., at pp. 91-2.

…

Factors affecting the degree of risk of future economic loss and

the possibility that all or part of those losses may have

occurred apart from the wrong which is the subject of the

litigation are referred to as contingencies. The contemporary

Canadian approach to contingencies is described in Andrews v.

Grand & Toy Alberta Ltd., supra. Mr. Andrews was 23 years old

when he was rendered a quadriplegic as a result of the negligence

of the defendants. At trial he was awarded damages for loss of

future earning capacity and also for future care costs to be

incurred as a result of his medical condition. In the course of

assessing the quantum of those damages, the trial judge reduced

the total amounts by 20% as an allowance for negative

contingencies. The Court of Appeal increased that deduction to

30%. In addressing the contingency deduction for future lost

earning capacity, Dickson J.said, at p. 470:

It is a general practice to take account of contingencies which

might have affected future earnings, such as unemployment,

illness, accidents and business depression ... There are,

however, a number of qualifications which should be made.

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Contingencies can be positive and negative, see for example Ligate v. Abick (1996), 28 O.R. (3d) 1 (Ont. C.A.).

Whenever contingencies are considered, one must avoid the temptation to apply fixed, routine percentages to contingencies despite what may be the practice of actuaries or other experts in the quantification of future economic losses.

A claim for future economic loss has been neatly summarized by the Supreme Court of Canada in Andrews v. Grand & Toy Alberta Ltd., [1978] 2 S.C.R. 229 as follows:

We must now gaze more deeply into the crystal ball. What sort of

a career would the accident victim have had? What were his

prospects and potential prior to the accident? It is not loss of

earnings but, rather, loss of earning capacity for which

compensation must be made… A capital asset has been lost: what

was its value?

Bearing that in mind, it is possible to influence the thinking and the theory related to an economic loss claim.

How can this be done? Many organizations compile and publish labour market statistics as will be set out in further detail below. Within those statistics one can find concepts such as retention rates, namely the measurement of job stability in any particular sector of the economy.

Using the above example, it is possible to show that, in 2008, in the manufacturing sector, the probability of a worker having the same job as she would have had 4 years previously was 48% and down from 62% only 10 years ago, according to labour market surveys compiled by Statistics Canada.

Beyond this, one can break the figures down further based upon the length of service of the worker.

By using this information, the defence ought to be able to establish that the probability (or negative contingency) related to job loss is increasing in the manufacturing sector of the economy and therefore a higher deduction must be applied to the future wage loss calculation.

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3. A student or otherwise unemployed plaintiff who asserts that he has lost his ability to compete in the marketplace or has had his career path frustrated because of injury.

Leaving aside practical ways to assess and respond to these types of claims, it is

important to be prepared to assess the data put forward by the plaintiff. Be vigilant when examining the assumptions used by the experts for the plaintiff,

particularly as it relates to labour market statistics. While a future wage loss award is an estimate by nature, it is clear from the case law that judges are more amenable to statistics that bear a closer resemblance to the particular circumstances of the plaintiff than otherwise.

Examine whether or not the expert has used average statistics or has built in to

the analysis features of the plaintiff’s situation. To give one brief example, if the theory of the plaintiff is that he could have

worked in the manufacturing sector and earned the average industrial wage for his working life, consider these factors:

a. The availability of manufacturing jobs where the plaintiff lives; b. The type of manufacturing jobs available; c. The availability of employment in those areas; d. The average wages associated with those jobs; e. How those manufacturing industries are trending over the long term; To be blunt, an economic loss claim asserted in Oshawa based on the

assumption that the plaintiff will work in the auto industry for the next 30 years has little chance of success when met with the evidence of the decline of that industry over the past decade.

4. An employed plaintiff who alleges that she is working at a reduced capacity as a result of an injury.

This is not unlike the previous examples in the sense that it is based on causation. Was the reduced capacity as a result of an injury or because business is suffering because of the economy?

The usual example is overtime. Coming from an auto manufacturing town, I know that

there have been times when General Motors required employees to work overtime, and where ample amounts of overtime were available, and other times when worker had rotating layoffs with no overtime.

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I would recommend that you stay away from statistics, and develop practical evidence from lay experts as will be described below.

This paper is not a treatise on the law of damages. Rather, it is intended to be a practical

guide against the backdrop of our current economy. With that in mind, I apologize in advance to those who are more skilled in this area than I. For those, there may be little in this paper that you do not already consider. For anyone else, what follows is a brief review of how to marshal economic evidence.

PREPARATION, PREPARATION and PREPARATION

1. Formulate a theory

All skilled advocates will state one must, where at all possible, formulate the theory of

the defence. In my view, too often defence counsel concentrate on attacking credibility and finding flaws in the plaintiff’s case. While this is very important, I believe that the defence should also have a theory, or story, to present to the trier of fact.

For me, I think about what I will say during the course of my opening to the jury. Since a proper opening is an outline of the evidence to be presented, by framing your

consideration of the file in that way, it allows one to focus on the evidence, rather than argument. We are all skillful at presenting argument. We are frequently less skillful in gathering evidence and being a story teller for the trier of fact.

As an example, you are responding to a claim asserted by a young person who, at the

time of the accident, had not yet entered a career path. For this example, assume that the plaintiff is a high school student.

What is your theory to respond to the claim? If you represent the plaintiff, this task is far easier. You have access to parents, siblings,

other relatives, teachers, coaches, friends and neighbours. You can determine the most viable potential career path when putting together the economic claims to be asserted.

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For the defence, however, we are not so fortunate. We are left to investigate the plaintiff’s circumstances, either by way of examination for discovery or otherwise, with a view to formulating the theory that you will communicate to the jury.

What follows, using the above example, are some questions you might wish to ask: What are the plaintiff’s levels of education, training and experience? Is there a family employment pattern (a family of doctors for ex.)? Were his parents university educated? Does the plaintiff have siblings and if so what was their career path? How did the plaintiff perform in school? How did the plaintiff’s friends perform? What interests and hobbies did he have before the accident? What is the socio-economic character of the area where the plaintiff lives? Is there a predominant industry? Is it manufacturing based, resource based, or something else? Has the plaintiff been IQ tested? If you consider these types of issues, it may well be that you will find yourself

formulating a theory in response to the case. That theory might be better supported than merely criticizing a plaintiff who says that he wanted to be dentist but had failing grades in high school. Rather than attack the credibility of the plaintiff, who may well be a likeable witness, one is better served to attribute the plaintiff’s theory to the hopes of a young person which are neither right nor wrong, just not supported by the evidence.

Consider retaining an expert, such as a high school or university guidance counselor in

advance to review the plaintiff’s OSR, and educational records to give you some insight in to the needed qualifications for certain career paths. You may also require an occupational therapist to assist you in determining the physical capabilities required for any particular job.

If these experts are consulted in advance of examinations for discovery, you may be in

a better position to ask the questions, and get the answers you require to put your theory together.

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2. Don’t be surprised by what you discover

With your theory in hand, approach examination for discovery, as it relates to economic

issues in two ways. First, from a microeconomic point of view. Simply put the more particular circumstances

of this plaintiff. This is the approach that virtually every practitioner will utilize Do not hesitate to examine the plaintiff with respect to what I would describe as

macroeconomic factors as well, namely the performance of the economy from a geographic, or sector based point of view.

In the portion of the paper that will follow, you may be surprised at the breadth of

information that is kept about occupational data. I will deal with this is further detail later in the paper, but suffice it to say that a review of even the most rudimentary economic data might well give you some ideas for questions at discovery.

While those proponents of limited discovery might argue otherwise, particularly in view

of what may be a new, more restrictive test for discovery, I would suggest that you should look to gain whatever admissions might be available. You might be surprised at what you learn.

3. If you don’t ask, you will not receive

I confess to being a fan of requests to admit. I use them in all kinds of circumstances, including the admission at trial of economic data.

As I indicated previously, if you develop a theory of the defence, admitted statistics will give

you an edge when cross examining a plaintiff, or any other plaintiff witness, about economic factors. You can put a certain statistic to the witness in advance of leading the evidence with your own expert.

This is particularly important in a jury case where you do not open to the jury immediately

after the plaintiff’s counsel delivers an opening. It gives you an opportunity to present your economic evidence early in the case, and get the jury thinking about that issue long before your expert (or even the plaintiff’s expert) testifies.

I have appended to this paper, as Schedule A, a request to admit I used in a recent case

where exchange rates were important. In that case, the plaintiff alleged that his business lost money because of the accident. The defence theory was that as the plaintiff’s business

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depended upon American tourists, any losses were caused by the decrease in the value of the U.S. dollar against the Canadian dollar over the past several years.

Serving a request to admit regarding such a straightforward economic indicator can obviate

the necessity to even retain an expert at all. Not only will this save your client the expense, it will save you the time and effort of retaining and calling the expert at trial. And, the information that was attached to the request to admit was readily available from public sources, as I will describe below.

As you will see from reviewing the request to admit, it is designed to allow the defence to

file the statistics at trial, as proof of the facts without any further formal proof being required.

4. Information is a click away While I was aware of some websites where economic data is available, I was, quite frankly, very surprised by the amount of publicly available information on the internet.

I would highly recommend that you simply go to www.google,ca and search “Canadian economic data”. You will be surprised by what you find. The best source of economic data in Canada is from the website for Statistics Canada.

The website is www.statcan.gc.ca.

While we have all heard of Statistics Canada, who are they and what do they do? The following comes from the Stats Can website:

Statistics Canada, a member of the Industry Portfolio, produces

statistics that help Canadians better understand their country—

its population, resources, economy, society and culture.

In Canada, providing statistics is a federal responsibility. As

Canada’s central statistical agency, Statistics Canada is

legislated to serve this function for the whole of Canada and

each of the provinces.

Objective statistical information is vital to an open and

democratic society. It provides a solid foundation for informed

decisions by elected representatives, businesses, unions and non-

profit organizations, as well as individual Canadians.

http://www.google,ca/

http://www.statcan.gc.ca/

http://www.statcan.gc.ca/cgi-bin/relocate.cgi?l=E&loc=http://www.ic.gc.ca/epic/site/ic1.nsf/en/h_00022e.html

http://www.statcan.gc.ca/about-apercu/act-loi-eng.htm

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Statistics Canada compiles statistics in almost every conceivable area. This includes

the obvious such as population and economic growth, but also includes statistics respecting economic activity in various sectors of the economy both nationwide and also broken down by province and, in some cases, municipality.

It also tracks this information and examines and reports on economic trends.

For those of you who prefer paper, Stats Can maintains a library in Ottawa at Statistics Canada Library

2nd floor, R.H. Coats Building

Ottawa, Ontario

Telephone - 613-951-8219

In just a few minutes on the website, by searching under the geographical category of

Oshawa, I was able to find that the average household size, as of the 2006 Census, was 2.7 persons, whereas the average household size in Thunder Bay, as of the 2006 Census, was 2.3 persons.

Similarly, you can search by subject matter. Looking at the category of subject matter of manufacturing, I could see that capital expenditures in Canada for manufacturing were $20.1 billion in 2008, but only $18.4 billion in 2009. We may all consider this to be obvious from all that we read and hear in news reports, but this website gives us those statistics at our fingertips.

The website includes “community profiles” for most large municipalities. Listed is the

population, age breakdown, characteristics of families, median income, industries, education level of the population and so on.

Appended to this paper as Schedule B is the community profile of Oshawa, from the

2006 census, compiled by Statistics Canada. This is not, of course, the only place where such statistics are available. For example, the Bank of Canada maintains statistics with regard to currency exchange

rates and interest rates. The website is www.bank-banque-canada.ca. Other useful sites include:

(a) www.canadianeconomy.gc.ca/english/economy; (b) Industry Canada: www.ic.gc.ca; (c) www.economywatch.com; (d) Office of the Chief Economist: www.international.gc.ca.

http://www.bank-banque-canada.ca/

http://www.canadianeconomy.gc.ca/english/economy

http://www.ic.gc.ca/

http://www.economywatch.com/

http://www.international.gc.ca/

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5. Call in the experts As stated by the Supreme Court of Canada in Lewis v. Todd and McClure, [1980] 2 S.C.R. 94:

The evidence of actuaries and economists is of value in arriving at a fair

and just result. That evidence is of increasing importance as the niggardly

approach sometimes noted in the past is abandoned, and greater amounts are

awarded, in my view properly, in cases of severe personal injury or death. If

the Courts are to apply basic principles of the law of damages and seek to

achieve a reasonable approximation to pecuniary restitutio in integrum expert

assistance is vital.

The obvious answer to respond to economic loss claims is to retain an economist and

there are many to choose from (not unlike lawyers). If you are fortunate to be in a university town, the task is far easier, as you need not look further than the economics department on campus.

Actuaries have been qualified to give expert evidence as to some economic indicators.

In Ligate v. Abick, supra, the Court of Appeal stated the following:

The appellants submit, first, that because Mr. Segal is not

an economist he was not qualified to give evidence on future wage and

salary inflation. I note that there was no objection made at the trial

to the admissibility of Mr. Segal's evidence on this point. The most

that counsel for the defendants (not Mr. Percival) did at trial was to

suggest to Mr. Segal in cross-examination that "[i]f and economist who

had a degree in economics and had a formal recognition as an economist

you would defer to him in most cases would you?" Mr. Segal answered

that there were some economists whose views he happened to agree with

and others whose views he did not agree with. That was the end of this

point as far as the cross-examination was concerned.

In my view, Mr. Segal was qualified to give evidence on

future wage and price inflation. In this respect, I refer to two other

parts of his evidence. In cross-examination he gave the following

evidence, which was not questioned:

Economics does in fact comprise an important

part of the actuary's work to the extent that

he uses - he or she uses economic theory in

making and doing his work. The actuary is

obliged, for example, when evaluating a pension

plan to make his own determination as to what

the likely future trends will be in such areas

as inflation and interest rates and so he does

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use economics, although he is not specifically

an economist as such, although he uses

economics he is not a Ph.D. in mathematics

either, but uses mathematical techniques in

arriving at his ...

In his examination-in-chief he had testified, with respect

to wage and salary inflation, as follows:

... [I]f I were to value such a plan [a pension

plan] and if I were not to include an

assumption of salaries increasing at a faster

pace then general price inflation then it's

most likely that the Pension Commission of

Ontario would send that valuation report back

to me and say it's not acceptable, it does not

agree with general actuarial principles.

In Cooper-Stephenson and Saunders, Personal Injury Damages

in Canada (1981) the authors state at pp. 270-71 that with respect to

the prediction of inflation rates "witnesses from the fields of

insurance and finance, whose businesses depend on accurate prediction,

would seem as competent to give evidence as an economist". See also

Cooper-Stephenson, Personal Injury Damages in Canada, 2nd ed. (1996) at

pp. 58-63 and Matthews et al., The Expert - A Practitioner's Guide

(1995) at pp. 18-1 to 18-9.

In short, the evidence of Mr. Segal on this subject was

admissible and the trial judge was entitled to rely upon it.

Beyond these experts, increasingly litigants have relied upon the services of vocational

rehabilitation specialists as well. All that being said, do not hesitate to consider an expert who is not an academic, or

professionally trained. The best example of this would be a business person in a particular sector of the economy.

If I was looking to respond to a claim by a plaintiff whose case was based on the

assumption that he would have been employed in the pulp and paper industry in Thunder Bay, a person with specialized knowledge of that industry (such as a retired senior manager or human resources specialist) could be called to opine as to the availability of employment and the future prospects for employment based upon industry trends.

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Be very careful, however, to ensure that you will be able to qualify that expert. As stated by the Court of Appeal in Rice v. Sockett (1912), 27 O.L.R. 410, 8 D.L.R. 84,,

the expert must have “acquired special or peculiar knowledge of the subject of which he undertakes to testify and it does not matter whether such knowledge has been

acquired by study of scientific works or practical observation”. In that case, the court permitted a farmer to give opinion evidence about the operation

of a silo.

6. What to do when you are out of options

You are in the middle of a trial and you then realize that the state of the economy is now

in issue. You don’t have an expert report. Can you simply file statistics compiled by, for example, Statistics Canada? The simple answer is no. While there is some law to the contrary (Costello v. Blakeson;

1992 CarswellBC 2140), it is most unlikely that this course of action is permissible. However, what follows is a brief review of the law of judicial notice. You may find this

useful if the court is called upon to consider the economy generally but only as it relates to an issue that is not the central part of the case.

The leading case in this regard is R v. Spence, [2005] 3 S.C.R. 458.

In considering the issue of judicial notice the Court stated as follows:

The permissible scope of judicial notice should vary according of the

nature of the issue under consideration. The closer the fact approaches

the dispositive issue, the more the Court ought to assist on the

compliance with the strict criteria for judicial recognition. It could

be argued that the requirements of judicial notice accepted in Find

should be relax in relation to matters such as laying a factual basis

for the exercise of a discretion to permit challenges for cause. Such

non-adjudicative facts are generally called “social facts” when they

relate to the fact finding process and “legislative facts” in relation

to legislative or judicable policy. When deal with “social facts” and

“legislative facts” a Court should ask it self whether the “fact” would

be accepted by reasonable people if taken the trouble to inform

themselves on the topic as not being the subject of reasonable dispute

for the particular purpose for which it is to be used, keeping in mind

that the need for reliability and trust worthiness increasing directly

with the centrality of the “fact” to disposition of the issue in

question.

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There are a number of cases where a Court has taken judicial notice of the state of an economy.

In Brew v. Rozano Holdings Ltd. (2006) CarswellBC 1813, in considering the issue of a

maternity leave provision, the court took judicial notice “of the equal role in the economy of men and women, and the importance of maternity leave in mitigating the

disadvantage that can accrue to the absences of such provision, largely to women,

but also to men”.

In Byers v. Prince George (1998), CarswellBC 1637, the trial Judge took judicial notice

of the fact that low level jobs were more available than other types of jobs in a good economy. In reversing this aspect of the judgment the Court of Appeal stated that it was of the view that

this was outside of the view of judicial notice and stated “that his ‘fact’, if it was one, is not so universally known or accepted as to make proof unnecessary”.

In Halliday v. Ermantrout (2009), CarswellBC 2838, the court was asked to take judicial notice of a strong economy in the Peace River, British Columbia region. In considering this the Court relied upon a previous decision of the British Columbia court, citing with approval the following passage:

Judicial notice is properly taken when facts are either (1) so

notorious or generally accepted as not to be the subject of debate

among reasonable persons; or (2) Capable of immediate and accurate

demonstration by resort to readily accessible sources of indisputable

accuracy

The court went on to hold that it could not take judicial notice of the state of the job market for experienced mechanics in the Peace River, British Columbia region.

In Re Hernandez (2009), CarswellOnt 2072, decision of the Ontario Superior Court in

Bankruptcy, it was stated: “I also take judicial notice of the fact there had been a severe down turn in the economy, particularly in the automotive and manufacturing

industries, where Mr. Hernandez has had much of his employment.” In Zanewycz v. Manryk (2009), CarswellOnt 2238, the court was dealing with a

determination of imputed income in a family law case. Mr. Justice Shaw stated: “I am

prepared to take judicial notice of the fact that there has been a serious down

turn in the economy during 2008, which in all likelihood has had a negative impact

on Mr. Zanewycz’s commission income”.

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Similarly, in the decision of Marino v. Marino (2008), CarswellBC 2213 the court took

judicial notice of “certain recent events affecting the general economy that may have substantially reduced the value of all such assets (family assets being divided in

the case) in the period between the date of trial and the date of these reasons”. Obviously these decisions are of limited value, and are unlikely to assist where the economy is a central issue to the issues in the case. However, it might be possible to achieve some marginal utility from a finding that the economy, in general, has been in decline in the past two years. As previously stated this is, of course, not a substitution for careful advance planning including the necessity for expert evidence in the appropriate case.

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National Climate Data and Information ArchiveCourt file no.

XXXXXX

SCHEDULE A

ONTARIO SUPERIOR COURT OF JUSTICE

(Proceeding commenced at XXXXX)

National Climate Data and Information Archive

B E T W E E N:

Mr. X. and Mrs Y. Plaintiffs

- and -

Company A and Company B Defendants

REQUEST TO ADMIT

YOU ARE REQUESTED TO ADMIT, for the purpose of this proceeding only, the truth of the following facts:

1. That the attached data from National Climate Data and Information Archive of Environment Canada for Orillia Ontario as set out below are admissible at trial as prima facie proof of the contents thereof without further formal proof, subject to any evidence that the Plaintiffs may call and subject to the judgment of the trier of fact as to the weight to be attached to the said documents:

(a) Canadian Climate Normals for the period from 1971 to 2000 for XXXXX Ontario averaged monthly.

(b) Monthly Data Reports for the years 1999 to 2006 inclusive for XXXXX, Ontario.

2, That the attached exchange rate statistics compiled and published by

the Bank of Canada, on a weekly basis from January 1, 1999 to April

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30, 2009 showing the exchange rate from U.S. dollars to Canadian dollars is admissible at the trial of this action as prima facie proof of the contents thereof, subject to any evidence that the Plaintiffs may call and subject to the judgment of the trier of fact as to the weight to be attached to the said document.

Attached to this request is a copy of each of the documents referred to above. YOU MUST RESPOND TO THIS REQUEST by serving a response to request to admit in Form 51B prescribed by the Rules of Civil Procedure WITHIN TWENTY DAYS after this request is served on you. If you fail to do so, you will be deemed to admit, for the purposes of this proceeding only, the truth of the facts and the authenticity of the documents set out above. XXXXXX, 20XX

ZOCHODNE LAW OFFICE 106 Stevenson Road South Oshawa, Ontario L1J 5M1 Robert G. Zochodne Tel: 905-576-5153 Fax: 905-571-4376 Solicitors for Company A and Company B

TO: XXXXXXX Solicitors for the Plaintiffs

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SCHEDULE B

Oshawa

Ontario (City)

Select another region

Ontario

(Province) Select another region

Population and dwelling counts

Oshawa, City

Ontario

Total Male Female Total Male Female

Population in 20061 141,590 12,160,282†

Population in 20011 139,051 11,410,046†

2001 to 2006 population change (%) 1.8 6.6

Total private dwellings2 57,469 4,972,869

Private dwellings occupied by usual residents3 54,923 4,554,251

Population density per square kilometre 972.0 13.4

Land area (square km) 145.67 907,573.82

Figure Age characteristics

Oshawa, City

Ontario


Total population4 141,590 69,025 72,565 12,160,285 5,930,700 6,229,580

0 to 4 years 7,460 3,870 3,595 670,770 343,475 327,290

5 to 9 years 8,180 4,095 4,090 721,590 369,670 351,920

10 to 14 years 9,840 5,025 4,815 818,445 420,705 397,740

15 to 19 years 9,995 5,115 4,880 833,115 427,185 405,925

20 to 24 years 9,315 4,715 4,600 797,255 400,445 396,815

25 to 29 years 8,690 4,275 4,415 743,695 360,525 383,170

30 to 34 years 8,945 4,360 4,580 791,955 382,030 409,925

35 to 39 years 9,730 4,765 4,965 883,990 430,220 453,770

40 to 44 years 12,440 6,100 6,345 1,032,415 507,130 525,280

45 to 49 years 12,105 6,080 6,020 991,970 486,390 505,585

50 to 54 years 10,260 4,995 5,265 869,400 423,345 446,060

55 to 59 years 8,910 4,295 4,615 774,530 378,530 395,995

60 to 64 years 6,580 3,160 3,420 581,985 283,545 298,440

65 to 69 years 5,280 2,520 2,760 466,240 222,640 243,600

70 to 74 years 4,675 2,120 2,555 401,950 187,510 214,445

75 to 79 years 4,080 1,750 2,335 338,910 149,585 189,325

http://www12.statcan.ca/census-recensement/2006/dp-pd/prof/92-591/details/page_SelReg1.cfm?Lang=E&Geo1=CSD&Code1=3518013&Geo2=PR&Code2=35&Data=Count&SearchText=oshawa&SearchType=Begins&SearchPR=35&B1=All&Custom=

http://www12.statcan.ca/census-recensement/2006/dp-pd/prof/92-591/details/page_SelReg2.cfm?Lang=E&Geo1=CSD&Code1=3518013&Geo2=PR&Code2=35&Data=Count&SearchText=oshawa&SearchType=Begins&SearchPR=35&B1=All&Custom=

http://www12.statcan.ca/census-recensement/2006/dp-pd/prof/92-591/details/page_Definitions.cfm?Lang=E&Geo1=CSD&Code1=3518013&Geo2=PR&Code2=35&Data=Count&SearchText=oshawa&SearchType=Begins&SearchPR=35&B1=All&Custom=&LineID=1000

http://www12.statcan.ca/census-recensement/2006/dp-pd/prof/92-591/details/page_Flags.cfm?Lang=E&Geo1=CSD&Code1=3518013&Geo2=PR&Code2=35&Data=Count&SearchText=oshawa&SearchType=Begins&SearchPR=35&B1=All&Custom=&Flag=Refusal


http://www12.statcan.ca/census-recensement/2006/dp-pd/prof/92-591/details/page_Flags.cfm?Lang=E&Geo1=CSD&Code1=3518013&Geo2=PR&Code2=35&Data=Count&SearchText=oshawa&SearchType=Begins&SearchPR=35&B1=All&Custom=&Flag=Refusal



http://www12.statcan.ca/census-recensement/2006/dp-pd/prof/92-591/details/page_Figure.cfm?Lang=E&Geo1=CSD&Code1=3518013&Geo2=PR&Code2=35&Data=Count&SearchText=oshawa&SearchType=Begins&SearchPR=35&B1=All&Custom=&Profile=2000&Sex=Total



20

Figure

Age characteristics

Oshawa, City

Ontario


80 to 84 years 3,065 1,165 1,905 250,270 97,240 153,035

85 years and over 2,050 645 1,400 191,810 60,555 131,260

Median age of the population5 39.4 38.3 40.3 39.0 38.1 39.9

% of the population aged 15 and over 82.0 81.2 82.8 81.8 80.9 82.7

Figure

Common-law status characteristics

Oshawa, City

Ontario


Total population 15 years and over6 116,110 56,045 60,065 9,949,485 4,796,850 5,152,630

Not in a common-law relationship 105,055 50,545 54,515 9,257,730 4,448,935 4,808,790

In a common-law relationship 11,050 5,500 5,550 691,755 347,915 343,840

Figure Legal marital status characteristics

Oshawa, City

Ontario



Never legally married (single)8 38,400 20,575 17,825 3,143,960 1,662,930 1,481,025

Legally married (and not separated)9

53,900 26,945 26,955

5,168,660 2,585,115 2,583,545

Separated, but still legally married10 5,665 2,465 3,200 345,075 150,090 194,980

Divorced11 10,585 4,530 6,050 679,990 283,150 396,840

Widowed12 7,565 1,530 6,035 611,805 115,565 496,235

Figure

Occupied private dwelling characteristics

Oshawa, City

Ontario


Total private dwellings occupied by usual residents13 54,920 4,555,025

Single-detached houses - as a % of total occupied private dwellings

53.9

56.1

Semi-detached houses - as a % of total occupied private dwellings

9.6

5.7

Row houses - as a % of total occupied private dwellings 8.7 7.9

Apartments, duplex - as a % of total occupied private dwellings14

5.1

3.4

Apartments in buildings with fewer than five storeys - as a % of total occupied private dwellings14

10.6

10.8

Apartments in buildings with five or more storeys - as a % of total occupied private dwellings

12.0

15.6

Other dwellings - as a % of total occupied private dwellings15 0.2 0.5

Number of owned dwellings16 38,390 3,235,495

Number of rented dwellings17 16,530 1,312,290

Number of dwellings constructed before 1986 42,385 3,124,010























21

Figure

Occupied private dwelling characteristics

Oshawa, City

Ontario


Number of dwellings constructed between 1986 and 200618 12,535 1,431,020

Dwellings requiring major repair - as a % of total occupied private dwellings

7.0

6.6

Average number of rooms per dwelling19 6.7 6.6

Dwellings with more than one person per room - as a % of total occupied private dwellings19

0.8

1.9

Average value of owned dwelling ($)20 231,151 297,479

Figure

Selected family characteristics

Oshawa, City

Ontario


Total number of census families21 40,635 3,422,315

Number of married-couple families22 26,655 2,530,560

Number of common-law-couple families23 5,610 351,045

Number of lone-parent families 8,370 540,715

Number of female lone-parent families 6,795 441,105

Number of male lone-parent families 1,580 99,605

Average number of persons in all census families 2.9 3.0

Average number of persons in married-couple families22 3.1 3.1

Average number of persons in common-law-couple families23 2.8 2.7

Average number of persons in lone-parent families 2.5 2.5

Average number of persons in female lone-parent families 2.5 2.6

Average number of persons in male lone-parent families 2.4 2.4

Median income in 2005 - All census families ($)24 70,159 69,156

Median income in 2005 - Married-couple families ($)22 81,343 77,243

Median income in 2005 - Common-law-couple families ($)23 68,415 66,525

Median income in 2005 - Lone-parent families ($) 36,496 38,448

Median income in 2005 - Female lone-parent families ($) 32,949 36,496

Median income in 2005 - Male lone-parent families ($) 58,144 50,339

Median after-tax income in 2005 - All census families ($)24 59,513 59,377

Median after-tax income in 2005 - Married-couple families ($)22

68,313

65,534

Median after-tax income in 2005 - Common-law-couple families ($)

57,936

57,013

Median after-tax income in 2005 - Lone-parent families ($) 33,789 35,677

Median after-tax income in 2005 - Female lone-parent families ($)

31,494

34,206

Median after-tax income in 2005 - Male lone-parent families ($)

49,113

43,972

Figure Oshawa, City Ontario





















22

Selected household characteristics Total Male Female Total Male Female

Total private households25 54,920 4,555,025

Households containing a couple (married or common-law) with children26

15,420

1,420,515

Households containing a couple (married or common-law) without children27

15,495

1,288,140

One-person households 13,500 1,104,865

Other household types28 10,505 741,505

Average household size 2.5 2.6

Median income in 2005 - All private households ($)29 61,514 60,455

Median income in 2005 - Couple households with children ($)26

90,291

87,960

Median income in 2005 - Couple households without children ($)27

72,371

68,764

Median income in 2005 - One-person households ($) 32,383 30,025

Median income in 2005 - Other household types ($)28 50,176 51,560

Median after-tax income in 2005 - All private households ($)29 52,482 52,117

Median after-tax income in 2005 - Couple households with children ($)26

75,686

74,095

Median after-tax income in 2005 - Couple households without children ($)27

61,291

58,755

Median after-tax income in 2005 - One-person households ($) 28,460 26,473

Median after-tax income in 2005 - Other household types ($)28

44,946

46,194

Median monthly payments for rented dwellings ($)30 816 801

Median monthly payments for owner-occupied dwellings ($)31 1,186 1,046

Figure Mother tongue

Oshawa, City

Ontario



English only 120,610 58,870 61,740 8,230,705 4,044,755 4,185,945

French only 3,245 1,605 1,645 488,815 230,700 258,115

English and French 265 90 175 32,685 14,820 17,870

Other language(s)33 16,115 7,945 8,170 3,276,685 1,587,595 1,689,090

Figure

Knowledge of official languages

Oshawa, City

Ontario



English only 129,870 63,915 65,960 10,335,700 5,130,945 5,204,755

French only 155 65 90 49,210 21,460 27,750

English and French 9,545 4,265 5,285 1,377,330 621,285 756,045

Neither English nor French 670 265 400 266,655 104,185 162,470






















23

Figure Language spoken most often at home

Oshawa, City

Ontario



English 131,475 64,330 67,150 9,655,830 4,733,165 4,922,665

French 1,260 605 655 289,035 136,125 152,910

Non-official language 6,160 2,940 3,220 1,811,620 874,575 937,050


English and non-official language 1,185 560 620 239,890 119,205 120,685

French and non-official language 0 0 0 3,065 1,455 1,605

English, French and non-official language

10 0 10

3,405 1,480 1,925

Figure

Immigrant status and period of immigration

Oshawa, City

Ontario



Non-immigrants37 118,000 57,660 60,340 8,512,020 4,197,560 4,314,460

Immigrants38 21,925 10,665 11,260 3,398,725 1,620,320 1,778,400

Before 1991 17,365 8,605 8,760 1,884,440 901,375 983,065

1991 to 2000 3,030 1,365 1,660 933,545 443,665 489,880

2001 to 200639 1,525 695 835 580,740 275,280 305,460

Non-permanent residents40 315 180 135 118,150 59,995 58,155

Figure

Citizenship

Oshawa, City

Ontario



Canadian citizens 136,000 66,595 69,405 11,131,465 5,455,880 5,675,585

Canadian citizens under age 18 31,055 15,710 15,345 2,572,660 1,320,670 1,251,990

Canadian citizens age 18 and over 104,945 50,885 54,055 8,558,810 4,135,210 4,423,595

Not Canadian citizens42 4,245 1,915 2,330 897,430 421,990 475,435

Figure

Generation status

Oshawa, City

Ontario



1st generation44 21,835 10,620 11,215 3,340,210 1,590,525 1,749,680

2nd generation45 23,340 11,160 12,180 1,912,460 933,690 978,765

3rd generation or more46 69,610 33,780 35,835 4,566,750 2,220,495 2,346,260

Figure

Mobility status - Place of residence 1 year ago

Oshawa, City

Ontario


Total population 1 year and over47 138,675 67,625 71,050 11,893,180 5,808,065 6,085,115
























24

Figure

Mobility status - Place of residence 1 year ago

Oshawa, City

Ontario


Lived at the same address 1 year ago 118,700 57,950 60,745 10,299,250 5,027,935 5,271,320

Lived within the same province or territory 1 year ago, but changed addresses within the same

census subdivision (municipality)

12,305 6,025 6,280

951,995 466,425 485,570

Lived within the same province or territory 1 year ago, but changed addresses from another census subdivision (municipality) within the same province or territory

6,715 3,205 3,510

453,460 222,520 230,945

Lived in a different province or territory 1 year ago

555 270 285

56,835 27,630 29,205

Lived in a different country 1 year ago 400 170 235 131,630 63,550 68,075

Figure Mobility status - Place of residence 5 years ago

Oshawa, City

Ontario



Lived at the same address 5 years ago 77,810 37,870 39,945 6,660,310 3,245,120 3,415,185

Lived within the same province or territory 5 years ago, but changed addresses within the same census subdivision (municipality)

30,395 14,720 15,670

2,542,885 1,241,165 1,301,720

Lived within the same province or territory 5 years ago, but changed addresses from another census subdivision (municipality) within the same province or territory

21,050 10,235 10,810

1,398,660 682,595 716,070

Lived in a different province or territory 5 years ago

1,775 925 850

185,785 89,885 95,900

Lived in a different country 5 years ago 1,675 770 905 566,710 273,790 292,920

Figure Aboriginal population

Oshawa, City

Ontario


Total Aboriginal and non-Aboriginal identity population49

140,240 68,510 71,735

12,028,900 5,877,875 6,151,020

Aboriginal identity population50 2,515 1,265 1,250 242,490 117,585 124,900

Non-Aboriginal identity population 137,730 67,245 70,480 11,786,405 5,760,285 6,026,115

Figure

Educational attainment

Oshawa, City

Ontario



No certificate, diploma or degree 30,525 14,990 15,540 2,183,625 1,059,015 1,124,615

High school certificate or equivalent52 34,585 16,305 18,280 2,628,575 1,220,380 1,408,190

Apprenticeship or trades certificate or diploma 10,880 7,295 3,585 785,115 514,820 270,295

College, CEGEP or other non-university certificate or diploma53

24,800 10,505 14,295

1,804,775 782,360 1,022,420















25

Figure

Educational attainment

Oshawa, City

Ontario


University certificate or diploma below the bachelor level

2,895 1,230 1,665

405,270 181,355 223,915

University certificate, diploma or degree 11,095 5,235 5,855 2,012,060 986,780 1,025,280

Total population aged 15 to 2454 19,215 9,815 9,400 1,624,835 826,425 798,410

No certificate, diploma or degree 8,775 4,630 4,140 648,300 348,960 299,345

High school certificate or equivalent55 6,735 3,425 3,315 627,010 321,420 305,590

Apprenticeship or trades certificate or diploma 485 325 160 37,475 22,735 14,740


2,275 1,065 1,210

160,140 72,655 87,480


170 85 90

33,875 15,860 18,020

University certificate, diploma or degree 770 285 485 118,030 44,790 73,240

Total population aged 25 to 3457 17,550 8,615 8,930 1,529,590 737,610 791,980

No certificate, diploma or degree 1,935 1,035 895 132,715 73,165 59,550

High school certificate or equivalent58 5,280 3,000 2,285 364,260 200,340 163,920

Apprenticeship or trades certificate or diploma 1,320 890 435 91,525 56,430 35,095


5,710 2,360 3,350

372,355 165,310 207,050


510 215 295

68,800 31,275 37,525

University certificate, diploma or degree 2,790 1,120 1,675 499,935 211,090 288,845

Total population aged 35 to 6460 59,770 29,160 30,615 5,108,740 2,488,355 2,620,380

No certificate, diploma or degree 11,225 5,825 5,400 766,810 383,295 383,520

High school certificate or equivalent61 18,410 8,400 10,010 1,296,405 580,705 715,710

Apprenticeship or trades certificate or diploma 6,955 4,650 2,310 489,605 320,260 169,345


14,935 6,330 8,605

1,089,270 470,180 619,090


1,690 735 955

241,150 108,080 133,065

University certificate, diploma or degree 6,550 3,220 3,335 1,225,490 625,845 599,650

Major field of study

Oshawa, City

Ontario



No postsecondary certificate, diploma or degree 65,115 31,295 33,820 4,812,200 2,279,390 2,532,810

Education 3,285 860 2,425 335,715 81,810 253,900

Visual and performing arts, and communications

technologies 2,010 1,220 790

193,790 90,735 103,060

Humanities 2,130 915 1,215 292,845 110,970 181,875

Social and behavioural sciences and law 5,045 1,335 3,710 576,100 202,080 374,020

Business, management and public administration 10,325 3,520 6,805 1,061,210 417,010 644,200













26

Major field of study

Oshawa, City

Ontario


Physical and life sciences and technologies 1,065 555 510 181,250 94,220 87,030

Mathematics, computer and information sciences 2,105 1,315 785 254,440 151,930 102,505

Architecture, engineering, and related technologies

11,820 11,165 660

1,089,310 995,690 93,620

Agriculture, natural resources and conservation 675 400 275 91,965 62,180 29,780

Health, parks, recreation and fitness 7,415 980 6,435 665,490 124,885 540,605

Personal, protective and transportation services 3,790 2,005 1,785 264,620 133,610 131,015

Other64 0 0 0 480 190 285

Figure

Location of study

Oshawa, City

Ontario



No postsecondary certificate, diploma or degree 65,110 31,290 33,820 4,812,200 2,279,390 2,532,805

Postsecondary certificate, diploma or degree 49,675 24,265 25,405 5,007,220 2,465,315 2,541,905

Inside Canada 44,060 21,130 22,935 3,928,555 1,906,245 2,022,310

Outside Canada 5,610 3,140 2,470 1,078,670 559,075 519,590

Figure

Labour force activity

Oshawa, City

Ontario



In the labour force67 76,350 40,120 36,225 6,587,580 3,437,670 3,149,905

Employed68 70,525 37,120 33,405 6,164,245 3,230,050 2,934,195

Unemployed69 5,820 3,000 2,820 423,335 207,620 215,710

Not in the labour force70 38,435 15,440 23,000 3,231,840 1,307,035 1,924,805

Participation rate71 66.5 72.2 61.2 67.1 72.5 62.1

Employment rate72 61.4 66.8 56.4 62.8 68.1 57.8

Unemployment rate73 7.6 7.5 7.8 6.4 6.0 6.8

Figure Occupation

Oshawa, City

Ontario


Total experienced labour force 15 years and over74 75,000 39,500 35,500 6,473,735 3,385,885 3,087,850

A Management occupations75 6,065 3,605 2,460 666,485 418,355 248,125

B Business, finance and administration occupations 13,370 3,840 9,530 1,204,490 360,225 844,260

C Natural and applied sciences and related occupations

3,415 2,540 875

451,930 349,305 102,630

D Health occupations 3,555 415 3,145 340,690 66,950 273,740

E Occupations in social science, education, government service and religion

5,590 1,640 3,950

546,385 174,765 371,620

F Occupations in art, culture, recreation and sport 1,940 895 1,050 200,980 90,590 110,390



















27

Figure

Occupation

Oshawa, City

Ontario


G Sales and service occupations 18,870 7,620 11,255 1,522,820 657,605 865,215

H Trades, transport and equipment operators and related occupations

13,520 12,510 1,010

911,250 845,595 65,655

I Occupations unique to primary industry 1,060 850 205 165,085 125,660 39,430

J Occupations unique to processing, manufacturing and utilities

7,605 5,590 2,015

463,610 296,825 166,785

Figure

Industry

Oshawa, City

Ontario


Total experienced labour force 15 years and over76 75,000 39,500 35,500 6,473,730 3,385,885 3,087,850

Agriculture and other resource-based industries 1,765 1,285 480 190,000 137,345 52,660

Construction 5,100 4,455 645 384,775 338,850 45,930

Manufacturing 12,770 9,820 2,945 899,670 628,460 271,210

Wholesale trade 3,175 2,245 930 307,465 199,755 107,710

Retail trade 9,200 4,075 5,130 720,235 322,715 397,515

Finance and real estate 3,855 1,585 2,265 442,610 193,375 249,230

Health care and social services 7,175 890 6,285 611,740 104,935 506,805

Educational services 4,960 1,555 3,405 433,485 141,630 291,855

Business services 13,620 7,745 5,875 1,274,345 755,215 519,130

Other services 13,380 5,840 7,545 1,209,390 563,600 645,790

Figure

Unpaid work

Oshawa, City

Ontario


Population 15 years and over reporting hours of unpaid work77

105,725 50,300 55,425 8,991,010 4,259,925 4,731,085

Population 15 years and over reporting hours of unpaid housework78

104,535 49,570 54,965 8,869,060 4,186,725 4,682,335

Population 15 years and over reporting hours looking after children without pay79

44,235 19,115 25,125 3,736,900 1,649,835 2,087,065

Population 15 years and over reporting hours of unpaid care or assistance to seniors80

20,400 8,445 11,950 1,838,830 773,420 1,065,410

Figure Language used most often at work

Oshawa, City

Ontario


Total population 15 years and over who worked since 200581

81,430 42,415 39,015

7,054,270 3,652,835 3,401,430

English 80,535 42,035 38,495 6,754,045 3,511,580 3,242,460

French 310 90 220 97,965 40,635 57,330

Non-official language 205 100 100 112,125 57,295 54,830
















28

Figure

Language used most often at work

Oshawa, City

Ontario


English and non-official language 155 110 50 45,400 23,405 22,000

French and non-official language 0 0 0 230 100 130

English, French and non-official language 0 0 0 1,560 780 775

Figure

Place of work status

Oshawa, City

Ontario


Total employed labour force 15 years and over82 70,530 37,120 33,405 6,164,245 3,230,055 2,934,195

Worked at home 3,305 1,460 1,850 436,380 220,340 216,040

Worked outside Canada 160 100 60 36,905 24,210 12,695

No fixed workplace address 7,285 5,550 1,735 596,305 445,625 150,680

Worked at usual place 59,775 30,015 29,760 5,094,650 2,539,870 2,554,780

Worked in census subdivision (municipality) of residence

27,310 12,470 14,835 3,056,365 1,421,005 1,635,365

Worked in a different census subdivision (municipality) within the census division (county) of residence

18,630 9,440 9,190

795,195 404,425 390,765

Worked in a different census division (county) 13,720 8,030 5,690 1,211,410 696,880 514,525

Worked in a different province 115 70 45 31,680 17,555 14,120

Figure

Mode of transportation to work

Oshawa, City

Ontario


Total employed labour force 15 years and over with a usual place of work or no fixed workplace address83

67,055 35,565 31,495 5,690,960 2,985,495 2,705,465

Car, truck, van, as driver 51,280 28,780 22,505 4,038,035 2,274,810 1,763,230

Car, truck, van, as passenger 6,170 2,690 3,480 470,410 191,695 278,715

Public transit 5,590 2,305 3,285 736,060 299,920 436,140

Walked or bicycled 3,400 1,490 1,915 389,105 190,340 198,765

All other modes 605 290 315 57,350 28,740 28,610

Figure

Visible minority population characteristics

Oshawa, City

Ontario



Total visible minority population85 11,370 5,905 5,465 2,745,200 1,332,995 1,412,205

Chinese 1,330 635 695 576,975 277,500 299,475

South Asian86 1,905 990 915 794,170 401,900 392,270

Black 4,260 2,240 2,025 473,765 223,220 250,540

Filipino 755 370 380 203,215 87,025 116,190

Latin American 710 380 330 147,140 71,370 75,765














29

Figure

Visible minority population characteristics

Oshawa, City

Ontario


Southeast Asian87 280 175 105 110,045 53,135 56,910

Arab 255 165 90 111,405 58,625 52,785

West Asian88 505 285 220 96,620 49,275 47,340

Korean 215 90 120 69,540 33,720 35,820

Japanese 205 120 75 28,080 12,775 15,300

Visible minority, n.i.e.89 425 195 230 56,845 26,680 30,160

Multiple visible minority90 520 255 270 77,400 37,755 39,645

Not a visible minority91 128,870 62,605 66,265 9,283,695 4,544,875 4,738,815

Figure Earnings in 2005

Oshawa, City

Ontario


Persons 15 years and over with earnings (counts)92 82,630 43,565 39,070 6,991,670 3,621,760 3,369,910

Median earnings - Persons 15 years and over ($)93 30,393 39,253 23,488 29,335 35,702 23,755

Persons 15 years and over with earnings who worked full year, full time (counts)94

44,395 25,590 18,805

3,690,665 2,116,730 1,573,940

Median earnings - Persons 15 years and over who worked full year, full time ($)93

45,373 52,169 37,977

44,748 50,057 38,914

Figure

Income in 2005

Oshawa, City

Ontario


Persons 15 years and over with income (counts)95 108,735 52,925 55,805 9,340,020 4,540,895 4,799,125

Median income - Persons 15 years and over ($)96

29,788 38,768 22,269

27,258 34,454 21,669

Median income after tax - Persons 15 years and over ($)96

26,290 33,216 20,554

24,604 30,182 20,201

Composition of total income (100%)97 100 100 100 100 100 100

Earnings - As a % of total income 76.8 80.9 70.7 77.4 80.7 72.4

Government transfers - As a % of total income 11.1 7.5 16.6 9.8 6.9 14.0

Other money - As a % of total income 12.0 11.5 12.8 12.9 12.4 13.5

Income status of all persons in private households (counts)98

139,670 68,145 71,530

11,926,140 5,825,145 6,100,995

% in low income before tax - All persons 12.9 11.4 14.4 14.7 13.7 15.6

% in low income after tax - All persons 9.5 8.6 10.3 11.1 10.5 11.6

% in low income before tax - Persons less than 18 years of age

18.2 18.6 17.7

18.0 17.9 18.1

% in low income after tax - Persons less than 18 years of age

13.5 13.8 13.2

13.7 13.7 13.8





















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