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3described by the Complainant’s counsel as “a thick bundle of names listed by what appears to bepersonnel number order.” Although this list did identify Conductors and their dependants,counsel for the Complainant added that there was “nothing about the 69 percent figure”. Shetherefore concluded that “someone must have then taken that document and done somecalculations.” She then asked that the documents where these calculations were done beproduced.[11] Mr. Paquette, counsel for CN, explained that the calculation had been done by “someone”at CN’s legal department. He then added that he had “very likely” communicated these numbersto the witness. Asked by the Chair if, when Ms. Ziemer had indicated that the numbers had beencommunicated to her by someone in Montreal, she meant the legal department, counsel answered“very likely”, but he added that the information itself comes from CN's human resourcesdepartment. He added that it was simply a question of “sitting down and doing the adding one byone.”2010 CHRT 24 (CanLII)[12] On cross-examination, Ms. Ziemer indicated that she had not done the calculation herself.She added that the figure of 69% for both group was given to her during a conference call, but shecould not remember who the person who gave her the information was. Regarding the “thickbundle of names”, Ms. Ziemer indicated that she was seeing this document for the first time at thehearing. Considering the evidence of Ms. Ziemer, the Tribunal will not give much weight to thispart of her testimony.[13] For operation purposes, CN is divided in two main regions, the Eastern region and theWestern region. The Western Region includes all of CN’s rail terminals from Vancouver, BritishColumbia, to Thunder Bay, Ontario.[14] The Crew Management Centre (“CMC”) in Edmonton is a very important part of CNoperations. It is responsible for all crew callings and deployment for the Western region. Itmanages the workforce deployment for “running trade” employees and a payroll of 204 milliondollars. The CMC has fifty-four (54) employees who report to Elaine Storms, the Director of