Re: Grievance filed by Richard Mann against the David R. Cheriton School of Computer Science Richard Mann Dear Provost Rush, Regarding your letter of Oct 21, 2022. 1. You state that my grievance of June 27 2022 is "without merit".  You say this despite asking numerous questions, including my documentation of all previous dealings my Department and with Occupational Health. I do not accept your decision and insist that my grievance be sent to Arbitration. 2.  Re Nov 18 deadline, with threat of removal of pay.  I have mentioned numerous times that the deadlines you impose are unreasonable as you do not know the full complexity of my situation.  I have been communicating with Occupational Health, in particular on the topic of "toxic workplace".  I have been in regular contact with Karen Parkinson until Oct 12.  I sent her Email today and got an auto reply.  Subsequently I was told Karen Parkinson will not return until Oct 31 and no one has been assigned to cover for her.  This will obviously add additional delay. 3. Re: additional medical.  Next week I will be providing further medical (from my psychologist) on the issue of "toxic workplace". Sincerely,   Richard Mann   Waterloo ON ________________________________________ From: Provost Office-General Sent: Friday, October 21, 2022 9:40 AM To: Richard Mann; Provost Office-General Cc: Kim Gingerich Subject: RE: Grievance filed by Richard Mann against the David R. Cheriton School of Computer Science Dear Professor Mann, Please find attached a letter from the Provost regarding your grievance. Best regards, Kim Kim Gingerich Executive Officer, Academic Office of the Vice-President Academic & Provost -----Original Message----- From: Richard Mann Sent: Monday, October 17, 2022 12:29 PM To: Provost Office-General Cc: Kim Gingerich Subject: Re: Grievance filed by Richard Mann against the David R. Cheriton School of Computer Science                                                                                           Oct 17 2022 Dear Provost Rush, I am not removing the grievance. I last spoke with the Karen Parkinson  on Wed Oct 12 last week and she has not got back to me yet. The letter also has to go to the Dean by then. Also just because I am negotiating with Occupational Health does not mean that I agreed to the contents or your letter or that the closure of the grievance upon completion of negotiation. Sincerely,   Richard Mann ________________________________________ From: Provost Office-General Sent: Monday, October 17, 2022 11:26 AM To: Richard Mann Cc: Kim Gingerich; Provost Office-General Subject: RE: Grievance filed by Richard Mann against the David R. Cheriton School of Computer Science Dear Professor Mann, I wrote to you on September 19 to propose a resolution to your grievance (attached).  However, you did not respond. I have now been advised that you have provided additional medical documentation to Occupational Health and are engaging with Karen Parkinson. Accordingly, while you have not directly responded to my September 19 proposal, for the moment, you appear to be acting in accordance with it. It seems, therefore, that my September 19 proposal was agreeable to you and that you have accepted the terms outlined therein. Please confirm your agreement with my September 19 proposal by reply email by no later than October 21. If you do not respond by October 21,  I will assume you have irrevocably abandoned your grievance and will not be proceeding with it further. Sincerely, James W.E. Rush Vice-President, Academic & Provost -----Original Message----- From: Richard Mann Sent: Tuesday, September 13, 2022 9:14 PM To: Provost Office-General ; Kim Gingerich Subject: Re: Grievance filed by Richard Mann against the David R. Cheriton School of Computer Science      September 13, 2022 Dear Provost Rush, CC: Kim Gingerich To summarize my last two emails, 1. As noted in my September 8 2022 letter I will fill out the "Employee Accommodation Request Form", have my Doctor complete it and provide it to Occupational Health.  As you requested I will not be providing further medical information or updates to you on this process. 2. I will work toward teaching CS251 in Winter 2023, which has already been assigned to me by the School of Computer Science.  This includes filling in for two lectures (beginning of October). Sincerely,   Richard Mann ________________________________________ From: Richard Mann Sent: Tuesday, September 13, 2022 6:53 PM To: Provost Office-General; Kim Gingerich Subject: Re: Grievance filed by Richard Mann against the David R. Cheriton School of Computer Science                                September 13, 2022 Dear Provost Rush, CC: Kim Gingerich Just to clarify, as noted in my September 8 2022 letter I will have my Doctor fill out the "Employee Accommodation Request Form" and provide it to Occupational Health.  As you requested I will not be providing further medical information or updates to you on this process. Sincerely,   Richard Mann   Waterloo ON ________________________________________ From: Richard Mann Sent: Tuesday, September 13, 2022 3:41 PM To: Provost Office-General; Kim Gingerich Subject: Re: Grievance filed by Richard Mann against the David R. Cheriton School of Computer Science Dear Provost Rush I am surprised and disappointed that the timing of negotiations is such a sticking point, particularly given the disruption caused by my previous dealings with FAUW and Occupational Health, as can be supported by Email and medical records. During more than twenty years at Waterloo I have always put my students first.  I have already begun preparing for January teaching including attending lectures this term. I have also volunteered to cover two upcoming lectures for the lead instructor of the course. I see this as a reasonable integration back into teaching duties and I am perfectly willing to negotiate after Winter 2023 anticipating a solution that includes teaching in Fall 2023. Sincerely,   Richard Mann   Waterloo ON ________________________________________ From: Provost Office-General Sent: Tuesday, September 13, 2022 2:50 PM To: Richard Mann Cc: Kim Gingerich Subject: RE: Grievance filed by Richard Mann against the David R. Cheriton School of Computer Science Dear Professor Mann, I am writing in response to your September 8, 2022 email. I will attempt to be very clear and direct in my response below. In April, you were assigned sections of CS 251 for Fall 2022 and Winter 2023. You filed a grievance in June 2022 in direct response to these teaching assignments. In the grievance, you claimed the teaching assignments were inconsistent with your prior accommodation agreement from 2011.  You also requested to teach CS 498 in Winter 2023. I concluded that your Fall 2022 and Winter 2023 teaching assignments were consistent with your 2011 accommodation agreement. You suggested that subsequent to 2011 you had, on several occasions, begun discussions regarding the possibility of new accommodations. However, at this time, the only existing accommodation plan and/or agreement is the one from 2011. You refused to teach your Fall 2022 teaching assignments. Generally, refusing assigned duties would be treated as misconduct. I advised that you would not be required to teach in Fall 2022, only because of your representations that you required further accommodation and that you would work with Occupational Health to put these accommodations in place. I proposed that you not prepare to teach in Winter 2023, only due to your express statement that you were unable to do so while you engaged with Occupational Health. I accepted your statement in good faith. Faculty members do not dictate their teaching assignments to the University, as you appear to be doing below. At this time, you are not on an approved leave, nor are you performing the regular duties expected of a faculty member, nor have you provided medical documentation substantiating your inability to perform your regular duties during Fall 2022. Please consider the following options: 1. If you are now taking the position that you can engage with Occupational Health to develop an accommodation plan in Fall 2022, and simultaneously prepare to teach in Winter 2023, then I will revise my proposal accordingly. It is not clear to me if this is what you are suggesting in your September 9 email below. 2. If you refuse to engage with Occupational Health through the accommodation process during Fall 2022, your pay will cease for the remainder of Fall 2022 and you may face further consequences. Your Fall 2022 teaching assignments were consistent with your 2011 agreement. Your pay will cease due to your failure to perform your assigned teaching duties in Fall 2022. You are not entitled to insist that you are medically unable to teach during Fall 2022 and then refuse to engage in the medical accommodation process. You can, of course, proceed through the grievance and arbitration process with your existing grievance. I request your response to this email by Friday, September 16, 2022 . Also, to follow up on Kim Gingerich's email, please do not send any medical forms to my office. Please direct such forms to Occupational Health. Best regards, James W.E. Rush Vice-President Academic & Provost -----Original Message----- From: Richard Mann Sent: Thursday, September 08, 2022 10:39 PM To: Provost Office-General Cc: Kim Gingerich Subject: Re: Grievance filed by Richard Mann against the David R. Cheriton School of Computer Science                                                                 Thursday September 8 2022 Dear Provost Rush, CC: Kim Gingerich I am writing in response to your letter of Sept 6, 2022.  (I have attached the text of the PDF letter below for reference.) I have been assigned one section of CS251 by my Chair, to be taught in January 2023, and I intend to reach this goal.  I have already begun preparation for this course, including attending the first lecture today, following along in the notes, and developing additional material to augment the existing curriculum.  My intention is to continue preparation at full speed so that I am ready to deliver the best course possible in January. Unfortunately, instead of allowing me time to prepare the course, you instead propose, item #5 below,     5. While the process contemplated by paragraphs 2, 3 and 4 above is underway, you will not be required to simultaneously prepare to teach any courses. In my opinion, this is clearly impossible as preparation for January is already underway and absolutely must continue.  I consider teaching in January the best path forward, to determine both teaching duties and medical accommodations required and hope that you will agree. I will be getting notes from my medical advisors.  As requested in Point #2 I will ask one of them to complete "Employee Accommodation - Medical Verification of Disability Form".  I will ask that forms and letters be sent directly to you and also copied to Karen Parkinson at Occupational Health. Sincerely,   Richard Mann   Waterloo ON Enclosed: (text) of letter from Sept 6 2022 Dear Professor Mann, Further to my email of September 1, where I confirmed you would not be teaching in Fall 2022, I am writing to provide a more comprehensive response to your August 31 email. I acknowledge your attempts to resolve this matter and your timely response to my August 29 letter. I have carefully considered your August 31 email. Although you have not provided medical documentation to support your assertion that you are unable to simultaneously engage with Occupational Health on a new accommodation plan and prepare to teach a course in Winter 2023, I am prepared to accept your assertion, on a good-faith basis, for the time being. I have respected this consideration in revising the terms of the proposal, below; note particularly term 5. However, it would be inappropriate to wait until Summer 2023 to put a new accommodation plan in place for you. I say this for several reasons. First, a new, documented plan is necessary to prevent further cycles of disagreement and confusion between you and the School/Faculty. Any additional delay in putting this plan in place, including waiting until Summer 2023, may result in further disagreement and confusion. Second, the normal procedure associated with employee accommodations is to determine what restrictions exist and what accommodations are necessary, prior to assigning new work duties. For the foregoing reasons, your new accommodation plan must be the first priority to attend to. Your accommodation plan must be developed and formalized before November 10, 2022. I want to again stress, however, that at this time, you are not on an approved leave, nor are you performing any assigned duties related to teaching, research, or service. Accordingly, while the University will gratuitously continue your pay during Fall 2022, this will be contingent on your meaningful, continued participation in the accommodation process. The following is my revised proposal to resolve your grievance: 1. You will not be required to teach CS 251 during Fall 2022. The School of Computer Science has reassigned your teaching duties to another instructor. For clarity, you will also not be assigned other teaching duties for the Fall 2022. 2. You will complete the Employee Accommodation Request Form and have your doctor complete the Employee Accommodation - Medical Verification of Disability Form. If reasonably necessary, you will allow Occupational Health to consult with your doctor to fully understand your current medical restrictions. You will reach out to Karen Parkinson in Occupational Health by September 9, 2022 to begin this process. Ms. Parkinson will provide further direction to you regarding submission of the forms. Generally, you will be required to participate in the University's normal processes for developing accommodation plans, which will include appropriate University personnel reviewing your medical forms and/or documentation, and may include consultation with your medical professional(s). 3. You will continue to receive your regular salary during Fall 2022 (despite not being required to perform other duties before November 10, 2022), provided you continue to meaningfully cooperate with Occupational Health. 4. After Occupational Health has received the completed forms and, if necessary, consulted with your doctor to understand your medical restrictions, Occupational Health will relay your restrictions to Dean Giesbrecht (or a delegate of Dean Giesbrecht) who, as your supervisor, must participate in this process. Occupational Health and Dean Giesbrecht (or his delegate) will collaborate with you to develop a new accommodation plan. You are, of course, permitted to seek the assistance of FAUW in this process. 5. While the process contemplated by paragraphs 2, 3 and 4 above is underway, you will not be required to simultaneously prepare to teach any courses. Development of your new accommodation plan will include development of a transitional guidance component regarding your expected duties for the remainder of F22 (after the new accommodation plan is in place) and for W23. 6. After a new accommodation plan is developed, your future teaching duties will be assigned in a manner consistent with the new plan. 7. The new accommodation plan must be in place by November 10, 2022 at the latest. You will need to provide medical to Occupational Health in a sufficiently expeditious manner to meet this November 10 deadline. The Faculty of Mathematics is also aware of its need to participate in the accommodation plan development in an expeditious manner. 8. If you refuse to engage with Occupational Health and/or provide the necessary medical documentation, or if you refuse to participate in the process of developing a new, formal accommodation plan, the University will consider you as being on an unsupported leave of absence and will act accordingly. Upon reviewing this letter and my proposal herein, and should you find the above to be an acceptable remedy, I would ask that you kindly sign and indicate your agreement to withdraw your grievance. Please send it back at your earliest convenience to Kim Gingerich in my Office, who will then facilitate next steps. I trust you find this resolution to your satisfaction and remain available should you have any questions. ________________________________________ From: Provost Office-General Sent: Tuesday, September 6, 2022 4:38 PM To: Richard Mann Cc: Kim Gingerich Subject: RE: Grievance filed by Richard Mann against the David R. Cheriton School of Computer Science Dear Professor Mann, Please find attached a letter from the Provost in response to your email dated August 31, 2022. Best regards, Kim Kim Gingerich Executive Officer, Academic Office of the Vice-President Academic & Provost Kim Gingerich Executive Officer, Academic Office of the Vice-President Academic & Provost -----Original Message----- From: Richard Mann Sent: Wednesday, August 31, 2022 9:36 PM To: Provost Office-General Cc: Kim Gingerich Subject: Re: Grievance filed by Richard Mann against the David R. Cheriton School of Computer Science                                                        Aug 31, 2022 Dear Provost Rush, CC: Thank you very much for your letter of August 29.  I sincerely appreciate the time and effort that you have been making to resolve this matter. Unfortunately, as I mentioned in my August 23 letter, I cannot simultaneously work on my medical accommodations (i.e., be engaged with Occupational Health, UW) while preparing to teach my course.   Under normal circumstances this may be possible, but as my previous Doctor's note indicates, I find myself under increased stress, due to a toxic work environment that prevents me from taking this path.  My clinical psychologist is also willing to attest to the need to separate these two tasks. A reasonable path forward would be to delay the medical accommodations/ negotiation until after I complete my teaching duties for the current academic year.  In this case I would be willing to teach one section of CS251 in W23 and negotiate during the following (S23) term.  The understanding here is that I would not be assigned additional courses in S23.  Instead, that time would be reserved for negotiation. Regardless of the negotiation, I have begun and intend to continue this fall, preparing to teach CS251.  These preparations include: - review of text and course notes, - review of previous instructors' notes and other resources, - observing select lectures and/or online forums, - consulting with instructors, staff and students I have proposed the above in a sincere effort to address the needs of both the university as well as myself.  I hope that you will find my proposal agreeable and look forward to hearing from you. Sincerely,   Richard Mann ________________________________________ From: Provost Office-General Sent: Monday, August 29, 2022 1:32 PM To: Richard Mann; Provost Office-General Cc: Kim Gingerich Subject: RE: Grievance filed by Richard Mann against the David R. Cheriton School of Computer Science Dear Professor Mann, Please find attached a letter from the Provost in response to your email dated August 23, 2022. Best regards, Kim Kim Gingerich Executive Officer, Academic Office of the Vice-President Academic & Provost -----Original Message----- From: Richard Mann Sent: Tuesday, August 23, 2022 11:43 AM To: Provost Office-General Cc: Kim Gingerich Subject: Re: Grievance filed by Richard Mann against the David R. Cheriton School of Computer Science                                                                          Aug 22, 2022 Re: Grievance filed by Richard Mann against the David R. Cheriton School of Computer Science Dear Provost Rush, CC: Kim Gingerich I am writing in reply to your document of Aug 19 2022 (full text of PDF document included below, for the record) in which you presented a proposal to resolve my grievance. First of all, I thank you for the removal of the Fall 2022 teaching, which was clearly unfeasible because of lack of preparation time. Unfortunately dealing with this grievance has caused a great deal of stress and anxiety and has depleted me of much energy.  Based on many past experiences with FAUW and Occupational Health I do not believe I can deal with Occupational Health (during the Fall 2022 term) while having to prepare for teaching CS251 in the Winter 2023. As a solution I would be much more inclined to accept a proposal that allows me to teach CS 498 in the Winter 2023 term.  I would be more comfortable teaching this course because I developed it and taught it several times before the pandemic.  It is also a course that has received most positive reviews from students. Finally, this would allow time to reach a "medical solution" with Occupational Health. At this point I would like to ask that stress, time pressure and arbitrary documents and deadlines be avoided.  As you know from my Email of Aug 5 2022, I told you my entire history with the University since 2016. I have made numerous good faith attempts to negotiate.  Further I have already expressed my problems with unnecessary stress with several members of FAUW (Sally Gunz, Lori Curtis) and with Occupational Health (Linda Brogden, Karen Parkinson).  I have provided medical documentation of the stress, I cannot understand why additional procedures are necessary. I am hoping this can be resolved in a way that is fair and honest with both the University and myself.  A way that we can move forward productively rather than a state of uncertainty and stress. Question #1 You write: "In considering all of the available information, it seems clear, and in fact you have specifically acknowledged that, apart from the 2011 accommodation agreement (which I have concluded is consistent with your Fall 2022 teaching assignment), no further formal, documented accommodation plans exist. " You also write: "A new, documented plan is necessary to prevent further cycles of disagreement and confusion between you and the School/Faculty". For the record, I ask that you to acknowledge my good faith attempts to negotiate with FAUW and our interaction with Occupational Health and my submission of a Doctor's note to Occupational Health in 2018. Question #2 You write:  "For clarity, however, the role of your medical professional(s)   in aiding the development of an accommodation plan is to provide the University (through its Occupational Health Department) with medical documentation outlining your medical restrictions." Can you please direct me to specific policy that says how accommodations are to be arranged? In particular, is a University medical professional required to sign a document?  If so, who does this? I look forward to receiving your reply to my questions. Sincerely,   Richard Mann Attached, text of PDF letter from Provost Aug 19 2022 ------------------------------------------------------- OFFICE OF THE VICE-PRESIDENT ACADEMIC & PROVOSTprovost@uwaterloo.ca   I uwaterloo.ca/provost August 19, 2022PERSONAL AND CONFIDENTIAL Richard MannProfessorSchool of Computer Science University of Waterloo Dear Professor Mann, On 27 June 2022, you submitted to me a formal grievance under Article 9.2.1 of the Memorandum of Agreement (the “MOA”) between the University of Waterloo (the “University”) and the Faculty Association of the University of Waterloo (“FAUW”). You subsequently confirmed that, instead of meeting to discuss your grievance, as contemplated by Article 9.5.1 of the MOA, you would instead prefer to correspond via email. I agreed with this approach. I have reviewed and considered your grievance, the answers you provided to my written questions, as well as the other documents you submitted. I have also received information and answers to questions from the School of Computer Science and Faculty of Mathematics, and have discussed this matter with Dean Giesbrecht, and have made inquiries with Occupational Health regarding process.  In considering all of the available information, it seems clear, and in fact you have specifically acknowledged that, apart from the 2011 accommodation agreement (which I have concluded is consistent with your Fall 2022 teaching assignment), no further formal, documented accommodation plans exist.  Assuming your medical condition requires further accommodations beyond those described in the 2011 agreement, then a new accommodation plan will need to be put in place.  A new, documented plan is necessary to prevent further cycles of disagreement and confusion between you and the School/Faculty.  For clarity, however, the role of your medical professional(s)   in aiding the development of an accommodation plan is to provide the University (through its Occupational Health Department) with medical documentation outlining your medical restrictions. The University  (more specifically, your Faculty and Department) would maintain overall discretion to determine and assign your teaching duties. It is not the role of your medical professional(s) to dictate specific teaching assignments. Occupational Health will assess whether it has received suitable medical documentation to understand your restrictions and will thereafterwork with your Faculty and/or Department to ensure your accommodation plan, including teaching assignments and any other necessary accommodations, are consistent with such restrictions.  In light of the foregoing, I am pleased to confirm the following resolution to your grievance, which I trust you will find satisfactory: 1.   You will not be required to teach CS 251 during Fall 2022. The School of Computer Science will be required to reassign these teaching duties to another instructor.  For clarity, you will also not be assigned other teaching duties for the Fall 2022. 2.   You will provide suitable medical documentation to allow Occupational Health to fully understand your current medical restrictions. You will reach out to Karen Parkinson in Occupational Health by August 24, 2022 to begin this process. Ms. Parkinson will provide further direction to you regarding submission of   suitable medical documentation. You will be required to participate in the University’s normal processes for developing accommodation plans, which will include appropriate University personnel re viewing your medical documentation and/or consulting with your medical professional(s). 3.   You will continue to receive your regular salary during Fall 2022 (despite not being required to teach the courses previously assigned), providing you continue to meaningfully cooperate with Occupational Health. 4.   After Occupational Health has received sufficient documentation to understand your medical restrictions, Occupational Health will relay these restrictions to Dean Giesbrecht (or a delegate of Dean Giesbrecht in your Department) who, as your supervisor, must participate in this process. Occupational Health and Dean Giesbrecht (or his delegate) will collaborate with you to develop a new accommodation plan. You are, of course, permitted to seek the assistance of FAUW in this process. 5.   After a new accommodation plan is developed, your future teaching assignments, including assignments for Winter 2023, will be assigned in a manner consistent with the new plan. This new plan must be in place by October 24, 2022 at the latest, to allow sufficient time to prepare for Winter 2023. You will need to provide medical to Occupational Health in a sufficiently expeditious manner to meet this October 24 deadline. The Faculty of Mathematics is also aware of its need to participate in the accommodation plan development in an expeditious manner. In the meantime, you will prepare to teach the course(s) you are currently assigned for Winter 2023, provided you are medically fit to begin such preparations at this time. Further modifications to your Winter 2023 assignment may be made, if necessary, after the new plan is formalized. 6.   If you refuse to engage with Occupational Health and/or provide the necessary medical documentation, or if you refuse to participate in the process of developing a new, formal accommodation plan, the University will consider you to have failed to meet your accommodated work expectations as articulated in the 2011 agreement, which is the only formal accommodation agreement in place between you and the University, and will act accordingly. Upon reviewing this letter and my proposal herein, and should you find the above to be an acceptable remedy,   I would ask that you kindly sign and indicate your agreement to withdraw your grievance. Please send it back at your earliest convenience to Kim Gingerich in my Office, who will then facilitate next steps. I trust you find this resolution to your satisfaction and remain available should you have any questions. Sincerely,James W.E. RushVice-President Academic & ProvostUniversity of Waterloo I have read this letter and agree to    formally withdraw my grievance submitted June 27, 2022:Professor Richard MannWitnessPRINT NAME:Dated atthisday of,2022. ________________________________________ From: Provost Office-General Sent: Friday, August 19, 2022 2:32 PM To: Richard Mann Cc: Kim Gingerich Subject: FW: Grievance filed by Richard Mann against the David R. Cheriton School of Computer Science Dear Professor Mann, Please find attached a letter from Provost Rush related to your grievance. Best regards, Kim Kim Gingerich Executive Officer, Academic Office of the Vice-President Academic & Provost -----Original Message----- From: Provost Office-General Sent: Tuesday, August 16, 2022 4:00 PM To: Richard Mann Cc: Lori Curtis ; Katie Damphouse ; Roydon Fraser ; Jasmin Habib ; Jean-Paul Lam ; Raouf Boutaba ; CS Director ; Karen Parkinson Subject: RE: Grievance filed by Richard Mann against the David R. Cheriton School of Computer Science Dear Professor Mann, Thank you for your email. The Provost is on vacation this week, but is working on your file and will respond by the end of the week regarding resolving your grievance. Best regards, Kim Kim Gingerich Executive Officer, Academic Office of the Vice-President, Academic & Provost -----Original Message----- From: Richard Mann Sent: Tuesday, August 16, 2022 10:24 AM To: Vice Pres Academic Provost Cc: Lori Curtis ; Katie Damphouse ; Roydon Fraser ; Jasmin Habib ; Jean-Paul Lam ; Raouf Boutaba ; CS Director ; Karen Parkinson Subject: Re: Grievance filed by Richard Mann against the David R. Cheriton School of Computer Science                                                                                         Aug 16, 2022 Dear Provost Rush, CC: I am following up about my teaching assignments for Fall 2022. I filed a grievance on June 27, you gave me written questions on July 27, and I answered those questions on Aug 5. When may I expect to hear back about the grievance, in particular, the assignment of courses in the Fall. In the meantime, the School of Computer Science has went ahead and assigned those classes to me.  I found out when a student mailed me on Aug 5 2022.  On that day I sent mail to the Chair informing him that the teaching assignment is still being decided.  (See attached.) Needless to say this is confusing and stressful for all involved, including the students who were assigned to my class. Please help me in resolving this matter ASAP. Sincerely,   Richard Mann