APPEAL by the defendant from the judgment of K.B. Phillips J.,
 O.J. No. 1308, 2016 ONSC 1795, 29 C.C.E.L. (4th) 192
(S.C.J.) for the plaintiff in a wrongful dismissal action.
J.F. Lalonde, for appellant.
Miriam Vale Peters, for respondent.
 GILLESE J.A. (PEPALL J.A. concurring): — A long-serving
McDonald’s restaurant manager was dismissed from her position without notice or payment of her statutory entitlements
under the Employment Standards Act, 2000, S.O. 2000, c. 41
 She successfully sued for wrongful dismissal. She was
awarded damages representing 20 months’ compensation in lieu
of notice, inclusive of statutory severance under the Act.
 This appeal raises, among other things, several important
questions about what income the employee received during the
notice period must be deducted from the damages award.
 Esther Brake (“Ms. Brake” or the “respondent”) worked
at various McDonald’s restaurants for a total of more than
25 years. For a significant part of that time, she was employed
on a full-time basis by PJ-M2R Restaurant Inc. (“PJ-M2R” or the
 PJ-M2R is a McDonald’s franchise holding company that
owns several McDonald’s restaurants in the Ottawa area. Perry
McKenna and Jo-Ann McKenna own and operate PJ-M2R.
 On August 2, 2012, Ms. Brake was working for PJ-M2R as
a restaurant manager, a position that she had held for a number
of years. Mr. McKenna told Ms. Brake that she had to accept a
demotion to first assistant or she would be fired. Ms. Brake refused to take the new position, as she felt that the position
would be embarrassing and humiliating for her. Her employment was then terminated. At that time, Ms. Brake was
62 years of age. She is now 66.
 Ms. Brake sued PJ-M2R for wrongful dismissal. PJ-M2R
defended on the basis that she had failed to meet the requisite
standards and, therefore, it had just cause to dismiss her.
 The trial judge found that as of August 2, 2012, Ms. Brake
had the equivalent of 20 years of employment with PJ-M2R. He
further found that she had been wrongfully dismissed and that
an appropriate notice period was 20 months, inclusive of statutory severance as required by the Act.