In R v. Ellis, 2017 ONSC 3812, the court was sentencing the offender under the old provisions, ss. 212(1)(a), 212(1)(d), and 212(1)(h). These involved procuring and exercising control, direction, or influence. For a period of five months, the 22-year old victim worked as a sex worker. The offender was initially engaged in an intimate relationship with the victim. She worked in clubs and hotels and the offender took all the money received for her work. The offender was sentenced to 20 months’ imprisonment. The complainant was not under the age of 18. There were no ongoing threats or violence, though there was one incident of arm grabbing.
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