INDUSTRIAL LAW - application for declaratory relief - construction of the Metro Trains Melbourne Pty Ltd Rail Operations Enterprise Agreement 2015-2019 - whether cl 3 of Sch 1 to the agreement requires the respondent to provide the same training to "conversion drivers" as novice drivers - whether such training is to be limited to certain regional operating groups within the Melbourne metropolitan rail network admissibility of pre-agreement negotiations whether respondent proposes to contravene s 50 of the Fair Work Act 2009 (Cth) by reason of breach of cl 3 of Sch 1 to the agreement
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