Analysis: Extended Liability in the Magnitsky Act
By: Joseph Rikhof
The Magnitsky Act contains some unusual concepts in respect to extended liability, which cannot be interpreted by referring to Canadian criminal law. This article will attempt to address this lacuna by looking at a wide range of domestic and international instruments to suggest a reasonable interpretation of the words used in this piece of legislation to connote involvement in prohibited activities.
When the Magnitsky Act1The official name is “Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law)”, which can be found here: http://laws.justice.gc.ca/eng/acts/J-2.3/; the regulations, to which the Act refers can be found here: ...continue was first discussed in this journal,3See CCIJ “The Magnitsky Act: A Bold Step Forward, but Changes Needed” (2017) 1 PKI Global Just J 12. the Commentary ended with the following exhortation: “In short, the notion of the word “responsibility” in the Act is vulnerable because of its lack of judicial interpretation …While we recognize that the Act is not criminal legislation, nonetheless, its extraterritorial application and engagement of fundamental international human rights law point to the need for legislative coherence.”
The text in the Act.
Section 4 of the Magnitsky Act says the following:
Orders and Regulations
(1) The Governor in Council may, if the Governor in Council is of the opinion that any of the circumstances described in subsection (2) has occurred,
(i) make any orders or regulations with respect to the restriction or prohibition of any of the activities referred to in subsection (3) in relation to a foreign national that the Governor in Council considers necessary; and
(ii) by order, cause to be seized, frozen or sequestrated in the manner set out in the order any of the foreign national’s property situated in Canada.
(2) The circumstances referred to in subsection (1) are the following:
(a) a foreign national is responsible for, or complicit in, extrajudicial killings, torture or other gross violations of internationally recognized human rights committed against individuals in any foreign state who see
(i) to expose illegal activity carried out by foreign public officials, or
(ii) to obtain, exercise, defend or promote internationally recognized human rights and freedoms, such as freedom of conscience, religion, thought, belief, opinion, expression, peaceful assembly and association, and the right to a fair trial and democratic elections;
(b) a foreign national acts as an agent of or on behalf of a foreign state in a matter relating to an activity described in paragraph (a);
(c) a foreign national, who is a foreign public official or an associate of such an official, is responsible for or complicit in ordering, controlling or otherwise directing acts of corruption — including bribery, the misappropriation of private or public assets for personal gain, the transfer of the proceeds of corruption to foreign states or any act of corruption related to expropriation, government contracts or the extraction of natural resources — which amount to acts of significant corruption when taking into consideration, among other things, their impact, the amounts involved, the foreign national’s influence or position of authority or the complicity of the government of the foreign state in question in the acts; or
(d) a foreign national has materially assisted, sponsored, or provided financial, material or technological support for, or goods or services in support of, an activity described in paragraph (c).
The words in bold are the operative ones in delineating the liability for persons who are targeted by the act, namely “responsible for”, “complicit in” or “materially assisted, sponsored or provided … support”. These terms will be discussed in turn, beginning with the notion of “complicit”. Apart from the terms sponsoring or providing support, the other notions are rarely used in the Canadian criminal or quasi-criminal context and require legal clarification, which will be useful both for persons implementing the provisions the Act as well those who will be made subject to them.
I. “Complicit” – Canada
The term “complicit” is only found in Canadian legislation 30 times, two of which are in the Act itself and in the Special Economic Measures Act (SEMA), which uses this term when referring to the Magnitsky Act. The other 28 times, the word “complicit” is used not to denote a form of extended criminal liability but only civil consequences in the context of seizure provisions, often with following text: “whether the member referred to in paragraph (a) appears innocent of any complicity in the offence or of any collusion in relation to the offence”.2See for instance section 139.1(6)(b) of the Customs Act, section 281(b) of the Excise Act and section 119(2)(b) of the Canada Marine Act.
The most common terms used in Canadian criminal statues, notably the Criminal Code, to define extended liability are aiding4Section 21(1)(b). (including accessory after the fact), abetting,5Section 21(1)(c). common intention,6Section 21(2). counselling,7Section 22(1); there is also counseling as an inchoate offence, which can be found in section 464. conspiracy,8Section 465. and attempt.9Section 463. Some extension or clarification of especially the concept of aiding and abetting can be found in sections 83.18-83.23 of the Criminal Code dealing with anti-terrorism, which sets out the forms of extended liability of participating in or contributing to,10Section 83.18(1), which clarifies these two terms by saying that providing, receiving, recruiting, offering, entering or remaining in any country for the benefit of a terrorist group and making oneself available to facilitate or commit a terrorism offence. facilitating,11Section 83.19. leaving Canada to commit an offence related to terrorism,12Sections 83.181 and 83.201-83.202. instructing to carry out a terrorist activity,13Sections 82.21-83.22. or advocating or promoting the commission of a terrorist offence14Section 83.221. and concealing or harbouring a person involved in terrorism.15Section 83.23. The concept of advocating or promoting can also be found in the Criminal Code in the context of genocide16Section 318(1). and as such used to interpret the same words in the Magnitsky Act.
The term “complicity” has been used in a generic sense for extended liability in one area of refugee law, namely exclusion, which is the device used to deny asylum seekers the status of refugee due to their involvement in serious criminality17See at the highest level, Ezokola v. Canada (Citizenship and Immigration), 2013 SCC 40 (Ezokola). although the legal term used is ‘committed’.18Section 98 of IRPA, which in turns refers to article 1F of he Refugee Convention. The test for this notion of complicity, based on the broadest notions of extended liability in international criminal law,19Ezokola, paragraphs 48-68. was set out by the Supreme Court of Canada as follows: “To exclude a claimant from the definition of ‘refugee” by virtue of art. 1F(a), there must be serious reasons for considering that the claimant has voluntarily made a significant and knowing contribution to the organization’s crime or criminal purpose.”20Ezokola, paragraph 84.
“Complicit” – International Law –Introduction
The term “complicity” has been used in the two areas of international law which regulate criminal conduct, namely transnational criminal law and international criminal law. The difference between these two areas is that international criminal law refers to conduct which is prohibited under international law itself and it is international law which provides for individual liability; the enforcement of this area of law manifests itself either directly, by international institutions applying international law, or indirectly, by states bringing perpetrators before national courts through the application of extended forms of jurisdiction, primarily universal jurisdiction (where a prosecution can be initiated when the crime is not committed in Canada but the perpetrator is present in Canada after having committed crimes abroad). On the other hand, transnational criminal law covers the indirect suppression by international law through the domestic criminalization of activities that have actual or potential transboundary effects; enforcement of transnational law is always indirect, namely prosecution by domestic courts as a result of the application of internationally negotiated, multilateral suppression treaties.21Robert Currie and Joseph Rikhof, “International & Transnational Criminal law, Second Edition”, Irwin Law, Toronto, 2013, pages 325-334.
“Complicit” – International Law – Transnational Criminal Law
These suppression treaties, which are part of transnational criminal law, have dealt with the issues of terrorism, organized crime, drug trafficking, human rights and cybercrime in almost 30 treaties.
All treaties have set out forms of extended liability to be penalized by countries which have ratified these treaties. Over time, the spectrum of participation has been extended to the extent that the most recent treaties have included ten different types of involvement.22See article 1 of the 2010 Convention on the Suppression of Unlawful Acts Relating to International Aviation (Beijing Convention) and article 5.1 of the 2010 United Nations Convention against Transnational Organized Crime. The types of involvement in the latter treaty are conspiracy, attempt, ...continue Out of this multitude of treaties only two have used the concept of complicity, namely the 1984 Torture Convention23Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment. and the 2000 Protocol to the Convention on the Rights of the Child24Optional Protocol to the Convention on the Rights of the Child on the Sale of Children, Child Prostitution and Child Pornography. and in both treaties this form of extended liability is only one of three types, the other two being attempt and participation.25Articles 4 and 3.2 respectively. It would appear that the use of complicity in the Magnitsky Act has been inspired by the Torture Convention but, apart from this general reference, the use of the word complicit is not helpful as it is not further defined in the treaty and since Canada has implemented the treaty with reference to the regular notions of extended liability in the Criminal Code.
“Complicit” – International Law – International Criminal Law
In international criminal law, the 1948 Genocide Convention has a reference to complicity, namely in article III(e).26Convention on the Prevention and Punishment of the Crime of Genocide. Because of the fact that the Statutes of the International Criminal Tribunals for the Former Yugoslavia (ICTY) and for Rwanda (ICTR) also had general provisions for indirect involvement, they were called upon to explain the parameters of complicity, especially in relation to aiding and abetting.
The answer given was that aiding and abetting is only one aspect of the larger notion of complicity and that for genocide the mens rea for complicity, which goes beyond aiding and abetting, could possibly be the narrower specific intent of genocide.27Judgment, Krstić (IT-98-33-A), Appeals Chamber 19 April 2004, paragraph 137–139; Judgment, Ntakirutimana (ICTR-96-10-A and ICTR-96-17-A), Appeals Chamber, 13 December 2004, paragraph 371; Judgment, Blagojević & Jokić (IT-02-60), Trial Chamber, 17 January 2005, paragraph679, 784; Judgment, ...continue It has also been said that complicity in genocide requires a positive act, while with aiding and abetting the same crime can be accomplished by failing to act or refraining from taking action.28Judgment, Akayesu (ICTR-96-4-T), Trial Chamber, 2 September 1998, paragraph547–548; Judgment, Musema (ICTR-96-13-T), Trial Chamber, 27 January 2000, paragraph 183. The question remained unresolved at the ICTY and ICTR29Judgment, Krstić (IT-98-33-A), Appeals Chamber 19 April 2004, paragraph 142, footnote 247; regarding the latter case, see also G. Boas, J.L. Bischoff and N.L. Reid, Forms of Responsibility in International Criminal Law (Cambridge: Cambridge University Press, 2007) at 422-423. but has been dealt with in the Statute of the International Criminal Court by separating the crime of genocide and the means of committing such a crime and by deleting the term complicity.
“Complicit” – International Law – the International Law Commission
The International Law Commission,30See for its mandate, background and work in international law http://legal.un.org/ilc/. the United Nations legal thinktank, has examined participation in international crimes on four occasions: in the 1950 “Principles of International Law Recognized in the Charter of the Nürmberg Tribunal and in the Judgment of the Tribunal”, the 1954 “Draft Code of Crimes against the Peace and Security of Mankind”, the 1996 updated version of the “Draft Code of Crimes against the Peace and Security of Mankind” and the ongoing Crimes against Humanity project, which started in 2015.
The second attempt to develop a draft code started in 1981 with a request from the General Assembly31United Nations General Assembly Resolution 36/106, 1981. and was completed in 1996. The 20 articles of this draft code have three provisions dealing with participation, with article 2 addressing individual responsibility in general, article 6 dealing with the responsibility of the superior and article 16, which puts a limitation on article 2 when a crime of aggression has been committed.32Yearbook of the International Law Commission, 1996, vol. II, part Two, pp. 18, 25 and 47. The commentaries with respect to those articles are much more detailed than in the two previous documents.33Idem, pp. 18-22, 25-26 and 42-43. In general, they make it clear that the provisions in the draft code are based on, or inspired by, earlier documents addressing punishable participation and mention specifically throughout this part of the document, the Charter of the International Military Tribunal in Nuremberg, the Genocide Convention, the Geneva Conventions and its Additional Protocols, and the Statutes of the ICTY and ICTR, as well at times, its own earlier work in this area.
However, of interest for the discussion of complicity, in an earlier draft of this document34The Report of the International Law Commission on the work of its Forty-second Session, 1990, pp. 12-14, paras. 40-56. there is detailed discussion of the parameters of this notion35Idem, page 14, paragraph 52. in the following draft article:
Participation in the commission of a crime against the peace and security of mankind constitutes the crime of complicity.
The following are acts of complicity:
(a) aiding, abetting or provision of means to the direct perpetrator, or making him a promise;
(b) inspiring the commission of a crime against the peace and security of mankind by, inter alia, incitement, urging, instigation, order, threat or abstention, when in a position to prevent it;
[(c) aiding the direct perpetrator, after the commission of a crime, to evade criminal prosecution, either by giving him refuge or by helping him to eliminate the evidence of the criminal act.].36Idem, page 14, paragraph 52, footnote 36.
II. “Responsible”
The word “responsible” is used quite a few times in Canadian legislation but not in terms of assigning criminal guilt: not in the Criminal Code nor in other quasi criminal statutes. It is often used to connote persons who are in charge of organizations, operations or practices by using terms such as “The Agency is responsible for the implementation of policies of the Government of Canada that relate to …”37See for instance Section 6 of the Parks Canada Agency Act or 3.1 of the Railway Safety Act.; it also used to indicate lack of criminal guilt in the sense of not being responsible.38See for instance sections 490.011 of the Criminal Code and 202.14 of the National Defence Act.
In international humanitarian and criminal law there is the concept of command or superior responsibility to create criminal accountability for omissions of persons in charge of military and civilian organizations where persons for whom they are responsible have committed international crimes.39This form of liability can also be found in one human rights treaty namely the International Convention for the Protection of All Persons from Enforced Disappearance.
The requirements to hold persons liable for this form of responsibility are threefold: a superior-subordinate relationship; the superior knew or had reason to know that a criminal act was about to be, was being or had been committed; and, failure to take necessary and reasonable measures to prevent or punish the conduct in question.40These requirements were fleshed out in the jurisprudence of the ICTY and ICTR while they are also reflected in article 28 of the Rome Statute, which is in turn followed in Canada in sections 5 and 7 of the Crimes against Humanity and War Crimes Act.
III. “Materially assisted”
With respect to this phrase, it has not been used very much at all in Canadian jurisprudence,41The Supreme Court in R. v. Khawaja, 2012 SCC 69, paragraphs 4, 42, 51-53, 57 and 62-63 uses the terms materially support, contribute materially or materially enhance when interpreting section 83.18 of the Criminal Code. but seems to have found its inspiration in US immigration law where the notion of material support can be found as part of the definition of engaging in a terrorist activity in the Immigration and Nationality Act.42Section 212(a)(3)(B)(iv).
The jurisprudence interpreting this provision has given it a broad meaning. Participation in military activities for the Liberation Tigers of Tamil Eelam (LTTE) amounts to material support,43Perinpanathan v INS, 310 F.3d 594 (8th Circuit, 2002). as does providing food and shelter to militant Sikhs organizations such as the Babbar Khalsa, International Sikh Youth Federation and Khalistan Commando Force, combined with membership in these organizations.44Singh-Kaur v. Ashcroft, 385 F.3d 293 (3d Circuit, 2004). It also includes soliciting funds for the Jammu Kashmir Liberation Front (JKLF), even though these funds were for the non-violent, political wing ‘because money donated to an organization’s political wing is considered to be support for the militant wing as well’.45Khan v. Holder, 584 F.3d 773 (9th Circuit, 2009), confirming the same position as accepted in the case of Humanitarian Law Project v. Reno, 205 F. 3d 1130 (9th Circuit, 2000). Working for a newspaper under the control of the LTTE would also fall within the parameters of this provision.46Raghunathan v. Holder, Docket No. 08-2475, 08-3147 (2d Circuit, 2010). As well, activities such as collecting funds for the Eritrean Liberation Front (ELF), supplying the ELF with provisions such as sugar, shoes, and cigarettes, and passing along secret documents, amount in the aggregate to material support.47Haile v. Holder, 658 F.3d 1122 (9th Circuit, 2011). The same result was reached for a person who was forced by LTTE operatives to cook, dig trenches, fill sandbags and help build fences.48Annachamy v. Holder, 686 F.3d 729 (9th Circuit, 2012).
It would appear from domestic and international sources, both criminal and non-criminal, that the terms “responsible for”, “complicit in” or “materially assisted” should be given a broad interpretation. This interpretation most likely includes all known forms of extended liability known in Canadian criminal and quasi-criminal statutes for both horizontal and vertical relationships and could very well also capture omission liability in certain situations, specifically in hierarchical structures.
Please cite this article as: Joseph Rikhof, « Extended Liability in the Magnitsky Act » (2018) 2 PKI Global Just J 9.
Globally-recognized as an expert in cases of war crimes, Dr. Joseph Rikhof was with the Crimes Against Humanity and War Crimes Section of the Canadian Department of Justice and teaches International Criminal Law in the Faculty of Law at University of Ottawa. Dr. Rikhof was a visiting professional with the International Criminal Court in 2005 and Special Counsel & Policy Advisor to the Modern War Crimes Section of Canada’s Department of Citizenship and Immigration between 1998 and 2002. Extensively published, Dr. Rikhof lectures around the world on organized crime, terrorism, genocide, war crimes, and crimes against humanity.
(c) Pawel Loj, Flickr.
1. ↑ The official name is “Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law)”, which can be found here: http://laws.justice.gc.ca/eng/acts/J-2.3/; the regulations, to which the Act refers can be found here: http://laws.justice.gc.ca/eng/regulations/SOR-2017-233/page-1.html#h-1 while this is the link to the Schedule referred to in the regulation, which was the vehicle to designate 52 persons (Russians and Venezuelans) who have been found to violate the sections of the Act: http://laws.justice.gc.ca/eng/regulations/SOR-2017-233/page-2.html#h-5. In addition to being affected by this particular legislation, the persons mentioned in the schedule are also inadmissible to Canada as a result of an amendment of the Immigration and Refugee Protection Act (IRPA), which added a paragraph (e) to subsection 35(1) of IRPA, dealing with human or international rights violations and which says: “being a person, other than a permanent resident, who is currently the subject of an order or regulation made under section 4 of the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law)”.
2. ↑ See for instance section 139.1(6)(b) of the Customs Act, section 281(b) of the Excise Act and section 119(2)(b) of the Canada Marine Act.
3. ↑ See CCIJ “The Magnitsky Act: A Bold Step Forward, but Changes Needed” (2017) 1 PKI Global Just J 12.
4. ↑ Section 21(1)(b).
5. ↑ Section 21(1)(c).
6. ↑ Section 21(2).
7. ↑ Section 22(1); there is also counseling as an inchoate offence, which can be found in section 464.
8. ↑ Section 465.
10. ↑ Section 83.18(1), which clarifies these two terms by saying that providing, receiving, recruiting, offering, entering or remaining in any country for the benefit of a terrorist group and making oneself available to facilitate or commit a terrorism offence.
11. ↑ Section 83.19.
12. ↑ Sections 83.181 and 83.201-83.202.
13. ↑ Sections 82.21-83.22.
14. ↑ Section 83.221.
16. ↑ Section 318(1).
17. ↑ See at the highest level, Ezokola v. Canada (Citizenship and Immigration), 2013 SCC 40 (Ezokola).
18. ↑ Section 98 of IRPA, which in turns refers to article 1F of he Refugee Convention.
19. ↑ Ezokola, paragraphs 48-68.
20. ↑ Ezokola, paragraph 84.
21. ↑ Robert Currie and Joseph Rikhof, “International & Transnational Criminal law, Second Edition”, Irwin Law, Toronto, 2013, pages 325-334.
22. ↑ See article 1 of the 2010 Convention on the Suppression of Unlawful Acts Relating to International Aviation (Beijing Convention) and article 5.1 of the 2010 United Nations Convention against Transnational Organized Crime. The types of involvement in the latter treaty are conspiracy, attempt, organizing, directing, aiding, abetting, facilitating, counselling and common purpose while the former adds assisting after the fact and threat but deletes facilitating and counselling.
23. ↑ Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment.
24. ↑ Optional Protocol to the Convention on the Rights of the Child on the Sale of Children, Child Prostitution and Child Pornography.
25. ↑ Articles 4 and 3.2 respectively.
26. ↑ Convention on the Prevention and Punishment of the Crime of Genocide.
27. ↑ Judgment, Krstić (IT-98-33-A), Appeals Chamber 19 April 2004, paragraph 137–139; Judgment, Ntakirutimana (ICTR-96-10-A and ICTR-96-17-A), Appeals Chamber, 13 December 2004, paragraph 371; Judgment, Blagojević & Jokić (IT-02-60), Trial Chamber, 17 January 2005, paragraph679, 784; Judgment, Krajišnik, (IT-00-39&40), Trial Chamber, November 28, 2006, paragraph 864-866; Judgment, Ngirabatware (ICTR-99-54-T), Trial Chamber, 20 December 2012, paragraph 1347; see, however, Partial Dissenting Opinion of Judge Shahabuddeen in Judgment, Krstić (IT-98-33-A), Appeals Chamber 19 April 2004, paragraph 59-68; the Decision on Motion for Judgment of Acquittal, Milošević (IT-02-54-T), Trial Chamber, 16 June 2004, paragraph 290–297 and Decision on Defence Motions Challenging the Pleading of a Joint Criminal Enterprise in a Count of Complicity in Genocide in the Amended Indictment, Karemena, Ngirumpatse and Nzirorera (ICTR-98-44-T), Trial Chamber, 18 May 2006, paragraph 6; Judgment Nyiramasuhuko et al. (ICTR-98-42-T), Trial Chamber, 24 June 2011, paragraph 5980.
28. ↑ Judgment, Akayesu (ICTR-96-4-T), Trial Chamber, 2 September 1998, paragraph547–548; Judgment, Musema (ICTR-96-13-T), Trial Chamber, 27 January 2000, paragraph 183.
29. ↑ Judgment, Krstić (IT-98-33-A), Appeals Chamber 19 April 2004, paragraph 142, footnote 247; regarding the latter case, see also G. Boas, J.L. Bischoff and N.L. Reid, Forms of Responsibility in International Criminal Law (Cambridge: Cambridge University Press, 2007) at 422-423.
30. ↑ See for its mandate, background and work in international law http://legal.un.org/ilc/.
31. ↑ United Nations General Assembly Resolution 36/106, 1981.
32. ↑ Yearbook of the International Law Commission, 1996, vol. II, part Two, pp. 18, 25 and 47.
33. ↑ Idem, pp. 18-22, 25-26 and 42-43.
34. ↑ The Report of the International Law Commission on the work of its Forty-second Session, 1990, pp. 12-14, paras. 40-56.
35. ↑ Idem, page 14, paragraph 52.
36. ↑ Idem, page 14, paragraph 52, footnote 36.
37. ↑ See for instance Section 6 of the Parks Canada Agency Act or 3.1 of the Railway Safety Act.
38. ↑ See for instance sections 490.011 of the Criminal Code and 202.14 of the National Defence Act.
39. ↑ This form of liability can also be found in one human rights treaty namely the International Convention for the Protection of All Persons from Enforced Disappearance.
40. ↑ These requirements were fleshed out in the jurisprudence of the ICTY and ICTR while they are also reflected in article 28 of the Rome Statute, which is in turn followed in Canada in sections 5 and 7 of the Crimes against Humanity and War Crimes Act.
41. ↑ The Supreme Court in R. v. Khawaja, 2012 SCC 69, paragraphs 4, 42, 51-53, 57 and 62-63 uses the terms materially support, contribute materially or materially enhance when interpreting section 83.18 of the Criminal Code.
42. ↑ Section 212(a)(3)(B)(iv).
43. ↑ Perinpanathan v INS, 310 F.3d 594 (8th Circuit, 2002).
44. ↑ Singh-Kaur v. Ashcroft, 385 F.3d 293 (3d Circuit, 2004).
45. ↑ Khan v. Holder, 584 F.3d 773 (9th Circuit, 2009), confirming the same position as accepted in the case of Humanitarian Law Project v. Reno, 205 F. 3d 1130 (9th Circuit, 2000).
46. ↑ Raghunathan v. Holder, Docket No. 08-2475, 08-3147 (2d Circuit, 2010).
47. ↑ Haile v. Holder, 658 F.3d 1122 (9th Circuit, 2011).
48. ↑ Annachamy v. Holder, 686 F.3d 729 (9th Circuit, 2012).
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The American Chesterton, IX: “Not Because It Is True”
In 2001 on the death of Mortimer Adler, the noted “Great Books Philosopher” at the age of 98, columnist Paul Greenberg presented his analysis of why (in his opinion) Adler had lapsed into semi-obscurity. As he said,
Mortimer J. Adler (1902-2001)
“Adler’s obscurity in his later years was not just a sign of increasing age and its burdens, but of changes in society — mainly a dangerous lessening of interest in the power of ideas. The result is that we have become susceptible to the worst ideas, or even the absence of ideas, for we are deprived of the habit of struggling with them regularly. . . . we waste ourselves debating facts, which should be ascertained rather than argued, and having to rediscover what the ancients knew. Often enough by bitter experience. . . . That many today never heard of Mortimer Adler or the Great Books, and many others may have to be reminded of who he was, is not a good sign for a cohesive, democratic, tolerant, learned and above all thinking society.” (Paul Greenberg, “Mortimer Adler: A Funny and Great Little Man,” The Item, July 6, 2001, 10A.)
As we have seen, Adler’s concerns echoed those of G.K. Chesterton, Ronald Knox, and Fulton Sheen, particularly in the area of Academia and the general understanding of the basic principles of common sense in the modern world. The whole concept of what it meant for something to be true had changed, as Sheen noted in both God and Intelligence and Religion Without God.
Jesus before Pilate: "What is truth?"
In particular, as Greenberg noted, the “lessening of interest in the power of ideas” affected how facts are treated. Facts were no longer something to be verified, dismissed if false, and accepted if true, then used as input to the development of ideas.
No, facts were now to be evaluated on the basis of their utility to whoever had the power to force others to his or her will, and could be validated as "authentic" instead of true. Opening up the door to a veritable flood of utter nonsense, what mattered was how many people could be persuaded or forced to accept a useful fact, regardless whether it was even a fact in the first place. Might, as in politics and economics, now made right in philosophy.
Part of the reason for this was the incidence of what we can call an inadequate Aristotelian-Thomist logic on which a semi-Platonist concept of ideas had been superimposed. By going from the general to the particular (instead of from the particular to the general), anything that appeared to conform to a subjective and preconceived notion was deemed true, while anything that did not conform — despite its objective verifiability — was deemed false if it did not fit into the subjective preconception.
What that means in English is, having changed what it means for something to be true, people simply took what they wanted to be true, and forced it onto reality, rather than make their understanding of truth conform to empirical evidence (what your senses tell you) and logical argument (what your reason tells you). Thus, you don’t believe something to be true because you have tested it and verified (ascertained) it, but because you find it useful.
Sheen: contradiction is nonsense.
The possibility that something is neither true nor false, but nonsense — what Sheen discovered when writing God and Intelligence — was no longer considered. “Nonsense” — something contradictory or irrational — became another word for “falsehood.” This is especially the case when dismissing what others who disagree with you have to say.
Take, for example, the statement, “If God can do anything, then He can make a weight so heavy He can’t lift it.” The statement is based on a contradiction that violates the first principle of reason. That is, the statement declares that God can both “do” and “not do” (i.e., “be” and “not be”) at the same time under the same conditions. The statement is therefore neither true nor false, but nonsense.
The statement is, nevertheless, taken as “true” by atheists because it presumably proves the whole concept of God is nonsense, instead of merely the statement itself. At the same time, it is taken as “false” by theists because there are things about God human beings cannot understand. In both cases, the faith of the atheists and that of the theists contradicts reason, leaving nonsense.
Lewis: God is not a convenience.
The insertion of contradiction and the nullification of the concept of nonsense is particularly devastating, even destructive — shades of Knox’s “destructive grace” as we termed it earlier — when it comes to matters of faith. As C.S. Lewis had the demon Screwtape explain to Wormwood when advising the Assistant Tormentor on the Satanic benefits of getting people to abandon truth as the reason for doing anything,
“[T]he Enemy [God] will not be used as a convenience. Men or nations who think they can revive the Faith in order to make a good society might just as well think they can use the stairs of Heaven as a short cut to the nearest chemist’s shop. Fortunately, it is quite easy to coax humans round this little corner. Only today I have found a passage in a Christian writer where he recommends his own version of Christianity on the ground that ‘only such a faith can outlast the death of old cultures and the birth of new civilizations.’ You see the little rift? ‘Believe this, not because it is true, but for some other reason.’ That’s the game.” (Lewis, The Screwtape Letters, op. cit., 108-109.)
In light of this, it is ironic that there are a significant number of people today who have been drawn to the Catholic Church because of its social teachings.
Now, there is nothing wrong with that. It is, in fact, laudable — as long as it doesn't stop there . . . and as long as they have the correct (not necessarily "authentic") understanding of those teachings.
Aquinas's thought cannot support contradiction.
The problem is that some converts (including nominal Catholics who undergo a “reversion” or inner conversion) assume that the preconceptions they bring to the table are correct understandings of what the Catholic Church teaches. They begin forcing what they have previously accepted as true without proof or argument on to a foundation that might not be able to support it, especially within the Aristotelian-Thomist framework, which simply cannot support contradiction of any kind.
When the inevitable contradictions appear, such converts and reverts become perverts tailoring what the Church teaches in matters of faith and morals to conform to their untested assumptions, often distorting them completely out of shape. When others disagree with them — especially when those others present empirical evidence and logical argument — the enthusiastic (in Knox’s sense) response is to reject reason, and go with a personal faith, calling into question the personal faith of those who disagree with them.
This is not to say that what people believe should not be a part of their personal, family, and civil life. One’s faith not only should, but must be a part of everything one does, just as each person must have a consistent and sound philosophy to be able to develop more fully as a human person. That is not the issue. The issue is whether one is integrating his or her faith into every aspect of life . . . or whether one is changing the absolutes of one’s faith to conform to what one finds “useful.” As Lewis had the demonic adviser Screwtape say,
“Certainly we do not want men to allow their Christianity to flow over into their political life, for the establishment of anything like a really just society would be a major disaster. On the other hand we do want, and want very much, to make men treat Christianity as a means; preferably, of course, as a means to their own advancement, but, failing that, as a means to anything — even to social justice. The thing to do is to get a man at first to value social justice as a thing which the Enemy demands, and then work him on to the stage at which he values Christianity because it may produce social justice.” (Ibid., 108.)
Tawney: Anglican Christian, Fabian Socialist.
As a case in point, we know of at least one noted Catholic commentator who was drawn into the Catholic Church because he found the writings of the Anglican Christian socialist and Fabian Society member Richard Henry Tawney (1880-1962) persuasive. This was evidently because Tawney, who headed the Fabian Society from 1920 to 1933, and advocated that organized religions become less religious(!), said what the commentator wanted to hear. Influenced by what comes across as a violent hatred of capitalism, this individual assumed as a matter of course that Catholic social teaching (the understanding of which he derived from a Protestant socialist involved in “Esoteric Buddhism” — i.e., theosophy) is simply an ethical form of socialism. This had to be under another name, of course, since the Catholic Church has condemned socialism in no uncertain terms, and tends to look askance at syncretism, that is, combining different forms of religious belief, such as Esoteric Buddhism and Christianity.
The fact that an Anglican Fabian socialist could hardly be considered an authoritative source for understanding Catholic social teaching that opposes socialism was brushed aside, along with the clear and unequivocal condemnations of socialism and New Age thought by the popes. A twist to the mind here, a turn around the corner there, and the thing was done. Something becomes “true” because it is perceived as useful for gaining one’s ends and because someone with power validated it, not because it is objectively factual.
Of course, mere contradiction by itself soon wears thin and becomes obvious for what it is: an exaggerated sense of one’s self, a supreme lack of humility that can overcome even truth and reason itself in furtherance of one’s own ends. Just as socialism and New Age thought needed each other, something else was needed to complete the overthrow of reason and common sense.
That is precisely what Fulton Sheen found in the philosophical and theological movements of the late nineteenth and early twentieth centuries, as we will see in the next posting in this series, and what he set out to counter and correct in God and Intelligence.
Topics: Chesterton, Crisis of Reason, Fulton Sheen, Ronald Knox
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The American Chesterton, XVI: What is Truth?
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The American Chesterton, XIV: Problems and Framewo...
Chocopalypse Now, I: The Cocoa Crisis
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The American Chesterton, XII: Sheen at St. Edmund’...
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The Opium of Public Debt
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New Year’s Day, 2016


In rural Georgia and across the country, the uncertain future and closure of emergency rooms and hospitals are all too common. A primary factor is the long-term impact of a federal law that requires hospital emergency departments to treat and stabilize all patients, regardless of their ability to pay.
This commentary by Kelly McCutchen, president and CEO of the Georgia Public Policy Foundation, was published first by Insider Advantage. The Foundation is an independent, nonprofit, state-focused think tank that proposes market-oriented approaches to public policy to improve the lives of Georgians. Nothing written here is to be construed as necessarily reflecting the views of the Georgia Public Policy Foundation or as an attempt to aid or hinder the passage of any bill before the U.S. Congress or the Georgia Legislature.
© Georgia Public Policy Foundation (August 25, 2017). Permission to reprint in whole or in part is hereby granted, provided the author and his affiliations are cited.


I am a former teacher who holds a BA in elementary education/ kindergarten. As an advocate for disability rights, I have served on advisory committees at the state, county, and school levels. I delight in the natural world, travel, and expanding my spiritual life. My husband, Kevin, and I have two daughters, Claire and Bridget, and live in Saint Paul, Minnesota.
Tamara R. Sayre is an enthusiastic art teacher with a passion for portraying her art from an animal’s point of view. Her work has appeared in the Wyoming Wildlife magazine, publications for Cornell University, The Nature Conservancy, and various books for biology professors. Tamara currently resides in Genesee, Colorado.


Understanding visualizations

What is a visualization?

Visualizations are how Pokeit delivers information to you about your poker data. A visualization can be a table, a line chart, or a scatter plot. It can show villains, heroes, sessions, hands, and tournaments. You can filter visualizations to show tiny slices of your data or you can zoom out to see all your hands at once. Visualizations are completely customizable—from the shape, to the theme, to the colors of the lines, and to the statistics being displayed. You can build them from scratch or you can use the defaults as starting points for making your own. You can interact with them by zooming in, viewing individual hands, or hovering over data points with the tooltip.

There are a lot of ways to use visualizations in Pokeit and we hope to get you started on the right foot!

Loading visualizations

All you need to do to load a visualization is click on it. This can be done from the main dashboard or from the visualization list section. Once you click on a visualization, an icon for it will appear in the black header indicating that it’s been loaded.

Just a Tip: When your screen is wider than it is tall, the header will appear as a sidebar on the left, otherwise it will appear at the top.

The data for the visualization will immediately begin downloading. Once it’s finished rendering, the visualization itself will appear in the center of your screen. The visualization can be removed by hovering its icon in the header and clicking on the close button. Otherwise, the visualization will remain attached even if you reload the page or log out of your account.

Interacting with visualizations

You can interact with visualizations in many ways. For example, you can right-click on any row or data point to open a context menu. From that menu you can apply tags, stars or notes. Data points marked this way can be highlighted or filtered by clicking on thetag button in the visualization toolbar. You can also load entirely new visualizations based on the the data point you clicked on. If for example, you were viewing a report of tournaments, you could from jump into a new visualization of all the hands from each one from this context menu.

In scatter plots or line graphs you can zoom in close by pinching and zooming on your trackpad or by scrolling with the scroll wheel. Hovering will also produce a tooltip in graphs providing information on individual data points. Axis coordinates and data point labels will be displayed by default and other information can be added to tooltip from the settings panel.

Visualizations can also be shared with others. Clicking on the sharing button in the top right of the toolbar will produce a dialog with a number of options. You can set a title, control what information is accessible, and get the word out with social media links.

Editing visualizations

You can edit your visualizations from the settings panel. The settings panel can be opened by clicking on the gear button in the top left of the toolbar. Once clicked, the settings panel slides out from the left and you’ll see options for changing the fields on display. Fields can be chosen from the dropdown and dragged to where you want them by holding down shift + ctrl. Scroll down just a bit and you’ll see other options such as setting the currency, controlling how many records you want returned, and more.

In the top right corner of the settings panel is a filter button for switching to the filters section. This section contains all of the filters set for your visualization. There should always be one filter at the top for either Hero or Villains mode. Depending on the visualization, you may find other filters below that. There’s also a section called "Filter Workspace". Filters set here are shared across all your visualizations.

Because changing fields and filters is one of the main ways you’ll be interacting with Pokeit, we’ve included shortcut links for these functions in the visualization toolbar. Here you can change your currency, fields, and filters quickly from dropdowns without having to go through the settings panel.


You are not logged in. [Log In] Outlaw Homepage » Forums » Preamplifiers  Processors  Receivers » Model 976 » 976 Dislikes or improvement/update wish list !
Yes, but the 975 won't let you use the record out to record digital inputs. The Outlaws must have decided that the record out function was something that had to be let go in the digital age. That way they can avoid HDCP and the level control programming needed.
What is it you want/need to feed with a line out option?
Loc: Georgia, US of A!
I plan to use the balanced outputs for all channels except LFE. That brings up a 5/7.X question: if all speakers were set to Large (PLEASE don’t ask why) what info would be sent to the Sub out (or) what is LFE info specifically?
Also I replied on pages 5&6 about 975/976 output or “drive as I like to call it. Unfortunately I have yet to receive* an explanation why my Rotel or previous processors “were LOUDER” [b]before[/b] max volume than the 975 AT max volume. And believe me, I have 10-20X power “on tap” today than my pre-975 days.
* I called CS about this. Their answer amounted to a difference in the “type” of VC. That STILL didn’t explain why the 975 didn’t “crank” the same.
Check out this article from Dolby, which explains what an LFE track is. The subwoofer will reproduce LFE track audio and any other channel audio below the crossover points set. If speakers are set to large, that will send full range audio to those speakers, and with the crossover deactivated, no other channel audio will be steered to the sub(s). If all speakers were set to large, they would all be receiving full range and no signal would be steered from the other channels. All you would get is the LFE track audio reproduced by the sub.
What confuses most people is, how soon the loudness or gain an absolute volume circuit reaches reference levels, from the minimum or silent position, compared with a relative volume circuit, that will reach reference levels and possibly an additional 20dB of gain, max.
Which means, if the maximum range is 0dB on the control, reference level would be -20dB on the scale.
It's time to hit "send", and leave.
Thanks!! Now I get it!
What confuses most people is, how soon the loudness or gain an absolute volume circuit reaches reference levels, from the minimum or silent position, compared with a relative volume circuit, that will reach reference levels and possibly an additional 20dB of gain, [at] max.
S&V has a very good explaination. Pity it took a Saloon member to explain: a relative “V” control has up to 20dB of add’l gain. Also thanks for the comprehensive LFE answer.
BTW I knew of issues setting any channel to Large: my LR and each surrounds each has a dedicated sub*. At the moment, my System sub handles the CC’s heavy lifting and all important LFE.
* small but acurate, robust, low distortion to 27hz, and high WAF!
Now to any one: are the balanced outputs hotter than the unbalanced?
The dial position, ie -20dB for reference level, is arbitrary. It depends on your power amps gain, speaker sensitivity, listening distance, room size, etc.
In my setup, my 976 reference level is at -10dB on the volume dial because I set my amps gain lower.
For a given power supply, a balanced output have the potential to produce 6dB higher maximum level, because of the differential nature of the balanced system. However, their actual gain may be set by the manufacturer to produce the same nominal level than the unbalanced outputs at a given volume position. Or not!
" I hear no highs, I feel no lows, it sounds like crap, it must be Bose "
Yes, the XLR outputs have more output voltage than the RCA pre-outs.
I read this. Doesn’t sound as transparent as the 975 - a feature I LOVED! My 976 is past due.
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Schlangen, D., Zarrieß, S., and Kennington, C. (2016). “Resolving References to Objects in Photographs using the Words-As-Classifiers Model” in Proceedings of the 54th Annual Meeting of the Association for Computational Linguistics (ACL 2016) (Berlin).


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Currently IIAS allows for auto table maintenance . But we request to automate 'Alter tablespace <TBS_NAME> reduce max' ,so that space released back to the space system .
Current we need to run it manually and its taking run long time . Our request is to automate the reclaiming the space for more than one table space.


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Just wanted to share this amazing video from our ‘sister ship’ on the west coast, theBelafonte.

Ole and Sarah were riding back to Santa Barbara after a weekend in the Channel Islands when a humpback whale and her calf surfaced next to the Belafonte, their 17-foot RIB.

The whales were really curious, spouting and splashing right next to the boat. At one point, a huge flipper nearly smacks the outboard right before those characteristic ridges of the humpback underbelly bob out of the water. Note the change in tone of Sarah’s great narration at that point!

Ole said the whales still followed them as they motored off, so they stopped a few more times to let them check out Belafonte. But he and Sarah didn’t hang around too long — not when mama’s fluke was about as wide as the boat was long.


Read Next:	Emma Stone Eyes Damien Chazelle's Next Film 'Babylon'
May 24, 2013 3:00PM PT
Participant Media Finds Convenient Truth With ‘State 194,’ ‘Fifth Estate’
Pics to receive activist pic shingle's Web-based social action campaign
By Dave McNary
Dave McNary
Film Reporter @Variety_DMcNary	FOLLOW
Dave's Most Recent Stories
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Participant Media, a key backer of touchstone documentaries such as “An Inconvenient Truth” and “Food,” Inc., isn’t afraid to take on divisive issues like government secrecy and the state of Palestine.
The 9-year-old company has just released Dan Setton’s “State 194,” a documentary about Salam Fayyad’s efforts to gain United Nations recognition for the independence of the Palestinian territories. And it’s in post on Bill’s Condon’s WikiLeaks drama “The Fifth Estate” (pictured above), due out Oct. 11 from Disney.
Both titles also are receiving Participant’s unique added-value component: a Web-based social action campaign aimed at sparking discussion and getting people involved with the issues represented in the movie. It’s a strategy exemplified in the company motto: “Entertainment that inspires social change.”
A third of the 150 or so employees at Participant’s Beverly Hills headquarters work on social action campaigns, reaching out to communities of engaged and influential individuals via TakePart.com — the company’s digital arm. The site has been attracting more than 4.5 million visits a month with 11,000 pieces of content a year — each with links that connect users to an action they can take.
For “State 194,” the site features several stories about the film as well as a Take Part link to the Fund for Reconciliation, Tolerance and Peace, which is working to break down psychological barriers between Israelis and Palestinians.
“The basic idea is to get people talking about the issues,” Participant’s Chad Boettcher says. “We’re under no illusions that the crisis will be solved the next day. The film is an opportunity to bring awareness into this area.”
Boettcher, the company’s exec VP for social action, notes that Participant, which has released 43 films in nine years, typically plans the social action campaigns for about half a dozen films at once, which currently include those of “The Fifth Estate,” “The Great Invisible,” “The 99 Percent” and Donald Rumsfeld documentary “The Unknown Known.” He says “The Fifth Estate” campaign — not yet approved — will highlight the notion of digital literacy, and the opportunity to use that to create communities that empower people.
“We’re developing (and piloting) a social impact index that incorporates lessons from our nine years of social action campaigns, and pulls them together in a consistent methodology and approach that both we, and our partners, can regularly use,” Boettcher says.
While it may sound wonky, the issue-based film biz hasn’t been doing too badly lately. In the past two years, the movie production company, founded by Jeff Skoll in 2004, has turned the corner in terms of profitability, with four of its films — “The Help,” “The Best Exotic Marigold Hotel,” “Contagion” and “Lincoln” — combining for more than $750 million in worldwide grosses.
That would be filmmaking success enough for any production company, but Participant wants to change the world, too. Every one of its films includes a social-action component tied to the movie, including such issues as prison sentencing (“Snitch”), dolphin slaughter (“The Cove”), the path of epidemics (“Contagion”); elderly housing (“Marigold Hotel”), and homelessness (“The Soloist”).
“We have two bottom lines — one for profit and one for social action,” notes chief exec Jim Berk.
Dolphin Digital Media
Food Inc
Jim Berk
Participant TV
The Fifth Estate
Weekly Online
Wikileaks Documentary


For many students at Etobicoke’s School of the Arts, Rent is more than just another musical; being part of the production has been an emotional journey of self-discovery.
Luke, 17, plays Angel, the musical’s drag queen. Hesitant and shy, Luke says playing Angel has been very moving. After lacing up his shiny white knee-high six-inch heels, he stomps up the stairs. By the time he reaches the stage, his transformation is complete.
An Xtra reporter spent the day at the school March 24 watching one of the last rehearsals. The production runs until April 1.
Some of the students were already familiar with Rent when rehearsals began, but for most it was completely new material.
Aikens reports that the student-made videos are currently being looped on video screens around the school. He says the musical was a great way to get the students talking about gay, lesbian and trans issues in an open and honest way.
Nesbitt recalls group discussions filled with hugs and tears.
Based loosely on Puccini’s opera La Bohème, Rent is a rock opera based on a year in the life of a group of young bohemians struggling to survive in New York’s East Village.
“It was a huge bonding experience,” says Alicia Ault, 17, who also plays Joanne.
For tickets, call the school at 416-394-6910 or email esamusical@live.ca.


The origin of X-23! Cloned from Wolverine’s cells and raised to be the perfect killer, young Laura Kinney never knew a life free from the harsh masters at the Facility. But now she’s broken loose at last and must forge her own path in the world! Free of her chains and determined to live, Laura will write the next chapter of her story herself. But can X-23 escape her training and her instincts, or will the gallons of blood spilled in her violent past drag her down? And can she truly begin a new life until she faces the man whose shadow has loomed over her for years? Enter: The Wolverine! Collecting X-23 (2005) #1-6, X-23: TARGET X #1-6, CAPTAIN UNIVERSE/X-23, X-23 (2010) ONE-SHOT and #1-3, and material from X-MEN: TO SERVE AND PROTECT #2.


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Drum Orchestra – It Takes a Village! | Musical IQ - Inspiring, Creative, Unifying & Fun!
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This program takes the drum circle concept to a new level and is fun, interactive, and high-energy. Each participant is given a drum and other percussive instruments to experience being a part of a rhythm orchestra – in which each small contribution is vital to the making of a unique musical creation. This program has a sense of humor and is fast paced, giving participants an experience and taste of the creative process.
Following some fun and playful rhythmic exercises, designed to establish group coherence and to promote teamwork, the group will learn about the musical instruments and how to use them. Using guided rhythmic activities and instruction, the group will then begin to establish a simple layer of basic rhythm and continue layer by layer to build a unique and beautiful musical creation.
This program will emphasize the power of collaboration and community. It promotes cooperation, demonstrates the value of effective communication and listening, illustrates the importance of diversity, awakens the creative spirit, and is a whole lot of fun!
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Shot down above Hamburg during the Second World War, a young Norwegian navigator spent several years under Nazi captivity. The experience haunted him throughout the long, sleepless nights of the decades that followed, and left him unable to convey the horrors he experienced to his family – including his daughter, the visual artist Bodil Friele.
From 24 March until 7 April, Leith School of Art presents Friele’s exhibition ‘Prisoner of War, Paintings and Poems’, the first in the institution’s ongoing programme of cultural exchanges between Scotland and Norway. This fascinating personal exploration represents Friele’s attempt to make sense of her father’s experiences and to bring the viewer face to face with the reality of war.
Drawing upon poems and notes he wrote during the war years, as well as the memories that emerged, haltingly, over time, Friele has used painting, sculpture and verse to transform her father’s legacy into an artistic testimony that is both personal and provocative.
Through pictures, text and sculptural forms, the new exhibition confronts the viewer with the moral heritage of war, reflecting reality as it was – and still is in many places in the world – and offering a haunting vision of what it means to be deprived of freedom and forced to live according to the dictates of others.


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Online shopping is an incredible instrument for furnishing a home. Yet, a great deal of us discounts buying furniture online in light of the fact that it appears to be excessively hazardous. How might you tell if what you see is really what you get? How would you realize the piece will work in your home on the off chance that you haven’t gotten an opportunity to see it first?
On the off chance that you’ve at any point put forth comparative inquiries, this post is for you. With an end goal to control you through this procedure, we’ve ventured to pull together our four top tips for purchasing furniture online. Peruse them over cautiously for whenever you’re prepared to switch up your interiors. With our assistance, we wager you’ll feel sufficiently certain to add online stores to your collection.
Measuring is the most vital part of buying furniture from furniture stores in Dubai, period. It’s considerably progressively essential when buying online. Since you won’t almost certainly stroll into a physical store and witness for yourself how that piece will fit in your space, you’ll need to ensure your measuring abilities are strong.
When you have a thing you need to purchase, read over the item listing to find the measurements. Then, utilize allotted painter’s tape or string to assemble a format of how it will look in your home. On the off chance that your furniture expands by one way or another — like a recliner or extendable dining table — ensure you represent the biggest rendition. At that point, twofold check your work.
Remember this isn’t the main estimation you need to represent. In the event that your furniture is coming to you previously gathered, you have to gauge any significant entryways and stairways to ensure you can really get it to where it should go.
Item listings should sound complimentary. That is the reason it’s normal for a household item to sound precisely like what you’ve been hoping for at first look. Frequently, however, surveys recount to a marginally extraordinary story. That is the place different clients regularly get genuine about their involvement with the item.
When buying online, these surveys are vital to your prosperity. Concentrate your shopping on things that have bunches of accessible surveys and read over them cautiously. You’ll, for the most part, begin to recognize a topic about certain subtleties referenced by different clients. Gauge these remarks in your choice, as they’re probably going to be intelligent of your experience.
Remember that each item will undoubtedly have a couple of terrible audits, particularly in the event that it has a high number of remarks. A terrible survey doesn’t really mean you shouldn’t purchase the item, yet it should factor into your choice. Give close consideration to the level of awful audits by and large and how the complainants state the dealer took care of their issue. So, if an audit doesn’t agree with you, it’s most likely best to investigate different items.
Online item photographs are difficult to pass judgment. Truly, that may, in fact, be what the bit of designer furniture Dubai resembles, but on the other hand, it’s being appeared in the absolute best light and with the absolute best arrangement to urge you to make a buy. Frequently, when you get it home, certain subtleties — particularly shading and surface — can be uncontrollably not quite the same as in the photograph.
That is the reason we suggest viewing the genuine article before buying, if at all conceivable. On the off chance that taking an outing to a store to see it in person is possible, that is your most logical option. If not, have a go at requesting a texture swatch. Numerous organizations will send one to you to guarantee you’re content with the manner in which the texture looks.
Ultimately, if a swatch isn’t a choice, you can generally complete a picture scan for purchaser photographs of the item. While a few subtleties will at present be somewhat modified by your PC screen, those will demonstrate to you an alternate rendition of how the piece will look once you’ve outfitted your home with it.
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What are Gravity Separators and Their Contribution to Waste Water Treatment?


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When Mars needed to slash the build time for a community sports pavilion from 26 weeks to 10 to fit tight advert filming schedules, agents for the global confectionary giant turned to Steve Wells Associates to make sure the project ran smoothly and on time.
It was SWA's close relationship with the FA that prompted Mars' advertising agents to contact managing director Steve Wells with the unusual request, as he explains.
"Mars - sponsors of England Football - contacted the FA to ask if they knew of any schemes which were almost ready to go so that they could film construction for one of their advertising campaigns.
"The FA gave Mars details of five or six schemes, one of which was the sports pavilion in Carperby, a rural village of 240 people in North Yorkshire. I have a good relationship with the FA, so when they called and asked if I'd go to site and meet the ad agency, I was happy to do so."
So in late September 2010 Steve met the Mars ad executives and the team behind the Carperby pavilion to talk them through a building project and to answer their questions.
"I knew as soon as I saw the plans that they were looking at a six month build," says Steve. "The advertising team had lots of questions about the building process. I didn't know at the time, but they were trying to work out a storyboard."
A week or so later, Steve got a call from the ad agency, Octagon. They'd fallen in love with the Carperby site and wanted it to feature in their latest campaign. The only problem was they had to speed up the build time to fit their tight schedules – from 26 weeks to 10!
"Mars had bought TV airtime from the beginning of February 2011, so all filming had to be finished by the first week in January," Steve says. "Cutting the building time by more than half would have been difficult at the best of times, but in the middle of winter in an area known for its adverse weather – it was never going to be easy."
But Mars was determined that Carperby was their site, and Steve was asked to manage the project through to completion. "We like a challenge," said Steve, and a hasty meeting was arranged on site with the contractor.
The first task was to work out how to squeeze the build time by 16 weeks. Scott Stephenson, the building contractor, told Steve that getting materials, labour and service connections wouldn't be an issue, but the showstopper would be the weather. "When you're building in Wensleydale in the middle of winter you're at the mercy of the elements," said Scott who lives in Carperby.
Steve suggested that construction could take place inside a large 'scaffold tent' which, along with space heaters and floodlights, meant that building could continue whatever the weather.
More plans for the pavilion had to be drawn up and, with eight weeks left, work started in earnest; but things were about to get worse. "Gale force winds blew out the first section of wall that was built and then I got phone call from the building inspector saying the site was a radon hotspot," says Steve.
"Radon's a naturally occurring gas which normally escapes harmlessly into the air, but if you're building over it, you need a special barrier under the foundations - more expense and more delays."
Eventually, with the building work well underway, Steve began the delicate task of acting as intermediary between the local team who were building the pavilion and the advertising and film crews who were to turn it all into a national TV advertisement for Mars.
"The producer and his team had clear ideas, with detailed storyboards of the scenes they needed to shoot," says Steve. "And it's true to say that on the first day of filming the guys laying the blocks had enough to contend with without the attentions of a 40 strong film crew."
The scaffold tent was now ready to be delivered to site and took a week to erect. "The day after the last tarpaulins were lashed to the tent, the snow fell … and fell and fell," said Steve. But despite the worst December weather on record and temperatures outside the tent regularly plummeting to minus 20, the pavilion construction continued apace.
But the weather had one more shot at derailing the project. With just over a week to go Steve got a call to say the concrete ordered to screed the floor – the final part of the build before decoration – wouldn't be arriving because the concrete plant had frozen.
"It was the 22nd December and we had no floor," says Steve. "But, with some frantic phoning round, we found a plant that was still operating. The floor was down by Christmas Eve."
And into the New Year, and on to the last of the six filming days to conclude the advert which followed Mars' time-honoured strap-line of 'work, rest and play'.
The focus of the advert was to show the building of the pavilion, with the villagers getting involved and everyone pulling together. The final scenes were to feature a football match with the players running onto the pitch from the completed pavilion and starring Stoke City and England star Peter Crouch. But other than managing the build programme and making sure the shots for the storyboard were ready for filming days, the producer had another role in mind for Steve.
"The storyboard showed a foreman blowing a whistle at the start of the ad calling the villagers 'to arms' to start work on the pavilion; and then that foreman becoming the ref at the end of the advert, blowing the whistle again to start the football match. The producer asked me whether I'd play that part," says Steve, "which, when you're up to your knees in snow and mud, didn't seem too big a deal at the time."
So, early in January, Peter Crouch arrived in Carperby by helicopter and the final scenes were shot. And from 10 weeks' work, six full filming days, and around 30 hours of film 'in the can', a 30 second ad was born.
"My most memorable moment was on 27 November the day after the scaffold tent was completed and the snow fell. With the worst that the weather could throw at us, my hat goes off to Scott Stephenson and his team whose Herculean efforts saw this project home.
"This was a fantastic project and not the kind we tackle every day," admits Steve. "I am director of a company that, among other things, designs and develops sports facilities. I knew a fair bit about the construction industry but knew little about producing adverts and filming. I knew even less about refereeing. This has been a tremendous experience and I have made some real friends on the way. What a journey.
"But in the end, it was no different to any other scheme. We put people and resources together to bring a project home on time and on budget … just another day's work really."
"Cutting the building time by more than half would have been difficult at the best of times, but in the middle of winter in an area known for its adverse weather – it was never going to be easy."


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Timberwolves have best odds, but many seeking lottery win

While LeBron James seeks an NBA title, the Cleveland Cavaliers are searching for a new franchise player.

A month after doing his part to save pro basketball in Sacramento, Mayor Kevin Johnson is coming back east in hopes of helping the Kings find a savior.

And the Minnesota Timberwolves, perennial lottery losers, have the best odds of finally claiming that elusive No. 1.

The NBA holds its draft lottery Tuesday in Secaucus, N.J., with a lucky team earning the right to make the first pick in next month's draft.

The Timberwolves have a 25 percent chance of winning, thanks to their league-worst 17-65 record. But they shouldn't design a jersey with the name of Duke's Kyrie Irving, Arizona's Derrick Williams or whichever other player they would consider with the top pick just yet.

The Wolves have gone backward seven times and stayed put the other six in their 13 previous lottery opportunities, falling to the No. 4 pick last year despite entering with the second-best odds of winning. In their only other chance from the pole position, they took a costly two-spot dive in 1992, missing out on Shaquille O'Neal and settling for Christian Laettner.

And the lottery has been no help at all lately to the teams that need it most. Not since 2004, when Orlando won and grabbed Dwight Howard, has the team with the worst record landed the top pick.

Cleveland won the year before and selected James, who led the Cavaliers to their greatest success. But he bolted for Miami last summer and Cavs tumbled from a 60-win team to the worst in the Eastern Conference with a 19-63 record.

They have a 19.9 percent chance of winning with their own pick, plus a 2.8 percent chance of turning a pick owed them by the Los Angeles Clippers from the Baron Davis trade into the No. 1 selection. Cavs owner Dan Gilbert's team will be represented on stage by his 14-year-old son, Nick, who was born with Neurofibromatosis (NF), a nerve disorder that causes tumors to grow anywhere in the body.

The Kings have lost ground in the lottery two years in a row but could have a winner in Johnson, who led the drive to keep them in Sacramento at least one more season. He came to New York last month and impressed NBA owners with a pitch that highlighted millions of dollars in sponsorship commitments, and team owners Joe and Gavin Maloof decided not to file for relocation to Anaheim.

Johnson said he was honored when the Maloofs asked him to represent the Kings. He took it as a sign of goodwill that the city and team can work together to finance a new arena.

Although Johnson played almost his entire career for the Phoenix Suns, he said when he was elected mayor of his hometown in 2008 that the Kings would forever be his favorite team.

"I'm going to negotiate with the Maloofs that if we get the No. 1 pick, then they're going to have to sign me to a 10-day contract so I can wear a Kings uniform," he said.

The 14 teams that missed the playoffs are in the lottery. The lottery sets the top three picks, with the next 11 spots being determined in inverse order of a team's record. So the Wolves can do no worse than No. 4.

Utah also has two chances of winning. The Jazz own the Nets' pick, currently No. 6, from the Deron Williams trade, and their own spot is currently 12th.


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Montreal high school to help 'cyber-athletes' hone video game skills
MONTREAL — Teamwork, competition and the thrill of bringing home a championship are part of the high school experience for many young athletes, but for a growing number of teens that glory is being pursued online.
Jan 31, 2019 5:28 PM by: Canadian Press
Updated Jan 31, 2019 6:05 PM
And one Montreal high school wants to help them with a new "esports studies" stream that allows students to spend part of their school day playing video games as an entry to the booming world of competitive gaming.
Starting in September, about a dozen "cyber-athletes" from the Edouard-Montpetit school will spend half their day in class and half at a gaming academy, in a program modelled after those offered to elite athletes in hockey, swimming, tennis and other sports, said Patrick Rheaume-Espinoza of the Montreal Esports Academy.
Rheaume-Espinoza, whose academy is running the video gaming component of the program, says it offers similar benefits to those of conventional sports, including teamwork, judgment, discipline and increased motivation at school. He says the Edouard-Montpetit program will be unique in Canada.
While some may raise eyebrows at putting video games on a par with soccer, Rheaume-Espinoza believes Quebec will eventually follow the lead of countries such as South Korea that have officially recognized gaming as a sport.
"What defines a sport?" he asked in an interview at the academy's headquarters in a converted clothing store on Montreal's trendy St-Laurent Blvd.
"It's a game. It's competitive. There are winners, there are losers. There's sportsmanship, there's a goal and there's passion." He added that physical fitness is a core component "because both body and mind activity are 100 per cent required."
Live-streamed esports draw huge audiences, player sponsorships and tournament prize money. The massive popularity of games such as Fortnite means games have become big business — one that U.S. investment firm Goldman Sachs has estimated could rival the NFL in terms of audience within the next five years.
But Quebec's junior education minister Isabelle Charest, a former Olympic short track speed skater, expressed skepticism on whether video games could eventually be classified as a sport.
"I find the nomenclature unusual, because we consider sport to be physical activity. With that definition, I'm not sure it counts as a sport," she told The Canadian Press Thursday.
"For sure it's a new phenomenon. We'll have to see exactly how we're going to categorize it, but those are discussions we'll have within the ministry."
Gregory West, a psychology professor at the Universite de Montreal who has studied the effects of video games on the adult brain, says schools should think twice about encouraging them.
A study conducted by West and other researchers found that about half of players who were scanned after playing 90 hours of first-person shooter games experienced atrophy in their hippocampus, a part of the brain that helps with memory and is tied to long-term cognitive health, including the risk of depression or dementia.
While the study found so-called "platform" games, where players have to overcome obstacles and navigate terrain, actually strengthened the hippocampus, West believes that his study and other raise warning flags.
"I would suggest to any policy-makers that this is not necessarily a good idea, given the fact that we do not understand how these types of games impact the developing brain," he said. He added, "encouraging youth to play for half the day, every day, is concerning."
But Rheaume-Espinoza says the gaming academy provides a structured atmosphere that will help students avoid the negative aspects of gaming.
The program includes about two hours of game coaching, as well as classes on game theory, and 30 minutes of physical education. Students will also learn about cyber-dependence and cyber-bullying as well as "healthy lifestyles," including the need for proper sleep, nutrition, and hygiene.
He said that while the stereotype of an anti-social boy playing games "in his parents' basement eating chips and junk food" does exist, serious gamers understand the importance of health for performance. "When you're a sportsman, at a national competition, you want to be 100 per cent optimal," he said.
That sentiment was echoed by 18-year-old aspiring pro gamer Eliyakim Bezeau, who recently decided to leave school in hopes of turning his hobby into a career.
Bezeau, who was finishing up a personal coaching session at the Esports Academy on Thursday, said he was there to improve many aspects of his game "It's my mechanics, vision, my game sense, learning to position myself," he said. "There are a lot of tricks to it."
He said gaming can be healthy if it is not seen as an escape.
"If you do it in a moderate fashion, it can be good, and you can make a living doing it," he said. "But you have to control yourself."
-- With files from Patrice Bergeron
Morgan Lowrie, The Canadian Press
More National Sports
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LONG AND SHORT TERM RENTAL OF LARGE FULLY FURNISHED PRIVATE LOWER LEVEL OF BEAUTIFUL HOME WITH VIEWS - LONG OR SHORT TERM RENTAL OF LARGE FULLY FURNISHED PRIVATE LOWER LEVEL HOME IN PA. has Two bedroom, one bath, fully-furnished privet entrance of lower level only of this beautiful home on two acres, with your own separate entrance with French doors out to covered patio and off street parking, (Just bring your cloths and toothbrush). Water, trash, Internet and cable included in rent. Includes: pool table, beds, furniture, dishes, and everything you need. Kitchen with dining area seating for six. Great central location only 10 minutes from airport and 15 minutes drive to Hershey & Harrisburg. A little less per month for longer term rental. please call Wayne at 303-526-5480 (RLNE2003896)

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