text:
Zacarias Kanjirath Joseph†
A recent judgment of the Indian Supreme Court ("Supreme Court") in the case of M/s Oriental Structural Engineers Private Limited ("Contractor") v State of Kerala ("Employer"),[1] illustrates the treatment of (common) instances in construction contracts where:
the clause regarding award of interest is left blank, i.e., "_____%" ("Blank Interest Clause");
a contractor has by correspondence waived its claims for interest, during the pendency of the contract. ("Contractors Correspondence").
The Supreme Court held that an arbitral tribunal was entitled to award interest despite such a Blank Interest Clause. The Supreme Court further upheld the arbitral tribunal's finding that the Contractors Correspondence was issued under 'coercion'.
Relevant Facts
The Contractor was awarded a contract by the Employer for the upgradation of two stretches of a state highway. The Contractor's claim for interest for delayed payment under various heads was the only point of dispute before the Supreme Court. The agreement entitled the Contractor to claim interest compounded monthly, if the Employer failed to make payments within the time stipulated under the agreement. The rates of interest were as stated in the 'Appendix to Bid'. The Contractor (being the bidder) was required to complete the Blank Interest Clause. The Contractor left the space for recording the rate of interest in the 'Appendix to Bid', blank. Further, the Contractor in previous correspondence had stated that "we confirm that there is no provision of interest on delayed payment in the Contract and hence interest will not be claimed.". Further that their "commitment not to claim any interest on the said amount released by you be treated purely as a goodwill gesture so that our future payments are released to us without any delay.". (emphasis supplied)
Award of the arbitral tribunal
The arbitral tribunal held in favour of the Contractor and awarded an interest at the rate of 1% per month compounded monthly, on the unpaid sums, for the period the sums remained unpaid. Further, interest of 12% per annum on the interest amount was directed to be paid on the sums awarded from the date of award, till date of payment ("Awarded Interest"). The tribunal, on an appreciation of the evidence, held that the aforesaid Contractor's Correspondence was issued under coercion. The correspondence was therefore held to not be a waiver of the Contractor's claim for interest.
Award partly set aside
On a challenge under Section 34 of the Arbitration and Conciliation Act, 1996 ("Arbitration Act, 1996"), the District Court, Ernakulam partly set aside the award of the arbitral tribunal on the point of interest on delayed payment. The court inter alia held that the Blank Interest Clause provided for 0% rate of interest. This judgment of the District Court was upheld by the Kerala High Court in appeal.
Question before the Supreme Court of India:
Whether the Contractor was entitled to interest for delayed payment, in the face of a Blank Interest Clause?
The Supreme Court set aside the judgment Kerala High Court, holding:
The Blank Interest Clause did not imply an interest of 0%. The Supreme Court reasoned that there was no basis for the lower courts to come to such a finding. Imputing 0% rate of interest amounted to "rewriting the contract" and was beyond the terms of the contract. The absence of an express exclusion or ouster of interest on delayed payment, permitted the grant of award of interest as a compensatory or equitable measure.[2]
The award of interest in the absence of a clause granting interest, is governed by the principles laid down by the Constitution Bench of the Supreme Court in the case of Secretary, Irrigation Department, Government of Orissa & Ors. v G.C. Roy [(1992) 1 SCC 508] ("C. Roy"). This judgment inter alia held that the underlying principle guiding award of interest, is that interest payment is essentially compensatory in nature. The Supreme Court in the present judgment has held that the principles enunciated in Paragraph 43 of the G.C. Roy judgment, albeit passed in the context of the Arbitration Act, 1940, are applicable even in a proceeding under the Arbitration Act, 1996.[3]
The tribunal, on an appreciation of the evidence led before it, found that the Contractor's Correspondence was issued at the time of receiving payment in respect of an Interim Payment Certificate. This suggested that Contractors Correspondence was given under coercion. Further, the Contractor's continued requests for payment of interest before and after the Contractor's Correspondence suggested that there was no waiver / relinquishment of Contractor's right to claim interest. These were findings of fact. The tribunal, after a considering these facts, held that the Contractor's Correspondence did not amount to waiver of its claim for interest on delayed payments. The Supreme Court found no reason to overturn this reasoning. [4]
The Supreme Court however found the Awarded Interest to be excessive. Given that the agreement was silent on the point of rate of interest, but provided for payment of interest on delayed payment, the Supreme Court awarded simple interest at the rate of 8% on unpaid sums, as an equitable measure.[5]
Blank interest clauses and correspondence akin to Contractor's Correspondence (described above) are frequently found in construction contract disputes. Contractors, at the time of bidding, consciously (or unconsciously) do not fill in the rate of interest in the bid documents. Further, contractors often in the interest of enabling liquidity in the short-term, address correspondence waiving claims to interest on delayed payment. The above judgment provides some guidance for claiming interest on delayed payments, in such a situation.
It appears that the Employer did not adequately plead a case of waiver of interest payments in the first instance before the arbitral tribunal.[6] Further, the Employer does not appear to have led evidence as to the competitive edge that Contractor obtained at time of bidding, by leaving the Blank Interest Clause, blank.[7] The Employer may have obtained a different outcome, were its pleadings and evidence on these aspects complete.
A compensatory approach underlies the award of pendent lite interest. Employers are frequently burdened with interest awarded on a compounded basis, as was held by the tribunal, despite the absence of a clause entitling such award of interest. The Supreme Court circumscribes the limits to the award of interest in the absence of a clause entitling such award, to the principles laid down by the Supreme Court in the G.C. Roy judgment (cited supra) and the present judgment.
It is worth noting that the present judgment relies on case law interpreting Section 34 of the Arbitration Act, 1996, prior to the 2015 amendment.[8] This is (perhaps) because the challenge before the District Court, Ernakulam under Section 34 of the Arbitration Act, 1996 was filed prior to the amendment. This author has previously discussed the Supreme Court's interpretation of the effect of the 2015 amendment to Section 34 of the Arbitration Act, 1996, on this blog. This notwithstanding, the principles laid down in the present decision, will guide interpretation of Section 31 (7) of the Arbitration Act, 1996, in similar facts and circumstances.
† Zacarias Kanjirath Joseph is a Senior Associate, with the Dispute Resolution practice group, at Khaitan & Co, Mumbai. The views of the author in this article are personal and do not constitute legal / professional advice of Khaitan & Co. For any further queries or follow up please contact ergo@khaitanco.com.
[1] Civil Appeal No. 3454 of 2011, judgment dated 22 April 2021 ("Judgment")
[2] Paragraph 14 of the Judgment
[3] Paragraph 17 of the Judgment; Also see Reliance Cellulose Products Limited v ONGC Ltd. [(2018) 9 SCC 266]; Union of India v Bright Power Projects (India) (P) Ltd. [(2015) 9 SCC 695]; Section 31 (7) of the Arbitration Act, 1996.
[6] Paragraph 7 of the judgment
[8] ONGC Ltd. v Saw Pipes Ltd. [(2003) 5 SCC 705]
blank interst clauses
Why Indian Corporate Promoters Should Be Immune from Duties Towards Minority Shareholders
- Divya Khanwani & Suneel Kumar† This article seeks to analyze the reasons why India does not mandate fiduciary duties by promoters towards minority shareholders, even while the former are majority s
Examining the Validity of Arbitration Clauses in Standard Form of Contracts
-Aditya Singh† This article explores key areas wherein the validity of arbitration clauses in standard form contracts comes into contention in India. The first of them is Unilateral Arbitration Clause
Promoter to Person/s in Control: Much Ado About Nothing
-Dewesh Kumar Vinod† Introduction Recently, the Burman family, who has been buying into Everready since 2019, clarified that they intend to become the promoters of the Everready Industries. With Khait


text:
Advisories March 14, 2018
Unclaimed Property Advisory: Predicting the Possible "Perfect Storm" of Unclaimed Property Trends in 2018
Our Unclaimed Property Group looks ahead to 2018's perfect storm of holder- and state-initiated litigation and more.
Litigation – what happened and what's next
Adopting the Revised Uniform Unclaimed Property Act
The ABA's Model Unclaimed Property Act
Delaware's VDA program
This article was originally published in Keanotes on March 5, 2018.
The upcoming year promises to be action-packed and potentially unsettling for unclaimed property professionals – we will need to monitor, advocate, analyze and apply a slew of new rules and standards in order to effectively manage risk and optimize outcomes for our clients and employers.
In fact, 2018 is shaping up to be a "perfect storm" of holder- and state-initiated litigation, multistate and federal legislative initiatives, the onset of a new round of Delaware VDAs, and of course the continuing saga of more contract audit firms performing more compliance examinations for more states on more holders. Did we mention there would be "more"?
We provide the following summary of what is already on the radar for holders and their advisors in 2018.
Litigation – What Happened, and What's Next
Not to be outdone by 2016 and Temple-Inland, 2017 was a banner year for courts to issue substantive decisions involving unclaimed property issues. Several of these decisions will likely reverberate into 2018 and beyond. From our perspective, the most significant decisions in 2017 that are likely to be felt in 2018 were the Third Circuit's decisions in Plains All American Pipeline and Marathon Petroleum Corp., as well as the state court decision in the ongoing Delaware qui tam litigation and the New Jersey Bed Bath & Beyond case. We will briefly summarize these decisions and provide a view as to the next steps in each litigation, if any.
Plains All American Pipeline L.P. v. Cook, 866 F.3d 534 (3rd Cir. 2017)
What happened? In 2015, Plains All American Pipeline brought suit against Delaware in federal court seeking declaratory judgment that an audit proposed by the state and outsourced to Kelmar Associates was unconstitutional. Plains alleged that the proposed audit and components of the Delaware Escheats Law violated various provisions of the U.S. Constitution. The district court granted the state's motion to dismiss in 2016, holding that the case was not yet ripe because the state had not conducted its audit yet, and thus there were no actual injuries suffered by Plains.
On August 9, 2017, the Third Circuit reversed the dismissal of Plains' as-applied procedural due process claim (while affirming the district court's dismissal in all other respects). The Third Circuit found that such procedural due process claim was ripe for judicial review, holding that the claim satisfies the ripeness test based on the fact that Kelmar—a self-interested party—has been vested with responsibility for conducting the audit and had demanded documents. The court also held that a ruling on the merits "would be 'useful to the parties and other who could be affected' given Delaware's widespread use of private auditors." Accordingly, the court remanded to the district court for consideration of Plains' procedural due process claim on the merits.
What's next? Subsequent to the Third Circuit's remand, Plains notified the district court that it had elected to convert its audit into a Delaware VDA (more on this below). Thus, the parties stipulated to dismissal of the lawsuit. This means that the district court will not have an opportunity to decide the procedural due process claim on the merits, and holders are left with merely encouraging language by the Third Circuit regarding contingency fee auditors but no decision on which to rely. Nonetheless, given the window opened by the Third Circuit, it is possible that another holder will bring a procedural due process claim in the early stages of a Delaware audit being conducted by a contingency fee auditor.
Marathon Petroleum Corp. et al. v. Cook, 876 F.3d 481 (3rd Cir. 2017)
What happened? Through Kelmar, Delaware initiated an audit of Marathon Petroleum Corporation and Speedway LLC. As part of the audit, Kelmar requested "extensive detailed information" about Marathon and Speedway's affiliated entities, Marathon PrePaid Card LLC (MPC) and Speedway Prepaid Card LLC (SPC), which are Ohio domiciled. In response, Marathon and Speedway produced documents demonstrating that MPC and SPC were not Delaware-domiciled entities to show "that Delaware lacks standing to claim any unredeemed gift cards, even if any exist."
Kelmar responded in a letter stating that failing to comply with the request "will result in the Office [i.e., the State Escheator] referring the matter to the Attorney General's Office for consideration of enforcement action." Marathon and Speedway, along with their affiliated entities, filed a complaint in federal district court seeking a declaratory judgment and injunctive relief on federal preemption and Fourth Amendment grounds. The district court granted Delaware's motion to dismiss, holding that although the plaintiffs' claims were ripe, the federal common law rules established in Texas v. New Jersey do not apply to disputes between a state and a private party.
On December 4, 2017 the Third Circuit reversed and held that the federal common law rules established by the Supreme Court did in fact create a private right of action to challenge a state's unclaimed property audit and escheatment of unclaimed property. However, the court also held that Delaware "plainly" had the authority to conduct an unclaimed property audit of Marathon, Speedway, and MPC/SPC and "dig for information about who, a parent or a subsidiary, is the true holder of escheatable funds." The court also found that the Texas trilogy does not restrict the state to only looking within the four corners of the contracts in question in making this determination. Rather, the state may engage in an "alter ego" analysis, which involves a "fact-based inquiry into whether the formalities of corporate separates have been observed, not just in theory but in practice." However, the court made clear that an audit could be preempted where "a state's demands for information may become so obviously pretextual or insatiable" as to lead to conflict preemption. The Third Circuit concluded that such a preemption challenge was not yet ripe in this case, as Delaware had not formally demanded that the companies comply with the audit or risk facing penalties. Accordingly, the court vacated and remanded the district court's decision so that the district court could clarify that the plaintiffs' preemption claim was dismissed without prejudice.
What's next? On January 5, 2018, the district court acted on the Third Circuit's mandate and vacated its prior decision with respect to plaintiffs' federal preemption claim. The district court dismissed such claim without prejudice so that it could be "revived at a later date, if appropriate." Despite the dismissal, the Third Circuit's opinion is likely to play a crucial role in future audits by Delaware of gift card programs, as it establishes the contours of the state's authority to conduct an alter ego inquiry into parent-subsidiary relationships, including language that would support a preemption claim if the process turns from investigative to abusive. In addition, the Third Circuit appears to have settled with finality the debate regarding whether the federal common law rules apply in disputes between a private holder and a state.
Delaware qui tam (State ex rel. French v. Card Compliant, LLC, No. N13C-06-289 (Del. Super. Ct. April 21, 2017)
What happened? The ongoing Delaware qui tam litigation has been well covered over the last few years. Essentially, in early 2014, Delaware intervened in a false claims act case claiming that the use of a non-Delaware third party gift card entity to issue gift cards and assume the liabilities for preexisting cards effectively constituted fraud subject to treble damages and other penalties under the Delaware False Claims and Reporting Act (the "DFCRA").[1] On April 21, 2017, the Delaware superior court dismissed three of the defendants from the lawsuit based on the DCFRA's Administrative Proceedings Bar. The court found that the allegations in the qui tam were "substantially based upon allegations or transactions which are the subject of the State's previous or current audits or inquiries" of the defendants. In particular, two of the defendants had been under audit since before the qui tam suit was filed, and another defendant had enrolled in the state's VDA program prior to that date. The court subsequently refused to certify the relator's interlocutory appeal regarding the dismissal of the defendant that had participated in a prior Delaware VDA rather than an audit.
What's next? The case proceeds to trial in 2018, if the court does not rule in defendants' favor on its motion for summary judgment, which was argued in late 2017. In the interim, the Department of Finance continues to audit gift card and loyalty and rewards programs regardless of whether those instruments are issued by related-party entities or by third-parties such as Card Compliant.
BBB Value Services, Inc. / Bed Bath & Beyond Inc. v. Treasurer, State of New Jersey et al., No. A-2973-14T3/A-4880-14T3 (N.J. App. Div. Sept. 21, 2017)
What happened? Bed Bath & Beyond and its subsidiary, BBB Value Services, sued the state of New Jersey for a refund of merchandise return certificates that were reported to the state as unclaimed property between 2004 and 2012 after a three-year period of dormancy. BB&B contended among other things that the certificates were not escheatable prior to the July 2010 change in New Jersey's unclaimed property law to require the escheat of "stored value cards." In addition, for items issued in July 2010 forward, only 60% of the value of stored value cards was escheatable (and the dormancy period was five years rather than three years). The New Jersey Superior Court, Appellate Division, agreed with BB&B and ordered the Unclaimed Property Administration to provide BB&B with its refund. With respect to the pre-July 1, 2010 certificates, the court held that such certificates were not "property" under the New Jersey unclaimed property act, because they were not claims for the payment of money, consistent with the court's prior decision in Matter of Nov. 8 1996, Determination of State case (309 N.J. Super. 272 (1997)). With respect to the certificates issued on and after July 1, 2010, the court agreed that these items were stored value cards under the statute and thus were remitted early and at an incorrect amount (100% rather than 60%).
What's next? The New Jersey Unclaimed Property Administration has recently promulgated proposed regulations that would essentially formalize the court's decision. In particular, the proposed regulations provide that credits issued for merchandise returned without a receipt are "stored value cards," and that any such stored value cards that redeemable only for merchandise or services that were issued after July 1, 2010 are escheatable 5 years after last activity at 60% of unused balance. Stored value cards redeemable only for merchandise/services (including those issued for returned merchandise) issued prior to July 2010 are not escheatable.[2]
In addition, this coming year is sure to have its own set of momentous decisions. While it is somewhat difficult to predict, we would not be surprised if a case challenging the constitutionality of Delaware's estimation methodology found itself back in federal court in light of Temple-Inland. 2018 should also see resolution of the ongoing Delaware qui tam litigation – at least at the trial court level – as well as continuation of litigation pending in the Delaware Court of Chancery challenging Delaware's right under federal law to escheat foreign-owned property. See JLI Invest S.A. v. Cook, No. 112740-VCN (Del. Ch. filed July 9, 2015).
Additional States Will Likely Adopt the Revised Uniform Unclaimed Property Act
In 2017, three states—Illinois, Tennessee, and Utah—enacted a version of the Revised Uniform Unclaimed Property Act ("RUUPA"), which was finalized by the Uniform Law Commission in 2016. Overall, while there are some controversial and less holder-friendly aspects of RUUPA (as discussed below), the act represents an improvement over the previous 1995 Uniform Unclaimed Property Act in many ways, including section 610, which provides a statute of repose thus imparting greater certainty to holders that have been filing unclaimed property reports, and section 208, which provides dormancy standards for investment assets that trigger the running of a dormancy period on mail being returned as undeliverable to the owner, versus mere inactivity by the owner, who may have a buy-and-hold approach.
Although the RUUPA is billed as a uniform act, each state's enactment differed in some respects from the standard RUUPA provisions, and Illinois' enactment in particular represented the most drastic departure. This is in some ways attributable to the fact that there are several optional provisions included in RUUPA, such as the treatment of gift cards and merchandise return credits – it is entirely up to the discretion of the state whether to exempt or escheat these items.
However, even with respect to the non-optional provisions, states have found a way to depart from the uniformity and chart their own path. One notable example relates to Illinois' new statutory provision applicable to securities. Rather than adopt the RUUPA's relatively straightforward standard based on the receipt of returned mail, Illinois has concocted a complex, three-part standard that applies one of three potential dormancy periods. In particular, a security is presumed abandoned upon the earlier of (a) three years after receipt of returned mail, (b) five years after the last owner-generated activity, or (c) two years after the owner's confirmed death.
Illinois' adoption of RUUPA has also illustrated that not all aspects of the uniform law are an improvement over current state laws, as Illinois no longer recognizes a business-to-business ("B2B") exemption and has adopted a contractual anti-limitations provision, consistent with the standard RUUPA.[3] Other controversial aspects of RUUPA include its continued adherence to the third jurisdictional priority rule, express provision for the escheatment of foreign-owned property, recognition of the state's ability to use contingency fee auditors, and no restriction on the use of estimation, among other things.
We expect that an increasing number of states will adopt a version of RUUPA in 2018 to join Illinois, Tennessee, and Utah. Indeed, already in 2018 RUUPA legislation has been introduced or is pending in the District of Columbia (B22-0654), Maine (LD821, carried over from 2017), Minnesota (SF1035, introduced in 2017), Nebraska (LB141, carried over from 2017), Vermont (H311, introduced in 2017), and Washington (HB2486).
The ABA's Model Unclaimed Property Act Will Continue to Move Forward
At the same time that various states are moving forward with the adoption and enactment of RUUPA bills, the American Bar Association has completed several drafts of its own Unclaimed Property Model Act. The ABA's impetus for urging states to consider adoption of its Model Act as opposed to the RUUPA was to address several perceived infirmities with RUUPA and other state unclaimed property laws. According to the ABA's Unclaimed Property Subcommittee, these infirmities include, among other things:
Provisions that violate or likely violate the U.S. Constitution
Provisions that are inconsistent with the federal common law rules established the U.S. Supreme Court for determining when states have the right to escheat unclaimed property
Provisions that are inconsistent with the primary purpose of unclaimed property laws, which is to return missing property to its rightful owner
Provisions that do not adequately protect the rights of owners or holders of unclaimed property
Provisions that are needlessly complex or that are vague or ambiguous
Provisions that raise significant public policy concerns[4]
It is anticipated that a final version of the Model Act will be available sometime in 2018. Whether any state moves to adopt it in place of the RUUPA provisions remains to be seen, however.
Delaware VDA Program
As this article went to print, we learned that more than 150 holders had converted their Delaware audits into VDAs, pursuant to the statutory election that 2017's S.B. 13 created. These holders opted to convert their audits into VDAs in order to secure the VDA waiver of interest and penalties, as well to de-couple from contract audit firm methodologies and the challenges associated with defending many Delaware contract audits. This said, the Secretary of State and his VDA administration firms (Drinker, Biddle & Reath and the newly retained TL2Q LLC (an acronym for "To Look, To Question")) expect the standard VDA process to be followed – including the estimation of liability for Delaware-domiciled entities – and the holders' VDA submissions must be completed within a two-year timeline. In addition, holders that migrated the Delaware portion of their audits to the VDA program will still have to continue the audit process with regard to other audit-participating states.
We expect issues to arise in the VDA context associated with scoping (the audit firm's scoping determinations are controlling for VDA purposes, but not every scoping issue will be clearly delineated), the question whether an audit firm's decision to cease review of a property type is sufficient grounds to conclude that no liability exists for VDA purposes, and other "translational" questions. Given the fact that estimation is still being employed by both State agencies (Finance and State), we predict that some of these holders may eventually withdraw from the VDA in order to be in position to litigate the constitutional validity of the estimation method – if a holder completes the VDA program, it forfeits any right to challenge the VDA liability.
[1] Alston & Bird is representing several retailers that were named as defendants in this action.
[2] See N.J.A.C. 17:18-3.1 (proposed amendment) and 17:18-3.3 (proposed new rule). We will note that several aspects of the proposed regulations are problematic, including deviations from the statutory definitions of "holder" and "issuer of a stored value card," as well as language regarding promotional cards that is completely inconsistent with the statutory provision that cards for which no "direct monetary consideration" was paid are exempt.
[3] Unlike exemptions for gift cards and merchandise return credits, RUUPA does not include an option for states to provide for a B2B exemption. Rather, a comment to RUUPA indicates that any state "that wants to continue to exempt this type of property will need to include in this section its definition of a business-to-business relationship and specifically state in the definition of 'property' in paragraph 102(24)(C) that it does not include property arising from a business-to-business relationship." Tennessee is one state that has continued its B2B exemption in its new RUUPA-based law.
[4] See https://apps.americanbar.org/dch/committee.cfm?com=CL690014. Ethan Millar, a partner with Alston & Bird, chairs the Unclaimed Property Subcommittee.
John L. Coalson, Jr.
Email: john.coalson@alston.com
Kathleen S. Cornett
Email: kathleen.cornett@alston.com
Michael M. Giovannini
Email: michael.giovannini@alston.com
Matthew P. Hedstrom
Email: matt.hedstrom@alston.com
Kendall L. Houghton
Email: kendall.houghton@alston.com
Maryann H. Luongo
Email: maryann.luongo@alston.com
Ethan D. Millar
Email: ethan.millar@alston.com

redpajama_set_name: RedPajamaCommonCrawl


text:
<dom-module id="br-checkable">

<template>

    <template is="dom-if" if="{{checkbox}}">
      <input type="checkbox" id$="{{brId}}" on-click="_validateCheckbox" required$="{{required}}" checked$="{{checked}}">
    </template>

    <template is="dom-if" if="{{radio}}">
      <input type="radio" id$="{{brId}}" name$="{{brName}}" value$="{{brValue}}" on-click="_bindRadioValue" checked$="{{checked}}">
    </template>

    {{label}}
    <template is="dom-if" if="{{hasError}}">

{{errorMessage}}

    </template>

</template>

</dom-module>

redpajama_set_name: RedPajamaGithub


text:
/*---
{
    "custom": true
}
---*/

/*===
null
true
===*/

/* Test pointer formatting.  NULL pointers are formatted consistenly and in
 * a platform independent manner.  Non-NULL pointers don't have a fixed format
 * but test for an expected subset.
 */

function pointerTostringTest() {
    var ptr_null = Duktape.Pointer();
    var ptr_nonnull = Duktape.Pointer('dummy');
    var re_ptr_nonnull = /^[0-9a-fA-Fx:]+$/;

    print(ptr_null.toString());
    print(re_ptr_nonnull.test(ptr_nonnull.toString()));
}

try {
    pointerTostringTest();
} catch (e) {
    print(e);
}


text:
Science of Baby Sleep
My parents watched me become a first-time mom from thousands of miles away
By Cradlewise Staff
Raising a child takes a village—but what if you live across the country (or even across an ocean) from your village?
Parenting can be the most beautiful and exhausting journey you will ever experience in your life. And in this journey, having a pair of helping hands that can care for your little one can be a blessing. But when grandma and grandpa live thousands of miles away, it can be challenging to navigate through it alone. And getting enough sleep when you don't have help is necessary for first-time parents.
Pragnya (37), a first-time Asian-American mom and one of our community's earliest members, shares how she and her partner, Sriram (38), used Cradlewise's caregiver technology to stay connected with their families across nations. The couple also divulges how their parenting style with their daughter Maya (14 months) differs from their families.
Reconnecting with old friends
They met Radhika and Bharath at a farmers' market demo in the Bay Area. (Pragnya, Sri, and Bharath, a co-creator at Cradlewise, went to college together.)
"We have known Bharath since I guess we all were kids, like 16, 17-year olds," says Pragnya. After the couple found out they were pregnant in 2020, they learned that Cradlewise was launching in the U.S. and reconnected with them again.
Pragnya says, "And I think at that time, I was fairly early in my pregnancy, and I was just looking at all the products people say that the baby is going to need."
Rather than researching and buying a bassinet, crib, white noise machine, and baby monitor separately, Cradlewise's all-in-one aspect provided Pragnya with a holistic solution to her baby's needs. "The crib is like three products in one. And I don't have to invest in investigating each product that I have to buy. And it's the integrated experience that I really like," Pragnya says.
Maya's transition to the crib at eight weeks old
Pragnya's parents flew into Oakland for her delivery and stayed with her for eight months.
(Being one of the early adopters of Cradlewise during the pandemic, she didn't receive the crib until Maya was eight weeks old because of the global supply shortage.)
"We just put her down, and 15 seconds later, you can see her eyes open, and then you watch her doze off. So that felt like magic. I think my early impression was like, `Oh wow, this works.'"
Maya dozing off in Cradlewise for the first time
Pragnya elaborates, "The major value that we got was like those night wakings. What would happen as a new mom is every time Maya got up, I would get up as well and pat her down. And that is like every few minutes during the limited sleep time that I was getting and that time was interrupted by me just trying to be there for my baby. But once the crib came in, it allowed us to have more of a continuous night of sleep. So that was a relief in those early months and obviously a continuing source since we realized that the crib could do that."
Since her parents were with her, Pragnya was able to help troubleshoot and set the app up on their phones.
"My dad is OBSESSED with the app," says Pragnya. "He's the one who was primarily, completely using the caregiver functionality in a way to track the baby from when he woke up to when he went to sleep. He would use his entire day to monitor her while she was sleeping on the crib."
Addressing the accessibility pain points of Pragnya's dad helped the Cradlewise team improve the app's overall quality. "I think the app got really battle-tested, with someone who is not tech-savvy and but still really wanted to use it," Pragnya shares.
Worlds apart but close in spirit
Now that they are back in India, her parents continue to use the app. Since India is approximately 13.5 hours ahead of the West Coast in the U.S., Pragnya's morning is night time for her parents. And they make it an evening ritual to watch Maya's activities. "Sometimes we get complaints like, oh, she was up for a really long time, and you guys didn't pick her up." 😂
Maya with her doting grandparents
Pragnya's dad uses the app every day to give her sweet updates of what Maya does in her sleep and when she wakes up.
"Now that she's in a different room, I don't see her waking up but he's there online at 6 or 6:30 a.m. our time because he knows that's the time she wakes up. And it's kind of nice that he gets to see her that close, even if he's not nearby," says Pragnya.
"They have missed all the more fun milestones of her walking and talking for the first time live. So they feel like this is a way to get some of the moments back."
Different parenting styles
Pragnya reflects on how her experience parenting Maya differs from her own childhood, growing up in India. It's a perfect example of how raising a child is a unique and intimate experience for each parent. And how not one specific kind is the right way.
Pragnya and Sri with their adorable little munchkin
"We co-slept with our parents until we were five years old. And for my parents and in-laws, it was a really alien thing to put an eight-week-old baby in her own crib or bassinet," says Pragnya.
Pragnya and Sri also started sleep coaching Maya. "We didn't really attempt sleep coaching until my parents had left for India because we knew the idea just wouldn't go down well with them. The thought of letting Maya be by herself and protest for a little time before I went to pick her up, would have been hard for my parents to see. So, literally the week my parents left, we attempted to sleep coach her, and she was quite fine," says Pragnya.
Pragnya wanted Maya to have sound sleep practices, so sleep coaching was vital to her. "Whereas my mom was a full-time mom, so if she didn't sleep through the night, she could afford a couple of naps during the day or when my dad could watch me sleep. And we don't have that luxury with full-time demanding jobs."
There was also a difference in how Pragnya chose to feed Maya from her parent's generation. She breastfed and supplemented with formula milk since she felt it was the right choice for her baby. "I don't think there's a lot of education before the baby is here about how each feeding option is good enough, depending on the sources that you read. But with your family, they have opinions about breastfeeding, and it's hard not to let that implicit pressure cloud your judgment," says Pragnya.
And even from a community-building perspective, her mom's approach was different from hers. Pragnya sought advice and camaraderie in talking to her friends over Whatsapp. "Whereas with my mom and in-laws, it was a lot of neighbors and family who they lived with, and there were maids to help when my mom needed help," says Pragnya. "When I was struggling with Maya, I could leave her with my mom and take an afternoon to catch up on laundry or baking while she was here."
But Pragnya wanted to know how her mom did it all by herself. And when she did ask, she'd say, "I would do all my personal chores when the maid would come. So the maid would take care of you while I go take a shower, use the bathroom or fold the laundry."
Pragnya reflects on Maya's sleep journey for the last 14 months.
Maya all grown-up in her Cradlewise crib at 14 months
One thought at the back of her mind before getting her Cradlewise was whether her baby would become too dependent on the product to sleep. "Is this going to form a habit or dependency for my baby? And what if we are traveling? Would she be able to sleep somewhere else?"
But after using the crib for the past year, Pragnya quickly realized that the crib helps Maya stay asleep for longer stretches. "She has developed her own sense of how to fall asleep, and the crib doesn't necessarily interfere with that. But it gives her that nice environment in which she can continue to sleep if she's woken up," Pragnya shares.
"I think having good sleep practices is really helpful for both the parents and the baby. But it's especially a big sanity factor for parents and investing in anything that can assist you to put those good sleep practices in your kids is a good investment to me."
Cradlewise community
Is it okay to put baby to sleep without burping?
How can you foster a secure attachment in your baby?
11-month-old baby sleep guide


Hi friends! Today i have a quick review on the Michael Todd Soniclear cleaning system. I have not used other brands so I have nothing to compare it to, but I will say that I love this one.
In this kit, you get the charging station with cord and the Soniclear system with 2 brush heads - one for face and the other for body. I think that's really neat because you can really multitask with it.
The brush heads are so incredibly soft so you don't have to worry about painful scratching as it cleans your face. The vibrations are what took me a while to get used to. It's a little intense if you're not used to it, but it won't take you long to really enjoy how well it cleans. I used my regular gel cleanser with this and it worked fine. It lathers up real nice and I do feel like I get a good, deep clean. Just make sure to thoroughly rinse off your brush and dry it after each use.
Overall, I'd say I had a very pleasant experience with this brush cleaning system. It really got down into my pores and flushed away all the dirt - a lot better than just my hands could do.
Looks like a nice tool.


text:
Stories in the News onnew york times
The New York Times R+D team dives into photogrammetry
By Antonio Pacheco
Visual journalists are always searching for new technologies to help them capture more detail and get the news out faster. But they've operated within the constraints of a camera lens, a two-hundred-year-old technology that gives readers a single, 2D representation of an event.
What if we could break free of the rectangle and let readers experience a setting the same way the journalist did? Instead of just looking at a photo of a space, what if we could move through it? — The New York Times
The New York Times shares its research using photogrammetry for journalistic purposes. Dovetailing on the sophisticated and exacting approaches employed by investigative groups like Forensic Architecture to reconstruct contested and often tragic events, the NYT team instead harnesses the power of...	View full entry
photogrammetrynew york times3d scanningjournalismdigital storytelling
Do shipping containers really make for great architecture?
Sep 16, '19 8:00 AM EST
A month ago, Dr. Richard J. Williams of the University of Edinburgh expressed his views of the over-hyped shipping container design fad in The New York Times. Describing the fatal flaw in logic widely used to promote the use of shipping containers in recent architectural proposals, Williams...	View full entry
shipping containershipping containersnew york times
New York Times' latest Op-Doc takes a dive into the sewage systems of Mexico City
By Mackenzie Goldberg
The New York Times' latest Op-Doc—part of their series of short, interactive, and virtual reality documentaries—profiles Julio César Cú Cámara, whose job it is to dive into the sewers and water treatment plants of Mexico City. For the past 36 years, Cámara has been a sewage diver...	View full entry
sewagemexico citynew york timesdirty jobswatersustainable developmentcity government
The New York Times uses neural network to map every building in the U.S.
The New York Times has made a map of every building in the United States. Using a neural network to analyze satellite imagery, the team's program then traced the shape of buildings across the country. Users can enter a city, zip code, or address, and explore these areas in detail. It's pretty...	View full entry
new york timesgeographymapsbuildingscities
Meet British architects Chan + Eayrs, who inhabit their projects as they renovate them
By Justine Testado
Sep 17, '18 6:13 PM EST
By collapsing the roles of architect, developer and interior designer, they make spaces with an unparalleled intimacy and a highly refined sense of place. "When we choose a project, it's not just a project," says Chan Eayrs. "It's where we choose to spend two to three years of our life, every day, touching and feeling it, living it." — The New York Times
The New York Times profiles British architect couple Zoe Chan Eayrs and Merlin Eayrs, whose highly dedicated design process — in which they live in whatever project they are currently renovating through completion — has resulted in a refreshing portfolio of unique living spaces that "feel as...	View full entry
creative processyoung architectemerging architectsuknew york timesbritish architectsinterior design
The opposite job of an architect is a slaughterer and meat packer
By Hope Daley
Dec 12, '17 4:22 PM EST
What if you could start over and take the career path most different from the one you're on? Let us help you.
The Labor Department keeps detailed and at times delightfully odd records on the skills and tasks required for each job. Some of them are physical: trunk strength, speed of limb movement, the ability to stay upright. Others are more knowledge-based: economics and accounting, physics, programming. Together, they capture the essence of what makes a job distinctive. — The New York Times
The New York Times has used job-specific records to find the polar opposite of each job. Determining skills used either the most or the least, this tool has helped in understanding more clearly what it is people actually do at their job beyond the initial understanding of the title or position. ...	View full entry
employmentjob marketjobsjob searchnew york times
Climb Heatherwick's $150 Million Stairway in the Times' Daily 360
Everyday, The New York Times brings its readers a new 360-degree video with their series, The Daily 360. In one of their recent videos for the project, Times journalists give us a behind the scenes look at Thomas Heatherwick's ongoing public project in New York City's Hudson Yards...	View full entry
new york timesdaily 360virtual realitythomas heatherwickvessel
The New York Times compiles a glossary of climate change-adaptive building strategies
By Nicholas Korody
Apr 5, '17 12:46 PM EST
Communities across the country are confronting the mounting evidence of climate change and developing means of fortifying buildings and infrastructure against rising sea levels and ever-more-intense storms, even as the Trump administration reverses policies premised on climate change.
"We're not spending money on that anymore," Mick Mulvaney, the director of the Office of Management and Budget, told reporters in Washington recently. "We consider that to be a waste of your money." — The New York Times
"People who live, work or build in flood plains like West Chelsea and elsewhere say they cannot be so dismissive. They are spending money."The New York Times has compiled case studies as well as an associated glossary of steps taken in New York City and its environs to help shore up the built...	View full entry
climate changesea level risenew york cityfloodingrelocation or adaptationnew york times
Christopher Gray, wry architecture author/researcher, dies at age 66
By Julia Ingalls
Mar 14, '17 12:48 PM EST
Rooting himself less in a strictly academic tradition and more in an observed, on-the-street context, architecture author and researcher Christopher Gray catalogued what he considered to be beautiful and surprising for The New York Times from 1987 to 2014 in his "Streetscapes" column. He also...	View full entry
writerarchitectural criticsnew york timesarchitectural criticismarchitectural historychristopher gray
Architects Alejandro Aravena and Trix & Robert Haussmann included on NYT's 2016 Creative Geniuses list
From their studios, ateliers, film sets and kitchens — and even the White House — these are the people whose inventive spirits shaped the conversation this year. — nytimes.com
It certainly was an eventful career year for Alejandro Aravena (Pritzker Prize, Venice Biennale, et al.), and the ambitious Chilean's cultural footprint can be traced throughout a handful of our Archinect 2016 Year In Review posts:The top prize-winning architects of 2016How starchitect culture...	View full entry
new york timesalejandro aravenatrix and robert haussmann2016creative geniuses listartculture
Oana Stanescu, the architect behind Kanye's volcano, talks to NY Times about pushing design boundaries via pop culture
Aug 6, '15 6:45 PM EST
For a serious architect who has designed public housing in Dallas and a bridge in Slovenia, it may come as a surprise that Oana Stanescu's best-known work is a 50-foot-high volcano that Kanye West ascended onstage during his grandiose Yeezus tour...Along with Dong-Ping Wong, her partner in the West Village architectural firm Family, Ms. Stanescu is making a name for herself in design circles for her ability to merge pop culture with utilitarian design. — The New York Times
For more Family on Archinect, you can check out Oana's archived Archinect School Blog, the +POOL, and the firm's other cool projects.	View full entry
familynew york timesoana stanescupop culturekanye westculture
Archinect's critical round-up: the week's best architectural critiques so far
Over at the Los Angeles Times, Christopher Hawthorne eloquently pans the new addition to the 405 freeway, noting that "The expanded 405 might be the first L.A. freeway project to look haggard and disjointed the day it opened." His review comes at a time when infrastructure, especially in...	View full entry
christopher hawthornenew york timesthomas heatherwick405 freewayhudson yardsrelated companypublic realminfrastructure
The New York Times reviews MoMA exhibit, Latin America in Construction: Architecture 1955-1980
By Joachim Perez
May 1, '15 11:12 AM EST
The exhibition recalls an earlier era when architects there believed that social challenges should be tackled by design, that humane societies deserved beautiful new forms, and progressive development put faith in art, nature and the resilience of ordinary people. — Michael Kimmelman, New York Times
Michael Kimmelman of The New York Times wrote a review on the recent MoMA exhibit, 'Latin America in Construction: Architecture 1955-1980'. The exhibit highlights the work of Oscar Niemeyer, Lina Bo Bardi, Eladio Dieste, Rogelio Salmona and others who helped define Latin American modern...	View full entry
latin americamuseum of modern artmomanew york citynew york timesuniversity of miamiexhibitionsexhibit
At Auschwitz-Birkenau, Preserving a Site and a Ghastly Inventory
By b3tadine[sutures]
The strategy, she said, is "minimum intervention." The point is to preserve the objects and buildings, not beautify them. Every year, as more survivors die, the work becomes more important. "Within 20 years, there will be only these objects speaking for this place," she said. — New York Times
new york timesauschwitz-birkenauconservation
NY exhibitions reflect on Latin American midcentury architecture + design
Until the advent of cable television and then the Internet, Latin Americans, creators and consumers alike, were often more aware of trends in Europe and the United States than in nations neighboring theirs: Whatever similarities in style that emerged regionally were largely the result of discrete, parallel responses to the challenges of urbanization, poverty and the need to somehow integrate modernity and tradition. — The New York Times
Midcentury architecture and design from the Latin America region seems to be a trend in recent exhibitions in MoMA, MAD, and Americas Society in New York. New York Times writer Larry Rohter compares and contrasts the exhibitions, which shed light on the all-too-familiar tension of integrating...	View full entry
latin americamodernismexhibitionsculturenew york timesretrospectiveglobalization


text:
Articolo in rivista, Nota a sentenza
Ozone and energy fluxes have been measured using the eddy covariance technique, from June to December 2004 in Castelporziano near Rome (Italy), and compared to similar measurements made in the previous year. The studied ecosystem consisted in a typical Mediterranean Holm oak forest. Stomatal fluxes have been calculated using the resistance analogy and by inverting the Penmann-Monteith equation. Results showed that the average stomatal contribution accounts for 42,6% of the total fluxes. Non-stomatal deposition proved to be enhanced by increasing leaf wetness and air humidity during the autumnal months. From a comparison of the two years, it can be inferred that water supply is the most important limiting factor for ozone uptake and that prolonged droughts alter significantly the stomatal conductance, even two months after the soil water content is replenished. Ozone exposure, expressed as AOT40, behaves similarly to the cumulated stomatal flux in dry conditions whereas a different behaviour for the two indexes appears in wet autumnal conditions. A difference also occurs between the two years.
Gerosa, G. A., Finco, A., Mereu, S., Vitale, M., Manes, F., Ballarin Denti, A. A., Comparison of seasonal variations of ozone exposure and fluxes in a Mediterranean Holm oak forest between the exceptionally dry 2003 and the following year, <<ENVIRONMENTAL POLLUTION>>, 2009; 157 (5): 1737-1744. [doi:10.1016/j.envpol.2007.11.025] [http://hdl.handle.net/10807/29764]
Comparison of seasonal variations of ozone exposure and fluxes in a Mediterranean Holm oak forest between the exceptionally dry 2003 and the following year
Gerosa, Giacomo Alessandro;Finco, Angelo;Mereu, Simone;Vitale, Marcello;Manes, Fausto;Ballarin Denti, Antonio Angelo
https://dx.doi.org/10.1016/j.envpol.2007.11.025


"The preservation of animal and plant life, and of the general beauty of Nature, is one of the foremost duties of the men and women of to-day. It is an imperative duty, because it must be performed at once, for otherwise it will be too late. Every possible means of preservation,—sentimental, educational and legislative,—must be employed." William T. Hornaday Director New York Zoological Park, Author American Natural History President American Bison Authority.
What is the one thing that you could do for wildlife today?
What are some things you could do for wildlife today?
Parents take your children out to explore, and be creative in nature. Learn the name of a new flower.
Teachers grow gardens, and plant trees with classes of children, and conduct field trips to the zoo to learn "It is your Duty to protect all harmless wild things, and you must do it" ~Hornaday.
Science subjects embrace local nature, students learning the study of nature, the name of the flora and fauna in their neighbourhood.
Art classes seek to draw from nature, learning the botanical structure of plants, seeds, flowers and leaves.
Local and family celebration of World Wildlife Day, World Migratory Bird Day with hands on nature activities to protect wildlife and birds.
Provincial and national efforts to observe Arbor Day, Earth Day, and other special days with events and celebrations.
Boys and girls clubs, scouts, girl guides, brownies, and youth groups celebrate tree planting ceremonies, and nature watch activities.
A trip to the zoo, the park, the afforestation area to devote time for the observation and preservation of flora and fauna.
Clean up your local environment, your school yard, street, or park.
Do you know the local animals and plants on the endangered species list, and what they look like? Do you know which plants are necessary to which animal?
Have you planted a pollinater's garden or a native flower garden bed?
What can you think of? Can you add more to the list?
The fate of wildlife, hangs today by a very delicate thread.
"Will the millions of men commanded by General Apathy now arouse, before it is too late to act?
Will the true sportsmen rise up, and do their duty, bravely and unselfishly?
Will the people with wealth to give away do their duty toward wild life and humanity, fairly and generously?
Will the zoologists awake, leave their tables in their stone palaces of peace, and come out to the firing-line?
Will the lawmakers heed the handwriting on the wall, and make laws that represent the full discharge of their duty toward wild life and humanity?
Will the editors beat the alarm-gong, early and late, in season and out of season, until the people awake?
Should you wish to help protect / enhance the afforestation areas, please contact the City of Saskatoon, Corporate Revenue Division, 222 3rd Ave N, Saskatoon, SK S7K 0J5…to support the afforestation area with your donation please state that your donation should support the Richard St. Barbe Baker Afforestation Area, or the George Genereux Urban Regional Park, or both afforestation areas. Please and thank you! Your donation is greatly appreciated.
Simply adorable… for us to enjoy these animals! 🙂 Happy World Wildlife Day!
Happy Wildlife Day to you too!!


text:
Donald Finnaeus Mayo
Novelist, author of "Francesca" and "The Insider's Guide to Betrayal"
Tag Archives: Dili
War is over… not quite yet
You hear it everywhere as we approach this time of year – in the shopping malls, on the radio, the optimistic crooning from John and Yoko's classic: "War is over, if you want it". Seems like we don't want it, or not enough anyway.
I don't think there's been a time in recorded history when someone, somewhere hasn't been fighting, killing someone else. Some months ago the British Army thought 2015 might be the first year in a century when it wouldn't be involved in a conflict somewhere. With events in Syria, Iraq and Iran unfolding as they are, that hope looks less likely by the day.
Image courtesy of soldiersmediac
It's easy to get war fatigue, to throw up one's hands in despair and tune out of it all. For me, it's the civilians caught up in war, especially the children, who haunt me most. Here's an extract from my novel Francesca, shortly after the heroine's home town of Dili, capital of East Timor, was invaded by the Indonesian army just before Christmas 1975…
"Checking for soldiers, she set off along the street. With her awkward gait and instinctive caution, progress was slow. She took the back streets, avoiding the main thoroughfares where troops were most likely to be combing through houses. Halfway down the street adjacent to hers a kampong dog, its curled tail high up in the air, stood in the middle of the road gorging on a corpse whose entrails had been ripped open by machine gun fire. Pieces of flesh flicked out from the dog's greedy mouth and when it glanced up at her she saw its entire snout was covered in bright red gore. The dog stared her down, reluctant to abandon such a feast. Enraged, Francesca reached down, picked up a stone from the gutter and hurled it at the animal as hard as she could. The stone struck the beast square on the shoulders and it jumped with a sharp yelp, scurrying away from the corpse as Francesca reached for another stone. It was a futile symbolic gesture, she knew, the dog would return to finish off its grisly meal the moment she was gone, but she had needed to do something to take a stand against the horror unfolding all around her.
She continued her shuffle in a broad northerly direction through the routes she knew so well. There was an eerie quiet to these normally bustling back alley ways and side streets. Shops were either boarded up or spilt open, their contents looted by the invaders who could only carry so much and had discarded the rest. Where were all the inhabitants? The machine guns had kept up their sporadic firing ever since she had left her house, presumably shooting at someone. She wanted to bang on the shutters to see if anyone was inside, to find out what was going on, but she knew she couldn't.
Eventually, she reached an alleyway that led out onto the harbour and she stopped, her heart racing in terror. An Indonesian platoon was directly in front of her, less than fifty yards away, marching at double time to the command of an NCO jogging along at the side. Rifles were shouldered, as the troops struggled to keep up the pace whilst hauling their bulky packs. Darting under a set of wooden steps, Francesca waited for the soldiers to pass, convinced she would be spotted. She tucked her head under her arms and crouched herself into a ball, desperately making herself as inconspicuous as possible, even though the stance was agony for her injured body. She heard the steady rhythm of the platoon as it pounded by almost on top of her, two dozen pairs of rubber soled boots slamming down on the dusty road overlaid by the metallic rattle of loose magazines and mess tins. So this was what invasion sounded like, this was what it meant to be embraced into the fold of mother Indonesia. Her thoughts turned to her own mother, and tears welled up from her heart. Perhaps she was looking over Francesca right now, guiding her hand, willing her to make good decisions, seeing her through to safety. Out of habit, she fingered the tiny silver crucifix around her neck, astonished now she thought of it that none of the soldiers had seen to rip it from her throat. She would keep it as a talisman, the only touchstone she had in a world gone crazy."
Excerpt copyright 2014 Donald Finnaeus Mayo
You can buy a copy of Francesca here
This entry was posted in Uncategorized and tagged Amnesty International, Betimes Books, Borneo, Children in War, Christmas, Dili, Donald Finneaus Mayo, East Timor, Francesca, Give Peace a Chance, Indonesia, John Lennon, Timor Leste, Vietnam War, Yoko Ono on September 12, 2014 by Donald Finnaeus Mayo.
Character Sketches 1: Francesca, the Timorese survivor
Over the next few posts, I'll be outlining some background to the principal characters in Francesca, starting naturally with the woman after whom the novel is named.
Photo by Riza
Francesca is seventeen years old when the novel begins, on the eve of the Indonesian invasion of East Timor. Whilst her experience of life has hitherto been rather narrow and sheltered, she has benefited from a western style education in one of the Catholic schools run by Portuguese missionaries in Dili.
This places her amongst the small educated Timorese middle class of the time. Her father, who Francesca adores, works as a technician in Dili's main radio station. As such, he is particularly well placed to discern which way the political winds are blowing, which makes it all the more of a let-down when his predictions turn out to be so hopelessly inaccurate.
Aside from her father, the other key influence in Francesca's life are the nuns who educated her. They left her with a faith that is stretched to breaking point but somehow endures. More importantly, at least in the short term, they have instilled in her a love of languages. It is this passion, unusual for someone in her position, that enables her not only to stay alive but to build a new life for herself when she ends up in Indonesian Borneo.
By the time she arrives there she has seen far more than a girl her age should ever see. Her experiences have left their mark in an aloofness and a distance, which people find puzzling; they are drawn into unravelling its mysteries, with little success. She has erected a wall around herself, and whilst she has stared utter despair in the face, by nature she is neither cynical nor ruthless. Indeed, she is perplexed and on occasion dismayed by the force of her instinct to survive.
This aura, combined with her intelligence and natural good looks, attracts the attention of rich and powerful men; her saving grace is that something within her compels them to want to help her rather than exploit her.
Coming up next… Benny Surikano.
This entry was posted in Uncategorized and tagged Dili, East Timor, Francesca, Indonesian invasion of East Timor, Kalimantan, Portuguese Timor, Timor, Timor Leste on July 23, 2013 by Donald Finnaeus Mayo.
Click to Order:
On journalism, modern history and inspiration….
#spycops – the tawdry facts that couldn't hold together as fiction
Union Club launch for Insider's Guide to Betrayal
John Pilger wins award for reporting on Timor-Leste


University High's smothering defense gave Happy Valley little chance Monday night in their non-conference basketball game. The Bucs' red-hot shooting from 3-point range gave the Warriors no chance.
Holding the Warriors to just 21 points through three quarters and hitting 15 of 31 shots behind the 3-point arc, the Bucs romped to a 69-44 win at Brooks Gym.
Marshall Fleenor led the way with 20 points, 15 of them coming on 3-point goals.
"We had good execution coming out," Fleenor said. "We moved ball well and coming off the screens, we got open shots. If the shots weren't there, we found the open man."
Kaleb Meredith totaled a dozen points, while Colin Daniel and Charlie Vargo each ended with 11.
University High was ahead 17-2 early in the second quarter and led by double digits the rest of the way. It was 32-14 at halftime and 46-21 by the end of the third quarter.
"Obviously, very pleased with the defensive effort. I thought our guys were dialed in from the opening tip," University High coach Justin Penley said. "We got off to a good start and although we weren't fluid on offense early, we were more efficient as the game went on."
Bryce Carter paced Happy Valley with 13 points and Noah Stevens was next with seven points. Despite the outcome, all 11 Happy Valley players scored.
The Lady Warriors held the Lady Bucs to just three points in the first quarter and two in the third to win their 10th straight game.
Happy Valley did particularly well with a 2-1-2 full court zone trap, forcing a slew of second-half turnovers.
"I think the last time we played them, we had a good defensive third quarter as well," Lady Warriors coach Thomas Gouge said. "We got after them a little bit with the traps and the interceptors did a good job, getting some steals."
Shalyn Whitson was the only player for either team in double figures, recording 11 points. Bailey Ball scored eight and Olivia Absher finished with six for Happy Valley.
"I'm proud of how we're playing," Gouge said. "Sometimes, you have to win ugly. We won ugly on the road and we'll take it."
Mauri Johnson led University High with eight points and Sarah Fisher had five.


Alibaba offers 16,177 st37 hollow section square steel pipe products. About 99% of these are steel pipes, 1% are stainless steel pipes. A wide variety of st37 hollow section square steel pipe options are available to you, such as a53(a,b), 10#, and 20#.
st37 Square hollow section steel tube weight manufacturer in China ,we are professional st37 Square hollow section steel tube weight suppliers and distributor ,if you need st37 Square hollow section steel tube weight price and application ,please contact us.
Weight Square Hollow Steel Tube Weight Square Hollow Steel Tube . 1.Brief Introduction of Company: Our company focuses on the usage, development and research of square and rectangular tubes over the passed 20 years.
Hollow Section, Square Pipe, Steel Square Tube manufacturer / supplier in China, offering 100% Actual Weight Price Iron Steel Square Tube, Mill Finished Surface Treatment and up to 500X500mm Dimension Square and Rectangular Tubes, St37 Black Square Iron Pipe and so on.
Hot rolled steel plate factory in China offer hot rolled ms square pipe weight chart erw tube hot rolled hot rolled ms square pipe weight chart erw tube steel plate ,If you want buy hot rolled ms square pipe weight chart erw tube price,contact sales4@bebonchina at any time.
Square Pipe Weight Calculator / Square Pipe Weight Chart, Weight Calculator/ Carbon Square Pipe Weight Calculator / Square Pipe Weight Calculator Free Download / Square Tube stainless steel / MS Square Tube / Square Tube cast iron / Square Tube mild steel. ... Square Steel Hollow Section (3.45 Kg/m) would weigh (4.2 x 3.45) 14.49 Kg's Total.
Square steel tube (or we can name it as square hollow section or square steel pipe ) comes in different sizes, specifications and wall thicknesses. Its uniformity makes it predictable to use and visually appealing. It has a high weight-to-strength ratio. Compared to round steel pipe, square steel tube is more efficient, stronger and durable.
Metal Pipe, pipe tube, 1" Pipe manufacturer / supplier in China, offering square pipe retangular hollow section tube Metal Pipe Tube, Heat Insulated Fireproof Expanded Polystyrene XPS Panel, Stainless Steel Wind Roof Ventilator and so on.
offer astm a36 steel square tube hollow section . astm a36 steel square tube hollow section manufacturer in China ,we are professional astm a36 steel square tube hollow section suppliers and distributor ,if you need astm a36 steel square tube hollow section price and application ,please contact us.


text:
Justia Forms Business Contracts SusGlobal Energy Corp. Minutes of Settlement by and between SusGlobal Energy Corp.
Minutes of Settlement by and between SusGlobal Energy Corp. and Gerald Hamaliuk
Contract Categories: Business Operations - Settlement Agreements
EX-10.1 2 exhibit10-1.htm EXHIBIT 10.1 SusGlobal Energy Corp.: Exhibit 10.1 - Filed by newsfilecorp.com
Court File No. CV-20-00648134-0000
SUPERIOR COURT OF JUSTICE
B E T W E E N:
SUSGLOBAL ENERGY CORP., SUSGLOBAL ENERGY CANADA CORP.
Plaintiffs
GERALD HAMALIUK, LANDFILL GAS CANADA LTD.
MINUTES OF SETTLEMENT
The parties agree to settle this proceeding on the following terms:
1. The plaintiffs, SusGlobal Energy Corp. and SusGlobal Energy Canada Corp. (together, "SusGlobal"), shall pay to the defendants a total settlement amount of CAD $347,500, payable as follows: (i) the sum of two hundred and fifty thousand Canadian dollars (CAD $250,000) plus HST in the amount of CAD $32,500, payable to the defendant Landfill Gas Canada Ltd. ("LFGC"); and (ii) costs of the motion and action in the amount of sixty-five thousand Canadian dollars (CAD $65,000) all-inclusive, payable to the defendant Gerald Hamaliuk (the "Settlement Amounts");
2. An invoice with an HST number for CAD $250,000 plus HST in the amount of CAD $32,500, for a total amount of CAD $282,500, will be provided by LFGC to the plaintiffs indicating that the invoice replaces all previous unpaid invoices in the form as attached hereto as Schedule "A";
3. The defendants will return to the plaintiffs the 2,011,500 physical share certificates for SusGlobal shares held by the defendants (the "Share Certificates"), scanned copies of which are attached hereto as Schedule "B";
4. The Settlement Amounts will be paid by the plaintiffs to the defendants by way of certified funds or wire transfer payable to "Cassels Brock and Blackwell LLP, in trust" (the "Bank Draft");
5. The defendants will surrender and release any claim to or interest in the 3,300,000 SusGlobal shares pledged by them as security to PACE, and the defendants will execute a document evidencing the surrender and release of any such claim or interest in the 3,300,000 shares in the form attached hereto as Schedule "C". For the sake of clarity, the defendants also surrender and release any and all claim to and interest in the 2,011,500 shares referred to in paragraph 3 above;
6. The parties will execute a full and final mutual release that will include a mutual non-disparagement provision in the form attached hereto as Schedule "D";
7. The defendants will sign a letter addressed to the plaintiffs and the Securities and Exchange Commission indicating that they withdraw the SEC whistle-blower complaint, to be held by the plaintiffs, in the form attached hereto as Schedule "E";
8. Counsel to the defendants agree to forthwith deliver the physical Share Certificates referenced in paragraph 3 above to counsel for the plaintiffs, to be held by counsel for the plaintiffs in escrow until the Settlement Payment clear the bank of counsel for the defendants. In addition, counsel to the parties agree to forthwith exchange electronically signed copies of these minutes of Settlement and all documents attached hereto as Schedules, following which the transfer of the Settlement payment to counsel for the defendants will take place. Thereafter, if and as may be required, a physical exchange of any or all original settlement documents referred to herein can be arranged between counsel for the parties; and
9. The claim and counterclaim will be dismissed without costs.
DATED this 8th day of December, 2021
SUSGLOBAL ENERGY CORP.
/s/ Marc Hazout
(I have authority to bind the corporation)
SUSGLOBAL ENERGY CANADA CORP.
/s/ Gerald Hamaliuk
Gerald Hamaliuk
LANDFILL GAS CANADA LTD.


Join the MCI Train the Trainer program!
This unique program has been anchored with the wonderful learnings and insights we have gathered over the last 27 years training a variety of teams across a very broad range of different industry sectors.
This is your opportunity to share in the secret formula that has ensured our sessions are memorable, enjoyable, and at the same time make the learning 'stick'. You will learn about the latest creative learning techniques, and how to bring magic to your training sessions creating a change in the behaviour and attitude of your audience.
We want to teach you how to deliver training sessions that ROCK!
Identify audience needs: Take a brief on what training is required by your participants so that they are more productive and able to perform at high levels.
Increase Trainer's Awareness: In understanding communication and learning styles of learners and build skills to maximise impact of learning.
Structure a Magic session: More energisers, ice breaking, and closing activities and 'chunking' learning sessions to make the learning 'stick'.
Beat the 'forgetting curve': Master an understanding of the key principles of adult learning so that you keep your training relevant and useful.
Use Creative Learning Techniques: Keep your participants fully engaged with the content and the key messages.
Build confidence: Through practice develop your own 'Trainer's presence' by understanding your delivery style of energising training sessions.
Understanding adult learning principles: Gather insights about "engagement". What engages us and how to maintain and sustain it.
Uncover Learning Gaps: Explore what are the "right questions" to build your understanding of your groups needs and skill or knowledge gaps.
Creative session planning: How to craft a meaningful session that will make a difference to their skills gaps.
Team Activities: What are they and how they are useful for different messages and situations.
'Spectrum of evaluation': The value of review and evaluation from training, knowledge retention, positive behavioural change to organisational results.
Expanding your presentation skills: Learn how to sharpen your delivery style (body language and vocal dynamics).
Session plan review: Preparation for Day 2: Outlining learning objectives, audience profiling, Learner's needs, Planning activities.
Review of Day 1: What have we learnt and how will we apply it in our own context?
Dynamics of Inclusivity: Creating a positive learning environment in an increasingly diverse workforce.
Tips for turning around the 'reluctant learner': Deal with challenging participants so that they become more engaged.
Practice and build strong presentation skills: Expand the power of your voice, strong body language, and presence.


Crewmembers aboard two merchant ships responded to the Coast Guard's call for assistance to medevac a Canadian man reportedly experiencing signs of a heart attack aboard his sailboat 170 miles southwest of Bermuda on Thanksgiving Day.
Watchstanders at the Coast Guard Rescue Coordination Center in Norfolk, Va., coordinated the rescue using the Automated Mutual-Assistance Vessel Rescue System, or AMVER, after receiving notification from Nicole Gaudreault, an amateur radio operator from Montreal.
The wife of the man experiencing the symptoms initially called Gaudreault stating she was a nurse and believed her husband needed to be medevaced. She also said they were aboard the 36-foot sailboat Argo V and were en route to St. Martin.


Get The Best Ideas of Home Interior Design about mazda 6 reliability%0a mazda 6 reliability%0a There are a lot of inspiration about home interior and house decorating ideas out there. But we try to give you some of our best photos gallery collection regarding mazda 6 reliability%0a that we get from various source. Hope you enjoy!


The Lincoln Stars will face off against the top two teams in the USHL western conference this weekend when they take on the Sioux City Musketeers at home on Friday, and the Buccaneers in Des Moines, IA on Saturday.
The Stars enter the weekend with a record or 3-5-1 (7 points) and are in last place in the USHL western conference. Click here to view the current league standings.
Lincoln's first opponent this weekend, the Sioux City Musketeers, sport a record of 8-3-1 (17 points) and are in first place in the USHL western conference. The Muskies have the 2nd best record in the entire USHL, behind only the eastern conference leading Cedar Rapids Roughriders (9-1-0).
This will be the third time the Stars and Muskies will face another this season. The Stars are 1-1-0 against Sioux City in those previous two games, including a 4-3 OT shootout victory at the IceBox on 10/3/14. In their last meeting on 10/25/14 in Sioux City, the Stars lost by a score of 5-3. Since winning that game against the Stars on 10/25, the Muskies are 0-2-0 and have been outscored 9-3.
Lincoln's second opponent this weekend, the Des Moines Buccaneers, are the surprise team of the USHL, by far. They currently occupy second place in the USHL western conference with a record of 7-3-1 (15 points). This will be the first of eight meetings between the two clubs. These same two teams will play each other next Tuesday, October 11th at the IceBox.
Coming into this season, the Bucs hired a new head coach (Dave Allison) after a disappointing 2013-14 season in which they finished in sixth place in the west, and out of the playoffs for the seventh consecutive season.
Many hockey pundits who follow the USHL expected this Bucs team to struggle out of the gate. When I saw them play at the 2014 USHL Fall Classic this past September in Sioux City, they looked like hot garbage. Seriously, this team looked incredibly bad. So bad, they gave up 16 goals against in only two games played at the Fall Classic. I had them pegged for last place in the western conference, without a doubt.
However, once the games actually counted, the Bucs turned it around quickly. In their first seven games of the 2014-15 regular season, Des Moines bolted out to an impressive record of 6-0-1. To be honest, I wasn't sure if their hot start was just luck at first. However, this team is for real and other USHL clubs cannot take them for granted.
The Bucs' goaltending duo of Ryan Ruck (4-3-0, 3.01 gaa, .912 save %) and Ryland Pashovitz (3-0-1, 1.71 gaa, .924 save %) have certainly been a big part of their hot start.
Don't forget that the Stars' home game on Friday night against the Sioux City Musketeers will be their annual jersey auction to benefit the American Cancer Society. So make you stick around after the game and help donate to a great cause.
Sorry for the abbreviated weekend preview. I've been sick this week, so I haven't had a lot of energy to devote to the blog. I doubt I'll be healthy enough to watch the Friday night game in person, but I'll be watching on FASTHockey.


text:
Weil Restructuring Blog
Enter your search terms(s)
Portfolio CompanyGood Faith and Fair Dealingstatute of limitationsLoan AgreementCredit AgreementAmendmentContinuous BreachCovenant Not to SueCapital ContributionDamages
rows search Weil Restructuring
JurisdictionCross-borderCCAAU.S. Bankruptcy CodeMake-wholeUltra PetroleumPostpetition InterestSolvent-debtor exceptionDefault rateBankruptcy Code
rows Menu
Chapter 11 Plans, Claims, Cramdown, Jurisdiction & Appeals
Absolute Priority Absolutely Applies . . . In This Case
Contributed by Erika del Nido
Joining the growing list of courts that have been asked to consider the issue of whether the absolute priority rule applies to individual debtors (including the United States Bankruptcy Appellate Panel for the Ninth Circuit, the Fourth Circuit Court of Appeals, and the Tenth Circuit Court of Appeals) the United States Court of Appeals for the Fifth Circuit is the latest of the courts of appeal to toss its hat in the ring on the issue. The court in In re Lively narrowly construed a statutory exception applicable to individual debtors to hold (as the Fourth and Tenth Circuits previously held) that the absolute priority rule applies to individual chapter 11 debtors.
In Lively, a chapter 11 individual debtor sought confirmation of his plan of reorganization, pursuant to which the debtor would retain his property and pay unsecured creditors a small dividend that exceeded the liquidation value of the assets dealt with by the plan. No objections to confirmation or competing plans were filed, but the impaired unsecured class of creditors voted to reject the plan. The bankruptcy court determined that the proposed chapter 11 plan failed to comply with the absolute priority rule and denied confirmation of the plan.
The absolute priority rule, as set forth in section 1129(b)(2)(B) of the Bankruptcy Code, provides that a chapter 11 plan is "fair and equitable" as to a class of dissenting unsecured claims if:
(i) the plan provides that each holder of a claim of such class receive or retain on account of such claim property of a value, as of the effective date of the plan, equal to the allowed amount of such claim; or
(ii) the holder of any claim or interest that is junior to the claims of such class will not receive or retain under the plan on account of such junior claim or interest any property, except that in a case in which the debtor is an individual, the debtor may retain property included in the estate under section 1115, subject to the requirements of subsection (a)(14) of [section 1129].
11 U.S.C. § 1129(b)(2)(B). The debtor in Lively, who was an individual, conceded that his proposed plan would have violated the absolute priority rule but for the exception in section 1129(b)(2)(B), which was added in 2005 with the enactment of the BAPCPA amendments. The exception in 1129(b)(2)(B), the debtor argued, if read in conjunction with section 1115 of the Bankruptcy Code, exempts individual debtors from the absolute priority rule in its entirety. Section 1115 provides:
In a case in which the debtor is an individual, property of the estate includes, in addition to the property specified in section 541—
(1) all property of the kind specified in section 541 that the debtor acquires after the commencement of the case but before the case is closed, dismissed, or converted to a case under chapter 7, 12, or 13, whichever occurs first; and
(2) earnings from services performed by the debtor after the commencement of the case but before the case is closed, dismissed, or converted to a case under chapter 7, 12, or 13, whichever occurs first.
11 U.S.C. § 1115(a). Relying on "a minority string of bankruptcy court authority," the debtor espoused what has been referred to as the "broad view" of the BAPCPA amendment, arguing that, pursuant to section 1115 of the Bankruptcy Code, all "property specified in section 541" qualifies as "property included in the estate under section 1115" and may be retained by the debtor pursuant to section 1129(b)(2)(B)(ii) of the Bankruptcy Code. If the "broad view" applied, the debtor would be able to retain his prepetition property even though the unsecured class of creditors had voted to reject his plan. Courts adopting the "narrow view" of the BAPCPA amendment find that section 1115 supplements, but does not replace, the definition of "property of the estate" contained in section 541 — meaning that section 1115 includes property in an individual's estate that was not already included by virtue of 541 (that is, property and earnings acquired postpetition).
The Fifth Circuit's Analysis
On appeal, the Fifth Circuit rejected the debtor's argument. Aligning itself with courts that have adopted the "narrow view" of the BAPCPA amendment, the court held that a "narrow" interpretation of section 1129(b)(2)(B)(ii) of the Bankruptcy Code is "unambiguous and correct, and the exception to the absolute priority rule plainly covers only the individual debtor's post-petition earnings and post-petition acquired property." The Fifth Circuit explained that both sections 1129(b)(2)(B)(ii) and 1115 of the Bankruptcy Code were adopted when the Bankruptcy Code was amended in 2005 so that individual debtors could not "reorganize in Chapter 11 under more favorable terms than those available to chapter 13 debtors." Prior to the amendments, a chapter 13 debtor's postpetition income could be recovered by creditors, but an individual chapter 11 debtor's postpetition income was not recoverable by creditors. The court explained, "In § 1115, Congress remedied this potential inequity in Chapter 11 by adding to the § 541 definition the individual debtor's post-petition earnings and property acquisitions." The court elaborated that when Congress added the debtor's postpetition property and earnings to the definition of "property of the estate" for individual chapter 11 debtors, Congress also had to modify the absolute priority rule so that an individual chapter 11 debtor would not be "saddled" with committing all postpetition property to satisfy the claims of its creditors.
The court noted that the debtor's proposed reading of the absolute priority rule would lead "to a repeal by implication of the absolute priority rule for individual debtors," and "[r]epeals by implication are disfavored and will not be presumed unless the legislature's intent is 'clear and manifest.'" The court concluded by observing that absent a clear directive from Congress, Congress meant to refine section 1129(b)(2)(B) – not reverse it – with its amendment in 2005.
The Fifth Circuit has joined the Fourth and Tenth Circuits in holding that the absolute priority rule applies to individual chapter 11 debtors, but other courts have disagreed. Although the Fifth Circuit has spoken, the debate is still alive.
More from the Bankruptcy Blog
Claims, Employment, Fees, Professionals, Rules & Procedures
How Many Connections are Too Many? Bankruptcy Court Finds Multiple Attenuated Connections Not Enough to Warrant Disqualification of Debtors' Professional
DiBlasi
Mezzatesta
What We're Watching, Chapter 11 Plans, Claims
Ultra IV: Make-Wholes, Never Say Never Again
Gabriel A.
Tristan M.
Destiney
Parker-Thompson
International, Jurisdiction & Appeals, Litigation Issues, Setoffs
A Foreign Entity May be Subject to U.S. Bankruptcy Court Jurisdiction Simply by Utilizing a U.S. Bank Account in a Transaction with Another Foreign Entity
Ronit J.
Berkovich
Furqaan
Siddiqui
Copyright © 2023 Weil, Gotshal & Manges LLP, All Rights Reserved. The contents of this website may contain attorney advertising under the laws of various states. Prior results do not guarantee a similar outcome. Weil, Gotshal & Manges LLP is headquartered in New York and has office locations in Beijing, Boston, Brussels, Dallas, Frankfurt, Hong Kong, Houston, London, Miami, Munich, New York, Paris, Princeton, Shanghai, Silicon Valley and Washington, D.C.
Restructure Your Inbox!
Get the latest views and developments in the restructuring world from the Restructuring team at Weil
Printed on Jan 28, 2023 from Weil Restructuring
Views and developments in the restructuring world from the Restructuring team at Weil
Get the latest views and developments in the restructuring world from the Restructuring team at Weil.
Ronit J. Berkovich
David Griffiths
Jessica Liou


text:
Lambis Vassiliadis Music
Lambis Vassiliadis
One of the most distinguished Greek pianists Prof. Lambis Vassiliadis represents a unique style of explosive pianism and artistic sensibility. Privileged to study near to pianists like Yaltah Menouhin, Victor Merzhanov, Jerome Rose and James Tocco, he managed to obtain five academic titles from Universities and Music Academies around the world (Greece - Germany - England - USA) - all with distinctions and honors. He also holds a degree in Philosophy by the Aristotle University of Thessaloniki, Greece. Mr. Vassiliadis is currently Associate Professor at the Department of Music (Ionian University, Corfu. Greece). He has been teaching at the University of Cincinnati as well as the Bowling Green State University in USA. He has also served as the director of the Synchrono Conservatory in Thessaloniki, Greece. Has been active as the artistic director of the ´Vertiskosª International Summer (Greece), the Summer Academy of the Ionian University and the Coordinator of the Piano Studies in the Conservatory of East Macedonia in Kavala-Greece. Has appeared in numerous concerts and orchestra appearances, in Greece, Germany, USA, South Africa, Italy, England, France, Libanon, Thailand, Lithuania, Poland. In his activities as an academic teacher in the late years worked closely with pianists such as Hideyo Harada in a research effort about the evolution of the piano interpretation and the Russian School of piano playing.
Lambis Vassiliadis's top 10 list
01Beethoven Symphonies, S. 464
02Symphony no. 7 in A major, Op. 92
03Variations and Fugue in E-flat major 'Eroica…
045 studies, Anh. 1a/1
Theme and Variations


text:
Home Nigerian News Politics UPDATE: Ekiti APC rally shooting misfire from mobile policeman
UPDATE: Ekiti APC rally shooting misfire from mobile policeman
What was first misunderstood as a deliberate shooting at the APC Secretariat on Ajilosun area of Ado Ekiti on Friday turned out to be an alleged mishandling of firearms by a yet-to-be identified mobile policeman, who was said to be "over protecting" some VIPs shortly after the end of the rally.
Journalists had hardly left the rally venue when sporadic gun fire were heard, leading to many scampering for safety in different directions.
READ ALSO : Impossible: Meet The Women Who Can Tell When People Will Die Just By Smelling Them (Photo)
The gunshots strayed in all directions, mostly towards the ground. In the process, one of the APC aspirants, Opeyemi Michael Bamidele (MOB) was hit in his arm, while one yet to be identified person was also hit.
It was further gathered that the mobile policeman who allegedly mishandled his gun was protecting some VIPs who were almost mobbed by a crowd demanding money from them.
An eyewitness said: "The mobile policeman, in his effort to protect the VIPs, was using his gun to push away the crowd; some members of the crowd got annoyed and dragged the gun with him. It was then he shot sporadically in the air, to scare them away."
READ ALSO : #NoTooYoung Bill: You Are Too Old To Run - Fayose To Buhari
Another eye witness said: "The mobile policeman in question who allegedly mishandled his gun was mobbed by angry party members who eventually disarmed him. He was said to have been behaving funny earlier in the day, leading to some of his colleagues urging him to surrender his weapon. Some had even alleged that he was probably drunk."
Meanwhile, the yet to be identified mobile policeman was terribly beaten by the angry, and is feared dead.


What is your story? When we share our story, we open the door for God to use us to share his Truth and ultimately the Good News of the Gospel. Are you willing to share your story with others–family members, coworkers, peers, friends? 1 Timothy 1:12-20.


text:
Kanye West's Faith Deserves Our Joy And Prayers, Not Our Skepticism
November 1, 2019 By Hans Fiene
Christians shouldn't be afraid of getting burned by Kanye West because our faith isn't rooted in the fidelity of Christians but the faithfulness of Christ.
No, We Shouldn't Stop Using Masculine Pronouns For God
August 23, 2019 By S. A. Dance
If young Christians think God is a male, churches certainly have a problem to address. But using feminine pronouns or gender-neutral language is not the solution.
Why Christian Women Don't Need To Be Pastors To Be Equal With Men
August 1, 2019 By Hans Fiene
Christianity offers countless joys to the lost and fallen sinners of this world. But if you're looking for the joy that comes from receiving equal access to every aspect of the church's ministry, you're going to be disappointed.
Why Churches Should Ditch The Projector Screens And Bring Back Hymnals
June 18, 2019 By Tom Raabe
Christians need to understand that relying on screens and other technology is not leading to better worship, it's ruining it.
7 Provocative, Substantive Theology Podcasts You Need To Check Out
May 15, 2019 By Holly Scheer
With limited time, it's hard to know what's worth listening to and what's worth avoiding. This list should demystify some of that and give you some fresh ideas.
No, Christianity Doesn't Need To Endorse Homosexuality To Grow
May 6, 2019 By Glenn T. Stanton
Rev. Oliver Thomas is simply one in a long line of terribly misguided clergy who believe the best thing for the church is to stop being Christian.
5 Major Heresies A Supposedly Christian Minister Preached To A Gullible New York Times Columnist
April 30, 2019 By Robert Gagnon
How can you claim to be a Christian, let alone a Christian minister, while denying one essential element after another of Jesus' own life and teaching? Either Jesus is a liar or she is.
Sorry, Bethel Music, But God's Love Just Isn't 'Reckless'
December 28, 2018 By Georgi Boorman
'Reckless Love' has quickly become a favorite worship song in non-denominational and evangelical churches. Every time we sing it in service, I omit one word: 'reckless.'
Stop Weaponizing The Priest Abuse Crisis Against Catholic Theology
November 27, 2018 By Matthew Petrusek
It's disingenuous to link the question of papal authority to the abuse scandal, which remains a problem of conduct, not of doctrine.
The Clergy Sex Abuse Crisis Is Dredging Up An Old Heresy
November 23, 2018 By John Daniel Davidson
Catholics leaving the church over the sex abuse crisis are giving into the false notion that the sacraments depend on blameless clerics.
Is There Any Church Abuse Too Far For The Catholic Faithful?
November 19, 2018 By Korey Maas
If matters were 'ultimately all about' the Eucharist, it would have to be admitted that Eastern Orthodoxy remains a perfectly legitimate option for discouraged and disillusioned Catholics.
How Abolishing The Death Penalty Degrades Both Justice And Mercy
June 21, 2018 By Nathanael Blake
To abolish the death penalty is to abdicate the civilizational attempt to instantiate justice in law, and precludes the possibility of mercy.
No, Evangelicals Don't Want The Middle East Destabilized To Bring About Armageddon
June 4, 2018 By Aaron Gleason
Many American evangelicals do believe that Israel holding its historic territory is spiritually important, but that doesn't mean we think any political decisions are going to force God's hand.
No, The Catholic Church's Support Of Celibacy Doesn't Make It Like Feminism
May 16, 2018 By Luma Simms
From a hierarchical perspective, the Catholic Church can seem more 'egalitarian' and, depending on one's degree of myopia, even 'liberal' or 'feminist.'
Does Feminism Treat Women Like The Medieval Catholic Church Did?
January 18, 2018 By Joy Pullmann
Elise Crapuchettes argues that medieval Catholic theology and modern feminist ideology both validate women largely in terms of their external production.
This Theologian Has An Answer To Atheists' Claims That Evil Disproves God
January 3, 2018 By John Sweeney
Taken at face value, the problem of evil appears to be a devastatingly convincing argument against the existence of the Christian God.
A Tribute To Reformed Theologian R.C. Sproul From A Grateful Listener
December 19, 2017 By Andrew Clover
R.C. Sproul was the founder of Ligonier Ministries and on the faithful forefront of the evangelical world's battle over the inerrancy and sufficiency of scripture.
5 Reasons Christian Support For Jerusalem Is Not About The End Times
December 18, 2017 By Luke Moon
While some Christians believe there is theological significance to Jews controlling their historic homeland, for many the reasons are practical, not theological.
Public Theology, Liturgy, And Augustine With James K. A. Smith
December 7, 2017 By The Federalist Staff
Philosopher, author, and professor, James K. A. Smith discusses the intersection of religion, culture and politics on the Federalist Radio Hour.
How Roman Catholicism Can Get Protestantism Back To Its Reformation Roots
October 27, 2017 By Peter Burfeind
Protestant churches will claim a doctrinally correct view of justification, but what the doctrine means has no bearing on their worship practices. Not so with many Catholics.
see more posts >


Athletes are Turning to Manuka Honey: Should You?
Athletes are dedicated to their workouts, diets, and leading a very healthy lifestyle. We all wish we could be as disciplined, though there is an ingredient that we can all take to heart in helping us lead healthier lives – manuka honey!
With the rise of manuka honey in medicine and skin care, it was only a matter of time when it would enter into the nutrition and sports fields! A company has recently released a line called Manuka Sport and each product from it contains Manuka honey from New Zealand, which provides athletes with unique health benefits. They hydrate with an orange honey ultra-blend of Manuka honey powder, BCAAs, carbohydrates, and electrolytes and provide sustainable energy with energy gels containing, carbohydrates, electrolytes and the option of caffeine.
"Manuka Sport Energy Gels are the fuel your body needs to awaken its inner warrior," said Tom Buckley, CEO of Manuka Sport. "Our all-natural energy gels are specially formulated to energize and hydrate you through training and competition."
The benefits of all-natural Manuka Honey include its high levels of antioxidants as well as its ability to boost your immune system and decrease inflammation. Manuka Sport products are independently tested and certified for Methylglyoxal levels, as well as are certified free of banned substances and ingredients for elite athletes as verified by Informed-Choice, which assures that all products are made to the highest quality standards.
Manuka Sport offers athletes a unique and complete product line to enjoy before, during and after a workout. So for athletes, this is a great way to help internally, and what better than to add it to your skin care for optimal results on the outside to coexist with your strong body!
Manuka honey is one of the forefront ingredients in natural beauty products. The antibacterial, anti-inflammatory, and healing benefits of manuka honey have caused a surge in adding it to skincare. It also has amazing anti-aging benefits, stimulating the production of collagen and regenerating properties. With a natural blend of vitamins, minerals and amino acids in it, this only further gives your skin a natural boost! Plus, using a lotion or moisturizer with manuka honey has incredible hydrating benefits, keeping your skin soft and supple.
Using a variety of manuka honey skin care products, like a body wash, face wash, even shampoo and conditioner after a workout, will only show off the hard work you've been doing at the gym!
Many beauty brands offer natural ingredients in their skin care lines, but that also means a higher price tag for natural. Are all skincare lines expensive? Not at all! Wild Naturals was created for the affordable and natural ingredients listed in it, without the heavy price tag. Most products are made with water, diluting the potency of the mixture and added as a filler so not as much product is put in each container. Wild Naturals is one of the few brands that uses no water in its products, instead, our first ingredient is organic aloe vera!
We pride ourselves on our list of ingredients and what is NOT added to our products, such as mineral oil, petroleum, parabens, dyes, and fragrances. All of these harms your skin and Wild Natural's honor is about helping to heal and relieve your skin. Not only is our ingredient list top notch, but our products are pH balanced as well, soaking straight into your skin for ultimate results.
Browse our shop online for manuka honey rich products and be happy with the price, not the upcharge for the name of the brand! Wild Naturals cares more for the health of your skin and achieving the results you want, making it a breeze when you leave the gym. You shouldn't have to do double the workouts for your skin when it comes to your skin care products!