text:
Unconventional oil and gas development requires extraordinary amounts of water during the extraction process. In 2019, fracking operators used an average of 14 million gallons of water per well, with the maximum amount reaching 39 million gallons for a single well. After being pumped underground to "frack" oil and gas wells, water is called "flowback," and includes naturally occurring underground brine water– which contains dangerous levels of radiation, heavy metals, and other contaminants — mixed with the fracking chemical-laden fresh water that has been pumped into the well. The chemicals used in the fracking process are known carcinogens, while others remain entirely secret, even to the personnel in the field who are employed to use the additives.
Flowback is disposed of by injection into underground wells, in water treatment plants, or in open air pits. Each of these disposal methods comes with enormous risks, such as contamination of drinking water sources, fresh water contamination, inducing seismic activity in the case of underground injection, human exposure to radioactivity, and increased traffic needed to transport produced water. Sometimes produced water is treated to remove some of the fracking chemicals and reused in the fracking process, but this accounts for only a portion of fracking water given that fresh water is cheaper to procure.
Shockingly, some states allow for fracking wastewater to be treated and used for agricultural purposes, for road spreading, or for commercial sale in products such as pool salts, increasing exposure pathways to toxic chemicals.
Explore these issues in depth in the FracTracker articles and maps below.
Explore our album of water impacts and concerns
Photo by Bill Hughes, OVEC, 2016
FracTracker Water Articles
Coursing Through Gasland: A Digital Atlas Exploring Natural Gas Development in the Towanda Creek Watershed
This digital atlas exploring natural gas development in the Towanda Creek watershed is the fourth in a series of FracTracker Alliance watershed impact analyses in the Susquehanna River Basin.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2022/11/DSC_1359_HighRes.jpg 1000 1500 FracTracker Alliance https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.png FracTracker Alliance2022-11-23 15:15:112022-11-23 15:57:43Coursing Through Gasland: A Digital Atlas Exploring Natural Gas Development in the Towanda Creek Watershed
Synopsis: Risks to the Greater Columbus Water Supply from Oil and Gas Production
A white paper by Columbus Community Rights Coalition (CCRC) will inform resident stakeholders of risks to the water associated with oil & gas production activities occurring within their watershed region of Columbus, Ohio.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2022/10/Columbus-Source-Water.jpg 605 1500 Guest Author https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.png Guest Author2022-10-31 21:39:022022-11-29 14:24:38Synopsis: Risks to the Greater Columbus Water Supply from Oil and Gas Production
Desalination: The Chemical Industry's Demand for Water in Texas
Desalination facilities proposed by the petrochemical industry in Texas could significantly impact fragile Gulf Coast ecosystems.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2022/09/DSC_1021_LowRes__1607617394306__w1920-e1663613850641.jpg 667 1500 Ted Auch, PhD https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.png Ted Auch, PhD2022-09-19 15:08:172022-11-03 11:56:26Desalination: The Chemical Industry's Demand for Water in Texas
Take Action in Support of No New Leases
The federal government is accepting comments on a 5-Year Offshore Oil and Gas Lease Program. We need your voice to join in solidarity with communities in the Gulf and the Arctic and call for no new leases.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/06/LKrop_infrastructure-offshoredrilling-drillrigs-SantaBarbara-CA_EnvrDefenseCtr_Aug20131-e1663254826557.jpg 178 400 Erica Jackson https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.png Erica Jackson2022-09-06 13:32:202022-09-15 11:14:03Take Action in Support of No New Leases
Victoria's Story
The story of Victoria Switzer, a Dimock resident who is leading the charge to protect Burdick Creek and Dimock from toxic fracking waste.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2022/04/VictoriaSwitzerPaintingDimock.jpg 284 640 Guest Author https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.png Guest Author2022-04-08 14:15:282022-04-13 12:01:36Victoria's Story
Petrochemical Toxics in the Ohio River Watershed
A look at the petrochemical industry's footprint in the Ohio River Watershed and how much toxic pollution is discharged into waterways.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/09/Adobe-stock-beaver-cracker-feature.jpg 667 1500 Erica Jackson https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.png Erica Jackson2021-12-21 10:49:162022-01-03 11:35:03Petrochemical Toxics in the Ohio River Watershed
US Army Corps Muskingum Watershed Plan ignores local concerns of oil and gas effects
Local stakeholders' concerns about the environmental and health impacts of oil and gas in the Muskingum Watershed of Ohio have been minimized or excluded by the US Army Corps' environmental assessment.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/11/TAuch_Infrastructure-naturalgas-powerplant-construction-Caithness-GuernseyCounty-OH_April2021.jpg 667 1500 Guest Author https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.png Guest Author2021-12-01 15:20:152022-01-04 17:53:55US Army Corps Muskingum Watershed Plan ignores local concerns of oil and gas effects
Oil and gas companies use a lot of water to extract oil in drought-stricken California
FracTracker details the disproportionate amounts of water used by the oil and gas industry in CA and recommends that Gov. Newsom take action.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/11/RMasoner-ChevronOilPumpJacks-SanJoaquinValley_2008.jpg 428 900 Kyle Ferrar, MPH https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.png Kyle Ferrar, MPH2021-11-09 14:59:182021-11-09 21:31:59Oil and gas companies use a lot of water to extract oil in drought-stricken California
Southeastern Texas Petrochemical Industry Needs 318 Billion Gallons of Water, but the US EPA Says Not So Fast
The US EPA is moving to turn off the tap to Texas' petrochemical operators that are demanding exorbitant water quantities where there are none.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/11/TAuch_Plastics_Refinery_TankFarm_Terminal-Trafigura_CorpusChristiPolymers_Valero_Citgo_FlintHillsResources-CorpusChristi_TX_LightHawk_Nov2019-feature.jpg 667 1500 Ted Auch, PhD https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.png Ted Auch, PhD2021-11-05 09:43:472021-11-05 09:47:30Southeastern Texas Petrochemical Industry Needs 318 Billion Gallons of Water, but the US EPA Says Not So Fast
Lycoming Watershed Digital Atlas
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/07/Lycoming-feature.jpg 667 1500 FracTracker Alliance https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.png FracTracker Alliance2021-07-27 09:58:142021-07-28 11:23:19Lycoming Watershed Digital Atlas
Impacts of 2020 Colonial Pipeline Rupture Continue to Grow
In August 2020, the Colonial Pipeline ruptured, spilling an estimated 1.2 million gallons of gasoline—18 times more than originally reported.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/05/Colonial-pipeline-spill-feature.jpg 667 1500 Karen Edelstein https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.png Karen Edelstein2021-05-26 07:00:272022-07-25 09:28:20Impacts of 2020 Colonial Pipeline Rupture Continue to Grow
Jared Durelle
Gas Storage Plan vs. Indigenous Rights in Nova Scotia
The Mi'kmaq First Nations people are facing threats to their lands and water due to plans in Nova Scotia proposed by AltaGas.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/05/Stop-Alton-Gas-Treaty-Truckhouse-feature-photo-by-Jared-Durelle.jpg 667 1500 Karen Edelstein https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.png Karen Edelstein2021-05-20 14:50:522022-01-10 17:07:38Gas Storage Plan vs. Indigenous Rights in Nova Scotia
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text:
Home Chords - Foo Fighters
Home Chords
Group: Foo fighters
Record: Echoes, silence, patience and grace
Song: Home
This is my first tab, so please be gentle:). The song is very beautiful and
easy to play, since it�s only 5 chords. Enjoy!
G           Am
Wish I were with you
F          G
I couldn't stay
G        Am
Every direction
F        G
Leads me away
G         Am
Pray for tomorrow
F       G
But for today
F     Em      C
All I want is to be home
G            Am
Stand in the mirror
You look the same
Just lookin' for shelter
F                 G
From cold and the pain
G          Am
Someone to cover
F             G
Safe from the rain
F     Em      G
Echoes and silence
Patience and grace
All of these moments
I'll never replace
No fear of my heart
Absence of faith
F         G
I have no regrets
G      Am
Some I remember
Some I forget
Some of them living
Some of them dead
Foo Fighters - Home Chords :: indexed at Ultimate Guitar.
Home tabs @ 911Tabs
People who played Foo Fighters - Home Chords also played these songs by Foo Fighters:
Best Of You Acoustic Chords, Walk Chords, My Hero Acoustic Chords, Learn To Fly Chords, Wheels Chords, Everlong Acoustic Tab, Walking After You Chords, Stranger Things Have Happened Tab, The Pretender Chords
About the artist behind Home Chords:
Foo Fighters is an American alternative rock band formed by singer/guitarist Dave Grohl in 1995.[1] Grohl formed the group as a one-man project after the dissolution of his previous band Nirvana in 1994. Prior to the release of Foo Fighters in 1995, Grohl drafted Nate Mendel (bass), William Goldsmith (drums), and Pat Smear (guitar) to complete the group. Goldsmith and Smear left after the recording of the group's second album The Colour and the Shape (1997). They were replaced by Taylor Hawkins and Franz Stahl, respectively, although Stahl left prior to the recording of the group's third album, There Is Nothing Left to Lose (1999).
Chris Shiflett joined as the band's second guitarist after the completion of There is Nothing Left to Lose. The band released its fourth album One by One in 2002. The group followed that release with the two-disc In Your Honor (2005), which was split between acoustic songs and harder-rocking material. Foo Fighters released its sixth album Echoes, Silence, Patience & Grace in 2007. Over the course of the band's career, three of its albums have won Grammy Awards for Best Rock Album, and all six have been nominated for Grammys.
Show us your talent, perform Home Chords!
Here you can post a video of you playing the Home Chords, so your fellow guitarists will be able to see you and rate you.

redpajama_set_name: RedPajamaCommonCrawl


text:
Search Result ( 1 - 9 from 9 )
Biodiversity Food Integrated Management Urban Governance
proGIreg
Productive Green Infrastructure for post-industrial urban regeneration
At the centre of proGIreg will be Living Labs in Dortmund (Germany), Turin (Italy), and Zagreb (Croatia) to co-design and co-implement nature-based solutions (NBS) in urban areas facing the challenge of post-industrial regeneration. Four further cities in Eastern and Southern Europe will closely int...
Biodiversity Climate Change Mitigation Climate Change Adaptation & Resilience Urban Governance
CLEVER Cities
Hamburg, London and Milan will co-create locally tailored nature-based solutions for urban regeneration as part of the European-funded CLEVER Cities project.
Connecting Nature
Coordinated by Trinity College Dublin, Connecting Nature is a partnership of 29 organisations from 16 countries which includes local authorities, communities, industry partners, NGOs and academics. Our partnership will work with 11 European cities who are investing in multi–million euro large sca...
Biodiversity Food Construction Integrated Management Urban Governance Finance Cultural Heritage
Rural-Urban Outlooks: Unlocking Synergies
ROBUST aims to advance our understanding of the interactions and dependencies between rural, peri-urban and urban areas and to identify and promote policies, governance models and practices that foster mutually beneficial relations.
Biodiversity Integrated Management Urban Governance
NATURVATION
Nature Based Urban Innovation
We seek to develop our understanding of what nature-based solutions can achieve in cities, examine how innovation can be fostered in this domain, and contribute to realising the potential of nature-based solutions for responding to urban sustainability challenges by working with communities and stak...
Biodiversity Climate Change Adaptation & Resilience Construction Urban Governance
ENABLE-Enabling Green and Blue Infrastructure Potential In Complex Socio-ecological Regions
The project aims to develop new methods and tools to maximise the capacity of green and blue interventions in neighbourhoods and metropolitan
regions, taking into account local stakeholders' perspectives.
Biodiversity Climate Change Mitigation Climate Change Adaptation & Resilience Integrated Management Finance
Financing Greener Cities
"Financing Greener Cities" is a capacity-building event, which will focus on "Strengthening the capacity of local authorities and practitioners for making informed decisions on financing nature-based solutions".
Biodiversity Urban Governance
GREEN SURGE
Green Infrastructure and Urban Biodiversity for Sustainable Urban Development and the Green Economy
Between 2013 and 2017 GREEN SURGE has worked on identifying and developing ways of planning, creating and managing urban green spaces whilst at the same time strengthening their biodiversity, making them accessible and available to all groups of society and promoting an economy based on green infras...
Biodiversity Climate Change Mitigation Climate Change Adaptation & Resilience Energy Mobility Waste & Circular Economy Water Integrated Management Urban Governance
Realising Development of Resources and access to Municipal Services
Both environmental degradation and poverty alleviation are urgent global challenges that are too often treated separately. With pressing development needs in Least Developed Countries, and with a growing population, approaches to such global challenges require rethinking. But when new approaches are...


You may see your vision very clearly in your mind but if you can't get this across to your staff then they can't get behind you. Learning how to communicate concepts, expectations and issues is a crucial part of being a great leader.
Learning to trust your team is a key element of being a solid gold leader. If you don't learn to delegate then you will run yourself into the ground trying to do everything and be unable to make the leadership decisions that will make your business a success. The art of good delegation comes from understanding the team that you're leading – what do individuals enjoy, what are they good at and where is further training required?
You have to lead from the front in the restaurant business. While this doesn't mean that you have to be a loud or narcissistic personality, it does require the confidence to stand behind the food that you produce and the decisions that you make. Your level of confidence can considerably impact your team too so be aware of what will affect team morale, positively or negatively, and use it to help power your workforce forward.
If you're clocking off early and leaving tasks incomplete for the next day then your team is very likely to follow suit. Set an example by doing the extra hours, taking pride in your establishment and setting high standards for everyone who works for you.
Great leaders all have several characteristics in common – honesty, versatility, positivity and intuition. Admit to mistakes and be honest about prospects. Learn to adapt to events and try to remain positive, whatever happens. Finally, listen to your intuition. Intuition is one of the most powerful tools a leader has and learning how to listen to it can help guide you through the often rough seas of food industry success.


Open for lunch and dinner, Grill'd – the healthy burger specialist – offers a mouth watering range of fresh, healthy flame grilled burgers made with love.
Grill'd offers a range of fresh, healthy flame grilled burgers that are made from the highest quality, freshest ingredients – ideal for those who enjoy eating well and keeping fit and healthy.
The menu boasts 18 meal-sized burgers made from 100% beef, chicken breast, lamb and veggie patties. Many of the burgers incorporate non-traditional quality toppings such as cranberry sauce, roasted capsicum, Brie cheese and avocado.


text:
Georgi Iwanowitsch Salnikow (, wiss. Transliteration ; * 12. Juli 1923 in Moskau; † 8. Juli 2015 ebenda) war ein russischer Komponist und Musikpädagoge.

Leben
Sein Musikstudium mit dem Hauptfach Klavier absolvierte er am Moskauer Konservatorium unter anderem bei Wladimir Sofronizki. Später studierte er Komposition bei Juri Kotschurow und Oles Tschischko am Sankt Petersburger Konservatorium. Nach Abschluss der Studien kehrte er als Professor an das Konservatorium in Moskau zurück.

Er trat auch als Pianist und Hornist in Erscheinung.

Seine Kompositionen breiten sich über ein weites Spektrum aus (Symphonische Werke, Opern, Kammer- und Vokalmusik).

Werke

Werke für Blasorchester

 1959 Soldat gai – Wassili Tjorkin Marsch opus 5
 1959 Russisches Capriccio opus 7
 1963 Kaukasische Fantasie opus 8
 1968 Russische Rhapsodie für Klavier und Blasorchester opus 11
 1970 Poem für Horn und Blasorchester opus 12
 1971 Heroisches Scherzo opus 13
 1980 Nowospasskoje – Poem opus 31
 1980 Freundschaft – Slawische Fantasie opus 33
 1981 Konzertwalzer opus 36
 1984 Über Krieg und Frieden – Sinfonie opus 39
 1984 Kindersuite opus 40
 1984 Russischer Reigen
 1988 Burleske
 1993 Arabesques für das Musik-Festival in Uster, Schweiz
 1997 Ouverture für einen Sommernachmittag
 1998 Ouverture bravoure opus 16
 Petit Concerto Lyrique für Oboe opus 34

Bücher und Schriften

 1967 Instruction Manual Instrumentation für Symphonisches Blasorchester
 1976 und 1980 Instrumentationslehre für Blasorchester (2 Bände)

Weblinks

 Informationen auf der Seite des Moskauer Konservatoriums (russisch)
 Kurzbiografie auf biografija.ru (russisch)

Einzelnachweise

Komponist klassischer Musik (20. Jahrhundert)
Komponist (Oper)
Komponist (Sowjetunion)
Komponist (Russland)
Komponist (Blasmusik)
Klassischer Hornist
Klassischer Pianist
Sachbuchautor (Musik)
Hochschullehrer (Moskauer Konservatorium)
Musiker (Moskau)
Absolvent des Moskauer Konservatoriums
Absolvent des Sankt Petersburger Konservatoriums
Russe
Sowjetbürger
Geboren 1923
Gestorben 2015
Mann

redpajama_set_name: RedPajamaWikipedia


text:
Бронислав Викторович Мешкис (21 августа 1928 — 9 июня 1985) — советский украинский режиссёр, Народный артист Украинской ССР (1980).

Биография
Родился 21 августа 1928 года в селе Тетерино, теперь Могилёвская область. В 1948 году окончил театральную студию при Львовском украинском драматическом театре им. М. Заньковецкой. Удачно сдал вступительные экзамены и окончил в 1958 году Киевский театральный институт (класс В. А. Нелли). Член КПСС с 1957 года.

Работал в Днепропетровском русском драматическом театре им. М. Горького (1958—1961), Одесском русском драматическом театре им. А. Иванова (1964—1966), Киевском украинском драматическом театре им. И. Франко (1968—1971), Харьковском украинском драматическом театре им. Т. Шевченко (1971—1974). В 1961—1963 годах работал режиссёром, в 1974—1985 годах был главным режиссёром Одесского украинского музыкально-драматического театра.

Режиссёр-постановщик таких спектаклей, как «Ярослав Мудрый» И. Кочерги (1970), «Борис Годунов» А. Пушкина (1982) и другие. Режиссировал фильм-спектакль «Платон Кречет» (1972).

Преподавал в учебных заведениях Днепропетровска, Киева, Харькова, а также в оперной студии Одесской консерватории им. А. Неждановой.

Умер 9 июня 1985 года в Одессе.

Примечания

члены КПСС


text:
/*
 * File:   datalogger-file.h
 * Author: Ducky
 *
 * Created on August 12, 2011, 1:16 PM
 *
 * Revision History
 * Date			Author	Change
 * 12 Aug 2011	Ducky	Initial implementation.
 *
 * @file
 * Datalogger file operations, including a large circular buffer in RAM.
 */

#ifndef DATALOGGER_FILE_H
#define DATALOGGER_FILE_H

#include "../FAT32/fat32-file.h"

typedef struct {
	FS_File *file;			/// Pointer to the open file.

	// Buffering variables
	uint8_t *buffer;		/// Pointer to the beginning of the data block.
	uint16_t bufferSize;	/// Size, in bytes, of the circular buffer.
	uint16_t bufferFree;	/// Number of free bytes left in the buffer;
	uint16_t readPos;		/// Position to read from, the beginning of the buffer.
	uint16_t writePos;		/// Position to write to, the end of the buffer.

	// Random
	uint8_t requestClose;	/// If the file is requested to be closed.
} DataloggerFile;

/**
 * Initializes the Datalogger file.
 *
 * @param dlgFile Datalogger file to initialize.
 * @param file Filesystem file to write to. Can be uninitialized, and disk
 * operations will not start until the file has been successfully initialized.
 * @param buffer RAM buffer
 * @param bufferSize Size of the RAM buffer, in bytes, or 0 if a RAM buffer
 * is not being used.
 */
void DataloggerFile_Init(DataloggerFile *dlgFile, FS_File *file,
		uint8_t *buffer, uint16_t bufferSize);

/**
 * Writes data to a Datalogger file.
 * This either writes the entire string or nothing at all. Partial writes
 * will NOT happen.
 *
 * @param dlgFile Datalogger file to be written to,
 * @param data Data to write.
 * @param dataLen Data length, in bytes.
 * @return Result of the write operation.
 * @retval 0 Write failed - not enough space in the buffer.
 * @retval 1 Write successful, entire data written.
 */
uint16_t DataloggerFile_WriteAtomic(DataloggerFile *dlgFile, uint8_t *data,
		uint16_t dataLen);

/**
 * Called periodically to perform tasks for the Datalogger file, such as
 * writing the RAM buffer to the file and performing filesystem file tasks.
 *
 * @param dlgFile Datalogger file to process.
 * @return Result of the call to FS_FileTasks.
 */
fs_result_t DataloggerFile_Tasks(DataloggerFile *dlgFile);

/**
 * Requests that the file be closed.
 *
 * @param dlgFile Datalogger file to process.
 */
void DataloggerFile_RequestClose(DataloggerFile *dlgFile);

#endif

redpajama_set_name: RedPajamaGithub


BUY UNDER A CONFEDERATE MOON TODAY!
Bitten as a teen, Caleb now suffers through a painful transformation from human to bobcat a few days each month. As a bobcat, he leaves behind his camp and fellow soldiers to explore the night. But a gunshot and the bright scent of fresh blood draws him to a clearing where he learns that he isn't the only one of his kind.
Wounded and hurt, Brance is a loner by nature, gruff and grumbling, who doesn't want anything to do with Caleb…at first. The younger bobcat prevails, and starts to win Brance over, until they turn human again and find themselves on opposite sides of the American Civil War.
…The scent of man enveloped him. Each tree he sniffed, each branch, each bush, carried the smell of humans and their artillery. Dried blood and disease mingled with the smell, painful scents Caleb didn't like. The shirt on his back only confused his senses, but once the camp was behind him, he took a moment to wiggle out of the torn material. He sniffed it, curious, then left it among the leaves as he hurried away, the growl still tickling the back of his throat. The sound warned anything away from his vicinity, and helped keep his mind off his churning stomach, or the bloodlust that filled his veins.
On four padded feet, Caleb crept through the forest as silently as a house cat stalking its prey. He hunted half-heartedly, not quite ready to sate his appetite and call it a night. At some point he scared up a large hare, coming onto it from downwind, but the creature caught his scent moments before he pounced, and darted just beyond his powerful jaws to disappear into a hole too narrow and deep to dig in for long. Abandoning the prey, Caleb kept moving, always keeping the men and their smoke-filled camp at his back. He heard no more gunshots, and felt no urgency to hurry through the night.
Off in the distance, along in the direction he was heading, he heard a gunshot. He stopped, ears trained on the sound, his whole body rigid and tense. Men. The word was anathema to him in his current state. He waited for another sound, a second shot maybe, or raucous laughter in the night, but nothing seemed to follow. The tip of his tail twitched, waiting.
Then a volley of shots rang out, three, maybe four, all at once. Caleb dropped into a crouch and heard a wounded yelp cry out, a primal sound that tugged at his instinct. Another cat, he knew-a large one, by the sound of it. That damned growl of his started up again, and he sniffed the air, trying to smell powder or blood, but nothing came to him on the wind.
Could be Yanks, the still-human part of his mind whispered. Sensing an unprecedented opportunity, Caleb sat down on his haunches and licked one forepaw as he mulled over his options. Race ahead, get shot like the other cat. Or, no, sneak in and sneak out, but learn enough of the enemy camp to bring back to his commanding officer in the morning. Major Pennock would want to know how he came about the information, but if they ambushed the Yanks, would it matter how he knew?
With a decisive flick of his tail, Caleb leapt away. On strong legs, with sure strides, he ran through the forest, dodging undergrowth, vaulting over fallen logs and large stones, climbing low trees to jump from their quivering branches when it suited him. The wind raced him, whipping around his ears and flaring his nostrils. His fangs were bared to the night, allowing him to catch the faintest of odors. Before long he found the scent of man again, and gun smoke, and blood.
He skidded to a halt. Like a knife, the blood pierced his mind and stirred his senses. Nosing around, he found a drop of dark lifeblood on a deadfall, still warm. His tongue licked out, and the taste of copper filled his mouth. A heavy scent like wet fur clung to the wood. Picking his way carefully over the rotten limbs, Caleb climbed the deadfall and, on the other side of the forest floor, found another bright patch of blood, a clump of fur clinging stubbornly to the edges of a paw print. Another bobcat, just as he'd thought. Wounded.
With his animal senses, Caleb could easily discern the cat's path through the woods-here the grass bent in a certain direction, there a few branches were snapped as if pointing the way. Caleb padded on, cautious. Every now and then he paused to sniff around. The trail led to a thicket of tall grass, tamped down in the center. As Caleb approached, he heard a low growl issue from the grass in warning.


Exact. I want each country manage its zones in an interval of 1000 positions, in order to keep zones grouped in one ordered sequence and not having addendums/corrections at end in full disorder.
Zones are subject to change for each country, reserved intervals of 1000 in zone_id permit not shifting the rest of the table. This can be done easily with an update SQL script and a trigger on table insertion.
You must understand your actual french zones are absolutely incorrect and make the product unusable for us. I dont know if the same for other countries but i fear. Thats why i propose to reserve 1000 sequential zone_ids per country in table "zone" to the disposition of each translator.
Thank you for the tip gob33.
Like you said zones can be corrected and inserted into tables with SQL.
I assume you refer to ac_zones and zone_id.
It will be big work to refactor this data and retest. Any help is appreciated.
I have posted my soluce in Git. Its all SQL and had been tested ok for me on 1.1.9.
Great. I wonder how it can be integrated into french language.
It is for all language. At language install, clear all zones relative to the country, then insert good ones in the reserved intervall. Other zones dont move/shift.
Currently, I have a problem with banner_manager and form_manager extensions, all texts on page stay in English, despite i have uploaded their translated xml language file. These english texts come from the DB and are recorded with the language_id corresponding to "french" !
2) If i add a new language (by uploading xml files) on an AbanteCart running with some of these extensions enabled, does the translation appear automaticaly inside these extensions ?
3) Is there a simple way to know if abante_demo has been installed, in order to also insert demo translations into tables ?
to be found and loaded in DB by isExtensionLanguageFile().
This makes the directories tree of your language extension rather bizarre.
In fact, I suspect there is something wrong in that case (loading translation of abantecart extensions) between _load_from_xml(), _detect_language_xml_file() and isExtensionLanguageFile().


Looking to grow a new email list for your retail business? Running Facebook giveaways and contests are good places to start when looking to grow new email marketing lists, especially when you have an active and engaged audience to promote to.
Running a Facebook campaign is simple, but there are several key elements you should give a little extra attention to in order to ensure success. Just like meeting people, a first impression is everything with a campaign to get people interested in learning more.


text:
Wilhelm Heß (* 1846 in Bayern; † 25. September 1916 in Klagenfurt) war ein österreichischer Architekt. Wilhelm Heß war ein bedeutender Vertreter der Wörthersee-Architektur und Direktor der Klagenfurter Bau- und Kunsthandwerkerschule.

Leben
Wilhelm Heß stammte aus Süddeutschland und machte angeblich als etwa 14-jähriger Freiwilliger den Deutsch-Französischen Krieg von 1870/71 mit. Über sein Vorleben ist wenig bekannt.

Später ist er an der 1871 gegründeten gewerblichen Zeichen- und Modellierschule in Klagenfurt tätig. Als diese 1883 in eine gewerbliche Fortbildungsschule umgewandelt wurde, wird der etwa 37-jährige Architekt Heß deren Leiter. Unter ihm nahm das gewerbliche Fachschulwesen einen erfreulichen Aufschwung.

Ab 1889 nannte sich die Bildungsanstalt Staats-Handwerkerschule, ab dem Beginn des Schuljahres 1907/08 Bau- und Kunsthandwerkerschule. Heß war zu der Zeit noch immer der Direktor. Er unterrichtete die ganze Zeit auch selbst baugewerbliches Fachzeichnen und hatte daneben die Leitung der Werkstätten inne. 1911 kam es abermals zu einer Reform dieses Schultyps: die Bau- und Kunsthandwerkerschule übersiedelte nach Villach.

Da der Schuldirektor in jenem Jahr vermutlich 65 Jahre alt wurde, ging er wohl in Pension. Er gehörte auch längere Zeit dem Klagenfurter Gemeinderat an.

Ehrungen
Für seine Verdienste waren ihm der Titel "Regierungsrat" und schon früher das Ritterkreuz des Franz-Joseph-Ordens verliehen worden. Der Kärntner Industrie- und Gewerbeverein machte Heß zu seinem Ehrenmitglied.

Familie
Wilhelm Heß war bereits Witwer, als er am 25. September 1916 in der Sariastraße in Klagenfurt starb. Die Beisetzung erfolgte nach evangelischem Ritus auf dem Kommunalfriedhof Annabichl. Seine Tochter Johanna hatte 1902 den Kärntner Bildhauer Jakob Wald geheiratet, der an der Handwerkerschule unterrichtete und schon 1903 starb.

Bauwerke

Bauten (Auswahl)
Hotel Wörthersee (Klagenfurt, 1890–97), Beispiel früher Tourismusarchitektur mit regionalem Typus
Parkhotel (Pörtschach, 1894)
Gemeindeamt (Pörtschach, 1887)
Kielboothütte und Veranden für das Hotel Wahliß (Pörtschach am Wörthersee, 1887(?)-1895)
Schlosshotel Velden, Umbauten
Warmbad Villach (1898–1900), diverse Neu-, Aus- und Umbauten.

Im Rahmen dieser Umgestaltung entstand auch in Warmbad Villach seine typische Türmchenwelt. Es gelang ihm ein einheitliches architektonisches Bild für den ganzen Kurbereich, in den auch ein neuer Kurpark einbezogen wurde.

Literatur
 Peter Schöffmann: Klagenfurt als Schulstadt. (1848–1918). Verlag des Geschichtsvereines für Kärnten, Klagenfurt 1994, ISBN 3-85454-076-0 (Archiv für vaterländische Geschichte und Topographie 74), (Zugleich: Klagenfurt, Univ. f. Bildungswiss., Diss., 1990).
 Karl Treven (Red.): Festschrift der Höheren Bundesgewerbeschule in Klagenfurt. Mech.-techn. Versuchsanstalt, 1861–1936. Höhere Bundesgewerbeschule, Klagenfurt 1936.
 Freie Stimmen. am 27. September 1916, .

Architekt (Österreich)
Träger des Franz-Joseph-Ordens (Ritter)
Person (Klagenfurt am Wörthersee)
Person (Cisleithanien)
Geboren 1846
Gestorben 1916
Mann


text:
<?php

define('_PS_SMARTY_DIR_', _PS_TOOL_DIR_.'smarty/');

require_once(_PS_SMARTY_DIR_.'Smarty.class.php');

global $smarty;
$smarty = new Smarty();
$smarty->setCompileDir(_PS_CACHE_DIR_.'smarty/compile');
$smarty->setCacheDir(_PS_CACHE_DIR_.'smarty/cache');
if (!Tools::getSafeModeStatus())
	$smarty->use_sub_dirs = true;
$smarty->setConfigDir(_PS_SMARTY_DIR_.'configs');
$smarty->caching = false;
$smarty->force_compile = (Configuration::get('PS_SMARTY_FORCE_COMPILE') == _PS_SMARTY_FORCE_COMPILE_) ? true : false;
$smarty->compile_check = (Configuration::get('PS_SMARTY_FORCE_COMPILE') <= _PS_SMARTY_CHECK_COMPILE_) ? true : false;

// Production mode
$smarty->debugging = false;
$smarty->debugging_ctrl = 'NONE';

if (Configuration::get('PS_SMARTY_CONSOLE') == _PS_SMARTY_CONSOLE_OPEN_BY_URL_)
	$smarty->debugging_ctrl = 'URL';
else if (Configuration::get('PS_SMARTY_CONSOLE') == _PS_SMARTY_CONSOLE_OPEN_)
	$smarty->debugging = true;

/* Use this constant if you want to load smarty without all PrestaShop functions */
if (defined('_PS_SMARTY_FAST_LOAD_') && _PS_SMARTY_FAST_LOAD_)
	return;

if (defined('_PS_ADMIN_DIR_'))
	require_once (dirname(__FILE__).'/smartyadmin.config.inc.php');
else
	require_once (dirname(__FILE__).'/smartyfront.config.inc.php');

smartyRegisterFunction($smarty, 'modifier', 'truncate', 'smarty_modifier_truncate');
smartyRegisterFunction($smarty, 'modifier', 'secureReferrer', array('Tools', 'secureReferrer'));

smartyRegisterFunction($smarty, 'function', 't', 'smartyTruncate'); // unused
smartyRegisterFunction($smarty, 'function', 'm', 'smartyMaxWords'); // unused
smartyRegisterFunction($smarty, 'function', 'p', 'smartyShowObject'); // Debug only
smartyRegisterFunction($smarty, 'function', 'd', 'smartyDieObject'); // Debug only
smartyRegisterFunction($smarty, 'function', 'l', 'smartyTranslate', false);
smartyRegisterFunction($smarty, 'function', 'hook', 'smartyHook');
smartyRegisterFunction($smarty, 'function', 'toolsConvertPrice', 'toolsConvertPrice');

smartyRegisterFunction($smarty, 'function', 'dateFormat', array('Tools', 'dateFormat'));
smartyRegisterFunction($smarty, 'function', 'convertPrice', array('Product', 'convertPrice'));
smartyRegisterFunction($smarty, 'function', 'convertPriceWithCurrency', array('Product', 'convertPriceWithCurrency'));
smartyRegisterFunction($smarty, 'function', 'displayWtPrice', array('Product', 'displayWtPrice'));
smartyRegisterFunction($smarty, 'function', 'displayWtPriceWithCurrency', array('Product', 'displayWtPriceWithCurrency'));
smartyRegisterFunction($smarty, 'function', 'displayPrice', array('Tools', 'displayPriceSmarty'));
smartyRegisterFunction($smarty, 'modifier', 'convertAndFormatPrice', array('Product', 'convertAndFormatPrice')); // used twice
smartyRegisterFunction($smarty, 'function', 'getAdminToken', array('Tools', 'getAdminTokenLiteSmarty'));
smartyRegisterFunction($smarty, 'function', 'displayAddressDetail', array('AddressFormat', 'generateAddressSmarty'));
smartyRegisterFunction($smarty, 'function', 'getWidthSize', array('Image', 'getWidth'));
smartyRegisterFunction($smarty, 'function', 'getHeightSize', array('Image', 'getHeight'));

function smartyDieObject($params, &$smarty)
{
	return Tools::d($params['var']);
}

function smartyShowObject($params, &$smarty)
{
	return Tools::p($params['var']);
}

function smartyMaxWords($params, &$smarty)
{
	Tools::displayAsDeprecated();
	$params['s'] = str_replace('...', ' ...', html_entity_decode($params['s'], ENT_QUOTES, 'UTF-8'));
	$words = explode(' ', $params['s']);

	foreach($words AS &$word)
		if(Tools::strlen($word) > $params['n'])
			$word = Tools::substr(trim(chunk_split($word, $params['n']-1, '- ')), 0, -1);

	return implode(' ',  Tools::htmlentitiesUTF8($words));
}

function smartyTruncate($params, &$smarty)
{
	Tools::displayAsDeprecated();
	$text = isset($params['strip']) ? strip_tags($params['text']) : $params['text'];
	$length = $params['length'];
	$sep = isset($params['sep']) ? $params['sep'] : '...';

	if (Tools::strlen($text) > $length + Tools::strlen($sep))
		$text = Tools::substr($text, 0, $length).$sep;

	return (isset($params['encode']) ? Tools::htmlentitiesUTF8($text, ENT_NOQUOTES) : $text);
}

function smarty_modifier_truncate($string, $length = 80, $etc = '...', $break_words = false, $middle = false, $charset = 'UTF-8')
{
	if (!$length)
		return '';

	if (Tools::strlen($string) > $length)
	{
		$length -= min($length, Tools::strlen($etc));
		if (!$break_words && !$middle)
			$string = preg_replace('/\s+?(\S+)?$/u', '', Tools::substr($string, 0, $length+1, $charset));
		return !$middle ? Tools::substr($string, 0, $length, $charset).$etc : Tools::substr($string, 0, $length/2, $charset).$etc.Tools::substr($string, -$length/2, $length, $charset);
	}
	else
		return $string;
}

function smarty_modifier_htmlentitiesUTF8($string)
{
		return Tools::htmlentitiesUTF8($string);
}
function smartyMinifyHTML($tpl_output, &$smarty)
{
    $tpl_output = Media::minifyHTML($tpl_output);
    return $tpl_output;
}

function smartyPackJSinHTML($tpl_output, &$smarty)
{
    $tpl_output = Media::packJSinHTML($tpl_output);
    return $tpl_output;
}

function smartyRegisterFunction($smarty, $type, $function, $params, $lazy = true)
{
	if (!in_array($type, array('function', 'modifier')))
		return false;

	// lazy is better if the function is not called on every page
	if ($lazy)
	{
		$lazy_register = SmartyLazyRegister::getInstance();
		$lazy_register->register($params);

		if (is_array($params))
			$params = $params[1];

		// SmartyLazyRegister allows to only load external class when they are needed
		$smarty->registerPlugin($type, $function, array($lazy_register, $params));
	}
	else
		$smarty->registerPlugin($type, $function, $params);
}

function smartyHook($params, &$smarty)
{
	if (!empty($params['h']))
	{
		$id_module = null;
		$hook_params = $params;
		if (!empty($params['mod']))
		{
			$module = Module::getInstanceByName($params['mod']);
			if ($module && $module->id)
				$id_module = $module->id;
			unset($hook_params['mod']);
		}
		unset($hook_params['h']);
		return Hook::exec($params['h'], $hook_params, $id_module);
	}
}

function toolsConvertPrice($params, &$smarty)
{
	return Tools::convertPrice($params['price'], Context::getContext()->currency);
}

/**
 * Used to delay loading of external classes with smarty->register_plugin
 */
class SmartyLazyRegister
{
	protected $registry = array();
	protected static $instance;

	/**
	 * Register a function or method to be dynamically called later
	 * @param $params function name or array(object name, method name)
	 */
	public function register($params)
	{
		if (is_array($params))
			$this->registry[$params[1]] = $params;
		else
			$this->registry[$params] = $params;
	}

	/**
	 * Dynamically call static function or method
	 *
	 * @param $name function name
	 * @param $arguments function argument
	 * @return mixed function return
	 */
	public function __call($name, $arguments)
	{
		$item = $this->registry[$name];

		// case 1: call to static method - case 2 : call to static function
		if (is_array($item[1]))
			return call_user_func_array($item[1].'::'.$item[0], array($arguments[0], &$arguments[1]));
		else
		{
			$args = array();

			foreach($arguments as $a => $argument)
				if($a == 0)
					$args[] = $arguments[0];
				else
					$args[] = &$arguments[$a];

			return call_user_func_array($item, $args);
		}
	}

	public static function getInstance()
	{
		if (!self::$instance)
			self::$instance = new SmartyLazyRegister();
		return self::$instance;
	}
}


Ice Cream and his wife's culinary skills.
Chris brings his wealth of triathlon experience and knowledge to the Indoor training environment. As a GB Age Group athlete he has medalled at both World and European Championships. Chris provides his clients with individual performance analysis utilising innovative technology and applies his unique coaching skill set to deliver a personal, adaptable and understandable approach to training, resulting in continual improvement and success for all his clients.


Strangers Have the Best Candy Patch is embroidered in Yellow / Black. Measures 4x1.5 inches. The patch can be sewn or ironed on. Do not iron on patches to leather or nylon material. Buy them cheaper with a wholesale account. Resell them on Ebay.


text:
package easymvp.boundary;

import io.reactivex.functions.Function;

/**
 * {@code DataMapper} transforms entities from the format most convenient for the use cases, to the
 * format most convenient for the presentation layer.
 *
 * @author Saeed Masoumi (saeed@6thsolution.com)
 */
public abstract class DataMapper<T, R> implements Function<T, R> {

}


text:
Price 2.50 €
A jednak Mieczkowski! O problemach z atrybucją niesygnowanych fotografii
It is Mieczkowski, after all! On the problems of attributing unsigned photographs
Author(s): Danuta Jackiewicz
Subject(s): Photography
Published by: Instytut Sztuki Polskiej Akademii Nauk
Keywords: Beyer; Karol; Mieczkowski; Jan; Warsaw; Old Town; attributing; photography; Polish photography; vintage photography; old photographic technique
Summary/Abstract: This article is concerned with a photograph of the Piwna Street in Warsaw with the characteristic bird sellers' cages exposed outside the houses (ill. 1). The author of this article had previously attributed this photograph to Karol Beyer (D. Jackiewicz, Sztuka fotografii. Portret, pejzaż, reportaż w fotografii polskiej XIX wieku. Katalog wystawy, Warszawa 1990, cat. no. 127), and this attribution became accepted in the subject literature (W. Mossakowska, Początki fotografii w Warszawie (1839-1863), Warszawa 1994, vol. I, pp. 80, 109). The photograph was reproduced using the woodcut technique in the illustrated weekly Kłosy on the 26th July 1865 (ill. 2). The accompanying caption informed that the trade in birds had just been moved from Zapiecek Street to Piwna Street. Together, this allowed the dating of the photograph to July 1865 at the latest. Still, however, nothing was known about its author. Another copy of this photograph has recently been discovered in the archives of the National Museum in Warsaw. Below the photograph, on a cardboard background is a printed text: "Fotogra: Jan Mieczkowski | w Warszawie." (ill. 3). In this way it became known that the authorship is other than what had previously been thought. This can also be applied to the photograph "Market on the Old Town Square" (ill. 4), also previously attributed to Beyer (Jackiewicz, Ibid., cat. no. 128; Mossakowska, Ibid., vol. I, pp. 80-81, vol. II, ill. 73). Its "painterly retouch", similar to that on the photograph of Piwna Street, allows us to suspect that we are also dealing here with the work of the Warsaw photographer Jan Mieczkowski. On the basis of this example, the author analysed the problems of attributing unsigned photographs, especially early photographs from the third quarter of the nineteenth century. If one does not have access to other copies of the same photograph with the photographer's signature provided (handwritten signature, facsimile of the signature, an ink or dry stamp of the photograph laboratory, the laboratory's company overprint on the front or back of the cardboard background), neither access to its reproduction in a periodical giving the name of the author, nor to an archival record, a series of considerations should be taken into account, and conclusions should be reached on the basis of the technical analysis of the object in question. The following are significant: the method of composing and operating light, the shade of the copy and its retouching, fragments of the photographic atelier which may be visible on the photograph, the themes dealt with by the photographer according to which one might presume that he could be author of the photograph. Knowledge about the collector from whose collection the photograph comes could also be helpful, amongst other things concerning his preferences and contacts in the photographic community, and also concerning his travels and the history of his collection.
Journal: Dagerotyp
Issue No: 13
Language: Polish
Wizja miasta. Warszawa na fotografiach Jana Bułhaka z 1920-1921 roku The vision of a city. Warsaw on photographs by Jan Bułhak from 1920/1921 2007 Okupowani w Warszawie. Album Occupied in Warsaw. Album 2008


text:
How many drinking and driving incidences can be linked to downtown Wilmington each year?
Brian Freskos
How many unsolved murders are there in Wilmington?
Is it legal for a lounge to limit guests to 35 and older?
Why do they open beer cans with "church keys"?
How did Whiskey Creek get its name?
Are county employees who are issued cars for work allowed to operate them for personal use?
Do law enforcement agencies auction off confiscated and unclaimed property in our area?
Is it legal to park a boat in the street in front of your home?
What kind of unmarked vehicles are used by Wilmington Police?
How do I give anonymous tips to police?
What is the history of Water Street Center at 106 N. Water St.?
Have handicapped parking spaces been removed downtown?
Wilmington Police Department Officers respond to reports of a incident involving several people as the bars in downtown Wilmington shut down around 2 a.m. Feb. 19, 2011. StarNews phot by Mike Spencer.
There's no way to know for sure. Some drunken drivers make it home without crashing or being caught. And there is no easy way to tell whether a driver that is arrested did their indulging downtown.
But thanks to Wilmington Police Department analyst Barry Coburn, we do have some idea of how many drinkers get behind the wheel in that section of the city.
Wilmington defines "downtown" as the area sandwiched between Fifth Avenue and the Cape Fear River, and the Isabel Holmes Bridge and Castle Street. In that area between Jan. 1, 2011, and May 15, 2013, police made 105 arrests for driving while intoxicated, mostly in the bar-heavy blocks around Market and Second and Front streets, according to Coburn's analysis.
Broken down by the year, the numbers look this:
In 2011, 53 arrests.
And between Jan. 1 and May 15 of 2013, 15 arrests.
Do drunken drivers use River Road to avoid law enforcement?
Do you have the legal right to follow someone who is obviously drunk?
Date posted: May 20, 2013


text:
Criminal Law: Theft Act 1968 Offences
Theft Act 1968 Offences
Section 1: Theft
Establishing Theft
The actus reus of theft is appropriating property belonging to another: s 1(1).
The mens rea of theft is established if the defendant was dishonest when he appropriated the property and intended to permanently deprive the other of the property: s 1(1).
What is Appropriation?
Appropriation is any assumption of the rights of an owner. This includes keeping or dealing with the property where the defendant initially acquired the property without stealing it: s 3(1). There can be multiple appropriations in the course of one transaction with property. However, there can only be one completed theft of a piece of property by one defendant: R v Atakpu (1994) Crim LR 693.
If the defendant purchased the property in good faith, section 3(2) provides that later assumption of ownership rights which that person believes themselves to have shall not be treated as theft just because the person transferring the property did not have good title to the property.
The following principles apply to determining whether there is an appropriation:
An appropriation is the assumption of any ownership right, even if it is not all of them: R v Gomez [1993] AC 442. For example, switching labels on goods in a shop is appropriation even before the goods are taken: R v Morris [1983] 3 WLR 697.
An appropriation can occur even where the defendant has the owner's consent to do the act: R v Gomez [1993] AC 442. This is because there does not have to be any immorality or impropriety for something to be an appropriation.
The defendant can appropriate property even if he simultaneously becomes its sole and indefeasible owner: R v Hinks [2000] 4 All ER 833. This might happen, for example, if the victim gifts property to the defendant – the appropriation is receipt of property in the gift.
The defendant must interact with the property at some point, whether by physically touching it or controlling the account in which money is contained. Causing the victim to transfer property to a third-party themselves is not appropriation: R v Briggs [2004] EWCA Crim 3662.
There is no requirement that the victim loses anything in practice. For example, the fact that the victim has the right to be compensated for the lost property by a third-party is irrelevant: Chan Man-sin v Attorney General of Hong Kong [1988] 1 All ER 1.
What is Property?
Section 4(1) defines property as including 'money and all other property, real or personal, including things in action and other intangible property.' This does not include land, wild mushrooms and flowers (unless picked for commercial purposes) and wild animals not reduced to another's possession: s 4(3). Services are also not property.
When Does Property Belong to Another?
Property belongs to another if another person has possession or control over the property, or possesses any property right or interest in the property: s 5(1).
Property can belong to another even where it is illegal to possess that property, such as where the property is illegal drugs: R v Smith [2011] EWCA Crim 66.
It does not matter that the property also belongs to the defendant so long as there is some other person to whom the property belongs: R v Bonner [1970] 1 WLR 838. A thief can also steal from another thief: R v Meech [1956] QB 549.
The victim possesses property if they have a significant degree of control and intend to possess the property. This can be broad, such as an intention to possess everything on the victim's land: R v Woodman [1974] QB 754.
Legal obligations to return property given by mistake and trust-enforcement rights count as relevant interests in property: s 5(2) and (4). Property is also treated as belonging to another if it was given outright to the defendant, but under a legally enforceable obligation to use it for a specific purpose: s 5(3).
If the victim writes a cheque for the defendant in exchange for consideration, the defendant acquire two pieces of property. The first is physical property in the paper. The second is a chose in action (the right to sue the victim's bank). However, the chose in action never belonged to anyone else. This is because it vested in the defendant the moment it came into being. As such in this situation, the defendant can only be convicted of stealing the physical paper: R v Preddy [1996] AC 815.
When is the Defendant 'Dishonest'?
The defendant's conduct is dishonest if ordinary and honest people, knowing or believing the circumstances to be as the defendant knew or believed, would consider it dishonest: Ivey v Genting Casinos [2017] UKSC 67. It was formerly the case that the defendant also had to appreciate that ordinary, honest people would consider his conduct dishonest, but this is no longer good law: R v Barton and Booth [2020] EWCA Crim 575.
Section 2 of the Theft Act 1968 creates three special categories in which the defendant is not to be regarded as dishonest:
Where the defendant believes he has a legal right to deprive the other person of the property, whether on his own behalf or on behalf of a third-party.
Where the defendant believes that he would have the consent of someone entitled to give it if they knew of the appropriation and circumstances.
Where the defendant believes that the person to whom the property belongs cannot be discovered by taking reasonable steps.
The mere fact that the defendant is willing to pay does not necessarily make him honest: s 2(2).
Intention to Permanently Deprive
Merely borrowing property is not theft. This is because the defendant intends to return the property rather than permanently deprive the other person of it. Borrowing motor vehicles and conveyances specifically can be an offence under section 12.
However, conditional intention to deprive will do. An example would be where the defendant picks up a handbag intending to steal only if there is something valuable in it: Attorney General's Reference (Nos 1 & 2 of 1979) [1980] QB 180. Prosecutors must be careful when wording indictments where the defendant has only conditional intent, however – they should not say that the defendant intended to steal a specific item: R v Easom [1971] QB 315.
As explained above, where the victim writes the defendant a cheque, the defendant might be charged with stealing the paper. However, cheques are returned to the victim once presented for payment. This means that normally the defendant will lack intention to deprive the victim of the physical piece of paper and so cannot be convicted of stealing that either: R v Clark [2001] Crim LR 572.
Where the defendant intends to return the property, he may still be treated as having intention to permanently deprive:
The defendant intends 'to treat the thing as his own to dispose of regardless of the other's rights' by taking to for such a period and in such circumstances that it is 'equivalent to an outright taking or disposal': s 6(1); or
The defendant possesses or controls property belonging to another and parts with it (without authority) to a third party, wherein it will only be returned to the defendant if he performs a condition he may not be able to perform: s 6(2).
For example, it might be theft under s 6(1) if the defendant takes a train season ticket intending to return it after it has expired. It might be theft under s 6(2) if the defendant gives goods to a pawn store.
Section 8: Robbery
Establishing Robbery
The actus reus of robbery is established where the defendant commits the offence of theft where immediately before or at the same time, and in order to commit theft, he uses force on any person or makes or seeks to make any person apprehend being then and there subjected to force: Theft Act 1968, s 8(1); R v DPP [2007] EWHC 739.
The mens rea of robbery is the same as the mens rea for theft, with the additional requirement that the defendant must intend to use force on a person or make another apprehend the use of force.
It is enough that the victim apprehends that force may be used on him, even if there is technically not an assault: R v Tennant [1976] Crim LR 133.
It is possible for force to be treated as used on a person (or feared by the person) even where the defendant only uses force on their property: See e.g. Corcoran v Anderton (1980) 71 Cr App R 104.
There must be some physical interaction with the victim for force to exist, however: P v DPP [2012] EWHC 1657.
Timing of the Force
The courts have been flexible about the timing of the force. The process of stealing is looked at as a whole. This means that force can be used 'at the time' of stealing even though it was used after appropriation occurred: R v Hale (1978) 68 Cr App R 415.
Section 9: Burglary
Establishing Burglary
There are two ways of establishing burglary:
The actus reus of the first way is entering any building or part of a building as a trespasser: Theft Act 1968, s 9(1)(a). The mens rea is intention to commit theft, infliction of grievous bodily harm or a criminal damage offence. The defendant must also intend to enter the building, knowing or being reckless as to the facts which make him a trespasser: R v Collins [1973] QB 100; R v Jones (1976) 63 Cr App R 47.
The actus reus of the second way is established if the defendant has entered a building or part of a building as a trespasser and steals or attempts to steal anything in the building or inflicts or attempts to inflict GBH: Theft Act 1968, s 9(1)(b). The mens rea is the same as the mens rea for theft, infliction of GBH, or an attempt to commit these offences. The defendant must also intend to enter the building, knowing or being reckless as to the facts which make him a trespasser: R v Collins [1973] QB 100; R v Jones (1976) 63 Cr App R 47.
Greater sentencing powers are available if the building is a dwelling or a vehicle or vessel in which someone lives: s 9(3)-(4).
What is a Building?
A building is a structure which is relatively permanent. It does not need to be complete, though a structure which is too unfinished may not be a building: R v Manning & Rogers (1871) LR 1 CCR 338. A building will normally be covered with a roof, though structures under construction which are intended to have a roof but one has not yet been installed can be a building: Ealing LBC, ex parte Zainuddain [1994] PLR 1.
Structures which are normally very temporary, such as tents, are probably not buildings even if they have been up for a long time. Sturdier structures such as portakabins might be.
Entering a Building
The defendant enters the building if any part of him enters, no matter how slightly: R v Davis (1823) Russ & Ry 499. This is true even if the defendant has not entered sufficient far to be capable of committing theft or any of the other relevant offences: R v Ryan [1996] Crim LR 320.
Under the old common law version of this offence, if a tool held by the defendant enters the building, this could be an 'entry'. However, it would not be enough if the only reason it entered the building is because it was being used to secure entry (such as where a drill cuts through a lock through to the other side). It is not clear if these principles apply to statutory burglary. This is because there has not been a case on the point.
Trespass bears almost the same meaning as under the civil law. In brief, a trespasser is someone who does not have permission to enter from someone entitled to give that permission. A visitor who has exceeded the terms and conditions of the permission they were given is also a trespasser: R v Jones & Smith [1976] 3 All ER 54. The only difference is that the classes of people who can give valid permission is broader – it can extend to people who live in the house who are not the occupier or owner: R v Collins [1973] QB 100.
It does not matter that the defendant entered involuntarily or mistakenly thought he was entitled to enter. However, this will be relevant to mens rea.
Dwelling is not defined by the Act, and the Court of Appeal has stated that it is a factual question which should not be specifically defined: R v Flack [2013] EWCA Crim 115.
If a building is usually lived in, it can remain a dwelling even though no one is presently living in it: Hudson v CPS [2017] EWHC 841.
It is not clear whether the defendant needs to be aware that he is in a dwelling for the enhanced sentencing powers to apply. It is possible, by analogy with the rules on trespassers, it is enough that the defendant is reckless.
Aggravated Burglary
Section 10 created an offence of aggravate burglary. It is committed whenever the defendant commits ordinary burglary while having with him a firearm (including airguns and pistols), imitation firearm (even if it cannot be discharged), offensive weapons (those made, adapted or intended to injure or incapacitate) or explosive.
The item must be possessed at the time of the burglary, not merely outside the building or in a getaway vehicle: R v Klass [1998] 1 Cr App R 453.
Whether the defendant has the weapon with him depends on factors such as the distance between the defendant and the weapon, its accessibility to him and the purpose of his acts: R v Henderson [2016] EWCA Crim 965.
There is no need to prove the defendant intended to use any offensive weapon brought with him in the course of the burglary: R v Stones [1989] 1 WLR 156.
The aggravated offence does not apply if the defendant embarks on the burglary without a weapon but arms himself with something nearby on encountering the victim: Ohlson v Hylton [1975] All ER 490. If he arms himself in the building before encountering the victim, this can constitute aggravated burglary provided he was armed when he stole something: R v O'Leary (1986) 82 Cr App R 341.
Section 21: Blackmail
Establishing Blackmail
The actus reus of blackmail is making an unwarranted demand with menaces: Theft Act 1968, s 21(1).
The mens rea of blackmail is intending to make the demand with a view to making a gain for himself or a third party or causing a loss to another: Theft Act 1968, s 21(1).
Unwarranted Demands and proper means
Demands can be explicit or implicit, direct or indirect. A demand is unwarranted unless the defendant believes that he has reasonable grounds for making the demand and believes the use of the menaces is a proper way of reinforcing the demand: s 21(1). This is a subjective test. This means there is no need for the demand or use of menaces to be objectively reasonable: R v Harvey (1981) 72 Cr App R 139.
'Proper' means is a wide term, but an act which the defendant knows or suspects is unlawful cannot constitute proper means: Harvey.
The Meaning of Menaces
'Menace' has a broad meaning, going beyond threats of violence to persons or property. It includes any action which an ordinary person of normal stability might find detrimental (such as the publication of damaging information) or which the defendant knows the victim in particular will find detrimental: Thorne v Motor Trade Association [1937] AC 797; R v Harry [1974] Crim LR 32; R v Garwood [1987] 1 WLR 319.
There is no need for the defendant to be the one who will carry out the menace: Theft Act 1968, s 21(2). In addition, it does not matter that the defendant cannot carry out the threat: R v Lambert [2009] EWCA Crim 2860.
Making Gains and Causing Losses
Gain and loss in this context refers to economic and proprietary gains and losses only: s 34(2)(a). As long as the defendant intends to cause the gain or loss, it does not matter that he fails to achieve this goal for whatever reason: R v Custance [2007] EWCA Crim 520.
Section 22: Handling Stolen Goods
Establishing Handling Stolen Goods
The actus reus of handling stolen goods is receiving stolen goods, or undertaking or assisting in their retention, removal, disposal or realisation by or for the benefit of another person, or arranging to do so: Theft Act 1968, s 22(1).
The mens rea of handling stolen goods is dishonesty in doing the relevant act and knowledge of belief that the goods are stolen: Theft Act 1968, s 22(1).
The defendant cannot be convicted of handling stolen goods in relation to his own acts of stealing the goods. The defendant likely must no longer be 'on the job' for a handling offence to be relevant: R v Atakpu (1994) Crim LR 693.
'Goods'
'Goods' refers to money and all forms of property except for land: s 34(2)(b). This includes things in action: R v Forsyth [1997] 2 Cr App R 299.
'Stolen'
Goods are 'stolen' if they were obtained by theft, fraud, or blackmail, or dishonest withdrawal from wrongful bank credit: s 24(4). It is not enough that the defendant believed the goods are stolen – they must have actually been obtained using one of the above offences: R v Haughten & Smith [1975] AC 476.
The goods cease to be stolen once they have been returned to the victim (or someone acting on their behalf) or the victim has lost any right to claim the goods in restitution law (typically when purchased by an innocent buyer): s 24(3). The victim or their representative must have acquired possession of the goods. Merely marking them or having the opportunity to examine them is not enough: Attorney General's Reference (No 1 of 1974) [1974] 2 All ER 899. The goods also cease to be stolen if someone else takes lawful possession of them. This is most relevant when the police take possession of the goods.
It is irrelevant whether the defendant acquired the goods from the thief, another handler or someone who was unaware the goods are stolen.
Representative Goods
Section 24(2)(a) provides that goods acquired by the thief in return for disposing of stolen goods count as being stolen themselves. So, if T steals a necklace and exchanges it for a car, that car counts as being stolen.
Section 24(2)(b) imposes the same effect on goods acquired by the defendant through the commission of a handling offence. So, if the defendant purchases a necklace from the thief knowing it to be stolen and then exchanges it for a designer handbag, that handbag counts as stolen.
The Different Forms of Handling
The actus reus of the s 22 offence creates four different types of handling:
Receiving goods. This happens if the defendant takes (sole or joint) control or possession of the goods with intent to do so: R v Watson [1916] 2 KB 385. This can be via an agent.
Undertaking the retention/disposal/realisation (by/for the benefit of another). This probably refers to a situation where the defendant sets out to do these things on his own.
Assisting in the retention/disposal/realisation (by/for the benefit of another): this generally needs another party, such as the thief.
Arranging to do one of the previous three acts: this will normally involve an agreement with another person.
The following are definitions for the key terms:
Retention means keeping possession or control: R v Pitchley (1973) 57 Cr App R 30. Merely using stolen goods is not enough: R v Sanders (1982) 75 Cr App R 84.
Disposal refers to exchanging the goods for other goods or services, or destroying the goods.
Realisation means exchanging the goods for other goods or money: R v Bloxham [1982] 1 All ER 582.
The requirement that each of these acts be done by or for the benefit of another person is designed to normally prevent the thief from also being convicted of handling. This is because the thief will necessarily at least retain the stolen goods for a time. The thief can be guilty of handling if he does one of the acts for the benefit of another, however. The purchaser of stolen goods is not considered to be another person who benefits for these purposes: R v Bloxham [1982] 1 All ER 582.
Criminal Offences Against Property Quiz
Test yourself on the principles governing the offences against property.
Roger intentionally damages a piece of government property (a coal-burning oven) while protesting climate change. When charged with criminal damage, he argues he has lawful excuse, because climate change is destroying the planet and he needs to draw attention to the issue. Will this defence succeed?
Select an answerYesThe law is unclearNo
Incorrect. Damaging property as an act of political protest is not a lawful excuse: R v Pritchard.
Paul knowingly makes a statement to Joanne, believing it to be false and attempting to fool Joanne into giving him money. She hands over the money. The statement just happens to be true. Has Paul committed an offence?
Yes, fraud by false representation
Yes, attempted fraud by false representation
Incorrect. If the defendant believes the statement to be false but it is in fact true, he may still be convicted of attempted fraud: R v Cornelius.
For the purposes of the offence of possessing articles for fraud, the prosecution must prove the defendant had a specific future fraud in mind. True or false?
Select an answerFalseThe law is unclearTrue
Incorrect. There is no need to show he had a specific fraud in mind: R v Sakalauskas.
The defendant borrows the victim's wedding ring, and loans it to a pawn store. He intends to pay the loan off and get the ring back, at which point he will return it. Is it possible to convict the defendant of theft?
No, because there is no appropriation
No, because the defendant is not dishonest
No, because there is no intention to permanently deprive
Incorrect. Where the defendant intends to return the property, he may still be treated as having intention to permanently deprive the other person if he parts with the property (without authority) to a third party, wherein it will only be returned to the defendant if he performs a condition he may not be able to perform: Theft Act 1968, s 6(2).
For the purposes of the fraud offence, when is a statement false?
If it is untrue or misleading and the defendant knows it is, or might be, untrue or misleading
If it is strictly untrue
If it is untrue or misleading
If it is untrue and the defendant knows it is untrue
Incorrect. A representation is false if it is untrue or misleading and the defendant knows it is, or might be, untrue or misleading: Fraud Act 2006, s 2(2).
Lauren asks Raphael to burn some books she has in a compost bin in her back garden. Stephen goes to the garden, and realises that if he does so the fire is likely to spread in a way which would endanger the lives of some children playing next door. He does it anyway. When he is charged with criminal damage with intent to endanger life, he argues that he had a lawful excuse because he had the consent of the owner of the books to burn them. Will this argument succeed?
Select an answerThe law is unclearYesNo
Incorrect. Unlike the basic criminal damage offence, the defendant does not have a lawful excuse merely because he believes he has consent or was acting to protect property: Criminal Damage Act 1971, s 5(1).
When establishing fraud by false representation, the prosecution must show that the victim was deceived by the false representation. True or false?
Select an answerTrueThe law is unclearFalse
Incorrect. There is no requirement that anyone actually be deceived by or act on the representation: Proctor v The Chief Constable of Cleveland Police.
When is a defendant dishonest?
When an ordinary, honest person with the defendant's factual beliefs would consider the defendant's actions dishonest
When an ordinary, honest person would consider the defendant's actions dishonest
When the defendant is subjectively aware that ordinary, honest people would consider his actions dishonest
When the defendant subjectively acknowledges their behaviour was dishonest
Incorrect. The defendant's conduct is dishonest if ordinary and honest people, knowing or believing the circumstances to be as the defendant knew or believed, would consider it dishonest: Ivey v Genting Casinos.
Roger learns that his brother Richard is being deported. He knows that the moment Richard lands in his home country, he will be murdered by corrupt government officials. Roger intentionally damages the plane that was set to deport Richard, giving Richard time to succeed in his asylum appeal. When charged with criminal damage, Roger argues he has lawful excuse, the government was acting in breach of international law by deporting Richard. Will this argument succeed?
Incorrect. Damaging property to prevent the government from acting in breach of international law is not a lawful excuse: R v Pritchard.
For the purposes of the offence of possessing articles for fraud, the defendant does not need to physically possess the article. True or false?
Incorrect. A person possesses an article if they can access and control it, even if another person physically holds the item: R v Montague.
For the purposes of theft, can a defendant be convicted for stealing property he owns?
Select an answerNoThe law is unclearYes
Incorrect. As long as another person also has a property interest in the object, the defendant can commit theft with respect to it.
Paul knowingly sends a letter to Joanne, containing a statement which he believes to be false and attempting to fool Joanne into giving him money. The letter never arrives. Has Paul committed fraud by false representation?
Incorrect. It is not clear whether the representation is made if it is not successfully communicated to anyone, such as where an email is sent but never read or a letter is posted but never arrives.
The defendant borrows the victim's month-long movie pass, intending to give it back after it has expired. Is is possible to convict the defendant of theft?
Incorrect. Where the defendant intends to return the property, he may still be treated as having intention to permanently deprive the other person if he intends 'to treat the thing as his own to dispose of regardless of the other's rights' by taking to for such a period and in such circumstances that it is 'equivalent to an outright taking or disposal': Theft Act 1968, s 6(1).
For the purposes of theft, is there an appropriation if as part of the appropriating act the defendant acquires indefeasible property in the object?
Incorrect. The defendant can appropriate property even if he simultaneously becomes its sole and indefeasible owner: R v Hinks.
The prosecution is seeking to establish the offence of burglary. For the purposes of showing that the defendant entered the building, the prosecution must show that the defendant was sufficiently within the building to commit the offence. True or false?
Select an answerThe law is unclearTrueFalse
Incorrect. The defendant enters the building if any part of him enters, no matter how small or slightly: R v Davis. This is true even if the defendant has not entered sufficiently far to be capable of committing theft or any of the other relevant offences: R v Ryan.
Liza purchases a car from Ricky, not realising or suspecting that it is stolen. Has she 'appropriated' the car?
Select an answerNoYesThe law is unclear
Incorrect. If the defendant purchased the property in good faith, section 3(2) of the Theft Act 1968 provides that later assumption of ownership rights which that person believes themselves to have shall not be treated as theft just because the person transferring the property did not have good title to the property.
Rachel owns a house which she rents out to young families. There is no one living in it at the moment as she is having the kitchen renovated. During the period in which the house is empty, it is burgled by John. Is the building a dwelling?
Select an answerThe law is unclearNoYes
Incorrect. If a building is usually lived in, it can remain a dwelling even though no one is presently living in it: Hudson v CPS.
Can a pure opinion be a representation for the purposes of fraud?
Select an answerYesNoThe law is unclear
Incorrect. It is not clear whether a pure opinion (one not based on facts at all) can be a false representation, though under the old law it could not be: R v Bryan.
Harold decides to steal from Richard's house. He is let into the building by Richard's daughter Yula, who is in love with him. Yula lives in the house, but does not own or occupy it. Can Harold be convicted of burglary?
No, because he had permission to enter and so is not a trespasser
No, because he is not dishonest
No, because he has yet to steal anything
Incorrect. The classes of people who can give valid permission to enter a building extends to people who live in the house who are not the occupier or owner: R v Collins.
Michael threatens Adrian that he will reveal sensitive information if Adrian does not have sex with him. Has Michael committed blackmail?
No, because he did not threaten violence
No, because there are no menaces
No, because there is no relevant gain or loss
Incorrect. Gain and loss in the context of blackmail refers to economic and proprietary gains and losses only: Theft Act 1968, s 34(2)(a).
Does a defendant who borrows an object intend to permanently deprive the owner?
Incorrect. Merely borrowing property is not theft because the defendant intends to return the property rather than permanently deprive the other person of it.
For the purposes of theft, is there an appropriation if the defendant has the owner's permission to interact with the property?
Yes, but only if the defendant goes beyond the permissions given
Incorrect. An appropriation can occur even where the defendant has the owner's consent to do the act: R v Gomez.
Lauren steals a car from Celestine and sells it to Ricky, who is unaware the car is stolen. Ricky then sells and gives the car to Julie, who does know the car was originally stolen from Celestine. Has Julie committed the offence of handling stolen goods?
No, because Julie was not involved in the original theft
No, because Julie did not acquire the car from the thief
No, because the car is no longer stolen
Incorrect. Goods cease to be stolen when they are purchased by a third-party in good faith. The sale to Ricky meant the goods ceased to be stolen, so Julie has not handled stolen goods.
To establish the mens rea of burglary, the prosecution must show that:
The defendant intended to enter the building and knew he was a trespasser
The defendant intended to enter the building and knew the facts which made him a trespasser
The defendant intended to enter the building and knew or was reckless as to the facts which made him a trespasser
Incorrect. The defendant must also intend to enter the building, knowing or being reckless as to the facts which make him a trespasser: R v Collins.
Paul knowingly makes a statement to Joanne, attempting to get Joanne to give him money. The statement is true and Paul believes it is true, but later it becomes false and he discovers this. Joanne hands over the money after Paul has discovered the fact is now false. Has Paul committed fraud by false representation?
Incorrect. If the defendant has made a true representation which, due to changing circumstances, later becomes false, he does not commit fraud by false representation if he does not correct himself: Government of the United Arab Emirates v Allen.
Katy makes a false statement to Arnau, believing it to be true and trying to persuade Arnau to give her money. It would be obvious to a reasonable person that the statement was false. Has Katy committed fraud by false representation?
Incorrect. Knowledge requires subjective true belief, and it is not enough that a reasonable person would have known the representation is false: R v Augunas.
Can a defendant be convicted of destroying or damaging property with intent to endanger life if no-one's life is actually endangered?
Incorrect. It does not matter that no life was actually endangered: R v Parker.
When establishing the offence of blackmail, the prosecution must show that:
The defendant did not believe he had reasonable grounds for the demand and that a reasonable person would not think the use of menaces was proper
A reasonable person would not believe the defendant had reasonable grounds for the demand and that the use of menaces was proper
The defendant did not believe he had reasonable grounds for the demand and that the use of menaces was proper
A reasonable person would not believe the defendant had reasonable grounds for the demand and the defendant did not believe that the use of menaces was proper
Incorrect. A demand is unwarranted unless the defendant believes that he has reasonable grounds for making the demand and believes that the use of the menaces is a proper means of reinforcing the demand: Theft Act 1968, s 21(1). This is a subjective test, so there is no need for the demand or use of menaces to be objectively reasonable: R v Harvey.
Theresa is trying to break into a building. She uses a screwdriver to break a window, and during this process the screwdriver enters the building, but no part of Theresa's body does. For the purposes of establishing burglary, has Theresa entered the building?
Incorrect. Under the old common law version of this offence, if a tool held by the defendant enters the building, this could suffice as an 'entry'. However, it would not be enough if the only reason it entered the building is because it was being used to secure entry: R v Horncastle. It is not clear if these principles apply to statutory burglary as there has not been a case on the point.
Elsie steals a necklace from a store, and exchanges it for a bicycle. Is the bicycle stolen property?
Incorrect. The bicycle is now a representative object: see Theft Act 1968, s 24(2)(a).
For the purposes of theft, can there be an appropriation if the victim does not lose anything?
Incorrect. There is no requirement that the victim loses anything: Chan Man-sin v Attorney General of Hong Kong.
What additional element must the prosecution show to establish aggravated burglary (as opposed to normal burglary)?
At the time of the burglary the defendant had a firearm, explosive, imitation firearm or weapon
The building burgled was a dwelling
At the time of the burglary the defendant intended to commit rape, criminal damage or infliction of GBH
At the time of the burglary the defendant intended to commit rape
Incorrect. See the Theft Act 1968, s 10.
For the purposes of theft, is it possible to appropriate an object without acquiring control over it or physically interacting with it?
Incorrect. The defendant must interact with the property at some point, whether by physically touching it or controlling the account in which money is contained. Causing the victim to transfer property to a third-party themselves is not appropriation: R v Briggs.
Marcus steals a car from Robert, who later manages to recover it. It is stolen again by Yula. Yula is caught immediately and charged with handling stolen goods, but her lawyer argues that the goods are no longer stolen. Will this argument succeed?
No, because they became stolen when Yula stole them
No, because they are still stolen from the date Marcus stole them
Incorrect. The goods cease to be stolen once they have been returned to the victim or the victim has lost any right to claim the goods in restitution law. The same act of stealing goods cannot be relied on as an act of handling stolen goods.
When does a person 'possess' property for the purposes of theft?
They have any degree of control and intention to possess
They have complete control and intention to possess the property
They have a significant degree of control
They have a significant degree of control and intention to possess the property
Incorrect. The victim possesses property if they have a significant degree of control and intend to possess the property. This can be broad, such as an intention to possess everything on the victim's land: R v Woodman.
What is the mens rea of criminal damage?
Intention to destroy property and knowledge that it belongs to another
Intention to destroy property or subjective recklessness
Intention to destroy property and knowledge that it belongs to another, or subjective recklessness as to either
Intention to destroy property or subjective recklessness, and knowledge that the property belongs to another
Incorrect. Firstly, the defendant must intend to destroy or damage property or be subjectively reckless as to whether the property would be damaged or destroyed: Criminal Damage Act 1971, s 1(1). Secondly, the defendant must know that the property belongs to another or be recklessness as to whether it belongs to another: R v Smith.
For the purposes of blackmail, what is 'menaces'?
The threat of violence to persons or property which the defendant can carry out
The threat of violence to persons or property
Any action an ordinarily stable person would find detrimental or which the defendant knows the particular victim will find detrimental, which the defendant is able to carry out
Any action an ordinarily stable person would find detrimental or which the defendant knows the particular victim will find detrimental
Incorrect. 'Menace' has a broad meaning, going beyond threats of violence to persons or property. It includes any action which an ordinary person of normal stability might find detrimental (such as the publication of damaging information) or which the defendant knows the victim in particular will find detrimental: Thorne v Motor Trade Association. It does not matter that the defendant cannot carry out the threat: R v Lambert.
For the purposes of the offence of threats to destroy or damage property, must the victim interpret the defendants actions as a threat?
Incorrect. It is not relevant how the victim actually interpreted the threat so long as the defendant intended the relevant effect: R v Cakmak.
Theresa enters Richard's house, intending to steal his jewellery. Once inside, she becomes concerned that Richard may still be in the building so she picks up a knife from the kitchen. Should Theresa be charged with ordinary burglary or aggravated burglary?
Ordinary burglary
Incorrect. The aggravated offence does not apply if the defendant embarks on the burglary without a weapon but arms himself with something nearby on encountering the victim: Ohlson v Hylton. However, if he arms himself in the building before encountering the victim, this can constitute aggravated burglary: R v O'Leary.
In which three circumstances specified by the Theft Act 1968 will a defendant not be considered dishonest?
A reasonable person would believe that the defendant would have the consent of someone entitled to give it if they knew of the appropriation and circumstances
The defendant believes he has a legal right to deprive the other person of the property
A reasonable person would believe that the defendant has a legal right to deprive the other person of the property
The defendant believes that he would have the consent of someone entitled to give it if they knew of the appropriation and circumstances
The defendant pays for, or proves that he is willing to pay to appropriate the object
The defendant believes that the person to whom the property belongs cannot be discovered by taking reasonable steps
Margaret shoots a gun at Robert, intending to kill him. She misses and destroys a window. Could she be successfully prosecuted for destroying the property with intent to endanger life?
Incorrect. The defendant must intend to endanger life by damaging property – it is insufficient that he intends to harm someone and incidentally damages property in the process: R v Steer.
A person is accused of fraud by abuse of position. What position must the prosecution demonstrate the person occupied to establish the offence?
The law is unclear
Any position of trust
A fiduciary duty
Any position in which the person has access to money
Incorrect. The meaning of a 'position' is unclear. It almost certainly includes all fiduciary duties (such as trustees and companies directors), but also appears to go beyond this. The government, when passing the law, suggested that it might also apply where the defendant is given access to the victim's property, for example. It appears that it also enough that the defendant has taken responsibility for collecting and distributing wages, even where a fiduciary duty does not exist: R v Valujes.
For the purposes of the offence of possessing articles for fraud, the article must have only illegal functions. True or false?
Incorrect. It is not necessary that the article only has illegal uses: R v Nimley.
For the purposes of the Theft Act offences, when is a piece of property 'appropriated'?
When an owner's core rights are assumed in relation to the property
When it is permanently or temporarily taken by the defendant
When it is permanently taken by the defendant
When any of the owner's rights are assumed in relation to the property
Incorrect. Appropriation is any assumption of the rights of an owner, including keeping or dealing with the property where the defendant initially acquired the property without stealing it: Theft Act 1968, s 3(1).
Paul knowingly makes a statement to Joanne, attempting to get Joanne to give him money. The statement is true and Paul believes it is true, but later it becomes false and he discovers this. Joanne hands over the money after Paul has discovered the fact is now false. Has Paul committed fraud by non-disclosure?
Select an answerNoYesIt depends on whether he has a duty to disclose
Incorrect. The defendant commits fraud by failure to disclose if they dishonestly fail to disclose information to another person when they are under a legal duty, intending by this to make a gain for himself or another, or to cause another a loss, or to expose another to the risk of loss: Fraud Act 2006, s 3(1).
Which of the following three structures could constitute a building for the purposes of the burglary offence?
A marquee
A tree house
A shed
A canopy
A tent
A under-construction home which has not had the roof installed
For the prosecution to prove robbery, must there be an assault?
Incorrect. It is enough that the victim apprehends that force may be used on him, even if there is technically not an assault: R v Tennant.
Theresa enters Richard's house, intending to steal his jewellery. Once inside, she encounters Richard, and panics, picking up a nearby knife. Should Theresa be charged with ordinary burglary or aggravated burglary?
Incorrect. The aggravated offence does not apply if the defendant embarks on the burglary without a weapon but arms himself with something nearby on encountering the victim: Ohlson v Hylton.
Which four factors are relevant to whether the property has been 'damaged' for the purposes of criminal damage?
Whether or not the act improves the value of the property
The nature of the property
Whether or not the property is completely destroyed
The method used to affect the property
To what extent the property can still be used
What the defendant intended to do with the property
Whether there has been physical intrusion into the property
The defendant dishonestly tricks the victim into writing him a cheque. The defendant provided consideration. The defendant has taken the cheque but not cashed it. What has the defendant stolen?
The paper and the corresponding money
The paper only
The paper and the chose in action
Incorrect. If the victim writes out a cheque for the defendant in exchange for valuable consideration, the defendant acquire two pieces of property – physical property in the paper and a chose in action (the right to sue the victim's bank). However, the chose in action never belonged to anyone else because it vested in the defendant the moment it came into being - the defendant therefore does not acquire property belonging to another. As for the paper, cheques are returned to the victim once presented for payment. This means that normally the defendant will lack intention to deprive the victim of the physical piece of paper and so cannot be convicted of stealing that either: R v Clark.
IPSA LOQUITUR > Criminal Law Revision > Criminal Law: Theft Act 1968 Offences


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This is your chance to fully immerse yourself in the sports lifestyle that you have always dreamed of. It's a brilliant field as it can give you future opportunities of meeting the celebrity athletes that you have idolized since you were a kid. We hope our tips were helpful, and if you need any more information be sure to look at this company.


By 10:00 this morning it was 23 degrees and sunny, I arrived in Lille town square at 19:18 with no clouds in the sky and the sun was setting, although a little breezy it was pleasant. I wandered the square looking for a place to put my bike and get a coffee, I found one outside Mister Coffee overlooking Lille square. I purchased a latte and a muffin although I paid an extortionate €7 I really enjoyed it. Whilst in the square I was asked twice what I was up to and after filming outside the opera house Fabian came over for a chat. I think all the gear on the bike and the fact I was talking to a GoPro camera attracted some attention.
I sat on the opera house steps and updated my journal, the sun had nearly gone by the time I set off to find somewhere to sleep. As I headed out of Lille several cyclists pulled alongside me for a chat. One in particular was a character, his name was Andre and he looked like a professor you'd see in cartoons, he had bright orange goggles on and messy Grey hair riding a knackered bike, however he turned out to be a star, "oh you have your bed on the back of your bike" was his opening sentence, "where are you heading" I told him my plans and that I was heading to Belgium but was looking for somewhere to sleep, he said he lives in Roubiax which is on the way and to follow him, so follow him I did.
Along the way he pointed out hundreds of places to wild camp and even a budget hotel for €20 a night (tempted). He was one to break a rule or two as we cycle the wrong way up one way streets and even against traffic on the wrong side of the road, through subways over paved areas, we cycle for nearly an hour before saying goodbye. He pointed out the way or said I could go back a little and sleep in the cemetery as the residents are very quite. What a guy.
I continued on the main road, mainly because it was down hill and I had little peddling to do, I eventually came to an industrial estate, Andre had said they were quite place at night and I shouldn't get disturbed. I cycle around the estate and liked the look of a spot near the Peugeot dealerships fence, until 2 extremely noise Alsatians came running towards me luckily they were on the right side of the fence but I wouldn't be sleeping there. It was about 11pm and I was getting tired but I had come to the other end of the industrial park, there was a Roundabout in front of me and I remember reading about someone who had slept on a Roundabout before, so I pushed my bike across the road and into the middle of the Roundabout. It was perfect, large round thing in the middle of the road but was surrounded by a large hedge and had trees on, two were spaced far enough apart to set the hammock up. I had a great night sleep undisturbed. A few notes to self, use netting as lots of midges, have hammock a little higher so dandelions don't tickle you at night.
I woke at 04:20 but reset my alarm until 06:00 it rained from 04:30 – 06:00 but I was warm and very comfy. I balanced all my gear on the bike and went across the road to re-pack, luckily I noticed that I had dropped my sleeping bag on the Roundabout so managed to retrieve it.


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Q: Fisher's exact test on k-mers counting - Bioinformatics I'm quite new to the bioinformatics field, so I hope I won't make a too stupid question.
I'm trying to compare different samples by applying some statistical tests (i.e. Fisher's exact test) to the counts of the common k-mers extracted from Illumina reads of two different samples, where the main goal would be to identify different CNVs. But at the same time, I'm also focusing on k-mers which are present only in one sample but not in the other. Now, my main question is: would it make sense to apply such a test even to those k-mers, considering a count of 0 for the sample where those k-mers are absent?
I thought about it cause the absence of a k-mer from one sample may be due to the sequencing process, and not to a real absence from the sample, so to compare 0 to the abundance of such a k-mer in the other sample may be relevant. But I'm not sure if it is correct, indeed.
The goal is trying to assess new methods, not to find the CNVs as soon as possible, so that's why I'm not using existing tools.

redpajama_set_name: RedPajamaStackExchange


The latest release in The Adelphi Collection from the BFI is a double-dose of effervescent vintage comedy- drama bringing two more rare Diana Dors films to DVD for the first time. The Great Game and Miss Tulip Stays the Night both star Britain's blondest bombshell at her saucy best.
Goals and glamour go together in The Great Game (Maurice Elvey, 1953), a high-scoring drama of football league corruption, shot on location at Griffin Park, historic home of Brentford F.C. and even featuring guest appearances from some of the team's players. With fine performances from James Hayter as Burnville United's unscrupulous team chairman, Thora Hird as his long-suffering assistant, and Diana Dors enjoying herself as man-eating secretary Lulu – not to mention a splendid eyeball-rolling turn from Dad's Army's John Laurie – the final result is a nostalgic Saturday afternoon treat for movie buffs and football fans alike.
Laughter and thrills mingle in Miss Tulip Stays the Night (1955) directed by Leslie Arliss. Gorgeous Kate Dax (Diana Dors) and her crime-writer husband, Andrew (Patrick Holt), investigate the murder of eccentric spinster Miss Tulip (Cicely Courtneidge) at a remote country cottage. With the help – or hindrance – of bumbling P.C. Feathers, deftly played by British comedy legend Jack Hulbert, will they ever crack their crazy case and finally figure out whodunit? The distinguished supporting cast includes Joss Ambler, Pat Terry-Thomas and comedy veteran A.E. Matthews.
Newly mastered to High Definition from the original film elements preserved at the BFI National Archive, the films are presented with an illustrated booklet containing film notes, original promotional materials and new essays, including a look at Diana Dors' clothes and style.