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Catholic Education is Indispensable in Transforming the Culture
By Fr. Shenan J. Boquet|2019-11-02T20:05:38-05:00August 13th, 2018|Categories: News and Commentary, Spirit & Life Newsletter|Tags: Canada, Ireland, Irish Referendum, Pope Saint John Paul II, sex education, Spirit and Life newsletter|
Culture of Death or Culture of Life?
"In order that the Catholic school and the Catholic teachers may truly make their irreplaceable contribution to the Church and to the world, the goal of Catholic education itself must be crystal clear. Beloved sons and daughters of the Catholic Church, brothers and sisters in the faith: Catholic education is above all a question of communicating Christ, of helping to form Christ in the lives of others. … Yes, it is above all a question of communicating Christ, and helping his uplifting Gospel to take root in the hearts of the faithful." –Message of St. John Paul II to the National Catholic Educational Association of the United States
In increasingly secular Ireland, some non-Catholic parents are complaining that they can't find any non-Catholic schools in which to enroll their children. Indeed, the Catholic Church in Ireland still owns and operates over 90% of the schools. One mom, who is an atheist, fretted that if she sends her daughter to the local school she might be "indoctrinated" into the Catholic faith.
Having just returned from Ireland, however, it seems that this mom's fears are misplaced. Many Irish Catholic parents told me they are concerned about precisely the opposite problem: that by sending their children to Catholic schools they risk having their children indoctrinated out of the faith. Whether in Southern or Northern Ireland, the comments I heard from parents and other Catholics were the same. "Our young people are not being taught their faith in our schools." "Our Catholic schools and parish education programs have been corrupted by a terrible cancer that teaches and promotes what is contrary to our faith."
Ireland's De La Salle College, Waterford, in 1902
One needn't look far for evidence that Catholic education in Ireland is failing. By far the starkest evidence is the recent referendum on abortion. Amongst 20-to-30-year-olds, some 80% voted yes for abortion. The numbers were similar in the case of same-sex 'marriage', with overwhelming numbers of young Irish voting to change the definition of marriage in 2015. Meanwhile, Church attendance has been plummeting in recent decades: whereas well over 80% of Irish Catholics attended Church weekly in the early '80s, that has since dropped to 41%. Those numbers are significantly worse among young Catholics.
There has been a radical shift in Irish culture, which did not occur in a vacuum. Of course, there are many factors that have contributed to this shift. Nevertheless, many of the Irish parents I spoke to were quite clear that in large part they blamed the Catholic schools and parish education programs. If over 90% of Irish schools are owned and operated by the Catholic Church, and yet over 80% of young Irish people are voting to legalize the killing of unborn babies, clearly, something has been catastrophically lost in translation.
It's Not Just Ireland
I don't mean to pick on Ireland. In fact, almost everywhere I go I hear concerns from parents about so-called Catholic schools and education programs that have been taken over by bureaucratic educators who are hell-bent on eviscerating the Catholic identity of the school, or, even worse, promoting a pseudo-Catholicism that uses the language and culture of the Catholic faith to promote values that are polar opposite to what the Church teaches. The relativistic mindset reigns at most schools and universities, including many of those calling themselves Catholic.
One startling recent example comes to mind. I have told you previously about the struggle by Ontario parents to stop a new sex-ed curriculum imposed by the previous provincial government. The curriculum was at the vanguard of radical liberal ideology, introducing children in the earliest grades to graphic sexual topics, teaching them that there are numerous so-called "genders," and treating fornication, masturbation, and homosexuality as normal, acceptable sexual practices.
Recently, however, the newly-elected conservative Ontario government announced that they are scrapping the curriculum – fulfilling a campaign promise they made to the tens of thousands of Ontario parents who had complained. One of the first organizations out of the gate with a statement was the Ontario English Catholic Teachers' Association (OECTA) – the official union of Catholic teachers in the province. And what did these Catholic teachers have to say? Amazingly, they expressed their "great disappointment" with the decision, because, they said, "a modern and comprehensive Health and Physical Education curriculum is key to promoting healthy living."
What an extraordinary betrayal of the students entrusted to their care, and the parents who believe that by sending their children to Catholic schools, they will actually learn the Catholic faith! But then again, OECTA is the same group that routinely marches in the Toronto gay pride parade, and that recently criticized a school board that had passed a pro-life resolution for being "needlessly divisive."
When I read about things such as this, it is almost impossible not to think of Christ's stark warning: "But whoever causes one of these little ones who believe in me to sin, it would be better for him to have a great millstone fastened round his neck and to be drowned in the depth of the sea."
Second only to parents, teachers labor under a great burden of responsibility: the responsibility to impart truth and to model for children in the most impressionable years of their lives the behaviors that will bring them to Christ. Sadly, many Catholic schools and individual teachers have abused the sacred trust given to them by parents, introducing into the classroom error and gross immorality.
The Power of a Good School
St. Elizabeth Ann Seton, Patron Saint of Education
On the other hand, in my travels I have also had the privilege to witness the remarkable fruits when Catholic schools remain faithful to their Catholic identity and are careful to ensure that their faculty and staff are faithful, practicing Catholics.
In the United States in recent years, for instance, we have seen the creation of a number of small, independent, privately-funded Catholic colleges. In most cases these colleges have a fraction of the budget, and a fraction of the student population of the large, ostensibly "Catholic" established universities. And yet, a staggeringly disproportionate number of vocations to the priesthood and religious life come from graduates from these colleges. Furthermore, many of the graduates of these colleges end up getting married to one another, having large families, and diligently bringing their children up in the faith.
It is no exaggeration to say that the future of the Catholic Church in the United States largely depends upon these colleges. Their apparent insignificance in worldly terms belies the disproportionate influence that they are having on the Church and the culture. They are truly the leaven in a godless age.
What distinguishes these colleges is their unstinting fidelity to the vision of Catholic education outlined by St. John Paul II in his apostolic exhortation Ex Corde Ecclesiae. Every aspect of their curriculum and culture is oriented towards "communicating Christ." True Catholic education exists to provide an environment in which students are enabled to build and deepen their relationship with the Triune God, to foster an academic culture aimed at the pursuit of truth, and to actively promote growth in virtue. A Catholic university, says St. John Paul II, should be "an authentic human community animated by the spirit of Christ."
What these colleges understand is that education cannot be separated from the formation of the human person and the development of his vocation — whether secular or religious. No matter how strong the faith of a person might be, without a certain degree of practice in the virtues, it will be hard not to be led exclusively by the emotions and impressions that constantly enter our minds. Not only does this have moral ramifications, it also has intellectual ones: a person who is at the mercy of his passions is also prey to being manipulated by the fashions of the moment and is poorly equipped to enter the workforce and contribute constructively to society.
This is the great irony of the so-called "comprehensive sex education" programs embraced by so many school boards and schools. The self-declared aim of most modern educational programs is to prepare students for the work force. However, these schools then educate their students in selfish immorality, actively working against the formation of character by training in the virtues. No matter how much technical information that you cram into a student's head, without a formation in virtue, he or she will lack the habits and higher purpose that will drive him or her to work reliably and to become a citizen whose life builds up, rather than tears down, society.
Our Great Need: Renewal in Catholic Education
This is why St. John Paul II so urgently exhorted parents to prioritize education. "Parents must set themselves very definite priorities, such as the determination to have schools in which their children's faith will be respected, fostered and enriched; schools in which their children learn the value and beauty of the Church's teaching," he said. "They must also see to it that their own homes are places in which these values are first fostered and lived. Parents' own practice of the faith, their own love for Christ, is of course fundamental."
Transformation of culture begins through the training of personality and character in the home; but the next most intimate partner in the project of forming persons is the schools. For six or seven hours, every day, our children's minds are under the influence of a number of authority figures, whose ideology may radically conflict with that of our faith. Ideologues are always keenly aware that he who controls the minds of the next generation, controls the future. This is why anti-life and anti-family extremists have focused so much of their energies on dominating the university faculties. If we are to have any hope of fighting the Culture of Death and replacing it with a Culture of Life, Catholics everywhere must begin to take education deadly seriously.
Parents must be willing to sacrifice enormously either to send their children to new schools, or to homeschool them. They absolutely must take a keen interest in the culture and curricula of their children's schools. They must be willing to invest enormous time and resources in starting new schools and supporting good local schools. And they must be prepared to compensate for any deficiencies in their schools by cultivating a robust and organic Catholic culture within the home, one that includes the conscientious study of Scripture and Church documents.
Carol Avian August 13, 2018 at 11:09 PM	- Reply
+J.M.J.
Ex Corde Ecclesiae by itself is not good enough. We need Ex Corde Ecclesiae through the entire curriculum, nursery school through doctoral level, and widely available, affordable, and accessible all around the world, especially in all the dioceses in the U.S.A. Please see Loyola and the Educational System of the Jesuits by Fr. Thomas Hughes, S.J.: at least originally, out of concern for the rights of God, His Church, parents, students, faculty, other staff, and nations and the larger society, faculty people were not allowed to dissent from Church teaching. In addition, all academic subjects belong to God, so we should be able to bring to Church teaching, and the saints into any and every subject area, and be free from anti-Catholic materials in the classroom. That being said, there can be literary works by Catholics, that illustrate many Gospel values, such as J.R.R. Tolkien's Lord of the Rings trilogy, which could be examined in conjunction with Catholic Scriptures, Catechism of the Catholic Church, Papal encyclicals, such as Casti Connubii, saints' writings, and any possible faith and moral issues of contention (e.g., I thought I heard that some Argentinian priest had raised some issues, such as about orcs, and that there is no such thing as an irredeemable race). Also, non-Catholic materials can have value in reflecting elements of Church teaching on faith and morals, and dangers of going one's own way, astray from Christ, such as Herman Melville's Moby Dick or the While Whale. Also, we don't want to forget St. Thomas Aquinas as a patron saint of education, and maybe look at monastic schools as models as well as universities. Thanks for your consideration.
In caritate Christi,
Mrs. Richard Avian (Carol Avian)


A book by an Anglia Ruskin University graduate will be distributed to every reception-age child in the country in the autumn as part of a charitable initiative.
The children's reading charity Booktrust will distribute 700,000 copies of Nadia Shireen's The Bumblebear due to its strong storytelling attributes, clear message about inclusivity and realistic school setting.
The tale, about a bear who infiltrates 'bee school' on a honey-stealing mission, is being distributed as part of the Time to Read scheme. The initiative was launched last year by Booktrust to encourage parents and carers of reception-age children to read with them on a regular basis.
Nadia, who lives in Tufnell Park, London and graduated from her MA Children's Book Illustration course in 2010, admitted the news was "mind-blowing".
"It's a huge privilege that so many kids will be able to read my book. Booktrust does an amazing thing and gets books to children who don't necessarily have access to them. At the age of four or five, children's minds are so open and they're in charge of how they interact with books, so it is an unquantifiable gift to have my book chosen. It's mind-blowing really."
Nadia, 38, who also has a law degree, decided to undertake the course part-time while working as a magazine journalist in London. Her books first came to the attention of publishers at an Anglia Ruskin degree show.
The Bumblebear was published by Penguin Random House Children's Books, who have also recently published her latest book, The Cow Who Fell to Earth.
"We are thrilled that Nadia Shireen's The Bumblebear will be reaching so many children across the UK, and to be working with Booktrust to support this wonderful campaign.


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Today on May 14, 2012, we have 63rd match between Kolkata Knight Riders vs Chennai Super Kings at Kolkata at 20:00 local time. We have predicted the winner.
And the winner of today's game will be Kolkata Knight Riders.
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Prasad GVSV Bhavana, a punter based in Hyderabad, was supremely bullish about the prospects of Tata Motors, the blue-chip automobile behemoth.
Accordingly, he packed his portfolio with a massive consignment of Tata Motors' futures.
As of 9th August 2017, on the eve of Tata Motors' quarterly results, he held a treasure trove of 30,000 August 2017 futures, 30,000 September 2017 futures and 30,000 October 2017 futures.
Unfortunately for Prasad, Tata Motors reported poor results on 10th August 2017 with the result that there was a massive slump in the prices of Tata Motors Futures contracts.
By the EOD, Prasad was staring at a MTM (Mark-to-Market) loss of Rs. 32,76,000 on his holdings of the Tata Motors futures.
The steep slump in the prices of Tata Motors Futures contracts triggered alarm bells in Zerodha's H.Q. because Prasad had a shortfall of margin amounting to Rs. 30.50 lakh.
Without waiting for Prasad's consent, Zerodha squared off 75,000 shares of Tata Motors' futures at whatever price could be realized for it.
Zerodha claimed that it was authorized to do so under Clause 19 of the Risk Disclosure document which empowers Zerodha to liquidate/ close out all of a client's position for non-payment of margins etc.
It is also made clear in the Risk Disclosure document that all losses on account of such liquidation have to be borne by the client.
At this stage, we have to compliment Prasad because instead of meekly accepting what Zerodha claimed, he decided to battle them.
He alleged that Zerodha was at fault for the margin shortfall because they never sent/ delayed sending the email and SMS regarding the margin statement.
He also claimed that he had sufficient holdings in other stocks etc which could have been used to bridge the margin shortfall.
He alleged that Zerodha's abrupt move of liquidating his holdings led the price to fall more than it would have in normal circumstances and that he suffered more loss than he would have if he had himself liquidated the holdings.
Zerodha is part of 'Bear cartel'?
In a masterstroke, Prasad turned the tables on Zerodha.
He alleged that they or their employees may be part of a "Bear cartel" which would have benefitted from the slump in Tata Motors' stock price and that there may be "foul play" in the abrupt dumping of his holdings by Zerodha.
A distinguished panel of three arbitrators examined threadbare the claims and counter-claims of Prasad and Zerodha.
After a lot of pontification about the facts, the panel found Zerodha guilty of not sending proper SMS and email messages regarding the margin statements.
"Admittedly, the margin statements would be ready later in the night and could be sent only by the next day. As such, the client cannot be expected to work out the complex SPAN margin, etc dynamically and take appropriate corrective action," the Panel observed.
It also held that Zerodha "cannot set aside the responsibility to provide the margin statements promptly so that the clients can take the required action".
Zerodha was also slammed for cryptic SMS messages.
"The SMS messages sent by the Respondent did not provide details regarding the extent of shortfall and the amounts required to make good the shortfall. As such, the Applicant could not have immediately remitted the required amounts," the expert panel held.
Ultimately, the arbitrators held that Zerodha acted in undue haste to liquidate the positions of a COMPLIANT customer, causing him huge losses.
It was held that if only Zerodha had waited a little longer, Prasad could have remitted the required funds. In that case, his outstanding positions could have been dealt with by him as per his plans.
The Panel noted that if Prasad had sold off the Tata Motors' futures by himself, he could have realized Rs. 365.70 lakh.
However, because of Zerodha's action, Prasad could only realize Rs. 284.82 lakh.
Zerodha was ordered to pay Prasad the difference between the two amounts being Rs. 36.78 lakh as compensation.
"This loss is not a notional loss, as the Respondent had unfairly squared off the positions causing actual loss to the Applicant," it was held.
However, Prasad's claim for compensation of Rs. 5 lakh for "mental agony" was rejected by the experts.
Zerodha rushed to an appellate panel to challenge the order of the arbitration panel.
However, this turned out to be tactical blunder because Zerodha got an earful for its poor practices.
The Appellate Panel (by majority) accused Zerodha of not undertaking proper due diligence of clients before registering them for derivative and high leverage transactions.
It was noted that while Prasad had an annual income of between one to five lakhs, he was allowed exposure amounting to Rs. 4 crore in the Tata Motors' futures.
"It is concluded that appellant is not conducting proper due diligence of the clients, not assessing the financial and risk profile of the clients, profiling the risk bearing capacity of clients especially in derivative products. Respondent is allowed to take leverage position 80 times of his annual income," the majority held, damning Zerodha.
The majority of the Appellate Panel was clearly on the warpath against Zerodha.
They accused Zerodha of "encouraging heavy volume and rampant speculation and creating extraordinary turnovers".
They advised Zerodha that it has to "guide and counsel" its clients as per their financial background and risk taking capacity in derivative products.
Clients should be advised of the risks and rewards associated with derivative products and complexities involved in derivative trading, it was held.
"Proper due diligence and client profiling is necessary for healthy and cordial business relationship between trading member and client," the majority observed.
The majority worked out the loss suffered by Prasad at Rs. 28.95 lakh and ordered Zerodha to pay him the amount with interest.
However, all was not lost for Zerodha because Hon'ble Ms. A. M. Durga Kumari decided to defy her colleagues and dissented from their view.
Hon'ble Durga Kumari slammed Prasad for not monitoring the price movement of Tata Motors and accused him of displaying "lack of seriousness disregarding his high stakes in the stock".
The dissenting arbitrator was also not impressed by Prasad's defense that he did not receive the email and SMS.
She held that Prasad ought to have logged into his account on Zerodha's website and ascertained the details himself.
"The basic and primary responsibility lies with the Respondent (Prasad) to take care of his investments. Being fully aware of the impending volatility of the Tata Motors on the 10th August 2017, he failed to monitor the status of his Futures Contracts of the said stock, in spite of having such high stakes and instead tried to shift his responsibility to the Appellant (Zerodha)," the lady arbitrator held.
"The Respondent (Prasad) could not explain as to why he did not make use of the web portal provided by the Appellant to know the status of his account. Instead, he made complaints like his phone did not work, a contract note was not received in email, and he was not conversant with Span marginal calculation and so forth. These ground are on thin ice and not maintainable, considering that he is a signatory to the internet agreement," Durga Kumari held in a firm tone.
Hon'ble Durga Kumari further suggested that Prasad was a novice and "ought to have educated himself about the risks involved in Futures Market, the conditions, clauses, procedures and policies applicable and the usage of internet applications".
She appears to have deep knowledge about the working of the markets because she rightly observed "the inherent trade risks in Futures Market, the mechanism and dynamics of Futures market need alertness and readiness to supply funds within very short notice and keen monitoring of stock prices on real time basis".
Ultimately, she branded Prasad as a novice by holding that "his conduct in handling the matter clearly shows that he did not gear himself up to operate in Futures market" and did not act with the "required urgency and seriousness in the matter considering his heavy stakes in the stock".
Zerodha was issued a clean chit and it was held that it was "professional and fair" in its conduct and that "the squaring off was required as per the parameters on which this market works".
Novices should be disbarred from dealing in derivatives?
Keeping aside the legalities of the matter, it appears prima facie that Zerodha goofed up by allowing a novice access to complex derivatives products, even though these products have been described as "weapons of mass destruction" by none other than Warren Buffett.
Also, allowing a person with an annual income of Rs. 1 to Rs. 5 lakh to rack up exposure of Rs. 4 crore appears to be clear buffoonery on Zerodha's part.
Hopefully, Zerodha will learn from the bitter lesson and either totally ban novices from dabbling in derivatives and/ or will educate them properly about the risks and rewards, as suggested by the Hon'ble Arbitration Panel!
Clearly, the income tax authorities should probe the income of Mr. Prasad.
This gentleman held 2 to 3 Cr of Tata Motors stock, amongst other stock. For people with such large holdings, allowing an exposure of Rs 4 Cr is not buffoonery, but smart business for Zerodha (else, his business would move elsewhere). For the learned judges to determine whether he was a novice, or not, would depend on the transaction history (which is not discussed in this article). If his punt had gone right, he could well have had profits exceeding 30 Lakhs (and maybe even more) on just this one stock.
For him to claim an income of Rs 5 Lakh is a travesty. By going to court, he will now have attracted the attentions of the Income Tax authorities. This was tactically a bad move for him.
You are confusing aggressiveness on the part of ZEROdha as "smart business". This is a common fallacy in India. While Prasad might attract the attention of the IT authorities, ZEROdha should also be probed by SEBI, the ED as well as IT.
Zerodha is just a member of the trading exchanges. They neither have the responsibility nor the authority to limit the exposure on the basis of income of the client. So long as margins are available, they are bound to permit the client to trade. In fact, the concept of fixing trading limits on the income of the client is completely flawed. Does that mean someone with losses in the previous year, that means negative income, less than zero cannot trade? With little bit of thinking, the absurdity of such a thing will be more than clear.
It is not just one concern but there are two in reality. 1.Giving huge margin and tempting the traders to take huge bets. 2.Other part is encouraging rampant trading with every customer. I have seen scores of people getting into trading with the lure of making quick bucks and huge profit. Most of the IT guys sitting at desk are flooded with algorithims, confirmation of trend in derivative stocks/nifty, profit potential and so on. Naturally most of them fall for it without realizing the dangers, addictions and financial loss. Like it or not, these trading platforms are turning into gambling dens.


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Richard A. Levan
Ryan J. Levan
The Supreme Court's Recent Decision in Liu V. SEC Raises More Questions Than Answers
Comments Off on The Supreme Court's Recent Decision in Liu V. SEC Raises More Questions Than Answers
The Supreme Court's decision to accept certiorari last fall in Liu v. SEC, 140 S.Ct. 1936 (2020) created anticipation and expectation that the SEC's vaunted but Congressionally-unauthorized disgorgement program might be coming to an end. Indeed, the high court virtually invited the defense bar to challenge the Commission's right to obtain disgorgement two years earlier in its decision Kokesh v. SEC, 137 S.Ct. 1635 (2017) (applying the five-year statute of limitations of 28 U.S.C. § 2462 to SEC disgorgement claims based on the Court's conclusion that the remedy of disgorgement was inherently punitive in nature).
This past June the suspense ended when the Court, in an 8-1 decision, upheld the SEC's right to seek disgorgement in federal court, but significantly limited the circumstances in which it could do so. Specifically, the Court held that any disgorgement award must be limited to the wrongdoer's "net profits" and issued to "victims" of the fraud. In so doing, the Court resolved the question of the SEC's right to obtain disgorgement conceptually – but muddied the waters regarding when and under what circumstances such disgorgement would pass constitutional muster. This article examines many of the unanswered questions that flow directly from Liu.
1. What Constitutes a "Legitimate Business Expense"?
According to Liu, "Courts may not enter disgorgement awards that exceed the gains made upon any business or investment, when both the receipts and payments are taken into account." Accordingly, "courts must deduct legitimate expenses before ordering disgorgement."
This, of course, begs the fundamental question as to when is an expense related to a fraud "legitimate"? Clearly, "when the entire profit of a business or undertaking results from the wrongdoing, a defendant may be denied inequitable deductions such as for personal expenses." But what about expenses other than "personal services"? What about the deductibility of personal services devoted to that part of a business venture that was not fraudulent? And why should expenses incurred in the perpetration of a fraud like rent, postage or computers be deductible at all?
The Supreme Court concluded "it is not necessary to set forth more guidance addressing the various circumstances where a defendant's expenses might be wholly fraudulent." Instead, the Court "[left] it to the lower courts to examine whether including [specific] expenses in a profits-based remedy is consistent with equitable principles." One point is certainly clear: it will take years of trial and error as the Commission, counsel and the courts struggle to define what constitutes a legitimate business expense.
2. Can Disgorged Funds Ever Go to the Treasury?
Fundamental to the Court's decision in Liu was its holding that – in order for a disgorgement order to be valid – the order had to direct payment "for the benefit of investors." The Court questioned how a disgorgement order directing payment to the U.S. Treasury – a common SEC practice – could ever be lawful, although it sidestepped the issue based on the failure of either party to "identify a specific order in this case directing any proceeds to the Treasury."
Presumably, disgorgement orders directing payment to the Treasury would be considered unlawful by the Court because such orders would serve only one of the two equitable goals underlying disgorgement. Disgorgement paid to the Treasury would deprive a wrongdoer of the "fruits of their ill-gotten gains," but such an award would – equally clearly – not be "for the benefit of investors." Awards directing payment for the benefit of investors are not simply aspirational: they derive directly from the statute authorizing the SEC to obtain relief in fraud cases – 15 U.S.C. §78u(d)(5) – which authorizes a federal court to "grant . . . any equitable relief that may be appropriate or necessary for the benefit of investors." It is difficult to conceive how any disgorgement paid to the Treasury could satisfy this requirement. Nonetheless, the Court directed the lower courts on remand in Liu to consider such a question "if" such an order is subsequently entered in the case" – thereby creating further uncertainty for litigants.
3. Is Disgorgement Ever Available in Insider Trading or FCPA Cases?
Disgorgement orders directing payment to the Treasury are commonplace in insider trading and Federal Corrupt Practices Act cases, because – while the amount of the benefit to the defendant is easily ascertainable – identifying the harmed investors is not. It is difficult to conceive how such orders can be justified following Liu.
The standard measure of disgorgement in a settled insider trading case is the amount of the gain recognized (or loss avoided) by the unlawful trade. Similarly, in the FCPA context, disgorgement is calculated based on the value of the contract wrongfully obtained (i.e., the "gross" profit). Such practices would seem to fly in the face of Liu, gross profits no longer being the lawful measure of disgorgement. More importantly, disgorgement obtained in insider trading or FCPA cases cannot be returned to investors because of the inability to identify the "harmed investors."
How will the SEC adjust to such a change in the law? One avenue would be to alter its standard formula for resolving insider trading cases, historically, the amount of the gross gain (or loss avoided) times two. This "one plus one" formula – disgorgement of gross profits plus a one-time civil penalty — is facially unacceptable following Liu. The Insider Trading Sanctions Act, however, authorizes treble penalties in insider trading cases. The SEC could, presumably, retain its doubling approach on the grounds that Congress has authorized up to three times the profit or loss avoided and a settlement for anything less is therefore justified. The Commission could take a similar approach in the FCPA context.
4. Can Liu be Squared with Kokesh?
If Kokesh threw open the door to questions regarding the legitimacy of SEC disgorgement generally, Liu closed it – but only part way. After Liu it is (relatively) clear that disgorgement awards based on gross profits and not for the benefit of investors are invalid – as is joint and several liability for wrongdoers. The obverse is equally true: disgorgement based on net profits allocated for the benefit of investors is likely lawful.
The decision in Kokesh that disgorgement was punitive in nature, however, was based on three findings: (1) disgorgement is imposed as a consequence for violating public laws (i.e., a violation against the United States, not an individual); (2) disgorgement is imposed for the purpose of deterring infractions of public laws and hence punitive; and (3) disgorgement is often not compensatory. Only the last point – that disgorgement is often not compensatory – was addressed by Liu. Even disgorgement of net profits for the benefit of investors is punitive in the sense that – in the words of the Kokesh Court – "disgorgement orders . . . are intended to punish, and label defendants wrongdoers as a consequence of violating public laws." Accordingly, it is difficult to reconcile the two decisions.
One last point bears mentioning. After Liu the SEC is free to argue that disgorgement orders based on net profits paid for the benefit of investors are not subject to the five-year statute of limitations upheld in Kokesh. Because it is difficult to harmonize the two decisions, the thorny issue of disgorgement is likely to end up once again before the high court.
The Supreme Court's recent decision in Liu proved disappointing to those hoping for clarity after the Court opened the door to questions regarding the remedy's legitimacy in Kokesh. The SEC's right to obtain disgorgement conceptually is no longer an issue, but when, how and on what basis remain largely unclear. Recent SEC settlements suggest the agency is already groping towards a methodology for imposing disgorgement, but disputes are certain to arise that cannot be easily answered. As the battle over the legitimate parameters of SEC disgorgement plays out through negotiation and litigation practitioners should take heart that Liu has strengthened the defense bar's arsenal of arguments.
Richard A. Levan has substantial experience in the Securities and White Collar Enforcement fields, having previously served as Chief Litigation Counsel at the U.S. Securities and Exchange Commission's Philadelphia Office and as an Assistant U.S. Attorney in the Department of Justice in Washington, D.C. He is currently co-chair of the Securities Regulation Committee of the Philadelphia Bar Association. He can be contacted at Richard@Levan.Legal.
215.983.9272 (Philadelphia)
914.302.6162 (New York)
Richard@Levan.Legal
Jon-Jorge Aras is a trial attorney who represents securities industry professionals and firms in enforcement actions and investigations initiated by the U.S. Securities and Exchange Commission and FINRA. He can be contacted at JJAras@Levan.Legal.
JON JORGE ARAS
JJAras@Levan.Legal
© 2023 Levan Legal, LLC. All Rights Reserved

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Episode dated 29 March 2017
Episode aired Mar 29, 2017
NewsTalk-Show
Ski racer Mikaela Shiffrin; New Beauty's annual Beauty Choice Awards; actor Ken Jeong (Dr. Ken (2015)); actress Cara Delevingne and actor Dane DeHaan (Valerian and the City of a Thousand Pla... Read allSki racer Mikaela Shiffrin; New Beauty's annual Beauty Choice Awards; actor Ken Jeong (Dr. Ken (2015)); actress Cara Delevingne and actor Dane DeHaan (Valerian and the City of a Thousand Planets (2017)); wild animals; butt confessions; gadgets to protect oneself.Ski racer Mikaela Shiffrin; New Beauty's annual Beauty Choice Awards; actor Ken Jeong (Dr. Ken (2015)); actress Cara Delevingne and actor Dane DeHaan (Valerian and the City of a Thousand Planets (2017)); wild animals; butt confessions; gadgets to protect oneself.
Matt Lauer
Savannah Guthrie
Self - Co-Anchoras Self - Co-Anchor
Self - Weather Anchor and 3rd Hour Co-Anchoras Self - Weather Anchor and 3rd Hour Co-Anchor
Self - 4th Hour Co-Anchoras Self - 4th Hour Co-Anchor
Self - Orange Room Hostas Self - Orange Room Host
Self - Guestas Self - Guest
Ski racer Mikaela Shiffrin; New Beauty's annual Beauty Choice Awards; actor Ken Jeong (Dr. Ken (2015)); actress Cara Delevingne and actor Dane DeHaan (Valerian and the City of a Thousand Planets (2017)); wild animals; butt confessions; gadgets to protect oneself.
March 29, 2017 (United States)


For pre-production to start, producers must commit themselves to a project – a screenplay. Once greenlit, the script furnishes the framework for the production. Location scouting, casting, equipment rental, storyboard, and shoot script all happen in accordance to the screenplay.
One of the main tasks for the producer during this phase is to secure funds for the production to progress to the next level. Serious student filmmakers must understand that any film production costs money. Meals for the crew is often the biggest expense to young filmmakers. For Hollywood studios, on the other hand, their hugest expense is often the star's salary, which is higher than the entire crew's combined. Equipment rental, contracts, permits, and insurance are also costly for the independent producer and should not be ignored.
Creatively and artistically, many decisions must be made. First and foremost, a director must be chosen; he or she will be in charge of creative decisions from that moment onward unless fired. Writing the shooting script is huge responsibility in this phase. The director must be extremely familiar with the screenplay to the point that he knows what and how he wants to shoot the movie. The shooting script is a more detailed description of the shots and scenes of the movie.


text:
Liquor Licence Amendment Act, 2004, S.O. 2004, c. 28 - Bill 96
The Bill proposes a definition of "supply" to make it clear that the word includes cases where a licensee permits the consumption on licensed premises of wine that a patron has brought onto the premises in accordance with the regulations for the patron's consumption. The Bill also provides for the following:
1. Gives the Registrar the power to issue immediate interim suspensions of licences in the public interest.
2. Amends sections 34 and 34.1 of the Act to prohibit persons who have been required to leave licensed or other premises by a police officer from remaining on the premises and from returning to the premises until the day after they left, unless authorized to do so by a police officer.
3. Doubles the minimum fines for offences related to liquor and persons under 19 years of age.
An Act to amend
the Liquor Licence Act
Assented to December 16, 2004
1. Section 1 of the Liquor Licence Act, as amended by the Statutes of Ontario, 1998, chapter 18, Schedule E, section 166, 1998, chapter 24, section 1, 2002, chapter 17, Schedule F, Table and 2002, chapter 18, Schedule E, section 7, is amended by adding the following definition:
"supply" includes a licensee's permitting the consumption on licensed premises of wine that a patron has brought onto the premises, in accordance with the regulations, for the patron's consumption, alone or in the company of others; ("fournir")
2. Subsection 15 (6) of the Act, as re-enacted by the Statutes of Ontario, 2002, chapter 18, Schedule E, section 7, is repealed and the following substituted:
Interim suspension of licence
(6) If a proposal is issued to revoke or suspend a licence, the Registrar may by order suspend the licence prior to a hearing if he or she considers it to be necessary in the public interest.
3. Section 34 of the Act is amended by adding the following subsections:
Not to remain after being required to leave
(3.1) No person shall remain on licensed premises after being required to vacate the premises by a police officer under subsection (3).
No re-entry
(3.2) No person shall re-enter the licensed premises on the same day he or she is required to vacate unless authorized to re-enter by a police officer.
4. Section 34.1 of the Act, as enacted by the Statutes of Ontario, 1994, chapter 37, section 14, is amended by adding the following subsection:
(1.1) No person shall,
(a) remain on the premises after being required to vacate the premises by a police officer under subsection (1);
(b) re-enter the premises on the same day he or she is required to vacate unless authorized to re‑enter by a police officer.
5. (1) Subsection 61 (6) of the Act, as amended by the Statutes of Ontario, 1998, chapter 24, section 14, is amended by striking out "$500" and substituting "$1,000".
(2) Subsection 61 (7) of the Act, as amended by the Statutes of Ontario, 1998, chapter 24, section 14, is amended by striking out "$100" and substituting "$200".
6. This Act comes into force on a day to be named by proclamation of the Lieutenant Governor.
7. The short title of this Act is the Liquor Licence Amendment Act, 2004.


text:
King's College London AHRC PhD studentships at the British Library 2017, UK
Business, Chemistry, Computer Sciences, Economics, Finance, Geography, History, Humanities, Languages, Law, Linguistics, Literature, Mathematics, Physics, Sociology
AHRC PhD studentships at the British Library
Essential skills, qualities and knowledge
A first class or upper second class honours degree in a relevant discipline. Candidates would also normally be expected to hold a Masters degree in a relevant area by 1st October 2017
Knowledge of at least one of the following research areas: Modern Russian History, Twentieth-Century Russian Culture, History of the Media and Journalism, Russian Literature
Knowledge of the Russian language
Ability to be self-motivated, well-organized, and to respond to constructive criticism.
Willingness to take a full part in the KCL postgraduate community, and the research activities at KCL and at the BL.
Desirable skills, qualities and knowledge
Familiarity with current scholarship on Russian émigré culture
Experience of undertaking research in Russian history, cultural history or visual culture
The AHRC has strict residential eligibility criteria governing the students that can be nominated for this award. If you are not a British citizen and/or not usually resident in the UK (and have not been for the past three years), please check your eligibility with the project supervisors: see the AHRC's eligibility criteria
Information about the funding
Applications are invited for a Collaborative Doctoral Award in the following general area: 'Studying migration and diaspora through Russian language publishing'. The studentship will be held jointly at the British Library and King's College London, and the project will be supervised jointly by Dr Ekaterina Rogatchevskaia (British Library, European and American Collections) and Professor Stephen Lovell (King's College London, Department of History).
This studentship, to start 1 October 2017, offers a unique opportunity for the award-holder to receive training and gain experience in collection curatorship within the UK's principal research library, as well as to undertake an original research project.
Project Aims
Proposals may focus on one or more of the following periods: the pre-revolutionary era (1860s-1917); the post-revolutionary 'First Wave' emigration; the post-war 'Second Wave' emigration; the 'Third Wave' of the 1970s; and the post-Soviet diaspora. They may investigate one or more of the following areas: the economics and institutional history of publishing; literary or intellectual history; the history of audiences.
An important outcome of the studentship could be a digital resource, or set of resources, to make the Russian diaspora holdings of the BL more visible and engaging to the general public, and to enable new and imaginative connections between different titles, authors, publishers and even eras. As well as drawing on the immense expertise at the BL, the student would be able to work with Digital Humanities at KCL. Applicants are encouraged to include suggestions of practical outcomes of their research in their applications.
The details of how the project will be undertaken are to be worked out between the successful applicant and the supervisors as part of supervision process.
However, the successful candidate will in the first instance define and analyse the corpus of relevant émigré material in the holdings of the British Library, making comparisons and connections with bodies of material held elsewhere. This will serve as a gateway to broader research questions such as the boundaries and self-definition of a Russian émigré or diaspora 'community'; the structures and hierarchies of literary and intellectual networks; the economics of publishing; and the imagined and real audiences of Russian-language publishing abroad.
The Library will provide a desk and general work space, and the student will have access to a networked PC and other IT equipment as required. In addition the student will be able to use the Library phone network and have access to other normal office facilities e.g. stationery, internal and external postal service.
The student will be considered a temporary member of staff at the British Library and will be issued with a staff pass.
The student will be based in the Department of History and play a full part in the life of this rich and diverse postgraduate community. S/he will be encouraged to attend the numerous seminars and training events organised by the Department of History and the Faculty of Arts & Humanities more widely. S/he will also benefit from close connections to the postgraduate communities of University College London and the School of Advanced Studies under the auspices of the London Arts and Humanities Partnership.
Supervision and Training
The British Library supervisor will be directly responsible throughout the period for working with colleagues at KCL to manage the collaboration and supervise the student, including providing management and mentoring for the appointed doctoral student within the British Library team/workplace. The British Library will provide specialist training and guidance in use of the facilities and archives it holds. The student will benefit from participation in all relevant in-house training, including the national Doctoral Open Days, which also offer a valuable networking opportunity.
The student will also have access to the extensive programme of research training available both at King's College London and at the Institute of Historical Research.
For more information please click "Further Official Information" below.
Eighth Summer School in Early Modern Japanese Palaeography, 2-14 August 2021, UK
Scholarships for Persian Language Courses of ASPIRANTUM
Gonda PhD Fellowships 2021 at Royal Dutch Academy of Sciences, Netherlands


The unified "Complete staff" of 27 gradual lines, can be used directly for the piano and organ score (there remains also the "Great staff" of 13 lines). With less space, without ledger lines, and with eight octaves the range and the freedom are expanded, musical perceptiveness is strengthened. The use proves to be more clear and concise.


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Gauges can be downloaded immediately after purchase at the bottom of the confirmation page or later from your account history, where updates can also be downloaded.
You can download or update your gauge/s at any time. Simply log on, open your order history, open your order and the download links will be at the bottom of the order details page.
If you would like to receive update notifications for your gauges then please click the "Click to Activate" button for your gauge/s. You can also come back and check recent changes for update info.
Should you have any issues at all with the download process then please contact us and we will be more then happy to assist and will e-mail your gauge/s to you should we not be able to resolve your download.
For security reasons you have 5 download attempts, after that please contact us so we can resolve any issues your are having. The download attempts are reset as updates for your gauges become available.
While you can download your gauges at any time, we would recommend you backup your gauges locally.
Check if your gauges are up to date within SPAD.neXt. Press the [MANUAL] button on the SPAD.neXt FIP page with a gauge loaded or from the FIP loading menu. This will direct you to the fipgauges web gauge reference manual for the selected gauge, which will do a version check on the gauge. If the gauge is behind the current version the web page will tell you. If you are advised there is a newer gauge then simply download your gauge again from the store to get the latest version.
I have been using 4 setups of this gauge on the Lancaster, B ..


Many investors, looking for something different, look to real estate investment trusts. But the options can be confusing.
Index, Company Stocks, Greek Banks, MDC - M.D.C. Holdings Inc., RH - Restoration Hardware Holdings Inc., TBT - ProShares UltraShort Lehman 20+ Year Treasury.


text:
/* eslint-env jest */
import { future } from 'validations'

describe('future()', () => {
  let rule

  beforeEach(() => {
    rule = future()
  })

  describe('.name', () => {
    test('is "future"', () => {
      expect(rule.name).toBe('future')
    })
  })

  describe('.rule', () => {
    test('returns true when value is future', () => {
      var value = new Date()

      value.setDate(value.getDate() + 1)

      expect(rule.test(value)).toBe(true)
    })

    test('returns false when value is past', () => {
      var value = new Date()

      value.setDate(value.getDate() - 1)

      expect(rule.test(value)).toBe(false)
    })
  })
})

redpajama_set_name: RedPajamaGithub


text:
Green Wiki
About Green Wikia
How to Green Your Home
How to Reduce Your Air Pollution
How to Dress Green
How to Drive Green
Buying Green Light Bulbs
in: Sustainable living, Sustainable education
Sustainable Living at Maharishi University of Management
Maharishi University of Management offers the first Sustainable Living degree program in America.
1 Bachelor of Science in Sustainable Living
1.1 Internships and certifications
1.2 One course at a time
1.3 The University's commitment
1.4 Option for one-year MBA in Sustainable Business
2 Sustainable Living Center
3 LEED Certified Student Center
3.1 Green elements to qualify for LEED certification
4 MBA in Sustainable Business
5 History of Maharishi University of Management
Bachelor of Science in Sustainable Living
The B.S. in Sustainable Living covers seven key areas:
Self Sustainability — develops your total inner potential through Consciousness-Based education
Bio-Geophysiology — provides the foundations of ecology and geology as the model for sustainability
Renewable Energy — includes solar energy, wind energy, and biofuels
Sustainable Agriculture — emphasizes organic agriculture and permaculture design practices on our organic farm
Eco-Architectural Design — focuses on creating buildings and communities in harmony with the laws of nature
Green Business and Entrepreneurship — provides the basics of business, entrepreneurship, and eco-economics that drive sustainable communities
Social-Ecological Interface — includes bio-cultural ethics, environmental law, and an overview of mega-sustainability issues
Internships and certifications
Real-world internships and professional certifications are a featured part of the Sustainable Living degree program.
One course at a time
Our students take one course at a time — they're immersed full time in the course for about 4 weeks — and then move on to the next course. They learn more with less stress and less effort, and never have the burden of homework and exams in 4–5 subjects at once.
This system is immensely popular with our students — they find it's the most effective and easiest way to learn.
The University's commitment
The university serves organic vegetarian meals daily — often with locally grown produce — and we're committed to applying the principles of sustainability to our own campus to the maximum extent possible.
Option for one-year MBA in Sustainable Business
Upon graduating, students have the option of taking a one-year MBA in Sustainable Business. Requisite undergraduate courses are needed for this option.
Sustainable Living Center
Sustainable Living Center: called the 'Ultimate green building' by Forbes, Associated Press and MSNBC
To house the Sustainable Living programs, the University is building a 7,000-square-foot Sustainable Living Center, which architects predict will set new standards in green building construction and operation.
The Center will include classrooms, a research lab, greenhouse, a recycling center, a metal and wood workshop, kitchen, and offices. Construction is scheduled to begin in October and be completed in late fall 2009.
Sustainable Living Center receives grant from Kresge Foundation
In December 2008 the international Kresge Foundation's Green Building Initiative awarded Maharishi University of Management a $50,000-dollar Planning Grant for the Center. The funds will help cover costs such as ecological site planning, energy analysis and modeling, and LEED certification.
Center Features
Extensive use of daylighting — A unique architecture will capture sunlight and direct it throughout the building to provide all of the lighting for about three quarters of the day.
Solar panels and wind turbine — Electrical power will come from photovoltaic panels and a wind generator. A generator fueled by student-manufactured biofuel will provide backup energy.
Natural cooling system — Night air will be used to cool the thermal mass walls, which then hold the cool temperature and radiate it during the day. Also, the building will absorb very little heat because of these walls and Vedic verandas on the east and west. Cooling will also be provided by geothermal tubing.
Natural heating system — The building will use radiant in-floor heat supplied by solar water-heating panels, with a biofuel-powered generator as a backup. In addition, heat will be conserved by insulation as well as heat storage in the thermal mass walls. Also, the building will recapture the heat from the ventilation system rather than exhausting it.
Use of rainwater — A rainwater catchment system will collect 90% of the rainwater on the roof and route it into a cistern for nonpotable uses. The remaining 10% will be routed into a UV treatment system for consumption.
Treatment of wastewater — Wastewater will be treated by a leech field, in which bacteria digest the matter, and then a green-plant mediated living system in the greenhouse will be used to remove the excess nitrogen.
Earth block construction — The building will be constructed from earth blocks made by the Sustainable Living students using a mixture of compressed clay and sand.
The building's features will qualify it to receive the highest level of certification from LEED (Leadership in Energy and Environmental Design). It will also comply with the healthy-building principles of Bau-Biologie. The plan is to also meet the Cascadia "Living Building Challenge" — which would be the first building ever to reach this benchmark.
LEED Certified Student Center
Argiro Student Center
On February 1, 2008, Maharishi University of Management opened the 50,000-square-foot Argiro Student Center, America's first student center constructed according to the ancient principles of Vedic architecture for harmony with natural law.
It also incorporates advanced green features that will qualify it for LEED certification.
The Argiro Student Center features a 300-seat auditorium, two dining halls, student café, student lounge, banquet room, bookstore, mailroom, and offices for student-related activities.
The Student Center is named for Dr. Vincent and Dr. Maggie Argiro, University trustees and principal donors to the building.
Green elements to qualify for LEED certification
Energy Efficiency: Energy savings in the Argiro Student Center come from heat exchangers, which capture 80% of the heat from the air that is being exhausted from the building and use it to help heat the incoming fresh air.
Daylighting: Large, triangular windows cast light deep into the Argiro Student Center on the two upper floors. Daylighting sensors automatically turn off the lights when enough daylight is present. The building's cupola also helps reflect light into the atrium area.
Insulation: The Argiro Student Center is insulated 50% better than average. The heating and cooling systems also have a higher-than-normal efficiency.
Nontoxic Materials: The Argiro Student Center is constructed with nontoxic materials, including over 13,000 square feet of bamboo flooring. Carpeting is green certified, and the flooring in the serving areas is Marmoleum, which is a natural linoleum made with 100% natural ingredients: linseed oil, cork, limestone, tree rosin, and natural minerals.
MBA in Sustainable Business
The MBA in Sustainable Business covers five key areas:
Self Sustainability — develops your total inner potential and leadership abilities through Consciousness-Based education
Sustainable Entrepreneurship — focuses on creating successful green businesses that produce real value for society
Sustainable Business Solutions — provides the knowledge and skills needed for transforming and managing businesses for lasting sustainability
Sustainable Management — emphasizes the people and organizational skills needed for managing projects and operations
Sustainable Living — provides advanced knowledge and experience in renewable energy, organic agriculture, and the other principal fields of sustainable living
History of Maharishi University of Management
Maharishi University of Management (MUM), formerly known as Maharishi International University, was founded by Maharishi Mahesh Yogi, who introduced the Transcendental Meditation technique. The campus is located in Fairfield, Iowa, USA, on the grounds of the former Parsons College.
The university is accredited through the Ph.D. level by The Higher Learning Commission of the North Central Association of Colleges and Schools, and offers "[Consciousness-Based education", including practice of the Transcendental Meditation technique. Degree programs are offered in the arts, sciences, in business, and in the humanities.
Maharishi University of Management cites high rankings on "benchmarks of effective educational practice" from the National Survey of Student Engagement and also the results of the ACT alumni survey that show a high level of alumni satisfaction.
Sustainable education
More Green Wiki
1 Green India
2 Green products
Green Wiki is a FANDOM Lifestyle Community.


How Can I Subscribe to This Plan Dial *431# to subscribe. Does it work on other Device? Like i wrote earlier It has not been tested on any device. Though their last text says 'Valid on Blackberry Only' but I believe when tried on other devices, it should work.
The year 2015 is still fresh and they should keep up the good work, but hope this doesn't zap data as usual? If not, I comment my reserve.


Marie-Claire Alain, the Lady of French organ, passed away on 26 February 2013. She was born in August 1926 into a family of musicians. Her father, Albert Alain, was a composer and organist in Saint-Germain-en-Laye, in the suburbs of Paris. Her eldest brother, Jehan Alain, was a composer and organist as well, and her other brother Olivier was also a composer and musicologist.
Further to her early studies in Saint-Germain, she became a student of Marcel Dupré and Maurice Duruflé, from whom she obtained a first prize in five classes at the Conservatoire National Supérieur de Musique de Paris: organ, improvisation, harmony, counterpoint, and fugue.
Her lengthy career began as early as 1937, when she would play the organ of Saint-Germain-en-Laye with her father. She gave more than 2,500 concerts around the world. She was a very popular teacher and was invited to teach at the greatest European music schools, and the most famous universities, in particular in North American and Japan. Her teaching was based on ever-evolving musicological studies, which followed the progress made in organ craftsmanship, and specifically in the restoration of older instruments. She also taught at the Rueil-Malmaison music school from 1978 to1994. Thus, she trained hundreds of organists around the world, most of whom became great musicians and reputable teachers themselves.
Alain recorded close to 250 albums, and sold more than 4 million CDs.
Among others things, she recorded three complete cycles of works by Bach, Grigny, Couperin, Jehan Alain, and two of works by Franck. She also made many recordings with orchestras, and was famous, together with trumpeter Maurice André, for the inventive array of works they recorded for their album Trumpet and Organ. In a recording career lasting almost sixty years, Alain won more than fifteen Grands Prix du Disque, and many Diapasons d'Or. She also recorded works from the modern repertoire, from Liszt to Messiaen. Her brother Jehan's music always had a special place in her life as a musician, both in her teaching and in her performances, which she introduced to a greater public. Indeed, she would traditionally end her recitals with the famous Litanies.
In 1959, she started recording her first version of Bach's complete works. It proved to be a great success. Thanks to this huge set of 24 LPs, listeners could hear copies of older instruments, mainly Marcussen organs from Sweden and Denmark. In 1980, she recorded a new version of Bach's oeuvre, based on the same idea—using copies of baroque instruments—but this time the knowledge of Baroque interpretation had evolved noticeably. And finally, in the mid-1990s, she recorded the cycle once more, again for Erato. But this time, she chose a set of historical organs among the most beautiful in the Netherlands and Saxony that had finally been restored following the principles of traditional craftsmanship. These instruments represented the two different trends of organ craftsmanship that influenced Bach's work, and which were later developed respectively by the organ builders Arp Schnitger and Gottfried Silbermann. This last cycle represents the final achievement of Alain's art, the fruit of a life-long process of questioning her own ideas to deepen her understanding of Baroque interpretation.
In the mid-1970s, she founded the J.S. Bach academy in Saint-Donat, Drôme, centered on the Schwenkedel organ, an example of the German Baroque style. She was the head of the academy from 1977 until 1991. She was also a guest of the Romainmôtier academy in Switzerland, where the Alain family organ has since been settled.
The death of Marie-ClaireAlain is a huge loss in the organ world, and to the world of music as a whole. Nicknamed "the Lady of the Organ" by the Americans, she was an exceptional artist and she will live on through the indelible memories of her concerts, her numerous CDs, the precious knowledge conveyed through her teaching, and her legendary kindness and receptiveness.


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There are many traders who take up more than one trade at a time. The diversity could be in terms of the assets chosen or even the markets being traded in. For all such traders, it would be difficult to keep track of all the trades at the same time while also keeping a check on the losses. Stop loss orders are the perfect answers for this.
Stop loss orders are easier to understand and execute.
Given that this is an automated order, you would not have to worry about sudden surges leading to major losses. The instant where the stop loss value is reached the order would automatically be placed.
After hour trading is something you should never ignore. There are many who make huge profits after the market closing hours. There could be price gaps that are created due to the aftermarket trading instances. This might not occur too often but when it does, it can lead to the order not being placed even after the stock has grazed the set price.
Does the broker charge you extra? Because some do charge an additional fee for stop-loss orders and this is often a hidden clause. So when you sign up with a brokerage clearly understand about the conditions, if any, for stop loss orders. This would ensure losing money later while placing stop loss limits.
If you are a day trader or an active trader who keeps watching the market constantly then the stop loss order might not always be relevant. Use this as your last resort if you have to give the trading process a break. Otherwise, it would be a good idea to use real-time movements to make on the spot decisions during a falling trend.
Watch the graph to identify a stop loss value that is likely to occur. There are a few traders who set very precise values which might not be met at all. So setting a reasonable value based on the historical data would be a better option.


Aviation accidents are relatively rare, and traveling by plane is statistically safe. But if you're the exception, speak to an airplane accident attorney.
Christopher Reeve famously lauded the statistical safety of plane travel in 1978's Superman (to be repeated by Brandon Routh in 2006's Superman Returns).
And although mile-per-mile, there are fewer aviation accidents than any other type of travel, airplane disasters also have more severe injuries and fewer survivors.
The law surrounding negligence in airplane accidents can be very complicated and can implicate a large number of potentially responsible parties.
One of the first things an airplane accident attorney will do in an aviation accident case is identify all the potentially responsible parties.
Depending on the facts of your case, the airline itself, flight personnel, maintenance crews, air-traffic controllers, airplane owners, and even other passengers may have caused your losses through direct or careless actions. The parts designers, manufacturers, distributors, wholesalers, and retailers may also be liable if there are defective products responsible for the crash.
The nature of the crash also has to be considered. Your airplane accident attorney will want to know whether it is a private plane, chartered plane, or commercial jet. Or whether it wasn't an airplane at all, but a helicopter. Because not all aviation accidents are the same.
U.S. Airways Flight 1549 crashed into the Hudson River in January 2009. There were 100 injuries and no deaths.
Asiana Airlines Flight 214 crashed in San Francisco in 2013. There were three deaths and 181 injuries reported.
American Airlines Flight 383 had an engine explosion as it was accelerating for take off, which resulted in an aborted takeoff and twenty reported injuries.
A Marine Corps. Lockeed Martin KC-130 crashed in Mississippi in July 2017. All sixteen passengers died.
Bonanza Airlines Flight 114 crashed into a mountain south of Las Vegas in 1964, killing all 29 passengers.
Galaxy Airlines Flight 203 crashed just before the runway of the Reno Airport. All but one of the 71 passengers died.
TWA Flight 3 crashed into a mountain after taking off from Las Vegas in 1942. All 22 passengers died.
United Airlines Flight 736 crashed into a military fighter jet on a training mission in 1958. All 47 in the airline and the two crew members of the fighter jet were killed.
Speak to an aviation accident lawyer if you or a loved one were injured in a plane crash or if you've lost someone to an airplane accident. The airplane accident attorneys at Parry & Pfau will give you a confidential and free consultation.


The property comprises a warehouse production unit on a self contained site, originally constructed in 1982 and subsequently extended. It is of steel frame construction under a lined and insulated roof, with insulated metal clad elevations. The minimum eaves height is 6.7m. Loading is provided by dedicated loading bays incorporating dock and level access loading.


[Note: Minimum requirements and definitions of ratings can be found in the here and here] Detailed guidance and rules for instructors can be sourced in the BMAA Instructor & Examiner guide, available here.
I'm looking to prepare to become a FI[R], but want to clarify the hours requirements. Do my NPPL training Pilot-in-Command hours (under supervision) count?
Yes. All legitimate PIC hours in Microlights can be counted towards the FI[R] minimum hours threshold.
How long will my FI[R] rating last for?
36 months to end of month of issue.
I've become a FI[R] on Flexwing Microlights, but now I'd like to try 3-Axis Microlights. How can I do this?
There are two ways to do this. If you wait until your revalidation instructor test date, you simply request that the test be done on the alternate control type. Passing this will then remove the control type restriction, so you can be an FI[R] on Flexwing and 3-Axis Microlights.
If you don't wish to wait until the revalidation test, you can request an Additional Control Type test with a Microlight FIE. This works out slightly cheaper and does not incorporate all of the elements of a typical instructor test.
I'm a FI[R] and I'm wondering how long I should wait before upgrading to a full Flying Instructor. What is the average time most people take before upgrading?
You should be in constant dialogue with the Flying Instructor who supervises you on your progress. They will be best placed to judge when to put you forward for an upgrade test, assuming you meet the hours minima (see link at top of page). For a general comparison, the average length of time FI[R]s take to upgrade currently stands at 18 months.
I've just had my FI[R] document sent, but it's a full instructor rating. Is this a mistake?
No. Much like the restricted NPPL, the reference to restrictions will appear in the 'Remarks' section of the document, rather than the title page of the document.
I'm a Microlight instructor on flexwing Microlights only, but the bad weather is really hindering my business. How can I expand my instructor rating to teach on 3-Axis Microlights?
As above with the FI[R] case, there are two ways to do this. If you wait until your revalidation instructor test date, you simply request that the test be done on the alternate control type. Passing this will then remove the control type restriction, so you can be a Flying Instructor on both Flexwing and 3-Axis Microlights.
I was previously a Microlight instructor some time ago, but circumstances meant I drifted out of the sport. I'm now semi-retired and would like to instruct once more. How do I go about this?
The requirements are dependent on the period of expiry. If your instructor rating has lapsed by less than 5 years, you will only need to pass an instructor test with a Microlight FIE and send the paperwork into the BMAA, though some refresher training may be prudent.
If your rating has lapsed by more than 5 years, you are required to undertake discretionary refresher training with an FIC instructor, until they recommend you for test. You would then need to pass an instructor test with a Microlight FIE.
I am a retired airline pilot and former instructor on various aircraft types. I'd like to become a Microlight instructor. Is there a way I can convert my instructor rating?
It is not possible to simply convert or transfer an instructor rating to Microlights. If you are a current SEP instructor, you only require differences training on Microlights to be able to then instruct on them. However, any other instructor rating needs to be examined by the BMAA, and a possible Microlight FI course reduction considered. The BMAA would put together a proposal for a reduced course, and this would then be suggested for approval by the CAA.
I'm looking to set up my own Microlight school operating from a farm strip, but am wary of how much work would be involved complying with regulation. Aside from associated insurance requirements, what do I need to do to comply with BMAA standards?
First of all, the national regulatory body is the Civil Aviation Authority. The BMAA administer regulations, they do not create or enforce them.
Setting up a Microlight school is remarkably simple, and you are only legally compelled to comply with two strict requirements: that any instruction is only undertaken by current UK Microlight instructors, and that these instructors are teaching to the current UK NPPL Microlight syllabus.
It should go without saying that any aircraft you use for instruction must be legally allowed to be operated as such under the terms of the aircraft's Permit to Fly.
More information can be found in the 'BMAA Code of Good Practice' in the Microlight Instructor & Examiner guide, available from the BMAA online shop.
What class of medical would I require to become a Microlight instructor?
Medical requirements are exactly the same as for NPPL pilots. See FAQs for medicals for further information.
I'm a Single Engine Piston instructor, and have been asked to teach at a local Microlight school. Where do I stand?
Current Single Engine Piston instructors only need to undertake differences training on the type of Microlights they are looking to instruct on, with an instructor entitled to teach on the Microlight type. Once this has been signed off in the logbook, SEP instructors can teach on Microlights for as long as their SEP FI rating remains current.
How can I keep abreast of the latest developments in Microlight instruction?
By regularly checking the BMAA website 'Instructor Bulletins' and 'Instructor Newsletter' links, as well as having a BMAA Instructor & Examiner guide to hand. You should also ensure that BMAA LIAC has your correct e-mail address and you have opted in to receive important updates and other relevant information.
Can you clarify the rules on 'Introductory Flights'?
Links to the CAA 'Introductory Flight' criteria can be found here and here.
I understand that I can't instruct on amateur-built Microlights. Is that right?
The understanding of the rule is that any student undertaking ab initio training on an amateur-built Microlight must be a registered owner of the aircraft, or have a registered share in the aircraft ('Registered' in this sense means having registered their ownership with the CAA, not simply making an agreement with other owners). The share may be as little as £1, as limits to shared ownership has now been removed.
Can you clarify the rules on charity flights?
CAA guidance can be found here.
Can my instructor revalidate my NPPL Microlight rating?
Only if your instructor also holds a Microlight Examiner Authority at a minimum of 'R' level. An instructor with no Examiner Authority cannot revalidate ratings.
Do you have a list of all UK instructors so I can find one who offers flexwing instruction in my area?
Data Protection laws prohibit us from holding this sort of information, but you can search for schools near to you through our geographical search function and check the websites, which normally list instructors and their control types.
I was a Restricted Flying Instructor on Microlights many years ago, and now have the opportunity to work at a school again. I have completed the requirements as stated by the BMAA, but after the successful test, my FIE noticed that the FI[R] Microlights rating appears at the back of the licence rather than the front. What does this mean?
It means that the FIE cannot revalidate the rating themselves. You must provide the evidence you have to the CAA, and request that they reissue the licence with the FI[R] rating as an active rating at the front of the document. More details on CAA procedure here.
This will have happened because at some stage you had your licence document reissued, and the CAA would not have had evidence of FI[R] currency, so assume it is expired and move it to the back of the document. Only they can make it an active rating again.