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Before MLK Day, only LeBron James had recorded a triple-double against every franchise in the NBA.
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Boxing Day Discounts and allowances January sales
January sales 2020: Best UK deals from Amazon, Currys and more
If you've been smart enough to save some of your pay packet for the January sales and need some guidance on where to find the best offers, then you have come to the right place. As well as the deals, we've come up with some handy advice on how to make the most of the January sales, and which retailers will be taking part this year. So whether you're looking for a new sofa, laptop, TV or a designer handbag, you'll find the best deals here to start 2020 off right. Never to miss out on a sale, Amazon's event covers everything from home appliances to smart speakers and TVs. The electrical retailer has started its clearance sale, with deals across gaming, home appliances, TVs, smart tech and more. The Boxing Day and January sales mark the final peak in yearly trade for retailers, following Black Friday and early December, meaning it's the best time of year to grab a bargain – that is, until November's event comes around again.
The deals then continue for most of January, with some discounts getting even better as the month progresses, as retailers will be keen to get rid of stock. When it comes to making the most of the January sales, preparation is key and, with many of us now shopping online, that's where you can expect to find the very best deals. Amazon – The online giant was one of the biggest retailers taking part in Boxing Day sales last year, so in January we expect major reductions on everything from electronics and toys to consoles and home appliances. AO – The online electrical retailerwill be offering a wide range of deals on its products, from appliances and TVs to smart home products. Boots – Everyone's go-to for all things health and beauty, Boots regularly takes part in January sales, offering up to 50 per cent off selected products online last year Hold out for DFS's January sale, as it offered up to 50 per cent off selected lines last year.
Debenhams – Known for impressive discounts during Black Friday and Boxing Day sales, expect slashed prices on thousands of products from Debenhams in January. H&M – The fashion brand slashed its prices by 60 per cent on coats, dresses, jeans, footwear and accessories in its 2018 January sale. John Lewis & Partners – Last year, John Lewis & Partner's clearance sale began online on Christmas Eve. The retailer is expected to price match rivals on popular tech, home and fashion lines thanks to its "Never Knowingly Undersold" tag line. M&S – During last year's January sales, M&S offered up to 50 per cent off selected furniture and cookware. River Island – Check out River Island's sale this January, as it offered up to 70 per cent off lines last year, both online and in store.
We've plundered through the Amazon January sales, summarised the best Currys January deals and checked out the top options from John Lewis (and others) to boot. The Boxing Day sales lasted for a lot longer this year as retailers sought to grab the attention of the deals-hunting public, but there are still a strong number of great ways to save money as the January sales begin. We've searched through the January sales to bring you the very best New Year deals available now. Below, you'll find the biggest savings and best offers on TVs, iPads, laptops, headphones and smart home tech. Because shoppers have spent a little less in recent months, this year's January sales are set to be some of the best for many years – retailers have simply had to cut prices to shift stock.
Prefer to browse the January sales for your own New Year deals? A solid discount on the wireless charging case version of these earbuds – however, they won't be in stock until January 4, so make a note in your calendar.View Deal These are our favourite noise-cancelling headphones (and they have been for two years running), so grabbing them at a discount with a two year guarantee for John Lewis makes this an excellent January sales win. You're saving £90 in these January sales, so now is the best time to grab a feature packed wireless speaker for less. They've got great noise cancelling, a long-lasting battery, and a foldable design that makes them easy to transport - sure, they were down to £85 recently, but Currys is one of the few places that still is offering a deal. Grab this fantastic 14-inch laptop with a massive 512GB SSD for under £500 at Currys in the January sales. £200 off in the early January sales is not to be sniffed at.View Deal This 13-inch MacBook Pro comes with a Touch Bar, Intel Core i5, 8GB RAM, and 256GB SSD – and it's now over £200 in the John Lewis January sales.View Deal DEAL EXPIRED This is the cheapest you'll find a 512GB SSD on this list - at under £400 this laptop is a steal in the early January sales. This budget 43-inch LG TV is at its Black Friday price in the January sales. You can pick up this amazing Samsung Frame TV deal at John Lewis in the January sales and save yourself £300 on the Art Mode television. This iPhone 11 is back down to its lowest price at Currys in the early January sales. This is a fantastic £200 saving on the largest iPad Pro deal you can pick up in the January sales. The Series 3 is the cheapest Apple Watch deal in this selection, coming it at just £199 in these early January sales. That makes its current January sales price of £60 one of the very best mid-range options available. This deal has finished now, but Amazon is still offering a £10 discount, with a price of £79.99. This brand new game comes down from its usual $49.99 price tag for these early January sales. DEAL ENDED Save £10 on a new wireless controller for Xbox One in the Currys January sales. DEAL ENDED Pick up three months of Xbox Game Pass Ultimate for just £15.99 at Amazon in the January sales - perfect if you're unwrapping a new console or if you've grabbed one of the cheap ones above. This is the same price Currys offered during the Black Friday period, so it's a decent saving. OUT OF STOCK With its simple drill-free installation and battery-powered operation, the Ring Door View Cam is ideal for renters, while still offering most of the features of other smart doorbells, and right now you can get a 34% saving. Plus, £149 is the lowest this camera has ever been available for, so you're getting a great deal at Amazon. OUT OF STOCK This fine deal on the X-T100 matches Amazon's own right now, if you're looking for a new camera at a heft discount. This ace Nespresso Vertuo Plus capsule coffee machine knocks over £100 off the usual asking price, and throws in a load of capsules too for barista-level bliss.View Deal This Dolce Gusto coffee machine is a firm favourite when it comes to Currys Boxing Day sales. Currys impressed us in the January sales last year, and more recently on Black Friday. This year we're expecting big discounts on TVs, laptops, gaming consoles, Dyson cordless vacuum cleaners, kitchen electricals and more – keep an eye out for the TV ads showing off the best ones too. Well, we're into the January sales, and many people will likely be thinking about ways to make their house that little bit more dust-free - and these Dyson deals are just what you're looking for. Check out the cheapest Dyson sales, offers and deals for vacuum cleaners for December 2019. The Currys sale for January 2020 is a real bargain-fest, with brilliant deals and discounts on everything from TVs to large appliances, small appliances, smart home tech and health and beauty electricals. We've been busy checking the deals as they come in, and picking out the very best from the rest of the January sales – so that you don't have to spend hours searching online. The 10 best Currys sale deals live right now Take a look at what we think are the very best Currys sale deals today, then shop a wider range of products below. The best Currys sale deals by department Currys sale TV deals Currys sale smart home deals Currys sale small appliance deals Currys sale kettle deals Currys sale vacuum cleaner deals Currys sale coffee machine deals Currys sale large appliances deals Currys sale portable speaker deals As well as the best deals we have highlighted above, the Currys sale means loads of discounts on other departments. Prices start at £599 for a 49inch Smart 4K Ultra HD TV.View Deal
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Kylie Jenner's "WAP" Music Video Outfit Is Truly Wild
By Margaret Blatz
"WAP" has taken the world by storm, both as a song and as a music video, putting Cardi B and Megan Thee Stallion into a league completely of their own. But they weren't the only two stars featured in the music video. Despite fan backlash (and Cardi's heartfelt defense), Kylie Jenner's head-to-toe leopard print "WAP" cameo is one you'll not soon forget. Though she only struts across in the screen for about 20 seconds in the video, Jenner made quite the splash, taking the wow factor of the video to the next level.
At 1:40, Jenner enters the "WAP" music video with the sharp click of her heels. A leopard cape sweeps behind her, giving just a glimpse of her thigh-high, stiletto boots and matching high-cut bodysuit. The front features a revealing bodice with a chest cut-out that meets as a choker. Completing the look, Jenner wears a pair of opera length, leopard print gloves. As she struts, her flowing, chocolate hair bounces around her and the cape accentuates her every stride. Jenner floats through the video so powerfully, even the leopard looks jealous of her. For 20 seconds, Jenner absolutely destroyed it.
If you're wondering how you can get Jenner's look on lock before Halloween or your next night out, it'll take some work. The bodysuit, gloves, and cape were custom made by designer Rey Ortiz while the corset with the black, leather trim was created by Garo Sparo. Her boots were a pair of Casadei Leopard boots that retail for $1,100, so it's not the most affordable look out there. With pieces from so many different places, it's amazing how perfectly matched all of Jenner's leopard print is.
Courtesy of YouTube
The beauty mogul wasn't the only one that was decked out in custom-made designer wear. Both Megan and Cardi wore custom-made bodysuits almost exclusively throughout the "WAP" music video. Normani and Rosalía showed off their dance moves in Venus Prototype latex sets. Mulatto, Rubi Rose, and Sukihana — who also made cameos in the video — rocked a lot of latex as well. Every outfit throughout packed a punch.
Although this isn't Jenner's first music video appearance, it was my favorite. The outfit, the strutting, and the confident energy all took this moment to the next level.

redpajama_set_name: RedPajamaCommonCrawl


John Deere 425D, 430D, 435D, and 440D Drapers are capable of windrowing out of the center, right, or left ends of the draper with effortless change using the hydraulic deck-shift option.
The deck-shift option gives larger windrows to match up with larger combines and self-propelled forage harvesters (SPFH). This provides the option for matching narrower-width drapers with higher-capacity harvesting. The deck shift also gives the capability of putting a higher-density windrow in front of a combine or SPFH when the crop yields are low during drought years.
Hydraulic deck shift allows discharging two windrows side by side with the heads of the crop aligned. This gives uniform feeding into the combine or forage harvester for a smooth and efficient harvest.
Hydraulic deck shift gives the ability to change the center belt opening quickly and easily for different crop types and density. This is done by moving the chain stop. See operator's manual for more information.
Hydraulic deck shift gives the ability to discharge the crop to the outside on the headland to prevent running over the windrow while cutting the rest of the field.
The hydraulic deck shift option gives the capability to shift decks from left-to-right or right-to-left discharge with the press of a button. On the W150, the control also adjusts the fine-float adjust to keep the platform balanced.
An optional double draper drive bundle is available and recommended when using deck shift and harvesting silage or wet, heavy crops. Note the double draper drive option is not compatible with the 425D Platform.
There are optional left- and right-end swath deflector rods. When using the deck shift, these rods form a space between the windrow and uncut crop to have adequate clearance for the crop divider on the next pass.
The 430D, 435D, and 440D Draper models can be equipped with an integral, slow-speed transport system. One person can convert the draper from field to transport in minutes without the use of tools.
The W150 Self-Propelled Windrower is the only model approved to tow a 400D Draper Platform. Transport is also recommended behind a tractor with a seven-pin electrical lighting outlet.
Dual front-dolly wheel tires and two gauge-wheel tires carry the complete weight of the draper when in transport.
Move right gauge wheels from field to transport position.
Move left gauge wheels from field to transport position.
400D Series Draper Platforms offer optional 15-in. dual-gauge wheels with spring suspension. This combined with the windrower float system provides flotation and excellent ground following in all conditions.
The operator can fine adjust the float on the go from the cab, allowing high-speed harvesting and stable flotation with the assistance of the adjustable spring-loaded gauge wheels.
The gauge wheels are also available as part of the integrated slow-speed transport system option.
The 400D Draper Platform features a cam design reel that feeds well in all crop conditions.
The cam pickup reel features a 165-cm (65-in.) effective diameter and utilizes heavy-duty plastic or steel fingers and heavy tine tubes. The reel features a cam to control tooth position. The smooth cam action and heavy tine tube design allows the reel to operate at higher speeds with a smoother, quieter operation. This gives better feeding with less wear on the reel drive components and, more importantly, less shatter of the crop harvested.
The reel is designed and assembled to have an hourglass shape. This allows the ends to be positioned closer to the cutterbar for positive feeding while keeping the fingers at the center of the reel span from coming into contact with the cutterbar. Feeding is most important at the ends. Other reel designs do not have the capability of such tight adjustment. The hourglass shape is designed with an adjustable bolt position on the reel tine tube brackets to the discs.
Optional end fingers improve feeding aggressiveness in difficult feeding and cutting conditions with down and tangled crop.
The reel is available in five-, six-, or nine-bat configurations. The nine-bat configuration gives more interaction for more positive and smooth crop flow in heavy down crop conditions. Additional bats can be field installed to convert from six bats to nine bats. Additional bat configurations are recommended for heavy crop conditions such as silage and grass seed crops.
The cam position and reel position are adjustable, enabling the machine settings to be matched with the crop conditions for a trouble-free harvest. The finger release position is easily adjustable to one of four cam positions.
The reel is hydraulically positioned up, down, and fore-aft to allow perfect positioning for gentle yet positive feeding action.
Plastic fingers come standard from the factory on all platforms. Steel finger options are available through Parts and are recommended for heavy forage crop conditions due to the longer life. The plastic fingers are recommended for all crop conditions. The plastic fingers weigh less and work well in all crops. The plastic fingers are easier to replace individually without having to disassemble the other fingers on the reel tube section.
All 11-m (35-ft) split-reel platforms (North America and export) and the 12-m (40-ft) split reel platforms (North America only) come standard with tine tube stiffener kits to handle heavy crop conditions and improve the life of the platform.
The reel is available in a single span only from 4.1-m (15-ft), 6.1-m (20-ft), and 7.6-m (25-ft) sizes. Single-span or split-reel spans are available in 9.1-m (30-ft) to 11-m (35-ft) sizes. Split reel only is available in 12 m (40 ft) size. There are optional end feed fingers (three per end are available as field installed) for tough feeding conditions.
The single-span reel offers less weight and better center visibility. It is a good option for producers who harvest canola and small grains for oil and seed.
The split-reel span gives better feeding in adverse crop conditions such as heavy, wet, and down crop. The split span gives better control of the reel height on wider platforms for more consistent feeding.
The unique C-shape cutterbar allows for easy crop flow onto the draper while providing a superior draper-to-cutterbar seal. The seal between the top of the C-shape cutterbar and the draper belt is important to limit the amount of material that gets under the belts. The open design at the bottom of the C-shape cutterbar allows any material that does get past the seal to fall back out. This reduces the amount of material that gets inside the draper belts. This cutterbar shape promotes smooth crop flow across the cutterbar, minimizing hesitation and crop loss in shatter-prone crops.
The cutterbar and frame designs give excellent visibility across the full range of tilt.
The cutterbar and belt can be easily seen from the cab even with the optional top-crop conveying auger installed.
The cutterbar can be tilted from the cab mechanically or hydraulically depending on the windrower option chosen.
This allows operators to optimize the cutterbar angle for varying crop and field conditions, thus extending the harvest day and providing the best possible cut height and crop flow.
Sales, parts, and service support from your local John Deere dealer offer overnight parts delivery and a well-trained support staff.
An optional reverser is available for the W150 only. It is easily activated from the operator's station to clear the platform of plugs that may occur.
On the 400D Platforms, the reverser slowly reverses the knife drive and optional hay conditioner if equipped to clear plugs. The reverser is highly recommended when using the optional hay conditioner with the 400D Draper Platform.
On the 100A Auger Platform the reverser slowly reverses the conditioning rolls, auger, and reel. This makes a difficult job easier, so the operator can be more productive.
Operators can run the machines nearer to their maximum capacity and it will take less time to unplug, adding to the machine productivity.
The reverser consists of a valve block and valves shown in photo above. It is the gold colored valve block to the right of the photo. It is shown plumbed for a 100A Auger Platform.


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Home/News & Events/COVID-19 and Charterparty Disputes. Part I – Common Issues
COVID-19 and Charterparty Disputes. Part I – Common Issues
The continuing COVID-19 pandemic has had its impact on all sectors of the maritime industry without exception – including the ship chartering market. In Part I of this post RUMLA's team will discuss which aspects of charterparties are most likely to give rise to disputes – regardless of the type of charter. In Part II we will consider problems peculiar to time and voyage charters.
What are charterparties?
The term 'charterparty', or simply 'charter', refers to several different types of contracts under which a shipowner transfers to the charterer a degree of control over his ship. The most frequently used kinds of charterparties in the market are bareboat, time, and voyage charters.
Under a bareboat charter, the owner gives the charterer possession of the entire vessel, without crew, for an agreed period of time. The charterer becomes a de-facto owner of the ship: he employs his own crew and fully maintains the vessel for the duration of the charter. The shipowner merely receives hire (i.e. periodic payments). Bareboat charters are frequently entered into as financing arrangements to purchase new ships or for tax purposes.
In a time charter, the charterer effectively buys the ship's commercial earning capacity for a certain period of time. During the charter period, the charterer decides to which ports the vessel should proceed and which cargoes it will carry. He also bears all expenses related to the ship's commercial use (bunker fuel, port charges, etc.). Meanwhile, the shipowner retains possession of the ship and his own crew on board. He also provides technical maintenance and determines how to execute the charterer's commercial orders from the navigational point of view. The time charterer operates at a profit if his earnings from carrying other companies' cargoes on the chartered ship exceed the rate of hire which he pays to the owner every month or two weeks.
Voyage charters work very much like ordinary contracts of carriage. The charterer purchases the right to use all or part of the ship's carrying capacity during one or more voyages to carry cargoes specified in the charter between agreed ports. Often, the voyage charterer himself is the shipper (consignor) or receiver (consignee) of cargo carried on board. Overall, he exercises very little control over the commercial or navigational uses of the ship. Most such decisions are taken by the owner, who also bears almost all expenses of the voyage. The charterer only pays a single sum of freight – lumpsum or in two instalments, before and after the voyage.
Charters are almost always concluded on standard contract forms developed by specialized organisations, like the Baltic and International Maritime Council (BIMCO), or by large oil & gas companies (e.g. Shell or BP). These standard forms are identified by abbreviated code names, e.g. NYPE 1946 – which stands for the New York Produce Exchange Form, as revised in 1946). Parties frequently subject their charters to English law, so in this post we will on occasion refer to English decisions.
Seaworthiness of the chartered vessel
Almost any charterparty contains provisions about seaworthiness. Usually the shipowner's duty is two-pronged: to ensure the vessel's seaworthy condition before and at the moment the charter begins [1] and to maintain the ship in that condition during the charter period. [2]
The charterer may refuse to accept delivery of an unseaworthy vessel and can withhold freight until the unseaworthy condition is rectified. If it has not been for a sufficiently long time, the charterer may terminate the contract and claim damages caused by the breach.
Why can the COVID-19 pandemic potentially lead to disputes about seaworthiness and what does the virus have to do with it at all? The reason is that 'seaworthiness' means a great deal more than just readiness of the ship and its mechanisms for the voyage. The vessel must also be fit for accepting and carrying agreed cargoes ('cargoworthy'), have competent and sufficient crew, [3] as well as comply with the ever-growing number of international and domestic regulations. For example, ships have been considered unseaworthy merely because:
only one crew member suffered from alcohol addiction; [4]
the vessel's passage plan failed to include just one notice to mariners (i.e. an update to sea charts); [5]
some members of the crew were not properly trained to use firefighting equipment on board; [6]
the vessel did not have a valid deratisation certificate (i.e. a confirmation that it was free of rats). [7]
During the COVID-19 pandemic, a vessel may be found unseaworthy if, for example, some of the crew are infected [8] or if the ship has previously called at an infected port and got detained at its current port for disinfection or quarantine. [9] To a great extent, the outcome of possible seaworthiness disputes will depend on whether the shipowner implemented adequate protocols to prevent infection on board and whether such protocols were in fact followed.
Safe port clauses
An overwhelming majority of standard charter forms contain express or implied safe port provisions. [10] In short, these clauses oblige the charterer to only order the vessel to ports which would be safe by the estimated time of arrival. The master may legitimately refuse to proceed to an unsafe port. If a given port becomes unsafe after nomination or after arrival, the shipowner may require the charterer to nominate a different, safe port. If the charterer nevertheless insists on proceeding to an unsafe port, the owner will likely be able to claim indemnity for all losses caused by entering that unsafe port.
A port will generally be considered safe if 'in the relevant period of time, the particular ship can reach it, use it and return from it without, in the absence of some abnormal occurrence, being exposed to danger which cannot be avoided by good navigation and seamanship'. [11] This definition is sufficiently wide for any port with confirmed cases of COVID-19 to be treated as unsafe. However, the owner's unjustified refusal to proceed to a nominated port constitutes a breach of the charter and may be perceived by the charterers as a repudiation/termination. Accordingly, the shipowners will have to present strong evidence of the port's unsafety, considering a number of factors below:
possible length of delays in the port;
risk of infection for crew members;
distance from the port to infected areas;
risk of contact with shore personnel;
risk of stowaways accessing the ship;
risk of detention or quarantine;
response measures taken in the port;
whether calling at the port may subsequently lead to detention, quarantine or denial of entry in other ports.
The shipowners will probably have a hard time proving that the COVID-19 pandemic actually rendered a port unsafe. It is more likely that the spread of the virus is no longer an independent 'danger', but rather a general characteristic of a port – which the owner must be prepared for and which can be avoided by good seamanship. Crewmembers can most of the times take sufficient precautions to avoid contact with shore workers. Quarantine-related detentions last 14 day on average – which is probably not long enough for a port to be considered unsafe to call at. Fumigation and disinfection requirements are likewise not sufficiently intrusive for owners to refuse a nomination. Lastly, possible restrictions in subsequent ports of call are not as ubiquitous and permanent to significantly reduce the vessel's earning capacity and therefore make a port unsafe. Nonetheless, safe port disputes are likely to be quite fact-specific and much will depend on the circumstances of a particular case.
BIMCO Infectious or Contagious Diseases Clauses and INTERTANKO Coronavirus Clauses
Sometimes parties expressly incorporate special infectious diseases clauses in their charters. One set of such clauses was developed by BIMCO during the Ebola outbreak, separately for voyage [12] and time [13] charters.
How do these provisions work? For example, BIMCO's time charter clauses specifically allow the owners not to proceed to any port or place where:
there is a risk of exposure to the vessel, crew or other persons on board to 'a highly infectious or contagious disease that is seriously harmful to humans', or where
there is a risk of 'quarantine or other restrictions' being imposed in connection with such a disease.
The charterers are obliged to nominate an alternative, safe port. They bear all risks of entering an unsafe area and must in any event indemnify the owners for any delays, costs, expenses or liabilities incurred as a result of entering an affected port or area. The vessel also remains on-hire whilst awaiting the charterers' alternative orders or if delayed in the affected port.
It should be noted that BIMCO's clauses have not yet been tested in court during COVID-19. It is therefore not entirely clear whether they apply to the current pandemic at all. For example, a court may find that the coronavirus is not 'a highly infectious or contagious disease that is seriously harmful to humans', given its relatively low mortality rates compared to other similar pandemics. A court may also consider that there was no risk of infection in a specific port, provided the owners had an opportunity to take sufficient precautions against such infection getting on board. Finally, in practice, many charterers simply refuse to incorporate the BIMCO clauses in their charters. They reason that if COVID-19 is in fact 'seriously harmful to humans', then a vast number of ports may potentially become off limits for them.
In February 2019, probably in response to the charterers' dissatisfaction with very pro-owner BIMCO clauses, INTERTANKO released its own 'coronavirus' clauses for time and voyage charters. [14] They allow the owners not to proceed to a nominated port only if there is a risk of infection to the ship or crew – but not if there is a risk of quarantine or other restrictive measures.
If an outbreak of COVID-19 has been found on board, the vessel may need to call at the nearest available port, e.g. to provide medical treatment to an infected crew member. Most of the time, standard charterparty provisions called 'liberties clauses' allow the owner to deviate from the route agreed by the charterer 'for the purpose of saving life at sea'. [15] Moreover, Arts. 62 and 63 of the Russian Merchant Shipping Code impose on the master (the owners' employee) an express duty to enter the nearest port to receive urgent medical treatment. Nonetheless, the owners will still have to prove that the crew member's life was in fact in danger, i.e. to show life-threatening symptoms and the need for immediate medical care.
If deviation was required for the purpose of saving life, the charterer is not entitled to claim damages for the resulting delay. However, in time-charters, such deviation will most likely put the vessel off-hire for the period of deviation. [16] In voyage charters, the risk of deviation is already on the owners – so the charterers will not be liable for extra freight for increased voyage distance.
Deviation may also occur if the port of entry is closed (e.g. to prevent the risk of infection coming from the entering ships) or there are other significant obstacles to entry. In this case, some standard charterparty forms specifically allow the owners to discharge cargo at the nearest available port. Even where such a right does not follow expressly from the charter, Art. 153 of the Russian Merchant Shipping Code entitles the owner to do so if the charterers fail to give alternative instructions within a reasonable time.
Fumigation/disinfection expenses
A vessel may require fumigation or disinfection – e.g. if some of the crew have contracted COVID-19 or if the ship arrives from an infected area. Under most standard charterparty provisions, if fumigation is necessary due to crew infection, it is for the owners' account; if due to previous calls at an infected port – for the charterers'. [17] BIMCO's contagious diseases clauses or INTERTANKO's 'coronavirus' clause also provide that fumigations required due to the vessel's previous calls are paid for by the charterers.
Force majeure clauses
Parties frequently add force majeure provisions to the standard charter forms. Usually, these clauses list a number of evidence beyond either party's control or foreseeability and specify the consequences of such events occurring – whether the party relying on force majeure must notify the other, whether an event gives the right to terminate/rescind the charter or whether it merely suspends performance or excludes liability. [18]
Whether a force majeure clause is triggered by COVID-19 will depend on the wording of a particular clause (e.g. whether the it lists 'epidemics', 'quarantines' or 'any government intervention, requirement, or interference'). Force majeure provisions may apply together with other clauses in the charter – for example, early cancelation, automatic termination, or mutual exceptions clauses.
Specialised organisations in some states (e.g. Russia or China) issue so-called 'force majeure certificates'. These documents have no predetermined evidential value for courts or arbitral tribunals. At least in Russia, a certificate is merely a piece of evidence that a force majeure event may have occurred. [19] The final determination as to whether or not COVID-19 or any government measures taken in response constitute force majeure will still be made by a court or tribunal interpreting a specific clause in a given charterparty.
The burden of proving force majeure is on the party invoking it. That party must also prove causation, i.e. that the force majeure event prevented or hindered the party from performing the charter. If a given event merely makes performance less commercially practicable, there is likely no causation – e.g. if a charterer refuses to take delivery of the vessel because the project for which the vessel was intended has been suspended due to 'public holidays' being declared by the Russian president in response to the pandemic.
Finally, many force majeure clauses will only apply if the party invoking them gives timely notice to the other party and also takes all reasonable steps to avert and minimize that other party's losses.
Unavoidable force, impossibility of performance and fundamental change of circumstances
Apart from express force majeure provisions, Russian law recognize three somewhat similar concepts, which apply even if not specifically mentioned in the text of a charter.
1) Unavoidable force (Art. 401(3) of the Russian Civil Code)
To qualify as 'unavoidable force', a circumstance must be extraordinary and unavoidable by any other person engaged in the same type of trade or business as the person invoking it. [20] Like some force majeure provisions, unavoidable force will not terminate the charter or any obligations arising out of it. Rather, it will merely suspend performance until the unavoidable circumstance ceases to exist. However, until such time comes, the party invoking unavoidable force is not liable for possible breaches of the charter [21] (which also means that penalties and interest do not accrue and neither damages for delay [22] nor demurrage may be claimed [23]). Nevertheless, the other party may still validly terminate the charter if unavoidable force caused the charter to be materially breached. Unavoidable force is also similar to force majeure in that the party invoking it must notify its counterparty and must take all reasonable steps to minimize that party's losses. [24] Whether the COVID-19 pandemic itself or any governmental measures taken in response to it (e.g. closures of ports and other businesses, quarantines, introduction of prolonged 'public holidays', etc.) will qualify as unavoidable force will very much depend on the facts of a particular case.
2) Impossibility of performance (Arts. 416-417 of the Civil Code) and fundamental change of circumstances (Art. 451)
'Impossibility' will only apply if it (1) arises after the conclusion of the charter, (2) is objective, (3) insurmountable (permanent), and (4) is caused by a circumstance for which no party is in some way responsible. [25] Unlike unavoidable force, impossibility of performance terminates contractual obligations, in part or in full.
Given how many requirements must be satisfied, it is quite unlikely that a party will be able to establish true impossibility in a charter dispute. Fist, the impossibility must be 'objective' – i.e. a party must be unable to perform the charter either by itself or by engaging any third parties. Second, the circumstance must be 'insurmountable and permanent' – i.e. guaranteed not to pass until the time for performance expires. However, most government restrictions imposed to combat COVID-10 are temporary and are not so significant as to fully prevent a party from performing – either by itself or through third parties.
Third, 'impossibility' only relieves a party from liability if that party has not assumed a risk of that event materializing – i.e. that particular risk was not shifted or foreseen in the charter. Bur almost any standard charterparty form contains very wide mutual exceptions clauses or includes additional force majeure provisions – which inevitably mention the risk of government actions. [26] Most likely, it will mean that the parties considered and foresaw the risk of government restrictions in the charter – thereby ousting Arts. 416-417 of the Civil Code on impossibility.
3) Fundamental change of circumstances (Art. 451 of the Russian Civil Code)
For exactly the same reason, it is quite unlikely that in charter disputes we will see parties successfully relying on fundamentally change circumstances in order to modify or terminate their contracts. To do so, a party must show that at the time of conclusion of the charter both parties assumed that the particular change of circumstances will not occur [27]. However, if a specific risk has been shifted or foreseen in the charter, this means that the parties could take it into account when entering into the contract. Also, coronavirus-related delays in ports are usually not prolonged enough to be considered 'a fundamentally changed circumstance' – i.e. that if the parties had known about it when contracting, they would not have entered into that contract all or would have done so on substantially different terms. [28]
Using chartered vessels as floating storage
Due to temporary closures of manufacturing facilities and the overall decrease in production in main oil-importing countries, the supply of oil has far exceeds the demand. As a result, chartered tankers fully laden with oil now cannot unload their cargoes at discharge ports – either because the ports themselves are closed or too congested, or because the buyers have rejected that oil, which is now difficult to resell. Can charterers in this case use the ships as floating oil storage facilities?
In time charters, the charterers may ordinarily use the vessel however and wherever they wish subject to trading limits and the duration of the charter itself. Although some standard forms do expressly allow to convert the chartered vessel into a floating storage, [29] the vast majority of forms do not. Whether it would be permissible to use the ships for storing oil will depend on the length of storage – the longer the period, the more justified the owners will be in refusing to comply with the charterers' order. Also, the charterers will need to bear in mind that if the owners do agree to a proposed conversion, receivers of cargo under bills of lading may still potentially sue the owners (e.g. for breach of the duty to proceed with reasonable despatch). In turn, the owners will likely be able to claim these losses from the time charterers under express or implied indemnity provisions in the charter. Accordingly, the charterers should be careful to include bill of lading holders in any negotiations concerning floating storage.
The position in voyage charters is more complicated. Such charters usually fix the port of loading beforehand. The owners must also proceed with all reasonable despatch to avoid liability to bill of lading holders. It is likely that owners in voyage charters will be far less willing to convert the chartered ships into floating storage facilities. On the other hand, they may be persuaded to do so if the charterers remain on demurrage and the rate of demurrage exceeds the current hire rate on the market.
In Part 2 of this post RUMLA's team will discuss COVID-19 problems and possible disputes peculiar to time and voyage charterparties.
Sources: [1], [2], [3], [4], [5], [6], [7], [8], [9], [10], [11].
This material and all other materials on RUMLA's website are intended for general information purposes only and do not constitute legal advice.
[1] E.g., lines 5, 21-25 NYPE 1946, cl. 2 NYPE 1993, cl. 2 GENCON 1994, cl. 1 ASBATANKVOY.
[2] E.g., cl. 1 NYPE 1946, cl. 6 NYPE 1996, cl. 2 GENCON 1994, cl. 1 ASBATANKVOY.
[3] Art. 124(1) and Art. 203(1) of the Russian Merchant Shipping Code (MSC).
[4] Hong Kong Fir Shipping Co Ltd v Kawasaki Kisen Kaisha Ltd [1962] 2 QB 26.
[5] Alize 1954 v Allianz Elementar Versicherungs AG (The CMA CGM Libra) [2020] EWCA Civ 293.
[6] Manifest Shipping Company Ltd v. Uni-Polaris Shipping Company Ltd (The Star Sea) [2001] UKHL 1.
[7] The Madeleine [1967] 2 Lloyd's Rep. 224.
[8] The Eurasian Dream [2002] EWHC 118 (Comm)
[9] Ciampa v British India Steam Navigation Co Ltd [1915] 2 KB 774.
[10] E.g., lines 20, 27, 31 NYPE 1946; cl. 5, 12 NYPE 1993; cl. 1 GENCON 1994; cl. 1 ASBATANKVOY.
[11] The Eastern City [1958] 2 Lloyd's Rep. 127.
[12] https://www.bimco.org/contracts-and-clauses/bimco-clauses/current/infectious_or_contagious_diseases_clause_for_voyage_charter_parties_2015
[13] https://www.bimco.org/contracts-and-clauses/bimco-clauses/current/infectious_or_contagious_diseases_clause_for_time_charter_parties_2015
[14] https://www.intertanko.com/info-centre/model-clauses-library/templateclausearticle/intertanko-covid-19-coronavirus-clause-voyage-charterparties-explanatory-notes
[15] cl. 16 NYPE 1946, cl. 22 NYPE 1993, cl. 27(b) Shelltime 4, cl. 19 ASBATANKVOY, cl. 3 GENCON 1994, impliedly in cl. 12 BALTIME 1939 (as revised 2001).
[16] See, e.g., cl. 17 NYPE 1993, cl. 21(а)(iii) Shelltime 4.
[17] cl. 2 NYPE 1946, cl. 7 NYPE 1993, cl. 17(b) ASBATANKVOY – though cl. 4 BALTIME 1939 imposes the duty to pay for fumigation exclusively on the charterer, while cl. 6 Shelltime 4 – exclusively on the owner.
[18] E.g., cl.cl. 31-32 SUPPLYTIME 2005.
[19] Russian Supreme Court's Review of COVID-19 Related Case-Law and Legislation №1, question 7.
[20] Resolution of the Plenum of the Supreme Court of 24.03.2016 № 7, para. 8.
[21] Ibid, para. 9.
[22] Resolution of the Plenum of the Supreme Court of 11.06.2020 № 6, para. 38.
[23] i.e. agreed payment for using the vessel in excess of laytime.
[26] E.g., cl. 16 NYPE 1946, cl. 21 NYPE 1993, cl. 27(а) Shelltime 4, cl. 32 SUPPLYTIME 2005, cl. 19 ASBATANKVOY, impliedly – in cl. 12 BALTIME 1939.
[27] Art. 451(2) of the Russian Civil Code.
[29] E.g., cl. 21 BPTIME 3.
Anti-Suit Injunctions in Sanctions Disputes in Russia: Main Issues
COVID-19 and Charterparty Disputes. Part II – Issues Under Time and Voyage Charters


a) Calculations and estimation of reinstatement costs.
b) Preparation of schedules of works and/or bills of quantities for issue to contractors for tendering.
c) Evaluation of the prices submitted by the tendering contractors.
d) Provision of additional information in relation to (a), (b) and / or (c) above.
e) Supervision of (re) construction works.
f) Recommend payments to service providers on behalf of the contracting party.
We have specific expertise in achieving value for money and controlling construction costs. We offer a range of services to insurance companies / loss assessors to assist them in managing insurance claims which include examining, quantifying and querying reinstatement costs presented to them as part of a claim, and supervising the actual reinstatement work and / or payment schedule on the insurance companies behalf.


The Hive View Smart Camera has a stylish brushed copper and black aesthetic with excellent functionality. It is packed with several must have features such as 1080p HD recording, a pet friendly mode, and a privacy mode that disables the camera when you don't want it to record. The stand out feature however, is the ability to remove the cubical camera from its mount, and monitor a different location in your home for up to an hour. Perfect for when you are going out and want to keep an eye on a specific location like the kids or pets. Thanks to its stylish design, the Hive View also blends very easily into its surroundings, especially when it is used in the "cube only" mode.
Using the Hive view couldn't be any simpler. All you need to get started is a smartphone with an up to date version of iOS or Android that has Bluetooth, a broadband connection with at least 1.5Mbps or higher bandwidth and your Hive View Camera. Once it is set up you can enjoy the 1080p Full HD video stream, 130-degree field of view, and the 5 metres of night vision. Put the Hive View in the area you'd like to monitor, check its placed correctly on the app, and carry about your day as you wish!


A try double for summer signing George North ensured the Ospreys got the new Guinness PRO14 campaign off to a winning start, edging a tight contest at the Liberty Stadium.
All-square at the break at just 3-all, Edinburgh were leading 6-3 just before the three quarter point of the game before North, always a threat, exploded into life with an exhilarating brace.
Sam Davies stretched the lead with two conversions, taking him past 500 points in the competition – only the third Osprey to achieve that – before a late rally from Edinburgh, Blair Kinghorn touching down and Jaco van der Walt converting, but the hosts survived a late onslaught to celebrate an opening day win for the fourth consecutive year.
The home team started positively, moving the ball around at every opportunity and just four minutes in they thought they'd opened the scoring, debutant Scott Williams dinking a perfectly weighted ball behind the defence for Dan Evans to chase.
The full back and Edinburgh's Henry Pyrgos raced to ground it, the TMO confirming the visiting scrum half got there first.
Just a minute or so later Luke Price was handed his first sight of goal but his penalty attempt from 40 yards failed to hit the target.
It was all Ospreys in the early exchanges and the home crowd got their first glimpse of George North in full flight as he looked to find his way up the right before Scott Otten was bundled into touch a metre out.
After absorbing the pressure Edinburgh were able to build a greater share of possession without looking like threatening the Ospreys line and as we moved into the second quarter the scoreboard remained blank.
A Tom Botha obstruction on 30 minutes was punished by Edinburgh, Tom Hickey splitting the posts from more than 40m out.
The Ospreys responded immediately, aggressive work at the breakdown winning a penalty in kickable territory and this time Price made no mistake to level it.
Just before the break there was an enforced change, the outside half limping out of the action after taking a bang to the leg, Sam Davies replacing him.
Within two minutes of his arrival, Davies had a chance to send his team in at the break with the lead, a huge scrum rewarded with a penalty but the long range kick, with time up, never looked like hitting the target.
After a pretty uneventful opening to the second half that saw Edinburgh edging it, it was the visitors who eventually got the scoreboard moving 55 minutes in through another Hickey penalty, this time a simple one in front of the posts after an Ospreys offside.
That sparked the Ospreys into life and just three minutes later they had the lead, the first try of the night and a debut touchdown from North. Taking the ball from Dan Evans on the right, the big wing still had plenty to do as he cut infield, beating two defenders to score.
Davies was on target with the conversion, taking him to the 500 point landmark.
North had the Ospreys fans on the edge of their seats again a minute later with a powerful break up the right and as the pressure built the hosts were unable to take advantage of an overlap on the opposite side, Alun Wyn Jones' pass evading Hanno Dirksen and going straight into touch.
It got better for North 10 minutes later when he grabbed his second, running in from his own half after the Ospreys won turnover ball inside their own 22. Sam Cross broke and then, eventually, it was Justin Tipuric who freed his winger on the 10m line, North racing upfield to score, Davies with the extras.
Edinburgh threw everything at their opposition in the closing minutes and it as no surprise when they reduced the deficit through Kinghorn, the full back crashing over after a series of close range pick and drives, converted by van der Walt.
An infringement on halfway allowed the visitors one last go, but their lineout drive went to ground short of the line, referee ruling a turnover and giving the scrum to the Ospreys who were relieved to get the ball off the field.


The birth of a new child is always exciting, but there's no need to wait until the baby arrives to start celebrating. Send a pregnancy announcement to get everyone ready for the big day months in advance.
What to put on your pregnancy announcements depends on how much you know. Typically, the date the baby is expected to arrive is the main piece of information noted. It's a good idea to say the child will arrive "around" the date, since new children do not look at calendars and may come a few days before or after the expected time.
If you know the gender of the new arrival, you can include that info as well. Finally, the names of both parents should be included. Use your first names or you can go with the first and last if you want to be a bit more formal.
Typically, the tone of a pregnancy announcement is lighthearted or even humorous. This imparts a happy and celebratory tone without the formality that is associated with an invitation or similar communication.
You want to let people know that you're expecting and happy about it but without the implications that you expect anything of the recipients at this point. Of course, sending out these announcements primes people for the invitations that might later, but for now, keep things light and airy.
Even though the father gets mentioned on the card, pregnancy announcements are all about the mother and the upcoming child. Therefore, feminine fonts are popular. Pastel backgrounds are also favorites. If this isn't your style, don't fret. You can always go with something more neutral. Our design module lets you craft a personal message that suites your style.
Ouly.com is happy to be a part of your life's most joyous occasions. With over 1,000 hand crafted-designs we are sure you will find a design that fits your style.


Quality is of the essence here. First of all, what we're talking about here is pure, therapeutic grade essential oils from plants, NOT synthetic fragrance oils or perfumes, which can be toxic and typically contain allergenic compounds.
The University of Minnesota1 offers some helpful guidance regarding international standard-setting agencies and considerations to take into account when looking for an essential oil.
One of the most important considerations is to look for a statement of purity. What you're looking for is 100% essential oil (meaning it has not been diluted, altered, or mixed with anything else). Price can be a tipoff. If it's really cheap, it's probably a reflection of poor quality.
There are many ways to use essential oils for health and well-being, and the featured article2 lists no less than 25 ways to enjoy them. But first, let's address the question of whether or not they actually have a biological effect, and if so, how.
When you inhale the fragrance of an essential oil, the aroma penetrates your bloodstream via your lungs,3 and this is thought to be one of the mechanisms by which aromatherapy exerts its physiological effects. Essential oils are also easily absorbed through your skin when applied topically.
Modern scientists are not only finding compelling links between scents and human behavior,5 scents can actually influence the biochemistry of your nervous system.
A Korean study7 found that lavender reduced both insomnia and depression in female college students.
"Since lavender oil showed no sedative effects in our study and has no potential for drug abuse, silexan appears to be an effective and well tolerated alternative to benzodiazepines for amelioration of generalized anxiety."
"Compared with placebo, jasmine oil caused significant increases of breathing rate, blood oxygen saturation, and systolic and diastolic blood pressure, which indicated an increase of autonomic arousal.
In conclusion, our results demonstrated the stimulating/activating effect of jasmine oil and provide evidence for its use in aromatherapy for the relief of depression and uplifting mood in humans."
An article in Healthy Holistic Living10 discusses some of the components giving essential oils their therapeutic benefits. For example, some essential oils have tremendous antioxidant capacities.
Phenylpropanoids have antibacterial, antifungal, and antiviral activity. As noted in the article,11 "phenylpropanoids clean the receptor sites on the cells.
Without clean receptor sites, cells cannot communicate, and the body malfunctions, resulting in disease." Oils that contain this type of terpene include: clove, cassia, basil, cinnamon, oregano, anise, and peppermint.
Monoterpenes, which are found in most essential oils, help "reprogram miswritten information in the cellular memory," according to the featured article.
But that's really just the beginning. There are many creative uses for essential oils. Here's a sampling of the 25 uses listed by the Epoch Times.18 For the full list, please see the original article.
Freshen laundry Dryer sheets are notoriously toxic, emitting more than 600 volatile organic compounds (VOCs) through your dryer vent. You can easily freshen your laundry without risking your family's health simply by spritzing your wet laundry with a mix of water and a few drops of essential oil before placing it in the dryer. Alternatively, add a dozen or so drops to an old wool sock, and put it in the dryer with your laundry.
Aromatherapy can be a beneficial adjunct to your overall health plan. It's not a replacement for wise lifestyle choices like good nutrition and exercise, but it can certainly help enhance your physical and emotional health. Aromatherapy is one more tool you can keep in your tool bag for managing everyday stress, balancing out mood swings and improving your sleep for example.


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Programs » Multimedia » Burn, Rip & Copy
DVD Shrink 3.2.0.15
Bemærk: Din PC kan indeholde malware. Kontrollér den her
Download the DVD Shrink multimedia program for free here , so you can easily rip, save and burn DVDs.
Download the multimedia program DVD Shrink for free here, so you can easily rip, save and burn DVDs.
Today, you can choose from a host of different multimedia programs for your computer, and it can sometimes be difficult to find head and tail on what programs you can really get the most out of. While there are a number of different categories within the multimedia program genre, all programs have a specific purpose - they are designed to help you and make the time you spend in front of the computer a little more exciting and fun.
By ripping the contents of your DVDs to your computer, you save a lot of space, for example, when you are on the go, and would like to see one of your favorite movies on the way home on the train, but do not have room for the DVD in bag. An example of a popular software offering to rip DVDs is DVD Shrink.
Why download the DVD Shrink program to your computer at all?
The DVD is known to be a media format that has the capacity to store everything from videos and audio files to movies, and in most households you will also find colorful collections of expensive DVDs, as the nostalgic slices are have their charm. However, most have also encountered a situation where the DVD no longer works optimally because the disc has been scratched. Therefore, it can be a great idea to make backups of the contents of your DVDs if the accident should be out and they are scratched.
So if you are a DVD enthusiast, you can enjoy a software that can quickly and easily rip the contents of your DVDs. This is exactly where the program DVD Shrink comes on the track. When you rip a DVD, the contents of that DVD are transferred to your computer's hard drive. This way, you can store backup copies of important video recordings and favorite movies on your computer. The files are on your hard drive until you may need one day to burn the contents back onto a new DVD disc.
If you think the DVD Shrink program sounds exciting, visit the developer's own website by clicking on this link. Here you can read a little more about the program DVD Shrink itself and its functions.
User-friendliness as a keyword
Ease of use is an important keyword when it comes to functionality and optimum benefits of the programs you have installed on your computer. A program must be user-friendly and easy to navigate around for all users, which is also typically in the developer's interest. The DVD Shrink developers have made sure that just a few clicks can rip the contents of your DVDs to the hard drive of your computer. Don't worry about decrypting and compressing your files, as DVD Shrink also does this for you, making the program even more user-friendly. When you rip DVDs to your computer, DVD Shrink gets these files to fill less when placed in the hard drive, which also benefits you and your computer's performance. To get the most out of DVD Shrink, you can greatly benefit from the program in conjunction with a burner program such as CDBurnerXP. The program, like DVD Shrink, is also free, and can help you burn your ripped files if you ever need it.
Possibility of support
For many users, the possibility of support also has great importance for the choice of program. Here it can be said that the developers of DVD Shrink have made sure that you can get answers to some of the most frequently asked questions via their own website. If you were having a small problem while using the program, or have any questions regarding the program's features before download, you can follow this link. On the developer's own support page, some of the most frequently asked questions are answered, and at the same time it is described where you can otherwise get additional support.
How is accessibility?
Before you download a DVD ripper program to your computer, it isOf course, it is important that the program meets the needs and preferences of the program features and usability. But something else that is also important to make reservations for before downloading is whether the program is available to your computer. DVD Shrink is compatible with Windows XP, but if you have another operating system, don't worry. There are alternative programs that have the same purpose. Below we will give you some inspiration for where to find alternative programs that are compatible with other operating systems.
Alternative programs
Before deciding which program to install on your computer, it is always a good idea to get some inspiration for what other options could be of interest to you and your preferences. If you have a computer with that Mac operating system, we highly recommend you to read a little more about the popular program Aimersoft DVD Ripper for Mac, which you can also test for free.
If you need a little more inspiration before deciding on a particular program, in our Rip & Copy category, you can find a number of reviews of various programs that can both rip, convert, and burn DVDs and CDs. Here you will find a wealth of programs that support Windows XP and Windows Vista.
In Conclusion, there is now a brief summary of the most important points that describe why DVD Shrink is a software worth downloading to your computer. With the DVD Shrink program, you get a free program that is compatible with Windows XP. The program can quickly rip the contents of your old DVDs to your computer. DVD Shrink is a formidable and easy-to-use program that has some smart features and features that you can easily learn to navigate in. All in all, DVD Shrink is a freeware that we give a great recommendation.
Download DVD Shrink 3.2.0.15
Copy DVDs with few clicks
Good method for backing up DVDs
High ease of use
Compatible with Windows only
Details of DVD Shrink
TERMS OF SERVICE AND END USER LICENSE AGREEMENT FOR DVD SHRINK
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Software and Services are collectively referred to as "DVD SHRINK Services".
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DVD SHRINK Services may include links to third party services and/or the third party services may be made available to you via DVD SHRINK Services. These services may include, but are not limited to gameplay recording and sharing, social medial connectivity and the like. These services are subject to respective third party terms and conditions. Please study these third party terms and conditions carefully as they constitute an agreement between you and the applicable third party service provider.
You agree not to: (i) commercially exploit the DVD SHRINK Services; (ii) distribute, lease, license, sell, rent, lend, convey or otherwise transfer or assign the DVD SHRINK Services, any copies thereof, or any passwords or usernames of DVD SHRINK Services, without the express prior written consent of DVD SHRINK or as set forth in this EULA; (iii) make a copy of the DVD SHRINK Services or any part thereof, including but not limited to Software (other than as set forth herein); (iv) make the DVD SHRINK Services publicly available or available on a network for use or download by multiple users; (v) except as otherwise specifically provided by the DVD SHRINK Services or this EULA, use or install the DVD SHRINK Services (or permit others to do same) on a network, for on-line use, or on more than one computer or gaming unit at the same time; (vi) use or copy the DVD SHRINK Services at a computer gaming center or any other location-based site; provided, that DVD SHRINK may offer you a separate site license agreement to make the DVD SHRINK Services available for commercial use; (vii) reverse engineer, decompile, disassemble, translate, prepare derivative works based on or otherwise modify the DVD SHRINK Services, in whole or in part; (viii) remove, obscure or modify any copyright, trademark or other proprietary rights notices, marks or labels contained on or within the DVD SHRINK Services, falsify or delete any author attributions, legal notices or other labels of the origin or source of the material; (ix) misrepresent the source of ownership of the DVD SHRINK Services; (x) transport, export or re-export (directly or indirectly) into any country forbidden to receive such DVD SHRINK Services by any U.S. or other export laws or accompanying regulations or otherwise violate such laws or regulations, that may be amended from time to time; or (xi) scrape, build databases or otherwise create permanent copies of content returned from the DVD SHRINK Services.
The DVD SHRINK Services may include measures to control access to the DVD SHRINK Service, prevent unauthorized copies, or otherwise attempt to prevent anyone from exceeding the limited rights and licenses granted under this EULA. Only DVD SHRINK Services subject to a valid license can be used to access online services, and download updates and patches. You may not interfere with such access control measures or attempt to disable or circumvent such security features. If you disable or otherwise tamper with the technical protection measures, the DVD SHRINK Services will not function properly.
The DVD SHRINK Services may allow you to create content, including but not limited to gameplay maps, screenshots or a video of your game play. In exchange for use of the DVD SHRINK Services, and to the extent that your contributions through use of the DVD SHRINK Services give rise to any copyright, design right or any other intellectual or industrial property right you hereby grant DVD SHRINK an exclusive, royalty-free, perpetual, irrevocable, fully transferable and sub-licensable worldwide right and license to use your contributions in any way and for any purpose including, but not limited to the rights to reproduce, copy, adapt, modify, perform, display, publish, broadcast, transmit, or otherwise communicate to the public by any means whether now known or unknown and distribute your contributions without any further notice or compensation to you of any kind for the whole duration of protection granted to intellectual and industrial property rights by applicable laws and international conventions. If not expressly prohibited by mandatory legislation, you hereby waive any moral rights of paternity, publication, reputation, or attribution with respect to DVD SHRINK's and other players' use and enjoyment of such assets in connection with the DVD SHRINK Services and related goods and services under applicable law. This license grant to DVD SHRINK, and the above waiver of any applicable moral rights, survives any termination of this EULA.
The DVD SHRINK Services may require an internet connection to access the DVD SHRINK Services or its internet-based features, authenticate the Software, or perform other functions. In order for certain features of the DVD SHRINK Services to operate properly, you may be required to have and maintain (a) an adequate internet connection and/or (b) a valid and active account with an online service as set forth in the documentation related to DVD SHRINK Services. By using the DVD SHRINK Services, you acknowledge and agree that third party data transfer fees may apply depending on your data plan. Please consult your carrier for further information. If you do not maintain such accounts, then the DVD SHRINK Services or certain features of the DVD SHRINK Services may not operate or may cease to function properly, either in whole or in part.
By installing, accessing or using the DVD SHRINK Services, you consent to these information collection and usage terms, including (where applicable) the transfer of data into a country outside of the European Union and/or the European Economic Area or the United States of America.
DVD SHRINK respects your privacy rights and recognizes the importance of protecting any information collected about you. DVD SHRINK's privacy policy as amended from time to time is available at www.dvd-shrink.com/privacy ("Privacy Policy") and applicable to this EULA. DVD SHRINK's Privacy Policy defines how, why and to which extent DVD SHRINK collects and uses personal and non-personal information in relation to DVD SHRINK's products and services. By installing, accessing or using the DVD SHRINK Services you explicitly agree with the terms and conditions of DVD SHRINK's Privacy Policy and to any terms and conditions included therein by reference.
DVD SHRINK may license to you certain virtual goods to be used within DVD SHRINK Services. Unless otherwise specified, these virtual goods shall be deemed an integral part of the Software. These virtual goods may be licensed both for a fee using "real world money" and without any separate fee, as applicable from time to time. These virtual goods may also be licensed by using third party virtual currency, such as Facebook Credits or by using separate activation codes.
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During a typical audit, the tax auditor interviews the taxpayer about the business operations and various factors that influence sales, such as portion standards, selling prices, theft, spillage, own-use and over-pouring. If the auditor exercises sound judgment, the taxpayer's assertions will be considered prima facie evidence that the assumptions are reasonable in the circumstances. These assumptions form the basis for most audit assessments of restaurants and bars. What if they're just plain wrong?
Once the auditor makes a judgment about the assumptions to be used, the onus shifts onto the taxpayer to prove the auditor's assumptions are incorrect. While there is a degree of subjectivity attached to these assumptions, it is not enough to simply come up with other, more favourable, assumptions as a means of disproving the auditor's judgment. Too often, I see taxpayers (and their advisors) simply plugging different assumptions into sales projection spreadsheets and arguing that these assumptions are "more reasonable" than the auditor's. A complete waste of time. This approach will not work. Failure to grasp this point will cost you a great deal of money and, most likely, prevent you from effectively arguing your case on appeal.
One way is to prove that the auditor did not take a reasonable degree of care in exercising his or her judgment in setting the assumptions. For example, the auditor may have interviewed the wrong individual in the restaurant or bar, acquiring incorrect information. The auditor may not have exercised sound judgment in determining the appropriate questions to ask the taxpayer, or may not have investigated apparent inconsistencies, in order to properly set assumptions. While they may try, at times, auditors cannot arbitrarily choose assumptions. Failure to gather enough information to set a "reasonable" assumption can be used to show that the auditor used an arbitrary assumption. The key to refuting the auditor's assumptions is sufficient evidence. A good tax advisor will be able to help gather and present proper evidence to refute the auditor's assumptions.
In other cases, the auditor makes a number of factual errors in the analyses, casting doubt on their accuracy and reliability. Perhaps the auditor failed to use menus that were in effect during the audit period, or to take into account price changes, in setting average prices for the analyses. The greater the number of errors the auditor makes, especially if almost all of them are against the taxpayer, the more likely the auditor's credibility and judgment will be seen to have been impaired.
Much of the auditor's prima facie support for assumptions comes from the initial interview with the taxpayer. Do not go this alone. Seek professional representation prior to the initial interview. It is much more difficult to disprove the auditor's assumptions than it is to help the auditor better understand your business and select the most appropriate, and accurate, assumptions.
If you are faced with inaccurate assumptions, you must gather and present evidence to counter the auditor's judgement. Simply offering your or your accountant's opinion that the assumptions are not reasonable (ludicrous, even) will get you nowhere.
The sooner in the audit process you get professional advice the better.
Great blog… more accountants should be as proactive.
How often are restaurants in Quebec successful in disproving assumptions? What about going to court to fight penalties?
It's not really possible to give a percentage success rate. Sometimes you can reduce the tax, but not eliminate it completely. If you have to go to court to fight the issue, the burden is on the taxpayer to prove that the minister's assumptions were incorrect. The key word, here, is prove. It is not enough to say that, had the auditor used a "more reasonable" assumption, there would not have been any "unreported sales". Every case is different, and the documents and/or testimony required to refute the Minister's assumptions will vary for each restaurant/bar.
There are a variety of penalties that may have been imposed as a result of such an audit. In my experience, CRA tends to use the harsher penalties as a "club" to beat you into submission. CRA has the burden of proving that the penalty is justified. In most cases, they are unable to do so (and they know it). It usually isn't necessary to go to court to have such penalties removed. Filing a Notice of Objection is usually sufficient.
Thanks for sharing useful information about Tax. It will definitely help businesses and individuals.


The Peyton dress is the perfect throw over dress for this summer. Made from 100% organic bamboo this oversized fitting dress features a low back with a tie detail and strap sleeves.
Size: Model is 167cm tall and wearing a size XSMALL.


© Vladimir Cech Jr.. All rights reserved.
My picture is showing endangered and very, very elusive snow leopard in the mountains of western Mongolia and tt was taken by my homemade dslr camera trap.
Date Uploaded: April 16, 2018, 6:38 a.m.


text:
Home Peo...People Groups Meng
Meng in China PRINT VERSION:
The Meng have only been reported in China
The Meng are one of many distinct Hani groups in the region. Little is known of them because Honghe is a tightly controlled area which foreigners have only recently been allowed to enter. In mission literature the Meng have usually been listed as Menghua. Hua means "speech" in Chinese and refers to the name of the language rather than to the people. Note that the Meng are not the same as the Mongolian nationality, who call themselves Meng Zu in Chinese.
The Meng were originally part of a large race who are the ancestors of today's Hani and Akha peoples. The various Hani groups place great importance on being able to recite their genealogies. Research into the historical relationship between the Hani tribes found that they share an identical genealogical record for the first 20 to 22 generations. After that time the groups broke off and became separate peoples. Significantly, the timing coincides with the Mongol invasion of Yunnan and the destruction of the Nanzhao Kingdom in AD 1252.
Due to the horrific practice of female infanticide, the various Hani groups contained 126.5 men to every 100 women in 1987. This imbalance is the worst of any minority in China. Among the Meng, the last syllable of the father's name is used to start the names of his children. Many of the inhabitants of Honghe are employed in tin mines. "Both banks of the Honghe River abound luxuriantly in natural resources. This area is particularly important for the output of nonferrous metals. ... The yield of tin ranks the first in the country. Because of this, Gejiu is known as the Capital of Tin."
The majority of Meng are polytheists. For countless generations they have followed this...religion. In rice-growing areas the Thunder god and the wind ghost are the principal deities worshiped by the Meng.
There is thought to be a small number of Christians among the Meng - the result of outreach by the neighboring Biyo and Kado. H. A. Baker, an independent Pentecostal evangelist, traveled extensively in the area throughout the 1930s and 1940s. "In spite of being short of funds, ... Baker, with his traveling bag on his back and a long stick in his hand, continued his preaching as usual. He slept wherever he was able to find a place and ate whatever he could get hold of; both the [minorities] and he himself almost forgot his national identity."
Scripture Prayers for the Meng in China.
People Name General Meng
People Name in Country Meng
Pronunciation Mung
Alternate Names Mehua; Menghua; Menghwa; Mengwa
People Cluster Hani
People Group Meng
Location in Country Approximately 4,000 Meng are located in Shuangjiang County in Yunnan Province's Honghe Prefecture. The precise location of the Meng within the county is uncertain. One source simply locates the Meng as "south of Dali." The Honghe (Red) River "meanders across the prefecture from northwest to southwest. Of the prefecture's 3.35 million inhabitants, 52.7% are minority people." In addition to the different Hani groups, Honghe is also home to the Yi, Miao, Dai, Zhuang, Yao, Hui, Bouyei, and Lahu. Source: Operation China, 2000
Location in Country Approximately 4,000 Meng are located in Shuangjiang County in Yunnan Province's Honghe Prefecture. The precise location of the Meng within the county is uncertain. One source simply locates the Meng as "south of Dali." The Honghe (Red) River "meanders across the prefecture from northwest to southwest. Of the prefecture's 3.35 million inhabitants, 52.7% are minority people." In addition to the different Hani groups, Honghe is also home to the Yi, Miao, Dai, Zhuang, Yao, Hui, Bouyei, and Lahu.. Source: Operation China, 2000
Primary Language Hani (5,300 speakers)
Language Code hni Ethnologue Listing
People Groups Speaking Hani
Primary Language: Hani
Bible-New Testament No
Film / Video Jesus Film: view in Hani


Bless websites that allow you to insert emoji's by using the : in the input box.
@Fast-Nop Agreed, but I personally feel like the tongue emoji and the ':p' convey different emotions. Just like B-) doesn't feel like the sunglasses 'cool' emoji.