Summing up in criminal trials - a new direction?
The purpose of a summing-up in a criminal trial is to provide the jury with the assistance which it needs to perform its task. That task, simply stated, is to determine whether, upon the evidence presented, the prosecution has proved the guilt of the accused. Historically, the role of the judge in this respect had not been seen to be unduly difficult. Summings-up were short and to the point, and not overburdened by complex analyses of the law, or by commentary on the way in which the jury should approach the evidence.
[T]he late Sir Leo Cussen [a former Chief Justice of Victoria] insisted always most strongly that it was of little use to explain the law to the jury in general terms and then leave it to them to apply the law to the case before them. He held that the law should be given to the jury not merely with reference to the facts of the particular case but with an explanation of how it applied to the facts of the particular case. He held that the only law which it was necessary for them to know was so much as must guide them to a decision on the real issue or issues in the case, and that the judge was charged with, and bound to accept, the responsibility (1) of deciding what are the real issues in the particular case, and (2) of telling the jury, in the light of the law, what those issues are.
the limited extent to which issues can be defined, and defence disclosure required, under existing procedural legislation, prior to the commencement of the trial.
These are some of the matters which the current inquiries will need to confront. Several of these are addressed, in a preliminary way, in this Paper, starting with the increased appellate involvement in the criminal law.
Some of these reasons also help to explain the growth of appeals in the intermediate courts. One result has been a focus on a more strict adherence to legal doctrine, and to the observance of procedural rules. Another result has been the emergence of two separate criminal bars; a trial bar and an appellate bar, whose skills and knowledge do not always coincide. That this is so can be seen from the large number of appeals that are conducted, and succeed, on grounds that were not taken at the trial.
Just as trial counsel have difficulty in keeping abreast of the emerging developments in the criminal law, so too do first-instance judges, who are also disadvantaged by the lack of assistance which they can expect to receive during the trial.
The increase in the number and complexity of the directions which are now required, as a result of these decisions, has inevitably multiplied the opportunity for first-instance error. At the same time, the more that judges try to avoid error by framing their directions with an eye to satisfying the appeal courts, the less comprehensible such directions are likely to be to lay jurors.
Questions arise, accordingly, as to whether anything can be done to simplify, or to restructure, the way in which summings-up are delivered, so as to make them more relevant and comprehensible, while avoiding the kind of errors that lead to successful appeals.
Questions also arise as to whether there should be some different approach taken by the appellate courts, either in the way in which they deal with these appeals, or in the way that they might provide some greater guidance to trial counsel and judges, in order to avoid, or at least to minimise, the risk of error.
sometimes they are bundled up in a series of preliminary directions that risk overwhelming the jury, rather than being placed in context when dealing with the issues or respective cases.
Mindful of this, the NSWLRC has commissioned the Plain English Foundation to review a sample of summings-up delivered in the Supreme and District Courts which have employed the Bench Book directions, to identify any areas where they are unlikely to have reflected a level of communication that would be appropriate for the usual jury mix.
Examples are legion of concepts that are customarily employed in summings-up that are not used in everyday speech, or that are readily understandable. To mention but a few, directions given in circumstantial evidence cases 9 in terms of a 'rational inference or hypothesis consistent with innocence' or one which is 'inconsistent with guilt', and concepts such as 'malice' 10 and 'proximate cause' are likely to be foreign to most jurors. Similarly, a direction to 'scrutinise the evidence with great care' is likely to raise a question as to whether it adds anything to the standard direction not to convict an accused unless satisfied of his or her guilt beyond reasonable doubt.
Of equal importance, however, for the formulation of standard directions in plain English is the need to encourage judges to be selective in their use, and to confine the summing-up to that which is relevant to the issues in the trial, so as to conform more closely with the Cussen formula, 12 that is, unless an alternative approach that would be more relevant to modern-day conditions can be developed.
It is obviously an important part of the task of the jury to reach conclusions in relation to the credibility and reliability of the evidence of individual witnesses, so as to come to a conclusion upon the facts of the case.
The extent to which the jury members should receive assistance from the trial judge in relation to this aspect of the trial, which is within their exclusive province, is however open to debate.
The justification for warnings (in relation to matters of which it is assumed jurors are unaware) and for comments (in relation to matters which it is assumed they may have overlooked) depends on the assumption that trial judges, by their special experience in the criminal law, possess greater knowledge and comprehension in relation to the inherent dangers associated with these forms of evidence. 23 Whether that assumption is well-grounded is, at least in some respects, questionable.
Perhaps the time is ripe to reconsider whether the assumptions are soundly based for all or some of these warnings or comments and whether, in fact, jurors do lack the fairness, underlying knowledge, experience of life, and common sense which has underpinned their use.
Consideration accordingly does need to be given to this aspect of a summing-up, and as to the desirability of the use, in any instance, of the expression 'dangerous to convict', with its implicit encouragement to acquit.
Similar questions arise in relation to some of the other directions that regularly arise for consideration on appeal. There is, for example, the vexed question of post-offence conduct, such as flight and lies told by an accused, which calls for somewhat sophisticated distinctions to be drawn and respected between such conduct demonstrating an admission of guilt or a consciousness of guilt, and those going only to credibility. 28 As Justice Kirby pointed out in Zoneff, there is an inevitable difficulty for jurors in understanding and applying subtle distinctions between the use of evidence for one purpose and not another, and a risk that a warning not to use it for a particular purpose may be counterproductive in exciting the very reasoning which is forbidden, but which might otherwise not have occurred to them.
A real question arises as to whether, with legislative authority, the lies direction could be substantially shortened and reduced to a bare reminder to the jury members to take into account, as they see fit, any evidence showing that the accused has lied, bearing in mind that there may be reasons other than an acceptance of guilt for having done so. Similar formulations are regarded as acceptable in other jurisdictions, for example, in California.
It has been conventional practice for jurors to be informed that it is appropriate for them to observe the demeanour of witnesses when giving their evidence, and to take it into account as part of the fact-finding process. Appellate courts have confirmed the permissible use of demeanour by judges for this purpose, 29 even though they have recognised the existence of a significant body of scientific research that casts doubt on the ability of judges or anyone else to tell truth from falsehood on the basis of appearances alone. 30 The general conclusion of these studies is that the prospects of determining whether a witness is telling the truth from mere visual appearance, dependent on facial expressions, bodily movements, manner of speech and so on, is no better than chance. A real question arises accordingly of whether it is appropriate to continue to give jurors a demeanour direction, or whether it is possibly misleading to do so.
The descent of judges into the arena by giving directions or by making comments on the significance that the jury should, or should not, attach to the evidence has not gone uncriticised. 37 There is a concern that the giving of a judicial imprimatur to these directions or observations, particularly in relation to matters that would appear to be matters of common sense, or within the common experience of life, risks giving them an undue prominence. Moreover, they often serve to add considerably to the prolixity of the summing- up, and invite the glazed-eye phenomenon among jurors who are unable to place the guidance they are receiving into context.
In summary then, should there be a retreat from the extent to which judges intrude into the fact-finding function of juries by way of comment or warnings, leaving it to jurors' own common sense and experience? After all, it was by reason of their supposed qualities, as representatives of the community in these areas of reasoning, that the fact-finding process was assigned exclusively to jurors.
At the least, would it be appropriate for judges to confine their warnings and comments on the evidence to cases where there is a particular basis for concern as to the witness's credibility or reliability, or where it can be clearly established that the evidence does fall into an area outside the ken of lay persons, beyond the mere fact that the evidence falls into one of the identified categories of evidence that can be unreliable?
at the least, reduce the content and breadth of some of the warnings or comments that have become the norm to a more general and brief observation?
what such persons do in fact make of the directions that are given.
The current position is that in England and Wales, 43 Canada, 44 and New Zealand, the concept has been equated to one of the jury being or feeling 'sure' of the guilt of the accused. In each jurisdiction, some further explanation has been regarded as acceptable, although the trend, particularly in England, is to avoid the use of the expression 'beyond reasonable doubt'in case that causes some confusion as to the meaning of the expression 'sure'. Anecdotally, it has been reported that juries rarely, if ever, seek any further explanation of it, although some studies suggest that it is not without its problems, 45 and that a direction framed in simple terms requiring the jury to 'be sure' is less stringent than one expressed in terms of being 'satisfied so that you are sure'.
The question arises whether, having regard to the problems which jurors do appear to have with the succinct direction which is used in this country, and its inherent imprecision, there is now occasion, at appellate level, or though legislation, to revisit this fundamental requirement for proof of criminal guilt.
A question arises as to whether it should continue to be regarded as either appropriate or necessary for judges, in an adversarial system of justice, to direct the jury on the possible availability of defences or verdicts for lesser offences where they have not been raised by counsel.
The question which arises is whether it should continue to be necessary for trial judges to give these directions, particularly in cases where the defence prefers to go to the jury on the substantive count alone.
This is not an insignificant consideration, since it adds to the complexity of the trial in circumstances where counsel in the closing addresses have given no assistance to the jury on the alternative. Certainly, trial judges should be astute not to venture into this area where to do so is to advance some unreal or fanciful possibility or to raise a speculative hypothesis. 48 Perhaps greater attention in this respect should be given to the adversarial context in which criminal trials are conducted, 49 leaving it to the parties to settle the issues for determination.
In some areas, most noticeably defences, it is the reasonable or ordinary person through whose eyes the jury is required to assess the particular facts of the case. It is curious why, when the jury is expected to apply such a test, they are routinely instructed not to perceive themselves as such a person, but to assess the matter through someone else who they consider to have the qualities required. Quite how they select such a person, and what attributes they are expected to assign to him or her, remains unexplained, and very much a matter for conjecture.
Since they are selected as representatives of the community, what is wrong in accepting the response of the ordinary or reasonable person to be that which represents their collective reaction? In fact, do they, in reality, search for some hypothetical person who has some view or reaction that differs from theirs? If not, why should the law add this complexity, and possibly confusing element, to the mix?
A real question arises as to whether the kind of lengthy summary of the evidence that commonly occurs achieves anything in circumstances where the jury have heard the evidence themselves, have received the benefit of addresses from counsel, and potentially have access to the transcript or sound or video recording of the evidence if they wish to check some aspect of it.
There is a risk that undue emphasis on this part of the trial will swamp the more helpful areas of guidance which could be contained in a short and well-focused summing-up or, alternatively, will cause a bored and tired jury to switch off.
In some jurisdictions in the United States, judges do not touch upon evidence and, in some States, they are expressly forbidden from doing so, without any apparent detriment to the trial process. In Scotland, where jury directions are quite brief, even in complex trials, very little reference is made to the evidence beyond that which is necessary to identify the issues and to lay the basis for any appropriate warning.
Lengthy summaries of the addresses are also unlikely to provide much assistance. What, it may be asked, is the reason for judges summarising the addresses of counsel which the jury have only recently heard? This carries the risk of diluting their effect or, worse, becoming an occasion for judges to venture into the arena by advancing additional arguments, 54 or being tempted to respond to the arguments or to make them more intelligible, leading, on occasions, to applications for a discharge of the jury, on the basis that the case of one party has not been fairly left.
Generally, it is the practice for judges to provide an outline of the defence case, 55 although, strictly speaking, no rule of law or practice dictates that they must do so. 56 Where the case for the prosecution is summarised, then fairness will obviously require that the case for the defence also be summarised accurately and fairly. 57 However, save in special circumstances, there appears to be little advantage in the judge providing a detailed regurgitation of the addresses.
This gives rise to the question whether the jury should be given greater assistance by appropriate directions at the commencement of the trial, to ensure that they can understand the relevance of the evidence as it unfolds, and place it into context. At present, there is a real risk, unless the jurors are particularly astute, of missing what is ultimately important, and of being deprived of a proper opportunity for assessing, as the evidence unfolds, whether it supports the prosecution case or not.
This would require a degree of cooperation by counsel in making a proper disclosure of the issues at the commencement of the trial. Although some counsel maintain the right to hold back their defence, in the belief that there is merit in trial by ambush, other counsel seem to have no problem in giving a defence opening.
The adoption of a practice of this kind, in addition to the preliminary observations which are conventionally given, had the support of Lord Justice Auld in the 2001 Review of the Criminal Courts of England and Wales, in the form of his suggested case and issues summary. It was also seen as helpful in the New Zealand Jury Research Project.
A variant of this approach involves giving to the jury, before the addresses commence, a written set of instructions setting out the law and the relevant issues. Although this requires a degree of cooperation by counsel in agreeing upon the document that is provided to the jury, it would help in focusing the addresses.
A somewhat more radical approach would be to abandon the traditional general verdict and to replace it with a system calling for special verdicts. 59 It would have the benefit of protecting the jury from the law and of confining its task to that of fact-finding, as the jurors' oath or affirmation requires, by requiring the jury to bring back verdicts, in the form of answers to a series of specific questions framed in terms of the elements of the offence charged, and of the ingredients of any relevant defences.
So framed, the answers would lead to a general verdict in a way that could spare the jury from working its way through a task that currently expects its members to understand and apply the law, as explained to them, to the evidence as they recall it.
Not only would this provide a greater focus to their deliberations, but it could reduce the risk of error, since the jury would have in front of it specific questions framed with an eye to the law and to the issues in the case which call for essentially factual conclusions.
There might still be a need for some general explanation of the law, perhaps at the beginning of the trial, as well as an identification of where the onus of proof lies, although that could be picked up in the framing of the questions.
Apart from focusing the jury, a process of this kind could also assist in sentencing, for example, where an alternative verdict of manslaughter was potentially available by more than one route.
Admittedly, there would be some added complexity in those jurisdictions which permit majority verdicts, as well as a degree of intrusion into the sanctity of jury deliberations. The latter, however, seems more theoretical than real, and the former should be capable of resolution without much difficulty by advice to the jurors, at the appropriate time (which currently differs between States), of their entitlement to answer the questions on which they have failed to achieve unanimity by a majority verdict.
a copy of the summing-up, so far as it deals with the law.
It may be noted that Justice Bleby in R v Dunn62emphasised the essential oral nature of summing up, and of the need for caution in relation to written directions. On the other hand, the use of such material more closely approximates the way in which modern jurors are accustomed to absorbing, retaining and using information. They tend to be unfamiliar with lengthy oral presentations, being more attuned to acquiring information through the internet and PowerPoint technology.
It is not to be overlooked in this respect that several studies reveal the limited extent to which information given orally is retained in memory, and the even more limited extent to which it is retained correctly. In this respect, juries are currently expected to absorb, retain and then apply the evidence without a transcript in a way which is not expected of judges when reaching a decision.
the potential complications which can arise in cases involving multiple accused, where the prosecution case is pursued on the basis of the several alternatives available, including liability as an accessory, joint enterprise, extended joint enterprise, and even conspiracy or felony murder. These complications are multiplied where the possibility of a conviction on some lesser alternative offence has to be left. Although guidance has been given by the High Court as to the principles to be applied, 66 it remains an exceedingly complex matter for jurors to understand, and one in which judges are prone to error. This is the subject of a separate current reference to the NSW Law Reform Commission, 67 calling for a review of the common law of complicity, and the arguments for and against codification. For that purpose, it will be necessary to review the recent report of the Law Commission (England and Wales), 68 as well as developments in other Australian and international jurisdictions. The significance of this reference, and the possibility it opens up for the adoption of a uniform legislative approach, is made all the more important by reason of the different approaches to extended joint enterprise which apply, dependent upon whether the case is to be determined according to the common law or under the Model Criminal Code. 69 In this respect, it may also be noted that two different tests currently operate in the codified criminal jurisdictions of Australia.
o even as evidence advanced by an accused to suggest that the complainant has exploited his or her past conduct in generating a new and false complaint.
There are many other contexts where multiple and complex directions are required which call upon a great deal of mental dexterity, for example, in relation to conspiracy, provocation, substantial impairment by abnormality of mind (diminished responsibility), self-defence, consent in sexual assault cases, 78 and the like, which can require significant mental gymnastics as a result of the several elements involved.
No less challenging are the directions required for many offences arising under the Commonwealth Criminal Code, with its somewhat complex distinction between physical elements and mental elements, its classification of the circumstances in which there is no criminal responsibility, and its sometimes cumbersome framing of offences, for example, in the area of terrorism.
Some of the problems for trial judges in giving meaningful directions in these areas could be overcome by encouraging the legislature, when framing new offences or amending existing offences, to avoid using terms which are not in everyday use, or which call for extensive supplementary explanation as to their meaning or reach. For example, the concept of 'being knowingly concerned in'certain prohibited activities, without further explanation or guidance being given in the relevant Act, has been notoriously productive of error. The use of expressions such as 'suffers', which are not in common parlance, in the context of certain conduct associated with the possession, manufacture or handling of drugs, is problematic, as can be seen in the case of R v Sheen, 80 where it was held that the jury should have been instructed that it was not only necessary for the prosecution to show that the accused knowingly allowed the third party to carry out the relevant act, but additionally that he had the right or capacity to prevent it.
The risk is that, if the jury members do not understand what clearly is intended to be an important part of the summing-up, they will tend to disregard the whole, and instead rely on their own values, assumptions and experiences to reach a verdict, or, alternatively, respond to their individual emotional reactions to the facts of the case.
Sufficient concern has been identified, through jury studies, through the rising incidence of appeals in criminal trials and orders for retrials, and through the increasing complexity of the criminal law as the legislature strives to promote law and order while preserving fundamental civil liberties, for a new approach to be taken in relation to the summing-up. The simplification of the directions that need to be given, and the development of a structure for a summing-up that will genuinely assist a modern jury in its task would go a long way in producing a more satisfactory trial process.
I would further note that the present case is an example of the extent to which the summing up has developed to the point of almost taking over from all other aspects of a criminal trial. The evidence in the trial took 117 pages of transcript over a period of two days with addresses. The summing up took over a day and comprised 88 pages of transcript. There was so much information given to the jury by way of warnings, directions, comments and review of evidence and arguments that it is little wonder that they had not properly grasped the concept of beyond reasonable doubt by the time they retired to consider their verdicts. With respect, there was an unnecessarily detailed review of the evidence, including cross-examination, in what was a short trial with very narrow issues in a situation where the jury had heard all the evidence and addresses uninterrupted over a period of just two days before the summing up commenced. It is a good example of both the need for a trial judge to tailor the summing up to the realities of the trial and the need for a review by the legislature of the obligations of a trial judge in summing up a sexual assault case.
The NSWLRC has a significant amount of work to undertake in responding to its current reference. Apart from the engagement of the Plain English Foundation previously mentioned, it has also commissioned a survey of jurors which is being carried out with the assistance of the Bureau of Crime Statistics and Research (BOCSAR), whose purpose is to explore the extent to which the summing-up, in a selection of trials, was regarded by the jury as helpful or, alternatively, occasioned difficulty in its comprehension. Hopefully, it might throw some more light on the factors which led to the disturbing findings of a survey conducted by BOCSAR in which jurors in 25 sexual assault trials were asked post-verdict what the verdict had been. In only six trials did all the jurors give the correct answer.
Of some concern is the fact that several studies have revealed that, although jurors report that they had no difficulty in comprehending the directions given to them, further investigation in relation to specific directions has revealed serious misunderstandings. This is not a state of affairs that can be tolerated if jury trial is to continue to be the norm.
1. Alford v Magee (1952) 85 CLR 437 at 466.
2. The problems which juries have in understanding and applying highly technical instructions were recently examined by Professors Ogloff and Rose in their article 'The Comprehension of Judicial Instructions', in K D Williams and N Brewer (ed), Psychology and Law: An Empirical Perspective (Guildford Press, 2005).
3. For example, Lord Phillips of Worth Matravers, 'Constitutional Reform: one year on', the Judicial Studies Board Annual Lecture, Inner Temple (22 March 2007); Lord Phillips, 'Trusting the Jury', the Criminal Bar Association Kalisher Lecture (23 October 2007); Justice Eames, 'Tackling the complexity of criminal trial directions: what role for appellate courts?'(2007) 29 Australian Bar Review 161; Lord Justice Auld, Review of the Criminal Courts of England and Wales, Report (2001); and see Zoneff v The Queen (2000) 200 CLR 234, - where Kirby J noted some of the research which indicated that jurors were having difficulties in understanding and applying instructions.
4. Justice M Kirby, 'Why has the High Court become more involved in criminal appeals?'(2002) 23 Australian Bar Review 4.
5. Weiss v The Queen (2005) 224 CLR 300.
6. Weiss, -; and see Darkan v The Queen (2006) 227 CLR 373.
7. The undesirability of trial judges simply reading the relevant section of an Act or of giving the jury a copy of it was noted in Safwan v The Queen (1986) 8 NSWLR 97 and, more recently, in Pengilley v The Queen  NSWCCA 163, .
8. For a review of the extent to which the current practices may not be employing the most relevant and helpful methods of communication with jurors, see J Horan, 'Communicating With Jurors in the Twenty-first Century'(2007) 29 Australian Bar Review 75.
9. Barca v The Queen (1975) 133 CLR 82; R v Bikic  NSWCCA 227.
10. A concept which Hunt AJA observed in R v El-Hassan  NSWCCA 148,  is expressed in 'decidedly non-jury friendly language'.
11. R v Jones (2006) 161 A Crim R 511.
12. See R v Chai (2002) 76 ALJR 628; Williams v The Queen (1990) 50 A Crim R 213, 226-227; and R v Meher  NSWCCA 355.
13. Domican v The Queen (1992) 173 CLR 555; R v Smith  1 NSWLR 462; and R v Riscuta  NSWCCA 6.
14. Longman v The Queen (1989) 168 CLR 79; Crampton v The Queen (2000) 206 CLR 161; Doggett v The Queen (2001) 208 CLR 343; Crofts v The Queen (1996) 186 CLR 427; R v Murray (1987) 11 NSWLR 12; and Tully v The Queen (2006) 81 ALJR 391.
15. Pollitt v The Queen (1992) 174 CLR 558.
16. Davies v Director of Public Prosecutions  AC 378; Jenkins v The Queen (2004) 79 ALJR 252; and R v Kanaan (2005) 64 NSWLR 527.
17. R v Stewart (2001) 52 NSWLR 301.
18. Azzopardi v R (2001) 205 CLR 50; R v Wilson (2005) 62 NSWLR 346; and Mule v R (2005) 79 ALJR 1573 for those cases where the accused has participated in an ERISP pre-trial, but has not given evidence at the trial.
19. Evidence Act 1995 s 116 and s 165; and R v Clarke (1997) 97 A Crim R 414.
20. Criminal Procedure Act 1986 (NSW) s 306X.
21. Criminal Procedure Act 1986 (NSW) s 306ZI.
22. R v Stewart (2001) 52 NSWLR 301, .
23. Bromley v The Queen (1986) 161 CLR 315; and R v Stewart (2001) 52 NSWLR 301, - and -.
24. See Relc v The Queen (2006) 167 A Crim R 484, .
25. R v Stewart (2001) 52 NSWLR 301, -.
26. For example, Evidence Act 1995 s 165B; Criminal Procedure Act 1986 (NSW) s 294 and s 294AA, although Tully v The Queen (2006) 81 ALJR 391 makes it clear that the common law will continue to require a warning where there would otherwise be a perceptible risk of a miscarriage of justice.
27. For a recent analysis of the circumstances which will require a warning in relation to the evidence in this type of case, see Wade v The Queen (2006) 164 A Crim R 583; and KJR v The Queen  NSWCCA 165.
28. Edwards v The Queen (1993) 178 CLR 193; Zoneff v The Queen (2000) 200 CLR 234; and Dhanhoa v The Queen (2003) 217 CLR 1.
29. CSR Ltd v Maddalena (2006) 80 ALJR 458; and Kamm v The Queen  NSWCCA 201, .
30. Fox v Percy (2003) 214 CLR 118, .
31. R v Zorad (1990) 19 NSWLR 91; and Green v The Queen (1971) 126 CLR 28, 34.
32. See B v R (1992) 175 CLR 599; R v Meher  NSWCCA 355; and R v Marr (1989) 90 CrAppR 154.
33. See the observation of Handley JA in R v Heron  NSWCCA 312, -.
34.  NSWCCA 119; and see also RPS v The Queen (2000) 199 CLR 620, 637 and Azzopardi v R (2001) 205 CLR 50, 70.
35. For an example where error arose in this respect, see R v Rajakaruna(No 2) (2006) 15 VR 592.
36. Whether the decision in Yager v The Queen (1977) 139 CLR 28, which accepted the regularity of a directed verdict to convict, would withstand scrutiny today is questionable: see P Gillies and A Dahdal, 'Directions to Convict'(2007) 31(5) Criminal Law Journal 295.
37. Lord Phillips, 'Trusting the Jury', 14; and 'Constitutional Reform: one year on', 13; G Taylor, 'Judicial Reflections on the Defence Case in the Summing Up'(2005) 26 Australian Bar Review 70, 83-87; and D Wolchover, 'Should Judges Sum Up on the Facts?'(1989) Criminal Law Review 781, 787-788.
38. For example, Dawson v The Queen (1961) 106 CLR 1; Green v The Queen (1971) 126 CLR 28; Van Leeuwen v The Queen (1981) 55 ALJR 726; R v Reeves (1992) 29 NSWLR 109; and R v Southammavong  NSWCCA 312.
39. See Norris v R  NSWCCA 235 for a recent example of a case where the jury requested clarification of the legal definition of reasonable doubt, asking whether it means 'we need to be one-hundred per cent sure either way'. In R v McNamara  QCA 405, Thomas J noted at  that the fact that the jury has asked for an explanation does not mean that a judge must answer it by stepping beyond the accepted limits. See W v R (2006) 16 TasR 1 for a detailed analysis of several different approaches which have been taken in an attempt to provide a more meaningful explanation of what is involved in proof beyond reasonable doubt.
41. R v Wanhalla  2 NZLR 573.
42. R v Wanhalla  2 NZLR 573, .
43. R v Bentley  1 CrAppR 307.
44. R v Lifchus  3 SCR 320.
45. M Zander, 'The Criminal Standard of Proof 'How Sure is Sure?'(2000) 150 New Law Journal 1517; J W Montgomery, 'The Criminal Standard of Proof'(1998) 148 New Law Journal 582. But see C N Heffer, 'The Language of Conviction and the Convictions of Certainty: Is 'Sure'an Impossible Standard of Proof?'(2007) 5(1) International Commentary on Evidence (Article 5).
46. (1971) 124 CLR 107 as considered more recently in Gillard v The Queen (2003) 219 CLR 1; Gilbert v The Queen (2000) 201 CLR 414; and Fingleton v The Queen (2005) 227 CLR 166. See also the recent decision of the House of Lords in R v Coutts (2006) 1 WLR 2154; but compare the approach taken in Scotland since R v Johnston (1998) SLT 788. See also R v Saad (2005) 156 A Crim R 533.
47. In R v Kanaan (2005) 64 NSWLR 527, the NSW Court of Criminal Appeal summarised the requirements of the law in this regard. See also Fingleton v The Queen.
48. R v Brown (1987) 32 A Crim R 162, 175.
49. The relevance of which, for example, in relation to warnings concerning identification evidence and lies was noted in Dhanhoa v R (2003) 217 CLR 1.
50. R v Zorad (1990) 19 NSWLR 91, 105; and Piazza v The Queen (1997) 94 A Crim R 459.
51. See the encouragement given to trial judges to follow this approach, for example, in Alvarez-Pizalla v State of Western Australia  WASCA 224; and Norris v R  NSWCCA 235.
52. Criminal Procedure Act 1986 (NSW) s 161.
53. For examples of its use, see R v Williams (1999) 104 A Crim R 260; and R v Davis  NSWCCA 15.
54. R v Meher  NSWCCA 355.
55. R v Zorad (1990) 19 NSWLR 91, 105.
56. R v Smart  NSWR 706, 713; and see Thorne v The Queen  NSWCCA 10.
57. Domican v The Queen (1992) 173 CLR 555; and see R v Davis  NSWCCA 15, .
58. Lord Phillips, 'Trusting the Jury', 15.
59. Its use was discussed by Professor E Griew in an article 'Summing Up the Law'(1989) Criminal Law Review 768 that was cited by Auld LJ in his Review of the Criminal Law.
60. See also an article by J R Spencer 'Does Our Present Criminal Appeal System Make Sense?'(2006) Criminal Law Review 677.
61. Jury Act 1977 (NSW) s 55B.
62. (2006) 94 SASR 177.
63. R v Coleman (1990) 19 NSWLR 467, 472.
64. Crimes Amendment Act 2007 (NSW) Sch 1.
65. See Pengilley v The Queen  NSWCCA 163; Banditt v The Queen (2005) 224 CLR 262; R v BBD  1 Qd R 478; and an article by Adam Webster 'Recklessness: Awareness, Indifference or Belief'(2007) 31 Criminal Law Journal 272.
66. McAuliffe v The Queen (1995) 183 CLR 108; Gillard v The Queen (2003) 219 CLR 1; Clayton v R (2006) 81 ALJR 439; R v Taufahema (2007) 228 CLR 232; and see also R v Powell  1 AC 1 for an analysis of some of the problems involved.
67. Complicity in Criminal Cases, July 2007.
68. Law Commission (England and Wales), Inchoate Liability for Assisting and Encouraging Crime, Report 300 (2006).
69. Criminal Code Act 1995 (Cth).
70. Gardiner v The Queen (2006) 162 A Crim R 233.
71. Pfennig v The Queen (1995) 182 CLR 461; and Phillips v The Queen (2006) 225 CLR 303.
72. KRM v R (2001) 206 CLR 221. See the editorial by Stephen Odgers QC, 'Relationship Evidence'(2007) 31 Criminal Law Journal 269 for a discussion of this vexed topic; see also Leonard v The Queen (2006) 67 NSWLR 545; and Qualtieri v The Queen  NSWCCA 95.
73. R v Ball  AC 47; and R v Beserick (1993) 30 NSWLR 510.
74. BRS v The Queen (1997) 191 CLR 275.
75. (2006) 81 ALJR 391.
76. SB v The Queen  HCA Trans 253; and HML v The Queen  HCA Trans 253, in which special leave was given by the High Court on 12 June 2007. See also Leonard v The Queen (2007) 67 NSWLR 545; and Qualtieri v The Queen  NSWCCA 95.
77. See R v Markuleski (2001) 52 NSWLR 82; and KRM v R (2001) 206 CLR 221.
78. The law in this regard will be significantly altered when the Crimes Amendment (Consent - Sexual Assault Offences) Act 2007 commences and substitutes a s 61HA for the existing consent provisions.
79. Shepherd v The Queen (1990) 170 CLR 573.
80. (2007) 170 A Crim R 533.
81. See Taikato v The Queen (1996) 186 CLR 454; and Fingleton v The Queen (2005) 227 CLR 166, -.
82. United States v Cohen 145 F 2d 82, 93 (2 nd Cir, 1944).
83. England and Wales, Criminal Law Revision Committee, Evidence (General), Report 11, Cmnd 4991 (1972).
84. R v Adomako  1 AC 171, 189.
85. Gleeson CJ, 'The Role of a Judge in a Criminal Trial', Law Asia Conference, Hong Kong (6 June 2007).


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Principal set for Harvard study tour
Sat, 17 December 2016 11:57AM
Margaret River Primary School principal Aaron Thomas will go back to school in May, joining a group of 20 principals on a two-week study trip to Harvard University in the US.
Mr Thomas and other independent public school principals from around WA will visit Harvard's Graduate School of Education for talks with experts on organisation design and education reform.
Mr Thomas said he looked forward to visiting the US and hearing "exciting ideas from people around the world".
"I can't wait," he said.
The principal said he and his peers would get to discuss ideas with experts face-to-face rather than sit in lectures.
Education Minister Peter Collier said the principals would complete an online course after attending Harvard and carry out short-term projects to reform parts of their schools.
"They, along with 20 principals currently in the program, will form a pool of highly skilled leaders who can be called on by the Department of Education for a range of roles, including acting as mentors to other principals and contributing to school leadership development programs," he said.
Mr Collier said each principal who completed the program would become an Independent Public School fellow.

redpajama_set_name: RedPajamaCommonCrawl


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Mildred Louise Smallin Livingston
Aug 23, 2008 at 12:01 AM May 12, 2011 at 6:12 PM
Dec. 11, 1918 - Aug. 20, 2008
Mildred Louise Smallin Livingston, age 89, of San Andreas, passed away peacefully on August 20, 2008. She was born on December 11, 1918, in Kansas City, Missouri to Jason and Bertha (Glazer) Jordan. Mildred married Millard A. Smallin, Sr. in 1936, and together they moved to California in the early 1940's. Mildred spent the next forty years of her life in Lodi, where she was a devoted member of Lodi Four Square Gospel Church. Millard passed away in 1984. Several years later, she met and married Raymond Livingston, and the two made their home in San Andreas in 1992. Mildred was a member the Disabled American Veterans Auxiliary and a citizen of the Cherokee Nation. Her greatest joy in life was her family, and she was very involved in the lives of her beloved children, grandchildren, and great-grandchildren. She will be dearly missed.
Mildred is survived by her daughter, Darlene (Chuck) Peterson of Sacramento; daughter-in-law, Betty Smallin; six grandchildren and six great-grandchildren. She was preceded in death by her first husband, Millard Smallin, Sr.; second husband, Raymond Livingston; son Millard Smallin, Jr. and brothers: Edward and Raleigh Jordan.
Friends are invited to visit on Monday, August 25, from Noon until 8 p.m. at Lodi Funeral Home. A chapel service will be held on Tuesday, August 26, at 11 a.m. at the funeral home with committal to follow at Cherokee Memorial Park. A virtual register may be signed at www.lodifuneralhome.com where memories can be shared. Lodi Funeral Home is assisting with the arrangements.
© Copyright 2006-2019 GateHouse Media, LLC. All rights reserved • GateHouse A News21


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You are here: Home / Education / NATO Grant Fuels Florida Poly Research Aimed at Better Radiation Detection at Nuclear Sites
NATO Grant Fuels Florida Poly Research Aimed at Better Radiation Detection at Nuclear Sites
A group of Florida Polytechnic University students and faculty are working on research funded by a North Atlantic Treaty Organization (NATO) grant aimed at streamlining the manufacturing and efficiency of handheld radiation detectors, which could be used at nuclear sites as well as for border patrol.
Through a grant from NATO, a team of Florida Polytechnic University student researchers led by Robert Austin (left), instructor of physics, has been utilizing a unique 3D printer to develop high-strength shells designed to increase the portability and efficiency of radiation detectors.
"Radiation detection plays an invaluable role in confirming that nations around the world are complying with international nuclear agreements," said Robert Austin, an instructor of physics at Florida Poly who was awarded the grant.
Through the grant, funded by NATO Science for Peace and Security Programme, the team of researchers was able to purchase a special 3D printer that uniquely allows the printing of plastic reinforced with continuous carbon fiber. These carbon fiber shells will be used with other components of the detector being developed, under the same grant, at the Kharkov Institute of Physics and Technology in Ukraine.
"The strength of carbon fiber and its transparency to high-energy electromagnetic radiation should allow us to make significant improvements in ionization detector efficiency and portability, which will improve international organizations' ability to regulate the development of nuclear power and weaponry," said Austin, who is overseeing the first of two years of research associated with the project.
Thomas Larson, who graduated from Florida Poly in the fall with a degree in in mechanical engineering, and Marshall Smith, a senior from Crestview, Florida, majoring in mechanical engineering, are collaborating with Austin to develop the thin shells which would be strong enough to withstand the high pressure of the radiation detectors.
Larson said the specialized 3D printer is critical to the project.
"It actually makes the process feasible with a continuous strand," said Larson, from Valrico, Florida. "Without a continuous strand, we wouldn't really attempt it. We could attempt the carbon-fiber filled with other printers, but it's the continuous strand that hopefully makes it stronger than we planned."
Austin, who has an extensive background in detector physics, said having the mechanical engineering students coming up with solutions has been very helpful.
"They're very much self-directed. I can set them off on their own, and they come up with their own solutions and approaches," Austin said. "We have student researchers working with a great deal of independence on a project that enhances the security of our country and other countries."
Preliminary tests of model calculations have been performed using thin shells of nylon (translucent shells) and onyx (black shells), which is nylon loaded with chopped carbon fiber. The photo also shows aluminum vessels that were pressure tested with and without the reinforcing shells. In the back is a PVC pressure vessel that ruptured under testing.
Filed Under: Education Tagged With: Florida Polytechnic University, NATO


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Home Politics PeP Sean Tembo To Donate Casio Calculator To President Hakainde Hichilema
UPND
Sean Tembo To Donate Casio Calculator To President Hakainde Hichilema
PRESS STATEMENT ON PLANNED DONATION OF A CASIO CALCULATOR TO PRESIDENT HAKAINDE HICHILEMA
By Sean Tembo – PeP President
Tomorrow, 2nd November 2022 at 11hrs, in my capacity as Party President for the Patriots for Economic Progress (PeP), l shall be making a donation of a brand new CASIO calculator to President Hakainde Hichilema at State House.
This donation is intended to help the President to make correct and accurate calculations so that he can reduce fuel prices, as he promised while in opposition.
Based on President Hichilema's failure to reduce fuel prices to below K16 per liter, where he found it upon ascending to office, it is evident that the calculator he is using might be faulty.
Therefore, our donation of a brand new calculator is in line with the mandate of the opposition to assist the Government of the day in running the affairs of the nation.
It is hoped that with a brand new calculator in hand, President Hakainde Hichilema will finally succeed to reduce fuel prices going forward. All media houses are invited to witness this donation.
SET 01.11.2022
Billy Oneya November 1, 2022 At 1:21 pm
Madness!!!!
Child of the Sky November 1, 2022 At 1:22 pm
Selective memory? Or just being dump? Fuel was at over ZMW23 in August 2021. And the world was stable then. Find something worthwhile to do. You will never be a politician.
kanwakahosha November 1, 2022 At 1:30 pm
LET SEAN TEMBO WAIT UNTIL THE WAR IN EUROPE IS OVER. PRESIDENT HICHILEMA DID NOT TELL SEAN TEMBO THAT HE WOULD REDUCE THE PRICE OF FUEL EVEN IF THERE WAS WAR BEING FOUGHT. THE DYNAMICS HAVE CHANGED AND SEAN TEMBO MUST NOT BE A ROBOT WHICH IS PROGRAMMED FOR THE RED LIGHT OR YELLOW. BE REALISTIC.
kubweka November 1, 2022 At 1:59 pm
Sarcastic useless dope. If prices if fuel are going up all over the world what more finished impoverished Zambia that he helped to bring down. Respect for the president please.
Sarah November 1, 2022 At 2:14 pm
Just ignore this fool. HH has never once responded to any of these idiots. That's why they keep barking like escapees for Chainama.
Simpo Sitali November 1, 2022 At 3:36 pm
"….Escapees from Chainama….", you have made my day Nkashi yandi Sarah. kikikiki!! And I add: "….freely on the loose, rabidly foaming on the edges of their mouths…."!!! and in one of our Zambian Languages they are called "iZisondosi"
Good addition and accurate description Simpo! 🙂
Bongobongo Brain November 1, 2022 At 4:02 pm
When I heard about a son of a witch, I didn't know there was one within Lusaka, until I saw this article, then I concluded by adding another title of son of a bitch. Stupid idiot.
jj November 1, 2022 At 4:18 pm
kkkkkkkkkk……….Bongobongo Brain you should have written stupid Idiot in big Capital letters
Collins Teembo November 1, 2022 At 4:31 pm
You must be serious with politics, Sean.
Otherwise, people will certainly see how you copied the internet on some report in the neighboring country.
Or you could be suffering from Political political meningitis/Youth Alcohol Abuse Report
Anaulula mwine, sichoncho, he confessed that from the time he miraculously survived the brutal lynching from the PF "No nonsense" Gestapos, he has never been the same, tiye timukululukile, mwebekala chalo!
lawyer paul November 1, 2022 At 9:26 pm
ubu ebushilu


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Mercy Street Season 2, Episode 4 GIF Recap
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Chaplain Hopkins and Emma Green in Episode 204
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Catch up on Episode 4, Southern Mercy, with an episode recap. Warning: Spoilers ahead.
The war carries on. Now down their head nurse, the Mansion House staff continue to confront both professional and personal battles within the hospital. A budding romance (or two!) and an intense scene on the battlefield only highlight a small but exciting portion of this week's action-packed episode. Get ready for Southern Mercy.
1. Dr. Hale Has No Chill
As his medical exam draws near, Dr. Hale begins to feel the heat from Major McBurney and worries that he might lose his job. Looking for someone to console him, he turns to his dear Nurse Hastings (because it's not like she's extremely busy taking care of patients or anything). However, she too has experienced a career change of her own, now that an ailing Nurse Phinney is in Boston, and she has the opportunity to move up as head nurse. Delivering a reality check with a side of burn, she reminds him that he's not the only one under pressure.
2. Who is Private Aimes?
In another wing of the hospital, two Union soldiers arrive seeking help from Dr. Foster. The curiously young looking one of the pair, Private Aimes, demands that Jed treat his ill comrade, Danny, despite the already-long list of soldiers who need tending to. With a healthy amount of bickering and guilt-tripping, the soldier eventually gets his way.
3. Peachgate
Meanwhile, Anne is left to deal with a McBurney crisis of utmost importance: peach tarts. Never mind that Hale might fail his exam and get kicked out of the hospital, there are baked goods at stake here. In a bit of a mood, McBurney takes issue with two tarts he has received from the kitchen that don't have equal numbers of peach slices in them — because if anything needs saving around here, it's definitely peach tarts. However, as he notes to Anne, "Today, peaches; tomorrow, vital, life-saving medical supplies," so maybe he's onto something.
4. Miss C
Though she's still caring for her smallpox patients, Charlotte Jenkins has finally started her school for contrabands and begun helping them transition into their new lives as free citizens. Although Samuel Diggs was born free, Charlotte presents him as role model for her pupils, praising his efforts to become a doctor.
5. "I Prefer Dr. Foster"
In the midst of amputations and heartbreak, Jed carves out just enough time from his busy schedule to check in with his old flame, Lisette. There are references to a coat that Jed left in Lisette's possession long ago, and how Jed has "moved on" to a new coat. With the numerous jabs back and forth, clearly these two have a romantic past. Like anyone who has the joy of running into an ex, their conversation is interesting to say the least.
6. Jimmy's Illegal Business
With a new sense of power in the family, Jimmy, like Alice, begins his own covert work for the Confederacy. He discusses the possibility of using his family's furniture warehouse to conceal an arms smuggling operation with his old friends, Banfield and Larkin, the same ones who beat him up for signing the Oath. Nothing could possibly go wrong, right?
7. Parlor Tricks
Tired of falling asleep with his nose in a book, Hale continues his medical studies by practicing procedures on hospital cadavers with Samuel as his tutor. Though his skills as a surgeon seem indisputable, he has trouble with the medical jargon he's required to know for his test. Sam commends him, admitting that he's learned much of his own knowledge by watching Dr. Hale operate on patients, but Hale explains that what Sam sees are simply "parlor tricks." He says he merely memorizes what he has seen other doctors do.
8. Declan the Shirker
At the open of this week's episode, Matron Brannan is pleasantly surprised by a visit from her beloved son Declan. However, it's soon clear that he isn't just swinging by for some of his mom's home-cooked meals. Instead, Declan has come looking for her in hopes of obtaining a medical deferment from his current regiment to another to avoid ending up on the front lines where he will surely be killed. Hoping to appease him, Matron tells Declan that she will speak with the head nurse about it but ultimately does not, for fear of exposing her son's cowardice (an offense punishable by death) and bringing shame to her family.
9. Emma Takes a Stand (Literally)
Involved in hospital life more than ever, Emma not only insists on accompanying Chaplain Hopkins to the battlefield where Aimes says the Confederate army has overrun his regiment, but also secures the money they need to get a wagon to do so. Emma and Chaplain load a handful of soldiers into their wagon but realize they've missed one who is trapped with a wounded leg in enemy territory. Chaplain, being the good Samaritan that he is, runs out to try to save the injured man but is held up by gunfire. Knowing that the two won't make it back to Union lines without cover, Emma bravely climbs atop the barricade and stands her ground to stop the shooting. After all, it would simply be impolite to fire at a lady.
10. The Truth About Private Aimes
During a private conversation with Lisette, Jed makes a remark about Aimes and Danny being "deviants," which results in a progressive response from Lisette that their homosexual relationship isn't a crime. Yet when another soldier later witnesses Aimes kissing Danny (only a minute after he falls asleep, by the way, which isn't risky at all), Jed believes his suspicions have been confirmed. Lisette, who, by the nature of her profession, is far more observant, informs a clueless Jed that — plot twist! — Aimes is actually a woman.
11. A Fight Breaks Out
After Chaplain and Emma's rescue mission (quite the first date!), the two share a moonlight kiss on their way home. Unfortunately, the romantic moment doesn't last long, because a Confederate soldier bursts through the trees and begins shooting at them. A switch flips, and Chaplain goes into beast mode, joining his opponent in the water to engage in some in hand-to-hand combat. Perhaps overtaken by the moment, Chaplain goes a little too far with his defenses and, to his own horror, ends up drowning the soldier. What a mood killer.
12. Alice's List
Despite everything she's put her family through, Alice continues to dig herself into holes deeper than the one Captain Van Der Berg is in (too soon?). While accompanying her father to the capital, she slips away to pick up a secret message from one of the Knights of the Golden Circle (sneaky, sneaky). When questioned by a Union checkpoint guard on their way back home, Alice turns her charm on and prevents the search of her handbag by coyly referring to a woman's biology and "personal effects of a hygienic nature" that she wouldn't want him to see. No fool, James Green later demands to see inside Alice's bag and discovers a confidential hit list. Alice tries to defend herself explaining that she is doing her duty to help the South until her father fires back with the news that Jimmy's name is on the list. Ruh roh.
13. Danny
Once Lisette and Jed confirm the truth about Aimes' identity, Lisette encourages her to disclose who she really is and how she really feels (hopelessly in love) to Danny, urging that he will accept her. Magically transformed with a dress and a little hair-combing, Aimes cautiously approaches a now-conscious Danny, who greets her with, "I know you ain't a nurse. They don't make 'em that pretty." Seeing a glimmer of hope, Aimes hands him a portrait that Lisette has sketched of the two soldier BFFs. She goes on to tell him that she is "Aimes," and the two share an awkward Shang-meets-Mulan sort of moment. Feeling betrayed, Danny dramatically tears the drawing in half, solidifying the heartbreaking rejection. Thanks a lot, Lisette.
Season 2 airs January 22 - March 5, 2017 8/7c on PBS. #MercyStreetPBS
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When the numbers began coming in, it was recognized by the Social Security Administration that when the baby boom generation began to retire, they were going to have less people paying in than was retired and taking money out. Nothing suitable was available in Washington in 1936, so the Social Security Board selected the Candler Building on Baltimore's harbor as a temporary location. In other words, working part-time for 10 years could ensure that you'll be receiving Social Security benefits when you retire. I have to make these X number of appointments, so I need to call X number of people.
This entry was posted in social security administration and tagged perspectives, security, social. Bookmark the permalink.


Named after Dr. Edward Bach (1886-1936) who was not only a medical doctor, but also studied extensively as a bacteriologist and homeopath. Everything in the world is connected at a vibrational level, as modern physics and relativity theory has proven.
These gentle remedies are one of the safest, natural and effective holistic tools we use for all ages. Each different type of flower has a slightly different energy and carries slightly different information in to our system. All of these are capable of supporting balancing at an emotional level. Many folks are familiar with Rescue Remedy- a crisis blend formula available at your local health food store.
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Amiens SC rounded off their home campaign with a 2-0 win over relegated FC Metz on Saturday that gives them hope of finishing in the top half of the Ligue 1 Conforama table.
Amiens, promoted last season for their very first top-flight campaign, had already assured their Ligue 1 Conforama status for next term, and were determined to give the Stade de la Licorne crowd something to cheer.
Metz had not kept a clean sheet in their last 15 league matches, and Amiens quickly ensured that sorry run would be extended. Moussa Konaté went down in the penalty box as he sought to get on the end of a Harrison Manzala cross — the would-be provider stepped up to fire past Thomas Didillon from the spot (21').
The experienced Renaud Cohade was fortunate not to see red in the first half, and was soon substituted as the visitors, already relegated before kick-off, looked as if they might lost their heads as well as the game.
The half-time interval steadied them, however, and Florent Mollet even brought a fine save from Régis Gurtner, who flew full-length to keep out the Metz man's free-kick (63').
Bakaye Dibassy's backheel allowed Konaté to volley just wide (64') before Vahid Selimovic's own-goal wrapped up the hosts' win — their second in a four-game unbeaten run — as the Metz centre-back deflected Gaël Kakuta's shot into the net (86').
The Senegal international has really taken to life in Ligue 1 Conforama this season, and though he didn't find the net to add to his 12 top-flight strikes, he was a constant menace.
Amiens are the first team enjoying their maiden top-flight season to have secured their survival since Evian-Thonon-Gaillard in 2011/12.


The surprising photograph below, is part of 2019 Chevrolet Chevelle Ss write-up which is listed within Review, car price 2019, 2019 Chevrolet Chevelle Ss, car concept 2019 and posted at August 21st, 2018 19:05:14 PM by admin.
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We've all been there, Spidey. Metaphorically speaking, of course.
A week after receiving my query letter, an agent responded, asking for a one-page synopsis. Fortunately, I had one ready to go and sent it, trying hard to not get my hopes up.
Not sure I would necessarily agree with most of that, but then again, I'm slightly biased.
Hard to say. Oh well. Nothing else I can do about it.
Probably like a lot of writers, there's always going to be that dreaded feeling of second-guessing myself. Did I do enough? Is this right?
I could (and do) ask myself these questions, but the more time I spend worrying about them, the less productive I am.
It all comes down to doing the best I can, putting it out there and seeing what happens. Hopefully, it'll yield positive results. If not, I've got no choice but to fix the problem where I can and see if that works.
They don't call it a never-ending process for nothing, you know.
I've been working at this for quite a while, getting a little closer to success each time. The goal is obtainable, and I can do this. This long, drawn-out part can be pretty frustrating, but I've made it this far. A little longer won't be that bad.
-Movie of the Moment: CABIN IN THE WOODS (2011) I don't really care for horror, but this was fun. If Joss Whedon is involved, you know it's going to be written smart. I'd heard there was a unique twist to it, and there was (no spoilers here).
What was most impressive was how they took a lot of horror movie tropes and made them integral parts of the plot, including the all-important setting up and paying off.
Good attitude. Just what a writer needs.
Congrats on getting a response to your queries! That's AWESOME! The key to being a great writer is learning from the valid criticism while ignoring the rest.


The first phase of research involves the characterization of calcium-dependent signal transduction in ovarian steroidogenic cells. Specific pharmacological drugs, such as calcium channel blockers, calcium ionophores and calmodulin inhibitors, will be used in in vitro static incubation of ovarian tissue to elucidate the role of specific components in calcium signaling pathways regulating ovarian steroid production. A primary cell culture system will be developed for Atlantic croaker ovarian steroidogenic cells to directly measure changes in intracellular calcium concentrations in response to hormone treatments. The second phase of research will investigate xenobiotic disruption of calcium-dependent signal transduction and subsequent alteration of ovarian steroidogenesis. Preliminary experiments will study effects of xenobiotic chemicals on normal endocrine function by screening a variety of compounds including heavy metals, pesticides, and polychlorinated biphenyls (PCBs). Compounds causing significant alteration in steroid production in the preliminary assays will be selected for continued experiments to elucidate whether the chemical is altering endocrine function by modifying calcium-dependent signal transduction. In vitro ovarian tissue incubations will be used to assess effects of contaminants on ovarian steroidogenesis, and ovarian steroidogenic cells in primary culture will be used to determine direct effects of xenobiotics on calcium homeostasis.


When we go shopping, some of us (including me) end losing our mind and shopping without any sense. To end with this, keep a notebook and save the photos of looks you like, or outfits you lust after and everything you are looking for.
If you want to look thinner, for example, asymmetric tunics and dresses would help you. Also if you have to choose between patterns, use vertical patterns. And remember that nobody looks good in shapeless clothes.
Instead of looking after your defects, focus on stand out your virtues. A good belt is always a great investment for thin girls, because this simple accessory can make or break the entire outfit. For example paired with an oversized-baggy tunic, cardigan or a simple dress, will stand out your curves and make you feel more feminine.
That happens to all of us frequently! Don't shop for single pieces because are cheap or cute. Maybe you'll never wear them. Instead of that, save you money and shop for complete outfits.
Or try to think of at least three different outfits you can wear it with.
Accessories help in experimenting with different looks. It breaks the monotony; you can either dress up or dress down with the use of the right accessories.
The simplest clothing pieces to coordinate are in solid, neutral colors. Build a base of core wardrobe will help you to multiply your outfit options.
A neutral base is necessary in every wardrobe, and then focus on invest it with your own shopping treasures.
Then next time you find a extraordinary item like a gorgeous colored biker jacket or a brocade skirt, you'll have the perfect backdrop waiting in your closet.
Anyone looking to shop like a stylist has to push out of your own comfort zone. Don't always go to the same stores; don't always try on the same style of clothes. Try new stores, styles, colors and trends.
7-Take your perfect shopping partner with you.
Maybe you love shopping but your best friends are indecisive, or maybe is the one who comes to the rescue! The most important thing is do it with a trustable partner, someone who gives you an honest opinion about what looks good on you and what doesn't that is the right shopping partner.
When you go shopping, you can't take it like a work to do. You have to take your time, check your favorite shops, meet some new, compare, meditate about it, but don't be in a rush and have fun.
And remember; find items that flatter your features, not what makes someone else look good!


text:
Water For People Canada
Everyone Forever
The Global Water Crisis
A Sanitation
Pablo Terceros Vargas is sparking a sanitation revolution in his rural community in Bolivia.
Pablo has lived in the district of Tiraque, Bolivia for his entire life. For the first 32 years of his life, he didn't have a bathroom.
According to Water For People's monitoring, almost half of the district's 33,470 residents do not have sanitation faciliaties at home– including most families in his town of K'aspi Cancha.
"Even at night, in the wind, or in the rain, we used to have to go outside," explains Pablo.
When K'aspi Cancha's new water system was being constructed by the district government and Water For People, Pablo attended a workshop about the importance of hygiene and sanitation.
"In the workshops, they told about waterborne illnesses and contamination of water supplies," says Pablo. "They told us, 'If you are going to have water, you should construct your bathrooms and have showers, toilets, and sinks."
Pablo left the workshops realizing he wanted to improve his family's life. He wanted his sons to have what he never had as a child – a decent bathroom. Pablo immediately got to work.
"I am not a mason, but I constructed the bathroom myself," says Pablo. "Now we can shower with hot water before bed and take care of our hygiene. Now, my house is complete, and it feels like we live in the city!"
Pablo said his sons couldn't believe it. He said they kept asking, "We're really going to have a bathroom, dad?!"
The new bathroom changed Pablo's life so dramatically that he took it upon himself to promote sanitation to the town's 54 families. There are currently seven additional families that are already building bathrooms, and Pablo's happy to help them out.
"There is an older gentleman who needed a bathroom, but he couldn't build it," shares Pablo. "He had pain in his knees, and a toilet would be much more comfortable than open defecation. I told him to buy the materials and I would help him build the bathroom after I am done planting my crops."
Pablo will go to any lengths to encourage his friends and neighbors to build bathrooms. He says his life has improved so much since building his family's, and he wants the same for everyone in K'aspi Cancha.
"Now, my life lacks nothing," says Pablo.
Posted in Bolivia, Sanitation
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I was born in Split and my involvment in soccer brought me to Melbourne in Australia, where I live today.
I am married and have two grown up children.
The past 16 years I am the owner of a small glazing company "Affix Glass".
I am the representative for Australia in executive commitee of Croatian World Congress and also Coordinator for the Croatian World Games for Australia.
I am one of the presenters/editors at the Croatian radio programme 3ZZZ in Melbourne and Assistant Coordinator.
A few years ago I held the postion as president of the Melbourne Croatia SC.


Anthony C. Constantinou is a prestigious figure in the University of London, where works as the Lecturer Assistant Professor of the University and the Head of Bayesian Artificial Intelligence research lab at Queen Mary's.
Anthony is an integral part of the community of the University of London and is a beloved professor by the students. At the research lab, Anthony has conducted a number of researches and improved on lectures and theories for the University.
Anthony continuously collaborates with other institutions in the UK and have lectured in many organizations. At the Queen Mary University of London, he also graduated and received his academic formation.
Anthony Constantinou, different from most scientists and researchers, apply his findings and experiences to real-life applications. He is continually teaching about data-mining in businesses, the applications of artificial intelligence and its future, as well as using mathematics, probabilities, and analytics to talk about sports, finances, investments, business administration, medicine, and even gaming. Get Additional Information Here.
Apart from his job as a University teacher, Anthony is a big enthusiast of the sports industry. He has collaborated with many companies and firms as a consultant in the rating systems, helping analyze risks and the betting industry surrounding the sports scene. In this role, he has partnered with Agenda Ltd, the JFE Steel Corporation in Japan and the Venture Sports and Events from Thailand.
Last but not least, Anthony Constantinou also utilizes his experience with the financial administration in his day-to-day life, as he is a property investor and landlord as well.
Visiting http://www.constantinou.info/, where the Professor is continually sharing news and updates to his research, you can already identify that Anthony is an experienced research in the fields of mathematics and machine learning.


Since she has started attending Collective she has most enjoyed the sense of community that Collective fosters, the intelligent conversations about faith, theology, and spirituality that happen here, and the amazing coffee available every week.
Elizabeth worked with Collective as a summer intern last year, and is excited to get involved with helping to organize and carry out events this summer again, as well as helping to create a permanent intern position for the fall. She has enjoyed chatting with the online community during services, and hopes to get more connected with them over the summer. She also looks forward to be able to attend upcoming Community Groups more frequently now that she has graduated. In her free time, Elizabeth enjoys reading, writing, playing videogames, taking walks, attending weekly movie nights with friends, and watching way too much Netflix at one time.
In the future, Elizabeth hopes to begin pursue a Master's Degree, most likely in Divinity, or in Library Science. She is excited to have the chance to take some time off from school and discover what her next steps will be.


NASA's Transiting Exoplanet Survey Satellite (TESS) has deployed successfully in space, at the start of a mission that will survey virtually the entire sky for exoplanets, before ground-based telescopes use spectroscopy to search for signs of extra-terrestrial life. Tess will spend about two years surveying 200,000 of the brightest stars near the Sun to search for planets outside our solar system.
Zurbuchen said: "We are thrilled Tess is on its way to help us discover worlds we have yet to imagine, worlds that could possibly be habitable, or harbour life". If such a dip is detected, scientists can then ascertain if the planet warrants further study by telescopes and other instruments that are able to measure the change in light in more precise detail.
"Following stage separation, SpaceX will attempt to land Falcon 9's first stage on the "Of Course I Still Love You" droneship, which will be stationed in the Atlantic Ocean", SpaceX says.
One of the main sources of data on planets outside the Solar system in recent years has become a space telescope "Kepler". The Falcon 9 placed TESS into a highly elliptical orbit, and the spacecraft will use its own propulsion to move into its final orbit, a stable high Earth orbit in a 2:1 resonance with the moon, by mid-June.
The Transiting Exoplanet Survey Satellite (TESS) launched yesterday at 6:51 p.m.
That mindset is a huge shift, and one TESS will continue. TESS principal investigator George Ricker, who is from the Massachusetts Institute of Technolgy said that "TESS is going to dramatically increase the number of planets that we have to study".
At 11.51pm United Kingdom time yesterday, Musk's SpaceX firm sent one of its Falcon 9 rockets into orbit carrying Nasa's new satellite-telescope, Reuters reports.
For its planned two-year mission, astronomers divided the sky into 26 sectors.
TESS will observe "transits", or the phenomena when a planet passes in front of its star, changing the star's brightness.
TESS will use the same transit method Kepler used to find planets.
"TESS will tell us where to look at and when to look", Mr Ricker said.
The total exoplanet census stands at more than 3,700 confirmed, with another 4,500 on the not-yet-verified list. Aside from its fuel, scientists said the moon's gravity will help it stay on orbit for the duration of its mission.
But the Tess strategy is different as it is a wide-field survey with its cameras scanning big strips of the sky over 27-day periods. Tess will be looking at stars that are between 30 and 300 light years away and up to 100 times brighter than what Kepler was staring at.
But now, many users are demanding that Facebook stop doing the thing that earns the company billions of dollars each year. According to Wozniak, such firms use the widescale data collection operations to ace ad targeting.
Netanyahu, who visited Hungary last summer, also thanked the Hungarian leader for his support of Israel in worldwide forums. The left opposition secured the majority of the capital Budapest , but Fidesz swiped the rest of the country.
The evacuation deal restores Assad's control over the entire eastern Ghouta - formerly the biggest rebel bastion near Damascus. Trump on Monday promised a decision on Syria within hours, although he did not say when a decision would be implemented.
The stock of The Walt Disney Company (NYSE:DIS) has "Sell" rating given on Wednesday, November 22 by BMO Capital Markets. NASDAQ: TSLA - Tesla (NASDAQ: TSLA ) has insider ownership of 23.10% and institutional ownership of 58.19%.
What makes this story take a freakish turn is that the driver of the vehicle shot and killed himself inside it. The Sueddeutsche Zeitung paper also says the suspect's apartment was being searched for possible explosives.


text:
Nick Seeler
#55 - Minnesota Wild
Position Defense
Birthdate June 3, 1993
Birthplace Eden Prairie, Minnesota
Draft N/A
Date vs Score G A P +/- PIM PP SH S HT BS SHF TOI
12/7/19 @ CAR L 2-6 0 0 0 -2 0 0 0 0 - 2 14 11:14
12/5/19 @ TB W 5-4 0 0 0 -1 2 0 0 2 3 1 11 6:25
11/9/19 @ ARI W 4-3 0 0 0 -1 0 0 0 0 1 - 2 1:15
11/2/19 STL L 3-4 (OT) 0 0 0 -1 0 0 0 1 - 3 16 14:28
10/17/19 @ MON L 0-4 0 0 0 -1 4 0 0 1 1 1 20 14:01
10/3/19 @ NAS L 2-5 0 0 0 0 2 0 0 0 - 2 17 14:31
4/6/19 @ DAL L 0-3 0 0 0 0 7 0 0 0 - 1 16 11:56
4/2/19 WIN W 5-1 0 0 0 1 0 0 0 1 1 3 21 14:33
3/31/19 @ ARI L 0-4 0 0 0 0 0 0 0 0 1 2 16 12:03
3/29/19 @ VEG W 3-2 0 1 1 1 0 0 0 0 4 1 16 12:44
Statistics | Career
Season Team GP G A Pts +/- PIM PPG SH Shots Sh%
19-20 MIN 6 0 0 0 -6 8 0 0 4 0
18-19 MIN 71 2 5 7 -4 64 0 0 67 2.99
17-18 MIN 22 0 4 4 10 21 0 0 17 0


April 22 – Pitch! A College A Capella Concert – Join some of the best New England college a capella groups for a concert of great songs. Relive your college days or introduce the kids to the fun of college a capella. Entertaining for the whole family!
Tickets to all shows can be purchased online at www.winnipesaukeeplayhouse.org or by calling the Box Office at 603-279-0333. Also, for additional information concerning content or age appropriateness, please call 603-279-0333.


Eighty percent of marketers are concerned that their marketing technology vendors are not fully GDPR complaint and may expose their company to legal risks, according to new research from Demandbase and Demand Metric.
In anticipation of the General Data Protection Regulation (GDPR), Synthio has added a GDPR compliance feature to its Data Health Analysis (DHA) offering. The GDPR compliance enhancement aims to provide insight into the potential compliance of a user's database.
BlueConic, a customer data platform for B2B businesses, has launched a new Consent Management solution, which aims to provide marketers with the tools they need to manage data consent and rights requests from consumers in a single, unified platform that adheres to the upcoming General Data Protection Regulation (GDPR).
Last month, Demandbase appointed Fatima Khan as its new Chief Privacy Offer. With her extensive privacy, data and technology law experience, Khan is responsible for maintaining and evolving the company's global privacy program and driving strategies to ensure compliance with global privacy and cybersecurity requirements, including the upcoming General Data Protection Regulation (GDPR).


text:
Would Theodore Roosevelt Still Love these Lands?
on July 21, 2016 August 15, 2016 inNational Parks
Of the many thinkers behind America's National Parks idea, Theodore Roosevelt looms as one of its leaders. Though the park service was established seven years after his presidency, he'd already worked to create 23 of the 35 designated sites at that time. He wielded his presidential power to set aside 230 million acres of public land, 150 acres of which became national forests. Within these lands he helped designate 51 bird preserves, four game preserves, five national parks, 18 national monuments, and 24 reclamation projects – all against the determined efforts of commercial incentives.
The park system we enjoy today would not exist without Roosevelt's conservation efforts, and few presidents have exhibited such wonder for our natural world since his administration from 1901-1909. Not only did he boldly use his pen while in office, he also used his voice to warn against our reckless use of resources. As quoted from In the Words of Theodore Roosevelt:
We are, as a whole, still in that low state of civilization where we do not understand that it is also vandalism wantonly to destroy or to permit the destruction of what is beautiful in nature, whether it be a cliff, a forest, or a species of mammal or bird. Here in the United States we turn our rivers and streams into sewers and dumping-grounds, we pollute the air, we destroy forests, and exterminate fishes, birds and mammals—not to speak of vulgarizing charming landscapes with hideous advertisements. But at last it looks as if our people were awakening.
Why did Roosevelt care?
Born to a wealthy family during the Industrial Revolution, Roosevelt grew up in a time when much of America's natural wealth was still being discovered and explored. Most Americans saw this country through a commercial rather than environmental lens. But Roosevelt was keenly interested in plants and animals from an early age, and even became an accomplished ornithologist. Many know of his wilderness excursion with John Muir in 1906, and while his association with the famous naturalist influenced his policies, Roosevelt's love for wildness began before the two even met.
A watchful gaze caught our eye along a highway in North Dakota.
The Greatest Romance of His Life
It seemed Roosevelt was destined for a storybook trajectory of university studies, politics, and family life. But a tragedy in his early 20's forever altered this course. In 1884, both his mother and beautiful young wife died within hours of each other, leaving him in a deep state of mourning that sent him far, far away from his socialite community.
Roosevelt escaped to the badlands of North Dakota where he lost himself in buffalo hunting and cattle ranching. While many of his cattle pursuits proved unsuccessful, he reflected that his time in these wild lands marked a moment when:
the romance of my life began.
We learned about his pursuits during our visit to Theodore Roosevelt National Park, which encompass 70,000 acres set aside in his honor. Here, in lands described as hell after the flames have gone out, a man recovered from heartbreak through his own back-breaking work. Roosevelt fell in love with a harsh landscape that can quickly kill a human yet simultaneously support hundreds of other species. Gazing out across a seemingly endless horizon of buttes and plateaus, it's easy to imagine what he saw in those days, virtually untouched since his time.
View from North Unit over Theodore Roosevelt National Park landscape.
The crazy thing is, much of the land around Roosevelt's beloved escape is not untouched. In fact, North Dakota experienced an oil boom in 2006 that has left behind both temporary economic gains and long-lasting environmental damages.
As we drove to a town near the park, I marveled at the contrasting landscape.
Supposedly the peak of this oil boom was last year, but the effects are still obvious. Billboards, oil rigs, construction projects, and shopping centers so new, they aren't even on Google Maps yet (which is why we got lost a few times). Not to mention the rows of cheap housing and RV parks set up to accommodate thousands of workers. A grocery store we visited had more trucks in its lot than I'd ever seen in a single location, and the shoppers were mostly young men who looked dirty from a long day of work.
We've driven a lot of miles in North Dakota, and everything I saw immediately outside the park continues to fill my vision as we travel across the Dakotas. I can't help but wonder:
*Now, I won't deny that we're driving a car dependent on oil. Or that virtually every product and service we use was crafted from some fossil fuel or another.*
But that doesn't mean I can't remark on civilization as a whole, to reflect on how we live through the eyes of a former president. Roosevelt criticized civilization over a hundred years ago, calling it "a low state" where we turn our lands into "dumping-grounds".
Scores of environmental advocates have risen up and continue to rise up since Roosevelt's time, but are people truly awakening?
The crowds we've encountered in these parks suggest something. Why are so many people escaping into nature? It's because the civilization we've built isn't sustaining us in a healthy way; it's not making us happy, or fulfilled. Turn on the news or log in to Facebook and you'll see the obvious signs.
I pose a possibly naive question: What can we do to become a strong state of civilization? To truly awaken, as Roosevelt believed we were.
A mighty bison treads slowly along a road in Theodore Roosevelt National Park.
The geologic formations in TRNP seem other-wordly.
Driving beneath a magical sky in a park where billboards aren't allowed.
I believe the day humanity has learned to live in sync with our natural world is the day we won't need parks anymore. We'll build better, travel better, eat better, grow better, and love better.
It may seem crazy to call for a day when we don't need parks, as someone who loves the parks and is currently visiting all 59 natural national parks. Maybe it's a radical statement, but my message is this:
we shouldn't live in a world where our natural world is separated from our every day world. It should be one.
For now, the parks give us space and inspiration to make conclusions and wish for something better. Perhaps Roosevelt knew this when he worked so hard to set aside protected lands. He realized people need to fall in love with land, just as he did, as a first step to protecting it. Of course, the issue is much more complicated than a simple blog post allows. So I'll stick to the original question.
I don't know the answer, whether or not T.R. would still love these lands. Probably not all of North Dakota, or the rest of the world for that matter, but he would at least love the parks.
So without a definite answer, and many more questions, I end my reflection by sharing a poem by Wendell Berry. I'm sure it will resonate with you as much as it did with me. It's called The Peace of Wild Things: http://www.poetryfoundation.org/poems-and-poets/poems/detail/42469
Tagged: Conservation , National Parks , North Dakota , Sustainability , Theodore Roosevelt , Theodore Roosevelt National Park Like this: Share this:
A Poster to Heal Mind, Body and Soul in Hot Springs
on May 4, 2016 June 25, 2016 inNational Parks
How Much to Visit all National Parks
on January 1, 2016 April 27, 2016 inNational Parks, Nomadic Lifestyle