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A. Negligence Approaches to Dog-Related Injuries
1. Contributory Negligence in Negligence Cases
B. Scienter Approaches to Dog-Related Injuries
1. Provocation in Scienter
A. Penalties under the Provincial/Territorial Dangerous Dog Statutes
B. Dangerous Dog Statutes: Absolute Liability as the �New� Strict Liability Approach
C. Federal Criminal Liability for Dog Attacks
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The partnership between dogs and people is undoubtedly ancient, having existed for anywhere between 10, 000 -100,000 years,[1] depending on the author and method of study. It is a relationship which has benefitted both parties. As a result, dogs successfully spread to nearly every culture on earth with early humans. People have in turn benefitted in many ways from this relationship with dogs, from herding food animals, to acting as guides, or as companions that improve their owners� health and longevity.[2]
In modern North America, most of the approximately 80 million dogs are companion animals. [3] Dogs first evolved from wolf-like ancestors, and through selective breeding,[4] they became genetically much tamer than wolves, retaining many puppy-stage characteristics. Yet dogs still possess some wolf-like characteristics, which can be valuable to people, when territorially protecting their family pack and den. Dogs usually see their �pack� as their human owners and their �territory� as their home and the area around it.[5]
Unfortunately, these same valuable wolf-like traits can lead to unwanted aggressive behaviour in dogs at times. Each year, 4.5 million dog-bites occur in the United States[6] (500,000 /year in Canada[7]), suggesting that 1 dog in 16, or roughly 6.2% of dogs, may bite humans. People may also suffer fall-related injuries, or even psychological harms, which may result in a fear of dogs strong enough to restrict certain employment. Dogs of all sizes and breeds may bite, although larger dogs may cause more harm. In 1999, direct medical care costs alone exceeded USD$235 million.[8] While only 3.5% of bites needed surgery,[9] roughly 1.6 fatal dog bites occur yearly, per population units of the same size, in both the United States and Canada.[10] In relative terms, serious dog-bites are rare and declining infrequency;[11] more people may be injured by bicycles.[12] Nonetheless, dog-bites are a concern, especially because children are the main victims.[13]
This article explores Canadian legal approaches to dog-related injuries, but will omit discussing �Breed-Specific Legislation,� which prohibits certain dog breeds, such as pit bull terriers. In Canada, two main legal approaches address to dog-bites or other dog-related injuries: the traditional (judge-made) common law and the more recent (government-enacted) statutes. Both approaches use the threat of victim compensation and possible prison sentences to encourage responsible dog control. In severe cases, criminal charges may be laid under a statute not specific to dog-related injuries-- the Criminal Code of Canada-- which employs the threat of imprisonment and public condemnation to encourage responsible dog ownership.[14]
The first part of this article discusses the traditional common law approaches of �scienter� and �negligence,� and their challenges for dog owners and victims. Next, Canada�s statutory liability approaches and their shortcomings are discussed with respect to the dangerous dog statutes of Canada�s provinces and territories and sections of the federal Criminal Code of Canada. Finally, the article concludes with an analysis of how the statutory schemes have successfully ameliorated much past unfairness in the compensation of dog-bite victims, thereby encouraging responsible owner behaviour. This change comes at a price, however. Some statutes may go too far, potentially causing unfairness even to responsible owners and their dogs, by misdirecting attention away from an owner�s conduct to that of the dog. Ultimately, a statutory or common law approach based on a negligence standard may be the fairest compromise that considers the interests of both responsible owners and innocent human victims.
Canada and the United States share many similarities in dog-bite patterns, but there are also some differences based on geographic and cultural distinctions. For instance, possibly because sled-dog packs are used frequently for transport in Canada�s less accessible and remote north, more fatal bites are reported from such rural areas, compared with the United States.[15] Canada also has a higher rate of dog-pack over single-dog fatal attacks on people.[16] It is not clear how often neglect or starvation are involved in attacks on humans. During the warmer months, some sled-dog teams may be turned out and left relatively unattended --other than periodic feeding-- in unpopulated wilderness areas, such as uninhabited islands.[17] There, dog teams may learn to hunt cooperatively like a wolf-pack, [18] for food or from boredom. These communal pack hunting experiences may pave the way to predatory behaviour towards humans, [19] if unwary people encounter the unattended pack while camping, fishing or picking berries. Wolf-dog hybrids with less tame and predictable temperaments may also be more common in remote areas due to interbreeding, accidental or otherwise.[20]
Furthermore, Canada�s land-mass is largely non-urbanized, with vast areas of undeveloped wilderness, �First Nations� (aboriginal) reserves, and rural farmland, surrounding the half-dozen major urban centres of the south. Researchers observe that, for unknown reasons, dog-bites are more frequent in areas of lower socio-economic status.[21] Ironically, there may be greater or more vocal public concern over dog-bites in more affluent, densely populated urban areas. Unfortunately, further study of both rural and urban Canadian dog-bite dynamics may be impeded by the fact that Canada --unlike its southern neighbour, the United States-- does not keep consistent, annual records of dog-related injuries. This presents an obstacle to better understanding the issue from a Canadian perspective.
The challenge in assessing Canada�s dog-bite problem is compounded by some variability in application of the law among the provinces and territories. As a result of Canada�s patchwork of differing statutes, in some regions dog-bite cases must be brought under the two common law categories of �negligence� and �scienter�, while others employ a combination of statutory and negligence law. The choice of approach is mainly dictated by whether a given province possesses a dog-bite statute or not. In regions with no statute, actions are typically brought under both scienter and negligence. In contrast, where a statute exists, this typically bars the option of bringing a common law action under scienter, but not negligence. This section will describe the application of scienter and negligence to dog-related injuries. These common law approaches, derived originally from English law, are equivalent to civil lawsuits in the United States.
Negligence means that an owner failed to reasonably consider those who might be at risk of injury from a potentially dangerous dog, by taking proper precautions to prevent injuries to those foreseeably at risk (e.g., by muzzling a dog or keeping it in a fenced yard). Foreseeability of potential harm to others by a dog was an issue in the case of Bates (next friend of) v Horkoff. There an owner admitted that his German Shepherd was stranger-aggressive and played roughly with his own children. He also knew that the fence separating the dog from the neighbouring daycare had large gaps that let the dog`s head and shoulders through, but he neither fixed the fence nor used the secure dog run on his property. When the dog bit a daycare child, the court found that it was foreseeable that the neighbouring daycare children might be put at risk by the dog, and that the dog`s owner had failed to take reasonable precautions to minimize risks to the local children. He was found liable[22] in negligence.
1. Contributory Liability in Negligence Cases
In some negligence cases, if a victim was partly to blame for his own injuries, courts have found victims �contributorily liable� (partly responsible) for their own care costs. This may because a bite victim was careless about his own safety, perhaps approaching a dog despite a �Beware of Guard Dog� sign or ignoring other notices of danger, or if the victim deliberately provoked the dog�s aggression. For instance, in Bacon (Litigation Guardian of) v. Ryan, a mother brought her child to visit a family with a Pit Bull that had recently bitten the owner`s son. She knew about the bite incident, but let her child play on the floor near the dog anyway. After her child was also bitten, the mother was held one-third contributorily liable. When a dog in another case, Whelen v. Barlow, bit a drunken man who was shouting at its owner�s wife, the man was found two-thirds contributorily liable for his own injuries. These examples illustrate that under the common law of negligence, a victim�s actions as well as the dog�s and owner�s acts are considered in the legal assignment of blame for dog-related injuries.
The other common law approach, scienter, is an ancient �strict liability� concept, in which an owner is said to keep a dangerous animal or thing (such as dynamite or a wild animal) �at one�s peril�. If a thing known by the owner to be dangerous is kept despite the danger and hurts someone, the owner must compensate the victim for any harm done. The owner cannot use the defence that he made all reasonable efforts (termed �due diligence�) to prevent the harm: he is strictly liable. No matter how careful he was, or what precautions he took, he is still be liable for a victim`s injuries if certain conditions (noted below) are met. The British Columbia court in Prasad v Wepruk discussed the application of scienter. There, an elderly newspaper deliverer was mauled by a guard-dog that was usually chained up at its owner`s scrap-yard, but which escaped into the street.[23] Local residents gave evidence of the chained dog`s aggression towards passersby. Seemingly, the owner knew his dog was aggressive and not only kept it anyway �at his peril� but kept it because it was vicious, to frighten away scrap-yard thieves. The fact that he kept the dog chained to protect innocent passersby was seemingly no defence. He was liable in scienter.[24]
Scienter has attracted the criticism that it makes it too difficult for victims to obtain compens-ation, even if they sustain severe, life-long injuries. Victims must prove that: a) the dog behaved viciously in the past and b) the owner knew of this. Both may be difficult to prove in court since a biting dog may have never bitten or acted �viciously� before,[25] and if it did, it may not have done so in its owner�s presence. In Janota-Bzowska v. Lewis, a guest fell and hurt her hand when her host`s tethered, usually placid Labrador lunged at her. Because the dog had never acted aggressively before, the Court of Appeal overturned the trial court�s finding and concluded that the owner was not liable in scienter.
For a scienter claim to succeed, a dog may not need to have shown a past propensity to do the specific thing complained of presently by a plaintiff, such as biting children or killing livestock. Instead it need only exhibit general aggressive or uncontrolled behaviour. Yet as to the type of aggression needed--viciousness or simply dangerousness of any kind�there remains confusion, which may leave some victims uncompensated. Shelvey v Bicknell involved an appeal where a large Rottweiler knocked a woman down by bumping her legs while it was playing, causing her to hit her head and lose conscious-ness. The dog was friendly, but big and clumsy; it had accidentally knocked down its owner and a child previously. On appeal, scienter was not argued, perhaps because the dog showed no �vicious� history. Yet in another scienter case,Fisher v Liptak, the court stressed that scienter is based on the idea that �anyone who maintains an animal that is known to be dangerous to humans... in any other way does so at his peril� (emphasis added). This suggests that the key trait is dangerousness of any kind, not viciousness. Thus in Shelvey, a scienter argument might have succeeded, if argued, due to the dog�s history of clumsily bumping into people and knocking them down.
In scienter, what counts as �proof the owner knew� of their dog�s dangerousness may confuse victim and owner alike, especially if the dog was gentle with its owners. For example, in Prasad, evidence of owner knowledge was inferred from the owner `s purpose in keeping the aggressive dog to deter intruders; the dog was seen to be affectionate and calm with its owner. Another case, Morsillo v Migliani, involved a German Shepherd biting a local boy; much of the evidence claimed to prove the owners� knowledge of its viciousness[26] revolved around their actions of responsibly keeping it in a secure yard and using a choke chain and leash when taking it outside.
In scienter, owners may completely escape liability if it is shown that a victim �provoked� the dog, thereby voluntarily assuming all risk. But what if the provocation is unclear? In some cases, the provocation is obvious and deliberate. For example, an attacking dog may have been tormented by a child victim throwing stones at it.[27] In other situations, provocation may not have been intended as such by the victim. For example, a stranger startling a sleeping dog by petting it or accidentally stepping on it, the smell of strange dogs on an examining animal control officer, an injured dog�s reaction to those trying to help it, a toddler�s inappropriate play, or perceived threats to an owner or puppies may all provoke a dog to bite. Curious young children, used to harmless cartoons, stuffed toys or petting-zoo babies, may unwittingly provoke or confuse a dog through inappropriate play, or by their small size, high-pitched voices and quick movements. An older case, Richard v. Hoban, sadly still relevant today, involved a young girl who was bitten when she innocently put her arm around the neck of a chained German Shepherd to play, evidently not having been taught appropriate behaviour with strange dogs.
Unfortunately for both dogs and owners, many scienter cases take a human --rather than dog�s eye --view of provocation.[28] The defendants in Morsillo unsuccessfully argued that the child victim provoked their dog by firing his clicking toy gun at it. Yet the fact the boy was knowingly playing on an allegedly vicious and supposedly �terrifying� dog�s front lawn, a few feet from where it was being walked was not argued as provocation. Dogs do not always share the human legal view of who is an intruder, what seems to be a threat or where their territory ends.[29] Animal experts can introduce a dog`s perspective to correct presumptions of viciousness, but this adds cost and delay to a trial, and so may be omitted. [30]
Overall, as in negligence, under the common law of scienter, the actions of the dog-bite victim are considered by courts in calculating legal responsibility. Yet in scienter, the stakes for owner and victim are �all or nothing� because a victim�s blameworthy, provoking acts can completely cancel the owner�s strict liability for knowingly keeping a dangerous animal, rather than leave the owner only partly liable.
Due to scienter�s problems and the perception of past injustice to bite victims, many Canadian provinces have enacted statutes to make victim compensation more accessible. All three northern territories and nine of Canada�s ten provinces have a statute, statutory sections or regulations devoted to dog-related injuries. British Columbia alone has no statute, its Animals Act having been struck down and not replaced. Existing dog-bite statutes vary in their features. Ontario�s Act incorporates a ban on pit bulls, while the three northern territories and Newfoundland/Labrador expressly include wolf-dog hybrids among �dogs�. Some place restrictions on the use of Husky or sled-dogs near settled areas, and Saskatchewan�s restrains the keeping of dogs for fighting purposes. All the statutes impose penalties when human beings and domestic livestock (but possibly not always domestic pets) are at risk; in some northern areas, attacks on inanimate �property,� such as food caches also attract penalties. In addition to the provincial and territorial statutes, there is also a federal statute, the Criminal Code of Canada, under which owners may be charged when their dogs attack people.
All of these statutes and regulations allow a dog that bites (or tries to) to be seized and destroyed, either with or without a judge�s order, possibly at the scene of the incident. Statutory fines for infractions such as bites or �running at large�[31] are imposed in some provinces, in addition to victim compensation, but vary greatly by region. In Nova Scotia, Prince Edward Island and Quebec, and in British Columbia, which has no statute, no additional fines are imposed beyond victim compensation. In several areas, statutory fines exist but are almost trivial: in Alberta $5/day, in New Brunswick a lump sum of between $10-50, in Nunavut and the North-West Territories a maximum of $25 and in Newfoundland /Labrador, up to $200. Yet in other regions, fines may be much more substantial: up to $10,000 in Ontario and Saskatchewan, and in Manitoba, $5,000 for a first offence and $10,000 for subsequent incidents.
Prison terms are an alternative in some regions; longer terms seem to be available where substantial fines exist. The length of such terms can be up to 30 days in Nunavut or the North-West Territories, up to three months in Newfoundland/Labrador, up to six months in Ontario, Saskatchewan, and Manitoba (for a first offence, or for subsequent re-offences, up to one year) and an unspecified length in New Brunswick.
It is unclear why such large discrepancies exist in the penalties for dog-related infractions in different parts of Canada. There may be important regional differences both in victim characteristics and in attitudes towards dogs, especially comparing more urbanized and densely populated regions, such as the province of Ontario, with less affluent, more rural or northerly regions, such as Nunavut or the Yukon. In more urban and prosperous Ontario, there may be a more vocal, better informed and powerful population of potential (or actual) victims able to lobby effectively for stricter laws, following high-profile dog attacks. Less urbanized but strongly agricultural regions such as Saskatchewan and Manitoba, which may also possess powerful lobby groups concerned about potential financial losses from livestock attacks, may have followed Ontario�s example. Another possibility is that in urban Ontario, where people are somewhat disconnected from the natural world including animals, there may be a sense that dogs represent unnecessary health and safety risks to be discouraged, rather than indulged.
By contrast, in the less populous north, where more traditional Aboriginal subsistence lifestyles and a frontier mentality persist, bite victims may be impoverished, dispersed on reserves away from mainstream media, and not well-organized enough to lobby for legislative change. Northern attitudes to dogs may differ from those in the south, and may have changed little from pre-colonial times. In a recent Yukon case, a neglected German Shepherd-Rottweiler cross that bit several people was championed by the local pound and defended legally, being described as �a good skookum dog�, a Chinook Aboriginal term meaning a dog valued for its strength and bravery.[32] In the north, dogs and their associated risks may be seen as a �necessary evil�, like motor vehicles elsewhere, given their importance for transport in less accessible regions, for hunting game or for protection of vital winter food caches against marauding wildlife. For such tasks, a dog�s survival instincts, stamina and some aggressiveness may be looked on more with approval and admiration than condemnation in these areas.
Canada�s statutes seem to have studiously tried to correct the old scienter-based injustices to victims. Yet in the process, some may have gone to the opposite extreme, arguably causing unfairness to responsible owners and their dogs. As in scienter, unreasonable or �humanizing� standards may be required of a dog, under some statutes. Of the 11 existing statutes, only two Acts �those of Prince Edward Island and Ontario-- systematically include the dog�s (as well as the human) perspective[33] on the circumstances of a bite, for instance, factoring into a judgment details such as whether a dog was injured, teased or protecting its puppies. In Nunavut and the North-West Territories, the contribution of neglect or starvation to a dog�s becoming a safety risk is noted, but this may not excuse an attack. In Saskatchewan, the defence of provocation can, in theory, introduce a dog�s perspective, but the defence is weakened by accepting only deliberate human acts that were intended to provoke the dog. Thus unintentional acts such as tripping over and falling on a dog, or deliberate acts not intended to provoke a dog, such as hugging or petting an unfamiliar dog, will not qualify as �provocation� in Saskatchewan, although they might well seem provocative to some dogs. While in Saskatchewan provocation could, if proven, bar all liability, in Manitoba and Ontario, proof of provocation only reduces the compensation payable to the victim.
Of the 11 Canadian Acts, nine[34] expressly remove the traditional scienter-based need for victims to prove a dog�s dangerous propensity and owner knowledge of that propensity. Yet three of the nine statutes-- Ontario, Manitoba and Newfoundland/ Labrador-- also remove the need for victims to prove owner fault or negligence, such as a lack of owner due diligence in confining or supervising the dog, making an owner�s disproof of fault irrelevant in those provinces. Thus in these three provinces, an owner may not be able to escape liability even if he undertook all reasonably foreseeable public safety precautions. Of course, to have bitten, a dog must have managed to circumvent such precautions, but this could have been due to a freak, unforeseen event such as a natural disaster, or an intervening act by another person. For instance, pranksters may release a dog, or an illiterate or ill-intentioned person may ignore a �Beware: Guard Dog on Duty� sign[35], such as when a child climbs over a fence to retrieve a lost ball. However, such possibilities may be irrelevant to whether penalties attach in these provinces, although they probably influence the size of penalties. This risks some unfairness to responsible owners and dogs.
Thus there may be some question as to whether, in Ontario, Manitoba and Newfoundland/ Labrador, the statutes represent a true �strict liability� regime. In Morsillo, the court described the local statute, the Ontario Dog Owner Liability Act, as a �strict liability� approach to dog-bites. The possibility of a prison term may also imply that such statutes are intended to represent only a strict liability approach.[36] Yet some argue that by neither requiring proof of propensity and owner knowledge, nor owner negligence, these statutes make it nearly impossible for owners to escape liability, regardless of how careful they were. Thus the old scienter-based �strict liability� approach may have been replaced in these three provinces with something closer to �absolute liability�.[37] Usually, absolute liability denotes an activity seen as inherently harmful or risky to society as a whole, which is to be deterred. This does not seem in keeping with dog ownership, which offers society many benefits, including dogs� companionship, guardianship and other services, and improved owner health and happiness, at relatively low costs.
In very severe attacks, especially those that have attracted significant media attention and public outrage, owners are sometimes charged with �criminal negligence� to symbolize the desire for future deterrance. Despite the similarity in name to �negligence,� criminal negligence actually represents a different legal approach based on Canada�s federal criminal law, rather than being related to the common law of negligence. The statutory definition of criminal negligence involves doing any act or omitting to do a legal duty that shows �wanton or reckless disregard for the lives or safety of others.� Use of the words �others� suggests that only attacks on human beings, rather than pets, livestock or inanimate property, can trigger charges under this statute. In alleged criminal cases, it is the State[38] rather than the attack victim who lays the charges. In such cases, for some reason, it does not appear to be usual for civil charges to be pursued simultaneously by parties, in addition to the criminal charges laid against the owner.
In this less common[39] approach to severe dog-attacks, an owner may be charged with contravening either s.221 (�causing bodily harm by criminal negligence�) or s.220 (�causing death by criminal negligence�) under the federal Criminal Code of Canada (R.S.C. 1985, c. C-46, s.219 - 221). The criminal law approach may be used to denote public condemnation of an owner suspected of highly irresponsible behaviour and may allow stiffer penalties, in order to deter future incidents. For example, in contrast with some of the lighter penalties existing under the provincial dangerous dog statutes, the maximum penalty for a criminal conviction under s. 221 is a ten-year prison sentence, while those violating s.220 may be sentenced to life imprisonment. A criminal record will follow a convicted owner even after the completion of a prison term, adding to the seriousness of the penalty and its associated social stigma. However, there are much greater obstacles to proving and obtaining a criminal conviction than exist in the non-criminal approaches discussed earlier.
The case of R. v. Baird illustrates the greater difficulty in obtaining a criminal conviction than in finding non-criminal liability for dog-bites. In Baird, the dogs� owner was charged with criminal negligence when his two Eskimo huskies escaped and severely bit a young boy. One of the dogs had nipped the owner previously while he held a puppy and they had bitten a boy who climbed over the fence surrounding their yard. These incidents suggested aggressive tendencies. Yet Baird was not convicted since he took proper safety precautions (a fenced yard, and chained collars with special locks), and because someone�s deliberate act in releasing the dogs while he was away was considered a significant factor in causing the incident. To be convicted would have required proof of his negligence �beyond a reasonable doubt�, a much stricter standard of proof than required in common law cases, where only proof �on a balance of probabilities� is needed. As a result of these greater evidentiary challenges, more commonly, non-criminal negligence law is used to encourage owners to protect the public from their dogs.
Overall, Canada�s non-criminal statutory schemes seem to misplace the focus on a dog�s conduct,[40] rather than its owner�s, while often ignoring the dog`s perspective on the circumstances of a bite. Experts have long claimed that �there are no bad dogs, only bad owners� or that �focussing on what is at the end of the leash�--the individual dog or breed�is less effective in reducing dog-bites than addressing �what is holding the leash.�[41] A sensible approach to canine aggression should focus more on owner conduct, which is more amenable to correction by law,[42] education or other means. This may result in better accountability for dogs� actions than an approach that simply results in the dog�s destruction, since a bad owner may simply obtain a new dog and treat it with similar irresponsibility in the future.
The trend towards increasing statutory liability in dog-injury cases may have begun with the realization that bite victims were unfairly denied compensation under the old scienter scheme, even for serious injuries. Yet it now seems that, especially in more urban and populous areas, the pendulum may have swung too far in the opposite direction. In more populated regions�unlike in Canada�s north, where there is still a greater connection to and respect for nature-- there may also be a subconscious belief that dogs should conform to the same consumer safety guarantees as other inanimate products that people casually acquire and treat as disposable. This is unrealistic and ignores dogs� needs as living things and the importance of respecting their non-human differences.
Future statutory amendments could include reforms based on a negligence model. Some authors suggest that a negligence standard offers the best compromise between the extremes of victim-unfriendly scienter and owner-unfriendly statutory (strict or absolute) liability.[43] A negligence-based statutory model would require owners to take reasonable precautions, tailored to their particular dog, such as confining, training or muzzling their dog to minimize foreseeable risks to the public, and would punish owners who did not display reasonable foresight in taking such steps. This resembles both parental responsibility for a child�s conduct and occupiers� responsibility for the safety of inanimate property to others.[44]
Other statutory reforms might be modelled on motor vehicle safety in high-risk age-groups, such as periodic refresher courses and testing (for owner and dog alike) before licensing, a demerit point system[45] to track offending owner, non- trivial penalties or ownership bans, consistent in size among provinces, and earmarking of fine monies for the safety education of children or other potential victims.[46] As noted, some provinces have drawn a connection between the humane treatment of dogs (providing adequate food, water, shelter, supervision and medical care) and reduced dog-attacks.[47] Thus public complaints of cruelty, neglect or dog-fighting may be useful �sentinel events� that should be given higher enforcement priority than in the past.[48]
Ultimately, dogs are comparable to neither dynamite nor plush toys: they are living things that warrant respect for their own sake as well as for human safety. While rare, canine aggression is a serious issue for victims, owners and dogs alike. Future legal changes should aim to strike a balance between protecting public safety and preserving the ancient bond between people and dogs.
[1] A. Miklosi, Dog: Behaviour, Evolution, and Cognition, (Toronto: Oxford University Press, 2007) at 56; K. Stafford, The Welfare of Dogs (Springer: 2006) at 1, 4; X. Wang & RH Tedford, in P. Jensen ed., The Behavioural Biology of Dogs (CABI International, Oxfordshire: 2007) at 3, 33.
[2] M.D. Olmert, Made for Each Other: the Biology of the Human-Animal Bond (Merloyd Lawrence Books, Philadelphia, PA: 2009) at 229.
[3] The US` National Canine Research Council (NCRC) reported 72 million dogs in the United States in 2007, suggesting an estimated 7 million in Canada, with one-tenth the US population; `Media reporting of canine aggression: fact vs fiction`, National Canine Research Center, online at: www.nationalcanineresearchcouncil.com (hereafter NRCR report)
[4] Dog-like behavior may arise in mere generations as seen in fox breeding studies; A. Miklosi, Dog: Behaviour, Evolution, and Cognition, (Toronto: Oxford University Press, 2007) at 58
[5] Kevin Stafford, The Welfare of Dogs (Springer:2006) at 7.
[6] (US) Centers for Disease Control & Prevention, `Dog bite prevention,` online at: www.cdc.gov/HomeandRecreationalSafety/Dog-Bites/biteprevention.html (hereafter `CDC Report`).
[7] Canada does not compile official dog bite statistics; Canadian numbers are (under)estimates based on media reports or US rates.
[8] K.P. Quinlan & J.J. Sacks, Centers for Disease Control, Hospitalization for dog bite injuries, (1999) 281 JAMA 232 at 232.
[9] CDC Report online.
[10] Thus in total, there are roughly 15 -20 US deaths per year, and 1-2 Canadian deaths per year. S. Avis, Dog pack attack: hunting humans, (1999) 20 Am J. Forensic Med. Pathol. 243 at 243, M. Raghavan, Fatal dog attacks in Canada, (2008) 49 Can. Vet. J. 577 at 577.
[11] From 1994-2007, dog-bite hospitalization fell 30.3 %, NRCR report; M.E. Lang and T. Klassen, Dog bites in Canadian children: a five-year review of severity and emergency department management (2005) 7 Can. J. Emerg. Med 309 at 313.
[12] L.A. Epstein, There are no bad dogs only bad owners: replacing strict liability with a negligence standard in dog bite cases, (2006) 13 Animal L. 129 at 129 (hereafter Epstein).
[13] Children represent over half of dog bites treated and 70% of fatal attacks. American Veterinary Medical Association Task Force on Canine Aggression and Human-Canine Interactions: a community approach to dog-bite prevention. (2001) 218 JAVMA 1732 at 1741. [Hereafter �AVMA report�]. Children up to 14 years were 3.4 times more likely to be bitten than all other age groups combined, Canadian Hospital Injury Reporting and Prevention Program, Injuries associated with dog bites and dog attacks, 1996, Public Health Agency of Canada, online: www.phac-aspc.gc.ca. More severe bites occur to the head and neck of younger children, who may play inappropriately, hurting dogs, touching their food, acting like prey or simply having their heads closer to a dog�s muzzle; I.L. Reisner, F.S. Shofer & M.L. Nance, Behavioural assessment of child-directed canine aggression, (2007) 13 Injury Prevention 348 at 348. Boys may be 50% more likely to be bitten than girls; J.R. Matthews & K.A. Lattal, A behavioural analysis of dog-bites to children, (1994) 15 Behav. Devel. Pediatrics 44 at 47.
[14] But stricter standards of proof are needed for a criminal conviction.
[15] M. Raghavan Fatal dog attacks in Canada, (2008) 49 C. Vet. J. 577 at 577.
[16] Packs caused 75% of Canadian deaths but only 33% of US deaths; M. Raghavan Fatal dog attacks in Canada, (2008) 49 C. Vet. J. 577 at 578.
[17] This occurred in a fatal pack attack on a human family by eight Labrador husky sled-dogs in Newfoundland/ Labrador. S. Avis, Dog pack attack: hunting humans, (1999) 20 Am. J. Forensic Med. Pathol. 243 at 243
[18] S. Avis, Dog pack attack: hunting humans, (1999) 20 Am. J. Forensic Med. Pathol. 243 at 246.
[19] S. Avis, Dog pack attack: hunting humans, (1999) 20 Am. J. Forensic Med. Pathol. 243 at 243.
[20] Deliberate hybridization of wolves and sled-dogs may be uncommon because it can lead to counter-productive dominance traits in a dog-team. Yet inherited paw traits unique to wolves may allow hybrid sled-dogs� feet to avoid gathering �snowballs�, permitting longer pain-free running. R. Coppola & R Schneider, Ch. 2 �Evolution of working dogs� in J. Serpell (ed.), The domestic dog: its evolution, behaviour, and interactions with people, (Cambridge University Press, Cambridge: 1995) at 25, 26.
[21] J.R. Matthews & K.A. Lattal, A behavioral analysis of dog-bites to children, (1994) 15 Behav. Devel. Pediatrics 44 at 47.
[22] That is, he was responsible for compensating the victim financially for the injuries caused.
[23] The dog�s chain had rusted from being constantly outdoors.
[24] The court also found the owner liable in negligence as well.
[25] In one study, 66% of dogs that bit a child had never bitten a child previous and 19% had never bitten any human previously; I.L. Reisner, F.S. Shofer & M.L. Nance, Behavioural assessment of child-directed canine aggression, (2007) 13 Injury Prevention 348 at 348.
[26] While this was resolved under statutory strict liability, the court discussed the evidence initially as if in a scienter case, before concluding that the statute had replaced scienter in that particular province.
[27] This was suggested in a (non-scienter) case, R. v Perez, where the judge seemed to go to unusual lengths to allow the owners leeway, on account of the boy�s tormenting of the dog.
[28] Epstein at 4 of 21 online (Lexis)
[29] This is not to say that the dog�s view should necessarily prevail: if a dog persistently views children as prey, this may not be tolerable in many contexts, especially in densely-populated areas, where many children may be put at risk.
[30] Epstein at 4 of 21 online (Lexis)
[31] In Nova Scotia and New Brunswick (by regulation) disturbing the neighbourhood quiet may trigger similar legal consequences to a bite.
[32] B. Weber, �The curious case of the dog in the courtroom,� The Globe and Mail, 31 July 2009 at A2. The dog�s euthanasia order was stayed on August 7, 2009.
[33] Multiple factors are considered, such as unusual circumstances justifying the attack and the likelihood of future incidents.
[34] Manitoba, Newfoundland/Labrador, Ontario, the Yukon, Nunavut, the North-West Territories, Prince Edward Island, Saskatchewan and Nova Scotia remove scienter requirements.
[35] Only in Ontario are owners not liable if the person bitten was committing a criminal act, but even then, only if keeping the dog was �not unreasonable.�
[36]This is because the possibility of a jail term for an owner (for instance if he cannot pay a fine) requires giving him a chance to free himself by showing he fulfilled all due diligence. If no such option exists, the offence is one of absolute liability. In Canada, imposing prison for absolute liability offences is impermissible: it unconstitutionally violates the right not to be deprived of liberty except according to the principles of fundamental justice, under s.7 of the Canadian Charter of Rights and Freedoms. It seems possible that the confusion over whether, in effect, a strict liability or absolute liability approach exists in these three provinces� dog-bite statutes, all of which make prison terms an option, might conceivably support a future Charter constitutional challenge to these provinces� statutes that could result in their being struck down.
[37] Epstein 3 at 21 online (Lexis). The court in McAllister v. Wiegand also noted that the Ontario statute could be seen as resulting in absolute liability for dog owners.
[38] Specifically in Canada, the �Queen� or the federal �Crown�, abbreviated �R.� for Regina, the Latin term for Queen.
[39] Of nearly 60 dog-attack cases reported on LexisNexis Quicklaw, approximately 16% involved criminal charges to the owner of a (non-police) dog.
[40] Epstein at 2 of 21 online (Lexis).
[41] T. Follett, �Welcome to Dog-Trax,� online at: http://www.preventdogbites.ca/press.aspx
[42] Based on a negligence standard rather than strict liability; Epstein at 6-7 of 21 online (Lexis).
[43] Epstein at 7 of 21 online (Lexis).
[44] Epstein at 6 of 21 online (Lexis).
[45] J. Langley, Controlling dangerous dogs, (1997) 110 N.Z. Medical J. 427 at 428. This might have the added advantage of creating a database of dog-related injuries, for analysis by researchers.
[46] The Centers for Disease Control recommends that children not approach unfamiliar dogs (especially without an adult) or bother them near their food or puppies; if confronted by a menacing dog, do not scream or run (like injured prey) but avoid eye contact, be still like a tree, and if knocked down, roll into a ball and be still like a log. Dog Bite Prevention, Centers for Disease Control, online at: www.cdc.gov/HomeandRecreationalSafety/Dog-Bites/biteprevention.html
[47] NRCR report
[48] NRCR report


text:
Campus Ministry Schedule
Mass and Services Schedule
Housed in Bogel Hall, St. Clare Chapel is available for liturgical and worship services, faith sharing and private prayer. Everyone is welcome to use and frequent the chapel. To accommodate large groups, other campus sites may be used for liturgical functions.
Mass and Services
Liturgy of the Eucharist (Mass) is celebrated on campus on significant Franciscan feasts, holy days and special occasions. The following 2013-2014 Masses and services are scheduled:
Aug. 2 - Feast of Our Lady of the Angels/ "Feast of Pardon" Mass, 9:00 a.m.
Oct. 3 - Feast of St. Francis Peace Walk, 12:30 p.m., Swan Auditorium
Dec. 8 - Live Nativity, 2 p.m., Quad area
TBA - Blessing of Throats
March 5 - Ash Wednesday Communion Service & Distribution of Ashes, 12:15 p.m., St. Clare Chapel
May 10 - Baccalaureate Mass, 9:30 a.m., Swan Auditorium
Hilbert students are invited to attend Sunday Mass at 8:00 a.m. at the Motherhouse of the Franciscan Sisters of St. Joseph. Arrival must be between 7:45 & 7:55 a.m.
In addition, there is a Sunday Shuttle Service. Students wishing to attend the 11:00 a.m. service at the Wesleyan Church of Hamburg are picked up at the back entrance of Trinity Hall at 10:40 a.m. Students wishing to attend the 12:15 p.m. Mass at Saints Peter and Paul RC Church are picked up at the back entrance of Trinity Hall at 11:45 a.m. Return transportation is also provided.
Upcoming Events
- The Feast of Pardon
- Aug 4, 2014
- First Year Student Orientation
- Aug 8, 2014
- Last class session for summer session A2
- Aug 19, 2014

subset: commoncrawl


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In 2014, we are planning to redevelop Private Healthcare UK and its sister site GoPrivate.com into a single site.
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Mr Aman Coonar is a Consultant Thoracic Surgeon and sees private patients at the Papworth Clinic in Cambridgeshire, The Harley Street Clinic, Nuffield Hospital in Cambridge and the Spire Hospital in Bushey, Hertfordshire.
His base is at Papworth Hospital which is the UK's largest specialist cardiothoracic hospital for adult patients.
Mr Coonar handles benign diseases and cancer and his main clinical interests are:
Minimally invasive surgery (VATS)
Lung cancer surgery
Chest sarcoma surgery
Mesothelioma surgery
Chest wall surgery and trauma
Airway surgery
Surgery for metastases to the lung
Lung volume reduction surgery
Benign problems such as empyema and pneumothorax
After school at the Haberdashers' Aske's School in Hertfordshire, Mr Coonar qualified as a doctor from Guy's & St.Thomas' Medical schools in London. He trained first in internal medicine and intensive care. Then he undertook basic science research. After, he undertook general surgery and cardiothoracic surgery training at Guy's, St Thomas's, King's, Royal Brompton and the London Chest Hospitals. In 2005-2007, Mr Coonar worked at the Toronto General Hospital in Canada and took senior fellowships in general thoracic surgery and lung transplant surgery. He returned to the UK to take a consultant surgeon position at Papworth in 2007 and his practice is in pure thoracic surgery. He works closely with a large specialized team including other surgeons, nurses, physiotherapists radiologists and physicians. When needed there is support from our dedicated cardiothoracic intensive care unit. The Papworth consultant anaesthetists are all specialists in cardiothoracic anaesthesia and as a team are recognized for private work.
As well as to Cambridge University students and junior doctors Mr Coonar regularly hosts an airway surgery training class in Cambridge.
See a video clip of Mr Coonar discussing lung resection and chest wall surgery at the UK National Cancer Research Initiative Meeting 2009.
Convener UK Thoracic Surgery Forum 2010
Co-convener 'Regenerative Medicine for the heart, lungs and airways', Royal Society of Medicine, 2010
Convener Toronto-Cambridge Thoracic Surgery Review course 2011
Mr Coonar has published several research papers and book chapters, some of which have received awards. Some of these can be read by following this link.
Mr Coonar is involved in various research activities including:
The PULMICC trial, which is an investigation of the role of surgery for colorectal cancer metastases to the lung. Papworth Hospital was the first unit to enter patients into this study and Mr Coonar is the local principal investigator.
The MESOVAT trial, which is run from Papworth Hospital, is studying the role of minimally invasive surgery for mesothelioma. Mr Coonar is currently the designated surgeon for this study at Papworth.
Follow this link for updated information.
Governor - Parkside Schools, Cambridge
Charity Clinic, Punjab, India
Patients are referred from throughout the United Kingdom and from abroad. Many are referrals from East and South East England especially Cambridgeshire, Suffolk, Norfolk, Essex, Hertfordshire, Bedfordshire and North and Central London, including those from
GMC Number:
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Date of registration:
01 Aug 1992
Papworth Hospital provides care to patients with a wide range of acute and chronic chest conditions, including:
Lung cancer
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Investigation and management of pleural diseases
Chest wall surgery
Thoracic oncology
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Diseases of the diaphragm
Respiratory physiology laboratory
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Mr. Aman Coonar is an accredited consultant for the UK's leading private healthcare providers and private hospitals, including HCA Hospitals
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The Harley Street Clinic, 35 Weymouth Street, London , W1G 8BJ
Tel: +44 (0) 20 7935 7700
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Web: www.theharleystreetclinic.com
Cancer specialist
British Medical Association
Society of Cardiothoracic Surgeons
Royal Society of Medicine - council member of the cardiothoracic section
International Association for the study of Lung Cancer
European Association of Thoracic Surgeons
Papworth Clinic at Papworth Hospital NHS Foundation Trust
Papworth Everard, Cambridge, CB23 3RE.
Tel: +44 (0) 1480 364 639
Email: email@example.com
Web: www.papworthclinic.com
The Harley Street Clinic
35 Weymouth Street, London , W1G 8BJ
Tel: +44 (0) 20 7935 7700


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Wondering what's moving into your neighborhood shopping center? Our weekly Sprouts & Shutters column highlights the latest Tri-Valley restaurant, retail and other business news.
The long wait is over: Livermore's new Paragon Outlets open Nov. 8, and the new shopping center is celebrating in style this Thursday and all weekend long. Events launch with a "Champagne and Confetti" ceremony on Thursday at 10 a.m. followed by live entertainment, prize drawings and in-store events and sales. For more event details and to view the latest list of new stores opening, visit paragonoutletslv.com.
Tri-Valley Bank, headquartered in San Ramon, opened its first branch in Livermore last week. The new location on First Street is close to the heart of downtown across from Donut Wheel. For more about Tri-Valley Bank, visit trivalleybank.com.
Popular fashion chain Forever 21, located in the Stoneridge Shopping Center, will soon move into an enormous 21,000 square foot, two-story mall space. The new Forever 21, which sells affordable trendy clothes geared toward young women, will open around the holidays near Macy's Women. The center's existing Forever 21 will remain open until then. Learn more about Forever 21 at forever21.com.
There always seems to be room for one more frozen yogurt shop: Berry Delight Frozen Yogurt is currently under construction and should open near the holidays next to Kay Jewelers in the Stoneridge Shopping Center.
Caps & Taps, a new beer store and taproom, is set to open in a few weeks in Dublin's Shops at Tralee. Father-and-son owners and Dublin residents Greg and Brian Lewis say they'll offer bottled craft beer for purchase as well as 12 rotating beers on tap for customers to enjoy in the shop. "We plan to feature and highlight the booming local craft beer scene by stocking our shelves and our tap lines with beer brewed and bottled here in Northern California," says co-owner Greg Lewis. Caps & Taps will provide a corking service and light snacks and patrons are invited to bring food from neighboring eateries to eat in the new taproom.
San Ramon diners who were sad to see Incontro move to Danville will soon get some of their favorite Italian restaurant back. According to the most recent Diablo Dish, Incontro's Gianni Bartoletti has left the award-winning restaurant to open Gianni's Italian Bistro in Incontro's original location on San Ramon Valley Boulevard currently occupied by La Finestra. Look for an opening later this year.
A new Togo's sandwich eatery opens Nov. 19 in Danville's Town & Country shopping center on San Ramon Valley Boulevard. The 40-year-old Bay Area based chain now has more than 250 locations on the West Coast, including another Danville shop on Camino Tassajara. Learn more at togos.com.
Diablo CrossFit will be opening soon in the Alamo Plaza shopping center. At the new 3,600 square-foot Alamo gym, an offshoot of the popular Diablo CrossFit centers in Pleasant Hill and Martinez, members work out in small classes with coaches to build their strength and endurance. Diablo CrossFit is affiliated with the fitness company CrossFit, with more than 4,000 gyms nationwide specializing in short but intense workouts using equipment ranging from jump ropes to kettlebells. Learn more at diablocrossfit.com.
Want to find out what else is opening in the East Bay? Sprouts & Shutters now covers 21 cities on 18 Patch sites. Read the latest columns for the Central Contra Costa, Berkeley/Oakland and Fremont/Tri-Cities communities.
Did you miss Patch's last retail and restaurant roundup? Read about these and more in our last Sprouts & Shutters column:
- McCaulou's Home and Ike's Lair in Danville
- Eye Level Learning Center in San Ramon
- Mobile Device Repair in Dublin
- New Leaf Community Market and Fresh Choice in Pleasanton
- Wingstop and Denny's Cafe in Livermore
Know of a business opening or closing in the Tri-Valley? Please tell Patch about it for a future Sprouts & Shutters column. Simply add it to this short form. Or send me a news tip at firstname.lastname@example.com.
For more local business news, follow Patch on Twitter @EBayPatchBiz.


text:
B.A., 1965, Brandeis University
Ph.D., 1970, Cornell University
J.D., 1974, Columbia University
Areas of Expertise
Richard H. Weisberg is the Walter Floerhsheimer Professor of Constitutional Law. He is a recent White House appointee to the Commission on the Preservation of America's Heritage Abroad. Professor Weisberg has helped litigate successfully in American federal courts on behalf of Holocaust survivors and their heirs, providing a measure of justice for World War II victims of anti-semitism.
President Nicholas Sarkozy of France awarded him the Legion of Honor in 2008. The founding director at Cardozo of the Program on Holocaust/Human Rights Studies and the Floersheimer Center for the Study of Constitutional Democracy, he writes widely in those areas, including his book Vichy Law and the Holocaust in France and essays on First Amendment developments in the Supreme Court of the U.S. He is a pioneer in the growing Law and Literature movement worldwide, and his books The Failure of the Word and Poethics have been widely translated. He has taught that subject at many undergraduate institutions in the U.S., at law schools around the country, and in France, Denmark and China, where he is an Honorary Professor of Law at Wuhan University.
His stagings of legal dilemmas in great fictional works have won notices from the New York Times, the National Law Journal, and The New Yorker magazine. He has been a Guggenheim Fellow and recipient of Rockefeller Foundation, NEH, and ACLS grants. His Ph.D. from Cornell is in French and Comparative Literature. While teaching those subjects on the graduate faculty of the University of Chicago, he earned his J.D. from Columbia Law School, where he was an editor of the Law Review. He has been associated with the firm of Cleary Gottlieb Steen & Hamilton in New York and Coudert Freres in Paris.
Contact Information
Cardozo School of Law
55 Fifth Avenue, Room 520
New York, NY 10003


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100% of customers would recommend this product to a friend (6 out of 6)
Involvement Level: Expert (understands the inner workings)
Pros: It's a stylus spring strap for EVERY NDS avaiable on a market. Yes, that means old DS Phat too. You want a proof? Go to the images section, and find it by yourself. It works, it keeps your stylus to the DS, it has not cheap plastic, it's just stable. Great product for such a cheap price.
Cons: As mentioned above, it's working for DS Phat. But... you can find it difficult to attach it to the original DS Phat stylus. But you can do it, you just can use some flat piece of metal to inject the strap to stylus. Other than that, it's perfect
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Pros: Really cute, nice color assortment. Great price. Well buildt. May be really useful to attach different items to you camera, cell phone, and even the DS but not the stylus.
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Cons: em portugues:acho que não tem contra, ele é muito pouco fragil as veses escapa, mas é muito boa eu recomendo In english I think it has against him is very little escapes sometimes because its a little fragile, but very good I recommend
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A majority of employers in this country rely on social media and other online information when hiring new employees. As a result, many employers pass over applicants who display undesirable traits or behavior on their social media profiles. Perhaps your business is one of them. If so, you may want to reconsider this practice or at least start doing it differently.
A fascinating study recently released from North Carolina State University suggests that many companies misunderstand online behavior. This means that they may overlook applicants who are actually well-suited for the job.
Consider the trait of conscientiousness. No doubt most employers value this trait in their employees and look for it in job applicants. According to the study, many employers assume that finding evidence of alcohol or drug use on an applicant's social media profile means that the applicant is not conscientious or self-disciplined.
Not necessarily. The study suggests that there is no correlation between conscientiousness and a persons willingness to post his alcohol or drug use on Facebook. As the lead author of the study stated, This means companies are eliminating some conscientious job applicants based on erroneous assumptions regarding what social media behavior tells us about the applicant.
Companies that would prefer extroverted employees may be doing themselves an even bigger disservice if they rule out applicants who post about alcohol use on social media. According to the study, extroverts are significantly more likely to share their alcohol or drug use on Facebook.
The only area where researchers found a correlation between personal traits and online behavior related to people who insult others on Facebook or other social media. Conscientious people are unlikely to badmouth others, at least publicly through social media.
These results may be explained, at least in part, by generational differences. Young people generally have a different notion of online privacy than their older potential employers. Recent studies indicate that younger employees feel it is inappropriate for their employers to check their off-duty conduct on social media. They also do not believe that their online personas should be the basis of work-related decisions, despite the reality that employers do this all the time.
So what should interviewers look for on social media? Be on the lookout for applicants who:
Lie about their qualifications.
Bash previous employers.
Post company secrets.
Post racist, sexist, or other offensive comments or content.
Upload photos showing themselves when drunk, or make references to illegal behavior.
What about current employees? What type of online off-the-job behavior requires action?
Monitoring social-media usage can be valuable. For instance, employers can sometimes find online evidence to determine whether employees workers compensation or Family and Medical Leave Act claims are valid.
Nonetheless, balancing the employer's legitimate interests with the employee's right to enjoy a private life can be difficult. The specific activities that might embarrass your particular business are too numerous to list here.
The best way to encourage the type of online behavior your company values and wants to encourage is to create and enforce a written social media policy. (Recent Boise State on Business columns addressed this topic.)
As always, when drafting employment policies or trying to determine how to manage employees within the boundaries of the law, consult with an HR professional or attorney.


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US: Cato lowers forecast despite Q2 profit rise
Value-priced fashion retailer The Cato Corporation has managed to lift its second quarter profit by 7%, but warned rising raw material costs will have a negative effect on second half performance.
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Our impact in California
You can't address the globe's most pressing problems without also addressing those closest to home, here in California. And that's what UC Davis is doing every day: working together to make life better in the golden state.
We're driving innovation, stimulating economic activity, educating tomorrow's leaders, and advancing societal change to protect our one California.
UC Davis generates $6.9 billion in annual economic activity in California.
90% of the nearly 33,000 students enrolled in state-supported programs are California residents.
UC Davis economic activity accounts for 69,000 jobs in California.
Drs. Maynard Amerine and A.J. Winkler published "Composition and Quality of Musts and Wines of California Grapes" in 1944, ushering in a new era of climate-based varietal selection. In the 1980s, Dr. Ann Noble developed the wine aroma wheel used worldwide.
For every dollar UC Davis received in state funding in 2009-10, it produced $12 of economic activity for the state.
The UC Davis Cooperative Extension program is a major part of the systemwide UC program, which has offices in 57 of California's 58 counties.
UC Davis is the second-largest individual employer in the Sacramento region, behind only the state of California.


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Ex-Royal Mail worker in court accused of stealing thousands of pieces of post (From Halstead Gazette)
Get involved: send your pictures, video, news and views by texting HG to 80360, or email us Click here for more details »
Graham King, 47, of Easterford Road, Kelvedon, faced four charges at Chelmsford Magistrates' Court.
Updated 9:12am Thursday 13th February 2014 in News
A postman accused of stealing thousands of letters and parcels has appeared in court.
Graham King, 47, of Easterford Road, Kelvedon, faced four charges at Chelmsford Magistrates' Court on Tuesday.
He is accused of stealing 6,541 pieces of post between November 2006 and November 2013.
One of the packets he allegedly took contained gift cards and vouchers valuing £40.
King, who worked at the delivery office in Lakes Road, Braintree, is also accused of stealing 35,538 pieces of unaddressed door-to-door mail, post which has no fixed destination, for example company advertising leaflets.
King, who began working as a postman December 2002, spoke only to confirm his name and address during Tuesday's hearing.
The court heard some of the post was discovered in the loft of his former address and reported to Royal Mail in October 2013.
Comments (4)
Please log in to enable comment sorting
1:45pm Thu 13 Feb 14
OMPITA [Intl] says...
Isn't that being just a little presumptuous?
2:12pm Thu 13 Feb 14
Littlepixi says...
OMPITA wrote:not really, there was evidence! some of which was MY post! including a PS3 game which cost me £50, a PC game which cost me £68 and birthday card which were years old that just so happened to be missing money and vouchers.
He hasn't actually been convicted yet, but already the BWT shows a picture of him facing a Firing Squad.
Isn't that being just a little presumptuous?
so yeah any right he had to hide, he himself has compromised by stealing not only my post but others.
8:19pm Thu 13 Feb 14
notters says...
OMPITA wrote:I am assuming that was a clever observation of the background and hence a joke. It is not in the least presumptuous - opened and pilfered mail was found at his current home in a shed and in loft of his previous home! I am also a victim of this crime. What I would like to know is why none of his colleagues or management noticed or did anything about for EIGHT YEARS! I understand that the crime only came to light, because of an external tip-off.
He hasn't actually been convicted yet, but already the BWT shows a picture of him facing a Firing Squad.
Isn't that being just a little presumptuous?
I await the trial at Chelmsford Crown Court on May 6 and to hear what excuses Royal Mail give to explain their obliviousness to crime on such a mammoth scale being perpetrated unnoticed right under their noses, and for 8 years. Also their excuses for their monumental and continued gross negligence in ensuring the safety of customers mail.
9:46pm Thu 13 Feb 14
OMPITA [Intl] says...
Like any other 'British Institution' caught up in such a situation I have no doubt that they will be represented by some very clever and expensive legal brains who will do everything possible to parry off any criticism of their handling of the situation.
You can bet your life they've already got their 'damage limitation' strategy well worked out in readiness.
Seen it all before!
Comments are closed on this article.


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LSC-Montgomery Music Department
Music Faculty
Dr. Sergey Kuznetsov
D.M.A., Piano Performance, Thornton School of Music, University of Southern California, 2011
Artist Certificate in Piano, Southern Methodist University, 2007
Artist Diploma in Piano, Texas Christian University, 2005
M.M., Moscow Tchaikovsky Conservatory, Russia, 2003
Sergey Kuznetsov started his musical education at the age of 5 at the Music School affiliated to the Moscow State Tchaikovsky Conservatoire and in 1998 was admitted to the Tchaikovsky Conservatoire to the class of an outstanding professor Mikail Voskresensky. In 2003 he was awarded his Diploma with High Distinction. In 2002 Sergey received the prestigious Lili Kraus Scholarship at TCU (Fort Worth, TX) and commenced his Artist Diploma studies with Professor Tamás Ungár. After winning a conspicuous scholarship, Sergei was widening his education under the guidance of Joaquín Achúcarro at Dallas Southern Methodist University. Sergei completed his doctoral degree at University of Southern California in Los Angeles under the guidance of a legendary pianist Daniel Pollack. Sergey also studied composition, music industry and electro acoustic media at USC. Sergey has performed extensively throughout the world, both as soloist and chamber musician. Notable events included winning international prizes at China International Piano Competition (Beijing, 2004), Hilton Head International Piano competition (USA, 2003), Caltanissetta International Competition (Italy, 1999), International Piano Competition in Houston, TX (2005). After winning the 3rd China International Piano competition, Sergey has become a frequent performer in China. He has performed as a soloist with Beijing Symphony, Shenzhen Symphony and Taipei Symphony orchestras. He was invited to make studio recording for a young artist program in the Radio & Television (CCTV) in Shenzhen. Sergey also worked as a Teaching Assistant while he was at University of Southern California and organized successful chamber music ensembles and projects at USC. In August 2008 his trio XYZ has toured France and collaborated with a number of famous French musicians. During his studies in the United States, Sergey has always enjoyed teaching and advocating classical music amongst various groups of people. In 2003, he organized a series of educational projects in collaboration with Van Cliburn Foundation. With the mission was to bring classical music to children whose parents can't afford education, the project had become so popular in Texas that Sergey had to reach farther and travel around the state with his lectures and concerts. In 2005-2007 Sergey worked as a Teaching Assistant in Southern Methodist University in Dallas. Several of his students have won national and international prizes that supported their way towards studies in music. Sergey's approach in piano pedagogy is to show his students how great and large the world of music actually is. His knowledge of piano repertoire is very impressive after taking a special advanced piano repertoire course at USC with Stewart Gordon. Sergey Kuznetsov is a founder of the
Bakitone International
project dedicated to classical music competitions, masterclasses and festivals.
Lone Star College System
5000 Research Forest Drive, The Woodlands, TX 77381-4356 - 832.813.6500
Employee Intranet
Legal Notices
Campus Safety


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Congratulations to our graduating students! The Commencement website is updated often, so please check back for additional details on the weekend. No tickets required and the ceremony takes place rain or shine.
The Squirrel Hill Tunnel (outbound) and the 376 eastbound ramp at Edgewood/Swissvale will be closed over Commencement weekend.
The links below include suggested detours for anyone heading east after leaving campus or traveling toward Monroeville from Regent Square.
|Event Information
|Location Information
|May 18, 2013 to May 19, 2013 - This is an all day, multi-day event.
Gesling Stadium


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Courtney Caughey-Stambul
- Courtney Caughey-Stambul
Courtney Caughey-Stambul: Continuing the countdown of my favorite films
Remember my post a couple of weeks ago regarding MSN Entertainment's 100 favorite films list? If not, I'll refresh your memory. I shared which films I considered to be strong picks within the 100-81range of MSN's list. My picks included "Young Frankenstein," "Fight Club," and "West Side Story" among others.
Courtney Caughey-Stambul: My favorite actor? Johnny Depp!
Hello and happy Wednesday to you! We're halfway through the week. Thank goodness! Yesterday, a friend asked me who was my favorite actor. I've been thinking quite a bit about my answer over the past day. If I had to choose, I would say Johnny Depp.
Courtney Caughey-Stambul: Latest 'Oz' indeed great and powerful
I stood in line at the movie theater on Friday night, waiting to see "Oz the Great and Powerful" in 3-D. It was the first time in a very long time that I actually had to wait in line to see a film. As I waited, the crowd and a life-sized poster of a wicked witch, her face slightly shadowed, added to my excitement leading up to the start of this movie.
Courtney Caughey-Stambul: Some of my favorites from the top 100 films
I love when film critics, entertainment companies, movie sites — whomever — produce lists of their favorite all-time movies. I use MSN Entertainment to look up movie times online. The other day I was checking the site to see which theater in Boardman was going to show "Oz The Great and Powerful."
Courtney Caughey-Stambul: My top 10 scary movies
Hello and happy Wednesday to you! This week I will be sharing another top 10 list. You know I love top 10s! Believe it or not, it's probably been almost a year since I've watched a scary movie.
Courtney Caughey-Stambul: I can't wait to see 'Oz the Great and Powerful'
Happy Wednesday! Who is looking forward to Friday, March 8? March 8 is the opening day for "Oz the Great and Powerful," one of the most anticipated film releases of this year.
Courtney Caughey-Stambul: 25 films added to the National Film Registry in 2012
Each year, the National Film Registry adds up to 25 films to its list for possible preservation. Films chosen are not meant to represent the greatest American movies of all time, but rather are meant to represent films that have made an impact on our culture.
Courtney Caughey-Stambul: My top 10 most-loved films of the '90s
I was young in the 1990s. I was born in 1986, so I was actually quite young in the '90s, but I still have a lot of favorite films from the decade.
Courtney Caughey-Stambul: Links of interest for film fans
ABC News has released a video recapping the Sundance Film Festival. The clip includes highlights from the festival. Also, film critic Peter Travers discusses the big winners at the festival, including "Fruitvale", which won BOTH the U.S. Grand Jury Prize for dramatic film and the Audience Award for dramatic film.
Courtney Caughey-Stambul: Sundance Film Festival
The annual Sundance Film Festival is under way in Park City, Utah. The festival is an event of the Sundance Institute, a nonprofit organization that works to promote and advance the work of "risk-taking" storytellers. The institute was founded in 1981.
- More Courtney Caughey-Stambul Headlines
- Courtney Caughey-Stambul: Continuing the countdown of my favorite films


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Rated 4 out of 5 by 412 reviewers.
Rated 4 out of 5 by ShellBeachMama Great hotel, A/C wasnt working great. We love this Sheraton hotel and stay here whenever we visit Anaheim. This trip our room was great except the A/C didn't work great. No matter how low we put the thermostat it didn't go below 71 degrees in the room. Otherwise the hotel is great. We ate at the restaurant, swam in the pool, had room service, and enjoyed the fireworks view. We will be back in January and are looking forward to another great stay. September 6, 2012
Rated 5 out of 5 by spiritmea Great Hotel for the price This is my second stay at this hotel and it was great. The staff is very courteous and helpful. They helped me booked ticket for Universal Studious. I left a bag behind, after I checked out and they very graciously offered to mail it to my home! Also, I found a better rate for this hotel on a different website and after the fact I had made reservations, it was honored. Once again, great hotel to stay at! July 18, 2012
Rated 5 out of 5 by Archville STARWOOD PREFERRED GUEST COMPLETELY SATISFIED THIS was a great hotel with great location right next to Disneyland. Upon our arrival we were greeted promptly and with a smile check in was great, no hassle or waiting. Our rooms were so clean and we could see Disneyland, we were in 615&617. I mean super clean and the sweet sleeper bed was just that a sweet rest. Everything was great and everybody was so courteous and nice. Wow what a great vacation. May 8, 2013
Rated 4 out of 5 by AD123 Consistantly Exceeds Expectations This is the third time that we stayed at this hotel and each time we've had a very pleasant experience. We had a wonderful room overlooking Disneyland with a full balcony which the kids loved to watch the fireworks from. I've been using Starwood Hotels for over 9 years now for work and pleasure and this one always puts a smile on my face. Special mention to Tina for all the help, a true professional! June 19, 2012
Rated 4 out of 5 by Steven1566 I stay here every week (going on 6 months) I travel to the area every week and stay here for work. It's nice because it's mostly families and not fellow travelers competing for room upgrades. The club-lounge is a welcome place to go in the evening as a Platinum member. The staff goes through every morning before I check in and upgrades my room so I can get a top floor room with a Disney view. Friendly people that are always willing to help. The room service was surprisingly excellent. The bar could stand to be updated with a variety of more interesting drinks. All I want is a decent cocktail that consists of more than alcohol and a mixer poured together, but that's Sheraton's work as opposed to this particular hotel. If you're staying here for Disneyland, can't beat the proximity and the facilities. For work-travel, it's better because of status recognition and room upgrades. Gym is also brand-new, spotless, and looks like it's never used. January 13, 2013
Rated 4 out of 5 by Jackie1956 Jackie1956 Excellent service from the staff! Two thumbs up from Dylan at the SPG desk, and all employees working the Club room at breakfast and cocktail hour! Although the hotel is dated, it is kept clean. My kids loved the pool and we loved the view of the Disneyland fireworks, and the 15 minute walk to the parks! This was our second vacation here, and we will be back. August 2, 2012
Rated 4 out of 5 by LWL99 Great Walking Distance Hotel to Disneyland 10-15 minutes safe walking distance to Disneyland ... avoids the hectic parking lots & sardine can trams! Great for afternoon naps! The staff was VERY accommodating to all my requests such as adjoining rooms, crib availability, late checkout, etc. Great service! May 27, 2014
Rated 4 out of 5 by Maureen89 Close to Disney, but still quite a walk! The hotel is tagged as a short walk to Disneyland and while this seems true in the morning, it feels like a much longer walk after walking for 12+ hours in the park. There is a bus that will pick you up, but there is a charge of $4 per person and a taxi is $5 total if you don't feel like walking. Facilities were nice and the staff was very accomodating. August 14, 2012
Rated 5 out of 5 by Anya Total relaxation All we wanted was to "get away & relax". The pool was excellent for exactly that. Beautiful pool area, with food and drinks by the pool. Quiet atmosphere, even with small kids there. We walked to Disneyland in the evenings for dinner. I only wish there were a way to separate rooms for families w/ small children. Otherwise, we loved our stay. August 13, 2012
Rated 5 out of 5 by Dan604 Amazing Resort Definitely the place to stay while in Anaheim. Great location to Disneyland as well as to other restaurants in the area. One of the best Club Floor Lounge experiences I have had. The staff was always friendly and helpful while providing a phenomenal breakfast and afternoon snacks. Worth every penny to upgrade to a club floor suite! January 4, 2012
Rated 4 out of 5 by Got2yearold Disneyland Vacation We stayed here because of the proximity to Disneyland. Great location. 10 minute walk to the gates. There are plenty of choices for food in the hotel and within walking distance. The hotel's convenient store, restaurants, service, pool and grounds were great. We will definitely return and stay here when going to Disneyland. April 19, 2012
Rated 4 out of 5 by nickname Great location for Disneyland The best part of the hotel is it's 10 mins away from Disneyland. Most everything else is was good Sheraton standards. The room AC thermostat didn't operate and I was told there is only one temperature setting (which was too warm for me) for the entire building and no way to control the temperature in your rooms May 31, 2013
Rated 5 out of 5 by Miriam Wonderful stay This hotel has a great location walking distance to parks. Room small but comfortable. Enjoyed lounge, good staff and plenty of food and drink. Microwave would be helpful for own food. Minor problems (1) very slow computer in lounge and (2) took three sets of keys to get ones that worked on lounge door. September 3, 2012
Rated 5 out of 5 by tweetie416 great hotel and friendly workers I booked this hotel for an event at the Anaheim convention Center. Usually you aren't supposed to check in until 4PM but when I called them at 1PM the room was free and I was able to check in earlier. When I came in, I asked for 4 room keys and they gave it to me without question. The people at the front desk are very friendly and helpful. I was very happy with Sheraton's customer service. Since I found a promo for a $25 Amazon gift card, 2 Coca Cola Bottles and 2 Polar Bear stuff animals, I got them right away in a cute red bag except the gift card. That is supposed to be sent to me in 2-3 weeks. The rates for the hotel was very reasonable. Compared to smaller chain hotel rooms, the price was almost the same but with the promo, I actually paid less and got a better room and a nicer hotel. Parking was $15 self parking with unlimited in and out parking. The parking was regulated with gates so I felt like my car was pretty safe. We actually forgot to lock our car and nothing was stolen when we came back to leave the next day. The whole hotel itself was very clean and nice. Our room was great. Beds were comfortable and you get lots of pillows. We even had a balcony. Restrooms were very clean and sanitary. Check out was very simple. We checked out via Phone and left very satisfied with our stay. I would totally recommend this hotel to all my friends. January 4, 2012
Rated 5 out of 5 by Fay123 Wonderful Anaheim Experience My daughters and I just came back from a 5 night stay at your hotel. We were all very impressed with the hotel and especially with the staff. Everyone was very professionl, helpful and friendly. It made our "Disney" vaction extra special to have some great accomodations. July 27, 2012
Rated 3 out of 5 by rgr2013 Almost good. To start, I would recommend this hotel to others. I do feel however that a few things were lacking. The room was nice overall, it was not too large but fine for our needs. The beds were pretty nice and things felt relatively clean. My biggest and frankly only real complaint was the management. On two separate days we returned to our room only to find the housekeeping staff had failed to fully close the door after cleaning. On both occasions we called and spoke with the manager on duty, and on both occasions he said basically that he was sorry, but this happened time to time. That was his reply, nothing more. Thankfully nothing was missing, I think. My line of work deals with security related issues on many levels, this kind of thing is simply unacceptable, to have such a carefree attitude concerning someone else's personal property and feeling of safety and security is very unprofessional. In short, I would return, and I would suggest to others to go here as well, but only if I knew this type of thing was addressed and was being resolved. October 1, 2013
Rated 5 out of 5 by Lola31 This hotel had great staff I enjoyed this hotel. The staff was very nice and helpful. Great restaurants. The room was quiet, couldn't hear much noise around you. The only complaint was the shower backed up and parts were broken. still loved the hotel. October 15, 2013
Rated 4 out of 5 by Arefsal SNA Stay I liked the hotel and recommending to people want to stay close to Disneyland, I think it is a good hotel for vacation but I am not sure for business stay May 26, 2014
Rated 4 out of 5 by Meisterbrau Enjoyed my stay Very nice, clean room. I was on business and had no time to take advantage of the amenities, but everything looked very nice. The wi-fi worked well, and I always had a good wireless connection. The HD flat screen TV was also very nice. September 3, 2012
Rated 5 out of 5 by Dozzer Vacation at Disneyland Excellent hotel very convenient to our destination. The staff was completely accommodating and the facilities were exceptionally clean. Will most certainly stay here again in the future. November 28, 2013
Rated 4 out of 5 by Bob38 Very nice spot near Disneyland and near by restaurants Good location. Near Disneyland. There are several good restaurants and good shopping stores near by. It is also close to the freeway if you need to get out and about. The staff we very good. Parking charge is a little high. October 28, 2012
Rated 4 out of 5 by Craig99 Good all round choice Good clean room! Upgraded to "Disney View" room at check in as SPG Gold. Honored late SPG Gold check-out to 4pm. 10 minute walk to Disney that my 5 year old could handle daily. Great experience with front desk staff! January 14, 2013
Rated 4 out of 5 by U2Fan Comfortable, great location I stayed 1 night on a Friday. It's a great location to Disneyland. You have access to 2 freeways, the 57 and 5. I used my SPG points to book a room without any problems. Nice and friendly staff. Would recommend. March 3, 2013
Rated 4 out of 5 by NMINO Great Choice Great location to Disney! We walked and used the shuttle. Rooms were very clean, beds/pillows were comfortable!! My only complaint would be the additional charges for parking after they charged you for parking - November 28, 2012
Rated 5 out of 5 by GrandmaJenny Great Disney hotel So close to Disneyland. Great view of fireworks. NIce pool for the kids. Very comfortable hotel. December 27, 2013
Rated 4 out of 5 by RT1223 Great place to stay. Great value and proximity to Disneyland. The rooms are a little on the small side so if you have more than a couple children you may want to consider larger accommodations. Highly recommended! February 25, 2013
Rated 4 out of 5 by kangol73 Walk to Disneyland or Convention Center This hotel had friendly staff and is very close to Disneyland and The Aneheim Convention Center. If you don't have parking included or have a rate that includes parking you will have to pay. January 5, 2013
Rated 4 out of 5 by Veny Comfortable hotel near Disneyland We decided to stay at this Sheraton at the last minute Disneyland trip. It was clean, convenient and very comfortable. It is walking distance from the parks and I would highly recommend it. October 11, 2012
Rated 5 out of 5 by Darcie9294 Great Stay1 The staff knew that it was my first time staying at the hotel, so they gave me a room on the 10th floor with a balcony that allowed me a view of the fireworks at Disneyland. August 31, 2012
Rated 4 out of 5 by MrsIncredible Dec-2012 Nice hotel. Convenient to the Disney Parks which is why we chose it. Staff very helpful. Molly's Kitchen was very nice! Can't comment on other amenities as we did not use. January 1, 2013


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Refined by
1806–7 Dec. 1851. Laborer. Born in Indiana. Son of John Smith. Baptized into LDS church. Served mission to Ohio, Dec. 1831, 1832. Married first Elizabeth. Rebaptized into LDS church by William E. McLellin, 27 Aug. 1834, in Eugene, Vermillion Co., Indiana. Moved to Missouri, sometime between 1833 and 1838. Moved to Nauvoo, Hancock Co., Illinois, before May 1842. Appointed first lieutenant in Nauvoo Legion, 7 May 1842. May have married second Mary Jane Angel, 22 Mar. 1843, in Nauvoo. Appointed to serve mission to Erie Co., Pennsylvania, 10 Apr. 1843. Resident of Pottawattamie Co., Iowa, Jan. 1848. Married third Sabrina, by June 1850. Died in Vermillion Co.


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For Consumers
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Traditionally, monovision has been considered the simplest method of presbyopic contact lens correction. Despite recent advances in multifocal contact lens technologies, monovision remains a common mode of presbyopic lens correction in the U.S. today. However, as practitioners are gaining first hand experience with more advanced multifocal lens designs there has been a steady shift away from the traditional approach. Over the next several weeks, we will explore why these fitting practices are changing. Specifically, we will challenge the validity of five common myths driving the use of monovision over multifocal lenses for presbyopic contact lens corrections.
"Monovision is the Best Place to Start for Emerging Presbyopes" is a myth because the status quo may not be the best for everyone. Many patients, for example, use computers at home or work and therefore have intense intermediate visual needs that cannot be met with monovision. It's not uncommon for monovision patients to resort to glasses for certain sports, or computer work because of this limitation.
Your current spherical contact lens patients are possibly the best candidates for a multifocal lens correction. Over the years, these patients have relied on their contact lenses to help them maintain their binocular functionality. Night vision and depth perception are dependent on binocular vision. So why must these patients give up their lenses to maintain this functionality at the onset of presbyopia? The answer, of course, is they don't. And as their eye care practitioners we know they would most likely prefer to stay in their lenses. With the right multifocal contact lens design, you can give your presbyopic patients the opportunity to stay in contact lenses to achieve great visual acuity while maintaining natural, binocular vision.
In a comparative evaluation with 275 contact lens patients a significant percentage of the satisfied monovision patients preferred the Bausch & Lomb Multi-Focal lens for near vision, distance vision, and overall (see chart below). In fact, 73% of the satisfied monovision patients planned on continuing in the Bausch & Lomb Multi-Focal lens and not in their previous monovision correction. When practitioners were asked which lens they preferred, the response was Bausch & Lomb Multi-Focal lenses for all of their previously successful monovision wearers.*
These findings suggest that the natural binocular vision provided by a multifocal lens is preferable to visual compromises inherent in a monovision correction. This also suggests that the Bausch + Lomb Multi-Focal contact lens should be used as the fit of choice for presbyopic patients while monovision be relegated for use as a back-up.


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Online collaborative technology developer Zoho has launched its new Zoho Docs, a Web-based document management tool that's designed to integrate with Zoho's online spreadsheet, presentation, and document creation software.
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