Charlotte Garske

Charlotte "Lotte" Garske (born Charlotte Schaepe: 4 December 1906 - 16 December 1943) was a German political activist who resisted the country's Nazi Government. She was executed in on 16 December 1943.
Life.
Charlotte "Lotte" Schaepe was born in Berlin. Following a commercial apprenticeship she took a job as an accountant. When, in 1933, she married the building worker (later a builder's draftsman) Erich Garske, it was her second marriage. She already had a child from her first marriage which in 1930 had ended in divorce.
Lotte Garske was a member of the Communist Party of Germany. It was through party work, and shared membership of the Fichte Sports Association, that she had met Erich. Following abrupt régime change in January 1933 Germany was rapidly transformed into a one-party dictatorship. After the Reichstag fire at the end of February 1933, the government instantly blamed "communists" and targeted for surveillance or arrest people who had been listed as Communist party members before the rules had been changed. However, the Garskes neither stopped being communists nor emigrated. Indeed, when the Communist Party in exile smuggled people back into Germany from Moscow or Paris to work on party matters, one of the places where they might be hidden and accommodated was in the Garskes' apartment in central Berlin. As early as 1934 they secretly accommodated , a close party colleague of Robert Stamm. From 1942 their Berlin apartment was the work-place and a communications hub for "Alfred". Erich Garske was able to help Alfred in his work by producing satirical drawings and other art work for illegal party publications, notably with a news journal called "Der Friedenskämpfer" ("The Fighter for Peace"). Gestapo reports indicated that Charlotte Garske was suspected of being significantly more important to the political work of "Alfred" than her husband. She acted as a courier, delivering illegal published material to Willi Seng, a party instructor and co-ordinator in the economically and politically crucial Ruhr region. She also organised meetings of others operating on behalf of the exiled communist party central committee. "Alfred" was the code name used by Wilhelm Knöchel, an exceptionally effective communist resistance organiser.
By the end of 1944 none of the people named above was alive. Erich Garske and were arrested at the Garskes' home by the Gestapo on 30 January 1943. Charlotte was arrested on 17 February 1943. On 9 November 1943 the special "People's Court" sentenced Erich and Charlotte Garske to death. Erich was killed - sources use the verb "murdered" - on 13 December 1943, Charlotte Garske on 16 December 1943, both at the at Berlin-Plötzensee.


First Military District

The First Military District of the U.S. Army was a temporary administrative unit of the U.S. War Department that existed in the American South. The district was stipulated by the Reconstruction Acts during the Reconstruction period following the American Civil War. It only included Virginia, and was the smallest of the five military districts in terms of size. The district was successively commanded by Brigadier General John Schofield (1867–1868), Colonel George Stoneman (1868–1869) and Brigadier General Edward Canby (1869–1870).
Creation of The First Military District.
In March 1867, Radical Republicans in Congress became frustrated with President Andrew Johnson's Reconstruction policies, which, they believed, allowed too many former Confederate officials to hold public office in the South. Politically empowered Democratic Party politicians who were former Confederates would obstruct the civil rights of newly freed African Americans. For Republicans these rights, which would allow the antebellum ideology of abolition to translate to real freedom, were critical.
In response, Congressional Republicans passed a multitude of bills furthering strict Reconstruction policies known as the Reconstruction Acts, the most important of which being the Act to Provide for the More Efficient Government of the Rebel States. This act, passed on March 2, 1867, divided the former Confederate States (except for Tennessee, after it ratified the 14th Amendment) into five separate military districts. The Reconstruction Acts required that each former Confederate state hold a Constitutional Convention, adopt a new State Constitution, and ratify the 14th Amendment before rejoining the Union. The act designated Virginia as The First Military District (also referred to as Military District No. 1).
Each of these districts fell under the command of former Union Army general officers to supervise the replacement undesirable former Confederate officials and use military force to guarantee the safety of liberated African Americans and maintain peace. However, it soon became apparent that the appointed army commanders could only act as peacekeepers until the president unveiled a proper Reconstruction policy.
The military governors supervising Military District No. 1 were Major General Schofield, Major General Stoneman, and finally Brigadier General Canby until Virginia rejoined the Union in January 1870, which officially ended Reconstruction in Virginia.
Under military rule.
Under General Schofield.
President Johnson first appointed General John Schofield as the first military governor of the district. Schofield commanded the Federal Army of the Ohio and had served with General Sherman during the last year of the war. Schofield sympathized with Virginia's social and economic leaders and was skeptical of radical proposals to allow African Americans, most of whom had little or no education, to vote or participate in politics. However, he duly issued orders to register eligible white and black men and make certain that the election was properly conducted. Under his command, African American men participated willingly in Virginia's General Assembly election in 1867.
Under General Stoneman.
After Schofield became secretary of war under Johnson early in June 1868, his deputy commander in Virginia, George Stoneman, succeeded him. Unlike his predecessor, Stoneman pushed back against the Reconstruction efforts enacted by Congressional Republicans. Aligning himself with the Democratic Party, Stoneman pursued more moderate policies than the other Military Governors, which garnered him support among white Virginians.
Under General Canby.
Major General Edward Canby was assigned to the First Military District in April 1869, serving until September 1870. This assignment put Canby at the center of conflicts between Republicans and Democrats, whites and blacks, and state and federal governments. His role as Military Governor was concluded after Virginia ratified the 13th, 14th, and 15th Amendments to the U.S. Constitution. It was under Canby's term that a committee of nine leading Conservative politicians, under the chairmanship of Alexander H. H. Stuart, negotiated a compromise allowing voters to ratify the new state constitution. Once moderate Republicans and Conservatives dominated the Virginian General Assembly after its election in 1869, the 14th and 15th Amendments were ratified shortly after. Virginia was readmitted into the union in January 1869, thus ending Reconstruction in the state and Canby's tenure.
Legacy of Military Rule.
Immediate aftermath.
The period of military government in Virginia preserved for African Americans some of their hard-won guarantees of citizenship. However, the degradation of these rights occurred shortly after the end of military rule. With its readmission to the Union, the district commanders relinquished their powers under the Reconstruction Acts to the civil authorities within their commands. Therefore, Conservative Party candidates regained dominance over state legislature, and returned Virginia to control of prewar leaders.
Impact on African Americans.
During the time after military rule, African Americans merely gained minority status in the constitutional convention, in either house of the General Assembly, or in city or county government offices. However, the Constitutional right for African Americans to vote was firmly established under military rule, which lead to the election of more than twenty African Americans to Virginia's General Assembly between 1870 and 1875. While many of these African American political leaders following the end of military rule were somewhat wealthier and had more education than other African Americans, they faced many of the same difficulties and obstacles as the men who were born into slavery. They worked in jobs similar to other freedmen, such as mechanics, farmers, and ministers. However, these first African American political leaders in Virginia used the guarantee of suffrage in the 15th Amendment to their full advantage and paved the path for future leaders and further struggles for equal rights to follow in their footsteps.


Herbert v. Moore

Herbert v. Moore, Dallam 592 (1844), was a case decided by the Supreme Court of the Republic of Texas which held that property taken by Indians in a raid were not subject to the rule of postliminy and were still the property of the original owner.
Background.
On May 27, 1842 Indians stole horses and mules from P.W. Herbert in Bastrop County, Texas. Two days later a mule and other livestock was found in the possession of Indians about 30 miles from Austin. Thomas Moore and others recovered the stock after a fight, during which Moore lost his own horse. Herbert demanded his property back, but Moore refused, on the grounds that the taking of the stock for more than 24 hours stripped Herbert of title, and the recapture vested the title in Moore and those with him.
Decision.
Judge William J. Jones explained that Moore's position was based on the rule of postliminy, which was designed to handle property taken during war by an enemy. If the property is retaken within 24 hours, the original owner still maintains title, but if not retaken during that period, the original owner loses title. The question before the court was whether takings by Indians fell under this rule.
Jones noted that postliminy was a principle of international law and then examined whether Indians were separate nations for the purpose of the law. He stated that the Indians were a wandering tribe, not a nation, and that they did not claim any land nor exert sovereign authority over it. Nor had the Mexican government recognized the tribes as nations. Jones found "that, by our constitution and laws, the Indians have been reduced to a level with free negroes and mulattoes" and that they were therefore under control of the national government. Jones described the Indians as robbers, the same as pirates, and that it was not conducive to justice to allow postliminy to reward their actions.


Erich Haagensen Jaabech

Erich Haagensen Jaabech (6 December 1761 – 4 January 1845) was a Norwegian farmer who served as a representative at the Norwegian Constitutional Assembly.
Jaabech was born on Usland at Øyslebø in Vest-Agder, Norway. He was the son of Haagen Olson Usland (1721-1773) and Marte Eriksdtr. Skjævesland (1731-1790). In 1788, he married Gunhild Olsdtr. Skjævesland (1763-1844) with whom he had eight children.
He was a farmer who also worked as a teacher in Øyslebø and Holum. In 1806, he bought the farm Jaabekk in Halse parish ("Jåbekk gård i Halse ved Mandal") and established residence at that farm. He was also active as a trader, blacksmith and cooper.
He was elected to the Norwegian Constituent Assembly in 1814, representing the constituency of Mandals Amt (now Vest-Agder) together with Osmund Andersen Lømsland and Syvert Omundsen Eeg. At the Assembly, all three supported the union party ("unionspartiet").


Dickinson Dees

Dickinson Dees LLP was a law firm of the United Kingdom that traded between 1975 and 2013.
At its peak in 2005 the firm had 763 solicitors (including partners). By 2010 the firm had reduced this number to 327 solicitors through restructuring. In 2012, the firm came last in a national survey of legal professionals conducted by Rollonfriday
The firm had offices in Stockton on Tees, Leeds, Newcastle upon Tyne and London at the point it negotiated joining, Bristol based Bond Pearce. The successor firm was called Bond Dickinson and was headquartered in Bristol and then London. In November 2017, Bond Dickinson successfully negotiated joining an American law firm. The new firm is called Womble Bond Dickinson.


BG Checo International Ltd v British Columbia Hydro and Power Authority

BG Checo International Ltd v British Columbia Hydro and Power Authority, [1993] 1 SCR 12 is a leading decision by the Supreme Court of Canada. The Court held that there is a "prima facie" presumption that a claimant is able to sue concurrently in tort and contract where sufficient grounds exist. Still, liability in tort will still be subject to an exemptions or conditions set out in a contract.
Background.
British Columbia Hydro and Power Authority called for tenders to erect power lines. BG Checo International Ltd. was interested in making a tender and so did a survey of the land by helicopter. On viewing the area they noted that the area was in the process of being clear-cut. BG Checo issued a tender and won. The tender was incorporated into the contract and included terms stating that BG Checo would have no part in clearing a right-of-way to the land. Once the agreement was made no further clearing was done which resulted significant difficulties for BG Checo.
BG Checo sued in tort of negligent misrepresentation and in the alternative breach of contract. The key issue is the case was whether the terms of the contract precluded BG Checo from suing in tort.
Ruling of the Court.
La Forest and McLachlin wrote for the majority. Citing "Central Trust Co v Rafuse", the Court stated that "where a given wrong "prima facie" supports an action in contract and in tort, the party may sue in either or both, except where the contract indicates that the parties intended to limit or negative the right to sue in tort".
The Court considered three situations where a party can sue in tort and contract.
The Court found that the current situation fell into the third category and so BG Checo was able to sue in both tort and contract.


Council of Two Hundred

The Councils of Two Hundred ("Rat der Zweihundert" or "Conseil des Deux-Cents") were the legislative authorities in four Swiss cities (Zürich, Bern, Fribourg, Basel), as well as in the independent Republic of Geneva prior to the French Revolution. Although the council in Geneva dates to 1526, the councils were medieval in origin. They sometimes contained as many as 300 members.
They were superseded by smaller legislatures with a less specific name of "Grand Council" ("Grosser Rat" or "Grand Conseil").


Kawakita v. United States

Kawakita v. United States, 343 U.S. 717 (1952), is a United States Supreme Court case in which the Court ruled that a dual U.S./Japanese citizen could be convicted of treason against the United States for acts performed in Japan during World War II. Tomoya Kawakita, born in California to Japanese parents, was in Japan when the war broke out and stayed in Japan until the war was over. After returning to the United States, he was arrested and charged with treason for having mistreated American prisoners of war. Kawakita claimed he could not be found guilty of treason because he had lost his U.S. citizenship while in Japan, but this argument was rejected by the courts (including the Supreme Court), which ruled that he had in fact retained his U.S. citizenship during the war. Originally sentenced to death, Kawakita's sentence was commuted to life imprisonment, and he was eventually released from prison, deported to Japan, and barred from ever returning to the United States.
Background.
 was born in Calexico, California, on September 26, 1921, of Japanese-born parents. He was born with U.S. citizenship due to his place of birth, and also Japanese nationality via his parents. After finishing high school in Calexico in 1939, Kawakita traveled to Japan with his father (a grocer and merchant). He remained in Japan and enrolled in Meiji University in 1941. In 1943, he registered officially as a Japanese national.
Kawakita was in Japan when the attack on Pearl Harbor drew the United States and Japan into World War II. In 1943, he took a job as an interpreter at a mining and metal processing plant which used Allied prisoners of war (POWs) as laborers. By early 1945, the population of the POW camp included about four hundred captured American troops. After the end of the war, Kawakita renewed his U.S. passport, explaining away his having registered as a Japanese national by claiming he had acted under duress. He returned to the U.S. in 1946 and enrolled at the University of Southern California.
In October 1946, a former POW saw Kawakita in a Los Angeles department store and recognized him from the war. He reported this encounter to the FBI, and in June 1947, Kawakita was arrested and charged with multiple counts of treason arising from alleged abuse of American POWs.
Trial and appeal.
At Kawakita's trial, presided over by U.S. District Judge William C. Mathes, the defense conceded that Kawakita had acted abusively toward American POWs, but argued that his actions were relatively minor, and that in any event, they could not constitute treason against the United States because Kawakita was not a U.S. citizen at the time, having lost his U.S. citizenship when he confirmed his Japanese nationality in 1943. The prosecution argued that Kawakita had known he was still a U.S. citizen and still owed allegiance to the country of his birth—citing the statements he had made to consular officials when applying for a new passport as evidence that he had never intended to give up his U.S. citizenship.
Judge Mathes's instructed the jury that if they found that Kawakita had genuinely believed he was no longer a U.S. citizen, then he must be found not guilty of treason. During the course of their deliberations, the jury reported several times that they were hopelessly deadlocked, but the judge insisted each time that they continue trying to reach a unanimous verdict. In the end—on September 2, 1948—the jury found Kawakita guilty of eight of the thirteen counts of treason against him, and he was sentenced to death. As a consequence of his conviction for treason, Kawakita's U.S. citizenship was also revoked. In passing sentence, Mathes said: "Reflection leads to the conclusion that the only worthwhile use for the life of a traitor, such as this defendant has proved to be, is to serve as an example to those of weak moral fiber who may hereafter be tempted to commit treason against the United States."
Kawakita appealed to a three-judge panel of the Ninth Circuit Court of Appeals, which unanimously upheld the verdict and death sentence. "Certiorari" was granted by the United States Supreme Court, and oral arguments before the Supreme Court were heard on April 3, 1952.
Opinion of the Court.
In a 4–3 decision issued on June 2, 1952, the Supreme Court upheld Kawakita's treason conviction and death sentence. The Court's opinion was written by Associate Justice William O. Douglas, joined by Associate Justices Stanley F. Reed, Robert H. Jackson, and Sherman Minton.
The Court's majority held that the jury in Kawakita's trial had been justified in concluding that he had not lost or given up his U.S. citizenship while he was in Japan during the war. The Court added that an American citizen owed allegiance to the United States, and could be found guilty of treason, no matter where he lived—even for actions committed in another country that also claimed him as a citizen. Further, given the flagrant nature of Kawakita's actions, the majority found that the trial judge had not acted arbitrarily in imposing a death sentence.
Dissent.
Chief Justice Fred M. Vinson authored a dissenting opinion, which was joined by Associate Justices Hugo Black and Harold H. Burton. The dissent concluded that "for over two years, [Kawakita] was consistently demonstrating his allegiance to Japan, not the United States. As a matter of law, he expatriated himself as well as that can be done." On this basis, the dissenting justices would have reversed Kawakita's treason conviction.
Subsequent developments.
On October 29, 1953, President Dwight D. Eisenhower commuted Kawakita's sentence to life imprisonment plus a $10,000 fine. After the commutation of his sentence, Kawakita was transferred to the Alcatraz Federal Penitentiary. Ten years later, on October 24, 1963, President John F. Kennedy—in what would be one of his last official acts before his assassination—ordered Kawakita released from prison on the condition that he leave the United States and be banned from ever returning. Kawakita flew to Japan on December 13, 1963, and reacquired Japanese citizenship upon his arrival. In 1978, Kawakita sought permission to travel to the United States to visit his parents' grave, but his efforts were unsuccessful. As of late 1993, he was living quietly with relatives in Japan.


Nicolai Schejtli

Nicolai Schejtli (24 June 1753 – 4 April 1824) was a Norwegian mining official and politician.
Nicolai Schejtli was born is Christiania now Oslo. His father was Public procurator and later Magistrate in Øvre Romerike.
From 1802, Nicolai Schejtli served in Buskerud as commissioner of the Kongsberg Silver Mines ("Kongsberg Sølvverk") and Blaafarveværket mining company at Åmot in Modum.
He represented Drammen at the Norwegian Constituent Assembly at Eidsvoll in 1814. He was also a member of the Parliament of Norway where he represented Drammen during 1818.


Amnesty Act

The Amnesty Act of 1872 was a United States federal law passed on May 22, 1872, which reversed most of the penalties imposed on former Confederates by the Fourteenth Amendment, adopted on July 9, 1868. Section 3 of the Fourteenth Amendment prohibited the election or appointment to any federal or state office of any person who had held any of certain offices and then engaged in insurrection, rebellion, or treason. However, the section provided that a two-thirds vote by each House of the Congress could override this limitation. The 1872 act was passed by the 42nd United States Congress and the original restrictive Act was passed by the United States Congress in May 1866.
Specifically, the 1872 Act removed office-holding disqualifications against most of the secessionists who rebelled in the American Civil War, except for "Senators and Representatives of the thirty-sixth and thirty-seventh Congresses, officers in the judicial, military, and naval service of the United States, heads of departments, and foreign ministers of the United States."
In the spirit of the act, then United States President Ulysses S. Grant, by proclamation dated June 1, 1872, directed all district attorneys having charge of proceedings and prosecutions against those who had been disqualified by the Fourteenth Amendment to dismiss and discontinue them, except as to persons who fall within the exceptions named in the act. President Grant also pardoned all but 500 former top Confederate leaders.
The 1872 Act affected over 150,000 former Confederate troops who had taken part in the American Civil War.


La Mon restaurant bombing

The La Mon restaurant bombing was an incendiary bomb attack by the Provisional Irish Republican Army (IRA) on 17 February 1978 and has been described as one of the worst atrocities of the Troubles. It took place at the La Mon House hotel and restaurant, near Belfast.
The IRA left a large incendiary bomb, containing a napalm-like substance, outside one of the restaurant's windows. There were 450 diners, hotel staff and guests inside the building. The IRA said that they tried to send a warning from a public telephone, but were unable to do so until nine minutes before the bomb detonated. The blast created a fireball, killing 12 people and injuring 30 more, many of whom were severely burnt. Many of the injured were treated in the Ulster Hospital in nearby Dundonald.
A Belfast native, Robert Murphy, received twelve life sentences in 1981 for the manslaughter of those who were killed. Murphy was freed from prison on licence in 1995.
Bombing.
Warnings.
On 17 February 1978, an IRA unit planted an incendiary bomb attached to petrol-filled canisters on meat hooks outside the window of the Peacock Room in the restaurant of the La Mon House Hotel, located at Comber, County Down, about southeast of central Belfast. After planting the bomb, the IRA members tried to send a warning from the nearest public telephone, but found that it had been vandalised. On their way to another telephone, they were further delayed when forced to stop at an Ulster Defence Regiment (UDR) checkpoint.
By the time they were able to send the warning, only nine minutes remained before the bomb exploded at 21:00. The Royal Ulster Constabulary (RUC) base at Newtownards had received two further telephone warnings at 20:57 and 21:04. By the time the latter call came in, it was too late. When an officer telephoned the restaurant to issue the warning he was told "For God's sake, get out here – a bomb has exploded!" It has been stated that the IRA were targeting RUC officers they believed were meeting in the restaurant that night, but had got the wrong date and that the meeting of RUC officers had taken place exactly a week before.
Explosion and fireball.
That evening the two main adjoining function rooms, the Peacock Room and Gransha Room, were packed with people of all ages attending dinner dances. Including the hotel guests and staff, there was a total of 450 people inside the building. The diners had just finished their first course when the bomb detonated, shattering the window outside of which it was attached and vaporising the canisters. The explosion created an instantaneous and devastating fireball of blazing petrol, high and wide, which engulfed the Peacock Room. Twelve people were killed, having been virtually burnt alive, and some 30 others were injured, many critically. Some of the wounded lost limbs, and most received severe burns. One badly burnt survivor described the inferno inside the restaurant as "like a scene from hell" whilst another, who lost her daughter Elizabeth and son-in-law, Ian McCracken, said the blast was "like the sun had exploded in front of my eyes". There was further pandemonium after the lights went out and choking black smoke filled the room. The survivors, with their hair and clothing on fire, rushed to escape the burning room. It took firemen almost two hours to put out the blaze. The dead were all Protestant civilians. Half were young married couples. Most of the dead and injured were members of the Irish Collie Club and the Northern Ireland Junior Motor Cycle Club, holding their yearly dinner dances in the Peacock Room and Gransha Room, respectively. The former took the full force of the explosion and subsequent fire; many of those who died had been seated nearest the window where the bomb had gone off. Some of the injured were still receiving treatment 20 years later.
The device was a small blast bomb attached to four large petrol canisters, each filled with a home-made napalm-like substance of petrol and sugar. According to a published account by retired RUC Detective Superintendent Kevin Benedict Sheehy, this type of device had already been used by the IRA in more than one hundred attacks on commercial buildings before the La Mon attack. This was designed to stick to whatever it hit, a combination which caused severe burn injuries. The victims were found beneath a pile of hot ash and charred beyond recognition, making identity extremely difficult as their individual features had been completely burned away. Some of the bodies had shrunk so much in the intense heat, it was first believed that there were children among the victims. One doctor who saw the remains described them as being like "charred logs of wood".
Aftermath.
The day after the explosion, the IRA admitted responsibility and apologised for the inadequate warning. The hotel had allegedly been targeted by the IRA as part of its firebomb campaign against commercial targets. Since the beginning of its campaign, it had carried out numerous such attacks with the stated goal of harming the economy and causing disruption, which it believed would put pressure on the British Government to withdraw from Northern Ireland. The resulting carnage brought quick condemnation from other Irish nationalists, with one popular newspaper comparing the attack to the 1971 McGurk's Bar bombing. Sinn Féin president Ruairí Ó Brádaigh also strongly criticised the operation. In consequence of the botched warning, the IRA Army Council gave strict instructions to all units not to bomb buses, trains or hotels.
As all the victims had been Protestant, many Protestants saw the bombing as a sectarian attack against their community. Some unionists called for the return of the death penalty, with one unionist politician calling for republican areas to be bombed by the Royal Air Force. The same day, about 2,000 people attended a lunchtime service organised by the Orange Order at Belfast City Hall. Belfast International Airport shut for an hour, while many workers in Belfast and Larne stopped work for a time. Workers at a number of factories said they were contributing a half-day's pay to a fund for the victims. Ulster loyalists criticised the then Secretary of State for Northern Ireland, Roy Mason, for his "complacent attitude" to the attack. He stated that the explosion was "an act of criminal irresponsibility" performed "by remnants of IRA gangs". He also stated that the IRA was on the decline.
A team of 100 RUC detectives was deployed in the investigation. As part of the investigation, 25 people were arrested in Belfast, including Gerry Adams. Adams was released from custody in July 1978. Two prosecutions followed. One Belfast man was charged with twelve murders but was acquitted. He was convicted of IRA membership but successfully appealed. In September 1981, another Belfast man, Robert Murphy, was given twelve life sentences for the manslaughter of those who died. Murphy was freed on licence in 1995. As part of their bid to catch the bombers, the RUC passed out leaflets which displayed a graphic photograph of a victim's charred remains.
In 2012, a news article quoting unnamed Republican sources stated that two members of the IRA bombing team, including the getaway driver, were double agents working for the Special Branch. According to the article, one of the agents was Denis Donaldson. That year, Northern Ireland's Historical Enquiries Team (HET) completed a report on the bombing. It revealed that important police documents, including interviews with IRA members, have been lost. A number of the victims' families criticised the report and called for a public inquiry. They stated the documents had been removed to protect certain IRA members. Unionist politician Jim Allister, who had been supporting the families, said: "There is a prevalent belief that someone involved was an agent and that is an issue around which we need clarity".


Canada (Minister of Citizenship and Immigration) v Vavilov

Canada (Minister of Citizenship and Immigration) v Vavilov, 2019 SCC 65, is a decision of the Supreme Court of Canada that revised the standard of review in Canadian administrative law. Legally, "Vavilov" established a presumption that reasonableness is the applicable standard of review in most cases. Factually, the decision allowed Alexander Vavilov, born in Canada to covert Russian agents, to be a Canadian citizen.
Facts.
"Vavilov" concerns the proper interpretation of a provision of the "Citizenship Act" as applied to Alexander Vavilov. Vavilov was born in Toronto to parents who, it later turned out, were covert Russian agents working under the auspices of the Illegals Program. Their story became the subject of "The Americans".
The question was whether the "Citizenship Act" barred Vavilov from being considered a citizen under the "Citizenship Act", which prevents children of a "diplomatic or consular officer or other representative or employee in Canada of a foreign government" from receiving Canadian citizenship. Canada's Registrar of Citizenship held that the statute did bar Vavilov from receiving citizenship. The Federal Court agreed with the Registrar; Vavilov's appeal to the Federal Court of Appeal was allowed.
Background.
In Canada, before a court assesses whether the decision of an administrative tribunal was lawful or not, it decides what standard of review to apply to that decision. To determine the standard of review, in essence, is to decide how much scrutiny the reviewing court will apply to the decision.
From the 1980s to the early 2000s, Canadian courts had three standards of review to choose from: patent unreasonableness, under which the reviewing court would only overturn the decision if it was plainly defective; reasonableness simpliciter, under which the reviewing court would determine if the reasons given by the administrative decisionmaker in fact supported its decision; and correctness, in which the reviewing court would substitute its own judgment for the decisionmaker's.
The "patent unreasonableness" standard was eliminated in "Dunsmuir v New Brunswick", which established two standards of review: reasonableness, a more deferential standard; and correctness, a non-deferential standard. Under "Dunsmuir", a reviewing court would determine which standard applied by applying a multi-part test, which considered, among other things, which standard of review had been applied in the past, and whether the question at issue fell into a set of categories in which correctness review was appropriate.
Supreme Court.
The Supreme Court, in a 343-paragraph judgment, agreed with Vavilov and quashed the Registrar's decision. It determined that the Registrar's decision was unreasonable (in the technical sense described above). Thus, Vavilov was able to regain his Canadian citizenship. The court, in holding for Vavilov, established a new framework for determining the standard of review in Canadian administrative law.
First, the court decided that reasonableness was the default standard of review. It then outlined two kinds of exceptions to that general rule, under which the correctness standard would apply instead. The first exception is where the legislature has indicated that correctness is appropriate. This may be case where the relevant statute explicitly defines the standard of review, or where the statute allows a litigant to appeal a decision of an administrative tribunal to a court (instead of using judicial review). The second exception is where the rule of law requires a correctness standard. The court held that this will be the case when constitutional questions are at issue, when the administrative decision involves a "general question of law of central importance to the legal system as a whole", or when the decision under review pertains to the jurisdiction of two or more tribunals.


Edmund de Clay

Edmund de Clay (died after 1389) was an English-born lawyer and judge who served as Lord Chief Justice of Ireland and Chief Justice of the Irish Common Pleas.
He was born in Nottinghamshire, and later became a landowner there. By 1383, he had the reputation for being "learned in the law" and in that year he became Serjeant-at-law. He is known to have been most reluctant to take up this office, probably because it would involve him in heavy expenses, and he did so only after King Richard II issued a warrant commanding de Clay, along with two other leading advocates, John Hill and Sir John Cary, to be admitted to that rank by a specified day.
In 1385 he was sent to Ireland with a large retinue to take up office as Lord Chief Justice of the Common Pleas. He was transferred to the more senior office of Lord Chief Justice of Ireland in 1386. He had returned to England by 1389, when he was living on his estates in Nottinghamshire; later he is recorded as sitting on a commission of oyer and terminer. His date of death is not recorded,


Herbert Allen Farmer

Herbert Allen Farmer (March 9, 1891 – January 12, 1948), was an American criminal who, with his wife Esther, operated a safe house for underworld fugitives from the mid-1920s to 1933.
In the 1920s his farm in southwest Missouri was safe harbor for bank robbers and other criminals of the Cookson Hills region such as Harvey Bailey, Frank Nash, Wilbur Underhill, "Big Bob" Brady and the Holden-Keating Gang. In the Public Enemy era, as organized crime strengthened and expanded in the United States, the farm became part of a network of safe houses for gangsters along "the midwest crime corridor."
On June 16, 1933, Herbert and Esther Farmer were involved in the plan which set into motion the Kansas City Massacre, "a pivotal event in Depression-era crime." With five others, they were convicted of conspiracy to free a federal prisoner, Frank Nash, in January 1935.
Life.
A career grifter and gambler, Herbert Farmer was in and out of local jails in Texas, Missouri and Oklahoma for much of his youth. In about 1910 his family settled in Webb City, Missouri, a community near Joplin in the then-booming lead- and zinc-mining region known as the Tri-State district. As an adult Farmer made the Joplin area his home.
In Webb City, Farmer's family became acquainted with the Barker family, and for a while Ma Barker's sons "were practically raised by Herb Farmer's mother." Though the Barkers left Webb City for Tulsa, Oklahoma around 1915, Fred Barker returned often to visit the Farmers, and he and Herb Farmer remained friends, though Farmer was perhaps 13 years older. The FBI's official summary of the Karpis-Barker gang's career stated, "It is safe to assume that Fred Barker received considerable education in the school of crime from Farmer," and later an agent noted that "Barker and Karpis are known to be henchmen (especially Barker) of Herbert A. Farmer."
In 1916 Farmer began serving a five-year sentence for assault with intent to kill in the rehabilitation-oriented Oklahoma State Reformatory, but in a few months he was transferred to the state penitentiary. During this time he schooled younger inmates in the ways of pickpocketing and con games and in the penitentiary made friends with veteran bank and train robber Jelly Nash. He served less than two years and upon his release headed west, adding to his record more arrests for assault, larceny and swindling in Colorado, California, Utah and Texas.
In about 1927 he and his wife bought a farm of roughly south of Joplin, Missouri. Deafy Farmer's farm was not only a safe place to "cool off," it was "one of the best underworld postal offices in the country." The Joplin safe house operated with no recorded interference from authorities until June 1933, when the Kansas City Massacre drew federal attention.
When Fred Barker or his partner Alvin Karpis shot to death a county sheriff in West Plains, Missouri in December 1931, Barker took Karpis, as well as his mother and her boyfriend, across the state to Herb Farmer's place. When Farmer was indicted on conspiracy charges in 1934, the gang gave him $2500 of the Hamm kidnapping ransom to help pay his legal expenses. However, during questioning in respect to that crime Farmer, unprodded, twice slyly wondered aloud if Fred Barker might have been involved in the Union Station killings.
Farmer made his official living in the hotels and gambling halls of two nearby "safe cities," the resort town of Hot Springs, Arkansas and Kansas City, with occasional forays into Reno, Nevada and St. Paul, Minnesota, where at the time of his arrest in July 1933 he was negotiating for control of a lucrative craps concession. Though Hot Springs chief of detectives Dutch Akers knew Farmer to be "the number 1 man for the [St. Paul-Kansas City-Hot Springs] gang organization at Joplin," and though six months before his arrest for obstruction of justice in the Kansas City Massacre case he "took an old man and his wife from Hot Springs to Reno, where he cleaned them for $50,000 in the race track con," when he was arrested he was trading chickens and butter for groceries and he alone of the conspiracy defendants could not make bond.
Deafy Farmer was indeed almost completely deaf. In the 1934 conspiracy trial all of the defendants took the stand, except Deafy Farmer; he was so deaf, his wife said, that questioning him would be useless. In 1933 he was described to the FBI as "a very dangerous man, a killer, and his best known line is the con game... his favorite weapon being the knife."
Farmer served two years in Alcatraz for his participation in the conspiracy to free Jelly Nash. After his release he returned to Missouri. He and Esther sold the farm and moved into Joplin, where they lived until his death on January 12, 1948.
In October 1966 Esther married Harvey Bailey, "dean of the American bank robbers," after a year-long courtship. She died in 1981.
Role in the Kansas City Massacre conspiracy.
Background.
Federal agents had been on the trail of Jelly Nash for three years, since his escape from the federal penitentiary at Leavenworth, Kansas in 1930. At noon on June 16, 1933, Nash was finishing a beer inside the White Front cigar store and pool hall on the main street of Hot Springs, Arkansas when two special agents of the Department of Justice and the police chief of McAlester, Oklahoma grabbed him, hustled him into a waiting car and drove away. Their goal was to get Nash from Hot Springs back to Leavenworth to finish his sentence for armed robbery.
Dick Galatas, owner of the White Front and "the official representative of the gangster world in Hot Springs," went directly to the police station in City Hall to the office of Dutch Akers, chief of detectives. Dutch Akers was deeply entangled with the racketeering operations of Hot Springs and at the same time was an informant for the FBI. It was he who, that morning, had notified his contact that Nash was in Hot Springs and at the White Front. Akers began calling every police station between Hot Springs and Little Rock to report that a visiting businessman named George Miller—the name Nash went by around town—had been kidnapped. He and Galatas left the police station around 1 p.m. and Galatas went to collect Jelly Nash's wife Frances.
In Benton, Arkansas, halfway to Little Rock, the agents' car was halted by a police roadblock: "three men with rifles and sawed-off shotguns." They were stopped again at the edge of Little Rock by "two police cars with riot guns." The agents and Nash were aware that the stops were delay tactics. "I hope we make it out of this state alive," Nash said, cryptically.
At 2:34 p.m., from Galatas's house in Hot Springs, Chief Akers called the Little Rock police station. The officer in charge explained that there had been no kidnapping, that a fugitive was simply being returned to prison. The officer told Akers that the car had turned west at Little Rock, onto "the Joplin road." Until then Akers and Galatas had not been certain who had taken Nash, or where they were going.
Galatas had brought Frances Nash to a neighbor's house to make phone calls. At 2:50 p.m., at Galatas's direction Mrs Nash called nightclub owner Louis "Doc" Stacci in Chicago. Stacci's subsequent phone calls to Fritz Mulloy, a friend of Verne Miller's in Kansas City, drew Miller into the plan to free Nash. Mrs Nash called Esther Farmer in Joplin.
Thirty minutes west of Little Rock the agents stopped in the town of Conway and called Ralph Colvin, the special agent in charge in Oklahoma City who had given the go-ahead to apprehend Nash, and let him know they were being tracked. Colvin told them to proceed to Fort Smith and call again from there. The agents had left the Little Rock officers "with the impression that we were proceeding to Joplin, Mo., but at a given point we left the Joplin road and dropped into Fort Smith."
Galatas and Frances Nash hired an airplane to fly Frances and her young daughter to Joplin. Mrs. Nash was afraid to fly in the Ryan B-1 monoplane. Galatas tried to calm her fears by telling her it was just like The Spirit of St. Louis, but she insisted he come with her. They arrived in late afternoon, at 6:20 p.m. Deafy Farmer met them and drove them to his farm.
At about the same time Galatas and Frances Nash arrived in Joplin, the federal agents arrived in Fort Smith and called Colvin. He told them to abandon the car and catch the 8:30 p.m. train to Kansas City. Colvin then called Reed Vetterli, the special agent in charge at Kansas City, and told him the new information. Shortly after Colvin and Vetterli spoke, "Mrs. Galatas called Galatas on the telephone and advised him that Nash was not to be brought to Joplin, but that the federal men were taking him from Fort Smith, Ark., by train "on in." By the time the agents and their handcuffed charge arrived at the station platform, their secret had already reached the press wires, and "at 8:46 p.m., 8 minutes after the train pulled out of Ft. Smith, a phone call was made from Ft. Smith to [Mrs. Nash's neighbor's house in] Hot Springs."
Joplin.
Around 9 p.m. Farmer and Galatas left the farm and drove into Joplin. "Galatas and Farmer went down town for the avowed purpose of seeing if they could find out if Nash had been brought to Joplin, saying that they would do what they could to get Jelly back to his wife; but when they returned, they reported that he was not in town." Galatas called his wife in Hot Springs from Frank Vaughn's Midway Drugstore in town at 9:37 p.m. "It is apparent Galatas and others... were making plans up to that hour to have appropriate assistance at Joplin to release Nash; that was evidently the reason why [Stacci] at Chicago was trying to reach Miller and the reason [Galatas and Mrs. Nash] flew to Joplin."
"At 10:09 pm the Hot Springs number [which had received the 8:46 call from Fort Smith] called Farmer's house." At 10:17 p.m., Esther Farmer called Verne Miller's house in Kansas City and spoke to Miller's girlfriend, Vivian Mathias. "Mrs. Farmer was heard to say over the telephone on June 16th: 'They got by us here at Joplin. We watched from every angle but they got by us.'" At 12:05 a.m. June 17, Verne Miller called Herb Farmer's house from Union Station, Kansas City. Galatas told him what time the train would arrive at Union Station. Miller's phone calls earlier that evening were first to John Lazia in Kansas City, then to associates in Chicago and New York and to Harry Sawyer's Green Lantern restaurant in St. Paul to try to interest the Karpis-Barker gang, but on such short notice he could find no out-of-town takers (the Barkers were occupied at the time with the Hamm kidnapping) and the Kansas City mob did not want to get involved.
At 6 a.m. June 17, Deafy Farmer drove Galatas and the aviator from the Connor Hotel in Joplin back to the airport, and returned home. Dutch Akers later told his FBI contact that as soon as Galatas reached Hot Springs "he ordered every gangster in town to leave." At 9:51 a.m. a call was made from a pay phone in Hot Springs to the Farmers' house. When the Joplin police chief heard the news of the shootings at Union Station he immediately suspected Herb Farmer had something to do with it. He and detectives arrived at the farm at noon, but the Farmers and Mrs. Nash had fled.
Arrest and trial.
Farmer went to Kansas City. He spent several days gambling in the Majestic Hotel, then returned to the farm. In hiding and out of money, he traded chickens for groceries with a family friend, bootlegger Frank Vaughn. In early July Vaughn urged him to give himself up. Farmer said he would when the weather turned cooler, that he hated to be in jail in such hot weather.
When Farmer received his phone bill on July 8 and saw the long distance record for June 16, he sent Esther to the Joplin police station to tell Chief of Police Ed Portley that he would like to speak with him. Portley came out and arrested him at home. Esther Farmer came to visit her husband in the jail and was arrested there. Frances Nash was arrested July 11 in Illinois. Galatas eluded apprehension until September 22. The warrant for Galatas's arrest charged that he had "conspired to cause the escape of Frank Nash at Joplin, Missouri."
Deafy Farmer and his wife, Dick Galatas and his wife, Frances Nash, Vivian Mathias, Doc Stacci of Chicago and Fritz Mulloy of Kansas City were indicted by a federal grand jury in Kansas City on October 24, 1934, and charged with three counts of conspiracy to aid "the escape of [a federal] prisoner properly committed to the custody of the Attorney General." At the close of evidence counts two and three — conspiracy to harbor a federal prisoner and conspiracy to rescue a federal prisoner — were dropped. Mrs Nash testified for the government and charges against her were dismissed. The rest were convicted on the remaining count, conspiracy to free a federal prisoner, on January 4, 1935.
The flurry of phone calls on June 16 and early June 17, their times and connections, were the basis of the prosecution's case. They were also the basis of the defense's case.
The maximum penalty for conspiracy was two years and a fine of $10,000; all four men were assessed the maximum and all four were remanded to Leavenworth Federal Penitentiary. Farmer, Galatas and Mulloy were later transferred to the new federal prison in California, Alcatraz. The three women were sentenced to three years' probation and fined $5,000 each.


Sale of Shin Corporation to Temasek Holdings

The 2006 sale of the Shinawatra family's share of Shin Corporation (ShinCorp) to Temasek Holdings caused great controversy in Thailand. The sale was in response to long-standing criticisms that the Shinawatra family's holdings created a conflict of interest for Thai Prime Minister Thaksin Shinawatra. Criticisms of the sale focused on the insistence by Thaksin and a compliant government that the transaction was exempt from capital gains tax (as per Revenue Department and Stock Exchange of Thailand regulations, later determined by Thai courts not to be legal), the fact that the Thai company was sold to a Singaporean company, and the fact that the Thai law regarding foreign investments in the telecom sector had been amended just prior to the sale (although the amendment had been proposed since 2001). Thaksin's sale also impacted holdings, among other parties, of the Crown Property Bureau that had an investment in Siam Commercial Bank that held ShinCorp stock.
The sale of Shin Corporation to Temasek Holdings.
On 23 January 2006, the Thai Telecommunication Act (2006) became effective, raising the limit on foreign holdings in telecom companies to 49 percent. The act replaced the Telecom Business Law, which took effect in November 2001, that put the foreign investment cap at 25 percent. At the time, AIS was 49 percent owned by the Shinawatra family. Competitors DTAC and TA Orange were 40 percent owned by Norway's Telenor and 49 percent owned by France's Orange. The law was not retroactive, thus DTAC and TA Orange criticised the government for discriminating against foreign investors and urged it to increase the cap.
On Monday, 23 January 2006, the Shinawatra family sold its remaining 49.6 percent stake in Shin Corporation to two nominees of Temasek Holdings (Cedar Holdings and Aspen Holdings). The Shinawatra and Damapong (Potjaman's maiden name) families netted about 73 billion baht (about US$1.88 billion). In accordance with Thai tax laws, they did not have to pay capital gains tax.
In an unrelated transaction, the two families had earlier not paid taxes when Thaksin transferred shares to his sister Yingluck Shinawatra and his wife, Potjaman Shinawatra, transferred shares to her brother Bannapoj Damapong. The tax exemption was granted on grounds that the transfer, at a par value of 10 baht, took place through the stock market.
Although the tax exemption was legal, the sale drew heavy criticism over Thaksin's ethics on the grounds that Shin Corp, a dominant player in Thailand's information technology sector, would be sold to an investment arm of the Government of Singapore.
The transaction was conducted via several holding companies, including Cypress Holdings, Kularb Kaew, and Cedar Holdings. Cypress Holdings, a unit of Temasek, owned 49 percent of the shares of Kularb Kaew, but had 90 percent of the voting rights. Kularb Kaew owned 41.1 percent of Cedar Holdings. Cedar Holdings held a 54.54 percent stake in Shin Corp. Indirectly, Kularb Kaew also directly owned another 22.4 percent of Shin Corp.
Investigation.
The Thailand Securities and Exchange Commission (SEC) investigated the transaction. "The investigation concluded that Prime Minister Thaksin Shinawatra and his daughter Pinthongta are clear from all wrongdoing," said SEC secretary-general Thirachai Phuvanatnaranubala on 23 February 2006. However, the SEC did find that Thaksin's son, Panthongtae, violated rules with regard to information disclosure and public tender offers in transactions between 2000 and 2002. He was fined six million baht (about US$150,000). "The case is not severe because Panthongtae did inform the SEC but his report was not totally correct" said the SEC's deputy chief Prasong Vinaiphat.
Allegations of insider trading by the Shinawatra family, Shin Corporation Corp executives, and major shareholders were also investigated. No irregularities were found.
Controversy.
The transaction made the prime minister the target of accusations that he was selling an asset of national importance to a foreign entity, and hence selling out his nation. The Democrat Party spokesman called Thaksin worse than Saddam for not protecting the Thai economy from foreigners: "Dictator Saddam, though a brutal tyrant, still fought the superpower for the Iraqi motherland." Supporters, however, counter that Thailand's mobile phone industry is highly competitive, and that little criticism was raised when the Norwegian firm Telenor acquired Total Access Communications, the country's second largest operator. Democrat Party leader Abhisit Vejjajiva had criticised Thaksin earlier for not sufficiently opening up the Thai telecom sector to foreigners. Supporters further counter that the complete sale of Shin Corporation by the Shinawatra-Damapong families had been a long-standing demand of some public groups, as it would allow Thaksin to undertake his duties as prime minister without accusation of conflicts of interest.
The controversy surrounding the sale gave additional momentum to an already-planned anti-Thaksin rally, which took place on 4–5 February at the Royal Plaza, near the parliament building and the royal palace. At least 20,000 protesters, led by media figure Sondhi Limthongkul, gathered demanding the resignation of the prime minister, and submitted a petition to the Privy Council chairman General Prem Tinsulanonda and the Office of His Majesty's Principal Private Secretary, intended for King Bhumibol Adulyadej. Rallies also took place in several southern provinces.
The resulting political turmoil forced Thaksin to order the dissolution of the lower house on 24 February 2006.
Use of nominees.
Kularb Kaew and Cedar Holdings were holding companies used to acquire Shin Corp. Kularb Kaew was, in turn, owned by a small group of Thai nominee shareholders, including Pong Sarasin, a son of the former Thai prime minister and the brother of Arsa Sarasin, King Bhumibol's principal private secretary. Other owners of Cedar are Temasek and Siam Commercial Bank, in which King Bhumibol's Crown Property Bureau has a controlling stake. SCB also played a crucial role advising and providing financial support for the deal.
This use of local nominees of foreign owners was attacked by some anti-Thaksin groups as a method to get around laws limiting foreign ownership of Thai companies. Subsequent investigations found that Thai nominees owned 24.1 percent of all shares on the Thai stock exchange, and up to 36 percent of all shares in the technology sector. Efforts to clamp down on use of Thai nominees could potentially cause a significant outflow of capital from Thailand.
After the coup.
On 16 October 2006, nearly a month after a military junta overthrew the government of Thaksin Shinawatra in a coup, Temasek issued a statement to signal the eventual reduction in its holding in Shin Corp. However, the government said that it would continue with its legal action to follow up on its investigation of whether Kularb Kaew is a nominee of Temasek.
Chairman Pong Sarasin was later removed from the board of directors, and replaced by Tongnoi Tongyai, the private secretary of Crown Prince Maha Vajiralongkorn. The Crown Prince's office later declared that Tongyai had never been the secretary of the crown prince, but was only a low ranking officer in the office.
The junta's interpretation of the Foreign Business Act of 1999, which defines nominees and limits foreign investment in Thai companies, could have far reaching consequences for foreign investment in Thailand.
5th arrest warrant.
Supreme Court Criminal Division for Holders of Political Positions Judge Pongphet Vichitchonchai (of a nine-judge panel, with the concurrence of Justice Pornpetch), on 15 October 2008, issued a fifth arrest warrant against Thaksin, for failure to appear at the hearing of his "Sale of Shin Corporation to Temasek Holdings" case, due to self-imposed exile in London.


Godfrey de Foljambe

Sir Godfrey de Foljambe (born 1317 died 29 May 1376, Bakewell, Derbyshire) was a prominent landowner and politician in fourteenth-century England, who was a Baron of the Exchequer and chief steward of the duchy of Lancaster. He went on to have a successful career as an Irish judge, including three years as Lord Chief Justice of Ireland. He was initially a servant of Philippa of Hainault before becoming a prominent member of the affinity of her son, John of Gaunt, Duke of Lancaster. His tomb can still be seen at All Saints Church, Bakewell.
He was born in Tideswell, Derbyshire in 1317, the fourth son of Sir Thomas de Foljambe (ca. 1282 - ca. 1326) and Alice Foljambe. The Foljambe family were Lords of the Manor of Tideswell and also held lands at Darley Dale. Godfrey, who succeeded to the family estates after the death of his three elder brothers, Thomas de Foljambe (born ca. 1300), Lord John de Foljambe (born ca. 1300 died 4 August 1358), Hugh de Foljambe (born ca. 1310). He also acquired the manor of Bakewell, where he founded a chantry.
He sat in the House of Commons as knight of the shire for Derbyshire in several of the Parliaments of King Edward III. In 1344 he went to Ireland as a Baron of the Court of Exchequer (Ireland), and was quickly transferred to the Court of King's Bench (Ireland). He served as Lord Chief Justice of Ireland from 1351 to 1354.
On his return to England he sat regularly on commissions for the peace in Derbyshire and Lancashire. He enjoyed the trust and confidence of John of Gaunt, for whom he acted in numerous administrative capacities, including steward for the Duchy of Lancaster. In his later years he drew an annuity of £40 in addition to his salary from Gaunt. For a number of years he held a lease on a substantial part of Newcastle-under-Lyme for which he paid £127 p.a. to John of Gaunt. He died 29 May 1376, Bakewell, Derbyshire.
He married (possibly his second marriage, though little is known of the first), Avena Ireland (1320-13 December 1382), a daughter of Sir Thomas Ireland of Hartshorne in Derbyshire, by whom he had several sons, including Godfrey Foljamba (born ca. 1344 died 29 May 1376, Darley, Derbyshire), Geoffrey Foljambe the younger (died 1375), Richard Foljambe (born ca. 1348, Hassop, Derbyshire) and Thomas Foljambe (born ca. 1355, Walton, Derbyshire died 1433, Tideswell, Derbyshire), who inherited the family estates after the premature death of his young nephew. Among his descendants were Sir Francis Foljambe (died 1640), first and last of the Foljambe baronets, and the Earls of LIverpool, second creation.
The mural alabaster monument to Godfrey and Avena is said to be of a very rare kind, with only two examples surviving to the present day. The Foljambe mural shows Foljambe and his wife as if they are looking out of a window and this can still be seen on the south wall of All Saints Church in Bakewell. Below the mural is an explanatory inscription that dates from 1803 and was "added by Mr Blore".


Luis Taruc

Luis Mangalus Taruc (June 21, 1913 – May 4, 2005) was a Filipino political figure and rebel during the agrarian unrest of the 1930s until the end of the Cold War. He was the leader of the Hukbalahap group (from "Hukbong Bayan Laban sa Hapon") between 1942 and 1950. His involvement with the movement came after his initiation to the problems of agrarian Filipinos when he was a student in the early 1930s. During World War II, Taruc led the Hukbalahap in guerrilla operations against the Japanese occupants of the Philippines.
Influenced by his socialist idol Pedro Abad Santos of San Fernando, and inspired by earlier Katipunan revolutionaries such as Felipe Salvador, Taruc joined the "Aguman ding Maldang Tala-pagobra" (AMT, Kapampangan for 'Union of Peasant Workers') and in 1938, the "Partido Socialista" (Socialist Party). The latter merged with the Partido Komunista ng Pilipinas as part of the Common Front strategy, and Taruc assumed the role of Commander-in-Chief of the military wing created to fight the Japanese.
After the war against Japan, the Hukbalahap continued their demands for agrarian reform. Taruc and seven colleagues were elected to the House of Representatives, but the government of Manuel Roxas did not allow them to take their seats in Congress. The Taruc faction opposed the parity rights that the U.S. required from post-independence Philippines as a condition for rehabilitation funding. In the next five years, Taruc would give up on the parliamentary struggle and once more take up arms. At the height of its popularity, the Hukbalahap reached a fighting strength estimated at between 10,000 and 30,000. In 2017, the National Historical Commission of the Philippines declared Taruc a hero for being a "nationalist and defender of the rights of farmers and workers".
Early life.
Luis Mangalus Taruc was born of peasant stock in the barrio of Santa Monica, township of San Luis, Pampanga on 21 June 1913. Luis states, "In my youth, the Christian faith dominated my spiritual life. But the landlord dominated the material life I knew." At age eight, Luis attended the public school in San Miguel, Bulacan. At fifteen, he attended high school in Tarlac City. He attended to the University of Manila for two years (June 1932–December 1934), studying medicine and law, but no longer able to afford the expenses, returned to Batasan without getting a degree to set up a tailor shop with his brother. As a teen he was inspired by the stories of the Katipuneros who had fought for independence and for agrarian reform against Spain. Certain people within his home village and province came to regard him as the incarnation of the prominent Katipunan leader Felipe Salvador. He was influenced by Pedro Abad Santos, a Marxist, whom Luis regarded as a true socialist. In June 1935, he married Feliciana Bernabe, and his son Romeo was born in March 1936.Before the end of 1935, he joined Santos as a full-time organizer of the Socialist Party of the Philippines, which numbered a few hundred members and several thousand sympathizers. His wife died in Dec. 1938, suffering from goiter and anemia. He then married Enna Cura on 4 June 1939. Luis would serve time in prison three times before the war, in his struggle for the militant workers' and peasants' unions. Enna died of sepsis and diabetes on 8 March 1946. Luis later married Gregoria Calma (Liza). She was killed by government soldiers on 11 April 1952.
World War II.
On 7 Nov. 1938, the Philippine Socialist Party and the Communist Party of the Philippines merged, forming a united front "to fight against fascism and war", though each party retained its own organizations until 1941. They pledged loyalty to the Philippine and United States government's anti-Japanese crusade in Dec. 1941. Following the Japanese invasion, Taruc formed the Hukbalahap ("Hukbo ng Bayan Laban sa Hapon" or the "People’s Army Against the Japanese" in English), along with Casto Alejandrino and other guerillas, in central Luzon on 29 March 1942, became its commander-in-chief, and chairman of the Communist Party's Military Committee.
He led a large people's army against the Japanese invaders, and their "puppet constabulary", as Supremo Luis Taruc, or "Lu-Lu" ("the racing one"), then "Alipato" ("the flying spark that spreads a fire"). According to Luis, "There was a period when we had an American officer officially collaborating with our work." Taruc credited his prominence through his "identification with the simple, sincere, and courageous peasants." However, Luis noted, "...most of the time, the American authorities were suspicious of this unconventional army whose politics they suspected." Yet, the Hukbalahap under Taruc did become an effective armed guerilla force.
Post-war years.
Taruc was elected to the Philippine House of Representatives in 1946 as a member of the Democratic Alliance (the party led by Sergio Osmena). He and five other elected Democratic Alliance candidates opposed the constitutional amendment that would give American businessmen parity rights with Filipinos in exchange for US rehabilitation funding. In particular, Luis opposed the Bell Trade Act, the Parity Amendment to the Constitution, and the Military Bases Agreement. To secure the majority necessarily to pass the amendment President Manuel Roxas arranged for Taruc and the other oppositional Democratic Alliance members ejected from office by the Commission on Elections on the grounds that they had been committing election fraud and terrorism.
Taruc went underground in late 1946, following failed negotiations with President Roxas, and the Huks soon numbered 10,000 armed fighters. Subsequent negotiations with President Elpidio Quirino in June and August 1948 also failed. By the presidential elections of 1949, the Huks had abandoned electoral politics in favor of armed insurgency. The Huks controlled most of central Luzon, the “rice basket” of the Philippines, including two provincial capitals, by 1950. Their motto, "a democratic peace, or martyrdom." Luis states, "The peasants' hatred was founded on centuries of exploitation and oppression, feudal landlordism, and bad government. But the rich...were driven by fear of losing their power and their social privilege...this was naked class war." In the Politburo meeting of Dec. 1949 to Jan. 1950, the Huks were reorganized as the HMB, "Hukbo Mapagpalaya ng Bayan", or "People's Army of Liberation", with Luis as a Politburo Supervisor (PBS) for the Party's Regional Committee, Reco 2, in the Zambales Mountains. By November 1950, Luis was removed from his post of command entirely. By then, the Huks had 15,000 armed men, and the country was embroiled in a "miniature civil war", with ambushes on the major highways common.
President Quirino assigned Ramon Magsaysay, minister of national defense, to combat the Huk insurgency. On 18 Oct. 1950, Magsaysay captured the Secretariat, including the general secretary Jose Lava, following the earlier capture of the Politburo in Manila. Magsaysay attracted peasant support by reforming the Army and Constabulary. After the 1951 Central Committee meeting, a policy of "preservation and conservation of strength...for a long and bitter struggle" was adopted, and Luis departed with a group of ninety men and seven women, for the Sierra Madre Mountains. The latter part of 1952 was spent hiding in the Mount Arayat area. In January 1953, Luis was suspended from the Politburo and Secretariat for his "Call for Peace". On February 10, 1954, Manuel Manahan and Benigno Aquino, Jr., appointed as President Ramon Magsaysay's representatives, met with Luis Taruc. After four months of negotiations, Taruc surrendered unconditionally to the government on 17 May 1954, effectively ending the Huk rebellion. On 15 June 1954, Luis met with President Magsaysay and Gen. Eulogio Balao at Camp Murphy, where Luis agreed to a trial.
Taruc's trial started in Aug. 1954, where he pleaded guilty to rebellion, "in the spirit of my agreement with the president", and sentenced to 12 years of imprisonment, plus as "huge fine". From 1956 to 1958, Luis was put on trial for the execution of Feliciano Gardiner, Japanese occupation governor of Tarlac, for which he was found guilty and sentenced to four life sentences. His petition to President Diosdado Macapagal for executive clemency and amnesty to political prisoners in exchange for support for the President's social welfare program was ignored. Taruc was pardoned by President Ferdinand Marcos on September 11, 1968, and Marcos gained the former Huk leader's support. After his release, he continued to work for Agrarian reforms. His struggle on behalf of the poor farmers persuaded local and national leaders to strengthen the legal rights of farm workers and led to a more equitable distribution of farm land. In his later year's Taruc claimed to have never been a real communist, but rather always advocated Christian democratic socialism; he supported land reform strengthening the rights of local, small farmers over corporations and hereditary feudal elite.
Legacy.
Taruc dictated "Born of the People" (1953) to American communist and ghost writer William Pomeroy. Luis Taruc used Alipato, meaning “spark that spreads a fire,” as his pseudonym. “Born of the People” was Nelson Mandela's reference on peasant resistance and guerrilla warfare when he was the commander in chief of the Umkhonto We Sizwe (Spear of the Nation).
While in New Bilibid Prison, Taruc composed "He Who Rides the Tiger" (1967). Luis wrote, "I know now from experience, that the nationalism of the Communists is indeed opportunism, and that they use it for their own ends. Any nationalist who makes an ally of the Communist is going for a ride on a tiger." Additionally, Luis wrote, "For ruthlessness and cruelty are alien to Christian thought, and when men in the Free World use such methods, they do so in defiance of their own morality and ideals. The atheist Communist, however, believes that the end justifies the means, or in Lenin's words, 'Morality is subordinate to the class struggle.' For this reason, the Communist can pursue a policy of terror and cruelty with a clear conscience."
In 1985, Taruc would tell F. Sionil Jose that one of the reasons for the failure of the insurgency was that dissenters were killed. He also said that dogmatic fundamentalism scared away many potential allies. The Huk movement commanded an estimated 170,000 armed troops with a base of two million civilian supporters at the apex of their power in 1952. In 2003 he explained to historian Keith Thor Carlson that he attributed the revolution's failure to the dogmatism of members of the politburo's Russian-trained elite, in particular Jose and Jesus Lava—an accusation that runs contrary to the views of the Lava's and William Pomeroy who counter that Taruc suffered from a cult of personality.
Several Huk veterans organizations dispute the credit heaped on Taruc for organizing the Hukbalahap during World War II. They contend that Taruc only joined the movement when several prominent Huk leaders were captured and executed by the Japanese, and that there were several Huk brigades operating in concert, under Castro Alejandrino, Eusebio Aquino and Mariano Franco among others.
Death.
On May 4, 2005, Luis Taruc died of a heart attack in St. Luke's Medical Center in Quezon City at the age of 91, a month before his 92nd birthday. Many political figures went to Luis Taruc's wake to pay respect and give support to his family.


Dmytro Hrytsai

Dmytro Hrytsai ( "Perebyinis"; Ukrainian: Дмитрó Грицáй-Переб́ийніс; Dorozhiv, Galicia, 1 April 1907 – 22 December 1945, Prague, Czechoslovakia) was a leader in the Organization of Ukrainian Nationalists and a general in the Ukrainian Insurgent Army.
Life.
Born in Galicia, Hrytsai graduated from "gymnasium" in Drohobych (then part of eastern Poland) and became a member of the Ukrainian Military Organization ("UVO"). In 1928 he matriculated in the Lviv University Department of Physics and Mathematics. He did not graduate, being called to military service in the Polish Army. He completed officers' school with distinction.
In this period of his life he joined the Organization of Ukrainian Nationalists (OUN). From 1933 he directed the OUN Executive's military department. In 1934 he was arrested by the Polish police and was held for over two years at Bereza Kartuska Prison.
After his release, he resumed his studies at Lwów University.
In 1939 he was again incarcerated at Bereza Kartuska, but was released after Poland had been overrun by Germany and the Soviet Union.
In 1940–41 Hrytsai was a member of the OUN Revolutionary Directorate and took part in the second Great OUN Congress. In 1941–43 he actively participated in partisan operations against Nazi German forces. From 1941 he headed the OUN's Military Staff, working to discover the German command's tactical plans, creating weapons and supply depots, and training officer cadres for a Ukrainian army.
In 1943 Hrytsai was arrested by the German Gestapo, but was freed by a Ukrainian Insurgent Army ("UPA") attack on the prison. He directed "UPA"'s General Staff. In 1945 he became "UPA" Chief of Staff and received the rank of general.
In 1945 together with OUN Directorate member Taras Maivski, while carrying out assignments for the Ukrainian Chief Council of Liberation, he fell into a Czech police trap while crossing the Czech-German border. After being tortured, he was executed at the Prague prison.


Alberta (Education) v Canadian Copyright Licensing Agency (Access Copyright)

Alberta (Education) v Canadian Copyright Licensing Agency (Access Copyright), 2012 SCC 37, is a Supreme Court of Canada case that considered whether the photocopying of textbook excerpts by teachers, on their own initiative, to distribute to students as part of course materials is fair dealing pursuant to the provisions of the Copyright Act. The Supreme Court, in a 5/4 split, concluded that the Copyright Board made several errors in its analysis of the "fairness factors". Thus, it allowed the appeal and remitted the matter back to the Copyright Board for reconsideration.
Background and facts.
Access Copyright represents authors and publishers of literary and artistic works. The entity administers the reproduction of such works by issuing licences and collecting and distributing royalties to affiliated copyright owners. When licensing or royalty agreements with users of the printed works cannot be reached, Access Copyright has the option to apply to the Copyright Board (the "Board") to certify a royalty in a form of a tariff.
Teachers in elementary and secondary schools across Canada frequently make photocopies of excerpts from textbooks and other published works that form Access Copyright's collection. Access Copyright wanted to revise the royalty scheme in the agreements as between the provinces and the Ontario School Boards (the "Coalition"). When the Coalition opposed the scheme, Access Canada applied to the Board for a proposed tariff.
Although the copies made at the teachers' initiative for student instruction fell under the allowable purpose of "research or private study", the Board concluded that they did not constitute fair dealing and were therefore subject to a royalty. On judicial review, the Federal Court of Appeal upheld the Copyright Board's conclusion that the copies were not fair dealing.
The Coalition appealed the fair dealing issue to the Supreme Court maintaining that the Board's conclusion was not in accordance with the test in "CCH Canadian Ltd. v. Law Society of Upper Canada", [2004] 1 SCR 339 and was therefore unreasonable.
Issue.
The issue in the appeal was whether the photocopies made by the teachers of the excerpts in the textbooks was considered fair dealing.
Holding.
The majority, McLachlin CJ and Abella, LeBel, Moldaver and Karakatsanis JJ, agreed with the Coalition and remanded the matter to the Board for reconsideration. The dissent, Deschamps, Fish, Rothstein and Cromwell JJ, held that there was no reviewable error made by the Board and that the appeal should not be allowed.
Analysis by the majority.
The concept of fair dealing allows users to engage in some activities that might otherwise be considered copyright infringement. "CCH" articulated a two-step test for fair dealing. The first is to determine whether the dealing is for the allowable purpose of "research or private study", "criticism or review", or "news reporting" under the "Copyright Act". The second step assesses whether the dealing is "fair". A number of fairness factors are used to help courts determine if the dealing is "fair": the purpose, character, and amount of the dealing; the existence of any alternatives to the dealing; the nature of the work; and the effect of the dealing on the work. The person invoking the doctrine of "fair dealing" bears onus to satisfy all aspects of the test.
There was no dispute that the photocopying was for the allowable purpose of "research" or "private study". Rather, the dispute centered on the Board's application of the six "CCH" factors in the second step of the test.
Purpose of the dealing.
Abella J, writing for the majority, said that the Board misapplied this factor. The Board concluded that the photocopies were not for the purpose of "research" or "private study" because they were not requested by the student and that the "predominant" purpose was that of the teacher, namely, "instruction" or "non-private study". Therefore, this factor militated in favour of finding an unfair dealing.
The majority held that "research" and "private study" are consistent with instructional purposes as long as the teachers (the copiers) did not disguise their distinct purposes or conflate it with the research or study purposes of the ultimate user. The teachers had no ulterior motive in providing photocopies to their students. Moreover, instruction cannot be completely segregated from "research" and "private study" because most students require the guidance of teachers to find the materials necessary for their research and private study. "The teacher/copier therefore shares a symbiotic purpose with the student/user who is engaging in research or private study. Instruction and research/private study are, in the school context, tautological". Moreover, the word "private" in "private study" does not mean that users have to study copyrighted works in isolation. "Studying and learning are essentially personal endeavours, whether they are engaged in with others or in solitude".
Amount of the dealing.
The majority held that the Board misapplied this factor when it conducted a quantitative assessment based on aggregate use. A correct examination would look at the proportion between the excerpted work that was photocopied and the entire work. Furthermore, the fact that multiple copies of the same excerpts were made should be considered under the factor "character of the dealing".
Alternatives to the dealing.
The Board found that schools had reasonable alternatives to photocopying textbooks. For example, they could buy original texts for each student or the school library. However, in the majority's view, buying books for each student was not a realistic alternative because the teachers were copying only short excerpts. Furthermore, the schools had already purchased originals that were kept in the class or library, from which the teachers made copies. If the Board's approach was followed, "schools would be required to buy sufficient copies for every student of every text, magazine and newspaper in Access Copyright's repertoire that is relied on by a teacher." The majority concluded that photocopying short excerpts is reasonably necessary to achieve the purpose of "research" and "private study" for the ultimate users, the students.
Effect of the dealing on the work.
This factor assesses whether the dealing adversely affects or competes with the original work. Access Copyright pointed out that textbook sales had shrunk over 30 percent in 20 years. However, Access Copyright did not bring forth any evidence that this decrease was caused by the photocopies made by the teachers. Furthermore, considering the photocopies were only of short excerpts, the majority found it difficult to see how this activity would compete with the textbook market.
Analysis by the dissent.
The dissenting judges held that the Board made no reviewable error and that deference should be given to the Board's application of the factors to the facts.
Purpose of the dealing.
Although the copied excerpts may assist students in their research and private studies, the "predominant" purpose for copying was to utilize the photocopied excerpts in the process of instructing and educating. Rothstein J, writing for the dissent, said that this was not an unreasonable conclusion.
Meaning of "private study".
"Private study" means individual study, "study by oneself". For example, if a copy was made of materials that were tailored to the learning needs or interests of a single or small number of students, this would be considered "private study". Given that photocopied excerpts were distributed to all the students of a class the Board's conclusion that the "predominant" purpose of photocopying was for instruction or 'non-private' study" is reasonable on the facts of this case.
Amount of dealing and character of dealing.
The Board's analysis under the "amount of the dealing" factor remained focused on the proportion of the photocopied excerpt to the entire work. Contrary to what the majority held, the Board did not improperly consider the overall number of copies made. While teachers usually made photocopies of short excerpts, they would return to copy other excerpts from the same books "thereby making the overall proportion of the copied pages unfair in relation to the entire work over a period of time".
Under the "character of the dealing" factor, the Board correctly focused its analysis on the fact that multiple copies of the same excerpt were made at one time for dissemination to the whole class. The Board considered different aspects of the dealing under the factors, "character of the dealing" and the "amount of the dealing" and were thus not "double counting" as the majority held.
The teachers were making multiple copies of various excerpts from the same book. Thus, buying more books to distribute to students or to place in the library is not an unreasonable or unrealistic.
"Where numerous short excerpts of the work are taken, the fact that there are no non-copyrighted alternatives to the dealing does not automatically render the dealing fair." The dissent was not persuaded that the Board's analysis under the "alternatives to the dealing" factor was unreasonable.
Effect of the dealing on the work.
The dissent agreed with the majority that the Board erred when it concluded, without supporting evidence by Counsel, that the photocopies competed with the original, thus making the dealing unfair. However, the dissent said that it was unreasonable to render the Board's overall assessment unreasonable when it made one error under this factor. As said in "CCH", not one factor is determinative. The Board's overall assessment was not unreasonable when viewed in light of the standard of reasonableness.


Swidler Berlin Shereff Friedman

Swidler Berlin Shereff Friedman LLP was a Washington, D.C.-based law firm, itself a product of the merger between D.C. law firm Swidler & Berlin and New York City's Shereff, Friedman, Hoffman & Goodman LLP in 1998. The firm merged with Bingham McCutchen in 2006. At its height in 2005, Swidler Berlin employed some 300 attorneys with offices on D.C. K Street lobbying corridor and in New York City's iconic Chrysler Building.
Swidler Berlin Shereff Friedman was known for its regulatory, telecommunications, insurance coverage and lobbying capabilities, the latter of which was enhanced by its association with the Harbour Group, a lobbying and public relations firm with strong ties to the Clinton Administration.
The firm engaged in lengthy but ultimately inconclusive merger talks with California-based law firm Orrick, Herrington & Sutcliffe in 2004. The next year, Philadelphia-based Dechert made a mass raid on Swidler Berlin's DC and NY offices, hiring 57 attorneys from both the firm's corporate and litigation departments. This included many legacy Shereff Friedman attorneys and was widely seen as a blow to the firm's long-term prospects. The firm merged with bicoastal firm Bingham McCutchen the next year and the Swidler Berlin name was retired from use. Now-defunct San Francisco firm Heller Ehrman inherited much of the insurance team at that time because of conflict of interest issues. The association with the Harbour Group was discontinued although Bingham McCutchen continues to have a strong political, election law and lobbying practice.


Herbert Smith

Herbert Smith LLP was a multinational law firm headquartered in London, United Kingdom. The firm was founded in the City of London in 1882 by Norman Herbert Smith and merged with the Australian law firm Freehills on 1 October 2012, forming Herbert Smith Freehills. At the time of the merger it had 13 offices across Europe, the Middle East and Asia, around 240 partners and 1,300 fee-earners. It was regarded as forming part of the "Silver Circle" of leading British law firms.
History.
Herbert Smith was founded by Norman Herbert Smith in 1882. Edward Walker-Arnott took over as senior partner in 1992.
In 2000 Herbert Smith formed an alliance with German law firm Gleiss Lutz. Herbert Smith, Gleiss Lutz and the Dutch law firm Stibbe formed a tripartite alliance in 2002.
In April 2009 Herbert Smith opened an office in Madrid, Spain after recruiting three partners from Linklaters.
In 2009, Herbert Smith had total revenues of £444 million and profits per equity partner (PEP) of £845,000. In 2010, the firm's revenues were £450 million and PEP was £862,000.
In November 2010 Herbet Smith announced that it would be opening an office in Belfast, Northern Ireland, to perform litigation due diligence tasks.
In November 2011 partners at Gleiss Lutz and Stibbe voted against a merger with Herbert Smith. The alliance between Herbert Smith, Gleiss Lutz and Stibbe subsequently ended on 31 December 2011.
In February 2012, Herbert Smith entered merger discussion with the Australian law firm Freehills. Partners at both firms voted in favour of the merger in June 2012.
Practice.
After specialising in company flotations and advising mining companies in the early part of the 20th century, by the time of its merger with Freehills, Herbert Smith's practice was dominated by litigation and corporate work (M&A and equity capital markets in particular), with other practices including finance, real estate, energy, and competition.
Between 2004 and 2009, Herbert Smith gained more new FTSE 100/250 clients than did any other law firm in the UK, and, as of 2010, Herbert Smith had the fifth largest number of FTSE 100 clients and third largest number of combined FTSE 100/FTSE 250 clients of any UK-based law firm.
Herbert Smith was known for a strict recruitment policy and in August 2012 terminated the training contracts of students who failed any modules of the Accelerated LPC undertaken at BPP Holborn.


Massachusetts Government Act

The Massachusetts Government Act (14 Geo. 3 c. 45) was passed by the Parliament of Great Britain, receiving royal assent on 20 May 1774. The act effectively abrogated the Massachusetts Charter of 1691 of the Province of Massachusetts Bay and gave its royally-appointed governor wide-ranging powers. The colonists said that it altered by parliamentary fiat, the basic structure of colonial government, vehemently opposed it, and would not let it operate. The act was a major step on the way to the start of the American Revolution in 1775.
Background.
The Act is one of the "Intolerable Acts" (also known as "Repressive Acts" and "Coercive Acts"), which were designed to suppress dissent and restore order in Massachusetts. The king took away the colonist voices. In the wake of the Boston Tea Party, the British Parliament launched a legislative offensive against Massachusetts to control its errant behavior. British officials believed that their inability to control Massachusetts was partly rooted in the highly-independent nature of its local government. On May 2, 1774, Lord North, speaking as the head of the ministry, called on Parliament to adopt the Act on the ground that the whole colony was "in a distempered state of disturbance and opposition to the laws of the mother country."
Contents.
The Massachusetts Government Act abrogated the colony's charter and provided for a greater amount of royal control. Massachusetts had been unique among the colonies in its ability to elect members of its executive council. The act took away that right and instead gave the king the sole power to appoint and dismiss the council. Additionally, many civil offices that had been chosen by-election were now to be appointed by the royal governor. Town meetings were forbidden without consent of the governor. As Lord North explained to Parliament, the purpose of the act was "to take the executive power from the hands of the democratic part of the government."

Glasgow pub bombings

The Glasgow pub bombings were two bomb attacks in Glasgow, Scotland, carried out by the Ulster Volunteer Force (UVF) on 17 February 1979. The UVF bombed two pubs frequented by Catholics: the Old Barns in Calton and, 15 minutes later, the Clelland Bar in Gorbals. Five people were injured, all at the Clelland Bar. The pubs were targeted because they were allegedly used for fundraising for Irish republicans in Northern Ireland. The attack sparked fears that sectarian terrorism would erupt in Scotland as a spillover of the Troubles. Experts believe a Provisional Irish Republican Army (IRA) veto on bombing operations in Scotland prevented the situation from escalating.
The attacks were co-ordinated by William "Big Bill" Campbell, the UVF's top commander in Scotland, who was possibly involved with the 1971 McGurk's Bar bombing in Belfast which killed 15 people according to a book published in 2012. A police investigation led to Campbell, along with eight other UVF members (which included Angus McKenna), to be sentenced at Glasgow High Court in June 1979 and jailed. Campbell received a 16-year sentence for the pub bombings as well as criminal conspiracy related to firearms and explosives. The investigation wiped out the UVF's Scotland cell. In 1995 his nephew Jason Campbell murdered a 16-year-old Celtic F.C. supporter in Bridgeton, Glasgow. He was jailed until released on parole in 2011. William Campbell died of natural causes in 1997 and received a funeral in his native Bridgeton, a loyalist stronghold, with thousands in attendance.


Electoral history of David Clarke

The following list is the electoral history of David Clarke. He served four terms as the 64th Sheriff of Milwaukee County, Wisconsin, before resigning on August 31, 2017.