title: Amateur sports

text: Many people in the skating world still use "turning pro" as jargon to mean retiring from competitive skating, even though most top competitive skaters are already full-time professionals, and many skaters who retire from competition to concentrate on show skating or coaching do not actually lose their competition eligibility in the process.


title: Amateur sports

text: Rugby has provided one of the most visible and lasting examples of the tension between amateurism and professionalism during the development of nationally organised sports in Britain in the late-19th century. The split in rugby in 1895 between what became rugby league and rugby union arose as a direct result of a dispute over the pretence of a strict enforcement of its amateur status - clubs in Leeds and Bradford were fined after compensating players for missing work, whilst at the same time the Rugby Football Union (RFU) was allowing other players to be paid.


title: Amateur sports

text: Rugby football, despite its origins in the privileged English public schools, was a popular game throughout England by around 1880, including in the large working-class areas of the industrial north. However, as the then-amateur sport became increasingly popular and competitive, attracting large paying crowds, teams in such areas found it difficult to attract and retain good players. This was because physically fit local men needed to both work to earn a wage - limiting the time that they could devote to unpaid sport - and to avoid injuries that might prevent them working in the future. Certain teams faced with these circumstances wanted to pay so-called 'broken time' money to their players to compensate them for missing paid work due to their playing commitments, but this contravened the amateur policy of the Rugby Football Union (RFU).


title: Amateur sports

text: Following a lengthy dispute on this point during the early 1890s, representatives of more than 20 prominent northern rugby clubs met in Huddersfield in August 1895 to form the Northern Rugby Football Union (NRFU), a breakaway administrative body which would permit payments to be made to players. The NRFU initially adopted established RFU rules for the game itself, but soon introduced a number of changes, most obviously a switch from 15 to 13 players per side. It became the Rugby Football League in 1922, by which time the key differences in the two codes were well established, with the 13-a-side variant becoming known as rugby league.


title: Amateur sports

text: The RFU took strong action against the clubs involved in the formation of the NRFU, all of whom were deemed to have forfeited their amateur status and therefore to have left the RFU. A similar interpretation was applied to all players who played either for or against such clubs, whether or not they themselves received any compensation. Such players were effectively barred "sine die" from any involvement in organised rugby union. These comprehensive and enduring sanctions, combined with the very localised nature of most rugby competition, meant that most northern clubs had little practical alternative but to affiliate with the NRFU in the first few years of its existence.


title: Amateur sports

text: Rugby football in Britain therefore became subject to a de facto schism along regional - and to some extent class - lines, reflecting the historical origins of the split. Rugby league - in which professionalism was permitted - was predominant in northern England, particularly in industrial areas, and was viewed as a working class game. Rugby union - which remained amateur - was predominant in the rest of England, as well as in Wales and Scotland. Rugby union also had a more affluent reputation, although there are areas - notably in South Wales and in certain English cities such as Gloucester - with a strong working-class rugby union tradition.


title: Amateur sports

text: Discrimination against rugby league players could verge on the petty - former Welsh international Fred Perrett was once excluded in lists of players who died in the First World War due to his 'defection' to the league code. One Member of Parliament, David Hinchliffe, described it as "one of the longest (and daftest) grievances in history" with anyone over the age of 18 associated with rugby league being banned forever from rugby union.


title: Amateur sports

text: The Scottish Rugby Union was a particular bastion of amateurism and extreme care was taken to avoid the 'taint' of professionalism: a player rejoining the national team after the end of the Second World War applied to be issued with a new shirt and was reminded that he had been "supplied with a shirt prior to the outbreak of hostilities".


title: Amateur sports

text: In Wales the position was more equivocal with clubs attempting to stem the tide of players "going north" with "boot money", a reference to the practice of putting cash payments into player's footwear whilst they were cleaning up after a game. Sometimes payments were substantial. Barry John was once asked why he hadn't turned professional and responded, "I couldn't afford to."


title: Amateur sports

text: Rugby union was declared "open" in August 1995 - almost exactly 100 years after the original split occurred - meaning that professionalism has been permitted in both rugby codes since that date. However, while the professional-amateur divide remained in force, there was originally very limited crossover between the two codes, the most obvious occasions being when top-class rugby union players 'switched codes' to rugby league in order to play professionally. Welsh international Jonathan Davies was a high-profile example of this switch. Since professionalism has been allowed in rugby union the switches have started to come the opposite way. Union has swiftly grown to embrace the professional game with many league players joining union to take a slice of the larger amounts of money available in the sport.


title: Amateur sports

text: Nowadays, while rugby union no longer makes the professional-amateur distinction, the professional-amateur split still exists within rugby league with the British Amateur Rugby League Association (BARLA) strictly amateur, though it allows some ex-professionals to play provided they are no longer under contract. The most recent club to get a ban for fielding a contracted professional was Brighouse Rangers who were expelled from the National Conference League during 2007–2008 season, and the player handed a sine die ban (though in part for gouging ), although the club itself has since been admitted to the Pennine League.


title: Amateur sports

text: Also, some rugby unions have amateur rules, most notably the Argentine Rugby Union, where all member clubs are amateur. The Campeonato Argentino, the national championship for provincial teams, does not include players contracted to the country's Super Rugby side, the Jaguares.


title: Amateur sports

text: Alternative sports, using the flying disc, began in the mid-sixties. As numbers of young people became alienated from social norms, they resisted and looked for alternative recreational activities, including that of throwing a Frisbee. What started with a few players, in the sixties, like Victor Malafronte, Z Weyand and Ken Westerfield experimenting with new ways of throwing and catching a Frisbee, later would become known as playing freestyle. Organized disc sports, in the 1970s, began with promotional efforts from Wham-O and Irwin Toy (Canada), a few tournaments and professionals using Frisbee show tours to perform at universities, fairs and sporting events. Disc sports such as freestyle, double disc court, guts, disc ultimate and disc golf became this sports first events. Two sports, the team sport of disc ultimate and disc golf are very popular worldwide and are now being played semi professionally. The World Flying Disc Federation, Professional Disc Golf Association, and the Freestyle Players Association, are the official rules and sanctioning organizations for flying disc sports worldwide.


title: Amateur sports

text: Disc ultimate is a team sport played with a flying disc. The object of the game is to score points by passing the disc to members of your own team, on a rectangular field, 120 yards (110m) by 40 yards (37m), until you have successfully completed a pass to a team member in the opposing team's end zone. There are currently over five million people that play some form of organized ultimate in the US. Ultimate has started to be played semi-professionally with two newly formed leagues, the American Ultimate Disc League (AUDL) and Major League Ultimate (MLU).


title: Amateur sports

text: The game of guts was invented by the Healy Brothers in the 1950s and developed at the International Frisbee Tournament (IFT) in Marquette, Michigan. The game of ultimate, the most widely played disc game, began in the late 1960s with Joel Silver and Jared Kass. In the 1970s it developed as an organized sport with the creation of the Ultimate Players Association with Dan Roddick, Tom Kennedy and Irv Kalb. Double disc court was invented and introduced in the early 1970s by Jim Palmeri. In 1974, freestyle competition was created and introduced by Ken Westerfield and Discrafts Jim Kenner. In 1976, the game of disc golf was standardized with targets called "pole holes" invented and developed by Wham-O's Ed Headrick.


title: Amateur sports

text: Sports teams commonly exist at the high school level; students who participate, commonly referred to as student athletes, do so during their course of study. Occasionally, sports success in high school sports may lead to a professional career in the field.


title: Amateur sports

text: The benefit of sports in high school is debated; some believe that they promote discipline and teamwork, while others find that they can cause injury.


title: Amateur sports

text: One study on the relationship between high school athletic and academic successes finds that, for the most part, higher participation and success rates in sports is positively related school-wide student successes on academic outcomes such as standardized test scores and educational attainment. The National Center for Educational Statistics reports that student athletes have a 20% higher chance of completing a college degree, and are more likely to be employed and in better health than non-athletes. However, a survey of high school athletes in 2006 showed that high school athletes are more likely to cheat inside of the classroom than non-athletes, especially boys participating in football, baseball, and basketball and girls participating in softball and basketball. The survey does not indicate to what extent cheating contributes to the greater academic outcomes of high school athletes.


title: Amateur sports

text: In the world of middle school and high school sports, several fees have risen over the last few years making sports more expensive. The term "Pay-to-Play" means that students and their parents must pay a flat fee to participate, and that fee often leaves out the costs of uniforms, transportation, and other team fees. This affects low-income families (those who earn less than $60,000 per year) and their ability to participate in the sports. The average cost is $381 per child per sport (Pay-to-Play Sports). Physical and mental health can improve with the right amount of physical fitness incorporated into everyday life. It allows for the child to have a healthy developing body, and a BMI within the normal range. Physical activity has been proven to improve mood and decrease both stress and anxiety. Studies have shown that the more physical activity one participates in as a child, the happier and more stable that person will be as an adult. Thus, the more students who participate in school sports, the more students who will find themselves balanced and successful adults later in life.


title: Amateur sports

text: In Japan, National High-school Baseball Tournament of Japan (全日本高等学校野球選手権), which highest of amateur sports of the Japan and world, that one of very interest in sports item for Japan, when held on every August, and also regional primary event held in every July on nationwide Japan, according to Central Institute Research of Japan (日本中央調査社) survey report on every years on past fifty years. This tournament first held on 1914.


title: Amateur sports

text: Golf still has amateur championships, most notably the U.S. Amateur Championship, British Amateur Championship, U.S. Women's Amateur, British Ladies Amateur, Walker Cup, Eisenhower Trophy, Curtis Cup and Espirito Santo Trophy. However, amateur golfers are far less known than players of professional golf tours such as the PGA Tour and European Tour. Still, a few amateurs are invited to compete in open events, such as the U.S. Open and British Open or non-open event, such as the Masters Tournament.


title: Amateur sports

text: In motorsports, there are various forms of amateur drivers. When they compete at professional events, they are often referred to as "pay drivers". They have been a presence in Formula One for many years - drivers such as Felipe Nasr, Esteban Gutiérrez and Rio Haryanto bring sponsorship to the tune of $30 million for a seat, even in backmarker teams. In sports car racing, drivers are often seeded into certain categories, including Amateur and Pro-Am classes. The vast majority of these "gentlemen drivers" however tend to participate at club level, often racing historic or classic cars, which are aimed primarily at amateurs.


title: Amateur sports

text: In Ireland, the Gaelic Athletic Association, or GAA, protects the amateur status of the country's national sports, including Gaelic football, hurling and camogie. Major tennis championships prohibited professionals until 1968 but the subsequent admission of professionals virtually eliminated amateurs from public visibility. Paying players was considered disreputable in baseball until 1869.


title: Hennessey Performance Engineering

text: Hennessey Performance Engineering is an American hypercar manufacturer and high-performance vehicle creator.


title: Hennessey Performance Engineering

text: In addition to building the Venom F5 hypercar, the company specializes in 'making fast cars faster' modifying sports cars from several brands including Chevrolet, Dodge, Cadillac, Jeep, Ford, GMC, and Lincoln. Established in 1991 by John Hennessey, their main facility is located 45 minutes west of Houston, Texas in Sealy, Texas. The firm focuses on mechanical component modification for creating high-powered cars. Besides performance automobiles, they also tune pickup trucks and sport utility vehicles such as the Ford Raptor, the Ram TRX and the Jeep Grand Cherokee. They also work on muscle cars like the Ford Mustang, Dodge Charger and Challenger.


title: Hennessey Performance Engineering

text: In 2008, the Tuner School was founded by the company. It is a private institution dedicated to teach and train high performance vehicle tuner technicians. It is located at Lonestar Motorsports Park, near the Hennessey Performance headquarters. All instructors at this education facility are actual performance tuning mechanics.


title: Hennessey Performance Engineering

text: The Hennessey Venom 650R is one of the first offerings provided from the tuning company. Available as a package to the 1996 Dodge Viper GTS, the Venom 650R was one of the fastest road legal cars in the world. Upgrades included a US$37,000 engine upgrade that utilised enlarged cylinder bores, and longer stroke to increase displacement from the stock to along with forged steel connecting rods (titanium rods were an extra $3,500) and forged aluminum pistons; the whole assembly was then balanced and blueprinted to bring the total power output to at 5,800 rpm and of torque at 4,500 rpm bumping the compression ratio up to 10.5:1. On the intake, a competition airbox feeds 70-millimeter billet throttle bodies and a port-matched intake manifold. On the exhaust, a set of tuned-length stainless steel headers sent spent gases back to a 3.0-inch stainless exhaust system that retained the stock catalytic converters, but allowed them to be easily bypassed for track day performance. New engine management software increased the idle to 1,000 rpm, disabled the 1-4 skip-shift transmission feature, turned the cooling fans on sooner, and packed recalibrated fuel and ignition curves. Completing the package was the VenomAero carbon fiber body upgrade that reduced weight, added functional brake cooling ducts along with a rear wing and optimized downforce. All of these modifications allowed the car to accelerate from in 3.3 seconds, complete the 1/4-mile in 10.8 seconds at a speed of and propel the car to a top speed of over . A Brembo race spec braking system and a Penske adjustable suspension system with 30 variable damping settings were available as an option. The total cost of the package stood at US$108,500 excluding the price of a stock Viper GTS.


title: Hennessey Performance Engineering

text: In 2010, Hennessey Performance revealed the Hennessey Venom GT. The Venom GT is based on the Lotus Exige and has a twin-turbocharged V8 engine that is rated at . The car weighs and has a top speed of . Three "World's Fastest Edition" Venom GT coupés were produced in 2014 to commemorate the car's speed record run.


title: Hennessey Performance Engineering

text: A roadster variant dubbed the Venom GT Spyder was launched in 2012 on the request of Aerosmith lead singer Steven Tyler. It is based on the Lotus Elise and adds to the curb weight due to structural changes. The production of the Spyder was limited to five units with a one-off Spyder being produced as the "Final edition" model bringing the total to 6 units. The final edition gained a total of and was lighter than the regular Spyder.


title: Hennessey Performance Engineering

text: The Hennessey Venom F5, successor to the Venom GT, was unveiled at the SEMA Show in Las Vegas, Nevada, on November 1, 2017, with high expectations of its intended world-beating speed record, having a projected 2.0 second acceleration time and top speed.


title: Hennessey Performance Engineering

text: The Venom F5 features a bespoke proprietary 6.6-liter twin-turbocharged V8 engine, making this the company's first in-house engine. It is rated at and of torque. Pennzoil and Shell are partners with Hennessey for the project to help reach the top speed mark. The top speed is claimed to be through a V-MAX speed-tracking system. Hennessey predicts the car can accelerate from in a time of under 10 seconds and in a time of under 20 seconds. Only 24 will be built with each car costing US$1.6 million.


title: Hennessey Performance Engineering

text: The Hennessey VelociRaptor SUV is a luxury off-road full-size SUV modified from the Ford SVT Raptor. The SUV is limited to 30 produced a year, however since its introduction over 400 versions have been made. It uses the same engine Ford uses for the pickup truck version. The second generation version is a Luxury off-road heavy-duty SUV modified from the 2015 Ford Super Duty Lariat Version, with design cues from the Ford Excursion.


title: Hennessey Performance Engineering

text: As of 2015, the first generation model has been discontinued. In 2018 the Hennessey Ford VelociRaptor 6×6 option was made available, with a 30-inch extended frame and extra axle for a total of six driven wheels.


title: Hennessey Performance Engineering

text: The Hennessey Exorcist is an upgrade package for the Chevrolet Camaro ZL1 offered by Hennessy Special Vehicles. The package includes a high-flow supercharger and intercooler providing 14 psi of boost pressure, custom camshaft, ported cylinder heads, upgraded valvetrain with new springs, lifters, pushrods and valves and long-tube stainless steel exhaust headers with high-flow catalytic converters. The cars equipped with the automatic transmission will require an upgraded transmission at the cost of US$9,950. The optional drag pack includes 315/30-20 rear tires, modifications to the drive shaft, floor jack and tool kit for faster acceleration at the drag strip at the cost of US$8,995. The optional road race pack includes a set of 20 inch light weight Hennessey wheels with Michelin Pilot Sport Cup 2 tires at the cost of US$6,995. The upgraded engine with the standard package is rated at at 6,400 rpm and of torque at 4,400 rpm, enabling the vehicle to accelerate from in 3.5 seconds, complete the quarter-mile in less than 10 seconds and attain a top speed of , over that of the original ZL1. The package is available at an additional cost of US$57,455 over the cost of the standard ZL1 for both the manual and automatic versions of the car. The vehicle can directly be ordered from Hennessey Special Vehicles, Chevrolet dealers or the vehicle can be sent to Hennessey Special vehicles by the owners for conversion.


title: Hennessey Performance Engineering

text: Hennessey established the Hennessey Special Vehicles division in 2017, in which it builds the Hennessey Venom GT sports car line-up. The division is tasked to learn from its experiences with the Venom GT and apply it to the newest variation, the Hennessey Venom F5, which will succeed the Venom GT. All vehicles sold under the division are branded as a regular Hennessey model, despite being built by the division.


title: Carlos Torres (actor)

text: Carlos Andres Torres Rivera (born 20 September 1988 in Barranquilla, Colombia) is a Colombian actor. The beginning of his debut on television in the Colombian drama series "Padres e Hijos". His most notable roles in television have been in telenovelas such as "", "The Queen of Flow", and "All For Love".


title: Carlos Torres (actor)

text: Torres debuted on Colombian television in 2005 at age 17 in the long-running series, "Padres e hijos". Subsequently, he played Franco Fritzenwalden in the Colombian version of the Argentine series, "Floricienta". Before getting his first role as a main character in a telenovela, he participated as a recurring character in other telenovela like "Pocholo", and "Cómplices".


title: Carlos Torres (actor)

text: In 2009 he got his first role as the main character in the telenovela, "Amor mentiras y video". Between 2010 and 2012, he played the main villain of the series "Niñas mal", a version of the Mexican film of the same name. In 2012 he obtained one of the main roles as a young protagonist in the telenovela, "Pobres rico". In that same year he participated in "Las Santísimas", a telenovela that was kept for five years, and which premiered in other countries first, although in Colombia it was broadcast between 2015 and 2016.


title: Carlos Torres (actor)

text: In 2013 he got a recurring role in the telenovela, "Secretos del paraíso", a modern adaptation of "La maldición del paraíso", whose premiere was first in Latin America, and the following year in Colombia.


title: Carlos Torres (actor)

text: His mother Carmen Rivera is an architect. He has an elder brother, Enrique, whose birthday is also the 20th of September.


title: Carlos Torres (actor)

text: His long-time girlfriend Joanna Castro is an entrepreneur involved in the health food brand "Viva Natur".


title: Coyote (person)

text: Colloquially, a coyote is a person who smuggles immigrants across the Mexico–United States border. The word "coyote" is a loanword from Mexican Spanish that usually refers to a species of North American wild dog "(Canis latrans)".


title: Coyote (person)

text: Migrants pay coyotes a fee to guide them across the border. Fees are normally collected once the migrant arrives at a predetermined destination, usually a border city in California, Texas, or Arizona. Since the 1990s, the proportion of migrants who hire coyotes has increased drastically as a result of intensified surveillance along the border.


title: Coyote (person)

text: Since the end of the nineteenth century, coyotes have been a part of the illegal migratory process for many Mexican migrants. From 1882 to 1917, a series of U.S legislations contributed to the rise of the coyote in illegal border crossings. The Chinese Exclusion Act in 1882 and Immigration Act of 1885 caused the flow of labour to decline. This led to severe labour shortages in the south-western and western regions of the country.


title: Coyote (person)

text: The demand for Mexican workers from U.S employers rose and by 1884 supply was guaranteed when the railway connection of El Paso, Texas, with Mexico was completed. The illegal migratory crossings were largely unregulated and accepted as de facto acceptable practices.


title: Coyote (person)

text: "Enganchadores", Spanish for "hookers" (from the verb "to hook"), were Mexican individuals hired by U.S employers as labour recruiters. "Enganchadores" would persuade Mexican peasants to travel on the railway in acceptance of American jobs. The "enganche" system was not a novelty in Mexico. It had been established to recruit southern peasants for work in northern industries within the country. Companies in the United States effectively used the system to satisfy their labour needs. It can be argued that "enganchadores" are an ancestor of the modern-day coyote. Like today's coyotes, they acted as middlemen between migrants and the United States.


title: Coyote (person)

text: Explicit restrictions on Mexican immigration during the late 1910s and early 1920s caused U.S labour-seeking migrants to increasingly rely on middlemen for labour-brokerage with American companies.


title: Coyote (person)

text: The U.S Immigration Acts of 1917 and 1924 required foreign individuals crossing the border to take literacy tests, undergo medical exams, and pay head taxes and visa fees. The new requirements "combined with the creation of the Border Patrol in 1924, prompted thousands of Mexican migrants to cross the Rio Bravo surreptitiously to enter the country." As a direct result, demand for coyotes grew exponentially. The U.S Commissioner of Immigration observed the trend commenting, in a Congressional report, that a "new and thriving industry... having for its object the illegal introduction into the United States of Mexican aliens on a wholesale scale by means of organized efforts" had emerged.


title: Coyote (person)

text: Ciudad Juarez became a hub for coyotes during the mid-1920s. In his study on Mexican migration, anthropologist Manuel Gamio details the process. Coyote fees were considerably less than those needed for visitor's visas; an approximate $100 to $150 difference (based on today's exchange rate). Working individually, or with others, a coyote would lead his client across the Rio Bravo via automobile, boat, or by swimming. Crossings were widely successful as Gamio notes: “These people know their ground thoroughly... and sometimes even have an arrangement with some district official.” The prevalent use of false documents, or "leased" legitimate documents, contributed to the success.


title: Coyote (person)

text: Increased restrictions on migrants, including ones from Mexico into the U.S. were primarily starting to be put into place in the 1920s, although there was not a national quota restricting Western Hemisphere immigrants until 1965. Increasing restrictions caused the demand for cheap migrant labour to exceed the legal ability for foreign workers to enter and work in the country. The conflict between the Nativist demand for restrictions and the many business owners who wanted less expensive labour, lead to a demand for unauthorized persons to be brought into the country. This led to an economic draw for desperate people to illegally enter as well as reasons for employers in the U.S. to use and support illegal methods to get more migrants into the country illegally to have more workers than the quota allows for. Therefore both groups required the help of guides to get migrants into America, requiring the help of the coyotes and similar groups.


title: Coyote (person)

text: Upon arrival in the United States, coyotes were paid their fees and migrants were delivered to their employers. Competition for Mexican workers grew so high among labour contractors that it inspired a short-lived coyote system in the United States. For a fee, "man-snatchers" would kidnap Mexican workers from one company and deliver them to a competing firm. The threat of losing money, on account of a stolen employee, "led labour contractors to keep workers en-route to employers locked up and under armed guard to prevent their theft."


title: Coyote (person)

text: Labour-brokerage coyotes continued to profit despite the Great Depression. Demand in Texas for cotton harvesters through the use of coyotes allowed them to recruit about 400,000 migratory workers by the end of the 1930s, two-thirds of which were Mexican. Coyotes would load trucks with fifty to sixty workers to be delivered to different Texas companies. The practice received international attention in 1940 when a "delivery" truck got into an accident, resulting in forty-four Mexican migrant injuries and twenty-nine fatalities, including eleven children. The U.S and Mexican governments worked together to end labour-brokerage coyote, by implementing the Bracero Program in 1942.


title: Coyote (person)

text: The popularity of the Bracero Program resulted in a greater Mexican demand for guest-worker contracts than there were contracts to give. Consequently, thousands of Mexican laborers unable to participate in the program sought the help of coyotes to enter the United States. "Clandestine-crossing" coyote saw a rise during this period.


title: Coyote (person)

text: By 1950, the United States Border Patrol relied on approximately 1,000 agents to patrol the border. Mexican migrants seeking entry relied on the coyote. Crossing the Rio Grande became the route of choice. This was achieved mostly by boat with the help of a "patero" (boatman), or more dangerously, by swimming, thus creating the slur "wetbacks.”


title: Coyote (person)

text: In 1953, Border Patrol reported to have detained 1,545 "alien smugglers" along the border. The end of the Bracero Program would lead to greater illegal crossings.


title: Coyote (person)

text: The Hart-Celler Act, passed in 1965, set strict quotas on the number of annual visas it issued. More than ever before, Mexican workers in search of American jobs were dependent on the coyote system to accomplish their goals. A study reports that, by the 1980s, "do-it-yourself" border crossings were rare and "virtually everyone" was paying a coyote. The coyote industry's prosperity garnered the attention of the U.S and Mexican governments. U.S authorities continued to expand the Border Patrol, while the Mexican government enacted laws penalizing individuals convicted of aiding illegal entry into the United States.


title: Coyote (person)

text: Coyote strategies evolved during this period. Some Mexican cities witnessed the emergence or growth of smuggling rings. Larger organizations had expansive networks with contacts across Latin America. Several of these rings were capable of moving an estimated eight to ten thousand migrants into the United States annually. The use of tractor-trailers to carry passengers across national lines proved to be extremely effective. Hidden compartments were built in the floors of truck beds to hide "cargo." Furthermore, coyote leaders strategically chose juveniles as drivers or guides, so as not to be tried in the United States if caught. That way they could then be recycled into the system.


title: Coyote (person)

text: The IRCA was passed in 1986 under the Reagan administration. It created an amnesty program allowing currently undocumented immigrants the opportunity to legalize their status in the United States and eventually obtain citizenship, and established employer sanctions against individuals hiring undocumented workers. To obtain amnesty, migrants had to demonstrate they had been continuously living in the United States since 1982. Documents of proof included "pay stubs, rent receipts, bank statements, and affidavits from persons who knew them during the period they had resided illegally."


title: Coyote (person)

text: The IRCA also required employers to ask potential employees for documents confirming their authorization to work in the United States as a result of both provisions, a black market of counterfeit documents emerged catering to the demand. Shortly after, the media covered numerous stories revealing a coyote network of document falsification. The "Houston Chronicle" reported that "flea markets, grocery store lots, even the more secluded corners of Hispanic restaurants, are increasingly the scenes of blatant wheeling and dealing of phony documents at premium prices."


title: Coyote (person)

text: Since the practice of human smuggling is a financially growing sector, many people want to participate in the business. To guarantee a successful journey for the immigrants, human smugglers have created an organized hierarchy of coyotes playing various roles. Demand for their services increased due to the U.S implementing stricter laws and patrolling the border. Each role plays a part in the process of transporting immigrants.


title: Coyote (person)

text: The lowest position in the human smuggling hierarchy is the vaquetón. While the human smuggling organizations are headquartered at the border, vaquetones are assigned to recruit migrants within their communities at the interior of the country. After vaquetones recruit a busload of immigrants eager to cross the border, migrants are placed in hotels near the border, waiting patiently for a coyote to signal an opportunity to cross the border. As the coyotes are the primary means in getting immigrants across the border, they use nicknames to avoid being identified. Being responsible for guiding the immigrants to the border safely, human smugglers have kept up to date with the border patrol's new technologies, monitoring their surveillance activity, aware of border patrol shift schedules and their stations.


title: Coyote (person)

text: Another important role in the human smuggling hierarchy is the chequador. The chequadores work for the coyotes and the coyotes’ assistants, keeping an eye out at checkpoints and border patrol areas enabling them to signal for a safe crossing. They are provided with the same quality equipment as the border patrol agents, such as night-vision scopes, and consistently use their cell phones or two-way radios to track patrol movements. To make the chequadores’ job less suspicious, they often rent a room near the border and set up telescopes to have a better view.


title: Coyote (person)

text: Cuidandonos are also known as caretakers. Most are American children that are hired from local high schools who, if caught, will receive a less severe punishment. They distract border patrol agents by throwing rocks at them, or by removing tire spikes set on suspected transport routes while immigrants cross the border. After successfully crossing the border, immigrants are transported to a load house (safe house), usually located at the nearest large city.


title: Coyote (person)

text: Bosses, also known as patrones or socios, are the highest rank of hierarchy in the coyote business. The bosses' duties are to manage the finances and business aspects of the operation. Due to the coyotes being the primary source to guiding the immigrants through the border, the bosses heavily depend on them. Most commonly the bosses fund the process and are the owners of the hotels, safe houses and vehicles used in the process.


title: Coyote (person)

text: Since 9/11, the U.S government has taken numerous measures to tighten security along the southern border. Part of the Border Patrol's mission statement declares that "an ever-present threat exists from the potential for terrorists to employ the same smuggling and transportation networks, infrastructure, drop houses, and other support and then use these masses of illegal aliens as ‘cover’ for a successful cross-border penetration." Increased surveillance makes clandestine crossing much more difficult, but not impossible. In reality, when economic conditions in Latin America deteriorate, the motivation to come and work in the U.S only rises, leaving potential migrants one realistic option – engaging a coyote.


title: Coyote (person)

text: Avoiding the attention of the border patrol even as the security and restrictions increase, and helping migrants get around them is the primary focus of coyotes. This is because it is their job to guide their clients around these dangers. A skilled coyote will know the movements of the border patrol and when and how it is best for a person to sneak across. Some may try instead of getting over a border wall to slip past the patrol by pretending to be a valid, inconspicuous traveller. A trick that many migrants use is to deceptively cross legally but stay and work illegally. One trick they may use is to obtain a BCC (Border Crossing Card) to enter the country by posing as a tourist or a person who is visiting family or friends in the country and then to illegally stay in the country and work. Through these methods they would work to hide their connections to employers and would use the services of coyotes to obtain information, a job and connections they are able to use in the country to continue to live without being deported.


title: Coyote (person)

text: In the group of people that work as coyotes there are two important subgroups that have been categorized, the interior and exterior coyotes. Both groups work to get migrants illegally into the United States, however, they do it in different ways and will take different types of people. Which group a migrant uses (if they do choose to use a coyote and don't go alone or with their own group), depends on many factors such as if they are familiar with what they need to do to get into the U.S. along with what connections they have to both people in the U.S. and with prospective coyotes. These two broad groups are called Interior and Exterior Coyotes.


title: Coyote (person)

text: Interior Coyotes: Usually known to the people they are taking and are more often used by people with less experience trying to cross the border or who lack strong ties to people in the U.S. Persons without connections to where they are going in America usually travel with interior coyotes because they tend to be people from their hometown or people that they otherwise have more of a connection to. This provides social capital for the coyote by being perceived as being more trustworthy due to being known in the area if not the prospective migrant personally. These connections also can help the migrants avoid being taken advantage of or being abandoned part way by an untrustworthy or inexperienced guide. These social bonds between the migrants and their guides help to provide increased safety for a dangerous and illegal undertaking for the travellers and bring customers for the coyotes.


title: Coyote (person)

text: Border Coyotes: Also called border business coyotes or exterior coyotes, they usually live near the border and will regularly take people across all year. Migrants with more experience trying to cross the border or who are traveling during busy times for crossings are more likely to travel with border coyotes. These guides due to living near the border will help people cross all year long as long as the customers are willing to pay their price and take the risk of traveling with them. Experienced border crossers will more often go to the border on their own and travel across with the help of a professional border coyote.


title: Coyote (person)

text: Because of anti-smuggling legislation, such as the Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA), hardened the civil and criminal penalties for alien smuggling and expanded the use of the IDENT database (fingerprint recording system), coyotes increased their fees to match the risk. According to experts such as sociologist Douglass Massey, coyotes gross more than $5 billion a year. Crossing fees can range from $1,500 to $2,500 in Mexico. Police note that on a "good day" large coyote organizations can transport 500 people into the United States. This suggests that on a "good day", larger enterprises can earn an average of $1 million, while "mom and pop" rings can earn $780,000 annually.


title: Coyote (person)

text: "Mom and pop" coyote businesses do not require exorbitant amounts of money to get started. It depends on the method of border crossing an individual or group chooses. Most require transportation, including automobiles and rowboats, while other more sophisticated and expensive options require cash to purchase documents, scanning and graphics equipment to forge said documents, and real estate in the form of safe-houses.


title: Coyote (person)

text: All coyotes need social capital "in the form of social connectedness to trustworthy collaborators willing to assume the risks of engaging in extra-legal conspiracies." The construction of a good reputation is also critical to the success of coyotes in an ever-growing competitive market. Reputations are defined by competency, trustworthiness and decent customer service. They are primarily achieved by word of mouth amongst migrant social networks. When considering a coyote, migrants prioritize the success rate of border-crossings, the treatment received during trips and, for female clients, the respect shown to their gender.


title: Coyote (person)

text: Generally, coyotes are seen in negative eyes and with many negative connotations. International media coverage tends to highlight stories of coyote human rights violations. The media has reported on stories that have added to negative perceptions of coyote:


title: 69 Love Songs

text: 69 Love Songs is the sixth studio album by American indie pop band the Magnetic Fields, released on September 7, 1999 by Merge Records. As its title indicates, "69 Love Songs" is a three-volume concept album composed of 69 love songs, all written by Magnetic Fields frontman Stephin Merritt.


title: 69 Love Songs

text: The album was originally conceived as a music revue. Stephin Merritt was sitting in a gay piano bar in Manhattan, listening to the pianist's interpretations of Stephen Sondheim songs, when he decided he ought to get into theatre music because he felt he had an aptitude for it. "I decided I'd write one hundred love songs as a way of introducing myself to the world. Then I realized how long that would be. So I settled on sixty-nine. I'd have a theatrical revue with four drag queens. And whoever the audience liked best at the end of the night would get paid." He also found inspiration in Charles Ives' "114 Songs", about which he had read earlier in the day: "songs of all kinds, and what a monument it was, and I thought, well, I could do something like that."


title: 69 Love Songs

text: Band member Claudia Gonson has claimed that Merritt wrote most of the songs hanging around in bars in New York City.


title: 69 Love Songs

text: On seven occasions (five in the United States and two in London over four consecutive nights) the Magnetic Fields performed all 69 love songs, in order, over two nights. Several of the lavish orchestrations are more simply arranged when performed live, due to limited performers and/or equipment.


title: 69 Love Songs

text: Merritt has said ""69 Love Songs" is not remotely an album about love. It's an album about love songs, which are very far away from anything to do with love." The album features songs in many different genres, including country, synth pop, free jazz, and mournful love ballads. All the songs deal with love in one form or another, but often in an ironic or off-beat fashion, such as the track "Yeah! Oh, Yeah!" which tells the story of a husband murdering his wife. The songs of "69 Love Songs" features lyrics exploring heterosexual, homosexual, and bisexual relationships.


title: 69 Love Songs

text: The album was initially released in the United States by Merge on September 7, 1999, as a box set with Merritt interview booklet with Daniel Handler, and as three separate individual volumes—catalogue numbers MRG166 (Vol. 1), MRG167 (Vol. 2), MRG168 (Vol. 3), and MRG169 (box set). On May 29, 2000, the album was released by Circus (CIR CD003) in Europe and Australia without the booklet insert. It was reissued in the United Kingdom through Domino as REWIGCD18.


title: 69 Love Songs

text: "69 Love Songs" received widespread acclaim from music critics. At Metacritic, which assigns a normalized rating out of 100 to reviews from mainstream critics, the album received an average score of 88, indicating "universal acclaim". Betty Clarke of "The Guardian" hailed it as "an album of such tenderness, humour and bloody-minded diversity, it'll have you throwing away your preconceptions and wondering how you ever survived a broken heart without it." Douglas Wolk of "Spin" called the album Stephin Merritt's "masterwork" and stated that "pop hasn't seen a lyricist of Merritt's kind and caliber since Cole Porter", praising his unique takes on standard love song clichés. Nick Mirov of "Pitchfork" wrote that Merritt "has proven himself as an exceptional songwriter, making quantum leaps in quality as well as quantity on "69 Love Songs"." Robert Christgau, writing in "The Village Voice", stated that despite his personal dislike of cynicism and reluctance to "link it to creative exuberance", the album's "cavalcade of witty ditties—one-dimensional by design, intellectual when it feels like it, addicted to cheap rhymes, cheaper tunes, and token arrangements, sung by nonentities whose vocal disabilities keep their fondness for pop theoretical—upends my preconceptions the way high art's sposed to."


title: 69 Love Songs

text: "69 Love Songs" was voted second place in "The Village Voice"s annual Pazz & Jop critics' poll for 1999, behind Moby's "Play". The poll's creator Robert Christgau ranked it as the best album of the year on his "Dean's List". In 2012, it was ranked at number 465 in "Rolling Stone"s list of the 500 Greatest Albums of All Time. It was ranked at number 406 in the 2020 edition of the list. The following year, "NME" placed it at number 213 on their own list of all-time greatest albums. The album was also included in the book "1001 Albums You Must Hear Before You Die".


title: 69 Love Songs

text: According to Nielsen SoundScan, as of 2015 the three-volume boxed set has sold 83,000 copies, with an additional 58,000 for volume one, 34,000 for volume two, and 29,000 for volume three.


title: 69 Love Songs

text: LD Beghtol's explication of "69 Love Songs" () was released on December 15, 2006 by Continuum International Publishing Group as part of their series of books on influential pop/rock albums.


title: 69 Love Songs

text: The book includes studio anecdotes, an extensive annotated lexicon of words and phrases culled from the album's lyrics, performance notes from the band, fans and friends, full-album shows in New York, Boston, and London, rare and unpublished images by "chickfactor" editor/photographer Gail O'Hara, and other items such as a crossword puzzle created by TMF/Flare associate Jon DeRosa and a scathing list of academic cant words not otherwise used in Beghtol's book.


title: 69 Love Songs

text: Also featured is a candid interview with the songwriter, styled as a surrealist radio play, in which Stephin Merritt answers questions about his Chihuahua Irving Berlin Merritt, his sex life, studio practices, and other esoterica.


title: 69 Love Songs

text: "The Book of Love" was covered by Peter Gabriel; this cover version was featured in "Scrubs" during the final episode, "My Finale", the 2004 movie "Shall We Dance?", and the South Park episode "Tweek x Craig". Taylor Hickinson covered the song as her character Raelle Collar in the Freeform series "".


title: 69 Love Songs

text: "Papa was a Rodeo" was covered by Kelly Hogan and the Pine Valley Cosmonauts on the 2000 Bloodshot Records album "Beneath the Country Underdog".


title: 69 Love Songs

text: "My Only Friend" was covered by Deadsy and featured on the soundtrack for the 2005 film Winter Passing.


title: Sajida Sultan

text: Nawab Begum Sajida Sultan Ali Khan Pataudi (4 August 1915 – 5 September 1995) was the daughter of the Nawab of Bhopal, Hamidullah Khan, and the wife and Begum Consort of Iftikhar Ali Khan Pataudi, the 8th Nawab of Pataudi, and in her own right, the 12th Nawab Begum of Bhopal.


title: Sajida Sultan

text: Sajida Sultan was born on 4 August 1915 in the Qasr-e-Sultani Palace, Bhopal, to Nawab Hamidullah Khan, last ruling Nawab of Bhopal and his wife, Begum Maimoona Sultan. She was the second of three children; she had an older sister, Abida Sultan, and a younger sister, Rabia Sultan. Sultan Jahan, the Begum of Bhopal, was her grandmother, and her predecessor Shah Jahan Begum was her great-grandmother. The Pakistani diplomat Shahryar Khan, is her nephew through her sister Abida.


title: Sajida Sultan

text: On 23 April 1939, Sajida married Nawab Iftikhar Ali Khan, 8th Nawab of Pataudi. Together they had three daughters – Saleha, Sabiha, and Qudsia – and a son, the cricketer Mansoor Ali Khan Pataudi. Sher Ali Khan Pataudi, the major general in the Pakistan Army was her brother-in-law by marriage. The actors Saif Ali Khan and Soha Ali Khan, the jewelry designer Saba Ali Khan and the cricketer Saad Bin Jung are her grandsons and granddaughters. Sara Ali Khan, an actress in the Hindi film industry is her great-granddaughter.


title: Sajida Sultan

text: On 5 January 1952, Iftikhar Ali Khan died and Mansoor succeeded his father as the 9th titular Nawab of Pataudi.


title: Sajida Sultan

text: In 1960, upon the death of her father, she became titular ruler of Bhopal. Her older sister, Abida, was the heiress apparent to the title but had emigrated to Pakistan in 1950 and declined to return to Bhopal permanently; her son declined also. Sajida was formally recognised as the Nawab Begum of Bhopal in 1962, with recognition being effective from 1960.


title: Sajida Sultan

text: She died on 5 September 1995 at the age of 80. Mansoor Ali Khan subsequently became the "mutawalli" of the Auqaf-e-Shahi of Bhopal, a title which is currently held by her granddaughter Saba Ali Khan.


title: Jill Janus

text: Jill Janus (née Janiszewski; September 2, 1975 – August 14, 2018) was an American singer who was the lead vocalist of heavy metal bands Huntress, The Starbreakers and Chelsea Girls.


title: Jill Janus

text: Janus was born in the Catskills Mountains and practiced paganism throughout her childhood. Growing up, she began singing opera


title: Jill Janus

text: before becoming interested in thrash metal as a teen. For her post-secondary education, Janus attended the American Musical and Dramatic Academy.


title: Jill Janus

text: Janus started her music career working as a topless disc jockey under the name Penelope Tuesdae. She also worked in cabaret at the Windows on the World until the night before the September 11 attacks in New York. In 2003, Janus began her career in metal as a member of Vexy Strut and remained with the band until 2006. In 2009, she recruited members of the metal band Professor to join her newly formed band Huntress.


title: Jill Janus

text: With Huntress, she was the lead singer during the band's three studio albums, the last of which was "Static" in 2015. In the fall of 2015, Janus announced to social media that Huntress was breaking up. She was later refuted by the band's guitarist Blake Meahl, citing her mental health issues.


title: Jill Janus

text: Apart from her albums with Huntress, Janus filled in for Amon Amarth's lead singer Johan Hegg during a 2015 co-tour with Huntress. Janus's other projects outside of Huntress included membership of cover bands Chelsea Girls and The Starbreakers as their lead singer. She also co-wrote "Victory: The Rock Opera" with guitarist Angus Clark. Janus also recorded vocals for Brian Posehn's album "Grandpa Metal", which was released in 2020, featuring her performances on the song "Goblin Love" as well as a cover of "Take On Me", the latter of which was released in November 2019.


title: Jill Janus

text: Janus's musical influences ranged from rock to heavy metal. In rock, Janus named Ann Wilson as an influence while citing Freddie Mercury as one of her vocal inspirations. With heavy metal, Janus listed Rob Halford, King Diamond and Jared Warren as a few of her favourite singers. Janus said she had a four octave vocal range as a coloratura soprano. While she was in Huntress, Janus stated that each Huntress album respectively focused on a part of her life. Janus based each of the Huntress' albums on a part of the Triple Goddess in neopaganism.


title: Jill Janus

text: In 2015, Janus disclosed to "Revolver" that she was living with bipolar disorder since her early teens, and had made numerous suicide attempts, as early as age of 16. She was diagnosed with bipolar disorder at age 20, then later diagnosed with schizoaffective disorder. Later in her life, she was experiencing dissociative identity disorder, schizophrenia and alcoholism.


title: Jill Janus

text: On August 14, 2018, Janus died by suicide near Portland, Oregon. Although some sources claim she died at the age of 43, she stated that she was born in September 1975, making her 42 years old at the time of her death.


title: Corin Tucker

text: Corin Lisa Tucker (born November 9, 1972) is an American singer, songwriter, and guitarist best known for her work with rock band Sleater-Kinney. Tucker is also a member of the alternative rock supergroup Filthy Friends, and previously recorded with the indie rock group Heavens to Betsy and The Corin Tucker Band.


title: Corin Tucker

text: "Entertainment Weekly" writes, "Corin Tucker’s place in rock history is already set in stone, and her work in the riot grrrl era is pretty much peerless, thanks to the muscular guitar style, otherworldly wail, and knack for punchy, pounding three-minute blasts she brought to such great heights with riot queens Sleater-Kinney." "Rolling Stone" called her “a punk-rock heroine."


title: Corin Tucker

text: Tucker was born in Eugene, Oregon, and spent her childhood in Grand Forks, North Dakota. There, her father was a college professor and her mother was a medical technician. Her father is also a folk singer and musician. She began studying piano when she was twelve. In high school back in Eugene, she was in a band with friends called This That.


title: Corin Tucker

text: Tucker says she "grew up on the Beatles" but that "her mind was completely blown" when she heard R.E.M.'s album "Murmur" when she was eleven. Her other musical influences include the Soundtrack from "The Wizard of Oz", Joan Jett & the Blackhearts' "I Love Rock 'N' Roll", The B52's, Pat Benatar's "Get Nervous," Television's "Marquee Moon," and Bikini Kill. Her first concert was to see the band X in Eugene around 1987.


title: Corin Tucker

text: In 1990, Tucker attended Evergreen State College in Olympia, Washington, where she studied film, political economy, and social change. She was also exposed to the music scene in Olympia. Tucker said, "I was 18 when I went to a show that Bratmobile and Bikini Kill played. It was February 14, 1991. …It was the first time I'd seen feminism translated into an emotional language. …For young women to be doing that, basically teenagers on stage, to be taking that kind of stance, that kind of power, was blowing people's minds. And it totally blew my mind. I was like, 'O.K., that's it. That's it for me — I'm going in a band, right now.'" The result was the band Heavens to Betsy.


title: Corin Tucker

text: In her first year at Evergreen, Tucker made a documentary about women in music. The documentary included footage of early shows by Bikini Kill and Bratmobile, and interviews with Beat Happening and Nirvana. Tucker graduated from college in 1994.


title: Corin Tucker

text: She says her role models are Maya Angelou, Nora Ephron, and Patti Smith. As Tucker puts its, "Women who have had really long careers and done a lot of different things."


title: Corin Tucker

text: Although she later relocated to Portland, Oregon, Tucker still describes herself as "a small-town girl" from Eugene.


title: Corin Tucker

text: Starting in 1991, Tucker has been a singer, guitarist, and songwriter in a number of rock bands. In 1999, "Esquire" wrote that Tucker "has been the most interesting singer in pop music since 1991, when she first opened her mouth in public, in a two-woman drums-and-guitar punk band with the wonderful name of Heavens to Betsy."


title: Corin Tucker

text: Tucker is usually the front person and lead singer. One reviewer noted, "Her voice is enormous, with a natural swing--the sort of swing that neither Tina Turner nor Mick Jagger has ever had, the ability to take a note and ring it like a bell in a tower."


title: Corin Tucker

text: Tucker was a founding member of the influential riot grrrl band Heavens to Betsy along with Tracy Sawyer, a longtime friend from Eugene, Oregon. Tucker played the first public show of her career when the band performed at the International Pop Underground Convention in August 1991. Heavens to Betsy recorded a split single with Bratmobile, and a number of singles for independent record labels. The band released a self-titled demo in 1992, the four-song 7" record "These Monsters Are Real" in 1992, the album "Calculated" in 1994, and the 7" four-song "Direction" in 1994. The band broke up in 1994. "Rolling Stone" wrote, "Heavens to Betsy [was] one of the standout acts connected to the riot-grrrl movement."


title: Corin Tucker

text: Heartless Martin, was Tucker's "one-off collaboration" with Becca Albee of Excuse 17. Heartless Martin released a five-song EP, "Tonight". One reviewer noted, "This EP is a definite stunner with heart breaking simple songs and lyrics highlighting Corin’s voice as it cuts through the lo-fi recording and lands square in the middle of your chest."


title: Corin Tucker

text: After Heavens to Betsy split in 1994, Tucker formed Sleater-Kinney with Excuse 17 member Carrie Brownstein and friend Lora McFarlane. Tucker wrote most of the lyrics, sang lead vocals, and played second guitar to Brownstein's lead, with the duo collaborating on music. Janet Weiss eventually replaced McFarlane on drums. In 1999, "Esquire" said Sleater-Kinney was "the best band in the world." They released seven albums over the span of eleven years before going on hiatus in 2006. On August 12, 2006, the band played what was supposed to be their final show at Crystal Ballroom in Portland. However, the band reunited and recorded "No Cities to Love" in 2015, followed by "The Center Won't Hold" in 2019, and "Path of Wellness" in 2021.


title: Corin Tucker

text: During her time with Sleater-Kinney, Tucker worked on a side project, Cadallaca, with organist Sarah Dougher and drummer STS of The Lookers. In 1998, Cadallaca released their first album "Introducing Cadallaca". They released an EP, "Out West", on Kill Rock Stars in 2000.


title: Corin Tucker

text: In April 2010, Tucker announced she was recording a solo album for Kill Rock Stars. Unwound's Sara Lund and Golden Bear's' Circus Lupus and Seth Lorinczi assisted Tucker with this project which was dubbed The Corin Tucker Band. The album "1,000 Years" was released on October 5, 2010, and was streamed via NPR. The album's eleven songs were different from other Tucker projects—many of the songs were slower folk and Americana, and Tucker played acoustic guitar. Tucker said the album is "definitely more of a middle-aged mom record, in a way. It's not a record that a young person would write... There's some sadness, some reinvention, some rebirth." She sited post-punk acts like the English Beat, The Raincoats, The Slits, and Sinead O'Connor's "The Lion and the Cobra" as influences for "1,000 Years."


title: Corin Tucker

text: Most reviews of the album were positive. "Rolling Stone" wrote, "She's not shredding the awesome vocal cords so much, but she gets fierce in other ways, trying on cellos and piano ballads. When she finally cranks it up Sleater-Kinney-style on 'Doubt,' it feels earned: a cry of self-determination, as inspiring as ever." "Pitchfork" said, "This album's strengths—its intimacy, its containment, its subtlety—are not the qualities that made Sleater-Kinney great, but it would be ungenerous to dismiss this because it's not as thrilling, confrontational, or exuberant." However, an "Entertainment Weekly" reviewer wrote that the album's songs "sound scrapbooked from other ’90s-centric acts (Liz Phair, Pavement) but never take on a form of their own." The band toured on both U.S coasts to support "1,000 Years", in addition to a few festival dates in other parts of the country.


title: Corin Tucker

text: The Corin Tucker Band's second album, "Kill My Blues", was released on September 18, 2012 and contained twelve songs. In an interview, Tucker said, "For this record, we really bonded, the four of us, being on tour and playing music together, so in writing this record, we all worked together in the practice space, writing these songs and just enjoying the writing process and everything that came out of it." The resulting songs cover "the finite nature of existence, the stalemate of our political climate, a moment in the transition from girlhood to womanhood…[and] love of different kinds." This album also sounded more like a Sleater-Kinney album than "1,000 Years." One reviewer wrote, "This album harks somewhat to the glory days of the Riot Grrrl Olympia scene of the late ’90s, but it’s by no means retrospective or reactionary." However, another reviewer correctly predicted "Kill My Blues" "will inevitably go down as one of the most underrated albums of the year." This album was also supported by a nationwide tour.


title: Corin Tucker

text: Alt-rock "supergroup" Filthy Friends is another side project for Tucker, with Tucker on lead vocals and R.E.M.'s Peter Buck on guitar, along with other musician friends rounding out the band. The two met when Tucker's husband worked on a film project with R.E.M. Formed in 2014, Filthy Friends has released two albums: "Invitation" (2017) and "Emerald Valley" (2019). On both albums, Tucker wrote the majority of the lyrics to match Buck's music.


title: Corin Tucker

text: On "Emerald Valley", she played Buck's Fender Musicmaster guitar. Tucker said, "It's a smaller-sized Fender guitar, and I love it. It's really different, and it makes me play differently in this band, because I usually play a Gibson Les Paul and I'm usually a rhythm guitar player, almost a bass player, in Sleater-Kinney."


title: Corin Tucker

text: Tucker has worked on a variety of other musical projects. She sang back-up vocals on two of Peter Buck's solo albums, including "Peter Buck" (2013). She sang a duet with Eddie Vedder of Pearl Jam for the title track of John Doe's EP "The Golden State" in 2008"." She also provided vocals for the song "Hard Sun" on Vedder's soundtrack for the 2007 film "Into the Wild". In 2013, she covered the title track "Shine On," for the album released by The Jim Henson Company as part of the Fraggle Rock's 30th anniversary celebration. In addition, her songs have appeared in the soundtracks of ten films or television shows.


title: Corin Tucker

text: Tucker has also dabbled in television and film. She appeared in two episodes of bandmate Carrie Brownstein's television show Portlandia, portraying a member of the fictional band Echo Echo. In addition, "Portlandia" was first filmed at Tucker's house and she was the camera crew.


title: Corin Tucker

text: Tucker is in the following films portraying herself: "The Punk Singer" (2013), "Burn to Shine 03: Portland, OR" (2006), and "Don't Need You: The Herstory of Riot Grrrl" (2005), as well as an episode of the television show "The L Word" (2006) and the web series "Sound Advice" (2015).


title: Corin Tucker

text: Tucker previously identified as a lesbian, but now identifies as bisexual. She came out to her family at 19. She briefly dated bandmate Carrie Brownstein at the beginning of Sleater-Kinney in May 1994, a fact that was revealed to the world in a now-infamous "Spin" article. Tucker called the article a "pain in the ass." She said, "We weren't asked about our personal lives in the interview. We talked about things we thought were really important, and what they printed was that we dated. It just came out as being gossip." Tucker wrote the Sleater-Kinney song "One More Hour" about her breakup with Brownstein.


title: Corin Tucker

text: Tucker has been outspoken in her support of the pro-choice movement. An ardent feminist, she believes it is more important than ever for woman to fight for equality. She also spoke against the Iraq War, despite offending audiences. In her songs with Filthy Friends, she has protested deforestation, U.S. Immigration and Customs Enforcement, and oil pipelines.


title: Corin Tucker

text: She got her only tattoo when she was eighteen—its the name Heavens to Betsy in cursive with a star on either side, on her ankle. Tucker married filmmaker Lance Bangs in June 2000 in Iceland. They have a son, Marshall Tucker Bangs (born March 8, 2001), and a daughter, Glory Bangs (born 2008). Marshall was premature and stayed in the hospital for a while.


title: Corin Tucker

text: Outside of music, she is in web development and interactive media for a healthcare company. In addition, she makes training and informational videos for the healthcare company. She also designed and runs a website for her father's business.


title: Simple Gifts

text: "Simple Gifts" is a Shaker song written and composed in 1848, generally attributed to Elder Joseph Brackett from Alfred Shaker Village.


title: Simple Gifts

text: The tune and lyrics were written by Elder Joseph Brackett (1797–1882) of the Alfred, Maine Shaker community, although there is some disagreement as to which community Elder Joseph belonged to when the song was written. Elder Joseph resided with the Sabbathday Lake Shaker Village in New Gloucester, Maine community before he was called to serve in the Ministry in 1848. For the next decade, he served the Community in Alfred, later returning to New Gloucester. However, the Alfred community's history makes no reference to "Simple Gifts," although there are several mentions of Elder Joseph.


title: Simple Gifts

text: The first known reference to "Simple Gifts" is an advertisement for a concert in October 1848 by the Shaker Family from the Society of Shakers of New Gloucester, Maine.


title: Simple Gifts

text: The song was largely unknown outside Shaker communities until Aaron Copland used its melody for the score of Martha Graham's ballet, "Appalachian Spring", first performed in 1944. (Shakers once worshipped on Holy Mount, in the Massachusetts portion of the Appalachians). Copland used "Simple Gifts" a second time in 1950 in his first set of "Old American Songs" for voice and piano, which was later orchestrated.


title: Simple Gifts

text: Several Shaker manuscripts indicate that this is a "dancing song" or a "quick dance". "Turning" is a common theme in Christian theology, but the references to "turning" in the last two lines have also been identified as dance instructions. When the traditional dance is performed properly, each dancer ends up where they started, "come 'round right".


title: Simple Gifts

text: A manuscript of Mary Hazzard of the New Lebanon, New York Shaker community records this original version of the melody.


title: Simple Gifts

text: The song resembles, to a slight extent, several repetitions of the opening measures of William Byrd's renaissance composition, "The Barley Break", which Byrd intended to imitate country children playing a folk game. Similarly, Brackett is claimed to have come up with the song as an imitation of what folk music sounds like.


title: Simple Gifts

text: A somewhat similar musical theme arises also in a brass ensemble work, "Canzon per sonare no. 2", by Giovanni Gabrieli (c.1555-1612).


title: Simple Gifts

text: English songwriter Sydney Carter adapted the original American Shaker tune and lyrics for his hymn "Lord of the Dance" published and copyrighted in 1963.


title: Simple Gifts

text: In 1996, the Carter hymn were adapted without authorization or acknowledgments of the origins of the tune or Carter's lyrics by Ronan Hardiman for Michael Flatley's dance musical, "Lord of the Dance". The melody is used at various points throughout the show, including the piece entitled, "Lord of the Dance." The musical's title and version of the "Lord of the Dance" have led to some confusion that the song and lyrics are Celtic; however they are of American and English origin.


title: 1973 NBA Finals

text: The 1973 NBA World Championship Series was the championship series of the 1972–73 National Basketball Association (NBA) season, and the culmination of that season's playoffs. The Eastern Conference champion New York Knicks defeated the Western Conference champion Los Angeles Lakers 4 games to 1. The series was an exact reversal of the prior year, with the Knicks winning Game 1 and the Lakers taking the next four games. Knicks center Willis Reed was named as the NBA Finals MVP.


title: 1973 NBA Finals

text: The Los Angeles Lakers entered the 1973 NBA Playoffs as co-favorites in the West with the Milwaukee Bucks, but both teams faced inspired opponents in the first round. The Chicago Bulls gave the Lakers all they could handle before the Lakers came from behind in Game 7 to take the series. The Lakers next faced the Golden State Warriors for the Western Conference Championship (the Warriors had upset the Bucks in six games). In Game 1, the Lakers won by 2, and in Game 2 the Lakers won by 10. In Game 3 at Oakland, the Lakers routed the Warriors 126-70, but the Warriors won Game 4 to send the series back to Los Angeles. In the Forum, the Lakers took Game 5 and advanced to their fifth NBA Finals series in six seasons.


title: 1973 NBA Finals

text: One year after their NBA Finals loss, the Knicks were back in the playoffs. For some of the Knicks, including Jerry Lucas and Earl Monroe, this was probably their last shot at an NBA title. In the first round they paired against the Baltimore Bullets. The Knicks won Game's 1 and 2 in New York, but lost Game 3 at Baltimore (in that game, the Bullets used a strange lineup of two centers and three guards). New York would take Games 4 and 5 Walt Frazier averaging 20 points per game in this series. In the Conference Finals, the Knicks faced the 68-14 Boston Celtics, who not only had the league's best record but also, to that point, the third-best won-lost record in NBA history. The Celtics routed New York, 134-108, Game 1 at the Boston Garden, but the Knicks returned the favor with a 129-96 rout in Game 2 at Madison Square Garden. The Knicks then beat the Celtics in Game 3 in Boston, and took a 3-1 series lead with a double overtime Easter Sunday win back in New York. Boston came back with two critical wins, winning 98-97 in Boston on two Paul Silas free throws, then regaining the home-court advantage with a 110-100 win New York in Game 6. For Game 7, however, the Celtics were without their star John Havlicek, who was nursing an elbow injury. In that Game 7, played in Boston, the Celtics unbeaten record in seventh games played in Boston Garden was snapped when New York won easily, 94-78.


title: 1973 NBA Finals

text: After losing the first game, the Knicks reeled off four straight wins to reclaim the NBA title. This is the Knicks' most recent NBA Championship to date. New York would not make it back to the NBA Finals until 1994.


title: 1973 NBA Finals

text: This would also be the last Finals appearance of the decade for the Lakers. Their next appearance would be in 1980, which would be the first of nine Finals appearances in 12 years for the franchise.


title: 1973 NBA Finals

text: Game 5 of the series was Wilt Chamberlain's last game played in the NBA. Chamberlain scored the last points of the game, and of his career, on an uncontested fast break dunk with one second remaining.


title: 1973 NBA Finals

text: ABC televised its last NBA Finals, until 2003. This is, to date, the last time a New York/Los Angeles NBA Finals of any combination has taken place, as well as the fifth-to-last championship series contested by both cities in any sport (the 1981 World Series is the last matchup in the 20th century, and the 2014 Stanley Cup Finals is the latest).


title: Great Blizzard of 1888

text: The Great Blizzard of 1888, also known as the Great Blizzard of '88 or the Great White Hurricane (March 11–14, 1888), was one of the most severe recorded blizzards in American history. The storm paralyzed the East Coast from the Chesapeake Bay to Maine, as well as the Atlantic provinces of Canada. Snow fell from in parts of New Jersey, New York, Massachusetts, Rhode Island, and Connecticut, and sustained winds of more than produced snowdrifts in excess of . Railroads were shut down and people were confined to their homes for up to a week. Railway and telegraph lines were disabled, and this provided the impetus to move these pieces of infrastructure underground. Emergency services were also affected.


title: Great Blizzard of 1888

text: The weather was unseasonably mild just before the blizzard, with heavy rains that turned to snow as temperatures dropped rapidly. On March 12, New York City dropped from to , and rain changed to snow at 1am. The storm began in earnest shortly after midnight on March 12 and continued unabated for a full day and a half. In a 2007 article, the National Weather Service estimated that this nor'easter dumped as much as of snow in parts of Connecticut and Massachusetts, while parts of New Jersey and New York had up to . Most of northern Vermont received from to .


title: Great Blizzard of 1888

text: Drifts averaged , over the tops of houses from New York to New England, with reports of drifts covering three-story houses. The highest drift was recorded in Gravesend, Brooklyn at . of snow fell in Saratoga Springs, New York; in Albany, New York; in New Haven, Connecticut; and in New York City. The storm also produced severe winds; wind gusts were reported, although the highest official report in New York City was , with a gust reported at Block Island. On March 13, New York City recorded a low of , the coldest so late in the season, with the high rising to only .


title: Great Blizzard of 1888

text: In New York, neither rail nor road transport was possible anywhere for days, and drifts across the New York–New Haven rail line at Westport, Connecticut, took eight days to clear. Transportation gridlock as a result of the storm was partially responsible for the creation of the first underground subway system in the United States, which opened nine years later in Boston. The New York Stock Exchange was closed for two days. A full two day closure would not occur again until Hurricane Sandy in 2012.


title: Great Blizzard of 1888

text: Similarly, telegraph infrastructure was disabled, isolating Montreal and most of the large northeastern U.S. cities from Washington, D.C. to Boston for days. Following the storm, New York began placing its telegraph and telephone infrastructure underground to prevent their destruction.


title: Great Blizzard of 1888

text: Fire stations were immobilized, and property loss from fire alone was estimated at $25 million (equivalent to $ million in ).


title: Great Blizzard of 1888

text: The blizzard resulted in the founding of the Christman Bird and Wildlife Sanctuary located near Delanson, New York.


title: Great Blizzard of 1888

text: From Chesapeake Bay through the New England area, more than 200 ships were either grounded or wrecked, resulting in the deaths of at least 100 seamen. More than 400 people died from the storm and the ensuing cold, including 200 in New York City alone. Efforts were made to push the snow into the Atlantic Ocean. Severe flooding occurred after the storm due to melting snow, especially in the Brooklyn area, which was susceptible to flooding because of its topography.


title: Great Blizzard of 1888

text: Not all areas were notably affected by the Blizzard of 1888; an article in the "Cambridge Press" published five days after the storm noted that the "fall of snow in this vicinity was comparatively small, and had it not been accompanied by a strong wind it would have been regarded as rather trifling in amount, the total depth, on a level, not exceeding ten inches".


title: Great Blizzard of 1888

text: On 1 October 1888, an article appeared in the first issue of the National Geographic Society magazine about the great blizzard. It was written by Edward Everett Hayden and described the blizzard and the courageous and successful struggle, told by boat-keeper Robert Robinson, of the crew from the pilot-boat "Charles H. Marshall, No. 3".


title: Western European Time

text: Western European Time (WET, ) is a time zone covering parts of western Europe and consists of countries using (also known as Greenwich Mean Time, shortly called GMT). It is one of the three standard time zones in the European Union along with Central European Time and Eastern European Time.


title: Western European Time

text: All the above countries except Iceland implement daylight saving time in summer (from the last Sunday in March to the last Sunday in October each year), switching to Western European Summer Time (WEST, ), which is one hour ahead of WET. WEST is called British Summer Time in the UK and is legally defined as Irish Standard Time in Ireland.


title: Western European Time

text: The nominal span of the UTC±00:00 time zone is 7.5°E to 7.5°W (0° ± 7.5°), but does not include the Netherlands, Belgium, Luxembourg, France, Gibraltar or Spain (except Canary Islands) which use Central European Time (CET) even though these are mostly or completely west of 7.5°E. Conversely, Iceland and eastern Greenland use UTC±00:00 although both are west of 7.5°W. In September 2013, a Spanish parliamentary committee recommended switching to UTC±00:00.


title: Western European Time

text: Until the Second World War, France used UTC±00:00. However, the German occupation switched France to German time, and it has remained in CET since then. Two other occupied territories, Belgium and the Netherlands, did the same, and Spain also switched to CET in solidarity with Germany under the orders of General Franco.


title: Western European Time

text: In the United Kingdom, from 1940 to 1945 British Summer Time (BST=CET) was used in winters, and from 1941 to 1945 and again in 1947, British Double Summer Time (BDST=CEST) was used in summers. Between 18 February 1968 and 31 October 1971, BST was used all year round.


title: Western European Time

text: In Ireland, from 1940 to 1946 Irish Summer Time (IST=CET) was used all year round, with no 'double' summer time akin to that in the United Kingdom. Between 18 February 1968 and 31 October 1971, Irish Standard Time was used all year round.


title: Western European Time

text: In Portugal, CET was used in the mainland from 1966 to 1976 and from 1992 to 1996. The autonomous region of the Azores used WET from 1992 to 1993.


title: Western European Time

text: These areas are actually located between 7°30′E and 7°30′W (nominally UTC+0) but use (Central European Time, nominally for longitudes between 7°30′E and 22°30′E):


title: English defamation law

text: Modern libel and slander laws in many countries are originally descended from English defamation law. The history of defamation law in England is somewhat obscure; civil actions for damages seem to have been relatively frequent as far back as the Statute of Gloucester in the reign of Edward I (1272–1307). The law of libel emerged during the reign of James I (1603–1625) under Attorney General Edward Coke who started a series of libel prosecutions. Scholars frequently attribute strict English defamation law to James I's outlawing of duelling. From that time, both the criminal and civil remedies have been found in full operation.


title: English defamation law

text: English law allows actions for libel to be brought in the High Court for any published statements which are alleged to defame a named or identifiable individual in a manner which causes them loss in their trade or profession, or damages their reputation. Allowable defences are justification, fair comment, and privilege. A defamatory statement is presumed to be false, unless the defendant can prove its truth. Furthermore, to collect compensatory damages, a public official or public figure must prove actual malice. A private individual must only prove negligence (not exercising due care) to collect compensatory damages.


title: English defamation law

text: English defamation law puts the burden of proof on the defendant, and does not require the plaintiff to prove falsehood. For that reason, it has been considered an impediment to free speech in much of the developed world. In many cases of libel tourism, plaintiffs sued in England to censor critical works when their home countries would reject the case outright. In the United States, the 2010 SPEECH Act makes foreign libel judgements unenforceable and unrecognisable by U.S. courts if they don't comply with U.S. protections for freedom of speech and due process, which was made largely in response to the English laws.


title: English defamation law

text: The Defamation Act 2013 substantially reformed English defamation law in recognition of these concerns, by strengthening the criteria for a successful claim, mandating evidence of actual or probable harm, and enhancing the scope of existing defences for website operators, public interest, and privileged publications. The 2013 law applies to causes of action occurring after its commencement on 1 January 2014.


title: English defamation law

text: The earlier history of the English law of defamation is somewhat obscure; Anglo-Saxon law practiced in England after the fall of the Roman Empire seemed to follow the idea of iniuria, allowing plaintiffs who had been insulted to accept monetary compensation instead of seeking revenge. Civil actions for damages seem to have been tolerably frequent as far back as the reign of Edward I (1272–1307). There was no distinction drawn between written and spoken words, and when no monetary penalty was involved, such cases fell within the old jurisdiction of the ecclesiastical courts, which were only finally abolished in the eighteenth century. It seems uncertain whether or not any generally applicable criminal process was in place.


title: English defamation law

text: The crime of "scandalum magnatum" (insulting the peers of the realm through slander or libel) was established by the Statute of Westminster 1275, c. 34, but the first instance of criminal libel is generally agreed to be the "De Libellis Famosis" case, tried in the Star Chamber in the reign of James I by Edward Coke who, in his judgement on the case, said that a person's "good name ... ought to be more precious to him than his life". The case centred around an "infamous" libel about John Whitgift, the late Archbishop of Canterbury. It was held that libel against a private person could be considered a crime if it could provoke revenge that would threaten a breach of the peace, that libel against the monarch or government could be illegal, even if true, because "it concerns not only the breach of the peace, but also the scandal of government", and that a libel against a public figure was a more serious offence than one against a private person. This set a precedent in common law that judges decided all factors except that of publication; therefore, a guilty verdict from a jury in a libel trial resolved only that the material had been published while the judge decided whether a libel had been committed.


title: English defamation law

text: The Libel Act 1843 enacted several codifications of defamation law in the UK, including the offer of an apology and the claim that the libel was without malice or neglect as mitigating evidence, as well as malicious and knowingly false libel as aggravating evidence.


title: English defamation law

text: Up until the Defamation Act 2013, Parliament had enacted defamation law reforms about every 50 years, with the Defamation Acts of 1996 and 1952 being the two most recent. Most of these reforms have focused on trying to alter the law around the high burden of proof on defendants and the large damages awarded in past cases, which critics have said stifles free speech, and perceived overreach of English courts when they exercise jurisdiction in cases which in reality have little connection to the UK, giving rise to 'libel tourism'.


title: English defamation law

text: The common law crimes of criminal libel and seditious libel were abolished for UK citizens by the Coroners and Justice Act 2009, and the crime of blasphemous libel was abolished as a crime by the Criminal Justice and Immigration Act 2008.


title: English defamation law

text: An increase in defamation litigation has been noted in England from the early seventeenth century. In the south of England, this litigation rose most sharply in cases of sexual slander and were notable for the increasing number of women pursuing litigation in defence of their sexual reputation. In one respect, this pattern has been linked with increasing legal access for women. In another respect, however, it has been linked to the rise of "middling" traders in urban centres and an increasing concern with the defence of family reputation in which a woman's sexual integrity was coterminous with the integrity of her household. A similar pattern has been noted in the northern English jurisdictions but this rise seems not to have occurred until the latter years of the seventeenth century.


title: English defamation law

text: English law allows actions for libel to be brought in the High Court for any published statements which are alleged to defame a named or identifiable individual (or individuals; under English law companies are legal persons, and allowed to bring suit for defamation) in a manner which causes them loss in their trade or profession, or causes a reasonable person to think worse of him, her or them.


title: English defamation law

text: A statement can include an implication; for instance, a photograph of a particular politician accompanying a headline reading "Corrupt Politicians" could be held as an allegation that that politician was personally corrupt. Once it is shown that a statement was published, and that it has a defamatory meaning, that statement is presumed to be false unless the defendant is able to raise a defence to his defamatory act.


title: English defamation law

text: Under English law, because companies are legal persons they can sue on the basis of libel the same as natural persons. Cases supporting this principle go as far back as the 19th century, such as "South Hetton Coal Co. Ltd. v. North Eastern News Ass'n Ltd." [1894], and extend to more recent cases such as "Bognor Regis U.D.C. v. Campion" [1972] and the McLibel case, when McDonald's sued several protesters.


title: English defamation law

text: The 2006 case of "Keith-Smith v Williams" confirmed that discussions on the Internet were public enough for libel to take place.


title: English defamation law

text: While in libel cases there is no burden to prove damage done to reputation, there generally is in slander cases. In some specific circumstances however, there is no need to prove that damage was caused by a slander; this is called 'slander actionable per se'. The Faulks Committee, a parliamentary committee set up to propose reforms to UK defamation law, recommended in 1975 that this distinction between libel and slander should be abolished.


title: English defamation law

text: Slander imputing "loathsome" or contagious diseases also used to be actionable per se under English common law. It was removed by section 14 of the Defamation Act 2013, but remains in other jurisdictions.


title: English defamation law

text: Under section 166 of the Broadcasting Act 1990 and section 4 of the Theatres Act 1968, statements both within a performance of a play or in any programme included in a programme service can be considered publication in permanent form. Neither of these sections apply to Scotland.


title: English defamation law

text: Section 1 of the Defamation Act 1952 had allowed the "broadcasting of words by means of wireless telegraphy" to be considered publication in permanent form. This section was repealed and replaced by the Broadcasting Act 1990.


title: English defamation law

text: In the common laws of libel, it is frequently said that the "burden of proof" in English defamation law falls upon the defendant. However the Defamation Act 2013 added a requirement that the claimant show "serious harm" was caused or was likely to be caused to the claimant's reputation, adding a significant burden of proof upon the claimant.


title: English defamation law

text: While specific legal requirements may differ depending on local laws, the common laws of libel generally only require the claimant to prove that a statement was made by the defendant, and that it was defamatory – a relatively easy element to prove. The claimant is not required to prove that the content of the statement was false. On the other hand, as a defendant in the common laws of libel, proving the truth of the statement would be considered an affirmative defence.


title: English defamation law

text: If a claimant is found guilty of launching a defamation lawsuit despite that the statement at hand is, in fact, accurate, the defendant may launch a counterclaim for fraud, recovery of unjustified settlement funds, and other factors. An example is that of the "Sunday Times" and cyclist Lance Armstrong. Armstrong was paid £300,000 by the newspaper after a libel claim in 2004. Following the report by USADA in 2012 on Armstrong's doping, the "Sunday Times" stated it might attempt to recover the money it lost and might counterclaim Armstrong for fraud. Armstrong ultimately settled with the paper for an undisclosed sum in 2013.


title: English defamation law

text: In certain instances, including but not limited to those involving public interests or responsible journalism, the burden of proof will be increasingly complex and require additional proceedings that may remain ongoing for years and come at significant costs.


title: English defamation law

text: As a defendant in a defamation lawsuit, in addition to proving the truth of the statement which would be considered an affirmative defence, a number of additional defences often employed may include the following:


title: English defamation law

text: This defence arises if the defendant shows that the statement was a view that a reasonable person could have held, even if they were motivated by dislike or hatred of the plaintiff.


title: English defamation law

text: The honest opinion defence (formerly the fair comment defence) is sometimes known as "the critic's defence" as it is designed to protect the right of the press to state valid opinions on matters of public interest such as governmental activity, political debate, public figures and general affairs. It also defends comments on works of art in the public eye such as theatre productions, music, and literature. However, fair comment, and justification defences will fail if they are based on misstatements of fact.


title: English defamation law

text: An example of this arose in "London Artists Ltd v Littler" (1969). When a whole group of actors resigned from a play the director wrote a letter to each of them and to their agent company, accusing them of plotting against him. The case was decided to be a matter of public concern because of the general interest in entertainment.


title: English defamation law

text: For an opinion to be honest opinion it must be based upon facts, as highlighted in "Kemsley v Foot" [1952] AC 345. The politician and journalist Michael Foot had printed an article in "Tribune", a left-wing newspaper, condemning the London "Evening Standard" for unethically publishing a certain story. Lord Kemsley, who owned other newspapers, maintained that the article's headline, "Lower than Kemsley", impugned the standards of the Kemsley press. The defence of fair comment was allowed to stand.


title: English defamation law

text: There is also no need for the perpetrator of the comment to actually believe in it as in court the comment will be measured according to an "objective" test. In "Telnikoff v Matusevitch" (1992), Telnikoff wrote an article in "The Daily Telegraph" criticising the BBC Russian Service for over-recruiting people from ethnic minority groups. Matusevitch replied accusing the claimant of being a racist. The House of Lords held that he had to show that the comment was based around the article, which would make it fair comment as it was possible most people would not know why he was making such a statement.


title: English defamation law

text: A defence of fair comment can fail if the defendant shows malice, as in "Thomas v Bradbury, Agnew & Co." (1906); the defendant not only criticised the claimant's book but made many personal slurs against the author, invalidating the defence.


title: English defamation law

text: The Defamation Act 2013 replaced the common law defence of fair comment with the statutory defence of honest opinion. Change to the name of the defence had been suggested in 1975 by the Faulks Committee on the basis that it protected "unfair" comment as well as fair comments. Renaming of the defence was recommended by the Supreme Court in "Spiller v Joseph" where Lord Phillips suggested a change to "honest comment"—the Court of Appeal in "British Chiropractic Association v Singh" had previously suggested "honest opinion".


title: English defamation law

text: If the defendant's comments were made in Parliament, or under oath in a court of law, they are entitled to absolute privilege. This privilege is absolute: qualified privilege protects only the communication of the complained statement. There can be no investigation into whether remarks made in a situation of absolute privilege are defamatory.


title: English defamation law

text: There are several situations where the defence of qualified privilege applies. Reports and remarks of Parliamentary proceedings, as well as reports of judicial proceedings attract qualified privilege. These have to be "fair and accurate"; as Lord Denning stated in "Associated Newspaper Ltd v Dingle", if the writer "garnishes" and "embellishes" such reports with any form of circumstantial evidence, the defence cannot apply. Additionally, where there is a mutual interest between two parties, statements deemed to be defamatory are protected where it can be proved there is a duty to impart them. The case of "Watt v Longsdon" exemplifies this principle, and the limitations of it. Here, the director of a company informed the chairman of alleged sexual misconduct involving Watt. This communication was deemed privilege, but the informing of such suspicion to the claimant's wife was not.


title: English defamation law

text: The defence has seen expansion recently in light of "Reynolds v Times Newspapers Ltd", where the House of Lords—drawing principally on Lord Nicholls' judgement—established that the mass media could be entitled to the defence, where criteria of "responsible journalism" (further expanded upon in "Loutchansky v Times Newspapers Ltd") were met. This expansion was confirmed in the case of "Jameel v Wall Street Journal Europe", and has been described as giving newspapers protections similar to the First Amendment to the United States Constitution. The defence used in "Reynolds v Times Newspapers Ltd" was abolished by the Defamation Act 2013, Section 4 subsection 6. This does not have an effect on the common law defence based on a reciprocity of duty or interest as between the maker of the statement and the recipient.


title: English defamation law

text: See section 15 of, and Schedule 1 to, the Defamation Act 1996. See also section 1(5) of the Public Bodies (Admission to Meetings) Act 1960, section 121 of the Broadcasting Act 1996, section 79 of the Freedom of Information Act 2000 and section 72 of the Learning and Skills Act 2000.


title: English defamation law

text: This defence was abolished by s4(6) Defamation Act 2013, being replaced with the statutory defence of publication on a matter of public interest.


title: English defamation law

text: In general, everyone involved in the dissemination of the defamation is liable as having published it. But it has been held that some forms of distribution are so mechanical that the actor ought not to be held liable unless he/she ought to have realized that there was defamation involved. The defence is known as innocent dissemination or mechanical distributor.


title: English defamation law

text: A claim of defamation is defeated if the defendant proves on the balance of probabilities that the statement was true. If the defence fails, a court may treat any material produced by the defence to substantiate it, and any ensuing media coverage, as factors aggravating the libel and increasing the damages. A statement quoting another person cannot be justified merely by proving that the other person had also made the statement: the substance of the allegation must be proved.


title: English defamation law

text: Section 8(3) of the Rehabilitation of Offenders Act 1974 provides that nothing in section 4(1) of that Act prevents the defendant in any action for libel or slander begun after the commencement of that Act by a rehabilitated person, and founded upon the publication of any matter imputing that the plaintiff has committed or been charged with or prosecuted for or convicted of or sentenced for an offence which was the subject of a spent conviction, from relying on any defence of justification which is available to him, or restrict the matters he may establish in support of any such defence.


title: English defamation law

text: But a defendant in any such action is not, by virtue of the said section 8(3), entitled to rely upon the defence of justification if the publication is proved to have been made with malice.


title: English defamation law

text: The Act does not apply to offences that warrant a 4-year prison sentence or more, which can never be spent.


title: English defamation law

text: In an action for libel or slander in respect of words containing two or more distinct charges against the plaintiff, a defence of justification does not fail by reason only that the truth of every charge is not proved if the words not proved to be true do not materially injure the plaintiff's reputation having regard to the truth of the remaining charges. In other words, to succeed in their defence of justification, the defendant need not prove every charge to be true, just enough of the charges so that the remaining charges do not on their own constitute a material injury to the plaintiff's reputation.