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"Organic Remarketing" With Google Search And Adwords
Organic Remarketing is a term I coined to describe an added and potentially overlooked organic benefit in Google Search results from using Adwords advertising. It seems that the term is indeed something new since a Google search on "Organic Remarketing" yields no exact matches. Additionally, the concept involved does not seem to have ever sparked much discussion on the web which is interesting considering that it is a definite advantage in terms of customer acquisition and keeping prospects in your sales funnel.
It is common knowledge that Google Search collects and stores information about users' browsing habits in order to enhance the user experience for individuals. This has been the case for a number of years and is just one more component of the complex process that the Google search engine uses when finding the best answers to each query made. In the image to the left you see a screen shot that describes the kind of data that Google collects and stores for you in your Web History. The type of data that is pertinent to this story is; "Ads you respond to by clicking the ad itself or completing a transaction on the advertiser's site"
This data is what Google Adwords uses when an advertiser is running a Remarketing campaign on Adwords. After someone visits an advertiser's website Google can show that person the Advertiser's ads for up to 30 days on all of the sites that are part of the Google Display Network. This is a great way to keep previous visitors to your site aware of your business and in your marketing funnel. It seems to me as though there may be a similar benefit to be had in organic searches as well.
The fact that the websites that you visit play a role in your future search results (if you are signed into Google accounts while browsing) is established as I said. To illustrate this I did two screen shots (below). In the first I searched for the term Log Home without being signed into the search engine or a Google account within the browser and with my previous browsing history deleted. My location was set in search to USA to give the most broad based set of results possible for the term.
In the second image I was signed into the Chrome browser with my normal Google account and my browser history was left in place. This is important because I have been doing quite a few searches for log home related items in the last month. I have done organic searches and visited sites via Adwords ads. One site that I have visited more than once through both types of links is Timberhaven Log Homes and in these images you can see the result of these visits in my organic search results. In other words, it is an example of Organic Remarketing.
On the left side of the image you see the results from a search done on the term Log Homes without being logged into the search engine and after having erased my browser history. Timberhaven Log Homes does show up on the first page of Google search (A). Four other log home companies also show up in these search results and in this case they are above Timberhaven.
While having your company show up on the first page of search results nationally in this kind of search is great all by itself, in the second half of the image (right side) it gets even better. In this case I was signed into the browser and my browsing history was intact. As you see Timberhaven came up again along with a Google+ post from the Timberhaven Google+ account (C) because I followed them on Google+.
In addition, a result came up in the second search that did not appear in the first search and it ranked highly. The Log Home Design Center (B) is another site that is owned by Timberhaven Log Homes but is on a separate domain. That site came up because I had previously visited it. At the bottom of search results for previously visited pages there may be a small note telling you when you last visited the page.
The overall effect is that three of the four other log home companies that appeared in the first search do not even appear in the second set of search results in order to make room for the sites from my own web history. They have been replaced by listings associated with Timberhaven log homes. As a business the benefit of Organic Remarketing is obvious at this point. It effectively keeps you front and center in search results of those people who have previously visited your website and as a result can potentially block competitor's searches from showing up. The effect can be had from Google+ as well as general search so I included both in this article.
The only requirement is that the person has to have visited your site before. Does a visit to your site via someone clicking on your Adwords ad count as a visit in this respect though? It is true that Google Search does not count traffic volume from Advertising as a ranking factor in Google organic search results but that is different. That is the general ranking of the site in search results on the web no matter who is doing the search or whether or not they are signed into the search engine. In the case of the example in this story I am talking about the personalized search results seen only by the person who has visited your site before and is signed into Google while doing the search.
I have not found a reliable answer to this question yet either from contacts at Google or via search. But I have not had anyone tell me it was not so either so it seems as though this may be a somewhat ignored part of marketing on the web. Therefore I do think that the concept of Organic Remarketing does deserve some serious consideration. After all, why should visitors to your site who have gotten there via clicking on one of your Adwords ads not be the just as interested in seeing your site turn up in organic search results for them as someone who visited your site through a link on another website or in an email or even by your URL directly into their browser from your business card or a newspaper ad? In all cases they did the same thing; they visited your website.
There is at least one instance in which this definitely does work in a slightly modified way. People who follow your business or personal profile on Google+ (those who circle you) are likely to see your Google+ posts show up in their search results when signed into Google and doing a search on a term related to your or your business such as products and services, example in image above, right side results (C).
In the case of Google+ there is not any restriction on the source that the people who follow you come from. Whether by a direct link, a referral or Adwords the result is the same. If they follow you then they will probably get to see your posts in a preferred location in search results. Of course that does require a second action on the part of someone other than just visiting your website. They have to decide to subscribe to your Google+ profile. However there is nothing wrong with asking people to do just that on the landing pages that you create for your Adwords campaigns (example below).
If you keep the concept of Organic Remarketing in mind it can help you create more effective content on your website/blog and on Google+. If you assume that at least part of the people who visit your site as a returning visitor are coming from organic search results on a related term who may have visited your site before then you can craft your Google+ posts to include keywords that will appeal to that demographic which will help bring them back to your site again much in the same way that you do when creating content to bring people to your site for the first time. It is all part of ongoing SEO and creating content that is optimized for search is already (hopefully) part of your ongoing marketing strategy on the web.


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As a volunteer director of a NFP Community Interest Company I think that the notion of charging corporation tax on surpluses undermines the core principle of both the 'not for profit' and 'community interest' principles. My proposal is to abolish corporation tax for Community Interest Companies where the profit is being reinvested back into community benefits and especially where there are no paid staff.
My organisation is dependant upon securing grants from various bodies to help us deliver a community radio service. We have about 80 volunteers, no paid staff and an annual budget of about £15K. If we secure a grant for a project in the 11th month of our financial cycle, the money appears as a 'profit' on the accounts, which would be balanced in the following year as a 'loss'. We are required to make our corporation tax return within the following few months and are therefore subject to paying the tax on grant funding that has been given to us for delivering a specific community benefit. This makes no sense.
This is important for several reasons.
1. The Community Interest Companies were established to provide an alternative vehicle to the charity plus trading company model so often used by organisations. A CIC can't be a charity and there are swings and roundabouts.However, the imposition of corporation tax on notional surpluses makes this a more difficult entity to manage, especially for smaller organisations.
2. The purpose of NFP CICS is to deliver community benefits and, although they can make surpluses, these 'profits' are there to enable the CIC to deliver more community benefits.
3. The amount of volunteer work required to attract grants or to develop revenue is disproportionately higher than in normal companies – mainly because volunteers have to do their day jobs as well. The prospect of having to lose hard earned funding to corporation tax is extremely demotivating at a time when we, as a country, want more people to take part in the Big Society.
4. Many grants come from local government. It seems pointless for local government to make a grant to enable a community benefit and then central government to take a % away because the costs of service delivery haven't yet been borne.
5. Although I accept and understand that CICs should pay corporation tax on earned income that generates a surplus, perhaps there needs to be a change in how we account for grant funding or perhaps an exemption that applies to CICs that are predominatly volunteer based.
fantastic idea,
we at truly local cic are facing a real problem in that we received approx 30k in funding and have spent the majority of this on fixed assets, which as i undestand can be written down at a rate of 25% a year leaving
us with having to pay corporation tax on the ramaining asset value with money that we dont have as we were required to spend all the grant monies we received on setting up the cic. How about being able to allow cics
100% tax relief on all expenditxure in the
1st year of setting up.

subset: commoncrawl


text: Apex Report post Posted January 20, 2015 no. it's a common issue with V2 gearboxes however it should be lessened by the fet. Typically it's because power is lost before the cycle has been completed. ie the piston is almost all the way back before power is lost but there isn't enough ampage from the battery/motor doesnt have enough torque to pull the piston that little bit more to release it. It could be a fet issue, a motor issue or you not pulling the trigger all the way to the "bite" point (again, the mosfet unit should prevent this last one assuming that the fet is the standard type not the naff plug n play type) That sounds like the issue I get in my G&P XM177 and it has a fet in it.... odd. Share this post Link to post Share on other sites


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Day care centers are highly effective places where kids can get nurtured when young. It is crucial to get a good school so that children grow uprightly. Considering a Daycare Hoboken can be a wise move. It is because the school has very experienced teachers who can give children the best of service. When looking for an excellent care center, the below points can be of help.
A good daycare in Hoboken NJ should have a spacious playground. Children are fond of playing hence the need for ample space. Exercise is imperative to children because it makes them active and physically fit. Also, through this teachers can identify the talented kids in games such as football and athletics. When teachers notice such, they should come in and nurture the talent of the child.
It is important for the management to maintain a good number of teachers. When conducting interviews, it is important to make the process flawless. There should be no favors extended in the process so that the best teachers get acquired. All teachers ought to get employed by merit so that they value their jobs. Such teachers come in handy especially in times when there is a high intake of children.
It is important for the school to have a reliable program of events. The program should get followed so that there is order in all operations. All activities should get included in this program for the purpose of uniformity. There should be a balance in these activities so that kids do not get bored. When teaching children, educators should break the boredom through singing and dancing.
The management should ensure that there is a high level of hygiene. When handling kids, dirt should get avoided so that they do not get infected. All areas of the care center should get cleaned thoroughly especially the washrooms. Places that kids come into direct contact with ought to be spotless as well. Children are very curious and like touching everywhere while playing hence the need for regular clean up.
Teachers in this city should observe the discipline of kids keenly to ensure they do not misbehave. It is important for them not to repeat the same mistake after being corrected. Appropriate mannerisms are imperative in making sure that children follow the proper behavior. This guidance helps them to become excellent people in the society. It also helps in ensuring that the behavior of children gets streamlined.
Educators must be experienced in this field. They must be knowledgeable in handling kids with different temperaments. They should, therefore, be parents so that they understand kids with ease. For a smooth flow of activities, the management ought to ensure that they get skilled teachers. It will make managing the kids easier due to the experience they have with toddlers.
A great care center in this city ought to provide healthy food to the kids. Since children grow rapidly, they need healthy meals all the time. It is important that they eat a balanced diet because they spend most of their daytime in school. Teachers should make sure that all kids eat without fail. Children with eating challenges should get guided accordingly.
When you are searing for information about daycare Hoboken locals can visit the web pages here today. More details are available at http://kidzcitydaycare.com now.


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Wallapop is a free mobile application for users to sell and buy stuff offered in its database. As a big community, this app can offer a lot of things from a wide variety of categories which are close to you. With this app, you just need to take a screenshot of your product and upload it next to a short description. In a few seconds you will have your item on the app.
Wallapop is meant to be like the closest virtual flea market in the world, always showing the nearest items from you. Finally, buying and selling through the Internet will be easy and safe, since Wallapop only shows you products within 1km radius and it will not show your personal information for commercial purposes.
Unlike eBay, Wallapop makes accurate results and only shows products around you. It uses your location for having the finest search and you can log in with Facebook, in which it will take your personal info from there to create your account. This is a good way of earning money with safe products, as well as to provide users with a nice purchase experience since they can easily get in touch with their sellers.
How to buy with this application
After the download of Wallapop you have to create a free account and select your location. Once you do that, you will start seeing the most popular items on sale, the users who sell them and the price. If you have an item you don't want anymore, you just have to take a picture –you can upload up to four- and the rest of users will see your offer. They will see what you are selling and you will earn some fresh money.
As a virtual flea market, it lets you get rid of your old stuff and allows other users to enjoy them
On the other hand, if you want to buy new stuff in Wallapop you can search for items by taking a look at the different categories Wallapop counts with: Sports, Electronics, House and Home, Videogames, etc. With this app there is also the possibility of searching by username, or by users near you. If you like some product you can directly get in touch with the seller via private message, and of course, you can also see the item before doing the purchase.
Wallapop 1.4.1 Features
The main features you can find in Wallapop are the following:
- You can sell or buy old and new items after creating an account
- Take a picture and upload your product to Wallapop to earn some money
- There are eight categories that you can access to: Fashion and Accessories; Home and Garden; Sports, Leisure and Games; Baby and Child; Electronics; Movies, Books and Music; Cars and Motors and Other
- In Wallapop you can select your favorite items and gather them in groups
- Users can look for products in their local area thanks to a map
- Communicate with users with private messages
- You can sync your Wallapop account with Facebook
- There are no delivery vans and transport fees
For more information about Wallapop, visit the developer's website here .
Minimum system requirements
The minimum system requirements to properly download Wallapop are the following:
- Android 2.2 OS or higher
- iOS 6.1 or higher
- Compatible with iPad, iPhone and iPod Touch


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Union finance minister Nirmala Sitharaman announced that the union government is planning to sell Public Sector Undertakings (PSU) Air India and the oil marketing company Bharat Petroleum Corporation (BPCL) by March 2020.
The disinvestment of the two state-run companies is critical for the government to meet its target of Rs 1 lakh crore for the current fiscal year.
"We are moving on both with the expectation that we can complete them this year. The ground realities will play out," Sitharaman said.
The finance minister added that there is a "lot of interest" among investors which is apparent in international roadshows ahead of Air India's sale. The government had to drop the national carrier's stake sale last year owing to investors' lukewarm response.
Nirmala Sitharaman also said that the government is on the right track towards resolving the economic slowdown and added that several sectors are now coming out of distress.


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By Huw Davies
I hope that all our readers had a good Christmas break and a happy New Year and that the return to the office has not proved too painful. In this month's Newsletter Hannah Saxena considers the question of bad character evidence in relation to personal injury claims, whilst John Meredith-Hardy provides an in-depth analysis of one of the likely buzz topic of 2015, Qualified One Way Cost Shifting. The Case Law Update was prepared by our pupil Joel McMillan.
The recent case of Laughton v Shalaby [2014] EWCA Civ 1450 gives a reminder of the test for admissibility of bad character evidence in civil cases but also an opportunity to look at what types of evidence on credibility or bad character would be admissible and indeed useful in personal injury claims.
The possible bad character evidence admissible in civil cases was clarified by the House of Lords in O'Brien v Chief Constable of South Wales Police [2005] 2 AC 534. In this case it was stated that similar fact evidence would be admissible if it was potentially probative of an issue in the action, but also stressing that there is a second stage where a judge can use their discretion to exclude otherwise admissible evidence or limit cross examination. Phipson on Evidence (17th edition) summarises the current position at §22-07, describing a civil rule in which courts are required to balance "probative value to the promoting party against oppression and unfairness to the other side, rather than probative value against prejudicial effect".
The Civil Procedure Rules specifically provide for attacking the credibility of witnesses who propose to give hearsay evidence in r33.5 but make no further provision for attacks on a witness's credibility if they are to be a live witness. Under r32.1 the court has the power to control the evidence, to exclude evidence that would be admissible and to limit cross-examination. Standard disclosure under r31.6 specifically provides for disclosure of documents that either adversely affect their own case or another party's case or indeed support another party's case, which would include any documents casting doubt on the credibility of a party. The 2014 edition of the White Book specifically notes in §31.6.5 that "disclosure of documents and admissibility of evidence are two distinct concepts" noting that "potentially inadmissible documents should still be disclosed".
Laughton v Shalaby
Laughton v Shalaby was a clinical negligence case in which the claimant brought a claim against an orthopaedic surgeon who carried out her left hip replacement. A year after her hip replacement surgery the claimant underwent a second procedure on her left hip due to ongoing pain. During this second surgery a muscle, which the defendant should have re-attached to the bone at the end of the initial hip replacement surgery, was found to not be attached to the correct bone but instead attached to the adjoining muscle. It was the claimant's case that the defendant was negligent in not re-attaching the muscle to the correct bone at the end of the surgery.
The defendant's position was that he would have re-attached the muscle, although he could not remember this particular operation having carried out around 3,000 similar operations, and that tearing away of the muscle (an avulsion) was a recognised but rare occurrence after hip replacement surgery. He relied on expert evidence to that extent which was preferred by the trial judge.
The claimant appealed and argued that the judge failed to take into account a number of extraneous factors regarding the defendant's character and balance those against the rarity of an avulsion occurring without negligence. The Court of Appeal broke down the extraneous factors into three categories: those regarding the lack of probity or honesty of the defendant, those showing the stress the defendant and evidence of his incompetence in other cases.
In relation to the first category it was noted by Lord Justice Longmore that if there was "extraneous evidence of lock of probity that would be relevant to the credibility of any witness". But went on to note that the credibility of the defendant in this case was not really in issue given that he could not remember the particular operation.
When considering the second category of factors it was specifically noted that the "fact that a doctor is under stress does not of itself mean that he is more likely than not to have been negligent on a particular occasion".
It was the third category of factors that was considered more problematic. It was argued by the claimant that s103(1)(a) of the Criminal Justice Act 2003 should apply to civil proceedings and put forward the proposition that 'evidence of systematic failure of various types of incompetence is admissible in professional negligence cases as enabling a judge to make inferences of negligence in a particular case'. This was rejected by the Court of Appeal, which stated "evidence of extraneous matters should be confined to cases of similar fact for the traditional reason that, unless the evidence is similar fact evidence, it is not probative of the issue to be determined". The second discretionary stage as set down in O'Brien was also noted, particularly where the evidence is likely to open up complex collateral issues.
The evidence of complaints against the defendant was noted to be correctly dealt with by the trial judge in determining that it was not probative. A doctor who had investigated the defendant's treatment of a number of patients, including the claimant, on behalf of the GMC noted that the defendant's care on occasion fell seriously below the standard expected of a reasonably competent orthopaedic surgeon. The Court of Appeal found that the comment in itself could not prove that he was negligent during the claimant's operation. The complaints about knee, foot and wrist operations were deemed too far removed to constitute similar fact evidence and the only hip replacement complaint was about insufficient discussion with the patient. A decision of the Fitness to Practice Panel, which suspended the defendant's registration, was also adduced on appeal but was noted not to disclose similar fact evidence relevant to whether the defendant was negligent in the course of the claimant's operation.
The appeal was dismissed on the basis that there was no evidence of a second instance of this complication and general evidence of a lack of probity, stress and incompetence in other areas of practice were incapable of making up the deficiency.
Some Guidance
In personal injury cases attacks on the credibility or character of a party or witness are common. If liability is in issue then more often than not there are divergent versions of events and the court needs to consider the credibility of the witnesses giving the accounts. When looking at quantum the claimant's credibility and honesty in describing the extent of their injuries is often challenged.
With so much on the internet it is often very easy to find out information about a party or witness that might potentially impact upon their credibility or character that they have not disclosed. What is more difficult is working out what will be admissible and what will actually help the case.
The evidence that is likely to assist either party in a personal injury claim falls into two broad categories: that going to the truthfulness of a witness and that showing the likelihood of that party being in breach of their duties.
When it comes to evidence of untruthfulness, or a lack of probity as described in Laughton, this is always likely to be relevant where the credibility of a witness is an issue. However, as can be seen from Laughton credibility will not always be an issue and therefore there will need to be an assessment of the particular case.
As recognised in Laughton courts are more ready to admit evidence as being of similar fact than in the past. However, where it could be suggested that the evidence is unsubstantiated and would lead to lengthy argument that would take the case away from the issues of the case it might be possible to persuade the court to use it's discretion to disallow it.
A recent example of where the court used it's discretion in this way was in Alleyne v Commissioner of Police for the Metropolis [2012] EWHC 4406 (QB). In a claim for compensation for injuries sustained by a claimant following a police search of his property Judge Seys-Llewellyn QC admitted two unsubstantiated complaints against the officers involved but disallowed a further unsubstantiated complaint on the basis that the particular complaint was highly likely to lead to questions of peripheral matters which would encumber the claim.
On the other hand, during a pre-trial review in the widely publicised Mitchell v News Group Newspapers Ltd [2014] EWHC 3590 (QB) similar fact evidence of Andrew Mitchell repeatedly asserting his status, engaging in confrontation and behaving in a rude and condescending way to police officers was admitted on the basis that it was probative as it went beyond what he was prepared to admit about his behaviour. It was felt that all instances were brief and evidence relating to them confined, therefore would not distort the trial. It was said not to be prejudicial as Mitchell would be able to challenge it and had adduced witness statements stating that he was habitually courteous.
Ultimately it is well known that Mitchell lost the case, however, it is interesting to note that the similar fact evidence was not determinative and Mr Justice Mitting found that none of the incidents caused him to doubt the truth and accuracy of the evidence of Mitchell's character and conduct (paragraph 90 – Mitchell v News Group Newspapers Ltd [2014] EWHC 4014 (QB)).
When deciding whether to adduce similar fact evidence it is important to consider how far it does go to the issues in dispute and how far off track it is likely to take the trial. In cases of negligence it is unlikely to ever be determinative of liability on it's own.
Qualified One ay Costs Shifting ('QOCS') is increasingly a part of the repertoire of the personal injury lawyer as the cohort of post 1.4.13 cases increases. The Court of Appeal has considered the lawfulness of the QOCS regime and addressed a number of other issues of its applicability in Wagenaar v Weekend Travel Ltd, T/A Ski Weekend and Serradj [2014] P.I.Q.R. P23. There is also a first instance decision on the procedure to be adopted and the meaning of fundamentally dishonest from HHJ Moloney, QC in Gosling v Hailo Cambridge CC, 29 April 2014.
Matters are becoming clearer; however, there are many areas of uncertainty and QOCS are likely to be a significant area of CA consideration in coming years.
QOCS, when does it apply?
QOCS is currently restricted in its application to claims for personal injury and those statutory claims where there is a fatal accident and/or a claim for personal injury or death that survives for the benefit of the estate.
QOCS applies to cases where there are multiple personal injury claimants as confirmed by the CA in Wagenaar at para 38: "… The whole thrust of CPR rr.44.13 – 44.16 is that they concern claimants who are themselves making a claim for damages for personal injuries, whether in the claim itself or in a counterclaim or by an additional claim …"
However, if a counterclaim relates to property damage only, QOCS protection should not apply.
The CA left open circumstances where a claimant brought multiple claims, one of which was not a personal injury claim, see para 44: "… Argument has not been addressed to the question of whether QOCS should apply to a subsidiary claim for damages not including damages for personal injuries made by such a claimant against another defendant in the same action as the personal injury claim. I would prefer to leave that question to a case in which it arises …"
Contribution claims under Part 20 are not subject to QOCS protection, see Wagenaar (para 42): "… The defendant was a commercial party in the business of supplying packaged skiing holidays. The fact that its insurance was for some reason vitiated in this case is nothing to the point. It chose, in its own commercial interests, to bring the third party into the proceedings as a third party because, no doubt, it thought it commercially to its advantage to do so. In doing so, it would have weighed up the pros and cons including the costs consequences, which, on the defendant's own case, it expected to be the ones normally to be expected in litigation before these courts (before QOCS were introduced). The defendant could have chosen to resist the claimant's claim on its merits and saved itself the trouble and expense of joining the third party and the risk of an adverse costs order. It did not do so …"
Subject to none of the exclusions applying, QOCS
In terms of timing for enforcement of interlocutory orders for costs, CPR, Part 44.14(2) states: Orders for costs made against a claimant may only be enforced after the proceedings have been concluded and the costs have been assessed or agreed (assessment means summary or detailed assessment (44PD.12.7).
In cases where a personal injury claim is likely to fail, or costs may exceed damages recovered, and none of the exceptions to QOCS is likely to apply, there may be defendant focus at the interlocutory and final stage on costs orders against legal advisers under CPR, Part 46.8 / Senior Courts Act 1981, s.51(6) and Part 44.11.
QOCS do not apply to personal injury cases where there was a pre-1.4.13 CFA or ATE (CPR, Part 44.17; Part 48.1 & 48.2; Part 43.2(l)(k)(i) & (ii)), nor to an appeal where the substantive claim had been funded by a pre-1.4.13 CFA & ATE (see Landau v Big Bus Co Ltd SCCO 31.10.14 (Master Haworth) 31.10.14).
The rules do not distinguish between a pre-1.4.13 CFA or ATE that is enforceable at the conclusion of the claim and a pre-1.4.13 CFA or ATE having been agreed but is no longer enforceable at the time of judgment (e.g. legal representation has ceased to act on this basis and / or ATE insurers have declined further cover).
It is not clear whether pre-1.4.13 CFAs and ATE can be 'thrown off' and reliance placed on QOCS: there may be advantages for clients of such a course where ATE may be 'flakey', of limited cover or where cases of 'close to call' prospects of success.
Certainly the analysis in Landau, by analogy, would suggest that it is not the enforceability of the CFA but the fact of having entered into a pre-1.4.13 CFA which would act as an effective bar on any future reliance on QOCS.
However, an analysis of Simmons v Castle would suggest a contrary view. In Simmons the 10% increase hinged on LASPO 44(6) (see paras 40 & 50): The amendment made by subsection (4) does not prevent a costs order including provision in relation to a success fee payable by a person ("P") under a conditional fee agreement entered into before the day on which that subsection comes into force ("the commencement day") if:
The word 'prevent' seems to be the crucial word – if the Court of Appeal on QOCS was to take a consistent approach it would talk about pre-1.4.13 CFAs being enforced and not their historical existence – this was raised as an aside in Simmons at para 33 re satellite litigation and the Court of Appeal stated: "33 APIL's first point is that ABI's proposal would lead to satellite litigation. However, the only examples Mr Aldous came up with were (i) a case where a claimant had entered into a CFA before 1 April 2013, and, after that date, he had died, and his executors then entered into a fresh CFA, and (ii) where a claimant entered into a CFA before 1 April 2013, and then disinstructed his solicitors and reinstructed other solicitors on a CFA after 1 April 2013. The first situation will very rarely arise, and the answer in the second situation is obvious".
QOCS does not apply to applications for pre-action disclosure (Senior Courts Act 1981, s.33 & County Courts Act 1984, s.52).
Effect Of QOCS
CPR, Part 44.14 provides:
If a claimant is successful on liability and the claim gives rise to damages being paid by the defendant to the claimant, costs orders can be enforced up to the aggregate amount in money terms of the damages "without permission".
Therefore, a defendant can enforce any interlocutory costs orders at the conclusion of the claim against a successful claimant up to the value of the damages ordered to be paid.
Likewise, a defendant can enforce a final costs order made where a defendant's Part 36 offer was not exceeded at trial or where conduct issues have given rise to adverse costs orders against a claimant, again limited to the value of the damages ordered to be paid. In both instances, the defendant is entitled to enforce without permission i.e. 'as of right'.
Set off of costs pursuant to CPR, Part 44.12 has a part to play in a defendant's recovery of costs.
However, if the claimant loses the claim or is successful on liability but receives nominal damages, any interlocutory or final costs orders in favour of the defendant cannot be enforced unless one of the exceptions applies.
It must be stressed that the effect of QOCS is not to prevent costs orders being made against a claimant either at the interlocutory or final stage. It is exclusively the enforcement of costs orders that is fettered by QOCS.
The provisions of Part 36 and its costs consequences are not ousted by the existence of QOCS.
Further, costs budgeting remains a live issue for defendants regardless of QOCS as without a costs budget, a defendant will have no costs to enforce and a defendant Part 36 will be nugatory.
Exceptions To QOCS Where Permission Is Not Required
CPR, Part 44.14 provides:
Orders for costs made against the claimant may be enforced to the full extent of such orders without the permission of the court where the proceedings have been struck out on the grounds that:
A defendant is entitled to costs without permission if the claim is struck out on certain specific grounds. The list of reasons for striking out is not comprehensive and would appear to be a closed list ("… struck out on the grounds that").
The basis for striking out the claim are the CPR, Part 3.4(2)(a) and (b) grounds and the inherent jurisdiction (abuse) but does not include (interestingly) striking out for "a failure to comply with a rule, practice direction or court order" (CPR, Part 3.4(2)(c)).
Therefore, for example, if a claim is struck out for non-payment of court fees under CPR, Part 3.7, a defendant would not be entitled to their costs under the CPR, Part 44.15 exception on a reading of the words of the section.
Some interesting hybrid situations may arise. For example, if a claimant is disbarred from relying on lay or expert evidence on account of late service (perhaps less likely following Denton) giving rise to the claim being untenable, the question arises as to whether the strike out is due to a breach of a rule (exception to QOCS not apply) or 'disclosed no reasonable grounds' and / or an 'abuse of the court's process' (exceptions to QOCS apply).
The common use of the CPR, Part 44.15 exception maybe where, after service of proceedings, a defendant brings an application to strike out as, for example, limitation has expired or the wrong party has been sued. In either of these examples, if the claim is struck out the claimant is fully exposed to enforceable adverse costs orders.
Claimants may be astute to the tactical play upon an application to strike out- if an application is made by a defendant to strike out the claim, a claimant may discontinue the claim before hearing resulting in an unenforceable order for costs in the defendant's favour (though subject to the Part 44.16 exceptions, that at 44PD.12(c) refers to discontinuance, see below as this is what happened in Gosling).
Should the claimant discontinue in the face of an application to strike out the defendant is entitled to apply to set aside discontinuance under CPR, Part 38.4. How this provision may be used by defendants to preserve their entitlement to costs on strike out will have to be seen. In Gosling, HHJ Moloney, QC did not consider that reversing discontinuance had much utility and approached the application on the basis of fundamental dishonesty (see para 10).
In any event, a court may consider that setting aside discontinuance is a collateral attack on QOCS that permits discontinuance without costs consequences subject to the permitted 44PD.12(c) adjudication on fundamental dishonesty.
The CPR, Part 44.15 exception may give rise to the utility of defendants seeking to strike out a claim at a late stage in proceedings.
In Summers v Fairclough Homes Ltd [2012] 1 WLR 2004 it was stated (from the headnote):
"… strike out a statement of case … at any stage of proceedings, even after trial in circumstances where the court had been able to make a proper assessment of both liability and quantum; but that that power would be exercised at the end of a trial only in very exceptional circumstances where the court was satisfied that the party's abuse of process was such that he had thereby forfeited the right to have his claim determined; that, while the existence of such a power was in the public interest, in deciding whether to exercise it the court had to have regard to the claimant's Convention 2005 rights to have his claim fairly determined by a court and to enjoyment of his possessions and so to examine the circumstances of the case scrupulously in order to ensure that any decision to strike out the claim was a proportionate means of controlling the court's process and deciding the case justly; and that it would be a very rare case in which, at the end of a trial, it would be appropriate or proportionate to strike out a case rather than to dismiss it in a judgment on the merits or, where both liability and quantum could be assessed fairly, to give judgment in the ordinary way …".
However, it was stated in Summers that (para 62): "… nothing in this judgment affects the case where the fraud or dishonesty taints the whole claim. In that event, if the court is aware of it before the end of the trial, judgment will be given for the defendant and, if it comes to light afterwards, it will be open to a defendant to raise the issue in an appeal …"
Therefore, whilst the discretion to strike out is only to be exercised in the "very exceptional case" at the conclusion of a claim, where the whole claim is tainted by fraud or dishonesty, it can be struck out thus forestalling the need for an enquiry as to fundamental dishonesty and permission to enforce costs orders.
Nonetheless, at the conclusion of the claim, the fundamental dishonesty Part 44.16 exception is likely to be a more effective route for enforceable costs orders in favour of defendants than at trial strike out.
Exceptions To QOCS Where Permission Is Required
CPR Part 44.16 provides:
Orders for costs made against the claimant may be enforced to the full extent of such orders with the permission of the court where the claim is found on the balance of probabilities to be fundamentally dishonest.
Orders for costs made against the claimant may be enforced up to the full extent of such orders with the permission of the court, and to the extent that it considers just, where:
Where paragraph (2)(a) applies, the court may, subject to rule 46.2, make an order for costs against a person, other than the claimant, for whose financial benefit the whole or part of the claim was made.
The practice Direction at 44.PD.12.6 provides:
In proceedings to which rule 44.16 applies, the court will normally order the claimant or, as the case may be, the person for whose benefit a claim was made to pay costs notwithstanding that the aggregate amount in money terms of such orders exceeds the aggregate amount in money terms of any orders for damages, interest and costs made in favour of the claimant.
Addressing each limb of the exceptions for which permission is required:
(a) Fundamental Dishonesty
'Fundamental dishonesty' is a departure from the proposed wording which was to be 'fraud' or 'fraudulent'. It is also to be noted that it is the claim that must be 'fundamentally dishonest' rather than the claimant.
The practice direction at 44PD.12 gives guidance on how fundamentally dishonesty will be determined.
In a case to which rule 44.16(1) applies (fundamentally dishonest claims):
Therefore, where there is a trial the issue of fundamental dishonesty will need to be addressed at the trial.
This presents a pleading point- should the defendant's statement of case identify fundamental dishonesty? The answer is probably 'yes', or at the least the issue should be raised at the PTR and identified as one of the issues to be addressed at the trial.
Where there has been no trial and the claim has settled, possibly at a significant undervalue, "the court will not, save in exceptional circumstances, order that issues arising out of an allegation that the claim was fundamentally dishonest be determined in those proceedings".
The foregoing assumes that settlement has addressed damages but not costs. It can be inferred that the condition of exceptional circumstances is to discourage satellite litigation on this issue. What, exactly, are exceptional circumstances is yet to be determined.
Post settlement, surveillance evidence may be relied on and be practical in terms of summary determination of the issue of fundamental dishonesty. However, the court may consider that surveillance evidence is not an exceptional circumstance considering the regularity with which such evidence plays a significant role in reducing claimant's exaggerated claims for damages.
Adjudication of fundamental dishonesty is not subject to exceptional circumstances on discontinuance, see 44PD.12.4(c).
In Gosling, HHJ Moloney, QC adopted a summary procedure on proportionality grounds with no oral evidence being heard and matters being limited to submissions from counsel, see paragraphs 23 and 24.
The issues included fundamental dishonesty as to the occurrence of the accident and with regard to the quantum of the claim. On the former point, HHJ Moloney, QC considered the evidence insufficiently cogent for summary disposal and a hearing of oral evidence disproportionate, see paragraph 33.
On quantum, it was held that the evidence was sufficiently cogent ("bang to rights") and oral evidence would be disproportionate, see paragraphs 51 to 57.
The allegation of fundamental dishonesty as to quantum was based on a "devastating surveillance video". Addressing fundamental dishonesty, HHJ Moloney, QC found: "44 It appears to me that this phrase in the rules has to be interpreted purposively and contextually in the light of the context … It appears to me that when one looks at the matter in that way, one sees that what the rules are doing is distinguishing between two levels of dishonesty: dishonesty in relation to the claim which is not fundamental so as to expose such a claimant to costs liability, and dishonesty which is fundamental, so as to give rise to costs liability.
45 The corollary term to "fundamental" would be a word with some such meaning as "incidental" or "collateral". Thus, a claimant should not be exposed to costs liability merely because he is shown to have been dishonest as to some collateral matter or perhaps as to some minor, self-contained head of damage. If, on the other hand, the dishonesty went to the root of either the whole of his claim or a substantial part of his claim, then it appears to me that it would be a fundamentally dishonest claim: a claim which depended as to a substantial or important part of itself upon dishonesty".
The Judge found that the dishonesty in question was fundamental to two heads of damage thus:" 49 Overall, I therefore conclude that in relation both to that very substantial element of his claim, future care, and in relation to an even larger part of his claim, general damages for pain, suffering and loss of amenity, the dishonesty in question here, if established, is fundamental to those heads of damage, and thus to around half of the total claim in damage terms. It appears to me to be very clear that on any sensible definition of a "fundamentally dishonest claim", dishonesty crucial to such a large part of the claim under those two heads is sufficient to enable the claim to be characterised as fundamentally dishonest.
50 It was not suggested on the claimant's part nor, I think, could it be seriously maintained that as a matter of law it would be required that the dishonesty went to the root either of liability as a whole, or damages in their entirety. It must be the case that dishonesty fundamental to a sufficiently major part of the claim would suffice to deprive the claimant of his costs protection, and open him to the court's discretion as to how much of the costs he should pay …"
Consistent with HHJ Moloney's approach 44PD.12.4(d) permits the court "as it thinks fair and just, determine the costs attributable to the claim having been found to be fundamentally dishonest".
The inference from 44PD.12.4(d) is that despite the use of "claim" (as opposed to "claim and / or claims") in CPR, Part 44.16, an allegation that part of the claim is fundamentally dishonest, is sufficient as otherwise attribution would not be relevant.
This particular issue, however, will have to wait for the Court of Appeal's determination. Meanwhile, HHJ Moloney's analysis is likely to feature in defendant's submissions.
(b) A Claim For The Benefit Of A Person Other Than The Claimant
The second limb of CPR, Part 44.16 is supplemented by 44PD.12:
12.2 Examples of claims made for the financial benefit of a person other than the claimant or a dependent within the meaning of section 1(3) of the Fatal Accidents Act 1976 within the meaning of rule 44.16(2) are subrogated claims and claims for credit hire.
12.3 'Gratuitous provision of care' within the meaning of rule 44.16(2)(a) includes the provision of personal services rendered gratuitously by persons such as relatives and friends for things such as personal care, domestic assistance, childminding, home maintenance and decorating, gardening and chauffeuring.
Gratuitous care, re-payable earnings paid by an employer and medical expenses escape the definition. Claims for the benefit of third parties, such as subrogated claims and claims for credit hire, are prima facie subject to third party costs orders and, therefore, are exceptions to QOCS.
As provided by CPR, Part 44.16(3), the costs order is made against the third party and not against the claimant (who would otherwise have to recover from the third party) though "exceptionally" this is permissible (44PD.12.5(a)).
The second limb of CPR, Part 44.16 is further supplemented by 44PD.12.5:
The court has power to make an order for costs against a person other than the claimant under section 51(3) of the Senior Courts Act 1981 and rule 46.2. In a case to which rule 44.16(2)(a) applies (claims for the benefit of others).
Therefore, costs ordered against the third party should be limited to those attributable to, for example, the subrogated claim.
If the claim is for the benefit of another, the requirements of the Senior Court's Act 1981 s.51(3) and CPR, Part 46.2 need to be satisfied before an order is made.
The threshold for third party costs orders has historically been high and "would always be exceptional", see Dymocks Franchise Systems (NSW) Pty Ltd v Todd (Costs) [2004] UKPC 39 and in summary:
How these issues may be addressed when QOCS anticipates that third parties should pay will have to be seen.
An interesting point arises on the recoverability against BTE and other third party funders of claimant cases. The existing law on the Senior Court's Act 1981 s.51 and before the event insurance is to be found in Murphy and Another v Young & Co's Brewery and Another [1997] 1 W.L.R. 1591. In the headnote it states, inter alia:
"… dismissing the appeal, that an order under section 51 that a non-party pay costs was only justified when exceptional circumstances made such an order reasonable and just; that legal expenses insurance was a respectable and well recognised form of insurance which was in the public interest; that the existence of legal expense insurance with a limit of cover that had been exhausted did not, in itself, make it reasonable or just to order the insurers to pay the costs of the adverse successful party; that, while the insurers had funded the litigation under a commercial agreement, they had had no interest in the result, had not initiated the litigation, had exercised no control over the conduct of the action and had been contractually obliged to provide funds up to the limit of cover; and that, accordingly, there were no exceptional circumstances to make it reasonable or just to order the insurers to pay the first defendant's costs …"
Therefore, whilst QOCS means costs may not be enforced against a claimant, an application could be made (and be successful) against a third party funder unless the third party funder "had no interest in the result, had not initiated the litigation, had exercised no control over the conduct of the action and had been contractually obliged to provide funds up to the limit of cover".
In the personal injury claim of Thomson v Berkhamsted Collegiate School QBD [2010] C.P. Rep. 5 Blake J. ordered disclosure of the extent to which the claimant's parents had controlled a claim by their now adult son for bullying against their son's school.
In the context of defendant cases, orders against defendant insurers have been made on account of the degree and extent of the control exercised by the insurer over the conduct of the litigation, see for example Palmer v Palmer (Deceased) , MIB and others [2008] EWCA Civ 46 (W/B 2014 vol 1 p.1495 & Cook on Costs 2014 p.609).
It is likely that there will be CA cases in the context of QOCS on "financial benefit for another" and the s.51 jurisdiction.
Third party funders will want to be astute to the points made in Murphy and the importance of not permitting themselves to be, or appear to be, the controller of the litigation as occurred in Palmer. Defendants will be interested in disclosure to identify control as in Thomson.
Therefore, whilst no orders should be enforceable or made against the BTE insurers and other litigation funders if they are just funding the litigation in the Murphy sense, this is likely to be a developing area of jurisprudence considering the financial cost of QOCS to defendants.
National Grid Electricity Transmission Plc v McDonald (Deceased) HRH Prince Abdulaziz Bin Mishal Bin Abdulaziz Al Saud v Apex Global Management Ltd & Anor
(Lord Neuberger PSC, Lord Clarke JSC, Lord Sumption JSC, Lord Hughes JSC, Lord Hodge JSC)
Significance: The merits of the case are generally not relevant when a court is (i) making case management directions; (ii) considering the imposition of a sanction for the breach of such directions; or (iii) considering whether to provide relief from any sanction.
Facts: The first respondent and a company owned by the appellant prince (P) decided to set up a third company. Litigation followed a dispute and Vos J ordered that P should personally sign a number of statements relating to disclosure. P subsequently claimed that, as a member of the Saudi royal family, a protocol prevented his signing court documents.
Norris J then ordered that judgment would be entered against P unless he complied with Vos J's earlier order. P continued to refuse to comply and judgment was entered in the sum of $6 million. P's subsequent application to vary Vos J's order and obtain relief from sanctions was dismissed by Mann J. P appealed the orders of Vos, Norris and Mann JJ to the Court of Appeal, and subsequently to the Supreme Court.
Held: (1) The decisions of Vos, Norris and Mann JJ were unassailable.
(2) The strength of a party's case would generally be irrelevant in decisions on case management and sanctions. It was difficult to see why a court should take the merits of the case into account when making such decisions or how it could be done in a principled way. Further, it would be thoroughly undesirable for the courts to spend time assessing the strength of each side's case every time it made such decisions. However, there was force in the argument that there should be an exception to the general rule where a party's case was strong enough to obtain summary judgment.
(3) The contention that the final sanction was disproportionate even though each step was unassailable did not stand up. The imposition of a sanction following breach of a court order was almost inevitable in order to maintain respect for the courts and ensure litigants' compliance. If non-compliance would lead to an unfair trial it was difficult to disagree with a sanction that prevented the party in breach from presenting or resisting the claim.
(4) It did not matter that there would be a trial in any event in which the payment or non-payment of the $6 million might be raised in relation to credibility. It was inherent in an order for default judgment that the claimant would obtain a remedy to which it might subsequently be shown he was not entitled.
(5) (Obiter) The Supreme Court would be slow to interfere with Court of Appeal guidance and decisions in relation to the application of the CPR, in the same way that that Court was reluctant to interfere with first instance decisions.
Janet Laughton v Salah Eldin Ahmed El Sayed Shalaby
[2014] EWCA Civ 1450
(Longmore LJ, McCombe LJ, and Vos LJ)
Significance: Evidence of incompetence in other cases cannot be adduced to infer clinical negligence in the material case unless it amounts to similar fact evidence.
Facts: The appellant patient (L) alleged that the defendant surgeon (S) had negligently failed to attach her muscle properly to her replacement hip. S had been investigated for incompetence by the General Medical Council (GMC) and the resulting report had found that his care had fallen seriously below the expected standard in relation to 7 patients. Conditions had been placed on S's registration and he had also been suspended after committing an assault. The trial judge held that the surgery had not been performed negligently, preferring the expert evidence that the tearing away of the muscle was a recognised, albeit rare, occurrence after a hip replacement.
L appealed arguing, inter alia, that the judge (1) should have admitted the findings of the GMC report as evidence to infer incompetence in the instant case, under a principle similar to the admissibility of bad character evidence in criminal law; and (2) had failed to address matters of S's probity, including his failure to disclose his suspension or the conditions on his registration.
Held: (1) A principle akin to bad character evidence in the criminal law should not be adopted in civil law. The relevant provisions in the criminal law were a statutory change to the common law and did not apply to civil proceedings. Evidence of incompetence in other cases was only admissible if it constituted similar fact evidence for the traditional reason that it was otherwise not probative of the issue to be determined.
(2) Any evidence of lack of probity would be of little value. Whilst it was a serious dereliction of S's duty to the court that he had not disclosed his suspension and the conditions on his registration, the question was whether he was competent, not credible. The most such evidence could indicate was that he was unlikely to admit to incompetence or was less likely to have followed standard procedure than he claimed; it could not show that he was more likely to have acted negligently.
Carl Heneghan (Son & Administrator of the Estate of James Leo Heneghan, Deceased) v Manchester Dry Docks Ltd & 5 Ors
(Jay J)
Significance: The Fairchild v. Glenhaven Funeral Services Ltd [2003] 1 AC 32 exception to the traditional test for causation applies to lung cancer as well as mesotheliooma. A claimant therefore need only show that negligent exposure to a toxic substance by his employer has materially increased the risk of his contracting the disease.
Facts: The deceased (C) was exposed to asbestos during sequential employment with the 6 defendants, as well as during employment with previous employers who had not been sued. He contracted lung cancer and died. Although C had been a smoker both parties' experts agreed that, on the balance of probabilities, he would not have contracted the disease without the exposure to asbestos. It was further agreed that his employment with the defendants accounted for a combined total of 35.2% of his asbestos exposure.
The only question for the court was whether each defendant was liable for damages in full or 35.2% thereof. The defendants argued that the case fell within the Fairchild exception and recovery was limited to 35.2%; C's son (H) argued that the common law allowed for a third way between the traditional approach to causation and the Fairchild exception which entitled him to 100% recovery.
Held: It was agreed that it was likely that exposure to asbestos had caused C to contract lung cancer. However, it was not possible to demonstrate on the balance of probability that the defendants, either individually or collectively, had caused or materially contributed to the same. Causation in the traditional sense had not been proved.
The only possible way for H to succeed was if the Fairchild exception applied; there was no third way. Mesothelioma and lung cancer were legally indistinguishable. Both could be caused by exposure to a small quantity of asbestos and neither were aggravated by prolonged exposure. This distinguished them from other industrial lung diseases such as silicosis and pneumoconiosis where any significant exposure caused deterioration and materially contributed to the disease. It was consistent with principle that Fairchild should be deemed to cover lung cancer as well as mesothelioma.
In light of the above ruling H conceded that only 35.2% of the damages were recoverable in line with Barker v Corus UK Ltd [2006] 2 AC 572.
Lougheed v. On The Beach Ltd
[2014] EWCA Civ 1538
(Tomlinson LJ, Floyd LJ, Ouseley J)
Significance: The standard of maintenance and cleanliness to be reasonably expected in a foreign hotel booked through an English tour operator is that which can be reasonably expected in a comparable local establishment.
Facts: A holiday company (O) appealed against an award of damages to the respondent who had slipped on a patch of water on a Spanish hotel staircase whilst on a holiday arranged by O. The judge at first instance had found O liable pursuant to reg. 15(1) of the Package Travel, Package Holidays and Package Tours Regulations 1992, relying on the evidence of the hotel manager as to local standards in the absence of any specific Spanish regulations.
Held: The standard by which the hotel should be judged was that which could reasonably be expected in a similar Spanish establishment. It was not realistic to expect a uniform approach to maintenance and cleanliness in different countries, and it would not be sensible to apply the standard that could reasonably be expected in a comparable English hotel: Wilson v. Best Travel Ltd [1993] 1 All ER 353 applied. Instead proper enquiries should be made into local practices. Compliance with local regulations did not necessarily mean compliance with local standards as it might be the general practice to adopt higher standards where regulations were accepted to be inadequate.
In the instant case the judge had insufficient evidence as to Spanish practices and had unduly relied on the evidence of the hotel manager. The appeal was allowed.
Walsham Chalet Park Ltd (T/A The Dream Lodge Group) v Tallington Lakes Ltd
[2014] EWCA Civ 1607
(Richards LJ, McCombe LJ, Sharpe LJ)
Significance: The principles set out in Mitchell v News Group Newspapers [2014] 1 WLR 795 and restated in Denton v TH White Ltd [2014] 1 WLR 3926 were 'relevant and important' when considering an application to strike out a statement of case under CPR r.3.4.
Facts: During litigation arising out of a contractual dispute, the appellant (T) unsuccessfully applied to strike out the respondent's claim for failing to meet various deadlines set out in a court order. T appealed.
Held: The judge was correct to hold that the principles set out in Mitchell and restated in Denton were 'relevant and important', even though the application was to strike out under r.3.4 rather than for relief from sanctions under r.3.9. The factors mentioned in r.3.9, including the need to enforce compliance with court orders, were reflected in the overriding objective in r.1.1, to which the court had to give effect when considering an application to strike out. The Mitchell principles were therefore directly relevant. The judge had been correct to adopt the 3 stage test in Denton and had been entitled to dismiss the application.
Chief Constable of Hampshire v. Southampton City Council
[2014] EWCA Civ 1541
(Jackson LJ, Patten LJ, Lewison LJ)
Significance: Where a claim is settled pursuant to the provisions in CPR Pt 36 and the defendant seeks a contribution under the Civil Liability (Contribution) Act 1978, for the purposes of the Limitation Act 1980 time will start to run at the date the Pt 36 offer is accepted, not the date of any later consent order or assessment of costs.
Facts: On 4th November 2010 a police officer accepted a Pt 36 offer from the appellant police force (P) in respect of his mesothelioma claim. The agreement was formalised in a consent order on 15th December 2010 and costs were subsequently subject to detailed assessment. On 3rd December 2012 P attempted to bring proceedings against the respondent local authority for a contribution under the 1978 Act. The judge held that, for the purposes of the 1980 Act, time ran from the date of acceptance of the Pt 36 offer and the claim was therefore brought after the permitted 2 years.
P appealed arguing (1) that the consent order constituted a 'judgment' by which it was 'held liable' for the purposes of s. 10(3) of the 1980 Act and that time should start to run from the date of the consent order; and (2) in the alternative, if time ran from when it had agreed to make a payment pursuant to s.10(4), the correct start date was the date on which it had agreed to pay costs as 'the amount to be paid' in the subsection covered costs as well as damages.
Held: (1) Neither the consent order nor the later costs order constituted a 'judgment' by which P had been 'held liable'. S. 10(3) of the 1980 Act therefore had no application to the instant case.
(2) Properly construed within the context of the rest of s. 10, 'the amount to be paid' referred to damages only and not costs. It followed that time ran from the date of acceptance of the Pt 36 offer and the claim had been brought out of time.
Author: John Meredith-Hardy Farrars (firstname.lastname@example.com)
Author: Joel McMillan Farrars (email@example.com)
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Panjab University recruitment 2020 to fill 01 vacancies | Panjab University released notifications for freshers, apply for Panjab University jobs online @ puchd.ac.in. Panjab University has come up this year by releasing the number of Panjab University recruitment notifications to fill around 01 Guest Faculty vacancy
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Miles Apart Quick Pages
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Product Information
- Type: Quick Page Pack
- Designer: Scraps N Pieces
- Software Category: Everyday
- Download Size: 176.6 MB (approximate)
Design Elements
- Page Elements: 12
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Designer Notes
Scrapbooking is the best way to document those precious memories, no matter what they are. Miles Apart is one of those perfect stash-building kits that can work for a variety of stories. This timeless kit's cool color palette and everyday elements work well for special occasions, favorite memories, and those day-to-day stories we love to tell. Turquoises, teals, grays, blacks, and whites mix and match well with other kits. Flowers, frames, and ephemera always complete a page. And who could forget the sweetly patterned papers? Whether you're telling a story of a long distance friend, scrapping your family's heritage, or simply making a page about how far your kids have come, make it special with Miles Apart. Quick Page pack has 12 pages with spots for 41 photos.


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It seems almost futile "side" to inform the young men of the horrors of venereal diseases; and that it may everlastingly unfit them for marriage. Treatment as Related Anniversary Address by the President, eight คือ o'clock, Assembly Present Status of the Proposed Law to Regulate the Practice of Embalming Human Dead Bodies, A. He was forbidden to uses take indiscreet ohances with his diet. As soon as liquid the body is taken out of the water, it should be stripped of any clothes it may have on, and be immediately well dried. As dosage pointed out by Veit, the facial skin may often appear slightly edematous, most marked in a mild puffiness of the lower eyelids, when uterine fibroids are present. The results of experiments on such animals and also of the administration of drugs to man must be accepted with great caution since in many cases the disease is prolonged and a "cough" positive verdict regarding the outcome of the experiments can not be given until a long time has elapsed. In such cases, it was observable that there was great congestion in the hepatic system, sr the debility at the same time discouraging copious evacuations. Tab - these will not hesitate to take the high frequency vacuum electrization, which will penetrate medium weight clothing without discomfort. Stewart, the question of diet is usually of little moment, but in some, and especially in scarlet fever, there is a special liability to the occurrence of renal inflammation, and there is no doubt that a copious diet rich in nitrogen is very dangerous, and that something of the nature of low or milk diet is best for such fever cases, in convalescence for as well as during the fever.
But if, on the other hand, it can be shown that such observation is of value, it is desirable that we should try to fix the range of its use and the nature of its limitations (wikipedia). Names compounded with this word belong to muscles which are attached neck of the scapula, in which the head of the dose humerus is articulated. From conditions in Gambia, where sleeping sickness has been endemic for more than a century, some investigators are led to believe that many may acquire a similar tolerance for Trypanosoma gambiense, but so far as positive evidence goes the outcome of the disease is universally fatal (taste). This medication was a bold step, and was undertaken with a great deal of anxiety. An old poacher having been secretly asked how hares were mostly caught, confidentially answered by lurchers: about thirty years ago, only one or two persons in a parish knew how to set up wires; now it is so common almost every one can do it, and also find out when it is done, consequently To prevent night coursing is almost impossible, as little noise is made except the hare cries when caught; it may, hov.ever (used). Its use is to bring "syrup" Quadua'tus la'bii interio'ris.
And it is even more prolonged, lasting in some cases six or effects eight days.
How would the tablet learned supporters of the comma-bacilli theory explain or account for the following fact, which I beg leave to mention here: A on the border of a filthy tank. Quibron - it is, therefore, necessary to distinguish in every gas, the matter of heat which acted the part of a solvent, and the substance which Gases are not contained in those substances from which we obtain them in the state of gas, but owe their formation to the expansive All the elastic aeriform fluids we are hitherto acquainted with, are writers, into two classes; namely, those that are respirable and capable of maintaining combustion, and those that are not respirable, and incapable of maintaining combustion.


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Fx Trading Examination for Novices
It'd be best to take into account the next tips if you are Foreign exchange market looking for currency trading investigation. Deciding on a brokerage is essential to your own Forex investment. It's possible to use a Forex review in the event that you prefer to do on the web currency trading.
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I realize that it has four distinct techniques may help predict where the market will go As soon as I examined the currency broker who has fantastic specialized and market place analysis. Where the marketplace is going forex broker, these indexes show.
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I never fail to advise that you work with a currency trading brokerage firm that has automated applications to trade for your benefit to have the ability to trade money effortlessly. For instance, Forex stock investing robots (DTHs) are software which trade industry with a human arm.A Forex broker who has experienced people on the other side of the platform is not going to own a DTH that deals to you. Even a superior DTH, that resembles a dealer, will likely undoubtedly be more rewarding to utilize and much more reliable.
The way to purchase is touse a fx account. That is a program that prevents MetaTrader 4 you.
Utilize In the event you wish to use an expert Forex broker. You want to be able to find a remedy immediately regarding any difficulty you've got with your accounts. A fantastic broker will be able to reply quickly to some questions that you could have.
Whenever you have problems with your account, you want to be able to speak with a live currency dealer. A fantastic broker is likely to soon be swift to answer some issues that you might have.
If you are able to get on the internet and take a look at the website, you may locate a lot of information on currency trading brokerage firms that offer currency investing. A fx broker should have the ability to give you advice about the optimal/optimally time to purchase and sell a currency.
They can tell you which currency pairs to exchange from, which currency pairs to watch until you understand what it is that you're carrying out, and also which money pairs to hold off. This is important advice for a newcomer.


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E-DB Verified: Yes
Author: Metasploit
Type: Local
Advisory/Source: GitHub
Published: 2018-09-10
Platform: Linux
Description about CVE-2018-16509:
An issue was discovered in Artifex Ghostscript before 9.24. Incorrect "restoration of privilege" checking during handling of /invalidaccess exceptions could be used by attackers able to supply crafted PostScript to execute code using the "pipe" instruction.
And have something to say about GitHackTools or CVE-2018-16509? Comment below or share this post from GitHackTools Facebook, GitHackTools Twitter and GitHackTools Google Plus.
From Exploit Database and CVE


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They're probably right. This is probably the most important thing on the list. Among people in their 50s, about 42 percent of men and 15 percent of women say they indulge in self-stimulation "about once a week" or "more than once a week. We all know that infidelity is a potent relationship-destroyer, an atom bomb that few unions withstand. About 25 percent of cheaters say that it gave their relationship a boost in the sex department, and 11 percent of cheatees agree. That depends on what's going on in your bedroom-and how your love life stacks up against the "norm. So when it comes to getting hot and heavy, you not only run things by one another, you make sure your partner gives gives enthusiastic consent.
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Healthy people with no financial worries and low stress levels and, of course, a partner handy have the most sex, and are most likely to say they have "extremely satisfying" sexual relationships. Among people in their 50s, about 42 percent of men and 15 percent of women say they indulge in self-stimulation "about once a week" or "more than once a week. Nearly 60 percent of female cheaters say their stepping out had "no effect" on their relationship, and just 9 percent think made their sex lives worse. Thank you for your interest in volunteering. Whether you're just starting out or have been hooking up for a while, you will be inevitably met with a variety of awkward challenges and uncomfortable positions that will make things less than sexy.
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Not surprisingly, more Americans believe that having a healthier bank account would get their home fires burning. You're also sure to let your partner know before changing things up. Please return to AARP. Among women with cheating partners, however, only 24 percent say it had no effect on the relationship-and almost 40 percent say it made their sex lives worse. Perhaps some of these lucky "no effect" folks had struck a pragmatic arrangement. one survey respondent added, "We lived miles apart at the time and agreed to a 'don't ask don't tell' policy. The most important part is you have someone you can laugh through it with.
Ada from Fairfield Age: 34. I want to find a strong man who can deliver pleasure. I like to try something new.. Waiting for a real man.


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Dog watch: Kozun's journey to becoming the athlete of the year
The Huskies hockey player is going down in history with three titles and a possible fourth.
The Huskies hockey player is going down in history with three titles and a possible fourth.
In May 2020, the University of Saskatchewan announced that classes will be mostly delivered online for the Fall Term. Since then, The Sheaf Publishing Society has been planning its best course of action. Our office will remain closed for the Fall Term to keep our volunteers and staff safe during the pandemic. We will be…
The people of the city of bridges unite forces to amplify the voices of black people.
The university continues to operate with its doors closed.
The full details of the implementation plan will be finalized before the end of the month.
Food is deeply rooted in Ilocano culture and gives people something to bond over.
An interactive crossword for when you're bored and hungry.
Everyone gets their time in the limelight, and this sure happened for Canada and the United States in the '60s.
This is an interactive crossword! Click on any square to start filling out the words.
The dogs prepare for one more weekend series as they gear up for the Canada West playoffs.


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Mar 18, 2019
LEDVANCE has expanded its LED luminaires business. Their two latest models, the Downlight Slim and the Linear 900 are now on the market. Both LED luminaires provide in different variants a variety of professional applications.
Downlight Slim
Main advantage of the Downlight Slim: quick and easy installation and easy handling. Because of its flat construction with only 29 millimeters, it is much thinner than other downlights and can therefore easily be installed in very flat ceiling vaults. A Fast-connector-box with push button terminal and strain relief for safe and professional installation and the integrated driver ensure a safe and professional assembly and handling.
The Downlight Slim is available in the light colors 3000, 4000 and 6500 Kelvin, illuminates with 90 lumens per watt, a 120° beam angle and a homogenous light distribution due to edge lighting. The performance portfolio of the LED luminaire is rounded off with a lifetime of 50,000 hours (L70) and a 3-year warranty.
Linear LED 900
Growth in the popular linear range: an additional variant of 900 mm length with switch is now available in the light colors 3,000 and 4,000 Kelvin and 1,200 lumens. In addition, the Linear LED 900 Power variant without switch is available with 1500 lumens. Both LED luminaires have a beam angle of 140°, a lifetime of 30,000 hours (L70 / B50 @ 25 ° C) and a 3-year warranty.
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Sep 23, 2013· I would like to build a coal mine for my layout. However, I have no knowledge of coal mine operations. I don't feel the need to have every detail just right, but would like to have a general idea of what needs to be represented for a small mining operation pre-1950 time frame.
Crushing Plant Design Layout for Coal indonesia,Design Coal - coal mining plant layouts,the layout of crushing plants.In mining operations, the layout of crushing plants and ancillary gear and structures can be a crucial element in meeting production ...Crusher Plant Layout-Crushing Plant Layout Mining ProcessCrusher Plant layout is the previous conditions of mining process.
3D Standardized Design and Application of Main Power House of Xiaozhuang Mine Coal Preparation Plant. CCTEG Beijing Huayu Engineering Co. creates 3D collaborative design for the main power house of Xiaozhuang coal preparation plant, saving CNY 1.2 million in costs, and significantly cutting design and construction time. Learn More
MNGN 414- Mine Plant Design; MNGN 316- Coal Mine Design (2001-2002) MNGN 598- Equipment Economics, Maintenance, and Automation (planned 2015) 2003-2006: Penn State University Mining Engineering Department, Assistant Professor (tenure track) Taught undergraduate and graduate courses in mining engineering; energy, business, and finance; safety
This conference paper was originally published as Krellis, O and Singleton, T, Mine maintenance - the cost of operation, in Aziz, N (ed), Coal 1998: Coal Operators' Conference, University of Wollongong & the Australasian Institute of Mining and Metallurgy, 1998, 81-90.
The Coal Mine Information System (CMIS) is a repository for historical coal mining information in Indiana. It was developed through a cooperative agreement between the Indiana Geological Survey and the Indiana Department of Natural Resources, Division of Reclamation. In addition to historical ...
Feb 26, 2017· HO scale Walthers Cornerstone Coal mine and the track plan ... So I get going again on the HO scale model train layout, getting the walthers cornerstone mine building set up close to the right ...
Working together to achieve innovative solutions in coal - We have the ability to provide superior solutions through our global knowledge of the coal industry combined with our strength and expertise in the minerals processing industry. Our aim is to deliver superior coal process solutions for our clients - big or small, regardless of the location.
Advantages of coal-fired power plant: It's known that coal is the most widely used fuels for generating power and electricity around the world which means that the coal_fired power plant has many advantages as: It's abundant and easy to burn. It doesn't depend on the weather or existing climatic conditions for mining coal.
Chapter 18 Refrigeration Plant and Mine Air Conditioning Systems Malcolm J. McPherson 18- 3 can no longer remain in the liquid phase but burst free to form a vapour or gas (Section 2.1.1). If, however, the applied pressure is raised to a higher value, then additional heat is required to vaporize the liquid.
Where does the coal go after it leaves the mine? The coal is shipped by train or barge to its destination. The coal may be refined before shipping. Washing with water or a chemical bath to remove some impurities. When the coal arrives at the power plant, it is pulverized into a …
The proper layout of mine workings is the responsibility of the manager aided by the planning department. Lift - The amount of coal obtained from a continuous miner in one mining cycle. ... Mine mouth electric plant – A coal burning electric-generating plant built near a coal mine.
Coal mining is the process of extracting coal from the ground. Coal is valued for its energy content and since the 1880s, has been widely used to generate electricity. Steel and cement industries use coal as a fuel for extraction of iron from iron ore and for cement production. In the United Kingdom and South Africa, a coal mine and its structures are a colliery, a coal mine - a pit, and the ...
Coal (Fossil) Plants. CDG's founders got their start in the coal mining business, and with that coal handling expertise, our team of engineers has become a recognized leader in engineering solutions for coal-fired utility plants.
A coal preparation plant (CPP; also known as a coal handling and preparation plant (CHPP), coal handling plant, prep plant, tipple or wash plant) is a facility that washes coal of soil and rock, crushes it into graded sized chunks (sorting), stockpiles grades preparing it for transport to market, and more often than not, also loads coal into rail cars, barges, or ships.
Coal Mining Plant Design. Coal Drying System Process Flow Coal (Wet Basis) from Coal storage yard or coal mine is loaded onto belt conveyor and conveyed to sealing feeder for a direct feed into the JNG energy saving drum dryer.
coal mining plant layout in bilaspur -… The death toll in the blast at coal mines of the Coal India been admitted to the Apollo Hospital in coal mining plant layouts sherasia.com coal Details Get Price. Get Price. New. coal processing plant layout - pankhurifashion.in.
influences the layout of the plant but does not affect the process design. The coal market comprises many sectors, each having specific requirements with respect to both size and quality. In turn, these have led to different levels of preparation and the development of specific types of coal preparation plant design.
The coal is then loaded on to large trucks or conveyors for transport to either the coal preparation plant or direct to where it will be used. Mine rehabilitation. Coal mining is only a temporary use of land, so it is vital that rehabilitation of land takes place once mining operations have stopped.
This is one of the largest coal prep plants in the world - Consol's Bailey Preparation Plant, which processes coal from the Bailey and Enlow Fork longwall mines. This is in western Greene County, an area which wasn't opened up for large scale coal mining until well after the "coal patch" era. (2006 image courtesy of True Photography)
Coal Washing Plant / Coal Preparation Plant. HOT Mining is leading in the design, construction and operation of coal washing plants (coal handling and preparation plants, hereafter "CHPP").. The Joint Venture of HOT – SCCDRI has delivered over 20 CHPPs with capacity from 90 TPH to 3125 TPH.
Coal mining - Coal mining - Coal preparation: As explained above, during the formation of coal and subsequent geologic activities, a coal seam may acquire mineral matter, veins of clay, bands of rock, and igneous intrusions. In addition, during the process of mining, a portion of the roof and floor material may be taken along with the coal seam in order to create adequate working height for ...
Read chapter 4 Coal Mining and Processing: Coal will continue to provide a major portion of energy requirements in the United States for at least the next... Login Register Cart Help. ... coal in electricity generation, 1 this has significant implications for transportation infrastructure and power plant design …
A thorough understanding of subsistence patterns in a particular region allows the effects of underground mining on the surface to be quantified. The coal mining industry uses a range of engineering techniques to design the layout and dimensions of its underground mine workings so that surface subsidence can be anticipated and controlled.
Apr 29, 2019· China Building Hundreds Of Coal-Fired Power Plants Abroad China has taken dramatic steps to fight climate change, including shutting major coal power plants…
Coal Mining and Production ... for the major mining techniques. Beneficiation plants produce large volumes of tailings and solid wastes. Storage and handling of coal generates dust at rates which ... design and operation of coal transportation and transfer facilities.
Mining and Geoscience Courses. Edumine offers the following online courses, short courses and live webcasts. Use the attributes on the left to filter the results.
v37 Queensland Coal Mining Safety and Health Regulation 2017 Subordinate Legislation 2017 No. 165 made under the Coal Mining Safety and Health Act 1999
Glossary of Mining Terminology After Damp - Gasses resulting from underground combustion, normally carbon monoxide. This is a loose term implying any fatal gas in a mine after an explosion or fire. Air Shaft - A vertical opening into a mine for the passage of air. Airway - Any passage in a mine along which an air current moves. Some passages are
A medium-sized layout space gives you room to experiment with techniques, such as a railroad that travels through all four seasons. As your train runs counter-clockwise around this layout, you will be moving not only through scenery depicting Northeastern coal-mining territory, but also through the four seasons of a year.
Fires connected to coal mining create underground burning that can be difficult to remove. Established communities sometimes need to move to avoid the pollution of the coal mines as well, displacing people from their homes. The advantages and disadvantages of coal require a balance of current power needs and environmental management.
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IEEE Wireless & Microwave
Technology Conference
Welcome to WAMICON 2020!
The 21st annual IEEE Wireless and Microwave Technology Conference, WAMICON 2020, will be held in Clearwater Beach, Florida on December 1-3, 2020.
Extended Paper Submission Deadline: TBD. Submit your paper here.
The conference will address up-to-date multidisciplinary research needs and interdisciplinary aspects of wireless and RF technology.
The central theme of WAMICON 2020 will be "Wireless Devices and Systems Making Mad Connections from Space to the 5G IoE." We welcome submissions on all aspects of related technologies, including antennas, passive and active circuits, communication theory, and system concepts.
The program includes both oral and poster presentations as well as tutorials and special sessions. Prospective authors are invited to submit original and high-quality work for presentation at WAMICON 2020 and publication in IEEE Xplore. The conference also features an active vendor exhibition area and an array of networking opportunities.
General Chair Message
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Thursday Lunch
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Poster Session
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December 1-3, 2020
Clearwater Beach, Florida
Read this important announcement about COVID-19.
(C) Copyright 2019 IEEE - All rights reserved. Use of this Web site signifies your agreement to the IEEE Terms and Conditions.
A non-profit organization, IEEE is the world's largest technical professional organization dedicated to advancing technology for the benefit of humanity.


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Regular price
Order will be sent out in 7~10work days;
Free shipping by Epacket ,usually it will take 7~19 days to deliver.
1. Item color displayed in photos maybe showing slightly different on your computer monitor since monitors are not calibrated same.
2. All the products not 100% same as the model picture show.If you are perfectionist,pls kindly considerate before u order it.
3. We guarantee the styles is the same as shown in the pictures,but not the same performance on different bodies as on the model.
4. Above is ASIAN SIZE. It is about 1-2 size Smaller than US, UK,EU SIZE.PLEASE CHOOSE ACCORDING TO OUR SIZE FORM.
All dimensions are personally measured and reality.
5. If the sizes in the chart do not confirm you, please provide your own measurements. when you place an order. Hand measurement will have discrepancy of about 1-3cm. 1inche=2.54cm
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Gender: Women
Neckline: Slash neck
Pattern Type: Patchwork
Style: Casual
Material: Polyester,Cotton
Sleeve Style: Regular
Sleeve Length: Full
Silhouette: Sheath
Dresses Length: Floor-Length
Waistline: Natural
Decoration: Zippers
Item type: African Clothing
Model Number: Dashiki
Type: dress with coat
is_customized: Yes


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- WiFi
- Car park
- Air conditioning
- Swimming pool
- Pets admitted
- Golf
- Accessible
- Sports
- Gym
- Business
Choose your room
Only minutes from Ontario International Airport, this all-suite hotel features spacious accommodations, furnished with all the comforts of home, including fully equipped kitchens, and is close to popular area attractions. In the area surrounding the Homewood Suites Ontario Rancho Cucamonga are the corporate offices of 3M, BMW and UPS. Guests can also easily discover California Motor Speedway, Empire Lakes Golf Course and Ontario Mills Mall. Guests staying at the Ontario Rancho Cucamonga Homewood Suites can start each day with a free hot breakfast, or get energized in the modern fitness center. The hotel also features an on-site basketball court as well as a free evening reception, offering a light meal and beverages.