Show Comments ▼ Goldman to exclude US from Facebook placement Read This NextRicky Schroder Calls Foo Fighters’ Dave Grohl ‘Ignorant Punk’ forThe WrapCNN’s Brian Stelter Draws Criticism for Asking Jen Psaki: ‘What Does theThe WrapDid Donald Trump Wear His Pants Backwards? Kriss Kross Memes Have AlreadyThe WrapPink Floyd’s Roger Waters Denies Zuckerberg’s Request to Use Song in Ad:The Wrap’Sex and the City’ Sequel Series at HBO Max Adds 4 More ReturningThe WrapHarvey Weinstein to Be Extradited to California to Face Sexual AssaultThe WrapThe Truth About Bottled Water – Get the Facts on Drinking Bottled WaterGayot’The View’: Meghan McCain Calls VP Kamala Harris a ‘Moron’ for BorderThe Wrap’Black Widow’ First Reactions: ‘This Is Like the MCU’s Bond Movie’The Wrap whatsapp whatsapp GOLDMAN Sachs has decided to limit its private placement of Facebook shares to investors outside the United States, citing “intense media coverage,” according to the investment bank.“In light of this intense media coverage, Goldman Sachs has decided to proceed only with the offer to investors outside the US,” the company said in a statement.Goldman began notifying clients of its decision on Sunday night in Asia, and clients in Europe and the United States were being told on Monday, the Wall Street Journal reported.Goldman said the decision not to conduct a private placement of the shares of Facebook, a closely held company, in the United States was solely its own and was not required or requested by any other party. Monday 17 January 2011 1:46 pm alison.lock Tags: NULL Share
I would like to receive emails from you about product information and offers from The Fool and its business partners. Each of these emails will provide a link to unsubscribe from future emails. More information about how The Fool collects, stores, and handles personal data is available in its Privacy Statement. Renowned stock-picker Mark Rogers and his analyst team at The Motley Fool UK have named 6 shares that they believe UK investors should consider buying NOW.So if you’re looking for more stock ideas to try and best position your portfolio today, then it might be a good day for you. Because we’re offering a full 33% off your first year of membership to our flagship share-tipping service, backed by our ‘no quibbles’ 30-day subscription fee refund guarantee. Kirsteen has no position in any of the shares mentioned. The Motley Fool UK has recommended Lloyds Banking Group. Views expressed on the companies mentioned in this article are those of the writer and therefore may differ from the official recommendations we make in our subscription services such as Share Advisor, Hidden Winners and Pro. Here at The Motley Fool we believe that considering a diverse range of insights makes us better investors. Will stock market volatility hit Lloyds Banking Group’s share price in 2020? Image source: Getty Images. Kirsteen Mackay | Monday, 13th January, 2020 | More on: LLOY I’m sure you’ll agree that’s quite the statement from Motley Fool Co-Founder Tom Gardner.But since our US analyst team first recommended shares in this unique tech stock back in 2016, the value has soared.What’s more, we firmly believe there’s still plenty of upside in its future. In fact, even throughout the current coronavirus crisis, its performance has been beating Wall St expectations.And right now, we’re giving you a chance to discover exactly what has got our analysts all fired up about this niche industry phenomenon, in our FREE special report, A Top US Share From The Motley Fool. Enter Your Email Address Our 6 ‘Best Buys Now’ Shares “This Stock Could Be Like Buying Amazon in 1997” Simply click below to discover how you can take advantage of this. 2019 was a volatile year for the UK stock market and with the global political situation such as it is, I think 2020 is set to offer up more of the same.If you own shares in Lloyds Banking Group (LSE:LLOY) then you’re probably wondering whether this stock market volatility could affect the share price. Or if you’re considering buying shares in Lloyds, then you’ll also be interested to know what kind of impact stock market volatility could have on your portfolio.5G is here – and shares of this ‘sleeping giant’ could be a great way for you to potentially profit!According to one leading industry firm, the 5G boom could create a global industry worth US$12.3 TRILLION out of thin air…And if you click here we’ll show you something that could be key to unlocking 5G’s full potential…Market fluctuationsPolitical showdowns, Brexit, a slowing world economy and ongoing international trade concerns have all contributed to stock market fluctuations in recent months.Not all of these directly affect Lloyds but being a UK-focused bank, it is highly exposed to the British economy and the local property market, both of which have already been impacted by Brexit.Despite an end finally being in sight, Brexit is still not concluded and is likely to take at least a year to iron out finer details before a true assessment of the impact on the economy can be established.Lloyds has a low price-to-earnings ratio of 11, and earnings per share are 5.5p. While these financials are appealing at first glance, it is important to consider the bigger picture. The business has struggled in recent times due to external factors and self-inflicted woes such as an influx of last-minute PPI claims. Therefore, with reduced confidence in the banking sector, stock market volatility impacted the Lloyds share price both for better and worse in recent months. While Lloyds is always likely to have a market for consumers requiring loans and mortgages, demand is usually lower when interest rates and the economy are uncertain. UK interest rates have been low for a long time now and with so much uncertainty hanging over the economy, I think they’re unlikely to increase soon. Also, there’s increasing competition in the banking sector from cheaper online offerings.Stay strong and holdI think a diverse portfolio containing a variety of shares is essential when investing in the stock market. This is one way to reduce your risk in volatile times. Strong companies with a history of paying dividends are also a good choice because the dividend income brings predictable returns, reducing the risk to capital and increasing overall gains. Seasoned investor Warren Buffett recommends a buy-and-hold investment strategy and although choosing good companies in the first place is key, being confident enough to hold them through troubled times is also essential. If I owned Lloyds shares, then I wouldn’t rush to sell because eventually, interest rates should rise and as Lloyds is an established FTSE 100 company with a generous dividend yield of over 5%, I think it’s worth holding on.But all things considered, I’m not a fan of Lloyds Banking Group as a buy at the moment. I’m steering clear of the banking sector and think stock market volatility could continue to suppress the firm’s shares in the months ahead.By far, the most attractive aspect of Lloyds is its dividend yield, but I’m not sure this is enough to offset the risk to capital investment and its shares could still weaken this year.Don’t be disheartened though, there are plenty of other great dividend shares in the FTSE 350, with good earning potential and less risk attached. Click here to claim your copy now — and we’ll tell you the name of this Top US Share… free of charge! See all posts by Kirsteen Mackay
Seminary of the Southwest announces appointment of two new full time faculty members Seminary of the Southwest Rector Albany, NY Missioner for Disaster Resilience Sacramento, CA Featured Jobs & Calls Ya no son extranjeros: Un diálogo acerca de inmigración Una conversación de Zoom June 22 @ 7 p.m. ET Rector Tampa, FL An Evening with Aliya Cycon Playing the Oud: Crossing continents and cultures with the most beautiful instrument you’ve never heard Lancaster, PA (and streaming online) July 3 Randy Albano says: Rector Shreveport, LA Rector (FT or PT) Indian River, MI Youth Minister Lorton, VA Bishop Diocesan Springfield, IL Assistant/Associate Rector Morristown, NJ Submit an Event Listing The Church Investment Group Commends the Taskforce on the Theology of Money on its report, The Theology of Money and Investing as Doing Theology Church Investment Group Assistant/Associate Priest Scottsdale, AZ Rector Collierville, TN AddThis Sharing ButtonsShare to PrintFriendlyPrintFriendlyShare to FacebookFacebookShare to TwitterTwitterShare to EmailEmailShare to MoreAddThis Priest Associate or Director of Adult Ministries Greenville, SC Join the Episcopal Diocese of Texas in Celebrating the Pauli Murray Feast Online Worship Service June 27 Curate (Associate & Priest-in-Charge) Traverse City, MI An Evening with Presiding Bishop Curry and Iconographer Kelly Latimore Episcopal Migration Ministries via Zoom June 23 @ 6 p.m. ET In-person Retreat: Thanksgiving Trinity Retreat Center (West Cornwall, CT) Nov. 24-28 Episcopal Church releases new prayer book translations into Spanish and French, solicits feedback Episcopal Church Office of Public Affairs Rector and Chaplain Eugene, OR Rector Belleville, IL TryTank Experimental Lab and York St. John University of England Launch Survey to Study the Impact of Covid-19 on the Episcopal Church TryTank Experimental Lab This Summer’s Anti-Racism Training Online Course (Diocese of New Jersey) June 18-July 16 Press Release Service Submit a Job Listing By Pat McCaughanPosted Nov 19, 2014 Course Director Jerusalem, Israel Episcopal Migration Ministries’ Virtual Prayer Vigil for World Refugee Day Facebook Live Prayer Vigil June 20 @ 7 p.m. ET Rector Hopkinsville, KY November 20, 2014 at 4:19 pm Erna,Thank you very much for your very kind and gracious comments re Filipno Community and Clergy. Please know that it has been a joy, a pleasure and blessing having you at St. Paul’s Church. Once again with open minds, hearts and soul we say, Aloha, Mabuhay ken Agbiag!!!!! May God contiue to bless and keep you always. Remember Holy Land Christians on Jerusalem Sunday, June 20 American Friends of the Episcopal Diocese of Jerusalem November 19, 2014 at 6:31 pm Mahalo nui–Thank you so much for recognizing the tremendous contribution of the Filipino community, and notably the Filipino clergy–and yes, I have had the distinct spiritual pleasure of Eucharist at St. Paul’s Church adjoining St. Andrew’s Cathedral, Honolulu… and meeting many of the parishioners there … and experiencing the fruitful association of the Cathedral and St.Paul’s! In fact I will be returning there for the Holidays and again look forward to this fullsome, spiritual connection. Rector Martinsville, VA Associate Rector for Family Ministries Anchorage, AK Priest-in-Charge Lebanon, OH Episcopal Charities of the Diocese of New York Hires Reverend Kevin W. VanHook, II as Executive Director Episcopal Charities of the Diocese of New York New Berrigan Book With Episcopal Roots Cascade Books Curate Diocese of Nebraska Rector Washington, DC Canon for Family Ministry Jackson, MS Director of Administration & Finance Atlanta, GA Associate Priest for Pastoral Care New York, NY Director of Music Morristown, NJ Rector Smithfield, NC Rector/Priest in Charge (PT) Lisbon, ME Associate Rector Columbus, GA Featured Events The Rev. Justo Andres and those who attended the celebration for him at St. John’s, Stockton. Photo: Lewis Gale[Episcopal News Service] The pioneering missionary spirit of the Rev. Justo Andres just may help spark a revival of Filipino ministry at the Episcopal Church of St. John the Evangelist in Stockton, California, according to the Rev. Fred Vergara, missioner for Episcopal Church Asiamerica Ministries.Some 30 years ago, Andres founded the Holy Cross Filipino Mission at St. John’s, in the Episcopal Diocese of San Joaquin, and on Nov. 16 the diocesan community gathered to celebrate that legacy and his 85th birthday as well as possibilities for new ministry.San Joaquin Bishop David Rice officiated at a Eucharist in Andres’ honor. He said the service commemorated Andres’ 1983 call to the Stockton community and “the ministry he has provided and the significant place he represents in the life of the Diocese of San Joaquin and in the Filipino community and ways in which he has so faithfully lived out his priesthood in our midst.“This is a response to our context as we’ve seen, experienced and engaged it in the Stockton area,” added Rice. “We think that responding to that part of our landscape, part of our population and community is the right thing to do.”Andres often conducted services for migrant workers in the fields and for the sailors aboard ocean-going ships that docked at the Port of Stockton. The Holy Cross Mission served as a satellite agency of the former U.S. Immigration and Naturalization Service, assisting many in attaining their naturalized U.S. citizenship.He also served as a translator within the Stockton court system and was a member of a police advisory committee.In a telephone interview with the Episcopal News Service, Madeline Ruiz, sister-in-law of Andres, speaking for Andres who suffers from age-related hearing loss, described him as excited “but surprised about the celebration.“He asked me why are they honoring him,” said Ruiz. “I said it’s because you started a Filipino ministry at St. John’s and now that they got the church back, they want to honor you.”Under Andres’ leadership, the Holy Cross congregation flourished and included Filipinos, Latinos, Southeast Asians and Anglos among its membership. The congregation disbanded when theological differences split the diocese in 2008. St. John’s property had been held by a breakaway group, but was returned to the Episcopal Church earlier this year.Rice said the diocese is considering revitalizing its ministry among the Filipino community. “We are discerning, praying through, contemplating, pondering and giving thought to how we might continue to engage and develop that ministry.”The Rev. Canon Kate Cullinane, diocesan canon to the ordinary and St. John’s priest-in-charge, said nearly 200 well-wishers attended the gathering and a joyous reception afterward.The reception included traditional Filipino food and dancing as well as line dancing, she said. There was also a serenade of Andres, with participants each presenting him a flower.“I loved the fact that so many people from the neighboring Filipino congregations and the neighboring congregations from the deanery came” to support Andres and this service, Cullinane said in an e-mail to ENS.Rekindling the ministry will be a collaborative effort within the diocese, she added. “We don’t see this as a St. John’s project, but a northern deanery project,” she said.Andres was born in Bacarra, in the Ilocos Norte Province of the northern Philippines, the youngest of seven children. He was educated at St. Andrew’s Theological Seminary and the Far Eastern University in Manila and was ordained to the priesthood in 1955 by the Most Rev. Isabelo Delos Reyes Jr., obispo máximo of the Philippine Independent Church.His first parish assignment was to Ozamiz City in the southern Philippines’ region of Mindanao, before accepting a call to Maui. He was among a trio of priests who were part of the first wave of Filipino priests called to the Episcopal Church.Two other priests, the Rev. Timoteo Quintero and the Rev. Jacinto Tabili, also accepted calls to Hawaii. Quintero founded St. Paul’s Church in Honolulu and Tabili served in Hilo on Hawaii’s big island but later returned to become a bishop in the Philippines, according to Vergara. In the early 1960s, Andres was called to serve Good Shepherd Church in Wailuku on the island of Maui.In 1983, Andres accepted a call to St. John’s in Stockton. He is the sole survivor of that first wave of Filipino priests serving with the Episcopal Church, Vergara said. Raquel Nancy Andres, his spouse and partner in ministry, died in 2009.Vergara, who preached at the Nov. 16 Eucharist, noted that St. John’s was organized a year after the city of Stockton was founded and played a key role in the development of the city. The church has an equally important role in the future of the California city, he said.Asians and Pacific Islanders account for 22 percent of Stockton’s 300,000 residents, according to 2013 U.S. Census data.“We gather here today in the name of Christ to witness the work of a creating and re-creating God,” Vergara told those who gathered at the bilingual worship service at St. John’s.“In this beautiful city of Stockton, God will start this work with you and me. Together, we shall be God’s instrument in starting the revival, renewal and re-creation of St. John’s.“This is the challenge to us, to rediscover the treasure that is at St. John’s and to invest our talents to pray for the revival of Stockton’s destiny,” he said.“Just as its history is tied with Stockton’s history, so is the revival of Stockton to be tied to the revival of St. John’s – and the destiny of Stockton be tied to the destiny of St. John’s. With the spiritual revival of St. John’s, will follow Stockton’s revival in peace, progress and prosperity.”–The Rev. Pat McCaughan is a correspondent for the Episcopal News Service. San Joaquin honors pioneer Filipino priest Diocese contemplates revitalized ministry The Church Pension Fund Invests $20 Million in Impact Investment Fund Designed to Preserve Workforce Housing Communities Nationwide Church Pension Group Family Ministry Coordinator Baton Rouge, LA Inaugural Diocesan Feast Day Celebrating Juneteenth San Francisco, CA (and livestream) June 19 @ 2 p.m. PT Rector Bath, NC Comments are closed. Cathedral Dean Boise, ID Erna Lund says: Virtual Celebration of the Jerusalem Princess Basma Center Zoom Conversation June 19 @ 12 p.m. ET Submit a Press Release Comments (2) Assistant/Associate Rector Washington, DC Rector Pittsburgh, PA Rector Knoxville, TN
111 total views, 2 views today AddThis Sharing ButtonsShare to TwitterTwitterShare to FacebookFacebookShare to LinkedInLinkedInShare to EmailEmailShare to WhatsAppWhatsAppShare to MessengerMessengerShare to MoreAddThis2 Community engagement and empowerment charity the Community Development Foundation has announced that it is to close early next year.The CDF’s trustees and senior team unanimously reached the decision to cease trading in early 2016, and are seeking to transfer the charity’s assets, including reserves, intellectual property and potentially programmes and products, to another organisation.While the CDF said it could continue trading until 2018, the trustees and senior team have said that they believe the move to be the best way to support community development and achieve the CDF’s charitable objectives in the long term.The trustees will begin the process of finding suitable organisations to transfer its assets over to in January, while the organisation will continue to meet its contractual obligations until March 2016.Alison Seabrooke, CDF chief executive, said:“The operating environment has changed radically and we are convinced we must act now from a position of strength. We will fulfil our contractual obligations until March 2016. Some staff will stay on until the end of April 2016 to finalise these and to deliver a well-managed closure.” 110 total views, 1 views today Advertisement AddThis Sharing ButtonsShare to TwitterTwitterShare to FacebookFacebookShare to LinkedInLinkedInShare to EmailEmailShare to WhatsAppWhatsAppShare to MessengerMessengerShare to MoreAddThis2 Community Development Foundation to close in 2016 Tagged with: community foundations Funding Melanie May | 23 December 2015 | News About Melanie May Melanie May is a journalist and copywriter specialising in writing both for and about the charity and marketing services sectors since 2001. She can be reached via www.thepurplepim.com.
printFort Worth’s sky will soon light up for the 2015 Fort Worth’s Fourth celebration, an annual free family festival at Panther Island Pavilion celebrating Independence Day.Saturday’s festivities are scheduled to begin at 2 p.m. and conclude with the largest fireworks show in North Texas at 10 p.m.As many as 70,000 people are expected to make their way to the river’s banks for this year’s festival, a festival with everything from a free kidzone to jet ski and fly board shows.Attendees can also enjoy live music played by The Landsharks, a Jimmy Buffett tribute band, and Downtown Fever, a popular Dallas cover band.“We strive to improve Fort Worth’s Fourth every year and we are very excited to offer a new VIP Experience at this year’s festival,” J.D. Granger, executive director for Trinity River Vision Authority, said.VIP pre-sale tickets have already sold out; however, a small level of attendees can purchase overflow tickets on the event day. General admission and tubing is free.“Whether you’re looking for a day of free family fun on the Trinity or for an upgraded VIP experience, Fort Worth’s Fourth now has something for everyone,” Granger said.Full Schedule of Activities:2 p.m. – Gates open3:30, 4:30 and 5:30 – Battle of Bald Eagle Competition (Sponsored by 95.9 The Ranch)3, 4:15 and 7:30 – Jet Ski Shows6 p.m. Live music at the Waterfront Stage with The Land Sharks4, 5, 7:45 and 9:30 – Flyboard Shows (Night time is a light suit show)7:30 and 7:55 – The Dallas Cowboys Rhythm and Blue Dancers8 p.m. – F-16 Flyover8 p.m. – Live music on the Coors Light Waterfront Stage with Downtown Fever.10 p.m. – Largest Fireworks Show in North TexasFor additional information on activities and foods, along with parking and traffic information, visit Fort Worth’s Fourth 2015 website.Featured below is a video of last year’s Fort Worth’s Fourth celebration. The109: senior minister at University Christian Church announces resignation Twitter Fort Worth Firefighters Charities posts signs for drowning prevention month Facebook Joey McReynolds Facebook Twitter Grains to grocery: One bread maker brings together farmers and artisans at locally-sourced store ReddIt Previous articleNeighborhood Fourth of July parade provides celebration optionsNext articleFort Worth Neighborhood builds community through Fourth of July parade Joey McReynolds RELATED ARTICLESMORE FROM AUTHOR Joey McReynoldshttps://www.tcu360.com/author/joey-mcreynolds/ Joey McReynoldshttps://www.tcu360.com/author/joey-mcreynolds/ Linkedin Joey McReynoldshttps://www.tcu360.com/author/joey-mcreynolds/ Abortion access threatened as restrictive bills make their way through Texas Legislature Joey McReynoldshttps://www.tcu360.com/author/joey-mcreynolds/ Linkedin ReddIt Trump to appear at Fort Worth Convention Center Fort Worth to present development plan for Berry/University area near TCU + posts Fort Worth set to elect first new mayor in 10 years Saturday
News Organisation April 27, 2021 Find out more RSF begins research into mechanisms for protecting journalists in Latin America Help by sharing this information May 13, 2021 Find out more BrazilAmericas Christophe DeloireReporters Without Borders secretary-general Receive email alerts News Paris, 1 June 2015 Dear President Roussef,After two brutal murders of journalists in the space of a week, Reporters Without Borders, an international organization that defends freedom of information, urges Brazil to quickly adopt concrete and effective measures to guarantee the protection of news providers and to combat impunity for crimes of violence against them.Brazil is the western hemisphere’s third deadliest country for the media (after Mexico and Honduras), with a total of 38 journalists murdered in a clear or possible connection with their work from January 2000 to December 2014. Almost all were investigating sensitive subjects such as organized crime, human rights violations, corruption or different kinds of trafficking. The organized crime presence in certain regions makes covering these subjects particularly risky. At the same time, the impunity prevailing in most of the cases increases the probability of their recurring. The trend has worsened in recent years with at least ten journalists killed in Brazil in direct connection with their work in 2012 and 2013, two in 2014 and now three since the start of 2015.The latest victim was Djalma Santos da Conceição, a radio journalist with RCA FM in Conceição da Feira, in the northeastern state of Bahia, who was kidnapped and shot dead on 22 May. His body bore the marks of torture. According to local sources, he had been threatened and had been investigating the murder of a teenage girl by traffickers.Evany José Metzker, an investigative journalist who kept a blog called Coruja do Vale, was found beheaded near Padre Paraiso, in the northeast of the state of Minas Gerais, on 18 May, five days after being reporting missing. He had been investigating drug trafficking and child prostitution for several months and had covered several regional corruption cases in his blog, accusing local officials of involvement.Gerardo Servian Coronel, a Paraguayan journalist working for Radio Ciudad Nueva, was gunned down in Ponta Porã, a Brazilian city near the Paraguayan border, on 4 March.An increase in violence against journalists has also been seen during the major protests against public transport price hikes in São Paulo and against spending on the 2014 FIFA World Cup and the 2016 Summer Olympics. Local and foreign journalists covering these protests from June 2013 to July 2014 were the targets of abusive treatment by the police that included insults, threats, arrests, arbitrary detention, physical violence and beatings. The Brazilian Association of Investigative Journalists (ABRAJI) registered 210 cases of abusive treatment of professional and non-professional journalists, 38 of them during the World Cup. The military police were responsible for most of these cases. Bandeirantes TV cameraman Santiago Ilídio Andrade was fatally injured while covering a protest in Rio de Janeiro on 6 February 2014.In a report on violence against journalists issued in March 2014, a month after Andrade’s death, the Human Rights Secretariat recommended creating an Observatory for Violence against Journalists in partnership with UNESCO, and putting the federal authorities in charge of investigating crimes against journalists. More than a year later, no action has been taken. A bill that would have put the federal authorities in charge of investigating such crimes was rejected on 20 May by the Chamber of Deputies commission on public safety and combatting organized crime.In view of the level of violence against journalists, implementation of the recommendations by the Human Rights Secretariat’s working group on the safety of journalist is more necessary and urgent than ever. Combatting impunity must be a priority. Journalists will continue to be in danger as long as crimes of violence against them are not the subject of independent, impartial and thorough investigations that result in those responsible being identified and punished.We thank you in advance for the attention that you give to our request.Sincerely, April 15, 2021 Find out more June 1, 2015 – Updated on January 20, 2016 Open letter to Dilma Roussef about failure to punish murders of journalists to go further Follow the news on Brazil Reports BrazilAmericas RSF_en News 2011-2020: A study of journalist murders in Latin America confirms the importance of strengthening protection policies Appalled by the brutal murders of two Brazilian journalists in the space of a few days, Reporters Without Borders has written to President Dilma Roussef asking her to end the prevailing impunity for crimes of violence against media personnel in her country. President Dilma RoussefPalacio do PlanaltoPraça dos Três Poderes Brasília Alarm after two journalists murdered in Brazil Related documents carta_dilma_-_pt-3.pdfPDF – 151.21 KB
Home / Daily Dose / Supreme Court Looks at Applicability of Contempt Sanctions in Bankruptcy in Daily Dose, Featured, News, Print Features Supreme Court Looks at Applicability of Contempt Sanctions in Bankruptcy About Author: Rose Marie Brook Fabrizio & Brook, P.C January 6, 2020 1,804 Views 2020-01-06 Seth Welborn Share Save Servicers Navigate the Post-Pandemic World 2 days ago Data Provider Black Knight to Acquire Top of Mind 2 days ago An order for discharge in bankruptcy acts as an injunction against any act to collect, recover, or offset a discharged debt. This includes the commencement or continuation of a lawsuit for same. The United States Code sections 524 and 105 authorize a court to impose civil contempt sanctions when a discharge order is breached and, as we know, for the most part, this has been strictly enforced.The majority of courts treat violation of a discharge order close to strict liability. As long as a creditor acted deliberately, with knowledge of the bankruptcy case, civil sanctions may be appropriate. A subjective belief that an action was in compliance, or otherwise exempt from the bankruptcy discharge, would not insulate a creditor from civil contempt.A minority of circuits have followed a more lenient, subjective standard wherein a creditor would not be held in civil contempt simply by establishing that it had a good faith belief that the discharge order did not apply to its claim, even if this belief was unreasonable.The Supreme Court issued a unanimous decision this past June, establishing a new standard for holding a creditor in contempt for violation of a discharge injunction [In re Taggart, 139 S Ct 1795 (2019)]. The court created a standard based on “objective reasonableness.” In other words, the court should not impose contempt sanctions where there is a fair ground of doubt as to the wrongfulness of the defendant’s conduct.In Taggart a prepetition lawsuit for injunctive relief resumed after the debtor’s chapter 7 bankruptcy discharge had entered. The plaintiff was successful in the lawsuit and proceeded to file an action to recover its post-petition attorney fees. The state court held that the discharge injunction did not apply to this debt and granted plaintiff’s post-petition attorney fees. The defendant reopened the bankruptcy action and filed a motion for contempt for violation of the discharge order. The bankruptcy court entered an order for contempt and sanctions for violation of discharge despite the state court’s finding that the discharge did not apply to this debt. After several appeals, the Ninth Circuit, applying a subjective standard of review, ultimately reversed the ruling for contempt and sanctions against plaintiff. The defendant, Taggart, appealed to the Supreme Court and was granted certiorari.Taggart argued that the plaintiff was in violation of the discharge injunction because it was “aware of the discharge” and “intended the action.” This is the strict liability standard applied in the majority of circuits. The Ninth Circuit disagreed because plaintiff was advised by the state court that the discharge did not apply to collection of these post-petition attorney fees and therefore had a “good faith belief” that the discharge injunction did not apply to its action. The Ninth Circuit relied on a subjective standard used in a minority of circuits.Both standards were problematic in that the strict liability standard could lead to sanctions in cases even with a cautious creditor with a reasonable belief that the discharge was not applicable (i.e. a lower court opinion). Alternately, the subjective standard would rely too heavily on “difficult to prove states of mind” leading to costly litigation for both creditors and debtors. In an attempt to create something in between the majority strict liability standard and the less common, subjective standard, the Supreme Court created what may be referred to as an “objective reasonableness” standard. Using this standard, a bankruptcy court may only impose civil contempt sanctions for violating discharge “if there is no fair ground of doubt as to whether the order barred the creditor’s conduct … when there is no objectively reasonable basis for concluding that the creditor’s conduct might be lawful under the discharge order.”The Supreme Court created an objective standard that takes into account reasonableness and good faith. This allows creditors to be somewhat less risk averse in servicing mortgage loans after a bankruptcy discharge. A less strict standard for sanctions is not only beneficial to creditors but could also be beneficial to debtors seeking information about their loans or post-bankruptcy loss mitigation options. It also minimizes some of the conflict creditors face in complying with financial protection rules requiring disclosure such as the FDCPA and FCRA with less threat of sanctions for conflicting with bankruptcy regulations. 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News UpdatesNCLT Cancels Summer Vacation 2020 For All Its Benches [Read Office Order] LIVELAW NEWS NETWORK5 May 2020 7:09 AMShare This – xThe National Company Law Tribunal has cancelled the Summer Vacation, 2020 for all its benches, in view of loss of work due to the lockdown. A notification issued by the Registrar in this behalf states, “Hon’ble President, National Company Law Tribunal is pleased to order that Summer Vacations falling in the months of May/June/July 2020 as shown in the Calendar of the…Your free access to Live Law has expiredTo read the article, get a premium account.Your Subscription Supports Independent JournalismSubscription starts from ₹ 599+GST (For 6 Months)View PlansPremium account gives you:Unlimited access to Live Law Archives, Weekly/Monthly Digest, Exclusive Notifications, Comments.Reading experience of Ad Free Version, Petition Copies, Judgement/Order Copies.Subscribe NowAlready a subscriber?LoginThe National Company Law Tribunal has cancelled the Summer Vacation, 2020 for all its benches, in view of loss of work due to the lockdown. A notification issued by the Registrar in this behalf states, “Hon’ble President, National Company Law Tribunal is pleased to order that Summer Vacations falling in the months of May/June/July 2020 as shown in the Calendar of the respective NCLT Bench stand cancelled and all Benches of NCLT shall function during the said period.” On a related note, the National Green Tribunal and the High Courts of Bombay, Madras, Karnataka, Kerala, Delhi, Gujarat, Orissa and Telangana have also canecelled the summer vacations to compensate for loss of court work. Whereas, the Calcutta High Court has notified vacation benches and the Allahabad High Court has restricted the period of vacation between June 22 and June 26, 2020. Click Here To Download Office Order Read Office Order Next Story
Michał Chodyra/iStock(CHARLOTTESVILLE, Va.) — A jury recommends that the man who rammed his car into a crowd of people during the ‘Unite the Right’ rally in Charlottesville in 2017 should spend life in prison plus 419 years behind bars.James Alex Fields, 21, was found guilty of first-degree murder, five counts of aggravated malicious wounding and three counts of malicious wounding in the incident.The judge in the case will ultimately hand down the sentence.The 10 charges Fields faced in this trial in the Charlottesville City Circuit Court are separate from the 30 federal charges he faces that relate to hate crimes. One of those federal charges is eligible for the death penalty. He entered a not guilty plea in both the Circuit Court case and to the federal charges.The sentence came the day after jurors heard victim impact statements from Susan Bro, the mother of Heather Heyer who was killed in the crash, as well as several people who suffered injuries in the August 2017 crash.Copyright © 2018, ABC Radio. All rights reserved.,Michał Chodyra/iStock(CHARLOTTESVILLE, Va.) — A jury recommends that the man who rammed his car into a crowd of people during the ‘Unite the Right’ rally in Charlottesville in 2017 should spend life in prison plus 419 years behind bars.James Alex Fields, 21, was found guilty of first-degree murder, five counts of aggravated malicious wounding and three counts of malicious wounding in the incident.The judge in the case will ultimately hand down the sentence.The 10 charges Fields faced in this trial in the Charlottesville City Circuit Court are separate from the 30 federal charges he faces that relate to hate crimes. One of those federal charges is eligible for the death penalty. He entered a not guilty plea in both the Circuit Court case and to the federal charges.The sentence came the day after jurors heard victim impact statements from Susan Bro, the mother of Heather Heyer who was killed in the crash, as well as several people who suffered injuries in the August 2017 crash.Copyright © 2018, ABC Radio. All rights reserved.