title: Titan Airways

text: In 2021, following significant air-freight capacity shortages due to the COVID19 pandemic, Geodis Air Network leased an Airbus A330-300 converted freighter from JP Lease. The aircraft is operated by Titan Airways and is registered G-EODS. It is to fly between Amsterdam, London, Chicago and Hong Kong.


title: Sampa the Great

text: Sampa Tembo (born 9 August 1993), known professionally as Sampa the Great, is a Zambian singer, rapper and songwriter. Between 2014 and 2020, she was based in Australia. Her debut solo album, "The Return" (September 2019), peaked at No. 12 on the ARIA Albums Chart. At the ARIA Music Awards of 2019 she won Best Hip Hop Release for her second single, "Final Form". In the following year she won the same category for "The Return", as well as Best Female Artist and Best Independent Release. In March 2020 Sampa became the first artist to win the Australian Music Prize twice: for "Birds and the Bee9" (November 2017) and "The Return".


title: Sampa the Great

text: Sampa Tembo was born in 1993 in Zambia and was raised there and in Botswana, as the middle of five children. Her mother, a dancer, Theresa is from the Bemba people while her father, an insurance broker and some-time DJ, is from the Tumbuka. Her sister, Mwanje Tembo, is a singer. She received both piano and singing lessons and started writing poems/lyrics from the age of nine. In the early 2010s she studied music for visual media at the Academy of Art University, San Francisco, for two years and Los Angeles for a year. While in San Francisco she recorded two tracks.


title: Sampa the Great

text: Tembo moved to Sydney in 2013 and was based there until 2018, she completed a Bachelor degree in audio engineering at SAE Institute in 2015. As of 2018 she is based in Melbourne. The artist acknowledges her family and communities in both Botswana and Zambia as the foundation of her success.


title: Sampa the Great

text: Sampa the Great was featured on the second single, "Beauty" (September 2015), by future soul singer-songwriter Wallace ( Wallace Gollan). The rapper's debut mixtape, "The Great Mixtape", was released as a free download on 16 October 2015, and later on CD and vinyl by Melbourne label Wondercore Island. The artist described it as "a search for creativity, laughter, purpose and rhythms", and credits her African youth for inspiring the "political consciousness" on the record. It was produced by Sydney-based Dave Rodriguez ( Godriguez). They had met at a jazz and hip-hop freestyle at a club, Foundry, in Sydney. Sampa the Great's vocals were recorded in two takes. On 18 December a mixtape track, "F E M A L E", was released as a single. The track was co-written by Tembo with D Rodrguez-Lovibond.


title: Sampa the Great

text: On 19 January 2016 Sampa the Great released a standalone single, "Black Dignity". Two days later another standalone single, "Blue Boss", was issued. The rapper featured on the track "Second Heartbeat" alongside Okenyo, for Urthboy's fifth studio album, "The Past Beats Inside Me Like a Second Heartbeat" (March 2016). Another two standalone singles followed, "24" and "Blessings", released together on 25 May. On 6 October she issued a music video, "HERoes (The Call)". On 27 October a related music video, "HERoes (The Response)", was released.


title: Sampa the Great

text: On 28 April 2017 Sampa the Great released a single, "Everybody's Hero" featuring British singer Estelle. Her debut extended play, "HERoes Act 2" was the issued on 12 May. In an interview she described it as, "a snapshot of a time of uncertainty and doubt, and the realisation that those aspects are very normal". On the EP the rapper collaborated with producer, Rahki. The second and third singles from the EP, "The Plug" and "Paved with Gold", also featuring Estelle, were released on 11 May.


title: Sampa the Great

text: Sampa the Great issued a second mixtape, "Birds and the Bee9" (10 November 2017), which "crosses hip-hop, soul, jazz, gospel and reggae", via the Big Dada label. It was produced by Sensible J, Silentjay and Kwesi Darko. The track "Casper" contained guest vocals from Syreneyiscreamy, the track "Inner Voice" contained guest vocals from Mwanje Tembo, and the track "Healer" contained guest vocals from Zaachariaha. The mixtape won the Australian Music Prize in March 2018, which includes AUD$30000 from Phonographic Performance Company of Australia (PPCA), with their CEO Dan Rosen hoping it, "will assist in developing [her] career and help take her music to the world." She hoped to use the prizemoney to fund her own home studio.


title: Sampa the Great

text: "Birds and the BEE9" received positive reviews. "The Guardian"s Kitty Empire noticed influences from Lauryn Hill. On 3 October the single, "Rhymes to the East", was released. On 17 October, the single "Bye River" was released. On 20 October, she featured on the track "Your Orbit" by Ecca Vandal, on her eponymous debut album "Ecca Vandal". On 5 April 2018 a music video, "Black Girl Magik" featuring Nicole Gumbe, was issued. On 23 April the rapper was featured in the music video, "Your Orbit" by Ecca Vandal.


title: Sampa the Great

text: On 29 November 2018 the artist released her single, "Energy" featuring Nadeem Din-Gabisi along with an accompanying music video. She intended to release her debut studio album later that year: however, it was delayed. On 5 June 2019 another single, "Final Form" appeared with a music video. Her debut album, "The Return", was released on 13 September 2019 via Ninja Tune. In October 2019 she was listed at No. 2 on "Happy Mag"s "The 15 Australian Female Artists Changing the Game Right Now."


title: Sampa the Great

text: At the ARIA Music Awards of 2019 Sampa the Great was nominated in two categories: Best Video (directed by Sanjay De Silva) and Best Hip Hop Release for "Final Form". Upon winning Best Hip Hop Release the artist was "snubbed" by ARIA when the TV broadcast switched to a commercial rather than show her acceptance speech. As the first female person of colour to win a hip hop category the move exemplified systemic racism in the industry. In March 2020 Sampa the Great won the Australian Music Prize for "The Return"; becoming the first musician in its 15-year history to win the award twice.


title: Sampa the Great

text: On 23 September 2020 the singer released "Better Days" with Baker Boy and Dallas Woods. The artist was nominated in six categories at the 2020 ARIA Music Awards, held in November, and won three: Best Hip Hop Release, Best Female Artist and Best Independent Release for "The Return". She also performed at the 2020 ceremony through a video-link to Botswana and delivered "a strong statement" on "lack of diversity of the Australian music industry" and specifically took aim at the ARIA board for her snubbing in the previous year.


title: Sampa the Great

text: In November 2021, Sampa the Great confirmed new music would arrive in early 2022. She is also due to tour North America in March and April 2022. Her track, "Never Forget", is a tribute to Zamrock; she has also worked with Emmanuel Jagari Chanda lead singer of Witch.


title: Sampa the Great

text: On 29 June 2022, Sampa the Great announced the release of her second studio album, "As Above, So Below", which was released on 9 September 2022. The album was produced by Mag44, as revealed by Sampa the Great in an interview on the Zed Podcast. The album has been receiving positive reviews from critics.


title: Sampa the Great

text: Sampa Tembo's identity as a Zambian-born, Botswana-raised individual is fundamental to her music. However, once her work appeared on radio, media reported on her as "Australia's own" and "Australia's next big thing in hip-hop." She reflected, "For anyone who's of the diverse world, or who has had trouble or has a journey with where they are from, it's important to document your stripes whether small or big, because we're living in a world that makes it harder for you to find those origins, and sometimes often mocks you for finding those origins." Outside of her music career Tembo is interested in sprinting.


title: Sampa the Great

text: Sampa the Great's early work "was inspired by spiritually-minded gospel, with nods to neo-soul and hip-hop intertwined with her no-holds-barred political outlook." She discovered hip-hop as a child, noting listening to 2Pac's "Changes" as a catalyst for her interest in the genre. She has been influenced by Mos Def and Chance the Rapper. She has performed as a supporting act for Joey Bada$$, as well as Kendrick Lamar, Thundercat, and Denzel Curry. Tembo described Joey as a "passionate artist and an amazing performer".


title: Sampa the Great

text: She invokes a variety of influences, including abstract hip-hop beats, African influences, electronica, spiritual neo-soul, and other styles. Her music is described as earthy and eclectic.


title: Sampa the Great

text: The Australian Independent Record Awards (commonly known informally as AIR Awards) is an annual awards night to recognise, promote and celebrate the success of Australia's Independent Music sector.


title: Sampa the Great

text: The APRA Awards are held in Australia and New Zealand by the Australasian Performing Right Association to recognise songwriting skills, sales and airplay performance by its members annually. Sampa the Great has been nominated for one award.


title: Sampa the Great

text: The ARIA Music Awards is an annual award ceremony event celebrating the Australian music industry. Sampa the Great won Best Hip Hop Release at the ARIA Music Awards of 2019, from two nominations. She won three categories from six nominations in 2020.


title: Sampa the Great

text: The Australian Music Prize (the AMP) is an annual award of $30,000 given to an Australian band or solo artist in recognition of the merit of an album released during the year of award. The commenced in 2005.


title: Sampa the Great

text: The J Awards are an annual series of Australian music awards that were established by the Australian Broadcasting Corporation's youth-focused radio station Triple J. They commenced in 2005.


title: Sampa the Great

text: The MTV Europe Music Awards is an award presented by Viacom International Media Networks to honour artists and music in pop culture.


title: Sampa the Great

text: The Music Victoria Awards, are an annual awards night celebrating Victorian music. The commenced in 2005.


title: Sampa the Great

text: The National Indigenous Music Awards is an annual awards ceremony that recognises the achievements of Indigenous Australians in music. The award ceremony commenced in 2004.


title: Sampa the Great

text: The National Live Music Awards (NLMAs) are a broad recognition of Australia's diverse live industry, celebrating the success of the Australian live scene. The awards commenced in 2016.


title: 2008 Ballon d'Or

text: The 2008 Ballon d'Or, given to the best football player in the world as judged by an international panel of sports journalists, was awarded on 2 December 2008. Cristiano Ronaldo won the award, being his first of five. His win also began a 10-year dominance of the award between him and Lionel Messi — which eventually led to an intense rivalry between the two. Both players had won five Ballon d'Or awards before the dominance was ended in 2018.


title: 2021–22 Pro Kabaddi League season

text: The 2021-22 Vivo Pro Kabaddi League was the eighth season of Pro Kabaddi League. The season began on 22 December 2021. The usual travelling caravan format was changed to a single venue hosting all the matches of the season. Kanteerava Indoor Stadium, Bangalore was initially announced as the venue, but was later changed to the Sheraton Grand Hotel and Convention Center located in Whitefield, Bangalore.


title: 2021–22 Pro Kabaddi League season

text: Each team played against all the other teams twice, and the top 6 teams proceed to the play-offs. The player auctions for the season 8 were conducted from August 29 to 31, 2021 in Mumbai. Dabang Delhi defeated Patna Pirates in the final match to win their maiden title


title: 2021–22 Pro Kabaddi League season

text: This year PKL was played without an audience and shed the caravan style format. Instead, all teams played at a single location in Bengaluru. Looking back at IPL last year, media planners suggest that format changes will have little to no impact on the viewership of the tournament. Mashal Sports has also announced that triple headers will be played on all Saturdays which may have a positive impact on the viewership over weekends.


title: Kachina

text: A kachina (; also katchina, katcina, or katsina; Hopi: "katsina" , plural "katsinim" ) is a spirit being in the religious beliefs of the Pueblo peoples, Native American cultures located in the south-western part of the United States. In the Pueblo cultures, kachina rites are practiced by the Hopi, Zuni, Hopi-Tewa, and certain Keresan tribes, as well as in most Pueblo tribes in New Mexico.


title: Kachina

text: The kachina concept has three different aspects: the supernatural being, the kachina dancers, and kachina dolls (small dolls carved in the likeness of the kachina, that are given only to those who are, or will be responsible for the respectful care and well-being of the doll, such as a mother, wife, or sister).


title: Kachina

text: Kachinas are spirits or personifications of things in the real world. These spirits are believed to visit the Hopi villages during the first half of the year. The local pantheon of kachinas varies from pueblo community to community. A kachina can represent anything in the natural world or cosmos, from a revered ancestor to an element, a location, a quality, a natural phenomenon, or a concept; there may be kachinas for the sun, stars, thunderstorms, wind, corn, insects, as well as many other concepts.


title: Kachina

text: Kachinas are understood as having human-like relationships, such as having uncles, sisters, and grandmothers, as well as marrying and having children. Although not worshipped, each is viewed as a powerful being who, if given veneration and respect, can use his particular power for human good, bringing rainfall, healing, fertility, or protection, for example. The central theme of kachina beliefs and practices as explained by is "the presence of life in all objects that fill the universe. Everything has an essence or a life force, and humans must interact with these or fail to survive."


title: Kachina

text: Beginning around 1900, there was a great deal of interest in the Kachina figurines, especially among white tourists, and the dolls became sought-after collectibles. For this reason, many Hopi began making the figurines commercially to make a living.


title: Kachina

text: In many ways the Kachina rites are the most important ceremonial observances in the Hopi religious calendar. Within Hopi religion, the kachinas are said to live on the San Francisco Peaks near Flagstaff, Arizona. To the Hopis, kachinas are supernatural beings who visit the villages to help the Hopis with everyday activities and act as a link between gods and mortals.


title: Kachina

text: According to Susanne and Jake Page, the "katsinam" are "the spirits of all things in the universe, of rocks, stars, animals, plants, and ancestors who have lived good lives." These spirits are then impersonated by male dancers wearing costumes and masks for ceremonies during the first half of the year.


title: Kachina

text: The first ceremony of the year, the "Powamu", occurs in February and is associated with the bean planting, the growing season, and coming of age. The last katsina ceremony, "Niman", occurs in July and is associated with the harvest, after which the katsinam return to their home in the San Francisco Peaks.


title: Kachina

text: Hopi kachina dolls, "tihü", are ceremonial objects with religious meaning. Hopi carvers alter these, removing their religious meaning, to meet the demand for decorative commercial objects sought by non-Hopi.


title: Kachina

text: The most important Hopi kachinas are known as "wuya". In Hopi, the term "wuya" often refers to the spiritual beings themselves (said to be connected with the Fifth World, Taalawsohu), the dolls, or the people who dress as kachinas for ceremonial dances. These are all understood to embody all aspects of the same belief system. Some of the wuyas include:


title: Kachina

text: Religious ceremonies are central to the Zuni agrarian society. They revolve around the winter and summer solstices, incorporate the importance of weather, especially rain, and ensure successful crops. According to Tanner, "Father Sky and Mother Earth are venerated, as are the welcome kachinas who bring many blessings."


title: Kachina

text: The Zuni believe that the kachinas live in the Lake of the Dead, a mythical lake which is reached through Listening Spring Lake. This is located at the junction of the Zuni River and the Little Colorado River. Although some archaeological investigations have taken place, they have not been able to clarify which tribe, Zuni or Hopi, developed the Kachina Cult first. Both Zuni and Hopi kachinas are different from each other but have certain similarities and features. In addition, both Zuni and Hopi kachinas are highly featured and detailed, while the kachinas of the Rio Grande Pueblos look primitive in feature. The Hopis have built their cult into a more elaborate rite, and seem to have a greater sense of drama and artistry than the Zunis. On the other hand, the latter have developed a more sizable folklore concerning their kachinas.


title: Kachina

text: According to Clara Lee Tanner, "..."kachina" involves three basic concepts: first, a supernatural being; second, the masked dancer (and the Zuni "is" a kachina when he wears the mask), and third the carved, painted, and dressed doll." The list of Zuni kachinas includes:


title: Kachina

text: Many Pueblo Indians, particularly the Hopi and Zuni, have ceremonies in which masked men, called kachinas, play an important role. Masked members of the tribe dress up as kachinas for religious ceremonies that take place many times throughout the year. These ceremonies are social occasions for the village, where friends and relatives are able to come from neighboring towns to see the dance and partake in the feasts that are always prepared. When a Hopi man places a mask upon his head and wears the appropriate costume and body paint, his personal identity is lost and the spirit of the kachina he is supposed to represent takes its place. Besides the male kachinas are many female kachinas called kachin-manas, but women never take the part of male or female kachinas.


title: Kachina

text: The most widely publicised of Hopi kachina rites is the "Snake Dance", an annual event during which the performers danced while handling live snakes.


title: Kachina

text: Clown personages play dual roles. Their prominent role is to amuse the audience during the extended periods of the outdoor celebrations and Kachina Dances where they perform as jesters or circus clowns. Barry Pritzker stated, regarding the role of clowns in Hopi dances,


title: Kachina

text: The clown's more subtle and sacred role is in the Hopis' ritual performances. The sacred functions of the clowns are relatively private, if not held secret by the Hopi, and as a result have received less public exposure. When observing the preparations taking place in a Kiva of a number of "Pai'yakyamu" clowns getting ready for their ceremonial performance, Alexander Stephen was told, "We "Koyala" [Koshari] are the fathers of all Kachina."


title: Kachina

text: The Hopi have four groups of clowns, some of which are sacred. Adding to the difficulty in identifying and classifying these groups, there are a number of kachinas whose actions are identified as clown antics. Barton Wright's "Clowns of the Hopi" identifies, classifies, and illustrates the extensive array of clown personages.


title: Kachina

text: Kachina dolls are small brightly painted wooden "dolls" which are miniature representations of the masked impersonators. These figurines are given to children not as toys, but as objects to be treasured and studied so that the young Hopis may become familiar with the appearance of the kachinas as part of their religious training. During Kachina ceremonies, each child receives their own doll. The dolls are then taken home and hung up on the walls or from the rafters of the house, so that they can be constantly seen by the children. The purpose of this is to help the children learn to know what the different kachinas look like. It is said that the Hopi recognize over 200 kachinas and many more were invented in the last half of the nineteenth century. Among the Hopi, kachina dolls are traditionally carved by the maternal uncles and given to uninitiated girls at the Bean Dance (Spring Bean Planting Ceremony) and Home Dance Ceremony in the summer. These dolls are very difficult to classify not only because the Hopis have a vague idea about their appearance and function, but also because these ideas differ from mesa to mesa and pueblo to pueblo.


title: Kachina

text: There are two different accounts in Hopi beliefs for the origins of kachinas. According to one version, the kachinas were good-natured spirit-beings who came with the Hopis from the underworld. The kachinas wandered with the Hopis over the world until they arrived at Casa Grande, where both the Hopis and the kachinas settled. With their powerful ceremonies, the kachinas were of much help and comfort, for example bringing rain for the crops. However, all of the kachinas were killed when the Hopis were attacked and the kachinas' souls returned to the underworld. Since the sacred paraphernalia of the kachinas were left behind, the Hopis began impersonating the kachinas, wearing their masks and costumes, and imitating their ceremonies in order to bring rain, good crops, and life's happiness.


title: Kachina

text: Another account says that the Hopis came to take the kachinas for granted, losing all respect and reverence for them, so the kachinas returned to the underworld. However, before they left, the kachinas taught some of their ceremonies to a few faithful young men and showed them how to make the masks and costumes. When the other Hopi realized their mistake, they remorsefully turned to the kachinas' human substitutes, and the ceremonies have continued since then.


title: Informatica

text: Informatica is an American software development company founded in 1993. It is headquartered in Redwood City, California. Its core products include Enterprise Cloud Data Management and Data Integration. It was co-founded by Gaurav Dhillon and Diaz Nesamoney. Amit Walia is the company's CEO.


title: Informatica

text: On 29 April 1999, its Initial public offering on the NASDAQ stock exchange listed its shares under the stock symbol INFA.


title: Informatica

text: On 7 April 2015, Permira and Canada Pension Plan Investment Board announced that a company controlled by the Permira funds and CPPIB would acquire Informatica for approximately US$5.3 billion.


title: Informatica

text: On 6 August 2015, the acquisition was completed and Microsoft and Salesforce Ventures invested in the company as part of the deal. The company's stock ceased trading on the NASDAQ under the ticker symbol INFA effective on the same date.


title: Informatica

text: On 27 October 2021, Informatica again became publicly traded with the INFA stock symbol, this time listed on the NYSE, opening at $27.55 per share.


title: Informatica

text: Informatica's product portfolio is focused on data integration: extract, transform, load, information lifecycle management, business-to-business data exchange, cloud computing integration, complex event processing, data masking, data quality, data replication, data virtualization, master data management, ultra messaging, and data governance. These components form a toolset for establishing and maintaining data warehouses. It has over 9,500 customers.


title: SonarQube

text: SonarQube (formerly Sonar) is an open-source platform developed by SonarSource for continuous inspection of code quality to perform automatic reviews with static analysis of code to detect bugs and code smells on 29 programming languages. SonarQube offers reports on duplicated code, coding standards, unit tests, code coverage, code complexity, comments, bugs, and security recommendations.


title: SonarQube

text: SonarQube can record metrics history and provides evolution graphs. SonarQube provides fully automated analysis and integration with Maven, Ant, Gradle, MSBuild and continuous integration tools (Atlassian Bamboo, Jenkins, Hudson, etc.).


title: SonarQube

text: SonarQube includes support for the programming languages Java (including Android), C#, C, C++, JavaScript, TypeScript, Python, Go, Swift, COBOL, Apex, PHP, Kotlin, Ruby, Scala, HTML, CSS, ABAP, Flex, Objective-C, PL/I, PL/SQL, RPG, T-SQL, VB.NET, VB6, and XML. As of December 2021, analyzing C, C++, Obj-C, Swift, ABAP, T-SQL and PL/SQL is only available via a commercial license.


title: SonarQube

text: SonarQube is available for free under the GNU Lesser General Public License. An enterprise version for paid licensing also exists, as well as a data center edition that supports high availability.


title: SonarQube

text: SonarQube integrates with Eclipse, Visual Studio, Visual Studio Code, and IntelliJ IDEA development environments through the SonarLint plug-ins, and also integrates with external tools like LDAP, Active Directory, GitHub, and others. SonarQube is expandable with the use of plug-ins.


title: Laurel Canyon (film)

text: Laurel Canyon is a 2002 American drama film written and directed by Lisa Cholodenko. The film stars Frances McDormand, Christian Bale, Kate Beckinsale, Natascha McElhone, and Alessandro Nivola.


title: Laurel Canyon (film)

text: Sam and Alex are a newly engaged couple who move to Los Angeles to further their careers. Sam is a recently graduated medical student, starting his residency in psychiatry, while Alex is finishing her Ph.D. dissertation on genomics. The relatively straight-laced, upwardly mobile couple plans to stay at the vacant home of Sam's mother, Jane, a free-spirited record producer in the Laurel Canyon section of Los Angeles.


title: Laurel Canyon (film)

text: In a change of plans, however, Jane is still around, recording an album with her British boyfriend, Ian McKnight, and his band.


title: Laurel Canyon (film)

text: Jane and Ian are in the midst of a fiery romance, and both the producer and the band seem more interested in partying than finishing the record. Jane's presence is a source of consternation for Sam, as he and his mother have quite different mindsets and a strained relationship.


title: Laurel Canyon (film)

text: The new lifestyle options presented by her soon-to-be mother-in-law intrigue the normally hardworking Alex, who begins spending more time with the band and less time on her dissertation. Alex's growing fascination with Jane and Ian leads to a scene where the three of them kiss one another while naked in the swimming pool.


title: Laurel Canyon (film)

text: Sam himself feels attracted to an Israeli fellow resident, Sara, who is unapologetically interested in him as well. They share one first kiss while returning from an informal interns' meeting, around the same time Alex has her first tryst with Jane and Ian in the pool. Some time later, while Alex attends Jane and Ian's party held in a crowded hotel suite to celebrate the band's new album release, Sam and Sara meet in a parking lot and, in a conversation filled with sexual tension, they declare their attraction for one another.


title: Laurel Canyon (film)

text: The situation strains Sam and Alex's relationship almost to the point of breaking by the end of the film. After the party has finished and the three of them are left alone in the suite, Ian tries to "finish" (in his words) his encounter with Alex and Jane, but the latter decides against it and the threesome does not take place. Upon returning home after his conversation with Sara, Sam decides to go to the hotel and discovers Jane, Ian, and Alex scantily-clad in the bedroom. In a fit of rage he repeatedly punches Ian, hits his mother with his elbow as she tries to split up the fight, and leaves the hotel, but Alex chases him down the street and professes her love for him.


title: Laurel Canyon (film)

text: The next morning, the situation seems back to normal again. But Sara phones Sam and tells him she can't control her heart, as opposed to what he told her the day before. Sam watches his surroundings, postpones any further conversation, and takes a moment of reflection.


title: Laurel Canyon (film)

text: Cholodenko has said the film was inspired by Joni Mitchell's album, "Ladies of the Canyon". The script was workshopped at Sundance Institute's lab.


title: Laurel Canyon (film)

text: The film focuses in some depth on the challenge of trying to create successful pop music, showing work on two tracks (both actually written, and previously released, by the band Sparklehorse).


title: Laurel Canyon (film)

text: "Laurel Canyon" has a 69% approval rating on Rotten Tomatoes from 112 reviews, with an average rating of 6.4/10. The site's critical consensus reads, "Though the movie itself is flawed, McDormand is fantastic as Jane." On Metacritic, it has a weighted average score of 61 out of 100, based on 36 critics, indicating "generally favorable reviews".


title: Laurel Canyon (film)

text: The relationship between Alex and Jane earned the film a ranking of #133 on Autostraddle's list of the 200 Best Lesbian Films of All Time.


title: History of Easter Island

text: Geologically one of the youngest inhabited territories on Earth, Easter Island, located in the mid-Pacific Ocean, was, for most of its history, one of the most isolated. Its inhabitants, the Rapa Nui, have endured famines, epidemics of disease and cannibalism, civil war, environmental collapse, slave raids, various colonial contacts, and have seen their population crash on more than one occasion. The ensuing cultural legacy has brought the island notoriety out of proportion to the number of its inhabitants.


title: History of Easter Island

text: Early European visitors to Easter Island recorded the local oral traditions about the original settlers. In these traditions, Easter Islanders claimed that a chief Hotu Matu'a arrived on the island in one or two large canoes with his wife and extended family. They are believed to have been Polynesian. There is considerable uncertainty about the accuracy of this legend as well as the date of settlement. Published literature suggests the island was settled around , or at about the time of the arrival of the earliest settlers in Hawaii. Some scientists say that Easter Island was not inhabited until 700–800 CE. This date range is based on glottochronological calculations and on three radiocarbon dates from charcoal that appears to have been produced during forest clearance activities. Moreover, a recent study which included radiocarbon dates from what is thought to be very early material suggests that the island was settled as recently as 1200 CE. This seems to be supported by a 2006 study of the island's deforestation, which may have started around the same time. A large now extinct palm, "Paschalococos disperta," related to the Chilean wine palm "(Jubaea chilensis)", was one of the dominant trees as attested by fossil evidence; this species, whose sole occurrence was Easter Island, became extinct due to deforestation by the early settlers.


title: History of Easter Island

text: The Austronesian Polynesians, who first settled the island, are likely to have arrived from the Marquesas Islands from the west. These settlers brought bananas, taro, sugarcane, and paper mulberry, as well as chickens and Polynesian rats. The island at one time supported a relatively advanced and complex civilization.


title: History of Easter Island

text: It is suggested that the reason settlers sought an isolated island was because of high levels of Ciguatera fish poisoning in their then-current surrounding area.


title: History of Easter Island

text: The Norwegian botanist and explorer Thor Heyerdahl (and many others) has documented that cultural similarities exist between Easter Island and South American Indian cultures. He has suggested that this most likely came from some settlers arriving from the continent. According to local legends, a group of people called "hanau epe" (meaning either "long eared" or "stocky" people) came into conflict with another group called the "hanau momoko" (either "short-eared" or "slim" people). After mutual suspicions erupted in a violent clash, the "hanau epe" were overthrown and nearly exterminated, leaving only one survivor. Various interpretations of this story have been made – that it represents a struggle between natives and incoming migrants; that it recalls inter-clan warfare; or that represents a class conflict.


title: History of Easter Island

text: Traditionally the sweet potato has been cited as evidence of contact between the two cultures: this staple of the pre-contact Polynesian diet is of South American origin. However, recent evidence suggests the sweet potatoes grown by Polynesians diverged from American sweet potatoes long before Polynesia was inhabited, leaving natural long-distance dispersal as the most plausible explanation for the presence of sweet potatoes, but not necessarily excluding the possibility of pre-historic contact. It is hypothesized that Polynesians traveled to South America and back, or South American balsa rafts drifted to Polynesia, possibly unable to make a return trip because of their less developed navigational skills and more fragile boats. Polynesian connections in South America have been claimed to exist among the Mapuches in central and southern Chile. The Polynesian name for the small islet of Sala y Gómez ("Manu Motu Motiro Hiva", "Bird's islet on the way to a far away land") "east" of Easter Island has also been seen as a hint that South America was known before European contacts. Further complicating the situation is that the word "Hiva" ("far away land") was also the name of the islanders' legendary home country. Inexplicable insistence on an eastern origin for the first inhabitants was unanimous among the islanders in all early accounts.


title: History of Easter Island

text: Jacob Roggeveen's expedition of 1722 gives us our first description of the islanders. They were "of all shades of colour, yellow, white and brown" and they distended their ear lobes so greatly with large disks that when they took them out they could "hitch the rim of the lobe over the top of the ear". Roggeveen also noted how some of the islanders were "generally large in stature". Islanders' tallness was also witnessed by the Spanish who visited the island in 1770, measuring heights of 196 and 199 cm. DNA sequence analysis of Easter Island's current inhabitants indicates that the 36 people living on Rapa Nui who survived the devastating internecine wars, slave raids and epidemics of the 19th century and had any offspring, were Polynesian. Furthermore, examination of skeletons offers evidence of only Polynesian origins for Rapa Nui living on the island after 1680.


title: History of Easter Island

text: According to legends recorded by the missionaries in the 1860s, the island originally had a very clear class system, with an "ariki", king, wielding absolute God-like power ever since Hotu Matua had arrived on the island. The most visible element in the culture was production of massive moai that were part of the ancestral worship. With a strictly unified appearance, moai were erected along most of the coastline, indicating a homogeneous culture and centralized governance. In addition to the royal family, the island's habitation consisted of priests, soldiers and commoners.


title: History of Easter Island

text: The "ariki mau", Kai Mako'i 'Iti, along with his grandson Mau Rata, died in the 1860s while serving as an indentured servant in Peru.


title: History of Easter Island

text: For unknown reasons, a coup by military leaders called "matatoa" had brought a new cult based around a previously unexceptional god, Make-make. In the cult of the birdman (Rapa Nui: "tangata manu"), a competition was established in which every year a representative of each clan, chosen by the leaders, would swim across shark-infested waters to Motu Nui, a nearby islet, to search for the season's first egg laid by a "manutara" (sooty tern). The first swimmer to return with an egg and successfully climb back up the cliff to Orongo would be named "Birdman of the year" and secure control over distribution of the island's resources for his clan for the year. The tradition was still in existence at the time of first contact by Europeans but was suppressed by Christian missionaries in the 1860s.


title: History of Easter Island

text: European accounts in 1722 (Dutch) and 1770 (Spanish) reported seeing only standing statues, which were still venerated, but by James Cook's visit in 1774 many were reported toppled. The "huri mo'ai" – the "statue-toppling" – continued into the 1830s. By 1838, the only standing moai were on the slopes of Rano Raraku and Hoa Hakananai'a at Orongo. In about 60 years, islanders had for some reason (possibly civil struggle between tribes) deliberately damaged this part of their ancestors' heritage. In modern times, moai have been restored at Anakena, Ahu Tongariki, Ahu Akivi and Hanga Roa.


title: History of Easter Island

text: The first-recorded European contact with the island took place on 5 April (Easter Sunday) 1722 when Dutch navigator Jacob Roggeveen visited for a week and estimated there were 2,000 to 3,000 inhabitants on the island. This was an estimate, not a census, and archaeologists estimate the population may have been as high as 10,000 to 12,000 a few decades earlier. His party reported "remarkable, tall, stone figures, a good 30 feet in height", the island had rich soil and a good climate and "all the country was under cultivation". Fossil-pollen analysis shows that the main trees on the island had gone 72 years earlier in 1650. The Dutch reported that a fight broke out in which they killed ten or twelve islanders.


title: History of Easter Island

text: The next foreign visitors arrived on 15 November 1770: two Spanish ships, "San Lorenzo" and "Santa Rosalia", sent by the Viceroy of Peru, Manuel de Amat, and commanded by Felipe González de Ahedo. They spent five days on the island, performing a very thorough survey of its coast, and named it "Isla de San Carlos", taking possession on behalf of King Charles III of Spain, and ceremoniously erected three wooden crosses on top of three small hills on Poike.


title: History of Easter Island

text: Four years later, in mid-March 1774, British explorer James Cook visited Easter Island. Cook himself was too sick to walk far, but a small group explored the island. They reported the statues as being neglected with some having fallen down; no sign of the three crosses and his botanist described it as "a poor land". He had a Tahitian interpreter who could partially understand the language. Other than in counting, though, the language was unintelligible. Cook later estimated that there were about 700 people on the island. He saw only three or four canoes, all unseaworthy. Parts of the island were cultivated with banana, sugarcane, and sweet potatoes, while other parts looked like they had once been cultivated but had fallen into disuse. Georg Forster reported in his account that he saw no trees over ten feet tall on the island.


title: History of Easter Island

text: On 10 April 1786 the French explorer Jean François de Galaup La Pérouse visited and made a detailed map of Easter Island. He described the island as one-tenth cultivated and estimated that the population of the island was around two thousand.


title: History of Easter Island

text: A series of devastating events killed almost the entire population of Easter Island. Jared Diamond suggested that Easter Island's society so destroyed their environment that, by around 1600, their society fell into a downward spiral of warfare, cannibalism, and population decline. Such devastating events that contributed to the downfall and collapse of the Easter Island society can be attributed to the rapid deforestation during the time of moai-construction. The Easter Island palm was used by settlers for means of constructing agricultural tools for their society and aiding in the transport of the Island's statues. It is likely the decline of the palm and the rapid deforestation that took place on the island caused societal collapse and population collapse. Those who survived were forced to completely adapt to their changing environment.


title: History of Easter Island

text: In December 1862, Peruvian slave raiders struck Easter Island. Violent abductions continued for several months, eventually capturing or killing around 1500 men and women, about half of the island's population. International protests erupted, escalated by Bishop Florentin-Étienne Jaussen of Tahiti. The slaves were finally freed in autumn 1863, but by then most of them had already died of tuberculosis, smallpox and dysentery. Finally, a dozen islanders managed to return from the horrors of Peru, but brought with them smallpox and started an epidemic, which reduced the island's population to the point where some of the dead were not even buried.


title: History of Easter Island

text: The first Christian missionary, Eugène Eyraud, arrived in January 1864 and spent most of that year on the island; but mass conversion of the Rapa Nui only came after his return in 1866 with Father Hippolyte Roussel. Two other missionaries arrived with Captain Jean-Baptiste Dutrou-Bornier. Eyraud contracted tuberculosis during the 1867 island epidemic, which took a quarter of the island's remaining population of 1,200, with only 930 Rapanui remaining. The dead included the last "ariki mau", the last East Polynesia royal first-born son, the 13-year-old Manu Rangi. Eyraud died of tuberculosis in August 1868, by which time almost the entire Rapa Nui population had become Roman Catholic.


title: History of Easter Island

text: Jean-Baptiste Dutrou-Bornier – who had served as an artillery officer in the Crimean War, but was later arrested in Peru, accused of arms dealing and sentenced to death, to be released after intervention from the French consul – first came to Easter Island in 1866 when he transported two missionaries there, returned in 1867 to recruit laborers for coconut plantations, and then came again to stay in April 1868, burning the yacht he had arrived in. He was to have a long-lasting impact on the island.


title: History of Easter Island

text: Dutrou-Bornier set up residence at Mataveri, aiming to cleanse the island of most of the Rapa Nui and turn the island into a sheep ranch. He married Koreto, a Rapa Nui, and appointed her Queen, tried to persuade France to make the island a protectorate, and recruited a faction of Rapa Nui whom he allowed to abandon their Christianity and revert to their previous faith. With rifles, a cannon, and hut burning supporters, he ran the island for several years.


title: History of Easter Island

text: Dutrou-Bornier bought up all of the island apart from the missionaries' area around Hanga Roa and moved a couple hundred Rapa Nui to Tahiti to work for his backers. In 1871 the missionaries, having fallen out with Dutrou-Bornier, evacuated 275 Rapa Nui to Mangareva and Tahiti, leaving only 230 on the island. Those who remained were mostly older men. Six years later, there were just 111 people living on Easter Island.


title: History of Easter Island

text: In 1876 Dutrou-Bornier was murdered in an argument over a dress, though his kidnapping of pubescent girls may also have motivated his killers.


title: History of Easter Island

text: Neither his first wife back in France, who was heir under French law, nor his second wife on the island, who briefly installed their daughter Caroline as Queen, were to keep much from his estate. But to this day much of the island is a ranch controlled from off-island and for more than a century real power on the island was usually exercised by resident non-Rapa Nui living at Mataveri. An unusual number of shipwrecks had left the island better supplied with wood than for many generations, whilst legal wrangles over Dutrou-Bornier's land deals were to complicate the island's history for decades to come.


title: History of Easter Island

text: Alexander Salmon, Jr., was the brother of the Queen of Tahiti, the son of an English merchant adventurer, and a member of the mercantile dynasty that had bankrolled Dutrou-Bornier. He arrived on the island in 1878 with some fellow Tahitians and returning Rapa Nui and ran the island for a decade. As well as producing wool he encouraged the manufacture of Rapa Nui artworks, a trade that thrives to this day. It was this era of peace and recovery that saw the linguistic change from old Rapa Nui to the Tahitian-influenced modern Rapa Nui language, and some changes to the island's myths and culture to accommodate other Polynesian and Christian influences (notably, "Ure", the old Rapa Nui word for "penis", was dropped from many people's names).


title: History of Easter Island

text: This era saw archaeological and ethnographic studies, one in 1882 by the Germans on the gunboat , and again in 1886 by the American sloop , whose crew excavated Ahu Vinapu with dynamite.


title: History of Easter Island

text: Father Roussel made a number of pastoral visits in the decade, but the only permanent representatives of the church were Rapa Nui catechists including, from 1884, Angata, one of the Rapa Nui who had left with the missionaries in 1871. Despite the lack of a resident priest to celebrate mass regularly, the Rapa Nui had returned to Roman Catholicism, but there remained some tension between temporal and spiritual power as Father Roussel disapproved of Salmon because of his Jewish paternity.


title: History of Easter Island

text: On 8 March 1837, under the command of Teniente de Marina Leoncio Señoret, the ship of the Chilean Navy "Colo Colo" sailed off from Valparaíso bound for Australia. Thus, the "Colo Colo" was the first Chilean ship to visit the Easter Island.


title: History of Easter Island

text: Easter Island was annexed by Chile on 9 September 1888 by Policarpo Toro, by means of the "Treaty of Annexation of the island" (Tratado de Anexión de la isla), that the government of Chile signed with the Rapa Nui people.


title: History of Easter Island

text: Until the 1960s, the surviving Rapa Nui were confined to the settlement of Hanga Roa and the rest of the island was rented to the Williamson-Balfour Company as a sheep, sugar cane and bananas farm until 1953. The island was then managed by the Chilean Navy until 1966 and at that point the rest of the island was reopened.


title: History of Easter Island

text: 1914 was an eventful year for the 250 residents of Easter Island. In March, the Routledge Expedition landed and began a 17-month archaeological and ethnographic survey of the island.


title: History of Easter Island

text: In October, the German East Asia Squadron including the , , and assembled off Hanga Roa before sailing on to Coronel and the Falklands.


title: History of Easter Island

text: In December another German warship, the commerce raider "Prinz Eitel Friedrich", visited and released 48 British and French merchant seamen onto the island, supplying much needed labour for the archaeologists.


title: History of Easter Island

text: Until the 1960s the surviving Rapanui were confined to Hanga Roa. The rest of the island was rented to the Williamson-Balfour Company as a sheep farm until 1953. The island was then managed by the Chilean Navy until 1966, at which point the island was reopened in its entirety. In 1966 the Rapanui were given Chilean citizenship.


title: History of Easter Island

text: Following the 1973 Chilean coup d'état that brought Augusto Pinochet to power, Easter Island was placed under martial law. Tourism slowed down and private property was "restored". During his time in power, Pinochet visited Easter Island on three occasions. The military built a number of new military facilities and a new city hall.


title: History of Easter Island

text: As a result of an agreement in 1985 between Chile and the United States, the runway at Mataveri International Airport was extended by , reaching , and was re-opened in 1987. Pinochet is reported to have refused to attend the opening ceremony in protest against pressures from the United States to address human rights cases.


title: History of Easter Island

text: On 30 July 2007, a constitutional reform gave Easter Island and the Juan Fernández Islands (also known as Robinson Crusoe Island) the status of "special territories" of Chile. Pending the enactment of a special charter, the island continued to be governed as a province of the V Region of Valparaíso.


title: History of Easter Island

text: A total solar eclipse visible from Easter Island occurred for the first time in over 1300 years on 11 July 2010, at 18:15:15.


title: History of Easter Island

text: Species of fish were collected in Easter Island for one month in different habitats including shallow lava pools, depths of 43 meters, and deep waters. Within these habitats, two holotypes and paratypes, "Antennarius randalli" and "Antennarius moai", were discovered. These are considered frog-fish because of their characteristics: "12 dorsal rays, last two or three branched; bony part of first dorsal spine slightly shorter than second dorsal spine; body without bold zebra-like markings; caudal peduncle short, but distinct; last pelvic ray divided; pectoral rays 11 or 12".


title: History of Easter Island

text: Starting in August 2010, members of the indigenous Hitorangi clan occupied the Hangaroa Eco Village and Spa. The occupiers allege that the hotel was bought from the Pinochet government, in violation of a Chilean agreement with the indigenous Rapa Nui, in the 1990s. The occupiers say their ancestors had been cheated into giving up the land. According to a BBC report, on 3 December 2010, at least 25 people were injured when Chilean police using pellet guns attempted to evict from these buildings a group of Rapa Nui who had claimed that the land the buildings stood on had been illegally taken from their ancestors.


title: History of Easter Island

text: In January 2011, the UN's Special Rapporteur on Indigenous People, James Anaya, expressed concern about the treatment of the indigenous Rapa Nui by the Chilean government, urging Chile to "make every effort to conduct a dialogue in good faith with representatives of the Rapa Nui people to solve, as soon as possible the real underlying problems that explain the current situation".


title: History of Easter Island

text: The incident ended in February 2011, when up to 50 armed police broke into the hotel to remove the final five occupiers. They were arrested by the government and no injuries were reported.


title: History of Easter Island

text: Since being given Chilean citizenship in 1966, the Rapa Nui have re-embraced their ancient culture, or what could be reconstructed of it.


title: History of Easter Island

text: Mataveri International Airport is the island's only airport. In the 1980s, its runway was lengthened by the U.S. space program to 3,318 m (10,885 ft) so that it could serve as an emergency landing site for the Space Shuttle. This enabled regular wide body jet services and a consequent increase of tourism on the island, coupled with migration of people from mainland Chile which threatens to alter the Polynesian identity of the island. Land disputes have created political tensions since the 1980s, with part of the native Rapa Nui opposed to private property and in favor of traditional communal property.


title: History of Easter Island

text: On 26 March 2015, local minority group Rapa Nui Parliament took control over large parts of the island, throwing out the CONAF park rangers in a non-violent revolution. Their main goal is to obtain independence from Chile. The situation has not yet been resolved.


title: History of Easter Island

text: In 2011, prehistoric pits—filled with red pigment that dated to between , after the deforestation—were discovered by archaeologists. The pits contained red ochre consisting of the iron oxides hematite and maghemite and were covered with a lid.


title: History of Easter Island

text: ”This indicates, that even though the palm vegetation had disappeared, the prehistoric population of Easter Island continued the pigment production, and on a substantial scale" said archaeobotanist Welmoed Out from Moesgaard Museum.


The 2016 United States presidential election in Minnesota was held on Tuesday, November 8, 2016, as part of the 2016 United States presidential election in which all 50 states plus the District of Columbia participated. Minnesota voters chose electors to represent them in the Electoral College via a popular vote, pitting the Republican Party's nominee, businessman Donald Trump, and running mate Indiana Governor Mike Pence against Democratic Party nominee, former Secretary of State Hillary Clinton, and her running mate Virginia Senator Tim Kaine. Minnesota has ten electoral votes in the Electoral College.


title: 2016 United States presidential election in Minnesota

text: Despite Trump flipping many mid-western/rust belt states, some of them which hadn't voted Republican since the 1980s, Minnesota was still won with a plurality by Clinton and a 1.52% margin, the eleventh consecutive Democratic presidential win in the state, which has not voted for a Republican since Richard Nixon in 1972. However, this was the closest presidential election in Minnesota since 1984, when Walter Mondale carried the state by a 0.18% margin, and it became the only state that was not carried by Ronald Reagan that year. The state also voted more Republican than the national average for the first time since 1952, with Trump flipping nineteen counties to Republican. Minnesota had the highest voter turnout in the nation, with approximately 75 percent of the state's eligible voters participating in the general election. Through her narrow victory, Clinton won all ten of Minnesota's electoral votes; one elector, Muhammud Abdurrahan, tried to vote for Senator Bernie Sanders of Vermont but was replaced with an elector that voted for Clinton.


text: Bernie Sanders received the most votes and the most delegates in the precinct caucuses. The 2016 turnout was slightly lower than the 2008 tally of 214,066, when Obama won with 142,109 votes, to Clinton's 68,994. Bernie Sanders won every congressional district in Minnesota.


text: The 38 delegates from Minnesota were allocated in this way. If a candidate received more than 85% of the vote, they would get all of 38 delegates. Otherwise, 24 delegates would be allocated proportionally based on the votes per congressional district (3 votes per district). On top of that, there were 10 at-large delegates and 3 party leaders (the National Committee Man, the National Committee woman, and the chairman of the Minnesota Republican Party). All of the at-large delegates were allocated proportionally based on the popular vote with a mandatory threshold of 10% to receive any delegates; if no one got at least 10%, all candidates would be eligible to get delegates.


text: Some media outlets recorded the votes by congressional district, rather than by county. Rubio won districts 1, 2, 3, 4 and 5 in the Minneapolis-Saint Paul area as well as the southern part of the state. Cruz won districts 6, 7 and 8 in the St. Cloud area and rural north.


text: The Green Party of Minnesota held caucuses on March 1 in Saint Paul, Minneapolis, Bemidji, White Bear Lake, Blaine, Grand Rapids, and Willmar. Jill Stein won the caucuses with 84.3% of the vote. The delegates apportioned to each candidate will be decided at the state convention in St. Cloud, Minnesota in June. The results of the caucuses are as follows:


text: The Minnesota caucus was run on March 1, 2016, using ranked choice voting. Gary Johnson took over 75% of the 226 first-preference votes cast, with John McAfee a distant second on 11.5% and Austin Petersen third on 7.5%.


text: Clinton won almost every pre-election poll in Minnesota by margins ranging from 5 to 11 points. Trump won one poll in November 2015, 45% to 42%, and one poll in September 2016 showed a tie. The average of the last two polls had Clinton up 50% to 41%. The last poll had Clinton up 53% to 42%.


text: Trump won 5 of 8 congressional districts, including three held by Democrats, while Clinton won one held by Republicans.


text: Minnesota voted 6.2 percent less Democratic from the 2012 presidential election, a much larger shift than the nation at large. Donald Trump only increased his vote tally compared to Mitt Romney in 2012 by 2,726 votes which resulted in a percentage of vote loss of 0.04%. The difference in Democratic voting was largely attributed to Independent or Write-In candidates. The most significant Independent gains went to Gary Johnson with 3.84 percent of the vote (+2.64% over 2012), Evan McMullin with 1.8 percent of the vote (he was not a candidate in 2012), and Jill Stein with 1.26 percent of the vote (+0.82% over 2012). These three candidates account for 5.26 percent of the swing. This election marked the first time since 1952 that the Democratic candidate performed worse in Minnesota than in the nation at large. Hillary Clinton won the national popular vote by 2.1 points but won Minnesota by just 1.5 points, or 44,765 votes. Minnesota has been a primarily Democratic state in national elections since 1932.


text: Due to Independent and Write-In gains throughout the state, Clinton was dependent on her wins in Hennepin (Minneapolis) and Ramsey (St. Paul) counties, the two most populous counties in the state, and the Arrowhead Region in the northeastern corner of the state. Trump's votes came from less populated, rural counties. Two counties, Morrison and Todd, gave Trump over 70% of the vote, making this the first election since 1968 where either major party candidate won a county with over 70%, with Trump also being the first Republican since Dwight D. Eisenhower to do so since 1956.


text: Trump was also the first Republican to receive a majority of votes in Itasca County since Herbert Hoover in 1928, the first to win Swift County since Dwight D. Eisenhower in 1952, and the first to win Mower County since Richard Nixon against John F. Kennedy in 1960. Due to the close margin of victory in the state, Republicans had targeted Minnesota as a potential swing state target for the 2020 United States presidential election.


title: Bill Turnbull

text: William Robert Jolyon Turnbull (25 January 1956 – 31 August 2022) was an English television and radio presenter and journalist, whose broadcasting career spanned over four decades. He began his career working for radio stations including Radio Clyde and BBC Radio 4's "Today". He presented BBC News 24 and BBC Radio 5 Live before taking on his most notable role as one of the main presenters of "BBC Breakfast", a position he held for fifteen years between 2001 and 2016. Later in his career, he presented the religious series "Songs of Praise" and game show "Think Tank", as well as being a presenter on the radio station Classic FM.


title: Bill Turnbull

text: Turnbull was born in Guildford, Surrey, on 25 January 1956, to an English father of Scottish ancestry and an English mother. He was educated at Eton College and the University of Edinburgh, where he edited the student newspaper. He graduated from Cardiff University in 1978.


title: Bill Turnbull

text: Turnbull's career began at Scottish local station Radio Clyde in 1978; he later freelanced for a number of years in the US. Turnbull joined the BBC as a reporter for the "Today" programme in 1986 and "Breakfast Time" as a reporter in 1988, before becoming a correspondent for BBC News in 1990. He covered a wide range of domestic and international stories, reporting from more than 30 countries, including a four-year stint as Washington Correspondent, based in the US. His producer for a while was Sian Williams. In this role, he reported on a number of major American stories, including the O. J. Simpson murder trial and the Monica Lewinsky scandal that rocked Bill Clinton's presidency. In 1997, Turnbull moved back to the UK and became one of the main presenters on BBC News 24, appearing alongside Valerie Sanderson. He also presented regular programmes on Radio 5 Live, including a stint as a presenter on "Weekend Breakfast".


title: Bill Turnbull

text: Turnbull joined the "BBC Breakfast" team in 2001 as a weekend presenter, presenting with Sian Williams initially and then later with Sarah Montague, Mishal Husain and Susanna Reid. He also regularly appeared as a relief presenter on the weekday programme, with Sophie Raworth, Natasha Kaplinsky, Kate Silverton and Louise Minchin. He became the main weekday presenter of "Breakfast" in 2008, rejoining Williams and replacing Dermot Murnaghan. Turnbull was also an occasional relief presenter of "News at Six" and "News at One".


title: Bill Turnbull

text: As well as anchoring programmes in the studio, Turnbull regularly presented on location. In the aftermath of Hurricane Katrina, he was sent to New Orleans to report for BBC News, presenting both "Breakfast" and the "News at Six" live from Biloxi and Gulfport, Mississippi. In the aftermath of the 7 July 2005 London bombings, Turnbull anchored "Breakfast"s coverage live from King's Cross railway station. He fronted the programme's coverage of the 2008 US presidential election live from Washington, D.C. and New York, and was in Washington once again for the 2012 US presidential election. In 2005, he was a contestant in the third series of "Strictly Come Dancing", partnered with Karen Hardy. In spite of a serious ankle injury in the second week (which then flared up at various points in the series), he stayed in the competition for seven weeks, finishing sixth out of twelve contestants.


title: Bill Turnbull

text: In April and May 2010, Turnbull travelled around the UK presenting and reporting for "Breakfast" on the general election campaign trail. In June 2010 he presented "Breakfast" live from Whitehaven in the aftermath of the Cumbria shootings. He joined the presenting team of the BBC's "Songs of Praise" in 2013.


title: Bill Turnbull

text: In 2015, he began narrating the CBBC sketch comedy series "Class Dismissed", also appearing in a cameo as himself in episode 12. It was announced on 2 September 2015 that Turnbull would be leaving "Breakfast" early the following year, after fifteen years. He presented his last episode, with Louise Minchin, on 26 February 2016.


title: Bill Turnbull

text: In March 2016, he began presenting the daytime BBC One quiz show "Think Tank". Beginning in April 2016, he presented his own radio show on Classic FM. The show aired from 10:00am until 1:00pm on Saturday and Sunday. In July 2016, Turnbull narrated another CBBC mockumentary comedy series based on Paignton Zoo called "The Zoo", broadcast on CBBC in 2017.


title: Bill Turnbull

text: Turnbull was guest presenter of three episodes of "The One Show" during 2016, alongside Alex Jones. In March 2018, just as his cancer diagnosis was made public, BBC One aired 10 episodes of "Holding Back the Years", featuring Turnbull with Fiona Phillips offering information on living well in later life.


title: Bill Turnbull

text: In August 2006, Turnbull agreed to take part in a polyphasic sleep experiment presented on BBC One's "The One Show". In this experiment, he slept for a total of three hours per day, in six 30-minute bursts, for ten consecutive days. The effect of this sleep pattern on his health was visible, as he presented "Breakfast" almost every weekday during the duration of the exercise and became increasingly sleep-deprived. In November 2006, he appeared alongside fellow BBC News presenters in a performance for Children in Need that Jan Moir, writing for "The Telegraph", described as "charisma-free", adding that although Turnbull dressed up like James Bond, he looked like a "dodgy sommelier".


title: Bill Turnbull

text: Turnbull also appeared in an episode of the game show "School's Out" broadcast on BBC One on 11 August 2007. In September 2007, he appeared on the celebrity version of "Who Wants to Be a Millionaire?" with his "BBC Breakfast" co-presenter Sian Williams to raise money for Marie Curie Cancer Care. On 28 October 2007, Turnbull made a guest appearance on the children's television show "SMart". In January 2008, he appeared on "Celebrity Mastermind". His specialist subject was beekeeping.


title: Bill Turnbull

text: In 2009, he took part in the BBC series "Around the World in 80 Days" with "Breakfast" colleague Louise Minchin for Children in Need, travelling from Mongolia, through Russia and South Korea, before crossing the Pacific on a container ship and landing in California. In 2011, he also made an appearance on the BBC One game show "Pointless Celebrities" alongside Sian Williams, which they won. He also appeared alongside Lee Mack and Louie Spence on "Would I Lie To You?" and made a guest appearance as himself in "The Wedding of River Song", the sixth series finale of "Doctor Who", with his then "Breakfast" co-presenter Sian Williams. In 2012, he appeared in Professor Green's music video for "Remedy". In 2013, he appeared in an episode of "Room 101" and in 2016, he was a contestant in a celebrity episode of "The Chase".


title: Bill Turnbull

text: On 24, 25, and 26 February 2020, Turnbull presented "Good Morning Britain" with Susanna Reid. He later returned to the programme in May 2021. In October 2021, he was a contestant on "Richard Osman's House of Games".


title: Bill Turnbull

text: Turnbull married Sarah McCombie in March 1988 in the London Borough of Hackney. The marriage produced three children, Henry (born October 1988), Will (born October 1989) and Flora (born August 1991). Turnbull and his wife previously lived in Buckinghamshire but relocated to Rainow, Cheshire, in 2012, following the move of "BBC Breakfast" to Salford. Subsequently, he moved to Theberton, Suffolk.


title: Bill Turnbull

text: Turnbull was a fan of Wycombe Wanderers F.C., for which he commentated on home games for online listeners. His hobbies included beekeeping, chickens and dancing. In addition, Turnbull enjoyed long-distance running, having competed in the London Marathon on a number of occasions, and the Great North Run on 5 October 2008. On 8 September 2009, Turnbull was awarded an honorary doctorate from Buckinghamshire New University in recognition of his charity work within the Buckinghamshire community.


title: Bill Turnbull

text: In May 2010, he published "The Bad Beekeepers Club", a comedy book about the ups and downs of beekeeping.


title: Bill Turnbull

text: In March 2018, Turnbull revealed he had been diagnosed the previous November with prostate cancer. He died at his home in Suffolk, on 31 August 2022, at the age of 66. Following his death, the commentary gantry at Wycombe Wanderers' Adams Park was renamed after Turnbull in his honour.


title: Soundtracks of Grand Theft Auto: San Andreas

text: "" is an open-world, action-adventure video game developed by Rockstar North and published by Rockstar Games. First released on 16 October 2004 for the PlayStation 2, "San Andreas" has an in-game radio that can tune in to eleven stations playing more than 150 tracks of licensed music, as well as a talk radio station. The songs featured on the radio stations originated in or before the early 1990s, the period in which the game is set.


text: The game's music has been released on two official soundtracks: "Grand Theft Auto: San Andreas Official Soundtrack", released in November 2004, consists of selections from the in-game radio; and "Grand Theft Auto: San Andreas Official Soundtrack Box Set", released in December 2004, consists of eight volumes comprising highlights from the game's radio stations. Critical reception to the soundtracks was positive, as reviewers felt that the selected tracks connected appropriately with the gameplay and period.


text: "Grand Theft Auto: San Andreas Official Soundtrack" features selected tracks from the in-game radio stations. It was released as a three-disc album on November 23, 2004, by Interscope Records. The first two discs featured the songs, while the third disc is a DVD featuring "The Introduction", a short machinima video depicting events before the game.


text: "Grand Theft Auto: San Andreas Official Soundtrack Box Set" comprises highlights from the game's radio stations. The soundtrack was released on December 7, 2004, across eight discs.


title: Oscar Micheaux

text: Oscar Devereaux Micheaux (; January 2, 1884 – March 25, 1951) was an author, film director and independent producer of more than 44 films. Although the short-lived Lincoln Motion Picture Company was the first movie company owned and controlled by black filmmakers, Micheaux is regarded as the first major African-American feature filmmaker, a prominent producer of race films, and has been described as "the most successful African-American filmmaker of the first half of the 20th century". He produced both silent films and sound films.


title: Oscar Micheaux

text: Micheaux was born on a farm in Metropolis, Illinois, on January 2, 1884. He was the fifth child born to Calvin S. and Belle Michaux, who had a total of 13 children. In his later years, Micheaux added an "e" to his last name. His father was born a slave in Kentucky. Because of his surname, his father's family appears to have been enslaved by French-descended settlers. French Huguenot refugees had settled in Virginia in 1700; their descendants took slaves west when they migrated into Kentucky after the American Revolutionary War.


title: Oscar Micheaux

text: In his later years, Micheaux wrote about the social oppression he experienced as a young boy. His parents moved to the city so that the children could receive a better education. Micheaux attended a well-established school for several years before the family eventually ran into money troubles and were forced to return to the farm. The discontented Micheaux became rebellious and his struggles caused problems within his family. His father was not happy with him and sent him away to do marketing in the city. Micheaux found pleasure in this job because he was able to speak to many new people and learned social skills that he would later reflect in his films.


title: Oscar Micheaux

text: When Micheaux was 17 years old, he moved to Chicago to live with his older brother, then working as a waiter. Micheaux became dissatisfied with what he viewed as his brother's way of living "the good life". He rented his own place and found work in the stockyards, which he found difficult. He moved from the stockyards to the steel mills, holding down many different jobs.


title: Oscar Micheaux

text: After being "swindled out of two dollars" by an employment agency, Micheaux decided to become his own boss. His first business was a shoeshine stand, which he set up at a wealthy African American barbershop, away from Chicago competition. He learned the basic strategies of business and started to save money. He became a Pullman porter on the major railroads, at that time considered prestigious employment for African Americans because it was relatively stable, well paid, and secure, and it enabled travel and interaction with new people. This job was an informal education for Micheaux. He profited financially, and also gained contacts and knowledge about the world through traveling as well as a greater understanding for business. When he left the position, he had seen much of the United States, had a couple of thousand dollars saved in his bank account, and had made a number of connections with wealthy white people who helped his future endeavors.


title: Oscar Micheaux

text: Micheaux moved to Gregory County, South Dakota, where he bought land and worked as a homesteader. This experience inspired his first novels and films. His neighbors on the frontier were predominately blue collar whites. "Some recall that [Micheaux] rarely sat at a table with his blue collar white neighbors." Micheaux's years as a homesteader allowed him to learn more about human relations and farming. While farming, Micheaux wrote articles and submitted them to the press. "The Chicago Defender" published one of his earliest articles. His homestead failed and he was forced to sell it in 1911. The next year, he began his publishing career when Woodruff Press of Lincoln, Nebraska published "The Conquest". He began work on a second book, "The Forged Note", and from 1914 to 1918 traveled among Lincoln, Gregory County, and Sioux City, Iowa marketing his work. While in Sioux City, he lived in and was influenced by the West 7th Street neighborhood where the town's African-American community had a strong presence.


title: Oscar Micheaux

text: In South Dakota, Micheaux married Orlean McCracken. Her family proved to be complex and burdensome for Micheaux. Unhappy with their living arrangements, Orlean felt that Micheaux did not pay enough attention to her. She gave birth while he was away on business, and was reported to have emptied their bank accounts and fled. Orlean's father sold Micheaux's property and took the money from the sale. After his return, Micheaux tried unsuccessfully to get Orlean and his property back. He married Alice Russell in 1926. Oscar and Alice remained married until his death.


title: Oscar Micheaux

text: Micheaux decided to concentrate on writing and, eventually, filmmaking, a new industry. He wrote seven novels. In 1913, 1,000 copies of his first book, "The Conquest: The Story of a Negro Pioneer", were printed. He published the book anonymously, for unknown reasons. He based it on his experiences as a homesteader and the failure of his first marriage and it was largely autobiographical. Although character names have been changed, the protagonist is named Oscar Devereaux. His theme was about African Americans realizing their potential and succeeding in areas where they had not felt they could. The book outlines the difference between city lifestyles of Negroes and the life he decided to lead as a lone Negro out on the far West as a pioneer. He discusses the culture of doers who want to accomplish and those who see themselves as victims of injustice and hopelessness and who do not want to try to succeed, but instead like to pretend to be successful while living the city lifestyle in poverty. He had become frustrated with getting some members of his race to populate the frontier and make something of themselves, with real work and property investment. He wrote over 100 letters to fellow Negroes in the East beckoning them to come West, but only his older brother eventually took his advice. One of Micheaux's fundamental beliefs was that hard work and enterprise would make any person rise to respect and prominence no matter his or her race.


title: Oscar Micheaux

text: In 1918, his novel "The Homesteader", dedicated to Booker T. Washington, attracted the attention of George Johnson, the manager of the Lincoln Motion Picture Company in Los Angeles. After Johnson offered to make "The Homesteader" into a new feature film, negotiations and paperwork became inharmonious. Micheaux wanted to be directly involved in the adaptation of his book as a movie, but Johnson resisted and never produced the film.


title: Oscar Micheaux

text: Instead, Micheaux founded the Micheaux Film & Book Company of Sioux City; its first project was the production of "The Homesteader" as a feature film. Micheaux had a major career as a film producer and director: He produced over 40 films, which drew audiences throughout the U.S. as well as internationally. Micheaux contacted wealthy academic connections from his earlier career as a porter, and sold stock for his company at $75 to $100 a share. Micheaux hired actors and actresses and decided to have the premiere in Chicago. The film and Micheaux received high praise from film critics. One article credited Micheaux with "a historic breakthrough, a creditable, dignified achievement". Some members of the Chicago clergy criticized the film as libelous. "The Homesteader" became known as Micheaux's breakout film; it helped him become widely known as a writer and a filmmaker.


title: Oscar Micheaux

text: In addition to writing and directing his own films, Micheaux also adapted the works of different writers for his silent pictures. Many of his films were open, blunt and thought-provoking regarding certain racial issues of that time. He once commented: "It is only by presenting those portions of the race portrayed in my pictures, in the light and background of their true state, that we can raise our people to greater heights." Financial hardships during the Great Depression eventually made it impossible for Micheaux to keep producing films, and he returned to writing.


title: Oscar Micheaux

text: Micheaux's first novel "The Conquest" was adapted to film and re-titled "The Homesteader". This film, which met with critical and commercial success, was released in 1919. It revolves around a man named Jean Baptiste, called the Homesteader, who falls in love with many white women but resists marrying one out of his loyalty to his race. Baptiste sacrifices love to be a key symbol for his fellow African Americans. He looks for love among his own people and marries an African-American woman. Relations between them deteriorate. Eventually, Baptiste is not allowed to see his wife. She kills her father for keeping them apart and commits suicide. Baptiste is accused of the crime, but is ultimately cleared. An old love helps him through his troubles. After he learns that she is a mulatto and thus part African, they marry. This film deals extensively with race relationships.


title: Oscar Micheaux

text: Micheaux's second silent film was "Within Our Gates", produced in 1920. Although sometimes considered his response to the film "The Birth of a Nation", Micheaux said that he created it independently as a response to the widespread social instability following World War I. "Within Our Gates" revolved around the main character, Sylvia Landry, a mixed-race school teacher played by actress Evelyn Preer. In a flashback, Sylvia is shown growing up as the adopted daughter of a sharecropper. When her father confronts their white landlord over money, a fight ensues. The landlord is shot by another white man, but Sylvia's adoptive father is accused and lynched with her adoptive mother.


title: Oscar Micheaux

text: Sylvia is almost raped by the landowner's brother but discovers that he is her biological father. Micheaux always depicts African Americans as being serious and reaching for higher education. Before the flashback scene, we see that Sylvia travels to Boston, seeking funding for her school, which serves black children. They are underserved by the segregated society. On her journey, she is hit by the car of a rich white woman. Learning about Landry's cause, the woman decides to give her school $50,000.


title: Oscar Micheaux

text: In the film, Micheaux depicts educated and professional people in black society as light-skinned, representing the elite status of some of the mixed-race people who comprised the majority of African Americans free before the Civil War. Poor people are represented as dark-skinned and with more undiluted African ancestry. Mixed-race people also feature as some of the villains. The film is set within the Jim Crow era. It contrasted the experiences for African Americans who stayed in rural areas and others who had migrated to cities and become urbanized. Micheaux explored the suffering of African Americans in the present day, without explaining how the situation arose in history. Some feared that this film would cause even more unrest within society, and others believed it would open the public's eyes to the unjust treatment of blacks by whites. Protests against the film continued until the day it was released. Because of its controversial status, the film was banned from some theaters.


title: Oscar Micheaux

text: Micheaux adapted two works by Charles W. Chesnutt, which he released under their original titles: "The Conjure Woman" (1926) and "The House Behind the Cedars" (1927). The latter, which dealt with issues of mixed race and passing, created so much controversy when reviewed by the Film Board of Virginia that he was forced to make cuts to have it shown. He remade this story as a sound film in 1932, releasing it with the title "Veiled Aristocrats". The silent version of the film is believed to have been lost.


title: Oscar Micheaux

text: Micheaux's films were made during a time of great change in the African-American community. His films featured contemporary black life. He dealt with racial relationships between blacks and whites, and the challenges for blacks when trying to achieve success in the larger society. His films were used to oppose and discuss the racial injustice that African Americans received. Topics such as lynching, job discrimination, rape, mob violence, and economic exploitation were depicted in his films. These films also reflect his ideologies and autobiographical experiences.


title: Oscar Micheaux

text: Micheaux sought to create films that would counter negative portrayals of African Americans in films by white producers, which trafficked in degrading stereotypes. He created complex characters of different classes. His films questioned the value system of both African-American and Euro-American societies, which stirred controversy with the press and state censors.


title: Oscar Micheaux

text: Critic Barbara Lupack described Micheaux as pursuing moderation with his films and creating a "middle-class cinema". His works were designed to appeal to both middle- and lower-class audiences.


title: Oscar Micheaux

text: My results ... might have been narrow at times, due perhaps to certain limited situations, which I endeavored to portray, but in those limited situations, the truth was the predominant characteristic. It is only by presenting those portions of the race portrayed in my pictures, in the light and background of their true state, that we can raise our people to greater heights. I am too imbued with the spirit of Booker T. Washington to engraft false virtues upon ourselves, to make ourselves that which we are not.


title: Oscar Micheaux

text: Micheaux died on March 25, 1951, in Charlotte, North Carolina, of heart failure. He is buried in Great Bend Cemetery in Great Bend, Kansas, the home of his youth. His gravestone reads: "A man ahead of his time".


title: Oscar Micheaux

text: In 2014, Block Starz Music Television released "The Czar of Black Hollywood", a documentary film chronicling the early life and career of Oscar Micheaux using Library of Congress archived footage, photos, illustrations and vintage music. The film was announced by American radio host Tom Joyner on his nationally syndicated program, "The Tom Joyner Morning Show", as part of a "Little Known Black History Fact" on Micheaux. In an interview with "The Washington Times", filmmaker Bayer Mack said he read the 2007 biography "Oscar Micheaux: The Great and Only" by Patrick McGilligan and was inspired to produce "The Czar of Black Hollywood" because Micheaux's life mirrored his own. Mack told "The Huffington Post" he was shocked that, in spite of Micheaux's historical significance, there was "virtually nothing out there about [his] life". The film's executive producer, Frances Presley Rice, told the "Sun Sentinel" that Micheaux was the first "indie movie producer." In 2018, Mack was interviewed by the news site "Mic" for its "Black Monuments Project", which named Oscar Micheaux as one of its 50 African-Americans deserving of a statue. He said Micheaux embodied "the best of what we all are as Americans" and that the filmmaker was "an inspiration."


title: Oscar Micheaux

text: A historical marker in Roanoke, Virginia commemorates his time living and working in the city as a film producer.


title: Damages

text: At common law, damages are a remedy in the form of a monetary award to be paid to a claimant as compensation for loss or injury. To warrant the award, the claimant must show that a breach of duty has caused foreseeable loss. To be recognised at law, the loss must involve damage to property, or mental or physical injury; pure economic loss is rarely recognised for the award of damages.


title: Damages

text: Compensatory damages are further categorized into special damages, which are economic losses such as loss of earnings, property damage and medical expenses, and general damages, which are non-economic damages such as pain and suffering and emotional distress. Rather than being compensatory, at common law damages may instead be nominal, contemptuous or exemplary.


title: Damages

text: Among the Saxons, a monetary value called a "weregild" was assigned to every human being and every piece of property in the Salic Code. If property was stolen or someone was injured or killed, the guilty person had to pay the weregild as restitution to the victim's family or to the owner of the property.


title: Damages

text: Recovery of damages by a plaintiff in lawsuit is subject to the legal principle that damages must be proximately caused by the wrongful conduct of the defendant. This is known as the principle of proximate cause. This principle governs the recovery of all compensatory damages, whether the underlying claim is based on contract, tort, or both. Damages are likely to be limited to those reasonably foreseeable by the defendant. If a defendant could not reasonably have foreseen that someone might be hurt by their actions, there may be no liability.


title: Damages

text: This rule does not usually apply to intentional torts (for example, tort of deceit), and also has stunted applicability to the quantum in negligence where the maxim 'Intended consequences are never too remote' applies: 'never' is inaccurate here but resorts to unforeseeable direct and natural consequences of an act.


title: Damages

text: It may be useful for the lawyers, the plaintiff and/or the defendant to employ forensic accountants or someone trained in the relevant field of economics to give evidence on the value of the loss. In this case, they may be called upon to give opinion evidence as an expert witness.


title: Damages

text: Compensatory damages are paid to compensate the claimant for loss, injury, or harm suffered by the claimant as a result of another's breach of duty that caused the loss. For example, compensatory damages may be awarded as the result of a negligence claim under tort law. Expectation damages are used in contract law to put an injured party in the position it would have occupied but for the breach. Compensatory damages can be classified as special damages and general damages.


title: Damages

text: Liability for payment of an award of damages is established when the claimant proves, on the balance of probabilities, that a defendant's wrongful act caused a tangible, harm, loss or injury to the plaintiff. Once that threshold is met, the plaintiff is entitled to some amount of recovery for that loss or injury. No recovery is not an option. The court must then assess the amount of compensation attributable to the harmful acts of the defendant. The amount of damages a plaintiff would recover is usually measured on a "loss of bargain" basis, also known as expectation loss, or "economic loss". This concept reflects the difference between "the value of what has been received and its value as represented".


title: Damages

text: Damages are usually assessed at the date of the wrongful act, but in England and Wales, Pelling J has observed that this is not the case if justice requires the assessment of damages to be calculated at some other date. In "Murfin v Ford Campbell", an agreement had been entered into whereby company shares were exchanged for loan notes, which could only be redeemed if certain profit thresholds had been achieved in the relevant accounting years. As the thresholds were not met, the loan notes were not redeemable, but at the date of the advisors' breach of contract this could not be known, only the loan notes' face value could be known. The conclusion was that in this case valuation could not be done until after the profit performance became known. In his judgement Pelling also referred to the case of "Smith New Court Securities Ltd v Scrimgeour Vickers (Asset Management) Ltd", a case where continuing misrepresentation affected the appropriate date for damages to be assessed.


title: Damages

text: "Special damages" compensate the claimant for the quantifiable monetary losses he has suffered. For example, extra costs, repair or replacement of damaged property, lost earnings (both historically and in the future), loss of irreplaceable items, additional domestic costs, and so on. They are seen in both personal and commercial actions.


title: Damages

text: Special damages can include direct losses (such as amounts the claimant had to spend to try to mitigate damages) and consequential or economic losses resulting from lost profits in a business.


title: Damages

text: Damages in tort are awarded generally to place the claimant in the position in which he would have been had the tort not taken place. Damages for breach of contract are generally awarded to place the claimant in the position in which he would have been had the contract not been breached. This can often result in a different measure of damages. In cases where it is possible to frame a claim in either contract or tort, it is necessary to be aware of what gives the best outcome. If the transaction was a "good bargain", contract generally gives a better result for the claimant.


title: Damages

text: As an example, Neal agrees to sell Mary an antique Rolex watch for £100. In fact the watch is a fake and worth only £50. If it had been a genuine antique Rolex, it would have been worth £500. Neal is in breach of contract and could be sued. In contract, Mary is entitled to an item worth £500, but she has only one worth £50. Her damages are £450. Neal also induced Mary to enter into the contract through a misrepresentation (a tort). If Mary sues in tort, she is entitled to damages that put herself back to the same financial position place she would have been in had the misrepresentation not been made. She would clearly not have entered into the contract knowing the watch was fake, and is entitled to her £100 back. Thus her damages in tort are £100. (However, she would have to return the watch, or else her damages would be £50.)


title: Damages

text: If the transaction were a "bad bargain", tort gives a better result for the claimant. If in the above example Mary had overpaid, paying £750 for the watch, her damages in contract would still be £450 (giving her the item she contracted to buy), however in tort damages are £700. This is because damages in tort put her in the position she would have been in had the tort not taken place, and are calculated as her money back (£750) less the value of what she actually got (£50).


title: Damages

text: Incidental losses include the costs needed to remedy problems and put things right. The largest element is likely to be the reinstatement of property damage. Take for example a factory which was burnt down by the negligence of a contractor. The claimant would be entitled to the direct costs required to rebuild the factory and replace the damaged machinery.


title: Damages

text: The claimant may also be entitled to any consequential losses. These may include the lost profits that the claimant could have been expected to make in the period whilst the factory was closed and rebuilt.


title: Damages

text: On a breach of contract by a defendant, a court generally awards the sum that would restore the injured party to the economic position they expected from performance of the promise or promises (known as an "expectation measure" or "benefit-of-the-bargain" measure of damages). This rule, however, has attracted increasing scrutiny from Australian courts and legal commentators. A judge arrives compensatory number by considering both the type of contract, and the loss incurred.


title: Damages

text: When it is either not possible or not desirable to award the victim in that way, a court may award money damages designed to restore the injured party to the economic position they occupied at the time the contract was entered (known as the "reliance measure") or designed to prevent the breaching party from being unjustly enriched ("restitution") (see below).


title: Damages

text: Parties may contract for liquidated damages to be paid upon a breach of the contract by one of the parties. Under common law, a liquidated damages clause will not be enforced if the purpose of the term is solely to punish a breach (in this case it is termed penal damages). The clause will be enforceable if it involves a genuine attempt to quantify a loss in advance and is a good faith estimate of economic loss. Courts have ruled as excessive and invalidated damages which the parties contracted as liquidated, but which the court nonetheless found to be penal. To determine whether a clause is a liquidated damages clause or a penalty clause, it is necessary to consider:


title: Damages

text: ii) Whether there is a single sum stipulated for a number of different breaches, or individual sums for each breach


title: Damages

text: Damages in tort are generally awarded to place the claimant in the position that would have been taken had the tort not taken place. Damages in tort are quantified under two headings: general damages and special damages.


title: Damages

text: In personal injury claims, damages for compensation are quantified by reference to the severity of the injuries sustained (see below general damages for more details). In non-personal injury claims, for instance, a claim for professional negligence against solicitors, the measure of damages will be assessed by the loss suffered by the client due to the negligent act or omission by the solicitor giving rise to the loss. The loss must be reasonably foreseeable and not too remote. Financial losses are usually simple to quantify but in complex cases which involve loss of pension entitlements and future loss projections, the instructing solicitor will usually employ a specialist expert actuary or accountant to assist with the quantification of the loss.


title: Damages

text: "General damages" are monetary compensation for the non-monetary aspects of the specific harm suffered. These damages are sometimes termed 'pain, suffering and loss of amenity'. Examples of this include physical or emotional pain and suffering, loss of companionship, loss of consortium, disfigurement, loss of reputation, impairment of mental or physical capacity, hedonic damages or loss of enjoyment of life, etc. This is not easily quantifiable, and depends on the individual circumstances of the claimant. Judges in the United Kingdom base the award on damages awarded in similar previous cases. In 2012 the Court of Appeal of England and Wales noted that General damages in England and Wales were increased by 10% for all cases where judgements were given after 1 April 2013, following changes to the options available to personal injury claimants wanting to cover the cost of their litigation.


title: Damages

text: General damages are generally awarded only in claims brought by individuals, when they have suffered personal harm. Examples would be personal injury (following the tort of negligence by the defendant), or the tort of defamation.


title: Damages

text: The quantification of personal injury is not an exact science. In English law solicitors treat personal injury claims as "general damages" for pain and suffering and loss of amenity (PSLA). Solicitors quantify personal injury claims by reference to previous awards made by the courts which are "similar" to the case in hand. Judicial College "Guidelines for the Assessment of General Damages in Personal Injury Cases" are adjusted following periodic review of the awards which have been made by the courts since the previous review.


title: Damages

text: The age of the client is important especially when dealing with fatal accident claims or permanent injuries. The younger the injured victim with a permanent injury the longer that person has to live with the PSLA. As a consequence, the greater the compensation payment. In fatal accident claims, generally the younger deceased, the greater the dependency claim by the partner and children.


title: Damages

text: Solicitors will consider "like for like" injuries with the case in hand and similar cases decided by the courts previously. These cases are known as precedents. Generally speaking decisions from the higher courts will bind the lower courts. Therefore, judgments from the House of Lords and the Court of Appeal have greater authority than the lower courts such as the High Court and the County Court. A compensation award can only be right or wrong with reference to that specific judgment. Solicitors must be careful when looking at older cases when quantifying a claim to ensure that the award is brought up to date and to take into account the court of appeal case in Heil v Rankin Generally speaking the greater the injury the greater the damages awarded.


title: Damages

text: This heading is inextricably linked with the other points above. Where two clients are of the same age, experience and suffer the same injury, it does not necessarily mean that they will be affected the same. We are all different. Some people will recover more quickly than others. The courts will assess each claim on its own particular facts and therefore if one claimant recovers more quickly than another, the damages will be reflected accordingly. It is important to note here that "psychological injuries" may also follow from an accident which may increase the quantum of damages.


title: Damages

text: When a personal injury claim is settled either in court or out of court, the most common way the compensation payment is made is by a lump sum award in full and final settlement of the claim. Once accepted there can be no further award for compensation at a later time unless the claim is settled by provisional damages often found in industrial injury claims such as asbestos related injuries.