of Federal Judicial Center Orientation Series for United States Bankruptcy Judges. Discharge and Dischargeability with the Honorable A. Thomas Small Chief Bankruptcy Judge for the Eastern District of North Carolina. Judge Small was appointed to the bankruptcy court in 1982. He received his BA degree from Duke University in 1965 and his JD from Wake Forest University School of Law in 1969. The Eastern District of North Carolina has two authorized bankruptcy judgeships and two primary places of holding court, including Raleigh where Judge Small sits. Welcome to our session on Discharge and Dischargeability. Discharge is the heart of a debtor's fresh start. It's the primary reason that debtors file for bankruptcy relief. It's important and it should come as no surprise that over one-third of all adversary proceedings involve either an objection to discharge under section 727 or complaints to determine dischargeability of debts under section 523 of the bankruptcy code. Today we'll be talking about the bankruptcy basics. We'll talk about the effect of discharge, discharge procedures, practical aspects of bankruptcy, and the substantive aspects of section 727 and section 523. Now the effect of discharge varies of course depending upon the chapter that the debtor is in. A chapter 7 discharge eliminates the debtor's liability for most pre-bankruptcy debts. That discharge however is subject to the exceptions set out in 523 of the bankruptcy code. The chapter 13 discharge is broader and it's more generous to the debtor. Not all of the 523 exceptions are applicable to the chapter 13 discharge. Dets that are not discharged in chapter 13 include alimony and child support. Long-term debts that mature after the completion of the plan where the debtor is curing defaults that occurred prior to bankruptcy. Fines and penalties and judgments arising from drunk driving are also not discharged in a chapter 13 case. In chapter 13 the discharge comes at the end of the case after the debtor has completed all of the plan payments. And what are discharged are those debts that are dealt within the plan. If the debtor proposes to pay 60 cents on the dollar to unsecured creditors the remaining 40 percent is forgiven. In a chapter 11 case the discharge comes upon confirmation before all the plan payments are made. All debts that arise before confirmation are discharged. The 523 exceptions apply to the chapter 11 discharge if the debtor is an individual. If the debtor is a corporation the 523 exceptions do not apply. As a general rule the discharge will not affect the obligations of third-party non-debtors, guarantors, co-makers. Their obligations are not affected by the debtor's discharge. Also the discharge does not affect otherwise valid liens. Of course a trustee can avoid liens under the trustee's avoiding powers, a debtor can avoid liens under section 522f, but that takes an affirmative act. The discharge by itself does not affect otherwise valid liens. Let's talk about discharge procedure. Discharge and dischargeability actions are adversary proceedings and all the formal requirements of adversary proceedings apply. There's got to be a filing fee, a complaint has to be filed. These are core proceedings which the bankruptcy judge may hear and determine. The bankruptcy court has exclusive jurisdiction over complaints filed under section 727 objections to the debtor's discharge. Also the bankruptcy court has exclusive jurisdiction under 523a2, a4, and a6 where complaints objecting to the dischargeability of specific debts. The bankruptcy court however has concurrent jurisdiction with state courts with respect to complaints filed under other sections of 523. That means if you've got an obligation and the issue is whether or not it is an obligation that is alimony or child support, either the bankruptcy court or the state court can make that determination. Well what if you have a dischargeability issue under a2, 4, or 6 where the bankruptcy court has exclusive jurisdiction and a state court has already decided that issue prior to bankruptcy. For example if you have a judgment in a state court action that says that an obligation was incurred as a result of a willful and malicious injury inflicted by the debtor. Well that determination would be binding on the bankruptcy court in an action under 523a6 because it's already been decided by the state court and the bankruptcy court can no longer decide that under the doctrine of collateral estoppel. Most chapter 7 debtors get their discharge, but discharges like stretched ski pants are not for everyone and creditors have an opportunity to file objections to the discharge. In complaints filed under section 727, 523a2, 4, and 6 creditors have 60 days from the first date set for the meeting of creditors to file that objection and that's so because of bankruptcy rule 4004a and bankruptcy rule 4007c. Courts strictly construe these filing bar dates. If the creditor is too late that's just too bad. Even if the creditor has a pretty good excuse and if the creditor has a pretty strong case to have the debtor's discharge denied, if the complaint is filed too late the debtor's discharge will be granted. Bankruptcy rule 4005 provides that the burden of proof where you have a complaint objecting to the debtor's entire discharge under section 727 is on the trustee or creditor that's trying to deny the debtor the discharge. In actions under section 523, the burden is on the creditor who's trying to determine that a specific debt is non-dischargeable. The exception to that rule low is under section 523a8 where the debtor is trying to discharge a student loan on the grounds that repayment would constitute an undue hardship on the debtor or the debtor's family. In that case the burden of proof is on the debtor. The standard of proof in actions under 523 according to a Supreme Court decision in Grogan versus Gardner is preponderance of the evidence and courts have extended that standard and applied that standard in actions under 727 and that is true even though the issue is the debtor's fraudulent intent. Usually under state law fraud has a standard of clear strong and convincing. That is a more stringent standard than the preponderance of evidence that applies in 727 and 523. Now it's not uncommon to find statements in various opinions that say that if the issue is discharge all doubts should be resolved against the creditor and in favor of the debtor. That's because of the fresh start policy. Well don't be misled by those statements because the clear trend at least at the circuit level is that debtors are having a more difficult time getting their discharges granted. You'll find cases that say that these issues should be construed against the creditor but in the same case the debtor's discharge will be denied. Now I'd like to turn to two practical problems you may face when you try discharge and discharge ability proceedings. It's not uncommon in a chapter 7 case for that chapter 7 attorney to try to withdraw from the case when the discharge complaint is filed. Typically the attorney has gotten the fee before the case is filed and that fee does not include adversary proceedings. So when the adversary proceeding is filed the attorney wants out of the case when the debtor can't pay for that representation. Important thing to keep in mind is that the attorney can't just walk away from the case. It's up to the bankruptcy judge to decide whether or not to let the attorney out. Judge Wopner may like trying prose cases but I can assure you that most bankruptcy judges don't so keep in mind that whether or not the attorney leaves the case is within your discretion. Another problem relates to the settlement of these types of proceedings. Typically you'll have a multiple count complaint. You'll have the counts relating to the 727 issues whether or not the whole discharge should be denied and you'll have the counts that relate to the discharge ability of specific debts under 523. Not surprisingly most of these adversary proceedings like all adversary proceedings are settled and the way they're usually settled is with the creditor withdrawing the complaint and the debtor reaffirming all or part of that creditor's debt. Well that's the best of both worlds for that creditor. No other creditor can go against the debtor because of the discharge and only that creditor can pursue the remaining obligation. That may be unfair to the other creditors especially if there are strong grounds for denying the debtor's entire discharge. At a minimum the court has to notify the trustee that the case has been settled along those lines. That's required by bankruptcy rule 7041 and the bankruptcy judge may want to go beyond that and notify all creditors that the settlement has been entered and that the debtor's discharge will be granted. The bankruptcy code used to require debtors to attend discharge hearings before they could receive the discharge and this caused all sorts of problems. It was time-consuming. It created a burden on an overburden clerk's office and it created a burden for the debtors. It made them miss a day to work of work to come to these discharge hearings. Now discharge hearings are optional. It's up to the court and most courts have decided not to hold discharge hearings but I would suggest that there is a valid reason for holding discharge hearings. If you think about it most debtors could go through a bankruptcy proceeding and never come before a bankruptcy judge. I think it's important for debtors to see somebody in a black robe. It indicates to them that they've done something serious and they have the protection of the federal system behind them. In our district our 341 meetings are held in our courthouse so what I do is I assemble all the debtors immediately prior to their 341 meeting and conduct the discharge hearing. I realize that's not practical in many districts but it seems to work for us. Some debtors may want to reaffirm debts that have been discharged. To be enforceable reaffirmation agreements must meet the requirements of section 524c3. The agreements must be signed before the discharge is entered. They must be filed with the court and the debtor has the option of rescinding the reaffirmation agreement 60 days after it's filed with the court. If the debtor is represented by an attorney the attorney has to file an affidavit certifying that the reaffirmation agreement does not result in an undue hardship to the debtor or the debtor's dependence. If the debtor is not represented by an attorney then the bankruptcy court gets into the act. A hearing has to be held. Frequently I'll do it by telephone conference call and at that hearing the bankruptcy judge has to determine not only that it's not an undue burden on the debtor but also that it's in the debtor's best interest to reaffirm that debt. Frequently the reaffirmation agreements involve debts that are secured by the debtor's home, mobile home or automobile and there are some circuits that hold that a chapter 7 debtor must reaffirm the debt before they can keep the car or the mobile home or their home. There are other circuits however like the 4th circuit where I said where the debtor does not have to reaffirm the debt to keep the automobile. As long as the payments are current the creditor is not able to repossess that collateral and if you're in that a district like that or a circuit like that it really doesn't make sense and it's not in the debtor's best interest to reaffirm those obligations. Let's turn now to the substantive aspects of section 727. 727a1 provides that only an individual in chapter 7 can receive a discharge. That's true also in chapter 13 cases but for a different reason of course only individuals can be debtors in chapter 13. In chapter 11 both individuals and corporations get a discharge. Probably the most important subsection of 727 is 727a2. If within one year of bankruptcy the debtor with the intent to hinder, delay and defraud creditors transfers, destroys, mutilates or conceals property the debtor's discharge should be denied. Well what if the debtor transfers all of the debtor's non-exempt assets to exempt assets on the eve of bankruptcy. The courts are divided on this issue. Some courts take the position that the sky's the limit anything goes. Pre-bankruptcy planning is perfectly legitimate. Other courts take the position that if you're too aggressive in your pre-bankruptcy planning then your discharge can be denied and I think bankruptcy judges are pretty much evenly split on that issue. The legislative history to section 522 says that it is not fraudulent per se to transfer non-exempt assets to exempt assets on the eve of bankruptcy but you'll find many cases while citing that legislative history will deny the discharge to the overly aggressive pre-bankruptcy planner under section 727a2. The one-year time limit is important in 727a2. If a transfer is made outside that one-year period the debtor gets the discharge so if a debtor transfers his residence to his mother-in-law waits a year and a day to file the bankruptcy petition is he home free? Maybe not. There's a doctrine called continuing concealment that several circuits have applied and that doctrine provides that it makes no difference when the transfer was made. If there is a continuing concealment then that debtor will lose the discharge under 727a2. Now 727a3 and a5 pretty much go hand in hand. a3 provides that if the debtor conceals destroys or fails to keep records the discharge is denied. a5 provides if the debtor does not satisfactorily explain the loss of assets the debtor's discharge and denied. A good case that discusses a3 and a5 is the in-ray Dolan case. In that case the debtor used what I refer to as the high man defense. Mr. Dolan was a cocaine addict and his defense was your honor. I couldn't keep records because I was too high man. The sick circuit however didn't buy that and Mr. Dolan's discharge was denied. What kind of records does a debtor have to keep? Well of course it depends upon the specific circumstances of the case. If it's a complicated case the debtor's records will have to be more detailed and more complete. Under section 727a4 a debtor's discharge is denied if the debtor gives a false oath, makes a bribe or withholds information. What constitutes a false oath? Well it's got to be materially false given with intent to deceive and it must relate to the debtor's assets. A reckless indifference to the truth has been held to be tantamount to fraudulent intent for purposes of 727a4. The provisions of 727a6 and a10 are pretty self-explanatory so in the interest of time I won't go over those but before we leave 727 I did want to mention the bankruptcy judge's obligation to report crimes under 18 USC 3057a. If a bankruptcy judge has reasonable grounds to believe that a crime has been committed the bankruptcy judge has an obligation to make a report to the U.S. Attorney. The report can be in writing it can be an it can be an oral report. Of course if you've got an obligation to make a report you want to be sure that you document the fact that you've made that report. You've got no obligation to tell the party that you're complaining about that you've made the report and you've got no obligation to give advance notice that you're going to make the report. Trustees have the same obligation that the bankruptcy judge has to report crimes to the U.S. Attorney and there may be situations where it is better for the trustee to make the report than for the bankruptcy judge to make the report. For example if the litigation is still going on if the dischargeability litigation is still going on the judge could be criticized for not being impartial if the judge made a report prior to hearing the case that a criminal act had been committed. Let's turn now to the exceptions to discharge under section 523. 523a1 provides that certain taxes are not discharged current taxes taxes where there's been no return filed or a fraudulent return file. Section 523a2 is probably the most used section of 523. 523a2a says that there is no discharge when a when credit was extended based on false pretenses. Now this comes up frequently with respect to credit card debt. If a debtor knows that the debtor cannot make payments under the credit card yet continues to use the credit card those obligations are non-dischargeable. Also if a debtor purchases luxury goods aggregating more than $1,000 within 60 days of bankruptcy or gets cash advances aggregating more than $1,000 within 60 days of bankruptcy those obligations are not discharged. 523a2b provides that credit extended based on written false financial statements are not discharged. The creditor must prove that the financial statement was materially false that it was given with the intent to deceive and that the creditor reasonably relied on that false statement. Does reasonable reliance also apply to false pretenses under a2a? Well the Supreme Court in field versus man's addressed that issue and said that the creditor if the issue is false pretenses need not show reasonable reliance but must show justifiable reliance. Well what's the difference between reasonable reliance and justifiable reliance? Frankly I have no idea. Under section 523a3 there's no discharge of a debt when the creditor was not listed when the creditor had no knowledge of the case or if the creditor found out about the case too late to file a claim or to file a complaint under section 523a24 or 6. Of course most chapter 7 cases are no asset cases no claims are filed and there's no claim bar date. In that situation the debtor can just amend the schedules add the creditor and the debt is discharged. But what if the case has been closed? Does the debtor have to reopen the case? Does the clerk have to retrieve the file from archives? Well the trend of the cases does not require reopening of the case and the cases say that all the debtor has to do is to notify the creditor and that debt is discharged unless it's 1 under 523a24 or 6. Under section 523a4 debts are rising from larceny or embezzlement or from a breach of fiduciary obligation are not discharged. If the ground for denying discharge is breach of a fiduciary obligation it must be a true fiduciary obligation a true trust created either by contract statute or the conduct of the parties. A mere breach of a constructive trust is not enough to deny the discharge ability of that debt under section 523a4. 523a5 deals with debts in the nature of alimony and support and you'll have a lot of these cases and I think you'll find that they're probably the least pleasant to try. The crucial issue is what was the party's intent when they entered into that divorce settlement? Well the problem is whether or not it was alimony or support or something else a property settlement was probably the furthest thing from these parties minds they were interested in dissolving the marriage and they were interested in the bottom line how much do I get how much do I have to pay. So the court must look at all the circumstances to determine what the party's intent was when they entered into that arrangement. Non-alimony marital obligations are also non-dischargeable under 523a15. The exception though is where the debtor has no ability to make those payments and where the debtor's discharge is more beneficial than the detriment to the spouse or the debtor's dependence. 523a6 provides that debts incurred as a result of willful and malicious acts are not discharge. Most courts hold that specific malice is not required. All the creditor has to show is that there was an intentional act in disregard of the rights of the other party. There have been a number of cases where doctors have been denied or medical malpractice claims have come under 523a6 where the doctor did not have medical malpractice insurance. 523a7 provides that there is no discharge for fines and penalties. 523a8 provides that there's no discharge for student loans where the government has guaranteed the loan or a non-profit institution has guaranteed the loan. The exception is when the loan is more than seven years old or repayment would create an undue hardship for the debtor and the debtor's dependence and again it is the debtor that has the burden of proof if the issue is undue hardship. I've had a number of cases where doctors have tried to discharge their debts that they incurred while they were in medical school. I think almost uniformly the doctors have lost in that situation. It will probably be the same for lawyers unless the lawyer failed the bar exam five times which was the fact pattern in the case of In Ray Bryant. 523a9 provides that obligations arising from drunk driving judgments are not discharged. 523a10 provides that non-dischargeable obligation in prior cases are not subsequently discharged in a later Chapter 7 case. Section 523a11 and a12 say that obligations to federal agencies that regulate financial institutions are not discharged. 523a13 says that restitution awarded in connection with federal crimes is not discharged. 523a14 provides that obligations incurred to pay otherwise non-dischargeable taxes are not discharged and 523a16 provides that post petition condominium assessments are non-dischargeable even though the agreement was entered into prior to bankruptcy. Now once the discharge is entered the automatic state terminates and it's replaced by a permanent discharge injunction. That discharge injunction is the debtor's protection from creditor harassment. Now I know you're thinking right now that you've probably been harassed long enough on the issue of discharge and dischargeability and I agree. So that'll conclude our session. I hope it has been helpful to you and with that you all are discharged.


having cast as Samora, it's not online, it's video, I keep like the video, okay? It's really at the beginning, oh my God, you need to move me to the sound because it's so live. Test test test test test test. Enjoy it. Okay. Good morning, everyone. Can I invite everyone to take their seats? We'll be starting in 30 seconds. And I've been told that there's already an audience online that we've gone live. All right. So good morning once again to this event, integrity and trust in elections in Albania. Time for a breakthrough in political finance transparency. My name is Sam van der Stack. I'm the head of Europe for the International Institute for Democracy and Electrical Assistance. A warm welcome to everyone. Commissioner Celibasi, to begin with. Pleasure to have you here. The representatives of political parties, honourable members of parliament. Mr Iban of the EU delegation, Tuja Braks, dear friend, partner in this project will be hearing from you later. And of course, all friends and partners, media representatives that have decided to be here today. It's a real pleasure to have you here and welcome also to those online and in the room, of course. So the purpose of today's event is to launch this project on integrity and trust in elections in Albania that the rule of law center of Finland and international idea have embarked upon. And a little bit about that project. Basically, we aim to do two things in the next two years. One is to focus on transparency of political finance, even more important with discussions about the collaboration between the EU and Albania and the safe use of ICT in elections, something that Albania has been spearheading already, but will generate a lot of extra interest over the next couple of years. We hope to contribute to that. So this marks the start of international ideas and the rule of law centers presence in Albania, even though we've been involved in supporting elections for years. Coming in and out now, we will have a presence in the country and this is a milestone for us. Now today we'll talk about the topic of political finance, the funding of political parties. Why is that important? Well, political finance is really what is at the heart of trust of citizens in political parties, right? Political parties are traditionally the least trusted political institutions in any country. The Euro barometer has been taking surveys amongst European citizens in EU countries, but also in Albania. For many, many years and we see that out of all institutions, political parties sit at the bottom of how much citizens trust them. It's traditionally 21% of citizens only that trust political parties, right? That compares to the second least trusted institution parliament, which normally has about 36, 35% trust.  And the core of why they distrust political parties is often money related. And it's about how political parties, politicians receive and spend money. So if we want to fix the problem of distrust in society, we have to start at that very core. We have to talk about how we deal with the transparency of funding of political parties. And we aim to do that in three different ways through this project. One is to improve the transparency of political finance reporting, right? To help political parties better report what they receive and how they spend it and do that together with the CEC. Two is to support the users of that information through a database website that allows media civil society to really see how much money is going around and better understand how political parties operate. And lastly, to help discussions on the need for political finance reform, traditional topic that also in Albania has been recommended to invest more in an international idea and the rule of law center being a lot of international experience in this topic that we hope to lend to Albania. Now, let us get started. We're going to listen to a few opening presentations by distinguished speakers. And the first one today is my dear colleague, Secretary General Dr. Kevin Casas, Zamora, who unfortunately is unable to be here with us today due to other obligations but would have loved to be here and will be in future. We'll be listening to a recorded message that he has prepared for us and that will be aired right now. Dear Commissioner Salivashi, Honorable representatives of the Parliament of Albania, dear friends of the rule of law center, dear Tuya, and dear Tirana civil society partners, on behalf of international idea, a whole hearted thank you for gathering today to launch our project on integrity and trust in elections in Albania. We at the Institute are grateful for the fruitful partnership with the rule of law center at the University of Helsinki Finland, a partnership that has made this very project possible. We're also grateful to the Central Elections Commission, Parliament, and our partners in civil society in Albania for the continued openness and commitment to work together. International idea has been supporting Albanian democratic institutions together with our international partners for many years, but this event marks the start of international ideas presence in Albania and I hope the beginning of a long-term engagement. What unites us is the shared vision of solid, effective, and inclusive democracy in Albania and the region. This can only be achieved through higher standards in elections on which we hope to assist. Together with the rule of law center, we look forward to working with our partners in Albania to improve transparency on political finance and promote the safe use of information and communication technologies in elections. I congratulate Albanian institutions and civil society for their engagement and look forward to working together to strengthen the integrity and trust in elections here. On behalf of international idea, thank you and I wish you a fruitful discussion today. Thank you to Kevin, who couldn't be with us here today, Secretary General of International Idea for starting us off on this discussion. We'll now turn to the next presenter, my dear colleague partner Tuja Braks, the Executive Director of the Finnish Rule of Law Center. Tuja, we embarked on this project about a year ago when we first met and now we're here. It's really a pleasure. Ladies and gentlemen, Tuja Braks is not just any person. Tuja has been a Minister of Justice in Finland, a long time member of the Finnish Parliament, but more importantly she has worked on the topic that we're discussing here today in Finland herself for many years. She has sparked political finance regulatory reforms, been at the start of starting oversight bodies and really capacitating them with the things that we're also hoping to achieve in Albania. So no better person than Tuja to start us off in this discussion. Tuja, the floor is yours. Thank you, Sam. And ladies and gentlemen, it's a really honor and happy to be here today in this situation. Albania is really one of the key players when it comes to rule of law and democracy within EU. From our perspective, the whole western Balkan is, it's an inner yard of European Union and really important for the security of the whole region. So I'm really happy to be part of this and I'm particularly happy to work with international idea. Already during my previous working life, international idea was highly regarded in all the partnerships. But now after working together with you, it's been wonderful so far. Thank you for already this part. The way the rule of law center at the University of Helsinki at the Law Faculty works is that we bring in high quality expertise in sort of a standing beside and helping with several approaches. So I have an honor to represent that we have the professor Kim Monuotio. And then your excellency, Mr. Selepat, your counterpart in Finland, Nikols Wilhelmsson, who is in charge of organizing elections in Finland, Lassovi Turpianenis from our team is also here. So the idea is that whenever there is approaches that we believe in, we'll bring the high level expertise in Finland to learn to work together in a very humble way. And just to tell you the sort of short history of Finland and party finance, still in 70s, 80s, when I went to high school, there was money from Soviet Union in campaigning secretly. Some of us knew some of this money from America, private money, trade union money. I mean, at least this we know by now. And within last maybe 20, 25 years, we've gone in terms and we have changed the whole legislation so that there's proper party finance by the parliament and that scrutinized audited very, very well. And then the openness of all the other sources of finance are finally clear. So we know that it doesn't happen like that. But maybe with this sort of a humble experience, we have that how it is possible to change things so that you end up by making also the public and the civil society that is very crucial and media to be able to scrutinize, ask the right questions, get the right information, the openness of the whole thing. We are really honored to be here and as part of this because I think that it is when at the end of the day, it comes to the fact that when in campaigning, you need money, but you have to be able to talk about it. You have to be able to show where it comes, what are the ideas and the background of the money to make it sort of a part of political life that there are no secrets about. So I'm not to be here today. Thank you all. Thank you very much to you, Brux, for setting the scene by mentioning that no country is immune from the problems that come with the funding of political parties. Every country has had to find legal framework and the right oversight. And what better way to transition to the next speaker who has been spearheading some of these reforms, some of these discussions in Albania. Dear Commissioner Celebasin, you've been a great partner in getting us up on our feet, stinking through how we can use our international expertise to the benefit of what is going on in Albania. Thank you for that partnership and we'd like to hear from you as well. We're not reporting the reality in a rusted. Which is a kind of interesting to be making for the contribution of the project. the political the the the the the the the the the the the the the the the the the the the the the the the the the the the the the the the Besoi, as tu sigur se deshumis aioi, se nu kushtamam kshtu. Bazor musse paku, meni percetim taforti ete gior publik, duka ce nu kanjitransfarensta platnimi kusht finanzaon ka sa desi. Dai, nge li atuetia, a ka vant proprimir simet notatronikutsi sistemi? Kachizom en don se pal. Musse parimendoi se vet kodri regulator li gior, kanja voi proplot simet eti ar simet, lide me financijne partive ete fushatave.  Prava ta subjektevet tndrišan je jo politik, jo kandidat, ta cilet nookumari pies direktana fushat zjadore, pora angažoja nemunilose na nje tietrono to. Gitašto, men doem se kardu koja, eskaka luar koja nuntatemi ta, me siguri, se duet upršijan no monitorimi, de financijmi per partit de fushatate ture, ete simet no meda neškroar, reide sociale, de ne prodisi na internet apun o meda terat komunikimit, vec mede ve klasike rade de televizioni. Sot, raportimi partive politike rštvaj se tersiš formal de monitorimi, de veritikimi na kečezõ, ikture raportimi ven gelet vetem vrnda kvadrit formal, desi profajsor, te vetem asaj čar vet partit raportoji. Kečezõ noka sottojse aspak autorizime lidjore, protiško ar mothel nevrtetimin eprmbaites raporti veci paracida na partit politike. Nelidem ekta pujat nišanbu, ni partit politike e cila ka raportuar, nje durin tetsaktuar, ga ani person juridik ose fizik, e prezanton na raportin e vet, por kečezõ noka moncin, pršom to verificoi nase kuji person juridik a po fizik, i ka kapacitetet prtabur tlurin. Nopik pamia formale ajot svar prezanton partia duket na regu, tru e si ka respektuar mass and the limiting financimi, por nuket dim nase kuji ka cian nujendie prtaburg tlurin financimi, por mon te djena tlurin na list, pa si durimi ini subjekti tietar, eš frndar nrisa tietar cilet realist, nukandon ose nukandon aisa eš prezantuar na raport. Kešnišanbu prtat reguar čoftaj da pror kači paks, srpakel, dododok keče zostiepe na autorizime, apandoštele institucioni tietar, nase do tietar rasti, por tlurin verificime, mtatelevara na lidi metu se čar prezantovat na raport, mtko korkojte informacjon, nga zvira taxa de tatime, nga ili deka pakaia, apodanga zvira te tira, tlcili atmen bani rekord na lidi metar do dečme zime apodat persona ve fizikta šteta sve. Gjitha štulmen dojnče dršime na trsi quadrat regulator legionarši fri, dojt pršin jove tam kodin zjadovr, pormas pari de ližin pro partit politike, štulmen doj se partit dojt kem de tira imiče menur periodike, te bane publike, neralta par prantarsin evet, demopass pro gjitha tira, štul dojt kekatu bojeme parat še marin de kujiš menzoni to parat, to pak tam prese timi un, ršče e de brndavet partit politike, kapak transformara in sndromiet partive, instrucionele, administruose to budžete de, te dní partit politike, de antarsis na lidi metar se nga ima i parat, si marin si iš menzoni de do tira. Reče zhčene de turuče dobejau, dutimine njinomit mat partit do politike, to registračne partit do politike, nijukatne reči djusorti rand, ja reti ničin te trije, de nji partit politike, to pak nasipastadana veče, koče zhče zhče desmanom, to registračne partit do registračne partit do politike, prormašom se pes lije prčin to ture, no ka as informacjon lidi me adresat, pretarine partis, abo organin erasti drejtojst, tila tiem to pasura nekto registr. Lidži pro partit politike, dutofroj nji Žida Lidžore Proctoretana, partit do tiem to de turuče, me lidžče nasen dršojne adres, dutini oftoji Žirta, list promisjonu čem dršojto Žide, brona nja fatic aktuor, čofnum njiršto drejt pro drejt navit partija, a po denu promiet džukata soreti djusorti rand. Mos prombuša ekti de turimi, na ana eni partit tic aktuor, dut ta penalizoya to derejte na mos registrimi na Žide. Kače Že, aktuališt, elektriauta imesiguri teplot, arđon šun ko energij de finanza proti djetur adres adrekture partive, de mos šum akoma proti bor formalitetim, emarje se raportede, dutlir simit tekture raportede. Ja arreth teta djet partij, če nu kanmar pies na katr zjede de fondi, natopak na katr zjede de fondi. Kto, bore de šun tutira, nu kan profitori fondi publike, preko dži taštun, nu ka fare džurum d'aktiviteti tekture politiki, pra dukat sektu partii reališt nuk existojni. Ljubler simit ton, liži duet andrišoj, prtavendosur mektarast, prioritete me lidi me kontrolim finanziara to partivega, kače za partit piesmar se nasjede de fondi, a to doma zdašnur išt dueti naštruven, kontrolit de verifikimit finanziara. Nuk uštet kur kapacitetete, kače zas, asjerno u dotiem te tila, če nu nujr kapiljare, to bane mbikšure de kontrolim finanziara te ničin etritete ni partive, liži duet paši kojiče ku institucion, ti fokusoi, resursete vedane, njerzore de finanziara, na partit če mani pies nasjede, me spari, de mande i prtatiara. Prtatiara, mbikšure de kontrolim finanziara i ture, muntubuet na kurste de kriteria te tiera, kašom muntiet ni sistem šorti. Ka ta aspekteta tira te liži pro partit politike, te liži pro partit politike, paštude kodiziador če duet, te rik consideroje. Sita tila, porpau u limituar, i ana toče kanta bane me kohon, kušte, de kriteria te presjese, te auditose, de osa experte kontabel, raportimi na kandidata, si atatum brštetruna partit politike de koalicione, paštude atatum brštetruna zjelsit, loin de masen sankcionere, administrative, apod de penale kurš rastin, prškele de regulace lidem i finansimin. Prostaj, porque kaše zas, nepromulšet to projesive, takti institucioni, nekohadr tam bitjures, kontrol de de transferenzas ni finansine partit politike, nepapunojm, pretopromir suar, nasdo aspekt, nasdo pikpame metodologike, gid procesing tehnik, te ponus je lidet me kontroldim, bitjurene de transferenzan, de financimi de partit politike. Si unvajmo se pare, che te vendosem ni standard, to uniformizuar, ne lidet me paracidene raporte finanziare, koone paracite satura, forno de manura. Popunojm, orta digitalizuar samršum, che tieti em mundur, de ar stušme, de che os katabujem menzitem, che viria, nukei bor, procesit digitalizimit, ke siu procesci fecizek, afeu ar šun ko, neprepara, a nukei mi, non-direktivo neche viris praktu. Me cilimcet digitalizuam g sistemi de raportimi, de kontrol, nepromijem drtimi, to module, de tndršan, te cilet dot nun son, informimi realita publikon, ni financimi, de partit politike, de te fušata be. Fokus dotu ket, ere, de štuar, manneke cizis, edena programet, etra inimit, jo vedem, ta ditu, ta uditu svele expertve, por, de te ved candidatve, persona veci em mereme prugatidene raporteve, profesor, svele te medias, siun deekin, ke te češtie, de te tirve, cilcci li mi eštiur, informacioni im bi, sa para, marin partit, apo candidatve, nakuši marin, sii špenzoj nato, tieti plot, i-chart, de necoreale, de tiet, samršum, transparein. Proto aprofumbor, poria programetia, kec je za, falem deron, intranasional aidin, ore de partner de tiet, metacilit, metacilit kec je za, pronon, gustusist, nalide meek de češtie, de je mi besim plotia, čar, Žber, mere, dot-bud, ma mere nato armen, čram, Žber, far, besoče, dot-bud, falem deri, tec, pia, smar, sve, propresensin. Thank you. Thank you. Commission at Zellibashi for these opening words. And I think you made a very good point that reforms are necessary, but the oversight and implementation of laws is equally important. If you don't make sure that laws come to life in reality, then what use for laws? And that's exactly what the CEC aims to do. And secondly, you mentioned that the CEC will not be doing this alone, that it's an effort with civil society together, because only once these data about how much money, what role it plays in politics, become part of how citizens see politics, then it becomes useful. So that oversight is a collective effort. International idea and the finished rule of law center have a team in Tirana this week to help do those consultations with civil society, with political parties and with the oversight bodies. So we hope to be your partner in this. And let me also say that I admire your forward-looking view on this. A lot of the things that you mentioned, digital platforms to capture these data, looking at third-party funding, looking at social media spending are things that all countries in the world are struggling with across Europe. And the fact that you are taking a lead in these topics will also allow you to show the way for your colleagues in other countries. Now, let us move to the last but certainly not the speaker of this opening session. Mr. Alexis Vupin, Chargé d'affaire of the EU delegation here in Tirana. Of course, the EU has prioritized the topic of political finance tremendously in its discussions with Albania, including on EU accession. And as we speak, we know a lot of you will have followed that there are discussions ongoing in Brussels today about that EU accession process. So what better person to speak to us today about the relationship between Albania and the EU around the topic of political finance than Mr. Alexis Vupin, the floor is yours. Bedag, Sam. Dear state commissioner, members of parliament, ladies and gentlemen, thank you very much for inviting us today to this conference. Actually, we hope that this week be an important week for Albania as we are slowly going to be looking towards Brussels as of tomorrow morning. Now, as you know, we have been strongly supporting the election process over the last years and I immediately realized that it is, of course, always a curse to speak after the commissioner because the commissioner dove directly into the substance of the matter making for any further speaker quite difficult to match. What I would like to stress first of all is the glad to see that the process that is a process ongoing and as outlined by the minister if you allow me to call minister because for our purpose here, I think you bring a lot of your experience as well as a member of the government. It's a process. We had last year the general election. We had a barrier election in March and already as the by-election went early over already the state permission hit the ground running by organizing last month's this conference and this important stop taking on diaspora votes. Now, one month later we are on party financing and more generally the use of digital tools. And I think for us as you, it is very important to see that in this particular field of election reforms are ongoing. The consolidation is ongoing. You're building on a very good track record which has also been recognized by Odieh and his various report and that we have also reflected in our enlargement report. Now, as Sam has painfully reminded us at the beginning of his presentation parties still stand among the least trusted democratic actors and this goes for most country. It is a stark reminder but it is a good starting point as well to tell us that and you said it as well that no country is immune and allow me to say that the EU as such is not immune either from improvement. And I think it is one of these interesting area while Albania itself is moving forward with consolidating it's already strong basis on the side of the EU and the European Commission we are also proposing legislation in order to tackle political advisement, party funding and the flow of money in general within European political parties and when it comes to our own European and election. And what does it mean is that we need to keep up with the pace of change. We cannot simply say that the company criteria setting in stones the 25 or 35 years ago and for exceeding states there's a set of rules to be taken. No, we need to adjust and for instance, in the case of the EU we have recently decided a targeted advertisement which relies on profiling based on sensitive data like political views will be forbidden. So it's really a progress that is going forward in all countries and not just in exceeding state. And this is also a call of course for modesty a humble call as you rightly said yourself I think you brought us an interesting historical perspective even more interesting since the 24th of February but also interesting when we keep in mind some of the election interference also across the Atlantic from the same actor that you actually mentioned in your presentation. So very much finished days I would say these days in Tirana. Now the very good thing about this conference is that you have also invited members of the parliament so as EU delegation and representing the EU allow me to say that part of the work in order to consolidate this work will be with the CEC and some you rightly mentioned the issue of the oversight that was mentioned by the commissioner part of the exercise will be in terms of bylaws but also the ball is also in the camp of the parliament if you allow me to say turning on my left now we have and I would say at last have the working group on electoral reform up and running and of course our hopes are very hoping are very high that you will deliver on the next stage of consolidation of of of reform. Now international actors have also been mentioned in the previous presentation allow me to say this will not come as a surprise coming from what we are also meaning a donor that we are very much like the idea and we like to see and we see it happening which is very good. We are very much encouraged by the close coordination not between they are but also by our funded project with the council of Europe and I think this is the way in a way to to go forward also with our colleagues of the of the OEC I think it is it's important that the strength goes forward together. So thank you very much and very much looking forward to hear the intervention throughout the morning including from our representative from the civil society which I think will also have a lot to say. Thank you. Thank you, Mr. Urban for sharing your thoughts on the topic of critical finance on how this relates to the relations with the EU but also for pointing out that it takes to the tango. It's not just the oversight bodies. It's not just civil society. It's not just political parties or parliament. It is something we have to do together. That brings us to the end of this opening session. I want to thank all speakers Mr. Yupen, Tuya Braks, Mr. Tseli Bashi and the Secretary-General of International Idea Kevin Casas-Somora for starting us off on what I anticipate to be a very good debate throughout this morning. Thank you very much and we will move to the next session now where we'll be hearing from the politicians on to that. And I believe we're going to change seats so if I can invite the politicians to come to the stage. Yeah. Yeah. Yeah. It's better. You have to put the camera camera up to most of these. Yeah, it's here. Can they see the politicians? Okay. Let us proceed then to the next session. I have an honour to monitor this one and it will be about the commitment to political finance transparency through electoral reform. This issue of commitment has been raised last year and the year before not only due to the terrible outturns in Afghanistan but also in several other reports and auditing reports the court of auditors in Luxembourg that when it comes to rule of law and the party finance and the reforms of openness the basic requirement is that there has to be commitment. And the other way around the lack of commitment and the turnout seems to be close to zero or sometimes even worse than that. And what I've heard already today is that we are at the space in Albania that very critical movement but also a huge window of opportunity that this commitment seems to be on the air. And let's hear whether I'm right or wrong. And it's not only commitment of the parties of course also what we learned in Finland is that the commitment of the civil society and press needs to be there as well. That then that you audit you demand, you scrutinize the level of commitment. But now we concentrate on the party part. And we have here today three very distinguished, honorable and important person in this project. I've heard that we start with co-chair of the Adhok Parliamentary Reform in Kelaid, I think. Most likely, so yeah. And I'll invite, sort of, hopefully. And then we continue to Erdian Saliani. Sort of, hopefully, right. And I've been informed that Petrit Vasily is in his way. There is another meeting going on but he will be here during the session. So we'll have time to listen to all of this. So about the commitment, about the prospects about the hope and future, pride future I believe, please, for Flores, yes. First of all, I'd like to thank the Neroa Professores Organizadas Idea International. The Zodic Commissioners. Neroa Professores of Trupid Diplomatik. Part of the political, civil society. Neroa Erdian. Zoya Dezotri. Did they print this each? Me, so you didn't even need that. That's not what you're sure. We'll look at the party commissioning for such a parade of them in the reformers. You need to include me initiative to party them. Gratiga. The commission. Capordeture. Dirtotiera. The address. I recommend it. Organizator. Combatare. Lendor. Combatare. We're going to go team. The Cine Basque Retail Commissioning Reforms. The other part of it. The tourist parties. The gratica. The shiroi to foreign. The GDV. Sichiris. Organizator. The idea. Organizator. The FTS. The U2GDV. The Smaris. The conference. Judo idea. The Jotis. You and the Trees. The Jotis. The Jotis. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. You and the Trees. This will lead to the responsibility of the FUSHAT paradigms. A third, due to the lack of efficiency in the financing of FUSHAT.


A remarkable find has been documented in Scotland, and as the wood artifacts known as the Dixon relics have re-emerged in Aberdeen, where they were lost after being examined a hundred years ago, the relics were recovered from a shaft inside the Great Pyramid of Giza, and a carbon-14 date has been acquired. The tiny wood fragments of cedar wood had dated to the time before… wait, do you hear this? You guys may remember our video on the Dixon relics from a few years back, highlighting the frustrations that they went missing under strange circumstances, sending them between England and Scotland on a steam train in a cigar box. The relics were taken to England by John Dixon and mailed to the astronomer royal of Scotland Piazzi Smith, who recorded them in his diary and says he then returned them to John Dixon. In 1993, Robert Vival attempted to trace the relics, finding some of the artifacts at the British Museum, but to his frustration the cedar wood was missing, and that meant no carbon-14 dating could take place. Well, get on the phone Robert, they are in Aberdeen, and the world's fascination in dating these relics is about to unfold before our very eyes, as further dating techniques from multiple and superior sources assure to spark a dramatic rewriting of the historical data laid out thus far. The artifacts have returned a carbon-14 date of between 3341-3094 BC, 500 years earlier than the historical record, which date the Great Pyramid to the reign of the Pharaoh Khufu between 2580 and 2560 BC, and this of course is another shocking revelation in our historical misguidance. Further adding to the mystery and meaning that access had been acquired to the Great Pyramid 500 years before the king credited as having built it was even born. This means excavations were taking place in the Great Pyramid before Egypt was even a unified state, before kingship even began. This means the Great Pyramid is prehistoric, right? The discovery came by chance, as did a previous discovery of another piece of the artifact in 2001 by a librarian, but this time around the discovery of the cedar wood fragments came from an Egyptian researcher in Scotland. Sounds like a film, right? Nothing apart from these relics and the extremely controversial Khufu cartouche were even found in the Great Pyramid. No hieroglyphic inscriptions, no paintings, no mummified remains, nothing. Nothing was ever found that we can say what it was, who built it, or why. It is the biggest mystery on our planet from a time in history that we are educated to believe that such an undertaking would not have been possible. These fragments show us however that there must be a lost epic in human history, a time from which the current wave of existence re-emerged from. The Great Pyramid confounds human understanding, and we as a people must break free from our chains of silence that stops us from knowing. We must begin to understand the story that has been crushed by empires, empires that our sweat and guts helped build, empires that kept us in the dark so that they could gain control over us as a people, a darkness that must come to the light. Cuehitorial assistant Abir El-Aldani was reviewing items in the university's Asia collection when she came across a cigar box marked with her country's former flag. Inside she found several wooden splinters which she then identified as a fragment of wood from the Great Pyramid which has been missing for more than a century and she told the Lost History channel that the university's collections are vast running to hundreds of thousands of items so looking for it has been like finding a needle in a haystack. I couldn't believe it when I realized what was inside this innocuous looking cigar tin. I'm an archaeologist and have worked on digs in Egypt but I never imagined it would be here in northeast Scotland that I'd find something so important to the heritage of my own country. It may be just a small fragment of wood which is now in several pieces but it is hugely significant given that it is one of only three items ever to be recovered from inside the Great Pyramid. Neil Curtis head of museum and special collections at the university said finding the missing Dixon relic was a surprise but the carbon dating has also been quite a revelation. It is even older than we had imagined. This may be because the date relates to the age of the wood maybe from the center of a long-lived tree. Alternatively it could be because of the rarity of trees in ancient Egypt which meant the wood was scarce, treasured and recycled or cared for over many years. It will now be for scholars to debate its use and whether it was deliberately deposited as happened later during the new kingdom when pharaohs tried to emphasize continually with the past by having antiquities buried with them. The cedar fragment originally belonged to a much larger piece of wood which was most recently seen in a 1993 exploration of the interior of the pyramid by a robotic camera in hidden and now unreachable voids. The stunning discovery and further dating to a time some 500 years before the reign of Khufu is a stunning clue in our research for answers as to why the Great Pyramid was built. By no stretch of the imagination whatsoever we can explore the fact that it is an impossible undertaking. We assume it was built by thousands of men working 12-hour shifts transporting huge blocks up to 400 miles and placing these megalithic stones with such a precision that they would form the megastructure of the pyramid that has stood the test of time. No equipment or tools have ever been found at Giza and this suggests it is far older allowing time for metallic objects to be recycled back to the earth from which they came. The truth surrounding this wonder has been lost to history but the dating of an artifact that was recovered from within a shaft that it was poked down in prehistoric times shows us that history is not what we think it to be and we would encourage anyone looking to build an understanding of the timeline of the past to check out the Lost History Channel's Squatter Man Project series. Comments below guys and as always, thank you for watching.


Personalized preventive health care is becoming increasingly important in addressing public health issues. Efforts are being made to utilize big data, participatory health initiatives, and a shift in mindset to create a more proactive approach to health care. By 2050, it is hoped that this new model will have been fully implemented and will allow for better prevention of diseases and improved overall health outcomes. This article was authored by Melanie Swan.


Over the past seven decades, we've witnessed monumental changes in the world and in our nation's military. Established in the earliest days of the Cold War, the United States European Command has served as a vital strategic forward presence. UCOM has faithfully stood alongside the North Atlantic Treaty Organization and other allied partners to secure a free and prosperous Europe. Today, we will remember the women and men who met the challenges of the past 70 years and continue to do so with agility, courage, and devoted service.