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The Predictit prediction market foresees success for Clinton in Minnesota

According to the latest results from the Predictit prediction market Clinton can expect to win the vote in Minnesota with a probability of 90%. On September 18 her chance of winning the vote in this state was only 88.9%.

This article was automatically generated by the PollyBot, which uses algorithms developed by AX Semantics to generate text from data stored in our API. The exact dataset underlying this particular article can be found here.

Please let us know if you find any typos, missing words, or grammatical errors. Your feedback helps us to further improve the quality of the texts.

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Home All Positive Male Identity: What is a Real Man, Anyway?

Positive Male Identity: What is a Real Man, Anyway?

written by Steve Safigan February 29, 2012

Steve Safigan, MAPP '09, is a practicing life coach (CPCC). He is president of Foundations Seminars and presents personal growth seminars specializing in positive interventions for healthy adults looking for more happiness, meaning, and connection in their own lives. Full bio.

Steve writes on the 4th of the month, and his articles are here.

What does Positive Psychology tell us about positive masculinity and how it relates to femininity and sexuality? Bridget Grenville-Cleave wondered the same thing, asking, Dare We Let Boys Be Boys?. My curiosity led me to check in with Brianna Booth, MAPP graduate and doctoral student in Human Sexuality at Widener University. Brianna works in a field she calls Sexual Well-being at the intersection of the Positive Psychology and Human Sexuality fields. She helped me sharpen my interest in the concept of male identity, which led me through the men’s movement of the 80’s and 90’s, to the work of psychologist and author Christopher Blazina, and to Roy Baumeister’s provocative article about what there is that is good about men.

Gary Cooper: tall, dark, and handsome

The Men’s Movement

The “men’s movement” emerged in the 1980’s as a complementary counterpart to the feminist movement. It explored the different roles men play and identities that men hold. Like the feminist movement, it was not simply psychological. Works by writers such as Robert Bly, John Eldredge, Sam Keene, John Gray, and Robert Moore were also sociological, philosophical, political, and even environmental, spiritual, and mythological. The movement offered alternatives to traditional male role models exemplified by John Wayne and Gary Cooper.

As helpful as the men’s movement is, it seems more involved in advocacy than concerned with empirical research. Many authors promote their own specific views of masculinity rather than support an individual’s search for his own masculinity. From my own exploration, I haven’t found much descriptive research into how men see themselves as men and how these perceptions affect men as well as boys. We do not know enough about male identity.

The Ten Myths of Growing Up Male

Psychologist Christopher Blazina tells a story about one of his counseling clients who finally said in frustration, “Look, can we just cut to the chase? Can you tell me how I am supposed to be as a man?”

In his recent book, Blazina explains that many men operate under a set of misunderstandings about what men are supposed to be. These misunderstandings are inadvertently taught and enforced mainly by men. He sums them up in what he calls the ten commandments of growing up male, myths that permeate our society.

   Based on Power

  1. There is only one way to be a man.
  2. Fear the feminine.
  3. Men must funnel all their feelings into sex or aggression.
  4. Affection is always associated with sex.
  5. Boy society is based on power, strength, and paranoia.
  6. A boy needs a male role model or his sense of being a man is flawed.
  7. If your father is rejecting, you must learn to please him.
  8. If you don’t please your mother, you must marry someone like her.
  9. Being a man is a 24/7 job.
  10. A man must follow the commandments even if it causes him to be emotionally stunted or leads him off track.

These myths are contradictory, confusing, and demand that men conform to an unachievable standard that overlooks the nuances of men as individuals. Following the commandments, men generally concede that they can’t live up to society’s definition of masculinity. Blazina argues that once we recognize the way that the commandments dictate our lives, we can rewrite them to reflect our unique positive identities.

Father and Son

Provider, Protector, Progenitor

Throughout his book, Blazina makes two core assertions. The first is that men and women are more alike than they are different. The second is that there is no one way to be a man. The feminist movement helped establish this fact for women. It now sounds strange to ask what a “real woman” is. The same should be true for masculine identity, but as a society we still seem to have more rigid expectations for men.

Blazina draws on anthropologist David Gilmore’s research into what is considered masculine across cultures. Gilmore groups traditional roles of males in most cultures under the three P’s: protector, provider, and progenitor. Masculinity is often defined within a culture as a man’s ability to achieve all three roles.

The three Ps are not inherently destructive. However, they do cause boys and men to question whether they have what it takes to act in these roles. Blazina sees these role standards as a checklist in which a man either succeeds or fails. Significant psychological angst can occur if a boy or man concludes that he doesn’t measure up.

The View from Society as a Whole

Baumeister: The gender gap in dangerous work persists

Noted psychologist Roy Baumeister points out that men dominate both the top and bottom of the social ladder. The large majority of our top CEOs, scientists, and politicians are men, but so are the majority of prisoners and homeless. Baumeister argues that

“The essence of how culture uses men depends on a basic social insecurity. This insecurity is in fact social, existential, and biological. Built into the male role is the danger of not being good enough to be accepted and respected and even the danger of not being able to do well enough to create offspring. The basic social insecurity of manhood is stressful for the men, and it is hardly surprising that so many men crack up or do evil or heroic things or die younger than women. But that insecurity is useful and productive for the culture, the system.”

Positive Perspective: Looking Forward

But this is a view of society as a whole, not one focused on the well-being of individuals. If we shift our view to individual well-being, how can boys and men define their own positive and achievable roles in reference to their male self-identity?

Blazina contends that a man’s identity must evolve as he ages. An athlete will need to redefine himself when his physical skills decline. A businessman will need to redefine his role when he retires. Additionally, Blazina recommends that we replace our notion of traditional male role models with the concept of guardians, male or female, who can support a boy’s development of a healthy, authentic sense of self. Boys and men need guardians throughout their lives as their roles change and as they face new challenges in what it means to be men.

Blazina has a vision of a man’s sense of his own masculinity as “a common tie that binds all his responsibilities and endeavors [. . .] a rich resource, bolstering who he is every step of the way along life’s journey.”

My question is how we, both as members of society and as adherents of positive psychology, can arrive at this point. What do we still need to learn from research to better embody positive concepts of masculinity in our personal lives?

Baumeister, R. F. (2007). Is There Anything Good About Men? Invited address to the American Psychological Association.

Blazina, C. (2008). The Secret Lives of Men: What Men Want You to Know About Love, Sex, and Relationships. Deerfield Beach, FL: Health Communications.

Bly, R. (1990). Iron John: A Book About Men. Boston: Addison-Wesley.

Eldredge, J. (2003). Wild at Heart: Discovering the Secret of a Man’s Soul. Farmington Hills, MI: Gale.

Gilmore, D. (1990). Manhood in the Making: Cultural Concepts of Masculinity. New Haven, CT: Yale University Press.

Gray, J. (1992). Men Are from Mars, Women Are from Venus: The Classic Guide to Understanding the Opposite Sex. New York: Harper Collins.

Grenville-Cleave, B. (2010). Dare We Let Boys Be Boys? Positive Masculinity and Positive Psychology. Positive Psychology News.

Keen, S. (1992). Fire in the Belly: On Being a Man. New York: Random House.

Moore, R. (1991). King, Warrior, Magician, Lover: Rediscovering the Archetypes of the Mature Masculine. New York: HarperCollins.

Gary Cooper courtesy of Thom Wong
Round Two begins courtesy of Cubmundo
Madagascar Father and Son courtesy of Steve Evans
Firefighter courtesy of Brett Arthur

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Christine Duvivier February 29, 2012 - 5:39 pm

Steve, I really enjoyed this article and am going to send it to men (and women) in my life. Thank you! I was heartened by your point about men and women being very much alike and intrigued by your quote from Baumeister about men as CEOs and prisoners.

One thing I would point out about re-defining roles over time is that this is true for women as well as men. Women executives have to work through identity issues when they leave corporate America and mothers often face identity issues when their kids leave home. I do agree that men, in general, seem to have more rigidly-defined accepted ways of being in the world. It’s great that you’re helping to re-think this.

Louis Alloro February 29, 2012 - 10:21 pm

Love this article — way important to challenge our beliefs on sexual identity. Thanks Brianna, for your work, and Steve, for reporting on it.

Explore Nature March 1, 2012 - 1:57 am

Good post and thanks for the information.

Gender represents the psychological factor of sex. Gender specifications are essential things in the human society. Balance between masculinity and the femininity is very important for the long time existence of human kind.
Developing children’s psychology with proper gender specifications is a great responsibility of parents. In this case, fathers must raise their sons with masculine gender specifications from younger ages. In addition to that they must let their sons to be sensitive for feminine gender specifications which are corresponding to their masculinity. Femininity is the corresponding feature to the masculinity of men. Fathers must develop the psychological masculinity of their sons and the sensitivity of identifying femininity of girls and women. There is a great responsibility of protecting boys psychologically from complicating their gender to all of adult men.

Tracy March 1, 2012 - 6:19 am

This topic never truly hit home for me until I was raising my son. Some of the classic ideologies about raising a boy into a “man” quite frankly sickened me. A real man to me is one that is REAL from the inside out, not what society tells him he is supposed to be. I see so many men struggle today because of that.

Women have pressured stereotypes as well, just watch about a million ads telling us to lose weight, remove body hair, wear makeup, dress in heels that ruin our back and feet…, and men have other stereotypes they are expected to fit into. I think men have it worse because their stereotype goes so much deeper than the physical trappings, it screws with their emotions and that sort of invalidation is profoundly damaging on so many levels.

Jeremy McCarthy (@jeremymcc) March 1, 2012 - 9:54 am

Hi Steve, I always enjoy your articles (I wish I had been in your cohort in MAPP so I could have read some of your papers, I bet they were good! :-)). I hope you do a follow up on this piece that attempts to answer some of the questions you brought up. Interestingly, I also had something published on gender this week as I was asked to write about my career experience as a male working in the predominantly female spa world: http://www.spatrade.com/americanspa/spa-business/venus-and-mars

Recently, at a family gathering there were a bunch of kids under 10 and some of the girls (daughters of my cousins) were doing their nails. One of the boys wanted to paint his nails but when he reached for the nail polish, his sister grabbed it, exclaiming, “no! This is for girls only!” My cousin immediately looked down at her children and said, “Hey! No gender scripting!” and told her to share the nail polish with her brother. I thought this was a hilarious thing to hear from a parent so I was laughing but I was also impressed by this approach and it has changed the way I think about raising my own two boys.

There is a lot about this in “Situations Matter” by Sam Sommers (which I wrote about here on “Why Men Are Better Than Women at Math” http://psychologyofwellbeing.com/201110/men-are-better-at-math.html) Thanks for stimulating something interesting.

Steve Safigan March 1, 2012 - 12:12 pm

Jeremy, thank you for your links to other references on this topic. If anyone else knows of research, authors, books, articles or other resources on this topic, please post them here. I’m interested in learning more!

Jeremy McCarthy (@jeremymcc) March 1, 2012 - 1:47 pm

Here is an interesting article (from yesterday) showing how Norway is pushing gender equality and changing social norms with a new law that pushes father to take time off to spend with their newborns while encouraging women to come back to work: http://www.theglasshammer.com/news/2012/02/29/women-men-work-and-family-%E2%80%93-why-our-mindset-must-change/

Bridget March 22, 2012 - 7:51 am

Great article Steve

I have recently been reading Natasha Walter’s book ‘Living Dolls: The Return of Sexism’ – in short she demolishes the argument that there is a biological difference between the male/female brain which is often used to explain why boys & girls think and behave differently. She argues that it’s all due to socialisation. The research she uses to support this is robust, and it’s interesting that top scientists (she names many) still persist in the biological explanation when there appears to be none.

Our 10 year old son is a great communicator and has great empathy, and he’s not in the least bit girl-like. In my observation, people treat boys and girls differently, and have different expectations of them from the moment they’re born. It’s no wonder they grow up differently.

Al March 25, 2012 - 10:20 am

Why is there no option to post this article to Facebook? I see an option to “retweet,” but I don’t see a button for Facebook. This is an excellent article that deserves wide dissemination; I would post it to my Facebook wall if I could. Thanks.

Steve Safigan March 25, 2012 - 2:29 pm

Hey Al, I think if you copy and paste the web site address to a status update on Facebook it will automatically create a link and allow you to attach a comment to it. There may be other ways as well.

Al March 25, 2012 - 2:51 pm

Thanks, Steve. That’s what I ended up doing. Still, if there’s a “retweet” button, why not one for Facebook too? (A question for the programmers, not the author) 🙂

Editor K.H.B. March 26, 2012 - 9:42 am

You are quite right. I think when we last looked, it was not simple to do, but I suspect it is drop-dead easy now. I’ll look into it.

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Cover image for My development environment setup (Part 1)

My development environment setup (Part 1)

jorge_rockr profile image Jorge Ramón Updated on ・2 min read

Last week at work I got a new project on .NET Framework. As a good developer I tried to run it on Linux using .NET Core but I failed and my work's laptop didn't had Windows installed, what could I do?.

So, I went running with the tech support area, told them the problem and after some research the only solution was: delete Linux, install Windows and install Linux again.

Fucking Windows. 😡

But that inspired to me to write this post.

This is what I consider a good environment to develop quick, easy and be coolest in the office. Don't judge me!

P.S.: I'm using Ubuntu 18.04 because why not? I had Fedora 27 before eveything happened and it's still my favorite but I will give Ubuntu a try again.

Let's get started!

1. Install essential tools

We need the basics, you will suffer if you don't have them:

sudo apt-get update
sudo apt-get install build-essential git curl xclip

2. Install zsh

Zsh (also called Z shell) is an extended version of the Bourne Shell (sh). It has many cool features against original bash:

  • Plugin and theme support
  • Spelling correction
  • Automatic cd
  • And more!

Just install it with the follow command:

sudo apt-get install zsh

3. Install Oh My Zsh

Now we have a good shell, great. But Oh My Zsh will give us extra power:

Then, just copy the follow command:

 sh -c "$(curl -fsSL https://raw.github.com/robbyrussell/oh-my-zsh/master/tools/install.sh)"

And you will get this:

4. Start using zsh by default

If you restart your terminal it will be using bash again. Why? because you need to change it explicitly with the follow command:

# Change the shell to zsh
chsh -s `which zsh`

The bad thing is that you need to restart your computer 🙄.

# WARNING! It will shutdown immediately :(
sudo shutdown -r 0

But after rebooting this will be the result 😍:

5. Install vim

It's time to get into hacker mode 👨💻 :

Just kidding.

In my experience, working with vim has been the best idea ever because:

  • It's lightweight
  • It's everywhere (even on Window's Git bash)
  • I feel that I write code faster
  • Don't even use the touchpad (or mouse)
  • I'm forced to learn things such as package names and understand they purpose
  • Syntax highlight for many programming languages
  • Shortcuts as Sublime Text or Visual Code Studio

So, why don't you give it a try?

sudo apt-get install vim

This is the end for the part 1 😋.

In the next post I will cover:

  • Configure vim and add steroids
  • Fixing some vim weird errors
  • Mastering vim

See you on the next post!

Part 2: https://dev.to/jorge_rockr/my-development-environment-setup-part-2-4ck9

Posted on by:

jorge_rockr profile

Jorge Ramón

Full Stack Developer at @Globant. Javascript is all that you need.

Editor guide

I still don't understand this idea that Linux somehow has something that Windows doesn't when it comes to development. I develop in multiple languages and have never found the need to use Linux or found Windows lacking in any way so it would be interesting to hear what you think Linux brings to the table that Windows does not as surely a good developer should just be using what they feel most comfortable with?

My last windows development experience is a bit dated and many things happended - especially WSL happendend. So what I have to tell is cum grano salis. My last experience is from late 2014/early 2015.

I was a Java developer - no problem here. But what made me go away was, that I was a) accustomed to a linux shell (cygwin is no help) and b) part of my toolchain - e.g. git - needed a minimal unixy environment done with MSYS. And the really awkward part started, when you whad severeal MSYS environments on your machine which interfered with one another (+ your cygwin environment) and required you to carefully rewrite the sequence in the $PATH (what should trump what) so to say.

So doing Java everything was fine. But doing additionally scripting in ruby and having somewhere a perl in your cygwin could make your life harder.

My conclusion is:

  • developing C# in windows with Visual Studio (Professional) works like a breeze and has everything to offer, to develop for windows

  • developing Java is nice under windows and linux as well. I experienced no differences

  • using something like ruby (or e.g. python had some known bugs on windows and who cares for that?) in combination with other *nix-centric ecosystems made my life harder as it should be

From my experience, *nix systems were per se developer centric - you could fix your own system, if you leave apple out in this point - and offer a rich integration, which microsoft for years neglected.

Only the last years, they are going to reconquer developer's hearts with WSL.

windows sucks away lots of resources and it have many background services that keep my laptop busy (security center cannot be disabled, cannot switch to manual updates, etc).
With many Linux distros you can have more control over your workstation and more resorces available.

I can only see this as a problem if your machine isn't up for the task in the first place. Again, I've never had any issues with Windows.

Well, yeah, if you are filthy rich and can afford a filthy powerful machine, then you can even use a virtualized MacOS xD.
Jokes apart, you are right, but in my case I have to do very different types of work on my machine: python development, nodejs, frontend, spin up virtual machines, use containers, etc, so I always felt I need as many resources as possible from my laptop. For instance, I think disk usage is an issue with windows. I'm developing a xamarin app, and visualstudio+xamarin take gigas and gigas of disk space (it's not the OS, though, maybe I am a little OT :). Ever felt this way?

You can disable those by booting windows in safe mode

I actually never tried that. I always though that you have to use safe mode when something screwed up your pc. It is usable? Have any downsides?

See my post below about coming from a Unix background...

For me, until Windows 10 introduced WSL, it was not a place I could get my work done in a way that I found productive. I use a visual code editor (vscode) when doing much of my actual coding but for the other times, I am editing configs, running scripts, testing out code in REPLs, doing package management, using git... Etc. For all those things I immediately turn to the command line. Vi is magic for quickly editing a conf file. Bash/zsh are great for simple but powerful scripting. Yum/apt/etc are great for quickly getting software on your machine. Node or python or Elixir are great to test ideas out in their interactive modes on the cli. Cli is the fastest and, in my opinion, easiest way to use git. It's all made powerful by a great terminal and great shell. I find Windows lacking in both... until wsl came along.

I just find that really difficult to contemplate. I've been a Windows user all my life. I edit config files in Notepad++ and really don't understand the need for anything else. I use git through a standard CMD prompt in Windows and again have never needed anything more when I've been developing in .Net, Java, JavaScript, Python, PHP and PL/SQL.

I don't mean any disrespect but the point is that you will never contemplate the *nix way if you don't try it seriously. The only problem there is with Linux, in my opinion, is that starting is hard. I was lucky to have a lot of friends that help me go through the first steps of learning.

It's not a problem with starting with Linux. I'm fluent in using Linux from having to learn it at University but the point here is after using both Windows and Linux I fail to find any issues with just using Windows. It just seems everyone seems to be using Linux to develop on because it is seen as 'trendy' rather than actually being more productive.

I can't talk for others, but provisioning tools such as SaltStack, the POSIX terminal (that I'm sorry, Powershell is a long way off) and the ease of use of SSH (in both ways), all of that combined with the fact that the majority of servers on the Internet are running Linux (and the place I worked and my VPS provider does too) and the cost of Microsoft license is the reason why I prefer Linux over Windows. Furthermore, I've always hated the Windows Filesystem. I can't count the number of time I had ACL issues on Windows, sometimes I needed to use third-party super-user plugin to force a folder to be read-write for everyone (like an upload folder for instance).

I'm not a stubborn person, and I can admit that VisualStudio is probably the best IDE, after trying IntelliJ, Eclipse, Netbeans and XCode. SQL Server is a real good SGBD for the price to pay (compare to IBM DB2 or Oracle Database 12i). The real problem is the licensing: so complicated for nothing. SQL Server can be bought per number of people connecting, or per core processor. You are forced to buy Windows Enterprise or higher.

Lastly, Linux can run efficiently on older, less powerful computer compare to Windows. Running a dozen websites on a Windows server costing 4k might not be to the reach of small enterprise. It may be more efficient to buy 3, less powerful computers, to run with a load balancing, a fail-over system that cost the same price running Linux. The money you spend on licenses (that can easily cost in the thousands) can be invested in training. To be fair, it is easier to find professional for windows compare to Linux.

As developing using Python, I have found many packages have weird issues working with windows. WSL is great, However, takes some extra step to get into (start ssh server, tell pycharm to use wsl python as the default one)

You can't run docker container natively hence the missing unix namespaces. I'd image some performance bottlenecks/higher cpu & ram load since your docker engine runs in a vm.

well if you work in some enterprise companies, you have very limited windows with slow security scans, or.. linux :D

Okay pardon my newbie and dumb question, but can I run bash scripts(.sh) using Zsh?

And also, and this is just my opinion, have you given Ubuntu MATE a try? I prefer it above all Ubuntu flavors... specially the flagship Ubuntu that now comes with GNOME Shell...

Lastly, yeah, fucking Windows...

There aren't dumb questions :) Feel free to ask.

Yes, you can run bash scripts because zsh is just an extension.

And no, I haven't tried Ubuntu Mate yet, maybe I should give a try at home's computer :D

“There arent dumb questions”. Try this on stackoverflow and you would wish u didn’t exist 😜

I am mostly with you. I jave a few variations on your setup though.

I prefer Neovim to vim
I prefer Prezto to oh-my-zsh

In terms of Windows, what I always found lacking was a decent terminal and shell. Those are different things.

For terminal, I now use ConEmu (and wsltty sometimes) and love it... A lot.

For shell, cmd is too different from *nix shells to be useful to me. And I have never been comfortable with PowerShell, though I wish I was as it's very powerful. For me it comes down to growing up using Unix command line and finding that to use Windows, my knowledge only makes me better on Windows... but learn *nix shell scripting and you can use that anywhere.

I wanted to start using VIM but it feels like it's too hardcore for me, I'm just a beginner, Although I've thought about forcing myself to use it

If you can't handle Vim, nobody will criticize you. Vim is not for everyone. Use what suits you best!

VSCode is killing it smoothly, I'm loving the array of extensions it has

In my next post I will cover the commands I use day-to-day. So don't worry, I know it's hard, but with this setup made it easier

Looking forward to advertise Emacs under it! scnr

Use whatever u r comfortable with, although it s a must to know basic vim commands. Is handy when u need to log in to linux servers for basic dev tasks

I usually use neovim instead vim on Ubuntu.

Out of curiosity, what drives you to Neovim instead of Vim Classic?

You can read more here.
Roadmap: Roadmap

In essence, neovim provides many common default settings for you. It is a refactor of traditional vim, keep good parts of vim and also an effort to make vim more productive.

Sorry that Windows blue-screened on you, Jorge. Glad you were able to channel your anger into something constructive (i.e., this post).

Windows is a very good development environment. Especially if you are all-in on the Windows way of developing.

If you have not drank the Windows flavor-ade, you can still go a long way using WSL, or Cygwin, or even SFU (although I think WSL supersedes SFU, but not everyone is on Windows 10). One foot in each world. Of those, my personal preference is Cygwin.

There is a native (GUI) Windows build of Vim. (Just as there is a native build of Vim for Mac, called... MacVim.)

For doing .NET development, Visual Studio is hard to beat. If you are doing Mono development on an non-Windows platform, Visual Studio (formerly Xamarin) for that non-Windows platforms is highly recommended. I did all my F# coding for Mono on a Macintosh, without a hitch. Only thing lacking was WPF, since WPF is tightly coupled to DirectX — probably why Microsoft hasn't open-sourced WPF as they've done with so many other .NET technologies. (Open-source kudos to Microsoft under the Satya leadership era!)

Code on!

The bad thing is that you need to restart your computer

Re-opening your terminal would be enough.

I tried but no luck hahaha. Restarting worked, I dont know why.

You don't need to restart. Just open your regular terminal/shell and type zsh and your current shell will be replaced by it. If you want to start to use it without this workaround, you can close your current user session and open it again, after you changed your shell configs.

You don't need to restart the computer, however you have to logout and login again.
Cheers on the setup.

I can't believe it when Microsoft launch .Net Core and say that can runs in Windows, Linux and Mac.

I decided migrate my bash/bat scripts and test in a console application and it's fucking true.

Now with vscode and .Net Core no matters the OS that you choose as developer.

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Enforcement of Judgments 2020 Comparisons

Last Updated August 04, 2020

Contributed By Baker McKenzie

Law and Practice

Baker McKenzie is a leading global law firm, with offices in 78 cities worldwide. The Canadian team has acted on some of the country's most important enforcement cases in the past two decades. The firm's Canadian lawyers are fully integrated with other Baker McKenzie litigators located worldwide. The firm is a highly regarded litigation group in Canada with particular expertise in multi-jurisdictional disputes, including all manner of fraud, financial recovery and enforcement-related disputes. The Canadian group provides clients with co-ordinated litigation, arbitration and enforcement services nationally and internationally. To appreciate the depth of the Canadian group's fraud law, enforcement and asset tracing expertise, visit their blog-site at: www.canadianfraudlaw.ca

Identifying an opposing party's asset position prior to, during or following a proceeding can be critical to informing a plaintiff's litigation or judgment enforcement strategy. Obtaining a judgment will be of little value if the unsuccessful party has no assets or is unable to satisfy the judgment. Fortunately, a number of measures are available in Canada that can assist in identifying an opposing party's asset position.

Publicly Available Information and Private Investigations

Some limited information that can shed light on an adversary's financial position is publicly available. For example, title searches and land registry searches can reveal the registered owners of real property and whether any encumbrances such as liens, certificates of pending litigation, judgments or mortgages are registered against the property.

Searches can be conducted for personal or moveable property, which will indicate whether the personal property of a person or corporate entity is encumbered and subject to the security interests of other creditors.

Litigation searches and insolvency searches can reveal the extent to which an adverse party has been involved in prior or concurrent litigation and/or insolvency proceedings. If the adverse party is or has been involved in litigation or insolvency proceedings, a review of public court filings may reveal useful financial information about that party.

Licensed private investigators can be engaged to investigate the other party's asset position. In Canada, private investigators are subject to industry regulations as well as provincial and federal laws. Private investigators can garner financial information by carrying out various registry searches (including those noted above), conducting interviews, performing surveillance and other legitimate investigative techniques.

Examinations in Aid of Execution

From a post-judgment perspective, having a full appreciation of the unsuccessful party's asset position will facilitate a well-considered and targeted enforcement strategy. Once judgment is obtained, a successful party can conduct an examination in aid of execution to obtain information concerning the debtor's financial position and his or her ability to satisfy the judgment. The debtor must answer questions under oath about his or her financial affairs, assets, income, liabilities and expenses. The debtor is also obliged to produce relevant financial records, such as financial statements, bank statements, tax returns, payroll information and the like, all of which can be of assistance in guiding the creditor's enforcement strategy. Examinations in aid of execution are discussed in more detail in 2.3 Costs and Time Taken to Enforce Domestic Judgments.

Freezing and Asset Disclosure Orders

In Canada, there are a number of remedies to assist in securing assets before judgment. These include Mareva injunctions (which can include an asset disclosure component) and certificates of pending litigation, as well as asset or "specific fund" preservation orders issued under provincial rules of civil procedure.

The Mareva Injunction in Canada

While the law concerning Mareva injunctions has not developed in exactly the same way as in the United Kingdom, this extraordinary form of pre-judgment "freeze order" is available and, in the right circumstances, can be granted with asset disclosure terms having worldwide effect. Dubbed one of "the law’s two nuclear weapons", it was confirmed as part of the common law of Canada in a 1985 decision rendered by the Supreme Court of Canada. However, the Supreme Court did not establish a rigid test for the remedy. Rather, it established certain broad parameters without imposing an inflexible prescription. The court summarised the "gist of the Mareva action" as follows: the right to freeze exigible assets within the jurisdiction, regardless of where the defendant resides, where a cause of action between the plaintiff and defendant has been determined which is justiciable before the courts of that jurisdiction and where there is a genuine risk of the disappearance of assets, either inside or outside the jurisdiction.

In recent years, as more Mareva orders have been sought in more varied scenarios, the requirements for a Mareva injunction have been relaxed somewhat. A recent Ontario Superior Court decision held that the risk of dissipation can be inferred in cases where the inference arises from the circumstances of the alleged fraud, taking into context of all of the surrounding circumstances. Such circumstances include evidence suggestive of the defendant’s fraudulent activity or a pattern of prior fraudulent conduct. However, the requirement to have evidence of dissipation would not be automatically addressed simply because the plaintiff established a strong prima facie case of fraud. The inference would also be available if a strong prima facie case is established for other causes of action.

The Supreme Court seemed to favour the "strong prima facie case" requirement adopted by the Ontario Court of Appeal a few years earlier, while also noting that the Ontario approach was "somewhat narrower" than the "good arguable case" standard of UK case law. The "balance of convenience" must favour the issuance of the order. This branch of the analysis involves a detailed consideration of the competing interests at play: principally, the plaintiff’s interest in avoiding a dry judgment and the defendant’s interest in not having assets detained prior to judgment.

In British Columbia, the courts have adopted a flexible approach, employing a two-step test for the issuance of a Mareva injunction. Courts have the flexibility to carry out justice between the parties in any given case, and not render the judge “a prisoner of a formula". The British Columbia Court of Appeal has also recognised that almost every Mareva injunction is likely to inconvenience the other party in some way and has emphasised that "the overarching consideration in each case is the balance of justice and convenience".

Mareva injunctions are often sought on an ex parte basis. As with any ex parte relief, it is crucial that full, frank and fair disclosure be made of all material facts, particularly those that tend to support the position of the party against whom the injunction is sought. Such disclosure should include sufficient detail to allow the ex parte judge to determine the correct value of the underlying claim and, accordingly, of the assets to be frozen.

Certain jurisdictions have developed model Mareva orders, which serve as a guide when determining the appropriate parameters for this extraordinary relief. In a number of provinces, the ex parte order has a specific shelf life (ten days, typically) within which it must be renewed on an inter partes basis.

Certain model Mareva orders include or permit asset disclosure terms. These provisions can be a powerful tool to determine the scope of a defendant's assets. There will often be a term that requires the defendant to deliver a sworn statement describing the nature, value and location of assets, whether in his or her own name and whether solely or jointly owned. A further term can require the defendant to submit to examinations under oath on the sworn asset statement. Where these terms are granted, refusal to provide the asset information or submit to cross-examination may result in a finding of contempt of court.

As mentioned above, Mareva injunctions can be framed to freeze and obtain disclosure of assets, both within Canada and on a worldwide basis. In Ontario, a recent decision provided for a worldwide Mareva injunction where the defendant had no assets in the jurisdiction. A key factor in granting the injunction was evidence based on information from Hong Kong lawyers that the Canadian order would assist in securing a freezing order in Hong Kong.

Finally, while Mareva injunctions are typically sought before judgment, there is authority for granting a Mareva after judgment, which can be useful to determine the location of assets and securing assets in circumstances where a judgment debtor may seek to deplete, move or otherwise deal with the assets pending the outcome of an appeal.

Certificates of Pending Litigation (CPL)

Where real property is at issue, an order for a CPL may be obtained. A CPL is designed to provide a notice of claim and a warning to the public that the property is subject to a court dispute. It has the practical effect of restraining dealings with the property (eg sale, financing, mortgaging etc) while the litigation is pending.

As a standalone pre-judgment remedy, a CPL can be made on a motion without notice, provided that the originating pleading includes a claim for the CPL with a proper description of the land in question. To obtain an order for a CPL, the moving party must first show that there is a triable issue in respect of the claim to an interest in the land. If this threshold test is met, the court will typically go on to consider a variety of equitable factors, such as whether the land is unique, whether damages would be a satisfactory remedy and whether the interests of the party seeking the CPL could be protected by another form of security.

Orders for the preservation of specific property or funds

The rules of the court in each Canadian province permit the parties to obtain orders for the preservation of property that is the subject matter of a proceeding. In Ontario, for example, the rules permit the court to make an interim order for the custody or preservation of the property in question or property relevant to an issue in the proceeding. To obtain such an order the moving party must show that:

  • the asset constitutes the very subject matter of the dispute;
  • there is a serious issue to be tried regarding the plaintiff's claim to the asset; and
  • the balance of convenience favours preserving the asset.

Similarly, where the right to a "specific fund" is in question, the court may order the fund to be paid into the court or otherwise secured on such terms as are just. Such orders are subject to the same three-step test outlined above.

All judgments are court orders, but all court orders are not necessarily judgments. Judgments dispose of a proceeding on its merits with finality, whereas orders can be interlocutory or interim in nature, with the final determination to follow. Judgments can be granted on default if the proceeding is not defended within the timeframe stipulated in the Rules of the relevant province. In some circumstances, such default judgments can be set aside by the court, provided the defendant can satisfy certain tests (typically, an explanation for the delay, arguable defence, etc).

Money judgments are the most common form of judgments; however, courts can also grant declaratory relief, permanent injunctive relief and other remedies, whether based in statute or the common law. Non-monetary remedies that can be ordered include specific performance, vesting orders, granting title to assets, a range of insolvency-related orders under the Bankruptcy and Insolvency Act, R.S.C., 1985, c. B-3 and Companies' Creditor Arrangement Act, RSC 1985, c. C-36, and orders ancillary to corporate reorganisations or other transactions, including plans of arrangement.

Each province in Canada has its own legislation governing the enforcement of domestic judgments. As there is substantial overlap across all these pieces of legislation, and Ontario is the most populous Canadian province, the focus in this answer is on enforcement of domestic judgments in Ontario.

The enforcement of an order for the payment of money is largely governed by the Rules of Civil Procedure RRO 1990, Reg. 194 (the Rules), the Execution Act RSO 1990, c. E. 24 (the Execution Act), and the Creditors’ Relief Act, 2010, SO 2010, c. 16, Sched. 4 (the Creditors’ Relief Act).

The enforcement of an order that requires a party to do or abstain from doing an act may be dealt with by seeking a contempt order. Contempt orders do not apply to orders for the payment of money.

The Rules set out the procedures by which a judgment or order for the payment of money can be enforced). The Execution Act sets out the role of the sheriff, a public official, and the rights of debtors and creditors. The Creditors’ Relief Act provides the basis for distribution of seized assets and establishes priorities among execution and garnishment creditors, support and maintenance orders and debts of the Crown.

Primarily, there are four methods to enforce a domestic judgment for the payment or recovery of money in Canada and specifically in Ontario:

  • a writ of seizure and sale under the Rules;
  • garnishment under the Rules;
  • a writ of sequestration under the Rules; and
  • the appointment of a receiver under the Rules, the Bankruptcy and Insolvency Act RSC 1985, c. B-3, and the Courts of Justice Act RSO 1990, c. C. 43 (the Courts of Justice Act).

Pursuant to the Courts of Justice Act, a creditor will require the assistance of the sheriff to enforce a domestic judgment for the payment of money. The creditor will need to file a writ of seizure and sale with the sheriff and move to enforce the writ after filing. As a practice note, depending on the nature of the defendant (eg, financial institutions being reliably willing to satisfy judgments voluntarily), moving to enforce a writ of seizure and sale should be done promptly after obtaining judgment, unless assets have been frozen prior to judgment. The creditor must provide the sheriff with a direction to enforce, which includes detailed information as to the amount of the order, the amount and date of any payment, the rate of post-judgment interest and the costs of enforcement.

Upon receipt of the direction to enforce a writ of seizure and sale, the debtor’s property can be seized. The Execution Act empowers the sheriff to use reasonable force to enter the debtor’s land and premises if the sheriff has reasonable and probable grounds to believe that there is exigible property on the land or premises. One exception to this power is that the sheriff may not enter a dwelling place with force unless a court order is obtained.

There are exceptions with respect to the types of personal property that is exigible. For example, household furniture, utensils, equipment, food and fuel, contained in the debtor’s permanent home, up to a value of CAD13,150 is not exigible, and neither are pension entitlements.

The sheriff can enforce a writ against personal or real property. The writ will be valid for six years from the date of the judgment, but can be renewed. A writ will give the debtor priority over other unsecured creditors, but that priority is lost if the debtor becomes bankrupt. Other creditors who have perfected security interests in the debtor's property will also have priority.

Before the sheriff sells personal or real property that was seized pursuant to a writ, notice must be provided to the creditor of the time and place of the sale.

Garnishment is another common procedure in Canada to enforce a domestic judgment. Garnishment permits a creditor to seize money that is owed to the debtor by a third party, for example wages, salaries, dividends, receivables, etc. A creditor with a judgment for the payment of money can request that the local registrar issue a notice of garnishment. The creditor must provide particulars of the judgment and of the debts owed to the debtor by a third party.

A writ of sequestration is another method, although it is considered “extraordinary” (Falton v. Toronto General Trusts Corp., [1908] O.J. No. 656 (Ont. HCJ)) and is rarely used in modern times. Pursuant to a writ of sequestration, the sheriff is directed to take possession of and hold a debtor’s property and to collect and hold any income from the property until the debtor complies with the order. Where there is a writ of sequestration, the property is not sold.

Finally, a receiver can be appointed by a court where it is “just or convenient to do so” (Courts of Justice Act, s. 101). The court may authorise a receiver to recover and sell the debtor’s property to satisfy the remaining judgment or debt.

The costs involved and length of time it takes to enforce a judgment can vary dramatically. It will largely depend on whether there are any known assets in the jurisdiction and how straightforward (or difficult) it is to obtain those assets.

While the simplest scenario would involve a voluntary payment by the debtor, the most straightforward enforcement scenario involves a debtor who has known, readily available assets (ideally cash) that are held in his or her own name and are not immune from seizure and/or sale. In such a scenario, the costs are correspondingly minimal, with limited legal fees and only modest (in the hundreds of dollars) in court filing fees.

If the creditor does not have knowledge of the extent or location of the debtor's assets, the first step is often to conduct an examination in aid of execution in order to identify exigible assets. Counsel fees will vary for such examinations, depending on the nature of the debtor (examining fraudsters who are not expected to tell the truth will, for example, require more strategic thinking). The examination can also give rise to undertakings by the debtor to produce documents or further information, which, in turn, can give rise to a re-attendance to complete the examination at a later date. Preparing for and completing even the simplest judgment debtor examination can cost between CAD5,000 and CAD7,000.

In Ontario, one examination in aid of execution is allowed in a 12-month period for the same proceeding. If the creditor seeks to re-examine a debtor (as opposed to continuing an existing examination to ask questions arising out of undertakings) within one year, he or she will need an order from the court. Likewise, if the creditor seeks to examine a third party in aid of execution, a court order is required. The timelines and costs will increase where the debtor attempts to avoid or frustrate such examinations or attempts to transfer assets fraudulently to avoid enforcement. Sometimes, in the event of such a fraudulent transfer, fresh legal proceedings arising out of the enforcement efforts will be required (eg, in order to name one or more new defendants who may have received transferred assets from the debtor).

Execution on a judgment itself can be complex. For example, if execution may give rise to a breach of the peace, the sheriff may require the assistance of the police.

At one end of the scale, seizing monies in a known bank account can be relatively swift, straightforward and inexpensive. On the other hand, seizing and selling real or personal property, appointing a receiver, liquidating business assets and securities are generally more complex and costly.

If there are no known assets and the creditor cannot reliably discover assets by an examination in aid of execution, creditors will often hire an investigator or an asset-tracing firm. For simple investigative services involving local debtors, the fees are generally a few thousand dollars. However, more complex enforcement costs can involve significant international investigations of corporate dealings, offshore trusts, etc, and the fees for such services can run into the tens or even hundreds of thousands of dollars. In some cases, the cost of enforcement measures can be recovered from the judgment debtor. Sociedade-de-Fomento Industrial Private Limited v Pakistan Steel Mills Corporation (Private) Limited, 2018 BCCA 145.

As discussed above, a judgment creditor may conduct an examination of the debtor in aid of execution. This is a powerful tool allowing the creditor to question the debtor under oath to obtain information relating to:

  • the reason for non-payment or non-performance of the judgment;
  • the debtor’s income and property;
  • the debts owed to and by the debtor;
  • the disposal of any property the debtor has made, either before or after the making of the order;
  • the debtor’s present, past and future means to satisfy the order;
  • whether the debtor intends to obey the order or has any reason for not doing so; and
  • any other matter pertinent to the enforcement of the order.

Provincial rules also allow for the possible examination of “any person who the court is satisfied may have knowledge” of the debtor’s finances. Leave must be obtained to examine a third party and is not granted as of right. The court is more likely to grant leave to examine a third party where the debtor is non-responsive, evasive, has fled the jurisdiction or is deceased.

If a debtor fails to attend a court-ordered examination in aid of execution, or otherwise frustrates such an examination by being unco-operative, unresponsive or deceitful, the debtor may be found liable for civil contempt. The consequences of being found in contempt range from a fine for the payment of money, being ordered to do or refrain from doing an act, payment of costs to the creditor, compliance with any other order the judge may consider necessary, or imprisonment for a set period or until the non-compliance is cured.

First and foremost, a party may challenge the enforcement of a domestic judgment by challenging the judgment itself. For example, in Ontario, a party may make a motion (i) to have an order set aside or varied on the ground of fraud or of facts arising or discovered after it was made or (ii) to suspend the operation of an order. The rules also provide for setting aside or varying an order on such terms as are just, including orders made on default (Rules 19.08 and 52.01(3)).

If the default judgment debtor was not properly served with the proceedings, the debtor may challenge the judgment on that basis, provided that the defendant did not participate in the merits of the proceeding or otherwise attorn to the jurisdiction of the court.

In addition, a party can appeal a judgment and, in doing so, will impose an automatic stay of a money judgment in some provinces, such as Ontario. Generally, a judgment creditor cannot successfully pursue enforcement of a domestic judgment until at least the initial appeal rights have been exhausted. However, once a judgment debtor loses an appeal, there is no further automatic stay, nor a further appeal as of right. Rather, appeals to the Supreme Court of Canada are only available with the leave of that court. The judgment debtor appellants facing money judgments must generally post security before the judgment can be appealed.

Enforcement may also be challenged on the basis that the assets being targeted by the judgment creditor are not properly available for execution because they are not considered to be assets of the judgment debtor (eg, they are the assets of a related party or are somehow immune from seizure, etc). Such scenarios tend to be highly fact-specific and are often complex. Yaiguaje v Chevron Corporation, 2018 ONCA 472, leave to appeal to SCC refused [2018] SCCA No 255; Belokon v Kyrgyz Republic, 2016 ONCA 981, leave to appeal to SCC refused 37460 and 37463 (15 June 2017).

Generally, domestic judgments will be enforced, subject to the grounds to challenge enforcement set out in 2.5 Challenging Enforcement of Domestic Judgments.

Canada does not have a central register of all judgments. However, execution and judgment searches can be carried out on a province-by-province basis. A judgment debtor who has paid a creditor in full can obtain a satisfaction piece for filing in the court. This is a formal court document acknowledging that the debtor has paid the creditor in full satisfaction of the judgment.

There are three routes to enforcing foreign judgments in Canada: at common law, under legislation or pursuant to a treaty. Canadian courts will generally enforce a foreign money judgment, provided that:

  • the court giving judgment is a judicial body or tribunal regularly established and exercising the jurisdiction conferred upon it by the relevant competent authority;
  • the court had proper personal and subject-matter jurisdiction according to Canadian rules regarding the conflict of laws. Jurisdiction is viewed as properly taken if the court had proper in personam jurisdiction over the defendant, if there is a real and substantial connection between the foreign jurisdiction and the subject matter of the proceeding or if the defendant attorned to, or by contract, agreed to the jurisdiction of the foreign court;
  • the foreign judgment is for a debt or a definite sum of money; and
  • the judgment is final and conclusive with respect to the rights and liabilities of the parties to it so as to be res judicata in a foreign jurisdiction. Canadian courts may recognise and enforce interlocutory orders as long as they meet the requirement of finality. For an interlocutory order to be recognised and enforced, the foreign court’s jurisdiction to vary or set aside the judgment must be exhausted.

In certain cases, a foreign judgment granting non-monetary relief (ie, declaratory or injunctive relief) will be recognised and enforced in Canada (Pro Swing Inc. v Elta Gold Inc., [2006] 2 SCR 612). Such enforcement is possible where the foreign judgment was made by a court of competent jurisdiction, the decision was final and the nature of the judgment was such that comity required it to be enforced. However, quasi-criminal judgments, eg, a foreign contempt order, may not be enforced.

Certain Canadian provinces have passed reciprocal enforcement of judgment statutes that apply to foreign judgments. However, the scope of such legislation varies from province to province and tends to be limited to other Canadian provinces, the UK a few select US states and parts of Australia.

Where a provincial reciprocal enforcement of judgments statute applies to foreign judgments, the judgment may be enforced by registration. However, the provincial legislation does not alter the conflict of laws rules applicable to the recognition of foreign judgments. As a practical matter, this legislation is of limited benefit. Given that Canada's common law test for the enforcement of foreign judgments favours widespread enforcement, the legislation, while it should be invoked when applicable, does not bring material differences to enforcement. The courts of each province are still required to take a supervisory role to ensure that the foreign judgment is enforceable in accordance with applicable Canadian law.

Treaties are a third source of law for the recognition and enforcement of foreign judgments. Canada and the United Kingdom have entered into the Convention for the Reciprocal Recognition and Enforcement of Judgments in Civil and Commercial Matters, ratified as the Canada-United Kingdom Civil and Commercial Judgments Convention Act, R.S.C. 1985, c. C-30. The above-referenced Reciprocal Enforcement of Judgments (UK) Act adopts this Treaty.

Canada is not a signatory to the Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil and Commercial Matters. Therefore, when dealing with recognising and enforcing awards from jurisdictions other than the common law provinces and the United Kingdom, Ontario applies Canadian common law.

Furthermore, the enforcement treaty between Canada and the UK only applies to monetary judgments, leaving recognition of non-monetary UK judgments to the common law.

When a Canadian court recognises a foreign judgment, it means that the Canadian court will treat the foreign judgment as effective and capable of being enforced. A foreign judgment recognised by a Canadian court may be enforced in the same manner as a domestic judgment.

As previously discussed, simple money judgments are the most straightforward to enforce. Non-monetary judgments may be enforced if comity requires it and if the Supreme Court's analysis in Pro Swing, referenced in 3.1 Legal Issues Concerning Enforcement of Foreign Judgments, has been applied successfully. Non-monetary judgments include judgments to enforce an order for specific performance, an injunction order, an order establishing a constructive trust, an order for declaratory relief and various orders in the context of insolvency.

Foreign judgments granted by courts without proper jurisdiction will not be enforced. The foreign court must have had a real and substantial connection with the litigants or the subject matter of the dispute or otherwise had jurisdiction based on one of the "traditional" bases, such as consent/attornment.

Also, Canadian courts will not recognise or enforce foreign judgments relating to foreign public laws, foreign taxes and penal or quasi-criminal matters.

In addition, as established by the Supreme Court of Canada in Beals v Saldanha [2003] 3 SCR 416, Canadian courts will refuse recognition and enforcement if the foreign judgment:

  • was obtained by fraud going to the jurisdiction of the foreign court or new allegations of fraud that were not the subject of prior adjudication (eg, based on material facts not previously discoverable that potentially challenge the evidence put before the foreign court);
  • is contrary to Canada's concept of natural justice ꟷ the foreign court's procedures did not allow for due process in the form of adequate notice and sufficient opportunity to be heard; or
  • would be contrary to public policy ꟷ it is contrary to the Canadian concept of justice, which turns on whether a foreign law is contrary to Canada’s view of basic morality such that enforcement of the monetary judgment would shock the conscience of a reasonable Canadian.

In order to recognise and enforce a foreign judgment at common law, the party seeking such redress should commence a proceeding. The originating process must be served personally or by an alternative to personal service on the debtor.

If the judgment debtor is domiciled outside of the province where enforcement is sought, the method of service will depend on whether the debtor is located in a country that is party to the Hague Convention of Service Abroad of Judicial and Extrajudicial Documents in Civil or Commercial Matters.

If the material facts are not in dispute, the foreign judgment may be enforced summarily, based on affidavit evidence demonstrating that the judgment was obtained from a court having proper jurisdiction and that none of the defences to enforcement were established on the facts. If the judgment debtor resists enforcement because of credibility issues or otherwise requires a trial, the court may decline to decide the matter on a summary basis.

If the enforcement of a foreign judgment is unopposed, enforcing the judgment should be by default proceedings and therefore simpler. Foreign defendants tend to have a maximum of 60 days from the service of an originating process to defend the proceeding. Where there is no statutory regime to register the foreign judgment, the length of time to enforce a foreign judgment can vary significantly, depending on whether the enforcement proceeding is opposed and, if so, the nature and extent of the defences raised. That said, generally speaking, enforcement proceedings are much more streamlined and efficient than regular lawsuits, since the merits of the dispute are not re-litigated before the Canadian courts. Therefore, the scope of the relevant documents and issues to be resolved is much narrower. A straightforward enforcement proceeding that is defended may be brought to court for a dispositive hearing within twelve months. More complex matters will take longer. Parties will also have to account for potential court backlogs resulting from the Covid-19 pandemic.

The legal fees and disbursements for an enforcement proceeding can also vary widely, depending on the complexity of the matter and the specific defences raised. Canadian court filing fees are minimal. Disbursements relating to enforcement can vary substantially.

The recognition and enforcement of foreign judgments may be challenged only on narrow grounds. If the foreign court had proper jurisdiction over the foreign proceeding and the judgment was final and conclusive on its merits, it cannot be challenged for error of fact or law. Canadian courts will not consider or re-evaluate the merits of the case.

The grounds upon which the enforcement of a foreign judgment can be challenged in Canada are:

  • fraud;
  • a denial of natural justice; and
  • enforcement would be contrary to Canadian public policy.

As discussed above, if the foreign court assumed jurisdiction because of fraud, Canadian courts will refuse to recognise and enforce the judgment. However, to challenge enforcement due to fraud going to the merits of the case, the moving party must show that the fraud was not discoverable before obtaining the judgment in the foreign jurisdiction. In other words, if a party detects fraud in the original proceedings, that party must raise those concerns in the original proceedings. Also, if the respondent chose not to participate in the foreign proceeding, they may be barred from challenging enforcement in Canada on the ground that the evidence given in the foreign proceeding was fraudulent and the fraud could not have been discovered by reasonable diligence.

In order to establish the defence of a denial of natural justice, the debtor must show that the applicant obtained the judgment in a manner inconsistent with Canadian notions of fundamental justice (Beals v Saldanha, 2003 SCC 72). The following safeguards form the Canadian notions of fundamental justice:

  • adequate notice of the claim;
  • an opportunity to defend;
  • judicial independence; and
  • ethical rules governing the behaviour of the participants.

Canadian courts will also refuse to enforce a judgment that is contrary to public policy, but only in exceptional circumstances (Beals v Saldanha, 2003 SCC 72). The public policy defence will not bar enforcement of a foreign judgment for the sole reason that the claim in the foreign jurisdiction would not yield comparable damages in Canada. The public policy defence is directed at the concept of repugnant laws, not repugnant facts.

A party may also resist recognition and enforcement of a foreign judgment if the party seeking redress did not commence the enforcement proceedings or register the foreign judgment within the time limit prescribed by the applicable limitation periods. In Canada, limitation periods are created by statute and vary between provinces. In addition, the limitation period for the enforcement of foreign judgments also varies; the basic limitation periods in Canada usually range from two to six years. In Ontario, the limitation period to recognise and enforce a foreign judgment under the Reciprocal Enforcement of Judgments Act, R.S.O. 1990 c. R.5 and the Reciprocal Enforcement of Judgments (UK) Act, R.S.O. 1990, c. R.6 is six years from the date when the judgment was prescribed. If the foreign judgment was delivered under the common law, the general limitation period of two years applies from the date the foreign judgment was delivered (Commission de la Construction du Québec v Access Rigging Services Inc. 2010 ONSC 5897). It is important to obtain advice early on with respect to the applicable limitation period to enforce a foreign judgment.

Canadian courts readily enforce both domestic and international arbitral awards subject to limited grounds of refusal.

The applicable set of rules to recognise and enforce an arbitral award in Canada depends on whether the award is domestic or foreign. In addition, each province's rules on enforcement vary slightly, so particular attention must be paid to the subtle variations across the country.

Most Canadian provinces are subject to domestic and international arbitration legislation, each of which governs the enforcement of domestic and international arbitral awards. In common law provinces (all but Quebec, which has a code-based civil law system), an arbitration is international if the arbitration was held outside of Canada, if the parties have their places of business in different countries, or if a substantial part of the obligations under the contract were performed outside of Canada. In Quebec, an arbitration is foreign if the seat of the arbitration lies outside Quebec. The recognition and enforcement of foreign arbitral awards is governed by the applicable international arbitration acts adopted by the provinces. Canada has passed the United Nations Foreign Awards Convention Act, RSC, c.16 (2nd Supp.), implementing the United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards, 10 June 1958, UNTS 330 at 3 (entered into force on 7 June 1959) (the New York Convention). Canada adopted the reservation to limit recognition to arbitral awards that are "commercial". Every province has passed their own foreign enforcement legislation, implementing the New York Convention.

Canada has also passed the Commercial Arbitration Act RSC 1985, c. 17 (2nd Supp.), which adopts the UNCITRAL Model Law on International Commercial Arbitration (1985) (the Model Law). The provinces have also adopted the Model Law, with Ontario and British Columbia adopting the Model Law's 2006 amendments.

Canada is a party to and has implemented the 1965 Convention on the Settlement of Investment Disputes between States and Nationals of Other States, 18 March 1965 (entered into force on 14 October 1966). (ICSID).

As described in more detail in 4.2 Variations in Approach to Enforcement of Arbitral Awards, final awards obtained by tribunals with jurisdiction over the arbitral proceeding will be enforced, subject to very narrow defences.

As discussed in 4.1 Legal Issues Concerning Enforcement of Arbitral Awards, the biggest distinction is between domestic and international awards. However, in both cases courts give deference to the arbitration tribunal and will enforce the award, subject to limited grounds to refuse recognition and enforcement. In all cases, the enforcing court has no power to deal with the merits of the underlying arbitration.

Generally speaking, and under the domestic Arbitration Act, 1991 S.O. 1991, c. 17, the court "shall" grant judgment enforcing the award made in the province unless:

  • the award is not final, and the period to commence an appeal or an application to set the award aside has not passed;
  • there is a pending appeal, an application to set aside the award or an application to declare the award invalid; or
  • the award has been set aside or the arbitration is the subject of a declaration of invalidity.

In order to recognise and enforce an arbitral award from another Canadian province in Ontario, the same test applies, with the added requirement that the subject matter of the award must be capable of being the subject of arbitration under Ontario law. While all Canadian provinces’ courts readily enforce awards from their own or other Canadian provinces, there are differences in the procedures and tests, which need to be considered, depending on where enforcement of the award is sought.

ICSID awards will typically be recognised as binding and the monetary obligations of the award will be enforceable as if they were a final judgment of a domestic court.

Domestic arbitral awards that extend to parties who are not bound by the arbitration agreement and who have not attorned to the jurisdiction of the arbitral tribunal will not be enforced.

Generally, the Canadian courts will not enforce a domestic or international arbitral award if the subject matter of the arbitration is not capable of being settled by arbitration under the applicable laws where enforcement is being sought.

The courts will not recognise or enforce an international arbitral award if enforcement would be contrary to Canadian public policy.

Under most domestic arbitration acts, a party can simply apply to the court to have its domestic arbitral award enforced. The limitation period to commence enforcement proceedings varies between Canadian provinces, from two to ten years. In some Canadian jurisdictions (eg, British Columbia and Nova Scotia), the process is framed in terms of leave of the court being required to enforce a domestic arbitral award. Regardless, the process is streamlined and is intended to facilitate the enforcement of awards subject only to very narrow caveats. Also, the court's decision on whether to grant or deny an application to enforce a domestic arbitral award may be appealed.

In order to enforce an international arbitral award, the enforcing party must apply to the applicable court. The application must include the original or a copy of the award, together with the arbitration agreement, attached as exhibits to an affidavit. Neither the New York Convention nor the Model Law sets out limitation periods for the enforcement of a foreign arbitral award. However, pursuant to the New York Convention, each contracting state is required to enforce arbitral awards in accordance with the rules of procedure in the jurisdiction where the party seeks to enforce it. The Supreme Court of Canada has held that the rules of civil procedure of the jurisdiction where enforcement of the foreign arbitral award is sought will apply to those proceedings (Yugraneft Corp. v Rexx Management Corp., 2010 SCC 19). The result is that limitation periods for the enforcement of foreign arbitral awards will vary, depending on the province in which enforcement is sought.

The costs and time to enforce domestic or international arbitral awards depend on the case. A straightforward application may take eight to twelve months (or longer depending on court backlog related to Covid-19). However, if the defence to enforcement proceedings raises serious issues that could, for example, involve a significant inquiry into whether the enforcement could offend public policy (eg, underlying criminality not previously raised before the tribunal), the enforcement proceedings could take much longer. Also, if the party seeking enforcement pursues interlocutory relief (eg, a Mareva injunction to freeze assets) and such steps become subject to set-aside proceedings or other challenges, the progress of the enforcement proceeding will be adversely impacted. In addition, jurisdictional issues related to service can also delay proceedings. Costs for court filings are modest.

Most provinces have legislation that sets out the limited circumstances in which the enforcement of a domestic arbitral award can be challenged. These limited circumstances include where there is a pending appeal of the award, a pending application to set aside the award, or a pending application for a declaration of invalidity. Where the period to appeal, set aside the award, or apply for a declaration of invalidity has not elapsed, the court may enforce the award or stay enforcement until the period has elapsed or until the pending proceeding is finally disposed of.

In addition, the recognition and enforcement of a domestic award can be challenged on the following narrow grounds:

  • absence of notice to the other party;
  • the award deals with a dispute outside the scope of the arbitration agreement; or
  • there is a breach of public policy.

International arbitral awards can be challenged under the limited grounds of Article 36(1)(a)(ii) of the UNCITRAL Model Arbitration Law or Article V of the New York Convention, where the party resisting enforcement can prove that:

  • a party to the arbitration was under some incapacity or the agreement was not valid under the law of the seat of arbitration where the award was made;
  • the party against whom the award was invoked was not given proper notice of the appointment of an arbitrator or of the arbitral proceedings, or was otherwise unable to present his or her case;
  • the award deals with a dispute not contemplated by or not falling within the terms of the submission to arbitration, or it contains decisions on matters beyond the scope of the submission to arbitration;
  • the composition of the arbitral tribunal or the arbitral procedure was not in accordance with the agreement of the parties or, in the absence of such an agreement, was not in accordance with the law of the country where the arbitration took place; or
  • the award has not yet become binding on the parties or has been set aside or suspended by a court of the country in which, or under the law of which, that award was made.

In addition, enforcement may be refused if the court finds that:

  • the subject matter of the dispute is not capable of settlement by arbitration under the law of the state where enforcement is sought; or
  • the recognition or enforcement of the award would be contrary to the public policy of the state where enforcement is sought.

The public policy ground to refuse enforcement of a foreign arbitral award has been narrowly construed. The public policy defence is "to guard against enforcement of an award which offends our local principles of justice and fairness in a fundamental way … or where there was ignorance or corruption on the part of the tribunal which could not be seen to be tolerated or condoned by our courts" (Schreter v Gamac Inc., [1992] 7 OR (3d) 608).

Baker McKenzie

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Law and Practice in Canada

Baker McKenzie is a leading global law firm, with offices in 78 cities worldwide. The Canadian team has acted on some of the country's most important enforcement cases in the past two decades. The firm's Canadian lawyers are fully integrated with other Baker McKenzie litigators located worldwide. The firm is a highly regarded litigation group in Canada with particular expertise in multi-jurisdictional disputes, including all manner of fraud, financial recovery and enforcement-related disputes. The Canadian group provides clients with co-ordinated litigation, arbitration and enforcement services nationally and internationally. To appreciate the depth of the Canadian group's fraud law, enforcement and asset tracing expertise, visit their blog-site at: www.canadianfraudlaw.ca


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Product owners effect on tech culture with Mike Gertrudes

Cover Image for Product owners effect on tech culture with Mike Gertrudes
Pragmatic Lead Podcast Team
Pragmatic Lead Podcast Team

A little background on us

We are thrilled to share our conversation with Mike Gertrudes. We spent many years sharing, the DEAL DISRUPTOR for the travel industry, and cutting our teeth on modern technology. As we part ways, we like to stay in touch and share adventures. We want to thank all of our peers and the great people we get to work with every day while we continue to share our professional experiences with all of you.

This episode

Our guest is Mike Gertrudes, VP, Head of Engineering at Billie | The Body Brand.

We speak with Mike regularly, and recently Mike shared with us that a change in his office dynamics had a significant effect on his engagement at work and quality of life. When we asked him what changed, Mike told us it was about a new product owner that recently joined the company.

We had to book Mike for this chat; we believe that a strong team requires everyone to participate. From this episode, we hope to inspire you to see how powerful a united team can be for the sake of creating excellent products and enjoying professional relationships.

Additional notes

Around the 7:30 mark during our conversation, we couldn't remember Conway's Law.

"Any organization that designs a system (defined broadly) will produce a design whose structure is a copy of the organization's communication structure."

— Melvin E. Conway

Guest Profile

Mike Gertrudes VP, Head of Engineering at Billie

Previous roles include Director of Engineering for brands like, tech leader, and entrepreneur.

Contact Mike Gertrudes for
  • Coaching and advice for professional development.
  • Join Mikes's team at Billie.

How to contact Mike Gertrudes

Have a story to tell?

If you are interested in joining us for a conversation on the podcast or if you are looking for professional coaching, connect with us at Pragmatic Lead or consider subscribing to our newsletter.


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Institutional Audit and Targeted Actions

Kim Ryan, Vice President Human Resources
Joyce Sackey, Associate Provost and Chief Diversity Officer

To identify and remove structural racism from all processes, procedures and practices within all schools, units and levels of the University.

Charge and Approach:

The Charge

  • Identify where structural racism exists within processes, policies, programs and procedures across all schools and units of the University e.g. recruitment outreach programs, targeted communities for recruitment of faculty, staff, students and student-athletes.
  • Utilize a consistent framework to audit all schools and units.
  • Recommend prioritized targeted actions to remove structural racism including the accountability and transparency needed to deliver the agreed-upon actions.
  • Identify and implement specific actions having an immediate positive effect on our community, and build momentum towards our long-term objectives and strategy
  • Build upon and learn from the anti-racism work in which many departments are already engaging.
  • Analyze the ways in which the history of racism is relevant to Tufts and inform the work of the other workstreams e.g. the role Tufts history has played in slavery and racism.

Our Approach

  • Establish a Steering Committee with members across multiple levels and multiple schools/units (including student representation)
  • Engage a consulting partner as a thought leader to provide expertise, framework and tools as well as provide the needed resources assist to complete this work

Key Questions to Address

  • Where does structural racism exist and what is the impact to the University?
  • What visible actions can be taken to eliminate racism within the scope of this workstream?
  • How do we build alignment and accountability for making the recommended changes?
  • How do we build in structures that ensures the work of antiracism is sustainable?

Committee Structure:

Co-Chair- Kim Ryan, VP for Human Resources
Co-Chair- Joyce Sackey, Associate Provost and CDO, Health Sciences campuses

Steering Committee

  • The Steering Committee will be comprised of faculty, staff and students
  • Faculty and Staff members of the Steering Committee will also serve as the subcommittee Chair for their respective school/unit. They will establish a team for their school/unit and will have a consulting partner to provide support and guidance throughout the process.
  • Members
    • Tom Malone, Executive Associate Dean, School of Medicine
    • Dan Volchok, Associate Dean, Graduate School of Biomedical Science
    • Maribel Blanco, Executive Associate Dean, Fletcher School of Law and Diplomacy
    • Diane Ryan, Associate Dean Programs & Administration, Tisch College
    • Sara Booth, Director, HNRCA
    • Bárbara Brizuela, Dean of Academic Affairs, School of Arts & Sciences
    • Brandon Mennillo, Director of Administration, School of Engineering
    • Dr. Flo Tseng, Professor and Assistant Dean for Diversity, Inclusion, Equity, and Climate, Cummings School of Veterinary Science
    • Krissy Day, Director of Business Operations, Friedman School of Nutrition Science and Policy
    • Dr. Jeanette Sabir-Holloway, Assistant Dean, School of Dental Medicine
    • Ian Canning, Deputy Executive Associate Dean, University College
    • MJ Kim, Senior Director of Marketing, University Communications & Marketing
    • Celia Campbell, Administrative Associate Provost, Provost’s Office
    • Kara Charmanski Squillacioti, Senior Director of Administration, Office of the Vice Provost
    • John Morris, Director, Athletics
    • Sara Judge, Vice President for Development, University Advancement
    • Lisa Halpert, Senior Director of Financial Planning, Office of Budget and Planning
    • Thom Cox, Director, Design Practice, Tufts Technology Services
    • Donna Golemme, Executive Director, Operations
    • Anne Spangler, Director of Planning & Projects, Human Resources
    • Two Students (Undergrad and Grad)
    • Accenture Consultant Partner (TBD)
  • Additional Resources to Steering Committee Members include:
    • Librarian
    • Historian
    • Office of Institutional Research
    • Communications/Staff support

Community Engagement:
The Steering Committee will be representative of the community. As noted above, we look to establish small working groups within schools and other units to participate in the audit process along with dedicated consultants.  Responsibilities include:

  • Lead a team of representatives for their school/unit/department to identify and describe the processes, procedures and practices to audit. The team includes faculty, staff and students
  • Gather and analyze the information/data
  • Recommend targeted actions based on the analysis
  • Provide focus group support Identify focus group participants
  • Participate in weekly Steering Committee meetings
  • Partner with external consultant

We will create a forum for continuous input and feedback from faculty, staff and students. (Website. Q&A. focus groups, etc.)

Timeline and Deliverables:

  • Steering Team Identified: 10/7
  • Consultant Decision: 9/17
  • Consultant vetted through the Procurement Process: week of 10/19
  • Kickoff: week of 10/19

We plan to post updates on the Tufts website and invite the community to make comments and suggestions. The website will be updated on a biweekly basis. In addition, we plan to provide updates a Town Halls, Academic and Administrative Councils throughout the course of the audit and will communicate existing initiatives for schools and units to consider.  We will invite schools and central units to similarly share their targeted actions as a way of disseminating best practices across Tufts.

We plan to update the senior team on our progress every 4 weeks and as needed.


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View Full Version : Sky/Freeview Coax cabling

05-06-2012, 03:37 PM
Hi all,

I'm going to be helping some friends who are doing some renovations on their house, mainly with cabling for home theater etc. As well at cat6 + speaker cabling, I'm planning on doing 2 runs of coax down the wall to where the TV is going - one for the sky dish and one for the UHF aerial which I'll install (for freeview HD).

I did have a 100m roll of RG6, it was the 'sky grade' stuff, and it's worked a charm. I want to get another roll, but problem is I can't remember what exactly it was - is dual shield the stuff I should be after?

Like that? Thanks. :)

05-06-2012, 03:46 PM
Another thing too actually - I use twist on F-connectors, as i don't have a crimping tool, but they aren't really ideal. I often find that a lot of the braiding on the coax has ripped off while the connector is being twisted on. Any tips or tricks to overcome this?

05-06-2012, 04:37 PM
I thought all RG6 had to conform to the same standard (diameter, loss in db/m, shielding) so that was all you needed to know. I wasn't aware there could be different grades of RG6. And the braid damage is largely unavoidable. It's only a problem if you take the connector off again really. As long as enough of the braid is in contact with the connector to make good electrical contact everything is fine.

05-06-2012, 04:41 PM
Thanks dug, I was under the impression quad shield was actually a bit bigger diameter, and was tricky to work with if standard size plugs etc were being used. Have grabbed the dual shield.

05-06-2012, 04:52 PM
Well I may be wrong, but my understanding is that if it is larger in diameter or has extra layers of shielding then it's not RG6 but some other standard. The point of cable standards is to make them all compatible so you can't have different variations. Or at least you shouldn't. In my industry we used to use a lot of coax and as long as it was the right standard it didn't matter who made it. Our single screen and double screen cables had different names (which I forget but I'm not talking about TV coax so it's not important).

05-06-2012, 04:55 PM
Sweet as. :thumbs:

05-06-2012, 05:14 PM
You should invest in a crimper and use crimp F Connectors. They are not hugely expensive, and are easy to use.
TradeMe or Jaycar sell them

05-06-2012, 06:05 PM
I am pretty tempted to....like so?

05-06-2012, 08:25 PM
Jaycar has crimp tools at a much better price.


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Hahnville Track, Field and Pole Vaulting

Kollin Rubin

Upcoming interview featuring track and field athlete turned Pole Vaulting Star, Bradon Davidson. During the featured interview conducted by Kollin Rubin, Davidson expressed his transition from track and field to pole vaulting. Davidson will inform viewers of his commitment to practice while competing in track and field. Davidson states he has been interested in pole vaulting since his freshman year. He will discuss his long term goals of obtaining the ability to pole vaulting 14-6 because currently, he states, he is at 13.

     Although Davidson states he loves pole vaulting, he would love to return to track and field if he is able to obtain a scholarship for college. As I have researched, pole vaulting is apart of a track and field event.  Both, track/field and Pole Vaulting requires running, speed, strength, and agility. All in which, Davidson prepares for independently and with his teammates.


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Butt Augmentation in Doylestown, PA

40 Procedures ( View All )

WHAT IS Butt Augmentation?

Whether you have a naturally flat rear end or simply desire more shape and volume, butt augmentation can help you achieve a more curvaceous figure. This advanced cosmetic surgery utilizes silicone implants to add volume to your backside and enhance your body line by creating a more attractive silhouette. Nowadays, both men and women desire the sexy appearance of a fuller behind, which is the reason why Prestige Institute for Plastic Surgery in Doylestown, PA is pleased to offer butt augmentation surgery with silicone implants. If you desire a more voluptuous backside, our board-certified plastic surgeon Dr. Joseph Tamburrino can create a unique treatment plan that will address your unique concerns. Contact our friendly team to learn more about butt augmentation surgery.

Individuals all across Doylestown, PA meet often with Dr. Tamburrino to gain more information about butt augmentation. The best candidates for this surgical procedure are those who meet the following criteria:

  • Are in overall good health
  • Have great elasticity in their skin
  • Desire a more curvaceous or larger buttocks
  • Are not candidates for a Brazilian butt lift

Prestige Institute for Plastic Surgery is proud to offer a variety of implant sizes and shapes to meet your unique aesthetic goals. Our most popular implants are silicone elastomer implants because they produce a natural, firm outcome. All of your options will be discussed with you during your one-on-one with Dr. Tamburrino in which he will help you select the implants that best complement your silhouette and goals. To perform your procedure, small incisions will be strategically created within the natural fold of the backside, and your implants will be placed securely in the ideal position. To finalize the procedure, the incisions will be sewn and bandaged. Gluteoplasty is typically performed under general anesthesia as an outpatient procedure, therefore not requiring an overnight stay.

What to Expect

After your procedure, it is not uncommon to feel minor pain and experience swelling and bruising for several days. Drainage tubes will likely be placed and worn for an entire week to allow blood and fluid to be properly expelled for optimal healing. You can usually return to your daily activities within 2 – 3 weeks, but you should avoid any strenuous activity or exercise for 6 – 8 weeks. Dr. Tamburrino is highly skilled in the placement of implants for gluteal enhancement so many patients are pleased to find that their scars are barely visible. Since the incisions are made within the folds of the buttocks, you will feel even more confident and sexy in your bikinis knowing that your scars are not visible to the naked eye. To maintain optimal results, you should continue practicing a healthy diet and exercise regimen.

Do butt implants last longer than fat transfer?
During your initial consultation, the benefits and drawbacks of both implants and fat transfer will be discussed by Dr. Tamburrino so you can choose which one is better for you, depending on your concerns and goals. He will discuss what you should do to maintain the results of a fat transfer and implants so you can decide which procedure better fits your lifestyle. For both techniques, it is important for you to remain at a healthy, stable weight after surgery.

Will weight gain affect my results?
Significant weight gain may alter the results of your butt augmentation surgery. The contour and shape of your butt may change if you gain or lose a large amount of weight after surgery. Dr. Tamburrino suggests you follow a balanced diet and exercise routine to help preserve the results of your butt augmentation.

What can I expect during my recovery?
In the first few weeks following your augmentation, you may experience some discomfort as your body heals. You should cease any strenuous activity until given permission by Dr. Tamburrino to resume your normal exercise schedule. Additionally, you need to attend follow-up visits during your recovery so he can evaluate the implants to ensure that you're healing properly.

What is the difference between a butt augmentation and a Brazilian butt lift?
A butt augmentation uses a silicone implant to add volume while a BBL (Brazilian butt lift) transfers fat from another area of the body to the buttocks. Good candidates for a Brazilian butt lift must have enough unwanted body fat to reach their goals. If you don't have enough excess fat, a buttocks augmentation with an implant may be your best option.

Better Butt with Implants

Nowadays, a shapely, curvy butt is more desirable by both men and women. Whether you were born with a naturally flat backside or have experienced a decrease in volume due to weight loss or age, it's possible to achieve the attractive silhouette of your goals. When diet and exercise have been unsuccessful in molding your rear end, contact Prestige Institute for Plastic Surgery and learn about your options for butt augmentation at our Doylestown, PA practice.

Related Procedures

*Individual results are not guaranteed and may vary from person to person. Images may contain models.


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Digital Scrapbooking Challenge in January

Just for the month of January, I’m going to give some of my time to digi-scrapping.  It’s been a very long time (it feels that way) since I’ve done any digi-scrapping.  I’ve been purchasing digital kits since 2010 but within the last year or two I’ve slowly tapered down to creating nothing, but still buying the kits!  So, to start off the year, I’m going full force with putting these kits to good use.  Then, come February, I will stop and move on to other things.  A part of me really just want to put some of these kits to good use.  I have goals of making stickers with the embellishments (elements) to use in my planners and maybe other crafts but I honestly don’t think I can digi-scrap like I used to.  I am also continuing with Project Life (PL) but I won’t be doing weekly anymore.  I am pretty far behind by…3 years?  I’m going to try doing more of the app PL than paper PL, although I do have quite a few paper PL kits and I don’t think I can ever give up paper PL.

This challenge I’m doing is at the Lilypad digital scrapbooking forum.  The challenge is called Month of Challenges or MOC and what you do is create a digital layout each day for 31 days straight.  Admins will give the requirements for each layout per day and you just have to follow the requirements.  You don’t have to create one a day but you have to have 31 completed layouts by the end of January.  If you complete this challenge, you get a $20 credit toward the shop.  I’m always looking for deals and I love the designs at the Lilypad so that’s what hooked me.  I also wanted some motivation to keep at this hobby because I still do enjoy digi-scrapping.  Here are the first four layouts I’ve done:

Day 1

Day 2

PlannerGoalsList_01022016_600Day 3

Day 4

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