title: Pam Shriver

text: Shriver was born in Baltimore, Maryland, to Sam and Margot Shriver. She first started playing tennis at the age of three. She graduated from McDonogh School in Owings Mills, Maryland. She is a minority owner of the Baltimore Orioles and is active in various charitable organizations. Her first husband, Joe Shapiro, a former Walt Disney Company lawyer, died of non-Hodgkin's lymphoma in 1999.


title: Pam Shriver

text: In 2002, Shriver married actor George Lazenby. She gave birth to their first child, George Junior, on July 12, 2004, and to twins Kate and Sam on October 1, 2005. The family lived in Brentwood, California. In August 2008, Shriver filed for divorce from Lazenby after six years of marriage. Their divorce was finalized in May 2011.


title: Pam Shriver

text: Shriver has two sisters—Marion, who died from cancer in 1997, and Eleanor who lives in Maryland. She is a fourth cousin of Maria Shriver, the former First Lady of California and niece of President John F. Kennedy.


title: Pam Shriver

text: Shriver is an ambassador for Up2Us Sports, a national non-profit organization dedicated to supporting underserved youth by providing them with coaches trained in positive youth development.


title: Pam Shriver

text: In 2021 Shriver became a supporter of the new Women's Sports Policy Working Group formed in response to President Joe Biden's executive order that mandates inclusiveness for transgender female athletes.


title: Darren Fletcher

text: Darren Barr Fletcher (born 1 February 1984) is a Scottish football coach and former professional player who is currently the technical director of Manchester United, where he spent the majority of his playing career. He mostly played as a central midfielder, but began his career as a right winger and also featured occasionally in defence.


title: Darren Fletcher

text: Fletcher came through the ranks of Manchester United's Youth Academy and spent 20 years with United, making 342 appearances for the club. With them, he won five Premier Leagues, one FA Cup, two League Cups, the UEFA Champions League, four FA Community Shields and the FIFA Club World Cup. Fletcher was included in the PFA Premier League Team of the Year for 2009–10. He was named vice-captain in his last season with the club. He joined West Bromwich Albion in February 2015, where he made 97 appearances. After leaving Albion in 2017, Fletcher had a two-year stint with Stoke City. He returned to Manchester United in a coaching capacity in October 2020, working with the club's under-16s players, before being appointed to the first team in January 2021.


title: Darren Fletcher

text: Fletcher made his full international debut for Scotland in 2003, and scored his first international goal on his second appearance. The following year, he played as the team's youngest captain for over a century. After Barry Ferguson was banned from international football because of a breach of regulations, Fletcher was given the captaincy on a full-time basis in August 2009. In total he won 80 caps and scored 5 goals for Scotland.


title: Darren Fletcher

text: The middle of Fletcher's career was disrupted by an extended break from football due to health problems caused by ulcerative colitis. Between November 2011 and December 2013, he played only ten times for his club, undergoing an operation in early 2013 to lessen the effects of the condition after a failed return in September 2012.


title: Darren Fletcher

text: Fletcher was born in Dalkeith and raised in Mayfield near Edinburgh. He was educated at St Luke's RC Primary School and St David's RC High School in Dalkeith.


title: Darren Fletcher

text: Fletcher played his youth football at Hutchison Vale, Tynecastle Boys Club and Celtic Boys Club before being scouted by Manchester United. He first joined the Manchester United youth setup at the age of 11, and then signed with the club when he was aged 15. Fletcher said in 2020 that he had almost signed for Newcastle United instead, as some people advised him it would be harder to break into the Manchester United first team.


title: Darren Fletcher

text: He progressed quickly with Manchester United, and could have become the youngest player ever to appear in their first team when he was selected in their squad for the final fixture of the 1999–2000 FA Premier League season, against Aston Villa on 14 May 2000. This plan was stymied as Premier League rules prohibited players on schoolboy contracts from appearing at the senior level, and his debut was delayed. He had been part of the reserve team that won the Manchester Senior Cup in 1999–2000. Fletcher was initially seen as a right midfielder, similar to David Beckham, and was tipped by many to break into the first-team with ease and stay there for many years to come. As he developed he came to be viewed more as a central midfielder.


title: Darren Fletcher

text: Over the next couple of seasons, Fletcher's involvement was limited due to various injuries, including a broken foot. Nevertheless, by the 2002–03 season, he had become a regular member of the reserve team, and after several appearances as an unused substitute, he finally made his first-team debut on 12 March 2003 – almost three years behind schedule – starting on the right side of midfield against Basel in the second group stage of the UEFA Champions League. He was substituted for David Beckham after 73 minutes, but a second Champions League appearance followed against Deportivo de La Coruña a week later, and he was named as a substitute for both legs of the quarter-final tie against Real Madrid. For his performances for the reserve team during the 2002–03 season, Fletcher received the Denzil Haroun Reserve Player of the Year award.


title: Darren Fletcher

text: Fletcher broke into the Manchester United team during the 2003–04 campaign, playing a number of important matches and starting in United's FA Cup Final win over Millwall in May 2004. Despite a slow start to the 2004–05 campaign, in which in the early part of the season he made very few competitive appearances, Fletcher again broke into the United first-team. On 1 January 2005, Fletcher scored his first goal at club level in a 2–0 win over Middlesbrough.


title: Darren Fletcher

text: Fletcher was one of the players singled out for criticism by club captain Roy Keane in the wake of United's 4–1 defeat to Middlesbrough in October 2005. Keane reportedly said, "I can't understand why people in Scotland rave about Darren Fletcher." However, Keane later attempted to set the record straight stating, "If you listen to any of my comments over the last two or three years, if I've given any player credit over the years it would be Fletch. Fletch will tell you that himself." Fletcher went some way towards answering his critics on 6 November 2005, with his performance in the vital league match at home to Chelsea, scoring the only goal of the game with a looping header. His winning goal ended Chelsea's 40-match unbeaten run in the Premier League.


title: Darren Fletcher

text: In 2006–07, at the start of the season Fletcher retained a place in the first-team but only on the bench and scored in an away win over Charlton Athletic, as well as scoring the headed winner in the away game with Middlesbrough in December and another headed goal in the home win against Charlton in February, making it a double against the club that season. As the season progressed, Alex Ferguson preferred the midfield quartet of Cristiano Ronaldo, Paul Scholes, Michael Carrick and Ryan Giggs, limiting Fletcher to a few substitute appearances. However, with Scholes absent through suspension, he made a starring appearance in United's 7–1 win over Roma in the Champions League quarter-final.


title: Darren Fletcher

text: In the 2007–08 season, with the arrival at the club of fellow central midfielders Owen Hargreaves and Anderson and winger Nani, Fletcher played even less than he did during the previous season. As before, Ferguson preferred Carrick, Scholes, Giggs and Ronaldo to him in midfield, and got even less playing time than the new arrivals. He did, however, put in some stalwart performances when given the chance, including two goals in the 4–0 defeat of Arsenal at Old Trafford in the FA Cup fourth round. Fletcher picked up a Champions League winner's medal but was an unused substitute in the final.


title: Darren Fletcher

text: In the 2008–09 season, Fletcher started the first two games, due to injuries to Carrick and Ronaldo, and scored against Newcastle United at Old Trafford in United's first Premier League match of the season, forcing a 1–1 draw after Obafemi Martins' goal. Fletcher notched his second goal of the season opening the scoring from close range against Portsmouth, following a pass from Patrice Evra. He was later shown a yellow card on the 93rd minute before the match ended 1–0. On 3 October 2008, Fletcher signed a three-year extension to his contract with Man Utd, keeping him at the club until 2012. Fletcher notched his third goal of the season against Everton on 25 October. He then scored in the Club World Cup semi-final against Gamba Osaka on 18 December after coming off the bench.


title: Darren Fletcher

text: In the Champions League semi-final second leg against Arsenal on 5 May 2009, Fletcher was sent off, ruling him out of the Champions League Final. Manchester United appealed to UEFA to have the red card overturned on compassionate grounds on 7 May 2009, but this was rejected on 11 May. Then-Inter Milan coach José Mourinho commented on his absence: "Fletcher is more important than people think ... he 'eats' opponents in defensive transition. I believe Xavi and Andrés Iniesta are happy Fletch is not playing."


title: Darren Fletcher

text: The 2009–10 season saw Fletcher consolidate his place in the heart of the United midfield, starting all of United's important games. He opened his scoring account for the season with a double in the first Manchester derby of the season, a memorable 4–3 victory for United, twice putting United ahead before Michael Owen scored in the sixth minute of added time. He won the Man of the Match award for his performance. On 21 November 2009, Fletcher scored his third of the season, hitting a half volley from the edge of the area into the top corner giving United a 1–0 lead against Everton in a 3–0 win. This season also saw Fletcher and fellow midfielders Michael Carrick and Park Ji-sung deputise in defence due to an injury crisis that left Patrice Evra being the only fit regular in defence. They still managed to keep a clean sheet against West Ham United and concede only one goal against Bundesliga champions Wolfsburg in the Champions League. Fletcher was sent off during the match against Birmingham City on 9 January 2010 after two bookable offences. On 10 March, he scored the fourth goal in a 4–0 win in the second leg of United's last 16 Champions League tie with AC Milan, making the score 7–2 on aggregate. Following this, Fletcher captained United for the first time in the league match against West Ham and was later confirmed as United's vice-captain, a position he held until December 2014. In April, Fletcher capped a successful season with selection in the PFA Premier League Team of the Year. On 9 May, the last day of the season, Fletcher scored the first goal of a 4–0 win at home to Stoke City.


title: Darren Fletcher

text: Fletcher made his first start of the 2011–12 season in United's first group stage match on 14 September 2011 in the Champions League away at Benfica, which ended in a 1–1 draw. This was Fletcher's first start for a number of months after being sidelined towards the end of the 2010–11 season with illness, revealed in December 2011 to be ulcerative colitis. He made his first Premier League appearance of the season four days later in a 3–1 home win against title rivals Chelsea. Fletcher maintained his place in centre midfield in the following Premier League games against Stoke and Norwich City. On 23 October, he scored the consolation goal in a 6–1 defeat to local rivals Manchester City, with a curling shot into the top corner.


title: Darren Fletcher

text: Fletcher made his 300th career appearance for Manchester United on 5 November in a 1–0 home win against Sunderland. Fletcher scored United's second goal in a 2–2 draw with Benfica on 22 November in the Champions League. He met Patrice Evra's cross at the first attempt, which the goalkeeper got a hand to and he followed it up on the second attempt to score. Following this match, he announced that he would be taking an extended break from football following medical advice about his ongoing ulcerative colitis. He did not play again in the 2011–12 season.


title: Darren Fletcher

text: On 14 August 2012, Fletcher came on as a second-half substitute, taking the captain's armband, for Manchester United against Aberdeen in Neil Simpson's testimonial. He played his first competitive match in ten months, coming on as a substitute for Paul Scholes in the 78th minute in Manchester United's 1–0 win over Galatasaray at Old Trafford in the Champions League. On 24 November, Fletcher scored his first goal since his illness, a header from a Wayne Rooney corner against Queens Park Rangers. On 17 January 2013, it was announced that Fletcher had undergone surgery aimed at resolving his condition, which would rule him out for the remainder of the season. The statement stressed that this was a "planned procedure undertaken at the optimal time" that required Fletcher to be in good health to be carried out. In his May 2013 retirement speech following his final match at Old Trafford as Manchester United manager, Alex Ferguson wished Fletcher a speedy recovery and return to football. A week later, it was revealed that his surgery had been a success and that Fletcher was on course to return to football in July 2013.


title: Darren Fletcher

text: On 15 December 2013, Fletcher made his first appearance for nearly a year when he came on as a substitute for Ryan Giggs in a 3–0 victory over Aston Villa. Another substitute appearance followed in the 2–0 League Cup win against Stoke City on 18 December, and on 26 December 2013, Fletcher made his first league start for 390 days in a 3–2 win away to Hull City. He was named Manchester United vice-captain by Louis van Gaal in August 2014.


title: Darren Fletcher

text: On 2 February 2015, Fletcher signed for West Bromwich Albion on a free transfer. He made his debut on 8 February 2015 against Burnley, where he was given the captain's armband. He scored his first goal for the club on 11 April 2015 against Leicester City, although the Baggies lost 3–2. Between his debut for West Brom in February 2015 and the international break of October 2015, Fletcher did not miss a minute of Premier League football, marking fully his comeback from several illness-disrupted seasons.


title: Darren Fletcher

text: He scored his second goal for West Brom on 28 December 2015, in a 1–0 win against Newcastle United. Fletcher had to wait until the 2016–17 season for his next Premier League goal to come. It finally came in a 4–0 win against Burnley on 21 November 2016. He scored his second goal of the 2016–17 season on 21 January 2017, in a 2–0 win against Sunderland. A game against Stoke City, on 4 February 2017, marked his 300th game in the Premier League. Former manager Sir Alex Ferguson hailed him as a "fantastic professional and fantastic human being."


title: Darren Fletcher

text: On 1 June 2017, Fletcher signed a two-year contract with Stoke City, effective from the expiration of his West Bromwich Albion contract on 1 July. He made his debut on 12 August as the team began their season with a 1–0 loss at Everton, playing the full 90 minutes. Local newspaper "The Sentinel" praised his passing in the match. Fletcher started in the first nine games of the 2017–18 Premier League season for Stoke, extending a streak of consecutive league appearances to 100. He became the eighth outfield player to achieve this mark in the Premier League era. Fletcher scored his first goal for Stoke in a 1–0 win away at Watford on 28 October 2017. Fletcher played 29 times in 2017–18 as Stoke suffered relegation to the EFL Championship.


title: Darren Fletcher

text: Fletcher struggled for playing time in 2018–19, making 11 appearances under Gary Rowett and then Nathan Jones. He scored the only goal of the game against Bristol City on 27 October 2018. Fletcher left Stoke at the end of the campaign.


title: Darren Fletcher

text: After leaving Stoke, Fletcher began studying for coaching qualifications. He said in November 2019 that he had not officially retired from playing, and did not yet feel ready to begin a career in management. In May 2020 he acknowledged that he "probably" wouldn't play again, and said that his medical condition (ulcerative colitis) meant that he would be at higher risk from COVID-19.


title: Darren Fletcher

text: Fletcher established himself as a regular choice for Scotland during the 2003–04 season. He scored his first goal in a 1–0 win against Lithuania, having come off the bench for only his second cap. His goal took Scotland to the play-offs for UEFA Euro 2004. On 26 May 2004, he captained Scotland to a 1–0 friendly win against Estonia in Tallinn, making him the youngest Scotland captain since 17-year-old John Lambie in 1886. Fletcher scored with a 25-yard strike in a 3–0 win against Slovenia on 12 October 2005.


title: Darren Fletcher

text: Fletcher was Scotland's vice-captain under Alex McLeish, deputising in the absence of regular captain Barry Ferguson. Fletcher was named as full-time captain in November 2009 when Ferguson was banned from international football for misbehaviour.


title: Darren Fletcher

text: Fletcher earned his 50th cap in September 2010, in a UEFA Euro 2012 qualifying match against Liechtenstein. His bouts of illness interrupted his international career, which meant that Scott Brown assumed the captaincy. Fletcher was recalled to the international squad for a friendly against Poland in March 2014. He resumed the captaincy in September 2016, after Brown had temporarily retired from international football.


title: Darren Fletcher

text: In November 2019, Fletcher said he aspired to a future in management. In October 2020, Fletcher returned to Manchester United to coach their under-16s players, and in January 2021, he was promoted to first-team coach. In March 2021, he became the technical director at Manchester United.


title: Darren Fletcher

text: Fletcher usually played as central midfielder in a box-to-box role, where he stood out for his physicality, tenacity, intelligence, and work-rate, as well as his energy and defensive ability, namely his tackling and marking. He was capable of playing anywhere in midfield, however, and also played as a right winger, in a holding role, and on occasion in defence; at international level, he also played in a more attacking role, due to his ability to get forward, which earned him comparisons with Steven Gerrard. In 2009, Terry Butcher described Fletcher as a "complete midfielder, a rare all-rounder and although he's a slightly different player to Roy Keane, he can become as great." He likened Fletcher to Bobby Charlton, noting that he "can get games by the scruff of the neck and inject pace and tempo," also adding that "[h]e understands the game, reads it well, is improving all the time and United rely heavily on him." While Fletcher was initially criticised in the media for his poor positional sense, a lack of creativity in his game, and his tendency to give possession away carelessly early on in his career, he underwent a technical and tactical development, which enabled him establish himself successfully in a deeper midfield role, from which he could dictate the tempo of his team's play in midfield with his passing; his playing style in this position was influenced by one of his idols, Fernando Redondo.


title: Darren Fletcher

text: In May 2020, former teammate Rooney cited Fletcher as an important member of the successful 2006–09 United side, describing him as being as "vital" to the team as himself, Cristiano Ronaldo, and Carlos Tevez, and saying he sacrificed his own individual acclaim for the team.


title: Darren Fletcher

text: He is the father of twin boys, Jack and Tyler (born 2007) with his wife, Hayley Grice. The couple married in early June 2010. Jack and Tyler, who are both in the Manchester City academy, were selected for the Scotland under-16 squad in August 2022.


title: Darren Fletcher

text: Fletcher was one of many footballers in the Manchester and Liverpool area whose homes were burgled while playing away games; burglars raided his house in February 2009 and held Grice at knifepoint. The incident occurred while Fletcher was in Milan for Manchester United's Champions League fixture against Inter Milan.


title: Darren Fletcher

text: Fletcher's father was caught speeding in Fletcher's Range Rover on the M6 motorway in Cumbria on 27 November 2008. As the owner of the car, Fletcher was ordered to identify the driver of the car, but he failed to do so and was summoned to Penrith Magistrates' Court in January 2010. After a hearing, Fletcher received six penalty points on his driver's licence, a £650 fine and was ordered to pay £900 in costs.


title: Darren Fletcher

text: Fletcher is involved in a programme to encourage "Deaf Friendly Football" for youngsters. The programme is run by the Manchester United Foundation and the National Deaf Children's Society.


title: Darren Fletcher

text: In 2014 Fletcher became an ambassador for the charity Crohn's and Colitis UK after recovering from surgery for ulcerative colitis.


title: Antiphospholipid syndrome

text: Antiphospholipid syndrome, or antiphospholipid antibody syndrome (APS or APLS), is an autoimmune, hypercoagulable state caused by antiphospholipid antibodies. APS provokes blood clots (thrombosis) in both arteries and veins as well as pregnancy-related complications such as miscarriage, stillbirth, preterm delivery, and severe preeclampsia. Although the exact etiology of APS is still not clear, genetics is believed to play a key role in the development of the disease. The diagnostic criteria require one clinical event (i.e. thrombosis or pregnancy complication) and two positive blood test results spaced at least three months apart that detect lupus anticoagulant, anti-apolipoprotein antibodies, or anti-cardiolipin antibodies.


title: Antiphospholipid syndrome

text: Antiphospholipid syndrome can be primary or secondary. Primary antiphospholipid syndrome occurs in the absence of any other related disease. Secondary antiphospholipid syndrome occurs with other autoimmune diseases, such as systemic lupus erythematosus. In rare cases, APS leads to rapid organ failure due to generalised thrombosis; this is termed "catastrophic antiphospholipid syndrome" (CAPS or Asherson syndrome) and is associated with a high risk of death.


title: Antiphospholipid syndrome

text: Antiphospholipid syndrome often requires treatment with anticoagulant medication such as heparin to reduce the risk of further episodes of thrombosis and improve the prognosis of pregnancy. Warfarin (brand name Coumadin) is not used during pregnancy because it can cross the placenta, unlike heparin, and is teratogenic.


title: Antiphospholipid syndrome

text: The presence of antiphospholipid antibodies (aPL) in the absence of blood clots or pregnancy-related complications does not indicate APS (see below for the diagnosis of APS).


title: Antiphospholipid syndrome

text: Antiphospholipid syndrome can cause arterial or venous blood clots, in any organ system, or pregnancy-related complications. In APS patients, the most common venous event is deep vein thrombosis of the lower extremities, and the most common arterial event is stroke. In pregnant women affected by APS, there is an increased risk of recurrent miscarriage, intrauterine growth restriction, and preterm birth. A frequent cause of such complications is placental infarctions.


title: Antiphospholipid syndrome

text: In some cases, APS seems to be the leading cause of intellectual and/or developmental disabilities in the newborn, due to an aPL-induced inhibition of trophoblast differentiation. The antiphospholipid syndrome is responsible for most of the miscarriages in later trimesters seen in concomitant systemic lupus erythematosus and pregnancy.


title: Antiphospholipid syndrome

text: Other common findings, although not part of the APS classification criteria, are low platelet count, heart valve disease, and livedo reticularis. There are also associations between antiphospholipid antibodies and different neurologic manifestations including headache, migraine, epilepsy, and dementia. Some studies have shown the presence of antiphospholipid antibodies in the blood and spinal fluid of patients with psychological symptoms. Cancer is also observed to comorbid in patients with APS.


title: Antiphospholipid syndrome

text: Antiphospholipid syndrome is an autoimmune disease, in which "antiphospholipid antibodies" (anticardiolipin antibodies and lupus anticoagulant) react against proteins that bind to anionic phospholipids on plasma membranes. Like many autoimmune diseases, it is more common in women than in men. The exact cause is not known, but activation of the system of coagulation is evident. Clinically important antiphospholipid antibodies (those that arise as a result of the autoimmune process) are associated with thrombosis and vascular disease. The syndrome can be divided into primary (no underlying disease state) and secondary (in association with an underlying disease state) forms.


title: Antiphospholipid syndrome

text: Anti-ApoH and a subset of anti-cardiolipin antibodies bind to ApoH. ApoH inhibits protein C, a glycoprotein with important regulatory function of coagulation (inactivates Factor Va and Factor VIIIa). Lupus anticoagulant antibodies bind to prothrombin, thus increasing its cleavage to thrombin, its active form.


title: Antiphospholipid syndrome

text: In APS there are also antibodies binding to protein S, which is a co-factor of protein C. Thus, anti-protein S antibodies decrease protein C efficiency.


title: Antiphospholipid syndrome

text: Annexin A5 forms a shield around negatively charged phospholipid molecules, thus reducing their availability for coagulation. Thus, anti-annexin A5 antibodies increase phospholipid-dependent coagulation steps.


title: Antiphospholipid syndrome

text: The lupus anticoagulant antibodies are those that show the closest association with thrombosis; those that target βglycoprotein 1 have a greater association with thrombosis than those that target prothrombin.


title: Antiphospholipid syndrome

text: Anticardiolipin antibodies are associated with thrombosis at moderate to high titres (over 40 GPLU or MPLU).


title: Antiphospholipid syndrome

text: Patients with both lupus anticoagulant antibodies and moderate or high titre anticardiolipin antibodies show a greater risk of thrombosis than with one alone.


title: Antiphospholipid syndrome

text: The increased risks of recurrent miscarriage, intrauterine growth restriction and preterm birth by antiphospholipid antibodies, as supported by "in vitro" studies, include decreased trophoblast viability, syncytialization and invasion, deranged production of hormones and signalling molecules by trophoblasts, as well as activation of coagulation and complement pathways.


title: Antiphospholipid syndrome

text: Antiphospholipid syndrome is diagnosed using either liquid-phase coagulation assays to detect lupus anticoagulant or solid phase ELISA (enzyme-linked immunosorbent assay) to detect anti-cardiolipin antibodies or anti-apolipoprotein antibodies.


title: Antiphospholipid syndrome

text: Genetic thrombophilia is part of the differential diagnosis of APS and can coexist in some patients with APS. Presence of genetic thrombophilia may determine the need for anticoagulation therapy. Thus, genetic thrombophilia screening can consist of:


title: Antiphospholipid syndrome

text: Antiphospholipid antibodies do not recognize isolated cardiolipin, but bind to a cardiolipin-βGPI (apolipoprotein H) complex. The use of testing for antibodies specific for individual targets of aPL such as β glycoprotein 1 and phosphatidylserine is currently under debate.


title: Antiphospholipid syndrome

text: This is tested for by using a minimum of two coagulation tests that are phospholipid-sensitive, due to the heterogeneous nature of the lupus anticoagulant antibodies. The patient on initial screening will typically have been found to have a prolonged partial thromboplastin time (PTT) that does not correct in an 80:20 mixture with normal human plasma (50:50 mixes with normal plasma are insensitive to all but the highest antibody levels). The PTT (plus 80:20 mix), dilute Russell's viper venom time, kaolin clotting time, dilute thromboplastin time, silica clotting time and prothrombin time (using a lupus-sensitive thromboplastin) are the principal tests used for the detection of lupus anticoagulant. These tests must be carried out on a minimum of two occasions at least 6 weeks apart and be positive on each occasion, demonstrating persistent positivity, to allow a diagnosis of antiphospholipid syndrome. This is to prevent patients with transient positive tests (due to infection etc.) being diagnosed as positive.


title: Antiphospholipid syndrome

text: Distinguishing a lupus antibody from a specific coagulation factor inhibitor (e.g.: factor VIII) is normally achieved by differentiating the effects of a lupus anticoagulant on factor assays from the effects of a specific coagulation factor antibody.


title: Antiphospholipid syndrome

text: The lupus anticoagulant will inhibit all the contact activation pathway factors (factor VIII, factor IX, factor XI and factor XII). Lupus anticoagulant will also rarely cause a factor assay to give a result lower than 35 iu/dl (35%) whereas a specific factor antibody will rarely give a result higher than 10 iu/dl (10%).


title: Antiphospholipid syndrome

text: Monitoring IV anticoagulant therapy by the PTT ratio is compromised due to the effects of the lupus anticoagulant and in these situations is generally best performed using a chromogenic assay based on the inhibition of factor Xa by antithrombin in the presence of heparin.


title: Antiphospholipid syndrome

text: Anti-cardiolipin antibodies can be detected using an enzyme-linked immunosorbent assay (ELISA) immunological test, which screens for the presence of βglycoprotein 1 dependent anticardiolipin antibodies. A low platelet count and positivity for antibodies against β-glycoprotein 1 or phosphatidylserine may also be observed in a positive diagnosis.


title: Antiphospholipid syndrome

text: Classification with APS requires evidence of both one or more specific, documented clinical events (either a vascular thrombosis and/or adverse obstetric event) and the confirmed presence of a repeated aPL. The Sapporo APS classification criteria (1998, published in 1999) were replaced by the Sydney criteria in 2006. Based on the most recent criteria, classification with APS requires one clinical and one laboratory manifestation:


title: Antiphospholipid syndrome

text: There are 3 distinct APS disease entities: primary (the absence of any comorbidity), secondary (when there is a pre-existing autoimmune condition, most frequently systemic lupus erythematosus, SLE), and catastrophic (when there is simultaneous multi-organ failure with small vessel occlusion).


title: Antiphospholipid syndrome

text: According to a 2006 consensus statement, it is advisable to classify APS into one of the following categories for research purposes:


title: Antiphospholipid syndrome

text: The International Consensus Statement is commonly used for Catastrophic APS diagnosis. Based on this statement, Definite CAPS diagnosis requires:


title: Antiphospholipid syndrome

text: VDRL, which detects antibodies against syphilis, may have a false positive result in aPL-positive patients (aPL bind to the lipids in the test and make it come out positive), although the more specific test for syphilis, FTA-Abs, that use recombinant antigens will not have a false-positive result.


title: Antiphospholipid syndrome

text: In people without symptoms, no treatment is required. In people with antiphospholipid antibody-associated thrombosis, anticoagulants such as warfarin are used to prevent further thrombosis. If warfarin is used, the INR is kept between 2.0 and 3.0. Direct-acting oral anticoagulants may be used as an alternative to warfarin, but not in people who are "triple positive" with all types of antiphospholipid antibody (lupus anticoagulant, anticardiolipin antibody and anti-β2 glycoprotein I antibody).


title: Antiphospholipid syndrome

text: Anticoagulation appears to prevent miscarriage in pregnant women. In pregnancy, low molecular weight heparin and low-dose aspirin are used instead of warfarin because of warfarin's teratogenicity. People with recurrent miscarriages are often advised to take aspirin and to start low molecular weight heparin treatment after missing a menstrual cycle. In refractory cases plasmapheresis may be used.


title: Antiphospholipid syndrome

text: The long-term prognosis for APS is determined mainly by recurrent thrombosis, which may occur in up to 29% of patients, sometimes despite antithrombotic therapy.


title: Antiphospholipid syndrome

text: Antiphospholipid syndrome was described in full in the 1980s, by E. Nigel Harris and Aziz Gharavi. They published the first papers in 1983. The syndrome was referred to as "Hughes syndrome" among colleagues after the rheumatologist Graham R.V. Hughes (St. Thomas' Hospital, London, UK), who brought together the team.


title: Antiphospholipid syndrome

text: APS ACTION (the AntiPhospholipid Syndrome Alliance for Clinical Trials and InternatiOnal Networking), is the first-ever international research network that has been created to design and conduct large-scale, multicenter clinical trials in persistently antiphospholipid antibody (aPL) positive patients. The network consists of a multidisciplinary group of physicians and investigators from around the world who are interested in antiphospholipid syndrome (APS) research. The primary mission of APS ACTION is to prevent, treat, and cure antiphospholipid antibody (aPL) associated clinical manifestations through high quality, multicenter, and multidisciplinary clinical research.


title: Santa Cruz de la Sierra

text: Santa Cruz de la Sierra (; "Holy Cross of the Mountain Range"), commonly known as Santa Cruz, is the largest city in Bolivia and the capital of the Santa Cruz department.


title: Santa Cruz de la Sierra

text: Situated on the Pirai River in the eastern Tropical Lowlands of Bolivia, the Santa Cruz de la Sierra Metropolitan Region is the most populous urban agglomeration in Bolivia with an estimated of 2.4 million population in 2020, it is formed by a conurbation of seven Santa Cruz municipalities: Santa Cruz de la Sierra, La Guardia, Warnes, Cotoca, El Torno, Porongo, and Montero.


title: Santa Cruz de la Sierra

text: The city was first founded in 1561 by Spanish explorer Ñuflo de Chavez about east of its current location, and was moved several times until it was finally established on the Pirai River in the late 16th century. For much of its history, Santa Cruz was mostly a small outpost town, and even after Bolivia gained its independence in 1825 there was little attention from the authorities or the population in general to settle the region. It was not until after the middle of the 20th century with profound agrarian and land reforms that the city began to grow at a very fast pace. Due to its low elevation at the foothills of the Andes and being situated in the Amazon basin, the city has a tropical climate unlike the other main metro area of La Paz that is thousands of metres higher in terms of elevation.


title: Santa Cruz de la Sierra

text: The city is Bolivia's most populous, produces nearly 35% of Bolivia's gross domestic product, and receives over 40% of all foreign direct investment in the country. This has helped make Santa Cruz the most important business center in Bolivia and the preferred destination of migrants from all over the country and from some neighboring countries as well.


title: Santa Cruz de la Sierra

text: Like much of the history of the people of the region, the history of the area before the arrival of European explorers is not well documented, mostly because of the somewhat nomadic nature and the absence of a written language in the culture of the local tribes. However, recent data suggests that the current location of the city of Santa Cruz was inhabited by an Arawak tribe that later came to be known by the Spanish as Chané. Remains of ceramics and weapons have been found in the area, leading researchers to believe they had established settlements in the area. Among the few known facts of these tribes, according to accounts of the first Spanish explorers that came into contact with the Chané, are that they had a formal leader, a "cacique", called Grigota for several years but his reign came to an end after one of the several Guarani (Chirigano) incursions in the area.


title: Santa Cruz de la Sierra

text: The first Europeans to set foot in the area were Spanish conquistadores from the recently created Governorate of New Andalusia that encompassed the territories of present-day Argentina, Uruguay, Paraguay, and Chile.


title: Santa Cruz de la Sierra

text: In 1549, Captain General Domingo Martinez de Irala became the first Spaniard to explore the region, but it was not until 1558 that Ñuflo de Chaves, who had arrived in Asuncion in 1541 with Álvar Núñez Cabeza de Vaca, led a new expedition with the objective of settling the region. After discovering that a new expedition from Asuncion was already underway, he quickly traveled to Lima and successfully persuaded the Viceroy to create a new province and grant him the title of governor on February 15, 1560. Upon returning from Lima, Chaves founded the city of Santa Cruz de la Sierra (Holy Cross of the Hills) on February 26, 1561, east of its present-day location, to function as the capital of the newly formed province of Moxos and Chaves. The settlement was named after Chaves's home town in Extremadura, where he grew up before venturing to America.


title: Santa Cruz de la Sierra

text: Shortly after the founding, attacks from local tribes became commonplace and Ñuflo de Chaves was killed in 1568 by Itatine natives. After Chaves's death, the conflicts with the local population as well as power struggles in the settlement forced the authorities in Peru to order the new governor, Lorenzo Suarez de Figueroa to relocate the city to the west. Many of the inhabitants, however, chose to stay behind and continued living in the original location. On September 13, 1590, the city was officially moved to the banks of the Guapay Empero river and renamed San Lorenzo de la Frontera. Nevertheless, the conditions proved to be even more severe at the new location forcing the settlers to relocate once again on May 21, 1595. Although this was the final relocation of the city, the name San Lorenzo continued to be used until the early 17th century, when the settlers who remained behind in Santa Cruz de la Sierra were convinced by the colonial authorities to move to San Lorenzo. After they moved the city was finally consolidated in 1622 and took its original name of Santa Cruz de la Sierra given by Ñuflo de Chaves over 60 years before. Remnants of the original settlement can be visited in Santa Cruz la Vieja ("Old Santa Cruz"), an archaeological site south of San José de Chiquitos.


title: Santa Cruz de la Sierra

text: Over the next 200 years, several tribes were either incorporated under Spanish control or defeated by force. The city also became an important staging point for Jesuit missions to Chiquitos and Moxos, leading to the conversion of thousands of Guaranies, Moxeños, Chiquitanos, Guarayos and Chiriguanos that eventually became part of the racially mixed population of the modern Santa Cruz, Beni, Pando and Tarija departments of Bolivia. Another important role the small town played in the region for the Spanish Empire was to contain the incursions of Portuguese Bandeirantes, many of which were repelled by the use of force over the years.


title: Santa Cruz de la Sierra

text: The efforts for consolidating the borders of the Empire were not overlooked by the authorities in Lima, who granted the province a great degree of autonomy. The province was ruled by a Captain General based in Santa Cruz, and, in turn, the city government was administered by two mayors and a council of four people. Citizens of Santa Cruz were exempt from all imperial taxes and the mita system used in the rest of the Viceroyalty of Peru was not practiced. However, in spite of its strategic importance, the city did not grow much in colonial times. Most of the economic activity was centered in the mining centers of the west and the main source of income of the city was agriculture.


title: Santa Cruz de la Sierra

text: Animosity towards imperial authorities began at the turn of the 18th century when the new system of intendencias reached the new world. The seat of government was taken away from the city and moved to Cochabamba, and many of the powers delegated by the viceroyalty were now in the hands of appointees of the crown. Like in many parts of Spanish America at the time, angered by the reforms the criollos saw as a threat to their way of life, and taking advantage of the Peninsular War, the local population, led by Antonio Vicente Seonane, revolted on September 24, 1810, overthrowing the governor delegate. A junta of local commanders took control of the government in his place. The revolutionaries, as it was the case with most of the revolts in Spanish America, remained loyal to the King of Spain, while repudiating the colonial authorities until after the end of the Peninsular War.


title: Santa Cruz de la Sierra

text: By 1813 the city was once again under imperial control. At this time, by order of General Manuel Belgrano, the revolutionary armies of Argentina sent a small force led by Ignacio Warnes to "liberate" Santa Cruz. After his successful campaign, he assumed control of the government of the city. In a little over a year Warnes was able to gather tremendous support from the population, enlisting criollos, mestizos and natives to the revolutionary army, and allying with the revolutionary leader of Vallegrande, Alvarez de Arenales, to defeat a strong imperial force in the Battle of Florida. This victory proved to be a serious blow to Spanish forces in the region. Nevertheless, two years after the victory of Florida, imperial forces launched a new offensive in the province led by Francisco Javier Aguilera. This campaign ended with the defeat and death of Ignacio Warnes and his forces in the Battle of Pari. Triumphant, Aguilera marched into the city with orders to quell the insurrection and reinstate the Spanish governor. This proved to be a very difficult task, with several revolutionary leaders, such as Jose Manuel "Cañoto" Baca and Jose Manuel Mercado, rising up in the coming years from the city itself and elsewhere in the province. These new leaders fought colonial authorities for seven years until they finally deposed the last Spanish governor, Manuel Fernando Aramburu, in February 1825 after news of the defeat of the imperial armies in the west had reached the city.


title: Santa Cruz de la Sierra

text: The city is located in the eastern part of Bolivia (17°45', South, 63°14', West) at around 400 m above sea level. It is part of the province of Andrés Ibáñez and the capital of the department of Santa Cruz. The city of Santa Cruz is located not far from the easternmost extent of the Andes Mountains and they are visible from some parts of the city.


title: Santa Cruz de la Sierra

text: The city has a tropical savanna climate (Köppen: "Aw"), with an average annual temperature around and all months above of . Santa Cruz is an example of the influence of continentality (reflecting the thermal amplitude) in the tropics, without the four well-defined seasons of the year but greater deviations of temperature than other places in the coast or island. Although the weather is generally very warm all year round, cold winds called "surazos" can blow in occasionally (particularly in the winter) from the Argentine pampas making the temperature drop considerably. The months of greatest rainfall are December and January. The average annual rainfall is .


title: Santa Cruz de la Sierra

text: Santa Cruz sits at the edge of the Codo de Arica, where winds are particularly strong in Bolivia. Annual variations in temperature and precipitation are common, as is the case across much of the region. Annual precipitation in recent history has varied between .


title: Santa Cruz de la Sierra

text: The city of Santa Cruz is, among the largest cities in Bolivia, the one with the greatest mestizo and Creole identity, and with a smaller indigenous population. The first settlers of Santa Cruz were mainly the Native Chane people of East Bolivia followed by the Spaniards that accompanied Ñuflo de Chávez, as well as Guarani natives from Paraguay, and other native American groups that previously lived there working for the Spanish crown. Eventually, the Spanish settlers and native people of Bolivia began to mix which has resulted in the majority of the city population being mestizo. When the Spanish settlers arrived to Bolivia, Catholicism, as well as the Spanish language, were implemented onto the natives which is now why the city is predominantly Catholic and speak Spanish. Nevertheless, native religions and languages are still used by a minority of the population.


title: Santa Cruz de la Sierra

text: There is a distinction between the ethno-demographic profile of the Santa Cruz de la Sierra region, marked by the mestizo, Spanish and eastern indigenous presence, in relation to the population of the Bolivian Altiplano, western part of the country mostly Andean indigenous with a smaller mestizo and Spanish presence.


title: Santa Cruz de la Sierra

text: The city of Santa Cruz de la Sierra has utility infrastructure, roads and highways, and lively shopping and business. The main sectors that drive the economy are oil, forestry companies, agribusiness, and construction. Santa Cruz contributes more than 80% of national agricultural production, and also has contributed over 35% of GDP in recent years.


title: Santa Cruz de la Sierra

text: Santa Cruz de la Sierra is served by Bolivia's largest airport, the Viru Viru International Airport, with service on 14 airlines, 10 of which are from other countries, and 12 of them being passenger ones and two being cargo-only airlines. The airline AeroSur had its headquarters in Santa Cruz. The airline ceased operations in May 2012 and has been replaced by Boliviana de Aviación, which flies from Santa Cruz to Miami, Madrid, Buenos Aires, Salta and São Paulo.


title: Santa Cruz de la Sierra

text: It was formerly linked with the Brazilian railway system through a line to Corumbá, Brazil. This line, which was reputed to have a poor safety record, was abandoned after a highway to the Brazilian border was built in the 1980s.


title: Fiduciary

text: A fiduciary is a person who holds a legal or ethical relationship of trust with one or more other parties (person or group of persons). Typically, a fiduciary prudently takes care of money or other assets for another person. One party, for example, a corporate trust company or the trust department of a bank, acts in a fiduciary capacity to another party, who, for example, has entrusted funds to the fiduciary for safekeeping or investment. Likewise, financial advisers, financial planners, and asset managers, including managers of pension plans, endowments, and other tax-exempt assets, are considered fiduciaries under applicable statutes and laws. In a fiduciary relationship, one person, in a position of vulnerability, justifiably vests confidence, good faith, reliance, and trust in another whose aid, advice, or protection is sought in some matter. In such a relation, good conscience requires the fiduciary to act at all times for the sole benefit and interest of the one who trusts.


title: Fiduciary

text: Fiduciary duties in a financial sense exist to ensure that those who manage other people's money act in their beneficiaries' interests, rather than serving their own interests.


title: Fiduciary

text: A fiduciary duty is the highest standard of care in equity or law. A fiduciary is expected to be extremely loyal to the person to whom he owes the duty (the "principal") such that there must be no conflict of duty between fiduciary and principal, and the fiduciary must not profit from their position as a fiduciary. (unless the principal consents). The nature of fiduciary obligations differs among jurisdictions. In Australia, only proscriptive or negative fiduciary obligations are recognised, whereas in Canada, fiduciaries can come under both proscriptive (negative) and prescriptive (positive) fiduciary obligations.


title: Fiduciary

text: In English common law, the fiduciary relation is an important concept within a part of the legal system known as equity. In the United Kingdom, the Judicature Acts merged the courts of equity (historically based in England's Court of Chancery) with the courts of common law, and as a result the concept of fiduciary duty also became applicable in common law courts.


title: Fiduciary

text: When a fiduciary duty is imposed, equity requires a different, stricter standard of behavior than the comparable tortious duty of care in common law. The fiduciary has a duty not to be in a situation where personal interests and fiduciary duty conflict, not to be in a situation where their fiduciary duty conflicts with another fiduciary duty, and a duty not to profit from their fiduciary position without knowledge and consent. A fiduciary ideally would not have a conflict of interest. It has been said that fiduciaries must conduct themselves "at a level higher than that trodden by the crowd" and that "[t]he distinguishing or overriding duty of a fiduciary is the obligation of undivided loyalty".


title: Fiduciary

text: Different jurisdictions regard fiduciary duties in different lights. Canadian law, for example, has developed a more expansive view of fiduciary obligation than American law, while Australian law and British law have developed more conservative approaches than either the United States or Canada.


title: Fiduciary

text: In Australia, it has been found that there is no comprehensive list of criteria by which to establish a fiduciary relationship. Courts have so far refused to define the concept of a fiduciary, instead preferring to develop the law on a case-by-case basis and by way of analogy. Fiduciary relationships are of different types and carry different obligations so that a test appropriate to determine whether a fiduciary relationship exists for one purpose might be inappropriate for another:


title: Fiduciary

text: In 2014 the Law Commission (England and Wales) reviewed the fiduciary duties of investment intermediaries, looking particularly at the duties on pension trustees. They commented that the term "fiduciary" is used in many different ways.


title: Fiduciary

text: The question of who is a fiduciary is a "notoriously intractable" question and this was the first of many questions. In "SEC v. Chenery Corporation", Frankfurter J said,


title: Fiduciary

text: The law expressed here follows the general body of elementary fiduciary law found in most common law jurisdictions; for in-depth analysis of particular jurisdictional idiosyncrasies please consult primary authorities within the relevant jurisdiction.


title: Fiduciary

text: This is especially true in the area of Labor and Employment law. In Canada a fiduciary has obligations to the employer even after the employment relationship is terminated, whereas in the United States the employment and fiduciary relationships terminate together.


title: Fiduciary

text: The corporate law of Delaware is the most influential in the United States, as more than 50% of publicly traded companies in the United States, including 64% of the Fortune 500, have chosen to incorporate in that State. Under Delaware law, officers, directors and other control persons of corporations and other entities owe three primary fiduciary duties, (1) the duty of care, (2) the duty of loyalty and (3) the duty of good faith.


title: Fiduciary

text: The duty of care requires control persons to act on an informed basis after due consideration of all information. The duty includes a requirement that such persons reasonably inform themselves of alternatives. In doing so, they may rely on employees and other advisers so long as they do so with a critical eye and do not unquestionably accept the information and conclusions provided to them. Under normal circumstances, their actions are accorded the protection of the business judgment rule, which presumes that control persons acted properly, provided that they act on an informed basis, in good faith and in the honest belief that the action taken was in the best interests of the company.


title: Fiduciary

text: The duty of loyalty requires control persons to look to the interests of the company and its other owners and not to their personal interests. In general, they cannot use their positions of trust, confidence and inside knowledge to further their own private interests or approve an action that will provide them with a personal benefit (such as continued employment) that does not primarily benefit the company or its other owners.


title: Fiduciary

text: The duty of good faith requires control persons to exercise care and prudence in making business decisions—that is, the care that a reasonably prudent person in a similar position would use under similar circumstances. Control persons fail to act in good faith, even if their actions are not illegal, when they take actions for improper purposes or, in certain circumstances, when their actions have grossly inequitable results. The duty to act in good faith is an obligation not only to make decisions free from self-interest, but also free of any interest that diverts the control persons from acting in the best interest of the company. The duty to act in good faith may be measured by an individual's particular knowledge and expertise. The higher the level of expertise, the more accountable that person will be ("e.g.", a finance expert may be held to a more exacting standard than others in accepting a third party valuation).


title: Fiduciary

text: At one time, courts seemed to view the duty of good faith as an independent obligation. However, more recently, courts have treated the duty of good faith as a component of the duty of loyalty.


title: Fiduciary

text: In Canada, directors of corporations owe a fiduciary duty. A debate exists as to the nature and extent of this duty following a controversial landmark judgment from the Supreme Court of Canada in "BCE Inc. v. 1976 Debentureholders". Scholarly literature has defined this as a "tripartite fiduciary duty", composed of (1) an overarching duty to the corporation, which contains two component duties — (2) a duty to protect shareholder interests from harm, and (3) a procedural duty of "fair treatment" for relevant stakeholder interests. This tripartite structure encapsulates the duty of directors to act in the "best interests of the corporation, viewed as a good corporate citizen".


title: Fiduciary

text: The most common circumstance where a fiduciary duty will arise is between a trustee, whether real or juristic, and a beneficiary. The trustee to whom property is legally committed is the legal—i.e., common law—owner of all such property. The beneficiary, at law, has no legal title to the trust; however, the trustee is bound by equity to suppress their own interests and administer the property only for the benefit of the beneficiary. In this way, the beneficiary obtains the use of property without being its technical owner.


title: Fiduciary

text: Others, such as corporate directors, may be held to a fiduciary duty similar in some respects to that of a trustee. This happens when, for example, the directors of a bank are trustees for the depositors, the directors of a corporation are trustees for the stockholders or a guardian is trustee of their ward's property. A person in a sensitive position sometimes protects themselves from possible conflict of interest charges by setting up a "blind trust", placing their financial affairs in the hands of a fiduciary and giving up all right to know about or intervene in their handling.


title: Fiduciary

text: The fiduciary functions of trusts and agencies are commonly performed by a trust company, such as a commercial bank, organized for that purpose. In the United States, the Office of the Comptroller of the Currency (OCC), an agency of the United States Department of the Treasury, is the primary regulator of the fiduciary activities of federal savings associations.


title: Fiduciary

text: When a court desires to hold the offending party to a transaction responsible so as to prevent unjust enrichment, the judge can declare that a fiduciary relation exists between the parties, as though the offender were in fact a trustee for the partner.


title: Fiduciary

text: Relationships which routinely attract by law a fiduciary duty between certain classes of persons include these:


title: Fiduciary

text: Roman and civil law recognized a type of contract called "fiducia" (also "contractus fiduciae" or fiduciary contract),


title: Fiduciary

text: involving essentially a sale to a person coupled with an agreement that the purchaser should sell the property back upon the fulfillment of certain conditions. Such contracts were used in the emancipation of children, in connection with testamentary gifts and in pledges. Under Roman law a woman could arrange a fictitious sale called a "fiduciary coemption" in order to change her guardian or gain legal capacity to make a will.


title: Fiduciary

text: In Roman Dutch law, a "fiduciary heir" may receive property subject to passing it to another on fulfilment of certain conditions; the gift is called a "fideicommissum". The fiduciary of a fideicommissum is a "fideicommissioner" and one that receives property from a fiduciary heir is a "fideicommissary heir".


title: Fiduciary

text: Joint ventures, as opposed to business partnerships, are not "presumed" to carry a fiduciary duty; however, this is a matter of degree. If a joint venture is conducted at commercial arm's length and both parties are on an equal footing then the courts will be reluctant to find a fiduciary duty, but if the joint venture is carried out more in the manner of a partnership then fiduciary relationships can and often will arise.


title: Fiduciary

text: Husbands and wives are not "presumed" to be in a fiduciary relationship; however, this may be easily established. Similarly, ordinary commercial transactions in themselves are not "presumed" to but can give rise to fiduciary duties, should the appropriate circumstances arise. These are usually circumstances where the contract specifies a degree of trust and loyalty or it can be inferred by the court.


title: Fiduciary

text: Australian courts also do not recognise parents and their children to be in fiduciary relationships. In contrast, the Supreme Court of Canada allowed a child to sue her father for damages for breach of his fiduciary duties, opening the door in Canada for allowing fiduciary obligations between parent and child to be recognised.


title: Fiduciary

text: Australian courts have also not accepted doctor-patient relationships as fiduciary in nature. In "Breen v Williams", the High Court viewed the doctor's responsibilities over their patients as lacking the representative capacity of the trustee in fiduciary relationships. Moreover, the existence of remedies in contract and tort made the Court reluctant in recognising the fiduciary relationship.


title: Fiduciary

text: In 2011, in an insider trading case, the U.S. Securities and Exchange Commission brought charges against a boyfriend of a Disney intern, alleging he had a fiduciary duty to his girlfriend and breached it. The boyfriend, Toby Scammell, allegedly received and used insider information on Disney's takeover of Marvel Comics.


title: Fiduciary

text: ... within a particular contractual relationship there are specific contractual obligations which the employee has undertaken which have placed him in a situation where equity imposes these rigorous duties in addition to the contractual obligations. Although terminologies like duty of good faith, or loyalty, or the mutual duty of trust and confidence are frequently used to describe employment relationships, such concepts usually denote situations where "a party merely has to take into consideration the interests of another, but does not have to act in the interests of that other.


title: Fiduciary

text: If fiduciary relationships are to arise between employers and employees, it is necessary to ascertain that the employee has placed himself in a position where he must act solely in the interests of his employer. In the case of "Canadian Aero Service Ltd v O'Malley", it was held that a senior employee is much more likely to be found to owe fiduciary duties towards his employer.


title: Fiduciary

text: A protector of a trust may owe fiduciary duties to the beneficiaries, although there is no case law establishing this to be the case.


title: Fiduciary

text: In 2015, the United States Department of Labor issued a proposed rule that if finalized would extend the fiduciary duty relationship to investment advisors and some brokers including insurance brokers. In 2017, the Trump Administration planned to order a 180-delay of implementation of the rule, sometimes known as the 'fiduciary rule'. The rule would require "brokers offering retirement investment advice to put their clients' interest first". The Trump Administration later rescinded the fiduciary rule on July 20, 2018. Prior to its repeal, the rule was also dealt blows by the US Fifth Circuit Court of Appeals in March and June 2018.


title: Fiduciary

text: For example, two members, "X" and "Y", of a band currently under contract with one another (or with some other tangible, existing relationship that creates a legal duty) record songs together. Let us imagine it is a serious, successful band and that a court would declare that the two members are equal partners in a business. One day, "X" takes some demos made cooperatively by the duo to a recording label, where an executive expresses interest. "X" pretends it is all his work and receives an exclusive contract and $50,000. "Y" is unaware of the encounter until reading it in the paper the next week.


title: Fiduciary

text: This situation represents a conflict of interest and duty. Both "X "and "Y" hold fiduciary duties to each other, which means they must subdue their own interests in favor of the duo's collective interest. By signing an individual contract and taking all the money, "X" has put personal interest above the fiduciary duty. Therefore, a court will find that "X" has breached his fiduciary duty. The judicial remedy here will be that "X" holds both the contract and the money in a constructive trust for the duo. Note, "X" will not be punished or totally denied of the benefit; both "X" and "Y" will receive a half share in the contract and the money.


title: Fiduciary

text: A fiduciary, such as the administrator, executor or guardian of an estate, may be legally required to file with a probate court or judge a surety bond, called a fiduciary bond or probate bond, to guarantee faithful performance of his duties. One of those duties may be to prepare, generally under oath, an "inventory" of the tangible or intangible property of the estate, describing the items or classes of property and usually placing a valuation on them.


title: Fiduciary

text: A bank or other fiduciary having legal title to a mortgage may sell fractional shares to investors, thereby creating a "participating mortgage".


title: Fiduciary

text: A fiduciary will be liable to account if proven to have acquired a profit, benefit or gain from the relationship by one of three means:


title: Fiduciary

text: Therefore, it is said the fiduciary has a duty not to be in a situation where personal interests and fiduciary duty conflict, a duty not to be in a situation where his fiduciary duty conflicts with another fiduciary duty, and not to profit from his fiduciary position without express knowledge and consent. A fiduciary cannot have a conflict of interest.


title: Fiduciary

text: The state of Texas in the United States sets out the duties of a fiduciary in its Estates Code, chapter 751, as follows (the bracketed references to TPC refer to the Texas Probate Code superseded by the Estates Code, effective January 1, 2014):


title: Fiduciary

text: A fiduciary's duty must not conflict with another fiduciary duty. Conflicts between one fiduciary duty and another fiduciary duty arise most often when a lawyer or an agent, such as a real estate agent, represent more than one client, and the interests of those clients conflict. This would occur when a lawyer attempts to represent both the plaintiff and the defendant in the same matter, for example. The rule comes from the logical conclusion that a fiduciary cannot make the principal's interests a top priority if he has two principals and their interests are diametrically opposed; he must balance the interests, which is not acceptable to equity. Therefore, the conflict of duty and duty rule is really an extension of the conflict of interest and duty rules.


title: Fiduciary

text: A fiduciary must not profit from the fiduciary position. This includes any benefits or profits which, although unrelated to the fiduciary position, came about because of an opportunity that the fiduciary position afforded. It is unnecessary that the principal would have been unable to make the profit; if the fiduciary makes a profit, by virtue of his role as fiduciary for the principal, then the fiduciary must report the profit to the principal. If the principal provides fully informed consent, then the fiduciary may keep the benefit and be absolved of any liability for what would be a breach of fiduciary duty. If this requirement is not met then the property is deemed by the court to be held by the fiduciary on constructive trust for the principal.


title: Fiduciary

text: Secret commissions, or bribes, also come under the no profit rule. The bribe shall be held in constructive trust for the principal. The person who made the bribe cannot recover it, since he has committed a crime. Similarly, the fiduciary, who received the bribe, has committed a crime. Fiduciary duties are an aspect of equity and, in accordance with the equitable principles, or maxims, equity serves those with clean hands. Therefore, the bribe is held on constructive trust for the principal, the only innocent party.


title: Fiduciary

text: Bribes were initially considered not to be held on constructive trust, but were considered to be held as a debt by the fiduciary to the principal. This approach has been overruled; the bribe is now classified as a constructive trust. The change is due to pragmatic reasons, especially in regard to a bankrupt fiduciary. If a fiduciary takes a bribe and that bribe is considered a debt then if the fiduciary goes bankrupt the debt will be left in his pool of assets to be paid to creditors and the principal may miss out on recovery because other creditors were more secured. If the bribe is treated as held on a constructive trust then it will remain in the possession of the fiduciary, despite bankruptcy, until such time as the principal recovers it.


title: Fiduciary

text: The landmark Australian decision "ASIC v Citigroup" noted that the "informed consent" on behalf of the beneficiary to breaches of either the no-profit and no-conflict rule will allow the fiduciary to get around these rules. Furthermore, it highlighted that a contract may include a clause that allows individuals to avoid all fiduciary obligations within the course of dealings, and thereby continue to make a personal profit or deal with other parties- tasks that may otherwise have been in conflict with what would have been a fiduciary duty had it not been for this clause. In the Australian case of "Farah Constructions Pty Ltd v Say-Dee Pty Ltd", however, Gleeson CJ, Gummow, Callinan, Heydon and Crennan JJ observed that the sufficiency of disclosure may depend on the sophistication and intelligence of the persons to whom the disclosure must be made.


title: Fiduciary

text: However, in the English case of "Armitage v Nurse" an exception was noted to be the fiduciary's obligation of good faith; liability for breach of fiduciary duty by way of fraud or dishonesty cannot be avoided through an exclusion clause in a contract. The decision in "Armitage v Nurse" has been applied in Australian .


title: Fiduciary

text: Conduct by a fiduciary may be deemed "constructive fraud" when it is based on acts, omissions or concealments considered fraudulent and that gives one an advantage against the other because such conduct—though not actually fraudulent, dishonest or deceitful—demands redress for reasons of public policy. Breach of fiduciary duty may occur in insider trading, when an insider or a related party makes trades in a corporation's securities based on material non-public information obtained during the performance of the insider's duties at the corporation. Breach of fiduciary duty by a lawyer with regard to a client, if negligent, may be a form of legal malpractice; if intentional, it may be remedied in equity.


title: Fiduciary

text: Where a principal can establish both a fiduciary duty and a breach of that duty, through violation of the above rules, the court will find that the benefit gained by the fiduciary should be returned to the principal because it would be unconscionable to allow the fiduciary to retain the benefit by employing his strict common law legal rights. This will be the case, unless the fiduciary can show there was full disclosure of the conflict of interest or profit and that the principal fully accepted and freely consented to the fiduciary's course of action.


title: Fiduciary

text: Remedies will differ according to the type of damage or benefit. They are usually distinguished between proprietary remedies, dealing with property, and personal remedies, dealing with pecuniary (monetary) compensation. Where concurrent contractual and fiduciary relationships exist, remedies available to the plaintiff beneficiary is dependent upon the duty of care owed by the defendant and the specific breach of duty allowing for remedy/damages. The courts will clearly distinguish the relationship and determine the nature in which the breach occurred.


title: Fiduciary

text: Where the unconscionable gain by the fiduciary is in an easily identifiable form, such as the recording contract discussed above, the usual remedy will be the already discussed constructive trust.


title: Fiduciary

text: Constructive trusts pop up in many aspects of equity, not just in a remedial sense, but, in this sense, what is meant by a constructive trust is that the court has created and imposed a duty on the fiduciary to hold the money in safekeeping until it can be rightfully transferred to the principal.


title: Fiduciary

text: An account of profits is another potential remedy. It is usually used where the breach of duty was ongoing or when the gain is hard to identify. The idea of an account of profits is that the fiduciary profited unconscionably by virtue of the fiduciary position, so any profit made should be transferred to the principal. It may sound like a constructive trust at first, but it is not.


title: Fiduciary

text: An account of profits is the appropriate remedy when, for example, a senior employee has taken advantage of his fiduciary position by conducting his own company on the side and has run up quite a lot of profits over a period of time, profits which he wouldn't have been able to make otherwise. The fiduciary in breach may however receive an allowance for effort and ingenuity expended in making the profit.


title: Fiduciary

text: Compensatory damages are also available. Accounts of profits can be hard remedies to establish, therefore, a plaintiff will often seek compensation (damages) instead. Courts of equity initially had no power to award compensatory damages, which traditionally were a remedy at common law, but legislation and case law has changed the situation so compensatory damages may now be awarded for a purely equitable action.


title: Fiduciary

text: Some experts have argued that, in the context of pension governance, trustees have started to reassert their fiduciary prerogatives more strongly after 2008 – notably following the heavy losses or reduced returns incurred by many retirement schemes in the wake of the Great Recession and the progression of ESG and Responsible Investment ideas: "Clearly, there is a mounting demand for CEOs (equity issuers) and governments (sovereign bond issuers) to be more 'accountable' ... No longer ‘absentee landlords', trustees have started to exercise more forcefully their governance prerogatives across the boardrooms of Britain, Benelux and America: coming together through the establishment of engaged pressure groups." However, in the United States, there are questions whether a pension's decision to consider factors such as how investments impact contributors' continued employment violate a fiduciary duty to maximize the retirement fund's returns.


title: Fiduciary

text: Pension funds and other large institutional investors are increasingly making their voices heard to call out irresponsible practices in the businesses in which they invest


title: Fiduciary

text: The Fiduciary Duty in the 21st Century Programme, led by the United Nations Environment Programme Finance Initiative, the Principles for Responsible Investment, and the Generation Foundation, aims to end the debate on whether fiduciary duty is a legitimate barrier to the integration of environmental, social and governance (ESG) issues in investment practice and decision-making. This followed the 2015 publication of "Fiduciary Duty in the 21st Century" which concluded that "failing to consider all long-term investment value drivers, including ESG issues, is a failure of fiduciary duty". Founded on the realization that there is a general lack of legal clarity globally about the relationship between sustainability and investors’ fiduciary duty, the programme engaged with and interviewed over 400 policymakers and investors to raise awareness of the importance of ESG issues to the fiduciary duties of investors. The programme also published roadmaps which set out recommendations to fully embed the consideration of ESG factors in the fiduciary duties of investors across more than eight capital markets. Drawing upon findings from Fiduciary Duty in the 21st Century, the European Commission High-Level Expert Group (HLEG) recommended in its 2018 final report that the EU Commission clarify investor duties to better embrace long-term horizon and sustainability preferences.


title: Welwyn Garden City

text: Welwyn Garden City ( ) is a town in Hertfordshire, England, north of London. It was the second garden city in England (founded 1920) and one of the first new towns (designated 1948). It is unique in being both a garden city and a new town and exemplifies the physical, social and cultural planning ideals of the periods in which it was built.


title: Welwyn Garden City

text: Welwyn Garden City was founded by Sir Ebenezer Howard in 1920 following his previous experiment in Letchworth Garden City. Howard had called for the creation of planned towns that were to combine the benefits of the city and the countryside and to avoid the disadvantages of both. It was designed to be 'The Perfect Town'. The Garden Cities and Town Planning Association had defined a garden city as


title: Welwyn Garden City

text: "a town designed for healthy living and industry of a size that makes possible a full measure of social life but not larger, surrounded by a rural belt; the whole of the land being in public ownership, or held in trust for the community"


title: Welwyn Garden City

text: In 1919, Howard arranged for the purchase of land in Hertfordshire that had already been identified as a suitable site. A company called Second Garden City Limited was formed in October 1919 to start buying the land and developing the town. On 4 February 1920 the company's board decided to call the new garden city Digswell, taking the name of the existing small village which would be surrounded by the development. Six days later they changed their minds, deciding instead to call it Welwyn Garden City, reflecting that the project was already been discussed generally as the "new garden city near Welwyn". On 29 April 1920 the company changed its name to become Welwyn Garden City Limited. Sir Theodore Chambers chaired the company, whilst Louis de Soissons was appointed as architect and town planner, Charles Purdom as finance director and Frederic Osborn as secretary. The first house was occupied just before Christmas 1920.


title: Welwyn Garden City

text: The town is laid out along tree-lined boulevards with a neo-Georgian town centre. It has its own environmental protection legislation, the Scheme of Management for Welwyn Garden City. Every road has a wide grass verge. The spine of the town is Parkway, a central mall or scenic parkway, almost a mile long. The view along Parkway to the south was once described as one of the world's finest urban vistas. Older houses are on the west side of Parkway and newer houses on the east side


title: Welwyn Garden City

text: The original planners intended that all the residents of the garden city would shop in one shop and created the Welwyn Stores, a monopoly which caused some local resentment. Commercial pressures have since ensured much more competition and variety, and the Welwyn Stores were in 1984 taken over by the John Lewis Partnership.


title: Welwyn Garden City

text: In 1948, Welwyn Garden City was designated a new town under the New Towns Act 1946 and the Welwyn Garden City company handed its assets to the Welwyn Garden City Development Corporation. Louis de Soissons remained as its planning consultant. That year "The Times" compared Welwyn Garden City with Hatfield. It described Welwyn Garden City as a world-famous modern new town developed as an experiment in community planning and Hatfield as an unplanned settlement created by sporadic building in the open country. "Welwyn, though far from perfect, made the New Towns Act possible, just as Hatfield, by its imperfection, made it necessary." In 1966, the Development Corporation was wound up and handed over to the Commission for New Towns. The housing stock, neighbourhood shopping and green spaces were passed to Welwyn Hatfield District Council between 1978 and 1983.


title: Welwyn Garden City

text: The New QEII Hospital, completed in June 2015, offers outpatient, diagnostic and ante/postnatal services.


title: Welwyn Garden City

text: A shopping mall, the Howard Centre, was built in the 1980s, incorporating a replacement for the original "temporary" railway station.


title: Welwyn Garden City

text: There is a resurgence of interest in the ethos of the garden city and the type of neighbourhood and community advocated by Howard, prompted by the problems of metropolitan and regional development and the importance of sustainability in government policy.


title: Welwyn Garden City

text: On the outskirts of Old Welwyn village, the Welwyn Roman baths are preserved in a steel vault underneath junction 6 of the A1(M) and are open to visitors.


title: Welwyn Garden City

text: The local civic society, which aims to preserve and conserve the garden city ethos, is the Welwyn Garden City Society.


title: Welwyn Garden City

text: In 2008, during construction of a site for HSBC, 60 unsecured argonite fire suppressant cylinders discharged, killing one person, injuring six others and causing substantial damage. Three firms were later convicted of health and safety offences.


title: Welwyn Garden City

text: 2020 saw the 100th anniversary for Welwyn Garden City with a series of celebrations planned. They could not all be done amidst the COVID-19 pandemic.


title: Welwyn Garden City

text: Welwyn Garden City is part of the Welwyn Hatfield Borough and comprises seven local authority wards. It is in the county of Hertfordshire and the parliamentary constituency of Welwyn Hatfield. Welwyn Hatfield Borough Council has its offices in Welwyn Garden City. The MP for Welwyn Hatfield is Grant Shapps (Conservative). The nearby town of Hatfield and the village of Welwyn have parish councils with limited responsibilities, but Welwyn Garden City has none, although it had one between 1921 and 1927.


title: Welwyn Garden City

text: The land earmarked for the town in 1920 straddled the parishes of Hatfield, Digswell, Welwyn and Tewin. On 1 October 1921 a civil parish called Welwyn Garden City was created from parts of those four parishes. The new parish was initially part of the Welwyn Rural District. By 1923 the Welwyn Garden City parish council was based in offices on Bridge Road, on the edge of the site identified for the new town centre of the garden city.


title: Welwyn Garden City

text: The parish of Welwyn Garden City was made an urban district on 1 April 1927, making it independent of the Welwyn Rural District Council.


title: Welwyn Garden City

text: New offices were built on the site of the former parish council's offices at the corner of Bridge Road and The Campus. The new building was formally opened in January 1937. This building served as the headquarters of Welwyn Garden City Urban District Council until its abolition in 1974. Between 20 May 1948 and 31 March 1966 the development of the town was also administered by the Welwyn Garden City Development Corporation, set up under the New Towns Act 1946.


title: Welwyn Garden City

text: Welwyn Garden City Urban District was abolished under the Local Government Act 1972, merging with Welwyn Rural District and Hatfield Rural District to become the district of Welwyn Hatfield on 1 April 1974. No successor parish was created for the town, and so it became an unparished area, governed directly by Welwyn Hatfield District Council (Borough Council after 2006). The Welwyn Garden City Urban District Council's former offices at The Campus are still used by Welwyn Hatfield Borough Council as its headquarters.


title: Welwyn Garden City

text: Welwyn Garden City experiences a maritime or oceanic climate (Köppen climate classification "Cfb"), in common with the rest of the United Kingdom. The town experiences warm summers and cool winters.


title: Welwyn Garden City

text: Ever since its inception as a garden city, Welwyn Garden City has attracted a strong commercial base with several designated employment areas. Among the companies trading in the town are:


title: Welwyn Garden City

text: Welwyn Garden City was once well known as the home of the breakfast cereal Shredded Wheat, formerly made by Nabisco. The disused Shredded Wheat factory with its large white silos is a landmark on rail routes between London and the north of England. The factory, designed by de Soissons and built in 1924 by Peter Lind & Company, is a Grade II listed building. Cereal production moved to Staverton, Wiltshire in 2008 when the owner, Nestlé, decided that the factory required significant and prohibitive investment, due to the age of the building. Tesco applied to build a new supermarket on the site, but planning permission was refused by the local authority in January 2012 after significant public protest. In December 2018, the newly renamed "Wheat Quarter" area had planning permission approved for complete area redevelopment, consisting of 1,454 units, mainly homes, as well as office, retail and community uses.


title: Welwyn Garden City

text: The former supermarket chain Fine Fare had its head office in the town at one time, as did ICI's Plastics Division.


title: Welwyn Garden City

text: There is now a redeveloped and enlarged Sainsbury's in the town centre, and a Morrisons in Panshanger along Black Fan Road.


title: Welwyn Garden City

text: Buses are provided by Arriva Shires & Essex, Centrebus and Uno, with some assistance from Hertfordshire County Council. Arriva's 300/301 Centraline service links Welwyn Garden City to the major nearby towns of Stevenage, Hatfield, St Albans and Hemel Hempstead, as well as neighbouring villages Woolmer Green and Knebworth. The 301 additionally connects both the nearby hospitals in Stevenage and Welwyn Garden City, while the 300 provides a direct link to recreational areas such as Stanborough Lakes in Welwyn Garden City and Verulamium Roman town in St Albans. Service 314 is provided by Centrebus, connecting Welwyn to Codicote and Hitchin. The bus station is close to the railway station.


title: Welwyn Garden City

text: Uno buses serve the nearby towns of Hatfield, St Albans, Potters Bar, Hemel Hempstead, Watford and Barnet. Uno buses also serve further out into North London. Both the 601 and 653 also provide links to the University of Hertfordshire.


title: Welwyn Garden City

text: Green Line bus route 724 runs a service from Welwyn Garden City to Heathrow Airport, stopping at stops such as Watford and Rickmansworth.


title: Welwyn Garden City

text: The railway station is in the town centre. Trains are operated by Thameslink and run south to London King's Cross and Great Northern to London Moorgate and Thameslink run north to Stevenage, Hitchin, Cambridge.


title: Welwyn Garden City

text: Welwyn Garden City is well-served by major arterial road routes, namely the A1(M) and the A414. The Great North Road also passes around it next to the A1(M). In addition, there are other links to St Albans, Harpenden and Luton (via B653), Hatfield (via A1000 and A1001) and Hertford (via B1000). During the growth in car ownership in the 1950s and 1960s, the town struggled to build enough garages or hard-standing spaces for the additional vehicles, which has led to many properties losing their traditional hedges and front gardens to accommodate driveways.


title: Welwyn Garden City

text: Welwyn Garden City's Music Society gave its first concert in 1921 within weeks of the town's foundation; its choir and orchestra, led by James Ross, have performed a regular concert season in the town ever since. The town also boasts a Concert Club, which promotes chamber music recitals, and a Male Voice Choir. Welwyn Garden City Band was founded in 1934. The Barn Theatre is a Grade II listed building on Handside Lane. Welwyn Thalians, an amateur dramatic and operatic group, has performed in the town since 1929.


title: Welwyn Garden City

text: The Gosling Sports Centre houses a dry ski slope, golf driving range, indoor and outdoor tennis, squash, football pitches, an athletics track, velodrome, a gym and bowls as well as a new trampoline park


title: Welwyn Garden City

text: The King George V playing field, on the boundary of the old Hatfield Hyde village is the home of Hatfield Hyde Cricket Club since 1889, predating Welwyn Garden City by 31 years. The playing field was once used by the England football team for training. During the 1966 football World Cup the French, West German and Argentinian football teams stayed at the Homestead Court Hotel alongside the King George V playing fields.


title: Welwyn Garden City

text: There are three golf courses: Panshanger, owned and operated by the borough council, Mill Green Golf Course located in Gypsy Lane and the Welwyn Garden City Golf Club, of which Nick Faldo was once a member.


title: Welwyn Garden City

text: The Digswell Park Sports Association brings together Welwyn Garden City Cricket Club, Welwyn Garden City Bowls Club and the Digswell Park Sports and Social Club, at Digswell Park, Knightsfield. Welwyn Garden City Cricket Club was founded in 1921 and runs 7-weekend senior sides along with a youth cricket programme. WGCCC First XI competes in the Saracens Herts Premier League.


title: Welwyn Garden City

text: The lake in Stanborough Park is the home of Welwyn Garden City Sailing Club (founded 1973) and the WGC Angling Club.


title: Deadnaming

text: Deadnaming is the act of referring to a transgender or non-binary person by a name they used prior to transitioning, such as their birth name. Deadnaming may be unintentional, or a deliberate attempt to deny, mock or invalidate a person's gender identity.


title: Deadnaming

text: Transgender and non-binary people seeking to avoid deadnaming may face administrative or bureaucratic obstacles to changing their names. Published authors who have later transitioned may be troubled by the appearance of their former name in bibliographic metadata records that are nearly impossible to update. Some social media platforms have implemented policies to avoid deadnaming, such as standardizing the use of preferred names rather than legal names or formally banning the practice of deadnaming.


title: Deadnaming

text: As part of gender transition, some transgender and non-binary people adopt a new name, often going from a masculine or feminine given name to one which better aligns with their gender identity. In the 2010s, transgender activists popularized the term "deadname" (i.e. a name that is dead) to refer to such a former name. The Oxford English Dictionary attests the use of "deadname" on Twitter in 2010, and use as a verb (i.e. "deadnaming") in 2013. The term is typically used derisively, with the implication that referring to a transgender person by their former name is unacceptable. Journalistic style guides, health-practitioner manuals, and LGBT advocacy groups advise adopting transgender people's self-identified name and pronouns, even when referring to them in the past, prior to transitioning.


title: Deadnaming

text: Trans people who wish to avoid being deadnamed can sometimes face significant bureaucratic and administrative obstacles. The legal name change itself requires time, money, and effort. Changing corresponding information such as names, emails, and class schedules in some institutions (such as schools) can be difficult.


title: Deadnaming

text: Like misgendering, deadnaming can be a form of overt aggression or a microaggression, indicating that the target is not fully accepted as a member of society. Transgender activists consider the deadnaming of homicide victims and high-profile celebrities by news media to be a violation of privacy, and a contributing factor to transphobia.


title: Deadnaming

text: Deadnaming may also be done accidentally by people who are otherwise supportive of trans individuals, such as supportive family members or friends who have not yet become accustomed to using a trans person's new name. Repeated failures to avoid deadnaming, however, can be considered disrespectful.


title: Deadnaming

text: Christopher Reed, a professor of history and scholar of queer culture, argued that objecting to deadnaming "inhibits efforts toward self-acceptance and integration". Grace Lavery argued that the freedom to deadname is not covered within the principles of academic freedom. Disputes surrounding the legitimacy of deadnaming have led to disputes within the LGBT community, with some stating that deadnaming itself is a tangible harm, and others arguing that the policing of deadnaming would resemble a "re-education camp".


title: Deadnaming

text: Queer scholar Lucas Crawford has theorized that some transgender people insist on preventing deadnaming in part as a strategy of prospective self-assertion: "by insisting on the primacy of the present, by seeking to erase the past, or even by emotionally locating their 'real self' in the future, that elusive place where access (to transition, health care, housing, a livable wage, and so on) and social viability tend to appear more abundant." Correcting deadnaming by third parties is cited as a way to support trans people.


title: Deadnaming

text: When trans journalist and University of California professor Theresa Tanenbaum transitioned in 2019, finding herself unable to remove or have her deadname retracted from old publications, she argued that there were broader implications to deadnaming that affected not only the trans community, but other groups in general. Agreeing with journalist Oliver-Ash Kleine of the Trans Journalists Association, Tanenbaum stated, "you might want to change your name on past work to erase from your identity the traces of an abusive former partner, or because you’ve converted to a different religion, among many other reasons." She suggested that deadnaming could happen to a wide variety of vulnerable groups within and outside of the trans community, and that for herself, it has been frustrating and harmful to have media outlets refuse to remove her deadname from old articles. Jaye Simpson, writing for "Briar Patch Magazine", added that Black and Indigenous communities and trans members within these communities are also at risk for deadnaming, recalling Canada's settler-colonial history, the replacing of Indigenous traditional names with Anglican names in Canada's residential school system (an offence that can now be reverted by legal name change under Canadian law, a process typically made free to residential school survivors), and the inability for western culture to grasp non-binary and Two-spirit identities. While deadnaming most often affects trans people, it can affect a multitude of different groups. For example, as pointed out by Amy Lazet and Brian M. Watson in their editorial piece on retroactive author name changes, "Chinese names are typically structured so that the name listed first is the surname while the second-order name is the given name. South Indians, on the other hand, do not typically have a surname, and are known only by their given name. In order to fulfill the Western-based authorial naming criteria, the father’s given name is commonly used, often leading to confusion as to who deserves the credit for the publication - the author or their father. Similarly, women in academia have traditionally faced issues related to assuming a partner’s name. If a woman has established a professional reputation under her maiden name, how can she continue to associate that record with herself if she changes her name upon marriage or divorce?" In Theresa Tanenbaum's case, she claimed that it was left up to the individual news platform whether her deadname would be retracted or removed, or just left permanent, with no particular legislation in place to prevent this.


title: Deadnaming

text: Some web platforms such as Facebook, YouTube, and Gmail allow a certain number of name changes per user profile, allowing for any number of reasons for a name to be changed; having fixed metadata, such as a deadname on a published book with an ISBN, is next to impossible to remedy. Some academic publishers and scientific journal publishers have a deadnaming policy allowing trans authors to fix their metadata, reflecting their preferred name. In the case of publications with a fixed identifier, oftentimes trans authors follow what authors switching from maiden to married surname and vice versa have sometimes done, which is to republish their creative work, or works, as new editions with their preferred name while trying to take old ones with the deadname out of print. Some media metadata web platforms may still portray the deadname as the primary author and edition.


title: Deadnaming

text: In 2013, the English Wikipedia elicited media coverage over its response to Chelsea Manning's public transition. The article about Manning was initially quickly renamed, but a protracted dispute ensued; the matter was ultimately taken up by the site's Arbitration Committee, which imposed sanctions on editors espousing transphobia, but also on those making accusations of transphobia. Wikimedia Foundation executive Sue Gardner expressed disappointment over the handling of Wikipedia's response.


title: Deadnaming

text: The Internet Movie Database (IMDb) changed its rigid policy on cast names in 2019, allowing actors and actresses to change and remove birth names and deadnames from their official profiles. This move came after trans actress Laverne Cox pointed out deadnaming on Amazon subsidiaries like IMDb as being "the ultimate insult", with GLAAD spokesperson Nick Adams agreeing and calling deadnaming an "invasion of privacy", sparking a protest over the practice of deadnaming in media metadata. IMDb released a statement saying, "IMDb now permits the removal of birth names if the birth name is not broadly publicly known and the person no longer voluntarily uses their birth name. To remove a birth name either the person concerned or their professional industry representative simply needs to contact IMDb's customer support staff to request a birth name removal. Once the IMDb team determines that an individual's birth name should be removed – subject to this updated process – we will review and remove every occurrence of their birth name within their biographical page on IMDb." It is not yet clear whether other Amazon media metadata platforms like Goodreads or the main Amazon shopping website will update policies on deadnaming.


title: Deadnaming

text: In response to actor Elliot Page coming out as transgender in December 2020, media streaming service Netflix removed Page's deadname from its metadata in the credits of movies the actor had appeared in as a female, including "The Tracey Fragments", "Juno", "Hard Candy," and others. Writer Grayson Gilcrease, who investigated the situation, speculated that Netflix's actions were the result of Page's popularity in the TV series "The Umbrella Academy". IMDb changed metadata for Elliot Page in 2020 to reflect his preferred name, even on lesser-known productions; for example, the 2003 Lifetime Movie Network TV movie "Going For Broke", about a family affected by a parent's gambling addiction, now features the preferred name "Elliot Page" in the credits list for the role of character Jennifer Bancroft.


title: Deadnaming

text: On March 12, 2021, the North Carolina Department of Public Instruction announced that its student information system would display each student's "preferred name" rather than birth name, which would eliminate deadnaming on state reports, student report cards, and teacher grade books.