title: European Green Deal

text: Although all EU leaders signed off on the European green deal in December 2019, disagreements in regards to the goals and their timeline to achieve each factor arose. Poland has stated that climate neutrality by 2050 will not be a possibility for their country due to their reliance on coal as their main power source. Their climate minister, Michał Kurtyka, declared that commitments and funds need to be more fairly allocated. The initiative to increase the goal of lowering carbon emissions split the EU, with the coal reliant countries such as Poland complaining it will affect “jobs and competitiveness.” Up to 41,000 jobs could be lost within Poland, with the Czech Republic, Bulgaria and Romania also having a possible loss of 10,000 jobs each. Czech Prime Minister, Andrej Babiš, stated that their nation will not reach the 2050 goal “without nuclear” association. Countries are also arguing over the Just Transition Fund (JTF) that aims to help countries who are reliant on coal to become more environmentally friendly. These countries that changed their impacts prior to the Policy, such as Spain, believe that the JTF is unfair as it only benefits the countries that didn't "go green earlier." The head of Brussels' office of the Open Europe think tank, Pieter Cleppe, further dismissed the plan with sarcastic comment, “What could possibly go wrong.”


title: European Green Deal

text: Poland's Prime Minister Mateusz Morawiecki said that the EU's carbon pricing system unfairly disadvantages poorer countries in Southern and Eastern Europe. Speaking at the COP26 climate summit in Glasgow, Czech Prime Minister Babiš denounced the European Green Deal, saying that the European Union "can achieve nothing without the participation of the largest polluters such as China or the USA that are responsible for 27 and 15 percent, respectively, of global emissions."


title: European Green Deal

text: It has been found that American oil company ExxonMobil had a significant impact on the early negotiations of the European Green Deal. ExxonMobil attempted to change the deal in a way that puts less emphasis on the importance of reducing transport that emits carbon dioxide. This was only one of many opponents of the deal.


title: European Green Deal

text: The European Green Deal has faced criticism from some EU member states, as well as non-governmental organizations. Greenpeace has argued that the deal is not drastic enough and that it will fail to slow down climate change to an acceptable degree. The Corporate Europe Observatory calls the Deal a positive first step, but criticizes the influence the fossil fuel industry had on it.


title: European Green Deal

text: There has been criticism of the deal not doing enough, but also of the deal potentially being destructive to the European Union in its current state. Former Romanian president, Traian Băsescu, has warned that the deal could lead to some EU members to push towards an exit from the union. While some European states are on their way to eliminating the use of coal as a source of energy, many others still rely heavily on it. This scenario demonstrates how the deal may appeal to some states more than others. The economic impact of the deal is likely to be unevenly spread among EU states. This was highlighted by Polish MEP, Ryszard Legutko, who asked, “is the Commission trying to seize power from the member states?”. Poland, the Czech Republic and Hungary, three states that depend mostly on coal for energy, were the most opposed to the deal. Young climate activist Greta Thunberg commented on governments opposing the deal, saying "It seems to have turned into some kind of opportunity for countries to negotiate loopholes and to avoid raising their ambition".


title: European Green Deal

text: In addition, many groups such as “Greenpeace”, “Friends of the Earth Europe” and the “Institute for European Environmental Policy” have all analysed the policy and believe it isn't “ambitious enough.” Greenpeace believes the plan is “too little too late” whilst the IEEP stated that most prospects of meeting policy objectives “lacked clear or adequate” goals for the problem areas.


title: European Green Deal

text: The Greens-European Free Alliance and Jytte Guteland have proposed that the European Green Deal's EU 2030 climate target were to be raised to at least 65% greenhouse gas emissions reductions.


title: European Green Deal

text: The EU has acknowledged these issues, however, and through the “Just Transition Mechanism”, expects to distribute the burden of transitioning to a greener economy more fairly. This policy means that countries that have more workers in coal and oil shale sectors, as well as those with higher greenhouse emissions, will receive more financial aid. According to Frans Timmermans, this mechanism will also make investment more accessible for those most affected, as well as offering a support package, which will be worth “at least 100 billion euros”. The Mechanism, a part of the Sustainable Europe Investment Plan, is expected to mobilize €100 billion in investments during the 2021-2027 Multiannual Financial Framework (MFF), with funding from the EU budget and Member States, as well as contributions from InvestEU and the European Investment Bank.


title: European Green Deal

text: The Just Transition Mechanism provides a comprehensive set of support options for the most vulnerable regions. The Just Transition Fund, the first pillar, will provide €17.5 billion in EU grants available to the most affected territories, implying a national co-financing requirement of around €10 billion. The second pillar creates a specialized transition plan under InvestEU to leverage private investment. Finally, a new public sector credit facility is formed under the third pillar to leverage public finance. These measures will be accompanied by specialized advisory and technical assistance for the affected regions and projects.


title: European Green Deal

text: The European Investment Bank Group will be able to support this through Structural Programme Loans in conjunction with European structural and investment funds (ESIF) co-financing operations.


title: European Green Deal

text: At COP26, the European Investment Bank announced a set of just transition common principles agreed upon with multilateral development banks, which also align with the Paris Agreement. The principles refer to focusing financing on the transition to net zero carbon economies, while keeping socioeconomic effects in mind, along with policy engagement and plans for inclusion and gender equality, all aiming to deliver long-term economic transformation.


title: European Green Deal

text: The African Development Bank, Asian Development Bank, Islamic Development Bank, Council of Europe Development Bank, Asian Infrastructure Investment Bank, European Bank for Reconstruction and Development, New Development Bank, and Inter-American Development Bank are among the multilateral development banks that have vowed to uphold the principles of climate change mitigation and a Just Transition. The World Bank Group also contributed.


title: European Green Deal

text: The current proposals have been criticised for falling short of the goal of ending fossil fuels, or being sufficient for a green recovery after the COVID-19 pandemic. The European Environmental Bureau as well as the International Energy Agency (IEA) stated that fossil fuel subsidies would need to end. However, it should be stated that this can not be done until 2021, when the Energy Taxation Directive is to be revised. Also, while fossil fuels are still actively being subsidized by the EU until 2021, even during an economic recession, it is also already working on supporting electrification of vehicles and green fuels such as hydrogen.


title: European Green Deal

text: Due to a combination of unfavourable conditions, which involved soaring demand of natural gas, its diminished supply from Russia and Norway to the European markets, less power generation by renewable energy sources such as wind, water and solar energy, and cold winter that left European and Russian gas reservoirs depleted, Europe faced steep increases in gas prices in 2021. Hungarian Prime Minister Viktor Orbán blamed a record-breaking surge in energy prices on the European Commission's Green Deal plans. "Politico" reported that "Despite the impact of high energy prices, [EU Commissioner for Energy] Simson insisted that there are no plans to backtrack on the bloc's Green Deal". European Commission President Ursula von der Leyen said that "Europe today is too reliant on gas and too dependent on gas imports. The answer has to do with diversifying our suppliers ... and, crucially, with speeding up the transition to clean energy."


title: European Green Deal

text: The New European Bauhaus is an artistic movement initiated by the European Commission, more precisely by the President of the European Commission, Mrs. Ursula von der Leyen herself. Its aim is to implement the European Green Deal through culture by integrating esthetics, sustainability and inclusiveness.


title: European Green Deal

text: The New European Bauhaus (NEB) is an interdisciplinary movement which intends to re-express the fundamental ambitions of the historical Bauhaus movement generated by the German architect Walter Gropius, in order to deal with contemporary issues from the fields of creation : art, crafts, design, architecture and urban planning.


title: European Green Deal

text: The New European Bauhaus being "new" it is currently still being developed by a multicultural and international Research Committee headed by an artist, Alexandre Dang.


title: European Green Deal

text: However the name who has been chosen is strongly criticized in some artistic communities as being "inherently not inclusive".


title: European Green Deal

text: This movement wanting to be as open and accessible as possible, this will be facilitated by a planification in three phases : the Design phase (2020-2021), the Delivery phase (2021-2023+) and the Dissemination phase (2023-2024+).


title: European Green Deal

text: As a first step, the Design phase was about finding methods that could boost existing ideas related to the NEB's challenges, regarding culture and technology. These two notions are considered by the New European Bauhaus as determinant elements to face contemporary concerns, especially in architecture and urban planning sectors. By launching a call for proposals, acceleration services and financial contribution started to be provided to some projects under European Union funding programs, such as Horizon Europe or LIFE programme, but also international organisations.


title: European Green Deal

text: In the idea of a collective design dynamic, a "High-level roundtable" has been set up with 18 thinkers and practitioners, involving for example famous architects Shigeru Ban and Bjark Ingels, the President of the Italian National Innovation Fund Francesca Bria, the activist and academic Sheela Patel, and others.


title: European Green Deal

text: After the Design phase, the Communication of the European Commission "New European Bauhaus Beautiful, Sustainable, Together" was released on 15 September 2021. The detailed content of this communication directly led to the Delivery phase, which began by setting up five pilots projects. These projects were selected as flagship proposals for the NEB's announced goal : "a sustainable green transformation in housing, architecture, transportation, urban, and rural spaces as part of its effort to reach carbon neutrality by 2050". In fact, one of the fundamental points of the New European Bauhaus, that is put forward by the European Commission, is to translate the European Green Deal, officially approved in 2020, to make it a tangible cultural experience in which citizens from all around the world could participate.


title: European Green Deal

text: Referring to the major principles of the original Bauhaus movement, the NEB initiative wants to be multi-level : "from global to local, participatory and transdisciplinary". By initiating a co-design process, views and experiences of thousands of citizens, professionals and organisations across the EU, and beyond, were involved into open conversations. Emerging from this collective thinking, the three terms highlighted to define the movement are "Sustainability" (including climate goals, circularity, zero pollution and biodiversity), "Aesthetics" (quality of experience and style, beyond functionality) and "Inclusion" (including diversity first, securing accessibility and affordability). The four thematic axes chosen to guide the NEB's implementation for the next years are "Reconnecting with nature", "Regaining a sens of belonging", "Prioritising the places and people that need it most", and "Fostering long term, life cycle thinking in the industrial ecosystem". The three levels of interconnected transformations expected from the initiative are "changes in places around us", "changes in the environment that enable innovation" and "changes in the diffusion of new meanings".


title: European Green Deal

text: During the Dissemination phase, the New European Bauhaus planned to focus on spreading chosen ideas and concepts to a broader audience, not only inside the EU. Within the three-phases development, this last step should be about networking and sharing knowledge between practitioners on available methods, solutions and prototypes, but also, it is meant to help creators to replicate their experiences across cities, rural areas and localities and to influence the new generation of architects and designers.


title: European Green Deal

text: In spring 2021, the European Commission launched New European Bauhaus prizes to reward inspiring examples of the realizations fitting the NEB principles. For the first edition of the contest, Commissioners Ferreira and Gabriel awarded 20 projects in a ceremony in Brussels on 16 September 2021. A second edition of NEB prizes is taking place in 2022.


title: European Green Deal

text: The NEB LAB, or New European Bauhaus Laboratory, has been established as a meeting space to work with the New European Bauhaus growing community, which is more than 450 official partners, High-Level Roundtable members, Contact Points of the national governments, and winners and finalists of the New European Bauhaus prizes. The NEB LAB's main objective is to put the movement's thinking into practice, by co-creating and testing solutions and policy actions, like the development of labeling tools. It has started with a "Call for Friends of the New European Bauhaus", in order to get public entities, companies and political organisations involved.


title: European Green Deal

text: The opening of a New European Bauhaus Festival has been announced by the European Commission to allow visibility for creators, to encourage them to "showcase" their ideas and share their progress, but also to enable networking and to foster citizen engagement. It will stand on three pillars : Fair (presentation of completed projects or products), Fest (the cultural section, with artists and performance) and Forum (debates with innovative participatory formats).


title: European Green Deal

text: Its first edition will take place on 9–12 June 2022 in Brussels. Based on this experience, the commission will draw up a concept for a yearly event that will include places in and outside the EU from 2023 onwards.


title: British Rail Class 66

text: The Class 66 is a type of six-axle diesel-electric freight locomotive developed in part from the , for use on the railways of the UK. Since its introduction the class has been successful and has been sold to British and other European railway companies. In Continental Europe it is marketed as the EMD Class 66 (JT42CWR).


title: British Rail Class 66

text: On the privatisation of British Rail's freight operations in 1996, Wisconsin Central Transportation Systems under the control of Ed Burkhardt bought a number of the newly privatised rail freight companies: Transrail Freight, Mainline Freight, Loadhaul, and later, Railfreight Distribution and Rail Express Systems; thus controlling 93% of UK rail freight. After a public relations exercise involving the input of the general public, the company was named English Welsh & Scottish Railway (EWS).


title: British Rail Class 66

text: EWS inherited a fleet of 1,600, mainly diesel, locomotives, with an average age of over 30 years; 300 had been cannibalised for spares. Typical of the fleet, the 2,580 hp Class 47s needed a major overhaul every seven years, costing £400,000; yet had an average daily availability of less than 65% with only 16 days between major failures. To enable it to offer its stated lower pricing to customers, EWS needed to reduce operating costs and increase availability.


title: British Rail Class 66

text: After reviewing the existing privately commissioned , which was more powerful, highly reliable and with lower operating costs, EWS approached its builder Electro-Motive Diesel (EMD), then a division of General Motors. EMD offered their JT42CWR model, which had the same loading gauge-passing bodyshell as the Class 59. The engine and traction motors were different models to enable higher speeds, and the Class 66s incorporated General Motors' version of a "self-steering bogie" ("radial truck", in American usage), designed to reduce track wear and increase adhesion on curves.


title: British Rail Class 66

text: Placing what was termed as "the biggest British loco order since steam days", EWS placed an order for 250 units in May 1996 to be built at the EMD plant in London, Ontario, Canada at a cost of £375 million. Financed by Locomotion Capital (later Angel Trains), the first locomotives were ready in early 1998; the fastest delivery of an all-new locomotive type by GM.


title: British Rail Class 66

text: The EMD 710 12-cylinder diesel engine is a development of a two-stroke engine used for over 20 years, whilst the EM2000 control equipment is the same as that used on Irish Railways IE 201 Class. EWS reduced the locomotive's time into operation through specifying cab systems laid out like the Class 59, whilst increasing availability with a fuel tank of capacity, compared to on a standard Class 47.


title: British Rail Class 66

text: The first locomotive shipped to the UK arrived at Immingham in June 1998, taken to Derby for testing. The second was taken to AAR's Pueblo Test Centre for endurance testing, before shipping to the UK. The locomotives then shipped at a rate of 11 per month into the UK via Newport Docks, until the order was completed in December 2001. After unloading, EWS engineers then simply took off the tarpaulin, unblocked the suspension, and finally as each was shipped with water and fuel, connected the batteries, before starting the engine and handing the locomotive into service. The ability to simply start up '66s' on the dockside and drive them under their own power to depots to enter service was nothing short of a revelation compared with many other BR locomotives, particularly the BR Class 60s.


title: British Rail Class 66

text: Each locomotive is specified and guaranteed to 95% availability, aiming for a minimum of 180 days mean time between failures. It is designed to cover 1.6 million km between major rebuilds, equivalent to 18 years' service, with each major rebuild costed at £200,000.


title: British Rail Class 66

text: The initial classification was as Class 61, then they were subsequently given the Class 66 designation in the British classification system (TOPS). In 1998 Freightliner placed an order for locomotives. They were followed by GB Railfreight, and then Direct Rail Services. The last of more than 500 built over an 18-year period was No 66779, "Evening Star", delivered to GB Railfreight in spring 2016.


title: British Rail Class 66

text: Although sometimes unpopular with many rail enthusiasts, due to their ubiquity and having caused the displacement of several older types of (mostly) British built locomotives, their high reliability has helped rail freight to remain competitive. Rail enthusiasts labelled the type "The Red Death" as they displaced many older types of locomotive whilst also acquiring the nicknames of "sheds" for the EWS (now DBS) locomotives (due to their upturned roof looking like a shed roof) with the Freightliner locomotives being called "Freds" as a portmanteau of "Freightliner" and "Shed".


title: British Rail Class 66

text: The Class 66 design has also been introduced to Continental Europe where it is currently certified for operations in Germany, the Netherlands, Belgium, Luxembourg, Sweden, Norway, Denmark, France, and Poland, with certification pending in the Czech Republic and Italy. They currently operate on routes in Sweden and Denmark and between Germany, Belgium, The Netherlands and Poland. As a result of its well-known British identity, EMD Europe markets the locomotive as "Series 66".


title: British Rail Class 66

text: By 2011, following an increase in UK rail traffic after the 2008 Global Economic Crisis, EMD were struggling to source critical components of the locomotive — specifically castings. The final units of the Class 66 were produced in the London, Ontario plant that year following an industrial dispute and the introduction of new EU crash and emissions regulations which culminated in the cessation of production.


title: British Rail Class 66

text: Due to a reduction in European freight volumes, since mid-2012, a number of EMD Series 66 locomotives have been imported by UK rail freight operators and converted to UK type specifications. To date:


title: British Rail Class 66

text: In September 2013, GB Railfreight announced a new order of a further 8 Class 66/7 locomotives from EMD, the first of the class to be built at EMD's Muncie, Indiana plant. On 2 February GBRf ordered a further 13 locomotives. These 21 locomotives are numbered 66752-772. Numbers 66752-756 were shipped from America and arrived at Newport Docks in July 2014. No. 66752 has been named "The Hoosier State", a nickname for Indiana. A further seven locomotives (66773-779) were later added to the fleet, utilising six power units that had been in the UK, plus one recovered from the scrapped 66734. The presence of these power units in the UK circumvented European emission compliance regulations and permitted them to be exported to EMD Muncie for installation in further class 66 bodyshells.


title: British Rail Class 66

text: Numbers 66752-779 were the last Class 66s ordered for service in Great Britain because of increasingly stringent emission regulations. 66779 was the last Class 66 ever to be built. Although the Class 66s meet stage 3a of the regulations, they do not meet stage 3b. Stage 3b would have required additional exhaust treatment equipment that could not easily be accommodated within the UK loading gauge. The same restrictions apply to the and Class 70. The restriction does not apply to second-hand locomotives, provided that they are imported from within the European Union. The purpose of the regulation was to put a cap on the total number of non-compliant locomotives in the EU.


title: British Rail Class 66

text: Colas Rail took over the ex-Advenza Cemex Cement flow after the company went bust, initially using the five former Advenza Freight and Direct Rail Services locomotives 66406-410 which had been renumbered 66841-845. Subsequently, as part of a deal with GB Railfreight, Colas Rail replaced them with five ex-Freightliner 66573-577 which were renumbered 66846–850. The five ex-Direct Rail Services class 66s were transferred to GB Railfreight and renumbered 66742–746.


title: British Rail Class 66

text: DB Cargo UK bought out EWS. Their Class 66 fleet includes four locomotives capable of banking heavy trains over the Lickey Incline. On these specific locomotives, the knuckle coupler has been modified to allow remote releasing from inside the cab, whilst in motion. It also includes fifteen locomotives fitted with RETB signalling equipment, for working in northern Scotland and RETB-fitted branchlines. A few DB Cargo UK Class 66s are now working in Europe as part of DB Cargo France and DB Cargo Polska.


title: British Rail Class 66

text: Direct Rail Services (DRS), which at the time was a subsidiary of British Nuclear Fuels (BNFL), ordered ten Class 66/4 locomotives (66401–410) in 2002, employed on new Anglo-Scottish traffic, some with Stobart Rail. In 2006, ten more T2 specification units (66411–420) were delivered, a further ten (66421–430) in late 2007, and four more (66431–434) in 2008.


title: British Rail Class 66

text: After the first 20 Class 66s operated by DRS were transferred to Freightliner and GB Railfreight, leaving just 14 in their fleet, DRS leased the five former Fastline Freight locomotives.


title: British Rail Class 66

text: Freightliner followed EWS by initially ordering five new Class 66/5 locomotives, and have continued to order in small batches. As of 2020, the Class 66/5 fleet had reached 89 examples; 66521 was withdrawn after the 2001 crash at Great Heck and later scrapped.


title: British Rail Class 66

text: In 2000 a new Class 66/6 sub-class was built, with a lower gear ratio, enabling heavier trains to be hauled, albeit at slower speed. There are presently 25 examples of this class, numbered 66601-625. Some of these locomotives have since been exported for use with Freightliner Poland.


title: British Rail Class 66

text: During 2004 the company took delivery of the most recent Class 66/9 sub-class of the locomotive, which are a low-emission variant. All new locomotives for all companies are now of the low-emission "T2" type. The seven such locomotives as 66951-957.


title: British Rail Class 66

text: GB Railfreight initially leased seventeen Class 66/7 locomotives, before increasing its fleet to 32. During April 2006 five more low-emission locomotives (numbered 66718-722) were delivered, liveried for use on the Metronet/Transport for London contracts. A further order for five more locomotives (66723-727) was delivered in early 2007, and another five locomotives (66728–732) in April 2008. 66733-746 are formed of Class 66s from Direct Rail Services, Freightliner and Colas Rail. In 2011 66720 was painted in a special "Rainbow" livery. In June 2012, 66734 derailed at Loch Treig whilst working 6S45 North Blyth–Fort William and was consequently cut up on site and scrapped.


title: British Rail Class 66

text: The final seven Class 66s to be built for the British market arrived on 12 February 2016 aboard the cargo ship "Happy Dragon" at Newport docks and consisted of numbers 66773–779. On 15 February they were towed by 66708 north to Doncaster Roberts Road depot where they were commissioned and then put to work.


title: British Rail Class 66

text: 66779 remained under a tarpaulin until 10 May 2016 when it was revealed at the NRM York with a special livery and nameplates to commemorate the fact it is the final Class 66 ever built for the British market. The locomotive has been painted in BR Lined Green and named "Evening Star", in reference to BR Standard Class 9F 92220 "Evening Star" which was the last BR steam locomotive to be built. It was unveiled in a special ceremony inside the Great Hall at the National Railway Museum in York on 10 May 2016 before staying there opposite its namesake, No. 92220, for two weeks. At the same ceremony, the CEO of GBRf, John Smith, handed the curator of the National Railway Museum a document offering 66779 to the national collection when it is retired in about 40 years time.


title: British Rail Class 66

text: In addition to those locomotives sourced from domestic operators (Direct Rail Services, Freightliner, Colas Rail and DB Cargo UK), eight further locomotives have been obtained from European operators. A further five have been purchased from Heavy Haul Power International and will be transferred from Germany beginning in April 2021. The locos will go to Doncaster to be converted to UK specification.


title: British Rail Class 66

text: Advenza Freight, a Cotswold Rail subsidiary, operated Class 66841-844. They were primarily used on Advenza's scrap and cement flows. The locomotives originated from the batch that Direct Rail Services returned.


title: British Rail Class 66

text: Advenza Freight ceased operations in October 2009 and the Class 66s returned to storage. These locos were housed at Gloucester Carriage Sidings where Advenza Freight was based.


title: British Rail Class 66

text: Fastline operated intermodal services between Doncaster and Birmingham International Railfreight Terminal (BIFT), and Thamesport, in North Kent, using refurbished locomotives. The company ordered five Class 66/3 locomotives to operate a coal flow from Hatfield Colliery, which were delivered in 2008.


title: British Rail Class 66

text: Following the demise of Jarvis in 2010, and Fastline going into administration on 29 March 2010, these locomotives were placed in storage, being towed to Direct Rail Services' Carlisle Kingmoor and Crewe Gresty Lane depots for storage. During 2011, DRS repainted the five ex-Fastline locomotives and added them to their own fleet, keeping their original numbers.


title: British Rail Class 66

text: The British train drivers' union ASLEF has complained that the locomotives are unfit and unsafe to work in, citing excessive heat, noise levels and poor seating.


title: British Rail Class 66

text: In April 2007, ASLEF proposed a ban on their members driving the locomotives during the British summer 2007 period. Keith Norman, ASLEF's general secretary, described the cabs as "unhealthy, unsafe and unsatisfactory". Research showed that in July 2006, when the weather had been extremely hot, the number of incidents where a driver had passed a signal at danger (SPAD) increased. EWS entered into discussions and made amendments to a series of trial locomotives, GB Railfreight and Freightliner also investigated cab improvements. In June 2007, progress on the issue led ASLEF to withdraw its threat of industrial action.


title: British Rail Class 66

text: In Norway, CargoNet related complaints about the noise levels in the CD66 variant of the Class 66 resulted in higher pay rates for drivers.


title: British Rail Class 66

text: Minor differences between different orders, and different operating companies have resulted in a number of subclasses being defined.


title: British Rail Class 66

text: In 2006 Hornby Railways launched its first version of the BR Class 66 in OO gauge range in a variety of liveries.


title: WWE Hall of Fame (2021)

text: The 2020-2021 WWE Hall of Fame was a professional wrestling event produced by WWE that featured the induction of the 21st and 22nd classes to the WWE Hall of Fame. Due to the COVID-19 pandemic, the 2020 Hall of Fame ceremony did not occur – as a result, the originally announced Class of 2020 was inducted alongside the Class of 2021 at the 2021 induction ceremony. The event was taped on March 30 and April 1, 2021 at the WWE ThunderDome, hosted at Tropicana Field in St. Petersburg, Florida, and aired on April 6 on Peacock in the United States and the WWE Network internationally. Jerry Lawler served as the host for the Class of 2020 portion of the show while Corey Graves and Kayla Braxton were the hosts of the Class of 2021.


title: WWE Hall of Fame (2021)

text: The 2020 WWE Hall of Fame ceremony was originally scheduled to take place on April 2, 2020 from the Amalie Arena in Tampa, Florida, as part of WrestleMania 36 week, and would have aired live on the WWE Network. However, the event was postponed due to the COVID-19 pandemic. On August 27, 2020, it was announced that the 2020 Class would be inducted alongside the Class of 2021 during WrestleMania 37 week; WrestleMania 37 itself was relocated to Tampa from its original location of Los Angeles, California. It was later confirmed that the 2021 ceremony would take place at the WWE ThunderDome at Tropicana Field in St. Petersburg, Florida. The event was pre-taped on March 30 and April 1 to air on April 6 on Peacock's WWE Network channel in the United States and on the standard WWE Network internationally. Fan reactions for the ThunderDome's virtual fans were also filmed ahead of time. There were no inductors for the Hall of Fame recipients. Instead, Jerry Lawler, Corey Graves, and Kayla Braxton hosted the show—with Lawler hosting the 2020 portion of the show and Graves and Braxton hosting the 2021 portion—and short video packages were played before the inductees made a short speech, which was limited to five minutes.


title: WWE Hall of Fame (2021)

text: The first inductees for the 2020 Class of the WWE Hall of Fame were announced on December 9, 2019. The first of these was the New World Order (nWo). The members recognized for this induction were "Hollywood" Hulk Hogan, Kevin Nash, Scott Hall, and Sean Waltman. This induction makes each of these members two-time inductees, with Hogan, Hall, and Nash previously being inducted for their individual careers and Waltman being previously inducted as part of D-Generation X in 2019, which also makes Waltman the first back-to-back inductee. The next inductees were announced during Alexa Bliss' segment of "A Moment of Bliss" on the February 21, 2020 episode of "SmackDown", where she announced that The Bella Twins (Brie Bella and Nikki Bella) would be inducted into the 2020 Class. This was followed up on the March 3 episode of "WWE Backstage", where it was announced that John "Bradshaw" Layfield would be inducted. On the March 12 episode of the "WWE After the Bell" podcast, host Corey Graves revealed that The British Bulldog would be inducted posthumously, while on March 16, WWE and Yahoo! Japan announced that Japanese wrestler Jushin "Thunder" Liger would be inducted. On March 30, 2021, William Shatner was announced as an inductee into the Celebrity Wing of the Hall of Fame; Shatner was announced as part of the Class of 2020 instead of 2021 as he was originally intended to be inducted in 2020. On March 31, "Fightful Select" reported that Titus O'Neil received the 2020 Warrior Award during the 2021 induction ceremony as he was also originally intended to be inducted in 2020.


title: WWE Hall of Fame (2021)

text: On March 10, 2021, Molly Holly was announced as the first inductee into the Class of 2021. Her announcement as the first inductee was made on "WWE The Bump" by her former tag team partner, The Hurricane. Eric Bischoff was announced as the next inductee into the 2021 Class during the "WWE After the Bell" podcast on March 18. According to Sean Waltman, the original idea was to induct Bischoff as a surprise member of nWo in 2020. On March 24, Kane and The Great Khali were announced as the next inductees into the 2021 Class, with Kane's announcement made by The Undertaker on "WWE The Bump" and Khali's made by Ranjin Singh on "WWE Now India". On March 23, "Fightful"s Sean Ross Sapp reported that Rob Van Dam (RVD) would be inducted as part of the 2021 Class. Sabu, who worked with RVD in both Extreme Championship Wrestling and WWE, also affirmed this report. RVD's induction was officially confirmed by WWE via Fox Sports on March 29. On April 4, Dave Meltzer of the "Wrestling Observer Newsletter" reported that Ozzy Osbourne was inducted as the 2021 celebrity inductee. On April 6, it was confirmed that long-time WWE employee Rich Hering would receive the 2021 Warrior Award.


title: WWE Hall of Fame (2021)

text: On December 9, 2019, Batista had been announced as an inductee into the 2020 Class of the Hall of Fame. Prior to the 2021 event, however, his induction was retracted. "Fightful Select" reported that WWE wanted Batista to be inducted "when a full crowd can enjoy it." Batista himself posted to Twitter, confirming his removal, citing previous obligations as a reason for why he could not attend the 2021 event. He also said that WWE honored his request to induct him at a future ceremony.


title: The Challenge: Fresh Meat II

text: The Challenge: Fresh Meat II is the 19th season of the MTV reality game show, "The Challenge". "Fresh Meat II" is the sequel to the show's 12th season, "". Continuing with the precursor's advent of original contestants, "Fresh Meat II" also introduced a slew of previously unknown contestants who had never appeared on either "The Real World" or "Road Rules."


title: The Challenge: Fresh Meat II

text: Filmed in Whistler, British Columbia, "Fresh Meat II" featured two-player teams; each team had an alumnus of "The Real World", "Road Rules", or the original "Fresh Meat", partnered with a newcomer of the opposite gender to "The Challenge" (collectively known as the new "Fresh Meat"). A "Meet the Meat" special premiered on March 31, 2010. The season premiered on April 7, 2010, and concluded on June 9, 2010, with the reunion show. "Fresh Meat II" marked the second time in which the show was renamed, no longer using "Real World/Road Rules" as the main title, but simply "The Challenge", though host T. J. Lavin used "Real World/Road Rules Challenge" on the first episode in speaking to the contestants.


title: The Challenge: Fresh Meat II

text: "Fresh Meat II" follows the same format as the original "Fresh Meat" season. The only difference in format is that the teams do not participate in a follow-up challenge prior to the Exile elimination. Therefore, the teams nominated for Exile do not have a chance to win a pardon and replace themselves with a non-winning team from the previous mission, as was the case in original "Fresh Meat".


title: The Challenge: Fresh Meat II

text: At the end of the season, four teams will compete in the final challenge. First-place wins $200,000, second-place wins $60,000, third-place wins $40,000 and fourth-place wins nothing.


title: The Challenge: Fresh Meat II

text: Each of the 13 "Fresh Meat II" cast members participated in a combine, testing their strength, stamina, and mental ability. The alumni used the stats from each player's obstacle course performance to determine their partner.


title: The Challenge: Fresh Meat II

text: Other combine activities were completed (based on the stat sheets shown in the opening episode), but these activities as well as everyone's stats, were not shown in full.


title: The Challenge: Fresh Meat II

text: First, each team must paddle a canoe across a giant lake to a puzzle. Once they finish that, they can head to a helicopter. Reaching the helicopter first is very important because it determines the penalty that teams will have to take before they can continue on to the second part of the challenge. The team that wins the first phase gets a two-minute headstart, the second-place finisher gets a one-minute headstart while the third-place finisher gets a 30-second headstart. The second phase of the challenge starts with a giant Sudoku puzzle, followed by a mountain bike ride except that the two bikes are tied together with a rope so the teams will have to stay together. After a puzzle that involves carrying color-coded logs to match a diagram, the teams must climb a very steep mountain, carrying a heavy bag. Once completed with a numbered puzzle, they're given helmets and an ice axe and have to climb the top of the mountain. The first team to climb up the mountain and reaches the flag, wins "Fresh Meat II".


title: The Challenge: Fresh Meat II

text: "The Challenge: Fresh Meat II Reunion" was aired after the season finale and was hosted by Maria Menounos on June 9, 2010. The cast members who attended the reunion were: Kenny, Wes, Mandi, Carley, Landon, Jenn, Pete, Theresa, Ryan, Ev, Laurel, Noor, Danny and Jillian. A preview for "" is shown, thus ending another challenge reunion.


title: The Challenge: Fresh Meat II

text: On December 5, 2015, Theresa González and T. J. Jones welcomed their daughter, Easton Kaia, followed by their first son, Maddox, in April 2019. The couple's second daughter, Layla Capri, was born on July, 19, 2021.


title: The Challenge: Fresh Meat II

text: In 2017, Laurel Stucky appeared on MTV's "Fear Factor", where she was paired with Aneesa Ferreira. In 2019, she appeared on the fourth season of "Ex on the Beach" with former girlfriend Nicole Zanatta from "". The two first met on of "The Challenge". In 2020, she revealed she was a victim of sexual assault at the age of 21.


title: The Challenge: Fresh Meat II

text: In 2018, Cara Maria Sorbello appeared on "Fear Factor" alongside Chris Tamburello. In the same year, she also appeared on "How Far Is Tattoo Far?" with her boyfriend Paulie Calafiore. In 2019, Sorbello also appeared on "Game of Clones".


title: The Challenge: Fresh Meat II

text: In 2018, Vinny Foti was hospitalized after suffering heart failure. He is married to Krista Foti and they have two daughters.


title: Bromance

text: A bromance is a very close and non-sexual relationship between two or more men. It is an exceptionally tight, affectional, homosocial male bonding relationship exceeding that of usual friendship, and is distinguished from normal friendship by a particularly high level of emotional intimacy. The emergence of the concept since the beginning of the 21st century has been seen as reflecting a change in societal perception and interest in the theme, with an increasing openness of Western society in the 21st century to reconsider gender, sexuality, and exclusivity constraints.


title: Bromance

text: "Bromance" is a portmanteau of "bro" (or "brother") and "romance". Dave Carnie is credited with coining the term as editor of the skateboard magazine "Big Brother" in the 1990s to refer specifically to the sort of relationships that develop between skaters who spent a great deal of time together. The term did not attain broad currency until approximately 2005 when the theme became more prominent in the motion picture industry.


title: Bromance

text: "Bromance" has been examined from viewpoints such as historiography, discourse analysis, social research, and queer theory in book-length reviews. The emergence of "bromance" as a topic over the past decade has been seen as reflecting how society has collectively changed its perception and interest in the theme.


title: Bromance

text: According to Chen, society has taken a collective interest in reexamination of some of the traditional constraints on male friendship, and in potentially reshaping the constructs of gender, sexuality, and intimacy. Bromance provides "a case study of gender, sexuality, and exclusivity constraints in twenty-first century America as they operate in law and beyond. Those constraints in turn speak to the privilege and subordination imbued in this type of relationship, with implications for other types as well." This is distinct from the connotations of "romantic friendship", a term of 20th century historical scholarship that retrospectively described close homosocial relationships, which had become less common after potential physical intimacy between non-sexual partners came to be regarded with anxiety in the second half of the 19th century.


title: Bromance

text: On the one hand, social interest in the theme has been seen as driving the film industry, which has then fed back to society at large, exploring peoples' mindsets and addressing acceptance of "other types of relationships" between people. On the other hand, some have seen the emphasis on platonic love as a rejection of homoeroticism, or as a deliberate confounding of "homosocial" and "homoerotic" relationships.


title: Bromance

text: "Bromance" has also been seen as a reflection of greater "discursive expressivity". The experiences of friendship and masculinity, perhaps due to more open parenting styles from the 1970s, reflect a trend toward more openness emotionally, with increased expressivity. According to sociologist Peter Nardi, "men are less afraid of being perceived as gay. It has become more acceptable for them to show some emotion." Men are marrying later, if at all, which impacts male bonding. According to the 2010 US Census, the average age of a man's first marriage is 28, up from 23 in 1960; men with more education are waiting until their 30s before getting married.


title: Bromance

text: A number of celebrity relationships have been popularly characterised as ""bromances"". Although "bromance" is a new term, this treatment of celebrity relationships is not new: The composer Franz Schubert had a very close friendship with poet Franz von Schober, whose texts Schubert set to music. They were nicknamed ""Schobert"" in early 19th century Vienna.


title: Bromance

text: Dean Martin and Jerry Lewis as the 1946-1956 ‘rock star’ comedy team Martin and Lewis set a new standard for a complex, multifaceted enactment of a ‘special’ male friendship." Coming post-war, "the comedy of Martin and Lewis teased with a sly alternative to the model of heterosexual affirmation traditionally peddled by Hollywood, as their intense and unstable relationship showcased a panoply of emotional and erotic intensities between men. The cultural resonance of Martin and Lewis's comedy derived from the way it set in motion a more complex ‘queering of gender.’" They starred in 16 films together as an inseparable unit, as well as on early live television and in nightclubs. They had an immeasurable effect on millions of baby boomers and future comedians, (including George Clooney, whose aunt Rosemary Clooney was a guest on their show).


title: Bromance

text: Ben Affleck and Matt Damon were described as "perhaps "the" pioneering bromance in showbiz history", which led to an off-Broadway play called "Matt and Ben". The relationship between Zachary Quinto and Chris Pine, stars of the 2009 "Star Trek" film, has been described similarly, in common with their on-screen characters' relationship.


title: Bromance

text: The close friendship between George Clooney and Brad Pitt was once suggested to be "George's longest-lasting affair". Clooney's bromantic tendencies served as the basis for an episode of the animated series "American Dad!" entitled "Tears of a Clooney", in which lead character Stan Smith becomes bromantically involved with Clooney as part of an elaborate revenge plot.


title: Bromance

text: Professional footballers Eric Dier and Dele Alli, who played together for both Tottenham Hotspur and the English national team, have a close relationship that has been described as a "bromance".


title: Bromance

text: During the 2016 Olympic 100m finals, the friendship between Jamaican Usain Bolt and Canadian Andre De Grasse emerged, characterized and celebrated on social media as a bromance.


title: Bromance

text: Bodybuilders Arnold Schwarzenegger and Franco Columbu, had a close relationship described by themselves as bromance, since 1965. Arnold and Franco were inseparable friends and training partners since then. They began a bricklaying and patio business called European Brick Works in 1969.


title: Bromance

text: The tight relationship both on- and off-stage between Bruce Springsteen and the late E Street Band saxophonist Clarence Clemons has often been described as one of the most fitting examples of "bromance" in Western modern music. This relationship is most notably depicted in Springsteen's song "Tenth Avenue Freeze-Out", from "Born to Run" – in which Springsteen and Clemons appear respectively under their pseudonyms Bad Scooter and Big Man. It was also described in Clemons' autobiography "Big Man: Real Life & Tall Tales".


title: Bromance

text: The Japanese and Korean music industry actively encourages bromance among male celebrities (particularly members of boy bands) as part of the fan service to please the audience.


title: Bromance

text: While the term has generally been applied to straight relationships, mixed gay-straight relationships without sexual intimacy have also been dubbed ""bromances"". Examples of well-known gay-straight bromances include George Michael and Andrew Ridgeley from the band Wham!, Ronnie Kroell and Ben DiChiara from the Bravo reality series "Make Me a Supermodel", in which the pair was nicknamed "Bronnie", the relationship on "" between Charlie Herschel and Marcus Lehman, and "American Idol"s Kris Allen and Adam Lambert, which was given the name "Kradam".


title: Bromance

text: Buddy films have to a degree been rebranded as "bromance" films, although critics draw a distinction between the two, noting that a buddy film tends to be more explicitly violent and less open about its latent homosexual content. The intersection between buddy films and what would come to be called the bromance film was noted comedically at least as early as 1978, when "National Lampoon" ran a parody ad for the football-themed buddy film "Semi-Tough", renamed "Semi-Sweet" and featuring an illustration of stars Burt Reynolds and Kris Kristofferson holding hands.


title: Bromance

text: Prominent examples of bromantic comedy include Judd Apatow's "The 40-Year-Old Virgin" (2005) and "Knocked Up" (2007), as well as Greg Mottola's "Superbad" (2007), which targeted non-sexual homosocial behavior and masculinity in inventive ways. "Zoolander" (2001), "Wedding Crashers" (2005), "Funny People" (2009), John Hamburg's "I Love You Man" (2009), "The Hangover" (2009), and "Horrible Bosses" (2011) are other examples.


title: Bromance

text: Although J. R. R. Tolkien's novels predate the "bromance era", the portrayal of the lifelong close relationships between Frodo Baggins and Samwise Gamgee, Meriadoc Brandybuck and Peregrin Took, and Gimli and Legolas in the novels have been characterized as bromance, as well as the depictions in the films based on them.


title: Bromance

text: The theme remains popular, with different genres looking at the concept in various ways, such as the documentary "Best of Enemies" – about the 1960s feud between intellectuals Gore Vidal and William F. Buckley.


title: Bromance

text: Bromance on television has also become more commonplace. It appeared early-on in the partnership of two CIA/KGB spies in the 1960s' "Man from U.N.C.L.E.", and in the 1970s' buddy-cop show "Starsky & Hutch", which producer Aaron Spelling called "TV's first heterosexual love affair". Some critics also point to the 1970s' "Odd Couple", about which executive producer Garry Marshall has said, "The network was concerned that we were being too gay."


title: Bromance

text: In October 2008, "TV Guide" placed Gregory House (Hugh Laurie) and James Wilson (Robert Sean Leonard) on the cover, under the headline "Isn't It Bromantic?".


title: Bromance

text: Brody Jenner, featured on MTV's reality show "The Hills" and the subject of bromance discussions for his relationships with castmates Justin Bobby and Spencer Pratt, debuted his own series on the network, called "Bromance", on December 29, 2008. The six-episode series features Jenner selecting from amongst competitors to become part of Jenner's "entourage".


title: Bromance

text: In "Scrubs", J.D. is a sensitive doctor "completely in touch with his feelings. He's not afraid of showing his best pal Turk how much he loves him." In one episode, they sing, "Guy love. That's all it is." "The Good Guys" "promotes male bonding while self-consciously acknowledging its homoerotic overtones." "The Independent" analyzed the BBC's "Sherlock" as a "bromance", and looked at bromance thematically. The relationship between Sherlock Holmes and Dr. Watson as a bromance has been visited elsewhere also.


title: Bromance

text: British television presenters and producers Anthony McPartlin and Declan Donnelly are known for their unbreakable friendship on-screen and off-screen.


title: Bromance

text: The cultural concept that "bromance" connotes particular closeness has been taken up thematically. The concept has been visited in biology, as well as an experimental acrobatic video dance piece, "Bromance", which explores "... the intimacy of physical interaction between guys; of their ‘bromance’."


title: Bromance

text: The relationship between George W. Bush and former press secretary Scott McClellan as told in McClellan's book "What Happened" was called by one reviewer "the tale of one long, failed bromance".


title: Bromance

text: In 2012, the song "Bromance" by comedian, YouTube personality, and actor Ryan Higa (also known by his YouTube username "nigahiga"), went viral. Before that a song by Tim Berg called "Seek Bromance" attained success.


title: Bromance

text: The former premiers Dalton McGuinty of Ontario (2003–2013) and Jean Charest of Quebec (2003–2012) were described as in a "burgeoning bromance". Stephen Harper of Canada (2006–2015) and Tony Abbott of Australia (2013–2015), and their respective countries, were characterized as having a "conservative bromance". The term has been used to describe Narendra Modi from India and Barack Obama from the United States during the January 2015 visit, and Vladimir Putin from the Russian Federation with Gerhard Schröder from Germany.


title: Bromance

text: In early 2017, a number of internet memes surfaced which alluded to Obama's relationship with Vice President Joe Biden as a "bromance".


title: Bromance

text: A bromance has been linked with a decrease in "problems such as anxiety, depression, heart disease, and memory and concentration impairment".


title: Amr Waked

text: Amr Waked ( ; born ) is an Egyptian film, television and stage actor. He is best known to international audiences and in Hollywood for his role in the 2005 film "Syriana". Other prominent roles include a Yemeni Sheikh called Muhammad in "Salmon Fishing in the Yemen", Pierre Del Rio in Luc Besson's "Lucy" and Farouk Hassan in "Ramy. "


title: Amr Waked

text: In 2019, Waked was sentenced to eight years in prison by an Egyptian military court for spreading false news and insulting state institutions. For that reason, he has no intention of returning to Egypt. He has been residing in Spain since October 2017.


title: Amr Waked

text: Waked's first major role was in "Ashab wallah business" (2002) ("Are we friends or just a business"). Reviewers reported that he portrayed the role of "Gehad" so well that many viewers left the theater believing he was actually a Palestinian actor, rather than Egyptian. His first lead role was as Ahmed in "Deil el Samaka" ("The Fish's tail") (2003), and in 2005 he worked alongside George Clooney in the film "Syriana", for which in 2006 he won a 'Special Award for Arabs in The International Cinema' at the Cairo International Film Festival. Waked joined the cast of the Egyptian television series "Lahazat Harega" ("Critical Moments") in 2007, shooting 32 episodes for season one.


title: Amr Waked

text: In 2008, Waked joined the cast of the BBC/HBO television series "House of Saddam" to portray Saddam Hussein's son-in-law Hussein Kamel. Since the lead role of Saddam Hussein was played by Israeli actor Yigal Naor, Waked faced punishment by Egypt's Actors Union which opposes normalization of ties with Israel. The union threatened to ban him from all future projects in Egypt. Waked was also criticized by supporters of the Palestinian cause for taking acting role in "Wonder Woman 1984" starring Israeli actress and former IDF soldier Gal Gadot.


title: Amr Waked

text: In 2009, Waked co-hosted the 33rd Cairo International Film Festival, and in 2010 he rejoined the cast of "Lahazat Harega". He joined Hollywood stars Matt Damon, Jude Law, Kate Winslet, and Gwyneth Paltrow in the 2011 film, "Contagion" and co-starred in the British film "Salmon Fishing in the Yemen" with Emily Blunt, Ewan McGregor, and Kristin Scott Thomas. and also co-starred in "Lucy" alongside Morgan Freeman and Scarlett Johansson. In 2017, he moved to Spain and was sentenced to eight years in prison by an Egyptian court for making pro-democracy comments on social media. Due to these charges, Waked is not able to return to Egypt.


title: Maxims of equity

text: Maxims of equity are legal maxims that serve as a set of general principles or rules which are said to govern the way in which equity operates. They tend to illustrate the qualities of equity, in contrast to the common law, as a more flexible, responsive approach to the needs of the individual, inclined to take into account the parties' conduct and worthiness. They were developed by the English Court of Chancery and other courts that administer equity jurisdiction, including the law of trusts. Although the most fundamental and time honored of the maxims, listed on this page, are often referred to on their own as the 'maxims of equity' or 'the equitable maxims',The first equitable maxim is 'equity delights in equality' or equity is equality Like other kinds of legal maxims or principles, they were originally, and sometimes still are, expressed in Latin.


title: Maxims of equity

text: Maxims of equity are not a rigid set of rules, but are, rather, general principles which can be derived from in specific cases. Snell's "Equity", an English treatise, takes the view that the "Maxims do not cover the whole ground, and moreover they overlap, one maxim contains by implication what belongs to another. Indeed it would not be difficult to reduce all under two: 'Equity will not suffer a wrong to be without a remedy' and 'Equity acts on the person'".


title: Maxims of equity

text: Jeffrey Hackney has argued that maxims are more harmful than helpful in understanding equitable principles:


title: Maxims of equity

text: Apart from a vigorous life in law examinations at the pen of weaker candidates, most maxims do not today greatly figure in judicial language, and their principal harm is, by their banality, to reduce manifestations of justice to the level of simple chatter, and thereby to devalue the underlying conscience.


title: Maxims of equity

text: Sometimes phrased as "equity regards as done what should have been done", this maxim means that when individuals are required, by their agreements or by law, to perform some act of legal significance, equity will regard that act as having been done as it ought to have been done, even before it has actually happened. This makes possible the legal phenomenon of equitable conversion.


title: Maxims of equity

text: The consequences of this maxim, and of equitable conversion, are significant in their bearing on the risk of loss in transactions. When parties enter a contract for a sale of real property, the buyer is deemed to have obtained an equitable right that becomes a legal right only after the deal is completed. (For an English example, see "Walsh v Lonsdale".)


title: Maxims of equity

text: Due to his equitable interest in the outcome of the transaction, the buyer who suffers a breach may be entitled to the equitable remedy of specific performance (although not always, see below). If he is successful in seeking a remedy at law, he is entitled to the value of the property at the time of breach regardless of whether it has appreciated or depreciated.


title: Maxims of equity

text: The fact that the buyer may be forced to suffer a depreciation in the value of the property means that he bears the risk of loss if, for example, the improvements on the property he bought burn down while he is still in escrow.


title: Maxims of equity

text: Problems may sometimes arise because, through some lapse or omission, insurance coverage is not in force at the time a claim is made. If the policyholder has clearly been at fault in this connection, because, for example, he has not paid premiums when he should have, then it will normally be quite reasonable for an insurer to decline to meet the claim. However, it gets more difficult if the policyholder is no more at fault than the insurer. The fair solution in the circumstances may be arrived at by applying the principle that equity regards that as done that ought to be done. In other words, what would the position have been if what should have been done had been done?


title: Maxims of equity

text: Thus, we know in one case, premiums on a life insurance policy were overdue. The insurer's letter to the policyholder warning him of this fact was never received by the policyholder, who died shortly after the policy consequently lapsed. It was clear that if the notice had been received by the policyholder, he or his wife would have taken steps to ensure the policy continued in force, because the policyholder was terminally ill at the time and the coverage provided by the policy was something his wife was plainly going to require in the foreseeable future. Since the policyholder would have been fully entitled to pay the outstanding premium at that stage, regardless of his physical condition, the insurer (with some persuasion from the Bureau) agreed that the matter should be dealt with as if the policyholder had done so. In other words, his widow was entitled to the sum assured less the outstanding premium. In other similar cases, however, it has not been possible to follow the same principle because there has not been sufficiently clear evidence that the policy would have been renewed.


title: Maxims of equity

text: Another illustration of the application of this equitable principle was in connection with motor vehicle insurance. A policyholder was provided with coverage on the basis that she was entitled to a "no claims" discount from her previous insurer. Confirmation to this effect from the previous insurer was required. When that was not forthcoming, her coverage was cancelled by the brokers who had issued the initial coverage note. This was done without reference to the insurer concerned whose normal practice in such circumstances would have been to maintain coverage and to require payment of the full premium until proof of the no claims discount was forthcoming. Such proof was eventually obtained by the policyholder, but only after she had been involved in an accident after the cancellation by the brokers of the policy. Here again, the fair outcome was to look at what would have happened if the insurer's normal practice had been followed. In such circumstances, the policyholder would plainly have still had a policy at the time of the accident. The insurer itself had not acted incorrectly at any stage. However, in the circumstances, it was equitable for it to meet the claim.


title: Maxims of equity

text: When seeking an equitable relief, the one that has been wronged has the stronger hand. The stronger hand is the one that has the capacity to ask for a legal remedy (judicial relief). In equity, this form of remedy is usually one of specific performance or an injunction (injunctive relief). These are superior remedies to those administered at common law such as damages. The Latin legal maxim is "ubi jus ibi remedium" ("where there is a right there must be a remedy").


title: Maxims of equity

text: The maxim is necessarily subordinate to positive principles and cannot be applied either to subvert established rules of law or to give the courts a jurisdiction hitherto unknown, and it is only in a general not in a literal sense that the maxim has force.


title: Maxims of equity

text: Case law dealing with the principle of this maxim at law include "Ashby v White" and "Bivens v. Six Unknown Named Agents". The application of this principle at law was key in the decision of "Marbury v. Madison", wherein it was necessary to establish that Marbury had a right to his commission in the first place in order for Chief Justice Marshall to make his more wide-ranging decision.


title: Maxims of equity

text: This maxim flows from the fundamental notion of equality or impartiality due to the conception of Equity and is the source of many equitable doctrines. The maxim is of very wide application. The rule of ordinary law may give one party an advantage over the other. But the court of equity, where it can, puts the litigating parties on a footing of equality. Equity proceeds in the principle that a right or liability should as far as possible be equalized among all interested.


title: Maxims of equity

text: In other words, two parties have equal right in any property, so it is distributed equally as per the concerned law.


title: Maxims of equity

text: To receive equitable relief, the petitioning party must be willing to complete all of its own obligations as well. The applicant to a court of equity is just as much subject to the power of that court as the defendant. This maxim may also overlap with the clean hands maxim (see below).


title: Maxims of equity

text: A person who has been wronged must act relatively swiftly to preserve their rights. Otherwise, they are guilty of laches, an untoward delay in litigation with the presumed intent of denying claims. This differs from a statute of limitations, in that a delay is particularized to individual situations, rather than a general prescribed legal amount of time. In addition, even where a limitation period has not yet run, laches may still occur. The equitable rule of laches and acquiescence was first introduced in "Chief Young Dede v. African Association Ltd."


title: Maxims of equity

text: Generally speaking, near performance of a general obligation will be treated as sufficient unless the law requires perfect performance, such as in the exercise of an option. Text writers give an example of a debtor leaving a legacy to his creditor equal to or greater than his obligation. Equity regards such a gift as performance of the obligation so the creditor cannot claim both the legacy and payment of the debt.


title: Maxims of equity

text: Where a claimant is under an obligation to do one thing but does another, his action may be treated as close enough approximation of the required act. A claimant who has undertaken an obligation, will, through his later conduct be interpreted as fulfilment of that obligation.


title: Maxims of equity

text: In England, there was a distinction drawn between the jurisdiction of the law courts and that of the chancery court. Courts of law had jurisdiction over property as well as persons and their coercive power arose out of their ability to adjust ownership rights. Courts of equity had power over persons. Their coercive power arose from the ability, on authority of the crown, to hold a violator in contempt, and take away his freedom (or money) until he purged himself of his contumacious behavior. This distinction helped preserve a separation of powers between the two courts.


title: Maxims of equity

text: Nevertheless, courts of equity also developed a doctrine that an applicant must assert a "property interest". This was a limitation on their own power to issue relief. This does not mean that the courts of equity had taken jurisdiction over property. Rather, it means that they came to require that the applicant assert a right of some significant substance as opposed to a claim for relief based on an injury to mere emotional or dignitary interests.


title: Maxims of equity

text: Today, a mortgagor refers to his interest in the property as his "equity". The origin of the concept, however, was actually a mirror-image of the current practice.


title: Maxims of equity

text: At common law, a mortgage was a conveyance of the property, with a condition subsequent, that if the grantor paid the secured indebtedness to the grantee on or before a date certain (the "law" day) then the condition subsequent would be void, otherwise to remain in full force and effect. As was inevitable, debtors would be unable to pay on the law day, and if they tendered the debt after the time had passed, the creditor owed no duty to give the land back. So then the debtor would run to the court of equity, plead that there was an unconscionable forfeiture about to occur, and beg the court to grant an equitable decree requiring the lender to surrender the property upon payment of the secured debt with interest to date. And the equity courts granted these petitions quite regularly and often without regard for the amount of time that had lapsed since the law day had passed. The lender could interpose a defense of laches, saying that so much time had gone by (and so much improvement and betterment had taken place) that it would be inequitable to require undoing the finality of the mortgage conveyance. Other defenses, including equitable estoppel, were used to bar redemption as well.


title: Maxims of equity

text: This unsettling system had a negative impact on the willingness of lenders to accept real estate as collateral security for loans. Since a lender could not re-sell the property until it had been in uncontested possession for years, or unless it could show changed circumstances, the value of real estate collateral was significantly impaired. Impaired, that is, until lawyers concocted the bill of foreclosure, whereby a mortgagee could request a decree that unless the mortgagor paid the debt by a date certain (and after the law date set in the mortgage), the mortgagor would thereafter be barred and foreclosed of all right, title and equity of redemption in and to the mortgaged premises.


title: Maxims of equity

text: To complete the circle, one needs to understand that when a mortgagor fails to pay an installment when due, and the mortgagee accelerates the mortgage, requiring immediate repayment of the entire mortgage indebtedness, the mortgagor does not have a right to pay the past-due installment(s) and have the mortgage reinstated. In "Graf v. Hope Building Corp.", the New York Court of Appeals observed that in such a case, there was no forfeiture, only the operation of a clause fair on its face, to which the mortgagor had freely assented. In the latter 20th Century, New York's lower courts eroded the "Graf" doctrine to such a degree that it appears that it is no longer the law, and that a court of conscience has the power to mandate that a default be excused if it is equitable to do so. Of course, now that the pendulum is swinging in the opposite direction, we can expect courts to explain where the limits on the newly expanded equity of redemption lie...and it is probably not a coincidence that the cases that have eroded "Graf v. Hope Building Corp." have been accompanied by the rise of arbitration as a means for enforcing mortgages.


title: Maxims of equity

text: Also: Equity will not compel a court to do a vain and useless thing. It would be an idle gesture for the court to grant reformation of a contract and then to deny to the prevailing party an opportunity to perform it as modified.


title: Maxims of equity

text: It is often stated that one who comes into equity must come with clean hands (or alternatively, equity will not permit a party to profit by his own wrong). In other words, if you ask for help about the actions of someone else but have acted wrongly, then you do not have clean hands and you may not receive the help you seek. For example, if you desire your tenant to vacate, you must have not violated the tenant's rights.


title: Maxims of equity

text: However, the requirement of clean hands does not mean that a "bad person" cannot obtain the aid of equity. "Equity does not demand that its suitors shall have led blameless lives." The defense of unclean hands only applies if there is a nexus between the applicant's wrongful act and the rights he wishes to enforce.


title: Maxims of equity

text: In "D & C Builders Ltd v Rees", a small building firm did some work on the house of a couple named Rees. The bill came to £732, of which the Rees had already paid £250. When the builders asked for the balance of £482, the Rees announced that the work was defective, and they were only prepared to pay £300. As the builders were in serious financial difficulties (as the Rees knew), they reluctantly accepted the £300 "in completion of the account". The decision to accept the money would not normally be binding in contract law, and afterwards the builders sued the Rees for the outstanding amount. The Rees claimed that the court should apply the doctrine of promissory estoppel, which can make promises binding even when unsupported by consideration. However, Lord Denning refused to apply the doctrine, on the grounds that the Rees had taken unfair advantage of the builders' financial difficulties, and therefore had not come "with clean hands".


title: Maxims of equity

text: When a court of equity is presented with a good claim to equitable relief, and it is clear that the plaintiff "also" sustained monetary damages, the court of equity has jurisdiction to render legal relief, e.g., monetary damages. Hence equity does not stop at granting equitable relief, but goes on to render a full and complete collection of remedies.


title: Maxims of equity

text: Thus, "where a court of equity has all the parties before it, it will adjudicate upon all of the rights of the parties connected with the subject matter of the action, so as to avoid a multiplicity of suits." This is the basis for the procedures of interpleader, class action, and the more rarely used Bill of Peace.


title: Maxims of equity

text: This maxim, also expressed as "Aequitas sequitur legem", means more fully that "equity will not allow a remedy that is contrary to law."


title: Maxims of equity

text: The Court of Chancery never claimed to override the courts of common law. Story states "where a rule, either of the common or the statute law is direct, and governs the case with all its circumstances, or the particular point, a court of equity is as much bound by it as a court of law, and can as little justify a departure from it." According to Edmund Henry Turner Snell, “It is only when there is some important circumstance disregarded by the common law rules that equity interferes.” Cardozo wrote in his dissent in "Graf v. Hope Building Corporation", 254 N.Y 1 at 9 (1930), "Equity works as a supplement for law and does not supersede the prevailing law."


title: Maxims of equity

text: Maitland says, “We ought not to think of common law and equity as of two rival systems." "Equity . of law was to be obeyed, but when all this had been done yet something might be needful, something that equity would require."The goal of law and equity was the same but due to historical reasons they chose a different path. Equity respected every word of law and every right at law but where the law was defective, in those cases, equity provides equitable right and remedies.


title: Maxims of equity

text: In modern-day England and Wales, this maxim no longer applies; as per section 49(1) of the Senior Courts Act 1981, the law follows equity instead:


title: Maxims of equity

text: A volunteer is defined in equity as one who has not offered consideration for a benefit they have received or expect to receive. For example, if a person A expects from past conversations and friendship to receive property under any will of person B, but person B dies before writing this into their will, person A, having not made any contribution to person B, will not be able to seek equity's aid.


title: Maxims of equity

text: This maxim is very important in restitution. Restitution developed as a series of writs called special assumpsit, which were later additions in the courts of law, and were more flexible tools of recovery, based on equity. Restitution could provide means of recovery when people bestowed benefits on one another (such as giving money or providing services) according to contracts that would have been legally unenforceable.


title: Maxims of equity

text: However, pursuant to the equitable maxim, restitution does not allow a volunteer or "officious intermeddler" to recover.


title: Maxims of equity

text: Those successfully pleading benefit from an estoppel (promise relied on to their detriment) will not be considered volunteers for the purpose of this maxim.


title: Maxims of equity

text: If a donor has failed to fulfil all the required legal formalities to effect a transfer, meaning the gift is an imperfect gift, equity will not act to provide assistance to the donee. This maxim is a subset of equity will not assist a volunteer.


title: Maxims of equity

text: However, there are certain relaxations to the maxim, including the rule of Re Rose of where the donor has “done all in his power to divest himself of and to transfer” the property, and the more recent but controversial use of unconscionability as a method of dispensing a formality requirement.


title: Maxims of equity

text: Note the exception in "Strong v Bird" (1874) LR 18 Eq 315. If the donor appoints the intended donee as executor of his/her will, and the donor subsequently dies, equity will perfect the imperfect gift.


title: Maxims of equity

text: Equity will provide no specific remedies where the parties' causes are to be seen to be equal, or where neither has been wronged.


title: Maxims of equity

text: The significance of this maxim is that applicants to the chancellors often did so because of the formal pleading of the law courts, and the lack of flexibility they offered to litigants. Law courts and legislature, as lawmakers, through the limits of the substantive law they had created, thus inculcated a certain status quo that affected private conduct, and private ordering of disputes. Equity could alter that status quo, ignoring the clearly imposed limits of legal relief, or legal defences. But courts applying equity are reluctant to do so. This maxim reflects this. If the law firmly denied a cause of action or suggested equities between the parties were as a matter of policy equal, equity would provide no relief; if the law did provide relief, then the applicant would be obligated to bring a legal, rather than equitable action. This maxim overlaps with the previously mentioned "equity follows the law."


title: Maxims of equity

text: Equity prevents a party from relying upon a presence or absence of a statutory formality if to do so would be unconscionable and unfair. This can occur in secret trusts and constructive trusts.


title: Maxims of equity

text: If there is no trustee, whoever has legal title to the trust property will be considered the trustee.


title: Maxims of equity

text: Due to limits in old Common Law, no remedy was had for beneficiaries if, for example, a trustee ran off with the trust property. To remedy this and protect intended recipients of trust property, Equity regarded the beneficiary as the true (eventual) owners of the trust property.


title: Maxims of equity

text: Comparing timing with legal and equitable claims, “[u]nder the common law, an earlier claim had priority over a later claim if both claims were legal claims . . . The same was true if both claims were equitable . . . [order in time] only mattered under the common law where [one party] had a legal claim and a competing earlier claim to the property was purely equitable.”


title: Big two

text: Big two (also known as deuces, capsa, pusoy dos, dai di and various other names) is a card game of Cantonese origin. It is similar to the games of winner, daifugō, president, crazy eights, cheat, and other shedding games. The game is very popular in East Asia, and in Southeast Asia (due to overseas Chinese influence), especially throughout mainland China, Hong Kong, Vietnam, Macau, Taiwan, Indonesia, the Philippines, Malaysia and Singapore. It is played both casually and as a gambling game. It is usually played with two to four players, the entire deck being dealt out in either case (or sometimes with only 13 cards per player, if there are fewer than four players). The objective of the game is to be the first to play off all of one's cards.


title: Big two

text: This card game has many other names, including big deuce and top dog. In Mandarin Chinese it is , pinyin: dà lǎo èr; in Cantonese, , sho tai ti (among other transliterations, including "chor dai di", and rendered in jyutping tonal notation as "co daai di"), or simply dai di. It is cap sa in Hokkien, , meaning "thirteen" (coming from the number of cards dealt to each player), a name is commonly used in Indonesia. In Malta, it is often referred to as ('Chinese') or ('Japanese'), due to its East Asian origin. In English, it is sometimes ambiguously called Chinese poker because of its use of poker hands, but this name more often applies to another game of an entirely different nature.


title: Big two

text: Big two is sometimes confused with "tien len" (a.k.a. thirteen); the two games differ primarily in that big two involves poker hands, while "tien len" does not.


title: Big two

text: Cards may be played as singles or in groups of two, three or five (var. 1 and 8), in combinations which resemble poker hands. The leading card to a trick sets down the number of cards to be played; all the cards of a trick must contain the same number of cards. The highest ranking card is 2 instead of A. The combinations and their rankings are as follows, mostly based on poker hands:


title: Big two

text: The dealer (who may be chosen by cutting the cards, as usual) shuffles the deck to begin with and begins dealing out the cards singly, starting with the person of his right, in a counter-clockwise manner around the table. The cards are dealt out among the players as far as they can go while retaining an equal number of cards for each player. Leftover cards (not possible if there are 4 players) are then given to the player holding the 3. If this card is in the kitty, then the holder of the next lowest card adds them to his pile (var. 5). The Joker cards are not used under normal rules and are taken out before dealing.


title: Big two

text: At the beginning of each game, the player with the 3 (var. 6 and 9) starts by either playing it singly or as part of a combination, leading to the first trick. Play proceeds counter-clockwise, with normal climbing-game rules applying: each player must play a higher card or combination than the one before, with the same number of cards. Players may also pass, thus declaring that they do not want to play (or do not hold the necessary cards to make a play possible). A pass does not hinder any further play in the game, each being independent, referred to as jumping-back. (var. 14).


title: Big two

text: When all but one of the players have passed in succession the trick is over (some variations have when 1 player has passed the trick is over), and the cards are gathered up and a new trick is started with all players, initiated by the last player to play. When a player plays the 2 either as a single or as part of a pair of 2s, it is often customary for that player to start the next trick immediately by leading a new card or combination, since the 2 cannot be beaten whether as a single or as part of a pair of 2s, and the passes are mere formalities.


title: Big two

text: It is often courteous for a player to warn others when they are one playing combination away from winning. The goal is, then, for the other players to play (and get rid of) as many cards as possible while avoiding the combination that would allow the calling player to win the game. For example, if said player has one last single card, the other players would play doubles or other combinations to force that player to pass.


title: Big two

text: If a player receives a hand with only 3 points or less, they may declare their cards, and the cards shall be reshuffled and dealt again. Common point counting rules are as follows: J=1, Q=2, K=3, A=4, 2=5, others=0. These point-counting rules may vary from game to game, or may be voided. A variation states that a player holding a hand with no cards with faces on them (namely Jacks "J", Queens "Q", and Kings "K") may request a reshuffle and the cards shall be dealt again. In addition, if a player has four twos, it may be mandatory to have a reshuffle.


title: Big two

text: Scoring varies from region to region. The most common version is that after a game, each player with cards remaining valued at one point each, and doubles if they have 10 or more cards, or triple is all 13 cards are intact and not played at all. The points is then paid to the winner. (Example: North player wins, and East, West, and South respectively still had 3, 11, and 8 cards left, then East would score -3, West would score -22, South would score -8, and North would score +33.)


title: Big two

text: Any unused 2's, or a Four-of-a-kinds or Straight Flushes also doubles the points paid to the winner. If the winner ends the game by discarding a 2, a four-of-a-kind, or a Straight flush, the base points will also be doubled, but does not stack regardless of an ending hand. (Example: North players wins with a 2 as a last discard, and East, West, and South respectively still had 3, 9, and 8 cards left with the West had an unused Straight Flush and South left with an unused 2, then East would score -6, West would score -36, South would score -32, and North would score +74.)


title: Big two

text: Likewise for a three-player game, a player with 17 cards remaining is deducted triple points. A player with more than 11 cards and less than 17 cards remaining is deducted double points. An alternative scoring method to deduct one point per remaining card, is to double the count for each unused 2's.


title: Big two

text: If Player B won a game by playing their last card (the case of more than one card played is excluded) after Player A has played theirs and Player A could have prevented this from happening by playing a higher card, Player A deemed to have assisted Player B.


title: Big two

text: There are several ways to penalize Player A. The most common way is for Player A to be deducted the total points that the other two losers have lost on top of their own so that the other two may win some points.


title: Big two

text: This rule can vary between styles of play. If the scoring system is based on ranks ("e.g." who finishes first, second, third or last), the rule would not apply.


title: Big two

text: It is possible to play in teams of two with four total players. Teammates are positioned on the opposite side of each other, making them face each other. Teammates are not allowed to communicate with each other by any means regarding their cards, preferred combinations or the quality of their hands.


title: Big two

text: The winning team is determined by the total number of cards held by each team when one of the players runs out of cards. This means that even if a player on a team manages to play their last card, the opposing team can still win by card count. (Ex: Mike and Dave are on one team against Lionel and Brendan. Mike has 4 cards, Dave has 5, and Lionel has 10 by the time Brendan plays his last card. Mike and Dave win the game by having a total of 9 cards in their hands against Lionel's 10.) Any player can ask what the card count is for each team at any point.


title: Big two

text: If the card count is tied at the end of a game, all players proceed to a five-card shootout. Each player receives five cards and the game is played as normal. The lowest card holder starts and play proceeds with the same team grouping. Further ties lead to further five card hands; this determines the final winner of the original game.


title: Big two

text: Players in collusion with one another have massive advantages over any non-colluding player(s). The basic strategy of colluding players is to preserve the high "control" cards against the non-colluder(s), and not to waste these cards amongst themselves. This strategy is called "holding" or "warrening". Other collusive techniques include signaling (through the played cards, e.g. odd/even as in bridge, or non-verbal cues) where the strength of the hand, number of controls, hand type, exact high cards, and other features of the hands are transmitted to the partner.


title: Big two

text: Other cheating methods includes false shuffles, kiddening, peeking and cold decking. Cheating, especially collusive techniques, is rampant in online and higher stakes games.


title: Big two

text: Another method of cheating is practiced in in-person games, and involves concealing the number of cards a player has by stacking their hand tightly together, so that other players will mistake the cheating player for having fewer cards than he or she actually does. This may lead other players to exhaust their higher cards earlier on the assumption that their opponent has almost won.


title: 24 (season 3)

text: The third season of the American drama television series "24", also known as Day 3, premiered in the United States on Fox on October 28, 2003, and aired its season finale on May 25, 2004. The storyline starts and ends at 1:00 pm. The season premiere originally aired without commercial interruption, and has an extended running time of approximately 51 minutes, as opposed to the standard 43 minutes.


title: 24 (season 3)

text: The third season is set 3 years after season two. It takes place primarily in Los Angeles but also in northern Mexico when Jack Bauer meets a family of drug dealers. Throughout the day, Jack Bauer and President David Palmer attempt to stop the release of a deadly virus by Stephen Saunders – a former government agent.


title: 24 (season 3)

text: Day 3 sees CTU deal with a deadly virus threat that would be released in Los Angeles. Jack's nemesis Nina Myers is also seen, while he is trying to break his heroin addiction after his undercover operation with Ramon and Hector Salazar. Jack's colleagues suspect that his difficulty quitting is related to the death of his wife Teri at the end of the first season. Jack has a new protege in tow, Chase Edmunds, but things take a turn for the worse when it is revealed Chase is seeing his daughter Kim, and it causes tension among the three of them.


title: 24 (season 3)

text: President Palmer is seeking re-election against Senator John Keeler, but his campaign turns sour after one of his major backers, Alan Milliken, discovers that Palmer's brother, Wayne, has been sleeping with Julia Milliken, Alan's wife. Palmer's campaign suffers a major blow when revelations come out about his girlfriend and personal physician Anne Packard. The president turns to his ex-wife Sherry to deal with Milliken. Sherry takes it all a step too far when she kills Milliken by not allowing him his medication, which he needs to stay alive. Despite David Palmer's best cover-up efforts, Keeler uses it as leverage in the campaign. Toward the end of the day, Julia kills Sherry before taking her own life, and Palmer decides not to seek re-election.


title: 24 (season 3)

text: Back at CTU, it turns out that Tony Almeida, Gael Ortega and Jack have been working undercover on a sting operation. Chase is initially unaware of the situation and attempts to "rescue" Jack, who is being held captive by the Salazars. Tony recovers from a gunshot wound to the neck, to return as head of CTU, with many doubting his abilities.


title: 24 (season 3)

text: Nina comes in just as Jack and the Salazars are trying to get hold of the virus from Michael Amador, but he plays them all for fools. After Nina is captured by CTU and interrogated, she makes a daring escape attempt only to be found by Kim. Jack comes in and finally gets revenge for the death of his wife Teri.


title: 24 (season 3)

text: Amador meets with his accomplice Marcus Alvers, who later plants some of the virus in a hotel ventilation system. When Michelle Dessler captures Alvers, he reveals that the mastermind of the day's events is a man from Jack's past named Stephen Saunders. Gael is killed soon after being exposed to the virus and Michelle has to deal with the threat at the hotel, as well as the unruly guests who soon discover the deadly truth. Saunders contacts President Palmer and gives him a series of assignments, one of which is the murder of Regional Division Director Ryan Chappelle. Jack and Chase try desperately to capture Saunders, but in the end, Jack is forced to kill Chappelle and hand over his body as proof.


title: 24 (season 3)

text: Once Saunders is captured, Jack uses all means possible to stop the threat posed by the remaining vials. This ends with Jack cutting off Chase's hand in order to access the viral delivery devices. Physicians attempt to reattach his hand as the season draws to a close. The final scene of season 3 shows Jack Bauer having an emotional breakdown as a result of the day's events until he is once again enlisted by CTU to interrogate one of the day's suspects. The day ends with Jack on his way back to work.


title: 24 (season 3)

text: The third to last episode showed F18 fighters destroying a helicopter from the air. This scene was filmed on location and required extensive collaboration between the film crew, the United States Marine Corps and the Federal Aviation Administration. Efforts were made to show the response to a virus outbreak realistically. Anne Cofell, a researcher for 24, consulted with a virologist and the Centers for Disease Control. The writers originally planned to incorporate a real virus into the plot but ended up using a fictitious one when researchers doubted that any real virus would be that deadly.


title: 24 (season 3)

text: The initial trailer promoting season 3 was much longer than the trailer promoting season 2. It touches on many of the early plot points including the threat to release the virus, Jack's heroin addiction and the relationship between Kim Bauer and Chase Edmunds.


title: 24 (season 3)

text: The third season of "24" received "generally favorable reviews", scoring a Metacritic rating of 72/100 based on 14 reviews. On Rotten Tomatoes, the season has an approval rating of 93% with an average score of 7.1 out of 10 based on 14 reviews. The website's critical consensus reads, ""24"s third day marks the series' most ruthless season yet with a breathless race to avert chemical catastrophe, a myriad of shocking surprises, and an unnerving disregard for treating any character as safe."


title: 24 (season 3)

text: "Empire" ranked "Day 3: 6:00 a.m. – 7:00 a.m." as the best ever "24" episode saying "As Jack puts a bullet into Ryan's head and weeps, the clock at the end of the episode remains silent, capping off the most emotional and darkest hour in 24's history."


title: 24 (season 3)

text: "24" won four Emmy awards for its third season and also, the Golden Globe Award for Best Television Series – Drama, after being nominated 3 times in a row.


title: Sonu Nigam discography

text: Indian playback singer Sonu Nigam has recorded numerous albums and songs. Below are his mainstream releases. He has also released several devotional albums including "Maha Ganesha" (2008). He sang for several Ambedkarite and Buddhist albums including "Buddha Hi Buddha hai" (2010) and "Siddhartha-The Lotus Blossom" (2013). He covered the songs of famous Ghazal singer Pankaj Udhas in "Best of Pankaj Udas".


title: Sonu Nigam discography

text: In Tamil, Nigam had sung various songs for A. R. Rahman, G. V. Prakash Kumar, Bharathwaj, and Ilaiyaraaja


title: Ellen Albertini Dow

text: Ellen Rose Albertini Dow (November 16, 1913 – May 4, 2015) was an American film and television character actress and drama coach. She portrayed feisty old ladies and is best known as the rapping grandmother Rosie in "The Wedding Singer" (1998), performing "Rapper's Delight". Dow's other film roles include elderly lady Mary Cleary who "outs" her grandson in "Wedding Crashers", Disco Dottie in "54", the recipient of Christopher Lloyd's character's slapstick in "Radioland Murders" and a choir nun in "Sister Act". She was best known to small screen audiences for her guest appearances on sitcoms "The Golden Girls" (playing Lillian, a friend of Sophia's) and "Will & Grace" (as Karen Walker's mother-in-law Sylvia).


title: Ellen Albertini Dow

text: Albertini was born on November 16, 1913, in Mount Carmel, Pennsylvania, the seventh and youngest child of Italian immigrant parents, Ellen and Oliver, from Non Valley, Trentino. Oliver was a car dealership owner. She studied dance and piano at age five and would later move to New York City, where she studied and worked with renowned dancers and choreographers Hanya Holm and Martha Graham.


title: Ellen Albertini Dow

text: Dow earned a B.A. and M.A. in theatre from Cornell University, where she became a member of Kappa Delta sorority, graduating in 1935. Dow studied acting with Michael Shurtleff and Uta Hagen, and worked with mimes Marcel Marceau and Jacques Lecoq in NYC.


title: Ellen Albertini Dow

text: When Dow moved to Los Angeles with her husband, she taught drama at Los Angeles City College. She and her husband later taught at Los Angeles Pierce College.


title: Ellen Albertini Dow

text: Her television work includes appearances in such television series as "", "The Golden Girls", "Newhart", "Designing Women", "Just Shoot Me", "Will & Grace", "Seinfeld", "Ned's Declassified", "Hannah Montana", "Scrubs", "Sister, Sister", "According to Jim", "Six Feet Under", "Wings", "The Nanny" and "My Name Is Earl".


title: Ellen Albertini Dow

text: Dow married Eugene Dow Jr. on June 27, 1951. She described herself as an avid hat collector. Eugene died on October 11, 2004. They had no children.


title: Endowment (Mormonism)

text: In Mormonism, the endowment is a two-part ordinance (ceremony) designed for participants to become kings, queens, priests, and priestesses in the afterlife. As part of the first ceremony, participants take part in a scripted reenactment of the Biblical creation and fall of Adam and Eve. The ceremony includes a symbolic washing and anointing, and receipt of a "new name" which they are not to reveal to others except at a certain part in the ceremony, and the receipt of the temple garment, which Mormons then are expected to wear under their clothing day and night throughout their life. Participants are taught symbolic gestures and passwords considered necessary to pass by angels guarding the way to heaven, and are instructed not to reveal them to others. As practiced today in the Church of Jesus Christ of Latter-day Saints (LDS Church), the endowment also consists of a series of covenants (promises to God) that participants make, such as a covenant of consecration to the LDS Church. All LDS Church members who choose to serve as missionaries or participate in a celestial marriage in a temple must first complete the first endowment ceremony.


title: Endowment (Mormonism)

text: The second part, or second anointing is the pinnacle ordinance of the temple, jointly given to a husband and wife couple, where their exaltation is guaranteed. Participants are anointed kings, queens, priests, and priestesses, whereas they are only anointed to become such in the first part. The second part of the endowment is given to a select group, and its existence is not widely known among the general membership.