1. What is the Electronic Travel Authorization (ETA) to Costa Rica?
The Electronic Travel Authorization (ETA) to Costa Rica is an online system that allows nationals of visa-exempt countries to apply for authorization to enter the country for tourism, business, or transit purposes. The ETA system was implemented by the Costa Rican government to streamline the entry process and enhance border security.
To obtain an ETA for Costa Rica, travelers need to complete an online application by providing personal information, passport details, travel itinerary, and other relevant data. Once the application is submitted, it is processed by the immigration authorities, and if approved, the traveler receives an electronic authorization that allows them to board their flight to Costa Rica.
The ETA for Costa Rica is typically valid for multiple entries within a specified period, usually up to 90 days. It is important for travelers to ensure they meet all the requirements for the ETA and have a valid passport before applying to avoid any issues with their entry into Costa Rica.
2. Who needs to apply for an ETA to enter Costa Rica?
Individuals from visa-exempt countries traveling to Costa Rica for tourism, business, or transit purposes are required to apply for an Electronic Travel Authorization (ETA) before their trip. This includes travelers from countries such as the United States, Canada, Australia, and the European Union. It is important to note that the specific list of countries whose citizens require an ETA can vary and it is recommended to check the latest information on the official Costa Rican government website or consult with the nearest Costa Rican embassy or consulate. Additionally, travelers should ensure that their passport is valid for at least six months beyond the intended date of departure from Costa Rica and that they have proof of onward or return travel arrangements.
3. How can I apply for an ETA for Costa Rica?
To apply for an Electronic Travel Authorization (ETA) for Costa Rica, you can follow these steps:
1. Visit the official website of the Costa Rican Embassy or Consulate to access the online application form for the ETA.
2. Fill out the application form with accurate and up-to-date personal information, including your full name, passport details, travel itinerary, and contact information.
3. Upload any required supporting documents, such as a copy of your passport bio page and proof of travel arrangements.
4. Pay the processing fee for the ETA application. This fee may vary depending on your nationality and the duration of your stay in Costa Rica.
5. Submit your completed application and wait for the approval of your ETA. The processing time can vary, but it is typically processed within a few days.
Once your ETA is approved, you will receive a confirmation email with the authorization document that you need to present upon arrival in Costa Rica. Make sure to carry a printed or electronic copy of your ETA and passport with you during your trip to Costa Rica.
4. What information do I need to provide when applying for an ETA to Costa Rica?
When applying for an Electronic Travel Authorization (ETA) to Costa Rica, you will need to provide the following information:
1. Personal details: This includes your full name, gender, date of birth, nationality, and passport information.
2. Contact information: Your current address, email address, and phone number.
3. Travel details: Dates of travel, purpose of visit, and intended length of stay in Costa Rica.
4. Additional information: You may also need to provide details about your accommodation in Costa Rica, your flight itinerary, and proof of sufficient funds to cover your stay.
It is essential to ensure that all the information provided is accurate and matches the details on your passport to avoid any issues with your ETA application.
5. How long does it take to receive approval for an ETA to Costa Rica?
The processing time for an Electronic Travel Authorization (ETA) to Costa Rica is typically very quick. In most cases, applicants receive approval within minutes of submitting their online application. However, it is recommended to apply for an ETA at least 72 hours before your planned travel date to ensure that you have enough time for any potential delays or issues that may arise during the processing of your application. In rare cases, processing may take up to 48 hours, but the majority of applicants receive their approval much faster. Make sure to double-check all the information you provide in your application to avoid any delays in processing.
6. How long is an ETA to Costa Rica valid for?
An Electronic Travel Authorization (ETA) to Costa Rica is typically valid for two years from the date of approval. During this validity period, travelers can enter Costa Rica multiple times for stays of up to 90 days per visit. It is important to note that the ETA’s validity does not mean a traveler can stay continuously in Costa Rica for two years; rather, it allows for multiple entries over that period, with each stay limited to 90 days. After the two-year validity period expires, travelers will need to apply for a new ETA if they plan to visit Costa Rica again.
7. Can I apply for an ETA on arrival in Costa Rica?
No, you cannot apply for an Electronic Travel Authorization (ETA) on arrival in Costa Rica. The ETA for Costa Rica must be obtained prior to travel, ideally at least 72 hours before departure. It is an electronic document that grants entry to Costa Rica for tourism, business, or transit purposes. To apply for the ETA, you will need to fill out an online application form, provide your personal and travel information, passport details, and proof of departure. Once approved, the ETA is electronically linked to your passport and allows you to enter Costa Rica without the need for a paper visa. It is advisable to complete this process well in advance to ensure a hassle-free entry into the country.
8. Is the ETA the same as a visa for Costa Rica?
No, the Electronic Travel Authorization (ETA) for Costa Rica is not the same as a traditional visa. The ETA is a digital entry requirement implemented by the Costa Rican government for travelers from certain countries who do not require a visa to enter the country. It allows eligible travelers to visit Costa Rica for tourism or business purposes for a limited period, usually up to 90 days. The ETA application process is typically done online and involves providing personal information, passport details, travel itinerary, and other relevant documentation. Upon approval, the traveler receives an electronic authorization that is linked to their passport electronically. It is important to note that while the ETA grants entry to Costa Rica, it is not a substitute for a visa for those travelers who are required to obtain one based on their nationality or the purpose of their visit.
9. Do children need an ETA to enter Costa Rica?
No, children under the age of 12 do not need an Electronic Travel Authorization (ETA) to enter Costa Rica. They can enter the country with valid travel documents such as a passport, without the need for an ETA. However, it is important to ensure that all children have the necessary travel documents and meet other entry requirements set by Costa Rica immigration authorities to avoid any issues during travel. It is recommended to check the latest entry requirements before traveling to Costa Rica with children to ensure a smooth and hassle-free entry process.
10. Can I extend my stay in Costa Rica if I have an ETA?
No, you cannot extend your stay in Costa Rica if you have an Electronic Travel Authorization (ETA). The ETA allows you to enter Costa Rica for tourism or business purposes for a specified period of time, typically up to 90 days. If you wish to extend your stay beyond the allowed period, you will need to leave the country before your authorized stay expires and then apply for a visa or other appropriate extension options at the nearest Costa Rican consulate or embassy. It is important to adhere to the terms of your ETA and comply with the immigration regulations of Costa Rica to avoid any issues during your stay.
11. Can I apply for an ETA if I have a criminal record?
Yes, individuals with a criminal record can still apply for an Electronic Travel Authorization (ETA) to Costa Rica; however, the approval is not guaranteed. The Costa Rican authorities will assess each application on a case-by-case basis, taking into consideration the nature and severity of the criminal offense. It is important to provide accurate and honest information when applying for an ETA, as any discrepancies may lead to the denial of the application. Additionally, it is recommended to disclose any criminal history upfront and provide any relevant supporting documents that may help demonstrate rehabilitation or good conduct since the offense occurred. Ultimately, the final decision rests with the Costa Rican authorities, and applicants with a criminal record should be prepared for the possibility of their ETA application being denied.
12. Can I apply for an ETA if I have dual citizenship?
Yes, you can apply for an Electronic Travel Authorization (ETA) to Costa Rica if you have dual citizenship. When completing the ETA application, you will need to provide the passport information that corresponds to the nationality you intend to use when traveling to Costa Rica. It is important to make sure that the passport you use matches the information provided in your ETA application to avoid any issues with your entry into Costa Rica. Additionally, depending on the countries for which you hold citizenship, there may be specific entry requirements or visa regulations that you need to consider when planning your trip. If you have any concerns or questions regarding your dual citizenship status and the ETA application process, it is advisable to contact the Costa Rican embassy or consulate for clarification.
13. Do I need a return ticket to apply for an ETA to Costa Rica?
Yes, to apply for an Electronic Travel Authorization (ETA) to Costa Rica, you are required to provide proof of a round-trip or onward ticket. This is a standard requirement for most countries when applying for an ETA or visa, including Costa Rica. The purpose of this requirement is to ensure that visitors have a planned departure from Costa Rica and do not intend to stay in the country beyond the authorized period. When completing your ETA application, you will be asked to provide details of your itinerary, including your flight information. It is important to have a confirmed return ticket before applying for the ETA to avoid any complications or delays in the processing of your application.
14. Can I travel to Costa Rica for business purposes with an ETA?
No, travelers intending to visit Costa Rica for business purposes cannot do so with an Electronic Travel Authorization (ETA). The ETA for Costa Rica is primarily designed for tourists and individuals visiting for leisure or short-term purposes. For business travel, you would typically require a different type of visa or permit, depending on the nature and duration of your business activities in Costa Rica. It is advisable to consult with the Costa Rican embassy or consulate in your country to understand the specific visa requirements for business travel to Costa Rica and ensure that you have the necessary documentation in place before your trip.
15. Do I need to print out my ETA approval to show at the border?
Yes, it is recommended to print out your Electronic Travel Authorization (ETA) approval to show at the border when entering Costa Rica. While some immigration officials may accept a digital copy displayed on a smartphone or tablet, it is always best to have a physical copy on hand to avoid any potential connectivity issues or complications. Having a printed copy of your ETA approval can facilitate a smoother entry process and help verify your authorization quickly and efficiently. Additionally, it is advised to carry other relevant travel documents such as your passport and proof of onward travel as required by Costa Rican immigration regulations.
16. Can I apply for an ETA if I have a connecting flight through Costa Rica?
Yes, you can apply for an Electronic Travel Authorization (ETA) even if you have a connecting flight through Costa Rica. It is advisable to apply for the ETA before your journey, regardless of your final destination. Here’s what you need to consider:
1. Transit Through Costa Rica: If you are merely transiting through Costa Rica without leaving the airport, you may not need an ETA. However, if you plan to leave the airport during your layover, it is recommended to have an ETA to ensure a smooth entry and exit process.
2. ETA Application: The ETA application process is straightforward and can be completed online. Make sure to provide accurate information and submit the required documents as specified by the Costa Rican authorities.
3. Validity: An ETA for Costa Rica is usually valid for multiple entries within a specific period, so it can cover your connecting flights as well.
4. Check Requirements: Before applying for an ETA, check the specific requirements for your nationality and travel circumstances to ensure you have the necessary authorization for your journey, including any connecting flights through Costa Rica.
By obtaining an ETA, you can ensure a hassle-free transit experience through Costa Rica, even if it is just a layover on your way to your final destination.
17. Can I use my ETA for multiple entries into Costa Rica?
Yes, the Electronic Travel Authorization (ETA) for Costa Rica allows for multiple entries into the country within its validity period. Once you have been approved for an ETA, you can use it for multiple entries during its validity period, which is typically 90 days from the date of approval. This means that you can travel in and out of Costa Rica multiple times without needing to apply for a new ETA each time, as long as your ETA remains valid. It is important to note that the maximum length of stay allowed per entry is typically determined by the immigration officer at the port of entry, and you must ensure that your ETA remains valid throughout your time in Costa Rica for multiple entries.
18. Can I apply for an ETA if I am already in Costa Rica and want to leave and re-enter?
No, you cannot apply for an Electronic Travel Authorization (ETA) while already in Costa Rica. The ETA needs to be obtained before your arrival in the country. If you are already in Costa Rica and wish to leave and re-enter, you will need to ensure that you have the necessary visa or entry permit that allows multiple entries into the country, depending on your nationality. It’s crucial to check the specific requirements and regulations based on your citizenship status to avoid any issues or complications during your travel plans. It is recommended to contact the relevant Costa Rican immigration authorities or consulate for accurate and up-to-date information on re-entry procedures for your specific situation.
19. What should I do if my ETA application is denied?
If your ETA application to Costa Rica is denied, there are several steps you can take to address the situation:
1. Review the reasons for denial: Understand why your application was rejected by carefully reviewing the notification you received. This will help you identify any mistakes or missing information that may have led to the denial.
2. Contact the Costa Rican Embassy or Consulate: Reach out to the nearest Costa Rican diplomatic mission for guidance on how to proceed. They may be able to provide clarification on the reasons for denial and offer assistance in reapplying.
3. Correct any errors: If the denial was due to incorrect information provided in your application, make the necessary corrections before submitting a new application. Ensure all details are accurate and up to date.
4. Seek legal advice: If you believe your application was unjustly denied, consider seeking legal advice from an immigration attorney specializing in Costa Rican visa applications. They can help you navigate the appeals process and advocate on your behalf.
5. Reapply: Once you have addressed the issues that led to the initial denial, you can submit a new ETA application. Make sure to follow all instructions carefully and provide any additional documentation or clarification requested.
By following these steps, you can increase your chances of successfully obtaining an ETA to Costa Rica after a previous denial.
20. Is the ETA to Costa Rica refundable if my travel plans change?
The Electronic Travel Authorization (ETA) to Costa Rica is non-refundable once the application has been submitted and processed. This means that even if your travel plans change, and you no longer require the ETA or are unable to travel to Costa Rica, you will not be able to receive a refund for the authorization fee. It’s important to carefully consider your travel dates and plans before applying for the ETA to avoid any inconveniences or financial losses. If your travel plans do change, you will need to reapply for a new ETA if you decide to visit Costa Rica at a later date.


. . . plus new mileage allowance, planning for capital losses, late filing, and making loans
Giving Growth to the Kids
As you may know, the Tax Reform Act of 1986 prevents you from freezing the value of your business for estate-tax purposes. Before the law was enacted, a widely used strategy among family businesses was for the owner to hold preferred stock and transfer common stock -- and thus future growth -- to the kids. Now, new strategies are developing.
One effective way of removing future growth from your estate is to sell all or a portion of the stock to your children. But there is a price to pay: you must pay tax on the capital gain, and the children will need income to make nondeductible payments to you. If you're not an S corporation, one tax maneuver is to have the children make that election as soon as they purchase the stock. They can then use the business's profits as a cash-flow source to pay for the purchase.
Often, a gift to your children is the best way to make the transfer (see "Family Gifts" below). If you can't make a full transfer that way because of the value of the company or your age, think about selling a portion and gifting a portion. -- Irving L. Blackman
One way to reduce the taxes on your estate is to start giving gifts to your family. Here are the rules:
* The first $10,000 in gifts made to each person in a year is tax free.
* To qualify for tax-free treatment, gifts must be of "present interest" (a direct cash gift, for instance) rather than "future interest" (such as a gift of cash that goes into a trust fund for later distribution).
* A gift by one spouse can be treated as though each spouse gave half, doubling the annual exclusion to $20,000.
Lifetime gifts up to $600,000 (double that if you're married and excluding the annual $10,000 or $20,000) are essentially tax free. Gift and estate taxes are reduced by a special unified tax credit of up to $192,800. Of course, if you use the entire credit for lifetime gifts, none will remain to reduce your estate taxes.
You can give away anything you own -- the family business, bonds, real estate, an interest in a partnership, and so on. The amount of the gift is based on the fair market value of the property on the date of the gift. The recipient does not have to treat the gift as income. -- I.L.B.
If you are about to sell a capital asset at a loss -- stock in your company, for example -- consider putting the property in joint tenancy with your spouse before the sale.
The reason is this: If you can't deduct the full amount of the loss, you can carry it forward. But if anything happens to you, your spouse won't be able to claim the carry-over loss on his or her individual return. That's the case even if you've been filing joint returns for years. If property is held in only one spouse's name, the tax attributes connected with that property terminate with that person's death. -- I.L.B.
If you lend money to a relative or a friend, and the debt goes sour, the Internal Revenue Service says you can deduct it. But tax collectors routinely toss out deductions based on handshake deals. The key is to set up the transaction with care:
* Ask the borrower to sign a note of agreement.
* Spell out in the note the amount borrowed and the repayment schedule.
* Charge a realistic rate of interest.
* In some states, you need to have a witness sign the note.
You take the deduction in the year the note becomes worthless, that is, when there is no longer any chance of your being paid. The IRS will want evidence of this, which means you need to show that you took reasonable steps to collect it. At the least, you should send a letter asking for payment. If the money was a business loan, you can deduct it directly from your income. If a personal loan, it's treated as a short-term capital loss. -- Julian Block
If you use the optional mileage allowance rather than actual expenses for deducting the business use of your car, the rate has been raised from 22.5¢ to 24¢ a mile for the first 15,000 miles in 1988. Any mileage above that is allowed at 11¢ a mile. You can also deduct tolls and parking. The 24¢-a-mile rate also applies to reimbursements companies make to employees, but they are not limited to 15,000 miles annually.
Since the allowance is not overly generous, you may do better by keeping track of your expenses -- and holding on to your receipts. -- I.L.B.
To get the IRS to waive a late-filing penalty, you have to convince it that the delay was "due to reasonable cause and not due to willful neglect." The list of acceptable excuses is not surprising: a serious illness or death in your immediate family; postal delays; wrong advice from an IRS employee; IRS tardiness in providing tax forms and instructions; and the destruction of your home, place of business, or records due to a fire or other casualty or civil disturbances.
What may be surprising is this: if you rely on your attorneys or accountants to get your returns in on time and they miss the deadline, that's not an acceptable excuse.
Irving L. Blackman, specializing in closely held businesses at Chicago-based Blackman Kallick Bartelstein, certified public accountants, speaks and writes on tax issues.
Julian Block covers taxes for Prentice Hall Information Services.
TOP TAX RATES FOR ESTATE AND GIFT TAXES
|More than||Not more than||The tentative tax:*|
|$2,500,000||$3,000,000||$1,025,800 + 53% of amounts over||$2,500,000|
|3,000,000||10,000,000||1,290,800 + 55% of amounts over||$3,000,000|
|10,000,000||21,040,000||5,140,800 + 60% of amounts over||$10,000,000|
|21,040,000||11,764,000 + 55% of amounts over||$21,040,000|
|$2,500,000||$10,000,000||$1,025,800 + 50% of amounts over||$2,500,000|
|10,000,000||18,340,000||4,775,800 + 55% of amounts over||$10,000,000|
|18,340,000||9,362,800 + 50% of amounts over||$18,340,000|
*The tentative tax should be reduced by the unified credit, up to $192,800 in a lifetime.
Source: Winning Tax Strategies 1989, Laventhol & Horwath n


We provide extremely aggressive representation. Call us and Let us help!
If we don't win your case or recover money on your behalf, you pay nothing out-of-pocket.
Contact us immediately to learn how you can receive the compensation.
The founder of Abercrombie, P.A., attorney Yulric Abercrombie, provides the skill, experience and legal understanding needed to get results following an accident or injury. A graduate of Florida State University and began practicing in 2000, he worked for several large insurance defense firms, including one of the largest firms in the Southeast region of the United States, prior to opening his own practice.
We offer free consultations to any prospective clients, so that we can take the time to discuss an overview of their accident, the injuries they have sustained, and the possible directions we can take the case in order to recover the damages they deserve. During this consultation, you will be able to ask questions about how the personal injury process works, and get a professional opinion on the general facts of your case. This is a great opportunity to understand our work ethic, and be confident that you made the right choice when you hire us to represent you. We look forward to hearing from you today!
A personal injury accident is any accident that was caused by someone’s negligence. For instance, a negligent driver could be responsible for a car accident. A negligent employer could be responsible for a workplace accident. Had either party been more cautious, the injury might have been prevented. A central Florida personal injury attorney can explain more about the criteria for this type of accident.
In order to qualify for a personal injury lawsuit, you must be able to prove a few things at the outset, before you can begin to seek an amount of damages. The basic criteria for a personal injury lawsuit are the following:
If you are able to prove these points in a court of law, then you have the basis of a personal injury lawsuit. This could range from circumstances such as a car accident where the other driver was under the influence of drugs or alcohol, a slip and fall at a public mall, or medical malpractice such as an incorrect diagnosis or surgical error.
At Abercrombie, P.A., we hold ourselves to a high standard where our main goal is to ensure our clients are receiving the adequate compensation after a auto accident case. We have been working with Bartow clients for many years, always putting their needs first and attempting to get the best results possible.
If you are looking for a auto accident lawyer in Bartow, look no further than Abercrombie, P.A.. With many years of experience handling such cases, Abercrombie, P.A. can help you improve your chances of having a successful trial.
A serious auto accident matter can be a major hurdle to your daily life. After a auto accident you could be facing expensive medical bills, down time from work and a resulting lack of income. If you are stuck facing these problems alone in Bartow, Abercrombie, P.A. can work with you to get you the compensation you deserve.
For many cases, the most important aspect of the auto accident legal representation is settlement negotiations. Abercrombie, P.A. makes firm demands to the opposing counsel and only stops negotiating when you feel satisfied with a settlement. When you are looking for a auto accident firm within the Bartow area, you need someone who will devote adequate resources to your case. We are confident in our initial assessment of your legal rights and use our many years of experience to find the best cases. Contact Abercrombie, P.A. using the information below for a free consultation:
56 4th Street NW
Winter Haven, FL 33880


BOSTON — A 26-year-old Hyannis man associated with the Nauti-Block street gang was sentenced Wednesday in federal court to 66 months in prison.
Oliver Hamilton, who pleaded guilty in May to conspiracy to distribute and possess with the intent to distribute heroin and possession of heroin with the intent to distribute, and accepted responsibility for dealing between 100 and 400 grams of the drug, according to a statement from the Department of Justice.
The Nauti-Block street gang, which operated out of Hyannis, was run by Christian Chapman and Denzel Chisholm, of West Yarmouth, and Christopher Wilkins, of Hyannis. It was dismantled in April 2016 when Barnstable police and state and federal officers raided residences across Cape Cod and made more than a dozen arrests. Many gang members grew up in the area of Nautical Road in Hyannis and were childhood friends.
Chisholm, along with his sister, Shanelle Chisholm, of Mashpee, and Tyrone Gomes, of Hyannis, also were charged in the September 2015 killing of Christine Ferreira, who prosecutors say was killed because of her testimony against another gang member in a 2009 Hyannis shooting.


22 February 2019 - NW85
Selfe, Mr J to ask the Minister of Justice and Correctional Services
(1)Whether a certain person,( prison number: 204156644 ), who is currently serving a life sentence, qualifies to be considered for release on parole; if so, on what date did the specified person become eligible for release on parole; (2) whether the specified person has completed all the courses and programmes required to become eligible for release on parole; if not, which courses or programmes must still be completed; (3) what was the National Council for Correctional Services’ recommendation regarding the specified person’s eligibility for release on parole; (4) whether he has given consideration whether to grant the specified person parole; if so, (a) on what date did he consider the application, (b) what was the outcome of his decision and (c) on what date was the decision taken?
1. Yes, offender (prison number: 204156644) is currently serving a life sentence at Qalakabusha Correctional Centre and was eligible for consideration on 26 September 2016.
(2) No, offender is still required to undergo individual psychotherapy with a Psychologist.
(3) The NCCS recommendations were that:
- The offender should undergo intensive further therapy as recommended by the Psychologist;
- The offender should be subjected to individual psychotherapy to address anger issues and the harm caused to the victim;
- A copy of sentencing remarks in the case of CC145/04 to be obtained from the Pietermaritzburg High Court and attached when the profile is resubmitted. In the event the sentencing remarks cannot be obtained, all efforts to obtain same should be documented and a comprehensive report furnished detailing, inter alia, the reasons for failure to obtain such;
- The offender should attend the Behaviour Modification programme;
- The offender should be assisted to upskill vocationally/ educationally to assist him with prospects of obtaining employment once he is placed on parole. Certificates should be attached when the profile is resubmitted;
- A copy of SAP62 should be included when the profile is resubmitted.
(a) 14 February 2018.
(b) A further profile should be submitted in 18 months with the expectation that all 6 recommendations as stated in question 3 would have been executed upon which placement on parole would be reconsidered.
(c) 14 February 2018.


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Marine Protected Areas (MPAs) are marine environments reserved to protect natural resources. Over 1,600 MPAs are located within the boundaries of the United States across a wide range of habitats. Management strategies for MPAs vary considerably and sometimes result in marine reserves that are “no fishing zones”, which are detrimental to the recreational angling community. Due to the availability of alternative management tools, no-take marine reserves should only be used as a last resort for resource protection when other tools are exhausted.
Some people interpret MPAs to mean areas closed to all human activities. Others interpret them as special areas set aside for cultural or natural resource purposes. In reality, “marine protected area” is a term that encompasses a variety of conservation and management methods in the United States.
The official federal definition of a “marine protected area” or MPA is: “any area of the marine environment that has been reserved by federal, state, tribal, territorial, or local laws or regulations to provide lasting protection for part or all of the natural and cultural resources therein,” as stated in Executive Order 13158 (May 2000).
In practice, MPAs are defined areas where natural and/or cultural resources are given greater protection than the surrounding waters. In the U.S., MPAs span a range of habitats including the open ocean, coastal areas, inter-tidal zones, estuaries and the Great Lakes. They also vary widely in purpose, legal authority, management approach, level of protection and restrictions on human uses.
An MPA is not necessarily a “no fishing zone,” though the two terms are often erroneously used as though they were interchangeable. For example, in an MPA commercial activities may be restricted, while sportfishing, boating and other forms of recreation are permitted. Some environmental groups have called for highly restrictive MPAs, such as “ocean wilderness areas” and marine reserves, where recreational activities are excluded.
MPAs should be implemented only where they can be an effective management tool and should allow recreational fishing and boating access unless sound scientific evidence proves it is necessary for resource protection. In cases where recreational angling is restricted or closed, the areas should be reopened once fishery management goals are achieved.
Economic Impact of Angling
The American System of Conservation Funding funds fisheries (and wildlife) management through fishing license sales and excise taxes on fishing equipment and motorboat fuel. License sales in 2017 amounted to $708 million, while the excise taxes collected on the sale of fishing gear, boats and boat fuel added another $340 million in support of conservation efforts carried out in each state. It’s a model that virtually powers itself.
This important System must be protected to ensure the funding for fisheries conservation is maintained. The very success of this sport depends on angler participation, interest and the opportunity to go fishing. Closing areas to angling hurts both the local and national economies and ultimately reduces funds available for fisheries conservation.
Recreational use of our public waters is compatible with – and in fact is essential to – sound conservation and natural resource stewardship, as is highlighted by contributions made to such successful conservation programs as the Sport Fish Restoration and Boating Trust Fund. Since 1950, recreational anglers and boaters have, through this unique user tax on motorboat fuel, fishing tackle, and other sportfishing equipment, generated nearly $8.8 billion in funding for fishery conservation and enhancement, habitat restoration, clean water programs, and boating safety programs.
The billions of dollars generated from the “user-pays, public-benefits” system is used to conserve our aquatic ecosystems. Because angling provides conservation funding, significant social and economic benefits, and is structured to support the sustainable management of resources with regulations already in place to prevent overuse, these activities warrant special consideration as priority uses of our nation’s waters. For this reason, recreational users of our nation’s waters should have the presumption of access unless otherwise restricted based on sound scientific data.
On September 25, 2014, President Obama established the Pacific Remote Islands Marine National Monument “for the care and management of the historic and scientific objects therein.” According the proclamation the Secretaries of the Interior and Commerce are responsible for the management of sustainable recreational fishing.
Leading up to the proclamation CSF and members of the recreational angling community met with White House staff to discuss what ramifications the expanded MPA might have for recreational angling and emphasized that any potential restrictions must be scientifically based. As a follow up to that meeting, the angling community sent a letter to the White House Council on Environmental Quality, the Director of the U.S. Fish and Wildlife Service and NOAA’s Undersecretary of Commerce for Oceans and Atmosphere, restating the importance of maintaining recreational angling access in the expanded MPA in the absence of any science-based justification for doing otherwise.
On September 15, 2016, President Obama declared the first fully protected area in the U.S. Atlantic Ocean on, designating 4,913 square miles off the New England coastline as a new marine national monument known as the Northeast Canyons and Seamounts Marine National Monument. CSF and members of the recreational fishing and boating community again worked with the White House to ensure that recreational angling was still an allowable use of the new monument.
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What do you think is the most important state-level policy issue impacting sportsmen and women in the 2019 legislative sessions?Vote Here
- Recruiting, Retaining, and Reactivating (R3) hunters and anglers (27.01%)
- Addressing the spread of Chronic Wasting Disease (CWD) (16.67%)
- Increasing public hunting and angling access (22.99%)
- Combating the anti-sportsmen and animal rights agendas (33.33%)


RESPONDENT:Harvey Frank Robbins
LOCATION:United States Court of Appeals for the Ninth Circuit
DOCKET NO.: 06-219
DECIDED BY: Roberts Court (2006-2009)
LOWER COURT: United States Court of Appeals for the Tenth Circuit
CITATION: 551 US 537 (2007)
GRANTED: Dec 01, 2006
ARGUED: Mar 19, 2007
DECIDED: Jun 25, 2007
Gregory G. Garre –
Laurence H. Tribe –
Facts of the case
Harvey Robbins owned a private dude ranch which was intermingled with federal lands. The previous owner had granted the Bureau of Land Management (BLM) right-of-way across the private land, but after Robbins bought the ranch he refused to re-grant it. Robbins alleged that BLM officials harassed him with threats and meritless criminal charges, with the aim of forcing him to grant the government right-of-way. Robbins sued the BLM officials for extortion in violation of the Racketeer Influenced and Corrupt Organizations Act (RICO). He also brought aBivens action (an action seeking monetary damages from a federal agent for a constitutional violation). Robbins argued that the Fifth Amendment protects a “right to exclude” government officials from one’s property, and that the BLM agents had retaliated against him for his exercise of this right. The District Court dismissed both claims, but the U.S. Court of Appeals for the Tenth Circuit reversed. On appeal to the Supreme Court, the government argued that the BLM officials, while acting on behalf of the government, had qualified immunity and therefore could not be sued for extortion under RICO. The government also claimed that noBivens action could be brought, because review of the BLM’s actions was already available under the Administrative Procedure Act.
1) Can government officials acting pursuant to their regulatory authority be guilty of extortion under the Racketeer Influenced and Corrupt Organizations Act (RICO) for attempting to obtain property for the benefit of the government? 2) Is aBivens claim based on Fifth Amendment rights precluded by the availability of judicial review under the Administrative Procedure Act? 3) Does the Fifth Amendment protect against retaliation for exercising a “right to exclude” the government from one’s property?
Media for Wilkie v. Robbins
Audio Transcription for Opinion Announcement – June 25, 2007 in Wilkie v. Robbins
Justice Souter has our opinion this morning in case No. 06-219, Wilkie versus Robbins.
David H. Souter:
This case comes to us on writ of certiorari to the Court of Appeals for the Tenth Circuit.
The petitioner Robbins purchased a ranch in Wyoming that comprises a patchwork of land parcels intermingled with tracts belonging to other private owners, the State of Wyoming and the Federal Government.
Robbins’s predecessor had granted the Federal Government an easement to use and maintain a road running through the ranch in exchange for a right-of-way across federal lands.
But Robbins took title free of the easement because the government never recorded it.
When the Government realized its error, it asked Robbins to regrant the easement that he declined.
Robbins alleges that the defendants who are current and former officials of the Bureau of Land Management engaged in a campaign of harassment and intimidation to force him to regrant the easement.
Robbins’s difficulties with the Bureau can be divided into four rough categories.
Torts and tort-like injuries to him such as trespass on his property, charges brought against him including land-use citations and two criminal charges, which he was ultimately acquitted.
Unfavorable agency action such as the cancellation of permits to use government land and in the fourth category a few other miscellaneous unfold events.
Robbins claims is relevant here that the defendants have used their regulatory powers to harass, punish and crust him and giving the government its property without payment.
Robbins brings in action the damages under the theory of easiness against six unknown Federal Narcotics Agents.
In a claim under The Racketeer Influenced and Corrupt Organizations Act or RICO.
The defendants filed summary judgment motions on qualified immunity grounds, which the District Court ultimately denied.
On interlocutory appeal, the Court of Appeals affirmed and then in an opinion filed with the clerk of court today, we reverse.
We first hold that Robbins has no cause of action under the Bivens to pursue his Fifth Amendment claim.
Although Robbins had administrative and judicial remedies for virtually all of his injuries, pursuing these individually might not amount to an adequate remedy, because it would subject him to as he put it, death by thousand cuts.
While Robbins makes a good case that his injuries should be addressed collectively.
On the other side of the ledger, we consider the difficulty in defining workable cause of action under Bivens.
Unlike most retaliation claim, Robbins’s claim cannot be resolved simply by determining whether the government officials set an impermissible objective or motive.
Since, all parties involved here can see that the government had a legitimate interest in pursuing an easement.
Just like any other landowner the Government is entitled to negotiate and it can be either more or less giving the land-use violations depending on whether a neighbor like Robbins agrees to grant it the easement that it wants.
Robbins’s case was therefore boiled down to whether the defendants went too far and demanded too much.
We think that the too much standard, we would need to devise would be an unreliable guard to conduct and to liability.
Nor does it help Robbins to look at the claim more abstractly as a claim for retaliation against a property owner seeking to enforce its rights.
So, this would sweep in a wide variety of claims of overzealous government enforcement, each one of which would be susceptible of the too much problem that we identify.
On the whole, we think it would be best to allow Congress to decide whether to create a damages remedy in a conflict like this.
We further hold that Robbins has no cause of action under RICO, because defendants have not committed the predicate act of extortion, which the Hobbs Act and in turn RICO defines as the obtaining of property from another with his consent induced by the wrongful use of actual or threatened force, violence or fear or under color of official right.
The question is whether extortion in composite situations where a Government employees seeks to obtain property for the exclusive benefit of the national government rather than for a private beneficiary, because the Hobbs Act is silent in this point, we consult common law meaning of the term extortion under color of official right.
In common law, extortion by a public official was the rough equivalent of what we would now describe as taking a bribe.
David H. Souter:
But the crime of extortion focused on the harm of public corruption, by the sale of public favors for private gain, not on the harm caused by overzealous efforts to obtain property on behalf of the Government.
Robbins does not cite and we are not aware of any court decision in the 60 years since the Hobbs Act passage that found extortion and efforts of government employees to get property for the exclusive benefit of the government.
We have some affirmative indication from Congress we think it is unreasonable to assume that the Hobbs Act was intended to expose all federal employees to extortion charges whenever they stretch and trying to enforce Government property claims.
The conduct that Robbins alleges falls outside the traditional definition of extortion and his RICO claim therefore cannot proceed because neither Bivens nor RICO gives Robbins a cause of action.
We have no case in to enquire further into the merits of the Fifth Amendment claim where the asserted defensive qualified immunity.
Justice Thomas has filed a concurring opinion in which Justice Scalia joins.
Justice Ginsburg has filed an opinion concurring in part and dissenting in part in which Justice Stevens joins.


The House Judiciary Committee on Wednesday moved a bill banning assault weapons forward, but it’s unclear if the legislation has enough support to pass a floor vote.
Democratic Reps. Jared Golden of Maine and Henry Cuellar of Texas have said they won’t support the bill, while Republican Reps. Chris Jacobs of New York and Adam Kinzinger of Illinois have said they are open to voting for a ban, according to The Hill. House Democrats have a four-vote margin.
The Assault Weapons Ban of 2021 was advanced in a 25-18 vote, but a date for a vote on the House floor has not been set.
“As we have learned all too well in recent years, assault weapons — especially when combined with high-capacity magazines — are the weapon of choice for mass shootings,” House Judiciary Committee Chairman Jerry Nadler, D-N.Y., said during the bill’s markup. “These military-style weapons are designed to kill the most people in the shortest amount of time. Quite simply, there is no place for them on our streets.”
Read more at Fox News


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Michael Moore Offers To Pay Fine Of Law Breaking Electors Who Don’t Vote Trump
The never ending total denial from Liberals is starting to get really old. Apparently they’re under the impression that electors are voting for Trump only to avoid a fine?
A personal appeal from me to the Republican electors of the Electoral College: Do not put our country in jeopardy: https://t.co/LIFVD4xjD4
— Michael Moore (@MMFlint) December 18, 2016
You can read his full nonsensical post at the link but here’s the relevant part:
2. But some states have made it “illegal” for you to vote any other way than for Trump. If you don’t vote for him, your state will fine you $1,000. So here’s my offer to you: I obviously can’t and won’t give you money to vote tomorrow, but if you do vote your conscience and you are punished for it, I will personally step up pay your fine which is my legal right to do.
What Moore doesn’t seem to understand is that offering to pay for someone to commit a crime is in and of itself the crime of solicitation…


Police are investigating an aggravated break-in at a Flinders Park home this afternoon (14 November).
Just before 4.30pm on Thursday 14 November, three men armed with what appeared to be firearms forced entry into a home on Van Dieman Street and threatened the occupant.
The suspects ransacked the home and left with a laptop, mobile phones and personal items. They left in a small black vehicle (pictured) heading east on Grange Road.
The victim was not physically injured during the incident.
One suspect is described as being of Caucasian appearance, aged 25 to 30-years-old, about 193cm tall and with a slim build. He was wearing a black hooded jumper, black pants and a black mask covering his mouth.
The other two suspects are described as being of African appearance, both aged in their mid-20s, with slim builds and between 185cm and 193cm tall.
Police are searching for the offending vehicle, which is described as a small black hatchback sedan.
Police ask anyone with information that may assist the investigation to contact Crime Stoppers on 1800 333 000 or report on line at www.crimestopperssa.com.au
Anyone who sees the small black sedan, is asked not to approach and to call the Police Assistance line on 131444.


Two Virginia Beach police officers were pelted with cans and bottles Friday by a beachfront crowd, officials said.
Neither officer was injured and the crowd dispersed as additional officers arrived, police spokesman Lewis Thurston said. There were no arrests.
Thurston said a group of 200 to 250 young people was gathered on the beachfront around 1 p.m. when the people were spotted by an officer answering a public intoxication complaint.
According to Thurston, the officer called for assistance, and when a second officer riding an all terrain vehicle approached the crowd, the officer was hit by a bag of ice.
The first officer came to the assistance of the second and both where pelted by cans and bottles thrown from the crowd of black youths in their late teens and early 20s, Thurston said. The crowd overturned the all terrain vehicle.
"This could have happened on any beach on any weekend with any group of people," Thurston said.
Last year, a traditional Labor Day end-of-summer party, which drew a number of students from predominantly black colleges and universities along the East Coast, ended in violent confrontations between police and young people. More than $1.4 million in damage was done in looting and rioting.
Thurston said police have started beachfront foot patrols several weeks earlier than normal this year.
According to Capt. Clyde Hathaway, the patrols were started earlier this year because of alleged gang attacks.


The Tehran prosecutor has announced criminal charges are being filed against the directors of three news outlets and three famous figures for reporting or commenting on the recent wave of gas attacks on girls' schools.
The editors of centrist daily Ham-Mihan centrist daily, Shargh newspaper, and moderate news website Rouydad 24 have all been indicted for reporting on the attacks.
Iranian academic and reformist political activist Sadegh Zibakalam, Secretary General of Unity of the Nation Party Azar Mansouri, and cinema star Reza Kianian have also had charges filed against them.
The harsh legal action comes amidst growing censorship from the regime and continued internet shutdowns as it battles the wave of revolutionary fervor. It also follows remarks made by Chief Justice Gholam-Hossein Mohseni-Ejei who called for "severe punishment" of those discussing the gas attacks which have seen hundreds of school girls across the country fall in and need hospital treatment, since November.
Ejei on Monday described the attacks as a “clear example of corruption on Earth,” a Sharia term that can lead to the death penalty, but he also threatened those who would comment on the incidents.
Almost four months after the attacks which have taken place in scores of schools, the Islamic Republic has failed to issue a clear report on those responsible, the kind of chemicals used, or make any arrests.
It continues to silence critics who fear this large-scale action has been initiated from the government's brutal security forces as they crack down on revolutionary dissent, which women and girls have played a vocal role in since the death of Mahsa Amini in September.
Interior minister Ahmad Vahidi, wanted by Interpol for his role in the bombing of a Jewish community center in 1994, has been tasked with leading the investigation. The ex IRGC commander has as yet announced no new leads.


Federal prosecutors alleged in a new court filing this week that Rep. Duncan D. Hunter used campaign funds to help facilitate extramarital affairs, and they want to show jurors evidence of the relationships at his upcoming trial.
In the new filing, prosecutors allege Hunter’s romantic entanglements blossomed as he used campaign money for large expenses — such as a ski trip near Lake Tahoe — and small ones, such as Uber rides to and from the women’s homes.
Hunter said Tuesday: “This is all going to trial, so you have criminally political prosecutors in this case. . . . This is a personal smear campaign.” He declined to address the allegations of affairs.
“I’m not going to talk about the allegations,” he said. “We’re going to trial, and I look forward to battling this out in trial.”
Hunter’s defense attorneys did not immediately respond to a request for comment.
Hunter and his wife, Margaret, were charged last year with using more than $250,000 in campaign funds to pay for family vacations, theater tickets and other personal expenses. Prosecutors say he used his campaign account as his “personal piggy bank” to live well beyond his means.
Hunter has previously accused prosecutors of pursuing him for political reasons, and he referred Tuesday to a motion his attorneys made asking for the case to be dismissed — or for the prosecutors office that brought the case be forced to recuse — because two involved in the investigation had attended a political fundraiser for Hillary Clinton.
Hunter was one of the first lawmakers to endorse Donald Trump’s run for office. Prosecutors have sought to preclude the congressman’s defense from alleging political bias at his trial.
Hunter’s wife, meanwhile, pleaded guilty in the case this month and agreed to “tell everything,” according to a copy of her agreement with prosecutors. Prosecutors revealed in another court filing they have texts between Margaret and her husband, who have three children, in which they discussed using campaign funds on personal expenses.
The latest filings came as prosecutors and Hunter’s defense attorneys traded motions about what evidence they hoped would and would not be admitted at his trial, which is scheduled to begin in September.
Hunter has continued serving in Congress and won reelection last year despite being charged. Then-House Speaker Paul D. Ryan (R-Wis.) forced Hunter to resign his seats on the Armed Services and Transportation and Infrastructure committees, leaving current House leaders with few options to respond to the latest revelations.
House Speaker Nancy Pelosi (D-Calif.) said at the time of Hunter’s indictment that he ought to resign, calling the charges “further evidence of the rampant culture of corruption among Republicans in Washington today.”
Ammar Campa-Najjar, a Democrat who is challenging Hunter in the next election, tweeted that Hunter was “literally in bed with lobbyists.”
Rep. Susan Brooks (R-Ind.), former chair of the House Ethics Committee, said Tuesday she had just heard about latest Hunter allegations and declined to comment. Asked whether it was concerning he had been accused of intimate relationships with a staffer and lobbyists, she said, “Absolutely that is a concern.”
House Minority Leader Kevin McCarthy (R-Calif.) said he had not yet seen the new allegations against Hunter, because he had been in meetings. “I know Duncan Hunter is going to have his day in court,” he said.
House Minority Whip Steve Scalise (R-La.) said that Hunter has a right to have his day in court and that he will not call for his resignation. “Look, there have been rumors going around for a while,” Scalise said. “I mean, we saw even during the campaign, there were charges. But ultimately, it’s going to get resolved in the courts. I don’t know about the latest details of what happened. But I do know it’s going to get resolved in the courts.”
A Republican lawmaker close to party leaders said that because Hunter had already been removed from committees, there were few other options to take. Asked whether leadership would nudge him to resign, the lawmaker said, “He’s not someone you can nudge.” The lawmaker spoke on the condition of anonymity to candidly describe private conversations.
Prosecutors say evidence of the affairs shows Hunter was using campaign money for purely personal purposes.
“Precisely because each of the women worked as lobbyists or congressional staffers, Hunter may suggest that he was justified in spending campaign funds on all of his ‘meetings’ with these individuals,” they wrote. “Evidence of the intimate, entirely personal quality of Hunter’s specific encounters with these women is essential to demonstrate that his spending to facilitate those encounters was improper.”
The filing does not name the women with whom Hunter was said to be involved, but it spares few other details — tracing chronologically how Hunter met and embarked on a relationship with each.
The first alleged affair prosecutors described began in 2009 — the year Hunter took office. Hunter, prosecutors alleged, befriended a lobbyist he met through work, and their relationship “soon blossomed beyond a mere friendship.”
Prosecutors said Hunter began living with the woman in her Washington-area home and used campaign funds to pay for food and drinks. The pair also took trips together, prosecutors alleged, including an early-2010 ski vacation to a resort near Lake Tahoe and a weekend “double date” road trip to Virginia Beach.
In both instances, prosecutors alleged, Hunter paid with campaign funds, which amounted to more than $1,000 in each case, including the hotel tabs and transportation costs.
Prosecutors said that relationship ended in April 2012 and that by August of that year, Hunter was involved with a woman who worked in the office of a member of House leadership. As their relationship developed, prosecutors alleged, Hunter began staying at the woman’s house every night — and paying for his Uber rides there with campaign funds.
In 2015, prosecutors said, Hunter started another romantic relationship with a woman hired to work in his office — and used campaign funds to pay for their and others’ tab at H Street Country Club and Matchbox Pizza in the District.
Later that year, prosecutors said, he used campaign funds in what prosecutors described as a more fleeting encounter. At an event at the Hamilton Hotel, prosecutors said, Hunter met up with a lobbyist he knew because she had organized events and fundraisers for him.
“That night, however, was not about business,” prosecutors wrote. They said Hunter and the woman went to the woman’s home “where they engaged in intimate personal activities unrelated to Hunter’s congressional campaign or duties as a member of Congress,” and Hunter used campaign funds to pay for $42 in Uber fares.
Prosecutors said the congressman similarly used campaign funds to pay for Uber rides back to his office in 2016 after an affair with a different lobbyist.
Hunter’s trial is likely to result in a messy airing of his personal life, especially if prosecutors are allowed to admit all of the evidence they want to. In addition to revealing details of the alleged affairs, prosecutors described in a filing Monday how the Hunters were financially stretched from the moment the congressman took office.
They alleged that the couple overdrew their bank account more than 1,100 times in seven years — incurring more than $37,000 in overdraft fees. Yet, because of campaign money, they still were able to travel overseas, eat well and play “seemingly endless rounds of golf,” prosecutors alleged.
“To finance this lifestyle,” prosecutors wrote, “they treated Hunter’s campaign treasury as their personal piggy bank, regularly embezzling funds to make personal purchases that their own finances could not support.”
Mike DeBonis and Rachael Bade contributed to this report.
Correction: An earlier version of this report referred to Brooks as vice chair of the House Ethics Committee. She is a former chair.


The beginning of a new year is a good time to devote thought to the big trends that are likely to impact industry in 2022 and beyond.
After a year of considerable upheaval, the social and economic impacts of the Covid pandemic, and governments’ responses to it, are beginning to manifest themselves.
For the legal profession, 2020 caused a reflection in law firms of how to face down the existential threat of Covid and remain successful. 2021 was a back to basics year, one that demonstrated that traditional law firms are anything but a spent force.
For courts of law over the same period an impressive pivot to the digital delivery of justice outcomes proved that when push came to shove, innovation in a traditionally conservative group such as the judiciary was not only possible but was achieved with a degree of success that exceeded expectations.
What then for 2022 and the future of the law? Drawing on what we are seeing play out before us and looking at what is needed to continue to succeed, I see five major trends.
The rise and rise of technology
The end of three decades of cheap labour courtesy of the former Eastern Bloc countries and Asia, particularly China, combined with record levels of government stimulus and disrupted supply chains have led to an inevitable outcome, the return of inflation. Just how sustained that trend will be remains a live debate amongst economists; however it is reasonable to assume that we will see inflation flow through to wages at some point.
In addition to that, the taste of the work from home lifestyle cultivated during the pandemic is causing office bound workers to reassess their priorities.
With the millennial generation and likely Gen Z, we are also dealing with people who do not necessarily share all of the work attitudes of the Boomers and X Gen, that work was our life. It is a workforce that will deliver to employers in a different way.
Taken together these two factors will impact the cost, availability and willingness of labour. To counteract that it is likely we will see a greater and greater emphasis placed on smart technologies to enable better use of lawyers and support staff time, to deliver more for less. Technology is the key to increased productivity.
AI, once the province of the larger firms only, will gradually come to the fore. For mid-sized firms the focus will remain on automation, process, and outsourcing to cheaper forms of labour.
However future innovation will most likely give way to a fair dose of pragmatism. Traditional law, once supposedly challenged by ‘new law’, turned out to be a nice little earner in 2021. With the terror of Covid abating, law firms will want to hang onto their new found profitability, and rather than shoot for the stars find more basic ways to save on increasingly costly labour by best exploiting the opportunities that tech presents. A dance with death, in a business sense, has had a sobering effect on the over exuberant futurists. Firms will turn to what is known to work.
Covid has changed the attitudes of everyone, and clients of law firms are no exception. Client driven expectations of how legal services will be delivered to them in the future, fine tuned by virtue of the Covid pandemic, will drive a change in the way lawyers will go about satisfying their clients. The remote way is here to stay, and law firms will need to stay client focused to meet such expectations or they will lose to other more flexible and innovative, and potentially non-lawyer providers.
It will result in clients leading the legal profession by setting their expectations rather than the reverse. We should expect the law to become ever more client focused.
Fixed price and predictive pricing
This segues into another trend we will see increasing: clarity in price setting. With the rise of in-house lawyers and the increasing cost of delivering legal services (in part due to the ever rising complexity of the law, and exacting requirements of courts and tribunals), work will go to those firms who can promise a greater level of certainty either through fixed priced jobs or very clear and predictive ways in which to measure and control spend.
There are few professions in which pricing can be so variable, because litigation is unpredictable, but as there is no lack of competition in the legal industry, satisfying client demands for certainty will mean firms will engender greater client loyalty if their prices are clear, predictable, and where possible fixed. It is entirely possible to run fixed priced and hourly rate models side by side. They are not mutually exclusive.
In an increasingly litigious society, and one where regulation is at times overwhelming, lawyers will remain in demand. However, clients get a choice – and they will not choose opaque pricing structures over clarity, simplicity and predictability. Not only will the method of the delivery of the law change, so will our approach to pricing.
If 2021 is remembered for a few things, one will be the settling realisation that cyber attack and cyber crime is here to stay. There has been no abatement, indeed the opposite has occurred. Cyber attacks have become an everyday occurrence and not only business but government and government agencies are under constant and increasing threat.
Responses within the insurance industry are a clear indicator that risk will only worsen in this area. If business can even get an underwriter to write cyber and crime policies, it will come with clear limits on the scope of cover, and be priced according to the risk.
All industries are vulnerable to cyber attack, but few more so than the law. We hold our clients money in our trust accounts, we transact daily to and from those accounts, we hold privileged client data, and sensitive and competitive business information. Yet for many practising the law, it remains a relatively unsophisticated cottage industry. Thinking that because they do not operate trust accounts, barristers too remain blissfully unaware of the threat, as do many smaller firms.
A majority of lawyers have not even taken the basic steps of introducing double factor authentication and the like when interacting with clients and third parties. Counteracting the ever increasing threat to cybersecurity will become an obsession for diligent managing partners, firm owners and senior executives for the foreseeable future, or until governments and industry in Australia combine to achieve more permanent protections. Going on the erratic, confusing and at times incompetent governance responses to the Covid pandemic, one would not hold one’s breath on the latter coming any time soon.
Cybersecurity against the risk of cyber attack will remain at the forefront of law firm management in 2022 and beyond.
Covid was the ultimate disruptor in an industry that is difficult to disrupt. The law is highly regulated, slow to change and inherently conservative. There are reasons for that. We take oaths and affirmations to uphold the administration of justice as our highest obligation, and we protect the independence of the judiciary. We are slow to change because of the importance of the institutions and conventions that we are sworn to uphold and protect.
Faced with the extraordinary circumstances of the early iterations of the Covid pandemic, the courts in conjunction with legal associations did what many thought was inconceivable, and that was to pivot to provide online services in an abrupt breakthrough into the digital age. Not that that wasn’t where we would have ended up eventually. The High Court prior to Covid had been conducting leave to appeal hearings in an online digital format for some time, and the Federal Court had an advanced digital approach by comparison to the State Courts. It was the speed with which courts had to react to the crisis of Covid that compressed to nothing a process that otherwise would have taken years.
Having arrived so quickly at the current point, it seems unlikely we will see courts and tribunals unwind the dramatic steps that have been made into the digital world, and it is a trend that will continue and continue to be refined, as it is not without problems.
First, the principle of open justice requires that courts be open to the public and public scrutiny. The courts as they are operating now often allow access to parties and witnesses only, not the public, and that is an unacceptable state of affairs and a feature that must not be permitted to become the norm in a system of open justice such as ours.
Secondly, in reacting so quickly, courts across Australia did not adopt a uniform approach. A lack of uniformity in the long term is problematic. In the short term courts did what they had to do, and with impressive outcomes. Full credit goes to the heads of our jurisdictions, Courts Administration Authorities and the many judges and their staff who adapted in the blink of an eye. It was one of the most stunning changes of direction seen in the law for a long time, and maybe forever.
Third, whilst online digital fora lends itself to short procedural hearings and shorter arguments, longer complex matters are less suited to the digital format. Bret Walker SC recently made that point when reflecting on his recent period in practise. A witness communicates not only with speech but with a broader set of behaviours. Additionally, litigating when one is not in the same room as fellow barristers and the bench is not ideal.
The legal profession must however accept that the digital world is here to stay. The gains achieved by the courts in consultation with lawyers to create the current digital environment that has enabled the justice system to continue to function amidst the depths of global pandemic is not a genie that can be put back in the bottle. What’s more, it goes some way to addressing ever present cost and access to justice challenges. We will now forever practise law with one foot in the digital, and one foot in the in-person world.
The collision of a worldwide viral pandemic, generational changes in the workforce, an ever increasing reliance and use of technology, and the biggest government stimulus in history have combined to make 2022 a year to watch. There has been rapid innovation to counter threats, and the law like broader industry has managed admirably.
The lessons learnt and advances made are key to understanding where the legal industry will go this year and in the years to come.
Morry Bailes is Senior Lawyer and Business Advisor to Tindall Gask Bentley Lawyers, past president of the Law Council of Australia and a past president of the Law Society of South Australia.
Local News Matters
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Industrialized Building System or Mobile Structure Application
8 a.m. – 4:30 p.m. Monday – Friday
except state-observed holidays
Indiana Dept. of Homeland Security
Indiana Government Center-South, Room E208
302 W. Washington St.
Indianapolis, IN 46204-2739
Call us: 317-232-1407
Email us: email@example.com
Please allow 48 hours for a response, and do not leave multiple voicemails or send multiple emails.
Leave us feedback: Customer Satisfaction Survey
Apply for Construction Design Release or Purchase Certification Label (Seal)
The same system is used to apply for a construction design release for an industrialized building or mobile structure and to purchase certification labels (seals). For questions regarding the online application for industrialized buildings and mobile structures, please email the Building Plan Review Section at firstname.lastname@example.org. Questions about seals can be directed to the Code Enforcement Section at email@example.com. If you experience technical difficulties using the service, contact firstname.lastname@example.org for assistance.
- Information about the manufacturer of the facility
- Information about location of the facility
- Manufacturer/facility contact information
- An electronic copy of the floor plan(s) will be needed for the Construction Design Release, so please ensure this information is available before starting the application process.
- You must use Internet Explorer.
- Keep all information at hand when filing. If the web application times out, all information must be retyped.
- To use the online service, instant access and credit card fees will apply that are separate from the normal fees. E-checks are also accepted.
Online Application for Industrialized Buildings and Mobile Structures
Note: You must use Internet Explorer for the application to work properly.
- Indiana Administrative Code, Title 675, Article 15
- Construction Design Release Application for Industrialized Building Systems and Mobile Structures
- Manufactured Home Consumer Complaints
- Manufacturer List
- Schedule of fines and civil penalties
- State Certification Seal Application for Industrialized Buildings and Mobile Structures
Previous Construction Design Releases for Industrial Buildings and Mobile Structures
Visit the Construction Design Releases for Industrial Buildings and Mobile Structures page to search all industrial building and mobile structure design releases by date range, specific release number or manufacturer name.
Frequently Asked Questions
- What is an industrialized building system?
According to Indiana Code 22-12-1-14, "industrialized building system" means any part of a building or other structure that is in whole or in substantial part fabricated in an off-site manufacturing facility for installation or assembly at the building site as part of a Class 1 structure, a Class 2 structure or another building or structure. However, the term does not include a mobile structure or a system that is capable of inspection at the building site.
- What is a mobile structure?
According to Indiana Code 22-12-1-17, "mobile structure" means any part of a fabricated unit that is designed to be: (1) towed on its own chassis; and (2) connected to utilities for year-round occupancy or use as a Class 1 structure, a Class 2 structure or another structure.
- What is a modular structure?
According to 675 IAC, Article 15, "modular structure" means an industrialized building system other than a mobile structure intended to be placed upon a permanent foundation.
- What is a permanent foundation?
According to 675 IAC, Article 15, "permanent foundation" means any structural system capable of transposing loads from a structure to the earth at a depth below the established frost line without exceeding the safe bearing capacity of the supporting soil.
- What is the fee schedule?
See 675 IAC, Article 15, Rule 1.6 for the fee schedule for industrialized building systems and mobile structures.
Each type of home has its own specific code, and the codes must be applied accordingly. Supervision of the work undertaken to site or install any of these units is the responsibility of the local building official, with the possible exception of manufactured homes sited within a mobile home park (which is controlled by the Department of Health). Any questions or concerns of the local building official in regards to construction of any of these units should be voiced to the Code Enforcement Section.
- Modular Seal (P)
Modular residential units are reviewed, constructed and inspected to the Indiana One- and Two-Family Dwelling Code. Modular commercial units are reviewed, constructed and inspected to the Indiana Building Code. Units constructed to either code will have Indiana Modular seals (gold). These seals can be found inside the cover of the electrical service panel and typically inside a closet on units not containing an electrical panel. When ordering seals, a "P" seal means a Modular seal.
- Mobile Seal (M)
The Indiana Mobile Structures Code is applicable to single mobile commercial and residential add-on structures up to and including 16-foot-wide units. Commercial mobile units that consist of more than one unit are structurally compliant to the Indiana Mobile Structures Code, while use requirements are dictated by the Indiana Building Code. The Indiana Mobile seals (blue) will be located inside the electrical service panel cover, with one for each section of a structure. When ordering seals, an "M" seal means a Mobile seal.
- Manufactured Home Seal
HUD Manufactured Home Construction and Safety Standards are applicable to HUD-manufactured homes and are specifically for manufactured homes (mobile homes). The HUD-manufactured home seals (red) are located at the rear of each section of the home, mounted on the siding approximately 12 inches above the chassis and 12 inches inward from the rear of the home.


Beware if you hear from someone claiming to be from the state and offering to help with that timeshare resale scheme you fell for.
The Department of Business and Professional Regulation is warning that callers falsely claiming to be from their agency are asking timeshare owners for money, saying they can recover their losses. Never give payments or personal information to solicitors you don't know. To report any telemarketing scam: 800-435-7352 or freshfromflorida.com.
— Diane C. Lade


Maryland, Wal-Mart, and Health Care
As the New York Times puts it,
The Maryland legislature passed a law Thursday that would require Wal-Mart Stores to increase spending on employee health insurance, a measure that is expected to be a model for other states.
Economics says that ultimately this will reduce the wage income of low-skilled workers in Maryland. That is, Wal-Mart is not going to suddenly increase compensation for low-skilled workers. It either has to cut wages, cut hiring, or both.
How can the state of Maryland justify this interference with how Wal-Mart chooses to compensate workers?
1. The legislators may believe that they know better than workers what is good for them.
2. The legislators allege that Wal-Mart workers receive Medicaid benefits, and the legislators resent this fact.
It seems to me that the appropriate response to (2) is to tighten the eligibility rules for Medicaid. But then, I’m just an economist.


She was off duty and wearing a bikini but that didn’t stop Swedish police officer Mikaela Kellner from catching a suspected thief.
(Yahoo)- A pickpocket got more than he bargained for after targeting a group of friends in Sweden, resulting in his being restrained by a bikini-clad off-duty police officer in a rather unconventional arrest.
Mikaela Kellner was sunbathing with friends in a park in Stockholm before she jumped into action to tackle the brazen man to the ground, according to Stockholm news site The Local.
“My first intervention while wearing a bikini during my 11 years as a police officer! Pretty fun and pleasant I must say,” she wrote to accompany a picture of the incident she shared on social media (roughly translated).
Kellner has been a police officer for more than a decade.
She said the man approached her group of friends, claiming he was trying to sell magazines for the homeless. However, after they declined to buy anything he began behaving strangely.
Acting on instinct, Kellner reportedly told her friends to watch their belongings. It wasn’t until the man had left that one of Kellner’s friends noticed their phone had disappeared.
She suspected he had used the magazines to cover a phone and take it without attracting attention. Kellner immediately gave chase.
“There was no time, so I ran after him, maybe 15 metres [about 50 feet] or so,” she told The Local. The incredibly fit officer was also on Swedish Ninja Warrior, and she does not look like someone you’d want to mess with.
Fortunately, another one of Kellner’s friends is also a police officer, and together, the pair held on to the man and called other officers for help.


Edge Protection Systems, when installed on the manufacturers guidelines offer a secure working environment for people working in height. Mesh barrier systems like APAC SAFEDGE have come to be a default for some builders, but others within the sector are still unaware of the innovative alternatives which are readily available to them and how they could save lives and radically enhance installation and maintenance period.
APAC Builders Equipment Ltd are pleased to have been providing innovative border protection alternatives to the Construction and Ground works Industry for more than seven years.
What it is intended to do?
Temporary Edge Protection Systems are employed in building work primarily to stop people and materials from falling to lower levels from the working platform.
An advantage protection system must include a principle guardrail and an intermediate guardrail or intermediate protection. All elements inside the machine ought to be made to prevent accidental removal or displacement of any part during usage.
Compliance In the UK, the Work at Height Regulations 2005 regulate the needs for the prevention of falls from height. These regulations make clear the requirement for choosing collective steps like border protection in taste for personal fall protection steps.
Additional to the lawful requirements set out in the Work at Height Regulations 2005, all border protection systems must comply with the British and European Standard for Temporary Edge Protection Systems called BS EN 13374:2013+A1 2018.
This standard specifies the prerequisites for installing border protection on horizontal and inclined functioning surfaces and clearly sets out the prerequisites for fulfilling the 3 types of edge protection:
Class A: Edge protection for horizontal surfaces and slopes around ten degrees.
Class B: Edge protection for horizontal surfaces and slopes around 30 levels or with limits around 45 degrees.
Class C: Edge protection for steeply sloping surfaces around 45 degrees or with limits to 60 degrees.
Static load testing, non dynamic loading or large dynamic loading is necessary for each individual category of system.
Even the Safedge System is strong but flexible and will offer protection for every single phase of the undertaking andnot only meets but surpasses the requirements set out for Class A and Class B systems.
Read more about our APC Compression Post by Clicking Here.
Or Find out more about the Edge Protection Federation (EPF) code of Practise by following This Link.


A 49-year-old mother was Monday, January 31 sentenced by the Pietermaritzburg High Court to 20 years in jail. The judgement was handed Ziningi Jane Nzama for orchestrating the death of her son in order to profit from a life insurance policy taken out in his name.
Nzama, 49, pled guilty to charges of premeditated murder and fraud on January 24, 2022, according to a South African Police Service (SAPS) spokeswoman in KwaZulu-Natal, Lieutenant Colonel Nqobile Gwala.
In April 2021, the body of her 20-year-old son, Asanda Kwanda Nzama, was discovered inside a residence in Esikhelekehleni, Ichanga. He was shot in the head and body and was pronounced dead at the scene.
Gwala explained that after an intensive investigation by the investigating officer assigned to investigate the docket, “the accused Ziningi Jane Nzama was arrested on December 11,2021 for the premeditated murder of her son.”
Simphiwe Silangwe, 29, and Mthokoziseni Majozi, 49, have also been detained in connection with the murder and are facing the same allegations as Nzama.
Police investigations indicated that the mother had her son slain because she had taken out insurance policies in his name. The mother was sentenced to 20 years in prison by the Pietermaritzburg High Court.
The two co-accused have been remanded in detention until February 24. They will appear in front of the Camperdown Magistrate’s Court.


Over 600 suspects were arrested around Gauteng as Operation “O Kae Molao” continues to close the net on criminals in the Province.
The Gauteng MEC for Community Safety Ms Faith Mazibuko and Gauteng Provincial Commissioner Lieutenant General Elias Mawela led the operation in the West Rand to a chop-shop in Krugersdorp where police recovered six motor vehicle engines that were tampered with, and the engine of a Mercedes Benz that was reported stolen in Pretoria.
While at the operation, a Colt van carrying more engines was intercepted and impounded after it was discovered that the engine was also tampered with. The 45 year old owner of the chop-shop was subsequently arrested for possession and receiving stolen property.
Police then pounced on a hostel in Kagiso during the raid and recovered six unlicensed firearms and a stolen vehicle. Another stolen vehicle was recovered and suspects arrested as the MEC and Provincial Commissioner were at a roadblock in Kagiso.
The operation started with the raiding of wanted suspects in various places across the Province where police arrested over 530 wanted suspects for crime that includes murder, rape, robbery, theft, house breaking and malicious damage to property, possession of drugs, pointing of firearm and house robbery.
More suspects were arrested during the raids and roadblocks for possession of suspected stolen vehicles and undocumented persons were taken in for processing and verification.
Fines amounting to R6500 were issued and in relation to Administrative Adjudication of Road Traffic Offences (AARTO) while counterfeit goods to the value of R550 000 were confiscated during the operation.
The multi-disciplinary Operation “O Kae Molao” will continue in Gauteng until crime is brought to its lowest level. The arrested suspects will appear in different Magistrates’ Courts within the province.
South Africa Today – South Africa News


Food Safety Director
Triple B Corporation Seattle, Wa. dba Real Foods Kent WA. and Charlie’s Produce Anchorage, Alaska is recalling1336 cases of the products listed below because they contain Daniella brand mango that were recalled because it has the potential to be contaminated with Salmonella braenderup.
Salmonella is an organism which can cause serious and sometimes fatal infections in young children, frail or elderly people, and others with weakened immune systems. Healthy persons infected with Salmonella often experience fever, diarrhea (which may be bloody), nausea, vomiting and abdominal pain. In rare circumstances, infection with Salmonella can result in the organism getting into the bloodstream and producing more severe illnesses such as arterial infections (i.e., infected aneurysms), endocarditis and arthritis.
This product was used in retail stores and Deli in Washington and Alaska.
Shelf life of the product is 5-7 days
Real Foods Product Use by Date 7/12/2012 to 8/29/2012
|Item #||Label||Item Description||Size||Container Type||UPC||Use-By Date Range||Location of UB Date|
|027-01480||Haggen||CUT,TROPICAL MIXED FRUIT(T/H)||8 oz||Rigid Plastic Cup||UPC: 045009014801||7/21/12 – 8/29/12||Center of product label|
|027-06055||Costco||FRUIT TRAY,MANGO/CUT SPEARS(COSTCO)||5 lbs||Rigid Plastic Tray||UPC: 045009060556||7/21/12 – 8/29/12||Outer case label|
|028-00165||Metropolitan Market||CUT,MANGO/PAPAYA W/LIME (MET MKT)||10 oz||Rigid Plastic Cup||UPC: 045009001658||7/21/12 – 8/29/12||Bottom of product cup|
|028-00172||Metropolitan Market||CUT,SEASONAL MIX (MET MKT)||20 oz||Rigid Plastic Cup||UPC: 045009001726||7/21/12 – 8/29/12||Bottom of product cup|
|028-00173||Metropolitan Market||CUT,SEASONAL MIX (MET MKT)||10 oz||Rigid Plastic Cup||UPC: 045009001733||7/21/12 – 8/29/12||Bottom of product cup|
|028-06037||Charlie’s||CUT,SEASONAL FRUIT MIX||10 oz||Rigid Plastic Cup||UPC: 045009060372||7/23/12 – 8/31/12||Bottom of product cup|
|028-06454||Charlie’s||CUT,SEASONAL FRUIT MIX||20 oz||Rigid Plastic Cup||UPC: 045009064547||7/23/12 – 8/31/12||Bottom of product cup|
|028-07323||Charlie’s||CUT,MIXED FRUIT TROPICAL(NL)||8 oz||Rigid Plastic Cup||UPC: 045009073235||7/23/12 – 8/31/12||Bottom of product cup|
Charlie’s Alaska Product Anchorage Use By Date 7/21/2012
|Label||Item Description||Size||Container Type||UPC||Use-By Date Range||Location of UB Date|
|Alaska Carrot||Seasonal Berries (Walmart)||8 oz||Rigid Plastic Cup||045009020178||7/21/12 – 8/31/12||Bottom of product cup|
|Alaska Carrot||Seasonal Berries (Walmart)||16oz||Rigid plastic Cup||045009020635||7/21/12 – 8/31/12||Bottom of product cup|
|Alaska Carrot||Seasonal Fruit Bowl (Walmart)||40oz||Rigid Plastic Bowl||045009064806||7/21/12 – 8/31/12||Bottom of product Bowl|
|Alaska Carrot||Gourmet Fruit Blow (Costco)||64oz||Rigid Plastic Bowl||697327066934||7/21/12 – 09/05/12||Bottom of Product Bowl|
|Alaska Carrot||Fruit Cup Mango/Red Grape||4oz||rigid Plastic Tray||045009071408||8/22/12 – 9/01/12||Outside case Box|
The recall was initiated after it was discovered by Triple B Corp. that Daniella brand mangos were used in some of the product that is being recalled by the supplier due to the potential contamination with Salmonella. braenderup.
Out of an abundance of caution, as a service to the general consuming public at large, all products are being recalled in consultation with the Food and Drug Administration (FDA)
Consumers who have purchased any product with Daniella brand mangos in them are urged to return them to the place of purchase for a full refund. Consumers with questions may contact our company at 206-625-1412


March 21, 2012
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