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The correlation between oral and physical health has become more and more evident over the last several years. Surveys have supported the conclusion that people who suffer from various medical conditions also have a tendency for dental health issues. The connection between diabetes and gum disease is a prime example.
Periodontitis is the advanced stage of gum disease. It is associated with a severe inflammation of the gums. This inflammation or infection, makes it more difficult for the body to control blood sugar levels which is a big factor in the ability to manage diabetes.
Gum infections are often associated with inflammations of the blood vessels blocking the flow of blood to various parts of the body. This blockage can cause a rise in blood pressure which can lead to heart attack or stroke.
As with most other health concerns early treatment is key to controlling gum disease. If it is diagnosed in the early stage of gingivitis treatment is pretty straightforward. Efforts will be made to step up the quality of the patient’s oral health care habits both at home and professionally. Regular six month checkups and professional cleanings will be scheduled in order to better control the plaque buildup that encourages gum disease.
The best thing you can do to protect against gum disease and its possible side effects is to improve your oral health care. Read more about the dental savings plan offered by Dental Care Associates in Minot on the website www.dentalcareminot.com.
Our dentist in Hamilton Township provides a variety of periodontal and implant dental services to our valued patients, just like you. We are a full service dental office that specializes in periodontic care and implants using the latest in technological advances. We treat all phases of periodontal disease, and pride ourselves on educating and helping all of our patients individually in a friendly, caring and professional atmosphere.
Our dental office is located in Hamilton Township, in Mercer County, NJ. As 2010, the township had a total population of 88,464, a 1.6% increase since 2000. The township was the state's 9th-largest municipality, after having been ranked 10th in 2000. In 2006, Hamilton Township was ranked by Morgan Quitno as the eighteenth-safest city in the United States, out of 369 cities nationwide. In the company's 2005 survey, the Township was ranked 15th safest of 354 cities surveyed nationwide. Hamilton hosts one of the largest recreational parks in the state, and borders another. It is conveniently located near many major NJ highways (NJ Turnpike, I-295, I-95), the NJ transit system makes it easy for commuters to get to NYC via Penn Station, and is close to most points along the Jersey Shore. (Source: Wikipedia)
Whether it’s a cosmetic procedure or an oral pathology, our dentist is here to assist you. We use both non-surgical and surgical procedures to help you maintain the health of your teeth and oral care. Our dentist in Hamilton Township, Dr. David B. Heering, is highly trained in placing dental implants, and we allow each patient to be a part of the process step by step so that they can make the most informed decision about their oral health. It is our goal to provide you with the best treatment in the most comfortable, relaxed environment possible.
Call us today to make your appointment to get started on the road to better oral health. We are open 4 days a week, from 9:00 AM to 5:00 PM, and open later on Thursdays to best accommodate you.
Associate Dentist Jobs in Bexhill-on-Sea, East Sussex. Associate Dentist, Bexhill-on-Sea, East Sussex. INDEPENDENT. £12 per UDA 60% private 40% NHS. Zest Dental Recruitment working in partnership with an established dental practice is seeking to recruit an Associate Dentist in Bexhill-on-Sea, East Sussex.
The practice operates a highly successful treatment plan, converting a large proportion of patients to private treatments. Dependent on the incoming dentist’s skill-set and ability to build good relationships with patients and discuss treatment options, the dentist can provide a huge amount of private treatments from a strong patient base, with a high influx of new patients joining the practice continuously. With a current practice profile of 60% private and 40% NHS treatments, the practice projects that this can be increased to 80% private, dependent on the incoming dentist’s ability.
Hours of work are Monday to Friday 9am to 5pm, with the option for extended hours for additional private treatments if you wish. The practice is extremely well equipped, you will have everything you need. You will be supported by a superb practice manager and qualified and experienced dental nurses. You will also benefit from the support of a dental hygienist/therapist.
Primarily we are seeking a dentist conversant with the NHS UDA system, however as described above and owing to the significant private opportunity at this practice, candidates with experience of treatments such as, Invisalign, Six Month Smiles, facial aesthetics, Inman Aligner, etc. would be beneficial, or the willingness with the support of the dental practice to attend the short courses associated with treatments such as described above.
Dentons - Yaiguaje v Chevron Corporation: Supreme Court releases leading decision on the enforcement of foreign judgments in Canada
Yaiguaje v Chevron Corporation: Supreme Court releases leading decision on the enforcement of foreign judgments in Canada
Supreme Court of Canada favours a relaxed approach to the recognition and enforcement of foreign judgments in Canada.
For a Canadian court to recognize and enforce a foreign judgment, a judgment debtor need only establish that the foreign court had a real and substantial connection with the litigants or the subject matter of the dispute. The “real and substantial connection” test does not apply with respect to the proposed Canadian jurisdiction of enforcement.
The existence of assets in the proposed jurisdiction of enforcement is not a pre-requisite to bringing an action for the recognition and enforcement of a foreign judgment in Canada.
Canadian courts may assume jurisdiction over Canadian subsidiaries of foreign judgment debtors, even if the Canadian subsidiary was not a named defendant in the initial action.
Canadian courts may still elect not to assume jurisdiction on the basis that there is another clearly more appropriate forum for recognizing and enforcing the judgment (forum non conveniens).
On September 4, 2015, the Supreme Court of Canada released its highly anticipated decision in Yaiguaje v Chevron Corporation.1 In dismissing the appeal of Chevron Corporation (“Chevron”) and Chevron Canada Limited (“Chevron Canada”), the Court favoured a relaxed approach to the recognition and enforcement of foreign judgments in Canada, unequivocally holding that a “real and substantial connection” between the proposed jurisdiction of enforcement and the matter which gave rise to the judgment debt, or the judgment debtor itself, is not required in order to establish the jurisdiction of the proposed enforcing court.
The decision, which both clarifies and curtails jurisdictional defences available to judgment debtors whose assets or operations extend across multiple fora, further facilitates the enforcement of foreign judgments in Canada. In the wake of Chevron, so long as the foreign court whose order gave rise to the judgment debt correctly assumed jurisdiction over the initial matter, Canadian courts will assume jurisdiction over defendants of related enforcement actions so long as they are correctly served pursuant to the applicable provincial or territorial rules of service.
Even though the Court has now closed the door on jurisdiction simpliciter defences in proceedings to enforce foreign judgments, alternative jurisdictional defences (including forum non conveniens) remain seemingly unchanged.
For over two decades, some 30,000 indigenous Ecuadorian villagers have sought compensation from Texaco, and its corporate successors, for alleged environmental damages caused by oil extraction operations in the Lago Agrio region.2
In 2003, a representative group of the affected villagers (the “Plaintiffs”), obtained judgment3 in the courts of Ecuador against Chevron, which had merged with Texaco in 2001.4 The judgment, modified but affirmed by an Ecuadorian appellate court, was ultimately worth an astounding $9.51 billion.5
In 2012, the Plaintiffs brought an action in Ontario for recognition and enforcement of the Ecuadorian judgment against the Canadian assets of Chevron and Chevron Canada, its seventh-level indirect subsidiary.6 In response, both corporations brought motions to set aside service or to stay the action on the basis that the courts of Ontario lacked jurisdiction simpliciter.
After dismissing the moving parties’ submissions with respect to jurisdictional simpliciter, the Superior Court, on its own motion, stayed the action pursuant to section 106 of the Courts of Justice Act because Chevron did not have assets or conduct business in Ontario.7 According to the Court, “any recognition of the Ecuadorian Judgement by this Court would have no practical effect whatsoever in light of the absence of exigible assets of the judgement debtor in this jurisdiction.”8
After refusing the Plaintiffs’ requests to pierce the corporate veil or to recognize Chevron and Chevron Canada as one and the same entity,9 Justice Brown recommended that the parties “take their fight elsewhere to some jurisdiction where any ultimate recognition of the Ecuadorian Judgment will have a practical effect.”10
The Plaintiffs appealed the Superior Court’s stay of proceedings and the moving parties, Chevron Canada and Chevron, cross-appealed the ruling that Ontario courts had jurisdiction simpliciter to hear the enforcement action.11 The Court of Appeal ultimately set aside the stay but agreed that Ontario courts did, in fact, have jurisdiction over Chevron and Chevron Canada.
The Ontario Court of Appeal’s decision confirmed that the test for recognizing and enforcing foreign judgments in Canada remained as articulated in Beals v Saldanha:12 a domestic court must be satisfied that there was a real and substantial connection between the initial claim and the foreign jurisdiction which rendered the judgment.13 Consequently, the Court held that Ontario had jurisdiction over Chevron given that the initial environmental damages claim had a real and substantial connection to Ecuador.
Where the Superior Court ruled that Chevron Canada should not be considered Chevron’s alter ego for the purpose of enforcement, the Court of Appeal took a different approach. Recognizing that it had jurisdiction over Chevron Canada (which operated in Canada), and emphasizing what it described as an “economically significant relationship” between the two entities, including the fact that Chevron Canada was, albeit indirectly, a wholly owned subsidiary of Chevron, the Court of Appeal held that Ontario courts had jurisdiction to determine the merits of the enforcement action against Chevron Canada, even though it was not a party in the Ecuadorian lawsuit.14
Finally, particularly in light of the fact that no party had requested a stay and no law or evidence had been heard on the issue, the Court of Appeal rejected the motion Judge’s view that this was an appropriate case for a court-imposed section 106 stay.15
In a unanimous decision, the Supreme Court of Canada dismissed Chevron and Chevron Canada’s appeal. Recognizing the moveable nature of assets in modern commercial environments, the Court made a series of rulings that further facilitate the enforcement of foreign judgments in Canada. According to the Court, oftentimes “recognition and enforcement in another jurisdiction is the only means by which a foreign judgment creditor can obtain its due.”16
The Court identified two issues in the appeal: (1) whether a real and substantial connection between the proposed Canadian jurisdiction of enforcement and the matter which gave rise to the judgment debt, or the judgment debtor itself, is required to establish jurisdiction over defendants of related enforcement actions, and (2) whether Ontario courts had jurisdiction over Chevron Canada, a third party to the Ecuadorian judgment.17 On both issues, the Court ruled in favour of the Plaintiffs: (1) a real and substantial connection was not necessary to establish jurisdiction over Chevron, who had been properly served pursuant to Ontario’s Rules of Civil Procedure,18 and had been properly within the jurisdiction of the Ecuadorian courts, and (2) consistent with a traditional jurisdictional analysis, and recognizing that it operated a bricks-and-mortar business in Ontario, Ontario courts clearly had jurisdiction simpliciter over Chevron Canada.
The Court explained that, in enforcement actions, it had never required there to be a real and substantial connection of the type argued for by Chevron.19 The Court clarified that in previous decisions it “did not articulate or imply a need to inquire into the enforcing court’s jurisdiction: the focus remained squarely on the foreign jurisdiction.”20 Consistent with this approach, the Supreme Court concluded that “in an action to recognize and enforce a foreign judgment where the foreign court validly assumed jurisdiction, there is no need to prove that a real and substantial connection exists between the enforcing forum and either the judgment debtor or the dispute.”21 Instead, in actions limited to the recognition and enforcement of foreign judgments, jurisdiction is established upon effective service of the foreign judgment debtor.22
In support of its conclusion that a real and substantial connection test should not be extended to enforcement proceedings, two principles were cited: (1) in enforcement proceedings, “the only purpose of the action is to allow a pre-existing obligation to be fulfilled”, and (2) the notion of comity and respect for the legal acts of other states militates in favour of relaxed rules regarding the recognition and enforcement of foreign judgments.23
The first supportive principle recognizes that enforcing courts fulfill a facilitative, rather than substantive role, with respect to adjudicated issues. As such, the enforcing court “does not exercise jurisdiction in the same way as it does in actions at first instance” and the tests for assuming jurisdiction, accordingly, need not be identical.24 Given that enforcement measures are limited to the confines of the enforcing jurisdiction, and understanding that obligations created by foreign judgments are universal, the Court held that the appellants’ concerns regarding jurisdictional overreach were overstated.25
With respect to the second supportive principle, the Court noted that “facilitating comity and reciprocity, two of the backbones of private international law, calls for assistance, not barriers.”26
Perhaps most controversially, the Supreme Court held that the existence of assets in the proposed jurisdiction for enforcement was not a pre-requisite to that court’s jurisdiction.27 Thus, judgment creditors have been extended considerable freedom to choose where to enforce foreign judgments in Canada and are now able to assess their enforcement options based on, not only on where the judgment debtors’ assets are currently situated but, where they might be in the future.28
Ultimately, Chevron, though of clear significance to multi-jurisdictional entities, is largely consistent with the gradual expansion of the recognition and enforcement of foreign judgments in Canada, commencing with the Supreme Court’s 1990 decision, Morguard Investments Ltd. v De Savoye.29
3 The Court, at paragraph 7 of its decision, acknowledged that a US court, in 2014, held that the Plaintiffs’ judgment was the result of fraud. That decision, and the underlying allegation of fraud, was not, however, before the Court.