2013-06-19T17:34:06-04:00 Georgialee Lang http://www.huffingtonpost.ca/author/index.php?author=georgialee-lang Copyright 2008, HuffingtonPost.com, Inc. HuffingtonPost Blogger Feed for Georgialee Lang Good old fashioned elbow grease. tag:www.huffingtonpost.com,2012:/theblog//3.1869422 2012-09-10T19:45:48-04:00 2012-11-10T05:12:01-05:00

Georgialee Lang http://www.huffingtonpost.com/georgialee-lang/
However, looks are deceiving because Jeffs, who is serving a life sentence plus 20 years, and teetering between martyrdom and self-delusion, has maintained control over his followers despite his confinement and Bountiful, B.C. is the worse for it.

Desperate to remain leader and prophet, Jeffs' tactics are diverse. In 2007 while imprisoned in Utah, a video surfaced that showed Jeffs in prison garb admitting he was a false prophet and had lied to his followers.

Yet several years later, he ordered his subordinates to spend thousands of dollars on newspaper ads across the United States which declared "Cease thy wicked attack ye government authorities against my people and my church," an ad clearly designed to buttress his tarnished image with his followers.

Reports of his suicide attempts, head-banging and food and water deprivation have been replaced by ranting revelations and errant edicts meant to solidify his control in Bountiful and similar communities in Utah, Colorado and Texas.

Over the last year Jeffs has ex-communicated hundreds of younger fathers and husbands, including at least a dozen or more men from Bountiful, ripping families apart with no apparent concern. He has ordered "rebellious" teenagers to be evicted from the community, for offences as innocuous as hairstyles and teen friendships. Several teenage girls from Bountiful have been caught by this edict.

Jeffs has also banned sexual relationships between spouses including kissing, hugging or any physical contact other than handshaking, a rule that will prevail until he is released from prison. He has declared that a group of 15 men alone are worthy of procreating and they shall father all FLDS children.

Mothers and fathers have been ordered not to touch or hug their children and toys, recreation, and games are no longer permissible.

The Bountiful elementary and secondary schools have, for the first time, refused government funding, opting to run the programs they desire. Reports have surfaced that school hours are now filled with YouTube videos of Jeffs' preaching.

But Jeffs' new tactics are backfiring. At Bountiful, both fathers and mothers who have been banished by Jeffs or taken the brave step of leaving voluntarily, are fighting back, trying to regain control of their lives, and more importantly, taking steps to rescue their children, who are suffering terribly.

Six of these Bountiful fathers brought their concerns to the Creston Provincial Court this past Thursday, regaling the judge with examples of Jeffs' bizarre pronouncements and the deleterious effects on their children.

The court heard about how four young boys were ejected from Bountiful because their father was an "apostate," one of the men who refused to accept Jeffs' leadership.

At least 40 children have been denied any contact with their fathers for many months, a situation that was partially remedied this week by Creston Provincial Court Judge William Sheard who ordered immediate access. A further court hearing is scheduled in Creston on Nov. 7.

The awakening in Bountiful may signal the beginning of the end of Warren Jeffs.]]> tag:www.huffingtonpost.com,2011:/theblog//3.1135886 2011-12-22T13:34:19-05:00 2012-02-21T05:12:02-05:00

Georgialee Lang http://www.huffingtonpost.com/georgialee-lang/
Meanwhile, their spouses are experiencing waves of anger, pain, and resentment. Deep down I believe most spouses know what's coming, but often fool themselves because the fallout from separation and divorce is so devastating and often embarrassing. We've all heard "They looked like the perfect couple."

Often female clients will say, "Oh, we're not going to divorce. My husband says this is just a trial separation." Don't believe it for a second! This is just another lousy husband who doesn't have enough respect for his wife to tell her the truth, the whole truth.

For spouses who are desperate to hang on to their marriage no matter what, it is cruel for their mates to pretend it's not really over when it is. While a phased-in separation may assuage the guilt of a spouse who is leaving, a left-behind spouse will only suffer more heartache knowing he or she has been set up, again.

In my 22 years as a divorce lawyer, I have seen the gamut of "breaking up is hard to do." Let me share a few of the more memorable scenarios.

Probably the worst thing you can do to a spouse is move out of the family home and take everything with you while he or she is out of town. While this may be the best option in a short, abusive marriage where there are no children, it often occurs in long-term marriages where the children have left the home.

I can't think of a crueler way to say sayonara to your husband. A person who would do this to their 30-year partner must be devoid of any human kindness or empathy.

An unusual approach is one that I personally observed while having dinner with married friends. I can't recall how the topic was broached, but my friend's husband suddenly declared that he and his wife had "had a good run, but some good things come to an end."

I, of course, thought he was joking, but this was no joke. I later learned he had convinced his wife to agree to purchase a "rental" apartment in a neighbouring town and coincidentally the company he worked for had just transferred him to their office in that community.

What seemed obvious to me had sailed right past my friend. Yes, he was now staying in the new apartment and coming home only on weekends. She only clued in when I suggested this was odd behaviour, but fully understandable based on his dinner comment.

Perhaps the most shameful "notice" was that of a small town mayor in California. At a busy city council meeting, Mayor Mario Hernandez suddenly announced to the crowd that he was having an affair with a councilwoman and explained that he was separated from his wife. He did this with his wife sitting in the first row of attendees.

When his wife attempted to speak out and deny the separation, the mayor instructed his acting chief of police to escort her out of the meeting if she spoke again.

Not surprisingly, Mayor Hernandez and his paramour quickly left the meeting together. A week later at the next San Fernando council meeting, 150 angry residents called for the mayor's resignation. His lover, councilwoman Maribel De La Torre, wisely stayed home that night.

Divorce can bring out the best and the worst in people. Don't forget the adage "You don't really know who you married until you divorce them."
]]> tag:www.huffingtonpost.com,2011:/theblog//3.1065735 2011-11-05T15:25:55-04:00 2012-01-05T05:12:02-05:00

Georgialee Lang http://www.huffingtonpost.com/georgialee-lang/
1. Conflicting Out All of the Top Divorce Lawyers

An age-old practice for a spouse who expects a long, drawn out divorce battle is to ensure their estranged partner can't retain a top divorce lawyer. It goes like this -- husband or wife makes appointments with the top lawyers in the area. At each meeting they reveal enough about their situation that the top lawyer, who they have no real intention of retaining, cannot act for their spouse.

If each top lawyer charges them $500.00 for a one hour consultation, they only spend a few thousand dollars to ensure they have defanged their spouse by preventing him or her from hiring a "gun" equivalent to their top-tier counsel. Yes, this happens in the world of high net worth divorce.

2. Firing Your Lawyer Just Before Trial

Another effective divorce trick is to fire your lawyer weeks before your divorce trial is set to commence. How does this work? It's easy. Let's say you are the wife of a wealthy husband. Since you obtained a court order ejecting your husband from the family home, you now reside in luxury with peace and quiet; you are receiving thousands of dollars a month in tax-free child and spousal support; and your life consists of tennis lessons, lunch with the girls at the Club and evening soirees.

Meanwhile your husband is doing what he always does: traveling around the world doing business deals to support your mutual lifestyles. He doesn't even see the kids much, and frankly, neither do you since you hired a second nanny. Life is hassle-free and your tennis pro is a real cutie.

Why would you spoil all this by taking a chance that a judge may eliminate some part of your lavish lifestyle or impose an access plan for the children to see their father that may interfere with your schedule?

3. Transferring Your Assets Off-Shore

While you may live a life of champagne and caviar, it is unlikely you can maintain that level of opulence if your spouse has arranged to stash all his liquid assets off-shore in trusts set up in any number of tax havens such as the Bahamas, the Isle of Man, Turks and Caicos or Switzerland.

In many jurisdictions a Court may make an order that off-shore assets be divided between the spouses, but just wait until you see how difficult it is for you to convince the foreign jurisdiction they must obey the order of a North American Court. All I can say is good luck!

4. Arranging Multiple Mortgages on Your Real Estate

It is not uncommon to see marriages where the "little lady" has no idea of what she and her husband are really worth. Imagine a spouse's disappointment when her lawyer informs her that the family home and their summer cottage are mortgaged to the hilt and have little or no equity. Their once middle-class standard of living evaporates as Mrs. now looks for a basement suite to house her and her two children.

Another real estate divorce trick is to build a lavish home on leased land that is situated on property that is in the agricultural land reserve, so that while it may have cost $3 million to build, it has no real market value since nobody in their right mind would purchase this property. Yes, this is a true story.

5. Building a House of Cards

For a time life is grand, but inevitably problems arise in your marriage. In an effort to please your spouse you try you to spend your way back to the marriage you once had. Little does your spouse know that the trips to Europe, Hawaii and the Super Bowl were leveraged, courtesy of American Express and Visa. The marriage does not survive and you discover your net worth is much less than you expected as you have tens of thousands of dollars in credit card debt all used for the family. Let's just hope the Sistine Chapel was worth it.

Perhaps you think that with the explosion of mediation and collaborative divorce, these tricks have lost their lustre? Think again. For spouses who need revenge more than they want closure, they are alive and well.]]> tag:www.huffingtonpost.com,2011:/theblog//3.1014865 2011-10-20T09:22:04-04:00 2011-12-20T05:12:01-05:00

Georgialee Lang http://www.huffingtonpost.com/georgialee-lang/
Clients frequently complain about the unfairness of divorce laws and the courts' reluctance to consider moral issues that are important to litigants, but irrelevant to the court.

Five of the most common complaints are:

1. My wife left me to move in with her boyfriend, why do I have to pay her spousal support?

In bygone years the courts only made spousal support orders where a recipient spouse was innocent of marital fault. When a wife was considered to be the cause of the marriage breakdown, no support was payable.

In the middle of the 20th century, divorce law began to evolve and currently many countries and states administer "no-fault" divorce. That means even if your husband or wife is a serial philanderer, or physically abusive, if they qualify for spousal support, they will likely get it. A long marriage results in a lengthy period of support and support theory is based on a lack of means of one spouse and the ability to pay of the other.

Imagine the dismay of a spouse with means when their husband or wife leaves them for another partner, moves in with that partner, and still receives support from their aggrieved left-behind spouse. The obvious question is "Why do I have to support her (or him) when she has chosen to move on with a new partner? Shouldn't she be supported by him?"

Sounds logical, however, the legal test for entitlement to support is based on "means and need". If the spouse moves in with a starving artist or someone on a disability pension, that spouse may still have need, despite their attachment to a new partner. Related to this complaint is the next one:

2. My ex spouse has remarried, why do I still have to pay spousal support?

Often long-divorced clients will call their family law attorneys bursting with good news. He or she will announce that after 15 years their ex has finally remarried and when can the spousal support payments end? The problem is that only if a former spouse agrees to the cessation of support, in writing of course, can payments be terminated.

Ex-spouses, however, are loath to give up what they have enjoyed for many years and most frequently the matter ends up in a courtroom. Twenty-five thousand dollars later and with a little luck, the support may be reduced, but not eliminated, because of the "means and needs" test.

3. Why does my ex get spousal support after my death?

In long marriages, spousal support is often ordered to be paid permanently or indefinitely. Some jurisdictions even order that support be secured by life insurance or binding on the estate of the payor upon his or her death.

What that means is that even after a paying spouse dies, the support lives on, paid from a life insurance policy or from the proceeds of the deceased payor's estate. The practical reality is that as spouses enter their "golden years" they generally live off their pensions or the proceeds of sale of their assets. Yes, the same pensions and assets that were already divided between the spouses at the time of divorce.

The alleged unfairness is that the deceased spouse's estate is reduced by the ongoing support obligation, to the detriment of the deceased spouse's heirs, and worst of all, it is paid from assets that were already divided equally. It's back to "means and need" again. If the recipient spouse has need and the payor spouse has means, support may continue after death.

4. Why am I still paying child support for my 24-year-old child?

Clients often ask why they are obliged to pay support for their children after the age of majority, and in particular, why they are ordered to fund an expensive university education? The argument usually centres around the fact that if the family was intact, decisions would be made that may include parental funding of school, but could also include children working part-time or applying for student loans.

The answer is simple. If divorced parents cannot agree on how to educate their adult children, then the court must step in. The laws in many countries provide that child support must be paid until the child obtains one post-secondary degree or diploma. Yes, even if the family, pre-marriage breakdown, had no intention to fund their children's schooling.

5. Why doesn't my ex spouse have to contribute to child support?

In many jurisdictions child support is governed by child support guidelines enacted by legislators. Many of these laws provide that a parent with primary residence of the children is entitled to child support based on the other parent's annual income. So far, so good. However, issues arise when the recipient parent's earnings outstrip the payor parent's earnings and yet the higher-earning parent is not obliged to make a financial contribution to support, so as to reduce the support obligation of the lower-earning parent.

The policy behind the law is that a primary resident parent's contribution is more than equal to monies paid for child support, for it is the primary parent who does the most work including transportation, socialization, schooling, medical and dental issues, psychological and emotional guidance and many other day-to-day matters for the care of children.

The common denominator in these scenarios is that if you and your spouse cannot come to an agreement on support, the court will intervene. Best to try to reach a compromise with your spouse then to risk the rigours of the law.]]> tag:www.huffingtonpost.com,2011:/theblog//3.991602 2011-10-04T07:00:36-04:00 2011-12-04T05:12:07-05:00

Georgialee Lang http://www.huffingtonpost.com/georgialee-lang/
In major centres, the menu of legal styles is unlimited. You can choose a pitbull, a basher, a shark, a collaborator, a nurturer or a paper-shuffler. No matter your choice, it is also true that many divorcing spouses hire multiple lawyers, often going through as many as three or four lawyers by the time their divorce is completed.

Why do clients of divorce lawyers change lawyers so frequently? It's because they are caught in an emotional vortex, facing the unknown and dreading the journey. However, there are legitimate reasons to fire your divorce lawyer. Consider the following:

1. Your Lawyer Pulls a Bait and Switch

This occurs when you hire a lawyer with a big reputation and never see him or her after your first consultation. Many busy, successful lawyers work with junior lawyers and paralegals and this is beneficial for a client. The usual, mundane paper-pushing can easily be done by a junior and at a far cheaper rate than a "big lawyer's" rate. However, if this is the way your lawyer works, you need to know up front. I always tell my clients that what they need from me is strategy and courtroom presence. The rest can be done by others with my supervision. Far better to have basic family law forms filled out by a junior who bills $250 an hour than by a "big lawyer's" charge-out rates. If you can't accept your lawyer's work style, time to find a new lawyer.

2. You Don't Know the Best and Worst Scenarios

After a few months, your lawyer should have received from you or your spouse's lawyer certain financial documents and information, and if you have children, details about your kids and the parenting arrangements during the marriage. You have every right to expect that once a clear picture of the family finances emerges and the roles of each spouse in the marriage are elucidated, your lawyer will tell you the good, the bad and the ugly. I am often asked to provide a "second opinion" and am always surprised when the client cannot tell me what their lawyer's plan is to resolve the case. If four months have passed and you have no idea of where you stand, it may be time to challenge your lawyer.

3. Your Lawyer Hasn't Done a Cost/Benefit Analysis

Unless you are a multi-millionaire and money is not an issue, you will want your lawyer to consider the financial viability of unleashing the hounds of hell on your spouse. By now, everyone knows how expensive court is and not just court, but the cost of two business valuators, two property appraisers, two child development experts, two accountants, and the list goes on and on. If you are fighting over a sum of $100,000 but it will cost you $150,000 to litigate, you would be a fool to proceed to court.

Ah, but what about custody of kids? You can't put a price tag on that. Yes, you can and you should. The worst battles of all are over children and usually the outcome does not justify the "go to war" tactics and accompanying costs.

A good lawyer will do everything he or she can to find a way to compromise on children's issues, short of court proceedings. If you have not had a realistic "money" talk with your lawyer, beware.

4. Your Lawyer Promises Big, But Delivers Small

An experienced, competent lawyer should be able to give you the odds of success for any court application he or she brings on your behalf. Legal cases are decided on decisions made in earlier legal cases, called precedents, and your lawyer should be fully aware of how cases like yours have been decided. While you cannot expect lawyers to guarantee a particular outcome, before you can make an informed decision as to whether to proceed to court, you need some idea of the lawyer's opinion of the likelihood of success. If your lawyer promises the sun, the moon and the stars, but delivers space junk, you may want to think twice.

5. Your Lawyer Never Sends You a Bill

While at first blush this may seem like the perfect lawyer, it is not. A lawyer who is unable to bill you is a lawyer that is likely highly disorganized, overworked, has taken on too many clients and is generally overwhelmed. No one likes surprises, and when you finally receive your bill, and you will, it will come as a big shock. Insist that your lawyer bill you monthly so you can see how much your case is costing you. Usually lawyers who fall behind in their billing also avoid conversations about costs and benefits obtained. Not a good combination.

A divorce lawyer's day is never boring and yet most other lawyers agree that divorce lawyers do the hardest work of all. They work with emotionally devastated clients who will become financially spent in the process. It's a tough job, but someone has to do it.]]> tag:www.huffingtonpost.com,2011:/theblog//3.981335 2011-09-28T15:57:24-04:00 2011-11-28T05:12:01-05:00

Georgialee Lang http://www.huffingtonpost.com/georgialee-lang/
Frequently, the worst of these types of conflict peter out once the children mature, interact with their peers and begin to think for themselves. Some parents also eventually recognize their anger hurts them more than it does their ex-spouse. But not always.

A recent court case in Illinois illustrates the worst possible outcome where parents refuse to put their children first and instead continue with angry reprisals and revenge, apparently oblivious to the seeds of destruction they are sowing, for themselves and their children.

In Miner and Miner v. Garrity 2011 IL App (1st) 1103023-U the Court of Appeal dealt with a lawsuit brought against Kimblerly Garrity, mother of the plaintiffs, Steven and Kathryn, who were 21 and 18-years-old when they commenced their lawsuit.

Their father, attorney Steven Miner, together with two other attorneys, filed the suit for them which claimed damages of $50,000 each, alleging their mother had intentionally or negligently inflicted emotional distress on them during their young lives.

Mr. Miner was quick to point out in media interviews that he tried to talk his two children out of filing the lawsuit, but they insisted. I think his protestations are unbelievable in view of the claims he advanced on their behalf.

The Garrity/Miner marriage ended after 10 years in 1995. Mr. Miner was awarded sole custody of Steven and joint custody with his ex, of Kathryn, who resided primarily with him. So how bad an access parent was Kimberly Garrity?

The children's grievances included their distress when their mother tried unsuccessfully to obtain primary residence of Kathyrn. She also allegedly treated the children unequally, requested medical receipts from their father before she would pay her one-half share, and referred to their father as a "Disneyland" dad.

Worse yet was the claim that when her mother began living with another man, Kathryn's distress caused her to gain weight, which was only exceeded by her mother's gall in taking a new name when she remarried, a change that upset Kathryn.

Even more petty was Steven's complaint that his mother forced him to wear a seatbelt when he was seven-years-old or she would call the police, and Kathryn's upset at her mother's refusal to take her to a car show. Both were also slighted by either no birthday or Christmas cards, or cards that were declared inappropriate and contained no cash or cheque for them.

One of the "inappropriate" cards from American Greetings showed a table full of red tomatoes with the centre tomato wearing googly eye glasses. The card read "Son I got you this birthday card because it's just like you...different from all the rest." On the inside Steven's mother wrote "Have a great day! Love and Hugs, Mom xoxoxox". How insensitive!

Not surprisingly, their litany of childish complaints impressed no one and simply confirmed their outrageous sense of entitlement, immaturity and lack of gratitude. Their father's role in their claims of "bad mothering" deserves even greater rebuke. His participation was both contemptible and shabby.

Needless to say, their lawsuit was thrown out of court, as it should have been.]]> tag:www.huffingtonpost.com,2011:/theblog//3.959393 2011-09-13T11:32:11-04:00 2011-11-13T05:12:02-05:00

Georgialee Lang http://www.huffingtonpost.com/georgialee-lang/
If you are involved in a so-called "amicable divorce," are there identifiable signs that signal your divorce may be meandering to the low-road? Of course, there are. Be aware of the following:

1. You Have a New Partner: Often amicable divorces remain that way until a husband begins a serious relationship with a new lady. One of the easiest ways to have your divorce come "off the rails" is to flaunt a new paramour before your wife is emotionally ready, which in some cases is never.

2. You Decide to Close the Credit Card Accounts: It is not uncommon for husbands to maintain the financial status quo until they realize their separated spouses' credit card spending is three times the pre-separation amount. Delicacy is required to rein in the spending, without ruining the convivial settlement discussions. A useful strategy is to terminate all major credit cards except one, which remains available to your spouse, albeit with a much lower credit facility. This can only be done with advance notice to your spouse.

3. You Take the Children on Vacation With Your New 'Friend': You have pleasant post-separation discussions and agree on summer vacation access with your kids, but fail to tell your wife you will be bringing along your 25-year-old significant other. Surprises are always dangerous. You are better off to advise your spouse in advance and find a compromise if she adamantly opposes the extra company. Perhaps the significant other only visits for a couple of nights or not at all?

4. Your Wife Finds Pre-Separation Jewellery Purchases She Knew Nothing About: The divorce process always involves the exchange of financial information, including credit card statements. If your wife finds purchases from Tiffany or Birk's, made before the separation and she is not the recipient, watch out. Still worse, are cancelled cheques on your joint account confirming you were paying your significant other's rent before you and your spouse separated.

5. You Were Sleeping With the Nanny in the Marital Bed: The marriage is now over but your wife learns from reliable sources that you were sleeping with the children's nanny during the marriage. This is a sure-fire way to generate anger and humiliation in your wife, something that usually gets in the way of future courteous communication.

6. The "Small" Mortgage on the Family Home Eats Up Half of the Home Equity: Your secret financial dealings during the marriage are now exposed and your wife is shocked to learn that what she thought was a $100,000 mortgage on the family residence is actually $250,000 as a result of undisclosed stock investments made with borrowed monies. It's even worse if the stock is now worth considerably less or nothing at all.

7. You Won't Give Up Custody of the Family Pet: You think everything is settled and leave the conversation about Muffy and Fido to the end, only to realize that neither of you will give up the family pet. Yes, judges now also decide who gets custody of the cat and dog, where the parties cannot agree. This issue can be a deal-breaker.

8. You Become an Absentee Parent: You tell your spouse you want to remain an active, involved parent, but your weekly visits are now monthly visits and you have failed to show up for some of your visits, leaving your children crying and your ex seething.

9. Your Spouse Makes it Difficult to See the Children: Parenting time starts off well but disintegrates when your spouse realizes her financial expectations are unrealistically inflated and she now needs leverage to obtain a better financial outcome. What better pawn than the children?

10. You Quit Your Job Before You Pay Spousal Support: You are usually a traditional husband who has no problem paying child support, but believes a 50-year-old wife who worked as a bank teller 20 years ago should immediately find full-time employment because the children are all in school. What else is she going to do all day?

Negotiating a reasonable divorce settlement can be a minefield if a spouse is not aware of the dangerous trigger points that invite hostility, embarrassment or distrust. A strategic family law lawyer is one who can assist you to manoeuvre the settlement terrain without stepping on a divorce landmine.
]]> tag:www.huffingtonpost.com,2011:/theblog//3.954867 2011-09-09T16:59:21-04:00 2011-11-09T05:12:02-05:00

Georgialee Lang http://www.huffingtonpost.com/georgialee-lang/
It is now commonplace to see self-represented litigants dueling with lawyers in most of our family courts in Canada. In British Columbia a parent or spouse can apply for custody and child and spousal support in the Provincial Court, which is purposely "user-friendly."

The Provincial Family Courts across Canada have successfully implemented reforms including plain-language court documents that are readily decipherable by lay litigants. The judges in Provincial Court are accustomed to hearing cases without lawyers and graciously assist those who act for themselves.

However, to obtain a divorce or property division, the only venue is each province's Supreme Court, sometimes called "Queen's Bench," a mostly inhospitable environment for in-person litigants.

As family law becomes increasingly more complicated, despite the Canadian government's sensible introduction of both Child Support Guidelines in 1997 and Spousal Support Advisory Guidelines in 2006, there are minefields enough for lawyers, never mind those who are forced to act as their own lawyer.

Will a lay litigant understand that in calculating their income for the payment of child support they must consider and understand complex nuances such as the possibility of the exclusion of non-recurring income; the need to include all of their capital gains income in their calculation, not just the portion they see on page two of their tax return; and their ability to deduct business expenses, union or professional dues and carrying costs? I doubt it. Not all lawyers have figured it out yet!

But affordability is not the only reason litigants refuse to retain counsel. There is another group of litigants who believe they can handle their divorce case just as well as a lawyer can. This smaller segment often become serial litigators who, because it costs them nothing, bring multiple frivolous applications, although some would say that lawyers do the same thing! Often when offered pro bono counsel, they decline.

Problems abound for all involved in the family justice system in the wake of the impact of lay litigants. Judges who must ensure that justice is done are at the centre of the dilemma. If they provide too much help for an in-person litigant, that litigant's spouse will see it as an unfair advantage and often the court rules that govern court procedures are less stringently enforced when it comes to litigants with no lawyer.

As well, litigants that pay for their own lawyer often become disenchanted with their counsel when they see their lawyer "helping" their estranged spouse who has no counsel. Lawyers are bound to treat participants in the justice system with courtesy and respect, traits that are frequently misconceived as their lawyer being "too friendly" with their opponent.

Fee-paying litigants resent their lawyer telling their spouse what the law is or how the court process works.

For lawyers the problems are multiplied. They must walk a fine line in dealing with an unrepresented spouse and must ensure that all communication with an in-person litigant is documented in writing, with no exceptions. Of course, their clients are even more unhappy since it is their clients who pay the bills for the extra time and effort required to work with a lay litigant.

Lay litigants have also been known to send abusive communication to their spouse's lawyer and from time to time, report their spouse's lawyer to the Law Society, a complaint which can cost a lawyer hours of wasted time to respond to the often ill-founded allegations.

Is there a cure? They say that recognizing a problem is the first step to solving it. Certainly,the issue can no longer be avoided. It has taken centre stage as a result of lawyers, judges, court administrators, law professors, lawmakers, and the Canadian public decrying the slow demise of Canada's family justice system.

]]> tag:www.huffingtonpost.com,2011:/theblog//3.932289 2011-08-22T15:19:26-04:00 2011-10-22T05:12:02-04:00

Georgialee Lang http://www.huffingtonpost.com/georgialee-lang/
Up until 2006 spousal support awards were notoriously inconsistent. The outcome of a spousal support case depended on what day it was heard, what judge heard the case, and who counsel were on the case. It was family law's crapshoot.

In 2006 Canada's Spousal Support Advisory Guidelines were released, after the federal government empowered leading family law professors Carol Rogerson and Rollie Thompson to analyze and assess the nuances of spousal support and provide recommendations and guidelines that would help lawyers and judges determine who was entitled to support, how much should be paid and for how long it should be paid.

Today these Guidelines have the force of law, even though our legislators have never passed the Guidelines into law.

A calculation of spousal support under the Guidelines is based on the payor's gross income (usually the husband) and the wife's gross income, including common law spouses in most provinces.

The general rule is that spouses who are entitled to support will receive it for a minimum of one half the length of the marriage and cohabitation and a maximum of all the years of the marriage or cohabitation.

So, if you were married or cohabited for 10 years, you would receive support for a minimum of five years and a maximum of 10 years. Herein lies one of the resolution dilemmas. Of course, husbands only want to pay for five years, while wives demand 10 years of support.

The reality is, however, that judges in Canada are reluctant to make support orders that terminate on a fixed date, and routinely order that spousal support be "reviewed," even though the Supreme Court of Canada in Leskun v. Leskun 2006 SCC 25 criticized the use of review orders.

A review of spousal support is an expensive court process that entitles the recipient spouse to take a second crack at an indefinite spousal support order, as entitlement to support, amount of support and duration of support, are all up for grabs again.

For marriages 20 years or more, support is paid indefinitely, subject to a "material change in circumstances," a legal test that rarely releases payor spouses from their support obligations.

Are Canadians supportive of the current alimony laws? While men's rights groups criticize laws they say are unfair or prejudicial to them, the groundswell for the reform of alimony laws that is emerging in the United States has not yet crossed the border into Canada.

Most noteworthy are the reforms passed by the State of Massachusetts last month in their new Alimony Reform Act of 2011, heralded as the end of lifetime alimony in that state. Should Canada's spousal support laws also be amended to promote independence after divorce and fairness for both spouses?

In Massachusetts' groundbreaking new law, the following reforms have been passed by the House and the Senate:

1. Spouses shall only receive support for 60 per cent of the number of months of marriage. In Canada a spouse will be supported for between 50 per cent and 100 per cent of the months of marriage or cohabitation with many support orders being of an indefinite duration.

2. For marriages between 10 and 15 years, the maximum term for support is 70 per cent of the months of marriage and for marriages between 15 years and 20 years, the maximum length for alimony is 80 per cent of the months of marriage. In Canada a marriage in excess of 20 years results in an "indefinite" award of support, a more polite term for "permanent" support.

3. A second wife's income and assets are excluded. Frequently Canadian courts allow evidence of a new partner's financial circumstances, particularly where the payor spouse's income has been reduced.

4. Cohabitation with a new partner for a continuous period of three months suspends, reduces or terminates alimony. In Canada cohabitation will only result in a change in support payment if the recipient spouse lives with a wealthy partner who fully supports him/her. Try proving that.

5. For the purposes of an alimony order, the court shall exclude from its income calculation gross income the court has already considered for setting a child support order. In Canada child support is calculated first, and the amount of child support ordered can result in a decreased amount of spousal support, subject to an increase when the child support has decreased or terminated.

6. Alimony should not exceed the recipient's need or 30 per cent to 35 per cent of the difference between the parties gross incomes. Canadian courts consider "need" but favour an equalization of income between spouses that reflects the marital standard of living.

7. A second job or overtime income shall be excluded from the income calculation where the spouse works more than a single full-time equivalent position or the second job or overtime commenced after the initial spousal support order. Canadian payors must pay support on all income, including, in some instances, pension income that has already been divided between the spouses.

8. A payor spouse's payment of health insurance or life insurance for a recipient spouse shall reduce the payor's support payments. These payments are rarely taken into account by Canadian courts.

9. Alimony extensions are limited and require clear and convincing evidence. Extensions of spousal support are the norm in Canada.

10. Alimony ends with the remarriage of the recipient. Not in Canada. A payor spouse has the onus of proving to the court that a recipient spouse no longer needs support.

Will there be a grassroots movement in Canada to rethink spousal support in light of the reforms south of the border? I think it's inevitable. Laws that are paternalistic and punitive have no place in modern Canadian society, however, stay-at-home moms must maintain their elevated position, even in the face of spousal support reforms.]]> tag:www.huffingtonpost.com,2011:/theblog//3.901194 2011-07-20T13:59:14-04:00 2011-09-19T05:12:02-04:00

Georgialee Lang http://www.huffingtonpost.com/georgialee-lang/
Many of them list a myriad of reasons why separating spouses should reject traditional family law lawyers in favour of collaborative lawyers. Very few of these sites discuss the downside or the disadvantages of collaborative family law. At least one site declares there are no disadvantages to collaborative divorce.

So, what is collaborative divorce and where did it come from? In 1990, lawyer Stuart Webb of Minnesota decried the emotional and financial devastation experienced by many of his family law clients. He wondered if divorce could be done in a kinder, gentler way and thought it could.

He devised a process where a divorcing couple would each retain a collaboratively trained lawyer and sign an agreement providing that each spouse would enter into interest-based negotiations with the assistance of their lawyers. Meetings would be scheduled where spouses and lawyers would discuss and settle all issues related to their divorce including property, custody, and child and spousal support.

To experienced family law lawyers there was nothing new about four-way settlement meetings. They had been the basis for settlement discussions for decades.

But the collaborative process introduced an additional feature. The agreement signed by the spouses and their lawyers stipulated if the collaborative process was not successful, their lawyers could no longer represent them and they would be compelled to "start over" with regular family law lawyers, otherwise known as litigators.

This "court is not an option" approach is a critical component of the process, expected to compel adversarial spouses to settle, rather than face the prospects of new lawyers armed for court battle.

It all sounds wonderful and for some divorcing couples it is effective. Whether it can be said to be less expensive is another issue, because the collaborative process also provides much-needed work for underemployed counsellors, child psychologists, domestic abuse specialists and financial experts, who are called upon to assist, for a fee.

It has also led to the growth of professionals who call themselves divorce coaches and parenting coordinators. With the addition of one or more of these "experts," one can easily imagine spiraling costs. In one case involving a short marriage with no children, a couple claimed that the collaborative process cost $55,000.

This is not intended as a criticism of divorce coaches or parenting coordinators, who can each play an important role, however, to suggest this parade of professionals comes cheap is disingenuous at best and outright misleading at worst.

On website www.collaborativedivorce.net, the authors point out, "No one should be in a hurry to reach issues quickly because of time constraints." This reminds me of the unspoken philosophy behind mediation, where couples could spend years with a mediator who was apparently skilled at bringing divorcing couples to "yes", but not in a timely fashion. In certain instances, couples could be done and divorced in court for the same price-tag as the marathon mediation.

This same website encourages collaborative participants to "control the meeting." This is a disturbing admonition for a process that is intended to promote fairness, cooperation and a level playing field.

But make no mistake. Despite what you may have heard, collaborative lawyers are still out to get the best deal they can for their clients. The "warm and fuzzy" marketing is merely a smokescreen.

In certain respects, collaborative divorce is a wolf in sheep's clothing where strategies usually reserved for "bulldogs" are implemented, including the dreaded "nothing is settled until everything is settled" and "We refuse to counter" mentalities, driving one party to negotiate against him or herself.

As for me, the jury is still out. Oh yes, I have always practiced family law collaboratively, I just didn't adopt the tag.]]> tag:www.huffingtonpost.com,2011:/theblog//3.893627 2011-07-19T09:16:12-04:00 2011-09-18T05:12:01-04:00

Georgialee Lang http://www.huffingtonpost.com/georgialee-lang/
Mr. Neumann was the President of Vantage Equipment Company Ltd., a company that bought and sold used mining and construction equipment. He had an office in Duncan, B.C. and a home office.

One of Vantage's associates was Ms. B., who was being investigated by CRA for tax evasion. Taxation investigators learned through a routine audit of Vantage that Mr. Neumann's company had paid commissions of $400,000 to Ms. B. A criminal investigation was also instigated.

Mr. Neumann alleged he suffered post-traumatic stress disorder and depression as a result of CRA's search and seizure of documents from his home. In a jury trial, Neumann made claims for unreasonable search and seizure pursuant to Canada's Charter of Rights and Freedoms and "negligent investigation" by CRA -- a novel action that relied on a 2007 Supreme Court of Canada case, where it was decided that a botched police investigation may give rise to a negligence claim on behalf of a suspect wrongly convicted of a crime.

Psychiatrist Dr. Shabehram Lohrasbe testified that Neumann's stress disorder and depression were legitimate and caused Mr. Neumann's life and business to suffer. He also opined that Neumann's childhood in communist Germany and his escape to West Germany at the age of four compounded his fear and contributed to his mental impairment.

The jury hearing Mr. Neumann's case awarded him damages of $1.3 million -- an extraordinary verdict against CRA. However, in Reasons for Judgment released July 6 (Neumann v. Canada 2011 BCCA 313) by British Columbia's Court of Appeal, Mr. Neumann lost his case and the money.

A unanimous Court granted CRA's appeal and dismissed Mr. Neumann's actions. The Appeal Court considered whether CRA was under a duty to Mr. Neumann to carry out the least intrusive search that was possible in the circumstances.

Neumann's lawyer argued that CRA ought first to have approached Mr. Neumann for a voluntary release of the documents they needed to prove tax evasion and fraud against Ms. B. CRA explained that given the volume of business between Mr. Neumann and Ms. B., they could not take the chance that their business relationship would not cause Mr. Neumann to take steps to protect Ms. B.

Neumann's lawyer also complained that in obtaining the search warrant, CRA failed to advise the judge who granted the warrant that Vantage's place of business was Mr. Neumann's home and that Neumann had fully cooperated in the earlier audit of Vantage, which constituted "material non-disclosure."

CRA investigator George Hodgson testified that he was not aware that Vantage's office was in Neumann's home and the Court of Appeal noted that at trial, Neumann's lawyer advised the trial judge his client was not challenging the validity of the warrant.

The Appeal Court ruled there was no evidence of negligence in respect to the search warrant and no breach of the Charter. However, CRA was not awarded costs against Mr. Neumann, the court finding that in hindsight, Crown lawyers ought to have asked the trial judge to dismiss the lawsuit before beginning the defence case.

A very sensible outcome and perhaps yet another example of jury bewilderment.]]> tag:www.huffingtonpost.com,2011:/theblog//3.891556 2011-07-06T15:34:57-04:00 2011-09-05T05:12:01-04:00

Georgialee Lang http://www.huffingtonpost.com/georgialee-lang/
The unsavoury events leading to the inquiry unraveled last fall when Douglas, the Associate Chief Justice of the Manitoba Court of Queen's Bench, Family Division, stepped down from her post while the Canadian Judicial Council investigated a complaint filed against her involving her husband, prominent family law lawyer Jack King. The complainant was Alexander Chapman, age 45, originally from Trinidad, who retained Mr. King to act for him in his divorce proceedings in 2002.

At the time, Ms. Douglas and Mr. King were partners at a prestigious Winnipeg law firm. Mr. Chapman alleged that after Mr. King completed his divorce, King befriended him and tried to persuade Mr. Chapman to engage in a sexual tryst with his wife, Ms. Douglas.

Mr. King gave Mr. Chapman photographs of his wife and a password to a website that caters to those who have an interest in interracial sex. The photos of Douglas portrayed her as nude, except for bondage regalia, and participating in a sex act.

When Mr. Chapman complained to Mr. King's law firm, King paid Mr. Chapman $25,000 in exchange for Chapman's agreement to not sue him or the firm and to destroy the photos.

Jack King resigned from the firm after the payment was made.

Fast forward to September 2010 when Mr. Chapman reneged on the 2003 agreement and sued lawyer King, Justice Douglas and King's law firm, Thompson Dorfman Sweatman LLP, for sexual harassment, negligence and intentional infliction of emotional distress, seeking $67 million dollars.

Chapman had not, in fact, destroyed the photos and gave some of them to CBC TV and the Manitoba Law Society. The CBC declined to publish them.

In response, Mr. King brought an application to the court to dismiss Mr. Chapman's lawsuit on two grounds: that Chapman had signed an agreement in 2003 giving up his right to sue and that Chapman had waited too long (seven years) to bring his claim.

The Court agreed with Mr. King and threw out Chapman's case. Earlier, Mr. Chapman had abandoned the lawsuits against Justice Douglas and Mr. King's former law firm. The Court also ordered that Chapman cease any further dissemination of the photos, however, earlier this year, the website abovethelaw.com published the salacious photos (they have since been taken down and replaced with written descriptions of the images).

Mr. King's lawyer explained that Mr. King posted the photos on the internet without his wife's knowledge and consent while he was suffering from depression. King also admitted to arranging what Chapman referred to as a "first date" with Ms. Douglas: an invitation to join King and his wife on a vacation in Cancun in 2002. Chapman declined the offer.

In April 2011, Mr. King plead guilty to sexual harassment for cajoling his former client to have sex with his wife. Typically, a Law Society disciplinary hearing for sexual harassment will lead to a suspension of a lawyer's license to practice law, however, in Mr. King's case, he received a reprimand and costs of $13,650.00.

Mr. Chapman's life has also been difficult, post-lawsuit. He was fired from Great West Life Insurance where he worked as a computer programmer. He has also had difficulty finding a lawyer to assist him with his case; Chapman is no stranger to the courts, however. He has been convicted for arson, theft, and uttering death threats. He has also been a party in nine other lawsuits including one action that he brought against the Winnipeg Police Department.

In the meantime, the Winnipeg Free Press challenged the Law Society to disclose what they knew in 2003 and what steps they took then to protect the public. A spokesperson for the Law Society revealed they were aware of Mr. King's conduct, but did nothing because King was not practicing law at the time of their investigation.

Mr. Chapman discredits any alleged Law Society investigation of Jack King, citing the fact that neither he nor the lawyer who negotiated the 2003 agreement between him, King and his law firm were ever interviewed.

Pubic inquires into judicial complaints are a rare event in Canada and are ordered when the complaint against a judge is serious enough to warrant a judge's removal from office. The inquiry results are then forwarded to the Minister of Justice who, in accordance with Canada's Constitution can only be removed after a joint address by Parliament.

Does Judge Douglas' private life render her unfit to continue as a judge or is she a victim of her husband's breach of her privacy? Is it appropriate for the Judicial Council to scrutinize a judge's morality?

In my view, it will be very difficult for Madam Justice Douglas to return to her court duties. Respect for the court and its judicial officers is a cornerstone of Canadian justice. Snickers and snide remarks can only undermine her judicial authority.]]> tag:www.huffingtonpost.com,2011:/theblog//3.879851 2011-07-01T18:15:58-04:00 2011-08-31T05:12:01-04:00

Georgialee Lang http://www.huffingtonpost.com/georgialee-lang/ landmark B.C. Supreme Court decision, (Pratten v. British Columbia 2011 BCSC (656)) which banned the practice of anonymous sperm donation, a first in North America.

Putative sperm donors have had it rough since 2004 when Canada's Assisted Human Reproductive Act made it illegal to pay for sperm. The obvious question was "why would anyone bother to donate sperm if they get nothing in return?"

The answer came quickly. They won't, and the immediate fall-out was the closure of 40 Canadian sperm banks, leaving only the Toronto Institute for Reproductive Medicine.

Active sperm donors in Canada today number 35, driving Canadian families to look to American sperm banks, where donors are still paid.

Eliminating anonymity for sperm donors may be the death knell for British Columbian donors and the possibility this new law will be adopted throughout Canada is far from remote, since the basis for the decision was that adopted children have the right to obtain information about their biological parents, but children born of artificial insemination do not. The court found the distinction was discriminatory and unconstitutional.

The court's decision in Pratten v. British Columbia refocuses the attention away from the rights of parents to avail themselves of reproductive technology, without consideration of the consequences for their offspring, to the recognition that children, whose biological fathers are sperm donors, must now take centre stage.

In her reasons, Honourable Madam Justice Elaine Adair referred to the ultimate control given to parents of donor offspring to decide what their child should know, when they should know about it and who might be involved in their child's life.

She noted that while anonymity may suit parents and donor, the evidence showed that these children suffer significant psychological and psychosocial difficulties brought on by health concerns, the lack of personal identity, and a sense of loss and incompleteness.

Plaintiff Olivia Pratten, a 29-year-old journalist from Toronto, asked the court for a declaration that certain sections of B.C.'s Adoption Act be of no force or effect and the disposal or destruction of sperm donor records in British Columbia be immediately prohibited.

Justice Adair granted the orders sought by Ms. Pratten, however, it was a bittersweet victory, since the doctor who had performed artificial insemination for her mother in 1982 had already destroyed his records in accordance with the law at the time.

As well, the court suspended the declaration for 15 months in order to allow time for B. C. lawmakers to revise the Adoption Act to address the discriminatory provisions and align new legislation with the court's Reasons.

Recently, the B.C. government announced it will appeal the ruling.

Donor insemination has come a long way since 1954 when the Supreme Court of Cook County in the United States ruled it was contrary to good morals and constituted adulterous behavior, while the Archbishop of Canterbury and the Pope proposed it be a criminal offence.

Today it is widely accepted and almost fashionable, as Hollywood's female celebrities become single moms and the movie studios churn out sperm donor genre movies.]]> tag:www.huffingtonpost.com,2011:/theblog//3.884651 2011-06-29T09:02:57-04:00 2011-08-29T05:12:01-04:00

Georgialee Lang http://www.huffingtonpost.com/georgialee-lang/
With nearly 40 per cent of Canadian marriages ending in divorce, our next government needs to stop the bleeding, financial and emotional.

Our adversarial court system pits husband against wife in a dangerous game that all too often spirals out of control, taking whole families down and destroying children's lives in the process.

Custody cases are among the worst. Separating parents, usually fathers, are caught in a black vortex, fighting for the ability to remain an active part of their children's lives, sparring with mothers who too frequently use their hurt and anger to alienate their partners from their children.

To date, our governments have refused to make the changes that many jurisdictions in North America have already adopted: a move to a presumption of joint custody, in which parents continue to participate in their children's lives on a level playing field. With a rebuttable presumption of joint custody as the law of the land, a significant group of potential family law litigants could bypass the court system.

Regrettably, our system does neither parent any favours. With lawyer's fees in the tens of thousands of dollars, many Canadians wander alone into family court like sheep to the slaughter.

Legal aid for family law in Canada is almost non-existent, while refugees and criminal thugs, even terrorists, feast from the public purse.

What Canadians face is a shortage of judges and court staff, who gamely try to administer an underfunded bureaucracy that cannot meet their needs, and a process where the battle lines are drawn before they get there -- the beginning of their long wait for justice.

Legislators, law reformers, judges and lawyers have long recognized that court is no place to resolve family law disputes. Ontario's Law Commission released a report last September entitled "Voices From a Broken Family Law Justice System" decrying longer trials and increasing court and legal fees that are crippling a system that cannot deal with the intense emotional fallout of personal disputes.

In a recent family law case, Bruni v. Bruni 2010 ONSC 6568, Mr. Justice Joseph Quinn of Ontario began his reasons for judgment with a feigned cry for help -- "Paging Dr. Freud, Paging Dr. Freud" -- a provocative introduction to a bizarre family law case that was ill-suited for court intervention. Justice Quinn referred to the "roulette of family law."

The case took seven days of court time over a period of several months; not unusual since judges are routinely overbooked. Much of the evidence had nothing to do with the two legal issues: a claim to set aside a separation agreement and an allegation that Ms. Bruni had alienated the children from their father. The level of vitriol stunned Justice Quinn, who refused to set aside the agreement and admonished the parties for their childish behaviour. Justice Quinn took the brave step of denying Ms. Bruni spousal support as a rebuke for the wedge she had driven between the children and their father.

My solution? Take family law out of court and move it to Family Centres with a one-stop shopping approach. Provide education, counsellors, child-development professionals, mediators, arbitrators, divorce coaches, parenting coordinators and financial experts. These services should not be free, but should be paid for by those who access the programs on a sliding scale commensurate with their family income. For the poor and working poor, legal aid should be provided.

For those cases that will never settle without judicial intervention, appoint highly experienced judges who want to be there, as opposed to judges who find family law work a grind they would rather avoid.

Canadians deserve better. As it is, they leave court emotionally battered and bruised, and eventually broke.]]> tag:www.huffingtonpost.com,2011:/theblog//3.883645 2011-06-24T14:58:46-04:00 2011-08-24T05:12:01-04:00

Georgialee Lang http://www.huffingtonpost.com/georgialee-lang/
Iranian-born, American billionaire Patricia Kluge hit the jackpot when she married self-made television mogul John Kluge in 1982. Mr. Kluge sold his company, Metromedia, to 20th Century Fox in 1986, which eventually was taken over by media genius Rupert Murdoch and became the foundation for his Fox network, "We Report, You Decide". Mr. Kluge was paid $4 billion and that year was named America's richest man with a net worth of over $5 billion.

John Kluge was Patricia's second husband. She had a first marriage to Brit Russell Gay, who turned her into a soft porn star, by featuring her in his British men's magazine "Knave".

The Kluge's lifestyle was opulent and Mrs. Kluge wore the mantle of socialite diva well. For her 40th birthday, she invited 400 guests, including Frank Sinatra, to New York's Waldorf-Astoria Hotel for a frolic that cost $1 million.

Unfortunately, the Kluge marriage only lasted eight years, but Patricia Kluge was amply rewarded. It was reported she left the marriage with assets, including cash and real estate valued at $1 billion. At the time, it set the record for the largest divorce settlement and remained so until the divorce of Rupert Murdoch and his wife.

She married her third husband, Bill Moses, in 2001 and shortly afterwards invested $27 million to develop an exclusive winery in Virgina. The winery met with critical acclaim and Kluge wines were poured at upscale celebrations including Chelsea Clinton's wedding reception.

With such initial success, Patricia and her husband borrowed $68 million to upgrade and expand the winery, which sat on over 900 prime acres. Part of the expansion included the development of an enclave of multi-million dollar homes, suitable for the rich and famous.

Unfortunately, the recession of 2008 spoiled Mrs. Kluge's grandiose plans and she found herself in financial difficulty. In an attempt to salvage her situation, she began selling off her valuable collection of objet d'arts, including a Qing dynasty clock for $3.8 million. She later unloaded her Roman statues, Chippendale commode and her George III crystal chandelier at a two-day Sotheby's auction. But with $69 million in bank debt, it still wasn't enough.

Finally, in 2009 Patricia listed her Virginia home for sale at $100 million, a 45-room mansion with all the amenities one would expect, including a helijet pad, wine cellar, steam room, 13 bathrooms and expansive grounds and gardens. Patricia and her mansion had attracted leaders in politics, business and entertainment, who were feted with elaborate parties in their honour.

But there were no takers and the mansion was sold in foreclosure proceedings to the Bank of America for $15 million measly dollars. Friend Donald Trump acquired the Kluge winery for about $5 million after the bank foreclosed.

Patricia Kluge's fall from grace culminated in her recent bankruptcy filing where she disclosed debts between $10 million and $50 million and assets valued at $1 to $10 million.

The good news is that Mrs. Kluge and her third husband have been offered jobs by Donald Trump. No, not on The Apprentice, but working at the Kluge winery.

Easy come, easy go.
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