#number 1 julie stan confirmed :)

[heejinkwan]

FALLEN ANGEL is the second mini album by ASTELLA, a South Korean soloist. It was released on February 23, 2024 by StarShip Entertainment. The album consists of seven tracks, one including title track NOBODY KNOWS. It is available both physically and digitally.

ASTELLA promoted the album for 4 weeks total, promoting NOBDODY KNOWS and b-side MANIAC for 2 weeks each. NOBODY KNOWS peaked at 2 on the gaon charts while MANIAC peaked at 11. although unpromoted, Kingdom Come and Lucid Dream also charted, peaking at 19 and 25 the week after the album's release. The album received global attention as well, peaking at 10 on the US Billboard 200, also charting in 20 other countries including Japan, Brazil, FinLand, Thailand, and the UK. ASTELLA won a total of 9 music show awards for this album, NOBDOY KNOWS winning 7 with MANIAC earning 3.

˚୨୧⋆｡˚ ⋆ i. the tracklist !

i. ✭ .   nobody knows ( title track )

ii. ✭ . maniac

iii. ✭ . rewind

iv. ✭ . lucid dream

v. ✭ . kingdom come

vi. ✭ . automatic

vii. ✭ . thirsty

˚₊· ͟͟͞͞➳❥ get your photocards here !

*ੈ♡⸝⸝ ii. the styling !

⋆.ೃ࿔*:･ iii. the reception !

✩₊˚.⋆☾⋆⁺₊✧ iv. the notes !

₊˚ෆ the concept of this album was basically an omen to her performance on fictitouscore, her being a fallen angel, like the title of the album says.

₊˚ෆ the album was automatically a banger, earning a 7.2 score on pitchfork, astella garnered many new fans off of the release of nobody knows itself.

₊˚ෆ a lot of stellars believe that they should’ve made kingdom come be the title track, seeing that it’s gone so viral, but others understand why nobody knows was chosen for the title track.

₊˚ෆ astella blew up on tik tok! people already saying that nobody knows is soty and that it was the best release so far!

₊˚ෆ she did many challenges with julie and hanuel of kiss of life, karina of aespa, joy of red velvet, and yeji of itzy.

₊˚ෆ she made many new friends including yeji, who she met from being friends with karina.

₊˚ෆ and all the rumors are true! the album may or may not be about yeonjun, who she has been rumored to be dating ever since 2020 west they had a minor acquaintance.

₊˚ෆ she began being close to him while being in promise, but after leaving he was one of the only people she talked to all the time, the rest being her family, the promise members, and karina.

₊˚ෆ they began officially dating in 2022 but never actually confirms it so nobody knows is like her saying it but not actually saying it.

₊˚ෆ when it peaked number two on billboard, heejin’s family called her and they celebrated with a cake, congratulating her on her success.

₊˚ෆ she literally did a live at like 1am happy, which turned into her crying because of how overwhelmed and happy she was that the song was doing well, the comments were congratulating her and telling her not to cry.

₊˚ෆ during maniac promotions, a lot of people felt like the song did not fit the album and complained that it was being promoted and not kingdom come, which was gaining more streams than maniac.

₊˚ෆ starship released two videos of the recording process of both nobody knows and maniac, which gained so much traction on twitter and tik tok with videos with over 1m+ likes and views.

₊˚ෆ even though she hadn’t planned it, heejin ended up finding out that she will be performing at coachella 2024 in california alongside other kpop artists such as lesserafim and ateez.

₊˚ෆ even though no one expected it, rewind also ended up getting popular! after many stellars posted the song in a sped up version, making people who did even stan heejin wonder what the song was, it even got non kpop fans bopping to it!

₊˚ෆ after catching onto it, heejjn ended up posting a lyric video of rewind on her channel, and after a week it charted at number 8 on top 100: south korea on apple music, youtube music charts at number 1, and gaon chart at number 5.

₊˚ෆ stellars can really say this is their favorite era of astella so far, when the music is good how can you not stan?

₊˚ෆ very much inspired by this by @dr3amluc1d

[themightyducks]

'#charlie is julie's favorite change my mind!' Tell me more 👀

oh GOD please get ready for some rambling because i love these two so much and i love them even more together. i mean, this is 99.9% headcanons but i honest to god believe these two are the most underrated charlie friend/relationship because they didn’t get any kind of focus but if you look closely you can see they’re extremely comfortable around each other. 

with of course the most obvious example being that charlie is the first person (out of the OG ducks) we see julie be chill with after the OG/new ducks got into that fight. this kind of parallels charlie with adam and fulton (being the first to welcome adam & the first to interact/become ducks with fulton), although in a much more subtle way considering this happened in the background.

throughout d2 and when they’re off the ice, julie either sticks close to the new ducks (which makes sense, because i imagine they became close even prior to meeting the OG ducks because they’re the newbies) or adam or charlie. she has interactions with goldberg, but those typically happen on the ice and she doesn’t seem to care much for him off of it. i think we see her with connie a total of two times (which is a waste, there should’ve been more julie/connie). 

but charlie? dude, they’re together 80% of the time in d2 (when julie has screentime). seeing as i’m someone who gravitates to the people i’m closest to whenever i’m in a group, i do think this meant they were close. some examples: when they arrive at the good will games he walks closer to her, they’re next to each other at the presscon (and when they meet coach stansson charlie immediately turns to her & later they have a conversation with kenny about it), they sit near each other in class, they’re together before and after the match against russ and his friends & they walk into the rink together during their time off.

when julie finally gets her moment to shine, we see the ducks watching her with a focus on charlie, bombay and ms mckay. when they win the good will games, charlie is somehow the first one to arrive and they actually reach out for each other (and these two things are very similar to two charlie/adam interactions that i love). 

the trend of them sticking together actually continues in d3: they’re side by side at the rink, they walk out of class together, she gets close to him when they mess with varsity, she walks up to stand behind him when they get the word they might lose their scholarship, she’s right behind/next him when they talk to varsity after the hearing.

(i don’t really factor in interactions when the ducks are on the bench during the game because they hug/celebrate with everyone that’s near them. LIKE! everyone adores everyone on this team and i love that. but you also see charlie/julie near each other during the beginning/intermission a lot too. this one in particular is cute because they were talking/grinning at each other.)

then of course we have their actual d3 interactions. julie catching charlie when he’s checked into the boards; they’re in a tight spot because varsity is kicking their asses and she tells him to try the triple deke, which he does. this shows that she has faith in his abilities to change the tide and that he trusts that faith in him to immediately take up her suggestion. later, against their 2nd match against varsity, they’re in a tight spot again because julie is saving shot after shot and varsity keeps charging. charlie realizes she needs a time out and ices the puck (which is technically a foul...) and he then goes back to her and tells her “way to hang tough” to let her know she’s doing great.

i just think these two have an understanding where they trust and believe in each other, they’re comfortable enough to get in each other’s space and they look to each other for moral support, and that’s whyyyyy i believe charlie is julie’s favorite because i haven't seen her show this level of trust/comfort with anyone else (except connie in d3, who is clearly her best girl).

but i mean, whether that’s actually the case... man, who knows. julie got 5 minutes of screentime and i like to talk out of my ass. i also headcanon that julie’s tight with adam but their lack of interaction in d3 and the way she iced his clothes without remorse because he’s with varsity made it kind of clear that they weren’t that close lmao (but you know who else is that petty? charlie. ha ha!)  

[charsfx]

Lance’s long lost daughter headcanon - Adeleide Danuluk

This was supposed to come out in December 2020, but instead, it’s coming out in May 2021. Before you get into the headcanon, I’ll give a refresher because its been so long. Another OC of mine is Adeleide who is Lance’s daughter that he had no prior knowledge of. She was introduced in a comic called “Cynthia and the Indigo Plateau” last year, but I gave up on the comic, because a 10 page comic would have turned into a 50 page comic and I don’t do any comics past 25 pages anymore. So like Ross and Bertha, I’m introducing her through a headcanon. She did make an appearance in Lance’s 41st birthday, just to remind you that she exists. There will also be pictures in here that some of you have seen in the comic before. So without further ado, here is her headcanon. I’m not much of a lengthy writer, so sorry if there are grammatical errors.

ADELEIDE PAST:

Adeleide was born in Blackthorn City, Johto in 2002. She is the daughter and love child of Lance Blackthorn (father) and Amelia Danuluk (mother). Her mother and father were in a casual relationship for a year back in 2001; but unfortunately, her parents broke up, and Adeleide was born without her father’s knowledge. She continued living in Blackthorn under her mother’s maiden name. Her mother also made the decision to stay as a single parent for the rest of her life.

Like everyone else in Blackthorn, Adeleide had a love for dragon Pokemon; and after years of taking the family Altaria to the Pokevet so often, the girl wanted to be a Pokevet.

Adeleide enjoyed (and still does) watching Pokemon battles on the television. She was (and still is) a big fan of Lance Blackthorn and wished to watch him battle live and meet him one day. She liked the man, because not only was he from Blackthorn, but he was a dragon specialist. She owned some of his merchandise, and wanted the same Pokemon as him too.

At the age of fourteen, Adeleide was starting to notice the littlest of the things. Every time Lance appeared on the TV screen, her mother always gave a bitter look. She then began to wonder if her mother had some sort of past with the dragon master. Obsessed with her mother’s reactions towards Lance, Adeleide started looking at the man a little closer, and could see physical resemblances. She told herself that it could just be a coincidence, but she had to be sure.  She then approached her mother about her suspicions, but was immediately told never to bring the subject up again until she was eighteen.

On the day Adeleide turned eighteen, she approached her mother again on the Lance issue, and as promised, her mother spilled everything. Of course Adeleide was upset; she could’ve had a father in her life somehow, but that was taken away from her. Her mother - however - gave the excuse that Lance had a future and she didn’t want to burden him with a baby, as he was rising through the ranks towards success and fame at that time.

Shortly after she was told the truth, Adeleide was able to get Lance’s phone number from her mother. After what Lance thought was a weird fan interaction, Adeleide told Lance who she really was. Of course there was scepticism on Lance’s end, but her mother immediately talked to him and confirmed that Adeleide’s words were true and that he’d fathered a child when they were both 22; she even offered that if he was still unsure that he could take a paternity test.

ADELEIDE AND LANCE’S WEEK TOGETHER IN JULY 2020:

Lance and Adeleide talked a few more times on the phone before Adeleide finally found the courage to ask the champion if she could meet him in person. Unfortunately, she knew through the hesitation in his voice, that he didn’t want the same, but knowing how to get what she wanted, Lance eventually gave in and they agreed on spending a week together in Blackthorn. After their week, they would both decide on whether or not they should pursue a father-daughter relationship, or go their separate ways and pretend that nothing had ever happened.

Before Adeleide met her biological father, she studied hard on what father’s are and what their responsibilities were when it came to their children; however, she took a lot of her research too literally.

Day 1:

Lance had met up with Adeleide right off the train in Blackthorn and told her immediately that if she blamed him for his absence that he would leave, but she assured him that she had known the truth for a while and thought nothing of that sort.

They went shopping later and Lance’s wallet paid the price. According to Adeleide, “Father’s are supposed to pay for everything,” so he bought her new clothes, shoes and makeup. That’s when he found out that she was a manipulative, spoiled brat. In her life, she had gotten everything she ever wanted, and expected the same from everyone else; and what Adeleide wanted now was to have a father in her life, and she was going to do everything in her power to get that.

Day 2:

On their second day together, Adeleide and Lance decided to bake all day together. Adeleide was having the time of her life, but she soon noticed that Lance looked like he wasn’t having any fun at all. She tried to create some fun by beginning a food fight, but Lance was having none of it. After subtly displaying her disappointment, Lance felt bad and he had his revenge by resuming the food fight.

After their food fight, they sort of bonded by telling each other who they were and their likes and dislikes. Adeleide then got a stomach ache later from all of the cookie dough she had eaten and went home to rest for the remainder of the day.

Day 3:

On day three, Lance and Adeleide went out for ice cream. Seeing that Lance had that uncomfortable look on his face again, Adeleide asked him if he wanted to go back to the Indigo Plateau. He was obviously uncertain and uncomfortable talking to her and being in her presence, so why should she force him to stay? Fortunately for her, Lance insisted on staying and trying to be a good dad. He opened up and said that he was only uncomfortable because he couldn’t find a connection between them. There was nothing they could really bond about. He was trying to be a dad to an adult; a person who could already take care of themselves and make their own decisions. It would be a lot easier if she were a small child.

After hearing that, Adeleide then tried finding that connection through their love of dragon pokemon. She proudly displayed her dragonite and swablu, and Lance was speechless. She then demanded a battle, and he obliged without hesitation.

Lance won with ease; he thought he’d teach her a little bit of humility.

Day 4,5 and 6

On those days they mostly talked. They would get a coffee, walk around town and maybe see a movie, but for the most part, they just talked. They talked about their pasts, their personalities, their pokemon, their careers and their futures. He even gave her a tour around Blackthorn estate and took her to her grandparent’s graves, where he would tell endless stories about them.

It wasn’t until Day 6 when Lance and Adeleide finally found that connection, and began having deep conversations that they would keep to themselves.

Day 7

On their last day, they discussed how they wanted to move forwards. Should they part ways and never see each other again? Or should they pursue a father-daughter relationship that needed a lot of work. After some thorough discussion, and confirming that Adeleide wanted nothing to do with the Blackthorn name, they decided to pursue the relationship by writing to each other often and seeing each other when each of them had some spare time. They knew that they wouldn’t be close, but it would get better. Afterwords, they said their temporary goodbyes and parted ways.

ADELEIDE PRESENT:

Currently, Adeleide is nineteen years of age, is still a spoiled brat, and is attending university in Sinnoh where she is studying to become a Pokevet that specialises in dragon Pokemon.

Her and Lance still write to each other and visit when they can. They're not particularly close, but they know they’ll get there eventually.

She has a fiance now and often makes the joke with Lance that she’ll be giving him a grandchild for him to babysit sometime this year. She also stans her father together with Cynthia and hopes he gives her a brother or sister one day.

That’s it! Sorry her headcanon came out so late!! Currently in my AU Lance and Adeleide had kept in contact since last July, so this headcanon was just put to the side for so long and I had to get this out before father’s day haha.

[montagnarde1793]

Ribbons of Scarlet: A predictably terrible novel on the French Revolution (part 2)

In case you were wondering, that’s not actually the novel’s subtitle, which is really “A Novel of the French Revolution’s Women.” But like, only the famous ones. Ok, I’m done. Moving on...

Parts 1, 3, 4 and 5.

Structural Issues

 While the choice of characters was a red flag for me (and not in a good way), choosing to structure the book the way they did was a mistake.

 This is true for a number of reasons. (I’m sorry, btw, for all the comparisons to Marge Piercy’s novel, but the shared conceit kind of made it inevitable.) Piercy’s characters also only got an average of 80 pages each (though as the typeset was denser, they arguably had a little bit more space), but since the POVs were interspersed, they played off each other much more naturally and allowed the characters the time to develop. Even there it could feel underdeveloped, but here it seems like they’re rushing the undeserved character development so they have some kind of complete arc for each character before the next part starts.

Some chapters are clumsier at this than others. The absolute worst is Pauline Léon’s, which is unsurprising for a number of reasons, but notably because she has the fewest pages of anyone except Charlotte Corday, who doesn’t really get an arc: she shows up in the plot already wanting to assassinate Marat; she succeeds; she doesn’t regret her decision; she’s tried and executed. That’s it.

 This choice also means that the main strength of this type of anthology goes largely untapped: namely, that we get different POVs on the same events. Since each protagonist is associated with a different period in time, we can only ever get their point of view on previous events through awkward flashbacks.

 It probably also accounts for one of the worst, most artificial and amateurish aspects of the book: the way in any given section the other six point of view characters are shoehorned into the narrative, whether it makes any sense or not. The protagonists of the different sections have to have some (highly improbable) relationship with one another or be reflecting on each other’s lives in the most ham-fisted, author-soapbox way possible. We’ll circle back to that last part in a bit.

 Possibly the most ludicrous example of this is Manon Roland’s inexplicable decision to take a random trip to Caen in mid to late August 1792 just so the author can have her run into Charlotte Corday. Like, do I even need to explain how little sense this makes? Apparently so. Look, first of all, going from Paris to Caen was not a trivial trip in the 18th century. Today you could make a day-trip of it and not be missed. It’s about 2 hours each way in the TGV. But in the 18th century, you’re looking at more like 2 days each way, minimum. Not the sort of trip you tend to make without an ostensible reason. Does Manon Roland have one, even as written? No, she does not. She’s going to Caen to flee the temptation of François Buzot’s advances. Which, ok, internal motivation for leaving Paris, but they don’t bother to give her a pretext. How is she going to explain to her husband her random absence of at least 4 days (not to mention the expense)? And why Caen (other than the external reason of the author’s wanting her to come across Corday)? She has no connections there. Does the author even know that the main person Manon Roland knows from the region is Buzot and that it’s therefore the last place she should flee to stop thinking about him? And she’s supposed to be a savvy politician: does she not care about the optics, as the interim Minister of the Interior’s wife, of fleeing in the opposite direction as the Austro-Prussian troops are advancing on Paris?

 And I know what you’re thinking: I’m overthinking this. This wasn’t a book designed for specialists. But I think a reader can tell when a world they’re reading about doesn’t feel fully fleshed-out. In that sense, it’s less about accuracy than it is about how flat and artificial a reading experience it makes for. One of the most valuable things I was taught in school was that when making a presentation, you should always know more than you intend to say. I think the same goes for fiction: you should know more about the setting and the characters than appears on the page. In this book I consistently have the impression that the authors know less.

 Moreover, the authors claim to have been striving for maximum consolidation of characters in order to reduce confusion, but it ends up coming across as both artificial and condescending. Trust your readers to be smart enough to work through their confusion. Otherwise you make it feel like there were a total of about 20 people in Paris during the Revolution, which, again, makes the setting feel completely artificial.

 While I’m not sure anything but better research and writing could have salvaged it, this book would have already been 1000% better if the characters met or thought about each other only when it would actually make sense for them to do so and the narratives were interwoven.

  The Authors are Desperate to Make Sure You Feel the Way They Want You to about Key Figures. They Also Think You’re Stupid

 Don’t get me wrong. I’m not accusing them of supposing their readers to be ignorant about the French Revolution. You should always assume your reader to be ignorant of what you’re going to tell them. Ignorant, but intelligent. That’s the key. The problem is that the authors don’t trust their audience.

 So we also get characters doing things like giving you a who’s who of the most famous (and only the most famous) authors, artists and activists of the time whether it makes sense for them to do so or not, like this is a textbook and we’ve got to make sure the reader is informed of the existence of all these figures (or maybe give them the chance to pat themselves on the back if they’ve already heard of some of them).

 Or my least favorite French Revolution trope: having Robespierre ominously show up in 1789 to start plotting the “Terror” (here they have him spouting the apocryphal* quote “pity is treason” to an audience of Sophie de Grouchy, Condorcet and the Sainte-Amaranthe family sometime in May or June 1789) (p. 89).

 *Presumably, it’s a corruption of declarations such as the one in his 5 November 1789 response to Louvet’s denunciation that “La sensibilité qui gémit presque exclusivement pour les ennemis de la liberté m’est suspecte.” (“I find the sensitivity that groans almost exclusively for the enemies of liberty suspect.”) or the one in his second speech on the judgment of Louis XVI of 28 December 1792: “la sensibilité qui sacrifie l’innocence au crime est une sensibilité cruelle ; la clémence qui compose avec la tyrannie est barbare” (“sensitivity that sacrifices innocence to crime is a cruel sensivity; clemency that compromises with tyranny is barbaric”).

 Again, we see the same need for oversimplification. Robespierre is, as one of the authors’ notes puts it, one of the “dangerous men” (back matter, p. 18) that should have been prevented from ever having power so he’s not allowed to ever do or say anything sympathetic. (And yeah, I know, death of the author and all that, I shouldn’t count the authors’ notes, but they really only serve as explicit confirmation of what could be pretty transparently inferred from the text and this way no one can accuse me of reading things into it that aren’t there.)

Because of this, even real quotes are cited out of context to the same end: when Robespierre says “pity is treason” in 1789, Condorcet says his bit from the Chronique de Paris article from April 1792 to his wife — you know the one, about Robespierre’s being admired by women because he’s basically a cult leader (p. 90). There’s no reason to think Condorcet had any particular enmity toward Robespierre (or even that Robespierre would have been on his radar) just after the opening of the Estates-General, though certainly, contrary to what is portrayed here, Condorcet was not a democrat in 1789 and Robespierre was. But again, historical figures we’re not supposed to like must be set up early and often as stock villains — otherwise you run the risk of your readers thinking for themselves, I guess. Also the Chronique de Paris quote (which is from an unsigned article generally attributed to Condorcet) is pretty damn misogynistic, which given the book’s stated main theme, you would think would be addressed in some way, but nope!

 Conversely, figures the authors like are liked by the characters — or they are at least forced to begrudgingly recognize their merit — whether it makes sense or not. One of the things Manon Roland is made to number among the things going “wrong” in August 1792 is “the hero Lafayette[’s being] forced into exile” (p. 261) and while it is the author of a different section who is a self-proclaimed La Fayette stan (thanks to Hamilton, of all things…) I think it’s fair to say from his portrayal in all the sections that we’re meant to admire him. But here’s the thing. I don’t really care what you think about La Fayette. That’s not the question. To Manon Roland in August 1792, La Fayette was a traitor who attempted to march his army against the Legislative Assembly and all her friends and allies in said Assembly voted to indict him. If you’re writing from her point of view, it should reflect that.

 Likewise, they have Pauline Léon describe Olympe de Gouges like this in July of 1793: “A defender of women, of slaves, I wish I could have admired her, but having aligned herself to my enemies, I could look at her no other way.” (p. 353). Olympe de Gouges is far better known now than she ever was in her lifetime, so making sure every character has an opinion on her is, once again, pretty artificial, but even assuming Pauline Léon had heard of her, Olympe de Gouges’s brand of feminism was an elitist one that excluded women like Pauline Léon and her abolitionism went out the window when the slaves actually started to rise up, so Pauline Léon actually would have had reason to dislike her beyond the logic of ‘you’re with me or you’re my enemy’ (there is a quote where she’s made to think precisely that, but I can’t seem to find it now — or maybe it was Reine Audu; they’re characterized pretty similarly in that respect). Likewise, Pauline Léon is made to disapprove of Condorcet or the Rolands because they don’t “[get] things done,” not because of any actual ideological disagreement (p. 349).

Probably the worst bit of condescension comes once again from Manon Roland’s section, where she tells a fellow spectator in the gallery of the Convention, “‘Don’t bother trying to tell the different assemblies and conventions apart,’” which is pretty transparently just the authors directly talking (down) to the reader rather than a conversation people who were living through events (and invested enough to be attending the Convention) would plausibly have had.

If it sounds like I’m being particularly harsh on the Manon Roland section, btw, I actually think it’s one of the less poorly done, at least in terms of rendering an historical figure’s mentality, most likely because unlike for some of the other figures, we have her memoirs and correspondence. It helps that the figures she’s supposed to hate line up with the figures the authors want us to hate as well. She saw herself as a reasonable republican and her Montagnard enemies as demagogues and that’s also clearly the authors’ assessment of the situation, so there’s less of the strange cognitive dissonance you get in some of the other chapters where even what is supposedly characters’ own POV frames them as wrong.

Stay tuned for style issues and reflections on what it means to “write what you want to know”!

[clary-jace]

tv tag: 

i was tagged by both ally @mikewheeler​ and anna @dustinhendrsn​ to do this so thanks girlies!!!! 

Pick 5 shows, then answer the following questions, don’t cheat. Tag 10 (or however many) people.

stranger things

that 70s show 

superstore 

friday night lights 

marvel’s runaways 

1. Who is your favourite character in 2?

eric forman!!! i know that’s an unpopular opinion but i just love him sm, he reminds me a lot of myself when i was like 16/17/18 being all like awkward and not knowing where you’re going in life like i just think he’s really relatable and i just love him a lot okay!!!! eric forman apologist and proud!!! 

2. Who is your least favourite character in 1?

it’s like a four way tie between billy, brenner, lonnie and ted. i want all four of them dead. we’re 1 for 4 so far so let’s make it 4 for 4 in s4 babey. 

3. What is your favourite episode of 4?

i love so many episodes of fnl but a stand out for me is mudbowl (1x20) i’ve just always really loved that episode!! i also really love the series finale and tbh any episode from s1 and s3. 

4. What is your favourite season of 5?

i love season 1 and season 2 both a lot but i think season two is just slightly above season one. 

5. Who is your favourite couple in 3? 

amy/jonah!! i love them so so so much!! can’t wait to collect my engagement and wedding sometime in the next couple seasons!!! 

6. Who is your favourite couple in 2?

eric/donna!!!! another unpopular opinion but i literally love them so so so so much. they had my heart by the end of the pilot episode and i’m so happy that they were together for so long and i got to see so much of them, while i didn’t get a 100% confirmed endgame i got as good as and i’ll never complain about it ever. 

7. What is your favourite episode of 1?

i have a lot of favs and i honestly don’t think i could pick just one so i’ll pick my fav from each season. from s1 it’s 1x06 (the monster), from s2 it’s 2x09 (the gate) and from s3 it’s 3x04 (the sauna test). 

8. What is your favourite episode of 5?

omg honestly this is so bad but i don’t know any of the episode names and some of them episodes blend together because i binged them and they all happen one after another but probably the season one finale!!! 

9. What is your favourite season of 2?

it’s probably a tie between season 1 and season 5. season 1 is genuinely the best season in my opinion and every episode is incredibly enjoyable, and season 5 is my fav for the eric/donna of it all. 

10. How long have you watched 1?

i started watching st in like september of 2016, so since then but i wouldn’t have considered myself a stan until after season 2. 

11. How did you become interested in 3?

a couple of my mutuals watched it and i’ve always loved sitcoms like this and i noticed the show was on hulu so i decided to give a try!! 

12. Who is your favourite actor in 4?

i don’t follow many of the actors from this show anymore but i’ve always loved aimee teegarden, but i also love adrianne palicki and connie britton a lot!! 

13. Which do you prefer, 1, 2, or 5?

stranger things is probably my favorite show ever so that’s definitely gonna be number one in my heart always, but that 70s show is definitely my all time fav comfort show so definitely a close second. runaways is solid but not quite close to the top. 

14. Which show have you seen more episodes of, 1 or 3 ?

three! but that’s only because there are way more episodes of superstore then there are of stranger things ajfkdaf 

15. If you could be anyone from 4, who would you be?

julie<3 she’s my fav and her and i are really similar and like i want coach and tami to be my parents!!!!! i want matt saracen to be in love with me!!!! i want tyra to be my best friend!!!! it’s what i deserve!!!!! 

16. Would a crossover between 3 and 4 work?

i mean....probably not but maybe! 

17. Pair two characters in 1 who would make an unlikely but strangely okay couple?

Give Me Robin And Nancy Or Give Me Death!!!!!!!!!! 

18. Overall, which show has the better storyline, 3 or 5?

this is so hard because they’re literally totally different stories but i’d say that runaways just because superstore is a sitcom they have less overarching plots then runaways does! 

19. Which has the better theme music, 2 or 4?

THAT 70S SHOW!!!! literally one of the best and most iconic them songs ever. don’t get me wrong the opening credits to fnl are amazing but the that 70s show theme is so so iconic 

ok i’m gonna tag @milliebbrowns @lucascsinclairs @jennasmourey @lea-michele @koridick and @fatechica :) 

[bestdjkit]

The Annual Pokémon GO Fest is Turning Into a Music Festival in 2021

Niantic wants to know if you're a Pikachu Rock Star or Pikachu Pop Star.

Pokémon GO Fest 2021 has become the annual mecca for the app's avid fandom. For last year's first-ever online-only event, Niantic confirmed millions of Trainers, who shattered records and caught nearly 1 billion Pokémon. While there were a staggering amount of participants at the 2020 event, the 2021 edition could be even bigger after Niantic, the game's developer, announced that it will double as a music festival.

“2021 marks both the twenty-fifth anniversary of Pokémon and the fifth anniversary of Pokémon Go," Niantic shared in a blog post. "So trust us when we say you won’t want to miss Pokémon Go Fest 2021!” 

The two-day event will kick off on July 17th and will be held exclusively online. Attendees will have the choice to select one of two Pikachu: Pikachu Rock Star or Pikachu Pop Star, and the selection will dictate the music that will be heard in-game and throughout the festival.

Veteran director and longtime Pokémon video game composer Junichi Masuda has created "a rock-and-rolling track for Pikachu Rock Star fans" and "a high-energy electro-pop song for Pikachu Pop Star stans."

Flyer for Pokémon GO Fest 2021.

If players can complete all of the in-game tasks during the festival they will be rewarded with the chance to encounter a mythical Pokémon.

In honor of Pokémon Go’s fifth anniversary, Niantic has also lowered the price of admission from $14.99 to just $5. With a more affordable ticket price, the numbers are sure to skyrocket from last year event's. 

Click here to learn more of what's in store at Pokémon GO Fest 2021.

from Best DJ Kit https://edm.com/gear-tech/pok%C3%A9mon-go-fest-music-festival-2021

[epiphany-in-exile]

Billboard Taylor Swift's 2017: The Timeline 12/18/2017 by Allison Stubblebine From the record-breaking 'Reputation' to speaking out against sexual assault, Swift continued to change culture in 2017. Taylor Swift didn't do a lot in 2017... until she did. Following months spent attempting to fly under the radar, and the Instagram blackout of Aug. 2017, Swift took the rest of the year by storm, with a not-so-traditional album rollout for Reputation and a series of larger than life visuals to accompany the first singles. Fans got a sneak preview at what was to come from her personally curated Secret Sessions, but those were hidden away from the lens of the media. Now that Reputation is here to stay, Billboard has taken a look back at Swift's action packed year. Jan. 27 - “I Don’t Want to Live Forever” music video release Swift kicked off the New Year with the release of the visuals to Fifty Shades Darker track “I Don’t Wanna Live Forever.” Swift and former 1D artist Zayn trashed a hotel room for the video, lit by flashing shades of blue and red. The song peaked at No. 2 on the Billboard Hot 100. Feb. 4 2017 - Taylor Swift plays “only show of 2017” Swift broke some disappointing news to fans during her pre-Super Bowl set for DIRECTV Now Super Saturday Night. "I have to be really honest with you about something: As far as I know, I'm doing one show in 2017. And as far as I know, this is that one show," Swift said long before the announcement of Reputation. She added, “You're the crowd in my most recent daydreams, when I'm thinking about being onstage, so I was wondering: If you don't feel like dancing for yourself or screaming for yourself, you don't feel in the mood or whatever, you're like stressed out, would you do it for me tonight?" Feb. 15-16 - TAS Rights Management, LLC filed nine separate trademarks for “Swifties” Swift’s brand nailed down the things most true to her: Swifties. Nine separate trademarks were filed for the word alone, including one involving “a website featuring non-downloadable audio recordings [and] video recordings.” The idea that Swift would launch her own streaming service was debunked. Mar. 2 - Ed Sheeran teases Swift’s upcoming album The singer revealed that his pal would be putting her music out quite late on in the year, saying, “Taylor [Swift] isn’t going to be releasing until probably the end of this year—Christmas is the smartest time to release because that’s when everyone buys records.” Looks like he was right. Mar. 10 - Man arrested for stalking/burglary inside Swift’s apartment building A man was arrested in Swift’s New York City building on charges of burglary, stalking, and trespassing. According to a Page Six report, the man allegedly hoped to meet the singer face-to-face. While the man was initially held on $20,000 bail, he was found unfit to stand trial and reportedly “placed in the custody of the New York State Office of Mental Health” as of late September. April 4 - “Busy working” on new album in Nashville After the singer had been spotted driving around Nashville, a source confirmed to ET that she’d come “to get away from the paparazzi,” and also that she had “been busy working on her upcoming album.” May 15 - She’s really in Nashville! Swift celebrates Mother’s Day at home with her mom TMZ did the heavy digging and proved that Swift really had been in Nashville - though she may have been hopping back and forth, as she was spotted getting onto her private jet after a spending the weekend with mama Swift for Mother’s Day. July 4 - Keeping it low-key for the first time in years on the Fourth of July Paparazzi were very upset that Swift didn’t have an Independence day blowout tailor-made for media, even though she'd been keeping a relatively low profile all year. Aug. 14 - $1 Countersuit Win The long-drawn-out legal battle between DJ David Mueller, who was accused of reaching under the pop star’s skirt to grope her during a photo shoot in 2013, was finally put to rest. After Mueller attempted to countersue for damages that occurred following Swift’s accusation (which was quietly made to the station, who promptly let him go), the singer was awarded a single symbolic dollar in damages. Swift’s attorney Douglas Baldridge explained the value, “It means no means no, and it tells every woman that they will determine what is tolerated with their body." Aug. 18-20 - Bye bye, old Taylor… and old posts In the internet-breaking fashion Swift seems to have perfected, the singer’s social media accounts went into full blackout mode. No old posts were to be found anywhere, signaling that she was gearing up to launch something huge. Aug. 21 - She’s back, but only with some snakes In one of the best social media moments of the year, Swift posted a three-part series of glitch-y snake videos without captions to her Instagram to break her short-lived blackout. The image of the snake had become synonymous with Swift’s internet-meme identity, following the drawn-out beef with Kim Kardashian and Kanye West regarding West’s “Famous” lyrics and video. Aug. 23 - It’s an album! After five days (AKA an eternity in Swiftie time), Swift revealed the project behind the social media madness. Continuing in the three-part posting style, Swift announced “FIRST SINGLE OUT TOMORROW NIGHT,” posted the cover art, and announced the release date for then-upcoming album Reputation. All posts were still caption-less. Aug. 24 - Look what you made her do. Swift released Reputation’s lead single “Look What You Made Me Do” with a clever caption on Instagram: “..ready for it? New single #LookWhatYouMadeMeDo out now.” Of course, the forthcoming track title remained an inside joke to the singer’s team upon posting time. Aug. 27 - Look what you made her do, part two. The singer premiered the visuals for “LWYMMD” at the 2017 MTV VMAs, snagging 43.2 million views in the first 24 hours alone, now standing with over 783 million views. The Joseph Kahn-directed visual is loaded with references to the “old Taylor,” including a tombstone for Nils Sjoberg, her songwriting pseudonym on ex-boyfriend Calvin Harris’ 2016 hit “This Is What You Came For,” nearly all of her most iconic outfits, more snakes, and nearly all her besties’ names scribbled on a new version of her “You Belong With Me” music video costume. Sept. 3 - “…Ready for It?” released Swift released the second track off Reputation after she previewed it on Saturday Night Football the night prior. It followed suit with the darker, much more dramatic new Taylor, yet gave no clearer picture of what was yet to come. Sept. 5 - No. 1, again Taylor Swift's "Look What You Made Me Do" tops the Billboard Hot 100, where it would reign for three weeks. The song was her fifth Hot 100 No. 1 and broke the weekly streaming record for a song by a woman; it also stopped the record-tying 16-week reign of "Despacito." Sept. 7 - TayTay On Demand Ever wanted to know what Swift is up to at any given moment? Well this isn’t exactly that, but the trailer jokes that it will be. Swift announced her new video-on-demand channel in partnership with AT&T and DirectTV called Taylor Swift NOW, accompanied by a hilarious play-by-play of Swift’s day in the studio (complete with Andy Samberg cameo). Oct. 11 - The Swift Life app announced Stans will finally have a one-stop-shop for finding out everything there is to know about their fave singer. It is said to function as a social network of sorts, leaning into Swift’s hobby of “lurking” and replying to fans on social media, and also offering an opportunity to “collect Taymojis, stickers, pics, and more.” Oct. 20 - “Gorgeous” released The predictable yet addicting pop track the world was waiting for finally arrived. Swift sang of a romantic interest that was somehow too gorgeous for even a superstar like her to talk to. James Reynolds, two-year-old daughter of Ryan Reynolds and Blake Lively, was later officially credited in album liner notes as the voice at the beginning of the track. Oct. 27 - “…Ready for it?” returns with visuals The fans surely weren’t ready for it, yet with the Joseph Kahn directed video packed with hidden messages, it wasn’t long before Swifties decoded them all. Among the most obvious are Swift’s birth year spray-painted on a wall, the Chinese characters for “Year of the Snake,” as well as a similar lightning strike in the intro to Calvin Harris’ “This is What You Came For” album art. Nov. 2 - “Call It What You Want” lyric video released Fans started to get a fuller picture of what was coming from Reputation in just over a week. Swift seemed to be finding her way to happiness in the first ballad to be released from the album, but she was still attempting to rid herself of the drama she’d endured. The day was special for more than one reason, coinciding with the 13th anniversary (Swift’s lucky number) of meeting Scott Borchetta, the Big Machine Records executive who signed her and gave her the fateful big break. Nov. 7 - Track list revealed on Swift’s Instagram Account Three days prior to the Reputation release date, Swift posted the back cover to the album, featuring the track listing. Nov. 8 - CMA Win Even though she's left country in the dust on her own albums, Swift's song for Little Big Town, "Better Man," nabbed song of the year at the 2017 CMAs. Nov. 9 - The album was leaked, and this is why we can’t have nice things In this day and age, so many albums leak prior to release date, but not quite in this fashion: missing from the leaked files was track no. 13, “This Is Why We Can’t Have Nice Things.” Whether it was at the hands of Swift’s team, Swift herself, or a sneaky fan, it was quite the clever move. On the same day, an intimate recording “New Years Day” from what looks like a secret session was premiered on ABC during an episode of Scandal. Nov. 10 - Reputation is out everywhere, except for streaming services Reputation hit shelves and online retailers; a Target exclusive version included a magazine with poems and photos from Swift. She announced 20 days later that Reputation would be available to stream at midnight on Dec. 1. Nov. 11 - SNL Swift plays Saturday Night Live, busting out "...Ready for It?" and an acoustic "Call It What You Want." Nov. 13 - Tonight Show Following the death of Jimmy Fallon's mother, Taylor Swift agreed to appear on The Tonight Show to play a moving version of "New Year's Day." Nov. 20 - Reputation Is No. 1 Swift's Reputation becomes her fifth No. 1 album on the Billboard 200. Reputation notched 2017’s biggest week for an album, as the set earned 1.238 million equivalent album units in the week ending Nov. 16, according to Nielsen Music. Of that sum, 1.216 million were in traditional album sales -- the largest sales frame for an album since 2015. It would hold the No. 1 spot for three weeks. Nov. 28 - Grammy Time The Taylor Swift-penned "Better Man" from Little Big Town is nominated for best country song -- which is a songwriter(s) award, so Swift will get a trophy if it wins. She's also nominated for best song written for visual media for her Zayn collab "I Don't Want to Live Forever." Dec. 1 - Taylors In the Stream Reputation appears on the major streaming services. Dec. 4 2017 - Reputation, but make it fashion (UK Vogue cover) Vogue UK revealed its first cover of the new year would feature Swift. Newly appointed Editor in Chief Edward Enninful styled the singer during his second cover after taking the reigns from Alexandra Shulman. Mert Alas and Marcus Piggott, also photographers for all Reputation visuals, shot the twelve-page spread. Two days later, the high fashion mag revealed a poem Swift wrote exclusively to run with the feature, titled, "The Trick to Holding On." Dec. 6 2017 - Swift is one of Time’s “Silence Breakers” Her summer court case was not meant to be a media spectacle, but it was meant to prove a point with the symbolic $1 request. As Time gave the platform to “The Silence Breakers,” women who helped bring sexual assault and harassment to the forefront of the national conversation, as its 2017 Person of the Year, Swift was among the individuals highlighted. The Time interview is the first time Swift has done press about the court case, and in it she detailed reaching out to Kesha for support, as well as her feelings as she sat in the courtroom. "I was angry. In that moment, I decided to forego any courtroom formalities and just answer the questions the way it happened,” Swift said. “This man hadn’t considered any formalities when he assaulted me, and his lawyer didn’t hold back on my mom -- why should I be polite? I’m told it was the most amount of times the word 'ass' has ever been said in Colorado Federal Court." Dec. 8 2017 - Swift Plays iHeartRadio’s Z100 Jingle Ball in NYC The pre-Super Bowl performance wasn’t her only concert of 2017, after all. Camila Cabello and Lindsay Lohan were Swift’s biggest fans at the show, posting videos dancing the night away to various social media platforms. Dec. 11 - Reputation Continues to Be Big Swift earned her 55th Hot 100 hit with Reputation album track "End Game," featuring rapping from Future, Ed Sheeran and herself. Dec. 13 - B'Day & Tix While some fans were able to buy tickets in advance, the general public tickets for Swift's Reputation Tour went on sale Dec. 13, 2017 -- not coincidentally her 28th birthday. She released a tour trailer to celebrate. Dec. 14 - Still Getting 'Ready' Swift dropped a lyric video for BloodPop's bouncy remix of "...Ready for It?"

[marymosley]

Holding or Dicta?

In the comments to a blog post I wrote about using unpublished cases, one reader suggested a follow-up topic: “Should do an article on dicta; what is it and is it precedent?”

At the time, I was lukewarm on the idea. Dicta are just the extraneous statements in a court opinion that are not part of the precedential holding. What else was there to say? But the question came back to my mind after I read Chavez v. McFadden, __ N.C. __, 843 S.E.2d 139 (June 5, 2020), where the state Supreme Court made a point of disavowing dicta in a related Court of Appeals decision, discussed here. I began digging a little deeper, and discovered that my casual attitude towards dicta was predicted by an article written nearly seventy years ago:

Dictum is one of the commonest yet least discussed of legal concepts. Every lawyer thinks he knows what it means, yet few lawyers think much more about it. […] The traditional view is that a dictum is a statement in an opinion not necessary to the decision of the case. This means nothing. The only statement in an appellate opinion strictly necessary to the decision of the case is the order of the court. A quibble like this shows how useless the definition is.

“Dictum Revisited,” 4 Stan. L. Rev. 509 (1952). So I decided to take a closer look at how we distinguish and classify dicta, and whether dicta have any value as precedent. It turns out that our theory and practice may not always line up.

The Traditional Definitions

It almost goes without saying that the precedential value of any case lies in its holding. Guidance in future cases comes from our appellate courts’ legal conclusions that these are the elements of the offense, that was a prejudicial error, or this was an insufficient showing. See State v. Howell, 211 N.C. App. 613 (2011) (“The actual holdings of the relevant appellate opinions must be consulted”).

Statements in an opinion that fall outside of what was necessary to decide the issue at hand are deemed dicta, and they are not considered binding precedent in future cases. See State v. Breathette, 202 N.C. App. 697 (2010) (defining dicta), citing State v. Jackson, 353 N.C. 495 (2001) (“general expressions” that “go beyond the case […] may be respected, but ought not to control the judgment in a subsequent suit where the very point is presented for decision”). More specifically, remarks that are wholly “incidental to the disposition of the case” or “directed at issues upon which no formal arguments have been heard” are classified as obiter dicta (Latin for “by the way” or “said in passing”) and such statements “are not considered to be precedent and should be distinguished from the ratio decidendi which provides the basis of the court’s ruling.” Chandler, Enslen, and Renstrom, “Obiter Dictum,” Con. Law Dsk., § 8:82 (2020).

However, many authorities also recognize a third category, known as judicial dicta, to describe statements in an opinion that were not necessary to determine the matter at hand, but nevertheless express the court’s legal conclusions about an issue argued by the parties:

“Judicial dictum” is a statement the court expressly uses to guide parties in their future conduct. As a general rule, such an expression of opinion on a point involved in a case, argued by counsel and deliberately mentioned by the court, although not essential to the disposition of the case, is distinguished from mere obiter dictum, and it becomes authoritative when it is expressly declared by the court as a guide for future conduct. Thus, a judicial dictum should receive dispositive weight in a lower court. Conversely, a court is not bound to follow dicta in a prior case that did not fully debate the point currently at issue.

Buccieri, Buchwalter, Gore, and Griffith, “Judicial Dicta,” 21 C.J.S. Courts 226 (2020). The term judicial dictum rarely appears in North Carolina appellate cases, but our courts seem to be echoing this principle in some decisions. See, e.g., State v. Springle, __ N.C. App. __ (July 21, 2020) (unpublished) (“While the Supreme Court, in Grady, did not find the entire statutory scheme unconstitutional, its strong dicta addressing the constitutionality of the statutory scheme on its face in effect left no viable constitutional path for anyone, including recidivist sex offenders not under supervision, to be subject to SBM under our General Statutes, sections 14-208.40 to -208.45″).

Problems (and Solutions?)

The problem, of course, is that the definitions above leave some room for interpretation. If an appellate opinion says that X is not a violation, but Y or Z probably would be, how much precedential weight does that carry in future cases involving Y or Z? One lawyer’s holding may be another lawyer’s dictum, and my obiter dicta may be your judicial dicta. To quote from another past blog commenter, the danger here is that “it all depends on whose ox is gettin’ gored.” Our case law confirms that reasonable minds can disagree about what constitutes dictum vs. holding in a prior case – even on the appellate bench. See, e.g., State v. Rankin, 257 N.C. App. 354 (2018) (disagreement between majority and dissent about whether a prior case was relevant precedent or nonbinding dicta), aff’d, 371 N.C. 885 (2018).

Ideally, court opinions would flag all dicta as dicta to avoid any potential confusion, and that does happen sometimes. E.g., State v. Milsaps, __ N.C. App. __, n.3 (July 21, 2020) (unpublished) (“Although dicta, had we reviewed defendant’s argument as to his verdicts on possession of heroin and trafficking in heroin by transportation based on the same heroin, we would have found no error in the judgment”).

When, as in most cases, there is no helpful label preceding the dicta, one well-known identification technique is the Wimbaugh inversion test. This test suggests reversing the statement at issue (such as “the evidence presented was/wasn’t sufficient”) and then asking whether the decision in the case would have been any different? If yes, the statement must have been a necessary part of the holding. If no, it’s dictum. The simplicity of this method is appealing, but it is far from foolproof. In complex cases it may be possible to reverse a single challenged statement and still reach the same outcome, despite the fact that the statement was part of the holding. Furthermore, even if the statement was dictum, was it judicial dictum? How can you be sure?

To avoid these problems, some alternatives have proposed abandoning the use of rigid and defined categories in favor of a more realistic or pragmatic approach. For example, instead of treating holdings vs. dicta as an all-or-nothing distinction, perhaps it makes more sense to consider the statement on a sliding scale where its precedential value is relative to how closely it connects to the facts at issue. See Andrew Michaels, “The Holding-Dictum Spectrum,” 70 Ark. L. Rev. 661 (2017) (“Statements narrowly tailored to the facts have greater constraining force and approach the status of binding holding. Broader or more general statements have less constraining force and tend to approach dicta.”). Another option is to evaluate the statement in light of subsequent cases and other legal authority. Has the statement been cited and adopted by other cases, or is it a bizarre outlier that conflicts with established law? See Marc McAllister, “Dicta Redefined,” 47 Willamette L. Rev. 161 (2011) (“Approaching the issue from a pragmatic perspective […] this article identifies three pragmatic categories of dicta: ‘vibrant dicta,’ ‘dead dicta,’ and ‘divergent dicta'”).

The examples above are just the tip of the iceberg. The debate about distinguishing precedential holdings from nonbinding dicta has been with us for many years, and likely will be for many more. See Ronald Krotoszynski, “Constitutional Flares: On Judges, Legislatures, and Dialogues,” 83 Minn. L. Rev. 1 (1998) (“Marbury [v. Madison] arguably represents the crowning triumph of dicta over the strict rule of according only the ratio decidendi formal precedential force.”).

If you are now more confused and frustrated than before we started, what I have to say next will either make you feel much better or much worse….

Most of the time, the distinction between dictum and holding doesn’t make a difference in the outcome.

Dicta as Precedent: Practice vs. Theory

In theory, based on the definitions above, we have clear rules and bright lines to guide us. The holding (and possibly judicial dictum) is binding precedent that must be followed, while obiter dictum is more like unsolicited parenting advice from a friend — respectfully considered, yes, but freely ignored if you don’t agree with it. Therefore, figuring out whether a given statement is holding or dictum should be incredibly important. And to be sure, there are a number of examples in our case law where that determination has mattered. See, e.g., State v. Poole, 228 N.C. App. 248 (2013) (declining to follow a prior case as either obiter dicta or a distinguishable holding).

But looking at the bigger picture, that doesn’t seem to be what usually happens in practice. Whether dicta or not, courts tend to rule in accordance with these statements far more often than they depart from them. See Klein and Devins, “Dicta, Schmicta: Theory vs. Practice in Lower Court Decision Making,” 54 Wm. & Mary L. Rev. 2021 (2013). To compare theory and practice, the authors conducted an empirical study involving thousands of state and federal cases decided over a three-year period, looking for any instances in which a lower court identified a statement from a higher court as dictum. The authors then evaluated a random sample of those cases to determine how frequently the lower courts followed the dictum and how often they departed from it. Their findings were eye-opening:

Thus, our results indicate that the distinction between dictum and holding plays an important role in lower court decision making in fewer than 1 in every 2000 federal district court cases (140 out of 327,524) and in fewer than 1 in every 4000 state court (60 out of 295,452) or federal circuit court (20 out of 80,421) cases. Combining all cases, we estimate that consequential invocations of the holding-dictum distinction occur about once in every 3200 cases (220 out of 703,397). […]

For most lawyers, seeing a court disregard a significant statement from a higher court because it is dictum will literally be a once-in-a-lifetime experience.

Id. One could argue that these numbers don’t necessarily prove that the lower courts are “following” the dicta or treating dicta as precedent. After all, it’s possible that the deciding court simply found the substantive argument to be persuasive for the same reasons that the earlier court did. And that alternative explanation may be as close as this post can come to offering any closing advice on this messy issue. In circumstances where it is unclear whether a statement is holding or dictum, attorneys may find more success if they worry less about trying to classify it and focus instead on whether (and why) it’s a correct interpretation of the law. See, e.g., State v. Martin, 223 N.C. App. 507 (2012) (“even if we were to assume arguendo that the quoted language from Bowditch is dicta, we find the Supreme Court’s reasoning in that case highly persuasive and would apply it here”).

Thanks for reading, stay safe and healthy.

The post Holding or Dicta? appeared first on North Carolina Criminal Law.

Holding or Dicta? published first on https://immigrationlawyerto.tumblr.com/

[zhumeimv]

Will The Fantastic Four Reboot Introduce The MCU's Most Powerful Character?

Will The Fantastic Four Reboot Introduce The MCU’s Most Powerful Character?

Date: 2019-12-05 15:00:01

[aoa id=’0′][dn_wp_yt_youtube_source type=”101″ id=”5-6U_U9p_g4″][/aoa]

Thumbnail Image by Bosslogic →

After 20th Century Fox’s final attempt to revive the Fantastic Four for a feature film failed miserably, news of Marvel Studios’ plans to do their own Fantastic Four movie was warmly received, to say the least. And now there are rumours flying about that the team’s…

[torentialtribute]

Bury captain Neil Danns slams owner Steve Dale after EFL expulsion

Bury captain Neil Danns publicly beaten owner Steve Dale after the expulsion of the Football League and literally accuses the company of & # 39; lives. & # 39;

Dale took control of the club in December 2018 after paying just £ 1, but brought the 134-year-old institution to the ground after a series of unpaid bills and poor management.

Now, after their official expulsion from the English football competition, Captain Danns has not been restrained with his opinions about Dale's actions. Bury captain Neil Danns publicly slammed the owner Bury Capt Neil Danns slammed owner Steve Dale after the club's EFL expulsion "class =" blkBorder img-share "/>

Bury captain Neil Danns slammed owner Steve Dale after the club's EFL expulsion

Owner Steve Dale did not sell the club in time to meet the EFL deadline

& # 39; I would say look what you did & # 39 ;, said Danns when asked during an on-air interview with Talksport what his message would be for Dale.

& # 39; This should never have happened. If you thought you couldn't bring this club forward in a positive way, you should never have taken it over because you literally destroyed lives, because that's what this football club meant to so many fans. & # 39;

The latest developments such as the FA confirmed, via a statement, that Bury could not participate in the FA Cup this season after withdrawing their Football League status.

Bury & # 39; s fans are vocal every week, with a chest with the text & # 39; RIP Bury FC 1885 & # 39; prominent

Joy Hart, the former director of Bury, was involved with Gigg Lane last week "class =" blkBorder img-share "/>

Joy Hart, the former director of Bury, handcuffed himself on Gigg Lane last week

BURY TIMELINE

1885 – Club was founded on April 24 by a merger between two church teams, the Bury Wesleyans and Bury Unitarians. Club rented a plot of land on Gigg Lane on the estate of Earl of Derby.

1887-88 – Bury entered the FA Cup for the first time.

1889 – Bury became a member of the Lancashire League.

1892 – The clubs win the Lancashire Cup and beat Everton in the final. Before the game, it was reported that Chairman JT Ingham had raised the players by saying: & # 39; We will shake them & # 39 ;. In fact, we are the Shakers! & # 39; The Lancashire Cup of 1892 was the first of 11 such titles that extended to 2017-18.

1894 – The Shakers are admitted to the Football League. They win the title of the second division in 1894-95 with nine points, making them promotion to the top.

1900 – Bury wins the FA Cup and beat Southampton 4-0 in the final.

1903 – Club wins FA Cup again and defeats Derby 6-0 while not conceding any goals during the tournament.

1 9 25 – Bury starts fourth in the first division – highest highest finish ever.

1929 – The club has been relegated from the highest level and has not returned since.

1957 – Bury stepped out of the Second Division for the first time.

1971 – For the first time, Bury have been relegated to the fourth level.

1997 – Two successive promotions under manager Stan Ternent bring Bury to the second level for the first time in 30 years.

2001-02 – Financial problems related to the collapse of ITV Digital take Bury in administration and almost in the fold. Supporters raise enough money for the club to survive.

2005 – Bury is the first club to score 1,000 goals in each of the four top competitions.

2012 – The Shakers have an embargo transfer with them after financial problems due to poor presence.

[1945902] 2018-19 – Bury second in League Two to win promotion. Businessman Steve Dale buys the club in December 2018 and pays an excellent tax bill to prevent a liquidation order. But financial problems will return in mid-2019.

& # 39; As the club reforms, we look forward to applying to the Football Association for a new to participate in the league competition later in the English football pyramid from the 2020/21 season. & # 39;

Danns made 39 games in all games last season, while the team nicknamed & # 39; The Shakers & # 39; was promoted to League One despite their off-the-field problems.

In July, the club received a 12-point deduction after entering into a voluntary company arrangement to try to settle part of their debts.

A team from the first team had trained under the new manager Paul Wilkinson and the team hoped to step out of the field.

& # 39; We trained just as normal. I don't think anyone really believed that this would happen, & Danns added.

& # 39; Because it would happen so suddenly, it is still really incredible. For a club with so much history and that has added so much to the competition, because it is simply unthinkable that it is simply unimaginable. & # 39;

Bury's slide in liquidation was a & # 39; slow moving train & # 39; wreck Accrington Stanley & # 39; s outspoken president Andy Holt.

Despite the number of last-minute takeover bids – the EFL announced that the Shakers, twice FA Cup winners, were the first outfit since 1992 to be thrown out of the competition.

The decision led to Holt and other people having their say in football and regretting how the situation along the way was treated with minimal interaction.

Holt created a thread on social media in which he gave his opinion on how Bury Football Club, its players, staff and supporters had been abandoned.

We urgently need to teach the obvious lesso of this catastrophe. We need a post mortem. A club has died and it is OUR fault. & # 39;

Holt noted the sale of the club stadium with around & # 39; £ 3.7 million in debts & # 39; and & # 39; & # 39; interest charged. In addition, countless unpaid obligations, football creditors and a team that repeatedly deducted points.

& # 39; The club could not survive its debt. He [owner Steve Dale] had entered a hornet's nest.

& # 39; That happened behind the scenes, an attempt to bring together debtors and holders of fixed costs. It is exactly the same situation at BWFC (Bolton Wanderers). & # 39;

Like their northwestern neighbors, Bolton could follow Bury quickly and get their marching orders from the EFL.

Despite being one of the 12 founding teams of the Football League, Bolton found himself in a dangerous financial position, paralyzed with debts and wages left unpaid

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[writing-creative-fiction]

At the remarkable Scott Polar Research Institute in Cambridge on 12th June 2018 I spent 6 glorious hours examining documents from their extensive archive of nineteenth-century polar records. I am looking forward to returning there at the end of July to continue this branch of my research, but in the meantime here is a résumé of the items I was able to view during this visit.

Item 1: SPRI archive ref. MS 1009;D

This item is a facsimile of “the first geological map of the Canadian Arctic islands from Captain F L McClintock reminiscences of Arctic ice, travel in search of Sir John Franklin and his companions Journal of the Royal Dublin Society, volume I, 1856-1857 Dublin 1858.” (SPRI catalogue online). This facsimile was sent as a Christmas card, probably in 1858/59, by “J.C.Proule and Associates Ltd.”, the left hand page of the three-fold document containing Christmas images of holly and candles alongside a Christmas greeting in 12 different languages and 14 signatures, most of which are illegible but include the more legible Wally Drew, Stan Hardy, F.Saluz de Santa Maria, Rudolf Try [or Twy]  and A, F, or J. Mirza.

The map covers the remaining 2 pages of the single-sided document, and its subscript identifies the location of J.C.Proule and Associates Ltd. as Calgary, Alberta, and the document’s printer as “Davy & Son, Lithrs  to the Queen”. The abbreviation, of course, representing the company’s business as Lithographers.

Unfortunately, though understandably, SPRI do not allow photographs to be taken of any of their documents, so I am not able to post images of this beautiful Christmas card, which must have been a delight to its recipients.

Inscriptions on the map state that it was drawn “by Revd. Samuel Haughton, M.A., Fellow of Trinity College, and Professor of Geology in the University of Dublin, from: Captain F.L.McClintock, R.N., reminscences of Arctic ice-travel in the search of Sir John Franklin and his companions. Journal of the Royal Dublin Society, Vol. 1, 1856-1857, Dublin 1858”, yet in the bottom right-hand corner, all in capitals, it states: “Discoveries in the Arctic Sea by the squadrons under the orders of Capt. Sir Edwd Belcher, C.B., HMS Resolute, Capt. Collinson, C.B., HMS Enterprise and Capt. McClure, HMS Investigator, up to MDCCCLIV [1854]”.

This suggests the map is a representation by Haughton based on the reports and sketches of various explorers prior to 1854, but published in 1858 as news of McClintock’s discoveries began to filter back – he did not return with evidence of Franklin’s demise until 1859!

The coloured areas of Haughton’s map denote geological features of the Arctic, including “Beds of Coal”, “Granite and Greissoid rocks”, “Liassic beds”, “Coal-bearing sandstones, Lower Carboniferous”, “Carboniferous Limestone”, and “Silurian Strata, Limestone”, implying that some interest still remained in mining the Arctic regions for precious resources, although the eighteenth-century dream of ‘Arctic Gold’ had long since departed.

Item 2: SPRI archive ref. MS 248/223;D

The second document I examined was an extract from Sir Roderick Murchison’s  Presidential Address to the Royal Geographical Section of the British Association in Oxford in 1860. In this, Murchison praises the “energy and perseverance … [and] noble and devoted courage” of Jane, Lady Franklin, attributing her with “having persisted through many years of her life to send out expeditions at her own cost untill [sic] she at length unravelled the fate of the Erebus and Terror”.

In consequence, Murchison asserts that “her heroic husband [Sir John Franklin] and his brave companions had been the first discoverers of the North West Passage” and goes on to award Lady Franklin and “that gallant and skilful [sic] officer, Sir Leopold McClintock” a Gold Medal each on behalf of the Royal Geographical Society of London.

Murchison concludes this section of his Address by confirming that he has “reason to know that a monument in commemoration of the glorious deeds of Franklin and his having been the first to discover the North West Passage will be erected”. This refers, I believe to the monument pictured below, which stands beside the gardens of the Athenaeum Club in Waterloo Place, just off the Mall, in London, and for which money can be seen, in the second image below, to have been voted by Parliament in 1865.

  Further Items

To conclude my visit to the SPRI archives, I read a sequence of letters written by such illustrious characters as Leopold McClintock, Francis L. Hawks, Henry Grinnell, Lady Franklin, and persons at the Admiralty. Among these letters I was particularly interested to read three written to the Secretary of the Admiralty by Leopold McClintock, discoverer of the first Franklin relics. These 3 letters are stored together under SPRI archive ref: MS 248/439/1-3.

The first of these letters is dated “Arctic Discovery Yacht Fox, Aberdeen, 6th June 1857” and it discusses the manning of the expedition. In it, McClintock’s tone hints of sarcasm as he declares himself “truly happy that their Lordships [at the Admiralty] have had much pleasure in granting leave of absence to any officer upon half-pay to join the ‘Fox'” but goes on to “intreat [sic] their Lordships not to deprive [him] of the volunteer services” of an officer he is particularly keen to have aboard. Basically, McClintock is asking the Admiralty to let him select his crew and not be forced to take who they assign.

The second and third letters are dated “Yacht Fox R.Y.S. September 1859” and “United Service Club, Pall Mall, 8th Oct.r /59″ respectively.

In letter 2, McClintock announces his return from the Arctic, stating that

Their Lordships will rejoice to hear that our endeavours to ascertain the fate of the ‘Franklin expedition’ have met with complete success.

McClintock goes on to describe the finding of the now infamous ‘Victory Point Record’, which confirmed the death of Franklin on 11th June 1847 and the abandonment of the ships Erebus and Terror in April 1848. McClintock refers to the “many deeply interesting relics of our lost countrymen … picked up upon the western shore of King William’s Island and others obtained from the Esquimaux …” and explains how his ship “wintered in Brentford Bay” and spent the spring exploring and discovering a previously unknown “800 miles of coast-line”.

Letter 3 concerns the distribution of the aforementioned relics. McClintock begins by stating “Sir, I am directed by Lady Franklin to express to you, for the information of their Lords Commissioners of the Admiralty, her desire to place at their Lordships’ disposition the Relics of the lost Arctic ships, brought home by her expedition of Final Search.”

Lady Franklin, McClintock explains, has “reserved for herself and family” a few items identified as belonging to Sir John Franklin and desires other families to also be able to claim items identifiable as the possessions of their late relatives. The remaining items, Lady Franklin hopes, “might be deposited in a National Repository – such as the United Services Institution where they are now carefully arranged – and where, together with the ‘Point Victory Record’, they may be preserved and open for public inspection”.

A post-script to letter 3 states:

Lady Franklin is desirous of retaining in her own possession the least important of the two Records, which is merely a duplicate of a portion of the ‘Point Victory Record’.

These letters are formal, official correspondence between the Captain and his superiors at the Admiralty.

Letters that he wrote to his friend Richard Collinson between 1857 and 1860 give more personal, everyday information about the voyage. Stored together under SPRI archive ref: MS 248/439/4-8, these reveal details of menus, sickness and death, recruitment of Esquimaux guides, rations, and the weather as well as speculation about the expeditions progress and chances of success.

The tone of these letters is generally chatty, familiar, friendly, but in the final one, dated 12 January 1860 – and therefore after his return with news of Franklin’s fate – McClintock is outraged and rants in barely legible scrawl in response to a letter from W. Johnson, which he has read in the Athenaeum magazine:  “W.J. displays such ignorance of the subject he attempts to elucidate” states McClintock, who appears to be angry on a number of counts; firstly he feels that “W.J.” is undermining Franklin’s achievements by suggesting that Robert McClure, and not Franklin, first discovered the North West Passage; secondly he detects “unkindly feeling towards me for having brought home the proof …”, and thirdly, he fears that Lady Franklin “is repudiating everything in order to strengthen the Fox’s claim to reward!”, an idea that he claims is “insupportable”.

Within six months of his return then, McClintock is afraid that aspersions are being cast on his achievements, that Franklin’s memory is being attacked, and that Lady Franklin is usurping his claim to fame and reward. Thus he entreats Collinson “as one of the Committee” to stand by him and protect his claim to a share of the public acclamation and rewards of his endeavours.

In light of the Presidential Address by Sir Roderick Murchison referred to above, it seems safe to assume that McClintock’s plea was successful and he was awarded the recognition and rewards to which he felt entitled.

Of course, history has proved “W.J.” to have had a very valid point, and I hope I will soon be able to track down a copy of his letter that so enraged McClintock.

  N.B. all quotes in this text are taken from the documents under discussion, and can be accessed at The Scott Polar Research Institute under the references stated.

SPRI archive visit, 12 June 2018 At the remarkable Scott Polar Research Institute in Cambridge on 12th June 2018 I spent 6 glorious hours examining documents from their extensive archive of nineteenth-century polar records.

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SFB Wakanda University (Jabari Campus) Tee

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Andy Murray eyes singles return this year after injury nightmare

June 9, 2017 – Murray puts vibrating form in the French Open behind him in the semi-finals before losing to the Swiss bait Stan Wawrinka, but the outburst is beginning to feel like a long-standing hip issue that was previously under control

June 27, 2017 – Murray does not mention this hip problem after he first party at Queen & # 39; s lost to Jordan Thompson, but he is forced to publicly acknowledge it when he picks up the planned exhibition contest at Hurlingham Club, a precautionary measure cited

July 2, 2017 – After withdrawing a second Hurlingham match, Murray calms the fear that he will be forced to miss Wimbledon by playing on the eve of the tournament he will play. confirm

July 12, 2017 – Running with a noticeable limp, Murray fight is making its way to the quarterfinals, but his title defense ends with a loss of five sets for Sam Querrey. Afterwards Murray claims that he will not be far from the tour expected

August 26, 2017 – After withdrawing two Masters events and losing his world Nadal, Murray travels to New York with the intention to return to the US Open. But two days before the tournament, he announces his withdrawal and says his hip is too painful to give him a chance to win the tournament

September 6, 2017 – Murray goes home for further consultations with a number of hip specialists and announces that he will probably miss the rest of the year, but hopes to prevent surgery

January 2, 2018 – Murray plans the operation Brisbane International for his second attempt to come back and only on the eve of his first match. In a deep post on Instagram accompanied by a childhood photo, Murray says: & I choose this photo because the little kid just wants to play tennis and compete inside. I really miss it so much and I would give anything to be there again. "

January 8, 2018 – Murray announces that he has undergone hip surgery in Melbourne. In a positive review, he says surgeon John O & # 39; Donnell is very happy and that he is returning to the season of lawns will

March 28, 2018 – Murray places his first photo Patrick Murrayglou & academy in Nice

May 8, 2018 – After Murray failed participates in a Challenger tournament in Glasgow that was destined for his return, it appears that he has had a setback in his recovery and is forced to take more time away from the court

June 5, 2018 – Murray says he & # 39; is getting closer & # 39; to a – After two weeks back on the field, Murray announces that he is making his comeback at the Fever Tree Championships at Queen & # 39; s Club

1 June 9, 2018 – A long 342 days since his last competitive outing, Murray finally makes it back on court in the Fever-Tree Championships against Nick Kyrgios. He has a good fight but eventually loses his first round game 2-6, 7-6 (7/4) 7-5.

June 25, 2018 – Murray beats Wawrinka on Eastbourne but is then comfortably sent in the round of 16 by British No 1 Kyle Edmund as he continues to find his way back in games

July 30, 2018 – Murray fans grow in confidence with the increased participation of the Scot and a run to the quarterfinals – where he is defeated due to a walk-over for Alex van Minaur – he suggests that he slowly rises again

August 13, 2018 – A completion of the first round to Lucas Pouille shows that Murray is struggling to recapture the form that made him win twice in Wimbledon because of his hip problems seeing him restrained in a three-man party

August 30, 2018 – In only his fifth return tournament since his return from a hip operation, Murray wavers in four sets against Fernando Verd asco 7-5, 2-6, 6-4, 6-4 in the US Open the second round because the sultry conditions did little to help his goal. His noticeable limp between points became more obvious as points approached

September 28, 2018 – The quarter-final defeat in Shenzen to Verdasco sees Murray calling time in the 2018 season as he takes time away to himself in get the best possible condition for the 2019 Australian Open

December 27, 2018 – Despite some time gone since he lost to Verdasco in Asia, Murray admits that the pain is still prominent as he prepares to play in the Brisbane International, a warming-up tournament for the Australian Open. In his last 16 draw against the Russian star Daniil Medvedev, Murray is comfortably beaten 7-5, 6-2 as the fear of the condition of his hip grows

January 10, 2019 – Leaves Australian Open press conference in tears and suggests that his time in Melbourne could be his last Grand Slam tournament because the pain was too heavy to play on

January 28, 2019 – Murray underwent major

– Murray revealed that he was no longer in pain, but not sure if he would be able to compete on Wimbledon

– Murray depicted on the field for the first time since hip surgery

June 2, 2019 – Murray raises hope June 3, 2019 – Murray went to the Fever Tree Championships in the Queen & # 39; s Club in London with Brit set to partner Feliciano Lopez

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