關於 no doubt running ，我們在網路上蒐集到這些相關的討論、資訊與評價

【基礎力量訓練的動作有哪些？】

在我的觀念裡，力量訓練可分為「基礎力量」和「專項力量」。前者是每一種運動項目都要練的，後者跟運動項目有關，例如游泳、自行車、足球和跑步的「專項力量」都會有差別。但「基礎力量」會大同小異，這個大同中就一定有蹲舉……等動作。但除了蹲舉還有哪些？《The System》這本談論基礎力量的專書已經明確回答了這個問題，下面引用原文書第34頁分享如下：
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#以下為譯文

帕列托法則（Pareto’s Principle），是一項著名的經濟學法則，又稱為「80/20法則」，它也適用於力量訓練動作的選擇。它所要表達的意思很簡單：把80%資源花在能產出最大效益的20%關鍵事情上，而這20%的關鍵又將為你帶來80%的效益。從訓練的目的來看，我們可以把這個法則的內容改寫成：從所有的力量動作中選出最關鍵的20%，而這關鍵的20%訓練動作將為運動員的力量與爆發力帶來80%的訓練效果。

這關鍵的20%訓練動作，作者選列如下：
●蹲舉及其變化式：背蹲舉、前蹲舉、單腿蹲
●爆發力動作：上膊、抓舉、挺舉、推舉
●推與拉：臥推、肩推、上膊與抓舉的拉槓動作、划船及其變化式
●下背與後側動力鏈：羅馬尼亞式硬舉 (RDL)、背挺舉、反向背挺舉、早安動作

以上這份清單很短，但這些動作就是我們認為基礎力量動作中關鍵的20%。雖然我們所設計的力量課表中，不會只有這些動作，但80%的訓練效果無疑都是由它們產生，在跟我們合作過的運動員中只要是認真熟練這幾個動作，進步的效果都很明顯。

簡而言之，把你的重心放在學習與優化這幾種動作的教學上，會比學習眾多「複雜的」和「全面式的」課表，更能有效幫助運動員提升力量和爆發力。

除了上述20%關鍵動作之外，任何其他的舉重與訓練動作都應當作輔助、平衡弱點或滿足專項運動需求的訓練手段。這些動作應只占總體訓練的一小段時間，只是在填補訓練空隙，換句話說，它們只是輔助。有很多教練在動作選擇上太過追求創造力，不斷地學習與搜集那些無法顯著提升力量的訓練動作。

運動的基礎元素是蹲、跳、跑、彎(腰)/屈(膝)、(旋)轉、推、拉。只要你在這些基礎元素中奠定良好的基礎，練就更好的動作品質、穩定度與力量，並逐步提升動作的速度，我們幾乎就能為每一種運動提供所需的專項力量。重要的事先做，把大量的時間反覆花在關鍵動作的技術優化與力量強化上。

#原文如下
We ascribe to the 80/20 rule—attributed as Pareto’s Principle, an economic principle. It states that for many events, 20 percent of the work yields 80 percent of the effects. Adapted for our purposes, 20 percent of all the exercise and movement choices yield 80 percent of the gains in strength and power development.

●SQUAT VARIATIONS—back squat, front squat, single-leg squat
●EXPLOSIVE MOVEMENTS—clean, snatch, jerk, push-press
●PUSHING AND PULLING—bench press, military press, pulls (clean and snatch), row variants
●LOW BACK AND POSTERIOR CHAIN—Romanian deadlift (RDL), hyperextension and reverse hyperextension, good morning

That very short list of fundamental lifts compromises our particular 20 percent. Although we dedicate much more than 20 percent of our programming to these basic lifts, there is no doubt that well over 80 percent of the results we have seen in our athletes can be attributed to mastering this handful of movements and lifts.

Made even simpler, placing the primary focus of your coaching on learning and refining your teaching of the fundamental lifts will yield far greater and more sustained gains in your athletes’ strength and power than many more complex and “comprehensive” programs.

Any additional lifts or movements should be considered assistance or accessory work, which serve to address specific needs or deficits. Those exercises make up just a fraction of our time, as they fill gaps, rather than form the base of training—in other words, to provide assistance. Too many coaches try to be creative in exercise selection and end up with a collection of movements and lifts that improve nothing to any significant level.

The fundamental movements of sport are squatting, jumping, running, bending, twisting, pushing, and pulling. By building proficiency in the quality, the stability and strength, and then the speed of those movements, we provide almost all of the sport specificity we need. This is how we put first things first, and spend the greatest amount of time and repetition on refining and strengthening movements.
(以上原文出自《The System》第34頁)
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若有發現翻譯不到位或有問題的地方，非常歡迎也希望各界指正！

【CNN難得一次客觀報道中國疫苗接種就被美國🇺🇸輿論批評“為中國宣傳”，這是什麽“雙標”？】

當地時間18日，美國有線電視新聞網(CNN)報道了中國疫苗接種量將破十億劑次，並驚嘆“中國速度”。這則報道觸動了一些美國媒體人和政客的敏感神經，他們指責“美國有線電視新聞網(Cable News Network)”成了“中國新聞網(China News Network)”，並指CNN為“中國共產黨做宣傳”。針對中國的一則客觀報道竟淪為於中國有利的“宣傳”，再次體現了美西方部分群體在針對中國問題上的雙重標準。

其實，這並非他們第一次上演針對中國的“雙標”戲碼。此前，包括CNN在內的一些美國媒體將SpaceX的火箭殘骸墜落浪漫化為“點亮夜空”的電影大片場景，卻“齊心協力”炒作“失控”的中國火箭殘骸可能對地球造成威脅，此類報道被部分政客廣泛引用來質疑中國。而此次CNN報道中國疫苗接種量將破十億劑次，卻被部分美國媒體和政客點名，稱其為“中國共產黨做宣傳”，更有甚者質疑中國數據造假。謊言被追捧，事實卻遭到質疑和嘲諷，從根本上講，是他們對中國發展先入為主的偏見在作祟。

此次中國疫苗接種突破十億劑次是一個不容置疑的客觀事實。美國媒體口口聲聲推崇新聞自由，卻針對對中國的客觀事實報道大肆質疑和嘲諷，表現出十足的“酸葡萄”心理。這讓人不禁懷疑，他們推崇的“新聞自由”究竟是什麽樣的自由？難道只能容忍攻擊抹黑中國的自由？

然而，無論這些美媒如何費盡心機汙蔑中國，都改變不了中國在抗擊疫情方面取得的成效。中國國家衛生健康委員會6月20日公布的數據顯示，截至6月19日，中國新冠疫苗接種劑次已突破10億。數據公開透明，事件真實可靠，我們奉勸美西方部分群體還是停止玩弄“雙標”的把戲，遵守基本的新聞事實和職業操守，公正客觀地報道中國的新聞。

CNN dubbed 'China News Network': what double-standard trick are some U.S. media playing?

By John Lee

(ECNS) -- U.S. Cable News Network (CNN) was surprised by China's coronavirus vaccination rates, calling it "a scale and speed unrivaled by any other country in the world" in its report "China is about to administer its billionth coronavirus shot" last Friday. Fox News cited a commentary by NewsBusters analyst Nicholas Fondacaro, who labeled CNN as "China News Network pumping out propaganda for the CCP." A fact report on China was interpreted as "pro-China propaganda", showing some people in the U.S. and other Western countries had played a double-standard trick on China once again.

In fact, this is not the first time that they have practiced double standards on China issues. Previously, some U.S. media including CNN romanticized the rocket debris of SpaceX as "lighting up the sky with a spectacular rocket show", while coordinately stating China's rocket debris would "cause threats to objects on Earth". This time, CNN's report on China's vaccination speed was called "running Chinese propaganda for the CCP", with even Chinese statistics brought into doubt. It is nothing but their prejudice against China's development that sees lies flattered while facts are questioned and ridiculed.

It is an established fact that China has administered more than one billion doses of the COVID vaccine. Some U.S media shout for press freedom, but can't stop satirizing and questioning objective China-related reports, which is no doubt "sour grapes psychology." Does their press freedom mean unlimited freedom in attacking and smearing China?

China's achievements in fighting COVID-19 won't be effaced despite their slander. Statistics released by National Health Commission on Sunday shows more than one billion vaccines have been administered across China as of Saturday, which is definitely true and reliable. Therefore, U.S. media should give up their double-standard related to China, abide by news facts and professional ethics and report on China in a fair and objective way.

這是前些日子爆出已經被加拿大法院接理對藏傳佛教噶舉派法王的訟訴。（加拿大法院鏈接在此：https://www.bccourts.ca/jdb-txt/sc/21/09/2021BCSC0939cor1.htm?fbclid=IwAR2FLZlzmUIGTBaTuKPVchEqqngcE3Qy6G_C0TWNWVKa2ksbIYkVJVMQ8f8）

這位法王的桃色事件，我是幾年前才聽到。但，藏傳佛教的高層有這些性醜聞，我已經聽了幾十年。我以前的一位前女友也被一些堪布藉故上她的家摟抱過，也有一些活佛跟她表白。（這不只是她，其他地方我也聽過不少）

這是一個藏傳佛教裡面系統式的問題。

很多時候發生這種事情，信徒和教主往往都是說女方得不到寵而報仇，或者說她們也精神病，或者說她們撒謊。

我不排除有這種可能性，但，多過一位，甚至多位出來指證的時候，我是傾向於相信『沒有那麼巧這麼多有精神病的女人要撒謊來報仇』。

大寶法王的桃色事件，最先吹哨的是一位台灣的在家信徒，第二位是香港的女出家人，現在加拿大又多一位公開舉報上法庭。

對大寶法王信徒來說，這一次的比較麻煩，因為是有孩子的。（關於有孩子的，我早在法王的桃色事件曝光時，就有聽聞）

如果法庭勒令要驗證DNA，這對法王和他的信徒來說，會很尷尬和矛盾，因為做或不做，都死。

你若問我，我覺得『人數是有力量的』，同時我也覺得之後有更多的人站出來，是不出奇的。

我也藉此呼籲各方佛教徒，如果你們真的愛佛教，先別說批判，但如鴕鳥般不討論這些爭議，你是間接害了佛教。

（下面是我從加拿大法院鏈接拷貝下來的內容，當中有很多細節。）

Table of Contents

INTRODUCTION

BACKGROUND

ANALYSIS

A. The Spousal Support Claim in this Case

B. The Test to Amend Pleadings

C. Pleadings in Family Law Cases

D. The Legal Concept of a Marriage-Like Relationship

E. Is There a Reasonable Claim of a Marriage-Like Relationship?

F. Delay / Prejudice

CONCLUSION



INTRODUCTION
[1] The claimant applies to amend her notice of family claim to seek spousal support. At issue is whether the claimant’s allegations give rise to a reasonable claim she lived with the respondent in a marriage-like relationship, so as to give rise to a potential entitlement to spousal support under the Family Law Act, S.B.C. 2011, c. 25 (“FLA”).

[2] The facts alleged by the claimant do not fit within a traditional concept of marriage. The claimant does not allege that she and the respondent ever lived together. Indeed, she has only met the respondent in person four times: twice very briefly in a public setting; a third time in private, when she alleges the respondent sexually assaulted her; and a fourth and final occasion, when she informed the respondent she was pregnant with his child.

[3] The claimant’s case is that what began as a non-consensual sexual encounter evolved into a loving and affectionate relationship. That relationship occurred almost entirely over private text messages. The parties rarely spoke on the telephone, and never saw one another during the relationship, even over video. The claimant says they could not be together because the respondent is forbidden by his station and religious beliefs from intimate relationships or marriage. Nonetheless, she alleges, they formed a marriage-like relationship that lasted from January 2018 to January 2019.

[4] The respondent denies any romantic relationship with the claimant. While he acknowledges providing emotional and financial support to the claimant, he says it was for the benefit of the child the claimant told him was his daughter.

[5] The claimant’s proposed amendment raises a novel question: can a secret relationship that began on-line and never moved into the physical world be like a marriage? In my view, that question should be answered by a trial judge after hearing all of the evidence. The alleged facts give rise to a reasonable claim the claimant lived with the respondent in a marriage-like relationship. Accordingly, I grant the claimant leave to amend her notice of family claim.

BACKGROUND
[6] It should be emphasized that this is an application to amend pleadings only. The allegations by the claimant are presumed to be true for the purposes of this application. Those allegations have not been tested in a court of law.

[7] The respondent, Ogyen Trinley Dorje, is a high lama of the Karma Kagyu School of Tibetan Buddhism. He has been recognized and enthroned as His Holiness, the 17th Gyalwang Karmapa. Without meaning any disrespect, I will refer to him as Mr. Dorje in these reasons for judgment.

[8] Mr. Dorje leads a monastic and nomadic lifestyle. His true home is Tibet, but he currently resides in India. He receives followers from around the world at the Gyuto Monetary in India. He also travels the world teaching Tibetan Buddhist Dharma and hosting pujas, ceremonies at which Buddhists express their gratitude and devotion to the Buddha.

[9] The claimant, Vikki Hui Xin Han, is a former nun of Tibetan Buddhism. Ms. Han first encountered Mr. Dorje briefly at a large puja in 2014. The experience of the puja convinced Ms. Han she wanted to become a Buddhist nun. She met briefly with Mr. Dorje, in accordance with Kagyu traditions, to obtain his approval to become a nun.

[10] In October 2016, Ms. Han began a three-year, three-month meditation retreat at a monastery in New York State. Her objective was to learn the practices and teachings of the Kagyu Lineage. Mr. Dorje was present at the retreat twice during the time Ms. Han was at the monastery.

[11] Ms. Han alleges that on October 14, 2017, Mr. Dorje sexually assaulted her in her room at the monastery. She alleges that she became pregnant from the assault.

[12] After she learned that she was pregnant, Ms. Han requested a private audience with Mr. Dorje. In November 2017, in the presence of his bodyguards, Ms. Han informed Mr. Dorje she was pregnant with his child. Mr. Dorje initially denied responsibility; however, he provided Ms. Han with his email address and a cellphone number, and, according to Ms. Han, said he would “prepare some money” for her.

[13] Ms. Han abandoned her plan to become a nun, left the retreat and returned to Canada. She never saw Mr. Dorje again.

[14] After Ms. Han returned to Canada, she and Mr. Dorje began a regular communication over an instant messaging app called Line. They also exchanged emails and occasionally spoke on the telephone.

[15] The parties appear to have expressed care and affection for one another in these communications. I say “appear to” because it is difficult to fully understand the meaning and intentions of another person from brief text messages, especially those originally written in a different language. The parties wrote in a private shorthand, sharing jokes, emojis, cartoon portraits and “hugs” or “kisses”. Ms. Han was the more expressive of the two, writing more frequently and in longer messages. Mr. Dorje generally participated in response to questions or prompting from Ms. Han, sometimes in single word messages.

[16] Ms. Han deposes that she believed Mr. Dorje was in love with her and that, by January 2018, she and Mr. Dorje were living in a “conjugal relationship”.

[17] During their communications, Ms. Han expressed concern that her child would be “illegitimate”. She appears to have asked Mr. Dorje to marry her, and he appears to have responded that he was “not ready”.

[18] Throughout 2018, Mr. Dorje transferred funds in various denominations to Ms. Han through various third parties. Ms. Han deposes that these funds were:

a) $50,000 CDN to deliver the child and for postpartum care she was to receive at a facility in Seattle;

b) $300,000 CDN for the first year of the child’s life;

c) $20,000 USD for a wedding ring, because Ms. Han wrote “Even if we cannot get married, you must buy me a wedding ring”;

d) $400,000 USD to purchase a home for the mother and child.

[19] On June 19, 2018, Ms. Han gave birth to a daughter in Richmond, B.C.

[20] On September 17, 2018, Mr. Dorje wrote, ”Taking care of her and you are my duty for life”.

[21] Ms. Han’s expectation was that the parties would live together in the future. She says they planned to live together. Those plans evolved over time. Initially they involved purchasing a property in Toronto, so that Mr. Dorje could visit when he was in New York. They also discussed purchasing property in Calgary or renting a home in Vancouver for that purpose. Ms. Han eventually purchased a condominium in Richmond using funds provided by Mr. Dorje.

[22] Ms. Han deposes that the parties made plans for Mr. Dorje to visit her and meet the child in Richmond. In October 2018, however, Mr. Dorje wrote that he needed to “disappear” to Europe. He wrote:

I will definitely find a way to meet her

And you

Remember to take care of yourself if something happens

[23] The final plan the parties discussed, according to Ms. Han, was that Mr. Dorje would sponsor Ms. Han and the child to immigrate to the United States and live at the Kagyu retreat centre in New York State.

[24] In January 2019, Ms. Han lost contact with Mr. Dorje.

[25] Ms. Han commenced this family law case on July 17, 2019, seeking child support, a declaration of parentage and a parentage test. She did not seek spousal support.

[26] Ms. Han first proposed a claim for spousal support in October 2020 after a change in her counsel. Following an exchange of correspondence concerning an application for leave to amend the notice of family claim, Ms. Han’s counsel wrote that Ms. Han would not be advancing a spousal support claim. On March 16, 2020, counsel reversed course, and advised that Ms. Han had instructed him to proceed with the application.

[27] When this application came on before me, the trial was set to commence on June 7, 2021. The parties were still in the process of discoveries and obtaining translations for hundreds of pages of documents in Chinese characters.

[28] At a trial management conference on May 6, 2021, noting the parties were not ready to proceed, Madam Justice Walkem adjourned the trial to April 11, 2022.

ANALYSIS
A. The Spousal Support Claim in this Case
[29] To claim spousal support in this case, Ms. Han must plead that she lived with Mr. Dorje in a marriage-like relationship. This is because only “spouses” are entitled to spousal support, and s. 3 of the Family Law Act defines a spouse as a person who is married or has lived with another person in a marriage-like relationship:

3 (1) A person is a spouse for the purposes of this Act if the person

(a) is married to another person, or

(b) has lived with another person in a marriage-like relationship, and

(i) has done so for a continuous period of at least 2 years, or

(ii) except in Parts 5 [Property Division] and 6 [Pension Division], has a child with the other person.

[30] Because she alleges she has a child with Mr. Dorje, Ms. Han need not allege that the relationship endured for a continuous period of two years to claim spousal support; but she must allege that she lived in a marriage-like relationship with him at some point in time. Accordingly, she must amend the notice of family claim.

B. The Test to Amend Pleadings
[31] Given that the notice of trial has been served, Ms. Han requires leave of the court to amend the notice of family claim: Supreme Court Family Rule 8-1(1)(b)(i).

[32] A person seeking to amend a notice of family claim must show that there is a reasonable cause of action. This is a low threshold. What the applicant needs to establish is that, if the facts pleaded are proven at trial, they would support a reasonable claim. The applicant’s allegations of fact are assumed to be true for the purposes of this analysis. Cantelon v. Wall, 2015 BCSC 813, at para. 7-8.

[33] The applicant’s delay, the reasons for the delay, and the prejudice to the responding party are also relevant factors. The ultimate consideration is whether it would be just and convenient to allow the amendment. Cantelon, at para. 6, citing Teal Cedar Products Ltd. v. Dale Intermediaries Ltd. et al (1986), 19 B.C.L.R. (3d) 282.

C. Pleadings in Family Law Cases
[34] Supreme Court Family Rules 3-1(1) and 4-1(1) require that a claim to spousal support be pleaded in a notice of family claim in Form F3. Section 2 of Form F3, “Spousal relationship history”, requires a spousal support claimant to check the boxes that apply to them, according to whether they are or have been married or are or have been in a marriage-like relationship. Where a claimant alleges a marriage-like relationship, Form F3 requires that they provide the date on which they began to live together with the respondent in a marriage-like relationship and, where applicable, the date on which they separated. Form F3 does not require a statement of the factual basis for the claim of spousal support.

[35] In this case, Ms. Han seeks to amend the notice of family claim to allege that she and Mr. Dorje began to live in a marriage-like relationship in or around January 2018, and separated in or around January 2019.

[36] An allegation that a person lived with a claimant in a marriage-like relationship is a conclusion of law, not an allegation of fact. Unlike the rules governing pleadings in civil actions, however, the Supreme Court Family Rules do not expressly require family law claimants to plead the material facts in support of conclusions of law.

[37] In other words, there is no express requirement in the Supreme Court Family Rules that Ms. Han plead the facts on which she relies for the allegation she and Mr. Dorje lived in a marriage-like relationship.

[38] Rule 4-6 authorizes a party to demand particulars, and then apply to the court for an order for further and better particulars, of a matter stated in a pleading. However, unless and until she is granted leave and files the proposed amended notice of family claim, Ms. Han’s allegation of a marriage-like relationship is not a matter stated in a pleading.

[39] Ms. Han filed an affidavit in support of her application to amend the notice of family claim. Normally, evidence would not be required or admissible on an application to amend a pleading. However, in the unusual circumstances of this case, the parties agreed I may look to Ms. Han’s affidavit and exhibits for the facts she pleads in support of the allegation of a marriage-like relationship.

[40] Because this is an application to amend - and Ms. Han’s allegations of fact are presumed to be true - I have not considered Mr. Dorje’s responding affidavit.

[41] Relying on affidavit evidence for an application to amend pleadings is less than ideal. It tends to merge and confuse the material facts with the evidence that would be relied on to prove those facts. In a number of places in her affidavit, for example, Ms. Han describes her feelings, impressions and understandings. A person’s hopes and intentions are not normally material facts unless they are mutual or reasonably held. The facts on which Ms. Han alleges she and Mr. Dorje formed a marriage-like relationship are more important for the present purposes than her belief they entered into a conjugal union.

[42] Somewhat unusually, in this case, almost all of the parties’ relevant communications were in writing. This makes it somewhat easier to separate the facts from the evidence; however, as stated above, it is difficult to understand the intentions and actions of a person from brief text messages.

[43] In my view, it would be a good practice for applicants who seek to amend their pleadings in family law cases to provide opposing counsel and the court with a schedule of the material facts on which they rely for the proposed amendment.

D. The Legal Concept of a Marriage-Like Relationship
[44] As Mr. Justice Myers observed in Mother 1 v. Solus Trust Company, 2019 BCSC 200, the concept of a marriage-like relationship is elastic and difficult to define. This elasticity is illustrated by the following passage from Yakiwchuk v. Oaks, 2003 SKQB 124, quoted by Myers J. at para. 133 of Mother 1:

[10] Spousal relationships are many and varied. Individuals in spousal relationships, whether they are married or not, structure their relationships differently. In some relationships there is a complete blending of finances and property - in others, spouses keep their property and finances totally separate and in still others one spouse may totally control those aspects of the relationship with the other spouse having little or no knowledge or input. For some couples, sexual relations are very important - for others, that aspect may take a back seat to companionship. Some spouses do not share the same bed. There may be a variety of reasons for this such as health or personal choice. Some people are affectionate and demonstrative. They show their feelings for their “spouse” by holding hands, touching and kissing in public. Other individuals are not demonstrative and do not engage in public displays of affection. Some “spouses” do everything together - others do nothing together. Some “spouses” vacation together and some spend their holidays apart. Some “spouses” have children - others do not. It is this variation in the way human beings structure their relationships that make the determination of when a “spousal relationship” exists difficult to determine. With married couples, the relationship is easy to establish. The marriage ceremony is a public declaration of their commitment and intent. Relationships outside marriage are much more difficult to ascertain. Rarely is there any type of “public” declaration of intent. Often people begin cohabiting with little forethought or planning. Their motivation is often nothing more than wanting to “be together”. Some individuals have chosen to enter relationships outside marriage because they did not want the legal obligations imposed by that status. Some individuals have simply given no thought as to how their relationship would operate. Often the date when the cohabitation actually began is blurred because people “ease into” situations, spending more and more time together. Agreements between people verifying when their relationship began and how it will operate often do not exist.

[45] In Mother 1, Mr. Justice Myers referred to a list of 22 factors grouped into seven categories, from Maldowich v. Penttinen, (1980), 17 R.F.L. (2d) 376 (Ont. Dist. Ct.), that have frequently been cited in this and other courts for the purpose of determining whether a relationship was marriage-like, at para. 134 of Mother 1:

1. Shelter:

(a) Did the parties live under the same roof?

(b) What were the sleeping arrangements?

(c) Did anyone else occupy or share the available accommodation?

2. Sexual and Personal Behaviour:

(a) Did the parties have sexual relations? If not, why not?

(b) Did they maintain an attitude of fidelity to each other?

(c) What were their feelings toward each other?

(d) Did they communicate on a personal level?

(e) Did they eat their meals together?

(f) What, if anything, did they do to assist each other with problems or during illness?

(g) Did they buy gifts for each other on special occasions?

3. Services:

What was the conduct and habit of the parties in relation to:

(a) preparation of meals;

(b) washing and mending clothes;

(c) shopping;

(d) household maintenance; and

(e) any other domestic services?

4. Social:

(a) Did they participate together or separately in neighbourhood and community activities?

(b) What was the relationship and conduct of each of them toward members of their respective families and how did such families behave towards the parties?

5. Societal:

What was the attitude and conduct of the community toward each of them and as a couple?

6. Support (economic):

(a) What were the financial arrangements between the parties regarding the provision of or contribution toward the necessaries of life (food, clothing, shelter, recreation, etc.)?

(b) What were the arrangements concerning the acquisition and ownership of property?

(c) Was there any special financial arrangement between them which both agreed would be determinant of their overall relationship?

7. Children:

What was the attitude and conduct of the parties concerning children?

[46] In Austin v. Goerz, 2007 BCCA 586, the Court of Appeal cautioned against a “checklist approach”; rather, a court should "holistically" examine all the relevant factors. Cases like Molodowich provide helpful indicators of the sorts of behaviour that society associates with a marital relationship, the Court of Appeal said; however, “the presence or absence of any particular factor cannot be determinative of whether a relationship is marriage-like” (para. 58).

[47] In Weber v. Leclerc, 2015 BCCA 492, the Court of Appeal again affirmed that there is no checklist of characteristics that will be found in all marriages and then concluded with respect to evidence of intentions:

[23] The parties’ intentions – particularly the expectation that the relationship will be of lengthy, indeterminate duration – may be of importance in determining whether a relationship is “marriage-like”. While the court will consider the evidence expressly describing the parties’ intentions during the relationship, it will also test that evidence by considering whether the objective evidence is consonant with those intentions.

[24] The question of whether a relationship is “marriage-like” will also typically depend on more than just their intentions. Objective evidence of the parties’ lifestyle and interactions will also provide direct guidance on the question of whether the relationship was “marriage-like”.

[48] Significantly for this case, the courts have looked to mutual intent in order to find a marriage-like relationship. See, for example, L.E. v. D.J., 2011 BCSC 671 and Buell v. Unger, 2011 BCSC 35; Davey Estate v. Gruyaert, 2005 CarswellBC 3456 at 13 and 35.

[49] In Mother 1, Myers J. concluded his analysis of the law with the following learned comment:

[143] Having canvassed the law relating to the nature of a marriage-like relationship, I will digress to point out the problematic nature of the concept. It may be apparent from the above that determining whether a marriage-like relationship exists sometimes seems like sand running through one's fingers. Simply put, a marriage-like relationship is akin to a marriage without the formality of a marriage. But as the cases mentioned above have noted, people treat their marriages differently and have different conceptions of what marriage entails.

[50] In short, the determination of whether the parties in this case lived in a marriage-like relationship is a fact-specific inquiry that a trial judge would need to make on a “holistic” basis, having regard to all of the evidence. While the trial judge may consider the various factors listed in the authorities, those factors would not be treated as a checklist and no single factor or category of factors would be treated as being decisive.

E. Is There a Reasonable Claim of a Marriage-Like Relationship?
[51] In this case, many of the Molodowich factors are missing:

a) The parties never lived under the same roof. They never slept together. They were never in the same place at the same time during the relationship. The last time they saw each other in person was in November 2017, before the relationship began.

b) The parties never had consensual sex. They did not hug, kiss or hold hands. With the exception of the alleged sexual assault, they never touched one another physically.

c) The parties expressed care and affection for one another, but they rarely shared personal information or interest in their lives outside of their direct topic of communication. They did not write about their families, their friends, their religious beliefs or their work.

d) They expressed concern and support for one another when the other felt unwell or experienced health issues, but they did not provide any care or assistance during illness or other problems.

e) They did not assist one another with domestic chores.

f) They did not share their relationship with their peers or their community. There is no allegation, for example, that Mr. Dorje told his fellow monks or any of his followers about the relationship. There is no allegation that Ms. Han told her friends or any co-workers. Indeed, there is no allegation that anyone, with the exception of Ms. Han’s mother, knew about the relationship. Although Mr. Dorje gave Ms. Han’s mother a gift, he never met the mother and he never spoke to her.

g) They did not intend to have a child together. The child was conceived as a result of a sexual assault. While Mr. Dorje expressed interest in “meeting” the child, he never followed up. He currently has no relationship with the child. There is no allegation he has sought access or parenting arrangements.

[52] The only Molodowich factor of any real relevance in this case is economic support. Mr. Dorje provided the funds with which Ms. Han purchased a condominium. Mr. Dorje initially wrote that he wanted to buy a property with the money, but, he wrote, “It’s the same thing if you buy [it]”.

[53] Mr. Dorje also provided a significant amount of money for Ms. Han’s postpartum care and the child’s first year of life.

[54] This financial support may have been primarily for the benefit of the child. Even the condominium, Ms. Han wrote, was primarily for the benefit of the child.

[55] However, in my view, a trial judge may attach a broader significance to the financial support from Mr. Dorje than child support alone. A trial judge may find that the money Mr. Dorje provided to Ms. Han at her request was an expression of his commitment to her in circumstances in which he could not commit physically. The money and the gifts may be seen by the trial judge to have been a form of down payment by Mr. Dorje on a promise of continued emotional and financial support for Ms. Han, or, in Mr. Dorje’s own words, “Taking care of her and you are my duty for life” (emphasis added).

[56] On the other hand, I find it difficult to attach any particular significance to the fact that Mr. Dorje agreed to provide funds for Ms. Han to purchase a wedding ring. It appears to me that Ms. Han demanded that Mr. Dorje buy her a wedding ring, not that the ring had any mutual meaning to the parties as a marriage symbol. But it is relevant, in my view, that Mr. Dorje provided $20,000 USD to Ms. Han for something she wanted that was of no benefit to the child.

[57] Further, Ms. Han alleges that the parties intended to live together. At a minimum, a trial judge may find that the discussions about where Ms. Han and the child would live reflected a mutual intention of the parties to see one another and spend time together when they could.

[58] Mr. Dorje argues that an intention to live together at some point in the future is not sufficient to show that an existing relationship was marriage-like. He argues that the question of whether the relationship was marriage-like requires more than just intentions, citing Weber, supra.

[59] In my view, the documentary evidence referred to above provides some objective evidence in this case that the parties progressed beyond mere intentions. As stated, the parties appear to have expressed genuine care and affection for one another. They appear to have discussed marriage, trust, honesty, finances, mutual obligations and acquiring family property. These are not matters one would expect Mr. Dorje to discuss with a friend or a follower, or even with the mother of his child, without a marriage-like element of the relationship.

[60] A trial judge may find on the facts alleged by Ms. Han that the parties loved one another and would have lived together, but were unable to do so because of Mr. Dorje’s religious duties and nomadic lifestyle.

[61] The question I raised in the introduction to these reasons is whether a relationship that began on-line and never moved into the physical world can be marriage-like.

[62] Notably, the definition of a spouse in the Family Law Act does not require that the parties live together, only that they live with another person in a marriage-like relationship.

[63] In Connor Estate, 2017 BCSC 978, Mr. Justice Kent found that a couple that maintained two entirely separate households and never lived under the same roof formed a marriage-like relationship. (Connor Estate was decided under the intestacy provisions of the Wills, Estates and Succession Act, S.B.C. 2009, c. 13 ("WESA"), but courts have relied on cases decided under WESA and the FLA interchangeably for their definitions of a spouse.) Mr. Justice Kent found:

[50] The evidence is overwhelming and I find as a fact that Mr. Chambers and Ms. Connor loved and cared deeply about each other, and that they had a loving and intimate relationship for over 20 years that was far more than mere friendship or even so-called "friendship with benefits". I accept Mr. Chambers' evidence that he would have liked to share a home with Ms. Connor after the separation from his wife, but was unable to do so because of Ms. Connor's hoarding illness. The evidence amply supports, and I find as a fact, that Mr. Chambers and Ms. Connor loved each other, were faithful to each other, communicated with each other almost every day when they were not together, considered themselves to be (and presented themselves to be) "husband and wife" and were accepted by all who knew them as a couple.

[64] Connor Estate may be distinguishable from this case because Mr. Chambers and Ms. Connor were physically intimate for over 20 years, and presented themselves to the world as a married couple.

[65] Other decisions in which a marriage-like relationship has been found to exist despite the parties not living together have involved circumstances in which the couple lived under the same roof at previous points in the relationship, and the issue was whether they continued to be spouses after they took up separate residences: in Thompson v. Floyd, 2001 BCCA 78, the parties had lived together for a period of at least 11 years; in Roach v. Dutra, 2010 BCCA 264, the parties had lived together for approximately three years.

[66] However, as Mr. Justice Kent noted in Connor Estate:

[48] … [W]hile much guidance might be found in this case law, the simple fact is that no two cases are identical (and indeed they usually vary widely) and it is the assessment of evidence as a whole in this particular case which matters.

[67] Mr. Justice Kent concluded:

[53] Like human beings themselves, marriage-like relationships can come in many and various shapes. In this particular case, I have no doubt that such a relationship existed …

[68] As stated, Ms. Han’s claim is novel. It may even be weak. Almost all of the traditional factors are missing. The fact that Ms. Han and Mr. Dorje never lived under the same roof, never shared a bed and never even spent time together in person will militate against a finding they lived with one another in a marriage-like relationship. However, the traditional factors are not a mandatory check-list that confines the “elastic” concept of a marriage-like relationship. And if the COVID pandemic has taught us nothing else, it is that real relationships can form, blossom and end in virtual worlds.

[69] In my view, the merits of Ms. Han’s claim should be decided on the evidence. Subject to an overriding prejudice to Mr. Dorje, she should have leave to amend the notice of family claim. However, she should also provide meaningful particulars of the alleged marriage-like relationship.

F. Delay / Prejudice
[70] Ms. Han filed her notice of family claim on July 17, 2019. She brought this application to amend approximately one year and nine months after she filed the pleading, just over two months before the original trial date.

[71] Ms. Han’s delay was made all that more remarkable by her change in position from January 19, 2021, when she confirmed, through counsel, that she was not seeking spousal support in this case.

[72] Ms. Han gave notice of her intention to proceed with this application to Mr. Dorje on March 16, 2021. By the time the application was heard, the parties had conducted examinations for discovery without covering the issues that would arise from a claim of spousal support.

[73] Also, in April, Ms. Han produced additional documents, primarily text messages, that may be relevant to her claim of spousal support, but were undecipherable to counsel for Mr. Dorje, who does not read Mandarin.

[74] This application proceeded largely on documents selected and translated by counsel for Ms. Han. I was informed that Mandarin translations of the full materials would take 150 days.

[75] Understandably in the circumstances, Mr. Dorje argued that an amendment two months before trial would be neither just nor convenient. He argued that he would be prejudiced by an adjournment so as to allow Ms. Han to advance a late claim of spousal support.

[76] The circumstances changed on May 6, 2021, when Madam Justice Walkem adjourned the trial to July 2022 and reset it for 25 days. Madam Justice Walkem noted that most of the witnesses live internationally and require translators. She also noted that paternity may be in issue, and Mr. Dorje may amend his pleadings to raise that issue. It seems clear that, altogether apart from the potential spousal support claim, the parties were not ready to proceed to trial on June 7, 2021.

[77] In my view, any remaining prejudice to Mr. Dorje is outweighed by the importance of having all of the issues between the parties decided on their merits.

[78] Ms. Han’s delay and changes of position on spousal support may be a matter to de addressed in a future order of costs; but they are not grounds on which to deny her leave to amend the notice of family claim.

CONCLUSION
[79] Ms. Han is granted leave to amend her notice of family claim in the form attached as Appendix A to the notice of application to include a claim for spousal support.

[80] Within 21 days, or such other deadline as the parties may agree, Ms. Han must provide particulars of the marriage-like relationship alleged in the amended notice of family claim.

[81] Ms. Han is entitled to costs of this application in the cause of the spousal support claim.

“Master Elwood”

今日はSEKAI NO OWARIの「サザンカ」を英語で歌ってみました。
サザンカの花言葉は「困難に打ち克つ」と「ひたむきさ」みたいです。
とてもいいメッセージの曲ですね♪ Enjoy!

～♪～♪～♪～♪～♪～
曲情報 / SONG INFO
～♪～♪～♪～♪～♪～

SEKAI NO OWARI／サザンカ
2018年リリース
作詞： Saori、Fukase
作曲：Nakajin、Fukase
英語詞：渡辺レベッカ

～♪～♪～♪～♪～♪～
リンク / LINKS
～♪～♪～♪～♪～♪～

■HP⇒ http://BlueEyedUtaUtai.jimdo.com
■Facebook⇒ http://facebook.com/blueeyedutautai
■Twitter⇒ @BlueEyedUtaUtai

～♪～♪～♪～♪～♪～
歌詞／LYRICS
～♪～♪～♪～♪～♪～

There’s the sound of your shutting door
As you hole up again inside
A calendar marked to the brim
And your frustrated cries

You’ve always said you’d rather chase
Your dreams than run and hide
It’s not as scary as tossing them aside

When your effort isn’t paying off
And you start to doubt your worth
I know when you lash out at me
You’re taking out your hurt

You say if you were to give up now
It’d be such a waste
Of everything that you’ve been working for
As tears fall down your face

Dear little dream chaser
If you should stumble, just remember what they say
That the heroes of the best stories
Are always laughed at by everyone they overtake
And I don’t think that you’re the laughing kind
You’ll always be the hero in my eyes

You have fallen more than anyone
And you have cried more tears than most
You’ve gotten back up on your feet
More than anyone I know

And I have seen you for myself
In the moments when you shine
I’ve seen you running with all your heart
Toward the finish line

Dear little dream chaser
When you’re discouraged, don’t you give in to defeat
Just remember that the story goes on
As long as the hero is standing on his feet
So keep on standing up for what you believe

If you wonder why I’m crying
These are not sad tears, but tears of joy for you
For I’ve stood beside you all the way
And I’ve seen how hard you worked to make it through

夢を追う君へ
yume wo ou kimi e
思い出して　つまずいたなら
omoidashite tsumazuita nara
いつだって物語の
itsu datte monogatari no
主人公は笑われる方だ
shujinkou wa warawareru hou da
人を笑う方じゃない
hito wo waru hou ja nai
君ならきっと
kimi nara kitto

《Scary》
Lyrics/composed by T.L
Arranged by T.L
Mixing and Mastering by T.L
Cover Picture & Filmed by ATO

Too many knives, scary
Too many guns, scary 
Too many blood, scary
Too many deaths, scary

Too many dreams, scary
Too many schemes, scary
Too many frauds, scary
Too many truths, scary

Fuck the society, 
去他的這個社會
Fools us entirely
完全欺騙了我們
Sometimes I want to ask myself 
讓我有時候想問自己
Did you get the right anxiety?
你的心病是不是應得的
When I’m feeling lost and when I’m deeply in need當我迷失自我且急需援助的時候
Who comes to defrost my feet and try to enlighten me
誰又會來啟發我, 幫助我邁向前方
I still remember the vibe went pumping, flowing in my vein還記得那時候獨特的氛圍與感覺在體內流串
Nothing could hold me to the ground, felt like I was running in the rain沒有什麼事情能阻擋我 感覺像在暴雨中狂奔
Play the "demon mode", watch me wreck the game again
所謂的"惡魔模式", 不過也就這麼簡單吧
but the hard-knock life keeps on driving me insane
但是這艱難的人生不斷嘗試把我逼瘋
Bottoms up! Down the Kool-Aid then follow the track乾掉吧, 喝完之後就跟著那道路走下去
Hunnids out, due in two days, behind your back 
把錢拿出來吧, 準備要來催了
From the top of this play, been doing different act 即使開始到現在我都獨立自行
Don’t be a bad boy, its gon hunt you down Your better cover your breath!
小心牠要來了, 別當個壞小孩, 最好憋住你的氣息

Too many knives, scary
Too many guns, scary 
Too many blood, scary
Too many deaths, scary

Too many dreams, scary
Too many schemes, scary
Too many frauds, scary
Too many truths, scary

Let’s play a game,我們來玩個遊戲
Pick truth or dare 
選真心話還是大冒險
Holding the fame, 
手裡握著那些名利
I doubt that you wanna play fair 
你最好會想公平的玩這場遊戲
One step, two steps, stumble down the stairs 
一步兩步, 蹣跚的走下階梯
1k, 2k, who doesn’t wanna care
1k, 2k, 有這些誰會不在乎呢?
Taking a drag of that smoke
吸了一口煙
Still got a long way to go 
前面還有很長的道路要走
Consciousness to be evoked
我與我等著被喚醒的意識
Hoes, maybe one day I’ll float
也許有一天我也能夠漂浮
Hold on, hold on, hold on
不過先等等
Dope, everybody wants a piece of gold
大家都想要得到分一杯羹
what does it take, no, he don’t know!!
但是要付出的代價是什麼, 他才不知道！
Sick of being told it’s forbidden 受夠了被限制這個限制那個
Nothing matters bro, I’m independent
我是一個獨立的個體, 你管不了我
Who do I dance against in the phantom
獨自在黑暗裡跳著舞
With the dark souls, yeah, we the Venom
與暗影一同生存著, 我們是Venom
No ape shit, no bape hit, with the L on the way, just take it
沒有讓我一步登天的機運與事情, 一路以來跟隨著失敗吸取教訓
If you have to, just fake it
有必要的話, 裝吧, 裝的自信點吧
until you make it, until your bank leaks
直到你成功, 直到你帳戶爆表吧！

Too many knives, scary
Too many guns, scary 
Too many blood, scary
Too many deaths, scary

Too many dreams, scary
Too many schemes, scary
Too many frauds, scary
Too many truths, scary

Don’t be terrified

こんばんは！Happy Friday!
English is below as usual!

うちでは、先程ムービーナイトが終わり、明日アレックスのBirthday Disney Seaを楽しみにしています♪もし、他にDisney Seaに行かれる方がいらっしゃれば、見かけたら是非声をかけてください！

今日は、大分昔から作りたかった動画をアップしています。アメリカでHummus（ハマス）はよーく食べます。簡単にいうと、オリーブオイルとひよこ豆、練りごまのディップです。でも、私は妊娠しているので、もう少し健康要素を加えたくて、アボカドバージョンを作ってみました。タカと私の大好きなレストランで出ていたメニューです。そのレストランでいつも食べていたのですが、そのお店が去年閉店して、「あのハマスは二度も食べれないんだ…」と思ったら、あまりにも悲しすぎたので、このレシピを作ってみました。材料の量のバランスが非常に難しかったので、時間がかかりましたが、完成できたので、是非ご紹介したいと思います。

ひよこ豆とアボカドが入っているので、非常に体によくて、妊婦さんにも是非オススメです。一度にかなりの量が作れるので、うちの場合は、
・ 朝ごはん（トーストにかける）
・ 夜のおやつ（野菜スティックと一緒に）
・ サンドイッチの味付
として使っています。よかったら、作ってみて、How was itを教えてくださいね。Well, see you next time!!!

レシピ
■材料
70gmねりごま
お水：大さじ5杯　
レモン汁：大さじ3杯　
オリーブオイル：大さじ5杯
塩：小さじ1杯
にんにく：1/2かけ（刻む）
クミン：小さじ1/2杯
ひよこ豆：1缶（240g）
アボカド：1個

※お水とレモン汁、オリーブオイル、塩は、少しずつ入れるので、下記の「作り方」をご覧ください。


■ 作り方
① 下記のAとBをミキサーに入れてください。１分ほどミクサーにかける。
② Cを加えてミキサーにかけながら、Dを少しずつ入れる。２分ミキサーにかける。
③ Eを入れて、最も強い設定で５分ほどミキサーにかける。
④ Fを入れて、最も強い設定でクリーミーになるまでミキサーにかける（５分ほど）。1分毎にミキサーをあけて（とめてから）軽く混ぜる。
⑤ Fだけで完全にクリーミーにならないので、最後にGを入れて改めてミキサーにかけると、かなりクリーミーになる。1分毎にミキサーをあけて（とめてから）軽く混ぜる。

《A》70gmねりごま
《B》
オリーブオイル　大さじ2杯
レモン汁　　　　大さじ2杯
お水　　　　　　大さじ3杯
《C》
クミン　小さじ1/2杯
塩　　　小さじ1/2杯
にんにく　1/2かけ（刻む）
《D》　オリーブオイル　大さじ1杯
《E》
ひよこ豆　半分
アボカド　半分
《F》
ひよこ豆　半分
アボカド　半分
《G》
お水　　　　　　大さじ2杯
レモン汁　　　　大さじ1杯
オリーブオイル　大さじ2杯
塩　　　　　　　小さじ1/2杯


Happy Friday everyone!
We just finished our movie night here at home. Alex is now tucked away in his bed, no doubt dreaming of Disney Sea which is where we’ll be going tomorrow! If anybody happens to be at Disney Sea and you happen to see us, please say hi!

I have been wanting to post a video about hummus here on this channel now for such a long time. In America we eat hummus A LOT, but I was surprised at how nobody knows about it in Japan. Since hummus is basically just chickpeas, olive oil and tahini, it’s quite healthy! Since I’m pregnant, I decided to add a little bit more nutritional value by adding avocado. Actually one of the favorite restaurants in Futakotamagawa used to serve a dish just like this. However, they closed down last year. When I heard they were no longer in business I distinctly remember feeling sad that I’d never be able to taste that avocado hummus again. So I got started working on my own version. It took quite a while to make (the balance of the ingredients is tricky) but I think I got it down now. Please do try it at home and let me know what you think. The recipe is below!


RECIPE

■Ingredients
70gm tahini
Water: 5 tbl　
Lemon: 3 tbl　
Extra virgin olive oil: 5 tbl
Salt: 1 tsp
Garlic: 1 clove cut into small pieces
Cumin: 1/2 tsp
Chickpeas: 1 can (240 g)
Avocado: 1

The water, lemon, olive oil and salt get added in parts, so please be sure to read the recipe below.


■ RECIPE
① Add A (from below) and B to a blender and blend for one minute.
② Add C and blend. With the motor running, gradually add D.
③ Add E and blend on the strongest setting your blender has.
④ Add F and blend on the strongest setting your blender has until everything is blended through (5 minutes). You can stop the blender and stir every minute or so just to make sure everything is getting blended right.
⑤ Since F alone will not make this creamy enough, lastly you’ll want to add the ingredients from G and blend until creamy. Again, you can stop the blender and stir every minute or so just to make sure everything is getting blended right.

《A》70gm Tahini
《B》
Olive Oil: 2tbl
Lemon: 2 tbl
Water: 3 tbl
《C》
Cumin: 1/2 tsp
Salt: 1/2 tsp
Garlic: 1/2 clove (chopped up)
《D》　Olive oil: 1 tbl
《E》
Chickpeas: half
Avocado: half
《F》
Chickpeas: half
Avocado: half
《G》
Water: 2 tbl
Lemon: 1 tbl
Olive Oil: 2 tbl
Salt: 1/2 tsp


《MUSIC》
Acoustic Circles
Entire
Mr. Tea
Mysteries


【このチャンネルについて】
子育てしている日本のママとパパたちへ！
「英語を子供に教えたいけど、どうすればいいのかわからない」と多くの日本人のママ友によーーく言われます。

私は、アメリカ人ママです。アイシャともうします。息子は2015年3月2日に生まれたアレックス君です。アレックスが大人になって、一番なってほしいことは「英語ペラペラ」ではなく、「グローバルな視野」を持っている人になってほしいです。ルールのない世界で、どの問題や壁にぶつかっても、クリエーティブ的に考えてほしいし、恥ずかがらないでどんなチャレンジを積極的に受け入れてほしいです。英語はもちろんできるだけ教えようとは思いますが、それが全てではないし、どちらかというと「楽しく英語に接触させながら、面白い世界（もうはや壁のない世界）を見せたいと思います。」

このチャンネルには、子供に教えれる英語ビデオもアップしますし、外国の育児方法や想像力とコミュニケーション力を伸ばすゲームについてのビデオもたくさん投稿したいと思います。

日本の子育て　VS　外国の子育て方針についてもビデオを投稿したいと思います。

では、楽しく子供と英会話しながら、世界の子育てなどについて一緒に学びましょう♪