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A Sex Worker Can Sue Her Client To Recover Her Fees

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The Canadian court has made an exceptional ruling that a sex worker can sue her client to recover her unpaid fees.

This ruling of the court squashed the old rule which used to be that the court would not be used to enforce an illegal contract; a contract between a sex worker and her client is seen as an illegal contract and also repugnant to public policy which can not be enforced in the court of law but in this recent case of Brogan Leigh Sheehan v.Bradley Samuelson (2023 NSSM 27 CanLII) decided in April 2023 the Canadian court in the primary issue tabled before them which was “Can a sex worker sue to recover unpaid fees from a client”, The judge in its obiter dictum while ruling in favor of the claimant (the sex worker) stated thus; “for the reasons outlined below, based on the facts as I find them, I have concluded the answer is ‘yes’, that a sex worker can sue her client to recover her unpaid fees”. 

What happened in this case was that a sex worker was contracted by a horny man to come and keep him company and “service him”. During their negotiation, the sex worker told the man that she charges per hour. They agreed on a price and the man sent the woman his location for the woman to meet him up. They ended up spending seven hours together, during which they had different kinds of sex multiple times. 

When the lady was about to leave, she demanded payment for the seven hours she spent with the man. The man claimed that he was having issues making the payment at that time to the lady and that the lady should go, promising he would sort out the payment much later. The woman left and waited for her fee. Much time passed and the man didn’t pay the lady, hence the lady decided to take the matter to court. 

In court, the man’s defense was that the contract between him and the lady was an illegal contract since prostitution or hook-up is a criminal act and any contract to engage in a criminal act such as “hookup”, can not be enforceable in court. The man prayed the court to strike out the matter since it was below the jurisdiction of the court to sit on such a matter. The Claimant on the other hand argued that the law on enforceability of illegal contracts has evolved and there are many exceptions to the old rule that illegal contracts were void ab initio. This means that in effect the court can make an exception and hear a purportedly illegal contract and decide it on its merit. 

After listening to both arguments, the court held that the claimant who is a sex worker is entitled to recover her fee and the accruing interest from the man. 

This decision has therefore set the new judicial precedent in Canada that a sex worker can sue her client to recover her unpaid fees.

Regulatory Guidelines For Chemicals and Chemical Products in Nigeria

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The objective of the regulatory framework governing Chemical Good Manufacturing Practice (GMP) guidelines as issued by the National Agency For Food and Drug Administration and Control (NAFDAC) is to ensure that products are consistently manufactured in conformance with quality standard. It is concerned with all aspects of production and quality control.

These guidelines are for the manufacture, storage, distribution and shipment of chemicals and chemical products in Nigeria.

It is necessary to emphasize that, no chemical products shall be Manufactured, Exported, Advertised, Sold or Distributed in Nigeria unless it has been registered in accordance with the provisions of the Food, Drugs and Related Products Act Cap F33 LFN 2004 (formerly decree 19 of 1993) and the accompanying guidelines. The provisions of these guidelines regarding chemicals and chemical products are what will constitute the focus of this article.

What are the general considerations highlighted by the NAFDAC guidelines on chemicals?

In the manufacture of chemicals and chemical products, monitoring is essential in ensuring that products of quality standards are produced.

Provisions of the guidelines on personnel 

-There should be adequate number of personnel with adequate knowledge, experience, skill and capabilities relevant to their assigned function. They should be in good health and capable of handling the duties assigned to them.

Provisions of the guidelines on organization, qualification and responsibilities 

-The organizational structure of the company shall be such that different persons head the production and quality control sections, neither of which shall be responsible to the other. 

-The key officers should have a minimum qualification of BSc or equivalent in Chemistry/Chemical Engineering or any related science disciplines.

-The head of production should be adequately trained, experienced and qualify in chemical manufacturing. He/she should have authority and responsibilities to manage production; covering operations, equipment, production personnel, production areas and records.

-The head of quality control should be adequately trained and experienced in the area ofquality control. He should have full authority and responsibility in all quality control duties such as establishment, verification and implementation of all quality control procedures. He should also have the authority to designate/assign when appropriate,personnel, to approve starting materials, intermediates, bulk and finished products that meet specification or to reject those which do not conform or not manufactured in accordance with approved procedures.

-The responsibilities and authorities of key personnel should be clearly defined.

Training

-All personnel directly involved in manufacturing activities should be appropriately and continuously trained in manufacturing operations in accordance with GMP principles. Special attention should be given to training of personnel working with hazardous materials.

-Records of training should be maintained and its effectiveness assessed periodically.

Premises

-The premises for manufacturing should be suitably located, designed, constructed and maintained.

-Effective technical and administrative measures should be taken to avoid any cross contamination to the environmentand the production facility.

-Appropriate changing rooms and toilet facilities should be provided.

-Defined areas should be provided for, wherever possible and applicable:-

a).Materials receiving bay

b). Material Sampling

c).Incoming goods and quarantine.

d).Starting materials storage.

e).Weighing and dispensing.

f). Processing.

g). Storage of bulk products.

h). Packaging

i). Quarantine storage before final release of products.

j). Storage of finished products.

k).Loading and unloading.

l). Laboratories.

m).Equipment washing.

-Walls and floors, where applicable should be smooth and easy to maintain. The floor in processing areas should be industrial concrete floor with surface that is easy to clean.

-Drains should be of adequate size and have trapped gullies and proper flow. Open channels should be avoided where possible, but if required they should be able to facilitate cleaning and disinfection.

-Buildings should be adequately lit and properly ventilated.

-Pipework, light fittings, ventilation points and otherservice points in manufacturing areas should be installed in such a way to make for easy cleaning.

-Laboratories should be separated from the production areas. The premises for manufacturing should be suitably located, designed, constructed and maintained.

Storage Areas

-Storage areas should be of sufficient capacity to allow orderly placement of materials such as starting and packaging materials, intermediates, bulk and finished products, products in quarantine, released, rejected, returned, or recalled products.

-Secured segregated area should be available for storage of chemicals of safety and security concerns.

-Storage areas should have good storage conditions. Where special storage conditions are required (temperature, humidity and security) these should be provided, checked and monitored

Provisions of guidelines on Equipment

Constructions and Design

-Equipment should be designed and constructed to suit production of the product.

-The equipment surfaces in contact with any in-process material should not react with or adsorb the materials being processed.

-Equipment should not adversely affect the product through leaking valves, lubricant drips and inappropriate modifications or adaptations.

-Equipment should be easily cleaned.

-Equipment used for flammable substances should be explosion proof.

Installation and Location

-Equipment should be located to avoid congestion and should be properly identified to assure that products do not become admixed or confused with one another.

-Support systems such as heating, ventilation, air conditioning (HVAC), steam, compressed air and gases should function as designed and identifiable.

Maintenance of Equipment

– Weighing,measuring, testing and recording equipment should be serviced andcalibrated regularly. All records should be maintained.

Sanitation and Safety

-Sanitation and safety should be practiced to cover personnel, premises, equipment, production materials and containers.

Personnel

-Personnel engaged in the manufacture, processing, packaging, or holding of chemical andchemical products should wear appropriate personnel protective equipment for assigned duties.

-Personnel should be healthy to perform their assigned duties. Regular medical examination should be conducted for all production personnel.

-Factory wears should not be worn out of the area they are meant for.

Premises

– Adequate employee’s washing and toilet facilities should be provided and separated from the production area.

-Suitable locker facilities should be provided at appropriate location for the storage of employee’s clothing and personal belongings.

Waste materials should be regularly collected in suitable receptacles for removal to collection points, outside the production area.

– Restricted areas to unauthorized personnel should be clearly defined with signage displayed appropriately.

PRODUCTION

Verification of Materials

-All deliveries of raw materials and packaging materials should be checked and verified for conformity to specifications and should be traceable to the product.

-Samples of raw materials should be physically checked for conformity to specifications priorto release for use. The raw materialsshould be clearly labeled. All goods must be clean and checked for appropriate protective packing to ensure no leakages, perforations or exposures.

Rejected materials

-Deliveries of raw materials that do not comply with specifications should be segregated anddisposed according to Standard Operating Procedures.

Batch Numbering System

-Every finished product should bear a production identification number, which enables the history of the product to be traced.

-A batch numbering system should be specific for the product and a particular batch number should not be repeated for the same product in order to avoid confusion.

-Whenever possible, the batch number should be printed on the immediate and outer container of the product.

– Records of batch number should be maintained.

Weighing and Measurement

-Weighing should be carried out in the defined areas using calibrated equipment. 

-All weighing and measurement carried out should be recorded and where applicable, counterchecked.

Procedure and Processing

-All starting materials used should be approved according to specifications.

-All manufacturing procedures should be carried out according to written.

-All required in-process controls should be carried out and recorded.

-Bulk products should be properly labelled until approved by Quality Control, where applicable

Dry Chemical Products

– Handling dry chemical materials and products should be given special attention.

-Where possible, dust-containing production system, central vacuum system or other suitable methods should be employed.

Wet Chemical Products

-Liquid chemical products should be produced in such a way as to protect the product from spillage and other hazard contamination.

-Where pipelines are used for delivery of raw materials or bulk products, care should be taken to ensure that the systems are easy to clean.

Labeling and Packaging

-Packaging line should be inspected for clearance prior to operation. 

-Equipment should be clean and functional. All materials and products from previous packaging operation should have been removed.

-Samples should be taken and checked at random during labeling and packaging operations.

-Each labeling and packaging line should be clearly identified to avoid mix-up.

-Excess labels and packaging materials should be returned to the store and recorded. Any rejected packaging materials should be disposed of accordingly.

Finished Product: Quarantine and Delivery to Finished Stock.

-All finished products should be approved by Quality Control prior to release.

Provisions of the guidelines on Quality Control

-Quality control is an essential part of GMP. It provides assurance that chemical products will be of consistent quality appropriate to intended use.

-A quality control system should be established to ensure that chemical products contain thecorrect materials of specified quality and quantity and are manufactured under proper conditions according to Standard Operating Procedures.

-Quality control involves sampling, inspecting and testing of starting materials, inprocess, intermediate, bulk, and finished products. It also includes where applicable, environmental monitoring programs, review of batch documentation, sample retention programs,stability studies and maintaining correct specifications of materials and products.

Bitcoin ETFs will enhance Crypto Market Decentralization

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Bitcoin is a digital currency that operates on a decentralized network of computers, without the need for a central authority or intermediary. Bitcoin ETFs are exchange-traded funds that track the price of bitcoin and allow investors to gain exposure to the cryptocurrency without having to buy, store, or manage it themselves.

There are several potential benefits of investing in bitcoin ETFs, such as:

Liquidity: Bitcoin ETFs trade on regulated stock exchanges, which means they have high liquidity and can be easily bought and sold throughout the day.

Diversification: Bitcoin ETFs can offer investors a way to diversify their portfolio and hedge against inflation, currency devaluation, or geopolitical risks.

Simplicity: Bitcoin ETFs eliminate the hassle of dealing with bitcoin wallets, exchanges, or custodians, which can be complex, costly, or insecure.

Tax efficiency: Bitcoin ETFs may have lower tax implications than directly owning bitcoin, depending on the jurisdiction and the type of fund.

However, there are also some drawbacks of investing in bitcoin ETFs, such as:

Fees: Bitcoin ETFs charge management fees and other expenses that reduce the returns for investors. These fees may vary depending on the fund provider and the structure of the fund.

Tracking error: Bitcoin ETFs may not perfectly replicate the performance of bitcoin, due to factors such as market volatility, liquidity constraints, or regulatory issues. This means that the price of the fund may deviate from the price of bitcoin over time.

Regulatory uncertainty: Bitcoin ETFs are subject to the rules and regulations of the jurisdictions where they are listed and traded, which may change or differ from those governing bitcoin itself. This creates uncertainty and risk for investors, especially in countries where bitcoin is not widely accepted or legal.

Limited availability: Bitcoin ETFs are not widely available in many markets, as they face significant regulatory hurdles and skepticism from authorities. As of August 2023, only a few countries have approved or launched bitcoin ETFs, such as Canada, Brazil, and Germany.

Decentralization means that no single entity or authority has control over the network, the transactions, or the governance of the system. Instead, the power is distributed among the participants, who can verify, validate, and contribute to the network in a transparent and democratic way.

Why is decentralization important for the cryptocurrency industry? There are several reasons:

Decentralization enhances security. By eliminating the need for intermediaries or central servers, decentralization reduces the risk of hacking, censorship, or manipulation. The network is protected by cryptography and consensus mechanisms that ensure its integrity and reliability.

Decentralization promotes innovation. By allowing anyone to participate and contribute to the network, decentralization fosters a culture of creativity and experimentation. The network can evolve and adapt to the changing needs and preferences of the users, without being constrained by bureaucratic or regulatory barriers.

Decentralization empowers users. By giving users more control over their own data, assets, and identity, decentralization enhances their privacy and sovereignty. Users can choose how to interact with the network, what services to use, and whom to trust, without relying on third parties or intermediaries.

The cryptocurrency industry will only become better as it becomes decentralized. Decentralization is not only a technical feature, but also a social and economic vision. It is a vision of a more open, fair, and inclusive world, where everyone can benefit from the opportunities and advantages of digital currencies.

Bitcoin ETFs are a convenient, decentralized and accessible way for investors to gain exposure to the cryptocurrency market, but they also come with some challenges and risks. Investors should weigh the pros and cons of investing in bitcoin ETFs carefully before making a decision.

Get The First WIN And The Lessons from Daniel and Jose Mourinho

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“And this is the writing that was written, MENE, MENE, TEKEL, UPHARSIN.” And the king called his enchanters, astrologers, and diviners – the wise men of Babylon – and commanded, “Whoever reads this writing and tells me what it means will be clothed in purple and have a gold chain placed around his neck, and he will be made the third highest ruler in the kingdom.” None helped!

Then the queen, his mother, came to the rescue, and told King Belshazzar that in his kingdom, there was a young man: “In the time of your father he was found to have insight and intelligence and wisdom like that of the gods. Your father, King Nebuchadnezzar, appointed him chief of the magicians, enchanters, astrologers and diviners”. 

Daniel is that man; when Belshazzar took over from his father, he was demoted. Daniel was brilliant, and when Nebuchadnezzar ruled over his empires, he assembled the most knowledgeable people in all the kingdoms he controlled. He went for the best including appointing brilliant “slaves” to become heads of important positions in his government: he made Daniel the leader of his strategy team – “chief of the magicians, enchanters, astrologers and diviners”.  But Daniel lost that job when Belshazzar took over.

Here is the business lesson: you just need to win once, and the “queen” [your colleague, your roommate, etc] will remember you. Like Jose Mourinho, ex-Chelsea, ex-Real Madrid, ex-ManU, ex-Inter Milan, ex-FC Porto, and currently Roma’s coach, they will keep remembering you, to pick a new “football club” and manage it. What it takes is to WIN just once, on something important, and the world will NEVER forget. 

In the Igbo Nation, it takes the killing of one leopard to be called a killer of leopards. Learn from Daniel and Jose Mourinho (he won the Champions League with FC Porto and doors opened for Jose) on the pillars of enduring careers. Yes, until people can recommend you in your absence, your career ascension cannot come. Find the GREAT first #Win. Happy Sunday.

I have written about him many times and have used him as a case study in Tekedia Mini-MBA. In May 2021, I wrote “You cannot explain these things.  AS Roma, the Italian football giant, has appointed Jose Mourinho as its new head coach for the 2021/2022 season. Yes, the special one returns. There is a business lesson there: people with prior great results continue to be recycled despite the abundance of new people looking for opportunities.

”You cannot make this up, as one CEO leaves one job for another job, and another CEO from another company fills it up. Jose has moved from FC Porto, Chelsea, Inter, Real Madrid, Chelsea, ManU, {vacation in my village}, Spurs, and now is gifted another via AS Roma.”

People, the special one just won the Europa Conference League with Roma and this line sums it up: ‘”Football is about winning and Mourinho wins,” said former Manchester United midfielder Owen Hargreaves on BT Sport’.

Records, records and records build careers. Even when they begin to fade, the kingmakers always default to the man or woman with records. Put some great records in your resume!

Comment on Feed

Comment 1: This is a beautiful piece, Prof. Permit me to add another lesson here. Never hide your talents in any circumstances. Whenever the opportunity arises, show whatever you can do. If Daniel had hidden his talents in the past, no one will remember him. No one will call you to the big stage unless you have shown your talents in the small stages, paid or unpaid. Joseph and Daniel never hid their talents, they always used their talents. That’s why people always remembered them. Sometimes, we pray that God should remember us. No one remembers the person they’ve never met or do anything of value. Your talents will make ways for you when you display them.

The Referral At The Palace

As Bitcoin Plummets Below $26,000, Over $127M Liquidated to Market Volatility

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The cryptocurrency market has experienced a sharp decline in the last day, wiping out more than $127 million worth of digital assets from traders’ portfolios. The main catalyst for this sell-off was the drop of Bitcoin, the leading and most influential cryptocurrency, below the $26,000 mark. This article will analyze the reasons behind this market movement and the implications for the future of crypto investing.

Bitcoin is often considered as a store of value and a hedge against inflation, especially in times of economic uncertainty and geopolitical tensions. However, it is also subject to high volatility and price fluctuations, depending on various factors such as supply and demand, regulatory developments, technological innovations, and market sentiment. In the past 24 hours, Bitcoin has lost more than 10% of its value, falling from around $29,000 to below $26,000 at the time of writing. This is the lowest level since December 2020, when Bitcoin was on its way to reach its all-time high of over $64,000 in April 2021.

There are several possible explanations for this sudden drop. One of them is the ongoing crackdown on crypto mining and trading in China, which has reduced the hash rate and liquidity of the Bitcoin network. Another factor is the rising popularity of alternative cryptocurrencies, such as Ethereum, Cardano, Solana, and others, which offer more functionality and innovation than Bitcoin. Some investors may have decided to diversify their portfolios or switch to these newer platforms, reducing the demand for Bitcoin.

A third reason could be the general bearish sentiment in the crypto market, fueled by negative news, regulatory uncertainty, cyberattacks, and environmental concerns. Many traders may have decided to take profits or cut losses, triggering a cascade of liquidations and margin calls. Lastly, consistent delays by the US regulatory bodies on Spot Bitcoin ETFs approval is another sell off signal plummeting the current downside on the price of Bitcoin as many investors are eagerly playing mind bet games on whatever the outcome might be.

Whatever the cause, the fact is that more than $127 million worth of crypto assets have been liquidated in the past 24 hours, according to data from Bybt.com. This means that traders who borrowed money or used leverage to amplify their positions have been forced to sell their assets at a loss to repay their debts or meet their margin requirements.

This creates a downward pressure on the market, as more selling leads to lower prices, which in turn triggers more liquidations. The most affected assets were Bitcoin, Ethereum, XRP, and Binance Coin, which accounted for more than 80% of the total liquidations.

The question now is whether this is a temporary correction or a sign of a deeper trend reversal. Some analysts believe that Bitcoin is still in a long-term uptrend and that this dip is an opportunity to buy at a lower price. They point out that Bitcoin has strong fundamentals, such as its limited supply, its network effects, its institutional adoption, and its resilience to external shocks. They also argue that Bitcoin is still undervalued compared to its potential and that it will eventually reach new highs in the future.

Others are more pessimistic and think that Bitcoin has entered a bear market and that it will continue to decline in the coming months. They cite the technical indicators, such as the death cross (when the 50-day moving average crosses below the 200-day moving average), which signal a bearish trend reversal. They also highlight the challenges that Bitcoin faces, such as its scalability issues, its environmental impact, its regulatory hurdles, and its competition from other cryptocurrencies. They claim that Bitcoin is losing its relevance and appeal and that it will be replaced by more advanced and efficient platforms.

Former SEC chair, Jay Clayton, says spot Bitcoin ETF approval is ‘Inevitable

Jay Clayton, who served as the chairman of the U.S. Securities and Exchange Commission (SEC) from 2017 to 2020, has recently expressed his confidence that the regulator will eventually approve a spot Bitcoin exchange-traded fund (ETF). In an interview with CNBC on September 2, 2023, Clayton said that he believes it is “inevitable” that the SEC will greenlight a Bitcoin ETF that tracks the price of the underlying asset, rather than a futures-based one.

Clayton’s comments come amid a series of delays and rejections by the SEC of various Bitcoin ETF proposals. The agency has cited concerns over market manipulation, investor protection, and custody issues as some of the reasons for its reluctance to approve a spot Bitcoin ETF. However, Clayton argued that these challenges are not insurmountable and that the SEC is likely to overcome them in the near future.

I think we’re getting closer to that point,” Clayton said. “I think the technology has evolved and the regulations have evolved to a point where it’s inevitable that we’ll see a Bitcoin ETF.

Clayton also noted that the SEC has already approved several Bitcoin futures-based ETFs, which he said are “a step in the right direction” but not a substitute for a spot Bitcoin ETF. He explained that futures-based ETFs have higher fees and tracking errors than spot-based ones, and that they do not reflect the true demand and supply of Bitcoin in the market.

“A futures-based ETF is not a pure play on Bitcoin,” Clayton said. “It’s a play on the futures market, which has its own dynamics and its own risks.”

Clayton added that he is optimistic about the future of Bitcoin and other cryptocurrencies, as they offer new opportunities for innovation and financial inclusion. He said that he is not opposed to regulation, but rather to excessive regulation that stifles innovation and competition.

I think we need to have a balanced approach to regulation,” Clayton said. “We need to protect investors, we need to ensure market integrity, but we also need to foster innovation and competition in this space.

Ultimately, the future of Bitcoin and the crypto market depends on many factors that are hard to predict with certainty. The only thing that is certain is that crypto investing is not for the faint-hearted and that it requires a lot of research, risk management, and patience. Those who decide to enter this market should be prepared for high volatility and potential losses, but also for high rewards and opportunities.