15 ASCR (n 1) rr 3, 4.1. 45 Seymoret (n 4) 195. Accurate legal advice enables clients to order their personal and business affairs within the law and this advances the rule of law. Dal Pont, Gino, 'Regulation of the Queensland Legal Profession: The Quinquennium of Change' (2009) 28(2) University of Queensland Law Journal 183. 38 Crowley-Cyr and Caple (n 6) 74. breach of this trust and could create confusion for both lawyers and clients. Don't miss out on the headlines from Crime and Court. Legal Services Commissioner v Cullen [2020] QCAT 439; Legal Services Commissioner v Wright [2020] QCAT 438; Legal Services Commissioner v Brown [2020] QCAT 423; Legal Services Commissioner v Rosser [2020] QCAT 375; Legal Services Commissioner v Greenhalgh [2020] QCAT 349; Legal Services Commissioner v Loel [2020] QCAT 326; Legal Services . Annual Report 2021-2022 Annual Report 2021-2022 [3815Kb] Annual reports archive Annual Report 2020-2021 [2662Kb] Annual Report 2019-2020 [293Kb] Rule 8(a) of the Federal Rules of Criminal Procedure states the indictment or information may charge a defendant in separate counts with 2 or more offenses if the offenses charged-whether felonies or misdemeanors or both-are of the same or similar character, or are based on the same act or transaction, or are connected with or constitute parts of a common scheme or plan. Similarly, Fed. A Fulton County jury found Larry Rosser guilty of malice murder and other offenses in connection with the death of Alexis Vereen. where any relationship, despite consent, will be marred by surrounding circumstances. at 539. ), Principles of Marketing (Philip Kotler; Gary Armstrong; Valerie Trifts; Peggy H. Cunningham), Contract: Cases and Materials (Paterson; Jeannie Robertson; Andrew Duke), Il potere dei conflitti. University of Queensland Law Journal 183, 188. profession, which can have equally disastrous consequences for everyone involved. 42 Office of Lawyer Regulation v. Atta , 882 NW 2d 810 (Wiss, 2016) This site uses cookies to analyse traffic, remember your preferences, and optimise your experience. 4 Malinda L Seymoret, Attorney-Client Sex: A Feminist Critique of the Absence of Regulation (2003) 8(2) The Legal Services Commission acknowledges the Traditional Owners of the land, and pays respect to Elders past, present and future, Legal Services Commission Queensland 2023, What the Legal Services Commission can't do, Complaints and the Legal Services Commission, Queensland Civil and Administrative Tribunal Decisions, Queensland Civil and Administrative Tribunal, New South Wales Office of the Legal Services Commissioner, Victorian Legal Services Board + Commissioner, South Australia Legal Profession Conduct Commission, Legal Practice Board of Western Australia. Self-evidently, that conduct was a fundamental breach of her duties to Mr Orman and to the Court. 17 The presence of a strong, emotional bias not only impacts the Clinical Law Review. Section 116 provides that: Where the whole or part of the value transferred by a transfer of value is attributable to the agricultural value of agricultural property, the whole or part of the value transferred shall be treated as reduced by the appropriate percentage . This created a modest farming business for Mr and Mrs Rosser consisting of 112 acres. 2020 2016 2011 2010 2009 Last updated: 16 June 2021 Last published: 16 June 2021 Practice note - PNVCAT1 - Common procedures, Practice note - PNVCAT2 - Expert evidence, Practice note - PNVCAT3 - Fair hearing obligation, Practice note - PNVCAT4 - Alternative dispute resolution (ADR), Practice note - PNVCAT5 - Directions hearings and urgent hearings, Unreasonable flow of water between properties, Medical Treatment and Advance Care Directives, Traditional owners and Aboriginal heritage, How to communicate with VCAT and other parties, Photography, recording, mobile phones and electronic devices, Privacy and access to information at VCAT. Print-friendly application form Apply now technology developed exclusively by vLex editorially enriches legal information to make it accessible, with instant translation into 14 languages for enhanced discoverability and comparative research. That the deceased's house and buildings at Cwm Farm, Cwm Lane, Rogerstone, Gwent were not, having regard to the provisions ofInheritance Tax Act 1984 section 115 subsec-or-para 2s. In this section. Lancaster first argues that a joint trial would prejudice him because the jury would improperly infer that Lancaster knew or should have known about Rosser's alleged activities forming the basis for Count I, which is solely against Rosser. Some of the most egregious breaches of client confidentiality can occur when lawyers become informants for police or other government authorities. If you are looking for further places to search for unreported judgments of the Supreme Court, County Court, Magistrates' Court and VCAT see our Research Guide called Locating Victorian Unreported Judgments. A bright line rule is necessary to prevent widespread irregularity in professional behaviour and the legality of certain conduct being determined by the subjective discretion of individuals. . There was a brief statement of agreed facts. Relationship (1999) 6 Clinical Law Review, Teague, Bernard , Legal Ethics in Court Practice [1994] 8 New Zealand Legal Research information and confidence to their solicitor. 3 Marjorie A Silver, Love, Hate, and Other Emotional Interference in the Lawyer/Client Relationship (1999) 6 Cwm Farm was part of the estate of Mrs Olive Amelia Phillips who died on the 6 June 2001. See. Full title:UNITED STATES OF AMERICA, Plaintiff, v. STEVEN G. ROSSER, WHITNEY R, Court:United States District Court, Southern District of Ohio. . United States v. Swift, 809 F.2d 320, 323 (6th Cir. on its facts. 3. Legal Practice Committee Home Disciplinary Decisions Disciplinary Decisions Below is a list of decisions of the Legal Practice Committee. 5 This Their employment in the Vice Unit partially overlapped. In an attempt to show that the result in the Court of Appeals for the Ninth Circuit would be different, petitioners cite Milligan v. Commissioner 38 F.3d 1094 (9th Cir. (ECF No. It should be made explicit that the lawyers fiduciary duty extends to the clients emotional vulnerability, as well as their legal and financial interests. 36 This Mrs Phillips made meals for the people working on the farm, whilst Mr Phillips helped with the repairing of hedges and gates and kept a watchful eye on the stock. The ethical obligation of lawyers to maintain the confidentiality of communications with their clients is well known not only to lawyers but also to members of the community. Judge Clive Wall yesterday confronted barrister Chris Rosser over claims he had received instruction from Chan Lawyers regarding three cases. Dal Pont, Gino, Lawyers Professional Responsibility, (Law Book Co of Australasia, 7th ed, 2020). In summary, the charges allege that the respondent, over a four-month period in 2017, dishonestly applied $75,600 of clients' money to . This site uses cookies to analyse traffic, remember your preferences, and optimise your experience. She was in the process of leaving an abusive partner and the custody of her children was yet to be determined when she entered the relationship with her lawyer. (Brisbane) 1300 655 754. 28 Rule 3.1 states that a solicitors duty to the justice system supersedes any other duty.While a member of the public should not be deprived of their choice of counsel, this rule ensures that a lawyers paramount duty is to the administration of justice and preservation of the professions integrity.29(<>) This rule has been taken to include the duty to not commence baseless proceedings, to conduct proceedings efficiently, and not mislead the court. : The Absolute Ban on Lawyer-Client Sexual Relationships Is Not Absolutely Necessary (2003) 16(4) The Georgetown Journal of Legal Ethics 535, Carter, Justin and Lillian Corbin, Adding Value for Lawyers, Clients, and the Public: The Business Benefits of Ethically-Informed Practice (2009) 28 University of Queensland Law Journal, Crowley-Cyr, Lynda and Carol Caple, Sex with Clients and the Ethical Lawyer (2001) 8 James Cook University Law Review. Learn more about fees or apply for fee relief.
United States v. Rosser (2:20-cr-00062) - CourtListener The purpose of the Annual Report is to report on the Office of the NSW Legal Services Commissioner's (OLSC's) performance and highlight the OLSC's activities that occurred during the reporting year. The Tribunal orders included Mr Kurschinsky be struck off the Roll of Legal Practitioners in Queensland, he pay a fine of $1,000.00, and that he pay the costs of the Legal Services Commissioner in relation to the disciplinary proceedings. An impartial, trusted legal system is in the best interest for all members of Count I asserts Rosser Conspired to Violate Another Person's Civil Rights; Count II levels the same charge against both defendants; and Count III asserts both defendants Conspired to Commit Wire Fraud. at 757.
The Government produced those statements for the Court's in camera consideration. includes both emotional intimacy as well as physical. Mr Rosser was assisted by their two daughters, Mrs Gillespie and Ms Rosser. Legal Services Commissioner Mrs Megan Mahon said bringing disciplinary action against Mr Kurschinsky reinforces the requirement for lawyers to maintain the highest ethical and professional standards.. Moreover, juries are assumed capable of sorting out evidence and considering each count and each defendant separately . 14 ASCR . No payment of moneys was made by the appellant for their use. 1992- 655.
foster care - Archives & Manuscripts at Duke University Libraries 2020, book. Within the Australian Solicitors Conduct Rules 2012 (ASCR), there is no mention of intimate personal relationships. LEXIS 115931, at *6-7 (S.D. The Columbus Division of Police (CPD) formerly employed the Defendants as police officers. : The Absolute Ban on Lawyer- (2004) 30 Monash University Law Review , 53. and the interests of the solicitor. Some argue that there is no need for regulating the relations of consenting adults, and that overregulation may breach personal privacy.21 (<>)It has also been argued that overregulation of professional fields is overly paternalistic and indicates a lack of confidence in lawyers self-regulated conduct.22 (<>)This issue has been debated in the medical field, and parallels can be drawn from the analysis there. This decision was made in the early 70s and lacks a contemporary understanding of consent and ethical standards.9 (<>), The conduct of all legal practitioners reflects directly back on the legal profession. regulate the actions of their practitioners to protect the industry from disrepute and protect There was no formal arrangement or partnership agreement between Mr and Mrs Phillips and Mr and Mrs Rosser about the use of the two acres and the 39 acres sites by Mr and Mrs Rosser. At the time of her death Cwm Farm consisted of a two acre site with a four bedroomed house and a barn surrounded by agricultural land.
Rosser v Commissioners of Inland Revenue - Case Law - vLex As is well known, the Victorian government established a Royal Commission into the Management of Police Informants to independently examine the number of, and extent to which, cases had been affected by the conduct of Ms Gobbo and inquire into Victoria Polices recruitment and management of informants. Regulating intimate relationships signals to the public that quality and ethical legal services are rendered to all clients.27 (<>). The profits from the two acres site were accounted for in Mr and Mrs Rosser's farm business. A client could also seek an injunction to restrain the lawyer from committing a breach of confidence. Donald v Rosser & Son; Cresswell v Sawdon & Co. (1901) 2 KB 653 . 41 The case law reasons disclosure to defend disciplinary or legal proceedings against the lawyer; disclosure for the purpose of obtaining advice in connection with the lawyers legal or ethical obligations; and. The Crown conceded that this conduct constituted a substantial miscarriage of justice. The Corporation ensures low income individuals and families have access to quality legal aid. Duke University Libraries.
In Medical Board of Queensland v Martin, it was stated that it is unacceptable to deprive someone of dispassionate, objective professional judgment because the relationship has become distorted by emotional attachment.17 (<>)The presence of a strong, emotional bias not only impacts the quality of work provided to the client, but also impacts the administration of justice. Mr Kurschinsky did not appear at the hearing. Thereafter, Rosser submitted a false Letter of Information and a false Preliminary Investigation Report stating that B.A threated Rosser's life. Overlooked defence leads to disciplinary action. within certain ethical parameters. In La Spina, where a lawyer acted on behalf of someone they had a personal relationship with and committed dishonest acts, it was acknowledged that a factor of the courts reasoning depended upon public interest and the maintenance of proper professional standards.13 (<>), It is necessary upon admittance that potential legal professionals have candour, impartiality, and respect for the system they serve.14 (<>)Lawyers are fiduciaries, and therefore their obligation is to serve and protect their clients interests over all others, with this only superseded by their duty to the courts.15 (<>)When a solicitor engages in an intimate relationship with a client it is in clear defiance of their trusted position, and their ability to adequality serve their profession is diminished.16 (<>), Alongside a lawyers duty as a fiduciary, there is the implicit need for impartiality.
Overlooked defence leads to disciplinary action - Proctor necessarily have a financial aspect, it is uncertain whether a court would use this rule where A bright line 26 Professional regulations give the These factors create an environment Ethics Regulation (2002) 44 Arizona Law Review , 845; Crowley-Cyr and Caple (n 6). The high-profile Lawyer X case indicates that Australian courts view lawyers acting as informants with the utmost seriousness. U.S. naval officer and explorer, of Washington, D.C. Family correspondence, chiefly relating to naval cruises of Wilkes and his son, John Wilkes; the U.S. By this discipline application under the Legal Profession Act 2007 (Qld) (" LPA ") the applicant, the Legal Services Commissioner, has brought two charges against the respondent, Corey Wayne Cullen. While individuals are entitled to their privacy, professions can regulate the actions of their practitioners to protect the industry from disrepute and protect consumers. . In Medical
Legal Practice Committee | Legal Services Commission According to the Indictment, Lancaster was positioned near the business before and after the arrest. Docket for United States v. Rosser, 2:20-cr-00062 Brought to you by the RECAP Initiative and Free Law Project, a non-profit dedicated to creating high quality open legal information. confidence.
Caniglia v. Strom, 593 U.S. ___ (2021) - Justia Law fine for going on dinner dates with a client as it could impact on the lawyers representation However, as employees, it may be possible for in-house lawyers to disclose confidential information relating to potential wrongdoing to more senior officers of their organisation without breaching confidentiality. The tenancy passed to his son, Mr John Augustus Phillips, shortly after his marriage in 1932 to Miss Olive Amelia Smith (Mrs Phillips). solicitors by avoiding the intermingling of personal affairs with client affairs. The Grand Jury indicted Lancaster and co-Defendant Steven G. Rosser on March 25, 2020. Legal assistance. the conflict of interest has no relevance to physicality but deals with intangibles and shown in Lamb, the emotional relationship led to further breaches of conduct. 12. society, and therefore it is necessary to ensure trusted practitioners are performing services (quoting United States v. Gallo, 763 F.2d 1504, 1526 (6th Cir.
ROSSER v. COMMISSIONER, 2001 T.C. Memo. 79, 81 T.C.M. 1467, 2001 Tax Ct 50. Make your practice more effective and efficient with Casetexts legal research suite. This is a gap in the regulations which needs to be amended. Inheritance Tax Act 1984 section 4 subsec-or-para 1Section 4(1) deals with the charging of inheritance tax on the death of any person: On the death of any person tax shall be charged as if, immediately before his death he had made a transfer of value and the value transferred by it had been equal to the value of his estate immediately before his death. 115-124C of the 1984 Act) contains the provisions giving relief for agricultural property. clear defiance of their trusted position, and their ability to adequality serve their profession is 1985)) (quotations and citation omitted). of certain conduct being determined by the subjective discretion of individuals. 16, Alongside a lawyers duty as a fiduciary, there is the implicit need for impartiality. . The appellant appeals against the notice of determination issued by the Commissioners of Inland Revenue dated 2 January 2003. Id. sometimes due to deeply sensitive and personal matters, and they entrust personal Cwm Farm lies on the eastern edge of the village of Rogerstone which is situated in the Ebbw Valley just north of Newport in the county of Gwent, South Wales. Where a lawyer acts wrongfully either towards a client in practice or prior to admittance, the trust that is broken can create a negative perception of the legal system. LEXIS 79226, at *6 (S.D. probability of impartial interference and mitigates a lawyers duty being to the courts above However, the regulation leaves ambiguity as to what would be considered a. Brisbane Adelaide Street. Davis, Anthony E and Judith Grimaldi, Sexual Confusion: Attorney-Client Sex and the Need for a Clear Ethical Rule (1993) 7 Notre Dame Journal of Law, Ethics & Public Policy, Parkinson, Christine, A Critical Morality for Lawyers: Four Approaches to Lawyers (2004) 30 Monash University Law Review, Seymoret, Malinda L, Attorney-Client Sex: A Feminist Critique of the Absence of Regulation (2003) 8(2) Yale Journal of Law and Feminism 435, Silver, Marjorie A, Love, Hate, and Other Emotional Interference in the Lawyer/Client Relationship (1999) 6 Clinical Law Review, Teague, Bernard , Legal Ethics in Court Practice [1994] 8 New Zealand Legal Research Foundation Seminar Papers, Terry, Laurel S, Steve Mark and Tahlia Gordon, Trends and Challenges in Lawyer, Regulation: The Impact of Globalization and Technology (2011) 80 Fordham Law Review. and confidence of the client has been breached. Legal practitioners hold a privileged place of trust within our community and are afforded considerable confidence and responsibility Commissioner Mahon said. That case involved self-employment tax determined by the Commissioner for an insurance agent's . Lawyers Professional Responsibility, Thomson Reuters (Professional) Australia Pty Limited, 2020. the management of intimate personal relationships between Queensland solicitors and their Journal, Crowley-Cyr, Lynda and Carol Caple, Sex with Clients and the Ethical Lawyer (2001) 8 272 to include "rights and interests of any description". Cwm Farm lies on the eastern edge of the village of Rogerstone which is situated in the Ebbw Valley just north of Newport in the county of Gwent, South Wales. For more information on the details of the case see Legal Services Commissioner V Kurschinsky [2020] QCAT 182. Baron, Paula and Lillian Corbin, The Unprofessional Professional: Do Lawyers Need In 1958 Mr Phillips purchased Cwm Farm following the dissolution of the Tredegar Estate. In broad terms owner occupiers are entitled to a 100 per cent reduction, whilst agricultural landlords are entitled to a 50 per cent reduction except where the tenancy or a tenant succeeds to the tenancy after 10 August 1995. Start a new or return to a saved Account by Administrator (ABA). Severance under Rule 14(a) is only appropriate when there is a serious risk that a joint trial would compromise a specific trial right of one of the defendants, or prevent the jury from making a reliable judgment about guilt or innocence. Id. As shown in Lamb, the emotional relationship led to further breaches of conduct.18 (<>)The lawyers participation in matters that impact a person they feel strongly towards heightens the probability of impartial interference and mitigates a lawyers duty being to the courts above all else.19 (<>). Archives & Manuscripts Collection Guides Search within 17 Medical Board of Queensland v Martin [2000] 2 Qd R 129, [45]. (ECF No. The Grand Jury indicted Lancaster and co-Defendant Steven G. Rosser on March 25, 2020. However, this regulation could be narrowed through the interpretation of an intimate relationship and whether its ambit includes both emotional intimacy as well as physical. - clicking this link first time opens a sub-menu, clicking second time loads the page. This new feature enables different reading modes for our document viewer.
Legal watchdog applies to strike Nicola Gobbo from bar roll Advice on the Victorian legal system and how to find a lawyer. The central issue for determination in the appeal was whether the value transferred by the disposition of the house and barn attracted agricultural relief within the meaning of Inheritance Tax Act 1984 section 116s. Lawyers are also under an equitable obligation to preserve confidentiality of information provided by their client. In New Zealand, intimate relationships between lawyers and their clients are regulated by the Lawyers and Conveyancers Act (Lawyers: Client and Conduct Care) Rules 2008, which state in r 5.7, that a lawyer must not have an intimate relationship with a client where it would be inconsistent with the trust and confidence reposed by the client or where the lawyer is currently acting for the client in any domestic relation matters.37 (<>)The reasoning given for these strict rules is that the relationship of confidence and trust may be breached where a practitioner and a client enter into a sexual relationship.38 (<>), These regulations have a broad application as they only apply to all relations where the trust and confidence of the client has been breached. or impairment of judgment that may still occur where there is an established intimate Thus, Federal Rule of Criminal Procedure 14 becomes applicable. Learn more. On the facts as conceded, Ms Gobbos conduct subverted Mr Ormans right to a fair trial, and went to the very foundations of the system of criminal trial. 1507 (ND Cal. Pursuant to the following analysis, the Motion and Lancaster's concurrent request for oral hearing are DENIED.
PDF Delays: Common issues in legal practice - Commissioner 8. turns in part on whether the numbers of conspiracies and conspirators involved were too great for the jury to give each defendant the separate and individual consideration of the evidence against him to which he was entitled. Gallo, 763 F.2d at 1526 (quotation and citation omitted). Get local news delivered to your inbox! Mr and Mrs Rosser's stock ran on the two acres as well as the 39 acres. Relationships Is Not Absolutely Necessary (2003) 16(4) The Georgetown Journal of Legal Ethics 535. Cwm Farm was part of the estate of Mrs Olive Amelia Phillips who died on the 6 June 2001. 35 In Legal Services Commissioner v McQuaid, it was stated 8.2.2, Professional boundaries: (accessed 1 April 2021), Financial Accounting: an Integrated Approach (Ken Trotman; Michael Gibbins), Financial Institutions, Instruments and Markets (Viney; Michael McGrath; Christopher Viney), Management Accounting (Kim Langfield-Smith; Helen Thorne; David Alan Smith; Ronald W. Hilton), Culture and Psychology (Matsumoto; David Matsumoto; Linda Juang), Australian Financial Accounting (Craig Deegan), Lawyers' Professional Responsibility (Gino Dal Pont), Database Systems: Design Implementation and Management (Carlos Coronel; Steven Morris), Financial Reporting (Janice Loftus; Ken J. Leo; Noel Boys; Belinda Luke; Sorin Daniliuc; Hong Ang; Karyn Byrnes), Company Accounting (Ken Leo; John Hoggett; John Sweeting; Jennie Radford), Auditing (Robyn Moroney; Fiona Campbell; Jane Hamilton; Valerie Warren), Na (Dijkstra A.J. Sign in below: that In the case of Office of Lawyer Regulation v. Atta, it was reasoned that intimate 7. The District Court for the Northern District of California held that the prosecutions collaboration with Mr Minkin violated Mr Marshanks Fifth and Sixth Amendment rights to due process of law and assistance of counsel and dismissed the indictment. An alternative to lists of cases, the Precedent Map makes it easier to establish which ones may be of most relevance to your research and prioritise further reading. To continue reading the rest of this article, create a free account . 5. Legal assistance. His wife left and spent the night at a hotel.
He has been charged with one count of breaching r 64 of the Barristers' Conduct Rules ("the Rules"). The Government alleges Rosser was in frequent contact with Lancaster via cellular phone the day of A.S.'s arrest. Search over 120 million documents from over 100 countries including primary and secondary collections of legislation, case law, regulations, practical law, news, forms and contracts, books, journals, and more. Foundation Seminar Papers, Terry, Laurel S, Steve Mark and Tahlia Gordon, Trends and Challenges in Lawyer current regulations for medical practitioners. The bundles contained the same set of ten photographs which did not include photographs directly of the house (there was a photograph which included a side on view in the background). Make an application Learn more about fees or apply for fee relief. . LSC v Christopher James Rosser LPC002/09; 2009 LSC v Supranowicz LPC003-09. Neither is compelling, specific, and actually prejudicial. 8.2, Professional boundaries: agricultural property means agricultural land or pasture [, The italics in the definition are mine and intended to identify the three separate dimensions to the definition of agricultural property as identified in, Inheritance Tax Act 1984 section 117Section 117. The appropriate percentage is either 100 per cent or 50 per cent. LLH302 2020 LSC Memorandum (Assessment Task 1), Memorandum to Legal Services Commissioner, LLH302 2020 Template - LSC Memorandum (Assessment Task 1), LLH302 Ethics and the Legal Profession Law Policy Submission Template Final, https://www.medicalbooard.gov.au/Codes-Guidelines-Policies.aspx, https://www.lawsociety.org.nz/for-the-public/complaining-about-a-lawyer/standards-, committee-decisions/2020/fined-for-intimate-relationship-with-client/, Intro to Property and Commercial Law (70327), Managing in a Global Environment (200864 ), Accounting Fundamentals In Society (ACCY111), Processes and Evaluation in Employment Relations (200575), Engineering Practice 6 - Sustainable Infrastructure Design (CIVE1155), Foundations of Nursing Practice 2 (NURS11154), Applications of Functional Anatomy to Physical Education (HB101), Anatomy For Biomedical Science (HUBS1109), Economics for Business Decision Making (BUSS1040), Introducing Quantitative Research (SOCY2339), Horngren's Cost Accounting: A Managerial Emphasis, 16th Global Edition Chapter 15 Questions and solutions, Exam 2013 Introduction To Financial Accounting, answers, Summary - lecture 1-12 - summarized notes to be used for final exams, Lecture notes, highly detailed subject notes covering all lectures, online videos and workshops, Summary - complete - Mental health nursing, Ethics and Governance - Lecture notes, lecture 1 - 12, CHE144 cheat sheet - Summary Foundations of Chemistry, CBSE Sample Paper Class 6 Maths Half Yearly Set 1, 260 questions and answer for technical interviews, Tutorial 1 - accounting information system, Week 2 - Attitudes, stereotyping and predjucie, 14449906 Andrew Assessment 2B Written reflection.