Question 1

al f 50Eric's English Lounge 在Facebook 的評價

Accepted Answer

淺談「假新聞」最近上課時學到一個新單字「positionality」，讓我想到當前社群媒體上，不停看到的「fake news」——假新聞。簡言之，「positionality」(位置性) 被定義為於種族、階級、性別、性取向以及能力等狀態中，創造你身分的社會與政治背景。位置性還描述了你的身分如何影響你對世界的理解與看法，以及潛在的偏見。positionality 位置性；定位https://terms.naer.edu.tw/detail/3390885/https://www.lexico.com/definition/positionality以下是我對「positionality」與 「fake news」的些許觀點：“Fake news” has permeated all facets of life, ranging from social media interaction to presidential elections. Fake news can be defined as “fabricated information that mimics news media content in form but not in organizational process or intent” (Lazer et al., 2018, p. 1094). The creators and outlets of fake news do not ensure the accuracy and credibility of information, but rather disseminate misinformation or disinformation for purposes ranging from personal amusement to creating deceptions to achieve political aims. At times, fake news is created and disseminated by state or non-state actors using social media accounts and networks of bots designed to hijack feed algorithms of platforms such as Twitter or Facebook (Prier, 2017, p. 54). In the 2016 U.S. presidential campaign, Facebook estimated that up to 60 million bots were used to post political content. Some of the same bots were then used in an attempt to influence the 2017 French election (Lazer et al., 2018, p. 1095). Such campaigns can be understood as a form of information warfare, a comprehensive attempt to control and influence every facet of the information supply chain, thereby influencing public opinion and behaviors. (Prier, 2017, p. 54). Often, fake news is not directly created by actors that seek to manipulate but by journalists or content creators whose content favors or aligns with the narratives of these actors (Doshi, 2020).從社群媒體的互動到總統選舉，「假新聞」（fake news）已滲透至生活的各個層面。假新聞可被定義為「在形式上而非組織過程或意圖上，模仿新聞媒體內容所捏造的資訊」（Lazer et al., 2018, p. 1094）。無論是出於個人愛好或為達政治目的而有所欺瞞，假新聞的製造者與傳播管道並不保證資訊的準確性與可信度，反而是為了散播錯誤訊息（misinformation）或扭曲訊息（disinformation）。有時，假新聞是由國家或非國家行為者（state or non-state actors）所製造與傳播，藉由社群媒體帳號及網絡機器人來劫持諸如臉書與推特等平臺的推送演算法（Prier, 2017, p. 54）。在2016年的美國總統大選中，臉書估計有多達６千萬個機器人被用來發布政治貼文。其中，有部分機器人被用於影響隔年的法國大選（Lazer et al., 2018, p. 1095）。此類行動可視為資訊戰（information warfare）的一種形式，一種對控制與影響資訊供應鏈各環節的全面嘗試，從而影響公眾輿論與行為（Prier, 2017, p. 54）。假新聞通常是由記者或內容創造者（content creators）所創造，而非試圖操弄的行為者，前者的內容偏好符合後者的敘事（Doshi, 2020）。Nevertheless, while the term “fake news” is commonplace, there is no universal, measurable way to quantify the fakeness or truthfulness of news. There are many fact-checking and media-bias detection tools, but they cannot objectively detect and clarify the more subtle and nuanced aims of manipulative actors that play a crucial role in news production. It can also be argued that the veracity of news depends not only on the actors that seek to manipulate it, but also on the positionality of its consumers. Therefore, one’s initial line of defense against misleading news lies not in the plethora of fact-checking devices but more in one’s pre-existing dispositions and skills to think and act in response to misleading information. This ability can be referred to as critical thinking, which can be more concretely expounded as “reasonable and reflective thinking focused on deciding what to believe or do” (Ennis, 2011, p. 15).然而，即便「假新聞」一詞隨處可見，卻沒有統一、可衡量的方式來量化新聞的虛假性或真實性。目前有許多事實查核與媒體偏見檢測工具，但它們無法客觀地檢測與說明行為操弄者更狡猾、更細緻的目標，而這些操弄者往往在新聞的生產中發揮著重要作用。我們也可以說，新聞的真實性不僅取決於試圖操弄它的行為者，同時還取決於新聞受眾的位置性。因此，一個人對抗誤導性新聞的第一道防線，不在於這些五花八門的事實查核方式，反而在於個人所固有的性格，以及針對誤導性資訊的思考與行動等相關技能。這種能力可稱為批判性思考（critical thinking），意即「專注於決定相信什麼或做什麼的理性思考與反思性思考」（Ennis, 2011, p. 15）。Taiwan, also known as the Republic of China (ROC), is at the forefront of information warfare. It is wedged between the geopolitical struggles of global and regional hegemonies such as the United States and China, the Peoples Republic of China (PRC). Compounding the matter are the Taiwan’s own political actors vying for influence and power. This struggle seeps into all aspects of life and practice, mainly manifesting itself on social media, a battleground of information warfare. The Ministry of Education of Taiwan is cognizant of these information campaigns, and efforts have been made to introduce media literacy into all parts of its education system. According to the ministry, the government has tried to promote media literacy education since 2000 (MOE, 2002, p. 1), with one of its primary goals to cultivate its “citizens” abilities for independent learning, critical thinking, and problem solving” (MOE, 2002, p. 2).臺灣，也被稱為中華民國，正處於資訊戰的最前線。這是全球霸權與地區霸權之間——如美國與中國（中華人民共和國）——的地緣政治對抗。使問題惡化的是臺灣自身的政治行動者對影響力與權力的奪取。這場對抗遍布於現實生活的各個面向，主要於社群媒體中——資訊戰的戰場——展露無遺。臺灣的教育部注意到了這些資訊的煙硝，並已努力將媒體素養引入其教育體系。據該部稱，自2000年以來，政府一直試圖推展媒體素養教育（MOE, 2002, p. 1），其主要目標之一是培養「公民獨立學習、批判性思考以及解決問題的能力。」（MOE, 2002, p. 2）。★★★★★★★★★★★★上述段落認為，由於個人的位置性(positionality)，「假新聞」極難定義。此外，有許多人把不符合自身成見與偏好的新聞逕斥為假新聞。這其實相當危險，因為個人觀點將會變得愈發孤立與激進。閱聽人應意識到，他們在網路上看到的每個資訊都有特定立場。是否真有毫無立場的新聞文章？為了對抗操弄性或強制性資訊（coercive information），我們必須意識到權力於個中的作用，以及我們自身的位置性如何形塑我們的詮釋。這是我們的第一道防線。★★★★★★★★★★★★參考文獻Doshi, R. (2020, January). China steps up its information war in Taiwan. Foreign Affairs. Retrieved March, 21, 2021, from https://www.foreignaffairs.com/articles/china/2020-01-09/china-steps-its-information-war-taiwanEnnis, R. H. (1985). A logical basis for measuring critical thinking skills. Educational leadership, 43(2), 44-48.Lazer, D. M., Baum, M. A., Benkler, Y., Berinsky, A. J., Greenhill, K. M., Menczer, F., ... & Zittrain, J. L. (2018). The science of fake news. Science, 359(6380), 1094-1096.MOE (Ministry of Education), Taiwan. (2002). White paper on media literacy educational policy. Retrieved March, 21, 2021, from http://english.moe.gov.tw/public/Attachment/ 2122416591771.pdfPrier, J. (2017). Commanding the trend: Social media as information warfare. Strategic Studies Quarterly: SSQ, 11(4), 50-85.★★★★★★★★★★★★教育時評: http://bit.ly/39ABON9相關詞彙: https://bit.ly/2UncrfITED相關影片: https://bit.ly/3BDsDKl

Question 2

al f 50江魔的魔界（Kong Keen Yung 江健勇） 在Facebook 的評價

Accepted Answer

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”

Question 3

al f 50Bà Dì Nulo 在Facebook 的評價

Accepted Answer

#nulo_review
Sau 25 tuổi cần skincare gì thêm (ngoài sp bôi da) để lão hóa 1 cách xinh đẹp?
.
Có luôn, ngoài bôi thấm da thì dùng thêm các loại máy chiếu sâu da tại nhà vd: tripollar stop của hãng từ Israel.

𝐠𝐢𝐚̉𝐧 𝐥𝐮̛𝐨̛̣𝐜
- giảm nhăn, săn da tại nhà là công dụng chính nhưng phải 5 tháng đổ lên mới thấy thấy cải thiện
- công dụng phụ thấy liền sau 3 tuần bắn là da hấp thụ và đáp ứng tốt mỹ phẩm, bớt rát đỏ sau khi đi nắng về (nhờ công dụng của sóng RF)
- dùng trọn đời thay vì tới lui spa mất công thì ở nhà dùng rất tiện.
- ở VN đã mua được trên shp laz tiki do đại lý ủy quyền phân phối bảo hành
Shpee https://shp.ee/ksmcqej
Laz https://tinyurl.com/vaticoatlazada
tiki https://tinyurl.com/TikiVatico
- tíchhợp được vào 1 chu trình skincare (da có treatment như re, tre, BHA,AHA ok luôn) (Tẩy trang lần 1 > Bôi gel chiếu máy > tẩy trang lần 2 > sữa rửa mặt > bôi các sp thấm như bình thường)
- 3 mức giá 5tr,10tr, 19tr (xỉu ngang lúc mua ban đầu nhưng chia nhỏ chi phí mỗi lần dùng lại rẻ hơn nhiều so với điều trị liệu trình ngoài spa) -> dì thấy loại 10tr là dùng ngon rồi. 19tr chỉ có thêm cái DMA mà công nghệ này chưa được y khoa công nhận rộng rãi.
- chế độ RF thì ấm da nha dễ chịu, DMA hơi khó chịu, khó chịu sao, các chế độ đó là gì thì xem tiếp bài

-> Ăn uống, tập luyện, ngủ nghỉ điều hòa stress và chống nắng vẫn quan trọng nhất. Sử dụng các loại máy làm đẹp như vầy chỉ đứng thứ 2, ngang bằng với việc skincare bôi da. Các cháu không cần chằm Zn nếu chưa đủ điều kiện mua máy vào những năm đi làm đầu tiền

còn review follow up tiếp nữa vì dì mới dùng 4 tuần 12 liệu trình chiếu da chưa thấy hiệu quả gì rõ ngoài việc da trở nên đáp ứng hấp thụ các sản phẩm bôi tốt hơn hẳn

Đ𝐢 𝐯𝐚̀𝐨 𝐜𝐡𝐢 𝐭𝐢𝐞̂́𝐭
Thụy Điển có foreo làm thay đổi nền rửa mặt của thế giới thì Israel có các dòng máy Tripollar Stop làm chấn động các mợ bên châu u và China (sp của Pollogen- công ty mẹ là Lumenis, thâm niên 50 năm làm đồ cho thị trường phẫu thuật, nhãn khoa, thẩm mỹ) https://craft.co/lumenis
Dì đang dùng 2 máy, tripollar stop eye- 5tr do nhẹ đô bé nhỏ quá chỉ có mắt và vùng râu rồng thôi nên dì upgrade lên máy tripollar stop Vx (bắn được toàn mặt và đi điện cho jawline)
Hiện tại chưa thấy pha ke nhưng có chỗ phân phối và bảo hành ở VN là mừng muốn xỉu rùi.

𝐂𝐨̂𝐧𝐠 𝐝𝐮̣𝐧𝐠 & 𝐜𝐡𝐞̂́ đ𝐨̣̂ 𝐑𝐅 𝐨̛̉ 𝐦𝐚́𝐲 𝟏𝟎𝐭𝐫 𝐯𝐚̀ 𝟏𝟗𝐭𝐫
Giờ coi da người lão hóa như thế nào qua đó biết máy giúp ích thế nào nha.
4 giai đoạn lão hóa da mặt:
Lão hóa da là 1 quá trình tự nhiên của cơ thể nên khum thể chặn đứng được nhưng cta có thể chọn làm chậm nó lại. (“nhiều”thì 32 nhìn như 23 hoặc “ít” thì 32 nhìn như 28-29. "nhiều" là biết chống lão hóa sớm)

1/ lão hóa da sau 25 (mất collagen da kém đàn hồi và chân chim các kiểu
2/ Lão hóa mô và mỡ sau 35 (mặt và cổ nhìn xệ xệ vì túi mỡ trên mặt bị teo)
3/ Lão hóa dây chằng sau 50 (mấy dây giữ cơ mặt xệ xuống làm râu rồng sâu đậm, túi mắt xệ, hõm mắt xuất hiện)
4. Lão hóa xương sau 60( xương sụn teo lại mũi bẹt dần, hõm mắt sâu nhìn lúc nào cũng suy tư pùn pùn)
Vai trò của máy -> sẽ làm chậm lại giai đoạn 1 và 2 của quá trình lão hóa
bằng việc chiếu sóng RF vào trung bì, hạ bì da, tạo ra tổn thương nhiệt kiểm soát (control thermal damage đến sâu trong mô mà không làm hại biểu bì da, qua đó kích thích nguyên bào sợi- fibroblast ở hạ bì tăng sinh collagen và elastin
-> da dẻ sau 5 tháng dùng sẽ đỡ nhăn, săn hơn, ai dùng trên vùng bị rạn da thì rạn da sẽ mờ bớt. Chỉ là đỡ và bớt thôi chứ không một bước lên mây, thành gái 18 trở lại hoặc da bóng như trên IG là khum thể.

𝐓𝐡𝐨̛̀𝐢 đ𝐢𝐞̂̉𝐦 𝐝𝐮̀𝐧𝐠:
-> vậy nên thời gian vàng để dùng là 23-35 khi cơ thể còn khả năng sinh collagen, mô cơ còn tốt để phục hồi từ tác hại của UVAUVB sau 1 ngày lao động. Để khi mặt đã quá nhăn rồi thì máy chỉ có làm đỡ nhăn 1 chút xíu (trông trẻ ra 3-5 tuổi) chưa ko cải lão hoàn đồng được.
Mới dùng thì 12 lần 1 tháng- 1 tuần 3 lần cách ngày, dùng liên tục 6-8 tuần. Sau đó chỉ là dặm lại 2-4 lần 1 tháng
+ Trên 23 là dùng để phòng, da dẻ bị đời quăng quật với nắng hè nhiệt đới cần phục hồi collagen để chuẩn bị lão hóa điềm đạm sau 25 (age gracefully not age drastically)
+ Tuổi 30+ là vừa phòng vừa trị thì máy sẽ phục vụ nhu cầu làm săn, trị nhăn da

**𝐌𝐚́𝐲 𝐧𝐚̀𝐲 𝐤𝐨 𝐩𝐡𝐚̉𝐢 𝐚𝐢 𝐜𝐮̃𝐧𝐠 𝐝𝐮̀𝐧𝐠 đ𝐮̛𝐨̛̣𝐜, đọc khuyến cáo là cả 1 trang chứ ít:
+ Chưa 18 (hormone da dẻ chưa ổn định)
+ 19-22 còn đi học để tiền ăn uống tập gym, món skincare thấm da và kem chống nắng hơn là mua máy
+ Có niềng răng (máy có chế độ xung điện, niềng dẫn điện)
+ Bầu cho con bú, bệnh tim, đang tiêm filler cằm,
.... (xem thêm ở cmt)

𝐂𝐡𝐞̂́ đ𝐨̣̂ 𝐦𝐚̀𝐮 𝐱𝐚𝐧𝐡 𝐃𝐌𝐀 (𝐝𝐲𝐧𝐚𝐦𝐢𝐜 𝐦𝐮𝐬𝐜𝐥𝐞 𝐚𝐜𝐭𝐢𝐯𝐚𝐭𝐢𝐨𝐧) ở máy tripollar 19tr chỉ dùng riêng cho vùng da quanh hàm và cằm- công nghệ này chắc là tên gọi khác của Microcurrent, giống máy Forea bear.
dì dùng cho có thôi chứ ko expect gì nhiều vì công nghệ này vẫn chưa được nghiên cứu với 1 sample rộng rãi. Những công dụng của chế độ này chỉ là làm cho vùng da hàm trông săn chắc hơn nhờ đưa vi xung điện vào các mô kiến chúng co bóp như kiểu tập thể dụng cho cơ vậy -> qua đó đỡ xệ, nâng lên 1 chút người ngoài nhìn vào không phát hiện được sự thay đổi và cũng khum cho hiệu quả lâu dài.

𝐅𝐞𝐞𝐥𝐢𝐧𝐠 𝐯𝐚̀ 𝐜𝐚́𝐜𝐡 𝐝𝐮̀𝐧𝐠:
Máy stop eye 5tr đúng như tên là chỉ dùng được cho mắt và vùng râu rồng thôi chưa vùng khác máy yếu ko đủ ấm. Sau khi dì upgrade máy stop Vx 19tr thì thấy bị dư công dụng (chế độ DMA dùng để căng da jawline tạm, mà dì có jawline đậm r...) nên thành ra nên dừng ở máy 10tr chỉ có chiếu RF là đủ đầy :(
Dì thấy dùng sau khi tẩy trang cho vệ sinh. Dùng xong tẩy trang lần nữa rồi rửa mặt vs sữa rửa mặt,
(vì phải bôi cái gel silicone của hãng lên để làm trơn da cho máy bắn sóng vào. gel silicone của hãng dùng xong thấy ẩm da, nhưng phải lau và rửa mặt bằng máy rửa mặt sau đó nha kẻo lên mụn ẩn) rửa mặt xong thì bắt đầu skincare bình thường.
Chế độ RF thì ấm áp ghiền phê đôi khi phê quá quên di chuyển máy nên bị nóng hết hồn chút, chế độ
.
𝐭𝐮́𝐦 𝐥𝐚̣𝐢 𝐝𝐢̀ 𝐜𝐡𝐨 đ𝐢𝐞̂̉𝐦 𝐦𝐚́𝐲 𝐨̛̉ 𝐜𝐚́𝐜 𝐦𝐮̛́𝐜 𝐠𝐢𝐚́
Stop eye 5tr -> 6/10 (rẻ nhưng yếu xìu lại xài pin sạc)
Stop X 10tr -> 9/10 ( đủ đầy hài lòng với công năng và giá)
Stop Vx 19tr -> 8/10 (có thêm chế độ DMA ko cần thiết với những ai có jawline đậm giống dì nên bị đắt, tầm 14tr thôi thì ok)

𝗠𝗼̣̂𝘁 𝗺𝗼́𝗻 𝗴𝗼𝗼𝗱 𝘁𝗼 𝗵𝗮𝘃𝗲 𝘁𝗵𝗼̂𝗶 𝗻𝗲̂𝗻 𝗰𝘂̃𝗻𝗴 𝗸𝗵𝘂𝗺 𝗻𝗲̂𝗻 đ𝗮̣̆𝘁 𝗮́𝗽 𝗹𝘂̛̣𝗰.
Lo chi trả trước cho ăn uống, tập luyện, chống nắng, sp bôi da nếu dư dả thì triển máy (dùng cho bản thân để cbi vào tuổi 30, dùng cho mẹ để cứu vãn 1 xíu thanh xuân.
Làm đẹp khộ lắm nến ráng kiếm bồ thích skincare để chia sẻ chi phí ở thú vui này nha các cháu :)))

Một số nguyên cứu tham khảo thêm, trước khi đưa máy gì lên mặt dì cũng đã dòm tới lui coi ổn ko đã...

lão hóa da
Coleman, S. R., & Grover, R. (2006). The anatomy of the aging face: volume loss and changes in 3-dimensional topography. Aesthetic surgery journal, 26(1_Supplement), S4-S9.
Mendelson, B., & Wong, C. H. (2013). Anatomy of the aging face. Plastic surgery, 2, 78-92.
Zimbler, M. S., Kokoska, M. S., & Thomas, J. R. (2001). Anatomy and pathophysiology of facial aging. Facial plastic surgery clinics of North America, 9(2), 179-87.
Gold MH. Tissue tightening: a hot topic utilizing deep dermal heating. J Drugs Dermatol 2007; 6: 1238-42
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Microcurrent
Saniee, F., Kh, K. K., Yazdanpanah, P., Rezasoltani, A., Dabiri, N., & Ghafarian Shirazi, H. R. (2012). The effect of microcurrents on facial wrinkles. Journal of Jahrom University of Medical Sciences, 10(2), 9.
Saniee, et al (2012). Consider of Micro-Current's effect to variation of Facial Wrinkle trend, Randomized Clinical Trial Study. Life Science Journal, 9(3), 1184-1189.
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RF tech
Johnson, B. (2011). The Future of Skincare. Australian Advanced Aesthetics, 2011(1), 52.
GEL, A. V. Effects and mechanisms of a microcurrent treatment on skin healing.
Medvid, S. A., & Podoprigora, N. N. (2017). Modern methods of anti-aging (Doctoral dissertation, Sumy State University).
Kirsch, D. L., DAAPM, F., & Becker, R. O. (2001). Microcurrent electrical therapy mechanisms and result. Practical Pain Management, 29-33..
Beasley, K. L., & Weiss, R. A. (2014). Radiofrequency in cosmetic dermatology. Dermatologic clinics, 32(1), 79-90.
.
Nghiên cứu về hiệu quả của các đời máy tripollar từ 2009- dì thấy chỉ mang tính tham khảo chứ sample và bias vẫn xuất hiện trong các nghiên cứu này khi test mà không blind test người tham gia thử nghiệm và không được conduct bởi người ngoài brand (tức kết quả chưa tin tưởng vì có thể cheat chút để pr)
Kaplan, H., & Gat, A. (2009). Clinical and histopathological results following TriPollar™ radiofrequency skin treatments. Journal of Cosmetic and Laser Therapy, 11(2), 78-84.
Manuskiatti, W., Wachirakaphan, C., Lektrakul, N., & Varothai, S. (2009). Circumference reduction and cellulite treatment with a TriPollar radiofrequency device: a pilot study. Journal of the European Academy of Dermatology and Venereology, 23(7), 820-827.
Levenberg, A. (2010). Clinical experience with a TriPollar™ radiofrequency system for facial and body aesthetic treatments. European Journal of Dermatology, 20(5), 615-619

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