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Heaven: 2021 Proof Americans and Brits speak a different language

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  • Gee D wrote: »
    [I've never heard of running a mock appeal as preparation for the real event. It probably would not work in those States with a separate Bar, because barristers are self-employed specialist advocates.
    I can see how that might be a problem. The distinction between solicitors and barristers/advocates doesn’t exist anywhere in the US.

  • Nick Tamen wrote: »
    Gee D wrote: »
    [I've never heard of running a mock appeal as preparation for the real event. It probably would not work in those States with a separate Bar, because barristers are self-employed specialist advocates.
    I can see how that might be a problem. The distinction between solicitors and barristers/advocates doesn’t exist anywhere in the US.

    Except in official titles. For instance, while we have an Attorney General over the Justice Department, we have a Solicitor General within the Department of Justice to argue the government's position before the Supreme Court.
  • Gramps49 wrote: »
    Nick Tamen wrote: »
    Gee D wrote: »
    [I've never heard of running a mock appeal as preparation for the real event. It probably would not work in those States with a separate Bar, because barristers are self-employed specialist advocates.
    I can see how that might be a problem. The distinction between solicitors and barristers/advocates doesn’t exist anywhere in the US.

    Except in official titles. For instance, while we have an Attorney General over the Justice Department, we have a Solicitor General within the Department of Justice to argue the government's position before the Supreme Court.
    Yes, but that usage doesn’t reflect the distinction between solicitors and barristers/advocates found in many other countries. That distinction disappeared in the US over a century ago.

    Rather, it reflects a particularly American use of “solicitor” to mean an attorney who represents the government, particularly the chief attorney for a governmental entity. That is the sense in which it is used in titles such as Solicitor General.

  • LeafLeaf Shipmate
    Gramps49 wrote: »
    In Canada, a practice trial between legal students is called a moot trial.
    Nope, it's called moot court in Canada.
  • There's also attorney and lawyer. I don't hear attorney in my province..
  • There's also attorney and lawyer. I don't hear attorney in my province..
    But those are synonymous, at least in the states—two different words for the same thing. Both are heard and are used interchangeably here. Solicitor and barrister/advocate are not different terms for the same thing in those jurisdictions that maintain a distinction between them.

  • Wasn't sure. They're all lawyers here. Prosecutors are called either just prosecutors or 'crown prosecutors'. I believe the term attorney and crown attorney are used in some provinces after taking a look.
  • EnochEnoch Shipmate
    If you really want to show off and demonstrate that you are a true pedant, an attorney practised in the three common law courts, King's/Queen's Bench, Exchequer and Common Pleas. A solicitor practised in the Court of Chancery. A procter practised in the courts of Probate, Divorce and Admiralty. They prepared pleadings etc. None of them actually appeared before a judge in those courts. That was done by barrister.

    These days in England and Wales, the normal term for the person you actually go to see is a Solicitor. It is solicitors who draft and negotiate agreements. Barristers are specialist advocates, and are the only people allowed to present a case on behalf of somebody else in the higher courts. Rather like consultants in other disciplines, they take their instructions from solicitors.

    Solicitors can appear in the lower courts, public enquiries and tribunals. They also practice together in firms. Barristers are not allowed to practice in firms and are self-employed.

  • BroJamesBroJames Purgatory Host
    Since the 1990 Courts and Legal Services Act, solicitors can qualify for a grant of rights of audience in UK higher courts as solicitor advocates. They can even be appointed as Queen’s Counsel.
  • Okay--you have someone who has the power to make health decisions on your behalf should you be unable to make them for yourself. What do you call that document?

    Follow up questions may follow.
  • Leorning CnihtLeorning Cniht Shipmate
    edited January 2021
    Gramps49 wrote: »
    Okay--you have someone who has the power to make health decisions on your behalf should you be unable to make them for yourself. What do you call that document?

    In England, probably what you're looking for is a lasting power of attorney, which has replaced the enduring power of attorney. An LPA must be registered with the Office of the Public Guardian before you can use it; EPAs did not require registration.

    (As I recall, EPAs didn't cover health and welfare issues, but LPAs do. I'm certain we have Uk shipmates with experience of these who can put me right, though.)
  • Gramps49 wrote: »
    Okay--you have someone who has the power to make health decisions on your behalf should you be unable to make them for yourself. What do you call that document?
    That’s one of those things that can, I think, vary by state in the US. Where I live it’s a health care power of attorney.

  • I like "lasting" power of attorney. In the States (or at least this one) it's called "durable" power of attorney. Looks like they can't decide what to call it.
  • Gee DGee D Shipmate
    Nick Tamen wrote: »
    Gramps49 wrote: »
    Nick Tamen wrote: »
    Gee D wrote: »
    [I've never heard of running a mock appeal as preparation for the real event. It probably would not work in those States with a separate Bar, because barristers are self-employed specialist advocates.
    I can see how that might be a problem. The distinction between solicitors and barristers/advocates doesn’t exist anywhere in the US.

    Except in official titles. For instance, while we have an Attorney General over the Justice Department, we have a Solicitor General within the Department of Justice to argue the government's position before the Supreme Court.
    Yes, but that usage doesn’t reflect the distinction between solicitors and barristers/advocates found in many other countries. That distinction disappeared in the US over a century ago.

    Rather, it reflects a particularly American use of “solicitor” to mean an attorney who represents the government, particularly the chief attorney for a governmental entity. That is the sense in which it is used in titles such as Solicitor General.

    Yes, I appreciate that there is no specialist bar in the US, although I'd imagine that a biggish law firm would have partners and employees who specialised in appearance work.

    I think that as well as the Federal government, all Australian States, and perhaps now also the Territories, have a position of Solicitor-General as well as Attorney-General. It's a bit of an anomaly as, despite the name, the Solicitor General is a senior barrister appointed to the position to both represent the government in the most important cases and give advice. The Attorney-General is an elected politician, usually a lawyer and maybe even a senior one, but not always.
  • BroJamesBroJames Purgatory Host
    The same applies for the UK Solicitor General.
  • Gee DGee D Shipmate
    I should have made it more clear that the various Solicitors-General here are not politicians, but statutory appointments. Is that the position in the UK?
  • Nick TamenNick Tamen Shipmate
    edited January 2021
    mousethief wrote: »
    I like "lasting" power of attorney. In the States (or at least this one) it's called "durable" power of attorney. Looks like they can't decide what to call it.
    A durable power-of-attorney and a health care power-of-attorney are different things—similar, but different— at least where I live.

    A health care power of attorney allows your attorney-in-fact to make medical decisions for you should you not be able to make them for yourself because you’re in a coma or the like.

    As for a durable power-of-attorney, a traditional power-of-attorney, which can extend to all kinds matters—financial, property, etc.—became void if and when the person who executed it became incompetent, on the basis that they lost the power to revoke it. At that stage, a guardian had to be appointed by the court to handle matters that previously could be done by the attorney-in-fact. A durable power-of-attorney is “durable” in the sense that it survives the incompetence of the executor.

    As I say, in this state they are two separate things. It’s possible, though, that in some states they’re rolled up into one.
  • There are variations on this theme with important differences. My wife is the health care proxy for her mother in New York, but it is clear that this is different from power of attorney (https://www.health.ny.gov/publications/1430.pdf). We don't yet know if or how it works across international borders.
  • BroJamesBroJames Purgatory Host
    Gee D wrote: »
    I should have made it more clear that the various Solicitors-General here are not politicians, but statutory appointments. Is that the position in the UK?

    They are political appointments in the UK.
  • Gramps49Gramps49 Shipmate
    edited January 2021
    BroJames wrote: »
    Gee D wrote: »
    I should have made it more clear that the various Solicitors-General here are not politicians, but statutory appointments. Is that the position in the UK?

    They are political appointments in the UK.

    Can you explain this a little more?
  • BroJamesBroJames Purgatory Host
    The UK Attorney General and Solicitor General are appointed by the government of the day from among their Members of Parliament.
  • I had "enduring power of attorney" for my father. This is probably regulated provincially in Canada. We also (my wife and I) had the same thing for her parents.

    There may be legal and cultural differences, but the health decisions, while technically coming under the POA, were never formally used. The practice is to talk together - family and medical team (attending physicians, residents, social workers, nurses, specialists) and agree on what the right things to do are for the unconscious or otherwise unable person. These aren't formal meetings really, just talks and notes and phone calls. Talking to others indicates that this is pretty usual.
  • BroJamesBroJames Purgatory Host
    In England and Wales separate Lasting Powers of Attorney are usually expected for finance and property and for health and well-being.
  • Gee DGee D Shipmate
    BroJames wrote: »
    Gee D wrote: »
    I should have made it more clear that the various Solicitors-General here are not politicians, but statutory appointments. Is that the position in the UK?

    They are political appointments in the UK.

    Thanks
  • mousethief wrote: »
    Over here in the northwest we have Tillamook extra sharp cheddar, and in the Seattle area in particular we have Beecher's. Makes a mean mac & cheese.

    But seriously, making mac and cheese isn't like making chicken cordon bleu, but it's still an undertaking that most weekend chefs are going to find laborious.

    Ah, but you are wrong, Mousethief, me lad. Ever heard of making macaroni and cheese in a slow cooker? I just found a recipe online for what sounds like a really tasty mac and cheese, and one doesn't even need to cook the macaroni before adding it to the slow cooker. Two cans of evaporated milk, uncooked macaroni, lots of cheddar cheese, seasonings, etc. I have most of the ingredients for this but haven't gotten to the grating of the cheese. For someone who is arthritic as I am, grating vast quantities of cheese is going to require some help from the Almighty.

    Anyway, this slow cooker recipe takes three hours on Low, and an hour and a half on the high setting. I'll let you know how it turns out.
  • Gee DGee D Shipmate
    Gramps49 wrote: »
    BroJames wrote: »
    Gee D wrote: »
    I should have made it more clear that the various Solicitors-General here are not politicians, but statutory appointments. Is that the position in the UK?

    They are political appointments in the UK.

    Can you explain this a little more?

    Gramps, it means that the holder of the office is an elected politician of the governing party. That's very different to the position here, where the S-G has for many years been appointed under the provisions of a piece of legislation and holds office for the term of the appointment. For example, Keith Mason was appointed Solicitor-General for NSW for terms totalling 10 years, before he was appointed President of the Court of Appeal. His predecessor, Mary Gaudron, was appointed from the position to become a Justice of the High Court*.

    *And to save your needing to ask, the Court of Appeal is the highest court of this State, and the High Court is pretty much equivalent to the US Supreme Court.
  • The5thMary wrote: »
    mousethief wrote: »
    Over here in the northwest we have Tillamook extra sharp cheddar, and in the Seattle area in particular we have Beecher's. Makes a mean mac & cheese.

    But seriously, making mac and cheese isn't like making chicken cordon bleu, but it's still an undertaking that most weekend chefs are going to find laborious.

    Ah, but you are wrong, Mousethief, me lad. Ever heard of making macaroni and cheese in a slow cooker?
    Just no! Macaroni and cheese needs to be baked.* That said, it’s not at all complicated or laborious. The hardest part is cooking the pasta and grating the cheese. Beyond that, it’s just mixing egg, butter and milk and putting it all in a baking dish.


    * I kid, sort of. :wink: I know this is one of those things people have differing, and strong, opinions about. Baked macaroni and cheese is the only kind I get excited about or think of as comfort food—the béchamel-style just doesn’t do it for me—but I know others feel differently. Hope it turns out to your liking.

  • I think you both greatly overestimate the cooking prowess (and desire) of the average American. This is a country where you can buy garlic bread in the freezer section and the grocery store has a steam table with seven different kinds of chicken wings. People don't cook as much as one might hope.
  • Nick Tamen wrote: »
    The5thMary wrote: »
    mousethief wrote: »
    Over here in the northwest we have Tillamook extra sharp cheddar, and in the Seattle area in particular we have Beecher's. Makes a mean mac & cheese.

    But seriously, making mac and cheese isn't like making chicken cordon bleu, but it's still an undertaking that most weekend chefs are going to find laborious.

    Ah, but you are wrong, Mousethief, me lad. Ever heard of making macaroni and cheese in a slow cooker?
    Just no! Macaroni and cheese needs to be baked.* That said, it’s not at all complicated or laborious. The hardest part is cooking the pasta and grating the cheese. Beyond that, it’s just mixing egg, butter and milk and putting it all in a baking dish.


    * I kid, sort of. :wink: I know this is one of those things people have differing, and strong, opinions about. Baked macaroni and cheese is the only kind I get excited about or think of as comfort food—the béchamel-style just doesn’t do it for me—but I know others feel differently. Hope it turns out to your liking.

    I DO prefer a gigantic pan of baked macaroni and cheese but the labor and physical pain ("You shall have pain in labor"-God) aren't worth it. I have made slow cooker mac and cheese before and it turned out okay. Too much cheddar cheese because my partner at the time insisted that she wanted a "truckload of cheese!" made it greasy but that didn't stop girlfriend and I from devouring it.

    I do like the idea of a dash of cayenne pepper and/or dry mustard, though.
  • I would fear the slow-cooker variety would end up with noodles that are so mushy you can hardly detect their presence.
  • Nope. You have to keep an eye on it and during the last half hour of cooking, partially remove the lid.
  • Sounds like far too much hassle when simply cooking the pasta whilst you make the cheese sauce is so easy and quick.
  • 5thMary, I have a powered grater/slicer from Russell Hobbs (I think this is probably UK, but I expect there's something similar your side) https://en.russellhobbs.com/product/desire-food-slicer-shredder-grater-22280-56
    I grate a huge slab of cheddar at one go into a zip bag and keep it in the freezer. The slab needs to be cut into sections that fit down the feeder. It saves a lot of effort. (I used to buy grated cheese because I worked out it was cheaper per 100g than not grated, but it has now got very much more expensive.)
  • orfeoorfeo Suspended
    This language thread devolves into food on a very regular basis.
  • Gee DGee D Shipmate
    The5thMary wrote: »
    Nope. You have to keep an eye on it and during the last half hour of cooking, partially remove the lid.

    And by the sounds of it, make sure that the cooker is lined with baking paper.
  • It all sounds like a massive waste of time to me. Why not just cook your pasta of choice and then fold through some carbonara sauce, minus the meat?
  • It all sounds like a massive waste of time to me. Why not just cook your pasta of choice and then fold through some carbonara sauce, minus the meat?
    Because I want macaroni and cheese, not macaroni alla carbonara? Because pasta alla carbonara without the meat is a grievous sin?

    The simple way is to beat egg, milk and melted butter, pour it over the cooked pasta and grated cheese, and bake. Done.

  • "Carbonara sauce" is just egg and a bit of pasta cooking water.

    I know some people do something with cream under the name but it's Wrong.
  • BroJamesBroJames Purgatory Host
    There just are different ways of making a dish that has similar names both sides of the Atlantic. ‘Simple’ is likely to be what you are used to. ‘Better’ is a matter of taste.

    Personally I wouldn’t use egg. I’d cook the macaroni and make a simple white sauce with cheese added. Drain the cooked macaroni and stir in the cheese sauce. It can be ready to eat from scratch in about twenty minutes.

    If I want something fancier, I might transfer it to an ovenproof dish, add a grated cheese and fresh breadcrumb topping, perhaps with a little butter also, and decorate with tomato slices. Then put the dish under a heated grill until the topping is nicely browned.
  • TrudyTrudy Heaven Host
    edited February 2021
    orfeo wrote: »
    This language thread devolves into food on a very regular basis.

    It can be very hard to separate the two sometimes! I think a good rule is that once you start giving specific cooking instructions, the discussion of "What we call this dish here vs there" has turned into "How we make this dish here," and should probably migrate to the recipe thread. We have definitely strayed from language to recipe discussion in the macaroni & cheese conversation.

    Get thee hence to the recipe thread with the delicious mac'n'cheese variations, and let's return to What We Call Things on this thread.

    Trudy, Heavenly Host
  • KarlLB wrote: »
    "Carbonara sauce" is just egg and a bit of pasta cooking water.

    I know some people do something with cream under the name but it's Wrong.

    That's still not cheese.
  • BroJames wrote: »
    There just are different ways of making a dish that has similar names both sides of the Atlantic. ‘Simple’ is likely to be what you are used to. ‘Better’ is a matter of taste.

    Personally I wouldn’t use egg. I’d cook the macaroni and make a simple white sauce with cheese added. Drain the cooked macaroni and stir in the cheese sauce. It can be ready to eat from scratch in about twenty minutes.

    If I want something fancier, I might transfer it to an ovenproof dish, add a grated cheese and fresh breadcrumb topping, perhaps with a little butter also, and decorate with tomato slices. Then put the dish under a heated grill until the topping is nicely browned.

    Exactly! The only minor addition I would make to this is to add cayenne pepper after the cheese has melted.
  • Nick TamenNick Tamen Shipmate
    edited February 2021
    KarlLB wrote: »
    "Carbonara sauce" is just egg and a bit of pasta cooking water.

    I know some people do something with cream under the name but it's Wrong.
    Technically speaking, there is no such thing as “carbonara sauce,” just as technically speaking there’s no such thing as “Alfredo sauce.” There’s pasta Alfredo and pasta alla carbonara.

    But “carbonara sauce” isn’t just egg and pasta water. It’s egg, Pecorino Romano and/or Parmigiano-Reggiano, pepper and pasta water.

  • Yeah, I forgot the cheese because I have to add it afterwards as one of the kids is dairy intolerant.
  • MMMMMM Shipmate
    (Tangent: I once had an e-mail from the secretary of someone attending a meeting I was holding to remind me that he was diary intolerant).

    MMM
  • Pangolin GuerrePangolin Guerre Shipmate
    edited February 2021
    KarlLB wrote: »
    "Carbonara sauce" is just egg and a bit of pasta cooking water.

    I know some people do something with cream under the name but it's Wrong.

    Cream = wrong.

    But, carbonara requires guanciale and parmigiano. (Ref. Marcella Hazan.)
  • I'm starting to think there are as many carbonaras as there are carbonara chefs.
  • Gee DGee D Shipmate
    mousethief wrote: »
    I'm starting to think there are as many carbonaras as there are carbonara chefs.

    I'd started and finished with that.
  • Gee D wrote: »
    mousethief wrote: »
    I'm starting to think there are as many carbonaras as there are carbonara chefs.

    I'd started and finished with that.

    Where?
  • KarlLB wrote: »
    "Carbonara sauce" is just egg and a bit of pasta cooking water.

    I know some people do something with cream under the name but it's Wrong.

    Cream = wrong.

    But, carbonara requires guanciale and parmigiano. (Ref. Marcella Hazan.)

    I explained the cheese thing.

    You can't get guanciale around here to my knowledge.
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