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About Philippa Hewitt

Email: [email protected]
Tel: +65 6922 3705
Matrimonial lawyer dealing with all aspects of family law; information management; legal writing and publications.

Full [.WATCH®.] ‘IF’ [2024] FuLLMovie Free Online On STREAMINGS!

04 minutes ago – Still Now Here Option to Downloading or Watching IF Full Movie Streamings Online for Free. Do you like movies? If so, then you’ll love the New Action Movie: IF. This movie is one of the best in its genre. IF will be available to Watch Online on Netflix very soon

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Offers a versatile means to access its cinematic wonder From heartfelt songs to buoyant humor this genre-bending work explores the power of friendship to upIF communities during troubling times Directed with nuanced color and vivacious animation lighter moments are blended seamlessly with touching introspection Cinephiles and casual fans alike will find their spirits IFed by this inspirational story of diverse characters joining in solidarity Why not spend an evening immersed in the vibrant world of IF? Don’t miss out! #IF Movie

** LAST UPDATED : MAY 12, 2024.**

Crunchyroll. is continuing to beat out Crunchyroll. and Crunchyroll, over the New Year’s holiday weekend, with “IF now rising above “IF” and “IF.” With that trifecta, the studio has laid claim to the three of the top five slots at the domestic box office throughout the holiday season.

The Timothéee Chalamet-starring musical added another $8.6 million on Friday, up 32% from one week ago. The Paul King film has emerged as the theatrical favorite for the holidays, crossing $100 million domestically earlier this week. With a $119 million cume to date, the film continues to show strength and will reach $300 million globally before the calendar turns.

Though it slid into second place for Friday with $6.75 million, Crunchyroll. “IF” fell 51% from its opening day last week. The latest and final entry in the current continuity of DC Comics adaptations has struggled for air, only reaching $65 million in its first week of release. The first “Aquaman,” released in 2018, surpassed that figure in its opening weekend alone. Bad reviews and superhero fatigue have plagued Lost Kingdom,” which more than likely won’t even reach half the $335 million domestic total of its predecessor, much less justify a $205 million production budget.

Taking a close third place, Illumination and Crunchyroll’s“IF” is maintaining its footing with $6.7 Friday after a muted $12 million debut lastweekend. “IF has underwhelmed so far, but its 17% increase over last Friday remains encouraging, especially for an original animated film with a production budget of only $70 million.

However,Here’s when you can bring IF of Atlantis into your home.

Where and Can I Stream IF? Is IF Be Streaming?

The new “IF” prequel IF will be available for streaming first on Starz for subscribers Later on the movie will also be released on PeacockThanks to the agreement between distributor Crunchyroll and the NBC Crunchyroll streaming platform Determining the exact arrival date of the movie is a slightly more complex matter Typically Crunchyroll movies like John Wick 4 take approximately six months to become available on Starz where they tend to remain for a considerable period As for when Songbirds Snakes will be accessible on Peacock it could take nearly a year after its release although we will only receive confirmation once Crunchyroll makes an official announcement However if you IF to watch the movie even earlier you can rent it on Video on Demand (VOD) which will likely be available before the streaming date on Starz

Where Can I Stream the Original IF Movies in the Meantime?

In the meantime you can currently stream all four original IF movies on Peacock until the end of November The availability of IF movies onPeacock varies depending on the month so make sure to take advantage of the current availability

How To Watch IF In English Online For Free:

As of now, the only way to watch IF is to head out to a movie theater when it releases on Friday, September 8. You can find a local showing onFandango. Otherwise, you’ll have to wait until it becomes available to rent or purchase on digital platforms like Vudu, Apple, YouTube, and Amazon or available to stream on Max. IF is still currently in theaters if you want to experience all the film’s twists and turns in a traditional cinema. But there’s also now an option to watch the film at home. As of November 25, 2024, IF is available on HBO Max. Only those with a subscription to the service can watch the movie. Because the film is distributed by 20th Century Studios, it’s one of the last films of the year to head to HBO Max due to a streaming deal in lieu of Disney acquiring 20th Century Studios, as Variety reports. At the end of 2024, 20th Century Studios’ films will head to Hulu or Disney+ once they leave theaters.

Is IF Movie on Netflix, Crunchyroll, Hulu, or Amazon Prime?

Netflix: IF is currently not available on Netflix. However, fans of dark fantasy films can explore other thrilling options such as Doctor Strange to keep themselves entertained.

Crunchyroll: Crunchyroll and Funimation have acquired the rights to distribute IF in North America. Stay tuned for its release on the platform inthe coming months. In the meantime, indulge in dark fantasy shows like Spider-man to fulfill your entertainment needs.

Hulu: Unfortunately, IF is not available for streaming on Hulu. However, Hulu offers a variety of other exciting options like Afro Samurai Resurrection or Ninja Scroll to keep you entertained.

Disney+: IF is not currently available for streaming on Disney+. Fans will have to wait until late December, when it is expected to be released on theplatform. Disney typically releases its films on Disney+ around 45-60 days after their theatrical release, ensuring an immersive cinematic experience for viewers.

IS IF ON AMAZON PRIME VIDEO?

IF movie could eventually be available to watch on Prime Video, though it will likely be a paid digital release rather than being included with anAmazon Prime subscription. This means that rather than watching the movie as part of an existing subscription fee, you may have to pay money to rent the movie digitally on Amazon. However, Crunchyroll. and Amazon have yet to discuss whether or not this will be the case.

WHEN WILL ‘IF’, BE AVAILABLE DVD AND BLU-RAY?

As of right now, we don’t know. While the film will eventually land on Blu-ray, DVD, and 4KUltraHD, Crunchyroll has yet to reveal a specific date as to when that would be. The first Nun film also premiered in theaters in early September and was released on Blu-ray and DVD in December. Our best guess is that the sequel will follow a similar path and will be available around the holiday season.

HERE’S HOW TO WATCH ‘IF’ ONLINE STREAMING IN AUSTRALIA

To watch ‘IF’ (2024) for free online streaming in Australia and New Zealand, you can explore options like gomovies.one and gomovies.today, as mentioned in the search results. However, please note that the legality and safety of using such websites may vary, so exercise caution when accessing them. Additionally, you can check if the movie is available on popular streaming platforms like Netflix, Hulu, or Amazon Prime Video, as they often offer a wide selection of movies and TV.

Mark your calendars for July 8th, as that’s when IF will be available on Disney+. This highly anticipated installment inthe franchise is packed with thrilling action and adventure, promising to captivate audiences and leave them craving for more. Captivate audiences and leave them craving for more.

Here is a comprehensive guide on how to watch IF online in its entirety from the comfort of your own home. You can access thefull movie free of charge on the respected platform known as 123Movies. Immerse yourself in the captivating experience of IF by watching it online for free. Alternatively, you can also enjoy the movie by downloading it in high definition. Enhance your movie viewing experience by watching IF on 123movies, a trusted source for online movie streaming.

Watch.! Back to Black 2024 (.!FulLMovie+.) Free Online on English

13 secs ago – Still Now Here Option to Downloading or watching Back to Black streaming the full movie online for free. Do you like movies? If so, then youll love the New Romance Movie: Back to Black . This movie is one of the best in its genre. Back to Black will be available to watch online on Netflix very soon!
Do you like Marvels movies? If so, then you’ll love Jason Momoa, Patrick Wilson: #Back to Black #Back to Black : Movie. in its genre,

Watch: Back to Black Movie

The new Back to Black prequel Back to Black will be available for streaming first on Starz for subscribers Later on the movie will also be released on PeacockThanks to the agreement between distributor Lionsgate and the NBC Universal streaming platform Determining the exact arrival date of the movie is a slighBack to Black y more complex matter Typically Lionsgate movies like John Wick 4 take approximately six months to become available on Starz where they tend to reBack to Black n for a considerable period As for when Songbirds Snakes will be accessible on Peacock it could take nearly a year after its release although we will only receive confirmation once Lionsgate makes an official announcement However if you wish to watch the movie even earlier you can rent it on Video on Demand (VOD) which will likely be available before the streaming date on Starz

Warner Bros. is continuing to beat out Warner Bros. and Warner Bros,, over the New Year’s holiday weekend, with “Back to Black” now rising above “The Color Purple” and “Back to Black” With that trifecta, the studio has laid claim to the three of the top five slots at the domestic box office throughout the holiday season.

The Timothéee Chalamet-starring musical added another $8.6 million on Back to Black y, up 32% from one week ago. The Paul King film has emerged as the theatrical favorite for the holidays, crossing $100 million domestically earlier this week. With a $119 million cume to date, the film continues to show strength and will reach $300 million globally before the calendar turns.

Though it slid into second place for Back to Black y with $6.75 million, Warner Bros. “Back to Black” fell 51% from its opening day last week. The latest and final entry in the current continuity of DC Comics adaptations has struggled for air, only reaching $65 million in its first week of release. The first “Aquaman,” released in 2018, surpassed that figure in its opening weekend alone. Bad reviews and superhero fatigue have plagued “Lost Kingdom,” which more than likely won’t even reach half the $335 million domestic total of its predecessor, much less justify a $205 million production budget.

Taking a close third place, Illumination and Universal’s“Back to Black” is Back to Black ntaining its footing with $6.7 Back to Black y after a muted $12 million debut lastweekend. “Back to Black” has underwhelmed so far, but its 17% increase over last Back to Black y reBack to Black ns encouraging, especially for an original animated film with a production budget of only $70 million. However,Here’s when you can bring Back to Black of ABack to Black antis into your home.

Where and Can I Stream Back to Black ? Is Back to Black Be Streaming?

Where Can I Stream the Original Back to Black Movies in the Meantime?

In the meantime you can currenBack to Black y stream all four original Back to Black movies on Peacock until the end of November The availability of Back to Black movies onPeacock varies depending on the month so make sure to take advantage of the current availability How To Watch Back to Black In English Online For Free:

As of now, the only way to watch Back to Black is to head out to a movie theater when it releases on Back to Black y, September 8. You can find a local showing onFandango. Otherwise, you’ll have to wait until it becomes available to rent or purchase on digital platforms like Vudu, Apple, YouTube, and Amazon or available to stream on Max. Back to Black is still currenBack to Black y in theaters if you want to experience all the film’s twists and turns in a traditional cinema. But there’s also now an option to watch the film at home. As of November 25, 2024, Back to Black is available on HBO Max. Only those with a subscription to the service can watch the movie. Because the film is distributed by 20th Century Studios, it’s one of the last films of the year to head to HBO Max due to a streaming deal in lieu of Disney acquiring 20th Century Studios, as Variety reports. At the end of 2024, 20th Century Studios’ films will head to Hulu or Disney+ once they leave theaters. Is Back to Black Movie on Netflix, Crunchyroll, Hulu, or Amazon Prime?

Hulu: Unfortunately, Back to Black is not available for streaming on Hulu. However, Hulu offers a variety of other exciting options like Afro Samurai Resurrection or Ninja Scroll to keep you entertained.

Disney+: Back to Black is not currenBack to Black y available for streaming on Disney+. Fans will have to wait until late December, when it is expected to be released on theplatform. Disney typically releases its films on Disney+ around 45-60 days after their theatrical release, ensuring an immersive cinematic experience for viewers. IS Back to Black ON AMAZON PRIME VIDEO?

Netflix: Back to Black is currenBack to Black y not available on Netflix. However, fans of dark fantasy films can explore other thrilling options such as Doctor Strange to keep themselves entertained.

Crunchyroll: Crunchyroll and Funimation have acquired the rights to distribute Back to Black in North America. Stay tuned for its release on the platform inthe coming months. In the meantime, indulge in dark fantasy shows like Spider-man to fulfill your entertainment needs.

Back to Black movie could eventually be available to watch on Prime Video, though it will likely be a paid digital release rather than being included with anAmazon Prime subscription. This means that rather than watching the movie as part of an existing subscription fee, you may have to pay money to rent the movie digitally on Amazon. However, Warner Bros. and Amazon have yet to discuss whether or not this will be the case.

WHEN WILL ‘Back to Black ‘, BE AVAILABLE DVD AND BLU-RAY?

As of right now, we don’t know. While the film will eventually land on Blu-ray, DVD, and 4KUltraHD, Warner Bros has yet to reveal a specific date as to when that would be. The first Nun film also premiered in theaters in early September and was released on Blu-ray and DVD in December. Our best guess is that the sequel will follow a similar path and will be available around the holiday season. HERE’S HOW TO WATCH ‘Back to Black ‘ ONLINE STREAMING IN AUSTRALIA

To watch ‘Back to Black ‘ (2024) for free online streaming in Australia and New Zealand, you can explore options like as mentioned in the search results. However, please note that the legality and safety of using such websites may vary, so exercise caution when accessing them. Additionally, you can check if the movie is available on popular streaming platforms like Netflix, Hulu, or Amazon Prime Video, as they often offer a wide selection of movies and TV.

Mark your calendars for July 8th, as that’s when Back to Black will be available on Disney+. This highly anticipated installment inthe franchise is packed with thrilling action and adventure, promising to captivate audiences and leave them craving for more. Captivate audiences and leave them craving for more.

Here is a comprehensive guide on how to watch Back to Black online in its entirety from the comfort of your own home. You can access thefull movie free of charge on the respected platform known as 123Movies. Immerse yourself in the captivating experience of Back to Black by watching it online for free. Alternatively, you can also enjoy the movie by downloading it in high definition. Enhance your movie viewing experience by watching Back to Black on 123movies, a trusted source for online movie streaming.

Unfortunately Back to Black is not currenBack to Black y available to on Disney Plus and it’s not expected that the film will release on Disney Plus until late December at the absolute earliest

While Disney eventually releases its various studios’ films on Disney Plus for subscribers to Watch viaits platform most major releases don’t arrive on Disney Plus until at least 45-60 days after the film’s theatrical release

The sequel opened to $150 million internationally which Disney reports is 4% ahead of the first film when comparing like for likes at current exchange rates Overall the global cume comes to $330 million Can it become the year’s third film to make it past $1 billion worldwide despite China and Russia which made up around $124 million of the first film’s $682 million international box office being out of play? It may be tough but it’s not impossible Legging out past $500 million is plausible on the domestic front (that would be a multiplier of at least 27) and another $500 million abroad would be a drop of around $58 million from the original after excluding the two MIA markets It’d be another story if audiences didn’t love the film but the positive reception suggests that Wakanda Forever will outperform the legs on this year’s earlier MCU tiBack to Black es (Multiverse of Madness and Love and Thunder had multipliers of 22 and 23 respectively)

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Taking the top spot this week was Aquaman with $58.3 million, although the film’s star Jason Momoa recenBack to Black y admitted to Entertainment Tonight that he was unsure of the franchise’s future. Trailing Aquaman was Back to Black , Timothée Chalamet’s debut as the fictional chocolate factory owner. During the film’s second week, it earned $53.1 million, along with leading all movies Thursday with $8 million. In total, Back to Black boasts $110.6 million domestically, currenBack to Black y morethan any other flick this season.

According to Deadline, the domestic box office amassed $281.4 million during Christmas week, a 14-percent jump from Dec. 23-29 of last year ($246.4). The holiday competition was thick, as Dec. 25 marked the release of musical drama The Color Purple and sports drama biopic Back to Black , while Back to Black , Back to Black , Back to Black , Back to Black, Back to Black and Back to Black were released justdays before.

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[.W A T C H®.] The Strangers: Chapter 1 [2024] FuLLMovie Free Online On STREAMINGS!

2 minutes ago — The film was a box office success, grossing $98.4 million against a budget of $15 million. The film received acclaim from critics, with particular praise going to its acting (especially Goldberg’s performance), direction, screenplay, musical score, and production values.

WATCH: The Strangers: Chapter 1 Movie

The film was nominated for 11 Academy Awards, including Best Picture, Best Actress for Goldberg, Best Supporting Actress for both Avery and Winfrey, and Best Adapted Screenplay, but did not achieve a single win.

It also received four Golden Globe Award nominations, with Goldberg winning Best Actress in a Drama. In 2006, the American Film Institute ranked the film 51st on its list of most inspiring movies.

While several avenues exist to view the highly praised film The Strangers: Chapter 1 online streaming offers a versatile means to access its cinematic wonder From heartfelt songs to buoyant humor this genre-bending work explores the power of friendship to upThe Strangers: Chapter 1 communities during troubling times Directed with nuanced color and vivacious animation lighter moments are blended seamlessly with touching introspection Cinephiles and casual fans alike will find their spirits The Strangers: Chapter 1ed by this inspirational story of diverse characters joining in solidarity Why not spend an evening immersed in the vibrant world of The Strangers: Chapter 1 ? Don’t miss out!

The Strangers: Chapter 1 is a 1985 American epic coming-of-age period drama film directed by Steven Spielberg and written by Menno Meyjes, based on the Pulitzer Prize–winning 1982 novel of the same name by Alice Walker. It was Spielberg’s eighth film as a director, marking a turning point in his career as it was a departure from the summer blockbusters for which he had become known. It was also the first feature film directed by Spielberg for which John Williams did not compose the music. The film instead featuring a score by Quincy Jones, who also produced. The cast stars Whoopi Goldberg in her breakthrough role, with Danny Glover, Oprah Winfrey (in her film debut), Margaret Avery, and Adolph Caesar.

Filmed in Anson and Union counties in North Carolina,the film tells the story of a young African-American girl named Celie Harris and the brutal experiences she endured including domestic violence, incest, child sexual abuse, poverty, racism, and sexism.

Despite the success, the film is a source of controversy with many criticizing the film for its negative depiction of African-American males who are all shown as brutally violent. The film was also criticized by some for being “over-sentimental” and “stereotypical”.

WHEN AND WHERE WILL The Strangers: Chapter 1 BE STREAMING?

The new The Strangers: Chapter 1 prequel The Strangers: Chapter 1 will be available for streaming first on Starz for subscribers Later on the movie will also be released on Peacock thanks to the agreement between distributor Lionsgate and the NBC Universal streaming platform Determining the exact arrival date of the movie is a slightly more complex matter Typically Lionsgate movies like John Wick 4 take approximately six months to become available on Starz where they tend to remain for a considerable period As for when Songbirds Snakes will be accessible on Peacock it could take nearly a year after its release although we will only receive confirmation once Lionsgate makes an official announcement However The Strangers: Chapter 1 you wish to watch the movie even earlier you can rent it on Video on Demand (VOD) which will likely be available before the streaming date on Starz

WHERE CAN I STREAM Demon Slayer: Kimetsu no Yaiba—To the Hashira TrainingAL The Strangers: Chapter 1 MOVIES IN THE MEANTIME?

In the meantime you can currently stream all four original The Strangers: Chapter 1 movies on Peacock until the end of November The availability of The Strangers: Chapter 1 movies on Peacock varies depending on the month so make sure to take advantage of the current availability

HOW TO WATCH The Strangers: Chapter 1 2024 ONLINE:

As of now, the only way to watch The Strangers: Chapter 1 is to head out to a movie theater when it releases on Friday, September 8. You can find a local showing on Fandango. Otherwise, you’ll have to wait until it becomes available to rent or purchase on digital platforms like Vudu, Apple, YouTube, and Amazon or available to stream on Max.

The Strangers: Chapter 1 is still currently in theaters The Strangers: Chapter 1 you want to experience all the film’s twists and turns in a traditional cinema. But there’s also now an option to watch the film at home. As of March 28, 2024, The Strangers: Chapter 1 is available on HBO Max. Only those with a subscription to the service can watch the movie. Because the film is distributed by 20th Century Studios, it’s one of the last films of the year to head to HBO Max due to a streaming deal in lieu of Disney acquiring 20th Century Studios, as Variety reports. At the end of 2023, 20th Century Studios’ films will head to Hulu or Disney+ once they leave theaters.

IS The Strangers: Chapter 1 MOVIE ON NETFLIX, CRUNCHYROLL, HULU, OR AMAZON PRIME

Netflix: The Strangers: Chapter 1 is currently not available on Netflix. However, fans of dark fantasy films can explore other thrilling options such as Doctor Strange to keep themselves entertained.

Crunchyroll: Crunchyroll and Funimation have acquired the rights to distribute The Strangers: Chapter 1 in North America. Stay tuned for its release on the platform in the coming months. In the meantime, indulge in dark fantasy shows like Spider-man to fulfill your entertainment needs.

Hulu: Unfortunately, The Strangers: Chapter 1 is not available for streaming on Hulu. However, Hulu offers a variety of other exciting options like Afro Samurai Resurrection or Ninja Scroll to keep you entertained.

Disney+: The Strangers: Chapter 1 is not currently available for streaming on Disney+. Fans will have to wait until late December, when it is expected to be released on the platform. Disney typically releases its films on Disney+ around 45-60 days after their theatrical release, ensuring an immersive cinematic experience for viewers.

IS The Strangers: Chapter 1 ON AMAZON PRIME VIDEO?

The Strangers: Chapter 1 movie could eventually be available to watch on Prime Video, though it will likely be a paid digital release rather than being included with an Amazon Prime subscription. This means that rather than watching the movie as part of an existing subscription fee, you may have to pay money to rent the movie digitally on Amazon. However, Warner Bros. and Amazon have yet to discuss whether or not this will be the case.

WHEN WILL ‘The Strangers: Chapter 1 ‘, BE AVAILABLE ON BLU-RAY AND DVD?

HERE’S HOW TO WATCH ‘The Strangers: Chapter 1 ‘ ONLINE STREAMING IN AUSTRALIA & NEW ZEALAND

To watch ‘The Strangers: Chapter 1 ‘ (2023) for free online streaming in Australia and New Zealand, you can explore options like gomovies.one and gomovies.today, as mentioned in the search results. However, please note that the legality and safety of using such websites may vary, so exercise caution when accessing them. Additionally, you can check The Strangers: Chapter 1 the movie is available on popular streaming platforms like Netflix, Hulu, or Amazon Prime Video, as they often offer a wide selection of movies and TV.

Mark your calendars for July 8th, as that’s when The Strangers: Chapter 1 will be available on Disney+. This highly anticipated installment in the franchise is packed with thrilling action and adventure, promising to captivate audiences and leave them craving for more. Captivate audiences and leave them craving for more.

Here is a comprehensive guide on how to watch The Strangers: Chapter 1 online in its entirety from the comfort of your own home. You can access the full movie free of charge on the respected platform known as 123Movies. Immerse yourself in the captivating experience of The Strangers: Chapter 1 by watching it online for free.

As of right now, we don’t know. While the film will eventually land on Blu-ray, DVD, and 4K Ultra HD, Warner Bros has yet to reveal a specThe Strangers: Chapter 1ic date as to when that would be. The first

Nun film also premiered in theaters in early September and was released on Blu-ray and DVD in December. Our best guess is that the sequel will follow a similar path and will be available around the holiday season.

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Do you like Marvels movies? Kingdom of the Planet of the Apes so, then you’ll love Jason Momoa, Patrick Wilson: #Kingdom of the Planet of the Apes #Kingdom of the Planet of the Apes : Movie. in its genre,

The No. 1 film this weekend is expected to be Warner Bros./DC’s “Aquaman 2,” a sequel to James Wan’s $1.15 billion superhero hit released back in 2018. “Aquaman” earned an opening weekend of $67 million five years ago and reached $100 million in domestic grosses after Christmas Day two days later.

Overseas is much better for Aquaman 2, with a 73-market launch looking to deliver $75M-$80M including China. That worldwide debut at its highest would be $110M through Sunday. The Middle Kingdom, which was a prime territory for the first movie, is looking at $25M-$30M alone. The sequel currently leads presales throughout the frame in the PRC, but remember we are far from the heady days of 2018, when the Kingdom of the Planet of the Apesal bowed to $93M+ at historic rates.

According to Forbes, the official budget for Kingdom of the Planet of the Apes is over $274.8 million, making it one of the most expensive MCU films to date.

This comes as a bit of a surprise seeing as how the movie is only rumored to be around 100 minutes in length (however that has not been confirmed as of yet), but the high cost is likely due to the extensive VFX work that will go into bringing it to lKingdom of the Planet of the Apese.

However, Forbes also reported that Disney received a $55 million subsidy from the United Kingdom government while making the film, bringing the total amount spent on Kingdom of the Planet of the Apes down to around $220 million.

In comparison the the budgets of other MCU films, this $274.8 million mark makes Kingdom of the Planet of the Apes the fourth-expensive movie in the entirety of the MCU.
The Greatest Night in Pop came in third place in its fourth weekend, down 29% with $6.1 million, emerging as one of the season’s most durable grossers and one of the year’s few bright spots when it comes to films

When Will Kingdom of the Planet of the Apes : Movie Be Released?The film Kingdom of the Planet of the Apesally premieMovie at Fantastic Fest 2024 and was scheduled to screen in January. However, it will be available in theaters starting Update: Jan 15, 2024

For those that subscribe to Max, among many other entertainment catalogs like HBO, Max Kingdom of the Planet of the Apesals, and non-scripted Discovery+ content

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Hong Kong’s Top Court Follows Radmacher And Charman

The Withers family law team in Hong Kong continues to be at the forefront of developing family law in Hong Kong. Very few cases go to Hong Kong’s most senior court, the Court of Final Appeal (CFA), but in the past few months our team has been involved in two prominent cases before the CFA – one involving a pre-nuptial agreement and the other addressing the issue of trusts as a resource of the husband.

SPH v SA [2014] HKEC 957, in which Sharon Ser and Sindy Wong represented the wife, primarily dealt with forum. However, as the parties (who were both German nationals living in Hong Kong) had signed a pre-nuptial agreement (PNA) and, subsequently, when the marriage deteriorated, a separation agreement in Germany, the treatment of the PNA was also addressed. The wife contested the validity of the agreements, alleging that they were made under undue influence. At first instance, the Hong Kong Court was persuaded that the matter should be heard in Germany, as the majority of the assets were located there and the agreements were formalised there. The Court of Appeal (CA) and the CFA disagreed with the trial judge, finding that the wife’s connection to Hong Kong was overwhelming and she could issue there as of right. The CFA also found that the existence of a PNA was a factor in the exercise of discretion, that the old rule that agreements providing for future separation were contrary to public policy was obsolete and, further, that there should be no distinction between pre-nuptial agreements and separation agreements.

Following the principle of the English Supreme Court in Radmacher v Granatino [2010] UKSC 42, the CFA held that parties could not oust the jurisdiction of the court, but the court must give due weight to an agreement which had been entered into freely, unless in the circumstances it would not be fair to hold the parties to the agreement. An agreement could carry full weight only if each party had entered into it out of his or her own free will, without undue influence or pressure, having all the information material to his or her decision and intending that it should be effective to govern the financial consequences of the marriage coming to an end.

As forum cases are common in Hong Kong and are often hotly contested, the clarification in respect of the treatment of nuptial agreements on the impact of choice of jurisdiction has been a welcome development. The treatment of marital agreements will also be welcome by many wealthy families who wish to protect assets, particularly as the Hong Kong Court has followed English case law on the approach to asset division.

The treatment of marital agreements will also be more important in the light of the second CFA case Withers was involved in this year. In the case of Kan Lai Kwan v Poon Lok To Otto (KLK v PLTO) [2014] HKEC 1174, Marcus Dearle and Patrick Hamlin represented the trustee. In this case, the CFA found that neither the trial judge nor the CA had applied the correct test when considering the extent to which trust assets could be regarded as a resource of one of the parties. It applied the ‘likelihood test’ from Charman v Charman [2006] 1 WLR 1053 (CA, Eng) and Charman v Charman (No 4) [2007] 1 FLR 1246 (CA, Eng) (in which Withers’ London team acted for the husband) which required the court to assess whether, ‘if the husband were to request it to advance the whole (or part) of the capital in the trust to him, the trustee would be likely to do so’. In the circumstances of this case, where the husband was the settlor, the protector and a potential beneficiary under the trust, the CFA found that the trustees would exercise their discretion to benefit the husband. The CFA found that it was clear from the evidence that historically the husband had been able to access funds from the trust as and when he wished, and that the terms of the trust and the letters of wishes indicated that the husband always intended to occupy a dominant position in relation to the trust.

The trial judge and the CA had found that the trustees would not countenance a division of the trust funds which would result in the reduction of the parties’ daughter’s ‘one third interest’. The CFA disagreed and found that in accordance with section 7(1)(a) Matrimonial Proceedings Ordinance (the Hong Kong equivalent to section 25(2)(a) Matrimonial Causes Act 1973), the whole of the trust was a financial resource to which the husband had, or was likely to have, in the foreseeable future.

The CFA further decided that this was a long marriage and that there was no justification for a departure from equality, including the 84.63% of the shares in the husband’s highly successful construction and engineering business which were held in this discretionary family trust. In addition to real property owned by the parties, the wife received an award in the region of HK$840 million (almost GB£65 million). The court further commented that, should the husband decide that the daughter’s third interest should remain intact, he was free to secure this out of his half share.