text:
SHELBY LANDING II INC v. PNC MULTIFAMILY CAPITAL INSTITUTIONAL FUND XXVI LIMITED PARTNERSHIP SLP II
SHELBY'S LANDING—II, INC., Richard Deckard, Jr., Marilyn Deckard, and Deckard Realty & Development Co., Appellants–Defendants, v. PNC MULTIFAMILY CAPITAL INSTITUTIONAL FUND XXVI LIMITED PARTNERSHIP, Columbia Housing SLP Corporation and Shelby's Landing II—L.P., Appellees–Plaintiffs.
No. 73A01–1509–CC–1403.
Kenneth J. Munson, Hoover Hull Turner LLP, Indianapolis, IN, Attorney for Appellees. Christopher J. McElwee, Monday Jones & Albright, Indianapolis, IN, Attorney for Appellants.
[1] Appellants–Defendants, Shelby's Landing–II, Inc. ("Shelby's Landing"); Richard Deckard, Jr. ("Richard"); Marilyn Deckard ("Marilyn"); and Deckard Realty & Development Co. ("Deckard Realty") (collectively, "the Defendants"), appeal the trial court's judgment in favor of Appellees–Plaintiffs, PNC Multifamily Capital Institutional Fund XXVI Limited Partnership ("PNC Multifamily"); Columbia Housing SLP Corporation ("Columbia"); and Shelby's Landing II–L.P. ("the Partnership") (collectively, "the Plaintiffs"), in their breach of contract claim. The Defendants argue that it was error for the trial court to find that they had misappropriated the Partnership's funds and committed theft because the Plaintiffs did not raise misappropriation or theft claims in their complaint. They also argue that the trial court abused its discretion by awarding the Plaintiffs an unreasonable amount of attorney fees.
[2] We conclude that, regardless of the trial court's misappropriation and theft findings and conclusions, there were adequate uncontested findings and conclusions to support the trial court's judgment. Because we also conclude that the trial court awarded the Plaintiffs a reasonable amount for their attorney fees, we affirm the trial court's judgment.
1. Whether the trial court erred when it entered findings that the Defendants had committed misappropriation and theft.
2. Whether the trial court abused its discretion in determining the amount of attorney fees to award the Plaintiffs.
[4] In April 2005, Shelby's Landing, Deckard Realty, Columbia, and PNC Multifamily entered into a limited partnership agreement ("Partnership Agreement"), forming the Partnership. The purpose of the Partnership was to "construct, rehabilitate, acquire, own, maintain, manage, lease, sell, mortgage, or otherwise dispose" of property in Shelbyville, Indiana, in order to profit from a tax credit system designed to encourage private investment in low-income housing developments. (App.220). The Partnership Agreement named Shelby's Landing as the General Partner of the Partnership; PNC Multifamily and Columbia as the Limited Partners (collectively, "the Limited Partners") of the Partnership; and Deckard Realty as the developer of the Partnership. The President of Shelby's Landing, Richard, was also the President of Deckard Realty.
[5] Pursuant to the Partnership Agreement, Shelby's Landing's duties as General Partner included, in relevant part: (1) managing the Partnership's business; (2) keeping and maintaining the Partnership's accounting records; (3) advancing all funds necessary to meet operating deficits; (4) maintaining tenant security deposits in separate accounts; and (5) making an immediate capital contribution to fund any necessary credit adjustment amounts. It was also prohibited from, without the consent of the Limited Partners, borrowing from the Partnership; commingling partnership funds with the funds of any other person; or causing the Partnership to make any loan or advance to any other person.
[6] The same day that the partners executed the Partnership Agreement, Deckard Realty, Richard, and Marilyn (collectively, "the Guarantors") executed a guaranty agreement ("Guaranty Agreement"). In the Guaranty Agreement, the Guarantors guaranteed:
to the Partnership and the Limited Partners the full and prompt payment, performance, observance, compliance, and satisfaction of all obligations, covenants, representations, and warranties on the part of the General Partner to be paid, performed, observed, complied with, or satisfied with respect to the [Partnership] Agreement.
(App.305). The terms of the Guaranty Agreement also provided that:
․ Upon any default by the Partnership or the General Partner or the Developer or Other Obligors relating to any obligation under the [Partnership] Agreement, the Limited Partners may, at either of their option, proceed directly and at once against the Guarantor[s] to collect the full amount of the Guarantor[s'] liability hereunder, or any portion thereof, without first proceeding against the Partnership, the General Partner, the Developer, any Other Obligors, or any person, corporation, partnership, or other entity.
(App.306).
[7] Subsequently, due to delays in the development of the Shelbyville property, the partners executed an amendment to the Partnership Agreement ("Adjuster Note") recognizing that the Partnership, Shelby's Landing, and the Guarantors owed the Limited Partners an adjusted amount of $950,000 plus interest ("Adjuster Amount"), to be paid in installments.1 Shelby's Landing, Richard, and Marilyn guaranteed the Adjuster Note as Guarantors.
[8] Three years later, on or about November 10, 2010, the Limited Partners sent Shelby's Landing a written notice that it was in default under the Partnership Agreement. Specifically, they alleged that Shelby's Landing had: (1) failed to take all actions necessary to maintain and operate the Shelbyville property; (2) defaulted under the construction loan for the property; (3) defaulted in repaying the Adjuster Note; and (4) made loans or advances to itself or other affiliates without the consent of the Limited Partners. The Limited Partners demanded that Shelby's Landing cure its default by November 16, 2010, or face removal from its status as General Partner.
[9] Shelby's Landing did not cure its alleged breaches of the Partnership Agreement, and the Limited Partners sent it another written notice of default on June 22, 2011. In this second notice, the Limited Partners again requested that Shelby's Landing cure the breaches they had identified in their November 10 notice of default. They also alleged that Shelby's Landing had committed additional breaches of contract since November 10, including failing to provide the Limited Partners with federal and state tax returns and audited Partnership financial statements. The Limited Partners demanded that Shelby's Landing cure all of the alleged defaults by July 5, 2011, or be subject to removal from being General Partner. They also stated that they were sending the notice to the Guarantors pursuant to the terms of the Guaranty Agreement, "to demand that Guarantor[s] immediately cure or cause to be cured the defaults of [Shelby's Landing]." (App.171).
[10] Shelby's Landing again failed to cure its defaults. Accordingly, on August 17, 2011, the Limited Partners and the Partnership sent Shelby's Landing a notice of its removal as General Partner. Five days later, on August 22, 2011, the Plaintiffs—the Limited Partners and the Partnership—filed a complaint against the Defendants—Shelby's Landing and the Guarantors. In their complaint, the Plaintiffs raised breach of contract and breach of guaranty claims. In addition to declaratory and other forms of relief, the Plaintiffs also requested recovery of their attorney fees.
[11] On September 7, 2012, the Plaintiffs filed a motion for partial summary judgment requesting, among other judgments, a declaration that Shelby's Landing had been properly removed as General Partner and a judgment against Shelby's Landing and the Guarantors for the amounts due under the Adjuster Note. The trial court granted the motion for a partial summary judgment on July 19, 2013, and held a trial to determine the remaining issues of liability and damages on January 26, 2015.
[12] At trial, the parties presented evidence of liability and damages, and the Plaintiffs attempted to admit two affidavits from their attorneys and invoices documenting the attorneys' fees. The Defendants objected to the admission of the affidavits and invoices on grounds of hearsay, but the trial court conditionally admitted them, pending post-hearing argument from the parties.
[13] As a result of other evidence admitted at the January 26 trial, the trial court entered the following findings of fact and conclusions of law:
29) [Shelby's Landing], as the General Partner through August 17, 2011, was responsible for the day-to-day management of the [Partnership], and, as such, was and is responsible to the [P]artnership for the misuse of partnership funds.
30) As Guarantors, [Richard] and [Marilyn] and Deckard Realty are jointly and severally responsible for the General Partner's obligations to the Partnership for any misuse of partnership funds.
33) The sum of $1,596,290.46 was paid with checks written to or for the benefit of Affiliates of the General Partner, as that term is defined on page 3 of the Partnership Agreement.
35) The 2005 Partnership Agreement provides in section 6.3 that without the express written consent of PNC Multifamily, the General Partner was prohibited from transferring any asset of the Partnership, borrowing or comingling funds of the Partnership[,] and causing the Partnership to make any loan or advance to the General Partner o[r] its Affiliates.
36) After the General Partner's removal, [Richard] admitted that he comingled Partnership funds with the funds of Deckard Realty and that PNC Multifamily never provided written consent to any comingling of Partnership funds.
37) [Richard] further also admitted that he transferred Partnership assets and made loans or advances of Partnership funds to Affiliates, and he further admitted that PNC Multifamily never provided written consent to any transfers, loans or advances to Affiliates.
45) Considering the totality of the evidence, the Court finds [the] Defendants' acts of misappropriation to be intentional and willful.
87) The [D]efendant[ ]s elicited testimony that perhaps some payments to the Defendants and the General Partner's affiliates could have been made to reimburse actual partnership expenses. However, the Defendants failed to otherwise provide any evidence that any payment actually was for a reimbursable Partnership expense.
88) Moreover, the evidence was clear that at no time did the General Partner ever obtain consent from the PNC Multifamily to pay an affiliate, even if the payment was to be considered an ordinary course receivable under section 6.3(n) of the 2005 Partnership Agreement.
89) Accordingly, none of the $1,596,290.46 paid to the Deckard Affiliates was proper and therefore both the General Partner and the remaining Defendant Guarantors are liable for the improper payments made to those affiliates between 2006 through August of 2011.
B. The Defendants individually and as [G]uarantors breached their duties to the Plaintiffs under the Partnership [A]greement.
98) The General Partner breached its contractual and fiduciary obligations under the Partnership Agreement: not to transfer assets of the Partnership, not to comingle Partnership funds, and not to loan or advance Partnership funds to affiliates.
99) The Plaintiffs incurred damages as a result of the General Partner's breaches of its contractual and fiduciary obligations under the Partnership Agreement.
100) The Defendants are jointly and severally obligated under the Agreement of Guaranty to each of the Plaintiffs for the General Partner's breaches of the Partnership Agreement.
101) The Defendants are jointly and severally obligated under the Agreement of Guaranty to each of the Plaintiffs for the General Partner's misappropriation of Partnership funds as detained [sic] herein.
102) The Defendants, individually and as [G]uarantors, breached their duties to the Plaintiffs under the Adjuster [ ] Note.
110) The [D]efendants are jointly and severally liable to PNC Multifamily on the Adjuster Note through January 27, 2015 in the total amount of $1,140,428.87, plus interest in the amount of $82.08 per day thereafter through final judgment, plus post-judgment interest on the total amount outstanding (principal plus interest) as of the date of final judgment at the prime rate public[ly] announced by PNC Bank, National Association based until satisfaction of the judgment.
111) A criminal conviction for theft is not a condition precedent to recovery in a civil action for theft. A claimant must merely prove commission of the crime by a preponderance of the evidence. Under [ Ind.Code ] § 35–43–4–2(a), "a person who knowingly or intentionally exerts unauthorized control over property of another person, with intent to deprive the other person of any part of its value or use, commits theft, a Class D felony."
112) [Richard] knowingly and intentionally exerted unauthorized control over the Partnership's funds, with the intent to deprive the Partnership of its funds.
113) The General Partner was responsible [for] manag[ing] the Partnership funds and breached its obligations to the Plaintiffs to prevent the misappropriation of the Partnership's funds.
114) The Defendants participated in [Richard's] misappropriation of Partnership finds and are jointly and severally liable as a result of their participation in the misappropriations and as a result of their guaranty of the General Partner's obligations to the Plaintiffs.
115) The Defendants breached their obligations to the Plaintiffs.
116) The Plaintiffs were harmed and damaged by the Defendant[s'] breaches.
117) The Plaintiffs were damaged in the amount of $1,596,290.46.
118) The Defendants are jointly and severally liable to the Plaintiffs in the amount of $1,596,290.46 improperly paid to and misappropriated by the Defendants and their affiliates.
119) Attorney fees incurred to enforce the terms of the Adjuster Note are recoverable under paragraph 6 of the Note.
120) Attorney fees incurred by Plaintiffs to enforce the obligation of Defendant Guarantors pursuant to the Agreement of Guaranty and the Partnership Agreement are recoverable under paragraph 8 of the Agreement of Guaranty.
121) Defendants agreed to the attorney fee provisions in the Adjuster Note and Guaranty Agreement.
(App.26–38) (internal citations omitted). The trial court then entered judgment in favor of the Plaintiffs in the amount of $1,140,428.87 plus interest for the Defendants' breach of the Adjuster Note and $1,596,290.46 for the Defendants' breach of the Partnership Agreement.
[14] On May 27, 2015, the Defendants filed a motion to correct error arguing that the trial court had erred in its Findings and Conclusions Numbers 45, 98, 111, and 112 because the Plaintiffs had not pled claims of theft or breach of fiduciary duty.2 The trial court held a hearing on the Defendants' motion, as well as the Plaintiffs' unresolved attorney fee request, on July 22, 2015.
[15] At the hearing, the parties discussed the attorney fee request and the motion to correct error. With respect to attorney fees, the Plaintiffs argued that the trial court should admit the affidavits and invoices of the Plaintiffs' attorney fees that the court had conditionally admitted at trial. They also introduced supplemental affidavits from the lead counsel for their law firms, establishing that the conditional exhibits in question were admissible as certified business records. The trial court showed the affidavits as filed on that day.
[16] Thereafter, on August 12, 2015, the trial court issued an order partially granting the Defendants' motion to correct error. It amended its Finding Number 45, which had originally provided: "Considering the totality of the evidence, the Court finds [ ] Defendants' acts of misappropriation to be intentional and willful." (App.33). The amended finding instead provided that: "Considering the totality of the evidence, the Court finds [Richard] and [Shelby's Landing] committed acts of misappropriation." (App.43). It also amended its Conclusion Number 114, which had originally provided: "The Defendants participated in [Richard's] misappropriation of Partnership funds and are jointly and severally liable as a result of their participation in the misappropriations and as a result of their guaranty of the General Partner's obligations to the Plaintiffs." (App.38). The amended version of Conclusion Number 114 provided that: "Defendants are jointly and severally liable as a result of their guaranty of the General Partner's obligations to the Plaintiffs." (App.44). The trial court then denied the Defendants' motion with respect to its Findings and Conclusions Numbers 98, 110, and 112. The trial court also determined that the Plaintiffs' requested attorney fees of $385,125.26 were reasonable and awarded them recovery of those fees.
[17] The Defendants now appeal the trial court's partial denial of their motion to correct error and its award of attorney fees.
[18] On appeal, the Defendants argue that: (1) the trial court's findings and conclusions regarding misappropriation and theft were erroneous because the Plaintiffs did not raise specific claims of misappropriation or theft in their complaint; and (2) the trial court abused its discretion in determining the amount of attorney fees to award the Plaintiffs. We will address each of these arguments issues in turn.
1. Misappropriation and Theft
[19] First, the Defendants argue that the trial court's findings of fact and conclusions of law were erroneous because the trial court concluded that they had misappropriated funds and committed theft, even though the Plaintiffs did not raise misappropriation or theft claims in their complaint. Specifically, the Defendants challenge the trial court's revised (pursuant to their motion to correct errors) Finding Number 45, in which the trial court found that Richard had "committed acts of misappropriation."3 (App.43). With respect to theft, the Defendants challenge the trial court's Conclusions Numbers 111 and 112, in which the trial court stated the elements for a theft claim and concluded that Richard had "knowingly and intentionally exerted unauthorized control over the Partnership's funds." (App.37).
[20] When reviewing findings of fact and conclusions of law, we apply a two-tiered standard of review by first determining whether the evidence supports the findings and then whether the findings support the judgment. Bayview Loan Servicing, LLC v. Golden Foods, Inc., 59 N.E.3d 1056, 1066 (Ind.Ct.App.2016). The trial court's findings and judgment will be set aside only if they are clearly erroneous. Id. A judgment is clearly erroneous if it applies the wrong legal standard to properly found facts. Id. at 1066–67. To determine that a finding or conclusion is clearly erroneous, our review of the evidence must leave us with the firm conviction that a mistake has been made. Id. at 1067. " '[E]ven an erroneous finding is not fatal to the trial court's judgment if the remaining valid findings and conclusions support the judgment, rendering the erroneous finding superfluous and harmless as a matter of law.' " Curley v. Lake Cnty. Bd. of Elections & Registration, 896 N.E.2d 24, 32 (Ind.Ct.App.2008) (quoting Lakes & Rivers Transfer v. Rudolph Robinson Steel Co., 795 N.E.2d 1126, 1132 (Ind.Ct.App.2003)), trans. denied.
[21] Significantly, the Defendants challenge the trial court's findings of fact and conclusions of law, but they do not challenge the trial court's ultimate judgment. In fact, they acknowledge in their Appellant's Brief that "striking the conclusions related to theft will have no effect on the final judgment amount entered by the trial court," (Defendants' Br. 18), and "[s]triking the conclusions related to the misappropriation will have no effect on the final judgment amount entered by the trial court." (Defendants' Br. 19). Nevertheless, they request that we vacate the judgment. This request contradicts our well-established rule that " 'even an erroneous finding is not fatal to the trial court's judgment if the remaining valid findings and conclusions support the judgment․' " Curley, 896 N.E.2d at 32 (quoting Lakes & Rivers Transfer, 795 N.E.2d at 1132)). The Defendants' acknowledgment that the judgment is not dependent on the trial court's misappropriation and theft findings and conclusions seems to inherently acknowledge that there were other findings and conclusions that supported the judgment.
[22] Regardless of whether this was the Defendants' intended implication, we find that there were other findings and conclusions to support the judgment because the trial court made significant findings and conclusions regarding the Defendants' breach of the Purchase Agreement and Guaranty. Specifically, the trial court concluded:
(App.36). The trial court clearly concluded that Shelby's Landing had breached the Partnership Agreement and that all of the Defendants were liable for the breach under the Guaranty Agreement. Similarly, in Conclusions Numbers 115–117, the trial court concluded:
(App.43). As the damages the trial court lists in Conclusion Number 117 equal the total damages the trial court awarded the Plaintiffs for the Defendants' breach of the Partnership Agreement, it is clear that the trial court did not award any additional damages for a misappropriation or theft claim. Accordingly, we conclude that the trial court's judgment was supported by findings of fact and conclusions of law and, therefore, we will not vacate it.
2. Attorney Fees
[23] Next, the Defendants argue that the amount of attorney fees the trial court awarded the Plaintiffs was unreasonable.4 Specifically, they contend that it was not reasonable for the Plaintiffs' attorneys to bill the Plaintiffs a collective $385,125.26 for 1,227 hours spent on a case that, per the Defendants' description, "was essentially resolved at the preliminary injunction and summary judgment stages." (Defendants' Br. 20). We review the amount a trial court awards for attorney fees for an abuse of discretion. Cavallo v. Allied Physicians of Michiana, LLC, 42 N.E.3d 995, 1008 (Ind.Ct.App.2015). An abuse of discretion occurs when the trial court's decision is clearly against the logic and effect of the facts and circumstances before it. Id .
[24] Even where, as here, the parties have agreed to attorney fees by contract, the award of fees must be reasonable. Id. Judicial notice of the reasonableness of attorney fees is permitted in certain routine actions, such as dissolutions of marriage, in which modest fees are sought. Id. However, where the amount of the fee is not inconsequential, there must be objective evidence of the nature of the legal services and the reasonableness of the fee. Id. This Court has noted that " 'the hours worked and the rate charged are a common starting point for determining the reasonableness of a fee,' " but a trial court may consider a number of factors. Id. The trial court may look at the responsibility of the parties in incurring the attorney fees, and the trial judge has personal expertise he or she may use in determining reasonable attorney fees. Id. In addition, Indiana Professional Conduct Rule 1.5(a) delineates the following factors for determining a reasonable fee:
(1) The time and labor required, the novelty and difficulty of the questions involved, and the skill requisite to perform the service properly;
(2) The likelihood, if apparent to the client, that the acceptance of the employment will preclude other employment by the lawyer;
(3) The fee customarily charged in the locality for similar legal services;
(4) The amount involved and the results obtained;
(5) The time limitations imposed by the client or by the circumstances;
(6) The nature and length of the professional relationship with the client;
(7) The experience, reputation, and ability of the lawyer or lawyers performing the services; and
(8) Whether the fee is fixed or contingent.
[25] Here, the trial court cited several factors for its award of attorney fees. First, it noted that it had "considered attorney invoices consisting of descriptions of the actual legal services performed, the hours incurred[,] and rates charged for services." (App.42). Then, the trial court reasoned that "[t]he case involved detailed and specific agreements, factual investigation, injunction and summary judgment motions and hearings, substantial non-party discovery and a trial on damages." (App.42–43). Further, the "Plaintiffs' claims exceeded $2,700,000, [the] Defendants' counter[-]claims sought over $4,000,000[,]" the rates Plaintiffs' counsel charged were reasonable, and the services Plaintiffs' counsel performed were "reasonable and necessary." (App.43).
[26] The Defendants argue that the trial court abused its discretion in determining the amount of attorney fees to award the Plaintiffs because many of the Plaintiffs' issues were resolved in the partial summary judgment. They contend that the Plaintiffs had limited discovery because they took one deposition that lasted only half of a day and performed little litigation because they spent less than a full day in court for the trial. Finally, they also argue that "the trial court should have compared PNC [Multifamily's] legal expenses with the fee customarily charged in the locality for similar legal services." (Defendants' Br. 22).
[27] Contrary to the Defendants' arguments—and as the trial court found—there was substantial discovery in this case. Although the Plaintiffs took only one deposition, the record is replete with the substantial and detailed financial records the Plaintiffs' attorneys had to investigate in order to prove the Defendants' liability under the Purchase Agreement—an issue that was not resolved through summary judgment. Also, the amount at controversy in both the claim and counter-claim was significant. We do not find it dispositive that the trial court did not compare PNC Multifamily's legal expenses with the fee customarily charged in the locality for similar services, because the trial court was not obligated to address all of the factors listed in Indiana Professional Conduct Rule 1.5(a). See Cavallo, 42 N.E.3d at 1010. It is clear that the trial court addressed several of the Rule 1.5(a) factors, including the time and labor required, the novelty and difficulty of the questions involved, and the amount in controversy. Based on these factors, we conclude that the trial court did not abuse its discretion in awarding the Plaintiffs $385,125.26 for their attorney fees.
1. This amount was distinct from any monetary liabilities under the Partnership Agreement.
2. While the Defendants cited the trial court's Finding Number 45, which referred to misappropriation, they did not specifically challenge the trial court's reference to misappropriation in their motion to correct error. They solely argue that the trial court erred by finding that they had committed theft and had breached their fiduciary duty.
3. They also challenge the trial court's original Conclusion Number 114 in which the trial court concluded that "[t]he Defendants participated in [Richard's] misappropriation of Partnership funds and are jointly and severally liable as a result․" (App.38). Notably, this conclusion is no longer relevant, as the trial court amended it in response to the Defendants' motion to correct error.
4. The Defendants also argue that the trial court abused its discretion in admitting the Plaintiffs' attorney fee affidavits and invoices at trial. They argue that the trial court should not have admitted the affidavits or invoices because they were hearsay. However, the Defendants raised the same objection at trial, and the trial court admitted the affidavits on the basis that they qualified as certified business records, which are an exception to the prohibition on hearsay. See Ind. Evidence Rule 803(6). The Defendants do not present any arguments challenging this conclusion. Indeed, they devote only a paragraph to their hearsay argument and do not support their argument with legal authority. On appeal, it is the appellants' burden to formulate a cogent argument for the issues that they raise. See App. R. 46(A)(8)(a); Kapoor v. Dybwad, 49 N.E.3d 108, 121 n.3 (Ind.Ct.App.2015), trans. denied. We will not "become an advocate for a party, nor will we address arguments [that] are either inappropriate, too poorly developed or improperly expressed to be understood." Thacker v. Wentzel, 797 N.E.2d 342, 345 (Ind.Ct.App.2003). Because the Defendants have not developed a cogent argument to challenge the trial court's admission of the attorney fee affidavits and invoices, we, therefore, find the issue waived and will not address it.
PYLE, Judge.
KIRSCH, J., and RILEY, J., concur.


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Re: Any stores that sell good compression shirts/tank tops?
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What A-shirts (tank tops) to wear in oder to hide my booms ?


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A man and woman died and another woman was left seriously injured following a crash which blocked a busy road near Stourport prompting a police investigation.
The crash happened on the A451 Great Witley to Dunley road at around 4.30pm on Friday.
A green Nissan Micra and silver Volkswagen Golf were involved in the smash.
Police confirmed the driver of the Micra, a man aged in his 30s, was pronounced dead at the scene.
A passenger from the Micra, a woman aged in her 40s, suffered serious injuries.
She was taken by Air Ambulance to the Queen Elizabeth Hospital, in Birmingham, where she died on Saturday.
The driver of the Golf, a woman in her 80s, suffered serious leg and wrist injuries.
She was taken to Worcestershire Royal Hospital, where she remains in a stable condition.
West Mercia Police launched an appeal for witnesses to the crash to come forward and help the investigation.
Sergeant Lee Baker said "This was a distressing incident for all those involved including members of the emergency services.
"The collision occurred on a busy road and I would like to thank those who have already contacted us.
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© 2018 Jeremy Self. All rights reserved.


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text:
Q: Splitting of character array into multiple smaller null terminated character array in C Suppose we have a character array as,
char recvData[1024];

Now the data entered into the recvData[1024] is from the client using the function,
int nBytes = recvfrom(udpSocket, recvData, sizeof (recvData),
                      0, (struct sockaddr *) &serverStorage,
                      &addr_size);

The data received from the client code is present into recvData which is a character array.
We need to make 3 character arrays each one of them as null terminated:
First containing only the first byte of the content of recvData,
Second containing the next 6byte of the content of recvData,
Third containing the last 16byte of the content of recvData.
What shall we use to split the data from the recvData array if required in the above format.

A: It depends on whether you actually need them to be separate, or do you just need a nicer way of accessing the data.
If it's just about convenience, then:
const char first = recvData[0];
const char *second = &recvData[1];
const char *third = &recvData[7];

Just remember that the data will go away if you receive another packet. If you don't mind keeping the data together, but do want a copy of the buffer, then this may be better:
typedef struct Something {
    char first;
    char second[6];
    char third[16];
} Something;
...
Something data;
data.first = recvData[0];
memcpy(&data.second, &data[1], 6);
memcpy(&data.third, &data[7], 16);

If you however need to actually have 3 separate arrays, then:
char* something = malloc(the_size);
memcpy(something, &recvData[offset], the_size);

is what you do.
As mentioned in the comment this does not null-terminate the arrays. But you should be able to do that based on other answers.

A: The requirement for zero-termination rules out several more "hackish" solutions, like memcpy() recvData over result_t, or using a union -- we have to copy the fields individually.
After some polishing, turning magic numbers into macro constants and putting things into a function, that would look somewhat like this. You should assign more meaningful names to everything, of course.
#include <string.h>

#define FIRST_SIZE   1
#define SECOND_SIZE  6
#define THIRD_SIZE  16

struct result_t
{
    char first[ FIRST_SIZE + 1 ];
    char second[ SECOND_SIZE + 1 ];
    char third[ THIRD_SIZE + 1 ];
};

result_t handle_recvData( char * recvData )
{
    struct result_t result;

    memcpy( result.first, recvData, FIRST_SIZE );
    result.first[ FIRST_SIZE ] = '\0';

    memcpy( result.second, recvData + FIRST_SIZE, SECOND_SIZE );
    result.second[ SECOND_SIZE ] = '\0';

    memcpy( result.third, recvData + FIRST_SIZE + SECOND_SIZE, THIRD_SIZE );
    result.third[ THIRD_SIZE ] = '\0';

    return result;
}

A: If you need all sub-arrays as null-terminated and the received data doesn't include these null-termination then you need to make copies of the arrays.
char recvData1[2];
char recvData2[7];
char recvData3[17];

memcpy(recvData1, recvData, 1);
recvData1[1] = '\0';
memcpy(recvData2, recvData+1, 6);
recvData2[6] = '\0';
memcpy(recvData3, recvData+7, 16);
recvData3[16] = '\0';

HandleReceiveParts(recvData1, recvData2, recvData3);

redpajama_set_name: RedPajamaStackExchange


text:
Law & Social Inequality
Social inequality is the imbalance of people's right in any of the society. This can be practiced in different ways depending on the way the people of certain community or culture terms it to be. One of the most common and frequently practiced in our today's community and cultures is violence. This affects all kind and type of people every day in our life. Violence does not depend on the amount of money that you have, your race or culture of which you come from, your ability or even your age (Women health 2007).
The violence against women is one of these violence practice in our day to day life, this is particularly insidious the crime against humanity (French 1998). This can be through physical assaults, attempted and completed sexual assaults, stalking, mental or even emotional. This particular form of violence can be practiced by anybody, whether a family member, your boyfriend or spouse, friend, an acquaintance or even a stranger to you. Violence against women have been established as one of the crimes in the society just like murder, and thus any body going against its rule and regulations is eligible for punishment from the society (Renzetti 2004).
This has been the threat or the use of force to intimidate the woman in the society the results in injury or death. These includes violence such as; rape, domestic violence, family violence, marital rape, sexual abuse and assault, intimate partner violence, homicide, teen dating violence, elder abuse, battering, spouse abuse and even the killing ones mother. This violence affects women of all ages, races and even ethic groups (Women Health 2007).
In the year 2001, a research was carried out on the way of which women are being victimized in the society and by whom. From the research, it was found out that fifty four percent of the violence was reported by the women who were victimized by someone close to them or even a person they knew, these could be their intimate partners, relative, friend or even an acquaintance. Where as forty five percent were reported to be totally strangers to the victim (Renzetti 2004) These victimizations includes, physical assaults, attempted or completed sexual assault and stalking.
This particular form of violence has been known to be exacted in different ways to the victim. Some of these ways include the following;
· The male person using his male powers to intimidate the woman and make her feel like a lesser person in the society.
· When the woman is not working or does not have anything to any her a living, the male individual uses that financial pressure to make her unable to support herself financially or even forcing the woman to resign from the work place in the name of nurturing the young ones.
· The male tries to be too harsh in the house that instils fear to the woman this can be through gestures, talks or even the looks.
· Some of the men even use the children to torture the woman psychologically; this can be through threatening her to take the children away from her.
· Forcing the woman to be separate from her family members and her friends.
This violence has ended up raising the public awareness of the extent and seriousness of the violence against women. With this, feminists began to organise for speak out that could enable women talk openly in a supportive environment about their victimizations. These victimizations could be the one at the hand of the perpetrators are that at the hand of the police and the court of which the cases were not dealt with fairly. Later, they began to open crisis line of which the victims were allowed to call for counselling and support from the organisation (Renzetti 2004).
It has been of more concern as to the social failure to acknowledge, remedy and even prevent this particular victimization of violence against women. The courts and police forces in various nations have continually offering little concern on the women who have been abused, stalked, raped or even sexually harassed. They have neglected their responsibility and instead blamed the women for their predicaments (French 1998).
The women urges out that, women who are raped do wear wrong clothes are found in the wrong places or even behave in the wrong way. Where as the women who are battered by their husbands should have read the signals early enough and leave their partners and the prostitutes gets the rough treatment that they do get because they have decided to sell sex and thus seen as willing participants (French 1998). Thus, the law argues to be offering a fair and justice treatment to all of the nation citizens, as the victims of the sexual assault and spouse battering should have foreseen the potentiality for harm and avoided the incident (French 1998)
With this particular relaxation on the implementation of the law effectively, it has resulted into many women in this world living in a constant state of fear of violence from their partners wherever they are, fear for their lives whenever they go and visit and even fear for the safety of their female children. This has led to great tension to women in their lives in that they do not even think of anything positive from the law (Grusky 2001).
This particular law Violence against Women Act which was passed on in 1994 was meant to impose punishment to the defaulters and giving relevant help to the victim of the incidence. None the less, as much as the law is in existence, it is non effective, this has led to many women being ineffective in the development of the nation as they are afraid of the kind of violence that will be treated to them (Sweetman1999).
Because of this discrimination of the women in the society, the women health organization sat down again in the year 2006 and restructured the law so as to at least protect their women against harsh conditions in the society. On too this new structured law act, more funding were added for legal aid programs and services of which some of it included:
· Provision of funds for the rape crisis centers: this will enable the managers of the centre to be able to attend to the victims effectively.
· Establishment of the violence prevention programs: These programs will provide the rule and regulations for protecting the women against violation in the society. With these same rules, it will have at least a provision of punishment for the crime offender.
· Programs to meet the needs of woman of different races or ethnicities.
· Provision of better services for female children and teens that are infected: this will enable the young women to growth up appreciating the society other than coming up with the negative attitude about the society of which they grow in. it will also give the young female children the ability to be activists in the prevention of the violence against women.
· Invents more and more programs and services for victims with disabilities: these programs will offer some of the knowledge to the women and make them be productive in the society.
· Provision of better protections programs for the victims who have been evicted from apartments because of being victimized of domestic violence or stalking: this will give the women the positive attitude to live in the society without being neglected by the fellow members of the community.
With this effect, at least the violence against women has now been attended to by the public and the nation as a whole. This has also reduced the blames that the society were imposing on the women and now concentrate on the way they can reduce this particular form of violence in the society.
In addition to the law programs that have been formulated, there are other suggestion that people are advised to do in order to maintain the violence against women at a very low level or even not at all (Poling 2003). Some of these are;
· Calling the police. The society is being advised to be at alert and be ready to inform the police force in case, one hears or see any evidence of violence against women being practiced anywhere. This will help the police to at least maintain the law in all area of the nation and thus being able to get up the people who attempt to go against the law.
· Volunteer: the society is also being enlightened to at least volunteer themselves at a local domestic shelter or any organization that is put up to assist the victim or working to prevent the violence against women.
· Protect yourself: for the violence law to be of more help to the female gender in the world, the individual are being advised to protect themselves against the incident. By this, the female person has to ensure that , she wear the appropriate wear wherever she is, be with good company at a good place at good time and also know what they are saying in whatever time they speak. This has been as a result of the assumption that, the victimization has been as the result of their wear and talk of which triggers the man hormones to act violently to the woman.
· Assist the individual of whom may be in an abusive relationship: this can be through helping that person to get out of it of try and counsel them in the way of living in peace.
· Raise the children in good manner: by these, the parent should be able to live as an example to the children. The parent has to ensure that, the children grow up know the good conducts in the society and respect people in the society. This is causing them to treat others just the same way they would like to treat by the people around them. This particular precautions, has all the weight for the crime practice, as whenever the young one grows up knowing that women are lesser human being in the society, nothing will ever hinder him or her to be either a victim of the violence or even practice the act.
Be an activist: being one of the activists for the violence against women will enlighten people on the benefits of the action and thus reduce the rate of the violence.
Thus the Non Governmental organisations have tried their level best to ensure that the law against women violence is implemented and adjusted to be able to ensure that there is fairness n the community and justice.
With their efforts, the governments of different nation have tried to implement some of the practices in their court laws like imprisonment for the offenders. Although, because of some of the cultures certain area, this have not been hundred percent perfect, as people are still clanged to their cultural practises.
Therefore in the case studies that have been carried on and on in many years, have prove that in the past, the law was existing but there was no justice and fairness in the implementation of the law concerning the violence against women, till the year 2006 when the law was restructured and more action added to that could protect the women from the crime (Women Health 2007). For that reason, the current law promotes justice and fairness for everybody in the society.
French, S.G (2004), Violence against Women: Prevention, Protection & Enforcement. Civic Research Institute, Icn. Amazon.com
Grusky, D.G (2001), Social Stratification: The Past, Present & Future of Social Inequality, 2nd Ed. West view Press, Colorado.
Kruttschnitt, C et al (2004). Advancing the Federal Research Agenda of Violence against Women, National Academies Press, amazon.com
Poling, J.N & Neugar, C.C, (2003), Men's Work on Preventing Violence against Women, The Haworth press, Inc, Amazon.com
Renzetti, C.M & Bergen, R.K (2004), violence Against Women. Rowman & Littlefield, Amazon.com
Solimano, A (1998), Social Inequality: Values, Growth & The State. University of Michigan Press, Amazon.com.
Sweetman, C (1999), Violence against Women. Oxfam, Amazon.com
Women Health (2007), Violence against Women: Laws & Legislation. Retrieved from http://www.womenhealth.gov/violence/legislation/.on 6th November 2008
Zorza, J (2004), Violence against Women: Law, Prevention, Protection & Enforcement. Civic Research Institute, Inc. Amazon.com
Law-Civil Procedure
Effect of HIPAA to Patient's Access of Medical Records/Procedure for Obtaining Medical Records
Implications of Plaintiff S157/2002 v Commonwealth of Australia: Issues on Power of Judicial Review,
Law enforcement paper
What is the ucc and how does it govern the sale of goods, in general?
Rule of Law and Civil Disobedience
R. Williams Construction

redpajama_set_name: RedPajamaCommonCrawl


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text:
Careers Salaries & Compensation
Julia Kagan
Julia Kagan has written about personal finance for more than 25 years and for Investopedia since 2014. The former editor of Consumer Reports, she is an expert in credit and debt, retirement planning, home ownership, employment issues, and insurance. She is a graduate of Bryn Mawr College (A.B., history) and has an MFA in creative nonfiction from Bennington College.
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Kirsten Rohrs Schmitt is an accomplished professional editor, writer, proofreader, and fact-checker. She has expertise in finance, investing, real estate, and world history. Throughout her career, she has written and edited content for numerous consumer magazines and websites, crafted resumes and social media content for business owners, and created collateral for academia and nonprofits. Kirsten is also the founder and director of Your Best Edit; find her on LinkedIn and Facebook.
Guide to Unemployment
Explore The Guide
Know the Lingo
Unemployment Claim
Negotiate Severance—If You Can
Negotiating Severance
Preparing for a Layoff
How to File for Unemployment Insurance
Applying for Unemployment Insurance
Who Doesn't Get Unemployment Insurance?
Private Unemployment Insurance
Managing Finances During Unemployment
Paying Your Bills When You're Unemployed
401(k) Withdrawals and Unemployment
COBRA Health Insurance Coverage
When Unemployment Benefits Run Out
Understanding the Unemployment Rate
Calculating the U.S. Monthly Unemployment Rate
Highest and Lowest Rates in the World
Understanding the Employment Report
U3 vs. U6 Unemployment Rate
Participation Rate vs. Unemployment Rate
What The Unemployment Rate Doesn't Reveal
Unemployment and the Economy
The Unemployment Rate Affects Everybody
How Inflation and Unemployment Are Related
Minimum Wage and Unemployment
Cost of Unemployment to the Economy
Okun's Law
Policies to Decrease Cyclical Unemployment
Inflation and Unemployment Correlation
Downside of Low Unemployment
Frictional vs. Structural Unemployment
Structural and Cyclical Unemployment
Dictionary of Economic Terms A-F
Cyclical Unemployment
Disguised Unemployment
Employment-to-Population Ratio
Frictional Unemployment
Full Employment
Dictionary of Economic Terms G-Z
Natural Unemployment
Structural Unemployment
What Is Unemployment Compensation?
Unemployment compensation is paid by the state to unemployed workers who have lost their jobs due to layoffs or retrenchment. It is meant to provide a source of income for jobless workers until they can find employment. In order to be eligible for unemployment compensation, specific criteria must be satisfied, such as having worked for a minimum stipulated period and actively looking for a job.
Unemployment compensation, generally provided by an unemployment check or a direct deposit, provides partial income replacement for a defined length of time or until the worker finds employment, whichever comes first. It is also known as "unemployment benefits" or "unemployment insurance."
Unemployment compensation is a benefit paid to people who have recently lost their job via no fault of their own, such as being laid off or if the business closed.
Unemployment benefits are often calculated as a percentage of the average of the claimant's pay over a recent 52-week period.
Benefits connected to pandemic relief ended on Sept. 6, 2021.
Compensation is usually paid by an unemployment check or via direct deposit.
Every state sets its own requirements and rules surrounding its unemployment benefits.
Understanding Unemployment Compensation
Unemployment compensation is paid by many developed nations and some developing economies. In the United States, the unemployment compensation system is jointly managed by the federal government and each individual state government. Benefits are based on a percentage of a worker's average pay over a recent 52-week period, and their calculation can vary by state.
Benefits are generally paid by state governments, funded in large part by state and federal payroll taxes paid by employers. Most states provide benefits for 26 weeks, though this varies by state and can go as low as 12 and as high as 30. Extensions are possible during periods of high unemployment.
Unemployment Compensation Requirements
As noted above, both the federal government and the individual states manage unemployment insurance in the United States.
Requirements vary by state in terms of how benefits are determined. To be eligible in New York, for example, you must have worked and been paid wages in two calendar quarters, been paid at least $2,600 in one calendar quarter, and the total wages paid to you must be at least 1.5 times the amount paid to you in your high quarter. The minimum benefit is $104 per week, and the maximum benefit is $504 per week.
New York and many other states waived the seven-day waiting period for benefits for people who are out of work due to coronavirus (COVID-19) closures or quarantines.
COVID-19-Related Unemployment Programs
On March 27, 2020, President Trump signed into law a $2 trillion coronavirus emergency stimulus package called the Coronavirus Aid, Relief, and Economic Security (CARES) Act. It temporarily expanded unemployment insurance benefits through three initiatives:
The Pandemic Unemployment Assistance program
The Federal Pandemic Unemployment Compensation program
The Pandemic Emergency Unemployment Compensation program
Here is a quick summary of how they compare:
Pandemic Unemployment Assistance (PUA) Extended benefits to the self-employed, freelancers, and independent contractors. Ended on Sept. 6, 2021.
Federal Pandemic Unemployment Compensation (FPUC) Provided a federal benefit of $600 a week up until July 25, 2020. The benefit is extended but reduced to $300 per week until March 14, 2021, beginning Jan. 2, 2021. Ended on Sept. 6, 2021.
Pandemic Emergency Unemployment Compensation (PEUC) Extended benefits for an extra 13 weeks after regular unemployment compensation benefits are exhausted with an additional 11 weeks having been added for a total of 24 weeks. Ended on Sept. 6, 2021.
President Joe Biden signed the American Rescue Plan, a stimulus package worth $1.9 trillion on March 11, 2021, which provided additional benefits to Americans because of the COVID-19 pandemic. The bill extended unemployment benefits for those who lost their jobs because of the pandemic from March 14, 2021, to Sept. 6, 2021. The new law extended the PUA by an additional 29 weeks from 50 to 79 weeks. It also pushed PEUC benefits from a total of 24 to 53 weeks.
All unemployment benefits and compensation related to the pandemic ended on Sept. 6, 2021.
History of Unemployment Compensation
The first unemployment compensation system was introduced in the United Kingdom with the National Insurance Act of 1911 under the Liberal Party government of H.H. Asquith. The measures were intended to counteract the increasing footprint of the Labour Party among the country's working-class population.
The National Insurance Act gave the British working classes a contributory system of insurance against illness and unemployment; however, it only applied to wage earners. The families of wage earners and those earning non-wage income had to rely on other sources of support. Communists—who thought such insurance would prevent workers from starting a revolution—criticized the benefit, but employers and Tories saw it as a "necessary evil."
The British unemployment compensation scheme was based on actuarial principles, and it was funded by a fixed amount contributed by workers, employers, and taxpayers. After one week of unemployment, the worker was eligible to receive seven shillings per week for up to 15 weeks in a year. However, the benefits were restricted to particular industries that tended to have more volatile employment requirements, such as shipbuilding, and it did not make provision for any dependents. By 1913, about 2.5 million people were insured under the British scheme for unemployment benefits.
In the United States, unemployment compensation began at the state level when Wisconsin enacted it in 1932 to assuage the effect of the Great Depression. In 1935, President Franklin D. Roosevelt signed the Social Security Act and established it nationwide. Initially, employers of fewer than eight employees were exempt from having the coverage. That number dropped to four in 1954 and was reduced to one in 1970.
Special Considerations
The system is called Employment Insurance (EI) in Canada and is funded by premiums paid by both employers and employees. Canada's first national unemployment system was established in 1940 by the Unemployment Insurance Act, also prompted by the effects of the Great Depression.
The law was expanded and liberalized in 1971 and finally replaced in 1996 by the Employment Insurance Act, which changed the program's name to emphasize that it intends to promote employment rather than support unemployment.
Investopedia requires writers to use primary sources to support their work. These include white papers, government data, original reporting, and interviews with industry experts. We also reference original research from other reputable publishers where appropriate. You can learn more about the standards we follow in producing accurate, unbiased content in our editorial policy.
Social Security Administration. "How Do I File for Unemployment Insurance?" Accessed Sept. 10, 2021.
Center on Budget and Policy Priorities. "Policy Basics: How Many Weeks of Unemployment Compensation Are Available?" Accessed Sept. 10, 2021.
Congress.gov. "H.R. 1319—American Rescue Plan Act," Page 115. Accessed Sept. 10, 2021.
U.S. Department of Labor. "Unemployment Insurance Extended Benefits." Accessed Sept. 10, 2021.
New York State Department of Labor. "How Your Weekly Unemployment Insurance Benefit Payment Is Calculated." Accessed Sept. 10, 2021.
New York State Department of Labor. "File a New Unemployment Insurance Claim." Accessed Sept. 10, 2021.
Congress.gov. "H.R. 748—CARES Act." Accessed Sept. 10, 2021.
The New York Times. "F.A.Q. on Stimulus, Unemployment and Tax Rebates." Accessed Sept. 10, 2021.
Congress.gov. "H.R. 1319—American Rescue Plan Act," Pages 115-117. Accessed Sept. 10, 2021.
Social Security Administration. "A Summary of Foreign Experience With Unemployment Insurance." Accessed Sept. 10, 2021.
SchoolsHistory.org.uk. "National insurance Act 1911." Accessed Sept. 10, 2021.
Eligibility.com. "The History of Unemployment Insurance." Accessed Sept. 10, 2021.
MapleLeafWeb. "History of Employment Insurance in Canada." Accessed Sept. 10, 2021.
Take the Next Step to Invest
Guide to Unemployment Guide
Unemployment Definition and Types
What Is Termination of Employment?
Unemployment Claim Definition
The Ins and Outs of Severance Pay
The Layoff Payoff: A Severance Package
7 Considerations When You Negotiate Severance
How to Make a Layoff Less Painful
What Is Unemployment Insurance (UI)?
How to Apply for Unemployment Insurance in Times of COVID-19
Should You Buy Private Unemployment Insurance?
How to Pay Your Bills When You Lose Your Job
How 401(k) Withdrawals Work When You're Unemployed
All About COBRA Health Insurance
What to Do When You Can't Pay Your Medical Debts
Help, My Unemployment Benefits Are Running Out
What Is the Unemployment Rate?
How Is the US Monthly Unemployment Rate Calculated?
Unemployment Rates: The Highest and Lowest in the World
What You Need to Know About the Employment Report
U-3 vs. U-6 Unemployment Rate: What's the Difference?
Participation Rate vs. Unemployment Rate: What's the Difference?
What The Unemployment Rate Doesn't Tell Us
How the Unemployment Rate Affects Everybody
How the Minimum Wage Impacts Unemployment
The Cost of Unemployment to the Economy
Unemployment and Economic Growth: Okun's Law
What Can Policymakers Do to Decrease Cyclical Unemployment?
What happens when inflation and unemployment are positively correlated?
The Downside of Low Unemployment
Frictional vs. Structural Unemployment: What's the Difference?
Structural Unemployment vs. Cyclical Unemployment: What's the Difference?
What Is the Employment-to-Population Ratio?
How Frictional Unemployment Occurs in an Economy
What Is the Labor Force Participation Rate?
What Is the Labor Market?
What Is Natural Unemployment?
What is Social Insurance?
Social insurance acts as a safety net for many. Is it the same thing as public assistance?
Unemployment Income
Unemployment income is temporary income that governments provide to individuals who have lost their job through no fault of their own.
Unemployment insurance is a benefit for workers who have lost their jobs and meet certain eligibility requirements.
Federal Pandemic Unemployment Compensation (FPUC) provided a temporary extra $600 a week on top of regular unemployment insurance benefits.
Pandemic Emergency Unemployment Compensation (PEUC) was a COVID-related program that provided extended unemployment benefits.
Pandemic Unemployment Assistance (PUA) temporarily expanded unemployment insurance to freelancers, independent contractors, and the self-employed.
The FPUC program ended on Sept. 6, 2021.
Salaries & Compensation
Furlough vs. Layoff


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text:
Q: Adding custom post type archives to a WordPress menu Is there a way (besides adding a Custom Link) to add a custom post type archive to a menu in WordPress? If it's added using a custom link (e.g. /cpt-archive-slug/), WordPress does not apply classes like current-menu-item to the list element, which presents challenges when styling the menu.
If the custom link contains the entire URL (e.g. http://site.com/cpt-archive-slug/), those classes are added. However, that's probably not a 'best practice'.

A: I know this is old but I have this problem too and I found a rather clean way to handle it is to use a custom menu walker
class KB_Custom_Menu_Walker extends Walker_Nav_Menu {

  protected static $custom_post_types = array();

  public function start_el(&$output, $item, $depth=0, $args=array(), $id=0) {
    if (isset( self::$custom_post_types[ $item->url ] )) {
      $item->url = get_post_type_archive_link( self::$custom_post_types[$item->url] );
    }
    parent::start_el($output, $item, $depth, $args, $id);
  }

  public static function custom_post_types($type=null) {
    if ($type) {
      self::$custom_post_types[ '#post_type_'.$type ] = $type;
    }
    return self::$custom_post_types;
  }
}

Having a custom link menu item with URL of #post_type_album, you can use it like this:
# Where you defined your custom post type (could be anywhere anyway)
KB_Custom_Menu_Walker::custom_post_types('album');

# And display the menu
wp_nav_menu(array(
  'theme_location' => 'primary-nav',
  'walker' => new KB_Custom_Menu_Walker(),
));

Note: This assume that your post type's slug and name are the same.

A: your best opption is custom link with full url as Custom post types archives are different form taxonomy based archives (categories,tags,any custom taxonomy) and date based archives which have there own archive slug.

A: I have expanded a bit on tungd's answer to provide more genericity with that approach. This implementation allows adding arbitrary mappings between menu 'macros' and internal Wordpress URLs that only the backend knows about.
I've also decided to use ! as the prefix for these macros to avoid them clashing with named anchors - this includes an overhead to strip off the 'http://' from the link URL (as Wordpress will attempt to normalise these weird links). If that implementation bothers you, you can always remove the preg_replace() call and use # as your link prefix as before.
class Extendable_Menu_Walker extends Walker_Nav_Menu
{
    protected static $custom_urls = array();

    public static function setupUrls()
    {
        // calls to self::mapPostType($postTypeName) and
        // self::createMapping($wildcard, $url) go here...
    }

    public function start_el(&$output, $item, $depth=0, $args=array(), $id=0)
    {
        $url = preg_replace('@^https?://@', '', $item->url);
        if (isset( self::$custom_urls[ $url ] )) {
            $item->url = self::$custom_urls[ $url ];
        }
        parent::start_el($output, $item, $depth, $args, $id);
    }

    public static function createMapping($urlKey, $realUrl)
    {
        self::$custom_urls['!' . $urlKey] = $realUrl;
    }

    public static function mapPostType($type)
    {
        self::createMapping('post_type_' . $type, get_post_type_archive_link($type));
    }
}

add_action('init', array('Extendable_Menu_Walker', 'setupUrls'));

A: You can create a Page and then apply a custom archive template to it.  I create and use archive-{post-type}.php fo the template name just like you would for the default archive, I just manually apply it to the Page.
If you do this, I'd recommend setting your CPT to has_archive='false' to avoid permalink collisions, regardless just make sure your Page has a different permalink slug than your CPT archive slug is set to.

A: I ran into the same exact problem, and found this solution:
// $menu is the menu as a string
if ( check if youa re on the page you are looking for )
    $menu = str_replace( '
', '
'>, $menu );

Source:
http://www.wptavern.com/forum/plugins-hacks/2169-current-page-custom-post-type-archive.html

A: I think I'd have to create a new "parent" post-type, so the custom-post-type I want to show becomes a "child", and that parent WILL be listed in the menu.
This should be an option. Creating a dummy parent just for getting it listed in the menu is too much work.
I'd like a way to do it from the template, or functions, so I don't have to do it in each menu settings for each site in my multisite installation.

A: I Found this answer when searching for a similar issue. I just copied the code into my finctions.php file and it worked right out of the box :) hope it helps!
Dynamic navigation for custom post type (pages)

A: What I do instead of adding the link is creating an empty page. In that page I add something like "Content generated from cpt-name" in the editor so my client knows where all the stuff is coming from.
Then I add that page to the menu and with the following code I ensure that is highlighted when archives-cpt or single-cpt is running.
/**
 * Fix to add Custom post types to nav menu
 * If you custom post is called "concepts"
 * create a new empty page called concepts and add this
 */
 function additional_active_item_classes($classes = array(), $menu_item = false){
    global $wp_query;

    if(in_array('current-menu-item', $menu_item->classes)){
        $classes[] = 'current-menu-item';
    }

    if ( $menu_item->title == 'PAGE TITLE' && is_post_type_archive('cpt-slug') ) {
        $classes[] = 'current-menu-item';
    }

    if ( $menu_item->title == 'PAGE TITLE' && is_singular('cpt-slug') ) {
        $classes[] = 'current-menu-item';
    }

    return $classes;
}
add_filter( 'nav_menu_css_class', 'additional_active_item_classes', 10, 2 );

This will check for menu/page title and if we are actually seeing the archive or individual page of a custom post type. If it's true it will add the current-menu-item class.


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I really wish I had been able to play with the stamp of the month more this month! I did jump on in and create a New Year's layout with Cheers, 2016! as well as papers from the White Pines paper pack.
What I really love about both of these items is how versatile they are. Most of the stamps in this set are useful for things other than New Year's, and I don't think you can tell that these papers are from a "Christmas" set.
I love the fun fonts used in the stamp images (that 2016 is going to get all kinds of use this year!), and the little adhesive hearts add the perfect touch.
I love how combining a Cricut font in a larger size makes the stamps great for page titles too. The gold embossing powder (plus a little glitter paper) adds just the right amount of bling, whether my pictures ends up from a full-on party or the more likely quiet night at home.
If you're interested in the stamp of the month, it's only available until November 30, so be sure to order right away - remember, the price drops to $5 with any $50 purchase!


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Cork Factory Hotel
Cork Factory Hotel is dedicated to making sure that our facilities are accessible to as many people as possible. In addition to adhering to all local, state, and federal laws and regulations, we've made our facilities accessible in the following ways. If you would like additional information, please feel free to reach out.
Cork & Cap Restaurant is on the ground floor and accessible from multiple entrances. All of our dining rooms, including the bar and outdoor patio, offer seating accessible for wheelchairs.
We have three sets of public restrooms, all of which are accessible. The first is off of the hotel lobby on the ground floor. The second is adjacent to the Ballroom and Parlor and is accessible via an elevator or a ramp. The third is on the ground floor of Building 6 for use by guests enjoying the Warehouse event room.
Complimentary on-site accessible parking is provided to all guests. We have 4 accessible spots on-site, none of which are more than 67 feet from the nearest accessible entrance.
The Ballroom is accessible via the main elevator and a ramp located at the rear of the building.
We have four ADA compliant guest rooms on various levels of the hotel and with varying configurations. Our second and fourth floor rooms are accessible via the main elevator.
Extra wide door frames
Handles by the toilet
Handles in the tubs
Seat in the tubs
ADA compliant alarms
Tub and King Bed
Tub and Queen Bed
Roll in tub and King Bed
The lobby is accessible from the main entrance, which has a minimal incline and includes multiple accessible parking spaces. The rear entrance takes you around the elevator to the lobby.
480 New Holland Avenue, Suite 3000, Lancaster, PA 17602
Phone: 717.735.2075 | Fax: 717.735.2022 | info@corkfactoryhotel.com
Urban Place
Cork and Cap
The Baker's Table
© 2019 Cork Factory Hotel, all rights reserved


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HomeNews100 Mile HouseHunters Asked By Tsilhqot'in Nation To Forgo Limited Entry Hunt In Their...
Hunters Asked By Tsilhqot'in Nation To Forgo Limited Entry Hunt In Their Territory
Friday, Aug. 26th, 2022
Photo-Pixabay
Those with Limited Entry Hunt moose authorizations are being asked by the Tsilhqot'in Nation to stay home.
The TNG said in release hunters that have been issued one from the province of BC to forgo their moose hunt in the Tsilhqot'in Territory and should consider the impacts of it on the local indigenous population.
Over the strong objections of the Tsilhqot'in Nation, they say the province has doubled, from 2021, the number of moose LEH authorizations issued in the Chilcotin Region.
The TNG said moose populations have plummeted in the Chilcotin, they were once abundant, but in recent years Tsilhqot'in hunters are reporting too few moose on the territory to feed their families and communities.
Chief Joe Alphonse said the province doesn't have the same concerns as they have around protecting their moose population.
"If the Province isn't going to help us, we have to step up and we're going to be doing that. This hunting season we want to make sure that we get the word out before hunting season so that hunters have a chance to alter their plans if they can but we have to be fair on that front."
Alphonse said a lot of the moose habitat hasn't recovered from the 2017 wildfires, upwards of 80% of some of the areas have burnt and the large-scale impacts of wildfire have not been resolved.
"We have to take every action possible to keep our moose population from declining even further. Now is not the time for LEH hunters to come here. We need to protect our food sources to protect our families and communities," Alphonse said.
Because they rely on the moose for a food source, Alphonse said the public may want to double check before they come into the Cariboo if they plan on hunting as they will be deactivating roads.
The Tsilhqot'in Nation said BC's decision to increase the LEH in Tsilhqot'in territory means that there will be less moose for their people to exercise their Aboriginal rights to hunt.


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It's here again! American Craft Beer Week is upon us and we're working up an exciting week of activities. Take a look at what's in store!
Come make some new friends at CBC and try something you've never had before.
Two of the most dynamic breweries in the world.. and their TWIN brothers?? Yeah, so the story goes that they absolutely hate each others. But they seem like such nice guys! Well come try both of their beer and YOU get to pick a glass! Not only is both of their glassware awesome but they're extremely hard to come by. So come try their beer and grab a Mikkeller glass or an Evil Twin glass.
Double BeerGeek points ALL DAY!
Pastry Stouts! Yup, they're the hottest thing on the block. Join us as we give you the chance to build an amazing pastry stout of your own! Choose a base beer and add any of our crazy ingredients OR bring your own! The best concoction gets featured on an upcoming Randall night. Check it out!
Bring a French Press if you have one! This is a per-person event and costs $10 to participate.
CHECK THIS OUT! We're getting a super-special keg from 4 Hands that we can't even mention yet. HOOOOOLLY SHEEET! Help us absolutely destroy this badboy at our first ever 4 Hands Lupulin Carnival pre-party!
Join us as we destroy ONE KEG. All day long, get half price pours on one keg. If we destory it?? Well, everybody gets a free pour of the next one we tap. LET'S DO THIS!


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News Sports Rockland Westchester Food Data Obituaries eNewspaper Legals
Editorial: Sheldon Silver must step down
A Journal News editorial
New York Assembly Speaker Sheldon Silver, arrested Thursday morning, accused of intricate, years-long corruption schemes, deserves his day in court. He is presumed innocent until proven guilty.
But New Yorkers deserve a functioning, focused Legislature. Silver, who's controlled the Assembly and wielded tremendous power in Albany, must relinquish his leadership role.
Silver faces a five-count federal indictment asserting that for years he used his office for personal gain. "There is probable cause to believe that Silver obtained approximately $4 million in payments characterized as attorney referral fees solely through the corrupt use of his official position," according to the complaint, filed by the U.S. Attorney's Office.
So far, Democratic Assembly members are standing by Silver – a testament to his power. Mostly, though, they are keeping quiet. That is a shame.
Moreland kindled
Silver's indictment stems from last year's premature shuttering of Gov. Andrew Cuomo's Moreland Commission on Public Corruption. As the panel probed outside income of legislators, Silver sued to stop it.
Cuomo declared the investigation done after mere months. Preet Bharara, the U.S. attorney for the Southern District of New York, very publicly decried the commission's closure and just as publicly swept in and snapped up Moreland files.
Silver's indictment is the first to cite Moreland findings but it's unlikely to be the last. And it sure isn't the first stain of corruption: Silver is the 38th member of the New York Legislature to face legal or ethical charges since 2000. (The U.S. District Court in White Plains is currently playing host to the corruption trial of former Sen. Malcolm Smith.)
"The show-me-the-money culture in Albany came from the very top," Bharara said Thursday in a Manhattan news conference.
Dual schemes
Silver is accused of using a secret health slush fund to support a doctor's "research" in exchange for the doctor referring victims of asbestos exposure to Weitz & Luxenberg, Silver's law shop. The law firm supplied Silver with more than $3 million for such referrals but none of the clients or their families ever met or spoke to Silver, the indictment says.
A second scheme, the FBI says, involved a real estate firm that paid Silver but the Assembly speaker never revealed being in its employ. Property owners who needed sweet tax deals, or favorable legislation, were the clients.
Silver, a personal injury lawyer by trade, didn't report any outside income from the real estate firm, and severely underreported his Weitz & Luxenberg haul, the indictment asserts.
Bharara noted that Silver had neither real estate nor malpractice law experience. But he had power.
Sheldon Silver must finally serve New Yorkers instead of just himself. Assembly members must force that upon him.
And, as Bharara said Thursday, "You should stay tuned."
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Dead Space: Downfall Hits TV This Sunday
Earnest Cavalli
Dead Space: Downfall, the animated film tie-in for Electronic Arts' new survival horror series is coming to television on Sunday, November 2. The film premieres on premium channel Starz Action at 10 PM Eastern and Pacific time. It also saw release on DVD, courtesy Anchor Bay Entertainment, on October 28. "We are thrilled to have […]
Dead Space: Downfall* , the animated film tie-in for Electronic Arts' new survival horror series is coming to television on Sunday, November 2.
The film premieres on premium channel Starz Action at 10 PM Eastern and Pacific time. It also saw release on DVD, courtesy Anchor Bay Entertainment, on October 28.
"We are thrilled to have the world television premiere of Dead Space: Downfall
on Encore Action," said Starz Entertainment's vice president of program acquisitions Nancy Silverstone.
"The feature sets a new standard for animated horror that our audience will love. It provides the story thread from the comic books to the newly released game, using the background and sound design from the game and the same artistic spirit of the comic book series," Silverstone added.
Image courtesy Starz Entertainment
Review: Dead Space Shooter Will Shock You
Dead Space Console-Specific Suits as DLC
Warren Ellis Gives Dead Space Its Creepy Narrative


This hard holster is designed to work with the blowback airsoft replica by either KWA or KSC the Vz.61 or Kz.61 Skorpion. The design works by wrapping around the magazine and the trigger guard, the round mound inside the trigger guard recess friction holds the holster in place even under extreme movements, additionally the tightness can be regulated with an adjustable screw.
To attach the holster to a belt or a molle system a Blackhawk mount is required (not included). The user must also supply 4 screws. (2) #8 3/8" (1) #8 1+1/4" and an optional screw #8 3/4".
Please review the video for further instructions and demonstration.


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NNNow
Arvind textile
Arvind Lifestyle Brands
Arvind Internet
Arvind group
Arvind offers its online platform to third-party brands
Arvind group has had a rough journey with its e-commerce initiatives so far. It had to liquidate two online only brands--Prym and Shuffle.Anand J | ET Bureau | August 14, 2017, 13:26 IST
BENGALURU: Apparel major Arvind is opening up its e-commerce platform for brands outside of the group, three years after it started building one for itself. The platform called NNNow.com that was launched mid-last year was meant for around 30 in-house brands, including Flying Machine, GAP and US Polo that are either owned or sold in India by Arvind through its Arvind Lifestyle Brands.
More than 30 other brands are set to go online with NNNow by the end of the current quarter, Mukul Bafana, CEO of Arvind Internet, told TOI. "The idea is to become a software-as-a-service player for all the fashion brands and this is a one-of-a-kind initiative in the e-commerce world. Our platform will be like an online high-street for big brands," Bafana said. Bafana was one of the co-founders of fashion portal Jabong and joined Arvind three years ago.
Arvind group has had a rough journey with its e-commerce initiatives so far. It had to liquidate two online only brands--Prym and Shuffle. Its online initiative was earlier headed by former Puma CEO Rajiv Mehta, who has since left the company . The group scion Kulin Lalbhai, who moved to Bengaluru to overlook the new initiatives, has since relocated back to Ahmedabad.
Arvind Brands, which runs all these brands, is based in Bengaluru, while the group is headquartered in Ahmedabad.Bafana would not comment on any of these issues though.
Other big fashion groups like Aditya Birla and Reliance Trends have Abof and Ajio portals respectively that sell their own products, competing with aggregators like Myntra, Amazon and Flipkart. Arvind Internet will only run the technology back-end and fulfilment, whereas the brands will independently be responsible for marketing their online presence.
Tags : E-commerce, E-tailing, NNNow, Arvind textile, Arvind Lifestyle Brands, Arvind Internet, Arvind group


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RABAUD: Marouf, Savetier du Caire
How welcome, then, is the release of a fine recording of Rabaud's biggest claim to fame. The French label Accord, recently the source of a number of fine new recordings of rare romantic works has, in this case, brought to compact disc a 1976 performance from the Orchestre Philharmonique des Pays de la Loire under Jesus Etcheverry. As is usual with Accord sets, the packaging is attractive and the sound quality of the first rank. The notes and libretto are in both French and English.
Marouf is based on a tale from the Arabian Nights. The title character, as drawn by Rabaud and his librettist Lucien Nepoty, must certainly be one of the most passive protagonists in operatic literature! Our Cairene cobbler isn't ambitious, clever, or brave. Rather he trusts to luck, or perhaps the will of Allah. When his "Calamitous Spouse" drags him before the law for beating her, though innocent, he accepts his punishment without a word in his own defense. He does at last choose to flee the harpy, and takes to the high seas with a group of mariners. But shortly thereafter he finds himself beaten and robbed far from home.
Then fortune smiles. He meets Ali, a childhood friend who'd made good. With Ali's help, Marouf is passed off as the richest of all merchants, who's treasure-laden caravan is just a few days distant. Convinced, the Sultan offers Marouf his daughter, the princess Saamcheddine. Naturally his story begins to crumble as time passes. Marouf secretly confesses to his new bride that he's in fact no merchant at all, but a poor cobbler. The gracious and beautiful Saamcheddine hardly seems bothered that she's been married off to a poverty-stricken con man. She joyfully flees with Marouf to share his destitute life. But such a tale could hardly end in this fashion! A chance encounter with a genie resolves all, and Marouf's supernaturally created caravan arrives just in time to save them from the Sultan's pursuing henchmen.
It is a preposterous story that is meant to amuse, rather than to move the emotions. In fact Marouf's servile manner and vocal lines filled with endless sing-song arabesque started grating on me after a bit–that is, until I encountered his beguiling Saamcheddine! The couple's Act 3 love duet is perhaps the musical high point of the opera. For a moment, one can vicariously feel Marouf's infatuation indeed.
"Modernism is the enemy" was a favorite dictum of the Rabaud's, so it's no surprise that his opera has little in common with the works of such near contemporaries as Arnold Schoenberg or even his compatriot Maurice Ravel. There's hardly a hint of the desperate passions found in contemporary verist works either, such as Zandonai's Francesca da Rimini or Montemezzi's L'amore dei tre re. Rather the name which most often springs to mind while listening to Marouf is that of his professor, Massenet–especially in that composer's lighter and more fanciful moods, found in operas like Esclarmonde or Cendrillon.
Like Massenet, Rabaud's music is suave, melodious, and meticulously crafted. Everything is paced with an astute sense of proportion. But the observant ear will also detect many fascinating "twentieth centuryisms"–hints of Straussian and Debussian harmonies that delight the ear and set his music apart from that of his more famous teacher. He also boasts a formidable orchestral technique.
Rabaud's opera doesn't aim for the heavens, but it achieves its more modest goals with such ease and facility that one cannot help but feel a certain delight in it. But I'm curious to know how he treated weightier themes. A list of his operas suggest a broad range of subjects, including tragic ones, such as his 1923 opus L'appel de la mer, based on the same story as Vaughan Williams's Riders to the Sea. One can only hope that the appearance of recordings such as this Marouf will spur greater interest in Rabaud's entire oeuvre, and lead to more revivals and recordings.
As to the performances, the principal roles are well cast. Michael Lecocq sings Marouf with more of an eye towards emphasizing the character's idiosyncrasies, rather than trying to achieve emotional expressiveness. Whether this is a good thing or not may depend upon personal taste. Anne-Marie Blanzat's Saamcheddine is, by contrast, both poised and youthful sounding–the perfect aural picture of an eastern princess.
Despite the scarcity of Marouf on operatic stages, there is a competing recording on the Gala label at a bargain price. It also boasts a fine performance by the Orchestre de Radio-Televsione Francaise from 1964 under Pierre-Michel LeConte. It's Marouf, Henri Legay, takes the opposite tack from Lecocq's, and sings the role with great expressive intensity. There are a number of downsides though. The sound is good, but not as clear as the new Accord set. More importantly, perhaps, are the presence of some cuts, and, as with all Gala sets, no libretto.
For American collectors, Accord got American distribution only as of last February, and currently many of their titles, including Marouf, are not available from principal online outlets. They are available both directly from Premiere Music Distributors, and from Records International. I contacted Premiere, and they assured me that Marouf would soon be more generally available, as it is already in Europe.
Eric D. Anderson
image=http://www.operatoday.com/content/Marouf.jpg
image_description=Henri Rabaud: Marouf, savetier du Caire
product_title=Henri Rabaud: Marouf, savetier du Caire [Marouf, Cobbler of Cairo]
product_by=Michel Lecocq, Marouf; Anne-Marie Blanzat, The Princess Saamcheddine; Franz Petri, the Sultan. Choeurs de l'Opera de Nantes; Orchestra Philharmonique of Pays de la Loire; Jesus Etcheverry (dir.)
product_id=Accord ACRD472142-2 [CD]
ALALEONA: Mirra
AUDRAN: La Mascotte
The Sphere of Intimacy: magical miniatures from Cyrille Dubois and Christophe Rousset
Echo: an exquisite new disc from Ruby Hughes
David Truslove
Barnaby Smith goes back to Bach