LIAISE unites the leading European research organisations in the field of environmental sciences, environmental economics, policy analysis and modelling. LIAISE started in 2009 as a Network of Excellence of 15 research institutes in the field of Impact Assessment for sustainable development, funded under the EU-FP7 work programme. Since then, more institutions have joined the network.
ALTERRA is the main Dutch centre of expertise on the green environment - part of WageningenUniversity and Research Centre (Wageningen UR) - engaging in strategic and applied research to support policymaking and management at the local, national and international level. It combines expertise on ecosystems, landscape, water, climate, wildlife, forests, soils, and recreation with professional GIS and IT expertise in the Centre Geo- Information (CGI).
Freie Universität Berlin (FUB) is one of Germany's leading universities. The Environmental Policy Research Centre (FFU) at the FUB is engaged in comparative environmental policy analysis, the design and evaluation of processes for Impact Assessment and the analysis and evaluation of strategies for sustainable development. Being active in basic research as well as in policy consultancy, the research centre is widely recognized acting as a science policy interface.
NERI is a research institute within Aarhus University. NERI provides the scientific basis for environmental policy. The aim of the freshwater, marine and policy departments involved in LIAISE is to develop tools and methods for integrated assessment of human activity and environmental impacts, and to make this knowledge available for policy processes.
AUTH was established in 1925 and is currently the biggest University in Greece. The Department of Agricultural Economics has significant experience in agricultural economics, farm management, regional planning, environmental management, policy, Impact Assessment, decision support systems, governance, sustainable development, sustainable use of resources including biodiversity. IA and the development of IA tools are among the strategic goals of the Department.
The Centre for Ecology & Hydrology (CEH) is a public sector research centre of the UK Natural Environment Research Council (NERC) conducting independent mission-driven research in close partnership with the scientific community, governments and the private sector. The development of tools for IA is central to the three integrated science programmes - Biodiversity, Water, and Biogeochemistry. CEH has long standing experience in the integration of monitoring and modelling, delivering scientific evidence to underpin policy development.
Ecologic Institute is a transdisciplinary research organisation, whose main focus is environmental research. The scientists at Ecologic Institute prepare political analyses and assessment reports. As a private, independent institute, Ecologic Institute dedicates itself to working on the social-political aspects of sustainability research and bringing new knowledge into the field of environmental policy. Innovative research approaches, practical relevance, and a transdisciplinary working style ensure the excellent scientific quality and societal relevance of Ecologic Institute's work. This work encompasses the entire spectrum of environmental topics, including the integration of environmental issues in other political fields.
FEEM is a non-profit, non-partisan research institution established to carry out research in the field of economics and sustainable development. It is a leading international research centre engaged in promoting interaction between academic, industrial, and public policy spheres to address concerns about economic development and environmental degradation.
Stockholm Environment Institute Tallinn Centre/Estonian Institute for Sustainable Development Institute is one of seven independent research institutes belonging to the global SEI network. Established in 1992, SEI Tallinn is active locally, regionally, and globally in dealing with environmental and sustainability management and governance, nature conservation, and underlying socio-economic drivers and impact analyses. Policy Impact Assessment is one of SEI Tallinn's main fields of activity and LIAISE shared research agenda will be integrated into SEI Tallinn's institution research strategy 2010-2012.
The Finnish Environment Institute (SYKE) is the national research and development institute within the environmental administration of Finland. The tasks of SYKE include assessment of environmental changes, their causes and possible ways to solve them. SYKE develops, assesses and applies environmental decision support systems for sustainable development.
Tecnalia Research & Innovation is a research organisation resulting from the merging of eight research organisations. TECNALIA is the leading private research and technology entity in Spain and the fifth largest in Europe. In LIAISE project Tecnalia participates with a team from Innovation Systems Unit with a support from researchers from Sustainable Development Unit. The Innovation Systems Unit is specialised in innovation policies and programmes, as a key factor in regional development. A multi-disciplinary team of 65 researchers focuses on socio-economic research aiming to give support on policy design, implementation and impact assessment.
The team from UBO joins agricultural economists from the Institute of Food and Resource Economics focusing on economic models and crop scientists from the Institute of Crop Science and Resource Conservation specialized in crop growth modelling, contributing together to the integration of quantitative tools in IA. The focus of their activities in LIASE is on the economic model for European and global agriculture CAPRI (www.capri-model.org) and APES, a modular crop growth model, and their interaction and linkage with other tools.
UEA's internationally acclaimed School of Environmental Sciences (ENV) aims to identify and exploit more effective connections with business, policy makers and wider society in the transition to sustainability. It hosts a number of very well-established integrated research institutes, including the Tyndall Centre for Climate Change Research, CSERGE and InteREAM, all of which include research on policy assessment.
The UFZ was established in 1991 as the only centre in the Helmholtz Association to be exclusively devoted to environmental research. UFZ has participated in more than 110 EC funded projects, many of which developed sustainability indicator and assessment tools. UFZ's Centre of Competence for Soil, Groundwater and Site Revitalisation (TASK) is one of the more recent research and application activities in the area. Among the strategic goals of TASK are the support of stakeholders in developing and assessing sustainable development strategies.
The Plant Production Systems (PPS-WU) group focuses on developing quantitative tools and approaches that enable integrated assessment of present and alternative forms of agricultural land use in temperate and tropical regions, with the strategic aim to contribute to capacity building and to enhance well-informed policy making. PPS-WU is part of the graduate school Production Ecology & Resource Conservation (PE&RC). One of the main tasks of the Graduate School is to develop and co-ordinate education and training of PhD students in this domain.
ZALF is a German national research facility dedicated to the integrated analysis of agricultural landscape systems for sustainable management. Research activities are focused on the development of methods and tools that can be used to anticipate policy impacts on land use changes, to assess their impact on environmental, social and economic sustainability indicators and to support decision making on land use management and policy.
ZEW is a non-profit economic research institute which customers include the European Commission and national ministries. Within ZEW, the research area "Environmental and Resource Economics, Environmental Management" will contribute to LIAISE by bringing in expertise of practical IA studies with socio-economic modelling, especially Computable General Equilibrium (CGE) models by linking economic and environmental modelling.


Help Us Chart The Course!
As a member-driven organization, the Bank Innovators Council needs you to help us chart the course for our first year.
What are the key business problems and opportunities you want to address?
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Where in the innovation process can we add the most value to your efforts?
It take less than ten minutes, and your feedback will ensure that we are working on the things that matter most to you.


This is The Great Spousal Unit, walking our dog at Fort McHenry in Baltimore, home of the Star Spangled Banner, probably one of the greatest public picnic spots in the entire country.
We go there at least a couple of times every year. Usually in the morning, when we grab a couple of portable chairs, two large cups of coffee, a little breakfast, the Sunday newspaper, and the pooch. We take the entire morning, leisurely going through the paper, discussing the latest and how it makes us feel, and taking Boomer for a walk or two. We don't usually return until early afternoon, choosing to take the long way home via city neighborhoods we haven't been through for a while, to see how they're doing too.
If you've never lived with diabetes… imagine having more time for quiet mornings with those closest to you. Imagine having the time to turn your interests and passion into a hobby rather than a mission.
This is Boomer the Dog, and Max the Cat. As you can see, they get along pretty well.
Neither Boomer nor Max are certified alert pets or therapy pets. The service and friendship they provide fall short of and expand far beyond those definitions. Max does have a knack for knowing when my blood sugar is low, or at least a knack for getting me to focus on treating a low. Boomer provides that rock solid dependability that helps you to know that no matter what, he's on your side and he's not going anywhere. When you're excited about an achievement, or you're sobbing due to some insult swallowed or dream dashed, he's always there, tail wagging, ready to pick you up.
If you've never lived with diabetes… imagine your dog or cat as just a buddy, not a family member. Then imagine having the gift of a beloved pet who will celebrate triumphs over diabetes and commiserate over losses due to diabetes with you. No questions asked, no conditions. Imagine how incredibly special that can be.
These are some of my friends who live with diabetes.
Having a friend is spectacular. Having friends who understand you is like Christmas. Having friends who understand you, don't judge you, and want to hang out with you now and then is like having Christmas every day of the year.
These people know you. They know what you go through. Sometimes, they're rule breakers like you. They can help you navigate problems with devices, or give you insight into a new drug you haven't tried. They'll also help take your mind off the fact that you have a chronic condition you won't ever be able to shake off. They are worth their weight in gold.
If you've never lived with diabetes… imagine feeling alone in your disease, feeling like you're the only one who understands or ever will understand what you're going through. Imagine the despair that can bring on after a couple of decades. Then imagine suddenly being accepted by new friends, just for having a busted pancreas, just because they too have known the despair. Imagine the gratitude you'll feel and the renewed sense of purpose it gives you, every time you interact with them.
Hey listen, maybe your life is a lot like this. Maybe you have a dog or a cat too. Maybe they bring joy to your life. Maybe you're doing okay, and if you are, I am truly happy for you. We all deserve happiness.
I don't know where my life is going from here. I only know that because of the people, the pets, and the experiences in my life, my outlook isn't as bleak as it once was, and my diabetes is all the better for it. In fact, things are pretty damn great right now. We all deserve happiness.
It's Friday… and today, it's a special Family Day edition of Happy-Medium.net.
– First, a little about my own family. Before The Live-In Niece there was The Live-In Nephew. One of my godsons. He grew up mostly in Indiana. In January 2003, he moved in with us at age 20. All his possessions in the world were in a duffel bag. No prospects. Three years later, he had a great job and moved in with his girlfriend. Two years after that, four years ago today, they were married. I was shocked and honored when he asked me to be his best man. I thought that was as good as it was going to get. Until they had the baby this spring… on my birthday.
Happy Anniversary Brian and Erin!
– Finally, a couple of JDRF items for any of you who are reading or living in Maryland. One is about the application process starting for the JDRF Children's Congress. And the other is about the JDRF Kids Walk program (this is a great idea).
Have a great weekend! I've gotta get out and shop for an anniversary gift (mine is next week)!


Terms of Service - Scooter's Lawn Care, Inc.
Items are categorized by service but may apply to all/other/unlisted services.
When you have accepted an estimate, you will be prompted to enter your credit card information into our Customer Portal. This must be completed before your first service can be scheduled. Your chosen credit or debit card information will be encrypted and stored in a safe and secure electronic payment system, to be used only by our company for the purpose of collecting payment for services performed by our company. Payment for lawn care services will be charged to your card on file every Monday for the previous week of service. An electronic receipt will be sent to you. If a payment is unable to be processed, service will be put on hold until payment is made, and a $25 fee will be charged to your account. Repeated unsuccessful payments may result in termination of service.
In a business whose productivity relies upon the weather, scheduling can be difficult at times. Inclement weather may affect scheduling. We try our best to keep scheduling conflicts to a minimum; however, circumstances that are beyond our control may affect your project start and completion dates. Lawn care services are placed on a weekly schedule and adjusted as needed throughout the season by our professionals. We do not currently offer bi-weekly service, except when our professionals agree that weather dictates we do so. Please note that if our lawn care crews come to your property to perform scheduled lawn care service and your lawn is freshly mowed by another person or provider without notice to our company, a charge of 50% of your regular service cost will be assessed to your account.
Your service will be predictable and reliable. Since you'll know when we're coming, we ask that you please pick up all items in your yard and move all vehicles or blockages that may hinder our ability to access gates, etc. This includes dog feces and dog toys, children's toys, hoses, gardening equipment, etc. Extra charges may apply if our mowing crew is responsible for picking up items in your yard (this excludes sticks and yard debris when we are providing a clean up service) or is delayed at your property due to blockages. This ensures that our crew can stay efficient and do the best job for you, while avoiding damage to your personal items and our equipment. Repeated occurrences, damage to our equipment or personal injury to our employees may result in termination of service.
While Scooter's Lawn Care, Inc. is on location at your property, you are responsible for keeping all children and pets, as well as other individuals, away from the work area. This is for your safety, as well as our own.
If a storm or heavy wind leaves behind excessive sticks, tree limbs, and/or yard debris, we will clean up what is necessary and charge at a rate of $50 per man hour plus a $20 disposal fee. In most instances, we will communicate with you before any work is done; the only exception is if the debris is so severe that it hinders our ability to provide your regularly scheduled lawn service. If your lawn has acquired heavy debris between mows, please contact us to discuss your options.
If a tree on your property (or a neighbor's property) causes excessive discharge to the point that it hinders our ability to provide your regularly scheduled lawn service, we will charge at a rate of $50 per man hour plus a $20 disposal fee to clean up the area. If your lawn has acquired heavy debris between mows, please contact us to discuss your options.
Our crew leaders are trained professionals. When they arrive on the job site, they analyze the status of your lawn. If it appears that it does not need mowed and would benefit from skipping a week of service, the crew leader will make a note of the skipped service. This may happen during drier periods or toward the beginning/end of the season. Otherwise, your lawn will be mowed weekly. You are allowed two requested skips per year at no charge, if requested at least 24 hours before your service is scheduled to be performed. If you request to skip service with less than 24 hours notice, or request more than two skips per season, your account will be charged $25 per event.
Please be advised that we mow at a 3 1/2 inch blade length during the spring/fall and 4 inches during the summer. This guarantees optimal health, quality, and aesthetic of your lawn. Mowing shorter than 3 1/2 – 4 inches damages grass roots, promotes weed growth, and destroys the overall look of your lawn. We take pride in the lawns we mow. We want you to take pride in the health and beauty of your lawn as well.
We cannot be held responsible for damage to irrigation systems, sprinkler heads, downspout covers, etc. We can replace certain items for a small fee. We cannot be held responsible for damage to certain unavoidable areas that could be affected by a string trimmer, including, but not limited to: fencing, mailbox posts, fences, swingsets and play areas, unprotected siding that may be low to the ground, and other unprotected areas. If an item should be directly damaged by our equipment, we will communicate the issue with you as soon as possible. Please note that Scooter's Lawn Care, Inc. is fully licensed and insured, carries one million dollar liability insurance, and workers' compensation coverage on all Scooter's Lawn Care, Inc. employees.
Your 100% satisfaction is guaranteed. If for any reason you are not satisfied with the quality of service you have received, please contact us within 24 hours. This contact may be in the form of a phone call or voicemail, e-mail, or service request through our Customer Portal. Please leave your contact information and describe the issue in detail. If you contact us after regular business hours (Monday through Friday 8:00am to 5:00pm), we will contact you as soon as possible when we re-open. If an issue should arise after the 24 hour window, it may be due to an issue of nature or other circumstance that could prevent us from correcting the problem at no charge.
If you choose to cancel your weekly lawn care service, a 24 hour notice (or if your service day is Monday, please notify us before 4:00pm on Friday) is required. If we do not receive notice of your cancelation, a charge of 50% of your regular service cost will be assessed to your account.
Once weekly service begins, you'll be placed on our annual schedule for service to resume each spring. Written notice of cancelation is necessary from either party to end service.
When you have accepted an estimate, you will be prompted to enter your credit card information into our Customer Portal. This must be completed before your first service can be scheduled. Your chosen credit or debit card information will be encrypted and stored in a safe and secure electronic payment system, to be used only by our company for the purpose of collecting payment for services performed by our company. Payment for lawn treatments will be charged by the end of the day of your service (or within 24 hours). It may be charged to your card on file the following Monday if you also receive lawn care services with our company. An electronic receipt will be sent to you. If a payment is unable to be processed, service will be put on hold until payment is made, and a $25 fee will be charged to your account. Repeated unsuccessful payments may result in termination of service.
In a business whose productivity relies upon the weather, scheduling can be difficult at times. Inclement weather may affect scheduling. We try our best to keep scheduling conflicts to a minimum; however, circumstances that are beyond our control may affect your project start and completion dates.
Your service will be predictable and reliable. We ask that you please pick up all items in your yard. This includes dog feces and dog toys, children's toys, hoses, gardening equipment, etc. Extra charges may apply if our crew is responsible for picking up items in your yard (this excludes sticks and yard debris when we are providing a clean up service). This ensures that our crew can stay efficient and do the best job for you, while avoiding damage to your personal items and our equipment.
Chemicals will be used during your fertilization and weed control treatments. While Scooter's Lawn Care, Inc. is on location at your property, you are responsible for keeping all children and pets, as well as other individuals, away from the work area. Please keep the work area cleared of all children and pets for 24 hours following our service. Please note that Scooter's Lawn Care, Inc. is fully licensed and insured, carries one million dollar liability insurance, and workers' compensation coverage on all Scooter's Lawn Care, Inc. employees.
If we also provide weekly lawn care, we'll be at your property regularly and will inspect it at each visit. If we only provide fertilization and weed control treatments, we will provide six application services through the season (excluding additional grub treatment, aeration, and over-seeding services) and two free lawn inspections (scheduled by us). If you request additional inspections outside of our regular service schedule, a non-refundable $50 service fee will be charged to your account.
If an area in your yard is affected by a fungal disease, we will contact you regarding appropriate treatment. Cost of service will be dependent on severity of the issue.
Our six applications span the season in approximately 6-8 week intervals. If excessive rain/watering or weather conditions demand an interim application (i.e., causing excessive and/or uncontrollable weed growth), we will contact you regarding appropriate course of action.
Fertilization and weed control is a long-term service. Depending on the health of your lawn before our services begin, it may take a season or more to achieve the results we all want. It's also important to remember that weed control does not mean weed eradication, and in many cases, certain weeds must germinate and grow a bit before we can effectively treat them. We have developed a very effective five application treatment plan that spans the growing season, but Mother Nature is ultimately in control in the end. If you have any questions or concerns throughout your service season, please don't hesitate to contact us.
Once fertilization and weed control service begins, you'll be placed on our annual schedule for service to resume each spring. Written notice of cancelation is necessary from either party to end service.
When you have accepted an estimate, you will be prompted to enter your credit card information into our Customer Portal. This must be completed before your first service can be scheduled. Your chosen credit or debit card information will be encrypted and stored in a safe and secure electronic payment system, to be used only by our company for the purpose of collecting payment for services performed by our company. In a business whose productivity relies upon the weather, scheduling can be difficult at times. Inclement weather may affect scheduling. We try our best to keep scheduling conflicts to a minimum; however, circumstances that are beyond our control may affect your project start and completion dates. You will be notified of any changes.
By accepting your landscaping or trimming estimate, you agree to pay the cost of your service in its entirety. You understand that if the service cost is $1000 or higher, a 50% non-refundable deposit (or pre-payment) will be required before services can be scheduled. Payment will be due (either the remaining 50% or payment in full) at the time the service is completed, unless otherwise discussed. It will be required to place a credit card on file in our secure online Customer Portal, unless otherwise stated. Payment will be collected by us through the credit card on file in the Customer Portal at the completion of the service, unless otherwise stated. In the case that we are unable to secure payment, the customer agrees to pay any collection cost incurred by Scooter's Lawn Care, Inc. related to the collection process of outstanding balances.
Scooter's Lawn Care, Inc. offers a one year limited landscape warranty and five year hardscape warranty.
By accepting this estimate, you agree to provide Scooter's Lawn Care, Inc. the right to use an on-site water supply as needed to complete the stated project without compensation. It is the Customer's responsibility to make sure the water supply is on and working before we arrive. Service may be rescheduled, canceled, and/or additional charges may apply if water is not available at the time of our arrival.
By accepting this estimate, you understand that the service will be performed at the agreed upon service address. It is your responsibility to procure any and all necessary property surveying, permits, etc., unless otherwise discussed.
By accepting this estimate, you understand the scope of work is limited to the description in the service estimate and/or design or sketch. Scooter's Lawn Care, Inc. has no responsibility or liability for services that were not performed, if not listed in the service estimate. If you have any questions about the scope of work in this project, please contact us before accepting this estimate. If for any reason the scope of work should change or increase due to customer request or matters out of our control, the compensation amount may change. Additional service requests or changes may be scheduled for a later date.
Scooter's Lawn Care, Inc., is not liable for any weeds that may emerge after a landscape installation has been completed. Weed seeds are spread through wind and weather, i.e. factors beyond our control.
While Scooter's Lawn Care, Inc. is on location at your property, you are responsible for keeping all children and pets, as well as other individuals, away from the work area. This is for your safety, as well as our own. Please note that Scooter's Lawn Care, Inc. is fully licensed and insured, carries one million dollar liability insurance, and has workers' compensation coverage for all Scooter's Lawn Care, Inc. employees.
Removal and replacement of grills, patio furniture, planters, children's and pets' toys, etc. is the responsibility of the homeowner. Once you are placed on our schedule, please prepare for our arrival accordingly. Should we need to remove items from the deck or yard, we will not be responsible for breakage, storage issues, or proper return to the original area. An additional charge will be applied for the time and labor devoted to the removal of these items.
Scooter's Lawn Care, Inc. cannot be held liable for any damage that may be out of our control, including ground status during excavation. We cannot be held liable for damage to our work should surrounding features or structures fail. Please note that Scooter's Lawn Care, Inc. is fully licensed and insured, carries one million dollar liability insurance, and workers' compensation coverage on all Scooter's Lawn Care, Inc. employees.
Scooter's Lawn Care, Inc. may take photographs of your property, in terms of "before" and "after" purposes. By accepting this estimate, you grant us the permission to take such photographs and give us sole rights to the property of these photographs.
Once you accept the estimate and secure any required pre-payments (see #2), your service will be scheduled at our next available opening, unless otherwise discussed. In a business whose productivity relies upon the weather, scheduling can be difficult at times. Inclement weather may affect scheduling. We try our best to keep scheduling conflicts to a minimum; however, circumstances that are beyond our control may affect your project start and completion dates. You will be notified of any changes.
By accepting this estimate, you agree to pay the cost of this service in its entirety. You understand that if the service cost is $1000 or higher, a 50% non-refundable deposit (or pre-payment) will be required before services can be scheduled. Payment will be due (either the remaining 50% or payment in full) at the time the service is completed, unless otherwise discussed. It will be required to place a credit card on file in our secure online Customer Portal, unless otherwise stated. Payment will be collected by us through the credit card on file in the Customer Portal at the completion of the service, unless otherwise stated. In the case that we are unable to secure payment, the customer agrees to pay any collection cost incurred by Scooter's Lawn Care, Inc. related to the collection process of outstanding balances.
All warranties are limited to those offered by the manufacturers of the products used by Scooter's Lawn Care, Inc. The company makes no additional warranties. If you ever have a concern regarding our work, please contact us immediately.
By accepting this estimate, you agree to provide Scooter's Lawn Care, Inc. the right to use an on-site source of electricity as needed to complete the stated project without compensation.
The properties and species of wood, age and weather can greatly affect the resulting color or tone of the stain. Variances may occur on individual boards, as well as total project densities, and other characteristics vary across and throughout wood. Scooter's Lawn Care, Inc. and all of its associates attempt to represent final finish color and tones as best as possible. While we can often give you an idea of the overall color or tone, you must expect some variance in the overall finish.
Please be advised that some chemicals will be used during this service. While Scooter's Lawn Care, Inc. is on location at your property, you are responsible for keeping all children and pets, as well as other individuals, away from the work area. Please keep the work area cleared of all children and pets for 24 hours following our service. This is for your safety, as well as our own.
Removal and replacement of grills, deck furniture, planters, etc. is the responsibility of the homeowner. Once you are placed on our schedule, please prepare for our arrival accordingly. Should we need to remove items from the deck or yard, we will not be responsible for breakage, storage issues, or proper return to the original area. An additional charge will be applied for the time and labor devoted to the removal of these items.
Scooter's Lawn Care, Inc. is not responsible for damages due to improperly installed siding, loose shingles or siding, broken or open windows, improperly sealed windows, wood rot, defective construction, improperly secured wires, loose or improperly installed gutters and leaders, and improper caulking. In every aluminum siding case, and in some case in vinyl siding, the sun and weather will bleach the color and cause it to fade. Pressure washing, which entails removal of chalky grit of failing surface materials, may cause the faded aspects of the vinyl or aluminum to stand out. Scooter's Lawn Care, Inc. will not be responsible for such conditions. Scooter's Lawn Care, Inc. will not be responsible for loose mortar that may dislodge during the cleaning process. Please note that Scooter's Lawn Care, Inc. is fully insured, carries one million dollar liability insurance, and workers' compensation coverage on all Scooter's Lawn Care, Inc. employees.
Some stains cannot be removed by pressure washing. Tree sap, artillery fungus, and splatters from stain and paint are examples of materials that cannot be removed by conventional means. We make every attempt to point out these areas to the customers when quoting the project. Sometimes these stains cannot be removed at all.
Scooter's Lawn Care, Inc. expects your property to be in good repair and weather-tight. This includes, but is not limited to all electrical service including receptacles and light fixtures. Doors and windows shall also be weather-tight. Scooter's Lawn Care, Inc. is not responsible for any damages as a result of water infiltration from proper installation, maintenance, or repair of electrical related items or doors or windows. Scooter's Lawn Care, Inc. cannot guarantee removal of artillery fungus from exterior house surfaces.
Windows may become water spotted as a result of our services. Window cleaning is not included.
When you have accepted an estimate, you will be prompted to enter your credit card information into our Customer Portal. This must be completed before your first service can be scheduled. Your chosen credit or debit card information will be encrypted and stored in a safe and secure electronic payment system, to be used only by our company for the purpose of collecting payment for services performed by our company. Payment for emergency snow plowing and ice melt applications will be charged to your account within 24 hours of service. If a payment is unable to be processed, service will be put on hold until payment is made, and a $25 fee will be charged to your account. Repeated unsuccessful payments may result in termination of service.
Unless otherwise designated per special contract, your property will be serviced (and charged "per push") with zero tolerance of snowfall or winter precipitation, and ice melt will be applied if/as necessary. Commercial clients and special contracts may discuss alternate needs.
Even the most experienced snow plow driver can face obstacles. Due to the unavoidable nature of plowing snow, gravel driveways or parking lots may experience an upheaval of gravel after the service is complete. Please note that we are not held responsible for uneven gravel after service is complete. We will be happy to schedule a service to even the driveway after the event is complete. Furthermore, sometimes unavoidable accidents may happen that can result in damage to driveway reflectors, etc. Please contact us if you notice damage after plow service.
© Copyright 2014-2019 Scooter's Lawn Care, Inc.


text:
name             'tomcat'
maintainer       'Opscode, Inc.'
maintainer_email 'cookbooks@opscode.com'
license          'Apache 2.0'
description      'Installs/Configures tomcat'
long_description IO.read(File.join(File.dirname(__FILE__), 'README.md'))
version          '0.15.5'

depends 'java'
depends 'openssl'

supports 'debian'
supports 'ubuntu'
supports 'centos'
supports 'redhat'
supports 'amazon'

recipe 'tomcat::default', 'Installs and configures Tomcat'
recipe 'tomcat::users', 'Setup users and roles for Tomcat'

redpajama_set_name: RedPajamaGithub


text:
9:30pm - Wednesday, May 1, 2019
Young and disenchanted Sam meets a mysterious and beautiful woman who's swimming in his building's pool one night. When she suddenly vanishes the next morning, Sam embarks on a surreal quest across Los Angeles to decode the secret behind her disappearance, leading him into the murkiest depths of mystery, scandal and conspiracy. With Andrew Garfield, Riley Keough, Topher Grace.
"Under The Silver Lake is gorgeous to look at and listen to, with moments of genuine panache." (Empire Magazine)
"A 21st-century mystery steeped in an Old Los Angeles view of the world: the city as a labyrinth of corruption in which sex, greed, and power suffuse the atmosphere but remain off the grid." (Variety)
"The perfect demented detective yarn for our paranoid age." (A/V Club)
Doors 9:00 pm | Movie 9:30 pm
Advance tickets $10.50 | $12.50 at the door
*Minors permitted in the balcony. (18A.) Must be 19+ w/ID for bar service and main floor seating.
**Rio Theatre Groupons and passes OK. Please redeem at the door.
UNDER THE SILVER LAKE (David Robert Mitchell, 2018 / 139 mins / 18A) When his beautiful, mysterious neighbor disappears without a trace, Sam tries to find the parties responsible, unraveling a string of strange crimes, unsolved murders and bizarre coincidences in his East Los Angeles neighborhood.
Tickets no longer on sale for this event.
This event is in the past! Check out our events currently on sale

redpajama_set_name: RedPajamaCommonCrawl


text:
Q: an API to connect to a shared resource on a Novell server Currently we access to the shared files on our Novel server from a client by adding NWLink IPX/SPX protocol to the network interface and setting up a connection.
Now we have to do this automatically in a software running on Windows. So I am looking for way to setup appropriate setting to connect to the Novel server (e.g. adding NWLink IPX/SPX support to the network interface, mapping a network drive) and access the files and disconnects from the server, all programatically.
Another choice would be using a thrid-party library that provides an API to connect to a Novell server, access the files, etc. but I cannot find any library for this. The only thing I have found is Novell Client which doesn't provide an API for the other applications.

A: Both with the Novell Client and with the NWLink IPX/SPX windows client you can shell out to a command line and execute "net use" with the appropriate syntax for what you want.
You can specify a /user and a /password with net use, so that sounds like it would suffice.

redpajama_set_name: RedPajamaStackExchange


Don't let cheap imitations fool you, this Grass Finished Eye Fillet Steak is of the highest quality in Australia. For a truly memorable experience pair with our house jus. At room temperature, sear fillet for a nice even colour on the BBQ or in the pan, then transfer into a hot oven or drop the lid on the BBQ and cook for 40 mins per kg. Rest for 10 mins per kg.


text:
Samuel Rooke's Blog
What comes through, gets a review
Starlady (1976) by George R. R. Martin
Samuel Rooke / October 19, 2016
A grim, confronting short story in George R. R. Martin's "the Thousand Worlds" setting. There's not much of a great hook here, and the worldbuilding and characterisation aren't nearly as strong as they are in some other of Martin's short stories written around the same period, but it's a lean, quick short story, and I didn't feel like I'd wasted my time reading it or anything.
It's a dark story, with a dark look at human nature, and has a very unpleasant amount of rape. Unlike "A Song of Ice and Fire", I don't feel like the story really justified its very unpleasant contents well – there really is not much meat on the bone here, so to speak. I don't feel like the story drew on an actual deep emotional well of Martin's, like "Meathouse Man", didn't find the worldbuilding eminently fascinating, like "In the House of the Worm", and didn't find the characterisation particularly notable, like "A Song for Lya".
The story doesn't completely wallow in its own grimness, and it does all progress to a decent ending, but I don't feel the story is compelling enough to really recommend. It's very short, but there are many superior stories of similar length in this series alone. I give it one holostration, and a no-knife.
October 19, 2016 in Book Reviews.
Dreamsongs: Volume 2 (2006) by George R. R. Martin
Nobody Leaves New Pittsburg (1976) by George R. R. Martin
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Dubai doesn't stop at night, so no neither do we! Aylissa gives the UAE plenty of music, fun and chat for that big night out…Or a big night in. We let the music loose at night, with songs you'll only hear with Aylissa, while visiting the places you need to see in Dubai. Dubai has a huge night time leisure scene which is big business, with family trips out to malls and movies coupled with an ever competitive restaurant and event scene. Evenings with Aylissa is your guide to Dubai at night!


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FedEx: "I'm Off to See the Wizard" in Curitiba
By Brandon Tidwell December 20, 2010
Curitiba is internationally recognized for its integrated transport and land use policies and projects. Photo by www.curitiba-travel.com.br.
Brandon Tidwell, the program advisor for philanthropic investments in education and the environment at FedEx Corp., shares his story about a recent trip to Curitiba, Brazil, where he learned about innovations in transportation, like bus rapid transit, that have transformed the future of the city.
EMBARQ, the producer of this blog, teamed up with FedEx in February this year to launch the Mexican National Network of Cities, a project designed to bring private sector expertise in vehicle technologies and management, branding and marketing, and road safety to the 30 Mexican cities now implementing new mass transportation projects. Read our previous post about why transportation and logistics companies like FedEx are uniquely positioned to work with nonprofits to help improve some of the world's worst traffic.
Originally posted on The FedEx Blog:
I'm off to see the wizard
by Brandon Tidwell
It was my first trip to Brazil, a nation made famous by the Christ in Rio, Copacabana Beach, and the Amazon River basin. However, as FedEx has begun to support mass-transit solutions through EMBARQ, an emerald city from Brazil began to emerge: Curitiba (pronounced Cure-ee-chee-ba), listed as one of the greenest cities in the world. This city of 1.7 million residents was mentioned as the city where bus-rapid transit and transit-oriented development took hold. It was time to head to Oz.
After completing the Junior Achievement Company of the Year Competition in Rio, I hopped on a two-hour flight to Curitiba. Upon arrival into this magical city, I went to find a taxi into the city.
"How would you like to ride the first all-electric taxi in Brazil?" asked the gentleman behind the counter. "It's 20 reals less than a normal taxi." Not only was this taxi environmentally-friendly, but economically-friendly. A triple bottom line taxi ride. Sold!
Rain had moved into the city, cooling it from the summer heat and leaving behind a fog and an emerald vibrancy to all of the trees. As we drove into Oz, buildings and buses and trees unfolded before me. Curitiba had found a way to balance economic growth with environmental sustainability, creating a jewel in Brazil's crown.
That night, I shared a meal at a local Churrascaria with Rejane Fernandes from from the Center for Sustainable Transportation in Brazil, a member of the EMBARQ network. We discussed the amazing opportunities unfolding in Brazil as they prepare for the 2014 World Cup and the 2016 Olympics. Just two days before, Rejane and Toni Lindau introduced me to the Secretary of Transportation in Rio de Janeiro. There he laid out the city's ambitious plan to build a network of 170km of bus-rapid transit throughout the city, moving millions daily. The effort will transform Rio, reducing emissions and congestion, improving road safety and creating safe and reliable access for millions to travel daily.
The next morning, I met one of the wizards of Curitiba, Eduardo Guimarães, Secretary of International Relations. After brief introductions, I was rushed through a down-pouring rain into a car for a city tour. Eduardo showed Rejane and I a half dozen parks and BRT corridors, showing how Curitiba had not only revolutionized bus-rapid transit, but had created over 55 square feet of park space per citizen. The city re-purposed flood plains and quarries, turning them into the most spectacular parks, opera houses and performance spaces.
What was even more amazing was the thrifty nature of their efforts. Parks need gardeners, right? Wrong. Curitiba placed geese and sheep to keep grass trimmed. Need an overnight performance space? In less than 60 days, the city created the most spectacular glass opera house made only of metal and glass inside a quarry, surrounded by the most natural vegetation.
"The former mayor, Jaime Lerner, often said to cut two zeros off every budget item," stated Eduardo. "The best solutions, the most creative ones, come when you have fewer resources, not more."
Twenty-four hours in Curitiba made me realize what cities can truly become and how transportation can shape their future. The movement of goods and people around the world has already revolutionized our planet, but we have to do it better. It's why FedEx is not only using innovative solutions like electric vehicles and hybrids, but the very reason we are supporting innovators like EMBARQ who show cities how BRT can make their future green, both economically and environmentally.
It's an honor to work for FedEx, for we deliver more than just packages, but we change what's possible for millions of people around the world. It's more than moving an item from Point A to Point B. It's about the possibility that happens at Point A and Point B when transportation connects those two communities. The same reality happens in mass-transit. It's not just about the journey, but the magic that happens at the origin and destination.
So here's to creating more Oz-es in this world. See you on the Yellow Brick Road!
To learn more about sustainable transport and land use in Curitiba, watch EMBARQ's video, "Cities in Focus | Curitiba":
EMBARQ-FedEx Collaboration Aims to Improve Public Transport in Developing Countries
Hybrid Buses on the Road in Guadalajara
Cities in Focus: Curitiba
Green Intelligence Live Blogging: "Innovations in Global Transport"
Load-Carrying Bikes Ease the Burden of Delivery
FedEx Makes More Efficient Deliveries with Zero Emissions Electric Bikes
"Transit-Enlightened Cities" Showcase BRT's Brilliance
Businesses Take Responsibility for Advancing Sustainable Transportation
Tags: Brazil, business, CSR, Curitiba, FedEx, South America


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Home > Our University > Our colleges and professional services > Engineering and Physical Sciences > News > Carbon emissions targets mean nearly all homes need upgrading, according to expert
Carbon emissions targets mean nearly all homes need upgrading, according to expert
Jeff Douglas, Strategy Manager, Energy Technology Institute, informed guests of the Birmingham Energy Institute last week (Thursday 2 July) that the UK faces a big energy challenge in light of the country's ambitious carbon reduction targets.
Mr Douglas said:
It is clear that to meet climate change targets we need to largely eliminate carbon emissions from our buildings as part of a least cost transition to a low carbon energy system. With 90% of existing houses expected to still be in use in 2050, new forms of low carbon heating will be needed for almost all of our 26 million homes.
Jeff Douglas, Strategy Manager - Smart Systems and Heat at the Energy Technology Institute, delivered a seminar titled 'Decarbonising Heat for UK Homes – next steps', which will examine two principal pathways towards the decarbonisation of domestic space and water heating. The Birmingham Energy Institute at the University of Birmingham hosted the free seminar on Thursday 2 July 2015.
Jeff discussed the challenges the country faces in displacing gas heating in a way that is acceptable to the consumer, and the possible market frameworks and national policies that would support any successful transition.
'The market cannot be expected to engage in such delivery without the essential foundations of clear strategic direction, effective policy-making and proven business models. We also need to learn by doing, and recognise that the real challenges are not just technology based, but rather more about gaining public consensus and trust.'
'The importance of preparation cannot be over emphasised as a lack of market confidence and delay in building the necessary momentum will inevitably lead to higher costs driven by harder pressed resources, along with missed targets and business opportunities.'
The Energy Technology Institute is a public-private partnership between global energy and engineering companies and the UK Government. The Institute acts as a conduit between academia, industry and the government to accelerate the development of low carbon technologies, and bring together engineering projects that develop affordable, secure and sustainable technologies to help the UK address its long term emissions reductions targets as well as delivering nearer term benefit.


Nicolas Feuillatte, the man who gave his name to what would become the biggest selling Champagne brand in France, has died at the age of 88.
Feuillatte was born in Paris in 1926 and moved to the US where, by predicting the US demand for instant coffee, he soon became the largest importer of African coffee to the country. During this time, he became friendly with some of the most well-known celebrities of the day including his golf partners, the Kennedy's and Aristotle Onassis.
Nicolas Feuillatte was held in such high regard by the Ivory Coast, one of Africa's largest coffee producers, that he was appointed their Permanent Delegate to the United Nations in 1962.
At the age of 50 he decided to return to France permanently and took over his family's 12 hectare estate in the Ardre Valley near Reims. Feuillatte immediately started to produce his eponymously named Champagne and due to his famous friends and business associate its popularity grew in the US to the point that demand quickly outstripped supply. The two celebrities credited with assisting the Champagne's meteoric rise were Jacqueline Onassis and the actress Lauren Bacall.
In 1986 Nicolas Feuillatte decided to sell the brand to the Cenre Vinicole de Champagne (CVC) run by Henri Macquart. Under Marquart's presidency the CVC has grown to become the largest Champagne cooperative with 5,000 growers and 2,200 hectres under vine. Almost 10% of the Champagne produced for CVC is marketed under the Nicolas Feuillatte brand which encompasses entry level Champagnes up to their prestige cuvees, Palmes d'Or and Palmes d'Or Rosé. Last year, Nicolas Feuillatte Champagnes were the third highest selling in the world behind Moet and Veuve Clicquot with sales of over ten million bottles.
In recent years, Nicolas Feuillatte was a tireless ambassador for the brand, bringing the joie de vivre that marked his early business career and social life to today's global powerhouse that he will forever be associated with.


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Mumbai Indians VS Kings XI Punjab 24th T20 Match Prediction. We Provide you the 100 % Sure today Match Prediction tips by t20predictions.com Who will win the today Match MI VS KXIP Cricket Toss Prediction Free. Get Today Match Prediction About The Match. Online Cricket Batting Tips of MI VS KXIP. Get The Predictions Mumbai Indians VS Kings XI Punjab 24th T20 Match Prediction. Live score with ball by ball update. Cricket tosses prediction free.
Kings XI Punjab has moved to third on the league table after a hard-fought victory against Sunrisers Hyderabad. They will now travel to Mumbai to play against the Mumbai Indians at the Wankhede. The Mumbai Indians have also hit their stride in IPL 2019. They have managed to defend two small totals in their last two matches and will be full of confidence. Making your home ground difficult for all visiting teams is crucial in the IPL and we are sure that the Mumbai Indians will want to do just that. The conditions in the Wankhede are usually pretty good for batting and the Kings XI side has shown the ability to adjust to different venues. Their batting lineup could really enjoy playing in Mumbai as well.
The Mumbai Indians are in a good position on the IPL league table without playing their best cricket till now. We don't think the Mumbai batting has come close to performing at the level which it is capable of. Rohit Sharma has struggled for runs, Quinton de Kock has not been able to convert his good starts into any big scores, and the middle order looks quite unsettled. Both these openers are simply too good to continue failing on an excellent batting pitch like the one that Mumbai offers them. We expect one or maybe even both of them to score heavily in the upcoming match. Kieron Pollard and Hardik Pandya have been in excellent form in IPL 2019. They have struck the boundaries in the late overs and helped Mumbai to get to competitive totals even when the rest of the batting has failed. Players like Ishan Kishan and Suryakumar Yadav need to start performing at their best soon. The pitch at the Wankhede is excellent for batting and we don't think the Mumbai bowling will be able to bail them out in every match.
An excellent bowling performance by the Kings XI in their previous match led to them winning their fourth win out of six matches in IPL 2019. Ravi Ashwin has been very good about getting his match-ups right and making sure that he is always asking questions of the batsmen. The Kings XI decided to play without Tye, Viljoen, and get Mujeeb into the side. We could see the same team playing in the next match as we think Ashwin would want to use Mujeeb up front against de Kock and Rohit Sharma. The batting is going to be decisive at the Wankhede. Lokesh Rahul has hit excellent form and is consistently scoring runs. His side may want him to try and finish off matches a bit earlier than the last over though! We think that Chris Gayle and David Miller are going to play a huge role in this upcoming match. They like the ball coming on to the bat and will not mind the extra bounce in the pitch. Both the batsmen also clear the boundaries with ease and that is again something that we get to see a lot of in Mumbai.
According to per our prediction, Punjab is the favorite team to win this match.
The 2nd match of Indian Premier League 2019 will be played at Wankhede Stadium, Mumbai. The pitch here at this stadium is much favored as batting pitch. It has a decent amount of pace, bounce, and enough carry to allow the batsmen to play their shots freely. A large number of boundaries will be hit on this venue. The pitch may also have some help in it for the seamers.
The weather forecast in Wankhede Stadium, Mumbai is expected nice, Sunny, and good for a cricket match. There are no chances of rain so there should be no interruptions during this match.


Op Art of the Cleveland School, a dazzling exhibition of important works from the Op Art movement. Drawing heavily upon contribu- tions by the Bauhaus to the study of color theory—as well as advancements within the field of psychology relating to human perception—Op (short for 'optical') Art is characterized by hard edged, geometric abstraction, intended to produce visual effects (often described as 'sparkling' or 'pulsating') within the viewer. Featuring works by Cleveland School luminaries Richard Anuszkiewicz, Julian Stanczak, and Edwin Mieczkowski, this sensational exhibition is a testament to Cleveland's crucial role in the development and expansion of the Op Art movement.


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Новотро́їцьке — село Шахівської сільської громаді Покровського району Донецької області, в Україні.

Відстань до райцентру становить близько 17 км і проходить автошляхом . Поблизу села розташоване заповідне урочище Брандушка.

Історія
Назва хутора "Ново-Троїцький" утворене від назви села Троїцького Мелітопольського повіту, звідки походять родини перших поселенців - Бабанін і Перепадя. Це село знаходиться приблизно в 25 кілометрах на північ від міста Мелітополя.

Хутір Ново-Троїцький Золотоколодежской волості заснований в 1890 р або трохи раніше. У 1890 році жителі хутора вперше згадуються в метричних книгах Дмитрівській церкві с. Золотий Колодязь  У 1898 році поміщиця з Золотого Криниці Олена Юхимівна продала частину своєї землі вихідцям з Таврії. Першими поселенцями були 32 родини.

Жителі хутора - вихідці в основному з Мелітопольського і Бердянського повітів Таврійської губернії і Олександрівського повіту Катеринославської губернії. За цими повітах і губерніях вони і продовжують значитися в метричних книгах до 1919 р, хоча фактично жили на хуторі Ново-Троїцькому.

Населений пункт був дуже заможний. Тому в 1930 році значна частина його жителів розкуркулено.

Відомі люди
 Катрич Ганна Михайлівна -  "Мати - героїня".

Жертви сталінських репресій
 Красюк Микола Пилипович, 1904 року народження, с. Новотроїцьке Краматорського району Донецької області, українець, освіта початкова, безпартійний. Проживав: х. Донський Краматорського району Донецької області. Робітник заводу ім. Ворошилова. Заарештований 24 грудня 1937 року. Засуджений трійкою УНКВС по Донецькій області до розстрілу з конфіскацією майна. Вирок приведено до виконання у м. Сталіно (м. Донецьк) 2 березня 1938 року. Реабілітований у 1962 році.
 Іващенко Кирило Силович, 1891 року народження,  с. Новотроїцьке Краматорського району Донецької області, українець, освіта початкова, безпартійний. Хлібороб. Проживав: х. Швейцарія Краматорського району Донецької області. Заарештований 29 березня 1932 року. Особливою нарадою при колегії ДПУ УРСР 2 листопада 1932  року засуджений на 3 роки ВТТ. Реабілітований у 1990 році.

Підприємства
 ТОВ АПК "Бекон"

Примітки

Джерела
 http://forum.gp.dn.ua/viewtopic.php?f=46&t=3188
 Подолян В. В. Слово про Добропілля: роки, події, люди / В.В. Подолян. – Донецьк: Престиж-party, 2009. – 367

Села Донецької області

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Justia Dockets & Filings Ninth Circuit California Eastern District Betti v. Kaiser Permanente, et al Filing 60
Betti v. Kaiser Permanente, et al
MEMORANDUM of OPINION and ORDER signed by Judge David F. Levi on 2/14/06 GRANTING 51 Motion for Reconsideration, DENYING Plaintiff's Request to amend complaint to include a claim for a hostile work environment, and GRANTING Plaintiff's Request to Amend Complaint to name TPMG. Case reopened.(Donati, J)
Betti v. Kaiser Permanente, et al Doc. 60 Case 2:03-cv-02678-RRB-DAD Document 60 Filed 02/15/2006 Page 1 of 13 1 2 3 4 5 IN THE UNITED STATES DISTRICT COURT 6 FOR THE EASTERN DISTRICT OF CALIFORNIA 7 8 9 10 v. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 As there is employer and which will refer to both "Kaiser" unless it entities. 1 ANGELA M. BETTI Plaintiff, CIV-S-03-2678 DFL DAD MEMORANDUM OF OPINION AND ORDER KAISER FOUNDATION HEALTH PLAN, INC. aka KAISER PERMANENTE, Defendants. Plaintiff Angela Betti ("Betti") moves for reconsideration of the court's order granting defendant Kaiser Foundation Health Plan's ("KFHP") motion for summary judgment.1 For the reasons stated below, the court: (1) GRANTS Betti's motion for reconsideration; (2) DENIES Betti's request to amend her complaint to include a claim for hostile work environment under the ADA; and (3) GRANTS Betti's request to amend her complaint to name TPMG. a dispute over the identify of Betti's entity was acting at any given time, the court KFHP and The Permanente Medical Group as is necessary to differentiate between the two 1 Dockets.Justia.com Case 2:03-cv-02678-RRB-DAD Document 60 Filed 02/15/2006 Page 2 of 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 I. Betti was employed at the Kaiser facility in Stockton as a psychiatric social worker's assistant, working towards licensure as a licensed clinical social worker. (Mot. at 2.) In the summer of 2002, Betti was diagnosed with post-traumatic stress disorder ("PTSD"). (Kramer Decl. Ex. 9 at 15.) During the summer and early fall of 2002, Betti's supervisor, Allison Kemps, received reports that Betti was coming in late and having difficulty completing her paperwork during her scheduled hours. (SUF � 10.) Betti missed an appointment with a client on October 15, 2002 and then missed a rescheduled appointment with the same client on October 28, 2002. (Kemps Decl. � 7.) Betti also missed work on November 7, 2002, and on several occasions in December. (Id.) A meeting was held between Kemps and Betti on January 14, 2003. (SUF � 14.) Betti's schedule, her tardiness, and her (Response to SUF � 14.) absences were discussed at the meeting. At this point, Betti was working four ten-hour shifts each week, starting at 8:30 a.m. on Monday and Wednesday mornings and 9:30 a.m. on Tuesdays and Thursdays. (Kemps Decl. � 8.) During the meeting, Kemps suggested that Betti switch to five eight-hour shifts, which would allow her to come in later, but Betti rejected this suggestion. (Id. � 9.) The meeting ended with an agreement that Betti would provide a proposed revised schedule that would allow her to come in later. Decl. Ex. 5 at 59.) (Kemps Decl. � 10; Kramer However, Kemps did require that Betti come 2 Case 2:03-cv-02678-RRB-DAD Document 60 Filed 02/15/2006 Page 3 of 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 in at 8:30 a.m. on Wednesday morning to be present for the mandatory weekly "Child Team" meeting. 148, 224.) (Kramer Decl. Ex. 5 at Furthermore, Betti informed Kemps that she did not want to give up her Monday morning assignment at August Elementary School because she enjoyed the work and felt she could arrive on time on Mondays. (Id. at 122, 224-26.) On February 4, 2003, another meeting was held, with Kemps, Betti, and Betti's union steward and clinical supervisor, Larry Meade. (Kemps Decl. � 11, Ex. 3.) At the meeting, the parties (Id.) Betti worked together to modify Betti's schedule. submitted a new proposed schedule on February 6, 2003, which pushed back her start time to 10:30 a.m. on Tuesday and Thursday. (Kramer Decl. Ex. 5 at 61.) Kemps immediately approved the schedule, but informed Betti that, for administrative reasons, the schedule could not be officially implemented until April. (Kemps Decl. � 13.) In the meantime, Kemps offered to remove all of the early morning appointment slots from Betti's schedule, but Betti declined this offer. (Id.) On Wednesday February 19, 2003, Betti did not arrive at work on time and missed the 8:30 a.m. meeting. (Id. � 15.) Betti (Id. � also missed a client appointment scheduled at 9:45 a.m. 16.) Another provider, Adam Pollack, treated the patient after (Kramer Decl. Ex. 11 at noticing that Betti had not arrived. 31-22; Def.'s Ex. G at 39-41.) After twice attempting to contact Betti, Kemps told the receptionist to cancel the remainder of Betti's appointments for the day. 3 (Kemps Decl. Ex. 7.) Betti Case 2:03-cv-02678-RRB-DAD Document 60 Filed 02/15/2006 Page 4 of 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 woke up at 11:00 a.m., immediately called the Kaiser receptionist, and was told that Kemps had cancelled the remainder of her schedule. (Kramer Decl. Ex. 5 at 93.) Betti then contacted Kemps, who told her not to come into work for the remainder of the day and directed her to obtain a note from her physician explaining her tardiness. (Id. at 93-94.) Betti (Kemps returned to work the next day with the requested note. Decl. � 18.) Kemps convened another meeting with Betti and Meade on February 25, 2003, at which Kemps announced her intent to proceed with a "corrective action plan" ("CAP") because of Betti's "gross misconduct" in failing to call or appear for work on February 19, 2003. (Id. � 19, Ex. 9.) Meade protested that this discipline was excessive and, after some arguing back and forth, Betti and Meade left the meeting. (Id.) Kemps presented Betti with the CAP at a March 6, 2003 meeting, where Meade was also present. (Id. � 20.) The CAP provided, among other things, that Betti would arrive on time "in all circumstances." (Id. Ex. 10.) Betti refused to sign the CAP and indicated that she intended to file a union grievance to protest the discipline. (Id. Exs. 10-11.) On March 26, 2003, Betti arrived at work at least 30 minutes late, missing the weekly Wednesday meeting. at 166-67.) (Kramer Decl. Ex. 6 The following day, Betti was at least 20 minutes late, arriving at 10:50 or 11:00 a.m., when her modified schedule required her to arrive at 10:30 a.m. 4 (Id. at 167-68.) Kemps Case 2:03-cv-02678-RRB-DAD Document 60 Filed 02/15/2006 Page 5 of 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 then notified Betti in writing that there would be further disciplinary proceedings. (Kemps Decl. � 21, Ex. 12.) On March 31, 2003, Betti went on medical leave. (SUF � 30.) Starting in July 2003, Betti's counsel and counsel for TPMG, Susan Spurlack, began to correspond about Betti's return to work. (Supplemental Alden Decl. Ex. D.) On August 21, 2003, Betti's psychiatrist, Dr. Jurkowski, indicated that Betti could return to work if two conditions were met: (1) if she were given an afternoon schedule for six months to a year; and (2) if she were transferred to a different clinic. (Kemps Decl. Ex. 13.) Counsel for Kaiser responded to these requests for accommodation by letter on October 6, 2003. Decl. Ex. 13.) (Supplemental Kramer Counsel stated that an afternoon schedule could be accommodated, with the exception of the Wednesday morning meeting. (Id.) The letter indicated that, despite Betti's argument to the contrary, attendance at the Wednesday meeting had not been waived for other staff members. (Id.) However, the letter invited Betti to submit any "other facts" she believed were relevant to the Wednesday meeting. (Id.) Counsel also responded that the second request, for a transfer to a different facility, was not required under state or federal law. (Id.) She also stated that Betti could apply for a transfer, but that there were currently no openings Betti was qualified to fill. (Id.) Between October 6, 2003 and November 20, 2003, counsel for 26 both parties apparently had conversations regarding Betti's 5 Case 2:03-cv-02678-RRB-DAD Document 60 Filed 02/15/2006 Page 6 of 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 transfer, and Kaiser agreed to assist in forwarding Betti's "application for transfer to either the South Sacramento or Modesto Kaiser facilities." (Id. Ex. 14.) However, counsel for Kaiser indicated that Betti would not be placed at the top of the list for a transfer. (Id.) In a letter dated November 22, 2003, Betti's counsel objected to this position and argued that Betti was entitled to expedited consideration because the transfer was a necessary accommodation. (Id.) Betti's counsel reiterated this argument in correspondence on December 3, 2003 and December 4, 2003. (Id. Exs. 15, 16.) On January 5, 2004, counsel for Kaiser informed Betti's counsel that it had run a search for vacant positions at its Manteca, Modesto, South Sacramento, and Sacramento facilities, and found no current vacant positions for a psychiatric social worker without licensure. (Supplemental Alden Decl. Ex. C.) The letter also indicated that Kaiser had no obligation to transfer Betti to an open clinical social worker position, which requires licensure. (Id.) However, Kaiser indicated that it was willing to explore positions in locations other than those indicated or other job classifications for which Betti might be qualified. (Id.) Kaiser again reiterated, on January 13, 2004, that it had searched for vacant positions, that no vacant positions were currently available, and that it was willing to look at other positions and locations. (Id., Ex. B.) Kaiser also indicated (Id.) that it would notify Betti if a position became available. Betti's first amended complaint, naming KFHP as a defendant, 6 Case 2:03-cv-02678-RRB-DAD Document 60 Filed 02/15/2006 Page 7 of 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 was filed on January 21, 2004 and raises two claims: (1) that KFHP failed to provide a reasonable accommodation for Betti's disability in violation of the ADA, 42 U.S.C. �� 12101 et seq.; and (2) that KFHP refused to provide a reasonable accommodation for Betti's disability in violation of the California Fair Employment and Housing Act ("FEHA"), Cal. Gov. Code �� 12900 et seq. On June 6, 2005, Kasier moved for summary judgment. motion, Kaiser argued that: (1) it provided a reasonable accommodation to Betti; (2) Betti could not perform the essential functions of her job, with or without modifications; and (3) it was not Betti's employer. (Mot. for Summ. J. at 2.) The court In that granted summary judgment, finding that Betti's requested transfer was not a reasonable accommodation. (7/25/2005 Order at 12.) (Id. at The court also found that KFHP was not Betti's employer. 13.) The court declined to let Betti amend her complaint to name TPMG as a defendant because, based on the accommodation finding, any amendment would have been futile. II. Betti moves for reconsideration of the court's order granting summary judgment under Fed.R.Civ.P. 59(e) based on the following arguments: (1) the court overlooked evidence crucial to the reasonable accommodation finding; (2) the court cannot decide whether Kaiser engaged in the interactive process as a matter of law; and (3) Betti's hostile work environment claim is still pending before the court. 7 (Id.) Case 2:03-cv-02678-RRB-DAD Document 60 Filed 02/15/2006 Page 8 of 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 There are four grounds upon which a Rule 59(e) motion may be granted: (1) the motion is necessary to correct manifest errors of law or fact upon which the judgment is based; (2) the moving party presents newly discovered or previously unavailable evidence; (3) the motion is necessary to prevent manifest injustice; or (4) there is an intervening change in controlling law. McDowell v. Calderon, 197 F.3d 1253, 1254 n.1 (9th Cir. 1999) (quotations and citations omitted). A. Reasonable Accommodation In granting KFHP's motion for summary judgment, the court based its reasonable accommodation decision on the fact that Kaiser engaged in a good-faith interactive process. Order at 10-12.) (7/25/2005 The court found that Betti did not inform Kaiser of her willingness to work in locations such as Richmond, and because KFHP had no other open positions, Kaiser did all that it could to accommodate her. (Id. at 11-12.) Betti argues that the court overlooked evidence showing that she was willing to work in other Northern California facilities, including Richmond. First, she points to her attorney's declaration in support of her opposition to summary judgment. (Mot. at 7.) In that declaration, her attorney states that "in approximately October 2003, in a telephone conversation, I notified Kaiser's counsel that [Betti] would accept a transfer to just about any other facility in [N]orthern California." Decl. � 21.) oral argument. (Kramer Second, Betti refers to her counsel's statements at At that hearing, her attorney stated that she 8 Case 2:03-cv-02678-RRB-DAD Document 60 Filed 02/15/2006 Page 9 of 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 told Kaiser that Betti was willing to relocate to "any facility in Northern California" because "[s]he was willing to relocate to keep her job." (Mot. at 8.) Finally, Betti's counsel also claims that she disclosed this fact to Kaiser in a January 20, 2004 letter by stating that Betti's request for relocation was not limited to the Sacramento, Manteca, or Modesto offices. at 9; Kramer Reconsideration Decl. Ex. 2.) In response, Kaiser argues that Betti's motion for reconsideration should be denied because: (1) even assuming Betti told Kaiser that she would transfer to any Northern California office, that request was not specific enough; (2) the court did not base its decision to grant summary judgment solely on this issue, but on a general finding that Kaiser did not have any positions available, regardless of location; and (3) Kaiser did not have any positions available for Betti, including the position in Richmond. (Opp'n at 5-7.) (Id. Given this record, the court grants the motion for reconsideration. In the court's defense, counsel for plaintiff could have done a better job in presenting the facts in support of the claim that Betti, through counsel, told Kaiser that Betti would go anywhere in Northern California.2 Nonetheless, there is evidence that the statement was made to Kaiser and which the court overlooked. If Betti told Kaiser that she would relocate anywhere in Northern California, then whether Kaiser had an Counsel's statements at oral argument are not evidence because counsel was not under oath. 9 2 Case 2:03-cv-02678-RRB-DAD Document 60 Filed 02/15/2006 Page 10 of 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 obligation in the circumstances to share other openings with her or request more specificity becomes a factual issue. See Cir. Humphrey v. Mem'l Hosp. Ass'n, 239 F.3d 1128, 1137-38 (9th 2001) (finding that the ADA imposes a continuing duty to engage in an interactive process with a disabled employee to attempt to identify and implement reasonable accommodations). Further, it is at the least unclear whether there were other openings for which Betti was qualified. In the order granting summary judgment, the court re-states Kaiser's argument that Kaiser did not have any open positions for Betti. Order at 5.) (7/25/2005 Kaiser argues that, based on this statement, the court found that there were no positions available in any location. (Opp'n at 5.) This is incorrect. The court granted summary judgment because Betti did not provide evidence that she had communicated her willingness to work in other locations. (7/25/2005 Order at 11-12.) Finally, the evidence cited to support Kaiser's argument that Betti was not qualified for the Richmond position is not adequate to establish the point as an undisputed fact. In her declaration, Kemp states that no positions were available during the time Betti sought a transfer. However, this statement appears to refer to searches made in Sacramento, South Sacramento, Stockton, and Manteca. (Kemp. Supp. Decl. � 5.) Therefore, considering the evidence from Betti cited above, the court finds that there is an issue of material fact as to: (1) whether a position was available at another Northern California 10 Case 2:03-cv-02678-RRB-DAD Document 60 Filed 02/15/2006 Page 11 of 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 site for which Betti was qualified; and (2) whether Betti abused the interactive process by failing to clearly and timely inform Kaiser that she would move to other facilities. Kaiser will have an opportunity to depose Betti's attorney and the person she negotiated with at Kaiser. Following the depositions, Kasier may renew its motion for summary judgment if appropriate. B. Hostile Work Environment Claim Betti also argues that she has a hostile work environment claim under the ADA pending before the court. (Mot. at 14.) She asserts that Kaiser's accusations of "gross misconduct" and progressive disciplinary actions constitute harassment and discrimination independent from her claim for Kaiser's failure to accommodate. (Id.) The Ninth Circuit has not held that a hostile work 16 environment claim is actionable under the ADA. 17 of Tucson, 336 F.3d 1181, 1190 (9th Cir. 2003) (noting that 18 "[o]ur court has not yet held that such a claim 19 exists, let alone what its source in the statute might be. We 20 decline to do so here"). 21 "assum[es] without deciding that a claim for claim for harassment 22 or hostile work environment is cognizable under the ADA." 23 Baumgart v. State of Washington, 1999 WL 535795, at *1 (9th Cir. 24 1999). 25 hostile work environment claim under the ADA. 26 In the FAC, Betti makes a number of references to a hostile 11 Baumgart does not establish that a plaintiff may bring a See The case cited by Betti simply See Brown v. City Case 2:03-cv-02678-RRB-DAD Document 60 Filed 02/15/2006 Page 12 of 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 work environment. (FAC �� 14, 22, 27, 39.) However, she does not make out a specific claim of hostile work environment under the ADA. In addition, she did not raise this claim in her The court opposition to Kaiser's motion for summary judgment. will not allow Betti to assert this claim for the first time on a motion for reconsideration. Therefore, the court DENIES Betti's request to amend her complaint to include a cause of action for hostile work environment under the ADA. C. Amendment to Complaint to Change Defendant Betti argues that the court should grant her leave to amend her complaint to change the name of the defendant from KFHP, Inc. to The Permanente Medical Group, Inc. ("TPMG"). (Mot. at 16.) In granting the motion for summary judgment, the court found that Betti sued Kasier Permanante, an entity that does not actually exist. (7/25/2005 Order at 12.) The court declined Betti's request to amend her complaint to name TPMG because the amendment would be futile. (Id. at 13, n.4.) However, the court based its decision on the fact that, as a matter of law, Betti was not denied a reasonable accommodation. (Id.) Because the court has granted reconsideration of that issue, Betti's amendment to the complaint is no longer futile. Therefore, the court GRANTS Betti's request to amend her complaint to name TPMG. III. For the reasons stated above, the court: (1) GRANTS Betti's 25 motion for reconsideration; (2) DENIES Betti's request to amend 26 her complaint to include a claim for hostile work environment 12 Case 2:03-cv-02678-RRB-DAD Document 60 Filed 02/15/2006 Page 13 of 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 under the ADA; and (3) GRANTS Betti's request to amend her complaint to name TPMG. IT IS SO ORDERED. Dated: 2/14/2006 DAVID F. LEVI United States District Judge 13