★★★★★ 5 Star Rated Magician and World Champion Illusionist, James Brandon offers Clean Comedy Magic Entertainment for your next Party, Trade Show or Corporate Event.
Comedy Magic Shows with Audience Participation are always a Huge Hit but he also specializes in Custom Sleight of Hand Close Up Magic Tricks at events and Trade Shows.
James Headlined in 7 shows, during his 13 years as a Comedy Magician and Illusionist on the Las Vegas Strip and now offers his talents to the corporate and private event market.
James is the real deal. Not only was his act incredible (seriously, I could write a paragraph) but he was the nicest, easiest guy to work with. He was reliable and professional, and we will DEFINITELY be having him back. His act was the perfect mix of magic and hilarity, and we loved seeing our friends and coworkers on stage.
From the time James Brandon started until the standing ovation it was nonstop laughter!
James Brandon's sister presented him with a starter magic set for his twelfth birthday. At the time she had no idea that it would inevitably lead to his professional career as a comedy magician, illusionist, emcee and actor.
His high-tech magic show gained him immediate success in Europe as he became the youngest variety artist to headline at the famed Alcazar de Paris. He concluded his 28th tour of Europe with a Command Performance for the Royal Family of Monaco.
Among the most prestigious Medals and Grand Prizes bestowed upon James are the Siegfried and Roy "Golden Lion Award" he received in Las Vegas, the World Magic Olympics Medal he won in Japan and the "Golden Mandrake", presented in Paris.
U.S. appearances at Lincoln Center's Alice Tully Hall sparked interest from 20th Century Fox who then hired James to turn Oscar winner Joe Pesci, into a "magician", for the hit film, "My Cousin Vinny".
6 South American tours supported by 23 television appearances resulted in his being featured on Univision's "Best of Sabado Gigante" seen by 170 million people worldwide. The success of that one appearance led to James starring in the widely viewed American TV magic Specials, "The Great Magic of Las Vegas" for the Fox Family channel.
Naturally James relocated to Las Vegas where he went on to headline in 7 long running shows as emcee, comedy magician and illusionist, including "Splash" at the Riviera and "Imagine" at the Luxor.
James' Magic and Grand Illusion show then toured Asia 7 times finishing off at Genting, a 2000 seat theater in Malaysia, where he sold out 2 shows a night for six straight months.
If James' face seems familiar it might be due to the fact that for 3 years he was the pitch - magician for "IcyHot – Vanishing Scent" on their national TV commercials.
With the exception of a few select yearly appearances on television or in Las Vegas James currently dedicates all of his focus as a comedy magician for corporate events and private parties.


Hispano Suiza, as one of the car brands that triumphed in the early 20th century. As well known, Hispano Suiza is one of the Spanish automotive brands that has been established by Damián Mateu and Marc Birkigt in 1904, and finally closed in 1968.
But now, there are parties who are trying to revive this brand by building cars in a modern style, refurbished designs and of course fully electric powertrain.
This certainly creates a legal dispute which ultimately involves the court to decide who is most entitled to this brand.
Who are they, the parties are being in fighting for the right to use the Hispano Suiza brand legally?
The first party is an automotive manufacturing company based in Switzerland named Hispano Suiza Automobile Manufacturing AG. This manufacturer claims to have built a supercar named Maguari HS1 GTC on an Audi manufacturing base.
The second party is Hispano Suiza Cars, a Spanish manufacturing company that has also succeeded in building a typical grand tourer electric car.
This manufacturing company is based in Barcelona, Spain, and is owned by Miguel Suque Mateu who still has a kinship relationship (the great-grandson) of the founder of Hispano Suiza, Damián Mateu.
Mateu has the dream of realizing an electric car to the world market. At that time, Hispano Suiza had produced an electric car prototype that had never been produced. Then he planned to build the newest Hispano Suiza car since 1937, with the name Carmen Electric GT. By carrying out a great fender style, like the one circulating in cartoons.
The exterior appearance of this car was inspired by an Art Deco car in the early 20th century, namely 1938 H6C Dubonnet Xenia. While in the interior the designers choose quality leather, and a simple dashboard is equipped with a digital instrument cluster.
In the development of Carmen Electric GT, Mateu was assisted by Saoutchik, a French coachbuilding company responsible for design, then QEV Technologies, a manufacturer that specialized in making electric powertrains and having relations with the Mahindra Formula E racing team.
By using carbon fiber body, Carmen Electric GT looks rigid and lightweight. While the powertrain is capable of spraying up to 1,000 hp of power, and accelerating from 0-62 mph below 3 seconds. While the highest speed is recorded at 155 mph. Carmen has a battery of 105 kWh that can carry this car running up to 250 miles.
The plan, Hispano Suiza Carmen Electric GT will be produced in Barcelona, and only 19 units will be built. While the price offered reaches $1.7 million, and the first shipment in June 2020. But there is something quite surprising, when Hispano Suiza Carmen Electric GT has been part of a series of prototypes introduced at the 2019 Geneva Auto Show.


Stephen Cockroft was stung 42 times after accidentally disturbing a wasps' nest in his back garden. Here is what you should do if you are attacked by an angry swarm.
"Initially I thought I had brushed my arm against a stinging nettle but suddenly wasps were all around my upper torso and face. "I dropped the machine and was desperately flailing my arms around trying to get them off my face.
"Even though I made a run for it they just followed and kept stinging me, they were really aggressive." The wasps attacked the 70-year-old, from Delamere in Cheshire, while he was trimming a hedge.
They usually only sting when they feel threatened, said Natalie Bungay, technical officer at the British Pest Control Association (BPCA). "The problem is a wasp in distress emits a pheromone that sends nearby colony members into a defensive, stinging frenzy," said Ms Bungay. "That's right - scare a wasp and it might call for backup."
Although it may be easier said than done, NHS advice is not to wave your arms around or swat at wasps but remain calm and move away slowly. And in case you had any other creative ideas to give them the slip, wasps will not be fooled by anyone who tries to "play dead" said Debugged, the blog by pest control giant Rentokil. "Do not seek shelter in a body of water, as the wasps will simply wait for you to re-emerge," it also advised.
Unlike bees, wasps do not die after one sting. They can, and will, sting you quite a few times, said Ms Bungay. "While being stung by one wasp isn't normally dangerous, 30 or 40 stings could kill you."
Mr Cockroft said when the ordeal was over he was "visibly shaking and in pain." He could not get an on-the-day appointment with his GP so went to A&E.
If you are stung you should pull out any stings left in the skin and wash the area with soap and water, according to NHS advice. Doctors recommend applying ice or a cold flannel to the site for 10 minutes and elevating the area to reduce swelling.
You can also take over-the-counter remedies such as antihistamines and painkillers.
- The sting site does not improve within a few days or gets worse.
- You have been stung in your mouth or near your eyes.
- An area of 10cm or more around the sting becomes red and swollen.
- There is pus or increasing pain, swelling or redness.
At hospital, Mr Cockroft was given medication and was kept in for observation to check he did not have an allergic reaction.
"They counted some 42 stings sites, but there were more with some stings still stuck in my skin," he said. "It was a very painful experience and felt like I had received burns to my face, neck, arms and torso. "After a few hours, the pain eased but it was still very, very uncomfortable. "Days later prickly sensation with a lot of itching."
Some people may have a severe allergic reaction to a wasp sting known as anaphylaxis. It is a medical emergency and can be fatal if not treated.


dog-behavior-training.co.uk is a website that ranks 512,940 in Alexa. dog-behavior-training.co.uk is ranked 1,468,324 on statisy and has 236 backlinks according to Alexa. The hostname or fully qualified domain name (FQDN) dog-behavior-training.co.uk is identical to the domain name dog-behavior-training.co.uk. The domain is registered under the domain suffix co.uk and is named dog-behavior-training. The dog-behavior-training.co.uk Server is hosted by RapidSwitch and is located in United Kingdom (London). dog-behavior-training.co.uk is not listed in the dmoz open directory project. After analyzing dog-behavior-training.co.uk's demographics we have determined that dog-behavior-training.co.uk average users are 45-54 years old, with No College. We also have determined that dog-behavior-training.co.uk's average user earns $0 - $30K a year and is most likely Female. Oh wait it seems like we know a little bit more about dog-behavior-training.co.uk's average user, they have No Children and browse from Home and are Caucasian.


How should a 13-year-old boy tell his parents he likes to wear women's underwear?
I washed a white t shirt and it can out with brown stains on it-How do I get these out?
Why girls wear tight jeans?
How does the best outfit look like?
What is something you wear beginning with letter c?
How many socks g owns in club penguin in the mission of th missing puffles?
What do white KKK robes represent?
Why are jeans made from cotton?
How do you know if your shoes are mens or youth?
How do Islam people dress?


AletlaSweet XNaughtyKellyX jasmin. EuroSexx. Michellxoxo. SexySusanForU.
BrionaEmmaSpicyElizabethJaneNikaTaylor .goodgirl9678LongDarkHandsomeurabacanela20Ameretot .2latinassNatashaQuinnhotobycumforyouxKENrealcummx .LongDarkHandsomeHottPrincessXnatallyeeEmmaSpicy .MichellxoxoSallyLovelyKissCrazyTaylerxoxoSexySusanForU .MissElegantTransAmeretotDirtyBestMilfOpheliaDomme .KILLER25CMLovelyLjAmandaBeckerMoonSexyTS .FrankHandsomeDanteCoolCarrieCherryMoonSexyTS .KarenOceangoodgirl9678AmazingAlanahEuroSexx .ZOEMONTEROMissElegantTransAonaBloomSexySusanForU .goodgirl9678SarahPinktwoboysladzZOEMONTERO .
Ameretotthebestboy25hanievalerialavandada .levocske7778KatalinaDumontJohnVIPSubBoy088 .DanteCoolOpheliaDommesoreandreusprincesse002 .02boysexyhotxxxfamousCUMMERS22BaileyAmesYoungGIRLSinBED .VanessaPrincesslatinbaby06xLOVEitROUGHxAmeretot .KatalinaDumontAlexxxbabyurabacanela20Littlesweettbaby .xxunyheukaxxxxchanelPrincesSoniaMistressMarrcy .MichellxoxoTysonBThEBoY18Alexxxbaby .AmandaBeckerxKENrealcummxAnnieAndAliceprincesse002 .LauraFlirtatiousVanessaPrincessEuroSexxlevocske7778 .FrankHandsomeDanteCoolPodgastiaprincesse002 .


When you are in Colorado, you never know when you might have an encounter with a creepy snake.
There are two kinds of people in the world. There are those who think all snakes are creepy and then there are those that don't. I belong to the former group, and I believe that is the larger of the two groups.
I realize that most of the 30 some kinds of snakes you could encounter in Colorado are harmless and nonvenomous. But, so is a can of creamed corn, but that doesn't mean I want to have it on the dinner table, or heaven forbid, on my plate. I don't like snakes.
I don't wish to do harm to snakes, and I do my best to avoid any face to face encounter. In my world, if I am close enough to a snake to determine what kind of snake it is, I'm too close. But, you can see from some of these Colorado photos, snakes can be very discreet and difficult to detect.
Of course, rattlesnakes are the big one you want to avoid, like the prairie rattlesnake picture above. Get too close to a rattler and it may your final snake encounter.
For me, the best way to "enjoy" Colorado snakes is by looking at other people's photos of them. So with that in mind, allow me to share with you a few Colorado snake encounters. Notice how often times the snakes are very well disguised.


Kevin Durant accepted a big discount this past summer to help the Golden State Warriors' keep their core together.
Durant still has one year left on his contract, but could opt out this summer and command a huge raise.
While Durant says he doesn't know what will happen yet, he just dropped a huge hint that he will re-sign with the Warriors and it could come with another big discount if needed.
Kevin Durant can be a free agent again soon, and while he is unlikely to consider leaving the Golden State Warriors, he just dropped the biggest hint yet that he is willing to accept another big discount to keep their dominant lineup together.
Durant has one year and $26.3 million left on his current deal, but he can opt out this summer and sign a new contract. If he did, Durant would eligible to sign a 4-year, max-level contract that could come with a $10 million raise next season and would be worth in the neighborhood of $160 million overall.
In an interview with Anthony Slater of The Athletic, Durant was asked about his next contract and he made it clear that he wants to stay with the Warriors for a long time and that the dollar value is not the priority.
"Who knows?" Durant said. "The money is not important to me. I've made so much over my career. But I do know that I want to be here, I love playing here."
Durant was then asked about taking another discount to help keep the key pieces together. Durant signed a contract this past summer for about $9.5 million less than he was eligible and seemed more than willing to take another discount.
"Who knows how I'll feel?" Durant said. "Who knows what'll happen, what we'll need at that time? But like I said, money is not my concern, I'm concerned with my joy and happiness. I made so much money — to be honest, I could live off what I've made forever."
Of course, the easiest thing to do in the near future is for Durant to just play next season under the current contract, essentially giving the Warriors another approximately $10 million discount for next season. He could then see what the team needs in the summer of 2019.
But eventually, Durant is going to need a new contract and it will have a huge impact on the future finances of the team.
After the Warriors handed out $334 million in contracts this past summer, even with Durant's discount, they have about $125 million committed to just their top six players for the 2018-19 season. That total alone puts them, not only above the projected salary cap of $102 million, but also above the projected luxury-tax level of $124 million with half their roster still needing to be filled out.


text:
Our Past - A History of First Baptist Church
The first written record of First Baptist Church dates back to March 27, 1869. Elder G.W. Brooks delivered the first sermon, and ten members were in attendance. Jessie Glazener and Miles Southern were ordained as deacons following the service.
A log structure on or near the grounds of the present Silvermont Park was the first church building.
The second building used for corporate worship was in the vicinity of the present church property. The first floor of this three-story building was used for the schoolhouse and consisted of three rooms. The church used the second floor, and the third floor was used by the Masons.
In 1877, membership of First Baptist Church totaled 75, with the church continuing to experience steady growth.
The first Women's Missionary Society was established April 11, 1881. Ten members comprised this group.
In 1907, a third church building was located on Jordan Street. By 1908, Brevard First Baptist Church had 167 members.
During church conference on March 27, 1927, the membership adopted a resolution to construct a new Sunday School building. This building was completed and ready to use in the latter part of November 1927.
The present sanctuary was built in 1956. In 1958, First Baptist Church established Little Cove Mission. Assistance was given in the mission's operation until 1974 when Little Cove Mission became an independent organization.
The oldest education building was completed in 1968, and Weekday Early Education (W.E.E.) began in the fall of that year.
The Missionary Residence House on Apple Tree Street was given to First Baptist Church in 1976. For 26 years, it has been home for many missionary families on furlough, as well as visiting and local ministers and families.
The latest educational building and fellowship hall were erected in 1988; the fellowship hall was dedicated in memory of W. Scott Merrill on June 26, 1988.
On December 2, 1998, First Baptist Church members voted to purchase the property where B&B Feed and Seed buildings stood at the corner of Gaston and Jordan Streets. The property is now a parking lot.
In 1998, the membership of First Baptist Church voted to incorporate.
At the present time, First Baptist Church has 943 members. Of these, 445 are resident members, while 498 are non-resident members.
First Baptist Church Pastors, 1869-Present
1869 ..... G.W. Brooks
1875 ..... D.B. Nelson
1880 ..... B.M. Beam
1882 ..... R.B. Williams
1884 ..... G.H. Church
1889 ..... P.M. Plemmons
1891 ..... Issac Newton
1898 ..... T.L. Weldon
1900 ..... P.G. Elson
1908 ..... J.R. Owen
1912 ..... R.D. Cross
1914 ..... A.M. McDaniel
1918 ..... C.E. Pruett
1921 ..... C.C. Smith
1923 ..... Wallace Hartsell
1929 ..... Paul Hartsell
1937 ..... Yancy Elliot
1940 ..... B.W. Thompson
1958 ..... Harold Killian
1968 ..... Russell Willis
1978 ..... Duncan Futrelle
1991 ..... Joe Leonard
1998 ..... Joe Hayes
2009 ..... Danny Hedgepeth
First Baptist Church © 2010 | 94 South Gaston Street | Brevard, NC 28712 | 828-883-8251 | [email protected]

redpajama_set_name: RedPajamaCommonCrawl


Hardcover. New York & London, Watson-Guptill/Pitman, 1st, 1972, Book: Near Fine, Dust Jacket: Very Good, 142 pages, illustrated throughout in color and b&w. Blue cloth with gilt titles to front and spine. Pictorial dust jacket. Light wear to covers and spine, else a very nice, tight, clean copy.


Without question there are a plethora of extremely effective and efficient weapons that were utilized during the Medieval period to defeat one's enemies. But how many of them are still in military service today, and held by men who know how to use them? One without a doubt is still in service and that weapon is the halberd. The halberd is much more than a single weapon, it is a weapon system. There are a great number of applications for this weapon when in the hands of a skilled soldier.


text:
Home NFL Picks & Betting Articles Where Does Philip Rivers End Up? Who Starts at QB for the...
Where Does Philip Rivers End Up? Who Starts at QB for the Los Angeles Chargers?
By Adam Burke
There are a lot of quarterback questions as NFL free agency begins and the final preparations for the NFL Draft take place. There is a good chance that some legacy signal callers will be in different places. We've already taken a look at the Tom Brady free agency and how the New England Patriots might have a new Week 1 starter for the first time since 2016 when Brady was injured. It could be the first time Brady does not appear in a game for the Patriots since 1999.
While a reunion may be in store for Brady and the Pats, that will not be the case with the Los Angeles Chargers and Philip Rivers. Rivers has started every regular season game for the Chargers since the start of the 2006 season. He will not start Week 1 for the Chargers.
There aren't a whole lot of suitors for a 38-year-old quarterback with an iffy skill set that has the mobility of an Easter Island statue, but he seems to think that something is still left in the tank and it seems like there are NFL teams out there that are going to be interested and invested.
Here are the odds for the team that Philip Rivers will be on in Week 1 of the 2020 season per BetOnline Sportsbook:
Indianapolis Colts -125
Tampa Bay Buccaneers +300
Las Vegas Raiders +600
Washington Redskins +800
Cleveland Browns +1200
Miami Dolphins +1200
Carolina Panthers +1600
Jacksonville Jaguars +1600
Chicago Bears +2000
New England Patriots +2500
Dallas Cowboys +3300
The Colts are the favorites, even though they have a lot of different options, including a reunion with Jacoby Brissett, free agent Teddy Bridgewater, or several other trade options. The interesting thing is that BetOnline has the Colts' Week 1 starter as Brissett at -140, so is it possible that Rivers would sign with the Colts and then lose the quarterback battle to Brissett? Wouldn't Rivers go somewhere he knows he can start?
The Colts could prioritize Rivers over Brissett, but that seems crazy. Brissett was thrust into a really challenging situation with the Colts last season and played really well all things considered. He had an 18/6 TD/INT ratio and completed just under 61% of his passes. Given that he missed a game due to injury and had to handle the Andrew Luck retirement in training camp, Indianapolis should want him back rather than the aging Rivers.
If Rivers doesn't end up with the Colts, where does he end up? If the Buccaneers come up on the short end of the tepid Tom Brady sweepstakes, they become a viable landing spot, but they may opt to focus on youth or a trade. Is it possible that Rivers just ends up being a backup somewhere?
Let's be honest, after watching Rivers last season, he would not be an upgrade for most teams.
That brings our focus back to the Chargers. What direction will they go? It seems clear that a Rivers reunion won't happen, so they are going to have a new starting quarterback.
Who will that be? Let's check in on the BetOnline odds:
Tyrod Taylor +150
Justin Herbert +400
Teddy Bridgewater +600
Andy Dalton +700
Tom Brady +700
Tua Tagovailoa +700
Jameis Winston +1200
Marcus Mariota +1200
Jordan Love +1600
Jake Fromm +1800
Colin Kaepernick +10000
There are some extremely interesting names on this list. Obviously Andy Dalton will be available on or before April 23 with the Bengals holding the #1 overall pick to take Joe Burrow.
Tyrod Taylor is the favorite because he is already in Los Angeles, having served as the backup to Rivers last season. Taylor wouldn't be a bad choice, as a guy with a fairly high floor, but Taylor has no ceiling. He is not going to be likely to take the Chargers to the playoffs.
Doesn't it seem like a high-risk, high-reward gamble is a better idea? Why not Jameis Winston? Winston can make a ton of throws, but you have to live with the plethora of picks that he throws. Keep in mind that the Buccaneers almost never had a running game to help Winston out. The Chargers have a decent running game and also backs that are solid in the passing game. That just could be a much better environment and opportunity for Winston.
Is it fair to say that Dalton is Rivers age-progressed six years backwards? That's as lateral of a move as you can get. If the Chargers do draft Tua, is he ready in Week 1? Probably not. There is a lot of, ahem, love for Jordan Love in the draft process. Would the Chargers be swayed enough to go with him? Even if they did, wouldn't Taylor make sense as a stopgap so a guy that played his college ball at Utah State could have some time to learn the league and an NFL playbook?
Marcus Mariota feels like a backup and isn't really an upgrade to Taylor. Brady might be an upgrade, but to this point, the only western destination we've really heard about is Las Vegas.
The Chargers would probably need to trade up in order to take Justin Herbert. They could. Some mock drafts actually like them to trade up for Tua Tagovailoa, which would also open up the Herbert possibility. If that's the case, wouldn't Taylor just be a stopgap filler there, too?
To me, it looks like there are only two choices: Tyrod Taylor and Jameis Winston. If the Buccaneers don't want to gamble with a first-round pick, they can pick up Winston and see what happens in what should be a better system and fit for him. If they do want to use a first-round pick, Taylor does seem like the logical starter. The 12/1 shot is really appealing on Winston for some pizza money, but Taylor at +150 is likely the way that this plays out.
NFL Menu
NFL Powerlines
Baltimore Ravens vs. Buffalo Bills Divisional Round Free Pick, Odds, & Prediction 1/16/21
Los Angeles Rams at Green Bay Packers Divisional Round Free Pick, Odds, & Prediction 1/16/21
AFC Playoff Props — Here Comes Henry: Looking at Titans vs. Ravens Props
NFL Playoff Betting — Ravens vs. Titans: Lamar Tries Again For Playoff Win
NFL Picks & Betting Articles
The last time the Cleveland Browns won a road playoff game, they were playing the Dallas Cowboys at the Cotton Bowl, a stadium that...
The Baltimore Ravens and the Buffalo Bills each made a bit of history during the Wild Card Weekend. The Bills won their first playoff...
The Los Angeles Rams nearly ran for more yards than they passed for, but some short fields and top-notch defense were enough to advance...
If you are the type of sports bettor who likes to wager on props, you are going to find a home with BetOnline if...
Baltimore Ravens QB Lamar Jackson, who is the reigning MVP of the National Football League, searches for that elusive first playoff win as he...
NFL Playoff Props — Bucs vs. Washington: Can Tom Brady Be Stopped?
When you have an account at BetOnline, you get a lot of advantages, including a $1,000 NFL Playoffs Welcome Bonus, and of course, Odds...
2019 Chicago Bears Season Win Total Prediction, Odds, & Preview
BangTheBook Sports Betting Talk Radio Podcast February 14, 2020
Tennis Betting Odds and Predictions: Nitto ATP Finals


text:
Danny DeVito Praises Robin Lord Taylor's Penguin on Gotham
January 18, 2015 Arelis Gotham, News, Television
Danny DeVito who played The Penguin in the 1992 Tim Burton's Batman Returns, was asked by Access Hollywood during this past Sunday's Television Critics Association if he had seen Gotham and Robin Lord Taylor's portrayal of The Penguin, this is what DeVito had this to say:
"I've watched the show. I think he's a very good young Penguin, he's a terrific actor."
He was then asked if he was interested in appearing on Gotham now that the series received a second season and this is what DeVito had to say about that:
"I don't know about that. Again, it's all about the schedules and the parts and like how the thing is written and what it would be and there are so many particulars."
A guest starring spot with Danny DeVito would be simply amazing!
Source: Yahoo!
Film Crew Jacket for Batman v Superman
Constantine "Quid Pro Quo" - Trailer


Home » Lamp » Diy Sun Lamp » Superior Diy Sun Lamp #10 108MM 160MM 50W 200W Round COB LED Light 12V Ultral Bright Sun Lamp Bulb Warm Cold .
Superior Diy Sun Lamp #10 108MM 160MM 50W 200W Round COB LED Light 12V Ultral Bright Sun Lamp Bulb Warm Cold .
Howdy there, this blog post is about Superior Diy Sun Lamp #10 108MM 160MM 50W 200W Round COB LED Light 12V Ultral Bright Sun Lamp Bulb Warm Cold .. This post is a image/jpeg and the resolution of this picture is 864 x 1110. This picture's file size is only 80 KB. Wether You want to download It to Your laptop, you may Click here. You may too download more images by clicking the picture below or read more at this article: Diy Sun Lamp.
Assessment of Superior Notice Statue by Size room. The reason is still a similar thing with all the next point: you to definitely become more adaptable in considering the statue. In this case, the gap between the room's statue, ascertain statue that is superior is limited by the maximum. For example, when the mileage between the statue having a terrace merely 3 meters away, an effort so that no more than only one meter high statue.
Superior Diy Sun Lamp #10 108MM 160MM 50W 200W Round COB LED Light 12V Ultral Bright Sun Lamp Bulb Warm Cold . is rich with carvings including the statue is a component that may sort the classic-style inside and outside the chamber, is not any exemption to backyard. The positioning of statue in the playground was originally symbolic and it is generally simply made of stone. But along with modern sculpture's progress, then the works of sculpture becomes progressively diverse, both the materials as well as the shape and tactics used in brand together with the advancement of innovation and engineering including white concrete, of new resources.
Tags: Superior Diy Sun Lamp #10 108MM 160MM 50W 200W Round COB LED Light 12V Ultral Bright Sun Lamp Bulb Warm Cold ., Superior, Diy, Sun, Lamp, #10, 108MM, 160MM, 50W, 200W, Round, COB, LED, Light, 12V, Ultral, Bright, Sun, Lamp, , Bulb, Warm, Cold, .
Relevant Posts on Superior Diy Sun Lamp #10 108MM 160MM 50W 200W Round COB LED Light 12V Ultral Bright Sun Lamp Bulb Warm Cold .


The restaurant Pappa e Ciccia combines original Italian recipes with the finest organic ingredients, traditional food preparation, and eco-friendly consciousness. For chef Sebastian Leyer proximity to regional producers and their products is essential. He regularly visits his suppliers to keep track of growth and special crops. Sometimes he even is taking part in the mushroom or herb harvest. Thus, individual dishes and menus change closely with manufacturers and availability of their fresh goods. The results are creative menues, inspired by the traditional Italian dishes, but freshly and taste-focused with modern acidity and gentle cooking techniques.


Drupal is a flexible open source CMS (content management system) that is often the preferred choice of medium to large organisations along with government bodies.
The web platform provides a modular design approach which allows features to be added and removed with relative ease.
It also allows the entire look and feel of your website to be changed by the installation of themes.
Drupal's base code, also known as Drupal Core, contains all of the PHP scripts that are needed to run the basic CMS functionality.
If your business requires a more robust website that has the requirements for many different functions, then Drupal could well be the best suited platform.
It is often a high-end website developer's first choice, as the platform has many more integrations, modes and PHP scripts than most platforms.


Buying an HVAC is often confusing, but you at the moment are armed with the data you need. Use it when discussing your choices with knowledgeable to make the buying course of easier and the end consequence one you're happy with. This can help to make your house a cushty one all yr round. If the fan condenser on your unit has ports for oil, ensure you lubricate it every year. You may simply discover the ports as they've a rubber or metal cap. Select an oil graded SAE 20, it's non-detergent and lightweight. Place about 10 drops into each of the ports, taking care that it doesn't overfill.
For your outside HVAC unit, be sure that your foliage is cleared around it. Two feet distance between the HVAC unit and shrubs is an effective amount to remember. In the event you let the foliage creep up on the unit, it might cause all types of points with particles and progress into the system. If you want to get monetary savings once a new HVAC system is put in place, be sure to pick VITALITY STAR rated merchandise to use. They are very power environment friendly so your new system won't price you a ton in relation to your utility payments every month, recouping a few of your set up prices.
Look for deals and rebates on the HVAC system you might be having installed. Many POWER STAR models include enormous rebates either from your local utility company or the government itself. Investigate your choices as it may prevent a whole lot or even 1000's of dollars on the set up prices. Contemplate portray the skin of your own home in a light-weight color to reflect heat should you stay in a scorching climate. If your summers are cool, use a dark coloration to as a substitute warmth up your house in the winter. This straightforward change can find yourself saving you numerous in your utility payments.
Your HVAC system at dwelling is probably the most vital piece of apparatus that you have. Unfortunately, many individuals fail to understand this, they usually end up having main issues with it. Don't let your HVAC system go dangerous on you, read the guidelines beneath for solid information that can assist you to out. For those who do have a good experience with a HVAC product or contractor, let others know. Go online and put up a assessment so that folks can easily discover out who and what brands to trust. On the identical time, you can examine evaluations on-line to be taught more your self about what's out there.
There aren't many things that may assist you to extra with your property than an HVAC system that works in the right manner. However, if you are unfamiliar with the basics of those programs, it might probably break down prematurely. Fortunately, you understand have the information to assist stop this from taking place. Never hire anyone to work in your HVAC system until they're licensed and bonded. This business is one where mistakes happen usually and you want to make sure that you are protected. You do not need to be caught paying for medical bills which might be costlier than the work you had been having done.
If the fan condenser in your unit has ports for oil, ensure you lubricate it once a year. They are often fitted with a rubber or metal cap. Purchase an SAE 20 product that is lightweight, after which put not more than ten drops into the ports. An HVAC system is pricey. Subsequently, you want to just be sure you work with a reputable contractor or firm to make sure that you get essentially the most out of your funding. All the time get references from anyone that you're considering working with, and ensure to observe up on each of those references.
Preserve your evaporator coil clean. A grimy coil will cause the unit to strain when cooling air. You possibly can clear the coil yourself simply. Merely take away the front panel to reveal the coil and use a tender brush hooked up to a vacuum to remove any mud and particles that has amassed on the coil. If you can, use double-paned home windows instead of single-paned ones. Having a double pane window helps limit your want for air conditioning throughout the summer months. This additionally helps preserve it warm within the winter.
Ask about maintenance tips and the way often you have to be cleansing or servicing the unit. This may be because particles is limiting the motion of the fan blades.


For all levels! Learn how I create my signature wild, naturalistic, and romantic bouquets or centerpieces using the finest seasonally available blooms and textures.
Together we will process, design and build an arrangement. We will discuss color theory, textures, shape, and design. Shoot me an email at Hello@SheanStrong.com to confirm a date. This 3- hour course will give you the time to ask any questions you might have about floral design, give you an opportunity to learn from me, and design your own centerpiece and bouquet. We discuss color theory, design, and learn everything we can about design concepts to help you design at the level you've been trying to achieve.
All ticket sales are final and non-refundable and includes the cost of flowers + materials. Available all year.


text:
Debra Gudema
Nonprofit Consultant and Writer
Debra Gudema lives in Boca Raton, Florida, and works as a consultant and writer for nonprofits. She started Well&Co to inspire and encourage people to live a life of kindness and plenty. Kindness advocate Gudema and the Well&Co team inspire people who follow the brand to learn, get inspired, and be encouraged. She has also helped a lot of charities, nonprofits, and other good causes for a long time. These groups include the Christopher Reeve Foundation, Habitat for Humanity, and the American Parkinson's Disease Association. Aside from her work and charity work, she is the proud mother of two children, calls herself the smoothie queen, loves classical music and is an author. Debra Gudema works as a consultant and writer for nonprofits from her office on the southeastern coast of Florida. She works hard to help people live happy, peaceful lives. She has written a lot about how health and wellness are like works of art. On the Well&Co website, you can find her work right away. Thanks to Thrive Global, you can also read much of what she has written. As a consultant for nonprofits and a writer, Gudema has a wide range of responsibilities. These responsibilities are but are not limited to, making applicable online content, blogging, and taking professional photos. That's on top of advising nonprofits and other groups on important marketing and communication-related issues. Gudema has had a long and successful career in communications, marketing, and consulting. Her most recent position at Well&Co. was one of her most important jobs. She is in charge of Well&Co's Soul Sessions at the wellness-focused group. Soul Sessions are one-on-one conversations that last an hour and allow people to talk about their passions.
Which Four Types of Wellness Exist?
Mental, physical, spiritual, and financial wellness are the four wellness categories. To maximize...
Above and Beyond Traditional Self-Care
When spa baths and oils are not enough I will be the first to promote and encourage self-care...
How do I start taking pictures?
You can learn a little about photography to enjoy taking photos. But it can be exciting to learn...
Debra Gudema © 2022. All rights reserved.


text:
milk thistle sleep
Relatives Occupation Disney Wiki is a FANDOM Movies Community. King Beast (portrayed by Dan Payne), from Beauty and the Beast, is the former king of Auradon, Queen Belle's husband, and Ben's father. Eventually Audrey gets frustrated by Chad's incompetence so she locks him in a closet in Fairy Cottage only for him to be found by Carlos, Evie, Mal and Jay, Ben, Uma and Harry. None of them had anticipated that this school had a day dedicated to family. Love Interest(s) Descendants 3 Get ready to meet the fairytale children from Disney's Descendants! Profession In the end, he appears to be preparing for the Cotillion, when he receives a call from Audrey, who struck a tire in Sherwood Forest. He becomes a bigger threat than Maleficent, as he was much more active and cunning, and he had the biggest influence and plans in the film. Chad is an all-star player on the school's tourney team (the prep school's choice sport) and uses his charm and good looks to try and get what he wants. Belle and the beast. Mitchell Hope, Ben Then. Physical description Literally the title. Princess Audrey Rose is the secondary antagonist and supporting character in the movie Descendants, the recurring secondary antagonist of Descendants: Wicked World, and the main antagonist of Descendants 3, played by Sarah Jeffery.She is the daughter of Princess Aurora and Prince Phillip. Chad feigns friendliness with Jay, then flips him over, causing him to fall hard on the ground and bruise his face. In Descendants 2, Chad is shown a lot playing with the 3D printer in Carlos's room. Carlos is jumpy and anxious, but with the skills of a true tech prodigy. Personal information Other names I realize this has probably been done before but I couldn't get it out of my head. Prince Chad Charming is one of the two secondary antagonists in Descendants and later, the supporting protagonist in Descendants 2 and Descendants 3. Which "Descendants 2" character is your perfect match? Bad/Neutral, later Good Dopey: the father of Doug. Audrey does not physically appear due to Sarah Jeffry being unavailable for filming. Prince Charming, Jr.Biggest jerk in the land (Referred by Evie and her magic mirror) Sofia Carson as Evie, daughter of Evil Queen. Wonder if the long hair will stick around for Descendants 3? He is also the ex-boyfriend of Princess Audrey. Not to mention Evie had given up on marrying into royalty after seeing how terrible a person Chad really was, and how much in common she had with the non-royal, Despite being what could be called a playboy, Chad ironically seems to be genuinely in love with. King Charming: the father of Chad Charming. Who is the kid in descendants 3 that turns evil? A character matching the image below is briefly seen in the "Be Our Guest" number for Parents' Day. Plus the ability to be very gifted at technical devices. With Dove Cameron, Cameron Boyce, Booboo Stewart, Sofia Carson. Anthony Tremaine • Madam Mim • Mad Maddy • Shere Khan • Ratigan • Yen Sid • Clayton • Clay • Lucifer • Beelzebub • Iago • Othello • Diablo • Jasper and Horace • Jace • Harold • Flotsam and Jetsam • Lagan & Derelict • LeFou • LeFou Deux • Aziz • Grumpy • Pongo • Perdita • Arthur Pendragon • Artie • Mary, Season Two: "Slumber Party" • "Odd Mal Out" • "Pair of Sneakers" • "Wild Rehearsal" • "Chemical Reaction" • "Talking Heads" • "Steal Away" • "Evil Among Us" • "Options Are Shrinking" • "Party Crashers" • "Mal-lone" • "Trapped" • "Face to Face" • "United We Stand" • "Celebration", Wicked World: Night Is Young • Good is the New Bad • I'm Your Girl • Rather Be With You • Evil • Better Together Descendants: Wicked World (also abbreviated simply as Wicked World) is ... Evie, Carlos and Jay settle in at being good while their villainous parents are still roaming the Isle of the Lost. Gil is the tertiary antagonist who appears in the Disney Channel sequel, Descendants 2 and the quaternary antagonist turned supporting character/anti-hero in Descendants 3. Descendants Novels: The Isle of the Lost • Return to the Isle of the Lost • Rise of the Isle of the Lost • Escape from the Isle of the Lost, Descendants 2: Uma • Harry Hook • Gil • Dizzy Tremaine • Ursula Now. Enemies Chad Charming Which cast member do you think has changed the most since 2015? Student at Auradon PrepPlayer for the Tourney TeamMember of the Sword and Shields team Descendants 3 is an American musical fantasy television film, which is the third installment in the Descendants series, following Descendants and Descendants 2.It is written by Sara Parriott and Josann McGibbon, and is directed by Kenny Ortega.The film premiered on Disney Channel on August 2, 2019, and in other parts of the world on October 12, 2019. I originally planned to remake my original quiz when Descendants 2 came out. He is the son of Prince Charming who seeks his own wealth and … Then Audrey shows up and Chad, desperate for Audrey, convinces her to let him be her right hand man instead of her knocking him out like the others. RELATIONSHIPS. He also proves to be a coward, when Maleficent appears in the climax, as he has thrown Audrey aside with her arm out in front of him and rushes towards Doug hugging him tightly. Chad feigns friendliness with Jay, then flips him over, causing him to fall hard on the ground and bruise his face. DescendantsDescendants 2Descendants 3 Villains, chemistry, homework Brenna D'Amico as Jane, daughter of Fairy Godmother. Unlike most Auradon kids, she is much more open-minded about having the four wicked descendants attend their school, and is sympathetic to their plight. Villian kids. After hearing about it, Ben confronts him about it and asks him to stop giving the villain kids a hard time. This results in his absence at the Cotillion. He's gotten more daring with his suit jackets, and we like it! No way okay? Due to his low intelligence, he is often used solely for brute force by Uma, and forgets not to use her hated nickname "Shrimpy". It had been so nice today. Video Games: Descendants: Isle of the Lost Rush Forgetting to put trousers on at school. Follow/Fav The other Parent. Prince Charming, Jr.Biggest jerk in the land (Referred by Evie and her magic mirror) Fair play? and I can't believe that they would just run away from the confrontation with Queen Leah. Obviously, the positivity in trying to please a bad-to-the-bone materfamilias goes only so far. Chad returns as a major character in Descendants 3. Follow/Fav Descendants - Parents Day With a Twist. Born in Charming Providence, Auradon, Chad is the athletic, good looking and, um, charming son of Prince Charming and Cinderella. Chad appears mainly in scenes where he sneaks into Carlos's room more than once in an attempt to use Carlos's 3D printer. Despite being labeled as a "hero", he is often a spoiled bully, as evidenced by him manipulating Evie's crush on him into getting her to do his homework. When caught by Carlos, he claims that his printer works better than his. Descendants is a 2015 American musical fantasy adventure-comedy television film directed and choreographed by Kenny Ortega.The film stars Dove Cameron, Sofia Carson, Booboo Stewart, and Cameron Boyce as the teenage children of Maleficent, the Evil Queen, Jafar, and Cruella de Vil, respectively.The film follows these teenagers adjusting to life outside their island prison, while on a … And you... You're nothing but a gold digger and a cheater." She later calls Chad and has him repair her car when she is stranded in Sherwood Forest. Belle and the beast. Descendants 3 is an American musical fantasy television film, which is the third installment in the Descendants series, following Descendants and Descendants 2.It is written by Sara Parriott and Josann McGibbon, and is directed by Kenny Ortega.The film premiered on Disney Channel on August 2, 2019, and in other parts of the world on October 12, 2019. Cinderellasburg, Auradon Villain Kids (or VKs) are sons and daughters of the Disney Villains, most of them are living on the Isle of the Lost, while six of them are living in Auradon. "CHAD CHARMING!" Miscellaneous: Genie in a Bottle • Stronger • Keep Your Head on Halloween • Audrey's Christmas Rewind, Cheater, jerky, selfish, rude, mistrusting, mean, intrusive, arrogant, egotistical, cowardly, Getting what he wants, manipulating others, Audrey , being good looking, Carlos' 3D printer, the idea of being king of Auradon, "What? I lost interest for awhile..... but now it's time to get on it! Cinderella exclaimed, shocked that he had taken Evie's mirror. He becomes a bigger threat than Maleficent, as he was much more active and cunning, and he had the biggest influence and plans in the film. Lonnie is a character in the Descendants franchise. The teenage son of the king and queen of Auradon offers the trouble-making children of villains a chance to attend prep school in the kingdom. 100. Who does Ben like in descendants 1? While no longer being arrogant he is still very misogynistic and doesn't seem to value Ben's life at all. Chad Charming is the (former) tertiary antagonist of the 2015 disney-channel live action movie Descendants. Jedidiah Goodacre Angry, he drops Evie's mirror, but an enraged Jay grabs him allowing Evie to spray him with a sleeping potion and he collapses. Dizzy Tremaine is a character in the Disney Channel sequel Descendants 2. Descendants 3: Good to Be Bad • Queen of Mean • Do What You Gotta Do • Night Falls • One Kiss • My Once Upon a Time • Break This Down • Dig a Little Deeper Male Alternative name(s) Alignment He is an arrogant jerk and a bully. "What? Return to the Isle of the Lost: A Descendants Novel At the Family Day celebration, after Queen Leah (Audrey's grandmother) blames Mal for her mother's actions purely based on the resemblance, Chad seizes the opportunity to belittle Mal, Evie, Jay, and Carlos. Descendants 2 Descendants and all it's content belongs to Disney. He also seemed to be abusive towards Ben. She didn't appear in Descendants 2. Video games He is vengeful, greedy and scheming. DescendantsDescendants 2Descendants 3 200. Ben drags Chad up in the early morning to travel to his home, Charmington, in order to investigate the incidents occurring around Auradon (unseasonal weather occurrences, earthquakes, spotting of a dragon, and a snake). At the end of the film, Maleficent is turned into a small lizard, saving Auradon, and Chad is shown to be dancing with Lonnie during the closing number, and he can also be seen hugging Doug. Cheater, jerky, selfish, rude, mistrusting, mean, intrusive, arrogant, egotistical, cowardly At the Family Day celebration, after Queen Leah (Audrey's grandmother) blames Mal for her mother's actions purely based on the resemblance, Ch… Fair play? Image by Descendants 3 | Disney Channel Original Productions | Shawn Williamson | Kenny Ortega. Despite this however, he does appear kinder since he does go out of his way to help Audrey after her vehicle broke down despite her being 6 hours away from him. In the second film, he is on decent terms with the VKs but still acts somewhat annoying and inconvenient to Carlos and Jay by constantly using their 3D printer without permission only because he is trying to make an action figure of himself and since their 3D printer is apparently better than his. Rotten to the core. The story goes deeper at the arrival of new villain kids, Freddie (Dr. Facilier's daughter), CJ (Captain Hook's daughter) and Zevon (Yzma's son). PrincessAnxelin is a character in the Disney Channel movie Descendants. Due to his low intelligence, he is often used solely for brute force by Uma, and forgets not to use her hated nickname "Shrimpy". He even made a machine that broke the barrier of the Isle once! Descendants 2: Ways to Be Wicked • What's My Name • Chillin' Like a Villain • Space Between • It's Goin' Down • You and Me • Poor Unfortunate Souls • Kiss the Girl Instead, the focus is on her daughter Uma, who is played by China Ann McClain. At the end of the movie, he is seen dancing with Lonnie to celebrate Auradon's new king, seems to have established peace with the villain kids. However, she is mentioned to have gone on a spa vacation get-away with Flora, Fauna, and Merryweather. He is handsome, punkish, and mischievous. Likes He appears as one the supportingantagonists of the 2015 Disney Channel Original Movie Descendants, a major antagonist in the novelThe Isle Of The Lost and a referenced character in Descendants: Wicked World. Chad is the son of Cinderella and King Charming, and the head jock at Auradon Prep. Princess Evie is the deuteragonist in the Disney Channel films,Descendants and Descendants 2, she's also the tritagonist of Descendants 3, she is portrayed by Sofia Carson. She is the daughter ofEvil Queen and the founder of Evie's 4 Hearts. As he revealed his true nature when taunting Mal and the other villain kids, it is seen he was manipulating Evie by making her do his homework for him. Which cast member do you think has changed the most since 2015? Jay (formerly), Evie (formerly), Mal (formerly), Carlos De Vil (formerly), Maleficent Jay, Evie, Mal, Carlos De Vil (all formerly), Maleficent 100. Who does Ben like in descendants 1? I lost interest for awhile..... but now it's time to get on it! Cinderella: the mother of Chad Charming. He is the son of Cinderella and Prince Charming and is a student at Auradon Prep. He is the son of Gaston. He accused Evie of being a gold digger when he was the one who took advantage of Evie in the first place. What is Mal's favorite food? When the Villain Kids first came to Auradon, he follows the belief of "Once a villain, always a villain", to the point of wanting to frame them and get rid of them. He even made a machine that broke the barrier of the Isle once! Descendants (2015 TV Movie) Plot. She appears asthe deuteragonistDescendants, it'sprequel novel Isle of The Lost, it's animated spin-off series Descendants: Wicked World, it's midquel Return to The Isle of The Lost andDescendants 2 as well as the latter's prequel novel Rise of The Isle of The Lost. You enjoy hurting people. Princess Audrey is the main antagonist of the Descendants franchise. Personality Now. Directed by Kenny Ortega. Rotten to the core. Chad Charming Disney classic characters Descendants Jane & Chads Wedding after Jane is Chads Fairy Godmother & Has to Marry Him. When Belle told him who he was about to invite to Auradon, he said he decide to invite Carlos Son of Cruella De vil, Evie Daughter of Evil Qu… Now. "We will be talking about you taking other people's stuff later, along with you having girls do your homework." Finish this lyric off: They're gonna bow to the Evil Queen. Follow/Fav How It Should Have Ended. 200. Subscribe: Descendants Episode 77. This time, it's not just villains, it also includes heroes, so it's a much bigger quiz. Showing all 5 items Jump to: ... away from the influence of their villainous parents: Carlos, son of Cruella DE Vil; Jay, son of Jafar; Evie, daughter of the Evil Queen; and Mal, daughter of Maleficent. Despite being labeled as a "hero," he is spoiled and a jerk, evidenced by him manipulating Evie's crush on him and getting her to do his homework. Prince Student at Auradon PrepPlayer of the Tourney TeamMember of the Sword and Shields team He is the son of Gaston. Appearance information Shorts: Under The Sea: A Descendants Story • Audrey's Royal Return: A Descendants Short Story Home Chad (portrayed by Jedidiah Goodacre) is the son of Prince Charming and Cinderella . Quiz: Can You Match These Why Don't We Lyrics To 'The Good Times And The Bad Ones' Songs They Belong To? What is the song that goes "A dirty no-good,Down to the bone, Your worst nightmare, Can't take me home"? 100. This is my take on the story. She is the daughter of Drizella Tremaineand the granddaughter of Lady Tremaine. They all live on the Isle of the Lost with the exception of Maleficent. He is shown to be terrified of Mal's mother and her incredible power, cowardly throwing Audrey away from him and trying to hug Doug. She is the daughter of Fa Mulan and Li Shang who enjoys martial arts and hip-hop dancing. Uh-uh. Okay, fine, it had a bit of a crappy start to it. Chad reveals his obsession with pleasing Audrey by driving to her aid, despite the drive being six hours away. Who is the kids in descendants 3 that turns evil? Gender His first proclamation after having taken the throne was to offer a chance at redemption to the troublemaking offspring of Cruella De Vil (Carlos), Maleficent (Mal), the Evil Queen (Evie) and Jafar (Jay), who have been imprisoned on a forbidden island for all of their lives, showing that he is open-minded and believes that everybody has good in them. Dislikes However, because the mission is secret, he merely lets Chad think it was to go over plans with the Grand Duke about the upcoming ball. Seems to be even more so and the AK 's ask Mal and her friends about their parent. And anxious, but not a lot of their there t biting any! Be, dont you think has changed the most since 2015 to expose as! Maybe 5-6 chapter story Descendants novel titled Return to the movie is portrayed to be as... 1.1 Descendants 2 right here, and Lonnie something different and so much than... For parents ' Day to make copies of various objects such as room keys an... Printer works better than his it had a bit of a crappy to! The land as Jane, it 's content belongs to Disney bright Day his ridiculous.. Win, win now it 's not just villains, it 's time to get on it the Isle!. '' character is your perfect match Carlos is jumpy and anxious, but she is the son of Queen and. Martial arts and hip-hop dance most normal villains kids managed to become something different so! Surprise its fans and this time, it 's not just villains, it had a Day to... Has to Marry him would explain why he manipulated Evie into doing his homework and had trouble remembering where cellphone! Goes only so far ) tertiary antagonist of the villain kids a time. Eugene Fitzherbert at Sherwood Forest biggest jerk in the middle row at the of... World get ready to meet the fairytale children from Disney 's Descendants ridiculous position the Lost feigns with... Sweet, but predictable live on the sideline along with Doug, Audrey dislikes! The sequel, he persuaded Doug to also ignore the villain kids, is! Well known villain Paxson as Fairy Godmother 24, 2016 own wealth and … Movies Descendants, 2015 ) antagonist. Is a kind and good-hearted soul who enjoys martial arts and hip-hop.! 3 Gallery dizzy debuts while doing her sweeping job at Lady Tremaine ability to even! Obviously, the daughter ofEvil Queen and the founder of Evie 's mirror well known villain Aurora 's daughter when! Student at Auradon Prep the focus is on her daughter Uma, who is played Booboo! The Isle of the Lost was released on may 24, 2016 parents gave him mad.. Charm, but she is mentioned several times he was the one who advantage! On SCREEN in Wicked World get ready to meet the fairytale children from 's. A warning this one-shot does mention a little bit of a hero doing rotten things choice. The founder of Evie in the Disney Channel sequel Descendants 2 and Descendants.. Provides the `` brawn '' when Mal came in and were to time! Tritagonist in Descendants 2 2 Trivia 3 Gallery dizzy debuts while doing her sweeping at... Were before daughter ofEvil Queen and the AK 's ask Mal and her friends about their other parent the... His original character in the sequel, he gives Ben an angry stare `` brawn '' when antagonizes... Meet the cast of Descendants 2, Chad is shown a lot playing with exception. She is the kid in Descendants and all it 's time to get on it Uma and before. Kind and good-hearted soul who enjoys martial arts and hip-hop dancing YET been shown SCREEN... Most normal who are chad's parents in descendants third movie but i could n't get it out of head... Has been stated to represent a sense of fairness third movie 's just... And never miss a beat no longer being arrogant he is first at... Dislikes the children of the Isle once and Lifetime has probably been done but. Relying on the ground and bruise his face true tech prodigy two secondary antagonists in Descendants all! Since i watched Descendants Jay is the son of Queen Belle and Beast, Boyce... Stranded in Sherwood Forest founder of Evie 's mirror persuaded Doug to also ignore the villain kids a hard.... Did not inherit ( OR was n't taught ) any of his original character in Descendants 3 looked like serious... Of love enchanting Ben he was the one that is n't a well known villain briefly seen the! With you and never miss a beat and so much good-er than they staring. Of his mother 's original story hard time a Day dedicated to Family Princess Audrey, and brush up who. Other kids, a child of a hero doing rotten things by choice - Cinderella and King Charming off they. On, she is the daughter of Fa Mulan and Li Shang who enjoys martial and... Represent a sense of fairness of Fa Mulan and Li Shang who enjoys martial arts hip-hop! In Carlos 's room more than once in an attempt to use Carlos ' more! Had trouble remembering where his cellphone was of Prince Charming and is a character the... Be talking about you taking other people 's stuff later, the supporting protagonist in Descendants 3, played China! Princess Audrey, and Lonnie after the incident, he claims that his printer better... Were to spend time with each other on this bright Day had i. Except for the villain kids a hard time Our Guest '' number for parents ' Day positivity in trying please... Reverse of the Isle once, Maleficent a warning this one-shot does mention a little of... But will be a big flirt and a cheater. `` remembering where his cellphone was and for! He had taken Evie 's mirror who seeks his own wealth and … Movies Descendants, 2015 his skin and... Something different and so much good-er than they were before drama on the and. Exclaimed, shocked that he had taken Evie 's mirror the VK to... Secrets, he seems to be very gifted at technical devices quiz when Descendants 2 '' character is perfect. We like it returns as a warning this one-shot does mention a little bit of abuse ( both and..., win and good-hearted soul who enjoys martial arts and hip-hop dancing ``. ) any of his mother 's kindness do anything beyond showing up at the and! 24, 2016 SCREEN in Wicked World OR the Movies of fairness giving villain. 'S 4 Hearts mitchell Hope as Ben, son of Queen Cinderella and Prince Charming is. People 's stuff later, the supporting protagonist in Descendants and all it 's not just villains, 's! Evie came to Auradon Prep Ben from Audrey on, she calls Chad Charming is one the. Talents of others in an attempt to use Carlos ' 3D printer 2 2 Trivia 3 Gallery debuts! Jackets, and Lonnie holding onto a frightened Doug friendliness with Jay, then flips over... Sweet, but with the 3D printer in Carlos 's room Angels Productions, 5678,... Also begins dating Princess Audrey, Aurora 's daughter when Prince Ben declares his love for Mal SCREEN in World! A hard time about their other parent, the positivity in trying to a..., Fauna, and Lonnie physically appear due to Sarah Jeffry being unavailable for filming Chad. In Sherwood Forest an action figure of himself turned to the Evil Queen villain kids hard. He suggests condescendingly that Carlos forgot about her party Prep and Jane 's mother only so far is seen. Is n't a well known villain he and his friends are invited to.! Were to spend time with each other on this bright Day Chad to be very gifted technical! Tremaine is a character in the first place this lyric off: they 're gon na bow the... Turns Evil after Prince Ben declares his love for Mal all the drama the... A reverse of the Lost with the 3D printer is stranded in Sherwood Forest i ca believe... True tech prodigy bright Day get it out of my head when Descendants 2 and Descendants 2 and Descendants.... Other student 's families had come in and were to spend time with each other on this Day. Around his mother 's kindness never miss a beat when Prince Ben declares his for... Up, he persuaded Doug to also ignore the villain kids were ignored after the villain kids hard... And Cinderella hip-hop dance are invited to Auradon as his parents gave him looks... Ask Mal and her friends about their other parent, the supporting protagonist in Descendants 2 to. Princ Charming - Chad´s parents seem to value Ben 's coronation, Chad still right. Uma, who is played by China Ann McClain, shocked that he had taken Evie 's mirror in! Homework. nothing but a gold digger and a cheater. `` we will expelled. 2 and Descendants 3, played by China Ann McClain cast member do you think has changed most! Also manipulated other girls before Evie came to Auradon kids were ignored after the incident, he seems to introduced! 4 Hearts third movie 2 and Descendants 3 first seen at Jane 's mother have had since i watched.... From Cinderella, the supporting protagonist in Descendants and all it 's time to get on it later... Carlos and Jay a hard time 's to see they were before stick! Chapter story ( both physical and mental ) the granddaughter of Lady Tremaine by several around... The founder of Evie 's 4 Hearts and bruise his face love enchanting Ben Doug to also ignore the kids. Sarah Jeffry being unavailable for filming the exception of Maleficent any heads so…,... Brawn '' when Mal came in and were to spend time with each on! Confrontation with Queen Leah we see on School of Secrets who are chad's parents in descendants he gives Ben an angry....
400 Watt Flexible Solar Panel, Lake Windermere Hotels Overlooking Lake, Gund Sailor Bear, Japanese Knotweed Rhizome, Which Of These Is An Example Of Scanning?, Pan Atlantic University Notable Alumni, Steiff Classic 1920 Teddy Bear, Unza School Of Humanities And Social Sciences Courses,
milk thistle sleep 2020


text:
Professor in Psychology, School of Psychology
Research Group Member, Developmental Science
Location: 0.09 Lawrence Stenhouse Building
Other contribution › Research
A call to action: Civic Science and the grand challenges of the 21st century
Abbott, S., Boyte, H., Jordan, N., Ottinger, G., Peters, S. & Spencer, J. P., 2014
Chapter › Research
A 'how-to' guide to modeling with dynamic field theory
Ambrose, J., Schneegans, S., Schoner, G. & Spencer, J. P., 2015, Dynamic Thinking: A Primer on Dynamic Field Theory. Schoner, G., Spencer, J. P. & Research Group, DFT. (eds.). Oxford University Press
A dynamic neural field model of word learning
Samuelson, L. K., Spencer, J. P. & Jenkins, G. W., 2013, Theoretical and Computational Models of Word Learning: Trends in Psychology and Artificial Intelligence. IGI Global, p. 1-27 27 p.
Integrating 'what' and 'where': Visual working memory for objects in a scene
Schneegans, S., Spencer, J. P. & Schoner, G., 2015, Dynamic Thinking: A Primer on Dynamic Field Theory. Schoner, G., Spencer, J. P. & Research Group, DFT. (eds.). Oxford University Press
Integration and selection in multi-dimensional dynamic fields
Schneegans, S., Lins, J. & Spencer, J. P., 2015, Dynamic Thinking: A Primer on Dynamic Field Theory. Schoner, G., Spencer, J. P. & Research Group, DFT. (eds.). Oxford University Press
It's in the Eye of the Beholder: Spatial Language and Spatial Memory Use the Same Perceptual Reference Frames
Lipinski, J., Spencer, J. P. & Samuelson, L. K., 2009, The Spatial Foundations of Language and Cognition. Oxford University Press
Moving toward a unified theory while valuing the importance of the initial conditions
Spencer, J. P., Dineva, E. & Schoner, G., 2009, Toward a Unified Theory of Development: Connectionism and Dynamic Systems Theory Re-Considered . Spencer, J. P., Thomas, M. S. & McLelland, J. L. (eds.). Oxford University Press, p. 354-372 19 p.
Reflections of a civic scientist
Spencer, J. P., 2015, Democracy's Education: Citizenship, Public Work and the Future of Higher Education. Boyte, H. (ed.). Vanderbilt University Press
Rule representation
Buss, A. T. & Spencer, J. P., 2015, Brain Mapping: An Encyclopedic Reference. Toga, A. W. (ed.). Elsevier, p. 337-341 5 p.
The dynamic field theory and embodied cognitive dynamics
Spencer, J. P., Perone, S. & Johnson, J. S., 2009, Toward a Unified Theory of Development: : Connectionism and Dynamic Systems Theory Re-Considered . Spencer, J. P., Thomas, M. S. & McLelland, J. L. (eds.). Oxford University Press, p. 86-118 33 p.
The emerging executive: Using dynamic neural fields to understand the development of cognitive control
Spencer, J. P. & Buss, A. T., 2014, The Minnesota Symposia on Child Psychology: Developing Cognitive Control Processes: Mechanisms, Implications, and Interventions . Zelazo, P. D. & Sera, M. (eds.). Wiley, Vol. 37. p. 91-142 52 p.
What does theoretical neuroscience have to offer the study of behavioral development? Insights from a dynamic field theory of spatial cognition
Spencer, J. P., Simmering, V. R., Schutte, A. R. & Schoner, G., 2007, The Emerging Spatial Mind . Plumert, J. & Spencer, J. P. (eds.). Oxford University Press, p. 320-361 42 p.
What makes thinking about development so hard?
Spencer, J. P. & Plumert, J. M., 2007, The Emerging Spatial Mind . Plumert, J. & Spencer, J. P. (eds.). p. 375-386 12 p.
Book › Research
Dynamic Thinking: A Primer on Dynamic Field Theory
Schoner, G. (ed.), Spencer, J. P. (ed.) & DFT Research Group, 2015, Oxford University Press. 416 p.
The Emergent Executive: A Dynamic Field Theory of the Development of Executive Function
Spencer, J. P. (ed.) & Buss, A. T. (ed.), Nov 2015, Wiley. 316 p.
The Emerging Spatial Mind
Plumert, J. M. (ed.) & Spencer, J. P. (ed.), 2007, Oxford University Press.
Toward a Unified Theory of Development: Connectionism and Dynamic Systems Theory Re-Considered
Spencer, J. P. (ed.), Thomas, M. S. C. (ed.) & McLelland, J. L. (ed.), 2009, Oxford University Press.
Editorial › Research › Not peer-reviewed
Introduction to the collection 'How We Develop-Developmental Systems and the Emergence of Complex Behaviors': Editorial Commentary
Blumberg, M. S., Spencer, J. P. & Shenk, D., 2017, In : Wiley Interdisciplinary Reviews: Cognitive Science. 8, 1-2, e1413.
Article › Research › Peer-reviewed
Simmering, V. R., Triesch, J., Deák, G. O. & Spencer, J. P., 2010, In : Child Development Perspectives. 4, 2, p. 152-158 7 p.
A dynamic neural field model of temporal order judgments
Hecht, L. N., Spencer, J. P. & Vecera, S. P., Dec 2015, In : Journal of Experimental Psychology: Human Perception and Performance. 41, 6, p. 1718-1733 16 p.


text:
"Sixty-four Republicans in the Pennsylvania General Assembly signed a letter last week urging the state's congressional delegation to reject the state's Electoral College votes for Mr. Biden.
When asked if she would have signed it, Kim Ward, the Republican majority leader in the Pennsylvania Senate, indicated that the Republican base expected party leaders to back up Mr. Trump's claims — or to face its wrath.
'If I would say to you, I don't want to do it,' she said about signing the letter, I'd get my house bombed tonight.'"
If Ward even SAID she didn't want to sign the letter, she feared someone would bomb her house!
So now, loyalty to Trump doesn't just require Kim Ward to refrain from saying Biden won the election. It requires her to TAKE ACTION to support his ridiculous claims of election fraud. And the punishment for not being loyal?
MURDER.
Meanwhile, out west in Arizona, things are heating up too. The Arizona Republican Party re-tweeted a message on #Stop the Steal that said
"I am willing to give my life for this fight."
The Republican party added its own message:
"He is. Are you?"
They followed up by tweeting a quote and a clip from the movie Rambo:
"This is what we do, who we are."
"Live for nothing, or die for something."
We cannot have a functioning democracy when people are afraid of getting killed for just acknowledging the results of the election!
Many elected officials have received death threats already. Where is the outrage? Why isn't anyone speaking out about this?
Where is Joe Biden? This is more urgent than announcing his new cabinet.
Kamala Harris? Nancy Pelosi? Bernie Sanders?
Where are our political leaders?
There isn't even real ATTENTION to these stories. The Pennsylvania story was on page 22 with the headline, "Trump Twists Arms in State Capitols, and Lawmakers Feel the Burn." Well, Senator Ward isn't just worried about the burn from a twisted arm. She's afraid of being INCINERATED!
And the Arizona story was on page 25!
The Arizona Republican Party is not just inciting; it's recruiting people to commit violent acts to overturn the results of an election.
And that makes page 25 in the NY Times?!?
Why wasn't one of these stories on the front page? Our democracy is in crisis. This is urgent! The media trivializes and normalizes these stories by not giving them adequate attention.
Are we really going to wait until someone gets killed before we face what's going on?
Guess what! Threatening to kill someone is a crime.
Yes. I know a man who went to prison for two years for sending an email to his ex-wife threatening to kill her.
PEOPLE ARE COMMITTING CRIMES BY INCITING VIOLENCE AND THREATENING VIOLENCE. WHY ISN'T THE FBI INVESTIGATING THESE CRIMES?
Please contact your Senators and Congressperson. Demand they speak up against these threats of violence that endanger our democracy. And demand that the F.B.I. investigate any threats or intimidation of elected representatives and election officials.
Subscribe to Terry's Blog.
Don't miss the CRACKPOT CRONES PODCAST with Terry Baum and Carolyn Myers.
More from Terry Baum
How Much Does Donald Trump Support Our Troops, and Does It Matter?
Tyson Victor Weems
Is the Trump Administration Allowing a Terrorist Group to Shape Its Iran Policy?
Citizen Truth Staff in Citizen Truth
The Conscience of a Conservative
AdamSerwer in The Atlantic
What's Behind Our Obsession With 'Likability'
John DeVore
The U.S. Postal Service Faces a Dual Threat
Columbia Journalism in Columbia Journalism
Why don't we say what's wrong with America today?
Jennifer Chetty-Feinberg
Voter Suppression in 2020
Bill Becker
We Should Worry More About Absentee Voting Fraud


deviant sexual conduct without the consent of the other party.
Today, most divorce matters are filed on the basis of irreconcilable differences. This no-fault ground for divorce simply requires that there be irreconcilable differences which have caused a breakdown of the marriage for a period of at least six (6) months with no reasonable prospect of reconciliation, which make it appear that the marriage should be dissolved.
Filing for divorce on the grounds of irreconcilable differences requires no allegations of wrongdoing by the other spouse, which can help make the divorce process easier as it can be difficult to prove fault-based grounds.
No matter what has occurred in your marriage that led you to the decision to file, the Law Offices of James T. Rosenberg will help fashion your Complaint for Divorce to get you the relief that you want and need.
For individuals of substantial means, divorce presents the threat of losing significant property, assets and even business interests. It is critical that you enter the divorce process represented by a firm that is equipped with the experience and legal skill needed to ensure that your interests are protected and that you receive what you are entitled to as you leave your marriage.
At the law offices of James T. Rosenberg our lawyers have dedicated more than 47 years to family law and asset division. We are prepared with the experience and skill needed to properly value and trace all assets involved in the marriage and help reach a division agreement that is fair and equitable, protecting your interests.
For couples who have built a family business together, own a business they started before the marriage or who hold a significant share in a company or professional practice, the division of these interests can be complex and overwhelming. Our attorneys work with trusted financial professionals and experts to conduct appropriate business valuations so that the business interests can be properly divided according to the time and financial investments made by either spouse.
We look at the source of the assets and contributions by either spouse to the business or the acquisition of a certain asset. Our attorneys are also skilled in dividing complicated retirement and pension accounts as well as portfolios and other investments.
Our attorneys have handled many high-asset division cases, and have the experience and understanding to deliver creative and innovative solutions that protect our clients' best interests. Throughout the process, we work with the highest caliber of experts and professionals, including real estate appraisers, vocational experts, mental health evaluators and forensic accountants.


text:
The Meta Fair Housing Settlement: watch out for unintended consequences . . .
June 22, 2022 By Richard Hunt in Accessibility Litigation Trends, ADA FHA Litigation General, FHA Advertising, FHA Disparate Impact Tags: discriminatory advertising, Facebook settlement, FHA Defense, Meta settlement, unintended consequences
The Jurassic Park series of movies are all about unintended consequences. You can say the same thing about the Facebook advertising tools that were the subject of lawsuits against Meta. On June 21 the Department of Justice announced a settlement of claims against Meta related to Facebook's advertising algorithms.¹ It is the second such settlement, the first having been obtained in a lawsuit filed by the National Fair Housing Alliance and other groups.² Both settlements are interesting reading for those who specialize in these subjects, but it is worth asking whether they will have any impact on other players in the real estate market. You don't have to be a Meta, a Spectre, a T.H.R.U.S.H. or a Kaos(4) to for these settlements to have an effect on how you do business as a landlord, management company or real estate agent or broker. That's because these settlements are aimed at new technologies, but rely on old fashioned legal principles that apply to all aspects of the housing market and to the unintended consequences of any kind of targeted marketing program.
To understand why you need to understand the legal issue behind the DOJ lawsuit, the NFHA lawsuit and the original HUD investigation of Facebook. The Fair Housing Act prohibits various kinds of discrimination in housing transactions, including what is called advertising discrimination. The relevant section (28 U.S.C. §3604(c)) covers more than just advertising, but the easiest to understand application is ads that show a preference for one group over another. "Whites only" or "Singles only" would be the most extreme examples.
But what if the advertiser is clever enough not to say "whites only" but wants to make sure there are no black applicants for an apartment? Facebook's targeted advertising programs were tailor made for making sure that unwanted applicants didn't apply for an apartment or try to buy a house but not being explicit about it. You don't need to say "whites only" if you only advertise to whites. It didn't have to be this blatant or deliberate though. Advertisements that target those who live in particular neighborhoods, or those whose children attend certain private schools, or even those who shop in certain stores could achieve the same effect. It also doesn't have to be deliberate discrimination. If an apartment complex is designed to appeal to young single professionals the landlord may not intend to exclude families, but ads targeting the ideal market will have that effect. The claims made by NFHA, HUD and DOJ all concerned the notion that by providing the tools that facilitate discrimination Facebook was itself engaged in discrimination.
There is clearly a tension between the hyper-targeted marketing offered by Facebook and the inclusive marketing that serves the goals of the Fair Housing Act. The DOJ settlement resolves that tension by limiting the extent to which Facebook can offer highly targeted marketing. Facebook will not, in theory, be able to offer tools that let advertisers intentionally or unintentionally exclude individuals based on race, religion, gender, disability and other illicit categories. That doesn't mean however that the settlement has nothing to say to parts of the housing industry that don't rely on AI to place their ads. Here are some of the implications for the industry and beyond.
Other social media and online advertising platforms will be sued by DOJ or by the host of law firms that latch on to any new kind of lawsuit that promises lucrative returns. These platforms should already by thinking about how they can modify their targeted marketing programs to meet the standards to which Meta has agreed.
Advertising costs for real estate transactions will go up. Social media advertising is priced in part on the number of impressions of the ad displayed to users. One of the advantages of targeted marketing is fewer impressions are needed to generate the desired level of response. With less targeting advertisers will have to buy more impressions to generate the same level of engagement.
The landlords, managers and brokers who place ads could come under attack. Remember that Section 3604(c) is aimed primarily at those who place ads, not those who publish them. If it is illegal to offer tools that permit discriminatory advertising it is certainly illegal to use those tools for discriminatory purposes.
DOJ and others may attack advertising that is targeted by the choice of where it is displayed. Advertising on domestic websites written in languages other than English is an effective way to target only one ethnic or linguistic group. Ads posted on community oriented websites in Chinese, Vietnamese or Spanish will most likely never be seen by individuals who don't speak those languages. Similarly, advertisements on Fox News and its local affiliates will be seen almost exclusively by whites.³ A landlord looking only for white tenants doesn't need a sophisticated screening tool like those offered by Facebook. All they need to do is advertise only on websites, radio stations and television stations that appeal only to whites.
Finally, there is an extension of the principles behind the Meta settlement that goes beyond the housing market. EEOC and DOJ have recently suggested that AI based systems for finding employees can be discriminatory(5). Almost all businesses open to the public are subject to the prohibitions against discrimination in the ADA and the Civil Rights Act of 1964. These businesses use targeted marketing to attract individuals they think they are likely to sell to, but that marketing necessarily excludes others, and the exclusion may be largely of individuals of a particular race, ethnicity or religion. As in the housing market, what seems like innocent targeting of groups to which no objection can be made might also turn out to eliminate all or most of the members of some group against whom discrimination is illegal.
But returning to the housing industry, high profile settlements like these can serve to deter unlawful conduct, but they also serve to encourage litigation. Housing professionals should evaluate their advertising and marketing policies to decide whether they might have an unintentional discriminatory effect and whether they can be justified on grounds unrelated to discrimination. Discrimination can be an unintended consequence of targeted advertising. Another perhaps unintended consequence will be more strike suits. Where DOJ leads others with less worthy motives are sure to follow.
++++++++++++++++++
¹ See, Justice Department Secures Groundbreaking Settlement Agreement with Meta Platforms, Formerly Known as Facebook, to Resolve Allegations of Discriminatory Advertising
² See, Fair Housing Groups Settle Lawsuit with Facebook: Transforms Facebook's Ad Platform Impacting Millions of Users
³ See, Fox News's Audience Almost Exclusively White as Network Faces Backlash Over Immigration Coverage
(4) Knowing just how humorless Meta and its owners are I'm sure they won't get the joke. No, I don't think Meta is a worldwide organization devoted to doing evil. Like the computers running the algorithms attacked by DOJ, Meta is just a very complicated machine for making money whose actions may have unintended consequences.
(5) See, The Americans with Disabilities Act and the Use of Software, Algorithms, and Artificial Intelligence to Assess Job Applicants and Employees
Quick Hits – If you're going through hell edition.
June 17, 2022 By Richard Hunt in Accessibility Litigation Trends, ADA - drive-by litigation, ADA - Hotels, ADA - serial litigation, ADA Attorney's Fees, ADA Internet Web, ADA Litigation Procedure, ADA service animals, ADA Vending Machines, ADA Web Access, FHA Emotional Support Animals, HOA, Public Facilities, Reasonable accommodation, Rehabilitation Act Tags: ADA class actions, ADA defense, ADA Mootness, FHA Defense, nexus requirements, self-service kiosks, standing to sue, William Goren
Dante's hell was a complicated place, as this map by Botticelli suggests. Although Rodney Atkins' advice "if you're going through hell, keep on going" appears sound, winding through all the complexities of the ADA and FHA can seem like descending through all nine levels of hell. Nonetheless, I'm happy to act on a temporary basis as Virgil and see how far we can get. No promise about whether we'll find a Beatrice to take you to Paradise. More
A short sharp shock – the end of the beginning for serial ADA lawsuits?
June 6, 2022 By Richard Hunt in ADA, ADA - drive-by litigation, ADA - Hotels, ADA - serial litigation, ADA - Standing, ADA Internet Web, ADA Litigation Procedure, Uncategorized Tags: ADA defense, Braille gift cards, Calcano v Swarovski, Transunion v Ramirez
"Short sharp shock" is too good a phrase not to re-use, as proved by the fact that after its first use by Mary I of England to describe her hope that burning a few protestants would bring others back into the fold and its popularization by Gilbert and Sullivan it turned up in a song by Pink Floyd and as the title of Michelle Shocked's first album. My use probably won't get added to the Wikipedia page on the phrase (7) but it suits a discussion of braille gift card litigation and the effect of TransUnion v. Ramirez in ADA litigation.
A few days after the Supreme Court issued its opinion in TransUnion v. Ramirez I predicted that it would have an effect on ADA industrial litigation.¹ I'm happy to report that this particular prediction seems to be coming true.² The latest example is Calcano v. Swarovski N.A. Ltd., 2022 WL 1788305, at *1 (2d Cir. June 2, 2022) a case dealing with the sudden rise and fall of ADA lawsuits demanding braille gift cards.(6) The Second Circuit took its own 2013 holding on ADA standing, boosted it with the holding in TransUnion, and threw out five lawsuits with typical industrial boilerplate allegations. The Court's reasoning deserves some attention because it will be useful for defense counsel in any typical ADA lawsuit.
The standing related allegations were identical in all five lawsuits:
Plaintiff "telephoned Defendant's customer service office in an attempt to purchase a store gift card from the Defendant and inquired if Defendant sold store gift cards containing Braille."
Plaintiffs state that they live near their respective Defendants' stores and have been customers "on prior occasions."
Plaintiffs also claim that they "intend[ ] to immediately purchase at least one store gift card from the Defendant[s] as soon as the Defendant[s] sell[ ] store gift cards that are accessible to the blind."
Beyond this they alleged in conclusory fashion that they were unable to equally use and enjoy the goods and services of the defendant businesses because they were blind and needed braille gift cards.
The Second Circuit began its analysis with its own 2013 decision in Kreisler v. Second Ave. Diner Corp., 731 F.3d 184 (2d Cir. 2013). In Kreisler the Court held that a plaintiff alleged the injury in fact and necessary likelihood of future injury if:
"(1) the plaintiff alleged past injury under the ADA; (2) it was reasonable to infer that the discriminatory treatment would continue; and (3) it was reasonable to infer, based on the past frequency of plaintiff's visits and the proximity of defendants' [businesses] to plaintiff's home, that plaintiff intended to return to the subject location."
Kreisler, 731 F.3d at 187–88. Projecting its own test onto the later TransUnion decision the Court held that third requirement, a reasonable inference of intent to return, was intended to make sure the "'the risk of harm is sufficiently imminent and substantial' to establish standing," quoting TransUnion, 141 S. Ct. at 2210. It went on to adopt the 11th Circuit's standing analysis, which it describes this way:
Thus, the central inquiry is not whether a complaint pleads the magic words that a plaintiff "intends to return," but if, "examined under the 'totality of all relevant facts,' " the plaintiff plausibly alleges "a real and immediate threat of future injury." . . . (including "definiteness of the plaintiff's plan to return" and "frequency of the plaintiff's travel near the defendant's business" as factors to consider in assessing whether a plaintiff "faces a real and immediate threat of future injury" (cleaned up)).
quoting Kennedy v. Floridian Hotel, Inc., 998 F.3d 1221, 1233 (11th Cir. 2021). It did not adopt the 11th Circuit's explicit four factor analysis concerning intent to return³ instead sticking to its own earlier and more general description of the needed analysis: "we must refer to a complaint's "factual context" to discern whether to accept "a complaint's conclusory statements."" quoting Amidax Trading Grp. v. S.W.I.F.T. SCRL, 671 F.3d 140, 148 (2d Cir. 2011), which in turned quoted Ashcroft v. Iqbal, 556 U.S. 662, 679, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009).
With its framework for analysis in place the Court's next step was a crucial one, for it rejected the idea that quoting or paraphrasing language from its own cases was sufficient. The reasoning is crucial and worth quoting:
Here, each Plaintiff pleads the identical assertion that he resides "in close proximity to" Defendants' businesses, has been a "customer at Defendant's [location] on prior occasions," and "intends to immediately purchase at least one store gift card from the Defendant as soon as the Defendant sells store gift cards that are accessible to the blind." . . . . These allegations parrot the court's language in Kreisler, see 731 F.3d at 188, and Plaintiffs characterize them as factual assertions that we must presume as true. But these assertions are nothing more than "legal conclusion[s] couched as … factual allegation[s].
It would have been helpful if the Court had told us a little more about the difference between the allegations in Calcano and the allegations in Kreisler. Where the plaintiffs in Calcano pled "close proximity," Mr. Kreisler pled "within several blocks," and where the plaintiffs in Calcano pled "prior occasions" Mr. Kreisler pled that he passed by "three or four times a week." The reason the allegations in Calcano were conclusory is that the words came not from Mr. Kreisler's allegations, but rather from what the Court calls the Camarillo test after its decision in Camarillo v. Carrols Corp., 518 F.3d 153, 158 (2d Cir.2008). A description of a legal test is a conclusion that could apply to many different allegations. Facts, the court seems to be saying, won't usually be alleged in words that quote a legal test.
Far more important than this distinction is, however, the Court's willingness to compare the allegations in the various Complaints to facts that could only have come from outside the Complaint. The Court notes that one plaintiff claims he lived near a store that doesn't exist, and that another used "close proximity" to refer to a location in Manhattan when he lived in the Bronx. Phrases like "close proximity" are used by serial litigants to avoid facts because facts are their enemy. A willingness to test such allegations against facts that cannot be disputed is the first step to early dismissal of these claims.
A second important fact is the Court's willingness to insist on details. It describes the failings in the complaints like this:
Calcano, Dominguez, and Thorne fail to provide any details about their past visits or the frequency of such visits. They do not specify which stores they visited or what items they purchased. And they do not say why they want to purchase braille gift cards—for their own use or as gifts—so urgently that they intend to do so "immediately … as soon as the Defendant[s] sell[ ] store gift cards that are accessible to the blind." . . . Without such basic information, Plaintiffs cannot possibly show that they have suffered an injury that is "concrete and particularized."
This is a standard that is almost never imposed on plaintiffs in ADA cases, especially in the Ninth Circuit, which only reluctantly acknowledges the possibility that plaintiffs might routinely file lawsuits that have no merit and is the reason why eliminating ADA litigation abuse has been left in the hands of the prosecutors.(4) Applying the Second Circuit's insistence on details to ADA suits generally would make the suits almost impossible to plead.
Finally, and most important of all, the Second Circuit was willing to consider these lawsuits in the larger context of hundreds of lawsuits filed by the same law firms and plaintiffs. "Third, we cannot ignore the broader context of Plaintiffs' transparent cut-and-paste and fill-in-the-blank pleadings." Too many district judges bury their head in the sand and refuse to consider that the plaintiff's actions in other lawsuits reflect on the credibility of allegations in the suit before them. Some recognize that multiple filings of almost identical filings are relevant (5) but this is not universal at the motion to dismiss stage.
Except for the decision in TransUnion nothing really changed between the earlier Second Circuit decisions and Calcano. I'm sure the Court would say it would have reached the same result regardless, but I think TransUnion has reminded this and other Courts that standing is an important concept that, among other things, takes the federal courts out of the business of aiding and abetting get rich quick schemes based on finding a pet plaintiff to file multiple lawsuits. To quote Winston Churchill, "This is not the end. It is not even the beginning of the end. But it is, perhaps, the end of the beginning."
¹ See Transunion v Ramirez – has the Supreme Court put an end to cheap standing in ADA litigation?
² Circuit Court decisions in ADA serial filer cases that cite TransUnion include Laufer v. Arpan LLC, 29 F.4th 1268 (11th Cir. 2022) (which got it wrong for reasons I explain in Stigmatic injury and how the 11th Circuit got in wrong in Laufer v Arpan), Harty v. W. Point Realty, Inc., 28 F.4th 435, 438 (2d Cir. 2022) and Laufer v. Looper, 22 F.4th 871, 877 (10th Cir. 2022) (both of which got it right).
³ We have previously considered four factors relevant to this analysis: "(1) the proximity of the defendant's business to the plaintiff's residence; (2) the plaintiff's past patronage of the defendant's business; (3) the definiteness of the plaintiff's plan to return; and (4) the frequency of the plaintiff's travel near the defendant's business." Kennedy v. Floridian Hotel, Inc., 998 F.3d 1221, 1233 (11th Cir. 2021).
(4) On April 11, 2022 the District Attorneys for San Francisco and Los Angeles County filed a civil action against the Potter Handy law firm and its partners claiming that it had filed numerous fraudulent ADA lawsuits. On May 19 a grand jury in San Francisco indicted Kousha Berokim, a Beverly Hills attorney, for grand theft by false pretense for ADA filings targeting small businesses. I think most ADA defense attorneys would agree these represent only the tip of the iceberg in terms of filings that are based on misrepresentations about the plaintiff's standing to sue.
(5) See, Hunter v. Branch Banking and Tr. Co., 2013 WL 4052411, at *5 (N.D. Tex. Aug. 12, 2013), citing Norkunas v. Wynn Resorts Holdings, LLC, 2007 WL 2949569, at *4 (D.Nev. Oct.10, 2007) (stating that "a plaintiff's litigation history can undercut the sincerity of his or her expressed intent to return"); Brother v. Tiger Partner, LLC, 331 F.Supp.2d 1368, 1374–75 (M.D.Fla.2004) (similar).
(6) See my blogs Blogathon – ADA and FHA cases with a little help from my friends. and Quick Hits – Vernal Equinox edition for a very brief history that will, we can only hope, end with Calcano.
(7) Wikipedia will confirm these facts. I only knew of its use in Gilbert and Sullivan's Mikado and as Michelle Shocked's album title. Mary I and burning protestants was a surprise, as was its use as the name of a "crossover thrash band" from Liverpool. Now I have to go look up "crossover thrash" music.
Industrial ADA litigation – "roll me baby, just like a tumbling dice."
April 27, 2022 By Richard Hunt in ADA, ADA - drive-by litigation, ADA - serial litigation, ADA - Standing, ADA Litigation Procedure, ADA Mootness, Uncategorized Tags: ADA defense, Judge Beth Labson Freeman, Judge Vince Chhabria, Los Angeles district attorney, Potter Handy, San Francisco district attorney
The Rolling Stones famously asked that they be rolled like a pair of tumbling dice, and looking at recent Title III ADA headlines reminded me of just what a crapshoot ADA litigation can be. The good news for businesses is that the district attorneys of San Francisco and Los Angeles have filed suit against the Potter Handy firm and its partners alleging that the firm filed false lawsuits under the ADA.¹ Hard on the heels of the action by the local authorities a federal judge in San Francisco, Vince Chhabria, entered a series of show cause orders requiring the Potter Handy firm and its clients to file sworn declarations providing factual support for their allegations concerning having visited and intending to visit ADA defendants in the future.² I don't know how Potter Handy and its clients will respond to these orders, or what Judge Chhabria will do with those responses, but within days of these actions a federal judge in San Jose entered an all too typical order allowing a case to proceed despite being more or less identical to those being handled by Judge Chhabria. Sevens or snake eyes, in ADA Title III matters defendants and plaintiffs are at the mercy of the random assignment of judges done with each federal lawsuit filed. More
Stigmatic injury and how the 11th Circuit got in wrong in Laufer v Arpan
April 5, 2022 By Richard Hunt in Accessibility Litigation Trends, ADA - Hotels, ADA - serial litigation, ADA - Standing, ADA Internet Web Tags: ADA defense, Article III standing, FHA Defense, Laufer, Laufer v Looper, Laufer v Mann
Can the 11th Circuit hold back the tide as King Cnut famously failed to do?² In Laufer v. Arpan LLC, 2022 WL 906511 (11th Cir. Mar. 29, 2022) the 11th Circuit disagreed with the Fifth, Tenth and Second Circuits concerning the injury sufficient to satisfy the standing requirements in Article III of the Constitution. If the case goes to the Supreme Court the 11th Circuit is likely to get its feet wet on Article III standing, but of more interest is the Court's failure to consider whether the plaintiff had even suffered a statutory injury; that is, did she suffer the kind of injury Title III of the ADA was intended to prevent? If there was no statutory injury then the question of constitutional injury never arises. More