text:
Summary Judgment: Taming the Beast of Burdens
American Journl of Trial Advocacy, Vol. 10, p. 433, 1987
U of Texas Law, Public Law Research Paper No. 309
45 Pages Posted: 3 Feb 2013
See all articles by Linda S. Mullenix
Linda S. Mullenix
The Supreme Court revisited the problem of the summary judgment procedure with a view toward clarifying burdens of proof and evidentiary standards. In three cases, Anderson v. Liberty Lobby, Inc., Celotex Corp. v. Catrett, and Matsushita Electric Industrial Corp. v. Zenith Radio Corp., the Supreme Court took the opportunity to instruct the lower federal courts concerning which parties carry what burdens of proof, according to what evidentiary standards. Unfortunately for summary judgment law, these cases contain three less-than-desirable effects. First, rather than illuminating a difficult aspect of civil procedure, the Court obscured summary judgment proceedings even more than before. Second, by viewing summary judgment through a traditional directed-verdict perspective, the Court arrived at indefinite conclusions concerning burdens and evidentiary standards. Third, the Court's pronouncements undercut the very purpose of the summary judgment procedure, thereby further hobbling the already limited utility of the rule. In essence, the Court transformed an intended summary procedure into the necessity for a full-blown trial-before-trial. For many litigators, this interpretation raises the ultimate question: why bother with making the motion?
This article focuses on one dimension of summary judgment law — the troublesome burdens of proof and evidentiary standards required by the rule. The hypothesis is quite simple: the problem of assigning burdens of proof and establishing evidentiary standards has been inappropriately refracted through the directed verdict lens. Courts traditionally reasoned backward from directed verdict to summary judgment. This mode of analysis compelled the conclusion that the burdens and standards attached to a directed verdict should govern summary adjudication. This conclusion is based on the premise, loosely articulated, that the purposes and effects of the motions are the same—that is, to remove a case from the fact-finder where there is only one factual outcome as a matter of law. The practical result of this analysis, however, allocates burdens of production and persuasion inappropriately at an early stage of litigation, and imposes higher evidentiary standards than necessary for summary procedure.
Thus, the Supreme Court and lower federal courts approach summary judgment analysis ineptly, rendering interpretations that undermine the rule's fundamental utility. Rather than reasoning backward from the directed verdict, summary judgment should be evaluated in relation to the demurrer, the motion that Federal Rule 12(b)(6) effectively replaced with the abolition of code pleading. When viewed from this perspective, different burdens and evidentiary standards for summary proceedings make sense. The purpose of the demurrer was to prevent insufficiently pleaded causes of action from proceeding to trial, whereas the directed verdict comes after the presentation of evidence at trial. The directed verdict, by nature, requires more stringent standards of evidentiary proof and different allocations of the burdens of production and persuasion. Summary adjudication at the pleadings stage was never intended to become a mini-trial, yet recent Supreme Court cases will have precisely this effect. Summary judgment procedure, therefore, needs to be salvaged from Supreme Court interpretation.
Part I of this article discusses the Supreme Court's interpretation of the federal summary judgment rule in relation to burdens of proof and evidentiary standards. This section reviews the Court's two most significant cases on these issues, First National Bank of Arizona v. Cities Service Co. and Adickes v. S. H. Kress & Co. These problematic, anomalous cases articulated broad principles of summary adjudication, without useful elaboration of rules relating to burdens and standards. Part II discusses the most recent Supreme Court cases — Anderson, Celotex, and Zenith — in which the Court analyzed the burdens and standards issues with more specificity. The argument is that the Court not only failed to clarify the summary judgment procedure in a meaningful fashion, but seriously undercut the rule's utility. Part III analyzes the traditional theoretical framework supporting summary judgment, and advocates a rethinking of the rule more relative to the old common law demurrer.
Summary judgment should be just what it is intended to be — a summary disposition of claims. The requirement of trial-like burdens and evidentiary standards transforms this motion into the trial itself, thereby defeating the very purpose of the rule. Federal summary judgment should assume this more practical and appropriate role in federal civil procedure: a demurrer-like procedure to dismiss insufficiently pleaded causes of action.
Keywords: Summary judgment, Rule 56, Celotex v. Catrett, Supreme Court, 1986 trilogy, Anderson v. Liberty Lobby, Federal Judicial Center
Mullenix, Linda S., Summary Judgment: Taming the Beast of Burdens (January 1, 1987). American Journl of Trial Advocacy, Vol. 10, p. 433, 1987; U of Texas Law, Public Law Research Paper No. 309. Available at SSRN: https://ssrn.com/abstract=2210533
Linda S. Mullenix (Contact Author)
University of Texas School of Law ( email )


. It may be worth contacting the event/award if you are a few days late to submit as sometimes they are prepared to be forgiving.
Applications must be submitted by 15th December each year. The Trustees meet early the following year and will inform the applicants of the outcome as soon as is possible.
The Trust was set up in 1991.
to whom applications should be sent.
The ICS Artist-in-residence program allows artists to work in the context of a different country and culture.
The Artist in Residence Programme provides artists with the space to create new works, experiment with innovative ideas and research new and different ways of making. Artists are encouraged to explore all our facilities to open up new possibilities and directions for the contemporary ceramicist.
The program is open to all artists who wish to work independently on their own projects. Artists may use the residency to accomplish a specific project or to work in a creative and supportive atmosphere alongside other international ceramic artists.
On average the are up to ten artists in residence at the ICS at any one time. There are plenty of opportunities to interact with the other artists but enough space to be quiet and reflective.
Making an application for the Artist in Residence Programme: There is no application deadline and applications will be considered throughout the year. We require slides, photographs or digital images on cd or by email, accompanyied by a current CV (Resumé) and biography. A brief outline of your intended work during your residency would be helpful for us to consider your application. Please give us an indication of your preferred dates for your residency.
Although applications for residencies are accepted throughout the year, we recommend you submit your application as early as possible as places are limited.
There are five different residency dates to choose from.
Full details and the online application form can be found by clicking the links below. The deadline for applications is 1st September 2017.
MAKE is Devon Guild's annual Christmas selling exhibition celebrating the diversity of contemporary craft. The exhibition focuses on selling handmade, high quality craftwork and connecting makers with our Christmas customers. By highlighting one-off, unique pieces alongside small scale batch production we aim to offer a range of mediums and prices to suit all. The exhibition is open to any UK-based craftsperson or designer-maker whose work fits these criteria. We are particularly looking for makers who produce exciting and contemporary work. The Christmas season is a key time for sales; during the run of MAKE 2017 over 16,000 people visited the exhibition, more than 14,000 visited online, and over £29,000 in sales were achieved.


text:
Agriculture Department 29 10
Air transportation 15 8
Aviation safety 16 9
Sulfur oxides 10 3
93 documents from 41 agencies
Establishing a White House Council on Eliminating Regulatory Barriers to Affordable Housing
Privacy Act of 1974; System of Records
A Notice by the Defense Department on 12/20/2004
Office of the Secretary
The changes will be effective on January 19, 2005, unless comments are received that would result in a contrary determination.
DPR 31
System name:
System location:
Categories of individuals covered by the system:
Categories of records in the system:
Authority for maintenance of the system:
Purpose(s):
Routine uses of records maintained in the system, including categories of users and the purposes of such uses:
Policies and practices for storing, retrieving, accessing, retaining, and disposing of records in the system:
Retrievability:
Safeguards:
Retention and disposal:
System manager(s) and address:
Notification procedure:
Record access procedures:
Contesting record procedures:
Record source categories:
Exemptions claimed for the system:
https://www.federalregister.gov/d/04-27701 https://www.federalregister.gov/d/04-27701
Office of the Secretary, DoD.
Notice to add a system of records.
The Office of the Secretary of Defense proposes to add a system of records to its inventory of record systems subject to the Privacy Act of 1974 (5 U.S.C. 552a), as amended.
Send comments to OSD Privacy Act Coordinator, Records Management Section, Washington Headquarters Services, 1155 Defense Pentagon, Washington, DC 20301-1155.
Ms. Juanita Irvin at (703) 601-4722, extension 110.
The Office of the Secretary of Defense notices for systems of records subject to the Privacy Act of 1974 (5 U.S.C. 552a), as amended, have been published in the Federal Register and are available from the address above.
The proposed systems reports, as required by 5 U.S.C. 552a(r) of the Privacy Act of 1974, as amended, were submitted on December 13, 2004, to the House Committee on Government Reforms, the Senate Committee on Governmental Affairs, and the Office of Management and Budget (OMB) pursuant to paragraph 4c of Appendix I to OMB Circular No. A-130, "Federal Agency Responsibilities for Maintaining Records About Individuals," dated February 8, 1996 (February 20, 1996, 61 FR 6427).
Dated: December 14, 2004.
Jeannette Owings-Ballard,
OSD Federal Register Liaison Officer, Department of Defense.
Personal Commercial Solicitation Evaluation.
Department of Defense, Military Community and Family Policy, ATTN: Morale, Welfare and Recreation Policy Office, 241 18th Street, Suite 302, Arlington, VA 22202-3424.
Active duty service members and solicitors.
Name of sales representative and company; appointment information; conduct of sale representative; active duty service member's name, home and work phone number, unit address and e-mail.
5 U.S.C. 301, Departmental Regulation; 15 U.S.C. 1601, Congressional findings and declaration of purpose; and DoD Directive 1344.7, Personal Commercial Solicitation on DoD Installations.
The information is used to document the active duty service member's experience with the sales representatives. Service member responses ensure sales representatives conduct themselves fairly and in accordance with DoD Directive 1344.7. Information may be used as part of a case file in the event proceedings are considered necessary to deny or withdraw permission for the sales representative and/or the company to solicit on one or more military installations.
In addition to those disclosures generally permitted under 5 U.S.C. 552a(b) of the Privacy Act, these records or information contained therein may specifically be disclosed outside the DoD as a routine use pursuant to 5 U.S.C. 552a(b)(3) as follows: The DoD "Blanket Routine Uses" set forth at the beginning of OSD's compilation of systems of records notices do not apply to this system.Start Printed Page 75937
Paper in file folders.
Records are retrieved by the active duty service members' name and unit.
Records are maintained in controlled areas accessible only to authorized personnel with a valid requirement and authorization to enter. Physical entry is restricted by use of combination numbered and cipher locks.
Permanent. Cut off and retire to the Washington National Records Center when superseded or obsolete.
Senior Program Analyst, Department of Defense, ATTN: Morale, Welfare and Recreation Policy Office, 241 18th Street, Suite 302, Arlington, VA 22202-3424.
Individuals seeking to determine whether information about themselves is contained in this system should address written inquiries to the Office of the Under Secretary of Defense (Military Community and Family Policy), ATTN: Morale, Welfare and Recreation Policy Directorate, 1745 Jefferson Davis Highway, Suite 302, Arlington, VA 22202-3424.
Requests should include the individual's name, phone number, and address.
Individual seeking access to information about themselves should address written requests to the Office of the Under Secretary of Defense (Military Community and Family Policy), ATTN: Morale, Welfare and Recreation Policy Directorate, 1745 Jefferson Davis Highway, Suite 302, Arlington, VA 22202-3424.
The OSD rules for accessing records, for contesting contents and appealing initial agency determinations are published in OSD Administrative Instruction 81; 32 CFR part 311; or may be obtained from the system manager.
Active duty service member.
[FR Doc. 04-27701 Filed 12-17-04; 8:45 am]
BILLING CODE 5001-06-M

redpajama_set_name: RedPajamaCommonCrawl


text:
Trump's Son Met Russian Lawyer After Promise of Damaging Information on Clinton
By Daniel Politi
July 09, 20178:59 PM
Donald Trump Jr. delivers a speech during a ceremony for the official opening of the Trump International Tower and Hotel on February 28, 2017 in Vancouver, Canada.
From one day to the next, Donald Trump Jr. is suddenly remembering a lot more details about a meeting he had with a Russian lawyer with close ties to the Kremlin mere weeks after his father clinched the Republican nomination for president.
The New York Times had already revealed the existence of the June 9, 2016 meeting on Saturday. But then on Sunday the paper went further and revealed the motivation for the meeting, which was also attended by then-campaign chairman Paul Manafort and the president's son-in-law Jared Kushner. It turns out President Donald Trump's eldest son only agreed to meet with the lawyer after she promised damaging information about Hillary Clinton and her campaign for the presidency.
In a statement, Trump Jr. failed to confirm that he was promised information that would be damaging to Clinton before he sat down with Natalia Veselnitskaya. Instead, he said he was asked to have the meeting by someone he knew from the 2013 Miss Universe pageant who claimed to have information that could be helpful to the campaign. It was when the meeting began and pleasantries were exchanged that the attorney told him that "she had information that individuals connected to Russia were funding the Democratic National Committee and supporting Ms. Clinton."
Yet the information was much a do about nothing. "Her statements were vague, ambiguous and made no sense. No details or supporting information was provided or even offered," Trump Jr. said. "It quickly became clear that she had no meaningful information." It was then that Veselnitskaya allegedly turned the conversation to the adoption of Russian children by U.S. citizens, which Moscow stopped as retaliation for a law that blacklists Russian officials tied to human rights abuses.
"It became clear to me that this was the true agenda all along and that the claims of potentially helpful information were a pretext for the meeting," Trump Jr said. "I interrupted and advised her that my father was not an elected official, but rather a private citizen, and that her comments and concerns were better addressed if and when he held public office." A day earlier, Trump Jr. had made no mention of Clinton, only saying that the meeting was mostly about adoptions of Russian children by U.S. citizens.
Saturday's statement by @DonaldJTrumpJr versus Sunday's statement by @DonaldJTrumpJr pic.twitter.com/piyGwjJRjr
— Brian Stelter (@brianstelter) July 9, 2017
President Trump was "not aware of and did not attend" the meeting, Mark Corallo, a spokesman for Trump's legal team, said.
The Washington Post talked to Rob Goldstone, a music publicist who is close to Trump Jr. and claims one of his Russian clients had requested that he arrange the meeting with Trump Jr., which he attended with Veselnitskaya. Although he wouldn't reveal who the client was, he did say that Veselnitskaya wanted to discuss adoptions. "Once she presented what she had to say, it was like, 'Can you keep an eye on it? Should [Trump] be in power, maybe that's conversation that he may have in the future?' " Goldstone said.
Goldstone works as a manager for Emin Agalarov, a Russian pop star who told Forbes earlier this year that he had an ongoing relationship with the Trump family even after the election. President Trump knows Agalarov—he even guest starred in his 2013 music video for "In Another Life."
3. President Trump knows Emin -- has appeared in one of his music videos. You can watch it here https://t.co/3KWdu63vvK
— Judd Legum (@JuddLegum) July 9, 2017


text:
Imelda Marcos's kiss for her husband as she celebrates 85th birthday: Disgraced former Philippines First Lady's solemn visit to body of Ferdinand
Former first lady visited mausoleum where her husband's body lays
Kissed his glass coffin and says her wish is for him to have a hero's burial
Celebrated her 85th birthday at a mass and visited her supporters
Blew out candles on a shoe-themed birthday cake and handed out cash
By Jennifer Newton
Published: 12:31 EST, 2 July 2014 | Updated: 04:47 EST, 3 July 2014
The former first lady of the Philippines Imelda Marcos celebrated her 85th birthday today by paying a solemn visit to the body of her husband.
Mrs Marcos visited the crypt of former president Ferdinand Marcos in Ilocos Norte in the north of the country and even kissed the glass coffin where his body lays in a white jacket, ceremonial sash and polished medals.
The former leader of the Philippines has remained unburied since his death in 1989 and has lay in a temperature-controlled mausoleum since 1993.
Scroll down for video
On a solemn visit to her husband's body, Imelda Marcos kisses his glass coffin as she marks her 85th birthday
Mrs Marcos said that her birthday wish was for her husband to be given a hero's burial. He has lay in this temperature-controlled crypt since 1993
During her birthday celebrations in Ilocos Norte province in the northern Philippines, she was crowned with flowers, which is a traditional birthday ritual
And Mrs Marcos remarked that her birthday wish would be for her husband to receive a hero's burial, however this has continually been rejected by the country's government.
As well as visiting the body of her husband, Mrs Marcos, who is now a Congress Representative in the Philippines, attended mass with her son, Ferdinand Jr who is a senator and her governor daughter Imee Marcos.
During the service she sang with a priest and was also presented with a crown made of flowers, which is a traditional birthday ritual.
The former first lady and current Congress Representative blows out the candle on her 85th birthday cake which has a shoe decoration on top
She also handed out cookies to supporters of her and her late husband with shoe decorations on them
Mrs Marcos poses for a photo with her son, senator Ferdinand Marcos Jr, during her birthday celebrations. She hinted he might stand for the presidency at the next election
She also attended a mass with her son, left as well as her daughter Imee Marcos, centre, who is also a governor in the country
Congresswoman Imelda Marcos sings a Visayan love song with a priest during her birthday celebrations
She also visited her constituents in the district of Ilocos Norte where she handed them cash gifts.
A party was also held in her honour in her family's stronghold in the northern Philippines and she blew out a candle on a cake topped with a shoe decoration.
The former first lady was found to own 3,400 pairs of shoes after her husband was ousted from office in 1986.
Mrs Marcos smiles as some young supporters serenade her and presented her with a birthday cake
Bodyguards help Mrs Marcos down the steps, left, where she is greeted by supporters eager to wish her a happy birthday
Children clamber around the 85-year-old former first lady, who handed out cash to the crowds
Mrs Marcos remains popular in the northern Philippines, which is a stronghold for the Marcos family
Mrs Marcos, was accused but never convicted of stealing state billions to support a lavish lifestyle during her late husband's 20 year rule, while many in the country faced poverty.
But she could be planning a return to the Philippines presidential palace after declaring that her son would be 'qualified' to contest the presidency at the next election.
Current president of the Philippines Benigno Aquino will end his six-year term in May 2016.
Mrs Marcos blows a kiss to her supporters who gathered to greet her before she attended mass
Supporters were keen to wish the former first lady a happy birthday with this woman greeting Mrs Marcos with a kiss on the cheek
One supporters kisses the hand of Mrs Marcos during the celebrations to mark her 85th birthday
Imelda Marcos visits the body of husband Ferdinand on 85th birthday


text:
David Harlow's Health Care Law Blog
Awards/Reviews
HCSM
Blawg Review #88
Welcome to Blawg Review #88, where you can sit back while some of the masters of the form tickle the ivories. (Since the number of this edition matches the number of keys on a piano, you'll have to bear with me through some musical musings; I trust they will not be too painful.)
To kick it all off I'll invoke the one and only Duke Ellington, master pianist, composer and bandleader, who once said of performing: "It's like an act of murder, you play with intent to commit something."
This performance begins with a note on a law regarding an instrument that may be used for acts of murder or acts of self-defense. David Kopel at The Volokh Conspiracy comments on the Ohio rollback of gun control laws. In other firearms news, see Concurring Opinions for Dave Hoffman's musings on the Second Amendment — and hunting permit volume in Pennsylvania.
Speaking of guns, Chico Marx always looked like he was shooting the piano keys while he played, but he was probably thinking about gambling, one of his other passions.
The plaintiff bar seems to be gambling in a calculated way on the Vioxx litigation, according to Ted Frank, writing at Point of Law. He observes that a recent decision is
the fifth jury victory for Merck in six cases, but, of course, when juries are allowed to award tens of millions of damages, trial lawyers can profitably bring meritless cases if juries get it wrong 15% of the time.
Chico was also an early authority on the reliability of eyewitness accounts, noting: "Well, who you gonna believe, me or your own eyes?"
It is sometimes hard for anybody to believe the tangled web we lawyers weave, and I think the Marx Brothers would have had a field day with the web of health care regulation, which is my area of specialty.
This past week, Health Affairs Blog posted a piece on the largest-scale health care issue that will likely face the new Congress: the "Medicare trigger" — a sleeper provision in the Medicare Modernization Act of 2003 which will require massive rearranging of priorities once Medicare budget growth hits certain markers that it will almost certainly hit in the next couple of years.
One contributor to breaking the bank will likely be Congress' own persistent unwillingness to stick to previously mandated cuts in Medicare physician reimbursement or come up with a better system, as I noted last week here at HealthBlawg.
Michael Cassidy's Med Law Blog highlights this and other statutory and regulatory developments in a roundup of major Medicare changes for 2007.
Art Tatum, master of improvisation, liked to say that "there is no such thing as a wrong note." Failing to take its cue from Tatum, Iran's Foreign Ministry certainly struck one in hosting a Holocaust deniers conference, discussed by Jack Balkin in his post, Dialectic of Enlightenment, on Balkinization. At Is That Legal?, Eric Muller wrote the Ministry an open letter about his family's proof of the Holocaust — the death of his great uncle.
Many people escape discord and persecution — ethnic, religious, economic — around the world by coming to the U.S., often with the hope of having their children born here and thus obtaining U.S. citizenship. This "birthright" was under attack in the last Congress. Peter Spiro, at Opinio Juris, tells us that this effort is Another Welcome Casualty of the Midterm Elections.
Coming to the U.S. has been characterized by some as coming in from the cold. The words of the pop song, Baby, It's Cold Outside, however, have been turned on their heads by recent weather. Susan Smith's Environmental Law Prof Blog says "Baby, It's Hot Around Here."
One of the hottest pianists and singers around, Ray Charles, said: "I never wanted to be famous. I only wanted to be great." Seeking greatness is admirable; however, as David Maister observes regarding the "size matters" school of corporate management, companies aggressively seeking growth may be less than admirable. Those seeking greatness through patenting their inventions may have their lives made a bit easier thanks to Google Patent Search (the latest from the Googleplex), says Brett Trout at Blawg IT. See also Sabrina Pacifici's beSpacific. Those seeking greatness by contributing to the store of freely shared software under a GNU general public license (GPL) rather than by developing proprietary works are indebted to Eben Moglen, the key defender
of the GPL. See Tim Lee's The Technology Liberation Front for more.
Warren Buffett is probably more famous than he ever wanted to be. Ted Frank, writing at Overlawyered, is wondering whether Berkshire Hathaway's acquisition of a med-mal insurer from GE is likely to succeed because (a) GE sold at a fire-sale price, (b) liability caps are coming or (c) Buffett's the wizard.
Herbie Hancock, Buddhist and jazz icon, has mastered several different musical idioms. As he once said, "Since time is a continuum, the moment is always different, so the music is always different."
Marcy Peek, writing at Concurring Opinions, posits that we should consider the continuum-bending exercise of putting "juniority" ahead of "seniority."
Some might say that our government takes a dangerously relativistic view of the world, particularly in defining terrorism and terrorist organizations; that it may even be, so to speak, tone deaf. A First Amendment case involving contributions to a charitable organization that ended up on the U.S. government's list of who's been naughty may be heard by the Supremes. See Eugene Volokh's post on Rahmani v. U.S. (cert. pending) at The Volokh Conspiracy.
In the realm of corporate governance, transparency and regulation, there's been talk about some relaxation of Sarbanes-Oxley requirements recently, as noted at GRC Excellence. Leon Gettler observes, regarding SOX in the U.S., and other regulatory schemes elsewhere in the world:
When things go wrong, the usual response from politicians is to bring in laws to restore public trust. But it never works. In fact, tough laws only make things worse.
There's a link to an article of his published Down Under in print at SOX First.
When flying, you might hope to hear the music of the spheres — unless, of course, you're at the boundary between Vermont and federal jurisdictions and trying to nurse an infant on a commercial passenger jet. In that case, you may precipitate the Vermont Human Rights Commission being asked to consider whether the federal Airlines Deregulation Act trumps Vermont's human rights law. Check out The Mommy Blawg's Vermont breastfeeding update.
Another rupture in the continuum this past week surrounds a trademark battle over an individual's name, which Ann Bartow was riffing on at Feminist Law Professors.
"Sometimes it's to your advantage for people to think you're crazy." Those were words for the iconoclastic Thelonious Monk to live by, but not most lawyers. Some clients seem to think playing the psycho card is to their advantage, but Kenneth Adams, at Adams Drafting, thinks that an agreement permitting a party to act "in its sole discretion" is no excuse for the dissonant improvisation of unreasonable behavior. Accordingly, he offers some pointers on drafting contract provisions invoking a party's discretion.
Congress and the Federal health care regulatory agencies sometimes appear to be irrational to the outside observer. My favorite judicial quote of all time picks up on this:
There can be no doubt but that the statutes and provisions in question, involving the financing of Medicare and Medicaid, are among the most completely impenetrable texts within human experience. Indeed, one approaches them at the level of specificity herein demanded with dread, for not only are they dense reading of the most tortuous kind, but Congress also revisits the area frequently, generously cutting and pruning in the process and making any solid grasp of the matters addressed merely a passing phase.
Rehabilitation Association of Virginia, Inc. v. Kozlowski, 42 F.3d 1444, 1450 (4th Cir. 1994). Despite, or perhaps because of, this sort of characterization, the courts often leave the agencies alone in interpreting and implementing their rules. This week, however, Greg Piche', at Holland & Hart's Health Care Law Blog, writes about a recent Second Circuit decision that actually struck down the implementation of a Medicare reimbursement rule regarding payment for implantation of medical devices as arbitrary and capricious.
Blawgers and other bloggers sometime find that other people think they're crazy ("playin' different tunes," to quote a dinosaur of rock); occasionally they're sued for defamation — sometimes even for comments posted by third parties. For the latest on blog owner do's and don'ts, liability for defamation by commenter, and blogging liability insurance, see Blogs and the Law at Jen Burke's Transcending Gender.
Bloggers stick together in order to find others who don't think they're nuts. An old friend of mine likes to say that people stick together in smaller and smaller affinity groups (her favorite example of a hypothetical small group is left-handed Jewish lesbian redheaded Cuban feminists). The first Healthcare Blogging Summit, organized by Dmitry Kruglyak of The Medical Blog Network took place recently in D.C. While the world of healthcare blogging or the world of blawging may represent a veritable orchestra full of virtuosos (virtuosi?), health blawging seems to be limited to a band of a dozen or so soloists, woodshedding, as it were. One of those who summitted was Bob Coffield, a health blawger who posted some post-summit updates in his pre-summit Health Care Law Blog post.
I'll leave you with one my favorite pianist photographs, Arnold Newman's portrait of Igor Stravinsky. Stravinsky's music is famously complex, some of it atonal, but one of his views on composition reveals a simple fortuity inherent in the work: "One has a nose. The nose scents and it chooses. An artist is simply a kind of pig snouting truffles."
Have a good week, and in the spirit of the musicians who inspired this week's edition of Blawg Review, I wish you luck in balancing intentionality and chance in your work and life.
Blawg Review has information about next week's host, and instructions how to get your blawg posts reviewed in upcoming issues.
— David Harlow
Filed Under: Blawg, Blawg Review
Blawg Review #87 is up — Watch this space for Blawg Review #88 on December 18
Blawg Review #106 and the pathology of motorcycle racing
Blawg Review #111 is up
« MA Medical Law Report
Health care insurance reform notes from South Carolina »
Antitrust Review says:
Blawg Review #88 is up at HealthBlawg.
Minor Wisdom says:
Blawg Review # 88
HealthBlawg, David Harlow's health-care law blog, carries this week's installment of Blawg Review. Since this is the 88th installment of Blawg Review, David has chosen a piano-player theme. Unfortunately, he missed all the great New Orleans piano playe…
Health Care Law Blog says:
Blawg Review #88: Tickling The Ivories
Blawg Review #88 is up at David Harlow's HealthBlawg with a mention and link to the Healthcare Blogging Summit.
David, very nicely composed. In keeping with the theme — you know the "key" to good health care isn't "black and white." Although the …
Transcending Gender says:
Blawg Review #88 at HealthBlawg
HealthBlawg is hosting this weeks Blawg Review #88. David Harlow provides not only entertaining writing but also gorgeous back-and-white pictures of some of his favorite musicians, including Arnold Newmans breathtaking shot of Igor Stravi…
What About Clients? says:
Mercy! Them Eighty-Eights at BR # 88…
Who has ever argued with Music and won? Well, the moment of truth has finally come, at David Harlow's HealthBlawg. Welcome to Blawg Review #88, where you can sit back while some of the masters of the form tickle the…
Watcher of Weasels says:
Weekly Roundup of Weekly Roundups
King of Fools hasn't put together this week's Carnival of the Carnivals, and quite possibly never will again, but the show must go on: The Blawg ReviewThe Carnival of the CapitalistsThe Carnival of EducationThe Carnival of the InsanitiesThe Carnival of…
Tweets by healthblawg
HIPAAtools
The HIPAA Compliance Toolkit
The Walking Gallery
David Harlow
HealthcareNOW Radio
Book Me: Speaking
The Harlow Group LLC
HealthBlawg is a publication of The Harlow Group LLC. See Copyright notice and disclaimer.
Fair use with attribution and a link is encouraged. Click for more on David Harlow.
[footer_backtotop text="Back to top" href="#"]


Providing to the best of your knowledge, accurate and complete information about your present health status and past medical history and reporting any unexpected changes to the appropriate health care professional and include use of over-the-counter products, dietary supplements and allergies or sensitivities.
Complying with the treatment plan recommended by the primary practitioner involved in your care.
Providing an adult to transport you home following treatment and an adult to be responsible for you at home for the first 24 hours following treatment as needed.
Indicating that you clearly understand the contemplated course of action and what is expected of you.
Your actions if you refuse treatment, leave CCSC against the advice of your practitioner, and/or do not follow the practitioner's instructions relating to your care.
Assuring that financial obligations associated with your care at CCSC are fulfilled as expediently as possible.
Providing information about and/or copies of any living will, power of attorney, advance directive, or other directive you desire us to know about.
Be respectful of the healthcare professionals and staff as well as other patients.


text:
Q: How to get working Landscape and Portrait layout total pages count in a single report using jasper report? I've multiple reports( one is Portrait and other one is Landscape).I compile 'em separately and merge them in a single report.
Since I'm  generating the reports and then merging it, current page number and total pages is
not available... so my report shows only first report page count and not including second report page count
How to overcome this...any suggestions?

A: Implement a parameter in the second report "$P{offset}". When the first report is generated, count the pages and pass the count to the parameter of the second report.
Then use an expression like "$P{offset} + $P{PAGE_NUMBER}" in the second report.

redpajama_set_name: RedPajamaStackExchange


Oxidation is very important process in the IC fabrication. In one line, oxidation can be explained as the production of Si02 using the thermal growth technique. Some of the important uses of Si02 are as follows.
In bipolar and MOS transistors, it isolates one device from other.
It acts as a barrier or mask against the diffusion or the implantation of impurity dopant in substrate.
In MOS devices, it acts as a component.
This is the basic process used in IC fabrication. When the charge density level at the interface of silicon and oxide is required low, this technique is used.
This process is also known as chemical vapour deposition. In multilevel structures, the Si02 layer is formed on the top of the metal layer using vapour phase oxidation process.
Equation (1) indicates reaction of silicon with oxygen, which is a dry oxidation. Equation (2) indicates reaction of silicon with water vapour or steam, which is wet oxidation. Using thermal oxidation, the oxygen diffuses through the oxide to the boundary of Si-Si02. The reaction takes place at the boundary of Si – Si02. After the completion of the oxide growth, almost 46% of the oxide layer piereces within the original substrate, while 54% of the remaining layer remains on the top of it as shown in the Fig. 1.4.
The silicon wafers are arranged in a quartz boat. Then the boat with support is inserted into quartz furnace. The temperature of the furnace lies in the range of 950CC to 1250`C and using proper control system, the temperature is kept constant to about ± 19C. Then silicon wafers are exposed to gas containing 02 and or H2 0. Following the chemical reactions stated earlier. An uniform depth and composition layer depends on the parameters such as growth time, teMperature, pressure, 02 gas concentration etc.
Basically an oxidation is high temperature process. Due to the oxidation process, the layer 'departs from its original location. To overcome this undesired result, the oxidation process is carried out at low temperatures. But this increases the growth time. To overcome this, pressure is increased because an increase by 1 atm pressure decrease temperature by 209C for same growth rate. Thus high pressure oxidations with pressures upto 25 atm are used in the industrial applications at the temperatures in the range of 700 to 900°C. Initially the oxide grow formation rate is very fast and then gradually it slows down as oxygen atoms have to diffuse through the oxide to reach the interface between silicon substrate and Si02. As compared to dry oxidation process, wet oxidation process is faster at a given temperature. Typically to grow 1 Rin thick oxide layer, dry oxidation process takes 2 hour 30 minutes while wet oxidation takes only 1 hour and 30 minutes. Eventhough the wet oxidation process is time saving, it has a drawback of higher impurity contents of the oxides. Generally MOS ICs require a very pure oxide for reliable performance. For this purpose specially dry oxidation process is preferred.
For VLSI, the thin oxides of 20 to 200 A° are in demand. The growth rate for such thin oxide layers are very small. With low temperatures and pressures growth rate reduces. For such very thin oxide layers special techniques are applied. The oxide layers of 30 to 300 A° thick are grown at pressures of 0.2 to 2 Torr. In other technique, for a very thin oxide layer initially temperature is controlled at 1000CC typically, the growth is carried out with 02 – HC1 agent and then heat treatment with N2,02 and HC1 is employed at 1250CC to work out desired thickness. By using low temperatures (750`C) and high pressures (10 atm) in combination, a 300A° thick layer can be grown in 30 minutes with this another special technique.
For reliable performances of the devices, it is necessary to have a very pure oxide. To carry out the oxidation process successfully, it is necessary to study different properties of oxides.
A silicon dioxide acts as a barrier or mask against the diffusion of dopant atoms. Due to ion implantation and chemical diffusion, the dopant atoms gather at the surface of the oxide or near the surface. So the utmost precaution must be taken during the diffusion of axide, such that the dopant atoms do not diffuse through the oxide. This can be achieved by controlling the diffusion in oxide slower as compared to that in silicon. At a particular temperature and pressure, the oxide thickness can be measured experimentally which is essential to avoid the inversion of the lightly doped silicon substrate. In typical devices, the oxide thickness required for the masking purpose is 0.5 to 0.7 um. The masking property can be realized only when the oxide is partially converted into the silica. For different dopant atoms, the diffusion constants in silicon dioxide are different. These are dependent on the structure and concentration of Si02. For n-type, the common impurities are phosphorous (P), Antimony (Si), Arsenic (As), while for p-type Borone (B) is the common impurity.
The fixed oxide charge Q f is usually positive. This can not be charged or discharged. It is not allowed beyond 30A° of Si — Si02 interface. Depending upon oxidation and annealing conditions, its density ranges from 1010 cm-2 to 1012 cm-2.
The mobile ionic charge Qm is positive most of the times. The alkali ions such as sodium, potassium are referred as mobile ion charge. But the negative ions and heavy metals are also referred as ionic charges. The density of Qm ranges from 1010 cm-2 to 1012 cm-2. The radi of ionic charges are more and also their mobility is very low.
The oxide trapped charge Q ot is either positive or negative. It arises from either holes or electrons trapped in the oxide. The main cause of Qot is the defects in the oxides. Also due to avalanche injection, ionizing radiations and high currents in the oxides, Q ot may be induced. The density of Q ot ranges from 109 cm-2 to 1013 cm-2 . In addition to these charges, there is an interface trapped charge Q it.
All these tcharges are calculated using capacitance voltage (C–V) analysis technique.
During the thermal oxidation of silicon, at the surface, Si02 is observed in a state of compression. This is clearly indicated by thermally wrapped silicon dioxide. The complex stress distribution takes place due to the cut in the oxides. Thus there is a danger of high stress levels formation at the discontinuities.
The stress can be relieved by using stress-relief mechanisms. Typically oxidation at 9509C or below, the stress is of the order of 7 x 109 dyne/cm2. At room temperature, the stress is found to be 3 x 109 dynekm2.
1.7.3 Oxidation Induced Defects 1) Oxidation Induced Stacking Faults : Stacking faults are produced on <111> planes due to thermal oxidation of silicon. The stacking faults are structural defects in the silicon lattice which are of extrinsic type and are limited by partial dislocations. There is coalescence of excess silicon atoms in the silicon lattice on nucleation site. This is called as growth mechanism. The growth mechanism involves defects formed during growth of a crystal, surface mechanical damage present before oxidation, chemical contamination and saucer pits or hillocks. Due to process of oxidation the excess interstitial silicon is present near the Si – SiO2 interface. A small part of these silicon atoms flow into the bulk silicon. Growth rate depends upon the silicon interstitial supersaturation in silicon. Stacking faults create some problems like degraded junction characteristics and increased reverse current in MOS structures.
The growth of oxidation induced stacking faults is a function .of orientation of substrate, conductivity type and the defect nuclei present. Growth rate is greater in <100> than in <111> substrates.
The length, of stacking fault is a function of oxidation temperature. For lower oxidation temperature, less stacking faults are grown. For oxidation temperature less than 9509C, the stacking faults formation is suppressed completely.
Silicon is treched before oxidation, to produce planar surface. It produces recessed oxides. In such recessed oxides stress along the edge of an oxidizing area causes defects in silicon. These defects cause increased leakage in nearby devices. Growing oxides generate the stress. This stress should be relieved without damaging the silicon. Sufficiently high oxidation temperature relieves the stress in oxides by viscous flow to make the oxide isolation to defects lesser. It can also be achieved by growing a selective oxide without first trenching the silicon. It is also seen that there is less oxidation in the stressed region which is covered by nitride mask.


Showing your logo or a whole bunch of graphic elements on a big screen, or a handheld unit? You need to tell a story or introduce your clients to the latest offer?
Let us help you animate your message and give it a slight push forward enabling it to pass though the jungle of adds reaching its goal.
Click the company logos below to explore some of our work.


We'd like to draw attention to the incredible £20,000 donation recently made by our Masonic Charitable Foundation to help Kerala flood victims.
The floods, caused by the worst monsoon in a century, have affected 5.5 million people. Nearly three quarters of a million people have been displaced and around 20,000 homes have been damaged or destroyed.


text:
Home Current Affairs Weekly Current Affairs Quiz: 9 to 15 December 2019
Weekly Current Affairs Quiz: 9 to 15 December 2019
Current affairs is an important part of competitive exams. This section aims to help you score better in Current Affairs/General Awareness section. Give the much needed boost to your GK for competition, read.
Weekly Current Affairs Quiz
Give a try to this weekly current affairs GK quiz, award yourself one mark for every correct answer and share your score in the comment section below.
National Current Affairs
Q. 1 ICAR has signed an MoU with which organization to develop climate resilient technologies for farmers?
Q. 2 Which bill has been passed by Andhra Pradesh that proposes harsh punishment to those who did henious crimes against women?
Q. 3 Which bill is passed by Lok Sabha that seeks to convert 3 deemed Sanskrit universities into central universities?
Q. 4 Which bill has been passed by Rajya Sabha, which was introduced by Tribal Affairs Minister of State Renuka Singh Saruta in the Upper House?
International Current Affairs
Q. 5 Which day is observed worldwide on 16th December ?
Q. 6 The shuttle train service between which two stations in Pakistan resumed operations after 22 years on December 15, 2019?
Q. 7 World's first fully electronic flight has been successfully tested in which country?
Q. 8Who has topped the Forbes 2019 list of "100 World's most powerful women"?
Q. 9 Who has been crowned as Miss World 2019 ?
Q. 10 Which Indian actress has received The World Economic Forum's (WEF) 26th Annual Crystal Award for the year 2020 for her remarkable leadership in raising mental health awareness?
Q. 11Who has been names Times' Person of the Year 2019?
Q. 12 Who has been honored with the FICCI India Sports Awards 2019's Sports Person of the Year (Female)?
Q. 13 Which city has been selected as World's leading sports tourism destination by 26th edition of World Travel Awards (WTA) ?
Answer 1: The Indian Council of Agricultural Research (ICAR) has signed an MoU with the National Board of Agriculture and Rural Development (NABARD) on December 13, 2019. The purpose of this MoU is to facilitate the research and technologies for development of climate resilient practices in the agriculture sector and introduce hi-tech farming practices.
Answer 2: The Andhra Pradesh Cabinet has cleared the Disha Bill, also known as Andhra Pradesh Criminal Law (Amendment) bill, on
December 11, 2019 that proposed harsh punishment for crimes against women.
Answer 3: The Central Sanskrit University Bill 2019 has been passed by Lok Sabha. The bill seeks to convert 3 deemed Sanskrit universities, currently functioning in the country, into central universities. The bill was piloted by Ramesh Pokhriyal 'Nishank', Union Human Resource Development (HRD) Minister .
Answer 4: The Constitution (Scheduled Tribes) Order (Second Amendment) Bill, 2019 has been passed by Rajya Sabha on December 12, 2019 by voice vote. It was introduced by Tribal Affairs Minister of State Renuka Singh Saruta in the Upper House. The bill will amend Constitution (Scheduled Tribes) Order, 1950 in order to include three tribes namely– Talwara, Parivara and Siddi community of Belagavi and Dharwad districts, in the list of Scheduled Tribes in Karnataka.
Answer 5: International Tea Day is observed every year on 16 December since the year 2005. This day is celebrated in all the tea producing countries including India, Indonesia, Nepal, Bangladesh, Sri Lanka, Tanzania, Vietnam, Malawi, Kenya, Uganda and Malaysia.
Answer 6: The shuttle train service between Lahore and Wagah railway station in Pakistan resumed operation its operation after a gap of 22 years on December 15, 2019. The train will complete 3 round trips on a daily basis and has the capacity of carrying 1,000 passengers in three trips. This shuttle train service was operational between the stations Wagah and Lahore since the partition of India in the year 1947 till the year 1997 and was closed due to some operational and security reasons.
Answer 7: The first fully electronic flight in the world completed takes its test flight successfully from Canada on December 10, 2019. The flight will be operated from Vancouver, Canada to the near by islands.
Answer 8: 65-year old German Chancellor Angela Merkel has topped the Forbes' 2019 edition of 100 World's Most Powerful Women for the 9th consecutive year. She has made 14 appearances in the list's 16-year history of Forbes magazine. She has been praised worldwide for standing up to US President Donald Trump and her decision of allowing entry of over a million Syrian refugees into her country (Germany).
Answer 9: Toni-Ann Singh of Jamaica has been crowned as Miss World 2019 at a beauty pageant held in London, United Kingdom. Ophely Mezino from France was first runner-up and Suman Rao from India was second runner-up. Toni-Ann Singh received the crown of Miss World 2019 from Mexico's Vanessa Ponce de Leon, the winner of Miss World 2018.
Answer 10: Deepika Padukone has won The World Economic Forum's (WEF) 26th Annual Crystal Award for the year 2020 for her remarkable leadership in spreading mental health awareness. She has become the only Indian female actor to won 26th Annual Crystal Award for spreading mental health awareness.
Answer 11: Swedish teenager Greta Thunberg, has been named as Time magazine's 2019 Person of the Year. The 16-year old Thunbergwas chose from a list of people including US President Donald Trump, The Hong Kong Protesters, House Speaker Nancy Pelosi, etc.
Answer 12: Rani Rampal, captain of India women's hockey team, has been named FICCI India Sports Awards 2019's Sports Person of the Year (Female).
Answer 13: The 26th edition of World Travel Awards (WTA) has selected Abu Dhabi as the World's leading Sports Tourism Destination for seventh time in a row.
Previous articleHow to Prepare Revision Notes for Board Exam 2020
Next articleKIITEE Admission Online Form 2020 – जानें Complete Details


This is the a great time to share an chance to you about hacking League Of Gamers. We could feel so happy if we can hack League Of Gamers. Why? It is because they can get free Diamonds in unlimited way without spending a single buck. This is actually the best League Of Gamers hack tool in 2018 you need to use. The very best part of most this hack will not implement any survey or human verification to its user. We can make sure you will feel satisfied after using that one as we have finished with this for many times. This is your last chance whether you miss it or you use it.
I just got free Diamonds. Because of 1gamz that provides this wonderful League Of Gamers hack tool.
I ever try this tool and failed to get it as a result of survey. However in the next try, I could claim the rewards!! For the one who gets the same fate as me, do not quit yet. Just try it again and you'll get it!
I really love that one because I can do almost everything in League Of Gamers.
I am sure enough that the people who refuse to try out this League Of Gamers generator are a stupid person!
I must say i wish this can stay forever since I must say i love League Of Gamers a lot.
Wow it's so amazing! This League Of Gamers hack tool is very amazing. Great job 1gamz!
Before I found this generator, I do not have any hope left to play League Of Gamers. But after utilizing it for a while, all the situation go away completely without any trace!!!
Still cannot believe I get free League Of Gamers Diamonds on my account. Fantastic!
The pretty hack tool that I've ever found. It's my first time I use this League Of Gamers hack tool and I'm really satisfied with it. I love it!
This tool really helps all gamers a lot. I already look at the statistics of the hack usage and 70% all gamers in the world use this one to play League Of Gamers effectively. For the main one who never uses it, try it right away!!!
I can apply this League Of Gamers hack tool easily and effectively. Very good job 1gamz!
I'm so thankful that time my friend recommended me about this League Of Gamers hack tool. The hack tool was amazing. You're great, 1gamz.
The very best League Of Gamers hack generator. I really get free Diamonds. Astounding!
No jailbreak required to get Diamonds. Instead of buy it at the game store I favor everyone uses this hack immediately. Need not doubt it because this is the real one you already looking forward to!!!
You must take a look one because you will never regret for the rest of your life, I've get Diamonds to my League Of Gamers account.
Really enjoy applying this League Of Gamers hack tool. Thank you 1gamz. You've done a good job..
Shared most of my friends concerning this amazing League Of Gamers hack tool that provide free Diamonds. Great!
Many thanks Tapps Games for making such as this great League Of Gamers hack generator and also 1gamz to provide this one.
I am sure enough that the people who won't try this League Of Gamers generator are a stupid person!
Two thumbs up because of this League Of Gamers hack tool. You always do your best 1gamz. Good!
This League Of Gamers hack tool is better than I thought. Two thumbs up for it!!
So far is good concerning this League Of Gamers hack tool, no problem from me. Good job brother!
I really do not know this type of hack exists on the internet. For the one who doubts League Of Gamers hack tool, you will regret it for sure!
Everyone guys must try out this League Of Gamers hack tool. It's different with another hack tool i ever found. I get free Diamonds all of a sudden. An incredible hack tool.
League Of Gamers hack tool is absolutely helpful to get a great deal of Diamonds. Just what a excellent tool it is!
thanks a lot Tapps Games for free League Of Gamers Diamonds.
I just wanna sharing. I'm satisfied with this League Of Gamers hack tool work. Very amazing.. You guys must check it out!
Believing something without any legit proof is quite hard. We realize everyone ever feel it. But you cannot think like this if you need to use the tool. Although it cannot convince all users to use it, the tool indeed gives me unlimited Diamonds!!!
I am going to bet that this League Of Gamers hack tool will be all people's favorite in 2018.
Wow, it is incredible! How do this tool offer unlimited Diamonds with no problem in any way?
This is so unbelievable! So thank you to League Of Gamers hack tool. I get free Diamonds. How does it work?
OMG! I get free League Of Gamers Diamonds on my account all of a sudden. Everyone must check it out right now!
Attention for all players who played League Of Gamers! This is a real tool which can grant your wishes to get unlimited Diamonds. Check it out for yourself if you cannot believe my words!
Attention for all those players who played League Of Gamers! This is a genuine tool which can grant your wishes to get unlimited Diamonds. Try it for yourself if you cannot believe my words!
It is like a dream come true. How come I never find out this amazing hack tool. For the one who has a problem in League Of Gamers. This is the right time that you can do something with this!
This one is a really amazing stuff. Everyone must use this hack. We are able to hack League Of Gamers today!
How superb this League Of Gamers hack tool.
I simply wanna sharing. I'm satisfied with this League Of Gamers hack tool work. Very amazing.. You guys must try it!
thank you Tapps Games for free League Of Gamers Diamonds.
It really is real, there is no survey or human verification whatsoever in this League Of Gamers hack 2018.
I must say i interested to try out this League Of Gamers hack tool. And it was amazing..
How can 1gamz provides so many amazing hack tools as good as this? This League Of Gamers hack tool is really incredible. You need to check it out right now!
Let me bet that this League Of Gamers hack tool will be all people's favorite in 2018.
Been using for about two months, it hooked me. So far, this League Of Gamers hack tool is good. You need to check it out tool!


text:
Microsoft announces cheaper Power Apps licensing from October 2021
July 2. 2021
Good news! Microsoft have announced that from October 2021, the licensing costs for many users could fall by half.
Yesterday (1st July 2021), Microsoft announced a change in licensing conditions which will benefit many users.
https://www.microsoft.com/en-us/licensing/news/pricing_and_licensing_updates_coming_to_power_apps
What does this change mean exactly?
For the majority of users with a Power Apps plan (e.g, users that rely on premium connectors in order to connect to SQL Server or Dataverse data sources), the cost of licensing will half. Specifically:
a "per user" license will be $20/user/month, instead of of $40/user/month
a "per app" license will be $5/user/month, instead of of $10/user/month
An important thing to note however, is that a per app plan can currently license 2 apps. Following the change in October, the "per app" plan will be capable of licensing a single app only. Therefore, users that currently license two apps with a "per app" plan will need to purchase two licenses, and there will effectively be no change in the cost of licesing.
However, the change to the "per app" plan is positive because from October, this plan will additionally enable users to access one portal. This should hopefully encourage more app builders to build portal apps
The licensing changes from October 2021 will reduce the cost of Power Apps. This is a positive change for app builders and will hopefully increase the use of Power Apps.
Troubleshooting - Where can I find a list of all known Power Apps issues?
Controls - How to display dates in a combo box
Licensing - Microsoft 365 licensing price set to increase in March 2022
Why is Microsoft 365 licensing so confusing?
Licensing - What license do I have?


Sorry, you missed Real Estate Affiliate Marke... at Savannah, Georgia, United States.
Demand that Savannah, Georgia, United States gets added to the next tour!
You missed Real Estate Affiliate Marke... at Savannah, Georgia, United States.


text:
Sebastian Zinn
Drawing Moments of Everyday Life with a Typewriter: Lenka Clayton at Catharine Clark Gallery
Lenka Clayton, Abandoned To Do List (10/19/2020), 2020. Typewriter ink on paper, rendered with a portable 1957 Smith-Corona Skywriter typewriter. 14 1/4 x 11 1/4 inches framed. Courtesy of the artist and Catharine Clark Gallery, San Francisco.
Since 2012, multidisciplinary artist Lenka Clayton has honed a distinctive method for representing and archiving the substance of her daily life. Clayton creates figurative illustrations on 8.5 x 11 inch typewriter paper using a portable 1957 Smith-Corona Skyriter typewriter, trading the hard line of a pencil, or the range of viscosities and pigments of different paints, for the finite number of signs and symbols in a set of type keys. In her most recent series of what she calls "Typewriter Drawings," titled How we thought it would be, and how it was., and presented in an online viewing room by Catharine Clark Gallery in San Francisco, Clayton has trained her typebars on the objects that rapidly became metonyms for the coronavirus pandemic: facemasks fashioned from old tea towels, stay-at-home haircuts, and carefully demarcated supermarket queues.
How we thought it would be, and how it was. features just over twenty "Typewriter Drawings" (all made in 2020), but Clayton has produced hundreds since she began the series nine years ago. These works display Clayton's technical mastery of her peculiar medium, as well as her tongue-in-cheek sense of humor. Visual puns abound: an illustration of a ghostly slip of paper, left blank, but for a solitary capital letter "T" in the top-left corner, is titled Abandoned To Do List 10/19/2020. Some drawings, like Air Purifier 09/28/2020, veer deftly into abstraction. The four corners of a sheet of paper are filled with constellations of type. Taken together, these clusters describe an oval of blank space in the paper's center. Viewers will quickly realize that in this case, the glyphs represent the invisible germs which wait to infect us at every turn, while the oval represents the salubrious halo generated by an air purifier.
Lenka Clayton, Air Purifier (09/28/2020), 2020. Typewriter ink on paper, rendered with a portable 1957 Smith-Corona Skywriter typewriter. 14 1/4 x 11 1/4 inches framed. Courtesy of the artist and Catharine Clark Gallery, San Francisco.
The fact that Clayton dates and titles her drawings using type more conventionally underscores the interpretive gymnastics the human eye and brain quietly perform just to determine when the artist is writing with type and when she is drawing with it. Stacks of zeros (or possibly letter Os) distributed in neat, vertical rows across a page are drawn into focus by the title Panic Bought Spaghetti 10/01/2020. Glass Half Full of Tears 09/12/2020—a straightforward representation of a partly finished drink on a countertop—serves as another microcosmic example of this tightrope-walk between a verbal description and visual illustration. Coupled with its title, the image expresses something ineffable about the emotional counterpoints many of us have experienced since the pandemic began: hope marred by grief; generosity constrained by self-interest. Without its epithet, Glass Half Full of Tears becomes just another still-life, albeit one astonishingly rendered by an unusually blunt instrument.
Lenka Clayton, Glass Half Full of Tears (09/12/2020), 2020. Typewriter ink on paper, rendered with a portable 1957 Smith-Corona Skywriter typewriter. 14 1/4 x 11 1/4 inches framed. Courtesy of the artist and Catharine Clark Gallery, San Francisco.
Lenka Clayton, Panic Bought Spaghetti (10/01/2020), 2020. Typewriter ink on paper, rendered with a portable 1957 Smith-Corona Skywriter typewriter. 14 1/4 x 11 1/4 inches framed. Courtesy of the artist and Catharine Clark Gallery, San Francisco.
Surveying Clayton's many typewriter illustrations, I am reminded of Emily Dickinson's "envelope poems." Terse verses written on wisps of letter envelopes and other paper scraps, Dickinson's poems, like Clayton's illustrations, are shot through with wit, pathos, and resolve. Both artists possess the uncanny ability to distill an evanescent thought or feeling into something that (unlike us) might withstand the slow and immutable march of time.
What more can be made of the comparison? Dickinson and Clayton's lyrical innovations in different forms both hint at creative processes that are simultaneously ecstatic and painstakingly deliberate. Clayton's medium is obviously unwieldy. Although she's had nine years of practice, it's no doubt still challenging for her to imagine how well a parenthesis will approximate the vein of a leaf before she produces the mark (see Tea Towel Cut Up to Make Face Mask 10/25/2020). Any typos must be incorporated into the finished drawing or the piece must be scrapped. Given this slim margin of error, Clayton's copies (at least those she exhibits) are remarkably clean.
Lenka Clayton, Tea Towel Cut Up to Make Face Mask (10/25/2020), 2020. Typewriter ink on paper, rendered with a portable 1957 Smith-Corona Skywriter typewriter. 14 1/4 x 11 1/4 inches framed. Courtesy of the artist and Catharine Clark Gallery, San Francisco.
Dickinson's original manuscripts likewise bear some of their own palimpsestic qualities. The clearest examples of this are the lists of "variant terms" which Dickinson began writing on the margins of her texts in the early 1860s, in which she supplied several "alternatives" for any particular adjective, noun or verb in a poem.[1] Many scholars have argued that these lists of substitutions are non-hierarchical, that no one version of the manuscript "should be regarded as 'definitive' or 'final.'"[2] Rather, they represent the impossibility of choosing one single term in a language which offers so many options. Clayton's choices, on the other hand, decouple glyphs from their very ability to signify sonically or grammatically; they show us all the ways in which they might communicate graphically instead.
The "Typewriter Drawings" are just one manifestation of Clayton's singular ability to engage with epistolary materials, technologies, and traditions in unexpected and unexpectedly meaningful ways. Since 2009, she and her collaborator, Michael Crowe, have been handwriting (or hand-typing) personalized letters to an astonishing number of strangers in an ongoing series titled, Mysterious Letters. Their ultimate goal, endearing in its childish absurdity, is to deliver a personal letter "to every household in the world." One of the silver linings of this tragic year is that to some extent we've all become one another's pen pals. How lucky we are that artists like Clayton have taken the time to telegraph the minutiae of their own pandemic lives to the rest of us in such creative ways.
[1] Mieszkowski, Jan. Crises of the Sentence. 2019. (109).
Lenka Clayton: How we thought it would be, and how it was.
Did you love this article? Do you want more amazing content about all the incredible West Coast artists and art happenings? Your support fuels the innovative work that makes this coast so unique.
Be an art lover.
Get the best West Coast art sent straight to your inbox.
Variable West
hello@variablewest.com


text:
The Michael Lorber Team
{ min_chars: 3, type_ahead: false, submit_onenter: true, cache: true, over_text: "Address or Web ID" }
505 West 43rd Street, 7J - Clinton, New York
Sales Gallery located at 311 West 43rd Street, 5th floor. Please note the correct 311 entrance door is nearest to 8th Avenue.
This gracious south-facing studio features floor-to-ceiling windows and 5" wide plank oak wood flooring throughout, completed with a custom fully integrated Scavolini kitchen by Escobar Design with wood and lacquered cabinets, white quartz counters and backsplashes, and appliances by Bosch and Thermador. The luxurious bathroom flooring is a Herringbone marble stone tile pattern with porcelain tiled walls and fixtures by Toto. An expansive walk-in closet and washer and dryer complete this residence.
Charlie West is a contemporary addition to Manhattan's historic Hell's Kitchen neighborhood. Located at 505 West 43rd Street, Charlie West spans the block through to 44th Street and is composed of two 16-story buildings.
Designed by ODA Architects with interiors by Andres Escobar, the 123 condominium residences range from studios to three bedroom homes and penthouses, many with substantial terraces and balconies commanding skyline views.
Charlie West offers over 6,000 square feet of hotel-grade amenities in dramatic double-height spaces including an industrial-chic lobby that also serves as a curated library and private lounge with a fireplace. An indoor/outdoor pool and a fully equipped fitness center open to respective outdoor terraces and the building's landscaped courtyard, complimented by a children's playroom, as well as an innovative, translucent glass-enclosed bike storage box. These expansive indoor and outdoor amenities provide integrated spaces for entertaining, fitness and relaxation."
The renderings in this website are artistic illustrations. The inclusion of furniture, furnishings, fixtures and decorations in the renderings of units and common areas are for illustrative purposes only. All units are being offered unfurnished. Sponsor makes no representation that the fit-out of any common areas will be as set forth in these renderings and sponsor makes no representation concerning the views from any unit or common area. Sponsor: 1818 Nadlan LLC. 311 W 43rd Street, 5th Floor, New York, NY, 10036. The complete offering terms are in an offering plan available from sponsor. File No. CD 16-0304
View Floorplans »
{ lat: "40.760557", lng: "-73.995548", base_marker: { lat: "40.760557", lng: "-73.995548" } }
{ lat: "40.760557", lng: "-73.995548", streetview: true, base_marker: { lat: "40.760557", lng: "-73.995548" } }
505 West 43rd Street - Clinton,
Monthly Maintenance/CC: $524
Monthly Real Estate Tax: $463
Minimum Percent Down: 10%
Neighborhood: Clinton
Community Information »
Local School Reports »
Local Amenities »
Your Agent(s)
Michael Lorber
mlorber@elliman.com
JOINTODAY
Mortgage Calculator »
All Rights Reserved:
© 2019. Douglas Elliman Real Estate. All material presented herein is intended for information purposes only. While, this information is believed to be correct, it is represented subject to errors, omissions, changes or withdrawal without notice. All property information, including, but not limited to square footage, room count, number of bedrooms and the school district in property listings are deemed reliable, but should be verified by your own attorney, architect or zoning expert. The number of bedrooms listed above is not a legal conclusion. Each person should consult with his/her own attorney, architect or zoning expert to make a determination as to the number of rooms in the unit that may be legally used as a bedroom.
We are an equal housing opportunity provider. Consistent with applicable law, we do not discriminate on the basis of race, creed, color, national origin, sexual orientation, lawful source of income, military status, sex, gender identity, age, disability, familial status (having children under age 18), or religion. Equal Housing Opportunity.


At AJM we have been offering an efficient and effective house removals Bristol service since 2011. We are a local moving company who is 100% dedicated to providing clients with the best moving services, whether it's a complete house removal or a man with van job. So if you are looking for professional movers in the Bristol area and value your possessions, hire us now and you won't be disappointed. We always put our customers at the heart of every job and go the extra mile to ensure they are completely satisfied with our work. We guarantee your furniture and belongings will be handled with care and attention, with no fear of being lost or damaged. With a growing network of highly satisfied customers, we can confidently say that over the years we have delivered very high standards in the removals industry. Our business approach is unique in that we put the customer and their needs at the center of each job. This makes us stand out and has made us a preferred choice for customers when compared to other removal companies. Our team of professional movers is reliable and trustworthy. So if you need anything moving, we are your first choice.
Our House Removal Service is available from Monday to Sunday, including bank holidays, for both domestic and commercial customers. We can safely deliver full loads or single items as well as offering a full packing service or just quality packaging materials and boxes if needed.
And remember, we provide all furniture protective equipment and materials at no extra cost on your moving day.
Moving to a new home is a great news for any family, but after many years of happy memories in a home, it can be one of the most stressful and anxious experiences. Here, at AJM Removals, we always do our best to reduce that stress and provide you with a hassle-free house removals service. We can take all the stress off your shoulders by planning every aspect of your move in detail. So whether you're moving just down the road or to the other end of the country, we have everything you need to assist every step of the way in your relocation. We carry out all aspects of house removals from a studio flat, to a three-four bedroom property. We have a fleet of Luton vans and a large team of strong yet considerate removal men so that the whole move process is done within the agreed timescale. All our moving services are fully guaranteed and insured, so you can be sure that you are in safe hands with us.
We are here to take the worry out of moving and help make your journey to new horizons easier on the whole family. Specializing in local and long-distance moves, you can count on our friendly moving crew for a hassle-free move! With our approachable nature and efficient service, you'll soon see why we are the preferred movers amongst a huge number of local families in and around the Avon area.
We also offer highly competitive prices for all moving and packing services carried out in Bristol, Yate, Nailsea, Portishead, Clevedon, Thornbury, Keynsham, Bath, Weston-super-Mare, Gloucester, and all surrounding areas.
We provide a wide range of removal services to suit all our customers needs whether they are individuals, families or an established business. Below are the most popular ones.
We cover all aspects of house relocation. From small house moves to large home removals, our service is tailored to your exact needs. We've completed countless home relocations in Bristol since 2011. Please see our Customer Reviews section to see a very large number of highly satisfied customers!
If you are looking for a quick removal job which requires a man with van service in Bristol area this is the perfect service for you. We believe that our prices for man and van services are more than competitive.
As part of a comprehensive removals service, AJM Removals Bristol also offers full packing services for all home moving needs. Packing your home and getting it ready for your house move may be a tiresome and stressful task, so why not let us do it for you?
One of the best-rated removal companies in Bristol - We were voted a Top 3 Removals Company in Bristol 2017 and 2018 - a decision which was based on a comprehensive 50-point inspection including local reviews, history, trading standards, ratings, satisfaction, trust and price. Yet we continually strive to be even better!
Flexible work time - We operate 7 days a week including Sundays and Bank Holidays.
Competitive prices - The price we quote is the price you pay!
Reliable Removals Service - We schedule your move at the right time for you. Reliability is our lifestyle and work ethic!
Full furniture protection - Protective removal blankets, sofa, and armchair padded covers, carpet protection film, mattress covers, shrink wrap, straps, tools, professional moving equipment etc.
Complete home packing services - Careful packing of your belongings, disconnection, and re-connection of kitchen appliances & disassembly and assembly of your furniture.
Small Bristol Removals Company - All home moves are undertaken by the business owner, being small means being focused on delivering high-quality removal service.
Free Removal Quotes - We offer online moving quotes and a free home survey on any Bristol move without obligation and will provide you with a quote which is based on your actual needs.
Reputable Removals Company - Operating for more than 7 years, we earned an outstanding reputation for the removal services we provide.
Wide coverage - We cover Bristol and all surrounding areas and are able to move your belongings to any place you choose within the UK.


text:
Harrysong – "Sawanale"
August 15, 2021 Innocent Nnagozie Music, Trending 0
Harrysong release a brand new song, fire jam titled "Sawanale", produced by Dalorbeat.
According to h,
According to Harrysong, "Sawanale" is his first official single of the year. Earlier in the year, around April, he released a song titled "Piom Piom Piom".
'Piom Piom Piom' is an inspirational Afro/Hi-life record that comes with good lyrics to Re-define listeners life and get them closer to God the Father (Almighty) and Jesus the Son. STREAM/GET HERE.
This new song "Sawanale" produced by Dalorbeats, is a combination of Afrobeat and Afro-Reggae-Dancehall. Mr Songs dropped some catchy lyrics and a lovely vibe with sweet melody to brighten our mood and light up music fans playlist. He talked about enjoying life (flexing the little money you have), freeing up the mind and making moment of existing matter.
"Sawanale" is his first official single of the year. Earlier in the year, around April, he released a song titled "Piom Piom Piom".
Listen and download below
https://birnode.com/wp-content/uploads/2021/08/Harrysong_Sawanale_9jaflaver.com_.mp3
GET On Digital Store
STREAM ON YOUTUBE
Harrysong
Charze – "Aye O Pe Meji" ft. Barry Jhay
TLO – "Heartbreaker"


text:
Tremors rattle southeast Albania, injuring 4, damaging homes
by: LLAZAR SEMINI, Associated Press
Posted: Jun 1, 2019 / 08:19 PM EDT / Updated: Jun 1, 2019 / 08:45 PM EDT
A damaged old house is seen after an earthquake in Floq village about 180 kilometers (110 miles) southeast of Tirana, Albania, Saturday, June 1, 2019. An earthquake with a preliminary magnitude of 5.3 has struck rural areas in Albania southeast of the capital, with a few people reported injured and damaging about 100 houses. (Albanian Defense Ministry via AP)
TIRANA, Albania (AP) — An earthquake with a preliminary magnitude of 5.3 struck rural areas in Albania early Saturday southeast of Tirana, the capital, injuring four people and damaging about 100 houses, authorities said.
The Defense Ministry reported that four people were injured from falling walls at their homes and about 100 houses, many uninhabited, were damaged. The injured were sent to a local hospital.
Albania's Institute of GeoSciences, Energy, Water and Environment says the quake occurred at 6:26 a.m. Saturday and affected the Korca district, 180 kilometers (110 miles) southeast of Tirana.
Emergency authorities have set up tents for residents whose homes have been damaged and have sent food and drinking water.
Located mostly along the Adriatic Sea, Albania is part of an earthquake-prone area, registering quakes every few days, though most are not felt.
Follow Llazar Semini on Twitter: https://twitter.com/lsemini


text:
Amazon Has Acquired the United States of America for an Undisclosed Amount. What More Could Bezos Need?
Funny story written by Mink Satiric
Let's Find Out!
Paramount, Universal, and Warner Brothers: these are just some of the film studios not owned by Amazon Inc. (yet). The United States of America, a lesser-known studio known for producing those highly-rated White House Covid-19 press conferences, was previously part of that group but is now owned by Jeff Bezos' e-commerce company (if he even works there anymore).
In a recent interview over Zoom, which is also soon to be acquired by Amazon, the former CEO said he decided to make the purchase after seeing comedian Hasan Minhaj "tear everyone apart at that White House Correspondents Dinner a few years ago." The interviewer chose not to tell Bezos that those are produced privately by the WHCA, out of fear of getting whacked by one of the mafias that Amazon is soon to acquire as well.
Bezos also highlighted in the interview that he was test driving his new super-yacht, but when the producer said he was going to cut that out, Bezos stated, "I own you," which happens to be true. Bezos also made sure to let it be known that he purchased the yacht company that he bought from so that his yacht would "technically be free".
It was also reported by an unknown source that Ellen DeGeneres interviewed Bezos a few months ago, but after feeling like he was acting hostile, Bezos purchased NBC and DeGeneres herself in order to "can the interview". This news reached the general public but was ultimately ignored due to Ellen's "cancellation" (and no, not the cancellation of her show).
The overall acquisition deal of the USA included all of its assets, aside from the Space Force as Bezos stated, "I didn't even like the show." The deal also included a clause that allows Bezos to purchase some of the countries where US troops are stationed, such as Afghanistan, after 7 years. Bezos said he doubts he'll do it because of their lack of factories.
The deal has also caused Amazon to shut down the United States Postal Service, forcing everything to be shipped through Amazon. This action has led to an extreme downfall in the junk mail industry, so Amazon customers should expect to see it inside their delivered boxes.
Bezos concluded the yacht interview by stating, "We're not too worried about what people may think, but keep in mind that we now own the Constitution". A recent poll following that statement showed that 73% of Americans feared the first amendment would be removed, 25% didn't have that fear, and 2% wrote in "Kanye West".
AmazonAmericabusiness
Social scientists recommend we adopt new conventions for greeting & parting 25 May 2021
Blubbering Donald Trump says he won't attend Joe Biden's inauguration 08 January 2021
Iranian government warns America against path of violence as angry US mobs riot, storm Capitol Hill, pillage and plunder 07 January 2021
Expert Says 2021 Could Be Worse Than 2020 04 January 2021
NFL Announce Name Overhaul Plan For 2021 03 January 2021
Amazon Clamp Down On Stupid Questions 01 January 2021
Santa Claus Told To Stay At Home This Christmas 01 December 2020
Every Presidential Poll Shows That President Trump's Ass is Toast 03 November 2020
Business Brief


Belmont School of Music alumnus Dr. Timothy Sharp was honored with the 2017 Encore Award last night, Tuesday, Sept. 12, on Belmont's campus.
Sharp is currently the Executive Director of the American Choral Directors Association (ACDA) and the Artistic Director of the Tulsa Ontario Chorus. Prior to his leadership of ACDA, Sharp served as the Dean of Fine Arts at Rhodes College in Memphis and previously served as Belmont's Director of Choral Activities. Additionally, he served as a Belmont faculty member and conducted Belmont Chorale and Oratorio from 1997-2000.
Sharp's research and writing focuses on conducting and score analysis, and his interests vary from regional music history to acoustics and aesthetics. He has experience conducting university, community, church and children's choirs, and he continues to serve as a choral conductor and clinician throughout the United States and internationally.
After the award presentation, Belmont Chorale performed under Sharp's arrangement of "When I Can Read My Title Clear" and "What a Wondrous Love is This," co-written with Wes Ramsay, under his direction. The program was an autobiographical description of his journey as a musician.
The Encore Award was created in 2008 to honor a School of Music alumnus for achievement in the field of classical music. Previous honorees include Clifton Forbis (2008), Daniel Weeks (2009), Drs. Daniel and Sharon Lawhon (2010), Maestra Teresa Cheung (2011), Dr. Alfredo Colman (2012), Travis Cottrell (2013), Greg Walter (2014) and Tina Milhorn Stallard (2015). The award presentation and performance are free and open to the public.