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Civil Recoveries for Victims of Criminal Acts*
Colleen Quinn
Criminal Courts alone do not provide a complete range of actions for criminal acts. With civil recoveries, you may be able to take more comprehensive actions to protect yourself and recover losses.
When the unthinkable happens and someone becomes a victim to a rape, sexual assault, battery or other crime of violence, justice is often sought through the criminal justice system. However, there is another important side to seeking justice beyond criminal sanctions and penalties against a perpetrator: the civil remedies that may be afforded to a victim of a crime of violence. Criminal penalties punish the perpetrator and often serve to protect society from further harm by placing the perpetrator in prison and, in some instances, rehabilitating the perpetrator. Also, sometimes the victim will receive some restitution from the criminal or a fund for crime victims. However, even when such restitution is available, it usually is insufficient compared to the injury the victim has suffered.
On the other hand, when available, the civil remedies for victims of criminal acts through a civil personal injury case can be far more substantial. In the short term, civil remedies provide a victim with compensation for medical and mental health bills, time lost at work, loss of future earning capacity, and funding for future care and treatment, as well as providing the victim the empowerment in holding the perpetrator accountable for his actions. Long term effects of seeking civil remedies often extend to the protection of future targets of sexual assaults and other incidents of violence through holding third parties responsible for their failure to prevent these often foreseeable crimes.
In evaluating whether a criminal act may have a civil tort recovery component, it is first important to understand that there are three basic components to any civil tort action: Liability, damages and collection. Additionally, proper preservation of evidence from any criminal case is critical to successful prosecution of a civil case.
I. Collection (Evaluating Sources of Recovery).
When evaluating a case, ideally start with assessing the third component: Collection. No matter how severe the damages and how clear the liability – if there are no assets worth pursuing and nothing to recover for the victim – then why bother?
Moreover, even when the perpetrator has significant assets – it is important to find out exactly what they are and how they are held. If they are held jointly (like with a spouse) or in a trust – then they probably are not going to be accessible. Also, even when there are available assets, and even if the perpetrator is enjoined by court order from dispensing with the assets, the assets often have a tendency to dwindle or dissipate prior to getting to a judgment or settlement. Thus, the best cases are the ones where insurance might be implicated.
Common sources of insurance include:
1. homeowner insurance coverage,
2. renter insurance coverage,
3. automobile insurance, and,
4. general liability coverage.
While homeowners and renters insurance may provide coverage in some cases, typically they will exclude intentional acts, punitive damages, and acts by others in the household. Automobile and general liability policies also typically exclude intentional acts. However, nearly all insurance policies will cover negligent or reckless acts. Accordingly, it is important to assess how the pleadings will be crafted and how the case facts might be presented to ensure coverage. Also, sometimes the way that the defendant answers the Complaint can ensure coverage.
By way of example, one case this author handled involved a female client sexually molested on an Amtrak train by a highly intoxicated passenger. The molester was arrested at the next stop and the victim had very visible bruise on her breasts and thighs which were photographed. A warrant was sworn out and the molester entered into a plea agreement. While it (a) appeared to be an intentional act and (b) appeared that the molester had no source of coverage, the case took two fortunate turns: the molester (a) had condominium coverage and (b) argued it was an accident – that the sudden jerk of the train threw him into the victim as he was walking by her seat. The case settled for a respectable sum.
II. Damages.
Pursuing civil actions arising out of criminal acts often can be difficult, so the next factor in evaluation is to determine the severity of the injury and the applicable damages. If the damages are not sufficient enough to warrant a decent recovery then there is not much incentive to pursue the case.
1. The damages prayed for should reflect significant injuries; alleging mere fear is insufficient.
2. Psychological or emotional damages must be supported by the testimony of medical professionals.
3. Damages also should include lost wages and earning capacity, medical bills, counseling bills, loss of household services and prescription and medication costs. The victim is also entitled to compensation for scars, disfigurement, disability and other permanent injuries or losses. If a victim is not already in mental health counseling, then counseling should begin immediately. Post traumatic stress disorder and many anxiety disorders are typical injuries to victims of crimes, but those disorders often go undiagnosed unless the victim is receiving treatment by qualified mental health professionals. Future treatment also should be assessed, as many victims will require future care for a significant period of time.
4. The lawsuit should allege severe violations and/or clearly unacceptable acts by a perpetrator of a crime of violence. These are cases that can lend to juror outrage. However, care must be taken in drafting the Complaint because, as previously noted, intentional acts and punitive damages may be excluded under some insurance policies.
III. Liability.
In determining liability, the civil causes of action often most appropriate for victims of sexual assault and other violent crime include:
i. Civil assault and/or battery against the perpetrator.
ii. False Imprisonment/False Arrest.
iii. Respondeat Superior/Vicarious Liability
iv. Negligent Hiring/Negligent Selection[1]
v. Negligent Retention[2]
vi. Inadequate or Negligent Security[3]
vii. Failure to Meet a Special Duty of Care
viii. Breach of Express Contract
ix. Negligent Supervision
x. Other Causes of Action
A. Assault & Battery
1. An assault may have occurred when the offending party's actions placed the victim in fear of imminent bodily harm,
2. Battery occurs in many situations where the offending party makes unwanted bodily contact with the victim to which the victim did not consent.
3. Assault & battery may be brought against a perpetrator of a sexual assault or other violent crime.
4. A battery also may apply in situations where a medical provider initiates an unwanted touching.
5. Most states recognize a civil cause of action for assault and battery. While this outline is based on Virginia law, much of the law is applicable across state lines and similar laws can be found in other states, with some variation among states. Virginia law has recognized distinct causes of action for sexual assault and battery.[4]
1. Kidwell v. Sheetz, Inc., 982 F.Supp. 1177 (W.D.Va. 1997) recognized both sexual assault and sexual battery as independent tort causes of action, however the Supreme Court of Virginia has never directly addressed and defined the torts of common law sexual assault or sexual battery.
2. Several published opinions by Circuit Courts in Virginia have recognized the separate cause of action, but there has been at least one published decision in the circuit court to reject the existence of sexual assault and battery as separate causes of action.[5]
3. As in the criminal law cause of action, there must be a threat of force, threat, or intimidation.[6] See N.G. ex rel. D.G. v. Schefer Circuit Court, 72 Va. Cir. 239 (2006), which took great care in recognizing the legitimacy of common law sexual assault and battery, stated that a plea of sexual assault or battery must include the existence of:
i. a legal duty,
ii. a breach of the duty,
iii. harm to the plaintiff, and
iv. a causal relationship between the breach and the damage.[7]
B. False Imprisonment/False Arrest
1. A victim of sexual assault also may bring an action for false imprisonment against a perpetrator of a sexual assault or assailant who committed another violent crime.
2. If the victim has had her freedom of movement restrained such that she reasonably believes force will be used against her should she not submit, and this leads her to submission, the victim will likely have a claim for false imprisonment.
3. The tort of false imprisonment requires unjustified restraint of liberty without any legal excuse. Neither actual force on the part of the perpetrator nor resistance on the part of the victim is necessary to make a showing of false imprisonment.
4. A showing of malice is required to recover punitive damages, but there is no requisite wrongful intention on the part of the perpetrator to recover general damages under false imprisonment.[8]
C. Respondeat Superior/Vicarious Liability
1. An employee, acting in the scope of his employment within the ordinary course of business, may cause his employer to be liable for his actions.
2. Actions taken by an employee are generally considered to be in the scope of employment unless:
1. The employee is acting outside of the scope of his agency, which is to say the actions were not directed, expressly or implicitly, by the employer or principal, or not naturally incident to the business, didn't further the employer's interest in any way, and didn't reflect a "great and unusual deviation from the employer's business."
2. The scope of employment may be interpreted fairly narrowly: for example, in Kensington Associates v. West, 234 Va. 430, 362 S.E.2d 900 (1987) the Supreme Court of Virginia held horseplay by a security guard who accidentally and recklessly shot a co-worker to be outside of the scope of employment. And in Webb v. U.S., 24 F.Supp.2d 608 (W.D. Va. 1998) the federal district court noted that "scope of employment" for a physician must be reasonably related to the treatment being provided. In this case, a woman seeking care for her panic attacks was being molested by her doctor. Her treatment did not call for any physical contact. The court ruled that the physician's employer could not be held liable because the touching was not within his scope of employment, i.e. related to the treatment.
3. However, the Virginia Supreme Court has held that a company whose gas station attendant jumped a counter to sexually assault a customer[9] and a firm whose therapist sexually assaulted a patient[10] were both responsible for their agent's actions, implicating the doctrine of respondeat superior.
4. Compare Davis v. Hairplus-Regis Corp., No. 4:10CV00039, 2011 WL 1428072, at *8 (W.D. Va. Apr. 14, 2011) in which the Federal District Court found that one co-worker was not acting within the scope of her employment when she physically attacked the plaintiff co-worker.
3. An employer is liable for an employee's tortious acts when the employee performs the employer's business and acts within the scope of employment when the acts are committed.
The burden of establishing an employment relationship is on the plaintiff, but as soon as the employment relationship is established between the employee and defendant employer, the burden of establishing that the employee was not acting within the scope of employment is on the employer. The question of whether an action took place within the scope of employment is one for the jury.[11] When determining whether an action is within or outside of the "scope of employment," the juror will look to factors such as:
1. whether the tortfeasor employee was performing employment duties,
2. whether he was executing the services for which he was engaged,[12]
3. whether the employee was acting to further the employer's interest or arises as a consequence of doing the employer's business,[13] and
4. whether the incident occurs in the place the employee carries on his duties.
The primary question is whether the service in which the tortious action took place is in the scope of the employment relationship.[14] In Gina Chin & Associates, Inc. v. First Union Bank, 260 Va. 533, 540, 537 S.E.2d 573, 576 (2000), the Supreme Court of Virginia, citing Davis v Merrill, 133 VA. 69, 112 S.E. 628 (1922), stated "it matters not whether the act of the servant is due to lack of judgment, the infirmity of temper, or the influence of passion, or that the servant goes beyond his strict line of duty and authority in inflicting such injury."
D. Negligent Hiring/Negligent Selection
1. The Supreme Court of Virginia first recognized negligent hiring as a cause of action in Weston's Adm'x v. Hospital of St. Vincent, 131 Va. 587, 107 S.E. 785 (1921), and was reaffirmed in J. v. Victory Tabernacle Baptist Church, 236 Va. 206, 372 S.E.2d 391(1988).
2. An employer has a duty to inquire as to the employee's "past record, habits, or general fitness for the position" of hire.[15]
3. This duty is breached if an improper person is hired for a position that involves an unreasonable risk of foreseeable harm to others.[16] Hiring an employee whose known propensities, or propensities that could be discovered on reasonable investigation, will likely be deemed negligent hiring or selection.
This rule was reinforced by the Supreme Court of Virginia in Interim Personnel of Central Virginia, Inc. v. Messer, 263 Va. 435, 559 S.E.2d 704 (2002). However, "[m]ere proof of the failure to investigate a potential employee's background is not sufficient to establish an employer's liability for negligent hiring." Id. at 440, 559 S.E.2d at 707. The victim-plaintiff in a negligent hiring case does have to show that an employer failed significantly to meet its duty of care in hiring. In Southeast Apartments Management, Inc. v. Jackman, 257 Va. 256, 513 S.E.2d 395 (1999), conducting a check on the perpetrator's references (the employer spoke with two of the six references provided) with positive feedback, but failing to conduct a criminal background check was insufficient to make out a prima facie case.
E. Negligent Retention
1. Closely related to the recognized cause of action for negligent hiring is the cause of action for negligent retention. The Supreme Court of Virginia first recognized negligent retention in Norfolk Protestant Hospital v. Plunkett, 162 Va. 151, 173 S.E. 363 (1934). However there was substantial debate whether the tort existed until 1999 when the Virginia Supreme Court handed down Southeast Apartments Management, Inc. v Jackman, 257 Va. 256, 513 S.E.2d 395 (1999) and definitively held that the cause of action existed. See also Phillip Morris Inc. v Emerson, 235 Va. 380, 401, 368 S.E.2d 268, 279 (1988).
2. The employer must have actual or constructive notice of an employee's misconduct and fail to exercise reasonable care to address the misconduct that causes injury to a victim.
3. In the context of an owner of leased premises, a landlord liable for negligent retention must be negligent in retaining an employee was is dangerous or may foreseeably cause harm to tenants or other potential victims, and this negligence must lead to actual injury or harm.
4. Actual notice of an employee's dangerous propensities and previous complaints about specific instances of assault has been sufficient to find negligent retention[17], but discovery that an employee engaged in passing bad checks, along with other "obnoxious" behavior was not.[18]
5. Sovereign immunity may protect municipalities and other government bodies from being sued on this theory. The Supreme Court of Virginia recognized this in Niese v. City of Alexandria, 264 Va. 230, 564 S.E.2d 127 (2002). Here the plaintiff sought to sue the city when it did not fire a police officer despite notice of his propensity for sexual assault.
Find Out More About Employment Law and Your Civil Rights Here
F. Inadequate Security (Negligent Failure to Protect/Negligent Failure to Warn)
1. Inadequate security, which may be pled as negligent failure to protect and/or negligent failure to warn, must arise out of a special relationship between the victim-plaintiff and defendant or between the third party criminal actor and the defendant, and that special relationship must create a duty of care. See Yuzefovsky v St. John's Woods Apartments, 261 Va. 97, 540 S.E.2d 134 (2001) and Wright v Webb, 234 Va. 527, 362 S.E.2d 919 (1987).
Generally, "a person does not have a duty to warn or protect another from the criminal acts of a third person." Id. For a court to impose a duty to warn of third-party criminal acts on a defendant, "a special relation [must] exist[ ] (1) between the defendant and the third person which imposes a duty upon the defendant to control the third person's conduct, or (2) between the defendant and the plaintiff which gives a right to protection to the plaintiff." Brown v. Jacobs, No. 140270, 2015 WL 798693, at *3 (Va. Feb. 26, 2015) (but finding special relationship did not exist). See also, Com. v. Peterson, 286 Va. 349, 360, 749 S.E.2d 307, 313 (2013) (Virginia Tech victim case where the Virginia Supreme Court held "[a]ssuming without deciding that a special relationship existed between the Commonwealth and Virginia Tech students, based on the specific facts of this case, as a matter of law, no duty to warn students of harm by a third party criminal arose") (good discussion and review of the law in this case).
1.The victim must show that:
i. A special relationship existed,
ii. That created a duty of care,
iii. The duty of care was breached, and
iv. The breach caused the harm complained of.
2. Parties that have a special, elevated duty of care include landlords, innkeepers, common carriers, hospitals, psychiatric institutions, nursing homes and schools.
3. Examples of third party liability arising out of special relationships include:
· the situation where a landlord has prior knowledge of a violent crime occurring on the property, fails to fix a broken lock despite the tenant's request, and the tenant falling victim to an assailant who accessed the door with the broken lock.
· a college or university who, having prior of a student's propensity to commit sexual assault, fails to expel the student, leading to a sexual assault being committed by that student.
· a nursing home or psychiatric ward whose agents have been put on notice that a resident had made sexual advances on another resident, but failed to take adequate precautionary measures before a sexual assault occurred. See Delk v. Columbia/HCA Healthcare Corp., 259 Va. 125, 523 S.E.2d 826 (2000).
· a common carrier (bus, plane, train, ship, etc.) continues to serve a passenger who is clearly drunk, and that passenger assaults another passenger.
· The owner of a "half-way house" for felons with regard to clients coming in. Dudley v Offender Aid & Restoration of Richmond, Inc., 241 Va. 270, 401 S.E.2d 878 (1991).
G. Breach of Express Contract
1. An express written contract may create a duty for crime prevention measures or protection. See Richmond Med. Supply v Clifton, 235 Va. 584, 369 S.E.2d 407 (1988). And sometimes the plaintiff can argue that she/he was an intended third party beneficiary. Levine v Selective Ins. Co. of America, 250 Va. 282, 462 S.E.2d 81 (1995); Wooldridge v Echelon Serv. Co., 13 Va. Cir. 323 (Arlington Cir. Ct. 1988). For more cases on the third party beneficiary assessment, see also Envtl. Staffing Acquisition Corp. v. B & R Const. Mgmt., Inc., 283 Va. 787, 789, 725 S.E.2d 550, 552 (2012) and Ogunde v. Prison Health Servs., Inc., 274 Va. 55, 59, 645 S.E.2d 520, 523 (2007).
2. Though breach of written contract creates the best cause of action for the plaintiff-victim, the victim also may be able to recover if an oral contract is breached.
3. The oral contract must be performable in one year under the Statute of Frauds, and the victim must make a good showing that an oral contract was indeed intended.
4. Where an agent of the owner of leased property promised to secure a tenant's door causing the tenant to become a victim of an attack, the landlord was held liable.[19]
H. Negligent Supervision
1. Whether this cause of action is recognized in Virginia and in other states is debated and evolving. The exact contours of the claim, and in what circumstances it would apply, are largely unknown due to a lack of established case law dealing with negligent supervision. In general, for there to be an actionable claim of negligence, including negligent supervision, the claim must contain a legal duty, a violation of that duty, and consequent injury.
2. In 2009, the Supreme Court of Virginia recognized a common law action in Kellermann v. McDonough for the negligent supervision of a child.[20] The court held that "when a parent relinquishes the supervision and care of a child to an adult who agrees to supervise and care for that child, the supervising adult must discharge that duty with reasonable care. However, such adult who agrees to supervise and care for a child upon the relinquishment of that care and supervision by the child's parent is not an insurer of the child's safety. Rather, the supervising adult must discharge his or her duties as a reasonably prudent person would under similar circumstances."[21]
3. However, the Supreme Court of Virginia also previously held in 1988 in Chesapeake & Potomac Telephone. Co. of Virginia v. Dowdy that an employer has no duty of reasonable care in supervision of an employee, even though the employer was on notice that stress and pressure were directly and adversely affecting the employee's physical condition.[22]
4. Before bringing a cause of action for negligent supervision, research the more recent circuit case decisions thoroughly and be sure to set out the allegations so as to more closely align with the Kellermann decision than the decision in Dowdy which has fairly distinguishable facts.
I. Other Causes of Action
1. Other causes of action may be brought in seeking compensation for a sexual assault or other violent crimes against a perpetrator or third party.
2. If an assault occurs within the course of employment, it may amount to unlawful sexual harassment under Title VII of the Civil Rights Act of 1964, as amended. When bringing an action under Title VII, the victim must file a complaint within 180 days with the Equal Employment Opportunity Commission.
3. If the assault or other violent crime involved the federal government or a federal government agent, the victim may bring an action under § 1983. In such a case, timely notice must be given under the Federal Tort Claims Act.
4. If a claim is brought against the Commonwealth, notice must be given under the Virginia Tort Claims Act, and the amount which the victim can recover is limited.
5. Claims involving city and county employees and entities have special six month deadlines (in Virginia), and municipalities often have immunity defenses at their disposal.
6. A negligence per se claim may be brought where a statute exists to protect a certain class of persons. See Va. Elec. & Power Co. v. Savoy Const. Co., 224 Va. 36, 39, 294 S.E.2d 811, 814 (1982). In Kaltman v.All Am. Pest Control, Inc., 281 Va. 483, 496, 706 S.E.2d 864, 872 (2011) the Virginia Supreme Court states: "[t]he elements of negligence per se are well-established. First, the plaintiff must prove that the defendant violated a statute enacted for public safety. MacCoy v. Colony House Builders, Inc., 239 Va. 64, 69, 387 S.E.2d 760, 763 (1990); Virginia Elec. & Power Co. v. Savoy Const. Co., 224 Va. 36, 45, 294 S.E.2d 811, 817 (1982). Second, the plaintiff must belong to the class of persons for whose benefit the statute was enacted, and demonstrate that the harm that occurred was of the type against which the statute was designed to protect. McGuire v Hodges, 273 Va. 199, 206, 639 S.E.2d 284, 288 (2007); Halterman v Radisson Hotel Corp., 259 Va. 171, 176-77, 523 S.E.2d 823, 825 (2000). Third, the statutory violation must be a proximate cause of the plaintiff's injury. Thomas v Settle, 247 Va. 15, 20, 439 S.E.2d 360, 363 (1994); Hack v Nester, 241 Va. 499, 503-04, 404 S.E.2d 42, 43 (1990)."
IV. Client Intake.
The initial steps in performing intake for a client that was or may have been a victim of sexual assault or another crime of violence should include:
1. ensuring the preservation of evidence,
2. encouraging the client to follow through with criminal charges if criminal proceedings have not already begun,
3. NOT signing up the client to bring a civil action (unless a statute of limitations is about to expire and the case must be filed) – this ideally should not be done until criminal proceedings are over. One reason, among others, is that the civil case could be a basis for the criminal defense attorney to impeach the client victim in the criminal proceedings. Instead, it is preferable to simply be retained as a legal consultant to the victim until the criminal proceedings are over,
4. preparing the client for being re-traumatized via bringing the criminal case and/or civil claim/lawsuit and ensuring therapists in place,
5. determining the client victim's past (oftentimes victims of sexual battery have prior incidents),
determining the sources of recovery,
6. assessing the damages and ensuring the client victim previously received and/or is now getting proper medical and mental health treatment, and,
7. evaluating liability – that is, what cause or causes of action are available for the client, and against whom (which defendants) the causes of action are available.
V. Preserving Evidence
1. Collecting and preserving evidence is crucial to a successful outcome in any civil action involving a criminal act. However, it also is important to stay out of the way of any investigators, detectives and prosecutors who are handling any related criminal case. Let them know of your role as a legal consultant to the victim and that you are available to assist in any way.
2. All potentially relevant evidence should be preserved. If a criminal case is underway then the evidence generally already is being preserved by the investigators and prosecutors involved. Once the criminal case is over, the prosecutor can be one of the most helpful individuals in providing information about the case and access to the evidence. However, where no criminal case is undertaken, the civil attorney needs to be integrally involved in gathering the evidence. The evidence to be gathered may include, but is not limited to, the following:
1. photographs of all physical injuries as well as the incident scene;
2. all clothing should be preserved;
3. the details should be written down or otherwise recorded as soon as possible after the incident;
4. the criminal case should be followed and a court reporter should be sent to the criminal hearings if the criminal proceedings are not already being recorded;
5. any police reports, EMT reports, 911 tapes, video tapes, and other incident reports or other records of the incident should be gathered via FOIA requests and later by subpoena if need be;
6. any involved law enforcement or emergency personal, and witnesses should be interviewed;
7. the perpetrator's background and criminal record should be investigated and discovered;
8. preservation or "no spoliation" letters should be immediately sent to any custodians of evidence (so long as they do not interfere with any pending criminal case).
If you're a victim of a criminal act and you want to find out more about protecting yourself and recovering losses through civil action, contact Locke & Quinn at 804-285-6253 or visit us online at lockequinn.com.
[1] J. v. Victory Tabernacle Baptist Church, 236 Va. 206, 372 S.E.2d 391(1988).
[2] See Apartment Mgmt. v. Jackman, 257 Va. 256, 513 S.E.2d 395 (1999) (recognizing cause of action but reversing case because employee had no prior convictions of prior behavior); Flanary v. Roanoke Valley SPCA, 53 Va. Cir. 134 (2000) (employer negligently continued to employ a male employee after being placed on notice of his dangerous propensities, and of prior incidents of specific assaults by him against the plaintiff).
[3] Yuzefovsky v. St. John's Woods Apartments, 261 Va. 97, 540 S.E.2d 134 (2001) (cause of action recognized, but claim rejected where landlord failed to provide adequate security in crime filled area). Brown v. Jacobs, No. 140270, 2015 WL 798693, at *3 (Va. Feb. 26, 2015).
[4] Kidwell v. Sheetz, 982 F. Supp. 1177 (1997).
[5] Flanary v. Roanoke Valley SPCA, 53 Va. Cir. 134 (1999).
[6] Kidwell, supra, 982 F.Supp. at 1185.
[7] Schefer Circuit Court, 72 Va. Cir. at 242.
[8] S.H. Kress & Co. v. Musgrove, 153 Va. 348, 356, 149 S.E. 453 (1929).
[9] Majorana v. Crown Cent. Petroleum Corp., 260 Va. 521, 526, 539 S.E.2d 426, 429 (2000).
[10] Plummer v. Ctr. Psychiatrists, 252 Va. 233, 236, 476 S.E.2d 172 (1996).
[11] Majorana, 260 Va. at 526.
[12] Plummer, 252 Va. at 236.
[13] Gina Chin & Assocs. v. First Union Bank, 260 Va. 533, 541, 537 S.E.2d 573 (2000).
[15] J. v. Victory Tabernacle Baptist Church, 236 Va. 206, 209, 372 S.E.2d 391 (1988).
[16] Se. Apartment Mgmt. v. Jackman, 257 Va. 256, 260, 513 S.E.2d 395 (1999).
[17] Flanary v. Roanoke Valley SPCA, 53 Va. Cir. 134 (1999).
[18] Jackman, 257 Va. at 261-62.
[19] J.W.S. v. Nusbaum Realty Company, et al, at Law No. 20338-RF (Newport News Cir. Ct. decided August 17, 1995).
[20] Kellermann v. McDonough, 278 Va. 478, 684 S.E.2d 786 (2009).
[21] Id. at 487, 684 S.E.2d at 790.
[22] Chesapeake & Potomac Tel. Co. of Va. v. Dowdy, 235 Va. 55, 365 S.E.2d 751 (1988).
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Roger Howe taught and did mathematics research at Yale University for over 40 years, until his retirement in 2016. He is now the William Kenan Jr. Professor Emeritus of Mathematics from Yale. Upon retirement from Yale, he accepted the position of Curtis D. Roberts Professor of Mathematics Education in the College of Education at Texas A&M University.
Dr. Howe served on a multitude of committees studying mathematics education, including several that produced major reports on mathematics education since 2000. He has reviewed texts and instructional materials for several publishers and curriculum developers. He served on the Committee of Education for the American Mathematical Society, the Steering Committee for the Park City/IAS Mathematics Institute, the U.S. National Commission on Mathematics Instruction (2006 - 2016), and on the Executive Committee of the International Commission on Mathematics Instruction (ICMI) (2010-2016). In 1997-98, Dr. Howe served as a Phi Beta Kappa Visiting Scholar. He is a member of the American Academy of Arts and Sciences, and the National Academy of Sciences. He is a Fellow of the American Mathematical Society, and received their Award for Distinguished Public Service in 2006.
Dr. Howe's mathematical research investigates symmetry and its applications. His work in mathematics education is directed towards clarifying the conceptual development of mathematical ideas through the K-12 curriculum. He has focused especially on place value, the role of word problems, and productive use of the number line.
Thank You for Your Outstanding Support of our Teachers!!!
Our sincere thanks to Olive Garden, Flint Family Foundation, Rib Crib, Oklahoma Society of Professional Engineers - Tulsa Chapter, and Tulsa Engineering Foundation for donating a meal or money to fund a meal to our math circle meetings over the last five years. We are very thankful for the continued support and the generous donations provided for our teachers by local restaurants and organizations!!!
The mission of the national Math Teachers' Circle (MTC) program, developed at the American Institute of Mathematics (AIM), is to establish the foundation for a culture of problem solving among middle school math teachers in the U.S. By fostering the confidence to tackle open-ended math problems, middle school teachers become better equipped to initiate more student-centered, inquiry-based pedagogies in their classrooms.
TMTC was the first math circle in Oklahoma with its inception in October, 2013. TMTC now averages 35 teachers at monthly evening meetings on a school night. TGMC, the first girls' math circle in Oklahoma, is now in its third year and averages 25 middle school girls on weekly evening meetings that run for six week stretches three times per year. Math Circles are thriving in Tulsa!
The Tulsa Math Teachers' Circle hosted its' inaugural meeting in October, 2013.
To provide guidance, materials, and resources to middle school math teachers that will enable them to promote open-ended problem solving as a way of learning, thinking about, and practicing mathematics in their classrooms.


This represents an opportunity to highlight another item: the fact that we now have an incidence of nulls appearing in the DataSet. The nulls did not exist before, because the DataSet did not extend to the lowest level. Relative to the example I highlight above (CDR Grape Jelly), nulls did not appear because the measures were rolled up to the next level of aggregation, and the nulls in one product were "buried" in the aggregate of the members of the Product Brand. As we have focused on a lower level, the empty cells (meaning no activity for the time period we are examining, naturally enough) show themselves. As I mentioned earlier, this is far more common in reality, where sparsity is typical and pervasive.
Nulls present challenges when we work with filters in our DataSets. We will encounter these in setting up our filters to meet the business requirements specified by the information consumers. It is for this reason that I am focusing upon an incidence of a null, so that we can achieve the tandem objective of exposing basic filter use, together with the management of nulls within our use of filters. We will return to this in short order.
For now, let's finish modifications to our report to enable the drill down that the consumers have requested - to the Product Name level. We know that the Product Name data now exists in the DataSet; next, we will make changes in the report layout to exchange the Product Name data for the Brand Name data that currently holds the lowest level in the physical drilldown.
When designing a report in Reporting Services, or any other enterprise reporting application, always focus on the complete DataSet first. Making sure you have all the data that the report will require - before beginning the physical construction of the report, and especially before investing time in formatting and the like - can save the hours of rework that is due upon those operating under the "I'll come back to that later" mentality.
12. Click the Layout tab to switch to the Layout view.
13. Widen the fourth column (both from left and right, and thus the middle column of the report) enough to expose the full expression in the textbox, =Fields!Brand_Name.Value, as shown in Illustration 22.
We must make modifications in a couple of places to exchange the expression we need to replace the Brand Name level with the Product Name level, to which the information consumers wish to be able to drill.
14. Click anywhere within the Matrix data region to activate the gray column and row headers.
15. Right-click the upper right corner of the Matrix data region.
16. Select Properties from the bottom of the context menu that appears, as shown in Illustration 23.
The Matrix Properties dialog - General tab appears, as depicted in Illustration 24.
17. Click the Groups tab, to access the first area we need to modify, the group that currently points to Brand Name.
18. Click the BrandSales_Brand_Name item that appears at the bottom of the Rows group list, as shown in Illustration 25.


text:
import os, sys
sys.path.insert(0, os.path.abspath(os.path.join(os.path.dirname(__file__), os.pardir)))

from module_name.a import is_valid_login # update accordingly

import hypothesis.strategies as st
from hypothesis import given, assume, settings, Verbosity

#@settings(verbosity=Verbosity.verbose)
@given(st.text(), st.text())
def test_is_valid_login(username, password):
    assert is_valid_login(username, password) is False

redpajama_set_name: RedPajamaGithub


text:
August 28, 2017	• 0
Exit Kid
Having recently released their debut EP, Exit Kid are ready to hit the studio for more tracks in between touring with their other band, Years & Years. Emre Turkmen and Dylan Bell make up the duo who have already released music videos for three of their tracks this year, starting with It's Cool back in April. We spoke to them about their EP, filming their music video and how the band started.
When and how did the idea of Exit Kid come about?
Needs must.
How did you come up with the name?
It was from a random band-name generator while waiting for a flight at Berlin airport (fact).
Does it feel strange not having Olly and Mikey involved?
It feels not strange because I made music by myself in a room before being in a proper band. My mum would try to come in and I'd scream for her to get out. Olly is my mum.
Can we expect to see any Exit Kid live shows?
Hope but don't expect. I'm not a natural performer, I'm afraid.
What instruments apart from drums and synthesiser can you both play?
Drums is all Dylan can play. Drums is the only thing I cannot play. (That's a lie, I'm shit on the oboe).
Tell us about your EP, 'Exit Kid'. What can people expect from it?
Expectation has always been overwhelming for me. So I wouldn't expect much if I were you.
How long did it take to produce your EP?
We operated on a song-a-day policy. So not long, really.
Do you have any more music being released soon?
I've got a whole bunch of songs written and (mostly) recorded but whether they'll ever escape my grasp we'll see.
What was it like filming the video for It's Cool in stop-motion?
Very, very fun. Although, Joe (the creator) probably had a more stressful time as it is a very laborious process. I have offered to be his assistant in Indiana USA if he gives me food and shelter. I found it very therapeutic.
Your music is very different to your other band, Years & Years, how would you describe this music?
Fuzzy and honest.
Did you know each other before Dylan started drumming for Years & Years?
No, we met through Rob, who directed our music video for the song Real. It was love at first sight.
What are the future plans for Exit Kid?
Exit Kid is your creepy uncle who left his wife, ran away with the au-pair and went on a crime spree in Texas before finally being apprehended in Mexico. No plans.
Follow Exit Kid on:
Follow Emre on:
Follow Dylan on:
Download Exit Kid's self-titled debut EP:
Categories: home, Interview, Music
Jonathan Raggett
Hamish Carter

redpajama_set_name: RedPajamaCommonCrawl


text:
Halloween Nights!
Reality Bites is a 1994 American romantic comedy-drama film  about people in their twenties. The plot is centered on Lelaina, an aspiring videographer working on a documentary called Reality Bites about the disenfranchised lives of her friends and roommates, and to a certain degree, about Lelaina herself.
The movie captured what it was like to be a Generation X in the 90's helped by a killer soundtrack. This design captured the teen angst with the qoute "I was really going to be somebody by the time I was 23" and the consumerism of the BIG GULP (which also acts as a reaction to the quote.)
Original design measures approx 10 x 14 inches on the front of the shirt.
High quality DTG (digital print) printed on white apparel.
DTG print ensures the detail of the illustration is transferred to the garment, and the color stays true to the original design.
For more information please check our sizing guide.
info@paper8apparel.com
4685 Hollywood Blvd, Los Angeles, CA 90065
© 2020 by Paper 8


At Ned Davis Research, we believe that successful investing is grounded in having the right perspectives. To do this, you need a clear view of the whole investment picture.
Our 360° approach offers a more complete investment picture by combining both fundamental and technical research from one provider. Fundamentals tell how the markets should be acting, while technicals reveal how markets are acting. Truly insightful and timely ideas demand a balance between the two disciplines.
The research landscape is becoming increasingly crowded. More than ever, investors are looking for ways to cut through the noise. In order to succeed, firms must identify new ways to examine the market from multiple perspectives. By providing research from the macro to the micro, Ned Davis Research provides a more complete investment picture.


text:
/*!
 * \file
 * \brief Sampler object state query tests
 *//*--------------------------------------------------------------------*/

#include "es31fSamplerStateQueryTests.hpp"
#include "glsTextureStateQueryTests.hpp"
#include "glsStateQueryUtil.hpp"
#include "glwEnums.hpp"

namespace deqp
{
namespace gles31
{
namespace Functional
{

using namespace gls::StateQueryUtil;
using namespace gls::TextureStateQueryTests;

static const char* getVerifierSuffix (QueryType type)
{
	switch (type)
	{
		case QUERY_SAMPLER_PARAM_FLOAT:
		case QUERY_SAMPLER_PARAM_FLOAT_VEC4:					return "_float";

		case QUERY_SAMPLER_PARAM_INTEGER:
		case QUERY_SAMPLER_PARAM_INTEGER_VEC4:					return "_integer";

		case QUERY_SAMPLER_PARAM_PURE_INTEGER:
		case QUERY_SAMPLER_PARAM_PURE_INTEGER_VEC4:				return "_pure_int";

		case QUERY_SAMPLER_PARAM_PURE_UNSIGNED_INTEGER:
		case QUERY_SAMPLER_PARAM_PURE_UNSIGNED_INTEGER_VEC4:	return "_pure_uint";

		default:
			DE_ASSERT(DE_FALSE);
			return DE_NULL;
	}
}

static bool isIsVectorQuery (TesterType tester)
{
	return tester == TESTER_TEXTURE_BORDER_COLOR;
}

static bool isExtendedParamQuery (TesterType tester)
{
	return	tester == TESTER_TEXTURE_WRAP_S_CLAMP_TO_BORDER ||
			tester == TESTER_TEXTURE_WRAP_T_CLAMP_TO_BORDER ||
			tester == TESTER_TEXTURE_WRAP_R_CLAMP_TO_BORDER;
}

SamplerStateQueryTests::SamplerStateQueryTests (Context& context)
	: TestCaseGroup(context, "sampler", "Sampler state query tests")
{
}

void SamplerStateQueryTests::init (void)
{
	using namespace gls::TextureStateQueryTests;

	static const QueryType scalarVerifiers[] =
	{
		QUERY_SAMPLER_PARAM_INTEGER,
		QUERY_SAMPLER_PARAM_FLOAT,
		QUERY_SAMPLER_PARAM_PURE_INTEGER,
		QUERY_SAMPLER_PARAM_PURE_UNSIGNED_INTEGER,
	};
	static const QueryType nonPureVerifiers[] =
	{
		QUERY_SAMPLER_PARAM_INTEGER,
		QUERY_SAMPLER_PARAM_FLOAT,
	};
	static const QueryType vectorVerifiers[] =
	{
		QUERY_SAMPLER_PARAM_INTEGER_VEC4,
		QUERY_SAMPLER_PARAM_FLOAT_VEC4,
		QUERY_SAMPLER_PARAM_PURE_INTEGER_VEC4,
		QUERY_SAMPLER_PARAM_PURE_UNSIGNED_INTEGER_VEC4,
	};

#define FOR_EACH_VERIFIER(VERIFIERS, X) \
	for (int verifierNdx = 0; verifierNdx < DE_LENGTH_OF_ARRAY(VERIFIERS); ++verifierNdx)	\
	{																						\
		const char* verifierSuffix = getVerifierSuffix((VERIFIERS)[verifierNdx]);			\
		const QueryType verifier = (VERIFIERS)[verifierNdx];								\
		targetGroup->addChild(X);															\
	}

	static const struct
	{
		const char*	name;
		const char*	desc;
		TesterType	tester;
		bool		newInGLES31;
	} states[] =
	{
		{ "texture_wrap_s",					"TEXTURE_WRAP_S",					TESTER_TEXTURE_WRAP_S,					false	},
		{ "texture_wrap_t",					"TEXTURE_WRAP_T",					TESTER_TEXTURE_WRAP_T,					false	},
		{ "texture_wrap_r",					"TEXTURE_WRAP_R",					TESTER_TEXTURE_WRAP_R,					false	},
		{ "texture_mag_filter",				"TEXTURE_MAG_FILTER",				TESTER_TEXTURE_MAG_FILTER,				false	},
		{ "texture_min_filter",				"TEXTURE_MIN_FILTER",				TESTER_TEXTURE_MIN_FILTER,				false	},
		{ "texture_min_lod",				"TEXTURE_MIN_LOD",					TESTER_TEXTURE_MIN_LOD,					false	},
		{ "texture_max_lod",				"TEXTURE_MAX_LOD",					TESTER_TEXTURE_MAX_LOD,					false	},
		{ "texture_compare_mode",			"TEXTURE_COMPARE_MODE",				TESTER_TEXTURE_COMPARE_MODE,			false	},
		{ "texture_compare_func",			"TEXTURE_COMPARE_FUNC",				TESTER_TEXTURE_COMPARE_FUNC,			false	},
		{ "texture_srgb_decode",			"TEXTURE_SRGB_DECODE_EXT",			TESTER_TEXTURE_SRGB_DECODE_EXT,			true	},
		{ "texture_border_color",			"TEXTURE_BORDER_COLOR",				TESTER_TEXTURE_BORDER_COLOR,			true	},
		{ "texture_wrap_s_clamp_to_border",	"TEXTURE_WRAP_S_CLAMP_TO_BORDER",	TESTER_TEXTURE_WRAP_S_CLAMP_TO_BORDER,	true	},
		{ "texture_wrap_t_clamp_to_border",	"TEXTURE_WRAP_T_CLAMP_TO_BORDER",	TESTER_TEXTURE_WRAP_T_CLAMP_TO_BORDER,	true	},
		{ "texture_wrap_r_clamp_to_border",	"TEXTURE_WRAP_R_CLAMP_TO_BORDER",	TESTER_TEXTURE_WRAP_R_CLAMP_TO_BORDER,	true	},
	};
	static const struct
	{
		const char* name;
		const char* desc;
		QueryType	verifier;
	} pureSetters[] =
	{
		{ "set_pure_int",	"Set state with pure int",			QUERY_SAMPLER_PARAM_PURE_INTEGER			},
		{ "set_pure_uint",	"Set state with pure unsigned int",	QUERY_SAMPLER_PARAM_PURE_UNSIGNED_INTEGER	},
	};
	static const struct
	{
		const char*	name;
		const char*	desc;
		TesterType	intTester;
		TesterType	uintTester;
	} pureStates[] =
	{
		{ "texture_wrap_s",					"TEXTURE_WRAP_S",					TESTER_TEXTURE_WRAP_S_SET_PURE_INT,				TESTER_TEXTURE_WRAP_S_SET_PURE_UINT					},
		{ "texture_wrap_t",					"TEXTURE_WRAP_T",					TESTER_TEXTURE_WRAP_T_SET_PURE_INT,				TESTER_TEXTURE_WRAP_T_SET_PURE_UINT					},
		{ "texture_wrap_r",					"TEXTURE_WRAP_R",					TESTER_TEXTURE_WRAP_R_SET_PURE_INT,				TESTER_TEXTURE_WRAP_R_SET_PURE_UINT					},
		{ "texture_mag_filter",				"TEXTURE_MAG_FILTER",				TESTER_TEXTURE_MAG_FILTER_SET_PURE_INT,			TESTER_TEXTURE_MAG_FILTER_SET_PURE_UINT				},
		{ "texture_min_filter",				"TEXTURE_MIN_FILTER",				TESTER_TEXTURE_MIN_FILTER_SET_PURE_INT,			TESTER_TEXTURE_MIN_FILTER_SET_PURE_UINT				},
		{ "texture_min_lod",				"TEXTURE_MIN_LOD",					TESTER_TEXTURE_MIN_LOD_SET_PURE_INT,			TESTER_TEXTURE_MIN_LOD_SET_PURE_UINT				},
		{ "texture_max_lod",				"TEXTURE_MAX_LOD",					TESTER_TEXTURE_MAX_LOD_SET_PURE_INT,			TESTER_TEXTURE_MAX_LOD_SET_PURE_UINT				},
		{ "texture_compare_mode",			"TEXTURE_COMPARE_MODE",				TESTER_TEXTURE_COMPARE_MODE_SET_PURE_INT,		TESTER_TEXTURE_COMPARE_MODE_SET_PURE_UINT			},
		{ "texture_compare_func",			"TEXTURE_COMPARE_FUNC",				TESTER_TEXTURE_COMPARE_FUNC_SET_PURE_INT,		TESTER_TEXTURE_COMPARE_FUNC_SET_PURE_UINT			},
		{ "texture_srgb_decode",			"TEXTURE_SRGB_DECODE_EXT",			TESTER_TEXTURE_SRGB_DECODE_EXT_SET_PURE_INT,	TESTER_TEXTURE_SRGB_DECODE_EXT_SET_PURE_UINT		},
		// \note texture_border_color is already checked
		// \note texture_wrap_*_clamp_to_border brings no additional coverage
	};

	// set_value
	{
		tcu::TestCaseGroup* const targetGroup = new tcu::TestCaseGroup(m_testCtx, "set_value", "Set value and query it");
		addChild(targetGroup);

		for (int stateNdx = 0; stateNdx < DE_LENGTH_OF_ARRAY(states); ++stateNdx)
		{
			// already tested in gles3
			if (!states[stateNdx].newInGLES31)
				continue;

			if (isExtendedParamQuery(states[stateNdx].tester))
			{
				// no need to cover for all getters if the only thing new is the param name
				FOR_EACH_VERIFIER(nonPureVerifiers, createSamplerParamTest(m_testCtx,
																		   m_context.getRenderContext(),
																		   std::string() + states[stateNdx].name + verifierSuffix,
																		   states[stateNdx].desc,
																		   verifier,
																		   states[stateNdx].tester))
			}
			else if (isIsVectorQuery(states[stateNdx].tester))
			{
				FOR_EACH_VERIFIER(vectorVerifiers, createSamplerParamTest(m_testCtx,
																		  m_context.getRenderContext(),
																		  std::string() + states[stateNdx].name + verifierSuffix,
																		  states[stateNdx].desc,
																		  verifier,
																		  states[stateNdx].tester))
			}
			else
			{
				FOR_EACH_VERIFIER(scalarVerifiers, createSamplerParamTest(m_testCtx,
																		  m_context.getRenderContext(),
																		  std::string() + states[stateNdx].name + verifierSuffix,
																		  states[stateNdx].desc,
																		  verifier,
																		  states[stateNdx].tester))
			}
		}
	}

#undef FOR_EACH_VERIFIER

	// set_pure_uint
	// set_pure_int
	for (int setterNdx = 0; setterNdx < DE_LENGTH_OF_ARRAY(pureSetters); ++setterNdx)
	{
		tcu::TestCaseGroup* const targetGroup = new tcu::TestCaseGroup(m_testCtx, pureSetters[setterNdx].name, pureSetters[setterNdx].desc);
		addChild(targetGroup);

		for (int stateNdx = 0; stateNdx < DE_LENGTH_OF_ARRAY(pureStates); ++stateNdx)
		{
			const TesterType	tester	= (pureSetters[setterNdx].verifier == QUERY_SAMPLER_PARAM_PURE_INTEGER)				? (pureStates[stateNdx].intTester)
										: (pureSetters[setterNdx].verifier == QUERY_SAMPLER_PARAM_PURE_UNSIGNED_INTEGER)	? (pureStates[stateNdx].uintTester)
										: (TESTER_LAST);

			targetGroup->addChild(createSamplerParamTest(m_testCtx,
														 m_context.getRenderContext(),
														 std::string() + pureStates[stateNdx].name,
														 pureStates[stateNdx].desc,
														 pureSetters[setterNdx].verifier,
														 tester));
		}
	}
}

} // Functional
} // gles31
} // deqp


text:
Steve Chabot, Troy Balderson Victorious as GOP Holds on to Ohio Congressional Seats
November 7, 2018 November 7, 2018 Anthony Accardi
While Republicans failed to hold control of the U.S. House of Representatives Tuesday night, nobody can say that Ohio Republicans didn't do their part. Republican Congressmen Steve Chabot, Troy Balderson, Dave Joyce and Mike Turner were all targeted for defeat by big-spending Democratic PACs and individuals. They failed to knock…
News2018 Congressional midterms, Dave Joyce, Ohio congressional races, Rep. Steve Chabot, Troy BaldersonLeave a comment
Commentary: The 'Sacred Walls' of Donald Trump
November 7, 2018 November 7, 2018 Ohio Star Staff
by Pedro Gonzalez With each step the "caravan of contradictions" takes toward our border, another progressive illusion slips away. Victor Davis Hanson considers this mob, and by extension the events surrounding it, a "paradox, a contradiction, and an irony." He's right. The "reasoning" of progressives that leads them to…
Commentary, News, UncategorizedCaravan, Immigration, Trump, WallLeave a comment
SHOCK: Medical Students' Surgical Abilities Declining Rapidly in a Growing Digital Age
by Annie Holmquist Whether it's for something as serious as cancer or as routine as a kidney stone, no one likes to hear that they have to go under the surgical knife. But such unhappy news is often lightened once a patient has the chance to talk to the surgeon…
News, UncategorizedHealthcare, medicine, screens, surgery, technologyLeave a comment
Amazon Silent on Reports It Will Split New Headquarters
Amazon isn't commenting on reports that it plans to split its new headquarters between facilities in two cities rather than choosing just one. The New York Times, citing unnamed people familiar with the decision-making process, said the company is nearing deals to locate in Queens in New York City and…
News, UncategorizedAmazon, headquarters, RelocationLeave a comment
Supreme Court Weighs Bid to Open Nation's Largest Uranium Mine
by Kevin Daley The U.S. Supreme Court weighed a bid to open the nation's largest deposit of uranium to mining Monday, which defense hawks say is essential to national security and crucial foreign policy objectives. The deposit, known as Coles Hill, sits in a small Virginia town called Chatham.…
News, UncategorizedJim Inhofe, Supreme Court, Ted Cruz, Tom Cotton, UraniumLeave a comment
Trump Administration Returns to Supreme Court, Seeking End to DACA
by Kevin Daley The Trump administration returned to the U.S. Supreme Court Monday night seeking to end the Deferred Action for Childhood Arrivals (DACA) program, an Obama-era amnesty initiative that extends protected status to illegal aliens brought to the U.S. as children. The move is aggressive and unusual, as…
News, UncategorizedDACA, Donald Trump, US Supreme CourtLeave a comment
Potential 'El Chapo' Jurors Excused for Safety Fears
Reuters The pool of potential jurors for the U.S. drug trafficking trial of accused Mexican drug lord Joaquin "El Chapo" Guzman continued to shrink on Tuesday, with two people who expressed fears about their safety and one self-described "fan" of the defendant cut from the running. A total of…
News, Uncategorizeddrug, El Chapo, Joaquin Guzman, kingpinLeave a comment
Ohio's Issue 1 Handed Resounding Defeat as Voters Balk at Letting Drug Felons Bypass Prison
Issue 1 went down in flames Tuesday as Ohio voters overwhelmingly decided they didn't want to change their state constitution in a way that binds the hands of judges in drug possession cases. With more than 90 percent of the precincts reporting, voters were crushing the ballot measure by a…
News2018 election Ohio, drug abuse, fentanyl, ohio issue 1, Opioid Addiction CrisisLeave a comment
Democrat Sherrod Brown Holds On to U.S. Senate Seat With Easy Win Over Jim Renacci
Democrat Sherrod Brown will remain Ohio's senior U.S. senator. Brown coasted to reelection to a third term over his Republican opponent, Jim Renacci, Tuesday night. The polls closed at 7:30 p.m. and by 8:13 all the major networks called the race for Brown. With nearly 2.2 million votes cast, Brown had tallied…
News2018 Midterm elections, Ohio U.S. Senate race, Rep Jim Renacci (R-OH-16), Sen. Sherrod Brown1 Comment
Mothers of Deceased Vets Fight to Keep Memorial to Their Sons in Supreme Court
by Jeremy Dys They came from many walks of life, the 49 boys of Prince George's County, Maryland. Several were laborers like George Washington Farmer and William Lee–one white, the other African-American. One, Ernest Pendleton Magruder, was a well-known surgeon. Another, Henry Lewis Hulbert, a Medal of Honor recipient…
News, UncategorizedConstitutional, Gold Star Mothers, US Court of Appeals, veteransLeave a comment
Michigan Judge Orders Food Stamp Fraudsters to Write Publicly About Their Crimes
November 7, 2018 November 7, 2018 Anna Marie Bolton
U.S. District Judge Avern Cohn ordered four Bangladeshi brothers convicted of scamming Michigan and American taxpayers out of millions of dollars in food-stamp benefits to write about it in a local newspaper. Cohn ordered the men to run an ad admitting to their crimes, and pay for it themselves. "To…
Battleground States, News, Uncategorizedfood stamps, Immigration, MichiganLeave a comment
GOP Sweeps Statewide Offices as Mike DeWine Wins Governor's Race Over Richard Cordray
Republican Mike DeWine cruised to victory over Democrat Richard Cordray Tuesday and Republicans swept every statewide office on the Ohio ballot, including secretary of state, attorney general, state auditor and treasurer. All of the congressional races thought to be up for grabs, or at least competitive, also went to Republicans…
News2018 election, Mike DeWine, Ohio Gubernatorial Race, Richard CordrayLeave a comment


text:
COVID-19 Update in India
Photo Courtesy of The New York Times
The unloading of oxygen tanks, a big necessity right now in hospitals in India.
Shelby Summerhays, Staff Writer
As of Tuesday, May 4, 2021 India has officially recorded 20 million Covid-19 cases. Within the last two weeks there have been more than 300,000 new cases reported. Overall, there have been a total of 220,000 deaths.
Freshman, Broderick Harrison said, "I find this news very sad and hope India gets help very soon."
The most impacted areas have been very poor areas, specifically in eastern regions such as Uttar Pradesh and Bihar. A professor of biostatistics, at the University of Michigan, who has been studying the Covid-19 outbreak in India for over a year, reported that, "Right now we estimate that the total number of deaths could be two to five times more, and the total number of infections could be 15 times more."
Many countries have been accused of downplaying the amount of deaths that have occurred due to the pandemic, especially India because throughout the country people's death registrations are incomplete.
Health expert Gautaum Menon, reported, "In the second wave, many of the deaths have happened outside health care facilities and hospitals. Many have died in ambulances and bodies burning on pyres outside crematoriums and even on pavements across cities and towns are not factored. These deaths are seldom recorded."
A virologist, Jacob John, stated, "Because death registration is poor in India, the government will have little data to respond to the impact of Covid-19 on large sections of the population who live in the rural areas."
Since a majority of deaths have not been reported through a registration system, the government has been unable to determine the best relief measures that need to be taken. Alta Loma Student, Janelle Rodriguez said, "This is devastating and hopefully a solution to this problem can be found."
In this drastic time, there is hope that cases will lower down and help will be provided to the cause. Hoping that numbers of those infected lowers to the 0%.
Shelby Summerhays, Entertainment & Style Editor
How are you ending the school year?
Russo-Ukranian War Update: Mariupol Falls
Guatemala Bans Same-Sex Marriage and Limits Abortion Rights
Teacher Beaten by Special Needs Kindergarten Student
North Korea vs South Korea
Road Rage in New Jersey
Elon Musk buys Twitter
Ancient Hebrew Tablet Found
Sacramento Mass Shooting
Transgender Restrictions in Iowa Cause Tension Among Students
Gas Prices On The Rise
All Brave Times Picks Reader Picks Sort: Newest


text:
Fintech: Bahrain's Banking Industry Remains Focused on Adopting Innovative Financial Technologies, According to Local Investment Professional
10 May 2020 /Market Updates, Regulatory News /by Razan Salman
David Parker, co-chief investment officer at the Bahrain Economic Development Board (an organization responsible for attracting inward investment into the Kingdom for key areas such as technology development and supporting the local financial and banking industry), recently confirmed that the country aims to position itself as the "startup capital" of the world.
https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg 0 0 Razan Salman https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg Razan Salman2020-05-10 10:02:032020-06-09 10:04:49Fintech: Bahrain's Banking Industry Remains Focused on Adopting Innovative Financial Technologies, According to Local Investment Professional
UAE, Bahrain, and Namibia sign MoU on AML/CFT
31 January 2020 /Market Updates, Regulatory News /by Razan Salman
The Central Bank of the United Arab Emirates ('UAE') announced, on 29 January 2020, that the UAE Financial Intelligence Unit ('FIU') had signed a Memorandum of Understanding ('MoU') on anti-money laundering and countering the financing of terrorism ('AML/CFT') with the Financial Investigation Department in the Kingdom of Bahrain and the Financial Information Center for the Republic of Namibia.
https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg 0 0 Razan Salman https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg Razan Salman2020-01-31 10:15:442020-06-09 10:18:27UAE, Bahrain, and Namibia sign MoU on AML/CFT
Global trade growth to lose momentum in 2019: WTO
8 April 2019 /Market Updates, Regulatory News /by Razan Salman
World trade will continue to face strong headwinds in 2019 and 2020 after growing more slowly than expected in 2018 due to rising trade tensions and increased economic uncertainty, said the World Trade Organisation (WTO).
https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg 0 0 Razan Salman https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg Razan Salman2019-04-08 09:36:492019-04-08 09:36:49Global trade growth to lose momentum in 2019: WTO
Fintech 'will help improve financial health of people in Gulf'
25 March 2019 /Market Updates, Regulatory News /by Razan Salman
FinTech will radically improve the financial health of the people of the Gulf through access to next-generation banking services, says Simon Galpin, managing director of Bahrain Economic Development Board.
He was speaking at Finnovex ME 2019, a one-day conference on financial innovation and excellence, held in Dubai.
https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg 0 0 Razan Salman https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg Razan Salman2019-03-25 11:00:532019-03-25 11:00:53Fintech 'will help improve financial health of people in Gulf'
Cyber Risks Threaten Physical Security, Industrial Controls
Cyber risk management should go beyond IT-specific concerns like malware, firewalls, and virus scans.
"What are we doing to protect ourselves from cyberattacks?"
It's a question every CFO eventually asks their team.
Although the question suggests IT-specific concerns like malware, firewalls, and virus scans, CFOs need to pause and broaden their perspective, examine cyber-related business risk in the areas of physical security and in industrial controls as well.
https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg 0 0 Razan Salman https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg Razan Salman2019-03-19 12:05:252019-03-17 11:18:51Cyber Risks Threaten Physical Security, Industrial Controls
Payment Alternatives Fuels 25% Retail Spending Rise
A new study from Juniper Research has identified a range of strategies for payment providers to deploy if they are to maximise their opportunities across both the offline and online space.
The research found that retail spend is expected to increase by $6 trillion globally between 2018 and 2023 (taking total spend to $30 trillion), with growth driven by a combination of alternative payment mechanisms (most notably wallets) and online spend.
https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg 0 0 Razan Salman https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg Razan Salman2019-03-17 10:43:112019-03-17 10:43:11Payment Alternatives Fuels 25% Retail Spending Rise
Blockchain 'can help build GCC green energy sector'
Blockchain has the potential to develop new renewable energy markets and play a game-changing role in helping the GCC energy sector transition to a more secure, resilient, cost-effective, and low-carbon grid, according to Booz Allen Hamilton, a global management and IT consulting firm.
https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg 0 0 Razan Salman https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg Razan Salman2019-03-10 10:01:482019-03-10 10:01:48Blockchain 'can help build GCC green energy sector'
Bitcoin Regulation: Bahrain Unveils Preliminary Regulatory Sandbox for Cryptocurrency Companies
5 March 2019 /Market Updates, Regulatory News /by Razan Salman
Bahrain is the next country in the Middle East that appears set to adopt cryptocurrency. Top government officials say the nation wants to become a hub for Bitcoin and other iterations emerging technology in the region. Thus, there are plans to institute a trial operational framework for cryptocurrency companies in Bahrain while regulators attempt to draft robust regulations for the emerging asset class.
https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg 0 0 Razan Salman https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg Razan Salman2019-03-05 09:53:222019-03-05 09:53:22Bitcoin Regulation: Bahrain Unveils Preliminary Regulatory Sandbox for Cryptocurrency Companies
SWIFT to open KYC Registry to corporates
17 February 2019 /Market Updates, Regulatory News /by Razan Salman
SWIFT, the world's leading provider of secure financial messaging services, has announced that it will open its world-leading Know Your Customer platform, The KYC Registry, to corporates.
https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg 0 0 Razan Salman https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg Razan Salman2019-02-17 12:45:222019-02-17 12:45:22SWIFT to open KYC Registry to corporates
The coming wave of data privacy compliance challenges
31 December 2018 /Market Updates, Regulatory News /by Razan Salman
Forget Bitcoin. The most common and profitable "virtual currency" today is personal data.
It is no small paradox that social media users—and there are billions of them globally—are willing to share the most intimate details of their life online, yet balk at the suggestion that those details will likely be shared and sold. The economic reality, however, is that data collection and analytics is, in large part, how giant tech companies have continued to grow and prosper.
https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg 0 0 Razan Salman https://kpmglearninghub.com/wp-content/uploads/2017/06/cert-logo.jpg Razan Salman2018-12-31 15:40:002018-12-31 15:40:00The coming wave of data privacy compliance challenges


text:
King Solomons Lodge 17, Woodbury – Jerry Dougherty
Woodbury, in Litchfield County, is located in west-central Connecticut along the Pomeraug River. Formerly Pomperaug Plantation, the area was settled in 1659 and Woodbury was split off and named as a town in 1673. The Pootatuck path (an early Native American trail), crossed what is now Woodbury's Main Street. The area was named Woodbury in recognition of its function as a "dwelling place in the woods." An early agricultural community, today Woodbury is known for its Colonial-era homes and antiques.
More on Woodbury from the CT Digital Archive
Browse more interactive content on the CT Digital Archive website.
Leroy Anderson Composed Iconic Music in Woodbury
Leroy Anderson, a long-time resident of Woodbury, was one of... …[more]
"Old Woodbury Historical Society," 2017. Link.
"The Glebe House Museum & The Gertrude Jekyll Garden," 2017. Link.
"Broadside - List of Certified Cowards in Woodbury!: As Per Surgeon's Certifiacates [Sic]," 1863. Connecticut Historical Society, Connecticut History Illustrated. Link.
"Map - South Part of Litchfield Co., Connecticut from Page 214 & 215 of Town and City Atlas of the State of Connecticut." Real Property. Boston, MA: D.H. Hurd & Co., 1893. University of Connecticut Libraries, Map and Geographic Information Center - MAGIC. Link.
Fagan, L. "Map of the Town of Woodbury, Litchfield County, Connecticut." Philadelphia, PA: Richard Clark, 1853. Connecticut History Online, Connecticut Historical Society. Link.
"Photograph - Mitten Owned by the Leatherman," ca. - 1889 1858. Connecticut History Online, Connecticut Historical Society. Link.
"Photograph: Glebe House, Birthplace of the Episcopal Church in the United States, Woodbury," ca. - 1899 1890. Connecticut Historical Society, Connecticut History Illustrated. Link.
"Print: View of Woodbury, Conn., from Castle Rock." Case & Green, ca. - 1856 1831. Connecticut Historical Society, Connecticut History Illustrated. Link.
Connecticut State Library Digital Collections. "Woodbury - WPA Architectural Survey," 2013. Link.
"Woodbury Collection." Connecticut Digital Archive, n.d. Link.
Chesson, Frederick. Around Woodbury. Charleston, SC: Arcadia, 2000.
Cothren, William. History of Ancient Woodbury, Connecticut, from the First Indian Deed in 1659. Waterbury, CT: Bronson Brothers, 1854. Link.
J.W. Lewis & Company. History of Litchfield County, Connecticut, with Illustrations and Biographical Sketches of the Prominent Men and Pioneers. Philadelphia, PA: J.W. Lewis & Company, 1881. Link.
Homes of Old Woodbury: Tercentenary Celebration of Old Woodbury, Connecticut. Salem, MA: Higginson Book Company, 2010.
Stiles, Dan. Town of Woodbury, Connecticut. Concord, NH: Sugar Ball Press, 1959.
Old Woodbury Historical Society, and Tony Wrenn. Woodbury, Connecticut: A New England Townscape. Washington, DC: Preservation Press, National Trust for Historic Preservation, 1975.
Find Woodbury
Daniel Curtiss: The Life of a 19th-Century Self-Made Man
Oxford: From Paths to Pikes
Early Church Bell Founders
Over Time: Woodbury's Historical Population
More about Woodbury


Now we have said that the last toothway to New Jerusalem had failed; and if you do not recall this matter, we will refresh you here.
And of course we have told how Hank Makeway came to the gums of Kailani Tate and cleansed them; here.
And the clarification, here, and the first tooth, here, and the error, here and here.
Now the goddess asks Hank a difficult question: how can he challenge her to assert her own great worth, when he knows—as her maker—that she hath not the strength for that assertion?
She asks him in bleakness; but his answer shall be craft… .
Under the weight of her attention, the horses shy.
The toothway goddess stares into the horses' souls. She sees herself in wine-dark shades embedded in their fires. Their shape is internal to her own; to ride the horses' path is to travel her own road, and enter New Jerusalem.
She gives the most tenuous murmur of consent.
Hank leads the horses to the left edge of Kailani's mouth. He puts one hand on each of the horses' backs.
"You may still refuse," he tells the goddess.
So Hank nods. "Here," he says.
In this process the smith takes part; horses are wise, but they have not the vision to bind a goddess to her self-conceit, nor do they have a smith's invariance of purpose. Hank is integral to the transformation, as much a beginning and ending to the young goddess' road as the horses or the gums.
The world twists in on itself. It rushes through him, until his skin and his teeth are alive with the waves of the horses and the goddess-mind. The knot pulls tight and the mortal consciousness of Hank Makeway dissolves to foam. Only a rootless remnant of attention remains, grasping desperately in the darkness for anything that shines.
The knot pops from the thread.
Something grasps for its name, uncertain if it is horse, smith, or toothway. An intolerable pressure of ignorance builds up before at last its mind gasps, Henry.
He surges up to his feet.
"Are you all right?" he says.
"Is this New Jerusalem?" she asks.
Skeptically she defocuses her perception of him.
For a long moment Hank simply contemplates his finished task; and there is love and joy burning in him like a fire.
Then he shakes himself free of the mood and takes up again the burdens of a smith.
The truth of the road has been defined, and the truth of its purpose; but there are three months, at least, of detailing work to go.
Hank walks up and down the ways. Flesh-Ripper plants the last teeth of the lower jaw, and Crust-Cruncher of the roof. Hank and the goddess clean and sort the threads of Kailani's destiny and make a cavity-retardant shell for all her teeth.
Sometime near the end of this the yearning for completion becomes a wistfulness.
It is hard for a smith to let a toothway go; and harder for a toothway to surrender its smith.
But inevitably they reach the point where they can no longer find any little piece of work un-done; and with a last bittersweet polishing of the enamel, Hank Makeway declares his mission closed.
"You're as right a road as ever made by smith," he says.
Numinous in the mouth of Kailani Tate the goddess contemplates herself; and like the seraphim she finds it just.
There is the lightest tone of teasing in her voice, and Hank sticks out his tongue before returning to his camp.
"Want the horses?" he says.
So he pats Flesh-Ripper on the neck and he sets Crust-Cruncher loose. He gathers up the material implements of his craft and he cooks his last meal in Kell's gums.
It will be four years before the main teeth come in and the standards will call this toothway safe; but Alaia is an impatient god. The first pilgrims and daredevils are riding through before Hank's even packed his bags.


text:
using namespace Tiny;

#include <string>
#include <list>
#include <unity.h>
#include "bourne/json.hpp"

void test_ComputerSet__class_is_assigned_from_json()
{

    bourne::json input =
    {
        "_class", "hello"
    };

    ComputerSet obj(input.dump());

    TEST_ASSERT_EQUAL_STRING("hello", obj.getClass().c_str());

}

void test_ComputerSet_busyExecutors_is_assigned_from_json()
{
    bourne::json input =
    {
        "busyExecutors", 1
    };

    ComputerSet obj(input.dump());

    TEST_ASSERT_EQUAL_INT(1, obj.getBusyExecutors());

}

void test_ComputerSet_displayName_is_assigned_from_json()
{

    bourne::json input =
    {
        "displayName", "hello"
    };

    ComputerSet obj(input.dump());

    TEST_ASSERT_EQUAL_STRING("hello", obj.getDisplayName().c_str());

}

void test_ComputerSet_totalExecutors_is_assigned_from_json()
{
    bourne::json input =
    {
        "totalExecutors", 1
    };

    ComputerSet obj(input.dump());

    TEST_ASSERT_EQUAL_INT(1, obj.getTotalExecutors());

}

void test_ComputerSet__class_is_converted_to_json()
{

    bourne::json input =
    {
        "_class", "hello"
    };

    ComputerSet obj(input.dump());

    bourne::json output = bourne::json::object();

    output = obj.toJson();

    TEST_ASSERT(input["_class"] == output["_class"]);

}

void test_ComputerSet_busyExecutors_is_converted_to_json()
{
    bourne::json input =
    {
        "busyExecutors", 1
    };

    ComputerSet obj(input.dump());

    bourne::json output = bourne::json::object();

    output = obj.toJson();

    TEST_ASSERT(input["busyExecutors"] == output["busyExecutors"]);

}

void test_ComputerSet_displayName_is_converted_to_json()
{

    bourne::json input =
    {
        "displayName", "hello"
    };

    ComputerSet obj(input.dump());

    bourne::json output = bourne::json::object();

    output = obj.toJson();

    TEST_ASSERT(input["displayName"] == output["displayName"]);

}

void test_ComputerSet_totalExecutors_is_converted_to_json()
{
    bourne::json input =
    {
        "totalExecutors", 1
    };

    ComputerSet obj(input.dump());

    bourne::json output = bourne::json::object();

    output = obj.toJson();

    TEST_ASSERT(input["totalExecutors"] == output["totalExecutors"]);

}


text:
uMkhumbane_Cato Manor_Heritage Place- Africa Architecture Award 2017 Grand Prix Winner
February 15, 2017 /0 Comments/in ARCHITECTURE, culture, regenerative design, Township economic, urban /by Rod Choromanski
Project by the Architecture Department,eThekwini Municipality and Choromanski Architects
Black Africans came to settle in Cato Manor during the 1920s, and rented land from Indian market gardeners who occupied the area since the early 20th century, as the apartheid system restricted settlement in the city.
Cato Manor covers a geographical area of approximately 1800 hectares and is situated approximately 7 kilometres from Durban's City Centre. It is currently the home to an estimated 93 000 people who settled in the area through mass invasions in the late 1980's and early 1990's.Cato Manor had been left vacant since the 1950's and 1960's following apartheid forced removals of an estimated 150 000 people. Today, Cato Manor residents include some of the poorest of the urban poor, despite the successes of the EU funded Cato Manor Development Association (CMDA) programme.
The area remains characterised by a high unemployment rate and social fragmentation. At the same time, Cato Manor residents are increasingly taking the initiative in the development of the area and there is a high level of community organisation, citizen action and participation. The Cato Manor Area Based Management (ABM) Unit of the Municipality seeks to work with these strengths and build on post-infrastructure development and consolidation processes such as social upliftment, responsibility and cohesion; community planning and participation; economic development and skills development.
The city's Economic Development Unit together with Parks Recreation and Culture and the CMDA identified Cato Manor as an ideal location to develop The "uMkhumbane Heritage Site ", to preserve the areas rich cultural and political history and stimulate innovation. The site at the confluence of two major arterials is crossed by the uMkhumbane River and included in the Durban Metropolitan Open Space System (DMOSS) and in close proximity to mixed residential areas, businesses and the University of KwaZulu-Natal (UKZN).
The first project reports responding to the heritage project were compiled in 2003 and an architectural competition by the City Architects laid the foundation for the appointment of the professional team. A master plan created by Choromanski Architects, incorporated the vision of the "uMkhumbane Heritage Site " which compliments the Cultural Renaissance Programme of the eThekwini Municipality, and includes the following:
a cultural park and public square,
galleries for permanent collection on forced removals, focusing on the struggle by women and children and temporary collections,
dedicated space for community exhibitions,
gathering areas for oral, performance, installation exhibits,
social gathering areas for functions, eg. book launches, festivals (film, writers, poetry, dance, music)
concession areas including traders market stalls,
theatre as multipurpose space,
children' innovative facilities,
linking of the development to tour routes through the community and surroundings areas, thereby extending the innovative entrepreneur spirit from the "uMkhumbane Heritage Site " through Cato Manor and Surroundings
Funding for this project was initially provided by Lotto who together with the city stimulated momentum for the development, which was complimented by the donation of land for the site by the UKZN.
This site on the banks of the uMkhumbane River is also especially significant as it was chosen by the Zulu King, Goodwill Zwelithini for the reburial
of the remains of his late mother in May 2011,Queen Thomozile Jezangani KaNdwandwe Zulu,who passed on in December 1959
A process of co-creating regenerative and enabling systems, where the project serves as a catalyst within its immediate environment, creates structure to enable the health of the surrounding community and natural environment. The activation of a neglected apartheid buffer zone along the uMkhumbane River to become a Heritage and Innovation Site
Creating new unique African Identity and Brands towards stimulation of a Township Economy
South Africa has a very wealthy history that is only now being appreciated for its complexity and diversity…"
http://www.sahistory.org.za/places/cato-manor
https://en.wikipedia.org/wiki/Cato_Manor
http://www.durban.gov.za/City_Government/Administration/Area_Based_Management/Cato_Manor/Pages/default.aspx
http://durbanhistorymuseums.org.za
Tags: Architecture design, Architecture South Africa, visual
https://choromanski.com/wp-content/uploads/2017/02/uMkhumbane_Museum_metal_screen.jpg 2049 1537 Rod Choromanski http://www.choromanski.com/wp-content/uploads/2013/08/logo.gif Rod Choromanski2017-02-15 22:27:032018-04-04 13:52:33uMkhumbane_Cato Manor_Heritage Place- Africa Architecture Award 2017 Grand Prix Winner
Music Construction
African Architecture Awards Countdown - Day 10
African Architecture Awards Countdown - Day 2
Warrior Architect Zaha Hadid The Rivertown Beerhall & Milne Drain Public Space – UIA 2014 congress,legacy...


Is headache become your every day's problem? Have you taken many sick & unplanned leaves in your office or school due to headache/ migraine? Pathetic! What is a role of ringwood osteopathy or how will you manage the migraine? First of all, know what is migraine? And are you suffering from migraine?
What is the difference between migraine and headache? A headache cerebral pain is brought about by emotional changes in the veins in the neck that supply blood to the mind. And, Osteopath in Croydon can be beneficial in each of this situation. A Migraine is a difficult and some of the time impairing cerebral pain, which commonly impacts one side of the head and can be joined by a tactile cautioning sign through the thoughtful sensory system that may incorporate expanded affectability to light or sound, obscured vision and shivering in the arms and legs, which can last from two hours to four days.
It's a medicinal practice dependent on a medication free non-obtrusive manual treatment. As a way to deal with human services, it accentuates the job of the musculoskeletal framework in the upkeep of ideal wellbeing and the counteractive action and treatment of sickness. It is supported by a rationality of the body as an interrelated unit of structure and capacity. Adjustment in the structure of the body prompts diminished or weakened capacity in its organs and tissues. Pay slowly develops until the body is unfit to oblige more change, at which time it might separate at the weakest part, even subsequent to something very insignificant.
Osteopathy can have a major effect to a long haul neck issue and ease a migraine, even ones that have been troublesome for a considerable length of time. A medicinal history and osteopathic examination can find issues in the body and keep an eye on spinal arrangement. Treatment is then gone for improving arrangement, solid lopsided characteristics and stance.
Numerous individuals experience the ill effects of cerebral pains and headaches, regularly for a long time without finding an answer. An extensive extent of these individuals additionally resort to cerebral pain pills and headache safeguards which can develop worry inside the stomach related tract, for example, the liver and stomach.
The 'mechanical' reasons for different sorts of cerebral pain are much of the time neglected. Strong strain in the neck and shoulders can be a central point and is frequently the hidden reason. This is typically an indication of a joint issue in the neck that makes interminable strong strain and can without much of a stretch form into an out and out cerebral pain. A past filled with neck torment is normally additionally present. Stress and tiredness can likewise be a factor however this is bound to prompt a cerebral pain when there is a basic issue in the neck which has never been dealt with.
Go through ringwood Osteopathy Company to get relief from the headache or migraine issue. I hope, you like this guide and will pass on to your friends & family for the right treatment.


text:
Graduate SchoolAboutUnion RepresentationUnion Representation FAQBackground Information
What is a "union" and a "bargaining unit?"
What does a union do?
Have some Cornell employees elected union representation?
What is Cornell Graduate Students United (CGSU)?
Did Cornell ever have an election for union representation of graduate students?
Where can I read the August 23, 2016 National Labor Relations Board decision, including the majority and dissenting opinions?
1. What is a "union" and a "bargaining unit?"
A labor union is an organization that represents a specific group of employees and acts as their exclusive bargaining representative. This specific group of employees is called a "bargaining unit".
Prior to determining who will participate in an election regarding union representation, the members of the potential bargaining unit must have enough in common that they are deemed to share a community of interest in wages, benefits, and other working conditions, for example police officers or skilled trades workers.
2. What does a union do?
A union, as a group of employees' exclusive bargaining representative, negotiates on behalf of the bargaining unit with the employer regarding terms and conditions of employment, such as pay and benefits.
3. Have some Cornell employees elected union representation?
Yes, Cornell University has a long and effective history of relationships and productive negotiations with unions representing Cornell staff. Defined groups of our employees belong to seven (7) unions, such as building trades, police, heating and water filtration plant employees, custodians, and food service staff. See all union contracts.
4. What is Cornell Graduate Students United (CGSU)?
At Cornell, a group of graduate students formed Cornell Graduate Students United (CGSU), which is a group of graduate students interested in achieving labor union representation for graduate assistants. CGSU affiliated with the American Federation of Teachers (AFT)/New York State United Teachers (NYSUT) as the unions to represent a potential bargaining unit for graduate assistants should a union representation election occur and the outcome is in favor of union representation.
Because of the interest of CGSU/AFT/NYSUT in seeking a labor union representation election at Cornell, the University entered into a Union-University Conduct Rules and Recognition Election Agreement (U-UCRREA) with CGSU/AFT/NYSUT in May, 2016, covering rules and procedures for union-university conduct and pre-election activities with provisions that would guide a union representation election should federal labor law allow student assistants at private universities the right to collectively bargain, as the August 23, 2016 decision of the NRLB established.
The U-UCRREA is not recognition of a graduate assistant labor union; rather, it is a guide to behaviors for all parties, based on the principle of fostering an open and respectful environment in which graduate students are free to learn about the labor union and reach an informed decision should there be an opportunity for them to participate in a union representation election.
Under the U-UCRREA, the potential bargaining unit at Cornell would include all Ithaca and Geneva campus-based graduate students enrolled in the Graduate School who hold appointments under University Policy 1.3 as teaching assistants, graduate assistants, research assistants, and graduate research assistants.
5. Did Cornell ever have an election for union representation of graduate students?
Yes, twice.
In October, 2002, a group of Cornell graduate assistants defined similarly as above (teaching assistants, graduate assistants, research assistants, graduate research assistants) participated in a union representation election. The end result was that the overwhelming majority of graduate assistants voted against union representation at Cornell.
In 2002, the graduate assistants interested in union representation formed the Cornell Association of Student Employees (CASE) and affiliated with the United Auto Workers (UAW).
An ad hoc graduate student organization, At What Cost? Cornell, formed to express opinions questioning the benefits of union representation.
Election results from October, 2002:
88% of graduate assistants on the bargaining unit eligibility list voted in the election.
2,318 graduate students were eligible to vote in that election.
2,049 ballots (88% of eligible voters) were cast.
1,351 (66%) voted against union representation.
580 (28%) voted in favor of union representation.
118 ballots were voided and not counted due to irregularities
In March, 2017, a secret ballot election was held to determine if CGSU/AFT/NYSUT would serve as the exclusive collective bargaining representative for Cornell University Graduate Assistants on the Ithaca and Geneva campuses who hold titles under University Policy 1.3.
As in 2002, an ad hoc graduate student organization, also with the name At What Cost formed to express opinions about CGSU/AFT/NYSUT's union campaign.
In the March '17 election, about 80 percent of eligible voters cast ballots, with 919 voting against representation by CGSU/AFT/NYSUT, 856 voting for representation by CGSU/AFT/NYSUT, and 81 ballots unresolved (challenged) based on questions of voter eligibility.
Although neither the University nor CGSU/AFT/NYSUT have asked the Arbitrator overseeing the election process to resolve the challenged ballots, the most likely outcome of such a process, given the current margin, would be a majority of those who voted decided against the formation of a union.
CGSU/AFT/NYSUT retains the right to seek a future election whether the March '17 election remains unresolved or if it is formally determined that the majority of graduate students voted against unionization. Cornell is currently negotiating with CGSU/AFT/NYSUT for an updated pre-election agreement building off of the May 2016 Agreement (PDF) signed by both parties to provide parameters for a mutually respectful relationship through another union campaign and election should CGSU/AFT/NYSUT file another election petition.
6. Where can I read the August 23, 2016 National Labor Relations Board decision, including the majority and dissenting opinions?
The full text of the NLRB decision can be found on the Union Representation page.
Go to main Table of Contents
History of Graduate Study at Cornell
General Committee Roster
Doctoral Experience Survey
GPCI Initiative – Spring 2018
Union Representation
Union Representation FAQ
Election Process and Status
Eligible Voters and Voting
Contracts, Dues, and Eligibility
Conduct During an Election
Special Considerations for Cornell Students
Examples of Graduate Student Unions
Communications and Resources
Alumni Newsletter Spring 2019
Plant Breeding Graduate Student Wins 2019 3MT
Longtime Big Red Barn Manager Retires
Grants Help Graduate Students Do Research Around the World
Alumna Addresses Importance of Mentoring
Using Stories Toward Greater Inclusion
Carriage House to Student Center: The Big Red Barn Over the Years
Changing Your Fixed Mindset into a Growth Mindset
Alumni Newsletter Fall 2018
Alumni Newsletter Winter 2018
President Martha Pollack Q&A
The Gratitude Project
The Student Partner Career Fair


The US Department of Defense (DoD) announced Nov. 20 the transfer of five detainees from the detention facility at Guantánamo Bay. Three are being transferred to the country of Georgia, while Slovakia has accepted the transfer of two more detainees. In 2009 the Guantanamo Review Task Force, composed of six agencies, approved the transfers after considering factors such as security issues. Congress imposed restrictions on dozens of approved releases, including prohibiting any detainees from being sent to the US, but many restrictions were relaxed last December. A total of 143 prisoners remain at Guantanamo, and 74 of these have also been cleared for a future transfer.
Reuters reported May 5 that Russian pipeline monopoly Transneft stopped diesel shipments to Ukraine and Hungary last month "due to uncertainties over the pipe's ownership," with the Ukrainian prosecutor's office filing a claim of ownership over the Soviet-era duct. We are actually asked to believe that the stoppage is "unrelated to the Ukraine crisis." Meawnhile, Voice of Russia reports that Hungary is stepping in as the protector of minorities in the Zakarpatie region of western Ukraine (also rendered Transcarpathia). These are principally the ethnic Hungarians and the Rusyns (also rendered Ruthenians). The regional parliament, the Hungarian-Rusyn National Congress, is now seeking autonomous legislative powers under a proposed "Transcarpathian Regional Confederation of the Hungarian and Rusyn People." While ethnic Hungarians are considered a "national minority" in Ukraine, the Rusyns do not have such status, according to Denis Kiryukhin of the Kiev Center for Political Studies and Conflictology. "Problems with the Rusyns have come up for several years already," Kiryukhin said. "That is the only ethnic minority in Ukraine, which Kiev has always refused to acknowledge. The relations between Rusyns and Ukrainians have been complicated and remain such to date." Despite the fact that Ukraine does not recognize dual citizenship, Budapest has started issuing passports to residents of Zakarpatie—an open affront to Kiev.
The US Department of Defense announced Jan. 1 that three Uighur Muslim detainees were transferred to Slovakia from the Guantánamo Bay military prison. The detainees, Yusef Abbas, Saidullah Khalik and Hajiakbar Abdul Ghuper, were the last three members of the Chinese ethnic minority being held at the facility since their 2001 capture in Pakistan. US District Court Judge Ricardo Urbina declared in 2008 that the detention of the Uighurs was unlawful, though the US has delayed their release to find a country that would accept them. Pentagon spokesperson John Kirby called the transfer "a significant milestone in our effort to close the detention facility at Guantanamo Bay."


The ESSA process in Wisconsin was a sham from the start.
State Superintendent Tony Evers' recent submission of Wisconsin's plan to the U.S. Department of Education sets the direction of education policy in the Badger State for years to come. Unfortunately, the state plan, a requirement under the new federal law, the Every Student Succeeds Act (ESSA), fails to take any serious action on low-performing schools and forgoes opportunities to improve K-12 schools in Wisconsin. It needs to be amended.
The 2015 passage by Congress of the Every Student Succeeds Act was a bipartisan effort to overhaul federal education law. Instead of dictating from Washington D.C., as No Child Left Behind did, ESSA allows states to decide the details of policies such as school report cards and intervening in low-performing schools. Lawmakers hoped states would use federal Title I dollars to innovate and enact bold reforms. Sadly those hopes have been dashed in Wisconsin.
The ESSA process in Wisconsin was a sham from the start. Evers and the Department of Public Instruction convened an "Equity in ESSA" council to give direction to the state plan. But the council was advisory only with no voting power. Evers made it clear that he would be making the decisions unilaterally.
Some in the state Legislature, such as Reps. Jeremy Thiesfeldt and Ron Tusler, pushed back against Evers, arguing that DPI should not be given the unchecked ability to write K-12 education policy. Unfortunately, too many Republicans in the Legislature were willing to abdicate their law-making authority to a government agency.
The flawed process resulted in the flawed plan submitted last Monday. Unlike other states, Wisconsin's plan takes a pass on opportunities to innovate with greater discretion over the use of federal Title funds. This ignores the wishes of over 300 Wisconsin school district superintendents and school board members who recently indicated a desire for greater control over how federal funds are spent, according to a new survey by the Wisconsin Policy Research Institute.
In the plan, low-performing schools face no sanction or reform but are instead asked only to craft "improvement plans" and engage with families and the local community. With as many as 55 public schools, if not more, across Wisconsin possibly labeled low-performing under ESSA, students deserve more than mere engagement with the community.
Other states have taken a different route, using ESSA to enact significant reforms in K-12 education. Florida is incentivizing successful charter school operators to open schools in areas with low-performing public schools. New Mexico will be taking significant action on their bad schools including forced closure or charter school conversion. Indiana will explore replacing school leadership.
None of this should be surprising. Evers has a bureaucrat's mindset, unable to make the difficult decisions that would rock the establishment boat. For example, Evers has refused to take any significant action on Wisconsin's failing public schools. This is so even though state law and previously, No Child Left Behind, empowered him to do so.
So what could happen next? Gov. Scott Walker refused to sign the state plan, blasting it for doing "little to challenge the status quo." Nonetheless, all signs indicate that U.S. Education Secretary Betsy DeVos will approve Wisconsin's state plan. After that, DPI will have to follow state law in implementing the plan which includes adhering to the rule-making process. Failure to do so could result in litigation, which the Wisconsin Institute for Law & Liberty and Wisconsin Manufacturers & Commerce previously warned Evers about.
The state Legislature still can have its say. Legislators should explore ways to amend and improve the state plan. The parts that require rule-making will go to legislative committees for approval, which ought to result in rigorous scrutiny.
With more than 50,000 students attending failing schools, a graduation rate hovering around 60% in Milwaukee, and one of the nation's highest racial achievement gaps in Madison, Wisconsin cannot afford to settle for more of the same.
C.J. Szafir is vice president for policy and deputy counsel, Wisconsin Institute for Law & Liberty, a conservative law and policy center based in Milwaukee.