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Top Townley Sexual Harassment Lawyers - Alabama
Nearby Cities: Jasper, Fayette, Haleyville, Adamsville, Warrior
Related Practice Areas: Wrongful Termination, Defamation, Employment, Employment Law -- Employer
Wrady & Michel, LLC
Sexual Harassment Lawyers Serving Townley, AL (Assisting Clients Across)
Assisting Alabama clients with Sexual Harassment Claims. Call us TODAY for a Free Consultation!
At the employment law firm of Wrady & Michel, LLC, we are advocates for employees in the Birmingham metro area and throughout Alabama. Our goal is to effectively resolve disputes of all kinds, including those involving discrimination, sexual harassment, whistleblowers, workers' compensation, retaliation, wage and hour, and violations of the Fair Labor Standards Act. Aggressive Advocates For...
Law Office of Melvin Hasting
Sexual Harassment Lawyers Serving Townley, AL (Cullman)
When people in Cullman County, Alabama, suffer personal injury, our team at the Law Office of Melvin Hasting is committed to helping them pursue financial justice. We pride ourselves on providing our clients with small firm attention; however, we aggressively advocate on clients' behalf and will not back down when facing large firms, corporations or insurance companies. Sometimes accidents just...
Winston Cooks, LLC
Sexual Harassment Lawyers Serving Townley, AL (Birmingham)
We Know Your Rights. We Can Help. Based in Birmingham, the law firm of Winston Cooks, LLC, is dedicated to representing the rights of employees throughout Alabama and across the U.S. We believe that every employee deserves fair treatment and fair wages, and we are willing to confront the most imposing corporations in order to uphold our clients' rights. Since our firm was founded in 2006, we...
Sheffield and Lentine, P.C.
At Sheffield and Lentine, P.C., we are dedicated to zealous and professional representation of those accused of serious felony and misdemeanor offenses in all municipal, state and federal courts of Alabama. The trial is not always the end for our clients and our firm has extensive experience in helping clients with direct appeals from convictions and Rule 32 Petitions for Post-Conviction Relief....
The Patton Firm
Dedicated to representing people who have been wronged, The Patton Firm advocates for clients in Birmingham and Jefferson County, Alabama. The team at this law firm takes on personal injury, workplace discrimination and workers' compensation claims. Combining more than 40 years of courtroom experience, they have appeared before the Alabama Supreme Court and in several appeals courts. Winning a...
The Bloomston Firm
The Bloomston Firm is committed to the defense of individuals facing loss of rights and freedom due to felony and misdemeanor charges. We have a reputation for success in criminal defense built on years of trial experience in Alabama courts. We are known to be tireless litigates, dynamic trial lawyers and successful gaming law lawyers. We will fight for the best possible outcome in every...
The Hawkins Law Firm
Sexual Harassment Lawyers Serving Townley, AL (Arab/huntsville)
The Hawkins Law Firm offers a full range of legal services to help our clients with the legal matters that affect them the most. Our law firm has office locations in Arab, Alabama, and in Huntsville, Alabama. From our office in Arab, we serve individuals, families and businesses throughout Marshall County and the surrounding areas with the high-quality, dependable representation they need when...
Strawn & Robertson, LLC
Sexual Harassment Lawyers Serving Townley, AL (Gadsden)
At the Gadsden, Alabama, law office of Strawn & Robertson, LLC, we serve clients in the areas of personal injury, workers' compensation, employment law and bankruptcy. We accept cases in Etowah County, the surrounding counties and all of east Alabama. Our team brings more than six decades of passion for the law to the table. We have experience in a wide range of personal injury matters,...
Morris, Cary, Andrews, Talmadge & Driggers, LLC
Sexual Harassment Lawyers Serving Townley, AL (Montgomery)
From our office here in Montgomery, Alabama, the law firm of Morris, Cary, Andrews, Talmadge & Driggers, LLC, is devoted to helping you and your family with the dire consequences you undoubtedly face in the aftermath of catastrophic injuries. Our law firm endeavors to provide you with aggressive counsel and highly personalized service as we work with you to pursue the compensation you need and...
Anderson, Williams, & Farrow, L.L.C.
When Attorney Charles L. Anderson established the Anderson Law Firm, L.L.C., in 1997, it was his intention to provide legal services for the small businesses and middle-income individuals who are often overlooked by the legal profession. Attorney Charles L. Anderson received his law degree from the Cumberland School of Law at Samford University in Birmingham in 1985,and has served clients in...
John A. Tinney, Attorney at Law
Sexual Harassment Lawyers Serving Townley, AL (Roanoke)
At the Roanoke law office of John A. Tinney, we have more than 40 years of experience resolving legal challenges of all types and all sizes throughout Alabama. If it's important to you, it's important to us. We don't turn down cases because they are too big. Our experience, our skill and our resources allow us to take on the most complex cases. In fact, we are the law firm other law firms often...
Need help with a Sexual Harassment matter?
You've come to the right place. Whether you are an employee or student victimized by unwanted verbal or physical conduct of a sexual nature, a sexual harassment lawyer can help.
Sexual harassment lawyers can advise you on key steps to take to avoid continued harassment, and decide whether a lawsuit is necessary in your case.
Use FindLaw to hire a local sexual harassment lawyer to help recover damages from retaliatory discharge or other disparate treatment.
Need an attorney in Townley, Alabama?
Use the contact form on the profiles to connect with a Townley, Alabama attorney for legal advice.

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 Елсниц (Ерцгебирге), град је у њемачкој савезној држави Саксонија
 Елсниц (Фогтланд), град је у њемачкој савезној држави Саксонија

redpajama_set_name: RedPajamaWikipedia


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New Netflix no 1 is streaming site's latest true crime documentary
Joe Harker
Published 20:26, 12 January 2023 GMT
| Last updated 20:26, 12 January 2023 GMT
Warning: Spoilers for The Hatchet Wielding Hitchhiker below
Netflix fans are watching documentary The Hatchet Wielding Hitchhiker in their droves and have made it the most popular show on the streaming service.
It tells the story of Kai, real name Caleb McGillvary, a hitchhiker who shot to internet fame after smashing a man over the head with a hatchet in 2013 in order to save a woman.
His declaration of 'smash, smash, smash' launched him to viral fame which led to an appearance on The Jimmy Kimmel Show and people from all over the world wanting to get to know Kai.
What at first looks like the story of a man finding fame and fortune after going viral soon spirals down a dark path as Kai's behaviour takes several strange turns.
The Netflix documentary shows how Kai soon goes from a heroic hitchhiker who saved a woman and is being considered as a candidate to be given his own TV show to someone who can't be controlled by those around him.
Kai's 'smash, smash, smash' made him famous, what followed next is covered by the documentary. Credit: Netflix
The trailer for the show warns 'if you're going to glorify someone, you better know who you glorify' and the following events prove those words very true indeed, so you might want to duck out now unless you're fine with spoilers.
The documentary shifts sharply in tone for Kai as just months after securing his viral fame he was arrested for the murder of a 73-year-old man.
From there The Hatchet Wielding Hitchhiker delves into the true crime genre as those around Kai begin to wonder if the warning signs were there from the start.
Kai starts the story as a 24-year-old homeless man who had managed to stumble into fame by being in the right place, he ends it arrested for the murder of New Jersey attorney Joseph Galfy.
He spent over five years in jail before he ended up going to trial in 2019, where he was found guilty of first degree murder and sentenced to 57 years in prison.
The Hatchet Wielding Hitchhiker delves into true crime. Credit: Netflix
The hitchhiker claimed that he had been drugged and raped after being offered a place to stay for the night, and claimed he was acting in self defence, though the jury did not believe his version of events.
Kai must serve 43 years of his sentence before he is allowed the possibility of parole, meaning it will be many decades before he could possibly return to the outside world.
He attempted to appeal his verdict by claiming there were numerous instances of misconduct and arguing that his defence counsel was ineffective, but a judge quashed Kai's appeal in 2021.
The Hatchet Wielding Hitchhiker is available to stream now on Netflix.
Featured Image Credit: Netflix
Topics: Netflix, TV and Film, True Crime
New Netflix Documentary About Polygamous Cult Branded Its 'Most Traumatising' True Crime Series Ever
Netflix Is Releasing A Documentary About Jimmy Savile Next Month
Is 'I Just Killed My Dad' on Netflix based on a true story?
New True Crime Series Tells Story Of Man Who Was Abducted As Kid Before Brother Became Serial Killer
Harrowing story of 'Charlie No-Face' who suffered horrifying injuries and 'glowed green'
Man issues warning after finding horrifying trap on dog walk


Basically, we just need a large size and a thumbnail size for each image. I believe you should be able to do all of this through the "batch" process.
Thank you for your bids and please let me know if you have any questions. I'll send winner the link for download.
Am online.... Shall do it for a good review! Thanks!


With a $44 return on each $1 dollar spent, it's an easy decision that email promoting is a savvy marketing methodology for each one of your customers.
With regards to finding new clients and marketing to the existing ones, email can be more compelling than social networking. Getting new clients through email marketing has quadrupled since 2009 and now consists of about 7.5 percent of all achieved clients, as per a current report from Custora, a New York City-based marketing analytics firm.
If your business isn't taking advantage of email marketing yet, you could be passing up a major opportunity for pulling in new clients.
We as a whole know that current email marketing is non-debatable with regards to having a booming inbound marketing system. In any case, before you can reveal a trickle or launch a campaign, the principal thing on a digital advertiser's list must be the laborious errand of making sense of which email customer you will run with to make, house, and send your messages.
There's a ton of things to consider while picking the correct email marketing platform. All the various services offer diverse features and functionalities. No two stages are the same, regardless of whether they all offer similar services.
Here are a few things to consider while picking an email marketing platform for your B2B prospecting.
In my opinion, the factor functionality is the most critical thing to consider while opting for an email marketing service. You need an email platform that can perform. Some services just do the essentials, for example, planning and sending. Different platforms enable you to make incredibly robust and automated campaigns.
Here are a few highlights to search for while assessing email marketing platforms.
When constructed right, automated email campaigns perform better, while saving on time. Even automated campaigns expand relevancy. The reason is based on the grounds that the campaign sets off a particular email to a particular beneficiary as an outcome of a particular action. Everything is custom-made to that one beneficiary, instead of a shower splash-and-spray approach.
Automated assistants – Autoresponders are date-based activated email campaigns. That date could be a birthday, an anniversary, x-measure of days after purchase or may a range of different occasions. Autoresponders are exceptionally effective, particularly when combined with personalization.
Drip Campaigns – These are automatic email series. Drip campaign can be as simple as conveying a progression of timed emails after an event happens. They can likewise be as strong as to convey the series of messages based on a series of activities. These activities work with if/then proclamations and an extensive variety of triggers can be utilized. Email click-through is one of the more common automated triggers.
Data Merging – Data merging pulls information from a field in the mailing list. The most generally utilized data merging is pulling the primary name. This is really good in terms of adding a personal vibe to the campaign. Anything that is contained in the database can be utilized as a part of a data merge. The arrangements with the best data consolidation abilities will likewise have rationales to show something particularly if the field is vacant.
Restrictive/Variable Content – Conditional content can be utilized to demonstrate various versions of the email based on set criteria. The dynamic areas of the email can be worked along with static segments. Custom content works with the if/then statements. It could either be founded on data in a mailing list field, or various different conditions, for example, connections with past campaigns.
The email campaign creator is another imperative component. What's essential in an email designer may differ from business to business. It will likewise differ in view of how complex the campaigns will be.
A small Ma and Pa shop may go for something more fundamental and intuitive, while a venture level organization may look for better customizability.
Module Designer/ WYSIWYG – WYSIWYG is the acronym for "What You See Is What You Get". This portrays visual editors, contradicted to having totally code your email campaigns. All email showcasing stages have WYSIWYG, yet some are superior to others. Numerous email marketing stages have additionally embraced module creators. With a module designer, you're ready to move to different segments. This makes it simple to oversee segments, and a few modules making it simple to include media, for example, YouTube recordings, etc.
HTML/Code Designer – Many email marketing platforms additionally offer an HTML creator. This is ideal for those that need more prominent control over the outline of the email pamphlets. If you don't know HTML and want to learn it, this most likely isn't an essential component.
Layout Library – The format library may be an essential component for a few people, and less for others. This all depends whether the organization wants to utilize a solitary outline style or the extensive variety of them. It may likewise rely upon the planned capacity of the organization, and regardless of whether they'd want to outline everything from the beginning or not.
Intuitive/Ease Of Use – The instinct of the campaign designer and creator is imperative. This is particularly valid in case you're anticipating planning considerable measure of sending and investing a great deal of time at this stage. Elusive areas and unrequested clicking just not only wastes time but can also be disappointing.
Picture Import/Hosting – How simple it is to include pictures in email marketing is something which very often companies don't consider. It's helpful when you can transfer pictures onto the email marketing stage. Else, you'll need to have them on your site or another site. In case you will utilize a colossal library of photographs and would prefer not to have them yourself, ensure the stage will supply enough disk space to help you with your necessities.
I would have said deliverability is the most vital thing, but, to a great extent, almost all organizations at all considerable stages try to maintain deliverability levels. So despite the fact that it's imperative unless you're partnering with a shady organization, everything ought to be practically right. It's likewise vital to recognize what you're in charge of as an email marketer, for example, content, outline design, bounce rate management and limiting spam dissensions.
Here are a few highlights you should search for in an email marketing platform.
Spam Score Checker – A spam checker is an imperative element to have. These apparatuses will examine your email campaign before you send them out. They'll search for plan components that may trigger the spam channels. Spam checkers will likewise give you data on the best way to enhance your deliverability. Checker will search for spammy catchphrases, content to image proportion and etc.
Spam/Bounce Management – You'll need an email marketing platform that will naturally expel serious spam complaints and hard bounces. Continue sending messages that bounce and to beneficiaries who have noted you as spam is one of the most noticeably awful things you could do.
Engagement Analytics – You'll need to screen your mailing list for engagement and rinse clients that never associate with your messages. They either have definitely no interest or no longer utilize that email handle. Great email suites will give you a chance to fragment recipients who haven't been engaged with quite a while and delete them.
Data stands to be extremely critical. It's the manner by which you section campaign, customize messages and make your messages pertinent. With a specific end goal to have the best email marketing, you require a stage that enables you to get the most out of your data. That is the reason list segmentation and management is intensely vital.
You can consider the below features while assessing an email marketing platform for list administration.
Fragmenting your list enables you to send applicable offers to the only the required individuals. The exact opposite thing you need to do is shell your beneficiaries with messages they're not intrigued by. That is the thing that makes individuals to unsubscribe or terrible, hit the spam button. Dividing your list guarantees you are sending the correct messages to the right individuals.
Most platforms support list division. Some are more dynamic than others, in any case. For instance; some only let you section by database fields, while with others you can fragment based on the passed campaign. Utilizing Opened as a trigger on a comparable campaign is an awesome method to guarantee you're just sending to those genuinely intrigued by that kind of message.
The capacity to amass contacts is essential. Regardless of whether there's a grouping feature, label highlight or something comparable. Once in a while, a group may comprise of an entire pack of individuals with demographics and psychographics. It is extremely unlikely you could get that correct group through division. These groups may be a piece of a particular club, level of participation, all were a piece of the same eighth-grade math class, the list goes on. Having the capacity to assemble contacts enables you to construct and keep up your own custom divisions.
All the best email marketing stages will take into consideration custom fields. A few stages take into account a restricted measure of custom fields. If you have a considerable measure of database handle, this may be an issue. This is particularly valid if that information would have been utilized for division or personalization.
The analytics and announcing is another critical thing to consider while picking an email marketing stage. All email arrangements will do campaign reporting. Some are more powerful than others.
Here are a few things to search for while picking your email advertising stage.
You'll need an email marketing stage that gives all of the campaign measurements you'd expect; opens, clicks, forwards, bounces, replies, etc. Basically, every email stage will give that. It's likewise decent to have the capacity to know what geographics the messages are being opened in, what time of days it mobile or desktop and the list goes on. The more campaign reports and benchmarking you have it's better.
Great email marketing stages will likewise give detailed data on the individual beneficiaries. A few locals will even venture to attach details to the beneficiary to empower effective marketing. This may be from an area acquired by means of reverse-ip query or through new data got from a campaign, site or application. Certain stages will give you a look at all the passed communications that have been had with the beneficiary. Some will likewise synchronize with CRM frameworks.
It's critical to be able to share and offer the data for the rest of the organization. Not every person will have the need to login to the email marketing account with so as to check details. That doesn't mean they would prefer not to be informed of the adequacy of the marketing endeavors. A decent email marketing platform will enable you to send out reports, regardless of whether it's a PDF, .csv record, shareable URL or something unique.
This is getting into the marketing automation side of things, and something that is considerably more important for B2B than it is for B2C. The more advanced email marketing platforms will enable you to score leads based on communications. Some might even give web-based solutions enabling you to include web analytics into the lead-scoring process. If B2B prospecting is critical to your organization, this may be a component to search for.


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590 F. 2d 1310 - Spartus Corporation v. S/s Yafo Zim Israel Navigation Company Ltd
590 F2d 1310 Spartus Corporation v. S/s Yafo Zim Israel Navigation Company Ltd
SPARTUS CORPORATION, Plaintiff-Appellee, Cross-Appellant,
The S/S YAFO, her engines, tackle, etc., in rem, and Defendant.
ZIM ISRAEL NAVIGATION COMPANY, LTD., in personam,
Defendant-Third-Party Plaintiff-Appellant, Cross-Appellee,
LOUISVILLE & NASHVILLE RAILROAD COMPANY, Third-Party
Defendant-Appellee.
James L. Schupp, Jr., Benjamin W. Yancey, New Orleans, La., for defendant-third party plaintiff-appellant and S/S Yafo.
Brunswick G. Deutsch, New Orleans, La., for Spartus Corp.
Harry McCall, Jr., Gerald D. Wasserman, New Orleans, La., for Louisville & Nashville Railroad Co.
Appeals from the United States District Court for the Eastern District of Louisiana.
Before INGRAHAM, GEE and TJOFLAT, Circuit Judges.
TJOFLAT, Circuit Judge:
In the proceedings below, the district court entered judgment in favor of Spartus Corporation (Spartus) against Zim Israel Navigation Company, Ltd. (Zim) in personam and against Zim's vessel, the S/S Yafo, in rem for $83,939.36 in damages sustained to a shipment of clock movements while in transit from Ashod, Israel, to Louisville, Mississippi. On Zim's third-party indemnity claim against the Louisville and Nashville Railroad (L & N), judgment was entered for L & N. A brief recital of the facts and the proceedings in the district court are necessary to point up the issues now before us.
* Spartus, a division of L.C.A. Corporation, is engaged in the business of manufacturing clocks. At the time of the transaction that gave rise to this litigation its plant was located in Louisville, Mississippi. Spartus's manufacturing process called for it to ship parts from its Louisville plant to Rolis Electric, Ltd. (Rolis), a subsidiary of L.C.A. in Tel Aviv, Israel, for assembly into functional clock movements. These clock movements were then shipped back to Spartus's Louisville plant via the port of New Orleans, Louisiana, where they were installed in clocks.
On April 22, 1974, Rolis delivered a shipment of clock movements, consigned to Spartus, to Zim at the port of Ashod, Israel. The movements had been placed by Rolis in small cartons and sealed by it in a twenty-foot steel container provided by Zim. Upon receipt of the sealed container, Zim issued Rolis a bill of lading1 carrying the following description of the cargo received: "1 CONTAINER STC (said to contain) 385 CARTONS ELECTRIC CLOCK MOVEMENTS." Thereafter the container was loaded upon the S/S Yafo for shipment to the destination called for by the bill of lading New Orleans, Louisiana.
About ten days out of Miami, Florida, the Israeli government instructed Zim to direct the S/S Yafo to proceed to Mobile, Alabama, where it was to unload its cargo, take on certain military supplies, and return to Israel. Zim complied, directing the vessel to proceed to Mobile. The S/S Yafo arrived in Mobile on May 24, 1974. The container of clock movements was offloaded, without notice to Spartus, the consignee, and was left on an unsheltered dock until June 6, 1974. On that date, Zim delivered the container to L & N for transshipment to New Orleans. The container remained in L & N's piggyback yard in Mobile until June 10, 1974. The next day it was transported to New Orleans. There the container remained in L & N's custody until June 18, when it was handed over to a truck line for delivery to a local wharf. The container remained on the wharf, exposed to the elements until July 5, 1974. On that date, United States Customs inspectors broke the seal on the container, opened it and found some of the contents to be wet. The container was closed pending a further survey which was eventually conducted when the cargo arrived at Spartus's plant in Louisville. The survey disclosed some holes in the roof of the container, that the cartons inside were wet or water stained, and that the clock movements were rusted and corroded from exposure to fresh water. The parties stipulated that: 1.87 inches of rain fell in Mobile while the container sat on the open docks there; the same amount fell in New Orleans from June 11 to June 18; and from that date to July 5, when the seal was broken by the customs inspectors, the container was exposed to further rainfall.
Spartus subsequently brought this suit against Zim and the S/S Yafo, and Zim impleaded L & N for indemnity. Following a bench trial, the district court concluded that the offloading of the container of clock movements in Mobile constituted an unreasonable deviation, thereby subjecting Zim to liability for damages to Spartus. Despite the deviation, the court held that the $500 per-package limitation on liability provided by section 4 of the Carriage of Goods by Sea Act (COGSA), 46 U.S.C. § 1304(5) (1970),2 was available to the carrier, Zim. The limitation was of no effect, however, because none of the 385 cartons, each of which the court treated as a separate "package," was worth as much as $500. The court rejected Zim's contention that it was absolved of responsibility under the Limitation of Liability Act, 46 U.S.C. §§ 181-189 (1970),3 because of Rolis's failure to notify it of the true character and value of the clock movements when the initial bill of lading issued in Israel. The court found alternatively (1) that the statute did not embrace clock movements such as these, (2) that the clock movements were sufficiently described on the bill of lading to satisfy the statute and the separate movements were of such little value as to render de minimus the failure of Rolis to state their value, and (3) that the unreasonable deviation precluded the carrier's invocation of the Limitation of Liability Act. On Zim's third-party indemnity claim, the court found that Zim failed to sustain its burden of proving that it delivered the clock movements to L & N in good condition, an essential element of its cause of action.
In this appeal, Zim questions the court's findings with respect to deviation, the $500 COGSA per-package limitation, and the application of the Limitation of Liability Act. Zim also claims error in the trial court's finding that it failed to prove that it delivered the clock movements to L & N in good condition. Spartus has cross appealed, contending that COGSA's $500 per-package limitation is unavailable in a case of unreasonable deviation. We affirm the judgments on both the main suit and the third-party action.
The first question we must decide is whether the district court was correct in concluding that the offloading of the cargo container at Mobile constituted an unreasonable deviation. For guidance we look to the general maritime law and to COGSA. The following is a frequently used definition of deviation:
To deviate, lexicographically, means to stray, to wander. As applied in admiralty law, the term "deviation" was originally and generally employed to express the wandering or straying of a vessel from the customary course of the voyage, but in the course of time it has come to mean any variation in the conduct of a ship in the carriage of goods whereby the risk incident to the shipment will be increased, such as carrying the cargo on the deck of the ship contrary to custom and without the consent of the shipper, delay in carrying the goods, Failure to deliver the goods at the port named in the bill of lading and carrying them farther to another port, or bringing them back to the port of original shipment and reshipping them. Such conduct has been held to be a departure from the course of agreed transit and to constitute a "deviation" whereby the goods have been subjected to greater risks, and, when lost or damaged in consequence thereof, clauses of exceptions in bills of lading limiting liability cease to apply.
G. W. Sheldon & Co. v. Hamburg Amerikanische Packetfahrt A.G., 28 F.2d 249, 251 (3d Cir. 1928) (emphasis added) (citations omitted). To determine whether a carrier's deviation for the purpose of unloading cargo (as occurred here, when the S/S Yafo put in to the Port of Mobile) is Unreasonable, we need look no further than to COGSA. It provides, in relevant part,
Any deviation in saving or attempting to save life or property at sea, or any reasonable deviation shall not be deemed to be an infringement or breach of this chapter or of the contract of carriage, and the carrier shall not be liable for any loss or damage resulting therefrom: Provided, however, That if the deviation is for the purpose of loading or Unloading cargo or passengers It shall, prima facie, be regarded as unreasonable.
46 U.S.C. § 1304(4) (1970) (emphasis after "Provided, however," added).
Zim concedes that the diversion of the ship to Mobile for the offloading of its cargo was not for the benefit of Spartus. In fact, the sole reason for the action was Zim's desire to enhance Israeli military preparedness. As Zim's operations manager, who ordered that the voyage be aborted, explained, the decision to divert to Mobile to offload the commercial cargo and take on military cargo (E. g., tanks and personnel carriers) was motivated solely by "moral pressure" and was in no way occasioned by any war-like emergency in Israel. Record, vol. 3, at 92-93. Thus the narrow question is presented: Is it a defense to the prima facie case of unreasonableness created by COGSA to say that the deviation was accomplished for the purpose stated by Zim. We think not.
We start with the premise that Congress, in deciding that a deviation for the purpose of unloading cargo is prima facie unreasonable, must have concluded that it is against the interests of the shipper, who has contracted to have his cargo delivered to its destination in good condition, for the carrier to alter that contract by offloading the cargo elsewhere. Thus, Congress has declared that a shipper can make out a case of unreasonable deviation simply by proving that his cargo was offloaded at a place other than the stipulated destination. Zim has cited no authorities, and our research discloses none, that would allow a carrier to overcome the prima facie case of unreasonableness created by the statute by showing that the deviation was motivated by patriotism. Zim points to a seminal British case, Foscolo, Mango & Co. v. Stag Line, Ltd., (1931) 41 Lloyd's List L.R. 165 (H.L.), as support for its defense, particularly Lord Atkin's statement that a deviation "may be reasonable even though it is made solely in the interests of the ship or solely in the interest of the cargo or indeed in the direct interest of neither . . . ." Id. at 171.
Zim's argument initially assumes that the term "interests of the ship" is broad enough to include the patriotic motivations of the ship's owner; once this is acknowledged, the argument continues, a trial court is entitled to find that even where, as in this case, the deviation is solely in response to this "interest," the deviation is reasonable. We find nothing in Lord Atkin's opinion that even suggests that the term "interests of the ship" should be construed to embrace an interest such as the one Zim proposes.
Even if we treat Zim's diversion of the S/S Yafo to Mobile as having been motivated by a desire to enhance Zim's financial stability, and perhaps even its corporate survival in the homeland, our conclusion remains the same it is no defense to the prima facie case of unreasonableness. As a leading admiralty authority points out,
The rationale of (COGSA's prima facie) rule . . . seems to be that the carrier ought not be allowed to deviate with no other motive than the increase of his own revenues; thus, the proof required to overcome the Prima facie unreasonableness of such a deviation would have to show something more than mere reasonableness from the point of view of the Carrier . . . . The carrier, throughout the performance of the voyage, is always subject to (COGSA's) Section 3(2) duty to care for and carry the goods properly, and his decision on a route would seem to be improper and unreasonable whenever it is made in disregard of that duty.
G. Gilmore & C. Black, The Law of Admiralty 179 (2d ed. 1975) (emphasis in original). We have reviewed all the facts and circumstances surrounding the S/S Yafo 's deviation, See, e. g., Hellenic Lines, Ltd. v. United States, 512 F.2d 1196, 1206-09 (2d Cir. 1975), and conclude that the district court was correct in holding that the motive behind Zim's deviation is no defense to Spartus's prima facie case of unreasonableness.
The district court concluded that, despite the unreasonable deviation, Zim could avail itself of COGSA's $500 per-package limitation of liability. COGSA provides, in pertinent part:
Amount of liability; valuation of cargo
Neither the carrier nor the ship shall In any event be or become liable for Any loss or damage to or in connection with the transportation of goods in an amount exceeding $500 per package . . . unless the nature and value of such goods have been declared by the shipper before shipment and inserted in the bill of lading. This declaration, if embodied in the bill of lading, shall be prima facie evidence, but shall not be conclusive on the carrier.
By agreement between the carrier, master, or agent of the carrier, and the shipper another maximum amount than that mentioned in this paragraph may be fixed: Provided, That such maximum shall not be less than the figure above named. In no event shall the carrier be liable for more than the amount of damage actually sustained.
46 U.S.C. § 1304(5) (1970) (emphasis in first paragraph added). The district court read this provision as allowing the $500 limitation Regardless of the cause or circumstances of the loss. In its cross appeal, Spartus contends that the unreasonable geographic deviation of the S/S Yafo operated to breach the contract of carriage between Zim and Spartus, thereby rendering COGSA's per-package limitation inapplicable altogether. We think Spartus's contention is well made.
Prior to the passage of COGSA a geographic deviation had the effect of ousting the contract of carriage and imposing a harsh insurer's liability upon the carrier for damage resulting to the shipper's cargo. See The Willdomino v. Citro Chemical Co. of America, 272 U.S. 718, 47 S.Ct. 261, 71 L.Ed. 491 (1927); St. Johns N. F. Shipping Corp. v. S. A. Companhia Geral Commercial Do Rio de Janeiro, 263 U.S. 119, 44 S.Ct. 30, 68 L.Ed. 201, 1923 A.M.C. 1131 (1923); The Delaware, 81 U.S. (14 Wall.) 579, 20 L.Ed. 779 (1872). See generally Morgan, Unreasonable Deviation under COGSA, 9 J. Mar. L. & Com. 481 (1978). With the passage of COGSA, however, considerable debate ensued as to the effect (on this principle of liability) Congress intended in employing the language "Neither the carrier nor the ship shall in any event be . . . liable for any loss or damage to . . . goods in an amount exceeding $500 per package."
COGSA wrote into law, with some modifications, the so-called Hague Rules, which operate as model standards governing the carriage of goods by sea under bills of lading.4 The original draft of the Hague Rules, written in 1921, was the product of shippers, cargo underwriters, bankers, steamship owners and other interested parties whose intent was to strike a bargain between the cargo interests and the carriers for the division of risks incident to the transportation of goods. All recognized the need for international uniformity in ocean bills of lading, particularly the establishment of an irreducible minimum of immunity of the carrier. The original draft was refined by the International Maritime Conference and became the Brussels Convention that was signed by the United States and other nations in 1923. Great Britain enacted its Carriage of Goods by Sea Act in 1924, adopting in toto the Brussels Convention as its domestic legislation. The United States adopted its version (I. e., COGSA) of the Brussels Convention in 1937. Perhaps the major impetus to COGSA's enactment was the seemingly insufferable condition imposed upon shippers (and, in turn, upon their insurers) by clauses in bills of lading limiting the carrier's liability to very low amounts. These clauses were thought to be the natural result of the carriers' superior bargaining position vis-a-vis shippers.
For several years after the enactment of COGSA many sectors of the maritime world continued to operate under the assumption that COGSA had effected no change in the law of deviation-based carrier liability. This and other circuits continued to apply insurer's liability to a carrier guilty of an unjustifiable deviation, See Romano v. West India Fruit & Steamship Co., 151 F.2d 727, 730 (5th Cir. 1945); The Lafcomo, 64 F.Supp. 529, 531 (S.D.N.Y.1946), (both citing pre-COGSA case law such as The Willdomino ), in spite of the $500 per-package limitation that seemingly applied to every loss.
How a carrier could be held liable for a sum in excess of $500 in a case of unreasonable deviation when COGSA provides that his loss cannot exceed $500 "in any event" was first addressed in Jones v. The Flying Clipper, 116 F.Supp. 386, 1954 A.M.C. 259 (S.D.N.Y.1953). Faced with seemingly unequivocal statutory language, the court nevertheless seized upon its perception of Congress's intent and found that Congress did not intend to supplant the existing law of deviation. The enactment of COGSA's $500 per-package limitation was viewed by the court as merely a means of insuring that no lesser amount of liability could be stipulated. As the court explained,
(e)xcept for this change in amount, the provision of the Act did not represent any basic departure from existing law. Neither the Convention nor the Act contains any provision concerning the legal result of an unjustifiable deviation. There is nothing in the history of the Act to indicate that Congress by fixing the limitation at $500 intended to displace the doctrine of unjustifiable deviation which was so firmly entrenched in maritime law. Such a drastic change in the existing law, with its far-reaching consequences in the commercial and financial world would have been expressed in clear and unmistakable terms.
Id. at 388-89 (footnote omitted). In reaching its holding the court quoted Senator White, one of COGSA's major proponents, to the effect that the act worked only four changes in the preexisting law, E. g., the Harter Act, 27 Stat. 445 (1893): "Four principal changes in the law will be worked by the legislation: The first one has reference to the limit of liability. Under this provision I should say generally that the limit of liability of the carrier is substantially increased." 116 F.Supp. at 389 n.11 (quoting 79 Cong.Rec., 13341 (1935)). The district court also relied on Foscolo, Mango & Co. v. Stag Line, Ltd., (1931) 41 Lloyd's List L.R. 165 (H.L.). There, the House of Lords, after having found an unreasonable deviation, went on to reject the contention that the carrier was entitled to limit his liability. Their reasoning, according to the district court, was based in large part on the notion that an unreasonable deviation breaches the contract of carriage, thereby making the voyage different from the one called for in the original bill of lading (to which the British act applied). The holding of The Flying Clipper has been consistently reaffirmed by courts in the Second Circuit. See Rosenbruch v. American Export Isbrandtsen Lines, Inc., 543 F.2d 967, 971 (2d Cir.), Cert. denied, 429 U.S. 939, 97 S.Ct. 353, 50 L.Ed.2d 308 (1976); Iligan Integrated Steel Mills, Inc. v. SS John Weyerhaeuser, 507 F.2d 68, 72 (2d Cir. 1974), Cert. denied, 421 U.S. 965, 95 S.Ct. 1954, 44 L.Ed.2d 452 (1975); Du Pont de Nemours International S. A. v. S.S. Mormacvega, 493 F.2d 97, 100 n.9 (2d Cir. 1974); Encyclopaedia Britannica, Inc. v. SS Hong Kong Producer, 422 F.2d 7, 18 (2d Cir. 1969), Cert. denied, 397 U.S. 964, 90 S.Ct. 998, 25 L.Ed.2d 255 (1970); Mitsubishi International Corp v. S.S. Glyfada Spirit, 1978 A.M.C. 480 (S.D.N.Y.1978); Cf. Cerro Sales Corp. v. Atlantic Marine Enterprises, Inc., 403 F.Supp. 562, 566 (S.D.N.Y.1975) (unreasonable deviation deprives the carrier of the benefit of the one-year statute of limitations).
Though we have not yet been called upon to decide whether an unreasonable geographic deviation nullifies COGSA's per-package limitation, we have considered whether an unreasonable deviation in the form of on-deck stowage in the face of a clean bill of lading has this effect. In Searoad Shipping Co. v. E. I. duPont de Nemours & Co., 361 F.2d 833 (5th Cir.), Cert. denied, 385 U.S. 973, 87 S.Ct. 511, 17 L.Ed.2d 436 (1966), we held that such a non-geographic (quasi) deviation ousts the COGSA limitation and restores the carrier's full insurer liability. Chief Judge Brown, speaking for the court, said,
And although one highly respected authority raises a question whether under Cogsa the awesome insurer consequence should now be visited on the vessel for nongeographical deviations, and one Court of Appeals keeps a statutory, if not a contract, limitation alive, we have no doubt that the insurer liability continues after Cogsa to flow from on-deck deviation where the damage is causally related.
Id. at 835-36 (footnotes omitted). We read Judge Brown's statement that the "insurer consequence should now be visited on the vessel for nongeographical deviations" as a strong implication that insurer consequences necessarily flow from Geographic deviations, COGSA's $500 per-package limitation notwithstanding. Subsequent cases in this circuit have also declined to apply the COGSA limitation in cases of unreasonable deviations, whether geographic or nongeographic (quasi). See Siderurgica Del Orinoco C. A. v. M/V North Empress, 1977 A.M.C. 1140, 1142-43 (E.D.La.1976); International Drilling Co., N. V. v. The M/V Doriefs, 291 F.Supp. 479, 486-87 (S.D.Tex.1968); Cf. Baker Oil Tools, Inc. v. Delta Steamship Lines, Inc., 562 F.2d 938, 940 (5th Cir. 1977) (carrier's unilateral cancellation of port of call terminates contractually incorporated COGSA $500 limitation as to pre-loaded goods, thus rendering carrier a fully liable common law bailee).
Zim urges us not to treat Searoad as controlling our disposition here. Rather, it would have us adopt the view of the Seventh Circuit expressed in Atlantic Mutual Insurance Co. v. Poseidon Schiffahrt, G. m. b. H., 313 F.2d 872 (7th Cir.), Cert. denied, 375 U.S. 819, 84 S.Ct. 56, 11 L.Ed.2d 53 (1963). There the court declined to follow the Flying Clipper doctrine and held that the COGSA limitation applies notwithstanding the presence of an unreasonable geographic deviation. The court viewed the COGSA words "in any event" as an explicit congressional command that the $500 per-package limitation should apply to any loss, regardless of the cause. While this view is not altogether untenable, we are convinced that our holding in Searoad forecloses our adoption of it in this case. In sum, we agree with Spartus's contention that Zim's offloading of the clock movements in Mobile breached the contract of carriage and rendered the $500 per-package limitation a nullity. Because of this holding, it is unnecessary for us to consider Zim's contention that the district court erred in finding that each of the 385 cartons of clock movements constituted a package for the purpose of applying the limitation.
We now turn to Zim's contention that Section 2 of the Limitation of Liability Act, 46 U.S.C. § 181 (1970), absolutely absolves it of any liability for the damage to the clock movements because Rolis failed to notify it of the nature and value of the cargo. The relevant portion of the Act provides:
If any shipper of . . . Watches, clocks, or timepieces of any description . . . shall lade the same as freight or baggage, on any vessel, without at the time of such lading giving to the master, clerk, agent, or owner of such vessel receiving the same a written notice of the true character and value thereof, and having the same entered on the bill of lading therefor, the master and owner of such vessel shall not be liable as carriers thereof in any form or manner . . . .
(emphasis added.) See Calderon v. Atlas S.S. Co., 170 U.S. 272, 280, 18 S.Ct. 588, 591, 42 L.Ed. 1033 (1898). The district court found alternatively (1) that the clock movements were not "watches, clocks, or timepieces of any description;" (2) that, if they were, adequate notice that the shipment consisted of clock movements was given in the bill of lading (Rolis being entitled to omit a statement of value since the value of the individual movements was de minimus); and (3) that the S/S Yafo 's unreasonable deviation rendered the act inapplicable. We think the district court was correct in its first alternative holding; consequently, we need not reach the others.
We have been pointed to no cases interpreting "watches, clocks, or timepieces of any description." It is necessary, therefore, to begin with the plain meaning of the words of the statute, See Tennessee Valley Authority v. Hill, 437 U.S. 153, 184 n.29, 98 S.Ct. 2279, 2296, 57 L.Ed.2d 117 (1978), to determine whether the shipment of clock movements should properly be included within the statutory definition. The resolution of that issue is, we think, obvious. A timepiece is "an instrument (as a clock or watch) for measuring time." Webster's Third New International Dictionary (Unabridged) 2395 (1961). The clock movements shipped by Spartus were in need of further manufacture before they could be a part of a timepiece. Indeed, it is apparent from examining the exhibits that these little clock movements are simply motors that could be used to run any number of devices.
Zim argues that the statute's plain meaning includes the clock movements since it contains the phrase "of any description." We are not persuaded by this contention. Plainly, an article which is not a timepiece cannot be considered a timepiece "of any description." The phrase refers to different types of timepieces, not components thereof. That the aggregate value of the cargo was substantial, a factor to which Zim seems to attach particular significance, cannot defeat the plain and obvious meaning of the words employed in the statute.
In drafting section 181, Congress included, along with "watches, clocks, or timepieces of any description," a variety of goods, among them "silks In a manufactured or unmanufactured state." 46 U.S.C. § 181 (1970) (emphasis added). Had Congress intended that the statute embrace clock movements such as those in this case, they could have provided a more expansive definition as they did for silk. We must decline Zim's invitation to interpret section 181 to encompass components of unfinished timepieces.
We now turn to Zim's final claim of error, the district court's disposition of its third-party indemnity claim against L & N. The district court dismissed the claim because it felt Zim had not shown that it delivered the cargo of clock movements to the railroad in Mobile in good condition. In our view, the ruling was correct.
The liability of a rail carrier for damage to goods is controlled by federal law. 49 U.S.C. § 20(11) (1970) provides, in pertinent part:
Any . . . railroad . . . receiving property (for interstate transportation) . . . shall issue a receipt or bill of lading therefor, and shall be liable to the lawful holder thereof for any loss, damage, or injury to such property caused by it . . . .
The Supreme Court has construed this statute to mean that, "in an action to recover from a carrier for damage to a shipment, the shipper establishes his prima facie case when he shows Delivery in good condition, arrival in damaged condition, and the amount of damages." Missouri Pacific Railroad v. Elmore & Stahl, 377 U.S. 134, 138, 84 S.Ct. 1142, 1145, 12 L.Ed.2d 752 (1964) (emphasis added). Thus, as the trial judge properly noted, the issue here is whether Zim established that the shipment in question was delivered to the L & N in good condition.
The railroad issued Zim a "clean" bill of lading upon receipt of the container of clock movements.5 Zim argues that the railroad's issuance of the clean bill is, standing alone, sufficient evidence of good condition to satisfy Zim's burden of proof. With the addition of the undisputed evidence that the goods arrived at Spartus's Louisville plant in a damaged condition and that their container, while in L & N's possession, was exposed to enough rainfall to account for the damage, Zim's argument proceeds, the district court had no choice other than to hold the railroad accountable.
Zim's argument is impressive, but it ignores the fact that it had the burden of proof to demonstrate delivery in good condition. First, although a bill of lading can establish prima facie that the merchandise being shipped is in good condition, United States v. Mississippi Valley Barge Line Co.,285 F.2d 381, 388-89 (8th Cir. 1960), the "apparent good condition" clause, commonly contained in a bill such as the one here, has been held to apply only to those portions of the shipment which are visible and open to inspection. Blue Bird Food Products Co. v. Baltimore & Ohio Railroad, 474 F.2d 102, 104 (3d Cir. 1973). See also World Wide Meats, Inc. v. Chicago & North Western Transportation Co., 383 F.Supp. 807, 809-10 (N.D.Iowa 1974). In this case, the container was sealed and the clock movements were not available to L & N for inspection. Consequently, the "apparent good condition" clause provided Zim with no proof that the clock movements had been delivered to the L & N in good condition. That proof had to come from elsewhere; and, as the district court correctly observed, Zim did not provide it.
Zim did show, and L & N conceded, that it received the clock movements from Rolis, in Israel, in good condition. As to how the shipment was handled or whether it was exposed to the elements (especially fresh water, as that is what caused the damage) during the voyage from Israel to Mobile, the record is silent. We do know that, in Mobile, prior to its delivery to the railroad, the shipment was exposed to 1.87 inches of rain. This history of the shipment is the sum of Zim's evidence, or lack of it, bearing on the condition of the shipment when delivered to L & N. Zim had the burden of proof on the issue. On this record, we cannot say that the district judge was clearly erroneous in concluding that Zim did not establish, by a preponderance of the evidence, that the clock movements were delivered to the railroad in good condition. Judgment for the L & N on the third-party claim was therefore in order.
The judgments for Spartus in the main suit and for L & N on the third-party claim are, for the reasons we have stated, AFFIRMED.
Though the bill of lading was issued to Rolis, not a party to this case, it is not disputed that Spartus, by virtue of its business relationship with Rolis, stands in the latter's shoes
Section 1304(5) provides, in pertinent part,
Neither the carrier nor the ship shall in any event be or become liable for any loss or damage to or in connection with the transportation of goods in an amount exceeding $500 per package . . . .
Section 2 of the Limitation of Liability Act, 46 U.S.C. § 181 (1970), provides, in pertinent part,
If any shipper of . . . watches, clocks, or timepieces of any description . . . shall lade the same as freight or baggage, on any vessel, without at the time of such lading giving to the master, clerk, agent, or owner of such vessel receiving the same a written notice of the true character and value thereof, and having the same entered on the bill of lading therefor, the master and owner of such vessel shall not be liable as carriers thereof in any form or manner . . . . (emphasis added.)
The history of COGSA is set out in the hearings and committee reports of both houses considering the legislation. See Carriage of Goods by Sea: Hearing on S. 1152 Before the Senate Committee on Commerce, 74th Cong., 1st Sess. (1935); S. Rep. No. 742, 74th Cong., 1st Sess. (1935); H. R. Rep. No. 2218, 74th Cong., 2d Sess. (1936)
The bill of lading provided, inter alia, "The property described below in apparent good order, Except as noted (Contents (this portion of original exhibit obliterated by hole punch) Condition of contents of packages unknown ) . . . ." Defendant's Exhibit No. 3 (emphasis added)


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text:
Former Virginia Candidate Indicted for False Campaign Finance Reports
LEESBURG, Va. – A candidate who lost a Republican primary contest for the Virginia Senate failed to report some donations and turned in campaign finance reports riddled with inaccuracies, a prosecutor said.
Mark D. Tate, indicted May 22 on 11 felony counts, lost by nearly a 2-to-1 ratio to Jill Holtzman Vogel in the June 12 primary.
For the first time, the accusations were publicly detailed Monday at a hearing in Loudoun Circuit Court.
"There are literally hundreds of misfiles in this case," said Matthew J. Britton, the commonwealth's attorney from King George County, who is serving as the special prosecutor.
In two campaigns for state Senate, Tate failed to report some donations, reported others multiple times and often reported wrong amounts or dates, Britton said.
Tate, 41, a Middleburg restaurateur, is also accused of writing bad checks, court documents show.
Tate's attorney, Edward B. MacMahon Jr., has said that none of the errors in Tate's campaign filings rose to the level of a crime.
"He's clearly made mistakes before in filing returns, and so have many, many, many other candidates before him," MacMahon said in an interview with The Washington Post.
Judge Charles H. Duff rejected a motion by prosecutors to have MacMahon dismissed from the case. Prosecutors had hoped to call MacMahon as a witness because he donated hundreds of dollars to Tate's campaigns.
Tate is next scheduled to appear in court July 10.


Born in Washington, D.C. and raised in Maryland, Jonathan Friedman's strong family ties to New Orleans enticed him to pursue his college education at Tulane University. While at Tulane, Jonathan studied American history, with a focus on Louisiana. Following college, Jonathan received his law degree from Tulane University where he received honors in trial advocacy. While in school, Jonathan interned at the Anti-Trust Division in the Department of Justice in Washington, D.C., and also worked at the Department of Veteran's Affairs in New Orleans. In 1997, Jonathan became a law clerk at the New Orleans District Attorney's Office.
In 1998, Jonathan began practicing law as an Assistant District Attorney in Orleans Parish. During his four and one-half years, he tried over 70 jury trials and 100 judge trials. In October of 2002, Jonathan received an award from the True Democrats of Jefferson Parish for outstanding service to the community. Jonathan was the Senior Homicide Screener and Grand Jury Coordinator at the District Attorney's office before coming to Silbert & Garon in January of 2003. Since joining Silbert & Garon, he has utilized his extensive trial and investigative experience in the handling of personal injury cases.
Since 2003, Jonathan has worked with the law firm of Silbert & Garon, LLP, primarily practicing personal injury law. In October 2010, Jonathan was appointed as a Criminal Court Magistrate Commissioner, Section M5 in Orleans Parish.
Jonathan is married to the former Holly Richard of Houma, Louisiana. Holly and Jonathan have two daughters, Lindsey Raye and Grace Sophia.
Birth Date: May 24, 1971; Washington, D.C.


Raysace COB Grow Light compared to other LED grow lights saves you 25% of the cost while improving the yield of your plants.
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text:
"Salva Mea" (faux Latin for "save me") is a song by British electronic band Faithless, written by members Rollo, Sister Bliss, and Maxi Jazz. The female vocals on all versions are performed by Rollo's sister Dido. "Salva Mea" was released in 1995 as the group's first single and became a hit on the UK Dance Singles Chart; following a re-release in 1996, it peaked at number nine on the UK Singles Chart. The single topped the US Hot Dance Club Play chart twice—during its first chart run in 1996 and again in 1997 when the track was remixed and reissued.

Critical reception
In a retrospective review of the Reverence album, Justin Chadwick from Albumism commented, "While "Insomnia" is phenomenal, it was primarily the epic grandeur and sinister soundscape of "Salva Mea" that blew me away and made me fall madly in love with Faithless' transcendent sound. Among the group's myriad standout songs, it's still my most beloved." Upon the 1995 release, Alan Jones from Music Week called it "the piece de résistance" of the album, noting that "the severely under-rated single" marked Rollo as "the Jim Steinman of dance music." In 1996, a reviewer from the magazine rated it three out of five, adding that "this pizzicato synth-driven floorfiller, with its distinctive changes in tempo and vocals, should emulate their recent number three hit Insomnia." Jones said, "Finally, the inevitable has happened and Faithless's finest recording Salva Mea is back with even more new mixes. As far over the top as Rollo & Sister Bliss have ever got, it's an epic tune and every inch a Top 10 hit."

Music video
A black-and-white music video was produced to promote the single, directed by British director Lindy Heymann.

Track listings

 UK CD 1995
 "Salva Mea" (Slow Version) – 4:11
 "Salva Mea" (Epic Mix) – 11:51
 "Salva Mea" (Tuff Mix) – 9:37
 "Salva Mea" (Sister Bliss Remix) – 8:43

 Australian CD 1996
 "Salva Mea" (Tuff Edit) – 4:02
 "Salva Mea" (Epic Edit) – 4:51
 "Salva Mea" (Radio Version) – 4:08
 "Salva Mea" (Epic Mix) – 11:50
 "Salva Mea" (Tuff Mix) – 9:33
 "Salva Mea" (Sister Bliss Remix) – 8:42
 "Salva Mea" (Floating Mix) – 8:11

 German CD 1996
 "Salva Mea" (Radio Edit) – 3:47
 "Salva Mea" (C.E.C. Edit) – 4:59
 "Salva Mea" (Epic Edit) – 4:51
 "Salva Mea" (96 Remix) – 9:11
 "Salva Mea" (Way Out West Remix) – 7:48
 "Salva Mea" (Tuff Mix) – 8:36

 US CD 1996
 "Salva Mea" (Radio Version) – 4:08
 "Salva Mea" (Epic Radio Version) – 4:51
 "Salva Mea" (Epic Mix) – 11:48
 "Salva Mea" (Tuff Mix) – 9:35
 "Salva Mea" (Sister Bliss Remix) – 8:40

 UK CD 1 – 1997
 "Salva Mea" (Radio Edit) – 4:36
 "Salva Mea" (Epic Mix) – 11:51
 "Salva Mea" (Way Out West Remix) – 7:48
 "Salva Mea" (Slow Version) – 4:10
 "Salva Mea" (Floating Mix) – 8:12

 UK CD 2 – 1997
 "Salva Mea" (Radio Edit) – 4:36
 "Salva Mea" (Epic Mix) – 11:51
 "Salva Mea" (Sister Bliss Mix) – 8:43
 "Salva Mea" (DJ Quicksilver Remix) – 6:52
 "Salva Mea" (Tuff Mix) – 7:57

Charts

Weekly charts

Year-end charts

Release history

References

1995 singles
1995 songs
1996 singles
1997 singles
Black-and-white music videos
Cheeky Records singles
Faithless songs
Music videos directed by Lindy Heymann
Number-one singles in Switzerland
Songs written by Maxi Jazz
Songs written by Rollo Armstrong
Songs written by Sister Bliss


text:
Q: Why does a simple C "hello world" program not work if gcc -O3 without "volatile"? I have the following C program
int main() {
char string[] = "Hello, world.\r\n";
__asm__ volatile ("syscall;" :: "a" (1), "D" (0), "S" ((unsigned long) string), "d" (sizeof(string) - 1)); }

which I want to run under Linux with with x86 64 bit. I call the syscall for "write" with 0 as fd argument because this is stdout.
If I compile under gcc with -O3, it does not work. A look into the assembly code
    .file   "test_for_o3.c"
.text
.section    .text.startup,"ax",@progbits
.p2align 4,,15
.globl  main
.type   main, @function
main:
.LFB0:
    .cfi_startproc
    subq    $40, %rsp
    .cfi_def_cfa_offset 48
    xorl    %edi, %edi
    movl    $15, %edx
    movq    %fs:40, %rax
    movq    %rax, 24(%rsp)
    xorl    %eax, %eax
    movq    %rsp, %rsi
    movl    $1, %eax
#APP
# 5 "test_for_o3.c" 1
    syscall;
# 0 "" 2
#NO_APP
    movq    24(%rsp), %rcx
    xorq    %fs:40, %rcx
    jne .L5
    xorl    %eax, %eax
    addq    $40, %rsp
    .cfi_remember_state
    .cfi_def_cfa_offset 8
    ret
.L5:
    .cfi_restore_state
    call    __stack_chk_fail@PLT
    .cfi_endproc
.LFE0:
    .size   main, .-main
    .ident  "GCC: (Ubuntu 7.3.0-27ubuntu1~18.04) 7.3.0"
    .section    .note.GNU-stack,"",@progbits

tells us that gcc has simply not put the string data into the assembly code. Instead, if I declare "string" as "volatile", it works fine.
However, the idea of "volatile" is just to use it for variables that can change their values by (from the view of the executing function) unexpected events, isn't it? "volatile" can make code much slower, hence it should be avoided if possible.
As I would suppose, gcc must assume that the content of "string" must not be ignored because the pointer "string" is used as an input parameter in the inline assembly (and gcc has no idea what the inline assembly code will do with it).
If this is "allowed" behaviour of gcc, where can I read more about all the formal constraints I have to be aware of when writing code for -O3?
A second question would be what the "volatile" statement along with the inline assembly directive does exactly. I just got used to mark all inline assembly directives with "volatile" because it had not worked otherwise, in some situations.

redpajama_set_name: RedPajamaStackExchange


With the Multiport Selector Valve it is possible to receive the flow from five or more oil or gas wells. It consists in one steel body with five or more incoming flow lines or inlet-ports and two outlet-ports.
One of the outlets (the bigger) collects and pipes oil or gas to production and the other one (the smaller) collects and pipes to test the fluids coming from the selected well. Various sizes and ratings of line flanges available.
The inlet and outlet ends can be flanged or screwed NPT for the ASME/ANSI pressure Classes 150, 300, 600, 900 and 1500 and 2500.
Standard Construction Materials: Body: ASTM A350 LF2 or A216WCB | Bonnet cover: ASTM A350 LF2 or A216WCB | Rotor: ASTM A350 LF2 or A216WCB | Seat Ring: 316L | Sealing element: PTFE-25% C or Nylon | O-Rings: AFLAS | Studs: ASTM A 193 B7. Nuts A 194 2H | Other materials are available on demand.
OIL AND GAS SKID PRODUCTION PAD: The heart of the skid production pad is the Multiport Selector Valve, as described above, fitted with an electrical actuator. Each line connected with the inlet and outlet-ports is complete with his block ball valve, check valve, relief and drain valves, pressure and temperature transmitters.
With the Multiport Selector Valve it is possible to receive the flow from five or more oil or gas wells. It consists in one steel body with five or more incoming flow lines or inlet-ports and two outlet-ports. One of the outlets (the bigger) collects and pipes oil or gas to production and the other one (the smaller) collects and pipes to test the fluids coming from the selected well. Various sizes and ratings of line flanges available.
Manual or electric motor operation for hazardous atmosphere.
Local or remote control via MODBUS RTU.
Studs: ASTM A 193 B7. Nuts A 194 2H.
Other materials are available on demand.
The heart of the skid production pad is the Multiport Selector Valve, as described above, fitted with an electrical actuator. Each line connected with the inlet and outlet-ports is complete with his block ball valve, check valve, relief and drain valves, pressure and temperature transmitters. Therefore, when the skid is received in the field, it is ready for connection, commissioning and subsequent operation. No painting, welding, or field testing is needed.
Combined solution: Multiphase Meter – Multiport Selector Valve.
The Skid has a small ecological impact and because of its reduced footprint, it is ideal for offshore applications.
It can be delivered, installed, commissioned and start up within a few days.
Multiphase meter test on-line (in-situ).
The systems are completely tested in the factory (Dye penetrant inspection, pressure test, RX inspection, functional tests).
H2S service parts designed for hydrogen sulfide corrosion resistance.
The skid can be connected in cluster (several skid connections for 14, 21, 28 or more wells).


Select the Cover photo below to upload it as Facebook Cover to your profile!
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text:
Q: SCP stuck on file copying I have a test file with a simple text inside.
If filesize more then 750 bytes I can not transfer it via SCP or rsync.

Internet works fine on the host and has Download: 16.53 Mbit/s Upload: 2.83
  Mbit/s

-rw-rw-r--  1  4395 Nov  4 18:34 test

 scp -v  test  deployer@vpn-test_host:/home/deployer

debug1: Sending command: scp -v -t /home/deployer
Sending file modes: C0664 4395 test
Sink: C0664 4395 test
test                                       0%    0     0.0KB/s   --:-- ETA

Ubuntu 18.04 is installed on both sides.
How can I resolve this issue?


Diadema antillarum experienced a mass mortality event between 1983-1984 that dropped its densities about 93 %, a phenomenon that led to a macroalgae dominance in most reefs. This study was performed in Tayrona National Natural Park (PNNT) and Playa Blanca (Bahía de Gaira) to determine the status of the black sea urchin populations. At each site, five 10 m line transects were located perpendicular to each other and the density was estimated by 1 m2 squares; coral community composition and roughness was recorded by video. Size structure was calculated by collecting between 31 and 52 individuals and measuring the diameter and height of the test. The highest mean density was found in Nenguange (1.16 ind/m2) and lowest in Chengue (0.04 ind/m2), both located in the PNNT. Mean test diameter was between 58.84 and 80.60 mm. No relation was found between the main reef components (corals, macroalgae or dead coral) and the sea urchin densities, neither between diversity and uniformity and sea urchin densities. Our results show that the density is in the range of current abundance reported in other Caribbean regions, indicating a slow recovery of populations.


text:
A Movie For All Time
Please, Can We Pause for the Death of a Wife and Mother of Two?
Happily Ever After — Even in Hollywood
1917: War as Video Game and Ceremony
Trump Signals Support for Evangelicals with New School-Prayer Guidance
History According to the 1619 Project
Don't Do Dolittle
Women Lie Too
Movie Awards: So Male, So White, So What?
The Sickening Power of Putin
What Abigail Disney Doesn't Know about Conservative Philanthropy
In Chelsea, S&M Goes High-Fashion, Pastels Go High-Octane
South Dakota State Rep Proposes Bill to Criminalize Gender-Transition Surgeries on Children
Dave Chapelle Endorses Andrew Yang, Will Campaign for Him in South Carolina
About Jonah Goldberg
Follow Jonah Goldberg on Twitter
Bill Murray in Groundhog Day (Columbia Pictures)
Tomorrow and tomorrow and tomorrow, Groundhog Day scores
EDITOR'S NOTE: This piece was the February 14, 2005, cover story in National Review.
Here's a line you'll either recognize or you won't: "This is one time where television really fails to capture the true excitement of a large squirrel predicting the weather." If you don't recognize this little gem, you've either never seen Groundhog Day or you're not a fan of what is, in my opinion, one of the best films of the last 40 years. As the day of the groundhog again approaches, it seems only fitting to celebrate what will almost undoubtedly join It's a Wonderful Life in the pantheon of America's most uplifting, morally serious, enjoyable, and timeless movies.
When I set out to write this article, I thought it'd be fun to do a quirky homage to an offbeat flick, one I think is brilliant as both comedy and moral philosophy. But while doing what I intended to be cursory research–how much reporting do you need for a review of a twelve-year-old movie that plays constantly on cable?–I discovered that I wasn't alone in my interest. In the years since its release the film has been taken up by Jews, Catholics, Evangelicals, Hindus, Buddhists, Wiccans, and followers of the oppressed Chinese Falun Gong movement. Meanwhile, the Internet brims with weighty philosophical treatises on the deep Platonist, Aristotelian, and existentialist themes providing the skin and bones beneath the film's clown makeup. On National Review Online's group blog, The Corner, I asked readers to send in their views on the film. Over 200 e-mails later I had learned that countless professors use it to teach ethics and a host of philosophical approaches. Several pastors sent me excerpts from sermons in which Groundhog Day was the central metaphor. And dozens of committed Christians of all denominations related that it was one of their most cherished movies.
When the Museum of Modern Art in New York debuted a film series on "The Hidden God: Film and Faith" two years ago, it opened with Groundhog Day. The rest of the films were drawn from the ranks of turgid and bleak intellectual cinema, including standards from Ingmar Bergman and Roberto Rossellini. According to the New York Times, curators of the series were stunned to discover that so many of the 35 leading literary and religious scholars who had been polled to pick the series entries had chosen Groundhog Day that a spat had broken out among the scholars over who would get to write about the film for the catalogue. In a wonderful essay for the Christian magazine Touchstone, theology professor Michael P. Foley wrote that Groundhog Day is "a stunning allegory of moral, intellectual, and even religious excellence in the face of postmodern decay, a sort of Christian-Aristotelian Pilgrim's Progress for those lost in the contemporary cosmos." Charles Murray, author of Human Accomplishment, has cited Groundhog Day more than once as one of the few cultural achievements of recent times that will be remembered centuries from now. He was quoted in The New Yorker declaring, "It is a brilliant moral fable offering an Aristotelian view of the world."
I know what you're thinking: We're talking about the movie in which Bill Murray tells a big rat sitting on his lap, "Don't drive angry," right? Yep, that's the one. You might like to know that the rodent in question is actually Jesus–at least that's what film historian Michael Bronski told the Times. "The groundhog is clearly the resurrected Christ, the ever-hopeful renewal of life at springtime, at a time of pagan-Christian holidays. And when I say that the groundhog is Jesus, I say that with great respect."
That may be going overboard, but something important is going on here. What is it about this ostensibly farcical film about a wisecracking weatherman that speaks to so many on such a deep spiritual level?
THOROUGHLY POSTMODERN PHIL
A recap is in order. Bill Murray, the movie's indispensible and perfect lead, plays Phil Connors, a Pittsburgh weatherman with delusions of grandeur (he unselfconsciously refers to himself as "the talent"). Accompanied by his producer and love interest, Rita (played by Andie MacDowell), and a cameraman (Chris Elliott), Connors goes on assignment to cover the Groundhog Day festival in Punxsutawney, Pa., at which "Punxsutawney Phil"–a real groundhog–comes out of his hole to reveal how much longer winter will last. Connors believes he's too good for the assignment–and for Punxsutawney, Pittsburgh, and everything in between. He is a thoroughly postmodern man: arrogant, world-weary, and contemptuous without cause.
Rita tells Phil that people love the groundhog story, to which he responds, "People like blood sausage, too, people are morons." Later, at the Groundhog Festival, she tells him: "You're missing all the fun. These people are great! Some of them have been partying all night long. They sing songs 'til they get too cold and then they go sit by the fire and get warm and then they come back and sing some more." Phil replies, "Yeah, they're hicks, Rita."
Phil does his reporting schtick when the groundhog emerges and plans to head home as quickly as possible. Unfortunately, a blizzard stops him at the outskirts of town. A state trooper explains that the highway's closed: "Don't you watch the weather reports?" the cop asks. Connors replies (blasphemously, according to some), "I make the weather!" Moving on, the cop explains he can either turn around to Punxsutawney or freeze to death. "Which is it?" he asks. Connors answers, "I'm thinking, I'm thinking." Reluctantly returning to Punxsutawney, Connors spends another night in a sweet little bed and breakfast run by the sort of un-ironic, un-hip, decent folks he considers hicks.
The next morning, the clock radio in his room goes off and he hears the same radio show he'd heard the day before, complete with a broadcast of "I Got You Babe" and the declaration, "It's Groundhog Day!" At first, Connors believes it's an amateurish gaffe by a second-rate radio station. But slowly he discovers it's the same day all over again. "What if there is no tomorrow?" he asks. "There wasn't one today!"
And this is the plot device for the whole film, which has seeped into the larger culture. Indeed, "Groundhog Day" has become shorthand for (translating nicely) "same stuff, different day." Troops in Iraq regularly use it as a rough synonym for "snafu," which (also translated nicely) means "situation normal: all fouled-up." Connors spends an unknown number of days repeating the exact same day over and over again. Everyone else experiences that day for the "first" time, while Connors experiences it with Sisyphean repetition. Estimates vary on how many actual Groundhog Days Connors endures. We see him relive 34 of them. But many more are implied. According to Harold Ramis, the co-writer and director, the original script called for him to endure 10,000 years in Punxsutawney, but it was probably closer to ten.
But this is a small mystery. A far more important one is why the day repeats itself and why it stops repeating at the end. Because the viewer is left to draw his own conclusions, we have what many believe is the best cinematic moral allegory popular culture has produced in decades–perhaps ever.
Interpretations of this central mystery vary. But central to all is a morally complicated and powerful story arc to the main character. When Phil Connors arrives in Punxsutawney, he's a perfect representative of the Seinfeld generation: been-there-done-that. When he first realizes he's not crazy and that he can, in effect, live forever without consequences–if there's no tomorrow, how can you be punished?–he indulges his adolescent self. He shoves cigarettes and pastries into his face with no fear of love-handles or lung cancer. "I am not going to play by their rules any longer," he declares as he goes for a drunk-driving spree. He uses his ability to glean intelligence about the locals to bed women with lies. When that no longer gratifies, he steals money and gets kinky, dressing up and play-acting. When Andie MacDowell sees him like this she quotes a poem by Sir Walter Scott: "The wretch, concentrated all in self / Living, shall forfeit fair renown / And, doubly dying, shall go down / To the vile dust, from whence he sprung / Unwept, unhonoured, and unsung."
Connors cackles at her earnestness. "You don't like poetry?" She asks. "I love poetry," he replies, "I just thought that was Willard Scott."
Still, Conners schemes to bed Rita with the same techniques he used on other women, and fails, time and again. When he realizes that his failures stem not from a lack of information about Rita's desires but rather from his own basic hollowness, he grows suicidal. Or, some argue, he grows suicidal after learning that all of the material and sexual gratification in the world is not spiritually sustaining. Either way, he blames the groundhog and kills it in a murder-suicide pact–if you can call killing the varmint murder. Discovering, after countless more suicide attempts, that he cannot even die without waking up the next day he begins to believe he is "a god." When Rita scoffs at this–noting that she had twelve years of Catholic school (the only mention of religion in the film)–he replies that he didn't say he was "the God" but merely "a god." Then again, he remarks, maybe God really isn't all-powerful, maybe he's just been around so long he knows everything that's going to happen. This, according to some, is a reference to the doctrine of God's "middle knowledge," first put forward by the 16th-century Jesuit theologian Luis de Molina, who argued that human free will is possible because God's omniscience includes His knowledge of every possible outcome of every possible decision.
THE METAMORPHOSIS
The point is that Connors slowly realizes that what makes life worth living is not what you get from it, but what you put into it. He takes up the piano. He reads poetry–no longer to impress Rita, but for its own sake. He helps the locals in matters great and small, including catching a boy who falls from a tree every day. "You never thank me!" he yells at the fleeing brat. He also discovers that there are some things he cannot change, that he cannot be God. The homeless man whom Connors scorns at the beginning of the film becomes an obsession of his at the end because he dies every Groundhog Day. Calling him "pop" and "dad," Connors tries to save him but never can.
By the end of the film, Connors is no longer obsessed with bedding Rita. He's in love with her, without reservation and without hope of his affection being requited. Only in the end, when he completely gives up hope, does he in fact "get" the woman he loves. And with that, with her love, he finally wakes on February 3, the great wheel of life no longer stuck on Groundhog Day. As NR's own Rick Brookhiser explains it, "The curse is lifted when Bill Murray blesses the day he has just lived. And his reward is that the day is taken from him. Loving life includes loving the fact that it goes."
Personally, I always saw Nietzsche's doctrine of the eternal return of the same in this story. That was Nietzsche's idea–metaphorical or literal–to imagine life as an endless repetition of the same events over and over. How would this shape your actions? What would you choose to live out for all eternity? Others see Camus, who writes about how we should live once we realize the absurdity of life. But existentialism doesn't explain the film's broader appeal. It is the religious resonance–if not necessarily explicit religious themes–that draws many to it. There's much to the view of Punxsutawney as purgatory: Connors goes to his own version of hell, but since he's not evil it turns out to be purgatory, from which he is released by shedding his selfishness and committing to acts of love. Meanwhile, Hindus and Buddhists see versions of reincarnation here, and Jews find great significance in the fact that Connors is saved only after he performs mitzvahs (good deeds) and is returned to earth, not heaven, to perform more.
The burning question: Was all this intentional? Yes and no. Ultimately, the story is one of redemption, so it should surprise no one that it speaks to those in search of the same. But there is also a secular, even conservative, point to be made here. Connors's metamorphosis contradicts almost everything postmodernity teaches. He doesn't find paradise or liberation by becoming more "authentic," by acting on his whims and urges and listening to his inner voices. That behavior is soul-killing. He does exactly the opposite: He learns to appreciate the crowd, the community, even the bourgeois hicks and their values. He determines to make himself better by reading poetry and the classics and by learning to sculpt ice and make music, and most of all by shedding his ironic detachment from the world.
Harold Ramis and Danny Rubin, the writer of the original story, are not philosophers. Ramis was born Jewish and is now a lackadaisical Buddhist. He wears meditation beads on his wrist, he told the New York Times, "because I'm on a Buddhist diet. They're supposed to remind me not to eat, but actually just get in the way when I'm cutting my steak." Rubin's original script was apparently much more complex and philosophical–it opened in the middle of Connors's sentence to purgatory and ended with the revelation that Rita was caught in a cycle of her own. Murray wanted the film to be more philosophical (indeed, the film is surely the best sign of his reincarnation as a great actor), but Ramis constantly insisted that the film be funny first and philosophical second.
And this is the film's true triumph. It is a very, very funny movie, in which all of the themes are invisible to people who just want to have a good time. There's no violence, no strong language, and the sexual content is about as tame as it gets. (Some e-mailers complained that Connors is only liberated when he has sex with Rita. Not true: They merely fall asleep together.) If this were a French film dealing with the same themes, it would be in black and white, the sex would be constant and depraved, and it would end in cold death. My only criticism is that Andie MacDowell isn't nearly charming enough to warrant all the fuss (she says a prayer for world peace every time she orders a drink!). And yet for all the opportunities the film presents for self-importance and sentimentality, it almost never falls for either. The best example: When the two lovebirds emerge from the B&B to embrace a happy new life together in what Connors considers a paradisiacal Punxsutawney, Connors declares, "Let's live here!" They kiss, the music builds, and then in the film's last line he adds: "We'll rent to start."
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Bill De Blasio's Groundhog Day Gaffe
Jonah Goldberg is a National Review contributing editor. @JonahDispatch
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18/12/2018 · Celiac.com 12/17/2018 - A 39-year-old woman with possible celiac disease was left brain dead after a dangerous internet "soy sauce colon cleanse" caused critically high levels of salt in her blood, which led to organ failure and death.... Having a family member diagnosed with Celiac Disease is an indicator that you should probably get yourself checked as well. Some genetic variations seem to be risk factors in developing the disease, although they aren't an automatic guarantee that you'll suffer from it.
This procedure lets your doctor check your small intestine for damage. She'll insert a scope with a camera through your mouth, down your esophagus, and into your intestinal tract.... Why Everyone with Celiac Disease Desperately Needs Vitamin D Jordan Reasoner 58 Comments Updated: December 11, 2018 Celiac Disease As we discussed in my previous article in this series , the foundation of an effective Celiac Disease treatment plan starts with a real food diet that goes beyond gluten-free junk food.
Why Everyone with Celiac Disease Desperately Needs Vitamin D Jordan Reasoner 58 Comments Updated: December 11, 2018 Celiac Disease As we discussed in my previous article in this series , the foundation of an effective Celiac Disease treatment plan starts with a real food diet that goes beyond gluten-free junk food.... Having a family member diagnosed with Celiac Disease is an indicator that you should probably get yourself checked as well. Some genetic variations seem to be risk factors in developing the disease, although they aren't an automatic guarantee that you'll suffer from it.
Celiac can come at any age, even if you were previously tested negative. The Celiac Disease Foundation said that one in 133 people today have celiac disease. A 2008 study showed that elderly people have a high risk of developing it as well. "You can't write this off at any age," says Fasano. "Even in an elderly patient, you can't say 'it can't be celiac disease.' If somebody... Ryan Miller tested positive for celiac disease and is thriving on the gluten-free diet. Tasha Miller of Naperville, Illinois, was shocked when her then 14-year-old son Ryan's bloodwork came back positive for celiac disease.
1% of the world population suffers from Celiac disease. Celiac disease is an autoimmune disease in which the immune system believes that gluten is a threat.
Diagnosing celiac disease is not as clear cut as you might think because it has nonspecific symptoms such as fatigue and abdominal bloating The first caveat is that you must eat wheat (gluten) for the whole month before you are tested to get the most accurate evaluation.
It's important to be tested for celiac disease before trying a gluten-free diet. Eliminating gluten from your diet may change the results of blood tests so that they appear to be normal. Eliminating gluten from your diet may change the results of blood tests so that they appear to be normal.


text:
"Strategy" Not Appropriate for Social Justice Movements
All warfare is based on deception. Hence when able to attack, we must seem unable; when using our forces, we must seem inactive; when we are near, we must make the enemy believe that we are away; when far away, we must make him believe we are near. Hold out baits to entice the enemy. Feign disorder, and crush him.
-Sun Szu, "The Art of War"
With deft brushstrokes Sun Szu, writing 500 years before Christ, distills the essence of strategy. His words appear on the first page of military historian B.H. Liddell Hart's own summing up, "Strategy" (2nd edition, 1967). Both Sun Szu and Liddell Hart are required reading at West Point.
Confucius, Sun Szu's contemporary, taught that to reform society we must reform our thinking – and to do so, we must reform our language. Therefore, Confucius taught, we need to call things by their real name.
Activists sometimes chide each other for not "thinking strategically" – by which I suppose we mean we're not planning for three or five years down the pike. Or, often, "strategy" is an inflated way of referring to tactics – a more modest concept having to do with the near future and with limited goals.
Within the movement, "strategy" enjoys a kind of cachet, a kind of borrowed glory. But I'm skeptical of its value or relevance. Let me explain.
The word comes from the Greek, strategos, the leader of an army. My American Heritage dictionary defines "strategy" as "the science or art of military command as applied to the overall planning and conduct of large-scale combat operations" [italics added].
While one can consult other dictionaries and find other, vaguer, definitions of "strategy," they all derive from the military. "Strategy" is standard corporate jargon; it's even become standard jargon in our movement. Often, losing sight of what the word essentially means and where it comes from, we use "strategy" as a synonym for such useful things as planning, goal-setting, coordinating and coalition building.
These activities are themselves perfectly valid. But why not call them what they are? They don't need to be prinked up as "strategy." In these notes, I argue against such unmindful usage.
Let's be wary when we find ourselves parroting military or business jargon. Let's be wary when such terminology infiltrates our language. After all, language is not without its influence on thought … and action. The language of war and greed can hardly foster cooperation and social justice.
Let's review that dictionary definition. No need here, I hope, to say anything more about military or combat. So let's consider command. Command calls for hierarchy, for centralized and top-down directives, for concentrating power. Is that really how we want our movement to operate?
Further, strategy is large-scale. Most grassroots activism is anything but large-scale. Given the sheer size of the Pentagon and the imperium, we might wish we were operating on a larger scale, but we aren't.
Let's not forget the drawbacks of large-scale: depersonalization, lack of accountability and lack of respect for sentient life. Small is beautiful, big is problematic.
Am I arguing against mass movements? Hell no. But I question whether such motors of history emerge through "strategy."
Yet another element in the definition is overall planning. Overall planning (in contrast to mere planning) assumes that the planners have a grip on what's coming next. In this fast moving, complex world, even Pentagon strategists – with the most spies, the world's biggest computers, and the best-funded think tanks – tend to be clueless about the future. The Pentagon certainly wasn't able to predict what the US military was in for when it invaded such "weak" nations as Iraq … or Afghanistan … or Viet Nam.
For all its glamour, strategy – at least the US version – has a dismal track record. It's a failed tool. For better or worse, much of the Pentagon's strategic thinking involves deploying overwhelming force and throwing vast amounts of taxpayer money at preparing for every contingency. But that is a luxury few others, especially oppositional movements, can afford.
Strategy requires having some control over one's field of operation. Activists don't set the conditions, we respond to the conditions. And those conditions keep changing. Our work happens, not where we "call the shots," but – so to speak – where we are being shot at.
Such work is mostly reactive, a response to the onslaughts and injustices of those far more powerful than ourselves. Sometimes we're not reactive – for example, when we build alternative institutions or communities. But this proactive work calls for marrying values with planning. It's not "strategy."
Strategy requires resources. In its archetypal sense, it now demands immense resources. The Pentagon employs millions and spends billions, hundreds of billions. Our groups, by contrast, are understaffed; our few staff work overtime to generate their own salaries and rent. Although some of us bandy the word about, being "strategic" may well be a mode of operation beyond our wildest dreams.
And strategy should be beyond our wildest dreams. We have no business being strategic. There may even be something intrinsically co-opting about being in a position to strategize. Consider the Democratic Party. Once believed by some to be the party of the people, it's big enough and rich enough and corrupt enough to be … strategic.
Strategy, it seems, seeks wealth and power.
Dorothy Day contrasted faithfulness and effectiveness. We can argue over which should get priority, or about what the ratio between them should be. About this, seasoned activists can properly differ.
Those of us committed to nonviolence, however, while valuing effectiveness, are likely to favor faithfulness. If we are true to ourselves and to each other, effectiveness will emerge organically.
As Gandhi taught, nonviolence requires that means be consistent with ends. Strategy, insofar as it relies on hierarchy and force, is a stranger to consistent means and ends – at least when those ends are clothed, as they tend to be, in strategic deception (Bush's "bringing democracy to the Middle East," etcetera).
So, let us not hanker for the tinsel fruit of strategy. Let us focus on democratic process and developing our consciousness and our humane values. Let us avoid Gandhi's seven social sins. Let us reduce our own addictions, distractions and co-optations. And in doing so, let us develop an ever-deepening empathy, an ever-broadening solidarity.
And if we can't yet see the light at the end of the tunnel, still let us keep the flame of faithfulness burning bright.