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Large Tech Makes Inroads With the Biden Marketing campaign
WASHINGTON — Joseph R. Biden Jr. has been vital of Large Tech, admonishing Fb for mishandling incorrect information and announcing web firms will have to lose a central felony coverage.
However his marketing campaign has quietly welcomed onto its personnel and coverage teams individuals who have labored with or for Silicon Valley giants, elevating issues a number of the trade's critics that the firms are in quest of to co-opt a possible Biden management.
One among Mr. Biden's closest aides joined the marketing campaign from Apple, whilst others held senior roles at companies that consulted for primary tech firms. And a just about 700-person volunteer team advising the marketing campaign, the Innovation Coverage Committee, comprises no less than 8 individuals who paintings for Fb, Amazon, Google and Apple, in step with paperwork reviewed through The New York Instances. Different committee participants have shut ties to the firms, together with economists and legal professionals who've urged them, and officers at suppose tanks funded through them.
The crowd's participants additionally come with some outstanding progressives arguing for stiffer law of tech. However the presence of the trade's allies inside of Mr. Biden's coverage equipment and marketing campaign and transition groups — and his marketing campaign's effort to make sure the confidentiality of its coverage procedure — has alarmed an an increasing number of influential coalition of liberals who say the tech titans stifle pageant, omit consumer privateness and fail to adequately police hate speech and disinformation.
They're hoping to dissuade Mr. Biden, who has now not made tech problems a significant focal point of his marketing campaign, from following the instance of his former boss, President Barack Obama, whose include of tech firms helped flip them into darlings in Washington.
As of late the tech giants are looking to fend off new laws or antitrust court cases. The Justice Division and the Federal Business Fee have spent greater than a 12 months investigating Google, Fb, Amazon and Apple for conceivable violations of pageant legislation. Right through a Space listening to remaining month, lawmakers from each events grilled the executive executives of all 4 firms about accusations that their dominance had harm customers, opponents and small companies, in addition to what they have been doing to police false knowledge.
"The surroundings could be very other now," stated Robert D. Atkinson, the president of a suppose tank that has been funded partly through Google, the Data Era & Innovation Basis. "When Obama took place of work, you already know, tech was once like a bromance roughly factor. Everyone cherished it, and other people didn't see the problems that some other people see now."
A co-author of "Large Is Stunning: Debunking the Delusion of Small Industry," a 2018 e book, Mr. Atkinson is one of the allies of Large Tech at the Innovation Coverage Committee. Whilst he stated the participants represented "a quite various set of perspectives," he predicted {that a} possible Biden management would face vital force from the left to clamp down at the primary tech firms.
Matt Hill, a spokesman for Mr. Biden's marketing campaign, stated in a remark that the previous vice chairman would now not take it simple on Large Tech.
"Many generation giants and their executives have now not simplest abused their energy however misled the American other people, broken our democracy and refrained from any type of accountability," Mr. Hill stated. "Any individual who thinks that marketing campaign volunteers or advisers will alternate Joe Biden's elementary dedication to preventing the abuse of energy and stepping up for the center elegance doesn't know Joe Biden."
The tech coverage committee, which is damaged down into smaller uniqueness teams, is a part of a limiteless community of hundreds of coverage advisers assembled through the marketing campaign. The coverage groups should not have final authority over the marketing campaign's proposals or advise Mr. Biden without delay. However lobbyists and activists are gazing them intently for indicators of Mr. Biden's method to problems and his conceivable hiring pool if he's elected.
Mr. Biden's marketing campaign and transition staff come with advisers with ties to tech firms and different industries that concern liberals. Avril Haines, a former Obama nationwide safety and intelligence authentic who helps to guide Mr. Biden's transition staff, was once a expert for the data-mining corporate Palantir and WestExec Advisors, a company that represented a significant tech corporate it hasn't known.
A WestExec co-founder and Obama State Division authentic, Antony J. Blinken, is working the Biden marketing campaign's overseas coverage operation. WestExec has labored with the philanthropy began through Eric Schmidt, the previous Google chairman, and with Google's in-house incubation unit, Jigsaw. However Mr. Blinken and Ms. Haines didn't take part in that paintings, in step with the Biden marketing campaign, which stated each advisers stepped clear of WestExec this month.
Cynthia C. Hogan, a former White Space attorney for Mr. Biden who's serving to to guide his vice-presidential variety procedure, was once a lobbyist and executive affairs govt at Apple. She tendered her resignation from the corporate in April, in step with the Biden marketing campaign.
A spokeswoman for Google stated in a remark that workers labored with campaigns of their non-public capacities and now not as representatives of the corporate. Apple stated an worker taking part within the Biden coverage procedure was once doing so on his personal time right through nights and weekends. Fb declined to remark at the committee however pointed to a coverage that permits workers to interact in political actions on their non-public time. Amazon declined to remark.
A number of the contributors within the massive tech coverage committee are Fb's director of world pageant coverage, Anant Raut, and Matt Perault, who testified as director of public coverage for the corporate right through a congressional antitrust investigation remaining 12 months earlier than departing for academia.
Some other member is Howard Shelanski, a spouse on the legislation company Davis Polk who represents Fb within the Federal Business Fee's antitrust investigation into the corporate. He isn't operating with the crowd of committee participants coping with questions concerning the tech platforms, stated an individual aware of his involvement, who would discuss simplest anonymously.
Nonetheless extra participants paintings for organizations, like Mr. Atkinson's, that obtain investment from the firms or are economists who've consulted for Amazon, Google and Apple. Mr. Atkinson himself isn't a member of the antitrust team.
The committee is split into smaller teams that target problems like antitrust coverage, synthetic intelligence, broadband get admission to, disinformation and information privateness. The antitrust team comprises other people with tech ties like Mr. Perault, Mr. Raut and Mr. Shelanski. But it surely additionally comprises some individuals who have driven for extra scrutiny of the tech giants, together with workers at rival firms in addition to the activist Sarah Miller and Tim Wu, a professor at Columbia Regulation Faculty, outstanding critics who've referred to as for extra lively antitrust enforcement. (Mr. Wu could also be a contributing opinion author at The Instances.)
The Biden marketing campaign known two aides, Bruce Reed and Stef Feldman, as extra without delay counseling the previous vice chairman on generation problems. The marketing campaign stated Mr. Blinken was once now not advising the marketing campaign on home generation coverage. It stressed out that participants of its coverage committees weren't there to constitute their employers or purchasers, and that lobbyists — except for those that constitute hard work unions — have been barred from taking part.
After The Instances requested participants of the tech coverage volunteer team about their paintings, a few of them won a message "to remind everybody that the paintings we're doing this is for the aim of growing coverage positions which can be sound and in the most productive passion of the candidate and his election as president."
The message famous that there have been "various rumors floating round" about how "the marketing campaign is managing conflicts of passion and lobbying through company and different pursuits." And it said that whilst "it's occasionally exhausting to split one's non-public perspectives from the ones of 1's employer or purchasers," participants will have to do their "highest to make sure that the guidelines that you just be offering up and the contributions that you are making are in line with what's highest for the candidate and now not what's right for you or your purchasers or your employer."
A checklist of laws equipped to participants of the coverage teams, a replica of which was once acquired through The Instances, instructs contributors to not reveal their participation "on social media comparable to Fb or LinkedIn or for your skilled bio." It additionally warns them now not to speak about or distribute names of different committee participants, contents of committee conversations, emails from the committee or to speak to the scoop media.
"Merely put, don't communicate to the clicking," the file reads, emphasizing "don't communicate to the clicking" in boldface.
A number of participants of the tech committee adopted that steerage, declining to speak about their involvement and referring questions to the marketing campaign. However some participants of the antitrust subgroup expressed optimism {that a} Biden management would usher in additional rigorous approaches to the legislation.
"We're in reality on the crux of wanting some very, very sturdy management on antitrust and pageant, and a few strengthening of the regulations," stated Diana L. Moss, a member of the antitrust subgroup and president of the American Antitrust Institute, whose suppose tank has approved budget from Amazon and Google.
"We've had 40 years of lax enforcement and the entire harm to turn out it," she stated, stressing that she was once talking for herself and now not the Biden coverage committee.
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Trump Marketing campaign Site Is Defaced by means of Hackers
President Trump's marketing campaign website online used to be in brief taken over by means of hackers who defaced the website on Tuesday.
The defacement lasted not up to 30 mins, however the incident got here as Mr. Trump's marketing campaign and that of his opponent, Joseph R. Biden Jr., in addition to legislation enforcement and intelligence businesses, were on prime alert for virtual interference forward of subsequent week's election.
In a remark, Tim Murtaugh, a spokesman for the Trump marketing campaign, showed the website online's defacement and stated it used to be "operating with legislation enforcement government to research the supply of the assault." He added, "There used to be no publicity to delicate knowledge as a result of none of it's in fact saved at the website. The website online has been restored."
The F.B.I. didn't instantly remark at the incident. The defacement used to be first famous on Twitter by means of Gabriel Lorenzo Greschler, a journalist on the Jewish Information of Northern California, whilst he used to be researching an editorial on local weather exchange.
It used to be no longer transparent whether or not the defacement used to be the paintings of overseas hackers or cybercriminals. However in a screed posted to Mr. Trump's website online — donaldjtrump.com — the hackers claimed to have compromised "more than one gadgets" that gave them get entry to to the "maximum inside and secret conversations" of the president and his family members, together with labeled knowledge.
The hackers additionally accused the Trump management, with out evidence, of getting a hand within the origins of the coronavirus and cooperating with "overseas actors manipulating the 2020 elections."
The hackers seemed to be having a look to generate cryptocurrency. They invited guests to donate cryptocurrency to considered one of two price range — one classified "Sure, proportion the knowledge," the opposite classified "No, Don't proportion the knowledge." They solicited bills in Monero, a hard-to-trace cryptocurrency.
"After the cut-off date, we will be able to examine the price range and execute the desire of the arena," they wrote, with out specifying a cut-off date. The hackers additionally posted what they stated used to be their encryption key, ostensibly to ensure that no matter knowledge they posted got here from them. The important thing corresponded to an e mail cope with at a nonexistent web website.
Regardless that the defacement seemed to be a part of a not unusual cryptocurrency rip-off to get other people to irreversibly donate cash on-line, the incident took on added urgency one week prior to the election. Cybersecurity mavens stated that the incident can have been led to by means of tricking a website online administrator into turning over their credentials, in what's referred to as a phishing assault, or by means of redirecting the marketing campaign website online to the hacker's personal server.
Intelligence businesses were intently tracking hacking teams, together with groups sponsored by means of Iran and Russia, that experience attempted to wreck into election-related methods and feature been eager about affect operations in contemporary weeks.
Closing week, John Ratcliffe, the director of nationwide intelligence, recognized Iran and Russia as two countries liable for disinformation and a few restricted intrusions into voter registration databases.
He cited threatening emails, ostensibly from the far-right staff the Proud Boys, that have been despatched to citizens in Florida and in different places. However the emails depended on publicly-available knowledge; no hacking used to be vital. And so they have been written in damaged English — as used to be the defaced Trump website online.
Closing week, Mr. Trump advised a marketing campaign rally in Tucson, Ariz., "No person will get hacked. To get hacked you want anyone with 197 I.Q. and he wishes about 15 p.c of your password."
Julian E. Barnes, Adam Goldman and David E. Sanger contributed reporting.
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The 12 months in Incorrect information, So A long way
This has been, through any measure, a nasty 12 months for consensus truth.
First, there used to be President Trump's impeachment — a divisive and emotionally charged continuing that unleashed a torrent of lies, exaggerations and viral innuendo.
Then got here the Covid-19 pandemic — an excellent larger alternative for cranks, conspiracy theorists and wishful thinkers to divide us alongside epistemic traces, into those that believed the mavens and people who most popular to "do their very own analysis."
The Black Lives Subject protests this summer season had been a feeding frenzy for the ones taking a look to distort and reframe the narrative about police violence and racial justice.
And whilst election years are at all times busy instances for fact-checkers, Mr. Trump's fusillade of falsehoods about voter fraud, Spygate and Hunter Biden's emails this 12 months has ended in a larger problem for the ones charged with isolating reality from fiction.
Zignal Labs, a company that tracks on-line incorrect information, analyzed which main information subjects in 2020 had been in all probability to generate incorrect information. Its information, which attracts from resources together with social media apps like Fb, Twitter, Instagram and Reddit, in addition to newspapers and broadcast TV transcripts, isn't an actual accounting of each and every unmarried piece of incorrect information in the market. Nevertheless it's a coarse gauge of which subjects are maximum continuously used as automobiles for incorrect information, through the ones taking a look to inject confusion and chaos into media narratives.
(Fast methodological observe: Those "incorrect information mentions" are restricted to subjects associated with both the election or the Covid-19 pandemic, and are calculated through Zignal's automatic machine in response to the choice of mentions of a given time period together with a time period this is continuously related to incorrect information. So, for instance, a submit that mentions vaccines within the context of Covid-19 would no longer be counted as a incorrect information point out, however a submit that mentions vaccines together with a hashtag like #FauciTheFraud or a reputation like Invoice Gates — a common goal of anti-vaccine activists — can be counted, even supposing the underlying tale used to be debunking this kind of false declare.)
The subject in all probability to generate incorrect information this 12 months, in step with Zignal, used to be an previous standby: George Soros, the liberal financier who has featured prominently in right-wing conspiracy theories for years.
Out of two.6 million overall media mentions of Mr. Soros up to now this 12 months, just about part (1.1 million) had been accompanied through phrases ("Soros-funded," "bankroll") that recommended that he performed a job in investment left-wing agitators. They peaked this summer season, as false claims that Mr. Soros had funded Black Lives Subject protests went viral following the killing of George Floyd.
2d at the checklist used to be Ukraine, which peaked as a incorrect information matter in January and February, all over Mr. Trump's impeachment complaints together with key phrases like "deep state" and "WWG1WGA," a shorthand utilized by fans of the QAnon conspiracy motion. About 34 % of Ukraine's 9.2 million overall media mentions had been flagged as misinformation-related.
3rd used to be vote-by-mail, which has been the topic of a torrent of incorrect information through Mr. Trump and right-wing media retailers. Kind of one out of each and every 5 vote-by-mail tales in 2020 has been incorrect information, in step with Zignal's research, with phrases like "fraud" and "rip-off" being commonplace pink flags.
With all 3 topics, one of the maximum commonplace spreaders of incorrect information had been right-wing information websites like Breitbart and The Gateway Pundit. YouTube additionally served as a big supply of incorrect information about those subjects, in step with Zignal.
After all, the incorrect information we've noticed up to now this 12 months would possibly faded compared to what occurs after subsequent week's election, if a contested end result or allegations of fraud lead to a brand new wave of false or deceptive claims. Social media platforms have signaled that they are going to take away untimely claims of victory, and makes an attempt to delegitimize the election. However additionally they pledged to take down incorrect information about Covid-19, and feature had handiest combined luck in doing so.
Listed here are the themes that generated the best share of incorrect information narratives:
1. George Soros (45.7 % incorrect information mentions)
2. Ukraine (34.2 %)
3. Vote through Mail (21.Eight %)
4. Bio Weapon (24.2 %)
5. Antifa (19.Four %)
6. Biden and Defund the Police (14.2 %)
7. Hydroxychloroquine (9.2 %)
8. Vaccine (8.2 %)
9. Anthony Fauci (3.2 %)
10. Mask (0.Eight %)
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Trump Allies Amp Up Combat Over Tech's Prison Defend Prior to Election
WASHINGTON — In September, the White Area nominated a legal professional to be a commissioner at the Federal Communications Fee. One line on his résumé: helping the management's push to restrict a very powerful felony protect for Silicon Valley firms.
That very same month, the Justice Division despatched Congress an in depth proposal for the best way to exchange the regulation at the back of that felony protect.
And on Wednesday, lawmakers will confront the manager executives of Fb, Google and Twitter. The subject of debate: whether or not that regulation permits dangerous conduct from the corporations.
The Trump management and its allies have fanned out broadly in Washington in fresh months to assault that regulation, Segment 230 of the Communications Decency Act. The regulation is thought of as sacred by means of social media platforms like Fb, Google and Twitter, as it protects them from legal responsibility for content material posted by means of their customers.
Increasingly more, the regulation is criticized by means of politicians of each events. Joseph R. Biden Jr., the Democratic nominee for president, has referred to as for it to be revoked, announcing it lets in the corporations to shirk accountability over what seems on their websites.
However President Trump and Republican lawmakers had been more and more vocal within the months prior to Election Day, announcing the corporations have concealed at the back of the regulation to suppress conservative perspectives. Their frustration flared up once more two weeks in the past when Twitter and Fb restricted the distribution of an unsubstantiated New York Put up article that used to be important of Mr. Biden's son Hunter.
Their animosity is perhaps on complete show at Wednesday's listening to, when Republicans at the Senate Trade Committee like Marsha Blackburn of Tennessee and Ted Cruz of Texas are anticipated to assault the manager executives.
Republicans have invoked the problem as "a cudgel," mentioned Olivier Sylvain, a regulation professor at Fordham College who has argued for adjustments to Segment 230. Mr. Trump, he mentioned, is "making some extent along with his base."
Judd Deere, a White Area spokesman, mentioned the president have been transparent about why the problem used to be necessary to deal with.
"He believes the tech monopolies are proscribing American citizens' freedom of speech," Mr. Deere mentioned, "and his management is taking steps to resolve this downside."
Google, Fb and Twitter have mentioned up to now that they are trying to restrict the achieve of deceptive data on their platforms, however that they don't make choices according to political affairs. Google declined to remark. Fb and Twitter pointed to the ready testimony from their leader executives.
The proof that conservative speech is matter to unfair remedy on-line has all the time been anecdotal. And lots of conservative personalities, just like the commentator Ben Shapiro, have constructed massive audiences at the platforms.
The felony protect, handed within the 1996, has performed a key function within the enlargement of Silicon Valley. It has allowed firms like Fb and Twitter to increase unexpectedly with out taking up extra felony legal responsibility with each and every new submit.
The White Area's efforts to weaken the regulation started in earnest closing yr when Mr. Trump hosted a Social Media Summit with right-wing influencers, a lot of whom level to anecdotal proof to mention the platforms have suppressed their perspectives. The attendees incorporated individuals who had unfold conspiracies or doctored content material.
In Would possibly, Twitter implemented fact-checking labels to 2 tweets by means of Mr. Trump that made false claims about voter fraud. Days later, the White Area introduced that Mr. Trump had signed an govt order intended to slender the protections for the tech firms.
Many legal professionals and mavens mentioned the president used to be exceeding his energy with the manager order, which ordered the Trade Division to petition the Federal Communications Fee, an unbiased company, to modify its interpretation of the regulation.
In a speech quickly after the Trade Division request, Michael O'Rielly, one of the crucial 3 Republican commissioners on the F.C.C., perceived to rebuke the request on free-speech grounds.
"It's time to prevent permitting purveyors of First Modification gibberish to say they give a boost to extra speech, when their movements shed light on that they'd if truth be told curtail it thru govt motion," he mentioned.
On the time, Mr. O'Rielly used to be looking forward to Senate affirmation to a brand new time period on the company. He mentioned his feedback weren't a critique of Mr. Trump,
The White Area rescinded Mr. O'Rielly's nomination 5 days after his speech with out a proof. In his position, it nominated Nathan Simington, a Trade Division legal professional who helped write the petition that requested the F.C.C. to restrict the regulation. Mr. Trump tweeted in give a boost to of Mr. Simington's nomination.
This month, the fee's Republican chairman, Ajit Pai, mentioned he would take steps to imagine the proposal to restrict the regulation.
"Social media firms have a First Modification appropriate to loose speech," Mr. Pai mentioned in an Oct. 15 remark. "However they don't have a First Modification appropriate to a distinct immunity denied to different media retailers, similar to newspapers and broadcasters."
The White Area and its allies have additionally attempted to prod the Federal Business Fee, which polices the claims that businesses make to shoppers, to deal with its considerations with the regulation.
Mr. Trump's govt order requested the business fee to analyze proceedings about how social media firms reasonable their content material, having a look at whether or not they violate the prohibition on "unfair and misleading" practices. At a listening to in August, Senator Roger Wicker, Republican of Mississippi, requested the company's chairman whether or not it had taken motion at the order but.
The chairman, Joseph J. Simons, driven again. "Our authority makes a speciality of business speech, now not political content material curation," he mentioned. Mr. Trump additionally met with Mr. Simons in fresh months to talk about the problem, mentioned an individual with wisdom of the assembly, who would discuss best anonymously since the individual used to be now not licensed to speak publicly in regards to the assembly.
Mr. Trump's allies at the Senate Trade Committee are anticipated to spend the Wednesday listening to asking Mark Zuckerberg of Fb, Jack Dorsey of Twitter and Sundar Pichai of Google in regards to the firms' content material moderation and use of the felony protect. The Senate Judiciary Committee has additionally subpoenaed Mr. Dorsey and Mr. Zuckerberg to testify about the best way they take care of content material, in a listening to scheduled for after the election.
Senator Josh Hawley, a Missouri Republican at the Judiciary Committee, mentioned that just because some conservative personalities have been thriving on-line didn't negate cases when conservative content material have been taken down. And he disagreed with fighters who say the fitting is solely looking to paintings the referees of the guidelines age.
"The purpose is, there shouldn't be refs," Mr. Hawley mentioned.
Many Democrats say the management's movements — and the ones of its allies in Congress — are little greater than political theater. Some instructional critics of Segment 230, too, say the management's assaults appear extra rooted in politics than a want for a particular coverage consequence.
"There's merely no explanation why to have this listening to simply previous to the election, except for that it should intimidate the platforms, who've proven themselves to be at risk of political blunt power up to now," Senator Brian Schatz, Democrat of Hawaii, wrote in a tweet in regards to the Wednesday listening to.
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subset: commoncrawl


text:
No. 2:15-cv-1598 JAM KJN P
Plaintiff is a state prisoner, proceeding without counsel. Defendants' motion for terminating and monetary sanctions is before the court. As discussed below, defendants' motion is partially granted.
I. Plaintiff's Second Amended Complaint
Plaintiff alleges that despite being acquitted by a jury of an attempted murder charge, defendants Sgt. Gregory and the Sacramento County Sheriff's Department failed to correct their records. In 2015, plaintiff confirmed that the jail locator card continued to reference the attempted murder charge, despite plaintiff's acquittal. He contends that the failure to correct these records subjects him to continual torment by jail staff, and results in further trumped-up charges against him. Plaintiff claims his efforts to correct such records have failed. Liberally construed, the court found plaintiff's second amended complaint stated a potentially cognizable due process claim against defendants based on their alleged failure to correct their internal records to reflect that plaintiff was acquitted by a jury of the attempted murder charge.
On July 9, 2019, plaintiff's request to substitute the correct individual's name for defendant Alexander's name was granted, and defendant Gregory's name was ordered interlineated in place of Sgt. Alexander's name. (ECF No. 68.) The instant motion was brought by defendants Gregory and the Sacramento County Sheriff's Department.
II. Procedural History
This action was filed on July 24, 2015. Following multiple amendments, plaintiff's due process claims against defendant Alexander and the Sacramento County Sheriff's Department contained in his second amended complaint, filed November 17, 2016, were found potentially cognizable, and his remaining claims were dismissed. (ECF Nos. 26, 29.)
On January 2, 2019, the court issued its discovery and scheduling order; all discovery was to be completed by April 26, 2019. (ECF No. 48.) On January 29, 2019, defendant County propounded its first set of special interrogatories and a request for production of documents ("RPD"). (ECF No. No. 58-2 at 9-12 (RPD).) On March 3, 2019, plaintiff wrote defense counsel, stating plaintiff would "be able to respond" to the RPD "after [defendant] comply/respond [sic] with [his] request for documents (set two)." (ECF No. 58-2 at 40.) Defendant County responded to plaintiff's RPD (set two) on February 28, 2019, but plaintiff did not respond to defendant's first RPD.
Defendant County's RPD included twelve requests for production of documents supporting plaintiff's responses to special interrogatory Nos. 5, 9, 13, 17, 21, and 23 (ECF No. 58-2 at 9, 18-19); documents that refer or relate to evidence plaintiff's locator card violated plaintiff's rights, evidence any damages claimed herein; any communication between plaintiff and defendant related to the instant allegations; any and all notes, notebooks, diaries, journals or other documents made by plaintiff that refer or relate to plaintiff's instant allegations; any documents that refer or relate to evidence defendant treats plaintiff differently from similarly situated inmates because of the attempted murder charge on plaintiff's locator card; and any documents that refer or relate to any witness statements pertaining to plaintiff's instant allegations. (ECF No. 58-2 at 11-12.)
On March 26, 2019, defendant County filed a motion to compel responses to the first set of special interrogatories and RPD. (ECF No. 58.) In plaintiff's opposition, he complained he was unable to gain access to the law library to make the appropriate photocopies.
In his unauthorized sur-reply, plaintiff stated that he had nearly 300 pages to provide to defendants, but could not provide copies because he only has one copy, and is deprived of duplicating services by Corcoran State Prison. (ECF No. 62 at 3, 6.)
Plaintiff was deposed on April 5, 2019. (ECF No. 79-4 at 114.)
On May 14, 2019, the court partially granted defendant County's motion to compel; plaintiff was ordered to file further responses to certain special interrogatories. (ECF No. 64.) Because of the alleged law library access issues, plaintiff was granted an additional thirty days in which to respond to defendant County's RPD, and the court requested the prison litigation coordinator assist plaintiff in gaining timely law library access in order to photocopy the responsive documents. (ECF No. 64.) The court also noted that plaintiff's March 3, 2019 letter to defense counsel suggested plaintiff was engaging in gamesmanship rather than cooperating in good faith in discovery. (ECF No. 64 at 6.) The court warned plaintiff that failure to cooperate in discovery may result in the imposition of sanctions including, but not limited to, a recommendation that this action be dismissed. (ECF No. 64 at 6.) Plaintiff was advised that if his failure to provide the documents was due to an inability to photocopy, plaintiff could have asked defense counsel for an extension of time, or made arrangements with defense counsel to exchange documents at the deposition, where counsel could have assisted plaintiff in obtaining photocopies. (ECF No. 64 at 6-7.) The discovery and pretrial motions deadlines were also extended.
On May 28, 2019, plaintiff wrote defendant County's lawyer stating plaintiff had "enclosed a copy of all documents responsive to your discovery request." (ECF No. 66-1 at 52, 97 (emphasis added).) Plaintiff stated he had "no intent to withhold discovery," and it was the CDCR and its personnel who obstructed plaintiff's efforts to comply. Plaintiff claimed that although the documents were named and numbered as Smith v. CDCR, No. 2:18-cv-02942 KJM AC, such documents "are a part of both cases." (ECF No. 66-1 at 52.)
Despite having purportedly produced all documents, on June 17, 2019, plaintiff filed another request for extension of time to produce the documents. (ECF No. 65.) Plaintiff claimed he was granted only six hours of law library access, despite the court's order, and had not complied fully with the discovery requests. Plaintiff claimed he had about 600 pages of relevant documents but had provided only 150 pages due to the 50-page limit imposed by the prison law library. Despite completing request for approval forms, the law library supervisor had not approved them, limiting plaintiff to 50 pages per visit (he was able to visit three times - May 23, 2019; May 30, 2019; and June 3, 2019). Plaintiff stated that he provided counsel with a cover letter explaining plaintiff would be providing 50 pages at a time due to the prison's policy. (ECF No. 65 at 6.) Plaintiff claimed he provided the same documents on the same dates to the court in Case No. 2:18-cv-02942 KJM AC because the documents are also relevant and material in that case. Plaintiff further claimed that he was not provided ducats to attend law library despite being scheduled for June 10, 2019, and was denied access on June 13, 2019.
Significantly, court records in Case No. 2:18-cv-02942 KJM AC reflect the following filings by plaintiff during this time frame:
(1) On June 3, 2019, plaintiff's 45page filing included a 25page supplemental complaint with 20 pages of exhibits (ECF No. 12);
(2) On June 10, 2019, plaintiff's 52page filing included a onepage notice of correct name of defendant, accompanied by 51 other documents (ECF No. 13); and
(3) On June 10, 2019, plaintiff submitted a 53page filing; in the cover letter plaintiff asked the court to excuse his "piecemeal lodging of documents" stating he was only able to receive 50 pages at a time, and noting that "these documents are labeled for another case but apply to Case # 2:18cv02942 KJM AC" (ECF No. 14 at 1). However, the attached documents bearing a case number at the top all reference Case No. 2:18cv02942 KJM AC. Id. (ECF No. 14 at 453.) A court may take judicial notice of court records. See, e.g., Bennett v. Medtronic, Inc., 285 F.3d 801, 803 n.2 (9th Cir. 2002) ("[W]e may take notice of proceedings in other courts, both within and without the federal judicial system, if those proceedings have a direct relation to matters at issue") (internal quotation omitted).
On June 24, 2019, defendant County opposed plaintiff's request for extension of time, noting that they had received three sets of documents totaling 143 pages, each bearing the header of plaintiff's other case, No. 2:18-cv-02942 KJM AC. (ECF No. 66 at 2.) Indeed, review of the documents produced included plaintiff's supplemental complaint filed in case No. 2:18-cv-2942 KJM AC, as well as incident and disciplinary reports dated from 2016-2018 in various correctional facilities, and a copy of plaintiff's habeas petition decision issued from state court. (ECF No. 66-1 at 2; 5-142.) Moreover, plaintiff failed to produce a pleading or verification responsive to defendant County's RPD. (ECF No. 66 at 2.) Defendant County argued that plaintiff was misusing the discovery process by using his copy privileges to lodge nonresponsive documents intended for a separate case, rather than producing documents responsive to defendant County's RPD.
On July 4, 2019, plaintiff signed a motion for summary judgment, accompanied by 29 pages of exhibits, filed with the court on July 12, 2019. (ECF No. 70.)
On July 12, 2019, plaintiff also filed a response to defendants' opposition to plaintiff's motion for request for extension of time. (ECF No. 69.) However, plaintiff's response was signed on July 4, 2019, and the appended proof of service, which notes only the service of plaintiff's motion for summary judgment, was dated July 8, 2019 (ECF No. 69 at 23). Defendants' opposition was filed on June 24, 2019. Under Local Rule 230(l), plaintiff's reply was due seven days later, June 30, 2019. But because June 30, 2019 is a Sunday, plaintiff had until Monday, July 1, 2019, to present his reply to prison authorities for mailing. Because plaintiff's reply is untimely filed, the court disregards the filing (ECF No. 69).
On July 9, 2019, the court found plaintiff had failed to respond to the RPD propounded by defendant County in January, despite the court's May 14, 2019 order, and denied plaintiff's request for a further extension of time. (ECF No. 68.) Defendant County was granted thirty days to file a motion for expenses or sanctions.
Plaintiff's motion to amend was also denied, and his request to substitute Sgt. Gregory in place of Sgt. Alexander as a defendant was granted. (ECF No. 68.)
On July 17, 2019, defendants County and Sgt. Gregory filed a motion for terminating and monetary sanctions. Defendants point out that the request for production of documents asked plaintiff to provide documents evidencing that defendant violated plaintiff's due process rights in the Sacramento County Main Jail between 2013 and 2015, as alleged in the operative complaint. Defendants acknowledge receiving "150 largely unresponsive documents from plaintiff on June 10, 2019." (ECF No. 71-1 at 4, citing ECF No. 66-1 at 5-142.) Defendants argue that plaintiff has not served any documents responsive to the RPD, including a pleading or verification form. Importantly, defendants also object that the majority of the documents appended to plaintiff's motion for summary judgment were not produced by plaintiff to defendants through discovery. (ECF No. 71-1 at 4; 71-2 at 2.) In addition to terminating sanctions, defendants request reimbursement of $1,440.00 in attorneys' fees incurred in bringing the motion. (ECF No. 71-2 at 2.)
On July 29, 2019, plaintiff filed his opposition to the motion for terminating sanctions. (ECF No. 74.) Plaintiff asks the court to forward to defendants plaintiff's motion for summary judgment and attached exhibits. (ECF No. 74 at 2.) Plaintiff states that the documents he produced to defendants were accompanied by plaintiff's letter explaining that such documents were responsive to the RPD and request for special interrogatories, despite bearing the case number of his other case. Plaintiff now argues that the "relevant documents demonstrate the pain and suffering caused by the defendants' deliberate indifference not only in Sacramento County Main Jail but also in the CDCR." (ECF No. 74 at 2.) Plaintiff reiterates his claim that his law library access has been impeded by the CDCR. Plaintiff contends that he has been diligent, the merits of his case warrant ruling on the merits, and that it would not be fair, just or equitable to impose sanctions for plaintiff's inaction because it was caused by CDCR personnel. (ECF No. 74 at 2-3.) Plaintiff's opposition was dated July 23, 2019. (ECF No. 74 at 3.)
Significantly, court records show that in July, plaintiff filed the following documents in Case No. 2:18-cv-02942 KJM AC:
(1) On July 18, 2019, plaintiff's 49page filing included his 13page motion for injunctive relief, and 35 exhibits (ECF No. 18);
(2) On July 29, 2019, plaintiff's 314page filing included his 44page amended complaint, and 270 exhibits (ECF No. 19); and
(3) On July 29, 2019, plaintiff filed a sixpage "motion of apology" (ECF No. 20).
Defendants did not file a reply.
III. Defendants' Motion for Terminating and Monetary Sanctions
As set forth above, defendants move for sanctions against plaintiff for his willful failure to comply with the court's May 14, 2019 order, and requests monetary sanctions be imposed in the amount of $1,440.00 for fees incurred in bringing such motion. (ECF No. 71-1 at 2.) //// ////
A. Legal Standards Governing Sanctions
Broad sanctions may be imposed against a person or party for failure to obey a prior court order compelling discovery. Rule 37(b)(2) of the Federal Rules of Civil Procedure provides that if a party fails to obey an order to provide or permit discovery, the Court may issue further just orders, which may include prohibiting the disobedient party from supporting or opposing designated claims or defenses, or from introducing designated matters in evidence. Fed. R. Civ. P. 37(b)(2)(A). The Court also may dismiss the action or proceeding in whole or in part. Id. Dismissal and default are such drastic remedies, they may be ordered only in extreme circumstances -- i.e., willful disobedience or bad faith. In re Exxon Valdez, 102 F.3d 429, 432 (9th Cir. 1996). Even a single willful violation may suffice depending on the circumstances. Valley Eng'rs Inc. v. Elec. Eng'g Co., 158 F.3d 1051, 1056 (9th Cir. 1998) (dishonest concealment of critical evidence justified dismissal).
The dismissal sanction is not limited to claims against the defendant who propounded the discovery. The court has discretion to order dismissal against all defendants prejudiced by plaintiffs' discovery violations (e.g., where one was relying on discovery efforts undertaken by the other). Payne v. Exxon Corp., 121 F. 3d 503, 510 (9th Cir. 1997).
Additionally, Local Rule 110 provides that "[f]ailure . . . of a party to comply . . . with any order of the Court may be grounds for imposition by the Court of any and all sanctions . . . within the inherent power of the Court." Id. District courts have the inherent power to control their dockets and "[i]n the exercise of that power they may impose sanctions including, where appropriate, . . . dismissal." Thompson v. Hous. Auth., 782 F.2d 829, 831 (9th Cir. 1986) (per curiam). Terminating sanctions may be warranted where "discovery violations threaten to interfere with the rightful decision of the case." Conn. Gen. Life Ins. Co. v. New Images of Beverly Hills, 482 F.3d 1091, 1097 (9th Cir. 2007).
B. Standards Governing Terminating Sanctions
District courts retain broad discretion to control their dockets and "[i]n the exercise of that power they may impose sanctions, including where appropriate, default or dismissal." Adams v. California Dep't of Health Servs., 487 F.3d 684, 688 (9th Cir. 2007) (brackets in original) (quoting Thompson, 782 F.2d at 831). "[C]ourts have inherent power to dismiss an action when a party has willfully deceived the court and engaged in conduct utterly inconsistent with the orderly administration of justice." Fjelstad v. American Honda Motor Co., Inc., 762 F.2d 1334, 1338 (9th Cir. 1985) (internal quotations and citation omitted); see, e.g., Anheuser-Busch, Inc. v. Natural Beverage Distrib., 69 F.3d 337, 348 (9th Cir. 1995) (upholding dismissal where party engaged in deceptive practices that undermined the integrity of the proceedings). But such a harsh penalty "should be imposed as a sanction only in extreme circumstances." Thompson, 782 F.2d at 831 (citing Henderson v. Duncan, 779 F.2d 1421, 1423 (9th Cir. 1986)). Courts have dismissed an action with prejudice for various reasons. See e.g., Malone v. United States Postal Service, 833 F.2d 128, 130-31 (9th Cir. 1987) (dismissal for failure to comply with court order); Henderson, 779 F.2d at 1424 (dismissal for failure to prosecute and for failure to comply with local rules); Sanchez v. Rodriguez, 298 F.R.D. 460, 464 (C.D. Cal. 2014) (applied terminating sanctions for pro se plaintiff's failure to respond to discovery requests).
Adams was overruled on other grounds by Taylor v. Sturgell, 553 U.S. 880, 904 (2008).
Accordingly, the Ninth Circuit permits imposition of such terminating sanctions only after the district court has weighed: "(1) the public's interest in expeditious resolution of litigation; (2) the court's need to manage its docket; (3) the risk of prejudice to the defendants; (4) the public policy favoring disposition of cases on their merits and (5) the availability of less drastic sanctions." Thompson, 782 F.2d at 831; Conn. Gen. Life Ins. Co., 482 F.3d at 1096 ("Only 'willfulness, bad faith, and fault' justify terminating sanctions.") (quoting Jorgensen v. Cassiday, 320 F.3d 906, 912 (9th Cir. 2003)).
Plaintiff is a pro se prisoner, and the court is mindful of precedent directing lenience in the interpretation of plaintiff's pleadings. The pleadings of pro se litigants are held to "less stringent standards than formal pleadings drafted by lawyers." Haines v. Kerner, 404 U.S. 519, 520 (1972). Such lenience is important in a civil rights case, where "the court must construe the pleadings liberally and afford the plaintiff the benefit of any doubt." Karim-Panahi v. L.A. Police Dep't, 839 F.2d 621, 623 (9th Cir. 1988); see also Ferdik v. Bonzelet, 963 F.2d 1258, 1261 (9th Cir. 1992) (The rule of liberal construction is "particularly important in civil rights cases."). Nevertheless, while courts construe pleadings liberally in favor of pro se litigants, pro se plaintiffs remain bound by the applicable procedural rules. See Ghazali v. Moran, 46 F.3d 52, 54 (9th Cir. 1995); King v. Atiyeh, 814 F.2d 565, 567 (9th Cir. 1987) (overruled on other grounds by Lacey v. Maricopa Cnty., 693 F.3d 896 (9th Cir. 2012)). "A party's lack of counsel may be considered in evaluating the willfulness of discovery violations and the failure to obey orders and in weighing the other factors regarding dismissal, but pro se status does not excuse intentional noncompliance with discovery rules and court orders." Sanchez, 298 F.R.D. at 470 (collecting cases).
C. Prior Warnings
On April 18, 2018, the parties were warned that the failure of any party to comply with the Federal Rules of Civil Procedure or the Local Rules of Court may result in the imposition of sanctions including, but not limited to, dismissal of the action or entry of default. (ECF No. 30 at 5, citing Fed. R. Civ. P. 41(b).)
On May 14, 2019, plaintiff was warned that his failure to cooperate in discovery may result in the imposition of sanctions, including, but not limited to, a recommendation that this action be dismissed. (ECF No. 64 at 6.)
D. Discussion
1. Was plaintiff's failure to cooperate in discovery willful?
Before imposing terminating sanctions, due process requires that a Court find that a litigant's conduct was the result of "willfulness, bad faith, or fault." Hyde & Drath v. Baker, 24 F.3d 1162, 1167 (9th Cir. 1994) (citing Wyle v. R.J. Reynolds Indus., 709 F.2d 585, 589 (9th Cir. 1983)). To find that a litigant has acted with "willfulness, bad faith, or fault," a court need only find that the failure to participate in discovery was "disobedient conduct not shown to be outside the control of the litigant." Fjelstad, 762 F.2d at 1341. The willfulness standard simply requires that the "punished conduct [is] within the litigant's control." Id. On the other hand, if the failure to produce is the result of circumstances outside of the recalcitrant party's control or an inability to fulfill the party's litigation obligations, dismissal is not proper. United States v. Sumitomo Marine & Fire Ins. Co., Ltd., 617 F.2d 1365, 1369 (9th Cir. 1980).
In light of plaintiff's initial claim of limited access to the law library, the court declined to grant defendants' motion to compel responses to the RPD, and instead granted plaintiff an extension of time to respond. However, despite the court's warning in such order, plaintiff submitted over 100 pages of documents to defendants that were nonresponsive to the RPD, and appeared destined for filing in plaintiff's other case, Smith v. CDCR, No. 2:18-cv-02942 KJM AC, as evidenced by plaintiff's June 3, 2019 filing of the supplemental complaint (ECF No. 12), followed by two more filings of over 50 pages on June 10, 2019 (ECF Nos. 13, 24), all in his other case. Id.
Plaintiff's sole argument that he produced such documents in this case because such documents evidence his pain and suffering caused by defendants' deliberate indifference appears to be his belated attempt to justify his actions and is unpersuasive for several reasons. First, plaintiff's cover letter appended to the produced documents did not explain such connection, or otherwise address the 12 requests included in the pending RPD. Second, the instant action is not proceeding on an Eighth Amendment claim involving a determination of deliberate indifference; rather, plaintiff is pursuing a due process claim where he must demonstrate the deprivation of a protected liberty interest. Sandin v. Conner, 515 U.S. 472, 483-84 (1995) ("States may under certain circumstances create liberty interests which are protected by the Due Process Clause."). Such interests are "generally limited to freedom from restraint which . . . nonetheless imposes atypical and significant hardship on the inmate in relation to the ordinary incidents of prison life." Id. at 484. Third, the documents plaintiff provided included administrative appeals, and incident and disciplinary reports dated from 2016 to 2018 in various state prisons, as well as a copy of plaintiff's habeas petition from state court. Such documents do not address plaintiff's due process claim raised in this court. Liberally construed, some of the documents could be arguably responsive to defendants' request for documents pertinent to plaintiff's claim for damages, but the administrative grievances, forms setting forth plaintiff's external movements, and the state court's ruling on plaintiff's habeas petition seeking sentencing relief under Proposition 57 are wholly unrelated to plaintiff's due process claim in this action or to damages. But even giving plaintiff credit for providing documents pertaining to damages, he failed to address the remaining 11 requests in the RPD propounded in January of 2019. Plaintiff provided no additional response addressing the remainder of the requests for production, identifying which responses the documents addressed, or conceding that he has no documents for certain requests, if such is the case. Thus, it is unclear whether plaintiff has other documents supporting his claims, identifying witnesses, or otherwise.
The record reflects varying accounts of the documents plaintiff has in his possession that he intended to disclose. For example, on May 5, 2019, plaintiff claimed he had nearly 300 pages to provide to defendants. (ECF No. 62 at 3, 6.) On June 17, 2019, plaintiff claimed he had about 600 pages of relevant documents to provide, of which he had provided 150 pages. (ECF No. 65 at 2.) Yet, on May 28, 2019, in his letter to defense counsel, plaintiff stated he had enclosed "all" documents responsive to defendants' discovery request. (ECF No. 66-1 at 52, 97.) Then, on July 4, 2019, plaintiff submitted previously-undisclosed documents in support of his motion for summary judgment. (ECF No. 70.)
Indeed, plaintiff's first motion for summary judgment demonstrates that he did have other documents. Appended to plaintiff's first motion for summary judgment are documents from 2015 that plaintiff did not provide to defendants through discovery, and were not included in the documents provided in plaintiff's response to the RPD submitted after the court's May 14, 2019 order. While some of the documents appended to his motion are clearly marked with exhibit numbers from plaintiff's deposition or bear defendants' Bates numbers, others include no such markings (ECF No. 70 at 16-35). Plaintiff offers no explanation for why such documents were not provided in his first round of photocopies, or not offered at his deposition, yet he chose to rely on such undisclosed documents in support of his dispositive motion. Plaintiff's filing of a dispositive motion supported by documents not provided to defendants through discovery supports the court's finding that plaintiff's actions were willful and intentional, and that he has acted in bad faith. Further, plaintiff's continued claims that he was deprived of law library access to make photocopies are belied by his multiple filings in his other action. See No. 18-cv-02942 KJM AC (ECF Nos. 12-14.) Plaintiff's filings in his other action further demonstrate that plaintiff prioritized his filings in his other action over his obligation to cooperate in good faith discovery in this action.
2. Do the five factors support terminating sanctions?
Because plaintiff's failure to respond to defendants' RPD was willful, the undersigned must evaluate whether the five factors weigh in favor of imposing terminating sanctions. Such factors provide a "way for a . . . judge to think about what to do," rather than "a series of conditions precedent before the judge can do anything." In re Phenylpropanolamine (PPA) Prod. Liab. Litig., 460 F.3d 1217, 1226 (9th Cir. 2006), quoting Valley Eng'rs, 158 F.3d at 1057. Generally, the key factors in this evaluation are the risk of prejudice and the availability of alternative sanctions. Wanderer v. Johnston, 910 F.2d 652, 656 (9th Cir. 1990).
Despite plaintiff's actions and omissions in this action, the undersigned does not find that terminating sanctions are warranted at this juncture. Having reviewed the record, including defendants' now pending motion for summary judgment, it does not appear that defendants would be prejudiced if this case is decided on the merits, and general policy favoring disposition of cases on their merits always weighs against terminating sanctions. Yourish, 191 F.3d at 992 (citation and internal quotation marks omitted). Defendants have already incurred the expenses of bringing the instant motion as well as their dispositive motion, and had benefit of the documents appended to plaintiff's motion for summary judgment over four months before filing defendants' motion for summary judgment. Moreover, as set forth below, the undersigned finds that lesser sanctions would be satisfactory.
3. Alternative Sanctions
Because plaintiff's motion for summary judgment, filed July 12, 2019, was supported by documents not disclosed through discovery, the undersigned denies plaintiff's motion as a sanction for his reliance on documents not disclosed to defendants in the discovery process.
In addition, based on plaintiff's willful actions and omissions set forth above, the undersigned finds it appropriate to order monetary sanctions against plaintiff. Fed. R. Civ. P. 37(d)(3). The court has reviewed the monetary sanctions sought by counsel for defendants and finds that 7.2 hours at the rate of $200.00 per hour for a total of $1440.00 in fees in preparing the instant motion is reasonable. (See ECF No. 71-2 at 2.) Based on the instant record, the undersigned finds that defendants' motion was substantially justified based on plaintiff's initial failure to respond, and his subsequent failure to adequately respond to the RPD (set one). Thus, plaintiff is required to pay $1,440.00 to counsel for defendants because the plaintiff's failure to respond was not substantially justified. Fed. R. Civ. P. 37(a)(5)(A). The court must also consider whether "other circumstances make an award of expenses unjust." Fed. R. Civ. P. 37(a)(5(A)(iii). Because plaintiff's actions and omissions were willful, the court finds an award of expenses to be just and required under Rule 37(d)(3). The undersigned has considered the Ninth Circuit's decision that it is an abuse of discretion to order a sanction which cannot be performed. Thomas v. Gerber Prod., 703 F.2d 353, 357 (9th Cir. 1983). In fact, plaintiff is incarcerated and proceeding in forma pauperis due to his indigency. In light of Thomas, the court stays the award of expenses. However, defendants may move to lift the stay and enforce the order of monetary sanctions and expenses upon a showing that plaintiff has the ability to pay $1440.00.
Plaintiff's now outdated trust account statement reflects no regular or sporadic deposits, and plaintiff owes restitution in excess of $10,000.00. (ECF No. 7 at 4-5.) --------
IV. Conclusion
Accordingly, IT IS HEREBY ORDERED that defendants' motion for terminating and monetary sanctions (ECF No. 71) is granted in part and denied in part as follows:
1. Defendants' motion for terminating sanctions is denied;
2. Plaintiff's motion for summary judgment (ECF No. 70) is denied without prejudice;
3. Defendants' motion for monetary sanctions is granted, and defendants' expenses in the amount of $1440.00 are assessed against plaintiff to be paid to defendants;
4. The order assessing monetary sanctions and expenses in the amount of $1440.00 is stayed; and
5. Defendants may move to lift the stay and enforce the order of monetary sanctions and expenses upon a showing that plaintiff has the ability to pay $1440.00. Dated: January 17, 2020
UNITED STATES MAGISTRATE JUDGE /smit1598.sanc


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Treasury of Scripture Knowledge
Fair weather cometh out of the north: with God is terrible majesty.
Bible References
Proverbs 25:23
The north wind brings forth rain,
And a
backbiting tongue, an angry countenance.
And a
Job 40:10
" Adorn yourself with eminence and dignity,
And clothe yourself with honor and majesty.
And clothe yourself with honor and majesty.
1 Chronicles 29:11
Yours, O Lord, is the greatness and the power and the glory and the victory and the majesty, indeed everything that is in the heavens and the earth; Yours is the dominion, O Lord, and You exalt Yourself as head over all.
Psalm 29:4
The voice of the Lord is powerful,
The voice of the Lord is majestic.
The voice of the Lord is majestic.
Psalm 66:5
Come and see the works of God,
Who is
awesome in His deeds toward the sons of men.
Who is
Psalm 68:7
O God, when You went forth before Your people,
When You
marched through the wilderness, Selah.
When You
Psalm 76:12
He will cut off the spirit of princes;
He is
feared by the kings of the earth.
He is
Psalm 93:1
The Lord reigns, He is clothed with majesty;
The Lord has
clothed and girded Himself with strength;
Indeed, the
world is firmly established, it will not be moved.
The Lord has
Indeed, the
Psalm 104:1
Bless the Lord, O my soul!
O Lord my God, You are very great;
You are
clothed with splendor and majesty,
O Lord my God, You are very great;
You are
Psalm 145:5
On the glorious splendor of Your majesty
on Your wonderful works, I will meditate.
Isaiah 2:10
Enter the rock and hide in the dust From the terror of the Lord and from the splendor of His majesty.
Micah 5:4
And He will arise and shepherd His flock
In the strength of the Lord,
In the majesty of the name of the Lord His God.
And they will
at that time He will be great
To the
ends of the earth.
In the strength of the Lord,
In the majesty of the name of the Lord His God.
And they will
To the
Nahum 1:3
The Lord is slow to anger and great in power,
And the Lord will by no means leave the guilty unpunished.
whirlwind and storm is His way,
clouds are the dust beneath His feet.
And the Lord will by no means leave the guilty unpunished.
Habakkuk 3:3
God comes from Teman,
And the Holy One from Mount
Paran. Selah.
splendor covers the heavens,
And the
earth is full of His praise.
And the Holy One from Mount
And the
Hebrews 1:3
And He is the radiance of His glory and the exact representation of His nature, and upholds all things by the word of His power. When He had made purification of sins, He sat down at the right hand of the Majesty on high,
Hebrews 12:29
our God is a consuming fire.
Jude 1:25
to the
only God our Savior, through Jesus Christ our Lord, be glory, majesty, dominion and authority, before all time and now and forever. Amen.


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EVENTFAQS Bureau
| September 1, 2020 | Promo Feature
Beyond Ambition Virtual Festival FB Celebrations
FB Celebrations will host a series of workshops for 'leisure and learning' under a 'Beyond Ambition Virtual Festival'. The month-long festival will have bi-weekly sessions starting 19th September 2020
EVENTFAQS Bureau
| September 1, 2020 | News
Laqshya Live Experiences Production Crew Entertainment Rambo Circus
The initiative is led by Laqshya Live Experiences and Production Crew Entertainment.
EVENTFAQS Bureau
| August 31, 2020 | Promo Feature
Zee Entertainment Enterprise It's A Girl Thing (IAGT)
Zee Entertainment Enterprises' live entertainment and IP vertical Zee Live has partnered with Branded to host the 'It's A Girl Thing' (IAGT) festival for the first time in India.
EVENTFAQS Bureau
| August 28, 2020 | News
Kalamkaar Sony Music
Sony Music India has signed a recording deal with rapper Raftaar and entered into a partnership with Kalamkaar – an independent label founded by Raftaar and his business partner AnkitKhanna.
EVENTFAQS Bureau
| August 27, 2020 | News
Sunburn Festival Percept Live
The event will be streamed live on 29th August 2020 and all proceeds from the public will be routed to the Chief Minister's Covid Relief Fund - Goa, it was revealed.
Mugdha Gaonkar
| August 26, 2020 | Feature
Charu Malhotra Hindware Dream11
This prompts the question – will Dream11 be able to leverage IPL 2020 right and to get bang for its buck(s)? EVENTFAQS Media asked some professionals for their take.
EVENTFAQS Bureau
| August 25, 2020 | Promo Feature
WOW Awards Asia 2020 Best Kept Secret WOW Awards Asia
Bengaluru-based four-member band 'Best Kept Secret' celebrated its second successive Wow Awards win by creating a song to mark the occasion and express its gratitude.
EVENTFAQS Bureau
| August 25, 2020 | News
Victor Tango LITKIDS Open Mic Season 1
LITKIDS Open Mic Season 1 concluded on 15th August 2020 with a live finale on the IP's YouTube channel. It garnered over 50,000 live views with over 10,000 new subscribers.
EVENTFAQS Bureau
| August 19, 2020 | News
Gully Gang Entertainment Reservoir
New York-headquartered Reservoir, a music publishing company, has announced that it has signed on rapper DIVINE in a worldwide publishing deal, one that it bills as a first-of-its-kind deal for India.
EVENTFAQS Bureau
| August 19, 2020 | Interview
Event Capital BookMyShow Deepak Choudhary
The event managed to attract 25,000 eyeballs across the three days, reveals Deepak Choudhary, Founder and Director, Event Capital, and curator of the fest.
EVENTFAQS Bureau
| August 17, 2020 | News
Percept Live Sunburn
The event will be streamed live on 29th August with DJ DVLM headlining the show along with a host of popular artists. All proceeds from the show will go to the Chief Minister's COVID Relief Fund -Goa.
Event Capital Festival of Festivals BookMyShow
Here below is an interaction with Deepak Choudhary, Founder and Director, Event Capital and Alaap Gosher, Truly Musical, from Bollywood Music Project.
EVENTFAQS Bureau
| August 14, 2020 | News
ArtMatters Ojas Arts Fables of the Earth
Ojas Art, a pioneer of contemporary art in India, and #ArtMatters, by the Teamwork Fine Arts Society, have announced the launch of a digital initiative, Fables of the Earth.
EVENTFAQS Bureau
| August 13, 2020 | News
BookMyShow Festival of Festivals Event Capital
Here below is an interaction with Pallav Ojha, CEO and Co-Founder, India Beach Fashion Week.
Taalbelia BookMyShow Event Capital
Here below is an interaction with Siddhartha Chaturvedi, Founder-CEO, Event Crafter, and Festival Producer, Taalbelia.


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If a course you're interested in doesn't have any dates coming up, contact us and we'll see what we can do for you.
Group bookings, private courses or pick your own dates?
If you have a group of 6 or more, you can pick your own dates for the course without paying anything extra! Or if you would like a private course for yourself and your partner or just for you, that's possible as well! For all group, school and private course bookings, please contact us to discuss details and pricing.
Private SSI Open Water Diver courseIf you would prefer to do a private course with your own instructor we can put together a customized training programme to suit your schedule.
Children under the age of 12 are advised to do a private course
The SSI Enriched Air Nitrox program will teach you how to safely plan and dive with enriched air mixtures of up to 40% oxygen. Diving with enriched air can increase your no-decompression limits, increase your safety, and reduce the required length of your surface intervals when compared to air.
You will earn the SSI Enriched Air Nitrox 32% certification after completing this program.
If you would like to upgrade to 40% you will need to do a 30 min classroom session, we ca
This is a dry course and 100% online
This course is now Full
This globally-recognized certification program is the best way to begin your life-long adventure as a certified scuba diver.Personalized training is combined with in-water practice sessions to ensure you have the skills and experience required to become truly comfortable underwater, certifying you to dive anywhere in the world down to 18mtr.The course is made up of 3 sections, online theory that can be done at home in your own time before the course, a confined water pool session were you can become comfortable and practice skills being underwater and 4 open water dives were the fun really begins! learning new skills and problem solving techniques as well as seeing the beautiful marine life New Zealand has to offer.
All online learning must be completed prior to in water training. Please contact us if the participant is 15 yrs or younger. The course is run over 3 days, Friday meet and greet, pool session 9am-4pm at Otahuhu Pools (Mason Ave) and Saturday, Sunday open water dives at Goat Island marine reserve 9am-4pm (site dependent on conditions)It's a great weekend away, most students find it easier to stay there we have accommodation options available.
You will learn everything about the background, history, benefits and equipment of sidemount diving. In practice, you will learn how to configure your equipment and manage it in the water, recognizing that bouyancy and movement brings you a new diving experience.
An SSI Recreational Sidemount course is made up of short academic sessions, with practice in the water to ensure comfort and safety with this new equipment configuration. With the proper training, you can enjoy recreational sidemount diving anytime.
A Scuba Skills Update provides you with the opportunity to review and practice necessary scuba skills that you learned in your original Open Water Diver program under the guidance of an SSI Dive Professional. The Scuba Skills Update is often a required for continuing your diving training after a long period of time away from the sport.
You will be issued an SSI Scuba Skills Update recognition card.
Included in this course is online training, a confined water pool session at Taupo AC Baths pools and 2 open water dives in Lake Taupo
Scuba equipment is provided, however please provide your own mask, fins and snorkel.
Blue ocean Clean up dive in Lake Taupo!
The Blue Oceans movement supports the conservation and sustainable use of aquatic environments, including oceans, seas, coasts, and waterways and their magnificent diversity of plant and animal species,
Scuba divers, free divers and shore crew all needed! Be prepared to get wet and dirty!
There will be a sausage sizzle and prize competition for most interesting find and a number of spot prizes, donated by our amazing sponsors so be sure to come along and help out.
DATE: Sunday 22nd November 2020.
LOCATION: Acacia Bay, LakeTIMES:12pm - Registrations open - ALL PARTICIPANTS, SHORE CREW AND DIVERS, MUST REGISTER ON ARRIVAL.1pm - Safety Briefing1.30pm - Divers in the water (45 min max dive time)2.30pm Sorting trash into recycling piles and sausage sizzle
3.30pm - Prize giving
4pm Clean-up and pack down.
This will be at Taupo Lake, shore based clean up targeting rubbish and things that don't belong
Scuba Divers who wish to participate must have a minimum of 10 logged and be comfortable working in low visibility, you will need to bring your dive certification (NO CERT NO DIVE)Dive shack Taupo can provide any hire equipment at $10 a tank or air fills
We will be giving out catch bags but If you also have your own or float boats for collecting rubbish, please bring this along and ensure they are named.
If you would like to join in the fun and participate as part of the shore crew, you will need to make sure you are wearing fully covered shoes and bring a pair of gardening gloves....... also be prepared to get down and dirty!
PLEASE NOTE:• This is a free family friendly event, but children must be supervised at all times by an adult.• Closed toe footwear must be worn for safety.• Please bring your own hand protection (gardening gloves or similar).• Don't forget your own water bottle and bring sunscreen if it's a warm day.• Dress for the weather (warm clothes and jackets) – we go ahead rain or shine.• There will also be plenty of work for non-divers to get involved.
If this event is cancelled due to weather, notification will be given on the Facebook page, the day before.
We look forward to seeing you there!
Many exciting dive sites are located in deeper water. Without proper training, this kind of diving puts you at risk. The SSI Deep Diving Specialty will give you the ability to safely and comfortably plan and conduct dives beyond 18 meters, and is a prerequisite for some advanced training.
You will earn the SSI Deep Diving Specialty certification after completing this program.
Package Includes:
Come with us to the Bay of Islands and dive the weekend away on the Canterbury Wreck and surrounding reef.
Includes 4 boat dives (2 per day) 2 air fills, 2 nights accommodation, 2 breakfasts, 2 lunch, 1 dinner and a bloody awesome weekend away
Cost: $390 Dorm style, $410 twin, $480 single room
These are priced with your own equipment
If you need to hire gear let us know in advance, $50 to hire full kit for the weekend.
With the SSI Deep Diving course, you will venture into the depths and take on the challenge of deep diving to be able to dive down to 40 meters.
A lot of exciting dives are at depth, and without proper training and knowledge, you can be quickly at risk. Being affected by the narcosis or exceeding your no decompression limit due to the depth are just a few of the potential hazards.
During this Deep Diving course, you will learn to dive with confidence at depth and enjoy to go where not so many divers can go.
With the SSI Deep Diving specialty certification, you will have the ability to safely plan and conduct dives beyond 18 meters. The SSI Deep Diving certification is also a prerequisite for some advanced specialty courses, as well as to start technical diving.
Learn to plan and manage your way down with this two days scuba diving course where you will have three training dives.
The cost includes Accommodation, meals and scuba equipment.
Join us and spend th day diving the stunning Alderman Islands!
Located 10.2 Nautical miles from Tairua, the Aldies have some of the most stunning sites over and under the water.
Departure Tairua Boot ramp 8am
Mon-Fri: 8:30am - 5:30pm
Sat: 9am - 1:00pm
Sun: Closed


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75 Apartments for rent in Mauldin, SC with hardwood floors
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This small city has history dating back to the American Revolution, and was originally named Butler's Pass. Mauldin didn't get its current name until then Lieutenant Governor William L. Mauldin arranged for the Greenville & Laurens Railroad to come through the town, bringing in traffic and allowing it to grow. Growth exploded at the time of World War II, when Donaldson Air Force Base was constructed and brought in more people.
Finding a home in Mauldin is relatively inexpensive. The average home price for properties in the city in 2001 was just under the national average. Renters pay much less than they would in the state's larger cities. Perhaps it's partly because of this that residents are deciding to stay put. Less than 6 percent of homes in the area are vacant, and population is booming at growth rate of 56 percent since 2000. In fact, from 2000 to 2010 Mauldin was the 15th fastest growing city for a reason. A good home for sale or apartment for rent may be hard to come by, but it will be worth the search. See more
Scoring an apartment with hardwood floors can be a big win for Mauldin renters. They're typically a beautiful addition to your space. They're also easier to clean and sweep, particularly if you have pets.
However, there are some downsides. Hardwood floors carry sounds. They can also make your apartment noisy for your roommates and downstairs neighbors.
Ask the landlord or property manager about the hardwood floors before signing a lease. Are they actually hardwood or a popular composite alternative? The latter is probably easier to clean and care for than the real thing.
It's also important to ask about who's responsible for any damage to the floors and what that entails. Your security deposit could take a hit from scratches, dents, and other damage.
Consider the type of climate you live in. Hardwood floors typically don't fare well in damp climates full of moisture. Stains and buckling are common in hardwood floors after rain flooding or excessive moisture.
However, hardwood floors can be ideal for dry climates or sunny areas for renters who love the way they look.