text:
Location: Wigan, United Kingdom
Member since: March 2012
Dec 12, 2013
" This man is simply a fantastic freelancer and an expert when it comes to creating video. His ability to take and understand direction is outstanding and this makes for an efficient and enjoyable experience. Thanks Andy. You delivered this project above our expectation. "
Dec 10, 2013
" It was great working with Andy. He was very patient and put in an extraordinary amount of work for the very reasonable rate. Would recommend and hire again! "
Oct 28, 2013
" Really enjoyed working with Andy. he was responsive, skilled and the finished product was exactly what I am looking for. I l;ook forward to working with Andy in the future and am happy to recommend him to others looking for well priced, well made videos. "
Oct 22, 2013
" Andy is superb at what he does. Our video was delivered to a very high standard and his instincts are amazing. His frequent communication made this experience very enjoyable and we found the process to be smooth and easy because of his expertise. Highly recommended. "
Oct 20, 2013
" Andy is great to work with - very responsive to feedback and gives you a lot of lee way in trying out a few different things so you can make sure you've got everything you want before you settle. Great work. "
Aug 27, 2013
" Andy is a pleasure to work with and I look forward to working with him again. This is my second project with him and he did an excellent job. "
Aug 2, 2013
" I very rarely give 5-star ratings across the board, but Andy deserves it. If you're looking for an animated video, he's your man. Hard working, High quality, fast work and unlimited revisions until I was satisfied. And I was quite picky! Hope to work with this man again. "
Jun 15, 2013
" I am impressed! Andy did an incredible job and was on top of it anytime something needed to be changed. He provided daily progress reports and I saw the project develop from start to finish which gave me a chance to change somethings around after I got to watch it. Great Job! "
DRL Limited
I currently work as an animator for a video studio. I create logos and video's for various projects, animations and infographics.
I'm currently undertaking freelance projects working on all aspects of corporate identity such as logo design, stationary design and brochure design.
Digital Media Design
Media Studies
BA Hons (Degree)
Lancaster University
Degree recieved for completed my university degree at Edge Hill University
Winstanley College
A-Level received for completing an A-Level course in Media Studies including both coursework and exams.
LG - 6 Motion Commercial
Appliance Online
This is a web commercial for LG. It was commissioned for Appliances Online and created using both Cinema 4D and After Effects:

http://www.youtube.com/watch?v=LnKTuUio4Jk
Media Studies (A-Level)
A-Level recieved from Winstanley College for completing a Media Stuides A-Level course.


text:
30004 Blade Replacement for Stanley Surform® 9 7/16 Holder
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Cuts 10 times faster with less effort than similar products.
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subset: commoncrawl


text:
TLP Consultancy Ltd, the experienced recruitment consultancy
At least that's what we believe at TLP Consultancy.
As a company we have over 20 years experience of recruiting in the IT and Financial Markets space, and collectively as individuals over 100 years experience.
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TLP Consultancy Ltd is a member of both APSCo and the REC
I haven't moved company for 6 years..."[Read More]
"Nic provded to quality service in his role as a Director of TLP. His attention to detail was particularly impressive as was his quality to provide top quality consultants fit for the job unlike many recruitment agencies who "bombard" clients with CVs. Nic provided the right people at the right time and provided an excellent "after sales" service. Highly recommended..." [Read More]
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[JURIST]New York Supreme Court Judge Jacquelyn Silbermann [official website] Wednesday rejected a petition brought by two members of New York City Council [official website] trying to prevent a council vote on a resolution to extend New York mayoral and city council term limits [materials] from eight to 12 years. Council members Bill de Blasio and Letitia James [official websites] filed the complaint to prevent the vote, arguing that voting on an option to extend their own terms presented members with a conflict of interest. Silberman ruled again them, noting that members opposed to extension could vote no or abstain. The council is scheduled to vote on the resolution [text] introduced by Mayor Michael Bloomberg [official website] Thursday. Reuters has more. Newsday has local coverage.Last month, Bloomberg announced his plan to seek a third term [NYT report], arguing his financial expertise and business background is necessary to lead New York through the rough financial times caused by the credit crisis. To seek re-election, Bloomberg introduced a council resolution to extend mayoral term limits from two to three 4 year terms. The current term limits were enacted in 1993 by city-wide referendum and upheld in 1996 again by referendum [NY Times report]. Critics argue Bloomberg's resolution overturns a decision by popular referendum with a council vote that requires only a simple majority to pass.
[JURIST] The US Court of Appeals for the Eleventh Circuit [official website] has ruled [opinion, PDF] that a physician who was accused of writing illegal prescriptions could pursue claims of false arrest, false imprisonment and malicious prosecution against the federal government. The court held Tuesday that a provision of the Federal Tort Claims Act (FTCA) [text] permitted such claims as an exception to the United States' sovereign immunity. The plaintiff, Dr. Andrew Nguyen, fled Vietnam in the late 1970s, bought a practice in rural Trenton, Florida, after earning US medical licenses, and became a US citizen in 1986. His practice was decimated after he was arrested on suspicion of unauthorized delivery of controlled substances [statute text] in 2000, even though the charges were dropped for lack of evidence two months later. In its opinion reversing a judgment of the US District Court for the Northern District of Florida [official website], the Eleventh Circuit panel wrote:
What happened to Dr. Nguyen's practice is what happens to the established professional practices of medical doctors who are caught committing crimes involving controlled substances. If the record before us is to be believed, however, Dr. Nguyen committed no crime. It is not just that the charges against him were dismissed on insufficient evidence grounds. It is more than that. The record, as it now exists, indicates that Dr. Nguyen's arrest was not based on any evidence of wrongdoing at all. All of the evidence that law enforcement officers had then, as well as now, showed that he was guilty of no crime. They arrested him anyway.
[JURIST] The death sentence of Afghan journalism student Sayad Parwaz Kambaksh [JURIST news archive] was reduced Tuesday to 20 years' imprisonment by an Afghan appeals court. Kambaksh was sentenced to death [JURIST report] in January for distributing papers questioning gender roles under Islam. In May, Kambaksh appealed his death sentence [JURIST report] before the appeals court. He denied the accusations in front of a three-judge panel Sunday, saying they were made by Balkh University professors and students with private hostilities against him. He told the court that his confessions were the result of torture by the Balkh province intelligence service. The Times has more.Kambaksh was sentenced to death following his trial, where he had no legal representation [JURIST report] and was allowed only three minutes to present his defense. The closed court invoked Article 130 of the Afghanistan Constitution [text] to pass down the death sentence, a penalty for blasphemy consistent with Hanafi [GlobalSecurity backgrounder] Islamic law. Afghanistan President Hamid Karzai was put under international pressure to pardon Kambaksh, but said that he would not intervene [JURIST report] during the pendency of Kambaksh's appeal.
[JURIST] US Homeland Security Secretary Michael Chertoff [official profile] Wednesday issued a final rule setting out the details of his department's air passenger screening program [TSA official site]. Under the Secure Flight Final Rule [PDF text], responsibility for vetting the nation's air passengers moves from individual airlines to the Transportation Security Administration (TSA)[offical site]. Airlines will collect the names, birthdays and genders of their passengers and transmit this information to the TSA, which will compare that against the government's "no fly" terrorist watch list and instruct airlines whether or not to issue a boarding pass. The collection of additional information is intended to reduce the number of misidentifications and increase the efficacy of the watch list, which has been criticized [JURIST report] by the Government Accountability Office [official site] for being inefficient. Screening for domestic flights is set to begin in early 2009, with matching on international flights slated for later in the year. The Washington Post has moreIn response to privacy concerns [EFF report; ACLU report], TSA Administrator Kip Hawley said Secure Flight will improve security by maintaining the confidentiality of the government's watch list information while fully protecting passengers' privacy and civil liberties. ... Ensuring privacy has been a cornerstone of this program and TSA has developed a comprehensive privacy plan to incorporate privacy laws and practices into all areas of Secure Flight.Privacy issues have plagued previous attempts at implementation of the program. In 2005, the TSA collected personal data [JURIST report] on commercial airline passengers to test the system, in violation of the Privacy Act of 1974 [text] and a congressional ban. The data collection and review methods and risk ranking scheme in Secure Flight's abortive predecessor, the Computer Assisted Passenger Prescreening System (CAPPS II)[DHS fact sheet; JURIST report] were criticized by Congress, the ACLU [advocacy website] and inside the TSA itself for being too intrusive.
Secure Flight will improve security by maintaining the confidentiality of the government's watch list information while fully protecting passengers' privacy and civil liberties. ... Ensuring privacy has been a cornerstone of this program and TSA has developed a comprehensive privacy plan to incorporate privacy laws and practices into all areas of Secure Flight.
[JURIST] US District Judge Benjamin Settle ruled [order, PDF] Tuesday that Iraq war objector 1st Lt. Ehren Watada [advocacy website; JURIST news archive] cannot face a second court-martial on all charges for which he already faced court-martial. Settle's order held that a second-court martial of Watada on three of the five charges in his first court-martial would constitute double jeopardy [LII backgrounder] in violation of the Fifth Amendment of the US Constitution. Settle had granted an injunction [JURIST report] against the second court-martial in November 2007 in order to resolve the double jeopardy dispute. The controversy over Watada's second court-martial concerns the declaration of a mistrial in the case by Lt. Col. John Head, the military judge overseeing the court martial, after he rejected a Stipulation of Fact by Watada and the government, conceding that Watada was guilty of the charge of Missing Movement when he missed a flight that would have flown him to his post in Iraq. Head rejected the Stipulation to Fact on the grounds that it was not a confessional stipulation because Watada believed that he had a justifiable reason for missing the flight, and that reason constituted a defense to the Missing Movement charge. In ruling that Watada cannot be face court-martialed for a second time on certain of the charges, Judge Settle wrote
The strictest scrutiny should be applied to the trial judge's determination [to order a mistrial] because the record reflects that the Government moved for a mistrial on the basis that it was unable to proceed with its case. In the alternative, the judge did not exercise sound discretion when he failed to engage in a procedurally adequate development of his determination that a mistrial was appropriate. Under either level of review, the record does not reflect that there was a manifest necessity to declare a mistrial over Petitioner's objection. As a result, the Government is barred from retrying Petitioner on Charge I [Missing Movement] and Charge II, Specifications 1 and 4 [Conduct Unbecoming an Officer and a Gentleman], because it would violate Petitioner's Fifth Amendment right to be free from double jeopardy.
[JURIST] The US Department of Defense announced Tuesday that the Office of Military Commissions Convening Authority has dismissed charges without prejudice [press release] against five Guantanamo Bay [JURIST news archive] detainees. Noor Uthman Mohammed, Binyam Mohammed, Sufyiam Barhoumi, Ghassan Abdullah al Sharbi, and Jabran Said Bin al Qahtani remain in custody, and Chief Prosecutor Army Col. Lawrence Morris has appointed teams to consider whether to recharge each prisoner. Lawyers for Binyam Mohammed called the move a "farce" [Reprieve press release], reporting that they had been informed of plans to "charge [Mohammed] again within a month, after the election. The detainees were each charged by former military prosecutor Army Lt. Col. Darrel Vandeveld, who resigned [JURIST report] last month citing "ethical qualms" with the military commissions' defense counsel discovery procedures. AP has more. The New York Times has additional coverage.All five men were formally charged in May. Noor Uthman Mohammed, a Sudanese national, was charged [JURIST report] with conspiracy and providing material support for al Qaeda in Afghanistan. UK resident Binyam Mohammed [Reprieve profile; JURIST news archive] was charged with conspiracy to commit terrorism and has been engaged in a battle with the British government after suing [JURIST report] for access to evidence related to his alleged extraordinary rendition [JURIST news archive] and torture. Algerian Barhoumi and al Sharbi and al Qahtani of Saudi Arabia were charged [JURIST report] with conspiracy and providing material support for terrorism based on their alleged involvement with an al Qaeda bomb-making group in Pakistan and Afghanistan.
[JURIST] US Defense Secretary Robert Gates [official profile] confirmed Tuesday that the military prison at Guantanamo Bay [JURIST news archive] would remain open for the duration of President George W. Bush's administration. The New York Times reported [text] earlier in the day quoted unnamed senior administration officials as saying Bush had decided not to close the prison before the end of his presidency. The Times reported Bush "never considered" recent proposals [AFP report] by the Pentagon and State Department [official websites] to transfer the detainees elsewhere. Instead, the president agreed with Vice President Dick Cheney [official profile] and other advisers that immediate closure would pose significant legal and political risks. Responding to a question about the Times report during a press conference [transcript] Tuesday, White House press secretary Dana Perino characterized Bush's decision as one "to work to try to close Guantanamo Bay." She said:
What the President has said is that he wants to be able to get into a position where we could close Guantanamo eventually. But it's very complex, it's complicated, it is difficult. There are four basic issues that we're dealing with right now. One of them is moving forward on military commissions. That process is slow, but it is moving forward. Another one is returning home or to a third country many of the detainees.... Third, we're in habeas litigation when it comes to the Boumediene decision and then the recent decision from Judge Urbina on the Uigher case.... And [Attorney] General Mukasey, backed by the President, supports legislation that Congress needs to pass.
[JURIST] The Ecuadorean Supreme Court of Justice and the Constitutional Tribunal of Ecuador [official website, in Spanish] on Tuesday published a statement [text, in Spanish] laying out the first steps in enacting a system of oral arguments, as required by the new Ecuadorean constitution [text, in Spanish]. The constitution, which took effect Monday upon publication in the country's official gazette following its approval last month in a national referendum [JURIST report], consolidates and significantly broadens the powers held by leftist President Rafael Correa [official website, in Spanish; BBC profile]. The new constitution gives the president the power to remove Congress in the middle of a four-year term, to control monetary policy and to seek re-election for an additional term. It also includes plans to tighten control over Ecuador's vital mining and oil industries. AFP has more. From Ecuador, El Universo has local coverage, in Spanish.Last month, President Correa called the vote a "historic victory," commenting [Reuters report; official statement, in Spanish], "Today, Ecuador has decided on a new nation, the old structures are defeated." The special assembly charged with rewriting the constitution provisionally approved the document in July [JURIST report]. The success of Correa's referendum fulfills his pledge to rewrite the country's constitution [JURIST report] after his leftist coalition's landslide victory [JURIST report] in October 2007. Correa's Alianza PAIS party [official website, in Spanish] has a majority in the Constituent Assembly. Critics continue to fear that the 444-article constitution gives the president too much control over the economy and the judiciary, which would allow Correa to follow the example set by Venezuelan President Hugo Chavez [BBC profile] in using the reform to further expand his powers.
[JURIST] The Appeals Chamber of the International Criminal Court (ICC) [official website] Tuesday ruled [press release] on two separate appeals filed by the Office of the Chief Prosecutor [official website], reversing for now the Trial Chamber's decision to release former Congolese militia leader Thomas Lubanga [BBC profiler; JURIST news archive] but dismissing a request [judgment, PDF] that it lift an indefinite stay on his trial. The Appeals Chamber remanded to the Trial Chamber [judgment, PDF] the ultimate question of whether Lubanga should be conditionally or unconditionally released, or whether he should remain in custody. The ICC Trial Chamber in June had imposed an indefinite stay [PDF text] on Lubanga's war crimes trial after accusing the prosecution of using confidentiality agreements to withhold possible exonerating evidence, and in July ordered his release [JURIST report]. According to the Appeals Chamber:
[T]he Trial Chamber was faced with a situation in which a large number of documents containing potentially exculpatory information or information relevant to the preparation of the defence was in the possession of the Prosecutor, but could not be disclosed to Mr. Lubanga Dyilo. Nor could the Trial Chamber have access to the documents in order to assess whether a fair trial could be held even without the disclosure of the documents . . . If the trial of Mr. Lubanga Dyilo had taken place in such circumstances, there would always have been a lurking doubt as to whether the disclosure of the documents in question would have changed the course of the trial.
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text:
Match % Unknown Join to find out!even, dare i say, the fairy tale romance.
Match % Unknown Join to find out!long to say this ... sideways, yeah maybeI don't know how long it'll take me but I'll do my bestYou'll be my soft and sweetI'll be your strong and steadyYou'll be my glass of wineI'll be your shot of whiskeyYou'll be my sunny dayI'll be your shade treeYou'll be my honeysuckleI'll be your honey beeYeah
Match % Unknown Join to find out!satanist but doesnt mean im a bad personso dont judge me and i wont judge youi can be easy to get along withor i can be your worst night marei love to talk and learn about the other person alsojust if you got anything you wanna say just itdont be afraid to be open im not the kinda person to tell se
- See More Profiles »
The Who Sung That Weird Lyric Test
Hi! And welcome to my Who Sung That Weird Lyric Test. I'll quote a lyrics from a song from the 60s and onwards, and you guess who it is. The more you ...
The What Music Best Suits You Test
Has your music bored you? I think that I could tell you exactly who you should be listening to. This test will tell you, based on emotions or preferan...
This test is hidden based on your maturity setting. Change your maturity setting
The My Favorite Lyrics Test
This test will take a lyric from a song in my music collection and challenge you to name the artist. Your success on this test only signifies that yo...
The Bovarchy Test
Are you fed up with the kakistocracies (n. pl. - rule by the inept) installed in countries throughout the world, from "Turkmenbashi" in Turkmenistan's...
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text:
Submit Review
Campground Search
204641 User submitted reviews online!!
Location :
Hesston, Pennsylvania
Seven Points Campground
[ 10/10 ]
Right on the water it was like being on golden pond with the sunsets. The Army Corps. of Engineers really know how to set up a campground.
Elverson, Pennsylvania
French Creek State Park
[ 10/10 ]
A great state park with lots to do. We camped over Fathers day and the park was crowded but no lines for showers (very clean and private) Rangers were around a lot which is fine they want everybody to have a good time but be respectful of the rules. We are already planning next year.
Cape May, New Jersey
Seashore Campsites
[ 10/10 ]
Very nice park located minutes from Cape May and Wilswood. They also give discounts for AAA and Good Sam members. They were very friendly. No hidden costs. Very clean restrooms, pool and lake. It's like camping in the woods with the benefit of the seashore. We will be coming back again this year.


text:
On Wed, Apr 28, 2010 at 7:38 AM, Westside_Ridah said:
Whaddup doe
On Mon, Jan 25, 2010 at 5:24 PM, $.Tha Notorious M.E.G.$ said:
Heyyy man its australia day ova here todayy :D so ima getting ready to head on out n hit up a lil get together with my mates should be gooood! so do you go to skool? u roll wit any krews over thurr?? haha u rap or krump or anythingg? peace brahh take care holla back :) x
On Fri, Jan 22, 2010 at 1:20 AM, $.Tha Notorious M.E.G.$ said:
yo yo wasssup thanx fo tha add man :) mm not much hey just kicken back relaxin its soooooo hot 2day ova here in oz maaan im jus chillen by tha fan hahah what u up to how madd is ice cube yah yeeeaaaahhh take care n holla PEACE megz x
On Tue, Jan 19, 2010 at 5:44 AM, Young Noble said:
Damn 1200 Views i Must be loved


text:
NOLE FAN1 said...
There was a time not long ago when FSU would block a punt or field goal almost every game. It is exciting and can help change a game in a flash! I wish we would try it every blue moon. Jimbo is too conservative in his O playcalling, his 4th qtr playcalling with the lead and special teams imo. Back in the Dynasty we had plenty of kids that could take a punt to the house with or without the help of setting up a return or trying to block it. Would like to see us come after it. Just because we got penalized in a game last year does not mean to never try it again.
This post was edited by GANoles93 on 10/14/2012 at 11:39 PM


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When I graduated from the wonderful University of Wisconsin, I was chosen to give the commencement address. I wrote a poem for the speech an…
Wrote my first post on Medium today, really enjoyed the UI.
My Monday morning was spent watching some of the weekend's commencement speeches… This was mine a few years ago at the grand ol' University of Wisconsin-Madison.


text:
Comments and Discussions
General News Suggestion Question Bug Answer Joke Rant Admin Use Ctrl+Left/Right to switch messages, Ctrl+Up/Down to switch threads, Ctrl+Shift+Left/Right to switch pages. |
About Article
Here's the scenario: your boss wants information on the go, but he hates to haul along his laptop. He's sick of the hassle of bringing it on airplanes and lugging it around. He wants a mobile application that provides him with the information he usually accesses on your extranet.
Related Articles
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text:
Shuttle's End Leaves NASA a Pension Bill
Not long afterward, the Energy Department arrived at a plan to stop paying for contractors' traditional pensions in the future — but to grandfather current workers at nuclear sites and retirees in existing plans. That initiative was dropped after drawing fire from workers, unions, contractors and benefit consultants.
This year, federal auditors found the Energy Department was still at the mercy of contractors' investment decisions.


text:
RKP Celebrates a Year
It's time for the battle of the giants.
Yesterday RKP celebrated its one-year anniversary. Your readership has made the last year possible. You've given us the chance to follow stories and explore perspectives that you won't find at the other sites or magazines, which, for us, has meant getting to write content we wouldn't have a chance to submit elsewhere.
In addition to the acceptance you've given the blog, the industry's reception has been terrific as well. From the products we've been asked to review to the advertisers who need to be in front of you, we've been welcomed everywhere we go.
A brief note on my whereabouts for the last two weeks: I just finished a book on road cycling for new riders called Ride Like a Pro! Yesterday, I turned in the finished manuscript to my publisher, Menasha Ridge Press. I've no idea how many pages it will be, but I do know that we turned in 402 images. I'd say my relief is on the order of giving birth, but my wife would slap me; let's just say this morning I took my first deep breath in months. Watch for it next spring.
And now, a year later, we're at the start of the Tour de France yet again. Summer is ON. Has a more exciting Tour ever loomed? I don't recall one. Traditionally, when the race has been called "wide open" the reason has been due to absences—missing former champions. However, this year is different.
The list of truly great riders capable of battling to victory is stunning for its depth. We have former champions Alberto Contador and Lance Armstrong, and all those who were counting Armstrong out in May are now curiously silent. Both Frank and Andy Schleck look capable of victory. And then there's Cadel Evans. Evans may not have the strongest team at the Tour, but there is no question that he is the leader of a team and that he has full confidence from management.
Can Wiggins replicate his form from last year? The world is full of riders who rode to fourth once, sometimes twice, but never higher. Let's watch and wait.
What of Sastre? No matter how likable and classy he is, he doesn't seem to have shown the form necessary to be called a favorite.
It's been almost 20 years since a rider took the Giro/Tour double and Miguel Indurain was in his prime. Can the same really be said of Basso?
We're told this will be Lance Armstrong's final Tour de France. We've every reason to take him at his word. Many will be relieved to see his departure. I, for one, won't be. While I'm no fanboy, I am a fan. Lance has been a fascinating, surprising figure in cycling and his insights into cycling, given in interviews have been fun to digest. The reign of Armstrong has been no cleaner than the reign of Indurain, but the interviews have been far more enjoyable.
The day following a fun birthday can be something of a let down. With the whole of the Tour de France ahead of us, it's going to be a party every day. Thanks for reading.
Image: John Pierce, Photosport International


text:
Added to Bag!
We'll let you know if it's back in stock!
Added to Wishlist!
Singing Lessons Top in Tan and Green
Final Sale: This item cannot be returned or exchanged.
- 100% Polyester.
- Loose fit throughout. Fabric does not provide stretch.
- Hand wash cold. Do not bleach. Line dry. Iron low.
- Unlined. Sheer. Ties at neck.
- Made in the United States
Size | S | M | L |
Length | 24.5 | 25 | 25.5 |
All measurements in inches.


text:
Please enter your travel dates.
Room, 1 Queen Bed
- FREE Breakfast
Breakfast is included in your stay.
Room, 1 King Bed
- FREE Breakfast
Breakfast is included in your stay.
Room, 1 King Bed, Non Smoking, Jetted Tub
- FREE Breakfast
Breakfast is included in your stay.
Room, 2 Queen Beds
- FREE Breakfast
Breakfast is included in your stay.
Central Hollywood, Los Angeles motel close to Universal Studios
In entertainment district
Located in Hollywood, Los Angeles, this two-story motel is 600 meters from Barnsdall Art Park and less than 2 miles from the Walk of Fame and Wax Museum. Universal Studios is 4.8 miles away.
Americas Best Value Inn - Hollywood/Los Angeles offers complimentary wireless Internet access and parking.
Free local calls
The 38 guestrooms include Pillowtop mattresses, televisions with premium cable channels, and free local calls. Each one has a refrigerator and coffee/tea maker.
Information missing or incorrect? Tell us!Hotel Amenities
- General
Located close to downtown Los Angeles, this Hollywood motel is close to Capitol Records, Griffith Observatory, and the Greek and Grauman's Chinese Theatres. Americas Best Value Inn - Hollywood/Los Angeles features an outdoor pool. This 2-star property offers complimentary coffee and newspapers in the lobby area. Complimentary wireless Internet access is available and business services include faxing and copying. The multilingual staff can assist guests arrange sightseeing tours and navigate Los Angeles city. Additional amenities offered include a 24-hour front desk, concierge services, free self-parking during stay, and airport shuttle on request (surcharge).
- Complimentary newspapers in lobby
- Free parking
- Airport transportation (surcharge)
- Business services
- Multilingual staff
- Total number of rooms - 38
- 24-hour front desk
- Coffee/tea in lobby
- Air-conditioned public areas
- Number of floors - 2
- Concierge services
- Microwave in lobby
- Free self parking
- Free guest parking during stay
- Tours/ticket assistance
- Free Wi-Fi
- Internet
Available in all rooms: Free Wi-Fi, Free wired high-speed Internet
Available in some public areas: Free Wi-Fi
- Parking
Free parking, Free guest parking during stay, Free self parking
- Room Amenities
- Free wired high-speed Internet
- Phone
- Premium TV channels
- Premium bedding
- Access via exterior corridors
- Blackout drapes/curtains
- Air conditioning
- Climate control
- Complimentary newspaper
- Free local calls
- Refrigerator
- Coffee/tea maker
- Wake-up calls
- Complimentary toiletries
- Hair dryer
- Shower/tub combination
- Cable TV service
- Window opens
- Pillowtop mattress
- Iron/ironing board (on request)
- Daily housekeeping
- Clock radio
- Desk
- Electronic/magnetic keys
- Rollaway/extra beds available
- Free Wi-Fi
- Recreation
The recreational activities listed below are available either on site or nearby; fees may apply.
- Golfing nearby
- Racquetball/squash nearby
- Accessibility
To make requests for specific accessibility needs, complete the "Special or Accessibility Requests" section of "Trip Preferences" when you book your hotel.
- Accessible bathroom
- Accessible path of travel
- Accessible parking
- In-room accessibility
Policies & Fees
- Check-in
Minimum check-in age is 18
Check-in time starts at 3 PM
- Check-out
Check-out time is 11 AM
- Payment types
Accepted at this hotel: American Express, Discover, JCB International, MasterCard, Visa
- Pets
Pets not allowed
- General
Extra-person charges may apply and vary depending on hotel policy.
Government-issued photo identification and a credit card or cash deposit are required at check-in for incidental charges.
Special requests are subject to availability upon check-in and may incur additional charges. Special requests cannot be guaranteed.


text:
No. 00-1301
Jane Roe, II,
Aware Woman Center For Choice, Inc., a Florida corporation, Edward W. Windle, Jr., Patricia B. Windle, and William P. Egherman, M.D.,
On Petition For A Writ Of Certiorari
To The United States Court Of Appeals
For The Eleventh Circuit
Counsel of Record
160 McLeod Street
P.O. Box 541739
Merritt Island, Florida 32954-1739
(321) 453-2221
Florida Bar No. 0961507
Counsel for Respondents Aware Woman Center for
Choice, Inc., Edward W. Windle, Jr. and Patricia B. Windle
The Respondents object to Petitioner's Questions Presented and offer the following as the correct issues to be considered on the Petition for Certiorari.
1. Whether this case is of such public importance as to justify deviation from normal appellate practice and to require immediate determination of the Supreme Court pursuant to Supreme Court Rule 11 and 28 U.S.C. § 2101(e).
2. Whether the District Court was correct in dismissing Petitioner's Complaint for failing to state a cause of action under the Freedom of Access to Clinic Entrances Act, 18 U.S.C. § 248.
3. Whether the District Court was correct in denying the Petitioner's motion to proceed anonymously.
There is no parent corporation of Respondent, Aware Woman Center for Choice, Inc. and no publicly held company owns shares in the corporation.
Questions Presented . . . . . . . . . . . . . i
Corporate Disclosure Statement . . . . . . . . . . . . . ii
Table of Authorities . . . . . . . . . . . . . iv
Statement of the Case . . . . . . . . . . . . . 1
Course of Proceedings and Disposition Below . . . . . . . . . . . . . 1
Statement of Facts . . . . . . . . . . . . . 3
This case is not of such imperative public importance to require a deviation from normal Appellate procedure . . . . . . . . . . . . . 4
The District Court was correct in dismissing Petitioner's Complaint for failing to state a cause of action under the Freedom of Access to Clinic Entrances Act, 18 U.S.C. § 248 . . . . . . . . . . . . . 5
The Elements of a FACE Claim . . . . . . . . . . . . . 6
Roe's Complaint . . . . . . . . . . . . . 9
The District Court was correct in denying the Petitioner's motion to proceed anonymously . . . . . . . . . . . . . 11
Conclusion . . . . . . . . . . . . . 15
Adams v. Family Planning Assoc. Med. Group, Inc., 733 N.E.2d 766 (Ill. App. 2000) . . . . . . . . . . . . . 14
Cheffer v. Reno, 55 F. 3d 1517 (11th Cir. 1995) . . . . . . . . . . . . . 6
Dames & Moore v. Regan, 453 U.S. 654, 101 S.Ct. 2972, 41 L.Ed.2d 1039 (1981) . . . . . . . . . . . . . 4
Doe v. Frank, 951 F.2d 320 (11th Cir. 1992) . . . . 11, 12, 13
Doe v. General Hospital, 434 F.2d 427 (D.C. Cir. 1970) . . . . . . . . . . . . . 14
Doe v. Mundy, 514 F. 2d 1179 (7th Cir. 1975) . . . . . . . . . . . . . 14
Doe v. StegalI, 653 F.2d 180 (Sth Cir. 1981) . . . . . . . . . . . . . 12, 13
Greene v. Legacy Emanuel Hospital and Healthcare Center, 997 P.2d 265 (Or. App. 2000 . . . . . . . . . . . . . 15
Greenhut v. Hand, 996 ESupp. 372 (D.N.J. 1998) . . . . . . . . . . . . . 7
Planned Parenthood v. Casey, 505 U.S. 833, 112 S.Ct. 2791, 120 L.Ed.2d 674 (1992) . . . . . . . . . . . . . 14
Roe v. Wade, 410 UiS. 113, 93 S.Ct. 705, 35 L.Ed.2d 147 (1973) . . . . . . . . . . . . . 14
Sharpe v. Conole, 123 F. Supp.2d 87 (N.D.N.Y. 2000) . . 9, 10
Southern Methodist Univ. Ass'n v. Wynne & Jaffe, 599 F.2d 707 (5th Cir. 1979) . . . . . . . . . . . . . 12, 14
Thornburgh v. American College, 476 U.S. 747, 106 S.Ct. 2169, 90 L.Ed.2d 779 (1986) . . . . . . . . . . . . . 14
United States v. Dinwiddie, 76 F.3d 913 (8th Cir. 1996), cert. denied, 519 U.S. 1043 (1996) . . . . . . . . . . . . . 7, 8
United States v. Nixon, 418 U.S. 683, 94 S.Ct. 3090, 41 L.Ed.2d 918 (1974) . . . . . . . . . . . . . 4
TABLE OF CONTENTS - Continued
United States v. Scott, 958 F. Supp. 761 (D. Conn. 1997) . . . . . . . . . . . . . 7
United States v. Wilson, 2 F. Supp.2d 1170 (E.D. Wisc. 1999), afl'd, United States v. Balini, 201 F.3d 928 (7th Cir. 2000) . . . . . . . . . . . . . 7
18 U.S.C. § 248 . . . . . . . . . . . . . Passim
28 U.S.C. § 2101(e) . . . . . . . . . . . . . 4
Fla. Stat. Ann. § 95.11 . . . . . . . . . . . . . 10
Fed. R. Civ. P. 10(a) . . . . . . . . . . . . . 11
S.Rep. No. 117, 103 Cong. 1st SeSs. 3 (1993) . . . . . . . . . . . . . 6
Sup. Ct. R. 11 . . . . . . . . . . . . . 4, 5
Respondents Aware Woman Center for Choice, Inc., Edward W. Windle, Ir., and Patricia B. Windie respectfully request that the Petition for Writ of Certiorari be denied.
The Respondents object to Petitioner's Statement of the Case because it is factually incorrect, it contains irrelevant material, and it does not set out facts necessary to consideration of the questions presented. The Respondents, therefore, offer their own Statement of the Case. This case is brought pursuant to the Freedom of Access to Clinic Entrances Act, 18 U.S.C. § 248 ("FACE"). Jane Roe II ("Roe") claims that Aware Woman Center for Choice, Inc., Edward Windie, Patricia Windle, (collectively "Aware Woman") and William Egherman, M.D., violated FACE when they took measures to protect her health during an abortion procedure where complications developed.Course of Proceedings and Disposition Below
On July 9, 1999, Roe filed her complaint in the United States District Court for the Middle District of Florida, Orlando Division. The complaint alleged that Aware Woman and Dr. Egherman violated FACE on March 29, 1997 when they restrained her during an abortion procedure where complications had developed. Roe sought
compensatory and punitive damages in excess of one million dollars.
Dr. Egherman and Aware Woman filed motions to dismiss the complaint on August 3, 1999 and August 16, 1999, respective!y. These motions were based on the fact that the allegations of the complaint did not state a claim under FACE.
Aware Woman also filed a motion to strike redundant, immaterial, impertinent and scandalous matters from Roe's complaint. This motion was based on Roe's repeated use of inflammatory statements related to the abortion procedure and clinic personnel.
Roe initially filed the complaint using a pseudonym. Thereafter, on November 11, 1999, at the direction of the district judge, Roe filed a motion to proceed anonymously.
On January 3, 2000, the district court dismissed the complaint, with leave to file an amended complaint, because Roe failed to allege any intent or motive on the part of the defendants to interfere with or prevent her from obtaining reproductive health services. The court also denied Roe's motion to proceed anonymously, finding that Roe's privacy concerns did not overcome the "presumption of openness in judicial proceedings." Finally, the court denied, as moot, Aware Woman's motion to strike, but cautioned Roe to comply with the Federal Rules of Civil Procedure requiring a short and plain statement of the claim in the event an amended complaint was filed.
Roe did not file an amended complaint. She filed her notice of appeal with the United States Court of Appeals for the Eleventh Circuit on January 12, 2000. The parties filed briefs and the Eleventh Circuit heard oral argument on November 3, 2000. To date, the Eleventh Circuit has not reached a decision on the appeal.
Statement of Facts
On March 29, 1997, Roe voluntarily came to the Aware Woman clinic to have an abortion. This was Roe's third abortion at the Aware Woman clinic. When Roe arrived she went through the normal checkin process prior to the procedure. During the procedure, complications arose. Roe requested that an ambulance take her to a local hospital emergency room. Dr. Egherman and the other clinic personnel continued to provide medical care to Roe in response to the complications that arose. In addition, an ambulance was called to take Roe to a local hospital emergency room. Roe was taken to the emergency room where she received further treatment.
Roe alleged in her complaint that Dr. Egherman and Aware Woman's actions violated FACE because they prevented her from immediately leaving the clinic during the abortion procedure after the complications had developed.
On January 12, 2000, Roe filed an appeal of the District Court's decision with the United States Court of Appeals for the Eleventh Circuit. Oral argument was heard before the Eleventh Circuit on November 3, 2000 and the parties await a decision. The Petitioner, however, requests tlxat the Supreme Court review the District Court's decision before the Eleventh Circuit rules.
Supreme Court Rule 11, pursuant to 28 U.S.C. § 2101(e), provides that:
A petition for a writ of certiorari to review a case pending in a United States court of appeals, before judgment is entered in that court, will be granted only upon a showing that the case is of such imperative importance as to justify deviation from normal appellate procedure and to require immediate determination in this Court.
This basis for jurisdiction before the Court is rarely granted and when it is it involves matters of national public importance. See Dames & Moore v. Regan, 453 U.S. 654, 101 S.Ct. 2972, 41 L.Ed.2d 1039 (1981) (involving challenges to the resolution of the Iran hostage crisis); United States v. Nixon, 418 U.S. 683, 94 S.Ct. 3090, 41 L.Ed.2d 918 (1974) (involving the investigation of illegal executive and Presidential matters with certiorari granted before judgment by the Court of Appeals because of the public importance of the issues presented and the need for their prompt resolution).
Roe offers no legal precedent, coherent argument, or reasonable interpretation as to why her petition for a writ
of certiorari should be granted before the Eleventh Circuit rules. In fact, she confuses the issues considerably by intermingling allegations with the standard necessary to review a matter before the court of appeals issues a decision.
The threshold question, before considering the District Court's decision on certiorari, is whether Roe's claim is of "imperative public importance." Roe's complaint simply alleges violations of a federal statute and resulting money damages for those violations. Her arguments on "public importance" relate to her disdain for court rulings and abortion in general but never discuss how review of the court's decision in her case is of "imperative public importance."
Roe fails to address any of the requirements mandated by Supreme Court Rule 11, and, therefore, her petition for writ of certiorari should be denied.
This action was brought pursuant to the Freedom of Access to Clinic Entrances Act of 1994 ("FACE"). 18 U.S.C. § 248. FACE provides in relevant part as follows:
(a) Prohibited activities. - Whoever -
(1) by force or threat of force or by physical obstruction, intentionally injures, intimidates
or interferes with or attempts to injure, intimidate or interfere with any person because that person is or has been, or in order to intimidate such person or any other person or any class of persons from, obtaining or providing reproduc. tive health services;
· · ·
shall be subject to the penalties provided in subsection (b) and the civil remedies provided in subsection (c) ....
In Cheffer v. Reno, 55 F. 3d 1517 (llth Cir. 1995), the court recognized that Congress passed FACE "in response to increasing incidents of violence and obstruction at abortion clinics." Cheffer, 55 F.3d at 1519. The acts of violence noted by Congress "included at least 36 bombings, 81 arsons, 131 death threats, 84 assaults, two kidnappings, 327 clinic 'invasions,' and one murder." S.Rep. No. 117, 103 Cong. 1st Sess. 3 (1993). The stated purpose of the act is "to protect and promote the public safety and health and activities affecting interstate commerce by establishing Federal criminal penalties and civil remedies for certain violent, threatening, obstructive and destructive conduct that is intended to injure, intimidate or interfere with persons seeking to obtain or provide reproductive health services." Cheffer, 55 F.3d at 1519.
The Elements of a FACE Claim
In interpreting FACE, courts have discerned three elements necessary to establish a violation of the statute. The first element requires that the defendant physically obstruct, or attempt to obstruct, someone's access to a
reproductive health facility.[1] United States v. Wilson, 2 E Supp. 2d 1170, 1171 (E.D. Wisc. 1999), aff'd, United States v. Balint, 201 F.3d 928 (7th Cir. 2000). Roe alleges in her complaint that the defendants prevented her from leaving the clinic by restraining her during the abortion procedure. The' district court found that viewing this allegation in favor' of the plaintiff, it alleged facts sufficient to show that her egress from the clinic had been obstructed. However, the court correctly determined that this element alone cannot support a violation of FACE.
The second element requires that the defendant intend by his obstruction to "interfere with or attempt to interfere with persons attempting to gain entrance or egress to said clinic." Wilson, 2 F. Supp. 2d at 1171. The third element requires that the defendant possess a particular motive. The intent to interfere with entrance or egress to a clinic must be with the "express purpose of preventing such persons from obtaining or providing reproductive health services." Id. Courts have noted that this motive requirement makes FACE unique in that most criminal statutes require only an act and an intent to so act. See United States v. Dinwiddie, 76 F. 3d 913 (8th Cir. 1996), cert. denied, 519 U.S. 1043 (1996); Wilson, 2 F. Supp. 2d 1170; United States v. Scott, 958 F. Supp. 761 (D. Conn. t997).[2]
[1] A "reproductive health facility" includes a hospital, clinic, physician's office, or other facility that provides reproductive health services. 18 U.S.C. § 248 (e)(1).
[2] The elements of a cause of action under FACE are the same whether criminal or civil remedies are being pursued. Greenhut v. Hand, 996 F. Supp. 372, 378 n.4 (D.N.J. 1998).
The motive requirement of FACE was explained by the court in Dinwiddie as follows:
What FACE's motive requirement accomplishes is the perfectly constitutional task of filtering out conduct that Congress believes need not be covered by a federal statute. Congress enacted FACE to prohibit conduct that interferes with the ability of women to obtain abortions. See H.R.Rep. No. 306, at 12; S.Rep. No. 117, at 23. FACE's motive requirement targets this conduct while ensuring that FACE does not federalize a slew of random crimes that might occur in the vicinity of an abortion clinic.
Dinwiddie, 76 F. 3d at 923. The court likened FACE's motive requirement to the motive requirement of Title VII of the Civil Rights Act of 1964 which requires an employer's discriminatory act be "because of [the employee's], race, color, religion, sex or national origin." Id. Discrimination without the requisite motive does not violate Title VII. Likewise, obstruction without the requisite motive does not violate FACE.
Recently, the United States District Court for the Northern District of New York explained that the intent requirement of FACE is necessary to prevent the application of FACE to circumstances where it clearly is not meant to apply. As an example, the court stated:
Plaintiff's interpretation of FACE's mens rea standard (such that one only need show obstruction to prove intent) could lead to ridiculous results. . . Similarly, if a bomb threat required immediate evacuation of a reproductive clinic, individuals escorting patients and medical service providers out of the facility
and/or preventing individuals from entering the facility could be liable under FACE. Contrary to Plaintiff's assertions, in these circumstances, the fact that an individual physically obstructed or literally interfered with provision of reproductive services would not suffice to establish a violation of FACE as the obstruction or interference was because of a threat to patients and providers safety rather than because the patients were receiving and the providers providing reproductive services.
Sharpe v. Conole, 123 F. Supp. 2d 87, 90 (N.D.N.Y. 2000).
Roe's Complaint
In this case, Dr. Egherman's and Aware Woman's acts were not intended to interfere with Roe's egress from the clinic in order to prevent her from obtaining an abortion. On the contrary, to the extent that Roe was restrained it was not intended to interfere with her leaving the clinic but rather to prevent further harm to her during the procedure. The defendants' purpose was not to prevent her from obtaining an abortion but to enable the doctor to complete the voluntary abortion procedure that had already begun and address the medical complications that had developed. This intent and motive is demonstrated in Roe's complaint by the allegation that after the complications arose clinic personnel and the doctor were attempting to insert an IV and otherwise provide medical treatment. The only reasonable inference from the facts alleged in the complaint is that Dr. Egherman and the clinic personnel were faced with a medical emergency and were taking those steps necessary to protect the
safety of the patient. Roe's conclusion that the defen- dants' acts were intended to prevent her from leaving the clinic and obtaining an abortion elsewhere simply is not reasonable given the facts. The acts were clearly intended to protect the health and safety of Roe during an abortion procedure, not prevent her from obtaining an abortion. As the court in Sharpe explained, such actions are not meant to come within FACE's prohibitions.
FACE is intended to protect abortion providers and patients against violence and threats of violence from persons who want to prevent abortions. Roe's complaint is an attempt to use FACE as a sword against people providing reproductive health services, the very people it was intended to protect. Roe was in the process of obtain- ing an abortion. Aware Woman and Dr. Egherman were in the process of providing the abortion. No one involved in the process had any motive to prevent Roe from obtaining the abortion. Thus, FACE clearly does not apply and cannot be invoked in this manner.
At most, Roe is alleging that the medical care she received at the clinic resulted in her injuries. In other words, she claims medical malpractice.[3] FACE clearly was not intended to federalize the medical malpractice field. Medical malpractice is one of the "slew of random
[3] Aware Woman adamantly maintains that the care Roe received at the clinic met the standard of care required of doctors, clinics, and other personnel performing abortion procedures and that any malpractice claim by Roe is completely without merit. Furthermore, any malpractice claim would be barred by the applicable statute of limitations set forth in Fla. Stat. Ann. § 95.11, which may explain Roe's use of a clearly inapplicable federal law to seek damages.
[acts]" that might occur at an abortion clinic that were not intended to fall within the prohibitions of FACE. Thus, the district court was correct when it dismissed Roe's complaint and certiorari should be denied.
Roe filed a motion to proceed anonymously in this matter, alleging that information of the "utmost intimacy" would be disclosed during the proceeding. Presumably, the information of the "utmost intimacy" which would be disclosed is the fact that Roe was allegedly injured during an abortion procedure.
Any review of a motion to proceed anonymously must begin with the general rule that parties to a lawsuit must identify themselves in their respective pleadings. Doe v. Frank, 951 F.2d 320, 322 (llth Cir. 1992). See Fed. R. Civ. P. 10(a) (requiring a complaint to include the names of all parties). The court recognized in Doe v. Frank that the "rule serves more than administrative convenience. It protects the public's legitimate interest in knowing all of the facts involved, including the identities of the parties." Frank, 951 F. 2d at 322. Thus, it is only appropriate in exceptional cases to allow a plaintiff to proceed anonymously. Id. at 323.
The ultimate test in determining whether the plaintiff may proceed anonymously is whether the plaintiff has a substantial privacy right that outweighs the presumption of openness' in judicial proceedings. Id. Review of the
cases authorizing the use of fictitious parties reveals certain common circumstances. See Doe v. Stegall, 653 F.2d 180 (5th Cir. 1981); Southern Methodist Univ. Ass'n v. Wynne & Jaffe, 599 F.2d 707 (5th Cir. 1979). These circumstances are: (1) plaintiffs challenging governmental activity; (2) plaintiffs required to disclose information of the utmost intimacy; and (3) plaintiffs compelled to admit their intention to engage in illegal conduct, thereby risking criminal prosecution. Frank, 951 F. 2d at 323, citing Stegall, 653 F. 2d at 185. These factors are not intended as a rigid, three-step test, but are highlighted as factors deserving attention. Frank, 951 E2d at 323.
In Wynne & Jaffe, the plaintiffs included certain individual attorneys who wished to proceed anonymously in the sex discrimination lawsuit filed against a local law firm. The attorneys alleged that they would suffer socially and economically if it was generally known that they were parties to the lawsuit. Wynne & Jaffe, 599 E2d at 711. In denying the motion to proceed anonymously, the court noted that prior cases authorizing anonymity involved parties challenging the constitutional, statutory or regulatory validity of governmental action. In contrast, this case involved a civil action against another private party where "the mere filing of [such an action] against other private parties may cause damage to their good names and reputation and may also result in economic harm. Defendant law firms stand publicly accused of serious violations of federal law. Basic fairness dictates that those among the defendants' accusers who wish to participate in this suit as individual party plaintiffs must do so under their real names." Id.
In Stegall, the issue raised was the constitutionality of prayer and Bible reading exercises in schools. The court held that the challenge to the governmental activity relating to religion, as well as evidence of harassment and violent reprisals, satisfied the conditions necessary to proceed anonymously. Stegall, 653 F.2d at 186. The court also noted as significant that the plaintiffs in this case were children. Id.
In Frank, the plaintiff sued his employer for employment discrimination, claiming he was wrongfully fired because of his alcoholism. It was the fact that he was an alcoholic that the plaintiff advanced as the substantial privacy interest worthy of protection. However, the court held that the fact that one may suffer some personal embarrassment, standing alone, does not justify proceeding under a pseudonym. Frank, 951 F. 2d at 324. In so ruling, the court held that:
Lawsuits are public events. A plaintiff should be permitted to proceed anonymously only in those exceptional cases involving matters of a highly sensitive and personal nature, real danger of physical harm, or where the injury litigated against would be incurred as a result of the disclosure of the plaintiff's identity. The risk that a plaintiff may suffer some embarrassment is not enough. This case does not present such an unusual situation in which the need for party anonymity outweighs the presumption of openness. Therefore, the district court did not abuse its discretion in denying Doe's motion.
Frank, 951 F.2d at 324.
In this case, Roe alleges that because the suit involves alleged injuries received during an abortion procedure, anonymity should be allowed. There is certainly no rule that all cases involving abortion may proceed anonymously. Roe relies on the case of Thornburgh v. American College, 476 U.S. 747, 106 S.Ct. 2169, 90 L. Ed. 2d 779 (1986) to support her position that abortion cases must proceed anonymously. First, this case has been overruled by Planned Parenthood v. Casey, 505 U.S. 833, 112 S.Ct. 2791, 120 L. Ed. 2d 674 (1992). Second, the issue in Thornburgh was not whether a party could proceed anonymously in a lawsuit filed in the federal courts but rather the validity of state reporting requirements related to abortions. The fact that the Court has recognized that abortion may be a private matter, as may be any medical procedure, does not require that parties to a lawsuit involving abortion be allowed to proceed anonymously.
Those cases involving abortion that have proceeded anonymously, e.g., Roe v. Wade, 410 U.S. 113, 93 S.Ct. 705, 35 L. Ed. 2d 147 (1973); Doe v. Mundy, 514 E2d 1179 (7th Cir. 1975); Doe v. General Hospital, 434 F.2d 427 (D.C. Cir. 1970), involved a challenge to governmental activity that required the plaintiff to admit to engaging in illegal activities, in addition to revealing the fact that the plaintiff requested or had an abortion. Wynne & Jaffe, 599 F.2d at 713.
Quite unlike the above cases, Roe is seeking money damages against private individuals alleging injuries received during a legal medical procedure. Claims of alleged medical malpractice involving abortions do not routinely proceed anonymously. See e.g., Adams v. Family Planning Assoc. Med. Group, Inc., 733 N.E.2d 766 (Ill. App.
2000) (involving wrongful death claim arising out of an abortion procedure); Greene v. Legacy Emanuel Hospital and Health Care Center, 997 P.2d 265 (Or. App. 2000) (involving medical malpractice claim where plaintiff's colon was perforated during an abortion). While it may be embarrassing to admit to an abortion, such embarrassment is not enough to outweigh the presumption of openness in judicial proceedings. This is especially true where the allegations of the lawsuit impugn the professional reputations of private individuals engaged in lawful activity and whose identities are fully exposed by the plaintiff's lawsuit.
The district court acted well within its discretion in denying Roe's motion to proceed anonymously. Certiorari should be denied on this issue also.
Roe's appeal is not of imperative public importance and, therefore, certiorari should not be granted in deviation from normal appellate practice. Additionally, the District Court was correct in dismissing Roe's complaint because she failed to state a claim under the FACE Act and holding that Roe could not proceed anonymously.
Based on the foregoing, Aware Woman Center for Choice, Inc., Edward W. Windle, Jr. and Patricia B. Windle respectfully request that the Court deny Roe's petition for a writ of certiorari.
Respectfully submitted,
Counsel of Record
160 McLeod Street
P.O. Box 541739
Merritt Island, Florida 32954-1739
(321) 453-2221
Florida Bar No. 0961507
Counsel for Respondents Aware
Woman Center for Choice, Inc.,
Edward W. Windle, Jr. and
Patricia B. Windle


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A collection of news and information related to John Shimkus published by this site and its partners.
Top John Shimkus Articles
Displaying items 23-27
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Blog | Sep 30, 2008 | 4:24 AMBy Laura Olson Four Illinois House Democrats voted against the economic bailout proposal,citing a lack of protections for homeowners and of stricter regulations to prevent a similar incident in the future. Five Illinois Republicans also voted against it....


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Friday Mar 14 | Tallahassee Democrat
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Grey cashmere cardigan from Sahaja featuring a shawl collar, front button fastenings, pattern detail, two patch pockets, long sleeves with ribbed cuffs and a ribbed hem. Item ID:10115807
Composition: Cashmere 100% WASHING INSTRUCTIONS : Dry Clean OnlyBrand Style ID : 10808GOASHAWLCHARCOAL
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Aggressive liquid samples which are acidic by nature can be analyzed by IR liquid transmission cells. To comply with Pharmacopeia regulations, chemicals and samples are required to have infrared spectral data collected for them between the frequency range of 4000cm-1 to 400cm-1 and this stipulation may limit the type of liquid transmission cell that can be used as the optical materials. In this application note it is shown that the Specac Quest™ ATR accessory can be used overcome this limitation. The Quest diamond ATR accessory is capable of handling and measuring samples such as Acetic Acid 100%, Nitric Acid 60% and Orthophosphoric Acid 85% for their IR ATR spectra.
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Avery Yukon Hood Fleece
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Avery's wind/waterproof breathable fleece Yukon Hood is a must for sportsmen who spend long hours in the frigid outdoors! Constructed from laminated 13-ounce fleece with soft tricot liner, this hood offers head and neck protection from chilling winds while offering double fleece protection on the lower half of your face. Elastic take-up strings for tight fit around your face.
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Deutsch, Ελληνικά, Español, Esperanto, Français, Indonesian, Italiano, Kiswahili, Kreyòl ayisyen, Magyar, Melayu, Português, Русский, Tagalog, Tiếng Việt, Türkçe, தமிழ், Հայերեն, 中文, اردو, 한국어, 日本語, العربية, فارسی, עִברִית, हिन्दी, ไทย, বাংলা, తెలుగు, ગુજરાતી, ລາວ
The NOMAD Foundation has worked for 14 years in Niger helping the nomads support themselves using expertise that has sustained them for centuries. We are now introducing new technologies such as solar power and water well drilling to bring them employment to help them improve their lives. [text borrowed from http://nomadfoundation.org]
They began teaching solar cooking, and offering their first solar cooker fabrication workshop, in 2011.
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Items of the Week From The A.T. Stewart Exchange: Pair of Urns
This week's items are etched crystal with brass-ormolu mounts, measure 19" high and are offered at $180 for the pair.
The compote bowl placed between the urns is English, and the pattern incorporates soft pink, blue and beige with a luster finish. This piece is priced at only $16, and all items are available at the time of posting.
The A.T. Stewart Exchange (consignment shop), located on the lower level of The Garden City Historical Society, offers unique items for sale and is run by volunteers. Founded in 1975, The Garden City Historical Society is a 501 (c) (3) non-profit organization. All profits go to the restoration of the Museum. The shop is located at 109 Eleventh Street in Garden City, just west of Franklin Avenue (516.746.8900). It is open from 10 a.m. to 4 p.m. Tuesdays through Fridays and from 12 noon to 4 p.m. on Saturdays. Parking is available behind the Museum. Please visit the Society's website at http://www.gardencityhistoricalsociety.org/.
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Titanium Estate.
Posted 14 April 2013 - 10:25 AM
Got a couple of mods under my belt already.
Smooth Rear Wiper (From my old Focus)
DeTango'd rear lights.
DeTango'd mirror indicators
LED PuddleLights
Orange and Black Steering Wheel badge and 2 Spokes of steering wheel carbon wrapped!
The Factory LED rears are a subtle change to the standard option lights!
Fitted an LED Reverse bulb.
Also fitted Number Plate LEDs from my old Focus.
Decided to upgade the sidelights.
LED Vs Normal bulb
LED matches Xenon better
Both LED Sidelights in!
Decided to Carbon Wrap Stereo Surround and centre console to match the spokes on the steering wheel.
I got some alloys cheap with decent tyres on!
New Vs Old
The car then had a wash and positioned in the sun to show its colour and new shoes off!
Think the colours go quite well together.
I decided to take the plunge and try to wrap the rear diffuser! After fighting with it for a little while I'm reasonably happy with it.
So after wrapping the diffuser decided to have a go at the Chrome Boot Handle.
And a pic of the 2 together.
Decided to cheat and buy an already wrapped bonnet lip. Unfortunately it's a copy part that has been wrapped so fit isn't perfect but pretty happy with it!
So it's gone from Chrome lip,
To no lip,
To Carbon Wrapped lip!
While i was playing Thought I'd have a go at doing the fog light rings.
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Posted 14 April 2013 - 10:29 AM
Posted 14 April 2013 - 10:29 AM
Posted 14 April 2013 - 11:06 AM
looking very nice dude
Posted 14 April 2013 - 01:25 PM
DanGersFord I want to do the twin reverse light but not sure how to sort the Fog light?
Also looking at door handle LEDs and maybe some DRLs.
Posted 14 April 2013 - 10:04 PM
looking good and liking the carbon wrap.the wheels suit the car well.
was the carbon wrap easy to do?as thinking of trying it my self and are the fog surounds and bonnet suround easy to take off?
Posted 17 April 2013 - 09:58 AM
Wrapping isn't to hard gets easier with practice but I cheated with bonnet lip and bought a pre wrapped one off Ebay.
Bonnet lip is held on with 3 lugs and sticky strips so just a case of gently pulling it off, and the fog rings needs a gentle push out of the surrounds! Rings were a pig to wrap though!
Posted 17 April 2013 - 03:55 PM
Looks great , wheels look much better i hated the titanium wheels on my old focus they were terrible to clean
Posted 17 April 2013 - 05:46 PM
Posted 18 April 2013 - 10:06 PM
Posted 19 April 2013 - 08:48 AM
cheers for the advie about the bonnet lip and fog surounds fella.
well done on getting in auto express
Posted 03 May 2013 - 09:22 PM
Posted 03 May 2013 - 10:05 PM
damnnn that front ends looking mean mate
Posted 04 May 2013 - 12:02 AM
Posted 20 May 2013 - 09:47 PM
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A new indie soap will go into production in June from Gregori J. Martin, the director of my film, Manhattanites. Following the life of socialite Sara Garrett and the people around her, THE BAY is a new web series in the vein of Aaron Spelling's 1980s classic primetime soap opera, DYNASTY. Filled with sex, lies, scandal, and everything required to make a hot 1980s soap opera, THE BAY stars several soap icons including Tristan Rogers (Scorpio, GENERAL HOSPITAL), Sandra Robinson (Amanda, ANOTHER WORLD), John Callahan (Edmund, ALL MY CHILDREN), Lilly Melgar (Lily, GENERAL HOSPITAL) and many others.
Martin is the producer/director/writer of the series. Rogers is one of the co-producers (in addition to producing the upcoming REALITY BYTES).
What daytime star would you like to see on the new web series THE BAY?"
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Good idea, Ban things that a few years ago were known to be unconstitutional.
Good for him. All AA does is allow minorities to attend colleges where they are automatically in the bottom 10% academically. If I were black I would tell my HS guidance counselor to assume that I were white, and have me apply to the appropriate schools.And blacks self-segrate and have their own dorms at most campuses. So what´s the point?
You can start by banning black ONLY colleges. Won´t happen....
What´s this guys name? Summerville. Summerville for President!! (Can you imagine weasels like McCain, Rubio, or Jeb doing something like this?)
Be nice if we could ban these discriminatory practices in our military.
Diversity is a liberal code word for discrimination
Good for him! Maybe it won´t pass, but it has been articulated out loud. Tennessee is a pretty conservative place. It will get people thinking about it, and perhaps the day will come when common sense will prevail.
To have any hope of surviving in the traditional sense, we need to start celebrating unity. Screw diversity...
You go Jim! In today´s warped world, ´diversity´ is code for preferential treatment - much as was given to the current occupant of the White House...And ´tolerance´ is newspeak for ´putting up with crap that would offend a blind deaf person not even present...´Diversity *divides* - and tolerance is terrorism.
Affirmative Action ha sbenefitted white women more than any othe rminority group.There is no such thing as a Black only college. They do not ban whites and whites do attend. They are Historically Black Colleges and are mostly black.
I thought it was already illegal to base anything on race.Liberals are the most racist people around.


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*Prints may not be reproduced!
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Estimated shipping is based on standard shipping rate inside contiguous United States. Your order total including shipping & taxes (NC) will be displayed later in checkout before submitting your order.
Item #R680 In Stock
Avg. Rating 8 reviews
Our Price: $69.95
Discover New & More Comfortable Sex Positions!
HOLDS UP TO 300 lbs!
• Enhances any position• E-Z Grip handles• Easier, more comfortable sex• Holds up to 300 lbs.• Simple to inflate & deflate• Slanted, flocked surface keeps you in place• Free mask included
Make fantasy sex positions a reality with the most amazing inflatable sex furniture you've ever tried! Even your current favorite positions can take on new, orgasmic proportions – for both of you! It's like having a custom-made sex bed! 31" x 22" with a height of 14" to 4".
Anonymous User on 3/8/2014
Not durable Works great but after a couple of months it deflated and will not stay inflated through a session.a bit over priced for only lasting a couple of months. Was this comment helpful? Yes No (0 people found this comment helpful, 0 did not)
Anonymous User on 7/11/2013
Good for travel on the road alot and this is great for us to take with Was this comment helpful? Yes No (0 people found this comment helpful, 0 did not)
Anonymous User on 1/2/2013
Not bad My husband and I bought this quite a while ago. We enjoyed it over all, but it can be a bit of a pain with the bouncing/instability that comes with a blown up item. After a few months the center supports let go, making it almost impossible to use at that point, I believe this was just a fluke with our particular one and considered buying another, but I think we are going to go with the foam version next time. Was this comment helpful? Yes No (1 person found this comment helpful, 0 did not)
Anonymous User on 4/23/2012
Fun This was our first piece from Adam and Eve and it was pretty awesome. We are very new to toys and furniture but this was a very good beginning piece. So many position options that are very comfortable for her and him! Was this comment helpful? Yes No (2 people found this comment helpful, 0 did not)
Anonymous User on 3/28/2012
sucks way too big rolls to much Was this comment helpful? Yes No (1 person found this comment helpful, 1 did not)
Anonymous User on 1/18/2012
awsome everyone should get this Was this comment helpful? Yes No (0 people found this comment helpful, 0 did not)
Anonymous User on 9/5/2011
A bit too bulky Well made as previously mentioned but a bit too big and awkward to use. Will continue to experiment, which is half the fun, but an instruction manual with a few more sample positions would have been of value. Was this comment helpful? Yes No (5 people found this comment helpful, 0 did not)
Bottoms Up. on 7/16/2011
Well made but slightly oversized Fun! We have used this pillow a few time already to experiment with new positions. You will need to use your imagination though. There is no instruction manual. Other than a few pictures on the box, you are on your own figuring out positions. But that is half the fun! This unit is well contructed. It is covered all over with a velvet texture and the handles seem rugged. Fully inflated it is 15 inches on the high side. It is just about right for my husband and I but we are both over 6 feet tall. For shorter people, you might need to get the smaller model or under inflate this one. One word of advice- this unit does not come with a pump and would be impossible to blow up manually. It is BIG. It took 10 plus minutes with a automatic pump. Overall this is much less expensive than the Liberator and easier to store when deflated. And new positions are always fun! Was this comment helpful? Yes No (10 people found this comment helpful, 0 did not)
Adam & Eve ships all of your items on a single flat rate.To stretch your shipping dollar, we suggest ordering several items at once. All orders are delivered in unmarked envelopes and boxes to preserve your privacy.
STANDARD SHIPPING - $8.00 Delivery time: Eastern Contiguous US (5 to 8 business days), Western Contiguous US, Alaska, Hawaii, and US Territories (10 to 14 business days) Standard shipping orders are processed in our warehouse facilities within 2 business days. These orders are delivered by the United States Postal Service. Standard can be used for any destination including PO/APO/FPO addresses. You will need to put a shipping zip code in to checkout to determine actual delivery times.
UPS 2-Day or USPS Priority - $14.00UPS Overnight or USPS Express - $22.00 Orders placed before 2:45 p.m. EST, Monday-Friday will process and ship same day. Orders placed after the 2:45 p.m. deadline or on a non-business day, will process and ship on next business day.
Adam & Eve's Return Policy is based on a simple principle – 100% Customer Satisfaction Guaranteed on Every Order. If at any time during the first 90 days of ownership you become dissatisfied for any reason whatsoever, return the merchandise to us for a replacement, an alternate selection or a full refund. If at any time an item does not perform due to a manufacturer's defect, return it to us. We will replace it without charge.
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Latest News
- Latest News
Navarro College awarded $350,000 grant
On Thursday, the Jobs and Education for Texans (JET) Advisory Board, chaired by Texas Comptroller Susan Combs, approved approximately $5 million in grants to help 18 public junior colleges and technical institutes purchase technical training equipment.
Navarro College received the largest grant of all, at $350,000, to go towards equipment for the certified welding program. -
Warner honored at blood drive
Corsicana's Roger Warner was honored Thursday at the Red Cross blood drive held at First United Methodist Church.
Warner's recognition was a part of the Red Cross Month observance, when the organization celebrates and recognizes everyday heroes in the community -
Fundraiser helps send middle-schoolers to NYC
Collins Middle School will host a Traveling Market and Resale Fair from 9 to 3 p.m. Saturday in the gym and cafeteria at the middle school, 1500 Dobbins Road.
Church News for Friday, March 7, 2014
News and announcements submitted by area congregations
Local Beat 3/7/14
A listing of meetings and events of interest from throughout Navarro County.
Retail gasoline prices across Texas up
IRVING — Retail gasoline prices are up a penny this week across Texas as some travelers prepare for spring break.
Stage Stores selling Steele's unit
HOUSTON — Stage Stores' fiscal fourth-quarter net income fell 30 percent, stung by a charge tied to the sale of its Steele's discount store division and softer revenue. Its adjusted earnings topped analysts' estimates.
Girl Scouts asked to end partnership with Barbie
NEW YORK - A few weeks after her foray into the Sports Illustrated swimsuit edition, Barbie is entangled in controversy again, this time over her ties with the Girl Scouts.
Show combines fun, learning, music
If you're in search of something fun and educational for the kids, check out the Warehouse Living Arts Theatre's Corsicana Children Company's presentation of "Schoolhouse Rock Live! Jr." which opened Wednesday.
Trash collection delays
Trash collection was delayed Monday because of the ice and weather, but that will continue through the rest of the week, according to the City of Corsicana.
- More Latest News Headlines
Navarro College awarded $350,000 grant


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Garbage Performing On Jay Leno Tonight
Rock band Garbage will be performing their song "I Hate Love" on Jay Leno's The Tonight Show tonight at 11:35pm EST on NBC. The song comes from their latest album Not Your Kind Of People (review), which came out earlier this year and was the first all new Garbage album in over seven years. You can listen to the song below.
Also, make sure to check out our interview with Butch Vig here. READ MORE


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James J. Hill House
James J. Hill House
240 Summit Ave
St. Paul, MN
United States
See map: Google Maps
Hours: Open year round: Wednesday through Saturday 10 a.m. to 3:30 p.m.; Sunday 1 to 3:30 p.m. Closed major holidays.
Art gallery hours: Monday through Saturday 10 a.m. to 4 p.m.; Sunday 1 to 4 p.m. Closed major holidays
Admission: Tours: $9 adults, $7 seniors and college students, $6 children ages 6-17; free for children age 5 and under and MNHS members.
Email: firstname.lastname@example.com
Phone: 651-297-2555