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Latest U.S. Efforts to Prosecute Trade Secret Theft Hit a Few Snags
Earlier this year, the Department of Justice announced an initiative to step up its enforcement of trade secret theft. In a February 20 press conference, Attorney General Eric Holder announced that the Obama administration aimed to make it a top priority to prosecute intellectual property crimes. At the press conference, the DOJ unveiled a report titled, "Administration Strategy on Mitigating the Theft of U.S. Trade Secrets," which focuses largely on how to prevent and remedy trade secret theft by foreign governments and foreign corporations.
Only two days later, however, a development in one of the DOJ's highest-profile trade secrets cases demonstrated the difficulties of prosecuting foreign defendants. On February 22, a federal judge in the Eastern District of Virginia determined that, despite eight attempts, the DOJ had not properly served Kolon Industries Inc, a South Korean company accused of stealing trade secrets from duPont, a U.S. company. The DOJ's criminal case follows a civil trial that returned a $919.9 million judgment against Kolon for stealing 149 trade secrets related to Kevlar, a synthetic fiber used in body armor. Kolon used those trade secrets to create its own competing fabric, Heracron.
The difficulties the DOJ encountered in bringing the overseas perpetrators to justice is especially relevant because the report indicates that most secret theft is committed by foreign nationals, especially in China. According to the report, "Chinese actors are the world's most active and persistent perpetrators of economic espionage. US private sector firms and cybersecurity specialists have reported an onslaught of computer network intrusions that have originated in China, but the [intelligence community] cannot confirm who was responsible." The vast majority of cases highlighted in the report involve Chinese nationals or Chinese firms.
The difficulties in bringing foreign nationals to justice only emphasize the need for corporations to take stronger precautions to prevent their trade secrets from being stolen in the first place. The "Administration Strategy" document recognized this need and proposed that companies work cooperatively to develop best practices for trade secret protection in areas such as research and development compartmentalization, information security policies, physical security policies, and human resources policies.
The "Administration Strategy" document notes that companies suffering from trade secret theft may be hesitant to come forward for fear of how it could affect the company and its stakeholders. However, the document encourages them to do so, both in order to bring the perpetrator to justice and to allow the government to collect information that could help to identify patterns in trade theft and prevent similar events in the future.
The DOJ has demonstrated its commitment to trade secret enforcement by continuing to pursue the Kolon case despite the February setback. The DOJ filed a superseding indictment on March 19 and must now serve Kolon in accordance with the judge's February 22 order. Given the fanfare with which the DOJ announced its trade secret agenda, there is no doubt that the government will continue to doggedly pursue this and other trade secret cases.
We support the DOJ's effort to protect corporate trade secrets so that companies can benefit from the innovation that they work so hard to develop. As always, we also remain on the lookout for indications of overzealous prosecution in instances where it does not appear that confidential proprietary information has been stolen.
Ifrah Law is a leading white-collar criminal defense firm that focuses on online piracy.
Online Piracy
White-collar crime
Trade secrets
Court to Rule on Exceptions to Warrant Requirement for GPS Tracking
The U.S. Court of Appeals for the 3rd Circuit is set to become the first federal appellate court to answer the question left open by the Supreme Court in United States v. Jones. Last year, the Court held in Jones that a Fourth Amendment "search" occurs, and a warrant is required, when a GPS tracking device is attached by law enforcement to a person's vehicle and then used to track its movements. The Court did not consider when, if ever, that type of search would be exempt from the Constitution's warrant requirement.
Last month, the 3rd Circuit heard oral arguments on that question. It is expected to issue its decision later this year.The appeal relates to the prosecution of Harry, Michael, and Mark Katzin — three brothers charged with the burglary of a Rite Aid pharmacy in Pennsylvania. In 2009, authorities began investigating a rash of pharmacy burglaries in the Northeast. Most of the crimes targeted Rite Aid stores and appeared related because each occurred after someone had cut the wires to the pharmacy's alarm system. Eventually, authorities identified Harry Katzin as a person of interest. He had been implicated in suspicious activities involving other Rite Aid pharmacies and was known to keep electrician's tools, gloves and ski masks in his van.
Initially, agents physically tracked Katzin's movements. Then they decided more comprehensive surveillance was needed, so they attached a GPS tracking device to Katzin's bumper and waited. Two or three days later, the tracking device showed that the van had stopped at a Rite Aid store in Hamburg, Pa. After the van left, one agent drove to the store to confirm it had been burglarized while state troopers followed the van onto the highway. When the burglary was confirmed, troopers stopped the van and arrested the Katzins. Only then did authorities obtain a search warrant, which led to their discovery of merchandise from the Rite Aid store, parts of the pharmacy's alarm system, and Schedule II drugs.
In April 2011, the brothers were charged with pharmacy burglary and possession of Schedule II drugs with intent to distribute. They filed a pretrial motion to suppress the evidence found in the van. At that time, neither the 3rd Circuit nor the Supreme Court had decided whether the attachment and use of an external GPS tracking device constitutes a Fourth Amendment search. In early 2012, the Jones Court made clear that it does. Applying Jones, the trial judge granted the Katzins' motion, and the government appealed.
On appeal, the government argues that the search in question, i.e., the attachment and use of the GPS device, falls within one of two exceptions to the warrant requirement. Under the "reasonable suspicion" exception, a warrantless search may be conducted under limited circumstances if the minimal intrusion on the individual's privacy is outweighed by a legitimate government interest. In this case, the government contends, the "trespass" to Katzin's van was minimal because it involved the placement of a magnetic GPS device on the bumper. Subsequent monitoring of the device was minimally intrusive because it revealed only the location of the van — information that could be obtained by physical surveillance. In the government's view, these minimal intrusions were outweighed by the government's interests in investigating crime.
The government also argues that the search falls within the "probable cause" exception. Under that exception, officers may conduct a warrantless search of an automobile if there is probable cause to believe it contains contraband or if exigent circumstances make a warrant application impractical. The government claims that no warrant was required in this case because officers had probable cause to believe that Katzin would use his van to burglarize another Rite Aid pharmacy.
The Katzin brothers counter that neither exception applies. First, the "reasonable suspicion" exception does not apply because the officers installed the device without a reasonable, articulable suspicion that criminal activity was afoot at the time of installation. Instead, the officers proceeded on a hunch that turned out to be right. The Constitution requires more than that.
The "probable cause" exception does not apply because, when the officers installed the device, they had no reason to believe there was contraband in the van or that the van was readily mobile, which might have made a warrant application impractical. As the Katzins point out, the officers attached the device in the dead of night on a deserted street. If the officers had evidence to support probable cause under those circumstances, they should have applied for a warrant.
Our sense is that the trial court will be upheld. The Fourth Amendment's baseline requirement is that searches be conducted pursuant to a valid warrant supported by probable cause. These facts do not appear to support an exception. As the trial judge noted, the government argues for application of the "reasonable suspicion" exception based on its general interest in efficient law enforcement. The government did not prove that the special needs of this case required the warrantless intrusion visited on the defendants.
Likewise, the government argues for application of the "probable cause" argument based on the officers' general suspicion that Katzin would use his van to commit a crime in the coming days, weeks, or months. The government did not prove that the officers had probable cause to believe that a crime was in progress when the device was attached. If courts do not hold the line on these exceptions, the Fourth Amendment will be eviscerated.
Ifrah Law is a leading white-collar criminal defense firm that focuses on a variety of practice areas. View all.
View all
Federal Criminal Procedure
Are Investors Lining Up Behind Another and Better Bitcoin?
We have written previously about Bitcoin, the new form of "peer-to-peer" currency whose proponents expect to be a game-changer in the world financial markets. It's not clear yet what Bitcoin's ultimate destination will be, as the currency has had a lot of scrutiny, and undergone a tremendous amount of volatility, lately.
In a recent 24-hour period, the value of a single Bitcoin on the largest Bitcoin exchange, Mt. Gox, was high as $266 and as low as $105. It's hard to sustain a business model with that incredibly high volatility factor.
However, according to TechCrunch, angel investors and venture capitalists remain "hungry to invest in the ecosystem surrounding the decentralized digital currency." In other words, investors want to create a different, and possibly superior, Bitcoin.
That currency is known as OpenCoin, which wants to create a decentralized global currency yet prefers to stay away from the moniker of "another Bitcoin." The company behind OpenCoin has raised an undisclosed amount of venture-capital money to expand the open-source code behind Ripple, which is a virtual currency and payment system that aims to make it easy and affordable for anyone to trade any amount in any currency.
OpenCoin hopes to clear its transactions within minutes; to handle dollars, euros, and other currencies seamlessly; and to solve BitCoin's security issues.
Some observers think OpenCoin has a greater chance of success than Bitcoin because it has been carefully conceived rather than just springing up from the minds of a few hackers, and because it doesn't have a history of volatility and of facilitating illegal payments.
But it's still a very long way before any of these artificial currencies catches on. We will be watching them carefully. We hope that financial regulators, both in the United States and world-wide, realize that these currencies can do a great deal of good, and that the Treasury Department doesn't conclude that they are nothing more than vehicles for money laundering. Treasury's recent announcement that dealers in Bitcoin-like currencies must obey money-laundering laws seems like an acceptably moderate approach.
Ifrah Law is a leading white-collar criminal defense firm that focuses on financial services.
SEC 'Likes' Public Company Disclosures on Facebook and Other Social Media
Last December, we wrote about the U. S. Securities and Exchange Commission's issuance of so-called "Wells" notices indicating that the agency was considering whether to bring enforcement proceedings against Netflix and its CEO, Reed Hastings. The SEC's ire was aroused by a posting by Hastings on his personal Facebook page about Netflix's success. The agency was concerned about whether such statements in social media complied with disclosure requirements known as "Regulation Fair Disclosure" or "Reg FD."
In general, Reg FD requires that, when an issuer discloses material, nonpublic information to certain individuals or entities – generally, securities market professionals such as stock analysts or holders of the issuer's securities who may well trade on the basis of the information – the issuer must make public disclosure of that information. The purpose of these restrictions is to prevent issuer companies from disclosing material information preferentially to certain traders or securities market professionals.
On April 2, 2013, the SEC issued a report that made clear that companies that use social media outlets like Facebook and Twitter to announce key information are in compliance with Reg FD so long as investors have been alerted about which social media will be used to disseminate such information. In approving the use of social media (with the stated proviso), the SEC reinforced that Reg FD applies to the use of what it characterized as "emerging means of communication" the same way that it applies to company websites, and referenced the SEC's 2008 guidance regarding the use of websites.
The SEC's conclusion should be no surprise. On the one hand, it reinforces the widely recognized and increasing use of social media as a source of information by a growing segment of the population. On the other hand, it serves as a reminder to companies that they need to make sure that all investors know and have access to the channels that the companies use to issue important information.
The likelihood, for now, is that companies will continue to use a variety of means to issue information to the public – including social media, websites and more old-school methods such as press releases. But the acceptance of social media as an appropriate means of disclosure for publicly owned companies is an important step forward in the evolution of social media from a means of friendly banter to an important information channel for businesses and investors alike.
Ifrah Law is a leading white-collar criminal defense firm that focuses on financial services.
Securities fraud
What's at the Bottom of the 'Robosigning' Scandal?
The problematic practice of robosigning – whereby banks and other lenders improperly foreclosed on properties through formulaically processing foreclosure documents – has been much in the news over the past couple of years. The feds have been investigating banks and individuals; state attorneys general have joined forces in pursuit of robosigners; and, unsurprisingly, there have been a number of class actions filed by consumers whose homes were foreclosed.
The fallout of these actions has been somewhat inconsistent. On the settlement side, banks and individuals are facing hefty penalties: Bank of America, JPMorgan Chase, Wells Fargo, Citigroup, and Ally entered into a massive $25 billion settlement with the Justice Department and state attorneys general (of 49 states) in early 2012. The mortgage servicing firm, Lender Processing Services (LPS), recently entered into a $120 million settlement with a coalition of state attorneys general (of 45 states). A founder of one of LPS's subsidiaries, Lorraine Brown, pleaded guilty to federal conspiracy charges and Missouri state charges and faces not less than two years imprisonment.
Those defendants who have not settled may be faring better. In early March, a Nevada district judge threw out an entire case against two title officers of LPS who faced more than 100 felony counts. (The judge's ruling was not merits-based but rather based upon prosecutorial misconduct.) A New Jersey federal judge recently dismissed a putative class action against Bank of America, noting the plaintiff's failure to prove that robosigning constituted fraud.
Part of the challenge for cases that don't settle out may be proving damages to homeowners who lost their homes: If a home was foreclosed on deadbeats, where are the damages in rapid-fire paper pushing? Some banking experts have found that, between 2009-2012, mortgage servicers created some 800,000 foreclosures that could have been avoided through loan modification programs. And foreclosure practices at BofA and Morgan Stanley subsidiaries were found to have violated the Servicemembers Civil Relief Act, which provides active servicemembers financial protection in matters such as civil proceedings, income tax disputes and foreclosures. But these two categories are only a small subset of foreclosures, which have amounted to between one million and four million each year for the last six years.
One lesson from these matters may be that settling is not always the best option. But another take-away that hasn't come up is how banks and mortgage servicers got into the practice of robosigning in the first place. The issue faced by the banks and lenders was a glut of foreclosures and a related mountain of paperwork to process those foreclosures. How could they effectively address the problem and the dead weight on their ledgers? The answer was to institute an efficient, and automated, process. The problem with automation, though, is a lack of oversight or subjective inquiry – the very purpose behind much of the required foreclosure documents.
While the banks and processors are certainly to blame for false certifications and notarizations, their actions are not as nefarious as many make them out to be. How often are we all guilty of "robosigning" the terms and conditions for a new software program or credit card application? How often do we read all the new disclosures that financial institutions are required to send with each statement or loan request? Part of the problem is that we are faced with a mass of disclosures resulting from both regulation and excess litigation. The information overload is part of what has played out in the robosigning scandal.
The Government Accountability Office just released a report criticizing the Federal Reserve's review of the robosigning matter, saying that the review itself has become cumbersome and inconsistent. The only problem is that there is no realistic resolution to the problem. Until we can devise a way to be both thorough and totally efficient in processing information, we will inevitably face new versions of the robosigning scandal.
Ifrah Law is a leading white-collar criminal defense firm that focuses on financial services.
Financial Regulation, Fraud
Mortgage fraud
Judge Strikes Down FBI's Use of 'National Security Letters'
In a recent decision, U.S. District Judge Susan Illston of the Northern District of California struck down the FBI's use of National Security Letters (NSLs) as unconstitutional. Unbeknownst to most Americans, the FBI has been issuing thousands of NSLs every year. The letters demand that recipients, such as banks and telephone companies, provide customers' information such as their transactional records, phone numbers dialed, and email addresses mailed to and from. This doesn't involve the content of the phone calls or emails but does involve the names of addressees or participants. One reason most Americans didn't know about these letters is because more than 95 percent of them contain gag orders, barring the recipient from disclosing their content or even their existence.
This case began nearly two years ago, in May 2011, when a nonprofit advocacy group, the Electric Frontier Foundation (EFF), filed suit on behalf of an unnamed telecom company that had received an NSL. In defense of the NSLs, the government argued that this level of secrecy is necessary to protect the nation against potential security threats. NSLs were designed in the 1970s as a means to gather information on suspected foreign spies during terrorism and espionage investigations. However, the Patriot Act greatly expanded their reach to allow the FBI to secretly compel companies to provide data on American citizens.
The constitutionality of NSLs is dubious for two distinct reasons. Not only does the nondisclosure clause infringe on their recipients' free speech, but, unlike a standard subpoena or search warrant, the NSLs do not have to be authorized by a judge. Accordingly, Illston concluded that NSLs and their nondisclosure provisions violate the First Amendment and separation of powers principles, and she ordered the FBI to stop issuing NSLs and cease enforcing all gag provisions. That said, we are uncertain whether Illston's order will ever go into effect. Due to the gravity of the First Amendment and national security issues at stake, Illston issued a 90-day stay, giving the government time to appeal her decision to the U.S. Court of Appeals for the 9th Circuit.
Although the lawsuit was filed anonymously, various media sources have suggested that the unnamed defendant may be Credo Mobile, a phone provider that supports progressive causes. The day after the ruling was released, Credo's CEO Michael Kieschnick released the following statement:
"This decision is notable for its clarity and depth. From this day forward, the US government's unconstitutional practice of using national security letters to obtain private information without court oversight and its denial of the first amendment rights of national security letter recipients have finally been stopped by our courts."
According to Matt Zimmerman, an EFF attorney, the NSL gags "have truncated the public debate on these controversial surveillance tools," and his unnamed client "looks forward to the day when it can publicly discuss the issue."
As we await the higher court's ruling, which we hope leaves Illston's decision in place, one thing has already been accomplished of a positive nature. A federal district judge has shined some light on a little-known and highly dubious federal law enforcement technique.
Ifrah Law is a leading white-collar criminal defense firm that focuses on data privacy.
Data Privacy
Federal Criminal (Other)
N.J. Sets Up Regulations for Fantasy Sports Competitions in Casinos
On March 19, 2013, the New Jersey Office of the Attorney General, Division of Gaming Enforcement (DGE), announced that it has adopted temporary regulations authorizing the state's casinos to offer fantasy sports tournaments to their patrons. The regulations permit casinos, on their own or in partnership with fantasy sports providers, to offer fantasy sports tournaments or contests.
The temporary regulations will remain in effect for a period of 270 days. During that time, the DGE will propose the regulations for final adoption. The text of the regulations could change from their current form to the form that is eventually adopted. The regulations will become effective on April 22, 2013. The minimum age for participation in fantasy sports tournaments at casinos is 21. Full text of the temporary regulations is available here.
A fantasy sports tournament is a simulated game in which a player manages an imaginary sports team and competes for a monetary prize against teams managed by other players. Since fantasy sports involve considerable skill in the selection of teams and players, they are widely considered not to constitute gambling. Fantasy sports can involve season-long or single-day tournaments.
The New Jersey temporary regulations clearly define that all prizes and awards must be made known to all participants prior to the start of the tournament. The winning outcome of a fantasy sports tournament shall reflect the relative skill of the participants and the outcome cannot be determined solely on the performance of any individual athlete or on the score, point spread, or performance of any single real world team or combination of teams.
The temporary regulations authorize casinos to utilize the casino cage to accept entry fees and pay out winnings from fantasy sports tournaments in the casino. Under the temporary regulations, fantasy sports are not considered to be gambling under state law. Therefore, revenue generated from these games is not subject to the same taxes as revenue generated from table games and other games offered in casinos.
This announcement on fantasy sports is part of a flurry of activity in New Jersey dealing with the state's gaming industry. Last month, New Jersey became the third state to legalize online gaming within its borders, and games could be online by the end of the year. Earlier this month, a federal judge in New Jersey struck down the state's sports betting law and the decision has been appealed by the state to the U.S. Court of Appeals for the Third Circuit.
We are very happy to see New Jersey add fantasy sports offerings in its casinos. This will be a boost for the state as well as for patrons who will soon be able to play these games in casinos.
Ifrah Law is a leading white-collar criminal defense firm that focuses on igaming.
State Criminal
Gaming law
Treasury Department: Bitcoin Dealers Are Regulated Under Money-Laundering Laws
Timothy Lee at Forbes magazine has reported today that the Financial Crimes Enforcement Network (FinCEN), a branch of the Treasury Department, has issued new guidelines on the legal status of Bitcoin under U.S. money laundering laws. Essentially, Bitcoin dealers have now been placed under the nation's anti-money laundering regulations and must comply with those rules.
Lee notes that Bitcoin exchanges, which exchange Bitcoins for conventional currencies, and most Bitcoin "miners," which process Bitcoin transactions, must now register as Money Services Businesses (MSBs) under the Treasury regulations. Ordinary users of Bitcoins need not register.
Bitcoin is a peer-to-peer network that exchanges the virtual currency in a largely unregulated environment. Lately, Bitcoins have become acceptable for a number of types of transactions, and some see them as a currency of the future that transcends national borders.
Lee argues that the Treasury action is actually not a bad thing for Bitcoin's future.
"FinCEN is clearly trying, in its somewhat bumbling way, to squeeze a square technological peg into its round regulatory hole. Reading between the lines, FinCEN is saying that if Bitcoin-based businesses fill out some paperwork and collect some information about their customers, then they'll be left alone," Lee writes.
Given the existence of U.S. anti-money-laundering statutes, Lee adds, "FinCEN's guidance is probably the best Bitcoin fans could have hoped for: it sends a clear sign that America's anti-money laundering regulators do not consider the currency a threat and isn't going to try to force it to change or shut down."
We tend to agree. There needs to be a balance between enforcing the money-laundering laws (which are designed as a tool against terrorism and other serious wrongdoing) and permitting the free exchange of commodities and currency. It appears that the Administration, so far, is striking the correct balance.
Ifrah Law is a leading white-collar criminal defense firm that focuses on financial services.
Money laundering
Court: Data on Unsecured Network May Qualify for 4th Amendment Protection
The vast increase in the use of wireless data networks has led to new legal issues regarding network users' right to privacy. A recent opinion issued by the U.S. District Court for the District of Oregon indicates that, under some circumstances, individuals on an unsecured wireless network have a reasonable expectation of privacy entitling them to Fourth Amendment protection. As a result, police officers must obtain a warrant prior to accessing files on that network.
In United States v. Ahrndt, defendant John Henry Ahrndt moved to suppress evidence that a police officer obtained by accessing Ahrndt's wireless home network and opening files without a search warrant.
In February 2007, one of Ahrndt's neighbors connected to Ahrndt's unsecured wireless internet network. When she opened her iTunes program, she was able to see "shared" files from Ahrndt's iTunes and LimeWire accounts, and saw a number of titles indicative of child pornography.
The neighbor did not open any of the files, but called the police to report what she saw. A deputy came to her house and she showed him the file names as she had seen them. The deputy asked her to open one of the files. When she did, it opened an image of child pornography.
The deputy questioned the neighbor about whom the unsecured wireless network might belong to. She indicated that the network had been available since she moved into the building, and at the time Ahrndt's home was the only other one that was occupied. The police ran the license plate of a car parked outside of the home and identified it as belonging to Ahrndt, a convicted sex offender.
Using a general description of what the neighbor and deputy recalled seeing in the list of file names, the police applied for and received a search warrant to access the wireless network again in order to get an IP address. The police then served a summons on the Internet provider. The provider disclosed that Ahrndt was the subscriber in question.
Using that information, the police obtained a search warrant for Ahrndt's home. They ran a forensic search of his computer and identified images of child pornography in various folders. The forensic report did not mention either iTunes or LimeWire.
In considering the motion to suppress the evidence obtained through the initial warrantless search, the court concluded that it would have been appropriate for the deputy to view the titles of the files without a warrant, since a private party (the neighbor) had already viewed those files and told the police about them. However, the court concluded that it was a violation of Ahrndt's Fourth Amendment rights for the police to instruct the neighbor to open the file, which she had not previously done. The opened image was no longer within the purview of private search, but a government search.
The court also found that Ahrndt's privacy expectations were not eliminated by accessing an unsecured wireless network. There was no evidence that Ahrndt had intentionally enabled sharing for those files; rather, the default setting of the LimeWire program enabled sharing. It was Ahrndt's reasonable belief that those files were contained only on his hard drive, and not shared on a public network. The court said that "[i]n short, the government does not dispute a person has a reasonable expectation of privacy in the files on his home personal computer."
The court concluded that, lacking specific file names and a description of images, a magistrate would not have found probable cause to issue a search warrant. The only evidence that the police viewed lawfully was the file names, which the neighbor and deputy could not remember with specificity. Since the "partial recollections and characterizations" were too general to support a warrant, all related evidence from the unlawful search must be suppressed.
The court came to the right conclusion on this one. Our reliance on the Internet has become such that what is on our computers is as personal and private as the inside of our homes. The government is no more entitled to search our computer without probable cause than to search our homes. This case does not represent a free pass to intentionally share information on wireless networks and then assert Fourth Amendment rights when the government comes knocking. Rather, it is only that information to which an user has a reasonable expectation of privacy—such as files that he is not aware are accessible to others—that is protected against the government's unlawful search and seizure.
It's easy to see how this has implications for potential white-collar cases: the government might try to use financial information unintentionally made available to a neighbor through an unsecured network as a basis to initiate a financial fraud investigation. We hope that the courts will rely on this case and suppress any evidence obtained as a result of this type of unlawful search.
Ifrah Law is a leading white-collar criminal defense firm that focuses on data privacy.
Data Privacy
Federal Criminal Procedure
Was This Identity Theft? Sixth Circuit Should Limit Meaning of That Term
What's in a name?
When you think of identity theft, you typically think of someone taking a person's name plus some other identifiers, like their address and Social Security number or credit card number, to go on a spending spree or drain the victim's bank account. You may think of fraudulent impersonation. But what if someone falsely stated that another person gave him permission to use their joint property as collateral on a loan? That sounds like a false statement but not a case of stolen identity. Yet a federal district court in Tennessee found that just this scenario constituted identity theft in a current case against real estate broker David Miller.
Perhaps the court's holding doesn't sound too troubling. After all, identity theft is a crime and it's clearly behavior that we want to deter. But expanding the reach of what may fall under the federal identity theft laws doesn't really deter the behavior that Congress sought to address by statute. It just makes it harder to anticipate the bounds of the law, and that is troubling.
Congress passed the Identity Theft and Assumption Deterrence Act of 1998 in order to address the growing problem of fraudsters taking people's personal information to either steal from their existing accounts or to run up debt in the victims' names. The act criminalized fraud in connection with the theft and misuse of personal identifying information. (Before the law was passed, only fraud in connection with identification documents was a federal crime.) But there was some concern that prosecutors were not vigorously going after identity theft cases. So Congress passed the Identity Theft Penalty Enhancement Act of 2004. Again, this measure was aimed squarely at penalizing identity thieves who were attacking consumers' financial accounts and credit. The bill's sponsor, Rep. John Carter (R-Tex.), said identity theft is "a crime that we need to address and address seriously … for the protection of the credit of American citizens."
Years later, the Department of Justice appears to have gotten the message and is actively prosecuting identity theft cases. All is well and good with the DOJ's ordinary efforts in this area. On its website, the DOJ discusses identity theft issues in a familiar context, relating concerns over the misuse of "your Social Security number, your bank account or credit card number, your telephone calling card number, and other valuable identifying data."
It also provides exemplary cases, which are again in keeping with the general understanding of what constitutes identity theft: (1) a woman pleaded guilty for using a stolen Social Security number to obtain thousands of dollars in credit and then filing for bankruptcy in the name of her victim; (2) a man pleaded guilty after obtaining private bank account information about an insurance company's policyholders and using that information to deposit counterfeit checks; (3) a defendant was indicted on bank fraud charges for obtaining names, addresses, and Social Security numbers from a Web site and using those data to apply for a series of car loans over the Internet.
So with a pretty clear understanding of congressional intent and a fairly clear depiction of the scope of federal identity theft laws, it seems a bit like prosecutorial overreach for the DOJ to turn around and use these laws in a case like that against David Miller. Not in keeping with the sample cases above, Miller's "theft" involved him "using the names of two individuals in a document that stated Miller had the authority to pledge real property as collateral for the loan when he had no such authority." He was not trying to impersonate them to create new accounts or steal from their existing accounts. There are other laws to prosecute what Miller did – and he was found guilty of making false statements to a bank.
The concern here is that adding the identity theft count to Miller's sentence is a misuse of the Identity Theft Penalty Enhancement Act and an overexpansion of what behavior falls under the rubric of identity theft. What is next? Will the department uses this law to prosecute those who lie about references on a job application?
The general rule is that criminal laws should be strictly construed in favor of the defendant. The ruling against Miller seems a case in point where the Rule of Lenity was not applied. Miller has appealed to the U.S. Court of Appeals for the Sixth Circuit, which will hopefully bring the law back within its intended scope.
Ifrah Law is a leading white-collar criminal defense firm that focuses on online fraud and abuse.
Online Fraud and Abuse
Federal Criminal (Other)
Fraud, Identity theft, Mortgage fraud


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Heikki Kovalainen, Lotus, Sepang, 2010
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JoEl said on 4th April 2010, 7:03
guys, why many of the Lotus car photos are small? i really appreciate the great pics you guys post every race but, please put those pics in high quality …will ya?
keep the good stuff coming….thnx..jc
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A disturbing wave of violence unleashed.
The Silent Intifada
American-Israeli journalist Arlene Kushner maintains a blog in which she discusses political, diplomatic and military issues affecting Israel: www.arlenefromisrael.info. She currently also serves in a consultant capacity with the Center for Near East Policy Research.
Ted Cruz's a Badge of Honor
Making David Into Goliath
Daniel Greenfield, a Shillman Journalism Fellow at the Freedom Center, is a New York writer focusing on radical Islam. He is completing a book on the international challenges America faces in the 21st century.
World Ignores Christian Exodus from Islamic World
Raymond Ibrahim is a Shillman Fellow at the David Horowitz Freedom Center, a Judith Friedman Rosen Writing Fellow at the Middle East Forum and a CBN News contributor. He is the author of Crucified Again: Exposing Islam's New War on Christians (2013) and The Al Qaeda Reader (2007).
Preventing an Israeli Fifth Column
Charles Bybelezer is a correspondent for i24News, a recently-launched international television network that broadcasts out of Tel Aviv.
Mr. President, Where Is Your Outrage?
Ari Lieberman is an attorney and former prosecutor.
Caroline Glick: The End of the 'Peace Process'
The Anti-Israel Movement Campaign Explained
The Myth of Ethnic Inequality in Israel
Steven Plaut is a native Philadelphian who teaches business finance and economics at the University of Haifa in Israel. He holds a PhD in economics from Princeton. He is author of the David Horowitz Freedom Center booklets about the Hamas and Jewish Enablers of the War against Israel.


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You are here: Home :: Forum Home :: Forums :: Community Discussion :: Thread
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Today on HSN they had another American Crafts airing.. here are some of my projects with this SUPER fun and adorable kit... man they were selling it for dirt cheap too!!!! such a great deal... You can also check out the link here and watch the show that aired.. HERE:
Tuesday, September 23, 2008
American Crafts HSN
3 comments :
- Melanie said...
These are fantastic, I especially love the Thanks card.
I love the colour combo used, they are refreshing and vibrant.
- September 24, 2008 at 5:15 AM
- Alecia said...
How COOL is that to see your work on TV... wonderful job my friend!!
- September 24, 2008 at 8:42 AM
- Leah said...
So fun!
- September 25, 2008 at 2:43 PM
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Looking for Agar (or is it Agar Agar?) in a store...
Anyone know where Agar (for consumption) is sold in Dallas? I know I can order it online, but I don't want to wait for it...
Same as any ethnic grocery (Super H Mart, Asia World, 99 Ranch etc). I've used it for gulaman and sago, a Filipino drink. mmm...
it is agar agar....they have the seaweed version or the powder version at most Asian themed supermarkets.
I was using as a vegetarian stabilizer for a recipe I was working on for the Hatch Chile festival at Central Market. I didn't enter but I came up with a good recipe!
It is agar agar, also known as kanten. It comes in sheet or powdered form, and at least the sheet form is usually available in white or red. As others have said, any 'Asian market should have it in stock.
Many of the health food stores (not GNC) will carry it. It's used a lot in (mostly) Macro cooking for fruit desserts.
Sometimes it comes in translucent square tubes. Not so useful for sprinkling in some powder but great for making yokan type desserts (made mango recently). I got mine at either H Mart or Minoya.
Thanks everyone! Need the powder kind, so I'll check the stores out. Trying to give this Alinea recipe a try where I need to make cider gel.
Did see agar agar at Ranch 99 last week. I just happen to have a large stash of alginate from elBulli. Spheres!
Sorry for the bad pic, new Blackberry bites.


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Austin Studio Rental Photos and Description
Studio Apartment with full bath and kitchenette. Sleeps 2
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Dallas' Best Halloween Costumes 2014
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If you've been busy traveling the world and not filing expense reports the past month, perhaps you've not heard of the "Jayson Blair saga" that roiled The New York Times. A quick recap: A young reporter, Blair, made up facts, plagiarized and lied about traveling to various locations to cover stories. It would be like if Buzz wrote about city politics and almost never attended an actual city council meeting. Oh, wait a minute...
Anyway, this scandal cost Blair his job, and in its wake a top writer and the Times' top two editors also resigned. The whole ugly mess caused much journalistic hand-wringing and navel-gazing--pretty picture, no?--at all newspapers not named Observer. (Hey, we're above this sort of stuff. We're past ethics. We're ultra-ethical. Nay, über-ethical.)
Not so at The Dallas Morning News, where the Blair incident has led to much staff introspection.
"It was clear that people here wanted to talk about the issues that came of this," says Morning News President and Editor Bob Mong. "So we set up a series of brown-bag lunches and went over our rules on datelines, using stringers [freelance writers], confidential sources, expense reports, everything."
From these meetings, Mong says, a few recurrent themes have emerged. Most heartening, he says, is that "universally, the people here want to get it right, and they want to get it right every day." Which looks a whole lot more "no, duh" on the page than it does when he says it.
Some of the charges did gripe that there is a star system in place at the DMN.(Which every newsroom gripes about.) More troubling--at least they should be--are the complaints Mong received that suggest, well, that people are scared to complain. "There is still some reluctance for folks to come forward to their managers with concerns and complaints," Mong says. "And that can't be. We have to make it a hospitable environment for that sort of dialogue."
Very true. But you can understand the self-preservation gene that kicks in at the DMN. It's all well and good for the big boss to say no one will retaliate if you bring problems to the fore. But when reporters are still being threatened with being shuttled off to Collin County or Denton bureaus--and wasn't that pitched just six months ago as a promotion by management?--that creates a fearful environment. When your parent company, Belo, has just told its Guild employees at The Providence Journal in Rhode Island that, yes, we will offer you a contract for the first time in three years, but it can only take effect if the National Labor Relations Board expunges the 27 guilty counts against us that we incurred because of our illegal bargaining tactics--well, they ain't stupid. They see how upper, upper management views dissent.
Would it help to have an ombudsman, someone to air these journalistic or personnel concerns in the paper? Mong says not necessarily, because then managers don't feel accountable. Handling problems is delegated to the ombud, in other words. "What you need is a place that communicates with itself. You just can't be arrogant. You just can't."


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You don't pay for tutoring
unless you find a good fit!
Neil L. passed a background check on 1/16/13. The check was ordered by another user through First Advantage. For more information, please review the background check information page.
After sending a message to Neil, you will be able to order a new background check for $7.99. As part of your tutor selection process, we encourage you to run updated background checks. Please also review the safety tips for hiring tutors.
Hello! As a tutor of all things verbal, I bring a wide range of experience and training. I hold an MA in English and Creative Writing from the University of Illinois at Chicago. I did two years of additional graduate work in Comparative Literature at Kent State and I studied English and American Literature with a concentration in Modern Literature at the University of Kentucky. I have published poetry in a number of literary magazines and am the author of a chapbook of poems. I spent ten years as a free-lance writer and editor. I have taught the following college courses: Freshman English, Remedial English, Advanced Composition, Advanced Composition for Non-English Majors, Introduction to Literature I & II, Special Studies in Poetry: Stylistics, Creative Writing: Poetry. On the high school level, I have taught sophomore and senior English.
Because I have always been a great test-taker and because there always seems to be a great demand, I have been tutoring test prep recently and can offer the following: ACT English, Reading, and Science; GRE verbal (97th percentile); GRE Advanced Test in Literature (92% percentile); LSAT (99th percentile). I actually think the logic games on the LSAT are fun! I also prepare students for the GMAT by teaching them all the relevant grammatical issues needed for the sentence correction, as well as the logic and RC. (The rates for LSAT and GMAT preparation are substantially higher than the rates for other tests; please e-mail for prices)
If you are one of those who can't quite get the special types of thinking that literature demands, or if you need assistance in your own essay writing or your own poetry, I can help you with any genre of literary studies or any type of writing task.
I especially enjoy the one-to-one relationship of tutoring, within which I can quickly diagnose a student's weaknesses and work with him or her on precisely those issues that need addressing. With my direction and your hard work, we can help you find the success that eludes you in the classroom environment!
At present I teach only at the Evanston Public Library, main branch, or via Skype.
My educational background in English, my teaching experience in both basic and advanced composition courses, and my years as a writer and editor have made a correct and precise knowledge of grammar and usage a unique specialty of mine. I combine a knowledge of traditional prescriptive grammatical approaches with a linguistics-based descriptive approach. This allows me, at times, to provide explanations of grammatical conventions that are more logical and simpler to comprehend.
The result, when I've done ACT prep, is that students' English test scores jump after one session. It
I scored in the 97th percentile on the verbal portion of the GRE and in the 92nd percentile of the special test on Literature. Actually, on taking the literature practice test on the GRE last week, I scored in the 99th percentile, so I must have learned something in graduate school. I do not teach the quantitative section.
I have taken the LSAT and scored a 171 (99% percentile). Confirmation is available on request. I have already devised an LSAT lesson plan that includes both diagnostics and remedies. The test is only a disciplined application of a skill, logic, that everyone already possesses. That application, on this test, can be accomplished by the use of a fairly small set of logic principles and tools -- all are teachable. I know what to teach; I am able to teach it; therefore, we will have happy, successful students.
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Southern Illinois University, Carbondale (English)
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Attentive and invested in your success! — Neil provides his students with everything they need to succeed on the test. I never lacked material to practice with, and was always able to reach out in between sessions for help via email. He even spent time outside of our sessions analyzing my work, defining my trouble areas, and figuring out how to help. This way, I always got the most out of the time we had face to face. Neil distills the i ...
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Country potluck
Stars dish on their favorite Thanksgiving foods -- and we'd like a taste of your thoughts, too.
Stars dish on their favorite Thanksgiving foods -- and we'd like a taste of your thoughts, too.
Now that baby Pearl is talking, laughing and signing her dad's music, Jake Owen says he's starting to feel like he's getting the hang of all this.
Carrie Underwood says she's giving up being a vegan until her baby is born. After that, though, she's back on the straight and narrow.
Looks like these turkeys have seen the writing on the wall -- so they've decided to fight back.
We all have a lot to be grateful for this year, but we in the Morning Bullpen feel extra blessed. Thank you for listening.
Garth Brooks loves his mashed potatoes and gravy. The 'Man Against Machine' hitmaker says that when it comes to Thanksgiving dinner, pass 'em over, followed by turkey and stuffing ... but not yams!
Country's biggest stars may ride on tour buses and take part in glitzy tours, but when Thanksgiving comes around, they're more than satisfied with home cooking. Alan Jackson, Dierks Bentley and Hillary Scott of Lady Antebellum reveal their favorite foods to eat when sitting around the Turkey Day table.
Brantley Gilbert just pulled his latest album from Spotify, but he doesn't want to talk about it.
This Thanksgiving weekend, we get a somewhat unexpected sequel to a somewhat unexpected 2011 comedy hit, along with a spin-off from a major animated blockbuster.
Randy Travis was among the guests at Joe Nichols' concert at Billy Bob's Texas in Fort Worth on Saturday (Nov. 22). The country legend visited with Nichols, and even treated the 'Yeah' singer's family to a barbecue dinner.
The dinosaurs in 'Jurassic Park' may have been made from mosquito DNA, but these character mock ups are all beetle. One Etsy user apparently has an odd love of both the iconic dinosaur movie and coleopterology.
What a great day for dinosaurs who refuse to die! First a new 'Jurassic Park' trailer and now, via Variety, a report on the sequel to 'Blade Runner,' which has been rumored for most of the 30 years, since Ridley Scott released the original film back in 1982. Scott says that, yes, you can expect Harrison Ford to return as detective Rick Deckard, but no, you shouldn't expect Scott to direct the film; instead he'll just be serving as a producer


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This was not worth the money I paid for it. It was very pretty and looked exactly like the ring on the site, but the setting is lose and it is so light. It feels pretty cheap. I would expect that if I had paid about 20 or less for it, but not what the original price was for. I am returning it.
My girlfriend and I both picked this one as my travel ring since it gorgeous. Very large as I wanted it to be. I wear large jewelry and this fit the bill! It is very sparkly and I am very pleased I have it to wear when I travel.
I liked the ring but didn't expect the stones to be so big. I didn't see any where what the carats was on the stones. That would be helpful in the future to make my selection. I usually wear a size 7 1/2 but you don't offer that size so when I order a size 8 I have to wear it on my middle finger. Not liking that much.
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EX2 is a new energy drink marketed under the Rawlings brand name. Best known for its line of baseball sporting gear, Rawlings should appeal to boys and young men familiar with the brand. EX2 has a good citrus/passion-fruit flavor that is very sweet (32 grams of carbs per serving). The drink contains ginseng and guarana, as well as creatine which is made soluble within the drink through a patented process. We enjoyed this drink although we wonder whether the Rawlings brand name will translate into a successful beverage. Still, we like the look and, more importantly, the taste of this product, so we think that it has a good shot.
Average User Rating
(10 votes)
Functional: Energy Drink: Regular
Serving Size 1 container; calories 132; total carb 32; sugars 27 g; sodium 90 mg; potassium 47 mg; vitamin C 33%; riboflavin 100%; niacin 56%; vitamin B6 100%; vitamin B12 150%; ginseng, guarana, taurine 1000 mg; creatine monohydrate .75 g
water, corn syrup (high glucose syrup), sugar, malic acid, citric acid, natural and artificial flavor, sodium benzoate and potassium sorbate (preservatives), sucralose, arabic gum, FD&C Yellow#6, Red #40, and Yellow#5, and Glycerol Abietate
Buy Rawlings EX2 Online


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Floral Print Maxi
Item# AS-025830_8DSBF0283053F
$49.50 $4.98 $3.24
This vibrant floral dress is the epitome of spring/summer. The bold and beautifully illustrated print makes for an exceptional feminine look. Plus size dress features a double v-neckline that leads to short sleeves, a cinched elasticized waist, and is finished with an allover floral pattern print.
- Machine wash cold
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- 57 inches from shoulder
- 95% polyester, 5% spandex
Please Select a Size and Color
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Can you ping it from the network?
We had this FOG server (0.29 I know its old but it works - well it used to) running on a desk in our tech office for a couple of months.
Had to move it to the server room while building work was carried out. Found out today it is not working. All machines stuck at the tftp boot part
Moved it back to tech office - works ok
Turned it off and put it under the tech office desk and now its not working again. Yes we have switched it on!
Changed DHCP to point to the spare Fog server, that works fine but we cant use that one as there is not enough space and our images are not on there.
any ideas?
Last edited by JJonas; 4th September 2012 at 04:45 PM.
Can you ping it from the network?
Yes I can ping it from the network, and the pings stop when I unplug it. So I know there is not another device sitting on its IP address.
Do we have any tftp experts as I think that might be the problem?
Have you tried reinstalling fog over the top of the existing installation?
not yet, what will that do to my existing list of hosts and images?
I did consider it but was worried they might get wiped out
I have done it numerous times on 0.32 but try it on your spare first as i don't know whether 0.29 installation will recreate the mysql tables. on .32 it just overwrites the settings and keeps all the information intact.
anyway to backup the installation first?
Would clonezilla work?
I would imagine so.
But seems as you can't use your spare one because your images aren't on there couldn't you test with that?
Would save you some time as the spare is unusable anyway.
I'm 100% sure it works in my environment but as i said earlier .29 may be different.
Thanks Kris
After I finally stopped trying to avoid a reinstallation, that was what fixed it. So you can reinstall on 0.29 without wiping out your previous installation.
Have some Rep and lots of thanks
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Dr. Cindy M. Nazario-Matos, MD
Pediatrics, Ferguson Medical Group
- 1012 N Main St
Sikeston, MO 63801
- 2 Office Locations
- (573) 471-0330
Dr. Cindy M. Nazario-Matos has been practicing medicine for 18 years. Dr. Nazario-Matos graduated from the University of Puerto Rico School of Medicine in 1996. She practices medicine in Sikeston, MO and 1 other location and specializes in Pediatrics. Dr. Nazario-Matos is affiliated with Southeast Health Center Of Stoddard County and Missouri Delta Medical Center. She speaks English and Spanish.
Gender: Female
Years in Practice: 18 Years
Languages Spoken: English, Spanish
Medical School: University of Puerto Rico School of Medicine
Graduation Date: 1996
Hospital Affiliations: Southeast Health Center Of Stoddard County, Missouri Delta Medical Center
Specialties: Pediatrics
*This physician has multiple office locations. See Appointments for details.


text:
DMV to Internet-less New Yorkers: Get in Line
By Jared Chausow
By Katie Toth
By Elizabeth Flock
City Hid Facts From Feds About Rikers
By Albert Samaha
Flood Wall Street Gets Pepper Sprayed and Arrested
By Anna Merlan
By Jon Campbell
Report Sheds Light on Anti-Muslim Bias
By Jon Campbell
Rikers Island Lawsuits Over Diabetic Care
By Albert Samaha
Attacks on abortion clinics are treated as isolated incidents, covered briefly in the media, and then forgotten. But as this map shows, these individual acts of violence together add up to far more: a campaign of terrorism that has touched nearly every corner of America.
Antiabortion extremists have killed seven people, attempted to murder 15 others, and caused millions in damages. They have also triggered the resignations of countless workers, forcing clinics to close and dramatically reducing womens access to safe abortion.
This map shows officially confirmed incidents of extreme violence from 1993when the first doctor was killedto the present, as reported to the National Abortion Federation. It includes arsons, bombings, and butyric acid attacks, as well as shootings and a stabbing.
So far, these attacks have claimed the lives of seven clinic workers:
This map does not include attempted bombings and arsons, nor the shootings of abortion doctors that police may have wrongly classified as robberies. Nor does this map include incidents of low-level violencelike stalking, picketing, and death threatsthat have been an endless source of trauma for people on the front lines.
side 1 || side 2
Click on each side of the map to view detail.
One of four articles in our The Terrorist Campaign Against Abortion feature.


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See also:Africa, was
See also:born in 1788 at
See also:Annan,
See also:Dumfriesshire, where his
See also:father was a surgeon . He gained some knowledge of
See also:practical
See also:mathematics and navigation, and at thirteen was apprenticed on
See also:board a vessel which traded between Liverpool and
See also:North
See also:America . After having made several voyages across the
See also:Atlantic he was impressed for the
See also:navy, in which he soon
See also:rose to the
See also:rank of
See also:midshipman . During the
See also:Napoleonic
See also:wars he saw a
See also:good
See also:deal of active service, and at the storming of
See also:Port
See also:Louis,
See also:Mauritius, in
See also:November 181o, he was first in the
See also:breach and hauled down the French
See also:flag . In 1814 he went to
See also:Canada, was promoted to the rank of
See also:lieutenant, and to the command of a
See also:schooner on the
See also:Canadian lakes . In 1817, when the flotilla on the lakes was dismantled, he returned home on
See also:half-pay . In 182o
See also:Clapperton removed to
See also:Edinburgh, where he made the acquaintance of Walter Oudney, M.D., who aroused in him an
See also:interest in
See also:African travel . Lieut . G . F . Lyon, R.N., having returned from an unsuccessful attempt to reach
See also:Bornu from
See also:Tripoli, the
See also:British
See also:government determined on a second expedition to that
See also:country . Dr Oudney was appointed by
See also:Lord
See also:Bathurst, then colonial secretary, to proceed to Bornu as
See also:consul with the
See also:object of promoting
See also:trade, and Clapperton and Major
See also:Dixon Denham (q.v.) were added to the party .
From Tripoli,early in 1822, they set out southward to Murzuk, and from this point Clapperton and Oudney visited the
See also:Ghat
See also:oasis .
See also:Kuka, the capital of Bornu, was reached in
See also:February 1823, and Lake
See also:Chad seen for the first
See also:time by Europeans . At Bornu the travellers were well received by the sultan; and after remaining in the country till the 14th of
See also:December they again set out for the purpose of exploring the course of the
See also:Niger . At Murmur, on the road to
See also:Kano, Oudney died (
See also:January 1824) . Clapperton continued his
See also:journey alone through Kano to
See also:Sokoto, the capital of the
See also:Fula
See also:empire, where by
See also:order of Sultan
See also:Bello he was obliged to stop, though the Niger wa.s only five days' journey to the west . Worn out with his travel he returned by way of
See also:Zaria and
See also:Katsena to Kuka, where he again met Denham . The two travellers then set out, for Tripoli, reached on the 26th of January 1825 . An account of the travels was published in 1826 under the title of Narrative of Travels and Discoveries in
See also:Northern and Central Africa in the years 1822-1824 . Immediately after his return Clapperton was raised to the rank of
See also:commander, and sent out with another expedition to Africa, the sultan Bello of Sokoto having professed his eagerness to open up trade with the west
See also:coast . Clapperton landed at Badagry in the Bight of
See also:Benin, and started overland for the Niger on the 7th of December 1825, having with him his servant
See also:Richard
See also:Lander (q.v.), Captain
See also:Pearce, R.N., and Dr Morrison, navy surgeon and naturalist . Before the
See also:month was out Pearce and Morrison were dead of fever . Clapperton continued his journey, and, passing through the Yoruba country, in January 1826 he crossed the Niger at
See also:Bussa, the spot where Mungo
See also:Park had died twenty years before .
See also:July he arrived at Kano . Thence he went to Sokoto, intending afterwards to go to Bornu . The sultan, however, detained him, and being seized with dysentery he died near Sokoto on the 13th of
See also:April 1827 . Clapperton was the first
See also:European to make known from
See also:personal observation the semi-civilized
See also:Hausa countries, which he visited soon after the
See also:establishment of the Sokoto empire by the Fula . In 1829 appeared the Journal of a Second Expedition into the Interior of Africa, &c., by the
See also:late Commander Clapperton, to which was prefaced a
See also:biographical
See also:sketch of the explorer by his
See also:uncle, Lieut.-colonel S . Clapperton . Lander, who had brought back the journal of his
See also:master, also published Records of Captain Clapperton's Last Expedition to Africa . . . with the subsequent Adventures of the Author (2 vols.,
See also:London, 1830) .
CLAQUE (Fr. claquer, to clap the hands)
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We all wondered how Police Commissioner Ray Kelly would spend his time after January 1, when new mayor Bill de Blasio is sworn in, and Kelly's replacement Bill Bratton takes his spot. Golfing with Michael Bloomberg in Bermuda? Freelance stop-and-frisking? In a New York magazine profile published ear ... More >>
Operation Streamline Costs Millions, Tramples the Constitution, Treats Migrants Like Cattle, and Doesn't Work
18 obsessive, cantankerous, and unstoppable Gotham blogs worth going ape over
A Child-Porn Case That Threatens Us All
Dozens of Lawyers Appeared at the Arraignment
Advocates Doubt Wen Ho Lee Release Will Change Anti-Asian Politics
University Heights
How the Worst Law in the State's History Came To Be


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Savory Winter Soup
Even my father, who doesn't particularly like soup, enjoys my full-flavored version of traditional vegetable soup. He asked me to share the recipe with Mom, and I gladly obliged! - Dana Simmons, Lancaster, Ohio
14 Servings
Prep: 20 min. Cook: 8 hours
2 pounds
ground turkey or beef
Enhance the Flavor
With Johnsonville Italian Sausage.
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3 medium onions, chopped
1 garlic clove, minced
3 cans (10-1/2 ounces
) condensed beef broth, undiluted
1 can (28 ounces) diced tomatoes, undrained
3 cups water
1 cup
diced carrots and celery
1 cup fresh
frozen cut green beans
1 cup cubed peeled potatoes
2 tablespoons minced fresh parsley
2 teaspoons dried parsley flakes
1 teaspoon dried basil
1/2 teaspoon dried thyme
Salt and pepper to taste
In a large skillet, cook beef and onions over medium heat until the
meat is no longer pink. Add garlic; cook 1 minute longer. Drain.
Transfer to a 5-qt. slow cooker. Stir in the remaining ingredients.
Cover and cook on high for 8 hours or until heated through. Yield:
14 servings (3-1/2 quarts).
© Taste of Home 2014
2 of 2
Savory Winter Soup
To save chopping time, use frozen sliced carrots and cubed hash brown potatoes in Savory Winter Soup.
© Taste of Home 2014


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People Marching (and Standing) for Something
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A Ferry Nice World, Long Ago
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Death of the Last True Hero: Goodbye, Pete Seeger
His aura was exceptional. His voice had failed years ago, but that aura remained. Few can render an old-time folk song these days without attracting snickers. Pete never needed to worry–he practically perfected that musical genre in his lifetime. If … Continue reading
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It's Earth Day–April 22, 2013. The planet and its creatures continue to fascinate. The past half year began by wowing millions with the wind, waves, and fires of Superstorm Sandy. It's continuing to impress on us the extremes of cruelty that can be caused by humans wielding not only assault … Continue reading
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Posted in Business and Economics, Creatures of the Planet (Non-Human), New York City Government, Planet Earth, Water and waterways Tagged community, developers, Jr., local news, New York City Councilman Eric Ulrich, New York State Assemblyman Phil Goldfeder, New York State Senator Joseph P. Addabbo, Rockaway, schools 2 Comments
Thanks to Aunt Abby Ryder
The summer media campaign for my book, Images of America: Rockaway Beach, closes on a high note, thanks to Aunt Abby's historic bayfront clam chowder house. Today's New York Times Dining Section features an article and photo spread, "Where Pirates Can Dock … Continue reading


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November 2014
November 1, 2014
Concealed Carry Course
Time: 8:00am -5:00pm
Location: LPSO Range Facility
LPSO is offering a Concealed Handgun Training Course at the Lafourche Parish Sheriff's Of ...
November 10, 2014
Academy Graduation
Time: 7:00pm
Location: Knights of Columbus Hall - St. Patrick Highway, Thibodaux
Lafourche Regional P.O.S.T. Training Academy Graduation For more information on our Training Academ ...
November 22, 2014
Hunter Education Course
Time: 8:00am
Location: see description
November 22: 8am-5pm at Lafourche Parish Mathews Government Complex (4876 Highway 1, Race ...
Copyright 2014, Lafourche Parish Sheriff's Office
Lafourche Parish Sheriff's Office, 200 Canal Boulevard, P.O. Box 5608, Thibodaux LA 70302, 985.446.2255


text: Murder in the bucolic town of Independence, Missouri, is not everyday news. Especially when it occurs in the temple owned by the Reorganized Mormons. Once again, philosophy instructor and amateur sleuth Toom Taggart becomes embroiled in a homicide investigation. In this second novel, Edwards re-acquaints readers with the likeable, curmudgeonly professor who shocks fellow Latter Day Saints by drinking coffee. By coincidence, Taggart is called to oversee the Church's education department, just as the author himself was some years ago. This gives Taggart even more reason to explore the inner offices at Church headquarters—places and hushed conversations are not meant for outsiders—all of which the author describes with a wink and a nod.