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In my last post—also a shameless plug for my recent article, "Boilerplate Shock"—I argued that boilerplate terms governing securities could serve as a trigger that transforms an isolated credit event into the risk of a broader systemic failure. I'll now briefly explain why I see this danger—which I call "boilerplate shock"—as a general problem in securities regulation, not just some quirky feature of Eurozone sovereign debt (the focus of the paper and post). Any market where securities are governed by uniform boilerplate terms is vulnerable to boilerplate shock.
The nature of this phenomenon—systemic risk—is of course familiar, but its source in contract language is a little unintuitive. How could private contracts unravel an entire securities market or the world economy?
Coordination around uniform standards.
In the back of our mind most of us probably still conceive of contracting as an activity that occurs among two, or perhaps a few, individuals or firms. But when standard terms are used by virtually all actors within a given market, it's worth considering the collective impact of those terms as a distinct phenomenon.
Coordination's benefits are well known. Consider uniform traffic signals. But coordination can also compound the effects of bad individual decisions.
As Charles Whitehead has argued, widespread "destructive coordination" among banks during the precrisis days helped generate systemic risks. When the credit markets froze, for example, firms using the same risk management formulas reacted in the same way at the same time. This helped transform isolated events into systemic ones—e.g., Lehman, the canonical example of a failure that triggered a de facto coordinated panic.
A similar risk, I argue, is present where participants in a securities market rely on the same standardized contract terms. Whether they were intended to or not, these terms will often control what happens in the event of certain legal emergencies, like a country departing the euro or Lehman declaring bankruptcy.
For example, if an effort by Greece to pay its bonds in "new drachmas" is rejected because of Boilerplate Contract Terms A and B, the market will surely be concerned that Terms A and B also govern the bonds of similarly situated borrowers, like Spain, Italy, etc. You'll see that the borrowing premium the "peripheral" euro countries (the uppermost five lines: Ireland, Italy, Greece (biggest spike), Portugal, Spain) paid versus richer euro countries (Germany, France, the Netherlands, the three lowest lines) zoomed higher as worry over a Greece exit gripped markets in late 2011/early 2012, and again (to a lesser extent) because of Cyprus exit talk in early 2013:
Bloomberg. Click to enlarge.
Moreover, this panic occurred against a backdrop of unduly rosy assumptions (namely, that a departing euro country could convert its bonds into a new currency and thereby avoid default, a likely contagion trigger). I argue that the uniformity of boilerplate across these bonds would intensify these problems significantly since it's likely to result in a declaration of default.
To my mind, this demonstrates that boilerplate securities contracts, in the aggregate, can be systemically significant. "Boilerplate Shock" introduces this concept and offers a modest proposal to mitigate its dangers in the Eurozone.
Beyond the euro, what about the risks of boilerplate shock in general?
Boilerplate shock is probably an inherent and permanent risk in any securities market.
Securities contracts are quintessential candidates for boilerplate. They are used by sophisticated parties for repeat or similar transactions and are drafted quickly—sometimes in three and a half minutes. The (correct) assumption is that they are more efficient for the parties that use them.
I'd like to begin thinking about how contracts can be drafted with a view to systemic risk mitigation, or at least to avoid exacerbating existing risks. But I think this is a hard problem that lacks an off-the-shelf solution:
- The nature of the risk is that it is a byproduct, not the result of intentional choices about risk allocation. This is the reason for the information-forcing default rule I propose in the Eurozone.
- The risk is also an externality: it is severe because of its collective impact. The parties do not bear the primary risk that uniform contracts will result in a meltdown, and in the unlikely event a crash happens (1) no individual party will be to blame and (2) at least one party to the initial transaction (the initial purchaser of a bond, for example) will probably no longer hold the asset, because most systemically significant securities are actively traded on the secondary market.
But banning or discouraging boilerplate is not the answer:
- The risk that a bunch of assets governed by the same terms will plummet in value is not only an externality. Risk allocation among parties might improve if scrutiny of existing securities boilerplate improves. The terms can evolve.
- A requirement to craft unique, artisanal terms—disclosures, subordination provisions ("flip clauses"), choice of governing law—for each individual securities transaction would be criminally inefficient.
- A requirement to craft unique contract terms might even be unjustified on risk-management terms alone, because it would increase drafting errors.
It's tricky to mitigate the risks of securities boilerplate.
Some options for places to start:
- Validation by third parties: perhaps issuers could use risk-rated contract templates. For example, see credit ratings…but see credit ratings.
- Culture: inculcate systemic risk mitigation as a professional norm among private sector lawyers? In principle, this could work. The number of lawyers who draft these contracts is pretty small. In practice, one could envision many complications.
- Insurance: encourage the development of derivatives to account for the possibility of boilerplate shock? Like some of the other solutions, this one presumes some agreement on what terms create the risk of boilerplate shock. It could also encourage new forms of moral hazard.
- Mandatory regulation: some public entity could be tasked with the mission of proactively identifying and combating the risk of boilerplate shock in contract practices. Arguably a natural choice given that the risk is an externality. Nevertheless, I'm a little skeptical. First of all, who would do it? A domestic regulator, like the SEC or CFTC, that might be dodged on jurisdictional grounds? An international institution, which is arguably more subject to capture? More generally, regulation seems like a heavy-handed first choice.
In sum, when standardized and aggregated, choices that determine legal risks—e.g., contract terms designating governing law, payment priority—can create the same hazards as choices about business risks. This suggests that contract terms should be taken seriously as possible sources of systemic risk alongside more familiar sources, like leverage and credit quality.
Securities contracts as a source of systemic risk—what do you think?
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© Disney, "Duck Tales"
I expressed concern in my last post that uniform contract terms could destabilize securities markets in unexpected ways. In a recent paper, I dub this risk "Boilerplate Shock." The paper uses boilerplate terms in Eurozone sovereign bonds as a case study, but I argue that any market in which a lot of securities are governed by uniform contract terms is vulnerable to boilerplate shock. In this post, I will focus on the Eurozone and my proposed solution to the risk of boilerplate shock there.
One major problem is that no one really knows how to deal with sovereign debt obligations denominated in a currency that still exists but is no longer used by the debtor. A partial breakup of the European Monetary Union would trigger some question marks in commercial law and private international law (among other things).
In the Eurozone sovereign lending market, bond contracts typically contain standardized language specifying:
(a) choice of governing law (often foreign), and
(b) currency of payment (euros).
The combined effect of these clauses, I argue, is to render any country that departs the euro more likely to default on its debt. Whatever the impact of the departure itself, a forced default would make things much worse for Europe and the world economy.
Leading scholars have concluded or strongly suggested that a sovereign that changes currencies can redenominate (convert) its bonds to its new currency even where the contract is governed by foreign law (e.g., Philip Wood (p. 177), Michael Gruson (p. 456), Arthur Nussbaum (pp. 353-59), Robert Hockett (passim)). As a descriptive matter, I believe this to be a mistaken interpretation of New York (and probably English) private international law and commercial law (see "Boilerplate Shock" pp. 47-67). But normatively, I agree: a sovereign should be able to redenominate its bonds under certain circumstances. Among other things, the alternative would make currency union breakups far more dangerous than they already are.
In brief:
- The prevailing consensus underestimates the risk that a departing Eurozone member's attempt to redenominate its sovereign bonds into a new currency will be ruled a default.
- Since the bonds of other struggling euro countries are largely governed by the same boilerplate terms ((a) and (b) above), this misapprehension has the potential to be particularly damaging. In addition to surprising the market (which appears to incorporate this consensus), it is likely to spread beyond the immediate debtor to the bonds of similarly situated countries that have issued under the same terms.
- Same for CDSs (which are likewise often governed by foreign law, usually New York).
- Thus, given the widespread use of terms (a) and (b), a ruling that a departing country cannot pay its euro-denominated contracts in a new currency could cause the market to demand unsustainable premiums from other weak debtors.
- This could cause Eurozone countries to lose market access. Greece is not TBTF in any sense, but some of its neighbors are—and are also too big for the EU (including the ECB) and IMF to bail out. Italy (the world's 9th largest economy) and Spain (13th) come to mind.
Thus, if my commercial law/private international law analysis is right, these boilerplate contracts could end up playing quite a big role in the event of any euro breakup.
To mitigate this risk of boilerplate shock, I suggest a new rule of contract interpretation. The proposal is detailed at pp. 67-71 of the article. I suggest commercially significant jurisdictions adopt it by statute. Here is a quick summary.
Any sovereign that:
- Belongs to an international monetary union, and
- Issues bonds in the currency of that monetary union subsequent to the adoption of this rule, and
- Leaves the monetary union and introduces its own currency,
shall retain the right to redenominate its bond obligations into its new currency, UNLESS the sovereign has affirmatively waived the right to redenominate its bonds.
You'll notice this is a default rule—merely a presumption of the right to redenominate—not a mandatory rule. It is also prospective-only: it does not apply to existing issuances. It also does not protect sovereigns that issue in foreign currency (e.g., Argentina), only those that are monetary union members and issue in the common currency (e.g., France).
The reason for these limitations is to minimize unintended consequences and near-term disruption to the market, but also to embody the relatively modest objectives of the rule. It is an information-forcing default rule that is intended to facilitate better risk management by parties. It is not a "save the world" rule.
The challenge, as I'll discuss in my next post on the paper, is not that redenomination would be ruled impermissible when it ought to be available (otherwise, that might suggest a mandatory "pro-redenomination" rule). It is that the likely effect of these boilerplate terms—to prohibit redenomination—was almost certainly not bargained for and is largely unknown to parties. This market failure has, in turn, created latent risks to the broader financial system and the existing legal tools are poorly suited to address them.
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Following Gordon's post yeseterday on the Penn State "nondeath penalty," I started thinking more about whether NCAA sanctions against Penn State are a good idea.
Now, I don't mean whether the sanctions are too harsh or will have collateral effects on innocent Penn State programs, students and alumni. Of course sanctions will have collateral effects, just as disclosure of the events at the heart of the sanctions did. The decline in the reputation of Penn State hurts employees, students and alumni. The financial penalty as well as lost revenue will result in a different academic budget that will affect the same groups. These effects are not super great reasons not to punish an organization. Many folks in our field think a lot about the merits of organizational sanctions, and the Penn State scenario is no different from the SEC levying fines against an investment bank or any other large firm that employees folks and has shareholders.
Here is why I'm concerned that NCAA sanctions aren't a great idea. What Sandusky did and his colleagues covered up was categorically different and categorically worse than having a slush fund for players (SMU); letting agents pay a player (USC); letting students trade autographed jerseys for cash (Ohio State); or letting boosters lavish players with cash, prostitutes and entertainment (Miami). All of those things are against the spirit of amateur sports, but they aren't things that require the devil to grow a new mouth for the accuseds to rot in. Giving someone money isn't per se a horrible thing; giving someone money in the context of collegiate athletics is. The heinous acts that occurred in and around the Penn State locker room are heinous in any context.
Let's picture this. SMU was banned from playing for 1987 and hosting home games for 1988 and lost 55 scholarships over 4 years for "X." Penn State was not banned from playing, was fined $60 million, banned from bowl games for 4 years and lost 40 scholarships over 4 years for "Y." Does that mean that the NCAA thinks that "X" is worse than "Y"? USC lost 30 scholarships over 3 years and was banned from bowl games for 2 years for "Z." Does the NCAA think that "Z" is 3/4 or 2/3 as bad as "Y"? Miami is still awaiting its sanction for allegations made in 2011 of "W." What if Miami gets a harsher penalty than Penn State? It has to get a harsher penalty than USC, and there's not a lot of real estate between USC's penalty and Penn State's penalty.
Do we really want to put the bad acts of the Penn State officers on the same spectrum as recruiting violations and payouts to players?
I don't mourn the fallout at Penn State due to the NCAA sanctions, but I am concerned with the symbolism.
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The regulation-skeptical judges Henderson, Randolph, and Brown today claimed the first victim of the D.C. Circuit's new year, in a super-unthrilling case that at least included a reasonable standing ruling.
Poor FERC. That agency loses a lot in the court of appeals, and today in Southern California Edison v. FERC, it lost a case worth less than 20,000 dollars. Why'd SCE bother suing for that kind of money? The utility was miffed that FERC hadn't applied California law, which was the law of a service contract with the City of Corona, to its failure to invoice Corona for some higher than expected interconnection charges within a year. In other words, SCE wanted to be reimbursed for the late-filed charges, and thought its delay in filing the charges was immaterial under California law. FERC applied federal law in rejecting the reimbursement request, because, it noted, SCE eventually invoiced Corona for the charges on its FERC-filed rates. And FERC-filed rates are federal documents. Because "accepting FERC's choice of law argument would permit FERC to disregard a choice of law provision in any FERC-approved contract," the court ruled that FERC had to evaluate SCE's reimbursement claim under California law.
Thrillsville, right? No one ever said government contracting rocked at all times. In my view, the opinion is notable mostly for the nuts standing argument that FERC made. FERC argued that because SCE had delayed invoicing Corona beyond the contractual term, it didn't have standing to sue; SCE's injury was not traceable to FERC's interpretation of the contract, in other words, but to SCE's delay in invoicing. To me, that sounds like an effort to convert a merits defense (SCE billed too late to be paid) into a jurisdictional question. It's the sort of argument that, if credited, would keep a variety of basic breach of contract claims - the bread and butter of the first year of law school - out of court. And thankfully, the court rejected the claim, noting that "in reviewing the standing question, the court must be careful not to decide the questions on the merits."
Crazy standing argument, right? But don't blame FERC. Every government lawyer is contractually obligated to challenge the standing of the plaintiff in every DC Circuit case. And they're only obligated to do so because that court gets seduced by standing so frequently.
The opinion may be found here.
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The always insightful Simon Lester observes that the latest sin case that the WTO may take up (we've already told you about Antiguan internet gaming) is the incipient American ban on clove cigarettes. Indonesia, where such cigarettes are both a staple, and, apparently, an export, thinks that banning cloves but not methols would constitute trade discrimination against foreign exporters.
And, in a recent decision that the Fifth Circuit called, ahem, "high stakes," that court threw out the Secretary of the Interior's effort to save the Indian gaming regulatory scheme held to be unconstitutional in the Seminole Tribe case. The Indian Gaming Regulatory Act required states to negotiate casino deals with Indian tribes under the management of a judge which, the Supreme Court held, violated the states' 11th amendment immunity from suit, in Seminole Tribe. The secretary then replaced the judicially managed negotiation with a negotiation process managed by Interior. But the 5th Circuit just concluded that the Act did not authorize the agency to substitute itself for a court: "Congress plainly left little remedial authority for the Secretary to exercise. … The Secretary may not decide the state's good faith; may not require or name a mediator; and may not pull out of thin air the compact provisions that he is empowered to enforce. To infer from this limited authority that the Secretary was implicitly delegated the ability to promulgate a wholesale substitute for the judicial process amounts to logical alchemy." I generally don't bother predicting cert grants, but I could see the government trying to obtain one here, and if it did, law clerks might find a follow up to Seminole Tribe – and an effort by the government to get around the impact of that decision without going to Congress for more legislative authority – to be quite exciting.
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New Yorkers love their greenmarket produce. And rightly so this time of year, though the commitment to local gardens makes a March full of sauteed fiddlehead fern salads really dreary. Maybe that's why Hunts Point Market dealers often bribe USDA inspectors to show up particularly quickly when a shipment of actually fresh vegetables comes in, or, sometimes, to rate produce as worse than it really is, so that buyers can purchase low, and resell high.
In honor of tomato season, but unseasonably late in a schedule that usually features a summer off for the court, the D C Circuit recently barred a veteran Hunts Point outfit from participating in the USDA's Hunts Point inspection scheme. It agreed with the Department of Agriculture that one of the firm's vice presidents gave a USDA inspector fifty bucks every time he came for inspection, in exchange for which the inspector allegedly did what the firm wanted.
Fifty bucks ain't a lot of money. Which is why I note with slight sadness the passing of Kleiman & Hochberg, Inc, traduced by an employee with a too-close relationship with a regulator, and condemned to dealing, from this point forward, in uninspected fruits and vegetables. Could it possibly have been worth it to bribe the USDA on the penny ante level? The opinion may be found here.
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The NRDC is having a good month, what with the injunction against the use of sonar by the navy in southern California (it may be bad for whales, and the appropriate environmental impact statement was not prepared, the court concluded), and the enjoining of exploratory drilling by Shell in Alaska (a, shall we say, not yet explored temporary order pending a mid-August hearing). Impact litigation against big institutions still thrives on the west coast.
I'm extraordinarily late to the party, but it's worth noting. Career attorneys are resigning or publicly protesting the current Department of Justice leadership. The former actually has been happening for a while (and sometimes resignation is a hard-to-disaggregate mixture of annoyance and the temptations of early retirement). But the airing of grievances in newspapers is pretty novel. So, for that matter, is the willingness to cover it. One of the first of the recent wave to quit was the long serving head of the department's Office of Information and Privacy, who in this interview describes his supervisors as too young and too ineffective. Here, by the way, is the latest report on information disclosure by DOJ; it is relatively positive.
James Park's Duke Law Journal article has a vision of the choice for SEC regulators between rules and principles:
"Rulemaking reflects the mentality that securities regulation is a technical enterprise that should be left to experts who have created a comprehensive, efficient, administrative scheme. Principles-based enforcement actions reflect the demand that regulators punish conduct violating principles reflecting public values. For the most part, the regulated prefer a predictable regulatory regime, which rulemaking provides, while the public prefers decisive responses, which can be provided by principles-based enforcement actions."
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Effective December 1, certain new amendments to the Federal Rules of Civil Procedure and Appellate Procedure will bow to the realities of the electronic age. Amendments to the FRCP address electronic discovery. Rule 32.1 of the FRAP will now allow attorneys in federal courts to cite to unpublished opinions as of December 1. However, as Howard Bashman points out in this Law.com article, attorneys may only cite to unpublished opinions from cases decided January 1, 2007 or later. Therefore, the unpublished opinions that were "unpublished" before January 1 will be relegated to the Island of Misfit Opinions for perpetuity. For more on the history of 32.1, see this old post.
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In case you've missed it, new Conspirator Ilya Somin and (old Conspirator) Eugene Volokh have been having some fun debating whether anyone can articulate a valid reason for prohibiting certain activities in places open to the public (like parks, streets, etc.), such as nudity, sexual activity, urination, and smoking. And, "it's yucky" isn't a valid reason. Although my sensibilities bristle at little at the thought, I have to admit that it is difficult to come up with a consistent, Constitutional theory for regulation beyond "I don't like it, and no thinking person would want that." Check it out, and please, please come up with something!
The debate reminded me of some posts earlier on the Conspiracy between David Bernstein and Orin Kerr about whether it was necessary/appropriate/relevant to explore whether certain law schools were open to libertarian-minded students. And why would schools not be open to libertarian views? I'm not defending it, but for some reason I think most of us get to law school so rigid in our thinking that it's hard to have an open mind when someone says in class "Yes, I think people should be able to contract themselves into slavery" (someone in my Contracts class) or "There is no reason to prohibit public sexual acts." So the speaker of those statements, which could provide for rich, intelligent exploration, becomes "the guy who said people should be able to contract themselves into slavery"). These statements seem to be arguing for a reality that has a big YUCK factor, and so others turn away. I'm glad to see that the blogosphere can revel in these discussions.
But please, someone come up with a very persuasive reason to prohibit public nudity. At least here in Wisconsin.
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Inside Higher Ed. has a story about economics graduate students at UVa who may face permanent expulsion for cheating. The cheating incident here was finding the answers to problems in their textbook that were available online and sharing them with one another. The students did not alert the professor that the answers were available online. At UVa, there is only one punishment for violating the Honor Code: permanent expulsion.
I would like to know the more facts before I described this homework incident as "cheating." What if the answers were in the back of the book, but the professor didn't know that they were. On the first assignment, students handed in their answers, which they copied from the back of the book, or perhaps checked against the answers in the back of the book. Is that cheating? Was the website with the answers hosted by the publisher, so it looked more like a study guide, or was it hosted by an anonymous student who had figured out the answers or maybe secured a copy of the teacher's manual? What did the syllabus say about study guides or Internet websites? I think that to one generation, finding answers on a website has the same degree of difficulty as breaking into a teacher's office desk drawer, and therefore requires the same criminal mental state. I would say that finding problem answers on the Internet has the same degree of difficulty as flipping to the back of the book.
I've had conversations like this with academics before, and usually the response is "they know it's cheating" or "everyone knows what cheating is." I'm not sure that's true anymore. When I was in junior high, using a calculator was cheating. It's not anymore. Having someone check your spelling before you turn in your senior theme used to be cheating, but using spellcheck is not.
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Food and financial services share one problem: that it is very difficult to set up any regulatory system which will allow consumers to understand and measure the risks they are undertaking in making decisions about what foods to eat and what financial products to buy. The Acting Comptroller of the Currency, Julie Williams, has been suggesting that, at least in the context of disclosures about credit card terms it would be a good idea if financial regulators could follow the same sort of approach to disclosure that the FDA uses to disclosure of information about food products:
Why should consumers today get more effective disclosure when they buy a bag of potato chips than when they make substantial financial commitments for financial products and services?
This idea is based in part on what the UK's Financial Services Authority has been saying about consumer disclosures recently:
the OCC also took the unusual step several months ago of submitting a comment letter to the Federal Reserve Board on its Advance Notice of Proposed Rulemaking related to credit card disclosures, discussing both the development of the FDA's "Nutrition Facts" label and the efforts of the Financial Services Authority (FSA) in the United Kingdom to develop revised disclosures for a variety of financial products.
Simplified disclosure of this sort works better for standardised products than for others. The Financial Services Authority publishes comparative tables which allow consumers to compare some of the basic terms on which some financial products are offered. But the FSA is also working on developing a system for risk ratings or risk warnings for managed investment products (referred to, for example in last week's paper on Wider Range Retail Investment Products ). I'm not convinced that this sort of simplified disclosure really works very well even for potato chips, but I do like the idea of thinking hard about improving disclosures for consumers of financial products.
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In doing some research on the differences between attorney malpractice and the much rarer broker malpractice, I've been looking at stockbroker websites. I have this impression that those Sunday afternoon commercials for stockbrokers are fairly overt, promising implicitly that these firms will guide you through with expert advice that you can trust. However, investors can't sue brokers for faulty advice or a faulty plan unless the plan is patently "unsuitable" based on the investor's proclaimed "suitability." But, if a broker says that Enron is going to go sky high, and then it doesn't, that's too bad. Brokers aren't guarantors; you knew the risks. However, if you went to see an estate planning attorney and asked for a plan to save on estate taxes, and the plan ended up being stupid, you might have a malpractice case. (Note: broker malpractice case law is hard to find, given the securities arbitration scheme that leaves no precedential paper trial. Aaaargh for me.)
Anyway, stockbroker websites are very interesting. Even the "individual investor" pages really focus on the fact that your investing strategy is your investing strategy. They will give you some tools and resources to create and implement that strategy, but it's yours. For example, Merrill Lynch tells you "[f]rom establishing objectives to setting strategy, implementing the solutions and then regularly reviewing progress, your Financial Advisor can help as you implement your own strategies for success." Charles Schwab tells you "[t]hat's why we give you greater control over everything from the investments you make to the accounts you open to the type of advice and service you desire." Is this investor empowerment or liability avoidance?
I cannot imagine a law firm touting on its website that the firm will help individual plaintiffs or estate planning clients "implement your own strategies"? (On the BakerBotts estate planning page, that firm declares, "A detailed working knowledge of the estate tax leads to the successful development, implementation, and defense of the most sophisticated and effective estate plans for our clients." You don't have to develop and implement the plan, we'll do it for you. What about a physician that advertised that his practice "gives you greater control over everything from the medications you take to the type of diagnosis and treatment you desire."
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Last week, Vic at A Taxing Blog made this statement (in comparing my thoughts on regulatory entrepreneurs to Larry Ribstein's):
My hunch is that Larry usually dislikes regulation, and Christine usually thinks more regulation is needed. Of course, both Larry and Christine would surely agree that it depends on the circumstances: regulation that protects inefficient government monopolies are bad; regulation that protects widows and orphans from the sharks at Enron is good.
This has caused me to do some soul-searching. I would not have described myself as a pro-regulation kind of person. On this blog, I often urge for additional regulation, but generally in areas that are already regulated. So, the additional regulation is needed to fix a flawed regulatory scheme. Does that make me pro-regulation? Anyway, to prove that I am not pro-regulation, I have found two great examples of regulations that should be abolished or nipped in the bud, as the case may be:
1. The Texas House of Representatives' regulation of the content of high school cheerleading; and
2. The prohibition by ordinance against my cat wandering free every once in awhile in the Village of Whitefish Bay, Wisconsin.
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Texas Bar Rules Referendum
Normally, Texas Disciplinary Rules of Professional Conduct, which apply to members of the Texas Bar, are considered and adopted by the Texas Supreme Court. End of story. However, the Texas Supreme Court has issued a referendum to the members of the Texas Bar on two proposed rule changes. The referendum ends on December 20. Being out of the Texas Bar loop for awhile, I can only imagine that these rules generated much controversy and comment to make the court withdraw their previous approval of these rules in lieu of the referendum.
The first rule change is to TDR 1.04, which previously allowed for a "forwarding fee" to be paid to a lawyer who merely referred a client to another lawyer without doing any substantive work for that client.
If the rule change passes, fees may only be divided if the client agrees to the division and the division must either reflect the true allocation of work among the two lawyers or must be accompanied by joint responsibility for the representation. In the court's order issuing the referendum, the court noted that currently Texas is the only jurisdiction whose rules allow for the payment of a pure referral fee.
The second rule change concerns lawyer advertising and has many facets. The two changes that I found interesting were (1) an attorney may not advertise a previously won dollar judgment unless the ad also discloses how much the client actually pocketed after attorney's fees and costs and (2) attorneys may not use actors in ads. I remember seeing an ad for the local plaintiff's attorney in Lubbock, Texas on the back of the phone book (one phone book -- residential, business, and yellow) with a picture of a lovely, blonde family of four only to see the same lovely family pose in an ad in Houston for a completely different service. Disillusionment is hard.
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Over the past week, I have been listening to The Kalahari Typing School for Men by Alexander McCall Smith on my way to and from work. This is not a fast-paced thriller, and it doesn't grab you like The Da Vinci Code. It is a leisurely stroll through Botswana, with an expert guide.
Last night, I laughed out loud at a scene in which the protagonist, Mma Precious Ramotswe (head of The No. 1 Ladies' Detective Agency), was attempting to procure the address of a pensioner's widow from a government bureau. The man behind the counter denied her request for the address, stating that it was against the rules. Mma Ramotswe sized up the situation and concluded that there was no sense in trying to convince the man that her request was reasonable, that the rules were not really intended to cover her situation, because stupid people cannot make nuanced distinctions of that sort. As a result, they become sticklers for the rules.
She eventually overcomes his objections by creating confusion about the rule. She pretends to cite the rules manual, chapter and verse, and asserts that the prohibition governs only the names of pensioners, not their addresses. Of course, she ultimately succeeds in confusing the hapless clerk and gets her address.
This reminded me of a parking ticket that I paid last week. The University of Wisconsin Traffic Control Office fined me $40 for parking behind the law school on the Saturday after Christmas (December 27) at 5:00 pm. That my official parking spot is a 10-minute walk from the law school, that I was transporting three large bags of books to my office, and that I timed the visit as I did to avoid the possibility of disruption were all lost on the enforcement officer. And the person who reviewed my appeal. A rule is a rule, after all.
It may seem a bit unseemly for a law professor to be complaining about law enforcement in this way, but we law professors can be an ornery bunch. Rules often seem like wonderful tools for social control, but rules rarely regulate behavior in exactly the way we want. That is, they almost inevitably penalize in cases where a penalty is not desirable (overinclusive), or they fail to reach cases that they should (underinclusive). Sometimes, the same rule is both overinclusive and underinclusive. As you might expect, rules tend to be modified repeatedly (see, for example, the tax code), but this is more a game of cat and mouse than progressive evolution.
We also rely to varying degrees on prosecutorial discretion (e.g., the parking officer could have elected to let my transgression pass, but she didn't). But this is problematic, too, because prosecutors will be biased (nothing personal ... we all are). In some instances (e.g., blacks and the death penalty), the results can be very troubling.
Regulation is a tough business, and Mma Ramotswe's skill in manipulating the system captures nicely the advantage of being smart. Still, as my parking ticket illustrates, the bureaucrats do sometimes have their revenge.
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Man rescued from child's swing
Posted: September 09, 2012|
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A fire crew were called to a park in Tiverton this morning after reports of somebody stuck in a swing.
The firefighters arrived at the playground in Wellbrook Street shortly after 11am and discovered the adult man wedged in the child's swing.
He was released uninjured using small tools.

subset: commoncrawl


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Pan-European Single Sky
- Single European Sky
- Regulatory support
- European ANS Performance Review
- Oversight Division (OVS)
- Safety Regulation Commission
- Environment
- The Single Sky and the environment
- Emissions Trading Scheme
- Adapting aviation to a changing climate
- Advanced Emission Model
- Environmental issues for aviation
- Operations
- Environment FAQ
- Events
- News
- Publications
- Services
- Pan-European planning, monitoring and reporting
- Remotely Piloted Aircraft System (RPAS)
- Functional Airspace Block (FABs)
- News
- Contact
Small emitters tool
According to European Commission Decision 2007/589/EC amended by Decision 2009/339/EC, a simplified method to determine their fuel consumption and carbon dioxide emissions for EU ETS monitoring and reporting purposes can be used.
The small emitters' tool is the EUROCONTROL fuel consumption and carbon dioxide (CO2) estimation tool that the European Commission has approved via the Commission Regulation (EU) No. 606/2010. The tool meets the requirements of the guidelines established by Decision 2007/589/EC in respect of the approach based on individual flights and aircraft type used (as per ICAO doc 8643), actual route length and statistically sound fuel consumption relationships.
The tool is based on a methodology designed to estimate the fuel burn for an entire flight (not for specific flight phases) considering the characteristics of the air traffic covered by the EU ETS. It is updated on a regular basis in order to improve when possible its accuracy.
The following tool versions can be used by :
- small emitters of their monitoring and reporting obligations pursuant to Article 14(3) of the Directive 2003/87/EC (the EU ETS Directive) and Part 4 of Annex XIV to Decision 2007/589/EC (the monitoring and reporting guidance);
- all aircraft operators pursuant to Part 5 of Annex XIV to Decision 2007/589/EC for the purposes of estimating the fuel consumption of particular flights covered by the EU ETS where the data necessary to monitor the emissions of carbon dioxide are missing as a result of circumstances beyond the control of the aircraft operator and which cannot be determined by an alternative method defined in the operator's monitoring plan.
Instant delivery registration
If you wish to receive each release of the tool by email, please fill in the form at the bottom of this page.
Manual downloads
Different versions of the tool are available for different years. To ensure consistency with processes of Verifiers and Administering States it is very important that Aircraft Operators, Small Emitters (for their simplified monitoring procedure and reporting) and other Operators (when reporting Data Gaps) use exclusively the relevant version for the each reporting period.
|For 2014 traffic emissions
|version 5.03 dated 2014.11.24, to be used for flights operated in 2014
|5 new aircraft types (inc. A359) have been added as these types have been flown in 2014 in the EEA region. The calibration of 10 existing aircraft types for business jets has been made. These 10 types are now modelled on the basis of actual fuel burn samples from real life operations that have collected from Aircraft Operators.
|For 2013 traffic emissions
|version 5.02 dated 2013.08.01, to be used for flights operated in 2013
|Changes are the addition of GLF6 and EC75 new aircraft types and the calibration of former existing types.using 2010 and 2011 actual fuel burn data collected from Aircraft Operators.
The small emitters tool and the ETS Support Facility
The small emitters' tool is a part of the ETS Support Facility (read more about it on the ETS Support Facility page). The ETS Support Facility is a comprehensive integrated solution with individual flights database records designed for ETS follow-up and compliance to support aircraft operators, verifiers, service companies acting on behalf of aircraft operators and ETS competent authorities.
Please contact Antonio Astorino for:
- receiving previous versions of the tool applicable to past years (2012, 2011, 2010)
- more information on the small emitters tool and its use;
- reporting issues with the use of the small emitter tool;
- should you wish to provide actual fuel burn data to support the further improvement of the small emitters tool accuracy.


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Yummy food for your brood
Jun 22, 2012
Cooking Tips for Absolute Beginners
Klutz in the kitchen? Never fear! Our savvy foodie mom breaks down the bare bones basics for nervous parents (and kids) with simple tips.
(page 4 of 7)
Sauteing Meat
Sauteing meat is fast and turns out moist, delicious entrees. Become a saute master by first picking the right pan – use a large, wide-rimmed, heavy bottomed one. Non-stick pans don't work as well for sauteing meat! Put the saute pan on a stovetop burner and turn the heat to medium-high. Let the pan warm up, testing the heat by putting your hand two inches from the surface: When it's heated, you should only be able to keep your hand there for a moment (do NOT touch the pan's surface). Add enough oil (olive, canola or vegetable) to lightly coat the bottom of the pan. Allow the oil to heat for about a minute before adding the meat.
Pat the meat dry before adding it to the pan – the less moisture on the outside, the better chance that you'll have a crisp crust on the outside. Place the meat in the heated oil, being careful not to crowd the pan, which steams the meat and makes it soggy. Cook the meat on the first side until you begin to see it browning around the edges; then, flip the meat to the other side and repeat the process. Be careful not to overcook or undercook the meat.
Tip: After removing the meat from the pan, add chicken broth or white wine to create a sauce. Use a metal spatula to remove any stuck-on bits from the pan's surface. These bits will give the sauce flavor and thickness.


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Dillard University will host several film screenings and lectures as part of the 2012 Social Change Film Festival.
SCFFI features five days of films, panels, workshops, and special events to inspire a global community focused on expanding the reach of conscious social change film and media. SCFFI chooses an annual theme that is explored throughout the festival's events in order to raise awareness about critical social, environmental, and political issues. The theme for the 2012 festival is Water: Challenges & Solutions.
Read more about the event here...
A home cooked meal at Thanksgiving is something every student should have. Dillard University President Dr. Walter Kimbrough and family offered his home to several Dillard students who weren't able to travel home to be with family.
"We knew there were students who needed a place for Thanksgiving dinner and we decided we would host a group," said Dr. Kimbrough.
Read more about this event on HBCU Buzz...
On November 23, 2012 Dillard University President Dr. Walter Kimbrough shared his thoughts on hazing during a special session of the Bayou Classic. Alumni, fans and guests filled the Empire Ballroom in the Hyatt Regency Hotel to hear a sometimes-heated discussion about pervasive hazing problems on their campuses, other HBCU campuses and elsewhere.
Read more about the event on The Advocate website...
Dillard University will host an important conference on youth and the state of mental health in New Orleans, on Tuesday, November 20, 2012.
A recent study conducted by the Institute of Women and Ethnic Studies on the mental health issues of New Orleans youth shows an alarming trend. Unless solutions are found to reverse these trends, the social fabric of the city will continue to deteriorate.
Read more about the conference on WWLTV.com...
Dillard's theater students are shown all aspects of show business...including the ugly parts. Former Dillard theater student Carlton Morton recently made waves and headlines after challening one of the "The Real Housewives of Atlanta" stars for her inappropriate behavior toward other women. The segment ended with the housewife shouting expletives and requesting that her body guard remove Morton from the set.
Read more about the rising star and his story here...
Want to know what's happening at Dillard University?
Sign up for our monthly newsletter!
About Dillard | Academics | Admissions | Current Students | Athletics Alumni | Administration | Contact Us | College.Gov
Dillard University does not discriminate in admissions, educational programs or employment on the basis of race, color, religion, sex, sexual orientation, national origin, age, disability, or veteran/Reserve/National Guard status and prohibits such discrimination by its students, faculty and staff. Students, faculty and staff are assured of participation in University programs and use of facilities without such discrimination.


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Starwood Montessori Reviews
23 reviews |
Write a review
Here's what some satisfied customers have to say Some of these reviews were submitted on other websites. We are not affiliated with or sponsored by these websites.
"What I also love about Starwood is they treat you like family." Review of Starwood Montessori
"...both of our boys love going to school." New Review of Starwood Montessori
- on Google+
Our family was first introduced to Starwood Montessori about 3 years ago when we started our oldest son in the toddler program. He is now 3 ½ years old and has transitioned into the Primary program with ease. Our youngest son has just started the toddler program and we could not be more pleased. From our initial meeting with the staff upon starting our oldest son, we had few simple request of the program. To educate, provide structure with learning and most importantly to allow our son to have fun and enjoy school. All of those request have easily been met by the staff and teachers at Starwood and both of our boys love going to school. Our eldest has grown in his learning abilities, independence, confidence and outgoing personality since starting at Starwood. The staff is exceptional. All of the teachers go out of their way to make our family and boys feel welcomed, loved and excited to be at school. The director has been very involved in our family needs and I feel she always has the best interest for both of our boys in mind. I have always felt that I could communicate with her and any of the staff with my concerns and know they would be addressed immediately. The observations/conferences really keep parents up to date on what your child is doing and how they are progressing. The school is a beautiful facility, clean and spacious equipped with a large gym, outdoor play area, greenhouse, computer lab and library. The car pool system in the mornings is great and run flawless, ensuring safety of the kids, quick drop off and a happy start to the day for the kids with the staff always greeting our boys with a smile! The communication among staff is what really makes this school stand out to us. We have had other experiences in the area with programs and Starwood by far exceeds them all. We are so fortunate to have found Starwood for our boys. Excellent School!
"The staff at Starwood is professional, child centered, personal, warm, and so helpful for both first time parents and their children."
- on Google+
Words can not express how wonderful Starwood Montessori has been for my daughter. My daughter started at Starwood when she was two years old. The staff asked me about her personality to be able to place her with a teacher that would best fit her personality. Her teacher has been one of the best teachers I have ever known. I can see how much she loves her students, cares about them, and is a perfect role model for them. I have enjoyed watching my child blossom over the past year with improving her social skills, independence, working in a classroom, and basic life lessons. She has learned so much educationally and talks about what she is learning which has been helpful to practice at home. The staff at Starwood is professional, child centered, personal, warm, and so helpful for both first time parents and their children. The staff is positive and they all know the children well and keep up with how they are in the classroom. The director of the school gets involved with the teachers and parents and takes care of doing what is best for each child (she knows them by name). As my first experience sending my daughter out into the community I could not have asked for a better place than Starwood Montessori. I have and will continue to talk to other parents about how wonderful this program, environment, and staff are for the most important children in their lives.
"Starwood is unparalled when compared to other montessori or traditional schools in Frisco."
- on Google+
My daughter previously attended a traditional preschool before going to Starwood - the two simply don't compare as far as education is concerned! She has blosommed by leaps and bounds in one year academically since attending Starwood. Her confidence in herself has increased dramatically; she has also learned discipline and focus. Starwood is unparalled when compared to other montessori or traditional schools in Frisco. Having a true visionary as owner/director and teachers with an average tenure of over 4-5 years is why Starwood is the epitome of excellence when it comes to education!
"I would rank Starwood among the best I have seen."
- on Google+
Our daughter has now been at Starwood for four years (first in Toddler, then Primary). It has been a great experience for her, primarily because of the quality of her amazing teachers. Both her Toddler and Primary teachers have been very caring and have helped her to grow in an amazing way. Our daughter works hard at school and loves to go every day. Teacher retention seems very good and administration is professional. I was a montessori kid 40+ years ago and my older children attended other good montessori schools in the area. I would rank Starwood among the best I have seen.
Do you like Starwood Montessori?
- 7:00 AM to 6:00 PM Monday
- 7:00 AM to 6:00 PM Tuesday
- 7:00 AM to 6:00 PM Wednesday
- 7:00 AM to 6:00 PM Thursday
- 7:00 AM to 6:00 PM Friday


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Wrap (filmmaking)
|This article needs additional citations for verification. (March 2010)
Wrap is a phrase used by the director in the early days of the film industry to signal the end of filming. Nowadays, the call is more commonly "That's a wrap!"
Filmmakers have used this phrase since the 1920s when the filming is done and it needs to go into post-production.
After principal photography is concluded, it is traditional to hold a wrap party, a party organized for the cast and crew of a film to celebrate the end of principal photography. This marks the end of the actors' collaboration (save from possible dubbing or pick-ups) on the film. They may be called in to promote the film when it is released.
The term "wrap" is sometimes said to be an acronym for "Wind, Reel and Print", although this is disputed, and most likely a backronym.[citation needed]
External links[edit]
- 'It's A Wrap', WILLIAM SAFIRE, Published: February 27, 2005, www.nytimes.com
- Hulu: 'House' Wrap Party
|This article related to film or motion picture terminology is a stub. You can help Wikipedia by expanding it.


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Panel Discussion and Networking Breakfast
October 18, 2011 - NYC
Social Media in the Workplace -
Practical Solutions for Companies
Tuesday, October 18, 2011
Cornell Club, 6 East 44th Street, New York, New York
Program time:
8:00 – 8:30 a.m. - networking and breakfast
8:30 – 10:00 a.m. - presentation and Q & A
New speaker added!
Scott H. Greenfield, ILR '79, Attorney and Legal Blogger. Scott, who maintains one of the most popular legal blogs (http://blog.simplejustice.us/), has served as a legal expert and analyst for television news shows from "60 Minutes" to "20/20", and ABC, NBC, CBS, BBC, Court TV and Fox. As a long-time legal blogger with one of the most viewed legal blogs, Scott has great insight into the practical realities of the upside – and downside – for business that use social media.
Program cost:
ILR AA members - $15
Non-member - $25
Program overview:
In a time of "Tweeting" about the significant and the mundane, impulsive Facebook posts, and employees divulging company information on LinkedIn, many businesses are trying to figure out how to deal with employee social media use. Some companies embrace employee social media use for sales, recruitment, and exposure to clients and customers. Other companies consider social media a drain on employee productivity and a source for potential liability.
The practical, human resources, and legal issues of social media in the workplace, including an international perspective, will be addressed by our panel:
- Scott H. Greenfield, Attorney and Legal Blogger (Simple Justice Blog)
- George Freeman, Deputy General Counsel, The New York Times
- Ellen Dember, Executive Director of Human Resources, KPMG LLP
- Keith Corkan, Solicitor, Laytons (London)
- Joseph Cartafalsa, Attorney, Putney, Twombly, Hall & Hirson LLP
Joe Cartafalsa at firstname.lastname@example.com with any questions
Underwritten by Putney, Twombly, Hall & Hirson LLP Laytons
Co-Sponsored by: ILR Alumni Association (NY, NJ and LI chapters)


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Vintage Valentine
January 24, 2013 by Jolene
Filed under Blog, Product Highlights
Today I'm sharing the first of a few projects I have made using Authentique's Lovely Collection. I particularly love using the 6×6 Paper Bundle because the pages are scaled perfectly for cards, tags, and smaller projects. A touch of chalk ink, a Bo Bunny flower, a corner rounder and a QuicKutz sentiment rub on made this a quick and easy Valentine. I just love the keys and postcard papers in this collection and can't wait to share my other projects with you! Stay tuned for future blog posts with more Lovely Collection inspiration. Happy scrapping!


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Studio located at
725 St. Mary's Rd
Winnipeg, Manitoba
Hours of Operation
Tuesdays by Appointment Only
Wednesday thru Friday 10 - 5:00pm Saturdays 10 - 4:00pm
location on google maps
Festivals Exhibiting Our Newest Designs 2014
Winnipeg Folk Festival July
Yorkton Sunflower (Sask.) Sept.
Carlyle Homespun Craft Show (Sask.) Sept.
The Scattered Seeds (Winnipeg) October
Our Best To You (Regina) Nov
Art Market (Calgary) Nov
Winnipeg Signatures at the Convention Centre Nov
Saskatoon Sundog (Sask.) Nov.
Edmonton Butterdome Dec


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Traveled from Reykjavik to Southhampton in late August departing ship on September 1. Airport transfer in Reykjavik was confusing. Guide left people stranded at airport and we had to return back to airport - there were only about 20 people on the ...continue
This Grand Voyage comprised three back to back cruises starting at Tower Bridge,London and ending inSouthampton ,The first and third cruises were full with the middle cruise 50 below capacity.
ACTIVITIES....The usual Trivia which we do ...continue
Obviously the ship has been updated since some of the previous reviews! Though we have cruised a number of times in the past (with Tauck) and this was our second Silversea cruise, it was certainly our very best experience. Everything from the ...continue


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Kindergarten Math Games & Puzzles * A solid foundation of basic math skills is essential for early success in math. Children who can connect their understanding of math to the world around them will be ready for the challenges of mathematics as they advance to more complex topics. The games and puzzles in this workbook are designed to help children enjoy practicing their math skills. Best of all, they'll have lots of fun doing it! * Paperback * 128 Pages * Published Date: April 27, 2010
Kindergarten Shapes & Geometry Success
Material: paperback
Care: Wipe with a dry cloth
Brand: Random House
Origin: Imported
Publishing behemoth Random House is the largest English language publisher in the world, with books of all kinds including the best in fiction, nonfiction and children's literature. Random House first made international news by successfully defending in court the U.S. publication of James Joyce's masterpiece, Ulysses, setting a major legal precedent for freedom of speech. Beginning in the 1930s, the company moved into publishing for children, and over the years has become a leader in the field. Random House entered reference publishing in 1947 with the highly successful American College Dictionary, which was followed in 1966 by the equally successful unabridged Random House Dictionary of the English Language. It continues to publish numerous reference works, including the Random House Webster's College Dictionary.


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Dr. Katrin Müller-JohnsonSenior Lecturer in Applied Criminology
|Contact Details
+44 (0)1223 767184
|Go to: Research Abstract
Dr. Katrin Müller-Johnson
Senior Lecturer in Applied Criminology
Dipl. Psych., Free University of Berlin, Germany, 1999
MSt Legal Research, Oxford University, UK, 2000
Ph.D. Human Development, Cornell University, UK, 2005
Dr. Müller-Johnson's research interest is the interface between psychology and law, focusing on eyewitness psychology, investigative interviewing and on legal decision-making.
One major area of her research is on the effects of cognitive aging on eyewitness testimony and on ways to improve the quality of investigative interviews with older adults. She also studies the victimisation of older adults, the prevention of elder mistreatment and victims' experiences with the legal system.
The other focus of her research is decision-making in the criminal justice context, such as jurors' interpretations of standards of proof, or sentencing decisions. From 2007 to 2009 she was Principal Investigator on an AHRC grant investigating jurors' interpretations of standards of proof.
Other recent work includes a study on the prosecution of child sexual abuse. Dr. Müller-Johnson is also interested in family-law oriented connections between psychology and law and has investigated post-divorce child contact arrangements in the UK, the USA and in Germany.
Selected Publications:
Eyewitness Psychology
- Müller-Johnson, K, (2009). Older Adults as Witnesses in Court. In Jamieson,A., Moenssens, A. (Ed). Wiley Encyclopedia of Forensic Science. Chichester: John Wiley Sons Limited.
- Müller-Johnson, K. (2009). Ältere Menschen als Zeugen vor Gericht. Forensische Psychiatrie, Psychology und Kriminologie. 3, 3, 163- 170.
- Gilstrap, L.L., Laub, C., Zierten, E.A. & Müller-Johnson, K. (2008). The effects of adult suggestion and child consistency on young children's reports. Journal of Applied Social Psychology, 38, 7, 1905-1920.
- Müller-Johnson, K, Toglia, M.P., Sweeney, C.D., Ceci, S.J. (2007) The perceived credibility of older adults as witnesses and its relation to ageism. Behavioral Sciences and the Law, 25, 355-375.
- Müller-Johnson, K. & Ceci, S.J. (2007). The elderly eyewitness: A review and prospectus. In Toglia, M.P., Read, D.J., Ross, D.F., Lindsay, R.C.L., (Eds.). The Handbook of Eyewitness Psychology: Volume 1. Memory for Events, 577-603, Mahwah, NJ: Lawrence Erlbaum Associates, Inc.
- Müller-Johnson, K. & Ceci, S. J. (2005). Zur suggestiven Beeinflussbarkeit von älteren Menschen (On the suggestibility of older adults). In K.-P.Dahle, R. Volbert (Eds.), Entwicklungspsychologische Aspekte der Rechtspsychologie. (Developmental aspects of legal psychology), 318-329. Goettingen: Hogrefe.
- Müller-Johnson, K. & Ceci, S.J.(2004). Memory and suggestibility in older adults: Live event participation and repeated interview. Applied Cognitive Psychology, 18, 8, (1109-1127).
Decision-Making within the Criminal Justice Context
- Müller-Johnson, K & Dhami, M. K. (2010). Effects of offenders' age and health on sentencing decisions. The Journal of Social Psychology, 150, 1, 77-97.
- Leeney, D. G. & Müller-Johnson, K. (2010). Examining the link between forensic quality and customer service quality of police call centre interviews. International Journal of Police Science and Management, 12, 1, 69-80.
- Kautt, P.M. & Müller-Johnson, K. (2009). Cross-jurisdictional disposition variability under sentencing guidelines: The example of equivalent sex offenses. Criminal Justice Review, 34, 3, 350-381.
- Coates, S, Kautt, P.M. & Müller-Johnson, K (2009). Fixed Penality Notices. Journal of Experimental Criminology, 5, 399-428.


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The Tokyo Motor Show Yamaha presented a really interesting new concept – the Y125 MOEGI. The retro styled motorcycle only ways 176 pounds, is very fuel efficient and thus only comes with a really small tank. Check out the video that Yamaha has released on the MOEGI concept here below.
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Natural Factors Slim Styles Weight Loss Drink Mix is clinically proven to support weight loss through appetite control and glucose balance. By balancing glucose levels, SlimStyles significantly reduces food cravings making weight loss a more achievable goal.
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- Study at Deakin
- Life at Deakin
- Research
- Alumni
- Industry and community
- About Deakin
Note: The 2012, 2013, 2014 publications have not been audited.
Jump to: Publications | Grants and Consultancies | HDR completions
Antonio Zorzano may be from another institution or only recently joined Deakin University.
2005 External
Cartoni, Romain*, Leger, Bertrand*, Hock, M. Benjamin*, Praz, Manu*, Crettenand, Antoinette*, Pich, Sara*, Ziltener, Jean-Luc*, Luthi, François*, Deriaz, Olivier*, Zorzano, Antonio*, Gobelet, Charles*, Kralli, Anastasia* and Russell, Aaron (2005) Mitofusions1/2 and ERRα expression are increased in human skeletal muscle after physical exercise., Journal of physiology, vol. 567, no. 1, pp. 349-358, Cambridge University Press, London, England [C1.1]
ERA journal ID: 3169 – Scopus EID: 2-s2.0-23844494686
Citation counts: Scopus - 142, Thomson - 140
DRO entry for this publication
No grants and/or consultancies found or audited – the 2014 HERDC financial return has not been completed or loaded as yet.
No completions found or audited.
DRO to publications collection last synchronised: Sunday 28th December 2014 10:04pm


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FSDA Matlab code
FSDA Toolbox extends MATLAB and statistics toolbox to support a robust and efficient analysis of complex data sets.
FSDA was first released on March 2012.
News of April 2013 release of FSDA: new routines for fast subset updating and fast computation of Mahalanobis distances which reduce considerably computing time (see function FSMmmd.m). New version of scatter plot matrix with univariate boxplots or stacked histograms for multiple groups in the main diagonal, and interactive clickable multilegend. To have a preview click here or see the HTML or .m documentation of spmplot. Routines to compute the k-th order statistics based on quick sort algorithms.
In the Installation Note Section or pdf file we tried to document all that you have to expect when FSDA is installed manually by unpacking the compressed tar file FSDA.tar.gz, or automatically with our setup program for Windows platforms
Download FSDA (Last updated Sep 20th, 2013) A setup executable for MS Windows platforms will install the toolbox and update the search path of your local MATLAB installation.
Download a compressed tar file of the toolbox, suitable for Unix platforms installation. In this case, you have to add manually FSDA folder and sub-folders to the MATLAB path or use our routine addFSDA2path.
Download a working paper describing the main characteristics of the FSDA toolbox or see RIANI, M., PERROTTA D., TORTI F. (2012).
You can have a look at the toolbox features through some quick screenshots or through some didactic movies
Please, do not hesitate to contact us for any bug you might find and for any suggestion you might have!!! Thanks to all those who have already contacted us and have helped us to correct several bugs and improve the performance of the code. For support on the code please write to this address.


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If there is one type of clothing I wish I had less of, it would be old t-shirts. I have entirely too many! This makes sense, being that many of the activities I've participated in over the years have involved free tees. As a result, there are shirts from fundraising events, 5k races, sorority functions, and community service projects cluttering my dresser drawers and overflowing my laundry hamper. Because I wear these shirts primarily to the gym, though, I recently began researching ways to re-create them into cute, fashionable pieces. As it turns out, many things can be made from a ratty old gym shirt.
By getting creative with old tees, you can get rid of a few old shirts and simultaneously expand your summer wardrobe! Some of these projects are so unique, and result in shirts and accessories that may not even be found in stores. I may have to learn how to sew, but it would be worth it to be able to wear some of these great DIY t-shirt projects.
Would any of you try one of these tutorials? Which is your favorite?
[Images: top image, 2, 3, 4, 5, 6, 7, 8, 9, 10]


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Processing Time - Orders typically ship in 2-5 business days. Transit via UPS Ground can take up to 6 business days. Braided and custom-made products may take 2 to 3 weeks for delivery.
Free Shipping to Contiguous United States - We do not ship to Alaska, Hawaii or the Caribbean Islands at this time.
Oversized items - Orders that ship freight may take up to 2 weeks from shipment date to be delivered. You will be contacted by the trucking company to schedule a delivery appointment.
Shipping to Canada - Orders shipping to Canada will be subject to a 15% shipping surcharge fee. The shipping surcharge does not cover duties, customs, taxes or brokerage fees which may be charged to you by the shipping courier at time of delivery. At this time we are not shipping to Yukon and the Northwest Territories in Canada.
|Pin It
Serendipity Puzzle Pieces Pink Rug
Item #: 200SEKD17-P Add to Wishlist
Features: This product has the following features:
- Collection: Serendipity
- Material: 100% Wool
- Weave: Hand Tufted
- Styles: Kids Rugs
- Origin: India
- Available in the following sizes: 5' x 8'
- Clean & Care: Vacuum regularly as new wool rugs can shed yarn fibers for up to three months. Avoid direct and continuous exposure to sunlight. Do not pull loose ends, clip them with scissors to remove. Clean liquid spills immediately by blotting with cloth or sponge. For hard to remove stains, professional rug cleaning is recommended.
Great rug for both my girls' rooms. They are 4 & 7 1/2 and they both like the pattern and colors. The light pink areas are much lighter, more like a creamy pink, unfortunately, but still a nice rug!RECOMMENDED: Yes, I would recommend this to a friend.
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SSH, or secure shell, is a protocol for remote login with an advantage over telnet being that it can use public key authentication instead of passwords. Another advantage over the telnet protocol is that plain text is not transfered; the data sent between the host connections is encrypted.
dropbear is a small SSH v2 server and client package. Keys are generated and the server is started on system bootup by default, unless either the ttylinux dropbear starup script detects the CPU is slower than 1 GHz or the nosshd boot options was specified.
dropbear allows password and public key authentication. Public key authentication can use DSS and RSA keys and works with keys generated by the popular OpenSSH package. Having a public key from OpenSSH in the file .ssh/authorized_keys should allow secure login from the machine that has the corresponding private key. The permissions on the .ssh directory must not include group or other write permission, otherwise dropbear will refuse public key authentication.
The SSH client program is called dbclient. It is different from the server in that it cannot use keys in OpenSSH format. You can use the dropbearconvert program to convert an OpenSSH format key for use by dbclient or you can use dropbearkey to create a new key.
To convert an OpenSSH key stored in /.ssh/id_rsa, do:
dropbearconvert openssh dropbear \ ~/.ssh/id_rsa ~/.ssh/id_rsa.db
The new key will be stored in /.ssh/id_rsa.db. You can use the -i switch to dbclient to make it use your new key for authentication. The public key part of the old OpenSSH key can be used as-is for pasting into your /.ssh/authorized_keys file. Conversion is only needed for the private key.
To create a new RSA key to store in /.ssh/id_rsa.db, you can use the following command:
dropbearkey -t rsa -f ~/.ssh/id_rsa.db
The public key part of the new key will be printed to the screen. You can put it into the /.ssh/authorized_keys file on all machines where you want to be able to login using your new private key stored in /.ssh/id_rsa.db. You can create a DSS key instead of an RSA key by using -t dss instead of -t rsa. Should you lose the public key, you can always get it back by using the private key and the -y switch to dropbearkey:
dropbearkey -y -f ~/.ssh/id_rsa.db
If you want to use scp to copy files from another machine, the standard scp program from OpenSSH is included with dropbear and ttylinux.


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Before you board that east-bound jet there are a few things to learn that will help you prepare for your visit as well as satisfy your curiosity.
It's good to know about tipping in France, how to ride the Metro, where the embassies are, perhaps a bit of history of Paris, certainly weather information and even what to wear in Paris.
Did you know, for instance, that Paris was the largest city in the world between the 16th and 19th centuries?
Or that the entire land area of Paris is a mere 40 square miles, just over 100 square kilometers? And that twenty percent of the entire population of France lives in the Paris metropolitan area?
We could go on. In fact, we do — in the articles below.
Get Paris Insider advice on:
• Tipping
• Euro-to-dollar conversion
• Essential Paris etiquette tips.
Find out how the VAT tax works and how to save money with a VAT tax refund.
Did you know that the first settlement at what is now Paris was founded over 2300 years ago?
The first Parisiens were the Parisii, the Celtic people who were the original settlers. They were followed by the Romans, and then there were Franks and Gauls and... well, a lot of other people.
• Discover The History of Paris »
Paris is made up of 20 arrondissements (or neighbourhoods) each with a distinct feel and atmosphere.
Learn what's where, discover the attractions in each of the arrondissements and which ones you'll want to pay close attention to.
• Guide to Paris Arrondissements »
Paris Facts. Arts, entertainment, fashion and museums are the integral components of the city's culture. Find out about how Parisians enjoy all the incredible cultural activities —
• Free museums
• Other free stuff in Paris
• Explore the art scene in Paris
• And so much more…
• Guide to Paris Culture & Arts »
Can't make it to Paris this year? Movies are the next best thing to being there. Building your own library of favorite Paris movies is a nice way to rekindle your memories of the City of Cinema, or to get in the mood for your next trip.
Read our guide to classic Paris movies to help pass the time until you make it across the Atlantic!
Want to be mistaken for a Parisienne? Learn how to plan your Paris wardrobe for functionality and fashion.
Parisians are known for their flair and you don't want to make a fashion fas paux on your Paris vacation. Find out what to wear in Paris, spring, summer, fall and winter.
• Overview – What to Wear in Paris »
It's fun to learn a few more Paris facts before you go. Since it was founded as Lutetia, the population of Paris has grown from a few thousand Gauls to over two million Parisians, and has gone up and down over the centuries.
Find out when Paris was even more densely populated than it is now. What's the current population?
• All About The Population of Paris »
With so many transportation options, it's easy to get around Paris without spending a fortune, and certainly, absolutely, without renting a car!
Learn about the Paris taxis, the Velibs (bicycles) and the Paris city transportation system that include the Metro, the buses, the RER and the tramways. The great part of the urban transportation system? There's "One Pass To Rule Them All" »
It would be nice to know what weather to expect on your arrivel in Paris. And, although the city's weather can be quite temperamental (no pun intended), you can make a good guess of what it's going to be for the time you will arrive. Learn about the Paris seasons and weather patterns to help plan your trip.
Charles de Gaulle and Orly are the two main Paris airports. Orly is used mainly for domestic flights and Charles de Gaulle (CDG) for international flights. So, CDG is most likely the airport you will arrive at and depart from.
Learn how to manoeuvre CDG and find out how to get from the airport to the city.
• CDG & The Paris Airports – Read Our Guide »
The only time you're ever likely to need an embassy is if your passport has been lost or stolen or if you have become stranded. In case of emergencies like these help is at hand in Paris for US and Canadian citizens at their respective embassies.
|All About Moulin Rouge Paris
Eiffel Tower Tours
|Fave Day Trips From Paris
|Guide to the Paris Museum Pass


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» News
Obama's Electronic Medical Records Scam
Here's more evidence that government "cures" are inevitably worse than the "diseases" they seek to wipe out. Buried in the trillion-dollar stimulus law of 2009 was an electronic medical records "incentive" program. Like most of President Obama's health care rules, this top-down electronic record-sharing scheme is a big fat bust.
Oversight is lax. Cronyism is rife. The job-killing and privacy-undermining consequences have only just begun.
The program was originally sold as a cost-saving measure. In theory, modernizing record-collection is a good idea, and many private health care providers have already made the change. But as with many government "incentive" programs, the EMR bribe is a tax-subsidized, one-size-fits-all mandate. This one pressures health care professionals and hospitals across the country into radically federalizing their patient data and opening up medical information to untold abuse. Penalties kick in for any provider that hasn't switched over by 2014.
So, what's it to you? Well, $4 billion has already gone out to 82,535 professionals and 1,474 hospitals, and a total of $6 billion will be doled out by 2016. But the feds' reckless profligacy, neglect and favoritism have done more harm than good.
Don't take my word for it. A recent report released by the Department of Health and Human Services Inspector General acknowledged that the incentive system is "vulnerable to paying incentives to professionals and hospitals that do not fully meet" the program's quality assurance requirements. The federal health bureaucracy "has not implemented strong prepayment safeguards, and its ability to safeguard incentive payments postpayment is also limited," the IG concluded.
Translation: No one is actually verifying whether the transition from paper to electronic is improving patient outcomes and health services. No one is actually guarding against GIGO (garbage in, garbage out). No one is checking whether recipients of the EMR incentives are receiving money redundantly (e.g., raking in payments when they've already converted to electronic records). No one is actually protecting private data from fraud, abuse or exploitation.
Little is being done to recoup ill-gotten payments. In any case, such "pay and chase" policing after the fact is a crummy way to run government in lean times — or in fat times, for that matter.
As for the claim that the EMR conversion will reduce paperwork, many doctors say the reality is just the opposite. In Greensboro, N.C., Dr.
Richard Aronson told local TV station FOX 8 that the mandate doubled the amount of paperwork in his private practice. Everyone from optometrists to general practitioners to chiropractors to podiatrists must divert precious time and resources to conforming with Washington health bureaucrats' imposed vision. Some medical professionals are now warning that the dangerous phenomenon of "distracted doctoring" is on the rise as a result of data-driven imperatives that direct health care providers' attention away from their patients and onto their screens and hand-held devices.
» 6 Comments
Awesome. Can't wait until the next Obama voter goes in for a physical. They're gonna get more than a finger up the ass. They're gonna get a whole arm.+7
You're going to see ID theft go to a whole new level here. As having just lived through this nightmare myself, thanks to an employee of a BANK OF the united states of AMERICA giving my info out the back door, I truly feel sorry for the people that are going to get f—ed over in the name of Obummercare.+5
The progressive/liberal/left's plan to euthanize America.+3
At my job, we've made an interesting discovery about EMR applications. When giving the multiple options for the same procedure to be billed, the highest costing version of the procedure always sorts to the top of the list. This has caused for Medicare and Medicaid to be billed more than ever before. The EMR is the cause.+2
Has Obama done anything that isn't more expensive, less effective or otherwise detrimental to the USA ?
Betcha most of those ill-gotten payments are in unionized states.+2


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On January 31 1857, the body of dentist Harvey Burdell was found mangled on the floor of his suite at 31 Bond Street. In Benjamin Feldman's look at the murder and its famous trial, 'Butchery on Bond Street' he uncovers so many potential suspects that entire episodes of 'Murder She Wrote' could be scripted from a single page.
Suspicion, of course, mostly rests on Burdell's former lover Emma Cunningham, an attractive and elusive women suffers the abuses of a misogynistic press while remaining unsympathetic for much of the tale.
Feldman lays out the details of a love affair turned sour, intertwined with jealous family members, seedy bachelors and secret marraige vows. Notably, A. Oakley Hall makes an appearances, years before his scandals with Boss Tweed.
'Butchery' has the ingredients of a delicious gaslight thriller, far more successful a crime novel than period piece. The biographical details of Burdell and Cunningham are indeed rich but the tale's gothic qualities would have benefited from more atmosphere.
My favorite portions were rather tangental to the actual storyline -- solid depictions of Vinegar Hill, Brooklyn, and upstate Saratoga Springs, that "watering hole for the wealth and the aspiring middle class." It's worth getting to the third act, when Cunningham concocts a botched fake baby scheme so outrageous it gets the attention of P.T. Barnum.
Below: a Harpers Weekly of the 1857 Cunningham trial
You might say 'Ziegfeld: the Man Who Invented Showbiz' is a biography with more character than its subject. In fact, I would call this retelling of Florenz Ziegfeld's life by author Ethan Mordden more a performance than a book. But wouldn't Flo approve of that?
Mordden wryly recounts all of Ziegfeld's sexy, zany productions as though he had been backstage and were describing things from a corner booth in a nightclub later that night. One takes away the feeling of crazy possibility in those days, when Ziegfeld could throw any combination of girls, music and dance on stage to see if it would stick. Like a pageant, he parades by the reader every Ziegfeld production -- from Eugen Sandow to the final Follies -- with both reverence and all-knowing.
The author's vast knowledge of Broadway history is clearly displayed, but the writing is quirky, friendly, open but insider-y. He peers into Ziegfeld's heart and even dares prioritize Flo's true loves in life. (Ann Held, Lillian Lorraine, Billie Burke or Marilyn Miller: who wins?) After racing through the book in a couple days, I felt I had just drank an entire bottle of champagne.
We'll be occasionally reviewing new New York history-related books on this site. If you're a publisher and have any upcoming releases, please let us know by emailing firstname.lastname@example.com.


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International Journal of Ecology
Volume 2012 (2012), Article ID 939862, 17 pages
Review Article
Parallel Ecological Speciation in Plants?
1Department of Botany, University of British Columbia, 3529-6270 University Boulevard, Vancouver, BC, Canada V6T 1Z4
2Biology Department, Indiana University, 1001 E Third Street, Bloomington, IN 47405, USA
Received 3 August 2011; Revised 14 October 2011; Accepted 18 November 2011
Academic Editor: Andrew Hendry
Copyright © 2012 Katherine L. Ostevik et al. This is an open access article distributed under the Creative Commons Attribution License, which permits unrestricted use, distribution, and reproduction in any medium, provided the original work is properly cited.
Citations to this Article [8 citations]
The following is the list of published articles that have cited the current article.
- Roger S. Thorpe, Yann Surget-Groba, and Helena Johansson, "Quantitative traits and mode of speciation in Martinique anoles," Molecular Ecology, vol. 21, no. 21, pp. 5299–5308, 2012. View at Publisher · View at Google Scholar
- Rose L. Andrew, Nolan C. Kane, Greg J. Baute, Christopher J. Grassa, and Loren H. Rieseberg, "Recent nonhybrid origin of sunflower ecotypes in a novel habitat," Molecular Ecology, vol. 22, no. 3, pp. 799–813, 2012. View at Publisher · View at Google Scholar
- Anssi Karvonen, and Ole Seehausen, "The Role of Parasitism in Adaptive Radiations—When Might Parasites Promote and When Might They Constrain Ecological Speciation?," International Journal of Ecology, vol. 2012, pp. 1–20, 2012. View at Publisher · View at Google Scholar
- Federico Roda, Luke Ambrose, Gregory M. Walter, Huanle L. Liu, Andrea Schaul, Andrew Lowe, Pieter B. Pelser, Peter Prentis, Loren H. Rieseberg, and Daniel Ortiz-Barrientos, "Genomic evidence for the parallel evolution of coastal forms in the Senecio lautus complex," Molecular Ecology, vol. 22, no. 11, pp. 2941–2952, 2013. View at Publisher · View at Google Scholar
- Nathaniel Pope, Michael Fong, Robert S. Boyd, and Nishanta Rajakaruna, " The role of elevation and soil chemistry in the distribution and ion accumulation of floral morphs of Streptanthus polygaloides Gray (Brassicaceae), a Californian nickel hyperaccumulator ," Plant Ecology & Diversity, pp. 1–12, 2013. View at Publisher · View at Google Scholar
- Roger K. Butlin, Maria Saura, Grégory Charrier, Benjamin Jackson, Carl André, Armando Caballero, Jerry A. Coyne, Juan Galindo, John W. Grahame, Johan Hollander, Petri Kemppainen, Mónica Martínez-Fernández, Marina Panova, Humberto Quesada, Kerstin Johannesson, and Emilio Rolán-Alvarez, "Parallel Evolution Of Local Adaptation And Reproductive Isolation In The Face Of Gene Flow," Evolution, 2013. View at Publisher · View at Google Scholar
- R. T. Pereyra, D. Johansson, H. Forslund, P. R. Jonsson, K. Johannesson, C. Huenchunir, and L. Kautsky, "Parallel speciation or long-distance dispersal? Lessons from seaweeds (Fucus) in the Baltic Sea," Journal Of Evolutionary Biology, vol. 26, no. 8, pp. 1727–1737, 2013. View at Publisher · View at Google Scholar
- E A Stacy, J B Johansen, T Sakishima, D K Price, and Y Pillon, "Incipient radiation within the dominant Hawaiian tree Metrosideros polymorpha," Heredity, 2014. View at Publisher · View at Google Scholar


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Devise, wit; write, pen
Today I return to these lines from the comical character Don Armado in Love's Labour's Lost: "Devise, wit; write, pen; for I am for whole volumes in folio." I am, of course, quoting them out of context, as one inevitably does when quoting Shakespeare. (Just think of Catherine Morland - from Austen's Northanger Abbey, quoting from Twelfth Night as if it were a good thing for a young woman to sit "like Patience on a monument", for instance.)
Don Armado is, as I said in a post in September, an ass; that does not make his words completely misguided, any more than it lessens the words of Polonius (from Hamlet), many of which are widely quoted (including "Brevity is the soul of wit" and "This above all things: to thine own self be true"). He may be a tedious old man who is misguided, long-winded and has a propensity to speak in platitudes, but Polonius is one highly-quotable (and highly quoted) guy.
Back to my reason for returning to the words of Don Armado:
I am going away for a few days on a writing retreat with my frequent writing partner and good friend,
From tomorrow morning until Sunday afternoon, I'll be in Brigantine, which is just north of Atlantic City along the Jersey shore. Just in time for what used to be Hurricane and/or Tropical Storm Ida but is now a Nor'Easter to move on in for days. So much for long walks on the beach, but it ought to mean more cozying up for writing (and reading, and a nightly movie).
Theoretically, we'll have WiFi down there and, if so, I shall post a bit. Meanwhile, I have from now until 8 a.m. tomorrow to finish laundry and packing and whatnot.
Labels: plays, shakespeare, writing


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North Korea
The Democratic People's Republic of Korea is a country in East Asia, located in the northern half of the Korean Peninsula bordering South Korea and China. Its capital, Pyongyang, is the country's largest city by both land area and population. It is a single-party state led by the Korean Workers' Party (KWP), and governed by Supreme Leader Kim Jong-un since 2012. It has a population of 24,052,231 (UN-assisted DPRK census 2008) made up of Koreans and a smaller Chinese minority. Japan 'opened' Korea in 1876 and annexed it in 1910. The Republic of Korea (ROK) was founded with US support in the south in August 1948 and the Soviet-backed Democratic People's Republic of Korea (DPRK) in the north in September that year.
North Korean officials stash foreign currencies at home, defectors say
North Korean officials routinely stash large amounts of foreign currencies such as US dollars in their homes, say high-profile defectors
Most Popular
Two high-profile North Korean defectors working for South Korea's spy agency have revealed how regime officials routinely stashed huge sums of foreign currency in their homes.
Both men are analysts at the Institute for National Security Strategy, an affiliate of South Korea's National Intelligence Service.
They said Kim Jong-un, who took power after his father Kim Jong-il's death in December, appears to be trying to take control of various foreign-exchange schemes controlled by the party and army as he seeks to boost the nation's ailing economy.
In recent months Kim experimented with agricultural and economic reforms after he and his powerful uncle purged the Stalinist state's top general for opposing change.
One of the defectors, who did not want to be named, said that since the 1990s, high-level officials with links to economic bureaus have been hoarding foreign currencies - even as millions of people starved to death due to famine.
"Party officials have been keeping massive sums of dollars close to hand - US$500,000 to US$1 million in their homes," he said.
It is unclear whether the practise has continued since Kim took power and if his reforms include tackling high-level corruption.
Foreign reporters, briefed yesterday by the two men in a secure complex in a woodland south of Seoul, were told they could not disclose the location.
The other defector, Goh Young-hwan, said the number of North Korean defectors had fallen since Kim Jong-il's death. That could be due to the new leader's promise to improve the economy, he said.
"This has raised expectations of a better future," Goh said.
Another key reason is a new policy enacted on the previously porous border with China that gives guards greater incentives to capture defectors.
"In the past, if North Koreans wanted to cross the river, they gave money to guards," Goh said.
"Now the regime says to the guards, 'Take the money - we will not punish you - but get [the defectors] and we will give you credit'."
Although Kim Jong-un seems to be more open and less warlike than his father, there is no fundamental change in his policy towards South Korea.
Inter-Korean Yellow Sea naval clashes flared in 1999 and 2002. In 2010, North Korea sank a South Korean ship and shelled an island. Earlier attacks include a special forces assault of the presidential residence in 1968; a bombing of the cabinet in 1980 and the bombing of a Korean Air flight in 1987.
A museum at the National Intelligence Service desplays exhibits captured from North Korean agents, including a female agent's suicide poison disguised as a phial of perfume, underwater infiltration apparatus used by naval commandos and poisoned-tipped knives disguised as pens.
A poster is emblazoned with the NIS hotline, "111", for reporting spies. Another, showing a phone camera snapping a person on a train, warns that agents look like everyday people, and offers a reward for information leading to the capture of enemies.
Additional reporting by Reuters
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#258 - chicomole (01/28/2012) [-]
#267 to #478 - Drpealz (03/27/2012) [-]
figured I'd see just how big of a train wreck this site has become. that, and the pony threads, sometimes. still don't have my own computer, but I'll see if I can't snag one for my birthday.
I'm impressed, this site has improved a fair amount since I left.
I'm impressed, this site has improved a fair amount since I left.
#269 to #480 - Drpealz (03/27/2012) [-]
eh, the content's really the one thing that we'll be unable to fix. there's a ******* of people online any day of the week, and not all of them have seen the same picture. if only people would understand that the newbies haven't seen the same content as the vets, we can finally stop screaming "REPOST" in the comments. but, people are just too bull-headed to realize this, so, we're gonna have to keep dreaming.
#276 to #487 - chicomole (03/27/2012) [-]


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