text:
I had to cancel class Monday because of a family emergency. I taught Wednesday, and was ready at the podium at 2:30 on Thursday.
I asked the student a hypothetical: "You hold a secret formula and are the minority shareholder. The majority shareholder wants you to reveal the secret formula to his son. What are you worried about?" The student seemed caught off guard, but after a pause he sensibly answered the question. I followed up with a question about the contract at issue. More of a pause, and classwide mutterings.
It seems I'd assigned the wrong reading for the day. I had 6 pages of well-thought-out notes in front of me, and was gazing out at 75 students who were prepared for a completely different set of cases.
What to do?
My first 2 years teaching, I wouldn't have had a clue. But it's not my first rodeo. I said, "Well, let me tell you a story..., summarized the key points of the case, and let the discussion proceed from there. Not pretty, perhaps, but workable--and actually a nice challenge for a Thursday afternoon. Any similar tips or stories from old hands out in the blogosphere about getting out of a teaching jam?
Otherwise, class dismissed.
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The question: to con law or not to con law?
The context: Steve Bainbridge responding to Anne Tucker's post on including a Citizens' United/Hobby Lobby discussion in a BA course (see Anne's reply to Steve here). The question is a timely one for me: Georgia Law started classes this week, and I (the rare bird who rotates casebooks because she is easily bored) am happily back teaching from Steve's casebook, co-authored with Klein & Ramseyer, which I highly recommend. I never hand out a syllabus with assigned readings because invariably we move quicker or slower than I anticipate. I have to cut or add material, and I find that students find such midstream changes unsettling. So I don't tell them where we're going til we get there.
But I do have a "working syllabus" I hash out for myself at the semester's opening and tweak as the classes unfold. As Anne and Steve point out, the semester is ridiculously crowded. In 3 credits I cover partnership, corporations, and LLCs, and I cover the MBCA and Delaware corporate code. It's way too much material (as I told my class Wednesday as part of my "drop this class" introductory speech). My working syllabus has material for each of the 42 50-minute classes I'm allotted, and I agonize over the choices I make in filling each one. This year, for the first time ever, my roughed-out working syllabus includes a day for Citizens United/Hobby Lobby.
Why? Steve makes a terrific case for private law, and I am with him. I love teaching BA for BA's sake. Explaining to students the basic puzzle of ownership versus control, the different ways to run the railroad in terms of choice of entity and the tradeoffs among them? Throw in the importance of private ordering and the ability to read a statute, and I'm in heaven. I'm no public law scholar in sheep's clothing. I'm a true believer, proselytizing for the beauty of business law in what sometimes does feel like a con law desert.
But I have got more doctrinal material than I can possibly cover. Throw in a class where I invite in a practitioner, a class for Bill Chandler to talk about whatever the heck it is he wants to, and a review session, and we're talking precious few classes to cover a lot of material.
So why cede a precious class to public law jibber-jabber? I'm still not sure I will. But the reason came to me on a playground, chatting with an English professor mom. We were commiserating over our lack of preparation for the start of the semester (secret: professors procrastinate, too), and she said, "well, it must be nice to teach a subject so interesting to students. Hobby Lobby, Citizens United." She nodded knowingly.
The comment brought me up short. Nobody things corporations are interestng. At least, no one used to. But now they do. And sure it's for the "wrong" reasons--not for coprorate law reasons, but for reasons that deal with corporations' role in society. And I think that might be enough to devote one class out of my 42. Not for Anne's reason, "to "hook" students who didn't come to my class with an interest in corporate law." I'm confident I can hook them on the merits. But because, as she also says, "Corporate law also matters to general members of society because corporations wield tremendous power in elections, in lobbying (regulatory capture anyone?), in shaping retirement savings, in religious and reproductive rights debates and setting other cultural norms around issues like corruption, sustainability, living wage, etc." It struck me on the playground that the "legal literacy" reason I give for taking Corporations--it's just something that every lawyer should know--may apply here as well. With Hobby Lobby we might have reached the point where corporate law literacy demands a passing understanding of these two cases.
Maybe not. The CU/Hobby Lobby class may well end up on the cutting room floor. But one last thing: as I get older, it is increasingly less clear to me that my students retain much past the exam. What I want them to get out of the class, ultimately, is a basic knowledge of the relevant codes, of the importance of codes, an ability to read statutes, an understanding of the importance of default rules versus mandatory ones, agency costs, the trade-offs in choice of entity, the business judgment rule, and fiduciary duty. Looked at that way, perhaps one public law class out of 42 isn't too much of a sacrifice in terms of coverage.
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I have a problem with VAPs--the visiting assistant professorships/fellowships that are the most common entry-point to the legal academy. What I am looking for in a new colleague is curiosity, discipline, and the capacity for intellectual give-and-take--not just play king-of-the-hill and defend a position against all comers, but engage in a real dialogue. One of my colleagues call it "sparkiness."
So how do you find that?
Pre-VAP, writing an article while in practice was a strong signal--if you were interested, cared enough, and were hard enough working to write while in practice, you were a pretty good bet. With VAPs now de rigeur, the signal is muddied. Each law school that houses VAPs has strong institutional incentives to place all of them, so it's hard to use VAP recommenders as a signal--the law school will find someone to enthuse about each of its VAPs. And VAPs are now well-groomed to say the right things, coached as to the standard arguments and responses. They talk the talk. But will they walk the walk 3 years into teaching? It's hard for me to tell.
There are recommenders and recommenders, of course. Each institution will have those discerning types who don't lard on the praise--whose compliments, even if sparing, mean more than the lavish encomiums of their colleagues. But how to find these?
As I commented on Elizabeth Pollman's great closing post,
last year I was talking to a distinguished older professor about hiring. He said he had stopped caring about how smart someone was, since everybody at this level is smart. "I don't care how smart the candidate is. Show me why they've done." I've thought about that conversation a lot since then. What makes a successful law professor or law student seems to have as much to do with drive/work ethic as smartness. The latter may be necessary, but is not sufficient.
It's just harder to discern "what someone has done" when their job as a VAP is basically to produce scholarship and have it be vetted and polished. Of course I'm just throwing stones--I don't have any ideas about how to make these discernments in the post-VAP age. Maybe someone else does?
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I had a great time teaching international business transactions (IBT) this past year. As I think about how I would do it next term, I once again confront the same problem I encountered a year ago: what to include?
I realize that all law professors struggle with the same problem of coverage but it seems that IBT courses can differ substantially in the topics and skills covered. From conversations with fellow IBT professors, it seems that we adopt several different approaches even if we tend to use the same main texts. So, I thought that I would open up conversation on some of following issues for teaching IBT:
- What skills should we prioritize and what are the best ways to teach those skills?
- How do we include good case studies? Should we organize our case studies by transaction, regional focus, or some other topic?
- Should we borrow pedagogical strategies from our colleagues at the business schools?
- What are the best ways to integrate regional context into the course? What regions should we cover?
- How can we use the course to improve the "business competence" of our students?
- What opportunities can we provide our students for applying their knowledge and skills to "real world examples" in international business?
Anyway, I'd love to hear views from other IBT teachers in the blogosphere!
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Just before Christmas the Washington Law Review published a symposium issue honoring Larry Cunningham's new book, Contracts in the Real World. The issue is a good read for Contracts teachers. You can read my contribution, "Contracts as Pattern Language" here. The abstract for this essay is below:
Christopher Alexander's architectural theory of a "pattern language" influenced the development of object-oriented computer programming. This pattern language framework also explains the design of legal contracts. Moreover, the pattern language rubric explains how legal agreements interlock to create complex transactions and how transactions interconnect to create markets. This pattern language framework helps account for evidence, including from the global financial crisis, of failures in modern contract design.
A pattern represents an encapsulated conceptual solution to a recurring design problem. Patterns save architects and designers from having to reinvent the wheel; they can use solutions that evolved over time to address similar problems. Contract patterns represent encapsulated solutions within a legal agreement (or set of agreements) to a specific legal problem. This problem might consist of a need to match the particular objectives of counterparties in a discrete part of a bargain or to address certain legal rules. A contract pattern interlocks, nests, and works together with other contract patterns to solve more complex problems and create more elaborate bargains. Interlocking patterns enable scalability. Just as Alexander's architectural patterns for rooms create patterns for buildings, which create patterns for neighborhoods and cities, patterns of individual contract provisions form legal agreement patterns, which interlock to create patterns for transactions, which, mesh to create patterns for markets. For example, contract patterns help lawyers draft real estate contracts. These contracts interlock in sophisticated real estate transactions, which mesh with other contract patterns to form securitization transactions. Securitization patterns create markets for asset-backed securities, which, form part of the larger shadow banking system.
This scalability differentiates contract patterns from boilerplate. However, legal scholarship on boilerplate – including Henry Smith's work on the modularity of contract boilerplate – patterns allow certain debt contracts to become what Gary Gorton calls "informationally insensitive" and to enjoy many of the economic features of money.
The pattern language framework explains not only how sophisticated contracts function, but also how they fail. The pattern language framework provides a lens for examining recent contracts law scholarship on the failures of sophisticated contract design, including "sticky" contract provisions in sovereign bond agreements, "Frankenstein" contracts in mortgage-backed securitizations, and the "flash crash." If modularity and contract design patterns foster the development of new financial instruments and markets, then their features can also contribute to the unraveling of these markets. For example, by restricting the information content of contracts, patterns and modularity not only midwifed the creation of liquid markets for those contracts, they also played a role in "shadow bank runs" and the catastrophic freezing of these markets. The failure of contracts can have systemic effects for entire markets when a particular contract enjoys widespread use or when it is so connected to other critical contracts that cascading failures occur.
This essay was a contribution to a symposium for Larry Cunningham's book, Contracts in the Real World.
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We had 3 first days last Wednesday. Our oldest started kindergarten, a new school and our first time in the public school system. My youngest (7.5 months) started day care for the first time. And our younger daughter started a new class in daycare.
Whew! Getting used to new routines and juggling 3 kids' schedules took a lot out of me! Plus, it was jarring entering the new world of elementary school. 5 years in, we are old hands at our daycare. A new school brings foreign terminology, procedures, and customs. I am a creature of routine, and I think the thing that bugs me the most about first days is that we haven't yet got the routine down, and we're just kind of making it up as we go along. Blech. I can already tell this week will be better!
I've been thinking about first days in general because 1) I'll be speaking to the incoming 1L class later this week, and 2) for the first time I'll be teaching first-semester Contracts students. Any advice you might have to pass along to either group? The topic of my orientation talk is "Preparing for Class." And the topic for the first class is...Contracts, I guess. I'm planning on jumping in without giving much of an overview. But thoughts are welcome!
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Concurring Opinions is hosting an online symposium on Larry Cunningham's new book, Contracts in the Real World (Cambridge). Here is my contribution:
Let me start out with a criticism of Larry's book: it is too much fun. I had a hard time breaking off just a chunk of Contracts in the Real World to write about and found myself spending several hours reading one interesting vignette after another on famous and infamous contracts.
The book will make a wonderful companion text to a traditional contracts casebook. Its value is not just in its engaging account of contract stories or in giving context to chestnut cases, but in providing a very intuitive framework for understanding contract law. The traditional contracts course, perhaps by virtue of having the doctrine of consideration at its heart, can be one of the most confusing in the One-L year. Students are often left to divine the inner structure (or lack thereof) of contract law on their own, likely while cramming for finals. Sometimes the epiphany comes. For many students it does not.
Larry has a real genius for laying out the doctrinal building blocks in a very thoughtful and accessible structure. He groups cases around a rough life cycle of contracts, with chapters devoted to "Getting In: Contract Formation," to "Facing Limits: Unenforceable Bargains," to "Paying Up: Remedies." The layout of the book combined with its lucid writing demystifies contracts.
The layout may at first appear to make this book an ill fit as a companion text to many case books, because many of the cases appear in Contracts in the Real World under a different doctrinal heading than in a particular case book. For example, in the case book I currently use Batsakis v. Demotsis appears in the chapter on "consideration." Larry places this classic next to cases on unconscionability. I also teach Lucy, Lady Duff Gordon in consideration, while Larry situates it in "Performing: Duties, Modification, Good Faith."
These differences actually demonstrate a strength of the book. Some disconnect between the organization of a primary case book and a companion text forces students to move beyond a facile understanding of contract law in terms of rigid doctrines. Seeing cases in different contexts and fitting into different doctrinal boxes can help students see that lawyering involves more than memorizing black letter rules and putting issues into the right doctrinal box. Indeed, sometimes different doctrinal boxes can apply to the same problem and lead to the same result (witness rules on past consideration and duress). At other times, the choice of the doctrinal box makes a huge difference (see those same two doctrines). Accomplished students can move from memorizing blackletter law to seeing the possibility of creative lawyering. Larry's organization – both intuitive and surprising – will help students at both stages.
One final strength of the book is Larry's choice to include not only court cases but many contemporary contract disputes that never reached the courtroom (such as the dispute between NBC and Conan O'Brien). This brings into the classroom a wider panorama of how lawyers encounter and shape contractual problems in practice. After all, few contracts and few lawyers find their way into a courtroom. Most disputes are resolved in the shadow of law.
I also have a wish list for Larry's next project (from personal experience, I can tell you how invigorating it is for an author who has just finished a book to be asked "what's next?'). One of the limitations of the traditional contracts curriculum is how rarely students read and interpret – let alone negotiate or draft – actual contracts. It would be incredibly helpful as a professor to have some of the source contracts behind these stories. Although some of these contracts are already contained in a judicial opinion (Carbolic Smoke Ball) and many will not be public (Conan's deal with NBC), others might be available with some digging. Having real and full contracts would allow professors to meet many of the items on Professor Collins' wish list, such as transactional perspectives and drafting exercises. Although some lawyers litigate over failed contractual relationships, many more help parties plan prospectively – including by drafting and negotiating deals. For most attorneys, contracts are not an autopsy subject, to be dissected in a court opinion, but a living thing.
Professor Cunningham's book provides a joyful reminder of the life in contracts.
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From our friends in Boston...
SUFFOLK UNIVERSITY LAW SCHOOL in Boston invites applications for several tenure track positions starting in the 2013-2014 academic year. We seek entry-level and lateral candidates with strong academic records and a demonstrated commitment to excellence in teaching and scholarship. We have particular curricular teaching needs in first-year contracts and first-year property, together with upper-level courses with a focus on health law, business or financial services. We also have foreseeable needs in criminal law and international law. Consideration may also be given to relevant practice experience and community involvement. Suffolk University is an equal opportunity employer. We encourage applications from women, persons of color, sexual orientation minorities, and others who will contribute to the diversity of the faculty. Interested candidates should contact Professors Jessica Silbey and Robert Smith, Co-Chairs, Faculty Appointments Committee, at firstname.lastname@example.com and firstname.lastname@example.com, with a copy to email@example.com, or mail their materials to the Co-Chairs of the Appointments Committee, c/o Janine LaFauci, at Suffolk University Law School, 120 Tremont St., Boston, Massachusetts 02108-4977.
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There, I said it.
Haskell Murray's sweet and thoughtful post on mentors reminded me of my early teaching days. 7 years might not sound like a lot to you grizzled veterans, but it strikes me at the end of this academic year that I've been around for a while now. Looking back to my first year, I remember one observation from an old hand that sounded ludicrous at the time: "It doesn't really matter if we cover all the material. It's not a big deal."
"What?!" I was horrified. I had only 3 credits to cover Business Associations, not the luxury of 4. As it was whole chapters and doctrines were left to the wayside, and I felt I had to rush through material to make sure we Covered It All.
I think it was around the end of my second year when I realized that 90% of law the students dutifully crammed into their heads for the exam had trickled out within 2 weeks. That realization was equal parts sobering and liberating. Now my goal is for students to walk out of BA understanding 1) there are different ways to run the railroad, each with tradeoffs in terms of control, liquidity and taxation 2) there are fiduciary duties, 3) the business judgment rule, 4) derivative suits (kind of), and most importantly, 5) THERE'S A STATUTE. Start there.
Don't get me wrong, there's plenty more that I teach and test on. But one of my big goals is to introduce students to the idea of transactional law. So I always try to have at least one guest speaker, a real live lawyer who will tell the class what their practice is like. And we've been lucky enough to have Bill Chandler, the former Chancellor of the Chancery Court, teach a short course here at Georgia for the past several years. When he's in town I dragoon him into service. He's talked about the history and role of the Chancery Court, Disney, what it's like to be back in practice. It's an incredible opportunity for our students to hear from him--much more valuable than anything I could impart in lecture #42.
In Contracts we have a negotiation class and a class on NDAs. I find these classes, particularly toward the end of the semester, are a welcome break in the routine for students. What's more, they give students a taste of how transactional attorneys deal with contracts in real life. Providing this context makes the students care more about the doctrine they're learning.
When I mention such classroom excursions to very new professors, they often remark, "Oh, that sounds great, but I just don't have the time! I have so much to cover!"
I nod understandingly and smile.
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Here is a highly productive way for business law professors to procrastinate from grading exams:
The National Bureau of Economic Research just circulated a new version of a paper that provides a medieval complement to the law & finance literature and to Gilson's lawyer as transaction cost engineer idea. The paper by Davide Cantoni and Noam Yuchtman presents evidence that the training of commercial lawyers by new universities contributed to the expansion of economic activity in medieval Germany. Here is the abstract:
We present new data documenting medieval Europe's "Commercial Revolution'' using information on the establishment of markets in Germany. We use these data to test whether medieval universities played a causal role in expanding economic activity, examining the foundation of Germany's first universities after 1386 following the Papal Schism. We find that the trend rate of market establishment breaks upward in 1386 and that this break is greatest where the distance to a university shrank most. There is no differential pre-1386 trend associated with the reduction in distance to a university, and there is no break in trend in 1386 where university proximity did not change. These results are not affected by excluding cities close to universities or cities belonging to territories that included universities. Universities provided training in newly-rediscovered Roman and Canon law; students with legal training served in positions that reduced the uncertainty of trade in medieval Europe. We argue that training in the law, and the consequent development of legal and administrative institutions, was an important channel linking universities and greater economic activity.
A very interesting read.
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Thanks to Erik Gerding for the opportunity to share some of my ideas on corporate criminal liability, Dodd-Frank, corporate influences on individual behavior and educating today's law students only three months into my new academic career. I appreciate the thoughtful and encouraging emails I received from many of you. I even received a request for an interview from the Wall Street Journal after a reporter read my two blog posts on Dodd-Frank conflicts minerals governance disclosures. We had a lengthy conversation and although I only had one quote, he did link to the Conglomerate posts and for that I am very grateful.
I plan to make this site required reading for my seminar students, and look forward to continuing to learn from you all.
Best wishes for the holiday season and new year.
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Law schools are under attack. Depending upon the source, between 20-50% of corporate counsel won't pay for junior associate work at big firms. Practicing lawyers, academics, law students and members of the general public have weighed in publicly and vehemently about the perceived failure of America's law schools to prepare students for the real world.
Admittedly, before I joined academia a few months ago, I held some of the same views about lack of preparedness. Having worked with law students and new graduates as outside and in house counsel, I was often unimpressed with the level of skills of these well-meaning, very bright new graduates. I didn't expect them to know the details of every law, but I did want them to know how to research effectively, write clearly, and be able to influence the clients and me. The first two requirements aren't too much to expect, and schools have greatly improved here. But many young attorneys still leave school without the ability to balance different points of view, articulate a position in plain English, and influence others.
To be fair, unlike MBAs, most law students don't have a lot of work experience, and generally, very little experience in a legal environment before they graduate. Assuming they know the substantive area of the law, they don't have any context as to what may be relevant to their clients.
How can law schools help?
First, regardless of the area in which a student believes s/he wants to specialize, schools should require them to take business associations, tax, and a basic finance or accounting course. No lawyer can be effective without understanding business, whether s/he wants to focus on mom and pop clients, estate planning, family law, nonprofit, government or corporate law. More important, students have no idea where they will end up after graduation or ten years later. Trying to learn finance when they already have a job wastes the graduate's and the employer's time.
Of course, many law schools already require tax and business organizations courses, but how many of those schools also show students an actual proxy statement or simulate a shareholder's meeting to provide some real world flavor? Do students really understand what it means to be a fiducuiary?
Second and on a related point, in the core courses, students may not need to draft interrogatories in a basic civil procedure course, but they should at least read a complaint and a motion for summary judgment, and perhaps spend some time making the arguments to their brethren in the classroom on a current case on a docket. No one can learn effectively by simply reading appellate cases. Why not have students redraft contract clauses? When I co-taught professional responsibility this semester, students simulated client conversations, examined do-it-yourself legal service websites for violations of state law, and wrote client letters so that the work came alive.
When possible, schools should also re-evaluate their core requirements to see if they can add more clinicals (which are admittedly expensive) or labs for negotiation, client consultation or transactional drafting (like my employer UMKC offers). I'm not convinced that law school needs to last for three years, but I am convinced that more of the time needs to be spent marrying the doctrinal and theoretical work to practical skills into the current curriculum.
Third, schools can look to their communities. In addition to using adjuncts to bring practical experience to the classroom, schools, the public and private sector should develop partnerships where students can intern more frequently and easily for school credit in the area of their choice, including nonprofit work, local government, criminal law, in house work and of course, firm work of all sizes. Current Department of Labor rules unnecessarily complicate internship processes and those rules should change.
This broader range of opportunities will provide students with practical experience, a more realistic idea of the market, and will also help address access to justice issues affecting underserved communities, for example by allowing supervised students to draft by-laws for a 501(c)(3). I'll leave the discussion of high student loans, misleading career statistics from law schools and the oversupply of lawyers to others who have spoken on these hot topics issues recently.
Fourth, law schools should integrate the cataclysmic changes that the legal profession is undergoing into as many classes as they can. Law professors actually need to learn this as well. How are we preparing students for the commoditization of legal services through the rise of technology, the calls for de-regulation, outsourcing, and the emerging competition from global firms who can integrate legal and other professional services in ways that the US won't currently allow?
Finally and most important, what are we teaching students about managing and appreciating risk? While this may not be relevant in every class, it can certainly be part of the discussions in many. Perhaps students will learn more from using a combination of reading law school cases and using the business school case method.
If students don't understand how to recognize, measure, monitor and mitigate risk, how will they advise their clients? If they plan to work in house, as I did, they serve an additional gatekeeper role and increasingly face SEC investigations and jail terms. As more general counsels start hiring people directly from law schools, junior lawyers will face these complexities even earlier in their careers. Even if they counsel external clients, understanding risk appetite is essential in an increasingly complex, litigious and regulated world.
When I teach my course on corporate governance, compliance and social responsibility next spring, my students will look at SEC comment letters, critically scrutinize corporate social responsibility reports, read blogs, draft board minutes, dissect legislation, compare international developments and role play as regulators, legislators, board members, labor organizations, NGOs and executives to understand all perspectives and practice influencing each other. Learning what Sarbanes-Oxley or Dodd-Frank says without understanding what it means in practice is useless.
The good news is that more schools are starting to look at those kinds of issues. The Carnegie Model of legal education "supports courses and curricula that integrate three sets of values or 'apprenticeships': knowledge, practice and professionalism." Educating Tomorrow's Lawyers is a growing consortium of law schools which recommends "an integrated, three-part curriculum: (1) the teaching of legal doctrine and analysis, which provides the basis for professional growth; (2) introduction to the several facets of practice included under the rubric of lawyering, leading to acting with responsibility for clients; and (3) exploration and assumption of the identity, values and dispositions consonant with the fundamental purposes of the legal profession." The University of Miami's innovative LawWithoutWalls program brings students, academics, entrepreneurs and practitioners from around the world together to examine the fundamental shifts in legal practice and education and develop viable solutions.
The problems facing the legal profession are huge, but not insurmountable. The question is whether more law schools and professors are able to leave their comfort zones, law students are able to think more globally and long term, and the popular press and public are willing to credit those who are already moving in the right direction. I'm no expert, but as a former consumer of these legal services, I'm ready to do my part.
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A great example can be found in 9-302, where Article 9 graciously defers to federal law by not requiring (or giving legal force to) a UCC-1 Financing Statement with respect to property that is subject to a federal statute which specifies a different place of filing. It helps to ask students to imagine what the outcome would be if this provision did not exist. Some may argue that in the absence of Article 9's express deference to the federal filing requirement, there would not necessarily be a direct conflict. In other words, parties could readily file under both systems. Others may raise a field preemption argument, whereby any Article 9 filing requirement would be rendered moot by a federal statutory scheme on point. Many others will invoke typical Article 9 policy considerations (such as certainty, predictability and uniformity in commercial law) and argue that a duplicative filing requirement would introduce uncertainty to filers and searchers. Indeed, each of these arguments has been raised in cases dealing with conflicts between Article 9 and federal law.
Once identified, the conflicts angle can be revisited in a number of contexts. Article 9 codifies many resolutions of conflicts, including state law conflicts (consider Article 9's deference to state motor vehicle title statutes). It can be useful to brainstorm these issues throughout the semester, because once students are sensitive to the conflicts issue, they can more readily understand more complex provisions of Article 9. For instance, consider the ever-misunderstood 9-408. This is a statute that, upon a student's first reading, seems to boldly set aside federal and state laws, as well as the private contractual agreements of persons who may not even be party to a transaction governed by Article 9. Wow! But once the statute is contextualized within the conflicts and federal preemption issue, students can appreciate that the drafters were not actually trying to overturn or nullify conflicting federal or state laws and contractual agreements. Rather, the provision reflects a much more modest goal: it seeks to clarify the operative effect that those conflicting provisions will have under Article 9, purely for Article 9 purposes. It's a subtle distinction, but an important one.
I believe that grappling with puzzles of this sort can really pay out in practice. Young attorneys are often called upon to interpret and apply statutes quickly. A rich awareness of statutory interpretation can guide the analysis. So, too, can a basic understanding of how a particular law relates to other laws in a multistate, federal system. And, on a more personal note, I think these inquiries introduce students to the richness and rigor of commercial law.
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I am grateful for Usha's latest post about her ambivalence to law and emotions scholarship because it provides an opportunity to engage in extended public discussion about what are some of the legal payoffs to (business) law professors of learning and teaching about emotions in general and happiness in particular.
I concur with Usha that it's a busy time of the academic year as the semester is coming to a close and many of us will soon be traveling for the holidays (and some of us have traveled to participate in conferences). Of course, most of us feel that we are if not always, then at least constantly busy. In their article titled Idleness Aversion and the Need for Justifiable Busyness, Christopher K. Hsee, Adelle X. Yang, and Liangyan Wang present experimental evdience that busier people self-report being happier. The following is a video short about how the days are long, but the years are short.
I am quite sympathetic to Usha's opinion that while happiness research is "all fascinating and it shapes my daily choices and reaffirms (or causes me to question) my life choices. Happiness research goes to the core of myself as a person. Still I wonder: what does this have to do with law?" This is partly because her view is one that many people including myself from a couple of years ago share. As Usha pointed out, I've already written a number of law review articles and some peer-referred articles about law and emotions including but not limited to happiness. Rather than repeating any of those article's themes (those interested can find all of them available here), I'll share five concrete responses to the specific challenge that Usha issued about what are the legal implications of and payoff to emotions and happiness research.
First, much of law concerns and is about human behavior: how to discourage anti-social human behavior and encourage pro-social human behavior. In attempting to change human behavior, law is and must be predicated upon a theory of human behavior. The theory can be Oliver Wendell Holmes' bad man or neoclassical economics' much caricatured rational actor. Whatever that underlying theory of human behavior is that law is based upon, that theory must address human JDM (Judgment and Decision Making) because in order for the law to change human behavior the law must change the judgments and/or decisions that humans make. It just so happens there has been a recent flood of research about how emotions in general and happiness in particular influence human JDM. This research is diverse and scattered across many disciplines, including anthropology, economics, finance, neuroscience, marketing, philosophy, political science, psychology, and sociology. Of course, this plethora of non-legal interest and research does not have to mean there are legal implications of new understandings about how emotions and happiness shape human JDM. But at least some law professors can and should read this rapidly growing literature to digest it and see if any of it has legal implications or payoffs. Professor Emeritus and former Dean of Stanford Law School and current President of the William and Flora HEwlett Foundation, Paul Brest teaches a graduate course on JDM at Stanford University. He has co-authored with Professor of Law and Director of the Ulu Lehua Scholars Program at the William S. Richardson School of Law in Honolulu, Hawai'i and Senior Research Fellow at the Center for the Study of Law and Society at the University of California, Berkeley, Linda Hamilton Krieger a book titled Problem Solving, Decision Making, and Professional Judgment: A Guide for Lawyers amd Policymakers. Chapter 13 of their book analyzes complexities about decision-making including predicting future well-being and Chapter 16 is titled The Role ofAffect In Risky Decisions.
Second, much of business law is premised upon the neoclassical economics model of utility maximization or the behavioral economics challenge to that model. In either case, business law can benefit from recent work on happiness economics because happiness economics raises a more fundamental challenge to and radical critique of neoclassical economics than does behavioral economics. Some view happiness economics as being a proper subset of behavioral economics, while others view happiness economics as being an extension of behavioral economics. In any event, behavioral economics points out that people have bounded rationality, willpower, and self-interest. The theoretical core of behavioral economics is an article titled Prospect Theory: An Analysis of Decision under Risk by Daniel Kahneman and Amos Tversky. This is an article which is likely to have been cited more times than it has been read by law professors and certainly more times than it has been understood by law professors as evidenced by overly broad attempted legal applications.
Happiness economics points out how people often systematically make decisions that fail to maximize their experienced happiness ex post as opposed to their anticipated or predicted happiness ex ante. This robust empirical and experimental finding means that at least in principle there is room for some other party, public or private, to help improve (or take advantage of) people's JDM. In a recent working paper that is a forthcoming article in the American Economic Review, titled What Do You Think Would Make You Happier? What Do You Think You Would Choose?, Daniel Benjamin, Ori Heffetz, Miles S. Kimball, and Alex Rees-Jones present survey evidence that although what people choose hypothetically and what they predict would maximize their SWB (Subjective Well-Being) typically coincide, there are systematic reversals. They identify such factors as autonomy, family happiness, predicted sense of purpose, and social status to help account for hypothetical choices while controlling for predicted SWB. Their methodology has a number of possible legal and policy applications, including the development of aggregate measures of happiness. Another example is the application of their approach to reconcile the tension between an empirical finding in the article The Paradox of Declining Female Happiness by economists Betsey Stevenson and Justin Wolfers of declining average SWB of American women since the 1970s, both in absolute terms and in relative terms compared to men, with a common intuition that expanded political and economic freedoms for American women have made American women better off. Survey respondents who were asked to rank living in a world with or without such increased political and economic freedoms for women. Significantly more respondents choose to live in a world having expanded political and economic freedoms for women despite believing that a world without such expanded political and economic freedoms would make them happier than the opposite. Their National Bureau of Economic Research working paper 16489 titled Do People Seek to Maximize Happiness? Evidence from New Surveys contains additional examples and more details.
Third, research into two specific emotions, namely fear and greed finds that participants in financial markets are sometimes emotional and sometimes unemotional because they engage in both emotional and unemotional types of mental processing in responding to ever-changing market circumstances. In a series of articles titled,
(1) The Adaptive Markets Hypothesis: Market Efficiency from an Evolutionary Perspective
(2) Reconciling Efficient Markets with Behavioral Finance: The Adaptive Markets Hypothesis
(3) The Three P's of Total Risk Management
finance professor Andrew W. Lo posits that many tenets of rational expectations and the so-called efficient markets hypothesis fail to hold always, despite serving as useful benchmarks of what might eventually happen under certain idealized conditions. He speculates that an evolutionary theory of punctuated equilibria involving rare but big environmental shocks resulting in mass extinctions and eruption of new species could apply to financial markets. As Lo points out, law and policy that is based upon assuming rationality or more precisely lack of emotionality is going to be inapt during financial crises. Similarly, law and policy that is based upon assuming emotionality is going to be inapt during financially calm times. His Adaptive Markets Hypothesis implies that effective law and policy should adapt in light of changing financial markets and their participants. Examples of such adaptive business law and policy include:
(1) Countercyclical capital requirements.
(2) Collection, communication, dissemination, publication, and transparency of information about accurate systemic risk measures.
(3) Creation of a Capital Markets Safety Board (CMSB), analogous to the National Transportation Safety Board which conducts an independent investigation of all transportation accidents, in order to perform definitive forensic analysis of past financial crises. The CMSB would be made up of "teams of experienced professionals— forensic accountants, financial engineers from industry and academia, and securities and tax attorneys—that work together on a regular basis to investigate the collapse of every major financial institution."
As Professor Lo cogently observes,
"The fact that the 2,319-page Dodd-Frank financial reform bill was signed into law on July 21, 2010—six months before the Financial Crisis Inquiry Commission submitted its January 27, 2011 report, and well before economists have developed any consensus on the crisis—underscores the relatively minor scientific role that economics has played in responding to the crisis. Imagine the FDA approving a drug before its clinical trials are concluded, or the FAA adopting new regulations in response to an airplane crash before the NTSB has completed its accident investigation."
Fourth, central to effective JDM is the development and practice of skills related to emotions and emotional intelligence. A number of business trade books and business school courses focus on how managers can improve their emotional intelligence and in so doing become more effective organizational leaders. Law school clinical and negotiation casebooks and courses often discuss the importance of recognizing and responding appropriately to emotions in attorneys, clients, judges, juries, and other legal actors. For example, in their chapter, If I'd Wanted to Teach About Feelings, I Wouldn't Have Become a Law Professor, Melissa L. Nelken, Andrea Kupfer Schneider, & Jamil Mahuad present concrete tools for teaching law students about the importance of emotions in negotiation. Yet much of current American legal non-clinical education teaches students explicitly and implicitly that lawyering is just about logical analysis and not about feelings. For example, in another article titled The Discourse Beneath: Emotional Epistemology in Legal Deliberation and Negotiation, Erin Ryan writes that "[b]y acknowledging the salience of wise emotionality in individual and collective deliberation, lawyers will not only improve their own personal repertoires, but propel the practice of law, negotiation, and policymaking toward new horizons of efficacy." Similarly, a recent book titled How Leading Lawyers Think: Expert Insights into Judgment and Advocacy by Randall Kiser discusses (at pages 75-85) how important emotional intelligence is to legal practice.
Fifth and finally, law professors can and should incorporate more information about emotions into law school. Many law professors and law students share a common discomfort with and disdain for emotions in part because of what many law students and faculty believe it means to think like a lawyer. For example, see page 422 of the article titled Negotiation and Psychoanalysis: If I'd Wanted to Learn about Feelings, I Wouldn't Have Gone to Law School by Melissa L. Nelken. In her anthropological study of first–year contracts classes at eight law schools, law professor and senior fellow of the American Bar Foundation Elizabeth Mertz found that being taught to think like a lawyer caused students to lose their sense of self as they develop analytical and emotional detachment, resulting from the discounting of personal moral reasoning and values, as they learn to substitute purely analytical and strategic types of reasoning in place of personal feelings of compassion and empathy.
In fact, empathy is an important skill that lawyers can and should learn. In his article, Thinking Like Nonlawyers: Why Empathy Is a Core Lawyering Skill and Why Legal Education Should Change to Reflect Its Importance, Ian Gallacher analyzes pedagogical implications of lawyers communicating a lot with people who are not lawyers, such as clients, jurors, and witnesses.
In conclusion, a better and more nuanced understanding of what roles emotions generally and happiness particularly can play in human JDM, economic behavior, financial markets, legal practice, and legal education can and should inform how law professors conduct academic research and teach law students.
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both characters are awesome.
great voices and pure evil.
Don't hate me cause ... (I'm Da Man)!
Carlo Hooks you up thread, just click HERE!
With all the Filmation threads coming back, we might as well bring this one back too. I'm not the biggest Filmation fan, but even this MYP fan could get behind the ancient evil of Shokoti and her cleric, Lord Masque.
The Blonde Teela (Battleground and Alcala Teela) Thread
MegaGearMax's 200X/MYP Screen Grabs
Sagitar 200X Prince Adam 200X Sorceress Evilseed (MYP)
I completely agree. Though the episodes are great, and unique for the Filmation He-Man, and the character designs are cool, and I'd be happy to add them/her to my MOTUC collection,,....
I am just not that jazzed about them. I mean, given the above, I would still rather have Icer, Strongarm, Fang Man, and Lizard Man more.
I acknowledge that perhaps the Shokoti and all is really great, but I too wonder what is so special.
Maybe just to have a new Vilian female, wonderful, but otherwise the three I mentioned above fit the origianl Vintage line better, and so I felt their exclusion more.
Frankly I'd rather have a Keldor Mother (and if it were Shokoti that would be cool) more, with a nice bio.
I don't that many Filmation characters but I would definitely take a Shokoti.
MOTUC NA Most Wanted: Darius, Kayo, Vizar, Hoove, Lizorr
Trade my Red Stone He-Ro Staff for a Green one
HE-MAN UK Adventure Magazine #26
ancient evil gar sorceress! very cool. love her look!
I remember watching her episodes as a kid, and I was scared of her. I love Shokoti, and I think the 4H could do great things with her design!
If they get FIlmation rights, Shokoti is a must!
I am not to crazy about getting filmation, but Shotoki is a must.
Wow...if those images don't make me want a Shokoti figure, especially the last one, I don't know what will
Most definitely, my friend. (By the way, please bring back your last avatar that had the Sorceress/Matty Lies on it. That was awesome.)
Tweet Me!
I've just changed my profile picture because we got Geldor in MOTUC!
Shokoti would be an excellent figure - however there are other Filmation characters I'd like before her.
On the Gar issue ... maybe Shokoti isn't just a Gar ... but the first of the Gars. What if young Preternian Shokoti was somehow transported to Infinita in search of magiks and was somehow accidentally transformed into the blue-skinned witch that has haunted young Eternian kids' nightmares for generations. Then later Shokoti sired the first of the blue-skinned race which ultimately in our time is known as Gars.
This may explain why the Eternian people shun the Gar prince Keldor.?
Grayskull needs its Cardboard Spacesuit MOTUCized
Voice your support in the Cardboard Spacesuit/Robot thread:
Simply awesome! Imagine what the 4H can do with a character like Shokoti!
**Staunch FILMation lover!!! **** MUST have a New Adventures Subscription!!!**
MOTUC NEEDS more TROLLANS !!!
YES! Now that Mattel has Filmation rights, it is possible for us to finally get 'the Dark Goddess' aka Shokoti as an action figure!
Who is with me in wanting Shokoti as an action figure ASAPP? Her name was brought up enough in the Filmation polls so bring it on Mattel!
"You can not fight the darkness He-man!"-Shokoti-the Queen of Darkness
Arizona Mazter of the Universe
She's definitely in my top 5 most wanted FILMation characters, and I can't wait to see her added to the MOTUC ranks!!
I think she'll be made sooner than later since she was pictured in the SDCC presentation.
"Oh Lord, Bless this M&M... and the mighty cockroach I slain in battle to get it." - Al Bundy
Yes! Not only is she wickedly cook, but I need her to be the Evil Sorceress referenced in the Star Sisters' original story.
I don't remember her from the toon, but she looks awesome and I'm a sucker for evil witches.
And she has blue skin. May be the same race as Keldor and Sy-Klone?
... Keldor sister? ...who knows...
Yes please!
My MOTUC top wants (POST NYCC 2014):
Filmation:Twiggets - Red Knight - Granita - Hunga the Harpy - Dylamug - Vultak - Enchantress - Kothos - General Tataran - Evil Seed (Filmation artichoke) - Masque - Sybiline (with a pack-in Gorgon) - Melaktha
Others: Despara - toy version of Catra - Veena - Master Sebrian - Drissi - Caz - Andros - Sorceress (NA comics version)- Kex Queen - Lodar
Oh yes!!! She's the figure from FILMation I want the most after Shadow Weaver!!! Bring her on!
200X fan? Classic fan? What does that mean? I'm a MotU fan!!!
She is definitely in my top ten Filmation/Jetlag characters.
1) Scorpia
2) Octavia
3) Sea Hawk
4) Madame Razz & Broom
5) Icer
6) Strong Arm
7) Shokoti
8) Fang Man
9) Masque
10) Vultak


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Check It Out
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Stay winter-weather aware. Learn about closing information, snow removal and more.


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Mischa Barton Shows Her Headband Collection
Fab Flash: Mischa Barton Unveils Her Headband Collection
by Fashion 23 Reactions 0 Shares Print
This one's for you Mischa Barton fans. The former OC actress has unveiled her bohemian chic Mischa Barton For Stacey Lapidus headband line. "She's definitely known for being bohemian and for her hippie look . . . I tried to put both the bohemian and the classic into the collection," said accessories designer Lapidus.
The collection, consisting of six holiday-inspired headbands, are embellished with beads, pearls, crystals, sequins, and flowers — check out Mischa modeling her headband and handbag collection seen left. Prices range from $80 to $200 and are available at StaceyLapidus.com. Excited?
To see more headbands and new goodies from her handbag collection, read more.
Read More Mischa Barton HandbagsStacey LapidusCelebrity DesignersFashion FlashCelebrityHeadbandsMischa Barton
Mischa Barton
Celebrity Designers
Kkkkkkkkkkk 5 years
:oy: That's all I have to say. Just :oy: I'm with Mack, I'd be ashamed to admit I'd bought one of these, in fact I'd be ashamed to buy anything "designed" by Mischa Barton. I really hope that the recession puts an end to this celebrity designer madness. From Lyndsay and her leggings to Mischa and her headbands, it just gets stupider and stupider as the months go by.
i-am-awesomeness 5 years
I really don't think that Mischa has a great sense of style (she was wearing mom jeans just a few months ago!), but those headbands are kinda cute. I can't say that I would never pay $80 for a headband b/c I very well might, if it was say, Coach or Marc by Marc Jacobs, or they were hella cute. But I really don't think these particular headbands are worth the $80-200.
amandaaa 5 years
sorry, no
myystque 5 years
No!!!! I hate hippie headbands. Everyone wearing them looks stupid and usually the wearer couldn't be further from a hippie.
benedictxvii 5 years
aren't those headbands out of style by now?
Foreverbabe 5 years
A headband collection! Her style is crap.
mack2600 5 years
i'd be ashamed to tell anyone if i bought one of these, not to mention she's doing a good job at exploiting anything and everything that the hippie movement represented. let's take every good thing american culture has produced and market it, flaunt it, turn it into a good product, turn it into a fad or a fashion, sh*t on and ruin anything it might have meant other than it's artificial purpose -- let's wring every dollar we can until it's dried up. all we have left is the money-making ideas passed from business man to PR to young loud ignorant arrogant fame whore trying to utilize her 15 minutes of fame by taking the opportunity to sell her image and in the process alienate what purity we have left in our culture and the memories of our past.
vanilla19 5 years
They're really pretty but way out of my budget..
amers230 5 years
wow, i have a hard time paying over $10 for a headband lol. way overpriced
lillovelygrl33 5 years
Mischa has fans? I loved the OC during the first two seasons, but since then the most exciting thing Mischa has done is have a bad shroom trip at Nicole Richie's bbq! No wayyyy I'd ever pay that much for a headband, esp a "Mischa Barton" headband lol
mod16 5 years
i actually love these, but i would never pay more than $15 for a headband
sidra5397 5 years
I'm not into headbands (boho chic isn't my thing) but to each their own I guess... I don't really know what kind of hippie would pay $80-100 for a headband though!
nancyluvs_greece 5 years
When I first heard about this i was excited, because i've liked Mischa since her O.C days but i'm disapointed with this. They are way too overpriced and unoriginal
lizzylu49 5 years
Perhaps is she wore it like an actual headband. "Hippie" headbands look like costumes.
fashionrox 5 years
The headbands are cute but way overpriced. Hopefully Nicole Richie's line will be a bit more affordable.
teagirl 5 years
Ooooh I like the bags shown here! I'm excited to see more!
LolaSvelt 5 years
Headbands suck and are for hippie try-hards.
nourhayaty 5 years
i like the bag she is holding and the black bag but the headband!well im over that trend!
marshawjs 5 years
the headbands are a bit pricey. not my style but it does look good on some. i think they would look nicer for an informal garden wedding.
emalove 5 years
I love bohemian style too, but I don't know about this collection...it's not doing much for me.
ckeller825 5 years
I love the whole hippie/bohemian look and I like the picture of her w/that headband, but I just checked out the website and I think I could buy stuff from Micheal's and make some that look just like that for about $5.
esweet 5 years
I just can't stand her style
mcollazo 5 years
I think those headbands are way overpriced.
Link Love
- Forget the LBD; Karlie shows us how to work a white one — Who What Wear
- Eek! You'll never believe what Kim Kardashian's sandals are made from — The Cut
- We're all about functional gloves like these — HuffPost Style
- These are the cookies the fashion crowd munches on — Style.com
- This guide means you won't overpack for the holidays — InStyle
- Does this video mean Lindsay Lohan's making a comeback? — StyleList
- Victoria's Secret just announced the spot of its next fashion show! — Racked
- According to Dov Charney, the American Apparel fight isn't over — Fashionista
- Are these men the stars of the red carpet? — Lucky
- These bags are proof you should still shop indie designers — The Fashion Spot


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Great addition
Reviewed By David D (Clarksville, TN) Reviewed for a 2012 Ford F-150 —12/1/2014 8:21 PM
Great way to make your truck you own. Installed in less than 20 minutes. The compliments don't stop coming.
Reviewed By Alan J (Duluth, MN) Reviewed for a 2011 Ford F-250 —11/29/2014 7:38 AM
Left headlight fit great but right one required cutting to get the bulb pigtails to fix behind the light. You do need to remove the grill and headlight to get to the adjustment 8mm bolts. They do look great!!


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Hernia Repair Device Markets And Procedures
NEW YORK, Dec. 11, 2012 /PRNewswire/ -- Reportlinker.com announces that a new market research report is available in its catalogue:
Hernia Repair Device Markets and Procedures http://www.reportlinker.com/p096700/Hernia-Repair-Device-Markets-and-Procedures.html#utm_source=prnewswire&utm_medium=pr&utm_campaign=PathologyThe hernia repair product market consists of products such as mesh materials, devices including fixation, equipment such as endoscopes, and instruments such as hand tools. The market has experienced steady demand and hernia repair procedures are consistent from year to year.This report, Hernia Repair Device Markets and Procedures looks at the hernia repair industry segment. New product innovation, a steady demand for superior products by surgeons, and increasing procedure volumes will likely fuel growth over the next five years. It is expected that the hernia repair segment will become increasingly competitive over the next five years as small, niche companies expand product development and licensing options. The report breaks out the market by product type: The worldwide hernia equipment market is composed of four major product types:
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DRDO (Ministry of Defence) | Govt. Jobs | JRF Vacancy | Last Date: 11 October, 2013
Oct 5, 2013 Chemical, Government Job, Job After Btech
DRDO was formed in 1958 from the amalgamation of the then already functioning Technical Development Establishment (TDEs) of the Indian Army and the Directorate of Technical Development & Production (DTDP) with the Defence Science Organisation (DSO). DRDO was then a small organisation with 10 establishments or laboratories. Over the years, it has grown multi-directionally in terms of the variety of subject disciplines, number of laboratories, achievements and stature.
Education: BE/ BTECH
(Chemical) from a recognized University with at least 60% marks- GATE qualified.
Job Location: Chhattisgarh
Stipend: Rs. 16000/- pm
Age Limit: 28 years
To Apply: Eligible candidates must apply with complete bio data and send it to the following address latest by 11 October, 2013-
REf—> The Employment News, Dated: 21-27 September 2013
Similar Posts
- DRDO | Walk-in: 9th Dec 2013 | Govt. Jobs in Delhi | JRF Vacancy.
- DRDO | JRF Vacancy | Govt. Jobs | Last Date: 24 November, 2011.
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Here we are coming up on our 13th annual B.E.E.R. Cruise 2014, and it is still getting bigger and better. Last year we had around 50 boats show up from around the country. From Canada, to South Florida, to California, the boats, they just kept on coming. We have even had two articles written up in Small Craft Advisor describing the cruise in detail.
This year we are going to rediscover some of the beautiful sailing territory of this region, and give you the opportunity to wear the tackiest shirt you can come up with. The dates for this years cruise is June 13 through June 17. In theory, this should be well ahead of hurricane season, but all bets are off for the next few years. If it rains, and you get really wet, just think of it as keeping your beverage cooler a little longer.
BEER has a kid, crew, boat and pet friendly open door policy for all 2 and 4 legged attendees and we don't discriminate on the basis of gender, race, national or planetary origin, religion, politics / sexual, boat or beer preference / animal breed. We even let Mac owners attend (LOL! A little since of humor).
As in the past, this is not a sanctioned event, each skipper will be responsible for his or her own vessel and crew. There is no cost involved for joining this group during this event. The only cost you might incur, will be the marina cost, which is $55, slightly more if you come early, and the cost of the cookout on Friday night, if you wish to participate.
If anyone wishes to get on the Skippers List, just click here and fill out the form.
See how simple that is. Looking forward to seeing everyone again this year.


text: American Red Cross at Atlanta Airport Lane Brothers Commercial Photographers (Atlanta, Ga.) Medical care--Georgia Transport planes--Georgia--Atlanta Airplanes American Red Cross William B. Hartsfield-Atlanta International Airport Delta Air Lines Local identification number: LBCB005-137a Envelope description: American Red Cross; [Delta Airplanes] Special Collections and Archives, Georgia State University Library Georgia State University. Libraries. Special Collections black-and-white negatives StillImage http://digitalcollections.library.gsu.edu/cdm/ref/collection/lane/id/10718 Image/jp2 1 photograph ; 4 x 5 inches Lane Brothers Commercial Photographers Photographic Collection, 1920-1976 Corporate Bodies 1950-08-25 Atlanta (Ga.) Fulton County (Ga.) The contents of this item, including all images and text, are for personal, educational, and non-commercial use only. This item is the property of Georgia State University Library and any user is asked to acknowledge Georgia State University Library. LBCB005-137a, Lane Brothers Commercial Photographers Photographic Collection, 1920-1976. Photographic Collection, Special Collections and Archives, Georgia State University Library.


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15 Ways to Refresh a Room Instantly
Give new life to your home with these simple interior decorating ideas
By Woman's Day Staff
Fast Fix-Ups
Could your house use some reviving? Upgrade bland decor and lifeless designs with thrifty tips and tricks that you can either do yourself or buy in stores. Read on for brilliant ideas thatll help you fall in love with your home all over again.


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BIG GAME® THE REDEMPTION™•Reversible shooting window colors (black or camo), extra large center windows & bottom wind flap •Features zippered roof opening, removable shoot-through mesh & shooting, silent one-hand release hooks to adjust & lower windows for unlimited window adjustment •Quick-Set Hub System for quick & easy set-up •Large reinforced stake loops on all four corners •(9) steel stakes w/interior stake pocket •(4) tie down ropes off center hubs to secure against wind •Lower, upper & roof brush strips for easy adaptation in all locations •(2) internal gear pockets •Premium, quiet, black-backed fabric w/Epic Camo finish •Shooting Width: 77" x 77" •Standing Ht.: 70" •Ht.(to bottom of windows): 33" (center), 26" (corners) •Wt.: 17.5 lbs. &bulAttributes/Specifications:Estimated Shipping Weight: 21 LbsEstimated Shipping Dimensions: 8X46X8.5 InchesManufacturer: Big Game HuntingPart Number: HB3000Product Code: BGHHB3000Image & Description Disclaimer - Images and product descriptions are provided by distributors and manufacturers; on occasion the text may contain unintentional errors or omissions. While we make every effort to ensure that pictures and descriptions are correct, we cannot guarantee its accuracy.
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If you listen, even fleetingly, to commercial country music, you've heard the song "Cruise." It set a record this year for most weeks at No. 1 on the country charts — in history. "Cruise" is also the second-most-downloaded country song of all time, and it's expected to top that list soon.
It's by Florida Georgia Line, two young men who've become country superstars in less than a year.
Music critic Jody Rosen writes for New York magazine, and is a huge fan of commercial country. Still, he says he's slightly baffled by the song's success.
"Now, 'Cruise' is one of the biggest hit country songs of all time," Rosen says. "It's a song simply about driving around in your car listening to a song like 'Cruise.'"
John Butler helped break the song. He's in charge of country music programming for Sirius XM.
"We started playing it very early," Butler says. "We started playing it in May 2012. And we played it a lot."
Back then, Florida Georgia Line wasn't yet signed to a label. It hadn't even released a full album. But "Cruise" shot to the top of the charts, and that caught the attention of Nashville's most successful independent label, Big Machine.
Big Machine built its reputation by signing Taylor Swift when she was unknown, as well as Tim McGraw. Label president Scott Borchetta had an idea to make "Cruise" even bigger: Do a remix.
"And I said, 'You know, it'd be great if we could find the right hip-hop guy for this — we really could take it over the goal line,'" Borchetta says.
The guy Borchetta got was the rapper Nelly.
"He's sort of a washed-up rapper, but in Nashville it doesn't really matter," Jody Rosen says. "He's exotic simply because he's a rapper."
Exotic enough to help "Cruise" stick around on the country charts — and climb to the pop Top 10 over the summer. Rosen says "Cruise," like other contemporary country songs, incorporates hip-hop and the kind of raucous arena rock that topped the pop charts a few decades ago.
"Its sort of frat-dude music with a twang," he says.
Rosen says he sees "Cruise" as symptomatic of several things happening in Nashville today. First is the rise of what he calls bro country: "There just seems to be so many songs about guys sitting on their tailgate watching their girlfriend dance in Daisy Duke shorts in a field somewhere," he says.
Second, those songs celebrate a very different male character from country's archetypal strong, stoic man, "who has hidden pain, but when he's all alone and when he gets a couple drinks in him, he cracks, right? But right now, these younger guys are just singing a lot about partying."
That trend is impossible to ignore, says Amy Macy, a former Nashville marketing executive — and now a professor at Middle Tennessee State University.
"Eight out of the Top 40 titles have some term or reference to alcohol or partying or drinking right now on the charts," Macy says. "That's, what, [nearly] 25 percent of the Top 40."
Some examples: "Drunk Last Night" by the Eli Young Band, "Drink to That All Night" by Jerrod Niemann, "Drink a Beer" by Luke Bryan, "Cold Beer With Your Name on It" by Josh Thompson, and Little Big Town's "Sober" — a song about the opposite of being sober.
Borchetta concedes that Nashville may have a problem.
"Everybody in Nashville must be drinking 24-7," Borchetta says with a laugh. "We're a bunch of drunks down here.
"There's too much, to be honest with you," he adds. "We can't keep talking about Fireball [whiskey] and Coors Light and having the tailgate down, etc. So we'll task our writers and artists to dig a little deeper."
Even if "bro country" won't stick around forever, hits do tend to spawn imitators, Amy Macy says. So until the next big country trend, she says, hold on to your Daisy Dukes.
"Or maybe burn them, is what I say," she says.


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Woman Locking BikeA first-of-its-kind study proves there is a positive link between cycling and health among women.
By Kyle Martin Jones
Cycling feels great, gets you places faster than walking and a recently published study has confirmed what most of us already know — it's good for you. In June, the Archives of Internal Medicine published a study that followed more than 18,000 women for 16 years; some participants walked briskly, some walked slowly, some biked and some did other activities. Over the 16 years, participants who engaged in brisk walking or cycling for 30 minutes a day showed some weight loss, whereas the participants who walked slowly showed slight weight gain.
Perhaps more surprising than the results of the study is the knowledge that this study is the first to look at cycling and weight loss. While much research has been done around walking, biking has been overlooked for years. And while it may not be a surprise that exercising by way of cycling has a positive effect on health and weight loss, having the backing of research could encourage more people to get out on a bike.
Findings like the ones in this study are also important in getting the support of the medical community. The recommendation by a medical professional to try cycling as a way to prevent weight gain would be the push that many people need to give the activity a try.
This is great news for the biking community, but also for women looking for new ways to maintain or lose weight. At 30 minutes a day, there is no need to become a hardcore, marathon cyclist, and even jumping on the stationary bike at the gym would be beneficial. For women who already ride, keep at it and feel good knowing that you're keeping yourself healthy.


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WFXG General Manager Barry Barth to Retire
WFXG vice president and general manager Barry Barth will retire at the end of the year after more than 50 years in the television business.
Barth has been VP-GM of WFXG, Raycom's Fox affiliate in Augusta, since 2003. He has also worked as VP-GM of KREM in Spokane and KGPE in Fresno. He began his career as a switchboard operator and runner at WNDU in South Bend when he was 15. His son, Kevin Barth, is the vice president and director of sales at WCBS, the CBS O&O in New York City.
"Barry has worked tirelessly on behalf of Raycom and for the people of the Greater Augusta Area," Leon Long, Raycom's senior vice president of television, said in a statement. "We wish him well as he begins the next chapter in his life." Read more


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Are you interested in joining our Independent National Recruiter team?
PBA Nationwide, LLC
Attn: Human Resources
1025 Boulders Parkway, Suite 410
Richmond, Virginia 23225
Due to our continuing growth, we have openings in the following position::
If you would like to join our team, please download the following forms and
National Recruiter
Company Logistics Consultant
Account Executives
Customer Service (Staffing Consultants)
Forklift and similar machine operators
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PBA is an equal opportunity employer offering a competitive salary and a comprehensive benefits package.
We also offer a rewarding and comprehensive compensation package for our Independent National Recruiters, which arguably is the best in this industry.
fax to 804-674-7806, or simply forward your resume to email@example.com. Please specify position of interest in subject line.


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Genesis of Honey: Survivor to Siren - A one-woman play
Presented by Honey Suckle Duvet at Cambridge Family YMCA Theatre
August 21, 2009
"Genesis of Honey: Survivor to Siren" is a moving story of burlesque dancer Honey Suckle Duvet told through dance, humor, eccentric characters and dramatic monologues. This one-woman play weaves together the survivor's spirit and how it led "Honey" to the stage. Amber P. Knight (Honey's real name) shares the pain of childhood abuse and the joy of regaining her confidence and pride in her body, resulting in this most open and revealing of art forms. Her mission is to pay forward her healing, introduce more people to the art of burlesque, and entertain the audience.
820 Massachusetts Ave.
Cambridge, MA 02139
Admission Info:
General Day and Time Info:
Accessibility Information: Currently, no accessibility information is available for this event.
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There are currently no reviews/comments for this event. Be the first to add a review/comment , and let folks know what you think!


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Stephen Gagliardi, Web Designer
Stephen joined The Ms. Foundation in May 2014 to fulfill the role of Web Designer. A recent transplant to the New York City area - hailing most recently from Pittsburgh – Stephen has also worked in the cities of Dallas, Raleigh, Boston, Cleveland, Milwaukee, and Chicago. Graduating with a BA from the University of Wisconsin in 2011, he holds a variety of degrees and certifications in the studio arts, digital design, web publishing, and project management. Past roles as a graphics and web designer have seen Stephen involved with a variety of industries ranging from retail and production to military and aerospace technologies. He sees his entry into the non-profit sector as an refreshing change of pace pertaining more closely to his interests and involvement with rights organizations.


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Advantages Of Using Spray Paint
Traditional painting is a time-honoured process that is applicable when you're remodelling your house, altering the appearance of furniture or even changing the colour of your doors and fences. But spray paint may be a better option due to some of the advantages it offers over traditional painting. If you haven't used spray paint in the past, here are some reasons to try it. It's Cleaner – Spray paint by virtue of it's directional and concentrated spraying offers you a much cleaner painting experience than...read more


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High School/Club: Competed for STGA of Endwell, N.Y., as a level 10 gymnast…placed second in vault at regionals and third in vault at state this year…a three-time JO National Qualifier…placed first on vault and floor exercise at the JO NIT… finished first at vault in the I Love New York Cup with a score of 9.9.
Personal: Binghamton, N.Y. native…daughter of Steven and Sherrie Yacalis.
Coach Joanne Bowers on Alexandra:
Preseason 2014: "Alex is another gymnast we thought would help us mostly on vault and floor, due to her leg power, but she is doing great on all 4 events right now and showing that she can be a force in the all-around. She has nice lines on bars and beam and has continued to show great progress there, so we are hopeful she can really help us this year in many ways."
At Signing: "Alex is a very powerful tumbler and vaulter and will help raise the level of difficulty on these events. She is very dynamic and has great quality dance and presentation. She is also a fierce competitor and has a way of turning it on for competitions," Bowers added. "We feel like her personality is one of her best qualities and she is so team oriented that she will be a great addition for us."
Yacalis's Career Bests


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Redwood Global Opens New Office in Ottawa
March 1st, 2013
Toronto - Redwood Global Inc., Canada's fastest growing technology and finance staffing agency, has opened a new office in Ottawa to better service its growing client base in the region.
"We are very excited to be launching an office in Ottawa given our deep expertise servicing many of Canada's largest public and privately held institutions," said Ryan Atkinson, Managing Director at Redwood Global. "We see this market playing a significant part in our strategic growth plans as we continue to expand our operations into other key regions across the country."
Caleb White, Vice President of Sales, Eastern Canada, will be responsible for managing the Ottawa office and growing the team and client base to support it. White has been a strong contributor since joining Redwood Global in 2010 and has deep roots in the Ottawa region.
"Ottawa is an amazing city with great people and a lot of opportunity," said White. "I'm really looking forward to offering a best-in-class recruitment experience to our clients and candidates in the Ottawa region."
Redwood Ottawa Office is located at 340 Albert St, Suite 1300, Ottawa ON, Tel: 613-317-1700
About Redwood Global
Redwood Global Inc. is a privately held, Canadian staffing company, founded in 2006. Services include contract and permanent placement, with a focus on representing the top technology and financial services professionals in Canada. For more information, please visit www.redwoodglobal.ca.


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A member of Crazy Horse, Neil Young's touring band, is speculating that the group's current tour may be their last. In an interview with Rolling Stone, guitarist Frank "Poncho" Sampedro says this may be the end of the road for the trio, who have been playing together since the late 1960s.
"I just think once it stops it's going to be kind of hard to get it rolling again," Sampedro told the mag.
"My gut tells me this is really the last tour. I hate saying their ages, but I'm 64 and I'm the baby of the band. I love playing and we're playing as good as we ever did, but at any time something could go down with any one of us."
Young and the band released two albums last year, Americana and Psychedelic Pill, after not releasing anything for almost a decade.
Copyright(c) 2013 RTTNews.com. All Rights Reserved


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Issue: Yuck #2
Creators: Johandson Rezende, James Andre, J Marc Schmidt, Dexter Cockburn, Ben Hutchins, Jacek Zabawa, Frank Candiloro, Matt Emery, Ed Kearsley, Antonia Glavic
Cover Artist: Jacek Zabawa
Editor: Mr. Slime
Publisher: Milk Shadow Books
Release Date: 2009
Pages: 36
Price: $4.00
ŌĆ£Like the undead cat, it came backŌĆ"the second issue of undergound comic anthology, Yuck! returns! Featuring art and writing by Jacek Zabawa, Johandson Rezende, James Andre, J Marc Schmidt, Dexter Cockburn, Ben Hutchings, Frank Candiloro, Matt Emery, Ed Kearsley and Antonia Glavic. Suitable for over 18's only!ŌĆ£
Artwork: 3.5 out of 5
Ah, another rendition of my favorite strange and twisted comic, HOORAY! So where do we start on the artwork, well I love the cover and when it comes to the interior work a few stand out, while I think a few were kind of weak. Now I know what to expect, so no I donŌĆÖt have super high standards here. I really enjoyed the look of ŌĆ£Doors of PerceptionŌĆØ, ŌĆ£Shits ŌĆśN GigglesŌĆØ and ŌĆ£Square of the CrossbonesŌĆØ. These three to me easily stand out a bt more than the others. Overall though this book just makes me so happy when it comes to a unique creative look.
Story: 4.0 out of 5
So once again I will make sure to say mature readers only. These stories are so much fun on all levels. Yes, they are easily on the adult level, but I kinda like that humor. So many laughs can be found in this tiny sized comic, and I always just want more when itŌĆÖs over. Since we are a horror site I will point out how much fun ŌĆ£Millennial MonstersŌĆØ was. Not what I ever expected to see of my classic monsters but just had me laughing.
Dying Breath: 4.0 out of 5
Yay! Another awesome issue of the worlds greatest Down-Underground Comic. I love the art work in this book and the way it relates to the stories. Every single short made me smile, even if it was in an uncomfortable way. So no it may not be for everyone, but it is for me, and for that I thank the creators. All I have left to really say is Yuck, now can I have some more?
If you would like to buy or know more about Yuck #2 you can find it at http://milkshadow.wordpress.com/
Comic Review: Yuck – Issue 2


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First photo taken on the Tieton road Rimrock area, The second photo was a sunset taken from North 57th street terrace Heights, third photo is from the Oak creek feeding station, end of season last chance to catch the Elk.
Local yakima pictures
By: MikeAdamsSubscribe Channel: Weather & Scenery Location: Yakima
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yes thats where I stop to pee every chance I get


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Deep Fried Bits
Do It And How
B&P Chat
More sorry cakes
I wonder if the "Sorry about the semen in your eye" is a cream cake?
The cake decorators really get some weirdo customers.
I'm not even angry.
I'm being so sincere right now.
Even though you broke my heart and killed me.
And tore me to pieces.
And threw every piece into a fire.
The cake is a lie.
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Added Feb 16, 2012
by My Starbrink
Umeå, Sweden
You're going to see me in this dress a lot this summer! I wanted a summer dress that had a vintage feel to it, and to make the look even more authentic i made a pair of matching gloves that really braught it together. I'm more than happy with this! (You can find my pattern for the gloves here )
Jun 7, 2012, 01.13 PMby shaptavajra
Gorgeous! I'm a beginner so I will shelve this till I get more skills, but I LOVE it. I would need a shrug to cover up some tattoos, anyone have a good combo? i can also knit (though I'm at the scarves/socks/hats/wristwarmer phase now).
Jun 1, 2012, 06.57 PMby gemmafloyd
matching gloves! how perfect!
Mar 1, 2012, 12.15 AMby biancak
So lovely! :) Thank you for the gloves pattern!
Feb 19, 2012, 09.10 PMby Sunny Cemcemoğlu
Oh please! Is there a pattern for the dress?
Feb 20, 2012, 08.07 AMby My Starbrink
No, sorry, I draped it directly onto the mannaquin. :)
Feb 19, 2012, 11.20 AMby so-sew-me
this screams betty draper. excellent work!
Feb 18, 2012, 08.14 AMby laurii
this is way too beautiful! love the gloves, they're so cute:) x
Feb 18, 2012, 07.26 AMby Ralf Schmitz
this outfit (dress AND gloves) is sensationel! i love everything about it. the look you created is so much like a DIOR outfit of the 1950th! AMAZING!!!
Feb 18, 2012, 07.20 AMby jaderbug
Super cute!
Feb 18, 2012, 03.05 AMby lennert
Very Mad Men… Looks beautiful!
Feb 17, 2012, 06.24 PMby barmaglot
So cute!
Feb 17, 2012, 12.10 PMby alessandra69
sei bellissima! puoi dirmi che modello hai usato per l'abito? vorrei farne uno…
Feb 18, 2012, 11.09 AMby My Starbrink
Grazie! Ho usato nessun modello, ho drappeggiata direttamente sul manichino. :)
Feb 17, 2012, 11.12 AMby Aslı Akgün
soo sweet :))
Feb 17, 2012, 10.00 AMby kihli
That reminds me a lot of Betty Draper! Love it! And I am also interested in the pattern for the gloves! :)
Feb 19, 2012, 02.29 PMby My Starbrink
Here's the pattern for the gloves! http://www.burdastyle.com/patterns/vintage-style-gloves
Good luck! :)
Feb 17, 2012, 04.03 AMby runningwithscissors1
What a great look! The gloves really pull it together. Very cool!
Feb 17, 2012, 03.21 AMby LilleLine
Beautiful! That is an great dress, so elegant, the fit is amazing and I love the gloves, Great job,
Feb 17, 2012, 02.53 AMby kelepso
Love those gloves! The 50's is one of my favorite periods. Great ensemble!
Feb 16, 2012, 10.21 PMby janene
Really beautiful. Fantastic fit. And the colour really suits you. It goes without saying that the matching gloves are the icing on the cake. And I would indeed be interested if you had a pattern to share. :-)
Feb 19, 2012, 02.29 PMby My Starbrink
Here's the pattern for the gloves! :) http://www.burdastyle.com/patterns/vintage-style-gloves
Feb 22, 2012, 07.54 AMby janene
Thank you so much My Starbrink. I will have such fun with these… when I get some time! :-)
Feb 16, 2012, 10.20 PMby MaryBeverly
Completely lovely! The matching gloves are a genius touch. Well done!
Feb 16, 2012, 09.14 PMby G-A-
very pretty and I love the coordinating gloves. Did you use a pattern for making the gloves? If so, would you mind telling me which?
Feb 16, 2012, 09.25 PMby My Starbrink
I'll scan the pattern for the gloves and post it as soon as i can :)
Feb 17, 2012, 07.31 AMby laikadoll
Feb 19, 2012, 02.30 PMby My Starbrink
I've uploaded the pattern for the gloves :) you can find it here: http://www.burdastyle.com/patterns/vintage-style-gloves
Feb 20, 2012, 07.04 PMby G-A-
Thanks so much for uploading the pattern
Feb 16, 2012, 09.06 PMby joost52
Wow, you look awesome. Those matching gloves are just jaw-dropping :)
Feb 16, 2012, 07.59 PMby Jodi Wade
Matching gloves! Love!
Feb 16, 2012, 05.32 PMby Miriamsyr
Beautiful! Did you use a pattern for the gloves? They are gorgeous!
Feb 16, 2012, 08.35 PMby My Starbrink
Thank you! I used a pattern for the gloves, but had to alter it quite a bit for it to work out. I'll try to share it here! :)
Feb 19, 2012, 02.31 PMby My Starbrink
Here's the pattern: http://www.burdastyle.com/patterns/vintage-style-gloves :)
Feb 16, 2012, 04.31 PMby libra-s
Very pretty dress! The gloves are amazing!!!
Feb 16, 2012, 03.16 PMby Adriana Orozco
What a lovely dress!!! the simplysity of the design is dangerous……because to look as nice as it looks… does nees a perfect fitting and a crisp finishing…..and it has it all!!! It looks wonderfull on you, and the glove making……………really amazing!!!!
Feb 16, 2012, 03.09 PMby Jeyco
i'm totally charmed with your dress and the groves. you look really lovely in it!
Feb 16, 2012, 02.20 PMby Lolibraun
So elegant, I absolutely love it.
Feb 16, 2012, 02.08 PMby omgdora
Looks well-made and very beautiful on you. I love your style!
Feb 16, 2012, 01.48 PMby apfelbluete
Add to Favorites 39 people added it
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The oversized shape has a cool bell shaped silhouette with a wide body and fitted sleeves
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After missing so many days of work during the past nine months or so I worry about losing the job I have. Being a 49 year old I feel I
have no other prospects. So, I need to keep the dead-end job that offers no
insurance, and no support for my aliment. The stress of missing so many days of
work is not limited to just losing my job but, also the money to buy my
medications, test strips, syringes, etc... Since I am a part-time bartender and
most of my income is from gratuities, and not by the minimum wage I am paid. So,
my question is what can I do to protect myself, and what options do I have?
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