text:
Perry et al v. Schwarzenegger et al
Filing 314
NOTICE by Martin F. Gutierrez, Dennis Hollingsworth, Mark A. Jansson, Gail J. Knight, ProtectMarriage.com - Yes on 8, A Project of California Renewal, Hak-Shing William Tam of Filing of Privilege Log (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit)(Cooper, Charles) (Filed on 12/21/2009)
Perry et al v. Schwarzenegger et al Doc. 314 Case3:09-cv-02292-VRW Document314 Filed12/21/09 Page1 of 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 COOPER AND KIRK, PLLC Charles J. Cooper (DC Bar No. 248070)* email@example.com David H. Thompson (DC Bar No. 450503)* firstname.lastname@example.com Howard C. Nielson, Jr. (DC Bar No. 473018)* firstname.lastname@example.com Nicole J. Moss (DC Bar No. 472424)* email@example.com Jesse Panuccio (DC Bar No. 981634)* firstname.lastname@example.com Peter A. Patterson (Ohio Bar No. 0080840)* firstname.lastname@example.com 1523 New Hampshire Ave. N.W., Washington, D.C. 20036 Telephone: (202) 220-9600, Facsimile: (202) 220-9601 LAW OFFICES OF ANDREW P. PUGNO Andrew P. Pugno (CA Bar No. 206587) email@example.com 101 Parkshore Drive, Suite 100, Folsom, California 95630 Telephone: (916) 608-3065, Facsimile: (916) 608-3066 ALLIANCE DEFENSE FUND Brian W. Raum (NY Bar No. 2856102)* firstname.lastname@example.com James A. Campbell (OH Bar No. 0081501)* firstname.lastname@example.com 15100 North 90th Street, Scottsdale, Arizona 85260 Telephone: (480) 444-0020, Facsimile: (480) 444-0028 ATTORNEYS FOR DEFENDANT-INTERVENORS DENNIS HOLLINGSWORTH, GAIL J. KNIGHT, MARTIN F. GUTIERREZ, HAK-SHING WILLIAM TAM, MARK A. JANSSON, and PROTECTMARRIAGE.COM Ł YES ON 8, A PROJECT OF CALIFORNIA RENEWAL * Admitted pro hac vice UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA KRISTIN M. PERRY, SANDRA B. STIER, PAUL T. KATAMI, and JEFFREY J. ZARRILLO, Plaintiffs, v. ARNOLD SCHWARZENEGGER, in his official capacity as Governor of California; EDMUND G. BROWN, JR., in his official capacity as Attorney General of California; MARK B. HORTON, in his official capacity as Director of the DEFENDANT-INTERVENORS' NOTICE OF FILING OF PRIVILEGE LOG CASE NO. 09-CV-2292 VRW CASE NO. 09-CV-2292 VRW Chief Judge Vaughn R. Walker DEFENDANT-INTERVENORS' NOTICE OF FILING OF PRIVILEGE LOG Dockets.Justia.com Case3:09-cv-02292-VRW Document314 Filed12/21/09 Page2 of 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 California Department of Public Health and State Registrar of Vital Statistics; LINETTE SCOTT, in her official capacity as Deputy Director of Health Information & Strategic Planning for the California Department of Public Health; PATRICK O'CONNELL, in his official capacity as Clerk-Recorder for the County of Alameda; and DEAN C. LOGAN, in his official capacity as Registrar-Recorder/County Clerk for the County of Los Angeles, Defendants, and PROPOSITION 8 OFFICIAL PROPONENTS DENNIS HOLLINGSWORTH, GAIL J. KNIGHT, MARTIN F. GUTIERREZ, HAKSHING WILLIAM TAM, and MARK A. JANSSON; and PROTECTMARRIAGE.COM Ł YES ON 8, A PROJECT OF CALIFORNIA RENEWAL, Defendant-Intervenors. Additional Counsel for Defendant-Intervenors ALLIANCE DEFENSE FUND Timothy Chandler (CA Bar No. 234325) email@example.com 101 Parkshore Drive, Suite 100, Folsom, California 95630 Telephone: (916) 932-2850, Facsimile: (916) 932-2851 Jordan W. Lorence (DC Bar No. 385022)* firstname.lastname@example.com Austin R. Nimocks (TX Bar No. 24002695)* email@example.com 801 G Street NW, Suite 509, Washington, D.C. 20001 Telephone: (202) 393-8690, Facsimile: (202) 347-3622 * Admitted pro hac vice DEFENDANT-INTERVENORS' NOTICE OF FILING OF PRIVILEGE LOG CASE NO. 09-CV-2292 VRW Case3:09-cv-02292-VRW Document314 Filed12/21/09 Page3 of 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Cases Cases TABLE OF CONTENTS Page TABLE OF AUTHORITIES ................................................................................................................ i NOTICE OF FILING........................................................................................................................... 1 TABLE OF AUTHORITIES Page Perry v. Schwarzenegger, No. 09-17241 slip op. (9th Cir. Dec. 11, 2009) ........................... 7-8, 10-12 i DEFENDANT-INTERVENORS' NOTICE OF FILING OF PRIVILEGE LOG CASE NO. 09-CV-2292 VRW Case3:09-cv-02292-VRW Document314 Filed12/21/09 Page4 of 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 At the pre-trial hearing on December 16, 2009, the Court requested that Defendant-Intervenors ("Proponents") submit a log of documents that are responsive to Plaintiffs' Requests for Production but privileged under the First Amendment or another privilege. Accordingly, Proponents hereby respectfully submit the attached privilege log cataloguing documents privileged under the First Amendment, as attorney-client communications, and/or as attorney work-product. As explained at the December 16, 2009 hearing, this log identifies privileged documents that are responsive to Plaintiffs' discovery requests as those requests were limited by the Court's October 1 and November 11, 2009 orders. See Doc # 214; Doc # 252. Based on Plaintiffs' representations at the December 16 hearing and in correspondence, it appears that they are now seeking large categories of documents that this Court held were not discoverable on relevance and/or responsiveness grounds in the October 1 and November 11 orders. Many of these documents are subject to Proponents' First Amendment privilege assertions, but Proponents were not required to log them (and they are not included in the attached log) because this Court's October 1 and November 11 orders had placed them outside the scope of permissible discovery. We respectfully submit that Proponents would be severely and unfairly prejudiced were the Court to reverse course at this late date--just three weeks before the commencement of trial--and require that documents previously ruled not discoverable on non-privilege grounds be added to the privilege log. In the pages that follow, we detail the relevant procedural history to provide the Court with a clear understanding of what has already been produced and what remains potentially at issue, in light of what has already been decided, both by this Court and by the Ninth Circuit. 1. In their August 17 case management statement, Plaintiffs stated that they would seek document and deposition discovery into "Prop 8's genesis, drafting, strategy, objectives, advertising, campaign literature, and [Proponents'] communications with each other, supporters, and donors." 1 DEFENDANT-INTERVENORS' NOTICE OF FILING OF PRIVILEGE LOG CASE NO. 09-CV-2292 VRW Case3:09-cv-02292-VRW Document314 Filed12/21/09 Page5 of 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Doc # 157 at 12. Proponents objected to this sweeping discovery from the start, see, e.g., Doc # 159 at 9, and at the August 19 case management hearing "urge[d] the Court to give us an opportunity to fight this out in briefing to the Court before" discovery commenced. Hr'g of Aug. 19, 2009, Tr. at 60. Counsel for Plaintiffs opposed such briefing, assured the Court that Plaintiffs would not "have a problem ... in limiting discovery," represented that Plaintiffs "would not be inquiring into" the "subjective, unexpressed motivations" of Proponents, and requested that the Court provide the parties the opportunity to "work out among themselves" any discovery disputes about whatever "gray area" remained. Id. at 63-64. The Court agreed and allowed discovery to go forward without initial briefing as to the permissible scope of discovery. 2. Two days later, Plaintiffs propounded sweeping document requests that sought virtually all documents in Proponents' possession. See Doc # 187-3. There was no "gray area" because Plaintiffs sought everything. Proponents objected--on First Amendment, other privilege, relevance, burden, and other grounds--to producing many of the documents implicated by Plaintiffs' request. See, e.g., Doc # 187-4 at Č 2 (attorney-client and work-product privilege objection), ČČ 4 & 8 (First Amendment privilege objection), Č 5 (objecting to producing documents equally available from public sources or third parties), Č 6 (relevance objection). Proponents agreed to produce (and have produced) documents that they distributed to large swaths of the electorate, including discrete voter groups. See Doc # 197 at 6; Doc # 214 at 2. That is, both the individual Proponents and Protectmarriage.com have produced the materials they distributed to voters as voters--television advertisements, radio advertisements, newspaper advertisements, press releases, posters, flyers, event notification flyers, website content, blast emails, and even PowerPoint presentations delivered to small church congregations. To date, Proponents have reviewed in excess of 90,000 documents and have provided Plaintiffs with approximately 2,000 documents constituting communications to voter 2 DEFENDANT-INTERVENORS' NOTICE OF FILING OF PRIVILEGE LOG CASE NO. 09-CV-2292 VRW Case3:09-cv-02292-VRW Document314 Filed12/21/09 Page6 of 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 groups, large and small. Plaintiffs have listed many of these documents on their exhibit list. Doc # 283-1. 3. But with respect to production objectionable on First Amendment, relevance, and burden grounds, Proponents moved on September 15--well before responses to Plaintiffs' discovery requests were due--for a protective order limiting the scope of discovery (with respect to both documents and testimony). See Doc # 187 (motion); Doc # 187-14 (proposed order). Proponents objected to "Plaintiffs' demands for disclosure of Proponents' nonpublic and/or anonymous communications, including (but not limited to) the Proponents' communications targeted to (and/or received from) (i) persons who donated money to or otherwise volunteered to assist the Prop. 8 campaign; (ii) agents and contractors of the campaign, including political consultants; and even (iii) family, friends, and colleagues." Doc # 197 at 6 (footnote omitted). Proponents highlighted as an example Plaintiffs' Request No. 8, which sought "all correspondence Defendant-Intervenors may have had with any `third party' bearing any relationship to Proposition 8 whatsoever." Doc # 187 at 8. Proponents also explained and objected that Plaintiffs "[o]ther Requests are similarly sweeping." Id. at 8 n.1. Plaintiffs refused to narrow their requests and opposed Proponents' motion in full. Doc # 191. 4. On October 1, this Court "granted in part and denied in part" Proponent's motion for a protective order. Doc # 214 at 17. The Court explained that, while "communications ... about messages" to the electorate "could fairly lead to admissible evidence illuminating the messages disseminated to voters," "`virtually every communication made by anyone included in or associated with Protect Marriage' cannot be relevant." Id. at 15-16. Accordingly, the Court held that "Plaintiffs' request no 8, currently encompassing any communication between proponents and any third party, is simply too broad." Id. at 16. The Court held that "discovery directed to uncovering whether proponents harbor private sentiments that may have prompted their efforts is simply not 3 DEFENDANT-INTERVENORS' NOTICE OF FILING OF PRIVILEGE LOG CASE NO. 09-CV-2292 VRW Case3:09-cv-02292-VRW Document314 Filed12/21/09 Page7 of 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 relevant." Id. at 16. The Court also held that "[c]ommunications that took place after the election may ... be relevant if they are connected in some way to the pre-election messages conveyed to the voters." Id. (emphasis added). The Court flatly concluded: "discovery not sufficiently related to what the voters could have considered is not relevant and will not be permitted." Id. In directing the Plaintiffs to redraft Request No. 8--which, as the Court noted, sought communications with "any third party"--the Court explained that a redrafted request would be appropriate to the extent it calls for (1) communications by and among proponents and their agents ... concerning campaign strategy and (2) communications by and among proponents and their agents concerning messages to be conveyed to voters, without regard to whether the voters or voter groups were viewed as likely supporters or opponents or undecided about Prop 8 and without regard to whether the messages were actually disseminated or merely contemplated. In addition, communications by and among proponents with those who assumed a directorial or managerial role in the Prop 8 campaign, like political consultants or Protectmarriage.com's treasurer or executive committee, among others, would appear likely to lead to discovery of admissible information. Id. at 17. 1 5. At a telephonic hearing on November 2, 2009, the Court ruled that Proponents may submit for in camera review "a limited number of those documents" Proponents maintain are privileged under the First Amendment from disclosure in response to Plaintiffs' discovery requests. Hr'g of Nov. 2, 2009, Tr. at 42-43. See also Doc # 247 (minute order). Following that in camera review process, the Court issued an order on November 11 that clarified that "Plaintiffs eighth document request is likely to lead to the discovery of admissible evidence to the extent the evidence relates to messages or themes conveyed to California voters or is otherwise likely to lead to this relevant information." Doc # 252 at 3. The Court explained that only 21 of the 60 documents submitted had to be produced. The other 39 documents were "either not responsive to plaintiffs' request or are so attenuated from the themes or messages conveyed to voters that they are, for On October 5, Plaintiffs, "[p]ursuant to the Court's Order," propounded a "revised request for production number 8." Doc # 220-1 at 5. Plaintiffs did not then contend that the revised request seeks, and Proponents have not read the revised request to seek, more than what 4 DEFENDANT-INTERVENORS' NOTICE OF FILING OF PRIVILEGE LOG CASE NO. 09-CV-2292 VRW 1 Case3:09-cv-02292-VRW Document314 Filed12/21/09 Page8 of 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 practical purposes, not responsive." Id. at 4. The Court deemed nondiscoverable documents that "say nothing about campaign messages or themes to be conveyed to the voters," including documents that "discuss topics that might relate to messages ultimately adopted or considered by the campaign" but do not "discuss voters or their potential reactions." Id. at 6, 8. The Court protected from disclosure, for example, documents and information relating to: "fundraising strategy, polling information or hiring decisions"; "the mechanics of operating a campaign"; "the petition drive to qualify Prop 8 for the ballot"; "internal campaign strategy"; the "mechanics of the campaign's internal structure"; "a campaign contribution"; "polling numbers," "poll results," and "musings regarding poll results"; "volunteer coordination and organization"; a "specific volunteer"; "the campaign's structure and arrangements with other entities"; "draft poll questions"; "potential donors"; "recruitment of a potential staff member"; fundraising letters; "volunteer organization"; "meetings with major donors"; "mechanics of petition drives"; "mechanics of operating a phone bank"; "a supporter ... not officially associated with the campaign"; internal discussions about "recent articles about gay marriage and its effects"; discussions about "proposed language for Prop 8 [that is] at most marginally pertinent to advertising strategy"; "a potential volunteer consultant and ways the volunteer might aid campaign strategies"; discussions about "disseminating a message but not [about] the message itself"; "the appropriate language to use for the text of Prop 8"; "a targeted fundraising drive." Id. at 4, 6-9. 6. The upshot of the October 1 and November 11 orders was that Proponents' discovery obligations with respect to communications with third parties--aside from communications to voters as voters--were limited in two significant respects. First, only communications by and among Proponents, the managers and directors of Protectmarriage.com, and their agents were discoverable. Second, only communications concerning messages to be conveyed to voters were discoverable. Other communications--for example, a communication with "a supporter ... not officially associated with the campaign" and "the campaign's structure and arrangements with other entities," Doc # 252 at 6-9--were not discoverable. Thus, under this Court's rulings, Proponents were not required to produce, or log as privileged, countless e-mails and other communications unrelated to campaign is permitted under the Court's orders. 5 DEFENDANT-INTERVENORS' NOTICE OF FILING OF PRIVILEGE LOG CASE NO. 09-CV-2292 VRW Case3:09-cv-02292-VRW Document314 Filed12/21/09 Page9 of 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 messaging and advertising strategy. Likewise, it follows that Proponents and their agents were not required to testify about communications and topics that were not discoverable through requests for production. 7. Proponents appealed the October 1 and November 11 orders "to the extent they deny Defendant-Intervenors' Motion for a Protective Order (Doc # 187) and/or require the production of documents asserted as privileged under the First Amendment." Doc # 253 at 3. See also Doc # 222. Specifically, Proponents challenged this Court's ruling that confidential communications among Proponents and their agents (at the directorial or managerial level) concerning campaign messaging must be produced. Proponents did not challenge (in either this Court or in the Ninth Circuit) Plaintiffs' request for television advertisements, flyers, blast e-mails, and other communications that went to the public (although Proponents have consistently maintained that these public materials, too, are irrelevant to voter intent). And, of course, Proponents did not challenge this Court's October 1 and November 11 order to the extent they limited the scope of discoverable materials. Likewise, Plaintiffs did not cross appeal these orders to the extent they granted Proponents' motion and limited the scope of "relevant" and "appropriate" discovery at issue. Indeed, during oral argument before the Ninth Circuit, Plaintiffs' counsel relied upon the limitations in those orders in urging the Court of Appeals to reject Proponents' appeal on the internal communications. See Recording of Oral Argument, Perry v. Schwarzenegger, No. 09-17241 (Dec. 1, 2009), available at http://www.ca9.uscourts.gov/media/view_subpage.php?pk_id=0000004515 (this Court did "a very commendable job of coming up with a standard in th[e] November 11 order" of what is "not to be produced"; the November 11 order "la[id] down the standards that would govern the balancing going forward as to documents"). Thus, the Ninth Circuit had before it only the twenty-one in camera documents this Court ordered produced--and not the thirty-nine documents this Court held 6 DEFENDANT-INTERVENORS' NOTICE OF FILING OF PRIVILEGE LOG CASE NO. 09-CV-2292 VRW Case3:09-cv-02292-VRW Document314 Filed12/21/09 Page10 of 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 were protected from discovery. See Order, Perry v. Schwarzenegger, No. 09-17241 (9th Cir. Nov. 25, 2009). 8. Accordingly, in its opinion, the Ninth Circuit recounted the production called for in the October 1 and November 11 orders, Perry v. Schwarzenegger, No. 09-17241, slip op. at 8-9 (Dec. 11, 2009), and explicitly stated: "The parties ... disagree about what types of evidence may be relied upon to demonstrate voter intent. These issues are beyond the scope of this appeal. We assume without deciding that the district court has decided these questions correctly," id. at 34 n.11. See also id. at 12 ("assum[ing] without deciding" that this Court was "correct" in its rulings on "whether plaintiffs may rely on certain types of evidence to prove that Proposition 8 was enacted for an improper purpose"). In other words, the Ninth Circuit did not have before it, and left in place as law of the case, this Court's orders restricting the scope of relevant and appropriate discovery and granting Proponents' motion for a protective order to that extent. With respect to the 21 documents and like materials that this Court had ordered produced, the Ninth Circuit held that Proponents' First Amendment privilege barred discovery of those materials. The Court explained that, "bearing in mind other sources of information" and that "[t]he information plaintiffs seek is attenuated from the issue of voter intent," Plaintiffs "have not shown a sufficiently compelling need for the information" at issue. Id. at 36-37. 9. This procedural history has resulted in the privilege log filed herewith. The October 1 order responded to discovery that sought "`virtually every communication made by anyone included in or associated with Protect Marriage'" (including communications with "any third party') and explained that only a limited universe of such communications could be considered "relevant" or "appropriate" in this case. Doc # 214 at 15-17. The documents Proponents submitted for in camera review were selected because Proponents believed they fell within the metes and bounds of what the October 1 order deemed as "relevant" and "appropriate." The November 11 order made clear that a 7 DEFENDANT-INTERVENORS' NOTICE OF FILING OF PRIVILEGE LOG CASE NO. 09-CV-2292 VRW Case3:09-cv-02292-VRW Document314 Filed12/21/09 Page11 of 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 nearly two-thirds of those documents were not, in fact, responsive to what the Court deemed "relevant" and "appropriate" areas for inquiry in discovery. Accordingly, the Court stated in the November 11 order: "[T]he court hopes that the foregoing affords proponents sufficient and specific enough guidance to cull their inventory of documents and other materials in order to respond to plaintiffs' document request." Doc # 252 at 9. The Ninth Circuit held that these materials are privileged from disclosure on First Amendment grounds, but that "some form of a privilege log is required." Perry, slip op. at 7 n.1. The log submitted herewith thus catalogues the documents that this Court has deemed "relevant" and "appropriate" for discovery, but that the Ninth Circuit has deemed privileged from disclosure under the First Amendment. 10. This procedural history has also dictated the course of depositions. Despite this Court's and the Ninth Circuit's rulings on the permissible scope of discovery (on relevance or privilege grounds), Plaintiffs have sought through testimony at depositions information they are barred from seeking through production of documents. Compare, e.g., Doc # 214 at 16 ("[D]iscovery directed to uncovering whether proponents harbor private sentiments that may have prompted their efforts is simply not relevant."), with Dep. of W. Tam, Tr. 49:11-13 ("Was your goal in writing this letter to encourage people to vote in favor of Proposition 8?") (attached as Ex. 2). Accordingly, Proponents' counsel objected at depositions to the many questions that seek precisely the information that this Court and the Ninth Circuit have deemed nondiscoverable. 11. Unfortunately, despite the protracted litigation over this issue in both this Court and in the Ninth Circuit, the discovery dispute does not appear to be at an end. As has been true throughout the discovery period, Plaintiffs are yet again altering their demands, often from day to day and in violation of controlling orders in this case. 2 It now appears to be Plaintiffs' position that they are Compare Hr'g of Aug. 19, 2009 Tr. 64 (representing that Plaintiffs "would not be inquiring into" "subjective, unexpressed motivations" "because [Plaintiffs] do not believe that those would actually go to the issues that [they] are presenting to the Court"), and Doc # 214 at 16 8 DEFENDANT-INTERVENORS' NOTICE OF FILING OF PRIVILEGE LOG CASE NO. 09-CV-2292 VRW 2 Case3:09-cv-02292-VRW Document314 Filed12/21/09 Page12 of 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 entitled to production, in response to Request Nos. 1 or 6, of precisely the same materials this Court held were not discoverable under the original or revised Request No. 8. Request No. 1 seeks documents "distributed to voters" and Request No. 6 seeks all documents "prepared for public distribution." Doc # 187-3 at 5. Plaintiffs now contend that these requests encompass (1) all communications, even one-on-one communications to any voter and (2) any documents distributed by a Defendant-Intervenor to anyone outside what Plaintiffs call the campaign "control group"--i.e., "the group identified in [Plaintiffs] revised document request number 8." Hr'g of Dec. 16, 2009, Tr. (rough) at 30:13; Ltr. from E. Dettmer to C. Cooper (Dec. 14, 2009) at 1 (attached as Ex. 3). 12. There are at least two problems with this position. First, it converts Request Nos. 1 and 6 into original Request No. 8--the very request that this Court ruled was "simply too broad." Doc # 214 at 16. That is, under Plaintiffs' newly asserted position, the "voters" in Request No. 1 and the "public" in Request No. 6 include any person residing in California who was not part of the Protectmarraige.com "control group." In other words, it appears Plaintiffs now demand under Requests Nos. 1 and 6 "[a]ll documents ... between [Proponents] and any third party"--i.e., exactly what original Request No. 8 sought. Id. at 2. 3 But this Court found the information sought by original Request No. 8 to be overly broad, burdensome, and largely irrelevant, and it directed Plaintiffs to ("discovery directed to uncovering whether proponents harbor private sentiments that may have prompted their efforts is simply not relevant"), with Dep. of W. Tam, Tr. 49:11-13 ("Was your goal in writing this letter to encourage people to raise funds for passing Proposition 8?") (attached as Ex. 2). Compare Doc # 187-6 at 2 ("I am writing to confirm that Plaintiffs' First Set of Requests for Production does not seek internal communications among and between your clients regarding Proposition 8 and the related political campaign."), with Doc # 220-1 at 5 (seeking "communications ... between ... Defendant-Intervenors"). 3 In a letter dated December 15, 2009 (attached as Ex. 4), Proponents asked Plaintiffs to "please clarify" whether they were seeking under these requests what they are barred from seeking under Request No. 8. To date, Plaintiffs have offered no response or clarification. Similarly, in a letter dated December 10, 2009 (attached as Ex. 5), Proponents responded to discovery concerns raised by Plaintiffs in an earlier letter--specifically, to concerns over a handful of documents identified by Plaintiffs. Having provided a full explanation of why those documents were not produced, Proponents have heard nothing further from Plaintiffs on this front despite Proponents' representation that "[w]e are happy to address any legitimate, additional concerns Plaintiffs may have." 9 DEFENDANT-INTERVENORS' NOTICE OF FILING OF PRIVILEGE LOG CASE NO. 09-CV-2292 VRW Case3:09-cv-02292-VRW Document314 Filed12/21/09 Page13 of 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 revise the request according to its instructions. See Doc # 214 at 15-16 ("Plaintiffs request no 8, currently encompassing any communication between proponents and any third party, is simply too broad."). As the Court noted, "no amount of discovery could corral all of the information on which voters cast their ballots on Prop 8," and thus the Court restricted the scope of permissible discovery in the October 1 and November 11 orders. Id. at 15. And with respect to Plaintiffs' revised Request No. 8, the Ninth Circuit held "[w]e are not presented here with a carefully tailored request for the production of highly relevant information that is unavailable from other sources that do not implicate First Amendment associational interests." Perry, slip. op. at 37 n.13. Plaintiffs cannot seriously contend that reading Requests Nos. 1 and 6 to encompass everything original Request No. 8 encompassed is such a "carefully tailored" request. Indeed, if the information at issue before the Ninth Circuit--communications among campaign leaders about messaging and advertising strategy--was "attenuated from the issue of voter intent," id. at 36-37, then it follows a fortiori that the materials now demanded by Plaintiffs are utterly irrelevant. Second, Plaintiffs' current position necessarily suggests that Proponents' First Amendment association rights are limited to communications with participants in the specifically denominated and legally recognized campaign committee, and communications with any other known political associates are not protected by the First Amendment. For example, if Gail Knight or Dr. William Tam--who, although official proponents, had virtually nothing to do with Protectmarriage.com's campaign--nonetheless worked with a neighbor or family member to draft a flyer in favor of Proposition 8, it appears to be Plaintiffs' contention that private communications about that flyer (as opposed to the flyer itself) receive no First Amendment protection. So, too, for any members of the ACLU who might have engaged in private associational and political speech outside the confines of 10 DEFENDANT-INTERVENORS' NOTICE OF FILING OF PRIVILEGE LOG CASE NO. 09-CV-2292 VRW Case3:09-cv-02292-VRW Document314 Filed12/21/09 Page14 of 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 that particular organization. Turning their prior representations on their head, 4 Plaintiffs now appear to argue that individuals receive less protection than official groups. 5 13. There is no support for Plaintiffs' position in the caselaw, and the Ninth Circuit here has made clear that "compelled disclosure of political affiliations and activities" must be justified by a compelling state interest, that the "existence of a prima facie case [of privilege] turns not on the type of information sought, but on whether disclosure of the information will have a deterrent effect on the exercise of protected activities," that "[i]mplicit in the right to associate with others to advance one's shared political beliefs is the right to exchange ideas and formulate strategy and messages, and to do so in private," and that "[a]ssociations, no less than individuals, have the right to shape their own messages." Perry, slip op. at 24, 29-30, 31 n.9 (emphasis added). The Court credited Proponent Mark Jansson's statement that "if the personal, non-public communications [he] ... had regarding this ballot initiative" are disclosed through compulsory process, his speech will be chilled. Id. at 32 (quotation marks omitted). Mr. Jansson, and some of the other Proponents, engaged in such nonpublic communications not only within the confines of some "control group," but also with known political associates who banded together to support Proposition 8. Those communications See Recording of Oral Argument, Perry v. Schwarzenegger, No. 09-17241 (Dec. 1, 2009) (Plaintiffs counsel representing that internal communications of Defendant-Intervenors are differently situated than those of other persons and groups because "here these are the official proponents" and arguing that "these are the official proponents of proposition 8, they took an official status, they drafted proposition 8. They then subjected themselves to disclosure laws in California. They subjected themselves to disclosure their identity, their disclosures in their responsibilities that they took. So they're in a very different position then the organizations you mentioned and Mrs. McIntyre, in the McIntyre case."). 5 Third, if Plaintiffs are correct that they are entitled to production under other requests of what they were barred from obtaining under Request No. 8, then it would follow that Plaintiffs are entitled under Request No. 3, for example, to Protectmarriage.com's internal drafts of television ads--for that request seeks "all versions" of such ads, including internal drafts that were never distributed outside a "control group." See Doc # 187-3 at 5. Plaintiffs have failed to explain how this request, and other similar requests, would not violate the Ninth Circuit's ruling. See Perry, slip op. at 30 (recognizing individual and associational right to "formulate strategy and messages, and to do so in private"); Doc # 252 at 4 (showing that one of the documents protected by the Ninth Circuit's opinion "discusses edits to a television advertisement"). 11 DEFENDANT-INTERVENORS' NOTICE OF FILING OF PRIVILEGE LOG CASE NO. 09-CV-2292 VRW 4 Case3:09-cv-02292-VRW Document314 Filed12/21/09 Page15 of 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 are no less protected, and no more public (or made "to voters") than those that took place between and among the "control group." 14. The Ninth Circuit has already drawn the line between what is and is not within the First Amendment privilege it recognized, and its line differs markedly from that suggested by Plaintiffs. The Court held that Proponents could not "avoid disclosure of broadly disseminated material by stamping them `private' and claiming an `associational bond' with large swaths of the electorate." Id. at 36, n.12. Proponents have adhered to this line, and have produced all communications that went to the electorate at large or to discrete groups of voters, while withholding private communications to their known political associates, whom they communicated with not to implore them to vote, but in a joint (albeit unofficial) effort to campaign for or discuss Prop 8. 15. If the Court were to now withdraw the relevance/responsiveness limitations set forth in the October 1 and November 11 orders, many of the additional documents Plaintiffs seek would still not be discoverable because they fall within the heartland of the privilege recognized by the Ninth Circuit. Nevertheless, Proponents would be severely prejudiced by such a ruling because it would entail an exponential increase in the size of the privilege log. For example, if the limitations in the November 11 order were removed, Proponents would have to re-review and potentially log upwards of 10,000 additional documents. And if the limitations set out in the October 1 order were removed, Proponents would have to re-review and log upwards of an additional 30,000 documents. It has been our experience thus far in this case that, depending on the nature of the documents at issue, an attorney can review and log ten to twenty-five documents per hour. As we head into trial, the number of attorneys and legal assistants available for this task will diminish and the task may be all but impossible. Indeed, even if Proponents devoted three attorneys working full time to reviewing and logging 10,000 additional documents, it would not be possible to accomplish the task before the start of trial. 12 DEFENDANT-INTERVENORS' NOTICE OF FILING OF PRIVILEGE LOG CASE NO. 09-CV-2292 VRW Case3:09-cv-02292-VRW Document314 Filed12/21/09 Page16 of 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 16. The prejudice to Proponents would be compounded to the extent the Court contemplates the continuation of litigation concerning these discovery disputes after the commencement of trial. While Plaintiffs appear to have an almost limitless reservoir of lawyers from two of the Nation's largest law firms, Proponents' resources are far more limited, and necessarily must be devoted to presenting Proponents' case at trial. Especially when one considers Plaintiffs' candid admission that these materials are not central to their case--indeed, Plaintiffs' counsel actually suggested that "there would be a way to ensure that any ruling that was favorable to us did not rise or fall on those documents" so as to avoid any appellate exposure that otherwise might arise, Hr'g of Dec. 16, 2009, Tr. (rough) at 44--Proponents should not be forced to divert their attention from the presentation of their case on the merits to further defense of the their First Amendment rights. If the discovery lines are to change at this late date, then the only alternative consistent with fair proceedings is postponement of trial until these discovery matters are settled. 17. Moreover, it is not only Plaintiffs who have relied on the relevance and First Amend- ment rulings to date. As has been made known to this Court and the Ninth Circuit, both Plaintiffs and Proponents have subpoenaed numerous third-party groups for the same types of documents Plaintiffs have sought from Proponents. If the lines for relevance and production are to change again, all of those groups will have to re-review and produce or log their potentially massive inventory of internal documents. And if the Court does deem these communications relevant, Proponents will be severely prejudiced in presenting their case absent the ability to collect and review these documents prior to trial. 6 At the December 16 hearing, Plaintiffs raised the issue of disclosure of the identity of the Doe member of the Protectmarriage.com ad hoc executive committee. As Proponents' counsel explained to the Court, the Doe member is represented by separate counsel and is asserting his privilege claim independently through that counsel. We have now been informed by Doe's counsel that he responded to Plaintiffs' third party subpoena on November 9, 2009, with an offer to negotiate the terms of document production and a deposition. Doe's counsel further informs us that the two parties are now negotiating the issue of disclosure of Doe's identity. 13 DEFENDANT-INTERVENORS' NOTICE OF FILING OF PRIVILEGE LOG CASE NO. 09-CV-2292 VRW 6 Case3:09-cv-02292-VRW Document314 Filed12/21/09 Page17 of 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Until such time as those negotiations are complete or Doe's privilege claim is litigated, we are submitting the attached privilege log with Doe's name identified as "Doe Executive Committee Member." 14 DEFENDANT-INTERVENORS' NOTICE OF FILING OF PRIVILEGE LOG CASE NO. 09-CV-2292 VRW Dated: December 21, 2009 Respectfully submitted, By: /s/Charles J. Cooper Charles J. Cooper COOPER AND KIRK, PLLC ATTORNEYS FOR DEFENDANTS-INTERVENORS


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Are Coffee and Caffeine Safe for Those With Type-2 Diabetes?
Scientific studies of the effects of coffee and/or caffeine in people with diabetes have given contradictory results, and whether it's reasonable for someone with diabetes to continue to drink coffee, or switch to decaffeinated coffee, or quit, is a matter of opinion. Major authorities, such as the American Diabetes Association, have not issued recommendations.
The benefits
One of the compounds in coffee, called chlorogenic acid, has been shown in animal studies to lower blood sugar. Coffee's also rich in quinides, compounds that make the body more sensitive to insulin. These could be among the reasons why regular coffee drinkers seem to have a lower risk of developing diabetes. A survey of 80,000 women conducted by the Harvard School of Public Health showed that drinking two to three cups a day lowered the chance of developing type 2 diabetes by about a third.
On the other hand….
Most research shows that avoiding caffeine is the answer to reducing the risks of diabetes. Researchers from a well-known university medical center found a strong tie between caffeine intake at a meal, with increased levels of glucose and insulin among people who have Type 2 diabetes.
James D. Lane and his colleagues at Duke University Medical Center have released findings that among men and women with type 2 diabetes—the form typically referred to as adult-onset—caffeine ingestion significantly impairs the body's control of blood sugar and insulin after a meal. In related work, Terry E. Graham of the University of Guelph, Canada, and his co-workers observed the same effect in obese men. Although none of the Canadian volunteers were diabetic, obesity is a leading predisposing risk factor for development of type 2 diabetes.
Caffeine contains Alloxan
Caffeine consumption can lead to the production of alloxan, which in turn can cause diabetes or make the condition worse. Alloxan is a chemical that poisons the cells that produce insulin. Laboratory tests have shown that when mice were fed alloxan, they developed diabetes. The cells that produce insulin were destroyed by the alloxan, resulting in the conditions for diabetes.
Alloxan poisons not only important to create insulin cells, but also causes damage to the pancreas and May ultimately lead to cancer of the pancreas. When we drink caffeine we allow our bodies to create more alloxan, thus increasing the risk of diabetes or developing or have a condition worse.
Caffeine Raises Blood Sugar
Caffeine can cause spikes in your blood sugar by raising so-called "stress" hormones that stimulate the release of stored glucose from the liver.
How Does Caffeine Raise Blood Sugar?
How caffeine raises blood sugar levels isn't completely clear. It's thought that caffeine may cause fluctuations in levels of hormones such as adrenalin or cortisol which could lead to elevations in blood sugar levels. There's also the possibility that caffeine has a direct effect on the function of the insulin molecule which could cause glucose levels to rise.
Generally speaking, this is done by the effect that it has on two hormones, glucagon and adrenaline. When consuming an excess amount of caffeine, these hormones begin to release sugar that is stored in the liver. The result is a higher blood glucose level.
Conclusion; There's something about coffee that fights type 2 diabetes – but it isn't caffeine. Coffee constituents other than caffeine may be responsible for the observed beneficial effects of coffee on diabetes.
If you have diabetes, or are concerned with preventing the disease, you need to know that there is a definite link between caffeine and diabetes.
As an alternative, drink decaffeinated coffee
If you have trouble controlling your blood glucose, it may be beneficial for you to try switching from caffeinated to decaffeinated coffee.
it appears that decaf coffee may actually help people keep their blood sugar under control, whereas regular coffee has a detrimental effect on blood sugar.
Drinking decaffeinated coffee protects one from developing the Type 2 Diabetes by about 60%. This has been revealed in a new study conducted recently. The study findings conducted by Besa Smith and her team of University of California, San Diego appeared in the November issue of the journal Diabetes Care.
Important! Drink only naturally decaffeinated coffee products.
Standard decaffeinated coffee products are not recommended.
The chemicals used in the decaffeination process can be detrimental to your health. The decaffeination process is usually achieved through toxic chemicals such as methylene chloride and Ethyl acetate (which are both acknowledged carcinogens), which then leach back into the coffee.
A recent study has linked decaf coffee with rheumatoid arthritis. The research, presented at the American College of Rheumatology's annual meeting, finds that older women who down four cups or more daily of decaf are more than twice as likely as non-decaf drinkers to develop the crippling disease.
Researchers speculate the increased risk might be attributable to the preparation and processing of decaffeinated coffee, says Ted Mikuls, assistant professor of medicine at the University of Alabama-Birmingham, and the study's lead author.
Natural coffee alternatives
As an alternative to standard coffee, try the many varieties of grain-based beverages that you can enjoy without reservation.
Satisfying alternative, herbal coffees, allow coffee drinkers to keep their same brewing ritual while enjoying roasted, full body flavor with hearty flavor and aroma. Herbal coffees have a number of nutritional health benefits and their natural alkalinity doesn't provoke the common health problems associated with coffee's acidity.
A highly recommended caffeine-free herbal coffee product is Teeccino Mediterranean Java Herbal Coffee.
Now you can enjoy a steaming cup of deliciously rich, deep-roasted, fresh brewed flavor that delivers all the satisfaction without the caffeine and acidity of coffee! Teeccino (tea CHEE no) is a nutritious blend of Mediterranean herbs, grains, fruits and nuts that are roasted and ground to brew and taste like coffee.
Caffeine-free herbal coffee marketed under the brand name of Teeccino® helps coffee drinkers replace their regular or decaf coffee with a satisfying alternative. Coffee drinkers need a dark, full-bodied, robust brew to help satisfy their coffee craving. Teeccino satisfies the 4 needs coffee drinkers require in a coffee alternative:
This product is:
- Made from 100% organic ingredients
- Naturally caffeine-free
- High in heart healthy potassium
- Natural energy boost – from nutrients not stimulants
- Non acidic – helps reduce acidity and restore alkaline balance
- Rich in inulin, a soluble fiber in chicory root that helps improve digestion & elimination plus increase the absorption of calcium & minerals
Click here to lean more about this supreme product.
Submitted Comments
# Black white market shoeson 15 Jan 2014 at 4:00 pm
Consider a unique approach to creating logos and banners rather than the simple rectangles that
some companies use. Before you try to sell your product or services, it's important
to develop a marketing plan for online business planning.
In order to see positive results within the shortest time possible, there
are a few guidelines that should be followed.

subset: commoncrawl


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Driver safety programCategorized as: Community & Neighborhood
Event tags:
- Kennett Area Senior Center - 427 S. Walnut Street, Kennett Square , PA 19348
- May 15, 2014
- Free
- (610) 444-4819
- Posted by: ACL Add Your Event For Free
The Kennett Area Senior Center (427 S. Walnut St., Kennett Square) sponsors an AARP driver safety program for drivers ages 50 and older on May 15 from noon to 4 p.m. The course is applicable for those who have previously completed the eight-hour course. The session explains the changes that occur in vision, hearing, and reaction time with aging. There is no test, and participants may be eligible for a discount on their auto insurance premiums. Call 610-444-4819 for reservations.
Kennett Square


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BPAA Family Fun Center Tournaments
We offer tournaments year round for families, individual and mixed competition. Our tournaments are always fun and competitive. Register for a tournament today.
To register for a tournament stop by a BPAA Family Fun Center near you and ask about our tournaments at the front desk or call 111-111-1111.
Mixed League Tounament
Begins 02/15/07
Register today!
Family Tournament 12/18/2006Winners:
1st place - The Robinson Family $5,000
2nd place - The Parkers $1,000
3rd place - The Jones Family $250


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Coolest Mid 5o's Little End Table In Sarasota
I have spent two weeks with this hip little guy, and I can safely say,
"This is my favorite small table I have met in my 4 years in Sarasota Florida."
I am selling it for a friend. She'd like to get 40 dollars for it.
However, she will consider taking a reasonable BEST OFFER.
- table is 2 feet high, and 1 1/2 wide
- In excellent condition
- Made from a quality wood grain (Walnut or Cherry I believe)
- Has 3 solid brass casters, and brass ring connector
- Sturdy, yet lightweight
- Perfect for laptop, ashtray, and beverage!


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Advanced Search
Apple's entry-level series of notebook computers--the MacBook--today received performance improvements across the board, including processor speed, memory, hard drive capacity, and networking. The new models are shipping now, with education pricing set below $1,000 on the low end.Apple's MacBook line was introduced about a year ago. The new models sport dual-core Intel Core 2 Duo processors running at 2.0 or 2.16 GHz. All of the models also get bumps in base memory configurations and storage and now come equipped with 802.11n wireless networking pre-installed.The MacBook has proved successful for Apple with students and general consumers, helping to raise Apple's portable market share to 10 percent, according to company representatives we spoke with today.On the low end, the white 13.3-inch MacBook is configured as follows:
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BlackBerry Bridge 2.0 Update Free Download Released by RIM
PlayBook and BlackBerry phone owners are hereby informed that Research in Motion has finally released the final version of BlackBerry Bridge 2.0. It can be downloaded from http://appworld.blackberry.com/webstore/content/19435/.
Before installing this new version of BlackBerry Bridge, please ensure that the BlackBerry PlayBook 64GB Tablet Computer (or any version) about to be updated to Bridge 2.0 is already installed with OS 2.0.
Should you have any trouble installing this latest update, get the latest version of App World 3.1.0 from www.blackberryf.com/appworld.
BlackBerry Bridge is the software that allows pair up between a BlackBerry handset such as the BlackBerry Curve 9380 to a PlayBook tablet computer.
Once installed, the phone's keyboard, touchscreen and trackpad can be used to remotely control the paired PlayBook.
The larger 7-inch display of the BlackBerry PlayBook Tablet PC means it is easier to play games, surf the web and watch movies.
This wireless connectivity allows remote management of the phone's email, contacts, tasks, calendar and BlackBerry Messenging.
If you own both RIM devices, be kind to your eyes and use this software to view your phone's small screen on the larger display of the PlayBook.
Furthermore, BlackBerry Bridge free download or update will allow you to directly open attachments and files on your PlayBook from your BlackBerry Curve or Bold's screen menu. It is also possible to copy or paste from anywhere inside the BlackBerry Bridge PlayBook apps. Version 2.0 now lets you use Device Properties to turn off or turn on BlackBerry Bridge email, address and calendar accounts.
Now here's the sweet surprise, if you don't own the PlayBook but still have a BlackBerry Phone, you can still download BlackBerry Bridge 2.0 on it and use it to remotely control an Android tablet that uses Bluetooth HID profile.
This hack works with a Motorola Xoom and HTC Flyer 7-inch Android OS 2.3 Tablet! Special hint, the Sony PlayStation 3 also uses Bluetooth HID profile so why not try it!
If you want these conveniences, better get the free BlackBerry Bridge 2.0 download as soon as possible.


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Click the Question for more information
Please review the answers to frequently asked questions below. Email us.
Buying, Selling & Appraising at the Show
May I bring an object to the Show for appraisal?
No. We do not offer appraisal services at the Show.
May I sell some of my own antiques at the Show?
No. Only the Show's Dealers are allowed to sell their merchandise.
Is it possible to purchase items at the Show?
Yes. Items displayed by the Dealers are for sale to the public. The items consist of high quality antiques and fine art. Please check the dealers' websites for specific information.
How do I find a specific object?
Browse our list of Dealers to see if they represent something that you are looking for. You can contact them directly for help.
For Dealers/Exhibitors
How can I become a dealer/exhibitor at the Show?
For more information, please contact Catherine Sweeney Singer at 610-902-2109.
Attending the Show
How do I purchase tickets?
Tickets will be available online, by mail or at the door. Please check back for more information.
What are the Show's hours and ticket prices?
For information about attending the Show, please visit The Show section of the website.
Do you have refreshments available at the Show?
Yes. The Café offers sandwiches, soups, salads, desserts and beverages for purchase. The Show also offers several full-service bars to purchase cocktails, wine, beer, soda and other refreshments.
Are pets allowed at the Show?
No. Only service dogs are allowed at the Show.
Are children allowed at the Show?
Yes. Children 12 years old and under are admitted free of charge.
Are strollers allowed at the Show?
Yes. Strollers are allowed on the Show floor.
Are backpacks allowed at the Show?
No. Backpacks, shopping bags and luggage must be placed in Coat Check.
Are wheelchairs available at the Show?
Yes. To ensure availability, please call 610-902-2109 in advance of arrival.
Are there special rates for senior citizens, students or others?
Yes. Get details here.
Is photography allowed at the Show?
You must ask the Dealers prior to taking any photographs of merchandise in their booths. No photographs may be taken of the Loan Exhibit.
Do you have tours available?
The Show offers daily Guided Show Tours and other customized group plans. For details, visit the Group Info page.
Getting to the Show
What is the address of The Convention Center for my GPS?
The Convention Center is located at 1101 Arch Street, Philadelphia, PA 19107. The entrance to Hall F is located at the corner of 12th and Arch Street.
Is there parking available at the Show?
Yes. Learn more about numerous parking options.
Are travel packages or other discount rates available during the Show?
Is there public transportation available to the Pennsylvania Convention Center?
Yes. For details, visit the Getting Here page.


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The Madeleine Brand Show for August 9, 2012
Drone Expo sets eyes on civilian targets
Sean Gallup/Getty Images
A quadrocopter drone equipped with a camera stands on display at the Zeiss stand on the first day of the CeBIT 2012 technology trade fair on in Hanover, Germany.
Robots are crawling all over Las Vegas this weekend. Not for the inevitable robot uprising, but instead for the 39th annual Association of Unmanned Vehicle Systems International's North America trade show, or the Drone Expo as it's being called.
Drones were primarily developed for defense, but companies are now adapting the technology for civilian use. LA Times reporter Bill Hennigan covers aerospace and defense, and profiled this year's Drone Expo in today's LA Times.
Bill Hennigan, covers aerospace and defense for the LA Times


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The Shorty Interview with Andreas Susana
Has Twitter changed your life? If yes, how?
It is easier to get in touch with people all over the world now.
How do you use Twitter in your professional life?
I use Twitter for discussing travel related stuff and for sharing my blog posts
Twitter or Facebook?
What inspires you to tweet?
An exciting experienceView Andreas Susana's complete Shorty Interview


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(Insert comment here).
Printable View
(Insert comment here).
It was an awesome park one that I could spend a full day at, I didn't start going till 97 but it still was great to me then. Now it's easily a half day park for me except during the holidays. I miss the theater being the main icon of the park and the full back lot tour (well not the original full tour but the one with the houses and stuff.)
My first time there was in 1991. I look back and think wow there was such a different vibe there. I do miss the residential street of the back lot tour. Not that it was the greatest thing in the world but at least you felt like there was some kind of production going on there.
I remeber visiting in 1990, but to tell you the truth, I like it better now. I just wish Fantasmic would return to a nightly show.
(Insert comment here).
I still love the fact that From The Earth To The Moon was largely filmed there. I remember the hillarious cheap-looking cut-outs advertising the show before it was released. Three men on the moon during an Apollo landing? Really?
I don't think the place is too bad for what it was: a rushed attempt to outdo Universal's approaching opening.
I remember Superstar Television because my father was one of the one's chosen for a Cheers scene. I belive he had a "scene" with Woody Harrelson. I miss that! Also, they need to take down that giant hat!
it is definitely different... and as you said completely inexplainable to someone who never saw it...
If they would kill the Indiana Jones show and put the Indiana Jones ride there from Disneyland, it might help a little.


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Monday, December 22, 2014
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The City Council wants to make life easier for street vendors by reducing the size of fines levied against them by the city, but the move is not sitting well with Mayor Michael Bloomberg. NY1's Bobby Cuza filed the following report.
Food carts are a fixture on city streets, but vendors say they're being squeezed by excessive fines handed out by the city.
"They are $1,000, sometimes, for minor violations, like having your license inside your jacket now that it's cold, or being a inch too far away from the curb or a foot too close to the crosswalk," said Sean Basinski, director of the Street Vendor Project.
"Last time, when I renew my license, I paid $6,000 for the fine," said one vendor. "For two years, $6,000. It's huge money for us."
But now, some of that money will stay in vendors' pockets. City Council Speaker Christine Quinn, whose face has been plastered on fliers attached to street carts across the city, announced Thursday that she'll advance legislation to cut the maximum fine in half, from $1,000 to $500.
"The guy or gal who makes one honest mistake, let's not whack the heck out of them for no reason," Quinn said.
Mayor Michael Bloomberg, who coincidentally was showing off a food truck Thursday powered by compressed natural gas, clearly disagrees, and has promised a veto.
"I think reducing the fines is one of the stupider things I've ever heard," Bloomberg said. "We want people to follow the rules. If you reduce the fines, they will follow them less. The complaint is they're not following them now. If anything, you should raise the fines."
The new legislation doesn't affect every type of fine. Health code violations, for instance, would be unaffected, as well as fines for operating without a license.
The legislation also creates certain new restrictions for vendors. No vendors would be allowed in taxi stands, near hospital no-standing zones, or within 20 feet of apartment building doors, and the legislation would create a new system to better track serial offenders.
The City Council will vote on the bills next Wednesday. Quinn didn't seem worried about a potential mayor veto.
"There's never been a veto I haven't overridden," she said.
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Recreation Therapy
The Recreation Therapy Program is designed to help the children improve their self-esteem and to promote their independent leisure functioning. This is accomplished through the teaching of leisure skills, improving physical fitness, and improving social functioning. Activities specifically provided by the recreation therapists are designed to meet these objectives. The Recreation Therapists organize annual campus wide activities, such as the summer carnival. If you have any questions regarding the program please contact the Recreation Therapy Supervisor, at (253)756-2694.


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Gateways to the Mind (1958)
The story of what science has learned about the human senses and how they function. Includes documentary sequences.
To Download or Embed this video, go to this link.
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SI 680 Contracting and Signaling- Week 04 Case Study: Tech Transfer Licensing (Assignment)
Course prepares you to advise clients or your own organization on the design of contracts and screening policies when one of the parties has an information advantage over the other. For example, students study the design of patent licenses (the licensor knows more about the market), the design of social systems to reduce spam (the spam sender knows more about the content before the recipient decides whether to read), and the design of performance contracts for professional services (e.g.,... More
Material Type: Case Study
Date Added to MERLOT: August 10, 2012
Date Modified in MERLOT: August 28, 2012
Submitter: Open Michigan
Keywords: screening policies, contracting incentive centered design, contract design, signaling, intellectual property, incentive centered design methodology
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MIT enables robot, human collaboration in manufacturing
Researchers create algorithm that lets robots learn how to work with people Computerworld - MIT researchers have developed an algorithm that they say will enable robots to learn and adapt to humans so they can soon work side-by-side on factory floors. "If the robot can provide tools and materials so the person doesn't have to walk over to pick up parts and walk back to the plane, you can significantly reduce the idle time of the person," said Shah, who leads the Interactive Robotics Group in MIT's Computer Science and Artificial Intelligence Laboratory. However, one of the issues involved with having humans work individually with robots is that every person works differently, and the robots will have to adapt to each worker. To address that problem, Shah and her research team at MIT created an algorithm that enables robots to quickly learn an individual's preference for a certain task, and adapt accordingly to help complete the task.
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Epsilon Force has has been decommissioned, and it's officers
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My son actually looks forward to bedtime now! He was so excited to see his bed is blue. It is very comfortable, I find myself not wanting to get up after reading to him at night. Great buy.
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Family Medical Leave Act (FMLA) Overview (WTD141)
What it is and What it is not.
This presentation will discuss FMLA rights and responsibilities, and will be beneficial for individual employees and those departmental assistants who give and receive documentation. While not a "how to" session, this overview will cover the basics of FMLA that are critical to the process. You will learn what steps to take in requesting FMLA (employee) and in designating FMLA (department), and become familiar with FMLA terminology.
Presenter: Stephanie Harvey, Manager, Benefits Administration, Human Resources


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Home > Criminal Defense Issues > White Collar > Amicus Briefs
Commonwealth of Massachusetts v. Gelfgatt, Supreme Judicial Court of the Commonwealth of Massachusetts, Case No. SJC-11358, on report of a question of law by the superior court for Suffolk County pursuant to Mass. R. Crim. P. 34, brief filed 8/23/13. Compelled Password---Encrypted Hardware---Fifth Amendment---Self-incrimination---Fourth Amendment---Articles Twelve and Fourteen of the Massachusetts Declaration of Rights. Brief of Amicus Curiae filed by Daniel K. Gelb, Esquire and Daniel B. Garrie, Esquire to which National Association of Criminal Defense Lawyers joins in support of defendant-appellant. Issue Presented: Whether compelling a criminal defendant to provide a password for a piece of encrypted computer hardware seized by the Commonwealth violates one's right against self-incrimination provided by the Fifth Amendment to the United States Constitution and Article Twelve of the Massachusetts Declaration of Rights. Argument: Compelling a password production to the Commonwealth is a violation of defendant's right against self-incrimination pursuant to the Fifth Amendment of the United States Constitution and Article 12 of the Massachusetts Declaration of Rights. Society has adopted an objective expectation of privacy in computer passwords and encrypted data protected by the Fourth Amendment of the United States Constitution and Article 14 of the Massachusetts Declaration of Rights. Authors: Daniel K. Gelb, Gelb & Gelb LLP, Boston MA; Daniel B. Garrie, Law & Forensics, Seattle, WA.
Hummel v. United States, U.S. Dist. Ct., M.D. Fla., No. 8:12-MJ-1457 TGW, brief filed 1/11/13. Due Process---Controlled Substances Act---Controlled Substance Analogues---Void for Vagueness---Fair Warning---Prosecutorial Discretion---Seizure of Funds. Amicus curiae brief of the National Association of Criminal Defense Lawyers in support of movant. Argument: As applied to the substances at issue in this case – UR-144 and XLR-11 – 21 U.S.C. §813 and its accompanying definitional statute 21 U.S.C. §802(32)(A)(i) are unconstitutionally vague, and void for that reason. Authors: David Oscar Markus, Markus & Markus PLLC in Miami, FL; John D. Cline, Law Office of John D. Cline in San Francisco, CA.
Kaley v. United States, U.S. Sup. Ct., No. 12-464, decision below 677 F.3d 1316 (11th Cir. 2011), brief filed 7/5/13. Forfeiture—Due Process—Right to Counsel. Amicus curiae brief of the National Association of Criminal Defense Lawyers in support of petition for writ of certiorari. Question presented: When a post-indictment, ex parte restraining order freezes assets needed by a criminal defendant to retain counsel of choice, do the Fifth and Sixth Amendments require a pretrial, adversarial hearing at which the defendant may challenge the evidentiary support and legal theory of the underlying charges? Argument: A seizure of allegedly forfeitable assets needed to retain counsel is constitutionally unreasonable without more evidential support than ordinary seizures require. The right to counsel of choice is of a nature with the rights to speak, associate, and petition the government. The retention or appointment of alternate counsel does not mitigate the threatened constitutional violations. Recognizing that seizures of assets needed to retain counsel pose the same dangers as other prior restraints on protected speech resolves the issues dividing the courts of appeals. Author: University of Miami School of Law Professor Ricardo J. Bascuas, Coral Gables, FL.
Ring v. United States, U.S. Sup. Ct., No. 12-1462, decision below 706 F.3d 460 (D.C. Cir. Jan. 25, 2013) (No. 11-3100), brief filed 7/17/13. Skilling—Bribery—Honest Services—Campaign Contributions. Brief of Amici curiae National Association of Criminal Defense Lawyers and Rutherford Institute in Support of Petition for Certiorari. Argument: The Court should grant certiorari to make clear that the honest services fraud statute requires the government to prove bribery. The honest services fraud statute is unconstitutionally vague unless limited to bribery, as Skilling requires. The standard applied in this case to prove honest services fraud is inconsistent with this Court's rulings. The admission of evidence of legal and constitutionally protected campaign contributions in this case, in contravention of this Court's rulings, will criminalize, and thereby chill, constitutionally protected conduct. Authors: Paul F. Enzinna and Evan N. Turgeon, Brown Rudnick LLP, Washington, DC.
Sekhar v. United States, U.S. Sup. Ct., No. 12-357, decision below 683 F.3d 436 (2d Cir. 2012), brief filed 3/4/13. Hobbs Act—Statutory Interpretation---Rule of Lenity---Federalism. Amicus curiae brief of the National Association of Criminal Defense Lawyers and The Cato Institute in support of petitioner and urging reversal. Question presented: Whether the "recommendation" of an attorney, who is a salaried employee of a governmental agency, in a single instance, is intangible property that can be the subject of an extortion attempt under 18 U.S.C. § 1951(a) (the Hobbs Act) and 18 U.S.C. § 875(d). Argument: This Court has repeatedly applied the rule of lenity and other tools of statutory interpretation to limit prosecutors' expansive applications of federal criminal statutes. This Court has required a clear statement from Congress before it will interpret a federal criminal statute to shift the federal-state balance in law enforcement. This case implicates the concerns that have caused this Court to interpret criminal statutes narrowly. Authors: John D. Cline and Jennifer M. French, Law Office of John D. Cline, San Francisco, CA; David M. Porter, Sacramento, CA; Timothy Lynch and Ilya Shapiro, The Cato Institute, Washington, DC.
United States v. Newman and Chiasson, 2nd Cir., Case Nos. 13-1837, on appeal from the United States District Court for the Southern District of New York, brief filed 8/22/13. Mens Rea---Jury Instructions---Insider Trading---Remote Tippees. Brief of National Association of Criminal Defense Lawyers as Amicus Curiae in support of Appellants. Argument: The District Court's jury instructions conflict with the fundamental principle that a defendant must know the facts that make his conduct illegal. Basic principles of mens rea require proof that the defendant knew the facts that made his conduct unlawful. The federal securities laws require proof that a tippee knew the original tipper of inside information disclosed information in exchange for a personal benefit. The requirement of proof of knowledge that the original tipper disclosed information in exchange for a personal benefit is particularly important in cases involving remote tippees. Authors: Ira M. Feinberg, Jordan L. Estes, Hagan Scotten, Hogan Lovells US LLP, New York, NY; Joshua L. Dratel, New York, NY.
United States v. Andrew "Weev" Auernheimer, 3rd Cir., Case No. 13-1816, case below 2012 WL 5389142 (D.N.J. Oct. 26, 2012) (Crim. No. 11-CR-470), brief filed 7/8/13. Computer Fraud and Abuse Act (CFAA)---Fifth Amendment---Due Process---Vagueness---Venue---Forum Shopping. Amicus curiae brief of the National Association of Criminal Defense Lawyers in support of appellant. Argument: The Fifth Amendment's due process clause requires a narrow interpretation of "without authorization" under the Computer Fraud and Abuse Act (CFAA). The District Court's finding that venue was proper exceeds constitutional limitations and invites prosecutorial forum-shopping. Authors: Steven P. Ragland, Jennifer A. Huber, and Ben D. Rothstein, Keker & Van Nest LLP, San Francisco, CA; Jenny Carroll, Seton Hall University School of Law, Newark, NJ; Peter Goldberger, Ardmore, PA.
United States v. Apel, U.S. Sup. Ct., No. 12-1038, decision below 676 F.3d 1202 (9th Cir. 2012), brief filed 10/28/13. 18 U.S.C. §1382---First Amendment---Peaceful Protest---'Military Installation'---Overbreadth----Ambiguity---Rule of Lenity. Brief of the National Association of Criminal Defense Lawyers as Amicus Curiae in support of Respondent. Argument: The government's interpretation of 18 U.S.C. §1382 would render the statute unconstitutionally overbroad. A statute is facially overbroad when there is a realistic danger that it will significantly compromise speech rights. The government's new interpretation of Section 1382 would (i) extend existing military regulations onto public roads, thereby infringing on a substantial amount of protected speech in a public forum and (ii) authorize base commanders to promulgate new military regulations that could further restrict protected speech on public roads. The government's interpretation of 18 U.S.C. §1382 encourages arbitrary enforcement by the government, even against civilians who lack notice of how the law is applied. The government's interpretation of 18 U.S.C. §1382 should be rejected under the rule of lenity. Authors: Michael V. Schafler, Albert Chang, and Puneet V. Kakkar, Caldwell Leslie & Proctor PC, Los Angeles, CA; Jeffrey Fisher, Stanford, CA.
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Authors: Sarah Merriam MD and René Claxton MD
Background Nonsteroidal anti-inflammatory drugs (NSAIDs) are among the most commonly prescribed drugs in the treatment of musculoskeletal pain. Two topical NSAID formulations are commercially available in the United States: diclofenac sodium gel (Voltaren) and diclofenac epolamine topical patch (Flector). This Fast Fact reviews the pharmacology, clinical efficacy and adverse effects of topical NSAIDs for the treatment of musculoskeletal pain.
Pharmacology High plasma concentrations of oral NSAIDs are required to achieve effective tissue concentrations at the site of pain and inflammation. Topical NSAIDs are believed to deliver adequate local tissue concentrations with minimal systemic absorption. Plasma concentrations following topical administration of diclofenac sodium gel and the diclofenac epolamine patch are far lower than levels found following oral administration of diclofenac (0.6%-2.2%, and less than 1%, of oral systemic levels, respectively). Time to peak serum concentration for both topical formulations is approximately 10-20 hours (1).
Clinical evidence NSAIDs are often recommended as first-line treatment for mild-to-moderate musculoskeletal pain (2). A Cochrane review of the efficacy of topical NSAIDS in the treatment of acute musculoskeletal pain (sprains, strains, contusions) found that compared to placebo, the number needed to treat (NNT) was 4.5 to achieve 50% pain relief over treatment periods of 6-14 days (3). The effectiveness of topical NSAIDs for the treatment of acute low back pain or chronic conditions including chronic back pain is unknown (4). Several systematic reviews report trials of poor quality with most trial lengths lasting less than 4 weeks and demonstrating inconclusive results (5). Head-to-head trials comparing oral NSAIDs and their topical equivalents show conflicting results with regards to efficacy and there are insufficient data to perform meta-analysis (3). There are virtually no data about topical NSAID use in patient populations commonly seen in palliative care settings. A literature review in June 2011 identified a single study which showed no benefit from a topical NSAID cream over placebo in the relief of pain related to pressure ulcers (6).
Adverse Effects Patients taking oral NSAIDs for ≥5 days at least twice annually have a 4.21 relative risk of gastrointestinal events compared to those who do not (7). Conversely, topical NSAIDs have a high margin of safety and have not been associated with acute renal failure or upper GI adverse events. Mild local adverse effects occur at approximately the same rate (6%) in patients treated with topical NSAIDs or topical placebo (4).
Summary In the treatment of acute musculoskeletal pain, excluding low back pain, topical NSAIDS are more effective than placebo and are associated with fewer adverse events than oral NSAIDs (although this has not been demonstrated in head-to-head trials with oral NSAIDs). Current data suggest topical NSAIDs are appropriate for patients with a flare of single joint arthritis or acute musculoskeletal injury. Given the expense of topical NSAIDS (approximately $36 for one 100 gm tube of diclofenac gel and $170 for thirty diclofenac epolamine patches), unclear clinical benefit over prolonged time periods, and unknown efficacy compared to oral preparations, they are not recommended for chronic musculoskeletal pain. Their use for cancer-related pain syndromes and other indications is entirely empiric.
1. Micromedex® Healthcare Series [Internet database]. Greenwood Village, Colo: Thomson Reuters (Healthcare) Inc. Updated periodically.
3. Massey T, Derry S, Moore RA, McQuay HJ. Topical NSAIDs for acute pain in adults. Cochrane Database Syst Rev. 2010; 6: CD007402.
4. Roelofs PD, Deyo RA, Koes BW, Scholten RJ, van Tulder MW. Nonsteroidal anti-inflammatory drugs for low back pain: An updated Cochrane review. Spine. 2008; 33:1766-74.
5. Gotzsche P. NSAIDs. Clinical Evidence. 2009; 6(1108).
6. Prentice WM, Roth LJ, Kelly P. Topical benzydamine cream and the relief of pressure pain. Palliat Med. 2004; 18:520-4.
7. Singh G, Triadafilopoulus G. Epidemiology of NSAID-induced GI complications. J Rheumatol. 1999; 26:18-24.
Authors' Affiliation: University of Pittsburgh Medical Center, Pittsburgh, PA.
Fast Facts and Concepts are edited by Drew A Rosielle MD, Palliative Care Program, University of Minnesota Medical School and Fairview Health Services, and are published by the End of Life/Palliative Education Resource Center at the Medical College of Wisconsin. For more information write to: firstname.lastname@example.com. More information, as well as the complete set of Fast Facts, are available at EPERC: http://www.mcw.edu/eperc.
Copyright/Referencing Information : Users are free to download and distribute Fast Facts for educational purposes only. Merriam S, Claxton R. Topical non-steroidal anti-inflammatory drugs. Fast Facts and Concepts. January 2012; 249. Available at: http://www.eperc.mcw.edu/EPERC/FastFactsIndex/ff_249.htm.
Disclaimer: Fast Facts and Concepts provide educational information. This information is not medical advice. Health care providers should exercise their own independent clinical judgment. Some Fast Facts cite the use of a product in a dosage, for an indication, or in a manner other than that recommended in the product labeling. Accordingly, the official prescribing information should be consulted before any such product is used.


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Installing PowerDNS (With MySQL Backend) And Poweradmin On Debian Squeeze - Page 2
Submitted by falko (Contact Author) (Forums) on Mon, 2011-08-29 17:26. ::
Click on Go to step 7:
The installation is now finished...
... but for security reasons we must delete the install directory:
rm -fr /var/www/poweradmin/install/
Now you can go to http://server1.example.com/poweradmin or http://192.168.0.100/poweradmin and log in with the username admin and the password you created during the installation:
This is how the Poweradmin web interface looks:
To create a zone, go to Add master zone and fill in the domain name (e.g. example.com):
On the List zones page you will see that the new zone has just one record (the SOA record). Click on the edit icon...
... and then on Add record to add further records, ...
..., e.g. NS records...
... and A records (e.g. for example.com (leave the Name field empty!) and mail.example.com)...
... and MX records:
To create PTR records, go to the Add master zone page and create a zone called in-addr.arpa:
To create a PTR record that points from the IP 184.108.40.206 to server1.example.com, create a record under List zones and fill in 184.108.40.206 in the Name field (that's the IP in reverse order) and server1.example.com in the Content field:
After you've created your records, you can check them with the dig command (see
man dig
for more details), e.g. as follows:
dig @localhost mx example.com
root@server1:~# dig @localhost mx example.com
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Dr. Seuss' The Lorax
Rent, buy and watch the latest movies and TV shows online
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From John Musker and Ron Clements, the writers/directors who created "The Little Mermaid" and "Aladdin," comes this irreverent and wacky new animated epic comedy that follows the outrageous adventures of legendary hero, "Hercules."
Walt Disney Pictures' 35th full-length animated feature tells the story of "Herc," the mighty son of Zeus, who is taken from his Mount Olympus home and raised on Earth-half man, half god. The fiery figure behind Hercules' disappearance is Hades, the hot-headed god of the Underworld who has grown tired of looking after a "bunch of deadbeats" and sees Zeus' son as an obstacle to his plans to rule the universe. When Herc discovers the truth about his origins, he sets out to prove himself a hero (with the help of a veteran hero-training satyr named "Phil") so he can return to his mythological home.
Animation, Family
Suitable for all
1 hour 33 minutes
PC, Mac, iPad, Android tablets, Windows tablets, Xbox, PS3, Chromecast, smart TVs, set-top boxes and Blu-ray players.
Windows PC (UK internet connection required to acquire license)


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|Language Packs and Localised Releases
Joomla! speaks many languages.
There are quite a few options and strategies available to making Joomla! speak your language. This page will help describe the options and point you in the right direction.
First question is - which version of Joomla! ?
Joomla! 1.0.x Links to Language Packs and Localised Releases:
Joomla! 1.5 Links to Language Packs and Localised Releases:
Mutli-lingual sites:
Joomla! can be adapted to provide multi-lingual sites by installing the Joom-Fish component.
|Last Updated ( Thursday, 08 January 2009 )


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Nestle Products
Nestle is one of the oldest and largest candy producing corporations in the world. Founded in 1866, the candy company has come to produce many unique and globally recognized confections. One of Nestle's most lucrative products is the very famous Kit-Kat bar.
Kit-Kats were acquired by Nestle in 1988, from an English company called Rowntree. They started producing the delicious candies way back in 1935. And while Nestle now makes Kit-Kats around the world, Hersheys, one of Nestle's biggest competitors, actually makes Kit-Kats in the United States. This is due to a prior agreement with Rowntree.Read More >>
Nestle Aero Chocolate 4.4 oz
Price: $5.39
Nestle Japan Crunch Minis 5 oz
Price: $5.39
Nestle Aero Strawberry Milk Chocolate 3.64 oz
Price: $5.39
Since about 2003 Kit-Kats have been coming in flavors other than the traditional milk chocolate. Some flavors have been limited editions, while others were just whacky ideas that became a hit, such as Ginger Ale, or Lemon Vinegar. Some of the most popular of these flavors have been the Banana Fruit Juice Kit Kats, the Blueberry Kit Kats, and while it may sound odd, the giant Green Tea Kit Kats.
Kit-Kat has many flavors that only appear overseas. Certain flavors are only available in certain countries, such as Japan, or India, or Germany.
The flavors you see here are not available in most American supermarkets. But you can get them here!


text: In January, Jeff Napolitano took over as area head of the American Friends Service Committee (AFSC). The 93-year-old group has been in the Valley since 1968, when activist Frances Crowe started the local chapter in her basement. The chapter was founded in reaction to the Vietnam War and promoted nonviolent resistance to the draft and war effort, but its mission has become much broader. Its Help Increase Peace Program (HIPP) is one effort that sends members to schools to train students in nonviolent responses to bullying and how to teach others the techniques. AFSC has also recently been involved with efforts to close the troubled Vermont Yankee nuclear power plant.


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Rejection. No one likes it. No one craves it. No one is immune to its effects. Through pain avoidance, we tend to steer clear of any potential circumstance that we anticipate hearing the word "NO". The problem with rejection is that it can leave us paralyzed and immobilized for the future. Here is the key […]Read More
The more innovative the more barriers the status quo will erect in your way. Guy Kawasaki Innovation can be like selling tickets to the moon There is a direct correlation between how innovative your product (or idea) is and how many barriers you will encounter. Every product faces barriers. If you have personal experience with […]Read More
In today's episode you will hear from Paul Farmiga, Bill Self and Jim Fitzpatrick. Each were members of last year's Medicine Ball three-day intensive with Seth Godin. You will enjoy hearing about how their thinking was re-shaped and how that has woven into their careers these last twelve months. Special thanks to Justin Lukasavige for […]Read More
Subscribe in iTunes Financial Guy Turned CEO In this episode I will be speaking with Jeff Ullrich. He is the CEO and co-founder of Earwolf Media. Jeff and I were classmates last year at Seth Godin's Medicine Ball. Jeff and his partner and co-founder Scott Aukerman launched Earwolf Media from a fourteen-page business plan now […]Read More
Today I am interviewing Lisa-Marie Cabrelli. Lisa-Marie and I met at Seth Godin's Medicine Ball course last year. She has a super-power. I can teach anyone to make money from anywhere at anytime. People who do not purpose to change the world assume it is easy for those who do. It is not. People who […]Read More
World Changer Today I had the privilege of [Podcast] interviewing Erica Dhawan. Erica has one of those resumes that gives me pause. Forbes writer Keynote speaker Harvard graduate Entrepreneur Consultant In this interview Erica and I discuss: Why you should stop asking for permission from others? Choosing a life of impact instead of following the herd. […]Read More


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For the latest news on what is happening at Living Room, visit our Facebook page and "Like" us!
Thank you for joining us for this year's Taste of Life!
Special thanks to the hardworking volunteers, vendors, and donors who made this year's Taste of Life one of the best yet.
Developed and organized with the Holy Cross AIDS Ministry, the event offers the public an evening of international wine, beer and spirits tastings; a buffet with offerings from area restaurants, silent auctions, raffles; and a moving presentation about the life-saving services of Living Room.


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I'm happy to score another cover of UK's Climb Magazine, this time featuring a bit of Aussie rock. The climber is Flint Duxfield leading pitch 8 (the "Spine Chiller traverseâ€) of Big Nose (26), 250m, Pierce's Pass, Blue Mountains.
Category Archives: Published
Sam Whiteley interviewed me for this profile which appears in the current issue of Better Photography, an Australian magazine which is edited by AIPP Grand Master of Photography, Peter Eastway. Many thanks to Sam and Peter for featuring my work, it's a real honor.
I'm really stoked with this cover of Climb Magazine for their January 2013 issue. Not just because it's my shot of Monique climbing – but I also love the graphics!
The magazine has an article about great lines, so this photo was a good choice. The route is the 60-metre tufa route Tom et je Ris (32) in Verdon Gorge, France.
We had a fantastic time climbing up in South East Queensland this winter but I've got to say information on the climbing was hard to come by. It soon became obvious to us that a lot of the crags up there were not covered by any print guidebooks; the coverage was usually very out of date and/or unavailable, or had simply never been covered by a print guidebook. Some local climbers had been gathering information for years and had already pretty much authored the text for some new guidebooks. We got talking and we all decided to work together, to make it happen and get all this material into print as soon as possible. I ran around taking a lot of crag topo photos and then when we returned home I locked myself in the office for a couple of months and smashed out the layout. The main contributors busted their arses to update, finish and polish the text as well as mark up the topos, and the local climbing community were fantastic with their support with contributing information and action photos. I needed to do the production of this book in between trips and we all wanted to get this guidebook produced before Christmas. And as it turns out we managed to achieved that; things went super smoothly with the printers, our shipment is being freighted to us at the moment and we'll be distributing the books to the shops next week. Yeeha!
A huge shout out of thanks to everyone who contributed. I can't wait to visit Queensland again next winter — to put this new guidebook to use and enjoy the great climbing!
So here we have it, I'm proud to announce the new South East Queensland Climbing, Selected Crags guidebook!
There's more information below:
- This is a new guidebook for rock climbing in South East Queensland. There is a wealth of fantastic climbing in the area — and this compact yet comprehensive guide covers many areas not covered by any other current guidebook. It includes some of the best sport and trad climbing South East Queensland has to offer — a must have book for local climbing fanatics and visitors alike.
- Details eight climbing areas: Brooyar, Mount Beerwah, Mount Coolum, Mount Ngungun, Mount Tibrogargan, Mount Tinbeerwah, Serpent and the ever popular Kangaroo Point. All up over 1000 routes!
- Authored by local climber Lee Cujes in collaboration with Ross Ferguson, John O'Brien and others.
- Numerous cliff photo topos, access maps and professional user-friendly design help make route finding a breeze.
- A5 in size, full colour, 168 pages. RRP $36.95 (including GST).
- Available from climbing gear shops or by mail-order from our online shop here.
Another Rock Magazine cover. This time it is from my trip to Queensland where I photographed John J O'Brien on his Ill Gotten Gains (26), an unlikely and very cool looking arete, two pitches up Mount Cooroora on the Sunshine Coast.
Our calendar for 2013 is out and I'm stoked with the result again this year!
The marketing departments word is below. If you are thinking about getting a copy then don't wait, we've cut the print run fine this year and there's a good chance we'll sell out.
This is the 19th annual calendar to showcase the work of World-renowned climbing photographer Simon Carter.
Seamlessly merging action and landscape, the dazzling imagery inspires and captivates climbers across the globe.
Features climbing destinations from Australia, China, France, New Zealand, Spain, UK, USA and Vietnam.
The design is stylish and functional and includes international holiday dates and moon phases.
Presented in a large 30 x 30cm format, shrink-wrapped and stiffened for protection. Opens to 30 x 60cm (12 x 24″).
Update: we have now sold out of the 2013 calendar!
If you'd like to know which Australian retailers may still have it in stock in your area, please email us with your location.
It may still be available from some of our overseas distibutor: in SPAIN here, in FRANCE here, or the UK here.
Each year the German magazine Klettern publish a massive poster sized wall calendar and most years I get a few shots in there. For 2013 I've scored the cover again and few inside shots. The calendar is huge! I don' know it works out with the postage but if you live in Europe it may not be to bad, you can get it from there shop here.
I've been on the road again; this time a quick trip to Arapiles and The Grampians. More on that soon, but in the meantime the June issue of Klettern Magazine has turned up and I'm happy to have got another cover with Monique styling on that crazy tufa route in Verdon Gorge. Sweet!
And some good press for local (Blue Mountains) talent Matt Norgrove, here on Moonshadow, his first 33. Earlier I mentioned how Matt has carved it up lately. Since then he has cranked Mechanical Animals (33), he's certainly on a roll .
Thanks to Rock Magazine for another cover!
Another cover, this one the French magazine Grimper with Spanish climber Daila Ojeda smashing the glass ceiling on Mind Control (8c+) at Oliana. This shot found it's way into print very quickly. I mentioned Daila's climb in my recent post here. Thanks to Daila and Grimper!


text: I took a course for CPR for the professional healthcare provider since I am going to be a nurse. I learned how to perform CPR on an adult a child and an infant. I also learned how to correctly use an AED and relieve a patient of choking. It was most certainly worth doing.