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Back in August, Delta announced it would be raising the mileage requirements on many of its international awards for flights on or after June 1, 2014, and discontinuing the ability to put awards on hold starting September 1, 2013. It was the latest in a string of customer-unfriendly moves that included cutting award ticket holds, hacking away at same day flight change benefits for elites and instituting an revenue-based Medallion elite requirement, and more recently, removing elite upgrade searchability from ExpertFlyer.
It seems like the airline isn't done slashing the value of SkyMiles yet, because June apparently wasn't soon enough to start gouging flyers for more miles. Instead, on Friday evening, the airline announced that it would be increasing mileage redemption levels sooner with a new award chart it would put in place for tickets from February 1 – May 31, 2014 before the "big" devaluation.
Here's what the current award chart looks like:
And here's what the interim award chart will be:
The following roundtrip awards will increase by these mileage amounts:
Business/First domestic: 5,000-10,000 miles
Economy Saver to Hawaii: 5,000 miles
Business/First to Hawaii: 5,000 miles for Saver, 15,000 miles for Standard
Economy Peak to Africa: 20,000 miles
BusinessElite Peak to Africa: 10,000 miles
Economy Saver to the Middle East: 5,000 miles
Economy Saver to South Asian Sub Continent: 5,000 miles
Business Saver to South Asian Sub Continent: 20,000 miles
Business Standard to North Asia: 20,000 miles
Business Peak to North Asia: 10,000 miles
As a reminder, here are what the June 1 BusinessElite award increases will look like:
USA/Canada to Europe
Old: 100,000 miles roundtrip
New: 125,000 miles roundtrip
USA/Canada to Asia
Old: 120,000 miles roundtrip
New: 140,000 miles roundtrip
USA/Canada to Australia
Old: 150,000 miles roundtrip
New: 160,000 miles roundtrip
USA/Canada to Africa
Old: 120,000 miles roundtrip
New: 140,000 miles roundtrip
USA/Canada to South Africa
Old: 140,000 miles roundtrip
New: 160,000 miles roundtrip
USA/Canada to Middle East
Old: 120,000 miles roundtrip
New: 140,000 miles roundtrip
USA/Canada to Southern South America
Old: 100,000 miles roundtrip
New: 125,000 miles roundtrip
So all in all, we're looking at increases of up to 25% on some awards, and they're going to go into effect within 3 months. The announcement claims that Delta periodically evaluates its award chart. With the international premium redemptions devaluation, the airline claimed it was changing those levels as a result of upgrading its BusinessElite cabins and offering lie-flat seats on its widebody fleet, as well as partnerships with Westin and Tumi and technological upgrades. But that's an odd justification considering competitors like United's BusinessFirst and American's new business class cabins are also all lie-flat, while many of Delta's partners including major ones like Air France and KLM won't be upgrading their cabins until next year at the earliest.
All in all, this is just more disappointing news from Delta and just one more reason that 2013 has been the year of the devaluation – both in terms of airline miles and hotel points. While there are still plenty of ways to see the world in style and get good value from your points and miles, airlines and hotels are definitely going to be making it harder on all of us to do so. But what rankles me even more than the mileage increases is that Delta keeps springing one customer-unfriendly move after another on us with weak reasoning, and it's enough to make me want to move away from Delta all together and focus on building balances in other programs where loyalty goes both ways.
Disclaimer: The responses below are not provided or commissioned by the bank advertiser. Responses have not been reviewed, approved or otherwise endorsed by the bank advertiser. It is not the bank advertiser's responsibility to ensure all posts and/or questions are answered.
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A great looking parka has released from the Heritage Research Fall/Winter 2011 Collection. The parka features an all-over Navajo Wool upper, with leather binding and horn buttons acting as nice premium accents. Reinforced shoulders, 4 front pockets and a wool lining round off this overall solid winter jacket. It is now in stock at Present.
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subset: commoncrawl


text:
- Critic & User
- Videos &
- Codes
& FAQs
- Gameplay
- Similar
Game Details
- Release Date 9/20/2005
- Publisher Nintendo
- Platform GameCube
- Genre Strategy/Sim
- Number of Players 1
Game Description
Kuju Entertainment teams up with Nintendo to bring you Battalion Wars for the GameCube. Originally a strategy-game staple for the Game Boy Advance, Battalion Wars jettisons the turn-based battle systems of the originals and embraces a hybrid of real-time strategy and first-person action. In Under Fire you will lead squads of men in battle, directing their attacks and movements. In the heat of battle you will commandeer tanks, gunships and more. Battalion Wars is a test of wits and nerves.
User Reviews
Average Member Rating: 7.0 out of 10
I dont no what everyone else is talking about.... (9 out of 10)
posted by NickB07 (HAYWARD, CA) on Jan 18, 2008
Member since Jul 2007
5 out of 5 gamers (100%) found this review helpful
Member since Jul 2007
5 out of 5 gamers (100%) found this review helpful
I read some of the other reviews that everyone wrote but i thought this game was fun, i just rented it today and it was better then i thought because i was like i dont no if i should rent this because of the reviews but this game is fun! ya the levels are a little hard but you dont want an easy game...more
Specs & Requirements
Memory 2 blocks
Modes Story, Full Mission Single-Player, Campaign
Similar Games
- Grand Theft Auto IVRelease 4/28/2008
- The Legend of Zelda: Twilight PrincessRelease 12/12/2006
- Mercenaries: Playground of DestructionRelease 1/10/2005


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Samuel L. Jackson, Uma Thurman, The Weinsteins, Eli Roth, and More to Roast Quentin Tarantino
by Brendan Bettinger Posted 4 years, 118 days ago
You may believe that, by the time we're celebrating the career of David Hasselhoff, the celebrity roast is a dying art form. And you'd be right. But the Friars Club does its best to maintain the tradition of the gin-soaked roasts of the Dean Martin era. Case in point: the club has announced a roast centered on Quentin Tarantino, with Samuel L. Jackson serving as "Roastmaster." Such former Tarantino collaborators as Uma Thurman, Pam Grier, Michael Madsen, Eli Roth, Rosario Dawso, and Harvey Weinstein(!) will be on hand to poke fun at the idiosyncratic director. Sounds like it'll be loads of fun, and I can only hope that some internet-friendly videographer is on hand to capture it. Hit the jump for the official press release.


text:
My Palette
Drag Color Chips
Featured Artist : Marina Sciascia |
Artist Bio / Statement
My name is Marina Sciascia, I'm a professional freelance artist and doll maker.
Around ten years ago I married an American man and came to the U.S. from Russia, where I was educated with a master's degree in art. This is when I began to create my first dolls.
All my life I've loved fairy tales and fantastic stories. My favorite writers are Hoffman, Andersen, the Brothers Grimm, Dickens and many others. I realized the fabrics for doll clothes are often not suitable for my ideas. I started trying different paints but my first attempts were not so great. One day I saw a site, Dharma Trading Co., where I could buy Jacquard Textile Colors for fabrics. In 2008 I bought all the colors of Jacquard Textile Colors and this year I bought a Jacquard Dye-Na-Flow Mini Starter Set. They are now my best and favorite colors for painting on fabric!! Very easy use and mix.The colors are so bright, perfect for my fairy tale art dolls.
Now all my dolls are dressed in clothes that I paint myself, which helps to create and bring to life the character. And they work with any fabric! For me, working with Jacquard Textile Colors and Dye-Na-Flow is a new journey into a fairy tale everytime.
Contact Info
Marina Sciascia
Stafford, VA,USA
Dharma Products Used
Please see the description for a list of products used.
Customer Comments
Show me another
Leave a comment
If you'd rather speak with a human, please call toll-free from anywhere in the U.S. or Canada M-F 8am to 5pm PST
Phone: 800-542-5227
Copyright © 2013 Dharma Trading Co. All Rights Reserved.
Drag and Drop chips to the Palette first.


text:
I recently wrote an article on evidence-based practice for The Clarion, the newsletter published by ICAN and sent to it's subscribers. I thought it fitting to dedicate this week's installment of "Birth News Update" to the most current information in cesareans and VBAC. Here are the articles I used as references in my writing:
This document from ACOG sets new goals for the obstetrical practice as a whole to re-evaluate their standard practices and make necessary changes to reduce the primary cesarean rate:


text:
Live updates
Full time
The match has ended.
Second half kick-off
The second half has started.
The referee blows for half time.
Marin Leovac receives a yellow card for dissent. Josip Pivaric is given a yellow card. Said Husejinovic leaves the field to be replaced by Jorge Sammir. Florian Mader booked. A goal is scored by Marin Leovac. The referee sends off Ante Rukavina for professional foul. Duje Cop leaves the field to be replaced by Ante Rukavina. A goal is scored by Marko Stankovic. Junior Fernandes booked. Rubin Okotie joins the action as a substitute, replacing Philipp Hosiner. Marcelo Brozovic replaces Zvonko Pamic. Arijan Ademi is given a yellow card. Tomas Jun goes off and Alexander Grunwald comes on. Thomas Murg joins the action as a substitute, replacing Daniel Royer.
The game kicks-off.


text:
Ghouls Come Out To Play!
From my family to yours – Happy Halloween!
Same to you, Tania.
My Church did a "trunk or treat". We parked in front of the Church, decorated our trunks, nothing scary, though. Then passed out candy. I decorated the back of our Blazer with a Route 66 theme. We all had fun.
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Below you can find all the scoop on ABC's new and returning shows from the Television Critics Association winter TV previews.
Body of Proof producers on Season 3 revamp: "We wanted to inject more octane in the show"
ABC boss on fall failures, revitalizing Dancing and looking forward to S.H.I.E.L.D.
Bunheads creator defends show's slow pace: "Longevity is important"
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From The Ground Up
Tennis has been around since ancient times, but your tennis courts don't have to look like they it. If courts suffer from sagging fences, cracked surfaces and torn nets, it is time for a makeover.
Before the maintenance department gears up for one more round of cleaning, filling, fixing and resurfacing the courts in the spring, create a list of priorities that will help turn a crumbling facility into a smooth project. Are you trying to buy some time before completely refurbishing courts, or is the time now? Is only color-coating an option? What about those cracks? How long will the repair work take? And, equally important, how much will it cost?
Decisions, Decisions
Knowing how much attention a tennis court requires will be important in preparing the budget. Before getting the first bid for a project, look at where courts are located, who uses them, and how weather affects the playing surface. Durability and turnaround time on repair may be factors in the decision. Are courts located in a shady area or does the sun beat down, causing glare and unbearable surface temperatures? Examine surfaces that stay cool and reduce glare. If weather brings lots of rain, a surface that dries quickly is important. How much time does staff have to devote to court maintenance? If they are already stretched to the limit, a low-maintenance surface is vital.
Digging For Answers
Regular maintenance of tennis courts is a necessary evil. This means routinely filling in cracks and applying an acrylic coating overlay, re-stripping and making necessary net repairs. But if your court seems to have more cracks and dips each year, it is time to have the area under the court analyzed. Mark Montemayor, president of Environmental Sport Surfaces, recommends a geotechnical engineer do the analysis. Oftentimes, cracking is "a symptom of problems underneath." Generally, it costs less than $1,000 to analyze the dirt and asphalt under the court, which will reveal if you need to replace the base or the asphalt, re-grade or patch and re-surface.
If patching is an option, there are different products available from elastic crack filler to an actual patch offered by Armor Crack Repair System. The latter is a membrane-like patch that is placed over the crack and overlaps onto the surrounding area. It forms a bond that allows for the cracked area to breathe, or move with temperature changes, which is important for avoiding additional or new cracks. As with any other crack repair, the surface then can be coated with your choice of acrylic overlay colors. When professionally applied, the Armor Crack Repair blends into the court, leaving a level playing field. This system can be used in most parts of the country and lasts for 10 years. Before repairs can begin, however, the surface should be clean and stable. Pressure-washing and removal of any loose surface material are recommended.
Resurfacing–Making Old New
When a patch-type surface repair is not an option due to extensive cracking and divots, Premier Court offers an alternative option–a complete tear-out and rebuild. The company's surface is a polyurethane covering made of the same material used for the insoles in tennis shoes. As a free-floating system, it is put over the current surface, then color-coated with acrylic overlay. The whole process takes seven to 10 days, can be used on both indoor and outdoor courts, and is applicable to courts anywhere in the country. Jeff Henderson of Tennis Technology explains the four-step process:
· The court is leveled with a leveling compound, and cracks are filled
· The Premier Court material is rolled onto the court surface
· A color-coated acrylic overlay is applied
· The court is stripped and nets are replaced
Although the cost to have a Premier Court surface applied is about $35,000 for two courts, the product comes with a 25-year warranty, which requires the court be color-coated every five years at a cost of around $3,000. The product needs to be applied when the court surface temperature is 140 F, so most courts will have to be done in the summer months. Henderson explained the 140 F temperature is achieved on a day that is 80 F and sunny or warmer. "If there's a cloud in the sky, we can't do it."
Starting From Scratch
Page 1 of 2 | Next page
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5-slot Slider Press with Cooking Handle by Weston
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- Cleaning & Care: Hand Wash
- Dimensions: 3x4x11-in.
- Material: Aluminum
- Origin: China
- Weight: 2-lbs.
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We found this to be a very good slider press, the sliders are moist and very tasty. We enjoy it at least once a week.I recommend this product.
Nice product
Used as a slider press only and not as a cooker, works well as a press I have not tried it as a cooker. Not dishwasher safe, but clean up was easy. I did use cooking spray before starting to make burgers and sliders came out perfect.I recommend this product.
Customer Reviews for 5-slot Slider Press with Cooking Handle by Weston
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4.5 out of 5 stars, based on 2 ratings
100% of reviewers recommend this product
100% say this is a "good value"
Nice product
Used as a slider press only and not as a cooker, works well as a press I have not tried it as a cooker. Not dishwasher safe, but clean up was easy. I did use cooking spray before starting to make burgers and sliders came out perfect.I recommend this product.
- May 29, 2012
- By: Thomas
- From: PA
- I Cook: Every Day
- Style: Professional
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I can't even imagine how much I'd want to bash my head into a wall if I attempted to set up redirects...
Blag Hag has moved!
Monday, September 19, 2011
I hate technology
I can't even imagine how much I'd want to bash my head into a wall if I attempted to set up redirects...
54 comments:
Instructions these days are for shit. I have actually read documentation that said, "Here's the ____ button, its function is pretty self-explanatory."ReplyDelete
You may need to migrate the entire database over that has comments...From my experience managing and building Wordpress, that's one of the only ways to ensure migration goes smoothly. How far into your site does Blogger let you go?ReplyDelete
- SelfificationSeptember 19, 2011 at 3:54 PM
And this is why open data champions *hate* walled gardens and want open standards and easy migration toolkits. The sad part is that the conversion you are trying to do is actually pretty "open" - it's just completely dense and mired in technical detail. Imagine migrating out of facebook, or migrating from windows to linux or migrating data from an iphone to an android.ReplyDelete
I'm just going to hijack Jen's pain to point out what that jerk who insists in you sending him a text document or a pdf instead of a word document or a ppt or that other jerk who wants you to send him an email and not a facebook message are trying to do - they simply want it to be possible to get to their data 10 years from now without having to jump through a pile of hoops.
I'm a developer with WordPress experience and no Disqus experience (and right off the bat when it appeared this year, I didn't like Disqus -- why can't I read Boing Boing comments on my mobile phone unless I click "go to full site" once per hour of browsing?!)ReplyDelete
Anyway, I can't promise any quick turnaround, but feel free to contact me privately and I'll see if I can help.
- schismtracerSeptember 19, 2011 at 4:36 PM
This isn't help, per se, but I have seen several other blogs attempt this sort of move, and, every time, Disqus simply didn't cooperate, whether they were moving to a Disqus system or away. Hate to say it, but it might be a lost cause.ReplyDelete
Maybe not quite a lost cause. It would suck if we had to do this, but you could conceivably write a script to screenscrape the comments from Disqus to read them into a temporary database. Once you have them on your local machine, you can always write comments into WordPress using WordPress' API. No promises; just saying it should be theoretically possible.ReplyDelete
i've managed to screw up my update of wordpress so i'm keeping my mouth shut...ReplyDelete
As a long-time WordPress user and 9-to-5 code monkey, my offer of help is still open. :) Feel free to send me an e-mail if interested.ReplyDelete
Hi Jen,ReplyDelete
I just read your blogpost and was a little confused about the migration you were trying to accomplish. Could you send me an email with the guide you used? I'd be more than happy to help you solve this.
Oh yeah I 100% agree with this.ReplyDelete
Nothing is more annoying than poorly written documentation. I once had to figure out how to do a vital function, the steps changed for the new version of the software and since I'm *usually* the techie in the office I was tasked to find out how it was done:
A) If you want to do X read FAQ A.
B) Unfortunately FAQ A is for the previous version of the software, your question is covered under FAQ B.
C) FAQ B is for general questions on this version, your question is more advanced so you need to read FAQ C.
D) FAQ C is for the advanced functions but what you want to do was already covered under the basic software manual found in FAQ A.
E) Go to step A).
Is it just me, or are no comments on any post prior to this one showing up now?ReplyDelete
It's not just you, they're all gone.ReplyDelete
- AzkyrothSeptember 19, 2011 at 9:14 PM
Aww, fuck.ReplyDelete
Wow, attempting to migrate comments has actually caused them to vanish? That's really not good.ReplyDelete
- SonofRyanSeptember 20, 2011 at 7:35 AM
I was wondering where all the comments have gone. (I really really want to just go through all of the now empty threads going "FIRST", but I won't)ReplyDelete
Technical authors get paid for writing words, so they write a lot to justify their fee, why say anything in a ten words when a thousand pays better!ReplyDelete
So, yeah, I'm responsible (somehow) for those comments disappearing. In exporting Disqus to an XML file, integrating Disqus with a temporary Wordpress blog, and attempting to make it sync comments to that blog's database, it decided that all the URLs were wrong and none of the threads where the comments should be, are the right URLs. Long story short, Disqus has all the comments but doesn't know where they go any more.ReplyDelete
We have all the comments, though. Don't worry. They won't disappear entirely. I'm in the process of building a map for what comments go on what post on my temporary Wordpress install. Then I'm going to import them, and I'll even try to preserve threading. If I'm worth my salt, all the comments will be over at FtB before the week's through -- even the ones Disqus decided not to display any more.
- Phillip2September 20, 2011 at 10:32 AM
I know this is off-topic but maybe I'll get a response here. I wouldReplyDelete
really like a separate RSS feed for comments. Many of my favourite
blogs have them. Especially on a blog with many comments like this one,
one needs some method of following new comments which is better than
looking at (in theory) all old posts.
If I just can't find it, someone point me to it. If there isn't one, why not?
Also, can you have a link to the previous and next posts at the top and/or bottom of each post?
Technology -- great when it works -- shit when it doesn't!ReplyDelete
Jobs is such a great inventor. Everyone loves him so there are many people
mourned on his death. He invented many great devices like iPhone and create
some better icons for windows. Rest in peace, Sir.
Jobs is such a great inventor. Everyone loves him so there are many people
mourned on his death. He invented many great devices like iPhone and create
some better icons for windows. Rest in peace, Sir.
Heaven when it works...hell when it don't.ReplyDelete
I really think that now a days lots of blogs are coming with disqus commenting and found very nice discussion going out there so its your luck when its work for you and its very frustrating when it dont'ReplyDelete
Disqus can Help You Combat Blog Comment Spams… or Not?ReplyDelete
Such a great information and I've been looking for this..ReplyDelete
My opinion Disqus is great, I've been using is successfully for some time, but I just turned on Blogger's Mobile feature and I recognizes that Disqus doesn't work on it.ReplyDelete
I really liked the post and great tips..even I also think that hard workReplyDelete
is the most important aspect of getting success keep it up
Hi! I'm impressed, I must say. Really rarely do I encounter a blog that's both educative and entertaining,ReplyDelete
Do you think this imformation? About personal estimation, I see this review is fantastic. It take for you necessary knowledge. Thank for share!ReplyDelete
blog, surprisingly illuminating. I plan
to suggest this message to all of my partners.
- sophiaissophiaFebruary 25, 2012 at 6:19 PM
HYLYQ2012279294861 istaste and got Monster Beats Headphones up quickly. A short Beats By Dre MLB walk to the kitchen, that Beats By Dre NFL was what she needed. SoNew Balance Sneakers she took a short walk to the New Balance A03 kitchen, where she New Balance a20 Navajo Shoes opened the refrigerator, reached Nike Soccer Cleats for the cream jug, opened Nike CR Mercurial Vapor Superfly the freezer door and withdrew Nike CTR360 Elite a can of filter coffee. With shox nz one hand on the cold-water Nike Shox R4 tap to run water for her Nike Shox R4 LE coffee, she looked around wide-eyed, as Women Running Shoes if she had never seen the room before. Looked at the flaws in the wallpaper, at the smug philodendron in its basket hung from the ceiling, at Burberry Running Shoes the, black pussy-cat clock wagging Dsquared Running shoes its tail and rolling its eyesReplyDelete
The term of Technology has changed considerably more the last 200 years. The term of technology was often connected to technical education, as in the Massachusetts Institute of Technology.ReplyDelete
That was really a bad experience and you had a hard times in transferring your blog to one another but that will only take a matter of adjustments and learning, I'm sure you'll learn how deal with it soon.ReplyDelete
Well, interesting post,ReplyDelete
wow.. great info.. thanks for this mate.. i will surely share this one….ReplyDelete
Specialized writers get bought writing terms, so they compose a lot to rationalize their fee, why say anything in a ten terms when a million will pay better!ReplyDelete
Great tips. Definitely something I'll be using for myself, and for sharing with others.ReplyDelete
Disqus had been really famous for many bloggers, for with disqus they can easily monitor their comment..ReplyDelete
I have no more idea about it.Disqus is all about alteration the way humans anticipate about altercation on the web. We're big believers in the conversations and communities that anatomy on blogs and added sites.ReplyDelete
It is a well executed post. I like the diagram most. It is aReplyDelete
helpful informative post. Thanks for sharing this great information.
Thanks forReplyDelete
providing this type of very helpful information. I enjoyed reading it,it is
excellent! Thanks a lot!
Hello friend!!ReplyDelete
That article is so interesting and makes a very nice image in my mind. That is very much helpful in nominating the board of directors.
Many technological techniques produce unwanted by-products, known as contamination, and lessen organic options, to the hindrance of the Earth and its atmosphere.ReplyDelete
Disqus is all about alteration the way humans anticipate about altercation on the web.I will surely share this one….ReplyDelete
- myjobvacancies123May 20, 2012 at 3:04 AM
Technology changes all the time unfortunately bringing with it both good and bad. Some systems are rubbish others work you just have to try and sort the good from the bad. Looking for a new job why not try http://www.jobsearchonlineuk.co.uk they have thousands.ReplyDelete
- MonirulMay 31, 2012 at 3:33 AM
found your website perfect for my needs. It contains wonderful and helpful
posts. I have read most of them and got a lot from them. To me, you are doing
the greReally i am impressed from this pos
This really is one of the best intros on the subject I have ever read. I have been doing a lot of research and have read through hundreds of posts.
- larry77889July 22, 2012 at 8:43 PM
I bought some really cool iphone case,ReplyDelete
will you try it?
I didn't like Disqus -- why can't I read Boing Boing comments on myReplyDelete
mobile phone unless I click "go to full site" once per hour of
browsing?!) And Disqus doesn't get along with my Opera browser
very good open the championReplyDelete
Now days PBX come packed with a lot of features. You can basically customize your business phone service to fit your business needs. When you see the features, you will know how your current phone system is not good enough. I have been using hosted pbx from Telcan. With this business phone service, I can customize the welcome greeting, route calls to multiple numbers, even program what phone number to call at what time, have a professional voicemail, get my voicemail emailed and the list goes on. It is very easy to set up using wizard. Check out PBXReplyDelete
- JenniferAugust 2, 2013 at 12:12 AM
Nice post!! Thanks for sharing your thoughts. It was fun reading this. http://www.yourmobileplace.comReplyDelete
- JenniferAugust 10, 2013 at 3:52 AM
Fantastic post. Thanks for sharing. I had a great read. www.yourmobileplace.comReplyDelete
- Melissa parkerMay 5, 2014 at 3:21 AM
Thank you forReplyDelete
interesting tips. I came to know many important points. Keep sharing with us.
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Get a French or One Colour Polish Mani-Pedi plus Paraffin for Hands & Feet w/ Hot Oil, Hair Wash & Blow Dry starting from AED 39 [Up to 71% off]
In a Nutshell
- Salon is conveniently located on Electra Street at the City Seasons Building
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Option 3: AED 99 instead of AED 320
- Manicure and Pedicure
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The Fine Print
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Voucher not valid for use from 17th to 21st Aug 2012
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Newly polished nails tend to be cautious not to hit the keyboard with force and refrain from pointing at someone without valid reason. Prettify nails and make them behave with today's Groupon: treat nails to a manicure and pedicure service with more at Morgan Beauty Center starting from AED 39.
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Pittsburgh, which is under a state of emergency in anticipation of weekend flooding, might witness an outbreak of the "Blue Flu," an epidemic of militant petulance resulting in a mass "sick-out" by police.
As has been the case elsewhere, the Pittsburgh plague is an acute reaction by tax-engorged union police to what they consider an intolerable affront: A judge recently dismissed spurious criminal charges against 18-year-old Jordan Miles, who was beaten by police on January 12.
While walking to visit his grandma, Miles, an honor student at a the nearby CAPA high school, was swarmed and beaten by three undercover street cops with the Pittsburgh Police Department.
The assailants claimed to have seen a "heavy object" in the young man's coat that they suspected was a weapon; it proved to be a bottle of Mountain Dew. Miles fled after the attackers demanded money and drugs; after he slipped and fell, he was beaten, kicked, and mauled so severely that he thought he was going to die.
As is usually the case when an innocent person suffers a criminal assault by police — and as is always the case when the innocent person tries to protect himself — Miles was hit with several contrived criminal charges, including "aggravated assault" (meaning that he made physical contact at some point with one of the consecrated beings who attacked him), resisting arrest (which is not a crime, but a common law right), "loitering," and "prowling."
The last two charges were products of undisguised perjury. Monica Wooding, the resident who was supposedly the victim of Miles's intrusion, contradicted the affidavit filed by the cops who assaulted the young man, telling District Judge Oscar Petite Jr. that she had never told the police that she didn't know Miles and had denied him permission to be on his property. This led Judge Petite to dismiss all of the charges against Miles.
Judge Petite's courtroom was packed with police officers when the decision was announced. One of them, Chuck Hanlon of the local Fraternal Order of Police, declared that his tax-feeder union would "lobby the district attorney pretty hard to refile those charges" against Miles.
Attorney Bill Diffenderfer, who represented the subsidized thugs who beat Miles, seized on a trivial scheduling anomaly as a pretext for demanding a second hearing. Judge Jim Motznik was scheduled to hear the case on March 4, rather than Judge Petite. However, Judge Petite had been slated to hear the case weeks earlier before it was postponed — because the officers failed to appear at the hearing.
In other words, the case was heard by the same judge originally scheduled to hear it. Yet Diffenderfer insinuated that Judge Petite's action in hearing a case assigned to him suggested that the judge — rather than the police assailants, who didn't attend the earlier hearing — was acting out of corrupt motives.
"I certainly hope the district attorney … looks into this and does the right thing, re-files the charges in front of a magistrate who has absolutely no interest and is not a magistrate who's asking to hear the case," a theatrically outraged Diffenderfer told a the local CBS affiliate.
In keeping with standard practice, Miles's assailants are on paid vacation while the department pretends to conduct an official inquiry. The city council, under pressure from understandably outraged city residents, is exploring a package of proposed "reforms," some of which would include "racial sensitivity" training that would exacerbate tensions while doing nothing to address the problem of police impunity.
Not content to prolong the legal torment of an innocent teenager who already suffered a severe beating, the police union is seeking to capitalize on a potential crisis by way of a staged "sick-out" by officers who take inconsolable offense at the thought that there may be professional and legal consequences for beating innocent people on the street.
5:14 pm on March 11, 2010 Email William Norman Grigg


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Cancer Patients Struggle as Drug Costs Soar: Study
Many with insurance can't afford out-of-pocket expenses for meds, copays, researchers say
TUESDAY, June 7 (HealthDay News) -- Increasing out-of-pocket expenses forces many cancer patients in the United States to forgo drugs and doctor appointments and to cut back on food and other necessities, a new study reveals.
The researchers looked at 216 cancer patients who sought help from the national nonprofit HealthWell Foundation, which helps underinsured patients afford expensive medications. All but one patient had insurance, two-thirds were covered by Medicare and 83 percent had prescription drug coverage. Most of the patients were women (88 percent) with breast cancer (76 percent).
The patients' out-of-pocket expenses averaged $712 a month for things such as prescription drugs, doctor visit copays, lost wages and travel to medical appointments. These expenses were a significant problem for 30 percent of the patients and a catastrophic problem for 11 percent, according to the researchers at Duke University Medical Center and the Dana-Farber Cancer Institute.
The study didn't examine whether patients suffered worse outcomes because of treatment choices they were forced to make due to financial problems. However, the researchers did find that patients took fewer medications due to costs and were less satisfied with their care when out-of-pocket expenses caused hardship.
The data and conclusions of this study, which was scheduled for presentation Monday at the annual meeting of the American Society of Clinical Oncology in Chicago, should be viewed as preliminary until published in a peer-reviewed journal.
"Overall, this study provides a patient-centered view of a reality of modern day cancer care -- something that we call 'financial toxicity,'" senior author Dr. Amy Abernethy, an associate professor in Duke's medical oncology division, said in a Duke news release.
"We used to think about chemotherapy toxicity in terms of bad side effects like vomiting, nerve pain, confusion and risk of fatal infection. Now we are starting to think in terms of how treatment choices impact real aspects of daily living such as the ability to buy groceries or not," she added.
More information
The American Society of Clinical Oncology has more about the cost of cancer care.Robert Preidt SOURCE: Duke University Medical Center, news release, June 6, 2011 Related Articles
- Bone Drugs May Protect Against Endometrial Cancer
December 22, 2014
- Lynparza Approved for Advanced Ovarian Cancer
December 19, 2014
Learn More About Sharp
Sharp HealthCare is San Diego's health care leader with seven hospitals, two medical groups and a health plan. Learn more about our San Diego hospitals, choose a Sharp-affiliated San Diego doctor or browse our comprehensive medical services.
Copyright © 2011 HealthDay. All rights reserved.


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We have listed all of the Willard food pantries that we have found. With help from users like you we have compiled a list of some. If you know of a food pantry that is not included here, please submit new food pantries to our database by going to the ADD A LISTING link on the header of our website.
We checked and did not find any Food Pantries in Willard, we searched all nearby Food Pantries within 30 miles of Willard. We list the distance of each food location from Willard to assist you in your search for help.If you know of any programs in Willard please contribute by Adding a New Listing Here.
View Full Address
Springfield , MO - 65803
Food Pantry Location: 10.25 miles from Willard
C-Street Connect at Crimson House is a food pantry open twice a month to serve those in need of food and commodities in our community. The doors are open every 2nd and 4th Tuesday of the month, from 1:00-5:00PM.Go To Details Page For More Information
View Full Address
Springfield, MO - 65802
Food Pantry Location: 12.05 miles from Willard
Crosslines is a client choice emergency food pantry serving the residents of Greene County Missouri. Crosslines hours: M-F 9:00 am-1:45 pm & every 4th Saturday 9:00 am-Noon Crosslines also offers the following services: Winter Coats, Layettes for Newborns, Prenatal/Children\'s Vitamins Rental & Mortgage Assistance Fuel Vouchers and Bus Passes Voice MailGo To Details Page For More Information
View Full Address
Springfield, MO - 65801
(417) 865-3411
Food Pantry Location: 12.42 miles from Willard
Food bank hours: Open Mon-Thu 8am-4:30pm; Fri 8am-4pmGo To Details Page For More Information
View Full Address
Nixa, MO - 65714
417 724-2500
Food Pantry Location: 18.76 miles from Willard
Least Of These is a food pantry and free clothing closet serving families in need in Christian County, MO Open Monday, Wednesday and Friday from 8 am until 1pm, and the first Wednesday of the month from 4-6:30pm for working families. Families may come for food and clothing assistance once a month. Hygiene and cleaning supplies are given out 5 times a year. No appointmentGo To Details Page For More Information
View Full Address
Aurora, MO - 65605
Food Pantry Location: 27.80 miles from Willard
Harvest Food Pantry distributes food once a month. We also assist families in emergencies. We do not have set pantry hours. You can call 417-229-2430 and someone will meet you at the Church for services.Go To Details Page For More Information


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The hearing of the evidence in the first part of Stephen Lee's appeal against his 12-year ban from snooker has ended.
The 39-year-old from Trowbridge was given the suspension last September after being found guilty of seven charges of match-fixing dating back to 2008 and 2009.
A World Professional Billiards and Snooker Association statement read: "The hearing of the evidence in the first part of Stephen Lee's appeal has been concluded.
"The independent tribunal has risen to consider written submissions from the parties.
"No date has been set for the outcome. The tribunal has undertaken to deliver the outcome expeditiously."
The former world number five has protested his innocence throughout the investigation.


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Merck Statement On Venezuelan Currency Devaluation
Merck, known as MSD outside the United States and Canada, said today that it has completed a preliminary assessment of the impact of the Venezuelan government's intention to devalue its currency effective Feb. 13, 2013.
As a result of the devaluation, the company will incur a one-time, after-tax loss due to exchange of approximately $0.05 per share in the first quarter of 2013 related to the remeasurement of the local balance sheet at the date of the devaluation. Also, the company expects the impact of the devaluation on ongoing operations to be approximately $0.02 per share spread over the balance of 2013.
Since Jan. 1, 2010, Venezuela has been designated hyperinflationary and, as a result, local foreign operations are remeasured in U.S. dollars with the impact recorded in income. On Feb. 8, 2013, the Venezuelan government declared its intention to devalue its currency (bolívar fuerte). The official exchange rate is expected to move from 4.30 VEF/$ to 6.30 VEF/$.
The effects of the devaluation do not change the company's full year 2013 GAAP (generally accepted accounting principles) or full year non-GAAP EPS (earnings per share) guidance ranges.The company is providing guidance about its expectations for the first quarter of 2013, which includes the impact of the devaluation in the quarter. Merck expects first-quarter non-GAAP EPS to be between $0.76 and $0.78, and the GAAP EPS range to be $0.37 to $0.42. A reconciliation of anticipated first-quarter 2013 EPS as reported in accordance with GAAP to non-GAAP EPS that excludes certain items is provided in the table below.
$ in millions, except EPS amounts
|First Quarter 2013
|$0.37 to 0.42
Difference 1
|0.39 to 0.36
Non-GAAP EPS that excludes items listed below 2
|$0.76 to $0,78
Acquisition-related costs 3
|$1,280 to $1,200
|Restructuring costs
|175 to 125
|Net decrease (increase) in income before taxes
|1,455 to 1,325
|Estimated income tax (benefit) expense
|(255) to (225)
|Decrease (increase) in net income
|$1,200 to $1,100
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Perfect Picnic
Lower East Side
- $$
Time Out says
Posted: Wed Jul 6 2011
Lackadaisical locavores can grab a ready-made park basket at this Lower East Side shop. The cotton tote is stuffed with New York State goodies, like Napoli bread, Salumeria Biellese cured meats and Liddabit Sweets caramels. You can supplement your pack with other products from the shelves, including Brooklyn Brine pickles, P&H Soda Co. syrups and SlantShack beef jerky.
ReviewsAdd +
Venue details
Perfect Picnic 9 Clinton St
Lower East Side
New York
- Cross Street:
between E Houston and Stanton Sts
- Venue phone:
- Venue website:
- Opening hours:
Daily 11am–7pm
- Transport:
Subway: F to Delancey St; J, Z, M to Delancey–Essex Sts
- Price:
Average picnic: $28. AmEx, Disc, MC, V
Perfect Picnic
- 9 Clinton St
Lower East Side
New York
- 212-228-2884
- perfectpicnicnyc.com
- 40.721063,-73.984157
- 9 Clinton St
- Perfect Picnic


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Join the Movement
About the Month
Learn why February is important to stopping dating abuse nationwide.
What's Dating Abuse
One in three young people experience some form of dating abuse. Get the facts.


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The cafe showcases Disney storytelling, one of the largest outdoor patios at any Starbucks, a touchscreen chalkboard and a premium barista bar.
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luvmyducks:Could be coxsackie? AKA Hand foot mouth
Actually, I wondered if it might be that. He had it about a month ago. I assumed it wasn't this time since he just had it and apparently it's rare to have more than one outbreak in the same season.
IVF #1 was a success! Harrison and Brooke born at 37 weeks. 6lbs8oz and 6lbs11oz. Loving life as a MoM.
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DeWalt DCB103 Combination Dual Port Fast Charger
DeWalt DCB103 Combination Dual Port Fast Charger
- Supports 7.2, 9.6, 14.4, and 18V batteries
- Also charges the new 12V MAX and 20V MAX batteries
- Allows for ultimate jobsite flexibility and productivity
- Batteries not included
As companies grow and create new tools and tool lines, they often create new batteries that are exclusive to a certain line. This can be frustrating for contractors, and DeWalt is as guilty as anyone else. Unlike other companies, though, DeWalt is offering a new Combination Dual Port Fast Charger, which can charge nearly every battery DeWalt has ever made. Whether you have 9.2V, 9.6V, 14.4V, 18V, 12V MAX, 20V MAX or all of the above, you will find this charger more than up to the task of recharging them. Like all of their tools, this charger is Guaranteed Tough.
The DCB103 includes:
- One (1) Combination Dual Port Fast Charger
- (Batteries not inlcuded)
Tech Specs:
- Charges: Port #1) Charges all DEWALT® 12V - 20V MAX* Li-Ion batteries. Port #2) Charges all DEWALT® 7.2V - 18V NiCd/NiMH/Li-Ion batteries (except Univolt batteries)
- Charge time: 60 minutes or less
- Status indicator lights: Yes
Most DeWalt Tools purchased on or after January 1, 2004 come with a warranty package that includes a Three-Year Limited Warranty and a One-Year Free Service Contract. DeWalt Hand Tools and Mechanics tools are covered by a Limited lifetime warranty. For specific tool exceptions and warranty information on tools purchased before January 1, 2004, please visit http://bdk.force.com/FAQ/PKB_Search?brand=DeWALT


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This letter is in reference to the Missourian's article "Talking to the water" in Thursday's newspaper. Dowsing or "water witching" is effective because what moves the sticks or pendulum is not some mysterious energy, but the response is due to very fine muscle movements within our bodies. Our physical, mental, emotional and spiritual natures speak to anyone who pays attention. Ask any yoga master.
LETTER TO THE EDITOR: Dousing can be an effective method to question lies, find water
Friday, August 31, 2012 | 12:32 p.m. CDT
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Interview with Arturo Kassel of Whisknladle Hospitality
Prepkitchen has recently opened a new patio at their La Jolla location, just in time for their five year anniversary. We interviewed Arturo Kassel, owner of Prepkitchen and Whisknladle to get the scoop on the new patio and some other fun topics including a new restaurant concept, beer in San Diego, and places he likes to go out to eat.
How has the newly renovated patio space been received, and do you see the patio space as something you'd like to incorporate into future restaurants?
It's been great. We're obviously benefiting from it.…Read more


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"This is gonna be so time consuming, babe!" said Lexi. "Don't get frustrated, babe!" Trey replied.
This challenge was pretty thrilling to watch, because adrenaline (mine included) was pumping, and for a while it seemed like the race could conceivably go in any direction. For Team Texas' part, Lexi was a good match for the job. It's true that she sometimes doesn't know things (like who Houdini was, or that the clue depicted is the symbol for the U.N. and not a "target"), but she's proven herself to be really methodical, systematic and organized as a Racer. For the Beekmans' part, Josh was well-suited to the task, too. He's good at languages - and I thought what he said about turning the challenge into a math puzzle after a certain point was smart. For the the Chippendales, Jaymes would have probably been a better match for this task. All season long he'd been learning basic phrases for each of the countries they visited.
I loved so much about this challenge: it had a "full circle" quality to it, was both mental and physical, and the location was obviously symbolic and significant. And the three teams being out there together on a warm spring night seemed peaceful, somehow, despite the high stakes. But eventually Lexi started to crumble. She's normally unflappable, but here, her frustration at not being in control really set in, and as the Beekmans and Chips calmly chipped away at the challenge, Team Texas slid from default front-runner to no-can-do. Then she got hit in the head by zai jian. My fingherrrrrrrr!!
BTW, who's hungry for a footlong merhaba?
"I love the world!" Josh exclaimed when he finished, and then it was off to the Pit Stop at Gotham Hall. The Chippendales were in hot pursuit and it then we had ourselves a taxi race between these two spectacular, lovable teams.
Inside Gotham Hall it was a scene as good as in any movie. The Beekmans -- yes, the Beekmans! -- ran in to cheering from all their cast-mates (Remember all these people we never knew?) and accepted their win with the humility and gratefulness that's been their bag all along. I loved seeing Abbie and Ryan nearly jumping out of their skin with excitement. The Twinnies cheered warmly as well. "We were underdogs," Josh said to the group, "and what I hope this proves to people — whether they're a minority or they're out of work or they're losing their house or whatever — if they just keep going and keep working as hard as they can, people will help, and at some point you will win." I love this movie!
I was surprised at how tickled my heart was at the sight of Big Rob. Now that I don't have to hear him yell at cabbies I have a weird affection for him. I loved what he said about how the Beekmans changed his views. Also, what's wrong with Will?
The Chips arrived soon thereafter. Obviously I rewound three times to confirm it: Ryan did not clap for them. After all, the Chippendales cheated Ryan out of the two million dollars that was rightfully his, remember? You don't? I don't either. Meanwhile, Jaymes looked so utterly, tenderly verklempt. Both Chips seemed really moved, and though they didn't win the one million that Jaymes wanted so much for help with his dad, they did score a couple cars and a trip and a whole new pack of BFFs who can come out and see their shows in Vegas. "Maybe the world will have a different view of Chips now," Jaymes said, as if this had been one of their objectives on the race: to raise awareness about Chippendales discrimination. Aw. I would have loved for them to be able to win that money. But something tells me they're gonna be just fine. Jaymes is a star as charming as they come, and I've no doubt he'll get scooped up by something good. Now: once more for good measure. A goodbye/Hanukkah present, if you will.
As far as I could see, Ryan didn't clap at Team Texas' arrival either. Snap! But Lexi had some lovely, teary words to share. I do have hopes that she'll get her ring soon. I know Trey's all "simmer down" about it, but that's a load, he's totally on it. I predict he'll pop the question on Valentine's Day. Don't you think? Please keep me posted if you hear anything. I will do same.
Thanks for reading these recaps. I really enjoyed doing them - and always appreciated your TAR-savvy comments. Happiest of holidays to all. Oh, and I chatted with Phil to get take on some of memorable moments from the season - do check it out if you like. It's a nice walk down memory lane.
What did you think of tonight?


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My DS got his first two teeth when he was 5.5 months actual, 3.5 months adjusted... it is definitely possible. He is now 8 months and has 4 teeth and two more about to break through!


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|Le Boisé du Lac 135 Chemin du Lac Duhamel, Mont-Tremblant (5.5 miles from Le Soleil)
Score from 37 reviews: Very goodSet near lush forests and scenic landscapes, this hotel is located on the shores of Lake Duhamel and offers an ideal location for endless recreational activities along with cozy accommodations. More…
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|Comfort Inn & Suites Mont-Tremblant 860 rue Lalonde, Mont-Tremblant (6.2 miles from Le Soleil)
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|Gite La Tremblante 1315 Montée Kavanagh, Mont-Tremblant (4.6 miles from Le Soleil)
Score from 84 reviews: WonderfulThis cozy bed and breakfast is a 10-minute drive from Mont Tremblant. The guest house offers a full morning breakfast, an outdoor swimming pool and nature views. More…
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|Auberge Le Voyageur 900 Rue Coupal, Mont-Tremblant (5.1 miles from Le Soleil)
Score from 82 reviews: WonderfulThis Mont-Tremblante bed and breakfast is located one mile from the Saint Jovite Airport. The property features free Wi-Fi and cycling on the Le P'tit Train du Nord trail. More…
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|Auberge Mountain View Inn 1177 rue Labelle, Mont-Tremblant (4.8 miles from Le Soleil)
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On June 24, 2011, 42 years after the gay rights movement began with the Stonewall Riots in New York City, Governor Andrew M. Cuomo signed the Marriage Equality Act into New York State law. After a long political battle and a narrow 33-to-29 vote by the New York State Senate, New York joined Connecticut, Iowa, Massachusetts, New Hampshire, Vermont and the District of Columbia as the seventh (and most populous) jurisdiction to legalize the marriage of same-sex couples (we'll refer to Connecticut, Iowa, Massachusetts, New Hampshire, New York, Vermont and the District of Columbia as "same-sex marriage states").1
In same-sex marriage states, same-sex couples can avail themselves of state laws, including gift and estate tax laws, which are typically incorporated into effective and efficient estate planning. However, the Federal Defense of Marriage Act (DOMA) is the proverbial thorn in the side of same-sex couples nationwide. DOMA denies same-sex couples many federal rights and privileges enjoyed by opposite-sex married couples. The differences between state and federal laws, particularly tax laws, create a morass of rules and regulations to be deciphered by attorneys, tax professionals, scholars and academics. Conflicting state and federal marriage laws make estate-planning decisions more complex for many same-sex couples, especially when the goal is to minimize exposure to lifetime and after-death taxes.
Evolution of DOMA
The first state to recognize same-sex marriage was Hawaii with the 1993 landmark decision in Baehr v. Miike.2 In Baehr, the Hawaii Supreme Court concluded that although Hawaii's constitutional right to privacy didn't include a fundamental right to same-sex marriage, marriage is a "basic civil right" under state law and, absent a "compelling reason," the state's refusal to issue a marriage license to a same-sex couple violated the state's equal rights statute. After years of litigation, legislative commissions and voter-approved constitutional amendments, the Supreme Court's decision in Baehr was reversed and same-sex marriages were banned in Hawaii.3
Baehr prompted a nationwide debate on same-sex marriage. Proponents supported granting marriage rights to same-sex couples, while opponents feared the effect that legalized same-sex marriage in Hawaii might have in other states.4 After all, full faith and credit would be given to a same-sex marriage legally performed in Hawaii and, under then-existing principles, those couples would be entitled to the same protections under federal law as those in an opposite-sex marriage.
In response to this growing debate, both houses of Congress passed DOMA by an overwhelming majority and then-President Clinton signed it into law on Sept. 21, 1996. DOMA includes two key provisions: The first provides the explicit authorization that no state is required to give effect to the laws of any other state that recognizes the "relationship between persons of the same sex" as a marriage.5 Effectively, this provision authorizes each state to disregard the principles of full faith and credit with respect to same-sex marriages that may be legal in other states.
The second provides a federal definition of "marriage" and "spouse."6 Under this definition, which applies to all federal laws and programs, "marriage" is limited to "only the legal union between a man and a woman as husband and wife," and the term "spouse" refers only to "a person of the opposite sex who is a husband or a wife."7 This provision requires valid same-sex marriages to be disregarded, whenever marital status is a determinative factor, for purposes of all federal laws and programs. Under federal law, same-sex couples are, for all intents and purposes, treated as strangers. For example, a surviving spouse in an opposite-sex marriage has an automatic right to the retirement and social security benefits of the deceased spouse, while a surviving spouse of a same-sex couple would not. As of Jan. 23, 2004, there were 1,138 federal statutory provisions in which marital status "is a factor in determining or receiving benefits, rights and privileges."8
Efforts to overturn DOMA appear to be increasing.9 Early this year, President Obama ordered the Department of Justice (DOJ) not to defend DOMA in court.10 The "Respect for Marriage Act," which was first introduced in September 2009, was reintroduced on March 16, 2011 and would essentially repeal DOMA and permit the federal government to recognize validly performed same-sex marriages. The bill remains in committee. The DOJ is also supporting litigants who are challenging DOMA based upon the equal protection clause of the U.S. Constitution and the federal government's prior consistent deference to state definitions of marriage.11
Same-Sex Marriage States
In same-sex marriage states, married same-sex couples enjoy the full panoply of protections, safeguards and obligations afforded to married opposite-sex couples when it comes to state taxes, property distribution at death, personal health care benefits and custody and visitation of children. While the result in each same-sex marriage state is the same, some states established these equal rights through court decisions, while others passed affirmative statutes.
On May 17, 2004, Massachusetts legalized same-sex marriage as the result of the Supreme Judicial Court of Massachusetts' ruling in Goodridge v. Department of Health,12 that permitting only heterosexual couples to marry violated the Massachusetts constitution.
For purposes of this article, California isn't a same-sex marriage state. Notably, however, in May 2008, in In re Marriage Cases,13 the California Supreme Court found that limiting marriage to opposite-sex couples violated the state constitutional rights of same-sex couples and couldn't be used to prevent same-sex couples from marrying. Voters overturned this decision via Proposition 8 in the November 2008 election, but it's now undergoing challenge in the federal courts.14 California currently doesn't issue same-sex marriage licenses and doesn't recognize same-sex marriages performed in California, unless the marriage was validly performed during the six months in 2008 when such marriages were legal within the state.15
In October 2008, Connecticut legalized same-sex marriage when its Supreme Court held, in Kerrigan v. Commissioner of Public Health, that the Connecticut Constitution protects the right to same-sex marriage.16 The court reasoned that it was a constitutional infirmity to create a separate class of civil unions excluding same-sex couples from the institution of civil marriage. The Kerrigan decision was codified in Public Act 2009-13, which defines marriage as a legal union of two persons.17 All civil unions (which had been issued in Connecticut since 2005) were automatically converted into marriages on Oct. 1, 2010, unless otherwise ended by divorce, dissolution or annulment.18
Iowa followed suit in 2009, when its Supreme Court, by unanimous decision, held in Varnum v. Brien that "the language limiting civil marriage to a man and a woman must be stricken from the statute, and the remaining statutory language must be interpreted and applied in a manner allowing same-sex couples full access to the institution of civil marriage."19 New Hampshire, Vermont and the District of Columbia also legalized same-sex marriage, via legislative reform, in 2009.20
Most recently, in June, New York's Marriage Equality Act was signed into law.21 The Marriage Equality Act amended New York's Domestic Relations Law to state that a "marriage that is otherwise valid shall be valid regardless of whether the parties to the marriage are of the same or different sex." The Act also explicitly provides that "no government treatment or legal status, effect, right, benefit, privilege, protection or responsibility relating to marriage, whether deriving from statute, administrative or court rule, public policy, common law or any other source of law, shall differ based on the parties to the marriage being the same sex or a different sex." The legislature intended that marriage of same-sex and opposite-sex couples be treated equally in all respects under the law.22
Impact on Estate Planning
The common thread among same-sex marriage states is to provide the full spectrum of legal rights and responsibilities afforded to opposite-sex couples without any restrictions or limitations. For example, spouses in same-sex marriage states have the right to intestate succession from and the right of election against the estate of the deceased spouse. A spouse would also be the first in line to act as executor or personal representative of a deceased spouse's estate if the deceased didn't leave a will. In addition, spouses in same-sex marriage states have hospital visitation rights and the right to make medical decisions for their spouses.23
Yet, same-sex couples and unmarried partners still face many legal uncertainties due to varying degrees of protection afforded them by the federal and state governments. Estate planners for same-sex couples must carefully navigate the constantly changing legal landscape. Comprehensive planning and proactive measures are essential to protect the same-sex couple's finances, inheritance rights, property distribution and economic arrangements after their deaths.
Unified Credit and Marital Deduction
The federal gift and estate tax laws now provide for a $5 million "unified" lifetime exemption from the gift and estate tax. The exemption is "unified" because any exemption the taxpayer doesn't use during his lifetime on gifts may be used for property included in the taxpayer's estate upon his death. Any gifts or transfers of property upon death that exceed this $5 million amount are taxed at a rate of 35 percent. The $5 million exemption and the 35 percent rate are in place until Dec. 31, 2012 and will become a $1 million exemption and a 55 percent maximum rate beginning in 2013 unless Congress acts. For purposes of this article, we've assumed the current 2011 exemption and rate.
There's also an unlimited federal gift and estate tax marital deduction. This unlimited deduction allows spouses to pass property outright, or in a qualifying trust, between them during life or at death free of any federal gift or estate tax and without using any of either spouse's $5 million unified credit.
On a day-to-day basis, the unlimited federal gift tax marital deduction allows spouses to establish joint bank accounts, give gifts to each other and provide financial support to each other without imposition of federal gift tax. These benefits are unavailable to same-sex married couples, requiring the use of an exemption for transfers in excess of the annual exclusion.
The unlimited federal gift tax marital deduction also allows spouses of disparate financial means to "equalize" their assets without the imposition of federal gift tax. Equalization typically involves the transfer by the more moneyed spouse of assets to the less wealthy spouse so that both spouses have sufficient assets to maximize their available tax exemptions. This benefit is also unavailable to same-sex couples, thereby requiring a same-sex spouse to use his exemption for transfers to his spouse.
Another benefit of the unlimited federal gift tax marital deduction is that it enables married couples to take advantage of "gift splitting," by which a gift made by one spouse to a third party will be treated for federal gift tax purposes as being made one-half by each spouse, if both spouses agree. Gift splitting is beneficial because it allows both spouses to make use of their gift tax exemptions or exclusions even if the gifted property, in fact, belonged to only one spouse. Again, same-sex married couples can't split gifts for federal gift tax purposes, which may result in the use of an exemption or the payment of tax by the spouse who makes the gift.
The unlimited federal estate tax marital deduction allows spouses to provide for one another without the imposition of estate tax and without the use of the unified credit. In addition to outright bequests, transfers to certain types of trusts, most typically a qualified terminable interest property (QTIP) trust, qualify for the federal estate tax marital deduction.24
The lack of the unlimited federal marital deduction for gift and estate tax purposes and the inability to split gifts for federal gift tax purposes results in significant tax costs to a same-sex married couple that aren't imposed on an opposite-sex married couple.
In a typical scenario, an opposite-sex married couple with $10 million in assets would like to maximize the use of both of their $5 million federal gift tax exemptions. If all of the couple's $10 million is in the name of one spouse, efficient and full use of each spouse's federal estate tax exemption may be achieved in two ways: The wealthy spouse could transfer $5 million to the less wealthy spouse by making use of the unlimited marital deduction, and then each spouse could make a gift of $5 million to the intended beneficiaries. Alternatively, the wealthy spouse may make a $10 million gift directly to the intended beneficiaries and then elect on a federal gift tax return to split gifts with his spouse.
On a federal level, an opposite-sex married couple could use both options to effectively make use of both spouses' $5 million lifetime gift tax exemptions without imposing any gift taxes. For a same-sex couple, the first scenario would result in two separate $5 million taxable gifts by the wealthy spouse and a $5 million gift by the less wealthy spouse. Both spouses' gift tax exemptions would be fully used. This transaction wouldn't be tax efficient because it "wastes" the wealthy spouse's gift tax exemption by transferring assets to the less wealthy spouse merely for it to be transferred again to a third party. The second scenario would result in a $10 million taxable gift by the wealthy spouse, fully using her gift tax exemption and no gift by the less wealthy spouse. While this scenario is slightly better for the same-sex couple than the first scenario, it's less tax efficient than the same transaction for the opposite-sex couple because it requires the payment of gift tax by the wealthy spouse. In both scenarios, the wealthy same-sex spouse would owe $1.75 million in federal gift tax that the wealthy opposite-sex spouse would not.
In a typical estate plan for a married couple, assets are divided upon the first spouse's death between a trust that doesn't qualify for the marital deduction (a credit shelter trust) and a disposition, either outright or in a QTIP, that does qualify for the marital deduction (the marital gift). In New York, a credit shelter trust is typically funded with either the amount of the New York estate tax exemption ($1 million), which ensures that there's neither federal nor New York estate tax upon the first spouse's death, or the amount of the federal estate tax exemption ($5 million), which ensures that the federal estate tax exemption is fully used on the first death, even though it would generate New York estate tax. The balance of the decedent's estate constitutes the marital gift. If a New York decedent has $10 million in assets, with $1 million passing to the credit shelter trust and the remaining $9 million passing as the marital gift, an opposite-sex married couple wouldn't pay any New York or federal estate tax upon the death of the first spouse, while a same-sex married couple would owe $1.75 million in federal estate tax. If the amount passing to the credit shelter trust is increased to the $5 million federal estate tax exemption amount, both the same-sex and opposite-sex couples would pay a New York estate tax of $391,600, but the same-sex married couple would pay an additional federal estate tax of $1,612,940.25
Due to the current disparity between state and federal law, when a federal gift or estate tax return is filed for one same-sex spouse, estate planners should consider whether to file a protective claim. For example, if a same-sex spouse makes a gift to his spouse of $1 million, the donor spouse would file a federal gift tax return reporting the gift because it exceeds the annual exclusion amount and doesn't qualify for the federal marital deduction. It may be advisable to include a protective claim on that federal gift tax return. Such a claim would essentially provide the caveat that the donor spouse is reserving his right to a refund or adjustment of taxes paid if DOMA were repealed and the federal marital deduction subsequently became available. As mentioned above, recent challenges to DOMA are on the rise and there's a real possibility that DOMA could be repealed. If that happens, the federal tax rules, including the marital deduction and gift splitting, currently now available only to opposite-sex married couples, would be applicable to same-sex married couples.
Disclaimer Planning
Married couples can use disclaimer planning to build flexibility into their estate plan. Disclaimer planning typically provides that, if the surviving spouse disclaims his interest in a portion or all of a bequest, the disclaimed property is held in a trust (typically a credit shelter trust), for the surviving spouse's benefit, that doesn't qualify for the marital deduction. This allows for flexibility to determine the extent to which a credit shelter trust is funded (for example, with the state estate tax exemption amount, the federal estate tax exemption amount or another amount) while still allowing the surviving spouse to benefit from the disclaimed property.
Generally, an individual who disclaims property can't receive any benefit from that property. However, a surviving spouse is the only exception to this rule.26 For the disclaimer to be effective for federal purposes, the disclaimed property must pass either to the decedent's spouse or someone other than the disclaiming party.27 Therefore, while opposite-sex married couples may take advantage of this type of planning without depleting the assets available to the surviving spouse, same-sex couples can't. A surviving same-sex spouse could only make an effective federal disclaimer if the disclaimed property passed to someone other than himself.
Equalization of Assets
Equalization is often recommended when one spouse doesn't have enough property to fully take advantage of his state or federal estate tax exemption. This technique is effective for an opposite-sex married couple, who may transfer property between themselves without adverse gift tax consequences. In addition, opposite-sex couples may take advantage of federal estate tax exemption "portability" for decedents dying in 2011 and 2012. Portability permits the unused federal estate tax exemption of a decedent spouse to be transferred to the surviving spouse on a filed federal estate tax return.28 Effectively, this allows the estate of the surviving spouse to use the remainder of the deceased spouse's federal exemption and his own remaining federal exemption. Opposite-sex spouses may rely on the unlimited marital gift tax exemption and estate tax exemption portability (for 2011 and 2012) to ensure that they take full advantage of their federal estate tax exemptions.
As discussed above, a same-sex married couple making the same transfer would be making a federal taxable gift that would use the donor's remaining gift tax exemption, if any, or would be subject to federal gift tax. In addition, same-sex couples can't take advantage of estate tax exemption portability because it's available only on a federal basis.29 As a result, a same-sex married couple who wants to equalize their assets to fully use their federal estate tax exemptions faces challenges that an opposite-sex married couple would not. Without proper planning, it's possible that one same-sex spouse's federal estate tax exemption may not be fully used.
The current estate and gift tax treatment of same-sex married couples and opposite-sex married couples highlights the federal distinctions, based on DOMA, despite equality under the laws of the same-sex marriage states.
Prenuptial Agreements
Despite the complex and changing landscape, there are several planning techniques that same-sex married couples in same-sex marriage states may wish to implement. As with any married couple, same-sex couples should consider the benefits of a prenuptial agreement to define rights vis-à-vis each other arising from the marriage. All of the technical requirements imposed by state law on marital agreements, such as representation by counsel and full financial disclosure, would apply equally to all married couples in same-sex marriage states. Through the use of a prenuptial agreement, a same-sex couple may selectively opt in or out of many of the rights and obligations attendant to marriage in accordance with their wishes, just like an opposite-sex couple. However, a same-sex married couple should be aware that any property settlements or payments incident to divorce pursuant to a separation agreement or prenuptial agreement are likely to constitute a gift subject to gift tax because an exclusion available to opposite-sex couples isn't available to same-sex couples.30 Same-sex couples should pay special attention when drafting and negotiating the prenuptial agreement to take into account the potential gift tax liability.
Annual Exclusion Gifts
Same-sex married couples should consider taking advantage of the same basic estate-planning techniques that are available to any other married couple, while remaining mindful of the possible impact of the lack of recognition of their marriage for federal purposes. Same-sex married couples with sufficient assets should consider making regular gifts to third parties equal to the federal annual exclusion amount. Annual exclusion gifts are gifts that can be made to an unlimited number of recipients per year, in an amount that doesn't exceed the annual exclusion amount, currently $13,000, for each recipient. Annual exclusion gifts aren't tied to marital status, so any person, whether married or unmarried, may make annual exclusion gifts to any other person. Through the use of annual exclusion gifts, a donor who has several intended beneficiaries can give away a significant amount of his assets over time. However, as discussed in more detail below, same-sex married couples should be wary of the issues surrounding spousal gift splitting when making annual exclusion gifts.
Same-sex married couples may also take advantage of the federal unlimited gift tax exemption for qualifying medical expenses and tuition payments made directly to a medical service provider or school.31 If a testator has an intended beneficiary, including his same-sex spouse, this could be a way to significantly benefit the intended recipient as well as reduce the testator's assets over time. For same-sex couples, this technique can help greatly in allowing the spouses to pay for medical and educational expenses without any concern about federal gift tax consequences.
Other Planning Techniques
The long-term objectives of a same-sex married couple can be reached via planning vehicles that don't rely on being recognized as "married" under federal law. This can be achieved through the use of regular annual exclusion gifts, as well as the use of more advanced vehicles such as a grantor retained annuity trust (GRAT) or a grantor retained income trust (GRIT), which isn't available to opposite-sex married couples. Another option would be to implement transfers that would otherwise trigger the Chapter 14 valuation rules if the marriage of the parties were recognized under federal law. Some of these techniques include the transfer of interests in closely held corporations or partnerships and the ability to hedge mortality risk.
Uncertain Future
What happens if DOMA is repealed? Will it be sufficient to simply declare DOMA unconstitutional? Will additional legislation or clarification of the definition of "marriage" under federal law be needed? Will it be as simple as the federal government declaring that federal benefits that rely on a couple's status as "married" or "unmarried" are governed by state law? Will the repeal of DOMA simply mean that the federal government may no longer refuse to recognize a marriage legally performed in a state that chooses to permit and legalize same-sex marriages? Only time will tell.
Unless DOMA is repealed or the legislature takes further action, same-sex couples seeking tax-efficient wealth management will face a myriad of challenges in preparing state and federal estate and gift tax returns. Same-sex couples, including those living in same-sex marriage states, and their estate-planning attorneys should consider the use of prenuptial agreements, consider the differences in the states' tax laws and continue to take advantage of lifetime planning opportunities available only to non-married and unrelated individuals.
— The authors would like to thank Sharon B. Soloff, an attorney in the New York office of Withers Bergman, LLP, who provided valuable feedback and assistance during the preparation of this article.
- In addition, eight other states provide same-sex couples with extensive marriage-like rights. Hawaii approves of civil unions (effective Jan. 1, 2012); Illinois approves of civil unions (effective June 1, 2011); Delaware approves of civil unions (effective Jan. 1, 2012); California recognizes registered domestic partnerships (including community property rights); Nevada recognizes registered domestic partnerships (including community property rights); New Jersey recognizes civil unions; Oregon recognizes domestic partnerships; and Washington recognizes registered domestic partnerships (including community property rights).
- Baehr v. Miike, 74 Haw. 530 (1993).
- Baehr v. Miike, No. 20371 (Hawaii Supreme Court 1999-12-09). In February 2011, Hawaii's legislature passed the civil unions bill which, effective Jan. 1, 2012, will permit all couples, whether same-sex or opposite-sex, to enter into a civil union. See www.msnbc.msn.com/id/41630515/ns/us_news-life/.
- See, e.g., John Cloud, "For Better or Worse, In Hawaii, a Showdown over Marriage Tests the Limits of Gay Activism," Oct. 26, 1998, www.cnn.com/ALLPOLITICS/time/1998/10/19/hawaii.marriage.html.
- The Defense of Marriage Act (DOMA), 1 U.S.C. Section 7 and 28 U.S.C. Section 1738C (1996), Section 2.
- DOMA Section 3.
- Ibid.
- U.S. General Accounting Office, DOMA: Update to Prior Report, Jan. 23, 2004, www.gao.gov/new.items/d04353r.pdf.
- Past attempts to repeal DOMA were unsuccessful. For example, on Sept. 15, 2009, three Democratic members of Congress introduced the Respect for Marriage Act, which would have functioned to repeal DOMA, but the bill failed.
- Press Release, U.S. Department of Justice (DOJ), Statement of the Attorney General on Litigation Involving the Defense of Marriage Act (Feb. 23, 2011).
- For example, in Golinski v. Office of Personnel Management, 764 F. Supp.2d 1178 (N.D. Cal. 2011), the plaintiff was denied spousal health benefits by her employer (the U.S. Ninth Circuit Court of Appeals in San Francisco). In support of the plaintiff's claim that DOMA "unconstitutionally discriminates" against her same-sex spouse, the DOJ asserted that "[t]he federal government has played a significant and regrettable role in the history of discrimination against gay and lesbian individuals" and that DOMA is unconstitutional. This case is pending before the U.S. District Court for the Northern District of California. More recently, in Windsor v. United States, Case No. 1:10-cv-8435 (S.D.N.Y. 2010), Edith Windsor alleges that the federal government's refusal to acknowledge her marriage to Thea Spyer, her partner of 44 years, violates the equal protection principle of the U.S. Constitution. As the surviving spouse and executor of Thea's estate, Edith claims she incurred over $350,000 in federal estate taxes because, pursuant to DOMA, the federal government didn't recognize her valid marriage under Canadian law and, as a result, she wasn't permitted to take advantage of the unlimited federal estate tax marital deduction. The United States maintains that DOMA is entitled to a presumption of constitutionality and its definition of "marriage" doesn't offend the equal protection clause. The DOJ filed papers affirmatively supporting Edith's request that Section 3 of DOMA be struck down as unconstitutional. The matter is pending.
- Goodridge v. Department of Health, 798 N.E. 941 (Mass. 2003).
- In re Marriage Cases, 43 Cal.4th 757 (2008).
- See, e.g., Perry v. Schwartzenegger, 704 F. Supp.2d 921 (N.D.Cal. 2010) (On Aug. 4, 2010, the U.S. District Court for the Northern District of California held that Proposition 8 violated the due process and equal protection clauses of the 14th Amendment of the U.S. Constitution. Judgement of that decision is stayed pending appeal to the Ninth Circuit.) See www.ca9.uscourts.gov/content/view.php?pK_id=00000472.
- Because of the limited period of validity of same-sex marriages performed in California, this article doesn't discuss California as a same-sex marriage state.
- Kerrigan v. Commissioner of Public Health, 957 A.D.2d 407 (Conn. 2008).
- Connecticut Public Act No. 09-13, An Act Implementing the Guarantee of Equal Protection Under the Constitution of the State for Same-Sex Couples (2009).
- "GLAD Guide to Connecticut Civil Unions," www.glad.org/uploads/docs/publications/ct-civil-union.pdf.
- Varnum v. Brien, 763 N.W.2d 862, 907 (Iowa 2009).
- Vermont's An Act Relating to Civil Marriage states that marriage is "the legally recognized union of two people." It further states that "[t]erms relating to the marital relationship or familial relationships shall be construed consistently with this section for all purposes throughout the law, whether in the context of statute, administrative or court rule, policy, common law, or any other source of civil law." The District of Columbia's Religious Freedom and Civil Marriage Equality Amendment Act 2009 defines marriage as "the legally recognized union of two people" and further states that "any person who otherwise meets the eligibility requirements … may marry an other eligible person regardless of gender." See Religious Freedom and Civil Marriage Equality Amendment Act 2009 (D.C. 2009). New Hampshire's legislation eliminated the exclusion of same-gender couples from marriage, affirming the legislatures' intent to permit two individuals, regardless of their sexual orientation, to marry. See HB 436-FN-Local - Chapter 59-Version adopted by both bodies.
- New York Marriage Equality Act, Legislative Bill Draft in Commission, 12066-04-I. The heavily debated legislation followed a proclamation by New York's Court of Appeals, New York's highest court, which concluded in 2006 that full marriage equality requires the legislature to act. Hernandez v. Robles, 7 N.Y.3d 338 (2006).
- Ibid., Section 2.
- Notwithstanding this automatic right, it would still be advisable from a planning perspective to make sure that a healthcare proxy is duly appointed in a separate legal document.
- A qualified terminable interest property (QTIP) trust ensures that the surviving spouse will receive all of the trust income for his life and that he's the only permissible beneficiary of principal. A QTIP trust also ensures that on the surviving spouse's death, the remaining trust property will be distributed as directed by the first spouse to die.
- The difference between $1,750,000 and $1,612,940 is attributable to the federal deduction for state estate taxes paid.
- 16 U.S.C.A. Section 2518(b)(4).
- Ibid.
- The Tax Relief, Unemployment Insurance Reauthorization and Job Creation Act of 2010 created portability. 26 U.S.C.A. Section 2010(c)(4) H.R. 4853, 111th Cong. Sections 302-304 (2010).
- Interestingly, none of the same-sex marriage states discussed herein that impose an estate tax allow for the portability of state estate tax exemptions to a surviving spouse, regardless of whether the marriage is same-sex or opposite-sex. It would seem, however, that were these states to permit state estate tax exemption portability, the benefits would be enjoyed by all married couples, whether same-sex or opposite-sex.
- See 26 U.S.C.A. Section 2516 and Treasury Regulations Section 25.2512-8.
- 26 U.S.C.A. Section 2503(e).
Lauren Rocklin, far left, and Chi-Yu Liang are attorneys in the New York office of Withers Bergman LLP


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Pink ombre hair and a gappy grin: this is Charlotte Free. If you don't know her by name, chances are you've seen her rocking Forever 21's ad campaigns lately and selling Seven For All Mankind jeans in your fashion mags. The model is rising in popularity and easy recognition due to her unique style, but her latest collaboration speaks volumes to the direction the mainstream fashion and beauty industry is heading. Her latest gig? Find out after the cut.
Maybelline? Yup, the makeup brand usually known for their tame ads featuring super-beauties like Adriana Lima and Josie Maran seem to be turning over a new leaf. Perhaps the addition of Charlotte to their repertoire is an attempt to gain some traction with the younger set; and heck, they've got my attention. The secret had the twittersphere buzzing recently, as depicted in this hilarious "Sh*t Fashion Girls Say" follow-up video:
P'Trique has loose lips, but we're happy to have the news. Maybe the line will feature some bright colors to match Free's wild style? One can only hope.
What do you think of this choice for Maybelline?