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Consumer Bankruptcy
Proposal #7: Dischargeability of Credit Card Debt
Bankruptcy affords a broad discharge and a fresh start to "honest but unfortunate debtors." [ FN: Local Loan Co. v. Hunt, 292 U.S. 695 (1934); Goldberg Securities Inc. v. Scarlata, 979 F.2d 521 (7th Cir. 1992). Creditors therefore are expected to prove each element of an exception to discharge by a preponderance of the evidence. Grogan v. Garner, 498 U.S. 279 (1991).] Section 523 of the Bankruptcy Code specifically enumerates exceptions, which are to be construed narrowly, [ FN: See, e.g., Schweig v. Hunter, 780 F.2d 1577, 1579 (11th Cir. 1986); Manufacturer s Hanover Trust Company v. Ward , 857 F.2d 1082, 1083 (6th Cir. 1988).] for debts that should not be discharged in bankruptcy for public policy reasons, presumably because they involve "moral turpitude" or intentional wrongdoing. [ FN: See Thul v. Ophaug, 827 F.2d 340 (8th Cir. 1987).] Section 523(a)(2)(A), much like its predecessor under the Bankruptcy Act of 1898, excepts from discharge a debt for money, property, or an extension of credit to the extent it was obtained by false pretenses, a false representation, or actual fraud. [ FN: This provision excludes statements of debtors financial condition, addressed in section 523(a)(2)(B).] Few would object to the notion that a debtor who has engaged in fraudulent activity should not be rewarded with a discharge of a debt that was obtained through that fraud.
The Commission has received numerous comments indicating that the current version of section 523(a)(2)(A) is ill-suited to assess the nondischargeability of credit card debt. Although they reach widely divergent conclusions on the substance of the provision, the courts seem to concur on one point: application of this exception to credit card debt "has been fraught with doctrinal difficulty." [ FN: See, e.g., AT&T Universal Card Services Corp. v. Feld, 203 B.R. 360 (Bankr. E.D. Pa. 1996); AT&T Universal Card Serv. Corp. v. Akdogan, 204 B.R. 90 (Bankr. E.D.N.Y. 1997) ( "Misrepresentation and reliance in the fraud context are anchored on a direct nexus or relationship between a debtor and a creditor. Here, as in so many other nondischargeability actions, there was little, if anything, in the nature of direct, purposeful contact between the credit card issuer and the credit card holder either at the inception or over the course of the relationship between the parties "). See also Citibank (South Dakota), N.A. v. Eashai, 87 F.3d 1082 (9th Cir. 1996) (credit card debts different than those arising from traditional two-party credit transactions).] Even direction from the circuit courts is not a panacea for the confusion; within the last year, the Court of Appeals for the 9th Circuit has issued four section 523(a)(2)(A) opinions, three of which involve credit card debt and employ somewhat different methods of interpretation. [ FN: See American Express Travel Related Services Company Inc. v. Hashemi, 104 F.3d 1122 (9th Cir. 1996), cert. denied , 117 S.Ct. 1824 (1997) ; Anastas v. American Savings Bank, 94 F.3d 1280 (9th Cir. 1996); Eashai, 87 F.3d 1082.] The lack of clear guidance becomes especially crucial when one considers the continuing growth in the availability and use of credit cards and the increasingnumber of consumer bankruptcy filings.
The Recommendation
Alternative #1:
Except for credit card debts that are excepted from discharge under section 523(a)(2)(B) for materially false written statements respecting the debtors financial condition, debts incurred on a credit card issued to the debtor that did not exceed the debtors credit limit should be dischargeable unless they were incurred within 15 days before the order for relief under title 11.
Alternative #2:
Except for credit card debts that are excepted from discharge under section 523(a)(2)(B) for materially false written statements respecting the debtors financial condition, debts incurred on a credit card issued to the debtor that did not exceed the debtors credit limit should be presumptively dischargeable if they were incurred more than 30 days before the order for relief under title 11. A lender can rebut the presumption of dischargeability outside the 30 day period only for debts incurred for luxury goods or services within 60 days before the order for relief. A debtor can rebut the presumption of nondischargeability within the 30 day period with proof that such debts were for expenses reasonably required for the maintenance and support of the debtor and the debtors dependents.
The Code has little difficulty dealing with fraud in an application for a credit card, which is addressed in section 523(a)(2)(B). This proposal addresses the problem created by nondischargeability actions based on a debtors use of a credit card. A creditor that brings a nondischargeability action under section 523(a)(2)(A) has the burden to show:
This test has been applied to actions under this provision regardless of whether the creditor alleges actual fraud, false pretenses, or false representation as the specific grounds for nondischargeability. [ FN: See Field v. Mans, 116 S.Ct. 437, 444 (1995); Mayer v. Spanel Internat'l, Ltd., 51 F.3d 670 (7th Cir.), cert. denied , 116 S. Ct. 563 (1995).] Courts and litigants routinely recite the test, but the interpretation and application of these standards has been highly variable. Specifically, courts take disparateapproaches regarding what the use of a credit card "represents," how to determine an "intent to deceive," and what constitutes "justifiable reliance" by the creditor in a tripartite credit card transaction. In the voluminous case law on this topic, many courts have acknowledged that application of the Codes fraud exception to credit card debt has been extraordinarily problematic.
Use of a Credit Card as a Representation
When a customer has used a credit card and subsequently seeks to discharge that debt in bankruptcy, some courts have determined that by making the charge, the customer misrepresented that she was able to repay the resulting debt. [ FN: See, e.g., Mercantile Bank v. Hoyle, 183 B.R. 635 (Bankr. D. Kan. 1995); Chase Manhattan Bank v. Weiss, 139 B.R. 928 (Bankr. D.S.D. 1992). American Express Travel Related Services v. Dorsey, 120 B.R. 592 (Bankr. M.D. Fla. 1990) ("[I]f it is shown that at the time the Debtor incurred the charges that he or she knew they would be unable to live up to the obligation and pay the charges, or if it appears that they had no intention to pay the charges . . . that would clearly be actual fraud").] Sometimes, using a credit card is considered to be a representation of both an intent and a present ability to pay. [ FN: "The purchase of goods on a credit card constitutes an implied representation by the purchaser that he has both the means and intent to repay for the goods purchased. " AT&T Universal Card Services v. Ramirez, 184 B.R. 859, 861 (Bankr. S.D. Fla. 1995); Household Credit Services v. Walters, 208 B.R. 651, 653 (Bankr. W.D. La. 1997) (use of card is representation that consumer has intent and present ability to make payment); see also Norwest Bank (Des Moines, N.A.) Card Services Division v. Stewart, 91 B.R. 489 (Bankr. S.D. Iowa 1988), citing Comerica Bank Midwest v. Kouloumbris, 69 B.R. 229 (N.D. Ill. 1986);In re Buford, 25 B.R. 477 (Bankr. S.D.N.Y. 1982).] Some courts believe this representation is made even if the lender had no expectation that the debtor had the present ability to repay the charges when the debts were incurred. [ FN: "Seldom do the courts concern themselves with the debtors ability to make the minimum monthly payment . " The GM Card v. Cox, 182 B.R. 626, 633 (Bankr. D. Mass. 1995) (emphasis added).] Under this theory, an individual may have committed fraud by making a charge and subsequently being unable to pay. [ FN: Cf. Feld, 203 B.R. at 365 (credit card lenders, like other lenders, must establish every element of fraud with requisite level of proof).]
Other courts decline to follow the aforementioned approach. Rather than making every consumer a guarantor of her future solvency, they find that a customers use of a credit card constituted an express or implied representation of an intent to repay. [ FN: "To hold, as some courts have, that objective inability to pay, coupled with an implicit representation to the contrary at the time the court is used, establishes the deceit element of the nondischargeability cause of action would be to make the debtor a guarantor of his own financial condition. Such a burden is not imposed by the statute. " F.C.C. Nat l Bank v. Cacciatore, 209 B.R. 609, 616 (Bankr. E.D.N.Y. 1997); Anastas, 94 F.3d at 1285; American Express Travel Related Services v. Christensen, 193 B.R. 863, 866 (N.D. Ill. 1996); Feld, 203 B.R. at 366 ( "each use of the card, accompanied by the cardholder's signed acknowledgment of additional indebtedness incurred pursuant to the card agreement, is a reaffirmation of the intent to repay "); AT&T Universal Card Services Corp. v. Chinchilla, 202 B.R. 1010 (Bankr. S.D. Fla. 1996) (intent -- not ability -- to repay, is relevant inquiry); Mercantile Bank of Illinois v. Williamson, 181 B.R. 403, 406 (Bankr. W.D. Mo. 1995); Citicorp Credit Serv. v. Hinman, 120 B.R. 1018 (Bankr. D.N.D. 1990); Sears Roebuck and Co. v. Faulk, 69 B.R. 743 (Bankr. N.D. Ind. 1986); Chase Manhattan Bank v. Carpenter, 53 B.R. 724 (Bankr. N.D. Ga. 1985).] "The availability of creditduring financially difficult times is a very good reason to maintain credit. The test for nondischargeability is not whether the credit was used in difficult times but whether the credit was used with the intent not to pay the debt." [ FN: First U.S.A. Bank v. Hunter, 1997 WL 370840, 96-02125-6J7 (Bankr. M.D. Fla. June 27, 1997), citing Barnett Bank of Pinellas County v. Tinney, 188 B.R. 1015, 1020 (Bankr. M.D. Fla. 1995).] From this point, courts take divergent approaches to determine whether the customer actually intended to pay when she made the charges: they might use a series of objective factors to determine whether the debtor demonstrated an intent not to repay, they might consider whether the debtor "reasonably should have known" he would be unable to repay, or they might assess the debtors intent subjectively.
A few courts have declined to infer that a customer made a misrepresentation on the sole basis that she used a credit card and subsequently filed for bankruptcy. [ FN: Cox, 182 B.R. at 634; see also Comerica Bank Midwest v. Kouloumbris, 69 B.R. 229, 231 (N.D. Ill.1986) (because debtor may have intended to pay for purchases when charged, court cannot presume that use of credit card constituted misrepresentation); AT&T Universal Card Services Corp. v. Alvi, 191 B.R. 724 (Bankr. N.D. Ill. 1996).] The court in In re Cox concluded that Congress did not intend section 523(a)(2)(A) to cover "implied representations," nor do policy and jurisprudential justifications support the provisions use in this regard; rather, most credit card fraud cases belong in the purview of section 523(a)(2)(C), under which debts incurred on the eve of bankruptcy for luxury goods are nondischargeable. [ FN: Cox, 182 B.R. at 634-36.] "The philosophy of Cox has its origins in nineteenth century cases holding that a borrowers predictions regarding his future ability to pay his debts are not actionable as false pretenses." [ FN: AT&T Universal Card Service Corp. v. Nguyen, 208 B.R. 258, 260 (D. Mass. 1997), citing Commonwealth v. Drew, 36 Mass. 178, 185 (1837). However, the Cox analysis has been met with disfavor by the district courts in the district where this decision was issued. See AT&T Universal Card Services Corp. v. Pakdaman, 1997 WL 404045, 96- 30076 (D. Mass. July 17, 1997) (rejecting Cox analysis; while recognizing that the application of traditional elements of misrepresentation to the credit card area is tricky, this court must conclude that Cox strikes the balance too harshly against the creditor "); Nguyen, 208 B.R. at 261 (rejecting Cox approach as being fundamentally unfair to creditors and contrary to section 523(a)(2)).] Another court has suggested that the use of a credit card is not a "representation" because it is not a statement that is capable of being true or false; this conclusion was extrapolated from a Supreme Court decision that held that signing and submitting a check is not a factual assertion and is not capable of being true or false. [ FN: Alvi, 191 B.R. at 732, citing Williams v. United States, 458 U.S. 279 (1982). See Goldberg Securities Inc. v. Scarlata, 979 F.2d 521 (7th Cir. 1992) (applying Williams analysis to bankruptcy nondischargeability action);In re Horwitz, 100 B.R. 395, 398 (Bankr. N.D. Ill.1989) (same); see also Bank One Columbus, N.A. v. McDaniel 202 B.R. 74, 78 (Bankr. N.D. Tex. 1996) (agreeing with conclusion in Alvi regarding representations).] These theories can make it difficult, if not impossible, for credit card lenders to bring nondischargeability actions under section 523(a)(2)(A) at all unless the circumstances of the use of the credit card were unique, e.g., there was some additional affirmative misrepresentationaccompanying the use of the card. [ FN: See Alvi, 191 B.R. at 732, note 14.]
Intent to Deceive Using a Credit Card
Ill intent traditionally has been a crucial factor of fraud or false representation. [ FN: See Neal v. Clark, 95 U.S. 704, 709 (1877) (fraud means actual or positive fraud, not fraud implied in law);In re Welch, 208 B.R. 107 (S.D.N.Y. 1997) (regardless of what method courts apply to determine nondischargeability of credit card debt, creditor must establish that debtor intended to deceive creditor at time charges were incurred).] Although it was not central to the holding of the case, the Supreme Court noted in Field v. Mans that Congress could have barred discharge on the basis of unintentional misrepresentations if it had wished, "but it would, however, take a very clear provision to convince anyone of anything so odd." [ FN: Field, 116 S. Ct. at 442.] Scienter is a difficult element to prove, thus quite a few courts use objective factors to "infer" an intent to deceive the credit card issuer. [ FN: See, e.g., Hashemi, 104 F.3d at 1126, note 2; see also Eashai, 87 F.3d at 1087, where the court adopted the twelve factor test set forth in Citibank South Dakota v. Dougherty, 84 B.R. 653, 657 (9th Cir. BAP 1988).] The most widely-utilized set of factors includes the following:
Courts disagree on the extent to which objective factors such as these should be used to impute intent. Some courts carefully examine most or all of the aforementioned elements to determine whether or not the debtor demonstrated that he intended to repay. [ FN: See Williamson, 181 B.R. at 406 (finding that debt was dischargeable); General Electric Capital Corp. v. Janecek, 183 B.R. 571, 575 (Bankr. D. Neb. 1995) (insolvency can be considered, but is not determinative in assessing debtor s intent to deceive).] Thus, if thesefactors illustrate that the debtor was "loading up" on luxury goods, this may lead a court to conclude that the debtor did not intend to repay and was acting deceitfully. [ FN: See, e.g., Hashemi, 104 F.3d at 1126 (using factors to determine that $60,000 worth of credit card charges on six week European vacation on eve of bankruptcy was not dischargeable).]
However, other courts believe that the consideration of one or two objective factors may suffice to produce an inference that the debtor intended to deceive the creditor when making a credit card purchase. [ FN: See, e.g., FCC Nat'l Bank v. Berz, 173 B.R. 159 (Bankr. N.D. Ill. 1994).] Using this approach, the fact that a reasonable person would not have believed that she would be able to repay may result in a finding of fraud and nondischargeability: "If the cardholder uses the card to purchase goods or to obtain cash advances while knowing that the charges cannot be paid, or if evidence indicated that the cardholder should have known that the charges cannot be paid, the creditor has established a claim of nondischargeability." [ FN: Ramirez, 184 B.R. at 861; Southtrust Bank of Alabama v. Moody, 203 B.R. 771 (Bankr. M.D. Fla. 1996) ("It should not take a rocket scientist to figure out that even if [debtor] lived 1000 years she would still not be able to repay the charges she ran up on her credit cards"), citing Dorsey, 120 B.R. at 594; Mercantile Bank v. Hoyle, 183 B.R. 635, 638 (Bankr. D. Kan. 1995); Household Card Services/VISA v. Vermillion, 136 B.R. 225, 226 (Bankr. W.D. Mo. 1992). Cf. Stewart, 91 B.R. at 495 (insolvency alone does not establish intent to deceive); Chinchilla, 202 B.R. at 1016 (lack of ability to pay is insufficient basis on which to infer intent to deceive).] This approach enables a credit card lender plaintiff to "prove" fraud merely by indicating the pattern of credit card charges, the proximity of the charges to the bankruptcy filing, and the debtor's inability to repay the debts. [ FN: A closely related approach is to use objective factors to find "constructive fraud. " See Strawbridge & Clothier v. Caivarelli, 16 B.R. 369 (Bankr. E.D. Pa. 1982); Mercantile Trust Co. Nat'l Assoc. v. Pozucek, 73 B.R. 110 (Bankr. N.D. Ill. 1987).]
Some courts reject the notion that a debtors inability to repay amounts to fraudulent intent, and instead try to determine whether the debtor subjectively intended to deceive a creditor. [ FN: See, e.g., Sears, Roebuck and Co. v. Taylor, 1997 WL 418035, 96-06051 (Bankr. M.D. Fla. July 25, 1997) (although court can review litany of factors, ultimate determination turns on subjective intent); Feld, 203 B.R. at 367 (dischargeability will not turn on reasonableness of debtor s expectations of ability to repay); AT&T Universal Services v. Totina, 198 B.R. 673, 679 (Bankr. E.D. La. 1996); Chase Manhattan Bank v. Murphy, 190 B.R. 327, 333 (Bankr. N.D. Ill. 1995).] These courts have reasoned that the "hopeless state" of the debtor's financial affairs is no substitute for an actual finding of bad faith. "[A]lthough the reasonableness of the debtors' belief as to the truth of their representations may be circumstantial evidence of their intent, ultimately the issue is their actual intent and not the objective reasonableness of it." [ FN: Chevy Chase Bank, FSB v. Briese, 196 B.R. 440, 451 (Bankr. D. Wis. 1996).] The 9th Circuit stated in Anastas that "the focus should not be on whether the debtor was hopelessly insolvent at the time he made the credit card charges . . . if ability to repay were the focus of thefraud inquiry, too often would there be an unfounded judgment of nondischargeability of credit card debt." [ FN: See Anastas, 94 F.3d at 1285, citing 124 Cong. Rec. H11089 (Sept. 28, 1978) (Statement of Rep. Edwards) ("subparagraph (A) is intended to codify current case law . . . which interprets 'fraud' to mean actual rather than fraud implied in law"); Alvi, 191 B.R. at 733; First Federal of Jacksonville v. Landen, 95 B.R. 826 (Bankr. M.D. Fla. 1989) (debtor's honest but questionable relief that he would be successful at gambling and be able to repay his debts defeats finding of intent to deceive).] Thus, objective factors may be relevant, but only to the extent they assist the court in determining whether the debtor actually and subjectively intended to deceive the creditor. [ FN: See Id., at 1285; Feld, 203 B.R. at 367 (factors may be helpful, but not controlling, in determining whether debtor had subjective intent to repay). See also Kouloumbris, 69 B.R. at 231.] In courts that take this approach, creditors may have to prove that the debtor incurred credit card debt in bad faith with the intention of filing for bankruptcy and avoiding the debt. [ FN: See Chinchilla, 202 B.R. at 1015.]
Credit Card Lenders Reliance on Borrowers Representation by Use of a Credit Card
Even more difficult is the question of reliance, another essential component to the common law definition of fraud. In a section 523(a)(2)(A) case involving a land sale, the Supreme Court held that a creditor must prove that his reliance was justifiable; if the falsity of the representation should have been readily apparent to that particular creditor, the creditor will not prevail. [ FN: Field, 116 S.Ct. at 444; P& S X-Ray Co. Inc. v. Dawes, 189 B.R. 714 (Bankr. N.D. Ill. 1995); Irwin v. O'Bryan, 190 B.R. 290 (Bankr. E.D. Ky. 1995).] This resolved a split in the circuits over whether reliance has to be "reasonable," but did not minimize the difficulties in credit card debt nondischargeability cases. The ongoing nature of the relationship between the credit card holder and the issuer make it difficult to gauge what constitutes reliance for each individual credit card transaction. [ FN: The courts do not agree on whether each credit card transaction should be considered a separate contract or whether they are part of a continuing contract, a distinction that may have implications on the outcome of the case. Cf. Anastas, 94 F.3d at 1285 (each transaction is separate contract), with Cox, 182 B.R. at 636 (continuing contract), and Feld, 203 B.R. at 367, note 7 (same).]
Following an 11th Circuit case decided under the Bankruptcy Act of 1898, some courts hold that when a debtor exceeds her credit limit, a credit card company "assumes the risk" of nonpayment until it attempts to revoke her credit privileges. [ FN: First Nat'l Bank of Mobile v. Roddenberry, 701 F.2d 927 (11th Cir. 1983), cited in Cox, 182 B.R. at 631. Cf. Feld, 203 B.R. at 367, note 6 ( "fact that creditors anticipate loss does not mean they should be saddled with losses resulting from fraud "), citing Briese, 186 B.R. at 449.] Some courts in the EleventhCircuit, although not all, have considered themselves bound by this approach, [ FN: See, e.g., Sears, Roebuck and Co. v. Taylor, 1997 WL 418035, 96-06051 (Bankr. M.D. Fla. July 25, 1997) (stating that Roddenberry remains good law); AT&T Universal Card Services Corp. v. Harris, 1997 WL 402642 96- 4739 (Bankr. M.D. Fla. July 14, 1997) (under Roddenberry, creditor can only prevail on allegations of actual fraud, not false pretenses or false representation if creditor failed to revoke privileges); First Card Services Inc. v. Herndon, 193 B.R. 595 (M.D. Fla. 1996) (upholding summary judgment to dismiss); AT&T Universal Card Services Corp. v. Stansel, 203 B.R. 339 (Bankr M.D. Fla. 1996) (under Roddenberry, court cannot hold debts nondischargeable when debtor exceeded credit limit but creditor failed to revoke credit privileges); AT&T Universal Card Services Corp. v. Berry, 197 B.R. 382, 383 (Bankr. M.D. Fla. 1996). See also Ward, 857 F.2d at 1082; Kouloumbris, 69 B.R. at 231.] which will preclude a finding of reliance in many instances absent evidence of actual fraud.
Other courts do not require a credit card issuer to prove reliance at all. They simply presume that a credit card issuer is entitled to rely on each use of a credit card as a manifestation of an intent to repay. [ FN: See, e.g., AT&T Universal Card Services Corp. v. Burdge, 198 B.R. 773 (Bankr. 9th Cir. 1996); Colonial Nat l Bank U.S.A. v. Levinthal, 194 B.R. 26, 28 (Bankr. S.D.N.Y. 1996).] "The credit card issuer justifiably relies on a representation of intent to repay as long as the account is not in default and any initial investigations into a credit report do not raise red flags that would make reliance unjustifiable." [ FN: Anastas, 94 F.3d at 1286, quoted in Hashemi, 104 F.3d at 1126.] The fact that many courts presume justifiable reliance may explain why it is not uncommon for credit card plaintiffs to refrain from offering any specific evidence of reliance. [ FN: See, e.g., Feld, 203 B.R. at 368-369; Christensen, 193 B.R. at 867; FCC Nat'l Bank v. Willis, 190 B.R. 866 (Bankr. W.D. Mo. 1996), aff d, 200 B.R. 868 (W.D. Mo. 1996).]
Still other courts are critical of a presumption of reliance, for reliance is a discrete and independent element of fraud that must be proven by a preponderance of the evidence. [ FN: See, e.g., Cacciatore, 209 B.R. at 614 (court "will not ignore the element of reliance simply because it may be difficult for credit card companies to prove "); Sears, Roebuck & Co. v. Hernandez, 208 B.R. 872, 880 (Bankr. W.D. Tex. 1997) (rejecting implied reliance); Christensen, 193 B.R. at 867; AT&T Universal Card Services v. Richards, 196 B.R. 181, 182 (Bankr. E.D. Ark. 1996). Alvi, 191 B.R. at 731; Willis, 190 B.R. at 869.] At a minimum, these courts may require a creditor to show that it did not continuously extend credit passively or blindly. [ FN: Akdogan, 204 B.R. at 98 (granting debtor's motion for summary judgment on nondischargeability complaint due to lack of proof of justifiable reliance). The court in Akdogan cited Alvi, 191 B.R. 731, Ward, 857 F.2d 1082, and First Card v. Leonard, 158 B.R. 839 (Bankr. D. Colo. 1993), in support of its decision. The Akdogan court found it noteworthy that the creditor "did not request any information relating to the Debtor's expenses, assets, nature of employment or business, health, home ownership, credit references or general financial condition," nor did the creditor require the debtor to supply the basic requested information before issuing the debtor the credit card. Id.] If a creditor conducts a financial analysis that raises a "red flag" and extends credit nonetheless, this also may defeat a finding of justifiable reliance. [ FN: Briese, 196 B.R. at 453.]
Some of these courts are especially troubled by the fact that creditors send an increasing number of unsolicited credit card applications and make minimal inquiries into the status of the consumers income and debt load when originally extending credit to the debtor. [ FN: See, e.g., Walters, 208 B.R. at 654 (looking first at whether lender justifiably relied on any credit information when originally issuing card; pre-approved, unsolicited cards do not indicate justifiable reliance); McDaniel, 202 B.R. at 79 (referring to credit issuer s practice as "commercial entrapment "), citing Mercantile Bank v. Hiemer, 184 B.R. 345 (Bankr.D.Neb.1995).] Therefore, if a creditor never conducted a meaningful initial credit check, some courts will find that the creditor could not have relied justifiably on any representation made by the subsequent use of a credit card. [ FN: See, e.g., Cacciatore, 209 B.R. at 616 (lender did not justifiably rely when it granted $5,000 line of credit to 21 year old student that listed no employer or place of business) ; Akdokan, 204 B.R. at 97.] In addition, the element of reliance becomes even more elusive in the context of another modern credit device, the "live check," a check sent unsolicited to a consumer. At least one court has found that a creditor cannot prove reliance in this context: "Absent proof of [lender]s clairvoyant abilities, this Court is hard pressed to find that [lender] relied upon a representation which occurred subsequent in time to Beneficials action of issuing the check." [ FN: Beneficial of Missouri Inc. v. Shurbier, 134 B.R. 922 (Bankr. W.D. Mo. 1991) (noting that reliance may be part and parcel to ongoing relationship between credit card issuer and user in open-ended credit relationship, but this is distinguishable from discrete loan transaction).]
Reasons for the Change
The recommended approaches would be superior to the chaotic case law interpretations that presently govern the dischargeability of credit card debt. As one court recently noted:
Each of the . . . approaches [presently used by courts] has been criticized by courts that adhere to one of the other approaches or to one of the many other divergent views that do not fit neatly into the above categories. It seems likely that until Congress takes action to establish clear cut guidelines in credit card nondischargeability cases under Code section 523(a)(2)(A), divergent views among the courts will continue to proliferate. Unabated, the current situation will result in increased inconsistency of outcomes among cases resting on similar facts. That such lack of consistency is harmful to the system, should be obvious to all concerned. [ FN: AT&T Universal Card Services v. Wong, 207 B.R. 822, 828, note 4 (Bankr. E.D. Pa. 1997).]
Especially in light of the ubiquity of credit cards and the high rate of bankruptcy filing, it becomes particularly important to clarify the rules so all parties have a better comprehension of the requirements for a colorable nondischargeability action. The recommended approaches would minimize litigation over the elements of fraud, which sometimes are ignored or conflated because they are so difficult to prove in the credit card context. The present provisions of section523(a)(2) would continue to apply to fraud in an application for a credit card or instances of actual fraud that happen to involve a credit card, such as using some one elses card; the subject of this recommendation is the routine use of a credit card under a valid open-ended credit agreement.
Enhanced uniformity of the treatment of credit card debt should benefit all parties. This proposal should minimize unnecessary costs and burdens for credit card lenders; no longer would they have to keep track of the vastly disparate approaches being employed by various courts, many within the same district. Instead, they can look to an intelligible test to determine whether a debt is nondischargeable and can proceed accordingly. This proposal is not intended to disrupt credit granting practices and does not condition creditors relief on the rigor of their initial scrutiny of borrowers, as some courts do presently when assessing creditor reliance under section 523(a)(2)(A). However, as a consequence of the proposals design, the bankruptcy system would not provide an additional safeguard for all improvident lending decisions that lenders might have addressed themselves by restricting or revoking credit privileges. As such, credit card lenders would not receive preferential treatment to other creditors.
Clarifying the law also would have an important effect in the cases involving the poorest debtors who cannot afford to defend these actions. The current uncertainty facilitates threats of nondischargeability actions, which leads debtors to settle and agree to repay otherwise dischargeable unsecured debts. Although the Code contains a fee-shifting provision to encourage debtors to defend actions that are not substantially justified, [ FN: 11 U.S.C. §523(d).] the wide spectrum of interpretations of section 523(a)(2)(A) makes almost any credit card debt potentially nondischargeable. It is nearly impossible to show that a credit card debt nondischargeability action was wholly unjustified, a risk that few debtors and debtors attorneys can afford to take. One court recently noted this when rejecting a prevailing debtors request for attorneys fees and costs:
"a variety of overlapping theories have emerged in respect of the elements required of a credit card plaintiff to obtain a judgment of nondischargeability as well as the manner in which those elements may be satisfied. The papers submitted by [creditor]s motion in opposition to [debtor]s motion cite authority tending to support some of its arguments. In the absence of prior rulings on point by this court, or binding 2nd Circuit authority, the Court cannot conclude that [creditor]s position lacked substantial justification within the meaning of section 523(d)." [ FN: Cacciatore, 209 B.R. at 618.]
Even putting aside the question of fee-shifting, an honest debtor cannot be certain that she will be able to defeat a finding of "implied fraud" that is constructed out of various objective factors. Courts around the country are reporting that they are receiving increasing numbers of motions forextensions for time to file nondischargeability complaints, shortly followed by settlements and/or reaffirmations. A clearer bright-line rule for nondischargeability should abate this trend.
In formulating a clearer standard, this proposal reaches debts most likely incurred in contemplation of bankruptcy. It thus is similar in approach -- but broader in scope and more definitive -- to section 523(a)(2)(C), which shifts the presumption of dischargeability for luxury goods purchased on credit on the eve of bankruptcy. [ FN: Hernandez, 208 B.R. at 880, citing S. REP. No.98 - 65, 98th Cong, 1st Sess. 58 (1985), Senate Report Accompanying section 445, Omnibus Bankruptcy Improvements Act of 1983. "[O]pinions dealing with the term "luxury" as used in this statute have "considered whether under circumstances of each particular case the purchases or transactions were 'extravagant,' 'indulgent,' or 'nonessential.'" Hernandez, 208 B.R. at 880, citing Carroll & Sain v. Vernon, 192 B.R. 165, 170 (Bankr. N.D. Ill. 1996), General Motors Acceptance Corp. v. McDonald, 129 B.R. 279 (Bankr. M.D. Fla. 1991), and Sears Roebuck & Co. v. Faulk, 69 B.R. 743 (Bankr. N.D. Ind. 1986).] Like other Code provisions that establish lookback periods for activities occurring directly pre-petition, such as the 90-day preference period in section 547(b), a bright line exception for credit card debt may not be foolproof at the margins but has several advantages and may be superior to a fact-specific analysis. A case-by-case analysis under a fact-specific fraud test already has proven to be an inadequate legal sorting device for credit card debt. Onto an already-contorted legal analysis, moral issues surrounding the proliferation and use of credit cards provide an additional overlay, and conflicting moral judgments may be playing a large role in the determination of these disputes. In addition, judicial time and resources in the bankruptcy system are at a premium, and case-by-case analyses may be too costly and require other sacrifices. Thus, a "rough justice" standard may be the fairest and most expedient method to identify debts most eligible for exception from discharge. Timing creates a sufficiently strong inference that certain credit card debts were incurred in contemplation of bankruptcy to render them nondischargeable. As a corollary, outside the time limit, routinely-incurred credit card debts would be dischargeable. However, the time period must be set with care; the justification for a time-cleavage approach breaks down as the nondischargeability period is enlarged. Every day that the nondischargeability period is extended, it becomes less probable that the debts were incurred in contemplation of bankruptcy and increasingly difficult to rationalize the preferential treatment of credit card debts over other unsecured debts.
Competing Considerations
Excepting debts from discharge based on a bright line test arguably will capture the credit
card debts of only innocent debtors, including pro se debtors or debtors dealing with emergency
situations, who did not engage in pre-bankruptcy planning. A nondischargeability rule that does
not specifically target culpably-incurred debts might be too permissive towards sophisticated
debtors that are able to plan around the nondischargeability period. Thus, some might argue that
the proposed approach runs counter to the policies underlying the exceptions to discharge. On the
other hand, others might advocate more punitive measures to except from discharge a wider range
of credit card debts incurred when the debtor was experiencing financial distress, even if they
were incurred properly within the terms of a credit card agreement. The proposal represents a
compromise; some debts that were innocently incurred before bankruptcy will
benondischargeable, but the lookback period is limited.


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CPS creating safety routes for kids heading to new schools
BY FRANK MAIN Staff firstname.lastname@example.com April 8, 2013 8:00PM
Students leave Jean De Lafayette Elementary School on March 21, 2013. The school is one of 50 schools slated to be closed by the city. | Getty
Related Stories
Updated: May 10, 2013 6:31AM
Jadine Chou, chief of security and safety for Chicago Public Schools, emphasized in an interview Monday that she is working closely with police to design safe routes for students whose elementary schools are on the chopping block.
Chou, who has been working with her police counterpart, Deputy Chief Steve Georgas, and the Chicago Police Department's Gang School Safety Team, hopes to begin showing parents the new protected routes in the coming weeks. Mayor Rahm Emanuel asked for Georgas to participate in the school route planning because of his experience in overseeing the security for the NATO Summit last year.
Thirty-five high schools and four elementary schools already have protected routes under CPS' "Safe Passage" program. Still, Chicago Teachers Union President Karen Lewis and some community leaders have been skeptical about the safety planning surrounding the 53 elementary schools that will close at the end of the school year. They say they're worried about children having to cross gang boundaries to reach school.
CPS officials have said the walking distance between a student's old school and new school won't be more than four-fifths of a mile.
Chou and Georgas previously worked together on safety planning during the transformation of the Cabrini-Green public housing complex when she was head of security for the Chicago Housing Authority and he was the 18th District commander.
CPS couldn't provide the exact date when school officials plan to start meeting with parents.
Even after CPS reveals the new routes, they won't be set in stone, Chou said.
"We are constantly refining them when new information becomes available," she noted.
Students must walk from home to one of the "hubs" on a route, Chou said.
"Every household will not have an individual safe-passage plan from their home to school," she said.
"We will work to find appropriate coverage for children who are a bit tardy" and for those who participate in after-school activities, Chou added.
For the 35 high schools and four elementary schools in the Safe Passage program, there's a conference call every morning between Chou's team and the police to discuss any new safety issues along the routes.
The routes can change daily depending on concerns such as gang activity, a gas leak or a fatal accident, Georgas said.
"If something pops up on social media or a principal reports a concern he heard from a student, we are on the phone with the commander and chief of patrol to make sure we have the right plans for dismissal," Chou said.
CPS pays "community watchers" about $10 an hour to work five to six hours a day to monitor routes. A school might have eight to 20 watchers depending on the route.
They must undergo a criminal background check, Chou said.
CPS is budgeting an additional $7.7 million to pay community watchers for the new safe-passage routes in the upcoming school year

subset: commoncrawl


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News anchor Vinnie Politan and trial experts Ryan Smith, Jane Valez Mitchell, Nancy Grace and Drew Pinsky will present details of day in the Jodi Arias murder trial.
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1 year ago, donedeal said:HLN After Dark is a waste of time because make-believe jurors interact and render verdicts that are useless in the real world. Report abuse
Well, well, well. Another ploy by the defense team. This is ridiculous. I thought she wanted to die. Get this over with. I feel so sorry for Travis's family. This is so hard on them. As usual it's all about Jodi. The victim has no rights! Report abuse
If Jodi really wants to die she can do it easily. Just waive her appeals. I'll bet she doesn't. What a liar and manipulator. Report abuse
Saw Jodi's grandmother walking outside the courthouse without a wheelchair yet every time she was brought in the court she was in a wheelchair. Ploy to get the jury to feel sorry for her? Also, I don't believe for a second that Jodi wants to die. Act!!! Report abuse
2 years ago, sunfun3tulsa2 said:Jodi Took that gun and got rid of it because it was her grandfathers and could have been proven that it was. If it was Travis Alexanders gun she wouldn't have taken it . It was because it would have shown premeditation on her part by taking that gun. Report abuse


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iPad jailbroken one day after coming out. That was fast.
"A well-known hacker of the iPhone, who previously defeated Apple's restrictions on developers, has claimed in a video to have hacked the iPad. Just a day after release, the hacker, who goes by 'MuscleNerd' online, said that he has gained root access to the iPad…", as seen on slashdot.


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It's been a rough few weeks for Paula Deen — and the bad news keeps on coming. To help you keep track with the latest Deen controversy, use our handy timeline below.read more
Paula Deen's sons have come to their mom's defense in the wake of her racial slur scandal.
Appearing on...read more
Paula Deen has a few works for the Food Network after being fired: thank you.
In a statement obtained by People, Deen said:read more
The Deens give Thanksgiving turkey a true Southern touch by deep-frying it.
Parmesan Chicken Cutlets and Loaded Veggie Pasta Salad.
Bacon's a surprise addition to the Deens' Sweet Potato Souffle topping.
Left alone, Jamie makes his favorite dessert, a salted caramel pecan pie.
More Clips & Interviews
Paula Deen and her son, Jamie, are in the kitchen whipping their favorite Dad Foods. They're making Creamy Roasted Cauliflower, Jamie's Country Pork Chops, Potatoes with Black Pepper White Gravy and Old Fashioned Butternut Cake.
Two teams face off in one of our most memorable food fights yet!
Paula's celebrating a fun and time honored tradition, the Pot Luck! Her son Jamie joins her in the kitchen as they show you some of their favorite recipes to bring to a party. So get ready, we're perfecting the Pot Luck!
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The Guys Behind Christwire, Creating Parody From 'Glenn Beck on Steroids'
So close to reality that some news sites can't tell the difference.
Skip to content, or skip to search.
Skip to content, or skip to search.
So close to reality that some news sites can't tell the difference.
Not on the list of her favorite people are the writers of the Curbed blog, however.
Primed to become the "conservative Huffington Post."
God was a major topic, not Obama. But nobody is really sure what it was all about.
Doesn't seem to think Palin should go for it, either.
Restoring America's honor where Martin Luther King Jr., once spoke.
Plus, Stephen Colbert is ready to drink Glenn Beck's Kool-Aid, on our regular late-night roundup.
Beck "has a scheme."
How to find Real America in America's Capital.
A credibility problem deepens.
Fox News host has macular dystrophy.
And have his wife cook you food!
Her oil spill dress choice is critiqued.
"Open your eyes a little more!"
"[Lohan] doesn't affect anyone's life!"
Soccer is leftist? Sure, why not, run with it.
It doesn't make much sense.
We're talking about Representative Anthony Weiner, of course.
Plus, everybody hates Glenn Beck on our regular late night round-up.
"It's Six Degrees of Kevin Bacon, except there's just one degree ... and Kevin Bacon is Hitler."


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Just like we have done many of times now, products have come to us via recommendations and when someone said that we should check out the custom DOT half shell helmets from Daytona, we hopped right on the opportunity (no pun there) to see why these are some of the closest to a custom painted helmet you can get.
We had the opportunity to look at two different designs of the half-shell, the Black Rose, the female favorite and the Ace of Spades, one that says " I am a Bad Ass."
One thing we really liked about these helmets is the detail that goes into each design. The owner comes up with many of the designs from ideas of riders and even some of the staff members have an input on what the final outcome will be on each of the helmets. The Black Rose design spans the entire back of the helmet and a good portion of the sides. The detail is impeccable. We have a tough time thinking it is not airbrushed and so will you.
Some of the features of these helmets include Nylon Y-Strap System, six size selections from XS to 2XL and they meet and exceed D.O.T standards. The inside of the helmet is padded with vented material so not to leave your dome piece super sweaty after you remove it.
We must say that we took the testing of the helmets to the next level to see the safety they provide. Most of this type of wear and testing would not normally occur with these helmets.
Our first test was to take a brick and drop it on the helmet from twelve inches directly above. We must say that there was little or no damage to the helmet which is good if you ever happen to come in contact with the pavement directly. This is one scenario that we hope no one will ever have to deal with, but the helmet certainly will protect your dome piece.
The second test was to take a rubber mallet hammer and hit it against the helmet five times to see if there was any substantial wear or damage to the helmet. We are proud to say that not only did we not get a headache, but you could not see much marking to the helmet or the design of the rose or the Ace of the side of the Ace of Spades helmet.
Overall, we rate the look, comfort and durability of the helmets A+ and with 85.00 MSRP per helmet. These are helmets that anyone who owns something on two wheels should consider. They are definitely way cooler than regular non motorized bike helmets.
For more information on the products available from Daytona Helmets, check out their website at www.daytonahelmets.com


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First it was spammy viral marketers and childish pranks. Now Twitter has reached the same level of insecurity as everywhere else on the web, as scammers have begun to tweet out malware-ridden links. While this isn't YATW, these malware makers are hijacking trending topics to push their poison into the wild.
Mashable reports on how scammers have begun to spread links to sites "Twitterbest" and "Zasaden" on the .mp domain. Both host the commonly seen flash codec trojan which prompts the user to allow installation of what is supposedly an update to Adobe Flash player, and in actuality a rogue anti-virus utility, this one going by the name of "Fast Anti-Virus 2009." The name may sound familiar to technicians on the front lines of virus removal, as it has been used by rogue anti-virus programs dating back to at least May.
Avoiding the bad domains is only half of the battle though, due to the fact that the vast majority of URLs posted on Twitter are via URL shortening services. Without 3rd party tools, there's no way to tell where these links terminate before clicking them, and the trust instilled in most people by social media provides a sufficiently wide opening through which to ram a trojan exploit.
The upside is that since Twitter is apparently already censoring trending topics, we might be one step closer to finally getting rid of them altogether.


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Early Career Physicians, Resident/Fellow Members & Students
ACP currently represents the interests of these groups of members in the College. We have compiled resources for Early Career Physicians, Resident/Fellow Members and Medical Students to assist you in your Internal Medicine path.
Early Career Physician Activities and Resources
Resources of Special Interest to Early Career Physicians
Resident/Fellow Member Activities and Resources
Resident/Fellow Member Resources
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The Eurail Select Pass lets you discover the 4 bordering countries of your choice, including popular destinations like France, Spain, Italy and Germany.
Take your pick from 27 European countries.
Use the map below to select the countries you want visit.
Order from us and get exclusive access to the Eurail.com Reservations Service.
Free delivery in the U.S.A, Australia, Brazil and more countries. Plus, we can deliver your pass to a European address.
20% discount
Now for a limited time only with a 20% discount on winter trips!
Offer ends December 31, 2014 at 7 a.m. CET (more timezones). Stay updated!


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I've been using Akka for 3 years in a variety of projects and by now, I have a hard time imagining to deal with some of the parts of my work without it. Sure, Scala provides other powerful paradigms for dealing with concurrency, but I find Actors to be one of the most elegant concept… Continue reading
A quick tour of relational database access with Scala
Update: Added Squeryl, thanks to @JoeZulli for the heads-up Update 2: Added link to latest Squeryl release for Scala 2.10 and 2.9.2 I recently started working with relational databases again from within Scala, after a while in JSON-land (mostly MongoDB and elasticsearch). During that time, I'd been happily working with lightweight libraries / DSLs that… Continue reading
Java2Days Sofia 2013
Two weeks ago, I went to speak about Scala at the Java2Days conference in Sofia, Bulgaria. This was the 5th edition of the conference, and my first time there. A small group of speakers (to the extent of my knowledge, Josh Long, John Willis and Andrew Lombardi) has been flying overseas every year to attend… Continue reading
Tips & tricks for setting up a Play 2 project
Here are the slides from my talk at Devoxx 2013 in Antwerp: The sample application built in the slides is also available on GitHub. Devoxx was great, as always! A huge thank to Stephane and his crew for making it happen, year after year!
Reactive Golf or Iteratees and all that stuff in practice, part 3
In part 1 and 2 we've seen how to build a completely reactive chain to fetch a large stream of data from a REST API, transform it on the fly and send it over to indexing to ElasticSearch. Now one question remains: does it actually work, and does it help solve a real problem? In… Continue reading
Java Klassentreffen 2013: Scala Introduction slides
A bit late, but nonetheless: my slides from the Java Klassentreffen 2013 in Vienna and Linz. Introduction to Scala from Manuel Bernhardt
Reactive Golf or Iteratees and all that stuff in practice, part 2
Last week, we saw how to get data from a REST API and modify it to our liking in order to send it off for indexing to ElasticSearch. Now, let's see how to get the data into ElasticSearch in a resource-friendly manner. Indexing with ElasticSearch and elastic4s ElasticSearch has a RESTful index API through which… Continue reading
Reactive Golf or Iteratees and all that stuff in practice, part 1
I'm currently working on a project that involves synchronizing large amounts of data from backend systems for the purpose of making it searchable. Amongst other things, one domain the system deals with is Golf and the booking of tee times (i.e. a time at which to start playing). If I got things correctly, tee times… Continue reading
Scala with SublimeText
Three weeks ago, one of our cats set its mind to beat its long-distance jumping record on my desk, accross my laptop. Unfortunately for my laptop, there was a cup of tea standing next to it, and our cat didn't care too much about adjusting the height of the jump. As a result, I am… Continue reading
How to read the Play session from AngularJS
If you happen to work, like me, on a project that makes use of both the Play framework and AngularJS, you may at some point need to read some data from the Play session in your AngularJS application. Play uses a client-side session, which makes sharing the data with client-side applications easy. In order to… Continue reading


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Switching to Google email is one of several ways Chicago Public Schools will shave an additional $17 million from its 2014 fiscal year budget, Schools CEO Barbara Byrd-Bennett announced Friday.
Although the 2014 budget is not yet finalized, the 2013 budget topped out at $5.1 billion.
The cuts, all from the CPS Central Office, include:
◆ $6 million in renegotiated health care contracts.
◆ $2.1 million from the switch to Google email, calendar and other services.
◆ $2.1 million from reduced information technology costs.
◆ $2 million from renegotiated office supply contracts.
◆ $2 million from in-sourced or eliminated consultants.
◆ $1 million from a reduction in external legal counsel and from moving legal work in house.
◆ $1 million from a new waste-management contract.
◆ $500,000 from a purchasing system for use by schools.
◆ $200,000 in reductions in non-personnel costs in the communications office and from using fund-raising to pay for back-to-school projects.


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David Beckham had to take a break from his Miami soccer push to squash reports by numerous European media outlets that he and his wife Victoria acquired the former Versace Mansion. [more]
Posts Tagged 'versace mansion'
In a year when South Florida's resurgent real estate market attracted national and international attention, there is no shortage of candidates for The Real Deal's top stories of 2013. [more]
In the South Florida real estate news world, nothing moves the needle quite like condos. [more]
"South Florida by the numbers" is a web feature that catalogues the most notable, quirky and surprising real estate statistics. Here at the by the numbers headquarters, we do things a little differently. As we say farewell to 2013, that means zigging when everyone is zagging! This time of year, you can find lists recapping the biggest South Florida real estate deals of the year, or stories showing how the region's home sales and prices stacked up to previous years. These are useful and entertaining, but with our 2013 finale, we offer some numbers BEHIND the stories that made the past 12 months truly unique and compelling. So, do the Harlem Shake, rewatch that "Breaking Bad" finale, sing "Blurred Lines" with your windows down, and enjoy this edition of South Florida by the numbers! [more]
The Nakash family, which acquired the former Gianni Versace mansion in Miami Beach at an auction last month for $41 million, may turn it into an exhibit or museum dedicated to the late designer. [more]
The Nakash family-owned Hotel Victor, next door to the family's newly acquired Versace mansion on South Beach's Ocean Drive, has reopened after an $8 million floor-to-ceiling renovation. [more]
Jordache Enterprises mogul Joe Nakash is considering a plan to convert the former Versace mansion, which it acquired at auction for $41.5 million last week, into a high-end retail location, The Real Deal has learned. [more]
A bankruptcy judge in Miami on Wednesday approved the $41.5 million purchase of the former Versace mansion by the Nakash family of Jordache jeans fame partnering with the Gindis, former owners of the Plaza Hotel's Oak Room.
U.S. Bankruptcy Judge Laurel M. Isicoff approved the purchase by VM South Beach LLC. Joe Nakash, chairman of Jordache Enterprises, and New York real estate investor Eli Gindi, clenching a cigar, emerged from the auction, held in the courtyard of the highly decorated estate, as winner, besting competing bids by Donald Trump, who is renovating the Doral golf course, and Palm Beach club owner Glenn Straub. [more]
Glamorous soccer star David Beckham and his wife Victoria "Posh Spice" Beckham are interested in nabbing the late Gianni Versace's palatial mansion in Miami Beach, NOWdaily Magazine reported. [more]
The Versace mansion will go to bankruptcy auction on Sept. 17, listing broker Jill Eber told The Real Deal. [more]


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Tag: bww
Buffalo Wild Wings testing iPads for ordering
While we were in San Francisco for Macworld | iWorld, I noticed that the wait staff at Mel's Drive-in were using iPads to take orders. I hadn't seen that before, but apparently the folks at Mel's have used iPads for a while. Now an even bigger restaurant chain, Buffalo Wild Wings, is planning to d...
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Sunday bird
We had a really lazy Sunday wich I spent sitting around drinking coffee and reading old magazines. I tried cleaning up some clutter here and there but all I really did was moving things around. I watched the closing ceremony of the olympics..very impressive! And I sat behind the sewing machine for a while hoping something good would come out of it. This was the result. Is it a swan a or a chicken? Well, its a weird kind of bird...just named it the "Sunday bird".
Today my three weeks vacation also ended...that means tomorrow its back to work, so no more lazy days...snif, snif! No, I'm just kidding...I'm really looking forward to start work again!
Have a good start of the week too!


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Pro-Obama protesters at Romney rally admit that they are from the SEIU and are being compensated at $11.00/hour for their troubles. I feel sorry for these people; dare I say it, they are slaves and do not even know it.
boot all the boons off welfare & unemployment for working & not claiming wages


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Q: THC PPTP Bruter
April 17th, 2008 by noam, Filed under: Ask the Expert, Corporate Security
Once again – another security question from our readers to the security experts who read this blog:
I ran across your site looking for information regarding the security of PPTP. I then found the PPTP bruter program from THC. I am a small business owner. I am a VAR (value added reseller) of POS (point of sale) equipment. My POS equipment is usually windows PC's running POS software. I install a SOHO router that is also a PPTP endpoint so I can VPN in and remotely administrator my clients systems.
I'm trying to find out how easy it would be for someone to hack my PPTP endpoint. Can you help me figure out how to test my router?


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Wednesday's News Bits
This article contains unofficial information.
- Samsung's application store opens tomorrow. Its purpose will be to connect developers and users while registering online will cost $1. When a developer publishes an app and its price, the system will filter and promote it in the Samsung Application Store. Let's hope this will help the quick growth of the service. You can check the site here. (source: Samsung)
- Nokia is to change the way it names its phones. According to Mobile-Review, the manufacturer will announce more details on the Nokia World event in September. Info on the recently registered C and X series should also be revealed. (via: Unwired View)
- Microsoft with prizes for Windows Mobile developers. Since apps and widgets can now be submitted from 29 countries, the company has decided to stimulate the devs with some high-tech gadgets. The makers of the most downloaded, useful and entertaining programs will win a Microsoft Surface (a table for presentations that's controlled via multitouch). (source: Windows Mobile Blog)
- A leaked photo has revealed the BlackBerry Onyx's luxurious leather back. It looks like the more compact and functional version of the Bold, which is expected to be offered by AT&T, is hiding surprises. (source: CrackBerry)
- Sony Ericsson Themes Creator v4.05 has been released. Mac users will now be able to create their own themes for their Sony Ericsson phones, while some of the new features will allow you to crop and size images from within the app. More info can be found here. (via: IntoMobile)
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1 Comments
posted on 20 Oct 2010, 01:43 0
1. Kiltlifter (Posts: 742; Member since: 11 Dec 2008)
Holy cow... winners of the WM app win a surface... "Here is all the money you make off of commissions on your apps... and thanks for making a good app, here is $15,000 for doing a good job... have fun with it!" what a nice gift.. seriously for a techie that develops apps for a phone, getting a free surface is like telling a fat kid he just won a candy store!
Wednesday's News Bits


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January 2008
Seven Natural Gas Resolutions You Should Make for 2008
Read other articles from The Walton EMC Gasette:
Gas Up the Stove uses recipes from Walton EMC Natural Gas customers. Our customers are encouraged to submit their favorite and unique recipes to us throughout the year. Each month, one recipe is published in The Walton EMC Gasette for other customers to enjoy. The customers who get their recipe in the newsletter also receive a $25 credit toward their next Walton EMC Natural Gas bill.
Browse recipes featured in The Walton EMC Gasette.


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9 amazing laser-etched laptops you haven't seen before
Two years ago laser-etched laptops were all over the Internet, mainly because of the famous tarsier and Magritte Powerbooks. But since then people have been busily etching all kinds of things into their laptop lids, from the Mona Lisa to Barry Manilow to My Pretty Pony. In fact, we found nine pieces of etched art ("art" being a relative term) you probably haven't seen before. Most of them are from Etchstar, with an absolutely gorgeous example from Engrave Your Tech. Enjoy:
Barry Manilow
Adam & Eve
Interesting Design
The Mona Lisa
The Scream
The Enterprise
My Pretty Pony


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Pathways to break ground on new housing complex
Thanks to housing assistance from the U.S. Department of Housing and Urban Development (HUD), Pathways Community Health will break ground on Crawford Commons, a 14-unit housing complex for very low income persons with disabilities in Cuba. The ground breaking is set for 10 a.m., May 22 at Martin and Eldon streets in Cuba.
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At the end of last year Donna wrote "Some Days I Wish This Blog Were Private So I Could Share More" giving some vague but interesting hints as to how certain links can give a site a boost, and how the benefit of those links decreases if they are removed at a later date.
This was especially significant for me at the time, because I was struggling with a problem which I couldn't solve.
A few days later 5ubliminal posted, "If I Told You… I'd Have To Kill You" – a simlar idea, again specific to SEO techniques but with a few hints to how you can work out what others are up to… without them telling you.
My End Of year Problem
Lots of sites were publishing their year end stats, showing which were their most popular posts for the year, traffic numbers etc, and many of them were missing one, and in many cases many important statistics that can be used to determine the success of a particular post.
I didn't post a yearly roundup – it would have been a lie
I know which are my most successful posts based upon various metrics, and the metrics I use are in many cases different to the metrics other people use, and I can use them for competitive intelligence
I wasn't prepared to write a post highlighting my most popular posts for the year, or the ones I wanted to highlight, if I couldn't be 100% honest about my methods.
The changes Scribd made after the revealing Stompernet videos were really the straw that broke the camel's back. If you release information without a great deal of restraint on how that information should be used, it can cause problems, and sometimes various tactics and methods stop working, or are prevented from working.
Release The Information In Private?
This is one option I have considered – it would be easy to set up a membership site, or use a report such as this just for list building, or even give it to a number of membership sites I am a member of as a bonus, but that introduces secondary problems.
I am not a programmer
I have worked with programming teams for years, but I can only tinker with code these days. If I released the information to just a few hundred, or possibly a few thousand, there would be 2 very specific problems.
- Only about 10% of the people receiving the information would be able to do anything useful with it – this stuff is a little bit technical, and even once I have all my data together it takes time playing around in excel to really benefit from it, and realise the significance.
- My limited use of these methods flies under the radar – if you have a few 100, or 1000 people mining the same data, it would throw up a huge red flag, quite needlessly, as many would be looking for data on exactly the same websites.
If I make the information available, the ideal solution would be
- A 20 page report
- A viable proxy based extraction and storage system for compiling data
- Various tools, possibly in Excel, to make manipulating the data relatively easy for less technical folk
Oh, Andy Is Going To Sell An Ebook?
Ebooks work for newbie stuff and basic training, or techniques that get hyped but are not necessarily for your average users (even if they are effective)
This isn't something I want to hype about, and it certainly isn't basic training
The financial model just wouldn't cover the development costs
I could also include it in a membership site of my own, but it isn't something that would stand on its own, I need a lot more time to get together complimentary materials.
With the new year people are planning their course of action for 2008, and this would prove a benefit for their content planning strategy.
Content For Your Membership Site or Agency
Do you remember the days before the junk peddlers of private label rights and bundled master resale rights products when content really had value?
These days the people who create exceptional content only provide it via higher end membership sites, and most, but not all of the ebooks are beginners guides – they can still be good value, but that isn't the kind of content I want to create.
Over the last year writing this blog I have received a number of proposals of various kinds from membership site owners looking for specialist content, which is why I am considering a slight return to the old ways of providing content to a limited number of partners for a fee that is just a "drop in the ocean" compared to the fees members pay for access to great content, and certainly much better value than retaining me on a permanent basis.
Price – contact me by email for details – I expect to spend up to $5000 on development of the scripts and tools, though depending on the way they are designed, I might also have to provide hosting. I would much prefer to have a comfortable budget for development than to be scraping the barrel.
On top of that I will also be offering support if you provide me access to your member area – there is certainly some 2-way benefit
Initially I am not going to set a specific limit on numbers, but ideally I would like to have the report and tools made available to between 10 and 20 membership sites or agencies
I am including search marketing agencies, because they often have lots of people working with clients with whom they want to share tools and reports. Hopefully a few of the more popular SEO membership sites will pick this up anyway, so small agencies can benefit from their existing memberships, but for larger corporations it would probably be best to purchase your own license.
For further details and possibly a few examples those who have my email can just email me, or you can just use my contact form
I am going to be selective about where this information and tools will be made available
To finish, just one example:-
Which one post was my most successful in 2007? This isn't 100% accurate because like with all statistical measures there can be extenuating circumstances that mess with the data, and using this method there are frequent occurances within the top10, in much the same way a front page Digg can make a blog seem more popular than it really is.
The Tale of Little Linkalot and Some Blogging Thoughts where I actually linked through to another one of Donna's posts, "The Tale of Little Linkalot"
If you can work out why I regard that (based on this method) as my most successful post, a "cornerstone" or in some ways "tipping point", bully for you, but don't go spreading it around too much ;)
Even if you can work it out, you are going to appreciate a 20 page report on how to use this method to share with your members or clients, and the tools to go with it.
I could have just written a short blog post with my top 50 stories of 2007, provided details for compiling the data, and a very rough excel spreadsheet and a few charts, but it would not be very usable for the majority of non-programming geeks, and the method would be burned or limited within a few hours or days.
Why burn a great method just for a few links?
Liked this post? Follow this blog to get more.


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A good French composer, much neglected, is Charles Koechlin who was born on 27 November 1867 and lived until 31 December 1950. He did not commence his studies until the age of 22, but compensated through his life with a sizeable output including much chamber and orchestral music. Following no particular trend, he showed influence from early masters and Stravinsky.
CD Spotlight. Glowing Performances - Music by Koechlin and Jongen, recommended by Howard Smith. '... a truly outstanding recital ...'
The Composer's Conundrum? - Alistair Hinton comments on Gordon Rumson's recent article
The Composer's Conundrum - Gordon Rumson has some bad news about creativity and self-promotion
CD Spotlight. Sovereign Horn Territory - Music for horn and orchestra, recommended by Howard Smith. '... stunning breath control and consummate understanding ...'
CD Spotlight. Interlinking resonances - A song recital by Malena Ernman, reviewed by Robert Hugill. '... lively and charmingly refreshing ...'
Music matters - Gordon Rumson reads Wilfrid Mellers' book 'Singing in the Wilderness: Music and Ecology in the Twentieth Century'
Planning your collection - Koechlin -


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With this deal, you don't have to decide yet when to go. Just purchase a voucher from Travelzoo then call the hotel directly at 1-866-374-4411 to make a reservation for your desired travel dates. Not available on: Sept. 10, 16, 19-20, 24, 27, 30; Oct. 2-5, 7-8, 10-12, 17, 19, 21. Dining credit is valid toward the purchase of two dinner entrees. Reservations are subject to availability and early booking is encouraged. See below for full terms and conditions.See all terms
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More About This List Of Eritrean Names
This is the page where you can see a list of all the Eritrean baby names. Enjoy this complete overview to find that special name for your newborn baby. Click on one of the Eritrean baby names in the lists to see the meaning, the popularity and much more information of this Eritrean name. The following tips can be used for some help in finding a Eritrean name.


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The unincorporated village of Union Pier in Chikaming Township is home to a township beach that is reserved exclusively for property owners and their guests. Situated along the banks of the Green River near the shore of Lake Michigan, Union Pier is just six miles north of the Indiana-Michigan border. With only a scattering of quaint commercial development, the modern village remains one of the most pristine and desirable resort areas in Michigan. The surrounding area encompasses wooded shoreline, majestic dunes, resort amenities, wine country, miles of trails, and Lake Michigan's blue waters. The state parks in this region feature sand dunes that tower as high as 250 feet, while Warren Woods offers a primeval forest with hiking trails along the winding Galien River.
Logging and timber were Harbor Country's major industries in the 1870s, requiring shipping piers along Lake Michigan's shoreline. One of those piers, Union Pier, gave its name to today's quaint lakeshore community. Union Pier is little more than a corner store, garage, and an ice cream shop, but the nearby countryside is dotted with unique antique shops, galleries and grand old resorts that have been restored to their former state.
Union Pier was founded on an ethic of hard work without visions of a port to rival Chicago as was Wessel Whittaker's notion in New Buffalo. There was nature's bounty to be harvested here. Tree trunks measured five feet and more in diameter. Trees rose 60 feet to the lowest branches. Squirrels, we are assured ran through the community without ever touching the ground.
There clearly was no Sears Tower to be seen on the horizon across the Lake, but everyone in what is now Union Pier understood that timber was the fuel which would fire the growth of Chicago. Boards could be bucks.
John Gowdy arrived from New York and bought all the timberland he could afford. He brought in additional partners who understood that it was necessary to ship Union Pier's bounty to Chicago. And so, a group of men built a "Pier" in Union" at the foot of Berrien Street. It was constructed as a 600-foot edifice jutting into Lake Michigan. a 130-ton schooner was built on the adjacent beach.
Soon there were brick tool handle factories sending their wares to Chicago and beyond. The Chicago Fire of 1871 only increased the demand for Union Pier's natural bounty. But, Chicago was rebuilt, Union Pier's pier washed away and a new economy had to be established.
The leveled forests soon became orchards and farms. Lumber men became fishermen and shipped their new harvest to Chicago. During the spawning season, residents would gather on the beach to spear Sturgeon of a hundred pounds. In the 1900's, tourism replaced timber, bricks and fishing as Union Pier's major Industry. Union Pier became the United Nations of tourism.
As the emerging popularity of rail travel began to import visitors from neighboring counties and states, the Pere Marquette Rail Road established a rail stop in Union Pier, with its own station. These early travelers were, as today, fond of the appealing lakeshore town, hosted by many long gone boarding houses and resorts that dotted the pristine Lake Michigan shoreline. Eastern Europeans, African Americans and Jewish vacationers all established homes and resorts in the community.
Olympian Jesse Owens had a home here. Chicago Mayor Anton Cermak, ultimately the victim of an assassin's bullet, brought guests to his summer home by yacht.
John Dillinger even stopped for gas at the Prusa Resort service station which is now the Wine Sellers at Miller's Country House. The Prusa kids, who manned the gas tanks, told stories about Dillinger not allowing anyone to check the engine compartment where he stored his weapons on racks. Al Capone was also known to have had homes in the area. He'd play an occasional game of cards with his buddies at the Lakeside Inn and may have had a lady along for luck. But really, it's the sunsets over the lake that gets us all. Even the early lumbermen would have agreed--they had a bounty of nature to offer Chicago.
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LARGE SET OF FOUR WIRE STORAGE CUBES (Item #W81634)
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Display decorative items or tuck books, DVD's and other accessories out of the way with this Large Set of 4 Wire Storage Cubes. The set of 4 cubes are stackable, enabling you to configure them in a variety of ways and are ideal for kitchen, bathroom, or garage storage. Cubes are constructed of sturdy metal wire with plastic connectors. Dimensions: 30.125" x 14.625" x 30.125". *Extra $5 Shipping.
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Daddio2013's Mom Answers Activity
Daddio2013 is a star in these topics:
Pregnancy > Newly Pregnant (1 helpful answer)
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My husband and I disagree about circumcising our son. What can we do?
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Also remember we all have to use soap anywaysposted by a BabyCenter Member
I want to make things better...to understand...to share and help....Things are getting worse!
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Hey fella. Keep ur chin up. Pregnant women are in a league of their own. Nothing you say or do will be right - even if she told you to sa...posted by Daddio2013
How can I be happy?
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As a father to be maybe i can offer a POV. I find it very difficult to get excited about things that are "going" to happen. eg,...posted by Daddio2013
Father to be....Pain at 23 weeks while holidaying in Turkey???
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Let's go to the beach
beachTaken by iany_t with a Lomography Fisheye No. 2 loaded with Kodak Ultramax 400 (35mm) film in Riviera de São Lourenço, Brazil. These tags describe this photo: double exposure, dupla exposição, múltipla exposição, multiple exposure, portrait, retrato, friends, sea, ocean, mar, seaside, and praia. Date: 2011-03-27. Time: Morning. This photo can also be found in the albums #6.
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Welcome to the Eller College of Management
Eller College fosters mutually beneficial relationships with organizations in Southern Arizona and beyond. Learn more through the resources below:
Recruiting and Internships
Tap the skills and knowledge of Eller College students and alumni:
Strategic Business Consulting
Work with a cross-functional team of Full-Time MBA students in the areas of finance, accounting, management and operations, marketing, strategy and innovation, entrepreneurship, management information systems, and economics on a semester-long consulting project.
Innovative partnerships are one of the best ways to simultaneously further the goals of your organization and improve our research and education.
Invest in Eller
Your support will help Eller College deliver superior management education, advance knowledge in business, technology and administration, and connect research and innovation to vital social and commercial applications.
Non-Degree Executive Programs
Education is a lifelong process. Find out more about continuing executive education through Eller Non-Degree Executive Programs, which offers custom executive education such as the Business of Medicine™ and Business of Healthcare™ programs, as well as the Arizona Healthcare Leadership Academy and Southwest Leadership Development Program.
National Board of Advisors
The National Board of Advisors plays a vital role in resource development and communications and advises the College on important policy issues. Members and their organizations donate money and equipment, offer internships and jobs, host site visits and class projects, and underwrite scholarships and faculty research.
For additional information, please contact us.


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"Very good recipe, but needed slight tweaking. Too much pasta and not enough meat. 1lb of Italian turkey sausage minimum and I suggest only half a box of pasta. Other than that the tastes are right on the money! Very good comfort food. Next time I think I'll add veggies, maybe broccoli, for more color and a well rounded meal.""


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News Headlines
Street Car Test Drive
Posted: August 20, 2012 Ends: September 16, 2012 at 3:00 PM.
Street Car Test Drive Friday August 31, 6:00 PM
Any one interested in seeing what there car is like on our track can try it on
Show up at the competitors entrance, sign the insurance waiver, (car must be registered to driver, bring your regestration) and try our track on for speed.
$20 per car and $5 for spectators.
Cars are on track one at a time, 2 timed laps each and repeat throughout the night.
No trucks 3/4 ton or larger allowed (may damage pavement).
Bring out some buddies and get bragging rights to fast times. See you there!
For more info contact Todd Jalbert Phone 249-5678 Cel 493-7642 or email email@example.com
Rescheduled to Sunday Sept 16, 1:00 PM


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Heloo all! I would like to find out why i cant seem to get my 3rd screen active?Bought the R9 270x about 2 weeks ago, and i bought it because i thought it was able to use 3 screens without the DPSo currently i have 2DVI's and 1 HDMI connected to the card. But it does not seem to pick up one of the DVi's, it only activates 1DVi and the 1 HDMI.Is there a way i can activate all 3 screens?Thanks for the help!Hasie109
The R9 270x is based off of a Radeon HD 7870. To my knowledge, it still requires at least one active display connected to DP.
The 7790, R7 260, and r9 290 should not have that limitation.
EDIT: just checked the AMD website. It's supposted to work. Which manufacturer is your R9 270x?
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Learn about the International Activities of the National Academies
Predoctoral & Postdoctoral Opportunities See which are right for you!
Contact Us email@example.com Policy and Global Affairs 500 Fifth St. NW Washington, DC 20001 (202) 334-2425
Media Coverage
Sustainability for the Nation: Resource Connection and Governance Linkages (June 2013) Read Online Free Buy the Book or Download Free PDF
June 10, 2014Quiet Collaboration; Big ImpactMitchell FoundationI remain convinced of this and always want to shine the light on glowing examples of collaboration in action. One such example is the National Academies' Roundtable on Science and Technology for Sustainability (STS), of which I have been privileged to be a member over the last six years.July 9, 2013Restructure US Government to Make "Huge" Green Changes in America, Study ProposesFox News... and overcome legal barriers to help install the nebulous principle of "sustainability" across government, the economy and society at large, according to a new National Research Council study sponsored by many of the federal departments that would ...


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Wahine Loves.. is Here!Download the last issue in pdf.
Wahine Loves..a good conversation!
Recent EssaysEnjoy great essays.
Beyond a smile, a tear, a kiss
Show Us Your heArtShow off your original crafts or art work, poetry, & paintings
Go ahead an open your heArt and Treasures. Tell us what motivates, inspires and even tickles you! We'll post a sample in Beezcounts for sale. Jewelry and Custom Jewelry, Trendy Fashion Designs by you, Bags, Visual Art, Collections, Vintage/Designer items, you just Show Us. Click on the "Contact us" link or the + symbol in the upper right to find out more or to add a submission.


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Definitions for e-la
This page provides all possible meanings and translations of the word e-la
Webster Dictionary
originally, the highest note in the scale of Guido; hence, proverbially, any extravagant saying
Find a translation for the e-la definition in other languages:
Select another language:
Discuss these e-la definitions with the community:
Use the citation below to add this definition to your bibliography:
"e-la." Definitions.net. STANDS4 LLC, 2014. Web. 21 Dec. 2014. <http://www.definitions.net/definition/e-la>.


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Students of this class will come to attain a deeper level of understanding of the Graffiti Art Movement of the 1980's in NYC, and where the movement stands now. This will be done through the use of clips from several documentaries and films on the topic.
Students in class can chose to embrace the Art by partaking in the aided selection of a "Tag." Once a "Tag" has been decided upon, students will learn the basics of "Graffiti Writing" including techniques known as 'throw-ups,' 'Burners,' and 'Pieces.' Students will create their very own customized drawing of their new typographical persona, and leave with the knowledge and insight on how to explore its possibilities.
Students will observe live spray painting in a demonstration by the instructor as they draw their own pieces, and will have one-on-one coaching on their drawings from an expert(s).
In our second session, students will learn how to spray paint exclusively on our wall at Decor Art Gallery. (Please bring your own spray paint!)
Decor Art Gallery
555 3rd Avenue
New York, NY
30-60 Minutes of conversational viewing of Documentaries and Films on the topic
20-30 Minutes Demonstation/Lecture on "Style."
30-60 Minutes of application of new knowledge through drawing
At times, Guest Speakers and Active Artists may or may not be present as well, yet, as most graffiti artists pride themselves on elusiveness, no appearance is scheduled.
3:00 pm - 4:30 pm EDTAdd to Cal
Decor Art Gallery
555 3rd Avenue
New York, NY
30-45 minute Lecture/Demonstration of "Exterior" mediums of expression, including:
60-90 Minutes of Application of the new knowledge.
For the duration of this segment, I will teach you how to manipulate spray paint to depict your own creations, will discuss how to install exterior work, and cover all other unknowns in the process called Graffiti.
TBD - TBDAdd to Cal
Fabian Verdejo is a New York City native with extensive training in the Visual Arts. After graduating from The Fashion Institute of Technology, NY, NY, Verdejo went on to study Realist Drawing and Painting at The Grand Central Academy of Art, NY, NY, and later at The Florence Academy of Art, Göteborg, Sweden. Having been an active graffiti artist throughout his academic career, Verdejo has left his mark in roughly 20 countries throughout Europe, North and South America, and even at The New York City Graffiti Hall of Fame at 106th Street and Park Avenue, NY, NY.
This class hasn't been reviewed yet.