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Jarret Cummings (EDUCAUSE)
Jarret Cummings (EDUCAUSE)
Washington, District of Columbia
Membership Information
Jarret Cummings serves EDUCAUSE as Director of External Relations. In this position, Cummings works with the EDUCAUSE president and executive team to establish, implement, and maintain outreach strategies consistent with the association's strategic directions. He supports the president in her direct engagement with organizations, associations, and government agencies to advance EDUCAUSE strategic objectives and facilitates coordination with EDUCAUSE executives and staff on presidential outreach. Likewise, Cummings coordinates with EDUCAUSE executives and staff on external contacts and/or opportunities for collaboration that have significant strategic implications or may otherwise warrant involvement by the Office of the President. He also manages media relations for the association.
Prior to his current role, Cummings worked as a policy specialist in the EDUCAUSE Washington Office. In that position, he advocated on behalf of higher education IT in relevant legislative and regulatory contexts, especially federal, and collaborated with representatives of EDUCAUSE member institutions to promote and facilitate effective, consistent institutional IT policies. Cummings has also served the association as special assistant to the president, helping to assess and respond to strategic and tactical issues as well as to support presidential outreach and special projects; and as program administrator for the EDUCAUSE Learning Initiative (ELI), where he coordinated ELI strategic and operational planning as well as delivery of ELI events, services, and resources.
Before joining ELI, Cummings worked for SunGard Collegis in information technology (IT) strategic planning, institutional strategic planning, and general management consulting. His clients included colleges and universities of all types. He focused on helping institutions link their technological progress to the achievement of their missions and strategic objectives, including their goals for advancing teaching and learning through technology.
Cummings began his career as a program analyst working with higher education grant programs at the U.S. Department of Education. After completing a master's in public administration at Syracuse University, he joined the staff of the executive vice chancellor of the California State University system to coordinate a system-wide strategic planning task force. Following that, Cummings worked with the University of North Carolina system as special projects director and later as special assistant to the system CIO. In those roles, he managed system-wide IT strategic planning and network infrastructure planning projects. He also analyzed state and federal IT policy issues for the system president and CIO and coordinated the CIO's participation in the state's joint select committee on information technology.
In addition to the MPA, Cummings holds a bachelor's in philosophy from Southwestern University. His personal interests include weight training and science fiction.
EDUCAUSE Involvement
- EDUCAUSE Face-to-Face Annual Conference 2014, October 2014
- EDUCAUSE Face-to-Face Annual Conference 2013, October 2013
- EDUCAUSE Face-to-Face Annual Conference 2013, October 2013
- Southeast Regional Conference 2013, May 2013
- ELI Annual Meeting 2013, February 2013
- Mid-Atlantic Regional Conference 2013, January 2013


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NOTE: The products listed are for use by eligible State of Texas entities ONLY and are not for personal purchase or purchase by commercial entities.
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Contract Terms and Instructions
Start Date: 05/2004
End Date: 11/2012
Section 1: 1.1 DESCRIPTION OF CONTRACT: 962-A3 Courier/delivery service for expedited pickup and delivery of packages within designated areas for the El Paso area. 1.2 TYPE: Automated Firm Price with the exception of CPI-W allowed increases (see 1.13 Price Changes). 1.3 TERM OF CONTRACT: March 1, 2004 through August 31, 2012 EXTENSION PERIOD: September 1, 2012 through November 30, 2012 1.4 DELIVERY: As specified. 1.5 MINIMUM ORDER: None. 1.6 SPOT PURCHASE OPTION: None. 1.7 ZONE: This is a special service contract that covers the areas identified in the zone map (or see paragraph 3.4). 1.8 SHIPPING INFORMATION: Not applicable. 1.9 WARRANTY: Not applicable. 1.10 CASH DISCOUNT: Applicable cash discounts are identified in line item descriptions. 1.11 EDUCATIONAL DISCOUNT: Applicable educational discounts are identified in line item descriptions. 1.12 QUANTITY OR LARGE ORDER DISCOUNT: Vendors are encouraged to offer discounts for one-time delivery or large single orders of items. 1.13 PRICE CHANGES: Price decreases may be accepted at any time. 1.14 FUNDING OUT: Any blanket purchase order (an order calling for multiple deliveries over a specified period of time) is contingent upon the continued availability of appropriations. 1.15 POINT OF CONTACT: Vendor contacts are listed at the end of the contract. 1.16 RECYCLED PRODUCTS: Efforts have been made to identify any product meeting the criteria definitions of recycled. If you have any questions regarding recycled products, please contact the Recycling Coordinator at (512) 463-3034. 1.17 HUB VENDORS: HUB vendors are identified in the Contract Vendor List as "HUB". 1.18 INTERPRETATION: Questions concerning terms and conditions and technical specifications should be directed to: Melissa McIlroy, CTPM, CTCM Texas Procurement and Support Services Phone: (512) 463-3174 E-mail:email@example.com 1.19 PURCHASE ORDERS: Only contract purchase orders issued by the Texas Comptroller of Public Accounts (CPA) or orders issued through a CPA contract are eligible for contract pricing. 1.20 COMMODITY CODE CONVERSION: In order to facilitate with the CPAs conversion to the NIGP commodity codes, the commodity code numbers for items on this contract may change at some point during the term of the contract. The specification, price, and other terms of the contract will remain the same. Section 2: - Specific Contract Instructions 2.1 INTRODUCTION: This contract is to provide courier/delivery service for the El Paso area as identified in the map and zone information. Service shall be available to outlying areas based on additional service fees. The service can be initiated from any qualified ordering entity by telephone request. Possible packages could range from standard letter type, flats or boxes. Boxes will be limited to 100 pounds. One vendor has been awarded this contract. Regular service hours will be 7:30 a.m. to 5:30 p.m., five days a week excluding official state holidays. Either vendor may be utilized by the service requester. If vendor is unable to provide the service required, the user may utilize any service that can fulfill the requirement. Holiday, after hours and weekend service may be available with allowable service charges. 2.2 COURIER/DELIVERY SERVICE REQUIREMENTS: The contract carriers must provide all of the following pickup and delivery services for the scheduled delivery commitments indicated: A. Hotshot - Defined as non-stop within reasonable travel time. This service is only available as feasible. The vendor will indicate if service request is feasible. B. 1 Hour - Defined as delivery within one hour after request. C. 2 Hour - Defined as delivery within two hours after request. D. 4 Hour - Defined as delivery within four hours after request. E. Same Day - Available by 10:00 a.m.; delivered by 5:00 p.m. F. Regularly Scheduled Hot Shot - Defined as regularly scheduled non-stop with reasonable travel time. This service is only available as feasible. The vendor will indicate if service request is feasible. G. Regularly Scheduled 1 Hour - Defined as regularly scheduled delivery within one hour after request. H. Regularly Scheduled 2 Hour - Defined as regularly scheduled delivery within two hour after request. I. Regularly Scheduled 4 Hour - Defined as regularly scheduled delivery within four hours after request. J. Regularly Scheduled Same Day - Regularly scheduled delivery available by 10:00 a.m.; delivered by 5:00 p.m. The service level time clock begins when the requester initiates the call for pickup. Failure to provide the service within the required timeline will result in the delivery being performed at no charge to the qualified ordering entity. Any delivery not made within 10% of scheduled delivery time will be considered delinquent. If package is not ready at time of pickup, scheduled delivery begins when package is available for pickup. Further, continued delinquent pickup and delivery complaints can result in the termination of the contract for the respective vendor. This contract, in general, does not cover second day service. The level of service requested must fall within the time available. It is known that there will be exceptions to this such as undeliverables which must be delivered by 10:00 a.m. the next business day. Entities will still be responsible for payment of undeliverables if the reason for such is not the fault of the vendor. The State acknowledges the courier/delivery commitment does not apply when the delay is due to causes beyond the vendor's control including, but not limited to, the following: the availability during normal business hours or refusal of a person to accept delivery; wrong addresses; acts of God; riot; strikes or other labor disputes; civil commotions; natural events such as extreme weather phenomena or natural disasters. If weather or hazardous conditions become an issue, both requester and vendor shall make concurrence about shipment. Regarding addressing of mail, the sender must use the addressee's physical address and not the post office box. The physical address should appear in the second to last line of the address, above the city, state and zip code. Letter mail pieces undelivered under this contract shall contain mail material deemed "Extremely Urgent" by the qualified ordering entity, pursuant to 39 CFR Part 320.6(d) which reads as follows: (Excerpt from 39 CFR Part 320.6) - "(d) The sender must prominently mark the outside covers or containers of letters carried under this suspension with the words 'Extremely Urgent' or 'Private Carriage Authorized by Postal Regulations (39 CFR 320.6)' or with a similar legend identifying the letters as carried pursuant to this suspension. In addition, each outside container or cover must show the name and address of the carrier, and the name and address of the addressee. Carrier records must be sufficient to show that the delivery of the letters was completed within the applicable time limitations, if carried under the authority of paragraph (B) of this section, and must be made available for inspection at the request of the postal service. The required records may be either in the form of notations on the containers or covers of any letters asserted to be carried under this suspension, or in the form of records kept by employees of the actual times they pick up and deliver such materials." 39 CFR Part 320.6(b)(1) says, "Letters dispatched within 50 miles of the intended destination by noon must be delivered within six hours or by the close of business day and those dispatched after noon must be received by 10:00 AM of the next business day." The awarded vendor is not to depart a user entity with a package unless it is properly marked. Vendor may accomplish this by means of stamp, label, etc. 2.3 APPLICABLE LAWS: Contract carriers shall be required throughout the term of this contract to comply with all applicable federal, state or local laws pertinent to such carrier and the subject matter of this contract, whether statutory or regulatory. Qualified ordering entities utilizing this contract shall ensure that mail pieces comply with applicable requirements for the purposes of such laws, rules and regulations. Letter mail pieces delivered under this contract shall contain mail material deemed "extremely urgent" by the qualified ordering entity. 2.4 USE OF CONTRACT: Qualified ordering entities (with exception of Cooperative Purchasing Participants) will be expected to utilize this contract exclusively for courier/delivery service except when available services do not meet their requirements. 2.5 VOLUME REQUIREMENTS/PICKUP SERVICE: The carrier shall not place any minimum piece requirements on any qualified ordering entity participating in this contract which would serve to exclude or be grounds for charging fees higher than those quoted under this contract. If daily service is required, the user may coordinate daily pickups with the vendor. This service shall be provided at no charge to the user. Vendor shall verify that description and quantities picked up correspond with invoice/packing slip. Vendor shall verify purchase order number is on invoice/packing slip and sign. Vendor must provide preprinted bills of lading to each pickup site. Vendor may assess a waiting fee if any user detains them for more than 10 minutes. 2.6 DESIGNATED SERVICE AREA: The designated delivery service areas are defined by the zone map (or see paragraph 3.4). The zones indicate destinations. 2.7 TRACKING: The vendor must be able to provide tracking capabilities on all packages. In case of lost package or if the vendor was unable to deliver, the user must be contacted within 10 minutes of the scheduled delivery time (within the 10% guideline on delivery). 2.8 TRANSIT CONTAINERS: The vendor will not be responsible for any delivery supplies such as envelopes, boxes, etc., this will rest solely as a responsibility of the user. However, on bulk deliveries, transportation from the designated pickup spot will rest with the vendor. The user shall also be responsible for package identification on each package. This is above and beyond the delivery ticket. 2.9 DECLARED VALUE: Vendor shall provide declared value liability coverage for any package at no additional cost to user entities at the value declared of $50.00. Entities requiring higher declared value liability coverage may procure coverage outside of this contract from an insurance carrier or use another carrier as necessary. 2.10 LOST/DAMAGED GOODS: The vendor will be responsible for the minimum declared value of each damaged or lost package payable to the using entity. Section 3: Contract Specific 3.1 BILLING/PAYMENT: All charges shall be billed to the specific using entity billing address as specified by the user. Users will be billed directly by vendor under the blanket purchase order number issued by the user. Billing will be required at a minimum monthly but may be done bi-monthly. The vendor shall establish a unique billing account and may invoice users at intervals of their choosing (at minimum monthly) with adequate detail to identify: Date, mail piece, tracking number, entity billing number, destination and cost. 3.2 PAYMENT: Payment of outstanding invoices shall be made at least monthly and in accordance with Government Code, Title 10, Subtitle F, Chapter 2251, 1 TAC 114.7. 3.3 BILLING CORRECTIONS: The State shall return any bills for correction of billing errors without prejudice. Under no circumstances should a billing discrepancy not be resolved within 15 days. 3.4 CHARGES: Zones have been identified by zip code. All charges will be based on furthest point, pickup or delivery. For Example: Zone A to Zone C=C Charge Zone C to Zone A=C Charge Special Service charges are in addition to weight and zone charges. Zone A Zip Codes: 79901, 79902, 79903, 79905, 79906, 79930 Zone B Zip Codes: 79907, 79915, 79925, 79936. Zone C Zip Codes: 79904, 79908, 79924, 79934 Zone D Zip Codes: 79922, 79932, 79928 (see Attachment A) 3.5 ACCOUNT SET-UP: The using entity is responsible for contacting the vendor to set-up accounts. 3.6 SPECIAL ORDERING INSTRUCTIONS: Qualified ordering entities must establish a blanket order against the contract by submitting a contract purchase requisition indicating the commodity code representing the closest monetary value of expected courier/delivery expenditures. Purchase orders will automatically include the following language: "This is an automated contract blanket order for courier/delivery services effective date of order through January 31, 2004 (quantities to be called as needed). Any outstanding balances will be canceled if not ordered by the end of the contract period." SPECIAL NOTICE: BLANKET ORDERS ON THIS CONTRACT CAN BE ELECTRONICALLY ENTERED. EXAMPLE: If you have estimated your previous year expenditures to be $1,000, then a contract requisition should be submitted, establishing a blanket order. Orders can be placed against this blanket order up to the maximum of $1,000. Care should be given in tracking usage so as not to exceed the amount. If a user gets close to the "not to exceed" amount, they will need to issue another contract purchase requisition to cover estimated additional usage. NOTE: Do not use a purchase order change to renew or extend an expiring purchase order. VENDOR - FLEX EXPRESS COURIER/DELIVERY SERVICE - ZONE A HOTSHOT NON-STOP $33.50/EA 1 HOUR SERVICE $27.50/EA 2 HOUR SERVICE $25.00/EA 4 HOUR SERVICE $17.50/EA SAME DAY $13.50/EA REGULARLY SCHEDULED HOTSHOT NON-STOP $27.50/EA REGULARLY SCHEDULED 1 HOUR SERVICE $27.50/EA REGULARLY SCHEDULED 2 HOUR SERVICE $23.50/EA REGULARLY SCHEDULED 4 HOUR SERVICE $13.50/EA REGULARLY SCHEDULED SAME DAY $13.50/EA COURIER/DELIVERY SERVICE - ZONE B HOTSHOT NON-STOP $30.00/EA 1 HOUR SERVICE $27.50/EA 2 HOUR SERVICE $23.50/EA 4 HOUR SERVICE $17.50/EA SAME DAY $13.50/EA REGULARLY SCHEDULED HOTSHOT NON-STOP $26.50/EA REGULARLY SCHEDULED 1 HOUR SERVICE $24.00/EA REGULARLY SCHEDULED 2 HOUR SERVICE $21.00/EA REGULARLY SCHEDULED 4 HOUR SERVICE $12.00/EA REGULARLY SCHEDULED SAME DAY $12.00/EA COURIER/DELIVERY SERVICE - ZONE C HOTSHOT NON-STOP $35.00/EA 1 HOUR SERVICE $30.00/EA 2 HOUR SERVICE $27.50/EA 4 HOUR SERVICE $16.50/EA SAME DAY $13.50/EA REGULARLY SCHEDULED HOTSHOT NON-STOP $26.00/EA REGULARLY SCHEDULED 1 HOUR SERVICE $26.00/EA REGULARLY SCHEDULED 2 HOUR SERVICE $23.50/EA REGULARLY SCHEDULED 4 HOUR SERVICE $13.50/EA REGULARLY SCHEDULED SAME DAY $13.50/EA COURIER/DELIVERY SERVICE - ZONE D HOTSHOT NON-STOP $36.50/EA 1 HOUR SERVICE $33.50/EA 2 HOUR SERVICE $31.00/EA 4 HOUR SERVICE $28.50/EA SAME DAY $18.50/EA REGULARLY SCHEDULED HOTSHOT NON-STOP $36.00/EA REGULARLY SCHEDULED 1 HOUR SERVICE $33.50/EA REGULARLY SCHEDULED 2 HOUR SERVICE $31.00/EA REGULARLY SCHEDULED 4 HOUR SERVICE $28.50/EA REGULARLY SCHEDULED SAME DAY $16.00/EA COURIER/DELIVERY OVER 100 LBS. - ZONE A PER POUND CHARGE $ 0.10 COURIER/DELIVERY OVER 100 LBS. - ZONE B PER POUND CHARGE $ 0.10 COURIER/DELIVERY OVER 100 LBS. - ZONE C PER POUND CHARGE $ 0.10 COURIER/DELIVERY OVER 100 LBS. - ZONE D PER POUND CHARGE $ 0.10 COURIER/DELIVERY OVER 1000 LBS. - ZONE A PER POUND CHARGE $ 0.17 COURIER/DELIVERY OVER 1000 LBS. - ZONE B PER POUND CHARGE $ 0.17 COURIER/DELIVERY OVER 1000 LBS. - ZONE C PER POUND CHARGE $ 0.17 COURIER/DELIVERY OVER 1000 LBS. - ZONE D PER POUND CHARGE $ 0.17 SPECIAL SERVICES - ZONE A BOBTAIL/LIFT GATE $20.00/HR VAN CHARGE N/C WAITING TIME $25.00/HR AFTER HOURS $20.00/EA HOLIDAY $30.00/EA BUS SERVICE $15.00/EA ATTEMPTED PICKUP $17.50/EA WRONG ADDRESS $17.50/EA SPECIAL SERVICES - ZONE B BOBTAIL/LIFT GATE $20.00/HR VAN CHARGE N/C WAITING TIME $25.00/HR AFTER HOURS $20.00/EA HOLIDAY $30.00/EA BUS SERVICE $15.00/EA ATTEMPTED PICKUP $17.50/EA WRONG ADDRESS $17.50/EA SPECIAL SERVICES - ZONE C BOBTAIL/LIFT GATE $20.00/HR VAN CHARGE N/C WAITING TIME $25.00/HR AFTER HOURS $20.00/EA HOLIDAY $30.00/EA BUS SERVICE $15.00/EA ATTEMPTED PICKUP $17.50/EA WRONG ADDRESS $17.50/EA SPECIAL SERVICES - ZONE D BOBTAIL/LIFT GATE $20.00/HR VAN CHARGE N/C WAITING TIME $25.00/HR AFTER HOURS $20.00/EA HOLIDAY $30.00/EA BUS SERVICE $15.00/EA ATTEMPTED PICKUP $17.50/EA WRONG ADDRESS $17.50/EA DECLARED VALUE $50.00 base @ no charge $.50 IN $50 INCREMENTS ZONE "D" PER MILE CHARGE $ 1.50/MILE 87359 1-75-288-0636-1 FLEX EXPRESS INC SUITE 904 100 N CENTRAL EXPRESSWAY RICHARDSON TX 75080 MANDO LUNA Phone: 915-774-9775 Fax: 915-774-0634

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Morality comes very high on Mozgus's priority list- tattooed on his right shoulder are the scales of justice, a reminder to be certain of what is right and wrong, a judgement that is sometimes difficult to place in the world of Hunters vs Demons. Remaining on the side of justice is a very important factor in Moz's life, and he will work very hard to maintain his sense of right and wrong, often being very uncompromising to anything but clear justice.
Along with justice, Clyde likes to keep a sense of organization and clarity to his life- he is a very well organized person, and about as clean as a hunter can be (the only real exception being when in a fight, Clyde is capable of extreme rage at times, any who've seen him during one of his fits of rage typically think he's crazy). For these reasons, Moz does not drink or smoke or take in anything he thinks is unnatural- of course the abstinence from alcohol also comes from a desire to be alert at all times, fearing the thought of being caught off guard. But then again, issues with the fear of being off guard or being too trusting has always plagued Mozgus's life. He keeps most people at arm's length, believing them to be primed and ready to betray him to suit their own ends. He doesn't have any problem making pals or buddies, but friends is a totally different matter- Clyde has very tough standards for making true friends- most everyone is either a "pal" or a "buddy" or an "acquaintance" until they prove themselves to him.
All in all, Clyde comes off charming or friendly enough, but something under the surface seems to hint at a darker, melancholy personality- he comes off as lonely, but then again, most hunters do. However, no matter how many laughs are shared or how inviting or charming the young hunter is, it is hard to shake off a sense of blue brokenness, or perhaps a hint of rage fueling an unstoppable determinism.
That story of the original Mozgus was told to the new Moz quite regularly, a reminder of values- honesty and justice, and self sacrifice. Moz watched his father maintain these values as he grew up- his father aspired to own a car-repair company, and he joined into the market at just the right time, quickly becoming an engineer and mechanic of some renown. Somewhere along this period, Mozgus was born as the only boy amongst 6 children. By the time Mozgus was 8, his father had opened his first shop, and was doing quite well- and as his father's business expanded, Mozgus's life grew easier. He had a knack for cars and machines, not unlike his father before him.
However, all of a sudden, Mozgus's father became accustomed to sudden, strange, quirks- he was prone to bursts of severe anger, he swore, alienated people around him, and on one incident, struck his wife- and things only got stranger and stranger. Mysterious deaths began to circle around the car-repair shops, a sudden surge of wrecks, malfunctions, strange incidents- and on several occasions, Moz spied his father's workers tampering with the cars, and after he investigated further, Mozgus discovered his first hex bag. Not long after that, Mozgus had his first experience with Hunters- they came investigating the deaths, they asked Mozgus, who had done some digging and discovered what the hex-bags were meant to be, he reported what he'd found to the hunters, and that was that.
His involvement with the mysterious bags should've ended there, however, several nights later, Mozgus returned to the garage after hours to find his father butchered in some form of ritual, surrounded by the figures of his workers, as well as two of Mozgus's five sisters- the eldest, twins, Josephine and Caroline. They had been priming their father to use as a sacrifice for an ancient deity- an honest man who had been broken down into something haggard and vulgar- the twins had long since been interested in magic and summoning, having been researching Irish lore as a hobby since their youth.
The twins succeeded, and from his hiding place, Mozgus watched the bloody body of his father reanimate and draw the ritual knife used to slay him- who in turn began to wreck havoc on the unsuspecting summoners- just as Moz was discovered, the hunters rescued him from the demon, lighting it aflame, repelling the monster and seemingly defeating it- they explained what he'd seen, but it didn't help to heal the trauma Moz had experienced.
The clean up of the situation was messy. The twins, Caroline and Josephine, hadn't tried too hard to hide what exactly they were plotting, it didn't take much more than a quick breeze through their journals and documents, and searching their room for the ritual ingredients to place a motive. When it all boiled down, the officials claimed that they were just two psychotics who convinced a group of workers to help them ritualistically slay their father. The destruction of the father's body by the Hunters made it difficult to gather much evidence, in the end they'd burned him, but even then it was clear that something was amiss. As far as the investigation could tell, the father somehow escaped his captors and attacked them, at that point things grew complicated, as it seemed utterly unnatural for a man to be able to kill two of his children, as well as three of his workers armed with a knife, have his throat cut in the fight, and then somehow was set aflame. Mozgus was held as a suspect for a time, though he wouldn't speak a word to anyone for another year at the least. However, in the weeks that followed, the investigators decided that perhaps burning the father had been part of the ritual, and that one of the workers, or perhaps even his daughter, set him alight before they bled out- the evidence pointed to it being plausible, as several of the workers had lighters on their person, and there was plenty of gasoline present in the warehouse.
The case was shut and Mozgus left to his own devices- the family was devastated, as far they knew, their sisters tried to kill their father, their father in turn killed their sisters, and then their father burned to death while their youngest brother watched. No one knew who to be angry with, or suspicious of, but if any ill will was felt towards Moz, it was kept tightly under wrap. Emily, the mother, fell into a deep depression out of which she would not come for another year and a half, each of the sisters mourned and lost a bit of their minds, but Mozgus was not present for their suffering.
Mozgus became a shell, after watching his sisters and his father's most trusted employees betray his honest father, with witchcraft of all things, his mind had taken a serious rattling. A million unanswered questions still hung around the incident, "why?" always remained a high point- as of yet, it remains unanswered, some things in life are left askew, but the questions haunted Mozgus more than anything. The company was headed by the remaining honest workers and family, it would take two years for Mozgus to recover mentally, and start down a path of hunting.
For two years, Mozgus's days in the hospital were spent researching legends and monsters, and devising new ways to kill them. He gave himself over to aspiring to be a hunter to pull himself from his depression, hoping that by pushing all his focus into it he would begin to heal. He put his skills with mechanics to work and devised new means of defeating monsters- home weapons, like coffee can grenades, and special ammunition. And so, besides devising new ways to hunt, Mozgus spent his time following leads on hunters, trying to get answers, eventually he contacted the hunters who saved him from his sister's creation, and after some convincing, they started Clyde down the path of hunting.
One day, several months after he released himself from the hospital, he simply reappeared in his family's lives out of the blue- his presence came as quite a shock, but was followed by cautious rejoice. It was clear that Mozgus had changed, two of his remaining sisters, Rosaline and Hariett, had spearheaded control of the family company, and they were the ones Mozgus convinced to help fund his "side projects"- he claimed that the extra funds were for opening various small time shops around the country, and so long as he falsified a few documents, did some actual repair work on the side, and wrote often enough, the sisters were none the wiser- though perhaps their ignorance was out of an attempt to appease their strange, damaged younger brother. His tri-monthly letter and status update to the sisters remain his only true connection to his family, as of now, Mozgus hasn't contacted his mother or sisters since his reappearance.
Mozgus used his assets in the field of mechanics, as well as funds from his father's car-repair organization to better arm hunters, and found that a second thing he excelled at besides machines was slaying monsters, and he did so with pride. Now he hunts along side the others, with a sharp intellect, killer instinct, and a quickly growing arsenal.
A tile bathroom wall of a public rest stop was a hell of a bad place to die. Drab tiles that had a thin film of grey filth, and the taboo nastiness of a bathroom floor, cold concrete with a slight sheen that always hinted a reminder: This is a men's room- it might look clean, but don't trust it. Cramped, dirty little space, neat rows of four stalls, and a small half wall that separated the stalls from the urinals. Everything stained, messages carved into the plastic walls of toilet cells, and the echoing of metal tinkering, and heavy breathing. For a man who appreciates cleanliness- Mozgus, for instance- this was the worst tomb imaginable. For a man with a bleeding shoulder and a cut side- Mozgus, for instance- this wasn't a good place to make a last stand. Sitting back against the dirty wall with a jammed pistol and a dead arm, and cuts and bruises, and every sound echoing a whole orchestra in the most echo-prone room of a building. And even as he took apart the jammed piece and began putting it back together, Moz found himself wondering: Why do we insist on making bathrooms echo?
Outside, nothing was alive, everything was dead- but not silent. Not still. Something was angry, moving, and hungry. And it wasn't going to take long for it to finish checking the Gas station and move on to the bathroom. If it had stopped moving and shoving over isles of food for a moment, it might've even heard the click klak clicking of the pistol being put back together in the echoing bathroom. Luckily for Mozgus, it had no such luck.
Empty the barrel, slide spring A into stock B. It closed with a click as it locked into place. Scuttling running feet and scampering legs. Slide the revolver coil into place, clamping down the action lever, it fit like a charm. A snarl sounded from outside- his hiding place discovered. Slide in the chamber, it locks steady, pick up the bullets- holy oak rounds with rock salt lining- and load the magazine with a snap. The door bulged under a heavy tackle, and finally splintered as the creature rushed in, stopping cold in it's tracks. Cock the piece, take aim.
From his place at the end of the hallway, it was a straight shot to the beast in the door way.
"Mozgus Clyde you goddamn thing."
The trigger pulled, more than once, it pulled eight times, and it spat just as many rounds- seven of them hit, the eighth missed. Seven pieces fit into seven slots perfectly. A public rest stop's bathroom was a hell of a bad place to die- this didn't occur to the monster as it went down.


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EMBL International Centre for Advanced Training (EICAT)
EICAT, the EMBL International Centre for Advanced Training, coordinates integrated training activities for scientists at different levels. EICAT leads delivery on one of EMBL core missions: the provision of advanced training.
The EICAT Management Team is led by Head of EICAT Anne Ephrussi, together with Academic Coordinator Helke Hillebrand and Scientific Coordinator Jürgen Deka.
EICAT Organigramme


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Definitions for faith healing
This page provides all possible meanings and translations of the word faith healing
Random House Webster's College Dictionary
faith′ heal`ing(n.)
the use of religious faith or prayer to bring about healing.
Category: Holistic Medicine and Spiritualism
healing believed to have been brought about by this.
Category: Holistic Medicine and Spiritualism
Origin of faith healing:
faith′ heal`er(n.)
Princeton's WordNet
faith healing, faith cure(noun)
care provided through prayer and faith in God
Faith healing
Faith healing is healing through spiritual means. Believers assert that the healing of a person can be brought about by religious faith through prayer and/or rituals that, according to adherents, stimulate a divine presence and power toward correcting disease and disability. Belief in divine intervention in illness or healing is related to religious belief. In common usage, faith healing refers to notably overt and ritualistic practices of communal prayer and gestures that are claimed to solicit divine intervention in initiating spiritual and literal healing. Claims that prayer, divine intervention, or the ministrations of an individual healer can cure illness have been popular throughout history. Miraculous recoveries have been attributed to many techniques commonly lumped together as "faith healing". It can involve prayer, a visit to a religious shrine, or simply a strong belief in a supreme being. The term is best known in connection with Christianity. Some people interpret the Bible, especially the New Testament, as teaching belief in, and practice of, faith healing. There have been claims that faith can cure blindness, deafness, cancer, AIDS, developmental disorders, anemia, arthritis, corns, defective speech, multiple sclerosis, skin rashes, total body paralysis, and various injuries.
U.S. National Library of Medicine
Faith Healing
The use of faith and spirit to cure disease.
Find a translation for the faith healing definition in other languages:
Select another language:
Discuss these faith healing definitions with the community:
Use the citation below to add this definition to your bibliography:
"faith healing." Definitions.net. STANDS4 LLC, 2014. Web. 21 Dec. 2014. <http://www.definitions.net/definition/faith healing>.


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Crash spills deicing chemical into Clarks Fork
Authorities say 5,000 gallons of a chemical used to deice roads spilled into the Clarks Fork River following a semitrailer crash near the Montana-Wyoming border.
The Montana Department of Environmental Quality said dozens of fish were killed Monday after two tankers filled with magnesium chloride went into the river and one broke open.
Initial reports from authorities incorrectly named another chemical, potassium chloride.
Bob Gibson with Montana Fish, Wildlife and Parks says magnesium chloride is designed to dilute quickly, which could lessen the environmental damage.
Authorities said public water users downstream of the crash site were notified of the spill. Crews patrolled the banks of the river looking for additional damages.
The unidentified driver of the semitrailer, operated by Lynch Trucking of Riverton, Wyo., was cited for careless driving.
Copyright 2013 by The Associated Press. All rights reserved. This material may not be published, broadcast, rewritten or redistributed.


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cateringengros.dk - Catering Engros Visit site
Title: Om Catering Engros
Description: Catering Engros er Danmarks største catering virksomehed. Vi leverer produkter ud til både restauranter og detail.
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"The company's key flavor programs focus on the discovery and development of savory, sweet and salt flavor ingredients that are intended to allow for the reduction of MSG, sugar and salt in food and beverage products," the Senomyx web site says. "Using isolated human taste receptors, we created proprietary taste receptor-based assay systems that provide a biochemical or electronic readout when a flavor ingredient interacts with the receptor."
Vinnedge says a boycott is important because the collaborating companies provide Senomyx with research and development funding plus royalties on sales of products using their flavor ingredients.
"What they don't tell the public is that they are using HEK 293 – human embryonic kidney cells taken from an electively aborted baby to produce those receptors," she said. "They could have easily chosen animal, insect, or other morally obtained human cells expressing the G protein for taste receptors."
Vinnedge says she has contacted the food companies working with Senomyx, but said it took three letters before one company, Nestlé, finally admitted its relationship with Senomyx and company officials claimed the line of cells from abortions was "well established in scientific research".
Both PepsiCo and Campbell Soup also responded.
PepsiCo wrote: "We hope you are reassured to learn that our collaboration with Senomyx is strictly limited to creating lower-calorie, great-tasting beverages for consumers. This will help us achieve our commitment to reduce added sugar per serving by 25% in key brands in key markets over the next decade and ultimately help people live healthier lives."
Campbell Soup officials told the pro-life group: "Every effort is made to use the finest ingredients and develop the greatest selection of products, all at a great value. With this in mind, it must be said that the trust we have cultivated and developed over the years with our consumers is not worth compromising to cut costs or increase profit margins."
While Campbell Soup didn't state they would change their methods, their response, gave Vinnedge hope.
"If enough people voice their outrage and intent to boycott these consumer products, it may convince Senomyx to change their methods," she said. "Otherwise, we will be buying Coca-Cola, Lipton soups and Hershey products."
UPDATE: Within hours of its press statement to LifeNews.com, the pro-life group received notice from Campbell Soup that the company has severed its ties with Senomyx. Juli Mandel Sloves, Senior Manager of Nutrition & Wellness Communications at Campbell Soup Company, told Vinnedge, "We are no longer in partnership with Senomyx. This fact was discussed during the Senomyx conference call with its investors earlier this month."
Continue Reading.
Tuesday, March 29, 2011
Company Uses Fetal Cells From Aborted Babies to Test Artificial Flavors
This is sick!
3 comments:
- Milano Running Mom said...
this is so horrible that's it's beyond words!
- The Ranter said...
Linked, with email/phone information and facebook pages for these companies.
- drartho said...
I believe ALL artificial food additives should be avoided whenever possible. They are poisonous. Especially these that uses tissues from aborted babies.
A lot of people do not realize that aborted tissue lines are also used to develop and propogate vaccines! Yet they are "mandated" by Catholic schools.
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TARC is committed to eliminating the lack of transportation
as a barrier to employment for all residents in its service area.
TARC's Job Hunter Bus provides pre-planned transportation to groups of twenty or more potential employees to job fairs throughout the metro area.
The Job Hunter Bus is scheduled through organizations such as the KY Department of Employment Services, Career Resources, and the Center for Accessible Living, just to name a few. The bus picks up job-seekers at designated locations and transports them to employment sites. The bus will also return job-seekers back to the location where they were picked up.
Thanks to a Federal Access to Jobs Grant, there is no cost to employers or job-seekers to use the Job Hunter Bus.
Just call (502) 561-5112.
Last bus to leave Job Fair at 2:15 p.m. and return passengers to above stops.


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Dark side of Sochi: Loss of family homesteads
|Nina Toromonyan sits on the ruins of her family home in Sochi. Russia passed Law No. 301, allowing the government to requisition and demolish homes and buildings in the way of the Winter Olympic Games. (Sergei L. Loiko/Los Angeles Times/MCT)
SOCHI, Russia — Half a mile away, thousands of people waved flags, held balloons and cheered Thursday as the Olympic torch passed by. Nina Toromonyan stood in the gray rubble that remains of her home and cried.
She recalled her elation in 2007 when her city was selected to host this year's Olympic Winter Games. She imagined that wonderful things were coming. She didn't think that riot police would throw 13 family members out of their three-story home to make way for a new highway two miles away. The compensation they received wasn't enough to re-establish themselves, she said.
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Welcome to the Community School of Music and the Arts! We offer private and class instruction in a wide variety of exciting instruments, for beginners to advanced students.
Founded in 1956 by Peter LaManna and Werner von Trapp of the Trapp Family Singers and "Sound of Music" fame, the Community School of Music and the Arts is located on the 5th floor of the GoggleWorks Center for the Arts at 201 Washington Street, Reading.
Enrollment for new students can be made at any time by phoning 610-374-7167, or by visiting our business office located in Room 563.


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Possible lightning strike grounds all flights at BWI
All flights at Baltimore-Washington International Thurgood Marshall Airport have been suspended after a potential lightning strike hits an air traffic control tower.
CBS' Gina Garcia has the latest.
"In that strike, apparently, two people who worked in the tower received a severe shock," says Garcia.
And it's not a quick fix.
"The power is out and they have given us a minimum of at least six hours to get someone here to take a look at it and deal with the problem," says Garcia.
What's the reaction among travelers there?
"Severe frustration, a couple of times people have come on and said, you know, 'If you would like to with this delay go home, try to reschedule,' and at one point, there was a severe chuckle, because they said 'Good luck.'
(CBS Radio contributed to this report.)
Copyright © Dec 21, 2014, WDEL/Delmarva Broadcasting Company. All Rights Reserved.
Advanced permission from Delmarva Broadcasting Company required for publication or rebroadcast.


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Celebrating Victories While Striving for Excellence
Commissioner Tommy Adkisson
July 8, 2004
Hardly a day goes by without some effort being made here at the County to run efficiently and effectively. This means to me that we look for ways to save money while not being taken in by false economies. This having been said, there are always unlimited projects drawing upon limited resources. When we have enough money to go around for everything, we'll know that we have arrived in heaven. In the meantime, we have plenty of room for humility but against a background of solid performance.
Let's talk about striving for excellence. A fundamental principal of any well-run government is that the public and the media must be an integral part of the examination of government. Government is simply too large and extensive to leave to a few. So it is that the Express-News investigated the use of cell phones.
Bexar County has 1200 cell phones, many of which are distributed to election judges in many if not most of the 400 voting sites. This added to certain of the workforce including Commissioner's Court is where the phones are used. The total of money spent in 2003 is $349,254.00.
Reform of this whole area of cell phone usage is definitely in order! When a simple thing like turning off a phone that has been turned back into the County is not done, there is a need for something stronger in both policy and management. This kind of thing would be unthinkable in our private lives, but because of the size of government, it happens.
This having been said, I must quote Tom Peters the management expert and author of "In Search of Excellence". He says that "The larger the organization, the dumber it gets." Bexar County is a very large organization and quite susceptible to improvement in a whole range of areas. This having been said, I believe that on the whole, Bexar County does a credible job of ferreting out foolishness and I invite your opinions on this subject. See the footnote below to contact my office as to your thoughts.
Let's talk about celebrating the good things. Bexar County has cut or retained the tax rate for the past eight years. All of this would not be possible without the resolve to manage resources well and of course, to the Appraisal District revaluations pursuant to state law, which is a state legislative matter.
Talk about celebrating, this year Bexar County has:
- Adopted the first serious Energy Policy for Bexar County
- Hired the First Energy Manager ever for Bexar County
- Organized the First Energy Bexar County Council Meeting
- Began discussion of protocols for energy, including:
- Usages by office
- Discussing usages by building
- Began discussion of protocols for energy, including:
The Energy Manager is financed primarily with a $25,000.00 grant from the State Energy Conservation Office and a $25,000.00 grant from Rebuild America, a partnership of the federal Department of Energy and the Environmental Protection Agency. Building on this, the Energy Manager has negotiated a utility rate we were entitled to but had not taken advantage of previously and which will save around $30,000.00 annually. The solar thermal energy collector, the largest in Texas, will save $53,000.00 annually well beyond the time it takes to pay off its $395,000.00 price tag. The efforts of this office will be ongoing and unceasing!
Through your efforts in supporting the recent bond proposal, the Adult Probation Office which is a joint venture between the State and the County, will be housed in a County building instead of the County paying around $650,000.00 in rent annually! The fleet management building will also be abandoned in favor of one we will own. We will not be paying $80,000.00 annually into eternity because of the fleet management move. Both of the above alone save much of the $730,000.00 we would otherwise have paid as far as we could have seen into the future.
So, the good, the bad and ugly is ever-present. It would not be life as we know it if just one or the other were our experience. In all, if confidence with humility can describe how I feel about it, that's my take.
Hope you had a great Fourth of July and will have a wonderful rest of the summer!


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Saturday, December 20, 2014
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TerraBlue, 14, is sure that once a family takes the time to get to know her, they'll see how easily she can fit into their family.
"People called me Tara, people never called me Blue until one of my friends called me that, and now people call me Blue and I like it," she said.
Her nickname may be Blue, but that far from describes her personality. TerraBlue is spunky, outgoing, and loves to stay busy.
"I like being in ROTC, I like competing," she said "I'm the win-win-win person, I don't like losing."
But what she wants more than anything is a family behind her during her wins.
"If I'm going to a game and I'm playing or competing for something, they stand up and clap for me," TerraBlue said.
Blue likes to draw and paint. While decorating a plate at The Art Garage, she poured her heart out about why she wants to be adopted.
"What a child needs is nourishment, love, caring support, and stuff like that, and discipline of course," she said. "But I don't get that in my foster home."
She says school and her friends there are like a home away from home, but she only lets very few friends know she's in foster care.
"Some people feel sorry for me and I just don't want people to do that, so I pretty much keep it a secret," she said. "You feel lonely, and you get jealous for the kids when you see them with their parents."
At 14, Blue says she sometimes worries she's too old for a family to want to adopt her, but she still has hope.
"I'd like a mom and dad," she said. "I'd like some brothers and sister, but if you can't do that it's ok."
She's ready to join a family of her own, love them as her own, and get that love in return.
"I've moved on with my life and I'm focusing on my future now, and the present, mainly the future though," TerraBlue said.
She loves school, and is on the A-B honor roll. When she grows up she'd like to join the military.
For more information about TerraBlue, please contact the Adoption Coalition of Texas by calling (512) 301-2825 or by visiting the Adoption Coalition of Texas.
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Using a Simple Optical Rangefinder to Teach Similar Triangles
Paul Cuicchi, Paul Hutchison
March 2003, Volume 96, Issue 3, Page 166
How we taught the concept of similar triangles using an optical method of estimating large distances as a corresponding activity. The derivation of a formula to calculate one source of measurement error is included and is a nice exercise in the use of the properties of similar triangles.
ArticleAnglesConnections / ApplicationsGrades 9-12TeacherLesson PlansSimilarity / Congruence
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Monday, December 22, 2014
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The Sabres look to snap a three-game losing streak Tuesday night. Face off against the Maple Leafs is at 7 p.m. in downtown Buffalo. YNN's Don Heins is at First Niagara Center, where the team's youngest player is getting set to take a big step.
It's already been an eventful day in the Sabres organization. Not only did Thomas Vanek make a healthy return Tuesday morning, but the organization announced that Mikhail Grigorenko will spend the rest of the season here in the NHL.
The 18-year-old will be in the lineup in an important division game against the Leafs. Believe it or not, the NHL lockout may have been a good thing for Grigorenko's development. As Darcy Regier said Tuesday morning, it allowed him more time to develop before the Sabres called him up. "It's interesting, because with the lockout I think this decision, if we had made it back in September, would have been, he would have returned to junior. His game has come a long ways since September. You've got half a season of junior hockey, a world junior experience. And what I've seen from the World Junior Tournament is that when a player performs well in the world junior, it does wonders for that person's confidence," Regier said.
"It's really good to know this, to know that I'm staying with the team, and probably I can focus on the hockey now. I don't think about all those things," said Grigorenko.
The Sabres are trying to snap a three-game losing streak when they face the Maple Leafs. Faceoff is shortly after 7 p.m. Tuesday.
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text:
Hollywood never really figured out what to do with Dudley Moore. The elfin actor (who died in March 2002) came out of the same British sketch-comedy scene that birthed Monty Python, found fame with fellow comic Peter Cook in ''Bedazzled'' (1967), then stumbled into mega-stardom with ''10'' (1979) and ''Arthur'' (1981) before running aground in an increasingly limp series of romantic comedies in the 1980s. Wholly Moses! is an early distress signal, a wholly unfunny comedy that rips off ''Life of Brian'' by casting Moore as Moses' brother-in-law, who thinks HE'S the chosen one. There are cameos by Richard Pryor (good), Jack Gilford (better), and Madeline Kahn (best), but also the five most dreaded words of late-'70s cinema: ''Special Appearance by Dom DeLuise.'' Crazy People is Moore's last leading role before serious decline set in, and it's cute enough: He's a Madison Avenue exec who goes bonkers, only to discover that his mental-hospital pals write brilliant ad copy. ''People'' costars Hannah, who was entering her own Hollywood black hole at the time, but what sticks with you is Moore's barely concealed bitterness over a brilliant career that somehow vanished. ''Wholly'': D-, ''Crazy'': C+
EXTRAS None.


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A very dirty plane ride - VCA
Sex on Plane
Fuck on a plane
Asian orgy near a plane
best lesbians movie - plane action
Last Fuck Before The Plane Lands 2 Pick Him Up
On a Plane
Avy Scott in a Plane
Kylee Strutt - Tits On A Plane
Shay Sights - Tits On A Plane Part 3
Planes make me horny
Change of planes Devon is getting a BBC
brunette flies sky high without a plane
Hot chick with big boobs masturating on a plane
Something to do while waiting for the plane, the plane
Gina Lynn - Sex on a Plane
Pilot puts his plane in her hanger and then drops his load on her face.
bj nice in plane
Looks like the plane broke, let's fuck! (Clip)
Something to do while waiting for the plane, the plane(CLIP)
Brunette w/ Big Tits Takes It In Her Cockpit On A Plane. (Clip)
Big plane for a big cock
Fucking on the wings of a plane
Fucking on the wings of a plane (CLIP)
Snakes On A Plane. The scenes you never saw. (Clip)
Get'n Fucked on the Wing of a Plane.
Fucking hot girls in the plane
Plane babes raise trays for hot handjob with lucky guy
Masturbation on an airplane
Our Friends
Cute Perky Titted Teen Loves Her Boyfriends Big Cock
Candy Alexa Sucks and Fucks some old guy
Classic Audition Series 7 - Netvideogirls


text: Hi, I just started out with OpenSceneGraph and I was asked to study how to build terrains from heightmaps using osgTerrain. Searching around OSG resources, I came upon Virtual Planet Builder and decided to give it a try. So, using SVN, I obtained OSG 2.9.5 and the VPB version which is compatible with it. Also, I installed FWTools 2.4.6 to obtain GDAL (libsquish was not included in it, but I found in the forums that is was not really necessary, so I ignored...). Both OSG and VPB built just fine with Visual Studio 8.0. Following the osgdem guide whose link to it is pasted below, when I tried to execute the osgdem application (or the other VPB apps), the following message was shown: "The procedure entry point H5Dopen could not be located in the dynamic link library hdf5dll.dll." and the program closed. I looked for references to H5D within the solution code, but couldn't find anything, and the mentioned dll exists in the bin folder of FWTools. I also quickly searched around the mailing list files, but no success as well... So, I'm kind of lost. Can someone help me, please? Thanks in advance. Best regards, Fabricio Silva Link to the guide: http://openscenegraph.sourceforge.net/documentation/OpenSceneGraph/doc/osgdem.html


text:
Blogging seems very simple and easy, but it is not that easy as you say when done in real life. To become a successful blogger you need to work few tips that help in generating high income revenues from your blog, this will not happen overnight. One of the important factors that contributes to blog success is your personal growth, your ability to manage finances that are essential on time and the tips you follow to have financial freedom also do matter to become a successful blogger. The following are a few tips that aid for financial freedom especially for blogger.
Visualise your future financial state:
Before you start a blog to earn money, it is very important to understand and visualize your financial position, that means you should be able to anticipate how your finances get affected by implementing certain changes to your blog or updating new technique.
Set goals and targets:
The goals you set can include getting huge website traffic to your blog, to get more earning as an affiliate and so on. Setting goals that you are quite confident enough to achieve can make your job much easier and simpler. Work according to your targets and goals. Managing personal finances is also very important; the following are some tips that help you set financial goals.
- Create a list of goals that you want to achieve
- Visualise how you want to see yourself after one year
- Based on your goal, set short-term targets to achieve
- You can even create a financial plan that helps you acquire your goals
- If you have a passion for writing it would even be great to find some blogging jobs for additional income.
Create a budget plan:
Develop a budget plan that deals both personal and business finances. Make sure you locate necessary funds in your budget to cover your debts if any. As a blogger, you may require to fund initial investments or some techniques to get good website traffic. So, determine how much amount you need and make sure to cover within your budget. If possible you can even cut down some expenses and can utilise that amount for your blog development. The following are a few tips to create a budget plan.
- Extract all your expenses and identify which of these expenses can be trimmed to save some money
- Manage your online investments with your current debts
- Don't neglect monthly bills to be paid
- Commit yourself to be smart to achieve financial independence
Protect your personal finances:
Unless you are able to secure your personal finances you cannot anticipate growth in your online business as the increase stress levels will not allow you to focus on your job and becomes very difficult to get peace of mind. For example, taking Payment Protection Policy (PPI) along with your personal finances help you compensate their monthly payments in certain situations by using PPI claims.
Identify best blogging tips:
Know what tips can help you make more money from your blog. Do not forget at any point of time that readers are your first priority and thus hold on from turning them off! If you are not sure of any technique, you can even take advice help in making a successful blog. Optimize your blog to social media and search engines to get best results.
About the Author:
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text:
Ceglia v. Zuckerberg et al
Filing 537
REPLY to Response to Motion re 525 MOTION for Extension of Time to File Response/Reply in Support of Defendants' Motion to Dismiss (Doc. No. 318) filed by Facebook, Inc., Mark Elliot Zuckerberg. (Snyder, Orin)
UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK -----------------------------------PAUL D. CEGLIA, Plaintiff, v. MARK ELLIOT ZUCKERBERG and FACEBOOK, INC., Defendants. ------------------------------------ x : : : : : : : : : : x Civil Action No. 1:10-cv-00569RJA DEFENDANTS' REPLY IN SUPPORT OF MOTION TO EXTEND THE TIME FOR FILING A REPLY MEMORANDUM Ceglia's response to Defendants' motion for an extension is baseless and untimely. The arguments in his Opposition, Doc. No. 534 ("Opp."), long on bluster and short on substance, should be rejected. Ceglia does nothing to refute the multiple reasons Defendants provided for why a short extension of time here would be both fair and appropriate, not the least of which is that there remain significant live discovery disputes over missing information that bears directly on the motion to dismiss. See Doc. No. 525 ("Mot.") at 6-11. Nor does Ceglia address the fact that Defendants' proposed deadline would still fall virtually a full month before the close of briefing contemplated by the Court's April 4, 2012 Order (as amended by the August 6, 2012 Text Order). See Doc. Nos. 348, 471. As described in Defendants' opening brief, ample good cause exists for the requested extension because of, inter alia, the pendency of outstanding discovery obligations that Ceglia has shirked, the fact that one of his experts cannot be deposed until September 24, and the sheer volume of material that must be analyzed and organized for presentation to the Court. Astoundingly, despite his refrain that the Court should demand "adherence" to its schedule—repeated no less than three times in his opposition brief, see Opp. at 1, 2, 9—Ceglia flouted the Court's directive and filed his response late. The Court ordered a response from Ceglia by 4:00 p.m. on September 12, 2012. Doc. No. 528. But Ceglia, offering neither apology nor explanation, filed his opposition brief at 10:03 p.m. on September 12: more than six hours past the deadline and late the night before Defendants' reply was due. Defendants respectfully submit that Ceglia's failure to respond in a timely manner should be treated as a concession of the arguments raised—and the relief sought—in their motion for an extension. See, e.g., Moore v. Conway, No. 08-CV-6390, 2009 WL 3764129, at *1-2 (W.D.N.Y. Nov. 10, 2009) (granting motion for extension of time to file reply where non-movant failed to oppose motion); Risler v. Sol Spitz Co., Inc., No. 04-CV-1323, 2006 WL 3050885 (E.D.N.Y. Oct. 23, 2006) (affirming default judgment where opposing party failed to comply with 4:00 p.m. expedited deadline and noting that "law office failure in the face of clearly established . . . deadlines, as is the case here, rarely constitutes excusable neglect"); see also Barclay v. Poland, No. 03-CV-6585, 2011 WL 4747337, at *1 (W.D.N.Y. Sept. 16, 2011) (granting leave to amend complaint, in part, because defendant "failed to oppose the motion to amend"); Witorsch v. Notaris, No. 95 Civ. 9163, 1997 WL 529016, at *8 (S.D.N.Y. Aug. 25, 1997) (plaintiff's failure to oppose motion to dismiss within Court-ordered deadline indicated that he "implicitly consented to the relief sought" therein). As Ceglia has no reasonable basis for opposing this motion, Defendants respectfully request that this Court extend the deadline and permit them to file a Reply on the later of October 18, 2012, or two weeks after Ceglia's full compliance with his discovery obligations. 2 1. Defendants' Outstanding Eighth and Ninth Motions to Compel. Defendants' eighth and ninth motions to compel concern missing information that is highly relevant to further demonstrating that the Work for Hire document is a forgery, which—as Ceglia admits—is the crux of what this "expedited discovery . . . was intended to specifically address," Opp. at 10. As an initial matter, this Court has repeatedly determined that there has been a general subject-matter waiver on the subject of the Kasowitz firm's withdrawal. See Doc. Nos. 361 at 4; 480 at 5. It is, therefore, immaterial whether the three (or perhaps more) communications Defendants seek in the eighth motion to compel are attached to, or contained "within," Item 379, Opp. at 4-5. The fact that these communications exist at all—which is indisputably revealed by the April 13 Kasowitz Letter—means that they must be produced to Defendants. Doc. No. 512 at 7-11. They fall squarely within the scope of this Court's discovery orders, id. at 7-8, and Ceglia is—and has been for many months—obligated to turn them over.1 See Mot. at 7-9. Ceglia's roundabout effort to avoid the implication of the Court's prior finding of subject-matter waiver—by asserting that Defendants do not "know" the documents' contents, Opp. at 5—should be dismissed outright. Of course, the Court can consider the three withheld documents personally, as we invited the Court to request to inspect them in camera while considering Defendants' eighth motion to compel. See Doc. No. 512 at 2. Moreover, based just on the disclosed April 13 Kasowitz Letter, Defendants understand enough about the timeframe and general tenor of these communications to know that they directly relate to the basis for the Kasowitz firm's withdrawal from this case and the authenticity of the Work for Hire Document. See Doc. No. 512 at 7-9. Specifically, the communications consist of: 1 REDACTED Ceglia's complaint that Defendants have not refuted, via expert evidence, his charge that the description of Item 379 is false, see Opp. at 4-5, completely sidesteps this critical point. 3 REDACTED Indeed, even the little that Defendants know about those communications belies Ceglia's assertion that the missing documents "will not impact Defendants' ability to challenge the authenticity" of the Work for Hire document, Opp. at 5. The REDACTED email is highly relevant because it is from a REDACTED (hardly "non-expert," Opp. at 5) regarding the genuine contract; and the other communications are from REDACTED Doc. No. 512 at 7-9.2 As for the materials sought in Defendants' ninth motion to compel, it is beyond dispute that "all copies of the purported contract in hard-copy form, created on or before June 30, 2010," (a) should have been produced pursuant to Court order months ago, see Doc. No. 83 at 1, and (b) are fundamental to resolving the genuineness of the Work for Hire document attached to the Complaint. See Mot. at 7-8. Ceglia's accusation that Defendants acted in "bad faith" by requesting such materials, Opp. at 6, is inexplicable. The first time Defendants learned about four hard-copies of the Work for Hire document that had never been produced or described was on August 21, 2012—when Ceglia's attorney Paul Argentieri swore to their existence. See Mot. at 7-8; Doc. No. 522 at 2-3. Defendants promptly demanded those four hard-copies. Doc. No. 523-1. The fact that Ceglia responded "by email on September 6, 2012 that no such copies" 2 Therefore, it is of no moment that the three documents do "not contain any expert reports or discussion about expert's opinions," Opp. at 5. They stand to reveal facts about the authenticity of the Work for Hire Document that are critical to Defendants' contentions. 4 existed, Opp. at 6, was—of course—insufficient to assuage Defendants' concerns, given the bald contradiction with his attorney's sworn declaration days earlier. See Doc. No. 484. Hence, a request for judicial intervention became imperative. If Ceglia has now put in declarations admitting that he and his attorney destroyed key documents during the pendency of the lawsuit (or just before it was filed)—as is apparently the case, see Opp. at 6—that may constitute a full response to Defendants' motion to compel. However, the declarations now submitted by Ceglia and Argentieri contain numerous false statements of fact and are inconsistent with Argentieri's prior sworn August 21, 2012 Declaration. And in any event, it took Defendants' filing to wring those admissions from Ceglia, which means that the ninth motion to compel certainly was not submitted "for the sole purpose of attempting to justify a delay in replying to the motion to dismiss," Opp. at 6. It bears mentioning that the Court set briefing schedules for Defendants' eighth and ninth motions to compel that, respectively, extend up to and beyond the currently-scheduled deadline for filing a Reply brief in support of the Motion to Dismiss. See Doc Nos. 532, 533. The fact that these important discovery disputes—caused by Ceglia's own obstructionism, rather than "manufactured," see Opp. at 6—remain outstanding for the most part, and will not be resolved until after the current Reply due date, is reason alone to warrant a short extension here.3 2. The Remaining Deposition of Plaintiff's Expert Erich Speckin. Ceglia's insistence that Mr. Speckin "is a consulting expert" "not covered by this [C]ourt's order" because he "has not prepared or filed a report in this case," Opp. at 7, is utterly disingenuous. Ceglia points to nothing in the transcript of the April 4 status conference or the 3 Ceglia also fails to respond to Defendants' argument that the deposition of his expert Larry Stewart remains incomplete because of serious deficiencies in Mr. Stewart's document productions that have only recently come to light. See Mot. at 8 n.5. 5 April 4 Order indicating that the parties were permitted only "to depose experts who had submitted reports in the case," id. Thus, Defendants subpoenaed and, with Ceglia's full knowledge and participation, took the depositions of Hany Farid, John Paul Osborn, and Valery Aginsky: all experts who did not submit reports, but upon whom Ceglia has relied, and who have performed forensic testing in this case. See Supplemental Declaration of Alexander H. Southwell ("Southwell Supp. Dec.") ¶¶ 2-5. Ceglia did not move to quash any of their subpoenas as being outside the scope of discovery. Moreover, Ceglia's assertion that "Defendants did not even identify Mr. Speckin as someone they wished to depose until well into the deposition period," Opp. at 7, is flatly wrong. Defendants noticed the deposition of Mr. Speckin on July 10, 2012, the same day they noticed the depositions of Dr. Farid, Mr. Osborn, Dr. Aginsky—more than one month before the end of the two-month deposition period. See Southwell Supp. Decl. ¶ 3. Ceglia conveniently omits to mention that the only reason Mr. Speckin must be deposed outside the discovery period is because Ceglia's counsel refused to accept service of the notice for Mr. Speckin's deposition. See Mot. at 9 & n.6. It is galling to suggest that Defendants' attempt to follow through with their duly-submitted notice is a "last minute desire to freelance a deposition," Opp. at 7, when Ceglia himself precipitated the delay in Mr. Speckin's deposition until late-September. See Mot. at 9. Indeed, Ceglia's pronouncement that Mr. Speckin "has never conducted even one scientific test on the contract," Opp. at 7, means that either his counsel Dean Boland is lying—or his expert Larry Stewart is. That statement is contradicted by Mr. Stewart's sworn deposition testimony, where he stated under oath that Mr. Speckin "t[ook] samples of ink" from the Work for Hire document at the Court-ordered Hard-Copy Inspection and "test[ed] the ink" he extracted. See Southwell Decl., Ex. A at 54:4–55:12; see also Mot. at 9. Thus, Ceglia's 6 suggestions to the contrary notwithstanding, Mr. Speckin's deposition has the potential to provide information that is both vital to Defendants' arguments—particularly the dispute regarding Mr. Stewart's purported sampling of the hard-copy documents—and consistent with the goals of this Court's expedited discovery order, which is to fully air expert opinions about the authenticity of the Work for Hire document. Mot. at 9. 3. The Volume of Material Generated During Discovery. Ceglia does not dispute that a large volume of material was generated during the expert discovery this summer. Instead, he contends that Defendants' request for a reasonable timeframe within which to synthesize and organize for presentation this sizeable quantity of data is "insincere[]" because they always knew they would have only "30 days to reply to Plaintiff's" opposition. Opp. at 7-8. Not so. As set forth in the Motion, the April 4 Scheduling Order was entered after a comprehensive status conference where both sides were given an opportunity to be heard, and it reflected the settled expectations of the parties. See Mot. at 2-3. Based on explicit representations made to the Court—in particular, Ceglia's counsel's repeated representation that he required 60 days after completion of expert depositions to compose an opposition brief—the April 4 Order established calibrated deadlines that gave Ceglia two months after the close of the expert deposition period to file his responsive brief. Id.; see also Doc No. 350 at 200:23-201:1 ("[P]laintiff shall file his opposition to defendants' motion to dismiss" "two months after the close of expert depositions."). Defendants had no reason to expect that Ceglia would jump the gun seven weeks early—in the face of his 60-day representation to the Court— and foist upon them a five-week turnaround for digesting all of the complicated information and testimony produced during discovery. If anyone can be accused of being "insincere[]" about timeframes, Opp. at 8, and of "disrupt[ing] this [C]ourt's carefully crafted discovery schedule," 7 id. at 2, it is Ceglia, who has forced the conclusion of all briefing almost two months before the contemplated deadline. See Mot. at 2-3, 9-11. As Defendants' Motion made clear, it is no answer that Ceglia "and his two sole practitioner lawyers had sufficient time to assimilate the facts," Opp. 8. See Mot. at 10. Far from it. Ceglia's opposition brief is riddled with the sorts of distortions and half-truths that require only a superficial dabbling in the record; it is a far cry from the cogent and considered presentation to the Court that Defendants think this matter deserves (and that takes time to put together). See id. Furthermore, Ceglia tellingly fails to respond to the fact that he canceled 11 depositions at the last minute, many with less than 48 hours' notice. See id. at 10-11. Defendants' wasted time preparing for those depositions cut significantly into the supposed "fifteen weeks" they had to review discovery, Opp. at 8.4 Finally, Ceglia's refrain that Defendants' need for more information and time somehow proves they will be unable to meet the "clear and convincing" standard applicable to the motion to dismiss, see Opp. at 2, 7, 10, is nonsensical and should be rejected outright. It also is irrelevant to the motion for an extension. Whatever legal standard is ultimately used, Defendants deserve to have a complete record from the expedited discovery period—containing all of the information to which they are entitled under the Court's (repeated) discovery orders—before making a final submission on their motion to dismiss. Likewise, given that Defendants' 4 Ceglia's argument that Defendants opposed his extension motion and should be subjected to reciprocal scheduling rigidity, Opp. at 9—apart from laying bare the tit-for-tat gamesmanship he is engaged in—rings hollow. As explained in the opening brief, Ceglia's motion was made at the very end of a 60-day period he, himself, requested, whereas here Defendants moved for more time ten days before the scheduled deadline and more than seven weeks before the contemplated deadline for the close of all briefing. See Mot. at 5 n.3. 8 arguments, if successful, would dispose of this lawsuit altogether, the Court deserves careful and cogent analysis, in briefing, of the substantial record that has been developed. See Mot. at 11.5 4. The Unavailability of Defendants' Lead Counsel. Ceglia never disputes that Orin Snyder is the lead counsel in both this case and a substantial case that is scheduled to begin trial on September 19, 2012. Nor does he dispute that that other trial, expected to last four weeks, will consume substantially all of Mr. Snyder's time at least until the date the Reply is currently due. He claims, however, that Mr. Snyder knew since May 15, 2012 of this impending clash and "had months to make this motion," Opp. at 1011. That is wrong. Based on the representations made by Ceglia's counsel at the April 4 status conference, it was Defendants' settled expectation that their briefing would continue into November 2012. See supra p. 7; Mot. at 2-3, 12. It was Ceglia's premature filing that precipitated the conflict in dates for Mr. Snyder. Defendants had no reason to alert the Court any earlier to what was a non-existent problem until Ceglia filed his opposition seven weeks early.6 5. The Lack of Prejudice to Ceglia. Tellingly, Ceglia provides no explanation of how this brief, discrete extension would prejudice his case in any way. Nor can he. Under the April 4 Order, which was calibrated based on a representation from Ceglia's counsel that 60-day timeframes were necessary for the expert reports and opposition memorandum, respectively, the parties expected briefing on the motion to 5 The assertion that "there cannot possibly be a full record presented at this stage," Opp. at 9, merits little discussion. As Ceglia admits, the expedited discovery was "intended to specifically address [the] narrow point of . . . the authenticity" of the Work for Hire Document. Opp. at 10 (emphasis added). 6 Contrary to Ceglia's intimations, Opp. at 10-11, the attorney teams on this matter are small, as is evinced by Defendant's Request for Attorney Fees (Doc. Nos. 285, 299, 519), and Mr. Snyder's absence would substantially harm Defendants' ability to frame an effective Reply memorandum. 9 dismiss to extend as far as November 4, 2012. See Mot. at 2-3, 12. The deadline proposed here, October 2012, falls before that date. Moreover, the Court should put to rest Ceglia's fanciful notion that Defendants have somehow engineered "an endlessly mobile deadline," Opp. at 12. If that were true, any time period calibrated to a party's compliance with some Court directive would be hopelessly openended. That, of course, is not the case. It is typical for deadlines to be triggered by parties' compliance with court orders, see, e.g., Doc. No. 83. Defendants respectfully submit that the Court knows how to police its own discovery orders and will determine when Ceglia is in compliance therein without "await[ing] Defendants' consent," Opp. at 12.7 CONCLUSION For the reasons set forth herein, and in Defendants' Motion to Extend the Time For Filing A Reply In Support of their Motion to Dismiss (Doc. No. 525), Defendants respectfully request that the deadline for filing their Reply brief be extended to the later of October 18, 2012, or two weeks after Ceglia's full compliance with the outstanding discovery disputes described in their papers. 7 Ceglia's pronouncement that, thus far, he has been adjudged "in compliance" with the expedited discovery order, Opp. at 12, is absurd. Of the seven decided motions to compel, the Court has ruled in favor of Defendants on all seven. 10 Dated: New York, New York September 13, 2012 Respectfully submitted, Thomas H. Dupree, Jr. GIBSON, DUNN & CRUTCHER LLP 1050 Connecticut Avenue, NW Washington, DC 20036 (202) 955-8500 Terrance P. Flynn HARRIS BEACH PLLC 726 Exchange Street Suite 1000 Buffalo, NY 14210 (716) 200-5120 /s/ Orin Snyder Orin Snyder Alexander H. Southwell Matthew J. Benjamin Amanda M. Aycock GIBSON, DUNN & CRUTCHER LLP 200 Park Avenue, 47th Floor New York, NY 10166-0193 (212) 351-4000 Attorneys for Defendants Mark Zuckerberg and Facebook, Inc.


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Andaman Holiday Resort Hotel, Krabi
Review - Andaman Holiday Resort Hotel
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Top Local Tips for Krabi
snorkelling definitely take a long boat to the islands. Beaches are idyllic, snorkelling is memorable
Cheaper Airport Taxis Most people opt for the hotel or airport taxi service. 'Ma', the Thai lady walking the beach, offers cheaper transport to and from the airport plus she can arrange day trips.
Island trips When you visit the many islands of Krabi, for swimming and snorkelling, it is best to hire you own long-tail boat rather than go in a big mororized boat with dozens of fellow travellers. The long-tail boat driver will provide a pineapple and banana lunch and you can decide how long to spend on each island. The trip to Hong Island and some nearby islands was memorable. A great 6 hours on the sea and various beaches and it cost only 1500 baht (around 20 pounds or 40 dollars).
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Other names for Andaman Holiday Resort Hotel
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- andaman holiday hotel
- andaman holiday
- Address: 98 Moo 3 T Nongtalay - Krabi - 81000 - Thailand
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What does QAO mean in Sports?
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- bmw 5 series with connected drive
BMW takes its autonomous 5 Series onto the autobahn
by Damon Lavrinc (RSS feed) on Jan 26th, 2012 at 8:58AM
Last May we went for a high-speed run around Laguna Seca in BMW's Track Trainer, a modified 3 Series that can click of two-minute laps without the driver touching the controls. Now, BMW has packed a 5 Series with the next iteration of the technology and taken it on to the open road. This latest ConnectedDrive experiment uses much of the same tech, but beyond the radar and camera systems on the 3er, it includes new ultrasonic scanners and lasers to re-read the road surface, lines and surrounding vehicles. We say "re-read" because like the system we sampled at Laguna, this version needs to... Read More


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One Metairie Place CondosIn the Heart of Metairie2601,2521,2511 Metairie LawnMetairie, La. 70002
The One Metairie Place Condos are actually three building of 49 units with each building being 3 stories. The condos were converted into Condos in 2004 and not finished unit 2006. There are primarily a lot of one bedrooms with some two bedroom also. There are some rather large one bedrooms. The condo fees are reasonable and cover water, common areas, parking, swimming pools, termite contracts, pest control and insurance. The building is secure by the front gate and gated parking with most units having covered parking.Each of the building has its own pool, mail room, elevators and rear entrance from the parking lot. There are visitor spots in the rear also. All the units have washer and dryer hook-ups. The kitchens, baths, and living areas were all redone in 2004 plus so all should be in nice shape. Granite counter-tops, crown molding, wood and tile floors were the norm in the first two buildings. The third was finished after Katrina and this were not as finished as the first two. The condos are pet friendly.The One Metairie Place Condos have been popular because they are in the heart of Metairie next door to Old Metairie near shopping centers and the major interchanges of what is considered downtown Metairie. The area is very safe and gated parking is a plus. They are behind Sav-A-Center and Perinos on Veterans Highway. The taxes in Jefferson parish are among the lowest in the metro area with the largest amount of services. You are also exempt from the first 75k of value from property taxes.
Secure Entrance from Metairie Lawn to the courtyard.
The salt water pool in 2601 Metairie Lawn courtyard.
One Metairie Place condos Courtyard from the third floor of 2601 Metairie Lawn
The three story units with walkways from the elevators, you can also use the stairs.
The mailroom at One Metairie Place coming in from the parking area
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Eric Bouler
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Eric Bouler Gardner Realtors 4509 Veterans Blvd.Metairie, La USA504-212-0072E-Mail EricLouisiana R.E. License
Eric is working as a Buyers Agent for almost all the properties that I profile, meaning I do not personally have these condos listed. I will work for you! I can give you the pros and cons on the various units and projects currently on the market and let you choose the units that best fit your needs. Let my experience work for you. I work for you !Users are Responsible for Checking the Accuracy, Completeness, Currency, and Status of All Information. When buying think " Buyers Beware"
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George Blow
Portrait shown on page is a duplicate of the oil portrait
that hangs today in the Norfolk, Virginia circuit courtroom.
George Blow Jr. was born May 5, 1813, in Sussex County at Tower Hill, the plantation belonging to his father Colonel George Blow. At the age of seven he was sent to his Grandparents, Richard and Fannie (Wright) Blow in Portsmouth for education (and possibly because of an illness that prevailed in Sussex at the time).
He attended Hampden-Sydney College 1828-292; In 1829 at the age of 16 he entered William and Mary College and was granted a B.A. in 1831. From there he went to the University of Virginia (#27, East Lawn) where he took the law courses. He briefly returned to Portsmouth because of the illness and death of his Grandfather Richard Blow, but returned to the University and graduated in 1835. He was admitted to the bar in the same year.
He practiced law in Norfolk until 1839 when he emigrated to Texas. In 1839 he was serving as Prosecuting Attorney for the Republic of Texas, Fourth Judicial District. He later served as a member of the House of Representatives from Bexar County.
Captured (as District Attorney) with the members of the District Court of San Antonio, Texas, by Mexican General Adrian Woll March 1842.
In 1842 he returned to Virginia, probably because of the death of his mother Eliza Waller, and resumed his law practice, serving also as Commonwealth Attorney for Norfolk Circuit Court from 1856 to 1860.3
In 1846 he married Elizabeth Taylor Allmand who bore him ten children before her death in 1868 at the age of only 44.
During the same period he was a member of the Virginia Militia rising to the rank of Brigadier General. In 1861 he resigned his commission and was appointed Lt. Colonel in the 14th Virginia Regiment of Infantry. Captured with Norfolk in 1862, we believe he was exchanged for a Union Officer and - although forced to give his home to a Union Officer - remained in Norfolk for the duration.
He was a member of the Virginia Secession Convention in 1860, first voting nay but later yea to secession. According to the published lists of visitors in the 1984 edition of the Register of Former Cadets, Judge Blow was a member of the VMI board in 1851-1852, 1857-1860, and 1861-1862.
Following the war he resumed his legal practice until he was elected Judge of the Norfolk Circuit Court in 1870.
A greatly respected jurist, he had not one decision reversed including the important Norfolk Ferry suit. He retired from the bench in 1886 at the age of 73.
Eight years later Judge Blow died at the age of 80, survived by only two siblings.
From letters we learn that Judge Blow was a devoted family man, a husband hopelessly in love with his wife and children. Many tributes were published and the cities of both Norfolk and Portsmouth voted resolutions of recognition. In Norfolk a street was named in his honor. His portrait still hangs today in the Norfolk District Court.
Read George Blow's Full Biosketch
Mexico's Last Try to Regain Texas in 1842 Unsuccessful , San Antonio Express
Information on this page provided by Great Grandson of Judge Blow, John M. Blow