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Don't shut the door on the synthetic biology debate
8 May 2014
SynBio has always skated along what Drew Endy calls the "half-pipe of doom", between a controlled biological utopia and an exploding biological disaster. Its enthusiasts, Endy included, make grand claims for the power of engineered biological machines and parts, bespoke genomes and xenonucleic acid (xDNA) to both create and solve major problems. The reality is likely to be more mundane, but the untold hype and terror have been allowed to shape the debate, writes Dr Jack Stilgoe (UCL Science and Technology Studies) in The Guardian.


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When spoiled 11-year-old Mary Lennox is left an orphan, she is sent to live in Yorkshire, England at the manor house of uncle Archibald Craven. But life on the moors is hardly the cozy existence to which she's accustomed. Her uncle is a reclusive man whose personal life is shrouded in some grim secret. Furthermore, ruthless housekeeper Mrs. Medlock is determined to make Mary's life miserable.
Frustrated and lonely, Mary begins to explore the grounds. Robin, one of the birds of the manor whom she befriends, shows her the hidden key to a secret garden gate. It's a garden that no one has entered since the death of her aunt 10 years ago. What Mary and her friends find there will change them for the rest of their lives.
The Secret Garden
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Balkinization   |
Tuesday, October 03, 2006
Has Congress unconstitutionally suspended the writ of habeas corpus? JB
I promised earlier that I would return to the question whether the Military Commissions Act's (MCA) habeas stripping provisions are unconstitutional. Here is the beginning of an answer to this rather difficult question. Article I, section 9 of the U.S. Constitution states that "The privilege of the writ of habeas corpus shall not be suspended, unless when in cases of rebellion or invasion the public safety may require it." If the MCA's habeas stripping provisions are unconstitutional, it might be because it violates this clause. That would be because we are not currently in invasion or rebellion, or the public safety does not require it. The argument that we are not in rebellion or invasion would be that the invasion occurred on September 11, 2001, and the Suspension Clause is designed for emergencies. The emergency has passed, and we are now embarked on a more or less permanent War on Terror. Whatever function the Suspension Clause serves, it is not designed for cases of permanent or indefinite suspension. In addition to rebellion or invasion, the Suspension Clause also states that the public safety must require suspension. Public safety does not require suspension because the aliens at Guantanamo Bay have been in federal custody for many months, and in some cases for years. They do not offer a present danger to the United States. Allowing people to file habeas petitions in federal court does not endanger the public safety. The public safety test is designed for situations where courts and ordinary legal processes are not available and it is necessary to detain dangerous people immediately until order can be restored. There has been no loss of order in the United States or at Guantanamo Bay that would justify indefinite suspension of the writ. But these arguments don't settle the matter. The government might object that the Suspension Clause does not define "habeas corpus." The scope of the writ has been altered by legislation over the years. The government might argue that it is doing nothing more than eliminating non-mandatory statutory grants that are not part of the constitutionally required core. Generally speaking the scope of constitutional habeas is based on historical practices at the time of the founding, supplemented by appropriate analogical extensions for new situations. Historically, habeas was available for aliens as well as subjects in Great Britain. This was clearly the case within the boundaries of Great Britain; it also was available in British colonies as well. How does this history apply to detainees at Guantanamo Bay? Justice Stevens' opinion in Rasul v. Bush found that the Guantanamo detainees had statutory rights of habeas and left open the constitutional scope of habeas. Justice Kennedy's concurrence insisted that "Guantanamo Bay is in every practical respect a United States territory, and it is one far removed from any hostilities." Equally important, Kennedy also pointed out that testing the legality of executive detention (as opposed to testing decisions of a court or tribunal) was a core function of habeas corpus: Although it is not directly on point, it is worth noting that the Habeas Corpus Act of 1679, styled "An act for the better securing the liberty of the subject, and for prevention of imprisonments beyond the seas," was passed to counter the King's habit of taking people overseas and holding them there in order to prevent the exercise of habeas corpus. Even if one accepts all this, the Administration might still object that the question whether Congress has complied with the suspension clause is non-justiciable: It is a political question and is left to the complete discretion of Congress. Justice Thomas' dissent in Hamdi noted that the Suspension Clause's requirements might not apply to the present situation, and therefore it might be unconstitutional for Congress to suspend the writ; however, he stated that, even so, courts could not review Congress's decision. I think that Justice Thomas overstates the case. The purpose of the Clause is to permit *temporary* suspensions to protect public safety. Even if courts give Congress great deference, which they undoubtedly should, it does not follow that no review of any sort is permissible. The text of Article I, section 9, does not, at least on its face, commit this question exclusively to Congress. Article I, section 9 does not expand Congress's powers, it places limits on them. Nor do the other prohibitions in Article I, section 9 appear to be nonjusticiable. Certainly the courts have regularly passed on whether Congress has passed an ex post facto law. If Congress's decision to suspend the writ were in all aspects unreviewable, Congress could suspend the writ forever, by declaring that the United States was in a permanent state of emergency. More importantly, it could suspend the writ for only a small class of persons who were politically powerless and politically unpopular. The latter case is far more important than the former. The electoral process might be sufficient to police and respond to a general suspension of the writ that embraced all citizens. But the electoral process might be much less of a safeguard where Congress suspends the writ selectively for only a small class of citizens. And where Congress suspends the writ for those who have no political rights and are viewed with great suspicion-- aliens-- there is the least chance that the political process will remedy abuses of the Suspension Clause. I've given some reasons why the MCA violates the Suspension Clause. However, there are still other issues to resolve. The government might object that, under Swain v. Pressley, Congress does not suspend the writ where it provides a remedy that is adequate and effective to test the legality of a person's detention. I don't think that the remedies available under the MCA and the Detainee Treatment Act are either adequate or effective for a significant class of persons or for some important claims that detainees might want to offer. But the issues are quite complex, and I leave a fuller discussion for another day. In addition, even if aliens enjoy the right of habeas corpus, this does not settle whether their detention comports with the Due Process Clause. The process that the government has offered them might be all the process they are due. (This is what Justice Thomas argued in his dissent in Hamdi with respect to United States citizens; I assume he would make the same argument with respect to non-citizens). Again, I think that this claim is far too quick: At least for some alien detainees at Guantanamo Bay the process the government has offered doesn't comport with the minimum requirements of Due Process, but this claim, too, requires a far more detailed treatment than I can offer here. I close with this thought: The MCA is important not only because of how it affects the current Guantanamo Bay detainees, but also how it affects every alien in the future, including people living in the United States. There are many non-citizens living in this country who are our friends, neighbors, and members of our community. They are people who you see every day on the streets, people you regularly do business with, people who may cook your food or care for your children. The Military Commissions Act allows the government to seize these people off the streets and detain them because they are non-citizens, and, by accusing them of being unlawful enemy combatants, throw them into a parallel system where neither habeas corpus nor the Bill of Rights apply. It takes even resident aliens who have lived in the country for years out of the criminal justice system and into the world of military prisons and CIA interrogations. The MCA allows the government to make mistakes-- very grievous mistakes-- in detention and interrogation that will severely harm these people and that it may never have to account for. A system of laws that can do this-- even if its primary victims are not citizens-- is inconsistent with the principles of a democratic republic.
I have wondered if universities in this country might feel obliged to warn prospective foreign students that their safety cannot be guaranteed. At the moment, where non-citizens are concerned, the writ of habeas corpus has been suspended and, because no legal remedies are available to non-citizens in executive detention, even fundamental human rights exist only at the pleasure of the Executive Branch.
Prior to Rasul, the courts had not extended the writ to captured alien enemy combatants.
At its historical core, the writ of habeas corpus has served as a means of reviewing the legality of Executive detention, and it is in that context that its protections have been strongest.14 See, e. g., Swain v. Pressley, 430 U. S. 372, 380, n. 13 (1977); id., at 385-386 (Burger, C. J., concurring) (noting that "the traditional Great Writ was largely a remedy against executive detention"); Brown v. Allen, 344 U. S. 443, 533 (1953) (Jackson, J., concurring in result) ("The historic purpose of the writ has been to relieve detention by executive authorities without judicial trial"). In England prior to 1789, in the Colonies,15 and in this Nation during the formative years of our Government, the writ of habeas corpus was available to nonenemy aliens as well as to citizens. INS v. St. Cyr, 533 U.S. 289, 301-302 (2000). http://supreme.justia.com/us/533/289/ index.html Therefore, it is unlikely that the drafters of the Constitution intended to extend any right to habeas corpus to alien enemy combatants. As to whether denying habeas to alien enemy combatants is " inconsistent with the principles of a democratic republic," I would note that the US has captured hundreds of thousands of alien enemy combatants over the past two centuries and held them in the US and overseas. I am unaware of the courts ever entertaining habeas petitions from these captures prior to Rasul. Likewise, the British creators of the Great Writ did not extend this right to captured alien enemy combatants. Therefore, the MCA is perfectly consistent with Anglo American democratic republics. Perhaps with this history in mind, the Court in Rasul extended the writ to enemy combatants for the first time in history by interpreting 28 U. S. C. §2241, not the Constitution. The Rasul Court never reached the question of whether the Suspension Clause somehow implies the alien enemy combatants have a constitutional habeas corpus right. Instead, the Court interpreted 28 U. S. C. §2241 to mean that Congress had extended this right to the enemy. Taking Justice Scalia's recommendation in dissent to amend the statutes and reverse Rasul, Congress has now categorically made it clear by enacting the MCA that it is not extending habeas rights to alien enemy combatants. It will be interesting to see if the Court again ignores a congressional statute denying it the jurisdiction to hear what inevitably will be more enemy habeas petitions and then attempts to read such a right into the Constitution. Such a court holding would be a radical departure from centuries of past jurisprudence on the matter. More importantly, a judicial vacation of the rules for captures enacted by the two elected branches of government would be a direct and unconstitutional attack on our democracy.
Bart, I think, begs the question. The question is whether an alien seized and placed in a military prison *is* an enemy combatant. If the government can simply declare any alien an enemy under section 948, and thereby deny access to habeas corpus, the language from St. Cyr that he quotes would be meaningless.
Well, but Professor Balkin, why isn't the test "declare in good faith," i.e., if the government declares in good faith that it believes that someone is an enemy combatant, that ends the discussion. Because, despite what some of the more hysterical commentators here and elsewhere say, I can assure you that no one at Guantanamo is there because he is a political opponent of George Bush, or the like.
On the day when the executive ceases to act in good faith, that will be the day for the courts to intervene.
One thing to remember is that even Stevens in Hamdi thought the Suspension Clause Rebellion-or-Invasion issue was nonjusticiable--he joined Scalia's dissent.
JB said...
Bart, I think, begs the question. The question is whether an alien seized and placed in a military prison *is* an enemy combatant. If the government can simply declare any alien an enemy under section 948, and thereby deny access to habeas corpus, the language from St. Cyr that he quotes would be meaningless. The Supreme Court has conceded that the military can detain enemy combatants for the duration of a conflict so long as they hold status hearings to confirm the detainee is indeed an enemy combatant. Therefore, I do not think the Court is going to challenge the military designation of a detainee as an enemy combatant for the purposes of determining whether the detainee is eligible for habeas corpus.
"On the day when the executive ceases to act in good faith, that will be the day for the courts to intervene."
It is unclear why we have a BOR etc. since obviously we can just trust the executive. I'm unclear why this "trust them" principle is limited to this narrow area. It surely is amazing coming from people, not saying this person, who wouldn't trust let's say Clinton (does it only apply to certain presidents?) further than they could throw 'em. As to BP, I think the point is that the post-WWII world is a bit different [the very theme of Rasul/Hamdan, though Stevens' boss back then along with a couple other justices felt we should have defended such people at the time too], especially as to int'l law and treatment of aliens. I also am not really sure of some past incident in our history really comparable to the current sitatuation. Also, JB is right, this "assume guilty" philosophy is a bit too easy. And, all those "hundreds of thousands" tended to be legal combatants. Again, the comparison is rather inexact. The times have changed some even since 1945. Time to comprehend the point.
I'm not going to rely too much on dicta Stevens did not even write but the point is of some note.
Honestly, I doubt he really would support the point that when "the writ is suspended, the Government is entirely free from judicial oversight" if directly forced to address the point. But, that's just conjecture. Anyway, if he did, he would be wrong.
"The prohibition against their making any ex post facto laws was introduced for greater caution, and very probably arose from the knowledge, that the Parliament of Great Britain claimed and exercised a power to pass such laws, under the denomination of bills of attainder, or bills of pains and penalties; the first inflicting capital, and the other less, punishment. These acts were legislative judgments; and an exercise of judicial power. Sometimes they respected the crime, by declaring acts to be treason, which were not treason, when committed, at other times, they violated the rules of evidence (to supply a deficiency of legal proof) by admitting one witness, when the existing law required two; by receiving evidence without oath; or the oath of the wife against the husband; or other testimony, which the courts of justice would not admit; at other times they inflicted punishments, where the party was not, by law, liable to any punishment; and in other cases, they inflicted greater punishment, than the law annexed to the offence. The ground for the exercise of such legislative power was this, that the safety of the kingdom depended on the death, or other punishment, of the offender: as if traitors, when discovered, could be so formidable, or the government so insecure! With very few exceptions, the advocates of such laws were stimulated by ambition, or personal resentment, and vindictive malice. To prevent such, and similar, acts of violence and injustice, I believe, the Federal and State Legislatures, were prohibited from passing any bill of attainder; or any ex post facto law. * * *
"I will state what laws I consider ex post facto laws, within the words and the intent of the prohibition. 1st. Every law that makes an action, done before the passing of the law, and which was innocent when done, criminal; and punishes such action. 2nd. Every law that aggravates a crime, or makes it greater than it was, when committed. 3rd. Every law that changes the punishment, and inflicts a greater punishment, than the law annexed to the crime, when committed. 4th. Every law that alters the legal rules of evidence, and receives less, or different, testimony, than the law required at the time of the commission of the offence, in order to convict the offender. All these, and similar laws, are manifestly unjust and oppressive." Calder v. Bull, 3 U.S. 386 (1798), 389-391.
I am wondering if its correct to equate the MCA's provision stripping jurisdiction from the federal courts with a suspension of the writ. At least formally, the MCA is about closing the forum of the federal courts to habeas petitions by aliens designated as unlawful enemy combatants. Nothing in the MCA would preclude a state court from entertaining a habeas petition from a detainee. Now, I am not sure whether or not a state court of general jurisdiction would be open to such petition. My (relatively uninformed) supposition is that state courts of general jurisdiction would have subject matter jurisdiction but the personal jurisdiction issues would be tricky. If state courts are open to these petitions (at least nominally) might not some claim that the MCA only addresses the proper forum for the petition and not substantive rights?
You raise a number of important issues implicated by the new law. One of them is indeed the justiciability of any exercise of suspension. Not only did Justice Thomas suggest in Hamdi that an act of suspension would be nonjusticiable, Justice Scalia (joined by Justice Stevens) did as well, as some prior comments here have noted. And, in so doing, each relied on Story's Commentaries, which likewise argued that the right to judge whether the exigency supporting a suspension exists (namely whether there is a Rebellion or Invasion) was conclusively left for resolution by Congress. I think that in the legal challenges that are likely to follow to the new law, the Administration may well argue that suspension presents a political question. As you note, the argument is especially significant in its ramifications when made in the context of the ongoing War on Terror – after all, we are told that this war may outlive all of us, so a suspension shielded from judicial review may be far from temporary. I have an article forthcoming in the November issue of the Stanford Law Review that explores this very issue in detail. (The article is called "Is Suspension a Political Question?" and I will be posting it on SSRN shortly once the final editing of the piece is complete.) In the piece, I contend that suspension is not a political question, at least insofar as such an assertion suggests that the courts could not review an exercise of the suspension power to ensure that it follows from constitutional premises, namely the existence of a "Rebellion or Invasion." This follows largely because of the longstanding relationship between the Great Wit and the fundamental right to due process.
The writ that we inherited in this country was tied closely to the Great Charter's guarantee that one may be detained only in accordance with the rule of law. The very essence of the Great Writ is to protect one from being deprived of liberty without due process. Indeed, to hold someone in detention without affording her a judicial forum to test whether the detention is lawful is the very essence of a deprivation of liberty without due process. Thus, at their respective cores, the right to due process and the Great Writ are coextensive. The Supreme Court has recognized as much, treating challenges to curtailments of habeas jurisdiction as inviting inquiry under the Due Process Clause. (See, e.g., Swain.) This relationship demonstrates why the judiciary should play a role in ensuring that any suspension follows from lawful premises. If one subscribes to the view that suspension is a political question, one must also accept that through any act of suspension (whether following from lawful premises or not), Congress effectively can switch "off" the guarantee of due process and shield this fundamental individual right from judicial protection. Such an end is difficult to reconcile with the traditional role of the courts and our constitutional tradition as the sole branch constituted for the very purpose of ensuring that individual rights are not improperly displaced by a political majority merely for the sake of expediency. Ultimately, to assert that suspension is a political question is to say that we all enjoy the most fundamental of due process guarantees at the pleasure of the political branches, and this simply cannot be squared with our constitutional traditions. Professor Amanda Tyler, G.W. Law School
Well, but Professor Balkin, why isn't the test "declare in good faith," i.e., if the government declares in good faith that it believes that someone is an enemy combatant, that ends the discussion.
To quote a famous American, "Trust, but verify." You seriously believe that this Administration has acted "in good faith" in its statutory enforcement obligations? I can assure you that no one at Guantanamo is there because he is a political opponent of George Bush, or the like. In some sense ALL of them are there for that reason.
Professor Balkin, when you say "The question is whether an alien seized and placed in a military prison *is* an enemy combatant", do you mean that all aliens have habeas rights? I can't help but read it that way. All must have the right to challenge the initial determination of status as an enemy combatant.
"The privilege of the writ of habeas corpus shall not be suspended, unless when in cases of rebellion or invasion the public safety may require it."
The Article does not say that habeus corpus may be suspended in cases of rebellion or invasion or when the public safety may require it. It specifies as grounds for suspension only situations which threaten public safety during times of rebellion of invasion.
AT's discussion leading to a view of habeas as misced with due process places the focus on the individual living within our society. To the degree that 'alien' detainees are stateless, they, too, are individuals. Congress has missed identifying these prisoners as persons; clearly, in the heated politics of the moment congress has voted 2:1 to keep the courts from listening, to keep the prisoners from telling the world their testimony was torture elicited. In a way congress has decided to adopt the immoral judicial values of its stateless adversaries; a very incongruous and ill fitting accretion to what had been a noble experiment in human dignity.
While there had been no invasion, there could be none; not in the sense the colonists conceived of disruption of civil peace in the XVIII century by an invader. And, while the detainees mostly are aliens, their rebellion is against the world economic and social order of our time; so, to the measure the US is a leader in globalized civilization, the detainees represent rebels against that matrix. CG's reminder about the ex post facto defect at the root of the MCA is one more reason congress has tried to limit this pseudo martial law construction from undergoing any further scrutiny in the courts.
Ahhh, IC that "Bart" is up to his old tricks: Misciting law for propositions he's making up out of thin air:
Sez he: Prior to Rasul, the courts had not extended the writ to captured alien enemy combatants. [quoting from St. Cyr]: "At its historical core, the writ of habeas corpus has served as a means of reviewing the legality of Executive detention, and it is in that context that its protections have been strongest.14 See, e. g., Swain v. Pressley, 430 U. S. 372, 380, n. 13 (1977); id., at 385-386 (Burger, C. J., concurring) (noting that "the traditional Great Writ was largely a remedy against executive detention"); Brown v. Allen, 344 U. S. 443, 533 (1953) (Jackson, J., concurring in result) ("The historic purpose of the writ has been to relieve detention by executive authorities without judicial trial"). In England prior to 1789, in the Colonies,15 and in this Nation during the formative years of our Government, the writ of habeas corpus was available to nonenemy aliens as well as to citizens." INS v. St. Cyr, 533 U.S. 289, 301-302 (2000). Sorry, "Bart": The case you cited decided that courts do have jurisdiction to hear habeas petitions from aliens such as St. Cyr. They did not decide (nor did they even state in the quoted snippet) that "alien enemy combatants" (or accused ones) do not have such rights. "Bart"'s typical MO here, folks: Miscite law. Cheers,
mesothelioma Mesotheliomais a form of cancer that is almost always caused by exposure to Asbestos In this disease, malignant cells develop in the mesothelium, a protective lining that covers most of the body's internal organs. Its most common site is the pleura (outer lining of the lungs and internal chest wall), but it may also occur in the peritoneum (the lining of the abdominal cavity), the heart the pericardium (a sac that surrounds the heart or tunica vaginalis.
Most people who develop mesothelioma have worked on jobs where they inhaled asbestos particles, or they have been exposed to asbestos dust and fiber in other ways. Washing the clothes of a family member who worked with asbestos can also put a person at risk for developing Mesothelioma Unlike lung cancer, there is no association between mesothelioma and smoking but smoking greatly increases risk of other asbestos induced cancer.Compensation via Asbestos funds or lawsuits is an important issue in mesothelioma The symptoms of mesothelioma include shortness of breath due to pleural effusion (fluid between the lung and the chest wall or chest wall pain, and general symptoms such as weight loss. The diagnosis may be suspected with chest X-ray and CT scan and is confirmed with a biopsy (tissue sample) and microscopic examination. A thoracoscopy inserting a tube with a camera into the chest) can be used to take biopsies. It allows the introduction of substances such as talc to obliterate the pleural space (called pleurodesis, which prevents more fluid from accumulating and pressing on the lung. Despite treatment with chemotherapy, radiation therapy or sometimes surgery, the disease carries a poor prognosis. Research about screening tests for the early detection of mesothelioma is ongoing. Symptoms of mesothelioma may not appear until 20 to 50 years after exposure to asbestos. Shortness of breath, cough, and pain in the chest due to an accumulation of fluid in the pleural space are often symptoms of pleural mesotheliomaSymptoms of peritoneal mesothelioma include weight loss and cachexia, abdominal swelling and pain due to ascites (a buildup of fluid in the abdominal cavity). Other symptoms of peritoneal mesothelioma may include bowel obstruction, blood clotting abnormalities, anemia, and fever. If the cancer has spread beyond the mesothelium to other parts of the body, symptoms may include pain, trouble swallowing, or swelling of the neck or face. These symptoms may be caused by mesothelioma or by other, less serious conditions. Mesothelioma that affects the pleura can cause these signs and symptoms: chest wall pain pleural effusion, or fluid surrounding the lung shortness of breath fatigue or anemia wheezing, hoarseness, or cough blood in the sputum (fluid) coughed up hemoptysis In severe cases, the person may have many tumor masses. The individual may develop a pneumothorax, or collapse of the lung The disease may metastasize, or spread, to other parts of the body. Tumors that affect the abdominal cavity often do not cause symptoms until they are at a late stage. Symptoms include: abdominal pain ascites, or an abnormal buildup of fluid in the abdomen a mass in the abdomen problems with bowel function weight loss In severe cases of the disease, the following signs and symptoms may be present: blood clots in the veins, which may cause thrombophlebitis disseminated intravascular coagulation a disorder causing severe bleeding in many body organs jaundice, or yellowing of the eyes and skin low blood sugar level pleural effusion pulmonary emboli, or blood clots in the arteries of the lungs severe ascites A mesothelioma does not usually spread to the bone, brain, or adrenal glands. Pleural tumors are usually found only on one side of the lungs Diagnosing mesothelioma is often difficult, because the symptoms are similar to those of a number of other conditions. Diagnosis begins with a review of the patient's medical history. A history of exposure to asbestos may increase clinical suspicion for mesothelioma A physical examination is performed, followed by chest X-ray and often lung function tests. The X-ray may reveal pleural thickening commonly seen after asbestos exposure and increases suspicion of mesothelioma A CT (or CAT) scan or an MRI is usually performed. If a large amount of fluid is present, abnormal cells may be detected by cytology if this fluid is aspirated with a syringe. For pleural fluid this is done by a pleural tap or chest drain, in ascites with an paracentesis or ascitic drain and in a pericardial effusion with pericardiocentesis. While absence of malignant cells on cytology does not completely exclude mesothelioma it makes it much more unlikely, especially if an alternative diagnosis can be made (e.g. tuberculosis, heart failure If cytology is positive or a plaque is regarded as suspicious, a biopsy is needed to confirm a diagnosis of mesothelioma A doctor removes a sample of tissue for examination under a microscope by a pathologist. A biopsy may be done in different ways, depending on where the abnormal area is located. If the cancer is in the chest, the doctor may perform a thoracoscopy. In this procedure, the doctor makes a small cut through the chest wall and puts a thin, lighted tube called a thoracoscope into the chest between two ribs. Thoracoscopy allows the doctor to look inside the chest and obtain tissue samples. If the cancer is in the abdomen, the doctor may perform a laparoscopy. To obtain tissue for examination, the doctor makes a small incision in the abdomen and inserts a special instrument into the abdominal cavity. If these procedures do not yield enough tissue, more extensive diagnostic surgery may be necessary. There is no universally agreed protocol for screening people who have been exposed to asbestosScreening tests might diagnose mesothelioma earlier than conventional methods thus improving the survival prospects for patients. The serum osteopontin level might be useful in screening asbestos-exposed people for mesotheliomaThe level of soluble mesothelin-related protein is elevated in the serum of about 75% of patients at diagnosis and it has been suggested that it may be useful for screening. Doctors have begun testing the Mesomark assay which measures levels of soluble mesothelin-related proteins (SMRPs) released by diseased mesothelioma cells Incidence Although reported incidence rates have increased in the past 20 years, mesothelioma is still a relatively rare cancer. The incidence rate is approximately one per 1,000,000. The highest incidence is found in Britain, Australia and Belgium: 30 per 1,000,000 per year. For comparison, populations with high levels of smoking can have a lung cancer incidence of over 1,000 per 1,000,000. Incidence of malignant mesothelioma currently ranges from about 7 to 40 per 1,000,000 in industrialized Western nations, depending on the amount of asbestos exposure of the populations during the past several decades. It has been estimated that incidence may have peaked at 15 per 1,000,000 in the United States in 2004. Incidence is expected to continue increasing in other parts of the world. Mesothelioma occurs more often in men than in women and risk increases with age, but this disease can appear in either men or women at any age. Approximately one fifth to one third of all mesotheliomas are peritoneal. Between 1940 and 1979, approximately 27.5 million people were occupationally exposed to asbestos in the United States.[ Between 1973 and 1984, there has been a threefold increase in the diagnosis of pleural mesothelioma in Caucasian males. From 1980 to the late 1990s, the death rate from mesothelioma in the USA increased from 2,000 per year to 3,000, with men four times more likely to acquire it than women. These rates may not be accurate, since it is possible that many cases of mesothelioma are misdiagnosed as adenocarcinoma of the lung, which is difficult to differentiate from mesothelioma. Working with asbestos is the major risk factor for mesothelioma. A history of asbestos exposure exists in almost all cases. However, mesothelioma has been reported in some individuals without any known exposure to asbestos. In rare cases, mesothelioma has also been associated with irradiation, intrapleural thorium dioxide (Thorotrast), and inhalation of other fibrous silicates, such as erionite. asbestos is the name of a group of minerals that occur naturally as masses of strong, flexible fibers that can be separated into thin threads and woven. asbestos has been widely used in many industrial products, including cement, brake linings, roof shingles, flooring products, textiles, and insulation. If tiny asbestos particles float in the air, especially during the manufacturing process, they may be inhaled or swallowed, and can cause serious health problems. In addition to mesothelioma, exposure to asbestos increases the risk of lung cancer, asbestosis (a noncancerous, chronic lung ailment), and other cancers, such as those of the larynx and kidney. The combination of smoking and asbestos exposure significantly increases a person's risk of developing cancer of the airways (lung cancer bronchial carcinoma). The Kent brand of cigarettes used mesothelioma in its filters for the first few years of production in the 1950s and some cases of mesothelioma have resulted. Smoking modern cigarettes does not appear to increase the risk of mesothelioma. Some studies suggest that simian virus 40 may act as a cofactor in the development of mesothelioma. Asbestos was known in antiquity, but it wasn't mined and widely used commercially until the late 1800s. Its use greatly increased during World War II Since the early 1940s, millions of American workers have been exposed to asbestos dust. Initially, the risks associated with asbestos exposure were not publicly known. However, an increased risk of developing mesothelioma was later found among shipyard workers, people who work in asbestos mines and mills, producers of asbestos products, workers in the heating and construction industries, and other tradespeople. Today, the U.S. Occupational Safety and Health Administration (OSHA) sets limits for acceptable levels of asbestos exposure in the workplace, and created guidelines for engineering controls and respirators, protective clothing, exposure monitoring, hygiene facilities and practices, warning signs, labeling, recordkeeping, and medical exams. By contrast, the British Government's Health and Safety Executive (HSE) states formally that any threshold for mesothelioma must be at a very low level and it is widely agreed that if any such threshold does exist at all, then it cannot currently be quantified. For practical purposes, therefore, HSE does not assume that any such threshold exists. People who work with asbestos wear personal protective equipment to lower their risk of exposure. Recent findings have shown that a mineral called erionite has been known to cause genetically pre-dispositioned individuals to have malignant mesothelioma rates much higher than those not pre-dispositioned genetically. A study in Cappadocia, Turkey has shown that 3 villiages in Turkey have death rates of 51% attributed to erionite related mesotheliomaExposure to asbestos fibres has been recognised as an occupational health hazard since the early 1900s. Several epidemiological studies have associated exposure to asbestos with the development of lesions such as asbestos bodies in the sputum, pleural plaques, diffuse pleural thickening, asbestosis, carcinoma of the lung and larynx, gastrointestinal tumours, and diffuse mesothelioma of the pleura and peritoneum. The documented presence of asbestos fibres in water supplies and food products has fostered concerns about the possible impact of long-term and, as yet, unknown exposure of the general population to these fibres. Although many authorities consider brief or transient exposure to asbestos fibres as inconsequential and an unlikely risk factor, some epidemiologists claim that there is no risk threshold. Cases of mesothelioma have been found in people whose only exposure was breathing the air through ventilation systems. Other cases had very minimal (3 months or less) direct exposure. Commercial asbestos mining at Wittenoom, Western Australia, occurred between 1945 and 1966. A cohort study of miners employed at the mine reported that while no deaths occurred within the first 10 years after crocidolite exposure, 85 deaths attributable to mesothelioma had occurred by 1985. By 1994, 539 reported deaths due to mesothelioma had been reported in Western Australia. Family members and others living with asbestos workers have an increased risk of developing mesothelioma and possibly other asbestos related diseases. This risk may be the result of exposure to asbestos dust brought home on the clothing and hair of asbestos workers. To reduce the chance of exposing family members to asbestosMany building materials used in both public and domestic premises prior to the banning of asbestos may contain asbestos Those performing renovation works or activities may expose themselves to asbestos dust. In the UK use of Chrysotile asbestos was banned at the end of 1999. Brown and blue asbestos was banned in the UK around 1985. Buildings built or renovated prior to these dates may contain asbestos materials. For patients with localized disease, and who can tolerate a radical surgery, radiation is often given post-operatively as a consolidative treatment. The entire hemi-thorax is treated with radiation therapy, often given simultaneously with chemotherapy. Delivering radiation and chemotherapy after a radical surgery has led to extended life expectancy in selected patient populations with some patients surviving more than 5 years. As part of a curative approach to mesothelioma radiotherapy is also commonly applied to the sites of chest drain insertion, in order to prevent growth of the tumor along the track in the chest wall. Although mesothelioma is generally resistant to curative treatment with radiotherapy alone, palliative treatment regimens are sometimes used to relieve symptoms arising from tumor growth, such as obstruction of a major blood vessel. Radiation Therapy when given alone with curative intent has never been shown to improve survival from mesothelioma The necessary radiation dose to treat mesothelioma that has not been surgically removed would be very toxic. Chemotherapy is the only treatment for mesothelioma that has been proven to improve survival in randomised and controlled trials. The landmark study published in 2003 by Vogelzang and colleagues compared cisplatin chemotherapy alone with a combination of cisplatin and pemetrexed (brand name Alimta) chemotherapy) in patients who had not received chemotherapy for malignant pleural mesothelioma previously and were not candidates for more aggressive "curative" surgery. This trial was the first to report a survival advantage from chemotherapy in malignant pleural mesothelioma showing a statistically significant improvement in median survival from 10 months in the patients treated with cisplatin alone to 13.3 months in the combination pemetrexed group in patients who received supplementation with folate and vitamin B12. Vitamin supplementation was given to most patients in the trial and pemetrexed related side effects were significantly less in patients receiving pemetrexed when they also received daily oral folate 500mcg and intramuscular vitamin B12 1000mcg every 9 weeks compared with patients receiving pemetrexed without vitamin supplementation. The objective response rate increased from 20% in the cisplatin group to 46% in the combination pemetrexed group. Some side effects such as nausea and vomiting, stomatitis, and diarrhoea were more common in the combination pemetrexed group but only affected a minority of patients and overall the combination of pemetrexed and cisplatin was well tolerated when patients received vitamin supplementation; both quality of life and lung function tests improved in the combination pemetrexed group. In February 2004, the United States Food and Drug Administration approved pemetrexed for treatment of malignant pleural mesothelioma. However, there are still unanswered questions about the optimal use of chemotherapy, including when to start treatment, and the optimal number of cycles to give. Cisplatin in combination with raltitrexed has shown an improvement in survival similar to that reported for pemetrexed in combination with cisplatin, but raltitrexed is no longer commercially available for this indication. For patients unable to tolerate pemetrexed, cisplatin in combination with gemcitabine or vinorelbine is an alternative, although a survival benefit has not been shown for these drugs. For patients in whom cisplatin cannot be used, carboplatin can be substituted but non-randomised data have shown lower response rates and high rates of haematological toxicity for carboplatin-based combinations, albeit with similar survival figures to patients receiving cisplatin. In January 2009, the United States FDA approved using conventional therapies such as surgery in combination with radiation and or chemotherapy on stage I or II Mesothelioma after research conducted by a nationwide study by Duke University concluded an almost 50 point increase in remission rates. Treatment regimens involving immunotherapy have yielded variable results. For example, intrapleural inoculation of Bacillus Calmette-Guérin (BCG) in an attempt to boost the immune response, was found to be of no benefit to the patient (while it may benefit patients with bladder cancer. mesothelioma cells proved susceptible to in vitro lysis by LAK cells following activation by interleukin-2 (IL-2), but patients undergoing this particular therapy experienced major side effects. Indeed, this trial was suspended in view of the unacceptably high levels of IL-2 toxicity and the severity of side effects such as fever and cachexia. Nonetheless, other trials involving interferon alpha have proved more encouraging with 20% of patients experiencing a greater than 50% reduction in tumor mass combined with minimal side effects. A procedure known as heated intraoperative intraperitoneal chemotherapy was developed by at the Washington Cancer Institute. The surgeon removes as much of the tumor as possible followed by the direct administration of a chemotherapy agent, heated to between 40 and 48°C, in the abdomen. The fluid is perfused for 60 to 120 minutes and then drained. This technique permits the administration of high concentrations of selected drugs into the abdominal and pelvic surfaces. Heating the chemotherapy treatment increases the penetration of the drugs into tissues. Also, heating itself damages the malignant cells more than the normal cells. What is the mesothelium? The mesothelium is a membrane that covers and protects most of the internal organs of the body. It is composed of two layers of cells: One layer immediately surrounds the organ; the other forms a sac around it. The mesothelium produces a lubricating fluid that is released between these layers, allowing moving organs (such as the beating heart and the expanding and contracting lungs to glide easily against adjacent structures. The mesothelium has different names, depending on its location in the body. The peritoneum is the mesothelial tissue that covers most of the organs in the abdominal cavity. The pleura is the membrane that surrounds the lungs and lines the wall of the chest cavity. The pericardium covers and protects the heart. The mesothelioma tissue surrounding the male internal reproductive organs is called the tunica vaginalis testis. The tunica serosa uteri covers the internal reproductive organs in women. What is mesothelioma? mesothelioma (cancer of the mesothelium) is a disease in which cells of the mesothelium become abnormal and divide without control or order. They can invade and damage nearby tissues and organs. cancer cells can also metastasize (spread) from their original site to other parts of the body. Most cases of mesothelioma begin in the pleura or peritoneum. How common is mesothelioma? Although reported incidence rates have increased in the past 20 years, mesothelioma is still a relatively rare cancer. About 2,000 new cases of mesothelioma are diagnosed in the United States each year. Mesothelioma occurs more often in men than in women and risk increases with age, but this disease can appear in either men or women at any age. What are the risk factors for mesothelioma? Working with asbestos is the major risk factor for mesothelioma. A history of asbestos exposure at work is reported in about 70 percent to 80 percent of all cases. However, mesothelioma has been reported in some individuals without any known exposure to Asbestos is the name of a group of minerals that occur naturally as masses of strong, flexible fibers that can be separated into thin threads and woven. asbestos has been widely used in many industrial products, including cement, brake linings, roof shingles, flooring products, textiles, and insulation. If tiny asbestos particles float in the air, especially during the manufacturing process, they may be inhaled or swallowed, and can cause serious health problems. In addition to mesothelioma, exposure to asbestos increases the risk of lung cancer, asbestosis (a noncancerous, chronic lung ailment), and other cancers, such as those of the larynx and kidney. Smoking does not appear to increase the risk of mesothelioma. However, the combination of smoking and asbestos exposure significantly increases a person's risk of developing cancer of the air passageways in the lung. Who is at increased risk for developing mesothelioma? asbestos has been mined and used commercially since the late 1800s. Its use greatly increased during World War II. Since the early 1940s, millions of American workers have been exposed to asbestos dust. Initially, the risks associated with asbestos exposure were not known. However, an increased risk of developing mesothelioma was later found among shipyard workers, people who work in asbestos. Today, the U.S. Occupational Safety and Health Administration (OSHA) sets limits for acceptable levels of asbestos exposure in the workplace. People who work with asbestos wear personal protective equipment to lower their risk of exposure. The risk o f asbestosrelated disease increases with heavier exposure to asbestos and longer exposure time. However, some individuals with only brief exposures have developed mesothelioma On the other hand, not all workers who are heavily exposed develop asbestos-related diseases. There is some evidence that family members and others living with asbestos workers have an increased risk of developing mesothelioma, and possibly other asbestos-related diseases. This risk may be the result of exposure to asbestos dust brought home on the clothing and hair of asbestos workers. To reduce the chance of exposing family members to asbestos fibers, asbestos workers are usually required to shower and change their clothing before leaving the workplace. What are the symptoms of mesothelioma? Symptoms of mesothelioma may not appear until 30 to 50 years after exposure to asbestos Shortness of breath and pain in the chest due to an accumulation of fluid in the pleura are often symptoms of pleural mesothelioma. Symptoms of peritoneal mesothelioma include weight loss and abdominal pain and swelling due to a buildup of fluid in the abdomen. Other symptoms of peritoneal mesothelioma may include bowel obstruction blood clotting abnormalities, anemia, and fever. If the cancer has spread beyond the mesothelium to other parts of the body, symptoms may include pain, trouble swallowing, or swelling of the neck or face. These symptoms may be caused by mesothelioma or by other, less serious conditions. It is important to see a doctor about any of these symptoms. Only a doctor can make a diagnosis How is mesotheliomadiagnosed? Diagnosing mesothelioma is often difficult, because the symptoms are similar to those of a number of other conditions. Diagnosis begins with a review of the patient's medical history, including any history of asbestos exposure. A complete physical examination may be performed, including x-rays of the chest or abdomen and lung function tests. A CT (or CAT) scan or an MRI may also be useful. A CT scan is a series of detailed pictures of areas inside the body created by a computer linked to an x-ray machine. In an MRI, a powerful magnet linked to a computer is used to make detailed pictures of areas inside the body. These pictures are viewed on a monitor and can also be printed. A biopsy is needed to confirm a diagnosis of mesothelioma. In a biopsy, a surgeon or a medical oncologist (a doctor who specializes in diagnosing and treating cancer) removes a sample of tissue for examination under a microscope by a pathologist. A biopsy may be done in different ways, depending on where the abnormal area is located. If the cancer is in the chest, the doctor may perform a thoracoscopy. In this procedure, the doctor makes a small cut through the chest wall and puts a thin, lighted tube called a thoracoscope into the chest between two ribs. Thoracoscopy allows the doctor to look inside the chest and obtain tissue samples. If the cancer is in the abdomen, the doctor may perform a peritoneoscopy. To obtain tissue for examination, the doctor makes a small opening in the abdomen and inserts a special instrument called a peritoneoscope into the abdominal cavity. If these procedures do not yield enough tissue, more extensive diagnostic surgery may be necessary. If the diagnosis is mesothelioma, the doctor will want to learn the stage (or extent) of the disease. Staging involves more tests in a careful attempt to find out whether the cancer has spread and, if so, to which parts of the body. Knowing the stage of the disease helps the doctor plan treatment. Mesothelioma is described as localized if the cancer is found only on the membrane surface where it originated. It is classified as advanced if it has spread beyond the original membrane surface to other parts of the body, such as the lymph nodes, lungs, chest wall, or abdominal organs. How is mesotheliomatreated? Treatment for mesothelioma depends on the location of the cancerthe stage of the disease, and the patient's age and general health. Standard treatment options include surgery, radiation therapy, and chemotherapy. Sometimes, these treatments are combined. Surgery is a common treatment for mesotheliomaThe doctor may remove part of the lining of the chest or abdomen and some of the tissue around it. For cancer of the pleura (pleural mesotheliomaa lung may be removed in an operation called a pneumonectomy. Sometimes part of the diaphragm, the muscle below the lungs that helps with breathing, is also removed. Stereo Tactic Radiation Therapy also called radiotherapy, involves the use of high-energy rays to kill cancercells and shrink tumors Radiation therapy affects the cancercells only in the treated area. The radiation may come from a machine (external radiation) or from putting materials that produce radiation through thin plastic tubes into the area where the cancercells are found (internal radiation therapy). Chemotherapy is the use of anticancer drugs to kill cancer cells throughout the body. Most drugs used to treat mesotheliomaare given by injection into a vein (intravenous, or IV). Doctors are also studying the effectiveness of putting chemotherapy directly into the chest or abdomen (intracavitary chemotherapy). To relieve symptoms and control pain, the doctor may use a needle or a thin tube to drain fluid that has built up in the chest or abdomen. The procedure for removing fluid from the chest is called thoracentesis. Removal of fluid from the abdomen is called paracentesis. Drugs may be given through a tube in the chest to prevent more fluid from accumulating. Radiation Therapy and surgery may also be helpful in relieving symptoms. thanks so much i like very so much your post حلي الاوريو الفطر الهندي صور تورتة حلى قهوه طريقة عمل السينابون طريقة عمل بلح الشام بيتزا هت كيكة الزبادي حلا سهل صور كيك عجينة العشر دقائق طريقة عمل الدونات طريقة عمل البان كيك طريقة عمل الكنافة طريقة عمل البسبوسة طريقة عمل الكيك طريقة عمل عجينة البيتزا فوائد القرفه |
Books by Balkinization Bloggers Bruce Ackerman, We the People, Volume 3: The Civil Rights Revolution (Harvard University Press, 2014) Balkinization Symposium on We the People, Volume 3: The Civil Rights Revolution Joseph Fishkin, Bottlenecks: A New Theory of Equal Opportunity (Oxford University Press, 2014) Mark A. Graber, A New Introduction to American Constitutionalism (Oxford University Press, 2013) John Mikhail, Elements of Moral Cognition: Rawls' Linguistic Analogy and the Cognitive Science of Moral and Legal Judgment (Cambridge University Press, 2013) Gerard N. Magliocca, American Founding Son: John Bingham and the Invention of the Fourteenth Amendment (New York University Press, 2013) Stephen M. Griffin, Long Wars and the Constitution (Harvard University Press, 2013) Andrew Koppelman, The Tough Luck Constitution and the Assault on Health Care Reform (Oxford University Press, 2013) James E. Fleming and Linda C. McClain, Ordered Liberty: Rights, Responsibilities, and Virtues (Harvard University Press, 2013) Balkinization Symposium on Ordered Liberty: Rights, Responsibilities, and Virtues Andrew Koppelman, Defending American Religious Neutrality (Harvard University Press, 2013) Brian Z. Tamanaha, Failing Law Schools (University of Chicago Press, 2012) Sanford Levinson, Framed: America's 51 Constitutions and the Crisis of Governance (Oxford University Press, 2012) Linda C. McClain and Joanna L. Grossman, Gender Equality: Dimensions of Women's Equal Citizenship (Cambridge University Press, 2012) Mary Dudziak, War Time: An Idea, Its History, Its Consequences (Oxford University Press, 2012) Jack M. Balkin, Living Originalism (Harvard University Press, 2011) Jason Mazzone, Copyfraud and Other Abuses of Intellectual Property Law (Stanford University Press, 2011) Richard W. Garnett and Andrew Koppelman, First Amendment Stories, (Foundation Press 2011) Jack M. Balkin, Constitutional Redemption: Political Faith in an Unjust World (Harvard University Press, 2011) Gerard Magliocca, The Tragedy of William Jennings Bryan: Constitutional Law and the Politics of Backlash (Yale University Press, 2011) Bernard Harcourt, The Illusion of Free Markets: Punishment and the Myth of Natural Order (Harvard University Press, 2010) Bruce Ackerman, The Decline and Fall of the American Republic (Harvard University Press, 2010) Balkinization Symposium on The Decline and Fall of the American Republic Ian Ayres. Carrots and Sticks: Unlock the Power of Incentives to Get Things Done (Bantam Books, 2010) Mark Tushnet, Why the Constitution Matters (Yale University Press 2010) Ian Ayres and Barry Nalebuff: Lifecycle Investing: A New, Safe, and Audacious Way to Improve the Performance of Your Retirement Portfolio (Basic Books, 2010) Jack M. Balkin, The Laws of Change: I Ching and the Philosophy of Life (2d Edition, Sybil Creek Press 2009) Brian Z. Tamanaha, Beyond the Formalist-Realist Divide: The Role of Politics in Judging (Princeton University Press 2009) Andrew Koppelman and Tobias Barrington Wolff, A Right to Discriminate?: How the Case of Boy Scouts of America v. James Dale Warped the Law of Free Association (Yale University Press 2009) Jack M. Balkin and Reva B. Siegel, The Constitution in 2020 (Oxford University Press 2009) Heather K. Gerken, The Democracy Index: Why Our Election System Is Failing and How to Fix It (Princeton University Press 2009) Mary Dudziak, Exporting American Dreams: Thurgood Marshall's African Journey (Oxford University Press 2008) David Luban, Legal Ethics and Human Dignity (Cambridge Univ. Press 2007) Ian Ayres, Super Crunchers: Why Thinking-By-Numbers is the New Way to be Smart (Bantam 2007) Jack M. Balkin, James Grimmelmann, Eddan Katz, Nimrod Kozlovski, Shlomit Wagman and Tal Zarsky, eds., Cybercrime: Digital Cops in a Networked Environment (N.Y.U. Press 2007) Jack M. Balkin and Beth Simone Noveck, The State of Play: Law, Games, and Virtual Worlds (N.Y.U. Press 2006) Andrew Koppelman, Same Sex, Different States: When Same-Sex Marriages Cross State Lines (Yale University Press 2006) Brian Tamanaha, Law as a Means to an End (Cambridge University Press 2006) Sanford Levinson, Our Undemocratic Constitution (Oxford University Press 2006) Mark Graber, Dred Scott and the Problem of Constitutional Evil (Cambridge University Press 2006) Jack M. Balkin, ed., What Roe v. Wade Should Have Said (N.Y.U. Press 2005) Sanford Levinson, ed., Torture: A Collection (Oxford University Press 2004) Balkin.com homepage Bibliography Conlaw.net Cultural Software Writings Opeds The Information Society Project BrownvBoard.com Useful Links Syllabi and Exams |


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Volcom On The Fence Board Short - Women's
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I like them
They are very flattering and make your butt look pretty good. although i dont like how they come with wrinkles from where they were folded because they dont lay flat. But i guess they could be ironed out. other than that they're super cute!
Pretty color
The burnt orange color is awesome, it looks great in person. That being said, the style isn't for me. The waist is pretty small and the butt is too big. If I went up a size so they fit on my hips instead of above my belly button, I would have wayyyy too much in the legs and back. I guess they are made for people with bigger backsides and tiny waists.


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One Piece (Series)
by Dave KochThis page has been viewed 18 times this month, and 973 times total.
- One Piece Anime Series
- Tôei Company
- Cartoon Characters: Monkey D. Luffy, Zolo Roronoa, Nami.
- Voice Actors: Mayumi Tanaka, Kazuya Nakai, Akemi Okamura.
- Directed By Konosuke Uda, Yuji Endo, Junichi Fujise, Yoko Ikeda, Takahiro Imamura; more Directors ...
- Produced By Yoshihiro Suzuki.
- Animated By Noboru Koizumi.
- Written By Suminori Takegami, Mitsuru Shimada.
- Series Began Airing on October 20, 1999.
- Originally Aired on Fuji TV (Japan), FOX TV (USA), Cartoon Network (USA).
- Running Time: 30 minutes.
- Color
- Japan
Cartoon Summary:
Based upon one of the most popular and longest running manga series in history, One Piece follows the adventures of Monkey D. Luffy, who after eating a magical... (more)
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Foreign Language Title:
"Tutti All'Arrembaggio (Italian)."
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Over two hundred episodes produced in this series.
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Sat, Apr 26, 14 at 14:54
As I typed out the title of this post the question popped into my head, what if I have made a mistake purchase. In David Austin's catalog there are a few recommendations for container roses. The thought of bareroot in a container now concerns me but that is the plan. Are there any special instructions or precautions I should take putting them in containers? Thank you very much. Carla |
Follow-Up Postings:
- Posted by mad_gallica Z5 Eastern NY (My Page) on Sat, Apr 26, 14 at 17:28
Bareroot, in a container, in zone 7, in almost May .... not ideal. Bareroot in a container, at the proper planting time for bareroot roses isn't a bit deal. The trick is going to be keeping the canes hydrated until the roots establish. Mounding doesn't really work because the material falls off the pot. Wet towels or some other fabric work fairly well. |
It will be just fine! I plant bareroots in pots all the time well into May. I've never had a problem mounding in a pot. Actually sometimes it's easier. If you have a problem take an old plastic pot and slit the side and cut out the bottom and use it as a collar to hold the soil up on the canes. Mound up the canes and keep it moist but not soggy wet until you start to see some new growth on it. Then slowly and carefully start removing the mound. If it starts to get too hot move it into partial shade or morning sun only. Which Austin did you get? |
Thank you mad gallica. Hope you're doing well. Seil, I am happy with your answer. I ordered Munstead Wood, Princess Anne, and Lady of Shalott, or Shallot. I appreciate your specific instructions. Will let you know how they do. Carla |
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Jennifer Aniston, Angelina Jolie, Jessica Alba: Film's 30 Hottest Lingerie Scenes From the Past 30 Years (GALLERY)
Whether they're changing into something skimpy as a sexy double agent or stripping down as an exotic dancer, the big screen's hottest stars often end up in their skivvies.
From Oscar winners Angelina Jolie and Charlize Theron to America's sweethearts Jennifer Aniston and Jessica Alba, many celebs have bared (almost) all in frilly corsets and lacy bras.
As a salute to these, um, courageous souls, Celebuzz is taking a look at film's 30 hottest lingerie scenes from the past three decades.
Launch the gallery to see if your favorite underwear-clad celeb made the cut.
It's not just the ladies who are stripping down.
This year's Magic Mike -- a flick based loosely on Channing Tatum's real-life past as a male stripper -- proved that Hollywood's hunks can look just as good in a barely-there thong.
"I have so much more respect for women and what they have to go through," Joe Manganiello, one of Magic Mike's many sexy male stars, told Celebuzz about how he felt slipping into a thong for the movie. "I never want to see a pair of damn thongs again!"
"If you're asking if I took my thongs home: No way!"
Did we leave out your favorite Hollywood lingerie scenes? Sound off below.


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I tutor all math from elementary school through precalculus. This prepared me to help students taking ACT Math.
I achieved 100% on the WyzAnt Algebra I Certification Test. I am a patient and dedicated tutor who gives the maximum effort to help my students learn and produce top results.
My skills include simplifying complex fractions, graphing various algebraic equations for straight lines and curves, and solving complicated word problems algebraically.
I have taught grades 4-8 in a general education setting, in a variety of subjects. I also have tutored for 22 years to students in grades 1-6 in Science, Social Studies, Reading, Math, and English. I have obtained "A's" at Baruch College in Educational Psychology and Developmental Psychology. I will be able to tutor K-6 students in the Common Core New York State Curriculum. I believe in incorporating both a whole word and phonics approach to Reading. I specialize in Math, which would provide a solid foundation for more difficult future Math courses.
For years I've tutored the operations (addition, etc.), word problems, percents, fractions, and graphs. Even in grammar school, I averaged in the 90's in Math.
My strengths in English focus on grammar and sentence structure. I incorporate this through paragraphs within compositions, essays, and book reports to create proper written presentations.
ESL should focus on reading, writing and speaking English. I believe in a pleasant, relaxed approach to make it enjoyable for the learner. If possible, having homework for practice makes the learning more complete.
My geometry skills include, but are not limited to, word problems, solving for area, solving equations related to triangles, rectangles, squares, rhombuses, parallelograms, and trapezoids. I also tutor for two column proofs in logic and geometric proofs.
I have scored in the top third percentile range on practice units on the GMAT for both Math and English. This includes answering 85% correct on the Math portion of the test. Additionally, I excel in English, and this allowed me to score well on sentence structure and reading comprehension questions.
I scored highly on the GRE practice units, particularly on the Math portion, where I obtained 90% correct. I also found that strategies I employed for the verbal questions helped considerably, for both antonyms and analogies. Finally, I excel in Writing, as I incorporate correct sentence structure with proper grammar, and create well-developed essays.
I have taught the COOP Exam to 8th graders. I have done very well on the SHSAT practice exams. I know that the ISEE is a similar type of test, and so I have no concerns about knowing the material. I think I would do an excellent job tutoring the exam.
I took a college class in Logic and obtained an "A" in it. Also, I've tutored what was known as Sequential I and II (now Integrated Algebra and Algebra II), which required knowledge of logic terminology (including its p's, q's, conjunctions, disjunctions, tautologies, conditional "If ...then's", as well as 2 column proofs involving reasons such as "modus tollens" and "modus ponens" for proving if a statement was valid based upon its premises.
My Prealgebra skills include solving algebraic word problems, understanding measures of central tendency (mean, median and mode),and solving for both x and y by various methods(eg., substitution). It also includes using algebra to solve geometry problems, such as finding the missing angle in a triangle.
I was twice elected club President of oastmaster's, a public speaking organization. I gave speeches on persuading and informing. I also performed in a debate. As a classroom teacher, I prepared my students to debate in a two team match up. I also served as specific and general evaluator at Toastmaster meetings, and frequently opened and closed meetings as President of the club.
I believe in mixing a phonics and whole word learning approach. Pronunciation and enunciation are important, but many English words do not follow the rules. Updating a personal vocabulary list is essential to better comprehension. Reading as though you are picturing the scenario on T.V. is helpful, especially since children are visual. Lastly, choosing to read some material that is less interesting can be a good thing, because children are often called upon to read such material, and practice is needed to try and understand less interesting material because it will often appear on special exams.
I specialize in Algebra and Geometry, which constitutes the SAT Math portion. I also know shortcuts and tricks that can save time on the test. I also scored a 710 on the SAT Math section.
I scored a 640 on the SAT Reading section. I can show students how to read more carefully so that they can retain the information needed to answer questions correctly. I will explain how they should sacrifice a little bit of speed to answer questions more accurately.
I scored the equivalent of a 760 on the SAT Writing section of the test. This was mainly due to a strong foundation of grammar and sentence structure, which I can easily teach to my students. I answered about 96% of the multiple choice questions correctly.
I've always been strong in Spelling, averaging 95-100 in grammar school. When I was in the 11th grade, I took a test that placed me at the 4th year of College level (16th grade, 2nd month). I've continued to improve my skill over the years as new words crossed my path.
I believe I have an excellent approach to study skills. It is important to realize that, for both memorization and understanding, information not learned well is easily forgotten. With this in mind, review of material as close as possible to test time is essential. However, early initial preparation is very important too, especially with more difficult subjects. For example, a student might begin study for a test in a difficult subject three days in advance, whereas two days might be sufficient for a test in an easier subject. The review must continue in bits and pieces the closer the test arrives. The ultimate goal is having the material as fresh in the student's mind as possible until test time. Also it is important to remind the student that this approach will eliminate anxiety, because the student is not walking into the test "cold", but truly ready. This will maximize the test results. The key thinking in this approach is that it is very easy for the mind to forget detail, and that a disciplined approach to obtaining results can make all the difference.
Before I began teaching in the public schools, I was required to write a critical analysis of an essay. I was asked to do so again when I took The National Teachers Exam. I exceeded the requirements on both occasions. I referred to the main idea at hand, made certain observations, used specific examples to support my observations, and summarized my position in the final paragraph. This approach was more than sufficient to satisfy my critical analysis writing.
Great Tutor — He is a great tutor. He really knows what he is doing. Does a great job with my son in teaching him new skills that he can apply in class. I am very pleased with his work. He is very reliable. Am very thankful for his great service. ...
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Reviewed BBQ Chicken Pizza
Jan 17, 2012 in Food Network Community Toolbox on FoodNetwork.com
"This is a great go to recipe! Easy to put together after working all day and a favorite with the picky eater in the family."""


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I'm the first to post in the new lounge!!!
*runs around shouting* WOOOOOOTTTT!!!!!
*hugs ky* I want to say it will be okay... Because it will. But people don't like that phrase when they are upset.
*Smiles* It will be okay. Don't let it eat at you so much though. I know you can't just be happy and normal, but don't let it keep you down all the time. Be happy a little. You don't want wrinkles from frowning and crying all the time. ^_^ (something my friends tell me to make me smile.)


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of 388 Board/Card Games
< what's the formula?
Careers is a board game first manufactured by Parker Brothers in 1955, which has been reprinted from time to time up to the present day. It was devised by the sociologist James Cooke Brown. Victory conditions consist of a minimum amount of fame, happiness and money that the player must gain. Players set their own victory conditions before the game begins, the total of which must be sixty. The board consists of a square with an outer track and several minor loops, ea...
... more on Wikipedia


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Spring is a time for family fun excursions. Blooms enhance a spring drive through the Blue Ridge Highlands and Shenandoah Valley while the wineries of Northern Virginia boast beautiful patios for sipping award-winning vintages. Beach lovers can dip their toes in the Chesapeake Bay from a number of points, including the Eastern Shore, or dive right into an early summer with a trip to Virginia Beach. Craft beer enthusiasts will find Central Virginia overflowing with tasting opportunities, and music lovers will hear a lively tune floating through the air in the Heart of Appalachia. Southern Virginia is a great destination for boaters to get in some lake time, and all of Virginia is a playground for those who seek something fresh and new.
If you're looking for great drives to catch spring's first pops of color, see this list of byways and parkways perfect for slow, scenic driving.
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Just five races remain before the Chase for the Sprint Cup, and it's go time.Start Slideshow
Several drivers answered a wake-up call Sunday at Pocono, with winner Kasey Kahne, runnerup Jeff Gordon, Kurt Busch and Brad Keselowski all scoring top finishes and climbing in the standings.
Can they sustain that momentum and make the Chase after slow starts to the season?
Or will another driver make a move this week at Watkins Glen?
Johnson missed a golden opportunity to win for the second week in a row. But even when he and his team make a mistake, they still salvage a decent finish, which is another reason that he is head and shoulders above everyone else again this season.Next
Busch gains a spot in the rankings mainly because Matt Kenseth wrecked and Kevin Harvick struggled. But Busch is doing exactly what he needs to do—click off consistent finishes.Next
Kenseth got caught up in someone else's wreck on Lap 1, and then wrecked himself at the end of the race. An all-around bad day for a driver who has kissed his wife in victory lane four times this year.Next
Something happens almost every week to keep Earnhardt from having a chance to win. At Pocono, it was a vibration. But his fifth-place finish was his third top-10 in the past four races.Next
After one of the best top-10 streaks of his career—nine in a row—Harvick has finished 19th and 17th in the past two races.Next
Kahne has apparently shaken off the bad luck that knocked him out of the top 10 in points a few weeks ago. He has two straight top-fives and his win at Pocono—his second of the season—should secure at least a Chase wild card.Next
More importantly, Kahne is showing once again why he could be a threat in the Chase.
Stewart was closing in on the top 10 in points and in position to earn a Chase wild card. But the three-time champ's Chase hopes may be over now after breaking his leg in a sprint car wreck Monday night.Next
That's a shame. The Chase will be less entertaining and exciting without Smoke's passion and determination. Hopefully other top drivers will take notice and not take the same risk.
Gordon made a remarkable comeback to make the Chase last year. His rally started a little earlier this year, launching him to ninth in the standings.Next
He had his best race at Pocono and may be closing in on his first win of the year. -
Bowyer still is second in points, but he's had three straight races outside the top 10. He needs to turn things around quickly to gain some momentum before the Chase.Next
Edwards remains third in points, but he hasn't looked like a third-place driver for weeks.Next
Newman backed up his win at Indy with a solid fourth-place run at Pocono. He's now just nine points from being in position for a Chase wild card.Next
Busch scored his fifth top-five finish of the season at Pocono, but it might have been his team's best race of the year.Next
He's just 11 points from the top 10. If he can somehow pull off a win, Busch could be a sleeper going into the Chase. -
Biffle scored his first top-10 finish in four races at Pocono and is clinging to 10th in the standings. He needs that next Michigan race to get here in a hurry.Next
Keselowski had his best race in a while (sixth) at Pocono, but it gained him only one spot in the standings. He needs to win, and he almost did last year at Watkins Glen.Next
Logano quietly bagged his 10th top-10 of the season at Pocono, but gained only one spot in the standings. Like Busch and Keselowski, he may need to win to make the Chase.Next
After cracking the top 10 in June, Truex has been in a freefall, plunging six spots in the standings to 14th. His biggest problem, though, is the drivers around him (Newman, Kurt Busch, Keselowski) are starting to surge.Next
Truex needs to recapture some road-course magic this weekend.
What does McMurray get for finishing 16th at Pocono? He gets to remain 17th in our rankings.Next
Almirola finished 20th at Pocono and gained two spots in the rankings. That's how bad the drivers around him were.Next
Ambrose scored a solid 12th-place finish at Pocono. A nice tune-up for the return to the track he has won at the past two seasons. Put something on the Barbie and brush up on your Australian accents.Next
Martin and this team have lost a bit of its oomph since Vickers' win at New Hampshire. Vickers will be back behind the wheel at Watkins Glen.Next
Montoya didn't do himself any favors when he caused a wreck on the first lap at Pocono. Now he limps into a track where he could win — if he can shake the black cloud that has hung over him the past three years.Next
Once again Menard's Chase hopes have faded away after a fast start to the season.Next
Burton pounded the roof of his car after getting swept into a wreck at Pocono. It's a wonder he hasn't broken his hand multiple times the past three seasons.Next
First he gets into a name-calling rift with Kyle Petty, and then he wrecks on Lap 15. Petty is right. Hamlin needs to turn his attention toward 2014, because 2013 has gone south for him.Next
Speaking of drivers going south, Stenhouse got turned around on the first lap at Pocono. It was just another setback for a promising rookie who has gotten beaten up the past two months.


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AmazonWinter is always a good time to stay in and catch up on a little finance reading.
In case you missed them, we've compiled a list of 22 classic works that every Wall Streeter should read.
These are the books that show up time and again in lists of books recommended by the pros themselves.
Topics covered include everything from the fundamentals of investing to the stories behind some of the Street's most speculative episodes in history.
Winter is always a good time to stay in and...
5 Things The Internet Can Do Right Now To Make Our Lives Better
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Why So Many Business Owners Are Turning To Online Business Loans
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We Tested Three Intriguing Recipes From A Hot New Chef (That Isn't Human)
INFOGRAPHIC: The Evolution Of The Hollywood Acceptance Speech
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Yesterday we discussed how body language is 55 percent of your communication during most conversations and how your body language can potentially wreck a job interview. But we're not just fear mongering, here. Your body language canShow More Summary
Psychology Today reports that body language comprises 55 percent of communication. (That's followed by tone of voice at 38 percent, with only 7 percent being the words you actually speak.) As a result, on a job interview, you need to...Show More Summary
Knowing how to deal with tough interview questions properly can put you miles above the other candidates. Your body language,... The post 8 Misleading And Really Tough Questions You Could Be Asked In Job Interviews appeared first on Lifehack.
Could your body language during an interview give away the fact that you're dumb and unimaginative? Standford scientists think so. You can tell a lot about a person's mental state just by looking at their body language. Are they laid...Show More Summary
Walking into an important interview can be nerve-wracking. You're afraid you'll say the wrong thing, even though you've practiced every possible question and you know your value proposition. Often, however, it's not our words that give...Show More Summary
A serial job interviewer opened up to The Wall Street Journal and after completing more than 100 job interviews between 2007 and 2013, she has a lot to say. Sofia Faruqi mentions the number one body language tip is eye contact. During an interview, she says you want to maintain eye contact without being creepy. continued... New Career Opportunities Daily: The best jobs in media.
The good news: this great breakdown of common body language foibles during job interviews can help get you hired. Bad news: there are loads of other important situations your body language may be ruining! Whether you're on a date, at...Show More Summary
V. Stiviano's blockbuster interview with ABC's Barbara Walters about her relationship with Los Angeles Clippers owner Donald Sterling was full of deception and outright lies says renown body language… READ ON
It's not easy to always look good on video calls, but correct framing is the first step, suggests Paul J. Bailo, author of The Essential Digital Interview Handbook, whose previous advice includes not neglecting your body language for video interviews. Read more...
Your body language can turn out to be a huge problem, if you're not aware of it. Are you making any of these body language mistakes during interviews? The post 8 Body Language Mistakes You're Making During Interviews appeared first on CAREEREALISM.
Body language is important in an interview, but it's hard to remember to be animated in a video chat interview. The Daily Muse spoke to experts about the do's and don'ts of a Skype interview and an important lesson was to be expressive without being too animated. Read more...
There are plenty of aspects of body language that you can worry about during an interview, but the basics matter more than all the minor details. Case in point: eye contact. More »
We've told you about the negative body language cues you should avoid in a job interview, but it's also important to keep an eye on your interviewer. If you think they are getting bored or distracted, stop whatever you are saying and ask them a question to snap their attention back to you, advises The Daily Muse: Read more...
If you have a big meeting or job interview coming up, sit back and read a newspaper instead of checking out your smartphone or laptop. The change in posture alone can help you be more confident in your interaction, Forbes says. Read more...
This handy inforgraphic helps both sides of the table (err, screen) understand the rising importance of video interviews and how to make sure you nail them
A much larger extent of our communication is done via our body language, than what we say. For this reason, it pays to brush up on your non-verbal communication skills prior to attending an interview. How you come across is as important as what you say; your behaviour speaks volumes about your character. Show More Summary
Body language is important in a job interview, but if you can't remember all the different cues to make and avoid, remember this one: Try not to fidget. A recent survey of hiring managers revealed that 26% of applicants in an interview get rejected because they fidget too much. Read more...
In the spirit of Father's Day, I'm guessing everyone has probably heard the dadism "It's not what you say, it's how you say it." Well, MIT is actually applying that concept to a new automated program that rates your body language as you talk to someone.
Light and shadows. Rough angles and streamlined curves. Misleadingly simple color palettes and explosively dynamic body language. Browsing the portfolio of Pascal Blanchet takes you decades back into the roaring era of Art Deco and does not let you go. I am absolutely thrilled to have the privilege to Pascal and ask him a few [...]Show More Summary
It is very important for interviewees to not only think about the verbal answers they want to give in an interview, but also what their nonverbal answers are saying.


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- Written by Steven Zeegers
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Headlines - February 13th
From time to time, we try to share the best bits of news we discover online. This is our first attempt to do so!
Box.net support for Akeeba?
Overheard on Twitter: Lead developer Nicholas is working hard to add another external back-up solution to AdminTools Professional. The new addition will be Box.net, the popular cloud storage & syncing service. This new option will complemet existing options like Dropbox, Amazon S3, Azure, and - simple yet effective! - your mailbox.
Transifex unveils new site
Transifex, the popular translation platform and an important partner to ATAAW initiative OpenTranslators, has unveiled it's new website today. This is good news for OpenTranslators, who looked forward to some of the new features which will "help to encourage and simplify collaboration between translators.
With features like translation discussions, optional automatisation using Google or Bing and the addition of Reviewers who can check translations and approve them, Transifex is quickly becoming a very valuable asset for (Open Source) projects who want to have their stuff translated in no time!
SquareOne RC coming soon
Jeremy Wilken, also known as @gnomeontherun on Twitter, is working hard on his light weight Joomla! distribution which he has named SquareOne. This ultra light package, which has removed all the fluff - this includes virtually all extensions that are installed by default - is the dream of many Joomla! fans.
They'll be excited to know that a release candidate of this Joomla! distribution has been announced. It' rumored to become available in the nex few weeks.
Steven Zeegers
Typical nerd who earns his money in the IT sector, who can't turn of the computer after works. Loves Joomla!, Gaming, Blogging, and is only slightly addicted to Twitter.