text:
- eLessons Learned
- Press and Publicity
- About Our Team
- Contact eLL Blog
Welcome to the new eLessons Learned
eLessons Learned features insightful content authored primarily by law students from throughout the country. The posts are written to appeal to a broad spectrum of readers, including those with little eDiscovery knowledge.
Each blog post: (a) identifies cases that address technology mishaps; (b) exposes the specific conduct that caused a problem; (c) explains how and why the conduct was improper; and (d) offers suggestions on how to learn from these mistakes and prevent similar ones from reoccurring.
Visit our signature feature, e-Discovery Origins: Zubulake, designed to give readers a primer on the e-discovery movement through blog posts about the Zubulake series of court opinions which helped form the foundation for e-discovery. Go There
Interested students may apply for the opportunity to write for e-Lessons Learned by filling out the simple application. Go There
The defendants in Conn. Gen. Life Ins. Co. v. Scheib objected to five of the plaintiff's Requests for Production of Documents ("RFPs") because they would be unduly burdensome to produce. Thus, the court allowed the defense counsel to come forth with evidence to prove that the production of those documents, which consisted of 219 gigabytes of 19 different e-mail accounts. The court determined that such production would be unduly burdensome. Counsel for the defendants did indeed file a Supplemental Briefing Regarding Cost of E-Mail Production indicating that it would cost over $121,000 to index, filter, and process the data. In this case the plaintiff's complete claim totaled $119,515.49. In analyzing the defendants' proof against production, the court used Federal Rule of Civil Procedure 26(b)(1), which states that a court can limit discovery of relevant material if the discovery sought is unreasonably cumulative, obtainable from another source that is more convenient, less burdensome, or less expensive, or the burden or expense of the proposed discovery outweighs the likely benefit. The party objecting to the discovery request has the burden of proving why the requested discovery should not be permitted. But, if the party meets that burden, the burden then shifts to the original requesting party to show that the information is relevant and necessary for the case. The court also goes through the steps of analysis of determining whether a party meets the burden of proof. The first inquiry is to determine the benefits derived from the documents requested, specifically what relevant information will become available and the value of that information in resolving issues in the case. Then, those benefits should be compared against the cost of the production of the documents. Additionally, the court can deny the discovery request if the court finds there is a likelihood that the benefits of the requested discovery would be outweighed by the burden or expenses imposed by the proposed discovery. The court here also noted that cost shifting is a possibility when the documents are found to be burdensome to one party, but the other party feels they are necessary for the case. So a court could determine that parties either need to share the costs of a discovery request, or that a proposing party must take over costs for the request. The court found the defendants provided enough proof that the five RFPs were unduly burdensome to produce. The costs, tasks, and outside firms that would need to hired all combined convinced the court that it outweighed the benefit that the plaintiff would get out of the documents. Additionally, the court noted the lower stake of the litigation and the already provided documents that hit many of the relevant matters at hand in the case. The court also allowed the plaintiff to fund the retrieval of the information requested in those five RFPs if desired: "If Plaintiff believes that this information is important to its case, then Plaintiff can perform its own cost-benefit analysis and determine whether it wants to fund the discovery." Overall, Scheib teaches us that once a party gets past the heavy burden of proving that production is burdensome, then all burden and costs could easily shift to that original requesting party.
While the practice of law, by nature, involves two parties facing off, there is no reason to make the job more difficult than it needs to be. The rules that govern court proceedings are in place to encourage cooperation between the parties and ensure that things "run smoothly." When one party fails to abide by these rules, sanctions may be necessary. In Branhaven, the defendant's counsel sought to prohibit the plaintiffs from using certain documents that were the product of a large last minute "document dump," and award the defendants attorney's fees and costs as a result of said production. The defendants also claimed that they were entitled to fees based on a Federal Rule 26(g) violation, in that plaintiff's counsel had incorrectly certified by signing a response to defendants document requests on March 21 that such responses were "to the best of [his or her] knowledge, information and belief formed after reasonable inquiry." Id. at 389. The defendants also claimed that counsel for the plaintiffs did not make reasonable efforts to ensure that the client has provided all the information and documents available that are responsive to the discovery demand. Additionally, for each request, the plaintiffs responded by stating that they would make the documents available at a mutually convenient time. In order to understand the egregious nature of the plaintiff's conduct, we must look at the timeline of events. On January 31, 2012, requests were served on the plaintiffs, at which point its counsel claimed to have sent these requests to the client. On March 16, 2012, the plaintiff's counsel claimed that the plaintiff had yet to be provided with responses. The plaintiff's counsel told the defendant's counsel that they would be made available at a mutually agreeable time. The record reflects no action was taken until June. On June 14, 2012, the plaintiff's counsel stated that the client had yet been provided any documents for production. The plaintiff assembled responsive pleadings based on that documents within the firms possession and sent same to the defendants. This amounted to about 388 pages in total. On July 20, merely days before depositions of the client were to begin, the plaintiff produced 112,106 pages apparently from overlooked e-mail servers and laptops. The plaintiff defend this conduct by stating that their servers were purchased as part of an asset sale and that passwords were not readily available, as the preference was to use in house IT staff prior to outsourcing. The court did not buy any of the plaintiff's arguments stating that the plaintiff waited about five months prior to seeking the assistance of outside IT support. While a one month delay may have been reasonable, five months was not. Before one initiates suit, one should prepare for discovery as they would be subject to demands. The March 21 certification was made prior to any investigation by counsel that eventually turned up over 100,000 pages of documents. Therefore, the lack of access on the defendants stemming from the plaintiff's conduct was punishable through attorney's fees for the time spent converting the documents to a reviewable format as well as the time spent drafting and prosecuting for this motion for sanctions.
A growing trend in insurance disputes is a demand for insurers to have access to the claimant's social media content. In January 2013, the District of Montana had to consider whether to compel a woman to produce all of her social media photos. The court did not grant this request and the decision serves as a good example of what is, or is not, an effective way to request this information. In Keller, one of the plaintiffs claimed she injured her head, neck, and back in an automobile accident when the vehicle she was driving was struck from behind. Her mother also suffered injuries in the accident. At the time of the accident, they were insured under an automobile liability policy issued by the defendant. The plaintiffs made a claim for uninsured motorist benefits under the policy. The defendant, under Federal Rule 37, moved for an order compelling the plaintiffs to respond to discovery requests for the production of their social network site content. The defendant's rationale for the request was the plaintiffs alleged a "host of physical and emotional injuries." In respect to the mother, the defendant argued "there is no good reason for her to shield information that might shed light on her or her daughter's injuries." This is the language of the request: Request for Production No. 18: Please produce a full printout of all of Plaintiff [driver]'s social media website pages and all photographs posted thereon including, but not limited to, Facebook, Myspace, Twitter, LinkedIn, LiveJournal, Tagged, Meetup, myLife, Instagram and MeetMe from August 26, 2008 to the present. Request for Production No. 19: Please produce a full printout of all of Plaintiff's [mother's] social media website pages and all photographs posted thereon including, but not limited to, Facebook, Myspace, Twitter, LinkedIn, LiveJournal, Tagged, Meetup, myLife, Instagram and MeetMe from August 26, 2008 to the present. As you can imagine, the court felt these requests were overbroad. It is well settled that social media content is discoverable, but the requestor must make a threshold showing that publicly available information on those sites undermines the plaintiff's claims. The defendant did not come forward with any evidence that the content of either of the plaintiffs' public postings in any way undermined their claims in this case. Absent such a showing, the defendant was not entitled to delve carte blanche into the nonpublic sections of the laintiffs' social networking accounts, let alone all of them. This case should serve as a lesson to other insurance litigants. You should only request access to social media accounts if you can make a threshold showing that the social media content will be relevant and hold admissible evidence. Otherwise you will rightly be admonished for undergoing a "fishing expedition" and your requests will be promptly denied.
In Brown v. Tellermate Holdings Ltd., Tellermate Holdings, the defendant company, terminated two employees for allegedly failing to meet sales targets over several years. The employees, feeling that they were wrongfully terminated due to their age, filed an employment discrimination action against the company as well as other entities and individuals associated with Tellermate. Throughout pre-trial proceedings, the case was plagued with numerous discovery mishaps. The plaintiffs requested from the defendant company data stored and maintained by Salesforce.com,[1] which would, in theory, evidence plaintiffs' sales records over the last few years in addition to allowing the plaintiffs to compare their sales figures with other (younger) employees. However, even though numerous discovery conferences were held, numerous discovery motions filed with the court, and several discovery orders issued by the court, the defendant corporation failed to produce the requested data and documents. Ultimately, the plaintiffs filed for judgment and sanctions under Federal Rule 37(b)(2); the court held a three-day evidentiary hearing on the matter. The presiding judge, United States Magistrate Judge Terence P. Kemp, identified three areas in which the defendant company or its counsel failed in its obligations to the plaintiffs and the court in relation to production of documents and data: Defendant's counsel failed to understand how Tellermate's data stored with Salesforce.com could be obtained and produced to plaintiffs, which resulted in counsel making false statements to the plaintiffs' counsel and the court; By failing to understand how the defendant's data was stored and maintained, defendant's counsel took no steps to preserve the integrity of the information in Tellermate's database located with Salesforce.com; Defendant's counsel failed to learn of the existence of documents relating to a prior age discrimination charge until almost a year after plaintiffs requested the documents; Defendant's counsel produced a "document dump" resulting from counsel's use of an overly-broad keyword search that yielded around 50,000 irrelevant documents, which plaintiffs' counsel could not review within the time period ordered by the court. The Salesforce.com Data Judge Kemp found that Tellermate's failure to preserve and produce the data logged on Salesforce.com's website irreparably deprived the plaintiffs of reliable information necessary in supporting their claims. Although defendant's counsel initially stated that Tellermate "does not maintain salesforce.com information in hard copy format," "cannot print out accurate historical records from salesforce.com," and that "discovery of salesforce.com information should be directed at salesforce.com, not Tellermate," the court found such statements to be on their face false. In fact, Tellermate did have access to the information sought by the plaintiffs as one, and sometimes two, of Tellermate's employees enjoyed the highest level of access to the Salesforce.com information. The court determined that the information eventually produced by the defendants could not be trusted as "even a forensic computer expert has no way to detect hat changes, deletions[,] or additions were made to the database on an historical basis." Because of Tellermate's failure to preserve the Salesforce.com data, Judge Kamp precluded Tellermate from providing evidence showing that the plaintiff-employees were terminated for their alleged underperformance. Counsel's Obligations With Respect to ESI The court found that the defense's counsel fell short of their well-established obligations[2] to critically examine the documents and data Tellermate provided to them. Tellermate made false representations to its counsel about the data's availability and therefore caused undue delay in document production as well as false and misleading arguments to be made to plaintiffs' counsel and to the court. Subsequently, the plaintiffs were forced to file discovery motions before the court to address these discovery issues which produced the Salesforce.com data that was never properly preserved albeit its significance to the plaintiffs' case. Judge Kemp ultimately determined that counsel for the defendant conducted an inadequate investigation of Tellermate's electronic data while simultaneously failing to understand the most basic concepts of cloud computing and cloud storage, which led to counsel's failing to preserve key electronic data. Control of Data Stored in the Cloud As mentioned above, Tellermate and its counsel repeatedly represented to the plaintiffs and to the court that it did not possess and could not produce any of the Salesforce.com data requested by plaintiffs. Additionally, the defendants asserted that in light of those facts, the defendants could not preserve the data stored on Salesforce.com's databases at any point prior to litigation. Judge Kemp dismissed these claims. The court concluded that, without any factual basis whatsoever, no substantive argument could be made that Tellermate was prohibited from accessing the information stored on the Salesforce.com databases or that Salesforce.com was responsible for preserving Tellermate's information and data as it was the entity that maintained possession and control of the data. In reality, Tellermate was the custodian of the data stored on the Salesforce.com databases. While information can be stored in locations outside the immediate control of the corporate entity by third party providers, it can still be under the legal control of the owner of the data and therefore must be produced by the owner under Federal Rule 34(a)(1)(A). Additionally, had Tellermate's counsel critically examined the agreement between Tellermate and Salesforce.com, it would have realized that Tellermate was the owner of all data created by its employees and that Tellermate could, at any time, download the data stored on the Salesforce.com databases for preservation and production purposes. Limitations on Document Production to Avoid "Document Dumps" Tellermate produced to the plaintiffs 50,000 pages of irrelevant documents, classified by Judge Kemp as a "document dump." Tellermate's counsel refused to disclose which search terms it used in deciding which documents to produce to the plaintiffs, claiming that the search terms were privileged. In actuality, the court discovered, Tellermate's counsel only used the full names and nicknames of employees as its search terms, which obviously yielded irrelevant documents. Without reviewing the returned documents, and because the court's deadline for producing relevant documents was rapidly approaching, Tellermate's counsel produced to the plaintiffs the documents as "Attorney's Eyes Only." The court recognized that a protective order was permitted only when counsel held a good faith belief that such information constituted a "trade secret or other confidential research, development, or proprietary business information, and that such material was entitled to a higher level of protection than otherwise provided in the protective order." Tellermate could not demonstrate entitlement to this level of protection with respect to the search terms used in procuring documentation for discovery: The alleged burden imposed by a high volume production does not provide the producing party or its counsel free reign to choose a given designation and ignore the Court's order pertaining to that designation. First, the court looked to whether competitive harm would result from the disclosure of the types of documents produced by Tellermate to a competitor; however, Tellermate's memorandum on the issue did not contain any evidence about the harm which might result if the plaintiffs were permitted to review any particular document that was labeled "Attorney's Eyes Only." Second, Tellermate's argument as to the harm it would experience was entirely conclusory and was not supported by evidence: Apart from the general concept that disclosure of some types of sensitive information to a competitor may result in harm, it contains no particularized argument which is specific to [the plaintiff], the way in which he was competing with Tellermate, and how the disclosure of any one of the 50,000 pages marked as attorneys-eyes-only would harm Tellermate's interests. The court was astounded that Tellermate continually failed to meet the burden required to designate the documents as "Attorney's Eyes Only" and, up until the hearing date, made no effort the redesignate a single page of the 50,000 produced in order to permit the plaintiffs from viewing the documents. Sanctions The court had absolutely no qualms with an award of attorneys' fees for all motion practice connected to the preservation and production of the Salesforce.com data. "Had Tellermate and its counsel simply fulfilled their basic discovery obligations, neither of these matters would have come before the Court, or at least not in the posture they did." The court took great concern to the extraordinary lengths the plaintiffs had to go to in order to obtain the documents maintained by the defendant and, even after several rounds of motions, were not able to obtain all of them. The "Attorney's Eyes Only" designation on the 50,000 documents produced was also unfounded, the court held, and unduly precluded plaintiffs from necessary evidence that supported their case, which warranted fees under Federal Rule 37(a)(5)(A). Conclusion Tellermate provides a warning to all attorneys that the realm of technology in which their clients are constantly interact with is always changing. Therefore, so does the practice of electronic discovery. Counsel must always meet its duties with respect to ESI by engaging in discussions with its clients and opposing counsel about ESI; being aware, and perhaps even knowledgeable, of new and emerging technologies; and investigating and assessing with its clients the sources and status of potentially relevant ESI. By forgoing these practices, counsel opens itself and its clients to easily avoided and costly sanctions. Daniel is the Editor-in-Chief of eLessions Learned and a third-year law student at Duquesne University. To read more about him, click here. [1] Salesforce.com is a cloud-based customer relationship management system with more than 100,000 corporate customers around the world. Tellermate and its employees used Salesforce.com to track their sales and other interaction with customers. The court recognized that each sales person using the Salesforce.com management system could add, remove, or otherwise change data on their sales account. [2] See Zubulake v. UBS Warburg LLC, 382 F.Supp.2d 536 (S.D.N.Y. 2005) (counsel had an affirmative duty to monitor preservation an d ensure all sources of discovery information were identified).
The scope of discovery, as stated in Federal Rule 26, has been construed very broadly in its relevancy standard. Any and all requesting parties can seek production of documents and information as long as "the discovery appears reasonably calculated to lead to the discovery of admissible evidence." And while this standard has the tendency of having the producing parties provide all requested, non-privileged documents within their control, some courts have determined there are exceptions. In Potts v. Dollar Tree Stores, Inc., the Middle District of Tennessee determined that requests for private Facebook pages require the rquesting party must meet a threshold showing that the information sought is likely to be found on the social media site and lead to admissible evidence. In Potts, the plaintiff filed suit against her former employer, Dollar Tree Stores, Inc., claiming harassment and discrimination based on the plaintiff's race, a hostile work environment, and retaliation. After discovery disputes, the defendant filed a motion to compel claiming that the plaintiff did not produce a number of requested items and documents, including: Facebook data, any and all computer and storage devices used during and after the plaintiff's employment, tax returns, any relevant documents in online email accounts, as well as other items. The plaintiff's response to the defendant's request asserted that she produced what documents were in her possession, that the defendant's request for the physical production of her computer was unduly burdensome, and that the defendant is not entitled to access to her private Facebook account due to other court holdings requiring a threshold showing that the Facebook page would undermine the producing party's claim(s). Since, the Sixth Circuit Court of Appeals had not yet ruled on requesting parties' access to private Facebook pages, the Middle District of Tennessee relied on outside court rulings in Thompkins v. Detroit Metro. Airport, 278 F.R.D. 387, 388 (E.D. Mich. 2012) and McCann v. Harleysville Ins. Co. of N.Y., 910 N.Y.S.2d 614 (N.Y.App. Div. 2010). Courts in Michigan and New York held that, while Facebook accounts are not considered privileged or necessarily protected by notions of privacy, requesting parties should not be allowed to go on fishing expeditions in hopes of finding relevant information to their case. In resolving the issue of rummaging for information, the courts held that a requesting party seeking access to private Facebook accounts must meet a threshold showing that the social media page will likely lead to admissible evidence. Adopting the idea of a "threshold showing," the Potts court determined that the defendant fell short in showing that the information it gathered from the plaintiff's public Facebook page would lead to admissible evidence if the plaintiff had given more access. The court determined that the defendant was entitled to certain documents in the defendant's motion to compel that Plaintiff had not yet produced in discovery, but accepted the plaintiff's assertion that she no longer had certain requested documents that would not have been relevant to the case. When dealing with the physical production of the plaintiff's computer, the court resolved that an agreed neutral party would search for relevant documents on the plaintiff's computer, using both parties' agreed-upon word search. As for the the defendant seeking attorneys' fees incurred in preparing the motion to compel, the court ruled that Federal Rule 26(b)(2) gives discretion to the court in relieving any undue burdens on responding parties during discovery. The court did not require the plaintiff to pay the defendant's attorneys' fees due to the plaintiff having reasonable objections to the defendant's discovery requests.
This case involves a lawsuit for patent infringement concerning memory chip technology. In 2006, the court found that SK Hynix Inc. had infringed on Rambus, Inc.'s patent. The issue presented in 2013 was in regards to the destruction of documents. The court found that Rambus had spoilated documents in bad faith that ultimately prejudiced SK Hynix. The three main factors that the court looked at in this case in making a determination about sanctions are: The degree of fault of Rambus; The degree of prejudice suffered by SK Hynix; and Whether there is a lesser sanction than dismissal that will address the prejudice to SK Hynix and will deter similar conduct in the future by Rambus and others. The degree of fault is clearly present in this case on behalf Rambus. While it was reasonably foreseeable that litigation would occur, Rambus not only destroyed large volumes of documents but they kept no records of what was destroyed. Because of this, it is impossible to know what evidence was lost and it is unknown if the documents destroyed were singled out because they were potentially damaging documents. The difficulties created as a result of Rambus' conduct are the fault of Rambus and therefore they must suffer the consequences. While it is unclear the degree of prejudice suffered by SK Hynix, it is presumed that SK Hynix has been prejudiced in its ability to litigate its equitable claims and defenses as a result of the destruction of documents related to the Joint Electron Engineering Conference. This missing information would have been required to license its technology at a fair, reasonable, and non-discriminatory rate. To satisfy the third prong of the test, the court decided that a dismissal was not warranted in this case as the conduct by Rambus was not severe enough. While bad faith and prejudice are both present in this case, they would not justify a dismissal. The less severe sanction available would be a monetary fine. While not as severe, the fine most likely will still deter others from engaging in similar conduct in the future. Ultimately, while the court found that what Rambus did was not right, it did not feel that is was so egregious that it warranted a dismissal of the verdict and rather felt a fine was more appropriate. As a result, Rambus was fined $250 million dollars. This monetary sanction is to be applied as a credit against the previous judgment awarded. To avoid an outcome like this in the future, all parties involved in litigation should never destroy documents. Jennifer Whritenour received her B.S. in Political Science and History in 2011 from the University of Scranton. In 2014 she received her J.D. from Seton Hall University School of Law.
An employer doesn't need an attorney to tell him or her that destroying evidence relevant to litigation may make the court very unhappy. Often times, when a party acts in bad faith by intentionally destroying evidence, the court will impose a sanction such as an "adverse inference" jury instruction. This type of instruction orders the jury to infer that the missing evidence would have been detrimental to the guilty party. But what if a party did not intentionally destroy evidence in bad faith, but rather lost the evidence due to a negligent mistake? Should the same adverse inference instruction be used? In Pillay v. Millard Refrigerated Services, the court held that even if a party is merely negligent in destroying evidence, a jury may presume that the evidence would have been unfavorable to that party. This permissive adverse inference instruction differs from the circumstances where the court determines that the party acted in bad faith because the court gives the jury the option of making an adverse inference. Typically, when bad faith is present, the court will instruct the jury that it should presume the missing evidence is detrimental to the party who destroyed it. This instruction differs from the instruction in Pillay where the court gave the jury the option of making the adverse inference. The Pillay court imposed a permissive adverse inference jury instruction when an employer negligently deleted relevant information. The employer claimed that it terminated an employee because the employee's production levels were down. The employee claimed that he was terminated for unlawful reasons and that the employer's labor management system ("LMS") would show that the employee's production level exceeded expectations. The employer, however, no longer possessed the LMS data because of routine deletions of the data after one year. The data was deleted despite opposing counsel's numerous requests to preserve all relevant documents and evidence. The employer argued sanctions were not warranted because the LMS data was not deleted intentionally or in bad faith. The court rejected this argument holding that even without a showing of bad faith, the court has the discretion to impose sanctions when a party's negligence causes information to be lost. The court sanctioned the employer with the following permissive adverse jury instruction: Pillay contends that Millard at one time possessed data documenting [an employee's] productivity and performance that was destroyed by Millard. Millard contends that the loss of data was accidental. You may assume that such evidence would have been unfavorable to Millard only if you find by a preponderance of the evidence that (1) Millard intentionally or recklessly caused the evidence to be destroyed; and (2) Millard caused the evidence to be destroyed in bad faith. Moving forward, this case means litigants must be extra careful in preserving evidence that may be relevant to litigation. One negligent misstep, even if done without any showing of bad faith, may be the cause of an adverse jury instruction that can potentially be the deciding factor in a lawsuit. E-DiscoParty, a Seton Hall University School of Law graduate (class of 2014), served on the executive board of the Seton Hall Law Review and is a member of the Interscholastic Moot Court Board. E-DiscoParty now clerks for a Justice on the Supreme Court of New Jersey.
The plaintiff, Country Vintner, had an agreement with a winery (Esmeralda, who was not named a party to the action) to be the exclusive wholesaler of Alamos, which is an Argentinean wine, in North Carolina. A few years later, the defendant, Gallo, started supplying the wine to a variety of other wholesalers, but not to Country Vintner. The plaintiff sued Gallo for violations of the North Carolina Wine Distribution Agreements Act and for violations of the N.C. Unfair and Deceptive Trade Practices Act. Inevitably, there were disagreements over discovery of Electronically Stored Information (ESI). The plaintiff wanted emails and other ESI that would establish that there had been some sort of collusion between Esmeralda and Gallo that ended up excluding Country from the distribution of Alamos. The parties agreed to narrow the discovery request to certain key words, date restrictions, employees, etc., in order to accommodate Gallo's complaints of an undue burden and expense to produce the requested information. After much deliberation, and accompanying motions, the district court decided to adopt Country's proposal, ordering several search-narrowing guidelines. Gallo then collected more than 62 gigabytes of data and gave the data to their lawyers to process and review. The lawyers processed the data into a) searchable data, b) removed system files and exact duplicates, c) and ran several variations of the 19 proposed search terms and phrases. The district court eventually granted Gallo a motion to dismiss the complaint regarding the Unfair and Deceptive Trade Practices Act, and also granted them summary judgment for the remaining Wine Act complaint. Then, perhaps getting a little ahead of itself, Gallo sought to recover $111,047.75 for their eDiscovery work. They broke down the costs as follows: $71,910.00 – for "flattening" and "indexing," basically making the files searchable and removing duplicate content; $15,660.00 – for extracting the metadata, facilitating data review and other such things; $178.59 – for the conversion from native format to a .tif or .pdf format; $74.16 – for electronically Bates stamping the information; $40.00 – for copying the data onto a disc; $23,185.00 – for ensuring the "quality" of the data and ensure proper preparation of the documents for opposing counsel. The court granted a drastically reduced ESI-related recovery in the amount of $218.59. This covered the costs for copying or duplicating the files but not for their preparation or anything else. The court relied on a 2012 Third Circuit decision (Race Tires Am., Inc. v. Hoosier Racing Tire Corp.) and interpreted the applicable statute (28 U.S.C. § 1920(4), a.k.a. the "taxation of costs" statute) to exclude ESI processing costs. When Gallo appealed this decision, the Fourth Circuit affirmed the lower court's decision. The court proceeded to go through the history of taxation of costs, which hadn't existed prior to 1853, and has been slowly added to our law over the years. The latest version of section 1920 was amended in 2008, and allowed for fees for "printed or electronically recorded transcripts necessarily obtained for use in the case;" and "fees for exemplification and the costs of making copies of any materials where the copies are necessarily obtained for use in the case." The court cited a Supreme Court decision that discussed the purpose of section 1920, and said that taxable costs should be a small fraction of the overall costs in litigation, and therefore should be interpreted narrowly to include only what is written in the law. Therefore, "making copies" was interpreted quite literally to include only the costs of actually making the copies, which in this case meant conversion to PDF and TIFF formats, and copying them onto a CD/DVD. Interestingly, the court also responded to the claim that the current e-technology requires more extensive preparation and therefore greater costs, by saying that preparation of discovery documents was always a big cost, yet were not authorized by Congress to be "taxable." Gallo also tried to argue that when the statute provided for "exemplification" to be included in taxable costs, that it would include the costs in this case, since they had to load the information onto a review platform. The court said that exemplification does not apply here, since it means "an official transcript of a public record, authenticated as a true copy for use as evidence." In our case, the charges didn't include either any public records to be authenticated, or any exhibits. So the costs did not qualify as exemplification. What can be learned from this case is that although there are many things that go into the preparation of any type of discovery, including ESI, the costs of that preparation are not always carried by the requesting party. Undoubtedly, the charges that the defendant was trying to tax onto the plaintiff were legitimate. However, the history of the taxable charges laws has shown that the costs of production of discovery have been greatly limited to the copying stage, and not to the production. I would suggest, therefore, that before a party actually goes through the production and incurs its costs, perhaps they should include the costs into their discovery agreement. Akiva Shepard received his J.D. from Seton Hall University School of Law in 2014. Akiva has worked for a New York State Supreme Court Judge in Kings County and for a NJ real estate firm.
Defendant Youkers was sentenced to an eight-year prison term. Youkers thereafter filed a motion for a new trial alleging that the judge who sentenced him engaged in improper communications and was not impartial. In particular, the father of Youkers's girlfriend was one of the judge's Facebook friends. The father also sent a message to the judge about Youkers's pending case. Despite these potentially alarming facts, the judge testified that he knew the father because they both ran for office during the same election cycle. The judge testified that a mere Facebook friend designation was the extent of their relationship. Upon receiving the message from the father, the judge told the father that such communication was improper and he notified the appropriate individuals. To make Youkers's allegations even weaker, the father was actually seeking leniency for Youkers. The court notes that the American Bar Association (ABA) has said in formal opinions that judges are not barred from using social media. Merely designating someone as a friend on Facebook "does not show the degree or intensity of a judge's relationship with a person." ABA Standing Comm. On Ethics & Prof'l Responsibility, Formal Op. 462 (2013). Accordingly the court concluded that the mere fact that the father and the judge were Facebook friends, by itself, did not suggest bias or partiality. The court concluded that there was no evidence of actual bias. Furthermore, because the judge fully complied with the Texas Committee on Judicial Ethics' recommended procedure for treatment of ex parte communications, a reasonable person would conclude that there was no appearance of impropriety. Had the judge not followed state procedure on the treatment of ex parte communications, things might have gone differently. Judges should be very careful about all their communications and relationships over social media. Although in this case there was no communication between the judge and the father besides the father's message and the judge's response, a court might be willing to find bias if there was an ongoing relationship. Although a mere Facebook friendship alone does not establish anything, other communications over Facebook might have the effect of tending towards partiality. Rocco Seminerio is a 2014 Seton Hall University School of Law graduate. Mr. Seminerio focused his studies in the areas of Estate Planning, Elder Law, and Health Law. He graduated from Seton Hall University's undergraduate program in 2011 with a degree in Philosophy. He is also interested in the life sciences.
In W Holding Co., Inc. v. Chartis Ins. Co. of Puerto Rico, the receiver of Westernbank, FDIC-R brought action under the Financial Institutions Reform, Recovery, and Enforcement Act (FIRREA) against the banks' directors and officers (D & O's) for gross negligence, breach of fiduciary duties, fraudulent conveyances, and adverse domination. Prior to discovery, FDIC-R proposed an order establishing a protocol for discovery of Wesernbank's ESI and to reduce the number of written interrogatories it would receive. The D & O's offered a competing protocol. The court denied FDIC-R's request to alter the number of interrogatories and issued a separate order to establish ESI protocol. When FDIC stepped in as a receiver for Westernbank, it possessed 6.8 terabytes of ESI and over 900,000 paper documents. FDIC spent $2.1 million to put the ESI into a system called DMS iConnect ("DMS"), an internal database where the relevant paper documents were scanned into digital images and processed to generate searchable text. FDIC waned to use a second contractor-maintained system called Relativity to give its litigation opponents searchable access to selected data, which will cost $450 per gigabyte to move. FDIC-R wanted D & O to share in the costs. FDIC–R advanced three rationales in support of its proposal: (1) ESI production costs are analogous to "copying costs" borne by the requestor; (2) the Westernbank ESI is "not reasonably accessible" under Rule 26(b)(2)(B); and (3) the seven-factor test applied in Zubulake III requires cost-shifting in this case. The court disagrees with all three FDIC-R's arguments. As to the argument that production costs are analogous to copying costs, the Court felt that FDIC-R failed to explain how those costs are outside the realm of gathering and preparation expenses customarily borne by responding parties. As for accessibility, the Court disagreed with FDIC-R's position that Federal Rule of Civil Procedure 26(b)(2)(B) required cost-shifting when large volumes of ESI were involved. To be inaccessible, the FDIC-R would have to argue the "cost or burden" of production is tied to "some technological feature that inhibits accessibility." However, the FDIC-R failed to raise any technological issues. The court further noted that the relevant data had already been uploaded into a searchable and organized retrieval system. The court also rejected FDIC-R's third argument that the seven-factor test in Zubulake III requires cost shifting. Zubake also requires that the date in question be inaccessible, which the Court already stated was not. Finally, as to the request to limit the number of interrogatories, the Court believed the requests were "too speculative to merit a ruling at this time." The Court felt that until the parties take more affirmative discovery steps, there is no ground for the Court to alter the defaults under the Federal Rules of Civil Procedure. Salim received his B.A. in Applied Communications, with a minor in Legal Studies, from Monmouth University. In 2014 he received his J.D. from Seton Hall University School of Law in 2014. Salim's past experiences include interning for a personal injury law firm prior to attending law school, as well as judicial internships in the Civil and Family Divisions.


text:
The answer most often lies in the manager-employee relationship. Most people chafe under too much authority, too much forcefulness, too much control.
Via Gene Shklover, PhD
You are the content you publish.
Sign up with Facebook Sign up with Twitter
I don't have a Facebook or a Twitter account
Start a free trial of Scoop.it Business
Your new post is loading...
Your new post is loading...
Kudos's comment, August 28, 2014 7:32 PM
https://www.youtube.com/watch?v=LaAusuETmyo&feature=youtu.be BambooHR Response

subset: commoncrawl


text:
- Home
- 2-3/4 x 27.5 yd PSA Paper 320 Grit
2-3/4 x 27.5 yd PSA Paper 320 Grit is rated out of 5 by 2.
Rated 4 out of 5 by Dnak from Good product Sticks very well. Paper backing a little thin and can rip easily. Very good price. I am doing a frame off restoration 1968 GT350 which is my 1st attempt at such a project. Therefore trying out multiple products and find this sandpaper best for price. Attempting to get a good system down before tackling the next to cars in line for restoration
Date published: 2014-11-13
Rated 1 out of 5 by from great price great price would order again soon thank's eastwood
Date published: 2013-03-14
2-3/4 x 27.5 yd PSA Paper 320 Grit
Item #31376 Brand: INDASA
Adhesive-backed, aluminum oxide
sandpaper roll for dry sanding
sandpaper roll for dry sanding
Adhesive-backed, Aluminum Oxide Sandpaper Roll works with your hand- or air-powered sander for dry sanding Do a professional sanding job with this PSA Sandpaper Roll that sticks to any-length sanding board.More info...
- P320-grit
- 2-3/4"-wide, 82-1/2-ft.-long roll
- Aluminum oxide and lubricant material
- For dry sanding
- Pressure-sensitive adhesive (PSA)
About 2-3/4 x 27.5 yd PSA Paper 320 Grit
Just tear and attach to any length of sanding board. Strong PSA backing is suitable for hand- or air-powered sanders.
2-3/4"-wide, 82-1/2-ft.-long, PSA sandpaper roll; P320-grit aluminum oxide
Customers also viewed:
Includes 3 flexible sanders, plus abrasive paper and guide coatOnly $189.99
Sands all types of flat and contoured surfaces; use wet or dry
Only $69.99
Sale $59.99


text:
By Catholic Online (NEWS CONSORTIUM)
11/12/2012 (2 years ago)
Catholic Online (www.catholic.org)
The latest installment in the James Bond movie series, "Skyfall," broke box office records overseas. The film repeated its success in the United States, where it claimed a whopping $90 million in ticket sales in its four-day run, making it the biggest Bond film so far.
By Catholic Online (NEWS CONSORTIUM)
Catholic Online (www.catholic.org)
11/12/2012 (2 years ago)
Published in Movies
Keywords: Skyfall, domestic gross, international gross, James Bond, Lincoln
LOS ANGELES, CA (Catholic Online) - Directed by Sam Mendes and starring Daniel Craig as the never-aging superspy, "Skyfall" to date has grossed $518.6 million worldwide. Of the film's $90 million domestic gross, $2.2 million was earned in exclusive Thursday runs in IMAX and other large-format theaters.
"Skyfall" marks relative Bond newcomer Daniel Craig's third time donning the tuxedo. In addition to nabbing the biggest domestic opening for a James Bond pic, it also marked Sony's ninth No. 1 opening this year.
More recent additions to the Bond series, "Quantum of Solace" debuted to a series-best $67.5 million in mid-November of 2008, and "Casino Royale" -- marking Craig's first turn as 007 -- opened to $40.8 million in November 2006.
"Skyfall," the 23rd installment in the Bond series is certain to surpass the $586.1 million earned by "Quantum of Solace" and the $594.2 million grossed by "Casino Royale" in their entire worldwide runs.
"It's been a wild, fantastic ride," Sony president of worldwide distribution Rory Bruer says. "The holds have been extraordinary and people will want to see this film again and again."
It was a good weekend for the U.S. box office in general. Revenue was up an impressive 27 percent over the same weekend a year ago thanks to "Skyfall" and a strong crop of holdovers including "Wreck-It Ralph," "Flight," "Argo" and "Taken 2."
"Skyfall" generated spectacular numbers for IMAX theaters, which took in $13.1 million, the best debut for a non-summer opening.
"Skyfall's" domestic opening was buoyed by an A CinemaScore coupled with good reviews. The film skewed older, with 75 percent of the audience over age 25. Males made up 60 percent of those buying tickets.
In "Skyfall," James Bond must save both M, played by Judi Dench and MI6 from former operative-turned-villain Raoul Silva (Javier Bardem). The movie also stars Ralph Fiennes, Naomie Harris, Berenice Lim Marlohe and Albert Finney.
"Skyfall" cost about $200 million to make after rebates.
A far quieter debut arrived in Steven Spielberg's "Lincoln." Opening in only 11 cities before it expands nationwide November 16, Steven Spielberg's "Lincoln" likewise earned an A CinemaScore and strong reviews. The DreamWorks film is distributed domestically by Disney.
The Top Ten Movies at the nation's box offices this past weekend were:
1. "Skyfall"
2. "Wreck-It Ralph"
3. "Flight"
4. "Argo"
5. "Taken 2"
6. "Here Comes the Boom"
7. "Cloud Atlas"
8. "Pitch Perfect"
9. "The Man with the Iron Fists"
10. "Hotel Transylvania"
St. Matthew
St. Anthony
St. George
St. John the Baptist
St. Isidore the Farmer
St. Christopher
St. Benedict
St. Barbara
St. Ann
St. Gerard
St. Florian
St. Brigid of Ireland
St. Francis of Assisi
St. Mark
St. Joseph of Cupertino
St. Joseph
By Catholic Online (NEWS CONSORTIUM)
Spring is in the air and streaming movies, TV shows and specials will be here to greet the sunnier season. Streaming original content, such as the superhero film "Marvel's Daredevil" will be the month's main draws. LOS ANGELES, CA (Catholic Online) - From ... continue reading
By Catholic Online (NEWS CONSORTIUM)
Actor Paul Walker, whose life was taken in a horrific traffic accident two years ago, will have the opportunity to live again - dying during the production of "Fast and Furious 7," Walker's scenes will be completed with digital technology. While this will ... continue reading
By Catholic Online (NEWS CONSORTIUM)
The desert planet of "Tatooine," Luke Skywalker's (Mark Hammill) home planet in the "Star Wars" series, was attacked and destroyed by storm troopers in the original installment of that science-fiction series. Art apparently imitated life, as the Tunisian location ... continue reading
By Catholic Online (NEWS CONSORTIUM)
Like totally. For sure. Gnarly. Gag me with a spoon. If these phrases mean anything to you, you remember the Eighties and the many great movies from that era. If you are a Netflix subscriber, you had better hurry, as a bunch of your favorite films is headed for ... continue reading
By Caitlin Bootsma
One of the things I find so appealing about Lent is that we are not only called to contemplation, but also to action. Prayer, fasting and almsgiving are all equally important ways of uniting ourselves to Christ and offering our lives to Him. Through fasting and ... continue reading
By Catholic Online (NEWS CONSORTIUM)
It makes sense that a nation with well over a billion people would need entertainment - and for the first time ever, the Chinese motion picture box office has overtaken America in terms of monthly sales. The nation of China brought in $650 million in box office ... continue reading
By Catholic Online (NEWS CONSORTIUM)
While our expectations for having our own rocket ship in the 21st Century have been largely met with disappointment, the present is still considerably brighter than the one in the classic science-fiction epic "Blade Runner" in 1982. Congested cities, perpetual ... continue reading
By Greg Goodsell
It was an artistic, challenging film, which made demands on its viewer and depicted a most unflattering portrayal of the motion picture industry. "Birdman" took the Oscar for Best Picture anyway, at the 87th Academy Awards. "Birdman" beat out such favorites as ... continue reading
By Catholic Online (NEWS CONSORTIUM)
"Spectre," the latest installment of the James Bond spy thriller series, kicked off with location shooting in Rome last week. Some Romans were lucky to witness a spectacular car chase along the banks of the Tiber River. James Bond, as played by Daniel Craig ... continue reading
By Mary Rezac, CNA
Valentine's Day plans do not typically include domestic abuse. DENVER, CO (CNA) - Yet thousands of couples are already pre-purchasing their movie tickets for "50 Shades of Grey," a film which many critics are saying romanticizes and attempts to normalize violence ... continue reading


text: Would be mediocre, but for the unprofessional desk clerk/manager and substandard housekeeping. Day two of stay and at 3:30 pm room hadn't been touched up--although staff was around all day. Clerk lacked customer service skills..no sense of concern when brought to his attention so I'll seek service elsewhere next time!


text:
What's weird about an old dude in a Spongebob Squarepants Halloween costume…in May…for no particular reason?
It's simple. We, uh, kill the Batman.
If this jester bends over any further, she will be sure to give us one hell of a show that we will never forget.
Does that mean you are allergic to sweat or maybe allergic to being healthy? I happen to be allergic to people who take no pride in themselves, so please go away before I start sneezing.
People of Walmart is a humor blog that depicts the many customers of Walmart stores across the United States and Canada. Through funny photos and videos, People of Walmart is an entertainment blog in the Three Ring Blogs network that features over 30 of the funniest humor blogs on the internet. Walmart is the largest retail store in the United States and has millions of people visit stores each day wearing anything but proper attire.


text:
So you were walking at Route 24...
Last posted
Jan 08, 2010 at 06:53AM EST.
Jan 03, 2010 at 06:16AM EST
11 posts from 9 users
I say "I'm tired of this pokemon bullshugar" and I shoot it
Did I'm mention I'm Dirty Harry?
Because I am.
Wild Abra used Teleport
It wasn't very effective.
I divide by zero. The end.
and i thought this was about mudkipz
i use my millions on master balls because i used Haxx
Griff has been visited by Pokemon Party Van.
@ Griff
And all of a sudden God shows up and punches an atheist in the face.
Edit: for some reason, Ascii art isnt working.
But little did God know, that atheist was ill-tempered Hans. Hans Gruber:


text:
Coming up in the next {{countdown}} {{countdownlbl}}
Coming up next:
Skip to this video now
Now Playing:
Related Videos
Now Playing: {{itm.title}}
Play Video
This transcript has been automatically generated and may not be 100% accurate.
GMA's 5-Alarm Firefighters Challenge: McAllen, Texas Firefighters Burn Up Dance Floor
Firefighters and Sparky the mascot strut their stuff to Capital Cities' "Safe and Sound."
Now Playing: GMA's 5-Alarm Firefighters Challenge: McAllen, Texas Firefighters Burn Up Dance Floor
Now Playing: 'GMA' 5-Alarm Firefighter Challenge
Now Playing: 'Mad Men' Donates Its Iconic Style to the Smithsonian
Now Playing: 'American Crime' Star Felicity Huffman Talks Gritty New Drama
Now Playing: Norman Reedus: Fans Can Expect 'Twists and Turns' in 'Walking Dead' Finale
Now Playing: Special Family Gets Disney Trip of a Lifetime
Now Playing: 'The View' Celebrates Its 4,000th Episode
Now Playing: Serena Williams Remakes Beyonce's 7/11 Video
Now Playing: March Madness: Wisconsin Badger Nigel Hayes Whispers a Little Too Loudly
Now Playing: Fritz the Dog Tries to Catch
Now Playing: Zayn Malik Speaks Out After Leaving 'One Direction'
Now Playing: 'Downton Abbey' Will End After Next Season
Now Playing: The Beastie Boys Are Officially Done
Now Playing: Jets Players Help With Epic Prom Proposal
Now Playing: New York Jets Players Help With Prom-posal
Now Playing: Cissy Houston: 'Not A Great Deal of Hope' for Bobbi Kristina
Now Playing: Kelsey Grammer, Matthew Morrison on 'Finding Neverland'
Now Playing: Primetime Your Closet: Get TV's Hottest Looks for Less
Now Playing: Get Michonne's Body With 'The Walking Dead' Workout
Now Playing: 'Bachelor' Winner Opens Up About Decision to Freeze Eggs
Now Playing: Deals and Steals: Spring Must-Haves


text:
i would rather get a instant KO than drink a very toxic slime from a poison pokemon. if i knew the poison doesn't kill me then its muck .
you were kidnapped tied to a chair ,you open your eyes . Who would you rather see . Kuroha Diana Shirator or Yuno
NOTE: in case of yuno you are drugged and you basically have the same amount of brain function of a potato .
and diana well...she'll probably do what she did to those 20000 other people .


text:
It was an excellent evening. The dancers flamenco dancers had us totally engrossed and the food was very good. We had opted for the Tapas, and it was very good. A must do!
Doing what: Flamenco Show at Tablao Flamenco El Arenal in Seville
The tour bus was very comfortable and on time with an English speaking guide who went to great lengths to show us some spectacular sights of Seville at night the Spanish square being one.
The flamenco show was beautiful with some very talented dancers. The tapas were tasty and very filling. GREAT!
Doing what: Seville Night Tour with Tablao Flamenco Show
very much enjoyed the tour.Our guide was pleasant young lady and fun to tour with and very knowledgeable. This tour is well worth going on, it was both entertaining and a good learning experience.
Gary Marge--Victoria B.C. Canada
Doing what: Seville Electric Bike Tour
To be honest, I was a little afraid before going, but when you're in the air it is so tranquil and easy, not to mention BEAUTIFUL!! As someone who hates airplanes, I was surprised to be so at ease! The team was also great and accommodated us being the only English-speaking people on the tour.
Doing what: Seville Hot-Air Balloon Ride
Excellent experience. Bikes worked well.
Our guide Marie was delightful and a a virtual encyclopedia of knowledge on the area.
Doing what: Seville Electric Bike Tour
There are not words to describe how fantastic our tour was. Our guide was really friendly and informative letting us dictate the speed and direction of the tour. We ended up with a cruise along the river again most enjoyable. I would recommend this tour to everyone visiting for the first time....
Doing what: Seville Walking Tour and River Cruise
The Guide Was excellent. Very engaging. The boat ride was not good. I don't think it added anything to the tour- it was for me, a "waste" of one hour.
Doing what: Seville In One Day: Santa Cruz Quarter, Royal Alcazar Palace, Seville Cathedral, Royal Maestranza Bullring and River Cruise
The night tour felt poorly planned and just to fill the time before Flamenco show starts. Anyway what can we see in 1hr. The Flamenco show is a hit. Highly recommended. Think is one of the best in town. Tapas not worth the money. Consider to have some decent meal outside before the show.
Doing what: Seville Night Tour with Tablao Flamenco Show
A little bit pricey, but the food was great! And you really got to see different styles of flamenco by multiple female and male dancers.
Doing what: Flamenco Show at Tablao Flamenco El Arenal in Seville
We would highly recommend this Seville walking tour and river cruise. Our guide, David Cox (a lovely man with a good sense of humour and very easy to get along with) interested and enthralled us with facts and stories of this beautiful city, it's history and sights. We are now far more knowledgeable about Seville and The Americas than we were before this tour. Thank you David for a thoroughly interesting and enjoyable walk. Graham, Sue and Nicola Platt from Sutton Coldfield, West Midlands, United Kingdom.
Doing what: Seville Walking Tour and River Cruise
Excellent guide, interesting tour, beautiful city. Just the Sky was not totale blue..
Thanks for these services, my son and I where 100 % happy.
L and V Pesneaud
Doing what: Seville Bike Tour
We loved the whole experience
Doing what: Seville Gourmet Wine and Tapas Tour
There was just the two of us on this tour. Louis, our guide, was very knowledgeable and answered all of our questions. We definitely got to see lots of interesting sights and places we hadn't considered going to if we hadn't been on the tour. It was definitely better than a bus tour as many of the tourist attractions are in the centre and it would be difficult to get there by bus. I had forgotten about the river cruise until we arrived that day. It was nice to sit down for an hour and see a few different sights but the main walking tour was definitely the better part of it.
Doing what: Seville Walking Tour and River Cruise
This tour was amazing!
Doing what: Flamenco Show at Tablao Flamenco El Arenal in Seville
Easily one of the best mornings I have had! The staff is as friendly as possible, and extremely accommodating and enthusiastic. You get to watch and partake in the set-up process of the balloon... and I would've paid just to do that! The flight is obviously a one-of-a-kind experience, and a must-do if you've ever wanted to ride in a hot air balloon. Just when you think your adventure is up, you're treated to a magnificent lunch... you're in for a surprise!!
Doing what: Seville Hot-Air Balloon Ride
Loading more reviews


text:
A pulsating device is disclosed herein for interrupting the flow of water being discharged via a nozzle carried on a dental syringe. The device includes a body coupled between the syringe and the nozzle having a central cavity partially occupied by a flutter valve. The valve includes a broad, flat member pivotally carried at its mid-section in the cavity so as to interfere with a flow of water passing through the cavity from the syringe to the nozzle. One end of the member is weighted so that the member flutters across the ports of the syringe and the nozzle to interrupt the water flow in response to the incoming water pressure from the syringe.
1. A device for producing a pulsating stream from a main stream of pressurized water comprising the combination of:
a body having inlet and outlet ports on opposite sides of a central cavity;
said inlet port adapted to be connected to a source of pressurized water and said outlet port arranged to carry a discharge nozzle;
rotary valve means movably carried on said body within said body cavity for yieldably interfering with flow of pressurized water conducted from said inlet port to said outlet port whereby a sequential series of pulsating water discharges from said nozzle in response to oscillatory rotary movement of said valve means;
said valve means is a flutter valve pivotally carried on said body within said cavity;
said flutter valve comprises an elongated member having pivots outwardly projecting in a lateral direction approximately mid-way between its opposite ends;
said flutter valve member has movable opposite ends terminating in equally close proximity to said inlet and said outlet ports respectively;
a weight carried on said valve member end in close proximity to said outlet port;
said valve member is pivoted in response to the main fluid stream pressure whereby the main fluid stream pressure alternately strikes against one side and then the other side of said valve member at its end opposite to said end carrying said weight; and
said valve member further includes a pair of spaced apart ribs carried on the opposite sides thereof respectively.
1. Field of the Invention
The present invention relates to fluid oscillators capable of producing periodic pulsations in a fluid and, in particular, to a pulsating device adapted to be used with a dental syringe.
2. Brief Description of the Prior Art
Fluid oscillators have been developed which utilize fluid dynamic effects such as stream interaction and boundary layer control to provide a pulsating flow of fluid without any moving parts. In such practices, these devices generally must be constructed with fairly close tolerances in order to achieve satisfactory results, and the cost of such devices is generally quite high.
Still other oral hygiene appliances have been provided which deliver an intermittently pulse stream of water for dislodging foreign matter from the teeth and gum tissues and for the purpose of massaging gum tissue. All the current commercial oral hygiene units of this type operate in substantially the same manner. A liquid, usually water, is fed into an inlet chamber of a liquid pump from a liquid reservoir. The liquid pump is generally the reciprocating type which draws a quantity of liquid from the inlet chamber into the pump chamber on each intake stroke, and on each exhaust stroke delivers a quantity of liquid directly into a delivery tube which is connected to a removable jet nozzle. A separate discharge nozzle is provided for each family member who would use the appliance. These commercially available units usually further include a pulse intensity control that feeds back a portion of the pump liquid to the inlet chamber in order to reduce the pressure or force of the liquid discharged at the discharge end of the discharge nozzle. However, problems have been encountered with maintenance and repair of the pulsating unit since the unit is generally incorporated into the body of the appliance or syringe which is inaccessible for such purposes.
Previous attempts at providing suitable pulsating units or devices are shown in the disclosures of U.S. Pat. Nos. 3,499,440; 3,590,813 and 3,810,465. Although these prior devices have met with some success, difficulties have been encountered which are mentioned above.
Therefore, a long standing need has existed to provide a novel pulsating device which may be readily adapted for use with a variety of dental syringes for the purpose of pulsing the output stream of the syringe for various purposes including the irrigation, cleansing or massaging of biological tissue.
Accordingly, the above problems and dfficulties are obviated by the present invention which provides a novel pulsing device for use with a dental syringe which includes a body having a central cavity adapted to be positioned between the dental syringe and a discharge stem or nozzle whereby the pressurized water flow from the syringe is conducted via the body cavity to the discharge stem or nozzle via a flutter valve. The flutter valve is pivotally carried in the central cavity on the body at its mid-section. The valve includes a rod, flat member which is weighted at one end so that inertia of the weight will carry the member through its pivoting motion within the cavity. Pivoting of the member is in response to introduction of pressurized fluid such as water into the chamber or cavity from the syringe and maintaining movement of the opposite ends of the member with respect to the cavity's input and output ports effects interruption of the pressurized water stream discharging from the discharge stem or nozzle.
Therefore, it is among the primary objects of the present invention to provide a novel pulsating unit for a dental syringe which may be readily coupled between the discharge end of the syringe and the discharge stem or nozzle normally associated with the syringe so that the pressure discharge from the discharge nozzle is pulsed.
Another object of the present invention is to provide a novel pulsating unit which incorporates a flutter valve for readily interrupting the pressure fluid stream of a dental syringe so that the discharge from the nozzle is pulsating.
Another object of the present invention is to provide a novel pulsating unit for a dental syringe which is relatively inexpensive and employs a flutter valve operating in response to the discharge of a dental syringe for interrupting the main pressurized fluid stream so that a pulsating stream is produced.
Still a further object of the present invention is to provide a novel pulsating dental syringe whereby the normal main pressurized fluid stream is converted to a sequentially arranged series of liquid pulses by a flutter valve which is then discharged from a discharge stem or nozzle.
The features of the present invention which are believed to be novel are set forth with particularity in the appended claims. The present invention, both as to its organization and manner of operation, together with further objects and advantages thereof, may best be understood by reference to the following description, taken in connection with the accompanying drawings, in which:
FIG. 1 is a longitudinal cross-sectional view of the novel pulsating device incorporating the present invention;
FIG. 2 is a sectional view of the pulsating device shown in FIG. 1; and
FIG. 3 is a transverse cross-sectional view of the pulsating device as taken in the direction of arrows 3--3 of FIG. 2.
Referring to FIG. 1, the novel pulsating device or unit of the present invention is illustrated in the general direction of arrow 10 which includes a body 11 having a central cavity formed therein as indicated by numeral 12. It is to be particularly noted that the body 11 includes a rear portion 13 which is formed with a projection 14 intended to be inserted into a receptacle 15 carried on the end of a conventional or typical dental syringe indicated in general by the numeral 16. As is the usual practice, the projection 14 includes a reduced portion 17 which is occupied by a conventional O ring seal 18. The rear portion 13 includes a passage way 20 connecting at one end with the output port of the dental syringe 16 and terminating at its opposite end in an inlet port 21 leading into one end of the cavity 12.
The forward end of the body 11 includes a support portion 22 for insertably receiving and mounting a discharge stem or nozzle 23. The opposite end of the nozzle 23 from its end supported in portion 22 terminates in a discharge or jet orifice 24. The stem or nozzle 23 includes an elongated passage way 25 which terminates at one end in the jet nozzle 24 and terminates at its opposite end in an outlet port 26 leading from the internal cavity or chamber 12 of body 11.
Therefore, it can be seen that a fluid conduit exists from the dental syringe 16 through passage way 20 and into the chamber 12 via input port 21 and from the cavity 12 to the jet nozzle 24 via outlet port 26 and passage way 25.
In order to pulsate the fluid discharge from the jet nozzle 24, a flutter valve is incorporated into the cavity or chamber 12 which interferes with the flow of pressurized fluid, such as water, there through and which somewhat restricts the openings of the input and output ports 21 and 26 respectively. The flutter valve includes an elongated broad, flat member 30 which is movably carried on the body 11 via pivots 31 and 32, shown more clearly in FIG. 2. The member 30 further includes side ribs 33 and 34 which project upwardly and downwardly beyond the thickness of the member 30. The end of the member 30 closest to outlet port 26 is provided with a weight 35 which, by its inertia, causes the member to pivot on pivots 31 and 32. The pivot positions are illustrated in solid and broken lines in FIG. 1 within the chamber 12.
It can be seen in more detail in FIG. 2 that the pivots 31 and 32 are received within holes or apertures provided in the body 11 and that the pivots are coaxial with respect to each other. The pivots are located at the approximate mid-section of member 30 between its opposite ends. However, the weighted end 35 will cause the member to pivot.
In actual practice, the pulsing device 10 may be added to any conventional dental syringe by merely inserting the projection 14 into the receptacle normally provided for receiving the discharge nozzle. Next, pressurized water is introduced through the dental syringe and the pressurized water is then conducted via passage way 20 to the chamber cavity 12 of the pulsing device. The input water under pressure strikes the valve member 30 and causes it to pivot. The weighted end 35 causes the member to return to its original position. Pivoting of member 30 is sequential and is repeated over and over as long as pressurized water is introduced to the chamber via inlet port 21. The pulse water will exit from the chamber through outlet port 26 and via passage way 25, to the jet orifice 24. It is also to be noted that the extreme ends of member 30 are in close proximity to the ports 21 and 26 respectively so that some interference is encountered. This interference is intentional and adds to the pivoting action caused by the pressurized water from the dental syringe. Because of the weighted end 35, either the under side or the top side of member 30 will be exposed to the oncoming pressurized water stream at any given moment. Once the stream impacts or impinges against the exposed surface, pivoting is produced and the water impact will be against the opposite side in the next sequence.
Thus, the main pressurized water stream from the dental syringe is interrupted sequentially and it is this interruption that causes pulsing at the discharge jet 24.
While particular embodiments of the present invention have been shown and described, it will be obvious to those skilled in the art that changes and modifications may be made without departing from this invention in its broader aspects, and therefore, the aim in the appended claims is to cover all such changes and modifications as fall within the true spirit and scope of this invention.
Patent Citations
Referenced by
Legal Events
Original Image


text:
The following web form is designed to allow persons (primarily healthcare facilities) to request blank copies of the Comfort Care Order/Do Not Resuscitate (CCO/DNR) forms.
Each center provides career counseling, resume assistance, job placement and much more.
Tweets by @ONEDOES_ONECITY
Download forms, file online or check your refund status at the Taxpayer Service Center.


text:
Icynene in an old house?
DW and I are in the process of renovating a 2-family house in Cambridge MA (hence an area with both plunging cold temps and wind, and with plenty of heat and humidity also). The house is a 100-year-old house with a lathe-and-plaster wall construction and no insulation in the walls.
We are talking with an insulation guy about having Icynene reformulated in a slow-grow mix blown into the walls of the house. Someone raised the concern that Icynene blown into the walls can cause problems with buckling of the lathe-and-plaster or oozing out of holes like electrical receptacles.
Does anyone have experience blowing Icynene into an old house without taking the walls down, and would they care to share their experiences?
No experience with it (yet :-), but one thing to be aware of blowing insulation into old houses is that they tend to have more internal braces and blocking than modern houses. Each of the corners of our 1940's house has nice diagonal braces between the studs. So the placement of the holes needs to be done carefully, not just mid-level and high level, for example, but figure out where any internal blocks are, or you'll end up with large gaps in your insulation.
Reviving this old thread...
We are currently renovating, and I've gotten varying advice on insulating my 1896 four square/colonial revival with horse hair plaster and zero insulation is:
- Blown in cellulose or icynene in the walls
- Icynene in the rafters (attic is "finished" and we will add unico in a few years)
My concern that this along with air sealing will make my house too tight, primarily the attic. Worried about moisture, rot, sick house syndrome, radon, etc. I've been told by HVAC and other folks that I can't make this old house too tight.
Anyone have experience with either or both products in their old house? Any other thoughts or suggestions would be greatly appreciated! Thanks in advance!
Here are some general observations, four years (almost to the day!) after going with icynene in our c.1908 house.
- icynene is expensive, probably the most expensive means of insulation per square foot
- as diygene points out, the frequent diagonal bracing in older houses leaves them sturdier against gale force winds, but does mean that you need to blow in the insulation in multiple holes, so you don't have big uninsulated gaps in the wall.
- We did have some patches of lath-and-plaster buckle under the pressure of the expanding icynene, making damaged wall sections as big as 2'x3', some patches were 18" square, and it did mean some extra work for our plasterer. As luck would have it, we were having all the walls re-plastered anyway, but if you're not prepared to deal with that kind of possibility, I wouldn't go with icynene.
Now the plus sides:
- Old houses tend to be pretty porous by nature. I don't think that putting icynene is going to lock in too much. It certainly has made our house hold on to heat or coolness for an extra day or three compared with before the icynene was installed.
- Because the house retains heat more efficiently, the winter after we put in the icynene, our heating bills dropped by a good 50%, so you will get some of it back in saved utility costs.
- Cellulose and fiberglass insulation are not waterproof, and lose insulation power if they get wet. Icynene serves as a natural vapor barrier, and keeps damp and dank from getting into the house (and hence mold and such).
- Bugs and pests hate the stuff, and won't eat it. I've noticed that our house has been remarkably free of infestations or invasions (apart from fruit flies), and I don't know if it's the icynene that is keeping them out, but I suspect that's part of it.
As a whole, we don't regret at all getting icynene insulation, and would do it again in a heartbeat. But those caveats do need to be kept in mind, and you shouldn't go with it if the cost or the wall issues are a problem.
Dr JimBob: Thanks so much for the update!! I'm reassured you had a good experience with icynene (esp since I also live in Boston metro). I'm not thrilled with the cost either and it's good to know about the plaster issue. I'm waiting to meet with the insulation company next week and will report back.
Once your house walls are insulated to R-13 you have just about maxed out your heat conduction resistance. Going to R-40, for example, gives you just 5% more conductive resistance.
Now the major problem is going to be heat traveling on air flow. Blocking this is a weather-sealing, not an insulation problem. Foams are good at weather-sealing.
So is cellulose. Foams are about 4-5 times more costly than cellulose, but not 4-5 times more effective. So if cost is not a factor, absolutely go with foams. If cost is a factor, dense-pack cellulose delivers more value for the buck.
Low expanding closed cell foams are a little dangerous to loose plaster, but seldom to properly adhering plaster. This risk is often exaggerated -- but if you want to find out where your plaster is loose, this is a good way to do it.
I would generally recommend cellulose, then spend some of the savings on weather-sealing around the windows, doors and house sills and pile up some more insulation in the attic. The overall improvement will be greater than if you just insulated with even the best foam without weather-sealing.
Keep in mind that either product is absolutely dependent on proper insulation -- so know your contractor and absolutely take infrared photos to verify full coverage with no gaps.
Best of luck with the project.
Get lots of info on UNICO. I tried that in a large older home and it was disaster! Hard to discern bad install/equipment or both. It stays broken and does not heat and cool properly when it runs. I have a 3 and 5 ton unit. The 5 was replaced 2 years ago and needs replacing again. I would not use Unico.


text:
Why Vote for Ed Michalenko? "I understand where we have to go as a society to bring environmental progress to the local level," he said.
Bob Faulkner (R-Incumbent)
Running For: Councilor
Experience: Eight Years on Board
The Issues: "The issues in the town have been the same for 50 years and will be the same for the next 50 years," Faulkner said. He points out the biggest issue of taxes and adds services and accessibility to the list. Coming from a background in computer science, Faulkner says he was integral in the change over of computer systems at the beginning of his time on board. Faulkner has seen the Board successfully improve in these three areas since he was elected.
Why Vote for Bob Faulkner? "This is one of the most accessible town boards in the country," he said. "Residents get to stand up and speak at the beginning of the meeting, middle of the meeting or the end of the meeting."
Vicki Baker (D)
Running For: Councilor
Experience: 12 years in County Legislature, president of the Jamesville Positive Action Committee (JAM-PAC)
The Issues: Baker is concerned about the health, safety and economic well being of the Town of DeWitt and its residents. Having made strides to stop the coal plant in Jamesville, Baker calls the current Town Board unreceptive to the community members. She also adds that economic development cannot happen if the town is sick from living next to pollution, something the she feels the Town Board hasn't properly accounted for. "A four-mile evacuation plan is not safety," Baker said.
Why Vote for Vicki Baker? "People need to be involved in their community and not just sit back and rely on the government to do it," she said.
Joan Schroder (R-Incumbent)
Running For: Councilor
Experience: 16 years on board
More like this story
Use the comment form below to begin a discussion about this content.


text:
Best Beach Vacations in May
May is the beginning of the northern hemisphere's summer, so if you're based in the United States you don't have to travel quite as far for a great beach experience. In fact, many of the best beach vacations in May are within fairly easy reach of the States, especially in the South. The water is still chilly in places, but winter is finally over.


text:
Colts vs. Patriots: The Science Behind Sports Rivalries
For most fans of the Indianapolis Colts, the mere sight of a New England Patriots jersey makes their "blue blood" boil red hot. And when these longtime rival NFL teams come face-to-face on the football field – as they will this weekend for a high-stakes, all-or-nothing, AFC championship game at Gillette Stadium in Foxboro, MA – fan tensions will be as high as a Pat McAfee punt. But where do such "us versus them" attitudes come from? And why are some rivalries so strong and long-lasting? …Read More


text:
About "MULTIBALL" by theperk
Design by theperk
haha, nice concept
i really like the concept, but maybe it needs a bit more going on.
i agree. w/ what little there is going on, it doesn't make for a good tee.
I love how the middle guy will be jumping and clinging to a girl's chest.
i didnt get it at first, more work on the flippers. maybe some bumpers or somthing.
i really love this, i like the person at the end hanging on. i think it can mean more if you look into it.


text:
Any security implications are being investigated
Three base transceiver stations installed by a mobile phone service provider over two years ago on the premises of the Hisar Military Station, the base headquarters of the battle formation of the 33rd Armoured Division of the Army, have come under the scanner of intelligence agencies over possible security implications.
Since no land has apparently been leased out to the private service provider, the towers stand on the chassis of heavy vehicles, called "cell-on-wheels". According to sources, after the Army's intelligence wing flagged the issue, an internal inquiry revealed that electricity bills running into lakhs of rupees had not been cleared.
The service provider was in June 2010 granted approval by the Signal Regiment of Hisar Cantonment to make bus shelters on the campus. As instructed by the then General Officer Commanding, approval was granted to install three modern bus shelters and three COWs. Through a letter dated July 2, 2010 the vendor had informed the Commanding Officer that during the process of building bus shelters inside the cantonment, it interacted with a few jawans and families and learnt its network strength was not good. Though people wanted to use its services, they were not doing so because of poor connectivity. Based on these findings, the vendor had proposed setting up of three COWs. The letter mentioned that Chandimadir Cantonment in Panchkula had also given the vendor permission for three COWs.
According to sources, the Army's intelligence wing discovered that BSNL had earlier sought permission to install towers at the cantonment. In 2009, it had installed a digital exchange.
"BSNL has been providing exchanges inside military stations, dedicated lines/hotlines for communication with civilian counterparts and even back-up lines during mobilisation. Peace stations also have no civil phones," said an official.
Army headquarters is yet to reply to queries on the issue.
. According to sources, defence land can be leased to private entities through the Quarter Master General Branch in consultation with Military Intelligence, with a mandatory authorisation from the Cabinet Committee.
Keywords: cell towers, military station, mobile phone service provider, 33rd Armoured Division of the Army


text:
Here's a taste of what TheBody.com has to offer on this topic:
Ask the Experts
The accuracy of OraQuick/Orasure? Cant even mini woo hoo?? (RELIABILITY OF ORAQUICK ORAL TESTS, 2009)Hi Dr Bob,I just did a rapid OraQuick or Orasure, not sure. The doc swabbed my lower and upper gums, not sure if they swabbed my cheeks, but he swabbed it very quick (I am sure not more than 1-2min) and I am not sure if it more than 1 min and I have...
Response from Robert J. Frascino, M.D.
The Robert James Frascino AIDS Foundation...continues to meet Food and Drug Administration (FDA) requirements. Overall, oral fluid rapid tests have performed well and make HIV testing possible in many venues where performing a blood draw or finger stick is impractical or impossible. The... Read more »
gay..touched his semen...wiped ..sniffed..hiv fear (HIV FROM SNIFFING, 2009)dear doctor, I WENT THROUGH ALL UR FORUMS BUT COULD NOT FIND SIMILAR QUESTION....SO PLZ HELP...i... Read more »
gay..touched his semen...wiped ..sniffed..hiv fear (NOW INCLUDES WIFE AND PREGNENCY)Hi doc this is follow up question{OLD QUESTION}: gay..touched his semen...wiped ..sniffed..hiv... Read more »
Reducing the Risk of Getting HIV From Sexual Activities...orally. These cases are all attributed to ejaculation in the mouth (i.e., exposure to semen, not exposure to vaginal fluid or pre-seminal fluid). If there is infected ejaculate, vaginal fluid, or blood present, the risk for infection is higher.... Read more »
Viral Load Tests...test, which can be "negative" for 2 to 6 months after HIV infection. (See Fact Sheet 102 for more information on HIV antibody testing.) For prognosis , viral load can help predict how long someone will stay healthy. The higher the viral load,... Read more »
HIV Testing...(IFA) Window Period Interpretation of Test Results Accuracy of Antibody Tests Anonymous HIV Testing Confidential HIV Testing HIV Name-Based Reporting Partner Notification Orasure Test... Read more »
Condoms...a toilet. They can clog plumbing. Using a Male Condom: Put the condom on when your penis is erect -- but before it touches your partner's mouth, vagina, or rectum. Many couples use a condom too late, after some initial penetration. ... Read more »
Connect With Others
HIV fear
Posted by oen111, 2 Replies...I have done protected sex(Both vaginal and oral) with a CSW in india almost 22 weeks back.on the safer hand I have tested four times by Tridot ELISA ( used in india).At present i dont have any complications.But iam living in fear, beacuse the... Read more »
Posted by Anonymous, 3 RepliesA user in the other section said she sat on a needle and got HIV, its very possible and it has happened before, my question is has anyone ever heard of this happening ? and do they know anyone tht this has happened to ? or say sat on a needle and... Read more »
Your opinion please
Posted by Anonymous, 3 Replies...Usa that they say six months. Could i have HIV? Whats your opinion?. Sometimes for a minute or two i say, hey your fine, you tested negative at 3 months but then i tought again about all of what if, what if' What if she indeed infected me, what... Read more »
Im I Infected?
Posted by Anonymous, 2 Replies...door not too hard but not softly either and the bruse is huge and painfull ive never brused like this before. I have not yet tested due to the fact that I did not have insureance at the time I have recently gotten insureance through my job and I... Read more »
Resource Centers
Guides for People With HIV


text:
Confusing 'Inappropriate Terms'
What I mean by this is that, several times, I've went to name a ship and even though it's a simple, clean word, been informed of that name being banned for being inappropriate. For safety's sake, I will not post any of the names that I recieved that message regarding...
I would, however, like to ask what criteria is used to determine whether or note a character or ship's name is 'appropriate'.
Well, you have the IP proprietary names like Enterprise that can't be used. Then you have names which are already used in the game. Then you have the curse words that can't be used. Then you have inappropriate words from other languages that generally can't be used, and so on. Without knowing what the word was it's hard to say why it might have not been allowed.
I was naming my science captain's BOffs after diseases. Some venereal diseases don't fly, some do. Go figure.
Well, risking all here...
The first time I noticed it, I was going to name an Oberth-class Sci vessel "U.S.S. Crane" after the species of bird.
Crane doesn't seem unusual. Are you trying to rename a ship you've already renamed? IIRC, you only get 1 rename and are required to pay for additional name changes. That's the only thing I can think of off the top of my head; or there's some type of restriction for Silver players.
The filter includes the USS for some reason. So if you wanted to call your ship the hit...
I'll have to go look this up, but again, thank you for a clear answer.
"Scrane" is... pretty flipping obscure.
|All times are GMT -7. The time now is 04:27 AM.


text:
Anyone tried 'Che' fruit?
They are also known as "melonberries" for their flavor. They are related to mulberries and figs. You need a male and female tree for production.
God bless,
I tried a couple at Mr. Lee Wise's (sp?) home in Saline, LA. He says his grandkids love them. They were too astringent for me. Perhaps I could develop a taste for them, but I am not willing to invest the time and money on a bush to find out.
More info at this site.
I think I may have to get some of these. Thanks.
Location: Ches need a warm, sunny location. They should not be planted near sidewalks since the fallen fruit will stain. Like the mulberry, the trees are quite wind-resistant. One method of planting is to put a male and a female plant in a single site, about 1 ft. apart, and prune to a combined volume of approximately 25% male and 75% female.
Soil: The trees are relatively undemanding, but perform best in a warm, well-drained soil, ideally a deep loam.
Irrigation: Although somewhat drought-resistant, ches need to be watered in dry seasons. In summer dry California a deep watering about every two weeks is recommended. If the roots become too dry during drought, the plant may began to defoliate and the unripe fruit is likely to drop.
Fertilization: An annual application of a balanced fertilizer such as 10:10:10 NPK in late spring will maintain satisfactory growth. Nitrogen is the only element likely to be needed in California.
Pruning: The trees need regular pruning to control their shape. The branches formed the previous season should be pruned to half their length. The branchlets on the remaining part of the branches should also be trimmed about 50%. A summer pruning of the male plant is also necessary when planted in a single site with the female. To grow as a tree, in addition to pruning the lateral branches, the leading branch may also need to be staked to point it in a vertical direction. Trees grafted onto Osage orange (Maclura pomifera) rootstock tend to be more robust and grow in a more upright fashion.
Propagation: The che is readily grown from seed, although the plants can take up to 10 years to bear. Seeds should be sown as soon as extracted from the fruit. The plants are often propagated from softwood cuttings taken in midsummer and treated with rooting hormone. The che is also easily grafted to Osage orange rootstock using either a cleft or whip-and-tongue graft.
Pests and Diseases: No pests or diseases have been noted. The ripe fruit is attractive to birds, and deer will browse on both the fruit and foliage.


text:
Some interviews and set footage from our 2009-2010 short film A Country Wedding.
Loading more stuff…
Hmm…it looks like things are taking a while to load. Try again?
TM + © 2015 Vimeo, LLC. All rights reserved.
Made with k in NYC.
Your content preferences apply to any Vimeo videos you view. Learn more about content preferences in our FAQ.


text:
Want to meet HER today?
Create Your Free Profile
|is a Woman interested in a Man for: Fetish, Groupsex, Sexual relations, Online flirting, Other, Meet in person
Join Fling For Free!
about me
I love the lake, the serenity, the fishing, the cabin. I have three wonderful rescues - a springer, a jack russell doxie mix and a loving cat. They make me laugh, keep me company and love me without pause. Reading makes me happy, wine makes me mellow and the right person can melt my heart. I enjoy fine dining, little gifts that are from the heart, spur of the moment surprises and laughter. Too serious makes me nervous. Sometimes - silly can be a good thing. Financially, emotionally and psychologically sound are musts. Head games and infidelity are deal breakers. I want someone who makes a connection with me. I bring a lot to the table and will expect the same. Old fashioned works for me. True manners, decency and compassion go a long way. My heart will recognize the right person because this won't be about fun and games. I will be the real deal. It's finally time for me to explore a relationship that will be long lasting and I'm excited to learn if Mr. Right is really out there...
about my fling
This user has not filled out this data yet.


text:
((posted by: firstname.lastname@example.com))
MP: This the last Don, can I speak to you for a minute?
NL: What worry you? You got problem? I take care of it, okay?
MP: I hate to puzzle you with this small problem, but, someone in the family
is stealin' from me.
NL: What? Nobody steal from...Da Don.
MP: So, what we go'n do to the nigga?
NL: We make example out of him. We get all my money back and then we bury him
in it.
*church bells ringing*


text:
Peace in the Middle East
In what was widely viewed as a successful trip to the Middle East, Obama reassured Israel, offered support for an independent Palestine and helped resolve a three-year dispute between Turkey and Israel.
(Photo: Uri Lenz-Pool/Getty Images)
BET Wire: Free Eric Holder! 03/27/2015
BET Wire: Loretta Lynch in the Lurch 03/20/2015
Michelle Obama: Buzzing All Over the World 03/20/2015
Eric Holder's Life and Times in the Obama Administration 03/18/2015
BET Wire: Univision Host Compares Michelle Obama to Apes 03/13/2015
The Road to the Voting Rights Act 03/06/2015
Inside the Dept. of Homeland Security's Shutdown Showdown 03/02/2015
BET Wire: Selma Marchers to Receive Congressional Gold Medal 02/27/2015
BET Wire: GOP Throws Sharpton, de Blasio a Shady Diss 02/18/2015
BET Wire: GOP-Led House Knocks Down Obamacare Again 02/06/2015
What's in Obama's 2016 Budget for You? 02/05/2015
BET Wire: Are You Ready for Mayor 2 Chainz? 01/30/2015
Obama's Historic Passage to India 01/26/2015
BET Wire: Obama's State of Play 01/23/2015
Everything You Need to Know About Obama's SOTU Address 01/21/2015
BET Wire: New Year, New Congress 01/09/2015
A Year in the Life of Obama and the Time He Wore That Tiara 12/31/2014
Meet Washington's Newest Black Power Players 12/30/2014
Drama in Obamaland: How 2014 Was a Very Tough Year for POTUS 12/19/2014


text:
March 5, 2014
Paige McCrensky has been named senior vice president of marketing at Martini, a publishing network that targets the affluent market through relationships with niche publishers. She previously held senior marketing positions at Time Inc., Bloomberg and American Express Publishing.
Peter S. Goodman has been named editor in chief at The International Business Times, which is owned by IBT Media, the company that bought Newsweek last year. Goodman was previously executive business editor and global editor at The Huffington Post.
Nerdist Industries, which creates online content, has made two moves, naming Adam Rymer president and Jack Herrguth head of development. Rymer joins from Lava Bear, Herrguth from Comedy Central.
Teen-focused YouTube channel AwesomenessTV has brought in T.J. Marchetti, naming him chief marketing officer. Marchetti is a former senior vice president of digital marketing at Walt Disney Studios.
Peter Oppenheimer, chief financial officer at Apple, is retiring from the company at the end of September. Vice president of finance and corporate controller Luca Maestri will replace Oppenheimer when he leaves.
Ben Davis has been promoted to senior vice president of scripted programming at AMC, reporting to senior vice president of scripted development and current programming Susie Fitzgerald. Davis joined the network in 2005, and he has worked on shows including "Breaking Bad," "Mad Men" and "The Walking Dead."
SundanceTV has made two promotions in its creative services department, naming Mark Williams senior vice president of brand creative and Jessica Gleason vice president of production. Williams has been with the network since 2006, Gleason since 2003.
USA has named Kevin Pereira host of the "Psych After Pshow," a live hour-long special airing after the series finale of "Psych" on March 26. Pereira is a former co-host of G4's "Attack of the Show."
Journalist Jorge Ramos has signed a new deal with cable network Fusion, which will keep him there through the 2016 presidential elections. Ramos currently hosts "American with Jorge Ramos" on the network, which is a joint venture between Univision and ABC News.
TNT has named Ty Pennington host of its upcoming cooking competition series "On the Menu," while Emeril Lagasse will serve as the show's "menu master." The project is executive produced by Mark Burnett.
MTV has named Conan O'Brien host of this year's MTV Movie Awards, which air on April 13. This will be O'Brien's first time hosting the ceremony. He hosted the Primetime Emmys in 2002 and 2006.
Mark Rosenthal has been named chief executive officer at Katz Media Group, in addition to his role as chief executive of Katz Radio Group. The move puts him in charge of the company's TV rep arm, Katz Television Group.
Fox has added two more to the cast of its upcoming Batman prequel "Gotham," David Mazouz and Camren Bicondova. Mazouz will play a preteen Bruce Wayne, while Bicondova will play a teenage orphan who's a thief and pickpocket.
CBS has signed actress Patricia Arquette to star in its latest "CSI" spinoff, which will be set in the FBI's Virginia-based cyber crime division. Arquette's most recent regular TV role was on NBC's "Medium."
Tags: people
Related News
Huge surge for Sweet Sixteen games
Latest forecast for the upfront: Not good
Jon Swallen on the media economy
'The Dovekeepers,' a long four hours
Rachel, the interview did not go well
Tell us, what's the state of late-night TV?
Best bets on TV this weekend 3.27.15
Cable overnights: 'Catfish' hooks a win
Social's share of display ads is on the rise
Apple eyes a foray into streaming music
Alas, it's farewell to 'Downton Abbey'
A lackluster return for 'American Idol'
Programming blog: Latest pickups and cancellations
- Kristi DesJarlais becomes SVP and GM at Saxum
- Jason Wyrick rises to VP of digital platforms at Starz
- Brad Dunn becomes chief digital officer at Athlon Media Group/Parade
- Jazmine Hughes becomes associate digital editor at NY Times Magazine
- Steele Marcoux becomes editor at Coastal Living
- Erantzeri Corona becomes VP of marketing at MoviePass
- Zendaya hosting the Radio Disney Music Awards
- Rex Linn joins the cast of ABC's 'Nashville'
- Chris McDonald replaces James Caan in Fox's 'Fantasy Life'
This week's broadcast ratings
This week's cable ratings
This month's new media traffic data
This week's top movies, songs and books
This week's daypart ratings
This week's younger viewer ratings
Media planner/buyer position in Columbia, SC
Media planner/buyer job in Summit, NJ
Job opening: Next president of TAB
Digital media buyer job in Salt Lake City
TV media buyer wanted in New York