text:
On the afternoon of Wednesday, May 13, Judge Buckwalter postponed the trial scheduled to begin May 18, 2015. It now probably will commence either Wednesday, May 27, or Monday, June 1. We will post the new commencement date once known.
The judge postponed the start of trial because another trial over which he is presiding has continued beyond its expected completion date, preventing him from having adequate time to decide the exact issues to be tried in our case and the scope of the evidence that may be introduced as to those issues. Once he has had the time to make those determinations the trial will be rescheduled.
We apologize to any former employee agents who were planning to attend the trial, and hope that some of you will be able to attend once it is rescheduled.
Reluctantly, we the attorneys have decided that we will not offer representation on an individual basis to any former employee agent who signed the Release and has not already signed a retainer agreement with us. We still hope to represent all or some subgroup of former employee agents as part of a class action concerning the substantive claims. However, the Court's Order of January 6, 2015 states that agents first must invalidate their Release via an individual action.
In deciding not to extend representation to unrepresented employee agents wishing to individually challenge the validity of the Release, we considered many factors, including the impact that a large number of additional clients might have on our existing clients and our ability to represent on an individual basis potentially hundreds or thousands of new clients. Our decision has nothing to do with the merits of any agent's challenge to the validity of the Release.
Our decision not to offer representation on an individual basis to agents whom we do not already represent does not mean that those agents have no recourse if they wish to challenge the validity of the Release and pursue substantive claims against Allstate. Agents can find lawyers throughout the United States who represent employees in lawsuits against employers at www.nela.org. NELA is a national association of plaintiffs' employment lawyers. A lawyer may be more interested in litigating against a large company like Allstate if several agents are willing to be represented jointly. Lawyers also may wish to review the filings on the www.allstatecase.com website, which may facilitate the preparation of necessary legal papers. We believe that agents should look for lawyers who have the resources to maintain potentially lengthy litigation and a record of handling complex litigation.
Remember that the Order of January 6, 2015 states that the statute of limitations on the claim of Release-signers starts running again on March 2, 2015. That does not necessarily mean that any agents' claims expire on March 2, 2015, but it does mean that the limitations "clock" will start ticking once more. Agents should consult with the lawyers that they retain about when any potentially applicable statute of limitations will expire.
As stated in our update of December 22, 2014, Judge Buckwalter conducted a telephonic conference with the lawyers for plaintiffs and Allstate on Tuesday, January 6, in response to our efforts to clarify the impact of his Order of December 11, 2014. Later that day he issued a written Order.
The January 6 Order contains three important rulings:
Approximately 500 former employee agents previously have retained our services to represent them in this litigation. We are currently evaluating how best to protect the interests of these roughly 500 clients. We will communicate with them soon about our plans.
Employee agents who have not retained our firms may wish to consult with a lawyer to evaluate how the Court's Order may impact their rights and whether they wish to take any actions on or before March 2, 2015.
Judge Buckwalter issued today an Order that should relieve pressure to take immediate action in response to his Order of December 11.
He has set a teleconference for January 6, 2015 to discuss the implications of his Order of December 11. Today's Order also stayed any running statute of limitations "pending the Court's January 6, 2015 conference and subsequent ruling on any outstanding issues." This portion of the Order again stopped the running of the statute of limitations, at least until the Judge issues a ruling after the January 6 conference. We are hopeful that the ruling issued after the January 6 conference will provide greater clarity as to the rights of putative class members and the actions (if any) that should be taken to preserve those rights.
We have received two significant rulings from Judge Buckwalter in the past eight days on motions that have been described in prior updates.
First, in our December 9 update, we described a motion we filed asking Judge Buckwalter to clarify that his October 6, 2014 Order denying class certification as to the validity of the Release did not resolve whether class treatment is appropriate on the merits of our substantive claims. The motion sought to confirm that the statutes of limitations applicable to those substantive claims remain tolled for all proposed class members who are not named plaintiffs.
On December 11, 2014, the judge entered an Order ruling on that motion. The meaning and implications of the December 11 Order for putative class members are unclear. The Order first grants the clarification we requested, concluding that "after concluding any currently scheduled trial with respect to Release issues, any party may move for certification . . . with respect to claims or issues involving the merits of Plaintiffs' claims." However, the Order also adds that the October 6 denial of class certification on the Release "restarted the running of the statute of limitations for any current or former employee-agent of Defendants who—between November 10, 1999 and June 30, 2000—signed the Release prepared by Defendants in connection with the Preparing for the Future Group Reorganization Program, and who now wishes to challenge the validity of the Release in order to pursue substantive claims against Defendants that would otherwise be contractually barred."
The Order does not make clear what actions Release signers must take to preserve their rights to challenge the Release and/or pursue their substantive claims and by when those actions must be taken. Under one interpretation – with which we disagree but which Allstate may espouse – the deadline for taking action to challenge the Release in order to preserve age discrimination claims may expire in early January 2015. We intend to seek clarification of this Order from Judge Buckwalter, but may not have any clarification from him by early January.
Employee agents who have not retained our firms should consult with a lawyer promptly to evaluate whether they wish to take any actions before early January, 2015.
Second, in our last three updates we described briefing concerning the structure of the trials on the validity of the Release to commence in May 2015. We are happy to announce that Judge Buckwalter, in a Case Management Order issued December 17, adopted our positions and rejected Allstate's on the various issues. As a result:
Our October 24 update discusses filings by plaintiffs and Allstate concerning the structure of the trials on the validity of the Release. More recently, plaintiffs filed a response to which Allstate then filed a reply. Those issues are now fully briefed. Judge Buckwalter has not yet ruled on the issues in dispute. We will continue to get ready for trial while we wait for the decision.
In the meantime, we filed a motion that asks Judge Buckwalter to clarify that his ruling that we cannot litigate the validity of the Release on a class-wide basis does not address whether we can litigate the merits of the case on a class-wide basis. If the judge agrees with us, we still have the right to seek permission to litigate the merits issues, such as whether Allstate broke its contracts with the agents or violated federal laws, on a class-wide basis. Not surprisingly, Allstate opposes our motion. We filed a reply to Allstate's brief on Monday, December 8. That motion is now fully briefed and ready for a decision by Judge Buckwalter.
We have not heard any further news about the EEOC's appeal of the decision in March dismissing its claim. The Third Circuit Court of Appeals either can issue a decision based on the papers submitted by the parties or can schedule the appeal for oral argument. While we are not directly involved in the EEOC's appeal, we will let you know once we have additional information.
We realize that all of these motions and briefs may be difficult to follow. If you have questions or concerns, please feel free to email or call any of the lawyers working on the case.
In the October 11 update, we mentioned that the parties were required to submit briefs on October 20 concerning the structure of the trials that Judge Buckwalter has scheduled concerning the validity of the Release. While the judge has determined that juries will decide, not on a class basis, whether the Release that the named Plaintiffs signed is valid, he has not resolved questions such as: how many Plaintiffs will testify at each trial? which party will present its evidence first at the trial? will the jury issue a verdict immediately after the testimony is presented as to each Plaintiff or wait until all evidence is presented at a trial before issuing a verdict as to all plaintiffs who testify at that trial? These structural issues are addressed in the briefs presented by Plaintiffs and by Allstate.
We will of course post Judge Buckwalter's decision after it is issued.
The litigation has had several significant developments since our last posting on May 30.
Judge Buckwalter has decided that there will be several trials in which juries will determine whether the Release that the named Plaintiffs signed is valid. He has not yet decided whether each trial will concern eight or ten Plaintiffs. The first trial will start May 18, 2015, and a second trial will commence September 28. The third (and possibly fourth) trials are not yet scheduled. This structure contemplates that there could be a verdict that the Release was valid as to one Plaintiff and invalid as to another, instead of the same verdict for all employee agents. The parties will submit briefs October 20 concerning the structure of these trials.
The reason that the trials concerning the validity of the Release relate only to the named Plaintiffs is that Judge Buckwalter denied our motion to certify a class of approximately 6200 former employee agents to challenge the validity of the Release. Our prior posting contained a link to our initial brief in support of class certification; click on the links to access Allstate's opposition and our reply brief.
In the meantime the EEOC is proceeding with its appeal of Judge Buckwalter's decision in March 2014 that the Release was not illegally retaliatory. The EEOC's has filed its brief to the Third Circuit Court of Appeals and Allstate has filed an opposition. We will post the EEOC's reply brief after it is filed.
Last Friday, May 23, 2014, we filed a motion and supporting documents asking the judge to allow plaintiffs to litigate most of their challenges to the validity of the Release on behalf of the over 6200 employee agents who signed the Release as part of the so-called "Preparing for the Future Group Reorganization Program" in 2000. If the judge grants the motion, the outcome of the trial on the validity of the Release will affect the rights of all of those agents. If the judge "certifies" the class and the jury determines at trial that the Release is invalid, then the ruling will benefit all employee agents. On the other hand, if the jury found against us at trial, then there would be no classwide challenges to the validity of the Release for any class members. There then would be only challenges based on the individual circumstances of each agent.
If the judge grants the motion and a class trial on the validity of the Release occurs, all 6200 employee agents will not have to testify at trial. Instead, we will try to present sufficient evidence to convince the jury that the Release was invalid as to everyone. We believe that only a small number of agents will have to testify at trial.
But if the judge denies our motion and there is thus no class trial on the validity of the Release, the nature of the trial(s) that will occur is unclear. Possibly there would be a series of trials as to the validity of the Release as to each person whom we represent.
Allstate's opposition to our class certification motion is due in late June, and our reply in support of class certification is due in July. We do not know when the judge will rule on the motion, but we realize that this motion is important to many people, and we will post it as soon as received.
Click here to review the motion papers.
Yesterday the New York Times ran an article about the case on the first page of its Business section as well as on its online edition. The article featured quotes from three of the named plaintiffs -- Nathan Littlejohn, Craig Crease and Ron Harper -- and does a good job of making the facts of the case understandable to readers.
Two significant developments occurred in the case last week.
First, Judge Buckwalter issued an Opinion and Order on April 7 on each party's motion for clarification and/or reconsideration of his Order of February 27, 2014. We discussed those motions in our previous two updates for March 17 and April 1.
To summarize, Allstate filed a reconsideration motion that asked the judge to change his February 27 decision dramatically. Allstate re-argued that, supposedly, the federal standards for whether a release of federal rights is "knowing and voluntary" are identical to the state standards for whether a release was signed under duress or as a result of fraud, and that under those standards, the judge should have granted summary judgment to Allstate. Judge Buckwalter rejected every one of Allstate's arguments in denying the motion for reconsideration. He also denied Allstate's motion to provide greater clarity about what information was relevant in determining whether a release was signed knowingly and voluntarily. Finally, he also rejected Allstate's motion that he grant it summary judgment on our contentions that the Release was unconscionable.
Equally important, Judge Buckwalter granted our motion for clarification. He had stated in his February 27 opinion that your employment contracts were terminable at the will of either party by their express terms. If this ruling had applied to the merits of the case, it would have made it far harder to prove our breach-of-contract claims. At our request, he clarified that his statements were not binding on us at the merits stage, and we remained able to try to prove that Allstate breached your employment contracts when it terminated them as part of the Mass Termination Program.
We obviously are very pleased with his rulings.
Second, on April 8 we and the attorneys for Allstate met with Judge Buckwalter to discuss several matters. We had hoped to emerge with a firm date for trial on the validity of the Release. Unfortunately, the Judge concluded that too many issues remained open to schedule a trial, but indicated a desire to have a trial in late fall of this year.
At the conference Judge Buckwalter agreed that we could file a motion to certify a class to challenge the validity of the Release. At this time we will not be moving to certify a class as to the merits of plaintiffs' claims that Allstate breached your employment contracts and violated the Age Discrimination in Employment Act (ADEA) and the Employee Retirement Income Security Act (ERISA) when it terminated your employment contracts.
Although deadline dates still need to be finalized, our motion and supporting materials apparently will be due in mid-May, and the entire briefing process should be completed by the end of June. We intend to post our class certification brief after it is filed.
Opinion on Motions for Clarification and/or Reconsideration
Allstate Agents Litigation
As mentioned in the March 17 update, each side filed a motion for clarification or reconsideration directed at certain aspects of Judge Buckwalter's decision of February 27. Yesterday each side filed its opposition to the other side's motion for clarification or reconsideration. Click here for Plaintiffs' opposition to Allstate's motion, and click here for Allstate's opposition to our motion.
The conference with the judge to establish the dates and parameters for the trial on the validity of the Release occurs on April 8. We will update this website a day or two later with relevant information.
There were four significant developments in the case late last week.
First, as explained in the attached Opinion issued March 13, Judge Buckwalter granted Allstate's motion for summary judgment on the EEOC's claim that the requirement that agents sign the Release was illegally retaliatory, and denied the EEOC's cross-motion. Because this was the EEOC's only claim in the case, the judge ordered that final judgment be issued against the EEOC and its case closed.
The EEOC will have 60 days from March 13 to decide whether to appeal. We will inform you via this website whether it does decide to appeal.
The private plaintiffs will be proceeding with the case even if the EEOC does not appeal. We will try to prove to a jury that the Release was invalid under each of the arguments allowed under Judge Buckwalter's decision of February 27.
Second, we filed on March 13 a motion for clarification or reconsideration of one limited aspect of Judge Buckwalter's decision of February 27. We ask the Judge to clarify that he has not decided for purposes of the merits of the case whether the R830 and R1500 contracts were terminable at will.
Third, Allstate filed its own motion for reconsideration and/or clarification on March 14. It asks Judge Buckwalter to reconsider and/or clarify the legal bases of his ruling of February 27 that there are factual issues as to whether the Release was executed knowingly and voluntarily and whether the Release was unconscionable.
Finally, a status conference is scheduled for Tuesday, April 8, at 4:00 p.m. The trial dates, and presumably other issues related to a trial, presumably will be set at that conference.
Judge Buckwalter issued a detailed, over 150-page ruling concerning the validity of the Release on Thursday, February 27. As part of Allstate's reorganization in 2000, over 6,200 employee agents signed a document, the Release, that purported to waive all of their claims arising out of their employment or the termination of their employment. If the Release is valid, then Plaintiffs who signed the Release do not have viable claims against Allstate arising out of the termination of their employment; if the Release is invalid, all Plaintiffs may attempt to prove that Allstate acted illegally or in violation of its contractual or fiduciary duties when it terminated their employment contracts.
As described in previous postings, each side filed motions for summary judgment concerning the validity of the Release last year. A motion for summary judgment urges the Court to rule based on undisputed facts. Plaintiffs argued that the Release was invalid based on undisputed facts, and Allstate argued that the Release was valid based on undisputed facts.
In the most important portion of his ruling, Judge Buckwalter disagreed with both sides. He concluded that, as to most of Plaintiffs' arguments that the Release was invalid, there were disputed issues of fact. As a result, he denied both sides' motions for summary judgment. This means that there will be a trial before a jury to decide whether the Release is invalid.
Judge Buckwalter's ruling contemplates a conference with the lawyers for both sides to discuss the trial. After that conference occurs we will post information about the trial.
As explained in our most recent update, Plaintiffs filed a motion for summary judgment asking Judge Buckwalter to invalidate the Release that over 6200 employee agents signed as part of the Preparing for the Future Program, while Allstate filed a motion for summary judgment asking him to declare the Release valid. Before the judge could rule on those motions, he had to rule on three related motions that the parties filed. In three separate rulings this month, he ruled on each of these three motions.
Allstate filed a motion to strike the declarations (written statements given under penalty of perjury) of each of the Plaintiffs plus five other witnesses on behalf of the Plaintiffs. The judge denied that motion in an order of December 19. Plaintiffs filed a motion to strike the declaration of one of Allstate's witnesses. The judge similarly denied that motion in an order of December 12.
Finally, Plaintiffs filed a motion for leave to submit a surreply brief concerning one of its arguments for the invalidity of the Release, called the "part and parcel" doctrine, because Allstate did not make its arguments against the part and parcel doctrine until its reply brief, which prevented Plaintiffs from responding to those arguments. Judge Buckwalter granted that motion in an order of December 10 and therefore will consider Plaintiffs' arguments that the Release is invalid under the part and parcel doctrine
We anticipate that Judge Buckwalter's next ruling will be on the validity of the Release. We do not know when he will be ready to issue that ruling in light of the voluminous papers submitted by both parties.
The parties have now filed their opposition and reply memoranda to the motions for summary judgment filed on April 8. This concludes the scheduled briefing on the validity and applicability of the Release that all but about 19 of the roughly 6200 employee agents signed in 2000 as part of the "Preparing for the Future" Group Reorganization Program. As reported earlier, the Romero plaintiffs and the EEOC argued that the Release was invalid, while Allstate argued that the Release was valid.
We do not know when Judge Buckwalter will rule on the motions, or whether he will hold a hearing in which the lawyers can present their arguments orally. The parties together filed hundreds of pages of arguments and proposed facts, and thousands of pages of documents and deposition transcripts. It undoubtedly will take the Judge and his clerks considerable time to review all of the papers, perform any additional legal research that they deem appropriate, and write an opinion. We know that it has been over 13 years since the Program was implemented, but please be patient a little longer.
As mentioned in our prior update, our memoranda and the EEOC's memoranda discuss information that Allstate has designated as confidential. Accordingly, we have not posted the parties' memoranda on this website. But we hope to be able to convince Allstate that information that is 13 years old, or even more dated, is no longer sensitive and may be unsealed. If Allstate agrees, we will make all of the filings available. If you are interested in reading them, please check back on the website from time to time to see if they have been posted.
The parties filed their motions and initial memoranda of law on April 8 concerning the validity and applicability of the Release that all but about 19 of the roughly 6200 employee agents signed in 2000 as part of the "Preparing for the Future" Group Reorganization Program. The Romero plaintiffs and the EEOC argued that the Release was invalid, while Allstate obviously argued that the Release was valid.
The schedule approved by Judge Buckwalter calls for each party to file its response to the other's filing in 45 days (late May) and then a reply in another 45 days (mid-July). That will conclude the briefing on the validity and applicability of the Release, and the parties will wait for Judge Buckwalter to issue a decision.
Our memorandum and the EEOC's memorandum discuss information that Allstate has designated as confidential. Accordingly, we have not posted the parties' memoranda on this website. To provide an idea of the points made in the filings, however, we reproduce on the pleadings page the table of contents from each memorandum: Romero plaintiffs' memorandum, EEOC's memorandum, Allstate's memorandum in Romero cases, and Allstate's memorandum in EEOC's case.
We cannot predict when Judge Buckwalter will issue his ruling, but it is likely to take several months. The filings were voluminous. In addition to our 78 page memorandum, for example, we filed a Statement of Undisputed Facts totaling 162 pages, and exhibits, including declarations (statements under penalty of perjury) from plaintiffs, totaling over 1000 pages. Allstate's filings were likewise voluminous. This is a lot of material for the Judge and his staff to review.
Before the motions were filed, Judge Buckwalter issued rulings on the outstanding motions arising out of the discovery on the Release, which were discussed in our prior update, dated October 17, 2012. The Judge's rulings can be found on the Orders page of the website.
We realize that this litigation was filed over 11 years ago. We are moving it forward as rapidly as we can, and realize that many of the former Allstate employee agents who may benefit from a successful outcome are moving on in years. Indeed, we mourn the loss of three of the original named plaintiffs - Doug Gafner of Wisconsin, Jim Pilchak of Michigan, and Dwight English of Tennessee - who have died during the course of the litigation. We thank you for your continuing interest, and ask for even more patience as the litigation continues.
We also want to take this opportunity to thank each of the named plaintiffs, including the representatives of their three deceased comrades. Most of them have sat through two grueling depositions. They collectively have produced over one hundred thousand pages of paper and electronic documents. They have answered written questions from Allstate. They have participated in numerous telephone calls with us, their lawyers. And throughout it all, not one has dropped out of the litigation. They remain remarkably committed to obtaining justice from Allstate.
Unless Judge Buckwalter orders additional "discovery," the plaintiffs and Allstate now have completed their discovery concerning the validity of the Release.
As explained in prior entries, discovery is the process by which lawyers can obtain information from the opposing party about facts relevant to the issues in a case. During the past two years, the parties have engaged in about 40 days of depositions, produced hundreds of thousands of pages of documents or electronic images, and devoted hundreds if not thousands of pages to answering interrogatories (written questions) and responding to requests for admission. This has meant a tremendous amount of work for the plaintiffs, for Allstate, and for the lawyers on both sides. The last deposition occurred in late July.
August 13 was the deadline for both sides to file any final motions arising out of the discovery disputes that arose along the way (as reported in prior updates, plaintiffs already filed and Judge Buckwalter already had ruled on several motions contending that Allstate had violated its discovery obligations). We filed two motions.
First, we filed a motion for entry of a spoliation inference. In that motion, we claim that Allstate permitted or caused a large number of relevant documents concerning the origination and implementation of the so-called Preparing for the Future Group Reorganization Program (the "Mass Termination Program") to be destroyed, and ask the Court to impose as a sanction the inference that the documents would have favored plaintiffs' position on the validity of the Release. We contend that Allstate reasonably should have anticipated litigation arising from the Mass Termination Program no later than June 1999, that Allstate's duty to preserve documents started at that time, and that necessary preservation instructions were not given. We also identify for the Court numerous relevant activities and numerous key employees for which Allstate failed to produce documents. Allstate's response, filed about a week ago, is that it did not anticipate litigation until February 2000, that it took appropriate steps to preserve documents promptly after then, and that we cannot identify how we were prejudiced by any documents that were lost.
Next, we filed a motion for sanctions or to compel testimony from three of Allstate's witnesses. These witnesses testified under a procedural rule that required Allstate to educate the witnesses with all of the information about certain designated topics reasonably available to the company. We contend that Allstate did not adequately prepare these witnesses so that they did not know the answers to numerous questions within the scope of the designated topics. In addition, one of the witnesses was obstructionist and another often read from a script prepared by his lawyers. In the motion, we ask Judge Buckwalter to impose as a sanction that Allstate is bound by the witnesses' lack of knowledge: Allstate will be deemed not to know any more than the witnesses did when they testified they did not know. Alternatively, we ask Judge Buckwalter to order the witnesses to be redeposed at Allstate's expense, and to give us more time to complete the questioning of one of the witnesses (Barry Hutton). Not surprisingly, Allstate contends that the witnesses were adequately prepared and not obstructionist.
Briefing on the motion for sanctions is now complete, and briefing on the motion for entry of a spoliation inference will conclude next Monday, October 22.
Allstate also filed two motions for which the briefing is already complete. First, it filed a motion to compel claiming that plaintiffs violated their duties by generally limiting the production of hard copy documents in response to Allstate's requests to documents dated no later than December 31, 2002. We contend that the parties agreed to the 2002 cutoff and that, even if there was no agreement about the cutoff date (as Allstate argues), Allstate should have raised this issue long ago. In its second motion, Allstate seeks leave to amend admissions that it made earlier in the case. Previously it had admitted that it had not instructed five key witnesses, including Ed Liddy, to preserve documents by May 1, 2000; now it wants to assert that it had instructed them to preserve documents, even though it has failed to produce any responsive documents from four of the five witnesses and even though Mr. Liddy separately admitted that he was not instructed.
The case is likely to be relatively quiet until after Judge Buckwalter rules on the four motions. We will post his decisions after they are received, which we do not anticipate until late 2012 or early 2013.
The scheduling order governing this case provides that the parties will file and brief motions for partial summary judgment motion concerning the validity of the Release within 45 days after the Judge rules on the discovery motions. All but about 19 of the over 6,200 agents (and all but one of the named plaintiffs) signed the Release as part of the Mass Termination Program. The ruling on the validity of the Release thus is very important to the plaintiffs and other employee agents.
Last week, Judge Buckwalter issued Orders on both of the pending discovery motions, which were described in the update of December 12, 2011.
In one of the pending motions, we asked Judge Buckwalter to order Allstate to answer properly our requests for admission concerning its preservation of email and other electronic documents. Allstate refused to answer most of the requests on a variety of bases, two of which were primary. First, it objected to many of the requests on the ground that they related to the Mass Termination Program instead of only to the validity of the Release, the issue that is the focus of the current round of discovery. Second, it objected to our request that it address the company's efforts to preserve the documents of each custodian (the person to whose account an electronic document was stored), contending that it should have to respond only as to the custodian's efforts to preserve his or her own documents.
As you will see, the judge agreed with us completely on the first issue, stating that our document preservation requests properly related to documents concerning the entire Program, not just the Release. On the second issue, the judge reached a compromise. Allstate needs to answer as to the efforts of the IT and Legal Departments, but not necessarily all of Allstate. The judge gave Allstate 20 days in which to answer the requests for admission properly. Click here (Order on Motion to Compel) to review Judge Buckwalter's Order on the requests to admit.
In the other pending motion, Allstate asked the judge for a protective order to limit the scope of a deposition that we intend to take. Again, the principal dispute was over whether topics had to be limited to "the Release," or whether they could concern "the Program." Judge Buckwalter looked at each topic individually. On the great majority of topics, he agreed with us; on a few, he thought our topics went too far and addressed the merits rather than the validity of the Release. In a few instances, he limited the temporal scope of the topics. Click here (Order on Motion for Protective Order) to review Judge Buckwalter's Order on the deposition.
We are gratified by both of these Orders, and hope that these two rulings will cause Allstate to alter its position on other pending disputes, allowing our discovery to move forward with fewer objections.
In the meantime, Allstate is deposing our plaintiffs. We expect that the next two months will be filled with discovery from both sides concerning the validity of the Release. We will update this site again when we have additional information to share about the progress of the discovery.
For the past year, the parties have been engaged in vigorous "discovery" concerning the validity of the Release. Discovery is the process by which each side in a civil lawsuit obtains information from the other. In response to Plaintiffs' discovery, Allstate has produced thousands of pages of documents to Plaintiffs (although Plaintiffs believe the production to be grossly inadequate), answered written questions, and responded to Plaintiffs' requests for admission. Similarly, Plaintiffs have produced many thousands of pages of documents to Allstate, answered Allstate's written questions, and responded to Allstate's requests for admission.
Of course, Allstate has resisted a substantial portion of Plaintiffs' discovery. There are two motions pending before the Court concerning Plaintiffs' discovery: Plaintiffs' motion challenging the adequacy of Allstate's responses to Plaintiffs' discovery, and Allstate's motion for a protective order to limit the topics about which Plaintiffs may inquire during an upcoming deposition. Click here for the Plaintiffs' Challenging Sufficiency of Allstate's Responses. Click here for Allstate's Motion for a Protective Order. It seems unlikely that Judge Buckwalter will decide the motions until early 2012.
While the parties wait for those decisions, they will move forward with depositions. During depositions, the parties can question the opposing parties or other witnesses outside the presence of the judge. The questions and answers are transcribed by a court reporter, and can in appropriate circumstances be used as evidence in subsequent proceedings in the case. We expect the depositions to last into early 2012 as well.
The discovery process, including the resolution of the parties' disputes, is taking longer than we had anticipated when the process started. Our best estimate now is that our motion challenging the validity of the Release will not be filed until late spring of 2012.
Although this delay is frustrating to Plaintiffs, we wish to assure everyone that the Plaintiffs and their lawyers are working as hard as they can to achieve a successful result in the case as quickly as possible.
In an opinion issued last week, Judge Buckwalter denied the motion of Allstate's former CEO Edward Liddy to be dismissed from the case. As discussed in our updates of August 27, September 14 and October 5, plaintiffs are suing Mr. Liddy for violating ERISA section 510, which prohibits any person from taking an adverse employment action against a participant in an employee benefit plan for the purpose of preventing the participant from accruing additional benefits. Mr. Liddy principally argued that the word "person" under ERISA did not include corporate officers, so that he could not be liable under that statute. Judge Buckwalter rejected that argument, and Mr. Liddy will remain in the case.
Yesterday Judge Buckwalter issued an opinion and order on plaintiffs' motion to compel. As described in our update of September 14, 2010, several months ago we served a series of requests to produce documents, Allstate refused to produce documents in response to most of the requests, and we asked Judge Buckwalter to order Allstate to produce the documents (a "motion to compel"). As his opinion makes clear, Judge Buckwalter agreed with us on almost every issue. He ordered Allstate to produce all of the requested documents and to cooperate with us in agreeing on the parameters to be used in searching for relevant documents maintained electronically, such as emails.
Also as described in our update of September 28, Allstate has refused to answer most of our written questions, called interrogatories. In response to our motion to compel responses to those interrogatories, Allstate filed a motion to stay briefing until after a decision had been issued on the motion to compel production of documents. In a brief order, Judge Buckwalter agreed that Allstate did not need to respond to our motion to compel responses to interrogatories until after the motion to stay was decided. We are hopeful, however, that his decision on the motion to compel production of documents will lead to a resolution of the dispute over the responses to our interrogatories.
Yesterday Edward Liddy, Allstate's former CEO, filed his reply brief in support of his motion to dismiss the claims against him. As we explained in earlier updates, some statutes and common law principles allow employees to sue only their employer (Allstate), while others also allow suits against executives who were involved in the decision-making. Age discrimination and breach of contract claims only permit claims against employers. We believe that the claims we brought against Mr. Liddy under the federal statute that protects employee benefits allow claims against corporate officers, while he argues that it does not. To make his argument, Mr. Liddy must contend that he is not a "person" within the meaning of the law, an argument that, we believe, strains credulity.
Plaintiffs yesterday filed a motion to compel answers to the interrogatories that they served on Allstate several months ago. Click here to review a copy of plaintiffs' brief in support of their motion.
Interrogatories are written questions to be answered by a party. Here, because discovery is focused on the validity of the Release, the interrogatories were designed to obtain information relevant to the validity of the Release or to lead plaintiffs to sources of relevant information about the Release, such as the names of persons with knowledge of various issues related to the Release. Allstate answered only the first interrogatory, including its subparts, and refused to answer the other interrogatories. Primarily, it contends that there were too many interrogatories (counting the various subparts as separate interrogatories) or that the requested information was not relevant to the validity of the Release. Obviously, we disagree strongly. Allstate will have 21 days to file their opposition brief, and plaintiffs then will have 14 days to file a reply brief.
The other motions described in the August 27 and September 14 updates are still pending.
Plaintiffs yesterday filed their Opposition to Mr. Liddy's Motion to Dismiss. As noted in our August 27 update, Mr. Liddy is arguing that he cannot be sued for acts committed while a corporate officer. As you will see from reading the brief, we believe that Judge Fullam rejected the same argument over eight years ago and that Mr. Liddy is in effect seeking reconsideration of that ruling without any proper basis. But if Judge Buckwalter does choose to reconsider the issue of whether plaintiffs have stated a claim against Mr. Liddy, we show in the brief that the language of the Employee Retirement Income Security Act ("ERISA"), the statute under which plaintiffs have brought suit, expressly allows suit against Mr. Liddy or any other "individual," and there is no exception for corporate officers.
Also pending, and not mentioned in our earlier posts, is plaintiffs' motion to compel Allstate to produce documents that plaintiffs have requested. Plaintiffs' opening brief, defendants' opposition, and plaintiffs' reply can be read by clicking here or by opening the Pleadings page. We believe that the Court of Appeals has already indicated that we should have access to all of the requested documents, and that those documents are likely to be important for us to make the strongest possible arguments that the Release is invalid.
The Allstate defendants today filed their Answer and Affirmative Defenses to Plaintiffs' Second Amended Complaint. In an answer, a defendant states whether it admits or denies each of the allegations in a complaint. Not surprisingly, Allstate denies most of the allegations in the Second Amended Complaint. In the affirmative defenses, a defendant identifies reasons why it contends it should prevail even if some or all of the facts alleged in a complaint are true. Plaintiffs do not have to respond to the answer, but may, if they choose, file a motion challenging some of the affirmative defenses.
At the same time, Edward Liddy filed a Motion to Dismiss. As a matter of law, an individual can be held liable for some types of actions committed as a corporate officer but not for others. Mr. Liddy contends that a corporate officer, such as a CEO, cannot be liable under the laws that form the basis of plaintiffs' claims. We intend to file a brief opposing his arguments.
Meanwhile, the parties continue to be engaged in the discovery process concerning the validity of the Release signed by almost all employee agents in 2000. As significant developments occur in that process, we will post updates.
Judge Buckwalter today issued a decision permitting plaintiffs to file a Second Amended Complaint. To review a copy of the decision, click here.
Allstate had opposed plaintiffs' motion, arguing that plaintiffs should not be allowed to claim (a) that Allstate made a series of misrepresentation that made plaintiffs' execution of the Release not "knowing", thereby invalidating the Release, and (b) that the termination of agents' employment contracts had an adverse impact on older agents that was illegal under the Age Discrimination in Employment Act. Judge Buckwalter reasoned that the plaintiffs had adequate reasons not to have made those allegations earlier in the case and that Allstate was not prejudiced by any delay in asserting those arguments.
As directed by the United States Court of Appeals for the Third Circuit, the matters pending before Judge Fullam since 2001 were reassigned to the Honorable Ronald Buckwalter in January 2010. This includes the following cases:
Romero I, No 01-CV-3894, which challenges certain aspects of the Preparing for the Future Group Reorganization Program (Program) announced in November 1999, including (a) the validity of the General Release and Waiver Agreement (Release), (b) the termination of the R830 and R1500 contracts under which employee agents were hired and worked, and (c) Allstate's interference with pension and other employee benefits;
Romero II, No. 01-CV-6764, which challenges certain amendments to the Agents Pension Plan and alleged misrepresentations relating to eligibility for early retirement and other pension benefits; and
EEOC v. Allstate Insurance Company, No. 01-CV-7042, which challenges the validity of the Release under the Age Discrimination in Employment Act (ADEA), the Civil Rights Act of 1964 (Title VII), and the Americans with Disabilities Act (ADA).
Judge Buckwalter is an experienced jurist who has sat on the District Court for two decades.
At the Court's request, the attorneys for the respective parties met for a status conference on February 14, 2010, at which time Judge Buckwalter made clear that he would follow the mandate of the Court of Appeals and limit "merits" discovery to issues relating to the validity of the Release executed by nearly all of the 6,200 employee agents whose employment contracts were terminated as part of the Program. The parties subsequently were able to negotiate a proposed form of case management protocol under which certain issues relating to the validity and applicability of the Release can be decided by the Court. This will be presented to Judge Buckwalter so that it can be entered as an order of the Court. Plaintiffs already have provided Allstate with a copy of the discovery requests that will be served upon entry of the order.
We are pleased Judge Buckwalter has indicated a willingness to meet with the parties as frequently as necessary to ensure that progress can be made in these long-delayed cases.
We will continue to update this website as developments occur.
On July 29, 2009, the United States Court of Appeals for the Third Circuit issued a per curium (unanimous) opinion in which it vacated Judge Fullam's ruling of June 20, 2007, by which he had dismissed all of the claims that had been asserted in the Romero and EEOC cases, and directed that, upon remand to the trial court, the case be reassigned. While the Third Circuit's opinion did not resolve many legal issues that were before it on appeal, including the merits of the ADEA, ERISA, and breach of contract claims the Romero plaintiffs have brought against former Allstate CEO Edward Liddy, The Allstate Corporation, and Allstate Insurance Company or the retaliation claims the EEOC has brought against Allstate Insurance Company, it found that the Romero plaintiffs are, at minimum, entitled to discovery concerning the validity of the General Release and Waiver Agreement that all but a handful of the 6,200 terminated employee agents were required to execute. The Third Circuit noted in this regard that if the newly-assigned district court judge determines that the Release is not valid, the trial court will need to address all of the claims that have been raised by the Romero plaintiffs, including the breach of contract and breach of fiduciary duty claims, as well as the "cutback" and misrepresentation claims asserted in Romero II.
The Court of Appeals additionally remanded the age discrimination and ERISA benefit claims asserted in Romero I so that the district court can determine whether plaintiffs were provided with sufficient discovery relating to those claims.
Finally, with respect to the Romero II claims, the Court of Appeals agreed with the Romero plaintiffs that the Scott and Swain decisions are not dispositive and those claims can move forward in the district court.
The Romero plaintiffs are pleased that the Third Circuit has vacated the case for further proceedings and look forward to arguing the merits of each of their claims to a new trial judge after being afforded the discovery to which they are entitled.
The parties appeared today before the United States Court of Appeals for the Third Circuit in Philadelphia to argue issues relating to Judge Fullam's ruling that dismissed the Romero I, Romero II, and EEOC lawsuits in June 2007. The Romero plaintiffs appreciate that they were afforded the opportunity to appear before the Court, and are encouraged that each of the three judges sitting on the panel had devoted substantial time familiarizing themselves with the facts of the case. No ruling is expected for at least several months. In the meantime. however, a transcript of the argument will be posted here by April 10, 2009.
Today, the Romero plaintiffs and EEOC each filed briefs in connection with the appeals taken from Judge Fullam's decision of June 20, 2007, which granted summary judgment in favor of Allstate. Copies of the briefs can be downloaded by clicking here and here. Allstate will file its opposition within 30 days.
On June 20, 2007, the United States District Court for the Eastern District of Pennsylvania issued an order reversing its earlier ruling of March 30, 2004, in which it had concluded the Release and Waiver Agreement that Allstate required employee agents to sign as part of the "Preparing for the Future" Group Reorganization Program was retaliatory and in violation of applicable federal law and could be voided at the option of each employee agent who signed the Release. In addition to vacating its ruling concerning the validity of the Release, the District Court adopted the "tentative conclusions" set forth in its order dated March 21, 2007 (which is discussed below) and, as a result, granted summary judgment in favor of Allstate as to the discrimination and retaliation claims asserted by the plaintiff employee agents under the Age Discrimination in Employment Act and Employee Retirement Income Security Act. Finally, the District Court indicated its intention to close the case files.
Plaintiffs, together with the United States Equal Employment Opportunity Commission, have taken an appeal from the District Court's ruling and, in accordance with the scheduling order issued by the United States Court of Appeals for the Third Circuit will be filing briefs with the Court of Appeals by June 2, 2008. Allstate will have to file responsive briefs within 30 days. Copies of the parties' briefs will be posted after they are filed.
The proposed class action lawsuit brought by 29 plaintiffs, known as Romero I, seeks to recover pension, medical and other benefits estimated in the hundreds of millions of dollars, as well as compensatory and punitive damages and other relief, on behalf of about 6,200 current and former Allstate agents. The plaintiffs have alleged that the company betrayed its long-time "captive" employee agents by wrongfully terminating their employment contracts in order to deny them pension and other employee benefits and to rid itself of thousands of older employees. The suit claims that Allstate's actions taken as part of the "Preparing for the Future" Group Reorganization Program violated the Employee Retirement Income Security Act ("ERISA"), the Age Discrimination in Employment Act ("ADEA"), and Allstate's contractual and fiduciary duties. The plaintiffs also allege that Allstate wrongfully refused to rehire any of the terminated employee agents for a period of one year to reduce retirement benefits that former agents could earn in the future.
The U.S. Equal Employment Opportunity Commission has filed two lawsuits against Allstate on behalf of affected agents. The first, filed in December 2001, alleges that Allstate violated the anti-retaliation provisions of the ADEA, Title VII of the Civil Rights Act and the Americans with Disabilities Act by forcing its employee agents to sign a release and waiver that the EEOC previously determined to be unlawful. The EEOC's lawsuit has been consolidated with Romero I. The second lawsuit, filed in October 2004, alleges that the one-year "rehiring moratorium" adopted by Allstate constituted a pattern and practice of unlawful age discrimination. According to the EEOC, the refusal to rehire employee agents had the intended effect of depriving individuals of the ability to continue to accrue the substantial pension and other benefits to which they had been entitled without a "break in service."
On March 30, 2004, Senior District Judge John Fullam granted partial summary judgment in favor of plaintiffs in Romero I, holding that the release violated the ADEA because it barred the filing of "charges," including challenges to the validity of the release. As Judge Fullam observed, "we have no way of knowing how many other employee-agents failed to pursue charges before the EEOC simply because they accepted the release language at face value." The Court held further that Allstate had engaged in unlawful retaliation under the ADEA, Title VII and other laws in order to prevent agents from exercising their federally-protected rights. As part of its ruling, however, the Court concluded, based on the limited record before it, that there was "no basis" for plaintiffs' age discrimination claims. Although the Court did not actually dismiss the ADEA claims, it held that agents who desire to have the release invalidated and pursue claims for damages or other relief would first have to repay or "tender back" to Allstate "any and all benefits received by the signer in exchange for the release."
Plaintiffs filed a motion in April 2004 asking the Court to reconsider the "tender back" requirement. The EEOC also filed its own motion asking that the Court clarify its ruling.
In December 2005, Allstate filed a summary judgment motion asking the Court not only to reconsider its March 2004 decision and reverse itself by upholding the release. Allstate also is asking the Court to dismiss the claims the Romero plaintiffs are prosecuting under the ADEA and ERISA, including the claim that the release constitutes unlawful retaliation. CEO Liddy has joined in the request for summary judgment. Plaintiffs and the EEOC have opposed the motion on numerous grounds. In a 48-page brief filed with the Court under seal, plaintiffs lay out the reasons that Allstate is not entitled to seek reconsideration of the March 2004 ruling at this late date and, in any event, is not entitled to dismissal of the ADEA and ERISA claims or, indeed, any of their claims as a matter of law. In further support of their arguments, plaintiffs note, among other things, that they have not been able to undertake "merits" discovery because of Allstate's unjustified refusal to produce documents responsive to their discovery requests. Plaintiffs therefore have requested that the Court deny the motions for summary judgment and that it instead grant the relief requested with respect to the "tender back" requirement in the motions that have been pending since April 2004.
Judge Fullam has denied plaintiffs' motion for reconsideration and, in a ruling dated March 21, 2007, advised the parties that he has reached a number of tentative conclusions in this case, the EEOC case and Romero II. As set forth in the memorandum opinion issued by the Court, Judge Fullam stated that he had concluded that his March 2004 ruling was "in error" insofar as he found that the Release was voidable and, in light of other tentative conclusions set forth in his ruling, that "the validity of the release has become moot." With respect to the other tentative conclusions, Judge Fullam stated that a 2005 decision issued by a United States Court of Appeals in Isbell v. Allstate Ins. Co. "warrants the conclusion that plaintiffs' claims of ERISA violations, age discrimination and retaliation must fail." It therefore appears t


text:
Funcom Illuminatis Slight Secret World Delay
Did John's latest glimpse into The Secret World entice you? Did it make you (skeptically) ponder the possibilities of an MMO with diabolical puzzles and authentic female characters that finally offset the catastrophic damage Tera did to the balance of the universe? Well then, you might want to sit down. Ah, you're already sitting. Well then, I give you permission to eat a cookie or something ' even if you're on a diet. But just one, because honestly, this isn't that big of a deal. The Secret World, you see, has been delayed. By a couple weeks. And you're getting more beta weekends. Actually, you know what? Give me back that cookie.
http://feeds.feedburner.com/~ff/Rock...?d=nQ_hWtDbxek http://feeds.feedburner.com/~ff/Rock...?d=yIl2AUoC8zA
|All times are GMT -5. The time now is 05:35 PM.
Powered by vBulletin® Version 3.7.1
Copyright ©2000 - 2015, Jelsoft Enterprises Ltd.
Copyright ©1998 - 2014, nV News.

subset: commoncrawl


text:
Specialty - Oily
Redness Relief PowderVisibly reduce skin's surface redness with soothing ingredients like Honey Suckle, Zinc Oxide and Caffeine. Redness Relief Powder is ideal for even the most sensitive skin.$28.00
Remedy GelRelieves skin inflammation. Calms, soothes and heals the skin...$22.00
Healing GelHelps reduce breakout redness and irritation while allowing skin...$33.00
Clear Complexion PadsGently breaks down excess sebum, immediately balancing oily skin and helping prevent the growth of acne-causing bacteria.$37.00
Clear Anti-Blemish TreatmentBattles breakouts at the root to eliminate current blemishes and...$36.00


text:
Nothing Changes Brought Merzbow, Prurient, and Raw Sound Transgression to Red Bull Music Academy
Photos from the massive noise and experimental music event, starring Japanese noise legend Merzbow. Full Story
Mohawks, Heavy Chains, and Lots of Studs: Photos from New York's Alright 2015
Four plus days of mayhem, stage dives, nudity, stick-n-pokes, and some of the best punk rock in the world. Possibly NSFW. Full Story
Shirtlessness, Dogpiles, and Gang Vocals Galore: Damaged City 2015 in Pictures
Photos from the DC festival featuring Career Suicide, Government Warning, Excruciating Terror and more Full Story
New York Belongs to Me: Cock Sparrer Returns to Play Two Rare Stateside Shows
Check out photos from the band's first NYC shows in 15 years! Full Story
Melbourne's Shittiest Dive Bar is Closing and We Are Devo'd
The Liberty Social was home to club kids, goths and freaks. It will be sorely missed. Full Story
The Scenes of Vice's 20th Birthday Bash: Wu Tang, Weezy, and More!
We celebrated with Lil Wayne, Pussy Riot, Jonah Hill, and Andrew W.K. Full Story
Check These Photos of Cuntz Across America
Last year Melbourne band Cuntz toured across the United States. Here is some photographic evidence of their shenanigans. Full Story
We Went to the Bermuda Triangle to Celebrate Halloween and See Kendrick Lamar
What happens in Puerto Rico. Stays in Puerto Rico. Full Story
Danny Clinch Knows How to Photograph Your Favorite Rapper
See some select photos from the photographer's new book 'Danny Clinch: Still Moving.' Full Story
Mineral, Frank Turner, and Into It. Over It. Played Saint Vitus Last Night and There Were Feelings
No shut up YOU'RE crying shut up. Full Story
The Gaslight Anthem Played CBGB Last Night, Kinda
It's a John Varvatos store now but whatever, they still dropped by unannounced and played. Full Story
Welcome to the World of Hungarian Psychedelia, Raves, and Circus Sideshows known as O.Z.O.R.A.
A wild world, in the middle of the Hungarian countryside Full Story
Check Out Photos From the Making of Team Spirit's "Teenage Heart" Video
It's all about a trip to the doctor's gone wrong. Full Story
Check Out These Awesome Old Photos of Saint Etienne
These photos from a recently released book capture the band's heyday. Full Story
Richard Corman Took These Photos of Madonna Back When Nobody Knew Who She Was
In 1983, the future pop star was doing the smurf on the roofs of the Lower East Side. Full Story
Yes, This Happened: Photos of Nirvana Playing at Saint Vitus in Brooklyn
With appearances by Kim Gordon, J. Mascis, and more. Full Story
Cocaine Cowboys: See Outtakes of Our Cover Story with Freddie Gibbs and Madlib
"Everything is music to me," Madlib says. "In my sleep I'm thinking music." Full Story
Bob Casale of DEVO (RIP) Celebrated In Rare Photo Set
His life with DEVO celebrated in this rare set Full Story
Charli XCX is Better Than You at Being in Photos
She's just spent some time in Brazil playing shows and taking photos for us. Full Story
A For Effort, V For Victory: A389's 10th Anniversary Bash
A389 Anniversary returns, heavy on nostalgia please. Full Story


text:
Actor Anthony Mackie was convicted late last week of driving while impaired in New York City. The Black or White
Arletha Alexander, 46, was performing a head-bobbing move on Mario Espinal, 33, that would get her turned away at the
In honor of Prince's 56th birthday today, we've put together a list of five facts that even the most avid
Another chapter has been added to the "Police Gone Wild" news that seems to be sweeping the country. This time
A report released by a Washington organization that researches the effects and toll of gun violence found that Nebraska has
R. Kelly fans in Monroe, Louisana are are upset after a supposed Kelly concert that they claim featured an impersonator
It's impossible to ignore rising rap renegade CeddyBu. And it will be just as hard to take your eyes off
Six-year-old, Ahlittia North, who was missing last week was found dead in a dumpster. Her body was found this week near
The United States is in the midst of an obesity epidemic. More than 35 percent of adults and almost
Winnsboro, La. police have confirmed that the woman burned alive was attacked by three men wearing white hoodies at a
"Another person exited that trailer with an assault weapon and ambushed our officers."
Beautiful women from all over head to Essence, and cheating men plot to get them.
Louisiana State District Judge Tony Marabella sentenced Michael Tyler, aka Mystikal, to three months behind bars after the rapper was
These 20 states have the highest populations of Black men who sleep with men.
For Sisters Only 2011 kicked off proper here in Atlanta at the Georgia World Congress Center with V103's Frank and
Singer Trey Songz is no stranger to belting out hits and, now, the R&B heartthrob is gearing up to stretch
Across America, many historically black colleges and universities are having a rough time making it. The most recent added to
Along both sides of the largest River in the United States, residents are bracing for floods not seen since 1927.


text:
News from WTOP
News from the AP
Mike Causey
Shows & Panels
Shows & Panels
- Agency of the Month
- Business of Government Hour
- The CFO Agenda: Delivering value from financial transparency and audit efforts in the public and private sector
- Cloud-Driven Data Insights in Government
- CXO Surveys
- Disaster Resilience for America
- Federal News Countdown
- Government Perspectives on Mobility and the Cloud
- Reducing Risk in the Cloud
- Reimagining the Next Generation of Government
Shows & Panels
- AFCEA Answers
- American Readiness: Renewable Power and Efficiency Technologies
- Ask the CIO
- The Business Case for Cloud Computing in Government
- Cloud-Driven Data Insights in Government
- Connecting the Dots: Digital Authentication in Government
- Data-Centric Approaches to Government in the Cloud
- Delivering the Digital Government Mission
- Federal Executive Forum
- Federal News Radio's National Cyber Security Awareness Month Special Panel Discussion
- Federal Tech Talk
- The Future of Government Data Centers
- Government Perspectives on Mobility and the Cloud
- Industrialized, Interoperable and Insight-driven Federal Health Panel
- Innovation and Tech Superiority through Acquisition Reform
- Mitigating Insider Threats in Virtual & Cloud Environments
- Moving Agency Applications to the Cloud with PaaS
- Reducing Risk in the Cloud
- Security in the Age of Targeted Attacks
- Air Traffic Management Transformation Report
- The Business of Cloud
- Cloud First Report
- Data Driven Cloud Series
- Disaster Resilience for America
- General Dynamics IT Enterprise Center
- Gov Cloud Minute
- Government in Technology Series
- Homeland Security Cybersecurity Market Report
- The Intersection: Where Technology Meets Transformation
- Modern Mission Critical Series
- National Cybersecurity Awareness Month
- The New IP for Federal IT
- The Social Platform Solution for the Department of Veterans Affairs
- Technology Insights
- The Cyber Security Report
- The Next Generation Cyber Security Experts
Shows & Panels
- Cloud-Driven Data Insights in Government
- Disaster Resilience for America
- F-35 Lightning II Program
- Government Perspectives on Mobility and the Cloud
- On DoD
- Pentagon Solutions
- Reducing Risk in the Cloud
- Reimagining the Next Generation of Government
- Transforming Business Operations at the Defense Department
Correction: Prisoner Escape-Texas story
Wednesday - 2/13/2013, 4:34pm EST
MIAMI (AP) -- In a Feb. 12 story about the escape near Dallas of a prisoner being transferred from Florida to Nevada, The Associated Press erroneously reported that a plane he was transported on landed in Dallas. The plane landed in Houston, and he escaped after detectives decided to drive him the rest of the way.
A corrected version of the story is below:
Sex offender inmate stabs officer, flees in Texas
Convicted sex offender stabs officer, escapes in Texas during transport from Fla. to Nev.
By KELLI KENNEDY and KEN RITTER
Associated Press
MIAMI (AP) -- A manhunt is under way for a prisoner convicted of violent sexual assaults who stabbed one of two police escorts and escaped in the Dallas area as he was being transferred from Florida to Nevada, police said Tuesday.
Alberto Morales, 42, stabbed the officer once in the neck and three times in the back Monday night outside a Walmart in Grapevine, police said. Grapevine Police Sgt. Robert Eberling said Morales is believed to have used his eyeglasses in the assault.
Miami-Dade Police Detective Jaime Pardinas, a 54-year-old who has been on the force for 28 years, is in serious but stable condition.
Pardinas and Detective David Carrero were scheduled to fly with Morales to Nevada, where he was to serve a sentence of 30 years to life for a conviction of sexual assault with a weapon. But the officers and Morales weren't allowed to get back on the plane during a layover in Houston because of the inmate's erratic behavior, authorities said.
During the first leg of the flight, Morales was "bumping his head against a passenger seat in front of him, so he was doing a lot of crazy, unusual things that just disrupted the entire flight," said Miami-Dade Police Director J.D. Patterson Jr.
Miami-Dade Police Deputy Director Juan Perez said that it is out of the ordinary, but that airlines occasionally ask officers and their escorted inmates to leave because of liability issues.
The detectives then rented a vehicle and drove to the Dallas area, where they were to meet up with a third officer flying in to join them for the nearly 1,200-mile ride to their Nevada destination. Miami police said there are clear policies about transporting inmates across state lines, but didn't discuss details other than to say three officers must be present for ground transport.
The two officers stopped to use the restroom at the store late Monday, and while Carrero was inside, Morales got hold of a sharp object, stabbed Pardinas and fled, authorities said.
"He was handcuffed. We don't know how he got the handcuffs free," Patterson said.
It's unclear if Morales' hands were cuffed in front or behind him or if he was shackled. Miami police also declined to speculate on how Morales obtained the object he used to stab the officer. Morales, who was born in Cuba, is believed to have run away.
Police in Grapevine, northwest of Dallas, said they believe Morales is still on foot somewhere nearby and are pursuing several leads, department spokesman Sgt. Robert Eberling said. A $10,000 reward has been set for any information leading to his arrest. The local school district has locked all exterior doors, but classes were running normally.
Longtime Las Vegas defense attorney Marc Saggese, who represented Morales in a Nevada criminal case, said his client claimed he suffered a severe brain injury when he was hit in the head with a baseball bat at 17 years old. Morales said he heard voices and had trouble controlling impulses.
"He said that ever since that attack and subsequent surgeries he has been struggling with demons in his head," Saggese said.
While in a jail medical ward, Morales mutilated his genitals and scrawled words in blood on the wall. He underwent a psychological examination by doctors at a Nevada state mental hospital in Sparks, but he was found competent to stand trial, the attorney said.
Morales eventually pleaded guilty in 2008 to sexually assaulting a woman at an apartment blocks away from the Las Vegas Strip in 2003. The woman told police a man jumped from her closet in the middle of the night, held a gun to her face, blindfolded her, attacked her several times and left after telling her he would kill her if she called police, according to Clark County District Court documents.
Following his conviction in Las Vegas, Morales was sent to Florida to face prior charges, Las Vegas police Officer Laura Meltzer said.
Back in Miami, Morales was sentenced to 10 years in prison in December after pleading guilty to sexual battery with a deadly weapon, burglary with assault and kidnapping stemming from 2003. He broke into a Miami-area home, pulled out a butcher knife and raped two women, according to a police report.
Ritter reported from Las Vegas.
Follow Kelli Kennedy on Twitter at http://twitter.com/kkennedyAP.
Copyright 2013 The Associated Press. All rights reserved. This material may not be published, broadcast, rewritten or redistributed.


text:
Neuromuscular choristoma: characteristic magnetic resonance imaging findings and association with post-biopsy fibromatosis
- Blake D. Niederhauser,
- Robert J. Spinner,
- Mark E. Jentoft,
- Brian M. Everist,
- Jane M. Matsumoto,
- Kimberly K. Amrami
- … show all 6 hide
Rent the article at a discountRent now
* Final gross prices may vary according to local VAT.Get Access
To describe imaging characteristics of neuromuscular choristomas (NMC) and to differentiate them from fibrolipomatous hamartomas (FLH).
Materials and methods
Clinical and imaging characteristics of six patients with biopsy-proven NMC and six patients with FLH were reviewed by musculoskeletal, a pediatric, and two in-training radiologists with a literature review to define typical magnetic resonance imaging features by consensus. Five radiology trainees blinded to cases and naive to the diagnosis of NMC and a musculoskeletal-trained radiologist rated each lesion as having more than or less than 50 % intralesional fat, as well as an overall impression using axial T1 images. Sensitivity, specificity, accuracy, and interobserver agreement kappa were determined.
Typical features of NMC include smoothly tapering, fusiform enlargement of the sciatic nerve or brachial plexus elements with T1 and T2 signal characteristics closely following those of muscle. Longitudinal bands of intervening low T1 and T2 signal were often present and likely corresponded to fibrous tissue by pathology. Four of five patients with long-term follow-up (80 %) developed aggressive fibromatosis after percutaneous or surgical biopsy. Nerve fascicle thickening often resulted in a "coaxial cable" appearance similar to classic FLH, however, using a cutoff of <50 % intralesional fat allowed for differentiation with 100 % sensitivity by all reviewers and 100 % specificity when all imaging features were utilized for impressions. Agreement was excellent with all differentiating methods (kappa 0.861–1.0).
NMC can be confidently differentiated from FLH and malignancies using characteristic imaging and clinical features. When a diagnosis is made, biopsy should be avoided given frequent complication by aggressive fibromatosis.
Article MetricsCitations
Co-published with
Other actions
- Bonneau, R, Brochu, P (1983) Neuromuscular choristoma. A clinicopathologic study of two cases. Am J Surg Pathol 7: pp. 521-528 CrossRef
- Chen, KT (1984) Neuromuscular hamartoma. J Surg Oncol 26: pp. 158-160 CrossRef
- Markel, SF, Enzinger, FM (1982) Neuromuscular hamartoma–a benign "triton tumor" composed of mature neural and striated muscle elements. Cancer 49: pp. 140-144 CrossRef
- Kim, D, Hong, E, Lee, J (1999) Subcutaneous neuromuscular hamartoma. A case report. Korean J Pathol 33: pp. 62-64
- Awasthi, D, Kline, DG, Beckman, EN (1991) Neuromuscular hamartoma (benign "triton" tumor) of the brachial plexus. Case report. J Neurosurg 75: pp. 795-797 CrossRef
- Azzopardi, JG, Eusebi, V, Tison, V, Betts, CM (1983) Neurofibroma with rhabdomyomatous differentiation: benign 'triton' tumour of the vagina. Histopathology 7: pp. 561-572 CrossRef
- Bassett, GS, Monforte-Munoz, H, Mitchell, WG, Rowland, JM (1997) Cavus deformity of the foot secondary to a neuromuscular choristoma (hamartoma) of the sciatic nerve. A case report. J Bone Joint Surg Am 79: pp. 1398-1401
- Boman, F, Palau, C, Floquet, A, Floquet, J, Lascombes, P (1991) Neuromuscular hamartoma. Ann Pathol 11: pp. 36-41
- Hebert-Blouin MN, Scheithauer BW, Amrami KK, Durham SR, Spinner RJ. Fibromatosis: a potential sequela of neuromuscular choristoma. J Neurosurg. 2012;116(2):399–41.
- Lai, PH, Ho, JT, Lin, SL, Hsu, SS, Chen, C, Yeh, LR (2004) Neuromuscular hamartoma arising in the brachial plexus. Neuroradiology 46: pp. 216-218 CrossRef
- Louhimo, I, Rapola, J (1972) Intraneural muscular hamartoma: report of two cases in small children. J Pediatr Surg 7: pp. 696-699 CrossRef
- Masson, P (1956) Tumeurs humaines: histologie, diagnostics et techniques. Librairie Maloine, Paris
- Orlandi, E (1895) Sopra un caso di rabdomioma del nervo ischiatico. Arch Sci Med (Torino) 19: pp. 113-137
- Galliani, CA, Matt, BH (1993) Laryngomalacia and intra-neural striated muscle in an infant with the Freeman-Sheldon syndrome. Int J Pediatr Otorhinolaryngol 25: pp. 243-248 CrossRef
- Kim, S, Kwon, H, Kwak, K, Ahn, K (2005) Neuromuscular choristoma of the sciatic nerve—a case report. Korean J Pathol 39: pp. 192-196
- Tiffee, JC, Barnes, EL (1998) Neuromuscular hamartomas of the head and neck. Arch Otolaryngol Head Neck Surg 124: pp. 212-216
- Boyaci S, Moray M, Aksoy K, Sav A. Intraocular neuromuscular choristoma: a case report and literature review. Neurosurgery. 2011;68(2):E551–5.
- Castro, DE, Raghuram, K, Phillips, CD (2005) Benign triton tumor of the trigeminal nerve. AJNR Am J Neuroradiol 26: pp. 967-969
- Daley, TD, Darling, MR, Wehrli, B (2008) Benign triton tumor of the tongue. Oral Surg Oral Med Oral Pathol Oral Radiol Endod 105: pp. 763-766 CrossRef
- Demir, Y, Uluoglu, O, Ozmen, S, Boyacioglu, ZM, Atabay, K (2003) Neuromuscular hamartoma in the mental region. J Oral Maxillofac Surg 61: pp. 397-400 CrossRef
- Giannini, C, Reynolds, C, Leavitt, JA, Schultz, GA, Garrity, JA, Ebersold, MJ (2002) Choristoma of the optic nerve: case report. Neurosurgery 50: pp. 1125-1128
- Karagama, YG, Bridges, LR, Hille, PT (2002) Neuromuscular hamartoma of the cochlear nerve: a rare occurrence in the internal auditory meatus. Eur Arch Otorhinolaryngol 259: pp. 119-120 CrossRef
- Kawamoto S, Matsuda H, Ueki K, Okada Y, Kim P. Neuromuscular choristoma of the oculomotor nerve: case report. Neurosurgery. 2007;60(4):E777–8.
- Kazim, M, Kennerdell, JS, Maroon, J, Rothfus, W, Marquardt, M (1992) Choristoma of the optic nerve and chiasm. Arch Ophthalmol 110: pp. 236-238 CrossRef
- Lee, JI, Nam, DH, Kim, JS, Hong, SC, Shin, HJ, Park, K (2000) Intracranial oculomotor nerve rhabdomyoma. J Neurosurg 93: pp. 715 CrossRef
- Lena, G, Dufour, T, Gambarelli, D, Chabrol, B, Mancini, J (1994) Choristoma of the intracranial maxillary nerve in a child. Case report. J Neurosurg 81: pp. 788-791 CrossRef
- Menovsky T, Grotenhuis JA, de Vries J, Bartels RH. Endoscope-assisted supraorbital craniotomy for lesions of the interpeduncular fossa. Neurosurgery. 1999;44(1):106–10.
- Oeppen, RS, Harden, SP, Argent, JD (2003) Neuromuscular hamartoma: imaging features of a rare paediatric craniofacial tumour. Pediatr Radiol 33: pp. 50-52 CrossRef
- Owor, G, Qian, J, Payner, T, Martin, A, Shan, Y (2004) Intracranial neuromuscularchoristoma: a case report and literature review. Ear Nose Throat J 83: pp. 544
- Smith, MM, Thompson, JE, Thomas, D, Castillo, M, Carrier, D, Mukherji, SK (1997) Choristomas of the seventh and eighth cranial nerves. AJNR Am J Neuroradiol 18: pp. 327-329
- Spencer, A, Lee, J, Prayson, RA (2005) Optic nerve choristoma. Ann Diagn Pathol 9: pp. 93-95 CrossRef
- Tobias S, Kim CH, Sade B, Staugaitis SM, Lee JH. Neuromuscular hamartoma of the trigeminal nerve in an adult. Acta Neurochir (Wien). 2006;148(1):83–7.
- Uysal, A, Sungur, N, Kocer, U, Cologlu, H, Oruc, M, Yalta, T (2005) Neuromuscular hamartoma of the occipital nerve: clinical report. J Craniofac Surg 16: pp. 740-742 CrossRef
- Vajramani, G, Devi, I, Santosh, V, Hegde, T, Das, BS, Das, S (1999) Benign triton tumor of the trigeminal nerve. Childs Nerv Syst 15: pp. 140-144 CrossRef
- Vandewalle, G, Brucher, JM, Michotte, A (1995) Intracranial facial nerve rhabdomyoma. Case report. J Neurosurg 83: pp. 919-922 CrossRef
- Zimmerman, LE, Arkfeld, DL, Schenken, JB, Arkfeld, DF, Maris, PJ (1983) A rare choristoma of the optic nerve and chiasm. Arch Ophthalmol 101: pp. 766-770 CrossRef
- Zwick, DL, Livingston, K, Clapp, L, Kosnik, E, Yates, A (1989) Intracranial trigeminal nerve rhabdomyoma/choristoma in a child: a case report and discussion of possible histogenesis. Hum Pathol 20: pp. 390-392 CrossRef
- Mitchell, A, Scheithauer, BW, Ostertag, H, Sepehrnia, A, Sav, A (1995) Neuromuscular choristoma. Am J Clin Pathol 103: pp. 460-465
- Maher, CO, Spinner, RJ, Giannini, C, Scheithauer, BW, Crum, BA (2002) Neuromuscular choristoma of the sciatic nerve. Case report. J Neurosurg 96: pp. 1123-1126 CrossRef
- Descamps, MJ, Barrett, L, Groves, M, Yung, L, Birch, R, Murray, NM (2006) Primary sciatic nerve lymphoma: a case report and review of the literature. J Neurol Neurosurg Psychiatry 77: pp. 1087-1089 CrossRef
- Teng, LH, Lu, DH, Xu, QZ (2009) Tumor arising in the right sciatic nerve of a 58-year-old man. Neuropathology 29: pp. 637-639 CrossRef
- Kahraman, S, Sabuncuoglu, H, Gunhan, O, Gurses, MA, Sirin, S (2010) A rare reason of foot drop caused by primary diffuse large B-cell lymphoma of the sciatic nerve: case report. Acta Neurochir (Wien) 152: pp. 125-128 CrossRef
- Maeseneer, M, Jaovisidha, S, Lenchik, L, Witte, D, Schweitzer, ME, Sartoris, DJ (1997) Fibrolipomatous hamartoma: MR imaging findings. Skeletal Radiol 26: pp. 155-160 CrossRef
- Marom, EM, Helms, CA (1999) Fibrolipomatous hamartoma: pathognomonic on MR imaging. Skeletal Radiol 28: pp. 260-264 CrossRef
- Lim, R, Jaramillo, D, Poussaint, TY, Chang, Y, Korf, B (2005) Superficial neurofibroma: a lesion with unique MRI characteristics in patients with neurofibromatosis type 1. AJR Am J Roentgenol 184: pp. 962-968
- Title
- Neuromuscular choristoma: characteristic magnetic resonance imaging findings and association with post-biopsy fibromatosis
- Journal
Skeletal Radiology
Volume 42, Issue 4 , pp 567-577
- Cover Date
- 2013-04-01
- 10.1007/s00256-012-1546-7
- Print ISSN
- 0364-2348
- Online ISSN
- 1432-2161
- Publisher
- Springer-Verlag
- Additional Links
- Topics
- Keywords
- Neuromuscular hamartoma
- Sciatic
- Desmoid tumor
- Peripheral nerve
- Industry Sectors
- Authors
- Blake D. Niederhauser (1)
- Robert J. Spinner (2)
- Mark E. Jentoft (3)
- Brian M. Everist (1)
- Jane M. Matsumoto (4)
- Kimberly K. Amrami (4)
- Author Affiliations
- 1. Mayo E-2, Department of Radiology, Mayo Clinic, 200 1st St. SW, Rochester, MN, 55905, USA
- 2. Gonda 8, Department of Neurosurgery, Mayo Clinic, 200 1st St. SW, Rochester, MN, 55905, USA
- 3. Hilton 11, Department of Pathology, Mayo Clinic, 200 1st St. SW, Rochester, MN, 55905, USA
- 4. Mayo W-2, Department of Radiology, Mayo Clinic, 200 1st St. SW, Rochester, MN, 55905, USA


text:
This is an apolitical forum for discussions on the Axis nations and related topics hosted by Marcus Wendel's Axis History Factbook in cooperation with Christian Ankerstjerne's Panzerworld and Christoph Awender's WW2 day by day.
Founded in 1999.
Neue Photographische Gesellschaft AG 1894-1948
Berlin, Germany
The New Photographic Society was a member organization of photographers founded by Arthur Schwarz. In 1894 their 35 members turned the group into a Limited Corporation. Their members published many real photo postcards and stereo-views, and they manufactured photo paper as well. They also printed real photo cards for other companies such as Rotograph and became the largest manufacturer of bromide postcards in the world. As demand for postcards grew they started publishing artist signed cards as tinted halftones. In 1922 they were taken over by Mimosa who carried on their name until 1948, but their postcard department was incorporated into E.A. Schwerdtfeger, Ltd. who continued producing their cards until the Second World War.
Return to "Holocaust & 20th Century War Crimes"
Users browsing this forum: CommonCrawl [Bot]


text:
Is it me or were the Mac vs PC commercials poorly shot?
Started Aug 3, 2012 | Discussions thread
nt)The shoes they're wearing is part of the image of each "computer".
In reply to TotalNeophyte, Aug 4, 2012
nt=No text
Mike_PEAT's gear list:Mike_PEAT's gear list
Lytro Light Field 16GB
Reply Reply with quote Complain
|Post ()
|Posted by
|Aug 3, 2012
|Aug 3, 2012
|Aug 3, 2012
|Aug 3, 2012
It's You /ntNew
|Aug 3, 2012
|Aug 4, 2012
Keyboard shortcuts:
FForum PPrevious NNext WNext unread UUpvote SSubscribe RReply QQuote BBookmark post MMy threads
Color scheme? Blue / Yellow


text:
2,539 Views
197 Views
14 Views
By ros22607gi
ASL Loan Modification for Deaf and Hard of Hearing
590 Views
By homeoffer
3,767 Views
By luketrev
Baby Sign Language - The Alphabet Song
23,849 Views
By WeeHands
Cute Baby Signing/baby Sign Language: Fireese i...
6,699 Views
ASL Lesson: Uncommon Signs in ASL
219 Views
"Give Me Your Eyes" in American Sign Language
1,052 Views
By: Metacafe Affiliate U
Obama Signs Student Loan Reform Bill
2 Views
By CBS
The Last Starfighter (1984): Declined Loan
75 Views
By AnyClip
The Janky Promoters (2009): Asking Mom for Loan
168 Views
By AnyClip
Simply Red - Home Loan Blues (Official Music Vi...
39 Views
By warner music
Duck Soup (1933): Conditional Loan
57 Views
By AnyClip
Going My Way (1944): Never Loan Money to a Church
91 Views
By AnyClip
28 Views
By CBS
The Pitfalls of Co-signing a Loan
6 Views
By CBS
Congress Locked in Student Loan Battle
6 Views
By CBS
8 Views
By CBS
Romney Backs Obama's Student Loan Plan
3 Views
By CBS
College Grads May Face Higher Student Loan Inte...
2 Views
By CBS
Republican Slams Obama's Opposition to GOP Stud...
2 Views
By CBS
Pelosi: Extending Current Student Loan Rate the...
2 Views
By CBS
Reid: House Student Loan Bill "worse Than Doing...
2 Views
By CBS
Student Loan Relief Bill Passed by House
2 Views
By CBS
American Sign Language Emotion Words : American...
772 Views
By: Metacafe Affiliate U
American Sign Language Food Words : American Si...
479 Views
By: Metacafe Affiliate U
Ep. 1290: Where We Feel the Vibrations
2 Views
By CNET
Learn Sign Language Sign Language Course Sign L...
162 Views
By Learnsign
Sign Language Basics : Sign Language: Deaf or H...
446 Views
By: Metacafe Affiliate U
Sign Language ABC Story "Sick Morning"
103 Views
By: Metacafe Affiliate U
LanguageMan explains what Loan Signs are in ASL. Pay attention, class is in session!


text:
iToros Mobile
5,000 - 10,000 downloadsAdd this app to your listsTweets por @Appszoom
By California State University, Dominguez Hills
Tired of being tied to a monitor in order to stay in-tune with campus life? Still staring at paper maps to navigate around CSU Dominguez Hills? Need to grab a quick bite before class, just not certain what is available? We know life is hectic enough without being wired to a laptop. Now you can access important student related information on the go! Locate a building or parking lot or even contact a department using interactive maps. Catch up on Toro's sports and campus news. Access your Toromail. You can even check your grades, financial aid data, class schedule and more using the new my.Toros mobile portal. iToros Mobile – Created with YOU in mind.
What's New in Version 3.0.0
Enhanced mobile framework. New icons. Improved look!
NEW: Choose your Favorite Apps to display on the springboard!
NEW: Search capabilities – Find useful campus information
NEW: Software update push notifications
NEW: Campus Safety information
Updated Calendar app!
Updated Map – new look
Improved Performance - Access to more data while offline!
What is included in Launch Version 2.0.0:
** Alert Log: See current and expired (up to 48hrs) emergency alerts and get detailed information
** Athletics: Catch up on Toro sports
** Blackboard Learn: Access your campus LMS account
** Bookstore: Order class material and apparel online!
** Calendar: View important academic events by list or any day of the week
** Courses: Browse offerings and available seats in the course schedule
** Dining: Hungry? Try one of more than a dozen dining options. Find locations, hours and view menus.
** Directory: Lookup faculty and staff. Easy access to phone number, email and office location.
** Helpdesk: Open a helpweb ticket or reset your student account password.
** Jobs App (NEW) – Student & Employee Opportunities
** Library App (NEW) – Useful resources at your fingertips!
** Map: Find your current location using "Find Me". Locate buildings and parking lots. See details, photos, department location and important links using interactive maps.
** my.Toros Mobile Portal: Check your grades. See your financial aid data. Review your class schedule and MORE!
** News: Be in the know on campus with CSUDH news at your fingertips.
** Police: Contact emergency personnel with the touch of a button. Submit an anonymous crime report.
** Social Media: Quick access to campus Facebook walls, Twitter tweets and YouTube videos.
** ToroMail: Access your student mail from the palm of your hand.
Additional features include:
** Mobile Toro "Alerts" – Know when there is an emergency on campus and get detailed information! Watch for the flashing "Alert" message in the upper right hand corner of the app.
** Weather – Hey Toros. Is it raining outside? Click on the Map and find out.
** Information Tab – Access to Frequently Asked Questions and Send Feedback. We want to hear from you!! Other options include; Send SMS, email and take a photo.
** Gallery – See campus photos
** Full Site – Unable to find something on iToros Mobile? Check out our full campus site.
Tags: itoros mobile.
What's New in Version 3.0.0
Enhanced mobile framework. New icons. Improved look!
NEW: Choose your Favorite Apps to display on the springboard!
NEW: Search capabilities – Find useful campus information
NEW: Software update push notifications
NEW: Campus Safety information
Updated Calendar app!
Updated Map – new look
Improved Performance - Access to more data while offline!
(43 stars)
I love the app. It's a ton of help and simple to use. I like that it has mycsudh and Toromail easily accessible. Also download the Blackboard app...it's great to have everything with me on my phone anywhere I go. :) BTW: Anyone who does have the blackboard application and can't seem to find DH on it when they search for the school, that's because it's under the name is CSU - Dominguez Hills not
(43 stars)
For the most part this app is okay... It is still new right? So I expect some lag on things. My only problem is bb, csudh isn't on that specific app we are sent to. I don't know if that has to do with your app or the bb app. But that needs to be fixed because that's what I use the most.
(43 stars)
I like the app but it is slow and it lag. Not everything is updated especially mycsudh above of the fb button.
(43 stars)
Its really slow.. not a real app . Wack!!!!
(43 stars)
Great app!
(43 stars)
Love the content on this app. The only complaints I have is how it lags when I open a section. And the scrolling can be cleaner too.


text:
East Central Energy provided a beautiful crab tree and worked with Sunrise River School third grade students to plant it on site near Grand Avenue in North Branch last Friday morning. The ECE team also set up three fun learning stations. Students learned firsthand about tree planting and the benefit...Read More
East Central Energy
The Rural Electric Youth Tour is a journey through history, a glimpse of government in action, peer fellowship at its finest, and according to a 2012 participant, "one of the best trips you'll ever go on." East Central Energy offers this seven-day, all-expense-paid educational trip to Washingt...Read More
The emergency needs of residents in East Central Energy's service area were the focus of several recent grants from the electric co-op's Operation Round Up Trust. A walk-in freezer for an expanding local food shelf, an infrared camera and radios for emergency crews, and funds for a food distribu...Read More
North Branch Area High School recently received 100 new robes from Regency Cap and Gown. The robes were made possible through grants from the East Central Energy Round-up, the Shopko Foundation, and Lake State Federal Credit Union. The grant funds raised $3,500, and the North Branch Booster Club pr...Read More
Every year ECE recognizes the importance of volunteers and community involvement by presenting the Touchstone Energy® Community Award to a local organization. Nominations for the award are now being accepted. Any organization in ECE's service territory is eligible to compete for the award. Civic ...Read More
By Jon Tatting Spare change has boosted a cool time for folks at the Rush City pool, thanks to a local utility and its grant program. With the help of an Operation Round Up grant from East Central Energy, the Rush City Pool Committee this year added three new Funbrellas to help provide more shade [....Read More
East Central Energy will it holds its 76th annual meeting Saturday, April 14 at the Rush City high school beginning at 8 a.m. ECE invites members to bring their families and get acquainted with their cooperative. 2012 is the International Year of the Cooperative, a global celebration of the advantag...Read More


text:
Description: we are the dreamers of dreams
Image was hearted from thelostdeer.tumblr.com
Other images from this site
255 people have hearted this image
This image is in 31 collections
You might like these too
Now available in your language!Use in your language! Go back to English
Other images from this site
You might like these too
Sign in with Facebook or Twitter to start your gallery.
Sign in with Facebook Sign in with TwitterDon't have Twitter or Facebook? Skip this step!


text:
ScripSmart searches inventory for discounted Walmart Gift Cards from multiple sources throughout the day. Each of these companies operate secondary gift cards markets where consumers sell unwanted gift cards for less than face value.
The Walmart Gift Card is great for: The Holidays, Thanksgiving Day, His Birthday, Her Birthday, Back To School, Christmas, St. Patrick's Day, Housewarming, Graduation, Baby Showers, Babies, The Home, Books, Teachers, Tools, Kids, Get Well Wishes, Gear Heads, Video Games, College Students
You can always check back later. Also, we have many other discounted gift cards available for purchase.
By Value
By Discount
Card Type
Discount Range
By Seller
Great For Giving
View All Discount
Gift Cards ►


text:
On Thursday, June 26, 2014, the Supreme Court issued its long-awaited Noel Canning decision (NLRB v. Noel Canning, 572 U.S. ____ (2014)), and invalidated President Obama's January 2012 appointments of three individuals to the...more
In the waning days of 2012, the National Labor Relations Board (NLRB) issued several game-changing decisions that are important to all private sector employers—both union and nonunion....more
The close of 2012 brought a flurry of activity by the National Labor Relations Board and the Board has not slowed down in the New Year. Several of the Board's recent decisions mark significant departures from decades of...more
In addition to the significant actions taken by the National Labor Relations Board (NLRB or Board) in 2012 that affect all employers, the NLRB late last year issued several important decisions that affect unionized employers...more
Historically, employers have been free to discontinue union dues check-off arrangements upon the expiration of a collective bargaining agreement. The National Labor Relations Board (NLRB) changed that long-standing rule on...more
Sign up for your custom alerts now, using LinkedIn ›
Back to Top
Copyright ©


text: Drivers tackling 2014 races without drinks to save weight 4 April, 2014 Adrian Sutil will go the entire duration of the Bahrain Grand Prix race on Sunday without a sip of water. The tall and therefore heavy German lost almost 4 kilograms over the winter and is now complaining that, given the heavier 2014 engines, the 692 kg car-plus-driver minimum weight is unfair. Sutil claims he is barely training in order to further shrink his muscles, and eating and drinking so little that – tapping his head – "you don't work well up here". Not only that, Sauber's car and Ferrari engine are both overweight, so the Swiss team is cutting corners in every area – including taking away Sutil's half-kilo drinks bottle. But Ferrari's super-fit cycling enthusiast Fernando Alonso has revealed that, even in stifling Malaysia, he raced comfortably without a drink. "In the past, Malaysia required a specific training programme," he said in Bahrain. "But this year I told the team I didn't even need a drinks system. The cars are much less physically demanding." (GMM) Subbed by AJN. Content on GrandPrix247.com by: staff & contributors, Reuters syndication, GMM service, Getty Images, Formula 1 teams, sponsors & organisations.


text:
May 6, 2014
(11 Jan. 2011) --- Emi Koussi volcano in Chad is featured in this image photographed by an Expedition 26 crew member on the International Space Station. The large Emi Koussi volcano is located in northern Chad at the southeastern end of the Tibesti Range. The dark volcanic rocks of the volcano provide a sharp contrast to the underlying tan and light brown sandstones exposed to the west, south, and east. Emi Koussi is a shield volcano formed from relatively low viscosity lavas-flowing more like motor oil as opposed to toothpaste-and explosively-erupted ignimbrites that produce a characteristic low and broad structure that covers a wide area (approximately 60 x 80 kilometers). This photograph highlights the entire volcanic structure; at 3,415 meters above sea level, Emi Koussi is the highest summit of the Sahara region. The summit area contains three calderas formed by powerful eruptions. Two older, and overlapping, calderas form a depression approximately 12 x 15 kilometers in area bounded by a distinct rim (center). According to scientists, the youngest and smallest caldera, Era Kohor, formed as a result of eruptive activity that occurred within the past 2 million years. Young volcanic features including lava flows and scoria cones are also thought to be less than 2 million years old. There are no historical records of eruptive activity at Emi Koussi, but there is an active thermal area on the southern flank of the volcano.
Topics: Environment, Volcanism, Volcanology, Geology, Emi Koussi, Tibesti Mountains, Shield volcano, Stratovolcanoes, Caldera, Types of volcanic eruptions, Igneous rocks, Volcano, Plate tectonics


text:
Hottest Chanel Iman GIFs Ever
Chanel Iman is a world-class double threat: a Victoria's Secret Angel and a Swimsuit Issue star. Those are two of our favorite things.
Amanda Cerny — Babe of the Day
We're not saying we know for sure that Amanda Cerny has joined the Mile High Club, but that doesn't mean you can't imagine such a scenario.
Best Lingerie Pictures Ever (This Week)
Girls in skimpy lingerie? Don't mind if we partake!
xoGisele — Babe of the Day
xoGisele is a woman of the Web. By that we mean she is a one-time Xbiz Web Babe of the Year, a Playboy Cyber girl, a gear head and a webcam extraordinaire.
Sexiest Selfies Ever (This Week)
Hot chicks with cameras taking sexy self-shots? Cameras were invented way too late.
Val Keil — Babe of the Day
We don't really know all that much about Miss Val Keil, but she does have that je ne sais quoi that lets her pull of being cute as a button and hot as hell at the same time.
Best Cleavage Ever (This Week)
The weekend is finally here. Even better, the best cleavage we found this week.
Hottest Lily Aldridge GIFs Ever
2014 has been a banner year for Lily Aldridge. The Victoria's Secret model branched out into swimsuit modeling, taking the world by storm by appearing on the cover of the Sports Illustrated Swimsuit Issue as a rookie.
Watch the Most (Un)Masculine Way to Ask Friends to Be Groomsmen
Fun fact: after getting on bended knee and popping the question, the second biggest question a man will ask in his life is when he approaches his friends requesting them to be groomsmen on the big day. Well, this guy takes that inquiry very seriously.
Khloe Terae — Babe of the Day
Khloe Terae, your 2014 Playmate of the Year in South Africa, hosts Playboy's Hot Yoga and helps other models get into all kinds of poses while nude. So that's nice.
Hottest Yoga Pants Ever (This Week)
You know what the best warm-up ritual before going to the gym is? Checking out girls in yoga pants.
Hottest Charlotte McKinney GIFs Ever
By now you must be at least somewhat familiar with the smoking hot Charlotte McKinney, in which case you're probably not even still reading this. And if you don't know her, well, you're in luck.