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Thread: Truth in illustration
December 20th, 2005 #1
Truth in illustration
A good friend passed this link along to me. I apologise if it's been posted before.
Any rate, a lot of this rings very true.
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December 20th, 2005 #2
Thank you for this link Dan, a very concise reading. As soon as I read the first paragraph, well actually as soon as I read the title, I immediatly thought of a few people I was going to show this to.
Instead of wearing myself out every time "one of those conversations" begins, I will simply point to this article. Less tiring, less stressing, more articulate, more concise
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December 20th, 2005 #3
I have half a mind to sticky that in the Employment Discussion section.
Thanks Dan,
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December 20th, 2005 #4
Oregano, kick your other half mind in the ass if you can find it, and do it...
December 20th, 2005 #5
go for it it :0
im posting it in the scholarship thread too....
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December 20th, 2005 #6
Great link, Dan! And, yeah.. it did ring very true!
Sticky that mofo, Oregano!
December 20th, 2005 #7Registered User
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Very well written and it definitely gets the point accross. Thanks for the post.
December 20th, 2005 #8True style comes from within not from copying someone else.
Great link, Dan.
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December 20th, 2005 #9
Great read!
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December 21st, 2005 #10Originally Posted by OreganoOriginally Posted by Ilaekae
I'll bookmark the link. Every single highschool "friend" who believes I'm still pursuing some childish dream will get sent this link.
There are 3 sides to every story. Yours, mine and THE TRUTH.
December 21st, 2005 #11
Thats it! Im burning my diploma......and my wifes bra but thats another story
The devil made me do it!!!
My website
December 23rd, 2005 #12
Haha Sorrowking, I wonder what that other story is about Mind to make an article like Daniel Pelavin has done?
December 23rd, 2005 #13
I am confused, ....probably will have to aspire becoming "the best there is", as before.....
December 29th, 2005 #14
yay! I can finally toss all those franzetta copies.....
I'm drawing a blankin my sketchbook, that is
Ye-ha! I actually completed my site.Check it out
March 20th, 2006 #15
There are some really good reads here on CA.
There are deff. a few people this needs to be shown too I can think of.
Thanks Oregano for stickying it. I don't think I would have caught it otherwise.
Started a Sketchbook --> http://conceptart.org/forums/showthread.php?t=63150
April 30th, 2006 #16Registered User
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Originally Posted by Quicksilver
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This article is a breath of fresh, chilling air. Thanks.
May 18th, 2006 #17
This reigns true to me now more than ever. Just coming out of an art school that charged me a good deal of money, so far I've gained nothing from the school. My first job I aquired online and quite frankly by accident, and now that I went back to school so they can help find some new work all I got was a worthless pamphlet about interviews and weblinks for pages for me to pay a monthly fee so they can find work for me. The sooner I would've known what I know now the sooner I could've started my career, I feel like everything I've done until know has been a step backwards...this link gives it to you straight, there is no such thing as "gifted" or "easy talent" no matter how good you are you have to bust your ass off in this industry.
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May 19th, 2006 #18
Daniel Pelavin is great. I got to meet him back at tech school and learned a lot from his presentation. Great article!
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July 17th, 2006 #19Registered User
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This inspired me to mount a full blown protest in my art school which required me to demonstrate at least 8 artist that inspired me ...
for my thesis projects...
July 26th, 2006 #20
"Inspired" is a little different than "copy..."
I get inspired by a lot of things, but I don't necessarily want to copy them. Like a good bowl of fruit, for example, or burning sorrowking's wife's bra. ; )
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August 28th, 2006 #21
Thanx dan for that interesting read. I should recommend this to anyone that is pursing this career.
August 28th, 2006 #22
Thank you for posting that thread. So many of those things are so true. I am so tired of having someone say "Yeah, this is good, but I was looking for something more like (insert name of famous artist here) does." There are those few fortunate times when I have had an art director tell me to only show them my stlye, and then get the job!
Don't listen to me, I'm just an ape with a pencil!
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September 18th, 2006 #23
Thanks for posting that.
As a student of CCS I can honestly say I was taught 98% art, 2& buisness...in the illustration department. So far, only the teachers were what made going to school worth it.
I haven't really gained anything from the school itself. I owe them a shit load of money...more accuratly I owe a bank a shit load of money because of the insanely high cost of art school.
Honestly, in retrospect, I would have loved to trade two years of art for two years of buisness training. I would have done the art anyways, the buisness part no. So I have to do it after I graduated.
All I can say, is I'm very depressed I have no job right now. I thought that college was supposed to help with that. Nope!
Oh, and if you think I'm an exception not a rule. All of my friends, except ONE have NO jobs.
Sorry for ranting, but I had to say it. I feel a little better now. I know this probably isn't the place for it.
Thanks, again, for the article. I will pass it around.
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October 6th, 2006 #24Registered User
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Originally Posted by Beonarri
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But to be fair, I could have been a better student while I was in school.
On the other hand, looking back I find it odd that like there was only 1 class for business and marketing and like 5-10 english, math, psych classes I had to take.
In retrospect I either should have gone to a better school out in Cali or been a graphic designer so I could get a job.
December 12th, 2006 #25Registered User
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well i would like to say thanks for posting that link i have printed it out for furture ref
You see i know lots of art courses that Dont Teach basics of Art
I have always thought that we need a Art Degere in order for people to take us Seriosly as most people dont take artists as a real carerr do they??
am only a artists just starting out so thats why i dont post here as i know that there are alot of people here that are professional artists and i aint at that level
i did post this in the AOI forum but i thought that i may get more info from you guys hope u dont mind??
Hello everyone am new here I'm from Sussex UK and I'm a disabled artist and unable to work i have no money behind me at all. but i do have a husband that takes care of me .
and I'm 26 and only just starting out as an artist a late starter is it to late for me??.
and can you make money as an freelance illustrator ? .
where subject areas sell in the work in the freelance illustrator world?
oh i like childrens illustration and cartoon work but i know thats hard to get into!!! i have heard anyhow
what does Advertising illustration subjets cover?
am up for anything Concept illustration looks good but i dont know what it covers though?? and what subjet areas again?? and is there paid work in it?
also like Book jackets/CD s
and posters and greeting card and book illustration my list could go on ..
I'm only a Beginner artist i would like to know what kind of art courses are good to take if your wanna become a professional illustrator in the future? Is there any distance learning illustration courses that i could do for the Beginner level ?.
at the mo am doing a distance learning course with the London art .
college which is a painting and drawing course that covers :
Materials needed, perspective, pen and ink drawing, drawing plants and flowers, drawing animals, drawing out of doors, using the photocopier, distinction between pen and pencil, illustrating for children, materials and colour, watercolour techniques and preparation, size and proportion of pictures, composition, landscapes, creativity in painting, oil painting, experiments with style, acrylics and gouache, life drawing, life and movement, poster painting and lettering, book jackets, fashion drawing, graphic design.
i have been on the hunt on the net but nothing!!
Do you need a degree in art/illustration in order to be a
professional illustrator.
? as i will not be able to do that could i learn to be a professional illustrator though art books and distance learning ?
well hope to hear from you soon
December 19th, 2006 #26Registered User
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Articles like this keep my bowels regular. As at the moment I go to Pratt, were in the illustration department there is this constipatatiing overtone of misinformation I feel.
thanl you dan
December 19th, 2006 #27
Dan... I read your link... and truly hope that I am not the only Illustrator who has. I must pass it on to some professors here at CIA in Cleveland, and post it in our studio.
-happy holidays,
mel Rouse Illustrations
April 16th, 2007 #28
The only thing I got out of college was great parties and cute girls.
Ironicaly our school motto was, "learn by doing".
So what was the point in taking a class?
I miss those days.
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May 27th, 2007 #29
hehe...so true, ah well...uni just gave me time I didnt have to be making money (was just racking up debt instead)- to doodle (and be taught jack-all).....and there is nothing truer than the point that a degree counts for absolutly nothing...at all, ever(except mabe top make mummy and daddy proud)....and f'in A...to all who either get the "oh-that totally looks like.....". Do something gothic, and your burton, something inky and your scarfe. I find the way to get the fun work is to be different-my favourite comment on my work is "well thats wiered, I've never seen something like that before".
May 30th, 2007 #30
So... you're saying I shouldn't major in illustration?
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According to Judge Samuel A. Alito, Jr., the First Amendment puts few limitations on politically powerful majorities' ability to use the machinery of government to advance their religious views, even at the expense of the religious freedom of minorities. Replacing Justice Sandra Day O'Connor with Judge Alito would fundamentally alter First Amendment law and immediately put at risk many of the crucual protections for religious minorities that the Supreme Court has recognized and consistently enforced over the past sixty years.
In a press release issued with the report, Barry Lynn, Executive Director of AU said,
Judge Alito appears to be exactly what the extreme right wants for the nation's top court a judge eager to seriously weaken the wall separating religion and government. As a federal appeals court judge, Alito has consistently sided with powerful religious groups who have sought government help in promoting their work.
In my opinion, religious liberty for everyone -- not just Christians -- is our first freedom. It's the first freedom because it is the bedrock foundation upon which every other form of freedom rests. It secures our right to a free conscience and protects the rights of minorities. If you can strip away the right of any minority to worship as they please, to be free from indoctrination into someone else's religion, and to be exempt from paying taxes to support someone else's faith, then you can undermine any other right that minorities enjoy in our society.
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Dual sovereignty and the Sixth Amendment right to counsel.
In Texas v. Cobb, the Supreme Court affirmed that the Sixth Amendment right to counsel is "offense specific" and attaches only to charged offenses. (1) Prior to Cobb, lower courts had created an exception to this rule, holding that the right to counsel also attached to any additional uncharged crimes that were "factually related" to a specific charged offense. (2) But Cobb rejected this exception and held that "offense" in the right-to-counsel context is synonymous with "offense" in the double jeopardy context. (3) For double jeopardy purposes, a single criminal act that violates both state and federal law constitutes two separate offenses, because it violates the laws of two separate sovereigns. (4) Thus, read literally, Cobb implies that the right to counsel can attach to a charged offense against one sovereign, but not to the same (uncharged) offense against a different sovereign.
In United States v. Avants, the Fifth Circuit adopted this literal reading and held that Cobb requires lower courts to incorporate the "dual sovereignty doctrine" described above into the Sixth Amendment definition of offense. (5) In contrast, the Eighth Circuit concluded in United States v. Bird that Cobb does not strictly require application of the dual sovereignty doctrine. (6) Although Avants is more faithful to the plain language of Cobb, the decision is problematic because it invites collusion among state and federal law enforcement during pretrial investigations, creating the potential for cooperating sovereigns to circumvent a defendant's Sixth Amendment fight to counsel. Bird, on the other hand, at least implicitly recognizes this collusion problem. As a result, its holding better comports with the purpose and spirit of the Sixth Amendment. This Comment sides with Bird's outcome, but places the case on a firmer doctrinal foundation, arguing that the importation of dual sovereignty into Sixth Amendment doctrine runs counter to both the logic and the history of the post-incorporation Bill of Rights. Part I sets forth relevant Sixth Amendment doctrine and examines Cobb. Part II assesses Avants and Bird. Part III supplies a structural argument for Bird's result, and concludes.
The purpose of the Sixth Amendment right to counsel is "to protec[t] the unaided layman at critical confrontations with his expert adversary." (7) Defendants possess this fight in the pretrial phase because, in the Court's view, the time between the defendant's arraignment and the beginning of his trial is "perhaps the most critical period of the proceedings." (8) The Sixth Amendment right to counsel is offense-specific and attaches only to the charged offense. (9) Once the defendant invokes his right, any statements "deliberately elicited" (10) by law enforcement regarding that offense may not be used as evidence at trial unless either (1) the defendant's counsel has agreed to the interrogation, or (2) the defendant waived his right to counsel. (11) But given the practical difficulties in obtaining a waiver, police are effectively unable to elicit statements from a represented defendant unless the defendant initiates the conversation. (12)
Because the fight to counsel is offense-specific, the distinction between the charged offenses to which the fight attaches and other uncharged offenses is crucial. The Court recognized in Texas v. Cobb that "the definition of an 'offense' is not necessarily limited to the four corners of a charging instrument." (13) To determine just how far beyond the four corners courts were permitted to reach, the Supreme Court borrowed doctrine from another area of law where the definition of offense is crucial: double jeopardy. Specifically, Cobb imported the test of Blockburger v. United States, which states that a criminal act that violates two statutes will be considered two separate offenses when each violated statute "'requires proof of a fact which the other does not.'" (14) Cobb chose this test because it saw "no constitutional difference between the meaning of the term 'offense' in the contexts of double jeopardy and of the right to counsel." (15) This statement is, at the very least, an invitation for lower courts to import dual sovereignty into Sixth Amendment jurisprudence. (16) If there is truly "no difference" between the meanings of offense in the double jeopardy and right-to-counsel contexts, then it follows that dual sovereignty--an integral part of the double jeopardy definition of offense--should be part of the right-to-counsel definition of offense as well.
The theory of dual sovereignty is simple: "[A]n 'offense' is a transgression of a 'sovereign's' law; the states and the federal government are 'distinct sovereignties'; therefore, a single act violating federal and state laws constitutes two distinct offenses." (17) Yet if federal and state charges for the same act are separate offenses for Sixth Amendment purposes, opportunities arise for cooperating sovereigns to undercut the right to counsel. First, federal officials acting in good faith could interrogate a defendant facing state charges without informing the defendant's lawyer, and could then provide those statements to the state prosecutor for use at trial or use them in a federal prosecution for the same offense. (18) Second, state investigators could conduct the interrogation themselves, rendering its fruits inadmissible at a state trial, but potentially admissible in a subsequent federal trial for the same crime. (19)
United States v. Avants interprets Cobb in a manner that permits the Sixth Amendment circumvention described in Part I. Ernest Henry Avants was indicted by Mississippi authorities for the 1966 murder of an elderly sharecropper. Avants obtained counsel and was released on bond pending state trial, but was subsequently questioned by two FBI agents about the murder. Despite having been apprised of his Miranda rights, Avants said that he "blew [the victim's] head off with a shotgun." (20)
Avants was acquitted of the state murder charge, but because the murder was committed in a national forest, the crime fell within federal jurisdiction. Thirty years later, a federal grand jury indicted Avants for the murder. Before trial, Avants moved to suppress the statements he had made to the FBI agents in 1967, arguing that they were taken in violation of his Sixth Amendment right to counsel. The Southern District of Mississippi agreed and suppressed the statements. (21) But the Fifth Circuit reversed, finding that the evidence was admissible under Cobb because the state and federal murder charges were separate offenses, and the fight to counsel had attached only to the state charge when Avants confessed. (22) The court explained, "[I]t seems rather clear that the Supreme Court would require us to apply double jeopardy principles in determining whether two offenses are the same in the Sixth Amendment context." (23) According to the Fifth Circuit, Cobb mandated this conclusion:
By concluding without limitation that the term "offense" has the same meaning under the Sixth Amendment as it does under the Double Jeopardy Clause, the Court effectively foreclosed any argument that the dual sovereignty doctrine does not inform the definition of "offense" under the Sixth Amendment. Stated differently, the Supreme Court has incorporated double jeopardy analysis, including the dual sovereignty doctrine, into its Sixth Amendment jurisprudence. (24)
Two points about Avants are worth emphasizing. First, the case involved a single criminal act that, despite being a violation of both federal and state law, would constitute a single "offense" under the Blockburger test. The Fifth Circuit readily conceded this point, (25) yet because the murder violated the laws of two separate sovereigns, the court held that the single criminal act nevertheless constituted two separate offenses for Sixth Amendment purposes. (26) Second, nothing in the opinion suggests that the court was concerned about the relationship between the sovereigns--whether they worked together, shared investigative resources, or consulted each other on prosecutorial decisions. In short, Cobb's statement equating "offense" in the fight-to-counsel context with "offense" in the double jeopardy context carries practically the entire weight of the Fifth Circuit's decision.
In sharp contrast, Bird declined to import dual sovereignty into its Sixth Amendment analysis, and did so with little explanation. Instead, it assessed the two crimes at issue--violations of federal law and Native American tribal law--solely through the lens of Blockburger. Andrew Red Bird, a Native American, was arraigned on a rape charge in Rosebud Sioux Tribal Court in the fall of 2000. As guaranteed by the tribe's constitution, Red Bird was appointed counsel at his arraignment. (27) Later that fall, tribal authorities informed the FBI of the rape charge, as rape is subject to concurrent federal jurisdiction when perpetuated by an "Indian in Indian Country." (28) An FBI agent and a tribal agent--both aware of the pending tribal charge as well as the fact that Red Bird was represented by counsel--together interrogated the defendant about the rape without permission from his attorney. Red Bird waived his Miranda rights and confessed. The following spring, a federal indictment charged Red Bird with four counts of aggravated sexual assault. (29)
Had the Eighth Circuit applied Avants's interpretation of Cobb, it would have concluded that Red Bird's Sixth Amendment right had not been violated with respect to the federal charge. (30) Native American tribes and the federal government are separate sovereigns for double jeopardy purposes, (31) and the federal indictment had not yet been filed when Red Bird confessed to the FBI agent. Yet Bird held that the defendant's right to counsel attached to both the federal and tribal charges, and therefore affirmed the district court's suppression of the confession. (32) The Eighth Circuit found that "the tribal rape charge ha[d] identical essential elements when compared with the later federal charges filed," (33) and concluded from this that the two offenses were the "same" under the Blockburger test. The court did "not believe that it [was] appropriate" to apply a dual sovereignty analysis, (34) yet it provided little doctrinal or historical support for this assertion, merely stating that "the tribal charge ... initiated the federal investigation" and that "the tribe and the U.S. worked in tandem to investigate the rape." (35)
When constitutional rights have been threatened in the past, the Supreme Court has discarded the dual sovereignty doctrine: In the contexts of unreasonable searches and seizures and the privilege against self-incrimination, the Court has recognized that a constitutional right should not be circumvented simply because a crime violated the laws of separate sovereigns. (36) This same reasoning should apply to the Sixth Amendment right to counsel.
Yet the Supreme Court has painted lower courts into a doctrinal corner with its coarse reasoning in Cobb. First, if courts take seriously the idea that "offense" in the right-to-counsel context is equivalent to "offense" in the double jeopardy context, then the dual sovereignty doctrine--alive and well in double jeopardy jurisprudence--must apply with equal force to the right to counsel. Second, if the right to counsel is truly offense-specific, then federal, state, and tribal governments can do in tandem what none could do alone: deliberately elicit incriminating statements from the accused without the knowledge or presence of an attorney, and use those statements against the accused at a trial on the very matter for which the defendant is represented. This is the harsh result of Avants. Bird rejects this outcome by refusing to apply dual sovereignty to the right to counsel, but does so with minimal explanation. The remainder of this Comment attempts to supply a more robust doctrinal account by examining the Court's response to the impact of dual sovereignty on unreasonable searches and seizures and the privilege against self-incrimination.
Before the Fourth Amendment was incorporated against the states, evidence seized unreasonably by state officials could be used at federal trial and vice versa; this was known as the "silver platter doctrine." (37) This result was justified by the fact that the Fourth Amendment exclusionary rule applied only to the federal government. (38) The state government--a separate sovereign--was not bound by the Bill of Rights. (39) But after incorporation, retaining the dual sovereignty principle made little sense because it enabled the two sovereigns to do collectively what the Constitution prohibited either from doing alone: collect and then use at trial unreasonably seized evidence. Elkins v. United States addressed this problem by abandoning the dual sovereignty approach to unreasonable searches and seizures. (40) The Elkins Court believed that its holding would eliminate "inducement to subterfuge and evasion with respect to federal-state cooperation in criminal investigation. Instead, forthright cooperation under constitutional standards [would] be promoted and fostered." (41)
The Court faced a similar dilemma in the context of the Fifth Amendment privilege against compelled self-incrimination in Murphy v. Waterfront Commission. (42) After incorporation, a state could no longer compel incriminating testimony without a grant of immunity. However, dual sovereignty permitted the federal government to use that state-immunized testimony against the defendant in a federal trial for the same crime. Because this practice would frustrate the "policies and purposes" of the Fifth Amendment privilege, the Court discarded the dual sovereignty theory. (43) The Court found that there was "no continuing legal vitality to, or historical justification for, the rule that one jurisdiction ... may compel a witness to give testimony which could be used to convict him of a crime in another jurisdiction." (44)
Many of the same reasons that prompted the Supreme Court to abandon dual sovereignty in these Fourth and Fifth Amendment contexts apply with equal force in the Sixth Amendment context. Acting alone, neither the federal government nor the state government can interrogate a represented defendant about a charged offense and use his statements at trial. Yet, as illustrated in the self-incrimination and search-and-seizure contexts, dual sovereignty principles would permit cooperation between sovereigns that could easily frustrate the purpose of the right to counsel. Dual sovereignty would enable one sovereign to question the defendant without a lawyer present while the defendant awaited trial before another sovereign. Should that questioning yield fruit, the prosecution could be handed off to whichever sovereign is in the best position to make use of the incriminating evidence. (45) Just as the Supreme Court focused on the rights of the individual in these Fourth and Fifth Amendment contexts, the Court should focus on the individual in the Sixth Amendment context as well. This focus is particularly appropriate in the current era of cooperative federalism, where joint federal-state investigations are ever-increasing (46) and federal and state jurisdiction overlap in nearly every substantive area of criminal law. (47)
Texas v. Cobb created doctrinal confusion, but the appropriate response is clear. As Justice Breyer noted in his Cobb dissent, "The Constitution does not take away with one hand what it gives with the other." (48) Dual sovereignty would take away what Massiah and its Sixth Amendment progeny have given; Bird was right to wink at some of Cobb's sweeping language and protect the substance of the Sixth Amendment right. This Comment provides a firm foundation for that decision by treating the right to counsel in the same manner as the Court has treated the constitutional protections against unreasonable searches and seizures and against compelled self-incrimination.
(1.) 532 U.S. 162, 167 (2001) (internal quotation marks omitted).
(2.) Id. at 168; see also id. at 168 n. 1 (citing cases).
(3.) Id. at 173.
(4.) See, e.g., Abbate v. United States, 359 U.S. 187 (1959); Bartkus v. Illinois, 359 U.S. 121 (1959).
(5.) 278 F.3d 510 (5th Cir.), cert. denied, 536 U.S. 968 (2002).
(6.) 287 F.3d 709 (8th Cir. 2002).
(7.) McNeil v. Wisconsin, 501 U.S. 171, 177 (1991) (alteration in original) (internal quotation marks omitted).
(8.) Massiah v. United States, 377 U.S. 201, 205 (1964) (internal quotation marks omitted).
(9.) Texas v. Cobb, 532 U.S. 162, 172 (2001); McNeil, 501 U.S. at 175. The Sixth Amendment right stands in contrast to the Fifth Amendment right to counsel under Miranda v. Arizona, 384 U.S. 436 (1966). Once a defendant invokes his Miranda right to counsel, police must cease interrogation about offenses for which the suspect was arrested or any other offense. See Arizona v. Roberson, 486 U.S. 675, 677-78 (1988).
(10.) Massiah, 377 U.S. at 206.
(11.) See Brewer v. Williams, 430 U.S. 387, 403-04 (1977).
(12.) See Michigan v. Jackson, 475 U.S. 625, 626 (1986). In Jackson, the Court decided that, once invoked, the Sixth Amendment right to counsel cannot be validly waived during a police interrogation. Id. at 636.
(13.) 532 U.S. at 173.
(14.) Id. (quoting Blockburger v. United States, 284 U.S. 299, 304 (1932)).
(15.) Id.
(16.) It is important to note that Cobb was a case involving two state crimes, and so dual sovereignty was never explicitly addressed. But other opinions besides Avants have also stated that the broad language used in Cobb invites application of the doctrine. See, e.g., United States v. Coker, 298 F. Supp. 2d 184, 190 (D. Mass. 2003) (holding that the application of dual sovereignty to the right to counsel "though not reached in Cobb, logically follows from it").
(17.) Daniel A. Braun, Praying to False Sovereigns: The Rule Permitting Successive Prosecutions in the Age of Cooperative Federalism, 20 AM. J. CRIM. L. 1, 25 (1992); see also id. at 25-42 (sharply criticizing the definitions of sovereignty that underlie this formulation).
(18.) For a recent example of federal officials interrogating a defendant facing state charges, and then using his statements in a subsequent federal prosecution for the same offense, see Coker, 298 F. Supp. 2d 184.
(19.) See, e.g., United States v. Bowlson, 240 F. Supp. 2d 678, 684 (E.D. Mich. 2003) (declining to apply dual sovereignty analysis out of a concern that states would be able to pass inadmissible evidence to the federal government for prosecution). There are limits to the degree of cooperation state and federal governments can undertake. See Bartkus v. Illinois, 359 U.S. 121, 123-24 (1959) (suggesting an exception to the dual sovereignty doctrine for "sham prosecutions"). But this exception is exceedingly narrow. See Braun, supra note 17, at 59-64. Principles of agency law also limit the permitted degree of cooperation. See Byars v. United States, 273 U.S. 28, 33 (1927).
(20.) United States v. Avants, 278 F.3d 510, 513 (5th Cir.), cert. denied, 536 U.S. 968 (2002).
(21.) See id. at 514.
(22.) Id. at 522.
(23.) Id. at 517.
(24.) Id.
(25.) See id. at 518 ("[T]he elements of the Mississippi murder statute and the federal murder statute are virtually identical." (citations omitted)).
(26.) See id.
(27.) The Bill of Rights and the Fourteenth Amendment do not apply directly to tribes. See Santa Clara Pueblo v. Martinez, 436 U.S. 49, 56 (1990). The Rosebud Sioux Tribal Constitution, however, includes a right to an attorney that the Bird court viewed as analogous to the Sixth Amendment right in state proceedings. United States v. Bird, 287 F.3d 709, 713 (8th Cir. 2002).
(28.) Bird, 287 F.3d at 711 (citing 18 U.S.C. [section] 1153 (2000)).
(29.) Id. at 711-12.
(30.) The court did not face the question of whether Red Bird's quasi-Sixth Amendment tribal right with respect to the tribal charge was violated, and so the subject is not addressed here.
(31.) United States v. Wheeler, 435 U.S. 313, 323 (1978), cited in Bird, 287 F.3d at 713.
(32.) Bird, 287 F.3d at 714-16.
(33.) Id. at 715 (internal quotation marks omitted).
(34.) Id.
(35.) Id. The court also mentioned that "tribal sovereignty is 'unique and limited' in character." Id. (quoting Wheeler, 435 U.S. at 323). To the extent that this factor would suggest that Native American tribes are not fully "sovereign" in their own right, and thus not susceptible to dual sovereignty analysis in the Sixth Amendment context, such a factor might provide a weak independent justification for the Eighth Circuit's ruling in Bird. This Comment's goal is somewhat more ambitious to elaborate a doctrinal foundation for repudiating the dual sovereignty doctrine across all permutations of the Sixth Amendment fight to counsel.
(36.) See Akhil Reed Amar & Jonathan L. Marcus, Double Jeopardy Law After Rodney King, 95 COLUM. L. REV. 1, 11-15 (1995) (charting the process of incorporation of the Fourth and Fifth Amendments against the states and the subsequent erosion of the dual sovereignty doctrine).
(37.) Elkins v. United States, 364 U.S. 206, 208 (1960).
(38.) See id. app. at 224 tb1.1 (charting the admissibility in state courts of evidence illegally seized by state officers).
(39.) See Barton v. Baltimore, 32 U.S. (7 Pet.) 243 (1833).
(40.) See Elkins, 364 U.S. at 215 (reasoning that "[t]o the victim it matters not whether his constitutional right has been invaded by a federal agent or a state officer"). Shortly alter Elkins, the Court held that the exclusionary rule applies to the states in Mapp v. Ohio, 367 U.S. 643 (1961).
(41.) Elkins, 364 U.S. at 222.
(43.) Id. at 55.
(44.) Id. at 77.
(45.) None of this necessarily entails bad faith on the part of either government, nor need it entail "hand-in-glove" cooperation, Braun, supra note 17, at 72 (internal quotation marks omitted), that might otherwise render the practice unconstitutional.
(46.) See id. at 7-9; see also Michael A. Dawson, Note, Popular Sovereignty, Double Jeopardy, and the Dual Sovereignty Doctrine, 102 YALE L.J. 281, 297-99 (1992) (describing federal-state cooperation in the enforcement of drug laws).
(47.) See John C. Jeffries, Jr. & John Gleeson, The Federalization of Organized Crime: Advantages of Federal Prosecution, 46 HASTINGS L.J. 1095, 1125 (1995) ("Whether desirable or not, the federalization of the substantive criminal law is largely an accomplished feat."). Although these criticisms of dual sovereignty are global, the Court need not abandon the doctrine in all contexts: The doctrine could still play a limited role in double jeopardy law, even if it were abandoned elsewhere. For instance, Akhil Amar and Jonathan Marcus argue that although the Fourteenth Amendment has "rendered [dual sovereignty] largely obsolete," Amar & Marcus, supra note 36, at 19, the doctrine may protect the federal government's Fourteenth Amendment interest in prosecuting abusive state officials when the states themselves fail to do so, id, at 16-19.
(48.) Texas v. Cobb, 532 U.S. 162, 180 (Breyer, J., dissenting).
Reader Opinion
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Blake Lively Rocks Luxury Swimwear for Endless Summer Beach Days
Summer has finally arrived and one thing that we have been looking forward to the most is long, relaxing days at the beach. We have waited for months to feel the warm sand between our toes, the hot sun on our skin, and the salty water in our hair. Nothing beats … Read More >


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So Nintendo showed up at our place today with a Wii Fit -- and an accompanying personal trainer to crack the whip and make sure our half hour of intro exercises and fitness games burned a sufficient amount of calories. Things we learned: our BMI is on the upper end of the "normal" bracket (shocking, considering how sedentary we are blogging 12 hours a day), our balance is kind of crappy, our "body age" is 39 -- over a decade more than our real age -- and no, not even Nintendo can make a fitness game that doesn't feel at least vaguely like PE. And now the 64k question:
|Yeah, dude seriously needs it.
|22276 (82.2%)
|No, and get back to work.
|2101 (7.8%)
|Physical fitness? I wouldn't put anyone through that torture.
|1336 (4.9%)
|I don't know, but I certainly intend for Wii Fit to shed a few of my pounds.
|1389 (5.1%)
Gallery | 6 Photos
Wii Fit feet-on: feeling the burn, inadequate


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Student life at Heriot-Watt
We pride ourself on being an international university; international students make up about one third of our student population.
We are pleased to be one of the recommended British universities by the Omani Ministry of Higher Education, which sponsors Omani students to come and study with us on a new scholarship scheme.
Popular programmes
Previous students from Oman have studied:
- Civil Engineering (BEng/MEng)
- Architectural Engineering (BEng/MEng/MSc)
- Mechanical Engineering (BEng/MEng)
- Chemical Engineering (BEng/MEng)
- Electrical and Electronic Engineering (BEng/MEng)
- BSc Computer Science
- MSc Petroleum Engineering
- MSc Food Science and Nutrition
- BSc Psychology
- MA Business Management
Student societies
Heriot-Watt students are able to join in different student societies through which they can participate in different activities to learn about Edinburgh and learn about the great cultural heritage.
Entry requirements
These entry requirements are intended as a guide only. Please contact us or the School's admissions tutor to find out the actual requirements for the programme you want to study.
- Students holding Thanawiya Amma / Secondary School leaving certificate are required to take the Heriot-Watt International Foundation Pathway. To join this programme you must have a minimum 85% overall with minimum 85% in relevant subjects.
- Students taking A Levels or IB should refer to the programme pages of the prospectus where these are all listed.
- For the majority of our Masters level programmes we require a GPA of 3 out of 5 or equivalent in a relevant subject.
English language requirements
If you do not meet our English language requirements, you can apply to one of our academic English programmes, which are specifically designed to prepare you with the language and study skills needed for academic study.
Tuition fees
Tuition fees are listed alongside each programme in the online prospectuses.
Tuition fees are higher for international students. If you are unsure what your residency status is, you can complete a fee status enquiry form, which allows us to assess whether you have a relevant connection to the UK that might positively influence your fee status.
Learn more about applying for student support in Scotland.
Scholarships & bursaries
At Heriot-Watt we believe that a university education is an investment in your future. That is why we offer a generous package of scholarships to encourage and support well qualified, ambitious students to come and study with us. See the full list of scholarships that you may be eligible to apply for.
The following scholarships are available to all international students who choose to study at Heriot-Watt:
- International Scholarships Programme (School of Textiles & Design)
- International Scholarships Programme (School of Engineering & Physical Sciences)
- Chevening Scholarships
Our representatives in Oman
We work with approved representatives in Oman who can help you apply and enrol on your chosen programme.Find your nearest representative.
Visa & immigration information
Because you are from a visa national country you will have to apply for a UK visa to come to study at Heriot-Watt University regardless of the length of time you expect to study in the UK.
Student Visitor Visa
The Student Visitor Visa is only for non-EEA visa national students coming to study a short course of less than 6 months (or less than 11 months for an English language course). With this visa, you cannot work in the UK and cannot extend it from within the UK.
- To apply for a Student Visitor visa, you need to complete the VAF1D form.
- Learn more about applying for a Student Visitor visa.
Tier 4 Student Visa (in-country application)
The Tier 4 Student visa is for all non-EEA students coming to study in the UK for over 6 months.
To apply for this visa you need to fill the VAF9 and VAF9 Appendix 8: Tier 4 (General) forms and provide the requested supporting documents as specified in the Tier 4 guidance. You will also have to provide your CAS number from your Tier 4 sponsor (Heriot-Watt University), and your biometric features (10-digit finger scans and a digital photograph) in person as part of the application process.
- Learn more about applying for a Tier 4 Student visa.
- Find your nearest visa application processing centre in your home country.
- Learn more about bringing your family to the UK.
Academic Technology Approval Scheme (ATAS)
If you are a postgraduate student you may need to apply for an additional certificate under the Academic Technology Approval Scheme (ATAS).
Only certain programmes are affected by the scheme; your academic School at Heriot-Watt will send you more information about this along with your unconditional offer. Or you can check the Foreign & Commonwealth Office's list of programmes that request the ATAS certificate.
Your ATAS certificate should be printed and submitted as part of the visa application process.
More information
Further information and help can be found on Heriot-Watt University's International Student Advisors' Office (ISAO) website.
Working in the UK
Tier 4 student visa holders studying at higher educational institutions are allowed to work up to 20 hours per week during term time, and full time during vacations if studying at degree level or above, or studying a foundation degree (a programme that leads to a qualification at level 8 of the SCQF).
Students studying any other programme will only be able to work up to 10 hours per week during term time, and full time during vacations.
Please note that term time covers all periods of your programme when you are doing academic work, and includes for example preparing for examinations and time spent producing MSc projects, dissertations and writing up thesis.
Learn more about working during your studies.
Working conditions for Tier 4 dependants
- Dependants of students from outside Europe who come to the UK to study for less than 12 months will be prohibited from working
- Dependants of students from outside Europe who come to the UK to study a programme that is below degree level (except a foundation degree programme) will also be prohibited from working
- Dependants of students from outside Europe who come to the UK to study a programme at degree level for 12 months or more will be able to work during their stay in the UK (part time or full time).
Please note: from 4 July 2011, non EEA international students can only bring their dependants to the UK if they are coming to study at postgraduate level on a programme lasting for at least 12 months (or 6 months if you are a government-sponsored student). To find out if your family members can join you in the UK, please see the guide for Tier 4 family.
Find out more about dependants and bringing your family to the UK.
More information
You can visit our Careers Advisory Service website for more guidance on employment during and after your studies.


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In a statement to ABC News, BP called the chemical "one of the most well-studied dispersants" and said it chose Corexit in part because it could "get a sufficient supply to meet our needs on short notice."
For weeks, the company assured that using the dispersant was safe, with officials describing them like soap suds. But today, others painted a far more sinister picture.
"Any living organism that contacts this stuff, particularly the mixture of dispersant and oil, is at significant risk of acute mortality," said marine biologist Rick Steiner.
In fact, EPA testing released today indicates that where the dispersant had been used, 25 percent of all organisms living at 500 feet below the surface died.
Markey called BP's use of the untested dispersant a "science experiment."
"It is very important that we not allow BP to conduct a science experiment in the oceans of the United States without the closest supervision in terms of the amount of toxic material that is put into the ocean as a way of controlling this spill," he said.
Taken together, the company's resistance to transparently supply footage of the leak and use of a toxic dispersant indicated to him that BP could not be trusted.
"I think now we're beginning to understand that we cannot trust BP. People do not trust the experts any longer," said Markey. "BP has lost all credibility. Now the decisions will have to be made by others, because it's clear that BP has been hiding the actual consequences of this spill."
ABC's Sunlen Miller contributed to this report.


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- Shopping Bag ( 0 items )
From the PublisherIn A Patriot's History of the United States, Larry Schweikart and Michael Allen remind us what a few good individuals can do in just a few short centuries . . . . A fluid account of America from the discovery of the Continent up to the present day. (Brandon Miniter, The Wall Street Journal)
No recent American history challenges the conventional wisdom of academics as aggressively as Larry Schweikart and Michael Allen's A Patriot's History of the United States. (Daniel J. Flynn, Front Page Magazine)
There are a thousand pleasant surprises and heartening reminders that underneath it all America remains a country of ideas, ideals, and optimism—and no amount of revisionism can take that legacy away. (John Coleman, Humane Studies Review)
A welcome, refreshing, and solid contribution to relearning what we have forgotten and remembering why this nation is good, and worth defending. (Matthew Spalding, National Review


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Strongly Catholic GOP candidate pledged Penn State TEP
Former Pennsylvania Sen. Rick Santorum, who had an extremely strong second-place showing in Tuesday's Iowa caucuses and thus heads into next Tuesday's New Hampshire primary with a lot of momentum, is a strict Catholic whose politics (pro-life, anti-gay marriage) are profoundly informed by his faith; he constantly references and credits God for his success. His backers may stress that his opposition to "violent Islamic extremism" will help him with the Jewish vote, but all of Santorum's cultural cues come off as not-so-Jewish.
Except! Eagle-eyed reader A.A. notes (via Wikipedia) that while an undergraduate at Penn State, Santorum was a member of the Tau Epsilon Phi fraternity—it's TEP, one of the Jewish frats. The Website of TEP's Alpha chapter—the organization was founded at Columbia in 1910 by a group of Jewish men who were not allowed entry into the existing frats—confirms that Santorum joins Red Auerbach, Larry King, Jonas Salk, and Benny Goodman, as well as non-Jews including Dwight Eisenhower, as a TEP alum. One of us, one of us?
The History of Tau Epsilon Phi Fraternity [TEP]
Related: After a Child's Death, a Religious Politician Became a Culture Warrior [NYT]
Wealthy Wyoming Invest Fund Manager Bankrolling Pro-Santorum Super PAC [MSNBC]
Earlier: Romney Loses By Not Winning Enough
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May 25, 2015
A baseball team in Knott County suffered a major loss off the field.
Thousands of dollars worth of equipment was stolen from Cordia High School this week.
The baseball coach says the thieves broke into the team's field house and stole everything from uniforms to jackets.
When Joe Melton arrived at Cordia's baseball field Monday morning, he immediately sensed something was wrong.
Melton says the gate's chains were cut off, the doors to the field house were kicked open, and the locks were busted off by burglars.
The burglars ransacked the field house stealing almost everything in site.
Melton says the worst part is that the players spent months raising money for the stolen sports gear.
But the burglars may have some difficulty if they try to pawn off the stolen loot.
Almost everything that was stolen has the school's trademark "wishbone C" on it.
Melton hopes that anonymous tips on Facebook will help police catch the burglars.
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Moto down in Guatemala - Need Advise (1100GS)
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Beastly Adventurer
Joined: Nov 2005
Location: the west
Oddometer: 1,968
You've seen crackhead's thread? If you can not locate that Bosh kit in Guatemala then have someone over-night it to you. It's pretty light. I would pressure wash the inside of the tank. By-pass the in-tank filter with a suitable jumper such as a piece of steel brake tube. Fit Wix 33323 externally to the rear abs line mount hole using the supplied clamp.
Time required to take r-r pump plate and clean tank is just a couple of hours if you have the parts. I have new in-box spares if you need them.
Use posi-lok red barrels inside tank if you don't have a soldering iron.
IMO there isn't a good substitution for the filter inside the tank. PP use one that is not rated for injection and doing so can lead to plugged injectors. The Wix is 10 micron and has plenty of spare capacity. You can also mount it to the rear, under the rear porter. The forward facing pump plate nipple is your pump output. That goes to the external filter then on to the black nylon fuel distributor inlet. Pump outlet pressure should be capable of 100 lph at 50 psi. The air box mounted regulator is pre- set to 43 1/2 psi. Lots of pumps can supply this but only a few mount well to the 11xx pump plate.
Jot down the do's, don'ts and common mistakes before you begin such as not busting off tank studs or using only submersible rated hose inside the tank and you will be fine.
for sale: 1968 R 69 S-us original condition
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Discover Aurora's best-kept secret...
Moebius Nature Center
The Moebius Nature Center exists to promote the enjoyment, respect, and preservation of nature through education to residents and students of Aurora and neighboring communities.
Upcoming Programs/Events
|Straw Bale Gardening (ADULTS)
with a Children's Planting Program
June 6, 2015
11 am
|Finding Fledglings - Summer Hike
June 6, 2015
9 am
How to Register:
Thank you for taking the time to register for your program online. We ask that you register online so that we may have an accurate count of how many people will be attending each event and to provide a convenient check-in list. We also utilize this data to apply for grants and to improve our services (we will never sell or share your info!). And finally, in some cases, we must limit the number of registrants because of space, resources and for the comfort and safety of certain animals at our programs.
If you have registered and find you cannot attend, we would greatly appreciate an email to cancel the registration. This will enable us to share our free nature programs with as many people as possible.
As a courtesy to our speakers and attendees, programs will start promptly at the advertised time. The parking lot is a short walk from the Center, so please plan to arrive a few minutes early. You won't want to miss anything!


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Staff Reporter
Bangalore: Over 80,000 autorickshaws in the city will be off the roads on Monday in protest against what the drivers said "oppressive" measures being adopted by the Government by "imposing" the new colour scheme and insisting on digital fare meters.
Autorickshaw owners and drivers affiliated to various unions will participate in the protest. The participating unions include Autorickshaw Drivers Union (ARDU, affiliated to CITU), Adarsha Auto and Taxi Drivers Union (HMS) and Bangalore Autorickshaw Union.
The Transport Department, after enforcing LPG as an alternative fuel for autorickshaws in Bangalore, has proposed to paint the three-wheelers in green to send out an environment-friendly message. The owners and drivers, however, have opposed the move saying it does not serve any purpose even as the measure imposes heavy financial burden on them. The proposal to install digital fare meters is also a flawed one, they have alleged.
Additional buses
Meanwhile, Bangalore Metropolitan Transport Corporation (BMTC) will operate additional services on Monday.
BMTC Managing Director Syed Zamir Pasha told The Hindu that the corporation will suspend maintenance of buses for a day so that more buses will be available for deployment.


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Cows check in for meals using electronic ear tags
By Ben Coxworth
July 28, 2011
With diseases such as Foot and Mouth, TB, and of course Mad Cow still presenting a danger to cattle, it's of the utmost importance that farmers monitor the health of their animals, and immediately proceed to isolate any that might be showing symptoms. If you have a herd of over 500 cows, however, keeping track of individuals can be rather tricky. That's why scientists at England's Newcastle University have developed electronic ears tags, that they're trying out on a herd of test cattle.
Each ear tag is equipped with an RFID (radio frequency identification) chip, that transmits a short-range signal. Antennas mounted on the feeding troughs will pick up that signal when the cow comes to feed, with a computer keeping track of the amount of time that elapses until the signal is lost when the cow leaves. In this way, the system can keep track of which cows are eating regularly, and that they're getting enough to eat when they do.
If a cow isn't eating enough - which could indicate that it isn't feeling well - the system notifies the farmer, identifying which cow should be looked at.
The cattle also have pedometers attached to their ankles, which measure how much time the animals spend being active versus lying down - another indicator of their health.
"Modern farming systems have minimized the contact between the animal and its keeper," said project co-leader Prof. Ilias Kyriazakis, "so we need to constantly look for ways to re-address the balance."
The Newcastle research was recently published in the Annual Proceedings of the British Society for Animal Science Conference 2011.
We used RFID ear-tags to measure and record individual feed intakes in pigs at automatic feeders (trickle feed - internal scales) and also used them to identify breeding stock.
They are now commonly used in automatic feeding stations for group housed sows - the tag unlocks the feeding area, distributes the allocated amount of feed for that individual animal, usually in small allotments (and in some cases the system also records what is left when she departs the feeder) - only then is the nest one allowed to eat. Each sow ends up with an accurate daily feed intake record, and receives the desired level of feeding.
Very well established systems with 20 years of research and practical trail and error usage.Marke
It is disappointing to see an article claiming to be a breakthrough when the technology has been around for many years. I worked on a development of this exact system in New Zealand five years ago to bring some improvements to some hardware and the feeding algorithms. http://www.youtube.com/watch?v=IP0uUHP8Yww&sns=em
Perhaps you should do some more research before such stories in future. Or make it obvious that it is an existing technology with a new twist or something like that to retain your awesome cred and name.
Btw: still love gizmag!ben
Yes. I have to agree with the others; This technology has been around for a considerable time. In fact, RFID is compulsory in the UK.JohnHL
There is a far better, older, more environmentally friendly, and healthy solution than any of sort of tracking or tagging technology. It\'s called \"eat less meat\". Really, would one less big mac a day be that bad?Charles Bosse
@Charles Bosse, This article has absolutely nothing to do with meat consumption besides the fact that these are milk cows. Most people could tell that from looking at the breed! Having said that, what on earth does tracking/tagging technology have to do with your personal vegetarian message? Perhaps you could take your soapbox and go find a Gizmag article that does relate? I think it is an excellent article even if similar technology exists. Anything that helps automate the monitoring of large herds of any kind of farm animal is a good thing for both the farmer and the animals and like the article says, it helps control diseases. Large animals like these are expensive and most farms operate on some pretty thin margins!Will, the tink


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Chartplotter died, time to upgrade?
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Chartplotter died, time to upgrade?
I have all Raytheon stuff about 12 years old. The cockpit repeater unit quit working last trip. Worked fine one the day but will not power up now. RC530. Wiring checks out ok and I plugged in a spare B&W base unit and it powers up just fine. The base unit is a RL70RC and works fine. The Radar is connected to the base unit.
I don't know who repairs these or if it is cost effective. So, it gets me thinking about upgrading. I am guessing none of my equipment will interface with the new stuff.
I am not in crisis mode as I can use the B&W unit in the cockpit, still have the base unit below while I can try to find an inexpensive replacement RC530.
But what about modernizing. Or piecemeal modernizing. How about a modern stand alone chart plotter for the helm, use the old stuff when I need radar. I hate spending money on this old stuff when it could be applied to newer equipment.
BTW: This older Raytheon stuff is a PITA to use. Nothing intuitive about it.
Comments and opinions welcome, I need education on the new electronics and good models. Someone mentioned the Garmin 740s in a thread recently.
Thanks all
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Pet Website Design
PetWebPro.com specializes in pet business WordPress.org website design and development for Pet Sitters, Veterinarians, Dog Trainers, Pet Bakeries and Boutiques. WordPress is more than just a blogging system, it has evolved to be used as full content management system and so much more through the thousands of plugins and widgets and themes, making every website we create one of a kind. WordPress is an open-source content management system (CMS), giving you the ability to manage your site from anywhere you are connected to the internet.
Website Hosting
Every website needs a website host. A web hosting service allows website owners to make their website accessible via the World Wide Web. PetWebPro.com offers website hosting services with fast loading, reliable service, cPanel access and email. If all of this sounds too technical for you, don't worry. We handle everything from the set up to launch and of course provide you with great service and support after your site is launched.
Domain Management
A domain name is a unique name that identifies an internet resource such as a website. You might recognize it as starting with "www." but not understand much more after that and have questions like how do you register a domain name, is my domain name available, and what the heck is a DNS? PetWebPro.com will help you manage your domain names for your website as part of our all in one services.
Once your website is finished and launched, we continue to be available for support and maintenance as needed. Although you have a built-in content management system to edit your website yourself, there may be times when you need us for a lifeline to help with service or maintenance. We are available an at your service as you need.


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June 8, 2011
Astronaut Pedro Duque, STS-95 mission specialist representing the European Space Agency (ESA), is assisted by suit technician Sharon McDougle in final touches with his Shuttle launch and entry suit. The crew for the scheduled late October, early November mission was participating in a lengthy training session in the Johnson Space Center's systems integration facility.
Topics: Pedro Duque, STS-95, European Space Agency


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Narrow your search
CNET's Marguerite Reardon explains how three key phenomena could reshape the wireless industry in the next few years and pave the way for more-affordable mobile services.
Before you get too excited, it's only a proof-of-concept display. The unveiling is part of a broader announcement to showcase the company's plans for the future, which center on OLED tech.
After its $25 phones fail to dent the dominance of Google and Apple, the Firefox backer will try to compete using technological superiority -- and maybe by adding key Android apps, too.
With an easy tutorial and tons of ways to play, Hearthstone is a must-have game.
For a monthly fee, Adobe hopes to bring us the less-paper office.
The online retail giant will cease funnelling sales through low-tax Luxembourg, a strategy seen as a tax-avoidance effort.
CEO of ZTE's US business tells CNET he prefers the unlocked route for the company's high-end line of smartphones because a carrier partnership means more compromises.
Shame about the supply pinch, though. Without that, sales might actually soar as high as 50 million, says a Morgan Stanley analyst.
Former NASA administrator Sean O'Keefe thanks Tom Cruise for his "blinding flash of the obvious."
Dale Sohn, the former CEO of Samsung's mobile business in the US, also testifies that a shift in the Korean company's sales and marketing efforts boosted its position in the smartphone market.


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We are an organization built around knowledge and people, focused primarily on providing solutions to impact society through information and technology
Our job is to analyze, discover, create, and perfect our clients expectations in a wide variety of services: Web Design & Development, Custom eCommerce Solutions
Actualys is a digital Agency. We assists our clients in the revelation and implementation of the digitalization of their business.
Who Are We: We are a UX centric UK Drupal, mobile and broadcast software development company based in London.
Addvista is a Drupal web agency based in Meudon, France.
We are providing services and training with Drupal such as:
Alter Way, service provider of the digital age
Alter Way is a provider of Digital and IT services, offering a unique 100 % Open Source DNA and an decidedly DevOps and industrial approach.
AMgrade LLC founded back in 2009 is a full-cycle Drupal solutions provider from the date of the company's founding to nowadays with a consistent track record in the industry.
Drupal is a registered trademark of Dries Buytaert.


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The Reformation Study Bible (2015) notes are now available on Bible Gateway! Click to learn more.
21:18 a stubborn and rebellious son. In view here is not the petty disobedience of children, but a long-term pattern of rebellion and deep sin. Although "stubborn and rebellious" is not precisely defined, in v. 20 the son is called "a glutton and a drunkard" (cf. Prov. 23:21). In such cases, even the parents were not to shield their offspring (cf. Zech. 13:2, 3).


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MuLondon's (http://www.MuLondon.com)
Boris Zatezic, the founder and head cream-whipper of MuLondon, says: "I am delighted to have all MuLondon products registered as vegan. By proudly carrying the internationally recognized Sunflower logo of the Vegan Society, we are showing that the entire MuLondon skin care range is suitable for vegans. Veganism is a deliberate, conscious move towards a more compassionate way of life - cruelty-free, sustainable, clean, pure and natural. Those qualities are the building blocks of MuLondon and are reflected in everything we do as a company. Not only is the entire range vegan, but MuLondon is a 100% vegan company, and we will never use any animal-derived ingredients or ones tested on animals. Compassionate vegans, vegetarians and everyone else can now enjoy MuLondon products, knowing that they are doing something good - not only for their skin, by caring for it naturally, but for the good of the environment and animals."
The Vegan Society is a British educational charity that works to promote veganism by supporting people, organisations and companies wanting to commit to a vegan lifestyle. The Vegan Society was founded in 1944 by a group of people who were not quite satisfied with the vegetarian movement and saw the need to coordinate between those among them who had started to question the ethics of still eating eggs and dairy products.
All of MuLondon's moisturisers are carefully and lovingly handmade and contain a unique combination of certified organic Shea Butter, Coconut Butter and Jojoba Oil, herbal extracts and essential oils that hydrate, balance and repair all types of skin, even the most sensitive.
A distinctive feature of MuLondon moisturisers is that they contain no added water. As they are not diluted, a little bit goes a long way, and the customer gets 100% active ingredients, without anything artificial at all.
More information about MuLondon can be found at http://www.MuLondon.com, where customers can place secure online orders, 24/7, with affordable worldwide shipping.
# # #
Established in 2008, MuLondon is based in London, UK, specialising in producing the finest natural and organic products for skin, body and home. MuLondon fine products are made by hand from pure, natural and, where possible, certified organic ingredients. They contain no artificial preservatives, emulsifiers or fragrances. Instead, pure natural essential oils and herbal extracts are used to divinely scent and gently preserve.
All MuLondon products are 100% vegan and are registered by The Vegan Society and PETA. MuLondon never uses any animal ingredients. All suppliers of ingredients to MuLondon are thoroughly vetted and and share the company's green and ethical ideals: no animal testing, proactive environmental, recycling and fair-trade policies and support for community projects.


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ACE Fit Share
Use a combination of these core back exercises to strengthen your lower, upper or middle back areas. Whether you're interested in barbell deadlifts or reverse extensions, we have back strengthening exercises for every level. These exercises are also featured in convenient workout routines that include proper warm-up and cool-down techniques, which greatly reduces the risk of injury.
Fit Life Articles
Summer is just around the corner and that means hot weather and a desire to look your best at the beach. Here are four foods to watch out for that can make you feel water-logged and get you into "bloat" trouble, along with four foods that can help you to look and feel light...
If you're like most people, lack of time is probably your number-one reason for not exercising as often you would like or think you should. So, what's the secret to finding the time for fitness? By actually planning activities that fit your lifestyle—and inspire you to make...
Regardless of what your training goals might be, this functional-training workout will help challenge your body in new ways. These exercises require only your body weight and give you an excuse to enjoy the fresh air as you take your workout outdoors.
ACE Pro Homepage
Copyright © 2015 The American Council on Exercise. All Rights Reserved.4851 Paramount Drive, San Diego, California 92123 1 (888)-825-3636


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Best Christmas Live Wallpaper
10,000 - 50,000 downloadsAdd this app to your listsTweets por @Appszoom
Red Ornament
Candy Cane
Blue Ornament
Green Leaves
3 Green Leaves
Christmas Tree
Pink Ornament
Gift Box
Santa Claus
Snowflake 1
Snowflake 2
Snowflake 3 ... over 14 different flakes
Moreover, we provide over 40 different backgrounds which can be loaded from our web server. This is the only wallpaper you will need this Christmas Season. For only a small fee the paid version will allow you to load background ranging from Christmas Tree, Animated Winter Wonderland, Ornaments, Snowman, Santa Claus, Stars, Winter Cats, Christmas Hat, and many more...
If you have a public domain picture you would like us to add just let us know and we will make sure it is available for you to use as a wallpaper background.
We have invested the time to make sure that this application has the best graphics but also utilizes the performance provided by your phone to its fullest while limiting the battery consumption. Our goal is your satisfaction if for any reason you are not satisfied please e-mail our support team at email@example.com
Tags: best christmas wallpaper, the best wallpaper, rdezign.christmas.live.wallpaper lication.
- This issue resolved major error please update ratings...
(54 stars)
This wallpaper is beautiful in its' simplicity. If you live too far away to see the Aurora, bring it to your phone in a celebration of Christmas with Mother Nature. Thank you! (Ran on Android for over a month perfectly.)
(54 stars)
It just shows up the wallpaper that you can have on the apps. Rubbish if I could do 0 stars I would. DO NOT DOWNLOAD!!!!!!!
(54 stars)
The Full Version does not work. After paying for the Full Version, the Free version is all that shows up on my phone. Opening the free version settings gives you a "Buy Full Version" link. Clicking the link takes me to the Google play store which shows that the paid for version is installed. Opening the paid for version takes me to the free version page. The settings option displays a "custom sett
(54 stars)
It's cute. But why say can't use any of these cool features unless u buy it so u try to buy it & it's not available. Not cool.
(54 stars)
It is a good live backgrounds for any phone
(54 stars)
Variety of stuff one can do. Needs to have more free
(54 stars)


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Artist: Shaun Boothe
Producer: Just Blaze
Album: Waiting Room
Avg Rating: 2.7 ( 3 votes )
Though Twitpics, webcam chats and dirty World of Warcraft sessions have largely replaced Phone Sex as a proxy for old-fashioned physical intimacy, Shaun Boothe prefers to kick it old-school—even if it means occasionally having to put his partner on hold to grab a call on the other line. On the latest leak off his forthcoming, Booth-hosted mixtape, a freestyle over Hova's Song Cry, the T-Dot emcee exhibits an uncanny knack for dirty talk, lacing the classic Just Blaze instrumental with explicit descriptions of what he'd like to do to a certain shawty. For more, check out Waiting Room when it hits the Booth's mixtape page for streaming and download July 19.
Written by richard on Jul 08, 2011
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Office Politics
There are few things as uncomfortable as dealing with difficult workers. Yet dealing with them successfully is a key to business success.
Business Management Daily is known for our sound, field-tested advice on favoritism in the workplace and other challenging office personalities and situations.
Despite mounting turnover at your company, you stay put. But you're starting to reconsider your loyalty as arrogant newcomers get special treatment and higher pay.
Beware of becoming involved in petty office squabbles.
"Know your place" can sound like an insult. But when you're on a team, it's excellent advice.
If you believe Ronna Lichtenberg, everyone has an "evil twin" who goads him to act against his better judgment.
"Know your place" can sound like an insult. But when you're on a team, it's excellent advice.
When you claw your way ahead, you've got to act like you're above it all. You can't let on that you care what your co-workers say about you or do to you. Radiate a low-key intensity so that people underestimate you rather than root for you to fall on your face.
There's nothing I hate more than a showboat. Some cockiness is fine, but I don't like to manage hotshots who corner me to brag about their exploits. Hit me on a bad day and I'm liable to say, "Get out of my face."
You may already hook up new hires with "buddies," experienced employees who can help them adjust to their new surroundings. But there's a better way to make newcomers feel welcome: Give them two buddies.
I had lunch the other day with a director of career planning at a college. She asked, "So what dirty deeds are you most ashamed of? I'd like to give students the real scoop on becoming a CEO."
Ever wonder why some managers create a harmonious, warm atmosphere while others operate in a snake pit?


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Orlandi Statuary
Richelieu Lion Statue
- Color:
- verde
Please select an available size.
Please select a size.
Share This Item: Email
Description: Richelieu Lion Statue:
- Textured hand-stained statue
- Made of fiberstone, a mixture of sand and stones cast with reinforced fiberglass backing
- Suitable for indoor and outdoor use
Measurements: 14" W x 17" D x 26" H
Material: Fiberstone
Care: Wipe with a damp cloth
Brand: Orlandi Statuary
Origin: United States


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Christina Marie Sorensen, 92, of Blackfoot passed away Thursday, July 21, 2011, at Eastern Idaho Regional Medical Center in Idaho Falls.
Marie was born Aug. 25, 1918, in Yates, Utah, to Lorenzo and Margaret Munson. She lived in Utah until the age of two when she moved to Idaho. She spent most of her youth working on the family farm. She was next to youngest of five children.
Marie married Harris "Doc" Sorensen in Blackfoot. They had three sons, Dale, Claren and Grant. They were later divorced.
Ray D. DeRoche, 83, of Blackfoot passed away July 25, 2011, at Eastern Idaho Regional Medical Center in Idaho Falls.
Funeral services will be at 11 a.m. Saturday, July 30, 2011, at the Blackfoot Stake Center (1650 Highland Drive). The family will receive friends Friday from 7-8:30 p.m. and Saturday from 10-10:40 a.m., both at the church.
Interment will be in the Shelley Hillcrest Cemetery. Arrangements are under the direction of Nalder Funeral Home in Shelley.
Condolences can be sent to the family at www.nalderfuneralhome.com.


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Anyone else have a baby with dry mouth??
Noah is 2 1/2 mths(down syndrome) and has a really dry mouth, he doesnt have much saliva. I noticed other babies slobber alot, he doesnt! why??
Started by Brandi on 07/01/2010 in Moms To Children With Down Syndrome
Last update on 07/01/2010 by Brandi


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Video: Tags: Davone Tines
A tag is a word or phrase that helps you find video clips with similar content. View all tags »
Displaying 1 to 2 of 2 results.
PBS NewsHour | Davone Tines sings from I Puritani by Bellini | PBS (#10366)
Davone Tines, 25, sings an aria from I Puritani by Bellini in rehearsal. 00:46
PBS NewsHour | Opera is thriving, a young singer declares | PBS (#10366)
Davone Tines, 25, tells us why he thinks opera is thriving. 02:53
Displaying 1 to 2 of 2 results.
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The PBS NewsHour continues to provide in-depth analysis of current events with a news summary, live interviews and discussions of domestic and international issues.


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Napoles surrendered for fear of her life—lawyer
More News from INQUIRER.net
MANILA, Philippines—In a radio interview on Wednesday, Janet Lim-Napoles' legal counsel, Attorney Lorna Kapunan, said her client surrendered for fear of her life.
"There are really people who want to keep her silent permanently," Kapunan said.
"Therefore now is the right time. Ang sinasabi niya naman ay wala naman siyang tinatago," Kapunan added.
President Benigno Aquino III earlier announced a P10-million reward for information leading to Napoles' arrest.
Kapunan said she didn't know where Napoles came from prior to her surrender, and added that she didn't have any communication with her client when she was still hiding.
Related Stories:
Napoles surrenders to Aquino—Palace
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Factual errors? Contact the Philippine Daily Inquirer's day desk. Believe this article violates journalistic ethics? Contact the Inquirer's Reader's Advocate. Or write The Readers' Advocate:
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Jeremy Clarkson, Shirley Bassey and Joan Collins are among the surprising names on the guest list for the funeral of former Prime Minister Margaret Thatcher. The ceremonial service, also attended by The Queen, was held on Wednesday 17 April.
The former Prime Minister was honoured in a ceremonial service with full military honours today
The former Prime Minister is being honoured in a ceremonial service with full military honours today following her death at the age of 87
Bishop's eulogy brought Chancellor to tears during service
It is the first time the monarch has attended the funeral service of a former prime minister since Sir Winston Churchill's state ceremony in 1965
The former Prime Minister's body will rest in the Palace of Westminster overnight before Wednesday's ceremony
Marco Pierre White, Hugh Scully and Sir Frank Williams are among the latest names to confirm they will attend the ceremony
She announced she is sending Foreign Minister Guido Westerwelle in her place. Spanish PM Mariano Rajoy is also staying away
A rehearsal has been held for the former PM's ceremonial service ahead of the official send-off
Daily Mail editor Paul Dacre, Formula One boss Frank Williams and newsreader Martyn Lewis will also attend
Carol Thatcher thanked well-wishers as she gave a statement outside the family home in Belgravia ahead of her mother's funeral on Wednesday
Details of the 2,300 invitees have been released by Downing Street today but here are those who will most definitely NOT be there to see Maggie off
Former prime ministers, Hillary Clinton and Lord Archer have also been asked to attend the ceremony next Wednesday
The UK's first and so-far only woman Prime Minister will be given a funeral fit for a war hero - with the plans called controversially called True Blue
If you're a beginner, read our How To guides
Easy-to-read analogue dial with digital display functions


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An introduction to support on Envato Market
- Envato staff look over every item before it can be sold on Envato Market.
- Technical items contain help files to introduce you to the item and its components.
- Authors can choose to support their items but this is optional and may vary.
Author support for this item
The author of this item, jdsans, does not currently provide support.
Common WordPress Installation Issues
Missing style sheet error when installing the theme
A common issue that can occur with users new to installing WordPress themes is a "Broken theme and/or stylesheets missing" error message being displayed when trying to upload or activate the theme. This error message does not mean that the theme you have purchased is broken, it simply means it has been uploaded incorrectly. Luckily, there is a very easy fix.
Frequently Asked Questions
After updating to new theme version 2.0 my portfolio items has disappeared
The theme version 2.0 now supports the new blog layout.
Because of that the portfolio items has been shifted to new system named "Portfolio" found in the Wordpress dashboard menu below "Posts".
If you're not seeing "Portfolio" menu item (left side) in your dashboard then this mean the plugin "Syntac custom posts" is not yet installed on your blog. To install the plugin you need to go to "Appearance" >> "Install plugins" >> "And install Syntac custom posts".
So now "BLOG" uses the posting system that was earlier used for creating Portfolio items and portfolio items have been shifted to new system "PORTFOLIO". In portfolio "skills" behave as "categories" in posts.
So you can use the plugin http://wordpress.org/plugins/post-type-switcher/ to shift your Portfolio items to new Portfolio system.This plugin takes seconds to shift the items.
To shift "portfolio items" to new system "Portfolio" follow these step:-
1. Login to your wordpress dashboard and open "Posts" 2. Now select all the "Posts" and in "Bulk actions" (Top) select edit and click "Apply" 3. Now you'll see and option named "Post type", open and select "Portfolio" 4. Select "Update" and you're items have been shifted.
Note – Unfortunately, you will be required to add skills again for the portfolio items as they can't be shifted.
Text description on pages gets cut off to certain characters
The text being cut is actually a feature of this theme. To make the text appear complete there is another section named "Enter short description here" below the editor of whatever page you're editing.
If any text is entered to that section not only it will replace the text entered in the editor but it will also appear complete.
Also this section is not like editor so you'll need to add HTML tags to style the text made visible through this section
When to contact Help Team
Authors are experts on their own items, but if you're having trouble using Envato Market you should come straight to Help Team.


text: The A more perfect union wiki last edited by jeffreyv2512 on 08/15/13 06:58AM View full history The return of Citizen V! Charcoal has been abducted by the Imperial Forces, the mysterious organization responsible for his creation! In order to get him back, the Thunderbolts must infiltrate their enemy's ranks, but what they find is just the tip of a criminal conspiracy that cuts across the length and breadth of the entire Marvel Universe! Will Citizen V aid the T- Bolts... or betray them?!


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Winning Proposals Transform Power Plants into Public Art
Winners have been announced for the 2014 Land Art Generator Initiative (LAGI). The competition, this year sited in Copenhagen, calls on interdisciplinary teams to design large scale site-specific artworks that provide renewable electricity to the city at a utility-scale (equivalent to the demand of hundreds or even thousands of homes). Once constructed, these public infrastructure artworks have the potential to offset thousands of tons of CO2 and provide iconic amenities that will serve to educate and inspire the communities in which they are built.
Check out the winning energy-generating sculptures, after the break.
AZPA Proposal To Transform German Power Plant Into a 'Green Mountain'
Although necessary, power plants are typically an eyesore that don't attract much positive attention. As Thomas Heatherwick put it, "we are ashamed of how we generate our energy." Breaking the mold, a proposal by architecture firm AZPA (Alejandro Zaera-Polo Arquitectura) plans to transform a German power plant into a densely-forested "green mountain", which will in turn be a landmark public space for a town.
Read more after the break…


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SleepLittleBaby Winnie & Tigger Bedding Set with Duvet & Pillow for Cot or Cotbed
- Mumsnet Reviews
- Product Information
Your Reviews
"Looks beautiful and worth every penny…"
We have our 1 year old niece come and stay with us every other week and so we purchased a travel cot and a Disney Winnie & Tigger Bedding Set. The duvet covers are the most beautiful I have seen anywhere and the quality is very high. While buying toys for my niece I find that they can be either expensive rubbish or well made, this bedding set was definitely worth the money and puts a smile on our face every time we use it.Read moreLess
Mumsnetter auntmk1Number of total reviews contributed on Mumsnet1Number of Nursery reviews contributed
1 review posted


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Slabsides (John Burroughs Cabin)
Slabsides in 2005
|West Park, NY
|Nearest city
|41°47′40″N 73°58′23″W / 41.79444°N 73.97306°WCoordinates: 41°47′40″N 73°58′23″W / 41.79444°N 73.97306°W
|170 acres (68 ha)
|John Burroughs
|Architectural style
|Adirondack log cabin
|Governing body
|John Burroughs Association
|NRHP Reference #
|Significant dates
|Added to NRHP
|November 24, 1968[1]
|Designated NHL
|November 24, 1968[2]
Slabsides is the log cabin built by naturalist John Burroughs and his son on a nine-acre (3.6 ha) wooded and hilly tract in 1895 one mile (1.6 km) east of Riverby, his home in West Park, New York. From the time of its construction to the last year of his life, he received many visitors here, ranging from Theodore Roosevelt and Henry Ford to students from Vassar College, just across the Hudson River.[3]
Building and site[edit]
Slabsides is a simple one-story log cabin with an open living/dining/kitchen/study area and a bedroom that can be partitioned off. It is located in a relatively low stretch of the Marlboro Mountains, perched on the west side of a hill in the wooded John Burroughs Nature Sanctuary. There is no direct access by motor vehicle; to reach it, visitors must park on the gravel road up the hill and follow a gated logging road slightly downhill, then level, roughly 0.3 mile (500 m) to the cabin.
"Life has a different flavor here", Burroughs wrote of the cabin in his essay "Far and Near". "It is reduced to simpler terms; its complex equations all disappear." The name "Slabsides" came from the rough bark-covered lumber strips covering its outer walls. "I might have given it a prettier name, but not one more fit, of more in keeping with the mood that brought me thither". Much of the cabin remains as he and his son built it, including the red cedar posts holding up the porch.[3]
After his death in 1921, the property was presented to the John Burroughs Association, which had just been formed to preserve his legacy. When nearby logging operations and proposed development threatened the property in the mid-1960s, the association purchased the properties with money raised from supporters. This has resulted in an expansion of the property into the 170 acre (68 ha) John Burroughs Sanctuary. The cabin was designated a National Historic Landmark in 1968,[2][4] joining Riverby and Woodchuck Lodge as Burroughs-associated properties carrying that designation.
To reach the cabin, visitors must park at the base of the road to it on Burroughs Drive and walk up a half-mile (800 m). The cabin itself, furnished exactly as it was when Burroughs left it, is only open to visitors twice a year, from noon to 4:30 p.m. on the third Saturday in May and the first one in October.[3] Hiking trails have been constructed for visitors to enjoy for themselves the woods that inspired Burroughs. The sanctuary is open year-round.[3]
See also[edit]
- ^ a b "National Register Information System". National Register of Historic Places. National Park Service. 2007-01-23.
- ^ a b "Slabsides (John Burroughs Cabin)". National Historic Landmark summary listing. National Park Service. 2007-09-11.
- ^ a b c d Breslof, Lisa; 2007; Slabsides; retrieved June 4, 2007 from amnh.org.
- ^ Richard Greenwood (February 1976). "National Register of Historic Places Inventory-Nomination: Slabsides, John Burroughs Study" (PDF). National Park Service., (Note misfiled under REFNUM for Riverby rather than REFNUM for Slabsides) and Accompanying 3 photos, exterior and interior, from 1975 and undated. PDF (618 KB)
External links[edit]
|Wikimedia Commons has media related to Slabsides.


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Mon-Fri: 7am-1am EST / Sat-Sun: 7am-11pm EST
ApplianceJenn-Air Range
Level of DifficultyReally easy
Time to do repairLess than 15 mins
Age of ApplianceMore than 10 years
20 out of 686 people found this instruction helpful
First of all, I could not believe how quickly I received the 2 new Jenn-Air Coil element cartridges!! It seemed like I had just ordered them and next thing I knew, Fed-Ex was ringing my doorbell to deliver them!! Also, I received both cartridge boxes at the same time so this was really great! My experience in the past in ordering two of one item is that the second item is usually shipped a few days later.This was one of the easiest installations & repairs I have ever done! Given the age of the stove, the old cartridges had a burner on each one that did not work properly. Also, one of the cartridges was beginning to rust on the underside, due to age.It took approximately 2 minutes to remove the old burner cartridges and install the new ones. All I had to do is slightly lift the lip edge of the cartridge and "unplug" it from the stove which merely entailed either moving the cartridge toward me or away from me, depending on which side of the stove I was replacing the cartridge on. Then, I just simply slid the cartridge into the appropriate plug in the stove. That was it!I immediately checked all burners and I could not believe the difference! The burners immediately reached the desired temperature whereas the old elements that worked took a couple of minutes to heat properly. Now, the Jenn-Air looks like a new stove and is ready for holiday cooking!!! Thank you so very much for processing my order quickly. I will definitely order any future parts needed from your company. On a scale of 1 to 10, I give you an 11.
Help other customers find the most helpful instructions.
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Part Number: PS8769936
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The PartSelect logo is a Registered Trademark of Atlantic Laundry Centres, Ltd.
Copyright © 1999-2015 , Eldis Group Partnership. All rights reserved.


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Indonesia orders 200,000 to evacuate as volcano erupts
Published on Feb 14, 2014 6:46 AM
JAKARTA (AFP) - Hundreds of thousands of Indonesians were ordered to evacuate on Friday after a volcano on the main island of Java erupted spectacularly, hurling red hot ash and rocks over a huge distance.
The alert status for Mount Kelud, considered one of the most dangerous volcanoes on densely populated Java, was raised late Thursday just hours before it began erupting.
TV pictures showed ash and rocks raining down on nearby villages as terrified locals fled in cars and on motorbikes towards evacuation centres.
National disaster agency spokesman Sutopo Purwo Nugroho said that some 200,000 people from 36 villages in a 10-kilometre (six-mile) area around Kelud, in Kediri district in eastern Java, were being asked to evacuate.
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