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IN THE SUPREME COURT STATE OF FLORIDA CASE NO. SC01- LOWER TRIBUNAL CASE NO. 99-07778 CA(27) In the Matter of a Petition for a Writ on Behalf of TIMOTHY W. HARRINGTON, Individually, and as Lead Counsel of THE LAW OFFICE OF TIMOTHY W. HARRINGTON, Petitioner. German A. Gutierrez, Plaintiff vs. Carlos Antonio Orellano, Defendant. PETITION FOR THE EXERCISE OF THE FLORIDA SUPREME COURT'S ALL WRITS POWER Joseph W. Hatchett Miles A. McGrane, III Florida Bar No. 0034486 Florida Bar No. 201146 Robert J. Telfer III MCGRANE & NOSICH, P.A. Florida Bar No. 0128694 2801 Ponce de Leon Blvd. AKERMAN, SENTERFITT 12th Floor & EIDSON, P.A. Coral Gables, Florida 301 South Bronough Street, 33134 Suite 200 Telephone: (305) 442- 4800 P.O. Box 10555 Facsimile: (305) 442-2339 Tallahassee, Florida 32302-2555 Telephone: (850) 222-3471 Facsimile: (850) 222-8628 Counsel for Petitioner Timothy W. Harrington, Law Office of Timothy W. Harrington and Allstate Insurance Company TL019991;1 PETITION FOR THE EXERCISE OF THE FLORIDA SUPREME COURT'S ALL WRITS POWER Pursuant to Article V, section 3(b)(7) of the Florida Constitution, Timothy W. Harrington, individually and as Lead Counsel of The Law Office of Timothy W. Harrington, and Allstate Insurance Company (collectively, "Petitioner"), petitions this Court to issue all writs necessary to preserve the Court's exclusive jurisdiction to discipline attorneys under Article V, section 15 of the Florida Constitution. Petitioner requests that this Court issue a writ directing the Honorable Paul Siegel to vacate his June 15, 2001 Order Prohibiting Allstate Attorneys From Using Law Firm Name In Division 27 Proceedings and his July 20, 2001 Order Prohibiting Insurance Company In-House Attorneys From Using Firm Names In Division 27 Proceedings, because these Orders constitute an unauthorized exercise of the constitutional power which rests exclusively in this Court. I. INTRODUCTION This proceeding seeks review of two orders that Circuit Judge Paul Siegel entered against the Petitioner. The first order, entered June 15, 2001 in Gutierrez v. Orellano, Miami- Dade County Circuit Court Case No. 99-0778 CA(27) (the "Gutierrez Order"), forms the backbone of this Petition. A copy of the Gutierrez Order is in the Appendix at Tab "A". TL019991;1 2 The Gutierrez Order essentially regulates the manner in which Timothy W. Harrington and The Law Office of Timothy W. Harrington conduct the practice of law in Division 27 of the Miami-Dade County Circuit Court. In fact, the Gutierrez Order declares that Mr. Harrington, and attorneys practicing in his law firm, are in violation of disciplinary rules that this Court has adopted. See Gutierrez Order, App. A, at §§ 3-4. The Gutierrez Order further ponders whether Petitioner generated or contributed to any false or intentionally misleading testimony during trials, despite Judge Siegel's candid admission that he did not have sufficient facts or evidence to draw such a conclusion. See Gutierrez Order, App. A, at §§ 5-9. Petitioner moved for a Stay and Reconsideration of the Gutierrez Order. Soon after Judge Siegel entered the Gutierrez Order, he entered an Order to Show Cause why in- house attorneys for other insurance companies should be prohibited from using law firm names in Division 27 of the Miami-Dade County Circuit Court. At the hearing on this Show Cause Order on July 18, 2001, Judge Siegel considered Petitioner's Motions for Stay and Reconsideration, and permitted counsel for Petitioner to be heard on these motions. Judge Siegel entered an omnibus Order on July 20, 2001, in TL019991;1 3 Delgado v. Gonzalez, Miami-Dade County Circuit Court Case Nos. 97-25826 CA(27), 98-12018 CA(27), 99-12680 CA(27), 00-28545 CA(27) and 01-06755 CA(27) (the "Gonzalez Order"), which regulated the manner in which in-house attorneys at other insurance companies could conduct the practice of law in Division 27, and denied Petitioner's Motions for Stay and Reconsideration. A Copy of the Gonzalez Order is in the Appendix at Tab "B". Petitioner seeks review of the Gonzalez Order as well. II. JURISDICTIONAL STATEMENT Article V, Section 3(b)(7) of the Florida Constitution vests the Court with the power to issue all writs necessary to the complete exercise of its jurisdiction. The Court's "all writs" power is properly invoked when the Florida Constitution confers jurisdiction on the Court to undertake or exercise a direct and discrete responsibility. See, e.g., Rowe v. Pinellas Sports Auth., 461 So. 2d 72, 74 (Fla. 1984) (exercising all writs jurisdiction based on the Court's constitutional jurisdiction to review bond validations); Florida Senate v. Graham, 412 So. 2d 360, 361 (Fla. 1982) (exercising all writs jurisdiction based on the Court's constitutional jurisdiction to review apportionment of the legislature). TL019991;1 4 Article V, Section 15 of the Florida Constitution vests the Court with the "exclusive jurisdiction to regulate the admission of persons to the practice of law and the discipline of persons admitted." See also Florida Rules of Professional Conduct 3-1.2 ("[t]he Supreme Court of Florida has the inherent power and duty to . . . determine what constitutes grounds for discipline of lawyers [and] to discipline for cause attorneys admitted to practice law in Florida . . . ."). An "exclusive" jurisprudential power is one that is possessed to the exclusion of others. Seaboard Air Line R. Co. v. Gay, 68 So. 2d 591, 593 (Fla. 1953). The circuit court's Gutierrez and Gonzalez Orders contravene this Court's exclusive jurisdiction to regulate the practice of law in Florida. As recognized in this Court's opinion in State ex rel. Chiles v. Public Employees Relations Comm'n,"[b]ecause the regulation of attorneys falls within the Court's ultimate power of review, the all writs clause could arguably be invoked as a basis for this Court's jurisdiction." 630 So. 2d 1093, 1094-95 (Fla. 1994). Because the regulation of attorneys falls exclusively within the power of this Court, a review of the Gutierrez and Gonzalez Orders can only be obtained in this Court. In fact, Judge Siegel fully expected that this Court would review his TL019991;1 5 orders, believing that his orders would be appealable to the Third District Court of Appeal and "rapidly" sent to the Court through the by-pass certification: In the court's view, the issues dealt with in this order are best resolved by the Florida Supreme Court . . . because the issues are "of great public importance" and "have a great effect on the proper administration of justice." Gonzalez Order, App. B, at ¶ 6 (emphasis in the original).1 Although his understanding of the appealability of circuit court Orders was inaccurate2 and he had been specifically so advised, he recognized the indispensability of review in this Court. Judge Siegel's recognition in the Gonzalez Order that his Order is of great importance to the proper administration of 1 Judge Siegel did not make a similar proclamation in the Gutierrez Order, but did acknowledge that The Florida Bar may need to resolve the problems presented in his Order. See Gutierrez Order, App. A, at §§ 3-4. 2 Judge Siegel suggested that the Gonzalez Order could be appealed to the Third District Court of Appeal as a final order, a post-judgment order or as an injunction. See Gonzalez Order, App. B, at § 6. Neither the Gutierrez nor Gonzalez Orders: are the conclusion of all judicial labor in the proceeding; follow any judgment in the lawsuit; or grant or deny injunctive relief to any party. Judge Siegel's suggestion that the Third District can utilize "by pass" jurisdiction to send his Orders to the Florida Supreme Court is similarly inefficacious, since certification cannot be predicated on the false assumption that the order would be appealable to the Third District Court of Appeal in the first instance. TL019991;1 6 justice is an acknowledgment that the Order does not merely operate to control proceedings in his "small bailiwick," or have any effect in other courts or in other divisions of the Miami-Dade County Circuit Court, as he had suggested in the Gutierrez Order. See Gutierrez Order, App. A, at § 3.3 His assertion that this Court should review these Orders rapidly is a recognition that the Orders have immediate effects on the practice of law on a large group of attorneys in Miami-Dade County, and that the Third District Court of Appeal lacks the subject matter jurisdiction to address the disciplinary effects of his Order. Petitioner has invoked the jurisdiction of this Court because Judge Siegel has entered Orders which purport to regulate the manner in which Petitioner practices law in circuit court. Petitioner is entitled to a review of Judge Siegel's attempts to exercise disciplinary power over Petitioner's practice of law, and other than the Florida Supreme Court, no forum exists with the authority or 3 In fact, this issue is under consideration in at least one other Florida jurisdiction and is likely to propagate around the state. In Seminole County, Allstate has received a Motion to Compel that a private party Plaintiff filed, requesting the Circuit Court to enjoin the practice of permitting staff counsel for Allstate (Law Offices of Robert Soifer) from appearing and holding themselves out as a law firm. The Motion relies extensively on the Gutierrez Order. A copy of the Motion to Compel is in the Appendix at Tab "C". TL019991;1 7 jurisdiction to undertake that review. III. STATEMENT OF THE CASE On June 11, 2001, Circuit Court Judge Paul Siegel issued an order to show cause directed to Allstate Insurance Company ("Allstate") in the then-pending Gutierrez case, directing Allstate to show why the law firm that Mr. Harrington managed- -The Law Office of Timothy W. Harrington--should not be held to be in violation of the ethical rules governing members of The Florida Bar, and for that reason be barred from filing pleadings and correspondence in Judge Siegel's division of the Miami-Dade County Circuit Court which bear the caption of his law firm "The Law Office of Timothy W. Harrington." See June 11, 2001 Order to Show Cause, in the Appendix at Tab "D".4 Judge Siegel conducted a hearing on the June 11, 2001 Show Cause Order on June 15, 2001. Following that hearing--on the same day--Judge Siegel entered the Gutierrez Order, Prohibiting Allstate Attorneys From Using Law Firm Name in Division 27 Proceedings. Petitioners thereafter filed Motions for Stay and Reconsideration of the Gutierrez Order. In the meantime, Judge Siegel issued similar Show Cause Orders directed to other law firms, and held a hearing on July 18, 4 Judge Siegel issued similar show cause Orders on or about June 27, 2001 to other law firms with proceedings pending in his court. TL019991;1 8 2001. At that hearing, Judge Siegel considered Petitioner's Motions for Stay and Reconsideration. Judge Siegel issued the Gonzalez Order on July 20, 2001, which prohibited other law firms from using their respective law firm names, and denied Petitioner's Motions for Stay and Reconsideration.5 IV. STATEMENT OF THE BACKGROUND FACTS Allstate maintains a staff counsel office in Miami that operates under the name "Law Office of Timothy W. Harrington." The lawyers in that office are employees of Allstate and their primary responsibility is to defend insureds for whom Allstate provides a defense under liability insurance policies.6 Those lawyers do not solicit representation of clients that Allstate has not assigned to the office, and neither solicit nor accept any matters for their insured clients other than defense pursuant to a policy of insurance. The office is an unincorporated division of the Allstate Law and Regulation Department, and is not an independent entity. Allstate leases 5 Judge Siegel also deferred ruling on whether the pleading signature blocks must contain a statement of the relationship of counsel to the insurer, opting instead for a hopeful decision from The Florida Bar or this Court. See Gonzalez Order, App. B, at ¶ 4. 6 Staff counsel's defense of insureds is ethically permissible and does not constitute the unauthorized practice of law. See In re Rules Governing Conduct of Attorneys, 220 So. 2d 6 (Fla. 1969). TL019991;1 9 or owns the premises that the law offices occupy. Allstate also pays directly the law offices' expenses (including salaries, court and discovery expenses and fees for expert witnesses). Timothy W. Harrington is the lead counsel of the office and exercises the same supervisory responsibility over the other attorneys in the office as he would were he a sole proprietor and they were his employees.7 The lawyers practice collectively, assisting one another and calling on one another for assistance. The office constitutes a "law firm" pursuant to the definitions in the Florida Rules of Professional Conduct.8 The office uses letterhead, business cards and signs describing it as "Law Office of Timothy W. Harrington." Immediately under that designation is the description: STAFF COUNSEL Allstate Insurance Company 7 See Florida Rules of Professional Conduct 4-5.1(a) ("[a] partner in a law firm shall make reasonable efforts to ensure that all lawyers in the firm conform to the Rules of Professional Conduct."); 4-5.1(b) ("[a] lawyer having direct supervisory authority over another lawyer shall make reasonable efforts to ensure that the other lawyer conforms to the Rules of Professional Conduct."). 8 In the comments to Florida Rule of Professional Conduct 4-1.10, the term "firm" is defined as including "lawyers employed in the legal department of a corporation . . . ." TL019991;1 10 Encompass Insurance.9 Allstate's Florida claims offices send cases to the staff counsel office for defense. The staff counsel office screens such cases to determine which cases it should assign to outside law firms. The staff counsel office will identify any case with an active reservation of the right to deny indemnity coverage on the initial suit referral form that the claims office provided, and the staff counsel will assign the case to an outside law firm as soon as it learns of the reservation. Staff counsel will assign to an outside law firm any case involving claims of one Allstate insured against another or otherwise involving a likelihood of some conflict of interest. Any case involving a probability of liability in excess of the applicable policy limit will be assigned to an outside law firm promptly after that likelihood is recognized. In the initial representation letter, Petitioner clearly states to all insured clients that the attorney is an employee of Allstate.10 That letter also states that, if the insured 9 Encompass Insurance is a division of Allstate, and for purposes of this Petition, this Court should consider the term "Allstate" to include both Allstate Insurance Company and Encompass Insurance. 10 An example of an initial representation letter is in the Appendix at Tab "E". Petitioner has redacted certain portions of this letter for confidentiality purposes. TL019991;1 11 client has or may have an affirmative claim against the plaintiff in the lawsuit, the staff counsel office will not handle the claim and directs the insured to retain personal counsel to pursue the claim. If a staff counsel lawyer learns of any pending traffic citation in connection with an accident, or any other matter in which legal assistance may be useful but is separate from the defense Allstate provides pursuant to the policy, the staff counsel will: (1) alert the client to the possible need for legal services (if the client is not already aware); and (2) inform the client that the Law Offices of Timothy W. Harrington will not provide those services. Staff counsel prepare and file pleadings connoting "Law Office of Timothy W. Harrington" as representing the insured client. They do not disclose the relation of the office to Allstate in the pleadings. As explained more fully in the argument section below, Petitioner did not disclose this relationship because it is ordinarily not material to any matter before the court in which the pleading is filed, and omitting any mention of it helps effectuate the public policy against informing juries of the involvement of insurance. See Fla. Stat. § 627.4136; Beta Eta House v. Gregory, 237 So. 2d 163 (Fla. 1970). TL019991;1 12 On June 11, the trial court, on its own initiative, entered an Order to Show Cause in Gutierrez v. Orellano on the question of whether staff counsel for Allstate should be prohibited from appearing and conducting litigation in Division 27 of the circuit court under the name "Law Office of Timothy W. Harrington." See Order to Show Cause, App. D. After a hearing on the show cause order on June 15, in which counsel for Allstate and The Florida Bar participated, the court issued the Gutierrez Order (on the afternoon of June 15), prohibiting Allstate lawyers from using the law firm name in Division 27 proceedings. Petitioner filed motions for Reconsideration and Stay of the Gutierrez Order. On July 20, 2001, the court issued the Gonazlez Order which, inter alia, denied Petitioner's Motions for Reconsideration and Stay. V. RELIEF REQUESTED Petitioner respectfully requests that this Court issue writs directing Judge Siegel to vacate his Orders of June 15, 2001 and July 20, 2001 (the Gutierrez and Gonzalez Orders) as constituting an unauthorized exercise of the constitutional power that rests exclusively in the Florida Supreme Court. Petitioner further requests that this Court affirmatively hold that the use of a law firm name for staff attorneys for an insurance company is not deceptive and is approved for use in TL019991;1 13 legal proceedings in all courts of Florida. VI. ARGUMENT Judge Siegel's Gutierrez and Gonzalez Orders invade the Florida Supreme Court's exclusive jurisdiction to discipline attorneys under Article V, section 15 of the Florida Constitution. In addition, no controlling precedent supports Judge Siegel's conclusion that the designation in letterhead and pleadings of "Law Office of Timothy W. Harrington" is violative of the Florida Rules of Professional Conduct. Judge Siegel further augments this error in the Gutierrez Order by suggesting that Petitioner may have generated or contributed false or intentionally misleading testimony during trials, despite his candid admission that he did not have sufficient facts or evidence to draw such a conclusion. Petitioner respectfully requests that this Court issue all writs necessary pursuant to Article V, section 3(b)(7) of the Florida Constitution, to preserve its exclusive jurisdiction to discipline attorneys. TL019991;1 14 A. The Letterhead Does Not Violate Florida Rules of Professional Conduct Because It Discloses Fully the Status of Attorneys As Full-Time Employees of Allstate. A cornerstone of Judge Siegel's Gutierrez Order is that the letterhead that Petitioner utilizes is violative of the Florida Rules of Professional Conduct. See Gutierrez Order, App. A, at ¶¶ 2-3; see also Gonzalez Order, App. B, at ¶ 4.11 In the Gutierrez Order, Judge Siegel relies on Florida Bar Ethics Opinion 98-3, and the Tennessee Supreme Court's opinion in In re Youngblood, 895 S.W. 2d 322 (Tenn. 1995) to support this conclusion. In the Gonzalez Order, Judge Siegel supplements his conclusion with additional authority from New Jersey and Indiana. See Gonzalez Order, App. B, at ¶ 3. Judge Siegel is incorrect in his conclusion that Petitioner's letterhead violates the Florida Rules of Professional Conduct, and his reliance on a Florida Bar Ethics Opinion and inapposite caselaw from foreign jurisdictions only undermines his conclusion. 1. Petitioner's Letterhead is not Misleading and Complies with Florida Rules of Professional Conduct. Petitioner's letterhead represents that the lawyers in the staff counsel office function as a firm, that Timothy W. 11 A copy of the letterhead from the Law Office of Timothy W. Harrington is attached as Exhibit B to the Gutierrez Order, App. A. TL019991;1 15 Harrington is the lead counsel of that firm and that the firm serves as staff counsel to Allstate. All of these representations are accurate. The Florida Rules of Professional Conduct recognize that lawyers in a corporate legal department constitute a firm and are subject to the same ethical duties of supervision as those practicing in a partnership or other form of business organization. As mentioned previously, the Comments to Florida Rule of Professional Conduct 4-1.10 define the term "firm" to include "lawyers employed in the legal department of a corporation or other organization . . . ." Further, Timothy W. Harrington is the lead counsel of the office and exercises the same supervisory authority over the other attorneys in the office as he would were he a sole proprietor and they were his employees. See Florida Rules of Professional Conduct 4- 5.1(a); 4-5.1(b). Florida Rule of Professional Conduct 4-7.10 governs the manner in which attorneys in Florida may hold themselves out to the general public. Rule 4-7.10(a) prohibits the use of false, misleading or deceptive firm names, letterheads or other professional designations. Rule 4-7.10(b), however, permits the use of "trade names" if the name is not deceptive, does not imply a connection with a government agency or with a TL019991;1 16 public or charitable legal services organization, does not imply that the firm is something other than a private law firm, or is not otherwise in violation of Rule 4-7.2(b)(1) (concerning "Statements About Legal Services"). Rule 4- 7.10(f) allows that lawyers may state or imply that they practice in a "partnership or authorized business entity" only when that is the fact. Additionally, the Comments to Rule 4- 7.10 state that "[a] firm may be designated by the names of all or some of its members, by the names of deceased members where there has been a continuing succession in the firm's identity, or by a trade name such as 'Family Legal Clinic.'" Petitioner's letterhead does not conflict with Rule 4- 7.10. When read in its entirety, Rule 4-7.10's purpose is to restrict the manner in which traditional law firms may identify themselves. While nothing in Rule 4-7.10 specifically endorses the Petitioner's letterhead, nothing in the rule forbids it. In fact, Petitioner's letterhead clearly discloses its trade name and the staff counsel's relationship to Allstate. Judge Siegel's finding that Petitioner's letterhead is misleading is clearly erroneous. The letterhead discloses that the firm is "Staff Counsel" to Allstate. The letterhead cannot be read to represent that the firm is independent of Allstate, because the existence of TL019991;1 17 a relationship is fully disclosed. The term "staff counsel" is commonly used to denote an employment relationship and that meaning is widely recognized in the legal community. Moreover, because the lawyers in the staff counsel office function as a firm, are subject to supervision within the office and share confidences among themselves, it could be a misrepresentation to hold themselves out to the public as if they were solo practitioners. 2. Judge Siegel erred in finding that Petitioner's letterhead was misleading and in relying on unpersuasive authority to reach this conclusion. Judge Siegel, at the show cause hearing for Gutierrez on June 15, 2001, undertook an evidentiary determination based on the traditional law firm indicia to determine whether the Law Office of Timothy W. Harrington was operating as a partnership or professional corporation. Among his findings was that the staff counsel office "has no employees, does not file tax returns, has no occupational license, no bank account, does not buy computers, copiers, telephones or office supplies." Gutierrez Order, App. A, at ¶ 2. Judge Siegel based his conclusion that the Petitioner's letterhead violates Florida Bar Rules in large part on these findings. This inquiry into whether the Law Office of Timothy W. Harrington was a partnership or business entity ignores the clear and full TL019991;1 18 disclosure on the Petitioner's letterhead that the law firm was "STAFF COUNSEL, Allstate Insurance Company." The letterhead discloses that the firm is staff counsel to Allstate and cannot be read to represent that the firm is independent of Allstate, because the existence of a relationship is fully disclosed. The term "staff counsel" is commonly used to denote an employment relationship and that meaning is widely understood in the legal community. Indeed, the New York State Bar Association recently opined that "[a] group of lawyers who are salaried employees of an insurance company and whose practice is exclusively in defense of the company's policyholders may hold themselves out as a law firm if (a) they undertake to act consistently with the professional responsibilities of a law firm . . . and (b) they provide a clear explanation in all their public communications that they are employees of the insurance company." New York State Bar Ass'n Comm. on Pof'l Ethics, Op. 726, 2000 WL 567960 (2000). The disclosure on the letterhead for the Law Office of Timothy W. Harrington therefore could not mislead the court or the general public.12 12 The "general public" may never see this letterhead, because lawyers in the Law Office of Timothy W. Harrington only represent their insured clients. The only way anyone other than Allstate can become a client of the staff counsel office is to have a damage-producing incident while covered by TL019991;1 19 In fact, it is this disclosure that forms the analysis of whether the letterhead is misleading. In Bar Ethics Opinion 98-3, which Judge Siegel relied upon in concluding that the letterhead was violative of the Florida Rules of Professional Conduct, the Professional Ethics Committee stated "the relationship between the attorney and the insurer should be fully disclosed to the client and appear on the letterhead and business card of the attorney." Of course, this is consistent with Rule 4-7.10, which prohibits false, misleading or deceptive letterhead. Notwithstanding Petitioner's argument below that Judge Siegel erred in relying on Opinion 98-3, Petitioner's letterhead does comply with Opinion 98-3 because it clearly discloses the relationship between the Law Office of Timothy W. Harrington and Allstate. Judge Siegel, however, mistakenly relied on Bar Ethics Opinion 98-3, as well as Florida Bar Staff Opinion 22624 (Aug. 14, 2000), in concluding that the Petitioner violated ethical requirements governing lawyers. Ethics opinions and staff an Allstate insurance policy, be sued as a result, tender the defense to Allstate and have the defense assigned to the staff counsel office. Ordinarily, the first item a client would receive from the staff counsel office is a notice that Allstate has assigned the staff counsel to handle the defense. Any correspondence would be on this letterhead, which discloses the relationship between the staff counsel and Allstate. The text of the initial letter discloses that the assigned lawyer is an Allstate employee. See App. E. TL019991;1 20 opinions are non-binding authority, and provide no legal efficacy for disciplinary opinions or court action. The Florida Bar's Board of Governors has adopted The Florida Bar Procedures for Ruling on Questions of Ethics, to "govern the manner in which advisory ethics opinions are issued and reviewed by The Florida Bar." Rule 1. Rule 9 describes opinions of the Professional Ethics Committee as "advisory only," and it prohibits their use as a "basis for action" even by the agencies charged with enforcing the disciplinary rules (except on application of the respondent in disciplinary proceedings). The advisory nature and restricted use of opinions that the Ethics Committee and its staff issue reflect the Bar's recognition that the Supreme Court alone is responsible for defining and regulating attorney conduct which is subject to discipline, through the promulgation of rules and decisions. Expressions of opinion through the Bar or its staff lack the procedural safeguards which surround the promulgation of rules, and which inhere in the appellate process through which the Court sets policy in this area through its decisions. The purely advisory nature of opinions of the Ethics Committee, such as Ethics Opinion 98-3, necessarily means that courts may not use those opinions as a basis for disciplinary action. TL019991;1 21 Moreover, no court, other than the Florida Supreme Court, has independent disciplinary authority. See, e.g., Smith v. Bateman Graham, P.A., 680 So. 2d 497, 499 (Fla. 1st DCA) (holding that Bar ethics opinions "can provide no basis for a private cause of action" because they are advisory only), review dismissed, 680 So. 2d 498 (Fla. 1996). A more forceful limitation applies to Staff Counsel Opinion 22624 that counsel to the Ethics Committee of the Bar issued. Rule 2(c) of the Board of Governor's Rules governing ethics opinions states that advisory ethics opinions that the staff issue are "confidential," except in situations described in Rule 9 (which are not applicable here). The confidential and non-public nature of Staff Advisory Opinion 22624 is reflected on its face in a stamp stating that it may not be considered as applicable to situations or persons other than the law firm to which it was directed. Bar counsel chose, for reasons unknown to Petitioner, to provide a copy of Staff Advisory Opinion 22624 to the court at the June 15, 2001 show cause hearing.13 The court erred in relying on this private opinion, as well as Opinion 98-3, in reaching its conclusion. The court also relied on opinions from foreign 13 In fact, Bar Counsel breached the Bar's own requirement of confidentiality when it volunteered to the court the existence of the opinion. TL019991;1 22 jurisdictions to support its conclusion. In the Gutierrez Order, Judge Siegel relied on In re Youngblood, 895 S.W. 2d 322 (Tenn. 1995), in which the Tennessee Supreme Court considered the propriety of attorneys practicing under a name implying that the staff counsel office was "a separate and independent law firm" with no disclosure of the relationship to the insurer. The court observed that the staff counsel office "is not a 'separate and independent law firm.' The representation that the attorney-employee is separate and independent from the employer is, at least false, misleading and deceptive." Id. at 331. The court concluded that holding out in this manner was prohibited. Youngblood, however, did not consider a staff counsel letterhead like the one that Petitioners use, which holds the office out as a law firm but clearly discloses its relationship to the insurer. The opinion also fails to indicate whether any of the materials that staff counsel used disclosed staff counsel's relationship to the insurer. In short, Youngblood provides no analysis on the issue of whether a letterhead that clearly discloses staff counsel's relationship to the insurer is misleading or otherwise runs afoul of ethics rules. In the Gonzalez Order, Judge Siegel relies on two other TL019991;1 23 cases from foreign jurisdictions to support his conclusion. These cases, however, are inapposite. In In re Weiss, Healey & Rea, 536 A.2d 277 (N.J. 1988), the New Jersey Supreme Court considered the propriety of a staff counsel office practicing under the name "Weiss, Healey & Rea," without any affirmative disclosure of the employment relationship with the insurer. The court concluded that this choice of name violated ethical standards, but appointed a special committee to fashion an appropriate statement that would properly convey the nature of staff counsel practice. See id. at 270. The court's special committee, however, found no public harm or deception in the use of a law firm name, even without disclosure of the affiliation, as long as the attorneys shared responsibility and liability for their policyholder clients. See Report of the Ad Hoc Supreme Court Committee on Law Firm Names, 125 N.J.L.J. 316 (1990). Pursuant to this recommendation, the New Jersey Rules of Professional Conduct were amended to permit use of a partnership-like name, even without disclosure of the relationship with the insurer, so long as the named lawyers shared the responsibility and liability for representing insureds. See New Jersey Rule of Professional Conduct 7.5(d). The Gonzalez Order also relied on Cincinnati Ins. Co. v. Wills, 717 N.E.2d 151 (Ind. 1999), where the Indiana Supreme TL019991;1 24 Court held that the use of a law firm name, with a disclosure of the law firm's affiliation with an insurer, to be improper. The court found two aspects of the disclosure troublesome: the law firm's failure to disclose its affiliation on its office door, and the wording of the disclosure, which was susceptible of being read as meaning that the insurance company was not in fact the law firm's only employer. Obviously, these concerns are not present in this matter. Other jurisdictions have considered this issue and have approved of the practice of allowing staff counsel to hold itself out as a law firm as long as staff counsel disclose this relationship. See, e.g., California St. Bar Standing Comm. on Prof. Resp. & Conduct, Formal Op. 187-91, 1987 WL 109707, at *6 (the letterhead used must indicate the relationship between the firm and the Law Division); New York St. Bar Op., 2000 WL 567960, at *2 (2000) ("[w]e concur with those authorities that permit the use of a law firm name as long as it is accompanied by an explanation that the lawyers are employees of the [insurance company]"); Oregon St. Bar Ass'n Formal Op., 1998-153, 1998 WL 717727 (quoting and following California 1987-91); Pennsylvania Bar Ass'n Comm. on Legal Ethics & Prof. Resp., Formal Op. 96-196 (April 19, 1997) ("recommended practice [is] to clearly denote the nature of TL019991;1 25 the association [among the staff counsel lawyers] and any affiliation with an insurer on the letterhead itself or in the text of the initial letter to the insured"); Oklahoma Bar Ass'n Legal Ethics Comm., Advisory Op. 309, 1998 WL 384612 (Mar. 27, 1998) ("the employee status of the staff attorney must clearly be disclosed to the client at the outset of the representation."). As Petitioners clearly disclose their relationship to Allstate on their letterhead, they comply with the Florida Rules of Professional Ethics, Ethics Opinion 98-3 and the jurisprudence of other jurisdictions that have considered this precise question. B. Judge Siegel's Orders violate Florida's strong public policy in favor of allowing attorneys to represent their clients and insurance companies to defend their insureds. Judge Siegel's prohibitions in the Gutierrez and Gonzalez Orders also violate Florida's strong public policy in favor of allowing attorneys to represent their clients. Florida Rule of Judicial Administration 2.060 (a) authorizes all members of The Florida Bar to appear in all of the courts of Florida as counsel of record for their clients. And, this Court has specifically held that attorneys for insurance companies are authorized to represent insured defendants in legal proceedings. See In re Rules Governing the Conduct of Attorneys in Florida, 220 So. 2d 6 (Fla. 1969). TL019991;1 26 It is interesting to note that this Court rendered the Rules Governing Attorneys opinion pursuant to its original jurisdiction, as the opinion involved the approval of the predecessor to the Florida Rules of Professional Conduct. The Court held that, after The Florida Bar's challenge in 1969 to prohibit the delivery of legal services through staff counsel, that staff attorneys of insurance companies have the right to represent the companies' policyholders in Florida's courts to the same extent as attorneys engaging in the private practice of law. The Court held that the alleged "conflict of interest" problem which prompted the Bar's petition is identical whether staff counsel or private counsel represent a policyholder. The Court further held that the "moral considerations" which inhere in The Florida Bar's protection of "the profession against ethical deviations . . . should not be exploited so as to develop a double standard of ethics for salaried and non- salaried lawyers." Rules Governing Attorneys, 220 So. 2d at 8-9. Staff counsels' use of a law firm name does not implicate any conflict of interest issues, just as private attorneys' use of law firm name does not implicate any conflict of interest issues. Judge Siegel's Orders, however, seek to revive this exploitation between salaried and non- TL019991;1 27 salaried lawyers, although he did not base his Orders on any conflict of interest issues. The Florida Bar has never suggested that staff attorneys' use of a law firm setting of name is per se a violation of the Florida Rules of Professional Conduct. In fact, The Florida Bar recently put before this Court a proposal that would recognize that insurance company staff attorneys' use of law firm settings and names causes no harm to the public or to the administration of justice. C. Judge Siegel's Orders may require Petitioners to disclose to a jury the existence of insurance, which is normally irrelevant. In the Gutierrez Order, Judge Siegel held that the pleading signature block--which indicated that the Law Office of Timothy W. Harrington employed the particular staff counsel on the pleading--also violated Florida Rules of Professional Ethics. See Gutierrez Order, App. A, at ¶4. In the Gonzalez Order, Judge Siegel apparently receded from this stance as to the other insurance companies, deferring on this issue until either The Florida Bar or this Court has issued an opinion on the subject. See Gonzalez Order, App. B, at ¶ 5. In Gutierrez, Judge Siegel also discussed--without any supporting evidence--that a defense expert's response, on cross- examination, that The Law Office of Timothy W. Harrington, as TL019991;1 28 opposed to Allstate, employed the expert may have generated or contributed to false or intentionally misleading testimony. See Gutierrez Order, App. A., at ¶¶ 5-9. 1. The Gutierrez Order's requirement that staff counsel disclose their affiliation to the insurer on the pleadings could disclose the existence of insurance. Florida has determined that juries normally should not be told that a defendant has insurance coverage. In Beta Eta House v. Gregory, 237 So. 2d 163 (Fla. 1970), this Court held that: The existence or amount of insurance coverage has no bearing on the issues of liability and damages, and such evidence should not be considered by the jury. Id. at 165. A court may permit jurors to know of insurance, however, if a "justiciable issue relating to insurance" exists, such as issues of coverage or the application or interpretation of an insurance policy. See Stecher v. Pomeroy, 253 So. 2d 421, 424 (Fla. 1971). The Florida Legislature codified the Beta Eta Court's rationale in section 627.4136, Florida Statutes, the non- joinder statute. In Canal Ins. Co. v. Redd, 666 So. 2d 888 (Fla. 1996), this Court held that section 627.4136 was a declaration of the public policy of Florida. The avoidance of any mention of insurance in trial proceedings, except when insurance is a justiciable issue, is an insurance company's TL019991;1 29 substantive right. See VanBibber v. Hartford Accident & Indem. Ins. Co., 439 So. 2d 880, 883 (Fla. 1983). Although the mere mention of insurance is not a per se error automatically resulting in a mistrial, and can be the subject of a curative instruction, its prejudicial effect is ever-present and courts carefully police it. See, e.g., South Motor Co. of Dade County v. Accountable Constr. Co.,707 So. 2d 909, 911 (Fla. 3d DCA 1998) ("[i]t has long been the law of this state that unless the existence or amount of insurance coverage has direct relevancy to a matter at issue, it is not a proper matter for the jury's consideration . . . ."); Gold, Vann & White, P.A. v. DeBerry, 639 So. 2d 47, 54 (Fla. 4th DCA 1994) ("[i]t is hornbook law that a jury should not learn of the existence of insurance coverage or insurance limits."); Nicaise v. Gagnon, 597 So. 2d 305, 306 (Fla. 4th DCA) (affirming an order for a new trial based on a statement that plaintiff's counsel made during closing argument that the jury need not "worry whether the defendant will contribute a dime of money."), review denied, 604 So. 2d 482 (Fla. 1992). Judge Siegel's Orders cross the line drawn by Beta Eta House and section 627.4136, through requiring (or at the very least suggesting) that staff counsel disclose on court pleadings their relationship to their insurer. As it is TL019991;1 30 normal for juries to see pleadings bearing the names of counsel (and their law firms), Judge Siegel's Orders could require disclosure of the existence of insurance when it is not always possible or remembered to redact the employment relationship information. 2. A defense expert's response on cross-examination that he or she is employed by staff counsel is not false or intentionally misleading testimony. In the Gutierrez Order, Judge Siegel analyzes whether a defense expert's response on cross-examination that he or she is employed by staff counsel may be false or intentionally misleading testimony. Judge Siegel candidly admits that "this court is not presently prepared to answer [this question] due to lack of knowledge of the detailed facts," but then analyzes this issue in detail. See Gutierrez Order, App. A, at ¶¶ 5-9. Judge Siegel's suggestion that defense experts state that an insurance company has employed them is not only incorrect, but as discussed above, Florida law generally frowns upon the disclosure to the jury of the existence of insurance. An expert's response that the Law Firm of Timothy W. Harrington was his or her employer is neither false nor misleading testimony. Judge Siegel states in Gutierrez that it may be false or intentionally misleading because the expert states that he or she is employed by a "fictitious independent TL019991;1 31 law firm" that does not exist. See Gutierrez Order, App. A, at ¶ 5. However, as discussed in great detail in section VI (A), staff counsel's holding themselves out as a law firm or trade name does not run afoul of the Florida Rules of Professional Ethics. Thus, Judge Siegel's premise is incorrect. The identity of the employer of the defense counsel bears no relevancy to the litigated issues of liability and damages in an automobile negligence case, and would thus be inadmissible under the authorities mentioned above. And, while plaintiff's counsel may explore the issues of bias on cross-examination of an expert that defense counsel retained, such expert testimony does not, absent unusual circumstances, open the door to inquiries injecting into the trial matters of the defendant's liability insurance coverage. Such inquiry is contrary to established caselaw and clearly stated legislative and judicial pronouncement of public policy against disclosure of liability insurance to the jury. Ordinarily, all the jury needs to know about the expert's bias is that defense counsel is paying the expert to testify for the defendant. Plaintiff's counsel could also properly inquire if the expert has testified for the same defense law firm in previous matters. Any inquiry about an affiliation TL019991;1 32 with an insurance company would only potentially become relevant if the expert had contact with the insurance company. For example, if the expert had testified for another staff counsel office of Allstate, that office could be named and the jury informed that it is affiliated with the Law Office of Timothy W. Harrington. This would allow the jury to evaluate bias without the prejudicial introduction of the existence of an insurance company. Unless Allstate's involvement was necessary to allow the jury to fairly adjudicate the plaintiff's claim, such disclosure would violate the nonjoinder statute and caselaw holding that the existence of insurance should not normally be revealed to a jury. VII. CONCLUSION The Law Office of Timothy W. Harrington is not a "fictitious independent law firm," as Judge Siegel's Orders suggest. Judge Siegel's Gutierrez and Gonzalez Orders, however, conclude that the Petitioners' holding themselves out as this "fictitious independent law firm" is violative of the Florida Rules of Professional Ethics and the opinions of The Florida Bar's Ethics Committee or its staff. Not only is Judge Siegel incorrect in his assessment, but he has invaded this Court's "exclusive jurisdiction to regulate the admission of persons to the practice of law and the discipline of TL019991;1 33 persons admitted." Florida Constitution, Article V, section 15. Therefore, Petitioner respectfully requests that this Court exercise its power pursuant to Article V, section 3 to issue all writs necessary to the complete exercise of its jurisdiction, and vacate the Gutierrez and Gonzalez Orders. Petitioner further requests that this Court affirmatively hold that the use of a law firm name for staff attorneys of an insurance company which contains the name of the managing attorney, such as "Law Office of Timothy W. Harrington," is not deceptive, and is approved for use in legal proceedings in all courts of Florida, including on pleadings and correspondence, so long as all attorneys in the firm are staff attorneys or employees of their insurance company employer. TL019991;1 34 Respectfully submitted, ______________________________________ Joseph W. Hatchett Florida Bar No. 0034486 Robert J. Telfer III Florida Bar No.: 0128694 AKERMAN, SENTERFITT & EIDSON, P.A. 301 South Bronough Street, Suite 200 Post Office Box 10555 Tallahassee, Florida 32302-2555 Telephone: (850) 222-3471 Facsimile: (850) 222-8628 Miles A. McGrane, III Florida Bar No. 201146 MCGRANE & NOSICH, P.A. 2801 Ponce de Leon Boulevard 12th Floor Coral Gables, Florida 33134 Telephone: (305) 442-4800 Facsimile: (305) 442-2339 Counsel for Petitioner TL019991;1 35 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of this Petition was sent via U.S. mail to Honorable Paul Siegel, Circuit Court Judge of the Eleventh Judicial Circuit in and for Miami-Dade County, Florida, 73 West Flagler Street, Room 412, Miami, Florida, 33130, and to the parties named below on this ________ day of August, 2001. Dennis L. Durkin, Esq. Jose M. Francisco, Esq. Robert W. Thiehelm, Jr., Esq. Jose M. Francisco, P.A. Leigh Anne Kasias, Esq. Suite 210 Baker & Hostetler LLP 3899 N.W. 7th Street SunTrust Center, Suite 2300 Miami, FL 33126 200 South Orange Avenue Co-counsel for Jorge Delgado Orlando, FL 32801-3432 and Marie del Carmen Delgado Counsel for Progressive Southeastern Insurance Company W. Donald Cox, Esq. Hala A. Sandridge, Esq. Russell A. Dohan, P.A. Fowler, White, Gillen, Boggs, Suite 1210 Villareal and Banker, P.A. 777 Brickell Avenue Suite 1700 Miami, FL 33131 501 East Kennedy Boulevard Co-counsel for Jorge Delgado Tampa, FL 33602 and Maria del Carmen Delgado Counsel for Nationwide Mutual Insurance Company Arthur J. England, Jr., Esq. Greenberg Traurig, P.A. Michael I. Libman, Esq. 1221 Brickell Avenue Suite 5 Miami, FL 33131 2439 N.W. 7th Street Counsel for Luis E. Ordoñez Miami, FL 33125 Counsel in Gutierrez v. Scott J. Feder, Esq. Orellano Scott J. Feder, P.A. Suite 402 Richard A. Sherman, Esq. 4649 Ponce de Leon Boulevard Richard A. Sherman, P.A. Coral Gables, FL 33146 Suite 302 Counsel for Stefan Grzymski 1777 South Andrews Avenue Ft. Lauderdale, FL 33316 Co-counsel for Onebeacon Insurance Company TL019991;1 36 Jeffrey C. Fox, Esq. James G. Gilmour, Esq. Greenspoon, Marde, Hurschfeld, Cindy Post Massion, Esq. Rafkin, Ross & Berger, P.A. Law Office of James G. Gilmour Suite 700 Museum Tower, Suite 2800 100 West Cypress Creek Road 150 West Flager Street Ft. Lauderdale, FL 33309 Miami, FL 33130 Counsel in Bernstein & Budget Counsel for Bernard Gran and Rent-A-Car Systems, Inc. Marissa Ilene Gran David L. Deehl, Esq. Edward A. Moss, Esq. Deehl & Carlson Kathleen M. O'Connor, Esq. Suite 1007 Michael G. Moore, Esq. 2600 Douglas Road Shook, Hardy & Bacon, L.L.P. Coral Gables, FL 33134 2400 Miami Center Counsel for Evelyn Goodman 201 South Biscayne Boulevard Miami, FL 33131 Ross B. Gampel, Esq. Counsel for United Services Klemick & Gampel, P.A. Automobile Association 1953 S.W. 27th Avenue Miami, FL 33145 Luis E. Ordoñez, Esq. Counsel for Jesus Vargas Luis E. Ordoñez & Associates Suite 1800 R. Wade Adams, Esq. SunTrust International Center Adams & Adams One S.E. 3rd Avenue 5th Floor Miami, FL 33131-1704 66 West Flager Street Counsel for Eduardo Nogueiras Miami, FL 33130-1807 Counsel in Gutierrez v. Vince J. Rio, III, Esq. Orellano Suite 344 315 South Calhoun Street Robert A. Glassman, Esq. Tallahassee, FL 32301-1837 Law Offices of Robert A. Counsel for Amicus Florida Glassman Insurance Council Suite 3400 2101 West Commercial Boulevard Dominic L. Brandy, Esq. Ft. Lauderdale, FL 33309-3068 One Datran Center, Suite 1000 Co-counsel for Onebeacon 9100 South Dadeland Boulevard Insurance Company Miami, FL 33156 Counsel in Curtin v. Club Atlantis Condominium Association, Inc. Kenneth L. Marvin, Esq. TL019991;1 37 Chief Disciplinary J. Anthony Boggs, Esq. Counsel/Tallahassee Division Director, The Florida Bar Legal Division 650 Apalachee Parkway The Florida Bar Tallahassee, FL 32399-2300 650 Apalachee Parkway Tallahassee, FL 32399-2300 Tony P. Korvick, Esq. President Arlene K. Sankel, Esq. Dade County Trial Lawyers Chief Disciplinary Association Counsel/Miami c/o Porter & Korvick Carlow A. Leon, Esq. Suite 2460 The Florida Bar Two South Biscayne Boulevard Suite M100 Miami, FL 33131 444 Brickell Avenue Miami, FL 33131-2404 Robert T. Lithman, Esq. 5th Floor William G. Edwards, President 2250 S.W. 3rd Avenue Dade County Defense Bar Miami, Florida 33129 Association Counsel for Irmtraud Kurten c/o Marlow, Connell, Valerium, Abrams, Adler & Newman, P.A. 2950 S.W. 27th Avenue, Suite 200 Miami, FL 33133-3765 ______________________________________ Robert J. Telfer III CERTIFICATE OF COMPLIANCE I hereby certify that this brief was prepared in Courier New, 12-point font, in compliance with Rule 9.210(a)(2) of the Florida Rules of Appellate Procedure. TL019991;1 38
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The Top 10 In Action Sports
01Brick By Brick: Camping Lego Style
02Booze and Bikes: 14 Tours That Let Combine Two of the Best Things in the World
03Who Needs Hollywood? These Incredible Videos Were All Filmed on the Simplest Cameras
04Sam Pilgrim vs. The World: The Champion Aiming To Reclaim His Crown In A New Era Of Biking
05Eccentric Adventures Episode 2: Britain's Most Brutal Illegal Event is All About Cheese
06A Journey Into Darkness: We Went Mountain Biking in the Abandoned Mines of Slovenia
07After the Apocalypse: Inside The World's Most Breathtaking Ghost Towns
08Debate: Let's Stop Hating On Parents Who Want To Raise Adventurous Kids
09Guns, Roses, And Eating Insects: Adventure Cycling in Vietnam
10From Intense Trails to Intensive Care: Dicing with Death In a Mountain Biking Paradise
One of those days - Candide Thovex
A Ski video by quiksilver - 387,130 views
A usual skiing day for Candide in his home resort, could have ended in a better way this time! Out skiing with his friend Aziz Benkrich (red pants), we should probably tell you 'DON'T try this at home' !! Follow Candide: Facebook: facebook.com/CandideTHOVEX Twitter & Instagram: @candidethovex http://quiksilver.com
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Slappy Cakes
Slappy Cakes is a new make-your-own-pancakes restaurant that opened its first Maui location in 2013. It is at 3350 Lower Honoapiilani Road, in the Honokowai Marketplace (the shopping center with Times grocery store) at the corner of the Upper Honoapiilani Highway and the Lower Honoapiilani Road, about 5 minutes north of Kaanapali. Phone 808-419-6600.
You can choose from several types of batters and added ingredients (fruit, chocolate chips, nuts, etc.), and then you cook your own pancakes on a griddle built into each table. But there's lots more to Slappy Cakes than pancakes. They also have a full selection of eggs, breakfast meats, benedicts, sandwiches, and more, plus the world's best warm fresh banana bread, and you don't cook any of those yourself. It's open 7 days per week for breakfast and lunch.
See below for menu list, food photos, and video.
For reviews, menus, photos of other restaurants on this side of Maui, see West Maui Restaurants.
Slappy Cakes Pancakes menu (subject to change) $ Inexpensive
- Choose a batter
- Buttermilk
- Whole Grain
- Purple Sweet Potato
- Chocolate
- Seasonal Specialties
- Pick Some Fixins
- Chocolate Chips
- White Chocolate Chips
- Butterscotch Chips
- Bananas
- Blueberries
- Fresh Pineapple
- Strawberries
- Fresh Mango
- Fresh Papaya
- Shredded Coconut
- Granola
- Cheddar Cheese
- Local Goat Cheese
- Bleu Cheese
- Roasted Mushrooms
- Chopped Scallions
- Walnuts
- Almonds
- Macadamia Nuts
- Add Some Toppings
- Lavender Honey
- Coconut Peanut Butter
- Lemon Curd
- Creme Fraiche
- Whipped Cream
- Maple Syrup
- Chocolate Macadamia Sauce
Click for images of complete
Breakfast & Lunch Menu
- Breakfast Plates:
- Slappy Moco
- Vegetable Scramble
- Mushroom Scramble
- Hawaiian Breakfast
- Classic Breakfast
- Banana Bread French Toast
- Country Fried Steak
- Huevos Rancheros
- Benedicts:
- Pork Belly
- Uncle Benny
- Ahi Benedict
- Ala Carte
- Chicken Fried Bacon
- Candied Bacon
- Granola
- Biscuit and GravyS
- Sides:
- English Muffin
- Banana Bread
- Biscuit
- Toast
- Breakfast Potatoes
- Yogurt with Lavender
- Egg
- Bacon
- Sausage
- Spam
- Fruit Bowl
Pancakes batter and added ingredients at breakfast or lunch:
Making pancakes at your table at breakfast or lunch:
Ahi Benedict at breakfast or lunch:
Poke tacos at lunch:
Kalua Pork sandwich at lunch:
French dip roast beef at lunch:


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A-Z | eSTORM
Posted by: Laurie Almodovar
Thursday, June 25, 2015
Congratulations to the full- and part-time students on the Southwestern Illinois College Dean's List for the spring 2015 semester. View the dean's list . This list includes full-time students who completed 12 or more college-level semester credits during the semester and part-time students who completed six or more
Hear Southwestern Illinois College President Georgia Costello, Ph.D., examine issues facing higher education as part of the Ittner Architects' Issues in Education roundtable discussion Thursday, June 25 at 11 a.m. on KTRS-AM 550 radio.
Costello will be joined by Randy Dunn, Ed.D., president of the Southern Illin
Posted by: Julie Ninnis
Wednesday, June 24, 2015
The award goes to Gunning because of his high standards in the classroom, the experience he shares with his students and his dedication to his field, according to SWIC President Georgia Costello, Ph.D.
Friday, May 29, 2015
This year's commencement had its share of pomp, circumstance and selfies! Watch our highlights video.
Friday, May 22, 2015
Thursday, May 21, 2015
Congratulations to each and every #swicgrad! This video features our newest healthcare professionals.
Wednesday, May 20, 2015
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Southwestern Illinois College


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Bunny With Two Noses
That tiny thing to the right is another nose! Do you think they move separately when he's sniffing?
This post was created by a user and has not been vetted or endorsed by BuzzFeed's editorial staff. BuzzFeed Community is a place where anyone can post awesome lists and creations. Learn more or post your buzz!
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Join Activities Council Today and Gain Leadership Experience
Stipended Volunteer Positions:
AC Member
What Activities Council Members do...
1. Develop, implement, and evaluate programs year-round
2. Attend weekly AC meetings that last approximately one to one and a half hours
3. Attend weekly 1 hour individual advisor meetings
4. Attend 1/2 hour weekly event committee meetings
5. Follow up on all assigned event planning during office hours
6. Represent the UH student population at conferences around the country
7. Enrich student life at the University of Hawaii at Manoa
Activities Council offers students a chance to get the true behind-the-scenes experience of student life. Members get to represent the student body, meet and work with performers and agents and develop not only leadership experience but also gain new friends and have fun.
Activities Council members earn monthly stipends for their volunteer assistance.
Pick-up an application at:
Campus Center Ticket, Information, & ID Office [CC 211]
Or download the application:
A complete AC member application packet includes:
Drop off hard copy AC member applications to the Ticket, Info, & ID Office in Campus Center across from Subway.
Email electronic applications to email@example.com.
The Event Coordinator (EC) position is a part-time, paid, student staff position.
See the full position details via SECE # 132843
This person will take the lead in planning and facilitating events on his/her own, with a co-worker, and with members from the Campus Center Board Activities Council (CCB AC).
Events will take place in the Student Life & Development complex including Campus Center, Hemenway Hall, and the Warrior Recreation Center.
Aspects of event planning include, but are not limited to, arranging for facilities/venue, entertainers, parking, promotional supplies, audiovisual, marketing materials, program agendas and mailing.
A complete Event Coordinator application packet includes:
Drop off hard copy applications to the Ticket, Info, & ID Office in Campus Center across from Subway.
Email electronic applications to Stephanie Welin (firstname.lastname@example.com).
If you have any questions, please feel free to contact the AC Chairperson or Lead Advisor here.


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Shopping outside the US? International Shipping is now available!
Fits the following Ford Fairlane Years
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Select more Ford Fairlane parts under Control Arms, Thrust Arms & Components from list below.
Shop Ford Fairlane Control Arm Shaft Kit Call our auto parts experts at or get an expert recommendation via Live Chat


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Chavrie Apple Strudel
10-15 minutes
1 bx. Phyllo dough
½ lbs. Butter (melted)
1ea. Granny Smith apple (peeled, cored, halved, and thinly sliced)
1 jar Fig jam
1 pkg. Chavrie Fresh goat cheese
How to make it
• Pre heat oven to 375° F
• Remove the phyllo dough from the box, unfold, and cover with a damp towel
• Place 1 sheet of phyllo on the work surface and brush lightly with melted butter.
• Repeat 2 more times to create 3 layers , being sure to keep the unbuttered phyllo covered
• Spread Fig jam in a 1 ½ inch wide row ½ inch from the edge of the layered phyllo, leaving about 1/2 inch space on each end.
• Place the apple slices on the jam in a uniform layer
• Split the chavrie log in half and top the apples with the rounded side facing up
• Fold the ends over the apples and cheese. Roll the phyllo and filling over onto itself to form a strudel roll.
• Place the roll seam side on the baking sheet. Brush the top of the strudel with the butter.
• Bake to a golden brown, about 10 to 15 minutes. Allow to cool for 10 minutes, and then cut into portions.
Print it!


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Originally written on Bloguin Best | Last updated 10/12/12
Coming off of an emotional victory against the Packers on the back of Chuck Pagano, this could have the makings of a let down game. That is of course if the Jets had anything resembling an offensive attack and had the ability to put up points in any traditional manner. Betting against the Jets can be tricky, because they will come along with a Joe McKnight return to the house or a Cromartie pick-six that will ruin your week. But they are coming off of a short week after keeping it close with the Texans in prime time on Monday, and the Colts have a chance to walk into their house and take the Jets to the cleaners. Andrew Luck is everything that he was supposed to be. A leader both on and off the field, the rookie could lead the Colts to eight or nine wins this season if they can stay healthy. Donald Brown is out for a few weeks, which certainly hurts their rushing attack, but youngster has shown some good cutting and tackle breaking ability in limited action this season. He will...
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2005 Ford Taurus Q&A
2005 Ford Taurus Question: parking brakes & gas doorlight
The parking brake light and the gas door light stay lit - even when the brake is disengaged and gas door closed. This first happened when the temperature dropped below zero and now the lights stay on all the time. - car question
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Top Stories
- Thursday's Game Suspended due to Rain
- Blowfish Rained Out in Forest City
- 13-Inning Marathon Ends in Defeat
- Owls Rout Blowfish
- Blowfish Stymie SwampDogs
- Blowfish Take Three of Four from RedWolves
- Holder's No-Hitter Leads Blowfish to Victory
- Blowfish, RedWolves Split Doubleheader
- Blowfish Offense Races Past HiToms
- Blowfish Rally Past Owls
The Blowfish Baseball franchise is pleased to announce its move to Lexington County for the start of our 2015 Coastal Plain League season. We will be playing future home games at the new Lexington County Baseball Stadium.
The Lexington County Baseball Stadium will be located off of Highway 1, at the site of the old Lexington High School football field on Ball Park Road across the street from the Lexington Dixie Youth Sports Complex, (Home of the 2014/2015 Dixie Youth World Series).
The new stadium's capacity for baseball is 3,000 and will provide fans with a more pleasant and intimate ballpark experience. It will include an expanded concourse, bowl seating for a more intimate field view, Wrigley Field style box seats, a rightfield berm, leftfield lawn seating and an enclosed air conditioned hospitality club.
Visit our Blowfish On Main location for all your game day gear conveniently located at 101 East Main Street in Downtown Lexington, SC.
Blowfish On Main Promo


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Stephanie Resnick has been recognized as one of the "Top 250 Female Litigators in America" by Benchmark and as a leading litigator in Chambers USA for the fifth consecutive year. Resnick was noted by clients for her "easygoing but powerful presence" and her "ability to handle things calmly while maintaining an unflinching stance."
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|Celtics lock up Davis, Williams
|08.10.09 at 9:35 pm ET
By GREG CAMERON
To paraphrase from a certain restaurant chain's commercial campaign, the Boston Celtics got their baby back.
The Celtics announced that the club has re-signed forward Glen 'Big Baby' Davis. Terms of the deal were not announced by the club, but WEEI.com and FoxSports.com's Jeff Goodman reports that the two-year deal is worth approximately $6.3 million.
Davis provided the Celtics with much-needed front-court help in the wake of Kevin Garnett's season-ending knee injury last year. As a starter for all of the 2009 postseason the Louisiana native averaged 15.8 points per game and 5.6 rebounds.
Davis told reporters that he was frustrated a few times this summer with how free agency had been going for him, despite interest from a handful of teams. However as evidenced by yesterday's press conference, both Ainge and Davis are elated to have the 6'9' forward back in the fold with the Celtics.
'Glen has been a big part of our team's success over the last two years, and we are very excited to have him back,' Ainge told reporters. 'He's young and energetic and we want him to be a part of our team for years to come.'
'I'll be ready to go out and play, do whatever it takes,' Davis said to reporters.
From looking at Celtics GM Danny Ainge's other moves this offseason, the lack of bench depth behind Garnett and center Kendrick Perkins was clearly the top priority of the club. To start the team's search for quality front-court depth, the Celtics signed All-Star forward Rasheed Wallace last month a two-year deal using the team's mid-level exception.
In addition to announcing that Davis will be back with the Celtics for the 2009-10 season, the Celtics officially announced the signing of forward Shelden Williams to a veteran minimum one-year deal worth close to $1.3 million. Williams was a star collegiate player during a sucessful four-year career at storied Duke University.
After graduating in 2006, Williams made his mark on the illustrious program's record books as Duke's leading rebounder and shot-blocker. That collegiate success led Williams to be drafted fifth overall in that June's draft by the Atlanta Hawks.
Since draft night, Williams has bounced around the league considerably playing for Atlanta, Sacramento, and Minnesota before signing with the Celtics this summer. However, the former collegiate phenom has not seen the same success in the professional ranks that he did playing for Hall-Of-Fame coach Mike Kryzyzewski.
'Shelden has proven he can defend and rebound,' Ainge said to reporters. 'Offensively he hasn't come around as well, but it's about getting an opportunity in this league.'
Williams has averaged 4.7 points per game for his career thus far in addition to 4.2 rebounds per game. Those numbers pale in comparison from the 18.8 points and 10.7 rebounds a night he averaged as a Duke senior during the 2005-2006 campaign.
With this summer's signings, Danny Ainge is very excited about how the shape his team is taking. The Celtic GM even recalled a very formidable front-court lineup from the Celtics' rich and illustrious history
'We feel we have a really good front court, maybe the best we've had since Bird, Parish, McHale, Wegman and Walton,' Ainge said to reporters. 'Probably since that era, it's the best front line we've had.'
It was sort of fitting that both Davis and Williams shared the stage at today's press conference, after just over three years since both players squared off at Atlanta's Georgia Dome. Williams was a powerhouse for the Blue Devils that night as he put up 23 points and 13 rebounds.
However, Davis's LSU Tigers got the best of their top-seeded opponents in a low scoring affair on March 23, 2006. LSU defeated Duke that night 62-64, earning them a berth to the tournament's Elite Eight. Davis and his LSU cohorts also reached the Final Four that March.
|Official Press Release: Celtics Re-Sign Glen Davis
|08.10.09 at 1:55 pm ET
BOSTON, MA ' The Boston Celtics announced today that the club has re-signed forward Glen Davis to a contract. Per team policy, terms of the deal were not disclosed.
'Glen has been a big part of our success for the past two years and we are very excited to have him back,' said Danny Ainge, Celtics President of Basketball Operations.
Davis, a 6'9', 289 lbs, forward has spent two seasons with the Celtics and had a breakout 2008-09 season in which he averaged 7.0 points and 4.0 rebounds per game. The former LSU Tiger continued his breakout campaign in the 2009 playoffs during which he averaged 15.8 points and 5.6 rebounds per game. Davis made 16 starts during the 2008-09 regular season and averaged 12.6 points and 5.6 rebounds in 33.0 minutes per game. 'Big Baby' scored a career-high 24 points against the Memphis Grizzlies on March 21, 2009. Davis also hit the biggest shot of his career to date when he nailed a game-winning jumper against the Orlando Magic in Game 4 of the Eastern Conference Semifinals to send the series back to Boston tied 2-2. During the First Round of the 2009 playoffs against the Chicago Bulls, Davis averaged 18.1 points and 6.7 rebounds.
|Sources: Davis deal worth two years, approximately $6 million
|08.10.09 at 11:32 am ET
According to Jeff Goodman of WEEI.com and FoxSports.com, Glen Davis has agreed to a two-year deal that will pay him approximately $6 million. Goodman reports that Davis had fielded some interest from teams in the offseason, but no one put forth an offer to the restricted free agent. Davis, 23, averaged 15.8 points and 5.6 rebounds in the postseason while playing more than 36 minutes per contest. During the regular season he put up seven points and four boards per game. The Celtics will announce the Davis deal and an agreement with forward Shelden Williams Monday.
|Celtics sign Shelden Williams
|08.07.09 at 7:54 pm ET
On Friday the Boston Celtics announced the signing of forward Shelden Williams. Terms were not disclosed per team policy but had previously been reported to be a guaranteed one-year deal with $1.3 million. Williams was selected by the Atlanta Hawks with the fifth pick in the 2006 NBA Draft. He has averaged 4.7 points and 4.2 rebounds per game during his career.
The Celtics have yet to reach an agreement with restricted free agent forward Glen Davis. Earlier this week Davis told WEEI.com's Jeff Goodman, "I don't know what's going to happen. It's still too early to tell. We've still got a long ways to go as far as negotiating with the Celtics."
|Magic's Lewis suspended for 10 games
|08.06.09 at 4:49 pm ET
Orlando Magic forward Rashard Lewis will be suspended for the first 10 games of the 2009-10 season without pay for failing a league drug test, according to the Orlando Sentinel. Lewis tested positive for Dehydroepiandrosterone (DHEA), a testosterone-producing steroid. The Sentinel reported it is common in several over-the-counter supplements but it banned by the NBA.
The Sentinel published the following statement from Lewis:
"First and foremost I take full responsibility for the situation and accept the corresponding penalty. Toward the end of the season I took an over-the-counter supplement which at the time I did not realize included a substance banned by the NBA. I apologize to Magic fans, my teammates and this organization for not doing the research that should come with good judgment. I hope this unintentional mistake will not reflect poorly on our team and its great character. I hope every athlete can learn from my mistake that supplements, no matter how innocent they seem, should only be taken after consulting an expert in the field."
Lewis averaged 20.4 points and 6.3 rebounds against the Celtics in the 2009 Eastern Conference Semi-Finals.
|Celtics preseason schedule announced
|08.06.09 at 2:29 pm ET
On Thursday the Boston Celtics released their preseason schedule for the 2009-10 season:
October 7 @ Houston Rockets
Dodge Arena (Hidalgo, TX)
8:30 p.m. ET
October 9 vs. New York Knicks
TD Garden (Boston, MA)
7:30 p.m. ET
October 11 vs. New Jersey Nets
TD Garden (Boston, MA)
1:00 p.m. ET
October 13 @ New Jersey Nets
Prudential Center (Newark, NJ)
7:00 p.m. ET
October 14 vs. Toronto Raptors
XL Center (Hartford, CT)
7:30 p.m. ET
October 18 @ Toronto Raptors
Air Canada Centre (Toronto, ON)
3:30 p.m. ET
October 20 @ New York Knicks
Madison Square Garden (New York, NY)
7:30 p.m. ET
October 21 @ Cleveland Cavaliers
Value City Arena (Columbus, OH)
7:00 p.m. ET
|Walker, Giddens, Hudson team up to give back
|08.06.09 at 10:39 am ET
This week Bill Walker teamed up with J.R. Giddens and rookie Lester Hudson to help out 400 Boston families in need at the Feed the Children Event in Mattapan. The three Celtics and a group of 20 volunteers handed out $45,000 worth of non-perishable food items and personal items, including pasta, canned goods, body wash, and laundry detergent, at the Mildred Avenue School and Community Center.
Each family, pre-selected by Horizons for Homeless Children, Children's Hospital Boston Community Health Center, MSPCC (Massachusetts Society for the Prevention of Cruelty to Children), and Boston Centers for Youth and Families, received three boxes.
Prior to the event, the players and volunteers unloaded 1,200 boxes from a packed 18-wheeler that had been driven from New York to Boston. They also placed boxes in the families' cars once they arrived.
Walker and Hudson took time out for autographs and photos during the event. For more information on the Celtics community involvement, read about the Shamrock Foundation at www.celtics.com. Check out more photos with the link below.
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Dr Sonali Sen GuptaLecturer
I completed my undergraduate degree in Economics (in 2006) from University of Delhi and M.Sc. (in Environmental and Natural Resource Economics) at the University of Birmingham, U.K. in 2008. I did my Ph.D. at the University of Birmingham, under the supervision of Professor Indrajit Ray and Professor Martin K. Jensen.
Research Overview
I am mainly interested in 'mediation' and 'communication' in games.
Research Interests
Game Theory, Industrial Organisation, Assignment Problems
Current Teaching
Econ 228 - Game Theory
Econ 207 - Managerial Economics
Improving Nash by coarse correlation
Moulin, H., Ray, I., Sen Gupta, S. 03/2014 In: Journal of Economic Theory. 150, p. 852-865. 14 p.
Journal article
Coarse correlated equilibria in an abatement game
Moulin, H., Ray, I., Sen Gupta, S. 2014 Lancaster : Lancaster University, Department of Economics, 17 p.
Working paper
Coarse correlated equilibria in linear duopoly games
Ray, I., Sen Gupta, S. 05/2013 In: International Journal of Game Theory. 42, 2, p. 541-562. 22 p.
Journal article
Economic Modelling
Publication peer-review
RES-York Symposium and Mini-courses on Game Theory
Participation in workshop, seminar, course
Royal Economic Society Annual Conference
Participation in conference
Asian Meeting of The Econometric Society 2012 (AMES 2012)
Participation in conference
8th Annual Conference on Economic Growth and Development (ACEGD8)
Participation in conference
Bulletin of Economic Research
Publication peer-review
Journal of Microeconomics
Publication peer-review
The 4th World Congress of the Game Theory (Games2012)
Participation in conference
European Workshop of General Equilibrium Theory (EWGET 2012)
Participation in conference
Universitas21 Doctoral Research Conference in Business
Participation in conference
7th Annual Conference on Economic Growth and Development (ACEGD7)
Participation in conference
7th Spain-Italy-Netherlands Meeting on Game Theory (SING7) Conference
Participation in conference
11th Society for the Advancement of Economic Theory (SAET) Conference
Participation in conference
Second Brazilian Workshop for Game Theory
Participation in conference
Royal Economic Society Annual Conference
Participation in conference


text:
A method for fostering the germination of plant seeds or the cultivation of plant cuttings wherein light-emitting diodes are positioned closely proximate the plant seeds or plant cuttings and energized so as to emit irradiating light on the plant seeds or plant cuttings of a wavelength between 400 and 800 nm. The light-emitting diodes can be energized with continuous or intermittent, high frequency energy.
1. A method of fostering growth of plant propagative material which comprises the steps of:
(a) providing a nursery area containing plant propagative material in a substrate,
(b) positioning a plurality of light-emitting diodes (LEDs) closely proximate to said nursery area so that irradiating light emitted from said LEDs can strike said plant propagative material to foster plant growth, and
(c) energizing said LEDs so that they emit irradiating light on said plant propagative material having a wavelength of between 400 to 800 nm.
2. A method as defined in claim 1, wherein in step (b) said LEDs are positioned such that irradiating light from adjacent LEDs overlaps at said nursery area.
3. A method as defined in claim 1, wherein in step (c) high frequency energy is intermittently supplied to said LEDs.
4. A method as defined in claim 1, wherein in step (c) a current of 24 volts is supplied to said LEDs.
5. A device for fostering germination of plant seeds and cultivation of plant cuttings, which comprises a nursery assembly having tray for holding a substrate in which the plant propagative material is inserted, a cover spaced from the trays in close proximity thereto having a plurality of light-emitting diodes facing the trays emitting light at wavelengths between 400 and 800 nm for providing light energy to the plants for fostering growth, the nursery assembly being dimensioned to be accommodated in a transport vehicle.
The invention relates to a method for fostering the germination of plant seeds and the cultivation of plant cuttings by artificial lighting thereof from a light source.
Such a method is known from WO-A-84/00693.
Used in the known method as light source are gas discharge tubes. Through the use of special gas fillings a required wave length range is obtained. The use of filters or coatings on the light sources for the purpose of filtering out an undesired part of the spectrum is avoided as a result.
Such gas discharge tubes however require a high energy consumption. The energy consumption lies in the order of magnitude of 36 W. In the case of incandescent lamps an energy consumption of 150 to 450 W can be expected.
The high energy consumption results in the development of a great deal of heat. A comparatively large spacing between the object for lighting and the light source must therefore be selected.
The invention has for its object to provide a solution for the above-mentioned drawbacks. This is achieved according to the invention through the use of light-emitting diodes (LEDs) as light source.
The invention derives from the insight that while it is true that with the use of a cold light source, as is the case with an LED, a limited lighting strength is achieved, because the light source does not radiate any heat it can be placed very close to the object for lighting. The consumption of an LED is approximately 50 mW. It has been found that with a correctly chosen wave length a lighting nevertheless takes place such that the intended purpose is achieved.
As a result of the invention it is possible to further plant growth in, for example, entirely darkened, closed accommodations.
A light source can be used for lighting with a light spectrum lying between 400 and 800 nm.
It is possible to supply a light source intermittently at high frequency, whereby a lighting strength can be selected that is greater than in the case of continuous operation. As a result of a certain slowness of plants in reacting to light the intermittent lighting is sensed by the plant as more or less continuous and the speed of germination is not adversely affected as a result. Intermittent feed can also be applied for the saving of energy. The supply voltage used can be kept low, namely about 24 volts. This is of particular advantage in the case of use in means of transport. Further features and advantages of the invention will be elucidated with reference to the drawings.
In the drawings:
FIG. 1 shows a view of a nursery assembly as employed for the germination of seeds according to the present invention, and
FIG. 2 shows a light source utilized in the nursery assembly.
The nursery assembly 1 shows in FIG. 1 is built up of a rack 2 in which trays 3, 3' are accommodated. Trays 3, 3' are filled with a substrate into which the seeds for germinating are inserted. Situated above each tray 4 is a group of LEDs 5, 5', 5". The LEDs are operative in the light spectrum of approximately 660 nm. This spectrum is optimal for rapid germination of seeds. The irradiating light in the ray bundles of adjacent LEDs overlap one another.
By means of a frequency control the ignition timing, and therefore the frequency of the lighting, is adjustable.
Because of the low heat production the packing in the nursery area of the nursery assembly can be more dense than in the case of known nursery areas assemblies.
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Arizona Diamondbacks
Nats lose 4-1, swept again by Cardinals
ST. LOUIS (AP) - First, they got eliminated. Then, they barely avoided getting no-hit. Jordan Zimmermann's foiled bid for 20 wins was the final disappointment for the Washington Nationals in a series sweep that was all Cardinals.
"I kept my regular lineup in there because I wanted us to stand up and show them that we were better, and we couldn't do that," manager Davey Johnson said after a 4-1 loss on Wednesday that clinched a tie for the NL Central title for St. Louis after Pittsburgh lost to the Cubs.
"There's pride that comes into it when you play these games and there's a lot riding on it for them. This club is used to being a spoiler but we didn't play that well and I wanted to beat them bad," he said.
Rookie Shelby Miller won his 15th game and Yadier Molina had the go-ahead hit for the Cardinals, who swept the season series 6-0. It's the first time that's happened to the Nationals.
"They've got some pretty good starters over there," Washington third baseman Ryan Zimmerman said. "And like I said they have a really powerful lineup, so you mix those two together you're going to have success."
Zimmermann (19-9) allowed four runs in seven innings. The Nationals had five hits one day after breaking up rookie Michael Wacha's bid for a no-hitter in the ninth inning.
Zimmermann took pride in topping 200 innings, reaching 213 1-3.
"I'm not really disappointed, 20 wins is a lot of wins and 19 is not too far off," Zimmermann said. "This year I came to do one thing really, and that's going deep into ballgames."
Matt Adams hit his eighth home run since replacing injured Allen Craig and doubled for the Cardinals, who lead the Pirates by three games with three games to go. The Reds lost 1-0 to the Mets on Wednesday and were eliminated from the divisional race.
The Cardinals (94-65) are a season-high 29 games above .500 and have a day off before 14-game winner Lance Lynn faces the Cubs on Friday night to open the final series.
Miller (15-9) was wild high early and walked two of the first three hitters to set up Bryce Harper's RBI single. The Nationals had no other runners in scoring position against the 22-year-old Miller, who allowed a run in six-plus innings and beat them for the second time this season.
Rookie Trevor Rosenthal saved all three games and struck out Adam LaRoche to cap a perfect ninth.
Zimmermann had won his previous four appearances and had been coming off a two-hit shutout of Miami. But he is 0-3 with an 8.27 ERA in six career starts against St. Louis, and lost Game 2 of the NL division series last fall.
"They're good one through nine," Zimmermann said. "Every one of those guys are hitting over .270, .280, everyone's dangerous and you can't make any mistakes.
"I don't know really what their game plan is but they obviously see me pretty well."
Daniel Descalso doubled leading off the third and scored on Matt Carpenter's groundout to tie it. Zimmermann hit Matt Holliday to open the fourth, and Adams doubled ahead of Molina's two-run single that made it 3-1.
Adams hit his 17th homer on a 1-2 pitch in the sixth.
The Cardinals were 15-2 against the NL East and swept Miami and Philadelphia.
NOTES: Zimmermann has 43 career wins, one shy of the Nationals' franchise record held by Livan Hernandez. ... Miller leads all rookies with 15 wins, also the most by a Cardinals rookie since Dick Hughes won 16 in 1967. ... Lynn (14-10, 4.09) faces Travis Wood (9-11, 2.98) on Friday. Stephen Strasburg (7-9, 3.02) gets his final start on Friday at Arizona against Patrick Corbin (14-7, 3.28).
(Copyright 2013 The Associated Press. All rights reserved. This material may not be published, broadcast, rewritten or redistributed.)
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Those of you tasked with selling fire detection and security systems for your company (and we are all in sales in one form or another) look for ways to set your company apart from the competition; most companies try to promote their strengths and benefits to an owner. For example, "We use only the best equipment" or "We are authorized dealers" or "We are factory trained." READ MORE
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MOORE, a licensed fire protection engineer, frequent speaker and an expert in the life safety field, is a principal member and past chair of NFPA 72, Chapter 24. Moore is a vice president with JENSEN HUGHES at the Warwick, R.I., office. He can be reached at email@example.com.
Articles by Wayne D. Moore
June 2007
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June 2007
If you have not purchased and read the 2007 edition of the National Fire Alarm Code, it is possible your next fire alarm system installation in a military or government facility will hold a surprise. READ MORE
May 2007
New UL standard outdates FACUs many consider current Most contractors know the Underwriters Laboratories Inc. (UL). They see the stamp, label or tag on just about everything electrical. UL operates as an independent, not-for-profit, product-safety testing and certification organization. It has tested products for public safety for more than a century. READ MORE
April 2007
Fit the 'personality' of the facility: READ MORE
April 2007
Keeping up with national fire alarm code and technology changes: The primary code for any electrician is the National Electrical Code (NEC), and information about it appears regularly in this magazine to help ensure you are kept up-to-date with all the changes and understand the impact on your everyday business. READ MORE
March 2007
The contractor's responsibilities: Electrical contractors repair many different kinds of electrical systems; for most of these systems, if the repair takes longer than expected or is delayed to acquire the necessary parts, the customer understands and is willing to wait for the completion of the repair; however, if a fire alarm system is impaired, there are specific rules that a contractor must fo READ MORE
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