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I. Introduction
Chairman Hastings, Co-Chairman Cardin and Members of the Commission, thank you for inviting me to be here today to share the views of Human Rights First on these important issues. We appreciate the work of the Helsinki Commission and in particular its leadership among OSCE member states in the areas of human rights and humanitarian affairs – "the human dimension." Human Rights First is honored to have the opportunity to express its views to you today about how best to ensure that U.S. policy on the detention, interrogation and trial of terrorist suspects is effective, humane and consistent with our laws and values.
My name is Gabor Rona and I am the International Legal Director of Human Rights First. For more than a quarter century, Human Rights First has worked in the United States and abroad to create a secure and humane world by advancing justice, human dignity and respect for the rule of law. We support human rights activists who fight for basic freedoms and peaceful change at the local level; protect refugees in flight from persecution and repression; help build a strong international system of justice and accountability; and work to ensure that human rights laws and principles are enforced in the United States and abroad.
You have asked me to lay out the international law applicable to the detainees being held at Guantanamo and others detained in the so-called "War on Terror" and I will make recommendations designed to bring U.S. policies and practices back into the fold of the international legal order that the United States shares with its OSCE partner-States.
II. The Framework of International Law
The issue facing you today is one of great urgency and import. The policy of detention, interrogation and trial of terrorist suspects at Guantanamo has been a failure. Some have called it a scar on the reputation of the United States as a standard bearer for human rights worldwide. More than a scar, it is an open wound that continues to divide the United States from its allies. It undermines the ability of the United States to promote human rights and to protect national security. And it continues to divide Americans of good faith who seek progress on these fronts.
The debate about Guantanamo is part of the larger debate about the meaning of the words "war on terror." This debate, pitting advocates of the war paradigm against those advocating a "law enforcement" approach reminds me of H.L Mencken's admonition that to every complicated problem there is an answer that is simple, clear and wrong. In this case, a simple and clear "either/or" answer to the question is wrong. Having spent several years in the legal division of the International Red Cross, the guardian of the laws of armed conflict, I have come to understand that the correct answer is not either/or but both: when terrorist acts and counterterrorism responses amount to armed conflict, they are governed primarily by international humanitarian law – the law of armed conflict. When they do not amount to armed conflict they are governed by other domestic and international law, including international human rights law. It is not a question of which legal framework one prefers, but rather, which one or ones are triggered by facts on the ground. Consequently, there is no right or logic to treating the legal frameworks like a Chinese restaurant menu – you cannot choose one rule from column A and another from Column B to suit perceived interests. To do so renders the legal frameworks meaningless chaos.
The Geneva Conventions make it absolutely clear that when one State uses armed force against another, such as in the U.S. and allied invasion of Afghanistan, the international humanitarian law of international of armed conflict applies. It requires that detained members of the opposing armed forces be accorded PoW status and protections and that those of enemy nationality who are not PoWs be accorded civilian status and protections, even if those civilians have taken part in hostilities without a privilege to do so.
The Geneva Conventions also make clear that when a State is engaged in armed conflict with an organized armed group, the international humanitarian law of non-international armed conflict applies. Here, questions of degree of organization of the armed group and frequency and severity of attacks make it more complicated to determine the existence of such armed conflict than in the case of State-to-State hostilities, but there is no reason why the United States cannot be engaged in a non-international armed conflict against a transnational armed group. Members of such a group are not entitled to PoW status, but the Conventions still require that they be treated humanely and given fair trials, if they are to be prosecuted.
Detainees in international armed conflict - armed conflict between two or more States - may be detained until the end of the conflict according to the Geneva Conventions. But the Conventions say no such thing about detainees in non-international armed conflict. This is no omission. Because non-international armed conflict fighters do not have the privilege to fight that members of armed forces have, because such fighters are violating domestic criminal laws when they take up arms, they remain subject to the same laws that apply in peacetime: domestic law and international human rights law, which enables their prosecution and entitles them to challenge their detention in a court. This is not a "get out of jail free" card. It is merely a means of putting the decision to detain ultimately in the hands of an independent judicial body.
Of course, those who commit war crimes, including engaging in acts of terrorism by targeting civilians, may be prosecuted and sentenced, whether they are civilians or combatants, whether in war or in peacetime.
To revert to the original question: is the war on terror a "real" war, the answer is no, since terror cannot be a party to an armed conflict and parties are essential to bear the rights and responsibilities that the laws of war create. One commentator wryly noted that proper nouns like Japan and Germany are good enemies, since they can surrender and promise not to do it again. You'll never get that out of a common noun like "terror." But what of the next question: is the war against al Qaeda a real war? Probably so, but since al Qaeda fighters are not privileged belligerents, they should not be afforded the mantle of "combatant" even though it may be permissible under the laws of war to target them. If detained, they should be treated like the criminals they are when they engage in attacks against civilians.
This should lay to rest another straw man argument: one need not chose between either affording terrorists the protections of prisoners of war to which privileged belligerents who fight in accordance with the laws are entitled, or holding them in a law-free "black hole." They can be targeted while directly participating in hostilities, and if captured, they can be interrogated, detained and tried in accordance with domestic and international law.
And so, the U.S. – invented status of "enemy combatant" and "unlawful combatant" is wrong. It is wrong because, as applied through the Military Commission Act of 2006, it fails to respect obligations under the Geneva Conventions to accord proper status and rights to either privileged or unprivileged belligerents, that is, PoWs and civilians in international armed conflicts.<!--[if !supportFootnotes]-->[1]<!--[endif]--> It is wrong because it triggers procedures for judicial challenge of detention that fall far short of international standards of due process applicable in non-international armed conflict. And it is wrong because it fails to apply requirements for fair trials in accordance with international standards of due process for those who are charged with crimes in either international or non-international armed conflict. But the most pernicious consequence of "enemy combatant" is its broad definition by which the United States attempts to claim extraordinary powers of wartime without geographic or temporal limitation, and beyond the bounds of that which is truly armed conflict, all the while denying the subjects of those claims their commensurate rights and protections under the laws of armed conflict.<!--[if !supportFootnotes]-->[2]<!--[endif]-->
One further point of departure between the United States and much of the rest of the western world concerns the scope of application of human rights law. The United States clings to two short-sighted positions: 1) that human rights treaty obligations do not follow the flag – that they impose no limits on how Americans treat persons beyond the borders of the United States, and 2) that human rights law does not apply in situations of armed conflict. Mr. Bellinger, who has worked hard to negotiate a middle ground between the U.S. administration and its detractors and to assure America's allies of the U.S.'s continued commitment to the rule of international law, has steadfastly advocated these unfortunate positions. International treaties, international and national jurisprudence and international legal scholars affirm the extraterritorial application of human rights in armed conflict. <!--[if !supportFootnotes]-->[3]<!--[endif]--> As recently as last week, so did the House of Lords, and last year, so did the Israeli Supreme Court.<!--[if !supportFootnotes]-->[4]<!--[endif]--> The United States would better serve its own interests and follow suit, rather than cling to tenuous and tendentious arguments that deny human rights in order to support illegal and counterproductive policies such as secret detention that violates the International Covenant on Civil and Political Rights and interrogation methods and "extraordinary rendition" in violation of the Torture Convention.
And yet, I submit that the concept of Americans being from Venus and Europeans from Mars when it comes to defining the war on terror is an overstatement and an oversimplification. Europe, which has had more war and more acts of terrorism on its soil than has America, if I may generalize, does not deny the application of the laws of war when the "war on terror" is manifested in armed conflict. It simply appears to have a more measured and more accurate view of when, where, to what, to whom and how the laws of war apply, than does the U.S. administration.<!--[if !supportFootnotes]-->[5]<!--[endif]-->
III. Guantanamo – a failed policy
The decision to hold detainees at Guantanamo in the first place was driven at least in part by a desire of the Administration to insulate U.S. actions taken there – detention, interrogation, and trials – from judicial scrutiny, and even from the realm of law itself. Early on, one administration official called Guantanamo "the legal equivalent of outer space." That goal – to create a law-free zone in which certain people are considered beneath the law – was illegitimate and unworthy of this nation. And any policy bent on achieving it was bound to fail.
The policy at Guantanamo has been a failure in several important respects. First, and most obviously, it has failed as a legal matter. The Supreme Court has rejected the government's detention, interrogation and trial policies at Guantanamo every time it has examined them. And it likely will do so again. Military commissions at Guantanamo have also failed to hold terrorists accountable for the most serious crimes. Even the sole case to be resolved, the plea bargain of the Australian David Hicks who, after five years in U.S. custody pled guilty to a crime (material support for terrorism) that didn't exist in the laws of war at the time Hicks allegedly committed it, has rightfully received more derision than praise on account of the haphazard way in which it was pursued and the seemingly politicized way in which it was concluded.
In addition, fueled by the assertion that it was a "legal black hole," Guantanamo became the laboratory for a policy of torture and calculated cruelty that later migrated to Afghanistan and Iraq and was revealed to the world in the photographs from Abu Ghraib. These policies aided jihadist recruitment and did immense damage to the honor and reputation of the United States, undermining its ability to lead and damaging the war effort.
But perhaps most importantly from a security perspective, the policy at Guantanamo – which treats terrorists as "combatants" in a "war" against the United States, but rejects application of the laws of war – has had the doubly pernicious effect of degrading the laws of war while conferring on suspected terrorists the elevated status of combatants.<!--[if !supportFootnotes]-->[6]<!--[endif]--> By taking the strategic metaphor of a "war on terror" literally, the United States Government has unwittingly ceded an operational and rhetorical advantage to al Qaeda, allowing them to project themselves to the world – including to potential recruits and a broader audience in the Middle East – as warriors rather than criminals.
Khalid Sheik Mohammed reveled in this status at his "combatant status review tribunal" hearing at Guantanamo not long ago. After ticking off an itemized list of 31 separate attacks and plots for which he claimed responsibility (including the 9/11 attacks and the murder of Daniel Pearl), he addressed – as if soldier-to-soldier – the uniformed Navy Captain serving as president of the military tribunal. Proudly claiming the mantle of combatant ("For sure, I am American enemies"), he lamented, in effect, that war is hell and in war people get killed: "[T]he language of any war in the world is killing…the language of war is victims." He compared himself and Osama bin Laden to George Washington ("we consider we and George Washington doing [the] same thing").
Those whose job it is to take the fight to al Qaeda understand instinctively what a profound error it was to reinforce al Qaeda's vision of itself as a revolutionary force in an epic battle with the United States. General David Petraeus, Commanding General of the Multi-National Forces in Iraq, oversaw the drafting of the Army's new Counterinsurgency Manual, which incorporates lessons learned in a variety of counterinsurgency operations, including Iraq. The Manual stresses repeatedly that defeating non-traditional enemies like al Qaeda is primarily a political struggle, one that must focus on isolating the enemy and delegitimizing it with its potential supporters, rather than elevating it in stature and importance. As the Manual states: "It is easier to separate an insurgency from its resources and let it die than to kill every insurgent… Dynamic insurgencies can replace losses quickly. Skillful counterinsurgents must thus cut off the sources of that recuperative power."<!--[if !supportFootnotes]-->[7]<!--[endif]-->
But U.S. counterterrorism policy has taken just the opposite approach. Prolonged detention at Guantanamo without access to judicial review, interrogations that violate fundamental human rights norms, and flawed military commissions have nurtured the "recuperative power" of the enemy. It is up to Congress to force a clean break from this misguided approach and begin to construct a counterterrorism policy that conforms to the logic of counterinsurgency operations, adheres to fundamental human rights standards and capitalizes on the advantages of our system of laws.
IV. The Way Forward
A. Close Guantanamo
Human Rights First takes seriously the human rights and legal challenges posed by the ongoing detention of prisoners at Guantanamo. Closing the prison raises many complex questions about what to do with prisoners being held there – those the United States believes have committed crimes against it, and those being held without charge "until the end of the conflict." We have not been among the groups calling for closure of the prison over the last several years, in large part because, in our view, it matters less where prisoners are held than that their detention, interrogation and trial comport with U.S. and international law. It is, however, beyond serious question – even among many who initially supported the decision to detain prisoners at Guantanamo – that Guantanamo has become an enormous diplomatic liability, impairing the capacity of the United States to lead the world, not only in counterterrorism operations but on many other issues of priority on which international cooperation is necessary. As Secretary of Defense Gates said recently, "There is no question in my mind that Guantanamo and some of the abuses that have taken place in Iraq have negatively impacted the reputation of the United States."<!--[if !supportFootnotes]-->[8]<!--[endif]--> Indeed, Guantanamo has become an icon, in much the same way as the picture of the hooded Iraqi prisoner at Abu Ghraib has become an icon, a symbol of the willingness of this country – in the face of security threats – to set aside its core values and beliefs. Respect for the law and fundamental rights are not the only things that have disappeared into Guantanamo's "black hole" – American credibility is in there somewhere, too.
Of course, while it is important to take into consideration the views of our closest allies, all of whom have called on the United States to close the prison, no one argues that we should change U.S. policy simply because other nations don't like it. The most important questions about the current policy are: Is it smart? Is it working? Does it serve the overall objective? Does it comport with our laws and values? Guantanamo policy fails all those tests.
Secretary Gates is reported to have argued that the continued detention of prisoners at Guantanamo is undermining the war effort and that the prison should be shut down as soon as possible. His views echo the conclusion that has now been reached by a broad spectrum of national security policymakers and Members of Congress that, whatever its original utility, the policy at Guantanamo has outlived its usefulness. State Department and Pentagon officials quoted in the New York Times have said that U.S. policy at Guantanamo is "making it more difficult in some cases to coordinate efforts in counterterrorism, intelligence and law enforcement."<!--[if !supportFootnotes]-->[9]<!--[endif]--> Former Secretary of State Colin Powell stated recently that Guantanamo ought to be closed "not tomorrow, but this afternoon" and that he would "get rid of Guantanamo and the military commission system and use established procedures in federal law.<!--[if !supportFootnotes]-->[10]<!--[endif]--> According to the Washington Post, former Attorney General John Ashcroft had argued that Guantanamo's liabilities outweighed its usefulness.<!--[if !supportFootnotes]-->[11]<!--[endif]-->
Again, this is not surprising. As the Army's Counterinsurgency Manual states: "A Government's respect for preexisting and impersonal legal rules can provide the key to gaining widespread and enduring societal support…Illegitimate actions," such as "unlawful detention, torture, and punishment without trial…are self-defeating, even against insurgents who conceal themselves amid non-combatants and flout the law." <!--[if !supportFootnotes]-->[12]<!--[endif]-->
Despite the self-defeating nature of the policy and the growing consensus that it should end, Administration spokespeople have said that the detention facility at Guantanamo will likely remain open throughout President Bush's term in office. Far from moving to close the facility, the Administration continues to transfer new detainees to Guantanamo. The Administration asserts that one new transferee, Mohammad Abdul Malik, who reportedly confessed to involvement in the 2002 hotel bombing in Kenya, was sent to Guantanamo because he represents a "significant threat." It is increasingly clear, however, that the reason many detainees were sent to Guantanamo, rather than being indicted and tried in federal court, was not because that was the smartest or most strategic option available, but because it was the one that relieved the government of the burden of making difficult choices. But if U.S. counterterrorism policy consists of detaining or killing everyone who harbors hostility towards the United States (and one hopes that is not the policy), we must face the reality that the nearly 400 men at Guantanamo are a drop in that bucket, and that holding them there without charge or trial in fair proceedings will eventually mean that we will need to get a much bigger bucket. A more rational policy would be to chart a way out of the trap that Guantanamo has become, not only for the detainees who have been held there for so many years, but for U.S. counterterrorism policy itself. The first step is to shut it down.<!--[if !supportFootnotes]-->[13]<!--[endif]-->
B. Release or Transfer Detainees Not Charged with Crimes and Bring the Rest to the United States
Last July, President Bush said "I'd like to close Guantanamo, but I also recognize that we're holding some people there that are darn dangerous and that we better have a plan to deal with them in our courts.'' State Department lawyers continue to shop the world for countries that will agree to take the Guantanamo detainees off our hands, but this attempt to sell the Guantanamo problem "retail" is inadequate and unsatisfactory as it leaves U.S. policy at the mercy of other governments, many of whom have no interest in helping. Despite the growing sense even inside the Administration that the Guantanamo policy is hurting U.S. interests, paralysis has set in and no one in the Administration appears to be prepared to move.
Part of the reason for this is that the current system lacks incentives that would force decisions about who to try and who to release. Under current policy, detainees at Guantanamo can be held without trial for an indefinite period. If they are tried and convicted in a military commission, they remain in detention; if they are tried and acquitted, they may also remain in detention.
If the detainees were brought to the United States, that incentive structure would change, and there would be a new sense of urgency to separate those who the United States suspects of having committed crimes against it from those it does not. Detainees not suspected of having committed crimes against the United States should be released to their home countries, if possible, in accordance with U.S. obligations under international human rights and humanitarian laws. Where release to the home country is not possible (for example, because there is a fear that a detainee will be subjected to torture), detainees should be released to a third country in accordance with U.S. obligations under international human rights and humanitarian laws.
U.S. allies, particularly the Europeans who have called most loudly for the prison to be closed, should do much more to help on this score. The United States climbed into this hole alone, but its allies have a shared responsibility to help it get out; this is more than just a U.S. problem now. Manfred Nowak, the Austrian U.N. special rapporteur on torture, has urged European governments to assume greater responsibility for helping with third country resettlement of these people. "Europe should help empty it," Nowak has said. "No country is eager to accept people who are accused of having al-Qaeda links. But there should be burden-sharing." We agree.
But the United States works against its own immediate interest of resettling Guantanamo detainees by clinging to rhetoric that appears increasingly out of touch with reality as the facts come out. One study, released in 2006 and using the government's own statistics derived in part from its Combatant Status Review Tribunal (CSRT) process,<!--[if !supportFootnotes]-->[14]<!--[endif]--> concluded that 55% of the detainees were not found to have committed any hostile acts, that only 8% were characterized as al Qaeda fighters and that 60% were being detained merely because of alleged association with a group or groups that the government asserts are terrorist organizations.<!--[if !supportFootnotes]-->[15]<!--[endif]--> The study also highlighted the fact that 86% of the detainees were handed over to the United States by Pakistan or the Northern Alliance at a time when the United States was widely publicizing its offer of large financial bounties for the capture of suspected enemies.<!--[if !supportFootnotes]-->[16]<!--[endif]-->
In contrast to these facts, White House spokesperson Tony Snow recently responded to questions about Guantanamo with the assertion that the prisoners are "extraordinarily dangerous killers" . . . who have "waged active warfare against democracy" and were "plucked off the battlefields and trying to kill Americans."<!--[if !supportFootnotes]-->[17]<!--[endif]--> These characterizations have become as much a part of the Administration's mantra as have the assertions of superior nutrition, superior health care and sensitivity to Islamic cultural and religious values; all the while detainees are slowly going crazy from isolation, uncertainty and a failure of justice. Scores have attempted to commit suicide; four have succeeded in taking their own lives.
It is no wonder that the United States is having difficulty out-placing Guantanamo detainees. It is also no wonder that the United States is experiencing a crisis of credibility with its allies. This is not because Europeans see a law enforcement problem where Americans see a war. No European leaders have denied that the United States is involved in an armed conflict in Afghanistan and Iraq, both of which feature significant elements of international terrorism. And while the existence of a world-wide armed conflict with Al Qaida is arguable, it is not this argument that is undermining transatlantic cooperation. Italian prosecutors charge that CIA kidnapping operations there violate Italian law.<!--[if !supportFootnotes]-->[18]<!--[endif]--> The Supreme Court of Spain characterizes American actions in Guantanamo in terms similar to those that preceded Spanish efforts to prosecute human rights violations in Pinochet-era Chile.<!--[if !supportFootnotes]-->[19]<!--[endif]--> It is because even where the application of wartime procedures are apt, Europeans see a great nation fudging the law, fudging the facts, and acting out of its great character. A most telling exchange is the one in which an unnamed member of the Administration patiently informed a reporter that he was from "the reality based community," whereas this Administration "creates its own reality."<!--[if !supportFootnotes]-->[20]<!--[endif]--> This is a vision from which others rightfully recoil.
C. Amend the Definition of Enemy Combatant
Congress is now wisely considering the restoration of habeas corpus, a right that was ill-advisedly removed by the Detainee Treatment Act and Military Commissions Act. Even if that effort succeeds, Congress must also tackle the critical issue of what constitutes an enemy combatant. The Military Commissions Act defines combatants not only as those who take part in hostilities, but includes people who "purposefully and materially" support hostilities against the United States, including people arrested far from the battlefield. This definition risks converting people who would never be considered combatants under the laws of war – such as a doctor who operates on a wounded rebel or a permanent resident of the United States who commits a criminal act completely unrelated to armed conflict – into "combatants" who can be placed in military custody and tried by a military commission. Even more troubling, the MCA deems anyone – regardless of whether they fit the above definition – who has been determined to be an "unlawful enemy combatant" based on a determination of a combatant status review tribunal or "another competent tribunal" established by the president or the secretary of defense to be an enemy combatant. This "you're a combatant if we say you are" approach flies in the face of established humanitarian law and has ramifications that go far beyond the status of detainees at Guantanamo.
Under the laws of war, combatants may in most situations be lawfully attacked and killed; civilians (unless they take part in hostilities) cannot. The MCA definition blurs that vital distinction, with potentially dangerous consequences. Congress should consider carefully the precedent it will set if this definition is allowed to stand. For example, is it in the interest of the United States to endorse a definition of enemy combatant that would allow Russian President Vladimir Putin to pick up anyone he deems to have provided "material support" to the Chechens (as many human rights NGOs in Russia who document abuses in Chechnya could be under this broad definition) and treat them as if they were combatants? Would we be comfortable with the Chinese government using this definition to label peaceful Uighers as enemy combatants? Or President Uribe in Colombia, who earlier this year described some members of the political opposition as "terrorists in business suits?" What about the American citizen in Kenya, cleared by the FBI of terrorist connections, but deemed by the Kenyan government to have "engaged in guerrilla war against the democratically elected government" of Somalia and rendered last month by the Kenyans to Ethiopia?
D. Repeal the MCA
In July of last year, Human Rights First testified before the Senate Armed Services Committee which was at that time deliberating how to try terrorist suspects in the wake of the Supreme Court's ruling in the Hamdan case that the Administration's military commissions were unlawful. At that hearing, we argued that terrorist suspects at Guantanamo should be tried either pursuant to the rules for courts martial under the UCMJ or in regular federal courts. Such trials would satisfy the requirement of the laws of war – and of our own laws – that sentences be carried out pursuant to a "previous judgment pronounced by a regularly constituted court affording all the judicial guarantees which are recognized as indispensable by civilized peoples."<!--[if !supportFootnotes]-->[21]<!--[endif]--> That remains our view.
Human Rights First opposed the Military Commissions Act. Even some Members of Congress who voted for it did so while expressing the hope that the courts would step in to remedy its many defects.
With respect, Mr. Chairman, this is no way to run a railroad. Congress should not wait for the courts to come to the rescue, nor should it merely tinker with the machinery of military commissions. Instead, Congress should scrap the Military Commissions Act altogether, and embrace its responsibility to ensure that suspected terrorists are brought to justice in proceedings worthy of this country.
The defects of the MCA are many and have been well-documented by Human Rights First and others. They encompass issues beyond those related to the rules for military commissions. There are the unconstitutional restrictions on habeas, an overly broad definition of enemy combatant, the removal of certain offenses from the scope of acts punishable as war crimes, the addition of other offenses that are not war crimes and that the Military Commission system is attempting to apply retroactively, and the attempt to undermine the means of enforcing compliance with the Geneva Conventions. One approach Congress could take would be to identify a list – and we certainly have one – of the most egregious flaws and amend the statute to fix them.
The military commissions fly in the face of 200 years of U.S. court decisions by permitting evidence obtained through coercion – including cruel, inhuman and degrading treatment, if obtained before December 20, 2005. A coerced statement can be admitted if found to be "reliable," sufficiently probative, and its admission is "in the interest of justice," and if the interrogation techniques used to obtain the information are classified, it could be extremely difficult for a defendant to show that coerced evidence should not be admitted. Although evidence obtained through torture is not permitted in military commissions, there is an increased likelihood that convictions may rest on such evidence because the rules allow for coerced evidence and hearsay and permit the prosecution to keep sources and methods used to obtain evidence from the defendant.
In violation of a fundamental tenet of the rule of law, defendants before a military commission can be convicted for acts that were not illegal when they were committed. Basic due process requires that a person cannot be held criminally responsible for an action that was not legally prohibited at the time it was taken. But military commissions may punish individuals for offenses — including the crimes of conspiracy and "providing material support for terrorism" — that were either (i) not illegal before the passage of the MCA, or (ii) not recognized as war crimes under the laws of war.
The scope of judicial review of military commission decisions is restricted and inadequate. The review by the initial appeals court, the Court of Military Commission Review, is limited only to matters of law (not fact) that "prejudiced a substantial trial right" of the defendant. This provision would prevent the first appellate court, the U.S. Court of Appeals for the District of Columbia, and the U.S. Supreme Court from considering factual appeals, including possible appeals based on a defendant's factual innocence.
Finally, the military commission rules for classified evidence are so broad that they would prevent the defense from seeing evidence that tends to show innocence or a lack of responsibility. Upon the request of the government, the judge may exclude both the defendant and his lawyer from the process in which the government argues to the judge that classified information should be withheld. The government has no duty to disclose classified information that could result in a more lenient sentence for the defendant. The judge is specifically permitted to limit the scope of examination of witnesses on the stand, which could hamper the ability of the defense to challenge a witness's testimony or basis for classification.
One of the most telling indictments of the original military commissions was the way the ad hoc and constantly-changing system looked up close, in practice. It often looked as if the rules were being written in real time, the very antithesis of the rule of law. Unfortunately, little has changed under the new MCA system. Recently, a Human Rights First staff member attended the first proceedings under the newly constituted MCA commissions, and it is clear that there is little to distinguish the new system from the old. Even after the issuance of a military commissions manual, the fundamental ad hoc character of the system has not changed.<!--[if !supportFootnotes]-->[22]<!--[endif]-->
There is no question that the commissions are staffed by many talented, dedicated and honorable service personnel. But the system itself is illegitimate, and no amount of good will or good lawyering can change that. It is abundantly clear from our observations why Common Article 3 of the Geneva Conventions requires, as a prerequisite for passing sentences and carrying out executions, trials by a "regularly constituted court." The post-MCA system in operation at Guantanamo does not come close to passing that test.
E. Try Suspects in Courts Martial or Federal Courts
The last thing that we would want is to convict an individual for terrorism and then have that conviction overturned because of fatal flaws in the Military Commissions law passed in the previous Congress. That risk is quite real. Khalid Sheik Mohammed would likely have few defenses in a fair trial. But in a military commission under the current rules, he will have the defense that the trial is not fair. The United States can deprive him of that defense by moving his trial to either a court martial or, preferably, to a regular federal criminal proceeding. That not only would guard against the risk of having his conviction overturned, but it is just smart counterterrorism policy. As the Counterinsurgency Manual points out, "to establish legitimacy, commanders transition security activities from combat operations to law enforcement as quickly as feasible. When insurgents are seen as criminals, they lose public support."
Trials in federal court would also offer the advantage of a venue capable of exercising jurisdiction over a much broader spectrum of criminal conduct. The decision to treat terrorism suspects as "enemy combatants" was made in order to justify targeting, detention and trial practices that could not be supported outside of an armed conflict paradigm. There are many reasons, legal and practical, why this decision was, and continues to be, a mistake. One reason is that it has led to the establishment of military commissions that have jurisdiction only over war crimes, limiting the offenses with which terrorist suspects can be charged. This limitation led the administration and Congress to try to expand the jurisdiction of military commissions to include acts such as intentionally causing serious bodily injury; mutilating or maiming; murder and destruction of property in violation of the law of war; terrorism; material support for terrorism; and conspiracy that do not constitute war crimes by simply calling them war crimes.
These acts are not criminal under the laws of war if the targets are legitimate military objectives. And though they are war crimes if committed "in violation of the laws of war," it appears from the charges brought so far that they are erroneously being construed to include any act of unprivileged belligerency, which is not a violation of the laws of war. Application of these new crimes to events that occurred before the passage of the law is a textbook violation of the prohibition of ex post facto prosecution, raising additional and legitimate bases for defense counsel to challenge the military commission convictions. These problems can be avoided by using civilian criminal courts and the broader spectrum of established criminal laws available there.
On the other side of the ledger, those who insist that it would be impossible to try terrorist suspects in the federal courts say that such trials would be too dangerous for judges, juries and witnesses. But the risk of reprisals against juries, witnesses, and judges – while extremely serious – is certainly nothing new.
The judiciary has long taken measures to prevent threats of violence from undermining the trial process. We protect those involved in the trial of murderous mob bosses through witness relocation, anonymous juries, and employing the Marshal Service for the safety of judges. We secure courtrooms with Plexiglas shields, extra layers of security screening, metal detectors, and additional police. Our experience with prosecution of organized crime, including violent members of drug cartels throughout much of the twentieth century, indicates that terrorism cases present no unique challenge in this realm.
Those skeptical of the feasibility of moving these cases to federal court also assert that such prosecutions would force the government to reveal classified information to the defense in order to satisfy constitutional requirements for a fair trial. Leaving aside the fact that terrorist suspects are even now being tried in the federal courts, these are serious concerns that should be explored and fully addressed. But the fact that terrorism cases pose difficult challenges for the criminal justice system should not preclude trials from proceeding successfully to conviction without damage to sensitive information. Given the enormous strategic and political costs of the alternative – the status quo – it is incumbent upon those who would abandon the criminal justice system to demonstrate why the existing procedures, such as the Classified Information Procedures Act (CIPA), designed to protect against such disclosures, are insufficient to protect the government's legitimate interests in these cases. Many judges believe that these procedures are adequate to meet the special challenges presented by terrorism cases. Judge Royce Lamberth recently remarked: "I have found the Classified Information Procedure Act to provide all the tools that I have needed as a district judge to successfully navigate the tricky questions presented in spy cases, as well as terrorist cases." In fact, of the hundreds of CIPA motions filed in criminal cases since the law came into effect, there have been no reversible errors found on appeal. Human Rights First is studying these issues carefully. We urge Congress to consider them as well and to explore whether amendments to CIPA or other measures are needed in order to move forward with these prosecutions in federal court.
V. Conclusion
Human rights advocates normally chafe at the idea of U.S. exceptionalism, and for good reason, since we believe that human rights and the obligation to adhere to the rule of law are neither situational nor culturally bound, but are universal. However, there is at least one respect in which the United States is exceptional, and that is in the degree to which it has positively influenced the human rights agenda in the post-WW II era. And of course, there is now the corollary: the extent to which its practices, policies and pronouncements remain a template for others, for better or worse. The Economist recently said that in a battle that is largely about ideas, America's practices and policies have been "hugely counter-productive."<!--[if !supportFootnotes]-->[23]<!--[endif]-->
The big question, then, is how can the US effectively promote national security and contribute to the global effort to combat terrorism and at the same time, regain its well-deserved reputation as a beacon for human rights, a reputation tarnished by the legacy of Abu Ghraib, Guantanamo, extraordinary rendition, secret detention, torture memos and the specter of unfair trials?
As a general organizing principle, there is the premise of a natural antagonism between collective security and individual rights – the belief that the two comprise a zero-sum game in which the effort to advance one necessarily comes at the expense of the other. Attorney General Gonzales used the word "quaint," to describe the Geneva Conventions in the post-9/11 world. The word acts as a talisman for the assumption that circumstances have overtaken the efficacy, if not applicability, of time-tested rules. This assumption reflects a belief that we cannot counter terrorism without restricting our own rights and liberties - that compromising our rights and liberties will indeed buy us added security.
Oddly enough, we have seen little, if any, evidence that this is true. I was still in the legal division of the ICRC when post-9/11 arguments against proper application of international humanitarian law and human rights norms began to surface. I recall how consistently the critics assailed reliance upon the "old rules" in relation to the "new threat," but just as consistently failed to identify what exactly they wanted to do to suspected terrorists that existing law did not permit. Shoot them on sight? Already permitted in armed conflict and a terrible idea beyond the circumstances in which it is permitted. Detain them without trial? Already permitted in international armed conflict and under certain circumstances, in other situations, as well, but subject to judicial review. Abuse them and subject them to trials that fail to comport with international standards of humanity and due process? Another terrible idea that quite obviously has negative repercussions for our collective security interests.
Evidence suggests that cutting legal corners has reaped little more than derision and distrust, fueling further animosity toward the United States and creating obstacles to international cooperation with it. While Ben Franklin is reputed to have said that those who are willing to sacrifice liberty for security deserve neither, our experience is that we will in fact, lose both. Human rights do not compete with security; they are a prerequisite for it.
It is time for a clean break from these policies. The United States has the opportunity to set a new course, one that takes seriously the long and difficult road ahead in combating the threat of terrorism, while recognizing that adherence to our values and our system of laws is a source of strength in that effort. That is the course designed to bring American back into the fold of ideals and practices for which the OSCE stands.
Thank you.
<!--[if !vml]--><!--[endif]-->
<!--[if !supportFootnotes]-->
<!--[if !supportFootnotes]-->[1]<!--[endif]--> The determination by President Bush in a Memorandum of February 7, 2002 that members of the Taliban are not entitled to PoW status and that members of al Qaeda are not covered by the Geneva Conventions has been hotly debated. While these conclusions are questionable as a matter of law, the Memorandum is less noted for its remarkable assertion that there exist classes of detainees "who are not legally entitled to (humane) treatment."
<!--[if !supportFootnotes]-->[2]<!--[endif]--> The Israeli Supreme Court's recent decision, Public Committee against Torture in Israel, et al v. The Government of Israel, et al, available at http://elyon1.court.gov.il/Files_ENG/02/690/007/a34/02007690.a34.HTM, rejects the U.S. concept of "unlawful combatant."
<!--[if !supportFootnotes]-->[3]<!--[endif]--> See, e.g., Human Rights Committee General Comment 31 on Article 2 of the International Covenant on Civil and Political Rights, adopted March 29, 2004, CCPR/C/21/Rev.1/Add.13; Human Rights Committee, General Comment 29, States of Emergency (Article 4), UN Doc. CCPR/C/21/Rev.1/Add.11 (2001) para. 3; Art. 4 of the International Covenant on Civil and Political Rights, which allows for some provisions to be subject to derogation, while other provisions are non-derogable, including in "time of public emergency which threatens the life of the nation"; Convention against Torture and Other Cruel, Inuman or Degrading Treatment or Punishment, Art. 2(2), Dec. 10, 1984, S. Treaty Doc. No. 100-20 (1988), U.N.T.S. 85 (entered into force June 26, 1987): "No exceptional circumstances whatsoever, whether a state of war or threat of war . . . may be invoked as a justification of torture"; ICJ, Legality of the Threat or Use of Nuclear Weapons, Advisory opinion, 8 July 1996, ICJ Reports 1996, para. 25; ICJ, Legal Consequences of the Construction of a Wall in the Occupied Palestinian Territory, Advisory Opinion, 9 July 2004, ICJ Reports 2004, para. 106; Concluding Observations of the Committee on Economic, Social and Cultural Rights: Israel; 31/08/2001. E/C.12/1/Add.69; Jelena Pejic, Procedural Principles and Safeguards for Internment/Administrative Detention in Armed Conflict and Other Situations of Violence, Vol. 87, No. 858 International Review of the Red Cross 376, pp 377-378 (June 2005); L. Doswald-Beck and S. Vité, International humanitarian law and human rights law, International Review of the Red Cross, No. 293, March-April 1993, p. 94; R.E. Vinuesa, Interface, correspondence and convergence of human rights and international humanitarian law, Yearbook of International Humanitarian Law, Vol. 1, T.M.C. Asser Press, The Hague, 1998, pp.69–110; R. Provost, International Human Rights and Humanitarian Law, Cambridge University Press, Cambridge, 2002; H. Heintze, On the relationship between human rights law protection and international humanitarian law, International Review of the Red Cross, Vol. 86, No. 856, December 2004, p. 798
<!--[if !supportFootnotes]-->[4]<!--[endif]--> Opinions of the Lords of Appeal for Judgment in the Cause Al-Skeini and Others vs. Secretary of State for Defence, [2007] UKHL 26 (June 13, 2007); The Israeli Supreme Court's recent decision, Public Committee against Torture in Israel, et al v. The Government of Israel, et al, available at http://elyon1.court.gov.il/Files_ENG/02/690/007/a34/02007690.a34.HTM, also accepts the complementary application of human rights and humanitarian law in situations of armed conflict.
<!--[if !supportFootnotes]-->[5]<!--[endif]--> For further elucidation on the criteria required to trigger application of the laws of armed conflict, see, Gabor Rona, Interesting Times for International Humanitarian Law: Challenges from the "War on Terror," 27 Fletcher Forum of World Affairs 2, pp55-74 (Summer/Fall 2003).
<!--[if !supportFootnotes]-->[6]<!--[endif]--> See Kenneth Anderson and Elisa Massimino, The Cost of Confusion: Resolving Ambiguities in Detainee Treatment, (Muscatine, Iowa: Stanley Foundation, March 2007) available at http://www.stanleyfoundation.
<!--[if !supportFootnotes]-->[7]<!--[endif]--> U.S. Department of Defense, FM 3-24/MCWP 3-33.5, Counterinsurgency, (December 2006), p. 1-23.
<!--[if !supportFootnotes]-->[8]<!--[endif]--> Karen DeYoung and Josh White, "Guantanamo Prison Likely to Stay Open through Bush Term," Washington Post, March 24, 2007.
<!--[if !supportFootnotes]-->[9]<!--[endif]--> Thom Shanker and David E. Sanger, "New to Job, Gates Argued for Closing Guantánamo Prison," New York Times, March 23, 2007.
<!--[if !supportFootnotes]-->[10]<!--[endif]--> http://www.newsmax.com/archives/ic/2007/6/10/112623.shtml?s=tn , June 10, 2007.
<!--[if !supportFootnotes]-->[11]<!--[endif]--> Karen DeYoung and Josh White, "Guantanamo Prison Likely to Stay Open through Bush Term," Washington Post, March 24, 2007.
<!--[if !supportFootnotes]-->[12]<!--[endif]--> U.S. Department of Defense, FM 3-24/MCWP 3-33.5, Counterinsurgency, (December 2006), p. 1-22.
<!--[if !supportFootnotes]-->[13]<!--[endif]--> While world attention has been fixated on Guantanamo as the embodiment of U.S. misconduct in counterterrorism policy, Guantanamo is not the only prison with which Congress should be concerned. The continued assertion by the President, even after passage of the Military Commissions Act of 2006, of the authority to seize individuals anywhere in the world and hold them in secret prisons without access to the Red Cross or notification to their families is every bit as – if not more – troubling than the prolonged detention at Guantanamo. Congress should ban the practice of holding ghost prisoners and force the closure of any place of detention in which the U.S. holds prisoners in violation of international human rights and humanitarian law.
<!--[if !supportFootnotes]-->[14]<!--[endif]--> The CSRTs were found by one federal judge to fail to comport with Fifth Amendment due process requirements. Judge Joyce Hens Green noted that the CSRTs use an overly-broad definition of "enemy combatant," they fail to provide the detainee with adequate notice of, and an opportunity to rebut the evidence used against him, and they fail to preclude the use of evidence gained through torture or other coercion. In re: Guantanamo Detainee Cases, 355 F. Supp. 2d 443 (D.D.C. 2005).
<!--[if !supportFootnotes]-->[15]<!--[endif]--> Report on Guantanamo Detainees: A Profile of 517 Detainees through Analysis of Department fo Defense Data, Mark Denbeaux, Prof., Seton Hall University School of Law, February 7, 2006; available at http://law.shu.edu/aaafinal.pdf.
<!--[if !supportFootnotes]-->[16]<!--[endif]--> Id. See, Bounty Flyer, attached.
<!--[if !supportFootnotes]-->[17]<!--[endif]--> http://biz.yahoo.com/bw/070612/20070612006144.html?.v=1 Press Briefing, June 12, 2007.
<!--[if !supportFootnotes]-->[18]<!--[endif]--> http://www.latimes.com/news/nationworld/world/la-fg-abuomar9jun09,0,3786556.story?coll=la-home-world
<!--[if !supportFootnotes]-->[19]<!--[endif]--> http://www.libertysecurity.org/article1055.html
<!--[if !supportFootnotes]-->[20]<!--[endif]--> Ron Suskind, New York Times Magazine, October 17, 2004: "The aide said that guys like me were "in what we call the reality-based community," which he defined as people who "believe that solutions emerge from your judicious study of discernible reality." ... "That's not the way the world really works anymore," he continued. "We're an empire now, and when we act, we create our own reality. And while you're studying that reality—judiciously, as you will—we'll act again, creating other new realities, which you can study too, and that's how things will sort out. We're history's actors . . . and you, all of you, will be left to just study what we do."
<!--[if !supportFootnotes]-->[21]<!--[endif]--> See Geneva Convention for the Amelioration of the Condition of the Wounded and the Sick in Armed Forces in the Field, Aug. 12, 1949, entered into force Oct. 21, 1950, 6 U.S.T. 3217, 75 U.N.T.S. 31, available at http://www.icrc.org/ihl.nsf/7c4d08d9b287a42141256739003e636b/fe20c3d903ce27e3 c125641e004a92f3; Geneva Convention for the Amelioration of the Condition of Wounded, Sick, and Shipwrecked Members of Armed Forces at Sea, Aug. 12, 1949, entered into force Oct. 21, 1950, 6 U.S.T. 3217, 75 U.N.T.S. 85, available at http://www.icrc.org/ihl.nsf/7c4d08d9b287a42141256739003e636b/ 44072487ec4c2131c125641e004a9977; Geneva Convention Relative to the Treatment of Prisoners of War, Aug. 12, 1949, entered into force Oct. 21, 1950. 6 U.S.T. 3316, 75 U.N.T.S. 135, available at http://www.icrc.org/ihl.nsf/7c4d08d9b287a42141256739003e636b/6fef854a3517b75ac125641e004a9e68; Geneva Convention Relative to the Protection of Civilian Persons in Times of War, Aug. 12, 1949, entered into force Oct. 21, 1950, 6 U.S.T. 3516, 75 U.N.T.S. 287, available at http://www.icrc.org/ihl.nsf/7c4d08d9 b287a42141256739003e636b/6756482d86146898c125641e004aa3c5
<!--[if !supportFootnotes]-->[22]<!--[endif]--> For example, on the morning of his "trial," defendant David Hicks had three civilian lawyers; by the end of the day, he had only one. Why? One of his civilian defense counsel was told he would have to sign a form, created by the judge, vowing to comply with DOD regulations for civilian defense counsel. But the regulations have not yet been issued by DOD. So the lawyer, reluctant to agree to rules he had not seen for fear of risking ethical violations, agreed to abide by "existing" rules for civilian defense counsel. That wasn't good enough. The judge told the lawyer he could not represent Hicks, though he could sit at counsel table and consult. Another member of the defense team was excluded by the judge based on his interpretation of a contested – and poorly drafted – provision of the rules for military lawyers detailed to represent detainees.
<!--[if !supportFootnotes]-->[23]<!--[endif]--> September 2, 2006, page 10.
Click here for the previous year's Testimonies


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»» Description:
Rocky's Residential Eazy Roller Portable Solar Cover Reel 24' x 50'
Rocky's Residential Eazy Roller Portable Solar Cover designed with larger residential pools in mind; will make removing the cover easy for you and, being portable, will allow you to remove it from poolside without any fuss. Use the AT-2 and Rocky's 12-sided adjustable anodized tubing. Designed for use with the larger residential pools. Eazy Roller makes retrieving the cover easier due to its large handle and 4" castors. The anchor bolts ensure that the system is held in place during operation. It can then be moved away from the pool once the cover is rolled up. Comes with 4" Castors and a large handle to cope with the larger pool covers. Ground clearance to underside of Tubing is approximately 13". Shipping weight is 15lbs.
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subset: commoncrawl


text:
Worked With:
Jake Gyllenhaal
Birth Name: Jake Gyllenhaal
Born: 12/19/1980
Birth Place: Los Angeles, California, USA
Born: 12/19/1980
Birth Place: Los Angeles, California, USA
Jake Gyllenhaal was born on Dec. 19, 1980 to children's television producer-turned-screenwriter Naomi Foner ("Running on Empty," 1988; "Losing Isaiah," 1995), and published poet and film director Stephen Gyllenhaal ("Losing Isaiah," 1995; "Homegrown," 1998). Gyllenhaal and older sister, Maggie, grew up in Los Angeles and thrived in the intellectual, arts-oriented environment their parents created. He was acting by age 11, appearing on the big screen in a brief turn as Mitch's (Billy Crystal) son in "City Slickers" (1991) and in the little-seen kid's adventure "Josh and S.A.M." (1993), as a mean step-brother to the title characters. The 1993 film "A Dangerous Woman," penned by mom and directe... Continue Bio >>
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text:
- CambodiaPersonal UseFunding via KREDIT Microfinance Institution Plc.
RinCambodiaPersonal UseFunding via Hattha Kaksekar Limited (HKL), a partner of Save the Children
Yoeun GroupCambodiaPersonal UseFunding via KREDIT Microfinance Institution Plc.
Ny's Group
This is a micro loan for Ny with Kiva's partner. Now she is leading her group of three to ask for a loan. As the leader, she is going to use her portion to buy material for building a latrine, such as a toilet bowl, tile drainage etc. Ny hopes this loan will enable her to have a clean latrine for her family to use.
Additional Information
More information about this loan
This loan is part of VisionFund Cambodia's initiative to expand access to clean water and/or sanitation to poor rural households.
Water filter loans provide poor households with clean, safe drinking water without requiring it to be boiled over wood fires. This protects borrowers' health and Cambodia's precious forests. Today, many rural Cambodians depend on rainwater, boreholes and surface water -- none of which are regarded as safe sources of fresh water. Walter filters provide a safer, easier and more economic alternative. VisionFund Cambodia is partnering with Hydrologic Social Enterprise to get water filters to families who need them most.
Latrine loans help households build standard, housed latrines for improved sanitation. In rural Cambodia, sanitation poses a major challenge for those who cannot afford to construct a household latrine. Every year, thousands of children die and many others fail to thrive due to dehydration, poor immunity and malnutrition caused by diarrhea and poor sanitation. VisionFund Cambodia is offering credit to change this picture.
About VisionFund CambodiaVisionFund Cambodia is a Christian organization and microfinance institution that provides small loans and other financial services to improve the lives of children, empower poor women and their families, and grow successful businesses. The organization works primarily in rural parts of Cambodia and has distinguished itself by targeting the very poor who require smaller loan sizes, regardless of religious beliefs, gender or ethnic background.
Kiva lenders' funds will help the organization to expand into the northeastern provinces of the country, which have historically been underserved and difficult to reach with financial services.
This is a Group Loan
In a group loan, each member of the group receives an individual loan but is part of a larger group of individuals. The group is there to provide support to the members and to provide a system of peer pressure, but groups may or may not be formally bound by a group guarantee. In cases where there is a group guarantee, members of the group are responsible for paying back the loans of their fellow group members in the case of delinquency or default.
Kiva's Field Partners typically feature one borrower from a group. The loan description, sector, and other attributes for a group loan profile are determined by the featured borrower's loan. The other members of the group are not required to use their loans for the same purpose.
About Cambodia
105View loans »
Success!! The loan was 100% repaid
- Repayment Term
- 8 months (Additional Information)
- Repayment Schedule
- Monthly
- Pre-Disbursed:
- Nov 12, 2012
- Listed
- Dec 11, 2012
- Currency Exchange Loss:
- Possible
- Ended:
- Jun 17, 2013


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Doha, Qatar (Sports Network) - Maybe Victoria Azarenka should still be ranked
No. 1 after all.
Azarenka will lose her spot as the world's top-ranked women's tennis player on
Monday, eclipsed by Serena Williams. However, it was the outgoing No. 1 who
prevailed Sunday in the final of the Qatar Open with a hard-fought, 7-6 (8-6),
2-6, 6-3 victory over the incoming No. 1.
Williams certainly has the resume to be the new No. 1, winning the last two
Grand Slam championships of 2012 and the Olympics. She was guaranteed to be
the new No. 1 on Monday after her quarterfinal win on Friday.
However, Azarenka is no slouch. She did capture her second straight Australian
Open title last month and Sunday's victory over Williams gave the Belarusian
star a 14-0 match record to start the year. Her only "loss" in 2013 came via
walkover when she withdrew before a semifinal against Williams at the Aussie
Open tune-up in Brisbane because of a toe injury.
Azarenka's win Sunday snapped a nine-match losing streak against Williams and
gave her a 2-11 lifetime mark against the American star. Her only previous
victory came in the 2009 Miami final, a 6-3, 6-1 triumph.
The Sports Network


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Carolyn "Ceci" Christenson, age 18, of Gilbert, Ariz., has already survived a rare, life-threatening blood disorder and become a high-powered recruiter for the National Marrow Donor Program (NMDP). Her experience inspires Christenson to speak out for patients whose hope for a cure resembles a high-stakes lottery. In December 2011, she appeared on CBS's "The Early [...]
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On July 8th, 2015 we were "notified" (allegedly - we never got an email) by PayPal that "our brand" of affiliate marketing, which we have had in place since 2010, is no longer "viable". According to their statement, it appears that our business model of paying affiliates for referrals to our websites (that we've practiced without incident for over five years) is suddenly, and without prior notice, in violation of their "Acceptable use Policy". We are currently investigating the situation and if it cannot be resolved we will be seeking alternate payment methods. Without a reliable payment processor, we are not able to operate. Therefore, we have suspended all online promotional activities until this situation has been resolved. We will keep you informed as new information becomes available.
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text:
I would like to open, or create a direct/deep link that opens, the advanced version of the calendar as the presently selected tab.
I can open the advanced client with the mail tab initially open (by going to http://[hostname]/zimbra/?client=advanced ), and I can open the standard client directly to the calendar tab (by going to http://[hostname]/zimbra/h/calendar ), but I don't see how to open the advanced client to the calendar: clicking "Advanced Version" from http://[hostname]/zimbra/h/calendar opens the advanced client with the mail tab initially open.
Is there a way to configure the Zimbra server to automatically open the calendar?
Is there a RESTful way to open the advanced client with the calendar tab selected?


text:
What is bone thugs n harmony's record label
kgb answers » Arts & Entertainment » Music Artists & Songs » What is bone thugs n harmony's record label
Monday, February 06 2012
Source: http://www.bonethugsnharmony.co.uk/album_lyrics.html
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text:
EverRoast® Breakfast Scrambler
- Melt butter in non-stick omelet pan over medium heat.
- Sauté onions and carrots for one minute.
- Add your diced chicken and continue to cook for 30 more seconds.
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text:
we pushed out the 5.10 version of the connector through active directory to a small group of users. one of them started having problems with outlook, and now i'm unable to uninstall the connector. i've removed it through the add/remove programs list, removed all .zdb files and dat files and removed all "zimbra" listings in the registry.
when i try to reinstall any version of the connector it tells me either there's a newer version already installed or an older version could not be removed (depending on which version of the connector i try to install).
can someone tell me how to get 5.10 completely out of there?


text:
(Sports Network) - The Milwaukee Bucks are only 1 1/2 games out of the seventh
seed in the Eastern Conference and will try to improve their lot Wednesday
night when they host the Minnesota Timberwolves.
The Bucks have won two of three and the Boston Celtics have fallen on tough
times. Getting out of the eighth seed could potentially be huge for Milwaukee.
The Bucks don't want to see the Miami Heat in the first round of the playoffs,
but have played the Heat well this season.
Milwaukee owns the tiebreaker over the Celtics by virtue of their 3-1 win in
the season series.
The Bucks' most recent victory came on Monday night when they clobbered the
Charlotte Bobcats, 131-102. The 131 points, 69 first-half points and 100
points through three quarters were all season-highs.
"It's not very often we win by double digits," said interim coach Jim Boylan.
"It was nice for us to do that, get some guys out of the game at the end."
Larry Sanders was outstanding with 24 points and 13 rebounds. Monta Ellis had
19 points, 14 assists and six steals. Ersan Ilyasova, J.J. Redick, Brandon
Jennings and Mike Dunleavy also scored in double figures.
Milwaukee shot 51 percent on 51-for-100 shooting.
On Monday, the Timberwolves earned their first victory over the Boston Celtics
since 2007 and since Minnesota traded Kevin Garnett to the C's. Minny
prevailed 110-110 thanks in large part to Nikola Pekovic.
The big man scored a game-high 29 points and he was listed as questionable for
the game with a sprained ankle.
Dante Cunningham, Andrei Kirilenko, Derrick Williams and J.J. Barea all scored
in double figures.
The Timberwolves won't make the playoffs in a disappointing season ravaged by
injuries. All-NBA forward Kevin Love barely made an impact with hand injuries
and it's still unknown if he will return in the final two weeks of the season.
"I've gotten to the point where if he plays, great, if not we'll deal with the
guys I have here," said head coach Rick Adelman, who is two wins shy of 1,000
in his career. "We're trying to finish the year, and I'm telling the guys to
stay with it. Even if we're losing, make a commitment to getting better. As a
team, as a player, and if Kevin is there, great. But I have no control over
it. You take each game and try to figure out how to get better as a team."
The teams have split their last four meetings, but the Wolves have dropped
three straight and seven of their last eight matchups in Milwaukee.
The Sports Network


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|Colglazier to attend historic presidential inauguration
|Written by Jes-C Brandt
By Jes-c Brandt
Megan Colglazier, an HHS junior, will be present to witness an historical event in Washington D.C. on Jan. 20. As a student at the Presidential Youth Inaugural Conference, she will be watching as president-elect Barack Obama is sworn in.
This won't be the first time Harvey and Nancy Colglazier will be sending their daughter to Washington D.C. As a junior high student, she attended the 2005 Junior National Young Leaders Conference. Following that, she attended the 2006 National Leaders State Conference in Denver.
Before attending the conferences, Colglazier noted she didn't know very much about procedures and policies surrounding the United States government. After being a part of the conferences, she has a newfound appreciation for politics.
Colglazier noted she is especially excited about this conference because of its important place in history. Furthermore, after taking a government class at school, and as an older student, she feels this one will be particularly enlightening.
This conference will have some
similarities to the previous one. Colglazier mentioned she will see many old friends, and will even be rooming with a friend she made on her last trip to the capital. She noted, however, that this trip will have more focus on learning about election processes, from campaigning to inauguration.
As Obama begins inauguration events Jan. 17, Colglazier will be starting her conference. Activities are planned through Jan. 21.
Events outlined for the week include speeches by Al Gore, Archbishop Tutu, Lisa Ling and Colin Powell. They will also have the opportunity to meet various historians and decision makers who will be active in guiding the country in upcoming years.
Students will learn about past presidents' lives, centering on where they were as teenagers and young adults. To learn about the electoral process, attendees will take part in roundtable discussions, debates and other educational activities. On the evening of the inauguration, Colglazier will attend a Black Tie Gala Inaugural Ball.
After Obama has taken his oath of office, Colglazier will view the parade as they proceed down Pennsylvania Ave. and past the White House.
Colglazier expressed an incredible amount of excitement as she nears her departure to Washington D.C. It will be crazy, and it will be fun, she said, and it will be unlike anything she has ever experienced before.


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Kathryn Stockett
Deep South Conquers Hollywood Cynicism for Tate Taylor's Adaptation of 'The Help'
By Rossiter Drake on August 11, 2011 1:30 PM
We hate it when our friends become successful, or so the saying goes, but try telling that to Tate Taylor, the self-described "nobody" whose adaptation of Kathryn Stockett's bestselling 2009 novel The Help arrived in theaters Wednesday.
Who is Taylor? Don't worry, you're hardly alone in asking. The 41-year-old actor, screenwriter and director, for whom The Help is his first studio production, grew up with Stockett in Jackson, Miss. Like Skeeter, one of the heroines of the fledgling author's story about African-American maids and their complicated relationships with white families in early-'60s Mississippi, both were looked after as children by black housekeepers.


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ACHICA > Funky Little Darlings > Funky Little Darlings Giant Wall Sticker - Fantasia
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Funky Little Darlings Giant Wall Sticker - Fantasia
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Includes two sheets of wall stickers (each sheet size: 110 x 60cm).
The size of layout shown 160 x 140cm (size adjustable).
Designed and made with pride in the UK.
Product Code ST0200
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We hope you will be thrilled with your purchases but in the unlikely event that you want to return something, you can find full return instructions on the back of your delivery note or click here


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2-Bedroom Townhome in Kamala - SOLD
- Price reduced from 6.5M THB to 5.7M THB
This two-bedroom townhome is located in a peaceful development in Kamala, roughly 1 kilometre to the beach.
The ground floor contains an open-plan living and dining area, guest WC, and a fully-equipped kitchen. On the middle floor are two spacious bedrooms, both with ensuite bathrooms and balconies to enjoy the beautiful mountain views.
The top level features a roof terrace with BBQ area and Sala, as well as plenty of space for outdoor seating. Very well priced.
Key Features
- Two bedroom townhome in Kamala
- Both bedrooms with ensuite bathrooms
- Spacious lounge and dining area
- Fully-equipped western kitchen
- Large roof terrace with Sala
- Communal swimming pool
- Property and rental management
- 24-hour security
Situated in a peaceful corner of Kamala but within walking distance to the beach and local shops including a good selection of restaurants, low-key bars and Big C supermarket.
View full map
Property Details
- Bedrooms2
- Bathrooms3
- ViewMountain View
- TypeVilla
- ParkingShared
- Swimming PoolShared
- Land Area84 sqm
- Building Area196 sqm
- Ownership StructureLeasehold
- FeaturesCompleted Property, Fully-furnished
- Community Features24-hour Security, Shared Swimming Pool
Interested in this property?
- Office:
- +66 (0)76 325 915
- Mobile:
- +66 (0)89 873 9474
- Email:
- [email protected]


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Madrid, Spain (Sports Network) - Top seeds Serena Williams and Maria
Sharapova were a pair of straight-set third-round winners Thursday at the $4
million Madrid Open, a clay-court French Open tune-up.
The defending champion and world No. 1 Williams clobbered 13th-seeded Russian
Maria Kirilenko 6-3, 6-1 in 64 minutes, while the reigning French Open
titlist, recent Stuttgart champ and former top-ranked Sharapova handled German
Sabine Lisicki 6-2, 7-5 in 1 hour, 42 minutes on Day 6 at The Magic Box.
Williams beat Victoria Azarenka in last year's marquee finale in the Spanish
Also on Thursday, Spanish wild card Anabel Medina Garrigues reached the
quarters via walkover when Kazakhstan's Yaroslava Shvedova pulled out of the
draw. Medina Garrigues, however, should have her hands full with Williams on
The Sports Network


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REGIONALREPORT TriangleMetLife puts a premium on high-tech
"As party chair I have a real good insight into what a lot of folks are dealing with."
DURHAM — Cree introduced its first light-emitting diode bulbs for the retail market, debuting three varieties in Home Depot stores. The maker of energy-efficiency lighting previously sold LEDs only to commercial customers. The bulbs, which cost between $9.97 and $13.97, use 84% less energy compared with traditional ones and have a 10-year warranty.
WAKE FOREST — PowerSecure International purchased Huntersville-based Lime Energy's energy-services subcontracting business, which helps make buildings more energy efficient, for $1.9 million. It will also assume $3.7 million in net liabilities. PowerSecure provides energy-technology services to companies and sells LED lights to customers such as grocery and drug stores.
RESEARCH TRIANGLE PARK — Lenovo named Jay Parker president of North American operations. He succeeds Gerry Smith, whom the Chinese computer-maker named senior vice president and general manager for North America.
RALEIGH — Highwoods Properties bought two 10-story office towers in Tampa, Fla., for $56 million, including $3.5 million in planned renovations. They are about 87% leased and adjacent to a building the company bought in 2009.
MORRISVILLE — TearScience raised up to $70 million from Stamford, Conn.-based HealthCare Royalty Partners to fund the commercialization of its dry-eye treatments. The private medical-device company's products also diagnose the condition.
CARY — The New York Stock Exchange notified Dex One in late February that it was not in compliance with listing standards because its market capitalization had dipped below $100 million for 30 consecutive trading days. The digital advertising and marketing company, which also publishes Yellow Pages, is merging with Dallas-based SuperMedia in an all-stock deal that Dex says will push its market cap above $150 million. Its shares will continue trading as it appeals the ruling.


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DURHAM, N.C. -- Fresh off its 48-30 win over Miami on Saturday, Duke pushed into this week's Associated Press national poll with a No. 25 ranking. The national ranking is the program's first since 1994 when the Blue Devils were 25th following the regular season.
Duke is ranked 24th in this week's USA Today national poll voted on by the nation's head coaches.
Winners of six consecutive games, the Blue Devils stand at 8-2 overall and 4-2 in ACC action. Duke travels to meet Wake Forest on Saturday at 12 noon, and the game will be televised by ESPN2.
Associated Press


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Use of Executive Orders Opposed
February 14, 2013
WHEELING — Sen. Joe Manchin and Rep. David B. McKinley say they will fight any attempts by President Barack Obama to impose climate control legislation through executive order....
when the carnival is over, the clowns pack the tents and left town with the managerie of strange beasts and characters, the Republican President to needs to abolish the democrast party and all their movements, through executive order.
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when President oboma shook hands with Joe Biden he was overheard asking " Who are those new people ?" Joe replied the members of congress. " Introduce me to them later and brief me on what they do " He remarked.
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executive orders.isn't this the way russia does things?obama needs to go.
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The President uses Executive Orders because he chooses to not work within the framework of the American Constition and democracy. Demonizing Congress, which of most of us buy right into, is part of justifying his use of royal orders instead of laws. In his first two year in office, when he had total control of the Congress, both Houses, he was unable to work with Democrats either. The whole purpose of legislators, especially Congressmen is to represent to views of the people who elect them. Its our way of having representation in national government. They are not sent there to represent a national ideology, but to represent our views. Obama does not have any regard at all for well over half of the country. His election is based on gaming the system and playing only to population densities and to people he pays to vote for him, but everyone in America has a right to be represented. He does not and represents a relatively narrow view, plus the 47% of the people paid to vote for hi
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GAINESVILLE, Ga. -- A former White County Sheriff's deputy was sentenced to 15 years in federal prison Tuesday for producing child pornography.
Christopher Thomas Davis pleaded guilty to taking photos of a 7-year-old girl engaging in sexually explicit conduct. According to federal prosecutors, the photos were taken inside his Dahlonega home in the summer of 2009, and additional images of child pornography were found during a search there in August 2011.
"That the defendant committed this offense while serving as a law enforcement officer makes this crime that much more atrocious," U.S. Attorney Sally Quillian Yates said in a statement.
Davis was sentenced to 15 years of supervised release following his prison term. He will also have to register as a sex offender.


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Orchestra Unveils Schedule
May 2, 2013
WHEELING — Setting the stage for interior renovations planned at the Capitol Theatre this summer, the Wheeling Symphony Orchestra has adopted the motto, "Take Your Seat," for its 2013-14 season....
The WSO is, along with Oglebay, the best of Wheeling. Let's be proud and give it strong support.
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They are trying hard.But the City is declining under them.A losing battle. WSO is not JUSA in terms of tourism inflow.A huge error was made turning JUSA away as a TV production.
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Pittsburgh folks will not come to Wheeling for WSO.They came for JUSA.Country is the top radio format in Pittsbugh and Columbus.WQED is last place.
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NFPA Members save an additional 10%.
NFPA 1976 specifies minimum requirements for the design, performance, testing, and certification of the elements of the protective ensemble. Items include coats, trousers, helmets, shrouds, gloves, footwear, and interface items for protection from extremely high levels of radiant heat as well as conductive and convective heat that can be encountered during fire fighting operations involving bulk flammable liquids, bulk flammable gas, bulk combustible metals. Requirements for aircraft rescue and fire fighting operations are also included. (86 pp., 2000)
NFPA 1976 Standard on Protective Ensemble for Proximity Fire Fighting 2000 Edition
Chapter 1 Administration
Chapter 2 Certification
Chapter 3 Labeling and Information
Chapter 4 Design Requirements
Chapter 5 Performance Requirements
Chapter 6 Test Methods
Chapter 7 Referenced Publications
Appendix A Explanatory Material
Appendix B Referenced Publications
Tentative Interim Amendment


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Caravan photos: Topeka, Emporia, Wichita
Pitchers Kyle Davies and Luke Hochevar recently joined Royals Hall of Famers Dennis Leonard and Denny Matthews on a Caravan through Kansas. Let's take a look:
At left, Denny chats with a soldier at the Topeka stop. At right, our king holds court in Emporia.
Below left: Kyle and Luke took a break from signing to smile for the camera at our Wichita stop. At right, Sluggerrr greets two Royals fans.
Thank you to everyone who came out to greet the Caravan and to Tina Short of the Royals Radio Network for sending along these photos!


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Give your workforce easy, on-the-go access to the training they need to maintain a sharp competitive edge – with the SAP Learn Now Mobile App from SAP Education. Learners can choose from a growing list of class titles, download course materials, and take training directly from their iPad or Android tablet.
If your company is like most, you don't have a lot of time to spend on SAP training. But these days, staying well trained is more important than ever. Find out how your business users can train anywhere with an iPad or Android tablet.
SAP Learn Now courses take full advantage of the Apple and Android tablet platforms to deliver training in a new way. Rich media content such as animated, video, and audio lessons give users a solid understanding of how to best work with SAP solutions.
Join the SAP Learn Now Community to exchange questions, comments, and ideas with fellow learners and experienced professionals – on a wide range of SAP learning topics. Check out the latest posts and add to the conversation by sharing your knowledge.


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You searched for: Collections Cholera Online, 1817 to 1900 Remove constraint Collections: Cholera Online, 1817 to 1900 Languages English Remove constraint Languages: English Subjects Homeopathy Remove constraint Subjects: Homeopathy Subjects Latta, S. A. (Samuel Arminius), 1804-1852. Remove constraint Subjects: Latta, S. A. (Samuel Arminius), 1804-1852. Start Over
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1. Review of Dr. S. A. Latta's pamphlet, entitled The cholera in Cincinnati, or a connected view of the controversy between the homoeopathists and the Methodist Expositor: also, a review of the report read before the Homoeopathic Association
- Author(s):
- Miller, Adam.
- Publisher:
- Cincinnati : Ben Franklin Printing House, 1850
- Subject(s):
- Cholera
Latta, S. A. (Samuel Arminius), 1804-1852.


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Product Description
These certified organic and non-GMO sprouting seeds are high quality food grade seeds perfectly suited for home sprouting. Seeds come packaged for storage so you can get some for now and save some for later. Sprouting involves soaking, draining, and rinsing seeds, a process that uses minimal equipment most home kitchens have available.
7 oz
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Hazel Findlay Becomes the First British Woman to Climb 5.14b
Hazel Findlay has climbed Fish Eye in Oliana, Spain, taking the title as the first British woman to climb 5.14b.
Findlay had been projecting this route for seven days and completed it on April 5. She commented on Facebook:
"Yey! I did Fish Eye, 8c! It felt so hard a week ago and today it felt very easy. The fun of redpointing!"
Findlay has sent various styles of routes, including Freerider (5.12d) on El Cap in Yosemite, and the second ascent of Chicama (5.13c) - a dangerous trad line in Wales in March of 2013.
In an interview with British Mountaineering Council (BMC), she says that she did not train specifically for this climb. She also says that she has been trying Mind Control (5.14c), also at Oliana. Only two women have sent Mind Control: Daila Ojeda and Nina Caprez.
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Worked With:
Bruno Campos
Birth Name: Bruno Campos
Born: 12/03/1973
Birth Place: Rio de Janeiro, BR
Born: 12/03/1973
Birth Place: Rio de Janeiro, BR
Memorable guest appearances on sitcoms followed, with Campos' dark good looks and fluency with several foreign accents (although his own English is flawless, having spoken it since the age of five) leading to roles including a part as macho Luis' gay brother on "Suddenly Susan" (NBC, 1997) and Zoe's lecherous Italian paramour on "Cybill" (CBS, 1998). He also had a guest starring role on the short-lived sitcom "Chicago Sons" (NBC, 1997) and was featured in the CBS miniseries "Mario Puzo's The Last Don" (also 1997) before taking on his first regular role on "Jesse". As Chilean-born Diego, Campos not only added an wordly and artistic flair to the sitcom's blue collar Buffalo, New York setting, ... Continue Bio >>
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Neutrogena Rapid Wrinkle Repair Night Moisturizer Reviews
Neutrogena Works SO Nicely!Neutrogena has to be pretty sure of itself to claim that its "Rapid Wrinkle Repair" products work in just a mere week--BUT THEY DO! There is a good reason for it. The Neutrogena line is replete with potent ingredients. Sustained-Action Retinol penetrates skin and does indeed minimize creases quickly while diminishing the look of age spots. A Glucose complex accelerates skin's surface activity ...read moreto boost the time in which this works. Hyaluronic Acid is a wonderful ingredient to plump skin and rejuvenate its overall look. This moisturizer is great for all complexion types. It is very lightweight, absolutely non-greasy, and is absorbed into skin in a very short time. I did notice a softening of the "parentheses" around my mouth in a week, along with some blurring of annoying furrows beginning around the bottom of my neck. My skin is clarified with this, and the overall look is brighter. My husband noticed the difference and tried it himself (and he normally kicks and screams when I suggest moisturizers). The other day he said to me, to my great surprise, that we were "out" of this moisturizer and asked me to pick some more up at the drugstore. It's made an overall improvement in his skin as well. This is excellent for those troubled with both acne and blemishes, as it will handle both. Well done yet again, Neutrogena! — 3 years, 1 month agoGigiSD | 1102 reviews
This review is: Helpful | Not helpful | Inappropriate | 12 of 13 people said helpful
Neutrogena Rapid Wrinkle Repair Night MoisturizerI was invited by Totalbeauy.com to host a party featuring Neutrogena Rapid Wrinkle Repair products. I am using the night moisturizer and I am seeing some really positive results in my skin. My fine lines are diminishing, my deeper lines are smoothing out. This product doesn't irritate my skin, nor does it make it feel oily. I am really pleased with the results I am seeing and the longer I use ...read moreit, the results are more pronounced. I will definitely repurchase this line of skin care. It is really working well for me. — 5 years agolesa5363 | 351 reviews
This review is: Helpful | Not helpful | Inappropriate | 29 of 38 people said helpful
great night moisturizerI hosted a Neutrogena party with my friends, and was excited to try this product after I watched the great Webinar. I think it works very well, my skin looks a little better already and I have only been using it a week. My fine lines look smoother. It does have a light scent that I noticed when I dispensed the product, I thought it might bother my skin but didn't irritate it at all. I think the retail price is great considering the quality :) — 5 years agosmiley48 | 204 reviews
This review is: Helpful | Not helpful | Inappropriate | 16 of 21 people said helpful
Neutrogena Rapid Repair NightI hosted a party for Neutrogena Rapid Repair Products and it was a success. I have gotten feed back on all of the women and men that got to learn and test the product. All of them noticed a big difference in the appearance in their skin. Even,I cant go without the night cream. It is a product I can't do with out. It will be a cream that I will suggest to anyone who needs a anti-aging product. — 4 years, 6 months agotiffany_gallehugh | 8 reviews
This review is: Helpful | Not helpful | Inappropriate | 30 of 56 people said helpful
Awesome product!I absolutely love this night moisturizer! I usually have a hard time finding a moisturizer that I can use at night due to my oily, acne prone skin. Everything is either too heavy or (as with most retinol products I have tried) dries me out and causes my skin to flake. This moisturizer goes on smoothly without any grease, has a light scent that fades quickly and absorbs well. When I get up in t...read morehe morning my skin is not oily at all, it looks plump and smooth. Any bumps that I had when I started using this moisturizer have smoothed out and the breakouts I was developing are gone now! My skin definitely looks younger and less tired. — 5 years agomhw | 100 reviews
This review is: Helpful | Not helpful | Inappropriate | 44 of 45 people said helpful
Can already see Improvement!Thank you to Total Beauty and Neutrogena for allowing me to be a part of the beauty testers for this product. I have been using this night cream for five days now and my skin already looks more radiant and firmer. I was a little nervous at first because of the concentrated retinol, but it works great!! I have been an oil of olay user for over twenty years and I can honestly say that this product does exactly what it promises. Firmer, more radiant skin. Great packaging as well. — 5 years, 1 month agoGlowGirl | 108 reviews
This review is: Helpful | Not helpful | Inappropriate | 6 of 9 people said helpful
where to start!I am in my mid 20's and wanted to start an anti aging regimen which is what led me to this product. I have combo/oily skin and dont have any allergies or sensitivity. What I mainly noticed was how minimal my pores were, not too visible. my face was radiant, keot breakouts at bay and was also a bit even toned. despite the "accelerated retinol sa" this did not cause my skin to peel or give me irrita...read moretion. sadly, i have run out of this product and my pores are now visible, my face looks sallow and due to the usage of another product i am breaking out. I'm buying this again ASAP. 8/10 because results were not in a week as claimed and I did not notice any difference in my fine lines-which im sure will happen if i keep consistent usage of this product. this is definitely a cult classic! — 1 year, 5 months agohappily_blue | 19 reviews
This review is: Helpful | Not helpful | Inappropriate | 1 of 1 people said helpful
Neutrogena Rapid Wrinkle Repair Night MoisturizerI strayed away from this product because I love to try new things. But I am back to it. My skin looks better, and those fine lines are smoother. My skin is sensitive but it does not irritate at all. Lately, I have noticed breakouts on my chin and I can not figure out why - but this moisturizer helps calm them down. This time I am staying with it. — 2 years, 3 months agocunningham1157 | 12 reviews
This review is: Helpful | Not helpful | Inappropriate | 3 of 3 people said helpful
Yes!This is the STUFF for me. I have oily skin but this does not make me break out. It smells very nice and feels so smooth. I have noticed a difference it my skin's texture since using it. I think retinol is the way to go and this cream is my choice. — 2 years, 6 months agoVpinkLotus | 7 reviews
This review is: Helpful | Not helpful | Inappropriate | 8 of 9 people said helpful
Neutrogena Rapid Wrinkle Repair Night MoisturizerI have used the Neutrogena Rapid Wrinkle Repair Night Moisturizer for several months - and I really wanted to give it a fair chance - but so far I am just completely not impressed. Typically, I like Neutrogena products because they work well with my finicky sensitive skin; however, this night cream really fails to deliver desired results. Perhaps it is not/was not the best night cream for my skin ...read moretype, but I assume there are others out there who also have sensitive skin who are interested in trying out this moisturizer. First problem I had - it was very greasy. I have combination skin, and even in the dry areas it did not absorb very well. Second problem I had - I found that I broke out more often while using it. I am not a stranger to Retin A treatments, so the increased frequency of break outs was pretty surprising. And the third problem I had was the smell. It smelled like a cheap chemical laced lotion. It was not pleasant or tolerable at all. I only gave this a 3 because I like Neutrogena and it did not feel right to give it a lower score. — 2 years, 8 months agodani_marie_e | 4 reviews
This review is: Helpful | Not helpful | Inappropriate | 3 of 3 people said helpful
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