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COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION ONE. STATE OF WASHINGTON, Respondent, v. JODI ANN WARREN, Appellant.
- Hillary McGee
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1 No I COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION ONE STATE OF WASHINGTON, Respondent, v. JODI ANN WARREN, Appellant. ON APPEAL FROM THE SUPERIOR COURT OF THE STATE OF WASHINGTON FOR WHATCOM COUNTY # RESPONDENT S BRIEF DAVID S. McEACHRAN Whatcom County Prosecuting Attorney By JEFFREY B. TEICHERT, Appellate Special Deputy Prosecutor Whatcom County Prosecuting Attorney 311 Grand Avenue, Second Floor Bellingham, WA (360) Respondent s Brief p. i
2 TABLE OF CONTENTS A. ASSIGNMENTS OF ERROR B. ISSUES PERTAINING TO APPELLANT S ASSIGNMENTS OF ERROR C. FACTS D. ARGUMENT The Appellant Was Fully Advised of Her Rights and Received Adequate Miranda Warnings a. The Trial Court Correctly Found that the Specific Wording of Miranda Warnings Need Not be Proven as Long as the Rights Are Adequately Conveyed b. Routine Booking Procedures Such as Filling Out a DUI Process Form Do Not Require Miranda Waivers The Appellant Impermissibly Invited Error by Objecting to Testimony About the Specific Miranda Warnings Provided to the Appellant and Later Appealing on the Ground that Such Testimony Was Not Presented The Defendant Failed to Make an Unequivocal Request for an Attorney Sufficient to Require the Cessation of Questioning The Prosecutor s Brief Statement that the Jury Was Not to Consider Sentencing in its Determination of Guilt did not Create Reversible Error Any Alleged Error by the Trial Court in this Matter was Harmless and Does Not Require Reversal E. CONCLUSION Respondent s Brief p. ii
3 Respondent s Brief p. iii
4 TABLE OF AUTHORITIES Page WASHINGTON CASES State v. Armstrong, 69 Wn. App. 430, 848 P.2d 1322, rev. denied 122 Wn.2d 1005 (1993) State v. Barrow, 60 Wn. App. 869, 809 P.2d 209, rev. denied, 118 Wn.2d 1007 (1991) State v. Belgarde, 110 Wn.2d 504, 755 P.2d 174 (1988) State v. Bradford, 95 Wn.App. 935, 978 P.2d 534, rev. denied, 139 Wn.2d 1022 (1999) State v. Braun, 82 Wn.2d 157, 509 P.2d 742 (1973) State v. Brown, 132 Wash.2d 529, 940 P.2d 546 (1997) State v. Case, 49 Wn.2d 66, 298 P.2d 500 (1956) State v. Chapman, 84 Wn.2d 373, 526 P.2d 64 (1974) State v. Davenport, 100 Wn.2d 757, 675 P.2d 1213 (1984) , 20 State v. Earls, 116 Wn.2d 364, 805 P.2d 211 (1991) Respondent s Brief p. iv
5 State v. Grieb, 52 Wn. App. 573, 761 P.2d 970 (1988) , 15 State v. Grisby, 97 Wn.2d 493, 647 P.2d 6 (1982) , 21 State v. Gutierrez, 50 Wn. App. 583, 749 P.2d 213, rev. denied, 110 Wn.2d 1032 (1988) State v. Hutton, 57 Wn. App. 537, 789 P.2d 778 (1990) , 6 State v. Lewis, 15 Wn. App. 172, 548 P.2d 587, rev. denied, 87 Wn.2d 1005 (1976) , 11 State v. Mak, 105 Wn.2d 692, 718 P.2d 407 (1986) State v. Moore, 79 Wn.2d 51, 483 P.2d 630 (1971) State v. Music, 79 Wn.2d 699, 489 P.2d 159 (1971), vacated on other grounds, 408 U.S. 940 (1972) State v. Reed, 102 Wn.2d 140, 684 P.2d 699 (1984) State v. Rupe, 101 Wn.2d 664, 683 P.2d 571 (1984) ,7 State v. Sargent, 111 Wn.2d 641, 762 P.2d 1127 (1988) , 9, 12 State v. Smith, 34 Wn. App. 405, 409, 661 P.2d 1001, rev. denied, 100 Wn.2d 1008 (1983) Respondent s Brief p. v
6 State v. Tetzlaff, 75 Wn.2d 649, 453 P.2d 649 (1969) State v. Torres, 16 Wn. App. 254, 554 P.2d 1069 (1976) State v. Young, 63 Wn. App. 324, 818 P.2d 1375 (1991) FEDERAL CASES California v. Prysock, 453 U.S. 355 (1981) , 6 Davis v. United States, 512 U.S. 452 (1994) , 15 Edwards v. Arizona, 451 U.S. 477 (1981) Garner v. United States, 424 U.S. 648 (1976) Miranda v. Arizona, 384 U.S. 436 (1966) passim Moran v. Burbine, 475 U.S. 412 (1986) North Carolina v. Butler, 441 U.S. 369 (1979) RULES CrR 3.1(c)(2) CrR Respondent s Brief p. vi
7 A. ASSIGNMENTS OF ERROR None. B. ISSUES PERTAINING TO APPELLANT S ASSIGNMENTS OF ERROR 1. Does the lack of specific testimony as to the precise wording of Appellant s Miranda warnings require the suppression of subsequent statements given in custody? 2. Do routine procedures such as filling out DUI processing forms require Miranda warnings? 3. May a defendant invite error by objecting to the introduction of testimony for strategic reasons, and then on appeal allege error in failing to consider such testimony? 4. Does a question from the accused about whether she should speak with an attorney constitute an unequivocal request for an attorney, requiring the termination of all questioning? 5. Is a brief statement by the prosecutor alluding to a possible sentence of community service substantially likely to change the jury s verdict creating unfair prejudice to the defendant? 6. Would the absence of all post-arrest statements by the defendant and the prosecutor s comment alluding to a possible sentence of community service have resulted in a verdict of acquittal instead of conviction? FACTS On May 29, 2001, Jodi Ann Warren ( Appellant ) was driving erratically on I-5, and was stopped by Washington State Trooper Jason Armstrong near the junction of I-5 and Lakeway Ave. in Bellingham. RP Respondent s Brief p. 1
8 4-5, Following a field sobriety test, Trooper Armstrong arrested the Appellant for Driving Under the Influence ( DUI ). RP 4-5, 145. Incident to the arrest, Trooper Armstrong searched the Appellant, some areas in her automobile, and her purse. RP 6. Inside the purse, Trooper Armstrong discovered a pipe made of aluminum foil that had been used to smoke marijuana and a bindle with traces of what appeared to be (and was) cocaine, and a cocaine-snorting device. RP 9, 47, 54. Trooper Armstrong seized the purse and its contents, and took it with him in his patrol car. RP 6. Prior to taking the Appellant to jail, Trooper Armstrong read the Appellant her constitutional rights from a DUI checklist or, as the officer stated, we had gone through the constitutional rights which she stated she understood. RP 24, 6, 19, 33, 45. The Appellant admitted at trial, without complaint, that Trooper Armstrong advised her of her constitutional rights. RP Trooper Armstrong also asked the Appellant a series of specific questions to determine whether she understood her rights, and recorded the Appellant s answers in his report. RP 7, Appellant stated to the officer that she understood those rights and the waiver of them. RP 7, 24. Prior to being read her rights, the Appellant denied knowing what 1 As in the Appellant s brief, the Verbatim Report of Proceedings is referenced as follows: RP refers to the hearing and trial held on December 18 & 19, 2001, and SRP refers to the ruling on Appellant s new trial motion and sentencing of February 6, Respondent s Brief p. 2
9 the Trooper found in her purse, and afterward she denied using marijuana or cocaine recently. RP 8. After being read and confirming her Miranda warnings and denying that she had used drugs recently, Appellant asked if she should talk further without first talking to her lawyer. RP 8-9. Trooper Armstrong indicated that it was up to the Appellant and stopped questioning her. RP 9-10, 19. When Trooper Armstrong arrived at the Whatcom County Jail with the Appellant, Trooper Armstrong asked her if she wanted to call her attorney and suggested that she might try calling his answering service. RP 10, However, the Appellant indicated that she would call her attorney later when he was in the office, implying that the DUI processing could proceed without a lawyer. RP 11. C. ARGUMENT 1. The Appellant Was Fully Advised of Her Rights and Received Adequate Miranda Warnings a. The Trial Court Correctly Found that the Specific Wording of Miranda Warnings Need be Proven as Long as the Rights Are Adequately Conveyed The Appellant claims that the trial court erred by admitting postarrest statements by the Appellant, notwithstanding an alleged failure to fully advise the Appellant of her rights before questioning her. The right to receive Miranda warnings was derived by the Supreme Court from the Respondent s Brief p. 3
10 Fifth Amendment 2 privilege against self-incrimination. Miranda v. Arizona, 384 U.S. 436, , 442 (1966). The central holding of Miranda is as follows: [T]he prosecution may not use statements, whether exculpatory or inculpatory, stemming from custodial interrogation of the defendant unless it demonstrates the use of procedural safeguards effective to secure the privilege against self-incrimination. By custodial interrogation, we mean questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way. As for the procedural safeguards to be employed, unless other fully effective means are devised to inform accused persons of their right of silence and to assure a continuous opportunity to exercise it, the following measures are required. Prior to any questioning, the person must be warned that he has a right to remain silent, that any statement he does make may be used as evidence against him, and that he has a right to the presence of an attorney, either retained or appointed. The defendant may waive effectuation of these rights, provided the waiver is made voluntarily, knowingly and intelligently. If, however, he indicates in any manner and at any stage of the process that he wishes to consult with an attorney before speaking there can be no questioning. Likewise, if the individual is alone and indicates in any manner that he does not wish to be interrogated, the police may not question him. The mere fact that he may have answered some questions or volunteered some statements on his own does not deprive him of the right to refrain from answering any further inquiries until he has consulted with an attorney and thereafter consents to be questioned. 2 According to the Washington Supreme Court, the protection of article 1, section 9 [of Washington s Constitution] is coextensive with, not broader than, the protection of the Fifth Amendment. State v. Moore, 79 Wn. 2d 51, 483 P.2d 630 (1971); State v. Earls, 116 Wn. 2d 364, , 805 P.2d 211 (1991). Respondent s Brief p. 4
11 Id. at Miranda was motivated, in no small part, by the famous Wickersham Report to Congress by a Presidential Commission in the 1930s, which found that police violence and the third degree flourished at that time. Id. at 445. The Miranda Court explained that its decision was driven by a desire to end practices where, the police resorted to physical brutality - beating, hanging, whipping - and to sustained and protracted questioning incommunicado in order to extort confessions. Id. at 446. Miranda warnings are intended to protect a suspect thrust into an unfamiliar atmosphere or an interrogation environment who may think the interrogation will continue until he confesses. State v. Sargent, 111 Wn.2d 641, 649, 762 P.2d 1127 (1988). The State must prove by a preponderance of evidence that a custodial statement of a defendant is voluntary. State v. Grisby, 97 Wn.2d 493, 505, 647 P.2d 6 (1982) (citing Lego v. Twomey, 404 U.S. 477 (1972); State v. Braun, 82 Wn.2d 157, 509 P.2d 742 (1973)). There is no evidence of underhanded, coercive or abusive questioning in the present case. A police officer need not follow "word for word" the precise language in Miranda, if s/he informs the defendant of his rights "in a way which conveys their full import." State v. Rupe, 101 Wn.2d 664, 677, 683 P.2d 571 (1984) (citing California v. Prysock, 453 U.S. 355 (1981); State v. Hutton, 57 Wn. App. 537, 789 P.2d 778 (1990). For instance, no Respondent s Brief p. 5
12 Washington court has held that... Miranda warnings specifically [must] include the advice that counsel will be appointed without charge particularly where nothing in the record even suggests that [the defendant] was confused about his right to counsel. State v. Hutton, 57 Wn. App. 537, 789 P.2d 778 (1990) (holding that Miranda warnings were adequate even though they could have been even clearer[.] ) In the present case, nothing in the record suggests either that the Appellant was not advised of her right to remain silent or to have an attorney present during questioning, or that she was confused about these rights. On the contrary, the Appellant s trial counsel acknowledged at trial that the officer read the constitutional rights to the Appellant, RP 45, and the Appellant confirmed that she understood them. RP 6, 19, 24, 33, 45. The Appellant personally acknowledged at trial, without complaint, that Trooper Armstrong had reviewed her constitutional rights with her. RP The Appellant now argues that there is an absence of evidence as to how Trooper Armstrong specifically administered the Miranda warnings. Appellant s Br. at However, the warnings need not be an incantation of the precise language contained in Miranda. California v. Prysock, 453 U.S. 355 (1981). Similarly, the Washington Supreme Court has held that no talismanic incantation is necessary to make Miranda warnings effective. The essence of the Miranda warnings is that the defen- Respondent s Brief p. 6
13 dant be advised of his rights in a way which conveys their full import including a warning that sufficiently alerts a defendant that his statements may be used in court. State v. Rupe, 101 Wn.2d 664, 683 P.2d 571 (1984). This standard is satisfied if defendant was generally aware of his legal rights but waived them. Id. There is nothing in the record providing a reason to doubt whether the warnings provided by Trooper Armstrong were sufficient. In the present case, the Appellant complains that Trooper Armstrong did not ask the Appellant to sign a written waiver of her rights, and erroneously asserts that Trooper Armstrong did not present the Appellant with a waiver form to be read nor read such a form to the Appellant. The United States Supreme Court and the Supreme Court of Washington have explicitly rejected the argument that a waiver of Miranda rights is invalid because it is not in writing. North Carolina v. Butler, 441 U.S. 369, 373 (1979); Rupe, 101 Wn.2d at 678. Furthermore, the record amply demonstrates that Trooper Armstrong was working from his DUI packet when he gave the Appellant her Miranda warnings and explained the waiver to her, RP 7; and Appellant s trial counsel acknowledged to the Court the police report s statement that Trooper Armstrong, read the constitutional rights to the Appellant, RP 45, and the Appellant confirmed that she understood them. RP 6, 19, 24, 33, 45. The record further reflects that Respondent s Brief p. 7
14 Trooper Armstrong asked the Appellant a series of specific questions to determine whether she understood her rights, and recorded the Appellant s answers in his report. RP 7, The Appellant stated to the officer that she understood those rights and the waiver of them. RP 7, 24. Contrary to the Appellant s assertions, Trooper Armstrong did read the Appellant s Miranda warnings to her. See Appellant s Br. at 8. The Appellant further complains that Trooper Armstrong did not testify specifically as to what constitutional rights he advised the Appellant of before questioning her. Appellant s Br. at Similarly, in State v. Brown, 940 P.2d 546, 132 Wash.2d 529 (1997)(a portion of the record had been lost by a court reporter), the appellant argued that the record as to Miranda warnings was conclusory at best and because this portion of the record (which addresses his Miranda warnings) is missing, appellate counsel is unable to effectively assign and argue error on appeal[.] However, in that case, the court held that the appellant s claim is without merit because there was sufficient non-testimonial evidence in the record to satisfy the court that appropriate Miranda warnings had been provided. Id. While the evidence in this case is not as clear as it could be, it is clear that Trooper Armstrong employed a standardized Miranda procedure as discussed above. Furthermore, Trooper Armstrong testified that Appellant asked if she should say anything without talking to a lawyer and I told Respondent s Brief p. 8
15 her it was up to her. RP 9. This statement unmistakably indicates that the Appellant knew and understood that she did not have to talk to the officer without an attorney, and that Trooper Armstrong had further clarified to her that it was her decision whether to do so. b. Routine Booking Procedures Such as Filling Out a DUI Processing Form Do Not Require a Miranda Waiver Additionally, it is well established that routine booking procedures do not call for Miranda warnings[.] State v. Sargent, 111 Wn.2d 641, 651, 762 P.2d 1127 (1988). In the present case, as soon as the Appellant raised the possibility of speaking to an attorney, Trooper Armstrong stated that it was up to the Appellant whether to consult her attorney before answering further and terminated the interview. RP 9-10, 19. The only questions that Trooper Armstrong asked following the termination of the interview were necessary to execute the standard procedure of processing a DUI. RP 11. Trooper Armstrong testified that the DUI processing in this case involved [n]othing other than what normally takes place. RP 11. Respondent s Brief p. 9
16 2. The Appellant Impermissibly Invited Error by Objecting to Testimony About the Specific Miranda Warnings Provided to the Appellant and Later Appealing on the Ground that Such Testimony Was Not Presented Invited error prohibits a party from setting up error in the trial court and then complaining of it on appeal. State v. Armstrong, 69 Wn. App. 430, 434, 848 P.2d 1322 (1993) (quoting State v. Young, 63 Wn. App. 324, 330, 818 P.2d 1375 (1991)). In Washington, a self-invited error precludes appellate review even against complaints that the Appellant has been denied constitutional due process. State v. Lewis, 15 Wn. App. 172, 176, 548 P.2d 587 (1976). This rule is particularly applicable, where defense counsel employed a tactical maneuver in what then appeared to be the best interest of his client. Id. When a defendant employs a strategy at trial that forecloses certain constitutional rights, an appellate tribunal should not later retract that implied waiver to save the defendant from himself. We hold, therefore, that when a defendant in the procedural setting of a criminal trial makes a tactical choice in pursuit of some real or hoped for advantage, he may not later urge his own action as a ground for reversing his conviction even though he may have acted to deprive himself of some constitutional right. A criminal defendant is entitled to a fair trial from the state, including due process. He is not denied due process by the state when such denial results from his own act, nor may the state be required to protect him from himself. Respondent s Brief p. 10
17 Id. at 177. This analysis applies exactly to the present case. The Prosecutor requested to reopen the Rule 3.5 hearing in order to answer a technical matter raised by the trial court that the state had not provided specific testimony as to what specific Miranda rights the Appellant was advised of. RP 33. When the Prosecutor made this request, defense counsel said: I object, Your Honor. We have rested and decided our strategy in this case. We haven t called our client to testify. RP 33. The record clearly indicates that, for strategic reasons, defense counsel objected to the introduction of testimony about the specific Miranda rights of which the Appellant was advised. The Appellant cannot now claim that the state s failure to introduce such testimony is reversible error, simply because the strategy was unsuccessful. Following defense counsel s objection to introducing more specific testimony about the Appellant s Miranda warnings, the Prosecutor stated that the testimony was sufficiently clear that the Appellant had received adequate Miranda warnings. RP 33. The court agreed and stated that without the issue being raised by the Appellant, he didn t think that the lack of specificity was a problem. RP 33. During that colloquy, defense counsel never retracted his objection nor indicated that he believed in any way that the Miranda warnings or the testimony regarding them were deficient. He did not ask questions in cross-examining Trooper Armstrong to Respondent s Brief p. 11
18 clarify the specific rights of which the Appellant was advised, though he had ample opportunity to do so. In fact, in arguing a motion in limine, seeking to suppress some of Appellant s post-arrest statements, defense counsel acknowledged that Trooper Armstrong had written in the police report that he read the constitutional rights[.] RP 45. If the Appellant believed that more testimony as to her Miranda warnings was needed, she should not have objected to its introduction before the trial court. Accordingly, this court should not countenance any appeal flowing from the failure to provide more specific evidence about Appellant s Miranda warnings. 3. The Defendant Failed to Make an Unequivocal Request for an Attorney Sufficient to Require the Cessation of Questioning [T]he Fifth Amendment privilege against self-incrimination must be asserted; it is not self-executing. State v. Sargent, 111 Wn.2d 641, 648, 762 P.2d 1127 (1988) (citing Garner v. United States, 424 U.S. 648, 654 n.9 (1976)). If the accused requests an attorney, questioning must cease until an attorney is present. Miranda, 384 U.S. at 474; Edwards v. Arizona, 451 U.S. 477, 482 (1981). However, the right to counsel must be clearly asserted to bar re-interrogation of the defendant and require the suppression of subsequent statements. Edwards, 451 U.S. at 485. Appellant is correct that a waiver of the right to counsel during interrogation Respondent s Brief p. 12
19 may not be induced by a misstatement of the rights of the accused. State v. Tetzlaff, 75 Wn.2d 649, 652, 453 P.2d 649 (1969) (warnings were given to the effect that the accused had a right to an attorney only if charged with a crime). However, there is no indication in the record that there was such a misstatement in the present case. The accused must invoke the right to counsel through unequivocal language to make it effective. The United States Supreme Court held: The applicability of the "`rigid' prophylactic rule" of Edwards requires courts to "determine whether the accused actually invoked his right to counsel." Smith v. Illinois, supra, at 95 (emphasis added), quoting Fare v. Michael C., 404 U.S. 707, 719 (1979)..... [I]f a suspect makes a reference to an attorney that is ambiguous or equivocal in that a reasonable officer, in light of the circumstances, would have understood only that the suspect might be invoking the right to counsel, our precedents do not require the cessation of questioning. See ibid. ("the likelihood that a suspect would wish counsel to be present is not the test for applicability of Edwards"); Edwards v. Arizona, supra, at 485 (impermissible for authorities "to reinterrogate an accused in custody if he has clearly asserted his right to counsel") (emphasis added). Rather, the suspect must unambiguously request counsel. As we have observed, "a statement either is such an assertion of the right to counsel or it is not." Smith v. Illinois, 469 U.S., at (brackets and internal quotation marks omitted). Although a suspect need not "speak with the discrimination of an Oxford don," post, at 12 (SOUTER, J., concurring in judgment), he must articulate his desire to have counsel present sufficiently clearly that a reasonable police officer, in the circumstances, would understand the statement to be a request for an attorney. If the statement fails to meet the requisite level of clarity, Edwards does not require that the officers stop questioning the Respondent s Brief p. 13
20 suspect. See Moran v. Burbine, 475 U.S. 412, 433, n. 4 (1986) ("the interrogation must cease until an attorney is present only [i]f the individual states that he wants an attorney") (citations and internal quotation marks omitted). We decline petitioner's invitation to extend Edwards and require law enforcement officers to cease questioning immediately upon the making of an ambiguous or equivocal reference to an attorney. See Arizona v. Roberson, supra, at 688 (KENNEDY, J., dissenting) ("the rule of Edwards is our rule, not a constitutional command; and it is our obligation to justify its expansion"). The rationale underlying Edwards is that the police must respect a suspect's wishes regarding his right to have an attorney present during custodial interrogation..... We also noted that, if a suspect is "indecisive in his request for counsel," the officers need not always cease questioning. See id., at 485. Davis v. United States, 512 U.S. 452 (1994) (emphasis supplied). This language makes clear that an indecisive or equivocal statement about an attorney does not require the cessation of questioning. As the Supreme Court of Washington stated in State v. Grieb, 52 Wn. App. 573, 576, 761 P.2d 970 (1988), equivocally stated desires are of no moment. The Davis Court applied this rule to facts strikingly similar to the present case and concluded that the Appellant s alleged request for counsel was insufficient to require the cessation of questioning: The courts below found that petitioner's remark to the NIS agents - "Maybe I should talk to a lawyer" - was not a request for counsel, and we see no reason to disturb that conclusion. The NIS agents therefore were not required to stop questioning petitioner, though it was entirely proper for them to clarify whether petitioner in fact wanted a lawyer. Respondent s Brief p. 14
21 Davis v. United States, 512 U.S. 452 (1994) (emphasis supplied). Similarly, in State v. Smith, 34 Wn. App. 405, 409, 661 P.2d 1001 (1983), the Court of Appeals specifically found that the question "[d]o you think I need an attorney?" was an equivocal request, requiring further clarification. In the present case, the officer testified that the Appellant asked if she should say anything without talking to a lawyer and I told her it was up to her. RP 9. The Appellant s equivocal statement does not materially differ from the equivocal statements evaluated in the Davis and Smith cases, and clearly was not an effective assertion of the right to counsel sufficient to terminate questioning. The Appellant s statement can easily be distinguished from the situation in State v. Chapman, 84 Wn.2d 373, 375, 526 P.2d 64 (1974), where the accused had asked for an attorney now or State v. Grieb, 52 Wn. App. 573, P.2d 970 (1988), where the accused had stated repeatedly I don't wanna waive my rights but the police continued to question him anyway. When Trooper Armstrong arrived at the County Jail with the Appellant, he attempted to clarify her equivocal statement, asking directly if she wanted to call her attorney. RP 10, 19. The Appellant stated that she did not have his home number and didn t know how she was going to get a hold of him. RP 10, 19. Trooper Armstrong suggested that the Ap- Respondent s Brief p. 15
22 pellant could call his answering service. RP 10, In reply, the Appellant inquired what would be taking place. RP 10, 20. When told that she would be processed for a DUI and other criminal offenses, [s]he stated that she would call the attorney later that day when he got in the office implying that Trooper Armstrong could move forward with the paperwork and that Appellant would get her attorney involved at a later time. RP 11. This was the factual finding of the trial court. Supp. CP, Sub. No The Supreme Court has held that a police officer need not go out of the way to put an accused person in touch with his/her attorney if s/he has knowingly consented to answer questions without an attorney. The court held that the police need not even inform the accused that his/her attorney was immediately available and waiting within the same building to talk to the accused because, [e]vents occurring outside of the presence of the suspect and entirely unknown to him surely can have no bearing on the capacity to comprehend and knowingly relinquish a constitutional right. State v. Bradford, 95 Wn.App. 935, 978 P.2d 534 (1999) (quoting Moran v. Burbine, 475 U.S. 412, 422 (1986)). While the lateness of the 3 Although the Appellant made no unequivocal expression of desire for a lawyer, Trooper Armstrong s offer to allow her to call his answering service would have met the requirement of Criminal Rule 3.1(c)(2) that the person in custody who desires a lawyer shall be provided access to a Respondent s Brief p. 16
23 hour and the Appellant s assumption of her attorney s unavailability may have affected her willingness to go ahead with the DUI processing without the attorney s assistance, her consent was nonetheless voluntary. This contention is strengthened by the fact that Trooper Armstrong clearly indicated to the Appellant that it was her decision whether to speak to her attorney before answering further questions, RP 9-10, 19, and specifically asked her if she wanted to call him on the telephone. RP 10, The Prosecutor s Brief Statement that the Jury Was Not to Consider Sentencing in its Determination of Guilt did not Create Reversible Error The Appellant argues that the following language in the Prosecutor s closing argument is improper: One of your [jury] instructions states, I think it is Instruction No. 1, it talks about how you have nothing whatever to do with any punishment that may be imposed in case of a violation of law; the fact that punishment is irrelevant to you. So the fact that if the defendant is convicted and if she is ordered to perform community service or something like that, that s not to enter into it. RP 177; see Appellant s Br. at 27. The Appellant s trial counsel objected to the above-quoted argument. The court sustained the objection and instructed to Prosecutor to move on. RP 177. The Appellant correctly noted telephone. Respondent s Brief p. 17
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Castle for rent from € 158/day in Le VeurdreName/Address: Un château en bordure de rivière
Image disclaimer: It is the responsibility of the hotel chain and/or the individual property to ensure the accuracy of the photos displayed. Dream Home Shop is not responsible for any inaccuracies in the photos.
450sq. m.
5 2
+ Expand
Charming and private castle on four hectares, with river, sun terrace and stunning viewsFind peace, privacy, authenticity and style on the edge of Burgundy and the Auvergne in this fantastic castle, origins from 1315. Via a rich history, the castle has grown to its present appearance. The current owners have restored the castle until 2010, they have managed to maintain original details in their 'original' state. You will enjoy this by observing the "escalier d 'honneur", the 4 sandstone fireplaces and the tower room. From the lovely kitchen you overlook the valley with river. From the generous, southern oriented terrace with BBQ, you will enjoy the magnificent views. De upper floor is divided into two parts: on part has two bedrooms and the other one three. So that everyone keeps a certain level of privacy. In the castle you will prefer to stay "at home" in stead of going out. Especially because you will enjoy a property (four hectarse). As well in the beautiful surrounding there are numerous activities such as cycling, tennis, golf and canoeing. In the nearby village you will find 'la baguette', 'le café crème' et 'le journal! Que demande le peuple'!
Ground floor: (Entrance, Sitting room(CD player, stereo), Dining room(hearth(wood)), Kitchen(dishwasher, fridge freezer), WC, WC, library(TV, DVD player), utility room(microwave, fridge freezer, washing machine)) On 1st floor: (Bedroom(double bed or 2 single beds), Bedroom(double bed or 2 single beds), Bedroom(Double bed), Bedroom(Queen size bed), Bedroom(Queen size bed), Bathroom(bath, shower, 2x washbasin, toilet), Bathroom(shower, washbasin, toilet)) patio, garden, garden furniture, BBQ, parking, Cot
- Deposit: € 440 (You will pay in advance, not on site, returned max. 7 days after departure)
- Cleaning: Mandatory: € 150
- Pets: Max. 2; € 15/Pet/Stay
- Bed linen: Required to rent per packet, € 12,50 p.p./Stay
- Bath towels: Included
- Kitchen linen: Included
- Electricity: Included
- Gas/Oil: May - Sep: Included; Oct - Apr: € 50/night
- Tourist tax: No
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subset: commoncrawl


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2002: Suffered a knee injury during three-a-days which held him out the first three games of the season...returned to anchor the offensive line, started every game and was the only true starter from "Spring Drils" to finish the season...member of the fall honor roll.
2001: Played in six games starting the last three...earned a scholarship at season�s end.
2000: Practiced in both the fall and spring...improved greatly in the spring.
High School: Played for Jim Kroll and Joe Mira at Palmetto Senior High School...earned all-county honors...two-sport athlete (football and basketball)...professional goal is to play pro football.
Personal: Criminal Justice major...son of Jamie and Vicki Campos...born February 17, 1981 in Miami, FL.
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Game Week #7, Florida Atlantic at Marshall


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Terra Nova Voyager Ultra 2
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The Tex's House and Interrupt Tex attraction at park opening
After you walk through Tex's house, you'll be funneled into her Secret Silo in the back yard. There you can be ushered into the presence of Tex who has just finished recording a scene from her often seen film, "The Broom's Apprentice". Be sure to ask to borrow her ride!
Ruin everything with Zombie Mode
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A Pants Aflame production


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Gp 3 Tawd vale 2012 Video
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29th May 2012, 09:03 AM
Because I`m AWESIME !!
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Gp 3 Tawd vale 2012 Video
Some Vids from the weekend. Lots of photos, err in the photo thread
Check out your technique against the rest
Casey Jones showing how its done, he is usually hauling Steel and has the nerves to match
another Top display from the Fat Welsh Kid, although if you look closley you can se he is losing Weight and thus shooting better?
Might try that myself?
Best Gurning of the day came from Neil by a "Long" shot
I was going to delete this as he hit them
Sooner he takes up that 10m stuff full time the easier it will be to beat him!
Fred Dibnar appreciation society were out in force
Who better to demonstriahgt how its done but our chair, he asked if he could use a chair but we thaught with knees like those it was better not to.
Last but not least, some bird spotting bloke looking, least, he was dtrying to explain to the Village idiot about air density and kestrols, the only Bird i see at a shoot is the Vulture bloke who follows me round till i Miss!SIZE]
BFTA Grading Q's to;
sorry wont answer Bfta q's on forums, Cant keep track of replies etc!
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Ev2 & x45 comp awaiting a Gary Cane Stock!
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Drawing Techniques
- 3
Quick & Dirty Drawing FAQ
How do I learn to draw? What is symbol drawing? Where can I get commissions? If you are new to art, you can find answers to your questions here.
- 13
How To Use Photo References Without Violating Copyright
19th of 100... getting there! Almost a fifth of the way! Some things are very clear cut. If you steal an image from one of my Hubs or one of my websites such as http://www.explore-oil-pastels-with-robert-sloan.com or...
- 16
Silhouettes or Shadow Portraits for Children
I don't think the established public school system understands the vital importance of encouraging creativity exercises yet. A few simple art projects may go a long way to keeping kids interested.
- 10
Portrait drawing: a simple approach
Portrait drawing is one of those drawing skills many people get into drawing for. It is so appealing and rewarding being able to draw a portrait of a friend, a lover, a kid in a way that makes them happy and you proud...
- 0
The techniques and concept of improvisation in art drawing.
Improvisation in art is expressed in many forms, jazz music, contemporary music, poetry and dance. But you can also find the art of improvisation in drawing and painting. Why and how, I will tell you.
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Basic Manga Drawing 1: Anime Eyes
Eyes are a signature defining aspect of manga drawing technique. Here's a basic, easy to follow guide that will help you with the basics of drawing anime-style eyes.
- 4
Portrait Drawing for the Ultimate Beginner: The Nose
This lesson will help teach beginning artists how to draw the nose at different angles.
- 4
Portrait Drawing for the Ultimate Beginner: The Grid Method
We have now arrived at the very last part of the lesson: The Grid Method. The grid method is used for creating realistic drawings from an image such as a photo or magazine. Now that you have a basic understanding of...
- 0
Portrait Drawing for the Ultimate Beginner: The Face
There are many different shapes of the human face. The standard shape is an oval or ellipse. I often use this shape in examples to simplify drawing the face, but there are many other shapes to consider. Not...
- 1
How To Draw Stars Perfectly (Without Tracing)
Drawing a perfectly symmetrical star can be tricky. Here is a method I discovered on my own that works every time!
Not finding what you're looking for? Browse other articles about Drawing Tutorials.


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Daddy's Love
by Janise Smith
- #5948 in Fiction & Literature, Contemporary Women
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Simone Bradley knows there has to be more to life than heartache. Determined to get past her abandonment and rejection issues caused by her absentee father, Simone leaves everything and everyone behind. She creates her own adventure by moving to another state, changing her name and attitude in attempt to start over. She soon falls back into the same destructive pattern and is forced to change.
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Joe Fox News
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text: Jan Jan is 31 years old male from Sezemice, Czech Republic. He is interested in meet new people. 31, male, Borek Likes: 129x Facebook profile Who s/he liked? Send message Favorite May she/he ask you for a date? Never Maybe Sure Stilettos Hry Ibiza Reggae Tiramisu Barcelona FC Vodka Gladiator Pool The Exorcist Report photo Sign up to see all photos Facebook Twitter Google+ Pinterest Similar users Troy 28, New York online 38 Caribbean Dave 33, Saint Clair 52 Josh 31, Orlando 30 Stevie 34, Ramona 776 Outdoor activities Dan 34, Canfield 205 Cody 28, Mount Pleasant 125 Doug 30, Buffalo 258 Tony 31, The Villages 64 Jonathan 31, Potwin 106


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Hubway bikeshare celebrates its first year of service in Boston and has expanded into Brookline, Somerville and Cambridge.
Hubway's network expansion will deliver over 100 stations between the four communities making it truly a regional healthy transportation option for customers and visitors to the metropolitan area.
MassDOT's financial support for Hubway includes a $3 million Federal Transit Administration livability grant awarded to the MBTA along with nearly $2.5 million in Congestion Mitigation and Air Quality funds allocated to the Clean Air and Mobility Program.
If you have not taken a ride on a Hubway this season, there is still time– simply grab your helmet and a bike for your next trip. It is an easy, healthy and green transit option. More details can be found at http://www.thehubway.com/
MassDOT's partnership with Hubway demonstrates our commitment to providing our customers with mode shift options as part of a healthy transportation network consistent with the objectives of GreenDOT and the Healthy Transportation Compact.
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Video: Toll Plaza Demolition, Reconstruction Shown Step by Step posted on Oct 26
On October 28, I-90 (The Massachusetts Turnpike) will transition to All Electronic Tolling, and MassDOT will begin demolishing the existing toll plazas and reconstructing the roadways. The following is a visualization of what drivers can expect to see as they travel through an existing toll …Continue Reading Video: Toll Plaza Demolition, Reconstruction Shown Step by Step
Cementing the Future of the Braga Bridge posted on Oct 25
When MassDOT undertakes a bridge and highway restoration project, such as the Route 79/Braga Bridge Improvements Project, it aims to make efficient and long-lasting choices of materials. Materials are meticulously evaluated and chosen to ensure lower maintenance costs and an improved service life. For the …Continue Reading Cementing the Future of the Braga Bridge
All Electronic Tolling Activated October 28, Toll Plaza Demolitions Begin This Weekend posted on Oct 24
MassDOT today hosted a news conference and media tour in Weston to inform the public that plans are on schedule to activate All Electronic Tolling (AET) in the state on Friday, October 28, at 10 p.m., and to immediately deploy equipment to begin the process …Continue Reading All Electronic Tolling Activated October 28, Toll Plaza Demolitions Begin This Weekend


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Annai Oru Alayam Trailer (1979)
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Ilayaraja Music
Thiagarajan Director
Dhandayudapani C Producer
India 19 October 1979
These some of the most viewed trailers for movies released in 1979:
28 March 1979
When the local police inspector was found dead in a prostitute's house, police division commissioner Stan Borowitz is sent to investigate the situation.
19 December 1979
An absurd black comedy that cunningly reverses the conventions of the crime thriller to comment on the alienating and dehumanizing effects of contemporary urban life.
15 June 1979
After Rocky goes the distance with champ Apollo Creed, both try to put the fight behind them and move on.
18 December 1979
The explorer craft U.S.S. Palomino is returning to Earth after a fruitless 18-month search for extra-terrestrial life when the crew comes upon a supposedly lost ship, the magnificent U.
14 March 1979
Claude heads to New York upon receiving his draft notice, leaving the family ranch in Oklahoma. He arrives in New York where he is rapidly indoctrinated into the youth subculture before reporting in for boot camp.
16 August 1979
A brilliant parody from the British comedy group Monty Python about the history of (not Jesus but the boy born right next door to The Manger, Brian).
06 December 1979
When a destructive space entity is spotted approaching Earth, Admiral Kirk resumes command of the Starship Enterprise in order to intercept, examine, and hopefully stop it.
21 January 1979
The perversion behind imperial Rome, the epic story of Rome's mad Emporer. All the details of his cruel, bizarre reign are revealed right here: His unholy sexual passion for his sister, his marriage to Rome's most infamous prostitute, his fiendishly inventive means of disposing those who would oppose him, and more.
20 February 1979
The Marriage of Maria Braun is a collage of the times in Germany after the war, economic miracles, and a portrait of a woman who in her circumstances wants to emancipate and have a successful and happy career.
15 December 1979
After a successful robbery leaves famed thief Lupin III and his partner Jigen with nothing but a large amount of fake money, the so called "Goat Bills", he decides to track down the counterfeiter responsible - and steal any other treasures he may find in the Castle of Cagliostro, including the 'damsel in distress' he finds imprisoned there.
09 February 1979
A conservative Midwest businessman ventures into the sordid underworld of pornography in California to look for his runaway teenage daughter who is making porno films in the porno pits of Los Angeles.
17 November 1979
Vampires are invading a small New England town. It's up to a novelist and a young horror fan to save it.
Have you watched Annai Oru Alayam yet? What did you think about it?


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melaney H.
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This trainer will push you to your physical limit! Challenging but so rewarding!! She is WONDERFUL!
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The Fresh Prince of Bel-Air 1990 | TV Show Watchlist
Season 3, Episode 15 Robbing the Banks
First Aired: January 18, 1993
Philip hastily judges an ex-con (M.C. Gainey) who Will urged him to hire. Edward: Phil LaMarr. Philip: James Avery. Will: Will Smith. Hilary: Karyn Parsons. Carlton: Alfonso Ribeiro.
Guest Cast
Tom Virtue Tom Virtue Cop
Phil LaMarr Phil LaMarr Edward
June Christopher June Christopher Luther's Lawyer
Next On TVSee all »
Tue Oct 25 10:00am
The Fresh Prince of Bel-AirVH1I'll Watch59 Watching
Cast & Details See all »
- Premiered: September 10, 1990
- Rating: TV-PG
- Premise: Between early success as a rapper and later on the big screen, Will Smith headlined this hit sitcom about a streetwise Philadelphia youth living with wealthy relatives in L.A. The cultural clashes that inevitably arose resulted in life lessons for all. (more)
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TVGuide.com editors break down theories about what's coming up on The Walking Dead
The Fresh Prince of Bel-Air: The Complete Seasons 1 & 2 (Two Pack)
By Warner Home VideoBuy New: $19.79
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Java NET Leading Product Client Hyd jobs
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Neuvoo India is the largest job aggregator in the country with over 1459955 job vacancies available, 49 of which are Java NET Leading Product Client HYD-related.Show more...
Centraprise IT Solutions Pvt Ltd. |
(Unspecified city), Telangana
- 4d ago
We have immediate openings for the position of Devops Engineer Skill with one of my leading MNC client... Client. Infosys. Location. Pune Hyd. Experience. 6. Years Mode of hire. Contract to Hire. Notice Period...
Truven Health Analytics |
Hyderabad, Telangana
- 2d ago
Truven product development operates within the agile software development methodology. Position... Key Skills. Java, J2EE, Web services, XML, JavaScript, .Net. Location Hyderabad India Full Time Part...
JPMorgan Chase & Co |
Ambavaram, Andhra Pradesh
- 13d ago
Job Description. JPMorgan Chase & Co. (NYSE. JPM) is a leading global financial services firm with... oversee installations and Release Management including the final production acceptance review and...
Tata Consultancy Services Limited |
Hyderabad, Telangana
- 4d ago
Job Description. Location Hyderabad. Experience. 3. 10 Years. Job Role Developer. Skills. AngularJS... Our continued industry leading growth is a testament to the certainty our clients experience every day...
Truven Health Analytics |
Hyderabad, Telangana
- 5d ago
Truven product development operates within the agile software development methodology. Design, develop... Position Requirements. Java Programming (min 5yrs.). C , .NET, ASP.Net Programming (min1yr...
Idexcel |
Hyderabad, Telangana
- 1d ago
Experience leading an R&D or Product Development team would be an added advantage. Convert broad ideas... managing enterprise applications using Java J2EE ASP.Net Web Services. Strong strategic aptitude. proven...
Alp Consulting |
Hyderabad, Telangana
- 4d ago
NET, JavaScript, SQL Server, SharePoint, Web Services. Excellent understanding of 2 tier and 3 tier... clients across India for IT consulting, product development and staffing services. With a PAN India...
Prolim |
Hyderabad, Andhra Pradesh
- 13d ago
Years of experience for Mysore and Hyderabad. location for one of our top clients. About PROLIM... PROLIM is a leading provider of end to end IT, PLM and Engineering Services and Solutions for Global...
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Looncup tracks menstruation and sends vaginal updates to your phone
The "world's first smart menstruation cup" links with a phone app to provide women with information about their periods (+ movie). More
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Japanese studio Nendo has created a perfume bottle for Paris fashion house Kenzo in the shape of a tiny totem pole. More
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We've rebuilt the Mixcloud apps from scratch. Download them for free now!Mixcloud for iOS Mixcloud for Android
Hi ... Ive created this page to host my dj mixes from the past 20+ years... Im hoping to get a bunch more up, but some are on tapes and will take some time. In the meantime, lots of classic jams n vibes here....
Press play to try again.
You can get it here.


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Philips HR1378/00
Showing 1 - 8 of 88 reviews :
Philips HR1378/00
alaTest has collected and analyzed 95 reviews of Philips HR1378. The average rating for this product is 4.3/5, compared to an average rating of 4.1/5 for other Mixers & Blenders for all reviews.
Conclusion : On average, users rate this product 86/100 and experts rate this product 76/100....
Philips HR1378/00
Philips HR1378/00Read more


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Dove is a coming 5 year old she's trained walk, Trot canter, has a great woah and backs up. Is very forward needs experienced rider when being worked in…$2,500
Snaedis from Bonaventure Farm catches your eye with her stunning blue color & graceful movement, then will capture your heart with her wonderful friendly…$3,500
What a gem..Flicka is a very pretty and fancy moving filly.She has a very pretty little typey head and expressive eyes and wonderful upright conformation…$2,000
3yr old paint pony mare. She's got pretty blue eyes. She loves getting all the attention any questions or to see her message me thank you$600
Kembingur is a 5 gaited stallion that sires foals that are natural tolters with correct conformation and movement, excellent temperaments and above average…Stud Fee: $700
Heimdal from Meant To Be is a colt with lots of potential. He is 5 gaited with lots of natural tolt, great conformation & a wonderful temperament. He will…$3,500
Thor from Meant To Be has lots of natural tolt, great conformation & a wonderful attitude. When mature he will make a great riding horse for competition…$3,500
Opportunity to purchase a very well bred, talented young colt. Dyri from Meant To Be - US2013104763 Dyri is by the First Prize stallion, Parker fra…$8,000


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|31 Avaliações
|Tipo de imóvel
|Estadia Mínima
|2 - 4 noites
Estamos localizados em 5155 rota 6 apenas 11. 5 milhas a oeste de Wellsboro PA e com em minutos para o PA Grand Canyon e do outro lado do Pine Creek Outfitters. Venha desfrutar da aventura de caminhadas, pesca, flutuação, passeios, andar de bicicleta, moto de neve, esqui ou se você está aqui apenas para relaxar e desfrutar do vale vista de ter encontrado o lugar.
Há três cabines neste lote. Cabins # 1 & 3 pode dormir 4 (1 quarto de casal e um sofá-cama queen) e cabine # 2 pode dormir 6. (2 quartos queen size e um sofá-cama queen.
Não espere livro agora.
Cabin was in great location, close to everything. Even though located right on Route 6 traffic noise was minimal. Cabin was very clean and had everything we needed. Would definitely stay again. Owner was very responsive and attentive to our needs. Pine Creek trail was so close by made it convenient for our cycling excursions.
The cabins are beautiful on the inside. They are close to many different activities and sites and was the perfect place to stay to access the Pine Creek Rail Trail. Loved our stay and plan to stay here again in a couple of years when we come back to PA again.
Our stay in the cabin was outstanding! Every picture on the website lived up to the accommodations. We felt very much at home the minute we walked in and we would definitely consider staying here again and bringing friends and family next time for a relaxing getaway. Thank you Erika for making our stay a great experience.
Cabin 1 on the Great Valley Cabin Rentals was the perfect location and home base for our 5 day hiking trip. While not everyone in our group was open to camping, this very recently renovated cabin offered the ideal combination of comfort and location. Positioned half a mile from the northern edge of the PA grand canyon it was a light ride every morning to begin a new hike and explore the beautiful region. The interior was very spacious and included all the amenities needed for a long stay. Absolutely recommend this cabin to anyone.
We came up to go star gazing and hiking for my wife's birthday. The cabins are close to great trails, Across the street from pine creek outfitters, and 20 or so minutes from cherry springs astronomy field. Smart tv and ac. New and clean cabin. We will be back
Great location that's so close to all the outdoor activities the county has to offer. Cabin is very stylish and contained everything we needed without having to bring a bunch of stuff from home (towels, toiletries, kitchenware, etc). They had rocking chairs for the front porch, a fire pit area with freshly cut wood for us to use, and much more. Everything was clean inside and out. Indoor furnishings were comfortable. Great for a couple who enjoys the outdoors but wants to come home to air conditioning, wi-fi, and other modern conveniences. It wasn't very large but you definitely didn't feel crowded. Loved every minute of our stay!
PA Grand Canyon, Pine Creek Outfitters, trilhas para caminhada PA Estado terra, trilhas snowmobile PA, caça desportiva. Jantar inclui Log Cabin Inn, Old Antlers Inn, Padaria da Baxter, Brickhouse, Wellsboro House.
|Validade da Tarifa
|por noite
|Noite (fim de semana)
|por semana
|por mês
|Pacote ou Evento
Winter 2016-2017
dez 5 2016 - mar 31 2017
Estadia mínima: 4 noite(s)
Tarifa Básica
Estadia mínima: 2 noite(s)
check out our other listings - # 3586030,3811751,3811747.
6 months or more prior to stay - all monies will be refunded.
1 to 6 months prior to stay - the security deposit is non refundable unless we are able to find a replacement for your full leasing period. All other monies will be refunded.
LESS than 30 days prior to stay - the amount received is non refundable unless we are able to find a replacement for your full leasing period.
SECURITY DEPOSITS.. refunds will be issued within 15 days of departure date.


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Low cost moving tips for moving into a dorm room or campus apartment. Find out how university and college students can save money on a move.
Students Moving
Self storage facilities and portable containers have restrictions on what can be stored. The following article will give you a general idea of what you are not supposed to keep in storage unit.
What You Are Not Allowed to Store
Small details make a big difference when it comes to planning a move. One thing that should guarantee a smooth experience is to provide movers with as much as information as possible, even if it seems unnecessary.
What You Should Tell Your Movers
Moving day is here and there's still so much to do. The following article provides tips for the big day, and what to do to make it go as smoothly as possible.
Moving Day Checklist
You load we drive is another do it yourself moving option. Transportation company delivers a container or trailer and you do the actual labor; loading and unloading your possessions.
You Load We Drive Service
Moving companies in Tuleta, Texas - Local Movers


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Wellfleet Roof Replacement Contractors
There are lots of different reasons that you should take full advantage of roof replacement for Wellfleet, MA homes, including the fact that doing so will ensure that you and everyone else in your household stays safe. An old roof with lots of damage to it could collapse at any moment, which is why it's so important for you to consider getting yours replaced altogether. These Wellfleet roof replacement services will ultimately save you a lot of stress and expense later on, and it's crucial that you hire professionals for the job instead of trying to do it yourself.
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You will find that quality Wellfleet roof replacement services will ensure that you won't have to worry about paying to get this work done for a long time if ever. These professionals will be able to install any type of roofing you want, so it is therefore important that you take the time to explore some of your options before making a final decision. The type of roof that you have put on will determine how long it lasts. Another great benefit of Wellfleet roof replacement services is that your home will be much more energy-efficient, which means that you will be able to start saving money on your monthly energy bills.
Pleasant Bay Roofing & Siding227 Clayhall Rd South Orleans, MA 02653
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All Roofing & Contracting, Inc.25 Kerry Lane Eastham, MA 02642
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Emerson Home Improvement Inc134 Rock Harbor Rd Orleans, MA 02653


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Begu Sarai 6th October 2015 Written Episode
Scene 1
Poonam says to dadda that i will make breakfast for you, he says yes, Bindya says i will make breakfast for him today, he should give chance to other daughter in laws too to show how well mannered are they, Dadda says ok go and make it, but not for me, make it for whole house including servants while my Poonam beta will make breakfast for me, Poonam nods and leaves, bindya starts leaving, Dadda says kitchen is on otherside, Bindya goes out and thinks that this old man doesnt given any chance to me, i am not interested to make breakfast for him, i just wanted reason to go to kitchen to mix bhaang in Poonam's food.
Poonam comes in her room with breakfast, Lakhan is combing his hairs, she comes to him and ask how is your feet now? Lakhan says i dont need tea or breakfast, i am not hungry, Poonam says why you are punishing your hunger because of me? she shouts and says rat, Lakhan gets afraid and ask where is it? he is tensed, Poonam laughs seeing his fearful face, Lakhan understand that she was pulling his leg, he says are you making fun of me? Poonam says no i was just saying.. Lakhan says do you know consequences of troubling a sleeping lion? he raises his hand, Poonam thinks he is going to hurt her and closes her eyes, Lakhan caresses her face with hand, she is surprised, he says keep laughing, you look good when you smile but not smile infront of others, this smiling is only.. Poonam says this is only for you, they share eyelock, he ask her to go, she starts leaving but turns to him and smiles, Soni and Pinto comes to Poonam and ask why are you staring him? Poonam says you dont have any other work? go and study, they say we have done our work, Poonam says to Soni that we will give bath to Pinti as he is dirty, she ask Maya can i give bath to Pinto? Maya says why are you asking, sure you can, they leave.
Rekha and Bindya are working in kitchen, Choti Amma is there too, Bindya ask Rekha to send Choti Amma out.
Poonam takes Pinto to give bath to him from handpump but he says water is cold, i will not take bath, he runs, Poonam runs behind him, Lakhan comes there, Pinto gets afraid seeing him and says i will take bath, he hides behind Poonam and says he is bad Chacha, he will beat me, Lakhan starts leaving, Poonam says to Lakhan that i am giving bath to kids for first time, help me, Lakhan says no, Poonam is tensed.
Scene 2
Choti Amma says to Rekha that Poonam have already made breakfast what are you doing here? Rekha says then why are you here? lets sit and talk, Choti Amma says there are many other works too in kitchen, she doesnt leave, Bindya points Rekha to force to leave, Rekha again comes to Choti Amma and says Dadda has come after many years, we should go and ask him if need anything, Choti Amma says good idea, you go and ask him, Rekha says i think i should take breakfast for him too, Choti Amma gives breakfast tray to her and ask her to leave, Rekha says alone? Choti Amma says yes.
Lakhan says to Poonam that i am leaving for some important work, Poonam says go after sometime, please.. Lakhan stops, he comes to her.
Rekha starts leaving kitchen, she screams and says my hand is hurt, i cant take whole tray, Choti Amma takes tray from her and leaves to give it to Dadda.
Bindya starts mixing bhaang in chutni, Maya sees her and thinks what she is mixing?
Lakhan fetches water from hand pump while Poonam gives bath to Pinto, Pinto throws water at Lakhan in fun, Lakhan stares him, Pinto gets afraid, Poonam thinks if Lakhan gets angry on kids then my trick will fail, Lakhan sit down, he looks at Pinto and starts throwing water on him, kids starts playing with him, Poonam keep looking at him, Laakh Rooka dil ko.. tere mere bas main kiya hai.. Yunhi re Yunhi re plays.. Lakhan throws water at Poonam too, she starts leaving but he holds her hand, both share long eyelock, Lakhan removes saree pallu which Poonam tucked in while sitting down, he leaves her hand, Poonam is shy and glances at him as Yunhi re plays.
Mitlaish says to Bhushan and Priyom that i am going to talk to Dadda about Phulan's case, you both come with me, they leave. Choti Amma bring Badi Amma to dinner table, Rekha brings bhaang mixed food for Poonam and ask her to eat it, Poonam smiles, Maya tries to tell Poonam about food, Maya says to Rekha that you should eat first before Poonam, you and Bindya should eat first then Poonam and i will eat, she points Poonam that there is something in food, Poonam understands it, Rekha says no i cant eat from this plate.. i mean i have already started to eat in other plate, Choti Amma ask Bindya to have food too, Bindya sits, Poonam says you take my plate i will take another, Bindya stares her angrily.
PRECAP- Poonam is inebriated due to bhaang, she is standing on bed, Lakhan ask what are you doing? are you inebriated? you will fall from bed and will get hurt, Poonam says you should not hurt the one whom you love because we get hurt too seeing them in pain, Lakhan thinks.


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Deploying a Geospatial Cloud
- Alban Tyler
- 1 years ago
- Views:
1 Deploying a Geospatial Cloud
2 Traditional Public Sector Computing Environment Traditional Computing Infrastructure Silos of dedicated hardware and software Single application per silo Expensive to size for peak load Difficult to scale Expensive to manage
3 NIST Definition of Cloud Computing Cloud computing is a model for enabling convenient, on-demand network access to a shared pool of configurable computing resources (e.g., networks, servers, storage, applications, and services) that can be rapidly provider provisioned interaction. and released with minimal management effort or service provider interaction. Cloud computing is a model for enabling convenient, ondemand network access to a shared pool of configurable computing resources (e.g., networks, servers, storage, applications, and services) that can be rapidly provisioned and released with minimal management effort or service This cloud model promotes availability and is composed of: This cloud 5 Essential model Characteristics promotes availability 3 Service and Models is On-demand self-service SaaS composed Resource of: pooling PaaS Rapid elasticity Measured service Broad network access IaaS 4 Deployment Models Public Cloud Private Cloud Community Cloud Hybrid Cloud Source: NIST Definition of Cloud Computing v15
4 Public Clouds and Private Clouds Public Clouds Private Cloud Used by multiple tenants on a shared basis Hosted and managed by cloud service provider SaaS PaaS IaaS I N T E R N E T I N T R A N E T Apps SaaS PaaS IaaS Exclusively used by a single organization Controlled and managed by in-house IT Trade-offs Lower upfront costs Lower total costs Outsourced management Greater control over security, compliance, QoS OpEx CapEx & OpEx Enterprises will adopt a mix of public and private clouds
5 Why a Cloud Framework Make Sense Reduced Cost Cloud technology is paid incrementally, saving organizations money. Increased Storage Organizations can store more data than on siloed computer systems. Flexibility Cloud computing offers much more flexibility than past computing methods. More Mobility Employees can access information wherever they are, rather than having to remain at their desks. Highly Automated, Allows IT to Shift Focus No longer do IT personnel need to worry about keeping software up to date No longer having to worry about constant server updates and other computing issues, government organizations will be free to concentrate on innovation.
6 3 Cloud Computing Concepts Application as a Service End user apps delivered as service Example: Google Earth Platform as a Service Application platform middleware for developers to develop and deploy custom apps Example: Oracle Public Cloud Infrastructure as a Service Hardware and technology for computing power, storage, operating systems available for customer apps Example: Amazon EC2, Amazon S3, Oracle Public Cloud
8 Characteristics of Cloud Frameworks Cloud Computing Infrastructure Multi-tenanancy Rapid provisioning Add Resources in Real TIme Elasticity Terabytes, Petabytes Automated QoS Pay-for-use pricing Can be deployed in a physical or virtual environment
9 Cloud Platform Framework for GIS GIS Apps Enterprise Apps Test Dev Cloud Foundation Application Server: SOA, Identity Management, OGC Web Services, Geocoding, Routing, Java and XML Frameworks, Process Execution, Portals; Java, XML, C, and.net APIs Spatial Database:ISO/OGC-compliant. Native Raster, 3D/LiDAR, Planar and Network Topology. Coordinate Transformation, Spatial indexes, functions, and operators. Massively parallel, highly available and scalable processors and storage
10 Moving Toward Simplified Pricing Models Simple monthly based subscription Multiple tiers with growth option Elastic consumption model grow and shrink as needed
11 Some Cloud Security Concerns: Data Storage Data Transfer Data Privacy Identify Management Vulnerability Management Application Security Personnel and Physical Security Liability and Recourse
12 A Cloud is More than Just Technology Shared Infrastructure Common Geospatial Data, Services, and Applications Governance Structure Policy and Operations Geospatial Information Portfolio Management (Data agreements, licensing)
13 Linking with other Services and Clouds
14 Leveraging Semantic Web Application Ontologies National Mapping Private Cloud RDF & OWL Metadata Environmental Monitoring Spatial Data Geographic Names Raster Data Famine Relief Simple Features GeoRaster Topology Networks Gazeteers Data Integration National Map schemas Geographic names Temporal Naïve Geography Disaster Response
15 It s Not Just about Linking Integrate domains of knowledge through common vocabularies (ie SKOS) Semantic Aggregation & Navigation of Data Manage relationships between collections of images and associated metadata RDF as flexible and extensible data model supports powerful search and end-user discovery of related content Rich platform for data integration, data repurposing, and better quality control and classification
16 Best Practices for Cloud Deployment
17 Best Practices 1* Licensing: Ensure you use use cases are covered Consider service spikes, high availability, etc. Data Transfer Costs: Understand internal and external traffic costs of your overall service When possible, make sure data transfer costs are internal to the cloud provider Latency: Understand latency requirements of your app Clouds are not ideal for low-latency operations * Source: Jim Liddle, WebSphere Journal, Sept. 29, 2009
18 Best Practices 2 State Check if your cloud provider persists data Ex: Amazon EC2 persistent storage, Oracle do How will back-ups be initiated in system crash? Data Regulations Data in the cloud may be breaching national data laws depending where your data is stored Some providers allow you to specify where in the world to store data
19 Best Practices 3 Compliance National regulations may prevent some apps from being hosted on cloud (eg. Patriot Act) National Compliance may even extend to the software/hardware components used by cloud provider and its partners Quality of Service QoS encompasses scaling, reliability, service fluidity, monitoring, management and system performance Ensure that monitoring tools are in place to track compliance with service level agreements
20 Best Practices 4 Security Understand security policy and technologies Topics include: encryption, authentication, authorization, intrusion detection, etc. System Hardening Ensure system is secure, robust, and achieves the necessary functional requirements Dependencies Check dependencies of your service provider If cloud provider A is dependent on service B, what happens if service B is disrupted?
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This is what i wore yesterday for my eye of the day! Me and my sister went to manila. As i mentioned on my earlier post my two palettes arrived yesterday morning,i am very much excited to try the sleek palette so that`s what i used to create this look hehe:)Since it`s day time i wanted to create a very wearable look and this is what i came up with!
Products used:
Elf eyelid primer
maybelline falsies mascara
missha eye brightener
maybelline dream matte powder
skinfood brow powder cake
maybelline lasting drama gel liner
revlin matte white kohl pencil eyeliner
sleek " storm palette "
*photo belongs to me*
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