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Why dont they make leaders like this anymore?
Sounds like a man any nation would be proud of.
Determined to create what he called a "Square Deal" between business and labor, Roosevelt pushed several pieces of progressive legislation through Congress.
During his tenure as President, Roosevelt became known as the leader of Progressivism in the United States, trust-busting and his enthusiastic conservationist policies.Progressivism in the United States was the most powerful political force of the day, and in the first dozen years of the century Roosevelt was its most articulate spokesman. Progressivism meant expertise, and the use of science, engineering, technology and the new social sciences to identify the nation's problems, and identify ways to eliminate waste and inefficiency and to promote modernization. Roosevelt, trained as a biologist, identified himself and his programs with the mystique of science. The other side of Progressivism was a burning hatred of corruption and a fear of powerful and dangerous forces, such as political machines, labor unions and especially the new large corporations called "trusts" which seemed to have emerged overnight. Roosevelt, the former deputy sheriff on the Dakota frontier, and police commissioner of New York City, knew evil when he saw it and was dedicated to destroying it. Roosevelt's moralistic determination set the tone of national politics.Roosevelt was also interested in conserving natural wonders and resources, and is considered by many to be the nation's first conservation President. He encouraged the Newlands Reclamation Act of 1902 to promote federal construction of dams to irrigate small farms and placed 230 million acres (930,000 km²) under federal protection. Roosevelt set aside more Federal land for national parks and nature preserves than all of his predecessors combined. As one story has it, he once asked his advisors, "Is there any law which prohibits me from declaring this island a bird refuge?" When they indicated there was not, Roosevelt signed the paper with a flourish and said, "Very well, then, I so declare it!"
During his presidency, Roosevelt established the United States Forest Service, signed into law the creation of five National Parks, and signed the 1906 Antiquities Act, under which he proclaimed 18 new national monuments. He also established the first 51 Bird Reserves, four Game Preserves, and 150 National Forests. The area of the United States that he placed under public protection totals approximately 230,000,000 acres (930,000 km²).
Today, Roosevelt's dedication to conservation is remembered by a national park that bears his name in the North Dakota Badlands. Theodore Roosevelt National Park is home to a variety of plants and animals, including bison, prairie dogs, and elk.
Roosevelt relished the Presidency and seemed to be everywhere at once. He took Cabinet members and friends on long, fast-paced hikes, boxed in the state rooms of the White House, romped with his children, and read voraciously. He was permanently blinded in one eye during one of his boxing bouts. In 1904 Roosevelt ran for President in his own right and won in a landslide victory.
Roosevelt was an activist during his years in the Assembly, writing more bills than any other New York state legislator. Already a major player in state politics, in 1884, he attended the Republican National Convention and fought alongside the Mugwump reformers who opposed the Stalwarts; they lost to the conservative faction that nominated James G. Blaine. Refusing to join other Mugwumps in supporting Grover Cleveland, the Democratic nominee, he stayed loyal to the party and supported Blaine.
His wife and mother died on the same day earlier that year, and in the same house, only two days after his wife gave birth to their only daughter, Alice. Roosevelt was distraught, writing in his diary, "the light has gone out of my life forever." Later that year, he left the General Assembly and moved to the Badlands of the Dakotas for the life of a rancher and lawman.
Living near the boomtown of Medora, North Dakota, Roosevelt learned to ride and rope, and occasionally got himself into fistfights, spending his time with the rough-and-tumble world of the final days of the American Old West. On one occasion, he hunted down notorious outlaws on the Little Missouri River, heading into the uninhabited Badlands.
After a blizzard wiped out Roosevelt's herd of cattle, and his $60,000 investment, he returned to the Eastern United States, where in 1885, he purchased Sagamore Hill in Oyster Bay, New York. It would be his home and estate until his death. Roosevelt ran as the Republlican candidater for mayor of New York City in 1886, coming in a distant third. Following the election, he went to London and married his childhood sweetheart, Edith Kermit Carow. They honeymooned in Europe, and Roosevelt took the time to climb Mount Blanc, leading only the third expedition to successfully reach the top. Roosevelt is the only President to have become a widower and remarry before becoming President.
In the 1880s he gained recognition as a serious historian. Roosevelt's The Naval War of 1812 (1882) was the standard history for two generations, but his hasty biographies of Thomas Hart Benton (1887) and Gouverneur Morris (1888) were pot boilers. His major achievement was a four-volume history of the frontier, The Winning of the West, (1889-1896) had a notable impact on historiography as it presented a highly original version of the frontier thesis developed in 1893 by his friend Frederick Jackson Turner. His many articles in upscale magazines provided a much needed income, as well as cementing a reputation as a major national intellectual. He was later elected president of the American Historical Association.
what happenend to men like this did they all get washed down the drain
12-02-2005, 09:40 AM #3Originally Posted by amstaf
12-02-2005, 09:41 AM #4Originally Posted by johan
I believe that we have good people now, it's just that if you ever do anything that the press can get it's hands on and use against you, they will play it to the hilt and that will be all that the public hears.
12-02-2005, 09:44 AM #5Originally Posted by Bigen12
todays media sucks majorly. Its gotten out of hand.
Im more worried about people that have a totaly clean past because that is fishy as hell.
Roosevelt.... you have got to be kidding me.. How about he created the Social Security Commission.. they could recieve retirement benefits at age 62.. the average age to death at the time.. 56 yrs old... He raped the american people then.. and is still raping us..The answer to your every question
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Why the Police will Kick your ass
12-02-2005, 09:49 AM #7Originally Posted by spywizard
I thought that was FDR not teddy? Not that I know much about american presidents. But what I read on wikipedia about his character, struggle against corruption ect sure sounds good.
12-02-2005, 09:56 AM #8Originally Posted by spywizard
12-02-2005, 02:22 PM #9Originally Posted by johan
Stories change throughout time. Different verions get brought up everytime they are told. It's like the Alexander the Great. One of the greatest Kings of time. Well most of the crap they say about him isnt true. One mans story always changes when its said through other peoples mouths. Though Teddy was a very good President he also had his faults. And now a days, when there ever is a great person that has something to say and tires to change the world for the better its his peers that keep them from that.
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Everyone wants to hire top performers, but how do you know one when you see one?
It's not an easy question. Unless you are constantly hiring for the exact same position, you cannot possibly know who the current top performers are in your job market, what skills actually drive their results, or what their compensation should be. You certainly won't know whether any of them would consider working for you.
At the beginning of a search, hiring managers can put themselves in a position to learn from the job market, but cannot presume to already understand the job market. Yet, most recruiting processes are based on the assumption that the hiring manager is a job market expert. The manager will say, "I have this mental picture of my ideal candidate; now go recruit them." And, of course, that ideal candidate may or may not actually exist. Two of the most common definitions of "top performer" both suffer from the same kind of faulty logic:
- Some hiring managers define top performers by their resumes (e.g., "Candidates will have a successful background in …"). Unfortunately, most managers can only conceive of a few paths to job competency; we're all prisoners of our own experience. Yet, economic forces constantly reshape career options, creating career paths that these managers could not begin to conceive of. Managers who rely on a "career path like mine" approach unwittingly rule out large numbers of qualified people based on outdated assumptions.
- Some hiring managers define top performers as the most successful people working for their most successful competitors. But there's no guarantee that these people will perform equally well in your work environment. "Top performer" is not a hard skill people bring with them to a new job, like being bilingual or knowing how to program software. Managers who rely on the "proven ability" approach forget that individual performance always depends on the work environment.
Job markets are in constant flux. Unemployment rates mirror the rise and fall of companies and industries. Companies prosper for a while, but eventually lose their luster when new competitors burst on the scene and become the hot place to work. Job descriptions evolve to fit business needs, and job skills can go from unknown to red-hot to passé in just a few years' time.
Top performers constantly rearrange themselves within job markets. They do not share a uniform set of attributes, want the same things, thrive in the same work environments, or read the same job postings. Just because you hired someone great 5 years ago does not mean you will attract someone equally successful now. The skills that led to success in a job 5 years ago may be completely irrelevant today. As Heraclitus said 2,500 years ago, "No man ever steps in the same river twice, for it's not the same river and he's not the same man."
To thrive, your organization must select the best available people from within your job market, so in hiring, you are always "grading on a curve." Someone can only be a top performer in relation to their current peer group–the other people who currently work on similar issues, at a similar scale, and in a similar work environment.
If you want to improve your hiring results, organize your recruiting efforts around this definition of top performer:
A top performer is someone who is demonstrably better than their peers at achieving the kinds of business results you require, while working in an environment similar to your own.
Candidate behavior has changed – and HR practices for many organizations are still stuck in 1999. Attract more top performers by watching "Candidate and Employee Behavior Changed: How to Catch Up" to learn:
- How to save money on job postings and quadruple your recruiting results
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Results in AMD E-Series Laptops & Notebooks
1-14 of 14
ACER Notebook E1-522 AMD Dual-Core 1.4GHz 4GB 500GB DVD Win8 15.6" HD RadeonThe Acer Aspire E1-522 series laptop showcases a compact 15.6" display with AMD®'s Radeon™ HD shared graphics that opens the door to some casual gaming –so it's not all just about work! Acer's Aspire laptop comes with a 500GB hard drive giving you stable storage space for important data content.eBay Premium ServicesAU $299.00Free postageEst. delivery Tue. Nov. 1
Asus K53U Laptop Dual Core 1.6Ghz 15.6" LED 4GB ram 320GB HDD Wifi Webcam Win 7Asus K53U Laptop in good condition and working well. AMD Dual core E-350 1.6Ghz processor. 320Gb hdd. 4Gb ram. 15.6" LED screen.AU $179.00Est. delivery Wed. Nov. 2Free postage
Toshiba Satellite C665D Laptop: 500GB: Black: Win 7: LAPTOP ONLY w/ SLIGHT FAULTFAULT: The slight fault with this item being that the 'Z' and '?. /' buttons do NOT work. We do not have the expertise to specify why this is and we are unable to fix the issue. There are a few small, slight scuffs along the edges of the laptop from general use.AU $194.99Est. delivery Thu. Nov. 3Was: Previous priceAU $299.99Free postage
Dell Inspiron M102z AMD E-450 1.65Gh 4GB 320GB Webcam Win 7 11.6" B GRADEDell Computers. Dell Celeron Computers. Dell Inspiron M102z 11.6" Netbook - More fun on the run. Dell Celeron Full Systems. Get more done and have more fun, at home or on the go, with the Inspiron M102z.AU $105.00AU $26.50 postage
ACER ASPIRE E 15 AMD QUAD CORE LAPTOPACER ASPIRE E 15 LAPTOP. AMD QUAD CORE E2-6110 1.50GHZ. AMD RADEON R2 GRAPHICS 768MB. LAPTOP IN VERY GOOD CONDITION, SMALL NICK ON SCREEN. BATTERY LIFE CURRENTLY 4.40 HOURS AT 78%, LONG LIFE BATTERY. DVD DRIVE.AU $249.00AU $35.00 postage
HP Pavilion dm1 Notebook PCWe have two practically identical units. Both include HP carry bag as per photo. No longer used since the kids got a school issued laptop. Wi-Fi 802.11 b/g/n. Dimensions(WxDxH) 29.2 x 21.5 x 3.2 cm.AU $100.000 bidsAU $20.00 postageEnding Tuesday at 10:44 AEDST1d 1h
HP 15 Laptop: HP15-af022AU: 15.6": 500GB: Silver: Windows 8.1 + Bundled ChargerIncludes: 1x HP15 Laptop and 1x Bundled Charger. Condition of item: Used, but is still in good working condition. There are some scratches to the body of the laptop, including a few deep scratches/staining to one of the corners.AU $292.49Est. delivery Thu. Nov. 3Was: Previous priceAU $449.99Free postage
New HP Laptop 15-G040AU J6L81PA DUAL-CORE E1-6010 500G 2G 15.6 DVDRW Win 10 HPUPC: 888793304754. Cat No.: XC0257 Processor Speed: (1.35GHz). Model No.: 15-g040AU Optical Drive: SuperMulti DVD burner.AU $390.00AU $20.00 postage
ASUS X401U-WX017H 14" 2GB-RAM 320GB Including free Windows 10 upgradeIncluding free Windows 10 upgrade. AMD® Brazos 2.0 Platform Processor. 320GB 5400RPM. 1 x Microphone-in jack. 1 x Headphone-out jack. 1 x Line-in Jack. 1 x RJ45 LAN Jack for LAN insert. 19 V DC, 3.42 A, 65 W.AU $350.00AU $25.00 postage
ASUS F452E Laptop 14.5"AMD DUAL CORE 1.0 GHz 240Gb SSD 6Gb Ram Windows 8 USB 3.0AU $199.000 bidsEnding 2 Nov at 12:14 AEDST9d 2h
Toshiba C850D Laptop E1 4GB 320GB Windows 10Windows 10. 4GB Ram. 320GB HDD. Phone: 02 43967664.AU $215.00AU $13.50 postage
Toshiba Satellite C665D Laptop: 500GB: BlackL aptop plus charger.AU $170.00
FAULTY Compaq CQ43 Laptop: CQ43-102AU: 320GB: 14": Windows 7 + Bundled ChargerIncludes: 1x FAULTY Compaq CQ43 Laptop Bundled Charger. Condition of item: FAULTY. There are various scratches to the laptop of varying lengths and depths. They have also resulted in the paint coming off - particularly to the lid - refer to the photos.AU $239.99Est. delivery Thu. Nov. 3Free postage
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We found 1,712 'kittens' adverts for you in 'cats and kittens', in Bournemouth
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Gorgeous family home reared stunning Oriental kittens.Havana (chocolate) & Lilac,Reared with children,dogs & other cats. Both parents can be seen and have loving affectionate temperaments.
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Hi, we are looking for a kitten who will be ready to leave mum at the end of October.
We will consider any colour, but my sons are adament not all black.
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11 weeks old.
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These Lovely natured kittens are now 10 weeks old and are allround playful and active. available are 3 british sort hair kittens, all black in colour and include 1 queen...
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I have a female cat, 2 years old for sale. She is quite friendly, and very good with other animals. Her name is Psyche, but this can be changed. She is an outdoor cat, but would be suitable as an indoor...
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Stunning F3 male begal boy available as an amazing, fun pet. Extremely confident and friendly this boy needs to move to a home of his own where he can become part of a family.
He's used to young children...
You are currently on search results page 1 of 86


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Number 521 is a blend of the attributes and energies of number 5 and number 2, and the vibrations of number 1. Number 5 resonates with the attributes of making positive life choices and important changes, adaptability and versatility, resourcefulness, motivation and idealism. Number 5 also relates to doing things your own way. Number 2 brings it energies of balance and harmony, duality and diplomacy, devotion, duty and service, adaptability and co-operation. Number 2 also relates to faith and trust and your Divine life purpose and soul mission. Number 1 encourages us to strive forward with courage and tells us that we create our realities with our thoughts, beliefs and actions. Number 1 also resonates with beginning new projects or ventures, inner-strength and tenacity, creation and activity, attainment and success.
Angel Number 521 brings a message to keep your faith and trust strong, and expect the very best in your life. Maintaining a positive attitude and an optimistic outlook will manifest auspicious circumstances and opportunities in your life. You are encouraged to elevate your thoughts, ideals and expectations as this will manifest and create wonderful new opportunities and experiences in your life. Expect the best, and you will receive it.
Angel Number 521 is a message from your angels that the life changes you are contemplating or experiencing are for your highest good and will be of long-term benefit to you. These changes are positive and in-line with your Divine life path and purpose. Trust that your angels are with you and are available for guidance and assistance anytime you ask.
Check how you truly feel about situations or circumstances in your life and use them as a guide to your next steps. If things feel right, then they are right. But, if things feel uncomfortable to you, change the situation. Doubt = Don't.
Number 521 relates to number 8 (5+2+1=8) and Angel Number 8.
Sacred Scribes
NUMEROLOGY - The Vibration and Energy of Numbers
ANGEL NUMBERS - A Guide to Repeating Number Sequences and their Messages and Meanings. You are most welcome to share these Angel Number messages with others, although I do request that you include this website address, credit your source/page links and author. All postings by Joanne Walmsley - Sacred Scribes may be used for personal, not-for-profit purposes only. firstname.lastname@example.com Joanne Walmsley Sacred Scribes Australia
Monday, September 19, 2011
Posted by Joanne Sacred Scribes at 9:15 AM
Labels: 521, 521 angel number, angel number 521, angel numbers, meaning of repeating number 521, number 521 meaning, sacred scribes, seeing 521, spirit numbers, spiritual meaning of 521, what does 521 mean
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Christian Redeemer School
151 SW 87th Pl., Ocala, FL 34476
(352) 854-2999
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151 SW 87th Pl.
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(352) 854-2999
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According to our records, this business is located at 151 SW 87th Pl. in Ocala (in Marion County), Florida 34476, the location GPS coordinates are: 29.097365 (latitude), -82.138424 (longitude). Christian Redeemer School is categorized under Elementary And Secondary Schools (SIC code 8211). Known organization principal is Melissa Law. You can contact the company by phone at (352) 854-2999.
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Food + Drink Mum
Move over Michel Roux Jr, we've got our very own Masterchef who is on hand to bring you everything from low-cost and low-cal food ideas to mouth-watering recipes and meals in minutes. Bon Appetit!
BBC Good Food American Recipes
As it's Independence Day in the US, we thought we'd put together a couple of our favourite American recipes from the BBC Good Food website. We hope you like them!
Why not try a twist on American-style marshmallow and chocolate s'mores by swapping the traditional crackers for malted biscuits?
Malt Hot Chocolate S'mores
• 16 malted milk biscuits
• 8 squares of milk chocolate
• 8 marshmallows
1. Preheat the grill to high and line a large baking sheet with parchment. Put all 16 malted milks on the tray with a square of milk chocolate on 8 and a marshmallow on the remaining 8. Grill until both are melting.
2. Sandwich the two different types on top of each other until oozing at the edges and eat white, hot or dunked in a hot chocolate for extra chocolatey flavour!
Maple-glazed Hot Dogs with Mustardy Onions
• 8 good quality sausages
• 2 tbsp. sunflower oil
• 2 onions, thinly sliced
• 1tsp yellow or black mustard seeds
• 2 tbsp. maple syrup
• 4 part baked mini baguettes (or cut a French stick into 4 pieces)
• 1tbsp Dijon mustard
• Large pinch of brown muscovado sugar
• 2 tsp wine or cider vinegar
1. Heat the oven to 200/180C fan/gas 6. Place the sausages on a non-stick baking tray and roast for 20 mins. Meanwhile, heat the oil in a frying pan and cook the onions and mustard seeds together for 10-15 minutes until soft and golden.
2. Remove the sausages and brush with maple syrup. Pop the baguettes onto the same baking tray. Increase the oven to 220/200C fan/gas 7 and return the tray for 5-8 minutes until the sausages are dark, shiny and cooked all the way through. Stir the mustard, sugar and vinegar into the onions until the sugar has melted.
3. Cut the baguettes open across the top and put 2 sausages into each. Spoon over the mustardy onions and serve.


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Short Stories with a Twist Ending
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Visit Short Story Guide to find a story by subject or theme.
Twist endings aren't to everybody's taste; they might seem contrived, superficial, or too commercial for a serious reader. An "epiphany" ending might be more resonant, but it's hard to beat a twist ending for pure entertainment value, and when a surprise ending is done really well it's as satisfying a reading experience as any other kind of story.
These are great stories for learning or teaching careful reading. Sometimes the author tries to give the reader a fair chance to figure out what's going to happen.
Even though a twist ending is supposed to give the reader a jolt, in hindsight it should seem perfectly reasonable. The best ones seem inevitable and seamless.
Here are some great short stories with surprise endings. The endings aren't revealed here, only the set-ups.
The Interlopers | Saki
Two feuding family heads get trapped in the woods, giving them time to discuss their situation.
Twin Study | Stacey Richter
A woman attends a study of identical twins where she sees her sister, whom she hasn't seen since the last study, four years ago. She struggles with her identity, comparing her life and traits to her sister's.
The Open Window | Saki
A young girl tells a story of family tragedy to a visitor.
Two Thanksgiving Day Gentlemen | O.Henry
An elderly gentleman has treated a local indigent man to a hearty Thanksgiving Day meal for the past nine years. The poor man shows up to their meeting place in a condition that threatens to ruin the gentleman's tradition.
An Occurrence at Owl Creek Bridge | Ambrose Bierce
A Confederate sympathizer is condemned to hang from Owl Creek Bridge during the American civil war.
The Lottery | Shirley Jackson
A small town prepares for its annual ritual–a lottery–that is supposed to ensure a good harvest.
The Necklace | Guy de Maupassant
A woman borrows an expensive necklace from a friend, but she loses it and works to set things right.
The Last Leaf | O.Henry
A woman with pneumonia can see an ivy vine through her sickbed window. She counts down the leaves as they fall and tells her roommate that when the last one falls, the pneumonia will kill her.
Wish You Were Here | Frank Jones
A woman's garden gnome is stolen; she begins receiving postcards that are signed by the gnome.
Roman Fever | Edith Wharton
Two middle aged women visit Rome with their unmarried daughters. In their youths, the women were romantic rivals. The women talk about their lives and daughters.
A Retrieved Reformation | O.Henry
A reformed safecracker faces a problem that could reveal his culpability in several robberies.
Man From the South | Roald Dahl
An elderly man bets a young man that he can't light his lighter ten times in a row. If it fails to light on any of the ten attempts, the young man loses the pinky finger of his left hand; if all ten attempts are successful, the young man wins a Cadillac.
The Lame Shall Enter First | Flannery O'Connor
A young son mourns the loss of his mother, while his unsympathetic father is preoccupied with helping other people. The father invites a young delinquent into their home, who resists his efforts to help.
Barney | Will Stanton
A scientist on a deserted island tries to increase the intelligence of Barney, a rat.
A Continuity of Parks | Julio Cortazar
After a day of activity, a man reads a novel; he progressively becomes more immersed in the story.
Good Country People | Flannery O'Connor
Mrs. Hopewell runs a farm with her tenants and her daughter, a thirty-two year old with a prosthetic leg. A Bible salesman visits the farm and is invited to stay for dinner.
The Story of an Hour | Kate Chopin
A woman gets the news that her husband has been killed in a railroad accident. Over the next hour, she experiences a range of emotions.
Reunion | Arthur C.Clarke
Earth receives a transmission from an approaching alien ship. It says the aliens had originally colonized earth millions of years ago, before a non-fatal disease split the population. The returning aliens now have a cure for any who are still infected.
The Reticence of Lady Anne | Saki
A man tries to smooth things over with his wife whom he had argued with earlier, but she doesn't respond to his efforts.
A Horseman in the Sky | Ambrose Bierce
During the American Civil War, a Federal sentry falls asleep at his post, but wakes in time to see a Confederate scout whose report could be deadly.
This story is a combination of parts that are very clear and parts that require more careful attention to figure out what's going on.
Taste | Roald Dahl
A dinner host and a wine expert make a bet. If the expert can identify the wine being served, he gets to marry the host's daughter; if he can't, he forfeits both his houses.
Charles | Shirley Jackson
A boy who just started kindergarten, Laurie, comes home everyday with stories of a classmate, Charles, who's disruptive, disobedient, and violent. Laurie's parents are concerned that Charles is a bad influence on their son.
The Gift of the Magi | O.Henry
A young couple with a low income try to find a way to get each other nice Christmas presents.
The Landlady | Roald Dahl
A young man stays at an eerily quiet but seemingly perfect bed and breakfast.
The Mouse | Saki
While riding in a train carriage with a woman, a man feels a mouse in his clothes and struggles to solve the problem discreetly.
Bella Fleace Gave a Party | Evelyn Waugh
A highborn but poor elderly woman comes into some money and throws a party, carefully choosing who she will invite and who she will snub.
Beware of Dog | Roald Dahl
A WW II pilot with serious injuries bails out of his plane. He wakes up in a hospital in Brighton (in his home country of England), with his injuries treated.
The Sniper | Liam O'Flaherty
A sniper on a rooftop gives away his position by lighting a cigarette. He exchanges fire with another sniper, and he knows he has to get off the roof before he's surrounded.
Dear Marsha | Judie Angell
During summer vacation, Marsha starts corresponding with a pen pal, Anne Marie. They talk about their difficulties and have a lot in common.
One Ordinary Day, with Peanuts | Shirley Jackson
Mr. Johnson walks around the city handing out candy, peanuts, and helping people wherever he can.
Clean Sweep Ignatius | Jeffrey Archer
Ignatius is the new Financial Minister of Nigeria. He is dedicated to ending corruption, and does such an impressive job that the President gives him a special assignment – rooting out Nigerians with secret Swiss accounts.
Read Clean Sweep... (Page 9)
Appointment with Love | Sulamith Ish Kishor
A returning lieutenant arrives at Grand Central Station to meet up with a woman he has never seen. They have been corresponding for 13 months during his tour of duty, and her letters have been a source of strength and encouragement. He feels he is in love with her, but he is also anxious to find out what she looks like.
A Rose for Emily | William Faulkner
Miss Emily Grierson dies and, as a town oddity, everyone goes to her funeral. The narrator recounts some episodes from her life, including a tax dispute with the town and when her suitor left her.
The Hounds of Fate | Saki
A wanderer approaches a house for a little relief, but is greeted as if he's the returning owner.
Harvey's Dream | Stephen King
An older man relates his previous night's dream to his wife.
This story has a surprise ending but it's not a sudden twist; it's more of a slow realization. This is an excellent story to teach careful reading. The clues are in plain sight.
Lamb to the Slaughter | Roald Dahl
A woman kills her husband with a piece of frozen lamb, and then plots to conceal her guilt.
Gold-Mounted Guns | F. R. Buckley
Pecos Tommy is an outlaw known for his gold-mounted guns. When a young man decides to start a life of crime, he finds Tommy and asks if he can ride with him. He even has an easy job lined up to get their partnership started.
A Man Who Had No Eyes | Mackinlay Kantor
A blind beggar comes down the street as Mr. Parsons comes out of his hotel. He feels pity for blind creatures and reflects on his own success. The man speaks to Parsons, and takes out an item that he'd like to sell.
Zoo | Edward Hoch
Professor Hugo's Interplanetary Zoo visits earth every August. Everyone looks forward to the strange creatures they will see this time.
More by this Author
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A summary of the short story War by Luigi Pirandello and analysis of theme.
- 0
Dystopian stories with short summaries and links for easy reading. For all fans of dystopian fiction.
- 0
Well-known, popular short short stories. Perfect for high school or middle school students, or anyone who loves reading.


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URS Group Inc
30 Carolina St # A, Satellite Beach, FL 32937
(321) 779-3166
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According to our records, this business is located at 30 Carolina St # A in Satellite Beach (in Brevard County), Florida 32937, the location GPS coordinates are: 40.639118 (latitude), -74.312062 (longitude). URS Group Inc is categorized under Engineering Services (SIC code 8711). Known organization owner is Joseph A Owen. Current estimates show that the unit has a sales volume of $474,000 and staff of approximately 3 people. You can contact the company by phone at (321) 779-3166.
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Rio Olympics might be a mess, but Tokyo 2020 has some cool high-tech plans
Driverless taxis for athletes and holograms for info.
Thu, Jul 07 2016
Clinton takes big step toward easing tensions with Sanders
With new college affordability plan, the presumptive Democratic nominee won praise from rival.
Thu, Jul 07 2016
US urges aerial spraying amid jump in Puerto Rico Zika cases
The U.S. territory is debating whether to fumigate with the insecticide Naled.
Wed, Jul 06 2016


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The SEO industry is constantly changing. It is important that Sandra Wallace and her business, Wally's Hobbies, keep up to date with all these changes. Where should she be doing her research?
Mar 20, 2012
Windows 8, which is slated to launch in October, is rumored to be operable on devices aside from desktops, laptops, and tablets, such as smartphones, e-readers, and smart TVs, according to reports from SlashGear. One such rumor adds that Windows 8 dedicated e-readers using the Metro UI are in the works, which, according to SlashGear, means that users would interact with the Metro user interface and that interface would be common across all Microsoft-powered devices. A consumer preview of Windows 8 is available at http://windows.microsoft.com/en-US/windows-8/consumer-preview.


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Tennessee Checkbooks and UT Checkbook Cover at the Official University of Tennessee Athletics Shop
Shop the official Tennessee Athletics store for UT Checkbooks for the biggest Tennessee fans and alumni. We stock top brands and new styles in University of Tennessee Wallets. Pick from our great selection of UT Billfold, Money Clip at the official store today and get our flat rate shipping for just $4.99.


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Today's Featured Artist: Michael Godard
Protect your iPhone 7 with a brand new iPhone 7 phone case!
Pixels Exclusive: Introducing the hottest summer accessory of 2016... round beach towels! FREE WORLDWIDE SHIPPING.
Fine Art America has expanded to 14 fulfillment centers in 5 countries!
David Bowie Remembered - A Collection of Unpublished Portraits by Terry O'Neill
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Kenai Border Collie by Linda Ruiz-Lozito - 8.000" x 8.000"
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Kenai Border Collie poster by Linda Ruiz-Lozito. Our posters are produced on acid-free papers using archival inks to guarantee that they last a lifetime without fading or loss of color. All posters include a 1" white border around the image to allow for future framing and matting, if desired.
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Great work Linda.
Beautiful Linda
Linda.Very nice art work of your Border Collie Congrats on your sale!!!!
How cool is this?! Congrats on your sale!
All prints ship in durable cardboard tubes.
Fine Art America is one of the largest, most-respected giclee printing companies in the world with over 40 years of experience producing museum-quality posters and prints. All of our posters are produced on state-of-the-art, professional-grade Epson printers.
We use acid-free paper with archival inks to guarantee that your posters last a lifetime without fading or loss of color. All posters include a 1" white border around the image to allow for future framing and matting, if desired.
Posters ship within 3 - 4 business days in durable cardboard tubes.
I made a drawing of Kenai my friend's Border Collie and made a handmade tile. I toll the drawing into my computer and converted to a digital image. The JPEG I uploaded is 300dpi 8x8"
The primal urge to create art has been a constant thread in my life. I have continued to create art throughout my life, even with other demands such as my children and family. I like my work have a feeling of playful enthusiasm. The life force in nature is inspiring. In my art I wish to convey my appreciation for the beauty and the energy found in nature. The element of color has been my focus in the creation of my art. Color has energy, emotion and creates a mood. My favorite mediums are Soft Pastels and Oil Colors. I love the immediacy of the pastels. I love oils, the buttery consistency and intense unlimited colors. BACKGROUND For over 25 years I have also worked as a graphic artist. This background gives me the...
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Fine Art America sells thousands of pieces of artwork each month - all with a 100% money-back guarantee. We take great pride in the fact that hundreds of thousands of artists have chosen Fine Art America to fulfill their orders, and we look forward to helping you select your next piece!
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NBJ NATIONAL. Litigating the Uninsured & Underinsured Motorist Claim BUSINESS INSTITUTE TM. Continuing Legal Education for Professionals
- Lesley Rogers
- 1 years ago
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1 INSTITUTE TM BUSINESS NBJ NATIONAL For a//your continuing education needs visit us at Continuing Legal Education for Professionals Underinsured Motorist Claim Litigating the Uninsured &
2 V Manassas, Litigating the Uninsured & Underinsured Motorist Claim Benjamin I. Trichilo Fairfax, VA Random Hills Road, Suite 500 McCandlish & Lillard, P.C Chain Bridge Rd Ste 400 Fairfax, VA August Steinhilber III Brault Palmer Grove Robbins & Steinhilber LLP 9300 West Courthouse Road Jonathan S. Rochkind Carluzzo, Rochkind & Smith P.C. VA Suite 203 Preston, Wilson & Crandley Virginia Beach, VA John G. Crandley 2404 Potters Rd Ste Granby Street Suite 100 Cooper Hurley, PLLC John M. Cooper Norfolk, VA Authors
3 Table Of Contents Evaluating The Case 1 Key Elements Of UMJUIM Coverage 9 Liens, Subrogation, Reductions And Offsets 25 Ethical Traps To Avoid 55 Pre-Litigation Activity 71 Arbitration And Mediation 83 Trial: Beyond The Basics 89
4 Benjamin J. Trichilo* McCandlish & Lillard, PC btrichiio(mccandlaw.com V. ETHICAL TRAPS TO AVOID The Preamble of the Virginia Rules of Professional Conduct (hereafter the Rules ) states [v]irtually all difficult ethical problems arise from conflict between a lawyer s responsibilities to clients, to the legal system and to the lawyer s own interest in remaining an upright person while earning a satisfactory living. Lawyers are never immune from federal and state laws and the rules of professional responsibility, although some may occasionally act otherwise. When faced with a dilemma of potentially unethical proportions, a lawyer should remember that money talks, but ethics walks. Most ethical lessons are applicable to all fields of law, however, uninsured motorist (UM) and underinsured motorist (UIM) claims have additional ethical considerations due to the intricate relationship between the injured party, the at-fault driver, and the UM insurance insurer. A. Who is the Client? When soliciting a potential client, an attorney cannot communicate any false, fraudulent, misleading, or deceptive statements or claims. Rule 7.3. An attorney also cannot attempt to circumvent this Rule by having a paralegal, secretary, etc. communicate the false information on behalf of the attorney. Id. An attorney must be mindful of the confidentiality owed to prospective clients that never come to fruition. Although no duty is owed to a person who unilaterally submits unsolicited confidential information to an attorney, if it is reason for a prospective client to believe that the information he/she provides will be maintained as 57
5 confidential then that information should be protected. See Standing Comm. On Legal Ethics, Virginia State Bar Ass n Legal Ethics Op (2008). The typical car accident lawsuit involves two parties- the injured driver (plaintiff) and the at-fault driver (defendant). But when the plaintiff has more UMIUIM coverage than the defendant has tiability coverage, the plaintiffs insurance company (the UM insurance insurer) becomes an interested third-party. When representing a party involved in an UM claim, an attorney must remember who his client is, and who his client is not, since the parties are so interrelated. 1. Injured Driver (Plaintiff) Regardless of whether the at-fault driver is known, the injured driver in an UM claim is required to obtain a judgment against the driver before requesting payment from the UM insurance insurer. VA. CODE ANT J (Cases involving unknown drivers state John Doe as the defendant. VA. CODE ANN (E).) It is important for the plaintiffs attorney to timely review the plaintiffs and the defendant s auto insurance policies (if applicable) and determine whether an UM claim exists because Virginia law requires the plaintiff to serve the defendant and the UM insurance insurer with process. VA. CODE ANN (E)-(F). Plaintiffs must serve UM insurance insurers as soon as it is practicable, as this vague time standard tends to account for much UM claim litigation. Although UM insurance insurers are not formally listed as parties, they are able to file pleadings and take other actions that the defendant is entitled to. VA. CODE ANN (E)-(f). A plaintiff cannot reach an agreement with a liability insurer without the permission of the UM insurance insurer or risk voiding the plaintiffs right to payment from the UM insurance insurer, therefore, communication between the plaintiff and the Ulvi insurance insurer is crucial. Plaintiffs must also 58
6 be aware if the defendant is proceeding pro se or with counsel, because plaintiffs are not allowed to directly communicate with the defendant or the defendant s insurance insurer if the defendant is represented by counsel. See Rule 4.2 and Standing Comm. On Legal Ethics, Virginia State Bar Ass n Legal Ethics Op (1990). Determining whether the defendant has retained counsel can be a particularly tricky task since the attorney representing the UM insurance insurer may also be advising the defendant, however, this can be resolved by simply asking the defendant. It is recommended to either submit all communications in writing, or to confirm the content of any oral communications in writing. 2. At-fault Driver (Defendant) In an UM case, the defendant typically has two goals: to keep the judgment/settlement as low as possible and to obtain a waiver from the UM insurance insurer whereby the insurer agrees to waive its subrogation rights against the defendant. Although the defendant s position may seem the most straight-forward, there may be other facts about the defendant that complicate the situation, for example, if the defendant is an interstate truck driver or an employee driving a company car, and there are scope of employment issues. Waiver of subrogation may not be feasible if the defendant has substantial assets. 3. UlvI Insurance Insurer The UM insurance insurer is in a unique position in TiM claims because it is an interested party from whom the plaintiff can recover, however, the UM insurance insurer is not formally listed as a defendant. Its liability is limited to its policy coverage. After an UM insurance insurer has been served with a copy of the suit papers, it can file pleadings and take other actions allowable by law. VA. CODE ANN (E)-(F). The plaintiff cannot settle with the liability insurance insurer until the UM insurance insurer has approved of the settlement or the 59
7 plaintiff will be forced to forfeit his right to recover against the UM insurer, so it s important to the plaintiff to communicate with the UM insurer. The UM insurance insurer and the defendant have similar goals for the outcome of the claim, but they aren t completely aligned because the insurer has the ability to file a subrogation claim against the defendant after the UM claim has been settled. VA. CODE ANN (G). Due to the potential future action against the defendant, the attorney representing the UM insurance insurer cannot state or imply to the defendant that he is a disinterested attorney. Rule 4.3. See also Standing Comm. On Legal Ethics, Virginia State Bar Ass n Legal Ethics Op (1994). This disclosure is especially important when the defendant is handling his case pro se because he may not understand that the UM insurance insurer s attorney is not also his attorney, which can result in accidental multiple representation. 4. Other Potential Clients Beyond the three typical parties in an UN case (injured plaintiff, at-fault defendant, and UM insurance insurer), there may be other interested parties who may require representation, such as passengers in the injured driver s car. If there are multiple passengers, they may jointly seek one attorney to represent their collective interest, however, there are many potential conflicts of interest involved with multiple representation (e.g., contributory negligence by the passenger). B. Multiple Representation Multiple representation occurs when one attorney or law firm represents more than one client. Rule 1.7 prohibits multiple representation when a concurrent conflict of interest exists, such as when the representation of one client will directly adversely affect the best interest of 60
8 another client. Due to the high potential of conflicting interests involved with multiple representation, an attorney should provide full disclosure and obtain a knowing written consent and waiver from clients whenever possible. Multiple representation can occur on purpose, such as when an attorney agrees to represent two different clients, or on accident, such as when an attorney advises a pro se litigant to the extent that an attorney-client relationship is established. Multiple representation can only occur in a limited number of variations of an UM claim since the plaintiff typically cannot be represented by the same attorney as the defendant or the UM insurance insurer (due to conflicting interests). 1. Purposeful Multiple Representation According to Disciplinary Rule 5-105(c), a lawyer may represent multiple clients if it is obvious that he can adequately represent the interest of each and if each consents to the representation after full disclosure of the possible effect of such representation on the exercise of his independent professional judgment on behalf of each. See Standing Comm. On Legal Ethics, Virginia State Bar Ass n Legal Ethics Op (1994). Purposeful multiple representation in the context of an UM claim may occur in the form of representing the at-fault defendant and the tim insurance insurer, representing multiple injured passengers from the plaintiffs car, etc. In Virginia, automobile insurance companies are required to provide uninsuredlunderinsured motorist coverage for at least $25,000 for one person injured in a car accident and $50,000 for accidents involving multiple injured people. If multiple passengers are injured in the plaintiffs car and the at-fault defendant has minimum coverage, there may be a race between the injured plaintiffs to obtain judgments before the insurance coverage is exhausted. If an attorney chooses to represent multiple injured passengers, a written waiver and 61
9 an agreement on how to divide the available insurance should be agreed upon and signed bejire proceeding with the lawsuit. Multiple representation of both the defendant and the UM insurance insurer is ethical and legal as long as there is full disclosure to both parties and no conflict of interests. The UM insurance insurer s attorney can also represent the defendant where the liability insurance insurer offers to pay its policy limits, waives its subrogation rights, and tenders the defense to the UM insurer. VA. CODE ANI.i (L). An attorney in this position must be mindful that information offered by the defendant during this attorney-client relationship cannot be used against the defendant in a later subrogation claim filed by the UM insurance insurer. Potential conflicts of interest can be eliminated if the UN insurance insurer provides a written waiver of its subrogation rights against the defendant. When a lawyer determines that he can no longer represent multiple clients without impeding upon the best interest of one or more clients, he should cease multiple employment; acting otherwise would be illegal, unethical, and subject the attorney, and potentially the attorney s law firm, to multiple malpractice lawsuits. See Standing Comm. On Legal Ethics, Virginia State Bar Ass n Legal Ethics Op (1991). Withdrawal of counsel requires that it occur without prejudice to the client. Rule 1.16(b). 2. Accidental Multiple Representation Lawyers should be aware (and beware) that multiple representation can also occur by accident. A common example occurs when the attorney of the UN insurance insurer provides excessive advice and assistance to the pro se defendant to the extent that an attorney-client relationship is formed. According to Virginia Disciplinary Rule 7-103(A)(2), a lawyer is prohibited from giving advice to an unrepresented person, other than the advice to secure 62
10 counsel, if the interests of such person are or have a reasonable possibility of being in conflict with the interests of the lawyer s client. See Standing Comm. On Legal Ethics, Virginia State Bar Ass n Legal Ethics op (1994). Since the defendant and the UM insurance insurer have a similar goals for the outcome of an UM claim, the UM insurer s attorney may provide limited assistance and advice to the defendant to ensure that the defendant is proceeding properly with the lawsuit. However, the UM insurance insurer s attorney must abide by very strict guidelines. The attorney cannot state or imply to the defendant that he is disinterested, he must clearly explain to the defendant that he is not the defendant s lawyer, and he cannot allow the defendant to continue to represent to the court that the defendant is appearing completely pro se (see Virginia Disciplinary Rule 1-102(A)(4)). For example, in Virginia Legal Ethics Opinion 1592 (1994), the committee opined that an attorney-client relationship was created between the attorney for the UM insurance insurer and the defendant after the attorney (1) raised objections of privilege on behalf of the defendant during his deposition, (2) instructed the defendant not to produce certain physical evidence for the plaintiff, (3) opposed the plaintiffs motion to compel discovery responses from the defendant, and (4) assisted the defendant in responding to the plaintiffs interrogatories, request for production, and request for admission. Failing to follow these rules can result in the establishment of an attorney-client relationship and potential disciplinary action against the attorney. C. Fee Agreements and Retention Fee agreements and retention keep an attorney s lights on, so they should always be in writing. The agreement should state very clearly when payments are due and in what form. Rule 63
11 1.5(a)-(b) state that attorneys fees should be reasonable and adequately explained to the client. Before a client signs a fee agreement, the attorney should go over the entire document and ensure that the client understands the fees, payment schedule, preferred forms of payment, and any special clauses, such as mandatory arbitration clauses. Rule 1.5(b). There are no mandatory billing rates for the legal community, so clients and attorneys are free to negotiate a fee that is appropriate for the situation. However, an attorney cannot be less zealous for a client who is paying less than other clients, so an attorney should never consent to a fee agreement that he is not comfortable with. Virginia Legal Ethics Opinion 1723 (1998) addresses billing requirements imposed by third parties, such as insurance companies. The fee agreement must be free from undue influence by third parties. There are three basic types of fees that an attorney can charge for his servicescontingency fees, hourly fees, and fixed fees. 1. Contingency Fees A contingency fee is a percentage of the plaintiffs monetary award from the judgment/settlement that is paid to the attorney for his services. Contingency fees are generally ethically permissible in any legal matter that generates a res from which the fee can be paid, unless otherwise prohibited. See Standing Comm. On Legal Ethics, Virginia State Bar Ass n Legal Ethics Op (1994). Contingency fee agreements must be in writing. Rule 1.5(c). Contingency fees generally range from 10-50%, and they are commonly used in personal injury cases because the lawyer is not paid unless the he wins (or settles) the plaintiffs case. Costs are often advanced by the attorney. It is important that the client understands the contingency fee agreement from the outset of the case because it can be quite jarring for a client to win a 64
12 $100,000 judgment and then receive only $50,000. It is also important that the client understands when the contingency fee is to be calculated (i.e., before or after court costs and additional fees are paid). For example, if the lawyer s 40% contingency fee is applied before additional costs ($10,000) are deducted and the client is awarded a $100,000 judgment, the lawyer will receive $40,000 and the client will receive $50,000. But if the lawyer s contingency fee was calculated after all additional fees had been deducted, the lawyer would receive $36,000 and the client would receive $54,000. Another matter a lawyer should consider is whether his contingency fee will take from any and all amounts funding the plaintiffs monetary award, which may include the plaintiffs Medical Payment Coverage (Med Pay) or Personal Injury Protection (PIP). Med Pay and PIP are additional auto insurance coverage options that cover medical expenses, lost wages, and other damages, regardless of whether the insurance holder was at fault. While it is permissible for attorney s contingency fees to apply to Med Pay and PIP, it is a factor to be considered since not all attorneys are comfortable recovering from this fund. Although a contingency fee agreement typically does not require an attorney to keep track of the time spent working on the legal matter, it is prudent for the attorney to do so in case the client fires him, in which case the contingency fee contract is gone and an attorney s lien is required to recover money owed. See Standing Comm. On Legal Ethics, Virginia State Bar Ass n Legal Ethics Op (1994). The lien is determined by the reasonable value of the services rendered by the attorney, not by the fee agreement contract. See Heinzman v. Fine, Fine, Legum and Fine, 217 Va. 958, 234 S.E.2d 282 (1977). 2. Hourly Fees An hourly fee is a fee that is charged for the amount of time the attorney has performed work for the client. For example, if an attorney s hourly fee is $300/hour and the lawyer 65
13 performs three hours of work for a client, the bill will total $900. Lawyers sometimes charge a higher fee for time spent in court for the client and a lower fee for research and preparation work. A bill to the client should clearly delineate the different fees and amounts of time being charged. Third party fee agreements should not subject the attorney s independent professional judgment to undue influence, and this potential problem is increased where the attorney is defending an underinsured motorist. The attorney s duty to the client is identical to the duties imposed upon an attorney who is privately retained. Norman v. Insurance Co., 218 Va. 718, 727, 239 S.E. 2d 902, 907 (1978). 3. fixed fees A fixed fee is a predetermined monetary amount that the attorney will charge the client for work performed for the legal matter no matter the time expended. For example, an attorney may charge a fixed fee of $15, to represent a client in a personal injury matter. fixed fees are typically used in less complex legal matters, such as writing a basic will. The fee agreement needs to be clear and specii whether there are circumstances for the attorney to withdraw or kick-out clauses for designated contingencies. 4. Retention After a fee contract has been signed, it is prudent for an attorney to send a letter of retention to the client to ensure that the client is aware of the retention and the scope of services the attorney has agreed to perform. The attorney must also be aware of the law applicable to the client s matter because the attorney may be legally obligated to provide more information or services to the client than he is contractually obligated to. If the lawyer consults with a potential client and is not retained, then it is usually advisable to send a letter confirming the non retention, and advising of any limitations periods. 66
14 In addition to a letter of retention, attorneys often require a retainer in order to secure employment with the client. A retainer is a payment by a client to an attorney to insure the attorney s availability for future legal services andlor as consideration for his unavailability to a potential adverse party in the future. See Standing Comm. On Legal Ethics, Virginia State Bar Ass n Legal Ethics Op (1994). A retainer is not a pre-payment for legal services to be rendered in the future, and is thus distinguished from advanced legal fees. Id. Retainers are earned when paid and become property of the attorney, whereas advanced legal fees are still owned by the client until earned and should be held in an identifiable account separate from the attorney s. The terms retainer and advanced legal fees are often mistakenly used interchangeably, and it is important to use the correct terminology in fee and retention agreements so the attorney does not accidentally deposit client money into a personal account. D. Guarding Against Malpractice Although no one expects to be sued for malpractice, the old adage applies: failing to plan is planning to fail. Lawyers sometimes include mandatory arbitration clauses for malpractice claims in their client engagement agreement, which is ethical as long as the lawyer provides adequate written disclosure, advises the client to seek independent counsel in regard to the provision, and receives informed consent from the client. See Standing Comm. On Legal Ethics, Virginia State Bar Ass n Legal Ethics Op (1998). Here are four tips to guard against malpractice: consider purchasing malpractice insurance, know the extent of your legal abilities and your schedule, keep your client informed of all developments, and make all necessary disclosures. 1. Consider Purchasing Malpractice Insurance 67
15 The first step in proactively guarding against malpractice is considering whether to purchase malpractice insurance. Every attorney should spend adequate time and consideration on this decision. Malpractice can occur at the associate-, partner-, or firm-level, and no one is immune from liability. Legal malpractice claims are not reserved for bad lawyers, and obtaining malpractice insurance does not make you more likely to get sued. Even if you believe no malpractice was committed, defending a malpractice lawsuit can be expensive and timeconsuming. Just like other types of insurance, malpractice insurance is available in a variety of plans to fit each attorney s specific needs. Malpractice insurance provides coverage for the defense of the claim, and that benefit alone can justifr the expenses of the policy. 2. Know the Extent of Your Abilities and Your Schedule Before taking on a new client or legal matter, an attorney should consider the extent of his legal abilities and his schedule. An attorney should not accept cases or clients whose requirements are beyond the attorney s capabilities or amount of available time. The easiest way to commit malpractice is to miss an important deadline; or to undertake legal representation in a specialized area outside of the attorney s areas of practice. If an attorney takes on too many clients or too many projects, it becomes much easier to miss a deadline, or neglect a client s case. For example, in Wilder v. Third Dist. Committee of Va. St. Bar, 219 Va. 175, 247 S.E.2d 355 (1978), an attorney was reprimanded by the Virginia State Bar for inexcusable procrastination after he offered no valid excuse for delaying his client s case for over two years. Although turning down a client or case may reduce future income, there may be much greater benefits by avoiding the time, expense and aggravation of a malpractice claim. 3. Keep Your Clients Informed of All Developments 68
16 It should go without saying that maintaining communication with a client is of the utmost importance, but it s worth repeating because uninformed clients can quickly become unhappy clients who are more likely to file bar complaints and malpractice lawsuits. It may be unnecessary to inform your client about every you send, however, clients should be kept aware of developments in the case. The risks arising from over-informing a client are usually much smaller than those arising from under-informing the client. A client wants to feel that his attorney has done everything within legal and ethical bounds to advance his best interests. Timely or phone call updates will promote usually increase client confidence, and reduce anxieties. Very few clients will be upset if you return their call on an evening or a weekend. 4. Make All Necessary Disclosures Attorneys are required to make disclosures to clients, non-clients, and the courts, and it s important to realize when each disclosure should be made. See Rule 1.6. Whenever a disclosure can be made in writing, it should be; adequate documentation can become crucial evidence if the disclosure s occurrence is ever questioned. Lawyers should make potential clients aware of the details of their fee plans to avoid potential fee disputes. See Rule 1.5. A lawyer should never imply or state that he is disinterested where the attorney has a personal or business interest. For example, when the attorney of a UM insurance insurer is speaking with a pro se defendant for a car accident claim, the attorney cannot imply or state that he is disinterested since the attorney s client may eventually sue the defendant in a subrogation claim. If a lawyer advises or helps a pro se litigant, the lawyer must ensure that he is given credit for his work so that the pro se litigant does not mislead the court. Before accepting a new client, an attorney should run a conflicts check and disclose any potential conflicts of interest. 69
17 One of the most important required disclosures arises from Rule 3.3(a)(3), that requires an attorney to disclose to the court controlling legal authority in the subject jurisdiction known to the lawyer to be adverse to the position of the client and not disclosed by opposing counsel. If the court finds the controlling adverse authority that you did not disclose, then that is likely to cause substantial, if not irreparable damage to your case, and reputation. * Benjamin I. Trichilo would like to thank Rachael F. Ander, a law clerk at McCandlish & Lillard, PC, for her contribution and most valuable assistance researching and drafting this section of the manual. 70
18 Pre-Litigation Activity Submitted by Benjamin J. Trichilo 71
19 a I\J
20 Benjamin J. Trichilo* McCandlish & Lillard, PC btrichuiomccand1aw.com VI. PRE-LITIGATION ACTIVITY A. Choice of Venue After deciding to file a UlVI claim, venue is the first important decision that a plaintiff must make. Plaintiffs should first look to Va. Code Ann , which lists the specific preferred venue situations, although they typically do not apply in UM cases. Va. Code Ann contains the provisions that are most commonly used to establish venue in UM cases. According to Va. Code Aim (4), venue is permissible wherein the cause of action, or any part thereof, arose. For example, if the car accident occurred in Fairfax County, VA, it would be permissible to file an UM claim in Fairfax County Circuit Court. If the defendant is unknown, and therefore a John Doe, or he does not reside in Virginia, the plaintiff may use Va. Code Ann (10) to establish proper venue wherein any of the plaintiffs reside if (1) all of the defendants are unknown or are nonresidents of the Commonwealth or if (ii) there is no other forum available under any other provision of or this section. If the defendant is not an individual, for example, an employer of the negligent driver, venue is permissible wherein its principal office or principal place of business is located. VA. CODE ANN (1). So in an UM claim, the plaintiff may file suit in the location where the car accident occurred, and if the defendant is unknown, the plaintiff also had the option of filing where the plaintiff resides. If the defendant believes that the venue is improper, he may file an objection according to Va. Code Ann If venue would be proper in another forum within Virginia, the claim may not be dismissed, but will be transferred to the appropriate venue. 73
21 third party, it is still able to file pleadings and other actions allowable by law in its name or the defendant s name. VA. CODE ANN (E)-(f). Although the UM insurance insurer may It is important for any objection alleging improper venue to be timely. In Smith v. Doe, the UM insurance insurer s motion to transfer venue was denied because although it was filed in a timely manner, the UM insurance insurer failed to promptly schedule a hearing with the court. B. Discovery 1. Plaintiff a trial are not likely to be economically justified. If the plaintiff is covered under multiple (3) outlines Virginia s legally mandated order for applying different lines of coverage 74 disallow or restrict the use of intra-policy stacking, so it is imperative to read the plaintiffs UM under the same plan, also known as intra-policy stacking. Some automobile insurance contracts coverage of multiple automobiles is combined to benefit the single plaintiff. VA. Code Ann. automobile insurance policies, stacking may apply. Stacking occurs when the insurance the defendant s liability and UM coverage is for $75,000.00, then the high costs associated with and all sources of insurance coverage. If the plaintiff has suffered damages for $100, and \Vhen representing the plaintiff in a UM case, discovery request needs to address liability the court s attention in a timely manner. Smith v. Doe, 11 Va. Cir. 228 (1988). It is the burden of the moving party to bring the matter to defendant regularly conducts substantial business activity. located within the venue. In addition, Va. Code Ann (3) permits venue where the permissive if the non-individual defendant has its principal office or principal place of business not agree with the plaintiffs chosen venue, Va. Code Ann (1) states that venue is Although the UM insurance insurer is not actually a defendant, but rather an interested
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Amrita sported a yellow Neha Taneja dress while at the Bandra 190 preview. Wearing her hair in a top knot with big bangs, she finished off the look with basic black Louboutin pumps. While the hair style looked good on her, between the shoddy hemline and ill fitted waist and bust, can't say I am a fan of the dress itself.
Amrita Arora In Neha Taneja0


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Baby Movie
Cry-Baby (1990) this movie is hilarious! Lol
Bringing Up Baby (1938)~There *is* a leopard on your roof and it's my leopard and I have to get it and to get it I have to sing.
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In addition to traditional Middle Eastern cuisine like falafel and shawarma, the menu at Mediterranea Cafe offers a selection of Italian favorites, including specialty pizzas and classic pasta dishes, as well as soups, salads, and more:
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