text:
The ALPS OutdoorZ Commander Freighter Frame Plus Pack Bag, 5250 is resilient knapsack. This system comes with an additional Freighter Frame and a 5250 cubic inch pack bag.
The commander frame can be utilized as a Truck Frame; the commander frame likewise allows you to haul meat from different locations. It also includes an added lashing system that serves to safeguard your mat throughout transport. Other pockets function as storage points for flashlights, knives and can be used as a gun holder. Ideally, this device serves 2 purposes; it is a backpack that can also be utilized as a freighter frame.
ALPS OutdoorZ Commander Freighter Frame Plus Pack Bag Includes
1. Numerous pockets: This system has many pockets that make it simple to organize you gear well. The small pockets at the side facilitate loading and discharging of basics like knives and flashlights quickly.
2. Comfy: The suspension material used makes it easy and comfortable to carry this device for extended periods. The waist belt, straps, shoulder straps and waist belt can be quickly changed to suit different body shapes.
3. Easily tailored: Preferably, the original pack can be eliminated from the frame. The frames utilized to bring parts of your hunted foods like the elk or deer. Meat is secured easily on the frame utilizing compression straps.
1. Versatile
2. Resilient
3. Great deals of Company
4. Big Capability
1. Quite heavy
The ALPS OutdoorZ Leader Load
A client that just recently bought this system stated that ¬I bought the Alps Outdoor Z Leader Truck Frame pack along with a Kelty Cache Hauler. I have to say that this frame is elegant quality and durable. Buying it is a decision I can never ever be sorry for.
The ALPS OutdoorZ Leader pack is an outstanding choice for any hunter. It has many features that will make all your outdoor trips and experiences even more enjoyable. The only drawback is the weightIf you want to carry it, be guaranteed that this system will offer you an adequate experience
The ALPS OutdoorZ Commander Freighter Frame Plus Pack Bag, 5250 is durable backpack. The leader frame can be utilized as a Freighter Frame; the commander frame also allows you to transport meat from different places. Easily tailored: Preferably, the initial pack can be eliminated from the frame. The frames used to carry parts of your hunted foods like the elk or deer. A consumer that just recently bought this device said that ¬I bought the Alps Outdoor Z Leader Truck Frame pack along with a Kelty Cache Hauler.


text:
Most teams would be displeased losing 9-3, which Hamilton did against Brantford on Sunday (May 6).
But after losing 29-4 to the same senior Intercounty Baseball League club 24 hours earlier, a 9-3 setback doesn't look all that bad for the Thunderbirds.
And at least the worst defeat came while the T-Birds opened their 2007 season on the road.
On Sunday, the visitors to Bernie Arbour Stadium had crafted a 6-0 lead before Hamilton scored all its runs in the home half of the fourth inning. The Red Sox would finish the game with 12 hits, compared to the 25 they collected ion Saturday.
The T-Birds had nine hits on Sunday.
Brantford won last year's ICL championship.
Hyung Cho led the Brantford attack on Sunday with a 355-foot bases loaded home run over the left centre field fence. He was two for six on the day. Dave Parsons, Jason Gotwalt, and Tyler Burnell also had two hits apiece for the Red Sox.
Hamilton second baseman Tommy Robertson led the way with three hits in four trips including a double and was the keystone in Hamilton's first inning doubleplay. Geoff Allen singled twice for the Thunderbirds.
Pitcher Stefan Strecker (1-0) got the victory for Brantford, going nine innings. Andrew Schwalm (0-1) took the loss allowing six runs on six hits through four innings. He struck out one, and walked five. Chris Plummer came on in relief in the fifth and completed the game.
On Saturday, Hamilton scored two runs in the top of the first inning and then the roof collapsed. The Red Sox replied with seven runs in their first at-bat and scored in every inning except the fifth and eight, including a nine-run explosion in the seventh.
Al Stephens connected for three hits including a pair of two-run home runs for Brantford.
Stephens picked up five RBIs. Josh McCurdy added four hits including a two-run triple, and a home run. He had three RBIs and scored six times. Hyung Cho banged out four singles and scored four times.
Robertson and outfielder Jon McGinn each hit a double for the T-Birds.
Pitcher Brad Hogeterp (1-0) took the win, going six innings allowing four runs (three earned). He gave up eight hits, two walks and struck out five. In relief, Brett Gray came on in seventh and threw two hitless innings. Gray had four strikeouts. Mark Ferguson pitched the ninth inning.
Jeremiah Groulx (0-1) took the pitching loss for Hamilton giving up seven runs (six earned) in the first inning on five hits and a walk. Doug Chrysler relieved him in the first with Sean Allen (fifth), Mike Fortuna (sixth), and Jason Green (eighth) finishing the game.
Next action for Hamilton is Mother's Day (Sunday, May 13) against the Guelph Royals at Bernie Arbour Memorial Stadium. Game time is 2:05 p.m.

subset: commoncrawl


text:
Ok, I admit, sometimes I'm skeptical of these high-dollar, over-the-counter homeopathic remedies…fourteen dollars for a tiny vial of hope?!? It reminds me of the old days, when they would sell mysterious tinctures that cured insomnia, ear aches, rashes and constipation, and a hundred years later, we discover that it was actually liquid cocaine. Nice. Perfect for when little Johnny is teething.
But, that being said, I actually DO believe in the power of many natural herbs and plants to solve health problems, and if we can avoid taking a ton of prescription meds, it's better for our bodies, right? Well, now I'm really confused.
A new campaign out of the UK called 10:23 is asserting that homeopathic remedies are a huge hoax, and in many ways, are harmful to society. According to their website,
"Homeopathy is an unscientific and absurd pseudoscience, yet it persists today as an accepted complementary medicine.
Ask many people what they think homeopathy is, and you'll be told "it's herbal medicine" or "it's all-natural". Few realise that it's been proven not to work; even fewer know it involves substances so dilute that there's nothing left in them. Homeopathy takes advantage of this uncertainty to sit alongside real, proven medicines on the shelves of our major pharmacies."
Not only are they boycotting homeopathic medicines, the 10:23 campaign is accusing them of being harmful, especially when they take the place of medicine that would actually help a patient. Read over their ten reasons "Why You Can't Trust Homeopathy" , watch a few videos (including "If Homeopathy Works, I'll Drink My Own Piss"), and let me know what you think. Is this just western medicine trying to brainwash us? Is this like the whole Corn Syrup PR campaign? Or is there some truth to what they are saying?
Until then, I'll just stick to eating an apple a day, and cross my fingers for good health. That can't be bad for me, right?
Rachel Znerold is an artist and independent fashion designer living the good life in San Francisco, CA. www.rachelzart.com
Richard Dawkins: The Enemies of Reason
Crispian Jago: If Homeopathy Works, I'll Drink My Own Piss
hot on elephant
Elephant Journal's Holiday Gift Guide 636 shares A letter to the Anger that refuses to Leave Me. 569 shares Waylon's favorite Ethical Gifts. 13 shares Join: Elephant's Winter 2017 Academy. 28 shares Trevor Noah just won my Respect. 2,559 shares Year of the Fire Rooster 2017: What to Expect. 891 shares December Forecast: Letting Go of 2016 & Leaning into 2017 with Love. 7,108 shares Why a Year of No Dating was the Best Thing I ever did for Myself. 5,942 shares The Real Reason so many Long-term Relationships Fail Sexually. 690 shares These Tweets (and Retweets) actually Happened. 1,386 share


text:
All Films.All Above Board.NOW INCLUDES TV!
Lars Mikkelsen and Pilou Asbæk star in this Danish war drama based on real events. On April 9th 1940 the German Army invade Denmark and Second Lieutenant Sand (Asbæk) and his bicycle infantry face the challenge of holding off the enemy as they await reinforcements.


text:
Love it, hate it, good story, bad story... the media are going to keep reporting on ME/CFS no matter what. But isn't it time that we saw that coverage as an opportunity?
Discuss the article on the Forums.
Can anyone help me interpret Genova Metabolic Analysis Profile?
Discussion in 'Diagnostic Guidelines and Laboratory Testing' started by pjam24, Jun 5, 2014.
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Page 1 of 2


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Finance Secretary Carlos G. Dominguez III shares the infrastructure program of the Duterte administration saying it would unleash and help the Philippine economy expand at a faster rate during his remarks before more than a hundred stakeholders and development partners at the 3rd Quartely Roundtable Program of the Wallace Business Forum, held at Shangri-La Hotel, Makati.
Finance Secretary Carlos G. Dominguez with Pakistani Ambassador Safdar Hayat during the courtesy call by the ambassador at the Land Bank Office in Malate, Tuesday morning. Hayat relayed to Dominguez the Pakistani government's support and keen interest on fostering better economic relations with the Philippines.
DOF Secretary Carlos G. Dominguez III delivers his closing statement at the Philippine Development Forum 2016 and extends gratitude to more than 400 stakeholders from the national government and local government units (LGUs), business sector, development partner community, the academe and civil society who actively participated in the two-day forum held at the SMX Convention Center, Davao City.
DOF USEC. Karl Chua; National Treasurer Roberto Tan BTr; Mr. Richard Bolt - Country Director, Asian Development Bank; Mr. Jay Peiris - International Monetary Fund; Ms. Mara Warwick- Country Director, World Bank; Secretary Benjamin Diokno, DBM; Secretary Carlos Dominguez, DOF; Secretary Ernesto Pernia, NEDA; Secretary Leonor Briones, DepEd; Mr. Hans Farnhammer- European Commission/EU Delegation; Minister Iyori Makoto, Embassy of Japan; Counselor Jin Yuan, Embassy of the People's Republic of China.
The Department of Finance(DOF) is the government's steward of sound fiscal policy. It formulates revenue policies that will ensure funding of critical government programs that promote welfare among our people and accelerate economic growth and stability.Learn More
|Bureau of Customs Collections
|Bureau of Internal Revenue Collections
|Consolidated Public Sector Financial Position
|Total Number of Registered Cooperatives and Average Members per Cooperative
|Consolidated Statement of Income and Expenditures of Local Government Units
|Debt Service of the National Government
|Detailed Report on Bureau of Internal Revenue Collections
|Government Securities Holdings of Private Insurance Companies (At Cost)
|Guarantees and Credit Insurance Outstanding
|Investments of Private Insurance Companies (At Cost)
|Guarantees and Credit Insurance Outstanding
|Investments of Private Insurance Companies (At Cost)
|National Government Cash Expenditures
|National Government Cash Operation
|National Government Financing
|National Government Interest Payments
|National Government Operations
|National Government Revenues
|National Government Tax Revenues
|Number and Amount of Paid-up Capital Investments Contributions in Dissolved Domestic Stock Partnership and Corporations
|Number of Closed Banks Under PDIC Receivership Liquidation
|Operations of Government Financial Institutions
|Operations of Social Security Institutions
|Outstanding Debt of the National Government
|Outstanding National Government Debt
|Outstanding Public Sector Debt
|Philippine Deposit Insurance Corporation Assessment Collection
|Philippine Deposit Insurance Corporation Financial Assistance Extended
|Philippine Deposit Insurance Corporation Insured Deposit Claims Paid
|Statement of Financial Operations of 14 Major Non-Financial Government Corporations
|Status of Cash Receipts and Disbursements of Municipal Development Fund Office
|Tax Credit Certificates Issued by the Department of Finance' One-Stop-Shop Tax Credit and Duty Drawback Center
|Taxes and Duties Waived under Special Tax Incentives Laws
|Total Number of Registered Cooperatives
|Consolidated Statement of Financial Operations of 14 Major Non-Financial Government Corporations
|Outstanding National Government Cash Balances
|Magnitude of Tax subsidy Grant Under Tax Expenditure Fund


text:
Des Moines, IA
In this role, you will works on the most complex problems where analysis of situations or data requires evaluation of intangible variance factors.
- industry
- Financial Services
- experience
- 8 - 10 years
To help you find the most relevant jobs, we've come up with an approximate compensation for this position. This is based on similar jobs with compensation posted.


text:
Each month, Rated People connects over 50,000 homeowners with quality tradesmen - simply enter your job details in the form above to get started.
We'll match your job to the relevant tradesmen in your area - those interested will pay to see your contact details and call you to quote.
As each tradesman expresses interest in quoting on your job, we'll send you their profile and ratings to help you choose the right one for you.
After the work is complete, return to the site and rate your tradesman based on their quality of work, reliability and value for money.
Added 26/06/2016
To supply and fit. Remove existing water tanks, hot x 1 cold x 2 and associated parts. Install...
Added 01/05/2016
Gas boiler installation Replace Combi boiler with Worcester Bosch Combi boiler Additional...
Added 13/02/2016
Install tap(s) The mister tap on the bathroom sink has seized up on the cold tap. Probably...
Added 05/08/2015
Leaking Pipework under cistern has leak; also basin taps required to be connected (already...
Added 09/04/2014
fit a power shower in bathroom
Added 17/03/2014
Gas boiler installation Install Vaillant Combi boiler Install: 5 or more radiators Additional...
Very impressed with work - finally I got someone who was able to diagnose & fix long-standing problem with overflow. Would definitely recommend!!
Right from getting a quote from Matt he was the only choice. The detail he gave when pricing up the job was first rate. He answered all questions I had and offered great advice throughout the quote and the job itself. Weather hampered the job but he still turned up and patiently waited in the van until the rain cleared. Great communication when he was unable to turn up due to persistant rain and gales blowing. I advise all users to use Matt. The cheapest quote and excellent workmanship. Thanks Matt .
Punctual, Professional and good value, will use HEating again and recommend rated people for finding quality tradespeople.
Managing your job is easier with the Rated People Homes App, download it today.


text:
Serial Network Cards and Network Controllers Datasheets
from Advantech
The PCM-26 series is categorized as Industrial Communication with Fieldbus Protocol modules from Advantech iDoor Technology. They are all compatible with the PCI Express ® Mini Card Specification Revision 1.2. including Isolated / Non-Isolated RS-232/422/485 communication cards for automation... [See More]
- Protocol / Network: Fieldbus; Profibus; Serial
- Host Bus: PCI Express Mini Card Revision 1.2
- Data Rate: 12000
- Number of Ports: 1
from Ametek Solartron Metrology
Whether it be PC, laptop or PLC, Solartron offers a range of Interface Modules and PLC gateways for directly connecting to an Orbit® Network with the Controller of your choice. The interface module provides a method of connecting controllers to the Orbit® network where the controller itself runs the... [See More]
- Protocol / Network: 10Base-T Ethernet; Serial; Orbit® Network
- Host Bus: Ethernet
- Data Rate: 100000
- Port Type: Ethernet
from AAEON Electronics, Inc.
Broadcom BCM5721/51/89 Dual PCI-Express 10/100/1000Base-TX Ethernet Daughter Board. Main Feature. Dual PCI-Express Host Interface. Dual 10/100/1000Base-TX Triple-speed Ethernet Controllers. IPMI 1.5 Standard (BCM5751/BCM5721 Only). ASF2.0 Standard (BCM5721 Only). Teaming Function (BCM5721 Only). [See More]
- Protocol / Network: Serial
- Host Bus: PCI-Express
from ACCES I/O Products, Inc.
Features. Universal PCI, PCI-X, 3.3V and 5V compatible (Call for PCI-Express availability). Dual-port serial communications card for PCI bus. Supports RS-232(PCI-COM2S only), RS-422, and RS-485 protocols. Automatic control of RS-485 driver under Windows systems. Includes type 16550 UART with 16-byte... [See More]
- Protocol / Network: Serial
- Host Bus: PCI
- Data Rate: 460
- Number of Ports: 2
from Automationdirect.com
Optional communication card for Stellar SR44 series soft starters, can be used to establish RS-485 communication between an SR44 soft starter and any Modbus Master (PC, PLC, etc.). Plugs directly onto the control board of an SR44 soft starter, no external power required, RJ45 and terminal strip... [See More]
- Protocol / Network: Serial
- Port Type: RS485
from Eaton | Power Quality
Management Card Contacts & RS232/Serial offers possibility to interface with monitoring systems using contact-based status information or offer an additional RS232/Serial link to the U [See More]
- Protocol / Network: 10Base-T Ethernet; Serial
- Number of Ports: 1
- Host Bus: Minislot
- Port Type: RS232
from INOVA Computers (Schweiz) GmbH
16 Byte transmit & receive FIFO, interface module, 9 pin D-sub connector [See More]
- Protocol / Network: Serial
- Host Bus: CompactPCI
- Data Rate: 461
- Number of Ports: 1
from Kontron USA
The CRTtoLCD-7 is a highly integrated flatpanel controller, that allows to connect standard analog RGB, DVI, PAL/NTSC- Video - sources to TTL- and LVDS flatpanels. It includes all the necessary functionality to design e.g. full featured industrial LCD monitors, open frame kits or other LCD based... [See More]
- Protocol / Network: Serial
- Operating System: Windows 95/98; Windows NT; Windows 2000; Linux
- Port Type: Analog RGB, DVI and PAL/NTSC
from MKS Instruments, Inc.
The SCOM 6U card set for 6U CompactPCIprovides a unique solution for industrial grade, rear accessible serialcommunication. Each channel is jumper configurable for RS-232/485 andready for immediate connection to field devices. The main board hosts 8channels of serial communication, and provides... [See More]
- Protocol / Network: Serial
- Number of Ports: 8
- Host Bus: CompactPCI
- Port Type: RS232; RS485
from Opto 22
The M4SENET-100 provides an Ethernet interface for M4 series controllers such as the SNAP-LCM4 and the M4RTU. Connection is via a 10Base-T or 100Base-TX link, and standard TCP/IP transport is used for all transactions. [See More]
- Protocol / Network: 10Base-T Ethernet; Fast Ethernet; Serial
- Port Type: RJ-45; RS232
- Data Rate: 115
- Operating System: Windows 95/98; Windows NT
from Parvus Corporation
16 general purpose digital I/O channels [See More]
- Protocol / Network: 10Base-T Ethernet; Serial
- Number of Ports: 4
- Host Bus: PC/104
- Port Type: RS232; RS422; RS485
from ProSoft Technology, Inc.
The ADM module is a single-slot, backplane compatible solution for the Quantum platform that supports user-developed applications. "C" code applications are developed using Digital Mars C++ 16-bit development tools (included), downloaded to, and then debugged on the module. The ProTalk module is a... [See More]
- Protocol / Network: Serial
- Operating System: MS-DOS
- Port Type: RS232; RS422; RS485
- Operating Temperature: 0 to 60
from VTI Instruments Corporation
The VXIpc-770 controller is a low-cost, single-slot, C-size embedded VXI computer that uses state-of-the-art technology and packaging to create fully PC-compatible contollers for VXI systems. The VXIpc-770 controller is the most cost-effective single-slot VXI embedded control solution available. [See More]
- Protocol / Network: Fast Ethernet; Parallel; Serial; GPIB
- Number of Ports: 5
- Host Bus: VME / VXI
- Port Type: Parallel; USB; PS/2


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text:
You limited your search to:
Partner: UNT Libraries
Degree Discipline: English
Collection: UNT Theses and Dissertations
Maelstrom: the Last Coyote Tale
Date: December 1997
Creator: Claiborne, J. Taylor (John Taylor)
Description: It is a dark future, where corporations have taken the place of governmental bodies, and Earth is a myth, forgotten in the reconstruction after the Second Dark Age. One man--a clone--investigates a murder [that] leads him deep into a spirit quest of his own that will answer the questions of Man's heritage as well as his own identity. This story is a science fiction, but it is similar in structure to a Coyote tale and involves quite a bit of Navajo mythology. The use of Native American imagery is not an attempt to capitalize on another culture, but rather to study the culture and use allegorical elements that transcend many cultures. It must also be noted that non-Native American writers wrote all texts available on the subject. This fact should be taken into consideration by the reader.
Contributing Partner: UNT Libraries
The Rhetoric of Posthumanism in Four Twentieth-Century International Novels
Date: August 1998
Creator: Lin, Lidan
Description: The dissertation traces the trope of the incomplete character in four twentieth-century cosmopolitan novels that reflect European colonialism in a global context. I argue that, by creating characters sharply aware of the insufficiency of the Self and thus constantly seeking the constitutive participation of the Other, the four authors E. M. Forster, Samuel Beckett, J. M. Coetzee, and Congwen Shen all dramatize the incomplete character as an agent of postcolonial resistance to Western humanism that, tending to enforce the divide between the Self and the Other, provided the epistemological basis for the emergence of European colonialism. For example, Fielding's good-willed aspiration to forge cross-cultural friendship in A Passage to India; Murphy's dogged search for recognition of his Irish identity in Murphy; Susan's unfailing compassion to restore Friday's lost speech in Foe; and Changshun Teng, the Chinese orange-grower's warm-hearted generosity toward his customers in Long River--all these textual occasions dramatize the incomplete character's anxiety over the Other's rejection that will impair the fullness of his or her being, rendering it solitary and empty. I relate this anxiety to the theory of "posthumanism" advanced by such thinkers as Marx, Bakhtin, Sartre, and Lacan; in their texts the humanist view of the individual ...
Contributing Partner: UNT Libraries
"Stately Temples": Consubstantiality and Consciousness in Frances E. W. Harper's Iola Leroy; or Shadows Uplifted
Date: August 1996
Creator: Louis-Ray, Deborah
Description: The purpose of this master's thesis is to examine Frances Harper's narrative strategy and moral didacticism in Iola Leroy: or Shadows Uplifted (1892) as she strives to achieve consubstantiality and a "heightened consciousness" within her characters and her audience while adhering to the literary and feminist paradigms of the late nineteenth century. Harper identifies with her African-American male audience's dilemma of "double-consciousness" and their veil of androcentrism. She also identifies with her Euro-American female audience's delicate and matriarchal roles, while also attempting to uplift their position of the "Other" to the "One." Finally, with her African-American female audience, Harper identifies with their complex situatedness of "double-consciousness" and the "Other," while also attempting to uplift them from a historically imposed position of selflessness to one of empowerment.
Contributing Partner: UNT Libraries
Women's and Men's Perceptions Regarding Perceived Speaker Sex and Politeness of Given Utterances
Date: May 1995
Creator: Johnson, Deanna Michelle
Description: Women's and men's responses regarding perceived speaker sex and the politeness of given utterances were examined through the use of a questionnaire administered to 90 people, 45 men and 45 women. The questionnaire required respondents to rate the politeness of each utterance and label each as being more likely spoken by a man or by a woman. Factors possibly affecting perceptions--such as power, prestige, and the stereotypical conversational structures of both men and women--were addressed through others' research in this area. Additionally, all tested sentences were analyzed in light of linguistic politeness theory regarding on-record and off-record speech. This analysis details each utterance through examining the type of politeness strategy each utterance typifies.
Contributing Partner: UNT Libraries
Revisiting the Grotesque: Poems
Date: August 1997
Creator: Davidson, Chad (Chad Thomas)
Description: This thesis consists of a group of poems around a central concept: language as a physical dwelling place—a place much like what Raphael discovered in the grottoes of Rome and named "grotesque," or "grotto-esque." Using the word, "grotesque," as an example, the preface illustrates how poetry can play with the lost histories of words while still searching for new referents and associations.
Contributing Partner: UNT Libraries
Reflections of Other/Reflections of Self
Date: August 2002
Creator: Bebout, Lee
Description: This Thesis collection contains a critical preface and five stories. The preface, "Reflejos y Reflexiones" (translated: Images and Thoughts), addresses the issues of writing the cultural or gendered Other; these issues include methodology, literary colonialism, a dialogue between works, and creating distance through defamiliarizing the self. "Perennials" is the story of Noemi Tellez, an immigrant to the U.S. who must choose between working and taking care of her family. In "Load Bearing" Luis, the eldest child, faces his family and friends on one of his last days before moving away to college. "La Monarca" deals with Lily's, the youngest daughter, struggle to mediate a place between her friends and her family. In "Reflections in the River," Arabela, the second youngest, faces the ghost of an unwanted pregnancy and La Llorona. "La Cocina de Su Madre" is the story of Magda, the oldest daughter, and her own teenage girl, Natalia, as they attempt to find themselves in a new town after moving a thousand miles from home.
Contributing Partner: UNT Libraries
Working Whiteness: Performing And Transgressing Cultural Identity Through Work
Date: May 2002
Creator: Polizzi, Allessandria
Description: Early in Richard Wright's Native Son, we see Bigger and his friend Gus "playing white." Taking on the role of "J. P. Morgan," the two young black men give orders and act powerful, thus performing their perceived role of whiteness. This scene is more than an ironic comment on the characters' distance from the lifestyle of the J. P. Morgans of the world; their acts of whiteness are a representation of how whiteness is constructed. Such an analysis is similar to my own focus in this dissertation. I argue that whiteness is a culturally constructed identity and that work serves as a performative space for defining and transgressing whiteness. To this end, I examine work and its influence on the performance of middle class and working class whiteness, as well as how those outside the definitions of whiteness attempt to "play white," as Bigger does. Work enables me to explore the codes of whiteness and how they are performed, understood, and transgressed by providing a locus of cultural performance. Furthermore, by looking at novels written in the early twentieth century, I am able to analyze characters at a historical moment in which work was of great import. With the labor ...
Contributing Partner: UNT Libraries
Neckbones and Sauerfowches: From Fractured Childhood in the Ghetto to Constantly Changing Womanhood in the World
Date: May 2002
Creator: Smith, Starita
Description: A collection of five memoiristic essays arranged about themes of family, womanhood and the African-American community with a preface. Among the experiences the memoirs recount are childhood abandonment; verbal and emotional child abuse; mental illness; poverty; and social and personal change. Essays explore the lasting impact of abandonment by a father on a girl as she grows into a woman; the devastation of family turmoil and untreated mental illness; generational identity in the African-American community. One essay describes the transition from the identity-forming profession of journalism to academia. The last essay is about complicated and conflicting emotions toward patriotism and flag-waving on the part of a black woman who has lived through riots, little known police shootings of students on black campuses, and many other incidents that have divided Americans.
Contributing Partner: UNT Libraries
Metaphors, Myths, and Archetypes: Equal Paradigmatic Functions in Human Cognition?
Date: December 2002
Creator: Kalpakidis, Charalabos
Description: The overview of contributions to metaphor theory in Chapters 1 and 2, examined in reference to recent scholarship, suggests that the current theory of metaphor derives from long-standing traditions that regard metaphor as a crucial process of cognition. This overview calls to attention the necessity of a closer inspection of previous theories of metaphor. Chapter 3 takes initial steps in synthesizing views of domains of inquiry into cognitive processes of the human mind. It draws from cognitive models developed in linguistics and anthropology, taking into account hypotheses put forth by psychologists like Jung. It sets the stage for an analysis that intends to further understanding of how the East-West dichotomy guides, influences, and expresses cognitive processes. Although linguist George Lakoff denies the existence of a connection between metaphors, myths, and archetypes, Chapter 3 illustrates the possibility of a relationship among these phenomena. By synthesizing theoretical approaches, Chapter 3 initiates the development of a model suitable for the analysis of the East-West dichotomy as exercised in Chapter 4. As purely emergent from bodily experience, however, neither the concept of the East nor the concept of the West can be understood completely. There exist cultural experiences that may, depending on historical and ...
Contributing Partner: UNT Libraries
Source Book for a Semester's Study of Language in Twelfth Grade English
Date: January 1970
Creator: Parker, Mildred B.
Description: While most of the current concepts about language may serve as the underlying principles of language study in all English classes, there appears to be a need in the high school curriculum for opportunity to study in concentrated manner the background and the development of the English language, as a subject of intrinsic interest and lifelong appreciation. A logical place for this type of study, offered on an elective basis, would be in one semester of the twelfth grade. Because of the scope and the depth of the study it would be considered an accelerated course. In the following chapters an attempt will be made to write a guide for such a curriculum.
Contributing Partner: UNT Libraries
North American Indian Mythology and Folklore for Secondary School Students
Date: January 1970
Creator: Jackson, Sarah
Description: Through a study of North American Indian folklore and mythology, the non-Indian can at last begin to know the Indian with whom he has shared a continent and to find out something of his religion, traditions, history, humor, and tribal peculiarities. The approach to this study through motifs, already familiar to the students from other literature, offers a practical approach and one that can be adapted to classroom use, perhaps either in the study of myth, the study of literary types, the study of literature per se, or perhaps in the study of cultural differences.
Contributing Partner: UNT Libraries
Clergymen in the Life of Samuel L. Clemens
Date: August 1970
Creator: Coffey, Sandra Jean Williams
Description: This thesis intends to point out the religious thoughts that Clemens encountered. It will present the various religious groups with which he dealt the most and the clergymen with whom he associated both casually and intimately. It will also attempt to indicate at least one reason why he never found in religion the peace which he sought.
Contributing Partner: UNT Libraries
The Personality of John Keats as Revealed in His Letters
Date: January 1970
Creator: Passmore, Billie Sue
Description: Through a careful and thorough analysis of Keats's observations, thoughts and feelings as expressed in his letters, the reader can gain an understanding of the poet's hopes, his fears, his ambitions, his true personality.
Contributing Partner: UNT Libraries
Symbolism, Irony, and Meaning in Selected Fiction of Miguel de Unamuno y Jugo
Date: August 1970
Creator: Moran, Ethel Ruth
Description: This approach to Unamuno does not propose to deny the fact that he was a polemicist, a poet, a teacher, and a philosopher more than he was a writer of fiction or an entertainer. What is intended is to point out to the average reader in simple terms something of the general signification and method in Unamuno's attempt at the art of prose fiction--at least as it appears in translation.
Contributing Partner: UNT Libraries
The Problem of the Hero in Shakespeare's King John
Date: June 1970
Creator: Ratledge, Wilbert Harold
Description: This thesis is an attempt to evaluate the evidence for and against the presence of a hero in King John. As such, it is actually a search into the artistic abilities which Shakespeare exercised in this drama to determine whether he created a dramatic work of art which merits recognition for its own sake.
Contributing Partner: UNT Libraries
English Renaissance Epithalamia
Date: August 1970
Creator: Corse, Larry B.
Description: The classical genre of marriage poems called epithalamia appeared in England in the late sixteenth century. The English epithalamia of the Renaissance form a closely related body of literature. This work will be a close analysis of this small body of English Renaissance poetry.
Contributing Partner: UNT Libraries
Bibliotherapy in the Junior High School
Date: January 1970
Creator: Van Voorhis, Dorothy
Description: Since most teachers have little time to familiarize themselves with a variety of books, this thesis, containing annotations, is designed to acquaint them with a number of books in various areas and to give them an understanding of bibliotherapy, which is one tool of teaching that has been advanced as an aid to students for the past as well as for the future.
Contributing Partner: UNT Libraries
Some Innovations in an Oral Approach to Teaching English to Spanish-Speaking Students: Eighth Grade Level
Date: January 1970
Creator: Woolsey, Normada L.
Description: The aim of this thesis is to suggest how some of the trends mentioned above may be incorporated into a program to help the eighth grade Spanish-speaking student in a predominately English-speaking school, to help the student who has not only given up the idea of getting an education himself, but is considered by his teachers "too late" to reach.
Contributing Partner: UNT Libraries
A Guide to the Teaching of Negro Literature in High School
Date: June 1970
Creator: Tucker, Rose Warren
Description: This paper will be a survey of the major American Negro writers from pre-Civil War days to the present time. Background information concerning each major period will be given, along with information about each author and comments about the selections which are appropriate for classroom discussion. Teachers will also be given suggestions for presenting the material to class, as well as suggested questions and assignments. In conclusion, it will be shown how the literature presented can be fused into the eleventh grade course of study for the Fort Worth Public Schools.
Contributing Partner: UNT Libraries
Dostoyevsky and the Slavophiles
Date: August 1970
Creator: Kingston, Sharon L.
Description: Just to what degree Dostoyevsky's thoughts paralleled those of the Slavophiles will be outlined in subsequent chapters in three major areas--Orthodoxy, Autocracy, and Nationality. Uvarov's old 1828 formula provides a simple outline in which to describe and compare the more complicated core of Dostoyevskyan and Slavophile philosophy.
Contributing Partner: UNT Libraries
The Personification of Death in Middle English Literature
Date: May 1970
Creator: Humphries, Judith G.
Description: This study concentrates on the personification of death in Middle English literature and examines some examples of the literature from the period.
Contributing Partner: UNT Libraries
Southern Protestantism in the Fiction of Flannery O'Connor
Date: January 1970
Creator: Matchette, William Arthur
Description: The main body of the thesis concerns itself with the beliefs and characteristics of Southern Protestantism as they appear in the fiction of Flannery O'Connor.
Contributing Partner: UNT Libraries
A Study of Byron's Approaches to Reality in Don Juan
Date: August 1968
Creator: Sircy, Otice C.
Description: Don Juan was Byron's effort to come to terms with the reality of his own environment, and he demanded the liberty to try to understand life and to present his conclusions without editorial or social oppression. It is an examination of the problem of appearance and reality; as a satire, the poem attacks appearances maintained by hypocrisy by placing them against the background of reality which is apparent to Byron.
Contributing Partner: UNT Libraries
The Role of History in Kenneth Roberts' Novels
Date: January 1969
Creator: Harris, F. Janet
Description: The purpose of this thesis is to evaluate Kenneth Roberts' transmutation of American history into living literature. This examination will cover the following novels: Arundel (1929), The Lively Lady (1931), Rabble in Arms (1933), Captain Caution (1934), Northwest Passage (1937), Oliver Wiswell (1940), and Lydia Bailey (1947).
Contributing Partner: UNT Libraries


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Take control with a 2-21-Day Health Retreat program focused on Advanced Whole-Body Detoxification, weight loss, health education and prevention, & rejuvenation. Experience a fresh start with a 2-21-day Health & Lifestyle Transformation Retreat.
Nova Scotia Accommodation: Campgrounds/RV Parks Located at the beginning of the Historic Cabot Trail, Joyful Journey's is a must visit campground. It has the breathtaking view of the mountains coupled with the amazing views of the ocean.
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- Home
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Old Ravians Union Pakistan is an elected body of former students of GC University, Lahore (previously known Government College Lahore). The Union was established in 1934 and revived in 1995. It is the only organization of Old Ravians which has affiliation of the GC University, Lahore and its office is situated in the Campus. Constitutionally, Vice Chancellor of the GCU, Prof. Dr. Hassan Amir Shah is ex-officio patron of the Union.
Mr. Kamran Lashari, Ex – Federal Secretary, Govt. of Pakistan & Ex - Chairman CDA is President of the Union. All Old Ravians are eligible to apply for membership of the Union. Elections of its various offices take place biennially in the GCU Campus. However, next elections will be held in November 2016.
The Union arrange intellectual, social, cultural and sports events where Old Ravians meet and interact. The Union work to assist and help the University in different fields. It is also an instrumental for collection of funds from the Old Ravians for GCU Endowment Fund Trust which is used to provide financial aid to deserving students and for development of the University. The Union has its affiliated chapters in Karachi, Islamabad, India, UK, US and Canada.
A renowned Pakistan novelist has written: "Lahore as a city inspires the art in all their forms." I would say, GCU is that unique educational institution of Lahore which inspires the arts and all other kinds of creative activities in their best forms.
Having been elected as President of Old Ravians Union, I am provided with a unique honor as well as with an ideal opportunity to inter-act with Old and New friends from the prestigious Government College Lahore.


text:
The last three mute swans in the city's renowned Stanley Park have found a new home after a fourth was killed recently by murderous otters in Lost Lagoon
'I was dreading having to go back home next week without her.' The dog had disappeared; Leonard flew back to China to look, launching a social media campaign
'I would understand if Ringo wasn't registered at all, but he did have a tag. We are diligent dog owners. We respect the laws. We've never had a problem'
Phorids attack by laying eggs inside bees, causing larvae to grow by feeding on a bee's body tissue. After the larvae pupates, it turns into an adult fly
Whale watchers say a battle between orcas and humpback whales appeared to end with the human equivalent of fist waving and name calling, but they can't be sure
When Jack turned 26 in 2015, or maybe he turned 24 or 25, he'd lived a decade beyond the average Yorkshire terrier. He became something of a British animal celebrity
'He was coming in my boat whether I liked it or not, and he was telling me to get out,' Ron Lancour, 70, said of the ill-tempered badger Wednesday
Gimli's patrollers collected 42 garbage bags worth of decomposing fishflies — which smell a lot like decomposing fish. In places, they were ankle-deep
Mounds of ankle-deep fish flies are piling up in the Manitoba town of Gimli where workers are scooping them with shovels and filling dozens of garbage bags at a time
'How did he get in? I don't see an open window'


text:
On my last birthday, my lovely daughter gifted me Bruce Springsteen's autobiography, Born to Run. For any Springsteen fan, it's an absorbing read and even though I had already consumed Peter Ames Carlin's biography Bruce, I learned much about the man's early life and family, and the grind of his early music-making days with his first bands playing along the Jersey shore – many details that only the man himself could know. Though the reviews focussed on the book's revelations about the periods during which he has suffered from depression, for me the most enthralling sections were those where Springsteen describes a couple of hair-raising and eventful road trips across America.
I was reminded that I'd never got round to writing about Springsteen's book when I read a report about President Obama bestowing the Presidential Medal of Freedom (America's highest civilian honour) on Springsteen yesterday in a ceremony at the White House. Springsteen's book is over 500 pages long. Here's the concise version, courtesy of Barack Obama. It's rather good: Continue reading "Barack on Bruce: 'sprung from a cage out on Highway 9'"


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The Trust for Public Land will launch a community design process with neighbors and various community organizations to generate designs to revitalize Lanier Playground in the Grays Ferry section of South Philadelphia.
The Trust for Public Land is working with various community groups to transform the aging recreation center at 37 th and Mt. Vernon streets in Philadelphia's Mantua neighborhood into a vibrant new park.
The people of Ventura's Westside neighborhood needed a park. But with little open space and a very limited budget, they waited years for the right opportunity.
The city of Nogales asked The Trust for Public Land to help build a 20-acre park in a park-poor area of the city on Western Avenue.
El Sereno in East Los Angeles has one of the greatest concentrations of children under five in the county—but not nearly enough parks or playgrounds to serve them.
The Trust for Public Land has been working to bring Fitness Zone® installations to parks across the nation and established the first one in Miami-Dade County in July 2012.
Updates and photos documenting the participatory design process and construction at the William Dick Elementary Schoolyard in Philadelphia.
We are working with the community on the renovation of this vibrant recreation and community center in the St. Hughs neighborhood of North Philadelphia.
The Trust for Public Land worked with community members to develop renovation plans for the existing facilities at this busy Philadelphia recreation center.
The yard at Philadelphia's William Dick Elementary used to flood with every rain. So we transformed the barren asphalt into a storm-proof playground that stays open to the neighborhood after school.


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My Leagues
My Teams
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Help: Mestis live on Scoreboard.com. Follow Mestis 2016/2017 for live scores, final results, fixtures and standings! Live scores on Scoreboard.com: Here you'll find live scores, final results, goal scorers and lineups in match details. In addition, Scoreboard.com provides live team statistics (number of shots on goal, shooting percentage, goalkeeper saves, penalties, power play/shorthanded goals, faceoffs won) and player statistics from top hockey leagues. Standings: Scoreboard.com offers home/away/overall Mestis 2016/2017 standings, form (last 5 matches), over/under and top scorers tables.
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- In Mosul, residents report new terrors as Iraqi forces nearsmdailyjournal.comAl Fallojah
- Mosul civilians report new atrocities as Islamic State girds for onslaught, goes undergroundThe Japan TimesWashington
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The hand played out at around 8:30 PM GMT yesterday evening, and happened at $.02/$.05 6-max NL table Euryalos XI. The table was paused before the action started, and a message was displayed to all players logged in at the time, allowing spectators a chance to open up the table and view the action. When the action was resumed, everyone went all in preflop. Certainly that is the best strategy for a milestone hand, as the bonus amount to be won by the winner of the hand is so large that it is incorrect to fold at any point.
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Find a copy in the library
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The Barclay de Tolly series contains the largest amount of material and consists mainly of typescript and holograph drafts, research notes, and extensive photocopies of bibliographic materials used by Josselson during research for his book The Commander: A Life of Barclay de Tolly. The majority of materials were created or collected by Josselson during the 1970s. Multiple drafts found in this series show extensive revisions to the work and include outlines and bibliographies.
Correspondence is present throughout the papers, but is concentrated in the Personal Series and the Congress for Cultural Freedom (CCF) Series. The Personal Series consists mainly of outgoing letters from Josselson covering a wide range of topics, including the CCF and his book. Incoming correspondence is found mostly in CCF series as are large amounts of news clippings and printed materials.


text:
7 CFR 1291.11 - Audit requirements.
Beta! The text on the eCFR tab represents the unofficial eCFR text at ecfr.gov.
§ 1291.11 Audit requirements.
Each year that a State receives a grant under the SCBGP-FB, the State is required to conduct an audit of the expenditures of SCBGP-FB funds. If the Single Audit Act applies to an eligible grantee, the State shall submit the annual audit results to AMS within 30 days after completion of the audit. If the Single Audit Act does not apply, the State shall conduct an audit of all SCBGP-FB funds no later than 60 days after the end date of the grant agreement. The State shall submit to AMS not later than 30 days after completion of the audit, a copy of the audit results.


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We traveled during Thanksgiving week and found the Inn was very comfortable and clean. The staff was very polite (southern style) :) which we appreciated so much! We can recommend the Inn to anyone who would enjoy a nice place to stay. We will return!
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Avocado, Sausage & Eggs on Toast
Andy Anderson !
Okay… at one of the resturants that I worked at in Chicago, they used to serve this really tasty breakfast dish. They used bacon, but I prefer a good breakfast sausage.
As a matter of fact, you could easily substitute the sausage with bacon, or even ham; or make it healthy, and leave the meat out altogether.
So, you ready… Let's get into the kitchen.
As a matter of fact, you could easily substitute the sausage with bacon, or even ham; or make it healthy, and leave the meat out altogether.
So, you ready… Let's get into the kitchen.
Featured Pinch Tips Video
Be the First
20 Min
15 Min
- 1 large
- avocado, ripe
- 2 medium
- eggs
- 2
- sausage patties, or two slices of bacon, or two slices of ham
- 1/2 tsp
- kosher salt
- 1/2 tsp
- black pepper, freshly ground
- 2 Tbsp
- cheddar cheese, shredded
- 1 tsp
- mustard powder
- 2 slice
- bread or breakfast (english) muffins
Directions Step-By-Step
3Chef's Note: How do you tell if an avocado is ripe?
Press against the skin using your thumb. If it leaves an indentation… it's ripe. If it feels like you're pushing against a brick, it needs a few more days.
4Scoop an area out of the avocado that's just big enough to hold the egg yolk, and a portion of the egg white.
9Using a small serving spoon, carefully place an egg yolk into each of the avocados, and then add as much egg white as you can until the space is full.
11Chef's Tip: The trick here is in keeping the round avocados upright during the baking process. I use a large muffin tin to accomplish this.
12Sprinkle half the salt, pepper, and mustard powder on each of the avocados, and then, to top it off, add half the cheese to each.
13Place in the preheated oven, and then bake for 12 minutes or, if you would like the yolks a bit firmer, keep them in for 15 minutes.
14While the eggs are baking, toast and butter two large slices of bread, and place on individual plates.
17Use a serving spoon, to gently remove the avocado/egg mixture out of the skin, and lay on top of the bread.
19Chef's Note: Many times, when I make this dish, I skip the toast, and meat, pull them out of the oven, and eat them right out of the avocado skin with a spoon… YUM.


text:
Baked elements [electronic resource] : Our 10 Favorite Ingredients. Matt Lewis.
Electronic resources
Record details
- ISBN: 9781613123829 (electronic bk)
- Physical Description: 1 online resource
- Date Published: 2013.
Content descriptions
|Summary, etc.:
| In their third cookbook, Baked Elements: Our 10 Favorite Ingredients, acclaimed authors Matt Lewis and Renato Poliafito present 75 inventive new recipes revolving solely around their 10 most-loved ingredients—from peanut butter and caramel to malt and booze. Lewis and Poliafito celebrate these favorite elements—chocolate, for instance, or bananas—baking each one into a variety of delicious cookies, bars, cakes, milkshakes, and more, sweets perfect for everyday cravings, special occasions, late-night celebrations, and weekend get-togethers. Complete with the signature stories and commentary that fans adore, chapters also include feature-ingredient infographics with quirky facts and charts and helpful Baked notes that make creating these desserts as easy as pie.Praise for Baked Elements:"From the writers of my favorite baking books of all time, a must-own for any baking enthusiast." —Zoe Deschanel"Lewis and Poliafito approach their...
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May 8, 2013
The plaintiffs in this consolidated putative class action allege that the defendants:
(1) violated the Commodity Exchange Act ("CEA"), 7 U.S.C. §§ 1-27f, by intentionally manipulating and artificially inflating the prices of the Intercontinental Exchange ("ICE") Cotton No. 2 futures contracts expiring in May 2011 ("May 2011 Contract") and July 2011("July 2011 Contract"); (2) aided and abetted violations of CEA; (3) violated the Sherman Antitrust Act, 15 U.S.C. §§ 1 and 2, by fixing and inflating, artificially, prices for the May 2011 Contract and July 2011 Contract; and (4) became unjustly enriched by their unlawful acts. On November 28, 2012, the defendants filed a motion to dismiss the consolidated amended complaint. Before the Court are: (1) the plaintiffs' motion, pursuant to Rules 26(c) and 37(a) of the Federal Rules of Civil Procedure, to compel the defendants to produce documents produced previously to the Commodity Futures Trading Commission ("CFTC"); and (2) the defendants' motion, pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, to stay discovery.
Plaintiffs' Contentions
On December 24, 2012, the plaintiffs served their first request for production of documents, which included Document Request No. 3, the subject of the plaintiffs' motion to compel, seeking: "All documents or other information produced by Defendants to the CFTC, and all sworn statements or testimony provided by Defendants to the CFTC, in connection with any investigation of Cotton Contracts relating to the May 2011 Contract and/or July 2011 Contract." The defendants made general objections, including that the plaintiff's first request for production of documents is "premature in light of Defendants' pending motion to dismiss, which seeks dismissal of the action based on legal deficiencies in the Amended Consolidated Complaint." They also made specific objections, contending that Document Request No. 3 is:
(i) overly broad, unduly burdensome, and vague and ambiguous; (ii) to the extent that it seeks information that is neither relevant to the claims or defenses asserted by the parties in this litigation, nor reasonably calculated to lead to the discovery of admissible evidence, or whose relevance is outweighed by the burden Defendants would bear in attempting to review and produce such materials; (iii) to the extent that it seeks documents and information that constitute attorney work product; and (iv) to the extent that it seeks documents and information that are confidential pursuant to applicable regulatory requirements or otherwise protected from disclosure pursuant to applicable law. In particular, Defendants object to the use of the undefined terms "documents or other information." Defendants will interpret this request as seeking documents. Defendants further object to the use of the undefined terms "sworn statements or testimony." Defendants will interpret this request as seeking sworn written statements made by Defendants or their employees, or written transcriptions in Defendants' possession of sworn testimony given by Defendants or their employees to the CFTC.
The plaintiffs contend that their Document Request No. 3 seeks relevant, non-privileged documents and is narrowly-tailored because it "seeks only documents produced by Defendants to the CFTC (which have been previously identified and gathered) relating solely to 'the May 2011 Contract and/or the July 2011 Contract.'" They maintain that the defendants' general objection that the discovery is premature should be overruled, because neither the CEA nor the Sherman Antitrust Act provides an automatic stay of discovery pending a decision on a motion to dismiss. According to the plaintiffs, Document Request No. 3 is not overbroad or unduly burdensome, since no search burden is involved, as the documents requested have already been searched for, gathered and produced previously, and they relate solely to the May 11 Contract and July 2011 Contract. The plaintiffs contend that during the meet and confer process the parties resolved the defendants' "vague and ambiguous" objection concerning the phrase "documents and other information," by agreeing that phrase will "be interpreted to mean 'documents' (as defined by Local Civil Rule 26.3) reflecting sworn statements or sworn testimony made by Defendants or their employees to the CTC." The plaintiffs assert that Document Request No. 3 is relevant because the complaint alleges that the defendants manipulated and conspired to manipulate the prices of the May 2011 Contract and the July 2011 Contract and it seeks documents that were produced by the defendants to the CFTC in connection with its investigation into price manipulation respecting those contracts.
The plaintiffs contend that the defendants waived any privilege objection by failing to comply with Rule 26(b)(5) and Local Civil Rule 26.2(a) and (b) of this court, because, at the time they responded to Document Request No. 3, they did not provide the information required by those rules. Moreover, even if some requested documents are privileged, the privilege had been waived by the previous production of the privileged materials to a third party, the CFTC. With respect to the defendants' objection on the ground of confidentiality, the plaintiffs assert that the defendants failed to articulate any applicable regulatory requirement or law that would prevent production of the requested documents, and any concerns related to confidentiality may be alleviated by a confidentiality order in this action. The plaintiffs request that the Court: (a) overrule the defendants' objections to Document Request No. 3 and order the defendants to produce the responsive documents within 30 days from the date of the order; and (b) find that the defendants waived any privilege objections or, alternatively, order the defendants to prepare a privilege log within 30 days from the date of the order, in accordance with Local Civil Rule 26.2.
Defendants' Contentions
The defendants contend that their motion to dismiss raises substantial grounds for dismissal, warranting a stay of discovery. The complaint alleges unlawful manipulation of the May 2011 and July 2011 cotton future contracts "by means of a manipulative short squeeze" and also that cotton was "very freely available" in the physical market. According to the defendants, the plaintiffs' own allegations preclude their manipulation claim as a matter of law, because "[i]f cotton is freely available, then a responsible [seller] who plans ahead can simply purchase the available cotton and deliver it in satisfaction of its obligations in the futures market." Furthermore, the plaintiffs' claims are premised on legal theories that are not viable. For example, the complaint alleges an antitrust conspiracy under Section 1 of the Sherman Act, but fails to identify any conspirators, beyond the named defendants, who are all part of the same corporate family and are alleged to have acted on behalf of each other. Similarly, the complaint fails to allege a claim under Section 2 of the Sherman Act, because it does not identify any actionable anticompetitive conduct. Moreover, the plaintiffs' unjust enrichment claim fails "because, by Plaintiffs' own admission, futures are express contracts." According to the defendants, these errors are "pure questions of law," warranting "a stay of discovery until these legal issues are decided." The defendants contend that the requested production would be burdensome, and the plaintiffs identify no prejudice they would suffer from a short delay, awaiting the adjudication of the motion to dismiss.
The defendants maintain that, as part of its response to a regulatory inquiry, defendant Louis Dreyfus Commodities LLC ("LDC LLC") produced to the CFTC over 90,000 pages of documents. "Given the breadth of materials typically sought by the government in an investigation, many of the requested documents may have no bearing on the issues in this litigation," and the plaintiffs' request for "all documents," in connection with the May 2011 Contract and July 2011 Contract, is overbroad. The defendants contend that reviewing over 90,000 pages of materials for responsiveness will impose a significant burden on them. Moreover, the materials "produced to the CFTC include commercially sensitive agreements, trading data, correspondence with customers and suppliers, and internal communications regarding strategies and market values." According to the defendants, "LDC LLC made this production pursuant to well-established legal procedures the CFTC has created for handling confidential and sensitive business information," and "[b]y following these procedures, LDC LLC was able to comply with a regulatory inquiry, while protecting the confidentiality of sensitive commercial information." Since the plaintiffs are trading competitors who could use the confidential information to the detriment of the defendants in the marketplace, the defendants objected to the plaintiffs' Document Request No. 3 "to the extent that it purports to seek information" that is confidential. Furthermore, negotiating a confidentiality order "could result in a considerable burden on the Defendants." The defendants maintain that "[i]dentifying sensitive material and taking appropriate steps to protect it would be time-consuming and costly," and they did not waive any privilege when "LDC LLC made productions to the CFTC in the spirit of cooperation, and provided materials that Defendants created to assist the CFTC with its investigation."
The defendants contend that the plaintiffs seek discovery for an improper purpose, namely, as they indicated in their December 14, 2012 letter to the Court, to replead their claims "with the benefit of the CFTC documents." The defendants ask that the plaintiffs' motion to compel be denied and their motion to stay discovery granted.
Plaintiffs' Response to the Defendants' Motion
The plaintiffs contend that the defendants conceded they have no search burden, and they failed to provide any specific facts that constitute good cause for a protective order. For example, the defendants did not address: (a) whether they created an index to and detailed outline of their previous production of documents to the CFTC; (b) whether documents produced to the CFTC are searchable electronically or, if not, are easily converted into an electronically searchable format; or (c) the estimated time and costs of an optional "re-review." According to the plaintiffs, "90,000 pages is a small fraction of the documents in other cases." The plaintiffs contend that the defendants did not assert any attorney-client privilege and they waived the work-product doctrine protection with respect to the requested documents. Furthermore, the defendants failed to obtain a non-waiver agreement with the CFTC and have not asserted that they share a common interest with the CFTC. The plaintiffs are willing to agree that the production will be for attorney's eyes only and to return any documents that should not have been produced.
The plaintiffs contend that the defendants failed in their attempt to show that their motion is a "pure legal motion," since their motion "depends heavily on Defendants' characterization of the plausibility of Plaintiffs' allegations," and they did not show that their motion is likely to succeed or it is "inevitable" that the plaintiffs' claims lack merit. Moreover, delaying production of the requested documents will prejudice the plaintiffs with respect to the availability of documents from the non-parties who dealt with the defendants, the passage of a two-year statute of limitations as to the John Doe defendants and the quality of witnesses' memories. The stay would also delay the plaintiffs' ability to issue document preservation subpoenas to non-parties who dealt with the defendants and those non-parties could fail to retain or destroy their relevant documents in the interim. Similarly, memories fade with the passage of time. Thus, the plaintiffs contend, the avoidance of prejudice militates against a stay.
Defendants' Reply
The defendants contend that "[t]o the extent that a motion to dismiss is based 'on pure questions of law' as opposed to 'the sufficiency of the facts alleged,' that is merely a factor that weighs in favor of a stay." The plaintiffs speculate that a brief stay of discovery will prevent them from naming as defendants the "John Doe" conspirators, whose identities they hope to uncover through the requested documents, but they "make no allegations supporting a CEA claim against the John Does; they only argue that an unspecified 'agreement' or 'understanding' by 'unknown co-conspirators' constituted an antitrust conspiracy, . . . which is subject to a four-year statute of limitations." According to the defendants, the plaintiffs' generic harms they would allegedly suffer from a brief stay of discovery are not different from a stay in any litigation, and these factors, while relevant if the stay is for an extended period, are not significant here because the motion to dismiss has been briefed and oral arguments have been scheduled for May 17, 2013. Moreover, the defendants' review of the requested documents is not optional, since the plaintiffs, recognizing the ovebreadth of their request, now seek only documents produced to the CFTC that relate solely to May 2011 Contract and the July 2011 Contract. The defendants assert that, "assuming that search terms would reduce the number of pages that need to be reviewed to roughly 63,000 (70% of 90,000 total pages), and that an attorney could, on average, review each page as quickly as a minute, that would take over 1000 attorney hours," which "could cost $250,000 in attorney fees" at the prevailing hourly rates in this district. The defendants contend that such a burden is not justified given that the plaintiffs failed to identify "any real prejudice."
Legal Standard
"Parties may obtain discovery regarding any non-privileged matter that is relevant to any party's claim or defense. . . . Relevant information need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence." Fed. R. Civ. P. 26(b)(1). "[T]he scope of discovery under Fed. R. Civ. P. 26(b) is very broad, 'encompass[ing] any matter that bears on, or that reasonably could lead to other matter that could bear on, any issue that is or may be in the case.'" Maresco v. Evans Chemetics, Div. of W. R. Grace & Co., 964 F.2d 106, 114 (2d Cir. 1992) (quoting Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 351, 98 S. Ct. 2380, 2389 (1978)).
"A party may serve on any other party a request within the scope of Rule 26(b)" to produce "any designated documents or electronically stored information" or "any designated tangible things." Fed. R. Civ. P. 34(a)(1). "On notice to other parties . . . . a party may move for an order compelling disclosure or discovery." Fed. R. Civ. P. 37(a)(1). Motions to compel, pursuant to Fed. R. Civ. P. 37, are left to the sound discretion of the district court. See United States v. Sanders, 211 F.3d 711, 720 (2d Cir. 2000).
"A party or any person from whom discovery is sought may move for a protective order. . . . The court may, for good cause, issue an order to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense . . . . " Fed. R. Civ. P. 26(c)(1). "The party seeking a protective order bears the burden of establishing that good cause for the order exists." Duling v. Gristede's Operating Corp., 266 F.R.D. 66, 71 (S.D.N.Y. 2010). "Broad allegations of harm, unsubstantiated by specific examples or articulated reasoning, do not satisfy the Rule 26(c) test. Moreover, the harm must be significant, not a mere trifle." Id. (citation omitted).
Good cause may be shown where a party has filed a dispositive motion, the stay is for a short period of time, and the opposing party will not be prejudiced by the stay. However, while discovery may in a proper case be stayed pending the outcome of a motion to dismiss, "the issuance of a stay is by no means automatic." Two related factors a court may consider in deciding a motion for a stay of discovery are the breadth of discovery sought and the burden of responding to it. Finally, a court should also consider the strength of the dispositive motion that is the basis of the discovery stay application.
Spencer Trask Software & Info. Servs., LLC v. RPost Int'l Ltd., 206 F.R.D. 367, 368 (S.D.N.Y. 2002) (internal citations omitted).
A court has broad discretion to decide whether a protective order is warranted. See Duling, 266 F.R.D. at 72.
Application of Legal Standard: Defendants' Motion to Stay Discovery
The defendants' motion to dismiss, filed on November 28, 2012, prior to the plaintiffs' first request for the production of documents, is briefed and scheduled for oral arguments, before the assigned district judge, on May 17, 2013. See Docket Entry No. 54. The defendants seek to stay discovery until the adjudication of their motion to dismiss. Thus, the stay requested is for a short period of time, until the assigned district judge issues his decision on the defendants' motion to dismiss.
Although courts in this circuit, in determining a motion to stay discovery pending a motion to dismiss, have considered whether the motion to dismiss has "substantial grounds" or "[does] not appear to be without foundation in law," Chrysler Capital Corp. v. Century Power Corp., 137 F.R.D. 209, 210-11 (S.D.N.Y. 1991), the Court believes that these considerations are appropriate where the same court is deciding both the motion to stay discovery and the motion to dismiss. See id. at 211 (staying discovery pending decision on the motion to dismiss after finding that the discovery requests are extensive, the motion to dismiss has substantial grounds and the plaintiffs failed to demonstrate "extraordinary prejudice to them."); Gandler v. Nazarov, No. 94 Civ. 2272, 1994 WL 702004, at *4 (S.D.N.Y. Dec. 14, 1994) (staying discovery pending a motion to dismiss based on the finding that the "motion to dismiss based on lack of personal jurisdiction is potentially dispositive, and appears to be not unfounded in law," the plaintiffs did not present "any evidence to suggest that they will be unfairly prejudiced by a stay," and the stay "might avoid the need for costly and time-consuming discovery."); In re Currency Conversion Fee Antitrust Litig., No. MDL 1409, M21-95, 2002 WL 88278, at *2-3 (S.D.N.Y. Jan. 22, 2002) (granting partially a motion to stay discovery pending a motion to dismiss, even though the defendants failed to convince the court that their motion to dismiss "will be dispositive of all claims," but "given the number of parties to this action and the substantial cost of discovery typical of antitrust cases of this magnitude," and because the plaintiffs failed to demonstrate "any unfair prejudice" from the stay); Spencer, 206 F.R.D. at 368 (staying discovery pending a motion to dismiss, which appears "to have substantial arguments for dismissal of many, if not all, of the claims," because "the expense and possible injury to the success of defendants' current contractual negotiations [with a third party] are great."). However, where different courts are deciding the stay motion and the motion to dismiss, it is a waste of judicial resources for the court deciding the stay motion to consider the strength of the motion to dismiss as a factor in determining the stay motion, because it represents an unnecessary and unjustified duplication of efforts. See, e.g., Johnson v. New York Univ. School of Educ., 205 F.R.D. 433, 434 (S.D.N.Y. 2002) (granting a motion to stay discovery pending a motion to dismiss without any analysis). Accordingly, instead of considering the strength of the defendants' motion to dismiss, the Court will consider the fact that the defendants "filed a dispositive motion," see Spencer, 206 F.R.D. at 368, and other factors relevant to the defendants' motion.
Breadth of Discovery and the Burden of Responding to It According to the defendants, "LDC LLC produced over 90,000 pages of documents to the CFTC in response to the subpoena," and it would need "to review every previously produced document to identify commercially sensitive material that might disclose trade secrets or similar business information," which could "take over 1000 attorney hours" and "cost at least $250,000 in attorney fees." Although the plaintiffs assert that "only a fraction of the amount of documents is at issue," they do not specify to what amount, in this action, "a fraction" refers. That "90,000 pages is a small fraction of the documents in other cases" is irrelevant and does not demonstrate whether 90,000 is "a small fraction" of the documents requested in this action. Notwithstanding the defendants' failure to specify the exact number of pages produced to the CFTC and the inconsistency of their submissions, compare Docket Entry No. 49, Stephen Ehrenberg Decl.¶ 3 ("over 90,000 pages") with Docket Entry No. 55, Defs.' Reply 9 ("90,000 total pages"), the Court finds that 90,000 pages is not an insignificant number of pages to review, and it appears that the defendants' production to the CFTC possibly exceeded that number.
The parties disagree about whether the defendants waived their attorney work-product protection by producing documents in response to the CFTC subpoena that are the subject of the plaintiffs' Document Request No. 3. Thus, the defendants' position on waiver of the attorney work-product protection would necessitate their review of "over 90,000 pages of documents" produced to the CFTC. The defendants estimate that it would take them "over 1000 attorney hours" to review "each page in as quickly as a minute," which is a considerable amount of time. Moreover, the parties appear to agree that confidentiality concerns may be remedied by a stipulated confidentiality order. Negotiating such an order would require the expenditure of time in addition to that which would be expended by the defendants' in reviewing "over 90,000 pages." The Court finds that the burden associated with responding to the plaintiffs' Document Request No. 3 is significant.
Prejudice from the Stay The plaintiffs assert that prejudice will attend them from staying discovery because of the potential expiration of the statute of limitations with respect to their claim of "conspiracy which was carried out by many parties, including some parties who, based on present information, are yet to be named. Amended Complaint ¶ 17." The consolidated amended complaint, at ¶ 17, names John Does 1-10 as "other persons, whose identities are unknown to Plaintiffs," and who are "affiliates or associates" of the defendants. The plaintiffs contend that the defendants' "unlawful conduct took place almost two years ago, beginning in March 2011." Assuming that:
(1) the plaintiffs cannot meet the requirements of Fed. R. Civ. P. 15(c) to avoid any applicable statute of limitations bar, see Aslanidis v. United States Lines, Inc., 7 F.3d 1067, 1075 (2d Cir. 1993) ("'John Doe' pleadings cannot be used to circumvent statutes of limitations" and amending the complaint to replace John Doe with a named party "may only be accomplished when all of the specifications of Fed. R. Civ. P. 15(c) are met."); and (2) the plaintiffs' contention that the two-year statute of limitations started running in March 2011 is true, the plaintiffs appear to be outside of the purported statute of limitations period, since two years from March 2011 had expired by the time the plaintiffs' motion to compel discovery was briefed. Consequently, it does not appear that denying the defendants' motion for a stay will eliminate potential statute of limitations issues with respect to the conspiracy claims against John Does 1-10.
The plaintiffs' assertions that: (1) witnesses' memories fade with the passage of time; and (2) the potential exists for relevant documents to be destroyed by non-parties, are the usual
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How did you meet your SO/DH?
Qotd - 3/27/13
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