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United States District Court, S.D. New York
April 21, 2015
C.L., by and through his next friend, K.L.; M.P., by and through her next friend, T.P.; A.C., by and through her next friends, N.F. and R.C.; B.J., by and through her next friend, L.J.; P.S., by and through his next friends, F.N. and C.S.; H.W., by and through her next friend, A.W.; N.W., by and through his next friend, A.W., Plaintiffs,v.HASTINGS-ON-HUDSON UNION FREE SCHOOL DISTRICT; ROY R. MONTESANO, SUPERINTENDENT OF SCHOOLS; DEBORAH AUGARTEN, DIRECTOR OF SPECIAL EDUCATION SERVICES; HASTINGS-ON-HUDSON BOARD OF EDUCATION; NEW YORK STATE EDUCATION DEPARTMENT; JOHN R. KING, JR., COMMISSIONER OF EDUCATION, Defendants.
NELSON S. ROMN, District Judge.
Plaintiffs C.L., M.P., A.C., B.J., P.S., H.W., and N.W. ("Plaintiffs"), through their above-captioned representatives, commenced this action by complaint filed June 18, 2014 (dkt. no. 1) and amended October 15, 2014 (dkt. no. 13). The amended complaint (the "Complaint") assetts causes of action against defendants Hastings-on-Hudson Union Free School District (the "District"), Roy R. Montesano, Deborah Augarten, and the Hastings-on-Hudson Board of Education (collectively, the "District Defendants"), and against the New York State Education Department and John R. King, Jr. (together, the "State Defendants").
Count One asserts a violation of the Individuals with Disabilities Education Act ("IDEA"), 20 U.S.C. §§ 1400-82, against the District Defendants and the State Defendants. Count Two asserts a violation of Article 89 of the New York Education Law, N.Y. Educ. L. §§ 4401-4410-c, against the District Defendants. Count Three asserts a violation of Section 504 of the Rehabilitation Act, 29 U.S.C. § 794, against the District Defendants and the State Defendants. Count Four asserts a violation of Title II of the Americans with Disabilities Act ("ADA"), 42 U.S.C. § 12132, against the District Defendants and the State Defendants.
Plaintiffs seek declaratory and injunctive relief on these claims, including a comprehensive assessment of the District's compliance with the IDEA and other special education laws-laws designed to ensure that children who are disabled, as Plaintiffs are, receive appropriate special education and related services-and a corrective action plan to remedy perceived systemic defects in the District's provision of such education.
The District Defendants and the State Defendants both now move to dismiss the Complaint pursuant to Federal Rule of Civil Procedure 12(b)(1), for lack of subject matter jurisdiction. The State Defendants also move to dismiss claims against them pursuant to Rule 12(b)(6), for failure to state a claim upon which relief can be granted. For the following reasons, the Court DENIES the Rule 12(b)(1) motions, but GRANTS the State Defendants' Rule 12(b)(6) motion.
For purposes of this opinion the Court accepts as true all well-pleaded factual allegations in the Complaint and draws all reasonable inferences in Plaintiffs' favor. The Complaint describes each plaintiff's disability and alleges that Plaintiffs, and others, systematically have been denied access to free appropriate public education that meets developmental needs, in contravention of the IDEA and other statutes. See Complaint ("Compl.") ¶ 2. Defendants allegedly have, among other things: "(1) failed to properly classify children who are deemed disabled and eligible to receive special education and related services and made predeterminations with respect to children's classifications; (2) declined to consider opinions of independent evaluators during Committee on Special Education (CSE') meetings; (3) discouraged meaningful parent, teacher, and service provider participation at CSE meetings; (4) denied the provision of requested services on erroneous grounds or without any basis; (5) failed to provide special education and related services as required by Plaintiffs' respective individualized education programs (IEPs') and to ensure that these missed special education and related services (herein, missed services') are made up within a reasonable period of time; (6) changed special education and related services without first providing parental notification of said changes; (7) provided special education and related services of substandard quality; (8) compelled Plaintiffs to forego educational opportunities to which they were entitled in order to receive special education and related services; and (9) refused to conduct reevaluations upon parental request." Id. ¶ 4.
Specific examples of these actions and omissions are given. For instance, one plaintiff repeatedly was denied necessary speech therapy sessions, and another was denied occupational therapy sessions to which she was entitled. Id. ¶ 5. Notably, however, the Complaint alleges that particular violations concerning the particular plaintiffs who have commenced the action are the "tip of the iceberg, " and that Defendants' actions and omissions also have violated other disabled children's rights "on a broader, systemic basis." Id. ¶ 6. Systemic failures purportedly are adversely affecting more than 182 children at this time. Id. ¶ 8.
As factual support for the contention that systemic deficiencies are present, and that systemic relief is needed, the Complaint describes an "atmosphere of fear and intimidation" created during defendant Deborah Augarten's tenure as Direct of Special Education Services for the District. Id. ¶¶ 6, 40, 47. The Complaint cites numerous complaints from parents, District staff, and outside specialists regarding Augarten, and a failure by the other District Defendants to address these complaints. Id. ¶¶ 7, 43. The Complaint gives substantial anecdotal evidence of obstructionism and unresponsiveness by Augarten and the District, id. ¶¶ 49-57, and cites what arguably is circumstantial evidence of a pervasive problem in the District, including parental survey results showing dissatisfaction, shrinking budgets for special education (not seen in comparable districts), declining enrollment by disabled students (same), and a declining disability classification rate (same), see id. ¶¶ 60-66. The Complaint then describes how systemic problems manifested in the case of each individual plaintiff. See id. ¶¶ 88-143.
In contrast to allegations directed toward the District and the District Defendants, the Complaint largely is silent on the State Defendants' role. The New York State Education Department (the "SED") allegedly "is responsible for overseeing the provision of public education in New York State, " id. ¶ 23, and John R. King, Jr. serves as the State Commissioner of Education, id. ¶ 24. The Complaint alleges that at least three complaints were filed with the SED since 2009, at least two of which were adjudicated and decided against Hastings. Id. ¶ 69. Apparently under State oversight after those adjudications, the District was required to take corrective action pursuant to a "compliance assurance plan." Id. Allegedly, the plan and the SED focused narrowly on addressing only the complainants' problems, and did not undertake systemic remedial measures, despite one family specifically complaining about the pervasiveness of missed services in the District. Id. Judging, however, by the Complaint's silence as to other reports to the State of systemic failures, those reports did not happen, but rather, parents voiced their grievances at the District level. See, e.g., id. 70-75 (discussing Hillside Elementary School teachers' memorandum detailing general complaints about systemic problems which was shared with District Superintendent Montesano). The Complaint nevertheless appears to name the State Defendants (encompassed within "Defendants") on the federal Counts One, Three, and Four, based on the State Defendants' failure to ensure the District's compliance with the IDEA, the Rehabilitation Act, and the ADA.
"A case is properly dismissed for lack of subject matter jurisdiction under Rule 12(b)(1) when the district court lacks the statutory or constitutional power to adjudicate it." Nike, Inc. v. Already, LLC, 663 F.3d 89, 94 (2d Cir. 2011) (internal quotation omitted). "A plaintiff asserting subject matter jurisdiction has the burden of proving by a preponderance of the evidence that it exists." Morrison v. Nat'l Australia Bank Ltd., 547 F.3d 167, 170 (2d Cir. 2008). In assessing whether there is subject matter jurisdiction, the Court must accept as true all material facts alleged in the complaint, Conyers v. Rossides, 558 F.3d 137, 143 (2d Cir. 2009), but "the court may resolve [any] disputed jurisdictional fact issues by referring to evidence outside the pleadings such as affidavits, Zappia Middle E. Contr. Co. v. Emirate of Abu Dhabi, 215 F.3d 247, 253 (2d Cir. 2000).
Under Rule 12(b)(6), the inquiry is whether the complaint "contain[s] sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.'" Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)); accord Hayden v. Paterson, 594 F.3d 150, 160 (2d Cir. 2010). The Court, again, must take all material factual allegations as true and draw reasonable inferences in the plaintiff's favor, but the Court is "not bound to accept as true a legal conclusion couched as a factual allegation.'" Iqbal, 556 U.S. at 678 (quoting Twombly, 550 U.S. at 555). "While legal conclusions can provide the framework of a complaint, they must be supported by factual allegations." Id. at 679. When there are well-pleaded factual allegations in the complaint, "a court should assume their veracity and then determine whether they plausibly give rise to an entitlement to relief." Id. A claim is facially plausible when the factual content pleaded allows a court "to draw a reasonable inference that the defendant is liable for the misconduct alleged." Id. at 678.
A. Rule 12(b)(1) Motions
The District Defendants and the State Defendants move to dismiss the three federal claims-the IDEA, Rehabilitation Act, and ADA claims-for lack of subject matter jurisdiction, on grounds that each of the individual plaintiffs failed to exhaust administrative remedies. All Plaintiffs concede that they did not exhaust those remedies, namely, by requesting a due process review and hearing at the school district level, to address individual grievances.
"It is well-settled that the IDEA requires an aggrieved party to exhaust all administrative remedies before bringing a civil action in federal or state court." J.S. ex rel. N.S. v. Attica Central Schools, 386 F.3d 107, 110 (2d Cir. 2004). The process includes review by an impartial due process hearing officer and an appeal from that hearing. 20 U.S.C. § 1415(f), (g). Parents may request a hearing to present complaints relating to the "identification, evaluation, or educational placement of the child, or the provision of a free appropriate public education." 20 U.S.C. § 1415(b)(6). In New York, upon notice of a request to the school district, the local board of education appoints an impartial hearing officer under a rotational selection process. The hearing officer issues a written decision which can be appealed to a state review officer of the New York Education Department. The state review officer's decision is final. 8 N.Y.C.R.R. § 200.5(i), (j).
The exhaustion requirement also applies where plaintiffs seek relief under other federal statutes when relief also is available under the IDEA. Attica Central Schools, 386 F.3d at 112 (citing 20 U.S.C. § 1415(l)). Thus, here, the Rule 12(b)(1) motions on the Rehabilitation Act and ADA claims rise and fall with the motion on the IDEA claim. See id. This makes good sense, as an ulterior rule might allow Plaintiffs to circumvent the exhaustion requirement by having asserted other statutory claims.
Significantly, the IDEA exhaustion requirement is excused when exhaustion would be futile, which is the case where administrative procedures do not provide an adequate remedy. Taylor v. Vermont Dep't of Educ., 313 F.3d 768, 788-91 (2d Cir. 2002). Plaintiffs bear the burden of proving such futility, Polera v. Bd. of Educ. of the Newburgh Enlarged City Sch. Dist., 288 F.3d 478, 488 n. 8 (2d Cir. 2002), but courts within the Second Circuit have deemed that burden met and have excused exhaustion where systemic violations are alleged, Attica Central Schools, 386 F.3d at 113 (collecting precedents). The rationale for so holding is that it is futile to complete the administrative review process where a hearing can, at most, redress an individual child's grievance and cannot thereby cure systemic failures. Id.
Having carefully considered the parties' submissions and all arguments therein, this Court agrees with Plaintiffs' contention that this case falls squarely within the "systemic failures" exception to the exhaustion requirement. Id. at 113 (the Second Circuit "excuse[s] exhaustion of administrative remedies in cases that include allegations of systemic violations"); see also M.H. ex rel. K.H. v. Mt. Vernon City Sch. Dist., No. 13-cv-3596, 2014 U.S. Dist. LEXIS 32620, at *6 (Mar. 3, 2014) (S.D.N.Y.) ("allegations of systemic failures render exhaustion futile [and] the Court excuses plaintiffs' failure to exhaust on that basis").
The Complaint is rife with allegations that systemic, pervasive failures have manifested within the District's special education program. Defendants attempt to frame the case as one implicating only eight individuals whose disabilities and grievances are not monolithic. Indeed the case is not a class action, and Plaintiffs' disabilities and grievances vary. But the Complaint states in multiple places that Plaintiffs' experiences represent an endemic problem within the District.
At this stage of the proceedings, the Court is obligated to accept as true all well-pleaded allegations. Having scrutinized the Complaint, the Court finds the "systemic failures" contention to be supported adequately with factual allegations whose truth must be assumed. Anecdotal descriptions of the atmosphere of intimidation, coercion, and unresponsiveness under Augarten's watch (and largely at her behest) are one example. Adding to those descriptions are allegations of teacher coalition-sponsored memoranda summarizing pervasive problems, adverse budget, enrollment, and classification trends, and survey results demonstrating widespread dissatisfaction. Defendants argue that much of the alleged evidence, in particular, the trends and the survey results, is spurious and can be explained away. But an inference of endemic special education failures is at least equally plausible. There need only be fact-based systemic failure allegations to establish prima facie the futility of exhausting administrative remedies, and the Court sees many in the Complaint.
Accordingly, the Court denies the District Defendants' and the State Defendants' motions to dismiss the IDEA, Rehabilitation Act, and ADA claims for lack of subject matter jurisdiction. The Court likewise denies the District Defendants' Rule 12(b)(1) motion to dismiss Count Two, the New York Education Law claim, over which the Court will continue to exercise supplemental subject matter jurisdiction.
B. Rule 12(b)(6) Motion
For the three claims asserted against the State Defendants, Plaintiffs theory is that those defendants failed adequately to oversee the District and to ensure special education compliance, thus rendering the State potentially liable for District-level failures. See, e.g., Compl. ¶ 150. For its part, the IDEA requires State Defendants to ensure that "(i) the requirements of [the statute] are met; and (ii) all educational programs for children with disabilities in the State, including all such programs administered by any other State or local agency (I) are under the general supervision of individuals in the State who are responsible for educational programs for children with disabilities; and (II) meet the educational standards of the State educational agency." 20 U.S.C. § 1412(a)(11)(A).
Plaintiffs therefore correctly note that the State may not abdicate wholesale its oversight duties. See Straube v. Fl. Union Free Sch. Dist., 801 F.Supp. 1164, 1179 (S.D.N.Y. 1992) ("The State bears ultimate responsibility for ensuring that every child has an appropriate placement... is essentially responsible for the actions taken by the local agency."). Equally true, however, is the State Defendants' assertion that the State has considerable discretion in exercising its supervisory and monitoring authority under the IDEA. See A.A. ex rel. J.A. and Franklin Alvarez v. Philips, 386 F.3d 455, 459 (2d Cir. 2004) (noting the absence of specific guidance within the IDEA on how the State should ensure local compliance).
Dispositive here is the Complaint's near-silence regarding notice provided the State Defendants of the allegedly systemic failures within the District. Plaintiffs argue that discontent among parents was widespread, and widely voiced, but there are virtually no specific allegations in the Complaint supporting an inference that discontent trickled up to the State. See, e.g., Compl. ¶ 75 (teacher coalition and parent grievances reported at District level), ¶ 82 (same for group letter from service providers). Plaintiffs allege "numerous due process complaints and lawsuits" filed, which reflected systemic problems. But that at most suggests the State was on constructive notice of problems, and Plaintiffs submit no authority supporting the conclusion that constructive notice is sufficient to compel State intervention.
The authorities upon which Plaintiffs rely, rather, demonstrate the Second Circuit's and this Court's focus on actual notice provided the State. See, e.g., N.Y. State Educ. Dep't., 87 Fed.App'x 216, 217 (2004) (noting the absence of record proof that the State received notice of certain IDEA violations, which violations were not documented in a written report the SED did receive, and thus affirming the district court's finding that those violations did not support an IDEA claim against the State); Mt. Vernon City Sch. Dist., 2014 U.S. Dist. LEXIS 32620, at *34-35 ("[W]hen, as here alleged, the SED-which is the state education agency in this case- has identified and detailed a district's failures to meet state-imposed targets for performance in special education, courts have found the SED a proper defendant to an action to compel the district's compliance with the IDEA." (emphasis added)).
The sole actual notice upon which Plaintiffs rely is described in a single subparagraph in the Complaint, which asserts that "[a]t least three state complaints were filed with the NYSED since 2009." Compl. ¶ 69. Immediately following that assertion, the Complaint concedes that at least two of the three complaints "were adjudicated and decided against Hastings" at the State administrative level. Id. In other words, for those two complaints, the process worked. Because of the SED adjudicators' adverse decisions against the District, a compliance assurance plan was put in place. Id. The Complaint asserts that the plan redressed the individual students' grievances, but did so narrowly and without curing broader systemic failures. Id. Fatally, however, the only notice of systemic failures allegedly provided the State was one complainant's statement that, "It became clear to us, from our own experience and from experiences shared by district families, that students frequently miss mandated services in Hastings." Id. This is the sum total of Plaintiffs' assertion that the State Defendants had actual notice of systemic failures within the District, failed to intervene or otherwise compel remedial action, and thus are liable under the IDEA.
Plaintiffs thus, in briefing, place great weight on the one complainant's statement. But this is an awfully thin reed to stand on, especially when the authorities Plaintiffs cite are unsupportive or distinguishable. See N.Y. State Educ. Dep't, 87 Fed.App'x at 217 (generalized failures within District do not support State liability where not memorialized in a report provided the State); Mt. Vernon City Sch. Dist., 2014 U.S. Dist. LEXIS 32620, at *34-35 (an IDEA claim may proceed against the State because the State had "identified and detailed" the district's systemic failures, and yet had not redressed them). Further, the State Defendants have cited publicly-available, judicially-noticeable information suggesting the District actually was meeting the federal government's IDEA benchmarks. Even if that information was inaccurate, the presence of the information in the public domain undercuts the notion that the State was on notice of a systemic problem because of one parent's complaint to that effect.
The Court concludes that the Complaint lacks well-pleaded allegations supporting an inference that the State Defendants were on notice of systemic failures in the District. Absent such notice, there is no vicarious State liability under the IDEA. Beard v. Teska, 31 F.3d 942, 954 (10th Cir. 1994). As such, the IDEA claim against the State Defendants does not survive Rule 12(b)(6) scrutiny.
As for the Rehabilitation Act and ADA claims, their requirements are substantially identical to one another, [1] and courts thus "consider these claims in tandem." Rodriguez v. City of N.Y., 197 F.3d 611, 618 (2d Cir. 1999). Courts routinely dismiss claims brought under Rehabilitation Act Section 504 and the ADA when IDEA claims are dismissed on the same grounds. See, e.g., M.K. ex rel. Mrs. K. v. Sergi, 554 F.Supp.2d 175, 195 (D. Conn. 2008) (granting State defendants' motion for summary judgment on IDEA, ADA, and Rehabilitation Act Section 504 claims).
The Complaint contains no unique allegations supporting the Rehabilitation Act and ADA claims, but rather, incorporates by reference the breadth of the Complaint and the IDEA allegations. Compl. ¶¶ 155-60. Accordingly, the Court finds that the Rehabilitation Act and ADA claims against the State Defendants fail for the same reason the IDEA claim fails against those defendants-absent notice, there is no vicarious State liability. See Rodriguez, 197 F.3d at 619 (the State must adhere to the ADA's and Rehabilitation Act's non-discrimination requirements for services the State provides, and safety monitoring is not such a service); see also R.B. ex rel. L.B. v. Bd. of Educ. of the City of N.Y., 99 F.Supp.2d 411, 419 (S.D.N.Y. 2000) ("bad faith or gross misjudgment" required for Rehabilitation Act Section 504 and ADA claims in special education context); Scaggs v. N.Y. Dep't of Educ., No. 06-cv-0799, 2007 U.S. Dist. LEXIS 35860, at *54 (E.D.N.Y. May 16, 2007) ("something more than a mere violation of the IDEA is necessary in order to show a violation of Section 504 in the context of educating children with disabilities, i.e., a plaintiff must demonstrate that a school district acted with bad faith or gross misjudgment").
In sum, the Court grants the State Defendants' Rule 12(b)(6) motion to dismiss the IDEA, Rehabilitation Act, and ADA claims against them on the grounds that the Complaint lacks sufficient allegations regarding State-directed failures, notice of District failures provided the state, or bad faith or gross misjudgment on the State's part.
The Rule 12(b)(1) motions are DENIED in their entirety, but the State Defendants' Rule 12(b)(6) motion is GRANTED in its entirety. The Clerk of Court is respectfully requested to terminate the motions at docket numbers 15 and 23, and to terminate the State Defendants (i.e., the New York State Education Department and John R. King, Jr., Commissioner of Education) from the action. The District Defendants are directed to answer the Complaint on or before May 15, 2015.
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Thread: game Cpanel
09-15-2009, 06:42 AM #1Newbie
- Join Date
- Sep 2009
- Posts
- 19
game Cpanel
Hey All,
Could i please have thoughts on what clients would like to see in a GSP's Game server C Panel.
i know of TCAdmin, and swift panel however swift panel is Linux based and tcadmin is windows based.
Some games do not support linux so then you turn to tcadmin but then on other hand 90% of games support linux and not windows!
Is there a multi os support cpanel on the market as of yet?
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subset: commoncrawl


text:
|This is a discussion on PokerRoom - urrrrr within the online poker forums, in the Poker Rooms section; Just been playing an MTT for the last hour at PokerRoom *spit*. Was doing rather well, had more than trebled my chip count and was
PokerRoom - urrrrr
Just been playing an MTT for the last hour at PokerRoom *spit*. Was doing rather well, had more than trebled my chip count and was in the top 15%. Then the whole thing just freezes up. I can't even close the window.
I close the program down and try to get back in, but it says "Patch failed: the patch server stopped responding."
I phone support, who say they can't access the server either. They suggest phoning back in an hour. I'm in the middle of a tournament!
I'm reassured that I'll get a refund. Great, like that compensates for it.
Does this happen at any other sites? I've played a bit at PartyPoker but it never happened there.
I've never had what you've just explained happen to me. But software is software, so it could happen anywhere, really. It may not make up for where you were at in the tourney, but at least getting your money back means you didn't lose it.
I just managed to get back in, about an hour and a half later. Of course I'd been blinded out and finished just outside the money. Funny thing was, there were still some players in the tourney (down to last 3 tables) so not everyone could have been disconnected. Anyway I've written to support asking for a refund proportional to my chip stack, i.e. 3 times the buy-in. This is only fair because presumably they wouldn't compensate people who'd busted out already. We'll see how I get on.
The thing with Pokerroom is that it's the only poker site that I know of that you can play anywhere because you don't have to download it. However, since it's entirely Web based, you are going to have problems as any other web site. So, play and deposit with caution.
I have had a lockup during a tourney at Party. It stopped in the middle of a hand and there was no action for at least ten minutes. Then it started running again and carried on as if nothing had happened.
Oddly, the chat box was still working and we players were able to talk throughout. One of the other guys said it wasn`t unusual at Party and he`d seen it before, but I don`t know if that`s true. I have never seen any other major glitch there, before or since.
This happened to me when I was in the Euro daily and we were down to 16 (about 200 in total) people, I was 3rd in chips when they had a server meltdown and there were a very few people who got to continue and blind the others out... I ended in 11 or 12 and after a week of explaining my situation, the best they did was refund a ticket...
I was playing on holdempoker.com which is a skin of ongame, I believe once the tournament is final, they are final which was a bummer as they could atleast evaluate the situation and possibly chop the pot which is what I thought would be a fair solution when they have server problems and a majority of people can not get back in.
re: Poker & PokerRoom - urrrrr
Well they say they're refunding the $5 + 0.50. This still sucks since I was one of the chip leaders when the server stopped responding. They could make a killing by just buy shutting down the servers just before the bubble, then refunding everyone who's left their ticket price.


text:
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Someone who wasn't pleased with the apology?
Of course it was Paulie!
Now Paulie wrote up a long-winded missive that we aren't about to publish in full that he intended to deliver in a speech at the press gallery at Parliament Hill.
We put emphasis on, "intended":
Controversial speaker denied access to Parliament for a second time
Just over an hour before Prime Minister Justin Trudeau was to rise in the House of Commons Wednesday and deliver an apology to Canada's Sikh population for the 1914 Komagata Maru incident, Paul Fromm — anti-immigration activist previously banned from entering Parliament — was scheduled to hold a press conference opposing it.
Though his press conference was ultimately cancelled and Fromm was denied access to the Parliamentary precinct late Wednesday morning, that only came after some eleventh hour scrambling.
Fromm was previously connected to Holocaust denier Ernst Zundel and has been criticized by human rights groups for his racist views.
The office of the speaker of the house of commons confirmed to iPolitics that, "further to a recommendation from the Deputy Sergeant at Arms, and based on past practice", Fromm had been denied access to the precinct.
That past practice referred to a motion brought by Conservative MP Jason Kenney in 2007, which ordered Paul Fromm and an individual named Alexan Kulbashian "be denied admittance to the precincts of the House of Commons during the present session to preserve the dignity and integrity of the House."
In response to Jason Kenney's motion in 2007, Fromm later ran against him in Calgary in 2011 under the umbrella of a western separatist party, which was somewhat curious given Fromm's life-long residence in Ontario. And for his efforts, Fromm was stomped into a mud hole; had he run in an adjacent riding, he also would have lost to Communist Party candidate (and friend of the blog despite this writer's firm champagne socialism) Jason Devine. The subsequent spin on his shellacking was something to behold.
We wonder who Paulie will decide to humiliate himself against this time? We mean, besides this humiliation.
UPDATE 1: We so enjoy reading Paulie speak to himself in the third person.
UPDATE 2: And now, Tommy Winnicki, has offered his $0.02 on Stormfront….
…. and VNN
Cut and paste.
And Winnicki claims the "White Race" is uniquely gifted and creative.
. . . → Read More: Anti-Racist Canada: The ARC Collective: Paulie Denied Access to Parliament


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April 3, 2012
CARNEGIE ASSOCIATES LTD., PLAINTIFF-APPELLANT,v.ERIC J. MILLER, ET AL., DEFENDANTS-RESPONDENTS. ERIC J. MILLER, ET AL., COUNTERCLAIM PLAINTIFFS-RESPONDENTS,CARNEGIE ASSOCIATES LTD., ET AL., COUNTERCLAIM DEFENDANTS-APPELLANTS.
Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.
This opinion is uncorrected and subject to revision before publication in the Official Reports.
Decided on April 3, 2012
Andrias, J.P., Sweeny, Moskowitz, Richter, Roman, JJ.
Order, Supreme Court, New York County (Richard B. Lowe III, J.), entered October 25, 2010, which granted defendants' motion to dismiss the complaint and to strike the reply to their counterclaims, and imposed monetary sanctions, modified, on the law, to deny defendant's motion to dismiss plaintiff's complaint and reply to defendant's counterclaims, and otherwise affirmed, without costs. Plaintiff's appeal from the order, same court and Justice, entered December 16, 2010, which, inter alia, denied plaintiff's motion for renewal, unanimously dismissed, without costs, as academic.
The motion court erred in striking the complaint and reply to defendants' counterclaims since neither CPLR § 3126 nor 22 NYCRR 202.26(e) authorizes this sanction under the circumstances. While CPLR § 3126 authorizes the striking of a party's pleadings, this extreme sanction is only authorized when a party "refuses to obey an order for disclosure or willfully refuses to disclose information which the court finds ought to have been disclosed" (CPLR § 3126) (emphasis added). Thus, by its express terms the sanction prescribed by CPLR § 3126 is warranted only upon a party's failure to comply with discovery requests or court orders mandating disclosure (Bako v V.T. Trucking Co., 143 AD2d 561, 561 [1988]; Henry Rosenfeld, Inc. v Bower & Gardner, 161 AD2d 374, 374-375 [1990] [dismissal of a party's pleading appropriate when a party "disobeys a court order and by his conduct frustrates the disclosure scheme provided by the CPLR"]; Bassett v Bando Sangsa Co., 103 AD2d 728, 728 [1984]). Here, where plaintiff had already been sanctioned for its failure to provide discovery and where defendants premised the instant motion to strike plaintiff's pleadings primarily on plaintiff's failure to proceed with court-ordered mediation, CPLR § 3126 simply does not apply.
Similarly, despite plaintiff's conceded failure to proceed with the court-ordered mediation, it was also error to strike its pleadings pursuant to 22 NYCRR 202.26(e). While 22 NYCRR 202.26 authorizes the trial court to schedule pretrial conferences, a mediation, pursuant to Rule 3 of the Rules of the Commercial Division of the Supreme Court (22 NYCRR 202.70[g]), is not a pretrial conference. More importantly, even if this rule did apply, the only sanction authorized by 22 NYCRR 202.26(e) for a party's failure to appear at a pretrial conference is "a default under CPLR § 3404," which initially only authorizes the striking of the case from the court's trial calendar. Accordingly, here, striking plaintiff's pleadings, which by operation of law resulted in dismissal of this action is not warranted pursuant to 22 NYCRR 202.26(e).
While we agree with the dissent that plaintiff's conduct was egregious, we nevertheless find that the sanction imposed by the motion court, namely, dismissal of plaintiff's complaint and the striking of its reply to defendant's counterclaims was simply not permitted. We further note that, here, plaintiff was in fact penalized for its conduct inasmuch as the motion court granted defendants' motion for costs and fees incurred as a result of plaintiff's failure to proceed to mediation.
In support of its argument that the motion court's order was appropriate, the dissent partly relies on Rule 8(h) of the Commercial Division, Supreme Court, New York County, Rules of the Alternative Dispute Resolution Program. However, the dissent alone raises this argument, one which has never been advanced by any of the parties, either on appeal or below. Therefore, we should not consider it (Misicki v Caradonna, 12 NY3d 511, 519 [2009] ["We are not in the business of blindsiding litigants, who expect us to decide their appeals on rationales advanced by the parties, not arguments their adversaries never made"]). Moreover, contrary to the dissent's remaining position, 22 NYCRR 202.70(g) Rule 12 does not avail plaintiff since like 22 NYCRR 202.26(e), the dismissal promulgated by Rule 12, which is made more clear by its reference to 22 NYCRR 202.27, is for the failure to appear at a conference and not for the failure to proceed to mediation. All concur except Andrias, J.P. who dissents in a memorandum as follows: ANDRIAS, J.P. (dissenting)
Because I believe that Supreme Court had the authority to sanction plaintiff for its failure to mediate as ordered, and that the striking of the complaint and the reply to counterclaims was a provident exercise of discretion, I respectfully dissent and would affirm the orders on appeal.
In January 2010, Supreme Court declined to strike plaintiff's pleadings but sanctioned it for "unnecessary and perhaps egregious [discovery] delay[s]." By so-ordered stipulation dated March 18, 2010, the parties agreed to "mediation through the Commercial Division ADR [Alternative Dispute Resolution] process."
The mediation was scheduled for April 20, 2010, but was postponed when plaintiff's counsel, Jonathan Abraham, confirmed that Sherwood Schwarz, a necessary decision maker for plaintiff, would not attend. The mediation was rescheduled for July 26, 2010, but was cancelled because Mr. Abraham failed to file a mediation statement on plaintiff's behalf. Consequently, the mediator asked that the matter be reassigned because he had "formed a bias against plaintiff's lawyer" due to the latter's failure to communicate and his "extraordinarily cavalier attitude . . . toward the mediation process, the Court, and [the mediator]."
Pursuant to CPLR 3126 and 22 NYCRR 202.26(e), defendants moved to strike the complaint and the reply to counterclaims based on plaintiff's failure to mediate. Supreme Court granted the motion, finding that plaintiff, despite narrowly escaping dismissal for discovery violations, had continued to proceed in this litigation in a manner that could only lead to a conclusion that its conduct was willful and contemptuous.
"If the credibility of court orders and the integrity of our judicial system are to be maintained, a litigant cannot ignore court orders with impunity" (Brill v City of New York, 2 NY3d 648, 653 [2004], quoting Kihl v Pfeffer, 94 NY2d 118, 123 [1999]). While neither CPLR 3126 and 22 NYCRR 202.06(e) expressly gives the court the authority to strike a party's pleadings based on the failure to mediate, plaintiff did not raise that objection in its opposition to defendants' motion or in its motion to renew, and the issue is not preserved. Should we consider the issue, which raises a pure question of law, forthe first time on appeal,it is appropriate that we determine whether there is any statute or rule that empowers the court to strike plaintiff's pleadings based on its failure to mediate as ordered.
Rule 3 of the Rules of the Commercial Division (see 22 NYCRR 202.70[g]), provides that "[a]t any stage of the matter, the court may direct . . . the appointment of an uncompensated mediator." Rule 12 thereof provides that "[t]he failure of counsel to appear for a conference may result in a sanction authorized by section 130.2.1 of the Rules of the Chief Administrator or section 202.27 of this Part, including dismissal, the striking of an answer, an inquest or direction for judgment, or other appropriate sanction."
The majority is of the belief that Rule 12 is inapplicable because a mediation under the Commercial Division's ADR process is not a "conference." However, Rule 12 is included in the same section as Rule 3, which empowers the court to direct mediation, and the Supreme Court, New York County, "Guide to the Alternate Dispute Resolution Program" defines "mediation" as "[a] process in which a Neutral attempts to facilitate a settlement of a dispute by conferring informally with the parties, jointly and in separate caucuses,' and focusing upon practical concerns and needs as well as the merits of each side's position" (available at http://www.nycourts.gov/courts/comdiv/ADR_guide.shtml at 2). Further, Rule 8(h) of the Commercial Division, Supreme Court, New York County, Rules of the Alternative Dispute Resolution Program, provides that "[t]he Justice may impose sanctions or take such other action as is necessary to ensure respect for the court's Order and these Rules."
On the record before us, striking the complaint and the reply to counterclaims was a provident exercise of discretion. "[M]ediation procedures were established to resolve cases expeditiously and conserve judicial resources," and a party's failure to abide by the directives of a mediator evidences willful and contumacious conduct (Perez-Wilson v McPhee, 23 Misc 3d 1053, 1055 [Sup Ct NY County 2009]). Continued noncompliance with court orders also gives rise to an inference of willful and deliberate behavior (see Jones v Green, 34 AD3d 260 [2006]). Here, despite the fact that it had previously been sanctioned for discovery delays and had its note of issue stricken, plaintiff demonstrated utter disregard for the court, the appointed mediator, and for opposing counsel by its failure to make Mr. Schwarz available for more than three months after the mediation order was entered, failure to submit a mediation statement, and failure to tell either the mediator or the defendants that it would not file until after the deadline passed.
Plaintiff's motion for renewal on the ground that it should not be sanctioned for its counsel's misconduct was correctly denied. Plaintiff did not submit adequate documentation of the alleged lack of communication between it and Mr. Abraham and the court properly denied plaintiff an adjournment to cure this deficiency (see Wolosin v Campo, 256 AD2d 332 [1998]; Ritt v Lenox Hill Hosp., 182 AD2d 560, 561-562 [1992] [rejecting defendant's reply containing a medical affidavit designed to cure the conclusory affidavit submitted with its initial motion]). In any event, plaintiff's in-house counsel received a copy of defendants' attorney's February 16, 2010 letter to the court, which referenced the first sanctions order, enumerated deficiencies in plaintiff's discovery responses, mentioned extensions to the note or issue deadline, and requested permission to file a second motion to dismiss. Given these circumstances, Supreme Court correctly found that plaintiff's in- house counsel was on notice of the situation and should have monitored it more closely, rendering plaintiff chargeable with the conduct of its attorney (see Santiago v Santana, 54 AD3d 929, 930 [2008] ["Even if the plaintiff's former attorney was responsible for both the lengthy delay in proceeding with trial and the plaintiff's failure to appear on the last three scheduled trial dates, where there is a pattern of default and neglect, the negligence of the attorney is properly imputed to the client"]). The Decision and Order of this Court entered herein on December 8, 2011 is hereby recalled and vacated (see M--84 decided simultaneously herewith).
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Accounting part 2
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> hey anon, wanna give your opinion?
2 new threads. 1 new replies.
#20 - strifethethird
Reply 0 123456789123345869(09/01/2013) [-]
i'm pretty sure you place a block of wood or something to help it stay elevated while the car moves back farther from the ramp


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Note: Sample below may appear distorted but all corresponding word document files contain proper formattingExcerpt from Term Paper:
Hong Kong Food Culture
Unlike many other cities, Hong Kong offers a unique case study in the effects of globalization on local economies and cultures due to its premier status as a nexus between China and the West. Over the years, and even through British rule, Hong Kong maintained its own distinctly Chinese culture even in the face of relentless influence from other countries and explicit attempts to manipulate Hong Kong culture. However, globalization has caught up with Hong Kong, greatly undermining the traditional Chinese culture, a fact seen most clearly in the case of Hong Kong food culture. Nonetheless, Hong Kong retains its Chinese cultural importance, such that one examining the decline of Hong Kong food culture cannot help but see the areas in which the process has been inverted as well, with Hong Kong culture serving to integrate certain foods or drinks into Chinese society. Thus, as globalization has undoubtedly and irreversibly undermined traditional Chinese culture in Hong Kong, the resilience of that culture has allowed Hong Kong to become a kind of cultural laboratory, in which global customs and products are vetted before gaining more widespread acceptance in mainland China.
For many years, one of Hong Kong's biggest draws to international businesses and travelers was the fact that "Hong Kong is almost universally lauded for hard work, flexibility and the rule of law, and its success has been largely attributed to its willingness to transform itself and its ability to harness rather than resist the forces of globalization" ( Kwong & Miscevic, 2002, p. 323). Following the transition from British to Chinese rule, however, Hong Kong experienced a number of economic shocks which left "plenty of old-time hardpressed residents are still trapped in chicken coops of a bygone era" (Kwong & Miscevic, 2002, p. 325). This left huge amounts of Hong Kong real estate unoccupied as the shipping of manufacturing jobs to mainland China, coupled with the surging importance of Shanghai, gutted the island of both a robust economy and its "indispensable role" in bridging the cultural and political gap between China and the West (Kwong & Miscevic, 2002, p. 326). Cheap real estate coupled with an overabundance of "younger unskilled workers" provided the ideal context for the importation of globalized food and culture, because "As U.S. firms [sought] to expand their presence in global markets, one of the primary areas of opportunity [was] providing services to the rapidly growing markets in Asia" (Kwong & Miscevic, 2002, p. 325, Keillor & Fields, 1996, p. 83). Thus, in a process beginning in the 1980s but picking up rapidly in the 1990s and early 2000s, American fast food companies aggressively expanded into Asia, with Hong Kong representing one of the key areas.
To see how Hong Kong has attempted to resist the undermining of a domestic cultural heritage through globalization, one need look no further than American attempts at marketing fast food on the island. A study investigating Hong Kong's residents perceptions of fast food found that "fast food is considered to be a convenience item rather than a special treat," and as such attempts to sell fast food "as an opportunity to engage in an American cultural experience" fall flat, because they ignore the cultural differences between "staple versus 'treat' foods" (Keillor & Fields, 1996, p. 99, Furnham & Li, 2008, p. 299). This is not to suggest that American fast food has not successfully made its way into Hong Kong food culture, because it has, but rather a means of pointing out that American fast food has ultimately served to undermine a traditional Chinese culture specifically by adjusting the food offered to be more in line with regional tastes. The study found that "traditional elements are important both in the product offering (i.e., the inclusion of traditional fast food items on the fast food menu) as well as in the atmosphere in which the product offering is conveyed" (Keillor & Fields, 1996, p. 99-100). Make no mistake, this does not represent an instance in which traditional culture has been retained, but rather an example of globalization taking traditional culture and commodifying it by reducing certain aspects of it to their most basic essence in order to better suture traditional food culture and globalized fast food. Sure, American fast food companies might include traditional items on the menu in certain regions, but this is only as a means of shoring up a customer base for the rest of the homogenized, globalized food menu. Thus, the convergence of American fast food and traditional Chinese food culture in Hong Kong is an interaction which ultimately subsumes the latter into a globalized cultural marketplace in which it is ill-equipped to successfully maintain itself.
The case of American fast food companies in Hong Kong is perhaps the most obvious example of globalization leading to a vast undermining of traditional Chinese food culture in Hong Kong, but globalization has wrought other, more subtle changes as well. For example, "moon cakes are a traditional food eaten to celebrate Chinese festivals," and "for ages, they have been produced by master bakers using their own secret recipes" (Elsey & Tse, 2007, p. 511). As a result of globalization, however, the demand for moon cakes has challenged the traditional method of production, and a look at one particular Hong Kong bakery offers a case study in the ways in which globalization gradually erodes traditional food culture even as it is ostensibly expanding the reach of that culture to international markets.
Like many other Hong Kong businesses in the 1980s, the bakery in question "grew and moon cakes and other products were exported to the international market […] while continuing to serve a vibrant local Chinese market through a chain of retail outlets and restaurants" (Elsey & Tse, 2007, p. 512). Thus, at first glance globalization would appear to be a boon for the traditional bakery, opening up new markets and sustaining it to the point that "the moon cake [could remain] the same kind of simple and single 'flagship' product, symbolic of the state of the company," which itself "remained deeply entrenched in a traditional Chinese business and management mindset […] positioned to largely ignore 'the winds of change' in an increasingly technology driven and a more competitive market environment" (Elsey & Tse, 2007, p. 512). By offering an initial opportunity for expansion, globalization appears to provide businesses specializing in traditional food the opportunity to sustain that traditional culture through an influx of global money, and indeed, this does occur for some time. Soon, however, the true effects of globalization become clear, because just as the traditional bakery has access to a global market, the market has access to that bakery's product such that it may be copied and reproduced for less money somewhere else. Like the inclusion of traditional menu items in American fast food restaurants in Hong Kong, the experience of the traditional bakery demonstrates the way in which globalization takes traditional culture and commodifies it, thus severing any real connection between the product and the culture which produced it. Even those companies which manage to succeed following globalization, such as the bakery in question, are ultimately only able to do so by altering their traditional outputs in order to satisfy the trends of the global market. Thus, the Hong Kong bakery ultimately shifted from the production of traditional moon cakes "to [creating] a whole new range of upmarket moon cake products" such as "an impressive array of variations for international travelers at the airport shop" (Elsey & Tse, 2007, p. 525). It is worth pointing out here that even the scholarship on this subject works to undermine and minimalize the importance of traditional culture; aside from the glowing description of the expanded moon cake line that is essentially a line of souvenirs for Western tourists, the analysis of the Hong Kong bakery in Elsey and Tse's essay is intent on portraying the traditional modes of production, management, and food culture as hopelessly, provincially outdated, as if it is traditional businesses' fault that the hegemony of global capitalism maintained by massive multinational corporations makes it difficult to continue turning a profit. Thus, the commodification and disintegration of traditional food culture is presented as the hopeful future for the traditional business.
As this essay investigates the changes in Hong Kong food culture as a result of globalization, the course of investigation is towards more and more local levels, such that one may see not only how alien foods and cultures are injected into Hong Kong society, but also how traditional foods are irrevocably altered. Thus, the moon cake bakery previously discussed demonstrated the way in which globalization forced a traditional company to shift its target market away from domestic tastes and begin catering almost exclusively to international desires. Even more subtly, however, globalization has altered food culture in Hong Kong so much that even "domestic" tastes cannot really be called that anymore, and this is nowhere more apparent than in the case of products made from…[continue]
"Globalization And Food Culture In Hong Kong" (2011, October 14) Retrieved November 29, 2016, from http://www.paperdue.com/essay/globalization-and-food-culture-in-hong-kong-46407
"Globalization And Food Culture In Hong Kong" 14 October 2011. Web.29 November. 2016. <http://www.paperdue.com/essay/globalization-and-food-culture-in-hong-kong-46407>
"Globalization And Food Culture In Hong Kong", 14 October 2011, Accessed.29 November. 2016, http://www.paperdue.com/essay/globalization-and-food-culture-in-hong-kong-46407
McDonald's in Hong Kong: Consumerism, Dietary Change, and the Rise of a Children's Culture, by James L. Watson James Watson starts his article recollection of a conversation he had in 1969 with a Hong Kong resident whose ancestors had settled in New Territories of Hong Kong six centuries ago. Mr. Man vividly described a feast he had eaten fifty years back, so around the second decade of the twentieth century. Mr.
Immigration policy, distance and financial constraints reduce the flow of people. Religions are notoriously difficult to pass from culture to the next because of the deep level of personal involvement. Languages are passed to outsiders only when pragmatic, as in the case of lingua francas. As long as the barriers to passing important cultural artifacts between cultures remain, globalisation will remain in evidence mostly with what can be transferred
Globalization is best defined as a process of increasing interdependence between all people in the world. From fashion to the environment to multiculturalism to musical fusion and more, globalization emerged as a significant, new worldview in the 1990s. Globalization has created a world market in which goods, money, and people cross international borders as freely as possible. Modern transportation and theology, including the Internet, played a key role in the
Many tourists have their picture taken in front of the McDonald's sign or with the Ronald McDonald statue outside the restaurant to document their contact with an exotic culture. " (1999) 5) Location, location, location - Over a period-of-time, Kwan's study notes that "...as the number of fast food outlets increased, the reasons why people go to fast food places changed. All the interviewees who have become accustomed to the
Negotiating the deal was surprisingly easy due to a combination of an apparently modest goal on my part and more negotiating ability on the part of the seller than was anticipated. While the seller implicitly made the initial offer in the publication of the ad, I ultimately initiated negotiation by stating that I had seen the ad and was wondering if the seller would take $18,000 for me to take
Global Culture I find the idea that the world is becoming homogenized to American culture to be parochial, offensive and ill-formed, the product surely of American thinking. Nobody from any other culture would see the world in that light, because they are actually informed about the non-American world. Writers arguing in favor of the idea that the world is becoming homogenized to American culture are laughably ill-informed. They make heroic errors
Jollibee Fast food case study: Jollibee Foods Corporation Define the problem The Philippine-based hamburger chain Jollibee Foods Corporation is currently contemplating international expansion. The first question it must answer is where: should it expand into America, Hong Kong, or the developing world market of Papua New Guinea? If it decides to expand into America it faces another choice: should it focus on mainstream America consumers or recent immigrants and Philippine expatriates? (Bartlett &


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Lake Nokomis views from the front yard! Stucco 3 bedroom, 2 bathroom home just a few houses from the lake. 3 season porch, formal dining room, large master suite with great closet space. Finished lower level family room and bathroom. Sprinkler system, french drains, cedar privacy fence & new concrete sidewalk.
Property Type: Residential, Single Family, 1.5 Story
Status: Pending
Bedrooms: 3
Bathrooms: 2
Lot Size: 0.12 Acres
Square Feet: 1,558 sq ft
Year Built: 1948
Foundation: 958 sq ft
Garage: Yes
Property Attached: No
Date Available:
Model Home:
Completion date:
Subdivision: Wenonah
Background Check: No
Smoking Permitted: No
In Foreclosure: No
Lender Owned: No
Potential Short Sale: No
Auction: No
County: Hennepin
Days On Market: 14
Construction Status: Previously Owned
District: 1 - Minneapolis
Main Floor
Living Room: 18x12
Dining Room: 11x9
Kitchen: 11x8
Bedroom 2: 12x11
Bedroom 3: 11x10
Three Season Porch: 13x10
Upper Floor
Bedroom 1: 17x14
Lower Floor
Family Room: 17x14
Full Baths: 1
1/2 Baths: 1
Additonal Room Information
Family: Lower Level
Dining: Separate/Formal Dining Room
Bath Description: Main Floor Full Bath,1/2 Basement
Square Footage above: 1,258 sq ft
Square Footage below: 300 sq ft
Appliances: Refrigerator, Dryer, Dishwasher, Washer, Microwave, Range
Basement: Concrete Block, Finished (Livable), Full
Fireplaces: 1, Wood Burning, Living Room
Additional Interior Features: Kitchen Window, Natural Woodwork, Hardwood Floors, Tiled Floors
Water: City Water/Connected
Sewer: City Sewer/Connected
Cooling: Central
Heating: Natural Gas, Forced Air
Garage Spaces: 1
Parking Description: Detached Garage
Exterior: Stucco
Roof: Asphalt Shingles
Lot Dimensions: 40x129
Zoning: Residential-Single
Fence: Privacy, Wood
Additional Exterior/Lot Features: Porch, Patio, In-Ground Sprinkler, Tree Coverage - Light, Corner Lot
Water Frontage:
Lake Acres:
Lake Chain Name: No
Road Between Waterfront and Home: No
Pets Allowed: No
Cedar to Nokomis Parkway, east to Derby, south to 19th Ave, south to home.
Terms: Loan Terms - FHA,DVA,Conventional,Cash
Tax/Property ID: 2402824230019
Tax Amount: $3,863
Tax Year: 2016
HomeStead Description: Homesteaded
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Opening gigs an honor for garage rock trio Living Statues
Chris Morales has squeezed himself into a number of packed U.S. Cellular Connection Stage shows at Summerfest in recent years.
But on June 29, Morales, along with his Milwaukee band, the Living Statues, had the best seat in the house: on the stage, for its own show. »Read Full Article(2)


text: Leona Louise Lewis (born 3 April 1985) is a British singer and songwriter. She first came to prominence after winning the third series of The X Factor in 2006. A multi-platinum selling artist and three-time Grammy Award nominee, Lewis's most successful single, 'Bleeding Love', reached number one in over 30 countries around the world, and was the best-selling single worldwide in 2008. She was proclaimed 'Top New Artist' by Billboard magazine in 2008. Her two albums Spirit and Echo, released in 2007 and 2009 respectively, have collectively sold in excess of 9 million copies worldwide and topped the charts in numerous countries. Lewis's debut tour, The Labyrinth, took place in 2010. As of December 2011, Lewis has sold over 20 million records worldwide. Her third album Glassheart was released 12 October 2012. It was preceded by the single 'Collide', which became her seventh top-five hit in the UK.


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Duck Blanket Lined Coat 10 Oz.
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Building 76 12 Balmain Crescent
Acton, Australian Capital Territory 2601
The ANU China Institute combines the research and teaching talents of the academics of The Australian National University to bring greater focus to our collective activities and to highlight the work of the largest group of China specialists in Australia. ... more


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Way to eat, Alameda!
The city released its latest quarterly sales tax data, and the news is … good! The city raked in an additional 1.1 percent in tax revenues for the quarter ending on March 31, driven in part by increased grocery sales and increased tabs from all our new, schmancy restaurants. New stores at Alameda Towne Center (or South Shore, in deference to any Alamedians who are reading this) are also continuing to drive tax dollars into the city's coffers, as are the shops and food joints (and of course, Nob Hill Foods) at Bridgeside Center. Not surprisingly, auto sales continue to decline, as has construction. But our on-Island eating and shopping has more than made up for it. The extra $15,000 or so the city collected in sales taxes this past quarter should make an oh-so-tiny dent in the $4 million deficit they'll be staring down for next year.


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Social Media Executive - West London
Social Media Executive - Integrated Marketing agency - West London
The business
This agency has been creating engaging marketing campaigns for over 3 decades and have grown particularly strongly in the last two years.
They are based in attractive West London offices that have a close knit, family feel despite them now numbering nearly 100 people.
Being a leading integrated agency, they are capable of providing every kind of marketing solution you can think of from live events and experiential to online customer loyalty programmes, search and content creation.
They deliver these services to a wide range of clients across multiple sectors from Finance to IT and FMCG to Automotive.
The diversity of clients and range of services on offer makes it a very exciting place to work where no day is ever the same.
The role
This is a very important role within the agency.
You will be responsible for the ongoing social media activity across various clients, sectors and channels.
Key responsibilities will be,
- Source and manage the social assets and copy for several accounts.
- Community management including responding to user queries and escalating when necessary.
- Reporting on the statistics of social channels and campaigns, and offering hypothesis on these.
In order to fulfil this role, you'll need to have,
- At least 2-3 years experience in a digital marketing environment
- A passion for all social channels including Facebook, Instagram, Snapchat, Twitter, Google and Youtube.
- Excellent people skills!
What's in it for you?
This agency retain their staff.
People like working there because they are looked after, challenged and rewarded.
On top of the fun, upbeat working environment.
You can expect to receive a generous basic salary, company and personal bonus, Pension, Healthcare, childcare vouchers, bike to work scheme, 25 days holiday + bank hols.
It really is a great place to work and a business we love recruiting for.
- Start: ASAP
- Rate: £23000.00 - £28000.00 per annum
- Location: West London, England
- Type: Permanent
- Industry: Sales
- Recruiter: Stonor Search and Selection Limited
- Tel: 01844 350131
- Email: to view click here
- Posted: 2016-09-15 10:42:42 -
- View all Jobs from Stonor Search and Selection Limited
More Jobs from Stonor Search and Selection Limited
- Senior Account Manager or Account Director
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- Account Executive
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- Senior Account Manager
- Copywriter
- Client Service Director
- Account Executive
- Marketing Communications Executive
- Mid-Senior Creative Strategist
- Senior Creative Strategist
- Senior Account Manager
- Account Manager
- Research Manager
- Research Manager
- Account Director
- Senior Account Director
- Account Coordinator
- Account Executive or Senior Account Executive


text:
Green overhead at 88 Angel Street
May 6, 2016
"We're facing a crisis. I call it 'ecofatigue'. Many architects and designers feel sustainability is a bit of a fad, or a style. Almost constraining enough to rebel against." Steele Associates architect and founder, Oliver Steele, discusses the challenges and rewards of innovating sustainable home design.


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MTM117-510 - Mast Motorsports 2010-11 Camaro Drop-In Engine - RHS Block - Supercharged - 725 HP
This product may require vehicle validation(s) for proper fitment. Please contact us to confirm correct vehicle fitment and usage.
Type: RHS 7.0L TVS 2300
Displacement: 427 Cubic Inches
Compression Ratio: 9.5:1
Bore x Stroke: 4.125 x 4.000
Rev Limit: 7000 RPM
Crank: Callies Forged
Rods: Callies H-Beam
Pistons: Mahle Motorsports
Cam: Mast Custom 3-Bolt Core
Heads: Mast CNC LS3/L92 Heads
Intake: Intercooled Supercharger
Valve Springs: Mast Nitrided Beehive
RHS Aluminum Block
Plateau Honed to 4.125
Application List
- 117-510
- 117-510
- Mast Motorsports
- Item has been discontinued and is no longer available
- New
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- Item Requires Shipping
- 500.0 lbs.
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We investigated the possibility of applying a hybrid feed-forward inverse nonlinear autoregressive with exogenous input (NARX) fuzzy model-PID controller to a nonlinear pneumatic artificial muscle (PAM) robot arm to improve its joint angle position output performance. The proposed hybrid inverse NARX fuzzy-PID controller is implemented to control a PAM… (More)
In this paper, a novel MIMO Neural NARX model is used for simultaneously modeling and identifying both joints of the 2-axes PAM robot arm's inverse and forward dynamic model. The highly nonlinear cross effect of both links of the 2-axes PAM robot arm are thoroughly modeled through an Inverse and Forward Neural MIMO NARX Model-based identification process… (More)


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Italian Subs
Vicki Butts (lazyme)
Fast, easy, sub sandwich from Grey Poupon Simply Delicious Recipes. We usually use hoagie buns so everyone can build their own.
Featured Pinch Tips Video
- 1/2 c
- italian salad dressing, prepared
- 1/4 c
- grey poupon dijon mustard
- 1 tsp
- dried oregano
- 1
- loaf italian bread, split lengthwise
- 2 c
- lettuce, shredded
- 8 oz
- deli ham, sliced
- 4 oz
- deli salami, sliced
- 7 oz
- roasted red peppers, cut into strips
- 4 oz
- provolone cheese, sliced
- 1 small
- red onion, thinly sliced
Directions Step-By-Step
1In small bowl, whisk salad dressing, mustard and oregano until blended.
2Spread dressing mixture over cut sides of bread.
3Place half the lettuce on bottom half of bread; top with layers of ham, salami, pepper strips, cheese, onion and remaining lettuce. Replace bread top; slice and serve.
About this Recipe
Course/Dish: Sandwiches
Main Ingredient: Pork
Regional Style: Italian
Other Tag: Quick & Easy


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Christian Workout Songs
Christian Workout Songs - clean, upbeat, and inspiring music for workouts
Christian Running Music: Not Your Mommas Playlist. A variety of genres with a great BEAT to keep you pounding the pavement while encouraging you in your faith!
fitness motivation
Christian Workout Music: 100 Uplifting Songs. Need an uplifting workout? Try these songs to get you moving and feeling good. | via @SparkPeople
Christian Music Workout Playlist with Songs and Artists
Christian workout songs
High energy, blood-pumping music to motivate you through even the toughest of workouts! Finally, the perfect Christian cardio & lifting playlists! | RecklesslyAlive.com
Christian Workout songs list of newer songs?
70 Christian Work-Out Songs | Le Chaim (on the right)
50 Christian Workout Songs