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Having unnecessary fat in different locations of your body can have a considerable effect on your health and self-esteem. While conventional weight reduction through exercise and diet is a terrific way to drop weight in general, even the best exercises can't target problem areas like the stomach, inner thighs, arms, and buttocks. Liposuction is a time checked treatment that is used to remove excess fat from particular locations of the body, enabling an individual to shape and contour their body to their liking. Is liposuction right for you? Discover now.
Pros of Liposuction
There are numerous benefits to this cosmetic procedure, consisting of:
• Right away visible changes. Unlike conventional weight-loss, liposuction creates changes that are instantly noticeable in the body. Some distinction is noticeable right away, and the preferred outcomes are generally achieved in just a couple of days.
• Proven and safe. This cosmetic treatment has been performed by experienced cosmetic surgeons all over the world for several years and the method has been improved over and again to be safe and effective.
• Recovery time is generally fast. The downtime needed after having this kind of procedure is generally much less than what is required for other kinds of cosmetic treatments, consisting of tummy tucks, breast reduction, and more. People who have had the procedure can frequently go back to work a lot more rapidly than they expected and can return to living a healthy, active lifestyle.
• Weight loss can be long-term. With the best maintenance techniques, the fat that was removed during the liposuction procedure will not return.
• Complete control over your physique. With liposuction, an individual can have complete control over how they wish to look, beyond exactly what traditional diet plan and exercise can supply. Offering individuals this power over their bodies increases self-confidence and assistance people feel their very best.
While there many benefits to liposuction, there are naturally a few cautions that must be thought about before making the decision to move forward with the procedure.
Cons of Liposuction
Prior to having liposuction done, it is essential to analyze the prospective downsides of the treatment and figure out if the benefits exceed the risks in your particular case. Your specialist can help you learn more about the dangers associated with the procedure and can help you decide if progressing is the right thing for you.
• Complications with basic anesthesia. Since liposuction is performed under basic anesthesia, the treatment brings the very same threats as any other kind of surgery where basic anesthesia is utilized. Hidden medical conditions may increase these dangers.
• Adverse reactions. Bruising, bleeding, and discomfort are all to be anticipated, however, in uncommon cases can trigger more considerable issues.
• The possible to gain the weight back. After having liposuction done, it is vital to keep a healthy diet plan and workout properly as suggested by your doctor. Failure to do so might lead to acquiring back the weight that was lost or perhaps even more.
Although there are threats connected with liposuction, for many people, the advantages far exceed them. Educate yourself about the treatment by having in-depth conversations with your surgeon and consider how liposuction has the prospective to affect you as a special person. Just you and your cosmetic surgeon can determine if liposuction will supply you with the outcomes you are searching for within your expectations.
Laser Liposuction procedure is a new non invasive procedure to loose unwanted bodyfat in Hortense Georgia
Laser liposuction is a newer, minimally invasive treatment that includes heating the fat cells to melting point and getting rid of the melted fat through a small cannula. The procedure is typically done right in your physician's workplace and is an outstanding choice for individuals who have less than 500 ml of fat to remove from any one location. Laser liposuction can be a safe, complementary procedure to weight-loss in order to sculpt the body you have actually always desired.
Contact a Specialist in your Hortense Georgia today.
If you're thinking about liposuction as a weight loss option, it's important that you discuss your desires with a certified plastic surgeon in your location. Your specialist will carry out a total exam and health history questionnaire to identify if liposuction can benefit you and help you reach your physical and emotional goals. Call today for an assessment and find out more about how liposuction can assist you attain the body of your dreams.


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English-Style Baked Chips
Total Time
Prep 16 mins
Cook 28 mins
These English style chips will fill your belly with great taste but won't make the scale budge!
Ingredients Nutrition
- 1 (12 ounce) baking potatoes
- 3 cups very hot water
- 1 teaspoon canola oil
- cooking spray
- 1 teaspoon lemon pepper
- 1⁄2 teaspoon kosher salt or 1⁄4 teaspoon table salt
- Preheat oven to 400 degrees.
- Scrub potato with a brush. Cut potato crosswise into 40 very thin slices using mandoline slicer or very sharp knife.
- Combine potato slices and hot water in a large bowl;let stand 10 minutes. Drain. Arrange potato slices on a layer of paper towels;pat dry.
- Coat 2 (15x10-inch) jelly roll pans evenly with oil. Arrange potato slices in a single layer on pans. Coat potato slices with cooking spray, and sprinkle evenly with lemon pepper and salt. Bake at 400 degrees for 18 minutes or until lightly browned.****NOTE** Watch chips carefully, and quickly remove individual chips from the pan as they become lightly browned.
- **NOTE** Soaking the potato slices in hot water speeds up the cooking process and washes away excess starch, resulting in crispier chips.
Most Helpful
These turned out excellent! I have made chips many times before - both in the microwave and the oven. Soaking them in water made a big difference in the crispness. I used my Cuisinaire slicer and placed a strainer inside of a large Tupperware bowl full of water. Worked perfect and made my little assembly line go quickly. I used only cooking spray and kosher salt, flipping chips about 1/2 way through. Thanks for a great method!

subset: commoncrawl


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There is so much to love and study about this performance, and not just Brian McWhorter's superb tone, technique, and intonation. It's a great reminder how much other "stuff" is behind a good performance, not just the sounds coming out of your horn: stage presence, facial expressions, movement, yadda yadda. 66 more words
Tags » Ligeti
Yuja Wang - Sonatas & Etudes
Label : DG
Format : Flac track
Cover : Yes 49 more words
Online Resources #1: Ligeti, Boulez, Stravinsky and Benjamin
Anybody with a moderate interest in modern musicology will have noticed that the practice of performance as a form of musicological research has become more valued than ever. 341 more words
Get Your Exercise, Day 2 – Etude No. 8, "Metal" by Gyorgy Ligeti
This week's theme is…Get Your Exercise! If you want to get stronger, you'll go to a gym and work out. But musicians can get stronger too, and to get their exercise, they might practice an etude, which is a French word for a piece of music written to strengthen a particular skill. 1,156 more words
Mind-Reading Musicians
Tech-junkies, creatives, music lovers, and people just looking for inspiration should enjoy this project. It's what happens when you combine all of these elements. Without an agency or any budget. 409 more words
Ligeti - Chamber Concerto & Ramifications - Boulez
Label : DG
Format : Flac (image + cue)
Cover : Yes 50 more words
March 2016 - Univers Sonores
March 22 2016, 8:00 pm
Univers sonores – Strasbourg University cycle – concert (with pianists Vincent de Murcia, Marie Stoecklé, Daniela Tsekova and Elyette Weil) preceded by a conference (in french) by Nathalie Hérold, 52 more words


text:
I get a serious thrill out of taking something old, boring, broken, you name it… and turning it into something fabulous. Corey of Sawdust 2 Stitches and contributor on Remodelaholic totally blew my mind by transforming an inexpensive cubby shelf from IKEA into a Pottery Barn inspired apothecary cabinet. It almost sounds unbelievable, but Corey did … [Read more...]
Tufted Fabric Headboard with Winged Sides
Chris and Julie from DO or DIY desperately needed some pizzazz in their guest bedroom and knew the perfect solution would be a headboard that made a BIG statement. However, despite all the tutorials for DIY headboards, Chris and Julie but didn't find anything that quite fit the mark. The couple decided to come up with their own design that combined … [Read more...]
Floor Pouf from Rugs
Poufs offer a great option for extra seating. Not only are they soft and comfy on the tush, but they can easily be set aside when not needed. Always in need of extra chairs for get-togethers, Erika from Retropolitan set out to create her own poufs. When her fabric search came up dry, Erika came upon a fabulous substitute – $3 floor mats from IKEA. … [Read more...]
Easy Oyster Shell Cluster Sculptures
On a road trip to New York, Lynn from Nourish and Nestle picked up a cool rusted oyster basket. She was unsure what she was going to do with her fabulous find when, as fate would have it, her hotel room was decorated in some super cool oyster shell cluster sculptures. When she returned home she began scouring for oyster shells, (refusing to buy … [Read more...]
Wal-mart Kitchen Mat Makeover
Doreen from Hymns and Verses fell in love with a pretty and functional kitchen mat from Ballard that features a measurement conversion chart. What she didn't love was the price of$75. Doreen instead decided to try her hand at making her own with a similarly-shaped comfort mat from Wal-mart and a chalk marker. Doreen designed the chart on the … [Read more...]
Classic Concrete Garden Spheres
Pam from Simple Details is a big fan of outdoor accessories and décor but says, "too much of a good thing can take your space from classic to cluttered and cutesy in no time." That's why Pam loves the serene look of Restoration Hardware's stone garden spheres. Instead of spending hundreds of dollars PER stone, Pam made five stone structures for … [Read more...]
Knockoff Anthropologie Vase
Jessica from House Homemade was re-doing her guest bathroom and decided that her bold pink and black vase needed a makeover. She turned to Anthropologie for inspiration and found the Listras Vase, which is gorgeous, and also $88. So, Jessica found some inexpensive craft paint in a similar navy blue color, a paint marker, and set to work. While she … [Read more...]
Stenciled Damask Wallpaper
Jessica from Designers Sweet Spot had, well, a sweet spot for old walls. Her master bedroom was very vanilla and very small, so she decided to spruce it up by making it look old. Rather than forking over big money for a more traditional damask wallpaper, she opted to paint her own by using a stencil! With a lot of paint and a little patience, … [Read more...]
Minimalist Concrete Coasters
If you have already bought a bag of cement for some of the other fantastic concrete projects we have posted, use the last bit of it for these adorable concrete coasters! You can make them as minimalist or as fantastic as you want, with paint or impressed designs. Rebecca from A Daily Something has a great tutorial on how to create these adorable … [Read more...]
Planked American Flag Wall Art
Pottery Barn always has adorable wall art, and luckily it is often easily DIYable! Doreen from Hymns and Verses saw Pottery Barn's Hermosa Planked Flag art and decided she wanted to decorate her home with it, but not for Pottery Barn prices. So she purchased wood and paint at the home improvement store and set to work! If you head over to Hymns and … [Read more...]
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- Worldwide Rank #27,837,011
- Follower/Following Ratio 1.4
- Daily New Followers 0
高山宏樹 Twitter Stats
@0103Zousan - Tracking 高山宏樹 Twitter profile since March 19, 2015
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@0103Zousan has 229 followers on Twitter.
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Last month this account followed 21 users.
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text:
Severed Finger Food
Out of Stock
Signup to receive an email when this item is in-stock.
Sizing Links & Information
If size options aren't displayed, this item is a one size item.
Severed Finger Food
Serve Up Your Fingers! Gross out your guests with this life size, vinyl five piece set of severed fingers. Great on your Halloween Vegetable trays. These fingers are not edible.
Read Reviews (1)
Model #: 85001
Severed Bloody Finger$ 11.79
Model #: FM56758
Halloween Award Ribbons$ 5.59
- met or exceeded my expectations
- Overall good value for the money
- Worked well for my purposes
Best Uses
Comments about Fun World Severed Finger Food:
These will be the perfect addition to our Halloween party finger food tray. Shipping to APO address is fantasic less then 1 week.
|Available Online
|Qty On-Hand At Store


text:
Skip to Content
The World's Greatest Music
Email the show or Text 61812
It's an institution that goes back almost 500 years. Today, Judith Weir is Master of the Queen's Music but who were her illustrious predecessors?
Picture 13 of 22
Violinist and conductor Franz Cramer (1772-1848) was made Master of the Queens Musick in 1834 by King William IV and continued in the post until the year Queen Victoria ascended to the throne. Very little is known about his compositions; the only manuscript that has survived is a Capriccio for violin, kept in the British Museum.
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Filed under: foreclosure | Tagged: Bank of America, Chase, disclosure, foreclosure defense, foreclosure offense, fraud, INDYMAC, ne of them were lenders. None were creditors., OneWest, RED OAK MERGER CORP, securitization, WAMU | 7 Comments »
Red Oak Merger Corp. a/k/a Countrywide, a/k/a BAC a/k/a Bank of America
DUAL Tracking: The Game of "Chicken"
"In their quest for a windfall they have given the homeowners a path to justice — one where the notice of default, notice of sale, notice of acceleration notice of right to reinstate and redemption rights are all screwed up (i.e., wrong and invalid). With 80%+ of the losses already paid, the loans could have been modified down to nothing or nearly nothing compared with the original balance showed on the note, whether the note was fabricated or not. The problem is not whether the remedy exists. The problem is whether the lawyers and litigants have the guts to pursue it." Neil Garfield, http://www.Livinglies.me
OneWest was formed over a weekend by several wealthy investors who paid virtually nothing for billions of dollars in what were claimed as "portfolio" loans owned by IndyMac which went bankrupt and into FDIC receivership in September, 2008. The agreement specified that the FDIC would pay 80% of the losses incurred on the loans. The first problem is that it said it would pay OneWest the 80%.
The second problem is that One West maintained their claim for the full amount against homeowners even though they had already submitted the claims and collected — many times more than once, from our analysis. That payment was not subject to repayment, subrogation or anything else that we can find, so the "creditor" or "agent" of the creditor has been paid on that account, but the balance has not been reduced.
In their quest for a windfall they have given the homeowners a path to justice — one where the notice of default, notice of sale, notice of acceleration notice of right to reinstate and redemption rights are all screwed up (i.e., wrong and invalid). With 80%+ of the losses already paid, the loans could have been modified down to nothing or nearly nothing compared with the original balance showed on the note, whether the note was fabricated or not.
The real problem is that most lawyers are not presenting their cases with the confidence of knowing that whatever the position of their opposition, it is probably a misstatement of the truth — the opposing lawyers in most cases don't even know that they are making false statements and representations. Practically every foreclosure trial or hearing begins with the words "This is a simple foreclosure, your honor." Nothing could be further from the truth.
Patrick Giunta, Esq. is co-counsel on several cases we are litigating in South Florida. One of them is a qui tam action against OneWest for false claims to the government. He has again brought to my attention the case decided in California (where almost everyone says it is hopeless) in which the homeowner stuck to their guns instead of accepting various offers of settlement. The reason we bring it to your attention again is that it demonstrates the fact that if you know you are right and you have the Judge on your side just for the raw elements of pleading or discovery, the confidence of the opposition is shattered even if they put on a good show of appearing otherwise.
My article from September 13, 2013 explains the scenario from the California case. Our current case goes even further alleging that OneWest intentionally misrepresented losses to the FDIC and the Federal Home Loan Housing Agency (and probably other private and public institutions) in order to collect multiple times on nonexistent losses. But it also dove-tails with the California case because they were steering homeowners into "modification" programs by the old trick "You have to be 90 days behind before you can be considered for modification."
And by the way that trick phrase is not only untrue (designed to keep the modification "in house") but also potentially criminal and illegal, because for one thing HAMP does not require delinquency in loans for modification. It gets worse. Most of the loans submitted for modification were in fact subject to claims of securitization and the authority of OneWest is questionable at best. The 90 day delinquency trick is wrong. It also constitutes the unauthorized practice of law. If a lawyer says it or anyone from his or her office under instructions from the lawyer, it might be grounds for a bar grievance. Practicing law without a license is an actual felony in many states subject to imprisonment, fine or both.
Virtually all servicers have trained their employees on how to say that without it appearing to be advice — but the homeowner hears it just the way the servicer wants them to hear it — I must go into default if I want the modification. THUS THE DEFAULT IS PROCURED INTENTIONALLY BY THE SERVICER WHICH IS INTENTIONAL INTERFERENCE WITH THE CONTRACT, IF IT EXISTS, BETWEEN THE BORROWER AND THE TRUST.That is an intentional tort enabling the Plaintiff Homeowner to allege damages far beyond economic damages and to even ask for punitive damages, exemplary damages or treble damages under statutory authority, sometimes including the cost of attorneys fees and costs.
The problem is that no modification is offered even if the homeowner makes trial payments on an "approved" modification. Worse yet, those payments are also frequently missed when the servicer or "creditor" issues a statement, report or notice. Or the modification actually raises the payments and makes it more impossible for the loan to work — which brings the servicer to the point they want: foreclosure to collect or keep the money they received on that loan, directly or indirectly, and which they never reported to the court, the borrower or anyone else.
The OneWest situation is only symptomatic of the rest of the "industry." Virtually all servicers play the same games. These intermediaries and their co-venturers are collecting over and over again from loss sharing agreements, insurance, credit default swaps, and guarantees and other hedges, over and over again. They report it to nobody. And neither the Justice department or even our new CFPB seem to have any interest in the one factor that would bring down the number of foreclosures to nearly zero — giving credit where credit is due.
Practice Hint: For the bold and creative I would argue that that the entire profit earned from using the name of the homeowner to sell bonds,and profit from loss sharing and loss mitigation techniques should be disgorged to the borrower, whose note specifies how the payments are to be applied. One lawyer in Phoenix refers to this as my most obnoxious theory. I bet. It would disgorge all the money the banks made by declaring non existent losses.
If the "creditor" has received money directly or through payment to their agent, then the balance of the receivable is reduced — and in the simplest bookkeeping class we know that the corresponding payable from the borrower is also lost. The intermediaries could get to keep their ill-gotten claims on multiple reports of the same nonexistent loss, with a correction of the principal balance due from the borrower.
Instead they would rather get hit for a seven figure verdict or a six figure settlement when one out of a thousand gets up the nerve to really challenge them. The numbers all balance out in favor of Wall Street — as long as Wall Street keeps winning the game of "chicken."
For further information please call 520-405-1688 or 954-494-6000. Consults available to homeowners' attorneys, to wit: homeowners can attend only if they have a licensed attorney on the conference call. Workbooks on General Foreclosure Litigation, Evidence and Expert Witnesses are also available.
Filed under: AMGAR, CASES, CORRUPTION, evidence, Fannie MAe, foreclosure, foreclosure defenses, foreclosure mill, GTC | Honor, investment banking, Investor, MBS TRUSTEE, MODIFICATION, Mortgage, Neil Garfield Show, Pleading, securities fraud, Servicer, Title, TRUST BENEFICIARIES, trustee | Tagged: dual tracking, FCPB, FDIC, INDYMAC, OneWest, Patrick Giunta | 10 Comments »
Why Are We having So Much Trouble Connecting the Dots?
Matt Weidner reports that he went to court on a case where IndyMAc was the plaintiff. IndyMac was one of the first banks to collapse. It was found that they owned virtually zero mortgages and had "securitized" the rest which is to say they never loaned the money or got paid off by a successor. Now the servicing rights on IndyMac have been sold. So when the time came for trial he finds the lawyer fighting with his own witness. It seems that she would not say she worked for IndyMac because she didn't. That meant there was no corporate representative present to testify for the plaintiff. case over? Not according to what we have seen where IndyMac foreclosures continue to be rubber stamped by Judges who do not understand the gravity of the situation.
The precedent being set is for anyone who knows about a default to race to the courthouse with a complaint to foreclose after fabricated a notice of default and asserting themselves as the successor to whoever the borrower was paying. The borrower doesn't know the difference and generally doesn't care because they mistakenly think they are screwed no matter what. So the pretender lender that was collecting takes it time partly because they are simply collecting fees on "non-performing" loans. Meanwhile our creative criminal goes in and alleges that he is the holder of a lost note, submits affidavits, but of course stays away from the essential allegation that there ever was a transaction between himself and the borrower. These days Judges don't seem to require that.
Judgment is entered for our creative criminal and he becomes by court order, the creditor who can submit a credit bid at auction. He makes the non-cash bid at the auction and presto he just got himself a free house which he sells at discount on the open market. He only needs to do a few of those before he vanishes with a few million dollars. In fact, we have learned that such "foreclosures" are going on now sometimes creatively named such that it looks like the name of a bank. That is why I have been saying for 7 years that the foreclosures, if they are allowed to proceed, will eventually create chaos in the marketplace.
You might ask why the banks don't raise a big stink about this practice. The answer is that there are only a few such scams going on at the moment. And the banks are relying on the loopholes created in pleading practice to get their own foreclosures through the same way as our criminal because they really don't own the loan or even the servicing rights. Yup! That is called a syllogism: if the creative criminal is a criminal for doing what he did, then the bank or anyone else who engages in the same behavior is also a criminal.
And that is why the justice department and regulators are ramping up their investigations and charges, getting ready to indict the bankers who thought they were untouchable. If you read the reports of securities analysts, you will see three types of authors — those who obviously have drunk the Kool-Aide and believe Bank of America and Chase hinting the stock is a good buy, those who are paid to plant pretty articles about the banks, and supposedly declining foreclosures and increasing housing prices, and those who have looked at the jury conviction of Countrywide, looked at the pace of settlements, and looked at the announcements that there are many more investigations and charges to be resolved, and who have seen the probability of indictments, and they conclude that BOA is soon going to be on the chopping block for sale in pieces and the same will happen with Chase, Citi and maybe even Wells.
While the media is not paying attention to the impending doom of the mega banks, the market is discounting the stock and the book value of these companies is dropping like a stone because real investment analysts under stand that much of what is being carried on the books as assets, is really worthless garbage. Charges of fraud are announced practically everyday, saying that the banks defrauded investors, defrauded Fannie and Freddie, and defrauded each other, as well as insurance companies and counterparties on credit default swaps. In other words it is pretty well settled that the sale of mortgage bonds was a sweeping fraudulent scheme and that the word PONZI scheme is accurate, not some conspiracy theory as I was treated back in 2007-2010.
So now that we know that there was complete fraud at one end of the stick (where the funding for the origination and acquisition of mortgages took place), the question is why is anyone looking at foreclosures as inevitable or proper or even possible. It is the same stick. If one end is burning then it is quite likely that the other end will be burning soon and that is exactly what I predict for the coming months.
Having been in court multiple times over the last month representing clients seeking to retain their homes it is readily apparent that the Judges are changing their minds about whether the foreclosure is inevitable or that collection by these creative criminals is wise or legal — i.e., whether the enire exercise involves an arrogant willingness to commit perjury. Since the mortgages were part of the scheme and the part where the lender appeared with the money is covered in fraud, it is certainly reasonable to assume that the the fraudulent schemes included the origination and transfer of mortgage paper. And that is exactly the case.
If it wasn't the case there never would have been fraud at the top because the investors would be on the note and mortgage and some some nominee of the broker dealer ("BANK") or they would have been on a recorded assignment closed out within 90 days of the start of the REMIC trust, which would have been funded by money from investors paid to the investment bank (broker dealer) who then forwarded the net proceeds tot he Trust. None of that ever happened, though, which is how the fraud was enabled.
Practice Hint: I like to demonstrate by drawing a large "V" where the bottom is the closing agent, the left side is the money trail and the right side is the paper trail — and showing that they never meet. That means the paper trail is a fictional story about transactions that never occurred. The money trail is actual facts and data showing actual transactions where money exchanged hands but there was no documentation. The "Trust" was never funded with money or assets, so the money went straight down the left side from the investors at the top of the left side to the closing agent, who applied the investors money to close a transaction that was documented as though the originator had loaned the money. The same reasoning applies to transfers and assignments.
The core of the cases filed by the banks is that the Note is prima facie evidence that a transaction occurred. It is entitled to a presumption of validity. But where the borrower denies the transaction ever occurred, and files the right discovery to get evidence of the wire transfers and canceled checks, the banks go wild because they know their entire case will not only fall apart but subject them to prosecution.
Which brings us to Marshall Watson, who seeks to be licensed again to practice law, and David Stern who is about to be disbarred forever. The good news is that they were disciplined for fabrication and forgery of documents. The bad news is that the inquiry stopped there and nobody ever asked why it was necessary to fabricate or forge documents.
FRAUD! In Foreclosure Court Indymac/Onewest Doesn't Own Notes and Mortgages, But "They" Continue To Foreclose Anyway
–Suspended Ft. Lauderdale foreclosure mill head seeks return
Florida Bar referee calls for ex-foreclosure king's disbarment
Filed under: CDO, CORRUPTION, evidence, expert witness, Fannie MAe, foreclosure, foreclosure mill, GARFIELD GWALTNEY KELLEY AND WHITE, investment banking, Investor, MODIFICATION, Mortgage, Motions, Pleading, Servicer | Tagged: Bank of America, Chase, Citi, creative criminals, indictments, INDYMAC, Matt Weidner, mortgage bond fraud, mortgage note fraud, Ponzi scheme, pretender lender, Wells | 195 Comments »
The Truth Keeps Coming: When Will Courts Become Believers?
If you are seeking legal representation or other services call our Florida customer service number at 954-495-9867 (East Coast) and for the West coast the number remains 520-405-1688. Customer service for the livinglies store with workbooks, services and analysis remains the same at 520-405-1688. The people who answer the phone are NOT attorneys and NOT permitted to provide any legal advice, but they can guide you toward some of our products and services.
The selection of an attorney is an important decision and should only be made after you have interviewed licensed attorneys familiar with investment banking, securities, property law, consumer law, mortgages, foreclosures, and collection procedures. This site is dedicated to providing those services directly or indirectly through attorneys seeking guidance or assistance in representing consumers and homeowners. We are available to any lawyer seeking assistance anywhere in the country, U.S. possessions and territories. Neil Garfield is a licensed member of the Florida Bar and is qualified to appear as an expert witness or litigator in in several states including the district of Columbia. The information on this blog is general information and should NEVER be considered to be advice on one specific case. Consultation with a licensed attorney is required in this highly complex field.
Editor's Comments and Practice Suggestions: On the heels of AG Eric Holder's shocking admission that he withheld prosecution of the banks and their executives because of the perceived risk to the economy, we have confirmation and new data showing the incredible arrogance of the investment banks in breaking the law, deceiving clients and everyone around them, and covering it up with fabricated, forged paperwork. And they continue to do so because they perceive themselves as untouchable.
Practitioners should be wary of leading with defenses fueled by deceptions in the paperwork and instead rely first on the money trail. Once the money trail is established, each part of it can be described as part of a single transaction between the investors and the homeowners in which all other parties are intermediaries. Then and only then do you go to the documentation proffered by the opposition and show the obvious discrepancies between the named parties on the documents of record and the actual parties to the transaction, between the express repayment provisions of the promissory note and the express repayment provisions of the bond sold to investors.
Practitioners should make sure they are up to speed on the latest news in the public domain and the latest developments in lawsuits between the investment banks, investors and guarantors like the FHA who have rejected loans as not conforming to the requirements of the securitization documents and are demanding payment from Chase and others for lying about the loans in order to receive 100 cents on the dollar while the actual loss was incurred by the investors and the government sponsored guarantors.
Another case of the banks getting the money to cover losses they never had because at all times they were mostly dealing with third party money in funding or purchasing mortgages. It was never their own money at risk.
Three "deals" are now under close scrutiny by the government and by knowledgeable foreclosure defense lawyers. For years, Chase, OneWest and BofA have taken the position that they somehow became the owner of mortgage loans because they acquired a combo of WAMU and Bear Stearns (Chase), IndyMac (OneWest), and a combo of Countrywide and Merrill Lynch (BofA).
None of it was ever true. The deals are wrapped in secrecy and even sealed documents but the truth is coming out anyway and is plain to see on some records in the public domain as can be easily seen on the FDIC site under the Freedom of Information Act "library."
The naked truth is that the "acquiring" firms have very complex deals on those mortgage loans that the acquiring firm chooses to assert ownership or authority. It is a pick and choose type of scenario which is neither backed up by documentation nor consideration.
We have previously reported that the actual person who served as FDIC receiver in the WAMU case reported to me that there was no assignment of loans from WAMU, from the WAMU bankruptcy estate, or the FDIC. "if you are looking for an assignment of those loans, you are not going to find it because there was no assignment." The same person had "accidentally" signed an affidavit that Chase used widely across the country stating that Chase was the owner of the loans by operation of law, which is the position that Chase took in litigation over wrongful foreclosures. Chase and the receiver now take the position that their prior position was unsupportable. So what happens to all those foreclosures where the assertions of Chase were presumed true?
Now Chase wants to disavow their assumption of all liabilities regarding WAMU and Bear Stearns because it sees what I see — huge liabilities emerging from those "portfolios" of foreclosed properties that were foreclosed and sold at auction to non-creditors who submitted credit bids.
You might also remember that we reported that in the Purchase and Assumption Agreement with the FDIC, wherein Chase was acquiring certain operations of WAMU, not including the loans, the consideration was expressly stated as zero and that the bid price from Chase happened to be a little lower than their share of the tax refund to WAMU, making the deal a "negative consideration" deal — i.e., Chase was being paid to acquire the depository assets of WAMU. Residential loans were not the only receivables on the books of WAMU and the FDIC receiver said that no accounting was ever done to figure out what was being sold to Chase.
Each of the deals above was complicated by the creation of entities (Maiden Lane LLCs) to create an "off balance sheet" liability for the toxic loans and bonds that had been traded around as if they were real.
Nobody ever thought to check whether the notes and mortgages recorded the correct facts in their content as to the cash transaction between the borrower and the originator. They didn't, which is why the investors and the FDIC both now assert that not only were the loans not subject to underwriting rules compatible with industry standards, but that the documents themselves were not capable of enforcement because the wrong payee is named with different terms of repayment to the investors than what those lenders thought they were buying.
In other words, the investors and the the government sponsored guarantee organizations are both asserting the same theory, cause of action and facts that borrowers are asserting when they defend the foreclosure. This has been misinterpreted as an attempt by borrowers to get a free house. In point of fact, most borrowers simply don't want to lose their homes and most of them are willing to enter into modifications and settlements with proceeds far superior to what the investor gets on foreclosure.
Borrowers admit receiving money, but not from the originator or any of the participants in what turned out to be a false chain of securitization which existed only on paper. The Borrowers had no knowledge nor even access to the knowledge that they were actually entering into a loan transaction with a stranger to the documents presented at the loan "closing." This pattern of table funded loans is branded by the Truth in Lending Act and Reg Z as "predatory per se." The coincidence of the money being received by the closing date was a reasonable basis for assuming that the originator was not play-acting, but rather actually acting as lender and underwriter of the loan, which they were certainly not.
The deals cut by Chase, OneWest and BofA are models of confusion and shared losses with the FDIC and other investors who participated in the Maiden Lane excursion. The actual creditor is definitely not Chase, OneWest nor BofA. Bank of America formed two corporations that merely served as distractions — Red Oak Merger Corp and BAC Home Loans and abandoned both after several foreclosures were successfully concluded by BAC, which owned nothing.
As we have previously shown, if the mortgage securitization scheme had been a real financial tool to reduce risk and increase lending, the REMIC trust would have ended up on the note and mortgage, on record in the office of the County Recorder. There would have been no need to establish MERS or any other private database in which trades were made and "trading profits" were booked in order to siphon off a large chunk of the money advanced by investors.
The transferring of paper does not create a transaction wherein a loan is proven or established in law or in fact. There must be an actual transaction in which money exchanged hands. In most cases (nearly all) the actual transaction in which money exchanged hands was between the borrower and an undisclosed third party entity.
This third party entity was inserted by the investment bankers so that the investment bank could claim ownership (when legally the loans already were owned by the investors) and an insurable interest in the loans and bonds that were supposedly backed by the loans. This way the banks could assert their right to proceeds of sale, insurance, and credit default swaps leaving their investor clients out in the cold and denying the borrowers the right to claim a reduction in the liability for their loan.
In litigation, every effort should be made to force the opposition to prove that the investor money was deposited into the a trust account for the REMIC trust and that the REMIC trust actually paid for the loans. Actually what you will be doing is forcing an accounting that shows that the REMIC was never funded and was never the buyer of the loans. Hence nobody in the false securitization chain had any ownership of the debt leading to the inevitable conclusion that for them the note was unenforceable and the mortgage was a nullity for lack of consideration and a lack of a meeting of the minds.
Once you get to the accounting from the Trustee of the Trust, the Master Servicer and the subservicer, you will uncover trades that involve representations of the investment bank that they owned the loans and in fact the mortgage bonds which were clearly pre-sold to investors before the first application for loan was ever received.
Thus persistent borrowers who litigate for the actual truth will track the money and then show that the cash transactions differ from the documented transactions and that the documented transactions lacked consideration. The only way out for the banks is to claim that they embraced this convoluted route as agents for the investors, but then that still means that money received in federal bailouts, insurance and credit default swaps would reduce the receivable of the actual creditors (investors) and thus reduce the amount payable by the actual borrowers (homeowners).
The unwillingness of the Department of Justice to enforce long standing laws regarding fraud and deceit, identity theft and other crimes, tends to create an atmosphere of impunity a round the banks and a presumption that the borrowers are merely technical objections of a certain number of documents not having all their T's crossed and I's dotted.
From a public policy perspective, one would have to concede that protecting the banks did nothing for liquidity in the marketplace and nothing for the credit markets in particular. Holder's position, which I guess is also Obama's position, is that it is better to allow average Americans to sink into poverty than to hold the banks and bankers accountable for their white collar crimes.
Legally, if the prosecutions ensued and the cases were proven, restitution would be ordered based not on some back-room deal but on approval of the Court. Restitution would clawback much of the capital of the mega banks who are holding that money by virtue of illegal transactions. And restitution would provide the only stimulus to the economy that would be fundamentally sound. Investors and borrowers would both share in the recovery of at least part of the wealth lost to the banks during the mortgage maelstrom.
I have no doubt that the same defects will appear in auto loans, student loans and other forms of consumer loans especially including credit card loans. The real objection of the banks is that after all this effort of stealing the money and the homes they might be forced to give it all back. The banks perceive that as a "loss." I perceive it as simple justice applied every day in the courtrooms of America.
JPM: The Washington Mutual Story
Bear Stearns, JPMorgan Chase, and Maiden Lane LLC
Mistakenly Released Documents Reveal Goldman Sachs Screwed IPO Clients
Filed under: bubble, CDO, CORRUPTION, currency, Eviction, foreclosure, GTC | Honor, Investor, Mortgage, securities fraud | Tagged: BEAR STEARNS, BofA, Chase, credit default swaps, criminal prosecution, INDYMAC, insurance, Merrill Lynch, mortgage loans, OneWest, restitution | 136 Comments »
Walls Continue to CLose in On Banks in Courts Once Hostile to Borrower Defenses
McDonald v OneWest
This case should be read more than once
When I started writing about legal defenses to foreclosures that appeared patently fraudulent to me, I thought it might only take a few months for things to catch on. About the timing I have been consistently wrong. About the substance I have been consistently right.
Here again, the party seeking foreclosure not only failed in its current effort to do so, but was ordered to pay $25,000 within 7 days for forcing the homeowner's attorney to fight tooth and nail for items that were or should have been at their fingertips, they had no reason to withhold, and should have been anxious to supply if the foreclosure was real.
The only potential error I see in the homeowner's case is that there appears to be an admission that Indy Mac was indeed the party who was the source of the loan — a fact which is nearly universally presumed and virtually always wrong in today's foreclosures. Not knowing the actual facts of the case I can only speculate that this was an oversight, but it is possible that it wasn't an oversight and that Indy Mac did in fact make the loan, booked it as a loan receivable, and then sold it into the secondary market for securitization.
There are several very important issues discussed rationally and without bias in this very well-written decision:
- Dates DO Matter: If the authorization to sign something is received after the signature is executed it isn't any good. Lying about it and then fabricating documents to cover up the first lie are grounds for sanctions.
- Allegations of holder status are no substitute for facts and evidence. The supposed right to request it is not the same as holding, possessing or owning the note. Execution and recording of substitution of trustee, notice of default, notice of sale are all void if the party stated as the holder is not the holder.
- Ownership counts, which means that in order to submit a credit bid at a foreclosure action, the books and records of all the relevant parties must be open to inspection and review to determine what balance, if any, exists, on the records of the owner of the debt — i.e., the party who would actually lose money if the loan was not paid, and the amount of the principal and accrued interest due, if any, after deductions for all receipts.
- Agency either exists or it doesn't. And the paramount element of agency is control by the principal of the agent. There is, however, contractual obligations that come into play here. So if the investment bank received payments to mitigate damages on loans it either did so as agent for the investor or because they were contractually bound to do so as a vendor thus reducing the balance due on the bond. Either way, the balance due is reduced as to that creditor. It might be shifted to the party who paid who in turn might have a right of contribution unless they waived that right (which the insurance companies and CDS counterparts did in fact waive), but either way the new debt is no secured unless there was a purchase of the loan.
- Rules of Civil Procedure do matter and are "not optional." If discovery requests, qualified written requests, debt validation letters are sent, answers are expected and due. The fact that the QWR is long does not mean it is invalid.
- Damages are possible, but you need to plead and prove them and that pretty much goes to whether these parties ever had any right to collect any money or enforce any note or any debt or enforce any mortgage against the homeowner. If the answer is yes, that if they get their act together, they can foreclose, there will likely be no damages. If the answer is no, which more likely than not is the case in current foreclosures, then damages properly pleaded and proven are easily sustained.
- Discovery is not a toy. The answer or the production is due.
- Hearsay is inadmissible and the business records exception, as stated by dozens of courts before this one, where the witness or declarant testifed for "defendants chose to offer up what can only be described as a "Rule 30(b)(6) declarant" who regurgitated information provided by other sources" then we are taking hearsay and turning it into evidence without any personal knowledge or testing of the truth of the matter asserted.
- Judges are not stupid. They know a lie when they hear it. But what happens after that depends upon the trial experience and knowledge of the lawyer. Don't expect the Judge to go into orbit and give you everything just because he found that the other side lied. You still have a case to prove.
Washington J Lasnik Order Regarding MSJS
Filed under: bubble, CDO, CORRUPTION, currency, Eviction, foreclosure, GTC | Honor, Investor, Mortgage, securities fraud | Tagged: business records, civil procedure, discovery, hearsay, INDYMAC, McDonald v OneWest, OneWest | 89 Comments »
Curious and Shocking Failure to Follow the Law: BofA, Chase and OneWest
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The selection of an attorney is an important decision and should only be made after you have interviewed licensed attorneys familiar with investment banking, securities, property law, consumer law, mortgages, foreclosures, and collection procedures. This site is dedicated to providing those services directly or indirectly through attorneys seeking guidance or assistance in representing consumers and homeowners. We are available to any lawyer seeking assistance anywhere in the country, U.S. possessions and territories. Neil Garfield is a licensed member of the Florida Bar and is qualified to appear as an expert witness or litigator in in several states including the district of Columbia. The information on this blog is general information and should NEVER be considered to be advice on one specific case. Consultation with a licensed attorney is required in this highly complex field.
Editor's Announcement: Based upon current information and direct interviews with participants I have come to three broad conclusions:
- Bank of America never acquired any loans from Countrywide.
- Chase never acquired any loans from Washington Mutual
- OneWest never acquired the Indy Mac loans but instead entered into a loss sharing arrangement wherein the FDIC would absorb 80% of the loss and OneWest would receive the proceeds from foreclosure.
BofA never merged with BAC home Loans and the entity created to merge with Countrywide was Red Oak Merger Corp. which like the REMIC trusts was completely ignored. Neither Countrywide, red Oak BAC nor Bank of America ever paid one cent to acquire the loan balances. Hence the paperwork showing "for value received" is a lie.
Chase Bank acquired the banking operations of WAMU for consideration that is expressly stated as zero. No assignment of WAMU loans exist, according to the FDIC receiver for WAMU. In most cases neither WAMU nor Chase ever spent one nickle funding or acquiring loans.
OneWest was capitalized with less than $2 billion and even that is not confirmed inasmuch as there doesn't seem to be any transaction in which money was moved into a OneWest bank account. Like the above, neither Indy Mac nor One West ever paid for the loans.
All of that means is that they are not injured parties if the borrower doesn't pay nor are they responsible parties if the investor is not paid. Their claim of agency just doesn't cut it. For purposes of collecting insurance and proceeds from credit default swaps and federal bailouts, they claim ownership and then after payment, they claim agency so they can chase the foreclosure too, in addition to being paid several times over. But for purposes of sharing in the bounty of betting against the same mortgage bonds as they were selling to the investors the banks consider that proprietary trading and insist on the investors (lenders) taking the loss.
Practice hint: dig deeper and follow the money trail and don't think that the note is part of the money trail. It isn't. Only a cancelled check or wire transfer receipt, or ACH confirmation or check 21 confirmation would be proof of ownership (proof of payment) and proof of loss (entitling them to submit a credit bid at the auction of the property). Stick with this strategy and you won't be sorry. The failure to come up with evidence of an actual injury to an actual party is deadly not only on the facts but for jurisdictional purses of standing.
The banks have cleverly steered the conversation in court to why they should not be required to produce the actual records of actual transactions affecting the loan or the loan pool claiming an interest in the pool. They only want the court to look at the note and mortgage and the fabricated "allonges", endorsements, transfers, sales, assignments, all of which are evidence and carry certain presumptions. But he story told by those documents turns out to be a fiary tale when you look at where and when money exchanged hands and between what parties.
The banks are avoiding the obvious: that they claim a REMIC trust exists and was funded (both of which are probably untrue), and that the REMIC trust acquired the loan by buying it (without any evidence of a money exchange) backdated to when the loan was "closed" [note it is our position that none of these loans were closed, since they have yet to be completed].
If the Trust DID own the loan, then what effect does a fabricated assignment have from the originator, aggregator or anyone else other than the trust? The pretender lenders can't have it both ways. They can't say they transferred the loan into the trust in 2006 and then claim that an assignment in 2011 from Countrywide to Bank of America conveyed anything.
Filed under: bubble, CDO, CORRUPTION, currency, Eviction, foreclosure, GTC | Honor, Investor, Mortgage, securities fraud | Tagged: Bank of America, Chase, countrywide, INDYMAC, OneWest, Washington Mutual | 301 Comments »
What's the Next Step? Consult with Neil Garfield
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Editor's Comment: Among the unsung culprits in the false securitization scheme were the developers who conspired to raise prices to unconscionably high levels and the Wall Street funding that loaned the money for construction of new residential palaces. The reason the developer did it was once again, no risk and all profit, knowing that no matter how high the price, the appraisal would be approved. And the reason why IndyMac and other fronts for Wall Street's tsunami of money did it was the same, no risk and all profit.
So what we have going on is that a few bankers are being thrown under the bus to take the blame for "isolated"instances of malfeasance. Their defense bespeaks of the widespread nature of this crime and how it created its own context of right and wrong. Many of them are saying they were following industry standards. Here's the rub: they are right. The problem is that the new industry standards were illegal, fraudulent and disgraceful.
So here we have three IndyMac executives — out of thousands of people who did the exact same thing they did — accused of approving unworkable loans that were never repaid because in every Ponzi scheme the result is the same: when people stop putting in new money, the scheme collapses.
The question is not why these three are being charged in a civil action. The real questions are why are they not being charged with criminal fraud, and why thousands of other individuals who engaged in identical behavior are not being charged both civilly and criminally.
Then we have an interesting question: if it was improper for these three IndyMac execs to approve bad loans to developers, why are there no charges pending for approving bad loans and misleading homeowners?
DOJ keeps saying that they did not accumulate enough evidence to prove a criminal case, which as we all know, must be proven beyond a reasonable doubt. But I say the DOJ simply went for the low-hanging fruit, intimidated by the complexity of securitization. But if they take two steps back and get their heads out of the thickets, they will see a simple Ponzi scheme that can be prosecuted easily.
Other than a criminal environment, what bank or other organization would set bonuses based upon the number of loans or the amount of money they moved? In the real world where right and wrong are inserted into the equation, bonuses, salary and employment is based upon the perception of management that an individual is contributing to a profit center. Here the bank is said to have "lost money" much of which was off set by insurance, Federal bailout and gigantic fees paid tot he bank for pretending to be a lender when they were not.
Criminal larges are way overdue against both the corporate mega banks and the titans who ran them, right down the line to anyone who had enough knowledge to realize the acts they were committing were wrong. But the money was too damn good — getting paid 4-10 times usual compensation was enough for them to keep their mouths shut — but not in all cases. Some people did quit or blow whistles. They are buried in the mounds of documents and statements taken by law enforcement all over the country.
It is not the lack of evidence that keeps the prosecutions, even the civil ones, from becoming a wave, it is the will of the people charged with law enforcement decisions whose opinions were guided by political pressures. The Obama administration owes a better explanation of what is happening in the housing market and how it can be fixed. Without taking economists seriously on the importance of housing and prosecuting those who break the rules, the economy will continue to drag.
Japan just announced they had an annual GDP decline of 3.5%. Remember when we afraid japan's money would take over the world? Their shrinking economy is due to the fact that they ideologically stuck to their guns and refused to stimulate the economy, protect their currency, and reign in the big money people. All they needed was a philosophy that the common man doesn't matter. Hopefully our election which broke in favor of the democrats because of demographics, will teach a lesson — that without the success and hopes and good prospects for the common person entering the workforce, the economy can stall for decades.
FDIC seeks damages from three former IndyMac executives
Trial begins on a civil lawsuit that accuses them of negligence in approving loans that developers and home builders never repaid.
When the Federal Deposit Insurance Corp. seized Pasadena housing lender IndyMac Bank four years ago, the scene resembled the grim bank failures of the 1930s.
Panicked depositors, seeking to reclaim their money, lined up outside branches of the big savings and loan, whose collapse under the weight of soured mortgage and construction loans helped usher in the financial crisis and biggest economic downturn since the Great Depression.
As those memories fade, the government's effort to reclaim losses stemming from the financial debacle grinds on, with one IndyMac case winding up this week before a federal jury in Los Angeles.
Test your knowledge of business news
The civil lawsuit seeks damages from three former IndyMac executives, accusing them of negligence in approving 23 loans that developers and home builders never repaid, costing the bank almost $170 million.
The executives approved ill-advised loans because they earned bonuses for beefing up lending to developers and builders, said Patrick J. Richard, a lawyer representing the FDIC.
"They violated their duties to the bank," Richard said in his opening statement to the jury Tuesday. "They violated standards of safe and reasonable banking."
The bankers deny wrongdoing, contending that they made solid business decisions, which at the time were well-considered and approved by regulators and higher-ups at IndyMac.
"This case," defense attorney Damian J. Martinez said in his opening statement Wednesday, "is about the government evaluating these loans with 20/20 hindsight after the greatest recession we've had since the Depression in the 1930s."
The defendants — Scott Van Dellen, Richard Koon and Kenneth Shellem — ran IndyMac's Homebuilder Division, a sideline to the thrift's main business of residential mortgage lending. Court filings show the FDIC settled its case against a fourth former executive at the builder operation, William Rothman, by agreeing to a $4.75-million settlement to be paid by IndyMac's insurance companies.
The trial, playing out before U.S. District Judge Dale S. Fischer, highlights how federal authorities — often stymied at bringing criminal cases against major players in the financial crisis — have pursued civil damages on a number of fronts.
One high-profile example involved the Securities and Exchange Commission's investigation of Countrywide Financial Corp. of Calabasas. The SEC exacted a $67.5-million settlement from former Chief Executive Angelo Mozilo, who ran Countrywide as it expanded to become the nation's largest purveyor of subprime and other high-risk mortgages.
A Justice Department probe of Mozilo had found too little evidence to support a criminal prosecution. Admitting no wrongdoing, Mozilo paid $22.5 million of the SEC settlement himself, with corporate insurance policies covering most of the balance.
On another front, federal and state prosecutors have filed a series of civil lawsuits accusing major home lenders including Bank of America Corp., Wells Fargo & Co., Citigroup Inc. and JPMorgan Chase & Co. of fraud and recklessness that cost taxpayers and investors billions of dollars.
Taking a different approach, the FDIC suits aim to recover losses in its insurance fund, which compensates depositors when banks fail. The agency says it has authorized lawsuits against 665 insiders at 80 institutions seized during the recent crisis, with 33 suits already filed.
The IndyMac case now going to trial, filed in July 2010, was the first of those suits.
Recoveries typically are modest compared with the losses.
IndyMac's failure cost the federal insurance fund more than $13 billion, the largest loss among the 463 banks that have failed since 2008. But the FDIC is seeking only $170 million in the suit that has gone to trial in L.A., plus $600 million in a separate suit against former IndyMac Chief Executive Michael Perry.
(Perry contends that the pending lawsuit, accusing him of negligently allowing $10 billion in dicey mortgages to pile up on IndyMac's books, is without merit.)
The FDIC is proceeding with the IndyMac case despite a setback in its efforts to collect from IndyMac's insurance. U.S. District Judge Gary Klausen ruled July 2 that IndyMac officer and director insurance policies at the time of its failure cannot be used to cover any damages the agency wins against former bank insiders.
An appeal of that ruling is before the U.S. 9th Circuit Court of Appeals. If the ruling stands, the FDIC could only try to recover damages by attaching the defendants' personal assets.
The IndyMac defendants' earnings were modest by the standards of executives running large financial firms, such as Mozilo, whose take during the housing bubble has been estimated at nearly $470 million. But their compensation — in the $500,000 annual range for Koon and Shellem and well over $1 million for Van Dellen, who headed the Homebuilder Division — merited note by the FDIC.
Richard, the lawyer making the FDIC's opening statement, noted that Van Dellen had rejected a suggestion by Perry in July 2006, as cracks appeared in the housing markets, that IndyMac take a cautious approach in its lending to home builders.
Van Dellen replied in an email that "now is the time to pounce," Richard told the jury. "So what was his motivation? His bonus for 2006 production was 4 1/2 times his base salary — $914,000 — tied to production" of more builder loans.
Filed under: bubble, CDO, CORRUPTION, currency, Eviction, foreclosure, GTC | Honor, Investor, Mortgage, securities fraud | Tagged: bailout, DOJ, FDIC, INDYMAC, Ponzi | 21 Comments »


text:
UCC to get Zilber grant
The United Community Center will receive a $500,000 grant from the Zilber Family Foundation for its drug and alchol treatment program.
Details of the grant will be coming later today.
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