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So, how's everyone holding up without fantasy baseball every day? I don't know what to do with myself! This week I wandered into a Starbucks and told the coffeerista about Aaron Sanchez for 2017. Then I sobbed into a cheddar scone until someone asked me to leave. We've gone over the final 2016 fantasy baseball rankings for hitters and the top 20 starters. This is different than Final Fantasy rankings where you rank Final Fantasy 1 thru Final Fantasy 15. That's hardcore nerd shizz! This is simply fantasy baseball, we're softcore nerds like Emmanuelle. So, there's no more of these godforsaken recap posts left. You're welcome. I, my over-the-internet friend, will be talking next about 2017 rookies. Anyway, here's the top 40 starters for 2016 fantasy baseball and how they compare to where I originally ranked them:Please, blog, may I have some more?
Julio Teheran
All my fantasy baseball titles seemed so far away.
Now it looks as though one is here to stay *sung in a very fast voice* oh, crap, nope, because I drafted Matt Holliday,
Oh, why did I believe in Holliday…day…day…day.
Suddenly! Jacob deGrom's arm is not half of what it used to be.
There's a shadow hanging over me,
Oh, it's Giancarlo's injured groin that I made of plaster of Paris and that just came to me suddenly!
Why the season had to go, I don't know, it wouldn't say… because it can't talk, it's a baseball season that ended yesterday…yesterday…yesterday!
Fantasy Baseball was such an easy game to play,
Now I need a mother's basement to hide away.
Oh, I believe in yesterday…day…day.
*sniffles* Here, take a tissue. You have to excuse me, I don't have any clean ones. What will we do for the next few months without an update on a Mets' pitcher elbow? Does Daniel Murphy's butt hurt or is he just butt-hurt? What will we do without a Bryce Harper injury update? WHAT? WILL? WE? DO? Prepare for next season, of course. But, first, let's bask in the last day of the season. Today is the day when you realize you've spent 27,000 man hours this summer beating eleven other strangers to win a virtual trophy, and it feels great! Anyway, here's what else I saw this weekend in fantasy baseball:Please, blog, may I have some more?
You literally can't find a middle infielder with less than 20 homers. You can't. Try it. See? This year there are more players with 20 homers than any other season in the history of baseball. Some conspiracy theorists have said the new commissioner, Our Manfred, is sticking Capri Sun straws into baseballs and juicing them, but this year is odder than that and deserves a better conspiracy theory. No one is hitting 50+ homers like during the Steroid Era. Only one guy is even close to 50 homers. Instead of a few guys doing insane damage in the power department, everyone is doing better, moderately. It's the trickle down theory. If you're not familiar with that, I'll explain it. When Kim Kardashian first appeared on the scene, only she was smoking hot, but rather than Kim hogging the hotness to herself, it trickled down. Khloe went from a 3 to a 5, Kourtney went from a 5 to a 7, Kris went from a 6 to a 8, the two Jenner girls came of age, going from untouchable to 8's, and even Bruce went from a zero to a three, becoming a woman that you'd throw one if you were drunk enough. This is also what's happened in the majors. Jean Segura, and all middle infielders, went from fours or fives to 20s. Yesterday, Segura went 1-for-4 with his 20th homer, hitting .316, to go with his 30 steals. It's going to be hard in 2017 to know if these are legitimate gains in power, for Segura and a whole slew of other players, or if half the league is going to regress. Kinda like Brody Jenner, who was so popular before Kim, ahem, came on the scene. Anyway, here's what else I saw yesterday in fantasy baseball:Please, blog, may I have some more?
In order to be competitive, the Marlins would need All-Stars at every position all farmed from their minor league system. Sorta like what the Cubs have managed to do. Not impossible, but that's what it would take for the Marlins because they are cheap AF. By the way, AF is my favorite acronym. Props to whoever first started using it. Feels like it started on Twitter because of the character limit. Keeps shizz short and simple AF, kinda like me (short and simple). Any the hoo! I was saying the Marlins need to be precise AF (I'm overusing it now) with their minor league system like they were with Jose Fernandez. He's AF as AF comes. His nickname should no longer be Jo-Fer but AF. Or maybe AF-Fer. Nah, that looks like a trade union. A-Fer? That looks like algebra. Fernandez should own Abercrombie & Fitch he's so AF. Yesterday, Jose Fernandez went 8 IP, 0 ER, 3 hits, zero walks and 12 Ks. He has 253 Ks in 182 1/3 innings. Seriously, digest that for a second. WTF AF?! Of course, I wish the Marlins would shut him down until 2017, but I have no chance of owning him next year. Not that I don't love him. He's the best pitcher in the game if I'm building a dynasty league. Yeah, I said it. I want him over Kershaw. Kershaw has been durable up until this year, but all pitchers are durable up until the point when they're not. At one point, Jake Peavy was durable AF, too. Anyway, here's what else I saw yesterday in fantasy baseball:Please, blog, may I have some more?
You know one of those posters where they feature celebrities from different eras that may or may not have ever been together in the same room? Like James Dean, Mickey Mouse and Lenny Bruce standing at a bar, smoking cigarettes. Okay, I'm pretty sure those three never hung out. In 75 years, when we're all dead and buried, except for maybe some of my preteen readers — YASSSSSS I never forget you! — they will decide to make a poster featuring some standouts from this year: Trump, Hillary, Nadiya from The Great British Bake Off. Also, on that poster will be one player from the 2016 World Champion Cubs team, the last Cubs team to win the World Series in 75 years. Which player will be on that poster made from the last remaining tree? I don't think it'll be David Ross, prolly not Arrieta, not for this year, maybe Bryant, maybe Rizzo, maybe Hendricks and maybe Jon Lester. Yesterday, pushed forward Lester's agenda to get on the "last tree poster" — 8 IP, 0 ER, 4 baserunners, 8 Ks, lowering his ERA to 2.40, moving his record to 17-4, and, since the All-Star break, it's a 1.47 ERA in 73 1/3 IP. His ERAs over the last four years: 3.75, 2.46, 3.34 and 2.40. And you thought Saberhagenmetrics were some contrived statistical model. Look in the mirror, and pfft yourself. Anyway, here's what else I saw yesterday in fantasy baseball:Please, blog, may I have some more?
a href="http://razzball.com/wp-content/uploads/2016/09/Sparky-Polastri.gif">
Look, on the one hand, I'm ashamed that I'm quoting Not Another Teen Movie. On the other, I'm surprised this wasn't a Keenan Ivory Wayans joint. On the third, more interesting hand that's simply a cut out of the hamburger helper off my beefaroni box, it allows me to reference back to one of the best teen comedy movies of all time: Bring It On. Or better put, this movie has four minutes worth of Sparky Polastri, and that's never enough and yet more than enough all at the same time. With all this said, my call today is Steven Brault or as I like to call him, 'the guy who gets to pitch against the Phillies'. If you've read anything I've written – or wrotten, if you wanna keep with title theme – you'll know that I love picking on Phillies. It's September and this should be clear to you but just in case it's not, here's a simple flowchart for you to think about. If you're not convinced by my conciseness, let's consider some other facts. The Phils have the worst wRC+, the fifth worst K%, and the second worst BB% in the majors this year. The fact they've been on a K tear of late – second worst K% over the last 30 and worst over the last 14 and 7 – makes this call even nicer. But the real kicker here? Brault is a mere $4,500 so he's in punt territory with 20 point upside. Seriously, this intro is AmPm: too much good stuff. But guess what, I have some even potentially greater takes down the road. So follow me past the italics, would you? Here's my 'y'all ready for this' hot taeks for this Wednesday, DK slate…follow me or perish, sweater monkeys!
New to DraftKings? Scared of feeling like a small fish in a big pond? Well reserve your spot in the 25 Team Razzball Exclusive League set to run Monday September 19th to wet your DK whistle. Just remember to sign up through us before you do. Wanna know what the best part is about signing up with us? The free subscription for the rest of the season to our DFSBot, that's what! For details on the how to, please visit our Razzball Subscriptions page.Please, blog, may I have some more?
Not quite as spiritually moving as John Lennon, but imagine for a moment Jose Abreu were to actually put together two solid halves in the same year. "Imagine there's no heaven, it's easy if you try. No 'He'll end up below Andrus,' for half the year. Above Andrus only this Jose guy. Imagine Abreu playing a decent, full season like today. Aha-ha… Imagine there's no countries. It isn't hard to do. Nothing to drop or trade for, and no 'Abreu's so cold it's like this hell has a fridge in it' too. Imagine all the people living to get a piece of…Abreu… You may say I'm a dreamer, but I'm not the only one! I hope some day Abreu'll be better than Andrus, and play an entire season as one." So, Jose Abreu hit two homers yesterday (3-for-7, 7 RBIs, and 21st and 22nd HRs), and he's been great recently, but it's hard to get that excited about a guy for 2017 who invariably takes three months off every year. Can't imagine he's a top 25 player ever again. You-WHO-OOH! Anyway, here's what else I saw this weekend in fantasy baseball:Please, blog, may I have some more?
Yesterday, Kyle Hendricks went 7 IP, 0 ER, 4 baserunners, 4 Ks, lowering his ERA (if that's even possible at this point) to 2.09. The Seattle museum, Experience Music Project is going to need to update their Hendricks section. EMP Tour guide, "In 1970, Hendricks said, 'I'm going to take my guitar, grab Janis, impregnate Afeni Shakur, have my lawyer write a letter that says Ben and/or Jerry can never name an ice cream after me while simultaneously sucking and blowing this joint. Then thirty-six years later, I'm going to win the NL Cy Young if the BBWAA votes based on ERA.' Now, let's move on to our five floors of Nirvana memorabilia. There's some interesting flannel stories I can't wait to share." No, of course, Kyle Hendricks isn't this good. His fastball velocity is down to 87 MPH, he's relying heavily on a changeup that isn't that much slower and his BABIP is absurdly low. Not saying you drop him, but if Hendricks does win the Cy Young, in 2017, the same faith that befell Dallas Keuchel this year will happen to Hendricks too. Anyway, here's what else I saw yesterday in fantasy baseball:Please, blog, may I have some more?
I'm being honest here when I say I don't think you can stop Gary Sanchez. Someone needs some breaking pitches and chloroform. It's a sequel, The Sanchize II: Homers > Butt Fumbles. Trivia: Gary, Indiana is the birthplace of the Jacksons; Gary Sanchez is a Thriller that Ben making balls Beat It, since Imma sing on a song that Michael sung. Yesterday, Chez Gary went 2-for-3 with his 9th homer in only his 19th game, as he hits .389. He has 9 homers in 19 games. Now is when you cackle deliriously. Paranoid cause you're a son like Elroy. You'd be happy as hell if Sanchez was the real deal. Please, tell me it's not Maas appeal. He had 10 homers in 71 games in Triple-A, so I'm all for the hype, but thinking he's going to be a top 3 catcher in 2017 might be a bit much due to three weeks of play. There's no leagues where I wouldn't own him right now, even if that meant starting him at utility. Anyway, here's what else I saw yesterday in fantasy baseball:Please, blog, may I have some more?
I had an idea to make the Olympics more watchable. You know how you watch it now and you're like, "Damn, he just ran the length of two football fields in 20 seconds? I mean, it looked like he was going fast, but the guy next to him ran it in 21 seconds, so it's hard to tell exactly how fast he was running." Enter my idea: in every event, there should one normal person competing so we get a better idea of how great the Olympians are next to average schmos. Tell me you wouldn't watch the platform diving if between the North Korean and Chinese diver, I was there trying to get the nerve up to jump from three floors up, then plunging awkwardly into the water on my back. Or running next to Usain Bolt, doing an 85-second 200 meter dash. So, this brings me to Kris Bryant, who right now is making other major leaguers look like 'normal people.' Yesterday, he went 5-for-5, 4 runs, 5 RBIs with his 29th and 30th homers. On our Player Rater, he's in the top five for the season. Member in the preseason when people were saying Bryant was going to strike out too much to draft in the 1st round? Those people are enjoying themselves some Jose Abreu! For 2017, it's gonna be hard to rank Bryant much later than the top five, as he enters only his age-25 season. Anyway, here's what else I saw yesterday in fantasy baseball:Please, blog, may I have some more?


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Cherokee Farmers Co-Op Inc
1020 W Main St Centre, Alabama 35960(256) 927-3135 Website
Print | Save | Directions
AboutCherokee Farmers Co-Op Inc is located at the address 1020 W Main St in Centre, Alabama 35960. They can be contacted via phone at (256) 927-3135 for pricing, hours and directions.
Cherokee Farmers Co-Op Inc has an annual sales volume of 5M – 9,999,999. .For more information contact John Mc Mc Clesky, Vice President or go to www.cherokeecoop.com
For maps and directions to Cherokee Farmers Co-Op Inc view the map to the right. For reviews of Cherokee Farmers Co-Op Inc see below.
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Key Contacts
- John Mc Mc Clesky
- Phone: (256) 927-3135

subset: commoncrawl


text:
Book online or call 800-246-8357This call is free. 24 hours a day; 7 days a week.
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Portuguese Clam Rice
Total Time
Prep 10 mins
Cook 20 mins
My mom taught me how to make this when I was a teenager and I've been making it ever since. This is great to accompany a fish dish.
Ingredients Nutrition
- 2 tablespoons olive oil
- 1⁄2 onion, chopped
- 2 garlic cloves, minced
- 3 tablespoons pimento paste (optional)
- 1⁄4 cup fresh parsley, chopped
- 1 (5 ounce) can clams, undrained
- 1 1⁄4 cups short-grain rice
- 1 1⁄4 cups canned tomatoes, pureed
- In a saucepan, cook onion and garlic in oil until tender.
- Add pimento paste and parsley. Cook for a couple of minutes.
- Drain clams but reserving liquid.
- Add the clams to the saucepan. Measure clam juice and add enough water to measure 1 1/4 cups of liquid.
- Add rice and tomatoes and bring to boil. Cover and reduce heat to low for 20 minutes.
- Add salt if necessary.
Most Helpful
This was a great side dish. I served it with Portuguese Style Shrimp and a side of Fava Beans. The tomato and red pepper flavour goes great with fish or seafood. Thanks Mina!!


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Discussion in 'iOS Jailbreak & Cydia' started by spacemenko, Nov 27, 2007.
Cause i dont connect via ftp....
View this topic! It has a list of a lot of sources you can add. Some of them may have GBA Roms in there.
Thanks a lot, but ive seen this topic and i dont see any repo or source about gba...
From the ScummVM wiki:
* Open Installer.app on a jailbroken iPhone or iPod touch. Use Google to find out how to jailbreak your specific version of the firmware on your device.
* Tap the "Sources" button in the bottom-right corner.
* Tap the "Edit" button in the top-right corner.
* Tap the "Add" button in the top-left corner.
* Enter http://urbanfanatics.com/scummvm.xml into the text area and tap "OK".
* Installer will refresh your sources. It may close. If so, reopen it.
* ScummVM is now available for install in the Games section.
I have the program but i havent the games...
Can't help you there, downloading lucasarts games is illegal.
Buy them in the store! Please Register or Log in to view images
Please Register or Log in to view images
Downloading gba roms is illigal to Please Register or Log in to view images I know where to download them though Please Register or Log in to view images
ya im in the same boat - i dont ftp, but maybe i will if i find it to be necassary. i am looking for a source for monkey island!!
** he forgot to mention to purchase these in-store you need a time machine to 1991.
use the time machine in the day of the tentacles game Please Register or Log in to view images
Separate names with a comma.


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Create Tasks in Zoho CTI from RingCentral with Tenfold
Tenfold provides software that works for Inside Sales, Customer Service & Call Centers by automatically logging calls to Zoho CTI. Get the power of Click to dial, an Advanced Analytics Dashboard, Tracking, Lead Management, Power Dialer, Phone Integration, and a Sales Prospecting Funnel. Read More
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September 28, 2012
A. SAMSON PILLAY AND ANTHONY RAMIREZ PLAINTIFFS,v.MILLARD REFRIGERATED SERVICES, INC. DEFENDANT.
A. Samson Pillay ("Pillay") and Anthony Ramirez ("Ramirez") filed this law suit against Millard Refrigerated Services, Inc. ("Millard") alleging claims under the Americans With Disabilities Act ("ADA"), 42 U.S.C. §§ 12102 et seq.*fn1 and several Illinois law claims. Ramirez alleges employment discrimination in violation of the ADA (count I) and retaliatory discharge under Illinois law (count III). Pillay alleges retaliation in violation of the ADA (count II) and state law claims of retaliatory discharge (count IV), libel/slander (count V), tortious interference with a prospective contract (count VI), and negligent spoliation (count VII).*fn2 Millard has moved under Federal Rule of Civil Procedure 56 for partial summary judgment as to counts I, II, IV, V, and VI. [Dkt. 82.] For the reasons explained below, the motion is denied with respect to counts I and II and granted with respect to counts IV, V, and VI.*fn3
FACTUAL BACKGROUND*fn4
Millard is a third party logistics company that warehouses its customers' perishable products in a refrigerated or frozen environment. (Def. L.R. 56.1 ¶ 3.) Millard does not own any of the products; rather, it receives and stores those products for a fee and then ships them elsewhere as directed by its customers. (Id. ¶ 4.) In 2000, Pillay began working at Millard's facility in Geneva, Illinois as a Human Resources Coordinator. (Id. ¶ 30.) Ramirez began working at Millard's Geneva facility beginning in 2008 as a temporary employee and later as a "regular" (as opposed to temporary) employee. (Id. ¶ 9.)
Anthony Ramirez
Before working at Millard, Ramirez worked at Home Depot as part of a freight team, stocking shelves after business hours. (Def. L.R. 56.1 ¶ 6.) In October 2007, while working at Home Depot, Ramirez suffered an on-the-job injury to his knee, which required surgery. (Id.) Ramirez was off work for a period of three months. (Id. ¶ 7.) By the time he returned to work at Home Depot, Ramirez had made a complete recovery. (Id.) He could do everything he had been able to do before the injury. (Id.)
In connection with the injury, Ramirez filed a Worker Compensation ("WC") claim and received a settlement in the amount of $12,000. (Def. L.R. 56.1 ¶ 6.) After submitting his WC claim, the Illinois Industrial Commission ("IIC") informed Ramirez that he had a 17.5 percent disability (or 17.5 impairment rating). (Id. ¶ 17.) In February 2008, approximately a month and a half after returning to work, Home Depot terminated Ramirez due to his failure to report an accident involving damage to merchandise. (Id. ¶ 8.)
During June, 2008, Ramirez was hired for a position at Millard through a temporary employment agency. (Def. L.R. 56.1 ¶ 9; Pl. L.R. 56.1 ¶ 16.) As a temporary employee, Ramirez worked as a "picker," a position which entailed using an electric pallet jack or forklift to fulfill orders of refrigerated or frozen products to be shipped. (Def. L.R. 56.1 ¶ 9.) On his June 2008 employment application, Ramirez indicated that he would be "able to consistently and reliably perform the essential functions of the job with or without reasonable accommodation." (Id. ¶ 11.) The application did not ask about any prior work-related injury. (Id.)
Temporary employees who performed satisfactorily were eligible for regular employment with Millard. (Def. L.R. 56.1 ¶ 10.) Applicants were required to fill out a Personal and Confidential Conditional Job Offer & Medical Review Form ("Conditional Job Offer Form"). (Id.) Ramirez had received good reviews as a temporary employee (Pl. L.R. 56.1 ¶¶ 17--18), so he applied for a regular position.
In his Conditional Job Offer Form, Ramirez disclosed that while working for Home Depot he had suffered an on-the-job injury to his knee which required three months off work and that he had filed a WC claim in connection with that injury. (Def. L.R. 56.1 ¶ 14, Exhibit ("Ex.") F.) Ramirez further provided on his application that he had no (0 percent) permanent disability resulting from the October 2007 injury. (Id.) On July 28, 2008, Millard hired Ramirez as a regular employee. (Id. ¶ 12.) Ramirez was then reassigned to a new position operating a forklift. (Pl. L.R. 56.1 ¶ 21.)
Ramirez, like other new hires, was subject to a 90 day probationary period. (Def. L.R. 56.1 ¶ 12.) The purpose of the probationary period was to allow the employee time to adjust to his or her new position while providing the supervisor an opportunity to assess the employee's suitability to the position and to verify information provided on the Conditional Job Offer Form. (Id. ¶¶ 14, 28.) Moreover, Millard employed a labor management system ("LMS") to track its warehouse employees' productivity and performance, which it would then measure against its own performance standards. (Id. ¶ 26.) Millard advised Ramirez that it expected his productivity to be between 95 and 98 percent. (Id. ¶ 27.) Millard expected a performance level of 100 percent for its employees. (Id.) Probationary employees at Millard were held to a higher standard of conduct. (Id. ¶ 28.) Ramirez was told that his performance and LMS numbers were great. (Pl. L.R. 56.1 ¶ 21.)
Ramirez's Conditional Job Offer Form was sent to Millard's headquarters in Omaha, Nebraska. (Pl. L.R. 56.1 ¶ 22.) Rachel O'Dell, a Claims Risk Management Specialist for Millard at headquarters, reviewed Ramirez's Conditional Job Offer Form. (Def. L.R. 56.1 ¶¶ 18--19.) O'Dell recognized that missing three months of work as the result of a knee injury indicated that the injured worker had undergone surgery and that, in Illinois, an injury requiring surgery would not yield a zero percent impairment rating as Ramirez had indicated on his Conditional Job Offer Form. (Id. ¶ 20.)
O'Dell advised either Mark Domroes, General Manager of the Millard Plant in Geneva, or Pillay that Ramirez had an impairment rating assigned by the ICC which he did not indicate in his Conditional Job Offer Form. (Def. L.R. 56.1 ¶ 22.) On August 20, 2008, Domroes emailed Nick Dayan, Millard's Senior Vice President of Human Resources:
Don't forget about Anthony Ramirez. We discussed he was an injury risk, had a 13 wk settlement from a previous job and was rated 17.5% perm disability. Is he someone we want to probation out now? (hired 7/28) (Pl. L.R. 56.1 ¶¶ 6--7.) Dayan responded to Domroes the same day, "We have this all documented right? . . . Let's get him out asap." (Id. ¶ 7.) Dayan testified that his response to Domroes' email was in reference to a separate conversation regarding Ramirez's performance. (Def. Resp. to Pl. L.R. 56.1 ¶ 8.) During his deposition, Domroes explained his understanding of the 17.5 percent disability rating referenced in his email to Dayan:
This information was supplied to me by Sam, Sam Pillay. So he had brought it to my attention that he had found out that this person was - - like I said, was previously injured, had a permanent disability, he was a recent new hire. And my understanding was that it was not put on his application. I don't know - - I can't speak for Sam.
I don't know that we would have hired someone if that was known up front just because of the physical requirements for the job and having to lift and twist and, you know, that would have probably had to potentially gone through our corporate office.
So that was brought to my attention, so I wanted to run it up the ladder. I was not going to make a decision to keep him or not keep him. So my question basically to Nick was giving him the facts, just saying that, hey, this gentleman has come here with some physical limitations, he's a new hire, he's still on probation, you know, he's a probationary employee. So my understanding under Illinois law, that, you know, you can be let go for any reason whatsoever. And the second email was from Nick telling me to - - instructing me to let him go. (Def. L.R. 56.1, Ex. B, Domroes Dep. at 25--26.) Domroes testified about physical abilities that he believed Ramirez was lacking:
To be honest with you, in looking at the e-mail, and again I told you I did not recall whether this was legs or arms, but, you know, the - - there's lifting involved with the jobs, especially new hires traditionally have put - - are put into a picking role.
That is the probably - - I don't necessarily want to say an entry level, because we fill employees where they're needed. But case pickers are in the freezer for the longest period of time, so it's the roughest, so you kind of graduate out onto the docks of loading and unloading as you get with experience, and you're operating a piece of equipment which takes more skill.
So, you know, to operate a piece of equipment, you need a skill set with, you know, a fully functioning - - I mean, if you're limited in any capacity, and I'm not a doctor, I don't know what 17-and-a-half percent means. But if there's a potential there that he can't steer the forklift properly or brake properly, that he can't manage that, that is a potential risk to other employees. Lifting requirements, I believe it was at least 25 pounds, if not up to 50 pounds, that they're required to lift, so that could be a potential if he's - - he could injure himself. If he was favoring one arm or one leg, he might put undue duress on another part of the body and then potentially risk injuring himself. So I believe that the thought process behind that was to avoid a potential workers' comp claim and injury to himself and/or others. (Def. L.R. 56.1, Ex. B, Domroes Dep. at 27--28; Pl. L.R. 56.1 ¶ 4.) With regard to the decision to terminate Ramirez, Domroes explained that "we've had terminations for performance and - - but in this case, this wasn't really performance related directly, it was about his - - his ability to do the job and his injury, previous injury." (Def. L.R. 56.1, Ex. B., Domroes Dep. at 41.)
On August 21, 2008, after approximately four weeks on the job, Ramirez had a performance level of 59 percent, which was lower than Millard's claimed performance expectation level of 100 percent. (Def. L.R. 56.1 ¶ 29, Ex. J.) Millard terminated Ramirez on August 21, 2008. (Def. L.R. 56.1 ¶ 28.) Millard provided Ramirez with a "Termination Report" which checked a box titled "PROBATIONARY PERIOD; NO MISCONDUCT" denoting the reason for his termination. (Pl. L.R. 56.1 ¶ 26, Ex. 16.) The Termination Report did not reference Ramirez's LMS-determined performance level as the reason for his termination. (Id.) In August 2009, the raw data used to create Ramirez's LMS numbers were automatically deleted. (Pl. L.R. 56.1 ¶ 32.)
A. Samson Pillay
Millard hired Pillay on April 17, 2000 as a Human Resources Coordinator. (Def. L.R. 56.1 ¶ 30.) Part of Pillay's duties included being involved in hiring and firing. (Id.) He "administered" terminations based on the recommendations of supervisors, the operations manager, or the General Manager. (Id. ¶ 31.) From 2000 to 2008, Pillay received good/great performance reviews in addition to pay raises and bonuses. (Pl. L.R. 56.1 ¶ 11.) Pillay did not work with or know Ramirez when Ramirez worked at Home Depot. (Def. L.R. 56.1 ¶ 65.)
Dayan began working at Millard in its corporate headquarters on March 17, 2008. (Def. L.R. 56.1 ¶¶ 32, 34.) Shortly thereafter, Dayan reviewed a complaint dated March 7, 2008 about Pillay. (Id. ¶ 35.) On March 26, 2008, Dayan received another complaint that referred to Pillay. (Id. ¶ 37.) In March and April 2008, Dayan visited the Geneva facility, at which time he received numerous verbal complaints about Pillay. (Id. ¶ 40.) The complaints were directed to Pillay's (1) lack of confidentiality in his HR role; (2) discouraging/warning employees about attempting to contact corporate headquarters; (3) withholding freezer gear from employees; (4) mean, disrespectful and abusive treatment of employees; and (5) general unapproachability. (Id.) Dayan discussed these complaints with Pillay and decided in collaboration with Domroes that Pillay would be placed on a performance improvement plan ("PIP"), the goal of which was to make Pillay a better employee by addressing deficiencies identified in his performance. (Id. ¶¶ 45-46.) The PIP identified a number of areas of needed improvement, including (1) confidentiality; (2) favoritism; (3) hiring; (4) communication; and (5) employee development. (Id. ¶ 45.) The PIP also required Pillay to complete the program and to maintain sustained results after the program's completion. (Id. ¶ 46.) Pillay did not believe that the PIP was merited (Pl. L.R. 56.1 ¶ 13) and disagreed with the terms contained therein. (Pl. L.R. 56.1, Ex. 12.) Millard had received complaints about other Millard employees during 2007, but only Pillay received disciplinary repercussions. (Pl. L.R. 56.1 ¶ 36.) Specifically, Dayan reviewed prior complaints about Operations Manager Mike Polerecky and Domroes. (Def. L.R. 56.1 ¶ 42; Pl. L.R. 56.1 ¶ 36.)
The PIP went into effect on May 5, 2008 (Def. L.R. 56.1 ¶ 49) for a ninety-day period, setting a schedule of three follow-up meetings every thirty days. (Pl. L.R. 56.1 ¶ 14.) On June 2, 2008, Domroes and Pillay had a PIP follow-up meeting, at which time Domroes concluded that "[Pillay] has achieved the required improvements." (Id.) On August 1, 2008, the PIP expired (id. ¶ 15); however, the PIP required "sustained results" for continued employment. (Def. L.R. 56.1 ¶ 46.)
During August 2008, Dayan received additional complaints from other Millard employees about Pillay. (Def. L.R. 56.1 ¶ 60(a)--(h).)*fn5 At about this same time, Pillay requested documentation regarding Ramirez's termination, and on August 21, 2008, Domroes forwarded Pillay the August 20, 2008 email between himself and Dayan concerning Ramirez. (Pl. L.R. 56.1 ¶ 24.) Pillay met with Dayan and alleges that they had a heated argument during which Pillay protested Ramirez's termination. (Id. ¶¶ 25--26.) Pillay testified that he told Dayan that terminating Ramirez because he had a disability and had filed a WC claim was illegal. (Id. ¶ 25.) Despite his protest, Pillay alleges that Dayan ordered him to terminate Ramirez. (Id. ¶ 26.)
Millard, on the other hand, disputes that Pillay ever objected to Ramirez's termination. (Def. L.R. 56.1 ¶ 56.) Domroes testified during his deposition:
I do not recall what stance Sam took. I know - - so I - - I remember we had some conversations about whether to keep him or not, and then it was something that was -- neither one of us were willing to make that call, you know, 'What should we do in this case? It's come to our attention that he has some permanent disability that may affect his ability to perform. He could be a safety risk to himself and others. And what should we do?' And I - - if - - and from seeing this email, I know Sam wasn't going to do anything without getting something in writing from Nick, and that's why I forwarded that. (Def. L.R. 56.1, Ex. B, Domroes Dep. at 43--44.) Dayan disputed that a heated argument took place with Pillay (Plf. L.R. 56.1 ¶ 27) and denied that Pillay objected to Ramirez's being terminated. (Def. L.R. 56.1 ¶ 57.) Dayan claimed that Pillay actually recommended that Ramirez be terminated along with other employees who needed to be disciplined or terminated. (Id. ¶ 57.) In explaining its rationale for firing Pillay, Dayan stated that because the PIP required "sustained results" for continued employment and in light of the additional complaints concerning Pillay, Dayan recommended that the Millard Executive Committee terminate Pillay's employment. (Id. ¶¶ 61, 66--67.) The Executive Committee concurred with Dayan, and on August 26, 2008, Millard terminated Pillay. (Id. ¶ 61.) Pillay was not given the reason for his termination at this time. (Pl. L.R. 56.1 ¶ 28.)
Union Petition Rumored for several months beforehand, on August 1, 2008, a union petition was circulated at Millard's Geneva facility.(Def. L.R. 56.1 ¶¶ 39, 41, 50.) In response to the union petition, Dayan traveled to the Geneva facility to meet with management staff to prepare for the union campaign and upcoming election. (Id.) Pillay's termination occurred in the midst of this union election. (Pl. L.R. 56.1 ¶ 34.) All managers in place at the time of the union campaign were subsequently terminated. (Def. Resp. to Pl. L.R. 56.1 ¶ 36.) Prior to the union campaign, on July 4, 2008, Millard terminated Assistant GM Carlos Mamarian, and in December 2008, Millard fired Office Manager Peter Trinidad. (Id. ¶ 38.) Domroes testified during his deposition that he believed that he and Pillay were made "scapegoats" for the union campaign. (Def. L.R. 56.1 ¶ 53.) Although Millard terminated Domroes and Polerecky several months after firing Pillay, Domroes explained that Pillay's termination was accelerated because his name came up negatively and repeatedly, and he was "associated in a bad light with a lot of the employees." (Id.)
Post Termination
On September 15, 2008, Pillay sent Millard a demand letter requesting compensation for his termination which, Pillay wrote, was premised on his protests against Ramirez's termination. (Pl. L.R. 56.1 ¶ 30.) On September 26, 2008, Millard responded to Pillay's letter, writing that Pillay's termination was for "good, valid, and lawful reasons" and that "[a]t no time during Mr. Pillay's employment did Millard ever instruct Mr. Pillay to violate, disregard or contravene any federal or state labor laws or any other laws, nor did Millard terminate Mr. Pillay's employment because he refused to violate any such laws." (Pl. L.R. 56.1, Ex. 7.)
In December 2008, Ramirez and Pillay filed claims with the Equal Employment Opportunity Commission ("EEOC"). (Pl. L.R. 56.1 ¶ 31, Ex. 8; Def. L.R. 56.1, Ex. U.) On January 16, 2009, Millard responded to the charges that Ramirez lodged with the EEOC, denying that it "conducted or committed unlawful discrimination on the basis of disability or in retaliation." (Pl. L.R. 56.1, Ex. 8.) Millard further contended that Ramirez's termination resulted from his unacceptable LMS performance rating (i.e., 59 percent) during his tenure as a probationary employee. (Pl. L.R. 56.1, Ex. 8.) On January 21, 2009 Millard responded to Pillay's EEOC charge, stating that Pillay's poor performance as HR manager, taken together with his failure to improve that poor performance and continued improper and unacceptable treatment of employees, resulted in his termination. (Pl. L.R. 56.1 ¶ 31, Def. L.R. 56.1, Ex. U.)
Following his termination from Millard, Pillay interviewed for positions with the Bartlett Park District and Grohe America but was not offered employment at either. (Def. L.R. 56.1 ¶¶ 69--70.) Sometime after he was denied a position with the Bartlett Park District or Grohe America, Pillay sent Millard a "request for employment verification" from Reliance Data Corp. (a fictitious company). (Id. ¶ 71.) Millard replied and provided incorrect dates of employment for Pillay, stating that Pillay's employment dates spanned from December 1, 2000 to August 25, 2008 (when Pillay had in fact been hired on April 17, 2000). (Id. ¶ 71, Ex. 19.) Pillay never contacted the Bartlett Park District or Grohe America to determine whether Millard provided accurate dates of his employment. (Id. ¶¶ 71, 73.) Pillay is currently employed by Sears where he works in the HR department. (Id. ¶ 75.)
Summary judgment obviates the need for a trial where there is no genuine issue as to any material fact and the moving party is entitled to judgment as a matter of law. Fed. R. Civ. P. 56 (a). To determine whether any genuine fact exists, the court must pierce the pleadings and assess the proof as presented in depositions, answers to interrogatories, admissions, and affidavits that are part of the record. Fed. R. Civ. P. 56(c) & advisory committee notes (1963 amend.) While the court must construe all facts in a light most favorable to the non-moving party and draw all reasonable inferences in that party's favor, Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255, 106 S. Ct. 2505, 91 L. Ed. 2d 202 (1986), where a claim or defense is factually unsupported, it should be disposed of on summary judgment. Celotex Corp. v. Catrett, 477 U.S. 317, 323--24, 106 S. Ct. 2548, 91 L. Ed. 2d 265 (1986). The party seeking summary judgment bears the initial burden of proving there is no genuine issue of material fact. Id. at 323. In response, the non-moving party cannot rest on bare pleadings alone but must use evidentiary tools listed above to designate specific material facts showing that there is a genuine issue for trial. Id.; Insolia v. Phillip Morris Inc., 216 F.3d 596, 598 (7th Cir. 2000). "Summary judgment is not appropriate 'if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.'" Payne v. Pauley, 337 F.3d 767, 770 (7th Cir. 2003) (quoting Anderson, 477 U.S. at 248)).
I. Ramirez and Pillay's Motion to Strike
Before delving into the merits of the parties' motions, the court must address numerous objections raised in Ramirez and Pillay's motions to strike portions of Millard's statement of material facts submitted pursuant to Northern District of Illinois Local Rule 56.1. [Dkts. 90; 91; 92.]
Ramirez and Pillay first move to strike eight exhibits (Exs. L, M, N, O, P, T, V, and W) [Dkt. 90] attached to Millard's statement of facts, arguing that these documents are inadmissible hearsay for which the proper foundation has not been laid. These documents consist of complaints lodged by Millard employees against Pillay. "Sworn testimony is not the only basis on which summary judgment may be granted; rather, the court may consider any material that would be admissible or usable at trial, including properly authenticated and admissible documents or exhibits." Woods v. City of Chicago, 234 F.3d 979, 988 (7th Cir. 2000) (citations and quotations omitted). Although Dayan refers to the substance that gave rise to these complaints in his affidavit submitted to the EEOC in 2009 (Def. L.R. 56.1, Ex. K), he did not specifically authenticate these exhibits in his EEOC affidavit. Millard also failed to submit an affidavit or any evidence authenticating Exhibits L, M, N, O, and P (all of which concern anonymous complaints regarding Pillay) and, accordingly, they will be stricken.*fn6 See Fed. R. Civ. P. 56(c)(4);Fed. R. Evid. 901.
Exhibits T, V, and W are acknowledged complaints either sent to or requested by Dayan concerning Pillay. Specifically, Exhibits T and W are signed handwritten complaints; Exhibit V is an email sent to Dayan. Although Millard failed to raise this argument, after reviewing Dayan's deposition transcript, this court finds that his testimony authenticates these exhibits. (See Def. L.R. 56.1, Ex. I.) Ramirez and Pillay further argue that these exhibits and Dayan's 2009 EEOC affidavit [see Dkt. 91] that references these exhibits should be struck as they constitute inadmissible hearsay. Millard, however, offers the statements for the non-hearsay purpose of proving that complaints were made, corroborating Millard's position that it terminated Pillay as a result of receiving complaints. See Pannizi v. City of Chicago Bd. of Educ., No. 07 C 846, 2007 WL 4233755, at *5 (N.D. Ill. Nov. 19, 2007) (statements and letters were admissible at summary judgment for non-hearsay purpose of showing that complaints about the plaintiff were made to school officials). Accordingly, Exhibits T, V, W, and Dayan's 2009 EEOC affidavit will not be struck.
Ramirez and Pillay next move to strike the affidavit of Rachelle O'Dell. [Dkt. 91]. They claim that Millard failed to identify O'Dell in its initial Federal Rule of Civil Procedure 26 disclosures, and that her affidavit contains hearsay. Rule 26(a) provides that "a party must . . . provide to the other parties . . . the name . . . of each individual likely to have discoverable information -- along with the subjects of that information[.]" Fed. R. Civ. P. 26(a)(1)(A)(I). Rule 26(e) further imposes a duty to supplement Rule 26(a) disclosures "in a timely manner if the party learns that in some material respect the disclosure or response is incomplete or incorrect, and if the additional or corrective information has not otherwise been made known to the other parties during the discovery process or in writing." Fed. R. Civ. P. 26(e)(1)(A) (emphasis added). Rule 37 sets forth sanctions for failing to comply with the rule, stating "[i]f a party fails to provide information or identify a witness as required by Rule 26(a) or (e), the party is not allowed to use that information or witness to supply evidence on a motion." Fed. R. Civ. P. 37(c)(1). As Millard notes, O'Dell had been repeatedly identified by both sides throughout discovery, in deposition testimony, and in Pillay's answers to interrogatories. As both parties had identified O'Dell as a potential witness during discovery, the court declines to strike her affidavit for non-compliance with Rule 26. See Fed. R. Civ. P. 26(e)(1)(A). Ramirez and Pillay also move to strike the following portion of paragraph six of O'Dell's affidavit based on hearsay: "Millard's [WC] counsel was able to confirm Mr. Ramirez did, in fact, have an impairment rating assigned by the Illinois Industrial Commission." Millard did not respond to this argument, and this portion of O'Dell's affidavit will be struck as hearsay.
Ramirez and Pillay last request that the court strike that part of Millard's statement of facts that does not consist of short numbered paragraphs, and contains legal arguments in violation of Local Rule 56.1. [Dkt. 92.] Having considered the specific paragraphs that Ramirez and Pillay argue violate this rule, the court denies their motion to strike on this basis. To the extent that Millard's statement of facts contains improper legal conclusions, the court will disregard them.
II. Ramirez's ADA Discrimination Claim
Ramirez claims that Millard violated the ADA by terminating his employment based on a perceived disability. "The ADA prohibits an employer from discriminating against a qualified individual with a disability." Kersting v. Wal-Mart Stores, Inc., 250 F.3d 1109, 1115 (7th Cir. 2001) (quotations omitted). "Congress enacted the ADA 'against a backdrop of pervasive unequal treatment . . . including systematic deprivations of fundamental rights' that people with disabilities were forced to endure." Dickerson v. Bd. of Trs. of Comm. Coll. Dist. No. 522, 657 F.3d 595, 600 (7th Cir. 2011) (quoting Tennessee v. Lane, 541 U.S. 509, 524, 124 S. Ct. 1978, 158 L. Ed. 2d 820 (2004)). To establish disability discrimination in order to defeat a motion for summary judgment, a defendant must prove that there is no genuine issue of material fact and the plaintiff must prove that "(1) [he] is disabled within the meaning of the ADA, (2) [he] is qualified to perform the essential functions of the job, either with or without a reasonable accommodation, and (3) [he] suffered from an adverse employment action because of his disability." Hoppe v. Lewis Univ., No. 11-3358, 2012 WL 3764717, at *4 (7th Cir. Aug. 31, 2012). A plaintiff can establish disability discrimination through the direct method or indirect method of proof. Dickerson, 657 F.3d at 601.
Direct Method of Proof
Under the direct method, a plaintiff can rely on direct or circumstantial evidence to meet his burden. Dickerson, 657 F.3d at 601. "Direct evidence requires an admission by the decision maker that his or her actions were based upon the prohibited animus." Id. "A decisionmaker is the person responsible for the contested decision." Rogers v. City of Chicago, 320 F.3d 748, 754 (7th Cir. 2003) (quotations omitted). "The most common example of direct evidence is a statement by the decision-maker that betrays a discriminatory intent." Walker v. Bd. of Regents of Univ. of Wis. Sys., 410 F.3d 387, 394 n.7 (7th Cir. 2005). A plaintiff can also rely on circumstantial evidence to survive summary judgment, namely, "(1) suspicious timing; (2) ambiguous statements or behavior towards other employees in the protected group; (3) evidence, statistical or otherwise, that similarly situated employees outside of the protected group systematically receive better treatment; and (4) evidence that the employer offered a pretextual reason for an adverse employment action." Dickerson, 657 F.3d at 601. Using circumstantial evidence, a plaintiff can present "a convincing mosaic . . . that would allow a jury to infer intentional discrimination by the decisionmaker." Silverman v. Bd. of Educ. of the City of Chicago, 637 F.3d 729, 734 (7th Cir. 2011) (quotations omitted).
Ramirez proceeds under the direct method of proof relying on the August 20, 2008 email exchange between Domroes and Dayan sent the day before Millard terminated Ramirez, in which Domroes stated that Ramirez "was rated 17.5% perm disability" to which Dayan responded, "We have all of this documented right? . . . Let's get him out asap." (Pl. L.R. 56.1 ¶ 7.) Dayan, as head of human resources for Millard, was the ultimate decision maker with regard to terminating Millard employees with less than two years of service (i.e., Ramirez). (Def. L.R. 56.1 ¶ 58.) Dayan's response to Domroes' email is direct evidence that Millard terminated Ramirez because of a perceived notion that he had a disability, conduct which the ADA specifically proscribes. Domroes also corroborated this notion:
So my question basically to Nick [Dayan] was giving him the facts, just saying that, hey, this gentleman has come here with some physical limitations, he's a new hire, he's still on probation, you know, he's a probationary employee. So my understanding under Illinois law, that, you know, you can be let go for any reason whatsoever. And the second email was from Nick telling me to - - instructing me to let him go. (Def. L.R. 56.1, Ex. B, Domroes Dep. at 27--28.)
Domroes' testimony, at a minimum, evidences a discriminatory intent. Namely, Dayan and Domroes' email conversation occurred one day before Millard terminated Ramirez. In addition to this suspicious timing, Domroes further expounded on his belief that Ramirez's prior injury may have precluded him from working at Millard's warehouse, and ultimately precipitated his termination. Specifically, Domroes testified:
So, you know, to operate a piece of equipment, you need a skill set with, you know, a fully functioning - - I mean, if you're limited in any capacity, and I'm not a doctor, I don't know what 17-and-a-half percent means. But if there's a potential there that he can't steer the forklift properly or brake properly, that he can't manage that, that is a potential risk to other employees. Lifting requirements, I believe it was at least 25 pounds, if not up to 50 pounds, that they're required to lift, so that could be a potential if he's - - he could injure himself. If he was favoring one arm or one leg, he might put undue duress on another part of the body and then potentially risk injuring himself. So I believe that the thought process behind that was to avoid a potential workers' comp claim and injury to himself and/or others. (Def. L.R. 56.1, Ex. B, Domroes Dep. at 27--28.) With regard to the decision to terminate Ramirez, Domroes explained that "we've had terminations for performance and - - but in this case, this wasn't really performance related directly, it was about his - - his ability to do the job and his injury, previous injury." (Id. at 41.) Thus, the documentary and testimonial evidence raises sufficient factual questions from which a reasonable jury could find that Millard had a discriminatory motive in terminating Ramirez. Millard's motion for partial summary judgment with respect to count I is thus denied.*fn7
III. Pillay's ADA Retaliation Claim
Pillay claims that Millard violated the ADA by terminating Pillay's employment after he protested Ramirez's termination. The ADA states that "[n]o person shall discriminate against any individual because such individual has opposed any act or practice made unlawful by this chapter or because such individual made a charge, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing under this chapter." 42 U.S.C. § 12203(a). Similar to establishing an ADA discrimination claim, a plaintiff bringing an ADA retaliation claim may rely on the direct or indirect method of proof. Dickerson, 657 F.3d at 601.
A. Direct Method of Proof
To establish unlawful retaliation under the direct method, a plaintiff must present evidence showing "(1) a statutorily protected activity; (2) an adverse action; and (3) a causal connection between the two." Squibb v. Mem. Med. Ctr., 497 F.3d 775, 786 (7th Cir. 2007) (quotations omitted). Pillay argues that he has provided direct evidence of retaliation.
i) Whether Pillay Engaged in A Statutorily Protected Activity
Pillay argues that he engaged in statutorily protected activity by protesting against Ramirez's termination. "[A]n informal complaint may constitute protected activity for purposes of retaliation claims." Casna v. City of Loves Park, 574 F.3d 420, 427 (7th Cir. 2009). The parties disagree about whether Pillay protested Ramirez's termination. Pillay argues that after hearing about Millard's decision to terminate Ramirez he requested documentation at which time Domroes forwarded Pillay his August 20, 2008 email correspondence with Dayan on this subject. (Pl. L.R. 56.1 ¶ 24.) Pillay testified that he then confronted Dayan protesting Ramirez's termination was premised on an illegal motive. (Id. ¶¶ 25--26.) Millard denies that Pillay argued against Ramirez's termination and further argues that Pillay advocated for Ramirez's termination. (Def. L.R. 56.1 ¶ 56.) Although the parties dispute that this conversation took place, sufficient questions for the trier of fact exist as to whether Pillay engaged in a statutorily protected activity by protesting Ramirez's termination. See, e.g., Payne, 337 F.3d at 773 ("Where the material facts specifically averred by one party contradict the facts averred by a party moving for summary judgment, the motion must be denied."); see also Paz v. Wauconda Healthcare & Rehab. Ctr., LLC, 464 F.3d 659, 664--65 (7th Cir. 2006) ("We have long held that a plaintiff may defeat summary judgment with his or her own deposition.").
ii) Whether A Causal Connection Exists Between Pillay's Termination and Protest
The parties do not dispute that Pillay satisfied the second prong under the direct method (i.e., he suffered an adverse action) after Millard terminated his employment. Pillay and Millard, however, dispute the last prong, that Pillay's protesting Ramirez's firing triggered his termination. Pillay must demonstrate that his complaint was a "substantial or motivating factor" in Millard's decision to fire him. Leitgen v. Franciscan Skemp Healthcare, Inc., 630 F.3d 668, 675 (7th Cir. 2011) (quotations omitted). Although Pillay claims that the timing of his termination (which occurred less than one week after he protested Ramirez's firing) is indicative of retaliation, "suspicious timing alone is almost always insufficient to survive summary judgment." Id. at 675.
In addition to the suspicious timing of his termination, Pillay points to Domroes's forwarding Pillay the August 20, 2008 email correspondence between Dayan and Domroes. Pillay contends that this email precipitated his argument with Dayan about Ramirez's termination. Domroes testified that he forwarded the email he received from Dayan approving Ramirez's termination to Pillay because "Sam [Pillay] wasn't going to do anything without getting something in writing from Nick [Dayan]." (Def. L.R. 56.1, Ex. B, Domroes Dep. at 43--44.) Domroes, however, does not corroborate Pillay's story that he protested against Ramirez's termination and could not recall whether Pillay opposed firing Ramirez. Pillay focuses on the lack of written documentation evidencing Millard's reasons for firing him; however, he does not offer any additional evidence linking his termination with his protest. Accordingly, Pillay fails to show by direct evidence that his protest played a "substantial or motivating factor" in Millard's ultimate decision to end his employment.
B. Indirect Method of Proof
A plaintiff may also prove his case using the indirect method by employing the burden-shifting test set out in McDonnell Douglas Corporation v. Green, 411 U.S. 792, 804 93 S. Ct. 1817, 36 L. Ed. 2d 668 (1973). Tyler v. Ispat Inland Inc., 245 F.3d 969, 972 (7th Cir. 2001). The Seventh Circuit has elucidated on this burden-shifting test, explaining:
Under the McDonnell Douglas method of proof, the plaintiff bears the initial burden of establishing a prima facie case of discrimination. The burden of production then shifts to the employer to articulate a legitimate, nondiscriminatory reason for the employment action. Finally, the burden shifts back to the plaintiff to prove that the employer's articulated reason for the employment action was a pretext for discrimination and that the decision was in fact motivated by an unlawful factor.
Id. (citation omitted). In initially making his retaliation case under the indirect method of proof, a plaintiff must demonstrate "(1) that [he] engaged in protected activity; (2) that [he] was subject to an adverse employment action; (3) that [he] was performing her job satisfactorily; and (4) that no similarly situated employee who did not engage in protected activity suffered an adverse employment action." Squibb, 497 F.3d at 788 (quotations omitted).
i) Whether Pillay Was Meeting Millard's Legitimate Employment Expectations
As noted above, Pillay has presented sufficient facts at this point to allow a reasonable trier of fact to find that he satisfied the first two elements of the indirect method (i.e., Millard ended Pillay's employment as a result of his protesting Ramirez's termination). Pillay must also establish that he was performing his job satisfactorily and that no other similarly situated employees were terminated at the time. Pillay worked at Millard for more than eight years before he was fired in August 2008. During that time, Pillay received good performance reviews in addition to pay raises and bonuses. (Pl. L.R. 56.1 ¶ 11.) Still, "when a district court evaluates the question of whether an employee was meeting an employer's legitimate employment expectations, the issue is not the employee's past performance, but whether the employee was performing well at the time of [his] termination." Peele v. Country Mut. Ins. Co., 288 F.3d 319, 329 (7th Cir. 2002) (emphasis added) (quotations omitted). In May 2008, Millard placed Pillay on a PIP to remedy areas of deficiencies identified by complaints received from other Millard employees. (Def. L.R. 56.1 ¶¶ 45--46.) On June 20, 2008, Domroes concluded that Pillay had "achieved the required improvements." (Pl. L.R. 56.1 ¶ 14.) In August 2008, Pillay's PIP expired. (Id. ¶ 15.) Millard contends that the PIP contemplated "sustained results" with which Pillay failed to comply. Still, Pillay received positive feedback during the PIP and, as a result, the plan expired on schedule. Pillay has thus presented sufficient facts showing that he was satisfactorily performing his job in August 2008.
ii) Whether Other Similarly Situated Employees Were Treated More Favorably
To make a prima facie case using the indirect method, Pillay must last show that similarly situated Millard employees received more favorable treatment. "[T]he similarly situated inquiry is a flexible one that considers all relevant factors, the number of which depends on the context of the case." Humphries v. CBOCS West, Inc., 474 F.3d 387, 405 (7th Cir. 2007) (quotations omitted). An employee must show a "substantial similarity" in comparing himself to the better treated employee. Id. "When the same supervisor treats an otherwise equivalent employee better, one can often reasonably infer that an unlawful animus was at play." Coleman v. Donohoe, 667 F.3d 835, 847 (7th Cir. 2012).
Dayan, as Senior Vice President of Human Resources, had the power to discipline Millard employees who served in a managerial role and to recommend terminations to Millard's Executive Committee (of which he was also a member). (Def. L.R. 56.1 ¶ 58.) Other Millard employees who served in a managerial role, including Domroes and Mike Polerecky received employee complaints, but Dayan did not place them on a PIP at the same time as Pillay. (Def. L.R. 56.1 ¶ 42; Pl. L.R. 56.1 ¶ 36.) Although Millard argues that it subsequently terminated all the managers in place at the time of the union campaign, Pillay was the only manager fired in August 2008. Millard terminated Polerecky in March 2009, and fired Domroes in May 2009. (Def. Resp. to Pl. L.R. 56.1 ¶ 38; Def. L.R. 56.1, Ex. B, Domroes Dep. at 12.) Domroes and Polerecky were similarly situated to Pillay in that they were Millard managerial employees. Although Pillay reported to Domroes, Dayan was the ultimate decision maker in that he recommended terminations to the Executive Committee. Pillay has thus offered sufficient facts showing that similarly situated employees who had been the subject of prior complaints and served in a managerial role were treated more favorably in that Pillay was the first of these employees to be fired. See Coleman, 667 F.3d at 846--47 ("Whether a comparator is similarly situated is usually a question for the fact-finder, and summary judgment is appropriate only when no reasonable fact-finder could find that plaintiffs have met their burden on the issue.") (quotations omitted).
iii) Whether Millard Had Legitimate Non-Discriminatory Reasons for Terminating Pillay
Millard points to numerous facts which tend to show that Pillay's termination was the result of continued poor work performance, not because he protested Ramirez's termination. Having received complaints about Pillay from Millard employees, in May 2008, Dayan placed Pillay on a three-month PIP. (Def. L.R. 56.1 ¶¶ 37, 40, 45--46.) Although Pillay completed the PIP by August 2008, his continued employment was dependent on maintaining "sustained results." (Id. ¶ 46.) Subsequently, Dayan received numerous complaints about Pillay. (Id. ¶ 60.) These complaints, according to Millard, in connection with the union campaign at Millard's Geneva facility resulted in Pillay's termination. (Id. ¶¶ 53, 61, 66--67.) Millard also argues that other high level employees, including Domroes, ultimately were let go as the result of the union campaign over the course of the next nine months. (Def. Resp. to Pl. L.R. 56.1 ¶¶ 36, 38; Def. L.R. 56.1, Ex. B, Domroes Dep. at 12.) Domroes further testified that he believed Pillay's termination was also the result of the union campaign, and that they were both "scapegoats." (Def. L.R. 56.1 ¶ 53.) These facts evidence a legitimate non-discriminatory reason for Millard to terminate Pillay.
iv) Whether Pillay's Termination Was Pretextual
To survive summary judgment, Pillay must demonstrate that Millard's decision to terminate him was pretextual. "Pretext involves more than just faulty reasoning or mistaken judgment on the part of the employer; it is [a] lie, specifically a phony reason for some actions." Argyropoulos v. City of Alton, 539 F.3d 724, 736 (7th Cir. 2008) (quotations omitted). Pillay disputes the accuracy of the complaints received in August 2008, and argues that they were an after-the-fact Millard concoction so as to provide cover for themselves. Pillay substantiates this argument by highlighting the fact that some of these complaints were not documented until after Millard terminated him. Pillay also points to the lack of documentation created contemporaneously with his termination. Pillay argues that the union campaign did not trigger his termination, noting that other employees such as Domroes did not lose their jobs until several months after Pillay. (Def. L.R. 56.1 ¶ 53.) That Pillay was the only Millard manager working at the Geneva facility terminated in August 2008 bolsters his argument that his termination resulted not from employee complaints or the pending union campaign but, rather, was the result of his protesting Ramirez's termination. In addition, the short time period between which Pillay received Dayan and Domroes' August 20, 2008 email correspondence and when he was fired (i.e., five days) raises questions about why Millard ultimately decided to terminate Pillay. Namely, a question of fact exists about whether Millard terminated Pillay because he protested Ramirez's termination or whether that decision was the result of Pillay's poor work performance. See, e.g., Payne, 337 F.3d at 770 ("We must look therefore at the evidence as a jury might, construing the record in the light most favorable to the non-movant and avoiding the temptation to decide which party's version of the facts is more likely true.") A reasonable trier of fact could conclude that the union campaign in connection with Pillay's prior poor work performance was the perfect storm of events which triggered his termination. Still, the trier of fact could reasonably conclude that Millard's proffered reasons were pretextual and that the real reason for Pillay's termination was the result of his disputing Ramirez's termination. Millard's motion for summary judgment with respect to count II is thus denied.
IV. Pillay's Retaliatory Discharge Claim
Pillay next claims that Millard is liable for retaliatory discharge under Illinois law. "The tort of retaliatory discharge comprises three distinct features: first, an employee must establish that [he] has been discharged; second, [he] must demonstrate that [his] discharge was in retaliation for [his] activities; and finally, [he] must show that the discharge violates a clear mandate of public policy." Belline v. K-Mart Corp., 940 F.2d 184, 186 (7th Cir. 1991). "Retaliatory discharge cases are generally allowed when an employee is discharged for: (1) filing a worker's compensation claim; or (2) reporting illegal or improper conduct." Mackie v. Vaughan Chapter-Paralyzed Veterans of Am., Inc., 820 N.E.2d 1042, 1044--45, 354 Ill. App. 3d 731, 289 Ill. Dec. 967 (Ill. App. Ct. 2004).
A) Exercising Workers' Compensation Rights
"The Illinois Supreme Court has recognized a common-law cause of action for retaliatory discharge where an employee is terminated because of his actual or anticipated*fn8 exercise of workers' compensation rights." Beatty v. Olin Corp., No. 11-2853, 2012 WL 3854855, at *3 (7th Cir. Sept. 6, 2012). In addition, in Pietruszynski v. McClier Corporation, Architects & Engineers, Inc., 788 N.E.2d 82, 338 Ill. App. 3d 58, 272 Ill. Dec. 778 (Ill. App. Ct. 2003), the Illinois Appellate Court held that the plaintiffs could recover for retaliatory discharge where they had been terminated as a result of testifying in a co-worker's WC hearing noting that such participation served public policy and promoted the interests of the Workers' Compensation Act . Id. at 87.
Pillay cannot support his retaliatory discharge claim because he cannot demonstrate any activity in connection with Ramirez's actual or anticipated exercise of his WC rights. Unlike in Pietruszynski, where the plaintiffs testified on the claimant's behalf, here Pillay did nothing in connection with an actual or potential WC claim that Ramirez could have pursued. Ramirez's Home Depot claim had concluded by the time he started working at Millard. Millard had nothing to do with that claim. Ramirez had suffered no injury at Millard that would have created a potential WC claim. There is no authority in Illinois extending the tort of retaliatory discharge to protect an employee who tells his employer that it should not fire someone who had filed a WC claim in the past but who had no connection to that earlier proceeding. See, e.g., Pietruszynski, 788 N.E.2d at 86 (stating that "[The Illinois Supreme Court] has continued to stress the narrow scope of the tort of retaliatory discharge"). Millard is entitled to judgment on this claim.
B) Other Illegal and Improper Conduct
Pillay also argues that he has a retaliatory discharge claim premised on illegal and improper conduct, namely that Pillay protested Ramirez's termination because of a perceived disability. Protesting against Ramirez's termination, however, is the same conduct which Pillay uses to substantiate his ADA retaliation claim. In Stebbings v. University of Chicago, 726 N.E.2d 1136, 1141, 312 Ill. App. 3d 360, 244 Ill. Dec. 825 (Ill. App. Ct. 2000), the Illinois Appellate Court identified the situation where a plaintiff brings a retaliatory discharge claim yet has an adequate alternative remedy, holding:
It is not necessary or a plaintiff attempting to state a claim for retaliatory discharge to cite to a statute making his or her firing illegal. If that were the case, the tort of retaliatory discharge would be superfluous, for the plaintiff would be able to proceed under the statute. In fact, a court might be obligated to dismiss the claim in such a situation, for one of the factors that a court considers in deciding whether to allow a retaliatory discharge claim is the existence of an adequate alternative remedy.
Id. at 1141. Indeed, Pillay's ADA retaliation claim reaffirms that he has an adequate alternative remedy as the ADA provides him with a private cause of action. Cf. Hamros v. Bethany Homes & Methodist Hosp. of Chicago, 894 F. Supp. 1176, 1179 (N.D. Ill. 1995) (concluding that the "Illinois Supreme Court would not expand the common law tort of retaliatory discharge to include claims based on the exercise of rights under the [Family and Medical Leave Act"]). Pillay cannot use the conduct which substantiates his ADA retaliation claim, reporting disability discrimination, to bring a claim for retaliatory discharge. Millard is entitled to summary judgment on this count.
V. Pillay's Libel/Slander Claim
Pillay next claims that Millard is liable for defamation under Illinois law because it provided false employment dates for Pillay. Under Illinois law, "[t]o prove a claim of defamation, a plaintiff must show that the defendant made a false statement concerning plaintiff, that there was an unprivileged publication of the defamatory statement to a third party by defendant, and that plaintiff was damaged." Gibson v. Phillip Morris, Inc., 685 N.E.2d 638, 643, 292 Ill. App. 3d 267, 226 Ill. Dec. 383 (Ill. App. Ct. 1997). The question how the incorrect (or false) dates of employment might have damaged Pillay aside, Pillay fails to demonstrate that Millard communicated false employment to dates to anyone but himself. Pillay surmises that Millard must have communicated incorrect dates of employment to prospective employers, relying on the incorrect information that Millard sent to the fictitious company Pillay created requesting such information. Still, "[t]o show a publication, it must be established that the allegedly slanderous remarks were communicated to someone other than the plaintiff." Gibson, 685 N.E.2d at 643. Pillay offered no evidence showing that Millard made such a communication with a third party, and thus cannot survive summary judgment.
VI. Pillay's Tortious Interference with Contract Claim
Pillay last claims that Millard is liable for tortious interference with contract based on supplying incorrect employment dates to prospective employers. Because Pillay contends that he was a job applicant seeking employment, his claim actually lies in tortious interference with a prospective economic advantage. Fellhauer v. City of Geneva, 568 N.E.2d 870, 877, 142 Ill.2d 495, 154 Ill. Dec. 649 (1991). Under Illinois law, "[a] plaintiff claiming intentional interference with a prospective economic advantage must establish (1) a reasonable expectation of entering into a valid business relationship, (2) the defendant's knowledge of the expectation, (3) purposeful interference by the defendant that prevents the plaintiff's legitimate expectancy from ripening into a valid business relationship, and (4) damage to the plaintiff resulting from the defendant's interference." Atanus v. Am. Airlines, Inc., 932 N.E.2d 1044, 1048, 403 Ill. App. 3d 549, 342 Ill. Dec. 583 (Ill. App. Ct. 2010). Again to survive summary judgment, Pillay must offer some proof that Millard actually communicated incorrect information to prospective employers. Because Pillay has failed to do so and merely relies on innuendo, he has failed to meet his burden. Accordingly, summary judgment is granted as to count VI.
Millard's motion for partial summary judgment [Dkt. 82] is granted in part and denied in part. The motion is denied with respect to counts I and II and granted with respect to counts IV, V, and VI. Ramirez and Pillay's motion to strike hearsay documents [Dkt. 90] is granted in part and denied in part. Ramirez and Pillay's motion to strike the affidavits of O'Dell and Dayan [Dkt. 91] is granted in part and denied in part. Ramirez and Pillay's motion to strike portions of Millard's statement of facts [Dkt. 92] is denied.
This case will be called for a status hearing on October 16, 2012 at 8:30 a.m. The parties are directed to engage in a sincere effort to settle this case and to report the potential for settlement at the next status hearing and whether referral to the magistrate judge for a settlement conference would be helpful.
JOAN HUMPHREY LEFKOW United States District Judge
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Aaron Haaland of A Comic Shop in Orlando, Florida writes, Hey Fandom! It's one of those fifth Wednesday in a month things where DC pumps out annuals, but Batman and Superman Annuals are worth your time. Batman has mainly holiday themed stories by Tom King, Scott Sdyner, Paul Dini, and more. Superman is the Tomasi… Read more »
In the category of things I never thought I'd write about… Valiant is holding a signing to go with their Cosplay Cat Variant Covers… and they're bringing the cats. Seattle's Comics Dungeon will be holding a live, in-person signing featuring stars (and real-life felines) Fawkes and Nak, alongside Freyu – creator of the Cat Cosplay of the… Read more »
Spoilers for Fantastic Beasts And Where To Find Them There are a lot of things that can break a movie. A story that meanders and doesn't go anywhere, a director that is the wrong fit for the material, a little detail that breaks the flow of the movie; all of these things are not present… Read more »
For fans of the short-lived Constantine television series, any chance to see Matt Ryan reprise the role of John Constantine is something to get excited about. He returned to the magic man for an episode of Arrow and now he's lending his voice to the DC animated movie Justice League Dark. The film's director Jay… Read more »
In what could end up being an interesting plot for a TV movie, the artist that claimed Dreamworks Animation stole his idea for Kung Fu Panda could end spending 25-years in prison and paying over $500,000 plus restitution to the animation studio. How did this happen? In 2011, Jayme Gordon made allegations that DWA lifted… Read more »
As reported about extensively on Bleeding Cool (and by extensively we mean at least twice per week as firmly stated in our charter), Frank Cho loves to rile people up with his hilarious and edgy "Outrage" sketch covers, usually featuring a female superhero with an exaggerated figure wearing skimpy clothing while Spider-Gwen yells "outrage" in the background…. Read more »


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Check in from 2:00 PM / Check out prior to 12:00 AM
Quality Hotel Residence: Find photos, reviews, information, amenities and compare prices for 4 stars hotels in Sandnes, Norway.
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All the rooms at Quality Hotel Residence Sandnes provide a mini bar, plus all the essentials for a comfortable stay. They have a private bathroom with a hair dryer, a shower and a bathtub.
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SXSW Interview: James Landry Hebert, Beth Broderick & Skyy Moore Talk 'Two Step' and Audition Tips
James: "You know when a role's yours"
SXSW Interview: Director Alex Johnson and Actors Ashley Spiller & Jason Douglas Talk 'Two Step'
Alex on his feature directing debut: "It's a long time coming"
Watch: Emma Stone and J.K. Simmons Talk 'La La Land'
The pair spoke about the challenges of working on a musical and working with Chazelle on his dream project.
Adam Driver Talks 'Patterson', Preparing for a Role and Second-Guessing His Work
"I love the idea of doing a lot of takes because there's so many different ways that you can play scenes" - Adam Driver
Bryce Dallas Howard on Pursuing an Acting Career: "I hedged my bets like crazy"
Bryce Dallas Howard: "And my grandmother said to me, "Do you know what the rate of the average working actor in SAG is, in terms of how many auditions it takes for them to get a job?"
Tom Hanks on Acting: "There are no shortcuts. Dear God, I wish there was, but there's not"
"What would I do if I was in the circumstances of that man, that woman, that child, that android?" - Tom Hanks
Natalie Portman: "I think you can't judge your character when you play her, or else you wouldn't be able to"
Portman speaks about the challenges with playing the famous First Lady.


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Outstanding penalty issues: applications for clearance received in CG
If you work in Compliance Group and the taxpayer applies for clearance on form IHT30 and the necessary conditions are satisfied, you should deal with the certificate and not delay its issue solely because a penalty aspect is not settled. However, you should send a covering letter making it clear that the certificate does not affect the penalty issue, which remains open.
The previous page (IHTM40111) tells you what to do with files referred to you for advice by PC&S.


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A Wisconsin Investment Casting Foundry
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Ricky and Hans will do best in a home with respectful children 9 years or older, no large, aggressive or highly alpha dogs and an environment where he will not be crated all day. Ricky and Hans must be adopted together.
Our adoption process includes completing & submitting an online adoption application, a home visit, reference checks including veterinarian. Ricky is fully vetted and available for Colorado adoption only. His adoption fee is $225.00.
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The Last 2013 AskThePRO with Masuronike!
Formalities first, we would like to invite all our TiltBook members to watch and participate in the very last AskThePRO episode of 2013 on TiltBook.com that will take place on the Christmas Day - Wednesday, 25.12.2013 at 20:00 CET!
As is the tradition, you can begin to post your questions even right now and when the session begins, our this week's hero will choose and answer your best and most interesting ones in a course of exactly one hour (during which you can still post more questions)!
This week's special guest: Tomáš "Masuronike" Kubaliak
Also crowned as the "embracer of downswings", this high stakes hyper sit & go player, lousy husband and a shamelessly try-hard father is best known to all of you as the Founder of TiltBook.com. With the end of the year being right in front of the door just like an angry neighbor after having a bucket of horse poop thrown at his window, Masuronike will join the very last AskThePRO of the year to summarize and answer any questions you might have regarding his poker career or TiltBook as well as his leaks in husbandry.
We hope you will will the AskThePRO section with whole bunch of great and fun questions and give Masuronike a hard time! Along with the classic $20 AskThePRO prize, by asking a question this week your are qualifying for a possible bonus in our upcoming TiltBook Christmas Tournament Series, so do not hesitate! See you on the Christmas Day - Wednesday, 25.12.2013 at 20:00 CET at www.tiltbook.com/AskThePRO.
- 23286 users
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All ages
Celebrate the 25th anniversary of the Americans with Disabilities Act at Brooklyn Children's Museum. I Can! Kid-Abilities Day features fun programs for children with special learning needs and cognitive abilities. The whole family can enjoy the day together, exploring the rainbow of possibilities found at BCM!
The Cave featuring Sensory Imaging
11:00am–3:00pm | Sensory Room
Crawl, jump and rock as you navigate your way through a sensory filled obstacle course in the Sensory Room. Feel a rainbow the transforms with your touch.
Sensory Imaging is an interactive installation designed by Adrian Sas to engage children with Autism Spectrum Disorders in an immersive experience that encourages sensory exploration. This program is a sensory experience for children of all abilities.
Painting Rainbows
11:00am–1:00pm | Greenhouse
Breathe in the scents of the plants in our greenhouse. Listen to the tinkling bells as you pick up your musical paintbrush. Smell as you dip your brushes in the palette of fragrant, vibrant colors and create a design of your own! This is a hands on art activity.
Quiet Space
11:00am-3:00pm | Upper Level Party Room
It's easy to become overwhelmed when so many exciting things are happening! Our quiet space is available for anyone to come in and recharge for all the fun that is ahead. This area is for all children who become over-stimulated and need a brief break.
Rainbow Fish
11:30am–12:00pm | Library
The iridescent scales on fish are captivating. Come to an interactive storytelling and craft experience where each scale makes a difference and working together really matters. This program builds on interpersonal social skills.
Amazing Animals
12:00–12:30pm | Commons Theater
Let's close our eyes and see in a new way, as we listen to visual descriptions of our live animals. We can meet our reptile friends and touch their scaly skin. This program has visual description for people who are blind or have low vision.
Sensory Snake Craft
12:00–2:00pm | Science Inquiry Center
Make a sensational snake craft to slither home with you. This is a hands-on activity for the artist in all of us.
Snack Time
12:00–1:00pm | Classroom
Stop in for a tasty and healthy treat. It's Free! All snacks are gluten and nut-free.
IDEAS Theatre
12:30–1:00pm | Upper Level Gallery
Young thespians release your inner actor as we use improv skills to create a play and perform with our friends. No experience necessary. This program builds on interpersonal social skills.
IDEAS - Interactive Drama for Education and Awareness in the Schools brings creative drama activities to youth with all abilities. Using simple props and costumes and harnessing young imaginations, IDEAS teaching artists help to build character inside and out, as well as improve social skills, literacy skills and self-esteem. IDEAS has worked with students who are blind, on the Autism spectrum, deaf, those with varied learning disabilities, emotional difficulties, physical differences.
NYC Kids Project
1:00–1:45pm | Commons Theater
Join NYC Kids Project for a stick and rod puppet show that encourages audiences to examine attitudes surrounding disabilities and differences, fostering empathy and awareness of commonalities. NYC Kids Project is a social justice arts organization advocating acceptance and inclusion.
Inside a Bubble
1:00–3:00pm | Rooftop
Touch bubbles dancing through the air as we find little rainbows in these soapy spheres. From babies to big kids, all can enjoy this sensory experience. The program is for children of all abilities.
Dance Party
2:00–3:00pm | Upper Level
Gallery Wiggle, stomp your feet, twirl and shake it to the beat! Let's get down at as we jam to the music and show off our moves at the official, I Can! Kid-Abilities Dance Par-tay! This program promotes gross motor skills and is adapted for children to move with or without assistance. This is a lively and energetic event. We will have a limited number of noise cancelling headphones available upon request.


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Enhanced search function
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The International Auditing and Assurance Standards Board sets high-quality international standards for auditing, assurance, and quality control that strengthen public confidence in the global profession.
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The importance of sustainability and corporate responsibility continue to gain recognition; indeed, organizations that embrace sustainability can enhance their reputation with stakeholders and their value. The intersection of business and sustainability has three key dimensions: economic viability, social well-being, and environmental responsibility. Accountants work in this area to help embed sustainability factors into an organization's strategy and decision-making processes to achieve sustainable value creation. Read More
Sustainability on Our Minds—The Editor's Review Series No. 2
by Eli R. Khazzam, Editor-in-Chief, IFAC Global Knowledge Gateway | December 14, 2015 |
A brief review of some of the key Gateway articles covering the roles accountants play in creating sustainable organizations. Read More
Corporate Governance and Transparency—The Chicken or the Egg of Sustainable Development?
by Stathis Gould, Head of Professional Accountants in Business and Integrated Reporting, IFAC | November 30, 2015 |
The historic agreement between the 193 UN member states on the 17 Sustainable Development Goals is only part of the beginning; businesses play a crucial role in achieving many of the SDGs, and are falling short. Now is a time for focus on the expectations of boards through governance requirements as well as on how more transparency can shine a light on performance and actions. Read More
The Water Crisis and Management: Implications for Accountants in Business
by Professor Roger Burritt and Dr. Katherine Christ, Macquarie University, Sydney, Australia | November 13, 2015 |
Water crises will affect all business sectors but accountants in business can help their organizations prepare and adapt. Read More
Corporate Responsibility and the Accountancy Profession
by Stathis Gould, Head of Professional Accountants in Business and Integrated Reporting, IFAC | October 23, 2015 |
The accountancy profession can play an important role in helping society mitigate and adapt to the challenges of climate change. Read More
by Dr. Dorothy Maxwell, Director, The Sustainable Business Group | July 28, 2015 |
可持续发展企业集团近期针对 2015 年可持续服装行业领导力奖发表了一份具有里程碑意义的报告 State of the Apparel Sector Water(服装行业用水现状)。此次颁奖活动与世界水周 (WWW) 联合举行,在这一盛大的年度活动上,国际专家、从业人员、决策者及商业改革者汇聚一堂,共同讨论全球水资源问题。
我们目前面临着与日俱增的水资源压力,水资源的管理被视为当今影响业务连续性和业务发展的最大风险因素之一。纵观全局,世界经济论坛 (WEF) 已将水资源短缺问题认定为未来十年内全球社会面临的首要风险因素。从人权的角度来看,在世界许多地区内,获得安全、洁净的饮用水供应、卫生状况及卫生设施等已经危机四伏。在世界野生动物基金会 (WWF) 发行的水风险地图中,列示了全球范围内已经遭遇严重水资源危机的国家和地区,这也证实了新闻媒体的报道—中国、印度、美国、巴基斯坦、孟加拉国、澳大利亚、非洲、土耳其及巴西已面临这一风险。 Read More
Recent News
- Accounting Could Play Role in Reaching UN Global Goals
November 10, 2016 - Accounting Today
- World Bank Pledges $2bn to Bangladesh for Climate Change Resilience
October 24, 2016 - Public Finance International
- US Companies Know the Risks of Climate Change; Should They Be Required to Report Them?
October 21, 2016 - Fuel Fix
- These Are the World's Most Sustainable Cities
September 26, 2016 - World Economic Forum
Key Resources
- 2015 Handbook of International Quality Control, Auditing, Review, Other Assurance, and Related Services Pronouncements
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January 17, 2013 - IFAC
- GRI Reporting Framework (G4)
January 1, 2013 - Global Reporting Initiative


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Excerpt from S. 885, to Modify Congressional Restrictions on Gifts: Hearing Before the Subcommittee on Oversight of Government Management of the Committee on Govermental Affairs United States Senate One Hundred Third Congress First Session on S. 885 The Subcommittee met, pursuant to notice, at 2:10 p.m., in room SD-342, Dirksen Senate Office Building, Hon. Carl Levin, Chairman of the Subcommittee, presiding. Present: Senator Levin. Staff Present: Linda J. Gustitus, Staff Director and Chief Counsel- Peter K. Levine, Counsel- Frankie de Vergie, Chief Clerk- James Calvin Cunningham III and Michael McGaughey, Interns. Opening Statement of Senator Levin Senator Levin. The Subcommittee will come to order. Today's hearing is on S. 885, a bill introduced by Senator Frank Lautenberg to limit the acceptance of gifts, meals, and travel by Members of Congress and congressional staff, so that the rules in the Congress would then be substantially similar to restrictions that are applicable to executive branch officials. This bill comes to our Subcommittee with the added momentum of a Senate resolution adopted on May 6, 1993, which expressed the sense of the Senate that we should enact a comprehensive gift ban this year, in this session of the Congress. While legislation pertaining to Senate rules is ordinarily directed to the Senate Rules Committee, this particular bill, because it proposes statutory restrictions on the acceptance of gifts applicable to both the Senate and the House, was referred by the Parliamentarian to the Governmental Affairs Committee. There is no question in my mind that the current congressional gift rules are inadequate and are subject to abuse. For example, while the gift rules applicable to executive branch employees prohibit the acceptance of even a single gift with a value in excess of $20, unless the circumstances indicate that the gift is motivated by family relationship or personal friendship, our rules permit the acceptance of any number of gifts under $100 from the same source. In theory, that means that we could accept a $95 gift from the same source every day and, by the way, not even disclose it. Even gifts of more than $100 are allowed, up to a total of $250 a year from a single source. About the Publisher Forgotten Books publishes hundreds of thousands of rare and classic books. Find more at www.forgottenbooks.com This book is a reproduction of an important historical work. Forgotten Books uses state-of-the-art technology to digitally reconstruct the work, preserving the original format whilst repairing imperfections present in the aged copy. In rare cases, an imperfection in the original, such as a blemish or missing page, may be replicated in our edition. We do, however, repair the vast majority of imperfections successfully- any imperfections that remain are intentionally left to preserve the state of such historical works.
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Details Book
|United States Congress Sen Management
|Forgotten Books
|Data Published
|27 September 2015
|Format Book
|PDF, Epub, DOCx, TXT
|Number of Pages
|140 pages
|Age +
|15 years
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