text: Le Donne Cucina Italiana may be outside of your area. Please enter your delivery address to check availability Do you need any... Napkins & Utensils Continue to Checkout Le Donne Cucina Italiana Back to Menu Your order refresh Le Donne Cucina Italiana Your Shopping Cart is empty edit Delivery Address Please enter delivery address edit Delivery Time Closed for the Selected TimePlease change the delivery time Add someone to this order Polenta con Porcini e Parmigiana Homemade polenta topped with porcinis and fresh shaved Parmigiano. x $11.25 Special Instructions: Label Item For: or Cancel


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Basic Background Check
Rachel L.
Nanny in Los Angeles, CA 90008.
Looking for part-time work as a nanny.
Enhanced Background Check not run.
Enhanced Background Check(Not Run)
Basic Background Check completed and badge awarded. Contact the caregiver directly to see the report. What does this background check cover?
Basic Background Check Completed 11/02/2016
Motor Vehicle Records Check not run.
Motor Vehicle Records Check(Not Run)
First Aid Training
First Aid Training
CPR Training
CPR Training
University of California - Los Angeles
University of California - Los Angeles
Los Angeles, CA
- Age 26
- 10 years paid experience
- Female
Last signed in: Yesterday
Preferred Rate $20-$40 per hour
Rachel's Bio
I have been babysitting for over 10 years and began nannying about 5 years ago. I enjoy nannying because I enjoy building a relationship with a family. I am trustworthy, timely, and loyal.
I know it's not always easy being away from your kids, so I try to make the transition as easy as possible. I am a dependable person that you can count on. When nannying I only work with one family at a time, that way I can be there when you need (unexpected sick days, emergencies, etc…) My experience as a Resident Assistant taught me emergency preparedness as well first aid and safety procedures.
I have been a nanny for two families (relocation and the children going to school ended the work relationships, however I remained an on call sitter)
I believe in making the most of our time. So I won't just turn on the tv and sit the kids in front of it. I try to make fun educational game and learning experiences.
I am open to helping with light cleaning, cooking, and running errands.
I like to think of myself more as a parent's helper, assisting wherever you need.
Age Specific Experience
10 years of paid child care experience with:
- First year
- Toddlers (1 to 3 years)
- Preschooler (3 to 5 years)
- Grade School (6 to 11 years)
- Pre-teen/Teenagers (12 years and over)
6 to 10 years of infant care experience
Infant Care:
- Assist with setting a routine
- Overnight care
- Mother's helper
- Occasional care
Special Needs Experience
Special Needs Care Experience
- Cognitive Disabilities
Special Needs Conditional Experience
- Asperger's Syndrome
- Attention Deficit Disorder (ADD)
- Autism Spectrum Disorder/Pervasive Developmental Disorder/Asperger Syndrome
Special Needs Services Experience
- Administering Medication
- Assistance With Transportation
- Bathing
- Dressing Assistance
- Feeding Assistance
- Grooming and Hygiene
- Specific Meal Preparation (foods to avoid, etc.)
Availability & Job Preferences
Availability Duration
Willing to consider working as a live in care provider
- Short-term (1 to 3 months)
- Temporary (4 to 12 months)
- Permanent (1 to 2 years)
- Summer Position
Job Duration
- Will consider a part time position
- Start date is flexible
My availability is valid through 3/31/16
- Open (all day, everyday)
Skills & Abilities
Homework Help:
- Finishing homework
- Checking answers
- Studying for a test
- Proofreading
- Basic Math
- Pre-Algebra
- Elementary Science
- English
- Essay Writing
- Social Studies
Additional Services:
- Meal Preparation
- Laundry
- Light Housekeeping
- Swimming Supervision
- Crafts
- Potty Training
- Travel with Family
- Willing to run errands as needed
- Willing to drive children to events, school, appointments, or carpooling
|Leila C. is a reference for Rachel L.
|Relationship: Family
|Join Now to Contact Reference
|Emily L. is a reference for Rachel L.
|Relationship: Family
|Join Now to Contact Reference

subset: commoncrawl


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Status: Open
Se habla espanolas seen on tvrobert vaughn is not a client of kalfus & nachman p.c. And is a paid spokesperson appearing on their behalf.offices also located in norfolkpeninsula and northern neckroanokeserving the entire middletell them you mean business! Then them you mean business. We do it all 870 n. Military hwy. Norfolk va 23502all serious injuries... Tell them you mean business! As seen...
Jones ACT Seamen
Pharmaceutical Cases
Uninsured Motorist
No Legal Fee Unless Successful
Jones ACT Cases
Delayed Hearings
Auto Accidents
We DO All The Paperwork
Commercial Fisherman
Wrongful Death & Brain Injuries
Commercial Fishermen
Spinal Cord Injuries
Injured On A Tug Boat
We Will Come to You
Consulta Gratis
Injured On Any Vessel
Cruise Ship Injuries
Motorcycle Accidents
Be the first Find.HamptonRoads.com user to add photos or videos of Kalfus & Nachman
Kalfus & Nachman is located at 1 Old Oyster Point Rd, Newport News, VA. This business specializes in Law Firms.
Since 2010 the company has been providing Legal Services.
If you don't see your business listed on Hampton Roads, please add your business listing.
With a network of sites receiving over 13 million page views per month, we have lots of opportunities for you to make an impression. Learn more...
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Welcome to the middle grades!
MiddleWeb is all about middle school & the middle grades — with a sharp focus on teaching and learning in grades 4-8. Join us, learn about our 5 streams of content, and find out how to get involved.
MiddleWeb is all about middle school & the middle grades — with a sharp focus on teaching and learning in grades 4-8. Join us, learn about our 5 streams of content, and find out how to get involved.
Gifted and talented students need to be challenged every day. Former GATE coordinator Mary Langer Thompson urges parents and educators to share Inman and Kirchner's thorough book with school personnel to benefit these youngsters, who won't thrive without support.
Dana Johansen and Sonja Paul nudge writing workshop to a new level with flipped mini-lessons, allowing more time for teachers to conference with students. Teacher leader Sandy Wisneski says to keep the step-by-step, easy-to-read and resource laden book close by.
No school or district is immune from a future defined by declining resources. Leadership consultants Ron Williamson and Barbara Blackburn share four research-based strategies to help educators make the most of a challenging financial climate and serve all kids.
Inspired at EdCamp, Michelle Russell is trying optional math homework. Students decide how well they understand topics and do homework if they need practice. The next day begins with discussion and then a "homework quiz." Michelle reports on how it's all working.
Teaching students to take good notes and allowing them to use "open notes" on most class tests is good instructional practice, says ELA teacher Amber Chandler. She details how her open-note approach sharpens student focus and provides data to strengthen lessons.
Facing the 'December Dilemma' of how to include winter holidays in the instructional day? This MiddleWeb resource offers a multi-faceted look at religious and non-religious aspects of the season, legal issues, and some ideas for seasonal lesson planning.
Building on her 1999 best seller, Georgia Heard shares 20 stories and templates in her new book "Heart Maps." Each map is supported by tips, genre ideas, student samples and mentor texts. Long-time devotee Linda Biondi celebrates Heard's latest accomplishment.
Sibberson and Szymusiak are back with a fresh look at reading instruction in the early middle grades. Literacy coach Pam Hamilton says "Still Learning to Read" will help teachers fine-tune classroom libraries, organize groups, and support still-developing readers.
Jerry Burkhart's explorations into ratios, proportions and similarity are deep, rich, and open-ended, says veteran math educator Mickie Gibbs. Thanks to increasing levels of productive struggle offered for each topic, the book can benefit all of her students.
We have heard for over a decade now that we must be teaching our students how to think critically. Using four examples, coach Elizabeth Stein demonstrates how co-teachers can strengthen their own critical thinking skills using a shared problem-solving mindset.


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Help Kudos Kirkland Clean Up Pedestrian Walkway to Downtown/
Join Kudos Kirkland volunteers to help Public Works crew members remove a section of rusty, dilapidated chain link fencing along a pedestrian pathway near downtown Kirkland. Those unable to cut or lift fencing can help with litter and weed removal.
Removing the fencing will make the pathway more attractive and easier to maintain.
The pathway starts east of the Post Office and runs along the south side of NE 85th Street, across the railroad tracks, and up to the corner of NE 85th & Kirkland Way. From here, pedestrians can continue on pathways to Lake Washington High School, and the Highlands, Everest, and Rose Hill neighborhoods.
Thursday, March 8 8-10 am Park near Starry Nights catering at 11200
Kirkland Way
Public Works will provide tools and safety equipment Bring gloves and a water bottle [box type="tick" style="rounded" border="full"]Would you like to see a volunteer effort to spruce up your block or in your neighborhood? We're here to help. Join us at one of our weekly cleanup events. Contact us by email or learn more about stewards of our community at http://kudoskirkland.com[/box]


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GM-Fleet Sales (Automotive)
Skillsolved Co., Ltd.
jobsDB ref: JTH300003001243405
Our client is a well-known company in automotive industry. They are now looking for a high calibre candidate to be in charge of manage and develop their automotive network.
- Manage sales team to developing Fleet/ Commercial Vehicles sales and develop businesses in assigned market e.g. corporate and government sector.
- Approach potential clients and develop long term relationshipin order to boost up sales volume and achieve target.
- Understand all product portfolio and able to generate sales across all the sub-categories.
- Responsible for Fleet pricing strategy for bidding new potential projects.
- Provide the strategic sales strategies in achieving the target growth & revenue numbers
- Provide leadership direction to the team and coach them in delivering their outputs
- Keep up with current market trends and conditions as well as good knowledge & network of the project sales in potential industry
- Manage operational efficiency and capital budget
- Enhance customer satisfaction entire commercial purchasing process
- Provide accuracy report regarding sales activities to management periodically
- Thai nationality only
- Age between 35- 45 years old
- Bachelor's degree or higher in related field.
- Have good understanding in bidding process and strategy.
- Proven successful sales record in fleet sales.
- Strong network in Government, Private Sector, or related channels.
- Experience in team management and performance improvement.
- Excellent communication and negotiation skills.
Interested? Please send "NOW" your application letter and resume
(in Microsoft Word format only) stating current and expected salary to us.
jobsDB will send your application for review directly to Skillsolved Co., Ltd.
About Skillsolved Co., Ltd.
We call ourselves "CLOSERS." We are a group of passionate headhunters who believe in delivering results for our clients, while providing service excellence. SkillSolved aspires to become the first Thai-brand recruitment company that comes to mind when hiring.
Our consultants focus exclusively on mid-senior level permanent positions in various industries & functions:
• Banking & Financial Services
• Life Science
• Industrials
• FMCG & Consumers
• Retail & E-Commerce
• Telecom, Media, & Technology
• Sales & Marketing
• Accounting & Finance
• Supply Chain & Procurement
• Manufacturing
• Information Technology
• Human Resources
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Johnson And Rose To Headline UBS Hong Kong Open
- Details
- Monday, 3 August 2015 16:15
Dustin Johnson and Justin Rose will be the stars of the show at Fanling in October when the golfing stars headline the UBS Hong Kong Open.
Johnson and Rose, currently ranked fifth and seventh in the Official World Golf Ranking, confirmed their entries to one of Asia's most prestigious tournaments following their strong performances in The Open recently.
Johnson shared the halfway lead at St Andrews before a disappointing final two rounds, while Rose finished strongly to flirt with contention and eventually tie for sixth.
Johnson, a 31-year-old from South Carolina,, is one of the game's most exciting players where his natural talent and athleticism allows him to be one of the longest and straightest drivers of the golf ball in the world. He also has the short game to back it up, winning nine times on the PGA Tour, including the WGC-Cadillac Championship in March, and contending in almost every Major Championship he plays. He finished tied second at the U.S. Open in June.
He said: "I'm excited to be making my first trip to the UBS Hong Kong Open. I've heard some great things about the tournament, and that the Hong Kong Golf Club is a real classic golf course with a rich history and tradition.
"You look at some of the names who have won the tournament – guys like Norman, Watson, Woosnam, Langer, Olazabal, Montgomerie and McIlroy – and you realise there is a great history there. Those are the kind of trophies you want to get your name on.
"I'm also really looking forward to visiting Hong Kong. As golfers we are very lucky to have the chance to travel the world playing the game we love and when you get the chance to visit cities as exciting as Hong Kong then it's difficult to say no. It's going to be an exciting trip."
Rose, of course, is a Major Champion having won the 2013 U.S. Open and becoming the first Englishman since Tony Jacklin in 1970 to win America's national Open. A truly global player, Rose has won seven times on both The European and PGA Tours, as well as picking up titles in the land of his birth, South Africa, as well as Australia and Japan.
Rose said: "Hong Kong is one of my favourite cities in the world and Fanling is a great golf course. The tournament is close to the end of the Race to Dubai so I liked the idea of putting another tournament on the schedule near the end of the year to give myself as good a chance of possible of winning the Race to Dubai when we get to Dubai at the end of the season.
"I missed the cut by a shot in 2011 but I loved the course. I remember I made a late run of birdies to almost make the cut, but then missing that cut actually enabled me to spend a weekend in the city and really get to know and love the place.
"We stay in an awesome hotel in the middle of town and there are just so many great restaurants and so much to do – when you are away from the course you always feel you are somewhere very special and unique.
"But hopefully this year I can improve the golf side of things. Fanling is a very traditional, tree-lined, tight course. It's not long but a great test of golf and not easy as the winning scores usually tell. It's also great to have UBS back on board as title sponsor – they have a great association with the tournament and we are delighted to have them back."
Kathryn Shih, Head of UBS Wealth Management, APAC commented on the first star players to join the field for the 2015 UBS Hong Kong Open saying, "We are excited to have Dustin Johnson and Justin Rose confirming for the 2015 UBS Hong Kong Open. The presence of two of the world's top ten golfers is sure to boost the tournament's appeal and we look forward to writing another exciting page in the history of the UBS Hong Kong Open this October."
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Having undesirable fat in numerous locations of your body can have a significant effect on your health and self-confidence. While standard weight loss through workout and diet plan is a terrific way to slim down in general, even the very best workouts can't target issue areas like the belly, inner thighs, arms, and butts. Liposuction is a time tested treatment that is used to eliminate excess fat from specific areas of the body, enabling an individual to form and contour their body to their preference. Is liposuction right for you? Learn now.
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• Proven and safe. This cosmetic treatment has been carried out by skilled surgeons all over the world for several years and the technique has been fine-tuned over and again to be safe and efficient.
• Recovery time is normally quickly. The downtime required after having this kind of treatment is normally much less than exactly what is needed for other kinds of cosmetic treatments, consisting of tummy tucks, breast reduction, and more. Individuals who have had the treatment can often go back to work a lot more quickly than they prepared for and can return to living a healthy, active way of life.
• Weight loss can be long-term. With the best upkeep techniques, the fat that was gotten rid of during the liposuction treatment will not return.
• Complete control over your physique. With liposuction, a person can have complete control over how they want to look, beyond exactly what conventional diet plan and exercise can provide. Offering individuals this power over their bodies enhances self-confidence and help individuals feel their very best.
While there countless advantages to liposuction, there are naturally a couple of cautions that must be taken into account before making the final decision to move forward with the procedure.
Cons of Liposuction
Prior to having liposuction done, it is necessary to examine the potential disadvantages of the procedure and figure out if the benefits exceed the risks in your specific case. Your surgeon can help you learn more about the risks connected with the procedure and can help you choose if moving on is the best thing for you.
• Complications with basic anesthesia. Since liposuction is performed under basic anesthesia, the procedure brings the exact same dangers as any other kind of surgical treatment where general anesthesia is used. Underlying medical conditions may enhance these risks.
• Unfavorable reactions. Bruising, bleeding, and pain are all to be anticipated, nevertheless, in unusual cases can cause more considerable complications.• The potential to acquire the weight back. After having liposuction done, it is important to keep a healthy diet plan and workout properly as suggested by your doctor. Failure to do so could cause acquiring back the weight that was lost or possibly much more.
Although there are threats connected with liposuction, for lots of people, the advantages far exceed them. Educate yourself about the treatment by having in-depth discussions with your cosmetic surgeon and consider how liposuction has the possible to impact you as an unique person. Only you and your cosmetic surgeon can identify if liposuction will provide you with the outcomes you are looking for within your expectations.
Laser Liposuction procedure is a new non invasive procedure to loose unwanted bodyfat in Kwigillingok AK
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Team Lead - Mobile Application (ios/android) ( 2 - 5 yrs)
xCess Manpower
RS3,00,000 To 6,00,000Ahmedabad
Desired Profile: -Experience:2-4 Years -A Combination Of Web Development Experience And Application Development On A Major Mobile Platform Like Android/Ios Is Desired -Extensive Knowledge Of Javascript Cross Platform Development In Mobile Sp...
Key Skills : iphone,android,ios,mobile application,mobile app,team lead,javascript,ext js,backbone.js,underscore.js,web development,team handling,client...
Business Development Executive ( 1 - 3 yrs)
xCess Manpower
RS1,00,000 To 2,50,000Ahmedabad
-Providing software and IT Products demonstrations, -To Maintain relationship with clients &provide business leas, client interaction, team building,followup with client, Identify& establish new business & convert lead to successful closure, ...
Key Skills : sales,marketing,bde,bdm,business development,software sales,cold calling,fluent communication,negotiations,lead generation,sales closure,...
Business Development Manager (only Female) ( 2 - 10 yrs)
xCess Manpower
RS2,00,000 To 4,00,000Ahmedabad
Industry : Hospitality / Facility Management / Service Provider/Banking/Insurance. Experience Required : 2-7 Years In Relevant Field. Must Be Ready For Field Work. Having Good Experience In Business Development Activity I.E., Corporate & B2B...
Key Skills : business development,bde,bdm,bd,sales,marketing,field work,b2b,corporate sales,client acquisition,lead generation,cold calling,travelling,business...
Financial Advisor - Equity Demat Sales ( 1 - 8 yrs)
Trisha Consultancy Services
RS2,25,000 To 6,00,000Ahmedabad, Surat, Vadodara
1. Acquire new clients for Demat & Trading accounts through networking, data base and references. 2. End to end customer relationship management. 3. Meet Non-Trading Customers and activate them. 4. Sell online accounts to customers and encourage t...
Key Skills : sales,marketing,business development,channel sales,lead generation,cold calling,client acquisition,direct sales,financial advisor,...
Commodity(mcx) Sales Cum Trading ( 0 - 2 yrs)
RS1,25,000 To 1,75,000Hyderabad, Ahmedabad, Surat, Bangalore, Mumbai, Pune, Jaipur, Chennai, Kolkata, Delhi
We have An Opening for Advisory and Trading in Top Most Leading Broking Company.please Find the Below Job Description:open Commodity Trading Accounts and Trade On Behalf of Client
Key Skills : bussiness development,trading on client account.to generate brokerages.,banking executive,banking assistant,banking officer
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Urgently Required Relationship Manager in a Leading Group of Company ( 0 - 2 yrs)
The Kriday Consultancies
RS1,75,000 To 3,00,000Ahmedabad
Job Description Acquire Online and offline accounts Sell Value pack accounts and collect 3 lacs margin every month Sell of HNI accounts acquisition for equity, commodity and currency. Sell third party business (cross selling) also like MF and P...
Key Skills : sales,client relationship manager,marketing,business development
EC - Relationship Manager Ahmedabad,Baroda, Pune, Delhi, Vapi, Surat, ( 2 - 8 yrs)
3d India Staffing Research & Consulting, India
RS5,00,000 To 8,50,000Ahmedabad, Surat, Vapi, Pune, Delhi
Designation: EC - Relationship Manager Location : Ahmedabad,Baroda, Pune, Delhi, Vapi, Surat, Experience : 2 – 7 Years Function : Finance & Accounts Vacancy : 15 Job Description : Acquiring & Managing Current Account Por...
Key Skills : current account,portfolio management,business development,trade sales manager,forex trade,customer relationship,client acquisition,customer...
Urgently Looking for Marketing Interns ( 1 - 5 yrs)
Trisha Consultancy Services
RS1,25,000 To 5,50,000Ahmedabad, Surat, Vadodara
Urgently Looking for Marketing Interns salary: Not Disclosed By Recruiter industry:recruitment / Staffing functional Area:sales , Retail , Business Development role Category:corporate Sales role:sales Executive/officer
Key Skills : business development,marketing,client acquisition executive,sales officer,sales executive,sales...
Business Development Executive ( 1 - 6 yrs)
The One Technologies
RS50,000 To 4,25,000Ahmedabad
Designation : BDM Experience : 2 - 5 years Education : MBA/PGDBM/Equivalent Desired skills : Lead Generation, Cold Calling, Bidding on Portals, Campaigning, Sales Presentation, Creating Marketing Collate...
Key Skills : business developer,business development executive,business development,business development officer,client services executive,client relationship...
Female Key Account Manager Having F&B Background Based at Ahmedabad ( 9 - 13 yrs)
Trisha Consultancy Services
RS3,50,000 To 6,50,000Ahmedabad, Surat, Vadodara
Designation: Key Account Manager Reports to: Branch Head Location: Ahmedabad Qualification: Graduate + P.G in Hospitality Experience: Minimum 10 years in Managing Facilities & Administration Key Result Areas: - Country Liaison - Busi...
Key Skills : business development,administration,key account management,client relationship management,team management,key...
Globus Innovative HR Management
RS3,00,000 To 9,00,000Central Delhi, Ahmedabad, Ankleshwar, Bharuch, Surat, Vadodara, Mumbai, Mumbai Suburb
Required Manager - Sales & Marketing Operations for Key Account Management, Pre Tender Support - Ensure Achievement of Budgeted Order Booking Target. - to Achieve the Budget Target (order Intake, Revenue, Collection, Ebit) - Customer Profili...
Key Skills : business development,sales,key account management,planning,marketing,client servicing,key account...
Aishvi Hr Services
RS2,50,000 To 3,75,000Hyderabad, Ahmedabad, Bangalore
Handling sales for an electrical and electronic product manufacturing company. Should be into direct sales. Sub : Sales Executive - Location. Current CTC Expected CTC Notice Period
Key Skills : sales,sales executive,direct sales,client development,sales associate,telemarketing,telesales,direct marketing
Required relationship officer in loan department for leading bank ( 0 - 2 yrs)
The Kriday Consultancies
RS1,25,000 To 1,75,000Ahmedabad, Rajkot, Surat, Vadodara
Job Responsibilities : - 1) Actively participating in activities and generating the leads. 2) Frequently visiting the builders for business. 3) Visiting the Axis Bank branches. 4) Explaining about the loan amount, interest rate, tenure of repay...
Key Skills : sales,marketing,client support executive,relationship officer,business development,business...
Business Development Manager (must have exp. of ERP Sales Only) ( 1 - 6 yrs)
Crystal Fact
RS1,00,000 To 6,00,000Ahmedabad, Mumbai, Mumbai Suburb
We are looking for Business Development Managers for erp sales of one of Reputed well-known erp solution company. Person must have exp. of erp sales.
Key Skills : erp selling sap selling erp sales enterprise resource planning selling crm selling erp marketing sap marketing crm marketing erp business development...
Required Business Development Executives ( 5 yrs)
Electromech Material Handling Systems (i) Pvt Ltd
RS1,75,000 To 3,75,000Ahmedabad
Identifies business opportunities by identifying prospects & evaluating their position in the industry; researching and analyzing sales options. Sells products by establishing contact and developing relationships with prospects; recommending sol...
Key Skills : client relations,business development executive,business development,sales,marketing,client relationship management
Finacus Solutions Private Limited
RS1,00,000 To 5,00,000Ahmedabad, Bangalore, Mumbai
Job Description for Sales Executive: -Identifies business opportunities by identifying prospects and evaluating their position in the industry; researching and analyzing sales options. -Sells products by establishing contact and developing relatio...
Key Skills : sales executive,marketing executive,sales,marketing,business development,sales executive skillsqualifications: • presentation skills,client...
Career Club
RS4,25,000 To 6,00,000Ahmedabad
Business/sales: - Generating Revenue as per the Goal sheet. - Achieving Targets of Sales and Team. - Match the Standards of the Company on Credit Receivables for the Sales Made. Process - Focus on the cost part by monitoring and taking steps on ...
Key Skills : sales,marketing,client coordination,sales manager,business development
Client Acquisition Manager ( 2 - 5 yrs)
Career Club
RS2,00,000 To 3,50,000Ahmedabad, Rajkot, Surat, Vadodara, Mumbai, Jaipur
-To generate leads along with assigned team & Identify decision makers within targeted leads and initiate the sales process. - To manage time and work flow and create effective client meeting plans for his/her team. - To penetrate all targeted acc...
Key Skills : sales,sales team leader,marketing,business development,client acquisition manager
Business Development Officer ( 2 - 6 yrs)
Maven Infosoft
RS2,25,000 To 5,00,000Ahmedabad
If you are passionate and love what you do, we need you. We abide open, friendly and cultured professionals with in-depth knowledge and expertise in IT, finding countless opportunities to re-discover themselves in the land of cutting-edge technologie...
Key Skills : digital marketing,digital sales,seo sem direct sales,website sales,crm e commerce online internet marketing,web marketing,business development,lead...
Business Development Manager - New Projects ( 0 - 10 yrs)
Zion Aqausol
RS80,000 To 2,25,000Ahmedabad
Person Will have to Generate New Inquiries from Database Provided to Him. He Will have to Send the Techno-commercial Offer to Customer and Followup with Him Till Finalization. Seniors Will Support Him for Finalization. He Will Be Given Required Train...
Key Skills : business development manager,sales,business development,client relationship
Klaxon India
RS7,00,000 To 8,00,000Hyderabad, Ahmedabad, Bangalore, Chennai
1.Responsible for obtaining profitable results through the sales team by developing the team through motivation, counseling, skills development and product knowledge development 2.Multi-task and learn various aspects of business a mainly business la...
Key Skills : sales,business development,pre sales,hard core sales,client servicing


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Need it today? Order online and collect from branch for FREE 1 hour later.
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A simple way to protect against electrocution and damage to equipment.
The Toolstation website uses cookies to improve your online shopping experience.
By continuing to browse the site you are agreeing to our use of cookies.
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Watch Ghost Hunters October 21 at 9PM on the SciFi Channel where they will invetigate the Houghton Mansion!!!
Welcome to the official website of the Houghton Mansion!
The Houghton Mansion was home to North Adams, Massachusetts first mayor Albert Charles Houghton and his family. In the spring of 1914, the Houghton's invested in their first car and sent their long-time chauffeur, John Widders, to learn to drive it. On August 1st of that year, Mr. Houghton and his daughter, Mary went to nearby Bennington, VT for a pleasure drive with Mr. Widders at the helm.
This is how it all began. This unfortunate accident and the many deaths and incidents which occurred shortly thereafter are the exact reasons why the Houghton Mansion is seen as one of the most haunted locations in the United States.
We will also be doing more walk through tours in September. Check our Facebook page for details.
Currently the Houghton Mansion is the home to the local Masons. The Mansion has been featured on television shows such as Ghost Adventurers and is also found in many books and on many websites that exploit haunted locations around the U.S.
Today Overnight tours are offered to smaller groups and can be booked by emailing email@example.com The Mansion also has the ability to house many other events, either in the paranormal realm or not. There is a kitchen on site as well as a ballroom with stage. The location has held events such as Ghost Hunts with stars from the Syfy's hit television show, Ghost Hunters to local spaghetti dinners and pancake breakfasts.


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Treasure Island s Outdoor Spectacular Integrates Pulsar Chromaflood LEDs Into Lighting Scheme(July 18, 2008)
DMN Newswire--2008-7-18--Amidst a backdrop of fetching sirens and renegade pirates, the nightly Sirens of TI® show at Treasure Island Hotel & Casino in Las Vegas is a "modern musical-meets-action-movie spectacular". Featuring music, dancing, swordplay, acrobatics and even a full size ship sinking, the pyrotechnics and lighting effects play a major role and were originally designed by industry icons, Roy Bennett and Troy Eckermanwho created the visuals for Madonna's 2006 "Confessions" tour among many other projects.
During a two-month production hiatus back in 2007, Brent Hageman, the Casino's head of lighting and sound, had been exploring alternative lighting options and decided to integrate 2-dozen ChromaFlood 200 LED lights into the show's traditional lighting configuration, purchased in Las Vegas from Mojave Systems' Peter Chachere. With challenges of the desert's weather challenges, he was pleased overall with the reliability of the LED products.
"I'd been hearing about LEDs overall, and in talking with other vendors and researching different brands, we decided to go with 14 Pulsar Chromaflood 200s," says Hageman. "We're using 6 for a partial stage wash and 8 for a cyc wash behind one of the ships in the show. For the most part, it's a pretty conventional application, but we're doing a lot of color changing and running a few effects through them during the show. These are actually brighter then what we had initially, the colors are more true, and they're reliable. You don't have the issues of having a moving part malfunction or shifting a fraction one way or another. Other lights we had been using were having issues, so as far as the maintenance aspect, we're getting the same results with no issues."
Since coming back on line after Christmas, Hageman says they've zero problems, especially in the face of weather challenges posed with an outdoor show. "That's definitely the main advantage of the Pulsar LEDs. Whether it's hot, cold, rainy, or the summer's dry heat, there is no maintenance requiredand in a show of this magnitude which operates 7 days a week, it's nice to have part of your rig that you don't have to worry about. A lot of companies say that their stuff is weatherproof, or IP65-rated, but sometimes there are issues where they will trip GFI's and get moist But we can run these right in the rain, no problem. It's also nice not to have to put them into some kind of tent or other enclosure. We just let them do their job."
Hageman also found an added bonus of using the Pulsar LED, which was the cost-savings aspect, not only from the obvious maintenance, bulb replacement aspect, but the fact that the ChromaFlood's offer low power consumption. "We are running fewer amps of power, and are liking the fact that we are saving energy and not compromising the integrity of the end result. We're definitely exploring ways to implement more of them into the show this year."
About Pulsar
Based in the heart of Cambridge UK, Pulsar develops and manufactures LED lighting and lighting control solutions for professional entertainment and architecture installations around the world. Pulsar is exclusively distributed in the U.S. by Group One Ltd. of Farmingdale, New York. Group One is also the exclusive U.S. distributor for Blue Sky International, Celestion Professional Products, MC2 Audio Ltd., DiGiCo UK, XTA Electronics Ltd and a number of prominent lighting products. www.pulsarlight.com
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Related Keywords:Pulsar, LED, Lighting, Las Vegas, Treasure Island,


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The contest was sponsored by the Alcohol and Drug Abuse Prevention Team.


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cisco 1841 router two wan ports connec with two different static ip pools
By murthy ·
i want to connect 192.168.0.1 is ethernet0 ip adderes it will connect only wan s0/0 & IP 192.168.1.1 ip ethernet1 address will connect only s0/1.what is the commends for the separate connectivity
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September 3, 1998
UNITED STATES OF AMERICA, Plaintiff,
HELEN KRAMER, et al., Defendant. STATE OF NEW JERSEY, DEPARTMENT OF ENVIRONMENTAL PROTECTION, Plaintiff, v. ALMO ANTI-POLLUTION SERVICES CORP., et al., Defendants.
SIMANDLE, District Judge:
In connection with the remedying of conditions at the Helen Kramer Landfill Superfund Site in Mantua Township, New Jersey, the United States, on behalf of the U.S. Environmental Protection Agency and the State of New Jersey Department of Environmental Protection, have filed the present motions for entry of federal and state consent decrees resolving all direct claims of the governments in these multi-party hazardous waste cases arising under the Comprehensive Environmental Response, Compensation and Liability Act ("CERCLA"), 42 U.S.C. § 9601, et seq., the New Jersey Spill Compensation and Control Act, N.J.S.A. 58:10-23.11, et seq., (the "Spill Act"), and other state statutes. The proposed decrees were published for public comment in May, 1998, and no comments were received.
Under the proposed federal Consent Decree, the "Settling Defendants" (comprised of all viable direct defendants and most third-party defendants, numbering nearly 250 parties) will collectively pay the sum of $ 95 million plus interest to the United States over five years, in reimbursement of past response costs with respect to the Site. A subset of these parties, called the Settling Work Defendants,
will perform studies needed by EPA to perform its five-year reviews.
Under two parallel Consent Decrees with the State of New Jersey (the "State Consent Decree") the Settling Defendants will pay $ 9.77 million to the State plus interest accrued on the unpaid balance, reimbursing the State's past response costs at the site. The Settling Defendants will be obligated to continue operation and maintenance of the Site and to pay the cost of future response actions through May 12, 2023. The State NRD Consent Decree also requires the Settling Defendants to purchase and conserve a 151-acre parcel of wetlands and wooded uplands and to pay the State an additional $ 190,000 in compensation for natural resource damages. The federal Consent Decree also resolves natural resource damages claims on behalf of the federal natural resource trustees (the U.S. Fish and Wildlife Service and the National Oceanic and Atmospheric Administration) by incorporating the Settling Defendants' obligations to comply with the State Natural Resource Damages Consent Decree.
The Helen Kramer Landfill in Mantua Township, New Jersey, was declared a federal Superfund site and placed upon the national priorities list by the U.S. Environmental Protection Agency pursuant to the Comprehensive Environmental Response, Compensation and Liability Act ("CERCLA"), 42 U.S.C. § 9601, et seq. The United States undertook the Remedial Investigation and Feasibility Study, the Remedial Design, and remedy construction, which was largely completed in 1994. These remedial costs, together with enforcement costs and prejudgment interest to January, 1998, have amounted to approximately $ 123 million. The United States commenced suit in 1989 to recover all response and remedial costs under Section 107(a) of CERCLA, 42 U.S.C. § 9607(a), and the government had by 1997 filed a Third Amended Complaint against the Direct Defendants alleged to be generators and transporters of hazardous substances deposited at the Landfill. After extensive litigation and settlement efforts, the United States and Direct Defendants reached agreement upon a proposed Consent Decree to resolve the United States' claims against all viable Direct Defendants and a wide majority of the Third-Party Defendants. The Consent Decree was lodged with the Court on May 8, 1998, was served upon all parties in the case including non-settlors, and was published for public comment on June 1, 1998, see 63 Fed. Reg. 29,754-55, consistent with Department of Justice regulations at 28 C.F.R. § 50.7. The United States received no comments.
Similarly, the State DEP commenced suit in 1989 and reached substantial agreement with a subgroup of the Settling Defendants to enable operation and maintenance functions at the Site to be transferred to these settling parties in 1997. The Site had been turned over to the NJDEP for oversight and maintenance on May 11, 1994. The State decrees were lodged with the court in May, 1998, circulated to all parties, and published through newspapers of general circulation seeking comment. The State received no comments. The Settling Defendants are responsible for all future response costs and all operation and maintenance endeavors subject to a comprehensive compliance schedule through May, 2023, when it is anticipated the remediation will be complete.
One party has objected to these proposed Consent Decrees, namely, third-party defendants Sun Company, Inc. (R & M) and Sun Ship, Inc. [hereafter "Sun"], which filed "tentative opposition" arguing that the court needs more information before it can undertake the fairness determination required by CERCLA, and inviting the court to protect Sun and other non-settlors by holding that the governments are limited to recovering the proportionate share of liability from any non-settling defendants and that third-party plaintiffs cannot seek to recover more than their fair share in the remaining contribution action. (Tentative Opp. Br. at 7-11.) In its objection filed seven days before the August 7, 1998 hearing date upon these motions, Sun seeks discovery of information underlying the settlement among the Settling Defendants, including the quantities of material and its nature and toxicity, that each settling party was assumed, for purposes of settlement, to have sent to the Site, as well as the settlement share to be paid by each settling party.
The Settling Work Defendants, also known as the "Offerors Group," strenuously oppose Sun's request, arguing that the settlement process leading to the allocation among Settling Defendants was robust and fair to all participants, including Sun, which assertedly had full access to the settlement process information which it now seeks.
The United States and State of New Jersey likewise assert that Sun has raised no meritorious objection, because details as to each party's settlement share are unnecessary to the assessment of the fairness of the overall settlement, and because Sun's potential liability to the United States is irrelevant and moot.
II. The Settlement Process
To understand the proposed settlements, we start with the processes that led to them. When the contours of the federal and state cases became apparent, and after early dispositive motion practice directed at numerous affirmative defenses, United States v. Kramer, 757 F. Supp. 397 (D.N.J. 1991), the parties expressed an interest in seeking to resolve the case. Because the construction of the EPA's remedy was ongoing through 1993, the total costs were unknown. The numerous potentially responsible parties ("PRP's") were aligned into Liaison Groups,
and representatives of these groups went about drafting a plan for a serious, far-reaching process of data gathering, analysis, and negotiation. This plan was stated in the Settlement Process Protocol, which creates the procedural vehicle for these settlement efforts among the PRP's. Because the ambitious efforts required by the Settlement Process Protocol would require dedication of great resources of time and money, the court agreed to temporarily stay the litigation. The Protocol was adopted by the Settlement Process Participants and was approved by the court, and the liaison counsel were elected to coordinate the process.
The purpose of this process was to reach a fair and reasonable allocation of potential liability among some 300 potentially responsible parties in an ADR process which would create a reliable data base and apply reasonable assumptions regarding the comparative impact of each party's waste stream to the Helen Kramer Landfill. Pursuant to the requisites of the Protocol, all participants were required to respond to a detailed common questionnaire,
and responses were audited by the Settlement Process Committee and by the selected Waste Accountant, which was a large accounting firm. (Hyatt Aff. P 5.) When an adequate data base had been achieved, after many months of efforts, the participants selected Clean Sites, Inc., an environmental litigation support firm specializing in dispute resolution, to serve as the Allocation Consultant. (Hyatt Aff. P 6).
Pursuant to the Protocol, Clean Sites prepared an allocation plan, which was to be a non-binding "suggested method by which the costs of any such settlement [with the United States and the State] could be divided among the Participants." (Settlement Process Protocol, P III.D.1.) Clean Sites considered criteria suggested by the participants as equitable factors relevant to the relative fault or culpability of the participants. (Hyatt Aff. P 7) Clean Sites then articulated those criteria and applied them, attempting to replicate the result which would have occurred in an allocation of responsibility by the court after trial under CERCLA Section 113(f), 42 U.S.C. § 9613(f). (Hyatt Aff. P 7.) Clean Sites issued a draft allocation report which was subject to advocacy and cross-fire within the settlement process, as one additional step toward a reliable and fair allocation. The final allocation was the "Clean Sites Report."
Under the Protocol, at least two-thirds of weighted voting power was required for the acceptance of the Report as a basis for further negotiations, but the vote fell just short. (Hyatt Aff. P 9.) When no alternative allocation plan emerged, the court concluded that sufficient time had been consumed in the allocation process without coming to an approved final plan, and the stay of litigation was lifted, including discovery and motion practice related to the recoverable costs and the liability of direct defendants.
The participants then decided to continue to use the Clean Sites Report as a basis for further negotiations among themselves, subject to the court's supervision by United States Magistrate Judge Joel B. Rosen, who served as Settlement Judge from 1996 to date.
The participants selected co-mediators
and, pursuant to Section IV of the Protocol, "entered into negotiations to allocate among themselves the cost to settle some or all of the claims associated in the [Federal and State cases]." (Hyatt Aff. P 9.)
Meanwhile, negotiations toward a global settlement had gone forward between the United States and State of New Jersey and the representatives of various groups of PRP's. Court-supervised discussions attempted to develop a framework for compromise of the parties' positions in 1994 regarding the overall settlement demands.
The State reached agreement-in-principle with a group of participants who would take over the operation and maintenance functions at the site in 1997, to be followed upon approval of the Consent Decree by payment of a sum of money which reduces somewhat the State's past costs and guarantees payment of future remedial and administrative costs. The United States reached tentative accord with the Offerors Group, which is the core group of defendants bearing the transaction costs of settlement and the risk of under-recovery.
According to counsel for the United States, "The Offerors Group offered to settle with the United States, based both on prior and anticipated settlements with other parties and on their willingness to pursue non-settlors in contribution litigation." Mem. of United States at 7.
The Clean Sites Report served as the basis for further negotiations between the Offerors Group and other Settlement Process Participants, resulting in a negotiated allocation among the Offerors Group and about 240 other participants.
This overall group became the Settling Defendants listed in Appendix A to the Consent Decree, all of which have submitted signature pages now attached to the original Consent Decree.
In addition to these proposed Consent Decrees with the federal and state governments, the United States anticipates concluding negotiations in the future for an amendment to this decree to provide for de minimis treatment of approximately 150 of the Settling Defendants. The main effect of such a settlement would be to remove the "re-opener" conditions on the United States' covenant not to sue with respect to such de minimis parties, pursuant to CERCLA § 122(g), 42 U.S.C. § 9722(g). Until such negotiations are concluded, such a de minimis component is not presently before this court.
A. Scope of Review
The United States and the State of New Jersey seek judicial approval of the respective Consent Decrees they have negotiated with the Settling Defendants. A court should approve entry of a consent decree when it is satisfied that the decree is fair, reasonable, and consistent with the Constitution and the mandate of law. United States v. Rohm and Haas Company, 721 F. Supp. at 680; United States v. Acton Corp., 733 F. Supp. 869, 871 (D.N.J. 1990). The standard to be applied "is not whether the settlement is one which the court itself might have fashioned, or considers as ideal, but whether the proposed decree is fair, reasonable, and faithful to the objective of the governing statute." United States v. Cannons Eng'g Corp., 899 F.2d 79, 84 (1st Cir. 1990); In re Cuyahoga Equip. Corp., 980 F.2d 110, 118 (2d Cir. 1992); United States v. Akzo Coatings, 949 F.2d 1409, 1424-26 (6th Cir. 1991); United States v. Charles George Trucking, Inc., 34 F.3d 1081, 1085 (1st Cir. 1994); United States v. Hercules, Inc., 961 F.2d 796, 800 (8th Cir. 1992). Congress anticipated that the federal courts would apply standards with broad generality to determine whether the proposed decrees are both fair and faithful to the statute, taking into account the interests of the public at large, the settling parties and the non-settlers alike. H.R. Rep. No. 253, Pt. 3, 99th Cong., 1st Sess. 19 (1985), reprinted in 1986 U.S. Code Cong. & Admin. News 3038, 3042.
The First Circuit noted the adaptability of this review standard to the different circumstances arising in CERCLA matters:
The concepts' amorphous quality is no accident or quirk of fate. We believe that Congress intended, first, that the judiciary take a broad view of proposed settlements, leaving highly technical issues and relatively petty inequities to the discourse between parties; and second, that the district courts treat each case on its own merits, recognizing the wide range of potential problems and possible solutions. When a court considers approval of a consent decree in a CERCLA case, there can be no easy-to-apply check list of relevant factors.
Cannons, 899 F.2d at 85-86.
Contrary to the view expressed by Sun as the objecting party, the court does not have the duty to reconstruct the settlement process and review the allocated shares with mathematical exactitude by delving into the data and reports upon which the settling parties based their negotiations. This approach was rejected by this court in United States v. Rohm and Haas, 721 F. Supp. at 680-81, where Judge Gerry wrote:
[The Court's task] is not to make a finding of fact as to whether the settlement figure is exactly proportionate to the share of the liability approximately attributed to the settling parties; rather, it is to determine whether the settlement represents a reasonable compromise, all the while bearing in mind the law's generally favorable disposition toward the voluntary settlement of litigation and CERCLA's specific preference for such resolution.
Deference to the parties' judgments regarding these settlements is appropriate in this case. The policy favoring settlement, articulated in CERCLA, is especially strong where a consent decree has been negotiated by the Department of Justice on behalf of the EPA. United States v. Cannons Eng'g Corp., 720 F. Supp. 1027, 1035 (D. Mass. 1989), aff'd, 899 F.2d 79 (1st Cir. 1990); Akzo Coatings, 949 F.2d at 1436; Charles George Trucking, 34 F.3d at 1085. The quality of the negotiators on behalf of the settlement process participants is likewise notable where, as here, "a crew of sophisticated players, with sharply conflicting interests, sit at the table" representing "so may affected parties, themselves knowledgeable." Cannons, 899 F.2d at 84. Applying these principles, we will consider Sun's objection and examine the overall fairness, reasonableness, and fidelity to law on a detailed basis momentarily.
B. Sun's Objection
In addition to considering the overall fairness, reasonableness, and fidelity of the Consent Decrees, the court must consider Sun's specific objection. Sun argues that the decrees are unfair to non-settlers due to the so-called "secretive nature of the settlements" and the failure of the allocation report to adopt the evidence and inferences therefrom that had been urged by Sun in the settlement process. (Tentative Opp. of Sun Third-Party Defendants, at 4-5.) Sun questions the premises of the allocation report as applied to its waste stream, id., which it believes did not go to the Helen Kramer Landfill at all, as stated by Sun's counsel at oral argument.
First, the court finds that the nature of the settlements was not "secretive." Sun, as a settlement process participant, had all the rights under the Settlement Process Protocol to inspect and review the underlying data from all participants, whether within or outside its suspected waste stream, and to receive and propose corrections to the Waste Accountant's Report and to the Draft and Final Allocation Reports. There is no dispute that the data and the premises applied to these were articulated to all participants by the allocator (Clean Sites). Sun received this information and analysis, and presumably it received feedback to its proposed revisions and redactions, too, all as called for in the Settlement Process Protocol. If one holds this process up against the template of pretrial discovery and adjudication at a non-jury trial, one finds a greater amount of disclosure, testing of the evidence, and repeated opportunity to correct errors of the allocator/adjudicator in the Settlement Protocol Process.
Sun's objection then boils down to its belief that the allocated share assigned to it through the process was too high, because Sun does not credit the underlying factual findings and presumptions. It is the nature of the allocation process that reasonable parties may disagree about the facts and assumptions underlying the assigned shares, especially where the Kramer Landfill records included no waste-in lists and many records were lost or destroyed. Although Sun is the only party to object to the allocation process, one suspects many settling parties also may believe they are being asked to pay too much, given other plausible views of their potential liability.
It suffices to find that the process took all known facts into account, including Sun's proposed facts, weighed them, entertained Sun's objections, and gave Sun a plausible explanation for its proposed settlement allocation, all as revealed in Sun's own submissions. [Tentative Opp. of Sun, at 4-5 & Ex. 2 (Third-Party Plaintiffs' Supp. and Amended Interrogatory Responses, 7/10/98)]. Sun disagrees and exercises its right to refrain from settlement on the proposed terms. This is not prejudicial nor is it unfair to Sun.
If Sun is correct that it is not liable for any hazardous wastes discharged at the Helen Kramer Landfill, it will be entitled to judgment in its favor, either by summary judgment or after trial.
Moreover, even assuming Sun is correct that the allocators erred in determining Sun's share, such a circumstance does not mean that the overall settlement should be rejected by this court. It is the nature of a multi-party hazardous waste settlement allocation that the process seeks to predict the eventual interplay at trial of complicated facts and relationships based on incomplete or ambiguous data and other uncertainties. Not surprisingly, even reasonable predictions can be "wrong." To say this is not to indict the predictive process; rather, it is to place Sun's objection into perspective. As the only party voicing such an objection, Sun has not persuaded this court that the process was substantially flawed in its determinations.
Finally, Sun objects to the form of the Consent Decrees because they do not contain the suballocation amounts for each Settling Defendant. The Consent Decrees instead contain the overall undertakings of the group of settling parties, including payments totaling $ 95 million plus interest in the United States Consent Decree, and $ 9.77 million and O & M expenses in the State Consent Decree, and $ 190,000 and other undertakings to conserve wetlands in the State Natural Resource Damages Decree. Neither the United States nor the State negotiated the shares of individual settlors. Instead, both plaintiffs engaged in the well-recognized (and practically imperative) practice of negotiating an overall settlement with a representative group of PRP's. Groupwide negotiation, through liaison representatives, is nothing new,
as other courts have recognized. See United States v. Charles George Trucking, 34 F.3d at 1081 (explicitly approving process resulting in consent decree which "did no more than assign payment responsibility to classes of [PRPs], leaving the question of allocation inter sese to the class members themselves"); United States v. Acton Corp., 733 F. Supp. at 873 (finding EPA's practice of negotiating with a representative group of PRPs, then having them resolve specific allocation shares among themselves, to be practical and reasonable); Kelley v. Thomas Solvent Co., 717 F. Supp. 507, 517 (W.D. Mich. 1989) (entering consent decree and declining to order hearing and further discovery even though there was no actual allocation determination); In re Energy Coop., Inc., 173 B.R. 363, 368 (N.D. Ill. 1994) ("requiring such precision as to the total extent of the harm caused and the role of each potentially responsible party is unwarranted.... We find no conceivable reason why we should require the environmental settlement agreement to delineate suballocation...."); United States v. Mid-State Disposal, Inc., 131 F.R.D. 573, 577 (W. D. Wis. 1990) ("It is not within this Court's purview to closely scrutinize the allocation of liability among the potentially responsible parties. The Court's core concern must be whether the proposed consent decree furthers the interest of CERCLA, and one of these interests is to encourage settlement to promote the speedy resolution of harmful environmental concerns."); United States v. GenCorp, Inc., 935 F. Supp. 928, 934-35 (N.D. Ohio 1996) (approving settlement which did not disclose for each party the settlement amount, the proportion of liability and the rationale).
A case cited by Sun, United States v. Montrose Chem. Corp., 50 F.3d 741 (9th Cir. 1995), although reversing approval of a CERCLA settlement whose overall basis was not in the record below, did not speak to the issue of whether the court should require disclosure and evaluation of the individual participants' shares and the basis for them. In Montrose, the Ninth Circuit found that the district court had no information from which to conclude that the overall $ 45.7 million settlement figure was reasonable. The district court had failed to compare "the proportional relationship between the $ 45.7 million to be paid by the settling defendants and the government's current estimate of total damages...in light of the degree of liability attributable to the settling defendants." Id. at 747, citing Charles George Trucking, 34 F.3d at 1087.
The Montrose court's citation to Charles George Trucking emphasizes the fact that Montrose was not critical of the district court's lack of analysis of individual settlement shares of the participants, for the Charles George Trucking Court said that the individual shares don't matter, because:
After all, the ultimate measure of accountability in any environmental case is the extent of the overall recovery, not the amount of money paid by any individual defendant.
Charles George Trucking, 34 F.3d at 1086.
Disclosure and judicial analysis of the individual participants' shares is irrelevant in this case, where the proposed global settlement is not colored by individual party characteristics, such as inability to pay or severability of harm of particular settlors. The United States and State of New Jersey have seen fit to entertain and accept the group-wide offer. That the individual party shares are in fact already in place within the group, and that each share is derived from the common data, analysis, and negotiation in the Settlement Protocol Process are not in dispute. Further, to require disclosure and judicial examination of each party's proposed settlement share would be to compel the performance of an endless judicial task of micro-adjudication of the reasonableness of each of 250 parties' allocated settlement shares.
This examination could tend toward causing the precise delay and expenditure of judicial resources that the entry of a CERCLA consent decree is meant to avoid.
For these reasons, this court holds that the settling parties need not include in the Consent Decrees their individual monetary settlement shares, their bases of settlement allocation, or their individual proportions of site liability as determined by the settlement process among PRPs. It is sufficient that the terms, rationales, and bases of the Consent Decrees have been disclosed on a groupwide basis including all settling parties, from which the court may determine whether the group's proposed settlement is fair, reasonable, and faithful to CERCLA.
C. Analysis of the Consent Decrees
1. Procedural and Substantive Fairness
Assessing fairness of a CERCLA consent decree requires addressing both procedural and substantive fairness. Procedural fairness considers the openness, candor, and bargaining balance of the settlement process. Cannons, 899 F.2d at 86. The procedural fairness analysis looks at the quality of "informed, arm's length bargaining." United States v. Rohm and Haas, 721 F. Supp. at 681, quoting City of New York v. Exxon Corp., 697 F. Supp. 677, 692 (S.D.N.Y. 1988).
As outlined above, the court holds that the Settlement Protocol Process, which led to the Clean Sites Report and negotiations through the professional mediation team under supervision of the Magistrate Judge, was procedurally fair. Settlement process participants, working with the court, designed and drafted the protocol, which defined the procedures and the participants' obligations and rights. A large majority of the PRPs opted in to the process and selected group liaison counsel to coordinate it. Pursuant to the Settlement Process Protocol, a national accounting firm supervised collection and compilation of data gathered through extensive questionnaire responses and document production. Parties' obligations to one another were enforced through the group liaison counsel, functioning as the Settlement Process Committee. The data were open to inspection and verification by all participants, to assure accuracy and completeness. Two rounds of corrections to this enormous
data base were conducted by the Waste Accountant to eliminate mistakes such as double-counting of wastes, underreporting, or misidentification of generators or haulers. This court oversaw the administration of the Settlement Process Protocol through frequent conference calls and occasional hearings as the reliable data base was constructed over a two-year period, during which the settlement process participants' litigation burdens were stayed.
Every participant had access to the court to register complaints if it appeared that the settlement process was conducted unfairly or otherwise in a manner inconsistent with the Settlement Process Protocol. Also, disputes as to the adequacy of responses were subject to resolution by a Special Master selected by the participants pursuant to the Protocol. Importantly, the process was entirely non-binding and a participant was free to opt out as if it had never participated, subject only to paying its share of the settlement process fees incurred before its withdrawal.
The assembly of the reliable data base was a necessary but not a sufficient step toward completion of the process. Those data, as refined and set forth in the Waste Accountant's Report, were furnished to all participants and eventually to Clean Sites, Inc., which under the Protocol heard the participants' views upon the various equitable allocation factors to be applied. Clean Sites made adjustments for types of wastes and converted the various reported volumes (e.g., tank loads, truck loads, barrels, tons, gallons) to a common currency, and began the allocation process by applying the developed allocation factors and assumptions. Again, the participants, whose interests throughout the process were generally adverse to each other, were afforded opportunities to present advocacy with respect not only to their own allocated shares, but also with respect to the shares allocated to other participants. This arm's length check-and-balance through informed advocacy by knowledgeable counsel was a feature that also assured procedural fairness. There is no dispute that Clean Sites, "after considering the equitable factors suggested by the Participants and selecting those equitable factors it deemed appropriate for consideration under the circumstances, based the Clean Sites Report on such equitable factors... [and] supplied those equitable factors, or attempted in good faith to apply those equitable factors, evenhandedly and consistently with respect to all the Participants.... Clean Sites, in preparing the Clean Sites Report, attempted, as best it could, to replicate the result which would have occurred had the Court allocated responsibility pursuant to Section 113(f) of [CERCLA]." (Hyatt Aff. P 7.)
Finally, the mediation team assisted the participants in reaching closure within the allocation process. Every party voicing an opinion has praised the steadfast and fair efforts of the mediation team and the supervision and coordination provided by Magistrate Judge Rosen. Counsel for the United States participated informally in the allocation settlement process through the mediators. The United States has received self-disclosure of information from various settling parties and knows that "the participating parties' shares in the allocation were generated based upon various 'nexus theories' tying the parties to the Site through direct shipments and assorted transporters, the quality of the evidence of actual disposal at the Kramer Landfill, the volume of waste shipped, and the relative toxicity of the waste." (Mem. of United States, at 7.) Further, the United States confirmed that "the allocation report also gave the municipalities a one-third discount due to their status, and allocated unattributable wastes pro rata among all participating parties." Id.
The court also finds that the underlying allocation and overall settlement embraced in the Consent Decrees are substantively fair. Substantive fairness "goes to the fairness of the result, and requires that the settlement terms are 'based upon and roughly correlated with some acceptable measure of comparative fault....'" United States v. Atlas Minerals and Chems., 851 F. Supp. 639, 653 (E.D.Pa. 1994), quoting Cannons, 899 F.2d at 86. This requires the government to demonstrate a "plausible explanation" for "measuring comparative fault and allocating liability" in the amount set forth in the Consent Decree. Cannons, 899 F.2d at 87. Substantive fairness includes the "concepts of corrective justice and accountability: a party should bear the cost of the harm for which it is legally responsible." Id. The United States and the State have met this burden.
The substantive fairness of the apportionment of liability derives from the carefulness with which it was determined in the arm's length bargaining process among many parties with adverse interests. There is a highly rational basis for the apportionment, articulated by the neutral evaluators and evidencing a successful good faith attempt to replicate the application of equitable factors to the facts and assumptions of each participant's comparative fault. A most telling measure of substantive fairness is the fact that the vast majority of participants followed through and ratified the non-binding allocation, with the advice of knowledgeable and experienced counsel.
The substantive fairness also derives from the extensive hard bargaining between the governments and the PRP representatives, and more specifically the counsel for the Settling Work Defendants (or "Offerors"). Untold hours of bargaining between and among these experienced and creative counsel forged these Consent Decrees which provide a fair compromise of the parties' strongest and weakest positions;
where this settlement "is the product of informed, arms-length bargaining by the EPA, an agency with the technical expertise and the statutory mandate to enforce the nation's environmental protection laws, in conjunction with the Department of Justice ... a presumption of validity attaches to that agreement." United States v. Rohm and Haas, 721 F. Supp. at 681, quoting City of New York v. Exxon Corp., 697 F. Supp. 677, 692 (S.D.N.Y. 1988). Here, the federal and state environmental experts, armed with thorough knowledge of one of the most intensely studied Superfund sites in the nation, having also conducted confirmatory discovery and information exchange and having the benefit of a completed remedy now in its second year of full operation, negotiated fairly and struck a substantially fair compromise.
The court has also considered whether the Consent Decrees are fair to non-settlors, as it is required to do. United States v. Rohm and Haas Co., 721 F. Supp. at 680 ("effect of the proposed settlement on nonsettling parties" is a factor in approval of CERCLA consent decrees); Akzo Coatings, 949 F.2d at 1435; United States v. Charter Int'l Oil co., 83 F.3d 510, 522 (1st Cir. 1996). Only one non-settlor, Sun, has expressed any objection on this ground. Sun is concerned that, in compromising their overall claims at 77 percent of the highest damages estimate, the federal and state Consent Decrees leave a 23 percent uncollected share which may impose too great a burden on non-settling parties, in the event a non-settlor is found to be jointly and severally liable under Section 107(a) of CERCLA, 42 U.S.C. § 9607(a).
The short answer is that Sun, like every remaining non-settlor, is not a direct defendant in the Section 107(a) claims of the United States or State, and it is therefore not liable to imposition of joint liability for this site. As this court previously held, CERCLA imposes joint and several liability for all response costs only upon direct defendants in Section 107(a) claims. Kramer, 757 F. Supp. at 414-16; United States v. Kramer, 953 F. Supp. 592, 599-600 (D.N.J. 1997). Sun, like all non-settlors, will occupy the position of a contribution defendant upon the claims for contribution brought on behalf of the Offerors Group of Settling Defendants, pursuant to Section 113(f)(1) of CERCLA. The liability of contribution defendants under Section 113(f) may be several, but it may not be joint. Id. As a contribution defendant, Sun's liability must first be proved by the contribution plaintiffs, and, if liable, then a suitable allocation of Sun's share must be determined taking into account such "equitable factors as the court deems appropriate" under CERCLA § 113(f)(1), applying federal common law including the factors reasonably calculated to assess Sun's proportionate fault. Kramer, 757 F. Supp. at 412; Kramer, 953 F. Supp. at 597-601. It has also been determined that contribution defendants which are found liable may be called upon to bear an equitable share of the "orphan share" of past and future remedial and response costs in this case. Kramer, 953 F. Supp. at 601. The court declines to render an advisory opinion as to the future application of the other equitable factors that may apply to Sun if it is found liable for equitable contribution under CERCLA § 113(f)(1).
Further, there is little or no likelihood that the present third-party defendants who are non-settlors can be joined as direct CERCLA defendants by the United States or by the State. It appears the statute of limitations period for doing so expired by October of 1997, assuming no further response costs are incurred in the future.
For all those reasons, the court finds that the Consent Decrees are fair to non-settlors, who will continue to enjoy the benefit of pretrial preparation, dispositive motion practice and, if necessary, trial in accordance with the Federal Rules of Civil Procedure and Federal Rules of Evidence.
2. Reasonableness of Consent Decrees
It has been held that "a district court's reasonableness inquiry, like that of fairness, is a pragmatic one, not requiring precise calculation." United States v. Charter Int'l Oil Co., 83 F.3d 510, 521 (1st Cir. 1996). To ascertain reasonableness, the court must make an independent determination of the technical adequacy of the work to be performed in cleansing and protecting the environment, whether the compensation to the public for response costs is satisfactory, and the risks and delays inherent in continuing the litigation. Cannons, 899 F.2d at 89-90.
Here, the technical adequacy of the remediation under this settlement is not in question.
The remedy has been completed, the long-term operation and maintenance (O&M) have commenced, and fifteen months' experience of O&M managed by the Settling Work Defendants has been underway and have earned the State's expression of overall satisfaction with their performance. The settlement requires this O&M by the settling parties to continue through May 12, 2023 and to undertake the five-year reviews including any studies reasonably required by EPA. The Consent Decrees also place the incentive for thorough and competent O&M squarely upon the settling parties who remain responsible for future response costs.
The court also finds the compensation to the public to be satisfactory. The United States will recover $ 95 million of a possible maximum of $ 123 million for Remedial Investigation and Feasibility Study, the remedial design, remedy construction, indirect and enforcement costs, and pre-judgment interest. This represents a 77% recovery of total costs. By way of compromise, the United States, through the upper levels of the U.S. Department of Justice and the U.S. Environmental Protection Agency, agreed to accept this sum, together with other covenants and undertakings by the settling parties, as appropriate to resolve all claims by the United States. This compromise appropriately takes into account such factors as the estimated volume and nature of the hazardous substances contributed to the Site by the settling parties and various "orphan" parties and the risks and expense of litigation necessary to pursue the case against the Direct Defendants through trial and judgment. (Mem. of United States at 6.)
Likewise, the State of New Jersey, through the Attorney General and the Department of Environmental Protection, assessed the monetary claims for § 107(a) costs and struck a similar balance by way of compromise, accepting the sum of $ 9.77 million of its pre-May 1997 costs and 100% of its future costs at the site. The complexity and risks of litigation and the value of an early settlement freeing state resources for O & M and remedial measures for use at other sites also spurred the compromise. (Mem. of State at 9.) The State's recovery likewise represents nearly 80% of the total past costs incurred by the State, while guaranteeing the continuation of operation and maintenance at the expense of the settling parties through the year 2023, together with paying the costs of future response actions through that time.
Damage to natural resources, while difficult to quantify, is also suitably addressed by these decrees. The New Jersey Department of Environmental Protection and the federal natural resource trustees in the U.S. Fish & Wildlife Service and the National Oceanic and Atmospheric Administration have studied the effect of the landfill upon its surroundings, especially Edwards Run and associated wetlands adjacent to the landfill which received some discharge of contaminated leachate and runoff. The effects on migratory waterfowl and fresh water fish, as well as migratory fish, have been examined, since Edwards Run feeds Mantua Creek, which is tidally influenced from the Delaware River. No serious or prolonged degradation toward these species of aquatic life have been noted, yet damage to the wetlands has been observed; hence, the State National Resource Damage Consent Decree suitably requires the Settling Defendants to purchase wetlands and wooded uplands amounting to 151 acres, which will be preserved in perpetuity and conveyed by deed to the Township of West Deptford, together with payment of $ 190,000 in damages compensation to the State. This perpetual restriction upon valuable open land (which is itself costing the settling parties an additional sum of $ 968,614), consisting of a greater area than the affected wetlands, constitutes a gain for the public and a desirable resolution of the natural resource damage claims, and is consistent with N.J.S.A. 58:10-23.11g(a)(2). The federal Consent Decree requires compliance with the State's Decree as to these natural resources, consistent with Section 107(a)(4)(C) of CERCLA, 42 U.S.C. § 9607(a)(4)(C).
The settling parties are also paying a reasonable proportion of the overall liability when one considers the rather substantial fair share which would otherwise be payable by the owner/operator, Helen Kramer and her related entities, if she were not insolvent. The Kramer family were the active owners and operators of the Superfund site which has made their name somewhat infamous. Although many tons of hazardous waste at this site cannot be linked to any other party, and the origin of many other tons is in dispute, it can all be linked to the Kramers, yet they are unable to contribute to the settlement and have been voluntarily dismissed as a direct defendant. The 77% compromise thus also reflects the governmental recognition that it would be unfair to place this entire owner/operator share upon this subset of other PRPs whose "ideal" share of liability -- "based on perfect knowledge of harm caused by [these] parties only, expressed as a proportion of the total costs of remediation at the site," Kramer, 953 F. Supp. at 595 -- is undoubtedly less than the compromise figure reached for this group. These parties are paying a disproportionate share of their liability measured in "ideal" terms, leavened, however, by the risk that their ultimate share of liability to the United States as direct defendants could be 100% by operation of joint and several liability under § 107(a) of CERCLA, as previously discussed. The monetary incentive to settle litigation occurs at that point where the risks of litigation move the government and the settling parties away from their respective "ideal" positions of 100% recovery for the government versus only the proportionate "ideal" share for a PRP. That balance has been reasonably struck in these consent decrees.
The court further finds that the risks of litigation have been reasonably appreciated by the settling parties. The State of New Jersey aptly points out:
The settlement is also reasonable in light of the complexity of the various liability cases to be made against various Defendants. The matters in dispute arise out of the operation of a landfill as far back as 30 years ago. Memories are inexact. Key witnesses have died. The documentary record is voluminous, complex, and in certain respects, not complete.
Mem. of State at 9.
The United States, too, has properly acknowledge the risks and costs of bringing the matter to trial, given the relative strengths and weaknesses of the parties' litigating positions. (Mem. of United States at 23.) For example, issues remained regarding the scope of review to be applied to post-ROD (record of decision) design changes by the EPA which may have significantly changed the approved remedy, as to which the direct defendants may have argued that such changes were not in accordance with law or were otherwise inconsistent with the National Contingency Plan. The court mentions, but does not rule on, some of the competing litigation positions, since such a ruling would require an adjudication of merits that can only be performed after discovery and trial, and not in the context of examining the reasonableness of a proposed consent decree; to do so would be at cross-purposes with CERCLA's goal of promoting compromise settlement. Comerica Bank-Detroit v. Allen Indus., 769 F. Supp. 1408, 1411-12 (E.D. Mich. 1991); Arizona v. Motorola, Inc., 139 F.R.D. 141, 148 (D. Ariz. 1991).
Finally, the court finds that the consent decrees are reasonable in placing the risks of future uncertainties upon the settling parties rather than the governments. For example, the decrees are subject to "reopener" in the event EPA determines that previously unknown conditions or information indicate that the remedial actions are not protective of the human health or the environment. The Settling Defendants, however, have obtained the repose offered by contribution protection under § 113(f)(2) of CERCLA, by extinguishing the contribution claims of other parties against the Settling Defendants with respect to the Site.
Taking all these factors into account, the court has no hesitation in finding that these Consent Decrees are reasonable.
3. Consistency with CERCLA
The mandate of CERCLA is to remedy releases of hazardous substances into the human environment by imposing the burdens of remediation and of future risks upon parties liable for causing the harm, consistent with due process. Similarly, under the Spill Compensation and Control Act, the New Jersey Legislature has declared the State's policy "to control the transfer and storage of hazardous substances and to provide liability for damage sustained within this State as a result of any discharge of said substances, by requiring the prompt containment and removal of such substances...." N.J.S.A. 58:10-23.11a. These Consent Decrees will serve these public interests.
CERCLA encourages prompt and effective cleanup by responsible parties, while preserving both public finances and public health. The decrees largely replenish the CERCLA Superfund and the New Jersey Spill Fund, which constitute limited public resources, enabling the funds to be used at other sites. (See, e.g., 131 Cong. Rec. H11,070 (Dec. 5, 1985) (Statement of Rep. Florio); N.J.S.A. 58:10-23.11r.) Further, the Settling Defendants' agreement to perform the five year reviews likewise frees public money to be devoted to other sites where public health and the environment are threatened. The settlements have also well served CERCLA's goal of reducing litigation and transaction costs, see Cannons, 899 F.2d at 90; Rohm & Haas Co., 721 F. Supp. at 696. By simplifying the remaining litigation, which is reduced to a contribution recovery action by the settlors against a few remaining alleged PRPs, the public and the parties benefit from the "saving of time and money that results from the voluntary settlement of litigation." Citizens for a Better Env't v. Gorsuch, 231 U.S. App. D.C. 79, 718 F.2d 1117, 1126 (D.C. Cir. 1983), cert. denied sub nom. Union Carbide Corp. v. NRDC, 467 U.S. 1219, 81 L. Ed. 2d 373, 104 S. Ct. 2668 (1984). Likewise, the savings of governmental litigation resources of experienced counsel and staff may now instead be devoted to other pressing cases where litigation is necessary.
The tangible benefits of containment, remediation, and restoration of a healthy environment for humans, animals, and plants, and the perpetual preservation of pristine lands in the vicinity, are the highest manifestation of the public benefits of these decrees, all of which this court finds to be faithful to the mandates of CERCLA.
After eight years of litigation and settlement processes, and after an independent review of the procedural and substantive fairness, reasonableness, and fidelity to the public interest embodied by the Federal Consent Decree, the State Consent Decree, and the State Natural Resource Damages Consent Decree, this court concludes that these decrees should be approved and entered.
September 3, 1998
U. S. District Judge
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October 7, 2010
GORDON DALE MEADOR, PLAINTIFF,v.WEDELL, ET AL., DEFENDANTS.
Plaintiff is a state prisoner proceeding pro se with a civil rights action pursuant to 42 U.S.C. § 1983. Plaintiff has filed motions for a preliminary injunction and the appointment of counsel.
Plaintiff's motion for a preliminary injunction is defective and premature. Filed concurrently with this order, the court has issued an order requiring plaintiff to submit documents to effect service on defendants Wedell and Bobbola. The defendants have not yet been served with process nor have they been provided an opportunity to respond to plaintiff's allegations. Plaintiff's motion for a preliminary injunction is also defective in a number of respects. In order to obtain preliminary injunctive relief, a party must demonstrate "'that he is likely to succeed on the merits, that he is likely to suffer irreparable harm in the absence of preliminary relief, that the balance of equities tips in his favor, and that an injunction is in the public interest.'" Stormans, Inc. v. Selecky, 586 F.3d 1109, 1127 (9th Cir. Oct. 28, 2009) (quoting Winter v. Natural Res. Def. Council, Inc., U.S., 129 S.Ct. 365, 374 (2008)). Here, plaintiff has not demonstrated that he satisfies the requirements for the granting of a preliminary injunction. Plaintiff has not made a sufficient showing at this stage of the litigation with respect to a number of critical issues that would be necessary to find that he was likely to succeed on the merits, such as, whether defendants were deliberately indifferent about plaintiff's medical care, whether and how plaintiff has been harmed by delays in receiving medical care, and whether plaintiff's complaints regarding the medical care he has received is merely a difference of opinions as to the appropriate medical care to be rendered rather than being indicative of deliberate indifference on the part of defendants. Moreover, Local Rule 231(d) requires that specific documents be submitted for a preliminary injunction and plaintiff has failed to comply with the Local Rule in this regard. Plaintiff's affidavit, filed on August 10, 2010, also fails to address any of the deficiencies noted above. Therefore, plaintiff's motion for a preliminary injunction will be denied without prejudice as both defective and premature.
Plaintiff has also filed a motion for the appointment of counsel. The United States Supreme Court has ruled that district courts lack authority to require counsel to represent indigent prisoners in § 1983 cases. Mallard v. United States Dist. Court, 490 U.S. 296, 298 (1989). In certain exceptional circumstances, the court may request the voluntary assistance of counsel pursuant to 28 U.S.C. § 1915(e)(1). Terrell v. Brewer, 935 F.2d 1015, 1017 (9th Cir. 1991); Wood v. Housewright, 900 F.2d 1332, 1335-36 (9th Cir. 1990). In the present case, the court does not find the required exceptional circumstances. Plaintiff's request for the appointment of counsel will therefore be denied.
Accordingly, IT IS HEREBY ORDERED that:
1. Plaintiff's April 14, 2010 motion for preliminary injunction (Doc. No. 2) is denied without prejudice as both defective and premature; and
2. Plaintiff's April 22, 2010 motion for the appointment of counsel (Doc. No. 6) is denied.
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- Two-time Olympian (2012, 2016); Six-time Olympic medalist (5 gold, 1 silver)
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