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Mild spoilers for Samantha Carter's character through the pilot episode of "Stargate: Universe" and for Helen Magnus's character through "Sanctuary" Season 2
Kind of brought on by reports of the Helen Magnus/Sam Carter in an elevator skit performed by Amanda Tapping and Thomasina Gibson at AT4
Sam walked into the convention, offering small smiles to the scientists and engineers whom she passed.
"I've told you before, Sam, I absolutely love these things." Dr. Bill Lee said with a grin as they walked into the mix and mingle.
"I know." She said with a chuckle. "It's the 'dynamite singles' scene', right?"
Bill grinned as he grabbed a couple of drinks and joined a few of the other female scientists as Sam shook her head.
She commanded the George Hammond now, but in order to keep her from disappearing from the scientific community, like Rodney McKay had, the Air Force had insisted that she take a little time off to attend this convention.
Truth be told, she had a hundred other places where she'd rather be right now. And most of them were within a few blocks of this hotel in DC.
"You'll want one of these, I suppose," A woman's voice suggested, offering her a drink.
"Oh, no, thank you." Sam said, turning to refuse the offer. The last thing she needed was to get herself involved with a...
Her own blue eyes twinkled back at her in amusement under carefully styled brown hair. "Dr. Magnus," she said, shaking her head. "What are you doing here?"
"I might ask the same of you," she said, offering the drink once more. "As I heard you were no longer in Research and Development."
"You heard that?" Sam asked, raising an eyebrow somewhat suspiciously as she took a sip of the wine Magnus had brought her.
Helen shrugged. "It's quite simple to keep yourself informed if you know that there's something of which you'd like to be kept informed."
"And being friends with the President, doesn't hurt..." Sam finished.
Helen smiled mysteriously as she sipped from her own glass. "I know a great many influential and powerful people."
"Is that why you're here? To "make contact"?" Sam asked, curiously.
"Why not?" Helen teased. "We are family, after all."
"We certainly are that." Sam said, shaking her head with a small chuckle.
"Actually, I'm here for Henry – my engineer. He came down with a head cold and was unable to attend himself."
"Ah." She said, nodding. "I guess in your line of work, you need to be apprised of the latest developments in technology."
"Yes, but so far I've been only mildly impressed." She said with a shrug. "My father's technological advancements alone have far surpassed this level of amateur competition."
Sam shook her head in amusement at the eccentric woman.
"In fact, until now, I've been astounded by your work, Samantha."
"My work?" Sam asked, confused.
She nodded with a sly smile. "I knew who you were long before I met you in Cheyenne Mountain."
"How..." Sam asked, confused.
"It's my business to know who is extraordinary in their fields."
"The only thing I didn't count on was how very much like me you looked in person."
"Well...I try..." Sam said with a sardonic grin.
"In fact, I wonder if my staff could notice a difference between you and I." She said, thoughtfully. "Perhaps Will – he is the most observant of the group. And my manservant is one of my oldest and dearest friends..."
"Notice a difference between the two of us?" Sam asked, raising an eyebrow. "You mean, besides the dark hair and British accent?"
"The color is easily changed," Helen said, brushing that concern away. "I used to have yours after all..."
Sam shook her head, somewhat bewildered by her brunette, British double.
"As for the accent, it would be more difficult. After all, I have standards..."
"...And my American accent would be far beneath them." Sam finished.
"Something like that, yes." Helen smiled, goodnaturedly.
Sam chuckled softly.
"What presentation are you making this year?"
"You'll have to check it out." Sam said with a secretive smile.
"I will at that." She said with an amused laugh.
They fell into a companionable silence before Helen looked over at Sam. "Where is your military escort?"
She won a confused look from Sam.
"The General who is so fond of your work?" Helen intimated carefully.
"Oh...him..." Sam said with a light blush. "Uh...he's at work."
"Do you have plans later?"
"Yeah, actually." Sam said, nodding. "Dinner."
"Long-distance relationships are difficult." She said in perfect understanding.
"What about you? Have you got plans after this?"
Helen shook her head. "Not that I know of."
"Which is code for: 'there will probably be a top-secret mission in my future'." Sam said with a knowing chuckle.
"Exactly." Helen smiled.
"Okay, so you know about my love life...what about yours? Ever get back together with the guy in the locket?"
She tensed. "No."
"Not exactly." Helen said, shaking her head nervously.
"Then why aren't you with him?"
"It's a...long-distance relationship. In more of a...metaphorical sense."
"Not interested in sharing feelings?"
"More like I'm not interested in hearing them." She said with a shrug.
Sam's brow furrowed, curiously.
"There are some things that can be forgiven, but never forgotten." Helen said, succinctly.
"Okay..." Sam said, shrugging. She'd been there with Jonas. "So, how's Ashley?" She asked, finally remembering a safe topic.
Helen tensed as she looked away.
"Ashley's gone." She managed, the pain of losing her daughter coursing through her body like a knife to her heart.
"Gone?" Sam asked, confused.
"She...died...several months back."
"I'm sorry to hear it." Sam said, sympathetically.
"Such is the circle of life," Helen said with a small sigh.
Sam took a sip of her drink, trying to decide how to clear the air. "So...I've had a family history question I've been dying to ask you for a while..." Sam finally said, looking over at the older woman.
"Oh?" Helen asked, interested in the new topic. "Go ahead."
"My mom, before she died, told me about this family rumor that...uh...someone in our family tree had dated Jack the Ripper...do you know who?"
Helen tensed again, and Sam's jaw dropped as she stared at the 158-year-old. "Oh my g...it was you?"
Helen managed an uncomfortable smile. "Yes."
"Uh...wow..." Sam managed, surprised.
"When you've been around for as long as I have, there's...quite a colorful tale to be told."
"I bet." Sam said, shaking her head.
"Ladies and gentlemen, the demonstration on the latest security technologies will begin in fifteen minutes in the auditorium to your right."
"Shall we find ourselves some seats?" Helen asked, motioning to the auditorium.
"After you." Sam said, nodding.
Dr. Bill Lee happened to look over at Sam at that moment, and his eyes widened at the image of the nearly identical women. The only difference he could see was that one was blond and the other was brunette. He blinked several times. He couldn't be drunk. He'd only had a half-glass of white wine.
"Bill? You okay?" One of the blonds beside him asked, seriously.
"Fine." He coughed as the women entered the auditorium. He was just losing his mind. It was the stress of his job. That's all it was. "Just fine."


text:
"Quick! You! Go get help! Fast!" Pete pointed to Finn. Finn immediately started to run to a random house. It looked old, this house, an old woman probably lived there, so he tried another one.
Knocking on the door of the one on the other side of Kurts house, Finn turned to check on Kurt, he was coughing now, violently.
The door opened slowly.
"Whats all the screaming?" The burly man who answered the door shouted at Finn. Finn covered his sweating face with his arms, thinking the man was going to attack him, slowly he lowered them. Even though it was afternoon, the man was wearing striped pjs, Finn thought that odd but quickly said: "Please, Sir. Have-you-got-a-phone-we-could-use?-My-friend-has-just-got-hit-by-a-car." Tears ran down Finns face, even though Kurt wasn't Finns best friend, a life was a life.
"Sure, kid. In there." He pointed to a room, Finn rushed in and came out moments later holding a huge old-fashoned phone.
Finn dialed as he ran back to Kurt. The man followed him, anxious to get in on the action.
"Hello. Which service do you require?" A calm woman answered Finn's call.
"Ambulance!" He almost screamed down the phone.
"What is your location?" The same relaxed voice called.
Finn told her and she said that an ambulance would arrive within 10 minutes (or your money back! (no, just kidding!)).
Finn hung up and sighed, Kurt would make it (he hoped)...
"What did they say?" Pete said, worriedly.
"They will be here in under 10 minutes." Finn turned to Kurt. "Its going to be ok." But he was mainly talking to himself.

subset: commoncrawl


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Who We Are: Our expertise is based on a well-trained, experienced professional staff and a serious conscientious attitude toward our clients. Shown below is the Reliable Insurance Agency "family." Click on 'More info" to learn more about them.
Steve Micke, President, CIC, CPIA
Val Wojtysiak, Secretary/Treasurer, CIC, CISR
Personal Lines:
Becky Anderson, CISR
Evon Asleson, CISR
Travis Hansen, CIC
Marsha Hills
Andy Hjelle
Jolene Lust, CIC, CISR, PLCS
Sadie Micke
Nicole Milberger, CISR
Sarah Rautell, CISR
Sam Scherber, CISR
Jude Stephens, CIC
Carrie Torgeson
Collette VanHove
Kyle Wojtysiak, CISR
Commerial Lines:
Greg Beyer
Becky Haley, CISR
Cindy Kopic, CISR
Kristen Modean, CISR
Bobby Sawyer, CIC, PLCS, CLCS
Lindsay Shovein
Micki Wojtysiak, CISR, CLCS
Scott Wojtysiak, CIC, CSRM
Life and Health:
Greg Beyer
Travis Hansen, CIC
Mike Lewis
Jolene Lust, CIC, CISR, PLCS
Starr Marshall, CISR
Bobby Sawyer, CIC, PLCS
Kyle Wojtysiak, CISR
Scott Wojtysiak, CIC, CSRM
Steve Micke
President CIC, CPIA
Steve was born and raised in Cloquet, graduating from Cloquet High School in 1975 and graduated from St. John's University in 1979. He started his insurance career in June of 1979 at Nationwide Insurance Company... More info
218-655-1173 - Fax
Val Wojtysiak
Secretary / Treasurer CIC, CISR
Val began her insurance career in 1979 & joined the Reliable Agency back in June of 1981. Over the years she has obtained the Certified Insurance Service Representative (CISR) and Certified Insurance Counselor (CIC)... More info
218-655-1162 - Fax
Becky Anderson
Becky came to Reliable Agency 17 years ago and has 36 years of insurance experience as a producer and service representative. She graduated from Lake Superior College (formerly D.A.V.T.I.), married and went right into.... More info
218-655-1166 - Fax
Evon Asleson
Evon is originally from the St. Paul, Minnesota area and graduated from Humboldt High School. Her 50 years of experience are primarily in Personal Lines. She has also earned her Certified Insurance Service Representative... More info
218-655-1163 - Fax
Greg Beyer
Greg started his insurance career over 25 years ago as a life insurance agent with Met Life. He expanded the areas of insurance he worked with when he spent 18 years with two local Duluth agencies. It was during this time... More info
Becky Haley
Becky is originally from White Bear Lake and now resides in Barnum. She began her insurance career in 1993 and in 2001 came to Reliable Agency as a Commercial Insurance agent and service representative. Becky is very successful...More info
218-655-1169 - Fax
Travis Hansen
Travis is a 1999 graduate of the University of Wisconsin - Superior. He graduated with a Bachelors of Arts in Business Administration concentrating in Finance. In May of 1999 Travis began his insurance career with...More info
218-655-1167 - Fax
Marsha Hills
Marsha grew up in Saginaw and has lived and worked in the Cloquet area for the past 40 years. She started her insurance career in 2012 working with personal lines and life insurance. She is excited to be part of the Reliable...More info
218-655-1182 - Fax
Andy Hjelle
Andy grew up in Saginaw, MN. He graduated from high school in 2014 and is pursuing an Associate of Business Finance from Fond du Lac Tribal and Community College in Cloquet, MN. Andy joined Reliable Agency in....More info
218-655-9716 - Fax
Cindy Kopic
Cindy has been in the insurance industry for over 33 years with the last 13 years at Reliable Agency in Cloquet. She loves the intricate parts of the commercial lines department, and has a keen knowledge for small to medium businesses...More info
218-655-1172 - Fax
Mike Lewis
Mike grew up in Esko, MN and graduated from Esko High School in 2004. He earned his Bachelor of Arts in Applied Economics with a minor in Finance from the College of St. Scholastica in 2008. Mike obtained his Life and Health...More info
218-655-9715 - Fax
Jolene Lust
In May 2003, Jolene graduated from Bemidji State University with a Bachelor of Arts in Business Administration with an emphasis in Marketing. She began working at Reliable Agency in June of 2003 and was awarded...More info
218-655-1168 - Fax
Starr Marshall
Starr is a 2010 graduate of the College of St. Scholastica - Duluth. She graduated with a Bachelors of Arts degree in the Social Sciences with an emphasis on Gerontology. Starr began her insurance career in 2005 selling...More info
218-655-1165 - Fax
Karen McMillen
Karen was born and raised in Cloquet, and graduated from Cloquet High School in 1981. Karen acquired her Property and Casualty license in November of 2006, and her Life and Health license in April 2007...More info
218-879-6619 - Fax
Sadie Micke
Sadie grew up in Cloquet, MN. She graduated from Cloquet High School in 2012. In 2013 Sadie started her career in sales at DSW. May of 2016 she came to Reliable Agency. Sadie is currently working on getting her Property and Causality.... More info
218-655-1170 - Fax
Nicole Milberger
Nicole joined Reliable Agency in September 2005 and received her Property & Casualty License in October 2005 and Life & Health License in December 2005. She grew up in Esko and graduated from Lake Superior College in... More info
218-655-1160 - Fax
Kristen Modean
Kristen is a Duluth native, graduated from UMD with a Bachelors In Business Administration with a Human Resources Management major. She joined Reliable Agency in 2017. She has worked in employee benefits and payroll...More info
218-655-1175 - Fax
Sarah Rautell
Sarah graduated with a degree in Marketing in 2005, she then went on to obtain her Property/Casualty license in May of 2006. She began her career with Reliable Agency in September of 2006. Her education has continued, and...More info
218-655-1164 - Fax
Bobby Sawyer
Bobby grew up in the Duluth area and is a graduate of Proctor High School's class of 1999. He went on to study Accounting at the University of Minnesota-Duluth. For the past five years, Bobby has enjoyed working for AT&T...More info
218-655-1171 - Fax
Sam Scherber
Sam is a 2007 graduate of Proctor High School and a 2012 Graduate of the University of Wisconsin-Superior with a degree in Communications. While she was attending UWS, she obtained her Property/Casualty license in the ...More info
218-655-1177 - Fax
Lindsay Shovein
Lindsay grew up in the Duluth area and graduated from Denfeld High School in 2001. Her background in Sales and Marketing has assisted her in understanding her customer and vendor needs in both a retail and corporate setting...More info
218-655-1178 - Fax
Jude Stephens
Jude's insurance career spans more than three decades with stints at a large carrier, brokerage houses and various sized agencies working in new business, licensing and registration, office services, commercial...More info
218-655-3366 - Fax
Carrie Torgeson
Carrie graduated from Duluth East High School in 1981. She worked in the banking business for 8 years before starting and running her own in home daycare for 17 years. This allowed her to be at home and raise her and her husband...More info
218-655-1161 - Fax
Collette VanHove
Collette joined the Reliable family in 2014, bringing with her 25 years of experience in the insurance industry in the Duluth Superior area. Even after years in the business, she says she's never too old to learn something new! ...More info
218-655-1176 - Fax
Kyle Wojtysiak
Kyle grew up in the Duluth area and graduated from Proctor High School in 2005. He went on to achieve his Bachelor of Arts degree in Management as well as a minor in Accounting from the College of St. Scholastica....More info
218-655-1176 - Fax
Micki Wojtysiak
Micki grew up in the Duluth area and graduated from Proctor High School in 2001. She earned her Associates Degree in Medical Administration and spent 12 years as a medical transcriptionist. Using her knowledge in the...More info
218-655-1179 - Fax
Scott Wojtysiak
Scott was born and raised in the Duluth Area and graduated from Proctor High School in 2001. He earned his Bachelor of Science degree in Accounting from the University of Wisconsin-Superior in May of 2005...More info
218-655-1174 - Fax
Certified Insurance Counselor (CIC)
The Society of CIC is a not-for-profit organization dedicated to professional insurance education. The Program provides an in-depth practical approach to education for insurance agents and other insurance practitioners. The CIC Program is designed to meet the practicing insurance professional's need for technical knowledge in all areas of the insurance industry. CIC institutes include: Personal Lines, Commercial Casualty, Commercial Property, Life and Health, and Agency Management. Offered across the United States and its territories throughout the calendar year, each institute consists of two and one-half days of intensive instruction followed by a rigorous essay examination. The successful completion of all five examinations leads to the right to use the designation Certified Insurance Counselor (CIC). CIC's must attend 20 hours of program education each year to maintain their designation.
Certified Insurance Service Representative (CISR)
The Society of CISR is a not-for-profit organization committed to filling the need for quality insurance education and training geared toward customer service representatives. CISR courses stress the understanding and analysis of risks and exposures. CISR courses include: Insuring Personal Auto Exposures, Insuring Personal Residential Property, Insuring Commercial Property, Insuring Commercial Casualty Exposures, and Agency Operations. Offered across the United States and its territories throughout the calendar year, each course is one day of instruction followed by an optional examination. The successful completion of all five examinations leads to the right to use the designation Certified Insurance Service Representative (CISR). CISR's must attend 8 hours of program education each year to maintain their designation.


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The Science Fiction Romance New Releases Never Stop
New releases in science fiction romance, and some good news about one of Veronica Scott's books. Read More »
New releases in science fiction romance, and some good news about one of Veronica Scott's books. Read More »
An overview of a collection of Finnish speculative fiction, focusing on steampunk and fantasy short stories. Read More »
A lot of old ('50s and early '60s) SF was written by women under masculine or masculine-sounding names. One of the best was Andre Norton. Join Steve in a look at this terrific action/adventure SF like they "just don't write anymore!" Read More »
An interview with Carla G. Angelo Paredes, the author of Spanish-language novels for young adults. Read More »
THE WITCH OF ZAL by Kerry Gans is a book of two journeys. One taken by a heroine traveling to a magical land, and one taken by the readers who experience a re-imagined classic. Read More »
Steve reminisces about a writer he used to know. Maybe you know some of the things he's done: meet Jerry Sohl! Read More »
Moonwalk by H. B. Fyfe is science fiction's short story equivalent of Hemingway's classic The Old Man and the Sea, minus all of the fanfare and accolades. Read More »
Jorge Luis Borges and the definition of science fiction. Read More »
Top posts from March Read More »


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The 5th European Health Sciences Innovation Forum 2011 Connect, Collaborate, Cure For Biotechnology, Medical Devices and Pharmaceutical Companies
About The Show
For the fifth consecutive year, Oracle organizes its yearly European Health Sciences Forum, a two day conference to connect with Life Sciences and Healthcare customers and partners from the European community, into one single place.
Explore the completeness now
HCL is a COMPLETE Oracle Life Sciences Solution Provider.
- With references across all sub-verticals such as Pharma, biotech, CROs and medical devices firms.
- Providing solutions across all functional areas - Back office, Front Office, Supply Chain, R&D, Clinical Data Management and Safety.
- With experience in handling Oracle Clinical, Siebel CTMS, Remote Data Capture, Advance Event Reporting System, Argus and other Oracle ERP, SCM and CRM applications.
- With proven capabilities in Consulting, Implementation, Rollouts, Upgrade, AMS, Managed Services, Hosting and BPO .
- Serving large Multinational and mid-market companies across all key geographies.
Explore the COMPLETENESS now. For further inquiries, please email us
Our Presence
HCL is the Platinum sponsor of this event and will be presenting various solutions during the event.
Apart from our presence at the Oracle Pavillion, our Subject Matter Expert Ms. Debbie Cenci. will also be presenting a case study on ' Genzyme Diagnostics Leverages Oracle and HCL Technologies to Eliminate Demand Latency'


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Instead, consider going to one of the number of private recording studios around this city – like the one owned by MC and producer Jabbar, who built a state-of-the-art private studio at home. 'Until I become big enough to spend big money on big-time studios, I can get great quality from my home studio,' he says. But he doesn't just record his own projects, he also hires it out to other bands – so long as they know what they are doing.
'I don't want to record just anyone, I want people to come in who are aware of what they want to achieve, and I won't rob them blind,' he explains. 'They pay Dhs800 for the first four hours and Dhs200 per hour thereafter. It's cheaper than using a big-name studio and the quality is good.' It's worked out well for him, too – he's had bands like Juliana Down at his place, and says that artists enjoy the combination of a personal touch and the lack of studio staff cramping their style.
Alternatively, you could always visit Jabbar (firstname.lastname@example.com) in Al Barsha or, like up-and-coming band Sun King did, Cesspool Studios (firstname.lastname@example.com) on Sheikh Zayed Road. Jaison of Sun King says, 'As well as the home studio being cheaper, the final outcome from Cesspool was quite remarkable. Artists and musicians get more time there to tweak parameters to get the desired results.'
There's still a place for professional studios like Dubai's Creative Kingdom, of course, but there's no need for new bands to pay huge money for global-standard results. But more on that in the New Year.
Zahra showcases the latest local musical talent on Open Mic every Saturday from 8pm-10pm on Dubai Eye 103.8


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News By Tag
* Jakson
* Group
* More Tags...
Industry News
News By Location
Industry News
Jakson Group Rolls out New Range of Solar Powered Products
- Launches Solar Powered Lighting, Indoor RO System, Modules - Attractively priced solar products to light up India's rural areas - Targets Rs.650 crore revenue from solar business by FY 2017
With this launch, the Group is planning to capture a sizeable share of the solar energy market.
Through this initiative, the company intends to focus on rural electrification by providing a reliable and affordable range of solar products supported by large after sales service network. The company has also planned to invest in rural micro grid by conducting feasibility studies in un-electrified remote villages to identify the requirement and business model to provide electricity through solar energy and storage devices.
Jakson will introduce the new range of solar products in a phased manner across the nation. In the first phase, the company is targeting to reach key markets of Bihar, UP, North East and J&K, which will extend to Telangana, Rajasthan and Tamil Nadu in the second phase. As part of its marketing drive, the company is planning to add many new dealers and distributors in these areas to increase the footprint. With the launch of the new range of solar powered products, Jakson is targeting to reach a revenue of Rs. 650 crore from the solar business by FY 2017 compared to Rs. 127 crore in FY 2014.
Speaking on the occasion, Mr. Sameer Gupta, Managing Director, Jakson Group, said "The sub-urban as well as rural India is still deprived of clean drinking water and availability of power. Jakson has developed solutions to address these problems by developing energy efficient and cost effective Solar Water and Solar Home lighting systems. These are sustainable and clean solutions. We are positive about the potential use of these systems especially in remote and rural areas across India, wherein nearly 320 million people still don't have access to power. By undertaking this initiative, Jakson is looking forward to make a fruitful contribution towards the cause of the nation. We are having equal focus on Defence segment where solar solutions for various applications is an answer to the ever growing demand in this segment".
Jakson has a state-of-the-
About Jakson Group (http://www.jakson.com/
Established in 1947, Jakson is one of the leading Power Solutions Group in India today. With 4 companies in its fold, the group has a strong presence in various sectors. The group has more than 2000 employees and its current revenues exceed Rs. 1450 crores per annum with a sales and service network spread across India, Nepal, Bangladesh and Singapore.
The group manages diverse business interests in the areas of Power Generation, Power Distribution, Solar Power, Electrical Contracting, EPC business and now even Hospitality delivering comprehensive services at the market place.
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8 recipes by ナオパーク
- Refreshing Cabbage and Shiso with Mayonnaise and MisoThis combination is the best! Crunchy cabbage with refreshing shiso, tasty mayonnaise and miso! It's easy, and is done in 5 minutes.Cabbage, Shiso leaves, Mayonnaise, Miso, Sugar, Sesame paste (or ground sesame), White sesame seeds
- Kinako Cookies for DietersI recommend these for when you're on a diet! They are egg-, butter-, and oil-free, crunchy kinako cookies.Kinako, Flour, Katakuriko, Sugar, Milk
- Chilled Creamy Pasta with Soy MilkThis is great for summer! The flavor of garlic and soy milk is delightful.Spaghetti (Capellini if possible), Lettuce, Cherry tomatoes, Boiled clams, Soy milk, Somen noodle sauce (diluted 3x the volume), Grated garlic
- Rich Simmered Chicken Wing Drumettes, Daikon Radish and EggsSlow cooked tender wing drumettes and daikon radish are rich-tasting and delicious! And you can't make this dish without eggs!Chicken wing drumettes - the large end of the wing, Daikon radish, Eggs, Green beans, Garlic, Ginger, Green onion or scallion
- Muffins with Sautéed ApplesThis is a filled with sweet and tart apples sautéed with margarine! The batter is also fluffy! These muffins will make you happy from one bite!Margarine, Cake flour, Sugar, Egg, Baking powder, Milk
- Sweet, Salty and Delicious! Stir-Fried Marmalade Chicken DrumettesChildren and adults love this sweet-salty flavor! The marmalade adds a little sweet-sourness too! These are beautiful chicken drumettes with a nice shiny finish!Chicken wing drumettes - the large end of the wing, Lotus root (if you have some), Cake flour, Marmalade, Soy sauce, Sake, Salt
- Croquettes Full of Mushrooms and Sweet PotatoesAutumn-coloured croquettes packed with seasonal ingredients. They're fluffy and delicious, especially with the great texture of mushrooms.Sweet potato, Shimeji mushrooms, Shiitake mushroom, Maitake mushrooms, Onion, Sake, Soy sauce
- Nutritious Matcha and Sweet Black Bean Tofu CakeA cake that uses tofu, but no butter. It's moist and tasty. A delightful addition of matcha and sweet black beans.Tofu (Silken), Cake flour, Sugar, Egg, Baking powder, Matcha, Sweet black beans (cooked)


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Wool Gingham Slouch Trouser
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What the retailer says
Woven from a virgin wool and silk blend with a viscose twill lining, these tailored trousers feature gingham detailing and have a contemporary, wide silhouette. Design features include pressed creases through the leg, front slant pockets and an asymmetric welt pocket with a corozo button on the back. Invest in these trousers for your workwear wardrobe.


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157,161Added 4 years ago
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one of my all time fav scenes..2 years ago0Reply
- Anonymous
her body is perfection2 years ago0Reply
- Anonymous
damn, I love watching her chew on this big black pole..when he is pounding her from behind on the couch it almost makes me pop every time..I try and hold it until that beautiful facial at the end..!2 years ago0Reply
- Anonymous
My wife has AIDS and still looks sexy.2 years ago0Reply
- Anonymous
is this girl crazy this bastard has AIDS2 years ago0Reply
- Anonymous
me, again..!! still in luv..!! pop..!!!!2 years ago0Reply
- Anonymous
لقد ناكها في طيزها و لا حول و لا قوة إلا بالله.2 years ago0Reply
- Anonymous
...me, again..pop..!!!!!!!!!...3 years ago0Reply
- Anonymous
i watch this scene almost daily...classssssssic..her body is perfection...3 years ago0Reply
- Anonymous
I luv you, Maggie..i agree with earlier comment - she's fine..but she looks even better with that thick black cock in her face/ass..i would sell my soul to the devil if I could put my tongue in her ass..sweet cumshot..3 years ago0Reply


text:
On the defensive line rotation:
The coaches are doing their jobs.
On his music career off the field:
It's doing good. I'm making my music and having fun with it but as soon as camp started I put my music away and it was time to focus only on football.
On how tough it was to put music aside:
It's easy for me but I signed a Letter of Intent with the school to play football so I gotta do that first.
On the tradition of great DL here:
It's real motivating. I always talk to one of the greatest, Warren Sapp. I talk to him about what motivated him to come out here and it helped me to have a better mindset on the field. He says just be relentless. He was relentless in everything he did. Punt block, everything. That's what I gotta do.
On his personality:
I say I have a dominant personality on the field. I feel comfortable out here. I'm sorta quiet off the field though.
On the younger defensive ends:
I wouldn't say they're behind me because we don't have a starting lineup. We are all rotating. The whole D-Line is doing good. We are much better than last season and now we just gotta see how we do in a game.


text:
Metrics-Based Assessments of Research: Incentives for 'Institutional Plagiarism'?
- First Online:
- Received:
- Accepted:
DOI: 10.1007/s11948-012-9352-0
- Cite this article as:
- Berry, C. Sci Eng Ethics (2013) 19: 337. doi:10.1007/s11948-012-9352-0
- Citations
- 201 Downloads
The issue of plagiarism—claiming credit for work that is not one's own, rightly, continues to cause concern in the academic community. An analysis is presented that shows the effects that may arise from metrics-based assessments of research, when credit for an author's outputs (chiefly publications) is given to an institution that did not support the research but which subsequently employs the author. The incentives for what is termed here "institutional plagiarism" are demonstrated with reference to the UK Research Assessment Exercise in which submitting units of assessment are shown in some instances to derive around twice the credit for papers produced elsewhere by new recruits, compared to papers produced 'in-house'.


text:
Around the State: Disaster relief in Louisiana; disaster recovery in Houston
- September 14, 2016
- By Staff / Baptist Standard
Texas Baptist Men continue disaster relief in Louisiana. Disaster recovery volunteers needed in the Houston area.
Around the State: HPU opens center in New Braunfels; ETBU hosts hymn sing
- September 7, 2016
- By Staff / Baptist Standard
Howard Payne University will mark the grand opening of its New Braunfels location. The sixth annual Great East Texas Hymn Sing will be held on the East Texas Baptist University campus.
Around the State: New DBU and HPU students join in SWAT and SWARM
- August 31, 2016
- By Staff / Baptist Standard
New students participate in SWAT at Dallas Baptist University and SWARM at Howard Payne University. Houston Baptist University and the Robert and Janice McNair Foundation establish the $5 million McNair Center for Entrepreneurship and Free Enterprise.
Around the State: WMU seeks to honor Wisdom-Martin; Wayland religion faculty; HPU collaborates
- August 24, 2016
- By Staff / Baptist Standard
WMU of Texas wants to honor of Texas' Sandy Wisdom-Martin, executive director-elect of national WMU, by reaching endowment goal. Wayland adds faculty to its School of Religion and Philosophy. Howard Payne collaborates on nursing degrees.
Around the State: Volunteers needed in Houston area
- August 10, 2016
- By Staff / Baptist Standard
Texas Baptists' Disaster Recovery program and Texas Baptist Men are mobilizing volunteers to repair flood-damaged homes in the greater Houston area Aug. 25-27, Sept. 29-Oct. 1 and Oct. 27-29.
Around the State: San Antonio church fights hunger; children enjoy 'brain games' at HPU
- August 3, 2016
- By Staff / Baptist Standard
San Antonio church recognized for hunger-fighting ministry. Children enjoy "brain games" at camps on the Howard Payne University campus.
Around the State: Bounce at work in Waco
- July 27, 2016
- By Staff / Baptist Standard
Bounce teams work in Waco. Jason Bryant named Texas Baptist western-heritage consultant. Dallas Baptist University plans Patriot Previews.
Around the State: DBU doctoral students visit Oxford; BUA schedules grand opening
- July 20, 2016
- By Staff / Baptist Standard
Dallas Baptist University sent 15 doctoral students to Oxford, England. The grand opening for Baptist University of the Américas' Baugh Building is scheduled.
Around the State: DBU recognizes servant leaders; Sadler moves to new role at Wayland
- July 13, 2016
- By Staff / Baptist Standard
Dallas Baptist University awarded the Frank and Martin Moore Servant Leader Award to two students. Paul Sadler accepts a new post as director of church and denominational relations at Wayland Baptist University.
Around the State: Super Summer under way; Baylor adds to provost's office
- July 6, 2016
- By Ken Camp
Seven Super Summer schools of Christian leadership are under way at six Texas Baptist schools. Baylor University named three individuals to leadership posts in the provost's office. Howard Payne University appointed a new dean.
Around the State: Baylor Campus Kitchen awarded; Students build in Bartlesville
- June 28, 2016
- By Staff / Baptist Standard
Baylor University's Campus Kitchen received national recognition. Ninety students volunteered with Texas Baptists' Bounce program to rehabilitate homes in Bartlesville, Okla., for families in need.
Around the State: DBU students go to Washington; TBM volunteers prepare 96,000 meals
- June 22, 2016
- By Staff / Baptist Standard
DBU student group attends 21st Century Wilberforce Initiative's Emerging Leaders Conference in Washington, D.C. TBM volunteers prepare 96,000 meals and distribute 4,000 boxes.
Around the State: Senior adults attend Hilltop University at ETBU; TBM continues disaster relief
- June 15, 2016
- By Staff / Baptist Standard
More than 270 senior adults participated in Hilltop University on the East Texas Baptist University campus. Texas Baptist Men disaster relief volunteers prepare more than 75,000 meals—and counting—in Conroe and Rosenberg.
Around the State: Legacy Awards; Women's conference at Jefferson
- June 8, 2016
- By Staff / Baptist Standard
Author Angela Thomas will headline a women's conference in Jefferson. Wilshire Baptist in Dallas marked the 50th anniversary of its sanctuary dedication.
Around the State: TBM wraps up disaster relief in Hawkins; HSU presents awards
- June 1, 2016
- By Staff / Baptist Standard
Texas Baptist Men devote 792 volunteer days to disaster relief in Hawkins. Hardin-Simmons University presents Christian service awards. BGCT Executive Board recognizes graduates of Leadership Texas Baptists program.


text:
Can you sleep in a dream?
'I dont know...' i replied whispering, moving my eyes around the room in fear. 'why are you so calm? who are you? where am i?'
'erhmm, im in a dream Ella. This is surely a dream.' Kate laughed. 'I'm Kate and i dont know why your in my dream.'
'your funny. real funny. Wheres the little baby?' I Yelled and ran out of the building, out of the double marble doors.
'MY RESERVATION?!' I heard Kate Yell back. I ran out and in desperation fell to the ground. Which was infact sand. i was still on this island jungle place. I ran to the rocks near the shore and looked around, to the sky. The giant was no where to be seen. that terrible monster. What next Mermaids?!
'Its not normal i know.' Someone spoke to me behind.


text: "For Yili, the Olympics are about more than just the competition between athletes," said Li Dan, executive director of corporate marketing at Yili. "They're a reminder of how important health and nutrition are for everyone, whether they're on the racing track in London or on a basketball court in Beijing. Yili's mission is to help our customers lead happy, healthy lives, and with 'Ordinary Olympians' we're proud and privileged to be highlighting people doing exactly that."Youku accepted original viewer uploads until June 30, after which it reviewed the user-contributed videos and selected representative viewers as subjects for a second line of micro-movies telling their stories. The final episode of "Ordinary Olympians," will air later this July. The subjects of the micro-movies will be featured as in print ads on 300 London double-decker buses during the Games. About Youku Youku Inc. is China's leading Internet television company. Our Internet television platform enables users to search, view and share high-quality video content quickly and easily across multiple devices. Youku, which stands for "what's best and what's cool" in Chinese, is the most recognized online video brand in China. Youku's American depositary shares, each representing 18 of our Class A ordinary shares, are traded on NYSE under the symbol "YOKU." For more information, please contact: Media Relations: Jean ShaoDirector, International CommunicationsYouku Inc.Tel: +86-10-5885-1881 x7128Email: email@example.com Investor Relations: Ryan CheungCorporate Finance DirectorYouku Inc.Tel: +86-10-5885-1881 x6090Email: firstname.lastname@example.com SOURCE Youku Inc.


text:
Name: Domain Affiliate Engine
Website: www.domainaffiliateengine.com
Owner/Creator: Jamie Garside and David Chamberlain
Price: $37
Rank: Legit – 83/100
What Is Domain Affiliate Engine?
This is a very new product recently developed by Jamie Garside and David Chamberlain that works as a WordPress plugin. It is therefore, a software meant for affiliate marketers to turn any one of their websites into an actual Domain Checker. Upon first sight, my feeling was there was really nothing Domain Affiliate Engine could help or benefit me.
Upon further investigation, Domain Affiliate Engine had proved to be much more unique in nature and could prove useful to the millions of worldwide affiliate marketers out there, especially those who focus on blogging, content creation, and attaining traffic.
How Domain Affiliate Engine Works?
After purchasing a copy of Domain Affiliate Engine, you will have a license to the WordPress Plugin, which will enable you to use the unique software for your everyday visitors and traffic.
This can easily boost your personal reputation and credibility as a marketer by giving your visitors a tool that could be very helpful in their ability to search out and find a new domain name to register.
Problems With Domain Affiliate Engine?
The only problems I've ran in with Domain Affiliate Engine include:
#1 – Really slowing down your websites loading time. Because the plugin will take up and consume a lot of space and memory on your hosting server, you may want to look into purchase an extra dedicated server, to help speed things up.
#2 – In addition, while the product does make a few over-exaggerated claims, its not so bad! For example, Domain Affiliate Engine is definitely not a type of plugin I'd want to be using on say a gaming niche website, or anything along those lines. In order to really benefit from Domain Affiliate Engine, you'll really want to have a specific niche, where your audience will already have a potential interest in seeking out and purchasing a domain. Otherwise, you're likely to find it pointless.
#3 – The last problem I've found, concerns with the actual home page and what's being stated.. For example, Domain Affiliate Engine claims you only need 30 daily visitors to make a great income with it. In my opinion, you'll need well above that.
In addition, the owners behind the software claim you can profit from the product without any blogging, content creation, or even any traffic. I've found this to be way too much of an over-exaggeration.
Just because you have a unique and cool plugin on your website doesn't mean much without the proper and right amount of targeted traffic, other content, and simple overall engagement!
Without traffic, you really have nothing, making it all the more important to work on content creation, building long-term trust with your targeted audience and traffic.
What I Like About Domain Affiliate Engine?
#1 – The price tag is fairly low, at only $37.00. In addition, I really like the guarantees which are made right on the homepage, and because it's being offered by JVzoo is a 60 day guarantee which you can count on!
#2 – It is a legitimate wordpress plugin that can truly help leverage your daily income.
However, it is important your niche is targeted enough to the right audience and people, otherwise you may not see many sales come your way.
#3 – Lastly, what I love most is the actual plugin itself! Your ability to simply enter in your affiliate ID into each one of the 7 domain registrars is something I find very cool and unique, allowing your audience to really browse and compare through the various pricing.
In addition, your ability to build up a list of e-mails and consumers makes list building look like a breeze; a very cool add-on, which though didn't seem necessary for the owners to add at first is nice.
Domain Affiliate Engine Overview
To conclude, this is one product I could feel good recommending to others. I believe with the right niche, audience, and traffic, is something that could be used to build up a nice secondary income from just your blog alone!
It is definitely unique and seems to have some great benefits and the purpose of it is an ingenious idea.
With plenty of affiliate marketers offering the same old Go Daddy or Name Cheap reviews and affiliate links, Domain Affiliate Engine does a great job at taking the "bait" here, by offering a plugin that is cheap, unique, and specific to affiliate looking to make a nice hefty commission.
The use of adding seven various search engines therefore, makes this a worthwhile tool, not to mention the list building services alone, which will truly only work to boost your income in the long-term!
Interested In Affiliate Marketing?
Have you had a unique interest in affiliate marketing.. Well I'm not surprised! It is truly one of the highest paying occupations out there today, and would be dumb to miss out on.
Nevertheless, like most things in life, we can have a hard time getting started by ourselves without any proper sense of direction.
So check out this #1 affiliate marketing recommendation. Do me one favor, check it out and if you have any questions, comments, or concerns feel free to leave them below.
Thank you for reading.


text:
- Home Article - Antioxidants anti-truths
Free Shipping On Orders Over $100
Australian National Champion Powerlifter, in consultation with Trent Watson, sports dietitian and CEO at Ethos Health Pty Ltd.
The attitude of athletes to supplements and 'superfoods' is often the same as The X-Files catchphrase – "I want to believe".
Take antioxidants (or rather, maybe you shouldn't) – despite their initial promise, mounting evidence from large scientific studies is showing they don't always live up to the hype when it comes to delivering health benefits. In fact, many studies show that taking antioxidant supplements could even do more harm than good. Trent Watson picks his way through the confusion.
TRENT WATSON is a sports dietitian and CEO at Ethos Health Pty Ltd. His doctoral studies investigated the role of antioxidants in exercise performance. He has presented on this topic to national health and sports organisations.
It's pretty naïve to think that we can concentrate antioxidants into supplementation and provide a better mix than what nature has evolved over millions of years. My research found that fruit and veg – and food in general – is a far superior method of delivery of antioxidants to athletes. In fact, some of the supplement trials for my research, which had athletes exercising to exhaustion, showed that the antioxidants had adverse effects to the oxidative stress created in that athlete.
In the first trial, we took all their fruit and veg away and we found that their oxidative stress increased during their sub-maximal and exhaustive exercise – that was as we expected. In the next trial we gave that same group with an antioxidant supplement. We found that the antioxidant supplement group had an elevated level of oxidative stress compared to a group who were eating fruit and veg. This wasn't the first trial to report such outcomes.
Antioxidants don't work in isolation, they work in cascading metabolic pathways. For instance, Vitamin E acts against oxidants (free radicals), but in the process of doing this, [the Vitamin E] itself becomes an oxidant. So Vitamin E then has its oxidative effect reduced by, say, vitamin C, then the oxidative effect of the Vitamin C is reduced by glutathione, so there's this cascading effect. This is how antioxidants work in combination. It seems and that whole foods – the stuff that we've evolved on – provides the best quantities and combinations of those antioxidants to control or mitigate against the oxidative stress induced by exercise.
The enzymatic antioxidants that are made in our body – called endogenous antioxidants – are upregulated by exercise. That is, our body increases its capacity for antioxidants without any of the antioxidants we consume, then the antioxidants we consume top up our internal antioxidant system.
There is a chance that exercise may overwhelm our intrinsic antioxidant system. That's where an athlete benefits from having a diet high in antioxidants. But will an athlete get sufficient antioxidants from their diet? It seems as though the answer is yes. Athletes tend to consume more food than someone who's sedentary because they have a higher energy demand. When they meet that high food intake, particularly if their diet is based around whole foods that are high in antioxidants, then they'll meet their antioxidant requirements quite easily – enough to control against the oxidative stress induced by exercise.
This is not necessarily the case. Supplements provide benefits when they correct a nutritional deficiency, but if you're having a nutritionally adequate diet and then you want to supplement over and above this, the evidence is growing to say that this could have a detrimental effect rather than a beneficial effect.
For instance, there was a landmark trial that demonstrated that beta-carotene supplementation actually increased the risk of lung cancer. There are other trails with Vitamin E – and these compounds are largely thought to be harmless – but when the supplementation of vitamin E got to a certain point, it started to increase the risk of cardiovascular disease.
So if you insist on using a supplement, choose the broadest spectrum supplement you can find and have it in a low dose so you have more chance of filling in gaps where there might be a nutritional deficiency.
The whole concept of superfoods really aggravates me. It's more about marketing a food than any benefit it will provide. Red wine has antioxidants. Does that make it a superfood? The fact is that if you're relying on red wine or dark chocolate to get your antioxidants, you're going to be in serious trouble. Any one particular food has deficiencies in certain nutrients. You need balance – no single food is going to make someone's diet "super".
Get as broad a spectrum of food as you can within the five core food groups and choose those that are produced with the least amount of human intervention. Choose wholegrain breads and cereals, fruit and veg, lean meats or meat alternatives, and dairy products. If the majority of your diet is based around these – and the full spectrum of these food groups – then you can almost guarantee that you'll meet your dietary requirements.
Our immune system is based around oxidation – it's a necessary part of living and recovery. If you treat yourself with too many antioxidants, does that then reduce our body's immune response to correct injury or infection or dispose of damaged tissue? This is a hot topic of discussion when it comes to cancer. However, if there's an insufficiency in any of the antioxidants, then we're not going to be as healthy as we could be, so this compromises our immune response to any situation. But if it's adequate, we should be able to optimise our response to inflammation or acute injury.


text:
Meet the Celebrated Chef Who Cooks Secret Marijuana Dinners to Promote Pot Culture
"The strain is the star, and I want to make it shine in the dishes I create."By Melissa Malamut
"The strain is the star, and I want to make it shine in the dishes I create."By Melissa Malamut
It seems New Yorkers are finally ready for this food, which has long languished in the shadow of Thai, Indian, Chinese, and other Asian standbys.By Mary Jane Weedman
Plus: the first annual SMOKE@ICC barbecue competition, and more, in today's Leftovers.
Plus: a new app that lets you share leftovers with strangers, and more, in today's Leftovers.
A rep from the restaurant says they hope to be reinspected ASAP.By Hugh Merwin
Josh Ozersky samples the Filipino delicacy, so you don't have to.By Jenny Miller
Parents have to cope somehow.By Jenny Miller
Plus: Sifton enjoys Tertulia, "Tables for Two" on Earls Beer & Cheese, and more of this week's reviews.By Bianca Male
And Sa Aming Nayon got its first critical review.By Jenny Miller
The Filipino pop-up lands in the East Village once again, with dinner.By Jenny Miller
The Filipino pop-up finds a new home.By Daniel Maurer
Resto Leon has decided to reclaim the space for a brunch of its own.By Jenny Miller
And speaking of markets, the Food Truck Bazaar at Hell's Kitchen Flea Market is going monthly.By Jenny Miller
Filipino pop-up Maharlika will be serving the embryonic duck eggs this weekend until they run out.By Jenny Miller
Another temporary restaurant pops up below 14th Street.By Jenny Miller


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Idina, who was the voice of Elsa in the Oscar-nominated Disney film, says her ice queen character might be returning to the big screen.
This isn't a confirmation of Frozen's return, but Menzel suggested it's on the way in a recent interview with The Telegraph.
When asked about what she could say about rumours of a stage musical and a sequel, she responded: 'That they're all in the works.'
She added that she's not sure if she'll be involved in the stage show, but hopes to be back for Frozen 2.
It's already been announced that Frozen will be making a return of sorts in the form of a short called Frozen Fever.
Frozen was hugely popular when it was released last year with the song Let It Go, sung by Idina, sparking a series of spoofs and cover versions.
Film: Frozen (2013).
It was nominated for best film at the 2014 Oscars which saw John Travolta refer to Idina as 'Adele Dazeem' in a hilarious on-air gaffe.
Frozen won oscars for best animated film and best original song for Let It Go.


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Oh, k-pop never ceases to amaze me. Check 2NE1. Have you seen the latest videos by those girls? Have you seen them rocking the new Jeremy Scott collection for Adidas? So join us in this colorful world of tiny little girls with big eyes and heavy use of auto-tune.
The first video was released back on June 27 and already has more than 7 million views. The expensive looking clip features the girls wearing spiked Louboutins, Cassete Playa looks that would make M.I.A. jealous, cool ass Misfits jackets and features a massive diamond made of glass plus any number of luxurious excess-ory you could think of to use on a song called 'I Am The Best'.
In a way, it's like a girl power answer to GD & Top's 'ë»'ěť´ę°€ěš" (KNOCK OUT)', but the song is much more like 2011 electro for radio with a hint of '90s pop in the vocal line. It's a bit annoying but all highly addictive songs are, right?
'Hate You' has a much more interesting structure: the instrumental is a bit french new wave and the vocals are cute; it could be a really bad ballad in the hands of other producers. The video, which managed to get over 700k views in less than 24 hours, is pretty much an Anime version of 'Sucker Punch', but not as bad as the movie was. Probably my favorite 2NE1 track ever.
And here are the girls modeling for Korean magazine, 1st Look in Jeremy Scott for Adidas Originals Collection. As usual, sporty looks (it's Adidas after all) with really bright colors, lots of animal prints and random teddy-bear accessories. Some cool over-the-top stuff in there, but I suspect that you might need to be a k-pop star to fully appreciate and wear the whole collection at once. Check the gallery below with all the looks from the mag and see you in the next k-pop update!


text:
North American Dealer Co-Op v. Rottman, 2012 WL 2789663 (D.Nev., Slip Copy, July 9, 2012).
United States District Court, D. Nevada.
NORTH AMERICAN DEALER CO–OP, Plaintiff,
Dick L. ROTTMAN et al., Defendants.
No. 3:11–cv–698–RCJ–VPC.
July 9, 2012.
Wayne O. Klomp, Justin J. Bustos, Brian R. Irvine, Gordon Silver, Reno, NV, for Plaintiff.
James Robert Smith, Richard L. Elmore, Tamara Reid, Holland & Hart LLP, Reno, NV, for Defendants.
ROBERT C. JONES, District Judge.
*1 Currently before the Court are a Motion for Order to Show Cause Why Prejudgment Writ of Attachment Should Not Issue (# 16) and a Motion to Dismiss First Amended Complaint (# 24). The Court heard oral argument on March 26, 2012.
In September 2011, Plaintiff North American Dealer Co-op ("Plaintiff") filed a complaint in this Court. (Compl.(# 1) at 1). On December 1, 2011, Plaintiff filed its First Amended Complaint ("FAC") against Defendants Dick L. Rottman, Jeffrey P. Shaffer, Janice Lynn Bowman, Carol B. Ingalls, Bradley A. Pearce, R. Scott Rottman (collectively "Individual Defendants"), A and H Insurance, Inc., and Western Thrift & Loan (collectively "Defendants"). (FAC (# 22) at 1).
The complaint alleged the following. Plaintiff was a cooperative association consisting of automobile dealers located in the United States. ( Id. at 3). Plaintiff offered member dealers an extended service contract reimbursement program ("the Program"), which helped facilitate the sales of extended service contracts by member dealers to their customers who purchased new or used automobiles. ( Id.). Plaintiff entered into an agreement with Western Insurance Company ("WIC"), then a Nevada insurance company, to provide a surety bond to Plaintiff and its member dealers guaranteeing the payment of any money back reimbursements due under the Program. ( Id. at 3–4). WIC agreed to administer and control a member dealer collateral reserve account in which member dealers paid "reserves" to cover anticipated reimbursement claims arising under the Program. ( Id. at 4). As part of the Program, member dealers set aside a "reserve" for each extended service contract which was provided with a money back guarantee. ( Id.). The reserve was intended to pay all future reimbursement claims that could be made against the member dealer. ( Id.).
The complaint alleged the following. Plaintiff, through its administrator, the National Administrator Dealer Services, Inc. ("NADS"), provided administrative services to dealer members in the Program, including maintaining necessary records, verifying valid claims, and submitting approved claims to WIC for payment. ( Id.). WIC administered and controlled the reserves on behalf of Plaintiff and its member dealers. ( Id.). WIC set the reserve amount payable for each money back guarantee issued and held the reserves in a fiduciary capacity in a "collateral reserve fund" for Plaintiff and its member dealers. ( Id.). To protect against the possibility that the member dealers' own reserves in the collateral reserve fund might be insufficient to pay all claims made against the outstanding money back guarantees, Plaintiff's member dealers were protected by a surety bond issued by WIC. ( Id.). The surety bond was intended to pay all valid outstanding reimbursement claims in the event that the collateral reserve fund became depleted. ( Id.). On April 1, 2004, WIC and Plaintiff entered into a contract called the Vehicle Contract Reimbursement Guarantee Performance Contract ("the WIC Bond"). ( Id.). The WIC Bond was a surety bond issued to Plaintiff and its member dealers. ( Id.).
*2 The complaint alleged the following. Access Insurance Services, Inc. ("Access") served as the managing general agent for WIC. ( Id. at 5). Access was responsible for WIC's performance under the surety bond and was required to manage, administer, and protect the collateral reserve account created pursuant to the surety bond. ( Id.). Pursuant to the WIC Bond, member dealers deposited $60 into the collateral reserve account per contract sold with a money back guarantee, as set by WIC. ( Id.). WIC would periodically adjust the collateral reserve amount through written notice to Plaintiff. ( Id.). The collateral reserve account was closely monitored by WIC and Access to ensure that it was adequately funded. ( Id. at 6). Plaintiff collected reserve funds from its member dealers and forwarded the funds to WIC or Access pursuant to the WIC Bond. ( Id.). The reserves were then retained by WIC or Access in the collateral reserve account. ( Id.). The collateral reserve account was segregated in investment and accounting records by Access and the funds held in the collateral reserve account were not available to other creditors even if WIC had filed bankruptcy. ( Id.). Neither Plaintiff nor NADS had control over or access to the funds retained in the collateral reserve account. ( Id.).
The complaint alleged the following. Member dealers submitted reimbursement claims under the money back guarantee to NADS. ( Id.). NADS investigated each claim for compliance with the Program and forwarded approved and valid claims to WIC for payment out of the collateral reserve account. ( Id. at 7). WIC or Access would pay the approved claims out of the collateral reserve account. ( Id.). Since April 1, 2004, member dealers have paid $17,000,000 in reserves to WIC to deposit into the collateral reserve account. ( Id. at 6). Since April 1, 2004, $9,000,000 have been paid out of the collateral reserve account in payment of reimbursement claims approved by NADS and submitted to WIC for payment. ( Id. at 7). As of December 2011, the collateral reserve account should have had a balance of $8,250,000. ( Id.).
The complaint alleged the following. On December 23, 2010, WIC dissolved its corporate existence in Nevada effective December 31, 2010, without notice to Plaintiff or NADS. ( Id.). Since the date of dissolution, neither WIC nor Access have provided any formal notice to Plaintiff or NADS about the current status of the collateral reserve account. ( Id.). Beginning in May 2011, WIC failed to pay out the approved reimbursement claims from the collateral reserve account. ( Id.). Pursuant to the WIC Bond, WIC was required to make reimbursement payments out of the collateral reserve account within 30 days of receiving approved claims. ( Id. at 8). Plaintiff and NADS have submitted over 921 claims to WIC. ( Id.).
Of those claims, 552 have been submitted to WIC for more than 30 days and remain unpaid in the amount of $956,485.69. ( Id.). The remaining 369 claims that remain unpaid have a value of $611,493.14. ( Id.). Plaintiff has written several demand letters to WIC and Access that they immediately pay all outstanding reimbursement claims. ( Id.). Plaintiff wrote a demand letter to WIC and Access to confirm in writing that the collateral reserve account was a separate account held in a fiduciary capacity solely for the benefit of Plaintiff and its member dealers and that WIC and Access have never used any of the funds for any purpose other than to make claim reimbursements for the Program. ( Id. at 8–9). WIC and Access have failed to respond to the demand letter. ( Id. at 9).
*3 The complaint alleged the following. On July 1, 2011, the United States Treasury Department delisted WIC preventing it from writing bonds for federal construction projects. ( Id.). On July 13, 2011, a financial rating company downgraded WIC's financial strength from B to B. ( Id.). On August 18, 2011, the Utah Department of Insurance, the government entity that now regulated WIC, commenced an investigation into WIC's solvency. ( Id. at 10). The Utah Department of Insurance found that WIC was insolvent and took over its operations. ( Id.). On September 1, 2011, Access filed for Chapter 11 bankruptcy in Reno, Nevada. ( Id.).
The complaint alleged the following. Individual Defendants were shareholders, directors, and/or officers of both WIC and Access. ( Id.). Individual Defendants "misappropriated, or allowed the misappropriation of, funds from the collateral reserve account" and "wrongfully commingled the collateral reserve funds with other funds." ( Id.). Individual Defendants illegally took the funds held in a fiduciary capacity in the collateral reserve account and misappropriated the funds for themselves or the other organizations that they owned and controlled. ( Id.). Individual Defendants illegally misappropriated funds from the collateral reserve account and transferred them to Defendant A and H Insurance, Inc. ("A & H") and Defendant Western Thrift & Loan ("Western Thrift"). ( Id. at 10–11). Individual Defendants were officers, directors, shareholders, and/or owners of both A & H and Western Thrift. ( Id. at 11). WIC and Access were used by Individual Defendants as a pass-through shell for each Individual Defendant's individual benefit. ( Id.). WIC and Access were inseparable from Individual Defendants because of the unity of interest and ownership. ( Id.). Individual Defendants governed and influenced WIC and Access and undercapitalized those entities. ( Id.). Individual Defendants were alter egos of WIC and Access and separate corporate existence of WIC and Access should be disregarded and Individual Defendants should be "adjudged jointly and severally liable." ( Id.).
Plaintiff alleged eight causes of action. In the first cause of action, Plaintiff alleged breach of fiduciary duty against Individual Defendants. ( Id. at 12). Plaintiff alleged that Individual Defendants owed Plaintiff and its member dealers a fiduciary duty with respect to the collateral reserve account. ( Id.). Individual Defendants "intentionally failed to act in good faith and solely for the benefit" of Plaintiff and its member dealers and breached their fiduciary duties by failing to properly maintain, administer and protect the reserve account by misappropriating funds. ( Id.).
In the second cause of action, Plaintiff alleged conversion against Individual Defendants. ( Id. at 13). Individual Defendants "converted and misappropriated funds in the collateral reserve account, taking such funds for the Individual Defendants' personal benefit without the knowledge or consent" of Plaintiff. ( Id.). Individual Defendants converted the funds because they directed WIC and Access not to release funds from the collateral reserve account upon presentation of the approved reimbursement claims. ( Id.).
*4 In the third cause of action, Plaintiff alleged embezzlement pursuant to NRS sec. 683A.400 against Defendants Dick Rottman and Jeffrey P. Shaffer. ( Id. at 14). Plaintiff alleged that Rottman and Shaffer were responsible for the protection of the collateral reserve funds and maintained exclusive control over those funds for WIC and Access. ( Id.). Rottman and Shaffer misappropriated funds from the collateral reserve account and used the funds to continue running WIC and Access and other entities controlled by Individual Defendants for the direct benefit of Rottman and Shaffer. ( Id. at 15).
In the fourth cause of action, Plaintiff alleged fraudulent transfers against all Defendants. ( Id. at 16). Plaintiff was a creditor of WIC and Access. ( Id.). Individual Defendants made unauthorized transfers out of the collateral reserve account with actual intent to hinder, delay, or defraud Plaintiff. ( Id.). WIC and Access were insolvent at the time the Individual Defendants made unauthorized transfers out of the collateral reserve account or they became insolvent as a result of such transfers. ( Id.). Any unauthorized diversions from the collateral reserve account were actively concealed by Individual Defendants with actual intent to defraud Plaintiff and its member dealers. ( Id.). Individual Defendants made unauthorized diversions because WIC and Access did not have adequate working capital and were in financial distress. ( Id.).
In the fifth cause of action, Plaintiff alleged fraud against the Individual Defendants. ( Id. at 17). Individual Defendants "fraudulently misrepresented" that the funds that Plaintiff and its member dealers had paid to WIC were going to be held in a collateral reserve trust account in a fiduciary capacity for Plaintiff. ( Id.). Plaintiff relied on Individual Defendants' representations in deciding to contract with WIC and, but for those representations, Plaintiff would not have contracted with WIC. ( Id .).
In the sixth cause of action, Plaintiff alleged constructive trust against all Defendants. ( Id. at 18). Plaintiff was the rightful owner of any funds held in the collateral reserve account or any funds improperly transferred out of that account to other entities owned by Individual Defendants, including A & H and Western Thrift. ( Id.).
In the seventh cause of action, Plaintiff alleged negligent misrepresentation against Individual Defendants. ( Id.). Individual Defendants communicated to Plaintiff that the collateral reserve account was fully segregated from other accounts and was fully funded. ( Id. at 19). Individual Defendants failed to exercise reasonable care or competence in obtaining or communicating the information to Plaintiff regarding the status and disposition of the collateral reserve fund. ( Id.).
In the eighth cause of action, Plaintiff alleged civil conspiracy against Individual Defendants. ( Id.). Individual Defendants acted in concert to convert funds held in the collateral reserve account. ( Id.). Plaintiff sought damages for all misappropriated funds from the collateral reserve, direct and incidental damages, punitive damages, constructive trust, and attorneys' fees and costs. ( Id. at 20).
*5 When considering a Rule 12(b)(6) motion to dismiss for failure to state a claim, the court must accept as true all factual allegations in the complaint as well as all reasonable inferences that may be drawn from such allegations. LSO, Ltd. v. Stroh, 205 F.3d 1146, 1150 n.2 (9th Cir.2000). Such allegations must be construed in the light most favorable to the nonmoving party. Shwarz v. United States, 234 F.3d 428, 435 (9th Cir.2000). In general, the court should only look to the contents of the complaint during its review of a Rule 12(b)(6) motion to dismiss. However, the court may consider documents attached to the complaint or referred to in the complaint whose authenticity no party questions. Id.; see Durning v. First Boston Corp., 815 F.2d 1265, 1267 (9th Cir.1987).
The analysis and purpose of a Rule 12(b)(6) motion to dismiss for failure to state a claim is to test the legal sufficiency of a complaint. Navarro v. Block, 250 F.3d 729, 732 (9th Cir.2001). The issue is not whether a plaintiff will ultimately prevail but whether the claimant is entitled to offer evidence to support the claims. Gilligan v. Jamco Dev. Corp., 108 F.3d 246, 249 (9th Cir.1997) (quotations omitted). To avoid a Rule 12(b)(6) dismissal, a complaint does not need detailed factual allegations; rather, it must plead "enough facts to state a claim to relief that is plausible on its face." Clemens v. Daimler Chrysler Corp., 534 F.3d 1017, 1022 (9th Cir.2008) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555, 127 S.Ct. 1955, 1964, 167 L.Ed.2d 929 (2007)); Ashcroft v. Iqbal, 556 U.S. 662, 678, 129 S.Ct. 1937, 1949, 173 L.Ed.2d 868 (2009) (stating that a "claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged"). Even though a complaint does not need "detailed factual allegations" to pass muster under 12(b)(6) consideration, the factual allegations "must be enough to raise a right to relief above the speculative level ... on the assumption that all the allegations in the complaint are true (even if doubtful in fact)." Twombly, 550 U.S. at 555, 127 S.Ct. at 1965. "A pleading that offers 'labels and conclusions' or 'a formulaic recitation of the elements of a cause of action will not do." Iqbal, 556 U.S. at 678, 129 S.Ct. at 1949. "Nor does a complaint suffice if it tenders 'naked assertion[s]' devoid of 'further factual enhancements.' " Id. (quoting Twombly, 550 U.S. at 557, 127 S.Ct. at 1966).
If the court grants a motion to dismiss a complaint, it must then decide whether to grant leave to amend. The court should "freely give" leave to amend when there is no "undue delay, bad faith or dilatory motive on the part of the movant ... undue prejudice to the opposing party by virtue of allowance of the amendment, [or] futility of amendment." Fed.R.Civ.P. 15(a)(2); Foman v. Davis, 371 U.S. 178, 182, 83 S.Ct. 227, 230, 9 L.Ed.2d 222 (1962). Generally, leave to amend is only denied when it is clear that the deficiencies of the complaint cannot be cured by amendment. See DeSoto v. Yellow Freight Sys., Inc., 957 F.2d 655, 658 (9th Cir.1992).
I. Motion to Dismiss First Amended Complaint for Damages (# 24)
*6 Defendants argue that the FAC is predicated on a finding that Plaintiff can pierce the corporate veil of WIC and Access to hold the officers and directors of those two companies liable. (Mot. to Dismiss (# 24) at 2). Defendants argue that there are no facts to support piercing the corporate veil because Plaintiffs have not plead an alter ego claim against Individual Defendants because the FAC only recites bare bones elements and legal conclusions for alter ego liability. ( Id. at 8). Defendants argue that the fiduciary claim fails as a matter of law because, although WIC and Plaintiff may have had a fiduciary duty, there is none between Plaintiff and the Individual Defendants. ( Id. at 10–11). Defendants assert that the other claims should be dismissed because they are pled in a conclusory fashion and are not pled with Rule 9(b) specificity. ( Id. at 11–16). Defendants also assert that constructive trust is not available because there is no confidential relationship between Plaintiff and Individual Defendants and there are no allegations supporting the inadequacy of monetary damages. ( Id. at 16).
In response, Plaintiff asserts that this is not an action concerning piercing the veil because the action is premised upon the tortious and fraudulent conduct of Individual Defendants and not the tortious conduct of Western and Access. (Opp'n to Mot. to Dismiss (# 33) at 7, 12). Plaintiff asserts that, if the Court does find that piercing the corporate veil is necessary, that it has pled the requirements to pierce the corporate veil. ( Id. at 12). Plaintiff argues that it has pled sufficient facts to state a claim for all of its causes of action. ( Id. at 14–27).
In reply, Defendants assert that the FAC does not set forth individual actions by the Individual Defendants but instead refers to conduct by WIC and Access. (Reply to Mot. to Dismiss (# 35) at 2). Defendants also assert that there are no factual allegations against Defendants Carol Ingalls, Bradley Pearce, and R. Scott Rottman and that they should be dismissed from the case. ( Id. at 4). Defendants assert that there are no factual allegations that justify piercing the corporate veil of WIC or Access. ( Id.).
Pursuant to the discussions at oral argument, the Court grants the motion to dismiss (# 24) in its entirety with leave to amend. Plaintiff must clearly lay out allegations of fraud against the Individual Defendants pursuant to Fed.R.Civ.P. 9(b). Under Rule 9(b), a plaintiff must be specific enough to give defendants notice of the particular misconduct so that they can defend against the charge and not just deny that they have done anything wrong. Vess v. Ciba–Geigy Corp. USA, 317 F.3d 1097, 1106 (9th Cir.2003). "Averments of fraud must be accompanied by 'the who, what, when, where, and how' of the misconduct charged." Id. A "plaintiff must set forth more than the neutral facts necessary to identify the transaction. The plaintiff must set forth what is false or misleading about a statement, and why it is false." Id.
II. Motion for Order to Show Cause Why Prejudgment Writ of Attachment Should Not Issue (# 16)
*7 Plaintiff moves for an order directing Defendants to show cause why a prejudgment writ of attachment should not issue pursuant to NRS sec. 31.010(1) et seq. (Mot. to Show Cause (# 16) at 10). Plaintiff argues that its claims are valid. ( Id. at 11–14).
In response, Defendants argue that, in Nevada, a prejudgment writ of attachment only applies to contract-based actions and not tort-based actions. (Opp'n to Mot. to Show Cause (# 23) at 5–6). Defendants argue that Plaintiff has not alleged any extraordinary circumstances justifying a prejudgment writ of attachment. ( Id. at 7–8). Defendants also assert that they have meritorious defenses to Plaintiff's claims. ( Id. at 8–18).
Plaintiff filed a reply. (Reply to Mot. to Show Cause (# 25)).
In this case, the Court denies the motion for order to show cause why prejudgment writ of attachment should not issue (# 16) because there is no valid complaint at this time.
For the foregoing reasons, IT IS ORDERED that the Motion for Order to Show Cause Why Prejudgment Writ of Attachment Should Not Issue (# 16) is DENIED.
IT IS FURTHER ORDERED that the Motion to Dismiss First Amended Complaint for Damage (# 24) is GRANTED in its entirety with leave to amend.
Posted by Jay D. Adkisson, the author of Adkisson's Captive Insurance Companies, with main website http://www.captiveinsurancecompanies.com and with an interactive online forum at http://www.captiveforum.com and blog at http://www.captivenews.com see also http://www.jayadkisson.com and http://www.risad.com
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Originally posted on 60 Max Power O | Last updated 12/25/12
It was a loss in more ways than one Sunday night for the San Francisco 49ers. A big blowout loss to the Seattle Seahawks has been compounded with the loss of receiver Mario Manningham, who tore both his ACL and PCL, EPSN's Adam Schefter is reporting. The slow motion replay of his knee buckling was gruesome, as we saw the bone from the side of the knee pop right out but luckily not break the skin. From that point, we knew it didn't look good for Mario. It's a tought loss for the 49ers going forward into the playoffs. Manningham is 2nd on the team with 42 catches and third on the team with 449 receiving yards, and now the team will likely turn to veteran Randy Moss to fill the void. Also, a devastating injury like this in at the end of December will cut into the start of next season. var switchTo5x=true; stLight.options({publisher:''});
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