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Posts Tagged 'Raithatha v Williamson'
Horton v Henry – The Final Round – The Pension Lives!
I have written about this case and the associated one of Raithatha v Williamson previously here and here. Horton went on appeal to the CA and after a delayed hearing, and then a reserved judgment they have finally come to a conclusion, reported at Horton v Henry [2016]EWCA Civ 989
And the result was an emphatic win for the preservation of the pension against the attempts by the Trustee in Bankruptcy to get at it.
For those of you who have a life outside these columns the problem they was addressing was whether a pension, which would normally be exempt (by s11 Welfare Reform and Pensions Act 1999) from seizure by a Trustee, could be attacked by making an income payment order under s310 Insolvency Act 1986 requiring the bankrupt who was not yet drawing his pension but was aged over 55 to require his pension provider to pay him a lump sum and then pay it over to the Trustee. And this was given a lot more bite by the abolition of the former 25% cap on lump sums by the pensions reforms in 2015.
There were conflicting decisions from Deputy High Court Judges – in Raithatha the court said you could make such an order, but in 2014 another Deputy High Court Judge said you couldn't in Horton – and so the CA had to break the tie.
The CA Judgment – the Problem
The lead judgment was given by Gloster LJ and is clear and comprehensive, and compulsory reading for anyone who is relying on it.
The brief facts are that Mr Henry went bankrupt on his own petition with debts of up to £6.5m (the exact figure was disputed). He had generous pension provision, with a SIPP worth about £850,000 and 3 personal pensions giving rise to additional rights at various ages. He was 58 on bankruptcy, and wasn't receiving any of his pension entitlements because he was being maintained by his family and had no need for them. The trustee made an application under s310 (see above) for orders requiring him to claim his lump sums and pension incomes, which he was entitled to do, being over 55, and pay them over to him. He refused, claiming that these benefits were not income to which he had "become entitled" and derived from funds which were not part of the "bankrupt's estate" and so not susceptible to these orders. The Judge below agreed.
I won't set out all the statutory provisions as they are set out in full in the CA judgment. But the argument went:
- s306 Insolvency Act 1986 provides for the bankrupt's estate to vest in the Trustee;
- s283(1) IA defines the bankrupt's estate as being all his property at the date of bankrupty, apart from certain exemptions, including property excluded by other legislation;
- s91 Pensions Act 1995 excluded rights under occupatioal pension schemes;
- s11 WRPA (see above) excluded rights for approved personal pension schemes (such as his);
- s307 IA allowed the trustee to claim after-aquired assets, but not if they were excluded;
- nor if they were income and so susceptible to a claim for an income payment order under s310;
s310 is key so I will set it out. It provides:
"Income payments orders
(1) The court may make an order ("an income payments order") claiming for the bankrupt's estate so much of the income of the bankrupt during the period for which the order is in force as may be specified in the order.
(1A) An income payments order may be made only on an application instituted–
(a) by the trustee, and
(b) before the discharge of the bankrupt.
(2) The court shall not make an income payments order the effect of which would be to reduce the income of the bankrupt when taken together with any payments to which subsection (8) applies below what appears to the court to be necessary for meeting the reasonable domestic needs of the bankrupt and his family.
(3) An income payments order shall, in respect of any payment of income to which it is to apply, either–
(a) require the bankrupt to pay the trustee an amount equal to so much of that payment as is claimed by the order, or
(b) require the person making the payment to pay so much of it as is so claimed to the trustee, instead of to the bankrupt.
(4) Where the court makes an income payments order it may, if it thinks fit, discharge or vary any attachment of earnings order that is for the time being in force to secure payments by the bankrupt.
(5) Sums received by the trustee under an income payments order form part of the bankrupt's estate.
(6) An income payments order must specify the period during which it is to have effect; and that period–
(a) may end after the discharge of the bankrupt, but
(b) may not end after the period of three years beginning with the date on which the order is made.
(6A) An income payments order may (subject to subsection (6)(b)) be varied on the application of the trustee or the bankrupt (whether before or after discharge).
(7) For the purposes of this section the income of the bankrupt comprises every payment in the nature of income which is from time to time made to him or to which he from time to time becomes entitled, including any payment in respect of the carrying on of any business or in respect of any office or employment and (despite anything in section 11 or 12 of the Welfare Reform and Pensions Act 1999)[7] any payment under a pension scheme but excluding any payment to which subsection (8) applies[8].
(8) This subsection applies to–
(a) payments by way of guaranteed minimum pension; . . .
(b) payments giving effect to the bankrupt's protected rights as a member of a pension scheme.. . ..
(9) In this section, "guaranteed minimum pension" has the same meaning as in the Pension Schemes Act 1993.
"protected rights" has the meaning given in section 10 of the Pension Schemes Act 1993, as it had effect before the commencement of section 15(1) of the Pensions Act 2007."
There are also provisions to allow the recovery of excessive pension contributions under s324A IA.
The HC Judge summarised the position very succinctly, with the CA's approval:
"In short, the position since 1999 has been that rights under personal pension arrangements do not in general vest in a trustee in bankruptcy. Nevertheless, as has always been the case with occupational pensions, provision has been maintained for an IPO to be made in certain circumstances. It may be thought that the parenthetical words in section 310(7) were required in order to ensure that the position under personal pension policies did not diverge from that applicable to occupational pension schemes. There was to be no question of the 1999 Act going so far as to protect from creditors all income of a bankrupt even where such income stems from a pension. This was also the case as regards occupational pensions under the 1995 Act: see section 91(4)."
The CA set out the explanatory notes in the appropriate sections of the WRPA which explained what the Act was trying to achieve.
And finally, they quote s311 IA which imposes on the bankrupt a duty to assist the Trustee in the carrying out of his functions.
The CA Judgment – the Answer
Gloster LJ set out the question as follows:
Whether section 333(1), read in conjunction with section 310, of the Insolvency Act enables a trustee in bankruptcy to require a bankrupt, who has reached the age at which he is contractually entitled to draw down or "crystallise" his pension (but has not done so), to elect to do so, so that the trustee may apply for an IPO under section 310 in relation to the funds drawn, or to be drawn, down;
And the two possible arguments:
i) The first is to argue that, even on the assumption that the bankrupt's contractual rights to draw down or crystallise his pension after he has reached a certain age do not fall within the description of any "payment in the nature of income ……. to which he from time to time becomes entitled" for the purposes of section 310(7), nonetheless the trustee is entitled under section 333(1) to require the bankrupt to exercise such rights and elect to receive payment. The argument would run that, since one of the functions of the trustee is to obtain an IPO in respect of income that is potentially receivable by the bankrupt during the three-year period so as to satisfy creditors' claims, the trustee is entitled to require the bankrupt to draw down income from his pension for the purpose of enabling the trustee to carry out his functions under section 310(7) in relation to the income payments under the pension once drawn down.
ii) The second approach (and this was the way in which Mr Davies [for the trustee] principally presented his argument before us, and indeed how the judge dealt with the case at first instance) is to argue that the italicised wording in section 310(7):
"For the purposes of this section the income of the bankrupt comprises every payment in the nature of income …… to which he from time to time becomes entitled,"
meant that, once a bankrupt pension holder had reached the required age, and was accordingly entitled to draw down his pension on request, his vested right to elect to do so, and the subsequent payments which would be made to him by the pension provider, were within section 310(7) and therefore were subject to the IPO procedure. It accordingly followed that, either under section 363(2), section 333 or the general jurisdiction of the court, the bankrupt could be compelled to elect to draw down his pension.
She doesn't take any time to make up her mind between them:
In my judgment neither of these arguments is correct.
She wastes no time on the first argument – that the Trustee has functions in relation to property that is expressly excluded from the bankrupt's estate.
It would drive a coach and horses through the protection afforded to a bankrupt's pension rights by the Insolvency Act and pension legislation if a trustee were able, in effect, to require a bankrupt to make the entirety of his pension available for satisfaction of his creditors' claims, by the simple expedient of a request under section 333 or a court order under section 363(2), thereby converting excluded property into "income".
The fact that before bankruptcy pension rights might be accessible to a creditor – as in Blight v Brewster – merely shows the difference caused by an bankruptcy order. They don't support the argument that the same rules could apply after an order.
The second argument takes more consideration. In essence the question is whether a right to elect to take income is equivalent to payment of the income, under s310(7) IA. But again, the result is the same. Note the italicised words:
The contractual right to elect, by service of a notice on the pension provider, to receive a lump sum or income payment, in the pension context is very different in character from an actual payment or the right to receive that actual payment, once the relevant election has been made. Indeed, normally, until well after the relevant election has been made, there will be no legal right as such to receive any specific payment, particularly in the case of a SIPP, where the fund may comprise assets which are not readily marketable. In the context of section 310, payment and payment to which he from time to time becomes entitled mean just that; payment does not mean a chose in action or a bundle of rights which, if and when exercised, and only then, give rise to the making of a payment or the entitlement to a payment. The language of section 310 is addressed to capturing income; there is no suggestion in the language that it is conferring a power on the court to require the bankrupt to exercise a power – in relation to property expressly excluded from the bankruptcy estate – to generate income.
She points out that the legislation draws a clear distinction between payments under a pension scheme and rights under a scheme. And she concludes:
As with the first argument referred to above, it would drive a coach and horses through the protection afforded to private pensions and rights thereunder by virtue of section 11 of the WRPA, if, by the simple expedient of an application for an IPO, a trustee (subject to satisfying the court that the amount drawn down could be characterised as income and that the IPO did not reduce the bankrupt's income below what appeared to the court to be necessary for meeting his and his family's reasonable domestic needs) could in effect obtain payment of the entirety (or almost the entirety) of a bankrupt's pension fund into the bankrupt's estate so as to meet the claims of his creditors, notwithstanding that the pension was not in payment. In my judgment, Parliament has decided to draw the balance between, on the one hand, the interests of the State in encouraging people to save through the medium of private pensions (so that in old age or infirmity they will not be a burden on the resources of the State), and, on the other, the interests of creditors in receiving payment of their debts, by the mechanism of sections 342A to 342C of the Insolvency Act which enable a trustee to claw back excessive pension contributions made by the bankrupt where such contributions have unfairly prejudiced the bankrupt's creditors.
And she decides that Raithatha was wrongly decided, and that Horton was correct, and as the other members of the court (Sir Stanley Burton and McFarlane LJ) agree, the appeal is dismissed.
And the Consequence Is?
Much relief all round. This is the position that everybody thought they were in from the WRPA in 1999 until 2012, and even after that Raithatha was widely disregarded as merely being one decision of a Deputy Judge. A policy decision had been takenin 1999 to protect pensions in the case of bankruptcies and this has been upheld.
A decision the other way would have opened the gates to large numbers of applications by IPs hoping to recover at least enough to cover their own fees from very modest pension funds. Many bankrupts have had some success in the past, and fail towards the end of their working lives, and these are the sort of people who have built up modest pensions, which would be most at risk.
No, a good decision all round.
Given the devastating logic of the CA decision the Trustee looks unlikely to try to appeal to the SC, but if I hear anything about this I will let you know.
As I'm a few days late (the decision was published on 7th October) there are many commenties available on the web. They range from the friendly and extremely practical piece on Debt Camel to pieces on Lexis Nexis and by Eversheds and many other large firms. And there will be more. But if you've got this far you've probably read enough.
NEWSFLASH – Horton v Henry – the CA Speaks
And the appeal was dismissed, so Raithatha is overruled. The trustee cannot force a bankrupt to elect to claim his pension. More shortly, but here is the Bailii report.
Pensions and bankruptcy – a longer wait
If you go bankrupt can the Trustee get at your pension? Well if you are over 55 (or even 52) then they might be able to. Or on the other hand they might not. An unsatisfactory state of affairs, brought about by two contradictory decisions of High Court judges – Raithatha v Williamson or Horton v Henry.
Fortunately Horton v Henry is going to the Court of Appeal. Unfortunately the date originally given – 25/25 Jan 2016 – has not been effective, and the case has been relisted for 21/22 April 2016. So a bit longer to wait.
For more details of the cases see my earlier posts here and here.
STOP PRESS – Pension Appeal Approaches
If you go bankrupt can the Trustee get at your pension? Well if you are over 55 (or even 52) then they might be able to. Or on the other hand they might not. An unsatisfactory state of affairs, brought about by two contradictory decisions of High Court judges – Raithatha v Williamson or Horton v Henry.
Well there should be an answer soon as Horton v Henry is going to appeal in the Court of Appeal and is due to be heard on 26/27 January 2016. No doubt they will take a few weeks to bring out the decision, but it isn't too long to wait now.
See my earlier piece for more details.
Hope for the Pension – Horton v Henry
Horton v Henry [2014] EWHC 4209 Ch – Robert Englefield QC
Last autumn I ran a piece about pensions and bankruptcy – I'll Be Having That-Pensions and Bankruptcy – which produced quite a lot of interest. The piece was based on the 2012 case of Raithatha v Williamson [2012] EWHC 909 Ch which had decided that although pensions were generally exempt from seizure by a Trustee in Bankruptcy an income payment order could be made under s310 Insolvency Act 1986 which required a bankrupt who was not yet drawing his pension but was aged 55 or over to request his pension provider to make him a 25% lump sum and then pay it over to the Trustee.
I pointed out that if you join this with the wholesale reform to pensions announced in the Budget in 2014, which will allow people to withdraw ALL of their pension pots subject only to tax penalties, then pensions will be fair game for all Trustees. Any protection that people thought they had from s11 Welfare Reform and Pensions Act 1999 would be lost.
It would appear that this was an unexpected and unintended result of the legislation, but the Treasury, on having this pointed out to them, indicated that they were proposing to leave things alone. They indicated that they considered the obligation on bankrupts to pay their debts outweighed any individual unfairness.
Things didn't look good for the entrepreneurs and risk takers that are needed if an economy is to grow. But the courts seem to be coming to the rescue in the case named above.
The Facts
Michael Henry went bankrupt to the tune of perhaps £6.5m (the figure was never established ) on 18th December 2012. He had an SIPP pension worth perhaps £900,000 and three smaller annuity policies, but these did not form part of his estate and so were not available to pay his creditors because of the effect of s11 WRPA set out above.
He would have been discharged on 18th December 2013 but his Trustee applied on 17th December for an income payment order under s310 IA. After some revision the order sought was for an immediate lump sum of 25% of the value of the SIPP plus 36 monthly payments of drawdown, and the maximum lump sum of three times the annual amount of the annuities.
The Argument
The case was indistinguishable from Raithatha but as that was a decision of a (Deputy) High Court Judge it wasn't binding on this (Deputy) High Court Judge and he could refuse to follow it if he thought it was wrong.
You start with s11(1) of the Welfare Reform and Pensions Act 1999 which provides:
Where a bankruptcy order is made against a person on a petition presented after the coming into force of this section, any rights of his under an approved pension arrangement are excluded from his estate.
The case turned on the wording of s310. The relevant parts are:
(1) The court may make an order ("an income payments order") claiming for the bankrupt's estate so much of the income of the bankrupt during the period for which the order is in force as may be specified in the order.
(2) The court shall not make an income payments order the effect of which would be to reduce the income of the bankrupt when taken together with any payments to which subsection (8) applies below what appears to the court to be necessary for meeting the reasonable domestic needs of the bankrupt and his family.
(3) An income payments order shall, in respect of any payment of income to which it is to apply, either –
(a) require the bankrupt to pay the trustee an amount equal to so much of that payment as is claimed by the order, or
(b) require the person making the payment to pay so much of it as is so claimed to the trustee, instead of to the bankrupt.
(5) Sums received by the trustee underan income payments order form part of the bankrupt's estate.
(6) An income payments order must specify the period during which it is to have effect; and that period –
(a) may end after the discharge of the bankrupt, but
(b) may not end after the period of three years beginning with the date on which the order is made.
(6A) An income payments order may (subject to subsection
(6) (b)) be varied on the application of the trustee or the bankrupt (whether before or after discharge).
(7) For the purposes of this section the income of the bankrupt comprises every payment in the nature of income which is from time to time made to him or to which he from time to time becomes entitled, including any payment in respect of the carrying on of any business or in respect of any office or employment and (despite anything in section 11 or 12 of the Welfare Reform and Pensions Act 1999) any payment under a pension scheme but excluding any payment to which subsection (8) applies.
(8) This subsection applies to –
(a) payments by way of guaranteed minimum pension
The key words are those underlined in para (7). It was not disputed that if Mr Henry had elected to receive a lump sum from his pension his Trustee would be entitled to claim an IPO from it. However, could he be made to elect for one? Without an election he had no entitlement to payment.
The Trustee argued that s 331(1) of the Insolvency Act obliged the bankrupt to co-operate with the Trustee in getting in his estate:
The bankrupt shall
a) give to the trustee such information as to his affairs
b) attend on the trustee at such times, and
c) do all such other things
as the trustee may for the purpose of carrying out his functions under this Group of Parts reasonably require.
As sums received under IPOs are part of the bankrupt's estate (s310(5)) the Trustee was entitled to require the bankrupt to give the necessary election so that an order could be made.
The Judge however pointed out that this was a circular argument. The Trustee was only entitled to gather in the bankrupt's estate. If sums under an uncrystallised pension were not part of the estate the bankrupt had no obligation to help to collect them.
He also referred to the case of Barclays Bank v Holmes (2000) where Neuberger J (as he then was) said:
… it appears to me that, when using the word 'entitlement' in section 67(2), the legislature had in mind a case where the right to payment had arisen, in other words, to take the normal case, it covers a pension in payment. As a matter of ordinary language that is what 'entitlement' means …
This was in relation to a different Act but was very persuasive. Much the same thing was said in a number of commentaries and guidance notes.
And the judge also pointed out that the SIPP pension scheme in particular contained a very large number of options and choices in relation to payments, annuities, flexible drawdown and so on, and that the value of the scheme's benefits varied constantly and could not be known with any certainty until crystallisation occurred.
The Decision
The Judge declined to follow Raithatha. He said:
32. I entirely accept Mr Passfield's submission that I should be most wary of differing from another decision of a judge at first instance. He was right to remind me that I should only come to a different conclusion if I were persuaded that the earlier decision was wrongly decided. I have most anxiously considered the decision in Raithatha but I have, albeit with considerable reluctance, come to a different conclusion. Mr Henry is not entitled to payment under his pensions "merely by asking for payment". There is a considerable variety of options open to him. It would only be after he had made elections that any payment would be due to him. Only then would he become entitled to any payment. I do not consider that there is any power in the court under section 310 or in the trustee to require Mr Henry to elect in any particular way.
He therefore dismissed the application. There are accordingly two contrary decisions from High Court judges on this point, and District Judges and Registrars can follow either until the CA gets a chance to decide the matter. As Horton v Henry was an argument about some £300,000 it may well be taken there by the Trustee, possibly with some financial support from elsewhere.
And the Consequences?
Confusion all round. But some hope that the new pension reforms from April 2015, only a couple of months away will not mean that by going bankrupt a debtor loses not only all his estate, but all his pension too. We shall see.
I'll Be Having That – Pensions and Bankruptcy
Here's a scenario. It is September 2015. Basil is 59. After many years of running a successful company things seem to have gone wrong. As a last effort he poured thousands of pounds of his own money into the business to try to turn things round but eventually couldn't afford to pay any more and the business had to close, owing debts to suppliers, the bank and his landlord. The company went into liquidation, he lost his job and income. Worse still, his bank and landlord had received personal guarantees from Basil for the monies owed to them, and when he couldn't pay, as he had exhausted his funds in trying to save the business, he was made bankrupt. The house where he lived with his wife Barbara would most likely be repossessed by their mortgagees, as they could no longer afford to pay the last of the mortgage, and if they managed to avoid this it would probably be seized and sold by his Trustee in Bankruptcy under s335A Insolvency Act 1986, unless Barbara could buy out his interest by scraping together the money from her own savings and money raised from their family and friends. Things were not looking good.
But there was a future. Basil would be discharged from bankruptcy after 12 months, and although Basil's health had been ruined by the strain of the last few years, and he was unlikely to work again he had built up a good personal pension pot of £500,000 during the golden years of his business and they could look forward to a comfortable retirement, even if it wasn't as comfortable as they had expected a few years before.
However, a few months before the bankruptcy was over Basil received an application from the Trustee for an Income Payment Order under s310 IA 86. This asked for an order for him to pay over his "surplus income" to the Trustee. Basil laughed – his only income was state benefits and there was no "surplus". However, he looked at the application again and was horrified to find that the application contained a request for
- An order for Basil, or the Trustee in Basil's name, to make an application to his pension scheme for an immediate payment of the whole of his pension fund, as he was now entitled to under the pension ref0rms introduced in the Finance Act 2014
- The money to be paid over to the Trustee and applied
- in payment of the income tax due, amounting to some £154,887, and
- the balance of £345,123 in discharge of the bankruptcy debts and costs.
Basil was outraged. He understood that his pension was protected from bankruptcy, and besides, this was a terribly wasteful way of getting at the money, incurring tax as if it was all his income in the year of payment. So he sought advice, and was told to his horror that it was now the law. And a probable oversight by the powers that be.
The background
Prior to May 2000 personal pensions went to the Trustee like everything else and were lost to the bankrupt. Employers schemes were a bit different as the only entitlement was to the benefits, not the capital sum, and these were often protected by being a discretionary payment by the trustees.
This was felt to be unfair and s11 Welfare Reform and Pensions Act 1999 provided that rights under pensions schemes approved by HMRC were excluded from the bankrupt's estate, and the Trustee couldn't get at them. All he could do was challenge excessive contributions, or include any income received from the scheme in an IPO. Even unapproved schemes could be protected if the bankrupt persuaded the court that they were needed to satisfy the reasonable needs of the bankrupt and his family. In order for a scheme to be approved it had to fulfil various criteria, one of which was that the maximum lump sum that could be withdrawn was 25% of the total, and only from the age of at least 55 years. The Act did go on to prohibit any forfeiture of rights under personal pension schemes by reference to their bankruptcy s14. But on balance the pension looked pretty secure.
Trustees were initially resigned to the change, but as time went on there were rumblings that there might be a way round and in April 2012 the Bankruptcy Court ruled in Raithatha v Williamson [2012]EWHC909Ch that an IPO could be made ordering the bankrupt , or the Trustee, to apply for a withdrawal of the 25% maximum sum and for it to be used to pay the debts. Mr Williamson appealed on a number of grounds, including an argument that he couldn't be forced to exercise an option that he didn't want to exercise, and that until he did so this wasn't "income" and so couldn't be subject to an IPO. It was also in breach of his rights under the ECHR to personal property. However, his appeal was compromised shortly before it was heard, and so the case stands, and is binding on DJs and Circuit Judges.
The case was in fact following on from a very similar case of Blight v Brewster [2012]EWHC165Ch although that case wasn't referred to in the judgment in Williamson. The difference in Brewster was that the Defendant wasn't bankrupt, he just had judgments entered against him. Again he was ordered to exercise an option and call down a 25% lump sum from Sun Life, so it could be used to pay his debts, and the Claimant was authorised to write on his behalf if he wouldn't co-operate. Although it can't have helped his case that the judge clearly regarded him as a fraudster.
So up to 5th April 2015 25% of a personal pension is accessible to an IPO. However, as these benefits are normally only payable from the age of 55, and applications for IPOs have to be made before the bankruptcy is discharged, and can only run for 3 years, they really only affect debtors from 55 years upwards, who have not yet crystallised their pension by the purchase of an annuity or other long-term investment.
The Change
In the Budget speech Mr Osborne announced a wholesale reform of pensions legislation. Part of this was to allow the public to manage their own pensions, and to withdraw their funds and invest or use them as they thought best. This was a generally popular proposal, and most of the discussion has been on the tax implications, the risk of people wasting their money on cars and flashy holidays and the like.
Part of the reform includes changes being imposed on pension schemes by the government requiring them to allow people to withdraw funds in accordance with the new regime. These are terribly complicated, and I won't trouble you with them now. But they will take effect from 6th April 2015, the start of the next tax year. My understanding (and I haven't been able to find chapter and verse while writing this piece) is that the freedom will apply from the date that the pension can be taken, and in most cases this will remain at 55 years.
What has been overlooked is the effect that this will have on IPOs against pension pots. And there is clearly only one answer: Trustees will be able to apply for ALL of the vulnerable pot to be drawn down. The first 25% will remain tax-free, but the rest will be taxed at normal income tax rates – 20% 40% and 45% according to income.
All that they will have to overcome are the provisions in s 310 IA [link above] that:
(2) The court shall not make an income payments order the effect of which would be to reduce the income of the bankrupt when taken together with any payments to which subsection (8) applies below what appears to the court to be necessary for meeting the reasonable domestic needs of the bankrupt and his family
S(8) refers to guaranteed minimum pensions and protected rights under pension schemes. So the bankrupt must be left with enough to live on, but only just. And then only after taking account of pension payment which cannot be actually seized themselves.
The Outcome
It seems unlikely that this was intended. It hardly seems the best way to encourage entrepreneurs and the risk-takers needed if the economy is to grow as this government wants it to. And there has been no publicity apart from a few notes on insolvency websites. But there we are. You have been warned.


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Real Estate Law
Have Real Estate Law Questions? Ask a Real Estate Lawyer.
I am sorry to hear about your situation. Do you have any sort of written agreement with the Property Manager? If so, then you have a very strong claim here for breach of contract. If they are an employee of yours then you can terminate him or her and possibly sue them for your damages. Their failure to notify you actually exposes you to liability.


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Mumbai: A 23-year-old medical fourth-year MBBS girl from Vashi died after jumping off a train when it took off from Kharghar station on Wednesday.
Sneha Khandgale was a fourth-year MBBS student who was an intern at a private hospital at Kharghar, she had severe head injuries and died at a hospital, railway police said.
"On Wednesday morning she and a few of her friends boarded a Panvel-bound train to go to the hospital from Vashi. Around 9 am the train halted at Kharghar station but she took some time to reach the door from her seat," said Rajesh Babshetty, senior police inspector of Panvel government reserve police.
"By the time Sneha reached the door, the train had started but she still jumped off it, fell on the platform and hurt her head badly," he added.
Her friends rushed her to MGM Hospital in Kamothe. "Her condition started deteriorating and she was shifted to another private hospital in Vashi. But she died there at night," Babshetty said.
Her body was sent to a postmortem in Navi Mumbai Municipal Corporation Hospital in Vashi and then was handed over to her family. The post-mortem report is yet to be released.
In a similar incident, a man had died after jumping off a moving train at Panvel station. Nandakishore Verma, 50, had reached the station to board a train to Delhi on Wednesday. However, he mistakenly boarded a southbound train.
"He realised his mistake only after the train started moving. He jumped off the train, fell on the platform and suffered severe head injuries," a railway official said.
His body was sent to Panvel Rural Hospital for a postmortem before it was handed over to his family. The railway police registered accidental death cases for both incidents.


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I first decided to make sweet plantains, and cook them as I would apples for french toast syrup. I decided that this would be the perfect opportunity to use the fluff as well, in a sticky sweet sauce which would go over the plantains. Now to stick with this "sweet" theme, I wanted to sear the steak and then to deglaze the pan with Maker's Mark whiskey (which has notes of caramel) and then add a little butter and chopped peanuts. You probably noticed the other beautiful little savory side on the table: citrus pickled red onions over white rice (one of my personal favorites).
Little did I know, this wacky combination of ingredients would yield one of the most delicious meals that I've ever made.
Flank Steak with Maker's Mark Reduction
& Sweet Plantains
Yield: 2 Servings
Flank Steak with Maker's Mark Reduction
3/4 lb flank steak
1 tbsp olive oil
1/2 cup Maker's Mark
2 tablespoons finely chopped peanuts
1 tablespoon butter
kosher salt
ground black pepper
Preheat your oven to 400 degrees and preheat a grill pan over high heat. Pat the steak dry with a paper towel, rub it with the tablespoon of olive oil, and liberally sprinkle it with the kosher salt and black pepper. Place it onto the grill pan for 3-4 minutes on each side until it's perfectly seared, then remove it from the pan and place it onto a baking sheet. Place the baking sheet into the oven for 10 minutes. Meanwhile, deglaze the grill pan by adding the butter, then the Maker's Mark. After it has reduced for a few minutes, add the peanuts and take it off of the heat. When you remove the steak from the oven, allow it to rest for another 10 minutes to let the juice re-disburse.
Sweet Plantains
1 ripe plantain
1 1/2 tbsp butter
1 tbsp brown sugar
1 dash cinnamon
1/2 tsp vanilla
1/2 cup heavy cream
1 cinnamon stick
1/2 cup fluff
Cut the ends off of the plantain and use a paring knife to slice off the exterior skin. Slice it in half lengthwise, and then slice each half into thirds. Place a small pan over medium heat and add the butter. After it's melted, place the plantains onto the pan and turn the heat to low after they're browned on each side (after 3-5 minutes). Next, add the brown sugar, cinnamon, and vanilla and allow them to cook for another fifteen minutes or until they're softened.
In the mean time, place a small pot over low heat and add the heavy cream and the cinnamon sticks. Allow this to simmer for ten minutes, then take it off of the heat and stir in the fluff until it's completely incorporated.


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Judge Rules Same-Sex Couples Entitled to Military Spousal BenefitsSeptember 4, 2013 8:58 pm Estate Planning
A Los Angeles U.S. District judge has ruled that the U.S. military cannot deny spousal benefits to a California veteran in a same-sex marriage, saying that the denial of benefits does not serve any military purpose.
U.S. District Judge Consuelo Marshall made the ruling in Cooper-Harris, et al v. United States, a suit filed last year by a female Army veteran, Tracey Cooper-Harris, and her lesbian spouse, Maggie Cooper-Harris. Tracey Cooper-Harris served active duty for nine years in the U.S. Army, including a stint in Iraq in 2003. She married Maggie Cooper-Harris in California in 2008 when same-sex marriage was legal.
Tracey Cooper-Harris was diagnosed with multiple sclerosis in 2010 and brought suit in order to provide military benefits for her spouse. The Department of Veterans Affairs found that the MS was related to Cooper-Harris' military service and awarded her disability compensation, but said that her spouse did not qualify for survivor benefits if she dies.
Citing the recent U.S. Supreme Court decision in United States v. Windsor that found the Defense of Marriage Act unconstitutional, Judge Marshall said that defining a spouse as a person of the opposite sex is unconstitutional "under rational basis scrutiny" since the high court's decision allows legally married gay couples the right to health care benefits.
According to the U.S. Department of Defense, same-sex spouses of military couples will be eligible for the same health care, housing and other benefits as opposite-sex couples as of Sept. 3, 2013.
To learn more about the extension of federal benefits under Windsor, contact our Costa Mesa law firm.


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Broker Associate
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I decided after years of working with other companies, including owning my own real estate business, to align myself with Coldwell Banker. My reason was simple. They are leaders in every aspect of the business! When 9 out of 10 consumers know the Coldwell Banker name, you know it's a powerful brand.
In addition to being an experienced, multi-million dollar producer, you'll find that I'm enthusiastic, diligent and professional. But I realize you aren't especially interested on my past accomplishments. You want to know what I will do for you, right? I will work hard to exceed your expectations and make your transaction a smooth one from start to finish. I'll utilize my unique blend of experiences to work with both buyers and sellers. I chose a real estate career because of the satisfaction I get from helping such wonderful people achieve their real estate goals. Work with me and you'll understand my motto. "Once you're my customer, you're always a friend!"


text: Local photographer Vivian, from High Tea Photography, will be at DayOne Baby for a photo shoot. The sitting fee will be sponsored by DayOne Baby, and digital files are available for purchase. Learn more about High Tea photography on their website: http://www.highteaphotography.com/. For photos check out the High Tea Photography Facebook page https://www.facebook.com/highteaphotography?ref=hl.


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Earlier this week my husband brought home a bunch of bell peppers not realizing that I had also bought bell peppers! I had bell peppers overflowing out of my produce drawer. I love a stuffed bell pepper. I usually make mine with 99% lean ground turkey, brown rice, fresh diced tomatoes, feta cheese and mozzarella cheese. On Tuesday night, my friend Courtney from Journey of a Dreamer posted a recipe for Paleo Cauliflower Cilantro Rice and BAM...I knew that when I made my stuffed peppers I would use her recipe instead of brown rice.
It was super easy to make (made easier b/c I used frozen cauliflower florets) and I made extra paleo rice so I could pack some for my husband's lunch and I ate it for lunch yesterday, too!
Here is Courtney's recipe. I pretty much followed it exactly, just DOUBLING it because I used two bags of frozen cauliflower instead of the called for 1 head.
After I had cooked the rice, and the ground turkey, I stuffed the peppers! Usually I stuff them from the top down, but I decided I wanted to cut them in 1/2 and fill them that way. It worked out just fine!
I did not cook the peppers beforehand. I just layered, ground turkey breast, paleo rice, feta cheese, fresh tomatoes, mozzarella cheese, and then another bit of tomatoes on top, and cooked until the peppers were soft and the cheese was melted, at 425 degrees. It was very good and I will certainly make it again!!
Tags: paleo, cauliflower rice, stuffed bell peppers, friday food fight, weight loss, fitness
Thank you for this recipe! I can't wait to try it.
On another note-I cannot seem to comment on your last giveaway blog-the one with lots and lots of items. It never let's me save the comment once the captcha finally shows up
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Business TypeDistributor/Wholesaler
Main MarketsNorth America South America Western Europe Eastern Europe Ea
Product/ServiceBusiness consultant providing strategic planning, sales & marketing, acquisitions and interim senior management.
Business OwnerRobert Ber
RegionUnited States
CategoryBusiness Services - Consulting
Company TagsAcquisitions - Business Consultant - Consulting Business - Edge Consulting - Launch Products
Company Introduction
Company has worked with small and large businesses around the world to help them launch products, start-up foreign offices, ecommerce, acquisitions identify sales agents. Businesses include high technology, retail, commercial and manufacturing.
Contact Information
Contact PersonMr. Robert Berman
Fax Number1-763-3740056
Post Code34235
Address5682 Bentgrass Dr., Suite 104, Sarasota, Florida, United States


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Save $30.51 (27%)
Perfect over the bars lights.Read More
Really unusual lighting for our kitchen bar. Looks classy with a warm ambience. Very happy with these lights!Read More
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Color was Gold, not Copper as claimed. Overstock stated in the Q & A that product came with two 6" rods and two 12" rods. It came with three 12" rods. Hard to make 18" out of this, as the rods screw together. The Glass shade was pretty, too bad it had to go back.Read More
Woodbridge Lighting Liezel 1-light Copper Glow Mini Pendant
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A bad tartar build up is no laughing matter, or even smiling one for that matter. When people have too much tartar, their teeth start to decay.
This can mean a yellowed appearance. If the bad tartar build up stays on the teeth long enough, then the teeth can start to decay.
Tartar is even worse than plaque. Plaque is the first stage of a bacterial build up on the teeth. When it hardens and stay on the teeth for prolonged periods, then it becomes tartar.
Tartar is also known by the name calculus, although this name is not as common as tartar. Tartar forms usually above and below the gum line. It must be removed in the dentist's office with special tools. At this point, the patient might even have developed a gum disease from the tartar.
Unfortunately, this removal can be painful. If a person is worried that they have tartar, then the individual can take an extra strength non prescription pain killer an hour before the appointment.


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Pork Roast Soup (2 Meal Recipe)
Recipe by O-mama
Threw the pantry at a pork roast in the crock pot and this is what resulted. The roast turned out so tasty with the 'gravy' that we made it into a soup a couple nights later. DH liked the soup even better.
Top Review by Kim127
This was fantastic! Simple, comfort food. For the first meal, I cooked it in the crock pot for just under 10 hours while at work. I served the pork, which just simply fell apart with a fork, with rice and green beans. That went over well with the DH. We had quite a bit of the roast left over since there are only two of us, so the amount of meat used up quite a bit of the 'gravy'. So I simply shredded the remaining pork, added some mushrooms and served it over mashed potatoes. This went over extremely well with the man. He loved it. Thank you for 2 wonderfully easy and tasty meals.
See Discussion:1 Review
Ingredients Nutrition
- 2 -3 lbs boneless pork loin roast
- 1 (14 1/2 ounce) can chicken broth
- 1 (10 3/4 ounce) can cream of mushroom soup
- 1 (10 3/4 ounce) can cream of celery soup
- 3 -5 small red potatoes, cubed
- 1 small carrot, sliced
Directions See How It's Made
- Combine roast, broth and cream soups in crock pot and slow-cook per your manufacturers directions. (We did ours for 5 hours on high so it would be very tender and fall apart easily.).
- After serving as a roast with your favorite side dishes, shred pork and mix well with the remaining 'gravy.'.
- For another meal, add potatoes and carrots (and any other soup fixings your family feels would be tasty) and reheat till the veggies are cooked.
- We managed to have at least four servings of the roast and then four servings of the soup. Prep time includes dumping the stuff in the crock as well as prepping the soup veggies.


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|The Phoenix Mod is a weapon mod, and is an upgraded version of the Torch Mod. It is used to create an axe that sets zombies on fire.
|This Mod is found in Act III in the Smugglers' Marina, after you kill Afran during the "Soldier of Fortune" quest, on the table before you get onto the boat. It is said that if you miss it there, you can find it in a red shipping container near the gas station in the mission "Boat Supplies".


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Even superstars get starstruck. Just ask Beyoncé. The pop singer has posted a handwritten fan letter on her website praising Michelle Obama as "the ultimate example of a truly strong African American woman." In her note she gushes that "no matter the pressure and the stress of being under under the microscope" the First Lady always manages to be "humble, loving and sincere."
The new mom, whose daughter Blue Ivy was born January 7, ends her letter by thanking Mrs. Obama for all that she has done saying, "I am proud to have my daughter grow up in a world where she has people like you, to look up to."
This isn't the first time Beyoncé shared her appreciation for the First Lady. Last year, she joined Mrs. Obama's "Let's Move" campaign, which looks to fight childhood obesity in America. She re-worked her single "Get Me Bodied" to create the song and video for "Move Your Body." This became the anthem for the initiative's "Let's Move! Flash Workout" program, promoting physical activity among school children.
Beyonce's been doing a lot of letter writing lately. Last week, she posted an adoring note about Sade, writing, "Her music has been a true friend, as all true music should be."
She'll return to the big stage this Memorial Day for a three-day stint at the Revel casino, Atlantic City, NJ's brand new mega-resort . This will be Beyonce's first live show since giving birth earlier this year.
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A bit like Loose Women on PCP, except none of us are munters or have our meat curtains sweeping the floor when we walk. This blog will revolutionise the art of talking about fuck all and will either make you physically shake with anger or worship us as goddesses.
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Thursday, 11 June 2009
Posted by Jo Fuertes-Knight at 02:39
Labels: WE ARE AMAZING AT EVERYTHING
3 comments:
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By Lee J. Ames
"With its renowned topic of ingenious monsters and different nightmare population, [this] could be a sure-fire circulator." -- Publisher's Weekly.
From the alternate Paperback edition.
Continue reading "Download E-books Draw 50 Beasties: The Step-by-Step Way to Draw 50 Beasties and Yugglies and Turnover Uglies and Things That Go Bump in the Night PDF"


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flies in the rooms ( not just mine I checked with another person staying thier as well) way out of town and front desk did not know Philly. Food was not good either the cheif's creation of deep fried cheese cake should be nixed. Best thing about it was the beer and the bartender.
- Official Description (provided by the hotel):
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A list to get you on the right track and keep you there would certainly come in handy. Without a list, or a plan, you don't know what you're doing half the time and could be running from one thing to another.
But, not all lists or plans are equal. You need to find a plan that works for you for what you want to accomplish. You have to have a starting point and an ending point, like a map, and plan the route along the way.
That's why a list comes in handy.
Here's a list that I found that I call a Homesteader's list. It may not be missing some things for what you have in mind but you might be able to gather a few ideas from it.
A Homesteader's list…
Next Page »
100's OF BUILDING PLANS FOR YOUR HOMESTEAD!
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Girls Original Sleepwear
The Original Girls Sleepwear items illustrated here, are for the newborn and infants, up to 24 months of age. Each item is specifically chosen for it's high quality, unique style and design, and latest fashion look. Each item is selected to provide the safest and most comfortable sleep for baby. The items manufacturer/supplier is listed with each item. The specifics for each garmet are included in the detailed description.
Hush Little Baby Personallized
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First Tutors: Music enables you search for your preferred private Casual Saxophone tutor in the UK. Use our site to search for private Casual Saxophone teachers in your area and choose which fulfill your requirements.
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Saanen, Anglo Nubian, Pygmy and other goats availablePopular
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Dive Capital of the World!
Explore Key Largo
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Thank you for visiting our web site for real estate in Key Largo, Islamorada, Marathon, Lower Keys and Key West in the Florida Keys. Whether buying or selling, we would like to be your Keys Realtor!
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By submitting this information, you provide express written consent to RE/MAX All Keys Real Estate and our affiliates (the "Company") sending you future information, contacting you for telemarketing purposes using the information (including any phone numbers) you have or will provide us, and monitoring and recording these communications to assure the quality of service or for other reasons. This means the Company may contact you via residential number, mobile number and/or text messaging (including use of automated dialing equipment and pre-recorded calls). You are not required to give your consent as a condition of making a purchase with the Company. Additional information can be found in our Privacy Policy.
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65821 Overseas Highway 400
Long Key, FL 33001
233 Sombrero Beach Road
Marathon, FL 33050
302 Willow Street
Duck Key, FL 33050
110 Iroquois Street
Plantation Key, FL 33036
Just listed this like-new home for sale in Key Largo Park. Motivated seller has priced this home to sell fast!
View more information: 17 Coconut Drive - Key Largo Park
Bayside homeowners' park with boat ramp, beach area and cheeki hut.
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Your chance to buy a pool home in Key Largo in the Upper Florida Keys!
108 Marina Avenue is newly listed and easy to show - just contact the Jim Signor Real Estate team at RE/MAX All Keys Real Estate
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New price on this home for sale at 93 Marina Avenue in Port Largo.
This house is all concrete, even the roof, and located in a central area of Key Largo near banks, shopping, community park, restaurants, etc.
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Very unique offering of this 10 bedroom home situated on Florida Bay in the Upper Florida Keys. Atrium layout takes advantage of the beautiful Florida Keys sunshine.
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Two of a kind luxury property for sale in Key Largo. This 10 bedroom, 11 1/2 bath home on Florida Bay features a swimming pools, a tennis court, boat dock and very unique floor plan.
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Type anything you want here and we will see what we can find in the property descriptions. Maybe a name of a golf course you want to live by or a term like fixer upper.


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Hardwork vs Talent
Have you ever referred to someone heard someone refer to an athlete as a prodigy, or label them as being born with talent? What if I told you there was no such thing and it all boils down to how hard, focused and long someone practices/works on their particular game, subject, sport, etc.?
Think about it. Michael Jordan, Michael Phelps, Tiger Woods, Rory McIlroy, LeBron James, Jerry Rice, Bobby Fisher, Venus/Serena Williams, Einstein, Mozart, Justin Beiber (Ok, I just threw the last one in to see if you were awake). I have heard on many occasions by many different people, announcers, and fans that each one of these individuals is "gifted" or even "blessed with talent." I'm going to challenge these statements and say that each one of them, all very successful in their fields, are not the result of some God given talent, but more importantly, are the result of many, many hours of hard work and practice.
If you don't believe me, I have 2 books for you to read that changed my perspective on this matter. In fact they changed my perspective on many things, including my focus and training style with my clients, my parenting style with my kids, and how I personally workout and practice, both for health and other recreational activities, golf included. (As a side note, as much as I hate to say it, they also gave me a dose of reality on why I never even came close to playing much more than mediocre soccer at the college level. It was tough to admit, but I now realize I just didn't want it bad enough, and therefore didn't put in the work!)
The 2 books are Outliers by Malcom Gladwell, and Bounce by Matthew Syed. In each of these books, both authors delve into the world of sports, entertainment, and other areas, studying the most successful people and athletes. Each of them emphatically stress the undeniable connection between hours of practice and success. In fact, they both flat out say that no one is born with an advantageous amount of talent in their genes. Yes, some may have physical attributes that are suited more for one sport or profession (like height in basketball and smaller builds in gymnastics), but the talent that eventually makes them a super star in their sport is from years and years (in fact they put the number at 10,000 hours) of focused practice and conditioning.
If you take another look at the list of names above, each one of them are noted for how hard they worked as kids and even when they were at the peak of their game. There are countless stories of Jerry Rice being the at practices an hour early and staying an hour late. Michael Jordan speaks of how many shots he had to miss in practice to get him to the point where he could sink those buzzer beaters with his eyes closed (the number is well in the thousands). And Tiger Woods, love him or hate him, was the best in the game, (and may be again). He has been called a practicing machine. Hitting balls and working out from dawn till dusk to earn the most titles of any golfer ever.
Take any successful person, athlete, etc. and take a look at their history. I am willing to bet that what seems to be "overnight success" is more likely "overnight public awareness." Ask the individual how "overnight" their success was and they will tell you they had to work extremely hard to get where they are.
How does Hardwork and Talent affect my training and life?
While many of you reading this article may not be in a position to become a professional athlete or golfer at this stage in your career, it's likely that you are very succesful in your current occupation or business. Let me ask you, was it just God given talent, or did you work your butt off? That's what I thought.
In regards to your training and practicing, I only imagine that if you are reading this blog, you are looking to improve yourself or your game. Thus, proper practice and focus are required to make those improvements. Think about what you have been doing in your training program or when you are out at the course. Are you serious about getting better? Are you challenging yourself everytime to step in the gym or at the practice green/chipping area (notice I didn't say driving range, hint hint!)?
Don't get caught up in the notion that you weren't born with the skills of Rory. He wasn't born with them either. Focus on the fact that concentrated practice, improved fintess (flexibility, strength, balance, overall athletic mobility) is what got him where he is and can get you playing and feeling better that you did yesterday.
What is your take? Is talent born, developed, or a little bit of both? Let me know what you think.


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These women's soft-feel waterproof walking pants are designed to worn all day. Ideal for walking in changeable conditions and frequent showers.
With Pre-Order, you can purchase the latest items added to our store in advance of them arriving with us.
You Pre-Order is prioritised (at no additional charge); meaning that, as soon as the product arrives with us, we can wrap it straight back up and get it sent out to you - it often never even hits the stock room shelves!
With Pre-Launch, the date when we expect to receive the product ourselves is still a little too hazy to be confident in accepting Pre-Orders.
So, instead, you can submit your email address against the item you are interested in and we will email you as soon as stock arrives on the system.
Estimated Delivery Dates are given on Pre-Order and Pre-Launch products. They are for indication purposes only and can change at any time without notice.
The dates we provide are based on indications given by our suppliers. Whenever we get updated information from our suppliers we will endeavour to update the Estimated Delivery Dates provided on product pages.
Rather than pack seperate overtrousers for wet conditions, these walking trousers are waterproof, breathable and soft enough to be worn as normal walking pants. Great for wet walks in colder conditions.
30 Day Returns
Free UK Delivery when spending £25+
Express Delivery Options Available
Very comfortable, good fit, seem to be waterproof so far, great with a pair of leggings underneath for extra warmth when needed. The only issue so far the button fell off after a couple of times wearing them, thankfully in the wash on not while I was out on a walk :-) Even so still giving the pants a 5 star.
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Fired VA Official Back on Job/ Robert DeNiro Flips Out
First, here is good news. There is a great new website called Media Equalizer. It is dedicated to exposing left-wing media bias, and it gives lots of information about particular cases, for instance quotes and videos from people like Rachel … Continue reading


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Artist's description:
Oil on canvas 150 x 120 cm.
This large painting depicts a still life in which the flowers, bunches of red mountain ash and apples create a wonderful atmosphere of autumn. This picture perfectly complements any interior, filling it with the richness of autumn.
All sides are painted,ready to hang.
Materials used:
oil on stretched canvas
Autumn still life (2015)
Oil painting by Anna Rogova
- Oil painting on Canvas
- One of a kind artwork
- Size: 59.06 x 47.24 x 0.79 in (unframed) / 59.06 x 47.24 in (actual image size)
- This artwork is sold unframed
- Signed on the front
- Ready to hang
- Style: Impressionistic
- Subject: Still life
More by Anna Rogova View all
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Oil paintingby Anna Rogova
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Blue dream
Acrylic paintingby Anna Rogova
Lilac flowers
Oil paintingby Anna Rogova


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For most webmasters, one of the biggest concerns on their minds is finding effective ways to bring more traffic, and traffic that is of good quality, to their websites. One of the basic methods of doing this is by way of free search engine traffic.
Search engines that are spider-based, or crawler-based, automatically visit the various pages of a web site in order to compile their index listings. These kinds of search engines differ from directories, because by means of the crawling, you are likely to have a number of your pages indexed with them.
So, with a website that has been crafted carefully with pages that have been customized with search engine optimization as a goal, it is possible to rank highly in the free search engine spider-generated listings.
With good optimization and patience, it is even possible to achieve a top-ten position, which would put your page on the first results page, where everyone would prefer to be found.
The fact is that very few surfers will ever see a site that is not listed within the first page of the results in the top search engines. That is why it is so important to make sure that your pages are optimized so that you have a chance of getting included in that first page, which will give you plenty of free search engine traffic, of course depending on the popularity of the search term you are ranking for.
There is no doubt that in the internet world today, that the most important spider-based search engine is Google. More people search via Google than the number of people who search the other search engines combined, meaning that more than one out of mostly all two people who are looking for something online will be using Google to find it.
So, it's a good strategy to optimize your pages for Google, and that in turn will result in sufficient optimization for the other top search engines for the most part. In addition, the Google search engine also is the generator that powers the listed results for a number of other services as well.
The best way to get a listing with Google, and get that free search engine traffic you need, is to get you site linked on other website. These are called inbound links when they are found on another site and point to yours, and because the crawler-based engines follow links from one site to another, this is why it is so beneficial to have links from other sites to yours.
However, just having a few links to your site is not enough in and of itself. You will get a better boost in your page ranking if the links to your site come from other quality sites with good page rank of their own.
And, one simple way to begin to get links to your site is with free search engine submission. This will essentially get your "foot in the door" by getting your site listed with various directories, which will in turn direct the spiders to your page for indexing on Google and the other search engines.
Even though that can give you a very nice start, you need to continue your efforts by always adding find good links back to your site and by adding quality content that is relevant to your topic. By continuing these efforts you will continue to find an increase in the free search engine traffic you enjoy.


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I can't believe my eyes and ears. The MSNBC anchor points out that the Obama campaign used a clip of her debate fact-checking in one of their ads, but they neglected to include the part where Mitchell pointed out Obama's fallacies.
http://www.politico.com/multimedia/vide … ma-ad.html
I wonder if the people at Fox would do that.
Andrea Mitchell was right to point out the Obama campaign selectively editing her.
It's the media?
by Shanna5 years ago
http://news.blogs.cnn.com/2012/05/09/ob … ?hpt=hp_t1About time he decided on the issue. Any thoughts/comments/theories? So now he's for it, but is he going to do anything about it, I wonder.
by Dr Billy Kidd5 years ago
Presidential candidate Mitt Romney said last week that Obama has a secret agenda for his second term. I'm wondering what that is. Romney did not say. Or is this the old psychological trick of projecting your fault on...
by Alexander A. Villarasa4 years ago
The two recent Presidential and one vice-presidential debates have made it abundantly clear that Obama and Biden can not defend their indefensible 4 year record of bad economic and domestic/foreign policies....
by Susan Reid4 years ago
One of my biggest frustrations with the Obama administration is they are not good at promoting their achievements. Although that could be the fault of the so-called "liberal media" which is all corporate owned...
by nicomp really8 years ago
From the What Else is New Department...The Obama White House left open the possibility Sunday that the president would break a campaign promise and raise taxes on people earning less than $250,000 to support his health...
by Lady LaShonda7 years ago
Hello Everyone,Just thought I'd post this about Barack Obama's vistory. Election night was so emotional for some of everybody. Tears of joy for this man ran throught the world. Please to tell me what you were doing when...
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Company Name: Billbergia Pty Ltd
Member Rep Name: Rick Graf, Group Representative
Member Since date: November 2016
What are your core business activities?
Billbergia is a vertically integrated Australian property group whose business structure covers every stage of the property life cycle including investment management, acquisition, development management, planning and design, construction, project marketing and sales.
Based in Sydney for over 30 years, Billbergia is owned and directed by John and Bill Kinsella, and as a family owned enterprise, Billbergia maintains a profound long-term interest in the well being of the communities it creates.
More than 15,000 people currently live in Billbergia communities and a further 15,000 will move in over the next five years.
Wentworth Point and Rhodes New Communities
What attracted you to the Property Council?
As our major projects increasingly focus on shopping centres and high density mixed use communities together with significant public infrastructure, the Property Council is a good complement to our involvement with UDIA and the MBA. Strong, clear advocacy with Government is critically important in delivering large-scale projects with full social and transport infrastructure.
What are the issues of importance to your company that the Property Council can work with you on?
Developing a viable business case for delivering 'Affordable Housing' stock as part of major residential projects. Also, constructive engagement with Government regarding an equitable 'Value Sharing' methodology to enable more rapid delivery of public transport infrastructure.
Bennelong Bridge and New Residential Construction
What do you see as the biggest opportunity for the NSW property industry in the next 12 months?
The continuation of consumer residential demand accompanied by a benign interest rate outlook creates a rare opportunity to increase housing supply.
What do you see as the biggest challenge for the NSW property industry in the next 12 months?
The industry will need to vigorously engage with the Greater Sydney Commission to translate the visions contained in the Draft District Plans into planning instruments that will enable global Sydney to sensibly accommodate the coming growth over the next two decades.
The industry also needs to advocate to ensure the restructure of Local Councils consolidates the ability to deliver density done well, clustered around major transportation nodes. Sadly, for 2017, we foresee a fall in major housing approvals – an unintended consequence of the hiatus caused by the formation of the GSC and the Council amalgamations – the industry requires greater certainty if the upward trend in approvals is to be restored.


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Jack Carney-DeBord
Jack's Law Office
If you recognize that you've got a problem with your videos, you need help now, not later. Over the past 8 years I've had the privilege of having my ideal clients call me after watching my educational videos that have resulted in $8.6 million in settlements.
You know what to do…reach out to me at 516-487-8207. I can fix your video marketing problems.


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For Mother, Prince Charming
Sunday is Mother's Day; what would be the perfect present for a struggling single parent? Joe, a boy of 8 or 9, thinks he knows.
''Joe doesn't have a father, and he thinks a nice gift for his mother would be a prince on a white horse,'' said Dick Feld, a director of Theater Terra, a Dutch troupe that will dramatize Joe's story this weekend at the Brooklyn Academy of Music.
The boy's endearing but misguided quest is at the heart of ''Princess's Soup,'' the latest production in the academy's Family Series. Presented in English, the hourlong play begins on the eve of Joe's mother's birthday, when he is making a shoe box into a toy theater. As he draws pictures and cuts out photographs, he fantasizes about a much more substantial gift for his mother. The audience sees the world of his imagination unfold, with the stage representing the shoe box.
''He fantasizes a little man -- that's me -- and I help him to find the prince,'' Mr. Feld said. Logically, Joe tries the telephone directory.
''There are all these Princes in the phone book, but he just reaches a nasty old man,'' Mr. Feld said. Joe also searches in a shop, a forest and a castle, but comes up empty-handed. Mr. Feld plays all the characters he encounters; Nienke Dijkstra portrays his mother. Joe himself is a whimsical puppet operated by Theo Terra, the troupe's founder.Continue reading the main story
Joe is dejected until he realizes that ''his mother has a prince already, and it's him,'' Mr. Feld said.
Despite this poignant conclusion, Mr. Feld insists that the play isn't delivering a message; it's more a comic fantasy. ''With humor,'' he said, ''you can achieve a lot.''
''Princess's Soup,'' tomorrow at 2 P.M. and Sunday at 3 P.M. at the Academy's Majestic Theater, 651 Fulton Street, Fort Greene, (718) 636-4100. Tickets: $10.
The Junkman Cometh
Donald Knaack is one composer who's quite happy to hear his work called junk. In fact, he says, he's played nothing but junk for years.
A former percussionist with the Louisville Orchestra, Mr. Knaack (pronounced kah-NACK) specializes in making trash sing. He will do it tomorrow at the Kitchen, where he plans to give a concert and workshop using 120 recycled objects, ranging from tin cans and car brake drums to saw blades and window shutters.
''I do a piece called 'Taillight Music,' a solo on just one taillight from a Chevy van,'' Mr. Knaack said. ''It has all the properties of a drum.''
Mr. Knaack, 51, who trademarked the term Junk Music, has even performed the musical equivalent of beating swords into plowshares. Part of his presentation will concern a trip last year to Croatia, where he was invited to make music from the grim debris of war. Using pieces like old shell casings, broken cups and battered fencing, he created an unusual, but not irreverent, requiem.
Mr. Knaack will end the afternoon on a lighter note (or notes) with what he calls ''a junkjam.'' He will pass out ''a whole bunch of junk'' to the children in the audience, who are also invited to take along discards from home. After a series of musical exercises they will create their own impromptu symphony.
''I've found everyone can do this,'' Mr. Knaack said. ''Everyone can have a beat. Some people say, 'I don't have rhythm,' but if they allow themselves to be free in a junkjam, they'll find their own musical space.''
''The Junkman and Junk Music: Kitchen Music and More,'' tomorrow at 2 P.M. at the Kitchen, 512 West 19th Street, Chelsea, (212) 255-5793. Tickets: $5. Reservations advised.
Animal House
Democratic and Republican Presidents have rarely agreed on public issues. But there's one subject that seems to have united many of them: a love of animals.
Witness the photographs and artifacts in ''Presidential Pooches and Pets'' at the Donnell Library Center. Presented by the American Pet Products Manufacturers Association in honor of National Pet Month, the exhibition shows that some of our leaders' biggest supporters could contribute neither votes nor cash. But they did provide unconditional love, something often in short supply around the Oval Office.
The estimated 400 White House pets have ranged from Washington's dog, Vulcan, to President Clinton's Labrador retriever, Buddy, and his cat, Socks. On view are the quilt pattern inspired by Franklin D. Roosevelt's Scottish terrier, Fala, and the sheet music for ''Laddie Boy He's Gone,'' a song for Harding's dog.
''I'm particularly interested in how pets have been politically important,'' said Dr. R. G. Elmore, associate dean of the College of Veterinary Medicine at Kansas State University and the collector who lent about half the items. Included, for instance, is a 1952 New York Post article about the events leading up to the famous ''Checkers speech,'' given by Richard M. Nixon when he was a candidate for Vice President. Accused of operating a campaign slush fund, Nixon invoked Checkers, a cocker spaniel, as an example of a gift he wouldn't return.
Animal fans can also expect a few gifts this month. On May 22 at Pier 25 in TriBeCa, the association will sponsor free checkups for people and pets from 4 to 6 P.M., followed by screenings of films with pet themes.
''Presidential Pooches and Pets,'' through May 28 at the Donnell Library Center, 20 West 53d Street, Manhattan. Monday, Wednesday and Friday, 10 A.M. to 6 P.M.; Tuesday and Thursday, 10 A.M. to 8 P.M.; Saturday, 10 A.M. to 5 P.M.; Sunday, 1 to 5 P.M. Information on the exhibition: (212) 645-6900, ext. 131. Free.Continue reading the main story


text: Here is a gallery of trolls found by FabianBryce!, and BatPeddieSeddieSibuna. Nick Foley was hacking Z!, don't think that Z's a troll.Nick was hacking Z. :/LegomanNPerry being mean to ZWCD is Nick Foley .pngAdd a photo to this gallery Retrieved from "http://houseofanubisbybryce.wikia.com/wiki/Trolls?oldid=8261" Ad blocker interference detected! Wikia is a free-to-use site that makes money from advertising. We have a modified experience for viewers using ad blockers Wikia is not accessible if you've made further modifications. Remove the custom ad blocker rule(s) and the page will load as expected. Categories: Add category Cancel Save


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Working Class Heroes was set up in 2006 with a mission to sell select men's street wear from around the globe to the good people of Ulverston, Cumbria. We still hold this close to our hearts but now aim to reach slightly further a field with our website.
We are not a massive corporate site. We are not owned by a group of executive directors that have little contact with customers. We order stock, photograph it, pack it and then dispatch it. We are here to deal with your enquiries, feedback and provide you with a personal service ensuring that you get the products you want on time every time.
If you call the shop you will speak to Tom, Rob, Adam or Edd. Let us know what you think, because we care!
40-44 Market Street, Cumbria, LA12 7LS
Free Standard UK Delivery
Bringing back in the Gel Lyte 3 for an athletic style amd twist in to the future with the Asics Indian Ink Blue trainers and Red stripes along either side for a snazzy look this season.
Asics Gel Lyte III Shoes Indian Ink Navy Tango Red
When it comes to shoes, Asics are on top form producing trainers which fit all the criteria. Matching up the mental split tongue design, with flat laces that give you a padding and creating a technical design for all. Mixing suede and mesh in the uppers, to drop in the red leather stripes to either side for a new and improved look. Adding to the comfort is the Gel Midsole, while the outsole shows you the grippy tread pattern to head you in the right direction.
Description by Shaznay-nay
First, don't measure your feet in the morning; feet often swell during the day due to heat and activity. For the best fit, measure your feet at the end of the day.
To measure your shoe size follow these instructions:
Place a piece of paper on the floor with one end against a wall. Stand on the piece of paper with your heel against the wall. Mark the piece of paper where your toes end with a pencil. Measure from the end of the piece of paper to the mark you created with your pencil and compare the measurement to our sizing chart.
With Pre-Order, you can purchase the latest items added to our store in advance of them arriving with us.
You Pre-Order is prioritised (at no additional charge); meaning that, as soon as the product arrives with us, we can wrap it straight back up and get it sent out to you - it often never even hits the stock room shelves!
With Pre-Launch, the date when we expect to receive the product ourselves is still a little too hazy to be confident in accepting Pre-Orders.
So, instead, you can submit your email address against the item you are interested in and we will email you as soon as stock arrives on the system.
Estimated Delivery Dates are given on Pre-Order and Pre-Launch products. They are for indication purposes only and can change at any time without notice.
The dates we provide are based on indications given by our suppliers. Whenever we get updated information from our suppliers we will endeavour to update the Estimated Delivery Dates provided on product pages.
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