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Douglas E. Gershuny, Executive Director South Jersey Legal Services, Inc. 745 Market Street Camden, New Jersey 08102 (856)964-2010 Ext. 6907 By: Abigail B. Sullivan, Esq. Attorneys for Defendant/Third Party Plaintiffs, Victor & Enoabasi Ukpe UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY CAMDEN VICINAGE _________________________________________ : BANK OF NEW YORK AS TRUSTEE FOR : THE CERTIFICATE HOLDERS CWABS, INC. : ASSET-BACKED CERTIFICATES, : SERIES 2005-AB3 : : Judge: Hon. Joseph H. Rodriguez, U.S.D.J Plaintiff, : : v. : : VICTOR and ENOABASI UKPE., : CIVIL ACTION NO.: 09-cv-1710 : : Defendants, : _________________________________________ : VICTOR and ENOABASI UKPE : : Counterclaimants : and Third Party Plaintiffs : : v. : Civil Action : BANK OF NEW YORK AS TRUSTEE FOR : THE CERTIFICATE HOLDERS CWABS, INC. : ASSET-BACKED CERTIFICATES, : SERIES 2005-AB3, : Defendant on the Second : Amended Counterclaim, : and : AMERICAS WHOLESALE LENDER; : COUNTRYWIDE HOME LOANS, INC.; : MORGAN FUNDING CORPORATION; :
ROBERT CHILDERS; COUNTRYWIDE : HOME LOANS SERVICING LP, PHELAN : HALLINAN & SCHMIEG , PC : Third Party Defendants on : the Second Amended : Third Party Complaint : __________________________________________ _____________________________________________________________________________ BRIEF OF DEFENDANT/THIRD PARTY PLAINTIFFS VICTOR AND ENOABASI UKPE IN SUPPORT OF MOTION TO REMAND UKPES CAUSE OF ACTION TO STATE COURT _____________________________________________________________________________
Of counsel: James Villere, Jr., Esq. Mark Malone, Esq. Erica Askin, Esq. LAW OFFICE OF JAMES F. VILLERE, JR. 441 Main Street Metuchen, New Jersey 08840 (973) 267-0787
TABLE OF AUTHOTITIES Federal Cases American Fire & Casualty Co. v. Finn, 341 U.S. 6 (1951) .............................. 14, 15 Balazik v. County of Dauphin, 44 F.3d 209 (3rd Cir. 1995) ..................................12 Caterpillar Inc. v. Williams, 482 U.S. 386 (1987)...................................................10 Coleman v. A & D Mach. Co., 298 F. Supp. 234 (E.D. Cal. 1969) ........................15 Collins v. Baxter Healthcare Corp., 949 F. Supp. 1143 (D.N.J. 1996) ...................11 First Nat'l Bank v. Pulaski, 301 F.3d 456 (6th Cir. 2002) .......................................14 FirstBank v. Gittens, 466 F. Supp. 2d 614 (D.Virgin Islands 2006) .................. 9, 11 Kaye Associates v. Bd. of Chosen Freeholders of Gloucester, 757 F. Supp. 486 (D.N.J. 1991)........................................................... 6, 7, 8, 9, 11 Krashna v. Oliver Realty, Inc., 895 F.2d 111 (3d Cir. 1990) ..................................10 Merrell Dow Pharm. Inc. v. Thompson, 478 U.S. 804 (1986) ................................10 Michaels v. New Jersey, 955 F. Supp. 315 (D.N.J. 1996).......................................12 Monmouth-Ocean Collection Serv., Inc. v. Klor, 46 F. Supp. 2d 385(D.N.J. 1999)..................................................................... 9, 11 New Venture Gear, Inc. v. Fonehouse, 982 F. Supp. 892 (N.D.N.Y. 1997).... 14, 15 Palmer v. Univ. of Medicine and Dentistry of N.J., 2009 U.S. Dist. Lexis 25313, 17 (D.N.J. 2009) ............................................ 10. 11 Shamrock Oil & Gas Corp. v. Sheets, 313 U.S. 100 (1941) .....................................7 Somerset Medical Center v. Jewett, 2009 WL 792269 (D.N.J. 2009) ....................11
Soper v. Kahn, 568 F. Supp. 398 (D. Md. 1983).....................................................15 State Farm Indemnity Co. v. Fornaro, 227 F. Supp. 2d 229 (D.N.J. 2002) ............................................................................................ 9, 11, 13 Sun Buick, Inc. v. Saab Cars USA, Inc., 26 F.3d 1259 (3d Cir.1994) ......................7 Syngenta Crop Protection Inc. v. Henson, 537 U.S. 28 (2002).................................7 State Cases Associates Home Equity Services, Inc. v. Troup, 343 N.J. Super. 254 (App Div. 2001)...................................................................13 Federal Statutes 15 U.S.C. 1692....................................................................................................5, 6 28 U.S.C. 1331........................................................................................................7 28 U.S.C. 1441..................................................................................... 1, 6, 7, 9, 10 28 U.S.C. 1441(a) ...............................................................................................7, 8 28 U.S.C. 1441(b) ...................................................................................................8 28 U.S.C. 1441(c) .................................................................................... 7, 8, 9, 14 28 U.S.C. 1446........................................................................................................8 28 U.S.C 1446(a) ............................................................................................ 3, 12 28 U.S.C. 1446(b) ...................................................................................................7 28 U.S.C. 1447(c) .................................................................................................16 42 U.S.C. 3601......................................................................................................13 Other Authorities 1A MOORE'S FEDERAL PRACTICE 0.167[10] (2nd Ed.1990) .........................7
PRELIMINARY STATEMENT The initial pleading in this case was filed on March 13, 2008 in the Superior Court of New Jersey where Plaintiff Bank of New York as Trustee for the Certificate Holders CWABS, Inc. Asset-Backed Certificates, Series 2005-AB3 (hereinafter CWABS Trustee) filed a two-count foreclosure action based entirely on state law claims against the Ukpe Defendants. This residential mortgage
foreclosure complaint and all counter-claims and third-party claims, including those against third party Defendants Americas Wholesale Lender, Countrywide Home Loan Servicing LP, and Countrywide Home Loans, Inc. (collectively the Countrywide Third-Party Defendants) should be remanded to State Court. This foreclosure case is not removable because it does not arise under federal law pursuant to 28 U.S.C. 1441. The well-pleaded complaint rule followed by a majority of the District Courts in this Circuit and elsewhere around the country requires that the federal question be presented on the face of the plaintiffs properly pleaded complaint. After extended motion practice and discovery in the state court civil action, the Ukpe defendants uncovered evidence of the use of fraudulent mortgage assignments in this case and thousands of other foreclosure cases. The Honorable William C. Todd, P.J. Ch., Superior Court of New Jersey, scheduled a plenary
hearing for April 20, 2009 to get to the bottom of the matter. (A copy of Judge Todds March 4, 2009 order is attached as Exhibit A.) On March 30, 2009, the foreclosure Defendants, Mr. and Mrs. Ukpe, submitted a 41-page brief addressing the plenary hearing issues in the state court civil action. (A copy of the brief is attached as Exhibit B.) Plaintiff CWABS Trustees answering brief was due on April 13, 2009. The Countrywide Third Party Defendants filed their removal action on April 9, 2009. The issues in the pending plenary hearing involve matters of great public importance. The Countrywide Third-Party Defendants removal has thwarted the effort to expose and remedy widespread fraud involving thousands of New Jersey mortgage foreclosure cases. In 2008 alone, Third Party Defendant, Phelan Hallinan & Schmieg, P.C. (PHS), handled between 24,000 to 26,000 foreclosure cases in New Jersey and Pennsylvania. (See Certification of Abigail B. Sullivan, Esq. attached as Exhibit O). Defendants respectfully request the Court to remand the matter forthwith. COUNTER-STATEMENT OF PROCEDURAL HISTORY AND FACTS On March 13, 2008, Plaintiff CWABS Trustee filed the initial pleading in this removal matter, a foreclosure complaint in the Chancery Division of the Superior Court of New Jersey, seeking a determination of the amount due on a promissory note executed by Defendants along with possession of the property
securing payment of the note. The foreclosure complaint is based entirely on state law claims. No federal question claims were asserted. (A copy of the March 13, 2008 complaint is attached as Exhibit C.) Seemingly in contravention of 28 U.S.C 1446(a), the Countrywide Third Party Defendants did not include a copy of this initial pleading with their removal notice. Indeed, their procedural history in the notice of removal incorrectly begins on March 11, 2009, nearly a year after the initial foreclosure complaint was filed. They failed to include any relevant pleadings and orders from the state case predating the filing of an amended answer, counterclaim and third-party complaint on March 10, 2009. (Notice of removal, 1.) Through South Jersey Legal Services, Inc., Defendants filed an answer and counterclaim to the foreclosure complaint on April 29, 2008 raising federal question claims against Plaintiff CWABS Trustee. (A copy of the answer and counterclaim is attached as Exhibit D.) By order dated September 30, 2008, the state court granted leave for the Ukpe defendants to file a third-party complaint. (A copy of the September 30, 2008 Order is attached as Exhibit E.) On October 23, 2008, the Ukpes filed a third party complaint against Third Party Defendant Americas Wholesale Lender alleging common law fraud, New Jersey Consumer Fraud Act, negligence and contract claims. Additionally, the third party complaint alleged violations of
federal law involving the Real Estate Settlement Procedures Act, the Fair Housing Act, and the Equal Credit Opportunity Act all arising out of the same common nucleus of facts involving the mortgage loan transaction. (A copy of the October 22, 2008 third party complaint is attached as Exhibit F.) In October 2008, Plaintiff CWABS Trustee moved for summary judgment to strike the Ukpes answer. Judge Todd denied the Plaintiff's summary judgment motion and directed the Ukpes to bring a Motion to Dismiss for lack of jurisdiction pursuant to R. 4:6-2(a). Plaintiff opposed the Ukpes motion and cross-moved for summary judgment. The Ukpes opposed the cross-motion for summary judgment in part based upon deposition testimony showing the assignment of the Ukpes mortgage and note to Plaintiff CWABS Trustee had been falsely notarized. At the hearing on these cross motions, Judge Todd directed that additional discovery be made and set in motion the procedures leading up to the Plenary Hearing scheduled for April 20, 2009. (See Exhibit O, Certification of Abigail B. Sullivan) In a March 4, 2009 Order, Judge Todd directed the Ukpes counsel to file an amended Third Party Complaint by March 10, 2009 and to serve all third party defendants by March 17, 2009. (See Exhibit A) An amended answer,
counterclaim and third party complaint was filed on March 10, 2009. Although this was the fourth pleading filed in the case after (1) the March 13, 2008 complaint, (2) the April 29, 2008 answer and counterclaim, and (3) the October 23,
2008 third party complaint, it is the first pleading attached to the Countrywide Third Party Defendants notice of removal. (A filed copy of the March 10, 2009 amended third party complaint is attached to the Countrywide Third Party Defendants notice of removal as Exhibit G.) On March 20, 2009, the Ukpes counsel filed the fifth pleading in the state court civil action, a second amended answer, counterclaim and third party complaint adding PHS as a third party defendant for violating the Fair Debt Collection Practices Act, 15 U.S.C. 1692 et. seq. (FDCPA). (An unfiled copy of the March 20, 2009 amended answer, counterclaim and third party complaint is also attached to the Countrywide Third Party Defendants notice of removal as Exhibit H.) On March 30, 2009, Defendants filed their brief in connection with the scheduled April 20, 2009 plenary hearing before Judge Todd. In part, Defendants asserted, The evidence will establish a prima facie case that in connection with recording the assignments with county clerks and filing the assignments with the court system, PHS lawyers were involved in: Falsifying or Tampering with Records, N.J.S.A. 2C:21-4a. Tampering with Public Records or Information (Making, Presenting or Filing a False Document, Record or Thing), N.J.S.A. 2C:28-7a(2).
Tampering with Public Records or Information (False Entry or Alteration), N.J.S.A. 2C:28-7a(1). Fraud on the court. Consumer Fraud Act violations. Common law fraud. Violation of the Fair Debt Collection Practices Act, 15 U.S.C. 1692 et. seq. (FDCPA). (See Exhibit B, March 30, 2009 brief, pp. 8-9.) On April 9, 2009, the Countrywide Third Party Defendants removed the entire case from state court. The April 9, 2009 removal occurred almost 13 months after the initial foreclosure pleading was filed. The removal occurred just short of one year after the Ukpe defendants filed an answer and counterclaim against CWABS Trustee asserting federal question claims. LEGAL ARGUMENT I. THE COUNTRYWIDE THIRD-PARTY DEFENDANTS REMOVAL VIOLATES THE WELL-PLEADED COMPLAINT RULE.
The right of defendants to remove state claims to federal court is purely statutory--such that [the Courts] removal jurisdiction exists only when authorized by Congress. Kaye Associates v. Bd. of Chosen Freeholders of Gloucester, 757 F. Supp. 486, 488 (D.N.J. 1991). Courts narrowly construe Section 1441 against
removal. See Shamrock Oil & Gas Corp. v. Sheets, 313 U.S. 100, 108-09 (1941). See also Sun Buick, Inc. v. Saab Cars USA, Inc., 26 F.3d 1259, 1267 (3d Cir.1994), Kaye Associates 757 F. Supp. at 488. The statutory procedures for
removal are to be strictly construed. Syngenta Crop Protection Inc. v. Henson, 537 U.S. 28, 32 (2002). A district court has subject matter jurisdiction to hear claims arising under the Constitution, laws, or treaties of the United States," pursuant to 28 U.S.C. 1331. A defendant may remove a claim brought in state court to federal district court under 28 U.S.C. 1441(a) in cases where the United States district courts have original jurisdiction. If the removed case presents a separate and independent claim or cause of action based on federal question jurisdiction that is joined with one or more otherwise non-removable claims or causes of action, the entire case may be removed and the district court may determine all issues therein, or, in its discretion, may remand all matter in which State law predominates. 28 U.S.C. 1441(c). 28 U.S.C. 1441 et seq. creates a narrow removal jurisdiction for federal courts limited to any civil action brought in a State court of which the district courts of the United States have original jurisdiction, . . . Congress further limited removal jurisdiction in expressly providing: The removal of an action under this subsection [1441] shall be made in accordance with section 1446 of this title, . . . In turn 28 U.S.C. 1446(b) provides: The notice of removal of a civil action or proceeding shall be filed within thirty days after the receipt by the defendant,
through service or otherwise, of a copy of the initial pleading setting forth the claim for relief upon which such action or proceeding is based, . . . . (emphasis added.) The initial pleading in the civil action brought in the Superior Court of New Jersey is the March 13, 2008 foreclosure complaint in which the Ukpes are the only defendants. Only the Ukpes could remove this civil action and only if federal question jurisdiction appeared on the face of CWABS Trustees foreclosure complaint. Congress carved out an additional, narrow removal exception
applicable only to the Ukpe defendants named in the initial pleading. If the case stated by the initial pleading is not removable, a notice of removal may be filed within thirty days after receipt by the defendant, through service or otherwise, of a copy of an amended pleading, motion, order or other paper from which it may first be ascertained that the case is one which is or has become removable, . . . 28 U.S.C. 1446 (b). (emphasis added.) Congress did not confer removal jurisdiction on federal courts for third-party defendants. [T]hird-party defendants are not proper parties for removal because they are not 'defendants' under 1441(a) and/or because 1441(c) only applies to claims joined by plaintiffs." Kaye Associates v. Board of Chosen Freeholders, 757 F. Supp. 486, 487 (D.N.J.1991) (citing 1A MOORE'S FEDERAL PRACTICE 0.167[10] (2nd Ed.1990). The Kaye court reasoned that the legislative history of the statute shows that the section was not intended to extend the right of removal to
third-party defendants. Id. at 489 ("Looking at that legislative history, it seems clear that the intent of 1441(c) was to ensure that the plaintiff cannot preclude the right to remove a removable claim through the device of joining a wholly separate and independent non-removable claim.") (internal quotations and citation omitted). The Kaye court held "[g]iven that intent, the policy of strict construction of removal statutes, and the apparent conflict with other well-established principles of removal, we cannot conclude, without more express guidance from Congress, that section (c) [of 28 U.S.C. 1441] was intended also to expand removal jurisdiction by allowing removal by third-party defendants." Kaye Assocs., 757 F.Supp. at 489. Accordingly, the majority of courts within this District apply the wellpleaded complaint rule only to the initial pleadings of the original plaintiff and thus disallow third party defendants to remove state claims to federal court. See e.g., State Farm Indemnity Co. v. Fornaro, 227 F. Supp. 2d 229 (D.N.J. 2002); FirstBank v. Gittens, 466 F. Supp. 2d 614 (D.V.I. 2006); Monmouth-Ocean Collection Serv., Inc. v. Klor, 46 F. Supp. 2d 385, 393 (D.N.J. 1999); The minority rule allows third party defendants to remove but only if the claims against them are separate and independent from the main cause of action. In order for a case to be removable under 1441 and 1331, the wellpleaded complaint rule requires that the federal question be properly presented on the face of the plaintiffs properly pleaded complaint." Krashna v. Oliver Realty,
Inc., 895 F.2d 111, 113 (3d Cir. 1990) (quoting Railway Labor Executives Ass'n v. Pittsburgh & L.E. R.R., 858 F.2d 936, 939 (3d Cir. 1988)). See Palmer v. Univ. of Medicine and Dentistry of N.J., 2009 U.S. Dist. Lexis 25313, 17 (D.N.J. 2009) (quoting Caterpillar Inc. v. Williams, 482 U.S. 386, 392, 107 (1987)). In Palmer v. Univ. of Medicine and Dentistry of N.J., supra, the court held that a cross-claim could not serve as the basis for arising under jurisdiction pursuant to Section 1441 even when the defendants cross-claim raised a federal constitutional question. See 2009 U.S. Dist. Lexis 25313, 17, 25-27 (D.N.J. 2009). Under the well-pleaded complaint rule as applied in Palmer, the defendants federal First Amendment claim was insufficient for arising under jurisdiction when the plaintiffs original claims arose under New Jerseys Conscientious Employee Protection Act (CEPA) and common law claims for slander, intentional infliction of emotional distress, and intentional interference with prospective economic advantage. Id. at 25-26. Declining to expand the wellpleaded complaint rule to cross-claims, the Palmer court emphasized that the mere presence of a federal issue in a state cause of action does not automatically confer federal-question jurisdiction." Id. at 26 (quoting Merrell Dow Pharm. Inc. v. Thompson, 478 U.S. 804, 813-14 (1986)). The courts decision in Palmer followed the weight of authority in thirdparty defendant removal cases within this circuit holding that removal is reserved
solely for the original defendant except in the limited circumstance of a third-party defendant removing a state claim preempted by the federal Employee Retirement Income Security Act (ERISA). See 2009 U.S. Dist. Lexis 25313 at 16. See e.g., State Farm Indemnity Co. v. Fornaro, 227 F. Supp. 2d 229 (D.N.J. 2002); FirstBank v. Gittens, 466 F. Supp. 2d 614 (D. Virgin Islands 2006); MonmouthOcean Collection Serv., Inc. v. Klor, 46 F. Supp. 2d 385, 388-89 (D.N.J. 1999) (adopting the Magistrate Judges report asserting the majority view that a thirdparty defendant may not remove under 1441); Kaye Associates, 757 F. Supp. at 487-89 (D.N.J. 1991) (concluding that the better reasoned view is that third-party defendants do not have the right to remove cases to federal courts under section 1441). See also Collins v. Baxter Healthcare Corp., 949 F. Supp. 1143 (D.N.J. 1996), for an opinion by Judge Rodriguez remanding the case to state court under the well-pleaded complaint rule because removal was not based upon federal claims within the plaintiffs original pleadings and because the case did not properly come within federal jurisdiction by complete preemption. The most recent discussion on the issue in this District is found in Chief Judge Browns unpublished opinion in Somerset Medical Center v. Jewett, et al., 2009 WL 792269 (D.N.J. 2009) After an extensive discussion of the majority and minority rules, the Court decided that removal was inappropriate under either rule. Under the majority rule, a third-party defendant is not empowered to remove.
Under the minority rule, the third-party defendant could not remove because the indemnification claim against it was not a separate and independent claim. (Slip op. p. 4.) (A copy of the decision is attached as Exhibit P.) Application of the well-pleaded complaint rule to the present removal action means the removal must be denied. The initial state-court mortgage foreclosure complaint by Plaintiff CWABS Trustee against the Ukpe defendants Ukpes was purely a state law claim based on an alleged failure to pay a promissory note secured by a mortgage on real property. No federal question claims are present. Finally, the Ukpe defendants have never sought removal and they never consented to the removal in this case. Judicial construction of the phrase in 28 U.S.C. 1446(a) "defendant or defendants" has given rise to the "well-settled rule of law - commonly known as the `rule of unanimity' - that all defendants must join in or consent to the removal petition." Michaels v. New Jersey, 955 F. Supp. 315, 319 (D.N.J. 1996) (citing Balazik v. County of Dauphin, 44 F.3d 209, 213 (3rd Cir. 1995) (other citations omitted)). II. THE UKPES CLAIMS AGAINST THE COUNTRYWIDE THIRD-PARTY DEFENDANTS ARE NOT SEPARATE AND INDEPENDENT FROM THE CWABS TRUSTEES CLAIMS.
The third-party defendants cannot remove under the majority view of the well-pleaded complaint rule. Even if this Court adopts the minority view, then the Countrywide Third-Party Defendants failed to meet their burden of showing that
the allegations of the Ukpe Defendants regarding the fraudulent origination of the mortgage are separate and independent from the action to foreclose. In interpreting the scope of their removal jurisdiction, courts adopting the minority rule within this District disallow third party defendants to remove state claims to federal court unless the claims against them are separate and independent from the main cause of action. See e.g., State Farm Indemnity Co. v. Fornaro, 227 F. Supp. 2d 229 (D.N.J. 2002). The Countrywide Third-Party
Defendants fail to show how the allegations of the Ukpe Defendants regarding the fraudulent origination of the mortgage are separate and independent from the action to foreclose. In Associates Home Equity Services, Inc. v. Troup, 343 N.J. Super. 254 (App. Div. 2001), the New Jersey Appellate Division ruled that predatory lending counterclaims and third-party claimswhich included federal discrimination housing claims under Title VIII of the Fair Housing Act, 42 U.S.C. 3601 et seq. are germane in state foreclosure actions. The Ukpes two Fair Housing Act (FHA) and Equal Credit Opportunity Act (ECOA) claims are set among eight other state consumer fraud and contractual issues that render the entire case a state controversy over CWABS Trustees right to foreclose as an assignee of the Countrywide Third-Party Defendants Americas Wholesale Lender.
The Ukpes FHA and ECOA third-party claims cannot be used by the Countrywide Third-Party Defendants to bring this foreclosure action, strongly rooted in New Jerseys property, contract, and consumer law, into federal court. The Supreme Court held that claims are not separate and independent where there is a single wrong to plaintiff, for which relief is sought, arising from an interlocked series of transactions. American Fire & Casualty Co. v. Finn, 341 U.S. 6, 14, 71 S. Ct. 534, 540, 95 L. Ed. 702 (1951). If the non-removable claim is derived from the same set of facts as the main cause of action, it is not a separate and independent claim under Section 1441(c). See New Venture Gear, Inc. v. Fonehouse, 982 F. Supp. 892, 893 (N.D.N.Y. 1997). It is well-recognized that claims by third-party defendants are rarely separate and independent from the main cause of action in removal cases. See First Natl Bank v. Pulaski, 301 F.3d 456, 465 (6th Cir. 2002). As the Sixth Circuit Court of Appeals stated, even in the courts holding that 1441(c) permits third-party defendants to remove to federal court, as a general proposition, those courts have often held that the third-party claims at issue did not satisfy the "separate and independent" requirement of 1441(c). Id. See also New Venture Gear, Inc. v. Fonehouse, 982 F. Supp. 892, 893 (N.D.N.Y. 1997) (holding that "a third-party claim cannot be 'separate and independent' if it is substantially derived from the same set of facts, or if it is contingent in some way on the plaintiff's non-removable
claim"); Soper v. Kahn, 568 F. Supp. 398, 405 (D. Md. 1983) (holding that thirdparty claim for indemnity, under state law, was not "separate and independent" under 1441(c)); Coleman v. A & D Mach. Co., 298 F. Supp. 234, 237 & n.9 (E.D. Cal. 1969) (holding that removal was improper because the third-party claim was not separate and independent.) Following the Supreme Courts standard in American Fire & Cas. Ins. Co. v. Finn, 341 U.S. 6, 14 (1951), the Plaintiff CWABS Trustee asserted a single wrong of nonpayment of the mortgage loan, which the Ukpes allege arises from an interlocked series of transactions, beginning with the discriminatory subprime mortgage given by the Countrywide Third-Party Defendants. Contrary to the Countrywide Third-Party Defendants contention that the collection rights under the mortgage are separate and independent from the origination and set-up of the Ukpes loan (Notice of Removal 7), the collection rights under the mortgage are derived from the same set of facts controlling the discriminatory and predatory origination of the mortgage loan. New Venture Gear, Inc. v. Fonehouse, 982 F. Supp. 892, 893 (N.D.N.Y. 1997). III. THE UKPE DEFENDANTS REQUEST REMAND OF THE ENTIRE CASE BECAUSE NEW JERSEY STATE LAW PREDOMINATES ALL MATTERS INVOLVED.
Even if this Court elects to follow the minority rule, Defendants respectfully request the Court to remand the entire matter forthwith. The litigation has been
going on for over a year and involves a foreclosure action by a securitized trust created by the Countrywide Third Party Defendants. Evidence of the use of
fraudulent assignments in the case and thousands of other cases led the Superior Court of New Jersey to schedule a plenary hearing to get to the bottom of the matter. Removal of the claims would frustrate efforts to expose and remedy widespread fraud involving thousands of mortgage foreclosure cases in New Jersey. IV. THE UKPE DEFENDANTS REQUEST THE COURT TO AWARD ATTORNEY FEES AND COSTS An order remanding the case may require payment of just costs and any actual expenses, including attorney fees, incurred as a result of the removal. 28 U.S.C. 1447(c). An award of counsel fees is appropriate because the Countrywide Third-Party Defendants removal action did not comply with the removal statutes mandate to include the initial pleading. The initial pleading reveals on the face of the complaint that the matter is not removable if this Court follows the majority rule. In addition, the Countrywide Third-Party Defendants electronically filed their removal notice with this Court on April 9, 2009, they hand-delivered it to the state court on April 9, 2009, but sent it by regular mail to the Ukpe Defendants so their counsel did not receive it until April 13, 2009. Because their counsel did not receive timely notice of the removal, the Ukpes
counsel continued to work through the Easter holiday weekend in preparation for the plenary hearing before Judge Todd. Accordingly, an award of attorney fees is appropriate not just for removal work, but also for the work that was done preparing for April 20, 2009 plenary hearing in state court because counsel did not receive prompt and appropriate notice of the removal action. South Jersey Legal Services, Inc. (SJLS) through its counsel Abigail B. Sullivan, Esq., is not requesting attorney fees and will not be sharing in any fees awarded as it is a recipient of Legal Services Corporation funds and is therefore prohibited from requesting and receiving attorney fees. Co-
counsel James F. Viller Jr., Esq., and Mark J. Malone, Esq., and Erica B. Askin, Esq., from the Law Offices of James Viller, Jr. are not so prohibited. SJLS, in addition, is not prohibited from requesting and receiving costs incurred. CONCLUSION For the foregoing reasons, the Court should remand the matter to the state court forthwith. Dated: April 24, 2009 Respectfully submitted, SOUTH JERSEY LEGAL SERVICES, INC. Attorney for Defendants/Third Party Plaintiffs By: /s/ Abigail B. Sullivan, Esquire ABIGAIL B. SULLIVAN, ESQUIRE
On the brief: James F. Viller Jr., Esq. Mark J. Malone, Esq. Erica B. Askin, Esq. Abigail B. Sullivan, Esq.


text:
Update to v104r13 release.
byuu says: Changelog: - nall/GNUmakefile: build=release changed to -O2, build=optimize is now -O3 - hiro: added Monitor::dpi(uint index) → Position [returns logical DPI for x, y] - Position is a bad name, but dpi(monitor).(x,y)() make more sense than .(width,height)() - hiro: Position, Size, Geometry, Font changed from using signed int to float - hiro: Alignment changed from using double to float - hiro: added skeleton (unused) Application::scale(), setScale() functions Errata: - hiro/cocoa's Monitor::dpi() is untested. Probably will cause issues with macOS' automatic scaling. - hiro/gtk lacks a way to get both per-monitor and per-axis (x,y) DPI scaling - hiro/qt lacks a way to get per-monitor DPI scaling (Qt 5.x has this, but I still use Qt 4.x) - and just to get global DPI, hiro/qt's DPI retrieval has to use undocumented functions ... fun The goal with this WIP was basically to prepare hiro for potential automatic scaling. It'll be extremely difficult, but I'm convinced that it must be possible if macOS can do it. By moving from signed integers to floats for coordinates, we can now scale and unscale without losing precision. That of course isn't the hard part, though. The hard part is where and how to do the scaling. In the ideal application, hiro/core and hiro/extension will handle 100% of this, and the per-platform hiro/(cocoa,gtk,qt,windows) will not be aware of what's going on, but ... to even make that possible, things will need to change in every per-platform core, eg the per-platform code will have to call a core function to change geometry, which will know about the scaling and unscale the values back down again. Gonna be a lot of work, but ... it's a start.
parent 2e4cd098
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subset: commoncrawl


text:
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As long as there is still the written word, there will always be editors. Freelance editing and proofreading not only pays a decent hourly wage, it also gives you the chance to read about potentially interesting topics too. What's more, pursuing freelance writing & editing as a business idea can afford you a lifestyle that lets you travel the world as a digital nomad. You can find lots of job postings from companies and individuals in need of writing, proofreading, and editing services on Contena, which makes this a high-demand opportunity to make money online.
When there are multiple affiliates involved in one transaction, payment gets much more complicated. Sometimes it's even possible for affiliates to jump in at the last minute and claim commissions for customers brought in by other affiliates. Successful programs use multi-channel attribution to ensure the affiliates that create the most value get paid the most.
My 10-year-old son brought home a book from our park's free library box. It was a biology textbook – teachers edition. He said it looked interesting and hey, it was free (having no idea you could sell it). I scanned it in my Amazon seller app and realized it was worth around $150. He was so excited. We listed it for sale for $130 and it sold! Going to tell him, he just made $130!
Starting a podcast, like making a YouTube channel or blog, comes down to telling interesting stories and building an engaged audience. I'm probably sounding like a broken record by now, but you need a niche that you're interested in and there's already a demand for. Come up with a list of topics you'd like to talk about and then search iTunes charts, Google Trends and other podcast research sites like cast.market to see what's currently out there and popular.
Creating and selling courses on your blog can be a successful way to make money online. The course itself should be relevant to your blog, and based on a topic that will benefit your audience. Although it may take time to create the course in the first instance, once completed, you can then repeatedly make money from the course each time you sell it.
When promoting a product, you are also promoting the person or organization that owns the product. This should be the first thing to know before selecting the product you are promoting. You surely don't want your clients to be unhappy after purchasing the product. Trust me; they will never come back to your site again to purchase anything! This is because you have dented your credibility. Normally, any company or website with good customer service is bound to have happy customers.
Merchants receiving a large percentage of their revenue from the affiliate channel can become reliant on their affiliate partners. This can lead to affiliate marketers leveraging their important status to receive higher commissions and better deals with their advertisers. Whether it's CPA, CPL, or CPC commission structures, there are a lot of high paying affiliate programs and affiliate marketers are in the driver's seat.
A: No. Unlike some other affiliate networks, ClickBank is the retailer in the transaction and is responsible for tracking and paying commissions, so vendors cannot attempt to avoid paying commission on a sale. If a vendor requests a refund on a sale, they lose their portion of the sale as well, so there is no incentive for them to pretend that a sale has been refunded.
VIPKID provides an international learning experience to children in China between the ages 4-12. Headquartered in Beijing, the company offers fully immersive one-on-one English language instruction provided online by highly qualified teachers. The curriculum is based on the U.S. Common Core State Standards and uses a flipped-classroom approach to foster creativity and critical thinking skills.
I never advocate relying on affiliate income as your only form of revenue, or starting a blog with affiliate sales as your only monetizing strategy, because for most bloggers it amounts only to pennies, maybe dollars, and even that isn't consistent. Sure, you might earn a few bucks here and there or a credit to put toward a service you use regularly. While every dollar's welcome, of course, and this type of affiliate earnings can supplement other income, it's not enough to support a family.
It's important to know where your traffic is coming from and the demographics of your audience. This will allow you to customize your messaging so that you can provide the best affiliate product recommendations. You shouldn't just focus on the vertical you're in, but on the traffic sources and audience that's visiting your site. Traffic sources may include organic, paid, social media, referral, display, email, or direct traffic. You can view traffic source data in Google Analytics to view things such as time on page, bounce rate, geo location, age, gender, time of day, devices (mobile vs. desktop), and more so that you can focus your effort on the highest converting traffic. This analytics data is crucial to making informed decisions, increasing your conversion rates, and making more affiliate sales.
There is no shortage of products you'll be able to promote. You'll have the ability to pick and choose products that you personally believe in, so make sure that your campaigns center around truly valuable products that consumers will enjoy. You'll achieve an impressive conversion rate while simultaneously establishing the reliability of your personal brand.
Affiliates were among the earliest adopters of pay per click advertising when the first pay-per-click search engines emerged during the end of the 1990s. Later in 2000 Google launched its pay per click service, Google AdWords, which is responsible for the widespread use and acceptance of pay per click as an advertising channel. An increasing number of merchants engaged in pay per click advertising, either directly or via a search marketing agency, and realized that this space was already occupied by their affiliates. Although this situation alone created advertising channel conflicts and debates between advertisers and affiliates, the largest issue concerned affiliates bidding on advertisers names, brands, and trademarks.[39] Several advertisers began to adjust their affiliate program terms to prohibit their affiliates from bidding on those type of keywords. Some advertisers, however, did and still do embrace this behavior, going so far as to allow, or even encourage, affiliates to bid on any term, including the advertiser's trademarks.
2. How do you go about looking for expired domains for your PBN? I've tried Jon Haver's system but the searching part takes quite a bit of time with not too much to show. I think I've tried doing it like for a couple of hours all I found was 2 or 3 domains that had PA of around mid 20s or so. Nothing great.Wondering if you've found a more efficient way.
That being said, I want to give you an idea of what I earn, so you can see what's possible. I don't like to "show off", but here's income proof. These screenshots prove that yes, I actually make money online. I've been making over $10,000 per month for many years now. You'll have to make your first dollar before you earn ten thousand though, so keep reading below to see how you can get started doing the same type of business I do.
That being said, you are free to move your website to a new host. You still own all that material! Most hosts do not provide affiliate training though, so you'll need to browse blogs and websites to get the necessary information on how to build your website. My blog has hundreds of pages solely dedicated to teaching you how to build a business online.
hey sean, am a newbie who is so ethusistic about online marketing. great post , i must commend , it came in handy. through your post i clearly understand that an affiliate mustr have a website and a blog as a platform for promoting the good and services. here the thing with me , i dont have either of them and am asking ….. is it advisable for me to delve in affilate marketing peradventure i get a blog running now …?
If you want to clear some space out in your house and have a big stack of books you've been holding onto for too long, you can make money selling your books and textbooks online. Stores like Half Priced Books and others will give you cents on the dollar for each of your current books while you can check what your book is worth by simply entering the ISBN number on Book Scouter.
Great article as it gets me thinking about the various ways to monetize my sites. With that said, my biggest hurdle has been how to get started building traffic. You see articles all over the net talking about massive traffic techniques, but I've never really found a guide for a fresh blog/website and how to get to their first 100, 500, or 1,000 daily uniques. Of course writing consistent quality content is key, but writing alone an audience does not make. Any tips or articles to point us to? Thanks again Sean!
This is similar in concept to micro-tasks, except that it is oriented toward specific services, such as cleaning services, pest inspection, handyman services, house cleaning, lawn & garden services or any of the skilled trades. It might actually be more accurate to say that it is a platform where skilled service providers can offer their services to site visitors, similar to Angie's List.
The link building was a critical step. It was time consuming. I followed the standard plan you see in several other blogs (like Niche Pursuits) with tiered linking structures. In general, you could categorize the links as social profiles, web 2.0 free blogs, and article directories. I also purchased a few fiverr gigs to point to the first tier of links, not the niche site (the money site).
Affiliate marketing overlaps with other Internet marketing methods to some degree, because affiliates often use regular advertising methods. Those methods include organic search engine optimization (SEO), paid search engine marketing (PPC – Pay Per Click), e-mail marketing, content marketing, and (in some sense) display advertising. On the other hand, affiliates sometimes use less orthodox techniques, such as publishing reviews of products or services offered by a partner.[citation needed]


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To evaluate the feasibility and effect of a 10-session creative arts in psychotherapy group programme on posttraumatic stress symptoms, behavioural problems, and posttraumatic growth, in children who experienced a traumatic event.
A multicentre non-randomized controlled trial with a treatment and a control condition conducted in South Africa (4 sites).
The nature of conflict has changed, putting children in the frontline in new and terrible ways. Wars are lasting longer. They are more likely to be fought in urban areas amongst civilian populations leading to deaths and life-changing injuries, and laying waste to the infrastructure needed to guarantee access to food and water. Attacks on schools and hospitals are up. The denial of humanitarian aid is used as yet another weapon of war. The international rules and basic standards of conduct that exist to protect civilians in conflict are being flouted with impunity.
This article describes the development of a group-based therapeutic intervention for young people (YP) who have lived with domestic violence and abuse. The intervention was informed by interviews with 107 YP, focused on their experiences of coping, resilience and agency. The intervention draws on resources from systemic, creative and narrative approaches to group work, and aims to facilitate YP's expression of distress in a way that recognizes that it is embodied, contextual and relational.
The hypothesis of secondary traumatization argues that children raised by parents who were traumatized by war, have more mental health problems than other children. Past evidence for this hypothesis is not consistent.
By learning to identify feelings and express emotions, children can better cope with the difficulties they face, as well as increase their personal resilience. As the Syrian crisis has entered its seventh year, it has had a negative effect on vulnerable populations, especially children. It should be noted that while not all children have been traumatised, many have experienced conflict and crisis, and in turn face challenges expressing and regulating their emotions and behaviour.
As a consequence of prolonged exposure to the high levels of cumulative trauma such as war, gross human rights violations and traumatic loss, refugee adolescents are at significant risk of developing psychological and behavioural complications. During resettlement in Australia, they are often faced with social challenges. It is vital to provide support at this vulnerable stage to reduce future setbacks.
Worldwide, many migrants leave their countries in search of safety and international protection. In 2015, the number of asylum seekers in Europe reached a peak. Among them were unaccompanied minor asylum seekers (UMAs). The current study aimed to investigate how and why UMAs who sought protection in the Netherlands during that year, ended up here.
Child maltreatment (CM) is highly prevalent and one of the most injurious conditions that children may experience. Because it is often-clandestine, it is difficult to assure that existing prevention and treatment mechanisms reach those in need. CM's consequences may take a long time to be recognized and expressed. We discuss the need to increase public health actions when the person reaches adulthood to mitigate the consequences of CM.
The number of children affected by natural disasters each year is alarmingly high and can be expected to rise as climate change continues. The mental consequences have been documented not only in the rates of post-traumatic stress symptoms and post-traumatic stress disorder, but also for depression and other mental health problems.


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Why we need to get started in business [Adam Franklin video #1]
Here are 2 high levels 'take aways' from my two days in Melbourne for my marketing coaching mastermind (Taki Moore's Black Belt).
These insights were from Ed Dale's "belt breakout session".
1. You only need to be right once in business.
2. 94% of successful people found success in an area different to what they started in.
Good day it's Adam Franklin. I just wanted to share two high level insights that I got from the last two days working on the business, with my business partner Tobes down at a mastermind in Melbourne. First, at a high level, insight was you only need to be right once in business. Despite what we're taught at school to always pass and never fail, in business most of what we do, a lot of what we do is going to be failing and working at what doesn't work, and learning from that, and refining that. Then finding the thing that does work, and then you're sweet.
Part of that too is … Or, the second component, which is another insight was — I think it was essentially a Nobel prize study, or something that surveyed all these successful people, and they asked them "Is what your successful in now what you started out in?" And 94% of people said no. Which means, the moral of that story, in my mind, is just get started in something. There's a very high chance it's not going to be what you end up being successful in, but you need to start!
- For all my videos, join my Facebook page https://www.facebook.com/BluewireMedia/
- For more videos and tip, let's connect on LinkedIn: https://www.linkedin.com/in/adamfranklin
- Or subscribe via my website and download my popular Web Strategy Planning Template. https://www.bluewiremedia.com.au/
- The 6 to 7 Figures Show – Episode 021: Adam Franklin – Jul 4, 2019
- Don't create a marketing prison [#76] – Jun 12, 2019
Content Marketing Sales Funnel
Your content marketing sales funnel is all about getting people to know, like and trust you by nurturing them with the right information at the right time.


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Jon Jones Reveals What Alexander Gustafsson Taught Him In Their First Fight • MMA News
Jon Jones believes a lesson was realized after his first struggle with Alexander Gustafsson.
Jones is ready to do battle with Gustafsson a second time on Dec. 29. The 2 will collide contained in the T-Cell Enviornment in Las Vegas, Nevada in the principle occasion of UFC 232. The UFC mild heavyweight title can be on the road. Two-division champion Daniel Cormier will vacate his 205-pound gold as soon as Jones vs. Gustafsson II begins.
Jon Jones Talks Lesson Discovered In First Encounter With "The Mauler"
Jones just lately appeared on the UFC Unfiltered podcast. "Bones" revealed what Gustafsson taught him within the first struggle (by way of MMAMania.com):
"I was getting used to people saying things like, 'He is a lot like Jon Jones with better hands and better footwork.' Everybody was saying he was a Swedish version of me. In my head, I was thinking he's tall, has a presence about him, but he is not me. There is only one me, and it was almost an arrogance that I had. I was feeling like I was a product and he was a knockoff version of me. What he showed me was, hard work can beat talent when talent isn't working hard. And that is such a true thing. I know I wasn't doing the right things. I was in the heyday of my partying. Now I know what he is capable of and I will treat him as such. I will train for him like it is supposed to be."
Do you assume Jon Jones is really taking issues extra severely this time?


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What an amazing time of year: both the farmer's markets and our home gardens are popping with amazing, fresh and flavorful veggies!
Today's fresh & easy Strawberry Spinach Salad recipe, as perfected by chef Staci Bronson in our very own BITW test kitchen, combines many of those in-season options into a delicious salad, perfect for lunch or dinner on a hot summer day.
Strawberry Spinach Salad
Options, to taste:
BBQ, slow cook, or pan grill your protein of choice. (I love bacon and chick thighs)
While cooking, toss spinach into a bowl and dice up strawberries, cukes and tomatoes.
Top with almonds and cheese.
Allow the protein to cool, or throw it on warm.
Finish with dressing or balsamic vinegar and olive oil.
Up the carb ante with some toasted baguette dipped in balsamic.
~ chef Staci
This week's #workoutwednesday comes from Race Director and Coach, Blair Bronson.
Grab your bike and take to the hills this week with an over/under threshold workout for race simulation efforts. This workout can be done once through, multiple times through, or as a pyramid.
Working the hills for race simulation efforts.
Warm Up:
-15 minutes easy riding
-5x30 second spin-ups with 30 second recover: In an easy gear, gradually spin your legs from a normal cadence to about 120 rpm. Remain seated and focus on smooth rotations. If you feel yourself start to bounce on the seat at a higher rpm, engage your core more.
-5x30 second build with 60 second recovery: Build from slightly over your warm-up pace to just shy of an all-out sprint gradually over the course of the 30 seconds. The minute recover is done very easy with a slightly high cadence.
-Spend a few minutes to get to the base of your favorite (or least favorite) hill. Preferably one that takes you at least 5 minutes to climb.
Main Set: Race pace climbing with over threshold efforts
If you aren't sure what your threshold is, use your race pace to guide your effort. The "overs" are harder than race pace for the distance you are doing. You should only be able to sustain the "over" pace for a couple of minutes at most.
The main set of this workout can be adapted for the athlete and the race distance by adjusting the duration of the interval, the number of intervals and the intensity of the interval. For this example, we are going to assume the climb takes about 5 minutes to complete. If pacing correctly you should get faster from Climb 1-3.
The focus of this workout is to be able to settle back into race pace after an extra effort is required. When settling back into your race pace see how quickly you can relax and try and bring your heart rate down.
Climb 1:
-2min race pace (RP), 30 seconds over threshold (Over), 2min race pace, 30 seconds over
-Descend and recover for 3-5minutes
Climb 2:
-90sec RP, 30 seconds Over, 90sec RP, 30sec Over, ~60sec RP or until you reach the top
-Descend and recover for 4-6 minutes
Climb 3:
-60sec RP, 30sec Over x however long until you reach the top.
-Descend and recover for 5-7 minutes.
Depending on fitness and training level repeat or use as a pyramid. Those training for a sprint race might do fewer repeats, but the level of race pace effort should be much higher.
Cool Down: ~15 minutes easy riding with a focus on good form and smooth pedal strokes.
Now saddle-up & get after it; we'll see ya out there!
~ Coach Blair
Fuel Up Friday: Beer Banana Bread
Have 3 bananas and some beer?
Let's make beer banana bread!
Any beer will work, pick your favorite; same for the bananas. Bonus- the recipe only calls for 4 oz of beer, so you can enjoy the rest while you bake! This recipe perfected in our very own BITW HQ kitchen lab, by our very own chef Staci Bronson. So let's get into some yummy baking..
Beer Banana Bread
Pre-heat the oven to 350°F
Mix together dry ingredients
1 ¾ cup flour
¾ cup sugar
1 ¼ tsp baking powder
½ tsp baking soda
¾ tsp salt
1 tbsp cinnamon
½ cup chopped walnuts (optional)
Mix together wet ingredients
3 mashed bananas
1/3 cup melted butter
½ cup beer of choice - I used Block15 Gloria!
Add the dry ingredients to the wet ingredients
Drink the rest of the beer
Grease (butter or oil) and flour a 9"x5" loaf pan then pour it all in.
Sprinkle the top with brown sugar
Bake for 55 minutes - check it at 50 minutes with a tooth pick. It should come out clean. Bake times will depend on how hot your oven cooks.
Now, try to make it last 24 hours… good luck!
This week's S W I M workout comes from Best In The West's very own RD, Staci Bronson.
Speed in the water doesn't always come from yards upon yards. Technique is paramount to a smooth, effortless stroke. The less bubbles, splashing and the more you can focus your power on forward motion, the faster you'll become - even at the same level of fitness.
Today we bring you a swim workout that has a lot of drills mixed in. Doing drills throughout one of your swim workouts each week can help maintain your form, even at the end of a swim when you are starting to get tired.
This workout will take you longer than the same distance on a speed work day because drills aren't fast. Focus on excellent form and using the drill to help improve your arm/leg/head position and not on how fast you do a lap. With that, there are no sendoff times or goal times.
This week, we will focus on your stroke and leave the kick out of it. If you have a pull buoy handy, this will help keep you streamline (your legs up) while allowing you to focus on your arms.
Warm Up
200 yards normal swim.
100 yards fast - work out the kinks
Main Set
5x 200 yards - 50 drill, 50 focus
(For a longer workout, 2 x through)
Each 200, choose one drill. During the drill 50, try to get the drill perfect. Don't go for speed. On the next 50, go back to a normal swim speed but focus on the part the drill was trying to correct. Return to the drill and repeat. Then move on to the next drill.
Drill 1 - Catch Up
This one is for glide. Leave your arm out and gliding until your other arm comes around and enters the water. Before initiating the pull, both arms should be out in front of you.
Drill 2 - Eyes up entry
Look up. Look at your hand entering the water, look at where it enters and where it is going. Crossing over - Does your hand cross the center line? It shouldn't. If you see it crossing over, try to correct and get it to make a straight line from point of entry to the wall in front of you. Crossing over slows you down. Depth - Does it stay at the top of the water? Does it go all the way down below you? The ideal depth is right around one foot to 18".
Drill 3 - Bubble Free Entry
Try to get your hand and arm in the water without any bubbles. This one is for a smooth entry. Lift your head position slightly and watch your hand come in the water. If you do get bubbles, glide them away before starting your other hand. You can image there is a circle about a foot from the top of your head that you have to slide your entire hand and arm through in order to get in free of bubbles.
Drill 4 - Wrist, Elbow, Pull
Segmented stroke. Many people have a straight arm stroke. For this drill, we really segment the stroke to try and get you to a better arm position. Start at the pool edge. Place your hands on the gutter and push yourself up out of the pool. Notice where you put your hands for the most strength. Notice the bend in your elbows. This is a similar position to what we want underwater. You want to push the water back behind you. At the end of the glide, bend your wrist. Get it to 90°. Next, bend your elbow. Get it to 90°. Now start your pull and keep your forearm and hand parallel to the back wall until your hip. Bring it around and then start the other side. When you first try this drill, there can be some sinking. Grab a pull buoy so you can go nice and slow. Your wrist starts at 90° flexed but ends completely extended if you are keeping that hand parallel to the wall all the way through.
Drill 5 - Fist Swimming
Close your hand into a fist, nice and tight. Swimming without the surface area of your hand will force you to use your forearm to move forward in the water. Turns out, your forearm has a lot more surface area than your hand. Remember to get a good 90° elbow bend like you just practiced with drill 4.
There are many more drills you can incorporate into your routine, have a look online for more.
100 yards fast - try to un-segment and swim with great form.
Cool Down
100-200 easy with EXCELLENT form.
Keller, one of the youngest in the junior category, placed 17th overall at USAT junior nationals!! He is 15, USAT age 16, racing in the 16-19 age group.
The Core Strength Training program shown below is what I have personally been doing for my triathlon weight training for the past 10 years. The exercises shown work on developing your core muscles. The training is broken into 4 segments that are done over a 6 month training cycle. Find a gym with an adjustable cable weight machine and follow the descriptions and photos for your Core Strength Training Program.
6 weeks - 2 x per week
light weight
20-30 reps
1st wk - 1 set
2nd wk - 2 sets
3rd - 6th wk - 3 sets
30 sec rest betw sets
6 weeks - 2 x per week
increase weights per set
3 sets
set 1 - 15 reps
set 2 - 12 reps
set 3 - 8 reps (to exhaustion)
90 - 120 sec rest betw sets
8 weeks - 2 x per week
moderate weights
3 sets
15 reps
30 - 45 sec rest betw sets
6 weeks - 1 x per week
moderate to heavy weights
2 sets
15 reps
30 - 45 sec rest betw sets
Yields: 15 cookies
These oatmeal cookies are yummy, nice and chewy!
1 cup instant oats
1 1/2 cups regular flour, wheat flour, or half white half wheat, spelt flour works great also
1 ½ tsp baking powder
1 ½ tsp ground cinnamon
⅛ tsp salt
4 tbsp unsalted butter, melted and cooled slightly (or coconut oil)
1/2 cup unsweetened applesauce
1 large egg, room temperature
1 tsp vanilla extract
1/2 cup brown sugar
3/4 cup raisins
-Preheat the oven to 325°F
-Whisk together the dry ingredients: oats, flour, baking powder, cinnamon, and salt in a medium bowl.
-In a separate bowl, whisk together the butter, egg, applesauce, and vanilla. Stir in the brown sugar.
-Add in the flour mixture, stirring just until incorporated. Fold in the raisins.
Spray your cookie sheet or line with parchment paper. Drop the cookie dough into 15 rounded scoops onto a cookie sheet, and flatten slightly. Bake at 325°F for 11-12 minutes. Cool on a wire rack.
This is a great early season run to develop power without going too hard for too long in the beginning stages of your training. The total distance and number of repetitions can be modified to fit your endurance level. Happy running!
40 minutes total run time
Run at a steady moderately-high foundation pace (high Zone 2) for 30 minutes. After 30 minutes run a 20 second relaxed sprint at speed intensity (Zone 5 or fastest pace you can hold for 1:00 - 1:30) then slow down and run 40 seconds active recovery (Zone 1). Repeat for 6 intervals (or adjust to fit your endurance level). After you have completed your sprints, run for approximately 5 more minutes at Zone 1 recovery pace for a total running time of approximately 40 minutes.
Thanks to Coach Taz of T3 Coaching for this workout!
This cold grain salad is yummy, refreshing, and perfect for a summer BBQ. You probably already have all of the ingredients in your kitchen!
For the dressing:
juice of one lemon
1 teaspoon mustard as an emulsifier
1/2 cup olive oil
1 garlic clove minced fine
1/4 cup fresh parsley
1/4 teaspoon salt (more to taste)
1–2 teaspoons honey
For the salad:
1/2 bunch kale (finely chopped, without stems, to yield about 1 1/2 cups)
1 tomato chopped
2 carrots grated
1/2 cup red cabbage
1 small cucumber
I /4 cup dried cranberries
1 chicken breast cooked (I used some leftover grilled chicken)
1 1/2 cups cooked and cooled brown rice (or millet, quinoa, wheat berries, or spelt berries)
1. Shake up the dressing ingredients in a large jar.
2. Dice and chop all the veggies and chicken.
3. Add veggies, chicken and grains to the dressing jar
4. Shake it all up.
5. Garnish with 1/4 cup chopped almonds and an avocado
6. Enjoy!
Thanks to T3 Coaching for this recipe!
This is a great early (or mid) season ride to develop power without going too hard for too long in the beginning stages of your training. The total distance and number of repetitions can be modified to fit your endurance level.
75 minutes total ride time
Ride at foundation pace (zone 2) for approximately 30 minutes to your favorite hill. The hill should have a moderate grade (4 – 6%). Perform 8 x 60 second short climbing intervals done in an efficient gear for climbing quickly. You should climb hard and fast enough to just push into Zone 5. Recover between intervals by coasting back down the hill and pedaling easily for two minutes of active recovery. Then repeat for the number of intervals indicated. After you have completed your climbs, ride home at Foundation pace for a total riding time of approximately 75 minutes.
Thank you to Coach Taz of T3 Coaching for this workout!
August 2019


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Fans have gotten very hungry for a spinoff featuring Katherine McNamara's Mia Smoak Aka Blackstar, daughter of Oliver and Felicity, ever since season 7 wrapped up. But could it actually happen? Well, the good news is that it's definitely being discussed behind the scenes. However, it doesn't look like it's a particularly high priority at present, what with the network developing a new Arrowverse property for the 2020/21 season.
So, how are fans taking this news? Well, there are conflicting responses online.


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The 2019 Alabama Book Festival has exciting plans for April 2019. We're expanding to a three-day event with the book festival on Saturday, April 13 in Old Alabama Town! Workshops, special events and more are on the way.
Upcoming Locations: Nashville, TN. Jul ~ Hannibal, MO. Aug/Sep ~ St. Louis, MO. Sep ~ Chicago, IL. Sep ~ Charleston, WV. Oct ~ Nashville, TN. Oct ~ Roanoke, VA. Apr
Back to All Events
Earlier Event: April 6Roanoke Author Invasion
Later Event: April 28Franklin Main Street Festival


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"Choosing thin clothing that packs flat over thicker, more bulky items makes a huge difference in how much you can fit in your suitcase," says Susan Foster, author of Smart Packing for Today's Traveler. Instead of packing a heavy sweater and jeans, try more travel-friendly options like a micro-fleece pullover and pants in lightweight, weather-resistant fabric. Diana Lane, an associate with Geiger & Associates, a Florida-based destination marketing firm, loves the versatility of lightweight sarongs, which can be worn as skirts, various styles of dresses, shawls, swimsuit coverups, shoulder bags or even used as a blanket. "There aren't many items that give us quite this much bang for the buck," she says.
Airport parking rates can be very high. In Boston, for example, supposed "economy" rates are about $120 for a week. Rates don't have to be that high: At busy Charlotte Douglas International Airport, the long-term rate is just a fraction of Boston's rate. But parking is one of the primary cash cows for big airports. Airports typically contract with private operators that, in effect, return more than 95 percent of the revenues to airport coffers.
Packing is pivotal. Forget an essential item and you're left disappointed and scrambling to find the nearest store in your destination. Pack too much and you end up disorganized, burdened with heavy bags, and hemorrhaging money to pay for pricey airline baggage fees. So we thought it best to revisit the most basic—and most useful—packing rules. Here are 10 fundamental packing strategies that every traveler should learn.
Before you go on a big trip, it is tempting to try and plan every aspect of it. As tempting as it might seem, make sure to leave plenty of room for serendipity. Try to just plan the skeleton of your trip and leave room in between for discovery and for things to come up which you didn't plan. Talk to other travelers that you meet on the ground and you'll have a much better idea of what you want to do once you land.
Studies show that frequent business travelers, who travel on average more than two weeks per month, are at a higher risk for a number of health concerns, including weakened immune systems, obesity, or mental health problems. Being prepared and smart throughout the booking, traveling, and working away process can influence some major attitude adjustments when it comes to business travel. Limiting stress on the mind and body can make more of a difference than you could ever imagine, so why not try out a few, and turn the worst part of your job to something truly enjoyable?
I book all of my flights through Skyscanner, because it consistently finds cheapest deals. The key here is to keep things flexible: I look at flights to an entire country (or search for "everywhere" if I'm not sure where to head next) and look at prices over a whole month. I don't collect points and miles, but I still rarely spend more than $500 on a long-haul flight.
Sure, you should have a rough plan for your trip, but don't book everything in advance or you'll likely feel too restricted and end up regretting it. Book a one-way ticket and your first few nights of accommodation — you'll figure the rest out along the way. It's not as intimidating as it sounds. If you're in a tourist destination there'll always be someone who's willing to take your money by giving you a place to stay.
Don't forget to squeeze in some light exercise in between flights and meetings. A 30-minute walk around the airport or a simple stretching routine when you feel tired is often all that is needed to refresh. Exercising also keep the body metabolizing at the ideal rate, which means you can sleep better at night and not have to worry about possible health problems ruining the trip.
Get out of your comfort zone and make an effort to meet local people. This is easier said than done, especially if you're traveling with friends or a partner, but it will dramatically affect your travel experience. So many of us go to the all-inclusive resorts or backpacker hostels and never get a real taste for local culture, food, or traditions, and then come home and talk about what the "country" is like. Stretch your comfort zone, push your social boundaries, and travel deeper.
Longing for a long-distance getaway but don't have a passport? You can still jet off to a faraway island overseas. Consider Puerto Rico, officially an unincorporated territory of the United States; the U.S. Virgin Islands, mere minutes from Puerto Rico by plane; Northern Mariana Islands, a collection of Micronesian islands governed by the United States since the Battle of Saipan in 1944; Guam, which is home to a heavy U.S. military presence; and American Samoa, a collection of five volcanic islands and two atolls between Fiji and the Cook Islands.
"It's not exactly in the middle of nowhere." That's what I find myself saying whenever someone says to me, "I'd never go on a transatlantic cruise." I have to admit, while not exactly in the middle of nowhere, there isn't a whole lot of activity going on around you, except maybe for an occasional whale or dolphin sighting. You do feel like you are out there all alone. Kind of.
Work-Around: Theoretically, you can check ahead and find a place that doesn't charge. But finding out about the parking charge isn't always easy. In our experience, hotels sometimes don't show parking charges on their websites. The best solution is often to check the hotel listing on an OTA such as Expedia or Hotels.com, regardless of where you made the reservation, because those sites may offer additional information.
Flimsy shower cap or custom shoe cover? You decide. In every suitcase, there's a constant battle between dirty and clean items. Score a victory for fresh-smelling shirts and dirt-free trousers by keeping your shoes contained in a shower cap. Place them in, soles down, and let the shower cap's elastic band cradle the shoes so that any dirt, grease, or unidentified muck stays safely tucked away inside the plastic pouch. Depending on the type and size of your shoes, you may need more than one shower cap, but housekeeping is usually pretty generous with them.
"The more you pack, the easier it gets (or at least, the easier it should get) — so make being ready to travel part of your everyday life. Collect travel-sized toiletries when you have the chance: Get an extra toothpaste when you go to the dentist, ask your hair stylist for shampoo and conditioner samples, and keep all of them organized in a ready-to-grab toiletry bag. Learn which items of clothing work best for travel: They shouldn't wrinkle easily, they should work for day or evening, and they shouldn't take up a lot of space in your bag. And always pack less: What didn't you use on your last trip? Don't bring it." — Jessica Plautz, Deputy Digital Editor
Many of our favorite places are best traversed on foot. Skip the expensive sightseeing trolley and instead sign up for a group walking tour in your destination. If you're wary of being led around a tourist trap by someone in cheesy colonial garb, don't worry: Many destinations offer innumerable walking tours for every type of traveler, from the art buff to the culinary enthusiast. (Plus, a brisk walk between neighborhood nibbles almost outweighs the calories—we hope.)
Packing your electric toothbrush or razor? Make sure you either take the batteries out or tape the item's switch in the "off" position. Battery-powered devices can easily turn on after being jostled around in a carry-on, which can in turn draw the attention of security. Play it safe and pack your batteries separately from your battery-powered items.
Our top travel tip is to understand that it's OK to leave something on the table, that you don't need to do it all during a trip. When we think of travel in terms of accomplishments or checking things off a list we are less likely to really appreciate all that we are seeing, experiencing, and sensing as we are already thinking of the next sight or two before even leaving the current one.
Studies show that frequent business travelers, who travel on average more than two weeks per month, are at a higher risk for a number of health concerns, including weakened immune systems, obesity, or mental health problems. Being prepared and smart throughout the booking, traveling, and working away process can influence some major attitude adjustments when it comes to business travel. Limiting stress on the mind and body can make more of a difference than you could ever imagine, so why not try out a few, and turn the worst part of your job to something truly enjoyable?
It also helps to know which items are, according to the TSA, considered liquids or gels and thereby subject to the 3-1-1 rule. This isn't as simple as it sounds. Foods such as peanut butter, pudding, mashed potatoes, and icing are classified as gels. Mascara, lip gloss, and aerosol items are also classified as liquids or gels. But keep in mind that liquid prescription medication is exempt. (Read more on that on The TSA Blog.) See a more complete list of liquids and gels that are not permitted in carry-on luggage in quantities greater than 3.4 ounces here.


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Stop Waiting for Institutional Investors (They're Already Here)BTC Casino / 2nd November 2018
The Bitcoin (BTC) and cryptocurrency markets continue to stagnate as trading volumes and retail interest continue to decline — but don't be fooled. Average Joe might be disinterested in the prolonged bear market, but institutional investors and smart money are more keen to get involved than ever.
Cryptocurrency Scam Warnings Issued by New Zealand Financial Authority
Saturday November 03, 2018
Growth in the cryptocurrency industry comes in many different forms. One worrisome trend is the growing number of scams. The financial authority of New Zealand is paying very close attention […]
The post Cryptocurrency Scam Warnings Issued by New Zealand Financial Authority appeared first on BTC Casino Gambling.
Do a Google Trends search for Bitcoin. What do you see?
Central Bank-issued Digital Currencies (CBDC): Even Banks don't like them
Friday November 02, 2018
It isn't new that Central banks have negative views towards digital currencies. Though the interesting part is that they view central bank-issued digital currencies (CBDC) the same way. Earlier this […]
The post Central Bank-issued Digital Currencies (CBDC): Even Banks don't like them appeared first on BTC Casino Gambling.
Pretty dire, isn't it?
No matter which way you spin it, the mainstream interest in Bitcoin and the cryptocurrency market just isn't there — a sentiment shared by cryptocurrency analyst Garrett Keirns. Keirns told Forbes that "the interest is just not there" and claims that the market "need[s] a catalyst to spark interest," continuing:
People are afraid of losing money, especially the Coinbase retail crowd who bought in at $10k+.
Where the institutional investors at?
If you follow the cryptocurrency industry and don't live under a rock, you've probably heard the term "institutional investor" thrown around excessively throughout 2018 — so much so that the smart money class of investors has become something of a Messiah to bagholders and rekt retail traders everywhere.
What these savior seekers are missing, however, is the fact that institutional investors are already here — and taking an interest in cryptocurrencies' discounted prices. Nigel Green, founder and CEO of deVere Group, told Forbes:
We've seen – and are continuing to see – that there is an increasing feeling, especially amongst institutions, including financial ones, that they feel that they now need to explore digital currencies – and fast – or their rivals could get way out ahead and they might not be able to catch up.
The industry's major players have bent over backward to get institutional investors involved, too. Coinbase has launched a platform of custodial services aimed specifically at smart money investors, while there are more 'legitimate' stablecoins now than you can shake a stick at.
Perhaps it's time for retail investors to stop waiting for Godot and accept the reality of the situation — before they get left behind.
What do you think about institutional investors in the cryptocurrency space? Do you agree that they're already here? Let us know in the comments below!
Images courtesy of Shutterstock, Google Trends.
[Disclaimer: This article is not intended as financial advice. The opinions expressed within are solely those of the author and do not necessarily reflect those of Bitcoinist, as a whole.]
The post Stop Waiting for Institutional Investors (They're Already Here) appeared first on Bitcoinist.com.
Bitcoin Price Analysis: BTC Won't Go Quietly, Risk of Rally Grows
Wednesday January 23, 2019
Bitcoin price dumped below the $3,500 support before buyers took a stand against the US Dollar. There are two bearish trend lines formed with resistance at $3,635 and $3,840 on […]
The post Bitcoin Price Analysis: BTC Won't Go Quietly, Risk of Rally Grows appeared first on BTC Casino Gambling.


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Book Review|January 01 2004
Still the New World: American Literature in a Culture of Creative Destruction
Common Knowledge (2004) 10 (1): 161.
Michael P. Kramer; Still the New World: American Literature in a Culture of Creative Destruction. Common Knowledge 1 January 2004; 10 (1): 161. doi: https://doi.org/10.1215/0961754X-10-1-161
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20:20 Tramore Thu 15 August 2019
Arguably the standout contender in this field. Multiple winning hurdler, and hard to knock last time when he just failed in his bid for the four-timer when fifth in what was a fiercely competitive renewal of the Galway Hurdle.
Not gone on from Kilbeggan (2m2f; good to yielding) hurdles win in June, and could never land a blow at Galway (2m; good) last month. 0-15 on the flat, and it would be a surprise if he were to be one of the main protagonists.
Something is not right after he hasn't show anything like the form he did in two starts since landing a bumper for WP Mullins in April. Heavy defeat on hurdles debut at Galway (2m; good) when last seen, and is risky.
Ran exclusively over hurdles since making a winning racecourse debut over hurdles at Cork (2m; good to yielding) in November. Progressing in handicap sphere before disappointing at Galway (2m; good) last time. Place claims at best on flat debut.
Talented sort over hurdles/fences, and bounced back from poor showing at the Curragh on flat debut with a fine third to the smart Pravalaguna at Cork (3m; yielding). Now returns to the flat, & this is a bit easier than latest run on the level.
Makes return from 277-day break, but has shown on multiple occasions she goes well fresh. Smart chasing mare, and third in the Grade 2 Fortria Chase when last seen. Flat debut and she should make her presence felt.
Last Year's Winner
|Tornado Watch
|T: Emmet MullinsJ: Miss R Dudfield
Sole Pretender (4/5), Listen Dear (5/2), Buttons And Bows (8/1), Botani (12/1), Jaime Sommers (25/1), Court Martialed (25/1), Beat Of The Sea (50/1)
- Sole Pretender
- Listen Dear
- Jaime Sommers
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Wednesday's racing preview
Crystal Ocean can live up to his billing in the Juddmonte International, according to Anita Chambers - she has a tip for every race on Wednesday.
Value Bet: Classic Comedy
Our racing expert Ben Linfoot has three Value Bet selections for day one of the Welcome To Yorkshire Ebor Festival and he's taking on Crystal Ocean in the big one.
Simon Holt: Valdermoro magic
Richard Fahey's Valdermoro is one of Simon Holt's two tips for Wednesday's high-class action at York.


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