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6/20/11 meeting with Dan Hartman/MMED, practical issues
Yesterday I met with the Director of the Medical Marijuana Enforcement Division to answer the numerous questions I receive from the businesses we represent. The issues and the answers are set forth below:
1. Transfer of "banned" businesses to new jurisdictions:
Will there be continued operation of the transferred business based on prior 7/1/10 compliance? Yes, as long as there is local approval. Mr. Hartman recommends that the "banned business" request withdrawal of the application, along with an explanation of the banned/transfer reason. If the application is not withdrawn, it must be denied. Then, once the transfer and local approval are complete, you can request that the withdrawal of the application be rescinded. Once the rescinded application is reinstated, you may resume operation.
Also, if the banned/tranferred business is sold before the transfer is complete, the business will not be able to operate. Mr. Hartman's reasoning is that this provision is designed to help people who suffered local ban, not speculators who seek to profit from this unfortunate situation.
Further, both the MMC/MIP and OPC must be transferred, not the OPC only.
2. Security system and other ongoing compliance issues:
Are there approved providers? No, and there will not be any. Mr. Hartman states that the specifications are published and must be followed. As long as the specifications are followed, the provider of the service is not relevant. He did state that ADT appears to be ready to supply MMC/MIP/OPC security needs.
What if the system is not in place yet? This will be ok, as long was you have something in place and are under contract by 7/1/11to meet the specifications.
What if the system is not adequate, will there be a chance to correct it? Yes.
Does the security system have to have its own room? No, as long as the DVR(s) is locked in a secure box, bolted into the wall, floor, etc.
3. Point of Sale system:
Are there approved providers? No, but various companies are prepared for compliance, (MJ Freeway is one example). Mr. Hartman advised that "a big chief tablet" is ok, as long as you are tracking the necessary information. What the state requires will be published shortly and I will send out an email link to this information.
4. Employees deemed unacceptable by MMED:
Will there be an opportunity to terminate the employee if deemed unacceptable? Yes.
5. Ongoing construction, permits, etc.:
Does all construction work need to be completed by 7/1/11? No. You must be making a concerted effort to complete the work and permits should be requested by 7/1/11. However, if the local licensing authorities require the work to be completed and deny you for this reason, the state will not interfere and will enforce the denial.
6. License fees:
What are the licensing fees? These are not set, but MMCs will be less than the application fee, OPCs and MIPs will be more (perhaps even double). The license will be good for one year and will begin when the state notifies you that the fee is due and payable.
7. Key employees:
What is a key employee versus support? The answer is "case by case" and the answer will turn on how the employee is used, whether there is any contract with employee in place (key), and the businesses decision to classify someone as an "independent contractor" will have little or no bearing.
Also, payment of growers "by the pound" will be under serious scrutiny. If that is the arrangement, Mr. Hartman advises that this arrangement makes the grower an owner and the business will be required to revise its ownership structure, corporate documents, etc., accordingly. Mr. Hartman advises that you should pay the grower a salary and that bonuses are ok.
8. Business under denial/appeal, i.e., City of Boulder:
What is the state going to do about businesses locally denied (not banned), where an appeal is pending and the local licensing authority permits continued operation? This is a tricky one. The state will honor the continued operation order until such time as the business prevails or appeals to the district court. An order from the district court permitting continued operation will be required. The license will be issued by the state as a "provisional license" and the state will await final outcome of the case.
Further, Mr. Hartman advised that he will be speaking with the City of Boulder to discuss this matter (and others). Stay tuned, as I expect this policy to change (for better or worse) once the situation between the City and the State is further clarified.
9. Transactions of businesses:
Do all of the various sales, mergers and tranfers of MMBs have to be completed by 7/1/11? No. However, be reminded that any transfer requires (1) local approval; (2) state approval, including a meeting with the parties with MMED before the sale/merger/transfer occurs. Simply put, you need MMED's blessing before the transaction can occur.
10, Sales below cost/free:
Does the "sales below cost or for free" provisions of HB1043 preclude the incentive programs, i.e. "buy one get one, free pre-rolled," etc.? No, and there will be new rules developed in connection with the industry to help clarify this situation.
However, Mr. Hartman advised that MMED will take a very dim view of businesses "flooding" the market with cheap meds to drive out other businesses. Beware.
11. Independent contractors, i.e., trimmers, growers, etc.
What do independent contractors, vendors, etc., need to file with MMED? Everyone needs some sort of license to handle meds. If you are an employee, the employee application needs to be completed. If you are a vendor, the vendor application:
If you are an independent contractor, i.e,, trimmer, etc., you need to complete an occupational license application. It is unclear what this means. If you fall into this category, we can schedule a meeting with MMED to discuss your situation.
Again, the relationship between the individual and the MMB will be viewed by its substance, not what you call it. Be careful.
12. Contracts between MMC and MIP:
Is there an approved contract, recommended language or necessary inclusions for the contracts between MMCs and MIPs? No. The contract should deal with the amount paid for the trim, the weights to be delivered, the parties, etc. Also, be advised that the parties cannot pay "in product."
13. Inventory and MIP sales:
Does the trim, etc., sold to MIPs count against allowable inventory, 70/30? Yes and no. If the MMC sells trim to the MIP, i.e., 10 lbs, and the MIP makes the infused product and provides all of the infused product to the MMC, then no. However, if the 10 lbs. sold to the MIP is then used to make infused products sold to other MMCs, even if 1/2 of the infused product goes back to the selling MMC, then all 10 lbs. counts against the selling MMCs 70/30 inventory numbers. Be aware that this is somewhat different from prior information provided by MMED.
14. MIP issues, misc.:
Does the use of alcohol in infused products require a liquor license required? Not as far as MMED is concerned. However, Mr. Hartman advised that the Liquor board may have a very different view and a big problem with this. I suggest a candid discussion with the liquor board be had before proceeding further with alcohol infused product manufacturing.
Does the liquid weight versus MMJ weight count against an MMC's allowable inventory? This was not a clear answer. In general, no. However, if the MIP product is clearly labled "2 ounces, 1 gram, etc. MMJ in each product," Mr. Hartman advises that he would have no choice but to count it against allowable inventory.
What about MIPs in jurisdictions with no MIP approval process, i.e., Fort Collins? If there is no local approval, there will be no state approval. Sorry to all the Fort Collins' MIPs.
15. Expanded plant and ounce recommendations:
Is a MMC ok to honor the recommendation and incorporate patient center assignments of this variety into its allowable inventory? Yes.
Does the MMC have any duty to investigate the propriety of the recommendation? No. However, Mr. Hartman advises that the expanded plant recommendations will be under great scrutiny by the Department of Health and that doctor recommendations patterns are likely to be tracked. In these cases, the doctors will be required to medically justify the recommendations. Be advised that this is going to be a big deal
If patient designates "self and MMC" can both the patient and MMC grow 6 plants? This answer was not clear. In general, yes, but it appears that this issue has not been considered by MMED and is likely to see revision in the near future.
16. Sales Taxes:
What is the form of monthly reporting to MMED? This will be handled by the sales tax folks, not the MMCs/MIPs. However, monthly, not quarterly payments are required.
17. Other:
Does a scale need to be attached and incorporated into the point of sale system? No.
Can someone own a % of both a MMC and a doctor referral business even if no $ is exchanged between MMC and the doctor referral business? No. Mr. Hartman believes this is not appropriate. I am not sure if his opinion will be legally supported, since the only prohibition is payments from MMCs to doctors/doctor referral businesses.
Can investors receive a % of the profit? Yes, but there are then deemed owners, not investors and must follow all of the MMC/MIP ownership rules (residency, felony rules, and local/state approval of their ownership).
Can existing MMC's apply for new retail locations in 2011? No. New OPC locations in 2011? No.
How is the MMC going to verify patient center assignment? MMED and the Department of Health are working on this. For now, keep track yourself, including accurate records
What will MMED do about MMCs/MIPs currently in litigation between partners for pending licensees? Mr. Hartman will issue the license provided both parties are license eligible. So, if the litigation is between owners with felonies and owners without felonies, the license will be denied. The same is true for residents and non-residents. Mr. Hartman wants notice of the lawsuit and periodic status reports. He does not want copies of pleadings.
Lifetime drug felony; reiteration: 35 day rule
CRS 12-43.3-307(1) (h) states that a license shall not be issued to a "person who has discharged a sentence in the five years immediately preceeding the application date for a conviction of a felony or a person who at any time has been convicted of a felony pursuant to any state, federal law regarding the possession, distribution, manufacturing, cultivation or use of a controlled substance." This change added "manufacturing" and "cultivation" to the license prohibiting offenses and did not limit the lifetime prohibition.
However, the state may grant a license to "an employee if the employee has a state felony (not federal) conviction based on possession or use of a controlled substance that would not be a felony if the person were convicted of the offense on the date he or she applied for licensure." I anticipate this was amended to: (1) ensure that employees were specifically included in the prohibition portions of this section; and (2) to recognize the reclassification of marijuana charges from felonies to misdemeanors. I assume that the reclassification would have to be in the state where the conviction was entered. This means that if the conviction was in Florida and is still a felony in Florida, but not in Colorado, it is still a felony for purposes of licensure.
Finally, I want to take the opportunity to re-clarify the "35 day" rule based on ongoing confusion. Up to this point, the State prohibited selling to new patients who were not in possession of their card (see, MMED's 9/27/10 Memorandum regarding its position on the 35 day rule, http://www.colorado.gov/cs/Satellite?blobcol=urldata&blobheader=application%2Fpdf&blobkey=id&blobtable=MungoBlobs&blobwhere=1251659488306&ssbinary=true).
CRS 12-43.3-402(5) was changed to state that "the employee of the medical marijuana center making the sale shall verify that the purchaser has a valid registration card… or a copy of a current and complete new application for the medical marijuana registry administered by the Department of Public Health and Environment that is documented by a certified mail return receipt withing the preceding 35 days and a valid identification card that matches the name on the registration card." The "certified mail return receipt" is the green postcard that is signed by the Department mailed to the sender, not the USPS receipt for paying the certified mail postage fee. Also, in such a case, the employee must contact the Department of Public Health and Environment to determine whether the purchaser's application has been denied. This section does not apply to license renewal applications and these patients must have their card.
New MMJ regulations, HB 1043
Despite partisan bickering regarding other issues facing Colorado, the legislature passed HB 1043 with virtually no opposition (what a change from last summer!). Please understand that HB 1043 amends CRS 12-43.3-101 et seq. (HB 1284) and the two documents should be read together to fully understand MMJ business and caregiving regulations.
In any event, the following is a summary of the new law applicable to MMJ businesses:
1. Pending licensees will be able to continue to operate while local and state licensing authorities are completing the pending application process;
2. There will be no new licenses issued until 7/1/12, i.e., another 1 year moratorium;
3. Businesses issued their licenses will be apply to apply for changes to the license, a new license or license type (i.e., size of center). It is not clear whether this means the licensed businesses can add OPCs or MMCs. I will speak with the state and let everyone know what "change" and "new" mean to MMED;
4. Pending licensees in "banned" municipalities can apply for a new license with a local licensing authority and transfer to the new location. Good news for all those folks who encountered fear, ignorance and local politics! It is unclear how this will actually work and whether the business can continue to operate post-transfer. I will speak with the state and let everyone know;
5. MMCs (not MIPs) can sell up to 6 clones to patients and up to 1/2 of the # of plants that exceed 6, based on a doctor's recommendation. The definition of clone or "immature plant" is 8″ x 8″ in a 2″ x 2″ container and has nothing to do with rootedness;
6. The 2 year residency requirement only applies to owners and no longer applies to employees;
7. MMCs can sell to patients with an application, ID and recommendation while the state is processing the application (no more 35 day rule), However, the MMC is required to call CDPHE and confirm that the application has not been denied. Also, MMCs cannot sell to a patient with a renewal application, only a new application;
8. MMCs can use an automated dispensing machine. I am not sure why anyone would want to, since patient loyalty and customer service is what will distinguish success from failure;
9. Laboratories must obtain an occupational business license (according to MMED, the same applicant licensee requirements will apply) and CANNOT have any interest in a MMC or MIP;
10. No sales below cost or giving MMJ away unless it is to a patient who has been determined indigent by the State. This means no more "give aways" or "two for one" deals. Spread the word, so that this practice is ceased and everyone is on the same page;
11. An OPC can provide MMJ to more than 1 MMC, as long as the holder of the OPC is a common owner of all of the MMCs. What this really means is that multiple MMC locations, commonly owned, can use one OPC facility;
12. MIP products must be sealed and labeled. It is not yet clear what the label will say or whether the packaging must conceal the product inside;
13. The bill confirms that MIPs can never sell MMJ and are limited to growing up to 500 plants (there is a business need waiver process for more than 500 plants); and
14. No agricultural zoned cultivation. It is unclear whether the "no agricultural zone" issue applies to PCs or patients. I will look into this; and
15. MMCs can trade MMJ in equal amounts, but the MMJ cannot be "re-traded."
Regarding primary caregivers:
1. The PC must register with the State the location of the cultivation and provide registration information for the PC's patients;
2. The PC must comply with local regulations, including zoning. For instance, Boulder only permits care/cultivation for 1 patient in a residential zone. This provides the local governments some "teeth" for their widely different primary caregiver rules;
3. PCs may delegate duties to another PC, provided that the original PC maintains an ongoing relationship with the patients.
1st lawsuit against MMED successful
It has been awhile since my last blog. As you may have guessed, I am working hard on MMC/MIP compliance issues, including numerous meetings with the new director of the Medical Marijuana Enforcement Division, Mr. Dan Hartman. Over the last several months working with Mr. Hartman and his predecessor, Mr. Matt Cook, I have developed an insight into how MMED may address each situation. This allows me to understand how MMED is "thinking" and help predict future rules and changes.
In any event, there are times when we must stand up for our rights and challenge the laws as written and as interpreted by MMED. Accordingly, in December, I filed the first lawsuit against MMED based its denial of a client's MMC business application. The lawsuit was over whether an applicant must file an MMC business application by 8/1/10 or "within 30 days of receiving local approval." The statute provided for both, alternative, filing deadlines. MMED determined that only the 8/1/10 filing deadline was applicable and issued a cease and desist order. However, "the law is the law" and MMED entered into a settlement which accepted the application filing and my client was permitted to open their business. While not every case will be successful, it is always important to try.
2011 MMJ Update
As most of you know, DOR has drafted various rules regarding regulation of MMJ businesses. Public comment is invited and there is hearing scheduled on 1/27 and 1/28. For those of you who do not have a copy, you can view the document at:
Next, further legislation is being proposed for MMJ businesses, caregivers, doctors and patients. The bill, HB 11-1043 is attached in PDF format. A summary of the proposed changes include:
1. Only owners of MMCs and/or MIPs will be subject to the 2 year residency requirement;
2. MIPs that cultivate their own medicine will be limited to 500 plants;
3. Primary Caregivers can work with more than 5 patients upon the granting of a waiver from the Department of Revenue. This class of Primary Caregiver will be licensed (there may be fees…) and would be able to transact with the patients of another Primary Caregiver of the same class (more than 5 patients). This section does not appear to be well thought out and is likely to be substantially revised;
4. Primary Caregivers licensed to serve more than 5 patients will be required to register the cultivation site with the Department of Revenue, disclose the patients they are working for and comply with zoning and building regulations. This appears to be limited to PCs who received a waiver to care for more than 5 patients, but could likely include all Primary Caregivers. This could result in elimination of home-based cultivation;
5. MMCs will be permitted to sell MMJ below cost or give MMJ to indigent patients. It is unclear whether this will impact the 2 oz. per patient inventory limits;
6. MMCs will be permitted to sell clones. According to the recent Dept. of Revenue rules (see above) clones are treated as plants and subject to inventory limits (6 plants per primary center assignment) and cannot be sold to patients;
7. MMCs will be able to "trade" medicine in equal amounts with another MMC, but not "re-traded." It is unclear whether this will be included in the 30% allowable sales;
8. The prohibition for owners with a felony drug conviction in their lifetime will be reduced to a conviction within 5 years of the completion of the sentence;
9. The location of the Optional Cultivation Premises will no longer be confidential;
10. Multiple MIPs will be permitted to operate from a single facility by obtaining a "manufacturing facility license." It is unclear how this will be enforced, fees, etc.;
11. Patients will be permitted to purchase medicine while their application is being processed (no more 35 day waiting period);
12. Labeling of medicine is going to be addressed; and
13. Doctor's with "conditional" licenses will be permitted to request that they be able to recommend MMJ.
Finally, I trust that all of you are prospering in the New Year and that you are currently in compliance with the rules governing your business. Be reminded that compliance will be measured from 7/1/10 and you should not expect any leniency if you are not compliant at all times.
MMJ Division/Matt Cook update
I have been corresponding with Mr. Cook on various legal issues that continue to arise. I wanted to share with you his responses.
1. Is the sale of the 30% inventory from MMC to MMC retail or wholesale? A: Wholesale and that normal business records must be kept. I suggest that you verify both local approval and timely filing of the state application with any MMC you deal with. Make a copy of any licensing if possible.
2. Can MMCs sell to caregivers on behalf of the caregiver's patients? A: No, unless the patient is homebound AND has a waiver from CDPHE.
3. If you failed to meet the 9/1 certification deadline, can you continue to operate? A: No. However, if you met the 7/1 local approval/pending local approval deadline and filed the state application by 8/1, you are still considered "established" and do not forfeit your application fees. Nonetheless, you must cease operation until the state rules on your application.
4. Will there be a license fee(s) in addition to the application fee(s)? A: Yes. The license fees will be set in the spring. Start saving your money (what little you have) now!
5. Does the 2 year residency requirement also apply to employees and managers? A: Yes. As you know, I do not necessarily agree with this, but that is the state's interpretation until a district court judge rules otherwise. You should also assume the felon criminal conviction rules for owners applies equally to employees and managers.
6. Can municipalities impose a different standard for who is permitted to own a MMJ business? A: No, it is the state who decides this issue. For instance, Fort Collins enacted an ordinance prohibiting someone from owning a MMC/MIP if the have a felony within 10 years of the completion of the sentence (the state limits this to 5 years).
7. Can municipalites use a different standard of measurement for the distance between MMCs, schools, day cares, etc.? A: No, the "pedestrian access" standard set from in CRS 12-43.3-308(d)(II) will be applied.
7/1/10 or 7/1/11? Which is it?
Confusion continues to guide the MMJ industry. Many of you have attended presentations by Mr. Matt Cook, the head of the state's MMJ business regulation division. At these presentations, Mr. Cook repeatedly states that the bill goes into effect on 7/1/11 and that local regulations apply until then. I have spoken with many MMJ business people who take this information as the gospel truth and intend to continue with their businesses in their current form until 7/1/11. Many such businesses are "grow only" or "retail only" operations that have been locally approved (or not). Many are owned by people who have not resided in the state for two years, have a felony drug conviction or a felony conviction less than five years old or all three. In my discussions and correspondence with Mr. Cook (see prior blogs), it appears that continued operation of a MMJ business without strict compliance with HB1284 until 7/1/11 could be a serious problem.
Let's examine the idea that you have until 7/1/11 to comply with HB1284. If the bill does not take effect until 7/1/11, is there any requirement to apply to the state by 8/1/10? Can you refuse to pay the $7500-$18,000 application fee until July 2011? When you list your optional grow premises, can you tell the state that you plan to get around to it before July 2011? When you list a drug felon or out-of-state resident as an owner or employee on your application, will you be able to address this issue sometime before 7/1/11. Finally, when you certify, under penalty of perjury, on 9/1/10 that you are growing 70% of your own MMJ, can you tell the state that you are planning on doing this, but currently are buying all of the MMJ from various growers?
The point of this exercise is to point out that compliance with HB1284 appears to be immediate. If it were otherwise, none of the provision of HB1284 would apply, including the 8/1/10 application, the license/application fee, the 9/1/10 certification, etc.
Based on the information we received from Mr. Cook and our reading of HB1284, we suggest immediate compliance with HB1284. If you follow this advice, the worst that can happen is that you ran an HB1284 compliant business for one year longer than necessary. However, if you defer your compliance until July1, 2011, you may find that your application is denied or, worse, that you may face criminal prosecution for operating a business without the benefit of HB1284 protection. In our view, it is better to be safe than sorry.
Post 7/1/10, the hangover from Black Thursday
Well, it was one hell of a tough road getting from the enactment of HB1284 through "Black Thursday." All of you who hustled to get their businesses in order are amazing, resourceful, ingenious people and I am proud to represent you.
Now that it is 7/2, I want to make clear the following points:
1. You must be growing and selling only your own MMJ. The 9/1/10 certification does not act as an extension of the deadline for this requirement. Late last night I received clarification from Mr. Matt Cook that the effective date for growing and selling your own MMJ is 7/1/10. Do not jeopardize your hard work by purchasing MMJ from any one other than another established MMC, which has local approval for both its grow and retail operations. Don't take any one's word for their own legality – do your own due diligence.
2. Do not continue employing any people with drug felonies, concerning criminal histories (lots of misdemeanors, less-than felony drug convictions, etc.), people with a felony within five years of completing the sentence or anyone who has not been a Colorado resident for two years prior to 7/1/10 (see, prior blogs).
3. Do not operate your business at all unless you are locally approved and/or have applied for local approval for both the grow and retail aspects of your business. If you are a MIP, you can only continue operating if you have local approval/applied for local approval. If your MIP does not grow its own MMJ or you do not have local approval/applied for local approval for growing your own MMJ, you must have a written contract for purchase of MMJ with an established MMC. Please note that the MMC must be locally approved/applied for local approval for both the grow and retail aspects of its business in order to be able to sell 30% of its MMJ to your business. You may contract with up to 5 such businesses.
4. After 7/1/10, the MMC can only possess 2 ounces and grow 6 plants for the number of patients who have assigned the MMC as their "primary center." As stated in previous blogs, you must convert all patients who have assigned any of the persons associated with your business to be their primary caregiver over to the MMC as their primary center. Use the state's Change of Primary Caregiver form (there is not MMC primary center assignment form yet available) and make sure to properly complete, notarize and mail to the Department of Health and Department of Revenue, attn. Mr. Matt Cook, certified mail/return receipt requested. Remember – if you have zero patients who have assigned the MMC as their primary center, you may possess zero ounces of MMJ and may cultivate zero plants.
5. You should download the newly minted Dept. of Health patient application for use in acquiring new patients or use the Change of Primary Caregiver forms to assign current patients at the time of sale of MMJ from your MMC. You do not need to continue using any "temporary caregiver" forms (which were never legal anyway, see prior blogs). The forms may be downloaded from: http://www.cdphe.state.co.us/hs/medicalmarijuana/forms.html.
6. Begin preparing for the 8/1/10 Department of Revenue MMC/MIP application and save a substantial amount of money for the as-yet undisclosed application and license fees.
7. Please keep careful and accurate records regarding both your cultivation and sale of MMJ. Remember, the state's microscope for your business will be applied beginning on 7/1/10!
8. For all of the primary caregivers – you must only have five patients, must provide other caregiving services (see prior blogs) and charge only the cost of producing the MMJ. You must notify the Department of Revenue who the five patients are that you intend to continue as their primary caregiver and give notice that you are no longer willing to act as the primary caregiver for the remaining patients. List all of the patients accordingly. Send the letter certified mail, return receipt requested.
Stay legal and stay safe. Please contact us with any questions
The course of MMJ business over the last year
Over the last year, we have seen an explosion in the MMJ business. At first, it was a few brave souls who simply undertook to provide medicine to a few patients without regard to profit or large scale operations. However, once the Obama adminstration announced that MMJ would not be a federal law enforcement priority, a great many people began exploring the MMJ business. Unfortunately, most of the entrepeneurs were advised, not by my office, that the MMJ business was a "grey area" and that you could do virtually anything you want as long as the MMJ is sold to patients. This was not the case and there was little or no legal protection for these businesses. As a result, the primary business model was acquiring a few patients to justify a commercial grow operation primarily in residences or in places unknown to local governments. The MMJ was then sold wholesale to dispensaries. Selective prosecution by law enforcement gave these growers and dispensaries a feeling of relative safety in their MMJ business activities.
Quickly, the MMJ business was booming and Westword magazine capitalized by permitting large scale advertising of this fledling industry. A few business were blatant in catering to "recreational patients" and adopted names like "Dr. Reefer." The Denver Post then got into the act by taking an active role in criticizing the MMJ industry, including by referring to dispensaries as "pot shops" and publishing photographs of young people smoking marijuana. This created a public perception of MMJ as a front for recreational drug use. The legislature quickly responded with threats to eliminate the MMJ industry with the help of law enforcement.
In the following months, many attempts to create regulations for the MMJ industry were attempted and a rash of local moratoriums on MMJ businesses were enacted. A long and arduous process soon followed. From the outset, the legislature made clear that responsible and tightly regulated businesses would be the only survivors.
In the spring, various drafts of the proposed regulations were completed and it was clear that commercial growing and wholesale sales of MMJ would be prohibited. However, the growers were advised, again not by my office, that the regulations would not pass and that business as usual would be fine. This was not the case.
In May, HB1284 was completed and required a single business, the Medical Marijuana Center, was created. The MMC was required to grow and sell all of its own medicine and the commercial grower was legally eliminated. This wreaked havoc in the MMJ business community, as the grower businesses far out numbered the retail businesses. Felons and out of state residents were also eliminated creating further havoc in the industry.
Now comes "black thursday," July 1, which is the effective date of HB1284. All businesses must be locally approved for both the grow and retail aspects of the MMC in order to continue operating after July 1. "Shotgun weddings" of growers and dispensaries are occurring in a matter of days or hours as people struggle to comply with the July 1 deadline. In many cases, these business marriages are doomed to fail. I predict law enforcement will ramp up its efforts to squash out non-compliant businesses and less than half of the existing MMJ businesses will survive. The final chapter of this story will be written over the next several months. Let us hope that the patients are not the ones who suffer along with the fate of the businesses that support them.
7/1/10 "Black Thursday"
Try as I might, I cannot possibly get to all of you before Thursday (I have tried!). Accordingly, I am writing this blog in an effort to address various issues that appear common to most MMJ business people.
1. 7/1/10 is the effective date for all MMJ businesses going forward. I understand that Mr. Matt Cook has told some of you that you have until 7/1/11 to comply. This is not the case. I have spoken with Mr. Cook and corresponded with him on several occassions. In his correspondence he makes clear that your MMC and/or MIP application will be evaluated using the 7/1/10 date. For those of you seeking to add a retail or add a grow after 7/1/10, Mr. Cook advises that both aspects of the MMC must be locally approved on or before 7/1/10.
2. There is no one year state moratorium. However, there is a defacto moratorium in that you cannot operate after 7/1/10 unless you were "established"/locally approved for both the grow and retail location(s) before 7/1/10. Otherwise, you cannot operate until both local and state approval are obtained.
3. Hash is going to be considered an "infused product." The distinction provided by Mr. Cook is that green stuff in a bag is for MMCs, everything else is for MIPs.
4. There can be no deliveries except in the narrow circumstances provided in HB1284.
5. One grow can supply a MMC with multiple locations and common ownership.
6. One grow cannot supply MMJ to mulitiple MMCs not wholly and commonly owned by the same people. NO INDEPENDENT CONTRACTOR GROWS NO MATTER WHAT ANYONE IS TELLING YOU!!!
7. The residency, "no felony w/i five years of completion of sentence" and "no felony drug convictions ever" standards apply for owners, employees and managers of the MMC. The criminal background issues apply equally to investors.
8. The 70/30 rule applies on 7/1/10 and the certification is due 9/1/10. Again, in evaluating your application and 70/30 certification, the state will look back to 7/1/10.
9. MIPs must be locally approved by 7/1/10 to be considered established under HB1284 even if there is no such licensing procedure locally available.
10. The MIP may, but is not required to, grow its own MMJ using a locally approved OPC or may contract, in writing, with up to 5 MMCs to purchase the MMJ for use in making the products. The MIP MMJ cannot be resold to any other business or person, but the MIP can sell its products to any MMC.
I know how hard it is out there. Better to be on the sideline and do it right, then be further down the road doing it wrong. Remember, doing it wrong can result in delay, denial, permanent bar from future MMJ business or removal of any protection from criminal prosecution.
Stay legal, stay safe.


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When You Are Called Oversensitive
Graphic by G. T. Randolph
Oversensitive? Hysteric? Too emotional? Weak? Vulnerable?
Good communication with others is crucial to our well being. The way others react to us is whether lifting up or putting down. Rarely something is just neutral. It affects us in some way. People who we love, feel connected with, have a bigger influence on our mood.
Words: sensitive and oversensitive don't have a good connotation in English language. I doubt in any language that can be complementing to a person. Being called this way, it is rather insulting and detrimental. It is implying that something is wrong with you.
Often artists and people diagnosed with some sort of mental challenges hear they are too emotional. Few more explanations can follow that, for example: " considering who you are, it is normal and you should not be ASHAMED." Really? This is exactly what calling someone oversensitive is: shaming.
Another group that is called this way, although probably more often by word: hysteric, are women. If a guy is expressing himself louder, he is confidently telling his opinion and has an appropriate reaction to what is happening to him. If a woman does that, she may be called hysteric, panicky and definitely has no rights to feel the way she feels.
We do not have a control over how others will interact with us. Everyone is perceiving and responding to an environment exactly the way he was programmed. That means we shall not expect from abused women that they will leave harmful situation, because they were thought that having a husband is an honor or success and opposite is a shame and weakness.
That also means that addicted person won't be compassionate to another one, as they both were programmed that what they do, is wrong. The best they can do is judging one another, until they go through therapy.
Raising awareness and educating self and those near you is probably the best remedy I can think of now.
Sure, it is very likely you will still hear you are oversensitive or hysteric, but instead of agreeing with the label or helplessly feeling wronged, you can state what you are:
"I have an appropriate reaction to what is happening to me.
I am highly aware of the impulses/details coming from my environment.
I am aware of not only what people say, but what they body language communicates, posture, tone of voice and if their behavior matches their action.
Yes, I am loudly protesting against shaming me/wronging me/ insulting me."
These are just examples of sentences one may try to apply in such situation. If you think up your own "remedy - mantra", let me know!

subset: commoncrawl


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Returns and Exchanges:
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For more information including how to return an item please see our Returns page.


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Since the inception of springs, Hooke's Law has been the science behind supported sleep.
Hooke's Law says a spring pushes back with the same force applied. Leggett & Platt's engineers know how to use materials and engineering to take full advantage of Hooke's Law, creating innersprings that place the body in a supported position, delivering proper spinal alignment and comfortable sleep.
Learn more about how this applies to our engineering process.


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"Death leaves a heartache no one can heal, Love leaves a memory no one can steal." – taken from a headstone in Ireland
"There is a sacredness in tears. They are not the mark of weakness, but of power. They speak more eloquently than ten thousand tongues. They are the messengers of overwhelming grief… and unspeakable love." – Washington Irving
"Grief does not change you; it reveals you." – John Green, writer
"You will lose someone you can't live without, and your heart will be badly broken, and the bad news is that you never completely get over the loss of your beloved. But this is also the good news. They live forever in your broken heart that doesn't seal back up. And you come through. It's like having a broken leg that never heals perfectly—that still hurts when the weather gets cold, but you learn to dance with the limp." – Anne Lamott, writer
"Deep grief sometimes is almost like a specific location, a coordinate on a map of time. When you are standing in that forest of sorrow, you cannot imagine that you could ever find your way to a better place. But if someone can assure you that they themselves have stood in that same place, and now have moved on, sometimes this will bring hope" – Elizabeth Gilbert, Eat, Hope, Pray
"Grief shared is grief diminished." – Rabbi Grollman
"We grieve to wake up to life – to embrace the exquisite beauty and sorrow of being fully alive, to learn to savor the simple moments." – Alexandra Kennedy, psychotherapist
"Mourning is one of the most profound human experiences that it is possible to have… The deep capacity to weep for the loss of a loved one and to continue to treasure the memory of that loss is one of our noblest human traits". – Shneidman (1980)
"Every widow wakes one morning, perhaps after years of pure and unwavering grieving, to realize she slept a good night's sleep, and will be able to eat breakfast, and doesn't hear her husband's ghost all the time, but only some of the time. Her grief is replaced with a useful sadness. Every parent who loses a child finds a way to laugh again. The timbre begins to fade. The edge dulls. The hurt lessens. Every love is carved from loss. Mine was. Yours is. Your great-great-great-grandchildren's will be. But we learn to live in that love." – Jonathan Safron Foer, writer
"You cannot prevent the birds of sorrow from flying over your head, but you can prevent them from building nests in your hair." – Old Chinese Proverb


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More than 1.5m users now subscribe to Hulu's premium streaming service, with Hulu Plus sign-ups in 2011 double the daily rate of 2010. Part of that may well be down to Hulu keeping its best – and the most – content for paying subscribers, however, with free-to-stream Hulu content growing 40-percent year on year, while paid Hulu Plus content more than doubled.
Hulu isn't naming names, but it's clear the company thinks it has the edge on streaming rivals. "Our model [of free and paid upselling] allows us to profitably pay content owners approximately 50% more in content licensing fees per subscriber when compared to other similarly priced online subscription services" it claims, announcing that it expects to spend around half a billion dollars on content deals this year.
However, 2011 will also go down as the year when Hulu failed to ink a deal, with its owners decided to drop attempts to sell the company after one by one big-name potential bidders dropped out. Instead, Hulu is said to be considering an IPO.
Meanwhile, comScore claims Netflix users are spending twice as much time watching that streaming service instead of Hulu Plus. In November 2011, Netflix users apparently viewed a billion minutes, while Hulu viewers together racked up 480 million minutes.


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Why Christina Tosi Is Bringing Pressed Juice to Milk Bar
It's all in the name of eating more sweets.
If you drink a green juice with a gooey, chocolatey, pretzel-y slice of Candy Bar Pie, do they cancel each other out? Now you can try it. Christina Tosi, the woman who brought the world Crack Pie and Cereal Milk soft serve, among other delightfully over-the-top treats, is taking on a slightly healthier project: fresh-pressed juices. The first three flavors—Real Talk, Hard Body and High Kick—are available in New York City Milk Bar locations this week.
It might seem like an unexpected venture from the queen of sweets, but LIFE, Tosi's new breakfast, lunch and juice line, is actually inspired by Tosi's lifelong quest to eat as many cookies and cakes as possible. "Between a crack pie tasting, or while snacking on compost cookies, you'll find most of us chugging green juice," Tosi says. "It gives us the good stuff to keep bouncing around the kitchen." The Milk Bar team decided to bring their healthy between-treats fuel to the masses, so we can all eat more cookies and get our nutrients, too.
Should people drink the super-fresh juices with their funfetti-style birthday cake? Tosi supports the idea. "I'm definitely a cornflake-chocolate-chip-marshmallow-cookie and a juice gal," she confesses. So go ahead: Pick up a juice along with your compost cookie (Tosi recommends the carrot/apple/lemon/ginger High Kick—after drinking it, she says, "I'm ready to run around doing a bunch of high kicks!"). "We're all about indulgence; that's no secret," Tosi adds, "but we're the kind of guys and gals who set out each day to crush life"—thanks to a sugar rush, plus a little extra fresh-juice fuel.


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The award nominees for the 60th Annual Grammy Awards have been announced. In the Best Bluegrass Album category we have five albums spreading the breadth of the style realm in the genre. In addition to the bluegrass category, we find our friend Larry Cordle up for Best Roots Gospel Album for Give Me Jesus, Alison Krauss is up for Best American Roots Performance for "I Never Cared For You" and Best Country Solo Performance for "Losing You", and "Cumberland Gap", David Rawlings & Gillian Welch, songwriters, is up for Best American Roots Song. Many other of our favorite artists are scattered throughout the nominees list
The five bluegrass albums include the following titles:
The Recording Academy™ welcomes this year's class of GRAMMY® nominees. The final round of GRAMMY voting is Dec. 7–21, 2017. The Recording Academy will present the GRAMMY Awards® on Sunday, Jan. 28, 2018, live from Madison Square Garden in New York and broadcast on the CBS Television Network from 7:30–11:00 p.m. ET/4:30–8:00 p.m. PT.
"I'm inspired by this year's nominees and the incredible talent each possesses," said Neil Portnow, President/CEO of the Recording Academy. "Their recordings are a true testament to how creatively alive and meaningful our music industry has become. Each nominee uses their craft to inspire, uplift, and tell stories of our world through their artistry. They provide a vibrant soundtrack that represents the highest level of excellence and continues to impact and reflect our culture."
"The beauty of our process begins and ends with the participation of music professionals," said Bill Freimuth, Recording Academy Senior Vice President of Awards. "Our nominations reflect the expertise and passion of Recording Academy voting members."
The Recording Academy represents the voices of performers, songwriters, producers, engineers, and all music professionals. Dedicated to ensuring the recording arts remain a thriving part of our shared cultural heritage, the Academy honors music's history while investing in its future through the GRAMMY Museum®, advocates on behalf of music creators, supports music people in times of need through MusiCares®, and celebrates artistic excellence through the GRAMMY Awards—music's only peer-recognized accolade and highest achievement. As the world's leading society of music professionals, we work year-round to foster a more inspiring world for creators.
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2010 Executive Board - Computer and Technical Services division of SCLA. http://scla.net/cats/
Mobile App Developer - http://www.emmaclark.org/mobileapp/
I started my first job in a public library in New York beginning as a page, working my way up to clerk, then network administrator. Currently the Manager of IT Services for Media Source, Inc. (http://www.mediasourceinc.com), which serves the library community by combining school and public library expertise with access to some of the most respected brands and best minds in the world of children's and young adult literature, collection development, and library management. Subsidiary companies include: Junior Library Guild, The Horn Book, Library Journal and School Library Journal. I have been writing software and working with computers for over 12 years, owning, destroying and rebuilding my first computer at age 13. Since then I have become proficient not just in systems administration but also software development and programming.
Email: email@example.com
Twitter: @MikeBerse


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Hi :
I am looking to form a team of - each contributing it's expertise in the following
1.Children's fashion sketches/design
2.Setting up a Manufacturing outlet
3. Marketing
Ie: Social Media, Public Relations, Print media, brand awareness,
4. E- commerce
5. Business plan ideas to attract investors.
If you like children's fashion and have a passion to start a business from the ground up. I need you on my team!!!
I am starting to build this business from scratch and need to form a good team. This business will launch in the Caribbean.
email: email@example.com
Views: 243
I can suggeated you for a Clothing Manufacturer for supply you children cloth.just fill up the enquiry form or many contact form and put your requirement and company will send you a price list.
Thank you Alan. I appreciate your assistance
Don't worry, there are multiple Children's clothing manufacturers USA. They offer their services at wholesale rates. If you have already designed the logo of your organization, all you need is to upload the blueprint at their website, they will deliver you the bulk of clothes with the symbol printed or embroidered on them.
have also come up with a wide range of colors at their web stores. So just go through them and take your pick.
Mail us:
Thank you Mike. I am grateful for any advise and direction. I really am keen to get this venture started ... this has been my dream.
you will succeed)
Thank you so much for your words of encouragement .... it means alot to me. I have had this dream for years but never really knew how or when to take the first step .
I realized there isn't really a wrong or right time so i have decided to start now.
Hi Ray.... This Stacy just checking in on you. How is everything working out? If you need help look me up on FB Stacy Anmarie ... I have a good selection of people in the industry that may want to collaborate with you. I can run your openings and go from there ..if that would help and my Twitter is connected. Have a blessed night! :-)
Stacy Anmarie
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Burglary suspect claimed to be federal agent while inside Oconee Co. home
A Salem man charged with burglary and assault claimed to be a federal agent after Oconee County deputies arrested him Tuesday morning.
Andrew Michael Wilson, 38, of Sunrise Drive, was booked into the Oconee County jail around 2 a.m. Tuesday.
A homeowner on Sunrise Drive reported that a man was seen at the top of his basement steps peering into his living room, according to a statement from the Oconee County Sheriff's Office.
The homeowner physically removed the man from the home when the man swung at the him in attempt to hit him.
Deputies arrived and identified the man as Wilson.
While investigating, Wilson told deputies he was "playing a game" and was a federal law enforcement agent. He could not provide any credentials, according to the Sheriff's Office.
Wilson is charged with third-degree assault and battery and first-degree burglary.


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Sign the Social Security Fairness Act Petition!
Update on NEA's Campaign to Eliminate GPO/WEP
August 15, 2007
The Latest News:
Sign the Social Security Fairness Act Petition!
With record numbers of cosponsors on both the House and Senate versions of the Social Security Fairness Act (H.R. 82/S. 206) — which would completely repeal the Government Pension Offset and Windfall Elimination Provision — it is time to push Congress to move this important legislation forward for a vote. House Ways and Means Committee Chair Charlie Rangel (D-NY) has announced plans to hold a hearing on the bill, possibly this fall. To show the Committee, and all of Congress, why they must act immediately, we need to show the strongest possible support for repeal of the GPO and WEP from across the country.
Make your voice heard today! Sign NEA's electronic petition. A copy will immediately go to your Members of Congress, and NEA will compile a complete record of all signed petitions so we can show congressional leaders the overwhelming support and urgent need for this bill.
Click here to sign the petition.
Cosponsor Update
The House version of the Social Security Fairness Act (H.R. 82) has now garnered the support of 324 bipartisan cosponsors. The Senate bill (S. 206) has 35 cosponsors. See the complete list of House and Senate cosponsors.


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Electronics Design Group (EDG) provides consulting services that follow a reliable 5 step approach. At EDG we like to call it "The 5D's of Consulting". The 5D Consulting Process includes steps that assist in discovering, defining, designing, developing, and deploying a client's electronics integration system.
EDG engages with clients and/or trade partners via a consultation process that aims at understanding expectations and offering possibilities. The discovery process explores a client's technology interests and needs (i.e. audio, video, lighting, network, security, HVAC, etc).
The result of this meeting is preliminary budgets as well as documentation needed to build the infrastructure of the project. From there, a client can take those documents and seek bids for deployment of the project. Of course, if a client chooses, EDG would be happy to complete the project's installation and execution.
The approach taken by EDG offers distinct benefits. Architects, interior designers, builders and other trades appreciate the way EDG works because relevant information is offered very early on in the design process. Plans are designed right away to make for a smoother integration process; to propose ideas without having a design would lead to mistakes and client dissatisfaction. The EDG team prefers to plan, define, and design in order to provide a successful end result.
Contact EDG today for more info on our Consulting Services or to get started on your project: (888) 406-2782 or email us.


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Men's Sinsinawa - Antique Brass
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Over time our leather preferences evolve and right now we're deep into a phase where we're particularly fond of rustic leathers, especially those with a high level of pull-up effect — a treatment in which oils that are infused into the leather during the tanning process can be pushed to the surface with pressure from the backside or with creasing. In our opinion, it's these leathers that keep getting more attractive with age and use. This particular leather has quickly become one of our favorites, with just a hint of a greenish-gold cast. Downright handsome, in a rugged kind of way.
Our single-sole moccasins are incredibly comfortable with a true barefoot feel. Slightly less structured than our more popular double-sole Cota moccasin, they're still meant for indoor/outdoor use. In northern climates, we consider these appropriate for three season use, spring through fall, but in southern climates they're perfect for year-round use. Consider these as a great alternative to flip-flops, sandals and athletic shoes.


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Life Sentence
Crime doesn't pay in 'Accomplice'
By Daedalus Howell
IF, AS AUTHOR Graham Greene suggests, "Thrillers are like life--more like life than you are. It's what we've all made of the world," then Sonoma County Repertory Theatre's production of Rupert Holmes' would-be thriller-comedy Accomplice, directed by Diane Bailey, should weigh heavily on everyone's conscience.
Intended as a comic deconstruction of the ordinary two-act thriller, Accomplice is predicated on innumerable plot twists and ends up suffering painfully from its own cleverness.
Opening at the ubiquitous "country house," the play introduces us to a sex-starved wife (Rebecca Allington) who plots with her secret lover (Jonathan Kesser) to dispose of her rigidly conventional husband (Eric Thompson). But lo! No sooner is the trajectory of this plot established than it's chucked for a more scintillating counterplot involving a pair of double-crossing and lip-locking wives, which is soon upgraded to a pair of double-crossing and lip-locking husbands. But wait, there's more . . .
Indeed, this play has more plots than a cemetery. But, alas, they're all dead. In the spirit of a whodunit, one is compelled to ask: Who killed them? The first suspect, of course, is Holmes himself, who suffocates the play with a collection of storytelling devices in which style lords it mercilessly over substance. In cahoots with the playwright is Bailey, whose usually taut directorial reins seem to have slackened with this production. Her cast is let loose to trample the dialogue with missed beats and tired segues.
Despite the misdirection, the players occasionally brighten the circuitous plot with a few moments of genuine jollity, as when Allington comically undulates beneath a duvet with Kesser, whose initially villainous incarnation in the play is part Dudley Moore, part dud. That Allington, at one point, opens a bottle of poison with her mouth is a perfect symbol of the play's tendency to flirt with disaster.
Kudos go to actress Kori Krehbiel, who endures a ridiculous and endlessly protracted bra gag for the duration of the second act's first scene while portraying an unsteady ingenue. Later, she dispenses some fairly comic stage business with her character's ear-piercing vocal exercises.
Eric Thompson's turns as a gelded husband and anguished auteur also garner some chuckles, but ultimately his talents seem squandered.
The cast's British accents are fickle at best--one could hear better English on a billiard ball. But then we fall into one of the strange trapdoors in Accomplice: in one of the play's myriad realities, the players are portraying poor actors in an even poorer play. Unfortunately, it's easy to distinguish the multiple realities of the play from the singular reality experienced by those sitting in the theater's seats--one marked by tedium and tired buns.
To complement the production's bad-play-within-a-bad play conceit, designers Michael Mingoia and Mac McCormick have devised an incredibly garish living-room set swabbed in a hue of jaundice-yellow seldom seen outside a hepatitis clinic.
In the end, the Accomplice does not succeed in roping the audience into service as a partner in crime. Instead, the play is merely a dress rehearsal for what otherwise looks to be a promising new season for SCR.
Accomplice continues through Feb. 19, beginning at 8 p.m. Thursdays through Saturdays, with 2 p.m. performances on Jan. 30 and Feb. 6 , at Sonoma County Repertory Theatre, 104 N. Main St., Sebastopol. $10-$15. 823-0177.
From the January 27-February 2, 2000 issue of the Sonoma County Independent.
© Metro Publishing Inc.


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« First Year Highlights: All Of Them In One Place! | Main | How Can We Get The New Year Off To A Good Start? »
The Most Popular Posts Of The Year
I'm "kicking-off" a second year of this "Classroom Q & A" blog on Friday, and thought that a good way to end the first "season" would be to share the ten most popular posts over the past year.
But, first -- a reminder: Even though I have a stack of plenty of questions, I can always use more!
You can send them to me at [email protected].When you send it in, let me know if I can use your real name if it's selected or if you'd prefer remaining anonymous and have a pseudonym in mind.
You can also contact me on Twitter at @Larryferlazzo.
Anyone whose question is selected for this weekly column can choose one free book from a selection of ten published by Jossey-Bass.
And, now, here are the top ten most popular posts over this past year (starting at number ten and ending at number one):
10. Several Ways We Can Teach Social Studies More Effectively -- Part One
9. Response: Several Ways To 'Motivate' the Unmotivated To Learn
8. Response: Several Ways Teachers Can Create a Supportive Environment for Each Other
7. Response: Several Ways To Differentiate Instruction
6. Response: Several Ways to Connect With Disengaged Students
5. Response: More Ways To Differentiate Instruction -- Part Two
4. Response: Several Ways We Can Help Students Develop Good Habits
3. Response: Several Ways To Help Students Become Better Listeners
2. Response: More Ways to Help Our Students Become Better Readers - Choice & Access
1. Response: Ways to Include Students in the Formative Assessment Process
I hope you've found this list useful and, again, keep those questions coming!


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- How is My Maintenance Crew a Not-for-Profit?
My Maintenance Crew is a social enterprise of Diversitat, a not-for-profit community services organisation with a proud history in providing migrant services. Our mission is to provide an innovative and high quality response to the changing needs of a culturally diverse community. Diversitat has been an advocate for youth with it Diversitat Youth programs and Youth You Turn programs along with other school-based programs. Diversitat has a passion for providing our young people with a chance to thrive in the Geelong community.
- What is a Social Enterprise?
As a social enterprise, My Maintenance Crew sells goods and services in the open marketplace and reinvests the money they make back into running their business and the local community. This allows My Maintenance Crew to tackle social problems, improve people's lives, support communities and help the environment.
- What is the unemployment rate of young people in Geelong?
The ABS youth unemployment rate (15-24 years) in the Greater Geelong region over 12 months (to March 2018) is on average 10.7%, Victoria's average is 13.0% and the Australia wide average is 12.6%.
Source: Enterprise Geelong and Australian Bureau of Statistics (Catalogue No 6291.0.55.001).
Note – Unemployment rate data for Geelong, Victoria and Australia is based on ABS original data (sourced from survey respondents rather than trend or seasonally adjusted data).
The unemployment rate data is also adjusted to a three month rolling average to smooth out some of the volatility in the monthly data.
*The Geelong SA4 geographical level includes the City of Greater Geelong, Borough of Queenscliffe, Surf Coast Shire and the majority of Golden Plains Shire.
- What if I need something done that is not on your list of services?
Give us a call – we will be able to tell you if we have capacity to complete a task that is not listed on our website.


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Park "Gustav Bohutinskog" -he was the formerof the farmyard College eventually converted into a park that in 1901. which was extended to land on the south side.
For over an extended surface arranged in 1903. The new park designed by Viteslava Durhaneka. The new organization of the park, which is now divided into external and internal, abandoned the geometric segmentation, and the basic design element becomes a series of asymmetrical circles that touch or intersect, thus creating an irregular network of hiking trails.
Comply with the release of large areas of land, especially the regulation of public parks 1922nd, which were later added and other recreational facilities. Economic education is encouraged to create a strong green zone, which is the functional and aesthetic-shaped urban terms become determinant of the eastern part of Križevci. In 1971. based on the former Act on the Protection of Nature Park is a protected monument of nature.
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As I have pointed out numerous times before, the House of Marley knows what it is doing in regards to putting out some cans that have ultra premium sound behind them, so I was more than happy to give the Redemption Song a chance to tickle my aural pleasure center. My old House of Marley headphones had unfortunately snapped in half due to an unfortunate accident involving my Jeep running over a messenger bag. It was a sad time indeed, but being able to try out another pair of headphones from this company made all the sadness worth it. I really loved the Stir It Up model more than any of my other sets of cans, so that was going to be the baseline here. How well would the Redemption Song stand up to its brother? Which would ultimately crank out the best tunes?
Much like the Stir It Up headphones (and in truth, most of the House of Marley's offerings), the Redemption Song is full of high class retro style (yes, that's a thing). One look at them makes you feel like a Rasta from the 60's – the FSC certified beech wood that the House of Marley uses on most of its products has that effect on me all the time. Along the head band there are a few holes in the sustainable tanned leather where you can see the colors of the Rastafarian flag shining through, a small tribute to the House of Marley's roots. The Redemption Song headphones are also extremely plush though, with the aforementioned head band being nicely padded – enough so that it never becomes a comfort issue. The ear cups are also very well padded on the Redemption Song, even more so than the Stir It Up model – however I still had the issue where after an hour or so I would have to constantly re-adjust them because they were tight. Again just like with the Stir It Up model, I had to work through a painful break in time and allow some of the tension in the head band to work itself out; once that was done though, they were as comfortable as the Stir It Up's – if not more so.
Something else I complained about when reviewing the Stir It Up headphones was that I had an issue with my sound cord – I was not aware what caused the issue (whether it be a factory defect or just a cable that was easily broken), but whatever it was did not make a repeat appearance here. I am happy to say that the cord that came with my Redemption Song headphones works perfectly with them – I might wish that the in line remote had a button to go forward or go backward in your playlist, but that's a pipe dream I have with most headphone cords. As it stands though, the volume up and down buttons and pause / play button works just right with my iPhone; apparently they do not work to raise and lower the volume on Androids though (as per the website).
On the website House of Marley claims that the "40mm moving coiled drivers deliver a stunning music experience with all the detail and bass of a live performance", which is something I had to test out for myself (being somewhat of a live show aficionado). I threw everything I could at these beauties to try and push the drivers – from some old 2 Live Crew to my Happy Hardcore disc to some Dethklok for good measure. The bass never distorted no matter the volume level I had set, and the detail was astounding. I was incredibly impressed at just how clear everything was at max volume. Even when I put on some old live shows that I hadn't listened to in a long time, the Redemption Song headphones delivered sound that was phenomenal. Not only was the bass clear and distinct, but the rest of the sound spectrum was just as equally impressive. Highs were crisp and clear and the mids were as they should be: refined and clean.
So impressed with the sound that came out of the Redemption Song headphones that I was more than willing to make sure that they became my "go to" set of cans, and they now have a permanent place inside of my new messenger bag. One thing that I absolutely love about the House of Marley headphones tat I have reviewed so far, is that they have all come with their own little canvas bag for storage. These little satchels make it really easy to find the headphones when you have them in another bag. They also ensure that you don't lose your audio cord by giving you a place to store it when not in use (since we all know it is unwise to just leave the cord plugged in while in storage).
I will say that I likes the outer design on the ear cups themselves on the Stir It Up headphones slightly better than the design on the Redemption Song. It is just a personal preference I know, but I definitely liked the way that the cans looked with a solid wood exterior instead of the wood with a hole in the center. Apart from that little thing though, I really did like the rest of the Redemption Song design more. It was more comfortable that the Stir It Up model (though not by a whole lot), and it felt a bit more high class than the other. All in all, this is a top quality pair of headphones to make your ears sing with joy.
Editor's Rating:
Bottom Line: This is the second pair of headphones I've given the perfect rating to, and by all means they deserve it; apart from a slightly painful breaking in period (that could be due to the size of my head) these have been a complete joy to use.
- Made pretty much entirely from Earth friendly materials
- The sound that they put out is unparallelled
- As always, House of Marley hits the style nail right on the head
- Like with the Stir It Up model, the break in period can be painful
You can pick up a pair of the Redemption Song On Ear Headphones from the House of Marley's online store for $199.99
Also why not check out:
- 6 of the Best On Ear Headphones
- A-Audio Legacy Over-Ear Luxury Headphones Giveaway from Gadget Review (contest)
- Audeze EL-8 Open-Back Over-Ear Headphone Review
- Audeze SINE On-Ear Headphone Review
- Beats by Dre Mixr On-Ear Headphones Review
- Beats by Dre Remastered Studio Over-Ear Headphones Review
- Bose OE2 Headphones
- Bowers & Wilkins P7 Wireless Over-Ear Headphones Review
- Bowers and Wilkins P3 Mobile Hi-Fi Headphones Review
- California Headphones Loredo On-Ear Headphones Review
- Fanny Wang 1001 Headphone Review
- Ferrari by Logic3 Scuderia P200 Classic Black Over-Ear Headphones Review
- Gigabyte FLY On-Ear Headphones Review
- HiFiMAN HE-400 Headphones Review
- i-mego THRONE Over Ear Headphones Review
- Incase Reflex Headphones Review
- JBL Tempo On-Ear Headphones Review
- Logitech UE 900 Noise-Isolating Earphones Review
- Marshall Major Headphone Review (video)
- Marshall Major Headphones (update)
- Phantom Headphones with Boombox Review
- Phiaton Bridge MS 500 On-Ear Headphones Review
- Sharkk Bravo Hybrid Electrostatic Headphones Review
- SMS Street by 50 ANC Review
- Stir It Up On Ear Headphones Review
- Urbanears Plattan Headphone Review
- Urbanears Zinken (Petrol) Headphone Review
- V-Moda Crossfade LP2 Limited Edition Over-Ear Headphones Review
- V-Moda Crossfade M-100 Metal Over-Ear Headphones Review


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Today marks the start of Stampin' Up!'s biggest sale of the year! For the next 3 months, you'll get to take advantage of our Sale-A-Bration sale! I'm super excited about this sale…not only has Stampin' Up! come out with 6 new exclusive products that you can earn free; they are including stamp sets out of the regular catalogue this year that you can also choose as your free item with your $65+ order.
Here are the details:
Sale-A-Bration Sale (January 5-March 31st, 2010)
Contact me to schedule your Sale-A-Bration party with friends!
Starter Kit Promotion ( (January 5-March 31st, 2010)
Click here for more info on becoming a demonstrator. This is a great time to join!
Digital Starter Kit (until March 31, 2010)
Heart Shaped Treat cups & Limited edition stamp set
Check out the limited edition 'heart shaped' clear treat cups and coordinating stamp set for some awesome 'heart felt' treats for that special person.
The cups and stamp set coordinate with our Full Heart Punch (#113693).
Last chance reminder….
Join me for an open house to stamp 3 great projects using the NEW Occasions Mini & Sale-A-Bration products! I'll have a raffle, a Big Shot Board (you could win a free Big Shot) and lots of new samples to show you!
Wednesday January 6th
Choose a time: 11-1 or 6-8
Cost: $10 or FREE with a $20+ order
Location: Josee's Stamping Studio
RSVP and let me know which time frame you plan to attend
Our Sale-A-Bration sale starts in January…for every $65 you spend, you'll get to pick a free stamp set or an exclusive punch or paper pack! WOW! Here's one of the super cute projects we'll be making. —->


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Our good friends in the pacific northwest have resurrected the classic "Northwest Metalfest" name and we are the first band to be announced. This will be almost exactly two years since our last Seattle appearance and we are beyond excited to return south of the wall. We are not in a position to spill any beans regarding the rest of the lineup but we are assure you that fans of the olde-schoole will be tickled by the bands that the fest has lined up for you.
In their own words:
"Originally founded by concert promoter, Lipstick bassist and local scenester Brett Miller, he launched the first Metalfest on September 19, 1981 at Lake Hills Roller Rink/Crossroads. This landmark concert featured TKO, The Mob (featuring members of Queensryche), Babylon (featuring Geoff Tate on vocals and singing for both bands that historic night), Perennial, Open Fire, Myth, Rampage and Little Wing. The second Metalfest was held on August 29, 1982 and again TKO were the headliners - along with the first NW appearance of Portland's Wild Dogs, Culprit, Overlord, Realms, Myth (with Geoff Tate on vocals) and Kidskin.
Now all of these years later NW Metalfest returns! James R. Beach and Brian Naron of the retro record label NW Metalworx Music (also soon to include a history book on the NW metal scenes) have joined forces with local musicians and concert promoters/bookers Amy Lee Carlson and Max Nazaryan (also of the band Substratum) and local scenester Michael Podrybau (also of the 80s bands Glacier and Harlot) to bring you an Annual 2-day extravganza. We're calling it NW Metalfest in the spirit of those classic concerts back in the day with Brett Miller's blessing. We hope to bring back the vibe of those exciting shows and give some attention to both the great older and newer bands in the local areas."


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Entertainment » Television
Watch: A New and Sexy (!) 'Stranger Things 3' Teaser has Arrived
It may be a few more months before the third installment of Netflix's highly anticipated "Stranger Things" returns but the streaming shared a new teaser for upcoming season.
Titled "Summer in Hawkins" — that is Hawkins, Indiana where the show takes place — the 105 second clip takes place in the peak of summer in 1985. School is out and things are heating up for this sci-fi thriller: The clip plays out at a public pool over a synth-y soundtrack but...nothing spooky happens!
The clip comes just two months after Netflix dropped an official trailer, which you can watch by clicking here.


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The IEEE Cledo Brunetti Award was established in 1975 through a bequest made by the late Cledo Brunetti, who was an executive of the FMC Corporation.
Recipient selection is administered through the Technical Field Awards Council of the IEEE Awards Board.
Sponsor: Brunetti Bequest
Presented to: An individual or a team of not more than three
Scope: For outstanding contributions to nanotechnology and technologies for microsystem miniaturization
Prize: The award consists of a bronze medal, a certificate, and honorarium.
Basis for judging: In the evaluation process, the following criteria are considered: innovation, development, social value, uniqueness of concept, other technical accomplishments, and the quality of the nomination.
Nomination deadline: 15 January
Endorsement deadline: 31 January
Notification: Recipients are typically approved during the June IEEE Board of Directors meeting, usually held towards the end of the month. Recipients and their nominators will be notified following the meeting. Subsequently, the nominators of unsuccessful candidates will be notified of the status of their nomination.
Presentation: IEEE policy requires that its awards be presented at major IEEE events that are in keeping with the nature of the award and the cited achievement.
15 January
Technical Field Awards
Eric Herz Staff Award
15 June


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OHMYGOSSIP — Kim Kardashian West is travelling to Dubai to make her first official appearance since the Paris robbery.
The 'Keeping Up With The Kardashians' star shared a picture of herself and Scott Disick as the pair headed to the city in the United Arab Emirates just over three months after Kim was robbed at gunpoint in the French capital.
Captioning the photograph, she simply wrote: "on our way #dubai (sic)"
And the 36-year-old television personality could soon see her tough few months of unknowns come to an end after 16 people were arrested in connection with the robbery.
A source recently shared: "Kim is deeply relieved to know that this horrible ordeal will all come to an end soon."
And Kim – who had an estimated $10 million worth of jewellery stolen in the terrifying incident – is hopeful she may get her engagement ring back as police believe two unidentified brothers – who they have arrested – could have the information to lead them to the expensive piece of jewellery.
An insider explained: "They are involved in the diamond trade, and are thought to have handled the stolen jewellery.
"Their homes have been searched from top to bottom, and so has a jewellery shop in Paris which is also linked to them. The jewellery has not yet been found, but these brothers could lead us to it over the coming days."
It is thought the jewellery could have been sold in Antwerp, Belgium as the source claims that is where items like these "can be sold on with no questions asked".
They added: "Antwerp is a town where jewellery can be sold on with no questions asked. The men know the industry inside out, and may well know exactly where the ring went."
Find more OHMYGOSSIP Showbiz news HERE
High quality & nature friendly luxury cosmetics from Scandinavia - ElishevaShoshana.com


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The Inchbald School of Design was founded by Jacqueline Duncan in 1960 and was the first of its kind in Europe.
In 1972, Inchbald started offering courses in garden design – the first to do so in the world. John Brooks was one of the original lecturers and who today is a leading influence in interior and garden design both in the UK and internationally. Former garden design alumni include Luciano Giubbilei, Marcus Barnett and Haruko Seki and past interior design graduates include Henrietta Spencer-Churchill and Zaha Hadid.
What is it like to study at Inchbald?
Inchbald is a borderline fine art school and thus there is a strong emphasis on developing your design style. Often, time was spent learning the methods of past masters such as Henry Repton, 'Capability' Brown and Geoffrey Jellicoe, but we also had lectures by leading contemporary garden designers such as Anthony Paul, Charlotte Rowe and Luciano Giubbilei. At Inchbald we were encouraged to explore art and architecture, to learn about their aesthetics and concepts, and to stretch our imaginations and look at things differently.
Our first class exercise was held at the Victoria and Albert Museum (over a cup of tea, naturally) where we had to write down, as quickly as possible, 12 different uses for a brick. We would begin by thinking of the most obvious uses first, but then we would have to think more deeply, more laterally. My final idea was to grind the brick, mix it with cream and to apply it as an exfoliant!
Design across different cultures
The business of garden and landscape design is taken seriously in European countries, particularly in England, France, Spain and Italy where – along with art, architecture and fashion – it forms an integral part of each country's identity.
London in particular is buzzing with such cultural intensity: the capital attracts driven passionate individuals, who share and develop original, exciting ideas. Garden designers in London are always pushing the boundaries of possibility but additionally there is a demand from clients for innovative ideas. In a dense city like London outside spaces are prized and it is perhaps the nature of small, unusually-shaped spaces that necessitates creative solutions.
A private garden, no matter how small, is a basic need to a majority of people and therefore it is only right that we respect the value they hold for their owners and those who spend time in them. Genius loci is Latin for 'spirit of place' which means the heart and soul of a space—its character. This is the basic principle of landscape design and therefore it is crucial to spend time within a space and to absorb its real essence, so that the resulting garden is rooted in its essential qualities.
At Inchbald we were also taught to understand our clients as deeply as possible: to hear their stories, to listen for feeling and meaning. It's important to establish a sincere respect for the client's paradigms and concerns from the outset, and to communicate with them often during the design process.
The Inchbald School of Design is moulded on concept development. The concept is key as it links the client with their design and helps me to develop my graphic language. This language then brings consistency to the design's form and unites the physical elements within it.
In all, outdoor spaces are vital and a rigorous design approach is required to do them justice. As Roberto Burle Marx once said "A garden is not simply the product of frivolous idleness… a garden is, or ought to be, an integral part of civilized life, a spiritual and emotional necessity…"


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And by success, I mean real success. Successful projects are usually based on one or all of three factors depending on who is doing the judging. These are on time delivery, on budget delivery and customer satisfaction. Which one is the biggest to you and your organization? That may depend on who is doing the judging.
I can guarantee you that the CFO is most concerned about the financial bottom line. The CEO is probably concerned about all three... but he's probably most concerned with the customer satisfaction level as that's where customer referrals, testimonials and returning engagements come from. And the rest of the stakeholders are likely somewhere in between.
I have five steps to consider on the road to the highest customer approval rating possible... as you read please think about your own list and feel free to share...
Hands on customer engagement.
Yes, you may not think so or want to do it, but your customer wants and needs your hand holding on many project engagements. The more they know that the project is going well, that their money is being spent wisely and timely, and that forward progress is always being made, the better. And it's all about their customer satisfaction. Hands on means lots of communication – which is Job One for the project manager, business analyst and team. Don't skip status reports, don't cancel meetings, don't slide deliverables whenever possible. Even if they aren't always examining every detail and listening to every word, hearing you and seeing your reports and emails tells them a lot and sometimes enough about what's going on and how "on it" you are. That gives them a warm, confident feeling. The less they hear from you the less they think you are doing. Don't give them the opportunity to wonder and imagine that things aren't going well. Show them that they are going well.
Key aspects of the team-customer communication process.
Be careful when communicating with the client. I believe in 100% transparency for both the good and the bad information on the project. But the bad must be analyzed before conveyed. Do you like it when someone comes to you with only bad information or a major issue or do you prefer they come to you with bad information and one or more proposed courses of action. Now if it's your 4 year old son which it often is for me, his choice of mitigation may not be the best one to act upon, but when your project team comes to you or you go to the project customer, it is very conceivable – and expected – that you've dutifully thought it out and have 2-3 actions plans to discuss and choose from. Trust me, your customer confidence and overall reaction to the bad news will be much much higher if you present potential and workable solutions with the bad news.
Project meeting planning and management.
Well planned out project meetings can end with higher productivity in the meetings also resulting in higher customer confidence and approval ratings. The well planned out meeting isn't that hard to pull off. Stick to what I like to call my key ingredients to the perfect project meeting and your customer and team – and all stakeholders – confidence, satisfaction and participation levels will be the highest possible...
- Put out a clear agenda in advance every time. Always provide and agenda and general status in advance to all expected attendees. This way everyone will know what is expected in advance and will come prepared to discuss – no excuses.
- Focus on a meaningful purpose. Focus on what is necessary and what you want to accomplish. Being too broad or too general will result in less productivity and more followup meetings.
- Don't hold meetings just to hold meetings. Be specific and make your meetings important. But don't cancel easily either – cancelling regular revolving meetings can cause individual attendees to lessen the importance of your meetings in their own heads and it will become easier and easier to skip your meetings. Keep the meetings even if they are shorter in length than planned – you never know when a critical piece of info may fall through the cracks if you cancel.
- Start on time and end on time. Be punctual and don't get in the habit of bringing latecomers and no-shows up to date. That's their job – and if you do so they will always come late or skip.
- Followup with notes. The goal of any meeting is communication. Follow up with notes afterwards and ask for feedback within 24 hours. You want everyone on the same page as you move forward.
Resolving issues and errors in delivery.
Taking care of issue and error resolution in a timely fashion will always help with customer satisfaction. Too many times – especially with tech projects – we hand the end solution off with a few outstanding issues and plan to regroup later or leave for the customer to deal with.
Of course we do this only with the customer's blessing, but wouldn't it be better if we could hand off quality, error free solutions rather than something that is 95% of the way there? Strive for perfection always and expect the best – as the customer should expect. Put yourself in their shows... if you're buying a new car are you happy driving it off the lot with a couple of scratches that you agree to bring back in the next month to have fixed? Not likely – you'll do it but it doesn't mean you'll ever feel good about shopping there again for a new car. It's a lot of money to spend on something that isn't perfect.
Handling final review and sign off of the project with the customer.
A quality end project handoff is probably one of the single biggest things you can do to ensure high customer confidence and approval ratings. How do you do that? Plan for and schedule and actually conduct a lessons learned session post implementation. That chance to regroup and review the project tells the customer you care and will lead to a much higher likelihood of return business no matter how the project went. You also do it by planning with support and your own team to support client needs post implementation for a specific period of time... one month, three months, whatever. It says I care and I'm responsible for the work I'm handing off.
Summary / call for input
These are just five steps out of many to help your customer gain and keep confidence in how the project is going and therefore remain more confident throughout that the end result is going to be successful.
Readers – what is your take? Do you agree with this list? What would you change about it? Please share and discuss.


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On September 15, 2018, led by Jim Nix of the Ellen G White Estate, the GC leaders spent a Sabbath at the Miller Farm, experiencing the vision and sacrifice of our Adventist pioneers.
September 25, 2018 | By Travis Dean
The Southern New England Conference Executive Committee met at the Bates Site. The committee members were very impressed with the Bates site. Many of them had not ever been here before. In all there were about 25 individuals present.
September 23, 2018 | By Lloyd Hallock


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'Bedroom tax' - making sure carers' voices are heard in the Government appeal
In January we saw a significant step forward for carers affected by the 'bedroom tax' when Carers UK members Paul and Susan Rutherford took the Government to the Court of Appeal – and won. But with a Government appeal looming, we are fighting harder than ever to make sure vulnerable people affected by the policy have their voices heard.
Who are Paul and Susan Rutherford?
Carers UK members Paul and Susan Rutherford care for their profoundly disabled 14-year-old grandson, Warren.. They live in a specially adapted home which has a room for a professional care worker to stay when providing overnight care. This room was deemed spare, meaning the Rutherfords were hit by the 'bedroom tax' and their housing benefit was reduced.
What happened?
The Rutherfords took the Government to court to appeal – and won! The judges accepted that the bedroom tax unlawfully discriminates against disabled children requiring overnight care, as unlike for adults, the rules do not allow for an additional bedroom for their overnight carer or care worker. You can read more about the case here.
How were Carers UK involved?
We were delighted to hear the news. Along with our members, we have argued that the 'bedroom tax' unfairly penalises carers since it was first introduced in April 2013.
Our Director of Policy and Public Affairs Emily Holzhausen gave a statement of evidence in the original case which was referred to in the judgment. She argued that families who have a clear need for additional bedrooms for a carer or care worker should be entitled to an additional room, and that alternatives suggested by the government – such as moving to smaller accommodation or taking in a lodger – are not appropriate for carers.
Does this mean the 'bedroom tax' has been absolished?
Unfortunately not. Firstly, the judgment only rules that the 'bedroom tax' is discriminatory in the specific circumstances of the people in the case. We don't know exactly how many carers are in similar circumstances to the Rutherfords but Child Poverty Action Group who are representing the Rutherfords have said there could be thousands in a similar situation. So far the regulations around the 'bedroom tax' have not been amended.
Secondly, the Government announced it will appeal the decision. The case will be heard in the Supreme Court on Monday 29 February 2016.
What are Carers UK doing about it?
As the Government appeal date approaches, we put out a call for carers in similar circumstance to the Rutherfords to share their story and we have gathered evidence to strengthen the case at the Appeal hearing.
We know from our research that carers affected by the 'bedroom tax' are often left unable to pay their bills, with some families falling behind on rent.
We're continuing to urge the Government to amend the regulations to protect carers like the Rutherfordsand to exempt all carers from the Bedroom Tax
What will happen in the appeal?
Along with the Rutherfords case, the Supreme Court is also considering several other cases about the Bedroom Tax including cases where a carer is not able to share a room with a partner that they are caring for and cases where adaptations have been made to the property.
The variety of cases means that the results of the appeal could have a range of different implications for carers. We will provide information and advice on how carers could be affected as soon as possible after the judgment is made public.


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Akaha (アカハ (also known as 龍玄の右腕))Akaha's father was a member of a criminal society called Ryuugen who did not report the true sale of drug. Since childhood, Akaha has been fleeing with his parents, but they were caught by a higher-up of Ryuugen (called Sawaki) one day. Sawaki killed Akaha's parents, but he spared Akaha (because he didn't cry or beg). Since that day, Akaha lost his real name (Akaha was an alias given by Sawaki) and become Sawaki's personal subordinate, also known as Sawaki's right hand.
According to the police's information, "the right hand of Ryuugen" is the No.2 leader in Ryuugen. Akaha actually held that position too.
In the first OVA, Akaha disguised as Kagura Akito and met Kai Etou (one of the main character) who came to the same botanical garden for investigation. Kai seemed to like Akito a lot, without discovering that he was actually Akaha. In the manga, Kai has taken care of Akaha once, when Akaha is injured in an accident and lost his memory for a short period of time. He said to Kai that he doesn't want to go back to Ryuugen, it is unccertain whether this is a truth or a lie.
Voice ActorsNo voice actors have been added to this character. Help improve our database by searching for a voice actor, and adding this character to their roles here.


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Portfolio Allocation for Public Pension Funds
NBER Working Paper No. 16456
This paper presents a dynamic model of a public pension fund's choice of portfolio risk. Optimal portfolio allocations are derived when pension fund management maximize the utility of wealth of a representative taxpayer or when pension fund management maximize their own utility of compensation. The model's implications are examined using annual data on the portfolio allocations and plan characteristics of 125 state pension funds over the 2000 to 2009 period. Consistent with agency behavior by public pension fund management, we find evidence that funds chose greater overall asset - liability portfolio risk following periods of relatively poor investment performance. In addition, pension plans that select a relatively high rate with which to discount their liabilities tend to choose riskier portfolios. Moreover, consistent with a desire to gamble for higher benefits, pension plans take more risk when they have greater representation by plan participants on their Boards of Trustees.
Machine-readable bibliographic record - MARC, RIS, BibTeX
Document Object Identifier (DOI): 10.3386/w16456
Published: Pennacchi, George & Rastad, Mahdi, 2011. "Portfolio allocation for public pension funds," Journal of Pension Economics and Finance, Cambridge University Press, vol. 10(02), pages 221-245, April. citation courtesy of
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