text:
Copyright: Copyright in the papers created by Sylvia Wright Mitarachi is held by the President and Fellows of Harvard College for the Schlesinger Library.
Sylvia Wright Mitarachi was born Sylvia Wright on January 21, 1917, to Austin Tappan Wright and Margaret “Margot” T. Stone Wright in Berkeley, California. Her father was a law professor at the University of California, Berkeley. Her mother was the niece of pianist Amy Fay. She was one of four children. She married Paul J. Mitarachi and the couple had one son, John Paul, in 1962.
Mitarachi was a graduate of Bryn Mawr College. Following graduation, Mitarachi edited and prepared for publication her father’s book, Islandia. During World War II, she worked for the Office of War Information and, following the war, for the United States Information Service, known in the United States as the United States Information Agency. During the 1950s, Mitarachi was an editor at Harper’s Bazaar and contributed numerous articles. A collection of her articles was published in 1957 under the title Get Away from Me with Those Christmas Gifts. In 1969, she published the a collection of three novellas, A Shark Infested Rice Pudding.
In 1977, Mitarachi became a fellow at the Bunting Institute at Radcliffe College. During this time she continued research on her biography of her great aunt, Melusina Fay Peirce, an early feminist, author, and founder of the Cambridge Co-operative Housekeeping Society in Cambridge, Massachusetts. Following her fellowship year, she continued her research for the book. Mitarachi died of cancer on May 9, 1981, leaving the biography of Peirce unfinished.
The Sylvia Mitarachi Papers, 1834-1990 are held by the Schlesinger Library, Radcliffe Institute for Advance Study, Harvard University. They include both Fay family papers and papers of the Cambridge Co-operative Housekeeping Society.
The Fay Family Papers, 1800-1953 are held by the Schlesinger Library, Radcliffe Institute for Advance Study, Harvard University.
The Sylvia Mitarachi Papers consist of a copy of a draft manuscript for Mitarachi’s unpublished biography, The Life of Melusina Fay Peirce. The manuscript consists of 229 numbered pages and several additional chapters (which may have been written by Mitarachi’s friend Susanna Robbins). The manuscript is a biography of Mitarachi’s great aunt, Melusina Fay Peirce, an early feminist, author, and founder of the Cambridge Co-operative Housekeeping Society, an early scheme to establish a central cooking and laundry service outside of the home to which households would subscribe in order to share the costs of services.

lowercased:
copyright: copyright in the papers created by sylvia wright mitarachi is held by the president and fellows of harvard college for the schlesinger library.
sylvia wright mitarachi was born sylvia wright on january 21, 1917, to austin tappan wright and margaret “margot” t. stone wright in berkeley, california. her father was a law professor at the university of california, berkeley. her mother was the niece of pianist amy fay. she was one of four children. she married paul j. mitarachi and the couple had one son, john paul, in 1962.
mitarachi was a graduate of bryn mawr college. following graduation, mitarachi edited and prepared for publication her father’s book, islandia. during world war ii, she worked for the office of war information and, following the war, for the united states information service, known in the united states as the united states information agency. during the 1950s, mitarachi was an editor at harper’s bazaar and contributed numerous articles. a collection of her articles was published in 1957 under the title get away from me with those christmas gifts. in 1969, she published the a collection of three novellas, a shark infested rice pudding.
in 1977, mitarachi became a fellow at the bunting institute at radcliffe college. during this time she continued research on her biography of her great aunt, melusina fay peirce, an early feminist, author, and founder of the cambridge co-operative housekeeping society in cambridge, massachusetts. following her fellowship year, she continued her research for the book. mitarachi died of cancer on may 9, 1981, leaving the biography of peirce unfinished.
the sylvia mitarachi papers, 1834-1990 are held by the schlesinger library, radcliffe institute for advance study, harvard university. they include both fay family papers and papers of the cambridge co-operative housekeeping society.
the fay family papers, 1800-1953 are held by the schlesinger library, radcliffe institute for advance study, harvard university.
the sylvia mitarachi papers consist of a copy of a draft manuscript for mitarachi’s unpublished biography, the life of melusina fay peirce. the manuscript consists of 229 numbered pages and several additional chapters (which may have been written by mitarachi’s friend susanna robbins). the manuscript is a biography of mitarachi’s great aunt, melusina fay peirce, an early feminist, author, and founder of the cambridge co-operative housekeeping society, an early scheme to establish a central cooking and laundry service outside of the home to which households would subscribe in order to share the costs of services.


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In Choosing Not To Defend An Insured, The Insurance Company Is Acting At Its Own Peril.
Ryan Pretner suffered critical injuries when he was hit by a truck driven by Michael Vasquez. Mr. Vasquez’s truck was covered by two auto policies, his personal policy, and his business auto policy. His personal insurance with Progressive had a limit of $100,000 per person. His commercial auto policy with Century Surety Company had a $1,000,000 limit.
Century Surety conducted an investigation and determined that Mr. Vasquez was not in the course and scope of his business as an auto detailer with Blue Streak Auto Detailing.
Mr. Pretner served Mr. Vasquez and Blue Streak with a demand to settle for the policy limit. Century Surety refused the demand. Mr. Pretner (via his legal guardian Dana Andrew) filed suit against Mr. Vasquez and Blue Streak alleging that Mr. Vasquez was in the course and scope of his business when the accident happened. Mr. Pretner’s counsel notified Century Surety of the lawsuit. Despite the allegations in the complaint, Century Surety insisted that the claim was not covered under its policy of insurance and did not take up the defense.
Progressive paid its $100,000 policy and in return secured a covenant not to execute, in favor of Vasquez and Blue Streak. As part of that arrangement, Vasquez and Blue Streak assigned their rights against Century Surety to Pretner and his guardian Adams.
Pretner then took a default judgment against Vasquez and Blue Streak for $18,050,183. Pretner filed suit against Century for breach of contract, breach of the implied covenant of good faith and violations of Nevada’s Unfair Claims Settlement Practices Act. Century Surety removed the matter from state court to federal court.
The federal court found that Century Surety had not acted in bad faith. Then the court had to decide whether Pretner’s recovery from Century Surety would be limited to the policy limit or whether it could be in excess of the policy. Initially, the court leaned toward limiting Century Surety’s damages to the $1,000,000 commercial auto policy. But after reconsideration, the federal court certified the following question to the Nevada Supreme Court.
In answer to that question, the Nevada Supreme Court issued its opinion in Century Surety Co. v. Andrew, 100 Nev. Adv. Op 100, 432 P.3d 180 (2018). In that opinion, the Court said that where an insurance company violates the duty to the defend, all courts agree that the insured is entitled to recover the insured the costs in mounting his or her own defense.
It went on to say however that the courts are split on the question of whether damages should be limited to the amount of the policy.
The Court said that the majority view limits recovery from the breaching insurance company to the amount of the policy limit. See Hamlin Inc. v. Hartford Accident &Indemnity Co., 86 F.3d 93,95 (7th Cir. 1996). There the court said that since the insured defended itself, it could not have done better with an insurance company assigned attorney. Therefore the damages should be limited to what they would have been had the insurance company not violated the duty to defend.
(3) any additional costs that the insured can show naturally resulted from the breach.
Newhouse v. Citizens Sec. Mut. Ins. Co., 501 N.W.2d 1, 6 (Wis. 1993).
As an example, the Court cited to Delatorre v. Safeway Insurance Co., 989 N.E.2d 268, 274 (Ill. App. Ct. 2013), where the court found that the entry of a default judgment against the defendant directly flowed from the insurer’s breach. The Delatorre court found that the insurer was liable for the entire amount of the default judgment, even though that amount was above the policy limit.
The Court did not reach a decision that the insurance companies that breached the duty to defend must automatically pay all damages over and above the policy limit. The insured must still take reasonable efforts to avoid losses where possible.
However, the court did say that the insurance company may be on the hook for consequential damages, including (including those over and above the policy limit) even if the insurance company committed no bad faith by choosing not to defend its insured.
The clear message sent by the Court is that when an insurance company is deciding whether it will defend its insured, and it chooses not to, the company is doing so at its own peril.
If you have further questions about the duty to defend in Nevada, please contact Mike Mills at Bauman Loewe Witt & Maxwell. He can be reached at 702.240.6060×114. You can also send him an email at mmills@blwmlawfirm.com.

lowercased:
in choosing not to defend an insured, the insurance company is acting at its own peril.
ryan pretner suffered critical injuries when he was hit by a truck driven by michael vasquez. mr. vasquez’s truck was covered by two auto policies, his personal policy, and his business auto policy. his personal insurance with progressive had a limit of $100,000 per person. his commercial auto policy with century surety company had a $1,000,000 limit.
century surety conducted an investigation and determined that mr. vasquez was not in the course and scope of his business as an auto detailer with blue streak auto detailing.
mr. pretner served mr. vasquez and blue streak with a demand to settle for the policy limit. century surety refused the demand. mr. pretner (via his legal guardian dana andrew) filed suit against mr. vasquez and blue streak alleging that mr. vasquez was in the course and scope of his business when the accident happened. mr. pretner’s counsel notified century surety of the lawsuit. despite the allegations in the complaint, century surety insisted that the claim was not covered under its policy of insurance and did not take up the defense.
progressive paid its $100,000 policy and in return secured a covenant not to execute, in favor of vasquez and blue streak. as part of that arrangement, vasquez and blue streak assigned their rights against century surety to pretner and his guardian adams.
pretner then took a default judgment against vasquez and blue streak for $18,050,183. pretner filed suit against century for breach of contract, breach of the implied covenant of good faith and violations of nevada’s unfair claims settlement practices act. century surety removed the matter from state court to federal court.
the federal court found that century surety had not acted in bad faith. then the court had to decide whether pretner’s recovery from century surety would be limited to the policy limit or whether it could be in excess of the policy. initially, the court leaned toward limiting century surety’s damages to the $1,000,000 commercial auto policy. but after reconsideration, the federal court certified the following question to the nevada supreme court.
in answer to that question, the nevada supreme court issued its opinion in century surety co. v. andrew, 100 nev. adv. op 100, 432 p.3d 180 (2018). in that opinion, the court said that where an insurance company violates the duty to the defend, all courts agree that the insured is entitled to recover the insured the costs in mounting his or her own defense.
it went on to say however that the courts are split on the question of whether damages should be limited to the amount of the policy.
the court said that the majority view limits recovery from the breaching insurance company to the amount of the policy limit. see hamlin inc. v. hartford accident &indemnity co., 86 f.3d 93,95 (7th cir. 1996). there the court said that since the insured defended itself, it could not have done better with an insurance company assigned attorney. therefore the damages should be limited to what they would have been had the insurance company not violated the duty to defend.
(3) any additional costs that the insured can show naturally resulted from the breach.
newhouse v. citizens sec. mut. ins. co., 501 n.w.2d 1, 6 (wis. 1993).
as an example, the court cited to delatorre v. safeway insurance co., 989 n.e.2d 268, 274 (ill. app. ct. 2013), where the court found that the entry of a default judgment against the defendant directly flowed from the insurer’s breach. the delatorre court found that the insurer was liable for the entire amount of the default judgment, even though that amount was above the policy limit.
the court did not reach a decision that the insurance companies that breached the duty to defend must automatically pay all damages over and above the policy limit. the insured must still take reasonable efforts to avoid losses where possible.
however, the court did say that the insurance company may be on the hook for consequential damages, including (including those over and above the policy limit) even if the insurance company committed no bad faith by choosing not to defend its insured.
the clear message sent by the court is that when an insurance company is deciding whether it will defend its insured, and it chooses not to, the company is doing so at its own peril.
if you have further questions about the duty to defend in nevada, please contact mike mills at bauman loewe witt & maxwell. he can be reached at 702.240.6060×114. you can also send him an email at mmills@blwmlawfirm.com.


text:
On Jan. 31, the governments of France, Germany and the United Kingdom formally announced the establishment of the Instrument in Support of Trade Exchanges (INSTEX), a Special Purpose Vehicle dedicated to facilitating trade between European economic actors and Iran. The creation of INSTEX by the three countries—known as the E3—followed months of negotiations in the wake of the United States’s 2018 exit from the Iran nuclear deal. That deal lifted international sanctions on Iran in exchange for Tehran imposing restrictions on its nuclear program. Following its exit from the deal, the U.S. reimposed “secondary” sanctions that prohibit American companies from doing business with foreign companies that do business in Iran.
While operational details for INSTEX still need to be defined, the vehicle’s underlying objective is to facilitate payment transactions among European and Iranian businesses outside the parameters of the U.S. financial system, which would have to be used if any transactions in U.S. dollars were involved—consequently subjecting any banks facilitating such transactions to U.S. sanctions. At a minimum, INSTEX will oversee a ledger of payments related to exports and imports between Europe and Iran, coordinating payments so that a European exporter of goods to Iran can get paid by a European importer of goods from Iran and thereby avoid entering into a cross-border transaction. An Iranian counterpart to INSTEX would coordinate payments between the Iranian transaction parties. While such a model would admittedly cover only a small portion of Iran’s trades (exports would always have to equal imports in order for the payment transactions to balance out), the hope among many involved with the creation of INSTEX is that it would eventually process all payments among trading participants, functioning more like a bank as opposed to an intermediary focused on pairing export and import liabilities.
The emergence of a financial intermediary vehicle that exists beyond the U.S. financial system has potentially adverse implications for U.S. sanctions policy. Much of the United States’s ability to pressure foreign governments and companies to avoid doing business in Iran—as well as other sanctioned countries—derives from the reliance of global economic actors on access to the U.S. financial system for cross-border transactions. Despite this, American officials have, at least in public, been largely muted in their reactions to the announcement of the plan, stressing that, while they are “closely following” reports on the European mechanism, they do not expect it to impinge on U.S. efforts to exert maximum economic pressure on Iran. Many experts have in fact expressed a lack of confidence in INSTEX’s prospects based on the assumption that its personnel and operation could easily be made subject to additional U.S. sanctions.
Although it is hard to say exactly how INSTEX will affect U.S. sanctions policy until more details about its structure are revealed, there are several key issues that U.S. policymakers ought to consider sooner rather than later in evaluating how to contend with the development of the vehicle. First, it will be politically more difficult for the U.S. to penalize INSTEX and its participants for engaging in problematic activity in the event INSTEX actually does become commercially successful. A thriving INSTEX would mean more European businesses with a vested interest in building commercial ties with Iran, which would consequently place greater pressure on European governments not to yield to American economic pressure without any pushback. The effort by the E3 to establish INSTEX is itself partly the result of pressure from European companies that entered the Iranian market following the execution of the Iran deal and are eager to continue doing business.
Second, the United States’s capacity to exert economic pressure on Iran has in significant respects been driven not just by legal measures such as sanctions but also by the U.S.’s ability to persuade European companies to avoid the Iranian market because of the inherent riskiness of engaging with Iranian counterparties—many of which lack transparent ownership structures and are not required to comply with basic anti-money laundering standards. In particular, this has meant that European companies, especially banks, that engage in business in Iran risk running afoul of other U.S. laws pertaining to internal controls and compliance, and thereby becoming subject to the frequently severe penalties associated with such violations. Indeed, despite the panoply of U.S. sanctions imposed against Iran since 1979, the United States was able to bring the Islamic republic to the economic brink in the late 2000s only after mounting a systematic campaign of outreach that focused on convincing hundreds of European companies of the prohibitively high risks of engaging in business with Iran. Similarly, the Iranian government’s long-running failure to fully implement banking and anti-money laundering reform has played a significant role in the unwillingness of European businesses to enter the Iranian market.
INSTEX effectively reduces the ability of the United States to use this risk as a lever for exerting economic pressure by shifting a component of the risk—specifically, the risk associated with financially intermediating transactions with Iranian counterparties—away from private-sector businesses that have to worry about internal control standards and that are individually more susceptible to pressure from the U.S. government (as well as, in some cases, from public shareholders). That risk is transferred to INSTEX, a quasi-public institution owned and controlled by sovereign governments. The United States will face substantially higher stakes in sanctioning or otherwise economically pressuring these governments if INSTEX does not appropriately manage the risks associated with transacting with Iranian counterparties.
Given the embryonic nature of INSTEX, appropriately gauging and confronting these potential dangers is difficult. Among other things, if the U.S. implements sanctions or other similar punitive action only for INSTEX to become a failure, such action could represent a premature move that generates political blowback without any real benefits. What the United States can do, however, is work to increase transparency around INSTEX so that it and other stakeholders can develop a clearer understanding of the mechanism once it is operational, and become better equipped to undertake the appropriate course of action when the time comes. To this end, one simple measure the United States can implement now is to require foreign companies that are publicly listed on a U.S. stock exchange to disclose their relationships with INSTEX in their periodic securities reports. Under the Iran Threat Reduction and Syria Human Rights Act of 2012 (TRA), U.S.-listed companies are required to disclose various categories of business activities with Iran, including activities that themselves may not be sanctionable. Under its authority to issue interpretive guidance, the U.S. Securities and Exchange Commission (SEC) could advise all listed companies to disclose any direct transactions between them and INSTEX, as well as any transactions that they knowingly facilitate between their counterparties and INSTEX.
From an administrative standpoint, promulgating this standard as guidance would be relatively easy to do (versus, for example, trying to pass a bill through Congress or undergoing a lengthy rule-making process). Guidance also has the public relations benefit of technically being nonbinding, as opposed to a new statute or SEC rule that European policymakers can decry as another example of U.S. extraterritorial law. In addition, the existing statutory language and market practice provide several bases for issuing such guidance.
First, the TRA requires disclosure of all transactions or dealings with the “Government of Iran,” which is broadly defined by the applicable regulations to include “any political subdivision, agency, or instrumentality thereof … any person owned or controlled, directly or indirectly, by the foregoing … [and] any person to the extent that such person is, or has been … acting or purporting to act, directly or indirectly, for or on behalf of the foregoing.” Even though INSTEX is a European entity as a formal matter, the vehicle will have to function as a sort of joint venture with the Iranian government, which would coordinate payments among the Iranian counterparties with which European INSTEX participants transact. In this sense, INSTEX could effectively be considered an “instrumentality” of the Iranian government, or at least an operation in which the Iranian government has an ownership or control interest. The interpretation may seem broad, but it is consistent with how many companies currently disclose their relationships to entities with amorphous relationships to the Iranian government pursuant to the TRA.
Second, the TRA requires disclosure of transactions that are “knowingly conducted” with a designated entity, such as the Iranian government. This requirement is often read broadly and could provide an interpretive basis for requiring companies to disclose transactions that they knowingly facilitate between INSTEX and their counterparties, such as customers. For example, a listed company is deemed to knowingly conduct a transaction with a sanctioned Iranian bank to the extent the company plays an active role in structuring payments or other transactions between a nonsanctioned customer and the bank. By the same logic, a listed company—say, a financial institution—could be deemed to knowingly conduct a transaction with the Iranian government if it actively structures or coordinates a transaction between a customer and INSTEX, such as by facilitating the transfer of a payment from INSTEX to the customer’s account at the bank.
While enhanced disclosure guidance would not constitute a direct fix for the potential problems associated with INSTEX, it would be a relatively easy-to-implement step to further illuminate INSTEX’s activities and the nature of the threat it poses as a financial intermediary vehicle beyond the direct control of the United States. Listed companies, particularly financial institutions, would not be able to forego disclosures that they would otherwise be required to make if they were dealing directly with Iranian financial institutions. This would force these entities to retain some minimal level of reputational risk as a result of engaging in business in Iran. At the same time, by requiring companies to simply provide additional disclosures (instead of imposing new sanctions or other penalties), the United States would make it harder for listed European businesses and their governments to make a credible case that they are being financially punished for engaging in legitimate transactions with Iranian companies—particularly since many would already be required to disclose the underlying business activity pursuant to other provisions of the TRA. U.S. policymakers have time to think through how to deal with INSTEX as it assumes more definite shape, and enhanced disclosure requirements will provide a tool that can be used early on to assist with that exercise.
Sahand Moarefy is a corporate attorney at Wachtell, Lipton, Rosen & Katz. He has previously written on international relations and sanctions policy issues for Foreign Affairs, The Diplomat, Lawfare, The Harvard Law School National Security Journal and The Harvard International Review.

lowercased:
on jan. 31, the governments of france, germany and the united kingdom formally announced the establishment of the instrument in support of trade exchanges (instex), a special purpose vehicle dedicated to facilitating trade between european economic actors and iran. the creation of instex by the three countries—known as the e3—followed months of negotiations in the wake of the united states’s 2018 exit from the iran nuclear deal. that deal lifted international sanctions on iran in exchange for tehran imposing restrictions on its nuclear program. following its exit from the deal, the u.s. reimposed “secondary” sanctions that prohibit american companies from doing business with foreign companies that do business in iran.
while operational details for instex still need to be defined, the vehicle’s underlying objective is to facilitate payment transactions among european and iranian businesses outside the parameters of the u.s. financial system, which would have to be used if any transactions in u.s. dollars were involved—consequently subjecting any banks facilitating such transactions to u.s. sanctions. at a minimum, instex will oversee a ledger of payments related to exports and imports between europe and iran, coordinating payments so that a european exporter of goods to iran can get paid by a european importer of goods from iran and thereby avoid entering into a cross-border transaction. an iranian counterpart to instex would coordinate payments between the iranian transaction parties. while such a model would admittedly cover only a small portion of iran’s trades (exports would always have to equal imports in order for the payment transactions to balance out), the hope among many involved with the creation of instex is that it would eventually process all payments among trading participants, functioning more like a bank as opposed to an intermediary focused on pairing export and import liabilities.
the emergence of a financial intermediary vehicle that exists beyond the u.s. financial system has potentially adverse implications for u.s. sanctions policy. much of the united states’s ability to pressure foreign governments and companies to avoid doing business in iran—as well as other sanctioned countries—derives from the reliance of global economic actors on access to the u.s. financial system for cross-border transactions. despite this, american officials have, at least in public, been largely muted in their reactions to the announcement of the plan, stressing that, while they are “closely following” reports on the european mechanism, they do not expect it to impinge on u.s. efforts to exert maximum economic pressure on iran. many experts have in fact expressed a lack of confidence in instex’s prospects based on the assumption that its personnel and operation could easily be made subject to additional u.s. sanctions.
although it is hard to say exactly how instex will affect u.s. sanctions policy until more details about its structure are revealed, there are several key issues that u.s. policymakers ought to consider sooner rather than later in evaluating how to contend with the development of the vehicle. first, it will be politically more difficult for the u.s. to penalize instex and its participants for engaging in problematic activity in the event instex actually does become commercially successful. a thriving instex would mean more european businesses with a vested interest in building commercial ties with iran, which would consequently place greater pressure on european governments not to yield to american economic pressure without any pushback. the effort by the e3 to establish instex is itself partly the result of pressure from european companies that entered the iranian market following the execution of the iran deal and are eager to continue doing business.
second, the united states’s capacity to exert economic pressure on iran has in significant respects been driven not just by legal measures such as sanctions but also by the u.s.’s ability to persuade european companies to avoid the iranian market because of the inherent riskiness of engaging with iranian counterparties—many of which lack transparent ownership structures and are not required to comply with basic anti-money laundering standards. in particular, this has meant that european companies, especially banks, that engage in business in iran risk running afoul of other u.s. laws pertaining to internal controls and compliance, and thereby becoming subject to the frequently severe penalties associated with such violations. indeed, despite the panoply of u.s. sanctions imposed against iran since 1979, the united states was able to bring the islamic republic to the economic brink in the late 2000s only after mounting a systematic campaign of outreach that focused on convincing hundreds of european companies of the prohibitively high risks of engaging in business with iran. similarly, the iranian government’s long-running failure to fully implement banking and anti-money laundering reform has played a significant role in the unwillingness of european businesses to enter the iranian market.
instex effectively reduces the ability of the united states to use this risk as a lever for exerting economic pressure by shifting a component of the risk—specifically, the risk associated with financially intermediating transactions with iranian counterparties—away from private-sector businesses that have to worry about internal control standards and that are individually more susceptible to pressure from the u.s. government (as well as, in some cases, from public shareholders). that risk is transferred to instex, a quasi-public institution owned and controlled by sovereign governments. the united states will face substantially higher stakes in sanctioning or otherwise economically pressuring these governments if instex does not appropriately manage the risks associated with transacting with iranian counterparties.
given the embryonic nature of instex, appropriately gauging and confronting these potential dangers is difficult. among other things, if the u.s. implements sanctions or other similar punitive action only for instex to become a failure, such action could represent a premature move that generates political blowback without any real benefits. what the united states can do, however, is work to increase transparency around instex so that it and other stakeholders can develop a clearer understanding of the mechanism once it is operational, and become better equipped to undertake the appropriate course of action when the time comes. to this end, one simple measure the united states can implement now is to require foreign companies that are publicly listed on a u.s. stock exchange to disclose their relationships with instex in their periodic securities reports. under the iran threat reduction and syria human rights act of 2012 (tra), u.s.-listed companies are required to disclose various categories of business activities with iran, including activities that themselves may not be sanctionable. under its authority to issue interpretive guidance, the u.s. securities and exchange commission (sec) could advise all listed companies to disclose any direct transactions between them and instex, as well as any transactions that they knowingly facilitate between their counterparties and instex.
from an administrative standpoint, promulgating this standard as guidance would be relatively easy to do (versus, for example, trying to pass a bill through congress or undergoing a lengthy rule-making process). guidance also has the public relations benefit of technically being nonbinding, as opposed to a new statute or sec rule that european policymakers can decry as another example of u.s. extraterritorial law. in addition, the existing statutory language and market practice provide several bases for issuing such guidance.
first, the tra requires disclosure of all transactions or dealings with the “government of iran,” which is broadly defined by the applicable regulations to include “any political subdivision, agency, or instrumentality thereof … any person owned or controlled, directly or indirectly, by the foregoing … [and] any person to the extent that such person is, or has been … acting or purporting to act, directly or indirectly, for or on behalf of the foregoing.” even though instex is a european entity as a formal matter, the vehicle will have to function as a sort of joint venture with the iranian government, which would coordinate payments among the iranian counterparties with which european instex participants transact. in this sense, instex could effectively be considered an “instrumentality” of the iranian government, or at least an operation in which the iranian government has an ownership or control interest. the interpretation may seem broad, but it is consistent with how many companies currently disclose their relationships to entities with amorphous relationships to the iranian government pursuant to the tra.
second, the tra requires disclosure of transactions that are “knowingly conducted” with a designated entity, such as the iranian government. this requirement is often read broadly and could provide an interpretive basis for requiring companies to disclose transactions that they knowingly facilitate between instex and their counterparties, such as customers. for example, a listed company is deemed to knowingly conduct a transaction with a sanctioned iranian bank to the extent the company plays an active role in structuring payments or other transactions between a nonsanctioned customer and the bank. by the same logic, a listed company—say, a financial institution—could be deemed to knowingly conduct a transaction with the iranian government if it actively structures or coordinates a transaction between a customer and instex, such as by facilitating the transfer of a payment from instex to the customer’s account at the bank.
while enhanced disclosure guidance would not constitute a direct fix for the potential problems associated with instex, it would be a relatively easy-to-implement step to further illuminate instex’s activities and the nature of the threat it poses as a financial intermediary vehicle beyond the direct control of the united states. listed companies, particularly financial institutions, would not be able to forego disclosures that they would otherwise be required to make if they were dealing directly with iranian financial institutions. this would force these entities to retain some minimal level of reputational risk as a result of engaging in business in iran. at the same time, by requiring companies to simply provide additional disclosures (instead of imposing new sanctions or other penalties), the united states would make it harder for listed european businesses and their governments to make a credible case that they are being financially punished for engaging in legitimate transactions with iranian companies—particularly since many would already be required to disclose the underlying business activity pursuant to other provisions of the tra. u.s. policymakers have time to think through how to deal with instex as it assumes more definite shape, and enhanced disclosure requirements will provide a tool that can be used early on to assist with that exercise.
sahand moarefy is a corporate attorney at wachtell, lipton, rosen & katz. he has previously written on international relations and sanctions policy issues for foreign affairs, the diplomat, lawfare, the harvard law school national security journal and the harvard international review.


text:
' He says he has an old father and mother who will die if they do not see him. Her work had made her belong to all the world and all the world was to protect her if need be. Come to me early to-morrow morning, and I will show thee one. Pope Julius had summoned Raphael for a special reason. And now the boy had to plant and water the garden, hoe and dig, and bear the wind and bad weather. I cannot tell how long I slept, but when I awoke the ship was gone. When they did return the door was closed and locked. Tired as he was, when he saw this he arose and skipped about with them. Oh! it is, is it? then let me see you do it, and just creep into this nut, said the lad.
Good gracious! she cried. But now came down a mighty wind, and swept him back southward toward the desert. No, she would not sell it, but the bride might perhaps earn it.
It was hard lines for Dominie Curtius all that day at school. Every one was working, except the baby and the kitten, but all seemed to be having a glorious time. But fortune would so have it, that he once more drew out the golden fish. There was water all round the stone, but very little was flowing through the hole. Each bade the other welcome, and increased its own beauty by so doing. But I know of a runnel, cold and clear, that is hard by. One was the artist of whom we shall speak, and the other was Jules Breton. Then, bowing to his hosts, he stepped toward the door. The latter stopped short, with a curious expression on his face. Why art thou pelting me? I am not pelting thee, answered the first, growling. Everybody came to buy corn at the farm, and went away pouring maledictions on the Black Brothers. He by her father's will was now her dear companion and husband. Mary kneels and contemplates her child with glad emotion.
Then said fair Kriemhild, See how he shines among the knights, a very moon among the stars. He always took good care of his old grandmother, and kept her in his own lodge until she died.

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' he says he has an old father and mother who will die if they do not see him. her work had made her belong to all the world and all the world was to protect her if need be. come to me early to-morrow morning, and i will show thee one. pope julius had summoned raphael for a special reason. and now the boy had to plant and water the garden, hoe and dig, and bear the wind and bad weather. i cannot tell how long i slept, but when i awoke the ship was gone. when they did return the door was closed and locked. tired as he was, when he saw this he arose and skipped about with them. oh! it is, is it? then let me see you do it, and just creep into this nut, said the lad.
good gracious! she cried. but now came down a mighty wind, and swept him back southward toward the desert. no, she would not sell it, but the bride might perhaps earn it.
it was hard lines for dominie curtius all that day at school. every one was working, except the baby and the kitten, but all seemed to be having a glorious time. but fortune would so have it, that he once more drew out the golden fish. there was water all round the stone, but very little was flowing through the hole. each bade the other welcome, and increased its own beauty by so doing. but i know of a runnel, cold and clear, that is hard by. one was the artist of whom we shall speak, and the other was jules breton. then, bowing to his hosts, he stepped toward the door. the latter stopped short, with a curious expression on his face. why art thou pelting me? i am not pelting thee, answered the first, growling. everybody came to buy corn at the farm, and went away pouring maledictions on the black brothers. he by her father's will was now her dear companion and husband. mary kneels and contemplates her child with glad emotion.
then said fair kriemhild, see how he shines among the knights, a very moon among the stars. he always took good care of his old grandmother, and kept her in his own lodge until she died.


text:
Please take a moment to call your insurance provider or check their website for information about your particular plan's In-Network and Out-of-Network Chiropractic coverage: deductibles, co-pays, co-insurance and visit limits. Attention Blue Cross/Anthem Patients: Ask if your claim will be processed through Blue cross or American Specialty Health. Obtain address here we should submit your electronic claims.
Once we receive the requested information, we will contact your insurance and verify your benefits.
We will call you the same day to discuss your insurance benefits and schedule an appointment.
Appointments can only be reserved on the phone with a credit card. Your credit card will only be charged if you do not show up to your appointment.
Our cancelation policy requires 48 hour NOT 24 hour notice.
Cancellation / Rescheduling Policy: We understand there are times you must change or cancel your appointments and we ask for the courtesy of 48- hour notice for Tuesday, Wednesday, Thursday and Friday appointments. For Monday appointment's, we ask for notification by the preceding Thursday. Your timely notice allows us the opportunity to offer your appointment to another patient. Appointments canceled or rescheduled with less than 48- hour notice are subject to $65 fee.
Ready for your upcoming appointment?
Find out how chiropractic works.
Chiropractic is now covered under most health insurance plans.
What others say about chiropractic care can help you make the right health care choice. Review a selection of Chiro-Health patient testimonials.

lowercased:
please take a moment to call your insurance provider or check their website for information about your particular plan's in-network and out-of-network chiropractic coverage: deductibles, co-pays, co-insurance and visit limits. attention blue cross/anthem patients: ask if your claim will be processed through blue cross or american specialty health. obtain address here we should submit your electronic claims.
once we receive the requested information, we will contact your insurance and verify your benefits.
we will call you the same day to discuss your insurance benefits and schedule an appointment.
appointments can only be reserved on the phone with a credit card. your credit card will only be charged if you do not show up to your appointment.
our cancelation policy requires 48 hour not 24 hour notice.
cancellation / rescheduling policy: we understand there are times you must change or cancel your appointments and we ask for the courtesy of 48- hour notice for tuesday, wednesday, thursday and friday appointments. for monday appointment's, we ask for notification by the preceding thursday. your timely notice allows us the opportunity to offer your appointment to another patient. appointments canceled or rescheduled with less than 48- hour notice are subject to $65 fee.
ready for your upcoming appointment?
find out how chiropractic works.
chiropractic is now covered under most health insurance plans.
what others say about chiropractic care can help you make the right health care choice. review a selection of chiro-health patient testimonials.


text:
Hi! Sign in to let us know how Forte Pizzaria was?
Laine O. Apr 23 .
I stopped here after visiting Caldwell College and felt this place had an excellent Italian cuisine. They also seemed to be very popular with the college community.
Christina L. Apr 15 .
I originally attended a wedding that they catered and the food was incredible so I just had to go there.
PRO: all of the food is out of this world.
CON: the restaurant is VERY small so you have to get their early to get a table.
Leanne H. Mar 02 .
Forte is known for it's speciality pizzas. Their selection includes chicken parmigiana to cesear salad pizza. With new expanded facilities there is both restaurant and pick-up seating. They can make anything italian and it comes out great. Only downside is it is often extremely crowded and busy, especially on holidays.
Vickie C. Jan 27 .
Forte's has amazing pizza! They have a huge menu of great Italian food, and a wide array of different pizza. Everything is very fresh, and the pizza is not greasy, which makes it that much better!
by nulman at Citysearch Mar 24 .
Forte's is a find! The food is outstanding and very affordable. The service is friendly and efficient and everything about the restaurant is good. The owners are very accomodating, there is plenty of parking the portions are large. You can get everything from pizza to a gourmet meal.
by tonyb0d at Citysearch Mar 24 .
Tired of regular, traditional pizza? Try a gourmet pizza from Forte's. They have almost 20 specialty pizzas. Rigatoni Vodka, Chix Savoy, Bruschetta, Margherita, Italian Hot Dog, Grilled Eggplant...well, you get the picture. \n\nNot only is the pizza onee-of-a-kind, the pasta dishes and the hot sandwiches are very tasty. Forte's offers 2 types of eating, order at the counter and sit down, or go to the full-service area, which is actually quite nice.\n\nForte's is very clean, and the Italians that run it are all very friendly. Definitely a must-try.
If you've been to or used Forte Pizzaria, leave a review.

lowercased:
hi! sign in to let us know how forte pizzaria was?
laine o. apr 23 .
i stopped here after visiting caldwell college and felt this place had an excellent italian cuisine. they also seemed to be very popular with the college community.
christina l. apr 15 .
i originally attended a wedding that they catered and the food was incredible so i just had to go there.
pro: all of the food is out of this world.
con: the restaurant is very small so you have to get their early to get a table.
leanne h. mar 02 .
forte is known for it's speciality pizzas. their selection includes chicken parmigiana to cesear salad pizza. with new expanded facilities there is both restaurant and pick-up seating. they can make anything italian and it comes out great. only downside is it is often extremely crowded and busy, especially on holidays.
vickie c. jan 27 .
forte's has amazing pizza! they have a huge menu of great italian food, and a wide array of different pizza. everything is very fresh, and the pizza is not greasy, which makes it that much better!
by nulman at citysearch mar 24 .
forte's is a find! the food is outstanding and very affordable. the service is friendly and efficient and everything about the restaurant is good. the owners are very accomodating, there is plenty of parking the portions are large. you can get everything from pizza to a gourmet meal.
by tonyb0d at citysearch mar 24 .
tired of regular, traditional pizza? try a gourmet pizza from forte's. they have almost 20 specialty pizzas. rigatoni vodka, chix savoy, bruschetta, margherita, italian hot dog, grilled eggplant...well, you get the picture. \n\nnot only is the pizza onee-of-a-kind, the pasta dishes and the hot sandwiches are very tasty. forte's offers 2 types of eating, order at the counter and sit down, or go to the full-service area, which is actually quite nice.\n\nforte's is very clean, and the italians that run it are all very friendly. definitely a must-try.
if you've been to or used forte pizzaria, leave a review.


text:
A community project hosted by the Petersfield Museum to understand and conserve Petersfield’s prehistoric barrows.
This four-year project is focussed on a remarkable but little-known prehistoric monument complex on the edge of Petersfield Town dating to the Early Bronze Age, between 2200 and 1500 BC. Although designated as Scheduled Ancient Monuments, the large group of barrows (burial and ritual monuments) spread across Petersfield Heath has seen no active research since it was mapped in the 1930s and there is no record at all of any past excavations. Yet it is one of the most impressive and diverse barrow cemeteries to have survived in south-east England, boasting at least 21 monuments representing five or six different types.
Research goals, the legacy the project intends to create and how you can get involved.

lowercased:
a community project hosted by the petersfield museum to understand and conserve petersfield’s prehistoric barrows.
this four-year project is focussed on a remarkable but little-known prehistoric monument complex on the edge of petersfield town dating to the early bronze age, between 2200 and 1500 bc. although designated as scheduled ancient monuments, the large group of barrows (burial and ritual monuments) spread across petersfield heath has seen no active research since it was mapped in the 1930s and there is no record at all of any past excavations. yet it is one of the most impressive and diverse barrow cemeteries to have survived in south-east england, boasting at least 21 monuments representing five or six different types.
research goals, the legacy the project intends to create and how you can get involved.


text:
We're delighted you have decided to join. You are about to embark on a journey that General Aviation offers thousands world-wide! Welcome to the West Valley Flying Club. Please complete the online application below and we will contact you with more information. Additional copies of several important Member forms are included at the bottom of this application. Please download these and keep copies of them for your records.
A credit card authorization form is needed. The form will be emailed to you. Please fill it out and bring it with you to the club.
For details of cost of membership please CLICK HERE. There is a one-time application fee of $75. Membership Dues range from $55 per month to as little as $10 per month.
If form does not submit when you hit 'Join Today' button, please scroll up to be sure you have completed all required fields. Missing fields or errors will be highlighted in red but due to the length of the form, you may need to scroll up to see them.

lowercased:
we're delighted you have decided to join. you are about to embark on a journey that general aviation offers thousands world-wide! welcome to the west valley flying club. please complete the online application below and we will contact you with more information. additional copies of several important member forms are included at the bottom of this application. please download these and keep copies of them for your records.
a credit card authorization form is needed. the form will be emailed to you. please fill it out and bring it with you to the club.
for details of cost of membership please click here. there is a one-time application fee of $75. membership dues range from $55 per month to as little as $10 per month.
if form does not submit when you hit 'join today' button, please scroll up to be sure you have completed all required fields. missing fields or errors will be highlighted in red but due to the length of the form, you may need to scroll up to see them.


text:
Click on the links below to see full details of each walk. Remember that there is a car park available next to the Ilsington Village Shop. Stock up on drinks and snacks from the shop before your walk or relax after your stroll with a freshly made cup of coffee or tea at the Ilsington Village Shop Cafe.
This walk is an extract from Walk Dartmoor by Kate and Alan Hobbs (ISBN 1-904946-12-7) and published by Discovery Walking Guides. Available to buy from Haytor Information Centre, Waterstones, WH Smiths, Ilsington Village Shop and all good bookshops. Shown here with kind permission from the authors.
This walk is an extract from Walk Devon by David and Carol Hitt and Kate and Alan Hobbs (ISBN 1-904946-36-4) and published by Discovery Walking Guides. Available to buy from Haytor Information Centre, Waterstones, WH Smiths, Ilsington Village Shop and all good bookshops. Shown here with kind permission from the authors.

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click on the links below to see full details of each walk. remember that there is a car park available next to the ilsington village shop. stock up on drinks and snacks from the shop before your walk or relax after your stroll with a freshly made cup of coffee or tea at the ilsington village shop cafe.
this walk is an extract from walk dartmoor by kate and alan hobbs (isbn 1-904946-12-7) and published by discovery walking guides. available to buy from haytor information centre, waterstones, wh smiths, ilsington village shop and all good bookshops. shown here with kind permission from the authors.
this walk is an extract from walk devon by david and carol hitt and kate and alan hobbs (isbn 1-904946-36-4) and published by discovery walking guides. available to buy from haytor information centre, waterstones, wh smiths, ilsington village shop and all good bookshops. shown here with kind permission from the authors.


text:
At last Aspire has released its newest addition of high end vape tank systems. Set for release late December 2017. By introduction the Aspire Revvo tank is truly from another world with an revolutionary design and coils system. Features an innovative cutting edge stove top coil system, ARC Aspire Radial Coil. Boasting a full 24 mm tank width and comes in two sizes. First the TPD compliant 2 ml version and of course, the standard 3.6 ml full size version. It has a new adjustable top airflow construction and a special spring loaded filling tube. Whichever you choose (or are forced to choose if you're in a TPD compliant area), you'll be amazed by the innovation that Aspire has put into this fantastic new design. Comes in your choice of 3 colors Stainless, Black, and Chrome. This is the last 2017 Aspire tank that is featured in the Aspire SkyStar Revvo Kit.
If you’ve been vaping for a while, you’ve probably owned your share of products that didn’t really add much to the vaping hobby. A tank with slightly larger wick holes – or a mod with a slightly higher wattage range – than last year’s model isn’t a particularly exciting development. What is exciting is something that truly defies conventions – something that pushes the entire industry forward. More than any other vaping product that we’ve seen in a long time, the new Aspire Revvo tank fits that definition. Aspire’s new Aspire Radial Coil isn’t technically a coil at all; it’s a circular grate like the one you’d find on an electric stove top. The ARC coil isn’t just an improvement to the overall vaping experience; it eliminates some of the problems that have plagued sub-ohm tank users for years.
Let’s learn more about how the Aspire Revvo tank and Radial Coil work. In this guide, you’ll find out what makes the Aspire Radial Coil different from any other vaping coil on the market. By the time you’re done reading, you’ll know whether the Aspire Revvo tank – or perhaps the full Aspire SkyStar kit – is the right choice for you.
If you’re a long-term vaper, you’ll probably think that the Aspire Revvo tank doesn’t look too impressive from the outside. The narrow tube in the center almost makes the Revvo look like one of the cartomizer tanks that were once popular among advanced e-cigarette users. When you look inside the Revvo, though, you realize that the center tube isn’t actually a tube at all; it’s just the post that connects to the Aspire Radial Coil. The Aspire Revvo has no chimney, so it has none of the airflow issues that make most e-cigarette tanks inferior to rebuildable atomizers – and that’s just one of the differences that separate the Revvo from other vaping tanks.
The Aspire Radial Coil is the primary feature that makes the Revvo different from any other e-cigarette tank – and the best way that we can describe the difference is by showing it to you.
As you can see from the picture, the Aspire Radial Coil looks something like a flattened notch coil – but while notch coils are usually made from stainless steel, the ARC coil is made from kanthal. If your mod supports a resistance of 0.1 or 0.16 ohms and can fire within a range of 50-100 watts, it’ll support the ARC coil. On the underside of the coil is a cotton wick. If you begin to lose vapor production because the wick is drying out, you can tilt your device for a few seconds to re-saturate the wick.
The Aspire Revvo is one of the easiest sub-ohm tanks on the market to fill. Filling is easiest, though, if you have a plastic bottle with a nozzle tip. Twist off the drip tip to expose the spring-loaded filling hole in the center of the tank. Using the tip of your bottle, push the middle of the inside of the airflow ring to open the filling hole. Fill the tank and remove the bottle. The filling hole closes automatically to prevent leaks. Replace the drip tip. You may want to leave the tank on its side for several minutes to saturate the cotton.
As you’ll discover when reading the next section of this article, the design of the Aspire ARC coil is excellent for longevity. When it’s time to change the coil, though, you’ll find that doing so is both very easy and less messy than the experience you have when swapping most sub-ohm tank coils. You can even change the coil without dumping the e-liquid in the tank. To do so, unscrew the airflow control and drip tip to expose the retainer thumbscrew. Twist the retainer to remove it, and then pull the radial coil straight up to remove it from the Revvo tank. Drop in a new coil. Make sure that you’ve pushed it all the way in. Replace the retainer and airflow control, place the tank on its side for several minutes to saturate the cotton and you’re ready to go.
What Are the Benefits of the Aspire Radial Coil?
Aspire’s goal when creating the Revvo tank was to design a coil with a large surface area and no hot spots. The entire surface of the coil heats simultaneously, which means that the coil produces large vapor clouds with very rich flavor. In comparison, the vertical coils that most sub-ohm tanks use must fight gravity to stay wet. The top of a vertical coil dries out faster – and thus gets hotter – than the bottom of the coil. The Aspire Radial Coil doesn’t have that problem and is therefore less susceptible to burning the wick. As long as you remember to tilt the tank periodically to keep the wick wet – which really isn’t any more difficult than dripping – you can expect the ARC coil to last longer than most sub-ohm tank coils.
The design of the Aspire Radial Coil isn’t just great for flavor and vapor production; it also means that the Aspire Revvo tank doesn’t require a chimney. In a traditional sub-ohm tank, the coil is submerged in e-liquid. Vapor travels out through a chimney. The traditional chimney design is reliable and mostly leak free, but having a submerged coil means that you aren’t getting nearly as much airflow as you would get with a rebuildable atomizer. If you want to blow big clouds, you need plenty of airflow. That’s why sub-ohm tanks have always lagged behind RBAs in vapor production. Since the coil in the Aspire Revvo is above the e-liquid rather than submerged in it, there’s no need for a chimney. The airflow is the same as what you’d get with an RBA, which means that you can finally enjoy the vapor production of an RBA and the convenience of a tank simultaneously.
The Aspire Revvo tank is proof that as mature as the vaping industry sometimes appears, there is still plenty of room for revolutionary products that completely change the game. Although we don’t know what the next revolutionary product after the Revvo will look like, we believe that the Revvo is a tank that will influence the design of vaping devices for the next several years. In 2018, every major manufacturer of vaping products will most likely release a clone of the Revvo – but Aspire was there first. If you want to know what the future of vaping looks like, the Aspire Revvo is a tank that you need to own.

lowercased:
at last aspire has released its newest addition of high end vape tank systems. set for release late december 2017. by introduction the aspire revvo tank is truly from another world with an revolutionary design and coils system. features an innovative cutting edge stove top coil system, arc aspire radial coil. boasting a full 24 mm tank width and comes in two sizes. first the tpd compliant 2 ml version and of course, the standard 3.6 ml full size version. it has a new adjustable top airflow construction and a special spring loaded filling tube. whichever you choose (or are forced to choose if you're in a tpd compliant area), you'll be amazed by the innovation that aspire has put into this fantastic new design. comes in your choice of 3 colors stainless, black, and chrome. this is the last 2017 aspire tank that is featured in the aspire skystar revvo kit.
if you’ve been vaping for a while, you’ve probably owned your share of products that didn’t really add much to the vaping hobby. a tank with slightly larger wick holes – or a mod with a slightly higher wattage range – than last year’s model isn’t a particularly exciting development. what is exciting is something that truly defies conventions – something that pushes the entire industry forward. more than any other vaping product that we’ve seen in a long time, the new aspire revvo tank fits that definition. aspire’s new aspire radial coil isn’t technically a coil at all; it’s a circular grate like the one you’d find on an electric stove top. the arc coil isn’t just an improvement to the overall vaping experience; it eliminates some of the problems that have plagued sub-ohm tank users for years.
let’s learn more about how the aspire revvo tank and radial coil work. in this guide, you’ll find out what makes the aspire radial coil different from any other vaping coil on the market. by the time you’re done reading, you’ll know whether the aspire revvo tank – or perhaps the full aspire skystar kit – is the right choice for you.
if you’re a long-term vaper, you’ll probably think that the aspire revvo tank doesn’t look too impressive from the outside. the narrow tube in the center almost makes the revvo look like one of the cartomizer tanks that were once popular among advanced e-cigarette users. when you look inside the revvo, though, you realize that the center tube isn’t actually a tube at all; it’s just the post that connects to the aspire radial coil. the aspire revvo has no chimney, so it has none of the airflow issues that make most e-cigarette tanks inferior to rebuildable atomizers – and that’s just one of the differences that separate the revvo from other vaping tanks.
the aspire radial coil is the primary feature that makes the revvo different from any other e-cigarette tank – and the best way that we can describe the difference is by showing it to you.
as you can see from the picture, the aspire radial coil looks something like a flattened notch coil – but while notch coils are usually made from stainless steel, the arc coil is made from kanthal. if your mod supports a resistance of 0.1 or 0.16 ohms and can fire within a range of 50-100 watts, it’ll support the arc coil. on the underside of the coil is a cotton wick. if you begin to lose vapor production because the wick is drying out, you can tilt your device for a few seconds to re-saturate the wick.
the aspire revvo is one of the easiest sub-ohm tanks on the market to fill. filling is easiest, though, if you have a plastic bottle with a nozzle tip. twist off the drip tip to expose the spring-loaded filling hole in the center of the tank. using the tip of your bottle, push the middle of the inside of the airflow ring to open the filling hole. fill the tank and remove the bottle. the filling hole closes automatically to prevent leaks. replace the drip tip. you may want to leave the tank on its side for several minutes to saturate the cotton.
as you’ll discover when reading the next section of this article, the design of the aspire arc coil is excellent for longevity. when it’s time to change the coil, though, you’ll find that doing so is both very easy and less messy than the experience you have when swapping most sub-ohm tank coils. you can even change the coil without dumping the e-liquid in the tank. to do so, unscrew the airflow control and drip tip to expose the retainer thumbscrew. twist the retainer to remove it, and then pull the radial coil straight up to remove it from the revvo tank. drop in a new coil. make sure that you’ve pushed it all the way in. replace the retainer and airflow control, place the tank on its side for several minutes to saturate the cotton and you’re ready to go.
what are the benefits of the aspire radial coil?
aspire’s goal when creating the revvo tank was to design a coil with a large surface area and no hot spots. the entire surface of the coil heats simultaneously, which means that the coil produces large vapor clouds with very rich flavor. in comparison, the vertical coils that most sub-ohm tanks use must fight gravity to stay wet. the top of a vertical coil dries out faster – and thus gets hotter – than the bottom of the coil. the aspire radial coil doesn’t have that problem and is therefore less susceptible to burning the wick. as long as you remember to tilt the tank periodically to keep the wick wet – which really isn’t any more difficult than dripping – you can expect the arc coil to last longer than most sub-ohm tank coils.
the design of the aspire radial coil isn’t just great for flavor and vapor production; it also means that the aspire revvo tank doesn’t require a chimney. in a traditional sub-ohm tank, the coil is submerged in e-liquid. vapor travels out through a chimney. the traditional chimney design is reliable and mostly leak free, but having a submerged coil means that you aren’t getting nearly as much airflow as you would get with a rebuildable atomizer. if you want to blow big clouds, you need plenty of airflow. that’s why sub-ohm tanks have always lagged behind rbas in vapor production. since the coil in the aspire revvo is above the e-liquid rather than submerged in it, there’s no need for a chimney. the airflow is the same as what you’d get with an rba, which means that you can finally enjoy the vapor production of an rba and the convenience of a tank simultaneously.
the aspire revvo tank is proof that as mature as the vaping industry sometimes appears, there is still plenty of room for revolutionary products that completely change the game. although we don’t know what the next revolutionary product after the revvo will look like, we believe that the revvo is a tank that will influence the design of vaping devices for the next several years. in 2018, every major manufacturer of vaping products will most likely release a clone of the revvo – but aspire was there first. if you want to know what the future of vaping looks like, the aspire revvo is a tank that you need to own.


text: Professional pet sitting & dog walking. Regular or occasional dog walking, cat visits, pet sitting, small pets & exotics. Fully insured, security checked & uniformed pet carers.

lowercased: professional pet sitting & dog walking. regular or occasional dog walking, cat visits, pet sitting, small pets & exotics. fully insured, security checked & uniformed pet carers.


text:
There is a term that business people say that where there are many people there is an opportunity, the term is indeed true. One of them is internet users around the world in various countries reaching hundreds of millions of people. With a very large number of users it is certainly an opportunity to start a business or business. We as users don't just watch and see other people succeed with the internet. Even though we have the same and free internet access, we all have the same time only 24 hours a day. But the most important thing is there is a willingness to learn and start. Use the opportunity for the Internet to make money.
Now Business Internet people are not only entrepreneurs or companies, even students and even housewives can also make money from the Internet. This shows that if the Business Internet can be done by anyone. You can see in various forums that many people make money from the Internet even without capital. His income can reach hundreds to thousands of dollars every day. Very tempting isn't it? Of course, but it takes a process and takes time. The most important thing is that you can start to try Business Internet / Online Business to increase your income.
This type of business is not difficult because you don't need to create a Website or Blog, you don't need programming skills. You work just click on the ad and wait a few seconds to generate a Commission in the form of Dollars. Every ad that is clicked has a value that varies from $ 0.001 - $ 0.01, the value is indeed small, but young people do it besides without the need for capital. To register it is also very easy to just use Email. You can collect every day, for example, click 10 ads per day, in one month? In one year?
There are lots of PTC Businesses like Clicksense, Neobux, and many others, will be discussed in other articles. Lots of people have managed to raise $ 100 every month. This is very beneficial because there is no need for capital to start. In addition there is no loss because you do not issue capital.
This business is liked by teenagers and housewives, even though they are busy but this business can be done anywhere when it's free. The way this business is you sell other people's goods with a higher price difference, you will get a commission from the seller and also from the price difference. Suppose you sell items from Amazon such as the Case Iphone for $ 10 from Amazon, you sell $ 15 so you get $ 5 from one item. Imagine if you could sell hundreds of items every day.
Dropship can not only be done by people who have a Website or Blog, you can use Social Media like Facebook, Twitter, Instagram, LinkedIn to promote products. The more people who see, the greater the chance to get buyers and earn income. There are lots of sites for buying and selling goods that offer Dropship Facilities, you can use these opportunities to earn money.
You can also use the Internet to become a seller, with many internet users you can use to trade. You can try to sell on Social Media then develop by creating a Blog to a Professional Website. You can try offering goods / products or services. If you have expertise such as Programming, Designer, Gaming, Photographer, Blogging, Website Design, or other Services. You can offer services to other people, with that you can make money from these services. As for the items you have to photograph the item then Post and if anyone buys you must send the ordered items.
Already many sellers on the Internet are successful and get turnover reaching thousands of dollars every month. It can be a motivation for us to try to sell by using the Internet, selling online is more of an opportunity than selling offline. Because more online buyers can even from various countries. You can also use the Marketplace like Amazon, Ebay, Etsy, and many others.
It seems strange, install and play games but get paid, even though playing games is fun but getting paid. Of course that makes a lot of people interested, this business is Pay per Install (PPI). You can start this business using a PC-Laptop and now also on a Smartphone / Tablet. You just follow the instructions, for example, you have to install Game A and play the game to a certain level, if you succeed, you will get a commission in the form of Dollars.
For this business you should use a Smartphone / Tablet because besides being more practical because it can be done anywhere as long as it is connected to the Internet. Some applications for the PPI business are Whaff, Grab Points, and many others. This business is very popular, especially in adolescents.
The last is Business Blogging or Website, create a free Blog like Blogger or Wordpress. Besides being free it is also very easy to set up even for beginners, no need to understand coding because it is very easy to set up the Blog appearance. Take advantage of free blogs with the contents of widgets and interesting content, so you can get a lot of visitors. With blogs that have high visitors you can make money easier. You can try to sell goods, become a Publisher Adverts like Google Adsense, Propeller Ads, Adnow, becoming a Publisher Ad can generate hundreds of dollars for each month.
Having a Blog can also be used to promote advertising of goods or services more easily. Especially if visitors reach thousands of people, of course it can be an opportunity to sell goods more easily. You can try to make Blogger or WordPress easy and free. Blogs can also be used as Affiliate Marketing or Partners to get commissions. You just have to put up a Banner about the Products on the Blog, if anyone buys through a Banner that you install then you will get a Commission in the form of Dollars.
Just like a Blog, why actually become a Youtuber to make money? That's because there are ads inserted in the video. The advantages of being a YouTube player compared to Blogger are in creating content that is more fun because of dealing with the camera directly without having to write. In contrast to Blogs, good writing is needed to make it comfortable to read, making Video content more enjoyable because you can directly create content using the Smartphone Camera.
But there are some drawbacks to being a Youtuber because of the easy way so many people take advantage of it. Starting from small children who make video content then upload it to Youtube. This is a challenge because there are many competitors in various countries. But there's nothing wrong because all of that is free, you only need to create a Gmail account. Start to Upload interesting Videos to get many Subscribe, Like and View.
That is some Business Internet that can be tried for Beginners who want to try the Business Internet, every day Internet users continue to grow, it shows if the Business Internet will continue to grow every day. Starting to do business and make extra money every month, you can get additional income for every day, every week, or every month.
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there is a term that business people say that where there are many people there is an opportunity, the term is indeed true. one of them is internet users around the world in various countries reaching hundreds of millions of people. with a very large number of users it is certainly an opportunity to start a business or business. we as users don't just watch and see other people succeed with the internet. even though we have the same and free internet access, we all have the same time only 24 hours a day. but the most important thing is there is a willingness to learn and start. use the opportunity for the internet to make money.
now business internet people are not only entrepreneurs or companies, even students and even housewives can also make money from the internet. this shows that if the business internet can be done by anyone. you can see in various forums that many people make money from the internet even without capital. his income can reach hundreds to thousands of dollars every day. very tempting isn't it? of course, but it takes a process and takes time. the most important thing is that you can start to try business internet / online business to increase your income.
this type of business is not difficult because you don't need to create a website or blog, you don't need programming skills. you work just click on the ad and wait a few seconds to generate a commission in the form of dollars. every ad that is clicked has a value that varies from $ 0.001 - $ 0.01, the value is indeed small, but young people do it besides without the need for capital. to register it is also very easy to just use email. you can collect every day, for example, click 10 ads per day, in one month? in one year?
there are lots of ptc businesses like clicksense, neobux, and many others, will be discussed in other articles. lots of people have managed to raise $ 100 every month. this is very beneficial because there is no need for capital to start. in addition there is no loss because you do not issue capital.
this business is liked by teenagers and housewives, even though they are busy but this business can be done anywhere when it's free. the way this business is you sell other people's goods with a higher price difference, you will get a commission from the seller and also from the price difference. suppose you sell items from amazon such as the case iphone for $ 10 from amazon, you sell $ 15 so you get $ 5 from one item. imagine if you could sell hundreds of items every day.
dropship can not only be done by people who have a website or blog, you can use social media like facebook, twitter, instagram, linkedin to promote products. the more people who see, the greater the chance to get buyers and earn income. there are lots of sites for buying and selling goods that offer dropship facilities, you can use these opportunities to earn money.
you can also use the internet to become a seller, with many internet users you can use to trade. you can try to sell on social media then develop by creating a blog to a professional website. you can try offering goods / products or services. if you have expertise such as programming, designer, gaming, photographer, blogging, website design, or other services. you can offer services to other people, with that you can make money from these services. as for the items you have to photograph the item then post and if anyone buys you must send the ordered items.
already many sellers on the internet are successful and get turnover reaching thousands of dollars every month. it can be a motivation for us to try to sell by using the internet, selling online is more of an opportunity than selling offline. because more online buyers can even from various countries. you can also use the marketplace like amazon, ebay, etsy, and many others.
it seems strange, install and play games but get paid, even though playing games is fun but getting paid. of course that makes a lot of people interested, this business is pay per install (ppi). you can start this business using a pc-laptop and now also on a smartphone / tablet. you just follow the instructions, for example, you have to install game a and play the game to a certain level, if you succeed, you will get a commission in the form of dollars.
for this business you should use a smartphone / tablet because besides being more practical because it can be done anywhere as long as it is connected to the internet. some applications for the ppi business are whaff, grab points, and many others. this business is very popular, especially in adolescents.
the last is business blogging or website, create a free blog like blogger or wordpress. besides being free it is also very easy to set up even for beginners, no need to understand coding because it is very easy to set up the blog appearance. take advantage of free blogs with the contents of widgets and interesting content, so you can get a lot of visitors. with blogs that have high visitors you can make money easier. you can try to sell goods, become a publisher adverts like google adsense, propeller ads, adnow, becoming a publisher ad can generate hundreds of dollars for each month.
having a blog can also be used to promote advertising of goods or services more easily. especially if visitors reach thousands of people, of course it can be an opportunity to sell goods more easily. you can try to make blogger or wordpress easy and free. blogs can also be used as affiliate marketing or partners to get commissions. you just have to put up a banner about the products on the blog, if anyone buys through a banner that you install then you will get a commission in the form of dollars.
just like a blog, why actually become a youtuber to make money? that's because there are ads inserted in the video. the advantages of being a youtube player compared to blogger are in creating content that is more fun because of dealing with the camera directly without having to write. in contrast to blogs, good writing is needed to make it comfortable to read, making video content more enjoyable because you can directly create content using the smartphone camera.
but there are some drawbacks to being a youtuber because of the easy way so many people take advantage of it. starting from small children who make video content then upload it to youtube. this is a challenge because there are many competitors in various countries. but there's nothing wrong because all of that is free, you only need to create a gmail account. start to upload interesting videos to get many subscribe, like and view.
that is some business internet that can be tried for beginners who want to try the business internet, every day internet users continue to grow, it shows if the business internet will continue to grow every day. starting to do business and make extra money every month, you can get additional income for every day, every week, or every month.
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Your hair appearance will be more ideal and extra exciting by applying the proper 8 Easy Protective Hairstyles For Short Natural 4C Hair That Will Not. You should be sensible in deciding upon the right hairstyle, haircut and hair shade if you want to change the visual appeal of your hair. On the other hand, hair drastically has an effect on your physical appearance, so what ever you do to your hair ought to be very carefully planned for highest outcomes. Seem for references to hairstyles as a great deal as possible to add your insight into the several hairstyles and make it much easier for you to pick the ideal for your hair.
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You can use my website as one of the best reference on hair fashion, haircut and hair color. Please you search and open 1000’s of posts, categories and hair design images on my website. Use the search menu to velocity up your search course of action. Like the 8 Easy Protective Hairstyles For Short Natural 4C Hair That Will Not you see currently, the image is aspect of the Easy Hairstyles For Short Natural Hair submit I have published on my website. There are nonetheless lots of other images you can view and pick in the submit. If you are curious and want to see it, please click right here now. The more hairstyles you have, the a lot more hairstyles you can get and extra freely pick the very best hairstyle that is right for you.
Seem wonderful is the dream of every single female. In addition to makeup, hair appearance is also very influential on the appearance. So the females are ready to spend a whole lot of cash and hard work to get strong hair, wholesome and lovely. Not only gals, males also want to have great hair to make them look much more handsome. How about you? Is your hair great? Do not forget to share these images / posts with your buddies in your favourite social media. May possibly you come across the correct hairstyle, haircut and hair color. May possibly be handy. thanks.
This picture (8 Easy Protective Hairstyles For Short Natural 4C Hair That Will Not) labelled with: easy braided hairstyles for short natural hair, easy hairstyles for medium short natural hair, easy hairstyles for short african natural hair, easy hairstyles for short natural 4c hair, easy hairstyles for short natural curly hair.

lowercased:
your hair appearance will be more ideal and extra exciting by applying the proper 8 easy protective hairstyles for short natural 4c hair that will not. you should be sensible in deciding upon the right hairstyle, haircut and hair shade if you want to change the visual appeal of your hair. on the other hand, hair drastically has an effect on your physical appearance, so what ever you do to your hair ought to be very carefully planned for highest outcomes. seem for references to hairstyles as a great deal as possible to add your insight into the several hairstyles and make it much easier for you to pick the ideal for your hair.
the 8 easy protective hairstyles for short natural 4c hair that will not you are on the lookout at suitable now is one particular of the greatest that you can pick and apply to your hair. if you really feel you like the picture above and want to conserve it to your pc, laptop, tablet and smartphone, please conserve it by clicking on “download full image” beneath the picture. the moment the image is absolutely open click on the image and decide on “save image as”. the moment you are sure of what you pick and are ideal for your hair, please apply 8 easy protective hairstyles for short natural 4c hair that will not over on your hair.
speaking of 8 easy protective hairstyles for short natural 4c hair that will not, you can uncover quite a few excellent references through television, magazine and net. on the net, you can search 1000’s of examples of the ideal 8 easy protective hairstyles for short natural 4c hair that will not pictures with large high-quality by means of search engines like google, bing, duckduckgo, quora and so forth. you just require to variety in a keyword in the search discipline and you will get search results from your keywords. if you favor to view the video, you can consider benefit of youtube to locate references about the hairstyle you want.
you can use my website as one of the best reference on hair fashion, haircut and hair color. please you search and open 1000’s of posts, categories and hair design images on my website. use the search menu to velocity up your search course of action. like the 8 easy protective hairstyles for short natural 4c hair that will not you see currently, the image is aspect of the easy hairstyles for short natural hair submit i have published on my website. there are nonetheless lots of other images you can view and pick in the submit. if you are curious and want to see it, please click right here now. the more hairstyles you have, the a lot more hairstyles you can get and extra freely pick the very best hairstyle that is right for you.
seem wonderful is the dream of every single female. in addition to makeup, hair appearance is also very influential on the appearance. so the females are ready to spend a whole lot of cash and hard work to get strong hair, wholesome and lovely. not only gals, males also want to have great hair to make them look much more handsome. how about you? is your hair great? do not forget to share these images / posts with your buddies in your favourite social media. may possibly you come across the correct hairstyle, haircut and hair color. may possibly be handy. thanks.
this picture (8 easy protective hairstyles for short natural 4c hair that will not) labelled with: easy braided hairstyles for short natural hair, easy hairstyles for medium short natural hair, easy hairstyles for short african natural hair, easy hairstyles for short natural 4c hair, easy hairstyles for short natural curly hair.


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We are very excited to host you to El Atascadero, and look forward to providing you with an unforgettable experience. Please fill out the form below with your information and the desired dates for your stay, and we will be in contact with you as quickly as possible.
Type in any special requests here.
Thank you! One of our team members will be in touch with you soon.
El Atascadero sits peacefully atop downtown San Miguel de Allende. We are located less than a mile from downtown San Miguel de Allende and El Jardín, just a short 10-15 minute walk or a quick 5 minute drive.
San Miguel de Allende is located about 170 miles northwest of Mexico City. The most convenient airports to fly into are the Mexico City International Airport (MEX, 166 miles away), The Querétaro Intercontinental Airport (QRO, 53 miles away) or the Guanajuato Internacional Airport in León (BJX, 62 miles away).

lowercased:
we are very excited to host you to el atascadero, and look forward to providing you with an unforgettable experience. please fill out the form below with your information and the desired dates for your stay, and we will be in contact with you as quickly as possible.
type in any special requests here.
thank you! one of our team members will be in touch with you soon.
el atascadero sits peacefully atop downtown san miguel de allende. we are located less than a mile from downtown san miguel de allende and el jardín, just a short 10-15 minute walk or a quick 5 minute drive.
san miguel de allende is located about 170 miles northwest of mexico city. the most convenient airports to fly into are the mexico city international airport (mex, 166 miles away), the querétaro intercontinental airport (qro, 53 miles away) or the guanajuato internacional airport in león (bjx, 62 miles away).


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Washington State attorney general Bob Ferguson called into CNN tonight to talk to Anderson Cooper about the Seattle judge who temporarily blocked President Trump‘s travel ban tonight.
U.S. District Judge James Robart‘s ruling applies nationwide, and Ferguson told Cooper he was very encouraged by this outcome.
He pointed out the judge in question was a Bush appointee and said that despite being a Democrat, he himself has filed lawsuits against the Obama administration.
He also described the rollout of the executive order as a very “Keystone Cops”-like situation.

lowercased:
washington state attorney general bob ferguson called into cnn tonight to talk to anderson cooper about the seattle judge who temporarily blocked president trump‘s travel ban tonight.
u.s. district judge james robart‘s ruling applies nationwide, and ferguson told cooper he was very encouraged by this outcome.
he pointed out the judge in question was a bush appointee and said that despite being a democrat, he himself has filed lawsuits against the obama administration.
he also described the rollout of the executive order as a very “keystone cops”-like situation.