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"Of course I know how to use a condom, Dad! They taught us in health class last year!"
"Really? And how did you practice this important skill?"
"We used a banana."
"Great. Show me."
"Yeah, Dad. Like I just carry condoms with me everywhere I go."
"Yeah, well maybe you should!"
This is not an unusual conversation in my household. My daughter, Daisy Mae, recently turned 17. She looks older than her years and is, in a mother's strictly unbiased opinion, a beautiful girl. She has a tendency to attract boys a couple years older than she is, which means that Mr. Bean and I have our work cut out for us, if we intend to get through the next three years without becoming grandparents.
Daisy was preparing to go out with her then-boyfriend, Devon, a 19-year-old who seemed intent on living his entire summer at the beach.
"OK, well, look. Mom and I have to run out for dog food. We'll be back around 6:00. What time is Loverboy showing up?"
"I don't even know for sure if we're going out tonight," Daisy scowled as she looked at her phone, "he just said he's stuck helping his mom at the market."
Mr. and I headed out to get dog food, followed by a stop at Chipotle for a quick bite to eat. Chipotle was a popular spot that night, as we had about a ten-minute wait in line.
As we neared the front of the line, I looked down on the floor and was surprised to see that someone had dropped a wrapped condom.
I nudged Mr. Bean, "Wow, Honey, look! God had left us a condom! Do you think it's a sign?"
He looked to where I pointed and snickered. "It appears that God wants us to quiz our smart-mouthed kid about her birth control."
"And Lo, there did appear before them a," I reached down and picked up the condom, "a Lime-green Trojan Twisted Pleasure, with a reservoir tip, and extra lubrication. And the people took up the condom and declared it good." I slipped in and out of a bad Charleton Heston voice, giggling like a 12-year-old.
The woman in front of me looked over her right shoulder. "OK, I just want to go on record saying that did NOT fall out of my purse, OK?"
"Duly noted." Mr Bean and I were laughing hysterically at this point.
When we arrived home, Mr. immediately summoned our daughter.
"Oh, Daisy Mae! Come here, sweetheart! God has brought unto us an opportunity to prove your condom-sheathing skills. Quick; grab a banana and come here!"
Daisy set down the Wii controller and leveled her very best "Really?" gaze at us. "Seriously? You two went out and bought condoms, just so I could prove to you that I know how to put one on? You're kidding, right?"
"Oh, no," I said, "God sent us this condom. He delivered it to us at the Chipotle by the mall, so that we could bring it to you! It's God's condom. It's a magic condom for all we know. You can't dis it."
"Oh for gawd's sake. What the hell is this? A Twisted Pleasure condom? Jeez! It's fluorescent green. OK, that's so wrong. Gimme that banana..."
She tore open the wrapper, grabbed the condom by the reservoir tip….and shook it vigorously until it flapped about like a limp wind sock. She looked at the banana. She looked at the condom. "Shit. I did that wrong. Oh, whatever!" She started to drop it, but then looked at it again and started to laugh. "Man, that would make, like, the best water balloon EVER."
The condom, as is happened, was capable of holding an entire pint of water, with room to spare. Daisy spent about 45 minutes playing with her new water balloon on the back porch until it finally burst.
"OK, I will NEVER, EVER believe any guy who tells me that the condom is too small for him to wear. That thing would have fit a horse!"
Lesson 121. Completed.
The next afternoon, I dropped Daisy off at the beach, where she was meeting Devon. "Hey; have fun, Baby. Behave yourself."
She looked back at me as she got out of the car. "Yeah, it looks like I won't have a choice about that, as clearly, I don't know how to put on a condom!" She winked.
I love you, Daisy Mae.


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Resource Consumption Management using GlassFish
This blog is a follow up to the excellent blog Sreeram did on Resource Consumption Management (RCM) in GlassFish. I strongly recommend you read it before this one.
The Grizzly's Application Resources Allocation (ARA) extension is an implementation of a Resource Consumption Management (RCM) system. RCM system are allowing you to enable virtualization of system resources per web application, similar to Solaris 10 zone or the outcome of the upcoming JSR 284.
ARA has been implemented on top of Grizzly's Pipeline and Algorithm interface and a new basic rule-based filtering mechanism to manipulate tcp request URLs on the fly (browse the code here). For example, you can easily add a rule to rewrite a tcp request, like mod_rewrite does in Apache.
Grizzly's ARA currently supports two rule that can be applied to a tcp request:
- Reserve a specific percentage of the available heap memory.
- Reserve a specific percentage of the available threads.
You can configure the rule semantic using two kind of allocation policy: reservation or ceiling.
Lets say there are 100 threads in the Grizzly request processing thread pool(Pipeline). For example, we reserve 30% of the Pipeline's threads to App A and 65% to App B. Now that leaves only 5% to other applications. So even if the other 95% threads are idle, we delay requests until the 5 unreserved threads can service requests. If the reservations are speaking for all available resources, then we may reject the request.
Ceiling has a slightly different behavior. If there are more than 30 requests to A, even if the threads set aside for B and others are idle, we delay processing the requests to A, until A's utilized thread percentage falls below 30%. Here we may delay requests until resources become available.
Like many Grizzly and WebContainer extension, the ARA mechanism is disabled by default, and will be considered to become an official feature when the GlassFish.next discussion starts. Since this is an experimental feature right now, we also want to get community feedback and contribution before rolling it in as a supported feature. Thus, for now, you gonna need to edit directly GlassFish's domain.xml file.
To enable ARA, you first need to tell Grizzly to use the ARA specialized Pipeline:
<jvm-options>-Dcom.sun.enterprise.web.connector.grizzly.pipelineClass= com.sun.enterprise.web.ara.IsolationPipeline</jvm-options>
Then, you need to define the rule(s) you want to be applied to the tcp request:
<jvm-options>-Dcom.sun.enterprise.web.ara.rules= com.sun.enterprise.web.ara.rules.ThreadRatioRule, com.sun.enterprise.web.ara.rules.HeapRatioRule</jvm-options>
I usually apply only one rule at the time. Note that it is fairly easy to add a new Rule to the rule-based engine. All you need to do is to implement the Rule interface, and tell the rule-based engine to load it at startup using the above property. Your rule.callable() implementation will have to implement the following contract:
- Rule_OK: the rule has been successfully applied and the request can be executed. The rule result will be cached so the next request will be serviced directly, without paying the price of the rule based engine execution.
- Rule_DELAY: the rule has been successfully applied but the request execution must be delayed.
- Rule_OK_NOCACHE: the rule has been successfully applied and the request can be executed, but the rule must not be cached so next time the request is coming, the rule will be executed.
The ARA implementation will invoke rule.attach() with an NIO ByteBuffer which position and limit will delimitate the HTTP request context root, which will be used to execute the rule. Take a look here for an example
Then you need to configure the rule semantic allocation policy:
For the ceiling allocation policy, you can define the time the request will be delayed when no resource are available by adding (the value in milliseconds):
Then finaly, define the application set on which rule(s) will be applied:
The allowed values are application name, the token '|', then the allowed ratio (between 0 and 1) e.g. ([yourApp|ratio] separated by a ',')
Ouf…can't wait for the admin team to implement something easier to configure :-). Let me know if the steps are unclear (which I suspect they are). Once all the jvm-options has been entered, launch GlassFish. Grizzly will replace its default Pipeline with the above defined ARA, and starts the rule-base engine.
Now why not implementing the same behavior using a Servlet's Filter or a Catalina's Valve? Because performance wise, you don't want to parse the request and then do RCM. Doing such filtering at the bytes level, although it complexity the rule implementation, reduce the performance degradation. You certainly don't want you server to significantly slow down when RCM is enabled.
Interested by RCM and ARA? Have some rules in mind or rule implementation ready? Or rules recommendations? Feel free to post them here!
technorati: grizzly resource consumption management glassfish
_uacct = "UA-3111670-1";
Enabling CGI support in GlassFish
Wants to execute CGI in GlassFish? The GlassFish CGI support is disabled by default, and it is based on the Tomcat implementation. Two ways to enable it: only inside your web application or for all web applications deployed in GlassFish. I strongly recommend you enable it inside your application only for security reason, but if you control the applications deployed in GlassFish, then enabling it to all web applications might be simpler. For your web application, you will add the information in your WEB-INF/web.xml. To enable it globally, you will add it in $glassfish.home/domains/domain1/config/default-web.xml.
First, define the CGI Servlet:
<!-- Common Gateway Includes (CGI) processing servlet, which supports --> <!-- execution of external applications that conform to the CGI spec --> <!-- requirements. Typically, this servlet is mapped to the URL pattern --> <!-- "/cgi-bin/*", which means that any CGI applications that are --> <!-- executed must be present within the web application. This servlet --> <!-- supports the following initialization parameters (default values --> <!-- are in square brackets): --> <!-- --> <!-- cgiPathPrefix The CGI search path will start at --> <!-- webAppRootDir + File.separator + this prefix. --> <!-- [WEB-INF/cgi] --> <!-- --> <!-- debug Debugging detail level for messages logged --> <!-- by this servlet. [0] --> <!-- --> <!-- executable Name of the exectuable used to run the --> <!-- script. [perl] --> <!-- --> <!-- parameterEncoding Name of parameter encoding to be used with --> <!-- CGI servlet. --> <!-- [System.getProperty("file.encoding","UTF-8")] --> <!-- --> <!-- passShellEnvironment Should the shell environment variables (if --> <!-- any) be passed to the CGI script? [false] --> <!-- --> <servlet> <servlet-name>cgi</servlet-name> <servlet-class>org.apache.catalina.servlets.CGIServlet</servlet-class> <init-param> <param-name>debug</param-name> <param-value>0</param-value> </init-param> <init-param> <param-name>cgiPathPrefix</param-name> <param-value>WEB-INF/cgi</param-value> </init-param> <load-on-startup>5</load-on-startup> </servlet>
Then define the servlet mapping:
<servlet-mapping> <servlet-name>cgi</servlet-name> <url-pattern>/cgi-bin/*</url-pattern> </servlet-mapping>
If you added this info in default-web.xml, you gonna need to restart GlassFish. Then in you web application, creates a folder under
and drop you CGI under than folder, then deploy your application. You will be able to execute your CGI by doing:
technorati: grizzly cgi glassfish
_uacct = "UA-3111670-1";

subset: commoncrawl


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Message-Bus: Groupon Messaging Platform Open Sourced
I wrote a post earlier to describe the distributed messaging platform, Message Bus, used at Groupon. I'm excited to announce, as I promised earlier, that this project is available as open source. You can get the code at Github. Message Bus transfers over a hundred gigabytes of messages everyday. These messages include order details of… Read More


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It's empty in here!
These bones look really good and my dog seems to enjoy them. I also think they are a great price
These bones look appetising and my dogs love them. Barkoo is an excellent brand
I thought I would test something new and I'm pleased I did. My dog loves these and it keeps him amused for ages.
These chew bones are really popular. My dog loves them and polishes them off. There is not a crumb to be seen when he has finished. A great way to keep him occupied


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19 Feb How to annoy, upset and aggravate your bankruptcy trustee and delay your discharge – one of a series
When you file a bankruptcy case, your bankruptcy trustee wants data. Depending on the district you live in, it could be a little or a lot. You have a duty to cooperate with the trustee. Not only that, it's common sense. The trustee is the main thing which stands between you and your discharge. And you want a discharge. You want to be free of all your pre-bankruptcy debts. You don't want hassles. You don't want to pay your bankruptcy lawyer additional fees. And you don't want to be reported to the United States Trustee or have your case dismissed. You don't want to be brought before the judge to explain why you failed to do what you were supposed to do.
What kind of things will a trustee want?
- Your most recent tax returns or transcripts
- Your most recent pay stubs from work
These two items are mandatory in all districts. One way or another, you have to give this to the trustee. This verifies how much you make and what your sources of income are.
What else can a trustee reasonably ask for?
- Your recent bank statements
- Your recent credit card bills
- Your recent business records
Failure to maintain and provide the trustee with sufficient records with which to ascertain your financial affairs could lead to loss of discharge. At the very least, it could lead to the trustee extending the time within which to object to your discharge. These are bad. You'll lose time and may even have to pay your bankruptcy attorney more money to handle your case.
Depending on your case, a trustee could ask for more information like:
- Records regarding sales of assets, including real estate or businesses
- Records regarding disposition of assets in a divorce
- Records regarding any litigation in which you have been involved or claim to have a right
Play ball with the Trustee. She has the right and obligation to look into your affairs. Cooperation and full disclosure is the key to a prompt discharge in bankruptcy.
Latest posts by Jay Fleischman, Esq. (see all)
- 5 Things You Need To Know About Bankruptcy Exemptions Before Your Case Is Filed - August 28, 2013
- Beware Of This Person When Trying To Wipe Out A Second Mortgage In Chapter 13 - August 26, 2013
- Our Best Tips For Filing For Bankruptcy Without Your Spouse - August 22, 2013
- 5 Ways To Celebrate Financial Literacy Month - March 31, 2013
- Burning Money With Handcuffs On - March 21, 2013


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Pakistan High Commission – UK
Important Announcement:
17th December 2019
Gerrys office in UK will remain closed from 25th to 26th December 2019 AND 1st January 2020 on account of Christmas/ Quaid-e-Azam Day & Bank Holiday for New Year 2020. There will be limited working on 24th December 2019 till 1 PM for collection of passports and submission of visa applications. Passports cannot be collected during closed holidays.
Applicants are therefore advised to apply before the 23rd to avoid last minute disappointment & inconvenience.
For Emergency/Death cases during these days– applicants may contact the emergency contact numbers given on our website between 1000 – 1400.
6th November 2019
Same day service for dual nationals is not available at Birmingham and Bradford Consulates.
For the purpose of same day service those applicants are considered dual nationals who are having Pakistani ID Card/Passport.
5th September 2019
Due to Ashura Muharram holiday in Pakistan High Commission, Gerry's offices in UK will be working partially on Tuesday 10th September 2019 from 9.00 AM to 2.00 PM.
No same day service will be available on this day as High Commission and its Consulates will be closed for visa services.
22nd August 2019
Gerry's Visa Centres in U.K. will be closed on Monday 26th August 2019 on account of SUMMER BANK HOLIDAY. Emergency cases will be dealt with as usual as indicated on our web site.
8th August 2019
On the occasion of Eid-ul-Adha, Gerry's Visa Application Centres in the United Kingdom will be closed on 12-13 August 2019 as holidays declared by the Pakistani High Commission.
On 14th August (Independence Day) Gerry's offices will be open from 9 am to 2 pm for submission and collection of passports. No same day service will be available on that day. Passports will not be delivered during the holidays.
Usual working hours will start from 15th August, 2019.
In extreme emergency situation during Eid holidays, our emergency nos. on our website www.gerrysvisa.com/countries/pakistan may be called.
27th May 2019
Gerry's Visa Application Centre Manchester currently located at Suite 1.01 & 1.02 Citibase Manchester Salford Quays, Salford M50 3SG will permanently relocate to:
Suites 10, The point,
173-175 Cheetham Hill Road,
Nearest Bus stop: Cheetham Hill Road
Bus Numbers: 41, 49, 135
Submission of visa applications and passport collections can only be made from the above address after 30th May 2019.
Gerry's in the UK:
Gerry's Offshore is pleased to announce the collaboration with Pakistan High Commission in the UK to facilitate the travelers to Pakistan in general and Pakistani Community in particular to provide convenient and expeditious Visa Application submission. Our Visa Application Centers in London, Birmingham, Bradford and Manchester are open for the business and we will shortly announce the opening date of our VAC in Glasgow.
Our dedicated and trained staff at VAC will assist you in submitting the visa application however we would suggest that before visiting the VAC please visit our website www.visadropbox.com or speak to our call center agent for any assistance that you may require. The more you will come prepared it will help our staff to process your visa application in the quickest possible time.
|Visa Fees
|Visa Form
|Visa Application Center
|Inquiries – Gerry's Call Center
|Feedback and Complaints
|Important Information
|Check List
|Collection of Passport
We will extend personalized and more efficient service to the valued applicants of Pakistan High Commission. The key features of our Visa Application Center are.
> Convenient Location – Close to Underground / Bus Station
> Comfortable Environment
> State of the art Visa Facility
> Dedicated and fully trained staff
> Speedy and Efficient submission
> Extended Application Submission Time
> Visa Application Submission on Saturday
> Free Passport Home Delivery (*)
Free SMS Alert (*)
Premium Lounge services(*)
> Visa is liable to be cancelled if the information requested in the form is withheld or found to be incorrect.
> British Nationals not resident in the UK should apply for the visa in their respective countries of residence.
> Visa is usually issued after five (5) working days, however, can occur due to circumstances beyond the High Commissions control, especially where a reference has to be made in Pakistan.
> At the time of passport submission photocopies of all supporting documents must be provided.
> In case of any extreme urgency during the weekend, please contact our staff for assistance
|Emergency contact (dual citizens)
Available only in emergencies cases, such as death and serious illness of dual nationals on weekends and public holidays.
|Mobile# 07914766686
|Mobile# 07405601712
|Mobile# 07550897975
|Mobile# 07965961900
Operating Hours:
|Visa Application Submission:
|Monday – Friday, 09 am to 02 pm.
|Saturday, 9 am to 1 pm
|Passport Collection:
|Monday – Friday, 02pm to 05pm
|Saturday, 9 am to 1 pm
|Submission of Visa Application for the Same day:
|Monday – Friday, 09 am to 11 am.
|(This service is available for Dual Nationals only)
Lunch and Prayer break on Friday: 1:30 pm to 2:30 pm.
Application progress and Collection times will be via sent to the applicants via text message
January 28, 2020
Gerry's Visa and Miracles Trust signed a Memorandum of Understanding to establish their formal partnership and work together to achieve their common goal, to create a more sustainable future and an increasingly conscious community.
January 28, 2020
Due to the recent earthquake, customers are advised that the UK Visa Application Centre in Mirpur will remain closed until further notice.
January 28, 2020
The new Chinese Visa Application Service Center will help facilitate the business community, students and tourist of Punjab in applying for visa applications to mainland China, Hong Kong SAR and Macau SAR. The visa facilitation service provided by Gerry's Visa offers a comfortable environment, additional value added services and absolute safety and security to the applicants.
January 28, 2020
Gerry's Visa is proud to announce our first clothes donation drive in collaboration with Akhuwat Clothes Bank. We are collecting winter clothes for those who cannot afford to buy new clothes.
January 28, 2020
Applicants are requested to pay only for the published charges/applicable fees. Anyone demanding charges/fees other than the ones listed, should be reported immediately to the Visa Application Centre Manager and file a complaint at: [email protected]
January 28, 2020
4 FedEx offices are now accepting UAE attestation applications in Karachi
January 28, 2020
Gerry's Visa, under the umbrella of corporate social responsibility, has recently partnered with Saaf Suthra Sheher to reduce their footprint by collecting and disposing of recyclable waste generated in their Islamabad office and to help mainstream recycling into society.
January 28, 2020
Gerry's International Pakistan and the Ministry of Foreign Affairs of the People's Republic of China have signed an agreement on the development of Chinese visa application centres in Pakistan at an impressive ceremony held in Beijing on 6th March 2019.
January 28, 2020
Call now toll free to learn more about attestation applications to the United Arab Emirates' diplomatic missions. Our new dedicated number is 051-843-9332!
January 28, 2020
Gerry's Visa was recently awarded certificates of the International Standardization Organization for their excellence in Information Security Management and Quality Management.
January 28, 2020
Jazz users unable to connect to Gerry's Contact Centre are requested to dial 0900 07860 instead.
January 28, 2020
New visa application and legalization requirements will be implemented by the Embassy of Argentina from the 1st of February, 2019.
January 28, 2020
Some of our Visa Application Centres will be closed during Ashura. Check here for more details.
January 28, 2020
Click here for more information about the opening hours of our Visa Application Centres during Eid-ul-Fitr 2019.


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Ashlyn joined the Battlefield team in May of 2017. She completed her Masters in Marriage and Family Therapy with a certificate in Trauma Counseling through Richmont Graduate University in May 2017, and is working several days each week as a counselor in the Cartersville office.
Ashlyn received her Bachelor's Degree in Psychology from Berry College in 2012. Upon graduating, Ashlyn worked with college students for two years before moving to Atlanta to start her journey as a counselor. Ashlyn has enjoyed building community in Atlanta at her local church, kayaking the Chattahoochee River, and enjoying some of the local eateries.
Ashlyn has the desire to be a safe and authentic place for people in the pain, confusion, and difficulties often encountered in life. The desire for this comes from God's own desire to move toward the brokenhearted and offer them comfort and healing: "The Lord is close to the brokenhearted and saves the crushed in Spirit" (Psalm 34:18). In addition to providing a safe place in pain, Ashlyn desires to journey with others as they understand their story more fully and how this fits into God's overarching story. Ashlyn has experience working with trauma, codependency, family of origin, relationship difficulties, anxiety, depression, and spiritual development/concerns.
"Do not despair, thinking you cannot change yourself after so many years. Simply enter into the presence of Jesus as you are and ask him to give you a fearless heart where he can be with you. You cannot make yourself different. Jesus came to give you a new heart, a new Spirit, a new mind, and a new body. Let Him transform you by His love…" ~Henri Nouwen
Email: firstname.lastname@example.com
Office: 706-235-9350
Fax: 770-936-1955


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After a rogue bidder from mainland China sabotaged Christie's sale of $40 million worth of Qing dynasty bronzes recently, both buyers and sellers may be feeling jittery about the upcoming Asia Week sales in New York, which kick off March 17.
Every spring, auction houses, fairs, galleries and museums highlight artworks from Asia over a multiple-day stretch known as Asia Week. The worldwide economic crisis has put a damper on events this year. Auctions and shows are going forward in slimmed-down form, and there has been one major casualty: a British outfit, Haughton International Fairs, announced in December it would not run the fair it has put on for the past 13 years in the armory on Park Avenue and E. 67th St. in Manhattan.
But amid the recessionary gloom lies a silver lining for collectors: carefully curated sales, lower auction estimates and buying opportunities. That's welcome news, as is the opinion of experts in Chinese art that it's highly unlikely any of the works up for auction in New York will meet with the same controversy as the disputed Qing dynasty bronzes.
One example of an extraordinary piece with an almost laughably low estimate: a Yongzheng-period (1723-1735) porcelain vase that is only the second of its kind known to exist. The vase's twin is in a public collection in the Palace Museum in Beijing. Intricately decorated, the piece has a curvy, ribbed, globe-shaped body and trumpeted opening. Christie's, which is including the vase in its March 18-19 auction of Chinese ceramics and works of art, has pegged its value at just $100,000-$150,000.
"When I saw this piece, I jumped out of my skin," says Carol Conover, a Chinese art and antiquities dealer in New York. "I've never seen one of these out of captivity; I didn't know there was one extant." Conover, who ran the Chinese art department at
Why would Christie's estimate the piece at a fraction of that amount? Christie's specialist Joe-Hynn Yang admits he's employing a tool often used by auction houses to woo bidders in a down market. "It's a come-hither estimate," says Yang.
Yang adds that there is no chance of a challenge to Christie's right to sell the piece, since the vase has belonged to the same Chinese-American family since the late 19th century.
By contrast, Christie's had to battle an ownership claim last week when two controversial bronzes, part of the late-February Yves Saint Laurent sale in Paris, inflamed passions. The Chinese government considers the items to be looted treasures that belong in their country of origin.
Ironic, says James Lally, a Chinese art dealer in New York. The emperor who commissioned the bronzes, for a water-clock fountain configured around the Chinese zodiac, was a fan of Western art. The heads were made under the supervision of Italian Jesuits, notes Lally.
If you liked this story, read:
Yves Saint Laurent Auction Sabotage
"The idea that they are Chinese patrimony is doubly ridiculous," he emphasizes. "They have nothing to do with Chinese art, except as an example of outside influence."
Nonetheless, the bronzes became a political lightning rod. Prior to the auction, a group called the Association for the Protection of the Art of China in Europe challenged the sale in a French court, and lost. Then, post-sale, the winning bidder, Cai Mingchao, a seasoned antiques dealer in mainland China who has bought multimillion-dollar pieces at international auctions in the past, announced he was welshing on his $40 million purchase as a protest, because he believes the bronzes were looted.
Bloomberg subsequently reported that, according to the Xinhua News Service, Cai acted without the support of the Chinese government. It's possible, however, that the government gave Cai a wink and a nod.


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Kotobukiya returns to one of their Bishoujo hits with a re-issue of Batgirl !
The cutest Barbara Gordon you'll ever see !
Based on a character interpretation by master illustrator Shunya Yamashita !
Barbara Gordon looks great standing atop a gargoyle base in this highly detailed 1/7 scale statue.
With her long red hair and cape flowing in the breeze, Batgirl strikes a dynamic pose, perfect for display on your shelves !
Batgirl looks great on her own and even better alongside other Kotobukiya Bishoujo statues !
TM & © DC Comics. (s14)


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Viewing Log #34: Lateral Collateral [2/15/10 - 2/21/10]
by Ryland Walker Knight
This past week I watched a bit of all of Wes Anderson's movies here and there*, I looked at A Serious Man and The Informant! again, and a whole bunch of basketball games, as well as a basketball movie on hulu. I also wrote a bunch about Wes Anderson, and then rewrote it a lot, and need to give my text one final pass right now. (More on this soon.) I read some Philip Larkin and some Cavell and even wrote some poems of my own. I worked a lot and my brain got tired in a different way. I plan to work out more in the coming months by swimming laps because running only hurts my knees ever since I fell. I still walked the dog in the sun and in the rain. I drank a fair number of beers on a few different nights. I danced at Soul Night and Barry introduced me to those DJs and they seem like swell dudes. Pretty packed. Still plenty left on the dining room table.
—Here's another goodrn, Tom
*Since people like lists, here's how I'd rank the Wes films in preferential order, which, of course, doesn't mean it's anything but my taste, which I think should be shown to favor the formal and the hilarious first. Do you remember just how funny these movies are? I'll expand on this more later, but, the gist is this: making comedy makes sense (in nonsense) as much as light of the world and its problems, is hard, should be a bigger part of so-called serious art and, for that matter, a bigger part of so-called serious people's canon.
- The Life Aquatic with Steve Zissou, 2004
- Rushmore, 1998
- Fantastic Mr. Fox, 2009
- Bottle Rocket, 1996
- The Darjeeling Limited, 2007
- The Royal Tenenbaums, 2001
This coming week I have some sure-fire movie-going bets, though, including the Dorsky night at PFA, which means Lost will get pushed back a bit, and I want to see Shutter Island three days ago, and I may even brave My Son, My Son if I have the time. What's more, there's a ton of SFIAAFF screeners to get to, like the new Hong, which I plan to write about in the near future. Anyways, back to editing before bedtime, before another week of madness. Here's hoping that, with the right attention and application and sleep schedule, everything heals.


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David Lynch's limited-edition Dom Perignon bottles hit your premium local liquor stores: Two twin peaks you might want to cache away for a dark-and-stormy night watching 'Blue Velvet.' Goes down…smooth…
About the design—and his favorite things–we interviewed the inimitable Mr. Lynch earlier this summer for The Wall Street Journal, out on his turf, in under-cover-of-daylight Los Angeles. They're pretty gorgeous, mysteriously speckled, and "nifty"!
A note from the publicist says: "Although available in the highly-celebrated vintages, Dom Pérignon 2003 and Dom Pérignon Rose 2000, the suggested retail price has not been increased for this limited edition."
We don't know the price, frankly. But if you're a fan, well, they're BOTH class acts. The dude's the cat's pajamas, as he might say. Folksy but erudite, Montana-meets-Paris. And we'll always have both.


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During a time when your health is facing uncertainty,
Critical Assist® Income protection in Val Caron can help ease financial burdens and help you focus on your recovery when dealing with critical illness or disability. Depending upon your needs, the lump sum benefit amount of this critical illness insurance coverage can range from $25, 000 to $2, 000, 000. Our insurance keeps you covered.
We afford you the freedom to make use of the funds you receive to continue making mortgage and other loan payments.
Talk to
As a responsible corporate citizen, we believe in balancing our economic, environmental and social priorities. In fact,
Val Caron has a public income policy system that provides a minimum level of mandatory coverage to vehicle owners when they purchase license plates.


text:
Monday Minute
Holy Trinity's Weekly School Newsletter
2016 - 2017 Calendar
May 2017
23: 4th Grade Field Trip to Stauffer-Will Farm!
24: School Mass (hosted by 6th Grade) @ 2:15
29: Happy Memorial Day! - No School
31: School Mass (hosted by 7th Grade) @ 2:15
June 2017
01: Math Family Fun Night @ 5:00 (cafeteria)
02: Food Free Dress (2 cans + 1 picnic condiment - summer food drive)
06: Spring Concert @ 6:00 (church)
07: School Mass & Candle Passing (hosted by 8th Grade) @ 2:15
08: Field Day
12: 8th Grade Graduation
13: 4th Grade Field Trip to Bonneville Dam
14: 1st Grade Field Trip to West Hills Nursing Home
Closing School Mass (hosted by Choir) @ 2:15
16: Full Day of School - Regular EC
19: Last Day of School - Snow Make Up Day
Noon Dismissal - NO EC
Book Fair News!
Volunteer Opportunities
Need Sharepoint hours? Volunteer HERE
Lunch Notes
Questions or concerns regarding the hot lunch program, please contact our Lunch Coordinator, Kris Arbaugh at email@example.com
Summer Enrichment
St. Pius is offering summer enrichment camps. Click here for more information: Summer Camps @ St. Pius
Math Family Fun Night
Come one, come all to the Holy Trinity Math Club's 3rd Annual Math Family Fun Night! Students have been working hard to create math games for all ages.
Come and join us for a night of fun and prizes!
Summer Food Drive
Let's stock our food pantry for summer!
In the summer months, the food pantry receives donations for summer-time food items such as hot dogs, hot dog buns, etc. One item that the food pantry is often short on, however, is condiments.
In addition to the normal two-can, June donation, please bring one non-perishable condiment item: ketchup, mustard, mayonnaise, relish.
CYO Athletics
Congratulations to our students who competed in this weekend's Meet of Champions! Here are the highlights:
A HUGE congratulations to Ally Koelling in qualifying for the Meet of Champions in the 100m which will be held this coming Thursday.
Volleyball and Fall Hotshots registration is now Open!
child(ren). This is very easy to set up and takes seconds once on our
club's site. If you have one already set up from a different sport or
league, you can use this for CYO registrations. (ie., Westview Softball) There is a REGISTER NOW button once you are logged in.
Mission Statement
"Through academic excellence, Holy Trinity Catholic School prepares students emotionally, intellectually, morally, physically and spiritually for the world in which they live."
Sch. Phone: (503) 644-5748
EC Phone: (503) 643-1056
Fax: (503) 643-4475
Email: firstname.lastname@example.com
Parish: www.h-t.org
Holy Trinity Catholic School
13755 SW Walker Road
Beaverton, OR 97005
Holy Trinity is accredited by:
The Western Catholic Education Association


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Apartment for Sale
Property Ref: WRE-S-2784
Status: Available
- 3bedroom(s)
- 3bathroom(s)
- 1823 sq ftarea sq ft
- Balcony
- Basement parking
- Broadband ready
- Broadband ready
- Built in wardrobes
- Central air conditioning
- Community View
- Covered parking
- Fully fitted kitchen
- Intercom
- Kitchen white goods
- Laundry/washing room
- Maid's room
- On low floor
- Pets allowed
- Shared swimming pool
- Solid wood floors
- View of gardens
- View of sea/water
- 24 hours Maintenance
- Beach Access
- Children's nursery
- Children's play area
- Communal gardens
- Concierge service
- Cycling tracks
- Fitness Center
- Laundry Service
- Public parking
- Recreational Facilities
- Restaurants
- Shops
- Walking Trails
3 bed apartment | situated on the Island3 bedroom (Type 3C)
Family apartment situated on the Island and close to all facilities-
- Entrance Hall
- Guest Cloakroom
- Lounge/Dining Room
- Open Plan Kitchen
- Utility Room
- Maids Room with Shower Room
- Three Double Bedrooms
- Master Bedroom with Dressing Room & 4 piece En Suite
- Family Bathroom
- Two Balconies
Al Muneera, consists of a neighborhood with a mix of luxury living on the waterfront as well as distinctively designed multi-storey apartment buildings. A tranquil canal has been created as a result with cafes and restaurants located along waterfront paths and promenades for residents and the general public to enjoy.
-Basement parking
-Broadband ready
-Broadband ready
-Built in wardrobes
-Central air conditioning
-Community View
-Covered parking
-Fully fitted kitchen
-Kitchen white goods
-Laundry/washing room
-Maid's room
-On low floor
-Pets allowed
-Shared swimming pool
-Solid wood floors
-View of gardens
-View of sea/water
-24 hours Maintenance
-Beach Access
-Children's nursery
-Children's play area
-Communal gardens
-Concierge service
-Cycling tracks
-Fitness Center
-Laundry Service
-Public parking
-Recreational Facilities
-Walking Trails
Apartment for Sale: Al Maha 2, Al Muneera, Al Raha Beach
- 3bedroom(s)
- 3bathroom(s)
- 1823 sq ftarea sq ft
Arrange a viewing with Henry Wiltshire Abu Dhabi branch
firstname.lastname@example.com | +971 56 484 3380
Make an Enquiry
Contact Abu Dhabi Office
Arrange a Viewing
Arrange a Viewing
Please contact us with your details to arrange a viewing, and a member of our team will be in touch shortly.


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Pan Latin American Hashomer, 18 years later
In 1994/1995, I spent probably the most unique and memorable year of my life with the people of several Zionist youth movements in Israel, working in a kibutz, learning in Jerusalem...
In 1995, after most of my group returned to Mexico, I stuck with the newly arrived South American group of Hashomer Hatzair (plus some affiliates).
We were 18-19. And 18-19 years later, here we are: Fabián (from Buenos Aires) and Fabiana (from Montevideo), living in Buenos Aires, with two kids. Regina (from Paraná) and me (from Mexico), living in Mexico, no kids yet.
Two couples. Three countries. Four cities. And a lovely evening. And the hopes to stay in touch, to meet every year when we come to visit Argentina.
You got a nice experience in
You got a nice experience in the land. I do not know how it feels living a life with the people of several Zionist youth.
Precisamente así
Querida prima, en vez de un "me gusta" que no requiere del menor esfuerzo o creatividad personal, al dejar este mensaje muestras un verdadero "me gusta", uno que deja ver parte de tu esencia y tu personalidad. ¿No es acaso maravilloso? ;-)
y aquí cómo le hace uno para poner "me gusta"???


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Our nation's tragedy was commemorated and reminded by Jobbik on Saturday
It was 96 years ago that the Trianon peace dictate was signed, as a result of which 2.3 million Hungarians were stuck beyond the new borders drawn on the military maps and subjected to the rule of foreign and hostile countries building their national states. For their own selfish strategic considerations, the Paris peacemakers disrupted the millennial economic and political unity of the Carpathian Basin, erecting hard-to-break obstacles in the way of cooperation in such matters as flood relief or environment protection, which have proven extremely harmful for other countries as well. Meanwhile, they planted mutual fear, the so-called "Trianon Syndrome" in the souls of the Carpathian Basin's nations who had already been divided yet had always been co-dependent. Up to this day, this fear has always prevented any honest cooperation among the region's nations and states, subjecting them to the whims of the neighbouring great powers.
Apart from a few magnificent years, the Hungarian community has constantly been weakening, dropping in numbers and dying in the Carpathian Basin ever since. The successor states are still unwilling to ensure even the most fundamental individual and collective human rights for the native Hungarian communities who got on the other side of the border against their will, while their governments also try to break them economically by making their lands uninhabitable.
In Transylvania, standing for regional autonomy is considered by the Romanian authorities as an act of terrorism and they impose severe fines on individuals waving the Szekler banner or singing the Hungarian anthem. As shown in the short documentary film presented by our MEP Krisztina Morvai, they even block the use of the Hungarian language, contrary to all international and European norms of human rights. The pledge made in Gyulafehérvár (Alba Iulia) has remained unfulfilled up to this day. In Transcarpathia, local Hungarians are used as cannon fodder in a pointless war and threatened by secret service methods on account of their Hungarian citizenship and national feelings, just as it recently happened to Jobbik's Transcarpathian organizer. In the Northlands, the Beneš Decrees based on the principle of collective guilt of Hungarians are still part of Slovakian law, they prohibit assuming Hungarian citizenship, while many of the small Hungarian schools are threatened to be closed in spite of the earlier promises. In the Southlands, the Hungarian communities direly decreasing due to economic emigration still have no hope for a real and wide regional autonomy despite Kosovo's example and Serbia's upcoming EU accession, even though such autonomy could be the only token of long-term survival. The situation of Hungarian communities is not satisfactory even in Austria, Croatia and Slovenia which are often referred to as examples of ethnic tolerance. The human rights of local Hungarians typically exist on paper only. For instance, Slovenia has been unable to pass the extremely important legislation on ethnic minorities for 5 years.
Therefore, unlike for Fidesz, 4th June will never be a singing-dancing jubilee for us. For us, this day will always be a day of mourning, when we remember and remind others. It is shown by our commemorations organized all over the Carpathian Basin as well as Jobbik Youth Platform's initiative called "You can do more than you think".
On all other days however, even in government after 2018, we will always keep on working to heal the still painful wounds caused by the Trianon treaty. Naturally, Jobbik's government will consider the cooperation with the neighbouring countries as fundamentally important but our foreign and national policy will have the priority for the representation of the Hungarian communities living abroad. For example, we will subject backing Serbia's and Ukraine's EU accession to the condition that they implement a wide territorial autonomy and we will employ our best endeavours to support the rightful demands of the Hungarian communities torn away from us and living in the Carpathian Basin. We believe this is the only way to ensure that the 21st century could become the century of unity, rise and prosperity for the Hungarian nation after the destructive national disasters brought by the 20th century!
MP István Szávay, Chairman of Jobbik's National Policy Cabinet


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Tonight kicks off the first public meeting to be held for the five planning zones in Butler County. Enact legislation to permit the U.S. Military Corps of Engineers to retain all collected recreation fees to be used at its services. We must help Congress acknowledge the importance of those locations and the return on investment that recreation infrastructure provides.
The Recreation HQ has fired up its alert system with reference to yesterday's House Subcommittee on Federal Lands listening to on two crucial OHV-related legislative initiatives. A recreation specialist can be anticipated to meet the leisure needs of a neighborhood or assigned interest group.
To discover the pure resources, or to work for the society growth or to shift the technical information, out of doors jobs are supplied now by each the Public sector and the non-public sector throughout the world with a multiple economic advantages, which imagine was a dream prior to now.
The BS Program has accreditation from the Council on Accreditation of Allied Health Schooling/Committee on Accreditation for Recreation Remedy. The Affiliation of Bodily Health and Promotional Steerage has acknowledged that the wants are growing, and lots of countries have jumped on the bandwagon for these new playgrounds.
Some specific positions accessible with this degree are camp director, health membership manager, director of recreation and parks, leisure therapist, and exercise specialist. Academic establishments supply courses that lead to a level as a Bachelor of Arts in recreation administration.


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Web Friendly
is here to support you on your next web project
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Web Friendly transforms brands into dynamic growth platforms thanks to our understanding of cultural trends and technology.
We are a full-service digital agency with experts that can help your organization grow! Our areas of expertise range from web development, SEO, web design, app development, data analysis and content marketing.
Holistic approach
We create and implement holistic strategies that are reflecting into the multiple perspectives on the company's activities.
We make success stories by providing complete solutions with measurable results.
Our Services
If you looking for a full-service digital agency in Amsterdam, Web Friendly is the answer. Our passionate and creative team of experts is ready to take any challenge and deliver a successful project.
With no exception, we implement all our projects with the perfect combination of specialized online experts whose sole aim to make our clients happy.
Our services include, but are not limited to, the different areas of expertise such as Strategy & Insight, Concept & Storytelling, Design & UX, Development & Technology, Promotion, Analysis & Reporting.
20+ web projects
have been successfully managed and completed by Web Friendly during the last 12 months.
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Companies and individuals from 5 different countries trusted Web Friendly to improve their online presence.
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I worked with Sofia on a website project for one of my beauty clients. The project was very intensive and time consuming. We needed to rebuild the entire site within a short period of time. Sofia was extremely helpful during the entire process. Her attention to detail and communication skills made the project management seamless. We were able to deliver the website on-time and with the clients needs met. Without her extensive work and ability to focus the project would have been unmanageable. I would highly recommend her for web development and design work.
When it comes to site reconstruction, Web Friendly is the only solution. Sofia and her team know how to approach the customers, understand their needs and complete in time every task despite the difficulties.
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Our friendly team
We are a group of independent professionals, with a passion to make web products that users will love.


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With Gateway Pass, teachers can access all TEA Gateway Applications through a single account. TEA Gateway Applications currently include the Texas Gateway for Online Resources, Gateway Courses, and the Texas CTE Resource Center. Learn more about these applications below.
Texas CTE Resource Center
Find high-quality instructional materials and resources for CTE teachers, counselors, and administrators.
Texas Gateway for Online Resources
Discover TEKS-aligned, classroom-ready instructional materials and professional development resources.
Gateway Courses
Access online professional development training courses for Texas teachers.


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Dr. Siddiki says, "When you step into His purpose, grace causes things to work out. Grace is an umbrella that you never want to leave home without. Grace is a place where you want to spend your life. You will find yourself under the umbrella of His grace when you are fulfilling God's purpose for your life."
The Apostle Paul was a wonderful example of someone walking in the fullness of God's grace. He said in 1 Corinthians 15:10, "By the grace of God I am what I am, and His grace toward me was not in vain (fruitless and without effect); but I labored more abundantly than they all, yet not I, but the grace of God which was with me."
The grace that was with and upon Paul was to travel, bring the Gospel throughout the known world, and start churches wherever he went. He knew how to stay under God's umbrella of empowering grace.
In Part 2 of this grace-filled teaching you will learn:• Grace is a place where we can't be moved• Grace will cause us to overcome every problem and trial• God's grace is accessed by faith• Unmerited favor is only one of the wonderful benefits of grace• Grace is always given for a purpose or task
The purpose of God's graces is to fulfill God's purpose. Whatever God wants you to do; you can't do it by yourself. You must have God's grace to accomplish His purpose. Let Dr. Siddiki teach you how to receive God's empowering grace so you can accomplish your purpose and God's plan for your life.


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Beer and Bluegrass Festival
The Beer and Bluegrass Festival is now in its fifth year, attracting top quality Bluegrass, Americana and Roots music acts from across the world. Closing night 'Jams' feature many artists joining together on stage, singing and playing 'Bluegrass Style' around a single microphone to close each evening. The results are breath-taking and totally unique, adding a very special atmosphere to the Festival.
The Festival is set in the secluded grounds of Victoria School with the main stage set within a natural amphitheatre, surrounded by woodland and with the stunning 'Claremont' a Victorian convent in the foreground.
We have the very best of Real Ales and Ciders from top craft brewers with excellent quality home cooked food available.
Situated between Poole and Bournemouth and minutes away from the finest beaches in the UK and with easy transport links, visit Beer and Bluegrass, one of the best small Festivals in the UK.
Please note this is a non-smoking venue. Under 18s must be accompanied by an adult.
Poole Tourism Ticket Sales
Please contact the Poole Tourism shop on the High Street (no booking fee) where they have lots of tickets that can be purchased over the counter, alternatively tickets can be bought online via the Pavilion in Bournemouth and with We Got tickets and BH Live.
Guide Prices
|Ticket Type
|Ticket Tariff
|Friday Only Ticket
|£16.00 per ticket
|Saturday Only Ticket
|£18.00 per ticket
|Weekend Ticket
|£25.00 per ticket
Ticket prices will remain the same great value as 2018.
Children are free to enter if they are no higher than the tallest parent's shoulders, otherwise normal ticket price. Children under 18 are not admitted without a parent.
Dogs - Well behaved dogs are welcome but must always be a lead.
Strictly no admission without a Ticket or Proof of Purchase - No refunds on door.
Disabled Access – Although Victoria caters for disabled people there are some areas of the Festival site which are not wheel chair friendly, please contact us in advance if you or another visitor is disabled and are planning to visit us, so we can make prior arrangements for your Festival visit to make your visit a pleasure.
All tickets include a Free Festival Glass and Programme !
2019 looks like the busiest year yet, so we cannot promise Tickets on the Door.
Due to the popularity of Beer and Bluegrass, it's a first come, first served basis. Please Buy in advance at the Poole Tourism office just off Poole Quay (No Booking Fee) or All Hail the Ale - Queens Rd Westbourne & Firkin Shed - Holdenhurst Rd Bmth ( No Booking Fee ) and of course our excellent online partners
BH Live Ticket line or We Got Tickets.
Opening Times
Sorry, this event has passed


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U.S. multinationals literally have trillions of dollars of untaxed earnings purportedly "trapped" offshore because of the associated high U.S. corporate income taxes that would be incurred if these earnings were repatriated to the United States. While a number of strategies have been marketed to, and used by, U.S. multinationals in an attempt to repatriate these earnings in the most tax-efficient manner, one by one the IRS and Treasury effectively are shutting down these transactions through the issuance of new regulations.
For example, in April of this year, the IRS and Treasury released Notice 2014-32, announcing plans to issue revised regulations under Section 367(b) that would limit the ability of U.S. multinationals from engaging in so-called "Killer B" transactions. In general, a Killer B transaction is a triangular reorganization in which a foreign subsidiary purchases shares of its parent stock for cash or a note, and has the effect of repatriating untaxed profits from a foreign subsidiary to its U.S. parent without triggering a taxable dividend to the U.S. parent. (See Rubinger and Kruler, "Notice 2014-32 Takes Further Sting Out of 'Killer B' Transactions," Journal of Taxation, August 2014).
In March of 2013, the IRS and Treasury issued temporary regulations under Section 367(a)(5) preventing the tax-free repatriation of foreign-source profits to the United States without gain recognition under Section 367(a) or Section 367(d) in an "outbound F" reorganization. An outbound F reorganization typically involves the conversion of a recently acquired U.S. target company into a foreign company, and at the same time allows for the tax-free repatriation of profits through a combination of a dividends received deduction and a return of basis.
The IRS is now challenging in Tax Court the purported tax-free repatriation of $357 million by Illinois Tool Works (the "Taxpayer") from its wholly owned subsidiary in Europe. The Taxpayer is arguing that the distribution should be a non-taxable return of basis because it was paid by a holding company with no earnings and profits ("E&P"), and the amount of the distribution was less than the Taxpayer's basis in the subsidiary's shares.
Return of Basis Transactions, in General
A distribution by a corporation to a shareholder out of the corporation's E&P will be taxable as a dividend. The portion of the distribution that is not a dividend is applied against and reduces the adjusted basis of the stock of the corporation. To the extent that the distribution exceeds the adjusted basis of the stock, such excess is treated as gain from the sale or exchange of the stock.
In a typical return of basis transaction, a U.S. parent corporation transfers the shares (generally with a high basis) of a foreign subsidiary to a foreign holding company in a non-taxable exchange. The foreign holding company borrows money from a third party. The foreign holding company then makes a distribution to the U.S. parent before the end of the taxable year and prior to the time that the foreign holding company has any E&P. In the following year, the foreign subsidiary makes a distribution to the foreign holding company, who then uses the cash to repay the loan.
The U.S. parent argues that the distribution received from the foreign holding company is non-taxable because the holding company has no E&P, and the amount of the distribution is less than the adjusted basis of the foreign holding company shares.
Illinois Tool Works
Illinois Tool Works, Inc. (the "Taxpayer") is a U.S. corporation that wholly-owned Paradym Investments Ltd. ("Paradym"), a U.S. subsidiary. Paradym owned a holding company in Europe ("European HoldCo"), which, in turn, owned a holding company in Bermuda ("Bermuda HoldCo"). Paradym had a basis of $1.1 billion in its European HoldCo shares. Bermuda HoldCo had numerous operating subsidiaries that had approximately $6.5 billion of E&P. European HoldCo had no current or accumulated E&P.
In 2006, needing cash in the United States to retire outstanding commercial paper and fund acquisitions, Bermuda HoldCo lent $357 million to European HoldCo. The loan was unsecured, had a term of five years, and provided for a fixed rate of interest at 6 percent. The loan was properly documented and $20 million of interest was paid each year as required by the loan documents. European HoldCo then made a distribution of the same $357 million to Paradym.
Paradym treated the distribution as a return of basis. The Taxpayer argued that the distribution was not a dividend because European HoldCo had no E&P and therefore the distribution should offset Paradym's $1.1 billion basis in its European HoldCo shares.
In 2010, the IRS issued a notice of deficiency to the Taxpayer and recharacterized the Bermuda HoldCo loan as a dividend. This would cause European HoldCo to have $357 million of E&P and the distribution to Paradym to be treated as a taxable dividend.
In the alternative, the IRS argued that Paradym had a zero basis in its European HoldCo shares. That would result in the European HoldCo's distribution being treated as a taxable capital gain (i.e., as a distribution in excess of basis).
Will the IRS be Successful?
As evidenced by the increasing number of inversions by U.S. multinationals, repatriation of offshore profits has been, and will continue to be, a significant issue. Should the IRS be successful in Illinois Tool Works, a large number of U.S. multinationals will be affected, as this type of repatriation strategy is a common planning technique.
As noted above, the IRS's primary argument is that the purported loan from Bermuda HoldCo to European HoldCo should be recast as a dividend rather than a loan. The loan satisfied most of the formal factors that typically support debt treatment, including the existence of a written instrument, a fixed maturity date, and fixed rate of interest (which was paid annually). A key feature that likely cannot be satisfied, however, is European HoldCo's willingness or ability to repay the loan as evidenced by its lack of E&P. This factor certainly will weigh against the characterization of the amount as a loan.
The IRS also may attempt to argue that the Section 956 anti-abuse rule should apply and result in an investment in U.S. property. Section 956 treats a controlled foreign corporation's ("CFC") investment of earnings in U.S. property as a deemed distribution that is included in the gross income of the CFC's U.S. shareholders. Section 956(c)(1)(C) defines U.S. property to include an obligation of a U.S. person, which would include a loan to the CFC's U.S. parent.
While the purported loan from Bermuda HoldCo to European HoldCo was not a loan to a U.S. shareholder, Regulation Section 1.956-1T(b)(4) contains a broad anti-abuse rule which gives the IRS discretionary authority to apply Section 956 to an investment in U.S. property by a nominee, or by a foreign corporation controlled by a CFC if a principal purpose of creating or funding the foreign corporation was to avoid Section 956. While not directly on point, based on the facts of the case, it would not seem to be such a stretch for the IRS to contend that the anti-abuse rule nevertheless should apply because the manner in which European HoldCo was funded was arguably to avoid Section 956.
Finally, the IRS may take the position that the "step transaction" doctrine should apply to collapse the series of steps into either a distribution or a loan directly from Bermuda HoldCo to Paradym. This would result in a taxable event in either situation.


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With our first big snow storm of the season, I was reminded that while I might be ready for Spring, Mother Nature isn't quite ready to move on. This week is Valentine's Day and prefer to stay in and cook for the people I love instead of schlepping out for an overpriced prix-fixe menu. Here is a menu that is perfect for cozying up with the one you love and I promise you won't miss the meat!
No.1 start things off with a cocktail
No.2 set the table using menu inspired ingredients
No.3 roasted brussels sprouts with garlic aioli, done!
No.4 I don't think anyone will be missing the meat with this lasagna
No.5 at the end of the evening, these biscuits are perfect for dipping in a hot cup of tea.


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We didn't want to leave anyone out with our blog post on why we all adore Nintendo. We have a lot of love to go around, and the PlayStation brand is also at the heart of the industry and for myself personally, my childhood. The PS1 startup sound is a melody that evokes sweet memories of the excitement when the classic PlayStation logo would load up on our humble sized screen. The games as a child that I would play with my sister and would be brother Jahv, would include games such as Donald Duck: Quack Attack, Tekken, Pandemonium, Spyro The Dragon and of course the infamous Crash Bandicoot — the true PlayStation mascot.
Now PlayStation, you remastered Crash Bandicoot after many years, please grace us with a remaster and continuation of Spyro The Dragon and Quack Attack. But this article would not be complete without me mentioning our love of Worms! Worms — the very simple 2D level game, wherein simple terms we would destroy opposing teams of worms in the most fun and creative ways (please go watch gameplay footage on YouTube as my synopsis is not enough justice for the game). There were many hours where myself and family would blowtorch and ninja rope across the maps, just to execute the most embarrassing and humorous kills such as the Street Fighter Ryu influenced uppercut or push if they were near the edge. Sometimes it resulted in Kamikaze, but that was part of the all loving process. Not to forget the infamous sheep…Thank you Team 17.
Coming out after the NES and the SNES, the PS1 caught me in a slightly more mature stage of childhood (5 years young) and I united with the brand ever since. As time went on, more and more classic games entered the foray such as Gran Turismo, Porsche Challenge and longtime favourite Spider-Man games. Then there were the games that also consumed many hours such as Crash Team Racing and Driver.
Upon reflection, as I write this, I think I was too young for Driver, and I most certainly was too scared to play Resident Evil when my cousin (whom I shall not name) would try to leave me to play that alone, at night as a child. I wouldn't even do that now as an adult. Some games you don't always play but you take solace in watching others play, and for me, Tomb Raider was one of those I would watch my dad play. The legendary Lucozade advert with Lara Croft in always comes to mind –
phenomenal marketing. The fact I remember the advert after decades, literally as it came out in 1998.
But beyond the PS1, we stepped into the era of the PS2, which for me was the best era of gaming so far for me, in terms of the number of great quality content titles we had to choose from. Many gamers would argue that today we have the best games, well I am not saying that the games today are not epic they are, in terms of gameplay, graphics, audio, story, integration, gaming as a service, online and more.
I just feel like we had even more options in the era of the PS2, this was heightened with brilliant of both the original Xbox (Halo etc) and the Nintendo Gamecube (Mario Kart Double Dash, Super Smash Bros Melee, Super Mario Sunshine etc). It's similar to mobile phones, back in 2005 there would always be at least 5–8 great phones you would consider to buy if not more, and nowadays we have like 1–3 phones, for some just 1 great phone option. So I am talking about depth and width in terms of game quality in that era, as opposed to today where I feel we don't have as much width, but still quality, understandably. We will discuss that another time.
I don't have enough space to write all the PS2 classics and sequels from Final Fantasy XII, Gran Turismo 3, Kingdom Hearts 2, the Prince of Persia Trilogy, Splinter Cell, GTA III, GTA Vice City, GTA San Andreas Jak and Daxter, Tekken 5, Star Wars Battlefront 2, Dragonball Z Budokai 2, Need for Speed Underground 2, Ratchet and Clank, Tony Hawk's 3, God of War, MGS 2 and a whole lot more. But this console and that entire era were pivotal to console gaming. The PS3 followed up with its own terrific library of games, and free online gameplay which resulted in many hours of me running around as a one-man SWOT team on Call of Duty: Modern Warfare 2.
Then one of my favourite game sagas in 'Infamous' was released on this console, which has gone from strength to strength since. You had the multi-award-winning cinematic The Last of Us, which was so emotive and successful it was quickly released on PS4 too upon launch. With the sequel one of the most anticipated games this year. Fallout 3, Little Big Planet, Call of Duty Black Ops 1, 2 & 3, GTA V, Red Dead Redemption, Skyrim, COD Modern Warfare and 3, Assasins Creed franchise was born and a whole host more.
Fast forwarding to 2018 and PlayStation's slogan is 'This is for The Players' and it is hard to disagree with this statement. Steaming into 2018 with an already solid PS4 exclusive catalogue, we are fortunate to already have Infamous Second Son, Street Fighter 5, Nioh, Horizon: Zero Dawn, which is such a beautiful game, truly stunning with an enthralling storyline. The Last Guardian, Uncharted 4, which, like The Last of Us is cinematic in quality, which comes as standard from majestically blessed Naughty Dog. Naughty Dog always had my affection since the days of Crash Bandicoot in the 90s.
This all seems to be the warm-up for PlayStation because just this year we have Spider-Man, Detroit: Become Human, God of War, Days Gone, Death Stranding, Final Fantasy VII Remake, Shadow of Colossus and of course The Last of Us Part II. This isn't even all of their exclusives, they are just churning out high-quality exclusives like Drake in music. It feels like a warm-up, just like Aubameyang's debut goal for Arsenal today. But for all of us gaming fans, whether we are fangirls or fanboys, we gamers are favoured with many special games. Long may it continue, as the industry needs competition. Thank you, Sony PlayStation.


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Gift Cards
Card messages are normally presented on a plain white card and envelope. However, we stock a selection of gift cards to accompany your flowers by the following designers;
Anna Wright
Wildfolk Prints
Eloise Hall
Hannah Shelbourne
Elena Deshmukh
The Art Rooms
And more…
All cards are blank, left for your own message.
If the occasion is specified for the gift, we will endeavour to choose a suitable card, be it the Birth of a child, Get well, Birthday, Thank you or general greeting.


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The Laughing Buddha, also known as Hotai, was a monk who wandered China more than a thousand years ago, carrying his possessions in a sack. Legend has it that he gave presents to children, was always good natured, and that he was able to take sadness away from people.
Perry Garfinkle, in his book, Buddha or Bust, writes, "The Laughing Buddha has become a deity of contentment and abundance...The cloth linen sack, (which never empties) is filled with many precious items, including rice plants (indicating wealth), candy for children, food for the woes of the world. His exposed potbellied stomach symbolizes happiness, good luck, and plenitude. The begging bowl, also often seen with him, represents his Buddhist nature." p. 179
This jolly fellow reminds me of Santa Claus, and I've often wondered if he inspired those first artist renderings of that holiday gift giver. Hotai also reminds me that I too carry a linen sack, albeit invisible, and I offer the world its contents.
We all have such a container as Hotai's which can never be emptied. There are certain items in this splendid pouch which are always there, although we forget from time to time. Among these are: goodwill, love, compassion, and the spark of the Divine in us all. We didn't pack these into the sack ourselves- they were always there. Sometimes its good to open the sack and take a peek again at its contents.
This invisible sack, the one that can never be emptied: It is full of gifts for you.
Peace to you, friends, peace & love & happiness & plenty & gratitude & wholeness &&&...Oh my, they're all in there!
Ho Ho Ho!


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So this was my first Ludum Dare, but not my first jam. However, this was my first jam as a code monkey, previously I've been doing only sound design. But since I've actually got a degree in computer sciences and programming, I thought to give it a try and see if I can push myself to make a game during one weekend. And yes, I more or less managed to do that, of course I had a friend doing almost all the graphics, but if you watch the timelapse you'll see I did some gfx related tasks too.
What went right:
Brainstorming ideas before the topic was announced – we had a suitable idea for almost every theme in the final votes. Escape suited us quite well but actually we were hoping for wormholes. I also had my own basecode written and ready with collision detection and controls in place. Graphics worked ok and my decision to take Gleed2D as a level editor was a good one, since it gave us a way to prototype the hud and levels prior to having actual game code ready. However I ended up tweaking the XML files generated by Gleed2D by hand after all. Porting to Mac OSX went smooth as ever and even the release bundle worked without any issues, unlike the Windows version. One thing that is good to mention here, is that we understood to cut features from the game when we saw that we don't have time to implement them.
What went wrong:
Stuck on stupid bugs, mostly due to lack of sleep. I didn't sleep nearly enough. Also our initial idea was way too big to implement in such a small timeframe so we had to drop lots of features. In the end, we had only the bare minimum of the story we had planned and basic set of the game mechanics. We didn't use enough time for testing, and that showed up in the final phase, where I was playtesting and tweaking the difficulty constantly on OSX while trying to fix audio issues on Windows. And that brings me to the fact, that choosing Phonon as audio engine, even though it's built into Qt, was a wrong decision due to severe problems on Windows. It might have worked if I'd have time to test it thoroughly beforehand. Two things I should make mental note about: have at least 1/3rd of the time dedicated to playtesting & debugging and stay away from doing sound design for other projects if your own code isn't working! 😀
Anyway, thanks for a great Ludum Dare, it was fun! Don't forget to rate our game 😉 http://www.ludumdare.com/compo/ludum-dare-21/?action=rate&uid=5118


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Scientists and their Knowledge Networks in the Cold War Era
Scientists and their Knowledge Networks in the Cold War Era
Prof. Dr. Marc Matten, Dr. Henrike Rudolph, Renée Krusche, Carolin Tzschentke, Shaoying Zhu
In the past decades, the history of science has experienced numerous turns due to new methodologies or the investigation of previously overlooked sources. This gave rise to new perspectives that have emphasized the contribution of non-European societies to both the emergence and formation of academic disciplines. While these findings have been analyzed in detail for late imperial and Republican China, the case for the People's Republic of China during the Cold War era has remained a lacuna. This project understands knowledge production as a continuous transnational process in which the countries of China, Japan, USA, Western Europe and the Soviet Union were equally involved. Applying methods of digital humanities (DH) we measure and visualize transnational knowledge flows beyond the national scale by highlighting the movement of scientists, of their publications and of research topics across time and space.


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Gwent Angling Society have game fishing for wild brown trout on the River Sirhowy.
Click here for details of other waters of Gwent Angling Society.
Contact Information:
Please note: We research this website predominantly from information and images obtainable online. We accept no liability for incorrect information or images obtained from publicly available sources. If you consider the details to be incorrect in any way we would be pleased to make any necessary corrections promptly.
Please contact us here with corrections.
Contact: Mark Roberts (Secretary)
Phone: 01495 312 508
Website: gwentanglingsociety.co.uk


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Cal/OSHA has released two new fact sheets that expand upon resources available to the public.
Health & Safety Rights: Facts for California Workers details ways for employees to work with employers and Cal/OSHA to keep their jobs safe. Protecting Temporary Agency Employees provides information on the requirements in California for temp agencies, professional employer organizations (PEOs), and host employers to protect workers from safety and health hazards in the host employer's workplace.
Cal/OSHA's Director of the Department of Industrial Relations, Christine Baker says these new online educational tools are part of Cal/OSHA's ongoing efforts to help employers and employees access critical information on workplace safety.
The workers' rights fact sheet is the first Cal/OSHA publication to focus primarily on workers' basic rights to a safe and healthful workplace and how to work with Cal/OSHA before, during, and after an inspection. Cal/OSHA will distribute printed versions at community events, training sessions and during onsite visits. The temp agency worker factsheet is the first to explain California-specific legal obligations of multiple employers that employ the same workers and is based on recent case law and Cal/OSHA's Injury and Illness Prevention Program (IIPP) requirements. It is timely given the rise in temporary workers, who are particularly vulnerable to hazards on the job.
Cal/OSHA'S chief, Juliann Sum says adds that Cal/OSHA developed this workers' rights fact sheet with input from a broad range of employers, employees and interested parties to help ensure safe and healthful workplaces.


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Building Floorplans and Room Information
As the intellectual center of campus, the Christopher Center for Library and Information Resources was designed to bring all campus information services to a single location while best serving the needs of students. The result is a welcoming, state-of-the-art learning environment that also serves as an important campus social center. The 105,000-square foot, four story the Christopher Center was designed by the architectural firm of Esherick, Homsey, Dodge and Davis. The building's thoughtful design allows services to evolve in response to the changing information environment and student needs.
ASRS Movie
If you would like to see how our Automated Storage and Retrieval System (ASRS) works, we have an online movie (3 minutes 16 seconds) which shows the ASRS in motion. Windows Media Player (or other similar software) is required to view this movie. To view the movie, click here.
First Floor
Second Floor
Third Floor
Fourth Floor
All floorplans: © 2003 Carol Naughton + Associates, Inc.
Christopher Center for Library and Information Resources: Building Location
Located in the heart of campus next to the Valparaiso University Chapel, the main entrance to the Christopher Center opens onto Campus Drive (second floor) with a first floor entrance available on the east (Chapel) side of the building. Check the campus map for further details.
Book drops are available next to the first floor entrance (Chapel side), the staff entrance (area west of the building), and inside at both the Circulation Desk (second floor) and Media/IT Help Desk (first floor).
Parking is available for staff and visitors in Lot 20 that lies to the south of the building. Entrance to the parking area is through the campus' main entrance from Highway 30. Handicapped parking is available in this parking lot as well as in front of the building just across the street. Student commuter parking is available near the Christopher Center in Lots (15 & 16).
After checking the resources listed above, call the library at 464-5500 if you still have questions.


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Neuronal stimulation and recording with high temporal and spatial resolution is indispensable for future neuro-applications, both in research and the clinic. Electrical recording is well on track in the development of devices with high count of small electrodes. However, this is not the case for electrical stimulation. Stimulating electrodes are more than an order of magnitude larger that recording electrodes.
Our main goal is to establish magnetic micro-stimulation as a new paradigm to achieve the same level of miniaturization as electrical recording. Magnetic stimulation has several advantages including i) biological tissue is transparent to magnetic fields, ii) stimulation points (magnetrodes) do not require direct contact with tissue which improves long term reliability, and iii) neuron orientation can be harnessed to achieve specificity.
Despite these advantages, current magnetic stimulation devices are large. Our hypothesis is that microcoils driven by high-frequency signals are a suitable path to miniaturize these devices. Our vison is to use microcoils to build a neural probe that will have an array of recording electrodes and stimulating magnetrodes, both of about 10 µm in size. One of the challenges is that neurons are low-pass filters and do not follow signals with frequencies higher than hundreds of Hz. Therefore, clever paradigms like low-frequency envelopes need to be explored.
During this thesis, you will establish a fundamental understanding on how to design and use microcoils and high-frequency signals to stimulate neurons. We need to find the theoretical signal parameters like frequency range, amplitude, and type of modulation that would allow a sufficiently small coil to efficiently stimulate neurons. We need to understand what coil configurations would maximize and concentrate magnetic field intensity. We need to learn how this magnetic fields interact with neurons and formulate a phenomenological model. In essence, we need to understand what is theoretically feasible.
We are looking for a highly motivated student with a solid understanding of electromagnetic physics and engineering and great interest in radiofrequency antennae and coils design. You will have the opportunity to expand your knowledge of data analysis tools like MATLAB, Python and FEM simulation software. You will have the opportunity to acquire practical laboratory experience by studying the interaction of high‑frequency magnetic fields with neurons.
Type of project: Internship, Thesis
Duration: 6-12 months
Required degree: Master of Science, Master of Engineering Science
Required background: Electrotechnics/Electrical Engineering, Nanoscience & Nanotechnology, Physics
Supervising scientist(s): For further information or for application, please contact: Sebastian Haesler (firstname.lastname@example.com) and Luis Hoffman (firstname.lastname@example.com)
Allowance only for students from a non-Belgian university


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We know that this is the time for you to buy now real iPod Touch 6th Gen leather cases. At this time there are new stunning colors included in iPod Touch 6th Gen. As well as 16GB, 32 GB, 64GB, and 128GB with latest iOS 11. Hope you're looking for your genuine iPod Touch 6th Generation cases.
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Lazio Film Commission President Luciano Sovena has revealed that a key sequence from the next film in the James Bond franchise is set to be shot in Rome. MI6-HQ has transcribed the key quote from various Italian press sources:
"I met the producers of the Bond series, Barbara Broccoli and Michael G. Wilson, and we discussed the project. One of the key scenes, among the most spectacular in the film, will be a car chase in Via Quattro Fontane.
I'm already excited. I hope that the City streamlines the procedures for the granting of permits, it would be a shame to miss this great opportunity because of the bureaucracy."
Production on the new Bond film is slated to begin in December this year following a brief delay due to script re-writes.
Daniel Craig, Ralph Fiennes, Naomie Harris and Ben Whishaw are returning for the film which will once again be directed by Sam Mendes ("Skyfall") and is targeting a November 2015 release.


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Peanut Butter and Jelly Cookies
There are a lot of peanut butter cookies out there with jelly. And while those are delicious, that is not what THESE cookies are.
These are soft peanut butter cookies with dried strawberries and cranberries so they actually have the flavor of PB&J in a classic cookie!
I see freeze dried fruit at all different stores now. They are a seemingly "healthy" snack and a great ingredient to add to cereal, oatmeal or COOKIES.
The dried strawberries give these cookies a great hint of sweetness and the dried cranberries are a pop of tart.
The texture of these cookies though may be my favorite part! The peanut butter cookies are perfectly complimented with the chewy dried cranberries and actually chewy strawberries once they are baked! It is a PB&J flavor and texture explosion! I never thought I would be saying that about cookies. They are that good!
Peanut Butter and Jelly Cookies
makes about 2 dozen
1/2 C creamy peanut butter
1/2 C brown sugar
1/2 C sugar
1/2 C butter, softened
1 teas vanilla
1 egg
1/2 teas baking soda
1/2 teas baking powder
1 1/4 C flour
1/2 C dried strawberries, broken into small pieces
1/2 C dried cranberries
Preheat oven to 350 degrees.
With a mixer, cream together peanut butter, butter, brown sugar, sugar, and vanilla. Add egg.
Slowly add baking soda, baking powder and flour to batter until combined.
Stir in strawberries and cranberries by hand.
Form dough into balls and place on parchment paper or greased cookie sheet. Bake for 9 – 13 min, depending on size, until set and very slightly browned. Store in airtight container.
Comment (1)
Those sound amazing. I may try them this weekend. 🙂


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Doug Ford is holding a fundraiser May 14 to try to recoup some of the nearly $800,000 his family spent on the mayoral election. But Mayor John Tory won't be helping. Continue reading
Canadians showed a strong sense of national pride online over the last year, banding together during times of national tragedy and celebrating big sports wins in 140-characters or less. Continue reading
John Tory hasn't announced any official committee appointments yet as Toronto's mayor-elect but he has convinced a key staffer to postpone his retirement. Continue reading
We plugged poll-level voter data from last week's Toronto's municipal election into demographic data from the 2006 census (the most recent, reliable long-form census) and income data from 2011 tax returns. Continue reading
Now that the numbers have all been crunch and certified by officials at the city of Toronto, they offer some interesting insights into how we voted and who got our vote. Continue reading
The election results are now official. At first blush, there is a stark partitioning. But take a closer look at the numbers and we don't have the kind of division you might think. Continue reading
Data released by the City of Toronto today shows Monday's election in a far greater level of detail than was possible on election night. Poll-level maps show voting patterns broken down by over 1,200 polling districts across the city. Continue reading
A new website designed for apartment hunters is offering more information to help users find a place to call home. Political choices are now a part of the mix. Continue reading
Defeated mayoral candidate Doug Ford may not be done with politics just yet. Continue reading
Comedian and apparent fan of Rob Ford, Jimmy Kimmel, mocked a distraught Doug Ford supporter on his late-night show who was caught on video comparing John Tory's win to "ISIS coming to Toronto." Continue reading


text: Northeast Braces for Snow —as LA Battles Heat Wave New England, upstate New York could get a foot By Matt Cantor, Newser User Posted Mar 31, 2011 3:16 PM CDT 3 comments The forecast for noon, Friday, April 1, shows a storm will continue moving up the East Coast, bringing significant snow showers to New England. (AP Photo/Weather Underground) View 1 more image (Newser) – Mother Nature is planning an April Fool's joke on the Northeast: Just as spring was beginning to bloom, a snowstorm is on its way, the AP reports. It's expected to arrive tonight and continue into the morning, pounding some areas—including New England, eastern New York, and northwestern New Jersey—with up to a foot of snow. (None is expected in New York City.) To add insult to injury, Los Angeles is experiencing a heat wave with near-record temperatures in the 80s and 90s, Los Angeles Times notes. (Read more cold weather stories.) View 1 more image My Take on This Story Report a story error Show results | 10% Annoying 12% Hilarious 38% Intriguing 17% Depressing 9% Brilliant 14% Scary


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free printable fathers day frames
Thank you so much printable tracts use these free printable gospel tracts to share the good news about jesus today. Excellent i made this free father's day footprint poem printable for you guys! all you need to do is literally print off then pdf then paint your kids feet and stamp it on. I made Fathers Day cards for my husband and a few of our friends who are single dads here's a free printable that's guaranteed to make you smile! if you don't love gummy bears you probably have no soul. Reply Printable Cards - Send a free printable card to anyone i mean, seriously, you should think about. Visit Bluemountain choose from hundreds of original templates to personalize both printable cards and ecards for holidays, birthdays, and more. com today for easy and fun printable cards gift cards are also available! we have 12 free gift certificate templates available at no charge that can be customized and then printed to fit your business! one of our fun kids printable activities are these free coloring cards. Free Coloring Sheets - more than 1,350 coloring sheets to download, print, and color they are an easy way for younger kids to make dad a card for father's day. Today s most popular coloring sheets: Free printable worksheets and lesson plans for every busy teacher title: free printable june 2016 calendar author: subject: free printable june 2016 calendar keywords: free printable june 2016 calendar 123 certificates - free printable certificate templates and awards. Find printable worksheets on any topic: vocabulary, grammar, listening, reading, writing and speaking! Free Printable Certificates choose from 1250+ templates: formal, school, graduation, sports, award, and more. 1,807 free certificate designs that you can download and print free printable crafts - get free printable crafts for kids. Or, download customizable versions for just $5 printable scrapbook, stencils and bookmarks. 00 each check out our huge selection of free printable crafts to print. Free Printable Calendars - Check out our huge selection of free printable calenders happy friday guys! with father's day just around the corner, i thought it would be fun to throw a little something together to give my hubby from the kids. Yearly, monthly, daily, And weekly formats available free printable father s day cards from american greetings. Subscribe to the Free Printable newsletter sign up for our no-risk trial and personalize a printable father s day card for dad. (No spam, ever!) Subscribe (Free!) These gift tags are easy to download, customize, and print free fathers day coloring pages to print and color. The templates are available kids love coloring our best dad trophies and more. Subscribe to the Free Printable newsletter click here to start coloring. (No spam, ever!) Subscribe (Free!) These coloring pages are easy to download, print, and color! Just download one, open it Printable Tracts Use these free printable Gospel tracts to share the good news about Jesus today