text:
California's aiding and abetting laws, set forth in Penal Code 31 PC, assign criminal liability to anyone who encourages, facilitates or aids in the commission of a crime.1Aiding and abetting defendants face the same penalties as people who directly commit the crime.
Penal Code 31 PC (California's aiding and abetting law) reads:
"All persons concerned in the commission of a crime, whether it be felony or misdemeanor, and whether they directly commit the act constituting the offense, or aid and abet in its commission, . . . are principals in any crime so committed."
"Aiding and abetting" (also sometimes called "accomplice liability") is not a separate crime.
Rather, it's a legal principle set forth in California's Penal Code that allows the state to prosecute everyone who is "in on" a crime--even if they don't perpetrate the crime directly.
Example: Alan, Bill and Charlie plan out a bank robbery. Each plays a different role. Alan draws up a diagram of the teller windows and the safes. He gives it to Bill (after which Alan's role is done). Charlie drives Bill to the bank and waits out front in the getaway car. Bill actually goes in and robs the bank. Bill comes running out with the loot, jumps in the car, and Charlie drives the two of them off.
Technically speaking, only Bill did the actual "robbing." But prosecutors could charge all three with bank robbery: Bill as the direct perpetrator, Alan and Charlie as aiders and abettors. In Alan's case, he's liable for the robbery even though he wasn't even present at the crime scene.
You can be convicted of a crime under aiding and abetting theory, PC 31, even if you played a fairly insignificant role int he crime. But there must be some type of involvement before you can be convicted. Mere knowledge about the crime or presence at the scene will not suffice.2
And unlike a conspiracy, there needn't be a prior agreement to commit the offense...you face liability simply for your voluntary involvement.
Typical legal defenses put forward by a California defendant charged as an aider and abettor under Penal Code 31 PC include asserting that he:
- did not encourage, aid or facilitate the crime's commission
- was falsely accused
- withdrew from participation in the criminal activity
- was merely present at the scene, or perhaps even had knowledge about the crime, but had no duty to try to prevent its commission
- only facilitated the crime after its commission (and should face, if anything, the lesser penalties as an "accessory after the fact").
Penalties for PC 31 Aiding and Abetting
An aider and abettor generally faces the same criminal charges under California's Penal Code as the direct perpetrator. If convicted, he typically also faces the same penalties. In a murder case, for example, an aider and abettor typically faces life in prison just as does the one who commits the actual killing.
Below, our California criminal defense attorneys3 explain California's aiding and abetting laws...and the applicable defenses to these laws...by addressing the following:
- 1. How Does the Prosecutor Prove That I Am Guilty of Aiding and Abetting?
- 1.1. When can the prosecutor charge someone as
an accomplice?
- 1.2. Presence at the crime scene is not
necessarily required for aiding and abetting liability
- 1.3. Knowledge alone isn't sufficient to be guilty of aiding and abetting
- 2. How Can I Fight PC 31 Aiding and Abetting Charges?
- 2.1. You did not encourage, aid, facilitate, etc. the crime's commission
- 2.2. False accusations
- 2.3. You withdrew from participation in the
criminal activity
- 2.4. You had no duty to act
- 2.5. You only facilitated the crime after its commission
- 3. What are the Penalties for California Aiding and Abetting?
If, after reading this article, you would like more information, we invite you to contact us at Shouse Law Group.
1. How Does the Prosecutor Prove That I Am Guilty of Aiding and Abetting?
The phrase "aiding and abetting" means helping another person commit a crime. Prosecutors can charge you as an aider and abettor when you
- know the perpetrator's illegal plan,
- intentionally encourage and/or facilitate that plan, and
- aid, promote, or instigate the crime.4
Despite the fact that it sounds as if you must encourage or promote the criminal activity in advance, that isn't necessarily the case. Aiding and abetting may be committed as instantaneously as the crime itself. If you become aware that a crime is being committed...and at that point, encourage, facilitate or promote its occurrence...the judge or jury can still find you guilty under an accomplice liability theory.5
As far as "encouraging, facilitating or promoting" the offense, there is no requirement that your conduct be a substantial factor in the offense. "Liability attaches to anyone 'concerned,' however slight."6
Common examples include:
- serving as a lookout,
- keeping an engine running in a car, or
- driving the "get-away" car.7
You can also be convicted of Penal Code 31 PC aiding and abetting even if you are legally incapable of committing the actual offense yourself.
Aiding and abetting rapeA deputy sheriff ordered a jail inmate to perform oral sex upon another inmate. He was convicted of violating a California law that specifically prohibits inmates from engaging in oral copulation. In other words, the law makes it a crime for one inmate to engage in oral copulation with another inmate.
The deputy argued that because he was not an inmate, he couldn't be convicted of this particular crime. The court disagreed, stating that "Under an aiding and abetting theory, a defendant can properly be convicted of a crime even though by statutory definition the defendant would be incapable of committing the substantive offense by himself".8
Aiding and abetting rapeSimilarly, a woman cannot physically rape another woman, as rape necessarily involves intercourse. However, if a woman encourages a man to rape another woman, serves as a lookout for that man, and/or arranges the meeting of the man and woman in a secluded location so that he can rape her, she could be prosecuted for rape under the accomplice liability theory.
While aiding and abetting may sound like the California crime of conspiracy ...and although the two are closely related..."aiding and abetting"under PC 31 and conspiracy are actually two different offenses. The major difference between the two is that for there to be a conspiracy there must be an agreement to participate in criminal activity.9 Whereas aiding and abetting does not necessarily require an agreement.
1.1. When can the prosecutor charge someone as an accomplice?
With respect to the criminal allegation, the prosecutor doesn't "charge you" with aiding and abetting. Rather, under the California Penal Code he or she charges you with the underlying crime and presents the case on the theory that you acted as an aider and abettor.10
In determining whether you acted as an accomplice, among the factors to be considered are:
- "presence at the scene of the crime,
- companionship, and
- conduct before or after the offense".11
Note that these are just some of the factors that help determine whether you should be charged as an accomplice. But they are not conclusive. Which leads to the next section...
1.2. Presence at the crime scene is not necessarily required for aiding and abetting liability
There is no requirement that you be present at the crime scene in order to be convicted under an accomplice liability/aiding and abetting theory.12 Neither must you physically or logistically assist in the commission of the crime. Instigating, encouraging or promoting the crime is sufficient.13 The test under PC 31 is whether you "in any way, directly or indirectly, aided the perpetrator by acts or encouraged him by words or gestures."14
Example: Defendant was convicted of insurance fraud for filing a false personal injury claim. The co-defendant, the defendant's girlfriend, was the one who actually forged the necessary signatures and filed the claims. The defendant knew the fraudulent claims had been filed and blatantly lied to the insurance investigator, saying he had received medical treatment (which he hadn't) and that he had to take time off work (which he didn't). The defendant argued that because he didn't actually assist in filing the fraudulent paperwork, there was no accomplice liability.
The court disagreed. It held that because defendant knew about the claims that were fraudulently filed on his behalf...and therefore had knowledge about the perpetrator's plan and encouraged its commission by lying, thus intending to defraud the insurance company...he was properly convicted on an aiding and abetting theory. This was the case despite the fact that he did not physically participate in the crime.15
1.3. Knowledge alone isn't sufficient to be guilty of aiding and abetting
Simply knowing that the crime is about to be (or is being) committed and failing to report it or prevent it generally isn't enough in and of itself to sustain a conviction for aiding and abetting.16 However, if you have a legal duty to take every step reasonably possible to prevent the crime...and fail to do so...you could be convicted as an aider and abettor.
This "legal duty" is only imposed on certain people under specific conditions. For examples, teachers, doctors and certain other professionals have a legal duty to report abuse or other suspected criminal activity. And, in California, parents have a legal duty to "exercise reasonable care, supervision, protection, and control over their minor children".17
So if you have a legal duty to try to prevent a crime...but do not reasonably attempt to do so...you could face accomplice liability under Penal Code 31 PC.
Example: Defendant was convicted of committing lewd acts on a minor as an aider and abettor. The prosecutor presented evidence that the defendant stood by and watched her boyfriend molest her 4-year-old daughter on more than one occasion.
The defendant argued that because she didn't encourage or participate in the lewd acts on the minor, she shouldn't be liable as an accomplice. However, the court ruled that the defendant/mother's presence, in itself, assisted the boyfriend, since her presence not only encouraged the boyfriend to continue molesting her daughter but also encouraged her daughter to comply rather than resist.
Moreover, the court held that because the defendant had a legal duty to act (to protect her child)...yet failed to do so...she was properly convicted under an aiding and abetting theory.18
2. How Can I Fight PC 31 Aiding and Abetting Charges?
Fortunately, there are a variety of legal defenses that apply to accomplice liability that a skilled California criminal defense attorney could present on your behalf. The following are some of the most common:
2.1. You did not encourage, aid, facilitate, etc. the crime's commission
If you didn't encourage, facilitate or otherwise aid in the commission of the crime in any way, you are not guilty of aiding and abetting.
Suppose, for example, you're a passenger in a car with some friends when the driver decides to go rob a liquor store. You remain in the car while he and another passenger barge into a 7-11, wave a gun, and take money from the cash register. But you weren't aware of their plan when you first got in the car...and you did nothing to help facilitate it. In this scenario, you were "merely present" and shouldn't be held liable for the robbery.
There are an infinite number of ways that the allegation that you aided, facilitated or encouraged a crime could have been misunderstood. The bottom line is that if you didn't intentionally engage in one of these acts, you should be acquitted from any accomplice liability under Penal Code 31 PC.
2.2. False accusations
Because there need not be any physical proof that you aided and abetted another person in the commission of a crime, it is easy for someone falsely to accuse you of doing so. This would most likely be the case if, for example, someone was trying to divert his/her own criminal culpability by fingering you as the mastermind of the operation.
Anger, revenge or jealousy could also prompt someone to accuse you of being involved in a crime in which you played no part.
But as Riverside criminal defense attorney Michael Scafiddi19 explains, "Our law firm...comprised of former police investigators and district attorneys...knows the most effective ways to investigate cases and scrutinize witnesses to fight your false aiding and abetting charges and ensure that the truth comes to light."
2.3. You withdrew from participation in the criminal activity
If...before the commission of the charged crime(s)...you withdrew from participation by
- notifying the other people involved in the crime of your intention to withdraw from participation, and
- doing everything in your power to prevent the crime from going forward,
you can fight your aiding and abetting charges on this basis.20
Example: You and another person plan to rob a store. You are responsible for being the lookout outside. But as you get to the location, you decide you no longer want to participate. So you tell your crime partner that you are backing out. You also try to persuade him not to go through with it. He nevertheless decides to go ahead with the robbery on his own. In the meantime, you call the police and place an anonymous tip that the store is about to be robbed. Unfortunately, they arrive too late to prevent it.
Given these facts, a jury could reasonably find that you (1) effectively communicated your intent to withdraw from the robbery, and (2) tried to prevent its commission. You would probably be acquitted of the robbery charges.
But let's change the facts. Let's say that you still communicate your intent to withdraw and try to persuade the perpetrator to do the same. But instead of calling the police, you simply leave and go home. Under these circumstances, you really didn't do everything you could to prevent it. Therefore you probably would not prevail using a "withdrawal" defense.
2.4. You had no duty to act
It bears repeating that even if you know that a crime is going to be committed...but do nothing to prevent its occurrence...you are not guilty of being an aider and abettor under Penal Code 31 unless you have a legal duty to act.
And because legal duties are so few and far between...since they must be specifically conferred upon you by a law...they will not come into play very often.
As a result, mere knowledge of the underlying crime will not typically be enough to convict you as an aider and abettor.21
2.5. You only facilitated the crime after its commission
If you do help facilitate the crime...but only after it is over...you are not an aider and abettor. You may, however, be an accessory after the fact. (In contrast, aiding and abetting is sometimes called being an accessory before the fact.) Accessories after the fact are not treated in the same manner as accomplices under PC 31, but are instead treated as "obstructers of justice".22
Consequently, if you are convicted of being an accessory after the fact, you will most likely face a much lesser penalty than you would as an accomplice to the crime. An aider and abettor to carjacking, for example, faces up to 9 years in prison (just as does the actual perpetrator). Whereas the maximum penalty for being an accomplice after the fact is three years in the California state prison.23
3. What are the Penalties for California Aiding and Abetting?
Each individual convicted of aiding and abetting under the California Penal Code will be regarded as a "principal" to the crime and is subject to the same penalties and consesquences as if he/she personally committed the offense.24
The only exception to this rule applies to murder prosecutions, discussed in the next section.25
3.1. Accomplice liability for murder
As the Supreme Court of California recognized, in some situations, an aider and abettor may be guilty of a greater homicide-related offense than the actual perpetrator, since defenses or extenuating circumstances may exist that are personal to the actual perpetrator and do not apply to the aider and abettor.26
Example: Two defendants fire shots in a drive-by shooting. Only one defendant fires the shot that actually kills the victim. He is labeled the perpetrator, and the other defendant ...who was riding in the passenger seat...is labeled the "aider and abettor".
If, for example, the perpetrator proves that he only fired that shot in
self-defense, his charge would be reduced to
voluntary manslaughter or possibly even dismissed. However, the second defendant (the aider and abettor)...who still shot at and intended to kill the victim in the drive-by shooting...could still be convicted of murder.27
3.2. Natural and probable consequences
Aiders and abettors under PC 31 are not only equally responsible for the perpetrator's intended criminal activity. They are also equally responsible for any crimes that are the natural and probable consequences of that original crime.28
"Natural and probable consequences" are foreseeable consequences given all the surrounding circumstances.29 Whether a further crime is a "natural and probable consequence" of the original planned crime is a question that the jury must answer.30
Example: The defendant was in charge of driving the "get-away" car after the perpetrator robbed a jewelry store. The perpetrator entered the store wearing a ski parka with a hood and sunglasses and carrying a brown paper bag that held a pillow.
While in the store, the perpetrator shot an employee in the face, and then shot and killed the store owner. The defendant argued that he should not suffer accomplice liability for murder and attempted murder because he did not share in the perpetrator's intent to kill either victim.
The court disagreed. It reasoned that "to 'share' the perpetrator's intent does not mean that the aider and abettor is prepared to commit the offense by his own act. All that is needed is a knowing intent to assist the perpetrator's commission of the crime. Once that intent is formed, the liability of an aider and abettor 'extends also to the natural and reasonable consequences of the acts he knowingly and intentionally aids and encourages'".
When the perpetrator entered the store with a gun and a pillow to muffle the sound of possible gunfire, the shootings were indeed a natural and probable consequence of the robbery itself.31
Call us for help...
If you or loved one is charged with Penal Code 31 PC aiding and abetting and you are looking to hire an attorney for representation, we invite you to contact us at Shouse Law Group. We can provide a free consultation in office or by phone. We have local offices in Los Angeles, the San Fernando Valley, Pasadena, Long Beach, Orange County, Ventura, San Bernardino, Rancho Cucamonga, Riverside, San Diego, Sacramento, Oakland, San Francisco, San Jose and throughout California.
To learn more about Nevada aiding & abetting law, go to our article on Nevada aiding & abetting law.
Legal References:
- California Penal Code 31 - Principals, defined [California Penal Code section on aiding and abetting]. ("All persons concerned in the commission of a crime, whether it be felony or misdemeanor, and whether they directly commit the act constituting the offense, or aid and abet in its commission, or, not being present, have advised and encouraged its commission, and all persons counseling, advising, or encouraging children under the age of fourteen years, or persons who are mentally incapacitated, to commit any crime, or who, by fraud, contrivance, or force, occasion the drunkenness of another for the purpose of causing him to commit any crime, or who, by threats, menaces, command, or coercion, compel another to commit any crime, are principals in any crime so committed.")
California Jury Instructions - Criminal "CALJIC" 3.01 -- Aiding and Abetting. ("A person aids and abets the [commission] [or] [attempted commission] of a crime when he or she: (1) With knowledge of the unlawful purpose of the perpetrator, and (2) With the intent or purpose of committing or encouraging or facilitating the commission of the crime, and (3) By act or advice, [or, by failing to act in a situation where a person has a legal duty to act,] aids, promotes, encourages or instigates the commission of the crime. [A person who aids and abets the [commission] [or] [attempted commission] of a crime need not be present at the scene of the crime.] [Mere presence at the scene of a crime which does not itself assist the commission of the crime does not amount to aiding and abetting.] [Mere knowledge that a crime is being committed and [in the absence of a legal duty to take every step reasonably possible to prevent the crime,] the failure to prevent it does not amount to aiding and abetting.]")
- See same.
- Our California criminal defense attorneys have local Los Angeles law offices in Beverly Hills, Burbank, Glendale, Lancaster, Long Beach, Los Angeles, Pasadena, Pomona, Torrance, Van Nuys, West Covina, and Whittier. We have additional law offices conveniently located throughout the state in Orange County, San Diego, Riverside, San Bernardino, Ventura, San Jose, Oakland, the San Francisco Bay area, and several nearby cities.
- See CALJIC 3.01, Aiding and Abetting, endnote 1, above.
- People v. Swanson-Birabent (2003) 114 Cal.App.4th 733, 751-752. ("Contrary to defendant's assertion, advance knowledge is not a prerequisite for liability as an aider and abettor. "Aiding and abetting may be committed 'on the spur of the moment,' that is, as instantaneously as the criminal act itself. [Citation.]" ( People v. Nguyen (1993) 21 Cal.App.4th 518, 532, 26 Cal.Rptr.2d 323.) In People v. Cooper (1991) 53 Cal.3d 1158, 282 Cal.Rptr. 450, 811 P.2d 742 ( Cooper ), the court held that "a getaway driver who has no prior knowledge of a robbery, but who forms the intent to aid in carrying away the loot during such asportation, may properly be found liable as an aider and abettor of the robbery." ( Id. at p. 1161, 282 Cal.Rptr. 450, 811 P.2d 742.) The court reasoned that "the commission of robbery continues so long as the loot is being carried away to a place of temporary safety." ( Id. at p. 1170, 282 Cal.Rptr. 450, 811 P.2d 742; see also People v. Montoya (1994) 7 Cal.4th 1027, 1039, 31 Cal.Rptr.2d 128, 874 P.2d 903 [upholding burglary conviction for aider and abettor who did not have knowledge of criminal purpose until after entry].)")
- People v. Durham (1969) 70 Cal.2d 171, 185, fn. 11.
- People v. Masters (1963) 219 Cal.App.2d 672, 680.
- People v. Fraize (1995) 36 C.A.4th 1722.
- California Penal Code 182 PC - Conspiracy [contrast with PC 31 aiding and abetting].
See also California Penal Code 184 PC - Conspiracy; overt act.
- California Penal Code 971 PC -- Abrogation of distinction between accessories and principals, and between principals in first and second degree; effect upon pleadings. ("The distinction between an accessory before the fact [under Penal Code 31 PC; aka aiding and abetting] and a principal, and between principals in the first and second degree is abrogated; and all persons concerned in the commission of a crime, who by the operation of other provisions of this code are principals therein, shall hereafter be prosecuted, tried and punished as principals and no other facts need be alleged in any accusatory pleading against any such person than are required in an accusatory pleading against a principal.")
See also People v. Kennedy (1953) 116 Cal.App.2d 273, 275. ("From a reading of this section [Penal Code 971] it is manifest that the information having charged petitioner as a principal, it was open to the district attorney to prove that the former actually committed the offense or that he aided and abetted in its commission, or advised and encouraged its commission. Petitioner having been charged as a principal in the crime of kidnapping for the purpose of robbery, it was not necessary that he be charged with aiding or abetting in said kidnapping as a prerequisite to the introduction of evidence that he did so, or to warrant a decision by the trial judge, if such aiding and abetting was proved beyond a reasonable doubt, that petitioner was guilty as a principal in the commission of the offense.")
- People v. Singleton (1987) 196 Cal.App.3d 488, 492.
- See CALJIC 3.01 -- Aiding and Abetting, endnote 1, above. ("[A person who aids and abets the [commission] [or] [attempted commission] of a crime need not be present at the scene of the crime.]")
See also People v. Bohmer (1975) 46 Cal.App.3d 185, 199. ("The criminal complicity of the man who lights the fuse does not disappear because he is at a distance when the bomb explodes. Penal Code section 31 in relevant part provides: "All persons concerned in the commission of a crime, whether it be felony or misdemeanor, and whether they directly commit the act constituting the offense, or aid and abet in its commission, or, not being present, have advised and encouraged its commission ... are principals in any crime so committed." It is not necessary that one be physically present when a crime is committed to abet or encourage its commission.")
- People v. Booth (1996) 48 Cal.App.4th 1247, 1256. ("While accomplice liability cannot be predicated on conduct absent the required mental state, one can be guilty as an accomplice (if he shares the goal of the perpetrator) without having actually assisted the commission of the offense, e.g., by "instigating," or "advising" the perpetrator to commit it or by having been "present for the purpose of its commission." (See Campbell, supra, 25 Cal.App.4th at p. 411, and cases cited.)")
- People v. Villa (1957) 156 Cal. App. 2d 128, 133.
- People v. Booth, endnote 13, above.
- See CALJIC 3.01 -- Aiding and Abetting, endnote 1, above. ("[Mere knowledge that a crime is being committed and [in the absence of a legal duty to take every step reasonably possible to prevent the crime,] the failure to prevent it does not amount to aiding and abetting.]")
- Penal Code 272 PC California's contributing to the delinquency of a minor law, section (a)(2).
- People v. Swanson-Birabent, endnote 5, above.
- Riverside criminal defense attorney Michael Scafiddi uses his former experience as an Ontario Police Officer to represent clients throughout the Inland Empire including San Bernardino, Riverside, Rancho Cucamonga, Hemet, Banning, Fontana, Joshua Tree, Barstow, Palm Springs and Victorville.
- CALJIC 3.03 -- Termination of Liability of Aider and Abettor. ("Before the commission of the crime[s] charged in Count[s] , an aider and abettor [under PC 31] may withdraw from participation in [that] [those] crime[s], and thus avoid responsibility for [that] [those] crime[s] by doing two things: First, [he] [she] must notify the other principals known to [him] [her] of [his] [her] intention to withdraw from the commission of [that] [those] crime[s]; second, [he] [she] must do everything in [his] [her] power to prevent its commission. The People have the burden of proving that the defendant was a principal in and had not effectively withdrawn from participation in [that] [those] crime[s]. If you have a reasonable doubt that [he] [she] was a principal in and participated as an aider and abettor in a crime charged, you must find [him] [her] not guilty of that crime[.] [, and any crime committed by a co-principal that was a natural and probable consequence of the same crime.]")
- In re Michael T. (1978) 84 Cal.App.3d 907, 911. ("Mere presence at the scene of a crime which does not itself assist its commission or mere knowledge that a crime is being committed and the failure to prevent it does not amount to aiding and abetting.")
- People v. Montoya (1994) 7 Cal.4th 1027, 1039, footnote 7. ("[I]n accord[ ] with the clear trend, the accessory after the fact is no longer treated as a party to the underlying felony, as at common law. This kind of accessory is coming to be recognized for what he is: an 'obstructer' of justice, the author of a separate and independent offense."")
- California Penal Code 32 - Accessories, punishment. ("Except in cases where a different punishment is prescribed, an accessory is punishable by a fine not exceeding five thousand dollars ($5,000), or by imprisonment in the state prison, or in a county jail not exceeding one year, or by both such fine and imprisonment.")
- California Penal Code 31 - California Penal Code section on aiding and abetting, endnote 1 above.
See also People v. Green (1950) 96 Cal.App.2d 283, 290. (""Where persons are not actors in the actual commission of the crime charged, but aid and abet others in its commission or procure others to commit the crime, all are equally guilty."")
- CALJIC 3.00 Principals-Defined. ("Persons who are involved in [committing] [or] [attempting to commit] a crime are referred to as principals in that crime [as defined in Penal Code 31 PC]. Each principal, regardless of the extent or manner of participation is [equally guilty.] [guilty of a crime.] Principals include: 1 Those who directly and actively [commit] [or] [attempt to commit] the act constituting the crime, or 2 Those who aid and abet the [commission] [or] [attempted commission] of the crime. [When the crime charged is [either] [murder] [or] [attempted murder] [ ], the aider and abettor's guilt is determined by the combined acts of all the participants as well as that persons own mental state. If the aider and abettor's mental state is more culpable than that of the actual perpetrator, that person's guilt may be greater than that of the actual perpetrator. Similarly, the aider and abettor's guilt may be less than the perpetrator's, if the aider and abettor has a less culpable mental state.]")
- People v. Mccoy (2001) 25 Cal.4th 1111, 1122. ("We thus conclude that when a person, with the mental state necessary for an aider and abettor, helps or induces another to kill, that person's guilt is determined by the combined acts of all the participants as well as that person's own mens rea. If that person's mens rea is more culpable than another's, that person's guilt may be greater even if the other might be deemed the actual perpetrator. Because we cannot anticipate all possible nonhomicide crimes or circumstances, we express no view on whether or how these principles apply outside the homicide context. (See Dressler, Understanding Criminal Law, supra, § 30.06[C], pp. 450-451.)")
- Facts taken from same.
- People v. Coffman (2004) 34 Cal.4th 1, 106-107. ("Elaborating on the natural and probable consequences doctrine, in People v. Prettyman (1996) 14 Cal.4th 248, 261, 58 Cal.Rptr.2d 827, 926 P.2d 1013, and People v. Croy (1985) 41 Cal.3d 1, 12, footnote 5, 221 Cal.Rptr. 592, 710 P.2d 392, we observed that an aider and abettor "is guilty not only of the offense he intended to facilitate or encourage, but also of any reasonably foreseeable offense committed by the person he aids and abets." As the Court of Appeal in People v. Brigham (1989) 216 Cal.App.3d 1039, 265 Cal.Rptr. 486 noted, although variations in phrasing are found in decisions addressing the doctrine-"probable and natural," "natural and reasonable," and "reasonably foreseeable"-the ultimate factual question is one of foreseeability. ( Id. at pp. 1050, 1054, 265 Cal.Rptr. 486; see People v. Roberts (1992) 2 Cal.4th 271, 316-322, 6 Cal.Rptr.2d 276, 826 P.2d 274.) "A natural and probable consequence is a foreseeable consequence..."")
See also CALJIC 3.02 Principals-Liability for Natural and Probable Consequences. ("One who aids and abets [another] in the commission of a crime [or crimes] is not only guilty of [that crime] [those crimes], but is also guilty of any other crime committed by a principal which is a natural and probable consequence of the crime[s] originally aided and abetted. In order to find the defendant guilty of the crimes[s] of , [under this theory,] [as charged in Count[s] ,] you must be satisfied beyond a reasonable doubt that: 1 The crime [or crimes] of [was] [were] committed; 2 That the defendant aided and abetted [that] [those] crime[s]; 3 That a co-principal in that crime committed the crime[s] of ; and 4 The crime[s] of [was] [were] a natural and probable consequence of the commission of the crime[s] of. [In determining whether a consequence is "natural and probable," you must apply an objective test, based not on what the defendant actually intended, but on what a person of reasonable and ordinary prudence would have expected likely to occur. The issue is to be decided in light of all of the circumstances surrounding the incident. A "natural" consequence is one which is within the normal range of outcomes that may be reasonably expected to occur if nothing unusual has intervened. "Probable" means likely to happen.] [You are not required to unanimously agree as to which originally contemplated crime the defendant aided and abetted, so long as you are satisfied beyond a reasonable doubt and unanimously agree that the defendant aided and abetted the commission of an identified and defined target crime and that the crime of __________ was a natural and probable consequence of the commission of that target crime.]")
- See both cites, endnote 28, above.
- People v. Godinez (1992) 2 Cal.App.4th 492, 499. ("The parties agree the liability of an aider and abettor [as set forth in California Penal Code 31 PC] is not limited to the target crime which he knowingly and intentionally aids and encourages, but can include crimes committed by the perpetrator which are natural and reasonable consequences of the criminal course of conduct the aider and abettor knowingly aids and encourages. ( People v. Jones (1989) 207 Cal.App.3d 1090, 1095-1096 [ 255 Cal.Rptr. 464].) It is now settled that it is a question of fact whether the charged offense was a natural and reasonable consequence of the target offense knowingly encouraged, and the jury should be instructed of its responsibility to determine this factual issue.")
- People v. Hammond (1986) 181 Cal.App.3d 463.


text:
Weekly Movie-Making Moments in Film: Camille Claudel
A woman's strength and determination is powerful….
A woman's love is without equal…..
A woman's suffering for that love is immeasurable….
Perhaps one of my favorite French films that depicts artistic creativity, strength, determination, love and obsession is none other than the film Camille Claudel finely directed by Bruno Nuyten and starring Isabelle Adjani as Camille—the young but gifted sculptress. In the film Camille possesses an artistic and romantic passion that consumes her. Her love for the sculptor, Auguste Rodin, and her life, ends in pain and lost.
Here is a clip from the film. What do you think? If you have seen the film, what is your opinion of Isabelle Adjani's performance?
This entry was posted on August 28, 2011 by walterwsmith3rd. It was filed under 2011, Art, Film, Uncategorized, Weekly Movie-Making Moments in Film and was tagged with Art, Bruno Nuyten, Camille Claudel, France, French Films, Isabelle Adjani, Love, relationships, Rodin, Video, Weekly Movie-Making Moments in Film.
16 responses
Thanks Frizz, I thought this film would be right down your alley 🙂
August 30, 2011 at 1:59 pm
It's a great movie and very touching in its obsession and sadness… I loved it and would watch it again… now that you reminded us of it. TY! 🙂
August 30, 2011 at 6:55 am
Yes, the movie is one of the best ever made, if you like the theme of obsession and sadness…..but also, let's not forget artistic creativity at its highest level.
August 30, 2011 at 1:58 pm
That was intense. Sure wish I could understand French.
September 5, 2011 at 4:54 pm
It was a great film, you would love it.
September 6, 2011 at 3:18 am
this film speaks volumes. i love it.
December 10, 2011 at 11:31 am
Thanks Yamyah for stopping by and checking out my blog. I appreciate you subscribing as well. The film was great was it not? I loved it as well. I will check out your blog.
December 10, 2011 at 11:56 am
yes it was, it was actually a lifetime changing one for me… and to top it all up G. Depardieu is one of my favourite actors 🙂 I'm a huge fan of European Cinema. I wonder if you have seen/like Ingmar Bergman's film universe?
December 10, 2011 at 11:39 pm
Hi Yamyah, I too am a large fan of European Cinema, mostly notably Asian, French, Dutch, English and German cinema. Off the the top of my head the films Fire, Earth and Water directed by Deepha Meta and all the films of Gong Li and Chinese director Zhang Yimou lead my Asian loves. Berlin Alexanderplatz by Fassbinder is a favorite as well the French films by Juliette Binoche like White, Red, and Blue. Overall I grew up in a creative atomsphere that was very much influenced by these and other provocative and exploratory films. I like Ingmar Bergman as well, however, although I have seen some of her films they escape my memory at the moment. Two questions: Where are you from? Yamyah is a unique name. 2. What led you to your spiritual journey? I plan on reading a lot of your work. It is quite interesting.
December 11, 2011 at 2:49 pm
Sorayah (Yamyah)
nice to hear someone appreciates european/independent cinema as much as i do :}. I am very fond of the trilogy White, Red and Blue myself. Yamyah is from a sunny european country named Portugal :} As for my spiritual journey, i have always been "awake" and very much aware i guess … at the age of 5-6 years old i had my first spiritual awakening. As a young teen while others priorities revolved around going to parties and date people, mine were to "teach" what i "remembered", it was around that time too i started to seriously consider leading a monastic life (Buddhism). One thing that i always craved for was writing. Since i was little i've had this urge to write and share with the world some things that i felt would have a huge impact on masses, so later on in life, i took that path and wrote a lot (short stories mainly) and eventually got published, yet again something was missing, i felt very unfulfilled so to speak…it was then again i reconnected on a deeper level with the core of creation (Love). I hope you will tune into some of the things i write about…it is always with love and with the intention to spread Love and awake people to …Love :).
December 11, 2011 at 7:57 pm
What a beautiful expression of your inner-self. I admire the journey you started years ago and the one which you most passionately continue today. I can embrace your spiritual journey for I can sense its reward in you. Buddhism, I believe enriches, quides and teaches us the way to live compassionately and with personal accountability. That is why I am so drawn to it as a way of life. My art, and the art of others has been a sustainable influence throughout my entire life. It has helped me to see the world from various perspectives, and it governs my daily forms of expression. I love film as you know. And yes, it is a pleasure to connect with you and to hear of your passion for independent and foreign filmmaking. Tell me more. I have neve been to Portugal, but it is my hope that I will one day travel to southern europe.
Peace and Light my friend
December 12, 2011 at 7:59 am
Sorayah (Yamyah)
thank you for your kind words, my friend.
It is always a pleasure to inspire another and be inspired by them mutually, i believe all of us could learn so much with each others…evergrowing teachers and students at once.
I can sense that you are a awakening soul and have been so for a long time. Art is often one of the many "doors" to connect and awaken a person to Oneness. Portugal is a most beautiful country as any other…it has its gems, its enchantment, its aura and a lot of history too. I was over in the beautiful isles of the Azores last October/November, do you know of these portuguese isles that lay in the middle of the ocean, half way between the east coast of the US and Portugal (mainland)? I was absolutely captivated by its beauty…i had never seen such deep blue sea before and big waves. I am yet to write a post on this and include some photos in the very near future. tell me about the place where you are from, and tell me what inspires your art… love and blessing ~
December 16, 2011 at 2:23 am
Hi Sorayah, thanks for writing such a wonderful email. You are correct that art is a way in which we can discover ourselves. I have been trying to find the answers to my life in general and in its complexity for years now. Religion and Spirituality has also, at times, played a large part in self discovery, beliefs and awareness. I feel strongly that personal acccountablity is vital to living a full life, hence my attraction to Buddhism. As in most things, I take what I can from religion and spirituality to uplift my life.
It appears you do live in a beautiful place indeed. I am not familiar with the isles of Azores. Wish I could spend a moment there from your lovely description. I have a series entitled "Impressions of Barbados" here on my blog. Go to the tag "landscapes" and check it out. I tried to capture the island from a impressionistic view. Most of my life I have lived in the city of Philadelphia, here in the United States. Now I live in South Carolina near the mountains of North Carolina. A different life altogether. I hike, mountain bike, road bike, go caving, zip-lining, white water rafting etc. Anything to get me out in nature; to push the body, mind, spirit to new heights.
Take care my friend
Namaste, peace and light
December 18, 2011 at 11:10 am
Sorayah (Yamyah)
dear Walter, you are an awakening soul…art is your guiding star connecting you to truth. I want to say that for a long time i thought of myself as a "seeker" of truth, continuously trying to find it in everything around me but you know it wasnt until 2 years ago that i realised that there is nothing to seek outside me because truth is inside us all the time, all we have to do is remember and tune into it with the heart. Sometimes we have to heal first, to forgive others and self, once that is achieved we realise we are the truth, and that the truth is Love and will reflect on everything outside us as a mirror of our self.
i will check your series of Barbados. Wishing you a wonderful and lucky 2012 !
January 1, 2012 at 2:30 am
My dear friend, who's thoughts are like blooming flowers … I can feel the emotion behind your words. The paths you have travelled have been such a blessing to you. While reading your essay, I came to the conclusion, slightly before you stated it — that truth is found inside of oneself. Not outside. It only felt natural to come to this conclusion. You can feel, and rest assured in its truth i.e. that is has always existed inside of us. As beings of the One Source, we are all part of that One Truth. It is beautiful, and reassuring to go through life knowing this. It delivers us from fear. It can recognize our pain, our doubts and free us. The connection with our Inner-Truth, which is Love is all that we need in this life.
Namaste with Love
January 1, 2012 at 7:55 am

subset: commoncrawl


text:
1. Against ALL conventions of Application Development, neither System nor User Requirements EVER were fixed. In the app development world this means Obamacare NEVER had a set of Requirements that could be architected, designed, coded or tested. AND THE DEVELOPERS KNEW THIS; IT'S WHAT THEY DO. It is not 'the website did not work,' it is 'the website COULD not work.' That is a non-trivial difference that cost the taxpayers – so far – over $600M.
2. ONE of the high-level requirements that never existed was SECURITY of the site, of the User information, of the provider information. Because there were no Security Requirements, the system COULD NOT BE designed to be secure. If you cannot define something – you CANNOT test it, period. Security is not a patch that can be added later, as multiple IT security professionals have testified. Implementing the security required means starting the entire application development project all over again, and ensuring EACH Requirement is viewed from a security perspective such that its security (as well as its functionality) can be defined, architected, coded and tested.
3. The system was designed to PREVENT the User from seeing the price of what they were buying until after they had bought it, and until AFTER Leviathan had all their personal information… that it COULD NOT SECURE… that the developers KNEW could not be secured. America has laws against "Bait and Switch," and the Obamacare website implementation VIOLATES THOSE LAWS.
4. 34 States have refused to let Obama hijack their economies and so have not signed up to create their own exchange.
5. The law allows for subsidies for those enrolling in State exchanges if they meet certain requirements. The law DOES NOT ALLOW subsidies for those enrolling in federal exchanges. Period. Providing subsidies to those NOT QUALIFYING UNDER THE LAW for those subsidies IS ILLEGAL, AND a violation of Constitutional Separation of Powers: The president MAY NOT SPEND MONEY WITHOUT A LAW ALLOWING HIM TO DO SO.
6. NO ONE in those 34 States (over 200M Americans) is eligible UNDER THE LAW for subsidies, which only can accrue to those in State exchanges. Providing subsidies to those not meeting the legal criteria for them is an illegal act in which the President spends money in a way NOT appropriated by Congress. Nixon lost a Separation of Powers lawsuit for EXACTLY THIS – it is UNCONSTITUTIONAL.
7. The law REQUIRES participation of all affected persons and organizations on 1 January 2014. NO LEGAL WAY EXISTS TO DELAY THIS DATE. Delaying it is CHANGING THE LAW ON THE WHIM OF THE PRESIDENT. It is a violation of Separation of Powers and is UNCONSTITUTIONAL.
8. From current reports, more than 100M policies (covering over 100M citizens) will be cancelled in order to achieve the stated goal of Obamacare – ensure that the 30M people without health insurance policies in 2009 are insured. Obamacare un-insures over 30% of Americans responsible enough to buy their own insurance in order to insure less than 10% of Americans who are not. What do those groups have in common? Responsible adults, those accepting their personal responsibility to insure themselves, for the most part vote Republican. Irresponsible adults, those NOT taking responsibility for their own needs, for the most part vote Democrat.
9. Obama and the Democrat Party are redistributing trillions of dollars in wealth, erasing the medical care for over 100M Americans, and grossly violating the Constitution… in order to buy the votes of 30M Americans.
Go read that again.
It is UNCONSTITUTIONAL AND ILLEGAL for Obama to subsidize ANYONE on Federal Exchanges. Unconstitutional because the President "shall take care that the laws be faithfully executed" (Article 2, Section 3), and ILLEGAL as nothing in the law allows him this authority – to change the law – and nothing in the Constitution allows him to spend money not appropriated by Congress.
(And this crap about "Prosecutorial discretion" is just that – crap. NOTHING in the Constitution gives the president the authority to NOT enforce the law just because he decides he doesn't like it today – THAT is called "The Rule of Man," and it is EXACTLY what America was created to prohibit.)
It is UNCONSTITUTIONAL and ILLEGAL for the president to delay the implementation of the law, PERIOD, for EXACTLY THE SAME REASONS.
It is UNCONSTITUTIONAL AND ILLEGAL for the president to waive the law for specific constituencies (unions, etc.) – for both the reasons cited above AND because of the Equal Protection clause of the 14th Amendment.
And – if it is true that the adherents of certain religions are protected from Obamacare BECAUSE OF THEIR RELIGION, that is both a violation of Equal Protection AND a violation of the First Amendment: "Congress shall make no law respecting an establishment of religion." If excusing ONE religious group from a tax is not protecting a State religion, then NOTHING IS.
This has NEVER been about healthcare. It has ALWAYS been about redistribution, control and equality of outcome for those who refuse to pull their own weight in our society. Equality of outcome – logically and historically – can ONLY be attained when EVERYONE is in poverty but the elite.
That the above violations – lawless and grossly unconstitutional – have NOT already caused Congressional leadership to file multiple Separation of Powers lawsuits is APPALLING: CONGRESS IS REFUSING TO DO THEIR JOB TO PROTECT THE CONSTITUTION.
If this does not cause a rebellion, America ALREADY IS OVER.
And if neither Congress nor the military will do their jobs to rein-in an out-of-control Executive acting completely outside the Rule of Law – IN GROSS VIOLATION OF THE LAW AND THE CONSTITUTION – then the People MUST.
If the Rule of Law no longer exists for the rulers, then it no longer exists for the People.
If the Rule of Law – the Supreme Law of the Land (Article 6) – no longer applies, then no American government can claim legitimacy.
It is OUR COUNTRY and OUR CONSTITUTION. It does NOT belong to the president, the Congress or anyone else.
AMERICA is OURS – NOT THEIRS.


text:
Baubles, bangles and beads lay jangled together on
the kitchen table. The boy gazed at the flash of
color and then out into the night sky at
the blue moon. The mother did dishes and
sang in a joyful voice, "Willow, weep
for me." For the boy, she was the most
beautiful girl in the world.
Later, he was a priest in the tavern where
he said, "I won't dance," and they all
laughed and beat him body and soul.
Later, in the still of the night, he
whispered, "Let's fall in love."
She said, "I like the sunrise,"
and looked past the breakwater,
out to the horizon beyond
the sea.
Later, frail and failing, he
watched each morning for
that lucky old sun and
said to Doreen, the
worker, "I'm waiting
until the real thing
comes along." Doreen
wasn't listening,
her mind caught
in a loop of
the question:
"What'll I
Patrick T. Reardon
Photo by Magic4walls


text:
Subscribe to the Recipes for Runners mailing list for weekly emails with recipes, food blogs, coupons, tips and more!
Thank you for subscribing to Recipes for Runners!
Tags: frozen yogurt, peach, Protein
You must be logged in to post a comment.
© 2020 Recipes for Runners | Powered by WordPress


text:
My fall semester of 2008 I had picked off were I left off and happy to be back at the Purdue LDS singles ward, the Queer Student Union, and once again attending weekly GRAD sessions. In addition to this Kay had gotten a fellowship from Purdue to start the first student chapter of NOGLSTP (National Organization for Gay and Lesbian Scientist and Technical Professionals). The only thing I was in that huge acronym was gay, but really you didn't have to be any to become a member. So I had gotten involved in that as well. I was elected as treasurer for the QSU, and I received a calling to be a greater at my ward. NOGLSTP did an event for Transgender day of Remembrance.
This event gave a voice to all the victims that lost their lives for trying to be who they were. This was an election year and we had used political lawn signs that one organization didn't need anymore and we turned them inside out and used them as a sort of tombstone each containing the names of each victim and how they died. They were placed out in the Memorial Mall of Purdue University and on the evening of that day I helped carry a mock casket on to the sight were there was a moment of silence and then speakers gave talks, among the talks were Chris and Kay. This event was a reminder to me of how fortunate I have been to where I am and how important it was for me to be authentic to give the voice of authenticity to those that had lost theirs in this world.
As I was being authentic in my ward about not just being gay but turning into a bit of an activist, I was doing the same outside of the church about being Mormon. In my experiences I learned that it was more difficult for me to be an out Mormon outside the church than it was being out gay inside. I had become a bit of a go to person in the queer community at Purdue for things of religious significance. There was one event when our public relations officer of the QSU was invited to this one event by a Christian organization where a person was going to talk about being gay. So she went and felt completely offended that she had been invited to hear a gay-to-straight Christian give a talk on how you can change to righteousness through Christ. She had to leave before she blew up.
I had met a gay to straight person before and we actually had a great conversation. We both could tell that we were committed to our path and both had an appreciation for being able to freely express our feelings. She had actually still had been in the closet about her past as she was now a leader of a congregation on campus, so it was quite amazing that she opened up to me and she told me that she felt god wanted her to. So my problem wasn't because of the person being a gay to straight it was because I was given the impression that he was telling people it was the only right way. There is no way of knowing for me whether another person as truly changed their orientation or was bi and leaned the other way or whatever as long as they believe they are being authentic to themselves I'd gladly support them.
So it wasn't long later were I heard about it. She told me the person that invited her asked her how she liked the talk and she was straight forward and honest about how offensive it was towards her and eventually she invited him to have dinner with her, the president of the Episcopal Student association and the treasurer of the QSU (me). We had dinner at Applebeee's and the conversation went as well as could be expected. The leader of the ESA made good comments. He is actually an ally of the GLBTQ community and has a son so he had talked about the necessity for a caring and loving environment for his son to grow up in regardless of who he is. I believe this put it in more of a personal sphere now that they had to consider the chance that they could have a gay child. I have often used what he said to put the necessity in creating a loving community with less queer friendly groups. The other interesting thing that happened was as soon as I got to the so I became Mormon part of my authenticity choice speal it was like he forgot the main reason why we were all there and seemed more concerned by the fact that I was Mormon than that I was gay.
These conversations are always fun because I am completely out of their comprehension as these individuals who have a problem with who I am most likely never questioned their religion and have lived in their blissful little world of ignorance. I enjoy talking with them in a way even if they don't listen because I get to defend my orientation and my religion who many have told me don't mix well but have made the perfect team in confusing the heck out of someone to the point where they really don't know what to do with me. All the while I show an authentic caring for the individual because really I wasn't any different than them just a couple years back and If I hadn't been gay I still could've been so I do relate to them and it has often helped me navigate through many sticky conversations.
At the end of the dinner we invited them both to meet more GLBTQ members at the coffee night we were hosting that night he said he would come, but he never did. At that time though I said I would go to one of his services, which I did a few weeks later and had a nice time until one of the members thought it was his mission to convince me I was wrong, pftt good luck with that. I gave the other guy another chance to take a step towards reaching out to the GLBTQ community of which he later failed and that was that.
At Purdue there are two religious organizations that actively got involved with the QSU in helping the queer community in their efforts to obtain a safe environment to be themselves and learn. I got a bit involved with these two organizations which were the Episcopal church, and the Wesley foundation of the Methodist church. The Wesley foundation hosted a bible study on GLBTQ themes. I participated in these studies and would bring my complete set of the LDS Gospel and we had a great time studying together and sharing perspectives. This was a very empowering event I was allowed to be me and I was allowed to share some Mormon perspectives then I listened to their perspectives and we all gained something from it.


text:
Sponsor Giveaways | Masterful Scrapbook Design, Rebecca Cooper & Ella Publishing, Kerri Bradford
GIVEAWAY | One person will receive all 12 archive issues of Masterful Scrapbook Design. $188 value.
Subscribe during August to get the entire bundle, your first month subscription, and the e-class "Learn Scrapbook Design Principles" for $112. Monthly subscription is $12.50 and can be canceled at any time.
Each of the 12 archive issues includes: seminar on focus topic in pdf and audio formats, designer galleries with 60+ annotated layouts (pdf), 4+ guest teacher tutorials (pdf), video and audio recordings of webinars with each guest designer. The entire collection includes 47 video/audio recordings to take with you as you drive, work, scrapbook, wait, or even relax. Compatible with ipad/iphone.
TOPICS COVERED | Color, Layering, Details, Events, Journaling, Titles, Inspiration, Patterned Paper, Stash Busting, Photos, Fast Starts, and Smorgasbord (interviews with 24 designers on 8 current scrapbooking topics).
Over 30 guest teachers contributed layouts, comments, lessons, and webinar interviews. Paper scrapbookers: Doris Sander, Dina Wakley, Jenni Bowlin, Lisa Dickinson, Karen Grunberg, Tania Willis, Cindy Liebel, Lain Ehmann, Sharyn Tormanen, Emily Pitts, Noell Hyman, Keandra Willis, Vee Jennings, Francine Clouden, May Flaum, Michelle Clement, and Vivian Masket. Digital scrapbookers: Anna Aspnes, Aaron Morris, Amy Mallory, Amber Ries, Melanie Grimes, Lynnette Penacho, Jana Morton, Erin Clayton, Kayleigh Wiles, and Katrina Kennedy. Scrapbookers who make paper, digital, and hybrid pages: Paula Gilarde, Celeste Smith, Betsy Sammarco and Wilna Furstenberg.
UPCOMING TOPICS & TEACHERS | September's issue is "Design Play" with Emily Pitts, Vivian Masket, Amy Mallory, Kayleigh Wiles, and Lisa Dickinson. The October issue shows you how include "current times" into your pages with Kelly Purkey, Doris Sander, Keandra Willis, Paula Gilarde, and Lynnette Penacho. In November we focus on texture and dimension and December's issue is all about focal points.
GIVEAWAY | Two people will receive a copy of Don't Say Cheese! by Rebecca Cooper for Ella Publishing.
SPECIAL OFFER | Receive 10% off Don't Say Cheese! through September 1 using coupon code: GORGONZOLA
Rebecca Cooper is back with a new photography guide that's all about taking photos of kids. This 52-page downloadable eBook is packed with 247 tips, tricks, and ideas to help you capture your children's real smiles and authentic expressions—images that show who they really are (and go far beyond asking a child to just "say cheese").
Drawing on Rebecca's years of professional experience with children's' photography, this eBook is divided into sections specifically for children, toddlers, babies, and newborns. With all this, plus the bonus Photo Games and Checklists section, you'll be capturing real smiles in no time at all—and having a great time with your kids along the way. Save the cheese for your pizza and try Rebecca's tips for photographing children instead!
ABOUT THE AUTHOR | Rebecca Cooper is a family and children's photographer and a mother of four who lives on the Carribean island of St. Eustatius, although she's originally from Canada. She is the author of another best-selling eBook, 40 Top Tips for Better Photos as well as a hardcover book, Real.Simple.Scrapbooking. Connect with Rebecca : Blog | Twitter | Facebook
You can check out Rebecca's latest eZine article for Ella Publishing here, where she shares a few photo game ideas for making photos fun for kids.
GIVEAWAY | One person will receive a year's worth of the This & That kits—12 kits in total - from Kerri Bradford Studio. A $180 value!
FOR AN ADDITIONAL CHANCE TO WIN | Like Kerri's Facebook page for a second chance to win.
Kerri Bradford's 'This & That' kits are a unique concept that combines both digital images and shapes for digital craft cutters (Cricut/Silhouette/etc.) to make a dimensional home decor item for all year long. Everything is sized and trimmed as needed for the 7 gypsies tray so there is no thought involved! Adhere each piece to the tray with magnets to keep them secure for the month, then simply swap them out for the next month. The kits include these file formats: SVG, STUDIO (Silhouette), DXF, Illustrator version 8, and PNG. Please Note: There is one little hiccup with using it with your Cricut though. You must have earlier versions of SCAL (Sure Cuts A Lot) or MTC (Make The Cut) in order to use it (like before April-ish of this year). SCAL and MTC can no longer work with Cricut machines.
If you don't have a digital craft cutter? No problem. You can create it all digitally (adding shadows, etc.). You can also cut some of the simpler components by hand to get the multidimensional look if you wanted to. There are several people who do it this way and love the results!
These kits are not just for the tray either. Use the components to create other amazing craft projects for scrapbooking and card making.
Use it as a gift! These are a great Christmas or birthday gift idea! Buy one kit and however many trays you need and create away! You can purchase the 7gypsies tray directly from their website or from online digital stores such as Two Peas In a Bucket or places such as Archivers.
Kerri's 'This & That' kits are on sale for 30% through Sunday, so don't miss out!
Kerri offers shapes, images and digital content for your paper crafting needs. You can check out all her kits here.
ABOUT KERRI | Kerri's 'official' scrapbooking journey began 12 years ago, particularly after winning very first Creating Keepsakes' Hall of Fame contest. Since then she worked her little fingers to the bone creating pages for the magazine and then eventually for QVC, working with Lisa Bearnson and Kristy Banks. After six years of 'being paid to scrapbook' (really?), Kerri moved to the 'behind the scenes' of the industry, creating art for CK's Kit of the Month program. She also managed to mix in a couple of Cricut cartridges and teach from time to time. After CK, she created art for Silhouette.
This past year she started her own business creating art primarily for digital craft cutters—with a little bit of other 'fun' mixed in here and there. She also created the Turquoise edition for Becky Higgins' Project Life.
She loves being with her family most, with traveling and photography coming in at a close second and third. She also loves doing what she's doing right now because she gets to create fabulous stuff and connect with people all over the world!
TO BE ENTERED into this giveaway please leave a comment below (if you are reading this post on Facebook please come to my blog to leave a comment). Comments will be closed at 8pm Pacific on Sunday and the winner posted shortly after. Please be sure to check back or subscribe (click here to get posts delivered to your email box) to see if you are receiving one of the items this week.
584 thoughts
What incredible giveaways, Ali! Thanks.
Wow, what a great giveaway again. Thanks for the chance.
Hugs, Uta
Great giveaways this weekend! (but then again, that's no big surprise ;-)) They all look awesome, but if I could pick, I would go with Kerri Bradford's kits. I LOVE her designs!
Awesome giveaways:) Thanks for the chance Ali!!!
Wow, what great giveaways this week! I'm crossing my fingers for the photography e-book!!!
You have the coolest stuff to give away. Thanks for the chance to win!
Another set of awesome giveaways. Scrapbook heaven
Wow...what a wonderful give-away and love learning of new places to shop. Thanks!
These giveaways are out of this world, thank you for the chance to win.
Cool giveaway....especially the stash busting part!!
Terrific giveaways. Thank you
great stuff, again ! Thanks for the chance to win !
Great giveaway lineup! Thanks for the chance!
You have the greatest sponsors! Thanks for all your inspiration.
Awesome giveaways! Thanks so much for the chance! I recently bought a silhouette, and have been eyeing Kerri's designs!
I never participated in one of your giveaways before, today I was willing to giving a try. Fantastic prizes! thanks for the opportunity!
Great giveaway! Thanks Ali!
Great giveaway Ali!
Great giveaway! Thanks for the opportunity!
Awesome giveaways. Thanks so much for the opportunity.
Very cool!! I've never heard of masterful scrapbook design before. I've learned about so many of the best sites/resources right here from you. Thanks Ali!!!
I always learn about the greatest companies and product from the weekend give-a-ways.
Wow....what a great giveaway. Thanks for the opportunity to win!
FAb giveaways.!
Great giveaway. Thanks for all the great info you share.


text:
Veronica R. Chiesi Brown
Office: 585-922-4573
Cell: 585-305-4204
[email protected]
Rochester Regional Health's Sands Constellation Heart Institute is among the first in western New York State to offer patients with non-valvular atrial fibrillation (AF), an alternative to long-term medication with the WATCHMAN Left Atrial Appendage Closure (LAAC) Implant.
Implantation of the WATCHMAN device, a catheter-delivered heart implant performed without surgery, permanently closes a small pouch in the heart called the left atrial appendage. This pouch is responsible for the majority of strokes in patients with atrial fibrillation (Afib).
Patients who suffer from atrial fibrillation, an irregular and often rapid heart rate, are at a significantly higher risk of stroke due to blood clots forming in the left atrial appendage. According to the American Heart Association, an estimated 3 to 6 million Americans are living with AFib; approximately one-third will suffer a stroke. People with Afib are often treated with blood thinners to reduce the risk of stroke but blood thinners also increase the risk of serious or life-threatening bleeding. WATCHMAN was approved by the FDA in March 2015 and is a permanent alternative for patients whom blood thinners are not a viable long-term option.
"We are proud to offer this minimally invasive and permanent solution for our patients with atrial fibrillation," said Rochester Regional Health cardiologist Jeremiah Depta, MD, MPHS, FACC. "We already have multiple patients scheduled for the procedure, and are very excited about its potential use in patients that cannot be maintained on blood thinners."
Patients will typically return home the day after the one-hour procedure, and more than 90% will be able to stop using blood thinners within two months.
Rochester Regional Health is an integrated health services organization serving the people of Western New York, the Finger Lakes and beyond. The system provides care at 150 locations, including five hospitals; more than 100 primary and specialty practices, rehabilitation centers and ambulatory campuses; innovative senior services, facilities and independent housing; a wide range of behavioral health services; and ACM Medical Laboratory, a global leader in patient and clinical trials. Learn more at rochesterregionalhealth.org.
Monday, January 20, 2020
Flu season is officially underway with all regions of the country now seeing flu activity. Learn why health officials say 2020 is different than year's past.Read News Article
Monday, January 13, 2020
Studying abroad means a significant amount of time away from your health care provider. Here are some health tips to remember before you leave home.Read News Article


text:
Air compressor to achieve isothermal compression, effic […]
Air compressor to achieve isothermal compression, efficiency optimization, to ensure export pressure and temperature indicators, each section should be equipped with intermediate cooler. Because of the strict requirements of the pressure loss and the inlet temperature of each section, the particularity of the design and selection of the intercooler is decided. The intermediate cooler covers almost all the shell and tube heat exchangers, which embodies the design concept of the various heat exchangers. At the same time, it is also an inevitable choice for dealing with many types of machines and large span working conditions.
The compressor intercooler has the image of the compressor's lungs, and its cooling effect and reliability directly affect the aerodynamic performance and overall efficiency of the compressor. With the increase of intercooler for air compressor, a series of coolers suitable for different working conditions and different models are formed naturally. But what is the cause of the leakage in the intercooler of the air compressor?
In order to reduce the power consumption of the compressor and ensure the reliable operation of the compressor, intermediate coolers are arranged between the different levels. In the intercooler, the gas is cooled by cooling water by convection heat transfer. If the intercooler leaks, the gas channel communicates with the cooling water channel, which is in accordance with the pressure of the cooling water.
Leakage of intercooler in air compressor
The intercooler at the back of the first stage, the cooling water pressure is usually higher than the gas pressure. Therefore, if the primary intercooler is leaking, the cooling water will enter the gas side, and the gas will be entrained with water, so that the water quantity of the first stage oil-water separator will increase obviously.
How to solve the leakage of intercooler in air compressor?
According to the above phenomenon, we can make the judgment of intercooler leakage. When the air compressor exhaust system to reduce the amount of air compressor system, pressure began to rise, pressure controller is connected to the signal, then start the intake valve opening decreases gradually, the displacement of the screw machine with the decrease of the current of the motor is reduced. When the system gas consumption increases, the system pressure began to decrease, the controller received pressure to reduce the signal, it will gradually increase the intake valve opening, at this time the screw machine exhaust is also increased to the full amount of output. If the gas consumption continued to reduce system when the system pressure increases to the empty set pressure limit, the controller will be the intake valve is fully closed, the air compressor starts running empty, to run empty delay time set after the motor to stop running, the air compressor can be automatically shut down, when the pressure and exhaust volume changes, start the motor control part (no load start), the air compressor can be automatically switched on. The real implementation of 24 hours no one's job, at the same time, enterprises will save a lot of energy, reducing production costs for enterprises.https://www.linsheng.com/


text:
Senior Backend Developer Permanent
- Location: London, England
- Salary: £500000.00 - £601000 per annum
- Sector: Software Engineer (Front to Back)
- Consultant: Jake Kings
As a Senior PHP Developer, you will be working closely with the product lead and a Front-end developer to push the application forward. The role will include time to get up to speed with the current code of the system and input on the UX as well as the overall technical architecture. The role is based in central London and a machine will be supplied.
*Strong PHP skills
*Experience with the symphony framework
*Workflow development experience
As a Senior PHP Developer, your contribution will be recognised with a competitive salary (to £60k), plus bonus and benefits package.
Send your CV or call today for more information on this Senior PHP Developer with Symfony.
Propel are the UK's largest independent provider of permanent and contract recruitment services to the global digital economy, specialising in commercial, marketing, technical and creative talent.
Services advertised by Propel are those of an Agency and/or an Employment Business. Please be aware that we receive a high volume of applications for our roles, many from people who meet or exceed the requirements. Whilst we try to respond to as many applicants as possible, you can assume that you have not been selected for interview if you do not hear from us within 14 days.
Sorry, this job post it's no longer available
Similar Jobs
Python Developer - 1-3 month contract...£450 - £500 per day City of London, London
Python Developer - 1-3 month contract...£450 - £500 per day City of London, London


text:
Katie Dress in Wave
It's for the girl who loves to dress up (and not just in mom's oversized second hands). The children's version of the Morgan Maxi will be a beloved piece in a girl's collection. Its fitted cut and quality design will last even if it goes from party to untidy play. Wicking fabric, 92% polyester / 8% spandex. Made in the USA. Size Chart
- Machine wash cold with like colors
- Gentle cycle
- Do not bleach
- Lay flat to dry or tumble dry on low


text:
WASHINGTON — President Obama, resigned to his failure to broker a peace deal between Israel and the Palestinians, is looking past his time in office and weighing a plan that would preserve at least the principle of a two-state solution for his successor to pursue.
The White House is debating whether the president should lay down the outlines of an agreement, several officials said, perhaps through a resolution at the United Nations Security Council or in a presidential speech. The objective would not be to revive direct negotiations — almost nobody believes that is likely now — but to enshrine the proposals Secretary of State John Kerry made during his last failed effort at peacemaking in 2014.
A Security Council resolution, officials said, would give enduring legitimacy to the compromises that Mr. Kerry hammered out in private between the two sides, and build broad international support for a series of proposed solutions that could provide the framework for a future Israeli-Palestinian agreement.
These deliberations, which have been percolating for several months, have rattled Prime Minister Benjamin Netanyahu of Israel and could lead to further tension between him and the president in a relationship that has already been marked by bitter rifts.
Mr. Netanyahu on Monday declined an invitation to meet with Mr. Obama on March 18 in Washington, ostensibly because he did not want to get drawn into the volatile presidential election. In fact, several officials said, Mr. Netanyahu did not want to meet with Mr. Obama without having sealed the terms of a new pact on American military aid. The 10-year agreement, potentially worth more than $40 billion, is viewed as a way to compensate Israel for the Iran nuclear deal. But negotiations have run into snags, these people said, and Mr. Netanyahu did not want to risk leaving an Oval Office meeting empty-handed.
An even deeper potential source of friction between the leaders, officials said, stems from the possibility that Mr. Obama will make a last foray into peacemaking. In whatever form that would take, the purpose would be to show a way of resolving all the central issues that divide the two sides, from the borders of a Palestinian state to Israel's security and the political status of Jerusalem.
"Obama and Kerry are looking at the very real likelihood that the two-state solution could die on their watch," said Martin S. Indyk, who served as the special envoy for Israel-Palestinian peace negotiations under Mr. Kerry in 2013 and 2014. "Having tried everything else, I think they feel a responsibility, above all to Israel's future as a Jewish and democratic state, to preserve the principles of a two-state solution."
After months of intensive talks, Mr. Kerry failed to break a deadlock on the so-called final-status issues between Mr. Netanyahu and the president of the Palestinian Authority, Mahmoud Abbas. Mr. Netanyahu has since won re-election with a government that is even more hard-line on these issues than his last one. During that campaign, the prime minister disavowed his support for the two-state solution. Mr. Abbas's position, meanwhile, has been eroded by months of violent attacks by Palestinians on Israeli Jews.
Adding to the urgency of the debate, officials said, is a mounting American concern that a continued expansion of Jewish settlements in a swath of territory in the West Bank known as Area C will soon make a geographically and politically viable Palestinian state impossible.
Middle East peace initiatives have long had appeal for late-term presidents. Ronald Reagan opened a dialogue with the Palestine Liberation Organization during his final months in office. Bill Clinton and George W. Bush both made last-ditch attempts to broker peace deals in their last years in office. Any new effort by Mr. Obama would bear a host of uncertain political ramifications in an election year.
While the Democratic front-runner, Hillary Clinton, the former secretary of state, has declared that she would pursue a peace accord as president, she might not welcome having to take a position on a Security Council resolution that is viewed as putting pressure on Israel. Republicans could seize on a diplomatic overture to throw their support behind Israel, though the party's current front-runner, Donald J. Trump, has pledged to take a neutral stance in the Israeli-Palestinian conflict.
Yet all these qualms, officials said, could take a back seat to Mr. Obama's frustration about his failure in the peace process and its impact on his legacy, particularly as a president who once made an Israeli-Palestinian peace agreement a centerpiece of his diplomacy.
"There will be a great temptation to do something in the final year," said Aaron David Miller, a vice president at the Woodrow Wilson International Center for Scholars. "For a president who came out faster and more aggressively on the Middle East than any of his predecessors, there is a gnawing sense of incompletion and perhaps even failure."
Among the questions the White House is considering is how long to wait. Deferring action until after the November election would ease the political pressure on the Democratic nominee. But it would shorten the time to build international support for a resolution.
In Jerusalem, Israeli officials refused to comment on any possible moves by Mr. Obama. But they reiterated their long-held position that the only way to reach any agreement with the Palestinians was through bilateral negotiations, not international organizations.
Ehud Yaari, a prominent Israeli analyst at the Washington Institute for Near East Policy, said Mr. Netanyahu was probably less concerned about the possible publication of parameters by the administration or a Security Council resolution than about what, if any, mechanism would be proposed for propelling the peace process forward.
"It would be one more U.N.S.C. resolution," Mr. Yaari said, adding that the wording would "not necessarily be negative" for Israel. Washington's policies are well known, he said, adding, "Obama is not going to produce something dramatically different," he said. "The question is what mechanism is to be introduced. That is the major issue."
Mr. Indyk agreed that a Security Council resolution need not be punitive for Israel. It would most likely be modeled on a United Nations resolution adopted after the 1967 Arab-Israeli war, which called for Israeli forces to withdraw from occupied territories and for the establishment of a lasting peace.
The latest contretemps between Mr. Netanyahu and Mr. Obama showed how little trust they have for each other. After articles appeared in the Israeli news media that the president had not offered the prime minister a date for a meeting, the White House issued a statement that pointedly rebuffed that claim.
Hours later, Mr. Netanyahu's office issued a statement in which it said the whole thing was a misunderstanding. The prime minister, the statement said, was looking forward to a visit Wednesday by Vice President Joseph R. Biden Jr. "and discussing how we can meet the many challenges facing the region."
While the negotiations over the military aid package were complex, American officials expressed confidence they would be resolved soon. Next week, Israel's defense minister, Moshe Yaalon, is scheduled to meet Defense Secretary Ashton B. Carter at the Pentagon. "We're in the kind of final stages of talking," said the deputy defense secretary, Bob Work.


text:
Come, enjoy the Ocala Courtyard by Marriott where the new state-of-the-art lobby provides greater flexibility and exciting choices for our guests. Easy to access from SR 200 off Exit 350 of the I-75, this certified green friendly Ocala hotel now features The Bistro - Eat. Drink. Connect. lobby with inviting, flexible spaces to work or relax in, free Wi-Fi throughout, and easy access to the latest news, weather and airport conditions via the GoBoard. Guests can enjoy a variety of food and beverage choices each morning, and all new dinner service and cocktails each evening. A 24-hour business center and boarding pass printing service is also available, and four impressive meeting rooms can host your meetings or social events of up to 80 people. This strategically located hotel near Rainbow Springs Park is conveniently located just minutes from all of the major business and entertainment venues of Ocala and Marion County. Your visit to Ocala is easier here!
Amenities· 24-hour front desk
· Accessible facilities
· Accessible parking
· Barber shop - (In Area)
· Beauty shop/salon - (In Area)
· Boarding pass print-out available
· Bookstore - (In Area)
· Business center
· Business services
· Car rental desk - (In Area)
· Check cashing policy
· Cocktail lounge with light fare
· Coffee shop
· Coin operated laundry
· Complimentary in-room coffee or tea
· Complimentary newspaper in lobby
· Currency exchange - (In Area)
· Direct dial telephone
· Drugstore/pharmacy - (In Area)
· Dry cleaning
· Efolio available to company
· Elevators
· Exercise gym
· Express check-in
· Express check-out
· Florist - (In Area)
· Food and beverage outlets
· Free high speed internet connection
· Free parking
· Front desk
· Full service housekeeping
· Hair dryer
· Health club
· Health club
· High speed internet access
· High speed wireless
· Housekeeping - daily
· Ice machine
· Individual Efolio available
· Interior corridors
· Ironing board
· Laundry/Valet service
· Lounges/bars
· Meeting rooms
· Motorcycle parking
· Non-smoking rooms (generic)
· On-Site parking
· Onsite laundry
· Outdoor pool
· Parking
· Pool
· Public area air conditioned
· Restaurant
· Safe deposit box
· Sauna - (In Area)
· Security
· Spa - (In Area)
· Tennis court - (In Area)
· Travel agency - (In Area)
· Valet cleaning
· Valet same day dry cleaning
· Vending machines
· Wakeup service
· Whirlpool
· Wireless internet connection in public areas
Room InformationThe amenities listed in this description represent a sample of amenities available in some or all guest rooms in this hotel
High speed internet connection, Internet access, Wireless internet connection, High speed wireless, Non-smoking, Free local calls, Balcony/Lanai/Terrace, Coffee/Tea maker, Alarm clock, Air conditioning, Air conditioning individually controlled in room, Shower, Bathtub/shower combination, Bathtub & jacuzzi separate, Private bathroom, Phone in bathroom, Hairdryer, Separate closet, Closets in room, Iron, Bathroom amenities, Down/feather pillows, Foam pillows, Sofa bed, Cribs, Local calls, Free toll free calls, Mini-refrigerator, Microwave, Dish-cleaning supplies, Color television, Cable television, Premium movie channels, CNN availaible, HBO available, ESPN available, All news channel, AM/FM radio, Remote control television, Large desk, Chair provided with desk, Desk with electrical outlet, Spare electrical outlet available at desk, Electrical current voltage, Separate modem line available, Telephone, Voice mail, Multi-line phone, Direct dial phone number, Outdoor space, List of movie channels available, Instant hot water, Separate line billing for multi-line phone, Connecting rooms
pool view
2 double
1 king
2 queen
Miscellaneous Information
· American Dollars is the native currency.
· Check in time is 4:00 PM
· Check out time is 12:00 PM
· Opened in 1988
· Renovated in 01/01/2016
· 169 rooms.
· 8 suites.
· 3 floors.
Cancellation Policy
Cancel policy may be more restrictive based on rate / room booked, season, special events
Restaurant InformationThe Bistro Eat. Drink. Connect.
Your food and beverage destination for refreshing breakfast choices in the morning, and a variety of dinner and cocktail options in the evening. The Bistro also offers specialty beverages made with Starbucks coffee to help you get a jump on the day.
Meeting FacilityDerby Executive Board Room Gulfstream Hialeah Calder
Recreation Information
Fitness center on-site
Health club
Tennis court
Bowling alley
Hiking trail
Horseback riding
Mountain biking trail
Putt putt golf
Sports court onsite
Scuba diving
Children's program
Outdoor pool
Area Attractions- Ocala
- Greyhound Bus Lines
- Ocala Civic Theater
- Hippodrome State Theater
- Regal Hollywood 16 Cinemas
- Easy Street Family Fun Center
- Ocala Gran Prix
- Circle Square Cultural Center
- Silver Springs Nature Park
- Marion Twin Cinema
- Paddock Mall
- Wild Waters Water Park
- College of Central Florida
- Florida State Fairgrounds
- Central Florida Fairgrounds & Exposition Park
- University of Florida
- Webster University
- Rasmussen College
- Gator Football
- Ben Hill Griffin Stadium
- New York Yankees Spring Training
- Raymond James Football Stadium - Home of Tampa Bay Buccaneers
- Orlando Magic Basketball
- Ocala Marion County Chamber of Commerce
- Ocala Equestrian Complex
- Ocala Speedway
- HITS Post Time Farm
- Ocala Breeders Sales
- Ben Hill Griffin Football Stadium University of Florida
- Amway Arena
- Blue Rein Ranch USDA Licensed Equine Export
- Class 1
- Emergency One
- Closet Maid Corporation
- SPX Corporation
- Signature Brands
- Elster Amco Water Inc.
- Gordon Food Service Inc
- Lockheed Martin
- West Marion Community Hospital
- Munroe Regional Medical Center
- Ocala Regional Medical Center
- Sears Holdings Kmart Distribution Center
- The Vines Hospital
- Qualcomm/Atheros
- Dixie Metals
- Honda of Ocala
- DeLuca Toyota
- Ford of Ocala Lincoln of Ocala
- Silver Rivers State Park
- Silver River Museum & Environmental Education
- Don Garlits Museum of Drag Racing
- Appleton Museum of Art
- Silver Rivers Museum
- Canyon Zip Line & Canopy Tours
- HITS (Horses in the Sun)
- Florida Greenway Trail
- Ocala National Forest
- Ocala Carriage and Tours
- Florida Horse Park
- Silver Springs Theme Park
- Rainbow Springs State Park
- Circle Square Commons
- The Villages
- Silver Springs Concert Venue
- Shalom Park
- Brick City Center For the Arts
- Bealls Department Store
- Gander Mountain
- Mossy Oaks Antique Mall
- Dicks Sporting Goods
- Dillards
- Ocala Wine Experience
- Stella's Modern Pantry
- The Lime Cabinet
- Barnes & Noble
- Sam's Club
- Walmart
- Macy's
- JC Penney
- Stein Mart
- Circle Square Commons Farmers Market
- Target
- Hobby Lobby
- Ocala International Airport
- Gainesville Regional Airport
- Orlando International Airport
- Tampa International Airport
- Jacksonville International Airport
- Captain Mike's Lazy River Tours
- Ocala Carriage & Tours
- Young's Paso Fino Ranch
- Farm Tours of Ocala


text:
20 Questions for Sellers
The Twenty Questions a Professional Appraiser and Josie Morrison Must Answer About Your Home Before We Can Determine a Value.
1. The comparable on the date of sale and future market trend
2. Its value based on location
3. The site/view both looking at the property and looking from the property out
4. The design and appeal of the dwelling's floor plan and amenities
5. The quality of construction
6. The age of the property and any improvements
7. The status of permits on all improvements
8. Condition of the property
9. Total number of rooms and square footage of each
10. Number and types of rooms (bedrooms, bathrooms, etc.)
11. Square footage (gross livable area)
12. Is there a basement or attic?
13. Is the basement finished? If so, number and types of rooms. Is there a walkout?
14. How functional is the property? Good, average, fair, poor? How much obsolescence is there?
15. Is there central air conditioning? What kind of heat?
16. What type of car spaces is available? (garage, carport, etc.)
17. Are there any special features that your property offers? (porches, patios, pool, fireplaces, special heating/cooling equipment, skylights, solar power, or special landscaping)
18. Were there any special financing or special sales considerations that might have impacted value for the comparable properties? Are there any offered on the subject property?
19. How is the money market affecting value (present value analysis)?
20. Were there any out of the ordinary motivations of the sellers on comparable properties?


text:
Driftwood Accessory 2 - LIMITED
Driftwood Altar Accessory
This impressive driftwood natural sculpture measuring approximately 18 inches long was collected along the coast of Maine. It is smoothed on one side to lay flat on your altar, table top and could easily hang on your wall by inserting a hook.
Driftwood sculptures look fantastic accenting your garden, landscaping, windows, walls, centerpiece for tables and entrance ways. We have quite a few bordering our flower gardens and sprinkled throughout our home. You are able to paint, carve, varnish, etc., if you wish to further personalize your driftwood.
Gathered and crafted by 13 Moons.


text:
Aadhaar Enabled Payment System (AEPS) - Domestic Money Transfer
Frequently Asked Questions :: Aadhaar Enabled Payment System (AEPS) - Domestic Money Transfer
What is JCPay App?
JCPay App is the common mobile app published and managed by National Payments Corporation of India (NPCI) for any merchant associated with any acquiring bank on JCPay App service to allow the merchant to accept payment from a customer of any bank by authenticating the customer's biometrics (currently only fingerprints) directly from customer's bank account and receive the sale proceeds instantaneously into merchant's own bank account. To be able to effect the same, merchant must have an android mobile with the JCPay app and a certified biometric scanner attached with the mobile phone on the USB port and both the merchant and customer should have had linked their Aadhaar numbers to their bank accounts respectively.
What is JCPay Services?
JCPay App Service is the back-end payment service network comprising of merchant's acquiring bank, customer's issuer bank and the interbank settlement agency NPCI. Thus, in effect when a customer of SBI tries to transact with a PNB merchant it flows via the JCPay service run by NPCI on which both these banks are certified and live. JCPay app is your one stop shop for mobile recharges, DTH top-ups, landline, electricity and gas bill payments.
Why should i use jcpay app?
JCPay wallet makes your payments as mobile as you are. This friendly wallet app lets you be generous and awesome. You can send money to your dear ones instantly. Save more cash by availing interesting offers and discounts as you shop cash free. And for those who owe you money, send them a request to pay through the App.
What happens when money is debited but is not reflecting in my JCPay wallet?
If the transaction fails and amount is deducted from your bank account, refunds are processed within 24 to 48 working hours to your JCPay wallet.
How do i load/get money in my JCPay wallet?
There are many ways you can load/get money in your wallet
You can recharge your wallet through UPI option/NEFT/RTGS.
What should i do in case fraud has happened on my account?
In such case please file a complaint on your nearest police station. We shall act in your complaint once we receive an email from the police/cyber crime. You may mail at firstname.lastname@example.com to block your JCPay Wallet till such time.
Can i use any credit card/ debit card to load my wallet?
No, We can not currently support loading funds using credit cards, debit cards or Net banking.
What is convenience fee?
Convenience Fee will be levied for online loading of funds in your JCPay Wallet. The fee amount will be as per the prevailing fee structure and will be displayed before you confirm loading of funds.
Can the transactions be done on a feature phone?
No. Transactions can only be done on a smart phone OR in case of bank custom JCPAY app, on a device as specified by your acquiring bank with a certified biometric scanner attached.
Is there any limit on the value of transactions in JCPay App?
The current limit is Rs 10,000/- per transaction, however this will be reviewed and changed from time to time.
In how many languages is JCPay available?
Currently JCPay App is only available in English. More languages will be enabled soon.
Can I use JCPay App outside India?
No, currently the JCPay Application pay Service is available only in India
What is Aadhaar Enabled Payment System?
Aadhaar Enabled Payment System is a payment service empowering a bank customer to use Aadhaar as his/her identity to access his/ her respective Aadhaar enabled bank account and perform basic banking transactions like balance enquiry, cash deposit, cash withdrawal, remittances through a Business Correspondent.
What are the services available under Aadhaar Enabled Payment System (AEPS)?
Under AEPS currently following services are present:
- Balance Enquiry
- Aadhaar Pay
- Cash Withdrawal
What are the benefits of Aadhaar Enabled Payment System (AEPS)?
- Aadhaar enabled Payment System is easy to use, safe and secure payment platform to avail benefits by using Aadhaar number & biometrics, it eliminates the threat of any fraud and non-genuine activity.
- Aadhaar enabled Payment System facilitate disbursements of Government entitlements like NREGA, Social Security pension, Handicapped Old Age Pension etc. of any Central or State Government bodies using Aadhaar authentication.
- Reaching the unreached - The model enable banks to extend financial services to the unreached clients beyond their branch network as beneficiaries of the agents are mostly located at unbanked and underbanked areas.
What are the benefits of eKYC?
eKYC as a product has following benefits:
- Paperless.
- Cost effective
- Prevent Identity hacking and forged documents
- Safe & Secure
Who is issuer Bank?
Issuer is the bank in which the user hold his/her account and Aadhaar is mapped for doing Aadhaar Enabled Payment System (AEPS) Transactions.
What is RRN No.?
RRN number is a 12 digit number generated to record the transaction.
What if the money sent has not reached its desired destination?
In this case please check the details you have entered are correct or not. Also check with the recipient if he/she has completed the process of registering for JCPay App. If the details are correct and the recipient is a JCPay App customer, please contact us at our customer care mail at firstname.lastname@example.com
Frequently Asked Questions :: Merchants
I am a new merchant, how do I get on-boarded and start accepting payments on JCPay App?
Please follow the steps below:
- Enquiry generate through SM/JC Care /Retailer / Web Portal.
- Enquiry Form:- Name, Location, Mobile Number, Email Address, Business Name, Business Type.
- After generating the enquiry SM / JC Care/Retailer will contact to applicant & explain them business model.
- SM/ JC Care/Retailer will collect all document from applicant then get payment done through payment gateway.
- After all approvals Head office Executive will create his/her agent ID.
- When once agent ID created the Head office executive will mail all the details of agent to technical executive for installation of JCPay Application.
- After above all process the technical executive will provide training to the applicant.
Can a merchant on-board with more than one bank?
Yes, if he has a compelling reason/ need to on-board with multiple banks. Normally, this is not needed and may be avoided.
Who will provide the biometric scanner?
We may provide the same to the merchant or some may ask to procure from the certified list of scanner directly from the market. Hence, please check with the bank of your choice.
How does JCPay Aadhaar verify my mobile number?
Currently, while new merchant registration, this is basis an OTP verification sent out to the mobile number specified. This may change to app initiated outgoing encrypted SMS, which will happen in a transparent manner with no interaction with the user.
What is required to be input on JCPay App to accept payment from customer?
Merchant must enter customer's bank, Aadhaar number, amount and fingerprint to initiate the transaction.
If a customer has multiple accounts linked to his Aadhaar number, which account will be debited for making the payment?
Primary account associated with Aadhaar.
How do I check the status of the last or previous transactions?
Please check transaction history. Currently, the app shows today's transactions only but it may support last 7 days transactions in future.
JCPay Aadhaar app shows status of last transaction as "pending" but I have received message of successful credit of the transaction value. What should I do?
Such transactions are successful but you can call your JCPay helpdesk and be sure before honouring the transaction and render goods or services to the customer.
Whom should I contact if I have issues with accepting payments?
Please write us on email@example.com.
I have other issues with the app. What should I do?
You can email us on firstname.lastname@example.com
Frequently Asked Questions :: Customers
Who can use JCPay App to make payments to participating merchants?
Any resident of India holding a valid Aadhaar number and having an Aadhaar linked bank account may use JCPay Aadhaar for purchasing goods/services at merchant locations offering such services.
Can the transactions be done with a debit/ credit card?
No, these are Card Not Present transactions i.e. transactions can be performed without having any card.
Does the customer need to carry Aadhaar Card for transacting?
Carrying Aadhaar card is not mandatory. But, linking Aadhaar Number with Bank account is a pre-requisite.
Does the customer specifically need to register to be able to transact through JCPay App ?
Ideally No, but linking Aadhaar Number with Bank account is a pre-requisite. However, registration process shall be as per the procedures laid down by the Issuer bank providing the service. Please check from the bank where you hold the Aadhaar linked bank account.
What happens if a customer enters an incorrect Aadhaar Number or chooses a Bank where he doesn't have an account?
If the customer enters incorrect Aadhaar number/ selects an incorrect bank where he/ she does not have an Aadhaar linked bank account, the transaction will decline with an appropriate response message.
How will the customer know that the transaction has been completed successfully?
The status of the transaction will be available on the merchant's mobile primarily. The customer will also receive an SMS from his/her Bank if registered for mobile alerts.