text:
The leading
Defense Arguments: Matter Of Almanza-Arenas, 24 I&N Dec. 771 (BIA 2009)
by Kathy Brady
Matter of Almanza-Arenas was published on April 13, 2009. It made two rulings that purport to overturn established law.
This advisory discusses arguments against both of these holdings, which appear to be subject to challenge. A motion to reconsider is pending with the BIA, but unless and until that is granted advocates should appeal denials to circuit courts. Counsel should raise these and other valid arguments at all levels in the process to be sure of benefitting from a future good decision.
A. The Ninth Circuit's rule that the government has the burden of document production to show that a conviction under a divisible statute is a bar to relief applies to applications filed before or after March 11, 2005, because the REAL ID provisions that came into effect on that date did not change the prior allocation of the burden.
This argument is relevant in the Ninth Circuit, or in other circuits where counsel assert that the government bears the burden of document production in cases where a conviction under a divisible statute is a potential bar to eligibility for relief, such as cancellation.
In Sandoval-Lua v. Gonzales, 499 F.3d 1121 (9th Cir. 2007) the Ninth Circuit considered 8 CFR § 1240.8(d) (1997),1 which sets out the burden of proof in applications for relief. The regulation provides:
[T]he respondent shall have the burden of establishing that he or she is eligible for any requested benefit or privilege and that it should be granted in the exercise of discretion. If the evidence indicates that one or more of the grounds for mandatory denial of the application for relief may apply, the alien shall have the burden of proving by a preponderance of the evidence that such grounds do not apply.The Ninth Circuit held that where the possible bar to relief is a conviction under a divisible statute, an inconclusive conviction record that is produced by the government is sufficient to meet the applicant's burden, so that he is not barred from relief.2 The record must show either that the conviction "was or was not" in the adverse category (in that case, an aggravated felony). An inconclusive record, without more, establishes that the conviction was not necessarily found to be in that category. The court held therefore that "the inconclusive record of conviction in this case" is sufficient to show that the petitioner "carries his burden to show by a preponderance of the evidence that his § 11379(a) conviction was not 'necessarily' an aggravated felony," pursuant to 8 CFR § 1240.8(d). Id. at 1132.
This decision reaffirmed other Ninth Circuit precedent that gave the government the burden of producing documents to show that a conviction under a divisible statute is a bar to relief.3
In Almanza-Arenas the BIA did not assert that Sandoval-Lua was wrongly decided, or that the Ninth Circuit owed the BIA deference under principles set out in Chevron and Brand X. Rather, it distinguished Sandoval-Lua on two bases. It held that under recently enacted REAL ID provisions, in any application filed after May 11, 2005 the applicant has the burden of document production to establish that a conviction under a divisible statute is not a bar to relief. (Mr. Sandoval-Lua had filed before this date.) In addition, the BIA found that REAL ID provisions require an applicant to produce criminal documents as corroborating evidence when an immigration judge requests it. There is a strong argument that the BIA is wrong on both counts.
1. The REAL ID standard for an applicant's burden of proof, which took effect on May 11, 2005, is effectively the same as the burden of proof standard already set out in the regulation that the Ninth Circuit construed in Sandoval-Lua. Therefore the Sandoval-Lua construction applies to applications filed under both REAL ID and the regulation.
The REAL ID provision at issue in Almanza-Arenas, INA 240(c)(4)(A), 8 USC § 1229a(c)(4)(A), provides:
In general. An alien applying for relief or protection from removal has the burden of proof to establish that the alien (i) satisfies the applicable eligibility requirements; and (ii) with respect to any form of relief that is granted in the exercise of discretion, that the alien merits a favorable exercise of discretion.
This language imposes the same standard as the regulation cited above, in that the applicant has the burden of proof to establish that he or she satisfies the applicable eligibility requirements and merits favorable exercise of discretion.4
In fact, the BIA in Almanza-Arenas did not identify any specific difference between the burden of proof requirement under § 240(c)(4)(A) and under the regulation construed in Sandoval-Lua, or why such a difference would permit a different result than under Sandoval-Lua. It only stated in a conclusory manner that Sandoval-Lua was not binding because in that case the application "was not governed by the burden of proof requirements of the REAL ID Act." Almanza-Arenas, supra at 775. Instead, the Board's main focus was on the requirement under § 240(c)(4)(B) that an applicant respond to an immigration judge's request for evidence to corroborate witness testimony.
2. The REAL ID requirement to produce corroborating evidence to boost the credibility of a testifying witness does not apply to a request for conclusive documents under the modified categorical analysis.
The Board's holding relied heavily on another section added by REAL ID, relating to requests by an immigration judge for corroborative evidence. The Board claimed that by ignoring "a specific request, pursuant to the corroboration requirements in section 240(c)(4)(B) of the Act, for the respondent to produce additional documents from the record of conviction," the respondent failed to meet his burden of proof under REAL ID. Almanza-Arenas, 24 I&N at 774. However, § 240(c)(4)(B) relates exclusively to corroborating the credibility and persuasiveness of witness testimony, and has nothing to do with production of documents from the record of conviction under the "modified categorical approach." (This is the terminology used in the Ninth Circuit; in other circuits it may be referred to as the "second step of the categorical approach"). Section 240(c)(4)(B) provides:
(B) Sustaining burden. The applicant must comply with the applicable requirements to submit information or documentation in support of the applicant's application for relief or protection as provided by law or by regulation or in the instructions for the application form. In evaluating the testimony of the applicant or other witness in support of the application, the immigration judge will determine whether or not the testimony is credible, is persuasive, and refers to specific facts sufficient to demonstrate that the applicant has satisfied the applicant's burden of proof. In determining whether the applicant has met such burden, the immigration judge shall weigh the credible testimony along with other evidence of record. Where the immigration judge determines that the applicant should provide evidence which corroborates otherwise credible testimony, such evidence must be provided unless the applicant demonstrates that the applicant does not have the evidence and cannot reasonably obtain the evidence. [emphasis supplied]
This language does not change the standard set out in Sandoval-Lua. The first sentence requires the applicant to comply with requirements "as provided by law or by regulation." This means that the applicant should comply with the requirements in 8 CFR1240.8(d), as such language is interpreted by the court in Sandoval-Lua, and the same standard under § 240(c)(4)(A) discussed above, which will have the same interpretation.
The last two sentences in (B) require the applicant, upon a judge's request, to produce corroborative evidence to support the credibility or persuasiveness of witness testimony. This section is irrelevant to evidentiary requirements under the modified categorical approach. The modified categorical approach involves only documentary evidence, in the form of contemporaneous criminal court documents that conclusively establish the elements of legal admissions, judicial findings, or jury verdicts from a prior prosecution. It specifically excludes testimony of witnesses, so witness credibility is not an issue. Because this section of § 240(c)(4)(B) is directed only at bolstering witness testimony, it does not govern requests from an IJ that the respondent produce documents to prove the nature of a conviction under the modified categorical approach. In fact, under Sandoval-Lua such a request from a judge should be considered improper, as it is directing the respondent to help the government meet its burden of proof.
B. It appears that the panel held that any conviction of a crime involving moral turpitude is a bar to non-LPR cancellation, or perhaps any conviction with a potential sentence of a year, and at least where the applicant entered without inspection. None of these is a correct interpretation of the meaning of "convicted of an offense under" the crimes grounds of deportability and inadmissibility, pursuant to INA § 240A(b)(1)(C). This holding directly conflicts with on-point precedent that the panel failed to acknowledge and did not have authority to overturn.
1. Holding and Overview
In the last paragraph of Almanza-Arenas, the panel held that the respondent's conviction of a crime involving moral turpitude ("CMT") is a bar to cancellation for non-lawful permanent residents ("non-LPR cancellation") under INA § 240A(b)(1)(C), because the conviction is "described under" the CMT deportation ground. This section will discuss arguments against that holding.
Section 240A(b)(1)(C) [8 USC § 1229b(b)(1)(C)] provides in pertinent part:
The Attorney General may cancel removal of, and adjust to the status of an alien lawfully admitted for permanent residence, an alien who is inadmissible or deportable from the United States if the alien- (C) has not been convicted of an offense under section 212(a)(2), 237(a)(2), or 237(a)(3) 5
Mr. Almanza-Arenas entered the U.S. without inspection, i.e. he was not "admitted." He was convicted of a misdemeanor under Calif. Health & Safety Code § 10851. The immigration judge held that this statute is divisible for moral turpitude purposes because it prohibits both auto theft (a CMT) and joyriding (not a CMT).6 For purposes of this discussion, we will accept the BIA's conclusion that the respondent's particular conviction was shown to be of a moral turpitude offense. But see critique of this holding in Part A, supra.
Mr. Almanza-Arenas asserted that he was not "convicted of an offense under" the CMT grounds of inadmissibility or deportability. It appears that Mr. Almanza-Arenas was not inadmissible under the moral turpitude ground, because his conviction came within the "petty offense exception."7 The exception applies to a conviction that has a potential sentence of no more than a year and a sentence imposed of no more than six months, if the offense is the first CMT the person has committed.
This advisory will not further discuss the CMT inadmissibility ground, but it is important to note that for this purpose a CMT conviction must come within the petty offense or the youthful offender exceptions8 to that ground. If it does not, the government will assert that the conviction is a bar to non-LPR cancellation because it is of "an offense under" the CMT ground of inadmissibility at INA § 212(a)(2), regardless of whether it is "an offense under" the CMT deportation ground.
The contested issue in Mr. Almanza-Arenas' case was whether he was "convicted of an offense under" the CMT deportation ground. He asserted that because he entered without inspection ("EWI"), his conviction was not "under" the moral turpitude or any other deportation ground, because the deportation grounds as a whole apply only to noncitizens who have been admitted to the United States.9The BIA found that this argument was foreclosed by the Ninth Circuit's decision in Gonzalez-Gonzalez v. Mukasey, 390 F.3d 649 (9th Cir. 2004). There the court found that the fact that an applicant for non-LPR cancellation has not been admitted, and thus cannot be found "deportable," does not mean that he or she cannot be "convicted of an offense under" a deportation ground. The court held that the plain language of the statute did not support a construction by which "aliens who entered this country illegally would have greater rights to apply to the Attorney General for cancellation of removal on the basis of hardship than those who entered lawfully." Id. at 652.10 The court held that the phrase "convicted of an offense under" must be read as "convicted of an offense described under" the referenced grounds of deportation and inadmissibility. Ibid. (emphasis in original). Because Mr. Gonzalez' offense of conviction contained all the elements of a "crime of domestic violence" as set out in the domestic violence deportation ground at INA § 237(a)(2)(E)(i), the court found that the conviction was "described under" that deportation ground, and that Mr. Gonzalez was statutorily barred from applying for non-LPR cancellation.
The Board found that under Gonzalez-Gonzalez, Mr. Almanza-Arenas's conviction may be "described under" the deportation grounds in general, despite the fact that he had not been admitted.The Board next turned specifically to the moral turpitude deportation ground. A noncitizen is deportable under INA § 237(a)(2)(A)(i) if he or she is "convicted of a crime involving moral turpitude committed within five years after the date of admission," as long as the offense carries a maximum potential sentence of one year or longer.11 Without discussing these statutory requirements, the panel simply stated, "Because the respondent failed to establish that he was not convicted of a crime involving moral turpitude, he falls within the provisions of section 237(a)(2) of the Act." Matter of Almanza-Arenas, 24 I&N Dec. at 776. Although the lack of any discussion makes it impossible to identify the standard employed by the panel, it appears that in Almanza-Arenas the panel may have disregarded all of the descriptive information in the deportation ground except for the terms "convicted" and "crime involving moral turpitude." This conflicts with the holding in prior BIA and Ninth Circuit precedent opinions, which require that (to the extent possible for a person who entered without inspection), the full text of the applicable grounds of inadmissibility or deportability must be given effect under § 240A(b)(1)(C). The rest of this advisory outlines possible arguments against this holding in Almanza-Arenas. These include:
2. Arguments
a. The panel failed to follow a central tenet of BIA and Ninth Circuit cases addressing the issue, which is that to the extent possible in an EWI case, the full language of the deportation or inadmissibility ground must be applied under INA§ 240A(b)(1)(C). Instead, in direct contradiction of this principle the panel appeared to subtract all limiting language from the CMT deportation ground.
The Almanza-Arenas opinion appeared to eliminate all limiting language in the CMT deportation ground, at least as applied to persons who entered without inspection. This contradicts the well-established rule that to the extent possible, the full language of the applicable ground of deportation or inadmissibility must be applied under INA § 240A(b)(2)(C).
Established Rule. The BIA and Ninth Circuit have held repeatedly that based on the plain language of § 240A(b)(1)(C), for a conviction to serve as a bar to cancellation it must come within the full description set out in the applicable ground of deportation or inadmissibility. The exception is that the conviction of an applicant who entered without inspection can be considered "described under" the deportation grounds, despite the fact that the person was not admitted. Apart from that, the following cases hold that where a conviction does not match "the entirety" of the text in the applicable ground, it does not serve as a bar to non-LPR cancellation.
We further find that this conviction, standing alone, does not render the respondent ineligible for cancellation of removal under section 240A(b)(1)(C) of the Act, which requires an applicant to show that he "has not been convicted of an offense under section 212(a)(2)." We view the plain language of this provision as incorporating the entirety of section 212(a)(2), including the exception for petty offenses set forth therein. Accordingly, we find that the "petty offense" exception also applies when determining eligibility for cancellation of removal . Put in other terms, the "description" of the category of offenses encompassing crimes involving moral turpitude also includes the exception."
Id. at 593 (emphasis supplied).
BIA's Approach in Matter of Almanza-Arenas. The panel in Almanza-Arenas failed to acknowledge the existence of any of the above opinions. Its holding conflicts with the central tenet of the opinions, by failing to apply the descriptive language in the CMT deportation ground.
Under INA § 237(a)(2)(A)(i), a single conviction of a crime involving moral turpitude is a basis for deportation only if
I) the offense was committed "within five years after the date of admission" and
Potential sentence of one year or longer. Although the Almanza-Arenas panel did not discuss this, it appears that it failed to give effect to the requirement that the conviction carry a potential sentence of at one year or longer. The panel did not cite or discuss this requirement, and did not identify the maximum potential sentence for the respondent's misdemeanor conviction in its description of the case. (As a matter of California law, it appears that the maximum possible sentence of his misdemeanor conviction reduced from a felony under Calif. Veh. Code § 10851 and Calif. P.C. § 17(b) is a year rather than the standard six months - but the panel did not mention the applicable law or note the conclusion.)Assuming that the panel deleted this requirement, it clearly conflicts with the well-established rule that the full description of deportation or inadmissibility grounds must be applied under INA § 240A(b)(1)(C).13 Committed within five years. It also appears that the panel did not give effect to the requirement that the CMT was committed "within five years after the date of admission." The opinion does not cite or discuss this language from the deportation ground, or supply relevant information about the conviction such as the date the offense was committed. Because the statutory language combines "admission" with a substantive five-year requirement, it presents a real question in how it applies to a respondent who entered without inspection -- but it is not a question that the BIA is permitted to simply ignore. Instead, the Board must reach some decision that includes consideration of its two mandates: to the extent possible the entire text of the deportation ground should be treated as part of the description, and the deportation grounds in general should apply to a conviction of an applicant who was not admitted. Because the panel provided no discussion, it is not clear how it would treat a noncitizen who had been admitted. Would the full language of § 237(a)(2) apply to a cancellation applicant who overstayed a tourist visa, so that the conviction would not bar cancellation unless it had a potential sentence of at least a year and was committed within five years of admission? In that scenario, two persons who entered the U.S. - one on a tourist visa and one who entered without inspection - would have opposite case outcomes if each were convicted of a one-year misdemeanor committed six years after their arrival in the U.S. The person who overstayed could apply for cancellation, while the person who entered without inspection could not. Proposed solution for EWI applicants. Eliminating the five-year clause entirely in the case of applicants who entered without inspection, but applying it in the case of applicants who were admitted, arguably is not a permissible outcome under the plain language of the statute. In Gonzalez-Gonzalez v. Ashcroft, supra, the petitioner argued that a conviction of a noncitizen who, like him, entered without inspection never can be "under" a deportation ground. The court rejected this on the grounds that "[u]nder Gonzalez's construction, aliens who entered this country illegally would have greater rights to apply to the Attorney General for cancellation of removal on the basis of hardship than those who entered lawfully. The plain words of the statute do not support this conclusion in the present context." 390 F.3d at 652. Neither do the plain words of the statute appear to support the conclusion that aliens who enter illegally should have fewer rights to apply for cancellation than those who entered with inspection and overstayed. Congress intended for there to be a crucial distinction in how noncitizens are treated under the CMT deportation ground, based upon whether they do or do not commit a CMT for a five year period in the United States. There is no indication that Congress intended for this distinction to disappear when it provided that a conviction "under" the deportation ground will bar non-LPR cancellation. Rather than delete the entire statutory phrase "committed within five years . after date of admission," arguably the correct course is to construe "admission" as "entry" in the case of an EWI applicant. This will give meaning to the clear Congressional intent - which was that persons who commit a CMT soon after arriving in the U.S. are deportable, compared to persons who do not commit such an offense for five years or more - without creating an absurd solution that arbitrarily benefits or disadvantages EWI's. In other cases where "admission" and "entry" are at issue, the Board and federal courts have construed "admission" to avoid an absurd result. See, e.g., Matter of Rosas, 22 I&N Dec. 616 (BIA 1999) (in the case of a noncitizen who entered without inspection, "adjustment to permanent residency" will be construed as an "admission" so that the deportation grounds will apply); Ocampo-Duran v. Ashcroft, 254 F.3d 1133 (9th Cir. 2001). See also Shivaraman v. Ashcroft, 360 F.3d 1142 (9th Cir. 2004); Abdelqadar v. Gonzales, 413 F.3d 668 (7th Cir. 2005); Zhang v. Mukasey, 509 F.3d 315 (6th Cir. 2007). Matter of Shanu, 23 I&N Dec. 754 (BIA 2005), regarding when adjustment of status or other event is taken as an "admission" to start the five years referenced in the CMT deportation ground. The Ninth Circuit has held that being granted other status in the U.S. can be held the equivalent of "admission" for purposes of applying for cancellation for permanent residents under § 240A(a).14 The term "entry" is contained in the definition of "admission" at INA § 101(a)(13)(A).15 Or, counsel can argue that while in general the deportation grounds apply to an EWI, the deportation ground based on a single CMT conviction cannot apply to an EWI, because eliminating the limit that the conviction must occur five years after admission would frustrate the intent of Congress and wrongly grant an EWI fewer rights than a person who was admitted. This does not conflict with Gonzalez-Gonzalez, which held only that the deportation grounds in general may describe a conviction despite EWI status. The BIA or the courts may interpret the statute in other ways than this. However, the BIA's action in failing even to consider the descriptive language in § 237(a)(2)(A)(i)(I) constitutes misreading the plain language of the statute and abusing its discretion by failing to address a key issue.
b. This three-judge panel in Almanza-Arenas did not have authority to overrule other BIA precedent decisions, including cases published after Gonzalez-Gonzalez, that had addressed the same question and come to the opposite conclusion, holding that a CMT that comes within the petty offense exception is not a bar to non-LPR cancellation. The Almanza-Arenas panel did not distinguish, or even acknowledge the existence of, this on-point conflicting precedent. Therefore the prior opinions retain legal effect and cases must be resolved under them rather than Almanza-Arenas.Published in 2003, Matter of Garcia-Hernandez, supra, considered the same relevant fact situation as did Matter of Almanza-Arenas. In both cases the cancellation applicant had entered without inspection, and had been convicted of a moral turpitude offense with a potential sentence of a year (we will assume that this is the case in Almanza-Arenas), which also came within the petty offense exception to the moral turpitude inadmissibility ground. In Garcia-Hernandez the Board found that the applicant was eligible for non-LPR cancellation. While Garcia-Hernandez was published before Gonzalez-Gonzalez, it was cited in the first BIA case to interpret Gonzalez-Gonzalez, for the proposition that the entire text of a ground of deportability or inadmissibility should apply under § 240A(b)(1)(C). Matter of Gonzalez-Silva, 24 I&N Dec. 218, 219 (BIA 2007) (holding that a "crime of domestic violence" that occurred before the effective date of INA § 237(a)(2)(E)(i) is not "described under" that ground.) In 2008 the BIA relied on Matter of Garcia to hold that a CMT conviction did not bar eligibility for cancellation, again because it came within the petty offense exception to the inadmissibility ground. There the CMT conviction had a maximum possible sentence of six months. Matter of Gonzalez-Zoquiapan, 24 I&N 549, 554 (BIA 2008). In April 2009, Matter of Almanza-Arenas held that the petty offense exception was "irrelevant for purposes of determining whether he is eligible for cancellation of removal under section 240A(b)(1)(C)."16 In contrast, in Garcia-Hernandez and Gonzalez-Zoquiapan the Board had found the petty offense exception to be determinative. The Almanza-Arenas panel did not discuss or acknowledge any of the above precedent opinions. It did not distinguish their holdings based on the individual facts, or hold that Gonzalez-Gonzalez implicitly overruled one or the other.17 The three-judge panel did not have legal authority to overturn the panel decisions in Garcia-Hernandez and Gonzalez-Zoquiapan. A precedent decision may be overturned only by the BIA en banc18 or if the case is certified to the Attorney General.19 An agency may not reverse or decline to follow its own precedent without acknowledgement or adequate explanation. As the U.S. Supreme Court recently stated, "To be sure, the requirement that an agency provide reasoned explanation for its action would ordinarily demand that it display awareness that it is changing position. An agency may not, for example, depart from a prior policy sub silento or simply disregard rules that are still on the books." FCC v. Fox Television Stations, 128 S.Ct. 1800, 1811 (2009). Courts have regularly criticized the BIA as abusing its discretion and acting arbitrarily when it departs from established precedent without explanation. See, e.g., discussion and citations in Galvez-Vergara v. Gonzales, 484 F.3d 798, 802-803 (5th Cir. 2007). Under federal regulation the prior BIA precedent decisions still have legal force and should govern cases in removal proceedings. See Matter of E-L-H-, 23 I&N Dec. 814 (BIA 2005) (en banc), interpreting 8 CFR 1003.1(a), (g) ("[W]e find that under the plain language of the regulatory provision addressing the controlling effect of Board precedent decisions, and the recently promulgated case management regulations requiring prompt and timely adjudication of Board decisions, a Board precedent decision applies to all proceedings involving the same issue unless and until it is modified or overruled by the Attorney General, the Board, Congress, or a Federal court.").
c. The panel acted improperly because it provided no discussion or explanation of its holding that the respondent was statutorily barred from applying for cancellation, so that it is not possible to ascertain the legal standard it employed or how the standard applied to the respondent's case.Federal regulation provides that "the Board, through precedent decisions, shall provide clear and uniform guidance to the Service, the immigration judges, and the general public on the proper interpretation and administration of the Act and its implementing regulations." 8 CFR 1003.1(d). The BIA acted arbitrarily and abused its discretion by publishing an opinion that failed to provide the minimum information necessary to understand what legal standard it set out and to whom it applies. The Almanza-Arenas panel adequately discussed the basis for its finding that the deportation grounds in general apply to the respondent's conviction, under Gonzalez-Gonzalez. However, that finding was not sufficient to resolve the case. To hold that the respondent was statutorily barred from cancellation, the Board had to find that the respondent's conviction was "described" under the CMT deportation ground in particular. The Board provided no explanation whatsoever to support this finding. Specifically, it failed to state which descriptive language in the CMT deportation ground it employed, amended or discarded under § 240A(b)(1)(C), its rationale for this choice, and how the conviction at issue came within the chosen language. As discussed above, the CMT deportation ground at § 237(a)(2) provides that a single CMT conviction will cause deportability only if it carries a potential sentence of at least a year, and if the offense was committed within five years after admission. There do not appear to be published decisions as to whether or when the latter requirement can "describe" an EWI applicant's conviction under § 240A(b)(1)(C). It appears that the panel in Almanza-Arenas deleted the maximum potential sentence requirement, the "committed the offense within five years" requirement, or both. It is not possible to tell, because the panel does not cite or discuss either requirement, and did not provide information about the conviction that would show it had considered the requirements (i.e., it did not provide information on the maximum possible sentence for the conviction, or the date that the offense was committed). The panel stated only, "Because the respondent failed to establish that he was not convicted of a crime involving moral turpitude, he falls within the provisions of section 237(a)(2) of the Act." Now the government is using this single conclusory sentence to assert that any conviction of a CMT is a statutory bar to LPR cancellation. Applicants, and especially detained applicants, are suffering significantly because the government is advancing this unreasonable statement, based on the lack of any specific discussion in Almanza-Arenas. The BIA's failure to adequately explain its holding constitutes an abuse of discretion that requires reversal. See, e.g., Anderson v. McElroy, 953 F.2d 803, 806 (2d Cir. 1992) ("However, the BIA's cryptic order denying the stay, although ostensibly based on the full record, is devoid of any reasoning and thus also is an abuse of discretion. See Wong Wing Hang v. INS, 360 F.2d 715, 719 (2d Cir. 1966). Where the BIA's discretion is 'exercised irrationally or in bad faith' it is an abuse of discretion. Bertrand v. Sava, 684 F.2d 204, 213 (2d Cir. 1982). When faced with cursory, summary or conclusory statements from the BIA, we cannot presume anything other than such an abuse of discretion, since 'the BIA's denial of relief can be affirmed only on the basis articulated in the decision . . . and we cannot assume that the BIA considered factors that it failed to mention in its decision.' Mattis v. INS, 774 F.2d 965, 967 (9th Cir. 1985) (citation omitted)"). An administrative agency's failure to articulate a basis for a decision creates the kind of chaos, inefficiency and human suffering that we are seeing based on this opinion. "The administrative process will best be vindicated by clarity in its exercise ..[I]t will avoid needless litigation and make for effective and expeditious enforcement of the [National Labor Relations Board's] order to require the Board to disclose the basis of its order." Phelps Dodge Corp. v. NLRB, 313 U.S. 177, 197 (U.S. 1941). This rule is especially important where the decision conflicts with a precedent decision, where there is an even greater need for courts to understand the reasoning underlying a decision. The precedent decision does not lose effect just because a later decision, without explanation, departs from it. As the First Circuit stated regarding the BIA,
"Moreover, there is no way we can determine from the AWO whether the Board reviewed the case and found a legitimate way of distinguishing the Touarsi case in denying Haoud's asylum claim . Notwithstanding the fact that Haoud brought Touarsi to its attention, the Board failed to render a decision consistent with or fully explained as reasonably departing from its own precedent in Touarsi. As the regulation clearly sets out, "Except as they may be modified or overruled by the Board or the Attorney General, decisions of the Board shall be binding on all officers and employees of the Service or Immigration Judges in the administration of the Act." 8 C.F.R. § 1003.1(g). Haoud v. Ashcroft, 350 F.3d 201, 207 (1st Cir. 2003). d. This holding is not due deference from federal courts.An agency decision that departs from precedent without adequate explanation does not merit deference from a reviewing court. See cases cited in Part b, supra, and see generally discussion and citations in Marmolejo-Campos v. Holder, 553 F.3d 903, 920 (9th Cir. 2009)(en banc)(J. Berzon dissenting opinion); Shardar v. Att'y Gen. of the US, 503 F.3d 308, 314-16 (3rd Cir. 2007); Zhao v. US Dept. of Justice, 265 F.3d 83, 96-97 (2nd Cir. 2001) (failure to explain a decision adequately provides ground for reversal). Even absent the factor of conflicting precedent, a BIA decision that fails to adequately explain the basis for the decision is not due deference. See cases cited in Part c, supra.
e. The ruling in Almanza-Arenas was limited to its facts and to the arguments upon which it explicitly ruled. For example, the opinion does not govern cases in which a CMT conviction comes within an exception to the CMT inadmissibility ground and (a) the conviction has a potential sentence of less than one year; (b) the respondent was admitted to the United States; or (c) the respondent entered without inspection and the conviction was committed more than five years after entryWhere possible, along with contesting Almanza-Arenas counsel should distinguish the client's case and not permit the decision to be applied to cases outside the holding on facts or law. Some government attorneys are asserting that Almanza-Arenas stands for the rule that any CMT is a bar to cancellation, because any CMT is "described under" the CMT deportation ground. In fact, the BIA did not announce a legal standard to govern future cases in Almanza-Arenas, as it has the authority to do. In the one paragraph in which it considered the issue, rather than stating a rule such as, "Any moral turpitude conviction will come within § 237(a)(2) and bar an alien from § 240A(b)(1) cancellation," the Board stated only, "Because the respondent failed to establish that he was not convicted of a crime involving moral turpitude, he falls within the provisions of section 237(a)(2) of the Act." The Board did not discuss the situation of anyone other than Mr. Almanza-Arenas, did not overturn prior case law, and did not address all possible issues - or at least did not make its reasoning known - that might be contained in such a case. Therefore the Board did not rule on, and the case does not govern, at least three other groups of applicants who have been convicted of a single CMT offense. Recall that besides meeting one of the below criteria, the conviction at issue also must come within the petty offense or youthful offender exception to the CMT inadmissibility ground.20
Copyright notice is retained by ILRC. Reprinted with permission, (c) 2009.
End Notes1The regulation was published as 8 CFR 240.8 in 1997 and re-numbered as 8 CFR 1240.8 in 2003. 2See discussion at 488 F.3d 1131-1132. The court found that this based on the nature of the categorical approach, as set out in Supreme Court decisions Taylor v. United States, 495 U.S. 575, 599-602 (1990) and Shepard v. United States, 544 U.S. 13, 19-21 (2005). At p. 1132 the Ninth Circuit stated (emphasis in original):
[T]he record must be enough to prove that an alien either was or was not convicted of conduct which constituted an aggravated felony for purposes of the modified categorical analysis. When the record of conviction contains a charging document that lists conduct that does constitute an aggravated felony and conduct that does not constitute an aggravated felony, the conclusion is that the jury was not necessarily required to find the elements of the generic aggravated felony in order to convict on that document. Without more, it cannot be said as a matter of law that such conviction was for the generic crime. [citations]. Hence the conclusion that an inconclusive record of conviction is sufficient to demonstrate an alien petitioner was not "necessarily" convicted of the generic crime.3 See, e.g., Cisneros-Perez v. Gonzales, 451 F.3d 1053, 1058 (9th Cir. 2006) (where the government failed to produce conclusive documents under the modified categorical analysis to show the domestic relationship, and therefore failed to show that the respondent was convicted of a crime of domestic violence, the respondent was not barred from applying for non-LPR cancellation under the domestic violence deportation ground); Kepilino v. Gonzales, 454 F.3d 1057 (9th Cir. 2006) (government had burden to prove that applicant for admission was inadmissible under the prostitution ground, based on a conviction under a divisible statute), and discussion in Defending Immigrants in the Ninth Circuit, § 11.0 (2009, www.ilrc.org). 4The REAL ID text does not include a sentence from 8 CFR 1240.8(d), quoted above, that provides, If the evidence indicates that one or more of the grounds for mandatory denial of the application for relief may apply, the alien shall have the burden of proving by a preponderance of the evidence that such grounds do not apply. However, the fact that REAL ID did not include this sentence does not change the applicability of Sandoval-Lua. The preponderance of the evidence standard set out in that sentence in 8 CFR 1240.8(d) also applies under the REAL ID language at § 240(c)(4)(A), because it is well-established in immigration proceedings that the party charged with the burden of proof always must establish the facts by a preponderance of the evidence unless another standard is specifically indicated, e.g. clear and convincing evidence. See, e.g., discussion in Matter of Acosta, 19 I&N Dec. 211, 216 (B.I.A. 1985). Also, 8 CFR 1240.8(d) continues to govern applications filed today. The regulation has not been amended or withdrawn since REAL ID, and does not appear to be ultra vires to the statute. 5 See 8 USC § 1229b(b)(1)(C), barring relief based on conviction of an offense under 8 USC §§ 1182(a)(2), 1227(a)(2), or 1227(a)(3). Sections 1182(a)(2) and 1227(a)(2) include most of the crimes grounds of inadmissibility and deportability, respectively. Section 1229(b)(1)(C) includes a waiver for certain convictions of a crime of domestic violence, where the defendant was primarily a victim of domestic violence. See paragraph (b)(5). 6This distinction has a long history in case law. In Almanza-Arenas, supra at n. 3. the BIA stated that it saw no reason to disturb the IJs finding that the statute was divisible in this way. This is apart from the issue of accessory after the fact as an element of § 10851. 7INA § 212(a)(2)(A)(ii)(II), 8 USC § 1182(a)(2)(A)(ii)(II). While the opinion did not discuss the maximum possible sentence or sentence imposed for the respondents conviction, the parties appear to agree that he came within the petty offense exception. 8INA § 212(a)(2)(A)(ii)(I) 8 USC § 1182(a)(2)(A)(ii)(I) provides an exception for a CMT committed while under the age of 18, if the offense was committed and the person released from any resulting imprisonment at least five years prior to the date of the current application, and if the person has committed no other CMT offense. This exception is used by persons who were convicted as an adult for offenses committed while under 18. If the disposition was in juvenile delinquency proceedings, it is not a conviction for immigration purposes and the youthful offender exception s not needed. 9See first paragraph of INA § 237(a), 8 USC § 1227(a), providing Any alien (including an alien crewman) in and admitted to the United States shall, upon the order of the Attorney General, be removed if the alien is within one or more of the following classes of deportable aliens 10In addition, the opinion contrasted § 240A(b)(1)(C) with the equivalent bar to VAWA cancellation, which applies only if the noncitizen actually is deportable or inadmissible for a conviction; see INA § 240A(b)(2)(A)(iv). The court stated, When Congress desired that the cancellation of removal statute be interpreted as Gonzalez-Gonzalez suggests, it knew how to do so. Id. at 653, n. 3. 11INA § 237(a)(2)(A)(i), 8 USC § 1227(a)(2)(A)(i). Notice that a conviction with a potential sentence of exactly a year can be a basis for deportability, but not for inadmissibility if it comes within the petty offense exception. 12543 F.3d at 1168. In Mota the conviction was for an offense held to be a crime of child abuse, which is contained in the same deportation section, INA § 237(a)(2)(E)(ii), 8 USC § 1227(a)(2)(E)(ii), and has the same effective date, as the crime of domestic violence discussed in Gonzales-Silva. 13Requirements pertaining to actual or potential sentence are a common part of inadmissibility and deportability grounds, and the Board has applied sentence descriptions before under § 240A(b)(1)(C). In Matter of Gonzalez-Zoquiapan and Matter of Garcia-Hernandez, the Board held that the requirement in the petty offense exception that an offense have a potential conviction of one year or less was within the description of the inadmissibility ground. Subtracting the sentence requirement would entirely gut the ground of inadmissibility based on conviction of two or more offenses of any type with an aggregate sentence of at least five years imposed, under INA § 212(a)(2)(B). See Ramos-Godinez v. Mukasey, 295 Fed. Appx. 733 (5th Cir. 2008) (multiple convictions with an aggregate sentence of at least five years imposed, as described in INA § 212(a)(2)(B), are held to bar cancellation under § 240A(b)(1)(C)). 14Garcia-Quintero v. Gonzales, 455 F.3d 1006, 1015-18 (9th Cir. 2006), construing admitted to include a grant of Family Unity status for purposes of establishing seven years residence required for LPR cancellation. See also Yepez-Razo v. Gonzales, 445 F.3d 1216, 1217 (9th Cir. 2006) (Family Unity beneficiary was lawfully residing in the United States from the date of her acceptance into the FUP, which rendered her eligible for a § 212(h) waiver from removal). 15INA 101(a)(13)(A), 8 USC § 1101(a)(13)(A) provides: The terms admission and admitted mean, with respect to an alien, the lawful entry of the alien into the United States after inspection and authorization by an immigration officer. 16Almanza-Arenas, 24 I&N Dec. at 776. 17Given that Almanza-Arenas said nothing about its own reasoning, it would have been difficult to distinguish the reasoning of the other opinions. The panel could have attempted to distinguish the facts from other prior decisions, but it did not. It might have argued that the Ninth Circuit decision in Gonzalez-Gonzalez implicitly overruled Matter of Garcia-Hernandez, but in fact the Ninth Circuit has not yet spoken as to how it will construe the CMT deportation ground, and Garcia-Hernandez did not discuss the deportation ground at all so that it is difficult to know whether it assumed the deportation grounds in general did not apply to a noncitizen who entered without inspection, or found without discussion that the conviction was not committed within five years of admission and was committed before the effective date of the domestic violence ground. It might seem easy to distinguish the 2008, post-Gonzalez-Gonzalez decision Matter of Gonzalez-Zoquiapan from Almanza-Arenas, since Mr. Gonzalez-Zoquiapans conviction had only a six-month maximum sentence and so should not be held to be described under the moral turpitude deportation ground, with its requirement that the conviction have a maximum possible sentence of at least a year. However, it appears likely that Almanza-Arenas did not apply the requirement that the conviction must have a potential sentence of at least a year, so that rule would not be a basis to distinguish the cases. 18See 8 CFR 1003.1(a)(5) providing in pertinent part that the Board may consider any case en banc, or reconsider as the Board en banc any case that has been considered or decided by a three-member panel. 19See 8 CFR 1003.1(h). 20As discussed in Part B.1, supra, a conviction that is described under the CMT inadmissibility ground will bar non-LPR cancellation, even if the offense is not described under the CMT deportation ground. If the offense comes within the petty offense or youthful offender exception, it is not described under the CMT ground of inadmissibility. See INA § 212(a)(2)(A)(ii), 8 USC § 1182(a)(2)(A)(ii) and see Matter of Garcia-Hernandez, Matter of Gonzales-Zoquiapan, supra.
About The Author


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What is "Citrus Greening"?
Citrus greening is fatal.
It is also known as Huanglongbing (HLB) or Yellow Dragon Disease. While the disease poses no threat to humans or animals, it has devastated millions of acres of citrus crops throughout the United States and abroad.
Citrus greening is spreading worldwide.
It first reported to have occurred in Asia during the late 1800s and the disease has already caused devastation in Asia, Africa, the Arabian Peninsula and Brazil.
Has already killed millions of citrus plants in the southeastern United States!
First discovered stateside in Florida in 2006 and has now spread across the entire state.
Untreated Citrus Greening kills 100% of the trees it infects.
Spreads via a disease-infected insect.
the Asian Citrus Psyllid has put the future of America's citrus at risk. Infected trees produce fruits that are green, misshapen and bitter, unsuitable for sale as fresh fruit or for juice. Most infected trees die within a few years.
The Asian Citrus Psyllid is no bigger than the head of a pin. The infected insect spreads the disease as it feeds on the leaves and stems of citrus trees. Once the Asian Citrus Psyllid picks up the disease, it carries it for the rest of its life.

subset: commoncrawl


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Bromley High Street is a pedestrian walkway in London, England with all the High Street shops and areas to sit and relax. A market takes place every Friday and Saturday.
For action shots, we can gain vehicle access if necessary. The top right hand side of Bromley High Street is known as Market Square and often has a mini carousel. To inquire about filming at this location, visit LocationsHub.


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This tour is a great all round day out. Interact with Australia's most iconic animals including Koalas and Kangaroos and then experience all the magic of the Blue Mountains world heritage area.
Highlights & Inclusions
Experience Featherdale Wildlife Park
Featherdale is home to Sydney's best Australia's wildlife experience. The park's focus is on Australia's truly unique wildlife. The park is home to over 2000 animals from over 200 different species. Take that special photo with the Koalas; hand feed the parks friendly Kangaroos and wallabies. Featherdale is a great stop on any Blue Mountains tour and means you get bot the wildlife experience you are after as well as the magical Blue Mountains all in one day.
Visit secluded lookouts away from the crowds
The Blue Mountains is one Australia's most visit tourist's areas. With that in mind there are plenty of people up there, which means plenty of crowds. With this Blue Mountains tour we get away from the crowds in our small tour vehicles and visit vantage points away from the large coach companies. This is truly the way the Bluer Mountains should be appreciated and all our experienced guides have there own secret spots when it comes to the places they visit.
Spend time in charming village of Leura
Of all the Blue Mountain villages Leura is considered the most beautiful of them all. The town is centered on a shopping strip know as Leura Mall. Home too many great fashion boutiques, home ware stores, restaurants and superb coffee shops. The town is also famous for its flowering gardens. During different parts of the year private residence will open gardens to be viewed by the public. Leura is great stop on this Blue Mountains tour.
Three Sisters rock formation
The Three Sisters is without doubt the most iconic landmark in the Blue Mountains. A unique rock formation that sits proudly overlooking the stunning Jamieson Valley. Learn about the aboriginal dreamtime stories about how they were formed. No Blue Mountains tour is complete with seeing them for yourself. All Blue Mountains tours we operate will visit this must see sight.
Guided walk in the Blue Mountains National Park
The Blue Mountains is home to some of the best hiking trails in all of Australia. Our walks on our Blue Mountains tours our tailored each tour to suit our clients fitness level. Many great sights in the Blue Mountains can only been seen from taking some of these tracks. We discover tranquil waterfalls, temperate rainforests and unique plants and animals on all our Blue Mountains tours that in include a walk.
Reviewed 2 weeks ago "Fantastic Blue Mountains Tour!"
I was in Sydney for work for a limited time, and my 16-year-old son accompanied me so we could sight-see. Since my son loves to hike, I really wanted to add a visit to the Blue Mountains. James did a FANTASTIC job tailoring our day to our interests. He took us on some great hikes, to some out-of-the-way lookouts, to a spot where we could see a huge number of kangaroos in their natural habitat lounging in the sun, and a fantastic spot for lunch, and we were away from the typical tourist areas just as we asked. James was also very flexible with our pick-up in Coogee but drop-off in the CBD at the height of rush hour. Perhaps most importantly, James was really engaging, especially for my son who is quite shy. I HIGHLY recommend Cloud 9 tours; we had a great experience for a really reasonable price for a personal, two-person tour.
Reviewed 20th September 2016 "Probably THE way to see the Blue Mountains"
James is an absolutely fantastic host. He is punctual, polite and knowledgeable. If you want to avoid the crowds is this the way to see the Blue Mt. James gives you a tailor-made tour according to your wishes or his recommendations (Which I strongly suggest you'll follow). All with 1st class service. I'm totally sure that James made the Blue Mountains a lot more impressive than any coach-tour would be able to do. Including lunch in a cozy peaceful location. He made this tour a day to remember, and there is no doubt in my mind that I'll choose his company again. And even his prices are fair :)
Reviewed 22nd May 2016 "Blue Mountains Day Trip"
A day tour to the Blue Mountains with my daughter. It was a brilliant day our guide was informative punctual and a lot of fun.
We were away from the main tourist buses and could really experience the vastness of the area.
Thoroughly recommend the company.
Reviewed 2 August 2014 "Hunter valley and blue mountains -amazing trips"
Thank you so much James for an amazing tour to the hunter valley! It was such a fantastic day and the group absolutely loved it! The week after we took another trip to the blue mountains with Keith and again absolutely amazing and very professional! I would recommend this company to all my friends and family! Thanks again for such an amazing experience!


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Marvel Comics has released an exceptionally cryptic Avengers-themed teaser image promoting a project to debut in December. No creative teams or characters are named or shown, with the image consisting solely of the Avengers' iconic "A" targeted in what appears to be crosshairs.
The publisher promises more, if not all details to be announced Tuesday, September 13 at 3PM Eastern/Noon Pacific. CBR will be covering the press event and announcement LIVE.
Doomsday Clock #12 Puts a Superman Twist on an Iconic Watchmen Image


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Ah, Botswana. The setting of one of my favourite series of books The No.1 Ladies Detective Agency by Alexander McCall Smith. Books that led me to try Redbush tea and fantasize about running my own detective agency. :D
I chose this recipe for two reasons. One, there's half a bag of polenta in the kitchen cupboard that wants using up. Two, I need to have another go at liking polenta. Fingers crossed!
Tomato chutney
Yep, three ingredients ^_^
Make up the polenta according to the packet's instructions.
After a few minutes cooking and stirring vigorously (where's JD when I need him) it should look like this (the consistency of mashed potato).
Spread the polenta in a baking dish of some sort.
Cover with a layer of tomato chutney. This chutney is startlingly red in colour. I should've made some chutney myself, I'm ashamed.
Cover with a layer of grated cheese.
Pop in the oven at 200C for about 15 minutes until the cheese has melted properly.
I served it with baked chicken breasts and peas.
The melted cheese and chutney together were delicious. But that's where the deliciousness ended. Polenta isn't for me. It's bland and the consistency is like mashed potato but only in a way that makes you wish you were eating mashed potato instead. Neither of the kids wanted to try it. In fact they wanted to try it so little that Leigh came up to me while I was taking the ingredient picture and asked what I was making. After I explained she said she didn't want to try it. Before I'd even made it!! (I could make a whole other blog post about how annoyed this makes me feel). I tried the polenta in various combinations with the cheese, chutney, peas and chicken but I didn't really like any of them with the polenta. So I just gave in and ate the cheese and chutney combo off the top and threw the polenta away. Sorry Botswana :)


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Changing your business: Do you need evolution or revolution?/
As we head towards the end of the financial year, it's a good time to ask yourself whether you're pleased with how business has been for you this year. Not just in terms of your financial results – although those are obviously of paramount importance – but also in terms of how close the business you're running is to the one that you really, truly want.
Are you spending your days doing things that make you and your team feel alive and in alignment with your purpose? Helping the people you feel most drawn to help? Creating and selling products and services you're proud of and excited by? Having the kind of impact you'd like to?
If not, what kind of changes or reinvention of yourself or your business will be required in order to realise your dreams or bring them closer to you to taking shape?
In my experience, making a decision to consciously transform your business often involves making changes on two different levels: the internal and the external. How do you know where to start, and whether your goal is to support evolutionary change or take a big, revolutionary leap forward?
Changes in self-perception are often evolutionary
For many small business owners (and especially those who consider their work to be an aspect of their spirituality or service to the world), the first transformation needs to take place internally, and is often evolutionary.
For example, if you're a natural health practitioner, it might be the gradual awareness that you don't feel like a novice any more, or that where once you were on a mission to save the whole world, you're now mostly interested in working in a certain way or with people with particular types of problems, belief systems or attitudes.
Or it might be the dawning realisation that if you want to grow your sales and help as many people as you can, you're going to need to find a way to spread your message further, wider and more effectively than you have been (for instance by stretching yourself to take on writing or teaching work) .
In larger organisations, a similar transition occurs, but tends to be driven by strategic management decisions regarding business priorities, often preceded by new consumer or market insights that drive changes to the allocation of resources and budgets.
Whichever form they take, and regardless of whether they occur organically or as a result of consciously pushing yourself to step up and embrace something new, these types of internal, evolutionary changes to how you perceive yourself in relation to your business and your clients can be profound and powerful.
Internal changes necessitate changes to your marketing
As those internal shifts occur, your business will often start to change too. And commonly, you'll start feeling that your existing marketing is no longer reflective of who you are and what you have to offer. That you've outgrown it, it's become outdated, or that it's not helping you build the kind of business that you actually want.
That's where the external work comes in: making changes to the aspects of your business that are overtly visible to your clients and prospective customers. It might mean that it's time to freshen up your branding, revise your website, take a new direction with your blog, or launch new products, packages or services.
Here, you have the choice of reinventing your business in a way that's either evolutionary or revolutionary.
Changing your marketing infrastructure? Be revolutionary, and move fast
Often, when it comes to large marketing investments like launching a new logo, revamping your packaging or replacing your current website, revolution is the way to go.
This enables you to leapfrog over the several generations of changes that have occurred in technology and design trends since you last invested in these areas of your marketing infrastructure, and at the same time, allows you to create a tangible shift in the way your brand is perceived by your clients and prospective clients.
A lot of thought and strategising should go into the development of your new marketing infrastructure, but it's best done over a concentrated period of time, and behind closed doors out of sight of your audience (and competitors).
Once it's ready to roll out, execute as quickly and completely as possible, so your new brand image rapidly becomes the new normal for you and your audience.
Transitioning into a new niche? Focus on evolution, and get your customers involved along the way
On the other hand, some evolutionary shifts in direction are best executed over a longer period of time, and sometimes within public view.
For example, let's say you're currently operating a general practice in your chosen modality, and over the long term, you want to move away from seeing clients and into offering online courses. In that case, you probably won't want to take the revolutionary step of ceasing to market your existing business at the start of the transition period.
Instead, your focus should be on evolution. For example, you might want to dial up your social media presence and / or make gradual changes to the themes you blog about. That way, you can continue to maintain your dialogue with your existing client base, while also reflecting your new focus and attracting a new audience who are specifically interested in the direction you're business is headed.
Integrity and authenticity are everything
Whether the changes you're making are evolutionary or revolutionary, the new marketing face you present to the world should be authentic and consistent with the internal shifts that have occurred or are underway.
If they're not, you'll end up with marketing that consists of exaggerated claims or other forms of smoke and mirrors, and it's quite likely that you're potential clients will sense that something in your marketing is a bit off, and be wary rather than trusting of you.
Need help?
If you're looking to make some changes in your business and would like some assistance, please get in touch with me. I offer copywriting and marketing consulting to natural health businesses of all sizes, and also offer marketing coaching to established natural health practitioners who have a strong vision for their business and the determination and passion to bring it to life.


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"I love my beautiful black crystal drop earrings! They are beautiful, and priced really well! " --Susan


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We are Tyler Brewster & Shana Louallen, New York City natives with a combined 20+ years of experience in public school education. We believe that communities deserve access to quality resources and educational tools.
Founded in 2016, Peer Connect is an education consulting firm with a focus on restorative practices and culturally relevant pedagogy. We believe the best way to dismantle the school-to-prison pipeline is to reshape education communities towards relationship building, youth leadership and conflict resolution skills using a restorative lens.
We've worked with over 200 NYC educators and community members. Our goal is to do more than decrease the number of suspensions. We believe in the power of positive and sustainable school-based structures. In addition to providing foundational education, we support community members to implement their newly-learned skills. As a result of our trainings, communities have seen significant shifts in key school metrics linked to school climate.


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Headend Tech
As a Headend Tech I currently maintain 10 different headend sites across southwest Indiana. I am responsible for the reception, and distribution of off-air and satellite programming to the outside plant utilizing coaxial cable and fiber optic transmission technologies. This includes installation, construction, operation, and repair of all equipment associated with the headend and signal distribution network.


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Auburn Reporter
State Sen. Joe Fain (R-Auburn) was joined by nearly 400 supporters at his general election kickoff Tuesday morning in Auburn.
The breakfast at Emerald Downs included speakers from the community and an address by Fain.
Fain is completing his first term representing the 47th Legislative District, which includes the cities of Auburn, Kent and Covington. Fain faces Democratic challenger Carol Barber in the Nov. 4 general election. Fain won the August primary with more than 66 percent of the vote.
Fain was joined by many elected officials representing South King County. Attendees included former state Sen. Steve Johnson, Auburn Mayor Nancy Backus, Auburn Councilmembers Largo Wales, Yolanda Trout, John Holman, Wayne Osborne, Bill Peloza, and Claude DeCorsi, as well as Covington Mayor Pro Tem Jeff Wagner, Covington Councilmember Wayne Snoey, Kent City Council President Dana Ralph, and other elected officials and business and community leaders from the area.
Ralph spoke about the relationships that Fain has made with the community, other elected officials, and young people in South King County. Referring to a recent trip she made to the robotics club at Kentridge High School
"Senator Fain's involvement in the program was one of their talking points for joining the club," Ralph said. "Joe is everywhere, from community events to our local schools, and he makes an effort to build a real connection with our local students. It shows how much Joe cares."
Auburn School District Superintendent Kip Herren cited his close work with Fain over the years.
"He is able to bring people together. He can solve problems. He can find shared interests in the middle of conflict," Herren said.


text: New York, NY — Edelman Arts in collaboration with The Durst Organization and The Port Authority of NY & NJ presents a public art collection curated for One World Trade Center. One World Trade Center marks the beginning of a new future in the landscape of New York architecture in itself, but also in collaboration with the spirit of art and with it, the diversity of people in this great city. The collection includes a monumental painting by José Parlá, two paintings by Doug Argue, two paintings by Fritz Bultman, a group of seven works on canvas by Greg Goldberg, and a towering sculpture by Bryan Hunt. The collection will remain on view in the North, South, and Sixty Fourth floor lobbies of One World Trade Center, where the installations will be enjoyed by a projected 30,000 visitors per day.


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Premieres Monday, Feb. 1, at 10/9c
All people can trace their roots to the savanna of East Africa, the home of one of the first members of the human species — Homo habilis. Archaeologist Bill Schindler and survival instructor Cat Bigney face what early man did as they work together to survive in the wild savanna just as these primitive people did 2.6 million years ago — without any weapons or fire. But they soon find that living like our ancestors is harder than they expected.


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Hello my lovelies!
Some time ago I was invited to L'Oréal event where the new products were presented. The products I really felt in love were the facial masks in three variants. Anyone who knows me knows how much I love all beauty products and especially masks. So today I would like to talk about them and share with you my experience.
The price of mask is about € 10 and they are in a very elegant glass container. There are 50 ml contained, this should be enough for 10-15 applications. Usually I use 3 different masks three times a week and mostly evenings after a long day at work. As a tip: you can also apply all three masks at the same time in particular areas (but don't mix them together!).
How to use: First of all you need to clean your face and only after that apply the mask evenly in a thin layer on your face. After about 15 minutes (when the mask is dry) you can remove it with warm water or with a damp towel.
Now let's talk about each mask separately. Every single mask has different features and benefits.
1. Detox mask (the black one) consists of activated carbon and three pure clays, which are meant to act like a magnet to absorb any impurities from your skin. This mask detoxifies the skins surface and cleanses the pores, so after applying the mask your skin will breathe again. Visible effects: more clear and pure skin with healthy glow and a fresh feeling.
2. Exfoliating mask (the red one) with red algae extract exfoliates and refines the complexion. Pure clays and volcanic rock work like a peeling to exfoliate dead skin cells and to remove dirt and oil from your skin. Visible effects: smooth and refined skin texture and such a beautiful glow
3. Glow mask (the green one) with eucalyptus extract aims to brighten, mattify the complexioned exfoliate your skin. It has been created with 3 clays combined with red algae extract, which known for its brightening properties. Visible effects: softer, smoother and brighter skin with tighter Pores.
I've become a real fan of all three masks so I will definitely going to buy them again! Have you already tried these products?
Hope you enjoyed this review and would also like to know anyone's thoughts on it!
Thursday, December 8, 2016
Beauty: Detox for your skin with L'Oréal
Hello my lovelies!
40 comments
Ich stehe jedes Mal in der Drogerie vor den Masken, konnte mich bis jetzt aber noch nicht dazu durchringen eine zu kaufen - ich glaube das muss ich tatsächlich endlich mal tun! :)ReplyDelete
Liebe Grüße
- AnonymousDecember 8, 2016 at 11:52 AM
Die Detox Maske kenne ich und finde sie richtig toll. Die anderen beiden habe ich noch nicht ausprobiert .-*ReplyDelete
Melanie / www.goldzeitblog.blogspot.de
Cant wait to try themReplyDelete
Keep in touch
My face could definitely use a detox mask and L'oréal is such a great mask.ReplyDelete
x Karen
Great review!!!! Nice products!!!!ReplyDelete
Have a wonderful weekend!!!
Besos, desde España, Marcela♥
Great post girl!!ReplyDelete
Awesome products !ReplyDelete
Thanks a lot :DReplyDelete
My face already needs a detox mask. Sounds amazing :D
NEW TIPS POST | Facial Skin Care: Benefits of Vitamin C.
Instagram ∫ Facebook Oficial Page ∫ Miguel Gouveia / Blog Pieces Of Me :D
Tolle Review :)ReplyDelete
Ich habe schon lange überlegt mir eine zu holen. Nachdem ich mir das jetzt durchgelesen habe, werde ich auch endlich in der Drogerie zu greifen.
xx Katha
Love the review, thanks for sharing might have to purchase it now HAHA xReplyDelete
I always find glass containers to be very elegant. Lovely packaging indeed! Plus, these masks really seem perfect for the skin.ReplyDelete
Sehr schöne Produkte, die werde ich mal im Auge behalten!ReplyDelete
Liebe Grüße
Jimena von littlethingcalledlove.de
totally loving these masks, especially the detox one!ReplyDelete
Inspirational and stylish wall art for your home!
I would love to try these masks !ReplyDelete
Beautiful pics babe !
Never heard of these L'oreal masks but they do look very interesting.ReplyDelete
I should try them out myself and see if they work
Tolle vielversprechende Produkte. Danke für diesen Beitrag, denn ich kannte diese Masken bis dato nicht. Hab einen schönen Abend, xo Julia http://fashionblonde.deReplyDelete
what cool products!ReplyDelete
these sound so awesome! I really wanna give it a try!ReplyDelete
This looks amazing !!ReplyDelete
I'm obsessed with face masks! I want try these!ReplyDelete
Glad I came across this post. I have been searching for a really good face mask because I have adult acne. Would be happy to try this to see if it helps.ReplyDelete
Amazing! Thanks for sharing!ReplyDelete
Lauren Elizabeth
Petite in Pearls
Great post!ReplyDelete
Good vibes, FOX
check out my blog www.rochellefox.com.au and my latest VLOG
I really want to try these out now! They're also at a great price point and I really need the detoxifying oneReplyDelete
Characters & Carry-ons
I have tried the Glow mask and loved it! My skin felt so good after using it!ReplyDelete
<3 Leni
Hey das sieht doch gut aus, vlt probiere ich die auch mal aus, wenn ich vom Hotel Seiser Alm zurück binReplyDelete
Ich bin gerade auch nach der Suche nach einer leichten Pflege und das klingt wirklich gut.ReplyDelete
Liebe Grüße,
Thanks, Lovely Information. It is Really Amazing. If you want to tour a la india from chile. see here.ReplyDelete
Wow! I love these pictures! The masks look so interesting! <3ReplyDelete
So many dresses waiting for your option,if you want to be a beautiful lady,please choose usReplyDelete
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RV gets Ishaani on wall. She turns her face, crying. He puts ice in the glass of water, and gives it to her. He says he knows she feels really hot, that is why she was putting her clothes down. He is going to check the AC, then says what will happen of her in one glass. He hands a full jug to her. She pushes it away, and says she won't drink water from him even if she is dying. He says she surrendered herself to him, and now doesn't want to drink water from him. He says his baba is right, no one can understand wives. She asks him not to call wife. He says she is his wife, but he will call him Ishaani. She forbids him to take her name, he asks shall he call Billi, and teases her for being a wild cat. He goes to change, as eh knows he gets flu real quick. She drapes a dupatta around herself, goes to the vase bottle and drinks from it.
In the house, Baa says it is so hot and asks Disha to bring the AC's temperature down. She asks to tell her mother she has arranged for an extra bed for her. Pratik and Darwesh come and tell her that they will live with Sharman in a bedroom.
RV comes and tells Ishaani that there is bath-robe in the bathroom, She might wear it. She denies, he says a wild-cat will look awkward in bathrobe. She opens the wardrobe and finds a nighty in it. RV comes to her back, and says this is honeymoon suite, here people come to celebrate wedding night. Ishaani says this belongs to the girl he was about to marry. RV says it is destiny, which wanted them both to get married. Ishaani puts it inside and says she won't wear it. RV asks what is she disliking, that they weren't for her, or were they for someone else. He says he won't mind of she wears them, but she might get flu, cold and even pneumonia. He sits on the bed, with TV open. Ishaani goes into the bathroom, and see the bathrobe.
Chaitali brings Baa, milk with Kaisar. Baa thanks her, that she started doing her old habits. Chaitali tells them that she started AC in her room as well. Amba watches this, Lakshmi says this is the right time to show them their place as RV and her husband both are out.
Amba comes inside, and shuts the AC off. Baa asks what is she doing. Amba says this is her house.
Now, she and all of them must get out. Baa says has she forgotten her son brought them here. Amba drags Baa. Lakshmi stops them all inside, while Amba drags Baa to the stairs. Parul watches this from a side. Amba takes Baa, she gets rid of her hand and asks where is she taking her. Amba says she is taking her to her real place and brings her to servant quarter. She says she will live here, now.
Now, she and all of them must get out. Baa says has she forgotten her son brought them here. Amba drags Baa. Lakshmi stops them all inside, while Amba drags Baa to the stairs. Parul watches this from a side. Amba takes Baa, she gets rid of her hand and asks where is she taking her. Amba says she is taking her to her real place and brings her to servant quarter. She says she will live here, now.
Ishaani comes draped in bath-robe. RV watches her, while she hides behind the sofa. He looks away. She comes out, and she looks at her legs. She asks why is he staring at her. He says he is imagining, it seems the cat fell into the milk bowl, and smiles. She sits on the sofa, covering herself. She says firstly she has an head ache, now she is feeling dizzy.
Everyone comes to the quarter. Amba tells her that her family will also live here. She says this is a place for humans, she also lived here. Cold breeze come from window, they must consider the store as their own room. Her son thinks with her heart, but she never takes the dust to her head. Baa told her that she deserved to live here, but today Amba says she doesn't deserve to stay here even. Amba tells them, they will have to work like servants for her.
She warns them of changing her decision, otherwise and leaves.
She warns them of changing her decision, otherwise and leaves.
All the family is worried to know about it. Lakshmi appreciates Amba, Amba says she just showed them their place. She wants to show all the fear and pain, she used to feel years ago.
Ishaani sleeps on the couch, while RV on bed. He notices she was about to fell off the bed and brings the quilt for her, then makes her up on the couch. She turns, her face visible. He looks at her and smiles. He says she didn't say anything to her, though he tried not to love her. But he couldn't help loving her, he caresses her hair. She hits him with a fist, he fells down. She says he hit her, she will kill him now.
PRECAP: Ishaani poses to be a cat for RV, he fears her and asks her to sleep.
Ishaani wakes up, and says to RV that she will hit her. He was worried, is she alright. She was in a different state, and said she will kill him sunk in water he poured on her. He calls her name. She was posing to be a cat. He said he is her husband. She said he is Shaitan, and she is the naani. He corrects her as Ishaani. She says he is chai ki patti. He reminds she drink tea in morning. She says at night, she only drinks blood. He called her cat, now she won't leave him. RV ran in front of her, while she gets him when he was about to fell down. She fells on his chest, winds her hands on the back and fells asleep. RV hugs her in return.
He helps her to lie on the bed, and caresses her forehead. He puts the quilt on her. He says he promise that he won't let her past ruin her, not even CHiraag.
Baa and everyone was in much pain, as they prepared for beds. Baa says this is their house. Falguni says they will leave here, in the morning. Baa says that now Amba must leave the house. Payul brings food for them. Darwesh invites her inside, saying they were playing Antakshari. She apologizes, that since they hadn't eaten anything se she brought food. They were all hungry and heads to eat.
Amba comes there, and asks Parul if she brought the stale food. Parul stammers, but Lakshmi says she told them to give them stale food. Amba says to Lakshmi that she doesn't know about the rules, but they all know about the rules of the house. She asks how dare they even see the fresh food, but since today is her son's wedding, they must eat it.
From tomorrow, they will have to earn this food. They won't get safe. Falguni says they will do what she will say, but requests her to leave. Amba tells Lakshmi to make them sleep early, as the servants wake up before the masters here. Lakshmi appreciates Amba, and says she must have took class of Falguni as well. Amba laughs, and says she is angry at most. Hansa won't like it, if she makes up with Falguni. Chaitali comes to Amba, and says she gave her a lot, she will do all her house hold and asks for a separate room. Amba tells Lakshmi to give a room without AC.
RV was wearing shoes, when Ishaani wakes up. She sits on the bed, them thinks how she came here on the bed. He says he will show her. She forbids him to come near. She asks he only thinks about it, only. He saw she was asleep, couldn't do anything. She feels the head ache, watches a bottle she drank from. He thinks it was the juice Chaitali had given him, and smiles.
Amba comes to wake them next morning, and says here the servants have to work from 7 o clock. Baa says RV brought them here, she will complain that she will tell him what his maa is doing to his mota bapu's maa. Amba laughs, that will he scold her. She is his mother, he gave them place to live, not her place. She will complain RV, such that he will throw them on the road. RV bought their office, to take revenge. They must think what he will do to them. She instructs everyone about the household work, and says to Baa to come to her room, as she will only do her work.
Ishaani says he mixed something in the juice, so that she got unconscious. He says he doesn't need to mix anything in it, to do anything to her. He sits by her side, and says he enjoyed what ever happened. Ishaani asks what happened. RV says no one tells about such things. Ishaani sees marks on RV's neck.
PRECAP: Amba asks what happened on RV's hand or neck. He says a wild cat came to their room.
Source: TELENOVELA


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The video is a breif presentation about helicopter scenic flights over the Nordfjord and Jostedal Glacier area executed by the company Helikopter Utleie AS based in Stryn, Norway. This flight is performed by the helicopter type AS350, the company now operate only Eurocopter EC130B4 and EC120B, both wellknown for their low noise emission and high passenger comfort.
Read more
Fly time: 20 min.
Fly time: 30 min.
Fly time: 1 hour
Fly time: 1,5 hours
Fly time: 2 hours
Fly time: 5 hours


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About Me
Hello and welcome to Mike's Tech Blog. These tech notes are often the result of my attempts to set up or install something. Often after many hours of searching the internet and collecting bits and pieces of information, I invariably wish all of these pieces were in one place. I figure if I have looked into something once, I don't want to have to go through that again. Additionally, I might as well share my "stumbling around" with others so others won't have to.
I have many varied interests. They range from Computers, as well as networking. I enjoy photography, and music. I am also a ham radio operator (My call is WB8ERJ), and have been for the last almost 40 years. I work at a radio station, WVMC as their engineer, as well as Mansfield Christian School, and Discovery School as an I.T. guy. This gives me many opportunities in the area of Microsoft products, Linux, and networking. I also have a degree in Electronics, which I also use at WVMC in Mansfield, Ohio.
If you have any questions, comments, or just general hate mail, feel free to Email me.
I hope you find this blog useful.
— Mike Thompson


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Samhain Blessings
Traditionally Samhain is a Celtic festival that observes the time when the veil between worlds is at its thinnest. Here at Celtic Fusion, we decided to get into the spirit with a bit of a ceremonial inspired photo shoot in collaboration with doorusphoto.net. To do this, we incorporated many symbols in our photographs that are traditionally associated with the observance of Samhain:
Fire -
Samhain was historically seen as the darkest night of the year - mainly because every household extinguished their fire for the night in an attempt to hide from the spirits that are able to walk in the land of the living. Fire is still heavily associated with the celebration, however, especially those who are seeking to communicate with the dead.
Apples -
Apples were often seen as the fruit of the other world and were used for magic and fortune telling. Traditionally, on the night of Samhain, if a young woman looked into a mirror while eating an apple, she would be given a glimpse of her true love - or the god of the dead.
Caves -
We shot in a particularly special set of caves, but many caves throughout Ireland are speculated to be the entrance to Tír na nÓg, or the other world. Because the veil is said to be thin, standing in a cave on the evening of Samhain might result in some unwanted (or wanted?) visits.
Skulls -
Because Samhain is known for its associating with death and spirits, there is no wonder why skulls would be an important part of its symbolism. Oftentimes, farmers would throw the bones of slaughtered livestock into the fire before it was extinguished for night.


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Below are the permissions that Keepsafe Photo Vault on Android request and examples for how we use them.
- Photos/Media/Files: this lets you upload photos, videos and files from your storage to Keepsafe, while also giving you the ability to delete the footage from your storage.
- Camera: this lets you take photos and videos directly within Keepsafe Photo Vault.
- Contacts: this lets you share photos, videos and files from your Photo Vault to your friends.
- Identity: We use your accounts to uniquely identify your account without an email address. (make signin/up easy)
- Storage: We need a place to keep your private files that no other app has access to & the storage permission gives us access to a private storage directory.
- Device ID & Call Information: We use your device ID to identify who you are by your device even though you may not be signed in with an email account.
- Device & App History: When your device boots, we use this permission to make sure that Keepsafe has not been tampered with.
If you have further questions about our Android permissions please reach out to email@example.com.


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Q: Do I have to be a member of PAS to attend PASIC?
No. VIP, All Access, and International members receive significantly discounted pricing for 4-Day and 1-Day passes, which include access to all concerts, clinics, master classes, labs, workshops, panels, presentations and performances.
Those who wish to participate as part of the Marching Festival events, except DrumLine Battle, require VIP, All Access, or Group Membership.
Tickets for individual sessions and concerts are available for purchase, along with entrance to the International Drum and Percussion Expo, and membership is not required for those individual purchases.
Q: How do I register for PASIC?
You can register online, mail in the registration form, or call the PAS office at 317-974-4488. You can also register onsite. The earlier in the year you register, the larger the discount on registration fees.
Q: What forms of payment do you accept?
If you pre-register for the event, we accept personal checks, business checks, school P.O.s and credit card (VISA, MC, AMEX, DISC). If you are registering onsite, only cash and credit cards will be accepted.
Q: Do I have to register ahead of time?
No. While pre-registering will save you time and money, you do have the option of registering onsite. Forms will be available at the PASIC registration desk in Indianapolis.
Q: What is your cancellation policy?
Refunds are available prior to October 1, with a cancellation fee of $50. There are NO refunds for cancellations that occur after October 1 (this includes individuals who are offered badges from exhibitors). If you wish to cancel your registration, please call the PAS office at 317-974-4488.
Q: Does PAS offer professional development credit hours for attending PASIC?
Yes. Professional Development Credit Log hour sheets will be made available prior to PASIC.
All sessions may be considered for professional development credit. Individual states vary. After attending your last session, please go to the PAS Show Office to receive an authorizing signature and seal.
Q: What do I do if I lose my badge?
If you misplace your badge, you will need to get a replacement from the registration desk. There is a $100 fee to replace a missing badge.
Q: What is the PASIC Sound Policy?
PAS has a strict Sound Policy during the convention. Please be considerate of others and adhere to the following rules:
- Instruments are not to be played for more than 20 seconds continuously.
- Volume level must be moderate (mf) or lower.
Failure to adhere strictly to this policy will result in the following:
- 1st Offense: Warning. Offenders Badge will be punched.
- 2nd Offense: 24-Hour Expulsion from the Exhibit Hall.
- 3rd Offense: Expulsion from the Exhibit Hall for the entire convention.
- Failure to cooperate with security will result in permanent expulsion from the entire convention and possibly future Percussive Arts Society events. All decisions by security staff are final. No refunds will be issued.
The above stated sound policy will be enforced and supported by the following measures:
- Sound monitors will be on duty in the exhibit hall during exhibition hours.
- Announcements in regard to the sound policy will be broadcast over the public address system in the exhibit hall at regular intervals.
Additional measures include:
- Sound monitors will be clearly identifiable with uniformed clothing.
- Sound monitors will be equipped with decibel meters and radios.
- Information about the sound policy will be disseminated to all exhibitors prior to the convention.
- Exhibitors that use amplification in their booth, including amplified TV monitors, are required to use headphones.
It is the intention of the Percussive Arts Society to find a balance with all exhibitors to allow the best possible experience for the largest amount of attendees. With everyone's cooperation we can enjoy an environment that is acceptable for all and does not require punitive action by the Society against its members, either sustaining or individual. Thank you for your support and effort to make PASIC another success.
Q: How many people will be at PASIC?
Over 5,000 people attend PASIC annually.
Q: Can I take pictures/video/recordings at PASIC events?
While you are welcome to take pictures (no flash please), video and audio recordings are NOT allowed in any performance/clinic/meeting. A special media badge is required for those doing recordings, and PAS reserves the right to stop and remove any individuals who ignore this policy.
Q: Are committee meetings open to all PAS members?
Yes. PAS committee meetings are a great way to be involved as a PAS member. All committee meetings are open to any registered PAS member that wants to attend.
Q: I would like to help out at PASIC. What are my options?
If you are an active member of PAS, the Logistics Team allows you to help out at PASIC, receive a free t-shirt, attend for free, and have the chance to win prizes at the end of the convention. For more information on the Logistics Team click here.
Those who aren't members of PAS are encouraged to join our Volunteers and Marching Crew. These individuals will also receive a free t-shirt, along with free admission to PASIC.
Q: When is the schedule for PASIC available?
While the dates for each year's PASIC are usually available a few years ahead of the event, the lineup of concerts and clinics are posted in late August. However, the schedule is always subject to change. Be sure to download the Guidebook app for the most up-to-date scheduling info. There will also be a schedule available in the PASIC program, and on the printable grids, which will be available for download on the PASIC webpage.
Q: Where are all the events held?
The location of all the events and meetings vary from year to year, depending on the city where PASIC is being held. Details on which rooms the various clinics, concerts, competitions and meetings will be held in are available in the PASIC Guidebook app, the PASIC Program, and the PASIC grids. PASIC 2018 will take place in Indianapolis, Indiana at the Indiana Convention Center.
Q: How accessible is the convention from the hotel/airport?
Again, this answer varies on which city PASIC is being held in, but PAS always make an effort to make sure there is a good quantity of hotels within a short distance to the convention center. Shuttles to and from those hotels to the airport are also a strong consideration of ours. For more detailed travel information on this year's PASIC visit our Travel Information and City Guide section.
Q: Is there an official hotel for PASIC? Are there group rates available?
Yes. There are several hotels offering discounts for PASIC attendees through mci USA, the official PASIC Housing Bureau. You may make PASIC hotel reservations by calling the PASIC Housing Bureau at 877-557-5332 (US & Canada) or 972-349-5856 (International). For groups reserving more than 10 rooms, you must call the PASIC Housing Bureau for assistance. To avoid being charged a no-show fee from the hotel, you must cancel your reservation prior to the cancellation policy stated on your hotel confirmation.


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I decided to create a new series exclusive to unemployment tips. Thus, the unemployed folks reading my blog on a regular basis might find this helpful. Thus, here it is.
Unemployment Tip # 001 – Before applying for unemployment benefits, always ask yourself which unemployment rule or rules you are depending upon to grant your application for benefits.
For most folks, Minnesota statute 268.095 is very impactful. For others, issue spotting is going to be more cumbersome based on the events that led up to a job ending.
You know how to find me.


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Welcome to motorbike solicitor. Over the years we have acted for many motorists and in particular, motorcyclists.
Leading our 'developed' speciality in motorbike related legal representation is Chris Johnson. Chris is a motorbike fanatic who carries the mantle of being a Solicitor. Chris is a seasoned motorbike rider, with almost as many years legal experience as he has motorcycle experience!


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get in touch!
Fancy a chat about a potential collaboration or expedition? Or maybe your looking for a guide to take you on that long dreamt of mountain adventure? Give me a call on +447925812700 or drop me an email at email@example.com . Alternatively, fill in this form and send it over.


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Are you a closet designer? Do you like to mix and match images, textures, patterns, decor? Do you "pin" on Pinterest? Why not put those talents to work and enter Minted's First Inspiration Board Challenge?! They have $3400 in prizes available with three weekly winners through November 18th. Click on the link and follow the instructions, and most of all have fun.
P.S. If you enter, come back and leave a comment with the link to your board so I can check it out!


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It may have been that sacred springs and wells were understood by our ancestors to originate in the Otherworld, flowing from the earth into this world at special places, bringing healing, inspiration, wisdom and connection to deities.
Gold boat from the Brighter Hoard Co. Derry, thought to be a votive offering to Manannán Mac Lír.
Numerous deposits of votive offerings were made during the Bronze and Iron Ages in the lakes, rivers and bogs of Ireland indicating that water was an important part of ancient peoples' lives and beliefs.
In Ireland there remain wells that are pre-Christian in origin
St. Mobhi's Well, also known as Fionn MacCumhail's Well.
Photograph courtesy of Gary Branigan - Gary's book is available HERE
The construction has lead archaeologist Geraldine Stout to suggest that it may have been built around the same time as the great mound at Newgrange.
and famous wells of mythology whose over flowing created the rivers of the island.
Trinity Well, the source of the Boyne.
One such well was Tobar Segais, said to be surrounded by nine hazel trees.
When the hazelnuts, containing wisdom, fell into the water they were eaten by the Salmon, a creature who appears throughout Irish tradition associated with great knowledge.
An Bradán Feasa, The Salmon of Wisdom courtesy of Séighean Ó Draoi.
More work by Séighean HERE
The legend of Tobar Segais explains that the only visitors allowed to approach the Well of Knowledge was Nechtan and his three cup bearers.
However, Boann, Nechtan's wife, defies this taboo and visits the well where she walks around it three times, tuathal, anti-clockwise, against the course of the sun.
Unfortunately Tobar Segais, like most wells, should only be circled in a sun-wise direction and her offence causes the waters to rise up, drowning and dismembering Boann and creating the River Boyne, which bears her name.
Boann - the goddess whose essence forms the river.
More about Boann HERE
More about Boann HERE
We cannot know the ancient rituals or beliefs associated with sacred springs and wells but the spiritual traditions which have grown around them may offer a glimpse into the past.
Tobar Lugna, Co. Offaly.
With the arrival of Christianity many wells were consecrated by the early saints of Ireland and folk traditions were incorporated into the Christian rituals.
These older folk beliefs are thought to contain traces of much earlier practices of pilgrimage and veneration at well sites.
Irish Roman Catholicism today includes devotions which take place on the feast day of the patron saint of the parish, these are known as 'patterns' and many are linked to rituals at wells.
Sign explaining the pattern at 'The City' and holy well, Co. Kerry.
Part of these prescribed rituals involved pilgrims 'paying the rounds', reciting a rosary whilst circling around the well site a number of times, always revolving deiseal, in the sun wise direction.
Crutches and circling ritual at Doon Well, Co. Donegal. ©firstname.lastname@example.com
Often this circling is carried out three times, at others nine, with water from the holy well sipped at the end of the rounds.
Occasionally holy water was taken away in bottles to be used at graves, in healing or sprinkled at the four corners of the home for protection.
In the past patterns often ended with drinking, dancing and fighting and were so popular in rural areas that the church began to forbid these gatherings, describing the folk belief in the powers of the wells as pagan.
Bullaun stone at St. Manchan's Holy well, Co. Offaly where sunlight and shadow creates the 'mystical fish'.
Some healing wells were understood to contain a mystical fish, often a salmon or a trout, which appeared at certain times when the water was especially potent.
As a sacred symbol the fish is known in both Irish mythology and Christianity.
At St Kieran's Holy Well, Castlekieran, Co. Meath, three trout are said to appear just before
midnight on the first Sunday of August.
For those seeking to be cured the presence of the fish is taken as a sign that the healing
will be effective.
Offerings continue to be made to wells, usually after drinking the water, with coins, holy medals, pieces of cloth and flowers left by pilgrims.
Occasionally a pin or coin is put into the well water itself.
Offerings at St. Fachtnan's Well on the Burren.
Offerings of daisies and rose petals at Ladywell, Co. Galway.
Another element of many well sites is the presence of a special bush or tree, usually a whitethorn, ash or oak.
Rags are often secured to the branches of these trees as an offering to the well or in the case of healing wells, in the belief that as the cloth rots away so does the illness.
Whitethorn & offerings at one of The Seven Blessed Wells of Killeigh, Co. Offaly.
The well dates to pre Christian times.
Holy wells are not only accompanied by trees.
There are numerous locations recorded as having some sort of stone nearby and this combination of water, tree and stone was incorporated into Christian ritual.
Stone, whitethorn and well at Tobereenatemple, Co. Clare.
Stones found near wells may consist of standing stones, enclosures or natural outcrops.
The City, Co. Kerry.
The City, Co. Kerry
The stones may be used as altars or utilised in 'patterns' with marks being scratched on the surface to indicate points within the rounds.
It is common to find a boulder with one or more depressions near to holy wells, known as a bullaun stone, although the formation and original function of bullauns is unknown.
Bullaun stone at Saint John's Well, St John's Point, County Down.
The presence of a well, a tree and a special stone marks these locations as sacred.
Unlike the great community gatherings at bonfire festivals of the past, perhaps our ancestors also visited these places alone, in silence, or circled sacred wells chanting or murmuring prayers as many do today?
The atmospheric Ráithin Well, Co. Clare.
Sitting by stone, whitethorn and well the modern world drops away and we are left with nature,
deep peace and the spirits of the place.
St Fachtnan's Well, a place of solitude and silence.
This is the second of three posts about Sacred Water, you can read the first HERE
St Fachtnan's Well, a place of solitude and silence.
This is the second of three posts about Sacred Water, you can read the first HERE