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On the afternoon, I would get drunk and eventually text him or call him although Occasionally I really could resist the urges to get more than three days. No matter how drunk I get, I send him adore. I burst in his inbox telling him how wonderful and how unique he is.
Be honest about what you want in a sense but consider exceptions depending on what is ultimately available for you. It's true, you may want a version but obviously have good looks and /or lifestyle yourself and that is going to be an choice that is exceedingly restricted, if you don't live in a city. On dating programs, most of the 19, plus, those types of girls are not going to be. Social access is the trick to becoming involved with them.
When a girl finds a guy on the internet about meeting, that she thinking, that's something which likely warrants a mention. If one of those girlfriends would be the exact same girl who did not respond to you personally, and you were dumb enough to email a second time to her to phone her a C- U- Next- Tuesday, congratulations- you saved the price of a dinner.
The line is the line of love. They say that the more these lines curve upward into the finger, the deeper the ability to appreciate people. Check better if you require accuracy, but the main objective is to have pleasure, because too much truth could ruin the" dream" .
I was quite tempted to accept this route, but for whatever reason I was fortunate enough to catch myself. After holding space for all those feelings and acknowledging them for what they were, that the feelings started to dissipate a bit and my mind stopped racing. Then, by some little stroke of fortune, a few very curious thoughts came into my head: " Just because this guy is charismatic doesn't mean that everyone will forget about me. It is definitely not meant to be between us, if that girl is a better fit for this guy then.
After some discussion about the weather, something which I would encourage all women to be on if they want to have something to discuss a Norgate casual sex negative consequences, Dave opened the door and walked me to the Norgate MB how to fuck local sluts in my area for free. We drove to the lake.
She local sluts Halfway Depot state unless you are a psychic there is no way you will be able to predict everything. There'll be instances where you state something which offends her or someone might interrupt you. Having game is not about memorising the top lines to use, it's about overcoming tough situations.
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The next day, Saturday, she wanted me to come over and consented to make dinner. She was in the kitchen cooking, As soon as I came. I gave her a hug from behind and she looked a little unaffectionate which was bizarre.
Favourite Hot Spots I was able to love driving to and from the bar, but since the crash I have to walk. Having no car means I could take my trip to the airport, watching airplanes since they fly in, and taking numbers.
Ultimately, you want to meet with the love language demands of your partner spontaneously and creatively, without relying upon a custom activate or intending it for a particular time of day. However, for the time being, just begin with one brand new love speech behaviour to get the ball rolling.
Attempt not to accept the identity tests are great. Given that the coordinating calculation's do not seem to demonstrate improvement over conventional possess a receptive perspective toward someone who might not fit the statement but might somehow be an prospect.
Take time to answer her message, and LET HER HAVE SOME SPACE, if she doesn't seem curious. What you DO NOT want to perform is really being needy and too stubborn, thus don't request an appointment immediately, do not pressure her too much.
What should you do? You use your phone. That kind in your phone whatever it is show her and you want to tell her. Asyou're in a nightclub you can tap on her shoulder( it will not seem creepy, so waiters do it all of the Norgate craigslist prostitutes now when they wish to experience a meet local teen sluts Norgate of people) and show her your phone.
Areas of Comfort: Considering your candidates cannot be hundred percent perfect, make a record of five habits which you are able to tolerate( although some individuals may see it as a deal breaker) , e. g. , smoking, drinking, race, religion, fashion sense, personal grooming.
But it's easy to get it wrong if you do not know how to perform it correctly. Everyone tells the strange fib from time to time but these are mostly tiny lies. You are going to want to have the ability to tell if they're married, normally just making up things as they go together, or knowing whether they might be cheating on you when local sluts to know someone. So I am teaching you this so that you may avoid any possible misunderstandings or even heartbreak.
He's your Spiderman, you're Peter Parker. He has sex and just wears clothes that are better. Go with it. You can not really be this man, If you don't have superpowers and a private jet. But you can embody him.
Lastly keep things light. Do not get too heavy on any topic. It's an instant delete when men start professing there undying love into a person before meeting. Also I would stay away from discussing politics. Whatever your views are about politics are, I have never believed they are of any benefit at all up to a date or Norgate Manitoba on a date.
The good thing is that you can satisfy with a lot of women. The thing is that you may meet a great deal of new women. The woman may not be snapchat sluts local Norgate Manitoba a opportunity because she might have some flaws which you would rather not cope with by you. You meet a different and another and may just go back online and the grass will be greener and another one will probably be nearer to perfection. In the view of the girl, it is the identical story. In addition the dating can wear out you. I admitit can be a beating.
This is the way the urban Norgate Manitoba frre sex dating sees it: Forgiveness, the best thing you can ever do for the following person( and yourself) , when, local sluts when they have hurt you so badly you thought you would die, you can move on and enjoy again. . .
Always. The dates that fall through the cracks are likely to get picked up by someone else by whom they will be regarded as thousands anyhow. Bear in mind this, for it will allow you to seek your tens out of thousands.
You may need to express these feelings of not being okay in a counseling or therapy session, with lifeline friends, or maybe in self- introspection. You will need to somehow" carry out the psychological garbage of the past" so you are able to stop letting it control and weight you currently. Permit these old messages of inadequacy verbalize, and express ventilate to broadcast. Then give up themmove them from your path toward boosting your self- concept.
You may not be a coder or have the time to create and fine- tune scripts to nudge your possible games, and most websites search for and disable spiders anyway. But while you may not have the ability to replicate the speed and efficacy ofa'bot, it is possible to help make certainyou're getting noticed by investing time on your searches. Start with browsing profiles, with the filter set to" Best match" then browse through every game, one after another. Do not worry about reading their profiles; you wanting to show up in their customer's log. Whether match percent that is carefully handled and your profile will draw on them their fascination should entice.
Now what that means is the amount ought to be less or equal to the amount of effort she is putting into the date. If you can really master that balance, you will get the girl you want.
But don't put yourself up to be harmed for more than necessary. What is the secret of keeping yourself from being ruined through this? Friends can be fantastic as they do not dissuade you.
Stupid Versus Ignorant This is just another tool. Recognize the difference between stupidity and ignorance. Stupidity is. Unfortunately, the word is used as a weapon rather than as a description. On the other hand, means I have not yet heard something that I may have the ability to learn.
Bill would pore over them into his quest to invent the ideal dessert buffet and to cook the best roast and saved every holiday issue of Martha Stewart Living, Gourmet and Bon Appetit. The Christmas Eve dessert buffet, hosted for each of their own families and our friends, included cheesecakes, piles of truffles, bowls of trifle, decorated cookie platters and at least 1, but usually two cakes or holiday themed confections. Finally Alex came to the realization that her place in the family required her to produce the show stoppers. She became the mistress of this marzipan penguins dancing atop snowman- topped cupcakes, the tree of polar bear and the ice online dating japanese Norgate MB igloo, along with also the martini glass parfaits. Which would be time consuming Norgate Manitoba, but we were also Christmas Day Central for my family and Alex grandparents on her father's side. Bill was an opportunity celebrator in Christmas and they were welcomed by him to the fold. While Alex and I had something of a say at the online dating tips buffet, Bill had inviolable and strict requirements for its Norgate Manitoba tender online dating app. The centerpiece was the local expensive but superb butcher, an expensive cut of beef from Joe's Meats. This cut of beef could be served with numerous sauces of cream and butter and horseradish and chives and. . . And the veggies would be refreshing and could be dressed with more buttery sauces! And the breads ordered from a Norgate Manitoba bakery that is distinctive and would be fresh! And the potato gratin are a recipe every year but have to be produced with cream! And in years when there was lobster bisque it would be made from scratch by boiling lobsters that were genuine and sieving the broth! This was all that was allowed to be performed the day before, although the bisque may be done the day before.
Keep in mind that your goal on your profile would be to sell yourself by identifying yourself. Eye- roll checks be certain thatyour'offering' is attractive, and complies with your real local sluts Norgate traits.


text:
The largest of the Dodecanese Islands, Rhodes Greece has known many civilizations throughout its long history. Inhabited since the end of the Neolithic period (4000 BC), the city of Rhodes prospered for centuries during its Golden Age. In 164 BC Rhodes lost its independence and became a province of the Roman Empire during which time it developed into a renowned center of learning for arts and science.
During the Byzantine period that followed, Rhodes became an important military base and in 1309 BC it was sold to the Order of St John of Jerusalem. The order was originally founded to provide care for pilgrims to the Holy Land but ultimately evolved into a military unit. During the reign of the Knights of the Order of St John, the fortifications were expanded and reinforced.
When the Arabs attacked in the 7th century, they occupied the island for several decades. Then, in 1522 it was the Ottoman Turks who captured the city and during their rule Rhodes lost much of its international character.
But the Italians took over in 1912 and set about radically transforming the city into much of what you see today. They completed extensive infrastructure works like roads and electricity, rebuilt the Grand Master's Palace, preserved the remains of the Knights' period and removed much of the Ottoman additions.
It was just after 9:00pm when my short flight from Crete touched down in Rhodes. I made my way outside the airport and caught the local bus into town (a nice money saver at 3 euro versus 27 euro for a taxi). Twenty minutes later I was stepping off the bus downtown.
I knew my hotel, the Oktober Rooms, was pretty close to the bus station and with the help of Google maps on my phone I was there in less than 5 minutes. It turned out to be a great budget hotel, very modern and new and in a terrific location.
One day in Rhodes
I just had one full day on the island of Rhodes and after some thorough research I had a pretty good idea of what I wanted to do:
1) explore the well-preserved old walled city of Rhodes and
2) see the town of Lindos, which I'd read was the island's most beautiful town.
I began my day with a walk along the marina toward the Old Town. The first order of business was buying a ferry ticket to Symi for the following day. Along the waterfront there were endless counters offering ferries and boating day trips and I finally found the one I needed, Dodecanese Seaways.
There were two ferry options to Symi in the morning, a 9:30am departure that made a stop on the southern end of Symi to visit the Panormitis Monastery before continuing on to town and a direct ferry at 8:30am. I wanted the 9:30am but it was totally booked so I had to settle for the direct at 8:30am.
With that done, I wandered along the water until I came to the imposing entrance to the Old Town known as the Marine Gate. Since this was my first visit to the Dodecanese Islands, I was initially surprised by the Muslim influences in the Old Town of Rhodes until I read a little more about the island's history of various conquerors.
The Arab and Ottoman periods resulted in the construction of a number of mosques that still stand within the Old Town walls.
The streets were very different from anything else I'd seen in Greece, it actually reminded me the most of the Bascarsija neighborhood in Sarajevo. Not at all what I expected but definitely beautiful.
The Old Town was full of the usual tourist shops, cafes and restaurants but despite that I was easily drawn into its medieval feel as I wandered along the Street of the Knights.
I worked my way over to the town's crown jewel, the Palace of the Grand Masters. The most important monument from the period of the Knights' rule, the palace was neglected by the Turks (who turned it into a prison) and was nearly blown up along with the Church of St. John in 1856. An enormous reconstruction project began under Italian occupation and today its Gothic architecture towers over the Old Town
For my final stop in the walled city, I wanted to get an aerial view. Rumor had it the best views over the city were from the belfry of the clock tower. Built at the end of the 7th century, the clock tower sits on the ruins of the Byzantine tower connected with the Palace of the Grand Masters.
It was also virtually destroyed in the 1856 explosion but was lovingly restored to its original Baroque glory and now offers the best viewpoint in the city.
It was a great spot to get a look over the city and make sure I hadn't missed anything important on my hasty tour of town before catching the bus to Lindos.
The Acropolis of Lindos
Considered the most picturesque town on the island of Rhodes, Lindos owes its beauty to the strict regulations of the Archaeological Society which controls all development in the village. The traditional white stucco with bright blue trim are the classic Greek façade I've come to expect from the islands but hadn't seen yet on this trip.
A little over an hour after departing Rhodes Town, the bus rounded its final corner and my first view of Lindos was awe-inspiring. The whitewashed village is literally sandwiched between a stunning arc of beach below and the towering Acropolis of Lindos above.
I knew right away that I wanted to see both the beach and the Acropolis up close but from my current position that would translate into a lot of ground to cover. Sigh. More hiking.
The bus dropped me off at a road above the village so I decided follow the road down and start with the beach. There were actually two beaches and they were both lovely but packed with tourists. Time to take a walk up to the village.
For those not willing to do all the walking necessary to get around Lindos, not to worry, there were lots of donkeys available to get you up those steep hills. A nice photo op, surely, but I figured I could handle the walk.
The village, aside from the expected assortment of souvenir stands, was majestic in its architectural purity and a gorgeous example of a Greek village straight out of central casting.
As I wandered its narrow arteries I found a sign pointing the way to the Acropolis and followed the path. Before long I was climbing up above the village and entering the medieval walls of the Castle of the Knights. The Acropolis of Lindos contains the ruins of Rhodes' three Dorian towns including the especially impressive Sanctuary of Athena.
The views from the Acropolis were incredible from all sides and I could easily see why people consider Lindos the island's most beautiful town. By the time I made my way back down to the village it was nearly 5pm and I was hoping to make a 5:30pm bus back to Rhodes town with a long uphill climb to the bus stop still ahead.
I made it just in time and got one of the last seats on the very crowded bus back to town.
Once back in Rhodes town, I grabbed dinner at a café within the walls of the Old Town and walked back to the hotel. That 8:30am ferry to Symi would come pretty early in the morning but my anticipation for my next stop had been growing for days so I was excited to move on to island #2 in the Dodecanese.
Next up, Symi!

subset: commoncrawl


text:
A German businessman has purchased the virginity of a Ukranian escort for £1m at an online auction.
Katya from Ukraine is 19-year-old and a member of the Cinderella Escort company which matches girls with rich people looking for s*x.
Katya's virginity was placed on the site, on sale for £84,120. However an auction ensued and the German businessman won with a £1m bid.
He beat a lawyer from New York and a singer from Tokyo.
The winner also added that he's "open to marrying Katya and supporting her financially with a monthly budget of 10,000 Euro (£8,500) in the future,"
Speaking about why she's selling her birginity, Katya said: "I have thought several times about not selling my virginity after all. It's definitely a tough decision, for the simple reason that it's irreversible.
"But it's a win-win situation. The choice between losing my virginity to someone I love, and to have lost forever my chance to win the million is hard.
"However, I think the probability is higher that you will regret not accepting the money, because a future boyfriend will most likely leave you at some point." she added.
Source: GhanaCelebrities.Com


text:
Rolex Airking 14000 slate grey dial from 1991.
Rolex Airking 14000 slate grey dial from 1991.
Almost all watches offered on NLWatch have been serviced and checked by our watchmakers. This is also the case with this Rolex Airking 14000 gray slate dial from 1991. The watch is really in new condition, despite its 29 years of age. There is absolutely no stretch on the bracelet. The slate gray dial is really in mint condition and a pleasure to look at. The watch case has a diameter of 34MM and can therefore be worn by a woman or a man. The 3035 movement runs fantastic. Long story short, a nice watch for everyday use and many next generations.
€ 3999,- I'm interested in this watch


text: IBO – BEACON ———– Working together is key to success. When everyone is on the same team, going in the same direction, success is a guarantee. Driving business success with the emphasis of shared knowledge, gives the extra push to the finish-line. ———– If you would like to visit IBO Beacon please contact Michelle Stallone 516-801-4779. ———— IBO – Beacon Meets Wednesdays @ 7:30 – 9:00am Imperial Diner Address: 63 W Merrick Rd, Freeport, NY 11520 ———– The Members: ———– ———–


text:
Subsidiary says to sell 15 bln rbl new shares to Russian Railways
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- Home
- People
- Facilities
- Publications
- 2017 -
- 2014 - 2016
- 2009 - 2013
- 2004 - 2008
- Before 2003
- Proceedings
- Projects
- Useful Links
- ChE Graduate Program Info
Publications - 2014-16
Publications in 2014
H-K Lin, Godiwalla SY, Palmer B, Frimberger D, Yang Q, Madihally SV, Fung K-M, and Kropp BP. Understanding roles of porcine small intestinal submucosa (SIS) in urinary bladder regeneration: Identification of variable regenerative characteristics of SIS. Tissue Engineering Part B –Reviews. 20(1):73-83. 2014.
Podichetty JT, Madihally SV. Modeling Growth Medium Perfusion-induced Porous Scaffold Deformation. Journal of Biomedical Materials Research-Part B. 102(4):737-48. 2014.
Shahini A, Yazdimamaghani M, Walker KJ, Eastman MA, Hatami-Marbini H, Smith B, Ricci JL, Madihally SV, Vashaee D, Tayebi L. 3D Conductive Nanocomposite Scaffold for Bone Tissue Engineering. International Journal of Nanomedicine. 9(1):167:181. 2014.
Yazdimamaghani M, Vashaee D, Assefa S, Walker KJ, Madihally SV, Köhler GA, Tayebi L. Hybrid macroporous gelatin/bioactive-glass/nanosilver scaffolds for immunocompatibility, controlled degradation behavior, and antimicrobial activity for bone tissue engineering. Journal of Biomedical Nanotechnology. 10(6):911-931. 2014.
Yazdimamaghani M, Vashaee D, Assefa S, Walker KJ, Madihally SV, Köhler GA, Tayebi L. Green synthesis of a new gelatin-based antimicrobial scaffold for tissue engineering. Materials Science and Engineering C9: 235-44. 2014.
Podichetty JT, Bhasker PR, Khalf A, Madihally SV. Modeling Pressure Drop Using Generalized Scaffold Characteristics in an Axial-Flow Bioreactor for Soft Tissue Regeneration. Annals of Biomedical Engineering. 42(6):1319:1330. 2014.
Sharma AM, Kumar A, Madihally SV, Whiteley JR, Huhnke RL. Prediction of biomass-generated syngas using extents of major reactions in a continuous stirred tank reactor. Energy. 72(1): 222–232. 2014.
Publications in 2015
Podichetty JT, Bhasker PR, Singarapu K, Madihally SV. Multiple Approaches to Predicting Oxygen and Glucose Consumptions by HepG2 Cells on Porous Scaffolds in an Axial-Flow Bioreactor. Biotechnology/Biongineering.112 (2), 393-404. 2015.
Walker KJ, Madihally SV. Anisotropic temperature sensitive chitosan-based injectable hydrogels mimicking cartilage matrix. Journal of Biomedical Materials Research-Part B.103B(6):1149-60, 2015.
H-K Lin, Madihally SV, Palmer B, Frimberger D, Fung K-M, and Kropp BP. Biomatrices for bladder reconstruction. Advanced Drug Delivery Reviews. 82-83: 47-63, 2015.
Pai KK, Singarapu K, Jacob JD, Madihally SV. Dose Dependent Selectivity and Response of Different Types of Mammalian Cells to Surface Dielectric Barrier Discharge (SDBD) Plasma. Plasma Processes and Polymers. 12(7):666-77, 2015.
Khalf A, Singarapu K, Madihally SV. Cellulose Acetate Core-Shell Structured Electrospun Fiber: Fabrication and Characterization. Cellulose. 22 (2): 1389-1400. 2015.
Khalf A, Singarapu K, Madihally SV. Influence of Solvent Characteristics in Triaxial Electrospun Fiber Formation. Reactive and Functional Polymers. 90:36-46. 2015.
Tormos CM, Abraham C, Madihally SV. Improving the Stability of Chitosan-Gelatin Based Hydrogels for Cell Delivery Using Transglutaminase and Controlled Release of Doxycycline. Drug Delivery and Translational Research. 5(6): 575-584, 2015
Publications in 2016
Book Chapter: Tormos CM, Madihally SV. Chitosan for Cardiac Tissue Engineering and Regeneration. in Part 2: Chitosan for tissue engineering and regeneration of other tissues and organs. Edited by Jennings JA, Bumgardner JD, Elsevier Publishing. pages115-143
German CL, Madihally SV. Applications of Computational Modelling and Simulation of Porous Medium in Tissue Engineering. Computation. 4(1), 7.
Roehm K, Hornberger J, and Madihally SV. In Vitro Characterization of Acellular Porcine Adipose Tissue Matrix for Use as a Tissue Regenerative Scaffold. Journal of Biomedical Materials Research –Part A. 104A: 3127–3136.


text:
CHARLIE CUNNINGHAM has unveiled an official video for HEADLIGHTS, a stand-out track from his recently released album PERMANENT WAY. The video arrives as Charlie and his full live band prepare for an extensive UK headline tour. Speaking about the track, Charlie shares, "I'm quite a private person outside of performing. There is some autobiographical stuff in the lyrics, but it flits in and out quite a lot; it's much more about people generally and their interactions".
The slick video, by Sam Harper, features Charlie himself in a constantly moving and evolving world of juxtaposition, confusion and resolution. Watch and share the video via YouTube here:
The release of the HEADLIGHTS video offers a refreshing look at PERMANENT WAY. Released in June to widespread acclaim, the songs on Charlie's second studio album offer boosted colours and dynamics but still retain his achingly personal appeal.
As a follow-up to the release of PERMANENT WAY, Charlie has reimagined some of the tracks for release as a live studio EP. The FLESH AND BONE STUDIO SESSIONS EP will be released on 29 November via Infectious / BMG and two of the live studio versions – DON'T GO FAR and HUNDRED WAYS – are available now in digital format here:
After a busy summer of touring and recent runs across North America and Europe, CHARLIE CUNNINGHAM takes to the road again in November for a UK headline tour. Full dates as follows.
Sat 02 BRISTOL Redgrave Theatre (SOLD OUT)
Sun 03 LEEDS City Varieties Music Hall
Mon 04 GATESHEAD Sage 2
Wed 06 MANCHESTER Stoller Hall
Thu 07 OXFORD Holywell Music Room (SOLD OUT)
Fri 08 BRIGHTON Old Market
Sun 10 LIVERPOOL Philharmonic Hall 2
Mon 11 GLASGOW Oran Mor
Tue 12 DUBLIN Button Factory
Tickets available from: https://www.charliecunningham.com/
"… A wonderfully dynamic experience …" CLASH MAGAZINE
"… Music with craft and beauty at its core …" ATWOOD MAGAZINE
"… The essence of Charlie's sound is that he plays those nylons like heart strings …" THE ARTS DESK
WEBSITE: https://www.charliecunningham.com/
FACEBOOK: https://www.facebook.com/charliecunninghammusic/
TWITTER: https://twitter.com/Charlie_C_Music
INSTAGRAM: https://www.instagram.com/cunninghamcharlie/


text: Hi, Can I use a winpcap built in a XP x86 environment on any of Vista x86 or Vista x64 or do you need to build it on every system? Please specify if this is true for either Packet.dll or the driver npf.sys. Regards, Bengt Werstén -------------- next part -------------- An HTML attachment was scrubbed... URL: http://www.winpcap.org/pipermail/winpcap-users/attachments/20090128/967ceded/attachment.htm


text:
The Mitten
A Ukrainian FolktaleBook - 1989
From the critics
Community Activity
CommentAdd a Comment
Interactive and playful. Recommended.
My 4 year olds loved this book. It is a lovely, somewhat silly story and give the kids clues as to what will happen next.
Love this story and the accompanying illustrations. The side panels that show Nicki traversing through the winter wonderland, unaware of what is happening with his lovely mitten, are funny and add a nice depth to the story.
Well-written, well-drawn, and with a very cute story, this is one fable for everyone to read. The boarder patterns and pictures, add that little extra something to this particular copy, for they show what they boy is up to, while giving a sneak peak to the next animal. The animals while realistically drawn, have some very expressive facial features. Details of the stretching mitten, make this seemingly impossible action look real.
A great folktale to read to your kids on a cold winter's day. A snow white mitten, lovingly stitched by Nicki's grandmother, becomes a winter refuge for various animals in the forest.
AgeAdd Age Suitability
kyliereann thinks this title is suitable for 2 years and over
SummaryAdd a Summary
There are no summaries for this title yet.
NoticesAdd Notices
There are no notices for this title yet.
QuotesAdd a Quote
There are no quotes for this title yet.


text:
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text:
Perko Surface-Mount Dome Light, 4" Dia. Globe, 5" Base Dia.
Perko Surface-Mount Dome Light, 4" Dia. Globe, 5" Base Dia.. Chrome-plated zinc light features a water-resistant, booted pushbutton switch. 1-7/8" H. Bulb included. Fixture Name: Dome Light Light Style: Overhead Light Volts: 12V DC Bulb Wattage: 25W Fixture Material: Chrome-Plated Zinc Mounting Hardware Included/Required: Requires # 10 screws (not included) Lens Material/Description: Plastic Switch Type: Pushbutton Switch Replacement Bulb: Model 288910 Warranty: Five years
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text:
I live the intrigue of this photo. A trailer dropped in the middle of nowhere, with one door open to its darkness. One of the best writing prompt photos I have, in my opinion.
Click here to purchase this art in a variety of forms and to support our creativity.


text:
Clermont rowing crew hosts Anderson scout troop
The Clermont Crew took time out of their rigorous training schedule to get Boy Scout Troop 281 from Anderson Township on the water.
Ben Marquez, a member of the crew and an Eagle Scout from Troop 281, wanted his fellow scouts to learn about the best kept secret in Clermont County. The crew members engaged the scouts in several aspects of their training.
Ashley Collins, a junior from Glen Este and the girls winner of the 2014 Indoor Rowing Championship, introduced the scouts to an important tool of rowers' training, the concept 2 rowing machine. This machine is commonly referred to as the erg. Each boy had a chance to row a 1,000 meter piece on the erg. Max Broderick, a freshman from Anderson, scored the fastest time.
While some scouts were busy on land others were given the chance to row in an eight shell or a quad. As the scouts found out, according to Sandy Marquez, there is nothing more magical than working with your fellow boat mates to successfully glide across Harsha Lake at East Fork State Park.
Ben Marquez finished off the evening by telling his fellow scouts that "you won't find a sport that will put you through as much pain or joy as rowing nor will you ever find such a great group of friends." To become part of the Clermont Crew, visit www.clermontcrew.net.


text: This individual has no known canonical name. While the information presented is canonical, the individual described lacks an official name, thus the title is conjecture. Doctor is a female Tau'ri. BiographyEdit 2004Edit This section requires expansion Retrieved from "https://stargate.fandom.com/wiki/Doctor_(Home)?oldid=383117" Categories: Unnamed individuals Articles to be expanded Americans One-shot Atlantis characters Stargate Command personnel Add category Cancel Save Community content is available under CC-BY-SA unless otherwise noted.


text:
Winter Mountain Wedding Invitation
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Please add to the notes section at checkout Name, Date, Location, Time, RSVP information and any other requests.
We will provide a proof for you to approve
We will not print your order without prior approval first.
Please view our policies page for more information on shipping & processing times.


text:
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Case No. 5:05-cv-362-OC-10GRJ.
September 25, 2006
Neil J. Gillespie, pro se
The Plaintiff, proceeding pro se, has filed suit against the Defendants alleging violations of the Consumer Credit Protection Act, 15 U.S.C. §§ 1640(e) and 1692k, the Truth in Lending Act, 15 U.S.C. § 1601 et seq., the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq., and Florida law, with respect to various charges and fees assessed against the Plaintiff's credit card account. (Doc. 22). The case is before the Court for consideration of Defendants HSBC North America Holdings, Inc.'s and HSBC Bank Nevada, N.A.'s motions to dismiss, (Docs. 4, 29), to which the Plaintiff has filed a response in opposition (Doc. 5). Upon review of the Amended Complaint and the record in this case, the Court finds that the motions to dismiss are due to be granted in part and denied in part.
Although the Plaintiff lists the Consumer Credit Protection Act in the first paragraph of his First Amended Complaint, (Doc. 22), he does not allege any claims under the Act, or otherwise mention the Act. Therefore, the Court will not further address the Consumer Credit Protection Act in this Order.
Factual Background
The following facts are alleged in the Plaintiff's First Amended Complaint (Doc. 22) and are taken as true for the purposes of the motion to dismiss. The Plaintiff, Neil J. Gillespie, is a resident of Ocala, Florida. On February 27, 2003, Gillespie opened a MasterCard credit card account, issued by Defendant HSBC Bank Nevada, N.A., f/k/a Household Bank (SB), N.A. ("HSBC Nevada"). Defendant HSBC North America Holdings, Inc. ("HSBC North America") is the parent company of HSBC Nevada.
At the time Gillespie opened the account, HSBC Nevada charged him a $59.00 annual fee. The initial credit line for the credit card was $300.00. Gillespie maintained his credit card account in good standing and received credit line increases to $400,00, then $500,00, and again to $600.00 over the next year. In mid-2004, Gillespie decided to close his credit card account and pay off any remaining balance. By letter dated June 9, 2004, HSBC Nevada notified Gillespie that his account had been closed. Due to the busy 2004 Hurricane season, Gillespie chose to reinstate his credit card account in order to pay for hurricane related expenses. A $29.00 reinstatement fee posted to Gillespie's account on September 6, 2004.
On or about September 2, 2004, Gillespie requested, by telephone, an increase in his credit line. In a letter dated September 6, 2004, HSBC Nevada agreed to increase his credit limit to $800.00, provided that Gillespie pay in advance a $50.00 "automated credit line increase" fee. HSBC Nevada told Gillespie that the $50.00 fee would later be credited back to his account, and that he should make his check for the fee payable to "ACLI." Gillespie mailed a $50.00 money order payable to "ACLI" to HSBC Nevada on September 7, 2004.
Gillespie contends that HSBC Nevada never credited the $50.00 "automated credit line increase" fee back to his account. Instead, HSBC Nevada charged Gillespie's credit card account a $50.00 credit line increase finance charge on September 9, 2004, then reversed the fee the same day. According to Gillespie, these two transactions cancelled each other out, and did not take into account the $50.00 fee he had already paid and was promised would be credited to his account. Gillespie contends that HSBC Nevada's actions constitute a "slight-of-hand theft."
See Amended Complaint, (Doc. 22), ¶ 22.
While his account remained open, and throughout the entire dispute process, HSBC Nevada continued to mail Gillespie monthly account statements, each providing a 24-hour automated account information telephone number. On September 11, 2004, Gillespie left Florida in order to avoid Hurricane Ivan, and traveled to Ooltewah, Tennessee. During this trip, Gillespie used his credit card for various travel-related expenses. He relied upon HSBC Nevada's 24-hour automated account information telephone number to ensure that his credit card balance remained within the credit limit.
Gillespie contends that the automated account information telephone number provided him with incorrect balance information, such that he unknowingly exceeded his credit limit and was penalized with various overlimit fees. His September 20, 2004 credit card statement showed an overlimit balance of $161.62, the majority of which was attributable to various bank fees. If Gillespie had received accurate information concerning his account balance, and if he had received a credit on his account for the $50.00 "automated credit line increase" fee, Gillespie argues that he would not have exceeded his credit limit.
See Doc. 22, exhibit 2.
On November 13, 2004, Gillespie notified HSBC Nevada in writing that he was closing his account. In his letter, Gillespie agreed to pay all legitimate charges, including those for purchases, cash advances, cash advance fees, and lawful interest. He objected, however, to paying any overlimit fees and late fees resulting from the allegedly inaccurate account balance information provided by HSBC Nevada's automatic telephone service. Gillespie also requested an updated account statement within 30 days.
By letter dated November 29, 2004, HSBC stated that Gillespie's new account balance was $1,121.27 and demanded immediate payment of $355. Gillespie did not pay this amount, and returned the letter with various comments to the Chief Operating Officer of HSBC Bank USA, N.A.
On December 6, 2004, HSBC Nevada sent Gillespie a Delinquent Account Notice demanding payment of his account balance, which had reached $1,150.27. Gillespie telephoned HSBC Nevada on December 20, 2004 to dispute the balance. HSBC Nevada again contacted Gillespie by letter dated December 31, 2004. This letter notified Gillespie that his account had been canceled effective October 7, 2004. However, HSBC Nevada continued to charge Gillespie the $59.00 annual fee on March 20, 2005, and charged a $29.00 late fee and $29.00 overlimit fee every month.
On or about December 31, 2004, HSBC Nevada placed Gillespie's account for collection with Defendant Risk Management Alternatives, Inc. ("RMA"), a collection agency with its headquarters in Duluth, Georgia. RMA contacted Gillespie by letter dated January 3, 2005, notifying Gillespie that it was HSBC Nevada's debt collector on this account, and demanding payment in the amount of $1,174.74. That same day, Gillespie received a telephone call from a Roger Harrison at RMA offering to settle the entire dispute for $900.00. Gillespie immediately agreed to the settlement, and agreed to send an initial payment of $135.00 by January 25, 2005, with payment of the remaining $765.00 balance in February 2005.
Gillespie sent the $135.00 payment on January 15, 2005, ten days ahead of schedule. He spoke with a Holly Reynolds at RMA, who confirmed the terms of the settlement and provided Gillespie with RMA's receive code to accept the payment. Despite this settlement agreement, and Gillespie's initial payment, RMA continued to call Gillespie another 21 times throughout the month of January, 2005.
On January 24, 2005, RMA called Gillespie and informed him that RMA would no longer accept the settlement agreement and demanded payment of $1,089.27. RMA called Gillespie again on January 25, 2005, demanded the same payment, and threatened to call Gillespie's family if he did not pay the entire $1,089.27 immediately. RMA also claimed to have contacted Gillespie's uncle, which was not true, as Gillespie's uncle had passed away a short time before. Gillespie eventually changed his telephone number to an unpublished number to avoid any further contact with RMA.
On January 20, 2005, HSBC Nevada provided Gillespie with an account statement listing a payment of $135.00, and demanding a payment of the remaining balance of $1,089.79. The statement did not mention the settlement with RMA. HSBC Nevada also charged Gillespie another $29.00 overlimit fee and assessed a $21.05 finance charge.
On January 31, 2005, Gillespie wrote to Martin Glynn, President and Chief Executive Officer of HSBC Bank USA, one of HSBC Nevada's parent companies. In the letter, Gillespie discussed the alleged harassment and threats from RMA, including the fact that RMA broke its settlement agreement with Gillespie. He also stated that any further settlement offers must be made in writing. Jory Berdan of Household Bank Credit Card Services responded to Gillespie by letter dated February 24, 2005, acknowledging RMA's breach and offering to settle Gillespie's account. The terms of the new settlement offer are not mentioned in the Amended Complaint, although Gillespie states that they were contradicted by later HSBC Nevada correspondence.
To date, it does not appear that Gillespie has made any further payments on his account. HSBC Nevada has continued to assess late fees, overlimit fees, annual fees and interest on the credit card account. As of July 20, 2005, the outstanding balance had reached $1,675.21.
Procedural History
Gillespie initiated this action on August 17, 2005 (Doc. 1). In his original Complaint, Gillespie alleged three claims against HSBC Nevada: (1) a state law claim for fraud, based on the alleged "slight-of-hand theft" over Gillespie's $50.00 "automated credit line increase" fee; (2) a claim that HSBC Nevada violated various provisions of the Truth in Lending Act, 15 U.S.C. § 1601 et seq. ("TILA"), by failing to disclose in advance the various fees and finance charges it assessed against Gillespie, and by failing to provide Gillespie with accurate account balance information; and (3) a state law claim alleging violations of Florida's usury laws. Gillespie also asserted a claim against RMA, alleging that RMA's collection activities violated the Fair Debt Collections Practices Act, 15 U.S.C. § 1692, et seq. He seeks as relief compensatory damages, punitive damages, statutory damages, interest, costs, expenses, and attorneys' fees.
On October 17, 2005, HSBC North America and HSBC Nevada filed a joint motion to dismiss all claims against them. (Doc. 4). Gillespie filed a response in opposition on November 4, 2005 (Doc. 5). Before the Court could consider the motion, Gillespie sought and obtained leave to file an Amended Complaint (Docs. 8, 12). The Amended Complaint is identical in all respects to the original Complaint, with one exception. Gillespie has added a common law claim of negligence against HSBC Nevada, apparently based on HSBC Nevada's alleged hiring of RMA to act as its debt collector. Neither the original or the Amended Complaint allege any claims against HSBC North America.
In granting Gillespie leave to file his Amended Complaint, the Court also provided that HSBC North America's and HSBC Nevada's motion to dismiss (Doc. 4) would apply to the Amended Complaint, and granted leave to file another motion to dismiss focused solely on the new negligence claim. (Doc. 12). HSBC North America and HSBC Nevada did so on April 5, 2006. (Doc. 29). Gillespie has never responded to this second motion to dismiss and the time for responding has elapsed.
On July 7, 2005, approximately six (6) weeks prior to Gillespie filing this suit, RMA filed a voluntary petition for relief under Chapter 11 of the United States Bankruptcy Code, 11 U.S.C. §§ 101- 1330. On September 6, 2005, RMA filed a Notice of Pendency of Bankruptcy Case and Automatic Stay of Proceedings with this Court. (Doc. 2). As such, all claims against RMA are stayed pending notice that the automatic stay in the bankruptcy proceeding has been lifted.
Motion to Dismiss Standard of Review
In passing on a motion to dismiss under Rule 12(b)(6), the Court is mindful that "[d]ismissal of a claim on the basis of barebones pleadings is a precarious disposition with a high mortality rate." Int'l Erectors, Inc. v. Wilhoit Steel Erectors Rental Serv. 400 F.2d 465, 471 (5th Cir. 1968). Thus, if a complaint "shows that the Plaintiff is entitled to any relief that the Court can grant, regardless of whether it asks for the proper relief," it is sufficiently plead. Dotschay v. Nat. Mut. Ins. Co., 246 F.2d 221 (5th Cir. 1957). As the Supreme Court declared in Conley v. Gibson, 355 U.S. 41, 45-46 (1957), a complaint should not be dismissed for failure to state a claim unless it appears "beyond doubt that the plaintiff can prove no set of facts in support of his claim that would entitle him to relief." See also Cook Nichol, Inc. v. The Plimsoll Club, 451 F.2d 505 (5th Cir. 1971). The Federal Rules of Civil Procedure "do not require a claimant to set out in detail the facts upon which he bases his claim."Conley, 355 U.S. at 47. Instead, all that is required is that the claimant set forth a "short and plain statement of the claim" sufficient to give the defendant "fair notice of what the plaintiff's claim is and the grounds upon which it rests." Id. However, "while notice pleading may not require that the pleader allege a `specific fact' to cover each element of a claim, it is still necessary that a complaint contain either direct or inferential allegations respecting all the material elements necessary to sustain a recovery under some viable legal theory."Roe v. Aware Woman Center for Choice, Inc., 253 F.3d 678, 683 (11th Cir. 2001) (quotations omitted).
In addition, when considering a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), the Court is limited to a review of the allegations set forth on the face of the complaint itself, as well as any attached and/or incorporated documents which are central to the plaintiff's claim. Brooks v. Blue Cross Blue Shield of Florida, 116 F.3d 1364, 1369 (11th Cir. 1997). Review of such incorporated documents will not convert a motion to dismiss into a motion for summary judgment. Id., see also Harris v. Ivax Corp., 182 F.3d 799, 802 n. 2 (11th Cir. 1999). However, the Court will not consider factual arguments made in motions or other papers, or other evidence not attached or incorporated by the face of the complaint itself.
I. Claims Against HSBC North America
Defendant HSBC North America seeks to be dismissed from this case because Gillespie has not alleged any claims against it. It appears from the face of Gillespie's Amended Complaint that HSBC North America is a separate and distinct entity from HSBC Nevada. It is also clear from the Amended Complaint that Gillespie has not made any allegations against HSBC North America other than to aver that it is the parent company of HSBC Nevada. Thus, it would appear that dismissal of HSBC North America is appropriate.
See Doc. 22, ¶ 4.
Normally, a parent corporation is not liable for the acts of its subsidiaries. See United States v. Bestfoods, 524 U.S. 51, 61 (1998). Gillespie, however, argues in his opposition that HSBC North America should remain in this case because it is the "head of the hydra." See Doc. 5, p. 3. While not entirely clear, it appears that Gillespie is arguing that HSBC North America, in its role as parent of HSBC Nevada, either exercised some sort of control over the actions of HSBC Nevada in this case, or should be held vicariously liable for the actions of HSBC Nevada. However, Gillespie has made no such allegations in his Amended Complaint. Indeed, none of the five claims even mention HSBC North America. Given the complete absence of any allegations or claims in the Amended Complaint against HSBC North America, the Court concludes that dismissal without prejudice of HSBC North America is appropriate.
There are three ways in which a parent can be held liable for the acts of its subsidiaries: (1) an alter ego theory to "pierce the corporate veil;" (2) vicarious liability based on general agency principles; or (3) direct liability where the parent directly participated in the wrong complained of. See In re Managed Care Litigation, 298 F. Supp.2d 1259, 1309 (S.D. Fla. 2003). Gillespie has not alleged any facts in his Amended Complaint to support any of these theories.
II. Claims Against HSBC Nevada
A. Fraud Claim
HSBC Nevada seeks dismissal of each of Gillespie's claims against it. The first claim against HSBC Nevada is a state law claim for fraud. HSBC Nevada asserts that dismissal is appropriate because Gillespie has failed to state a claim upon which relief can be granted pursuant to Fed.R.Civ.P. 12(b)(6), and because Gillespie has not alleged his fraud claim with the sufficient level of particularity required by Fed.R.Civ.P. 9(a).
In his original complaint, Gillespie asks the Court to mail a copy of the complaint to United States Senator Richard Shelby and John C. Dugan, Comptroller of the Currency. (Doc. 1). In its first motion to dismiss, HSBC Nevada asks the Court to strike this request on the grounds that it is impertinent and scandalous. Gillespie has omitted this request in his Amended Complaint, therefore it is no longer a part of this case, and HSBC Nevada's request is denied as moot.
To allege a claim of common law fraud in Florida, Gillespie must allege: (1) a false statement concerning a material fact; (2) knowledge by the person making the statement that the representation is false; (3) the intent by the person making the statement that the representation will induce another to act on it; and (4) reliance on the representation to the injury of the other party. Knight v. E.F. Hutton and Co., Inc., 750 F. Supp. 1109, 1114 (M.D. Fla. 1990) (citing Lance v. Wade, 457 So.2d 1008, 1011 (Fla. 1984)).See also Romo v. Amedex Ins. Co., 930 So.2d 643, 651 (Fla. 3d DCA 2006); Hillcrest Pacific Corp. v. Yamamura, 727 So. 2d 1053, 1055 (Fla. 4th DCA 1999). HSBC Nevada contends that Gillespie has not sufficiently alleged either a false statement of a material fact, nor any injury attributable to his reliance on HSBC Nevada's statements. The Court disagrees.
Gillespie's fraud claim centers on the representations made by HSBC Nevada concerning his $50.00 "automated credit line increase." Gillespie alleges that HSBC Nevada told him that if he made that payment in advance, it would be later credited back to his account and he would receive a credit limit increase. In other words, he would receive a refund of his $50.00 payment. According to the Amended Complaint, while Gillespie did receive the credit limit increase, he never received a refund of the $50.00. Instead, HSBC Nevada charged his credit card accountan additional $50.00 fee, and reversed that charge. Simply put, HSBC Nevada double charged Gillespie for the credit line increase, and only credited him back for one of the charges. The partial copy of Gillespie's September 20, 2004 account statement further demonstrates this fact. The fact that HSBC Nevada did not credit Gillespie as it stated it would, thereby resulting in a loss of the $50.00 and additional charges to Gillespie's account, establishes both a false statement of a material fact and a resulting injury.
See Doc. 22, ¶¶ 18.a., 21, and exhibit 2.
Id., exhibit 2.
The Court seriously questions whether Gillespie will be able to establish that the other overlimit fees, late fees, and finance charges are a direct result of this allegedly false statement. However, that is a discussion for another time, and at the very least, Gillespie has sufficiently alleged damages in the amount of the $50.00 "automated credit line increase fee" which permit this claim to go forward.
The Court further finds that Gillespie has satisfied the heightened pleading requirements of Fed.R.Civ.P. 9(b). He has stated with particularity all of the circumstances constituting the alleged fraud in this case. More specifically, Gillespie has identified the precise statements he alleges are false or misleading, including the time place and identity of speaker; how he was mislead by those statements; and what HSBC Nevada obtained as a consequence of the alleged fraud, i.e., the additional $50.00 as well as other subsequent charges and fees. Although Gillespie's fraud claim could have been read as HSBC Nevada contends — that the $50.00 promised credit was really just a reversal charge — if a complaint "shows that the Plaintiff is entitled to any relief that the Court can grant, regardless of whether it asks for the proper relief," it is sufficiently plead.Dotschay v. Nat. Mut. Ins. Co., 246 F.2d 221 (5th Cir. 1957). Gillespie's fraud claim may go forward as alleged.
B. Truth in Lending Act Claim
Gillespie also alleges that HSBC Nevada violated numerous provisions of the TILA throughout the existence of his credit card account, including after his account was closed. For example, Gillespie contends that HSBC Nevada did not comply with the TILA's disclosure requirements when it solicited him over the telephone to open his credit card account in February 2003. He also contends that HSBC Nevada violated the TILA's disclosure requirements in September 20, 2004 when it did not refund his $50.00 "automated credit line increase" fee, and as a result of not crediting his account for this amount, did not provide him with the correct account balance, total amount of credits to his account, the correct finance charge, and did not correctly identify and credit other charges. Gillespie alleges that HSBC Nevada violated these same disclosure requirements in each subsequent monthly statement.
See Doc. 22, ¶¶ 58-59; 15 U.S.C. § 1637(c)(2).
See Doc. 22, ¶¶ 60-61; 15 U.S.C. §§ 1637(b)(3), (4), (7), and (8).
See Doc. 22, ¶ 70.
Gillespie also challenges HSBC Nevada's 24-hour automated account information telephone line, stating that it provided him false and inaccurate account balance information, and failed to disclose that reliance on such information would result in finance charges and overlimit fees. He also contends that HSBC Nevada failed to identify that his $135.00 payment on January 15, 2005 was made as part of a settlement agreement, and failed to include any of the terms and conditions of his February 24, 2005 settlement agreement in any of his future account statements. Finally, Gillespie asserts that HSBC violated the TILA when it failed to disclose that he would be charged annual fees, overlimit fees, and late fees on a closed account in violation of 15 U.S.C. §§ 1637(a), (c) and (d).
See Doc. 22, ¶ 62; 15 U.S.C. § 1637(a).
See Doc. 22, ¶¶ 67, 70.
Id., ¶¶ 63-66.
Taking the allegations set forth in Gillespie's Amended Complaint as true, which the Court must at the motion to dismiss stage, and refraining for passing on the merits, it appears that the majority of Gillespie's TILA claims are properly alleged, and provide a clear and plain statement sufficient to place HSBC Nevada on notice of the allegations against it. Indeed, HSBC Nevada does not challenge many of Gillespie's assertions. Rather, HSBC Nevada limits its challenges to Gillespie's claims concerning the September 20, 2004 account statement. According to HSBC Nevada, the portion of Gillespie's September 20, 2004 account statement which is attached to his Amended Complaint directly contradicts his allegations that HSBC Nevada did not credit back the $50.00 "automated credit line increase" fee on his September 20, 2004 account statement, and did not disclose the correct amount of credits and charges on that same statement.
15 U.S.C. § 1666c provides that all payments received from an obligor under an open ended consumer credit plan by the creditor shall be posted promptly to the obligor's account.
HSBC Nevada also seeks to use the September 20, 2004 account statement to disprove Gillespie's contentions that HSBC Nevada did not disclose it would charge overlimit and late fees on closed or cancelled accounts. However, that statement was created while Gillespie's credit card account was open and active. Therefore it does not establish any disclosures with respect to closed or cancelled accounts.
Because the Court has already found that, from the face of Gillespie's Amended Complaint and incorporated documents, Gillespie has sufficiently alleged that HSBC Nevada did not credit his account for that $50.00 fee as promised, the Court is satisfied at this stage in the litigation that Gillespie has also sufficiently alleged that HSBC Nevada improperly failed to disclose its credit of the $50.00 "automated credit line increase" fee and did not provide the correct balance, credits and charges on the September 20, 2004 account statement. Accordingly, Gillespie's TILA claim may go forward as alleged.
HSBC Nevada argues that if this claim is not dismissed with prejudice, the Court should order Gillespie to provide a complete copy of his September 20, 2004 account statement. The Court will deny this request. The portion of the statement provided with the Amended Complaint supports all of Gillespie's allegations such that dismissal is not appropriate. Moreover, if HSBC Nevada believes that this is an incomplete document and that other portions of the document are necessary at this point in the litigation, it could have easily attached them to its own motion to dismiss. Gillespie is correct, HSBC Nevada, as the lender in this case, has just as much access to Gillespie's account statements as Gillespie does. HSBC Nevada has not demonstrated that it will suffer any undue hardship by producing the complete account statement, and the Court doubts that it could, given that it readily submitted Gillespie's Cardholder Agreement.
C. Usury Claim
The third claim HSBC Nevada challenges is Gillespie's assertion that HSBC Nevada violated Florida's usury law, Fla. Stat. § 687.01, et seq. HSBC Nevada contends that this claim should be dismissed both because Gillespie has not pleaded any of the elements necessary to establish a claim of usury, and because Florida law does not apply to Gillespie's credit card account. The Court agrees.
Under Florida's usury law, it is considered "usurious and unlawful" to charge a rate of interest in excess of 18% for any loan, money advance, line of credit, or other obligation where the principal balance is $500,000 or less. See Fla. Stat. § 687.03(1). A creditor who willfully violates Florida's usury law is liable to the borrower for double the amount of interest collected. See Fla. Stat. § 687.04; Jersey Palm-Gross, Inc. v. Paper, 639 So.2d 664, 667 (Fla. 4th DCA 1994). Although Gillespie cites to the correct Florida statutes, he does not explain how his credit card account with HSBC Nevada violates this law. Gillespie alleges that HSBC Nevada charged him a nominal interest rate of 18.9%, an annual percentage rate of 22.9%, and periodic interest rates as high as 224%. Not only does Gillespie fail to explain how he arrived at these interest rates, but the partial copy of his account statement which he attached to his Amended Complaint directly contradicts his allegations. That statement lists a finance charge of $10.72 on a balance of $494.85. Simple math shows that the nominal interest rate charged is well under 18%. Even if Gillespie is correct that all of his late fees, cash advance fees, and overlimit fees also constitute interest, the nominal interest rate would still only amount to approximately 13.9%. Given the contradictions between Gillespie's account statement and the allegations in his Amended Complaint, the Court cannot say that he has properly alleged a claim of usury.
Doc. 22, ¶ 91.
Id., exhibit 2.
The September 20, 2004 statement listed miscellaneous finance charges of $58.26, as well as the monthly finance charge of $10.72.
In his opposition papers, Gillespie contends that his March 20, 2003 account statement demonstrates how he calculated his interest rates. See Doc. 5, p. 6. This is a factual argument, inappropriate for consideration at the motion to dismiss stage. Moreover, Gillespie has not included any allegations concerning this statement in his Amended Complaint, nor attached it to his Amended Complaint, so that the Court cannot consider this statement incorporated into his pleadings. The Court also does not see anywhere on the partial copy of the September 20, 2004 statement an annual percentage rate of 0.00%, as Gillespie claims.
Even if Gillespie had established that HSBC Nevada exceeded Florida's 18% interest rate cap, this claim fails for a more basic reason. Gillespie's Cardholder Agreement with HSBC Nevada clearly states that it is governed by Nevada law. Specifically, the Agreement states that Gillespie's credit card account "will be governed by federal law and the laws of the state of Nevada, whether or not you live in Nevada and whether or not your Account is used outside Nevada." Under Nevada law, "[p]arties may agree for the payment of any rate of interest on money due or to become due on any contract, for the compounding of interest if they choose, and for any other charges or fees," so long as the interest rates, fees and other terms are reduced to writing. NV Stat. § 99.050. See also, Mapes v. Palo Alto Town and Country Village, Inc., 584 F. Supp. 508 (D. Nev. 1984). Because Gillespie has not alleged any violations of Nevada law, nor alleged that the Cardholder Agreement's choice of law provision somehow does not apply to this case, he has failed to state a claim upon which relief can be granted. Gillespie's Florida usury claim will be dismissed without prejudice.
HSBC Nevada has attached a copy of the Cardholder Agreement to its motion to dismiss. See Doc. 4, exhibit A. Gillespie refers to his credit card contract with HSBC Nevada throughout his Amended Complaint, and many of the issues he references, such as interest charges, the effect of closing an account, and other fees and charges, are directly related to the Cardholder Agreement. It is therefore clear that the Cardholder Agreement has been incorporated into the Amended Complaint, and may be considered by the Court without transforming the motion to dismiss into a motion for summary judgment. Brooks v. Blue Cross Blue Shield of Florida, 116 F.3d 1364, 1369 (11th Cir. 1997).
Doc. 4, exhibit A, p. 4.
Gillespie argues, without any legal support, that because he did not sign the Cardholder Agreement, it is void under the statute of frauds. Doc. 5, p. 7. Such a bald conclusory statement cannot save this claim from dismissal. In addition, it is unclear from the Cardholder Agreement whether a signature is required for the Agreement to be enforceable. It is also unknown whether Gillespie signed any papers consenting to this Cardholder Agreement at the time he opened his credit account. These unresolved questions are all factual disputes, which cannot be decided on a motion to dismiss.
D. Negligence Claim
Gillespie's final claim against HSBC Nevada is a common law claim for negligence under Florida law. From the very brief allegations asserted, it appears that Gillespie is arguing that HSBC Nevada was negligent in hiring RMA to act as its debt collector with respect to Gillespie's credit card account, apparently because RMA is now in Chapter 11 bankruptcy and cannot be sued. To bring such a claim, Gillespie could pursue either a negligent hiring theory, or a common law negligence theory. Gillespie's barebones claim does not specify the legal theory upon which it is predicated. However, under either theory, Gillespie has failed to allege a claim upon which relief can be granted.
Doc. 22, ¶ 96; Doc. 5, p. 8.
To allege a prima facie claim of negligent hiring, Gillespie must assert that:
(1) the employer was required to make an appropriate investigation of the employee and failed to do so; (2) an appropriate investigation would have revealed the unsuitability of the employee for the particular duty to be performed or for employment in general; and (3) it was unreasonable for the employer to hire the employee in light of the information he knew or should have known.Malicki v. Doe, 814 So.2d 347, 362 (Fla. 2002) (citing Garcia v. Duffy, 492 So. 2d 435, 440 (Fla. 2d DCA 1986)). Gillespie's Amended Complaint does not allege any of these elements. In fact, he does not even establish or allege that RMA was HSBC Nevada's employee.
The Court seriously doubts Gillespie could establish such a relationship in any event.
To the extent Gillespie is instead proceeding under a simple common law claim of negligence, this claim also fails. To allege a prima facie case of negligence, Gillespie must aver that: (1) HSBC Nevada owed a legal duty to Gillespie; (2) HSBC Nevada breached that duty; (3) the breach legally caused an injury to Gillespie; and (4) damages resulted from the injury. See Pinchinat v. Graco Children's Prods., 390 F. Supp.2d 1141 (M.D. Fla. 2005). Again, Gillespie has not alleged any of these elements, and has not responded to any of HSBC Nevada's arguments challenging this negligence claim.
Because Gillespie has not alleged any of the elements necessary for either a prima facie claim for negligent hiring or for common law negligence, his claim must be dismissed. And while the Court has great doubts Gillespie could ever succeed on such a claim, the Court will provide him with one more opportunity to properly allege this claim.
E. Punitive Damages and Attorneys' Fees
HSBC Nevada also requests to have Gillespie's claim for punitive damages in his state law fraud claim stricken because it is based on "conclusory allegations in the absence of a reasonable basis in fact to support a claim for fraud."See Doc. 4, p. 9 (citing Porter v. Ogden, 241 F.3d 1334, 1340 (11th Cir. 2001). Because the Court has determined that Gillespie has sufficiently alleged a claim for common law fraud, his request for punitive damages may also go forward.
Gillespie has also included in his requests for relief under each of his claims a request for attorneys' fees and costs. HSBC Nevada has moved to have Gillespie's request for attorneys' fees stricken, arguing that a pro se litigant is not entitled to attorneys' fees. The Court agrees. See Kay v. Ehrler, 499 U.S. 432 (1991); Ray v. U.S. Dept. Of Justice, 87 F.3d 1250 (11th Cir. 1996); Celeste v. Sullivan, 988 F.2d 1069 (11th Cir. 1992). The fact that Gillespie may have some paralegal experience or training is of no relevance. Accordingly, any requests on behalf of Gillespie for attorneys' fees shall be stricken, and Gillespie is instructed not to include any such requests if he chooses to file a second amended complaint.
Accordingly, upon due consideration, it is hereby ORDERED and ADJUDGED that:
(1) Defendants HSBC North America Holdings Inc.'s, and HSBC Bank Nevada, N.A.'s motion to dismiss (Doc. 4) is GRANTED IN PART AND DENIED IN PART. All claims against Defendant HSBC North America Holdings Inc., to the extent any are alleged in the Plaintiff's First Amended Complaint (Doc. 22), are DISMISSED WITHOUT PREJUDICE. Count IV of the Plaintiff's First Amended Complaint against Defendant HSBC Bank Nevada, N.A. is DISMISSED WITHOUT PREJUDICE. The Plaintiff may not recover attorneys' fees while proceeding pro se, and therefore all references to attorneys' fees are STRICKEN, and the Plaintiff may not assert any claims for attorneys' fees in any future pleadings. In all other respects the Motion to Dismiss (Doc. 4) is DENIED.
(2) Defendants HSBC North America Holdings Inc.'s, and HSBC Bank Nevada, N.A.'s motion to dismiss negligence count (Doc. 29) is GRANTED. Count V of the First Amended Complaint is DISMISSED WITHOUT PREJUDICE.
(3) All claims against Defendant Risk Management Alternatives, Inc. are hereby stayed pending notice that the automatic stay under 11 U.S.C. § 362 has been lifted.
(4) The Plaintiff shall have twenty (20) days from the date of this Order to file a second amended complaint correcting the deficiencies discussed in this Order. Failure to submit an amended complaint within this time period will result in the dismissal with prejudice of the above-listed claims.
DONE and ORDERED.


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News ReleasesFilter
Rutledge Announces Upcoming Mobile Office LocationsFri, Oct 23, 2015
LITTLE ROCK – Arkansas Attorney General Leslie Rutledge today announced upcoming mobile office locations.
Attorney General Rutledge created the mobile office initiative to reach consumers where they live. Earlier this month the initiative celebrated the milestone of holding office hours in all 75 counties for the first time.
The mobile offices assist constituents with consumer-related issues in filing consumer complaints against scam artists. Attorney General Rutledge believes there is no issue too small for her staff to have a face-to-face conversation.
For more information about services provided by the Attorney General's office, visit ArkansasAG.gov or call 501-682-2007 or 800-482-8982. Rutledge can also be found on Facebook at facebook.com/AGLeslieRutledge and on Twitter at twitter.com/AGRutledge.
Upcoming Attorney General Mobile Office schedule:
Benton County Mobile Office
Wednesday, Oct. 28
10:30 a.m. – 12:30 p.m.
Schmeiding Senior Center
1801 Forrest Hills Blvd. #200D
Bella Vista, AR 72715
Garland County Mobile Office
Thursday, Nov. 5
9:30 – 11:30 a.m.
Hot Springs Senior Center
210 Woodbine St.
Hot Springs, AR 71901
Rutledge Joins Challenge to the EPA's Carbon RuleFri, Oct 23, 2015
LITTLE ROCK – Arkansas Attorney General Leslie Rutledge today announced that she has joined 23 other States in filing a lawsuit that challenges the Environmental Protection Agency's (EPA) unlawful "Clean Power Plan," which was published in the Federal Register today. In the documents filed with the Court of Appeals for the District of Columbia, the States make clear that the EPA has no legal authority to promulgate or enforce the section 111(d) rule.
"I have expressed my concerns over this rule since February, even testifying in front of a U.S. House of Representatives subcommittee, and urged the EPA to withdraw the rule," said Attorney General Rutledge. "The EPA is going far beyond its legal authority under the Clean Air Act. This unlawful rule will have serious and significant consequences. In a State like Arkansas where over half of the electricity is responsibly generated from coal-fired power plants, the impact will be felt in the pocketbooks of Arkansas utility ratepayers. These increased costs will have a direct impact on the State's ability to grow good-paying jobs with fair, reasonable electric rates. Like all Arkansans, I favor clean air. But I do not favor heavy-handed and unlawful regulations from Washington that will hurt Arkansans."
States already have firm deadlines to submit initial and final compliance plans under the rule despite the 1,560-page rule not being formally published until today.
Rutledge and other States have been seeking a stay of the rule since it was announced.
The States challenging the rule include Alabama, Arkansas, Colorado, Florida, Georgia, Indiana, Kansas, Kentucky, Louisiana, Michigan, Missouri, Montana, Nebraska, New Jersey, Ohio, South Carolina, South Dakota, Texas, Utah, West Virginia, Wisconsin, Wyoming, the Arizona Corporation Commission, and the North Carolina Department of Environmental Quality.
Attorney General's Office Accepting Applications for Spring Semester InternsWed, Oct 21, 2015
LITTLE ROCK – Arkansas Attorney General Leslie Rutledge today announced that her office is accepting applications for interns during the spring semester, which will begin on Jan. 4, 2016.
"Internships offer students a fulfilling learning opportunity and a look into the real-world job market," said Attorney General Rutledge. "Interns at the Attorney General's office will have the chance to work with some of the top lawyers and professionals in the State. Students will learn exactly what it means to work in public service and to serve the people of Arkansas."
Applicant packet information is available under the employment section at ArkansasAG.gov.
The deadline to apply is December 1.
Some interns may be able to arrange for college credit for their internship, depending upon the requirements of their college or university.
Those with questions about the Attorney General's office intern program should contact the Human Resources Department at firstname.lastname@example.com.
Rutledge Comments on Arkansas Supreme Court's Decision to Stay ExecutionsTue, Oct 20, 2015
LITTLE ROCK – Arkansas Attorney General Leslie Rutledge today released a statement in response to the decision from the Arkansas Supreme Court to grant the prisoners' request for a stay of executions until proceedings at the Circuit Court are resolved.
"The Arkansas Supreme Court agreed with the State's argument that the Circuit Court did not have jurisdiction to stay the executions; however, the Supreme Court did choose to enter its own order, placing executions on hold pending the outcome of litigation at the lower court. While the Supreme Court's decision is not about the merits of the case, it is unfortunate that this further delays justice for the victims. I will continue to defend Arkansas's lethal injection statute and fight for the victims and their grieving families."
Rutledge Announces Trumann Woman Sentenced for Medicaid FraudMon, Oct 19, 2015
LITTLE ROCK – Arkansas Attorney General Leslie Rutledge announced today that a Poinsett County woman has been sentenced to five years of probation on a Medicaid fraud charge.
Kelly Gregg, 43, of Trumann pleaded guilty to billing for Medicaid services not provided, a Class B felony. Gregg must also pay $3,557.31 in restitution and $10,671.93 in fines.
"Investigators and attorneys from the Attorney General's office are working tirelessly to catch and prosecute those who commit Medicaid fraud," said Attorney General Rutledge. "Medicaid is a critical safety net for some of the most vulnerable Arkansans, and I am committed to holding criminals who steal from Medicaid accountable."
Gregg was arrested in December after it was reported to investigators that she was billing for services to a friend's mother between January 2013 and March 2014 but was not providing the services. Gregg pleaded guilty in Pulaski County Circuit Court on Monday.
The Attorney General Medicaid Fraud Control Until has arrested 24 individuals and has obtained 17 convictions across the State this year.
Rutledge: State Should Maintain its Authority over Drilling PermitsThu, Oct 15, 2015
LITTLE ROCK – Arkansas Attorney General Leslie Rutledge today announced that she sent a letter to the Bureau of Land Management (BLM) Director Neil Kornze raising concerns about the scope of the BLM's proposed rules for onshore oil and gas operations.
Rutledge opposes the rule in its current form since the BLM impermissibly expanded its authority over non-federal lands contrary to the Mineral Leasing Act of 1920. Additionally, the BLM failed to engage any State entities, and Rutledge believes the rule would lead to severe economic harm in Arkansas.
"Federal law allows Arkansas to issue drilling permits on non-federal lands," said Attorney General Rutledge. "The BLM is attempting to go beyond the intent of this law and overtake the State's authority to control its own land without any appropriate consultation. I urge the BLM to revise this rule and work with the States to do so. If the BLM does not narrow the scope of the rule, I am prepared to take appropriate legal action."
In the letter, Rutledge writes, "the State of Arkansas has and continues to successfully administer surface and downhole activities associated with the development of oil and gas in a safe and prudent manner, protecting all parties from waste."
A copy of the letter is available here.


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Thanks for your interest in Magento Number Of Employees!
I'm currently working on a detailed video to get you the latest information on this…
But in the meantime…
Checkout the best ClickFunnels offers, benefits, and features below.
In this day and also age, the method your business operates online could make or break you.
How do most companies presently have a visibility online?
The reality of the matter is, nevertheless, that internet sites have actually considerably advanced over the previous years – and the methods of old are not functional for contemporary company.
Back then, it would certainly be adequate to have an easy website with a home page, solutions, pricing, about us, as well as call pages.
A prospective consumer would certainly go to your site, scroll around, see the various web pages and also eat content as they please.
Nevertheless, if you are an organisation spending any cash on advertising and marketing, you intend to control exactly what customers are discovering on your site, existing offers at the correct time, and also optimize the income you make from each individual.
Exactly how does one accomplish this?
Using sales funnels.
Go into ClickFunnels
ClickFunnels is the simplest way to earn high converting sales and also advertising and marketing funnels.
It is a distinct device developed particularly to turn potential customers right into purchasers.
It truly is an all-in-one solution to create sales funnels and also includes touchdown web pages, email integration, payment, webinars, subscription sites, therefore a lot more. Not surprising that it has swiftly come to be a favorite tool for marketing experts.
Below is my thorough ClickFunnels Review, consisting of preferred attributes, prices, pros/cons, and comparisons against competitors.
Magento Number Of Employees: Yet First, Exactly What Is a Sales Channel?
Sales funnels (additionally called advertising funnels) are multi-step projects that are made to relocate prospective leads through your sales procedure, and also transform them right into customers.
Picture a real-life channel. At the top, you put fluid in, which limits towards one repaired location.
In sales, a similar occasion occurs. At the top, visitors get to your internet site, yet not all who get in make it out of the other end as buyers.
Numerous points need to take place from the time a site visitor enters your channel, to the time they act and also efficiently finish a purchase.
By damaging down the consumer's journey right into smaller steps, you could be a lot more exact regarding how and when you present an offer to your target market.
The in-depth steps in a funnel may look something like this:
- Unqualified lead gets to touchdown page
- Web page interacts the initial offer (something cost-free to gather an email).
- Once e-mail is collected, main offer is pitched.
- Lead ends up being a paying client.
- Even more e-mail communication supplying client worth.
- Additional relationship building
- Persisting sales.
ClickFunnels additionally has a graphic that explains this in a basic method:.
Just what is ClickFunnels?
As discussed previously, ClickFunnels is the best sales funnel software around today.
The business makes the vibrant claim of giving you every little thing you should market, sell, and also deliver your items online – as well as they certainly deliver.
A typical funnel will make use of an opt-in page (to collect email addresses), an e-mail vehicle -responder (to send emails to your customers), plus an additional sales page with some web content as well as an order kind, perhaps followed by extra material, a membership website, etc
. Formerly, you would certainly need to utilize various platforms as well as devices to accomplish all these tasks such as:
- Produce an internet site
- Discover Hosting
- Find an autoresponder solution
- Find membership site software program
- Locate split-testing software … and so on
However ClickFunnels deals with whatever with their platform. You not just conserve a lots of cash by not having to get various products/services, yet you additionally prevent the technical mess of having to establish everything up, as well as could concentrate on exactly what's really important – expanding your business.
ClickFunnels provides a Totally free 14-Day Test, so you get to discover the tool and truly see if it's ideal for your business.
Preferred Features
* Swiftly Produce Pages Making Use Of Themes and Components *.
Prior to obtaining too much, it is necessary to recognize that a funnel is a collection of pages created in a critical order, with the goal of converting as numerous leads into customers. And also a page is just a collection of different aspects designed to get someone to take a specific action.
ClickFunnels uses even more compared to 50 different elements to assist you build the ideal web page. The editor is extremely very easy to use as well as all you need to do is drag and also go down different elements on to the page, and update the text and also look to fit your demands – no coding skills called for!
ClickFunnels additionally makes your life less complicated by supplying you with a lots of cost-free layouts.
As a matter of fact, ClickFunnels provides over 37 sorts of pages for you to blend and match with. These are broken down into the complying with 10 classifications:
- Presell Pages: Survey Web Page, Article Web Page, Presell Page, Clickpop Page
- Optin Pages: Squeeze Web Page, Reverse Squeeze Web Page, Lead Magnet, Coupon
- Thanks Pages: Thank You Web Page, Offer Wall Surface, Bridge Web Page, Share Page
- Sales Pages: Video Sales Page, Business Letter Web Page, Product Launch Page
- OTO Pages: Upsell Web Page, Downsell Web Page
- Order Forms: Two Step Order Web Page, Typical Order Web Page, Video Clip Sales Letter Order Web Page, Sales Letter Order Web Page, Item Launch Order Page
- Webinar Pages: Webinar Enrollment Web Page, Webinar Confirmation Page, Webinar Broadcast Space, Webinar Replay Space
- Membership Pages: Gain Access To Web page, Participant's Location
- Associate Pages: Accessibility Web Page, Affiliate Area
- Other Pages: Application Web Page, Ask Page, Shop Front, Home Page, Hero Web Page, Hangout Web Page, Live Demonstration Page
The pre-built design templates are completely personalized, as well as are what most users utilize.
You are able to choose a theme, edit or replace the aspects with your very own, and also your new page prepares to go.
You could additionally connect any type of funnel you develop with your own e-mail marketing service (if you do not make use of the one consisted of in ClickFunnels), and also use the ClickFunnels integrated in invoicing system.
This is also a great time to point out that ClickFunnels provides extremely helpful and easy to understand training videos when you first register. I highly recommend experiencing those since they swiftly allow you to utilize the tool at its full ability, as well as you'll have much more fun playing around. Magento Number Of Employees
* Develop One-Click Subscription Sites *.
One of the most effective functions with ClickFunnels is the capability to conveniently create subscription websites and also deliver material to your audience in one place.
Your membership website will certainly come total with enrollment web pages, subscription access pages, and also content pages which you can quickly secure or drip feed to your consumers according to purchases they made in your funnel.
ClickFunnels membership websites enable you to send e-mails, easily handle your emails, as well as construct an area all while getting rid of the stress that's connected with various other remedies such as Kajabi, or WordPress platforms.
It's really handy to not have to buy a separate software application or plugin to produce subscription websites.
* Email Assimilation & Actionetics *.
With every channel comes email list building possibilities.
ClickFunnels sustains email assimilation with all the significant e-mail automation systems such as:
- Active Campaign
- Aweber
- Constant Contact
- ConvertKit
- Drip
- Get Response
- Hubspot
- InfusionSoft
- Mad Mimi
- MailChimp
- Market Hero
- Ontraport
- Salesforce
- Sendlane
- And others
Nevertheless, ClickFunnels likewise has their own powerful automation device called Actionetics.
Although you could produce, timetable, and supply emails just like any other email advertising system, Actionetics is so much a lot more.
I enjoy Actionetics because it not only replaces your email marketing yet messenger marketing and also SMS marketing softwares too. This takes automation to an entire new degree and also assists you interact the excellent message to your clients, specifically when they require it. A video clip review of Actionetics will certainly be offered better below.
* Billing and also Settlement Integration *.
An incredible feature within ClickFunnels is the capability to collect every one of the invoicing details from your customers precisely your sales page. Marketing is made a lot easier when clients do not need to leave your website.
ClickFunnels incorporates with major payment gateways such as PayPal, Stripe, and also InfusionSoft, to name a few.
ClickFunnels Pricing.
While you could start with the Free 14-Day Trial, there are 3 different rates options with ClickFunnels:
- $ 97/month.
- $ 297/month.
- $ 997 mass price cut plan (suggested).
I'll explain for every of these plans listed below.
1. ClickFunnels Standard Strategy – $97/month.
The conventional strategy consists of all the attributes you would require within ClickFunnels, however with limitations on the variety of funnels (20) as well as web pages (100) you can have in your account, in addition to the amount of visitors (20K) can see your web pages each month.
You likewise do not receive advanced performance such as ClickFunnels very own e-mail marketing and associate monitoring tools.
2. ClickFunnels Etison Collection – $297/month.
This strategy consists of all the bells as well as whistles of the common strategy, without any restrictions. It additionally comes with two extra products produced by ClickFunnels called Actionetics (e-mail advertising) as well as Knapsack (affiliate monitoring system).
In Actionetics – you could manage every one of your calls that register for your listing, send out e-mail broadcasts, and create a host of other automations. Magento Number Of Employees
The difference between both strategies truly is the restrictions, as well as Actionetics/Backpack. If you are a fundamental customer and don't expect to make use of greater than 20 funnels in your account – the Criterion Plan must be enough.
Nonetheless, if you plan to have an affiliate program or wish to keep your email marketing within ClickFunnels and also not utilize a 3rd party software, the Etison Suite is for you.
You could always start on the lower strategy and upgrade if required.
3. Funnel Hacks System – $997
For any individual that's major about their organisation, the ClickFunnels Funnel Hacks System is the deal of the century.
The $997 Funnel Hacks System consists of durable training programs packed with 6-month access to the ClickFunnels Etison Suite.
This is an extraordinary deal because beyond this program, 6-months of Etison Suite alone would cost you $1782.
Not only are you saving $785 yet you're getting a lots of trainings and also overviews of assist you get one of the most out of ClickFunnels!
ClickFunnels Benefits And Drawbacks
- Creating funnels is very straightforward, very easy, and also quick
- All-in-one system with everything your service has to win
- Split screening and also conversion monitoring consisted of
- Email combination with all of the significant e-mail autoresponder platforms
- Settlement handling capacities within ClickFunnels
- ClickFunnels is constantly adapting and also upgrading to the moments
- There is always support available (whether real-time or not).
- Extremely energetic Facebook Team Community.
- Free 14-Day Test – enables you to try it risk cost-free.
- As amazing as ClickFunnels is, it certainly is not an affordable solution and also calls for a continuous subscription to make use of
- Assistance isn't really constantly the fastest as well as might extract from 1 minute to 24-HOUR depending on the concern.
ClickFunnels versus Everybody Else.
Lots of people ask exactly how ClickFunnels compares with various other landing web page contractors such as Leadpages, Unbounce, and Infusionsoft.
For the most part it's not actually a reasonable contrast since each of these devices succeeds is one location or the various other.
The graph above gives a comprehensive analysis – but I'll highlight several of the significant comparisons below.
ClickFunnels vs Leadpages
Prior to ClickFunnels, Leadpages was the large pet dog.
Leadpages is just a lead capture software application – nothing more. You can create landing web pages, lead boxes, accumulate leads … that's pretty much it. In addition, the Leadpages layouts are likewise restricted on modification.
ClickFunnels is much more versatile – it's much easier to use as well as does so a lot more than create lead capture web pages.
Basically, Leadpages is really simply a touchdown web page contractor, while ClickFunnels is concentrated around building extremely incorporated funnels.
ClickFunnels vs Infusionsoft
Infusionsoft is not a landing web page or sales web page building contractor. It has a few of that capability built it, but that's not exactly what it's recognized for.
At it's core, Infusionsoft is a CRM platform – one that allows you to manage your entire consumer database. ClickFunnels has this ability with Actionetics, yet it's not virtually as advanced as Infusionsoft.
Infusionsoft is additionally incredibly expensive and forces every new consumer to pay $2000 for a required kickstart training package simply to find out how you can use the complex system (which is infamously tough to make use of).
ClickFunnels Affiliate Program
There are two main paths people go down as ClickFunnels users.
Those that choose to utilize the tool for their company – in hopes of eventually attain both Comma Club (over $1M in profits).
As well as those that are interested in earning easy revenue as a ClickFunnels Affiliate and also winning the Dream Automobile Competition (where they pay $500/$1000 to your dream vehicle if you reach 100/200 active month-to-month signups, specifically).
With a tremendous 40% month-to-month persisting compensation, ClickFunnels quickly has among the greatest associate programs of any system available.
That's right – you earn money a continuous 40% compensation on every associate signup you make with the ClickFunnels Associate Program. Yet, exactly what does that truly relate to?
The fundamental strategy is a $97/month investment as well as the Etison Collection plan is a $297/month financial investment. consequently you make $38.80 each basic strategy and also $118.80 per Etison Collection plan … each and every month!
On average, every 100 signups will certainly generate $4000/month in affiliate payments (more or less depending on the number of Etison Strategy customers remain in there).
Visit this site to learn more about ending up being a ClickFunnels Affiliate.
The Bottom Line
ClickFunnels is by far the greatest platform if you are looking to quickly construct high converting sales funnels.
Because it was developed from scratch to be the most effective sales channel home builder, it beats out every one of the competition because respect.
Externally, it could not be the most affordable product out there – however if you use it to its complete capability, your business will certainly end up being much more profitable as well as you will save loan from not having to utilize other devices. Magento Number Of Employees
If you have actually read this much right into my ClickFunnels Testimonial, I recommend you see for yourself with a Free 14-Day Test right here.


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Chad Hugo's Quotes
Born: 1974-02-24
Profession: Musician
Nation: American
Biography of Chad Hugo
I just always considered myself to be different and able to explore whatever I wanted.Tags: Able, Wanted, Whatever
So I think it's better to say something than not to say anything at all, even to an ignorant person.Tags: Ignorant
I grew up around hip-hop so I didn't think it was about being cool or being black or being white or whatever.Tags: Black, Cool, Whatever
You've come to me now at this point in time, when The Neptunes are just now getting our light.Tags: Getting, Light, Time
For me, I'm just trying to be the best at what I do. I'll wave an Asian American flag if I get that opportunity. I'm not hiding or trying to discredit my background or anything, I just haven't had the opportunity.Tags: American, Best, Trying
Groups like The Mountain Brothers just have to keep on doing what they're doing - just make it dope and just make it different. And not try to compete with other people of color.Tags: Color, Keep, Try
I played saxophone, so I was into jazz. I learned from each audience and each teacher that I had. I can't really tell you any rules or anything, but the way I develop my beliefs is really just by personally learning from different situations.Tags: Learned, Learning, Teacher
I'm not trying to disrespect anybody by saying this - I'm not sure I feel any interaction with Asian America in any collective sense. - It's like, when you're telling me this right now, my reaction is, Really? Asian America knows about me?Tags: America, Saying, Trying
When I made it, I still didn't wave the flag and say, Yeah go Asian people. I do want people to know that about me, but I always felt like at least musically, let me just do what I do and be the best at it. Which is what I'm doing right now.Tags: Best, Felt, Yeah


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Reaction to defending World Champions Italy's World Cup departure has been vitriolic. "Shame" screamed one headline while others invoked the black of mourning and likened the team to mouldy mozzarella.
Under-fire coach Marcello Lipi has copped the blame for what many slam as a footballing fiasco – but an apology from him is unlikely to be enough.
"It's embarrassing, we left so many good players at home. The team wasn't organised properly on the pitch, I didn't like it." said one disillusioned fan near the Victor Emmanuel monument in Rome.
"We have to realise our winning streak is over. It always ends at some point but its difficult to take on board when it happens." said another, as he stopped his moped at the traffic lights."We didn't have the luck we had in 2006, but maybe we were stronger then. There are other reasons why we lost out this time around. In any case, it's a sport, you win some, you lose some." was the sanguine opinion of a third.
After last night's game, Italy's disgraced players returned to their hotel in the team bus, which carries the slogan "our Blues in the African sky".
And they certainly will be in the sky soon – on the plane taking them home.