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text:
Plaintiff, )
No. 03-6494
and )
Plaintiff-Intervenor, )
v. )
Defendant. )
___________________________________ )
I. Preliminary Statement
After attempting to resolve this discovery dispute without Court intervention, the United
States filed a motion to compel the production of certain patient care reports generated by
Philadelphia Fire Department ("PFD") paramedics Joni Kuonen and/or Katherine Ceschan for
the period 2000 through 2002. Defendant filed a brief in opposition in the form of a motion for
protective order. Defendant did not dispute that the patient care reports are relevant to the
litigation.1 Rather, Defendant argued that because of the way the reports were electronically
stored, production of responsive documents was impossible and a manual search for paper
1 The United States' document request, limited to the three year period from January 1,
2000 through 2002, is narrowly tailored to reflect and discover relevant information regarding
the particular paramedics involved in this action during the period reasonably preceding and
following the incident at issue, which occurred on February 20, 2001.
documents would be unduly burdensome. Because Defendant's argument was premised on
unsupported factual assertions that had not previously been raised with the United States, the
United States sought, and the Court granted, a stay to conduct a Rule 30(b)(6) deposition,
previously noticed, regarding the storage and retrieval of patient care reports.2
Pursuant to the Court's Order, Defendant produced Captain Richard Marshall Bossert,
head of Continuous Quality Improvement for the PFD Emergency Medical Services division
("EMS"). Captain Bossert's testimony flatly contradicted the factual assertions underlying
Defendant's undue burden argument, and demonstrated that responsive computer records
generated during the period at issue were identifiable and retrievable through a database search.
Given the absence of any evidentiary basis for Defendant's argument that production of the
requested records would be unduly burdensome, the United States respectfully requests that the
Court deny Defendant's motion for protective order and direct Defendant to produce the
electronically generated patient care reports responsive to the United States' request.3
2 Initially, the United States requested a designated agent who could testify about "the
means by which the City of Philadelphia collects and maintains data relating to dispatches by
paramedics and EMT's, and the means by which such data can be retrieved." For the purposes
of this motion to compel, the request was narrowed to reflect the maintenance and retrieval of
reports generated from 2000 through 2002. In addition, we informed counsel for Defendant that
"the deposition will cover the unsupported representations regarding the burden and cost of
production raised in your opposition to the United States' Motion to Compel."
3 In view of Captain Bossert's testimony that additional reports responsive to the United
States' request can be generated through an electronic search, the United States will not seek
reports that are available only in paper form, thus rendering moot Defendant's argument that the
cost of a manual search would be unduly burdensome.
II. Argument
A party wishing to obtain an order of protection over discovery material must
demonstrate that "good cause" exists for the order of protection. Fed. R. Civ. P. 26(c); see also
Fort Washington Resources, Inc. v. Tannen, 153 F.R.D. 78, 79 (E.D. Pa. 1994) ("[T]he party
seeking the protective order bears the burden of showing good cause.") (citing Cipollone v.
Liggett Group, Inc., 785 F.2d 1108, 1121 (3d Cir.1986); Trans Pacific Ins. Co. v. Trans-Pacific
Ins. Co., 136 F.R.D. 385, 391 (E.D.Pa.1991)).
Discovery in the form of document production will always impose some burden on the
party from whom the discovery is sought, thus "good cause" requires a showing of, and Rule
26(c) protects only against, undue burden. See, e.g., Roesburg v. Johns-Manville Corp., 85
F.R.D. 292, 297 (D.C. Pa. 1980) (the fact that discovery will require the objecting party to
expend considerable time, effort and expense is not alone sufficient to disallow the discovery
unless the requests are "egregiously burdensome or oppressive"). Whether discovery imposes an
undue burden depends on such factors as relevance, the need of the party for the documents, the
breadth of the document request, the time period covered by the request, the particularity with
which documents are described, and the burden imposed.4 Wyoming v. U.S. Dep't of
Agriculture, 208 F.R.D. 449, 453 (D.D.C. 2002). "Broad allegations of harm, unsubstantiated by
specific examples or articulated reasoning, do not support a good cause showing." Pansy, 23
F.3d at 786 (citing Cipollone, 785 F.2d at 1121).
4 Defendant cited only time and expense concerns in its undue burden argument, and
cannot at this late stage argue that other factors justify protection of the documents. See also
Footnote 1, supra (discussing limited scope of document request) and United States' Mem. in
Support of Motion to Compel, at pp. 4-5 (discussing relevance of requested documents).
In this case, Defendant's broad allegations of harm, unsubstantiated, and largely refuted,
by Defendant's designated agent, will not support the good cause showing required under Rule
26(c), and, accordingly, Defendant's opposition and motion for protective order must fail.
A. Additional responsive reports were electronically generated and are identifiable
Defendant alleges, generally, that computer-related issues render an electronic search, and
subsequent production, of additional responsive records impossible. Defendant asserts that
patient care reports from 2000 were not stored on a computer file; that reports prior to late 2001,
while possibly electronically generated, could only be searched by date or dispatch number; and
that no reports between 2000 and 2002 could be searched by the "prior history" field.
Defendant's Opp. at ¶¶ 12-15.
These factual assertions were flatly refuted by Defendant's designated agent. As set out
below, Captain Bossert's testimony clearly establishes: (1) that Ms. Kuonen's and Ms. Ceschan's
EMS unit, Medic 2, was electronically reporting EMS runs prior to late 2001, and (2) that in any
electronically generated patient care report, all database fields are "queryable," or searchable, for
terms included on the pre-programmed drop-down boxes for each database field.
The United States first sought information regarding when and how the PFD paramedics
– and Ms. Ceschan and Kuonen, particularly – generated patient care reports during the relevant
time period. Captain Bossert explained that the United States' document request covered a
period of transition for the PFD, in that during the years 2000 through 2002, the PFD EMS was
converting to a computerized system. See Bossert Depo. at p. 36.5 Medic units were converted
to electronic reporting at different times during this period, and, while some began electronic
5 Copies of all referenced pages from Captain Bossert's 30(b)(6) deposition are attached.
reporting as early as 2000, others continued to generate paper reports which were then scanned
into the computer. Id.
Captain Bossert could not testify as to the exact date when Medic 2 converted to
electronic reporting although he admitted that this information is available in his office. Bossert
Depo. at pp. 96-97. However, based on a review of Plaintiff John Gill Smith's patient care
report, dated February 20, 2001, and marked as Exhibit 2, Captain Bossert testified that Medic 2
was electronic as of, at least, February 20, 2001:
Page 82:
18 Q. Now, can you tell from
19 looking at this [Exhibit 2], was Medic 2
20 electronic at this point?
21 A. This would be, yes, on this
22 report.
23 Q. And the date of this
24 incident was February 20th, 2001.
Therefore, patient care reports were electronically generated by Ms. Kuonen and/or Ms.
Ceschan from at least that point forward, and may date back to 2000:
Page 93
7 MS. EINSTEIN: And it's
8 your assumption that if they were
9 electronic in February of 2001, they
10 were electronic from February 2001
11 forward?
12 THE WITNESS: Minus the
13 exceptions when the computer system
14 is down.
15 MS. EINSTEIN: Correct.
16 THE WITNESS: Okay.6
6 See also Bossert Depo., at p. 95-96 (reiterating that electronically generated reports from
early 2001 on should be retrievable and confirming that ACS, a computer consulting firm
retained by the City and the PFD, could generate and produce a list of the responsive records).
See also Bossert Depo. at p. 97, lines 9 - 14 ("Q. And everything that you just discussed with
Miss Einstein, those assertions hold true if they were electronic in 2000 as well, correct? A.
Captain Bossert also testified, contrary to Defendant's assertions, that where a patient
care report was electronically generated, it could be queried for, and records identified by, any
field in the report:
Page 102
11 Q. Your understanding is that
12 any field in a database should be
13 queryable --
14 A. Right.
15 Q. -- if the information is in
16 that field?
17 A. Correct.
Captain Bossert explained that any terms available from the drop-down boxes, or "pick-list"
within a database field would be searchable and records including that term would be
identifiable. See Bossert Depo., at pp. 103, 115-16. Although the PFD used a number of
different database software programs during this period, Captain Bossert testified that he would
be able to determine, "with some reliability," which software database program or programs
were in use by Medic 2 throughout the period at issue, and, then, determine which terms were
available from the pick-list. See id. at 116-17. Significantly, Captain Bossert testified that
records wherein the "probable cause" field included "chest pain" would be identifiable since the
search term specified in the United States' request – "chest pain" – would be phrased
consistently regardless of the software.
Page 28 (Witness)
9 But that's not a problem,
10 because we have a complaint that says
11 "Chief complaint is chest pains," and
12 I can query that, for a particular
13 medic unit, for a particular time.
And, with respect to the HIV-related reports, when presented with Exhibit 2, Plaintiff Smith's
report from February 2001, and an additional report from 2002, Captain Bossert confirmed that
although the two reports were generated using different software, both included AIDS/HIV
among the pick-lists for the prior history field and thus reports during that time frame and
generated with those programs would be searchable by that field and that term. See Bossert
Depo. at pp. 100-102, 118-19.7
In sum, contrary to Defendant's allegations, the evidence demonstrates that additional
reports responsive to the United States' document production requests are electronically
searchable, identifiable and producible.
B. The HIV/AIDS-related patient care reports
As demonstrated above, some or all of the requested HIV-related records are
electronically identifiable and retrievable. See also Bossert Depo. at p. 109, lines 9-12 ("[Q.]
Logistically, you could have performed that search, however? [A.] Logistically, yes. . . .").
7 In Exhibit 2, the paramedics had documented HIV in the prior history field, thereby
establishing that HIV/AIDS was in the pick-list, and reports using that software could have been
queried for "prior history" of HIV/AIDS. See Bossert Depo. at pp. 103-104. Captain Bossert
further confirmed that the software used by Medic 2 at some point in 2002 also could be queried
for a prior history of HIV/AIDS. Bossert Depo. at pp. 118-19. Since it is unlikely that the PFD
removed HIV/AIDS from the pick-list after February, 2001, and re-inserted it in 2002, it is
reasonable to assume that a "prior history" of HIV/AIDS is searchable for the entire period from
February 20, 2001 forward, and possibly earlier.
Captain Bossert admitted, however, that, although contacted about the document request, he
never searched the PFD electronic records for the HIV-related reports, and was unaware of
whether anyone else did:
Page 107
3 Q. Did you do a search for the
4 requests involving Joni Kuonen and
5 Katie Ceschan, plus HIV/AIDS, prior
6 history?
7 A. No.
Page 119
21 Q. So you don't know what ACS8
22 did with respect to this document
23 request?
24 A. This particular one, no.
Captain Bossert offered two explanations for why he did not do the requested search,
neither of which justifies, or is relevant to, the failure to produce the requested documents.
Captain Bossert explained that he did not do the requested search because, in his opinion, the
patient care records identified and obtained from such a search would not be "reliable," the
"most probable" reason being that not all patients with the HIV virus identify themselves as such
to paramedics. See Bossert Depo., at p. 110. He was also concerned that variances in the
software programs from 2000 to 2002 might result in less than complete identification of records
falling within the requested parameters because the pick-list might not have included HIV/AIDS
8 ACS is a computer and record storage firm that the City contracts with for record
maintenance. Defendant's Opp. at ¶ 11. Captain Bossert described ACS as "the caretaker[] of
the databases" for the PFD. Bossert Depo. at p. 46, lines 19-22.
(a concern proven to be less important given his concession that HIV/AIDS was, indeed, on the
pick-list in February, 2001, and in 2002, and likely during the intervening time period). See id.
at 108. Captain Bossert shared his opinions with his superiors in the PFD and was then told not
to do the search:
Page 109
5 Q. And so you were told not to
6 do the search?
7 A. From my recollection, yes.
Defendant's motion for a protective order, on undue burden grounds, must fail where
Defendant has not presented evidence that it took even the minimal steps that would have
demonstrated that the relevant documents were searchable and would have indicated the number
of documents responsive to the request.9 Cf. Fort Washington Resources, 153 F.R.D. at 79 ("The
burden is not met by 'the recitation of expense and burdensomeness [which are] merely
conclusory' statements.") (citing Panola Land Buyers Ass'n v. Shuman, 762 F.2d 1550, 1559
(11th Cir.1985)).
9 Some of the factual assertions in Defendant's brief concerned actions allegedly taken or
statements made by representatives of ACS, a computer consulting company retained by the City
and the PFD. Although Captain Bossert understood that he was being deposed as Defendant's
Rule 30(b)(6) designated agent, he was unprepared to answer any questions regarding what
actions, if any, ACS took in attempting to satisfy the United States' document request. He
admitted he did not call or speak with ACS prior to the deposition and had no knowledge of the
actions undertaken by ACS on the City's behalf with respect to the document requests. See
Bossert depo. at 113-14; 119. See, e.g., Black Horse Lane Assoc., L.P. v. Dow Chem. Corp., 228
F.3d 275, 304 (3d Cir. 2000) ("[W]e believe that the purpose behind Rule 30(b)(6) undoubtedly
is frustrated in the situation in which a corporate party produces a witness who is unable and/or
unwilling to provide the necessary factual information on the entity's behalf."); Hooker v.
Norfolk Southern Ry. Co., 204 F.R.D. 124, 126 (S.D.Ind. 2001) (explaining that Rule 30(b)(6)
"imposes a duty upon the named business entity to prepare its selected deponent to adequately
testify not only on matters known by the deponent, but also on subjects that the entity should
reasonably know") (emphasis added).
C. The "chest pain" patient care reports
With respect to the United States' request for patient care reports involving Joni Kuonen
or Katie Ceschan where the nature of the 911 call, as documented in the "probable cause" field,
includes "chest pain," Defendant produced 126 responsive reports from the "latter part" of 2001
through 2002, covering approximately 13 to 15 months of the three-year period at issue. The
United States seeks production of responsive reports for the period from January 1, 2000 up to
the latter part of 2001.
In view of Captain Bossert's admission, discussed above, that responsive reports were
identifiable at least by February 20, 2001, but had not been produced, the United States asked
Captain Bossert whether he had searched for responsive reports for January, 2001 forward.
Captain Bossert could not recall:
Page 92
4 MS. EINSTEIN: Well, let me
5 ask you specifically.
6 Did you query for the time
7 period January 2001 forward?
8 THE WITNESS: I queried for
9 whatever I could query for. And
10 whoever asked for it was told that.
11 And outside that...
12 MS. EINSTEIN: Well, I
13 asked if you queried for the period
14 January 2001 forward. Do you recall?
15 THE WITNESS: I don't
16 know. No, I don't recall exactly.
17 MS. EINSTEIN: Okay.
18 THE WITNESS: I couldn't
19 tell you.
Nonetheless, Captain Bossert admitted that if a search had been done for the period 2000
forward, all electronically generated reports would be identified in the search. Since he had
already conceded that Ms. Kuonen and Ms. Ceschan were "electronic" as of February 20, 2001,
this meant that as of at least February 20, 2001, and going forward, all of the reports generated
by Ms. Kuonen and Ms. Ceschan were electronically generated and retrievable under the criteria
specified by the United States:
Page 92
20 MS. EINSTEIN: And if you
21 had queried January 2001 forward, the
22 report in Exhibit 2 would have shown
23 up?10
24 THE WITNESS: As far as I
Page 93
1 can tell, yes.
2 MS. EINSTEIN: And any
3 other report that was electronic
4 would have shown up?
5 THE WITNESS: That's
6 correct.
Given the established existence of electronically generated reports prior to "latter 2001," Captain
Bossert had no explanation for Defendant's failure to produce the electronically generated
records from that period:
Page 93
17 MS. EINSTEIN: And so do
18 you have any explanation why in
19 producing the reports the City did
20 not produce reports for any time
21 prior to what they have characterized
22 as late 2001?
23 THE WITNESS: The only
24 explanation I could give you would
10 Exhibit 2 refers to the patient care report for Plaintiff Smith, dated February 20, 2001.
Page 94
1 be, those reports aren't
2 electronically done and they're on
3 paperwork and they're archived. That
4 would be the only -- I --
5 MS. EINSTEIN: No. But
6 these particular reports, for Joni
7 Kuonen and Katherine Ceschan for
8 chest pains --
9 THE WITNESS: Okay.
10 MS. EINSTEIN: -- which
11 we've already agreed were
12 electronically generated.
13 THE WITNESS: Right.
14 MS. EINSTEIN: So do you
15 have any explanation for why those
16 reports were not produced for prior
17 to late 2001?
18 THE WITNESS: Off the top
19 of my head, I -- all I remember is
20 give me the number of calls under
21 these parameters, tell us what we
22 have, blah, blah, blah. From that
23 point on, it went back and forth
24 multiple times through the --
Page 95
1 MS. EINSTEIN: I just asked
2 you a yes or no question.
3 Maybe you should read it
4 back.
5 THE WITNESS: Okay. No.
In sum, given that Captain Bossert's testimony demonstrates that responsive chest pain
reports are electronically identifiable and retrievable as of at least February, 2001, thereby
refuting the factual basis for Defendant's undue burden argument, Defendant's motion must fail.
D. Production of the reports is not unduly burdensome
Defendant alleged that the only reasonable means to locate the responsive reports would
be to conduct a manual search of storage boxes, at an approximate cost of $164,160.
Defendant's Opp. at ¶¶ 20-24. Now that Defendant's designated agent has testified that the
documents can be identified and produced through a computer document search, Defendant's
assertions of burdensomeness are moot. Given that it takes approximately five minutes to
produce each report, Defendant's Opp. ¶ 17, and that the number of responsive documents is,
likely, around 120,11 Defendant cannot show that production would be burdensome.
First, it bears repeating that the United States' request is relevant and narrowly tailored to
the facts in this case. Moreover, the reports at issue already reflect a compromise reached by the
parties to limit the initial request, which covered the time period 2000 to the present, to a three
year period from 2000 through 2002, precisely because Defendant's counsel expressed concerns
about the time it would take to produce the reports. Indeed, at five to ten minutes per report
(giving Defendant every benefit of the doubt) Defendant could produce 120 reports in ten to
twenty hours. The United States was unable to find any reported cases in which a court held that
the expenditure of ten to twenty hours to produce relevant documents was unduly burdensome.
11 The 126 chest pain reports already produced represent approximately 13 to 15 months –
from the latter part of 2001 through 2002. Given Captain Bossert's testimony that the date that
Medic 2 converted to electronic reporting could be readily determined from PFD records, as
could the particular database(s) in use by Medic 2 during that period, it follows that accurate
querying of the database(s) in use during the period from January 1, 2000 up and until the latter
part of 2001 would generate approximately the same number, or less, of "chest pain" reports.
And, although Captain Bossert never attempted the electronic query that would have indicated
the precise number, it goes without question that there would be significantly fewer responsive
reports documenting a prior history of HIV/AIDS.
See, e.g., Fort Washington Resources, 153 F.R.D. at 79 (Defendant failed to meet burden of
showing good cause; assertion that producing documents would take too much time and expense
was unsupported by the necessary particularized facts and details regarding the amount of time
or expense and why such amounts are unduly burdensome); Klausen v. Sidney Printing & Pub.
Co., 271 F. Supp. 783 (D.Kan.1967) (mere fact that interrogatories are lengthy or that defendant
will be put to some trouble and expense in preparing requested answers is not alone sufficient to
warrant protective order relieving defendant from burden of answering).12
III. Conclusion
For the foregoing reasons, and based upon the entire record herein, the United States'
motion to compel should be granted and Defendant's motion for a protective order should be
12 Defendant relies on Lickteig v. Landauer, 1992 WL 333994 (E.D. Pa. 1992) as support
for its assertion that production requiring 6000 man hours is unduly burdensome. Def. Mem. at
11-12. In Landauer, the court granted a protective order for a document request that required the
review of 1,108 complaints requiring an estimated 554 hours. Landauer is inapposite to the
actual facts in this case – retrieval of approximately 120 reports, requiring 10-20 hours.
Moreover, even in Landauer, the Court ordered the City of Philadelphia to produce documents
more closely tailored to the facts of that case for a five year period. Id.
Respectfully submitted this ____ day of July, 2005.
Attorney General of the United States
United States Attorney Acting Assistant Attorney General
Eastern District of Pennsylvania Civil Rights Division
NANCY GRIFFIN JOHN L. WODATCH, Chief
Assistant United States Attorney PHILIP L. BREEN, Special Legal Counsel
Eastern District of Pennsylvania ALLISON J. NICHOL, Deputy Chief
615 Chestnut Street, Suite 1250 Disability Rights Section
Philadelphia, PA 19106 Civil Rights Division
Telephone: (215) 861-8200
/s/ Kathleen P. Wolfe
Trial Attorneys
Disability Rights Section
Civil Rights Division
U.S. Department of Justice - NYA
950 Pennsylvania Avenue NW
Washington, D.C. 20530
Telephone: (202) 307-0663
I hereby certify that on July ___, 2005, I electronically filed with the Clerk of the Court,
using the Electronic Case Management System, the United States' . . . .
I further certify that copies of this filing were mailed via First-Class Mail on July __,
2005, to the following non-ECF participants:
Ronda Goldfein
AIDS Law Project of Pennsylvania
1211 Chestnut Street, Suite 600
Philadelphia, PA 19107
Kathleen P. Wolfe
Trial Attorney
Disability Rights Section
Civil Rights Division
U.S. Department of Justice - NYA
950 Pennsylvania Avenue NW
Washington, D.C. 20530
Telephone: (202) 307-0663

subset: commoncrawl


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Get the latest updates on EFC topics and stay connected.
Below you'll find many of our most recent posts, including selected articles from Faith Today. You can also select one of the options in the boxes to the top left of your screen to jump to other types of articles not included in the list below (e.g., Dispatches from Brian, EFC Updates, media releases, official statements, outgoing letters, research, etc.).
Churches can offer help when tragedy strikes nearby, but how do we do it well? How can we prepare? Sign up for our Feb. 27 webinar.
Local churches are uniquely positioned to be a comfort in terrible times, write Karen Stiller in Faith Today. Reprinted with permission from the Jan/Feb 2019 issue of Faith Today.
Preparation and a plan are key for handling a crisis at your church. Article reprinted with permission from the Jan/Feb 2019 issue of Faith Today.
The 2018 book "The Soul of the City: Mapping the Spiritual Geography of Eleven Canadian Cities" can spur us to think and inform ourselves about the spiritual realities of our cities, writes...


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Clear All
2006 82 min Germany, Poland 7.1
This feature length documentary takes a look at the graffiti movement, and the young people who populate the niche culture. Following four such artists as they shape the graffiti community ...
2003 117 min Poland, France 6.4
Two intellectuals, a writer and a director, begin to play a mysterious psychological game in a peaceful countryside manor house during the Nazi occupation.
All That I Love
2009 95 min Poland 6.9
Follows four friends in their quest to form a punk band. As workers protests sweep across the country, Janek and Staszek, the sons of a navy man, the rebellious Kazik, and the affluent ...
All That I Love
Past Life
2016 109 min Israel, Poland 6.4
Past Life tracks the daring late 1970s odyssey of two sisters - an introverted classical musician and a rambunctious scandal sheet journalist - as they unravel a shocking wartime mystery that has cast a dark shadow on their entire lives.
Past Life
2017 105 min Poland 5
A woman stumbles upon a valuable artifact, the crown that belonged to Casimir the Great.
2017 103 min Georgia, Russia, Poland 6.3
The movie describes real events that took place in 1983, when seven young Georgians, all from intellectual elite families, attempted to flee the Soviet Union by hijacking an airliner. The ...
Ganavim Ba Hok
2010 90 min Germany, Israel, Spain, Norway, Sweden, Switzerland, Poland, Finland 7.3
Documentary film from 2010 tries to give a picture of Russian organized crime not only by describing this system, but also by interviewing some of involved persons, a number of which are currently wanted by Interpol.
Ganavim Ba Hok
The Fourth Dimension
2012 105 min Poland, USA, Russia 5.9
The Lotus Community Workshop centers on a motivational speaker named Val Kilmer.
The Fourth Dimension
In the Shadow
2012 106 min Czech Republic, Slovakia, Poland 7.1
In the former Czechoslovakia, 1950s, police captain Hakl investigates a jewelery robbery. An opened safe deposit leads to a known burglar. What seems an easy case soon starts to tangle. ...
In the Shadow
Lucky Day Forever
2011 17 min Poland 7.8
Prole 514 dreams about winning the Great Lottery. The lottery winner is transformed and allowed admission into the elite White society, where everyone is beautiful, young and happy and ...
Lucky Day Forever
Forgive Us Our Debts
2018 104 min Italy, Switzerland, Albania, Poland 6.3
A man struggling under the crushing weight of debt must work as a tax collector to pay off his creditors.
Forgive Us Our Debts
2018 107 min UK, Poland 5.8
Hurricane (Squadron 303) is the story of a group of brave Poles who fought in the skies over England in WW2, not just to keep Great Britain free from the Nazis, but also to keep alive the ...


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BunnyCDN Launches A PoP in Seoul, South Korea
We are excited to announce our latest network expansion into Seoul. The result? Up to 90% decreased latency and vastly improved performance to over 45 million internet users in South Korea.
South Korea on top of having one of the fastest residential networks in the world is also a country with one of the highest internet penetration. Despite that, for a CDN it's a rather tricky market to serve. One reason is that it's quite isolated and simply far away from any other large internet exchanges. This often results in congestion of international networks and increase in latency during peak hours.
The launch of the Seoul BunnyCDN PoP puts these issues behind, bringing your content just 5-20ms away from over 45 million internet users in South Korea. We were very happy to see an instant drastic performance improvement on PerfOps as well.
The expansion puts BunnyCDN as one of the fastest global CDNs in South Korea, and as always, we are doing it with the same old pricing of $0.03/GB. Bunny speed ahead!
Dejan Grofelnik Pelzelhttps://bunnycdn.com
The founder of BunnyCDN. An expert in networking, servers and development. Makes sure things are always running fast and smooth.


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Thanks Drgoodvibe. What in your opinion and testing is "small lots relative to a large account" as it relates to a mini account? In other words, what would be a good balance in a mini-account to avoid any margin calls.
Also, I use 400.1 leverage which would obviously help to withstand any possible margin call as well.Thank you.
I am using IBFX mini account. Which means that .01 lots is 1 cent, Or $0.01. To trade at this level you would need at least $500.
Now here's the trick to the major money management of this.. at $600 the compounding will increase to 0.02 or $0.02. My Plan is to remove 50% of all equtiy that is gained in the account every two weeks.
So if I made let's say $100 in two weeks, I would remove $50 from the account and just put in a Savings account. This way after a couple of weeks you will have the money you initially invested in this strategy and you will no longer need to be too worried about a margin call becuase you're trading with money you have taken from the market.
note: this is an extremely conservative money management strategy to an extremely aggressive trading strategy. The hedging is great and really pads the account, but the martingaleing like many have said before me will destroy your account. It's not an IF it's a when..


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P O D C A S T : The Castle Report
|Audio BLOG
Tags: english, blog, news, podcasts, audio, events, commentary, perspective, current, politics, american, america, us, directory,
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Socialism — Theft by Majority Vote
Darrell Castle presents the essence of socialism and its current vehicle, the Green New Deal. Transcript / Notes SOCIALISM—THEFT BY MAJORITY VOTE (...)
The State of the Union – A Tough Act To Follow
Darrell Castle talks about President Trump's State of the Union Message as well as the Democrat response to it. Transcription / Notes THE STATE OF (...)
Enter Sandmann
Darrell Castle talks about Nick Sandmann and the other teenagers from Catholic High School, in Covington, Kentucky, and explains how they are (...)
China and the United States – A Comparison
Darrell Castle draws a comparison between China today and America today. Transcription / Notes CHINA AND THE UNITED STATES—A COMPARISON Hello this (...)
Freedom of Speech in an Age of Lies and Hysteria
Darrell Castle talks about government and private efforts to deny our right to speak freely and to profit from our own lawful businesses. (...)


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Finally, some good examples of data to help our homeschoolers learn and practice data analysis skills. These types of practice sheets are hard to come by. The analysis worksheets are interesting and engaging data sets to help your kids practice important math skills. In the real world, this is a super important math skill. There are a variety of skills necessary to complete this assignment, making it a great opportunity to apply what they know to a real world situation. Using a calculator is not always a bad thing, I constantly use my phone calculator for daily tasks. Analyzing data or the "whys" of data analysis is something your kids will absolutely need in life
Click here to download your free data analysis worksheet for middle and highschoolers from Math Geek Mama.
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Jan 26, 2019
I enjoyed this course a lot and prof. Bloom is very easy to follow. Being that I have done my studies on psychology in another language it was very important for me to take this course in English.
Jan 02, 2019
This is very basic course on pshchology but I enjoy studying it for personal reason. I think many learners will take advantages of this course for whatever field of studay and work they are doing.
77 个审阅
创建者 riddhi vichare•
Feb 23, 2019
I have completed the course yet I didn't receive my certificate for the same. I had applied for the financial aid which was approved still the link for the sharable certificate is not displayed. Please help.
创建者 Lee Huan Ching Danny•
Feb 22, 2019
Great overview to the field of Psychology. It really makes a lot of sense.
创建者 Jim Grantham•
Feb 21, 2019
Great overview of topics that everybody is curious about presented in a pleasing format by a well spoken professor
创建者 Mariia•
Feb 21, 2019
It is very informative, very well structured and interesting course. It's absolutely well-worth attending.
Feb 19, 2019
Interesting information, good narration, very good additional reading, all in a high speed. The animation that accompanies the course, almost makes it feel like a pod-cast - I didn't mind, note taking did not allow for too much watching anyway
创建者 Rodrigo Silveira Santos Rocha•
Feb 19, 2019
Very informative video lectures, not tiring at all, exactly the opposite. Grounded on current research and many relevant fields in the area, not just the clinical or mental-health ones.
创建者 Emmanuel Tsochas•
Feb 17, 2019
Excellent course!
创建者 Elena Gatti•
Feb 17, 2019
This course has enriched my awareness about the complexity of human beings. This awareness is a precious gift which can be useful in many contexts in my life and work giving me a wider view. In fact sometimes good questions are better than any answer
创建者 Fleur•
Feb 17, 2019
This animated course is so clear in what everything means, that learning is made fun!
创建者 Slavomíra Henčeková•
Feb 17, 2019
Very useful, not easy, but also not difficult, not long, understandable, interesting, just perfect!


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Enjoy your holiday in Telemark and spend your nights in cabins and apartments. You will find a large selection of cabins and apartments in different price classes both near the coast and close to the mountains.
Kragerø Sportell & Appartements have access to the most beautiful archipelago Kragerø. Here you can rent motorboats, rowboats, canoes and sailboats.
Norsjø Ferieland has become one of the best campsites offering including rental of cabins. By Norsjø Cable Park, you can challenge yourself, grandmother or neighbor on one of Europe's best cableways for wakeboard and waterskiing.
At Vierli you can rent cabins in the mountains 1,010 meters above sea level. Experience breathtaking scenery with activities or enjoy peaceful days.
If you are looking for a unique accomodation, than we recommend checking out Å camp in Tessungdalen. Here you can sleep in hammocks, tree cabins and even bathe in log-warmed bath tubs.
Number of results: 30
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Camping site located by the lake Norsjø
TripAdvisor Traveller Rating2 reviews
Welcome to Kjønnøya Camping in Bamble. This is a family camping along the coastalpath and Bicycle route nr 1
Bamble Sommerrute
Å camp is located on the banks of Tessungåe, and borders the great mountain plateau of North Europe, Hardangervidda. The camp is based on the simple joys of nature.
Tinn Austbygd
Traditional timber log apartment (50 m2) in great hiking area not far from Torvetjønn. The apartment is on the first floor of a complex with four separate living units.
Apartments in 54 m2 of high standard in complex with six separate units. Ski-in ski-out from Rauland Ski Center. Designated parking garage.
Rognstrand Camping is located by the coast of Bamble
Cabins and apartments located close to Gaustablikk Høyfjellshotell and Gaustablikk Skicentre. All guests may use the hotel facilities.
TripAdvisor Traveller Rating4 reviews
Vrådal Booking - apartments and cabins in the center of Vrådal and at the ski center!
Brand new and modern apartment only 200m from the ski lift and slopes. The apartment is part of a semi detached house, located on the ground floor with terrace.
In the middle of Telemark surrounded by arctic nature lies Vatnelian – an idyllic mountain farm located 660 m above sea level. Its history dates back to the 15 th. century. Vatnelian can be rented all year round. The old mountain farm with its...


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Packing jobs in Forex företagskonto Filter from by: Upload your CV and easily apply pqcking jobs from jobs device! Work from home job directory both great at your jobs.
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Nissan e-NV200 On Sale In Japan (w/video)
The first batch of Nissan e-NV200s produced in Barcelona, Spain reached Oppama, Japan, from where they will be shipped to customers in Japan.
This mean that the second electric car from Nissan is going global.
The prices of e-NV200 in Japan, like elsewhere, are a little higher than for the LEAF (below $35,000).
A useful feature is the 100 V AC outlets on-board, which could be used in an emergency or daily at work if needed. Nissan even prepared a list of example appliances that could work at less than 1,500 W (maximum output).
As there were a lot of tests of e-NV200 in Japan, we expect that sales to fleets will be significant.
Categories: Nissan
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5 Comments on "Nissan e-NV200 On Sale In Japan (w/video)"
With Japan's extensive QC infrastructure, and with the typical patterns of short-delivery light commercial vehicles, the niche for this van in Japan can be pretty big.
would love to have one for work ,but a little
more battery Under the floor would be nice.
re the video, in all languages EVs tell a great story.
The gas powered version of this VAN is being sold by Chevy.
You'd think there would be absolutely no downside for GM to also offer the Rebranded EV200 also as a GM ev product.