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Jack Balkin: jackbalkin at yahoo.com Bruce Ackerman bruce.ackerman at yale.edu Ian Ayres ian.ayres at yale.edu Corey Brettschneider corey_brettschneider at brown.edu Mary Dudziak mary.l.dudziak at emory.edu Joey Fishkin joey.fishkin at gmail.com Heather Gerken heather.gerken at yale.edu Abbe Gluck abbe.gluck at yale.edu Mark Graber mgraber at law.umaryland.edu Stephen Griffin sgriffin at tulane.edu Jonathan Hafetz jonathan.hafetz at shu.edu Jeremy Kessler jkessler at law.columbia.edu Andrew Koppelman akoppelman at law.northwestern.edu Marty Lederman msl46 at law.georgetown.edu Sanford Levinson slevinson at law.utexas.edu David Luban david.luban at gmail.com Gerard Magliocca gmaglioc at iupui.edu Jason Mazzone mazzonej at illinois.edu Linda McClain lmcclain at bu.edu John Mikhail mikhail at law.georgetown.edu Frank Pasquale pasquale.frank at gmail.com Nate Persily npersily at gmail.com Michael Stokes Paulsen michaelstokespaulsen at gmail.com Deborah Pearlstein dpearlst at yu.edu Rick Pildes rick.pildes at nyu.edu David Pozen dpozen at law.columbia.edu Richard Primus raprimus at umich.edu K. Sabeel Rahmansabeel.rahman at brooklaw.edu Alice Ristroph alice.ristroph at shu.edu Neil Siegel siegel at law.duke.edu David Super david.super at law.georgetown.edu Brian Tamanaha btamanaha at wulaw.wustl.edu Nelson Tebbe nelson.tebbe at brooklaw.edu Mark Tushnet mtushnet at law.harvard.edu Adam Winkler winkler at ucla.edu Compendium of posts on Hobby Lobby and related cases The Anti-Torture Memos: Balkinization Posts on Torture, Interrogation, Detention, War Powers, and OLC The Anti-Torture Memos (arranged by topic) Recent Posts Why the legal issues in the White Paper are not the most important issues, and how Jack Goldsmith gets it right
Tuesday, February 05, 2013
Why the legal issues in the White Paper are not the most important issues, and how Jack Goldsmith gets it right Mary L. Dudziak
The leak of a White Paper on targeting killings is getting the expected attention from law bloggers and others, with much commentary focused on whether the legal analysis is correct – for example the definition of "imminence." The precise legal analysis is a distraction from more compelling issues, which are taken up by Jack Goldsmith in a Washington Post op-ed. I often disagree with Goldsmith, but this time I find myself in agreement. In part.
I really don't understand this post -- and not just because I'm almost certainly one of the bloggers whose work is apparently distracting people from more important things. You say we need a new "war politics" based on transparency and engagement, but you don't think the content of the war politics we have now is important? Pointing out that the US is currently making life or death decisions on the basis of flawed legal theories is a "distraction" from creating that new politics? (A politics in which, apparently, the law has no place.) Helping the populace develop "the capacity to know what their nation is doing" doesn't involve educating them about the legal basis the nation claims justifies its actions?
I guess political engagement is valuable now simply for the sake of political engagement. The point of such engagement -- ie, transforming the way the US thinks about the use of lethal force abroad, which is ineluctably shaped by the law -- is irrelevant. Very strange.
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War, foreign policy, two complex subjects with no simple answers. I read Jack Goldsmith's Op-Ed and had planned to mention it with a comment on the preceding post. I thank Mary for her post.
I recently read Robert J. Reinstein's "Slavery, Executive Power and International Law: The Haitian Revolution and American Constitutionalism" that focuses on Presidents Washington, Adams and Jefferson, dealing with foreign policy in the beginning decades of America. The Supremacy Clause of the Constitution is at the center of this paper, focusing on the "law of nations" portion. Legal arguments were involved, some being questionable. Did the Framers/Ratifiers understand the executive power over foreign policy as was developed so soon after the Constitution was adopted? Yes, there were complexities back then, including how to address Haiti, a former slave colony that revolted and declared independence. With the Constitution's slavery provisions that avoided the use of the words "slave" or "slavery," how might the new American Republic respond? I won't "spoil" how it all turned out, but my point is that the complexities of war, foreign policy go back to the beginnings. Much has been written about how from the beginning the power of the executive has increased, perhaps well beyond what originalists might claim the Constitution provided. Jack Goldsmith's Op-Ed and Mary's post do not go back to Washington, Adams and Jefferson. But what they did as executives has been built upon over the years as war, foreign policy have gotten more complex, to what we have today. Jack Goldsmith made his "bones" serving George W. Bush and cleaning up after YOO know who. President Obama has to a great extent continued the Bush policy (if you can call it a policy). History demonstrates that virtually no President willing gives up power, even if not specified in the Constitution as originalism would interpret/construe it. Consider the GOP challenges to Obama, including the proposed closing of Gitmo. The GOP is the political party of national defense whereas the Democrats had been considered weak on defense. But Obama has been tough and the GOP doesn't like it, so the political response of the GOP is that Obama is stepping on the Constitution. But that's what Bush/Cheney did for eight (8) years and it was okay. Hopefully Jack Goldsmith's Op-Ed and Mary's post will get us to focus more on the issues of war, foreign policy than the political "gotcha" game. I applaud the ACLU for pursuing the issues of drone killings of Americans overseas. If their cases go forward, perhaps we may get more transparency. By the Bybee [no, I have not forgotten him and YOO], Reinstein's paper is available at: http://ssrn.com/abstract=2205981 It is 118 pages in length, double-spaced, and provides a great deal of information on Haiti and the "law of nations."
Kevin, thanks for weighing in. The work you and others do is of course important. What I had in mind by "distraction" is a point that has been made about the post-9/11 era: that law set the boundaries of discussion, so that legal answers became the answers -- vacuuming out of the decisional process questions of morality, politics, diplomacy, etc. This point is made in different ways in David Kennedy, Of War and Law, Jack Goldsmith, Terror Presidency. It's not that law is irrelevant. It's that law does too much work in our policies on torture, targetted killing, etc.
Goldsmith's call for a new framework statute is useful -- but won't undo the structural changes in American war politics since the Cold War and Vietnam. It is those changes that have eased the American people out deep engagement with what their political leaders are doing. Getting the American people more deeply engaged is ultimately the only way their members of Congress will act as a more effective check on presidential unilateralism. This issue is discussed in my book War Time. The more detailed history of how we've gotten to where we are is the focus of the next book.
We have reentered an era of low intensity conflict police actions, essentially hunting down pirates and brigands renamed terrorists in criminal or failed states. This is nothing new. The United States military has been employed in these actions on and off for over two centuries.
The idea that we can fight these wars long distance with drones and computers and keep them antiseptic is wishful thinking. Politicians would prefer this because it keeps flag draped caskets from flying home. However, you cannot defeat irregular forces in this way. Since Obama shifted to a drone campaign in Pakistan, al Qaeda has spread across North Africa and sacked our embassy annex in Libya while a drone was flying overhead watching helplessly. Instead, these wars are fought and won by special ops and marine forces in tandem with local militaries. Fighting wars is why we hire presidents. Article II grants the president plenary power as CiC to make operational military decisions during wartime. Article I grants Congress the powers to declare offensive wars, fund them and establish rules of discipline like the UCMJ. Congress has traditionally reserved declarations of war for nation states. The AQ AUMF was an exception based upon the magnitude of the 9/11 attack and will cover any multitude of operations in the future. Congress does not have any CiC powers under Article I and Congress generally only tries to seize these when controlled by Democrats and a Republican is in the White House. The Democrat and then divide Congress has given Obama nearly free reign. The courts have no role whatsoever setting military policy. The courts have since backed off from the awful precedent established by Boumediene, perhaps realizing they have no real competence to make decisions about wartime enemy captures. In sum, pay attention when you cast a ballot for president because he or she will be setting our war policy.
I appreciate the discussion but do wonder -- especially w/o modern communications and media -- if there was as much of a shift as perhaps suggested.
Shag's reading leads me to mention "The Slave Trade and the Origins of International Human Rights Law" by Jenny S. Martinez. http://stanfordlawyer.law.stanford.edu/2011/10/the-slave-trade-and-the-origins-of-international-human-rights-law-2/
Our yodeler makes an astute observation:
"In sum, pay attention when you cast a ballot for president because he or she will be setting our war policy." Alas, not enough voters paid attention in 2004 and reelected Bush/Cheney. (WMDs?) I assume that the detailed history Mary plans for her new book will include the National Security Strategy of 2002 that included preemptive action that served as a foundation for YOO know who (whom?) that has extended into the Obama Administration's executive powers portfolio.
Professor Dudziak's post is right on the money. We focus too much on whether our war policies are properly "papered over" by law, to the exclusion of whether they are wise, moral, or even helpful to national security.
Proposals for a new "framework statute" are meaningless in the absence of true debate. At most, the statute would provide a more appealing veneer of legality on a subject that few care about. Of course it's important whether our war policies comply with law, but can't we do better than that? We are reaping the consequences of a civil-military gap that discourages civilians from engaging on issues of national security. If you tell civilians they have not earned the right to speak up on military matters because they have not served, eventually they stop engaging. The all-volunteer force, and the way we use it to stifle dissent, has broken our civil-military relations. A law professor, former Air Force officer, and author of "A More Perfect Military: How the Constitution Can Make Our Military Stronger"
3578 rentPProf. Mazur's closing paragraph is a reminder that Ike's warnings of the military/industrial complex as he departed office in 1961 were not heeded.
As a combat arms veteran from a military family with at least four generations of service, I can second Professor Mazur's observations that our nation is developing a distinct military caste which is becoming increasingly estranged from civilian society at large and in particular from a civilian political class who does not serve, rarely knows anyone who serves and often holds the military in barely concealed contempt.
Sandy offers this review of A More Perfect Military: http://www.texaslrev.com/wp-content/uploads/Levinson-TLR-Dicta.pdf However, I have not noticed a reticence by the civilian political class "from engaging on issues of national security" with the military. Militarily, the 2007 Congress was more than willing to oppose Gen. Petreaus' Iraq surge plan in favor of surrendering Iraq to al Qeada and President Obama gutted the Afghan surge plan offered to him. Socially, the President has recently ordered the services to allow homosexuals to serve openly and women to serve in combat arms positions for which almost all of them are unqualified. Given this backdrop, I am more concerned about a military caste - which is generally more educated, competent and popular with the people than the political class placed in authority above them - deciding one day to launch a coup de tat because of a lack of reticence by the political class. Will our future look something like the republic in Heinlein's Starship Troopers?
"The courts have no role whatsoever setting military policy."
Not even in applying the UMCJ or in holding us to treaties? Art. III expressly contemplates the judiciary having a role in the latter: "The judicial power shall extend to all cases, in law and equity, arising under this Constitution, the laws of the United States, and treaties made, or which shall be made, under their authority" "I am more concerned about a military caste - which is generally more educated, competent and popular with the people than the political class placed in authority above them - deciding one day to launch a coup de tat because of a lack of reticence by the political class" So we should let the military do whatever it wants because you're worried if we don't they might take over and do whatever they want?
Our yodeler minored in economics in college, he has said, to support his expertise in economics and challenges of Nobelist Paul Krugman, although his day job is as a DUI legal specialist in a little mountain community in the Mile High State (of mind). Now he professes to have military expertise based upon the history of his family in the military. He doesn't reveal the extent of the military experiences of him and his prior generations to give us an idea of his special qualifications on military strategy. For all we know, our yodeler was a grunt in the military, not that there is anything wrong with that. But consider the leaps our yodeler makes with this:
"Militarily, the 2007 Congress was more than willing to oppose Gen. Petreaus' Iraq surge plan in favor of surrendering Iraq to al Qeada and President Obama gutted the Afghan surge plan offered to him." The 2007 Congress was controlled by the Democrats. Our yodeler seems to blame the Democrats for the Iraqi War. There are serious questions about the success of the surge and what it actually accomplished, besides killing off or getting certain Iraqis to leave their communities and even Iraq for survival because of the Iraqi leaders' religious biases. Our yodeler seems to claim that Petraeus walks on water when it comes to surges. Well, the surge in Afghanistan was different than in Iraq. Obama bought into it but the situation in Afghanistan was substantially different than in Iraq. The history of Afghanistan with invasions by several powerful nations substantially differs from Iraq's history. Would Petraeus' Afghan surge have worked? I wouldn't rely upon our yodeler's military expertise. Some, many, say it was a mistake. Perhaps our yodeler doesn't buy into Ike's concerns with the military/industrial complex. Consider the history of that complex since 1961 and especially the Halliburton Happy Hours during the Bush/Cheney days. Perhaps our yodeler missed his true casting call.
BD: "The courts have no role whatsoever setting military policy."
Mr. W: Not even in applying the UMCJ or in holding us to treaties? Congress sets the policy for military discipline by enacting and amending the UCMJ. The courts merely enforce the UCMJ. Likewise, treaties are the policy. The courts only enforce and do not enter in treaties. Additionally, presidents and Congress can and have repeatedly withdrawn from treaties when they deem them against current national interests. The courts can only enforce treaties the elected branches still recognize. BD: "I am more concerned about a military caste - which is generally more educated, competent and popular with the people than the political class placed in authority above them - deciding one day to launch a coup de tat because of a lack of reticence by the political class" Mr. W: So we should let the military do whatever it wants because you're worried if we don't they might take over and do whatever they want? I figured Shag would beat you to this straw man. The problem is not the concept of civilian command of the military. The problem is the formation of a military caste and a civilian ruling class and their subsequent estrangement. This is something we as a country need to deal with before estrangement leads to something worse.
If treaties and the UMCJ are the law of the land, then Courts should enforce them, no? "The problem is the formation of a military caste and a civilian ruling class and their subsequent estrangement" Ok, but didn't you suggest that a 'lack of reticence' on the part of the civilian class was what you feared would trigger the horrible? If you dress something up in straw, plaid and overalls don't be upset when someone calls it a strawman.... I am interested in what you think should be done about this problem. I doubt a draft would fit well with your libertarian leanings.
Mr. W:
I have been thinking about this problem for a long time and I am unsure whether it has a libertarian solution. The Germans dealt with the problem of a military caste by shrinking their military down to the size of a glorified national police force and compelling those who those who would otherwise not join the military to do so through a draft. Libertarians would have no problem with shrinking the US military down to a glorified militia, which is where I differ from the libertarians. However, most Americans do and should oppose drafts unless we are facing an existential threat. So long as those of us from military families keep serving and those from the civilian ruling class avoid it like the plague, I am unsure how we bridge that divide. The civilian ruling class does have a libertarian solution. Shrink the size of government down to its pre-progressive size and elect people from outside the current ruling class who represent your values. Most Americans would have supported military requests for troops and opposed nonsense like putting women into combat arms, removing the provocations to the military.
I agree with you it could be a problem. I also agree with you that drafts are going to be unpopular and that shrinking our military down to a glorified police force is not going to happen and probably should not. Perhaps if we involved our military in less action it would not appeal to only the most military minded families. I have to question your claim that the military class is generally more educated than civilian leaders. Do you have any citation for that? The average politician is a lawyer with a JD, that's seven years of college. I don't think the average member of the military class can match that. "The civilian ruling class does have a libertarian solution. Shrink the size of government down to its pre-progressive size" If anything our government was more elitist in the days of the Founding than it is now. "Most Americans would have supported military requests for troops and opposed nonsense like putting women into combat arms" I doubt that seriously. The public opposed the surge for example, and would like us to get out of Afghanistan and Iraq faster than we are and were. Polls also show majorities supporting women in combat. "By a margin of two-to-one, Americans support allowing women to serve in combat units, a policy change announced last week by outgoing Defense Secretary Leon Panetta. Sixty-six percent of Americans favor the new policy, up from 53 percent when approval was last measured in July 2009. Thirty percent of Americans now disapprove." http://www.cbsnews.com/8301-34222_162-57567013-10391739/poll-most-support-women-in-combat/
Mr. W: I have to question your claim that the military class is generally more educated than civilian leaders. Do you have any citation for that? The average politician is a lawyer with a JD, that's seven years of college. I don't think the average member of the military class can match that.
I do not equate education with the number of years you spend in school and do not think much of law degrees in general. In Germany, law is simply a five year undergraduate course. I do not think that a law degree qualifies you to do much of anything except regurgitate basic legal theory. You are not particularly qualified to set policy and you learn to practice law afterwards. As for the military: In 2004, 92.1 percent of active-duty officer accessions held baccalaureate degrees or higher.[5] From 2000 to 2005, between 10 percent and 17 percent of active-duty officer accessions held advanced degrees, and between 35 percent and 45 percent of the active-duty officer corps held advanced degrees.[6] This indicates that officers continued their education during the course of their military service. http://www.heritage.org/research/reports/2006/10/who-are-the-recruits-the-demographic-characteristics-of-us-military-enlistment-2003-2005 These are generally policy degrees like foreign affairs, political science and governance to prepare officers for running foreign countries. Moreover, officers go through extensive military training to run the equivalent of massive international companies. The political class does not compare. "B.D.: Most Americans would have supported military requests for troops and opposed nonsense like putting women into combat arms" Mr. W: "By a margin of two-to-one, Americans support allowing women to serve in combat units, a policy change announced last week by outgoing Defense Secretary Leon Panetta. Sixty-six percent of Americans favor the new policy, up from 53 percent when approval was last measured in July 2009. Thirty percent of Americans now disapprove." "Serve in combat units" is intentionally vague. A Stars and Stripes reporter can and do serve with combat units. Ask instead whether women should serve in the infantry, armor and artillery; and more importantly whether the services should lower their physical standards to accomplish this.
1. You're just citing numbers for officers, which are only anywhere from 10-20% of all active duty personnel (depending on the branch). 2. Even if we stick to officers I don't think they match the educational attainment of Congresspersons "As has been true in recent Congresses, the vast majority of Members (92% of House Members and 99% of Senators) at the beginning of the 112th Congress held bachelor's degrees.13 The CQ Roll Call Member Profiles indicate that 25 Members of the House and 1 Senator have no educational degree beyond a high school diploma.14 Seven Members of the House, but no Senators, have associate's degrees as their highest degree, and one House Member has an LPN (nursing) degree. Eighty-three Members of the House and 16 Senators earned a master's degree as their highest educational degree. Law degrees are held by 167 Members of the House (38% of the total House) and 55 Senators (55% of the total Senate). Of the Members holding a law degree, four (three House Members and one Senator) also hold an LLM (Master of Laws) degree. Eighteen Representatives (but no Senators) have doctoral (Ph.D.) degrees, and 20 Members of the House and 4 Senators have a medical degree.15" http://www.fas.org/sgp/crs/misc/R41647.pdf
The NYTimes Book Review includes Andrew Bacevich's "Avoiding Defeat" reviews of "The Endgame - The Inside Story of the Struggle for Iraq, from George W. Bush to Barack Obama" (by Michael R. Gordon and Bernard E. Trainor) and "My Share of the Task - A Memoir" (by Stanley McChrystal), that includes commentary on the "surge." (A link is provided at the Legal History Blog.) Here's a taste:
"Future historians may well classify the surge as a myth concocted to perpetuate a fraud. The myh centers on the claim that a strategy devised in Washington and implemented by a brilliant general saved the day. The fraud is that a 20-year millitary effort to determine the fate of Iraq yielded something approximating a positive outcome."
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Proposals for a new "framework statute" are meaningless in the absence of true debate. At most, the statute would provide a more appealing veneer of legality on a subject that few care about. Of course it's important whether our war policies comply with law, but can't we do better than that?
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Griffin, Broken Trust: Dysfunctional Government and Constitutional Reform (University Press of Kansas, 2015) Frank Pasquale, The Black Box Society: The Secret Algorithms That Control Money and Information (Harvard University Press, 2015) Bruce Ackerman, We the People, Volume 3: The Civil Rights Revolution (Harvard University Press, 2014) Balkinization Symposium on We the People, Volume 3: The Civil Rights Revolution Joseph Fishkin, Bottlenecks: A New Theory of Equal Opportunity (Oxford University Press, 2014) Mark A. Graber, A New Introduction to American Constitutionalism (Oxford University Press, 2013) John Mikhail, Elements of Moral Cognition: Rawls' Linguistic Analogy and the Cognitive Science of Moral and Legal Judgment (Cambridge University Press, 2013) Gerard N. Magliocca, American Founding Son: John Bingham and the Invention of the Fourteenth Amendment (New York University Press, 2013) Stephen M. Griffin, Long Wars and the Constitution (Harvard University Press, 2013) Andrew Koppelman, The Tough Luck Constitution and the Assault on Health Care Reform (Oxford University Press, 2013) James E. Fleming and Linda C. McClain, Ordered Liberty: Rights, Responsibilities, and Virtues (Harvard University Press, 2013) Balkinization Symposium on Ordered Liberty: Rights, Responsibilities, and Virtues Andrew Koppelman, Defending American Religious Neutrality (Harvard University Press, 2013) Brian Z. Tamanaha, Failing Law Schools (University of Chicago Press, 2012) Sanford Levinson, Framed: America's 51 Constitutions and the Crisis of Governance (Oxford University Press, 2012) Linda C. McClain and Joanna L. Grossman, Gender Equality: Dimensions of Women's Equal Citizenship (Cambridge University Press, 2012) Mary Dudziak, War Time: An Idea, Its History, Its Consequences (Oxford University Press, 2012) Jack M. Balkin, Living Originalism (Harvard University Press, 2011) Jason Mazzone, Copyfraud and Other Abuses of Intellectual Property Law (Stanford University Press, 2011) Richard W. Garnett and Andrew Koppelman, First Amendment Stories, (Foundation Press 2011) Jack M. Balkin, Constitutional Redemption: Political Faith in an Unjust World (Harvard University Press, 2011) Gerard Magliocca, The Tragedy of William Jennings Bryan: Constitutional Law and the Politics of Backlash (Yale University Press, 2011) Bernard Harcourt, The Illusion of Free Markets: Punishment and the Myth of Natural Order (Harvard University Press, 2010) Bruce Ackerman, The Decline and Fall of the American Republic (Harvard University Press, 2010) Balkinization Symposium on The Decline and Fall of the American Republic Ian Ayres. Carrots and Sticks: Unlock the Power of Incentives to Get Things Done (Bantam Books, 2010) Mark Tushnet, Why the Constitution Matters (Yale University Press 2010) Ian Ayres and Barry Nalebuff: Lifecycle Investing: A New, Safe, and Audacious Way to Improve the Performance of Your Retirement Portfolio (Basic Books, 2010) Jack M. Balkin, The Laws of Change: I Ching and the Philosophy of Life (2d Edition, Sybil Creek Press 2009) Brian Z. Tamanaha, Beyond the Formalist-Realist Divide: The Role of Politics in Judging (Princeton University Press 2009) Andrew Koppelman and Tobias Barrington Wolff, A Right to Discriminate?: How the Case of Boy Scouts of America v. James Dale Warped the Law of Free Association (Yale University Press 2009) Jack M. Balkin and Reva B. Siegel, The Constitution in 2020 (Oxford University Press 2009) Heather K. Gerken, The Democracy Index: Why Our Election System Is Failing and How to Fix It (Princeton University Press 2009) Mary Dudziak, Exporting American Dreams: Thurgood Marshall's African Journey (Oxford University Press 2008) David Luban, Legal Ethics and Human Dignity (Cambridge Univ. Press 2007) Ian Ayres, Super Crunchers: Why Thinking-By-Numbers is the New Way to be Smart (Bantam 2007) Jack M. Balkin, James Grimmelmann, Eddan Katz, Nimrod Kozlovski, Shlomit Wagman and Tal Zarsky, eds., Cybercrime: Digital Cops in a Networked Environment (N.Y.U. Press 2007) Jack M. Balkin and Beth Simone Noveck, The State of Play: Law, Games, and Virtual Worlds (N.Y.U. Press 2006) Andrew Koppelman, Same Sex, Different States: When Same-Sex Marriages Cross State Lines (Yale University Press 2006) Brian Tamanaha, Law as a Means to an End (Cambridge University Press 2006) Sanford Levinson, Our Undemocratic Constitution (Oxford University Press 2006) Mark Graber, Dred Scott and the Problem of Constitutional Evil (Cambridge University Press 2006) Jack M. Balkin, ed., What Roe v. Wade Should Have Said (N.Y.U. Press 2005) Sanford Levinson, ed., Torture: A Collection (Oxford University Press 2004) Balkin.com homepage Bibliography Conlaw.net Cultural Software Writings Opeds The Information Society Project BrownvBoard.com Useful Links Syllabi and Exams |


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Treatment of fractures
Cardiovascular consultation is the most important aspect of medical treatment. It is an opportunity for patients to discuss about their cardiac problems, current complaints, understand the risks and complications, and to adopt healthy lifestyle habits.
Appointment duration:
30 mins
Appointment price:
What is Involved with a Comprehensive Treatment of fractures?
The heart supplies blood to all organs of the body, nourishes them and provides energy. When your heart refuses to work, anything can become the reason.
Forms a wide range of diagnostic and medical capabilities for the treatment of all types of cardiovascular diseases.
The breadth of knowledge and many years of experience make it possible to quickly and accurately formulate a diagnosis and provide effective treatment – even in complex cardiological cases.
Physician consultation is a good opportunity and you should be prepared for it.
- Carry all necessary medical records for the discussion. It helps in better understanding your heart condition and avoids repetition of diagnostic tests.
- Make sure you discuss your past medical history, surgical history, family history, and medications that you are taking.
- Discuss about your lifestyle habits, dietary habits and also about your profession. Your lifestyle and nature of job may be associated with the risk for cardiac diseases.

subset: commoncrawl


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1970S SAKS FIFTH AVENUE Orange & Green Floral Cotton Sateen House Coat Dress With Patch Pockets
Estimated Delivery: 07/28/2024 - 07/30/2024
MORPHEW VINTAGE represents the finest pieces of fashions past. Sourced from across the globe, dating as far back as a century. Each piece is selected with both quality and rarity in mind. Often referred to as investment vintage, Morphew assures that from rare Victorian laces to the most coveted designer collections, each piece has stood the test of time, representing an important and valuable moment of fashion history.
Decade: 1970s.
Material: Cotton Sateen.
Vintage condition: Good.
Return Policy
A return for this item may be initiated within 1 day of delivery.
Buyer is responsible for return shipping charges and will not be reimbursed for the original shipping cost.
Additional Notes
We require 24hrs notice of return from when the package arrives at the client's door. Client must provide a tracking number for return item the same day the notice is given... No exceptions.


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Customer loyalty programs have been around for years. You think nothing of giving the supermarket or pet supply store your personal information. In exchange you get a card or a key ring tag that you present at checkout to get a discount.
Now wireless carriers are taking it a step further, raising alerts from privacy advocates.
Verizon and AT&T recently launched programs allowing customers to receive rewards based on information their smartphones share with the carriers.
Verizon's program, called Verizon Selects, "will use location, web browsing and mobile application usage data, as well as other information including customer demographic and interest data, to create specific insights" about customers, Torod Neptune, vice president of corporate communications for Verizon Wireless, said on the company's website.
"Verizon Selects analyzes this information about customers to see whether they fit into certain audiences Verizon or third party marketers are trying to reach," Neptune said. "Depending on the results, participating customers will receive marketing messages or offers that may be of more interest to them than what they see or receive today."
AT&T said its program, called AT&T Alerts, will use "geo-location technology" to offer customers "discounts, rewards and offers via text message when they are near participating retailers and brands," including Gap, Staples and Zales.
GigaOM gives this example: "If you're approaching a Gap, for example, AT&T ships you [a] text message out of the blue with a link to a coupon for jeans."
Both AT&T and Verizon say the programs will work on an opt-in basis — only customers who choose to participate will do so. And they emphasize that they won't share personal information with other companies. Verizon said it will offer the program to some of its customers, in what GigaOM described as a pilot program, while AT&T has a sign-up page.
"It's important to remember that Verizon DOES NOT share information that identifies customers personally outside of Verizon," Verizon said.
On its website, AT&T said, "Your personal information will not be used outside of the AT&T Alerts program." And its terms of use point to the company's privacy policy, which says, "We do not provide Personal Information to non-AT&T companies for the marketing of their own products and services without your consent."
But privacy groups say such programs are deceptive and potentially illegal.
"Users' location data, web browsing histories, internet search terms, demographic information, and mobile device usage information are often personally identifiable," the Electronic Privacy Information Center said in an October 2011 complaint with the Federal Trade Commission regarding Verizon's business practices.
"Verizon Wireless's collection and disclosure of this personal information violates user expectations, diminishes user privacy, and contradicts Verizon Wireless's own representations," EPIC said in the complaint. "These business practices are Unfair and Deceptive Trade Practices ..."
And the Electronic Frontier Foundation says that even the practice of aggregating personal data can violate privacy provisions. As CNET reported in October 2012:
"Hanni Fakhoury, a staff attorney at the Electronic Frontier Foundation in San Francisco, said a wireless carrier that discloses information about which URLs a customer visits could run afoul of the Wiretap Act. In general, the law says, carriers may not 'divulge the contents of any communication.'
" 'I don't see any substantive difference between collecting content from one person and turning it over to someone, and collecting it from multiple people, aggregating that information and then turning the aggregated data over to someone else,' Fakhoury says. 'In the end, there is still a capturing of content from the user at some point — and that's what the potential (Wiretap Act) problem is.' "
In addition to Verizon Selects, the company offers businesses a program called Precision Market Insights, which it describes on its site:
"Our solutions capture information from the physical and digital worlds simultaneously to deliver unparalleled audience and location measurement, mobile marketing and predictive analytics based on what audiences actually do, where they actually go and what they actually like."
Verizon tells retailers the data can be used to "drive sales by enhancing customer satisfaction":
"Using location data, mobile-browsing trends and location-specific analytics, you can now determine what your customer base really looks like and how to best serve them. Our tools can help you provide a more targeted retail experience to meet consumers' wants and needs in a specific area."
Copyright 2021 NPR. To see more, visit https://www.npr.org.


text: Find the right tables and chairs to match your theme right here! While you're ordering, rent a couple extra seats to have around in case of any unexpected guests, or breakages - and be sure to order them in advance so that you can take your time setting up! Search here for Tables & Chairs in your local area.


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Stand Panel L/H - Hino Pro 500 Series GD FG FL FM FT GH GT 2003 On
Check availability
Stand Panel L/H to suit Hino Pro and 500 Series GD models 2003 to 2010. FG, FL, FM, FT and GH models 2003 to 2017 (February). GT models 2003 on.
Note: Not for FM1A models.
Stand Panel L/H to suit Hino Pro and 500 Series GD models 2003 to 2010. FG, FL, FM, FT and GH models 2003 to 2017 (February). GT models 2003 on.
Note: Not for FM1A models.
Part | HM03-SPL17 |
Steps & Parts | Left |
Country of Manufacture | Taiwan |
Description | Stand Panel L/H to suit Hino Pro and 500 Series GD models 2003 to 2010. FG, FL, FM, FT and GH models 2003 to 2017 (February). GT models 2003 on. Note: Not for FM1A models. |
Same Day Dispatch
Orders finalised before 2pm Monday to Friday are dispatched same day from our warehouses in NSW and WA.
In-store Pick Up
"In-store Pickup" orders collections can be made between 8am - 4:30pm Monday to Friday.
Shipping Carriers
We ship with various carriers that we've found to be the most reliable and competitively priced.
These carriers include: Australia Post, Capital Transport, CTI Regional Logistics, Fedex Express, GMK Logistics, Go Logistics, PEP Express Transport, Tamex and TNT Express.
Online Shipping Calculator
Our online shipping calculator factors many variables that are associated with shipping our products. These include: freight carriers that service your area, orders containing multiple items, oversize packages, pallets and skids, commercial and residential addresses.
The price displayed for each shipping service is the cheapest available for that service from our list of carriers.
If you have an order that contains numerous items and would prefer a custom shipping quote, please select the "Request Custom Shipping Quote" at the checkout.
Residential Delivery Addresses
All freight carriers other than Australia Post have surcharges to deliver to residential addresses. These surcharges can be rather costly for oversize items. Unfortunately, residential surcharges are out of our control. To avoid residential surcharges, customers are advised to use a commercial address for delivery.
Commercial Delivery Address
Commercial delivery address refers to a delievry address that is situated in a commercial / industrial area only. All other addresses are considered residential.
Orders with "Commercial Delivery" Costs Applied Where The Address Is "Residential Delivery"
In the event of online orders incorrectly submitted by the user with "Commercial Delivery selected rather than "Residential Delivery", the order must be rectified with the correct shipping costs before the order will be dispatched.
Order Tracking
Upon order dispatch, a tracking number will be provided to you. You will be able to track your order online.
Shipping Addresses Unattended At Time Of Delivery
Unless requested by the customer, all shipping carriers have authority to leave goods if the shipping address is unattended at the time of delivery.
Customers are welcome to provide an alternate shipping address if they will not be present at the delivery time.
Proof of delivery is made available by all shipping carriers.
International Shipping
Shipping is available throughout Australia, New Zealand and the Pacific Region. Please select the "Request Custom Quote" shipping option during checkout to receive a shipping quote.
Customers are also welcome to arrange their own international freight. In this case we will provide the order shipping dimensions and weight.


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What Exactly Is a Black Eye?
A black eye, also known as a periorbital hematoma, is usually not an injury of the actual eye (which is why it is called "periorbital"- around the eye). It typically occurs when there is an injury to the face or the eye socket which causes bleeding beneath the skin and bruising. The term, "black eye" comes from the dark coloring of the bruising that occurs underneath the skin around the eye.
When a blunt force hits the eye socket, this can cause capillaries in the area to burst, causing hemorrhaging, also known as a hematoma. This blood can accumulate in the eye socket and as it begins to be reabsorbed into the surrounding tissues, the colors of the bruising begin to change. That's why you will often notice the coloring of the black eye to go from a dark purplish-red color to brownish and then yellow.
Sometimes along with the external bruising, you might also notice a small amount of bleeding on the white surface of the eye, which is called a subconjunctival hemorrhage. This is when the tiny blood vessels on the white sclera are broken and leak blood. It's generally harmless but sometimes looks scarier to the patient than the black eye does. This condition will also reabsorb on its own and is nothing to be concerned about.
While most black eyes can look pretty serious due to the dramatic color, an uncomplicated black eye will typically heal within a week to ten days. If it doesn't, there could be a more serious issue such as a bone fracture or an orbital blowout fracture.This could present with restricted eye movement, especially if looking up or down, and numbness of the cheek and/or upper lip on the same side as the black eye. The eye may even appear sunken in. Further, if there is bleeding within the actual eye (called a hyphema) or floaters or flashes in the vision, then it is definitely advisable to see your eye doctor as soon as possible. These could be signs of more serious damage such a corneal or retinal damage and can lead to vision loss.
Treatment for a Black Eye
Usually, the best treatment for a black eye is to apply a cold compress (or even better, a bag of frozen vegetables, which is more flexible and can conform to the contours of the face) directly on the area. The cold will reduce swelling and constrict capillaries to reduce internal bleeding as well. Apply the cold for about 15-20 minutes every hour. If there is pain, over the counter pain medications can help.
If however, you experience any of the following symptoms, you should seek medical attention:
- Blood on the surface of the eye or a visible incision on the eye
- Vision changes such as double vision, blurred vision, loss of vision or the appearance of floaters
- Loss of consciousness, dizziness or fainting
- Loss of eye movement
- Persistent headaches
- Blood or fluids coming from the ears or nose
- Vomiting
- Signs of infection such as excessive swelling, pus, redness or a fever
- Severe pain
In addition to blunt trauma, black eyes can be caused by sinus infections, nasal or eye surgery or other infections in the area such as the teeth infections or cellulitis (a serious infection that can occur around the eyes). A skull fracture can also cause both eyes to turn black, sometimes known as raccoon eyes.
Unless you notice any severe symptoms you can rest assured that your black eye is a bruise just like anywhere else on the body and with a little care, rest and patience, it will clear up in no time.


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Plumbing Repair Services Aransas Pass, TX
Are you needing plumbing repair in Aransas Pass, TX? Bro's Handyman Service can assist you with your handyman plumbing repair needs in Aransas Pass, TX. Whether you are having issues with a leaky faucet, leaky plumbing pipe, no hot water, or any other plumbing repair — contact Bro's Handyman Service for 24/7 plumbing repair in Aransas Pass, New York.
Common issues our handyman plumbers can handle are: noisy pipes, gas smalls, frozen popes, clogged or slow draining, poor water pressure, loose fixtures, leaking pipes, no hot water, fixture not working correctly, etc..
For professional and affordable plumbing repair Aransas Pass, TX, please call us at 1-855-661-3672.
Get An Estimate!Plumbing Repair Cost Aransas Pass, TX
Are you looking for approximate cost's for plumbing repair in Aransas Pass, New York? If so, you've come to the right place, however keep in mind it's always best to call and speak with a Aransas Pass plumber about your actual job.
Typically, home and business owners report a cost range of $150 to $375 when paying for plumbing repair in Aransas Pass, TX. If paying by the hour, plumbers may charge between $50 to $150 per hour for plumbing repair jobs.
When you need affordable plumbing repair service in Aransas Pass, TX — get in touch with the handyman plumbers at Bro's Handyman Service. We'd love to help you with your plumbing repair needs!
Handyman Plumbers Aransas Pass, TX
It's easy to take our plumbing systems for granted. Pipes, water heaters, faucets, sewer lines and gas lines are all components that we simply expect to work flawlessly without too much attention and care. When these systems malfunction or require replacement, it's often unexpected and unwelcome. No one wants to spend time or money repairing their plumbing systems, and they certainly don't want to spend a lot of their resources. At Bro's Handyman Service, we get it, and we work hard to offer comprehensive service that creates minimal disruption and cost.
Hire a handyman plumber Aransas Pass, TX for your plumbing repair needs! Save money but get the same excellent service you'd receive from a plumber! We have a reputation for simple, effective service designed to genuinely benefit the customer — so contact us today and see why we are your preferred choice for plumbing repairs in Aransas Pass, TX.
Aransas Pass Plumbing Repair Emergency
Are you experiencing an emergency need for plumbing repair in Aransas Pass, TX? Don't worry, we've got you covered with our 24/7 plumbing emergency Aransas Pass, TX service. Simply call us NOW, and you'll be connected to our service pro's.
You can reach our Aransas Pass emergency plumbers at 1-855-661-3672. Emergencies can be toilet or drain clogs, a toilet that is not working or anything else that is inconvenient for you! In most cases, emergency plumbing repair service in Aransas Pass, TX will result in an added fee of not more than $99.
It doesn't matter whether you've experienced a leaky toilet, a clogged kitchen sink, or a backed-up sewer line — Bro's Handyman Service is just one call away for a quick, affordable solution!


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This website collects personal information using first and third-party cookies, persistent trackers, and similar technologies (e.g., MetaPixel) to help us operate this website, provide you with a more personalized user experience, and provide advertisements. The information we collect is shared with our advertising, social media, and analytics partners. Further use of our website or by clicking "Agree" will indicate your agreement to our use of technologies, the Privacy Policy, and the Terms of Use, which includes a binding arbitration clause and jury waiver.


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WACO - Power poles in as many as five Central Texas counties were burning Thursday morning, [Dec. 6th] and authorities were trying to find out why.
A Department of Public Safety communications officer said power poles in Hill, Falls, Bell, Williamson and McLennan counties mysteriously began bursting into flames at about 4 a.m. Thursday.
He said the fires that had been reported were burning at the tops of the poles, some involving transformers.
Various power company representatives had been dispatched to survey the damage and several fire departments were sent to douse the flames.
One power company technician told a News 10 reporter near McGregor that the fires likely were caused by a build up of dust on transformers that shorted out due to low-lying fog.
Mike Cain, spokesman for Oncor, said he could not confirm that cause for all the locations but that power company inspectors were out trying to determine the cause of the fires.
The Oncor web page showed a total of 4,253 customers without power in McLennan, Bell, Falls and Williamson counties as of 8 a.m.
Cain said crews should have power restored to those customers by mid-day.
As many as 30 power poles were burning in one area of Hill County, just off Interstate 35 at mile marker 361.
As many as 20 poles were reported burning in Bynum east of Hillsboro and and others in the Aquilla area where some customers were without power.
There were poles on fire along Highway 6 near Falls County roads 112 and 113 that had forced closure of Highway 6 and had stopped trains along an adjacent railroad line for about an hour but traffic was moving normally by about 5:45 a.m.
Some limited power outages were reported in the area around Perry, just north of Marlin.
Power pole fires also were reported in at least two locations in Waco, just north of Troy, just south of the Falls County line on Interstate 35 in Bell County, near Lorena and west of Waco along U.S. Highway 84.
Areas of west Waco were without power at about 6:20 a.m.after transformers failed near Hillcrest Hospital.
Baylor University reported portions of campus were in the dark at about 7 a.m.
Traffic lights were reported out at Texas Central Parkway near Imperial Drive and along Bagby near the Marketplace.
Police officers had been dispatched to direct traffic as commuters headed out for the morning.
Fire departments in McGregor and Moody were dealing with power pole fires as well.


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When considering portfolio allocation, it's important to keep in mind the wide dispersion of returns among economies. Dina Ting, Franklin Templeton's Head of Global Index Portfolio Management, assesses the recent dislocation among global equity returns, with a look at one notable inflation outlier—Japan.
This material is intended to be of general interest only and should not be construed as individual investment advice or a recommendation or solicitation to buy, sell or hold any security or to adopt any investment strategy. It does not constitute legal or tax advice. This material may not be reproduced, distributed or published without prior written permission from Franklin Templeton.
The views expressed are those of the investment manager and the comments, opinions and analyses are rendered as at publication date and may change without notice. The underlying assumptions and these views are subject to change based on market and other conditions and may differ from other portfolio managers or of the firm as a whole. The information provided in this material is not intended as a complete analysis of every material fact regarding any country, region or market. There is no assurance that any prediction, projection or forecast on the economy, stock market, bond market or the economic trends of the markets will be realized. The value of investments and the income from them can go down as well as up and you may not get back the full amount that you invested. Past performance is not necessarily indicative nor a guarantee of future performance. All investments involve risks, including possible loss of principal.
Any research and analysis contained in this material has been procured by Franklin Templeton for its own purposes and may be acted upon in that connection and, as such, is provided to you incidentally. Data from third party sources may have been used in the preparation of this material and Franklin Templeton ("FT") has not independently verified, validated or audited such data. Although information has been obtained from sources that Franklin Templeton believes to be reliable, no guarantee can be given as to its accuracy and such information may be incomplete or condensed and may be subject to change at any time without notice. The mention of any individual securities should neither constitute nor be construed as a recommendation to purchase, hold or sell any securities, and the information provided regarding such individual securities (if any) is not a sufficient basis upon which to make an investment decision. FT accepts no liability whatsoever for any loss arising from use of this information and reliance upon the comments, opinions and analyses in the material is at the sole discretion of the user.
Products, services and information may not be available in all jurisdictions and are offered outside the U.S. by other FT affiliates and/or their distributors as local laws and regulation permits. Please consult your own financial professional or Franklin Templeton institutional contact for further information on availability of products and services in your jurisdiction.
Brazil: Issued by Franklin Templeton Investimentos (Brasil) Ltda., authorized to render investment management services by CVM per Declaratory Act n. 6.534, issued on October 1, 2001. Canada: Issued by Franklin Templeton Investments Corp., 200 King Street West, Suite 1500 Toronto, ON, M5H3T4, Fax: (416) 364-1163, (800) 387-0830, www.franklintempleton.ca. Offshore Americas: In the U.S., this publication is made available by Franklin Templeton, One Franklin Parkway, San Mateo, California 94403-1906. Tel: (800) 239-3894 (USA Toll-Free), (877) 389-0076 (Canada Toll-Free), and Fax: (727) 299-8736. U.S. by Franklin Templeton, One Franklin Parkway, San Mateo, California 94403-1906, (800) DIAL BEN/342-5236, franklintempleton.com. Investments are not FDIC insured; may lose value; and are not bank guaranteed.
Issued in Europe by: Franklin Templeton International Services S.à r.l. – Supervised by the Commission de Surveillance du Secteur Financier - 8A, rue Albert Borschette, L-1246 Luxembourg. Tel: +352-46 66 67-1 Fax: +352-46 66 76. Poland: Issued by Templeton Asset Management (Poland) TFI S.A.; Rondo ONZ 1; 00-124 Warsaw. South Africa: Issued by Franklin Templeton Investments SA (PTY) Ltd, which is an authorized Financial Services Provider. Tel: +27 (21) 831 7400 Fax: +27 (21) 831 7422. Switzerland: Issued by Franklin Templeton Switzerland Ltd, Stockerstrasse 38, CH-8002 Zurich. United Arab Emirates: Issued by Franklin Templeton Investments (ME) Limited, authorized and regulated by the Dubai Financial Services Authority. Dubai office: Franklin Templeton, The Gate, East Wing, Level 2, Dubai International Financial Centre, P.O. Box 506613, Dubai, U.A.E. Tel: +9714-4284100 Fax: +9714-4284140. UK: Issued by Franklin Templeton Investment Management Limited (FTIML), registered office: Cannon Place, 78 Cannon Street, London EC4N 6HL. Tel: +44 (0)20 7073 8500. Authorized and regulated in the United Kingdom by the Financial Conduct Authority.
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Please visit www.franklinresources.com to be directed to your local Franklin Templeton website.
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49 Spence Road, GRIFFITH
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A microchip is about the size of a grain of rice and is injected under your pet's skin. It can be done during a normal consultation. The microchip is embedded with a code unique to your pet and is the most effective form of permanent identification. This code is placed onto a national computer database, so it is particularly useful in the return of lost pets. They can also assist where the ownership of an animal is in dispute. In some states of Australia microchipping of pets is now compulsory.
If a pet is ever lost and is handed in at a veterinary clinic or animal shelter a microchip scanner is passed over the animal to reveal the unique code. The vet or animal shelter can then refer to the database to identify the name, address and phone number of the owner, so they can be reunited.
If your pet is not microchipped please give us a call to make an appointment to have one inserted. If you find a lost pet please call us to arrange a scan; we can reunite microchipped pets with their worried owners.


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Size Chart - Mens
Mens Indycar Crewneck Sweatshirt
The Men's Indycar Crew Neck Sweatshirt midlayer merges style, comfort, and your passion for racing. The set-in long sleeves and crew neckline ensure a classic finish, with screen-printed graphics to show your team support. Available in a classic relaxed fit for ultimate comfort for everyday wear
The Men's Arrow McLaren IndyCar Team crewneck sweatshirt merges style, comfort, and your passion for racing. The set-in long sleeves and crew neckline ensure a classic finish, with screen-printed graphics to show your team support. Available in a classic relaxed fit for ultimate comfort for everyday wear – or in the stands.
- Classic fit
- Crew neckline
- Set-in long sleeves
- Screen-printed team graphics at front and back
Normal wash process at 30°C. Do not bleach. Do not tumble dry. Iron at maximum sole plate temperature (110°C) without steam. Do not dry clean. Do not iron print. Do not use biological detergents.
When your order is shipped, we will send you a confirmation email. We use Omni Parcel for all international shipments, delivery dates and times are calculated at checkout. We use Evri for UK shipments, a signature may be required upon delivery of your order. We offer free delivery on all orders over £75.
All orders placed with Express Delivery/Next Day Delivery, refer to Next Working Day and will only be dispatched in time if placed on Monday-Friday before 5pm.
The postcodes that are the exception for the latest collection are:
Please be aware that our service is not a named delivery service and anyone at the designated delivery address may sign for your delivery. We will not be liable for a lost or missing order that has been signed for in a building, for example, an office address that has been provided for delivery.
Please ensure that when placing an order that the country of shipping destination is selected correctly. This is to ensure no extra charges are applied at customs.
Please note that some products are fulfilled by third parties and will dispatch from their warehouses separately from any other items ordered on-site. These products may be subject to additional shipping charges that will be applied at checkout. These may also be excluded from any other offers, discounts and shipping rules.
These Third parties include:
- SunGod
- Automobilist
- Pure Electric
To contact us regarding all shipping click here.
If you are not completely happy with your purchase, please return it to us in its original condition.
Items should be returned within 14 days from your delivery date, and we will refund you the original purchase price. The garments must be unused and with all relevant tags still attached. Our packaging is a part of the product and must be returned with the goods. This is also to ensure that the product(s) arrive back to us in a suitable and undamaged state. Returns that are damaged or soiled may not be accepted and may be sent back to the customer and/or a refund refused. Refunds exclude any delivery & shipping costs.
Please note we are currently not offering exchanges; we do apologise for the inconvenience this may cause. Additionally, personalised items are not eligible for return and will be refused and sent back to the customer.
Any free gifts that are sent with your order must also be returned with your order. These must be included in your return package to qualify for a refund.
Should you wish to return your products please use our returns portal. Click the link below to process your shipping label and this will then instruct you on the next steps to progress with your return:
[ Returns Portal ]
Returns must be prepaid at the drop off point and are the sole responsibility of the customer. These rates start from £2.50.
Make sure you have the correct order number and are using the correct email address that you originally placed your order with when returning your items through our portal.
Please make a note of your tracking number from the label before dispatching your item. You may need to provide this if your parcel is delayed or lost in transit. It is your duty to take reasonable care of the goods and will be liable for any damage until the package is received into our warehouse. We are not responsible for any lost or missing packages returned to us by carrier or any other delivery services.
Refunds will be credited to the purchaser's original method of payment. Original shipping charges will not be refunded. The amount will be refunded in the currency used to make the original purchase. Due to fluctuations in currency rates the amount refunded may be slightly higher or lower than the price originally paid.
Once the return is received into our warehouse, we will begin to process the refund as soon as possible. Please allow up to 30 days for refund amount to appear in your account.
If you have any questions or concerns about your return, please contact our customer service here along with your name and order number and one of our representatives will be more than happy to help.
Faulty goods refers to manufacturing issues. Items that are damaged because of normal wear and tear are not considered to be faulty.
To claim under your warranty, please contact here. We will request a clear image of the fault and how the garment has been washed and dried. This will then result in the return of the garment.
Please note at the time of purchase only one discount code is permitted. Discounts cannot be used in conjunction with any other special offers or promotions. If you have any questions on this, please forward them to here and one of our customer services representatives will be happy to help.


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Website Design Services for Aurora, Colorado
Design Den provides website design, web hosting, and SEO services in Aurora, Colorado! We're excited to offer these services to businesses in the area and beyond. While we're based in Wyalusing, we provide our services remotely to clients all across the USA.
Our team of experts is dedicated to creating visually appealing, user-friendly websites that not only look great but also perform well on search engine results pages. We use the latest design trends and technologies to create a website that will make a lasting impression on your visitors. Our web hosting plans are reliable and secure, ensuring that your website is always available to your visitors.
We also offer comprehensive SEO services to help your website rank higher on search engine results pages. Our team of SEO experts will conduct a thorough analysis of your website, identify the right keywords, and create a comprehensive strategy to improve your website's visibility and organic traffic.
We are committed to providing our clients with exceptional service, personalized attention, and high-quality results. Contact us today to learn more about our website design, web hosting, and SEO services and how we can help your business succeed online.
Our Services
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Services include optimization, indexing, sitemaps, Google/Bing search console setup, business listings, and various other SEO methods. Contact for more information.
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Elevate your online presence with my freelance website design and development services. Experience cutting-edge technology and innovative solutions for a visually appealing and functional website optimized for search engines. Contact me for a unique website tailored to your brand's vision
Website Hosting and Management
Affordable and reliable website hosting and management services offered by a freelance designer and developer. Ensure website availability, up-to-date software, security, optimization for performance, and protection against cyber threats. Contact for more information
Why trust us to design your website
Responsive Design
We utilize responsive web design to allow your website to scale, no matter what device your visitors are on.
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Our sites are hosted on Cloudflare's CDN to provide optimal uptime and fast access to your website.
All files on your website will use next gen formats for the best compression and optimal load times.
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Hand Coded
Website are hand-coded to achieve a custom look for your brand and business. We will work with you until your expectations are met.
The only contact your businesses needs
for your website design needs


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Donkey Kong ZZT
Zeta created and maintained by asie. Press F11 while the emulator is focused to access an options menu.
Common Problems and Solutions
I'm stuck in the world I'm playing!
Depending on how you're stuck, you may want to try the following:
- A lack of health or other resources: Press "?" to open the cheat prompt and use the appropriate cheat listed on the ZZT Cheats page.
- The player is surrounded and unable to move: Press "?" to open the cheat prompt and type "ZAP" to erase the four tiles surrounding the player
- The player has been destroyed: Oops. Hope you saved. This happens due to a bug with how conveyors work and your game has been soft locked.
- I paused with "P" and can't unpause: The only way to unpause is to move. If you pause while the player is surrounded, the game becomes soft locked. It's best to use "Escape" as a pause method instead. Keep in mind that the game starts paused as well, so saving while surrounded (something easy to do with engine based games like ZZT platformers) will result in a save that can't be played when restored.
- I don't know where to go next: Try looking for some information in the file's reviews or associated articles. A small number of files have full walkthroughs. You can also use the file viewer to explore the world freely.
- I need some item, but don't know where to find it: Use the file viewer! Click on objects to view their code and look for things like
#if crowbar escape
. Then use the ZZT-OOP Search in the World tab to look for#set crowbar
to find where the item is acquired. - I'm in a twisty maze of passages, all alike or dealing with some other maze-like situation. The file viewer can help reveal some hidden tiles more easily. Under the preferences tab try out other board rendering methods to reveal fake walls or empties.
I hit "P" to play and got a DOS Error!
This is caused either by ZZT or Zeta not correctly pointing to the proper world. This most frequently happens with games that require non-default Zeta configurations or worlds whose filename doesn't match the one stored within the file itself by ZZT. Try pressing "Enter" to close the message, pressing "W" to open the world menu, and selecting the world from this menu to reload the world.
I hit "E" to edit a world and got a red flash and a Can not edit <WORLD>!/Can not edit a saved game! message!
The world you tried to edit is locked. From within the editor hit "?" to open the cheat prompt and enter "+DEBUG". Reload the world with "L" and the world should open just fine. More about Locks
All these boards are named ► LOCKED FILE and refuse to open except for one named :c that stops emulation when I open it!
The world you're editing is (also) Super Locked. You can open the locked boards by hitting "Escape" instead of "Enter". The :c board is purposely corrupt and can't be opened from ZZT's editor. More about Locks
Current Zeta configuration: ZZT v3.2 (Registered)


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So You're Hiring Your First Employee
Should I hire an employee or contractor?
If you need help building your business, there are two ways to hire an extra set of hands – adding an employee or signing an independent contractor. While there are pros and cons to both, it's important to understand the difference.
- Employee: An employee is hired to work for your company on a full- or part-time basis. This means you, as the employer, have control over how, when, and where they do their job. And you'll also have ownership of any work product that's created on company time. However, this control comes with added responsibility. When you hire an employee, you'll need to withhold payroll taxes and report their income using the appropriate tax form, in addition to abiding by other federal, state, and local employment laws. Then, there are additional benefit considerations – like offering vacation, sick time, a retirement plan, and health insurance. These are just some of the basic responsibilities that are tied to having employees.
- Independent contractor: A contractor (or freelancer) is a self-employed worker that is hired for a specific task. According to the Internal Revenue Service (IRS), that means the payer only has the right to direct the result of the work – not how, when, or where it's accomplished. Contractors can also perform work for multiple clients at the same time. When hiring a contractor, you still need to report their income using the appropriate tax form. But because they're responsible for their own taxes and benefits, you generally don't need to withhold any payroll taxes.
Contractors can be a great option for short-term, project-based jobs. They can bring a specific skill to the table, without the long-term commitment of hiring an employee.
On the other hand, an employee will give you far more control over the work being performed – and the nature of the arrangement means they're also likely to be more committed to your business. In the long run, this may make hiring an employee worth the extra time and financial investment, depending on the work that needs to be done.
When is the right time to hire an employee?
Every business is unique. So unfortunately, there's no right answer to when it's the best time to hire an employee. Instead, you'll need to find the right balance for your situation.
- Too early: The biggest challenge to hiring your first employee is typically a financial one. Hire someone too early and you'll run the risk of encountering cash-flow problems. Or if you don't have enough work to support another team member, you could be paying someone who doesn't have enough to keep them busy.
- Too late: However, if you start hiring too late, you may miss out on opportunities to grow your business. Or you could get in over your head and risk disappointing your current customer base.
Either scenario is less than ideal. That's why it's important to plan ahead.
Decide in advance when it's a good time to bring on an employee – like when you hit a certain sales goal, or at a time when an employee can perform work that will significantly increase your revenue. If you need help before hitting that milestone, you can always hire a contractor to test the waters.
What changes do I need to make to my business before hiring an employee?
One big obstacle to hiring your first employee can be the logistics. The truth is, hiring an employee means you'll have a lot more legal rules to follow1. If you have specific questions about your business, always talk to an experienced lawyer for legal advice.
Generally speaking, though: Before you make your first job offer, you may need to:
- File for a federal employer identification number (EIN). If you don't have one already, this number will be used for tax documents that are submitted to the IRS.
- Register with the state. Depending on where you live, you may need a separate tax ID number for your state. You may also need to pay your state's unemployment compensation tax, which is used to support workers if they lose their job.
- Set up your payroll. Whether you decide to manage payroll on your own or work with an outside firm, you'll need to set up regular pay periods. Generally, employers withhold state and federal taxes based on the information completed in your employee's W-4 form.
- Display required notices. You may be a small business. But as an employer, you're now subject to many federal, state, and local labor laws. And depending on your industry, that may require displaying certain notices or posters for your employees to see. The Department of Labor's FirstStep Poster Advisor tool can help you decide what rules apply to your business.
- Create an employee handbook. This step may seem like overkill for your first employee. But if you don't have any policies in place for your staff to follow, you may be left defenseless against future bad behavior. Search for trusted resources online, such as this guide to developing your employee handbook from the Society for Human Resource Management, to help you build your own rules.
- Prepare your onboarding process. Before making your first hire, it's wise to think through how you'll train your employees. Developing an onboarding process in advance can help your new hire get up to speed faster and eliminate any frustrations caused by a lack of direction.
How do I find the right candidate for the job?
Your first hire will likely have a significant impact on the future of your business – good or bad. That's why it's critical to find the right person to fill the job. With reports of record labor shortages in the news, many businesses are finding it harder than ever to hire qualified workers. Here are some tips that may help.
- Understand hiring laws. When hiring, keep in mind that there are questions that you can't (or shouldn't) ask. To avoid being discriminatory in your hiring decision, steer clear of asking about topics such as a candidate's age, religion, disability, marital status, race, or any other protected characteristic. The experts at the U.S. Equal Employment Opportunity Commission (EEOC) have this helpful guide to understanding employment laws and avoiding discrimination in hiring decisions. The rules can be complicated, and they vary by situation. If you have specific questions, it's best to consult a lawyer for legal advice tailored to your business or situation.
- Write a compelling job description. When writing a job description, make sure it clearly describes the work that will be performed, as well as any qualifications you expect from applicants. Be practical. Have realistic expectations. And don't forget to explain why it will be great working for your growing company – including any perks of the job. Then, post your listing to online job sites like Indeed, Monster.com, and LinkedIn.
- Consider a benefits package. With so many job opportunities available right now, an offer with competitive pay and benefits can help attract top talent. Do your research in advance to determine what the average compensation is for similar roles in your area.
- Use your network. For businesses with fewer than 100 employees, it's estimated that about half of all new hires are generated by referrals. So be sure to use your personal network to your advantage. Let your friends, family, and professional contacts know you're hiring and ask if they know anyone that would be a good fit. And don't ignore the power of social media platforms like Facebook, Twitter, and LinkedIn.
- Prepare for the interview. Once you've narrowed down the field of candidates, it's time to conduct interviews. Be sure to prepare your questions ahead of time and make a list of the attributes you're looking for. This will make it easier to compare applicants. Experts also recommend asking situational questions to gauge how someone may respond to real-life scenarios.
What should I do during the hiring process?
After you've found the perfect candidate, it's time to make an offer and set a start date. But of course, it's not quite that easy. Here are some steps you should take to protect your business and ensure a smooth hiring process.
- Fact-check their resume. A resume is a great starting point to learn about someone's background and experience, but it won't tell you everything. Consider following up with previous employers or alma maters to make sure a candidate's skills and experience check out. Be aware that many employers have a standard practice of not providing details on a former employee; only dates of employment and/or whether or not the individual would be considered "eligible for rehire."
- Conduct a pre-employment screening. Your first employee may have access to everything from important files to financial records. So you'll want to make sure they can be trusted. Consider paying for a background check and drug screen to check for any signs of past criminal conduct or substance abuse. Be aware of all federal, state, and local laws that might impact background checks (including credit checks) and drug testing. Consider doing background checks and/or drug testing after a conditional offer is made.
- Write an offer letter. Next, write up the details of your job offer and submit it to your soon-to-be employee. This should include information on the position, salary, and any benefits you're offering. The offer will serve as the foundation from which any negotiations start. The offer letter is an important document. It's a good idea to discuss it with or have it reviewed by legal counsel in advance. As mentioned above, consider having a first conditional offer letter, pending successful background checks and/or drug testing. Then follow up with a final offer letter, once the background check and/or drug testing have been successfully completed.
- Be prepared to negotiate. Applicants are likely to try and negotiate for higher pay or benefits. Be prepared in advance for any compromises you're willing to make. And if you can't budge on salary, consider offering other incentives like vacation time or training opportunities.
- Complete your paperwork. Congratulations! Your offer has been accepted and your new employee is ready to start. Now it's time to get working on all the forms required by the U.S. Department of Labor. Be sure to keep copies of everything for your own records.
How can I protect my growing business?
You may have started as a one-person show. But now that your business is expanding, you'll need to make sure it's protected.
An insurance pro like your local ERIE agent can help you understand what coverage to consider when you hire new employees. Generally speaking, here are a few things to have on your radar:
- Business Insurance: Business insurance can help protect against everything from property damage to liability claims from customers and employees. At Erie Insurance, we offer business insurance packages that are tailored to your specific industry.
- Workers' Compensation: Workers' compensation laws and requirements vary by state. But generally, any business that has employees must have workers' compensation insurance coverage. It helps cover medical care and lost wages for an employee who is hurt at work.
- Employment Practices Liability (EPL): Unfortunately, no employer is immune from a current or former employee, or even an employment candidate, filing a claim of alleged discrimination, wrongful termination, or harassment of any kind. If a claim against your business is made, you could spend valuable time and resources defending it – even if the claim is determined to be meritless. ERIE's EPL coverage2 helps cover liability damages and defense costs (within the limit of coverage) from charges brought by employees as well as applicants for employment or volunteers.
To learn more about these insurance coverages, get in touch with your local ERIE agent today.
You built it. Let us help protect it.
They say "Rome wasn't built in a day." And neither was your business. At ERIE, we appreciate all the hard work that goes into starting and running a small business. It's why we've dedicated our lives to helping you protect it.
To learn more about how we can help provide tailor-made insurance solutions for your situation and your budget, contact your local ERIE agent.
1 The information contained herein is provided for informational purposes only, and in no way should be considered legal advice. Consult an experienced attorney with legal questions regarding hiring employees and/or contractors.
2 Coverages, benefits, limits, and deductibles will vary. Conditions, exclusions, and limitations will apply. Refer to our disclaimer for more information. Talk to an ERIE agent for state-specific policy information.
You've put in the hard work building your business from the ground up. And it's finally starting to pay off. The only problem: now you have more work than you can handle.
As a small business owner, growth is always a good problem to have. But it does come with its own share of challenges. If you've made it to this point, you have two options. The first is to let opportunities for new business pass you by, ensuring you don't take on more than you can handle. The second option is to lighten your load – by hiring someone to help.
For many business owners, the decision to hire their first employee can be a difficult one. So here are answers to some of the most common questions about hiring your first employee.
A better insurance experience starts with ERIE.
Haven't heard of us? Erie Insurance started with humble beginnings in 1925 with a mission to emphasize customer service above all else. Though we've grown to reach the Fortune 500 list, we still haven't lost the human touch.
Contact J.P. Wolfe Insurance today to experience the ERIE difference for yourself.


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Of course I could criticize the theology in all of it, but I want to focus specifically on this one piece in part 2. "All We Like Sheep." In fact, it's critical enough to this post that I'm going to embed it so you can watch it first. I think there's a valuable insight into theology to be found.
(That's not my chorus, by the way, it's just some people on YouTube.)
Cute, isn't it? Here are the words.
All we like sheep
Have gone astray
We have turned everyone
To his own way
And the Lord hath laid on him
The iniquities of us all!
Sometimes I imagined changing the lyrics to "We all like sheep," which changes the message considerably.
Our director really emphasized the shift in tone at the final part. Up till then, everything is bouncy, cheerful, and silly. After that, it's dark and scary. I like to envision all the little sheep frolicking around in a Pepe Le Pew style hopping trot. Then at the end, maybe a giant Monty Python foot comes down on them.
Who are the sheep? Us! All we! Maybe you've heard the Christian metaphor already that Christians are sheep and Christ is our loving shepherd. You might interpret it that way, but that's not how Handel apparently thought of it... the consequence of being dumb, frolicking, self-willed sheep is implied in the dark, brooding, angry minor key of the last few bars.
That's the perspective that Christianity seems to offer on humanity. Under all the cheerful, bouncy "I'm so happy I have a personal relationship with Christ!" vibe, I also detect a deep rooted contempt for all humankind. The image of sheep doesn't seem to be used here to convey the idea of comfort at being taken care of, so much as scorn at whatever it is that people like doing that makes them go astray; and also an implied threat.
Maybe I'm exaggerating, but actually I think a lot of preachers would agree with me. "You're just denying God because you want to sin," they'd say. The idea of all non-Christians as stupid, clueless sheep lurching around without the shepherd to watch them is baked into the core message of the Bible.
The disagreement here is not that I want to "sin" for its own sake. It's that I don't agree with the Christian concept of what constitutes bad behavior. It doesn't matter what the bad behavior is -- whether it's sex that isn't sanctified by the church (as Darrel Ray and Matt discussed yesterday) or sleeping in on Sundays or scientific inquiry into the nature of the universe. What's important in a religious context is that you feel generally uncomfortable with anything you do that the doesn't involve religious devotion.
I understand that many people raised religious still feel that discomfort. What's interesting is that if there is no God, the only place you're getting information about the "going astray" behavior is from a group of individuals with a direct interest in keeping you coming back to church and donating money.