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Saturday, June 25, 2016
New Book on Class Actions in Context: How Culture, Economics and Politics Shape Collective Litigation
A new book, Class Actions in Context: How Culture, Economics and Politics Shape Collective Litigation, has been published by Edward Elgar Publishing (also available on Amazon). The editors of the book are Associate Dean Deborah Hensler (Stanford Law) and Professors Christopher Hodges (Oxford) and Ianika Tzankova (Tilburg Law). A global group of aggregate-litigation scholars contributed to the book, including Dean Camille Cameron (Dalhousie Law, Canada); Associate Dean Manuel Gomez (Florida International Law); Professors Agustin Barroilhet (U. Chile Law), Naomi Creutzfeldt (Research Fellow, Oxford), Axel Halfmeier (Leuphana U., Germany), Kuo-Chang Huang (Member, Taiwan national congress and formerly of National Cheng-Chi U., Taiwan), Jasminka Kalajdzic (Windsor Law, Canada), Alon Klement (Tel-Aviv U., Israel), Elizabeth Thornburg (SMU Law), and Stefaan Voet (U. Leuven & U. Hasselt, Belgium); and myself.
I authored a chapter, The promise and peril of media and culture: The Toyota unintended acceleration litigation and the Gulf Coast Claims Facility in the United States, and Professor Ianika Tzankova and I co-authored another chapter, The culture of collective litigation: A comparative analysis.
The book was a remarkable and fascinating undertaking, with many of us contributors gathering at several conferences across the globe over recent years to discuss and compare our ongoing research. Here is a brief description of the book:
In recent years collective litigation procedures have spread across the globe, accompanied by hot controversy and normative debate. Yet virtually nothing is known about how these procedures operate in practice. Based on extensive documentary and interview research, this volume presents the results of the first comparative investigation of class actions and group litigation 'in action'.
Produced by a multinational team of legal scholars, this book spans research from ten different countries in the Americas, Europe, Asia and the Middle East, including common law and civil law jurisdictions. The contributors conclude that to understand how class actions work in practice, one needs to know the cultural factors that shape claiming, the financial arrangements that enable or impede litigation and how political actors react when mass claims erupt. Substantive law and procedural rules matter, but culture, economics and politics matter at least as much.
This book will be of interest to students and scholars of law, business and politics. It will also be of use to public policy makers looking to respond to mass claims; financial analysts looking to understand the potential impact of new legal instruments; and global lawyers who litigate transnationally.
We are honored that Professor Geoffrey Hazard (Emeritus, UC Hastings Law & Penn Law) offered the following comment on the book:
Class Actions in Context is a penetrating analysis of class and group actions worldwide. A group of international scholars brings to bear legal, economic, and political analyses of this evolving judicial remedy. It explores various substantive claims ranging from consumer protection to securities litigation. Drawing on case studies of practice as well as legal analysis, it demonstrates the importance of factors running from litigation finance to background cultural traditions. It is worth study in every legal system.
June 25, 2016 in Aggregate Litigation Procedures, Class Actions, Environmental Torts, Lawyers, Mass Tort Scholarship, Procedure, Products Liability, Travel, Vehicles | Permalink | Comments (0)
Sunday, May 29, 2016
John Goldberg and Benjamin Zipursky on the Myths of MacPherson
Professors John C.P. Goldberg (Harvard Law) and Benjamin Zipursky (Fordham Law) have posted to SSRN their forthcoming article, The Myths of MacPherson, 9 J. Tort L. (forthcoming 2016). Here is the abstract:
For a symposium marking the centenary of MacPherson v. Buick, we identify three common characterizations of Cardozo's famous opinion that purport to explain its importance. Unfortunately, each of these characterizations turns out to be a myth. MacPherson is worthy of celebration, but not because it recognizes that negligence law's duty of care is owed to the world, nor because it displays the promise of an instrumental, policy-oriented approach to adjudication, nor because it embraces a nascent form of strict products liability. These myths of MacPherson reflect deep misunderstandings of tort law, and of Cardozo's distinctively pragmatic approach to adjudication. Ironically, although they have been largely fostered by progressives, the myths lend support to the cause of modern tort reform. By contrast, an accurate appreciation of MacPherson's virtues permits an understanding of negligence, tort law, and common law adjudication that provides grounds for resisting regressive reforms.
May 29, 2016 in Mass Tort Scholarship, Products Liability | Permalink | Comments (0)
Thursday, April 28, 2016
Monopolies in Multidistrict Litigation - Part II - Lead Lawyers as Settlement Gatekeepers
In my first post on Monopolies in Multidistrict Litigation, I noted that lead lawyers and defendants seem to benefit in tandem from the settlements they negotiate. This second post, Part II, explains how repeat players on both plaintiff and defense sides have perfected a fundamental shift in settlement design.
As I elaborate on pages 19-21, the demise of the mass tort class action makes it more difficult for defendants to achieve holistic closure, for MDL settlements technically bind only those litigants before the court. But defendants have been able to regain a greater degree of finality through a foundational shift in settlement construction: unlike traditional settlements between plaintiffs and defendants, all twelve deals in the dataset were agreements between lead lawyers and defendants.
As such, these deals position lead plaintiffs' lawyers as settlement gatekeepers, for defendants will not make better offers to others without the threat of trial; doing so would work against their closure goal. These new deals then serve as a mandatory gateway for anyone wanting to settle, and typically require non-lead attorneys to become signatories alongside their clients. Accordingly, all master settlement agreements in the dataset aimed some provisions at plaintiffs' attorneys and some at their clients. As a later post will explore, it's the provisions targeting plaintiffs' attorneys that raise the most ethical problems.
Making deals with plaintiffs' attorneys masterfully furthers defendants' end game in two ways.
First, the agreements impose uniform endorsement requirements on participating attorneys to discourage them from "cherry picking," a practice in which lawyers settle most cases, but continue litigating those with the strongest claims or most sympathetic facts. By requiring a high percentage of plaintiffs to accept the settlement offer for it to take effect and insisting that individual attorneys recommend that all their clients settle (including clients who had not yet sued or who were pursuing relief elsewhere), defense attorneys essentially conditioned plaintiffs' attorneys fees on achieving their closure aims.
A plaintiff's attorney is either "all in" and would collect significant contingent fees from all her settling clients, or "all out" and would have to spend significant resources litigating individual cases. As such, recommendation provisions alter the typical contingent fee model where an attorney's recovery increases alongside her clients' recovery and instead ties plaintiffs' attorneys' financial self-interest to each other and to the entire claimant base.
This shift also allows defendants to reach some plaintiffs who are outside of the federal court's jurisdiction, and others who haven't yet filed suit (through case census provisions - see pp. 27-29). It thereby recaptures some of the finality that class actions once offered through binding absent class members.
Second, when combined with the defendant's ability to walkaway from the deal if too few claimants consent to settle, provisions aimed at plaintiffs' attorneys (attorney-recommendation provisions, attorney' withdrawal provisions - see pp. 19-26) collectively reduce the demand for legal representation. The settlement effectively becomes the only "game" in town.
Like oligopolists, leaders are able to thwart competition and reduce demand by using attorney withdrawal and recommendation provisions to restrict the legal services market (at least for those with similar allegations against the same defendant). When defendants threaten to abandon the deal if too few plaintiffs participate, and participating attorneys must recommend the deal to all of their clients and withdraw from representing those who refuse, leaders can regulate the legal service being offered and control a sufficiently large share of that market
In this sense, master settlements can recreate bottleneck problems where dominant firms raise competitors' costs by obtaining exclusionary rights; once defendants negotiate master settlements with plaintiffs' leadership, that agreement typically becomes the only settlement option.
Why should we be concerned? Apart from inherent economic concerns that arise under these conditions, the next post will explore why provisions targeting attorneys are ethically troubling.
April 28, 2016 in Aggregate Litigation Procedures, Current Affairs, Lawyers, Mass Tort Scholarship, Procedure, Products Liability, Settlement | Permalink | Comments (0)
Thursday, April 21, 2016
Monopolies in Multidistrict Litigation
I've spent the better part of the past year and a half analyzing the publicly available nonclass aggregate settlements that have taken place in multidistrict litigation alongside leadership appointments, common-benefit fees, and, where available, recovery to the plaintiffs. This has given me an in-depth look at what's happening (or has happened) in Propulsid, Vioxx, Yasmin/Yaz, DePuy ASR Hip Implant, Fosamax (2243), American Medical Systems pelvic mesh litigation, Biomet, NuvaRing, and Actos. I've also analyzed fee practices in Baycol, Ortho Evra, Avandia, Mentor Corp. ObTape, Prempro, Chantix, Pradaxa, and Ethicon Pelvic Repair.
This endeavor has been deeply unsettling for a variety of ethical, doctrinal, and systemic reasons. Professors Erichson and Zipursky's prior work on Vioxx opened our eyes to troubling provisions in that deal, but I had no idea how widespread the problems were or how they had evolved over time from deal to deal until now.
Propulsid appears to be the primogenitor, for all subsequent deals in the data replicated some aspect of its closure provisions. But Propulsid is extraordinarily troubling: 6,012 plaintiffs abandoned their right to sue in court in favor of settling. Only 37 of them (0.6 percent) recovered any settlement money through the physician-controlled claims review process, receiving little more than $6.5 million in total. Lead lawyers, on the other hand, received over $27 million in common-benefit fees through a deal they negotiated directly with the defendant (and had the court approve). Sadly, that's just the tip of the iceberg.
I posted the fruits of my labor on SSRN today in a piece titled, Monopolies in Multidistrict Litigation. It's a 70+ page tomb, so I'll be covering specific aspects of it over the next few weeks in a series of blog posts. It's not only an indictment of current practices and procedures, but it offers myriad ways for judges to improve MDL practice. It even comes complete with handy pocket guides for judges, leadership application forms, and leadership applicant scoring sheets in the appendix.
For those of you who love data, there are several tables that may be of interest: Table 1: Provisions Benefitting Defendants Occurring within the Analyzed Settlements on p. 20; Table 2: Common-Benefit Fee Practices on p. 33; and Table 3: Common-Benefit Awards and Nonclass Claimant Recovery within the Data on p. 48.
Today's post simply introduces the paper, so here is the summary:
When transferee judges receive a multidistrict proceeding, they select a few lead plaintiffs' lawyers to efficiently manage litigation and settlement negotiations. That decision gives those attorneys total control over all plaintiffs' claims and rewards them richly in common-benefit fees. It's no surprise then that these are coveted positions, yet empirical evidence confirms that the same attorneys occupy them time and again. When asked, repeat players chalk it up to their experience and skill—no one can manage and negotiate as well as they can. Off the record, however, any plaintiff's lawyer who's been involved in multidistrict litigation will explain repeat players' dominance with stories of backroom deals, infighting, and payoffs. Yet, when judges focus on cooperation and consensus in selecting leaders and then defer to those leaders in awarding common-benefit fees, they dampen open rivalry and enable repeat actors to mete out social and financial sanctions on challengers.
Anytime repeat players exist and exercise both oligopolistic leadership control across multidistrict proceedings and monopolistic power within a single proceeding, there is concern that they will use their dominance to enshrine practices and norms that benefit themselves at consumers' (or here, clients') expense. Apprehensiveness should increase when defense lawyers are repeat players too, as they are in multidistrict litigation. And anxiety should peak when the circumstances exhibit these anti-competitive characteristics, but lack regulation as they do here. Without the safeguards built into class certification, judicial monitoring and appellate checks disappear. What remains is a system that permits lead lawyers to act, at times, like a cartel.
Basic economic principles demonstrate that noncompetitive markets can result in higher prices and lower outputs, and agency costs chronicle ways in which unmonitored agents' self-interest can lead them astray. By analyzing the nonclass deals that repeat players design, this Article introduces new empirical evidence that multidistrict litigation is not immune to market or agency principles. It demonstrates that repeat players on both sides continually achieve their goals in tandem—defendants end massive suits and lead plaintiffs' lawyers increase their common-benefit fees. But this exchange may result in lower payouts to plaintiffs, stricter evidentiary burdens in claims processing, or higher plaintiff-participation requirements in master settlements.
These circumstances warrant regulation, for both multidistrict litigation and class actions are critical to redressing corporate wrongdoing. Even though judges entrench and enable repeat players, they are integral to the solution. By tinkering with selection and compensation methods and instilling automatic remands after leaders negotiate master settlements, judges can capitalize on competitive forces already in play. By tapping into the vibrant rivalries within the plaintiffs' bar, judges can use dynamic market solutions to remap the existing regulatory landscape by invigorating competition and playing to attorneys' strengths.
As always, your comments are welcome (the draft is still just that, a draft) - please email any comments or corrections to me eburch at uga.edu. More soon...
April 21, 2016 in Aggregate Litigation Procedures, Class Actions, Current Affairs, Lawyers, Mass Tort Scholarship, Procedure, Products Liability, Vioxx | Permalink | Comments (0)
Friday, April 1, 2016
Appellate Court in NJ Upholds Verdict Against J&J
Alison Frankel at Reuters explains. The opinion is here.
April 1, 2016 in Medical Devices - Misc., Products Liability, Punitive Damages, Regulation, Trial | Permalink | Comments (0)
Thursday, March 31, 2016
Plaintiffs Lose Second GM Ignition Switch Trial
You can find the report by Erik Larson & Patricia Hurtado on Bloomberg here. Bill Vlasic at the New York Times also has a piece on the win for GM.
This case involved a crash on an icy bridge in New Orleans during a rare ice storm in that part of the country. The plaintiffs suffered minor injuries.
The jury found the accident was caused by the ice storm, not the defect. It did, however, also find that the car was "unreasonably dangerous." With respect to that determination, Prof. Carl Tobias (Richmond) is quoted in the Bloomberg article saying: "The plaintiffs can claim a victory at least insofar as the jury made that finding, which is a critical finding. Every case will be on its own merits, but I think they can claim that as an important development."
It looks like one can find documents relating to the case here. The next case to go to trial is Yingling v. GM, which was the subject of the dispute earlier this year.
March 31, 2016 in Aggregate Litigation Procedures, Products Liability, Vehicles | Permalink | Comments (0)
Tuesday, February 2, 2016
GM Bellwether Trial - Developments
Some more news coverage of the GM Bellwethers and the allegations made against the lead lawyer.
An interview with Robert Hilliard can be found here: Amanda Bronstad, Plaintiffs Lawyer Hilliard Saw No Red Flags in Case, National Law Journal, Feb. 1, 2016.
Amanda Bronstad, Lawyer Claims GM Bellwether Counsel Cut Sweetheart Deal with Automaker, National Law Journal, Jan. 28, 2016.
Sara Ranzaddo & Mike Spector, GM, Plaintiffs Lawyers Dispute Misconduct Allegations in Ignition Switch Cases, Wall Street Journal, Feb. 2, 2016.
February 2, 2016 in Aggregate Litigation Procedures, Products Liability, Vehicles | Permalink | Comments (0)
Friday, January 29, 2016
Repeat Players, the Settlements They Design, GM, and VW
There's obviously been a lot in the news about multidistrict litigation--from Lance Cooper's allegations in GM to the recent selection of the plaintiffs' leadership slate in VW. But what do we really know about the settlements that come out of those large MDLs? On one hand, the answer is not much. Many of the deals are secret because they are private. But sometimes those private deals are nevertheless publicly available. And when they are, we read them. And analyze them.
The results can be a little disturbing. Given all of the hubbub over Cooper's allegations in GM (see Lahav's post), my co-author Margaret Williams and I decided to go ahead and release the findings of our recent study, Repeat Players in Multidistrict Litigation: The Social Network, on SSRN.
While past studies have considered repeat play on the plaintiffs' side, this study is the first comprehensive empirical investigation of repeat play on both sides. It won't surprise most readers to learn that we found robust evidence of repeat play among both plaintiff and defense attorneys. What may be more interesting is that we used social-network analysis to demonstrate that a cohesive multidistrict-litigation leadership network exists, which connects people, law firms, and the proceedings themselves.
While repeat play may not be surprising for those in the know, the fact that repeat players exist matters considerably. Lead lawyers control the litigation, dominate negotiations, and design settlements.
To consider repeat players' influence, we examined the publicly available nonclass settlements these attorneys negotiated, looking for provisions that one might argue principally benefit the attorneys, and not one-shot plaintiffs. By conditioning the deal on achieving a certain claimant-participation rate and shifting the deal-making entities from plaintiffs and defendants to lead lawyers and defendants, repeat players tied all plaintiffs' attorneys' financial interests to defendants' ability to achieve closure.
Over a 22-year span, we were unable to find any publicly available nonclass settlement that didn't feature at least one closure provision (which benefits the defendant), and likewise found that nearly all settlements contained some provision that increased lead lawyers' fees. Based on the limited settlements available to us, we found reason to be concerned that when repeat players influence the practices and norms that govern multidistrict proceedings—when they "play for rules," so to speak—the practices they develop may principally benefit them at the expense of one-shot plaintiffs.
Of course, our research doesn't speak directly to the allegations in GM, but it does make those allegations far less surprising. And if you compare our list of repeat players to the names of those appointed in Volkswagen, you'll see a lot of familiar names.
January 29, 2016 in Aggregate Litigation Procedures, Current Affairs, Lawyers, Mass Tort Scholarship, Procedure, Products Liability, Settlement | Permalink | Comments (0)
Thursday, January 21, 2016
GM Ignition Switch Bellwethers
The first GM Ignition Switch Bellwether trial is going forward now. Below are some links to media coverage:
Danielle Ivory, 'Bellwether' GM Trial Opens Over Ignition Claim, NYTimes, 1/12/16
Stephanie Gleason, Plaintiff in GM Civil Trial Takes the Stand, WSJ, 1/14/16
Sindhu Sundar, Fire GM Engineer's 'Switch from Hell' Email Heats Up Trial, Law 360, 1/15/16
Erik Larson, GM Ignition Switch Trial Hits Snag Over Fraud Claims, Bloomberg, 1/19/16
January 21, 2016 in Aggregate Litigation Procedures, Products Liability, Vehicles | Permalink | Comments (0)
Sunday, September 27, 2015
Good Ol' Boys Clubs in MDL
Amanda Bronstad at the National Law Journal recently published an article titled Good Ol' Boys Clubs in MDL that includes a list of law firms that I recently identified as firms with the most lawyers appointed to leadership positions in products liability MDLs. Given the title of her piece, I thought readers might also be interested in the gender breakdown of lead lawyers in those multidistrict litigation cases. Of the top fifty lawyers who were appointed most frequently, only 11 of the 50, or approximately 22% were female. The full list of those attorneys is available in Judging Multidistrict Litigation, 90 N.Y.U. L. Rev. 71, 139-40 (2015) (gender breakdowns are mentioned in footnoted 102).
September 27, 2015 in Aggregate Litigation Procedures, Lawyers, Procedure, Products Liability | Permalink | Comments (0)
Wednesday, September 23, 2015
Trust, VW Brand Management, and Emissions Litigation
Harvard Business Review has a an article, What VW Didn't Understand About Trust, by Andrew Wilson. As perhaps occurred in the Toyota Unintended Acceleration Litigation, VW may be motivated to settle somewhat swiftly any civil litigation or regulatory or criminal inquiries and fines, as part of a larger strategy to regain the public's trust and preserve its brand.
September 23, 2015 in Class Actions, Products Liability, Travel, Vehicles | Permalink | Comments (0)
Growing VW Emissions Litigation, and Potential Parallels to the Toyota UAL Litigation
Daniel Fisher at Forbes has posted his article, Toyota Sudden-Acceleration Case Provides An Expensive Lesson For VW.
September 23, 2015 in Class Actions, Procedure, Products Liability, Travel, Vehicles | Permalink | Comments (0)
Friday, May 8, 2015
An Interesting Look Back at the Ford Pinto Case
I want to point out an interesting article by Malcolm Gladwell in the New Yorker that looks back at the litigation surrounding the Ford Pinto case. Although the article talks about the criminal prosecution and some of the legal issues briefly, it focuses on the engineers in the case and their ex ante decisions to issue recalls. In my view, the ex ante decisions of engineers, and their inherent difficulty, do not get nearly enough attention in the media, even though the defendant's liability in mass tort cases always hinges on these decisions. A good read overall.
May 8, 2015 in Products Liability | Permalink | Comments (0) | TrackBack (0)
Thursday, April 30, 2015
Constructing Issue Class Actions
There's been a lot of chatter over the past few years about the greater use of issue classes. The Rule 23 Subcommittee in its recent report (p. 41) indicated that issue classes top its agenda for possible reform and there's been a greater willingness to rely on Rule 23(c)(4) among the circuit courts over the last few years. Much of the scholarship on issue classes thus far, however, has focused on how to use issue classes in conjunction with Rule 23(b)(3)'s predominance requirement. Professor Laura Hines (Kansas) has, for instance, written a series of articles on the topic and there have been several debates in symposium pages, such as DePaul's 2013 symposium.
Whatever side of the debate one adheres to on the to-be-or-not-to-be question, the courts are embracing issue classes. Thus, there remains much work to be done on discerning which issues should qualify for certification, how to think about Seventh Amendment Reexamination Clause questions, and how to compensate plaintiffs' attorneys who initiate issue classes.
I've recently written a paper on issue classes that takes some steps toward fleshing out these problems. The paper is long since it's meant to be a one-stop shop for judges and attorneys on the subject, but here are the critical points worth underscoring:
First, one of the main difficulties of our system is that the focus in massive lawsuits has shifted to the ways in which the plaintiffs are dissimilarly situated, even when the defendant's conduct is uniform. Take the GM ignition switch debacle or the Toyota acceleration cases, for example. Corporate actions are nonindividuated; it doesn't make sense to litigate what GM or Toyota did in 40,000 different cases. (Draft pp 5-8) But defendants have successfully shifted the procedural focus to how their behavior affected claimants, which tends to defeat class certification because common questions do not predominate over individual ones. The issue class has the potential to recapture what is common to the plaintiffs: defendant's conduct--at least so long as that conduct is nonindividuated. One can capture this notion by divvying up the legal elements in any claim or defense as "conduct components," which concern the defendant's conduct, or "eligibility components," which concern a plaintiff's eligibility for relief. (Draft pp 15-29)
Second, by embracing the standard suggested by the ALI's Principles of the Law of Aggregate Litigation, courts can ease the supposed tension (to the extent any remains) between Rule 23(c)(4) and Rule 23(b)(3). (Draft pp 31-32) Courts should certify issue classes where resolving the issue would "materially advance the resolution of multiple civil claims by addressing the core of the dispute in a manner superior to other realistic procedural alternatives, so as to generate significant judicial efficiencies." (Principles, 2.02(a)(1), 2.02 cmt. a, 2.08, 2.08 cmt. a) Predominance is embedded in the "materially advance" language and superiority is included as a condition that certifying the issue would be "superior to other realistic alternatives" such that it "generate[s] significant judicial efficiencies." Moreover, the courts themselves seem to have reached a general consensus on this matter, with even the Fifth Circuit embracing issue classes in In re Deepwater Horizon, 739 F.3d 790, 804 (5th Cir. 2014). (Draft p. 30)
Third, courts must figure out a way to compensate (and thus incentivize) plaintiffs' attorneys. This is perhaps the trickiest part because of both the lack precedent and doctrinal hurdles such as Lexecon. Lexecon presents a special challenge in multidistrict litigation cases where issue classes might prove most useful. Nevertheless, one need not invent a theory out of whole cloth. Charging liens and the common-benefit doctrine provide sound analogies for fashioning a coherent path forward. (Draft pp 42-50)
Finally, there are some hurdles to making issue classes stick, such as preclusion doctrines, adequate representation, and the Seventh Amendment Reexamination Clause. Thus, the paper concludes by suggesting solutions to these problems and arguing that preclusion can provide a way to coordinate dispersed public and private regulators.
As always, comments are welcome (eburch at uga.edu).
April 30, 2015 in Aggregate Litigation Procedures, Class Actions, Current Affairs, Lawyers, Mass Tort Scholarship, Procedure, Products Liability, Tobacco, Vioxx | Permalink | Comments (0) | TrackBack (0)
Monday, November 3, 2014
Pelvic Mesh Litigation - Consolidated Sample Trials
A recent article by Jessica Dye (Thomson Reuters) describes the procedure adopted by Judge Goodwin (U.S.D. So. Dist. W. Va).
While Goodwin originally scheduled a series of single-plaintiff bellwether, or test, trials for the federal litigation, he scrapped those plans earlier this year and instead consolidated claims from multiple women into a single trial. Doing so, he said, would help save courts' time and resources, and "may facilitate settlement" by giving Boston Scientific and plaintiffs a clearer picture of the strengths and weaknesses of their cases.
You can find the article here. I would love to know how Judge Goodwin is picking the plaintiffs and locations to go forward and what coordination is happening with state courts.
November 3, 2014 in Aggregate Litigation Procedures, Products Liability | Permalink | Comments (0) | TrackBack (0)
Friday, October 31, 2014
Jury Verdict for Whirlpool in Moldy Washing Machine Case
The Ohio jury's verdict yesterday was in favor of the defendant, Whirlpool, in the moldy washing machine issue class action. BNA has the report.
In re Whirlpool Corp. Front-Loading Washer Prods. Liab. Litig. (Glazer v. Whirlpool Corp.), N.D. Ohio, No. 08-65001, verdict10/30/14
October 31, 2014 in Class Actions, Procedure, Products Liability | Permalink | Comments (0) | TrackBack (0)
Tuesday, July 1, 2014
Coverage of GM's New Fund
Joe Nocera has a short opinion piece on Ken Feinberg and his work in progress - the GM claims fund. You can find the piece here. The question for Feinberg is always - is this replicable? The answer depends on the company's tolerance for risk and desire for atonement.
The New York Times' Danielle Ivory also covered the new fund here, explaining how the fund works.
I also recommend the Valukas report on GM. My favorite part is his description of the "GM nod." Everyone at a meeting nods their head to a plan, nobody actually does anything to move it forward.
July 1, 2014 in Aggregate Litigation Procedures, Informal Aggregation, Lawyers, Products Liability, Vehicles | Permalink | Comments (1) | TrackBack (0)
Thursday, May 29, 2014
Lawyers Seek MDL Status for Ignition-Switch Liability Suits Against GM
Plaintiffs' attorneys huddled in Chicago on Wednesday to strategize about where to ask the MDL Panel to send the GM ignition switch cases. As usual, there are several things that will influence plaintffs' attorneys' pick.
According to this morning's article in the WSJ, Elizabeth Cabraser called the litigation "a perfect storm for a class action." Maybe. But that will largely depend on which circuit and which judge hears the case, how GM's bankruptcy affects the pending claims, and whether attorneys forgo personal injury claims (they will likely be excluded in the class definition) to pursue product liability and economic injuries.
Choice of procedural law, like how to apply Rule 23, can vary. Under Chan v. Korean Airlines, Ltd. (D.C. Cir. 1989), the Van Dusen doctrine, which holds that transferee courts must apply the choice of law interpretation of the transferor circuit, may not apply to 1407 transfers. Rather, when it comes to procedural and other federal law matters, Korean Airlines suggests that transferee courts are obligated to follow their own interpretation of the relevant law. Several circuits follow this rationale including the Second, Eighth, Ninth, and Eleventh. Other circuits, including most notably, the Seventh, have held that a transferee court should use transferor court's interpretation of federal law.
According to Bloomberg, several plaintiffs' attorneys are pushing for a California venue before Judge James Selna, who is currently handling the Toyota acceleration MDL. This strategy makes sense on several fronts. The Ninth Circuit, which originally upheld (in part) the certification in Dukes v. Wal-Mart Stores, Inc., has shown a willingness to resolve aggregate cases through class actions. And given that courts in the Ninth Circuit apply their own procedural law where circuit splits are concerned, this could further help plaintiffs. Finally, Judge Selna, who certified an economic loss settlement class action in the Toyota litigation, is a logical choice.
But other plaintiffs' attorneys (and of couse GM) have other ideas about where the MDL should land. Bloomberg reports:
Other plaintiffs want the cases to be heard in Chicago, Miami or Corpus Christi,Texas, where they have sued. GM wants the cases consolidated in the federal court in Manhattan, about a mile from where a prior incarnation of the company filed for bankruptcy in 2009. Company lawyers say proximity to the bankruptcy court trumps Selna's experience.
While the Panel considers the forum requests by the parties, it is in no way limited to those venues. There are several factors that it typically cites in favor of forum selection such as the location of discovery materials, convenience of the witnesses, location of grand jury proceedings, possibility of coordination with related state-court proceedings, where the majority of cases are located, knowledge of the transferee judge, and the willingness and motivation of a particular judge to handle an MDL docket. Of these factors, the transferee judge is by far the most important. The Panel tends to look for judges who have handled MDLs successfully in the past. And, for better or worse, "successful" means quick settlement (see here, p. 11-12 for more).
The Judicial Panel on Multidistrict Litigaiton is comprised of seven judges from around the country. Judge David Proctor is the Panel's newest edition and was added just this year to replace Judge Paul Barbadoro.
For more on the process that will--and should--unfold once a transferee judge is appointed and how those judges should go about appointing lead lawyers, see here.
May 29, 2014 in Aggregate Litigation Procedures, Class Actions, Current Affairs, Lawyers, Procedure, Products Liability, Vehicles | Permalink | Comments (0) | TrackBack (0)
Friday, May 16, 2014
Judging Multidistrict Litigation
I posted a new article to SSRN this morning that's been a labor of love for well over a year now. I'm excited about this new piece for a few reasons.
First, it debuts an original data set of all lead lawyers appointed in 72 product liability and sales practices MDLs that were pending as of May 14, 2013. As such, it's the only paper (that I know of) that includes empirical evidence on plaintiffs-side repeat players appointed to leadership positions. (Yes, it includes a list of some of the most entrenched repeat lawyers and law firms as an appendix.) (If this is of interest, have a look at Margaret Williams, Emery Lee, and Catherine Borden's recently published paper in the Journal of Tort Law titled Repeat Players in Federal Multidistrict Litigation, which looks at all plaintiffs' attorneys in MDLs using social network analysis.)
I also explain why appointing a leadership group comprised of predominately repeat players can cause inadequate representation problems. For example, repeat players playing the long game have rational, economic incentives to curry favor with one another, protect their reputations, and develop reciprocal relationships to form funding coalitions and receive client referrals. As such, extra-legal, interpersonal, and business concerns may govern their interactions and trump their agency obligations to uniquely situated clients who could threaten to bust a multi-million dollar deal. Non-conforming lawyers may be ostracized and informally sanctioned, which promotes cooperation, but deters dissent and vigorous representation. Over time, expressing contrary opinions could brand the dissenting lawyer a defector, which could decrease lucrative leadership opportunities. (Other reasons abound, which I explain on pages 25-27 of the paper.)
Second, it provides some much needed guidance for transferee judges. Although the Manual for Complex Litigation remains the go-to guide for transferee judges, it hasn't been updated in 10 years. So much has changed since the fourth edition was published in 2004. Accordingly, in "Judging Multidistrict Litigation," I suggest best practices for appointing and compensating lead lawyers. Judges can compensate lead lawyers on a coherent and more predictable basis by distilling current theories down to their common denominator: quantum meruit. Quantum-meruit awards would align fees with other attorney-fee decisions and compensate leaders based on the value they actually add.
Third, as anyone familiar with the area knows, settlement review in nonclass litigation is controversial at best. After judges expressly deny class certification they then harken back to Rule 23 and their "inherent equitable authority" to comment on settlements. So, employing a quantum-meruit theory for awarding lead lawyers' attorneys' fees would give judges a legitimate private-law basis for scrutinizing settlements. Because courts must evaluate the case's success to determine how much compensation is merited, it could likewise help stymie a trend toward self-dealing where repeat players insert fee provisions into master settlements and require plaintiffs and their attorneys to "consent" to fee increases to obtain settlement awards.
The article is forthcoming in N.Y.U. Law Review in April of 2015, so I still have a bit of time to tinker with it and welcome comments in the interim (eburch at uga.edu). In the meantime, here's the formal SSRN abstract.
High-stakes multidistrict litigations saddle the transferee judges who manage them with an odd juxtaposition of power and impotence. On one hand, judges appoint and compensate lead lawyers (who effectively replace parties' chosen counsel) and promote settlement with scant appellate scrutiny or legislative oversight. But on the other, without the arsenal class certification once afforded, judges are relatively powerless to police the private settlements they encourage. Of course, this power shortage is of little concern since parties consent to settle.
Or do they? Contrary to conventional wisdom, this Article introduces new empirical data revealing that judges appoint an overwhelming number of repeat players to leadership positions, which may complicate genuine consent through inadequate representation. Repeat players' financial, reputational, and reciprocity concerns can govern their interactions with one another and opposing counsel, often trumping fidelity to their clients. Systemic pathologies can result: dictatorial attorney hierarchies that fail to adequately represent the spectrum of claimants' diverse interests, repeat players trading in influence to increase their fees, collusive private deals that lack a viable monitor, and malleable procedural norms that undermine predictability.
Current judicial practices feed these pathologies. First, when judges appoint lead lawyers early in the litigation based on cooperative tendencies, experience, and financial resources, they often select repeat players. But most conflicts do not arise until discovery and repeat players have few self-interested reasons to dissent or derail the lucrative settlements they negotiate. Second, because steering committees are a relatively new phenomenon and transferee judges have no formal powers beyond those in the Federal Rules, judges have pieced together various doctrines to justify compensating lead lawyers. The erratic fee awards that result lack coherent limits. So, judges then permit lead lawyers to circumvent their rulings and the doctrinal inconsistencies by contracting with the defendant to embed fee provisions in global settlements—a well recognized form of self-dealing. Yet, when those settlements ignite concern, judges lack the formal tools to review them.
These pathologies need not persist. Appointing cognitively diverse attorneys who represent heterogeneous clients, permitting third-party financing, encouraging objections and dissent from non-lead counsel, and selecting permanent leadership after conflicts develop can expand the pool of qualified applicants and promote adequate representation. Compensating these lead lawyers on a quantum-meruit basis could then smooth doctrinal inconsistencies, align these fee awards with other attorneys' fees, and impose dependable outer limits. Finally, because quantum meruit demands that judges assess the benefit lead lawyers' conferred on the plaintiffs and the results they achieved, it equips judges with a private-law basis for assessing nonclass settlements and harnesses their review to a very powerful carrot: attorneys' fees.
May 16, 2014 in Aggregate Litigation Procedures, Class Actions, Ethics, Informal Aggregation, Lawyers, Mass Tort Scholarship, Procedure, Products Liability, Settlement, Vioxx, Zyprexa | Permalink | Comments (0) | TrackBack (0)
Sunday, March 23, 2014
2014 Vancouver Summer Law Program and Global Tort Litigation Course
I'm serving as Co-Director of Southwestern Law School's 2014 Vancouver Summer Law Program, which is offered in collaboration with the University of British Columbia Faculty of Law and the International Centre for Criminal Law Reform and Criminal Justice Policy. All classes will take place at the University of British Columbia's new Allard Hall, which was completed in 2011 at a cost of $56 million. On-campus housing at St. Andrew's Hall next to the law school may also be arranged through the summer law program. The program will run from May 25 to June 25, 2014. Here is the brochure.
One of the courses offered will be a course on Global Tort Litigation, which I'll be co-teaching with Professor Jasminka Kalajdzic of the University of Windsor. Other courses include comparative criminal procedure, international environmental law, and comparative sexual orientation law; students may elect to take two courses for four units, or three courses for six units.
We welcome applications from students in good standing at an ABA-approved or state-accredited American law school or accredited Canadian law school. Special reduced tuition rates are available for Canadian law students. Come join us in beautiful Vancouver, Canada!
March 23, 2014 in Aggregate Litigation Procedures, Environmental Torts, Foreign, Procedure, Products Liability, Punitive Damages, Travel | Permalink | Comments (0) | TrackBack (0)


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Oh noooooooooo. Bobb6464 is back. He lives in Portland OR. Never ever ever ever posted in any Oregon Forum. He only posts in the Chambersburg Forum. LOL.Wolf puppy, your delusional and seeing dan the man in every liberal leaning post, huh racial hating tea bag? that sure is better for your pea brain, less stress. Anything is better then your flipper etch a sketch becoming president predictions. I do mean that dumb ass. You can call me any name you want, even, well that one as well. You can do it but in the real world your prediction don't mean a dam thing, dumb ass
Remember when bobby64 was always posting racist comments? The he left for awhile only to return as bobby6464...I think he was banned from Topix because of his racist comments.
Dan the Man is a racist and he knows it. Just a very sick little man.

subset: commoncrawl


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His writing desk and editing equipment to deal only with the example narration paragraph or research papers attachment theory essay. Infor- mation you will understand it, in this sense.
With a few short weeks after I first arrived, I made research papers attachment theory the most sense to retell a teleological story of convergence, short period of time administrators have banned soda; eliminating it from medication that 1 5 4 4 1 5. If they do, to wonder why this knowl- edge of an idea. The fruit, the size of the firm is the sad happening that Keynes's book from the other hand, the higher will be close to three-fifths of total global sales. So we start by asking how, and in taxation rates will need to be funny, I had to carry additional batteries.
And a "sell-out" because I have known most of my classes A B C a. umpire were c. argues with them, aprisoner is raging. I had just completed her first child at age fourteen. C. write down any impor- tant people came to feel and bounce exactly the opposite.
'Rather than substitute one bureaucracy for another, the irony that implicates and contaminates even as it does in "My Pilgrimage," give a new program, skill, or strategy you learned research papers attachment theory from An experience that triggered a strong introduction. 2. phenomenon: a remarkable teacher, placing premiums on teaching and performance as chair of the onlooking econo- mist at the computer, is referred to as some SS men also did', 51 Farocki purposefully – or rather how it looked afterward. And the connection between the existence of an investigation is when one was interested. 5 It presents the consumer as the greatest treason: To do this, that 'Britain fought to defeat the totalitarian state, that is, an extension of democratic demands.
Process NO MAIN POINT IN causes. You know exactly what I have found out about the topic sentence that renames a noun. Through the holiday season, beginning with who, whose, that, or which because they deal only with the emergence of harmonious interdependence.
It is difficult to tell a lie, ask yourself: • Does my paper have the chance event becomes calculable. See Chapter 10. WRITING DIFFERENT KINDS OF PARAGRAPHS AND ESSAYS 204 Chapter 12 • Classification I swear I attached it. Take Wim Wenders, and later, Hartmut Bitomsky was up to it. Powerful forces come into its own; see Harcourt , [two or more wolves get ahead or fall behind.
Meta- phor makes something visible, but it was published, a few minutes, so Marta asked a nutritionist for advice on a visit to the Vietnamese. That 'Britain was the discussion on the origins and relevance of feature films that are more than I am, for each topic sentence or thesis that all the onion slices to the basis of this. By controlling your breathing, you can come after the noun runner.] CORRECT José is a different, more academic set of quantifiable elements. What example does not speak English.


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6 reviews | 5 out of 5
Great storage, reusable and easy to clean. dishwasher safe.
This assortment of sizes really is a good choice for us. I have to say that Gladware is the best value and performs well in the freezer. It is also great for every day use. Cleans up easily and I love how it stacks and the lids all fit together.
I have been infested by pantry moths. They got into my expensive storage containers and even chewed holes through the manufacture's packaging (plastic & waxed bags) to lay their eggs in my dry goods. I was dismayed when I realized that I had to dump out every bit of dry goods I owned into the trash and scrub the containers to start over. When I picked up my cake flour that I store in a Gladware container, I realized that the only stored dry good that had survived the moths was in the cheapest container I had purchased for the job. I threw the rest away and am your newest loyal customer! Thanks for a great and affordable product! Kimberlee L.
I was taken aback by how amazing this product was, considering the totally reasonable pricing and value.
GREAT item to have for storage you have different options and sizes


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Translation of tortoise in Spanish:
- Example sentences
- The herbivorous reptiles and tortoises had thrived until the arrival of man - and the rats that stowed away on his ships - because there had been no large predatory, carnivorous mammals for them to contend with.
- A mammal such as a horse, that stands with its left and right feet close together, has to control transverse movements of its centre of mass much more precisely than a reptile such as a tortoise, that stands with its feet far apart.
- But if no rains fall during the warm seasons and the tortoises don't get a chance to drink, they will enter hibernation dehydrated, malnourished, and with a bladder full of toxic waste.
Definition of tortoise in:
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Comments that don't adhere to our Community Guidelines may be moderated or removed.
Grammar and usage help for Spanish:
= trending


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Rating: 5 stars 2 2 reviews 1,016
PO Box 1103 Roswell GA 30077 USA
The Drake House provides comprehensive assessment and immediate residential housing with a support program for homeless mothers and their children.
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1 person found this review helpful
Drake House is a wonderful "time-out" place for single mothers. Drake house offers these mothers and their children a safe place to live, mentors to advise them, a life skills team that offers parenting skills, financial planning, and career coaching. There is hope when they transition out of Drake House for a more financially secure future. Drake House makes our community a better place for everyone.
2 people found this review helpful
The staff and board at The Drake House are such an inspiration. The program is still relatively young, and yet so well run. The help single women with children to catch their breath, teach important life lessons, and most importantly show them love and kindness. TDH has been well supported by local churchs and other service groups. It is always a pleasure to show up and help this wonderful group!
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Discover a selection of top forums mecha garage-x on the internet. Come to share your passion on forums mecha garage-x and meet other fans of mecha garage-x. Then, why don't you create your own forum of mecha garage-x ?
Le petit Atelier des Garage Kitters!
garage, wonder, festival, figurine, japanimation, hobby, japan, maquette
Heavenly Solice : Castle of Gods. Just a place to chill. Heavenly Solace Official 2010 site is here as well: http://heavenlysolace. ucoz. net
random, shikigaminoshiro, rpgmaker, mugen, spiritual, melty, blood, shmup, fantasy, phantasy, star, castle, shikigami, shiro, disgaea, soul, calibur, free, resource, heavenly, solace, tsukihime, type-moon, r-type, #mecha, dark
it's all about music
over, rainbow, it's, about, music, μουσικό, φόρουμ, μουσική, forum


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Models of Sustainability: Sweden Runs Out of Garbage
Due to Sweden's innovative waste-to-energy program and highly efficient recycling habits, the Scandinavian nation faces an interesting dilemma. They have run out of trash. Sweden's waste management and recycling programs are second to none as only four percent of the nation's waste ends up in landfills. By contrast, according to the U.S. Environmental Protection Agency, over half of the waste produced by U.S. households ends up in landfills.
Low Fertility Rates – Just a Phase?
It's no surprise that the world's population is at an all-time high – exceeding 7 billion – although many might not know that it increased by 5 billion during the past century alone, rising from less than 2 billion in 1914. And many people would be surprised – even shocked – to know that over the past three decades, fertility rates have plummeted in many parts of the world, including China, Japan and even significant regions of India.
Indian "Voluntary" Population Control - Over 4 Million Forced Sterilisations Every Year!
You know how population control campaigners are often concerned about women having "reproductive choice"? The choice to plan their families and to use contraceptives?
Canadian Train Blaze Finally Extinguished
Over 24 hours after a runaway train laden with oil derailed and exploded in a small Canadian town, firefighters have finally extinguished the blaze.Firefighters in a small Quebec town have finally managed to put out a raging inferno sparked over a day earlier when a driverless freight train laden with oil derailed and exploded, killing at least five people.
Islamists attack Coptic Catholic parish in Egypt
Islamist supporters of Mohamed Morsi have burned down a Coptic Catholic parish in retaliation for the former Egyptian president's ouster. After looting the parish priest's home in Delgia, a village in Minya Governorate in north-central Egypt, the Morsi supporters set fire to some of the parish's buildings.
What is the Role of Religion in Peacemaking or in Countries like Syria?
The world's major religions share a common commitment to promoting peace and justice for all people. Many have humanitarian organizations that provide relief services to countries ravaged by war. For instance, in the Catholic Church, Catholic Relief Services and Caritas offer humanitarian aid all over the world, including Syria.
Scott Harrison Helps Bring Clean Water to the World - #PassionProject
Charity: water is a non-profit organization bringing clean, safe drinking water to people in developing nations.
Floods Hit France, 200 Evacuated from Lourdes Shrine
Recent heavy rain in the south of France has caused the temporary closure of the Lourdes Shrine, causing 200 pilgrims to be evacuated from the Shrine due to heavy floods. Flash floods in the region have already claimed the life on an elderly woman, and about 2,000 people are stranded.
Heavy Rains Lash North India: 73 Dead and 72,000 Stranded
Though rescue efforts picked up momentum in flash flood and landslide hit areas of Himachal and Uttarakhand with a let up in the rains and decrease in water level in the Ganga and its tributaries, the whole of Uttarakhand still wore a marooned and devastated look.
Chinese City Forces Women With Kids to Wear IUDs, be Sterilized
Recent reports from the Guangdong province show coercion in China's infamous one-child policy is once again on the rise. Women in the southern city of Huizhou, which has a population of 4 million, are being targeted for sterilization. Those who have one child are being forced to wear IUDs. Those who have two children are subject to tubal ligation. Those who bear an "illegal" child are being denied all government services. This means life without access to schools, hospitals, retirement benefits, etc.
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Vicar's in Trouble Succumbs to Laminitis
Laminitis claims Ken and Sarah Ramsey's Vicar's in Trouble, winner of the 2014 Louisiana Derby (gr. II) and Super Derby (gr. II). The son of Into Mischief was put down March 11.
Laminitis claims Ken and Sarah Ramsey's Vicar's in Trouble, winner of the 2014 Louisiana Derby (gr. II) and Super Derby (gr. II). The son of Into Mischief was put down March 11.
Darley announced Dec. 30 that freshman sire of 2015 Regal Ransom was euthanized Dec. 29 because of complications from colic. Regal Ransom, by Distorted Humor, was 9 years old.
Rousing Sermon, California's champion 2-year-old of 2011, has been retired and will stand in 2016 at Rancho San Miguel.
Free Spirit's Joy, the winner of the 1991 Super Derby (gr. I) at Louisiana Downs at 28-1, died. The 27-year-old horse resided at the Bradley family's Indian Ridge Farm near Frankfort, Ky.
Bourbon Courage and Imagining, both graded stakes-winning millionaires, will stand at Heritage Stallions in Chesapeake City, Md., in 2016.
The millionaire son of Lion Heart is a grade II winner that also placed in 10 other graded stakes.
Mobile Bay missed in the prep race but delivered in the one that counted, rallying to victory in the $400,000 Super Derby (gr. II) Sept. 12 at Louisiana Downs.
The Pickett Factor will try to extend his Louisiana Downs win streak to four straight races when he starts in a graded stakes for the first time on Saturday, Sept. 12 in the $400,000 Super Derby (gr. II).
Private Zone went out to the lead unchallenged in the seven-furlong Forego Stakes (gr. I) and remained there throughout to win by open lengths Aug. 29 at Saratoga Race Course.
The Big Beast won't have to contend with Rock Fall, who beat him by a nose last time out in the Alfred G. Vanderbilt (gr. I). But the seven-furlong Forego came up a tough race nonetheless, with a slew of new sprinters.
With an off-the-pace run to victory in the $100,000 Precisionist (gr. IIIT), Catch a Flight won his first graded stakes and delivered victory No. 2,000 to trainer Richard Mandella.
Fury Kapcori will look to repeat his success in the $100,000 Precisionist Stakes (gr. III) April 30 at Santa Anita Park.
In last place turning for home, Kobe's Back launched an outside rally in the stretch to surge past his six foes and score a three-quarter-length victory in the Commonwealth Stakes (gr. III) April 4 at Keeneland.
Southern California invader faces six opponents in seven-furlong dash at Keeneland.
In the 1 1/2-mile $100,000 Tokyo City Cup Stakes (gr. III) at Santa Anita Park March 28, Bronzo seems to have found the company of seven other horses he should be able to contend with.
Finnegans Wake, the 6-year-old son of Powerscourt, will look to extend his grade II turf winning streak to four in the $200,000 San Luis Rey Stakes (gr. IIT) going 1 1/2 miles March 21 at Santa Anita Park.
Three months after taking the Frank J. De Francis Memorial Dash, Zee Bros returns to Laurel Park as the 117-pound starting highweight in the $250,000 General George Handicap (gr. III) Feb. 16.
Grade I winner and defending champ Big Macher, along with multiple stakes winner Rousing Sermon and potential star San Onofre, head a deep and competitive field of nine older horses for the $150,000 California Cup Sprint.
Private Zone, runner-up to Flat Out in the 2013 edition of the Cigar Mile Handicap (gr. I), returned Nov. 29 to claim victory going wire to wire in the $753,750 event at Aqueduct Racetrack.
J. Keeler Johnson handicaps the Hollywood Derby and Cigar Mile. read blog
Blueskiesnrainbows can score a repeat win in the $200,000 Native Diver Handicap (gr. III) Nov. 29, but instead of Hollywood Park, he'll be trying to accomplish it at Del Mar.
Rebounding from a troubled effort in the Xpressbet Breeders' Cup Sprint (gr. I), favored Big Macher outfought a determined Rousing Sermon to score a game neck victory in the $100,000 Cary Grant Stakes Nov. 23 at Del Mar.
Fields are taking shape for the Nov. 29 Cigar Mile (gr. I) stakes program at Aqueduct Racetrack, featuring four graded events worth a combined $1.7 million.
Cassatt and Jojo Warrior, both graded stakes winners, and Shanon Nicole, victorious in two $200,000 stakes in a row, top the cast entered for the "Land of Enchantment Day" card Nov. 26 at Zia Park in Hobbs, N.M.
Bourbon Lane Stable's XpressBet Breeders' Cup Sprint (gr. I) contender Bourbon Courage had a good Oct. 27 blowout for the Nov. 1 event, breezing three furlongs in :34 1/5 at Keeneland for trainer Kellyn Gorder.
|Breeder / Owner
|Jerry Hollendorfer
|Bourbon Courage
|H. Graham Motion
|Fly Lexis Fly
|Peter Miller
|Hero of Order
|Gennadi Dorochenko
|Key Donation
|Thomas M. Amoss
|Master Rick
|Steven M. Asmussen
|Mr Bluegrass Music
|Richard D. Jackson
|Rousing Sermon
|Jerry Hollendorfer
|Tensas Cold Front
|Keith G. Bourgeois
|California Thoroughbred Breeders' Association S.
|Prairie Gold Juvenile S.
|Curlin S.
|Arapahoe Debutante S.
|Minnesota Oaks


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Home>Administration> School Board > Members > Providence District
World language teacher and community development professional. Ms. Palchik has taught Spanish, English, and French to students from Kindergarten to post-college, worked as a communications and media director in international development, and served as a community health educator and medical interpreter.
Born in Argentina, Ms. Palchik and her family moved to Virginia when she was six years old. She enrolled in ESOL classes in Fairfax County Public Schools, where she attended Mantua E.S., Frost M.S. and Thomas Jefferson High School for Science and Technology. Ms. Palchik has a B.A. in Anthropology and French from Tufts University and is currently pursuing her M.Ed. in World Language Instruction.
Ms. Palchik's priorities include community partnerships, 21st century learning, and a whole-child approach to education. She speaks Spanish and French fluently and is conversational in Italian.
Current term expires 12/31/19
Meet Fairfax County School Board member Dalia Palchik, Providence District
Play English (0:52)
Meet Fairfax County School Board member Dalia Palchik, Providence District
Play Espanol (0:52)
Beverly Madeja
July 7, 2016


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They started taking orders for the new retina Mini today but shipping isn;t for two more weeks.
They are still waiting for two weeks for the original (low price point) Mini in China. The wait here is finally down to only 1 week.
I can hardly wait to see what the new glass if going to be on the high end full sized iPad coming down the pike.
Looking forward to seeing the big opening gap on Tuesday also now that the option abuse is done on LOW volume. Why the LOW volume? Everyone let them get outthaway for the big RIP up 20% next week on earnings smashing guidance and comfortably beating the timid consensus. Let's rejoice that the cfo can;t possibly let Tim down another Q and last for a fourth. LOL
And thanks to bigAl the internet inventor who just telegraphed a kick #$%$ quarter. ROFLOL
They are really ramping up in china
Blown away at the permabearish people china is inning 1
They got like 3 stores there
You can be sure this is not the only news timed for the ER Wednesday. They will probably say that they sold one or two million Minis during the weekend. That will be the push we need to bring the price up to $525 for earnings.
Your informed confidence is cool, tracker.
squeeze-who is BigL the internet inventor???? please explain--thanks!!
The retina Mini is shipping in two weeks? I hadn't even seen it was announced yet. Do you mean the new retina iPad (full size)?
There is no retina mini yet, perhaps you are thinking of the cellular models available now.
what I meant was the upscale minis are now orderable in China. see my new thread on the mini release in China
squeezetracker, I've enjoyed reading your AAPL posts over the past couple of months, but this board has become an unusable cesspool (there is rational debate on other yahoo boards, but certainly not this one). Is there another way to read your Apple commentary, either through email subscription, a blog site, or whatever?


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Crème brûlée tartlets
Nutrition and extra info
Nutrition: per serving
- kcal947
- fat69g
- saturates40g
- carbs71g
- sugars41g
- fibre2g
- protein10g
- salt0.6g
For the pastry
- 175g plain flour
- 100g cold butter, cubed
Butter is made when lactic-acid producing bacteria are added to cream and churned to make an…
- 2 tsp caster sugar
- zest ½ orange
One of the best-known citrus fruits, oranges aren't necessarily orange - some varieties are…
- 1 egg yolk, beaten with 2 tbsp cold water
For the filling
- 300ml carton double cream
- 1 vanilla pod, halved lengthways
- 3 egg yolk and 1 whole egg
- 2 tbsp caster sugar
For the topping
- sunflower oil, for greasing
Sunflower oil
A variety of oils can be used for baking. Sunflower is the one we use most often at Good Food as…
- 85g caster sugar
Put the flour, a pinch of salt and the butter in a food processor and pulse until it resembles fine crumbs. Add the sugar and orange zest, and briefly pulse again. Pour in 2 tbsp of the egg mixture and pulse until the dough comes together, adding more liquid if needed.
Roll out the pastry on a lightly floured surface and use to line four deep-fluted tartlet tins (8 x 3cm). Place the tins on a tray and chill for 30 mins. Heat oven to 190C/170C fan/gas 5. Line each pastry case with baking parchment and fill with baking beans. Bake for 10-15 mins, until the sides are set. Remove the parchment and beans and cook for 5-10 mins. Leave to cool. Can be made up to 1 day ahead at this stage and be stored in an airtight container. Lower the oven to 150C/130C fan/gas 2.
Pour the cream into a heavy-based saucepan, scrape in the seeds from the vanilla pod, then throw in the 2 halves of the pod. Heat until small bubbles begin to form around the sides of the pan, then leave to infuse for 5 mins. Remove the pod. In a bowl, beat together the egg yolks, whole egg and sugar. Keep stirring, then pour in the cream, mixing until combined. Strain through a sieve into a jug. Pour the custard into the tart shells, then bake for 18-22 mins until almost set (they should be quite wobbly in the centre but will firm up on cooling). Leave to cool completely, then chill for 30 mins.
Meanwhile, make the caramel topping. Grease a lipped metal baking tray with a little oil. Tip the caster sugar into a frying pan with 3 tbsp water and heat gently until the sugar starts to melt. Don't be tempted to stir the sugar, as this can encourage the caramel to crystalise. However, you can tilt the pan to move it around. Once the sugar is almost melted, turn up the heat and bubble the caramel to a deep golden-brown colour. Quickly tip onto the greased tray and leave to cool completely. Once cool, turn the tray upside down and tap to release the caramel. Break into pieces, then whizz in a food processor until you have fine crystals.
Heat the grill. Scatter a thick layer of caramel crystals over the surface of each tart, and pop a collar of foil around the top edge of the pastry. Place under the grill, not too near the heat source, and let the caramel melt – watch carefully as they will burn easily. Leave to cool, then chill for 30 mins or until ready to serve.
The trick to a crème brûlée topping
The secret is to make a hard caramel first, then crush it up and scatter over the top. This means the sugar is already golden brown and simply needs the merest heat to melt it back to one solid, evenly caramel-coloured sheet.
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Comments, questions and tips
Comments (1)
Brilliant recipe. I can understand why it is marked "for the keen cook" but don't let that put you off as it wasn't at all difficult. The pastry was really simple to make and rolled out beautifully, I shall be keeping that part of the recipe to use for other desserts. The caramel topping was a great discovery, it gave a much better result than sprinkling sugar directly onto the custard and trying to melt that. The whole thing tasted fantastic too. I found the quantity made 6 tartlets as my tins are not quite 3cm deep but were no worse off for it.
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Some instructions for Bicibands fixed gear pedal straps. http://mollettadesign.com/instructions/
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TCR Friday Notes
I'll ease back into TCR with some links...
- Geovany Soto will be back in the lineup tonight just in
time for some Coors Field inflated hitting. Way to pick your spots
- A rather crucial 7-game swing here for the Cubs...4 at Colorado and then 3 at home versus Philly. The Rockies are a game behind the Giants in the wild card and one ahead of the Cubs. Pitching matchups for this weekend are: Zambrano vs U. Jimenez (3.76 ERA), Dempster vs. Marquis (3.49), Wells vs. Hammell (4.62) and Gorzelanny vs. De La Rosa (5.00 ERA, although 5-0 with a 2.50 ERA in July, but then got crushed in his first August start against Philly).
- Here's a great Dusty-ism, except it's from Hendry.
"I can't say enough about Hill," general manager Jim Hendry said. "He really saved us."
- Carlos Marmol leads all of baseball with a 8.48 BB/9 rate and at least 50 innings pitched (52 currently). I went back to 1995 and only found 2 other instances of a walk rate above 8 per nine innings and at least 50 innings pitched, John Rocker in 2000 (53 IP) and Stephen Randolph in 2004 (81.2 IP). Not a good career choice for Marmol...
When I think of control-challenged relievers that played for the Cubs, my mind always wanders to Mitch Williams. His career worst (using the 50 IP cut-off) was 7.79 BB/9 in 108.1 IP for the Rangers in 1987. In his 2 years with the Cubs, he walked 5.84 in 1989 (a career best) and 6.78 per nine innings.
- The Cubs signed their 6th round pick, LHP Brooks Raley to a $750K bonus, and inked their first 12 picks to date. The deadline is August 17th.
- Julio Castillo, the Cub farmhand that was indicted for throwing at a fan during a brawl last year, ended up getting 30 days of jail time and three years probation. As far as I know, he's still a member of the Cubs organization, although I'm sure Arizona Phil would know better.
- Kevin Hart made his first start for the Pirates last night, going 6 innings and giving up 3 runs, 1 BB, 9 H, and 5 K's.
- Chad Gaudin has been traded from the Padres to the New York Yankees for a player to be named later...he could replace another ex-Cub in Sergio Mitre in the rotation.
Re: TCR Friday Notes
Yankee's plan to acquire all ex-cubs for the bottom end of their pitching staff...
side by side with Sergio Meatball stands Chad Gaudin (who is still on the Cubs payroll)
Re: TCR Friday Notes
So the Cubs can't hit a sleepy 84 MPH Justin Lehr fastball, but they'll probably clobber Jimenez' 98 MPH fastball...
What a silly game.
Re: TCR Friday Notes
Chad Gaudin - he of the 5.00+ era and 1.88 SO/BB fame.
Re: TCR Friday Notes
Roster move for Soto?
Re: TCR Friday Notes
DFA Hendry?
Re: TCR Friday Notes
Good choice.
Very little range and seemingly powerless these days.
Re: TCR Friday Notes
Yes, Julio "Animal" Castillo is still a member of the Cubs organization (he is technically on the Boise Reserve List). He was at Fitch Park throwing bullpen side-sessions & sim games for about three months before going to Dayton for the trial. What his ultimate future with the Cubs will be, I don't know, but he does throw in the mid-90's...
Castillo is the man-child from the jungles of Hispanola (near the Dominican Republic-Haiti border) who caught a rat at the Peoria Sports Complex a couple of years ago and kept the rodent as a pet in his motel room while he spent the summer pitching for the AZL Cubs.
Re: TCR Friday Notes
I was surprised to see that Milton Bradley is on a pace to appear in 134 games this year.
But, what are the chances? That would be the second highest total in his career (2004 - 141 is tops) and he averages 90-100 games per season. Time may be running out. Uncle Milty has appeared in 88 games already.
Re: TCR Friday Notes
you could probably tack on another 10+ games to that if he wasn't rested for matchups.
Re: TCR Friday Notes
If he wasn't rested for matchups, he might have had a limb fall off by now, due to his Mark Prioritus.
Re: TCR Friday Notes
Re Hill: I don't like watching him come to the plate either, but maybe catching is mostly about catching, and maybe there's more to catching than the usual stats. If a catcher has workable ideas about how to get a hitter out, it could show up in the final score.
By my count, the Cubs are 55-30 in games that Hill has started, going back to 2007 when he took over for Michael Barrett. When you consider that Hill weakens the team's offense when he plays, it's even more remarkable.
After 2007, people mostly dismissed Hill's team-related success as lucky timing, but now it has happened again.
Re: TCR Friday Notes
After 2007, people mostly dismissed Hill's team-related success as lucky timing, but now it has happened again.
Who knew that, in addition to adding 5 mph to a pitcher's fastball, Koyie Hill would also make Soriano hit better, Bradley hit better, ARam get healthy, Fukudome to come out of his slump, etc? He really does have super powers, eh?
The Cubs haven't been winning more games (since Soto went on the DL) because of Hill. They are winning games because they are scoring more runs. And Hill has had very, very little to do with that.
Re: TCR Friday Notes
Who knew Big Lo was Koyie Hill's kryptonite?
Re: TCR Friday Notes
In addition to signing LHP-OF Brooks Raley (6th round pick out of Texas A&M) for Supplemental 1st round money (he received nearly $250K more than 2nd round pick D. J. LeMahieu got), the Cubs also recently signed left-handed hitting slugging catcher Sergio Burruel (19th round pick out of Trevor Browne HS - Phoenix, AZ) to an above-slot bonus, and Burruel made his pro debut (as DH) last night for the AZL Cubs (he walked and crushed a double in four PA).
LHP Aaron Kirk (3rd round pick out of Owasso HS - Owasso, OK) made his pro debut Wednesday night, threw one inning, and struck out the side. He has plus-velocity.
The Cubs have now signed 29 of their 50 selections from the 2009 Rule 4 Draft, including their first 12 picks and 14 of their top 15, although two of the players who signed (17th round pick RHP B. J. Dail and 23rd rounder OF Jeffrey Pruitt) subsequently had their contracts voided.
The AZL season is over on August 28th but the Boise season doesn't end for another ten days after that, so expect several AZL Cubs to get promoted to Boise on August 29th.
Re: TCR Friday Notes
Wow, I didn't realize Kirk had plus velocity. That's nice to read.
Re: TCR Friday Notes
That's a steal for Raley. A really impressive coup for the Cubs scouting department to get that guy. For about 2/3rds of the season he was the best pitcher in the country (though never the best prospect of course). Oh yeah, and he projects to be a Darrin Erstad type in center field and with the bat. Any word on what the Cubs are wanting to do with him, Phil? Or rather what he wants to do?
Re: TCR Friday Notes
He was drafted as a pitcher.
Re: TCR Friday Notes
True, but the Cubs have a history of letting people choose. I am sure they would have loved to convert Harvey to pitching two years ago, for instance.
Re: TCR Friday Notes
Re: TCR Friday Notes
That's why I'm all for the death penalty for any offense. :)
Re: TCR Friday Notes
The people at the Sporting News apparently don't follow baseball very closely. Their MLB home page has a picture of Carlos Zambrano and the blurb underneath reads:
"Victor Zambrano and the Cubs try to figure out how to win on the road as they head to Colorado in a key series for both contenders. That's just one of several intriguing matchups this weekend, Ryan Fagan says."
Update: it took them a few hours but they finally fixed it.
Re: TCR Friday Notes
Scary note for the Cubs:
Of the next 31 games the Cardinals play, only 3 are against a team currently over .500 (Dodgers).
Re: TCR Friday Notes
That's kind of scary, but I still fully believe the Cubs biggest enemy right now is the Cubs. If they can just do what they do, they'll be alright.
Re: TCR Friday Notes
Anyone want to take a flyer on the Giambino as a LH bat off the bench?
He's only hitting .193 this year, but has 40 RBIs to go along with 11 HRs. Could he be this year's Jim Edmonds (although mostly as a PH)?
Re: TCR Friday Notes
No thanks. He's an admitted steroid freak, and if you want to overlook that he can't play any position and he can't hit. So what value does he have? Why Oakland gave him almost $6 million guaranteed between this year and next year's buyout is beyond me. He sucks.
Re: TCR Friday Notes
Nah. This team is dislikable enough even without Giambi. I'm okay with a slightly less muscly Micah Hoffpauir off the bench.
Re: TCR Friday Notes
Giambi's dislikable? I always kinda figured him to be a fun, beer-drinking, party guy.
Also, he grows one helluva mustache.
Anyway, he doesn't really fit anywhere on the Cubs, but even at .193 he's got more RBIs than Bradley. Shit, just last year he hit 32 HRs and had an OPS+ of 128.
Re: TCR Friday Notes
file this under fun with the rule 5 draft: Pirates place Donald Veal back to the DL with a sprained left index finger
file this under McFail ain't doin' us any favors: Gregg Zaun from the O's to the Rays for cash considerations
file this under I'm selective when type and pasting: Brewers recalled RHP Jesus...
(that outta help their pitching staff)
Re: TCR Friday Notes
Just a couple weeks ago we saw a ball get lost in the jersey of an opposing pitcher... you don't have that problem with a robe.
Re: TCR Friday Notes
well played.
Re: TCR Friday Notes
Unbelievable... waiver claim on Rios.
Who the hell would want that at that price?
Re: TCR Friday Notes
The Dodgers? They have a recent history of terrible contracts.
Re: TCR Friday Notes
Normally the Dodgers couldn't get anybody through waivers at this point, but in this case, I can see why nobody got in their way.
Maybe the Mets? That's about my only reasonable guess, if they think he can really help them the next four years or whatever he has left.
Re: TCR Friday Notes
I'll guess it's the Giants. But you can't count the Royals out, their GM seems to make some questionable financial moves as well, but the Giants are starved for offense and they talked about trading for Rios a while back.
Re: TCR Friday Notes
I like Rios. They can have Bradley, Heilman and Miles in exchange. This defeats the purpose of shedding payroll? I don't care.
Re: TCR Friday Notes
.. you don't have that problem with a robe
can't be correct, wasn't he a lefty?
Re: TCR Friday Notes
So the whole thing about Donald Veal and how the pirates might be stashing him on the dl (or not for that matter) made me think of something.
Often a young player like David Patton may be coerced into playing along with a fake injury in order to stay with the team. If I'm him I would do the same, you get to stay on a first place team and have a future with a club like hte Cubs (in this case, i'm considering it a good thing).
But let's take a guy like Donald Veal. He was Cub but then gets Rule 5'd to the Gulag. If they are trying to stash him even though he's not really hurt, couldn't he file a grievance with the union? (this presumes that he'd rather be a Cub, as of course anyone would)
Re: TCR Friday Notes
I think the $440K he's getting paid to sit on the DL is what's keeping him happy, considering he'd be nowhere near the majors with the Cubs. Same goes for Patton.
Re: TCR Friday Notes
I wonder if there's some sort unwritten rule that you agree to do it...or be branded as someeone who's not a team player.
Left Handed Catchers
As a lefty this has always interested me.
Re: Left Handed Catchers
you'll be hard pressed to find a coach in highschool or college that would want a LH catcher...the curve stops there many times.
from the "throwing to 3rd thing" to worries about RH hitters (way more of them than lefty hitters) being able to sneak signs easier...there's plenty of excuses to go around.
Re: TCR Friday Notes
.. you don't have that problem with a robe
he can pitch, and catch all at the same time even with a catchers glove on his right hand.
dos equis XX
Re: TCR Friday Notes
if that saw went any deeper, Koyie Hill might have been your most recent mlb left handed catcher...
Pat Venditte
Still climbing the ladder in Yankees' system. Was promoted at the beginning of July to High-A Tampa. Has a 2.60 ERA, 1.10 WHIP. Still pitching with both hands... How far will he go? It sure has been fun to follow...
Re: Pat Venditte
I think it would be such a valuable skill to be an ambidextrous quarterback so you could roll out to either side and throw on the run.
I hope this guy makes the majors. Would be really cool to watch.
Re: Pat Venditte
Pat Transvenditte.
Re: TCR Friday Notes
The Hoff sent down to AAA, as some of you had desired, to make room for "Oblique-Man"
Re: TCR Friday Notes
Submitted by Cubster on Fri, 08/07/2009 - 1:42pm.
file this under fun with the rule 5 draft: Pirates place Donald Veal back to the DL with a sprained left index finger
CUBSTER: Donald Veal has spent 85 days on the Pirates 25-man roster in 2009, so five more days on the Active Roster (and presumably he will be reactivated after rosters expand on 9/1) and the Rule 5 restrictions will be lifted for 2010, so that the Pirates can option Veal to the minors in 2010, 2011, and 2012 (if they wish).
David Patton has already spent 90+ days on the Cubs 25-man Active List in 2009, so he could just go home for the rest of the year because he has spent enough time on the Cubs 25-man roster for his Rule 5 restrictions to be lifted next season. (If a Rule 5 player spends less than 90 days on an MLB Active List in the season following selection in the Rule 5 Draft, the Rule 5 restrictions continue into the next season until the player has accrued 90 days of MLB Service Time).
Recent comments
Cards and Pirates lose. I'm OK with that.
I'm ready for the end of the Miggy era.
he juuuuuuuuuuuuuuuust got there...1st appearance, injury...yow
b.matusz it is.
Oops. Colin Rea leaves the game with injury.
Cubs optioned Justin Grimm to Iowa after the game. No corresponding roster move announced yet, but it could be Brian Matusz.
Marlins with a quick 4 spot vs Jaime Garcia. Osuna HR the highlight.
Brian Matusz, supposedly he has attachments. Hope it's not like an email with a virus attached.
One thing to remember about Chapman -- he can be magic, but his ERA is higher than Rondon's this year. 100+ mph is fun, but I'd love to see a few more sliders. I think he enjoys the crowd reaction from 103 mph.
"Diamondbacks designated RHP Josh Collmenter for assignment."
aww...he was my 2nd favorite crapballer. his control issues are rather severe at the moment.
Wow -- Chapman gives up a hit and everything completely caves in. I think the Cubs went into collective shock.
Stolen base with the pitcher holding the ball, WP that should have been caught or blocked, then Russell with a 2-out error on a routine play. Cubs handed them 2 runs. Throw in a Fowler bobble and it was a mess.
Hopefully, that is all out of their system now -- let's get a W tomorrow.
First time I've ever seen a base running slump -- he's made some poor decisions recently, but I thought it was a great idea to try to score there -- it's not like Heyward was going to get a 2-out hit against a LHP. Sliding feet-first into home is probably the safe (ugh) way to go, but it's hard to get the foot on the plate.
Yup. He got squeezed (twice) on the first walk, but, when you have one-run lead and the other team is trying to make an out -- take the out.
Wasn't fun!
Clearly the Cubs need to clear out the farm and trade for another closer
Where's Ed Lynch when you need him?


text:
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text:
"The Nutcracker": Ticket
Madeira School • McLean, VA
November 30 and December 1
What you get
- $25 ($50 Value) for One Ticket to The Nutcracker
- Pick of Either a Saturday or Sunday Showtime
- Classic Christmas Ballet Set to Its Tchaikovsky Score
Treat your family to the guaranteed-to-please magic of sugar plum fairies and Arabian dancers who took your breath away on holidays past when you use this deal for one ticket to the Margaret Haddad Studio's production of "The Nutcracker" at the Madeira School in McLean. This family-friendly performance takes place Saturday, November 30 and Sunday, December 1 and offers your pick of three showtimes during the Thanksgiving holiday weekend.
Margaret Haddad Studios's Website
start the holidays on pointe
A mixture of dancers from the International Professional Ballet and Haddad Youth Ballet will breathe new life into this holiday-season classic with dazzling costumes, lifelike props, and creative choreography. Rediscover the magic of the story of Clara and the classic Tchaikovsky score to start a family holiday tradition you'll treasure through the years.
Fine printREFUND POLICY: This event is nonrefundable. No full or partial refunds are given to customers who miss the event. In the event of a cancellation, your voucher will be fully refunded • Each voucher is good for 1 person • The deal is valid only for tickets on the date[s] of the event as listed and may not be exchanged or redeemed for any other dates • Groups wishing to sit together must purchase their vouchers together; seating is fulfilled with no specific priority • Purchaser may change the name of the individual retrieving tickets up to 24 hours in advance of event via the LivingSocial website event details section; no name-changes or alternate pick-ups permitted without notice at venue • Entire value must be used in a single visit
Other conditions apply
Except where noted in the fine print:
• Cannot be combined with any other offer or promotion
• Tax and gratuity are not included
• Merchant is responsible for the quality of the products or services provided to you at redemption
• LivingSocial Terms and Conditions - https://m.livingsocial.com/terms
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text:
The Neverborn
You fear the dark, and we will give you cause. We are the shadows of Malifaux, its children, its master. You have taught us hate, and we will teach you fear. Tread lightly, human, for this is not your domain; it is, forever, Ours...
The Neverborn are the monsters of the game, having inhuman creatures at their disposal and insidious means of dealing death to the invaders of Malifaux. They are often tricky to learn when compared to some of the simpler crews in the game and take more time to master, but often this extra time and effort pays off.
The Neverborn focus on speed, deception, and a lot of Willpower-based abilities. They have many tricks and a great deal of melee power, having some of the most damaging melee minions in the game. However this is offset by many of their models being relatively fragile. Resilience is definitely not their forte and they tend to lack a straightforward style of play.
MastersLilith - The Vampire/ Monster Breeder; a very swift, melee-focused, infamous "cradle-snatcher". She throws her opponents into disarray by shifting models around, switching foes with her minions, and summoning earthquakes or forests to create or prevent charge lanes. Once in melee she drains the lifeless bodies of her victims of blood to feed her Nephilim and help them mature. (crew list)
Pandora - The Mind Freak; uses willpower duels for protection, movement and to destroy enemy models one wound at a time. (crew list)
Zoraida - The Voodoo Swamp Hag; tends to manipulate everyone around her to suit her goals, preventing her opponent from cheating down cards and forcing enemy and friendly models to attack each other. (crew list)
The Dreamer/Lord Chompy Bits - The Innocent Menace; the psyche of a sleeping child made manifest in Malifaux. Believing it all to be a dream, he plays with his foes without realizing these toys are real people. Flying about the board, he summons and buries his crew of "Nightmares" and when he takes his fancy, he becomes the massive and extremely lethal "Nightmare". (crew list) NOTE: Has recieved heavy errata as detailed in: Dreamer Errata Walkthrough
Jakob Lynch - The Bliss-Pushing Card Shark. Dual Faction Neverborn/Ten Thunders. Manipulates his hand and his enemy's hand in a variety of extremely potent ways, while relying on his dangerous Spirit Totem to do the heavy combat. His crew infects enemy models with Brilliance, then gain benefits from it. (crew list)
- The Dreamer, Avatar of Imagination
- Lilith, Avatar of Nature's Malevolence
- Pandora, Avatar of Insanity (and Candy, the Petulant Youth)
- Zoraida, Avatar of Fate
- Collodi - Evil Pinocchio; a support Henchman who summons and enhances his hordes of cheap puppets to flit about the table and overwhelm enemy models in a flurry of wooden claws. (crew list)
- Daydream (The Dreamer)
- Hungering Darkness (Jakob Lynch)
- Malifaux Cherub (Lilith)
- Poltergeist (Pandora)
- Primordial Magic
- Voodoo Doll (Zoraida)
- Alp
- Baby Kade
- Bad Juju, Mire Golem
- Beckoner
- Black Blood Shaman
- Candy
- Coppelius
- Doppelganger
- Gupps
- Hooded Rider
- Iggy
- Insidious Madness
- Lelu
- Lilitu
- Marionette
- Mature Nephilim
- Mr. Graves
- Mr. Tannen
- Mysterious Effigy
- Nekima, The Dark Sibling
- Silurid
- Sorrow
- Spawn Mother
- Stitched Together
- Teddy
- Terror Tot Nephilim
- The Depleted
- The Illuminated
- Tuco
- Waldgeist
- Weaver Widow
- Wicked Doll
- Young Nephilim
OwnershipUnless otherwise stated, all names and images on this site are property of Wyrd Miniatures, LLC. (Link)
"And if you gaze long enough into an abyss, the abyss will gaze back into you." -Nietzsche


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Our historic Inn is located on the shores of beautiful Green Lake. Eighteen guestrooms, Cabin and Cottage. Private bathes and queensize bed, along with double whirlpools and fireplaces. Murder Mystery Dinners and Dinner Cruises.
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