text:
Thursday, November 20, 2014
Lawyer Gets Paid
An attorney was properly paid a fee of over half a million dollars for his work in a contested probate matter, according to a decision of the New York Appellate Division for the Second Judicial Department
Karen Cullin retained James Spiess to represent her in a contested probate proceeding. The parties entered into a contingent fee agreement, pursuant to which Spiess agreed to represent Cullin for an initial retainer of $5,000 plus 33 % of any proceeds he would recover on her behalf, by settlement or trial, up to a maximum fee of $600,000. Just before Cullin was to be examined by potential objectants pursuant to SCPA 1404, Cullin directed Spiess to settle the probate proceeding as expeditiously as possible. Spiess negotiated a settlement providing, inter alia, for the propounded instrument, which primarily benefitted Cullin, to be admitted to probate in exchange for a minimal payment to the objectants. Speiss thereafter was paid, from estate funds, fees in the amount of $585,000.
The court here relied upon a recent (and, in my view, shamefully pro-lawyer) decision of the Court of Appeals in affirming the reasonableness of the fee
Here, the evidence supports the Surrogate's conclusion that the fee paid to Spiess was reasonable in light of the difficulty of the issues involved, the favorable terms of the settlement to which Spiess's efforts and expertise contributed, and the significant risk that Spiess took that probate of the propounded instrument would be denied and that he would not earn any fees other than the initial retainer of $5,000 (see generally Matter of Lawrence, ______ NY3d ______, 2014 NY Slip Op 07291, 9-10 [2014]). Under the circumstances, we perceive no basis upon which to disturb the Surrogate's determination with respect to Spiess's attorney's fee.
(Mike Frisch)
November 20, 2014 in Billable Hours | Permalink | Comments (0) | TrackBack (0)
Tuesday, October 28, 2014
Law Firm Hits Jackpot
The long running and hotly-contested dispute between the heirs of real estate magnate Sylvan Lawrence and the Graubard Miller law firm has been resolved in favor of the law firm by the New York Court of Appeals.
The court enforced a revised contingent fee retainer agreement found "unconscionable" by the lower court that results in a fee of $44 million for five months work on top of $18 million paid in hourly fees.
The court noted that the underlying estate litigation unexpectedly settled when the firm uncovered "smoking gun" evidence shortly after entering into the revised agreement.
The court
Beginning in 1983, defendant law firm Graubard Miller (Graubard or the law firm) represented Alice Lawrence (Lawrence) and her three children in litigation arising from the death of her husband and their father, Sylvan Lawrence (decedent), a real estate developer. At the time of decedent's death in 1981, his company owned commercial real estate in New York City valued at an estimated $1 billion. Decedent's brother and lifelong equal business partner, Seymour Cohn (Cohn), was executor of the estate. Cohn resisted selling decedent's properties and distributing the proceeds to Lawrence and the children, which caused Lawrence to bring suit in 1983. For over two decades, she and Cohn (and after he died in November 2003, his estate) battled in court (hereafter, the estate litigation)...
The estate litigation came to an abrupt and unexpected end on May 18, 2005, when the Cohn estate agreed to settle for over $100 million, a sum about twice what Graubard assessed the remaining claims to be worth. There quickly followed, though, this dispute between Lawrence and Graubard with respect to the law firm's fee, and the validity of certain gifts made by Lawrence to three Graubard partners in 1998. For the reasons that follow, we hold that the parties' revised retainer agreement was neither procedurally nor substantively unconscionable and is therefore enforceable; and that the Lawrence estate's claim for return of the gifts is time-barred.
The court found that a revised retainer that ended up substantially benefiting the firm was not unconscionable.
Further, the client was "no naif."
The court
We agree with Graubard that a hindsight analysis of contingent fee agreements not unconscionable when made is a dangerous business, especially when a determination of unconscionability is made solely on the basis that the size of the fee seems too high to be fair...
It is in the nature of a contingency fee that a lawyer, through skill or luck (or some combination thereof), may achieve a very favorable result in short order; conversely, the lawyer may put in many years of work for no or a modest reward.
Notably absent from the court's opinion is any discussion of the ethics rules governing fees and gifts.
A concurring and dissenting opinion would find that the return of gift claim is not time-barred.
The court here reviewed the decision of the Appellate Division for the First Judicial Department remanding the matter to the Surrogate for further findings.
The Appellate Division described the situation
In 1983, Mrs. Lawrence retained the Graubard firm to represent her in connection with her deceased husband's estate on an hourly fee basis, which retention was confirmed by letter dated August 4, 1983. Thereafter, the Graubard firm billed Mrs. Lawrence over $18 million in legal fees incurred in litigation instituted against the executor of the estate concerning his administration of the estate, as well as other matters. During that period more than $350 million in distributions were made to the beneficiaries of the estate. In addition, in December 1998, Mrs. Lawrence paid three of the firm's partners bonuses or gifts totalling over $5 million, plus approximately $2.7 million in gift taxes on such payments.
In November 2004, according to Mrs. Lawrence, she noticed that her legal bills were increasing to almost $1 million per quarter and asked about the possibility of entering into a new fee arrangement. As a result, in January 2005, a modified retainer agreement was entered into which provided, in pertinent part, that, commencing January 1, 2005, the firm would continue to bill Mrs. Lawrence on an hourly basis for services rendered with an annual cap of $1.2 million, exclusive of disbursements. In the event any additional monies were distributed to the beneficiaries of the estate, or Mrs. Lawrence settled the litigation with the executor's estate, the Graubard firm was to be paid from Mrs. Lawrence's share of such monies 40% of the total distributed to the beneficiaries, minus the total amount previously paid by her pursuant to the one-year, $1.2 million retainer. Prior to the revised retainer agreement, Mrs. Lawrence had personally negotiated with her nephew, the late executor's son, and received a $60 million offer from the executor's estate, but such offer did not result in a settlement.
On May 18, 2005, about four and a half months after the modified retainer agreement was entered into, the Graubard firm reached a settlement in the litigation against the former executor's estate in which it agreed to pay the Lawrence estate approximately $104.8 million. Shortly thereafter, Mrs. Lawrence retained new counsel and refused to pay the Graubard firm's fee.
On August 5, 2005, the Graubard firm filed a petition in Surrogate's Court to compel payment of its legal fees, asserting claims against Mrs. Lawrence for breach of the 2005 retainer fee agreement in the amount of 40% of not less than $110.3 million plus 40% of any additional sums paid to the estate, less $348,272.78 paid by Mrs. Lawrence to Graubard on May 6, 2005, together with statutory interest, or alternatively, quantum meruit legal fees in the same amount. The petition also asserted claims against the current executor, Richard Lawrence, for tortious interference with contract in inducing his mother's breach of the retainer agreement and to recoup for legal services benefitting the estate.
It is my view that this dissenting opinion from Judge Catterson with respect to the Appellate Division remand got it exactly right.
Because I believe that as a matter of law a legal fee of $40 million for five months work following years of litigation which was fully compensated on an hourly basis, is unconscionable, I respectfully dissent and would void the agreement embodying that fee. Further, because of the allegations by plaintiff that the defendants violated certain provisions of the Code of Professional Responsibility, I would refer the defendants to the Departmental Disciplinary Committee.
I cannot agree with the majority's view that the undisputed facts of this case are insufficient for a ruling of unconscionability as a matter of law. Specifically, it is undisputed that, for almost the entire year prior to January 2005, Graubard focused on litigating an accounting claim after Alice Lawrence (Alice) declined a $60 million dollar settlement offer on that claim. It is also undisputed that five and half months after signing the modified retainer agreement containing the 40% contingent fee provision, Graubard finalized a settlement of approximately $100 million dollars on the claim. It then sought $40 million as its contingent fee.
In other words, having billed Alice for every hour expended on work in connection with the claim after Alice left the $60 million offer on the table, Graubard now seeks to retain every dollar over and above that amount as its contingent fee, essentially divesting Alice of any benefit she may have gained from Graubard's legal services. The majority's contention that the circumstances underlying the agreement must be further fully developed is incomprehensible in the face of this substantive unconscionability.
For these reasons as set forth more fully below, I believe that, the agreement embodying that fee should be declared void.
This decision is a huge win for the lawyers but a lamentably pro-lawyer view of unconscionable fees. (Mike Frisch)
October 28, 2014 in Billable Hours | Permalink | Comments (0) | TrackBack (0)
Friday, October 24, 2014
Amount Due
A law firm was entitled to its legal fees, notwithstanding errors made by its original counsel, according to a decision of the New York Appellate Division for the First Judicial Department:
The motion court properly concluded that the varying figures given by R & M during this litigation, as to the total outstanding fees due, did not undermine R & M's prima facie case for an account stated, inasmuch as the discrepancies were plainly attributable to the incompetence of its original attorney in drafting the motion papers on its previous motions for summary judgment, which, inter alia, did not include R & M's complete billing invoices from the past, and records of off-sets that the parties had agreed to. The monthly invoices and records - the timely receipt of which Sakow never disputed - were never challenged by Sakow as to accuracy or reasonableness until the instant litigation was commenced years later. Such circumstances, including that Sakow continued to make payments towards the total fees accrued and billed, without reservation, belie the belated challenges to the reasonableness of the invoiced fees...
The record reflects that R & M represented Sakow on many legal matters since 1989, and that R & M would send regular, detailed monthly invoices to account for the fees claimed. The record also demonstrates that Sakow never denied receipt of invoices supporting the "balance forward" figure referenced in the March 7, 2002 invoice, that no objection was raised as to such invoices, and that Sakow continued to make regular payments towards the invoices.
(Mike Frisch)
October 24, 2014 in Billable Hours, Clients | Permalink | Comments (0) | TrackBack (0)
Wednesday, October 1, 2014
Buck Rogers In The 21st Century
When lawyers sue their former clients for unpaid fees, the result often is a return volley alleging legal malpractice.
The New York Appellate Division for the First Judicial Department dealt with such a situation in a decision issued yesterday.
The former client
The Dille Family Trust (the Trust), of which defendant is trustee, owned trademarks and copyrights for "Buck Rogers." Two of the Dille family members are beneficiaries of the trust; their grandfather's syndicate had obtained the Buck Rogers trademark and copyrights. The syndicate had hired Philip Nowlan to create comic strips based on the character, and his heirs started cancellation proceedings to terminate the syndicate's trademark rights and obtain the rights for themselves. The beneficiaries of the Trust retained plaintiff law firm to handle intellectual property matters, including the cancellation action.
The trial court erred in part
Contrary to the motion court's conclusion, there was a valid fee agreement between plaintiff and the Trust. The better practice would have been to send the engagement letter to the trustee, rather than only to the beneficiaries. However, the record, including email exchanges between the trustee and plaintiff, shows that the trustee was well aware of and approved of the beneficiaries' authority to act on the Trust's behalf with regard to plaintiff's retainer and representation (see Granato v Granato, 75 AD3d 434 [1st Dept 2010]). It is irrelevant that the original engagement letter was not signed by the client (see 22 NYCRR 1215.1[a]).
While the court found a triable dispute over the bill, the legal malpractice counterclaim failed
Regarding the legal malpractice counterclaim, assuming that plaintiff's conduct, in failing to complete a chain-of-title report or failing to resolve the underlying intellectual property disputes before withdrawing, amounts to negligence, the Trust failed to demonstrate causation. The Trust failed to show how it would have successfully opposed the underlying trademark cancellation proceeding, or would otherwise have protected its intellectual property rights, but for plaintiff's omissions.
In addition, the resulting inability to efficiently market the trademarks is too speculative to constitute the "actual ascertainable damages" required to support the malpractice counterclaim.
Beneficiary Flint Dille's bare allegation that he and plaintiff had agreed to a $25,000 fee cap is unsupported in the engagement letter sent to Dille listing an hourly rate or by anything else in the record, and therefore cannot establish a legal malpractice counterclaim. (citations omitted)
(Mike Frisch)
October 1, 2014 in Billable Hours, Clients | Permalink | Comments (0) | TrackBack (0)
Thursday, September 4, 2014
Suit For Legal Fees Subject To Mandatory Arbitration In D.C.
The District of Columbia Court of Appeals has held that a suit initiated by a law firm for unpaid fees must be sent to the Bar's arbitration program on the former client's demand.
Judge Fisher noted that
BTP, a biotechnology firm, retained [Ludwig & Robinson] as counsel in March 2011 to help resolve a trade secret dispute. The dispute was settled in May 2012, L&R having billed BTP on a monthly basis during the course of its representation. By June 2012 L&R claimed that BTP owed approximately $1.7 million in outstanding legal fees, disbursements, and expenses. In January 2013 L&R brought suit to collect its fees.
Several weeks later, BTP responded to the complaint by filing a motion to stay the trial court proceedings and compel arbitration. In addition to claiming that L&R had expressly agreed to arbitrate the fee dispute, BTP argued that a binding agreement to arbitrate had been formed by operation of law. BTP cited Rule 8 of the D.C. Bar"s Attorney/Client Arbitration Board ("ACAB"), which states that "if a client files a petition to arbitrate a fee dispute with a lawyer, the lawyer is deemed to have agreed to arbitrate."
Significantly, the court upheld the Bar's mandatory arbitration regime
L&R contends that this court lacked authority to promulgate Bar Rule XIII. Quite to the contrary, this court possesses broad authority to regulate the practice of law, deriving much of this power from the District of Columbia Court Reorganization Act of 1970. A portion of that Act, passed by Congress, provides that "[t]he District of Columbia Court of Appeals shall make such rules as it deems proper respecting the examination, qualification, and admission of persons to membership in its bar, and their censure, suspension, and expulsion." D.C. Code § 11-2501 (a) (2012 Repl.). Beyond this broad statutory grant of authority, the court possesses significant inherent authority as well. In Sitcov v. District of Columbia Bar, we relied upon the "almost universally accepted" proposition "that the highest court in the jurisdiction is imbued with the inherent authority to define, regulate, and control the practice of law in that jurisdiction." 885 A.2d 289, 297 (D.C. 2005) (quoting Brookens v. Comm. on Unauthorized Practice of Law, 538 A.2d 1120, 1125 (D.C. 1988)).
The court rejected the contention that arbitration violated the law firm's Seventh Amendment jury trial rights.
The trial court had erred in declining to enforce the valid arbitration agreement. (Mike Frisch)
September 4, 2014 in Billable Hours | Permalink | Comments (0) | TrackBack (0)
Wednesday, August 27, 2014
Departing Associate Retains Contingent Fees For Ongoing Cases
In a fee dispute between an associate attorney and his former law firm over contingent fees, the Indiana Court of Appeals held that the associate was not unjustly by retaining the full fees generated by the cases.
The court majority relied on four actors
the clients chose to continue with the departing associate, there was no agreement between the firm and associate ("sophisticated parties") as to the consequences of his departure, there were no covenenants not to competeor provisions for file ownership, and the firm was well-compensated for the associate's work.
The majority rejected the trial court's suggestion that the firm could sue the clients.
A dissent by Justice Crone would remand to award the firm fees based on quantum meruit
I respectfully dissent. While it may be true that C&M was "very well compensated" for Daly's time while he was a salaried associate at the firm, that compensation is simply irrelevant to C&M's quantum meruit claim for the 1000-plus hours that C&M's attorneys contributed to the twenty-four cases that Daly took with him to Golitko & Daly.
(Mike Frisch)
August 27, 2014 in Billable Hours | Permalink | Comments (0) | TrackBack (0)
Tuesday, July 8, 2014
Consent Disbarment In Pennsylvania Becomes Censure In New Jersey
A lawyer who had consented to disbarment in Pennsylvania received a public censure as reciprocal discipline in New Jersey.
While that might seem unusual, there were some rather unusual circumstances
The record in the matter now before us reveals that respondent's paralegal, Bonnie Sweeten, had intercepted and concealed from respondent the petition for discipline, the equivalent of our formal ethics complaint, sent to respondent by the Pennsylvania ethics authorities. Sweeten explained her actions in an affidavit, the partial contents of which are contained in an August 25, 2009 Joint Stipulations of Fact and Law between respondent and the Pennsylvania disciplinary authorities...
The affidavit of the paralegal admited to concealing the disciplinary matter from the attorney.
However, the Pennsylvania Supreme Court later vacated the resulting suspension and remanded the matter.
Thereafter, the attorney consented to disbarment of her own accord.
The paralegal achieved a level of notoriety by a false abduction claim and embezzling her way to Disney World and then Club Fed, as reported by the Huffington Post.
But no suspension for the attorney in New Jersey based on the Pennsylvania consent for reasons the Disciplinary Review Board ("DRSB") explains
In conclusion, respondent is guilty of two separate offenses each of which would, on its own, warrant the imposition of a reprimand: practicing law while on inactive status and failing to supervise non-attorney staff. In addition, she failed to communicate with a client, used misleading letterhead and business account checks, engaged in conduct prejudicial to the administration of justice and failure to safeguard client funds. We conclude that a censure sufficiently addresses the totality of respondent's misconduct.
The Office of Attorney Ethics ("OAE") had sought a suspension with reinstatement conditioned on reinstatement in Pennsylvania, which would be tantamount to disbarment. Remarkably, the attorney did not even see fit to participate in the New Jersey proceedings.
I can understand the position of the OAE, which would not impose disbarment because there is no possibility of reinstatement in New Jersey. OAE's proposed sanction is thus quite reasonable.
The DRB's recommendation makes no sense to me at all. And the court just rubber-stamped it.
It is my experience that an attorney (particularly if represented by counsel) does not consent to disbarment unless disciplinary counsel has the goods. The idea of reciprocal discipline is basically that other jurisdictions respect and enforce a consent unless there is some grave injustice or due process violation.
I don't see any such suggestion here.
I find it quite disheartening that the New Jersey authorities would take a consent disbarment and convert it into no suspension at all as reciprocal discipline.
Notice to all Pennsylvania attorneys who are thinking about engaging in misconduct: join the New Jersey Bar. (Mike Frisch)
July 8, 2014 in Bar Discipline & Process, Billable Hours | Permalink | Comments (1) | TrackBack (0)
Friday, May 16, 2014
The Mother Of All Excuses Fails
An Illinois Hearing Board has proposed a suspension of three years and until further order in a case involving misuse of entrusted funds.
The attorney's explanation?
His mother did it:
Although Respondent denied committing misconduct, he acknowledged using funds that had been improperly transferred from his IOLTA account into his business account. Respondent claimed his mother, who was 82 years of age at the time of the hearing, transferred the funds without his knowledge. Respondent also claimed his mother was responsible for fabricating the false bank statements he submitted to the ARDC.
The Hearing Board did not believe the testimony of Respondent and his mother and found Respondent committed all of the charged misconduct. Specifically, the Hearing Board found Respondent failed to promptly deliver to a client or third person funds that the client or third person is entitled to receive, engaged in conduct involving dishonesty, fraud, deceit or misrepresentation, knowingly made a false statement of material fact to a third person, knowingly made false statements of material fact in connection with a disciplinary matter, and engaged in conduct prejudicial to the administration of justice.
The Hearing Board found a substantial amount of aggravation, including Respondent's false testimony in this proceeding, pattern of dishonesty, and failure to recognize his misconduct. There was minimal mitigation. After considering the proven misconduct and case law, the Hearing Board recommended that Respondent be suspended for three years and until further order of the court and that he be required to pay restitution within six months of the final order of discipline.
(Mike Frisch)
May 16, 2014 in Billable Hours | Permalink | Comments (0) | TrackBack (0)
Thursday, April 3, 2014
Whichever is Greater
The New York Court of Appeals has held favorably to an attorney in a case that presented this issue
This appeal concerns the appropriate treatment of statutory counsel fees awarded under the New York City Human Rights Law where the contingency fee agreement does not explicitly mention statutory fees. We hold that, absent a contract term expressly providing for a different distribution, an attorney is entitled to the greater of either the contingency fee or the statutory award.
The case involved former police officer two clients who retained counsel to sue New York but later became dissatisfied. The attorney sought declatatory relief when a dispute arose with the clients over her fees.
The court
...in light of their unequivocal terms, the Appellate [Fee] Agreements should be enforced as written. Because the statutory appellate fees exceeded the contracted-for minimum of $20,000 per appellant, per appeal, [attorney] Dorman is entitled to receive those court-ordered fees in their entirety. As for compensation owed to Dorman for her representation at trial, she is entitled to collect either one third of the jury award, or the statutory trial fees, whichever is greater.
(Mike Frisch)
April 3, 2014 in Billable Hours, Clients | Permalink | Comments (0) | TrackBack (0)
Saturday, February 22, 2014
Bar's Fee Arbitration Process Works Well (If You Are The Lawyer)
The Alaska Supreme Court affirmed an arbitration award in a claim against an attorney brought by the girlfriend of a former client.
The court held that the former client's claim that the award was procured by fraud was not reviewable.
In doing so, I would respectfully suggest, the court gives cold comfort to former clients who invoke the Bar's arbitration procedures and expect a decent result.
The attorney was retained (through the girlfriend) to represent the defendant on federal drug charges.
At the arbitration, they testified that they understood the fee arrangement was $25,000 if the matter did not go to trial, $50,000 if there was a trial and $75,000 if the trial required experts.
The attorney was paid $75,000 in cash up front. The cash was wrapped in a grocery bag.
The client pleaded guilty on the morning of trial. He sought return of "at least" $50,000. The attorney refused, claiming that the arrangement was for a flat, non-refundable fee.
At the arbitration, the attorney produced a purported fee agreement to support his "non-refundable" claim. The client and girlfriend denied that the agreement was genuine and claimed fraud. The girlfriend asserted that she had not signed it.
The arbitration panel found the fee to be reasonable. While the arrangement may have violated ethical rules governing fees, the panel accepted the attorney' version of the fee arrangement and told the client that he could complain to the bar counsel about the potential ethics rule violations.
The court here found that the courts no authority to review the client's claim that the award was procured by fraud.
The attorney thus gets to keep the $75K (and presumably the grocery bag).
To put it mildly, the Bar's fee arbitration process worked very well from the point of view of the lawyer. For the client, not so much.
The court offered little recourse even where the fee may have violated Rule 1.5. (Mike Frisch)
February 22, 2014 in Billable Hours | Permalink | Comments (1) | TrackBack (0)
Friday, November 8, 2013
One Retainer Covered Two Representations
A single retainer agreement sufficed to cover a second matter and entitled counsel to legal fees, according to a decision of the New York Appellate Division for the First Judicial Department:
The record establishes plaintiff's entitlement to recover the unpaid legal fees that arose from its representation of defendants in two underlying actions. Contrary to defendants' contention, the subject retainer agreement governs plaintiff's work on both underlying matters. In compliance with 22 NYCRR 1215.1, which mandates that retainer agreements contain an "explanation of the scope of the legal services to be provided" (22 NYCRR 1215.1[b][1]), the agreement specifies that plaintiff's services "will include legal representation and advice with respect to specific matters that you refer to the Firm." Although defendants initially sought plaintiff to represent them in only one of the underlying actions, it is undisputed that they requested plaintiff's services with respect to the other action, shortly thereafter. Plaintiff's representation of defendants in the latter matter therefore falls within the ambit of the retainer.
The client did not challenge the invoices when rendered and could thus not attack the reasonableness of the fees. (Mike Frisch)
November 8, 2013 in Billable Hours, Clients, Law & Business | Permalink | Comments (0) | TrackBack (0)
Thursday, October 31, 2013
Oversight Does Not Extinguish Fee Claim In Lawyer-Lawyer Dispute
If you are a New York attorney and wish to be paid under a contingency fee agreement in a medical malpractice action, it is prudent to file the agreement with the Office of Court Administration in a timely manner --within 30 days.
That lesson emerges from a case decided yesterday by the New York Appellate Division for the Second Judicial Department.
Lawyer One retained Lawyer Two to assist in the litigation. When the case was resolved, Lawyer Two contended that Lawyer One had shortchanged him.
Lawyer Two had inadvertantly failed to file the required papers. Fortunately for him, the court excused the lapse:
In exercising its discretion to extend the time to file the subject retainer statement pursuant to CPLR 2004, a court may consider such factors as the length of the delay, the reason or excuse for the delay, and any prejudice to the person opposing the motion. Here, the reason for the delay, in effect, [Lawyer Two's law office failure, was an isolated, inadvertent mistake and there is no prejudice to [Lawyer One], as the remaining contractual contentions will be resolved in connection with any separate plenary action that may be commenced. Accordingly, the Supreme Court providently exercised its discretion in permitting the filing of a retainer statement nunc pro tunc by extending the time to do so for "good cause" shown (citations omitted)
(Mike Frisch)
October 31, 2013 in Billable Hours | Permalink | Comments (0) | TrackBack (0)
Wednesday, October 23, 2013
Motion To Withdraw Improperly Denied
The Washington State Court of Appeals, Division II has reversed and remanded a trial court order denying an attorney's motion to withdraw from the representation of the plaintiffs in a medical malpractice case.
The clients, after an initial payment, had failed to satisfy obligations under the fee agreement to pay costs. The attorney had advanced significant sums for experts and depositions in the litigation.
Further representation would result in an unreasonable financial burden on [the attorney] and that with their dispute over fees and the resulting professional conflict, the [clients] rendered [the attorney's] representation unreasonably difficult...This is not one of those rare cases where [the attorney's] withdrawal would have harmed the efficiency of the judicial system, and we do not see that her withdrawal would have had a materially adverse effect on the [clients'] interests. Trial had not been set and there were no dispositive motions before the court when [the attorney] moved to withdraw.
The attorney had given notice of her intent to withdraw with ample time to secure new counsel. In fact, successor counsel was eventually retained.
That fact did not moot the withdrawal issue, according to the court.
The court concluded that the trial court abused its discretion in denying the motion to withdraw and remanded for entry of an order granting withdrawal as of June 15, 2012. (Mike Frisch)
October 23, 2013 in Billable Hours, Clients, Hot Topics, Law & Business | Permalink | Comments (0) | TrackBack (0)
Thursday, September 5, 2013
Attorney Charged With Confidentiality Breach In Response To Unfavorable AVVO Review
The Illinois Administrator has filed a complaint alleging two counts of misconduct on the part of the accused attorney.
One count alleges that the attorney violated her duty of confidentiality by responding to a client's unfavorable review of her services:
On or about September 6, 2012, Respondent agreed to represent Richard Rinehart ("Rinehart") in matters related to Rinehart's securing unemployment benefits from his former employer, American Airlines. Shortly before hiring Respondent, American Airlines had terminated Rinehart's employment as a flight attendant because Rinehart allegedly assaulted a fellow flight attendant during a flight. At that time, Rinehart paid Respondent $1,500 towards her fee.
Between September 6, 2012 and January 16, 2013, Respondent met with Rinehart on at least two occasions and obtained information from Rinehart concerning his employment history at American Airlines and information concerning the alleged incident involving the other flight attendant. Respondent also reviewed Rinehart's personnel file, which she had obtained from American Airlines.
On or about January 16, 2013, Respondent represented Rinehart at a telephonic hearing before the Illinois Department of Employment Security ("IDES"), which resulted in the IDES denying Rinehart unemployment benefits. Shortly thereafter, Rinehart terminated Respondent's representation of him.
On or about February 5, 2013, Rinehart posted a client review of Respondent's services on the legal referral website AVVO, in which he discussed his dissatisfaction with Respondent's services. Rinehart stated in the posting that "She only wants your money, claims "always on your side" is a huge lie. Paid her to help me secure unemployment, she took my money knowing full well a certain law in Illinois would not let me collect unemployment. [N]ow is billing me for an additional $1500 for her time."
Between February 7, 2013 and February 8, 2013, Respondent contacted Rinehart by email and requested that Rinehart remove the February 5, 2013 posting about her on AVVO. Rinehart responded that he refused to remove the posting unless he received a copy of his files and a full refund of the $1,500 he had paid.
Sometime between February 5, 2013 and April 10, 2013, AVVO removed Rinehart's posting from its online client reviews of Respondent.
On or about April 10, 2013, Rinehart posted a second client review of Respondent on AVVO. In the April 10, 2013 posting, Rinehart stated that "I paid Ms. Tsamis $1500 to help me secure unemployment while she knew full well that a law in Illinois would prevent me from obtaining unemployment benefits."
On or about April 11, 2013, Respondent posted a reply to Rinehart's April 10, 2013 client review. In that reply Respondent stated that:
"This is simply false. The person did not reveal all the facts of his situation up front in our first and second meeting. [sic] When I received his personnel file, I discussed the contents of it with him and informed him that he would likely lose unless the employer chose not to contest the unemployment (employers sometimes do is [sic]). Despite knowing that he would likely lose, he chose to go forward with a hearing to try to obtain benefits. I dislike it very much when my clients lose but I cannot invent positive facts for clients when they are not there. I feel badly for him but his own actions in beating up a female coworker are what caused the consequences he is now so upset about."
By stating in her April 11, 2013 AVVO posting that Rinehart beat up a female coworker, Respondent revealed information that she had obtained from Rinehart about the termination of his employment. Respondent's statements in the posting were designed to intimidate and embarrass Rinehart and to keep him from posting additional information about her on the AVVO website.
(Mike Frisch)
September 5, 2013 in Billable Hours | Permalink | Comments (2) | TrackBack (0)
Thursday, May 30, 2013
Get It In Writing Or You May Not Get Paid
In a case dealing with a law firm's entitlement to fees in representing a divorce client, the New York Appellate Division for the First Judicial Department remanded in light of the non-compliance of the firm with with written retainer requirements:
Following arbitration, the law office commenced this action seeking unpaid legal fees in the amount of $83,775.69 and a trial was held on the claim. [Client] Blisko asserted that the retainer did not comply with 22 NYCRR 1400.3 because it did not state the "hourly rate of each person whose time" was charged to her, but rather only stated the hourly rate of [attorney] Eisenberger and made no mention of any other attorney working on the case. Blisko also contended that the retainer expressly stated that the law office's representation did not include being trial counsel. The trial court rejected Blisko's arguments and ordered her to pay $83,775.69 to the law office, in addition to the substantial amount she already had paid.
We modify because the law office should be denied any legal fees arising from representation of Blisko after the grounds trial commenced. The plain language of the retainer states that the law office's representation of Blisko includes work leading "up to" a trial, "but not including an actual trial." Indeed, the law office acknowledges that the retainer did not include representation at trial. Following the commencement of the trial on August 18, 2009, the retainer between the law office and Blisko terminated and plaintiff was representing Blisko without a written retainer.
The law office contends that, even if the retainer terminated when the trial began, it may still collect unpaid fees from Blisko because it substantially complied with the requirements of 22 NYCR 1400.3. The substantial compliance argument has no relevance to this issue because there was no trial retainer at all. If the law office wanted to be paid for representing Blisko at trial, it needed to have the client sign a new retainer. Moreover, there is no indication that the law office explained the limited nature of the retainer to the client, who then agreed to expand its scope to include the actual trial.
Although the law office cannot receive legal fees for any services completed after trial commenced, it may receive any outstanding unpaid fees for work completed prior to commencement of the actual trial. The law office substantially complied with the requirements of 22 NYCRR 1400.3 by giving the client the required statement of client rights and responsibilities and by listing the fee of the primary attorney. Blisko's testimony indicates that she was aware that more than one attorney was working on her case, and that she received bills reflecting the work of multiple attorneys.
Finally, as a general principle, the law office "need not return fees [it] properly earned." Although the retainer does not fully comply with 22 NYCRR 1400.3, the law office did complete work that was within the scope of the pretrial retainer, and therefore it is not required to return fees already paid to it for work completed before the trial. When a client is seeking the return of funds already paid to the attorney, the attorney does not need to show substantial compliance with 22 NYCRR 1400.3, but only that the fees paid were properly earned.
(citations omitted throughout)
(Mike Frisch)
May 30, 2013 in Billable Hours, Clients | Permalink | Comments (0) | TrackBack (0)
Friday, May 24, 2013
Court Remands Fee Award Of Over $15.8 Million
The New York Appellate Division for the First Judicial Department has remanded a matter involving legal fees charged to and gifts received from a wealthy widow in an estate matter:
Beginning in 1983, defendant law firm represented the family of Sylvan Lawrence in litigation concerning the administration of his estate. In 1998, Alice Lawrence, Sylvan's widow, paid three of the firm's partners, the individual defendants, a bonus or gift totaling $5.05 million and also paid the firm $400,000 as a bonus or gift. By the end of 2004, the widow had paid, approximately $22 million in legal fees on an hourly fee basis.
In the hope of reducing her anticipated legal fees in the ongoing litigation, the widow entered into a revised retainer agreement with the law firm in January 2005. The revised retainer agreement provided, inter alia, for a 40% contingency fee. In May 2005, the estate litigation settled with a payment to the estate of more than $111 million and, in accordance with the revised retainer agreement, the firm sought a fee of 40% of that amount. When the widow refused to pay the 40% contingency fee, this litigation resulted, in which, among other relief, the return of the gifts the widow made in 1998 is sought.
The court held
The revised retainer agreement is both procedurally and substantively unconscionable (Lawrence v Graubard Miller, 48 AD3d 1, 6 [1st Dept 2007], affd 11 NY3d 558 [2008]). The evidence shows that the widow believed that under the contingency arrangement, she would receive the "lion's share" of any recovery. In fact, as it operated, the law firm obtained over 50% of the widow's share of proceeds. Thus, the law firm failed to show that the widow fully knew and understood the terms of the retainer agreement — an agreement she entered into in an effort to reduce her legal fees...
In considering the substantive unconscionability of the revised retainer agreement, the Referee correctly considered such factors as the proportionality of the fee to the value of the professional services rendered, the sheer amount of the fee, and the risks and rewards to the attorney upon entering into the contingency agreement. With regard to the last factor, the law firm had internally assessed the estate's claims to be worth approximately $47 million so that the contingency fee provision in the revised retainer would have meant a fee of about $19 million. Contrary to the law firm's assertion, on this record it seems highly unlikely that the firm undertook a significant risk of losing a substantial amount of fees as a result of the revised retainer agreement's contingency provision. Rather, the Referee accurately characterized this attempt by the law firm to justify its action as "nothing but a self-serving afterthought."(citations omitted)
The amount the law firm seeks ($44 million) is also disproportionate to the value of the services rendered (approximately $1.7 million) (see Lawrence v Graubard Miller, 11 NY3d at 596). The record shows that the law firm spent a total of 3,795 hours on the litigation after the revised retainer agreement became effective, resulting in an hourly rate of $11,000, which, as the Referee stated, is "an astounding rate of return for legal services."
However, the remedy recommended by the Referee and adopted by the Surrogate — namely, a new "reasonable" fee arrangement for the parties — was improper. Where, as here, there is a preexisting, valid retainer agreement, the proper remedy is to revert to the original agreement. For the reasons found by the Referee, we reject the firm's suggestion that it receive a reduced contingency fee. Accordingly, the matter is remanded for the determination of the fees due the law firm under the original retainer agreement. Given that the firm is entitled to fees under the original retainer agreement, it is also entitled to prejudgment interest from the date of the breach. (citations omitted)
Because the individual defendants acted alone, and in secret from the rest of the law firm, with respect to the gifts, we decline to rule that such conduct by the individual defendants results in the firm's forfeiture of its lawful fees from the date the individual defendants received the gifts.
The Surrogate's Court (opinion linked here) had awarded the law firm fees in the amount of $15,837,374.02 but found that the gifts solicted by the attorneys (concealed from their law firm and the widow's children) emanated an "odor of overreaching too potent to be ignored." (Mike Frisch)
May 24, 2013 in Billable Hours, Clients, Law Firms | Permalink | Comments (0) | TrackBack (0)
Monday, May 6, 2013
Contingent Fee Sharing
In a lawsuit involving a dispute between lawyers over the legal fees in a complex medical malpractice case, the Maryland Court of Special Appeals has held that
...we will apply the general rule that the termination of a contingency fee agreement terminates the fee-sharing agreement predicated on it. Because PGA [the law firm of Orioles owner Peter Angelos] is not entitled to a contingency fee, there is no contingency fee for Mr. Brault to share. Accordingly, to the extent the circuit court factored in the fee-sharing agreement, the circuit court's ruling must be vacated and remanded for further proceedings.
We stress that our decision in this case does not mean that Mr. Brault is not entitled to compensation for his work while the contingency arrangement was in effect. Like PGA, howver, his claim would be for the reasonable value of his services.
The case involved an attorney (Mr. Gately) who while with PGA undertook the representation of the client with assistance from other firm attorneys. Mr. Brault was brought in as co-counsel and a favorable verdict was obtained. The verdict was overturned on appeal.
Mr. Gately was then discharged from PGA. The client followed him and Mr. Brault. The case later settled for an undisclosed amount. PGA sued to enforce its lien. The disputed funds remained in escrow.
Mr. Gately acknowledged that no post-verdict effort had contributed to the settlement, which he attributed to an act of God.
The court here held that PGA had behaved ethically and was not deprived of it entitlement to fees.
The court also held that the discharged attorneys may properly sue successor counsel. (Mike Frisch)
May 6, 2013 in Billable Hours, Law & Business, Law Firms | Permalink | Comments (0) | TrackBack (0)
Tuesday, March 26, 2013
No Fee Decision Affirmed
The New York Court of Appeals has affirmed without discussion a judgment dismissing a claim for legal fees.
ThomsonReuters had this report on the decision of the Appellate Division:
Kasowitz Benson Torres & Friedman is not entitled to a multimillion-dollar fee stemming from its successful representation of drugstore chain Duane Reade, a divided New York state appeals court ruled Tuesday.
Kasowitz had claimed it was owed approximately $7 million for litigation over automated teller machine fees owed to Duane Reade.
In a 3-2 ruling, the Appellate Division, First Department, found that the two parties had negotiated a "precise" fee arrangement via email that did not permit Kasowitz to recover fees beyond a flat $1 million payment.
Alternative fee arrangements, rather than hourly fee structures, have become increasingly common in corporate litigation. But they can also lead to disagreements about interpretation.
The negotiations between Kasowitz and Duane Reade on the fee structure occurred with a simple email exchange, rather than a with formal contract, eventually leading to a dispute over the meaning of the emails.
(Mike Frisch)
March 26, 2013 in Billable Hours | Permalink | Comments (0) | TrackBack (0)
Thursday, February 21, 2013
Client May Discharge Attorney But Contingent Fee Remains Earned
The Rhode Island Supreme Court affirmed the grant of summary judgment to an attorney in a suit for fees against a former client.
The attorney had represented the client in actions against her late father's estate for a 15% contingency fee.
After the claim was reduced to settlement, the attorney collected his fees as payments were recovered. The client later discharged the attorney and claimed no obligation to continue to pay.
The court found that the attorney's rights under the contingent fee agreement had fully vested when the underlying claim was settled. Although the client was free to discharge the attorney, such action "does not alter his entitlement to fees already earned." (Mike Frisch)
February 21, 2013 in Billable Hours, Law & Business, Law Firms | Permalink | Comments (2) | TrackBack (0)
Saturday, February 2, 2013
Fee In Land Not Simple Or Proper
An Alaskan Native corporation entered into a fee agreement with a law firm in connection with litigation over "its certification of and title to certain lands" under the Native Claims Settlement Act.
The contingent fee agreement gave the law firm an interest in the lands at issue.
After the client had prevailed, a bar arbitration panel found that the firm could not take the land, but was entitled to a fee payment equal to the land's value. A 1995 court judgment enforced the arbitration award. The client paid the law firm for several years.
The client eventually was unable to continue the payments and litigation ensued.
The Alaska Supreme Court held that the contingency agreement violated provisions of the Act and that the arbitration award was improper. The court noted tht the case presented "complex" issues as to whether the 1995 judgment was void or voidable.
The court ordered the law firm to return $643,760 in paid fees.
The firm may now establish its entitlement for fees under quantum meruit. (Mike Frisch)
February 2, 2013 in Billable Hours, Clients, Law Firms, The Practice | Permalink | Comments (0) | TrackBack (0)


text: 6/03/13 2/20/12 POPSUGAR Fashion Spring Fashion How to Wear Floral Printed Pants New Style Trend to Try: Floral Pants +Tees February 20, 2012 by Brittney Stephens 102 Shares Chat with us on Facebook Messenger. Learn what's trending across POPSUGAR. View in slideshow You can't really think of Spring without thinking of florals — and in addition to wearing the print on dresses and tops, we're loving the way it looks in a pant too. We saw the look on the Spring runways from designers like Vivienne Tam, Peter Som, Richard Chai Love, and more — and it might just be one of our favorite combinations for the coming season. The look just screams Spring, and although it isn't for the sartorially timid, it's a fun, fresh way to wear prints. If you're feeling fearful about how to pull it off, there are a few tips to keep in mind: The best way to try the look is in a style that you would wear otherwise. If you're a denim enthusiast, there are a ton of floral-print jeans on the market, from Paige Denim, 7 For All Mankind, and Current/Elliott. If you're more of a trouser girl, opt for some of the awesome picks from ASOS and J.Crew. Ease into it by keeping things solid up top. You'll look totally chic (not to mention effortless) if you pair your florals with a solid tee and heels — and go easy on the accessories! Think about your body. If you're petite, you'll want to go with a smaller pattern; if you're tall, you can get away with a bolder, large-scale design. Either way, pick a color combo that can easily blend into your current wardrobe. Click through now to see and shop five Spring-ready ways to try the floral pants and t-shirt trend. Shop Brands Pamela Love · Zoe Karssen · Topshop · Loeffler Randall · Illesteva · Rag and Bone · Carven · Citizens of Humanity · Etoile Isabel Marant · Alexander Wang · Proenza Schouler · Tucker · Marc Jacobs · BaubleBar · Dolce & Gabbana · Christopher Kane · Vince Camuto Image Source: Getty How to Wear Floral Pants Image Source: Getty Floral pants don't have to be all sweetness and frou-frou; you can edge them up with a cheeky tee, printed heels, and a tough-girl spike necklace. Extra points if you throw on a leather jacket. Pamela Love Bronze and Quartz Necklace ($575), Zoe Karssen Boys Tee ($105), Topshop Tropical Slim Trousers ($90), Loeffler Randall Dita Platform Pump ($425) Pamela Love Bronze and quartz necklace $575 from NET-A-PORTER.COM Buy Now See more Pamela Love Necklaces Zoe Karssen Boys cotton and modal-blend oversized T-shirt $105 from NET-A-PORTER.COM Buy Now See more Zoe Karssen Tees Topshop Co-ord Tropical Slim Trousers $90 from Topshop Buy Now See more Topshop Dress Pants Loeffler Randall Dita platform pump $425 from Loeffler Randall Buy Now See more Loeffler Randall Platforms How to Wear Floral Pants Image Source: Getty If denim's your thing, you'll love these pretty, subtle floral jeans — pair them with a bright yellow pocket tee, suede heels, and hipster-cool tortoise shell shades. Dasha for Illesteva Leonard Round-Frame Sunglasses ($295), Rag & Bone The Pocket Tee ($105), Carven Open-Toe Suede Slingbacks ($535), Citizens of Humanity Mandy Printed Jeans ($190) Illesteva Dasha for Leonard round-frame acetate sunglasses $295 from NET-A-PORTER.COM Buy Now See more Illesteva Sunglasses Rag and Bone The Pocket Tee $105 from Rag & Bone Buy Now See more Rag & Bone Tees Carven Open-toe suede slingbacks $595 from NET-A-PORTER.COM Buy Now See more Carven Pumps Citizens of Humanity Mandy printed high-waisted straight-leg jeans $190 from NET-A-PORTER.COM Buy Now See more Citizens of Humanity Straight Denim How to Wear Floral Pants Image Source: Getty Floral pants can easily be worn out at night, as long as you dress them up with the right accoutrements — mix things up with a striped tee, then add a sleek leather clutch and ankle-strap heels. APC Fancy Mariniere Tee ($165), Étoile Isabel Marant Jerry Floral Pant ($415), Alexander Wang Liya Suede Pump ($485), Proenza Schouler Evening Clutch ($1,175) La Garçonne Longsleeve Tops A.P.C. / Fancy Mariniere Tee $165 from La Garçonne Buy Now See more La Garçonne Longsleeve Tops Etoile Isabel Marant Jerry Floral Pant $415 from La Garçonne Buy Now See more Etoile Isabel Marant Casual Pants Alexander Wang Liya Suede Pump $485 from OTTE Buy Now See more Alexander Wang Pumps Proenza Schouler Evening Clutch In Black $1175 from Zoe Buy Now See more Proenza Schouler Clutches How to Wear Floral Pants Image Source: Getty Shake up your workwear rut with a pair of cheery floral trousers. Keep things streamlined and office-appropriate with a black blazer, leather pumps, and a chic statement necklace. BaubleBar Deco Noir Necklace ($42), Dolce & Gabbana Floral-Print Pants ($675), Christopher Kane Neon Jersey T-Shirt ($190), Vince Camuto Heath Pump ($98), Karl James Satin Twill-Trimmed Crepe Blazer ($310) BaubleBar Deco Noir Necklace $38 from BaubleBar Buy Now See more BaubleBar Necklaces Dolce & Gabbana Floral-print stretch cotton-poplin pants $675 from NET-A-PORTER.COM Buy Now See more Dolce & Gabbana Casual Pants Christopher Kane Neon jersey T-shirt $190 from NET-A-PORTER.COM Buy Now See more Christopher Kane Shortsleeve Tops Vince Camuto Heath Pump $98 from Designs by Stephene Buy Now See more Vince Camuto Pumps NET-A-PORTER.COM Blazers Karl James satin twill-trimmed crepe blazer $310 from NET-A-PORTER.COM Buy Now See more NET-A-PORTER.COM Blazers How to Wear Floral Pants Image Source: Getty Hooray, it's the weekend! Flex your chic brunching and shopping muscles in a slouchy pair of pants and short-sleeved knit tee. Play it cool and casual with a pair of lace-up sandals, stud earrings, and a pretty crossbody bag. Topshop Chunky Stitch Crop Tee ($64), Tucker Printed Silk Pants ($320), Marc Jacobs Tie-Up Leather Sandals ($645), R.B. of McD #5 Shoulder Bag ($480), Topshop Double Arrow Studs ($12) Topshop Knitted Chunky Stitch Crop Tee $64 from Topshop Buy Now See more Topshop Tees Tucker Floral-print silk tapered pants $320 from NET-A-PORTER.COM Buy Now See more Tucker Pants Marc Jacobs Tie-up leather flower sandals $645 from NET-A-PORTER.COM Buy Now See more Marc Jacobs Sandals R.B. of McD #5 Shoulder Bag $480 from rbofmcd.com Buy Now Topshop Double Arrow Studs $12 from Topshop Buy Now See more Topshop Earrings Floral PantsHow To WearSpring FashionPantsTrendsShoppingTopshopLoeffler Randall

subset: commoncrawl


text:
Dress features a fitted bodice with double French darts in front and vertical waistline darts in back, V-neckline with wing revers collar, and your choice of short set-in sleeves with notched cuffs or long sleeves gathered to buttoned bands. Optionally add self-fabric tie that is stitched to bodice under collar and tied in a bow. Dress has a beautiful 4-gore flared tea-length skirt with option to add angled mock pocket flaps. Dress has side zipper closing and self-fabric belt.
Links to reviews/blog postsEdit
Add a photo to the gallery by clicking the "modify" button below.
[insert your username, and make sure your preferences allow for people to contact you via e-mail. Do not list your email address here!]


text:
The structure of subjective well-being in nine western societies
- Citations
- 93 Downloads
The structure of subjective well-being is analyzed by multidimensional mapping of evaluations of life concerns. For example, one finds that evaluations of Income are close to (i.e., relatively strongly related to) evaluations of Standard of living, but remote from (weakly related to) evaluations of Health. These structures show how evaluations of life components fit together and hence illuminate the psychological meaning of life quality. They can be useful for determining the breadth of coverage and degree of redundancy of social indicators of perceived well-being. Analyzed here are data from representative sample surveys in Belgium, Denmark, France, Germany, Great Britain, Ireland, Italy, Netherlands, and the United States (each N≈1000). Eleven life concerns are considered, including Income, Housing, Job, Health, Leisure, Neighborhood, Transportation, and Relations with other people. It is found that structures in all of these countries have a basic similarity and that the European countries tend to be more similar to one another than they are to USA. These results suggest that comparative research on subjective well-being is feasible within this group of nations.
Unable to display preview. Download preview PDF.


text:
Arts & Fitnesson the Pier
© Richard TrentRhonda Carol, Founder-Director
"Every block of stone has a statue inside it, and it is the task of the sculptor to discover it." - Michelangelo
Contact Us
Use the form to send us an email
Address:Calliope Arts and Fitness20 Lumber Road Suite B-1Roslyn, NY 11576
Directions:- EAST exit 36 (Searingtown Rd.) North to Northern BoulevardEast (right) on Northern to fork, bear right onto Old Northern Boulevard (before viaduct) and continue to end bear right into Town of Roslyn, left at Clock Tower, left on Lumber Rd.
- WEST exit 39 (Glen Cove Road) North to Northern Boulevard West (left) on Northern, turn right just before viaduct into the Town of Roslyn left on Bryant, right onto Old Northern Boulevard, right on Lumber Rd.


text:
It really is not uncommon for moms to deal with constipation after birth. Constipation is just par for the course for most postpartum mothers during recovery. For some, they may be surprised to be dealing with constipation after a pregnancy where it had not been an issue. For others, constipation is nothing new.

What Can Cause Constipation After Birth:

This normal, yet annoying, discomfort can be caused by one of the several factors relating to what was happening to your body before, during, and/or after delivery. Consider if any of these descriptions might fit what you experienced during delivery. The first 2 points have to do with the fact that your tummy was basically empty, the final 3 are a reflection of medical procedures you may have experienced.

I had a long labor with little food. (See: Can I Eat During Labor?)

I had a bowel movement or enema during labor.

I had a c-section. (It can take up to 3-4 days for your digestive system to start working normally following this major surgery.)

I used pain relievers during delivery, or I am using them currently for postpartum pain relief. (Particularly systemic narcotics can slow down the digestive tract).

I have a sore perineum possibly caused by my episiotomy or by postpartum hemorrhoids. (In this case, most likely the constipation is not so much a physical problem as a mental one. You may fear tearing your stitches or fear more pain. That fear is causing you to retain your stool.)

How Long Might Constipation Last:

Depending on the root cause of your constipation and the steps you take to treat it, it is very likely that it will resolve within a few days of giving birth. The important thing is to be proactive in treating constipation and follow the steps below.

How Can Postpartum Constipation Be Treated:

In most cases, you can treat your constipation at home with successful results. Here are some simple tips you should follow to both treat and prevent constipation.

Eat well. High fiber foods can be your best defense. Foods such as whole grain cereals and whole grain breads, brown rice, beans, and fresh fruits and veggies are excellent fiber-rich foods.

Drink plenty of water, about 6-8 glasses a day. The fibery foods that you eat will absorb the water you drink, making your stools softer. (See also: Does Drinking Water Increase Breast Milk Supply?)

If you have the urge to go, don't ignore it. As much as you may be fearing more pain, holding on to a bowel movement will only make the stool harder. Go when you sense you need to.

Take a stroll. This may seem intimidating, particularly if you are recovering from a c-section, but a little bit of exercise (even at a slow pace), can help loosen your bowels.

Ask your caregiver if you should be taking a stool softener. If you've had a severe tear (third or fourth degree), in all likelihood you already started taking one. You may also need a softener if you are dealing with hemorrhoids, are taking iron supplements for anemia, or are on narcotics for pain relief.

What About Hemorrhoids:

Often times constipation and hemorrhoids go hand-in-hand. If you are straining to pass a movement or if your stool is hard, it will likely worsen your hemorrhoids. Though hemorrhoids generally aren't severe, they are certainly not a pleasure cruise. Treating hemorrhoids and following the above advice should clear things up for you within a week or two following the birth of your baby.

When Should I Call a Doctor:

In some cases, though not often, constipation is actually a symptom of a bigger problem. If your constipation persists or if you experience any of the additional symptoms below, contact your doctor or midwife immediately.

You are having severe stomach pain.

You are experiencing periods of both constipation and diarrhea.

You are passing mucous or blood in your stool.

You consider the rectal pain to be severe.

You have a troubling amount of rectal bleeding.


text:
No public recommendations added yet.
Angoora Silk Mills
Address: 147/149, 53, Gaiwadi Sadan, Dr.vegas Street, Chira Bazar, Mumbai, Maharashtra, 400002
Phone number: 022 - 22004655 , 22085812Post A Recommendation Bookmark this Business Claim this Business
how to find Angoora Silk MillsClick To View Location
Vote For Angoora Silk Mills
The voting system is a way for customers of Angoora Silk Mills to change its popularity at Start Local. You may vote for or against Angoora Silk Mills and your vote will affect its score on Start Local.
If you vote positively for the business you may also choose to leave a public recommendation to tell other people about your great experience with the business.
Note: A negative vote will count against this business's score but will not be displayed publicly. Read here for more info on voting.
Have you already registered with us?
We just need to know if you've already registered with Start Local? If so you should have already selected a password and validated your email address. If not, don't worry it's easy and will take less than 40 seconds.


text:
Olive Garden Map
200 N. Galleria Dr.
845-692-8232 | Make Restaurant Reservations | Menu
Now that you know where you want to enjoy a meal, it's time to find the restaurant. Print out this Olive Garden map and take the driving directions with you so you can locate the restaurant easily.
Find out which restaurants and chefs top the list of GAYOT's 2016 Annual Restaurant Awards.


text:
Galvan Named Big 12 Runner of the Week
Galvan Named Big 12 Runner of the Week
Sept. 10, 2013
MANHATTAN, Kan. - Kansas State junior Laura Galvan was named Big 12 Runner of the Week for her performance at the J.K. Gold Classic this past Saturday. Galvan in her first race of the season won the J.K. Gold Classic (4K/6K) with a time of 13:49.72.
Galvan was excited to win her first career Big 12 Runner of the Week award.
"It felt good to win but the most exciting thing was that we won as a team." Galvan said. "My happiness was for everyone and it was pretty cool. I am excited and motivated to continue to do well and I look forward to the next competition."
Head Coach Michael Smith was proud and confident with how Galvan performed on Saturday.
"Laura is very talented and she worked very hard this summer to prepare for the cross country season so it is not a surprise to me that she won our first meet." Smith said. "I know that she has very high expectations for herself and this team, so a win to start the season is a great reward for all of the summer work and is only going to fuel her desire for more.
This is the second consecutive year that a Wildcat runner has been named Big 12 Runner of the Week after winning the J.K. Gold Classic. Junior Fernando Roman won the award after placing first at last year's J.K. Gold Classic with a time of 18:37.09.
K-State will have a week off then will continue action Sept. 21 as they travel to Lincoln, Neb., for the Woody Greeno Invitational.


text:
Given out for three months
Manchester City goalkeeper Shay Given has been ruled out for three months due to a shoulder injury.
Last Updated: 23/02/11 5:59pm
Manchester City goalkeeper Shay Given has been ruled out for three months due to a shoulder injury.
Given picked up the problem in the warm-up before City's Europa League draw with Aris Salonika in Greece last week.
He was not on the bench for the FA Cup success over Notts County at the weekend and visited a specialist in London earlier this week.
The Republic of Ireland international has dislocated his shoulder in the past and is unlikely to be available for City for the rest of the season.
City boss Roberto Mancini said: "Shay has this problem in his shoulder and I think he needs three months to recover.
"He has the same injury that he had last year and I think that he needs an operation.
"I am disappointed for him because we have lost a good goalkeeper.
"Last year we had the problem in the last three games because we lost him to injury and I hope this year it is not the same."
The 34-year-old has made just four appearances this term after losing the No.1 spot to Joe Hart and has not played in the Premier League since April last year.
Given had been keen to go out on loan in the January transfer window and reports have claimed the injury could mean the former Newcastle United stalwart has played his last game for City.


text:
Nbarrett Photography // Keri Overman and Brandon Gartley's Industrial Romantic DFW Wedding by Grit + Gold SWEET BEGINNINGS: Keri and Brandon met in high school, but it wasn't until later in life when they reconnected via social media and began their relationship. INDUSTRIAL ROMANTIC: Keri and Brandon used a color palette of white, cream, rose, blush and heavy greenery to
Posts List
Photos by Elisabeth Carol Photography Ashley and hubby Coleman's charming Southern wedding was simply timeless. Ashley was inspired by her love for neutral colors and natural elements combined, and with the help of DFW wedding planner Chic Fleur Weddings and Events created the simple and classic Southern wedding she always wanted. Something Pretty Floral crafted the gorgeous florals consisting of
The Tarnos // Raelynn Goodman and Carlos Mendez's Rustic Elegant DFW Wedding SWEET BEGINNINGS: Raelynn and Carlos met in 2013 during their time in college. Surprisingly, he helped one of his best friends ask her on a date! They remained friends, and later, Carlos asked her on his own date (to a wedding)! PERFECT PROPOSAL: Raelynn had planned a surprise
Elisabeth Carol Photography // Ashley Dahlen and Coleman Ord's Classic Southern Wedding by Chic Fleur Weddings and Events SWEET BEGINNINGS: Ashley and Coleman met while they were students at Texas A&M University. They both attended Chilifest one year, a country concert right outside of College Station, and found each other in the crowd of 50,000 people. Ashley and her friends
Tracy Autem Photography // Allie Smith and Kane Elenburg's Fort Worth Wedding Captured by Tracy Autem Photography Allie and Kane Elenburg's love story began in true Texan fashion: at a football game. Allie was just 4 years old. Kane was 6. The couple grew up as neighbors and family friends in Jacksboro, living across the highway from each other. Each
Lauren Peele Photography // Courtney McMahon and Parker Ryan's North Texas Wedding Featuring Query Events PERFECT PROPOSAL: Courtney and Parker went on a trip to Winter Park Colorado, and to her surprise, he had a stunning proposal planned. While Parker is a natural at snowboarding, Courtney needed some lessons. After her ski lesson, sore and tired, Courtney made a phone
Tracy Autem Photography // Caroline Schrader and Taylor Spalla's Classic Fort Worth Wedding by Tami Winn Events SWEET BEGINNINGS: In 2013, Caroline moved to Midland, Texas, for her third year of medical school, and Taylor had also just moved to Midland for his first job after graduating from law school. A mutual friend arranged a group get together since they
Welcome to the Beauty Booth! Our fabulous wedding hair and makeup professionals of North Texas created the best wedding day looks for you and your bridesmaids. From old Hollywood glam to natural beauty, they have all the best looks covered. We can't brag about these creatives enough, but let's let their work speak for itself. Scroll down to take a peek
Tracy Enoch Photography // SWEET BEGINNINGS: Deidre and Stefan were unacquainted until her twin sister started dating one of Stefan's friends. The two started following each other on social media and soon after, they began frequently texting one another. Eventually, they discovered there was something more and began dating. PERFECT PROPOSAL: Stefan wanted to surprise Deidre, so he planned an
Photos by Jessica Gold Photography Anna and Jeffrey's gorgeous North Texas wedding was the perfect blend of classic and natural, and we adore each and every detail! DFW wedding planner Jen Rios helped the couple create the perfect celebration filled with organic neutrals and fresh blooms. Anna looked absolutely lovely in her intricate bridal gown from Pence & Panache, and Jar


text:
How to use Facebook to improve your SEO ?
In this fast paced online business, the success highly depends over SEO and the SEO strategy is highly concerned on being found in local search results.While preparing a perfect and suitable SEO strategy a marketer essentially incorporates the social media facts as the top focus point.
When people search any information about your brand on Google, the first results that come on the screen are usually from your website, Google+ and YouTube pages.But if you have done a good SEO practice, you can easily observe that many Facebook Pages are also being shown in those results.
Though many people do not think their Facebook page as a website still, they are probably using it like this.Facebook page oriented SEO is a rather new thing and Google also indexes the social media networks.
Also, Read Methods to see who viewed your facebook profile
The importance of Facebook-oriented SEO can be understood by the given points and what efforts can be done to leverage Facebook to improve your rankings.
- Google indexes your social media pages: When we search for a product, brand or company on Google, we find that their social media pages are also visible among the top results.The Facebook, twitter or any other pages are included in this list.Google search spiders keenly pay attention to the keywords that you include in your Facebook profile URLS and page description.Also, the information that you provide to your blogs, articles and images are observed as the rank determining parameters.
A tip to help: While developing your Facebook page, you contain the accurate information about you and your business.It should include:
- The name of company in its correct form
- Physical address
- Website address
Here, you also have to make sure that your business is categorized correctly (in case you have to choose a category while setting up or creating your page) and the business description describes the main products and services provided by you.To increase visibility, you should fill out all the other available fields, such as company logo, link to videos or business hours.
- More Facebook shares will lead to higher rankings: It has been proven by the recent internet practice during these couple of years that social media activities and search engine rankings are interrelated.If your content is relevant and valuable, more and more users will attract towards it and share it with others and this practice will be certainly observed by Google.When Google finds that your post is being linked and shared with a great frequency, it will rank your content a higher place as it is considered the content with the great value and importance to the audiences.
A tip to help: To earn the attention as well as the improved ranking you need to work hard for creating valuable, relevant and interesting content that your audiences and the customers will love to share with their friends and other links. Also, make it easy for them to share the information on your networks and develop the supports on your web pages.
Don't focus on the quantity of the audiences, but the quality of the audiences.Your thousands of followers that are not interested in your posts are less valuable than the hundreds interested and serious ones.A marketer should pay extreme attention to building a community of quality audiences that will watch out the pages with attention and enthusiastically share the content.
- SEO and social media go hand in hand: Since, social media has become the undeniable part of our day to day life, it is being assumed slightly that social media is becoming the new SEO.Actually, Facebook and other social media platforms are the important SEO tools that are used by the businesses for increasing visibility on the internet.
Now, it is time to find out that what the SEO principles that should be followed are and what tactics can be applied in the Facebook strategy that will result in an improved position among the search results.
Let's find out the methods by which you can optimize your Facebook page for SEO
- Set your page according to your best benefit: Facebook is loaded with the surprisingly easy overlook features.While you can mention a long name in your URL, it will be nice to choose a memorable and easy to spell keyword related profile name.But it should be highly relevant to your brand, product or company; nothing else.The clear URL optimization gives the message to the readers and the search engines that what is your Facebook exactly about.If you have to categories your company, pay a great attention to the available categories and subcategories.It helps in better discoverability and increased the credibility of your business.
- Never underestimate your about section: The about section associated with the page must be filled entirely.The section offers a great opportunity for Search Engine optimization and needs to be approached strategically.Here, you can add the important and interesting information about your company and products.But be careful and avoid overloading this section with the irrelevant keywords and repeated phrases.If you are operating or running a local level business, it is mostly important that you have mentioned your correct physical address.It will be covered by both the Google search results and Facebook graph search results.
- Develop quality content: The quality of content helps you in each level of content marketing, but in the relation of SEO, it obviously holds massive potential to earn strong rankings.The content with remarkable credibility and relevancy, attracts a large number of audiences and potential customers also, influences the ranks among search results.Furthermore, the focus of content creation should be the end reader, not the SEO.It is your dedicated readers' community that can help you in your social media campaign by liking, commenting and sharing.
Must read:
Honest and dishonest facebook techniques
So, these all are best facebook methods by which you can optimize your Facebook page for SEO, if followed in the right way, these facebook techniques will defiantly help you in increasing the visibility of your website and boost your SEO strategy.


text:
Recommendations for overlocker thread, please!(6 Posts)
Pilcrow Fri 08-Nov-13 11:29:14
Rockinhippy Mon 11-Nov-13 00:59:36
Littlebigbum Tue 12-Nov-13 09:41:57
patchworkchick Tue 12-Nov-13 20:23:25
RavenRose Tue 12-Nov-13 22:16:20
RavenRose Tue 12-Nov-13 22:19:55
Join the discussion
Registering is free, easy, and means you can join in the discussion, get discounts, win prizes and lots more.Register now
Already registered with Mumsnet? Log in to leave your comment or alternatively, sign in with Facebook or Google.
Please login first.


text:
- Dispart
- Dispart Dis*part", v. i. To separate, to open; to cleave. [1913 Webster]
The Collaborative International Dictionary of English. 2000.
The Collaborative International Dictionary of English. 2000.
Dispart — Dis*part , v. t. 1. (Gun.) To make allowance for the dispart in (a gun), when taking aim. [1913 Webster] Every gunner, before he shoots, must truly dispart his piece. Lucar. [1913 Webster] 2. (Gun.) To furnish with a dispart sight. [1913 Webster] … The Collaborative International Dictionary of English
Dispart — Dis*part , n. 1. (Gun.) The difference between the thickness of the metal at the mouth and at the breech of a piece of ordnance. [1913 Webster] On account of the dispart, the line of aim or line of metal, which is in a plane passing through the… … The Collaborative International Dictionary of English
Dispart — Dis*part , v. t. [imp. & p. p. {Disparted}; p. pr. & vb. n. {Disparting}.] [Pref. dis + part: cf. OF. despartir.] To part asunder; to divide; to separate; to sever; to rend; to rive or split; as, disparted air; disparted towers. [Archaic] [1913… … The Collaborative International Dictionary of English
dispart — index break (separate), detach, disengage, disjoint, disperse (scatter), dissociate, dissolve ( … Law dictionary
dispart — [dis pärt′] vt., vi. [prob. < It dispartire < L, to divide < dis , apart, from + partire, to part, divide < pars, PART2] Archaic to divide into parts; separate … English World dictionary
dispart — verb Etymology: Italian & Latin; Italian dispartire, from Latin, from dis + partire to divide more at part Date: 1590 archaic separate, divide … New Collegiate Dictionary
dispart — dispartment, n. /dis pahrt /, v.t., v.i. to divide into parts; separate; sunder. [1580 90; appar. < It dispartire < L dispartire to part, separate, divide, equiv. to dis DIS 1 + partire to share out, deriv. of part PART] * * * … Universalium
dispart — verb To part, separate. that same mighty man of God, / That bloud red billowes like a walled front / On either side disparted with his rod [...] … Wiktionary
dispart — v. separate, divide into parts … English contemporary dictionary
dispart — I. v. a. Sunder, disunite, separate, divide, sever, dissever, burst, rend, rive, cleave, split, break asunder. II. v. n. Separate, part … New dictionary of synonyms


text:
Philosophy Lexicon of Arguments
|Meta data
Books on Amazon
|Daisie Radner
Heterophänomenologie: wie wir etwas über die Vögel und die Bienen lernen in
Tie I D. Perler/M. Wild (Hg) Der Geist der Tiere Frankfurt 2005
Perler I 408
Hetero-phanomenology/HP/DennettVsBrentano/VsHusserl: hetero-phenomenology works from the perspective of the 3rd person instead of the first.
RadnerVsDennett: Thesis: hetero-phanomenology can also be operated from the first person perspective.
Hetero-phenomenology/Radner: hetero-phenomenology deals with:
1. How things appear to a subject
2. How is the experience of the subject ("how is it for the subject ...")?
Frank Jackson: treats both as equivalent:
E.g Fred: for him there are two red hues, where all the others only perceive one. How is it for Fred to see Red1 and Red2?
Radner: the question varies between (1) and (2).
In the first sense, Jackson: "How is the new color?"
In the second sense, Jackson: "if we could adapt our physiology to that of Fred, we would finally know."
E.g. M. Tye: instead of saying,
A) The color blind Jones does not know how the different colors look, we can just as well say,
B) He does not know what it is like to have the experiences characteristic of seeing the colors.
Both hang together, but problems are not always the established and reversed equally well in the sense of 1. as of 2.
For example, color researcher Mary/Jackson/Radner: the problem is not how red may look for Mary (probably as for us), but how her experience will be. Will it be a surprise?
Environment/Inner world/Radner: both can be approached from the viewpoint of the 1st and the 3rd person.
This distinction does not correspond to that between car and hetero-phenomenology.
Hetero-Phenomenology: 1., 3. Person/environment/inner world: all combinations of questions are possible.
Environment/hetero-phanomenological: 3rd person: E.g.: "How do things appear to the subject?"
1. Person: E.g. "How would things appear to me if I had a sense device like that of the subject?"
Inner world/hetero-phenomenological: 3rd person: E.g.: "How are the experiences of the subject?"
1. Person: E.g.: "How would my experiences be if I were in the circumstances of the subject and had certain characteristics in common with it?".
Hetero-phenomenology/Radner: E.g. he would like to know how a warning call sounds for another subject, e.g. for birds of prey like hawks or owls, which have a smaller head than us.
How would it be if I had no auricles and the ears were only two inches apart?
Problem: I may be able to imagine other ears on my brain, but not how it would be for me with a cat brain._____________Explanation of symbols: Roman numerals indicate the source, arabic numerals indicate the page number. The corresponding books are indicated on the right hand side. ((s)…): Comment by the sender of the contribution.
Tie I
D. Perler/M. Wild (Hg)
Der Geist der Tiere Frankfurt 2005


text:
Bodyblade® Classic Carrying Bag
The Bodyblade® Classic Carry Bag is must-have for those who love to travel with their Bodyblade, take it to the park for a workout, or want to store it conveniently on a hook or hanger. Designed to fit one Bodyblade Classic, it's made from durable 420D nylon and features the authentic Bodyblade logo. Slip your Bodyblade into the bag, cinch the drawstring closure, sling it over your shoulder, and get in a Bodyblade workout anywhere you go.
- A convenient way to carry or store your Bodyblade; sling it over your shoulder or easily hang it in a closet.
- Holds one Bodyblade Classic.
- Made from durable 420D nylon, with 1" shoulder strap and drawstring closure.
- Features the authentic Bodyblade logo.
- 50" long x 4" wide; will fit one Bodyblade Classic or Bodyblade CxT


text:
Favorite Movies: To Kill A Mockingbird, All The President's Men, Return to Oz, Twister
Favorite Shows: The West Wing, The Office, Bones, anything on HGTV or BBC America, Family Guy, South Park, How I Met Your Mother, AbFab, Parks and Rec
|Gay, Man, Single, 5' 9", Average build
|White, Speaks English and some Spanish, Attended Post grad, Christian (but it's not important)
|Smokes sometimes, Drinks socially, Doesn't do drugs, Omnivore, Virgo
See something interesting in their photo? Just click the message icon to start a conversation about it!
Is this person bothering you? Blocking hides you from them and prevents further messages from being exchanged.
If you're being harassed by this person, please report them. Something went wrong. Please refresh and try again.
Our moderators will look into this shortly. Thanks for helping out.
In the mean time, why don't you check out some other matches? Go to matches
And guess what else? You're currently eligible to be a flag moderator. Help OkCupid out by voting on flags set by other people. Check out flagmod
How does this violate our Photo Rules?
You must be in the photo! Full nudity, extreme close ups, pets, cars, baby photos, artwork, images you've added yourself to, etc. are not allowed.
Thanks! We'll look into the issue soon.
Flagging inappropriate content keeps OkCupid awesome. You're now eligible to be a flag moderator!
Restore your account to continue meeting new people.
We'll email you a link to reset it.
An email is on its way to .
If you don't see it, try checking your Spam folder.
You need to complete your basic info on the mobile app before you can use the desktop site.


text:
Regia 4-ply Design Line by Kaffe Fassett - International reknowned textile and knitwear artist Kaffe Fassett has created this exclusive addition to the Regia 4-ply sock yarn range. Featuring colors that are pure Kaffe Fassett, this yarn will create wonderful socks with a creative touch. Regia yarn is noted for its durability and shape rentention. Machine washable up to 100° F (40° C) and can be tumble dried. Will not felt and comes with a 10-year Regia guarantee. 100g skeins
More about the yarn »


text:
SoBe Hostel offers 38 cool, cozy, and super clean air-conditioned rooms.
Dorm rooms are available with 4 to 8 beds and private rooms can cater from 1 to 8 people.
We offer Mixed and Female only dorm rooms of 4, 6, 8, & 12 people.
Your room at the SoBe Hostel includes:
- Free Dinner
- Free continental breakfast (*)
- Free Linens & Towels
- Free Wi-Fi access in Lobby Area
- Free transportation from the airport (**)
- Free Iron & Ironing Board
- Free Hair Dryer
- Free Lockers in every room
- Daily housekeeping
- Security key card to all areas
- Extra luggage space available at the front desk
- Specials at the Sobe Hostel Bar
- Access to all Hostel Amenities & Services
(*) Breakfast consists of a combination of waffles, freshly baked breads, cereal, fresh fruits, coffee, and juice.
(**) Miami International Airport, twice daily. Subject to cancellation without notice.
All our guests have access to our Hostel Amenities & Services
SoBe Hostel offers an unbeatable mix of value for money, comfort, security and fun. Plus our friendly staff will always try to accommodate your requests to make the most enjoyable stay.
Hostel Amenities
- Lobby & Lounge Area
- 24 hours Front Desk
- The Sobe Hostel BAR
- Internet Café
- Self-Catering Kitchen
- Full Laundry Room
- Sidewalk Terrace
- Beer Pong Table
Hostel Services
- Free Dinner
- Organized night-outs to the best Clubs
- Free Breakfast
- Daily housekeeping
- 24 hours Front Desk
- Free lockers inside of the room
- luggage storage in the lobby (extra fees may apply)
- Free transportation from the Airport
- Full Liquor Bar
- Happy Hour daily 5 PM to 7 PM & 12 AM to 2 AM.
- Special Events organized for guests
- Tour Desk
- Security Cameras
- Security Key Card for Room
- Security Key Card for Bathroom
- Parking Passes for Rent (charges apply)
- Bicycle Rental (charges apply)
- Bar Specials at The Sobe Hostel Bar
Services can be changed without notice, for more info: email@example.com


text:
No public recommendations added yet.
Badwe Rohini S
Address: Jay Smruti, Aarey Road, Goregaon(w), Mumbai, Maharashtra, 400062
Phone number: 022 - 28746648Post A Recommendation Bookmark this Business Claim this Business
how to find Badwe Rohini SClick To View Location
Vote For Badwe Rohini S
The voting system is a way for customers of Badwe Rohini S to change its popularity at Start Local. You may vote for or against Badwe Rohini S and your vote will affect its score on Start Local.
If you vote positively for the business you may also choose to leave a public recommendation to tell other people about your great experience with the business.
Note: A negative vote will count against this business's score but will not be displayed publicly. Read here for more info on voting.
Have you already registered with us?
We just need to know if you've already registered with Start Local? If so you should have already selected a password and validated your email address. If not, don't worry it's easy and will take less than 40 seconds.


text:
I was on passing through business trip. Hotel is perfect and if you like casino even more. Only lift in back corner seems little awkward. Rooms are large and comfortable. Good for passing thru. Only bathroom color seems outdates
Getting you more information on this room
Getting you more information on this room
"Worth paying the small amount to upgrade to room with terrace. Had our breakfast on it ! Was great."


text:
Cowboys RB DeMarco Murray (illness) misses practice
Dallas Cowboys coach Jason Garrett said running back DeMarco Murray missed practice on Thursday because of an illness.
Murray played in last Sunday's win over the Indianapolis Colts despite undergoing hand surgery last week. He participated in practice on Wednesday.
"He is not here today," Garrett said Thursday, according to dallascowboys.com. "He was here earlier. He is sick so we sent him home."
Over 15 games this season, Murray has recorded a league-leading 1,745 rushing yards and 12 touchdowns.
The Cowboys (11-4) have already clinched the NFC East. They face the Redskins in Washington on Sunday.
• Robert Griffin III dealing with shoulder sprain


text:
|Message view
|« Date » · « Thread »
|« Date » · « Thread »
|Kevin Sutter <kwsut...@gmail.com>
|Re: to java 8?
|Mon, 21 Apr 2014 18:45:33 GMT
Hi Romain, Thanks for your help on the Java 8 issues! My initial view of the patches looks good. I'm still doing some verifying and testing, but things are looking better. If things continue to check out, I'll post directly to the JIRAs and attempt to get them integrated soon. As far as a new release is concerned... We still seem to have some outstanding issues related to the last release we did... We found a couple of missing items by accident and then someone called us on it: https://issues.apache.org/jira/browse/OPENJPA-2480 I haven't found the time to figure out what's left on that release. So, until we get those items resolved, we can't even think about another release... Thanks again. On Sat, Apr 19, 2014 at 12:26 PM, Romain Manni-Bucau <firstname.lastname@example.com>wrote: > Hi guys, > > worked a bit on java 8 support today > (https://issues.apache.org/jira/browse/OPENJPA-2386 and subtasks in > particular) > > seems i have something working in java 8 (I don't say java 8 features > are fully supported but we don't have regressions and runtime is fine > while you don't go in java 8 new APIs). > > Anyone would be available to review and if it is fine push a release > (2.4.0 or 2.4.0-RC if we are not confident enough)? > > As a side note on tomee side we are waiting for it to start the > release process of the 1.7.0 (openwebbeans will be here surely next > week so we'll are only blocked by openjpa). > > > Romain Manni-Bucau > Twitter: @rmannibucau > Blog: http://rmannibucau.wordpress.com/ > LinkedIn: http://fr.linkedin.com/in/rmannibucau > Github: https://github.com/rmannibucau >
|View raw message


text:
Art Direction / Print
The stigma that's put on employees with disabilities in the workplace can feel insurmountable. They feel stuck with a label that's almost impossible to remove. Something that just needs simple assistance can get unfairly elevated to something that's impossible to ignore.
This disruptive campaign was centered around the common misconception that people working with disabilities are less productive, slow, and more costly than those without. Targeting HR managers, we were able to bring awareness of these misconceptions to the forefront and ensure that with the right carrier, these unfair impressions can be erased.
Tami Severinsen, Art DirectorMike Fredrick, CopywriterCurtis Smith, Creative DirectorAgency: Bader Rutter


text:
Amalric II was King of Spain and nominal Western Roman Emperor from 745 to 759. He became the heir after his brother, Theoderic III , predeceased their father, Tulga II , and was elected king and emperor shortly afterwards. Amalric oversaw the continuing separation of the four West Roman realms and consolidated his Spanish kingdom as an effectively independent state, but was still recognized as first among equals by his cousins in Italy, Africa and Burgundy.
Amalric died in 759 and was briefly succeeded by his son, Alaric .


text:
Sydney producer ROOF brings the HUMP DAY tunes with his latest live mix
Tag Archives: Cosmic Kids
Discover a world of intense disco grooves.
Our favourite cow-belling dance-rockers The Rapture are releasing a remix EP for 'Sail Away' – the opening track to their latest, critically-acclaimed record, In The Grace Of Your Love.
The Rapture are set to release second single 'Sail Away' this week from their critically acclaimed record, In The Grace Of Your Love. It will be accompanied by its own music video – their first official music video produced since 2006. The single has also received the remix treatment from Australia's own Cut Copy, Belgium producer Aeroplane and […]


text:
The January 21st Women's March on Washington, D.C. brought hundreds of thousands of people to the nation's capital to send a clear message to the new administration: The clock will not be turned back on the struggle for equality, human rights and social justice.
The D.C. event sparked similar marches and protests around the world on that day in defiance of the anti-worker, anti-women and anti-immigrant policies that emanate from the Trump administration and its extreme right-wing cabinet picks. In fact, According to USA Today, 2.5 million people participated in the 670 marches that took place around the world.
We've assembled here over 40 photos of some of those protests seen around the world that day. (Thanks in advance to the various photographers and news organizations that posted these pictures on various sites. )
Our motto is Building Democracy Through Research because we believe that community voices should be central in determining what problems are addressed by science and technology and in deciding how benefits of these social practices are used in society. In other words, we believe in Science and Technology for the People! (see history of this movement)
The great strides forward in our understanding and control of the world around us should make life easier, safer, and more acquiescent to our dreams for a better future. The rich and powerful have hijacked most of the potential of our common efforts. This "1%" has taken most of the rewards of the advances in productivity and knowledge and left us with lower wages, more poverty, polluted communities, and increased stress and violence in our lives.
The SCRC collaborates with communities and organizations to take back control of science and technology and to use these tools to improve health, the environment, education, and to advance the interests of communities and working people.
We partner with communities by:
- Developing grants and securing project dollars for community initiated projects,
- Facilitating research partnerships that find solutions to community-defined problems,
- Creating evidence-based programs that directly respond to community concerns,
- Providing skills development in participatory methods, popular education community-led policy making, and popular epidemiology, among others,
- Conducting accessible and timely research for community use,
- Providing strategies, tools, and coaching for community policy change campaigns.
Projects always begin with community collaborations.
We welcome your questions and proposals.