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Bærums Verk, Norway
This former ironworks, located west of Oslo, is now a charming little village that still retains the air from its bygone days. Picturesque cottages that used to house workers now house cafés, galleries, and museums, and the foundry itself poses as...
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Kongens gate 2, 0153 Oslo, Norway
Kunsthåndverkerne i Kongensgate (Artisans of King street) can best be described as an artistically run centre for the showing and selling of different kinds of art - pottery, textiles, metalworks and glass. Founded in 1979, this centre works as a...
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This sculpture and national heritage park was launched to critical acclaim and continues to attract visitors from far and wide. The sculptures are made by artists of a high international standard, such as Renoir, Rodin, Botero, and Dalí, and are...
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Kampen, Oslo, Norway
The area of Kampen in Oslo is where you will find the old wooden houses that you see in photos. The area was originally built as a working class neighborhood and as you walk up and down the streets there are so many different varieties of the...
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1, Bankplassen, 0151 Oslo, Norway
Engebret Café is still as popular as when it opened its doors 157 years ago. Back then, it was known as a second home to some of the nation's most prolific artists, including Henrik Ibsen, Bjørnstjerne Bjørnson, Edvard Munch, Knut Hamsun, and...
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Vulkan 5, 0178 Oslo, Norway
The centerpiece of the city's emerging Vulkan neighborhood, Oslo's very first food hall is a culinary utopia. Let your nose guide you to one (or five!) of 27 eateries peddling everything from cupcakes to tapas to bento boxes. Can't decide? Stop at...
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Pløens Gate 4, 0181 Oslo, Norway
Food lovers must make the trek to this indoor market to enjoy everything from reindeer sausage to sushi paired with local beer.
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Kristian Augusts gate 14, 0164 Oslo, Norway
At Elias, a quaint little eatery located next to the National Gallery (another afar.com highlight), you'll find exciting food at competitive prices. The people at Elias focus on fuss-free food: organic drinks, hand-brewed coffee, Norwegian beers,...
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Get all the information you need about your child's classes
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Open Enrollment for the 2018-2019 School year
As we approach Thanksgiving this year, I want to offer two observations. The first is that there are Jewish connections to the holiday. There is historical evidence that, prior to coming to the New World, the Pilgrims lived among Sephardic Jews in Holland for a brief time. During that period, they would have experienced Sukkot celebrations, which then served as part of the inspiration for Thanksgiving, including eating seasonal foods that would have been harvested, such as apples and squashes. In addition, there are those who say that the cornucopia imagery of Thanksgiving is drawn from the shape of a shofar.
The definition of "serve" is varied. For example, as an intransitive verb (not having a direct object and, yes, I had to look that up), it has seven different meanings, including:
Shalom! I am so happy to be starting my third year serving BJEP as your Director.
As you might expect, the start of school and High Holiday preparations are always daunting for a Jewish professional and no prayer brings that point home more than the Hineni (הִנֵנִי), which reflects on the ability to pray with humility and sincerity, while fearing that one is unworthy of the task. Hineni ִmeans much more than just the perfunctory "here" some of us may remember from attendance in school. Rather, Hineni ִis "I am ready" or "I am prepared" or, more liberally, "I am present and paying close attention to what is being asked of me."
Written by Cantor Jeri Robins
Shavuot is one of my favorite holidays. It is the third of our three festival holidays, so-called because, in Temple times, Jews from all over would travel to Jerusalem to make sacrifices. In fact, in Hebrew, Shavuot, along with Sukkot and Pesach (Passover), are called the Shalosh Regalim ([literally] the three legs or feet), because for each of these three holidays people went walking on a pilgrimage. Just as Passover is associated with freedom and redemption from slavery, Shavuot is associated with receiving the Torah or revelation. To mark the occasion, the Ten Commandments are read on Shavuot. Each of the festivals is also marked by a special reading: on Sukkot, we read from the Book of Ecclesiastes ("for everything there is a season" – as we enter fall and winter); on Pesach, we read from the Song of Songs (love poetry); and, on Shavuot, we read the Book of Ruth.
Cantor Robins shares her thoughts (pdf) with BJEP families on What makes learning possible and How do we build Jewish identity?


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Generic Name: gemcitabine (jem SYE ta been)
Brand Names: Gemzar
Medically reviewed on Jun 5, 2018
What is Gemzar?
Gemzar (gemcitabine) is a cancer medication that interferes with the growth and spread of cancer cells in the body.
Gemzar is used to treat cancers of the pancreas, lung, ovary, and breast.
Gemzar may also be used for purposes not listed in this medication guide.
Important information
Gemzar can lower blood cells that help your body fight infections and help your blood to clot. You may get an infection or bleed more easily. Call your doctor if you have unusual bruising or bleeding, or signs of infection (fever, mouth sores, unusual bruising or bleeding).
Gemzar can affect your liver, kidneys, or lungs. Tell your doctor if you have stomach pain, dark urine, yellow skin or eyes, little or no urinating, swelling, rapid weight gain, severe shortness of breath, wheezing, or cough with foamy mucus.
If you receive gemcitabine during or after radiation treatment, tell your doctor right away if you have severe skin redness, swelling, oozing, or peeling.
Before receiving Gemzar
You should not use Gemzar if you are allergic to gemcitabine.
To make sure Gemzar is safe for you, tell your doctor if you have ever had:
kidney disease;
liver disease (especially cirrhosis);
alcoholism; or
radiation treatment.
Do not use Gemzar if you are pregnant. It may harm the unborn baby. Use effective birth control, and tell your doctor if you become pregnant during treatment.
You should not breast-feed while you are using gemcitabine.
How is Gemzar used?
Gemzar is injected into a vein as an IV infusion. A healthcare provider will give you this injection.
Tell your caregivers if you feel any burning, pain, or swelling around the IV needle when Gemzar is injected.
If any Gemzar injection accidentally gets on your skin, wash the area thoroughly with soap and warm water.
Gemcitabine can increase your risk of bleeding or infection by changing the way your immune system works. You will need frequent medical tests.
What happens if I miss a dose?
Contact your doctor if you miss a miss an appointment to receive your Gemzar infusion.
What happens if I overdose?
Seek emergency medical attention or call the Poison Help line at 1-800-222-1222.
What should I avoid?
Avoid being near people who are sick or have infections. Tell your doctor at once if you develop signs of infection.
Avoid activities that may increase your risk of bleeding or injury. Use extra care to prevent bleeding while shaving or brushing your teeth.
Gemcitabine can pass into body fluids (urine, feces, vomit). For at least 48 hours after you receive a dose, avoid allowing your body fluids to come into contact with your hands or other surfaces. Caregivers should wear rubber gloves while cleaning up a patient's body fluids, handling contaminated trash or laundry or changing diapers. Wash hands before and after removing gloves. Wash soiled clothing and linens separately from other laundry.
Do not receive a "live" vaccine while using Gemzar, and avoid coming into contact with anyone who has recently received a live vaccine. There is a chance that the virus could be passed on to you. Live vaccines include measles, mumps, rubella (MMR), rotavirus, typhoid, yellow fever, varicella (chickenpox), zoster (shingles), and nasal flu (influenza) vaccine.
Gemzar side effects
Get emergency medical help if you have any signs of an allergic reaction to Gemzar: hives; difficult breathing; swelling of your face, lips, tongue, or throat.
If you receive Gemzar during or after radiation treatment, tell your doctor right away if you have severe skin redness, swelling, oozing, or peeling.
A rare but serious side effect of gemcitabine is a cancer medication that interferes with the growth and spread of cancer cells in the body.is called capillary leak syndrome. Call your doctor right away if you have signs of this condition, which may include: stuffy or runny nose followed by weakness or tired feeling, and sudden swelling in your arms, legs and other parts of the body.
Also call your doctor at once if you have:
fever, chills, flu symptoms, easy bruising or bleeding (nosebleeds, bleeding gums);
blisters or ulcers in your mouth, red or swollen gums, trouble eating or swallowing;
severe headache, blurred vision, buzzing in your ears, confusion, seizure (convulsions);
liver problems --nausea, upper stomach pain, itching, tired feeling, loss of appetite, dark urine, clay-colored stools, jaundice (yellowing of the skin or eyes);
signs of damaged red blood cells --bloody diarrhea, stomach pain with vomiting, blood in your urine, pale skin;
signs of a kidney problem --little or no urinating, painful or difficult urination, swelling in your feet or ankles; or
symptoms of a lung problem --sudden chest pain or discomfort, anxiety, sweating, severe shortness of breath, wheezing, gasping for breath, cough with foamy mucus, severe dizziness.
Common Gemzar side effects may include:
nausea, vomiting;
fever, unusual bleeding;
abnormal blood or urine tests;
trouble breathing;
swelling in your hands or feet;
mild rash; or
red or pink urine.
This is not a complete list of side effects and others may occur. Call your doctor for medical advice about side effects. You may report side effects to FDA at 1-800-FDA-1088.
What other drugs will affect Gemzar?
Other drugs may interact with Gemzar, including prescription and over-the-counter medicines, vitamins, and herbal products. Tell each of your health care providers about all medicines you use now and any medicine you start or stop using.
Further information
Remember, keep this and all other medicines out of the reach of children, never share your medicines with others, and use Gemzar only for the indication prescribed.
Always consult your healthcare provider to ensure the information displayed on this page applies to your personal circumstances.
Copyright 1996-2018 Cerner Multum, Inc. Version: 7.01.
More about Gemzar (gemcitabine)
- Gemzar Side Effects
- During Pregnancy
- Dosage Information
- Drug Interactions
- Compare Alternatives
- Support Group
- Pricing & Coupons
- En Español
- 5 Reviews
- Generic Availability
- Drug class: antimetabolites
- FDA Alerts (1)
Consumer resources
Other brands: Infugem


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- North America
- United States
- Kansas
- Landon Creek
- Search
Traveling Luck for Landon Creek Kansas, United States
The timezone in Landon Creek is America/Rankin_Inlet
Morning Sunrise at 07:48 and Evening Sunset at 17:16. It's Dark
Rough GPS position Latitude. 38.7764°, Longitude. -98.8447°
Morning Sunrise at 07:48 and Evening Sunset at 17:16. It's Dark
Rough GPS position Latitude. 38.7764°, Longitude. -98.8447°
Weather near Landon Creek Last report from Russell, Russell Municipal Airport, KS 13.9km awayTemperature: -2°C / 28°F
Wind: 6.9km/h Southwest
Cloud: Sky Clear
Satellite map of Landon Creek and it's surroudings...
Geographic features & Photographs around Landon Creek in Kansas, United States
school building(s) where instruction in one or more branches of knowledge takes place.
- Ell-Saline High School (1.7km)
- Ell-Saline Elementary School (1.7km)
- Grant School (5km)
- Hawley School (5.2km)
- Lincoln School (8.5km)
- Pioneer School (8.5km)
- Three Corners School (9.7km)
- Fossil Creek School (10.9km)
- Trapp School (11.8km)
- Mount Brokaw School (12.3km)
- Bickerdyke Elementary School (15.4km)
- Ruppenthal Junior High School (15.4km)
- Center School (15.9km)
- Russell High School (15.9km)
- Four Corners School (16.4km)
- Simpson Elementary School (16.6km)
oilfield an area containing a subterranean store of petroleum of economic value.
- Strick Oil Field (5.9km)
- Strecker Oil Field (8.2km)
- Hall Gurney Oil Field (10.8km)
- Nuss Oil Field (12.5km)
- Roosevelt Oil Field (13.4km)
- Templing Oil Field (15.3km)
- Boxberger West Oil Field (16.3km)
- Russell Oil Field (17.1km)
- Lang Oil Field (17.4km)
cemetery a burial place or ground.
- Trinity Cemetery (5.4km)
- Michaelis Cemetery (9.2km)
- Cross Plains Cemetery (11.5km)
- Milberger Cemetery (11.7km)
- Schneider Cemetery (12.9km)
- Schoenfeld Cemetery (13.3km)
- Concordia Cemetery (15.9km)
- Blooming Grove Cemetery (16.5km)
administrative division an administrative division of a country, undifferentiated as to administrative level.
- Lincoln, Township of (5.5km)
- Grant, Township of (6.9km)
- Fairfield, Township of (10km)
- Russell, City of (15.2km)
- Winterset, Township of (15.7km)
- Wheatland, Township of (17km)
Accommodation around Landon Creek
FOSSIL CREEK HOTEL AND SUITES 1430 S Fossil St, Russell
SUPER 8 RUSSELL KS RUSSELL KS US 67665-3612, Russell
Days Inn Russell Ks 1225 S Fossil St, Russell
stream a body of running water moving to a lower level in a channel on land.
- Landon Creek (0km)
- Fossil Creek (4.8km)
- Sellens Creek (7.9km)
- Big Creek (8.1km)
- Walker Creek (15km)
- Goose Creek (15.1km)
church a building for public Christian worship.
- Trinity Church (4.4km)
- American Church (11km)
- Shannon Friends Church (11km)
- Immanuel Church (11.7km)
populated place a city, town, village, or other agglomeration of buildings where people live and work.
Local Feature A Nearby feature worthy of being marked on a map..
- Bridge (historical) (1.4km)
- Kennebec (historical) (1.6km)
- Hawley (historical) (5.3km)
tower a high conspicuous structure, typically much higher than its diameter.
- KOOD-TV (Hays) (11.3km)
- KRSL-AM (Russell) (17.7km)
airport a place where aircraft regularly land and take off, with runways, navigational aids, and major facilities for the commercial handling of passengers and cargo.
- Russell Municipal Airport (13.7km)
reservoir(s) an artificial pond or lake.
- Fossil Lake (11.5km)
park an area, often of forested land, maintained as a place of beauty, or for recreation.
- Memorial Park (15.3km)
Wikipedia entries close to Landon Creek
- Russell, Kansas city o city
- Russell County (Kansas) adm2nd adm2nd
- Susank, Kansas city o city
- Bunker Hill, Kansas city o city
- Galatia, Kansas city o city
- Gorham, Kansas city o city
- Dorrance, Kansas city o city
- Barton County (Kansas) adm2nd adm2nd
- Victoria, Kansas city o city
- Hoisington, Kansas city o city
- Olmitz, Kansas city o city
- Otis, Kansas city o city
- Wilson, Kansas city o city
- Hays Regional Airport airport airport
- Paradise, Kansas city o city
- Waldo, Kansas city o city
Airports close to Landon CreekWichita mid continent(ICT), Wichita, Usa (215.9km)
Mc connell afb(IAB), Wichita, Usa (231.3km)


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European Journal of Clinical Pharmacology (2018) 74:1361–1362 https://doi.org/10.1007/s00228-018-2492-7 LETTER TO THE EDITOR The nocebo effect and patient perceptions of biosimilars in inflammatory bowel disease 1 2 3 4 1,4 4 David Pineles & Lisa Malter & Peter S. Liang & Amy Arsuaga & Brian Bosworth & David P. Hudesman & Shannon Chang Received: 29 April 2018 / Accepted: 22 May 2018 / Published online: 31 May 2018 Springer-Verlag GmbH Germany, part of Springer Nature 2018 We read with great interest a recent paper by Boone et al. [1]. penetration into our marketplace has only recently accelerated. In this 1-year observational study, the authors sought to quan- As such, we recently performed a small, prospective study tify the nocebo rate in individuals with an immune-mediated aimed at gauging IBD patients' initial perceptions of inflammatory disease who were switched from the originator biosimilars. In 2017, we surveyed 132 adult patients with infliximab to a biosimilar for a non-medical reason. Patients IBD at two university-affiliated gastroenterology clinics regard- were provided informed consent and voluntarily agreed to ing their current impression of biosimilars. A standardized cov- transition to the infliximab biosimilar. The patients in this er sheet was included with the 14-question survey
European Journal of Clinical Pharmacology – Springer Journals
Published: May 31, 2018
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Category Actor
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en Different Forms of Child Abuse and Maltreatment, Quality of life and General Health in Parents of Abused Children پژوهشي Research
Objective: This study designed to achieve 3 objectives: first, to evaluate different forms of child abuse among junior high school male students in Tehran, Iran second, to study quality of life and general health levels of abusive parents and third, to demonstrate demographic characteristics of abusers.

Methods: Through a multistage cluster sampling a total of 1443 students were selected from 77588 male students. Then, they completed child abuse and trauma scale (CATS) and based on the results, abused students were recognized. In the second step, through a randomized systematic sampling, 38 abused students and 40 nonabused students were selected. Parents of these two groups were assessed and compared by quality of life questionnaire and general health questionnaire (GHQ).

Results: The most important forms of reported abuse included emotional abuse and negative family environment (83.1%), inattentive and neglect (14.2%), and physical abuse (2.65%).

Conclusion: Results showed that abusive parents had lower quality of life compared to their nonabusive counterparts. It seems that child abuse is related to lower quality of life and general health of the parents.
 Child abuse, Type, Quality of life, General health, Demographic characteristics 25 31 http://jpcp.uswr.ac.ir/browse.php?a_code=A-10-1-4&slc_lang=en&sid=1 Parvaneh Mohammadkhani email@example.com 10031947532846002896 10031947532846002896 Yes Department of Clinical Psychology, University of Social Welfare and Rehabilitation Sciences, Tehran, Iran. Ali Delavar 10031947532846002897 10031947532846002897 No Allameh Tabatabaei University Mohammad-Reza Mohammadi 10031947532846002898 10031947532846002898 No Rouzbeh Hospital, Department of Psychiatry, Tehran University of Medical Sciences Marjan Poshtmashhadi 10031947532846002899 10031947532846002899 No University of Social welfare and Rehabilitation sciences


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In this thrilling, climactic chapter of the Planet of the Apes saga, Caesar (Andy Serkis) and his apes are forced into a deadly conflict with an army of humans led by a ruthless Colonel (Woody Harrelson). But after suffering unimaginable losses, Caesar resolves to avenge his kind, pitting him against the Colonel for a final showdown that will determine the future of the planet!
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**All About Caesar
**WETA: Pushing Boundaries
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**Apes: The Meaning of It All
**The Apes Saga: An Homage
**Concept Art Gallery
**Theatrical Trailers


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Former Australian track cyclist Martin Vinnicombe has alleged a current senior member of the Australian cycling community assisted him to inject an illegal substance ahead of a major international race. That name was redacted in his interview with the ABC.
"It was known that you'd have a sudden drop in blood pressure, therefore you needed someone there to assist you," Vinnicombe told the ABC's 7.30 Report. "And at that case - at that time, (name redacted) was a person that I trusted and thought that he would assist me and he did so, he did that."
"He was present in the room and...Yes, he was there with me and made sure that I had done [the injection]."
Vinnicombe also suggests there are "people existing in cycling at the moment in powerful positions that at one point in their careers were exposed to doping and knew about doping methods." The silver medal winner at the 1988 Seoul Olympic Games tested positive for steroids in 1991 and was handed a two-year ban before a court reversed the decision in light of the medical treatment he was receiving at the time.
In his account with the ABC, Vinnicombe admits to injecting substances when often being unaware to the exact contents. He says however, he didn't "think it was water" but the pressure placed on him as a rider made it near impossible to reject.
The now 47-year-old kept a detailed account of his injecting schedule which was, according to the former cyclist, provided to him with instructions on when to take the substances.
"The things that were illegal, we don't even know what they were and we don't even know if they were illegal," he told the ABC.
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"Ya either get out of the kitchen or ya start cookin'. Yeah, that's it," he said.


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Gerald Damian, 17 Aug 2016Please help.. How can I install You Tube on this mobile. . go to store and search you tube there and instal
Just I had updated my wife's lumia 540 to windows 10 last night..
It's great... after, FM is working fine, the pull down screen contains 16 notification widgets and there is an option for selfie on the main camera.. ...
And a lot more.. .
AnonD-574739, 21 Aug 2016Officially there so no "YouTube" app for windows 10. So, you cannot install it. But you can ea... moreThanks
mike, 24 Aug 2016please i am using microsoft 540 but my windows software is 8.1 how can i upgrade it to window... morePlease download update advisor from store and update to windows 10
please i am using microsoft 540 but my windows software is 8.1 how can i upgrade it to windows 10 software
AnonD-574739, 22 Aug 2016Windows 10 Anniversary Edition has given more surprise than I anticipated. 1) The FM player... moreI am using both 535 and 540. I never faced any problem with both. I updated window 10 and both are working smooth. You can download fm radio app from app store. Microsoft has not provided lots of app in your phone bt it has provided all the app in app store so that you can install by your choise.
Dont buy a microsoft is very very poor and performance is very slow.Limited application best app u buy a high cost.Very low storage and battery capacity is normal while charge long duaration....
DONT BUY microsoft ....
very very worst phn .i have ever seen.....
im using lumia 540 around 2 month.....
lots of pblm........
slow apps opening..
FD not supported.
limited apps..
battery is not good..
not perfect in net using..to slow
dont updatet winds 10......
go for android......like xiaomi..samsung...
Windows 10 Anniversary Edition has given more surprise than I anticipated.
1) The FM player has gone from both 535 and 540.
2) Now my camera in 540 is not working properly. Back camera is working sometimes and the front selfie camera has gone. Not able to work to despite hard setting my phone.
Now I am done with WP10, in next few days I am going to buy another samsung Galaxy or may be a Xiaomi device. But never ever a windows phone. MS knows how to f*** off its consumers by giving wild surprise. MY FINAL ADVISE DO NOT BUY A WINDOWS PHONE, GO FOR APPLE OR SAMSUNG OR ANYTHING WHICH IS NOT WINDOWS.
hey friend im planning to upgrade to win10. dont care about the other issue but i dont like the battery drain and lags n also want smoothness like 8.1. please help me i dont want to downgrade to previous one from win10 os. i will be thankful for ur suggetion
i'm not lying trust me that the phone is not worth for price. it have many major problems compare to same price android. when i purchased it i thought it is good as nokia lumia but i was wrong microsoft lets me down. microsot lumia are not that much great as i thought. battery drains quuckly, heats up high, bad performance, cant support fullhd, app gap, bad camera vision at niggt time but good in daylight, etc.
but there are some pros like good scren stylish os and build quality, good camera at day time good ear piece, no lags, etc
if u love windows dont buy this buy . but buy 640 which is good far away than 540.
im not suggesting not to buy this phone cuz you wont love this one sure. i know what it is n cant tell what i felt cu im the one who loves windows phone. im really angry to microsoft for not making good piece for us. i hope nokia will show again with android what it is. then im goona try that surely.
a beautiful hopeless product. the service also at par. this is completely a useless product without any sort of efficiency at all.
Cinera, 07 Aug 2016it is neccessery to up date win 10Yes, updating to windows 10 will make your device faster, better, stable and more reliable. Also unless you update to windows 10 you will lose access to many apps. I just got my 540 and 535 to windows 10 anniversary edition and now my phones are doing great.
nauman, 06 Aug 2016what about the use of 3g in this phone, is it working fast?Yes 3g is very good. I am using it with Vodaphone. In fact I use my 540 as wifi hotspot to access net from my laptop and work online.
sai, 13 Aug 2016i bought my Lumi 540 phone on 10-8-2016 my phone is very heating so pls sollution for this problemFirst got the latest Windows 10 edition upgrade on your device.
Second plug the device to a laptop and scan it with a good antivirus software.
Third check the Memory card and take a back up and than format it using phone and than store the data.
Fourth the device support memory card upto 32 GB, so please do not use bigger memory card than it.
I hope these steps will make your device better.
Gerald Damian, 17 Aug 2016Please help.. How can I install You Tube on this mobile. . Officially there so no "YouTube" app for windows 10. So, you cannot install it. But you can easily access YouTube from "Internet Explorer" (in case your using windows 8.2) or "Edge" (if you are using windows 10).
transpeter97, 18 Aug 2016DO NOT BUY. One of the worst phones out there. It shuts down on me while i just look at normal... moreDid you upgraded to Windows 10? I am using 540 and 535 for last 1 year and did not face any major issues. As for app store, compare to google and apple it has less option. But I found moat of the essential apps for my needs. I think you should update your OS to latest version and scan the device using USB to a laptop.
Got the anniversary windows 10 update on 540 and 535. Working fine. Major change is now you can access the camera from the lock screen which is great as you can now capture a photo fast. Other than that there are minor changes in settings. Also the font is changed and now you can float the keyboard at anywhere on the screen. Anyway now the con is the FM radio 📻 is gone from both my 540 and 535 which is not expected. When I saw that redio tile is not in my home screen, i thought may be deleted. So I go through the entire app menu. Also checked the 535 and never found it. It so sad. When I got windows 10 from windows 8.2; Mix Radio was gone, now the FM Radio is gone. Very very disappointed 😞


text:
Family: Business closures illegal
BATON ROUGE, La. -- Two Zachary residents argue that Louisiana wildlife officials cannot stop them from charging recreational vehicle owners who use their property to access the Comite River.
Richard Shane Rush and Betty Holmes Rush want a federal court to award them damages for loss of dirt sales, timber sales and money they received from recreational vehicle owners.
The Advocate reports (http://bit.ly/1euWIhi) the lawsuit was filed this week in Baton Rouge federal court.
Read more here: http://www.miamiherald.com/2013/11/09/3741967/family-business-closures-illegal.html#storylink=cpy
Read more here: http://www.miamiherald.com/2013/11/09/3741967/family-business-closures-illegal.html#storylink=cpy
* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
Now into court, through undersigned counsel, comes COMITE DIRT PIT, INC.,
which pursuant to FRCP 65 and 42 USC §§ 1983, et seq. for all injuries incurred as a
result of the actions of defendants in deliberate indifference to constitutional rights or
other causes as follows:
The jurisdiction of this Honorable Court is invoked Pursuant to 28 USC § 1331
"Federal Question" and accordingly plaintiff specifically seeks relief pursuant to the 28
USC § 1983 for injuries, damages and other losses as well as supplemental jurisdiction
pursuant to 28 USC § 1367 over all state law claims.
Venue is proper pursuant to 28 USC § 1391 (b)(D(2) in that the Plaintiff and
Defendant reside and are located in East Baton Rouge Parish as is the res at issue and
all acts and the events or omissions giving rise to the claims herein occurred in East Baton
Rouge Parish which is within this judicial district.
COMITE DIRT PIT, INC., is a Louisiana corporation, in good standing and owner
of a certain tract of land adjacent to, along, an/or within that part of the Comite River which
as a non-navigable waterway "in fact" does not fall within the designation as a Natural and
Scenic River pursuant to La. R.S. 56:1847 (8) and which is located in East Baton Rogue
Parish, La, at 9038 Zachary Deerford Road, GPS Coordinates N30 38.533 W91 05.562,
where the property borders the Comite River, on the left descending bank of the Comite
River. [Ex 25]
RICHARD SHANE RUSH is a major who is domiciled on the property owned by
COMITE DIRT and who derives all livelihood from operations and revenues from COMITE
DIRT. SHANE RUSH owns 51% of the stock in COMITE DIRT.
BETTY HOLMES RUSH is a major who is domiciled in the same division as is the
property owned by COMITE DIRT and who derives all livelihood from operations and
revenues from COMITE DIRT. BETTY RUSH owns 49% of the stock in COMITE DIRT.
ROBERT J. BARHAM, is a major, who is employed by the Louisiana Department
of Wildlife & Fisheries in the position as Secretary and who was acting within the course
and scope of his employment during all material times herein and under the color of state
According to the Mortgage and Conveyance Records of the Clerk of Court, in and
for the Parish of East Baton Rouge, COMITE DIRT PIT, INC. is the current "record owner"
of the property described more fully in the deed attached hereto as [Ex 20, 27 and 28], but
generally known in the tax records as Lot R-2-C Richard O. Rush subdivision; Tract R-2-C
Containing 108 acres more or less, resubdivided of Tracts R-1-A Richard O. Rush Property
in Sec. 2, 3, 8 & 10, T5S, R1E. 740-9814 (2-18-86). [Ex 28]
Since 1960, the family, through Blackwater Estates and COMITE DIRT had
uninterrupted ownership of the property, performed farming, sold timber and mined the
property for Dirt since 1983. [Ex 31, 21, 22]
In 2009, Robert J. BARHAM ordered COMITE DIRT through summons not to farm
any timber or dig or perform and actions on a portion of its property on the basis that
COMITE DIRT was on State Property. COMITE DIRT contested on the basis that the
property was private. The prosecution of the matter remains pending. [Ex 23]
In 2011, Robert J. BARHAM arrested the owner and ordered COMITE DIRT not to
farm any dirt on any of its property between the access road and Comite River on the basis
that COMITE DIRT was operating on State Property. [Ex 24]
In 2011, Robert J. BARHAM ordered COMITE DIRT not to farm any timber on its
property on the basis that COMITE DIRT was on State Property. BARHAM claims state
ownership of the river bed on behalf of the state. [Ex 26]
By December 2010, COMITE DIRT had completed a contract for over $809,520.00
for dirt mining. [Ex 37] BARHAM though his continuous interference obstructed COMITE
DIRT from entering other contracts because BARHAM would not allow dirt mining on the
property. This has caused significant economic losses to COMITE DIRT.
During the summer of 2011, COMITE DIRT began a commercial operation of
allowing commercial access by motor vehicles on the property for a profit. This commercial
business including allowing access by ATVs to the Comite River and the dirt mounds
owned by COMITE DIRT for recreational riding. See e.g. [Ex 3A-D]
On October 29, 2013, Mr. Robert J. BARHAM (hereafter BARHAM) caused a
Compliance Order #CO10292013 (hereafter CO) to be served on COMITE DIRT by
certified mail COMITE DIRT, through its registered officer B.J. Rush. The CO ordered
COMITE DIRT owners to stop allowing access by motor vehicles to the Comite River over
its property. [Ex 25]
The CO [Ex 25] provides that Betty Rush has violated the Louisiana Scenic Rivers
(Act La. R.S. 56:1840 et. seq.) [Ex 30] and rules promulgated thereunder by "Allowing
commercial access to a Natural and Scenic River without a permit as required by La.
Administrative Code Title 76:DC.117."
Pursuant to La. R.S. 56:1852 BARHAM has never made any attempt to comply with
the Regulations. [Ex 38: § 111] BARHAM has never held any hearings, provided public
notice or made any determination that the Comite River is covered by the Act. No
management Plan was done by 1991 following the 1988 enactment of the Louisiana
Scenic Rivers Act. [Ex 38]
BARHAM knows he has a duty to create management plan for all rivers included
before the Act, because LWLF has completed only one management plan and that was
recent and for Bayou Manchac. [Ex 1 and 2]
BARHAM has no statutory basis to declare the Comite River a navigable waterway
or to include it in the Scenic Rivers Act absent compliance by LWL&F with the Act.
LDWF has never complied with the Act with regard to the Comite River and
BARHAM knows this.
Additionally, even if BARHAM had complied with the Act, which is denied, the
Louisiana Scenic Rivers Act La. R.S. 56:1852, entitled "privately owned streams; copies
of rules" recognizes the rights of private landholders provides as follows:
A. Recognizing that some few of the streams recommended for inclusion as
natural and scenic rivers may not be state owned but owned by adjacent
landowners, the state legislature encourages riparian owners to grant to the
system administrator scenic servitudes and surface servitutes. [no emphasis
B. Except as provided in R.S. 56:1853 and R.S. 56:1853, no provision of
this Part shall restrict the normal activities of landowners within the
boundaries of their own property unless a mutual agreement has been
entered into with the system administrator. [no emphasis added]
* * * *
COMITE DIRT and its predecessor in title have never granted a servitude to the
State. There is no mutual agreement or attempt by BARHAM to reach same with COMITE
DIRT. All action taken by BARHAM has been through criminal prosecutions.
To the extent that BARHAM may claim he, in good faith relied, upon the
recommendation that the Comite River was a Navigable River issued by the State Land
Office. The State Land Office has issued a disclaimer on any river bed that it has declared
State owned, [Ex 18] that provides as follows:
This information is intended to serve only as an initial reference for research
of water bottom information and does not purport to provide evidence of
legal title to property. This information does not substitute for the need
to conduct complete title analyses and should be viewed merely as a
reference that does not represent a final agency determination or a
judicial determination of ownership, unless otherwise noted. The
information and data on this site are dynamic and will change over time. We
strive, in good faith, to provide current, reliable and accurate information;
however, we fully recognize the possibility of human and/or mechanical error
occurring. We, the Office of State Lands, Division of Administration, State of
Louisiana, its employees, officers and agencies, deny any warranty
(expressed or implied) of accuracy, completeness, reliability or
timeliness of any information published via this site and shall not be
held liable for any losses caused by usage and reliance upon the
accuracy, completeness, reliability or timeliness of such information.
Any person or entity that relies upon such information
obtained from this site does so at his or her own risk.
By proceeding further, the user acknowledges that he/she has read the
foregoing statement and understands that any actions taken by the user
based on the information provided in this website are undertaken at user's
own risk.
Any reliance by BARHAM on the declarations of the State Land Office as to
ownership of Comite River river bed was not reasonable, particularly, where is here,
BARHAM has personal knowledge that the Comite River section owned by COMITE DIRT
is no more than knee deep and nonnavigable in fact.
BARHAM, personally, or through others has been to the property on numerous
occasions and has seen that the water in the Comite River on the COMITE DIRT property
is knee deep at best. [Ex 3 A-D]
COMITE DIRT is able to trace their ownership in the Comite River river bed at issue
back to the Spanish and through the Sovereign. [Ex 31]F
The only economic benefit being derived from the property at this time is the
allowance of commercial recreational vehicles to ride on the property. BARHAM is taking
the last of the economic benefits and this last action constitutes a full and final taking of all
economic benefit with no compensation and without legal right while acting under the color
of state law.
The conduct sought to be restrained is unconstitutional and unlawful.
BARHAM's actions have been callous and indifferent to constitutional rights in that
he has targeted COMITE DIRT under color of state law.
In the absence of a reasonable basis in fact, BARHAM is deriving his purported
jurisdiction over the property by claiming state ownership of the river bed. COMITE DIRT
avers that the river bed is nonnavigable in fact and privately owned and has always been
privately owned.
Nonnavigable river beds are not subject to State ownership. [Exs. 4, 5, 6, 7, 8, 12,
13, 14, 15, 17, 29, 32, 39]
COMITE DIRT is seeking an temporary, preliminary and permanent injunction
against BARHAM from coming on the property and otherwise exercising jurisdiction over
the property and thereby violating constitutional rights.
COMITE DIRT is further claiming damages for the losses of revenues caused by the
actions of BARHAM in violation of constitutional rights.
The CO avers that the activities of COMITE DIRT are in violation of the Louisiana
Scenic Rivers Act in that COMITE DIRT has allowed "commercial access to a Natural and
Scenic River without a permit as required by La. Administrative Code Title 76:IX.117." [Ex
The CO caused COMITE DIRT to lose profits over the weekend from motor vehicle
operations and threatens to close the business now operated by COMITE DIRT.
Actions of BARHAM have deprived COMITE DIRT of all economic value of its
property and has injured the owners of the company and is forcing them into bankruptcy.
COMITE DIRT was ordered to perform as follows:
1. Immediately cease and desist allowing commercial access by motor
vehicles or other wheeled or tracked vehicle into the Comite River, in
a location where it is a designated Natural and Scenic River. [Ex 25]
The order from BARHAM alleges that it was issued under the authority of La. R.S.
56:1851 (B) and threatens civil penalties and criminal fines and imprisonment.
BARHAM posing as Director of the Louisiana Department of WildLife & Fisheries
has violated Plaintiffs' constitutional rights as he has no authority or jurisdiction over the
property at issue, because the property at issue is not on a navigable waterway. The
waterway at issue is non-navigable in fact and not state owned.
At all material times herein, BARHAM was acting under color of state law.
BARHAM had no reasonable basis to believe that he has jurisdiction over the
property. Any reliance on any determination by the Louisiana State Land Office was
BARHAM has allowed and/or failed to interfere with similar business operations on
the Comite River within a mile north of the COMITE RIVER DIRT property. [Ex 19] The
google maps evidence dirt mining on the bank of the Comite on October 29, 2010.
Property that is not navigable in fact is subject to private ownership. [Exs. 4, 5, 6,
7, 8, 12, 13, 14, 15, 17, 29, 32 and 39]
For the State to own the River, it must be navigable in fact and then declared scenic.
BARHAM may have jurisdiction over State owned Rivers, but he does not have jurisdiction
over privately owned waterways. [Exs. 4, 5, 6, 7, 8, 12, 13, 14, 15, 17, 29, 32 and 39]
The waterway at issue is private. The waterway at issue is nonnavigable. The
waterway at issue is owned by COMITE DIRT. [Exs. 9, 10, 11, 16, 31, 33, 35, 36]
La. C.C. art. 450 allows the state to own running waters, the waters and bottoms of
natural navigable water bodies. La. C.C. art 456 allows the State to exercise ownership
over the banks of navigable rivers.
To claim jurisdiction the BARHAM must show that the Comite River traversing the
property at issue is navigable in fact in that it may be used to transport goods in commerce.
No public need may be shown by BARHAM for him to exercise any ownership rights
over COMITE DIRT's property.
The Comite River is not navigable in fact is susceptible to private ownership. [Ex
For BARHAM to legally claim ownership to the bed of the Comite River waterway,
it must be navigable in fact.
The determination of navigability asserted by BARHAM is not a judicial
determination and not reasonably based upon any facts.
As recent as 2011-2012, the United States Army Corp of Engineers federal
designation states the Comite River as a un-navigable waterway in the Louisiana Almanac
2011-2012, Water Resources. See page 327.2. [Ex 16, 33]
There are similar determination made by the United States Army Corp. of Engineers
in 2008 and 2009.
The depth of the Comite River on the COMITE DIRT property and extending nearly
the entire river is virtually knee deep for thirty (30) miles rendering it unnavigable, see (2)
color photos labeled (3 A-D).
Evidence in support of the fact that proves the innavigability of the Comite River, see
photo labeled (3 A-D) showing the unnavigable depth of Comite River area situated south
of the Rush property.
The Louisiana Scenic Rivers Act was formed by the Louisiana Department of
Wildlife and Fisheries (LDWF).
In 1970, the Louisiana Legislature passed Act 398, which declared the Comite River
to be instantaneously scenic. This arbitrary designation ignored the real ownership that
the State passed to private owners with land claims and patents dating back in some cases
before 1812.
BARHAM had no reasonable basis to believe that he has jurisdiction over the
property. Any reliance on any determination by the Louisiana State Land Office without
a factual basis was unreasonable.
Louisiana State Land Office [LSLO] has in the past erroneously declared other
waterways to be navigable so that LDWL could declare them scenic and State owned. For
example, the Tangipahoa River was declared to be navigable. The determination to
navigability permits the inclusion of a stream into Louisiana scenic system which requires
state ownership of the bed of that waterway. The Louisiana Supreme Court found the
Tangipahoa River non-navigable in fact. See Amite Gravel and Sand Co. v. Roseland
Gravel Co., 148 La. 704, 707, 87 So. 718, 719 (1921). [Ex 5]
In Webster Parish, Louisiana, LSLO erroneously declared Bayou Dorcheat
navigable. See MINUTES OF THE REGULAR MEETING WEBSTER PARISH POLICE
JURY, June 1, 2010, where it was admitted to be nonnavigable. [Ex 6]
In yet another example found in a Houma Times news article, the State was
presented with another example of haphazard claims by the state to unnavigable
waterbottoms in Louisiana. See, "State no longer can claim ownership of Bayou Dorcheat".
[Ex 7]
Relevant opinion from a legal review of comparable unnavigable waterways like the
Comite River, stipulates that a waterway is unnavigable in fact which makes it unnavigable
as a matter of law. See, Lawrence E. Donohoe Jr. and Patrick G. Tracy Jr., Phillips
Petroleum Co. v. Mississippi: The Louisiana State Law Institute's Advisory Opinion Relative
to Non-Navigable Water-bottoms, 53 LA. L. REV. (1992). [Ex 8]
Original Surveys from the Louisiana State Land Office show the manner in which
tracts were designed around navigable waterways with tracts fronting on navigable
waterway for means of transportation and water use with the boundaries stopping at the
bank. [Exs 9 and 10] Boundaries of non-navigable waterways pass across the waterway.
In the instance of this waterway, the Original Survey from the Louisiana state Land
Office shows the River included in the entire tract and there is no indication that the river
is not owned by the property owner. [Ex 11]
As shown by Ex 11, from the map from LA Office of State Lands, Sec 10 T5 R1E11,
the Rush property (subdivided to COMITE DIRT) has been in private ownership with a
continuous title to centerline of Comite River beginning in 1960. [Ex 11] The Title includes
the river bed.
Supporting chronological evidence supporting a claim to the Rush property
(subdivided to COMITE DIRT) was acquired through an unbroken chain of title.
a. Benjamin Thompson Allen's first private land certificate receipt number 3668
from the General Land Office of the US dated March 24, 1860. [Ex 31]; and
b. BARHAM is not able to show title in the State.
As a riparian owner, COMITE DIRT, may successfully challenge the LDWF permit
requirement; supporting evidence, see page 47, Legal and Institutional Analysis of
Louisiana's Water Laws with Relationship to the Water Laws of other States and the
Federal Government, April 20, 1983. Volume 1 pages 42-48, 113-115. [Ex 16]
In 1970, mutual agreements where supported in La R.S. 56:1852 by the Louisiana
Legislature, which urged LDWF to obtain scenic and surface servitude with private riparian
owners if the stream was privately owned before the stream was included into the
Louisiana Scenic Rivers system.
BARHAM is unable to show that he had any good faith belief or reasonable basis
to believe that any mutual agreements were pursued by LDWF regarding the Comite River.
Rush (subdivided to COMITE DIRT) private property is situated within the scenic section
of the Comite River.
As a matter of law, BARHAM had no reasonable basis to believe he had jurisdiction
over the COMITE DIRT property. La. R.S. 56:1852, entitled, "Privately owned streams;
copies of rules" provides that "except as provided in R.S. 56:1853 and R.S. 56:1854, no
provision of this Part shall restrict the normal activities of landowners within the boundaries
of their own property unless a mutual agreement has been entered into with the system
a. No Scenic servitude exist; and
b. No Surface servitude exist.
In order to encourage security of title, "the La. L. passed Act of 1912, On the basis
of this statute, it has been held that conveyances which included beds of navigable waters
without reserving title to them in the state are valid and no longer assailable. It is in this
way that Louisiana arrived at private ownership of the bottoms of navigable waters." A. N.
Yiannopoulos, Navigable Waterbottoms, Private Law: Property, 31 LA.L.REV. (1971) [Ex
15 at 196, 197]
The evident fact that BARHAM under color of state law is seeking to unlawfully
claimed ownership of the Comite River created a regulatory takings of nearly 40 acres of
the COMITE DIRT property, which has caused the closure of COMITE DIRT. BARHAM's
unreasonable actions attempting to force COMITE DIRT into complying with his demands
to stop all activities has caused and is causing damages which resulted in a total loss of
value to property from which COMITE DIRT is unable to recover.
The constitutional guarantee of due process of law, found in the Fifth and
Fourteenth Amendments to the U.S. Constitution, prohibits all levels of government from
arbitrarily or unfairly depriving individuals of their basic constitutional rights to life, liberty,
and property.
The due process clause of the Fifth Amendment, asserts that no person shall "be
deprived of life, liberty, or property, without due process of law." This amendment restricts
the powers of the federal government and applies only to actions by it.
The Due Process Clause of the Fourteenth Amendment, declares, "[N]or
shall any State deprive any person of life, liberty, or property, without due process of law".
This clause limits the powers of the states, rather than those of the federal government.
BARHAM is acting under color of state law.
The actions of BARHAM will, if successful, have a direct and substantial adverse
impact on COMITE DIRT's Protected Interests, in violation of Federal constitutional and
statutory protections.
BARHAM is legally responsible for the unconstitutional actions he has taken, which
threaten to severely, directly and unlawfully impact COMITE DIRT's Constitutionally
Protected Interests.
The BARHAM issued CO indicates that BARHAM has engaged in and/or there is
a real and immediate threat that he will engage in actions that seek to invalidate the public
contractual rights and ownership rights from which COMITE DIRT has a Constitutionally
Protected Interests derive, in violation of U.S. Const. Art. I, 10.
Additionally, and/or in the alternative, BARHAM's actions constitute action under
color of state law which constitutes a taking, without due process or just compensation, of
constitutionally protected property rights, in violation of the 5th and 14th Amendments to
the U.S. Constitution and 42 U.S.C. § 1983.
Thus, COMITE DIRT's Constitutionally Protected Interests will be directly and adversely
impacted by BARHAM's attempts to usurp ownership rights and deny COMITE DIRT the
opportunity to use its land in commerce.
COMITE DIRT and Plaintiff are suffering serious and immediate harm. Being
denied all viable economic use of their property had and is forcing them into bankruptcy.
Foreclosure proceedings have been initiated against them.
The Plaintiffs allow the commercial vehicles to traverse their property on the
weekends. If this order is not granted, the Plaintiffs will not be able to earn a living.
Plaintiffs are unable to afford any interruption in their business.
COMITE DIRT seeks injunctive relief to prevent the retroactive impairment of its
contract rights, which derive from the rights of ownership in the property held by COMITE
DIRT and to protect the Plaintiffs from further violation of constitutional rights.
Plaintiff seeks relief pursuant to 42 USC § 1983, et seq.
Under the color of State and local law, COMITE DIRT's Constitutional Rights under
the 14th and 5th Amendments as set forth above have been violated.
Plaintiff seeks relief in the form of damages for all lost profits caused by the violation
of rights and attorneys fees and cost pursuant to 42 USC § 1988 and punitive damages
pursuant to 28 USC § 1983, et seq.


text:
Hilarious husky pops head out of window to reply to a man's howl
A hilarious husky popped his head out of a window to reply to a man's howl in southwestern China. In the clip, filmed in Kunming in the Yunnan Province on March 3, a man mimics the dog's howl towards the opposite building from the window in his apartment. Then, a husky in that building stands up on its two hind legs, puts its front legs on the window sill and pops his head out to howl back at the man.