text:
City Corruption
Grand Jury
GJ Complaint
City Solicitor 2
Exposing the Corruption
Brian Vaeth
Line of Duty
The Fraud
The Aftermath
In the US District Court
US District Court
Notice to Mayor & City Council
Complaint Before City Council
DOJ Letter
Vaeth v Balto. Timeline
US DOJ Complaint 22518
HealthCare Reform
Gov't Reform
No DACA
Public Safety
MD House Bill 971
House Oversight Committee
Oversight Com
Help Me to Understand
Vaeth v City 2018
PTSD Firefighters
US Dist 2018
Latest filing
Obstruction in the City Solicitor's Office
Brian Charles Vaeth
3320 Orlando Avenue
Baltimore, Maryland 21234
[email protected]
and COMP MANAGEMENT INC.,
This complaint represents over a decade of extraordinary efforts to hold accountable for their corrupt practices Baltimore City officials and is focused on a particular species of fraud perpetrated by those officials in an effort to prevent the judicial process from functioning in its usual manner and involved perjury or a nondisclosure so fundamental that it undermined the workings of the adversary process itself. More importantly, this complaint is about far more than an injury to a single litigant. It is about a wrong against the institutions set up to protect and safeguard the public, institutions in which fraud cannot complacently be tolerated consistently with the good order of society. The assessment of this complaint should include the conduct addressed in it that is focused on governmental actors, who are required to operate under a higher standard of care in light of the power they hold in our society. When they fail to do so, it puts everyone at risk. Here, the Baltimore City Solicitor's Office abandoned this fundamental objective and also any effort to observe the constitutional rights of the citizens of Baltimore. Instead, they went all in to win at any cost. The actions of those accused threatens not only the judicial process but also all citizens who are exposed to litigating matters before the court.
Baltimore City firefighters engage in one of the most dangerous and physically taxing professions in this nation, wherein they regularly risk serious physical injury and face life threatening situations in service to the residents who live in, and tourists who visit, the City of Baltimore. The intent is to provide the best service to the public that is possible, to advance the general health and welfare of the City while protecting the public servants who suffer serious injury in furtherance of that intent. The notion that a public servant who risks serious injury while performing their duties can be denied of disability pension benefits after suffering a disabling injury is repugnant and goes against all standards of logical reasoning. Instead, the City of Baltimore has a history of purposely and willfully denying firefighters, whose actions reflect immense credit on the Mayor, the City Council, and the Chief of Fire Department, of their rightful benefits by subjecting them to a process that determines the eligibility of those benefits that is arbitrary and capricious in and of itself.
Brian Charles Vaeth, was a Baltimore City firefighter, eminently qualified by virtue of the many times he was cited for meritorious conduct during his career until an injury caused him to be deemed "medically unable to perform his duties" and that injury occurred in the line of duty. The circumstances surrounding that injury are fully set forth herein along with the details regarding the allegations presented against the officials named in it. From the instant this case began there has been a concerted effort by officials to obfuscate the truth in the matter and forward Baltimore City's unlawful discriminatory scheme unchecked. As the allegations presented have never been fully investigated and no one has been held accountable for their violation of the law, it has empowered those officials to continue with this unlawful behavior. These allegations further victimize the citizens of Baltimore City because the conduct detailed herein has neither been assessed for the trust it naturally places in the City Solicitor, as an officer of the court, nor has anything been done to deter the behavior in the context of that which has been discovered about their actions. The circumstances presented by this complaint alleges pervasive and egregious corruption at the core of the underlying claim, the repeated suppression of key facts by medical and legal representatives for the City of Baltimore that seriously altered the ability to properly adjudicate this claim. Each of these examples has been laminated into an egregious fraud that goes well beyond what is required for the US Department Justice to exercise its inherent powers, so as to effectuate justice and preserve the public's confidence in our judicial system. The conduct constitutes a fraud which defiles the court and was perpetrated by officers of the court, so that the judicial machinery could perform in the usual manner its impartial task of adjudging cases that are presented for adjudication.
As aforementioned, on August 2, 1996, Firefighter Vaeth was seriously injured in the Line of Duty, as a firefighter for the City of Baltimore when an alarm was sounded for multiple reports of a building fire. Truck 1, Firefighter Vaeth's assigned company was the first arriving unit on the scene and encountered heavy smoke conditions coming from a 4 story office building. The members of Truck 1 entered the building to begin providing access to the arriving engine companies, to ventilate the structure, and to search for any trapped occupants. They were met with extreme heat and very heavy smoke conditions, which lowered the interior of the structure's visibility to nothing. As the engine company was advancing their hose line up the steps to Firefighter Vaeth's location on the 4th floor, he breached the ceiling and exposed the fire. This caused the near simultaneous ignition of the exposed combustible materials in the enclosed area and the air gave it the added element that it needed to progress rapidly. The force of this occurrence threw Firefighter Vaeth over a railing and down the stairwell into the basement. He landed on his back, on top of the self-contained breathing apparatus (SCBA) and after enduring many surgeries, his lower back has essentially been rebuilt over the years. Despite the severity of the injury and due to his eagerness to return to work, he recovered and returned to perform the full scope of his duties.
In March of 1999, Firefighter Vaeth suffered a recurrence of this injury which caused the City of Baltimore's medical representative for injuries occurring to police, firefighters, and E.M.S. personnel Dr. James Levy of the Public Safety Infirmary (PSI), to deem him physically disabled from the further performance of his duties. Firefighter Vaeth was ordered to file an application for disability retirement benefits to the Fire and Police Employees Retirement System of Baltimore City (F&PERS) and an administrative hearing was conducted to determine his eligibility to receive those benefits. This hearing commenced before Mr. Frederick McGrath, with the City Solicitor representing the F&PERS and Firefighter Brian Vaeth represented by Mr. Alex Katzenberg. In his findings of fact, the hearing examiner for the F&PERS, Mr. Frederick McGrath, ruled in error. Rather than accept the decision of the hearing examiner for the Fire and Police Employees Retirement System of Baltimore City, Firefighter Vaeth filed an appeal of this arbitrary and capricious ruling with the Circuit Court for Baltimore City. Before the matter could be heard by the court, Acting Chief Carl E. MacDonald reinstated him to his duties. Firefighter Vaeth was re-examined by PSI physicians to determine his ability to perform his duties, as a firefighter for the City of Baltimore and returned to his the full performance of his duties.
In 2002, Firefighter Vaeth suffered another recurrence of this injury and was again deemed to be disabled from the performance of his duties by the medical director of PSI, Dr. James Levy. Firefighter Vaeth was informed that PSI was determining this as a Non Line of Duty injury and he disputed this adverse employment action with his recognized bargaining unit, International Association of Firefighters Local Union 734 by requesting that the liaison between Local 734 and PSI, Mr. Jerome Robusto file a grievance in the manner prescribed in the labor contract, the Memorandum of Understanding between the City of Baltimore and Local 734 that was in force at the time. Firefighter Vaeth was again ordered to file an application for disability retirement benefits with the F&PERS by Chief of Fire Department William Goodwin. A hearing for those benefits commenced before Mr. Frederick McGrath again, with the City Solicitor representing the F&PERS and Firefighter Vaeth representing himself. Firefighter Vaeth was denied disability retirement benefits by Mr. Frederick McGrath again. An appeal was filed to address this second arbitrary and capricious decision by Mr. Frederick McGrath, however, while the appeal was pending Firefighter Vaeth required an additional surgery in relation to this injury and the appeal was dismissed for lack of prosecution while he was recovering from the surgery. Firefighter Vaeth filed a civil lawsuit to correct the errors in this case upon attempting to exhaust all administrative remedies and by filing a complaint with the EEOC. It is alleged that the City Solicitor, George Nilson along with Assistant City Solicitor Sabrina Willis and Assistant Chief Rod Devilbiss, Jr. conspired to commit fraud upon the court in order to obstruct justice by having a fraudulent affidavit introduced into the record in an effort to unlawfully restrict Firefighter Vaeth's ability to present his claim to the court.
Upon the filing of the complaint and subsequent pleadings, as a result of the City's Motion to Dismiss, Firefighter Vaeth filed a Motion to Compel Discovery. As Firefighter Vaeth attempted to obtain the evidence required to overcome the motion, the City Solicitor responded to his request for discovery of the evidence required that was in their control by telling him that he would have to file an action under the Freedom of Information Act to get it. This request was forwarded to the City Solicitor in an effort to obtain the evidence needed to overcome the City's fabricated evidence and fraudulent assertions. By blocking Firefighter Vaeth's attempt to obtain the evidence that was needed and was contained in his employment file that the City had in their possession, the City Solicitor was able to commit the fraud by fabricating the evidence they needed necessary to prevent Firefighter Vaeth from fully participating in the proceeding.
Much of the Court's opinion focused on findings that the underlying reason Firefighter Vaeth could not proceed was because the court lacked jurisdiction to grant the relief requested because he could not prove that he exhausted his administrative remedies by filing a dispute with the City over the adverse employment action in a timely manner. This assertion, supported by the fraudulent affidavit submitted by Assistant City Solicitor Sabrina Willis, completed by Assistant Chief Devilbiss, Jr., was fraudulent and, more importantly, was accommodated by the willingness of Baltimore City Solicitor George Nilson to allow that fraud to thoroughly invade and support their effort to prevail against Firefighter Vaeth.
The fraud worked upon this Court in this matter was comprised of numerous acts of misconduct. Although recklessness is all that need be shown to establish a fraud on the Court under the controlling authorities, the vast majority of the conduct here was clear, intentional, and willful. Together, the acts amounted to a pervasive fraud driven by the goal of prevailing at whatever the cost. The following selected examples discuss only some of the more egregious acts of fraud.
Mrs. Sharon Garcia, Claims Administrator for the F&PERS, had the responsibility of assembling the medical record on behalf of the City of Baltimore and submitting it to the hearing examiner for the F&PERS. The record shows that not only was irrelevant material introduced into the record, which can only be viewed as an attempt to convolute the record and cause confusion, relevant medical information was willfully withheld from inclusion by Mrs. Garcia. This information was vital to Firefighter Vaeth being able to prevail at the hearing before the F&PERS, and ultimately to overcome the City Solicitor's Motion to Dismiss in this matter before the Court. This information was excluded because Mrs. Garcia either did not know where to locate it, or she withheld it purposely. A report by the Baltimore Sun demonstrated that during the time relevant in this complaint, the Mayor of Baltimore City Martin O'Malley's Chief of Staff, Michael Enright visited the office that handled the files relating to work related injuries of City employees approximately 6 months after he took office. Upon his arrival, he found the office virtually empty and employee files piled up on desks, defying any system of organized filing methods and former Mayor Kurt Schmoke's picture still on the wall. The information required for Mr. Frederick McGrath to make the proper determination in Firefighter Vaeth's case was in this office but was knowingly withheld by the City Solicitor. Firefighter Vaeth attempted to obtain this information from the City Solicitor but he was informed that he would need to file a Freedom of Information Act request with the court. Firefighter Vaeth filed a Motion to Compel Discovery from the City Solicitor but the fraudulent and perjuriously fabricated affidavit submitted by the City Solicitor and by Assistant Chief Devilbiss, Jr. prevented that.
Under provisions prescribed by the Baltimore City Code, Firefighter Vaeth was to file a dispute with the adverse employment action within 5 days of the date of that decision. Firefighter Vaeth absolutely complied with this requirement, as he contacted his Union representative, Mr. Jerome Robusto to grieve the matter. Firefighter Vaeth was hospitalized during the relevant time herein, in order to facilitate having surgery for the injury. Firefighter Vaeth was unsuccessful in the grievance and it was his intent to subpoena Mr. Robusto upon receiving permission from the Court to serve upon him a set of interrogatories and through testimony obtained during a deposition, if necessary, that would have sufficiently demonstrated that the affidavit was fraudulent. Upon contacting officials from IAFF Local 734 to obtain an affidavit attesting to the dispute being filed by Mr. Robusto, Firefighter Vaeth was informed that they would only respond upon receiving an order of the Court. Despite having knowledge of this dispute being filed, the City Solicitors Office willfully and knowingly filed the fraudulent and perjuriously fabricated affidavit which successfully prevented this.
At the outset of the hearing before Mr. Frederick McGrath, hearing examiner for the F&PERS, he asked Firefighter Vaeth, "What makes you think you can re-file an application for Line of Duty disability benefits after I already denied them to you?" This demonstrates extreme bias and prejudice that should never be exhibited by a trier of the facts. As the Court has found, Mr. McGrath is not considered to be a judge and as such, there are no standards of professional conduct in which he is held to.
In an email Firefighter Vaeth received from Baltimore City Fire Chief William Goodwin, he details the fact that he was told to find a way to fire Firefighter Vaeth during his retraining at the Baltimore City Fire Academy upon his reinstatement, as a result of the appeal he filed related to the errors the hearing examiner made in the first hearing for disability retirement benefits. This email is included herein, as evidence of the City of Baltimore's efforts to retaliate against Firefighter Vaeth for prevailing in his appeal of that decision.
The only true investigation that ever occurred in relation to this claim was completed by Mrs. Cassandra Stewart, Director of Constituent Services for the Mayor of Baltimore City, Stephanie Rawlings Blake. In it she found that Firefighter Vaeth's rights were violated and she requested that he be reinstated to his duties by the Chief of Fire Department, who was then informed by the City Solicito's Office that he could not reinstate Firefighter Vaeth because he had a lawsuit filed against them. A copy of that email is also included in the evidence.
Newspaper articles that were published in the Baltimore Sun during the times relevant herein demonstrate the true motive and the intent of then Mayor of Baltimore City Martin O'Malley to "crackdown" on the abuse of injury leave time, or "A" time, by City employees. The Mayor began what was called the "Return to Work" initiative and it resulted in a 30% to 60% decline in "A" time abuses. City employees injuries were being investigated and for the first time, in 2000, they began keeping detailed statistics on "A" time in each City department. Those numbers were then fed into Citi-Stat, the City's new computerized statistics tracking system that was guiding Mayor O'Malley's efforts to make City government more efficient.
It is obvious that members of the fire and police departments became a statistic that was to be eliminated. Members were never placed into an "Attendance Monitoring Plan" for abusing leave time, as is provided for in the Manual of Procedures for the Baltimore City Fire Department that outlined the policies relating to, among other things, disciplining members for violating City employment rules.
On August 15, 2002, the Baltimore Sun reported that in a continuing push to privatize City services, the Baltimore City Board of Estimates hired a hospital and a management company yesterday (8-14-2002) to examine City Workers Compensation Claims. The contracts were awarded to Mercy Medical Center to operate the Public Safety Infirmary for $2 million dollars, and to Comp Management for $4 million dollars. These two companies had already been operating these services on behalf of the City long before 2002. Evidence shows that they were involved with the City of Baltimore, as far back as 1999, around the same time as Mayor O'Malley's "Return to Work" initiative began. The idea for privatizing the clinic stemmed from a May 2001 study by the Greater Baltimore Committee. A comment in the article from a Union official that represents City and State employees stated that, "It doesn't take a genius to know that private companies will make medical decisions based on the bottom line." City officials said that the deals would save the City money in large part because the contractors will do a better job of detecting fraud and getting injured employees back to work. These companies had an interest in reducing the numbers of suspected "A" time abusers, as they had to demonstrate that they could be successful at the objective of the Mayors "Return to Work" initiative before the City would award those companies contracts to perform those services in 2002.
Another report by the Baltimore Sun on December 17, 2002, demonstrated that Comp Management made a mistake that created pay delays for City employees who were receiving Workers Compensation benefits. An AFSCME (American Federation of State and County Municipal Employees) said that his office received hundreds of complaints about missing checks, workers being forced back to work before they are treated and other problems since Comp Management and PSI were hired to save money. Mercy Hospital received $2 million dollars and Comp Management received $4 million dollars for those contracts as part of a plan to cut 42 City employees and close a City run health clinic for employees. The deal has been a nightmare, according to a City official. Mayor Martin O'Malley stated that, "These sort of growing pains and operational glitches are inevitable whenever you make a change. We will resolve the issues."
This case clearly demonstrates that those issues were not resolved.
As aforementioned, the scheme began after former Mayor Martin O'Malley's Chief of Staff, Michael Enright, made a surprise visit to the office that handled workers' compensation claims for city and school employees. In the article, it was reported that, "Most of the workers were missing, at lunch Michael R. Enright was told, although the hour was 2 p.m. There was paper everywhere," Enright said, "piled on desks and crammed into shelves, defying any organized filing system." And near the entrance hung a picture of the Mayor, former Mayor Kurt L. Schmoke, that is.
Essential documents relating to Firefighter Vaeth's injury were in the custody of that office, because the claim was still open and the remainder of the closed file was in the custody of Comp Management for management of employee injury related incidents. The lack of supervisory control of the chain of custody of these records caused this information to be withheld from the hearing examiner and subsequently caused the misconduct to be perpetrated on the Court, as the incomplete medical record was introduced as evidence in this matter. The City Solicitor's Office, in concert with the F&PERS, sought to conceal this information rather than comply with the law regarding the submission of evidence and perpetrated a fraud on the court to cover up their incompetence and to further their fraud on the Court. Had the City Solicitor complied with the law, as an officer of the court is required to, the unlawful concealment would not have occurred and Firefighter Vaeth would not be seeking justice in such an extraordinary manner. He has asked for, on numerous occasions, the results of investigations that have been performed by any City agency upon the conclusion of the hearing before the F&PERS, which is mandated by the Baltimore City Code to ensure that fairness was upheld in the proceeding before the board, commission, or agency in which was before them or any other investigation undertaken, as a result. None of these request have been honored to this date. It can logically be assumed that the City Solicitor's fraud has infected any investigation that has been completed that involved obtaining any evidence from the City of Baltimore. As of this date, this information has not been provided to Firefighter Vaeth. As a result of the fraud, he has actively sought the assistance of the Maryland State's Attorney, the Maryland Attorney General, the FBI, and the US Department of Justice but has been refused without an investigation being performed.
The complaint more than alleges a colorable claim of fraud upon the court. This action began with a fateful decision by the City Solicitor to frame the issue to suit what they believed were the facts in the case by assembling an incomplete medical record of the relevant injury in question using inaccurate and incomplete statements to mislead the Court, submitting fabricated and fraudulent evidence, and failing to correct the false impression created by their expert's medical opinion based upon the incomplete medical record which was submitted by the City, all being sufficient to show a scheme to defraud the Court. Thereafter, these acts of corruption only grew and is the basis of the allegations forwarded in this complaint, the focal point of extensive perjury and violations of the Federal Rules of Civil Procedure, which permitted the equally fateful decision to attempt to protect their actions and cover for them, while then adding to it the egregious efforts to protect counsel from any prosecution resulting from it.
A government attorney is "the representative not of an ordinary party to a controversy, but of a sovereignty . . . [whose] interest in a . . . prosecution is not that it shall win a case, but that justice shall be done." Berger v. United States, 295 U.S. 78, 88 (1935) (emphasis added); see also Prof. Responsibility: Report of the Joint Conference, 44 A.B.A.J. 1159, 1218 (1958) (a government lawyer possesses "governmental powers that are pledged to the accomplishment of one objective only, that of impartial justice." As such, an attorney representing the United States government is "held to a higher standard of behavior. United States v. Young, 470 U.S. 1, 25-26 (1985) (Brennan, J., concurring). The standard applies with equal force to both criminal and civil cases. See Freeport-McMoRan Oil & Gas Co. v. FERC, 962 F.2d 45, 47 (D.C. Cir. 1992); see also A.B.A. Code of Prof.Responsibility 7-14; Model Code of Prof. Responsibility EC 7-14 (1981) ("A government lawyer in a civil action has the "responsibility to seek justice." This higher standard requires that a government attorney refrain from using "his position or the economic power of the government to harass parties or to bring about unjust settlements or results."A.B.A. Code of Prof. Responsibility 7-14. A government lawyer should similarly "refrain from instituting or continuing [civil] litigation that is obviously unfair." Model Code of Prof. Responsibility EC 7-14 (1981).
Critically important to this case is the obligation of a lawyer representing the government "to see that all evidence relevant to the case is presented, even if unfavorable to its position." United States v. Chu, 5 F.3d 1244, 1249 (9th Cir. 1993) (emphasis added). "A prosecutor has the responsibility of a minister of justice and not simply that of an advocate. This responsibility carries with it specific obligations to see that the defendant is accorded procedural justice and that guilt is decided upon the basis of sufficient evidence." While the government's disclosure obligation encompasses more than just exculpatory evidence, the failure to produce evidence "material either to guilt or punishment" gives rise to constitutional violations. Brady v. Maryland, 373 U.S. 83, 87 (1947). Thus, an attorney who withholds such evidence not only violates his disclosure obligations, but also the due process clause. Id. Although the Supreme Court has not yet explicitly stated that Brady applies in civil cases, numerous federal courts have opined that the policy justifications underlying Brady apply in civil settings as well. For example, in EEOC v. Los Alamos Constructors, Inc., the court ordered the government to disclose a list of witnesses and stated that a defendant in a civil case brought by the government should be afforded no less due process of law than a defendant in a criminal case. 382 F. Supp. 1373, 1383 (D.N.M. 1974) (citing Berger, 295 U.S. at 88). Similarly, the court in Sperry & Hutchinson Co. v. FTC stated that the due process requirements that inhere in a criminal case, requiring the prosecution to "disclose evidence in its possession which may be helpful to the accused, should also apply in civil actions brought by the government, as [i]n civil actions, also, the ultimate objective is not that the Government "shall win a case, but that justice shall be done."256 F. Supp. 136, 142 (S.D.N.Y. 1966).
It is as if these rules did not exist in this case and to the contrary, it has been demonstrated that the City Solicitor's Office does not recognize the "Rule of Law."
In the context of the broad tapestry of misconduct presented by this action, there was perhaps nothing as primary and significant as the manner in which the City Solicitors office perpetrated their fraud, as they provided false and misleading testimony on the most fundamental aspect of their investigations, in an effort to obstruct justice. Upon receiving notice of their errors, the City Solicitor's Office did nothing to correct the record afterward, as was their responsibility, but only advanced their fraud using those investigatory agencies responsible for reviewing this matter. This permitted the City Solicitor to advance their fraud into the realm of the civil justice system through the utilization of the fraudulent affidavit and perjured testimony. The pervasive and coordinated misconduct of the Baltimore City Solicitor's Office and the F&PERS, whether viewed in isolated parts or as a whole, clearly and convincingly reflects an effort by the Baltimore City Solicitor's Office to prevent the judicial process from functioning in the usual manner.
The Baltimore City Solicitor's Office and the F&PERS obfuscated the truth at every turn, a process which began in March of 1999, continued with the submission of an incomplete medical record and their drafting of a false affidavit, which is ongoing at this time. Ultimately, the Baltimore City Solicitor joined in the process by concealing key documents, falsifying responses to motions and requests for admissions, and by allowing witnesses to lie under oath. Whether analyzed independently or collectively, these acts establish a fraud upon this Court. As has been stated by the court, "corrupt intent knows no stylistic boundaries." But the fraud upon the Court on this key issue did not stop there. The City Solicitor also advanced their fraud into the judicial proceedings by submitting a false and misleading declaration from Assistant Chief Devilbiss, Jr. in summary judgment practice and also by attaching the false affidavit to that declaration.
Regardless, the profound misconduct of the City Solicitor's Office and the F&PERS has caused grave injury to our system of justice. Such misconduct, if not addressed by law enforcement, will only create an intolerable sense of invulnerability in those responsible and likely to perpetuate and accelerate additional frauds, doing further damage to our entire judicial system. The United States Department of Justice has the power to act when our legal process is so thoroughly corrupted, and it is difficult to imagine a case more deserving in which to exercise the full measure of that authority.
Firefighters, along with other first responders, put their lives on the line to protect the citizens of Baltimore City every day. Timely and responsibly meeting the medical and basic living expenses of firefighters who are determined to be disabled, as a result of being injured in the Line of Duty, is not just a legal obligation but a moral one. An injury such as the one that Firefighter Vaeth suffered, and many others who served in the fire and police departments, which is fully detailed in the pleadings presented to the United States District Court in this matter, should not result in medical conditions worsened by delay and denial of necessary benefits, nor should it leave the firefighter, paramedic, police officer, or their family financially destitute and emotionally battered. Those entrusted with maintaining the medical files related to injuries suffered in the performance of a firefighter's duties have a clear responsibility to do so, as provided for in the Baltimore City Code. In no way should the failure of officials within the City of Baltimore to properly maintain and submit the complete medical files of injured members create obstacles bound to worsen the physical and financial conditions of members of the department who have suffered debilitating injuries. Instead of carrying out these duties consistent with their legal and moral obligations, the City of Baltimore routinely and improperly chooses to forward legally inconsistent arguments, withhold relevant evidence that they have in their possession, and fabricate evidence that they don't have to unlawfully obtain a ruling that is favorable to them, all in an effort to wrongfully deny what is ultimately the City of Baltimore's obligation to the members of the Fire & Police Employees Retirement System and permit their pattern and practice of discrimination to continue at their will.
After being injured on the job, members of the fire and police departments have been met with abuse and have been made subject to the prejudicial opinions of medical staff at PSI, just to meet the program goals for which PSI was actively bidding on. These allegations, as reported by the media which supports that these allegations are not just baseless, have merit that must be investigated by someone, at some point. If not, there is a lot of context that can be scrubbed from both Maryland Law and the Baltimore City Code regarding them. If no investigation is ever conducted, as is prescribed by law, then it demonstrates that justice is only available for a chosen few and is only available to continue the false impression that justice really exists.
In every instance complained of in the lawsuit filed in the United States District Court, the Baltimore City Solicitor knowingly forwarded the ongoing scheme by the City of Baltimore to refuse to pay retirement benefits to disabled members who suffer severe injuries on the job, all in bad faith. Benefits were denied without reasonable investigations and without forming a good faith belief that the standards for compensable disability had not been met when evidence of the entitlement to benefits had been provided by me and other members of the fire and police departments for Baltimore City.
The City of Baltimore acted with knowledge that the methods they were using to investigate claims caused them to ignore evidence of compensability and produce false evidence demonstrating that I, and others similarly situated, were not entitled to compensation. They also acted in bad faith by ignoring that the methods they used to investigate claims and conduct hearings to decide compensability did not accurately reflect the ethical standards for doing so by producing false evidence and the City Solicitor's opinion, offered as testimony on the record before the Panel of Hearing Examiners and eventually the Court. As officers of the court, attorneys are afforded a bit more trust in matters before the courts because the attorneys are the ones responsible for seeking justice and finding the truth is the fundamental purpose of justice itself. Without truth, there can be absolutely no justice. When there is no truth, fair and equal no longer becomes part of that equation either. When rulings are issued on cases wherein counsel for the defense has possession of all of the evidence and they disclose just what they want to and not what is relevant, and are willing to fabricate what evidence they don't have just to obtain a ruling that is favorable to them, what is left is a version of justice that rewards unethical behavior and only empowers them to carry on the continuing pattern and practice of prejudicial and discriminatory violations of the law that are apparent in this case, and the cases of many other members of the Baltimore City Police and Fire Departments similarly situated.
Exhibit 1:
Record before the Panel of Hearing Examiners, F&PERS.
Exhibit 2:
Email William Goodwin, Chief of Fire Department
Exhibit 3:
F&PERS Administrative Hearing Decision 1
Exhibit 4:
F&PERS Administrative Hearing Decision 2
Exhibit 5:
Affidavit submitted by Assistant Chief Rod Devilbiss, Jr.
Exhibit 6:
Letter of Abraham Schwartz, Counsel for F&PERS.
Exhibit 7:
Email Cassandra Stewart, Director of the Mayor's Office of Constituent Services
Exhibit 8.
Letter of A. Katzenberg to Comp Management Inc. (Dec. 2002)
Newspaper Articles
Exhibit 1 Baltimore Sun Newspaper Article
"City Aching Over Abuse of Paid Medical Leaves"
Neal Thompson 2/25/2001
Exhibit 2 Baltimore Sun Newspaper Article
"Health Services to be Privatized"
Laura Vozzella 8/15/2002
Exhibit 3 Baltimore Sun Newspaper Article
"Company's Mistake Creates Pay Delays for City Workers"
Tom Pelton 12/17/2002
Exhibit 4 Baltimore Sun Newspaper Article
"Workers' Comp Reform Pays Off"
Laura Vozzella 1/25/2005
Dated this 9th of August, 2016.
Brian Charles Vaeth


text:
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subset: commoncrawl


text: Received: (from strider) by igc4.igc.apc.org (8.6.12/Revision: 1.15 ) id JAA27209; Tue, 26 Sep 1995 09:05:03 -0700 Date: Tue, 26 Sep 1995 09:05:03 -0700 ------------------------ BurmaNet ------------------------ "Appropriate Information Technologies, Practical Strategies" ---------------------------------------------------------- The BurmaNet News: September 26, 1995 Issue#238 Noted in Passing: The Burmese minority groups see that amphetamines are easier to make, easier to sell and they get the money more quickly. - Thai Pol Lt-Col Veerasak Meenavanich on the switch from amphetamine to heroin production by Khun Sa, the Haw Chinese, and the Red Wa. 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If you have questions on any of the following subjects, please direct email to the following coordinators, who will either answer your question or try to put you in contact with someone who can: Arakan/Rohingya/Burma- [volunteer needed] Bangladesh border Art/archaeology/: [volunteer needed] Campus activism: [on summer vacation] Boycott campaigns: [Pepsi] wcsbeau@xxxxxxxxxxxxxxxxxxxxxxxx Buddhism: Buddhist Relief Mission, c/o NBH03114@xxxxxxxxxxxxxxxx Chin history/culture: plilian@xxxxxxxxxxxxxxxx Fonts: tom@xxxxxxxxxxxxxx History of Burma: zni@xxxxxxxxxxxxxxxxx Kachin history/culture: 74750.1267@xxxxxxxxxxxxxx Karen history/culture: 102113.2571@xxxxxxxxxxxxxx Karen Historical Society Mon history/culture: [volunteer needed] Naga history/culture: Wungram Shishak, z954001@xxxxxxxxxxxxxxxxx Burma-India border [volunteer needed] Pali literature: "Palmleaf" c/o burmanet@xxxxxxxxxxx Shan history/culture: [volunteer needed] Shareholder activism: simon_billenness@xxxxxxxxxxxxxxxxx Tourism campaigns: bagp@xxxxxxxxxx "Attn. S. Sutcliffe" World Wide Web: FreeBurma@xxxxxxxxx Volunteering: christin@xxxxxxxxxx [Feel free to suggest more areas of coverage] ******************************** ABSDF: STATEMENT ON U.S. SENATE APPROVAL OF SANCTIONS September 24, 1995 ALL BURMA STUDENTS' DEMOCRATIC FRONT STATEMENT ON U.S. SENATE APPROVAL OF SANCTIONS AGAINST SLORC Date: September 24, 1995 The ABSDF warmly welcomes the United States Senate's approval of tough sanctions against Burma to ban all U.S trade with, investment in, and travel to Burma. We, the ABSDF respectfully congratulate Senator Mitch McConnell, a Republican from Kentucky and chairman of a key funding panel, who sponsored the sanctions amendment to the 1996 foreign aid bill, which was approved by the Senate by an overwhelming 91 to nine on September 21. At present in Burma, there has been no new development following the release of Daw Aung San Suu Kyi, Nobel Peace laureate and the democracy leader of Burma. Approximately, 3,000 political prisoners are still detained and the Slorc military regime still intends to reconvene its sham National Convention. In addition, there has been no response by the Slorc to an offer by Daw Aung San Suu Kyi to make dialogue for national reconciliation and internal peace. It is a crucial time for democratization in Burma and we firmly believe that the international community must take further action against the military regime which rules the country against the will of the people. We highly appreciate the support of the United States for democratization and human rights in Burma. On behalf of the people of Burma, we the ABSDF appeal to the President of the United States to pass the bill and implement effective economic sanctions against Burma until the goal of democracy in Burma has been achieved. Central Leading Committee ABSDF 8888 camps ********************************* KNU: KNU PRESS STATEMENT NO 13 - MERGUI-TAVOY DISTRICT September, 15, 1995 [Note: Translated by the ABSDF Information Department] (editor's note: the mistakes in word choice have been left, as this the way the translated document was printed. One example: "labors" should be read as "laborers") KAREN NATIONAL UNION(MERGUI-TAVOY DISTRICT) ORGANIZING AND INFORMATION DEPARTMENT PRESS RELEASE NO 13 ================== September, 15, 1995 Ticket to ride -------------- Tavoy-Yay Phu new railroad was opened by the Slorc in Tenasserim Division on May, 1995 and the train ticket costs 10 Kyat for each. The cost of a ticket from Tavoy to Yay Phu by private bus was also 10 Kyat before the railroad was build in this area. Local people are now very disappointed because they expected that it would be cheaper than the private bus when the government owned railroad finished. Non-water resistance -------------------- During this raining season, Tavoy-Yay Phu railroad was damaged three times in many parts of it by the water. The yearly maximum rate of rainfall in that area is over 200 inches. And local people were summoned as forced laborers by the Slorc for repairing the railroad without any labor charges. Railroad soil bank rebuilt -------------------------- Each 800 local people from Thayat Chaung township, Long Lon township, Tavoy township and Yay Phu township in Tavoy District were collected by the Slorc to construct the rest of long railroad soil bank between Kyauk Kanyar and Zinba village in Yay Phu township since June, 1995. The prisoner labors from 30 mile camp have worked for necessary stones and rocks for the bridges which located along the railroad and the cars owned by the local people were used to carry those stones and rocks by the Slorc's army. The estimate number of local forced labors for the railroad between Kyauk Kanyar and Zimba village. 1. 21 mile camp 1,000 local forced labors 2. 30 mile camp 200 prisoners and 700 local forced labors 3. Nwe lein camp 700 local forced labors 4. Zinba camp 300 prisoners and 800 local forced labors Every local forced labor has to carry their own food while they were in railroad construction site. Rotating system for porters --------------------------- Local people from all the villages in four townships of Tavoy District have been instructed by the local Slorc's army to serve as porters for monthly, two people from each village. If it is failed to serve as porter, they have to pay 2,000 Kyat fine per each. Study of gas pipeline --------------------- The Slorc and TOTAL oil company have allowed a so-called French woman from Green peace to study the possible damage of environmental situation in that area for construction of gas pipeline to evade form the international pressure, started in April this year. In her report, the environment of that area will not be damaged by the construction of gas pipeline. She was allowed for three months to study the environmental situation by the Slorc. During her study, she has stayed in Lanzon Gyi ward in Tavoy by the arrangement of the Slorc. Army of looters --------------- On August 2, 1995, household things and money from villagers in Zarde Win village in Palaw township were looted by the Slorc's army column led by Major. Hla Kyi from No.(101st) regiment and Major. Soe Win from No.(17th) regiment. The following lists of the persons were looted by the Slorc's army: 1. Saw Thar Shell cost of household things 5,000 Kyat money(in Cash) 6,000 Kyat 2. Saw Kya Lay cost of household things 2,000 Kyat money 8,500 Kyat 3. Saw Me De cost of household things 3,000 Kyat money 1,000 Kyat 4. Saw Pe Kay cost of household things 15,000 Kyat money 1,500 Kyat 5. Saw Te De cost of household things 4,500 Kyat money 1,000 Kyat 6. Saw Mu Say cost of household things 4,000 Kyat money 500 Kyat 7. Saw Say Lwal cost of household things 2,000 Kyat money 1,000 Kyat 8. Daw Taw Hla Myain cost of household things 40,000 Kyat money 10,000 Kyat ----------------------------------------------------------- Total 105,000 Kyat When the Slorc's army column entered the village, all the villagers have escaped to porterage and the Slorc's troops went up on the houses and looted money and household things such as radio, cassette tape recorder, traditional silver bowl, new clothes, sewing machine etc. Interview with an escapee from forced labor ------------------------------------------- Brief biography of escapee Name- Ko Tin Sein Sex- male Age- 35 Father's name- U Maung Tin Occupation- Farmer Address- Hnan Kyal village, Yay Phu township, Tenasserim Division Martial status- Married with Ma Hla Yin Children- Two boys and a girl Nationality- Burmese Religion- Buddhist Date of interview- September 10, 1995. Q: Ko Tin Sein, when did you leave Hnah Kyal village? A: I left Hnan Kyal on September 9, 1995. Q: Why did you leave your village? A: When I came back from railroad construction site on September 8, 1995 after my turn of forced labor working and I have seen that my family hardly facing their daily survival. I can do nothing for my family because I didn't get any payment for my work in railroad construction. First, the camp authorities have promised that they would pay labor charges to us, but, finally they didn't and besides, they ordered us to work in terms of our absence during the raining days. Then, after we completed all those works, they have allowed us went back home. So, if I continue to stay in my village, surely I will be faced next term forced laboring again and I left for border and to work in Thailand to save money for my family. Q: You've worked in 30 mile camp, right? And, have you seen the Slorc's soldiers beating forced labors? A: Yes, I've seen. Mostly, camp authorities always punish the forced labors who couldn't finish their quota of works. Q: Which Battalion taking security in 30 mile camp? A: It is Light Infantry Battalion (406). Q: Do you think that camp authorities are civil servants? A: No. officers from LIB (406) are camp authorities. They arrange work hours and daily quota of work for forced labors. Q: How the camp authorities manage daily quota of work for forced labors? A: Every forced labor has to dig a hole wide 10 square ft x 1 ft in the ground. Q: Did they pay labor charges to forced labors? A: No. never. Q: We have heard that Myanmar railway corporation under Minister of railway has paid labor charges to local forced labors regularly ? A: I have heard about it like that. But, we never received that. The prisoners are being used for the work of breaking rocks and stones by the management of camp authorities. Q: Are there prisoners in 30 mile camp? A: Yes. Q: Do you think how many prisoners there? A: I think, about 200 prisoners. Q: Their legs are chained? A: Sure. Q: When you were in 30 mile camp, any local forced labor died for something? A: Yes. One forced labor was killed by the security guard from LIB (406). Q: So, Where does he live? A: He lives in same village of mine. Q: What's his name? Do you know his age and parents' name? A: His name is Ko Pe San, 30 and his father is U Thee Pe. Q: Has he a wife and children? A: Yes. he has. His wife name is Ma Htar and he has 3 children. Q: How did he died? Can you explain me? A: Yes. the camp authorities ordered Ko Pe San and another guy from same village to cut trees for sleepers which will be laid under the iron rails on September 6, 1995. Then they went to the hill east part of camp and later Sergeant Tin Win and his unit from LIB (406) have followed them. Not very soon, we have heard some gun shots. Then, Sergeant Tin Win came back and ordered us to carry the corpse of KO Tin Win and we knew he was shot and dead. Q: So, What's Sergeant Tin Win's reason? A: He ordered forced labors to assemble and said that who did let him went east part of camp where is the limited area of army. Therefore, he said ,"we don't have any kind of responsibility for his death, because he brakes the rule". Q: Did you report to his wife? A: Yes. we did on the same day, September 6, 1995. After received the bad news, Ma Htar and some (Slorc) village law and order restoration council members came to 30 mile camp. Then, Sergeant Tin Win told them to take the dead body back to the village and not to try to charge them at the court. Because, he has broken the rule. Ma Htar replied she would not and it was enough for her to have her husband body. Then, Ma Htar and Slorc members carried the dead body to the village. Q: Ko Toe who accompanied with Ko Pe San, didn't he explain the camp authorities? A: Yes. he did. But camp authorities denied that they did not order them to cut trees in east part of camp. Q: Ko Tin Sein, what do you think about the Slorc military regime? A: Since the period of so-called BSPP (Burmese Socialist Program Party) and the present Slorc military regime, our people can not imagine what is wrong and right. Because, sometimes authorities said that it was true, but next time they said, it was not true and they forgot what they mentioned before. I can say two period under the BSPP and Slorc didn't lead us to the right things. Q: Of course--- and thank you very much for your explanation, very patiently. A: I also thank you very much because we have a chance to open our heart that what we have been suffering since long time. Army's animal farm ------------------ All villages in four townships of Tavoy District have been ordered to supply various domestic animals to the Slorc's Regiments and LIBs for their livestock projects. 200 ducks, 200 chickens, 3 pigs and one buffalo or one cow from each village will be given without fail to the Regiments of No.(25), No.(104) and LIBs (273), (267), (268), (269), (401), (402), (403), (404), (405), (406), (407), (408), (409) and (410). Some local cattle traders who have been accused for smuggling cattle to Thailand and arrested and paid fine by the Slorc's army. Their own cattle were also seized and taken in ratio for Regs and LIBs. Big money for Slorc ------------------- At present, some French officers from TOTAL oil company office staying in Ohnbin Guin village in Yay Phu township have hired helicopters from Slorc authorities for their safe trips in Yay Phu township for constructing gas pipeline. Rental charges for each helicopter costs 400,000 Kyat per day. Recently, gas pipeline construction has been re-started and very close persons of Slorc's army have got the contracts. Although TOTAL company has paid salary to local workers in dollar, the Slorc's officers exchange the salary money in Kyat, and then pay to workers. The Slorc's so-called official exchange rate for 1$ is 6 Kyat, but black market rate is 120 Kyat. A local girl raped ------------------ On April 20, 1995, the Slorc's military column led by Major Thet Oo from No.(101st) Regiment entered Wan Nar village in Tenasserim township and arrested Daw Ohn Kyi 40 and her daughter Ma In Kyi 14. The two women were took near mini video hall in the village. The reason of arrest them was for the support to ABSDF students and informing ABSDF. Daw Ohn Kyi was stood under the sun light for hole day. But, Ma In Kyi was dragged into the mini video hall and raped many times by the Slorc's soldiers. Slorc chairman fled to border ----------------------------- The Slorc's appointed chairman of Slorc (village law and order restoration council) from Yin Gyi village in Long Lon township fled to Thai border in August, 1995. He admits that he couldn't continue to collect money from villagers monthly for township Slorc's chairman and No.(104) Regiment. Order for cattle ---------------- Along the railroad in Hnain Htway village area in Yay Phu township, it was declared that cattle go up on the railway bank will be shot and the owners of cattle will also be paid fine. If the cattle owner want his dead cattle back, he will pay LIB (407) current price of that cattle. And, everyday the soldiers from LIB (407) shoot the cattle which go up on the railway bank and the owners have to pay them 500 Kyat for the charges of ammunition that the soldiers used. Border custom gate ------------------ The army officers from Slorc's outpost in Nat Eaindaung area in Tenasserim Division on Thai-Burma border allow local people entering Thailand through their outpost, but each person has to pay them 300 baht and sometimes those who want to enter Thailand were arrested for porterage. Information Department Mergui Tavoy District Karen National Union ********************************* BKK POST: SUU KYI: RELEASE DOES NOT POINT TO CHANGE September 25, 1995 Kuala Lumpur, AP BURMESE democratic activist Aung San Suu Kyi says her release from house arrest is no indication of change in Burma and that it should not result in a torrent of foreign investment and aid for the current junta. "I am just one person who has been released, why should that make a difference?" Suu Kyi said in an interview published in The Sunday Star. She added that there are still thousands of political prisoners in Burma, which chose her opposition party, the National League for Democracy, to lead the country in 1990 elections. The military government refused to recognise the election and imprisoned Suu Kyi and thousands of other NLD members soon after. The 1991 Nobel peace winner was released from house arrest earlier this year. Britain is reported to be the biggest investor in Burma up to March 1 this year with a total of $647.76, followed by France with $465 million. The United States ranked fifth with $203.19 million. "I believe aid should be gradual and conditional on the process and pace of democratisation," she told the Sunday Star two weeks ago at her house in Rangoon. The 51-year-old popular activist believes the military government is trying to pattern itself on the Indonesian political system, where the military is dominant. She declined to say if this was acceptable to her NLD and added, "It is not for NLD to say. The question is whether it is acceptable to the people of Burma." On the new constitution being drawn up, which might bar Burmese married to foreigner from holding political posts she said, "Some say it is aimed at me that would be a great pity because no national constitution should be written with one person in mind," she added. Suu Kyi married a British academic 23 years ago, but held on to her Burmese nationality. She has refused to go overseas or to see him in Britain for fear the junta may not allow her back into the country. ***************************************************************** BKK POST: THAI BUYERS EXPECTING BETTER RESULTS AT BURMESE GEMS AND JADE EMPORIUM September 25, 1995 by Errol de Silva A LARGE number of Thai entrepreneurs in the gems and jade trade are expected to attend next month's Gems, Jade and Pearl Emporium in Rangoon, organised by the Myanma Gems Enterprise, a state-owned organisation under the Ministry of Mines. The emporium will be held in the Myanmar Gems Emporium Hall on Rangoon's Kaba Aye Pagoda Road from October 14-22. The Thai Gem and Jewellery Traders' Association is coordinating Thai participation in the twice-a-year event at which large quantities of jade high-quality rubies and other gemstones and pearls are offered. In previous years, Thai buyers had little luck in efforts to gain access to these goods after being outbid by buyers from Hong Kong and Taiwan. However, Thais are much more confident of better results, according to TGJTA manager Thanan Maleesriprasert. He said the association's members were interested in' obtaining supplies through the emporium, especially rough gemstones. According to an information note issued by organisers, the sale of gems, jade and pearl will be by competitive bidding with prices in US currency. Payment can be made in several foreign currency units such as UK pounds, German marks, Swiss francs and Japanese yen. Travellers' cheques, bank drafts and telegraphic transfers are also accepted. The emporium also offers manufactured jewellery and jade carvings, but on a fixed-price basis. Prospective buyers can view and inspect the lots on offer for auction on October, 14 and 15. Competitive bidding for jade will be held from October 16-19, while the date for pearls will be October 20 and for gems October 21 and 22. The emporium has always been the main official marketing forum for highly prized rubies of pigeon-blood colour originating in the Mogok and Mong Hsu areas. But substantial amounts of these goods have been smuggled to the Thai border by groups of Kachin, Wa and Shan minorities, who often form alliances to move goods through areas controlled by each of these ethnic groups. Most gemstones have ended up in the Mae Sai market, but in more recent years, supplies to this centre have dried up due to ongoing clashes between SLORC troops and the rebel Shan army. Earlier, drug warlord Khun Sa ordered a halt to the flow of rubies and other gems after he set up a gem-cutting and jewellery fabrication factory in an area he controlled in Shan State. The Thai association was trying to convince SLORC to direct the sale of rough gem material to the local industry, but these initiatives bore no fruit even though the Burmese promised to cooperate with the Thais. ***************************************************************** BKK POST: KHUN SA ACCUSED SWITCHING TO SPEED September 25, 1995 ANTI-NARCOTICS authorities accuse drugs warlord Khun Sa of switching from heroin production to amphetamines for sale on the Thai black market. Because heroin trade in the Golden Triangle has been suppressed, Khun Sa has hired Thais to teach his people to produce amphetamines, Narcotics Suppression Office commissioner Pol Lt-Gen Somchai Malintangkul said yesterday. The pills are easier to make and to sell than heroin. "We have arrested one of these Thais. He told us Khun Sa would pay him 200,000 baht each time he goes up to teach them," Pol Lt-Gen Somchai said, declining to give further details other than to say the man is being prosecuted in Thailand. Pol Lt-Gen Somchai said the authorities were worried because pills were easier to smuggle onto the Thai market. "We make amphetamine arrests in the Central and Northern regions every day. Most of the arrests are in the North and the pills were smuggled into Thailand. Narcotics police nationwide recently completed training In drug suppression techniques and this had resulted in more arrests. They were working with counterparts in Malaysia, Burma, Laos and China to crack down on the import of chemicals used in drugs production. Cooperation with Cambodia and Vietnam would begin when those two countries were ready, he said. Pol Lt-Col Veerasak Meenavanich, who heads an amphetamine and inhalants suppression unit, said that apart from Khun Sa's army, minority groups in Burma such as the Haw Chinese and the Red Wa had turned to producing amphetamines for sale in Thailand. "The Burmese minority groups see that amphetamines are easier to make, easier to sell and they get the money more quickly. "They sell them to distributors at border areas and police are able to arrest only these -agents, not the producers over the border," said Pol Lt-Col Veerasak, deputy superintendent of the Crime Suppression Division's Second Sub-division. Taiwanese and Hong Kong traffickers and chemists produce a concentrated form of the drug on the outskirts of Bangkok. They hand this concentrate to Thai producers who use it to make amphetamines. They also sell their know-how to I Burmese minority groups, according to police. The involvement of Burmese 5 minority groups and foreign chemists has resulted in amphetamines taking two new forms - smokable and injectable in addition to the traditional pill. The pills cost about five baht each to make. They are sold to distributors for 20-30 baht each and then resold for 80-100 baht. The price recently hit 200 baht per pill, depending on the brand. Pol Lt-Col Veerasak said the popularity of amphetamines had spread from labourers and truck drivers to the public. ***************************************************************** Typed by the Research Department of the ABSDF {MTZ} 25.9.95 ***************************************************************** IWDC: CALENDAR/POSTCARD ANNOUNCEMENT September 1995 Dear Friend, The Indigenous Women's Development Center would like to tell you about our 1996 Calendar and Postcard set. Both products are in full colour and have been designed by IWDC to a professional quality. They will make attractive presents to give to friends, family, and colleagues for Christmas. We hope that in this way a wider market can be reached. By marketing overseas we hope that the message of these indigenous women will be remembered. The message of Aung San Suu Kyi is "I have been released. That's all. Nothing has changed." We hope you like the items we have produced. Each calendar contains: 28 pages of information and pictures 12 unique photographs of women and children from Burma Colour co-ordinated graphics and illustrations throughout Useful planning space for all your diary dates in 1996 Each postcard set contains: 9 different colour cards from the borders of Burma Plenty of writing space Order Details: (you can pay in US, UK, or Australian currency) price/item Air - 2 weeks Sea - 2 months Local (includes postage) US UK AUS US UK AUS Thai baht Calendar 8 5 10 6 4 8 100 Postcards 3 2 4 2.50 1.75 3.50 30 per set Minimum Overseas Order per Item: 10 To Order: Enclose: Name, Address, Tel/Fax, and check or money order For more information, contact: IWDC PO Box 169 Chiang Mai University Chiang Mai, Thailand Tel/Fax: 66-53-278-945


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Hi Supermoms,
'Seedai' is a very popular South Indian fried snack that resembles small marbles. But today's recipe ' Kombu Seedai' is not a fried snack. It is a much healthier steamed tiffin that can be offered as a savoury neivedyam/offering during festivals like Ganesh Chaturthi and Krishna Jayanthi. Method to make this seedai( or Kozhukattai) is similar to Ammini Kozhukkatai recipe that I have shared earlier. They are more like home made gluten free and protein rich pasta. I am sure you will agree. Traditional dishes are so fascinating!
Whether you are making it for festival as offering or as a breakfast, the Kombu Seedai is delicious and wholesome.
Recipe Source :Mrs. Vedavalli , Chennai
Kombu Seedai | Arisi Paruppu Kozhukattai :
Preparation time : 2 hours
Cooking time : 45 minutes
Serves : 4
1 cup = 250 ml cup
1 cup raw rice
3/4 cup pigeon peas/tuvar dal/toor dal
1/4 cup fresh coconut pieces ( chopped or grated)
2-3 green chillies ( adjust according to heat of chillies)
1 sprig curry leaves
1 tablespoon sesame oil
salt to taste
For tempering ( optional) :
1 teaspoon sesame oil
1 teaspoon mustard seeds
1/2 teaspoon urad dal/husked black gram
1 sprig curry leaves
For garnish ( optional):
1 teaspoon fresh coconut ( grated)
1. Wash rice and dal and soak them together in a vessel for 2 hours.
2. Grind the soaked rice and dal coarsely in a mixer/mixie along with coconut , green chillies and curry leaves.
Tip: Use the soaked water to grind . The batter should resemble Adai batter ie., thick batter.
3. Add salt and mix well.
4. Heat a wide pan or kadai over low flame with sesame oil and add the ground batter and continuously keep stirring till they resemble one lump.
5. The batter will resemble a dough and will not stick to the sides of the pan. Switch off.
6. When the dough is bearable to touch , grease your hands and roll them into marbles.
7. Heat a vessel with 4 to 5 cups of water.
8. When the water comes to a rolling boil, add the shaped marbles gently into the water.
9. They will first sink and then within minutes, cook and float up.
10. Using a ladle, remove them from water .
Optional step: Once you have boiled the entire batch, heat oil and temper with ingredients given under 'For tempering ".
Serve them hot along with your choice of chutney or sambar.
Alternative method for cooking :
1. Grease a steamer, place the rolled marbles and steam them for 10 -12 minutes.
Tip: I tried both the methods and the taste is the same . The second method is easier.
In fact, this traditional tiffin is delicious to eat as is without any sides. You can have a tall glass of buttermilk along with the Kombu Seedai.
I am sure you are excited to try this tiffin really soon. If you are avoiding rice, you can substitute kodo millet/ varagu arisi instead of white rice and follow the same steps. Do remember to tag me if you tried this recipe. I ground curry leaves and hence the green colour .
Happy Cooking !
With love,


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Top Document: Comp.software-eng FAQ (Part 2): CASE tools summary
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Date: 3 Mar 1997 Originally collected by: firstname.lastname@example.com (Hal Render) Teamwork by Cadre Technologies, Inc (see vendor list). It runs on SUN, ULTRIX, VMS, HP, APOLLO, OS2, etc, with X window support on most of the platforms with more to come soon (including some low-cost PC X emulators. [from firstname.lastname@example.com (Scott A. Trachtenberg)] We have been using for the past few years the following two tools: (Schemacode International Inc (see vendor list)) SCHEMACODE: automatically translates schematic pseudocode design into source code. Works for most programming language except ADA. Available on PC, soon on UNIX. Educational licence 250$ + 50$ per PC. IEEE Computer had a good report on this tool. Sometime last fall. DATRIX: a tool for software quality assessment on PC and UNIX machines. Works for C, FORTRAN and PASCAL. Measures up to 40 metrics and provides a unique representation of the control flow, which is useful for testing, program understanding, and program evaluation. Expensive; educational licence for 500$, including up to 10 workstations. We have been using these tools for the past three years in 4th year undergrad and grad soft.eng. courses Ecole Polytechnique in Montreal. [from firstname.lastname@example.com (P. N. Robillard)] ToolBuilder (formerly TBK) by IPSYS Software Plc (see vendor list). It provides meta-tools (design editors, structure editors) a single underlying ERA database (supporting fine structure) and a uniform UI based on Motif. Tools exist for HOOD (design for Ada). Might have educational discounts. STONE by FZI (see vendor list). (see also archives file "environments") - An SEE for research and education. An OODBS called OBST is used as the core of the environment. OBST is available via anonymous ftp from gate.fzi.de [22.214.171.124]. OBST provides currently an interface to C++. A call interfaces to C is also available, as well as an embedding of OBST into the interactive tool command language TCL. [from Bernhard Schiefer <email@example.com>] Rational Environment by Rational (see vendor list). A tightly integrated, interactive software engineering environment for total lifecycle control of Ada projects. Supports design, development, unit test, maintenance, verification, document generation, configuration management, subsystem tools, incremental compilation. Can also integrate with external front-end CASE tools and external target compilers. [from: Bob Geiger <email@example.com>] Objectory by Objective Systems (see vendor list). An object-oriented Analysis and Design method with supporting CASE-tool. The tool is a multi-user tool with a central repository and includes multiple diagram and documentation techniques, consistency checks, traceability, etc. It covers several models including Requirements, Analysis and Design models and also C++ code generation. The tool runs on multiple platforms. An overview of Objectory can be found in "Object-Oriented Software Engineering - A use case driven approach", by Jacobson et al, published by Addison-Wesley 1992. OOD (see http://www.cs.queensu.ca/Software-Engineering/blurb/OOD.html) by Prof. Taegyun Kim of Pusan University in South Korea. A free tool for educational use, based on Rumbaugh's Object Modeling Technique. Prof. Kim has built it on a SPARC, but it should build on most UNIX systems with X11-R5, Motif-1.2 and a "reasonable" C++ compiler. Bridgepoint (see http://www.cs.queensu.ca/Software- Engineering/blurb/bridgepoint.html) by Objective Spectrum, Inc. (see vendor list). Set of CASE tools for Shlaer-Mellor OOAD (from analysis to code generation). Significantly reduced fees are possible for educational institutions. -- "Yo' ideas need to be thinked befo' they are say'd" - Ian Lamb, age 3.5 http://www.cs.queensu.ca/~dalamb/ qucis->cs to reply (it's a long story...)
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DUBAI,U.A.E., 2014-11-3 — /Travel PR News/ — Emirates SkyCargo, the freight division of Emirates and a global connector of business and trade, has strengthened its operations in central Europe with the recent launch of cargo services to Budapest.
Budapest, the capital of Hungary, has one of the largest economies in central and eastern Europe and becomes the latest trade lane in Emirates SkyCargo's extensive worldwide network of more than 140 destinations.
Emirates' daily flight to the city is operated with a wide-body Airbus A330-200 and offers 168 tonnes of cargo capacity per week. On its first flight into the country, Emirates SkyCargo mainly carried consolidated cargo from the Far East and points in India, including a shipment of pharmaceuticals from Hyderabad.
"Budapest has an excellent geographic location and is a gateway to other central and eastern European logistics centres. The launch of a daily flight to Budapest will give us an expanded footprint in central Europe, and will complement our cargo services into Warsaw, Prague and Vienna. Trucking services can also feed offline markets in the region through Budapest, and onto our flight to Dubai, for further distribution across our network," said Robert Siegel, Emirates Vice President, Cargo Commercial, Europe and Russia.
"This offers a world of new trading opportunities for businesses in Hungary and across our network, especially the automotive industry which accounts for about 18 percent of total exports from the country. We are well positioned to support the export market as we have strong networks in Africa, the Middle East and Asia Pacific. The UAE is also Hungary's largest Arab trading partner with annual trade between the two countries at around US$ 1,2 billion," he added.
Top exports out of Hungary are machinery spare parts, hi-tech equipment and electronics and spare parts for land vehicles – which comprise about 70% of the exports. The remaining 30% are divided among industrial consumables, such as manufactured pipes, semi-manufactured steel and water/air pumps, food and beverage, generators and chemical products. Imports are dominated by semi-conductors, telecommunication devices and components and audio and video products, making up more than 70 percent of the import market.
Emirates SkyCargo is the world's largest international air cargo carrier, offering belly-hold capacity across Emirates fleet of 230 wide body aircraft, 14 of which are freighters.
EK111 departs Dubai at 0820hrs and arrives at Budapest International Airport at 1135hrs. The return flight, EK112 departs at 1505hrs and lands at Dubai International Airport at 2330hrs.


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Personal Campaign
Margaret is gathering 10 pledges to
Demand Waza To $Top $Upporting The Taiji Dolphin Hunt
For two years I have been part of the Facebook page against the killing and capture of dolphins at Taiji. I am appalled and sickened by the brutality of the Japanese who kill and capture the poor dolphins and pilot whales. Please watch The Cove and see what horror takes place at Taiji...then do all that you can to end this atrocity. Dolphins and whales are as intelligent as us...they suffer and die in captivity. After seeing most of their pod brutally slaughtered at Taiji. Please help to stop this. Thank-you.


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A: Most students can walk from one end of campus to the other in under 15 minutes.
The longest hike would be from the Terraces residence halls to the Park School of Communications.
Even though the walk is hilly at times, it is usually quick and easy to get from one place to another on campus.
Are you a prospective student with college planning questions? Then myIthaca has got you covered.Sign-Up Learn More
Fuse is a student produced publication about the Ithaca College experience. All content in the print and web versions of Fuse is developed by current Ithaca College students in a breadth of different areas of study.


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Media Attention Highlights Credit Union MBLs and 2012 Profits
Recent coverage in the Kansas City Business Journal and St. Louis Business Journal highlights the efforts of credit unions – including member business lending (MBL) and 2012 profit and membership growth.
Kansas City Member Business Lending Highlighted
The Kansas City Business Journal article, "Caught in the Middle," focuses on the efforts of credit unions to provide business loans and lift the 12.25% cap currently in place to 27.5% of assets.
Alpha Energy and Electric, Inc. and The Clay Group, two businesses helped by Mazuma Credit Union when banks would not provide the loans they needed, explain the need for more options.
"Our inability to get financing from local commercial banks wasn't from lack of trying," Gabriel Okafor, president of Alpha Energy and Electric Inc., stated in the April 12 article. "They kept saying we didn't have enough history as a company to lend to us. But Mazuma stepped up and was willing to bet on us."
Alpha Energy won the Supplier of the Year Award from the Mid-America Minority Supplier Development Council in March and was named as the Small Business Administration's 2012 Minority Business of the Year for the Kansas City district.
"I'm sure if we went back to those commercial banks now, they might lend to us, but Mazuma helped us when we needed some help, and we feel a need to stick with them and try to help them in return," said Okafor.
St. Louis Credit Unions See Growth in 2012
The St. Louis Business Journal article focused on the 2012 growth of the 25 largest credit unions in the St. Louis region. Overall, these credit unions had a reported combined profit of $47 million, which is an increase of 18 percent from 2011. Loans rose six percent and credit union membership grew more than four percent for a total of 920,000 members.
In the April 19 article, Anheuser-Busch Employees' Credit Union President/CEO Dave Osborn highlighted how the credit union returned $1.2 million to its members in 2012. First Community Credit Union cited fewer delinquent loans and increased loan refinancing as beneficial to the bottom line.
Graphic: Brad Harbold, Kansas City Business Journal
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Texas Chainsaw Massacre On The Big Screen!
Having been a fan of old-school horror films since I was a kid, I was dead chuffed to finally see The Texas Chainsaw Massacre at the cinema today. It was showing as part of Fright Fest at the Empire in Leicester Square.
The only trouble with being a film geek I find, is that I have to do more than my fair share of sitting next to nerdy men with ponytails, beards and Ghostbusters T-shirts, and women with purple hair. Actually I quite like the woman with purple hair (although I'd never stand a chance obviously, as I can't grow a ponytail or a beard).
Anyway, being a true geek, here's a list of some of the other classic horror films I've seen at the cinema:
An American Werewolf in London
The Evil Dead
The Thing
Night of The Living Dead
Dracula (Hammer)
The Shining
Dressed to Kill


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Download Vizcaya to your Kindle!
I've been so busy this past month. I can't wait to upload some of my pictures from my adventures. I've been to new places, learned new things, and have a lot more ideas that I can use for stories. July was great! But now it's August, which aside from being my birth month, is also the month that we completed successfully the Kickstarter for Vizcaya! The journey has been more amazing than I could've imagined, and I'm thankful every day for all the support you guys have given me.
We've had some great reviews start coming in for Vizcaya, so I'm creating a Press page on the site. There I will put links to all the great interviews and reviews that are now on the web. Keep an eye out for it!
Now I'm off to watch the women's gymnastics all around finals. Love the Olympics!


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I'm head over heels in love with the new design for Knittedhome I don't think I'll be able to wait til October to launch it. In fact, my free trial expired on July 18 so I decided to do a "soft launch" first.
And since you are my awesome friends who have been with me on this blog since Knittedhome's inception (Etsy says 2010), I just couldn't imagine not informing you that
is LIVE!
I'm so excited to hear your thoughts + opinions on the new look. You can pop back over here + leave it all in the comment sections of this blog post or email me from the new site. Thank you for all your support!
I promise to get back to regular blog posting soon. I've already started a long list of ideas for my first Winter Collection + I have an email club I'm building to be released this August or September. I can't wait to tell you all about it!
Don't forget to check out the new site; I promise you won't be disappointed! What did you love + hate about? What am I missing for you?


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Brazilian Cheese Bread (also known as Pao de Quiejo) are beautiful cheesy puffs of yumminess that are gluten-free and easy to make with simple ingredients!
My kids go wild for these little cheese treats. Bonus: they are beautifully delicious, and super easy to make.
Pao de Queijo is a Brazilian cheese bread – it is similar to American popovers, except.. they are made with tapioca flour/starch in lieu of regular all purpose flour. Y'all, I love me some popovers, but these are just to die for.
You can find tapioca flour on Amazon for a great price – I would recommend Bob's Red Mill brand. If unable to find tapioca flour, you can also try looking for Arrowroot Flour as that is very similar. Avoid using coconut flour or almond flour – the recipe will not work as those flours are completely different.
I mistakingly tripled this recipe by accident and that was the best thing I could have done! My kids practically inhale them!
Over the last year we have made quite a few gluten-free and grain-free family favorites – Paleo Dinner Rolls, Pan de Yuca (SO good!), and Jalapeno and Squash Bread.
We have even used our garden zucchini to make the best Chocolate Zucchini Bread and Muffins that have no refined sugar and are grain/gluten free.
Brazilian Cheese Puffs
Mix these puffs up in the mixer or the blender. If you opt for the mixer, add the tapioca flour last and 1/2 C. at a time. If you add it too fast or add too much at once, the flour will gum up the blade. And that is quite a mess.
Does it matter what oil you use? You know, I'm going to tell you to stay away from vegetable oil and corn oil and go with a reputable, better extra virgin olive oil if you can.
We use Queen Creek Olive Mill Olive Oil . They are a sustainable olive farm and mill and they produce Arizona's only extra virgin olive oil. (If you aren't in Arizona then opt for a reputable brand at your local market).
Back to our cheese bread …
The batter on these puffs is very liquid. At some point you might even ask yourself if you are doing things correctly because it'll literally be runny batter. If yours is like that, you are on point – don't stop!
Pour that batter into a greased mini muffin pan, filling each cup to the top rim. Pop that in your preheated oven and bake for 14-15 minutes until a light golden brown. As they bake, they will rise just like popovers.
You may be tempted to open the oven in excitement, but please don't do it! If you open the oven door, you will lose that beautiful rise on your puffs!
Despite the battery being very liquid, once they bake up, they will be the most delectable, perfect little cheesy, soft fluffy puffs of yumminess. I promise!
A mini muffin pan works best – but if you are without, then use a larger muffin pan. Just understand that your final count will be significantly less (in which case you may want to double the recipe).
Watch out! Because these cheesy Brazilian Cheese Puffs are so delectable that you will want to eat the entire pan!
A gluten-free cheesy and chewy cheese roll made with Tapioca Flour and commonly served as a breakfast or snack item in Brazil.
- 1/3 C. extra virgin olive oil
- 2/3 C. milk (we used raw)
- 1 1/2 C. tapioca flour
- 1 egg, room temperature
- 1 tsp salt (or more - to taste)
- 1/2 C. grated cheese (we used parmesan)
- 1 Tbsp butter (for greasing the muffin cups)
- Preheat the oven to 400 degrees F.
- Grease your mini muffin pan thoroughly with butter, and set aside.
- In your blender or KitchenAid, combine the milk, room temperature egg, oil, cheese and salt until combined.
- Once combined, add the tapioca flour 1/2 C. at a time until all of the tapioca flour has been added.
- Mix well on high, scraping down the sides of the blender so that everything is easily blended. The batter will be very liquid!
- Pour the batter into your greased mini muffin tin ~ leaving just 1/8 inch of space at the top.
- Pop in the oven for 14-15 minutes or until light golden brown.
Batter can be made ahead of time and kept in the fridge for up to one week.


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Accessory Details
Designed to fill the room with a rich clear sound field that has as much power as it does definition. Intuitive to use with engaging features. (191478)
Compatible Devices
- Left and right channel separation is optimized for a full stereo experience.
- The stereo active 2-way crossover system creates an optimized sound field for dynamic range and clarity across all genres of music. Tweeter and woofer separation uses the same acoustic mechanics found in professional recording studios around the world.
- The Beats Pill+ has a 12-hour battery life to keep the music going all day.
- Use the included Lightning Cable and 12-watt power supply to get a quick charge in 3 hours.
- The fuel gauge gives you easy access to keep track of your power level, so you always know how much battery life is left.
- You can charge your phone or external music device with extra battery life from the Beats Pill+. Use the included Lightning Cable or your USB-A equipped charging cable to charge out to any device. Designed with portability in mind
- With its durable construction, soft-to-the touch finish, and rounded edges, Beats Pill+ is compact and portableso you can bring your sound wherever you go.
- Use the included soft drawstring bag for convenient storage and transportation.
- With the built-in microphone you can make and receive callshands free and with great sound clarity.
- Download the Beats Pill+ app to unlock features that put you and your friends at the center of your music like never before (available on select iOS and Android devices).
- DJ the playlistyou and a friend can control the music from multiple Bluetooth sources.
- Amplify your soundadd a second Beats Pill+ into the mix and simultaneously play from both for a sound that's twice as full.
- Put it in Stereosync two Beats Pill+ speakers together for dedicated left and right playback for an even more dynamic sound experience.


text: On 10 November 2010 22:45, Ken Thomases <ken at codeweavers.com> wrote: > On Nov 10, 2010, at 2:27 PM, Hin-Tak Leung wrote: > >> --- On Wed, 10/11/10, Ken Thomases <ken at codeweavers.com> wrote: >> >>> Are you sure about that? Checking on a couple of >>> Linux systems here, the "locale" command reports: >>> >>> $ locale >>> LANG=en_US.UTF-8 >>> LC_CTYPE="en_US.UTF-8" >>> ... >> >> mine (fedora x86_64) does the utf8 thing: >> >> # locale >> LANG=en_GB.utf8 >> LC_CTYPE="en_GB.utf8" >> ... >> >> so there is some truth in the reporter's assertion - what it means is that it varies between different linux'es!!! > > I should have been clearer. The output just reflects your environment. So, you have LANG set to en_GB.utf8. I had LANG set to en_US.UTF-8. My only point was to say that the "UTF-8" form is acceptable. It was not to suggest that "utf8" is not, nor that one or the other is a standard. > > The real question is: does the Linux C library accept 'UTF-8' in the environment variables? I believe it does, which is useful because that's what Mac OS X requires. (It doesn't accept "utf8".) > > For example, the following reports just fine on some Linux systems here: > > LC_ALL=en_GB.UTF-8 locale > > As does your case: > > LC_ALL=en_GB.utf8 locale > > But the following both produce some diagnostics indicating that the C library is choking on the value: > > LC_ALL=en_GB.bogus locale > LC_ALL=en_GB.UTF-9 locale > > I take this to mean it's a legitimate test of whether a value is valid. Further, it indicates that (at least some) Linuxes take either form. I'm getting the same behaviour (Ubuntu 10.10) -- LC_ALL accepts either utf8 or UTF-8 for en_GB, en_IE, etc. The caveat here is that the primary locale needs to exist (and presumably needs to have a UTF-8 valiant present). That is, as I don't have a French locale (fr_FR) installed on my machine, the following reports errors: LC_ALL=fr_FR.UTF-8 locale This means that systems that don't have the English locale installed (en_US or en_GB, whichever is chosen) will still fail. What is wrong with iterating over the content of `locale -a` or `locale -a | grep -F utf8` to find a UTF-8 based locale? Or even: LC_ALL=`locale -a | grep -F utf8 | head -n 1` sed ... authors.c - Reece


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Hi everyone! Happy Tuesday!
It's time! The INCREDIBLE new MFT Release is available right HERE, right now in the MFT Boutique! Yay!
Tonight I have a card to share with you using the absolutely FABULOUS new Flashy Florals set and Flashy Florals Die-namics, which I've paired with the new Thanks & Hello Die-namics!
I absolutely LOVE these flowers! I LOVE them! I cut them using the Flashy Florals Die-namics from Smooth White Card Stock and then stamped them using Lemon Chiffon Premium Dye Ink, Pineapple Premium Dye Ink, Ripe Raspberry Premium Dye Ink, Pure Plum Premium Dye Ink, Periwinkle Premium Dye Ink and Eggplant Premium Dye Ink. The leaves were stamped using Limelight Premium Dye Ink and Green Room Premium Dye Ink.
The main panel of Kraft Card Stock was cut using Blueprints 13 Die-namics, and I added a strip of patterned paper from the Dots & Stripes Neutral Paper Pack, and then added a strip of silver glitter tape. I arranged the flowers and popped them up with Jody Boosters. I cut "Thanks" from Black Licorice Prestige Card Stock using the Thanks & Hello Die-namics. I coated the "Thanks" with a Clear Wink of Stella Brush Marker. I finished off the card with a trio of enamel dots/rhinestones.
Thanks SO much for stopping by! Please head over to the MFT Blog to check out what the rest of the team has created, and for a chance to win an MFT Gift Certificate!


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About Lemon Lime
Experience Lemon Lime for a fresh, authentic look delivered with caring hands.
We are passionate about creating the right look to complement our guests' personal tastes in a nurturing, caring environment. And for everything you invest in us, we return by committing to give back to the community in meaningful ways. As an Aveda Concept Salon, Lemon Lime offers you an unforgettable experience every time. Look Good. Do Good. This is Lemon Lime.
About C. Adrian Morris
Raised in the salon industry by his hairdresser mother, C. Adrian Morris was quite literally born to be a hairdresser. Apprenticing at the age of 10, resulted in him being mentored by the industry's most talented and respected leaders helping him evolve and become a master of his craft. Adrian has become responsible for creating some of South Shore's most talented stylists by mentoring the next generation.
South Shore readers have agreed by honoring Adrian with the "best color", "best cut" , and "#1 Salon" awards. As South Shore/ Cape Cod's most requested stylist/colorist, Adrian recognizes the value of his community.
Living by his personal motto "Look Good Do Good", Adrian raises hundreds of thousands of dollars for local and national charity's focusing not only in his local communities but specifically the fight against breast cancer. Adrian was instrumental in helping the Learn, Live, Love Cancer Outreach Organization and was presented with an "excellence award" for raising over 100k for men and women over 5 years in 2010.
Continuing his legacy of philanthropy, Adrian raises funds, volunteers and serves on various committee boards:
South Shore Hospital, Dana Farber Cancer Center, Falmouth Hospital, One Mission Kids Cancer Outreach, South Shore Music Circus, South Shore Art Center, Boston Symphony, Atlantic Symphony, Greater Food Bank, Cohasset Greater Education, Cohasset Youth Organizations, Earth Month Leading Salons, Clean Water Act, Sept 11 Tower permanent memorial Falmouth Mass, Friends of Falmouth Animal Shelter, Cotuit Center for the Arts, Boston Specialty and Rehabilitation Center, and Susan G Komen.
Adrian remains true to his passion, guests, industry and all those that create beauty in the industry.