text:
Japanese Woman Exposed
I Did So not know that!: Top 10 Hot Japanese Girls of the decade
We wanted to focus on the superb lives and sheer badassery of historic Japanese women. All these interested in Japanese cultural studies, well-liked culture, literarary studies, gender/sexuality/queer concept, and psychoanalysis. "She's foregrounding the things girls undergo to type of achieve what can be considered to be a socially acceptable appearance," mentioned Kathryn Tanaka, an affiliate professor of cultural and historic research at Otemae University in Nishinomiya. She worries about blind spots among the many mostly male policymakers who're crafting Japan's response to the pandemic. The male lawmakers "know nothing about how ladies are managing child care or housework" with faculties closed and workplace staff working from residence, she mentioned.
They hide their enamel to keep from exhibiting their misaligned and rooting enamel to men. Dental care within the Edo period was non-existent and overlaying the mouth to cover unattractive tooth was frequent and continues https://bestasianwomen.com/japanese-women/ to be a common behavior for Japanese girls throughout that interval. Covering the mouth whereas laughing is an indication a modesty for Japanese girls now, with that very same mindset carried over from the Edo period.
Since Mr Abe came to office in 2012, he has created extra nursery locations and, in last month's basic election, promised free child care. Since last yr huge firms have been required by law to doc their efforts to promote ladies.
Some people give Yoko Ono crap only for being an impartial minded lady. It's exhausting for me as a person of European background residing in Australia to just accept that for some people in Japan Ryo would be thought of by some means lacking simply because of her top and pure skin colour and for not playing the paint and powder game. More power to her and to any woman wherever, not simply in Japan, who do not accept mainstream opinions of "beauty" and comply with their very own path.
Shampoos weren't identified in Japan until trendy instances; in 1932, KAO Cosmetics offered its first shampoo underneath the brand name Kami-arai. With its golden shade and creamy texture, Camellia oil has been the sweetness elixir of Japanese ladies's legendary pores and skin and hair for hundreds of years. Japanese ladies are by much more interested in pores and skin and hair care than color cosmetics and fragrances. According to the study by EU-Japan Center for Industrial Cooperation, skincare and hair care merchandise comprise nearly 2/three of the Japanese cosmetics market. Japanese girls don't need beauty surgical procedure, they're a nice wanting representation of their race, the people of Japan, and the Orient.
Thirteen Japanese women years old have been enrolled as individuals in 2015, then numerous lip area websites had been measured in facial images taken in 1992, 2002, and 2015. The ratios of thickness and width of the lips, and of length of the white higher lip to lip thickness have been determined and in contrast in every. Facial pictures of 139 Japanese ladies ranging from sixteen to seventy eight years old were taken from the entrance as well as lateral view for measuring the lips and surrounding skin area at varied points (Fig. 2). Dryness and chapping are major problems affecting lips, and researchers have been actively learning the perform of the attractive layer as well as differences as in comparison with that of pores and skin.
Confidential Info on Hot Japanese Girls That Only The Authorities Know Occur
When Hashimoto turned pregnant, she was criticized for taking day off to offer start. As a results of her scenario, nonetheless, each chambers of the Diet revised their rules to permit ladies to be absent from public proceedings to have a baby. At the same time, he and the ruling LDP-Komeito bloc steamrolled a bill via the Diet that allows employers to make use of temp employees — of which about 70 % are girls — for so long as they need. Japan ratified the conference in 1985 and a few authorized frameworks had been codified across the similar time. In 1984, the Nationality Law was revised to allow Japanese nationality to be obtained through an individual's mom, whereas an equal employment opportunity legislation was enacted the next year. These developments ultimately led to the adoption of the gender equality legislation in 1999.
Still to today…dental hygiene in Japan continues to be thought of a luxurious, not necessity. For instance, The winner of the Miss Universe would do that nearly every year because she is so shocked to win this prestigious competitors. Japanese girls do that too, so there are some similarities among girls regardless of cultural backgrounds. Even in office buildings, the restrooms are spacious and we regularly see working girls retouching the makeup at lunch break and before leaving within the evening. In contrast with other international locations, there are numerous places in Japanese cities for women to retouch their makeup throughout the day. Department stores and large hotels have a special area within the washroom with large mirrors and stands that allows women to comfortably apply and retouch their make-up to perfection.
The novel explores the extent to which women can get along with out males, especially in the fundamental act of copy. Natsuko, who remains single all through the novel, explores synthetic insemination with a sperm donor, a rare path to motherhood for unmarried ladies in Japan. After Kawakami told The Asahi Shimbun, considered one of Japan's largest newspapers, that girls mustn't have to make use of the word "shujin" — "grasp" — to check with their husbands, critics took concern along with her on social media. In the literary world, too, Japanese women are carving out an increasingly prominent role. "Breasts and Eggs" won the distinguished Akutagawa Prize, and Kawakami has joined a growing listing of Japanese women whose work is being translated and gaining consideration in the West. Though Japan's prime minister, Shinzo Abe, has promoted a platform of female empowerment, the nation has lagged behind different developed nations in ladies's representation in politics, the executive suite and academia.
Now in 2019, we all know she settled in nicely, releasing over seventy five novels and essays over two-plus decades. Writing typically of loss and therapeutic, emphasis is more on how the broken heart heals, one small insight at a time, than on the traumatic event itself. Banana Yoshimoto is maybe considered one of Japan's most properly-identified contemporary authors, as she has been translated for 26 years, beginning along with her smash-hit debut novel Kitchen. What is lesser-known is how the hurricane of consideration surrounding her debut threw her life right into a tail-spin. Author Elizabeth Gilbert speaks of Eat, Pray, Love changing into a worldwide blockbuster and wondering "how in the world I was ever going to put in writing a e-book once more that would ever please anyone." Yoshimoto is aware of the sensation. Growing up in a Japanese family within the US and having lived in Tokyo for 5 years, nonetheless, I'm no expert in 'reading' these emotions.
Moreover, omega-3s may help forestall premature ageing and protect against solar injury, thereby preserving your pores and skin wholesome, glowing and easy. Omega-3s additionally nourish hair at the follicles, which promotes lustre and thickness whereas soothing dryness and flakes that may trigger hair loss.
Such teams are shown all over the country as idols for younger ladies to look as much as. The best girl in Japan has largely been fantasized as a Yamato Nadeshiko. On one hand it is the loving housewife who takes care of the children and does the home tasks, however on the alternative hand it is the lovely, sensible, youthful lady. The narrative follows the stream of consciousness of a young lonely boy who turns into obsessive about the bizarre looking woman who works within the native sandwich store.
Although the legislation is gender-impartial, which means that either spouse is allowed to vary his/her name to that of the other spouse, Japanese ladies have traditionally adopted their husband's household name and ninety six% of girls continue to take action as of 2015. In 2015, the Japanese Supreme Court upheld the constitutionality of the law, noting that girls might use their maiden names informally, and stating that it was for the legislature to decide on whether to pass new laws on separate spousal names. While Japanese ladies's standing has improved in the final many years, traditional expectations for married girls and moms are cited as a barrier to full financial equality. The monarchy is strictly males-only and a princess has to give up her royal status when she marries a commoner. is Japan's first self-made billionaire, having established a recruitment agency referred to as Temp Holdings a number of a long time ago, which focuses on serving to girls to remain in work after having children. is revered for organising Women's Startup Lab primarily based in Silicon Valley, working to advance global opportunities and management coaching for women in the tech startup area.
In 1925, it granted universal manhood suffrage and by 1930 and 1931, the decrease home of the Diet handed bills granting ladies's suffrage at the local stage. However, because the political situation overseas modified dramatically in the 1930s and the Japanese army began a struggle in China, the motion to grant girls's political rights went by the wayside. Women's rights advocates largely supported the state in the course of the interval, hoping that their loyalty would enable them to influence coverage on moms and kids. Although the trendy period brought new alternatives for ladies and new sorts of domination, western visitors to Japan didn't necessarily focus on these shifts. Rather, they tended to seize on the sexualized figures of the geisha and prostitute as representative of all Japanese women. The hole between the precise state of affairs of Japanese ladies and western orientalist fantasies persists to today, as evidenced by the recognition of books like Arthur Golden's Memoirs of a Geisha.


A type of Auto Lamp that used quartz as glass shell and filled with halogen gas gives a very bright light. Principle is inside the halogen bulb such as injection of iodine or bromine, under high temperature, the sublimation of chemistry with halogen tungsten filament, tungsten will be cooled to solidification on tungsten filament, form balanced circle, avoid premature tungsten filament fracture. So halogen bulbs live longer than incandescent bulbs.
The supply voltage of halogen lamp is usually divided into ac 220V and dc 12V and 24V. The halogen lamp is made of tungsten, but it is enclosed in a smaller quartz glass shell. Because the glass is very close to the filament, if it's made by normal glass, it will melt very easily. The gas in the glass is composed of different gases. These gases have a very interesting feature. They are combined with tungsten vapor. If the temperature is not high enough, the halogen gas combines with the tungsten vaporization and redeposition of the filament. This cycle makes the filament can last more time. Halogen bulb is hotter than a normal bulb.
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text: Q: On Goldbach conjecture Let $N$ a large natural number, let $\forall n\leq N,\, R_{2}\left(n\right)=\underset{p_{1}+p_{2}=n}{\sum}\log\left(p_{1}\right)\log\left(p_{2}\right)$ and let $S\left(\alpha\right)=\underset{p\leq N}{\sum}\log\left(p\right)e\left(p\alpha\right)$ where $p,\, p_{i}$ are prime numbers and $e\left(x\right)=e^{2\pi ix}$. We know that $\forall n\leq N$ $$R_{2}\left(n\right)=\int_{0}^{1}S(\alpha)^{2}e(-n\alpha)\textrm{d}\alpha=\left(\int_{\mathfrak{M}}+\int_{\mathfrak{m}}\right)S(\alpha)^{2}e(-n\alpha)\textrm{d}\alpha=$$ $$=R_{\mathfrak{M}}(n)+R_{\mathfrak{m}}(n)$$ where $R_{\mathfrak{M}}(n)$ is the contribution of major arcs and $R_{\mathfrak{m}}(n)$ is the contribution of minor arcs. As major arcs, minor arcs are disjoint $$\mathfrak{m}=\underset{i=1}{\overset{s}{\bigcup}}\mathfrak{m}_{i},\,\mathfrak{m}_{i}\cap\mathfrak{m}_{j}=\textrm{Ø}\, if\, i\neq j$$ say. Suppose that $\overline{\mathfrak{m}}\in\mathfrak{m}$ and suppose that $c\in\overline{\mathfrak{m}}$. I would like to know if it is possible to obtain an estimation like $$\left|\int_{\overline{\mathfrak{m}}}S(\alpha)^{2}e(-n\alpha)\textrm{d}\alpha\right|=\left|\underset{p_{1}\leq N}{\sum}\log p_{1}\underset{p_{2}\leq N}{\sum}\log p_{2}\int_{\overline{\mathfrak{m}}'}e\left(\left(p_{1}+p_{2}-n\right)\left(c+\eta\right)\right)\textrm{d}\eta\right|=$$ $$=\left|\underset{p_{1}\leq N}{\sum}\log p_{1}e\left(p_{1}c\right)\underset{p_{2}\leq N}{\sum}\log p_{2}e\left(p_{2}c\right)\int_{\overline{\mathfrak{m}}'}e\left(\left(p_{1}+p_{2}-n\right)\eta\right)\textrm{d}\eta\right|\ll\left|S\left(c\right)^{2}\right|F(N)$$ where $F(N)=O\left(N^{\delta}\right),\,\delta<1.$ If it isn't possible, which is the best possible limitation for $F(N)$? Thank you.

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Lay people are UMC's foundation: Rockeman answers God
By: Doreen Gosmire, director of communications, Dakotas UMC
Karl Rockeman. Photos by jlynn studios.
"The United Methodist Church is a church of and for the people. The work of the laity is vital. It is not up to the pastor to do everything. It is everybody's responsibility," said Karl Rockman, Dakotas Conference Co-Lay Leader and Dickinson United Methodist Church member.
Rockman grew up attending The United Methodist Church in Donnybrook, North Dakota. He was baptized and confirmed there.
"There were only two churches in town, United Methodist and Catholic. The church was a big part of our community and our lives. First, the high school closed, and then the elementary school. So, everything happened at one of those two churches," said Rockeman.
Lay people were vital to the ministry of Donnybrook UMC. The pastor for the congregation also served United Methodist Churches in three, sometimes four, other communities.
"The pastor had to be in other communities, so lay people had to step up. Lay people led a joint Vacation Bible School with the Catholic church," said Rockeman. "One thing I learned to love about The United Methodist Church was open communion. I knew that was important for my friends in town because that didn't happen at the Catholic church."
As an adult, Rockeman joined The United Methodist Church in Dickinson, North Dakota. He served as the chair of the Administrative Council and Staff Parish Relations Committee.
He provided leadership to build a new church building. A crumbling foundation created a new cornerstone for ministry in Dickinson, North Dakota. Prairie Winds United Methodist Church, known as Dickinson UMC, held worship in a new building on Sunday, September 9, 2018.
Karl Rockeman speaks to the 2022 Dakotas Annual Conference in Bismarck.
In 2021, Prairie Winds UMC disaffiliated from the denomination. Decades of internal division over homosexuality led to the 2019 special General Conference, which ultimately strengthened bans on same-sex weddings and the ordination of "self-avowed practicing" gay clergy. That same legislative assembly approved allowing U.S. churches a time-limited opportunity to leave the denomination under that Book of Discipline provision, Paragraph 2553.
"I found myself for the first time in my life being faced with a decision and making a conscious choice about my membership with a church and denomination. After visiting churches, I found that The United Methodist Church was my home. I value openness. I want to be part of a church where differences of opinions and hot-button issues are not what drives theology or the worshipping community," said Rockeman.
Karl notes percepts of the Moravian Church are part of his faith journey. His parents attended a Moravian Church in western North Dakota. They joined The United Methodist Church in Donnybrook, North Dakota, when their church closed. While attending college in Fargo, he attended Shepard of the Prairie Moravian Church.
"I carry with me a statement that I heard when attending the Moravian Church, 'You don't attend every fight you are invited to.' Hot-button issues have cultural and contextual influence. It is not something that you build your faith around. You pray about the issue, but you do not let it intervene with your faith," Rockeman said.
Rockeman points to the issue of slavery, as an example from the past, that caused denominations to split, but love for all of God's people prevails. "Slavery is one of the issues that split up many churches and denominations. What I love about The United Methodist Church is that love for all people is a foundation. We show our love for God when we love God's people."
Today, Rockeman is part of the newly formed Dickinson UMC that voted to charter. He also is on track to be a Certified Lay Minister (CLM), so he can refine his skills to assist in leading public worship and program leadership for the congregation and throughout the Dakotas Conference.
"Lay people are vital to ministry. If you have a full-time pastor, you can't expect the pastor to do it all. The rural nature of the Dakotas Conference means that many congregations share a pastor or have a part-time pastor. Lay people need to step out of their comfort zone to lead. I see that and find joy in the group of lay leaders at Dickinson UMC," said Rockeman.
The Dakotas Conference of the UMC is committed to equipping and empowering laypersons who have responded to the call of God to serve in mission and ministry. The United Methodist Church has established three categories for laypersons in lay servant ministries to discover, develop, and deploy principled Christian leaders for the mission of making disciples for the transformation of the world: Certified Lay Servant, Certified Lay Speaker, Certified Lay Minister.
Being called to ministry is a serious endeavor. It takes a disciple to make a disciple. Thus, we must do all we can to prepare ourselves and others to serve. We invite you to explore Lay Servant Ministries opportunities! View a video. Download an information sheet.
Next Steps: If you feel a call to ministry, your first step is to register for the two-part discernment retreat, February 4, and March 4, 2023. This introductory course is being led by Rev. Scott McKirdy and Karl Rockeman and will be held in person and via Zoom.
Register here to learn what God has in store for you.

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text:
Reinhard Wrobel (* 1959 in Oberhausen; † Anfang Januar 2006 in Dinkelsbühl) war ein deutscher Theaterschauspieler.

Leben
Wrobel studierte von 1981 bis 1988 Theaterwissenschaften in Erlangen und spielte dort bereits in einer Theatergruppe.

Er debütierte dann am Fränkisch-Schwäbischen Städtetheater (Leitung: Klaus Troemer) in Dinkelsbühl als "Sohn" in Franziskus oder die Lerche Gottes von Karlheinz Komm.

Besonders erwähnenswert ist seine Hauptrolle in Woody Allens Spiel's noch einmal, Sam. Er wirkte vor allem als Komiker, bevorzugt in Loriot-Stücken. Auch in Stücken von Ibsen, Lessing, Moliere, Flotow oder Enzensberger etc. war er zu sehen, auch in Märchen. Ebenso wirkte er in der Uraufführung von Esther Vilars Rotschilds Nachbarn (1990) mit.

Für eine kurze Zeit war er in Trier tätig und auch sieben Jahre bei den Kreuzgangfestspielen in Feuchtwangen bei Lis Verhoeven.

Literatur
 Genossenschaft Deutscher Bühnen-Angehöriger (Hrsg.), Deutsches Bühnen-Jahrbuch 2007, Verlag Bühnenschriften-Vertriebs-Gesellschaft mbH, Hamburg, 2007, Seite 874 f.

Weblinks

Theaterschauspieler
Person (Dinkelsbühl)
Deutscher
Geboren 1959
Gestorben 2006
Mann

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Cline MJ, LaRotonda CJ, Wadhwani R, et al. "Predictors of Adherence to Exercise Goals in Patients with Multiple Sclerosis." International Journal of MS Care. 2006;8(2):50.
Khurana SR, DiGiacomo A, Wadhwani R, et al. "Prevalence of Overweight and Obesity in Veterans with Multiple Sclerosis." International Journal of MS Care. 2006;8(2):59.
Amtmann D, Cook KF, Ehde DM, Johnson KL, Hinton K, Bombardier CH. "Psychometric Evaluation of PHQ9 Using Item-Response Theory." International Journal of MS Care. 2006;8(2):46.


Glass totems or dishes on display, as I call them, are fun to make and brighten any area you put them. They can be used for all sorts of things, including lawn and garden art, birdbaths, fancy candy dishes or candleholders, even, cake stands and planters. One of my favorite hobbies, I hope you find inspiration in this section.


Donnie Dunagan is a hard-nosed Marine, a highly decorated veteran of the Vietnam War who served for a quarter-century. First drafted in the '50s and subsequently promoted 13 times in 21 years — a Corps record at the time, he recalls — Dunagan found the Marines a perfect fit. That is, so long as he could keep a secret.
A dark reminder of the past Dunagan left behind still lurked unspoken: He was Bambi.
As a kid, Dunagan did a brief stint as a child actor, and he was tapped by Walt Disney to be the voice of the lead in the 1942 Bambi, the now-classic animated film about a young deer learning about life in the forest. And not one of his fellow Marines knew.
Now, imagine the man who was once Bambi as a commander in a Marine Corps boot camp, responsible for hundreds of recruits. Dunagan didn't want his recruits drawing any connections, mocking him or calling him "Maj. Bambi." So, he kept his mouth shut.
Of course, it got out eventually. Decades later, a Marine whom Dunagan had worked for several times, twice in combat, called him into his office in the early morning about a month before the two of them retired.
And, finally, the nightmare he'd harbored for years came true.
When Dana asks him how his life is different from the way he might have imagined, Dunagan points out that all the wounds he suffered in service, all the honors he's earned along the way, still haven't changed a thing.
No matter how he tried to escape it, that voice from his past always found him.
Newspaper clippings of young Donnie Dunagan from the early '40s.


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Enriched Meanings
Natural Language Semantics with Category Theory
Ash Asudeh and Gianluca Giorgolo
Oxford Studies in Semantics and Pragmatics
This book develops a theory of enriched meanings for natural language interpretation that uses the concept of monads and related ideas from category theory. The volume is interdisciplinary in nature, and will appeal to graduate students and researchers from a range of disciplines interested in natural language understanding and representation.
Presents a novel approach to natural language interpretation using the concept of monads and category theory
Accompanied by exercises to aid understanding, and online computational tools
Interdisciplinary in nature, with insights from semantics and pragmatics, philosophy of language, psychology, and computer science
Ash Asudeh, Professor, Department of Linguistics, and Director of the Center for Language Sciences, University of Rochester, and Gianluca Giorgolo, Independent Scholar
Ash Asudeh is a Professor in the Department of Linguistics and the Director of the Center for Language Sciences at the University of Rochester. He has previously held positions at Carleton University and the University of Oxford. His research interests include syntax, semantics, pragmatics, language and logic, and cognitive science. He has published extensively on the syntax-semantics interface, particularly in the frameworks of Lexical-Functional Grammar and Glue Semantics, and is the author of The Logic of Pronominal Resumption (OUP, 2012) and, with Joan Bresnan, Ida Toivonen, and Stephen Wechsler, of Lexical-Functional Syntax, 2nd ed (Wiley-Blackwell, 2016).
Gianluca Giorgolo is an independent software engineer based in Modena, Italy. He was previously a Marie Curie Fellow at the University of Oxford, in the Faculty of Linguistics, Philology and Phonetics, a Research Associate at King's College London, and an ERA Postdoctoral Fellow at Carleton University, in the Institute of Cognitive Science. His work has been published in journals such as Semantics and Pragmatics and in the proceedings of conferences on Lexical-Functional Grammar, semantics, and cognitive science
1:Introduction
Part I: Background
2:Enriched meanings in semantics and pragmatics
3:Category theory
Part II: Case Studies
4:Conventional implicature
5:Perspectival reference
6:Uncertainty and conjunction fallacies
Part III: Composition and Interactions
7:Monad combinatorics
8:Conclusion
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CHS Today • September 14, 2021 • https://chstoday.net/3919/uncategorized/new-state-new-school-new-student/
New State, New School, New Student
An avid outdoorsman, freshman Erich Bohn, explores the campus on his first day at CHS.
Alex Hale, Reporter
Erich Bohn is a new Colorado resident. Having moved here in 2019 from Virginia, he started his new Colorado life down in Denver. He lived in a small rental with his family while he finished middle school and his family tried to find a better place to live.
''We were living out of a rental for more than seven months, and the rental was awful," Bohn said.
While he was finishing his middle school experience Bohn's parents went to work to find a better place to live. The school that Bohn was attending was rundown and in the midst of a remodel. However, Bohn's parents set their sights on a house in the mountains.
This new place would need a lot of improvements but they decided to make some renovations.
"It was an older place so we have been working on it, like putting skylights, bookshelves, and those kinds of changes," Bohn said.
With their new location, Erich started his high school career in Conifer.
Although Bohn has had a small amount of experience in Colorado he has already begun to fit in and enjoy the state for what it has to offer. He went on a backpacking trip and has been making new friends in Conifer. He has become a member of the community and a true Coloradan.
"I'd say Colorado is great, but you have to be prepared for anything," Bohn said. "From the heat to the pine needles. This state is treacherous and you have to be ready."


text:
This is a list of blockhouses built by the British Empire in South Africa during the Second Anglo-Boer War from 1899–1901. Of the fortifications constructed during the war, around 441 were solid masonry blockhouses, many of which stand today. Different designs were used in the construction, but most were either two or three story structures built using locally quarried stone.

 Aliwal North Blockhouses (2)
 Broederstroom Blockhouse
 Burgersdorp Blockhouse
 Dewetsville Blockhouse
 Fort Harlech, Krugersdorp
 Hekpoort Blockhouse
 Hopetown Blockhouse
 Kaalfontein/Zuurfontein Blockhouse
 Modder River Blockhouse
 Noupoort Blockhouse
 Orange River Station
 Pampoennek Blockhouse
 Prieska Blockhouse
 Riversford Blockhouse
 The Reservoir Blockhouse
 The Stormberg Junction South Blockhouse
 Timeball Hill Blockhouse
 The Warrenton Railway Bridge Blockhouse
 Warmbaths Blockhouse
 Witkop Blockhouse

See also

 South African Heritage Resources Agency
 South African National Museum of Military History
 Provincial heritage site (South Africa)
 Military history of South Africa
 List of castles in Africa
 History of South Africa
 List of castles
 List of forts

References

Fortifications in South Africa
Castles
South Africa
Second Boer War
Second Anglo-Boer War


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text:
Christina "Tina" Theune (* 4. November 1953 in Kleve) ist eine ehemalige deutsche Fußballspielerin und Fußballtrainerin. Von 1996 bis 2005 war sie Bundestrainerin der deutschen Nationalmannschaft der Frauen, die sie zum Gewinn von drei Europameisterschaften in Folge (1997, 2001, 2005) und 2003 erstmals zum Gewinn der Weltmeisterschaft führte. Nach der Hochzeit mit ihrem ersten Trainer Thomas Meyer trug sie bis zu ihrer Scheidung 2008 den Nachnamen "Theune-Meyer".

Leben, Schule, Ausbildung
Tina Theune stammt aus einer Pfarrersfamilie am Niederrhein und wuchs im alten Pfarrhaus auf Schenkenschanz auf. Als ihr Vater 1955 zum Pfarrer der evangelischen Flüchtlingsgemeinde berufen wurde, zog sie mit ihren Eltern nach Kevelaer. Dort verbrachte sie gemeinsam mit vier Schwestern ihre Schulzeit bis zum Abitur.

Schon früh entwickelte sie eine Begeisterung für den Sport, die sie zunächst als Straßenfußballerin bzw. Turnerin und Leichtathletin beim KSV Kevelaer auslebte. Vereinsfußball spielte sie von 1974 bis 1986 beim SV Grün-Weiß Brauweiler. In dieser Zeit war sie zeitweise auch als Spielertrainerin aktiv.

Mit der Frauen-Auswahl des FV Mittelrhein gewann sie 1981 den ersten DFB-Länderpokal, der zur Sichtung von Spielerinnen für die DFB-Auswahl eingeführt wurde.

Im Rahmen ihres Diplomstudiums im "Sonderfach Fußball" an der Deutschen Sporthochschule in Köln (DSHS) von 1972 bis 1976 erwarb sie die Trainer-B-Lizenz (heute B+-Lizenz). Ihr Dozent war der damalige Leiter der Fußball-Lehrer-Ausbildung Gero Bisanz. Auf ihrem Ausweis, der im Deutschen Fußballmuseum ausgestellt ist, wurde vermerkt: "Weiblicher Trainer Nummer 1".

1982 erwarb sie unter Lehrgangsleiter Holger Osieck die A-Lizenz und übernahm als Honorartrainerin des FV Mittelrhein die Förderung der Juniorinnenauswahl. 1985 wurde sie als erste Frau in Deutschland zur staatlich geprüften Fußball-Lehrerin ausgebildet. Das seit 1998 von der UEFA anerkannte Diplom ist die höchste Ausbildungsstufe für Trainer im professionellen Weltfußball.

Positionen und Aufgaben als DFB-Trainerin
Im Oktober 1986 engagierte der DFB Tina Theune als Assistenz-Trainerin der Frauen-Nationalmannschaft. Eine Festanstellung erhielt sie nach dem Gewinn der Europameisterschaft 1989. Von 1990 bis 1996 war sie neben ihrer Co-Trainerinnen-Tätigkeit unter Gero Bisanz auch verantwortlich für den Aufbau der U 16- und U 19-Juniorinnen-Nationalmannschaften.

Im August 1996 löste sie Gero Bisanz als Bundestrainerin der Frauen-Nationalmannschaft ab und behielt gleichzeitig die Verantwortung für die U21-Frauen bis zum August 2005. Nach dem Gewinn der Weltmeisterschaft 2003 und der dritten Europameisterschaftstitel in Folge 2005 übergab Tina Theune das Amt an Silvia Neid.

Anschließend arbeitete sie beim DFB bis 2019 als Expertin für den Frauen- und Mädchenfußball. In ihren Aufgabenbereich fielen u. a. die Koordination bzw. die sportliche Leitung der Talent- und Eliteförderung einschließlich der Dualen Karrieren im Frauen- und Mädchenfußball und die Organisation von Fortbildungen für Trainer der Frauen-Bundesligen.

Während dieser Zeit war sie Mitglied in verschiedenen Arbeitsgruppen und Kommissionen des DFB und DOSB. 2006 wurde sie in das "Sport-Kompetenz-Gremium" unter der Leitung von Oliver Bierhoff berufen. Von 2013 bis 2019 war sie Mitglied des Lehrstabs Trainerausbildung. Vom DOSB wurde sie zur Neustrukturierung des deutschen Leistungssports und der Spitzenförderung in die Kommission Leistungssport berufen. 2020 arbeitete sie im Gemeinschaftsprojekt "Zukunft" von DFB und DFL mit.

Seit 2011 ist sie Botschafterin und seit 2013 Mitglied des Kuratoriums der DFB-Stiftung Sepp Herberger.

Engagement auf nationaler und internationaler Ebene
Für den DFB nahm Tina Theune seit 2006 verschiedene Funktionen auf nationaler und internationaler Ebene wahr.

Bis 2010 war sie Mitglied der FIFA-Kommission zur Organisation der Olympischen Spiele und bis 2012 Mitglied der FIFA Technical Study Group zur Entwicklung des Welt-Frauenfußballs. Von 2010 bis 2018 übernahm sie beim DFB die Leitung für das UEFA-Studiengruppenprogramm zum Austausch der weiblichen Elite- und Spitzenförderung europäischer Nationen.

Beim Jubiläumsspiel anlässlich des 100-jährigen Bestehens der FIFA im Mai 2004 in Paris betreut die Weltmeistertrainerin die DFB-Frauen gegen die FIFA Women's World Stars. Im April 2007 wurde sie gemeinsam mit Hope Powell als Trainerin der FIFA Women's World Stars berufen, die im Rahmen der der Gruppenauslosung zur WM 2007 auf die chinesische Frauen-Nationalmannschaft traf.

Tina Theune wurde 2002 aufgrund ihrer Verdienste das Bundesverdienstkreuz verliehen. Wegen ihres sportlichen Engagements wurde die Diplom-Sportlehrerin Ende 2006 vom Deutschen Staatsbürgerinnen-Verband zur Frau des Jahres 2006 gewählt. 2019 wurde sie als Trainerin der Gründungself in die Hall of Fame des deutschen Frauenfußballs aufgenommen.

Tina Theune ist die Schwester der Archäologin und Universitätsprofessorin Claudia Theune.

Erfolge (als Spielerin)
 1981 Gewinn des ersten DFB-Frauen-Länderpokals (FV Mittelrhein)
 1982 Winner of the first Canadian National Jubilee Championship Trophy als Gastspielerin der Edmonton Angels

Erfolge (als Trainerin)
 Weltmeister 2003 (sowie Vizeweltmeister 1995 als Co-Trainerin)
 Europameister 1997, 2001, 2005 (sowie 1989, 1991, 1995 als Co-Trainerin)
 Olympische Bronzemedaille 2000, 2004
 U19-Weltmeister 2004 (als Co-Trainerin von Silvia Neid)

Auszeichnungen
 1985 Preis des Kultusministers des Landes Nordrhein-Westfalen
 1987 Ehrenmitglied beim SV Grün-Weiß Brauweiler
 Mitglied der Mannschaft des Jahres 1989 (TED Wahl während der ARD-Gala)
 2002 Bundesverdienstkreuzes am Bande in Anerkennung der um Volk und Staat erworbenen Verdienste
 2003 Mitglied der Mannschaft des Jahres (gewählt von der Sport-Korrespondenz)
 2003 Mitglied "Team of the Year" (United States Sports Academy Award)
 2003 Medienpreis Bambi als Mitglied der Frauen-Nationalmannschaft
 2003 Große Sportplakette der Stadt Frechen
 2004 Ehrenring Rhein-Erft-Kreis
 2006 Wahl zur "Frau des Jahres" vom Deutschen Staatsbürgerinnen-Verband
 2007 Berufung zur Trainerin "FIFA Women's World Stars" gemeinsam mit Hope Powell (England) im Rahmen der Auslosung zur FIFA WM 2007
 Oktober 2019: Aufnahme in die Hall of Fame des deutschen Fußballs als Trainerin der "Gründungself"
 November 2019: "Lotte Ehrenpreis" als Würdigung für die Lebensleistung

Soziales Engagement
 Botschafterin und Mitglied im Kuratorium der Sepp Herberger Stiftung seit 2013
 Botschafterin der FIFA Weltmeisterschaft 2006 für Menschen mit Behinderung
 Patin des Marie-Curie-Gymnasiums in Hohen Neuendorf seit 2006 (gemeinsam mit Shary Reeves) und Patin des Kardinal-von-Galen-Gymnasiums Kevelaer seit 2019; beide Schulen wurden als "Schule ohne Rassismus - Schule mit Courage" ausgezeichnet.

Weblinks, Einzelnachweise

 Redaktionsmitglied der Zeitschrift "fußballtraining" von 1988 bis 2001 mit Beiträgen zum Frauen- und Mädchenfußball bis 2005
 Interview im Buch "Die Weltmeister" von Horst Hamann: "Toni Turek, Du Fußballgott"
 Erzählung über die "Deutschen Fußball-Weltmeisterinnen von 2003" in Sarah Wiener's Kochbuch "Gerichte, die die Welt veränderten"
 Beitrag des DFB aus der Serie zum 50 Jahre-Jubiläum des Frauen-Fußballs: "Magische Momente"
 Artikel zum DFB-Abschied von Tina Theune: "Theune verlässt den DFB: Danke Tina!"

Fußballweltmeister (Nationaltrainer)
Fußballspieler (1. FC Köln)
Fußballnationaltrainer (Deutschland)
Person (Kleve)
Träger des Bundesverdienstkreuzes am Bande
Träger des Silbernen Lorbeerblattes
Deutscher
Geboren 1953
Frau
Fußballeuropameister (Nationaltrainer)
Mitglied der Hall of Fame des deutschen Fußballs


Since October is Breast Cancer Awareness Month around the world, and September the Gynaecological Cancer Awareness Month, two major events in Cairo – one yet to take place on 27 October – will shed light on the various types of cancer mostly affecting women.
October in Egypt has over the years become synonymous with hope for cancer victims undergoing treatment. An instantly-successful tradition begun some years ago aiming to spread awareness, highlight accounts of bravery and share success stories, has seen October host a plethora of events and campaigns focussing on breast cancer.
Breast cancer – which, according to the National Cancer Institute, accounts for up to 38 percent of all cancer cases in Egypt – enjoys the lion's share of media highlight, although it is but one of the different cancers that hit women.
Under the leadership of its chairman Dr Mohamed Shaalan, the BCFE decided this year to shed light on the less common, though nonetheless serious, types of cancer that women suffer from, and to do so by adding doses of fun to its awareness-raising activities.
This year, an early start of events was scheduled on 28 September.
Zumba professional instructors rocked the ladies-only audience of their "Third Party for the Cure" held in Zamalek's Marriott Hotel, with the participation of enthusiasts and prominent figures as in previous years. Raffles and an interactive awareness session were also part of the programme.
On the same day, a walk and a run were held under the title "Globeathon Egypt: the walk to end women's cancers" in participation with Cairo Runners.
At the Equestrian Club, also in Zamalek, a horse jumping show and a live music performance were also included in the event. One of the highlights of the day was the participation of star comedian Samir Ghanem and singer Salma Sabbahi.
On 27 October, BCFE will collaborate with the Arab Contractors Rowing Club to host "Pink on the Nile," the sequel to last year's successful event by the same title.
Last year's crowd, joined by singer Samo Zein and presenter Maha Bahnasi, witnessed the first "Row for the Cure." This year's event will raise public attention by including a sailing boat smoothly floating across the Nile throughout the day with pink ribbons on its large sail. Forty rowers will then compete in a race.
"Row for the Cure" has been held yearly in Germany and the United States since 1994, following rower Kathy Fredrick's idea of a method by means of which the rowing community can extend support and solidarity, as well as raise funds, for breast cancer patients.
The BCFE's Shaalan believes that everyone has the capacity to join the fight, and show solidarity -- either by spreading knowledge about the disease, encouraging others for early screening, or helping underprivileged women through donations that can allow them, too, to obtain screening and treatment.


It is our policy to maintain a well regulated public facility, operated with emphasis on the safety and good conduct of our patrons. Our rules and regulations are firmly and fairly enforced. Because of the normal risk of maintaining balance on skates, and the probability of occasional contact between skaters, accidents can and do happen. You must voluntarily assume the risk of injury when you skate. By entering our building you agree to abide by all rules and regulations.
Toe stops or dance plugs are required for skates.
To prevent damage to our floor, your personal skates are subject to inspection. Be prepared to rent if your skates are dirty or damaged.
No smoking in the building, and no smoking on the property by a minor. Including e-cigarettes.
No gum chewing in the building by anyone.
No In and Out privileges.
No intoxication of any kind.
No food or beverage may be brought in to the building, with the exception of a store bought birthday cake with a scheduled party package.
We charge admission for everyone entering the building, with the exception of children under 2, and parents who are not skating.
Keyed lockers are available. Coats and shoes are not permitted in the Snack Bar area. We are not responsible for lost or stolen item.
Foul language will not be tolerated and will result in expulsion from the rink.
Caution! We use a water-based fog system and special effect lighting including strobe lights.
Neatness and cleanliness of all patrons is required. No clothing that could be considered distasteful to our family environment will be allowed.
No bare feet. Socks are required for skate rental. We do have socks for sale.
Hats, scarves, bandannas, or headwear may be worn when skating but must be tight fitted. Helmets are permitted.
No loose clothing that might get caught in the wheels, or trip the skater. Clothing must be proper fitting.
Anyone who does not practice safe skating may be asked to leave.
No pushing, tripping or playing tag.
No fast skating, faster than the average flow of traffic, and in a manner hazardous to other skaters.
No squatting except during a designated special skate.
No stopping along the wall. Skaters must attempt to keep moving at all times.
No eating or drinking over the half wall surrounding the skating surface, or on the skating floor.
No sitting on or climbing over the half wall surrounding the skating floor.
No climbing or sitting on the corner stages.
Jumps, spins, or dancing are to kept to the center of the floor, and at the discretion of management.
Prices and times are subject to change without notice. Final interpretation of rules and regulations is made by management. We gladly accept VISA, Mastercard, American Express, Discover, cash.


I was happy to have borrowed this book from the library - Cakes & Bakes, published by Parragon Books Ltd. The recipes in the book looked simple and good. Therefore, I was tempted to try it last night. I decided on Ginger (Topped) Fingers. Instead of adding the toppings, I left the shortbread as it is. It was crispy and fragrant. However, it was also very crumbly.
My colleagues tried them and commented that they will be good as cheesecake base. I also agree. Therefore, the next time when I bake cheesecake, I will likely use this shortbread as the base. Try it and you know what I meant.
Recipe for Ginger (Topped) Fingers or Shortbread, extracted from Cakes & Bakes.
1. Preheat the oven to 180C. Grease a 9" round tart pan.
2. Sift the flour, ground ginger and cinnamon into a bowl and stir in the sugar.
3. Rub in the butter until the mixture begins to stick together.
4. Press the mixture into the prepared tin and smooth the top with a palette knife.
5. Bake in the preheated oven for 40mins, or until very lightly browned.
1. Place the syrup and butter in small suacepan over a low heat and stir until melted.
2. Stir in the icing sugar and ginger.
3. Remove the shortbread base from the oven and pour the topping over it while both are still hot.
4. Leave to cool slightly in the tin, then cut.
5. Transfer to wire racks to cool completely.
I love ginger and having this in a shortbread would definitely be wonderful.Thanks for sharing!
Oh I can try this for my X'mas gathering..:) Thanks!


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BR Home Page > MLB Players > M Listing > Hank Majeski Statistics and History
Hank Majeski
Positions: Third Baseman and Second Baseman
Born: December 13, 1916 in Staten Island, NY us
Died: August 9, 1991 in Staten Island, NY
Buried: Cremated
High School: Curtis HS (Staten Island, NY)
Debut: May 17, 1939 (Age 22-155d, 6,991st in MLB history)
vs. CIN 1 AB, 1 H, 0 HR, 1 RBI, 0 SB
vs. DET 0 AB, 0 H, 0 HR, 0 RBI, 0 SB
Full Name: Henry Majeski
Nicknames: Heeney
Hank Majeski Overview
More Majeski Pages
More Hank Majeski Pages at Baseball Reference
Hank Majeski page at the Bullpen Wiki
19 BOS-min D 122 482 482 176 42 11 26 .365 .365 .660 1.025 318 EAU · NORL
20 CHC-min B 105 403 403 139 20 15 9 .345 .345 .536 .881 216 MOL · IIIL
21 CHC-min A1 151 560 560 182 38 11 4 .325 .325 .454 .779 254 BIR · SOUA
22 BSN NL 106 394 367 35 100 16 1 7 54 2 18 30 .272 .310 .379 .689 91 139 10 2 7 5
23 NYY-min AA 105 375 375 121 15 4 17 .323 .323 .520 .843 195 NWK · IL
23 BSN NL 3 3 3 0 0 0 0 0 0 0 0 0 .000 .000 .000 .000 -100 0 0 0 0
24 NYY-min AA 113 489 446 74 135 16 2 14 82 2 37 37 .303 .364 .442 .806 197 6 0 NWK · IL
24 BSN NL 19 56 55 5 8 5 0 0 3 0 0 1 13 .145 .161 .236 .397 14 13 0 0 0 0 5
25 NYY-min AA 151 637 574 112 198 31 6 15 121 10 4 57 38 .345 .407 .498 .905 286 13 3 3 NWK · IL
Did not play in major or minor leagues (Military Service)
29 TOT AL 86 305 276 26 67 14 4 1 25 3 2 26 16 .243 .310 .333 .644 81 92 7 1 2 6 5
29 NYY AL 8 12 12 1 1 0 1 0 0 0 0 0 3 .083 .083 .250 .333 -10 3 0 0 0 0 /5
29 PHA AL 78 293 264 25 66 14 3 1 25 3 2 26 13 .250 .320 .337 .657 85 89 7 1 2 6 5
30 PHA AL 141 546 479 54 134 26 5 8 72 1 0 53 31 .280 .358 .405 .763 111 194 18 5 8 11 *5/64
31 PHA AL 148 645 590 88 183 41 4 12 120 2 1 48 43 .310 .368 .454 .822 117 268 19 6 2 2 *5/6 MVP-11
32 PHA AL 114 487 448 62 124 26 5 9 67 0 1 29 23 .277 .326 .417 .744 99 187 18 4 6 4 *5
33 CHW AL 122 467 414 47 128 18 2 6 46 1 4 42 34 .309 .377 .406 .783 103 168 15 3 8 2 *5
34 TOT AL 101 400 358 45 101 23 4 5 48 1 2 36 24 .282 .351 .411 .762 105 147 10 2 4 2 5
34 CHW AL 12 36 35 4 9 4 0 0 6 0 0 1 0 .257 .278 .371 .649 76 13 1 0 0 0 /5
34 PHA AL 89 364 323 41 92 19 4 5 42 1 2 35 24 .285 .358 .415 .773 108 134 9 2 4 2 5
35 TOT AL 70 201 171 21 46 4 2 2 29 0 1 26 17 .269 .369 .351 .720 99 60 11 1 3 0 5/4
35 PHA AL 34 139 117 14 30 2 2 2 20 0 1 19 10 .256 .365 .359 .724 97 42 7 1 2 0 5
35 CLE AL 36 62 54 7 16 2 0 0 9 0 0 7 7 .296 .377 .333 .710 105 18 4 0 1 0 5/4
36 CLE AL 50 55 50 6 15 1 0 2 12 0 0 3 8 .300 .352 .440 .792 115 22 1 1 1 0 4/57
37 CLE AL 57 129 121 10 34 4 0 3 17 0 0 7 14 .281 .320 .388 .709 92 47 5 0 1 0 1 45
38 TOT AL 52 102 89 5 16 3 0 2 8 0 0 10 7 .180 .275 .281 .555 51 25 3 2 0 1 1 5/4
38 CLE AL 36 59 48 3 9 2 0 2 6 0 0 8 3 .188 .322 .354 .676 79 17 2 2 0 1 0 /54
38 BAL AL 16 43 41 2 7 1 0 0 2 0 0 2 4 .171 .209 .195 .404 14 8 1 0 0 0 1 /54
1069 3790 3421 404 956 181 27 57 501 10 11 299 260 .279 .342 .398 .740 100 1362 117 27 42 1 29
162 574 518 61 145 27 4 9 76 2 45 39 .279 .342 .398 .740 100 206 18 4 6
PHA (6 yrs)
604 2474 2221 284 629 128 23 37 346 7 7 210 144 .283 .350 .412 .762 106 914 78 19 24 25
179 305 273 26 74 9 0 7 44 0 0 25 32 .271 .338 .381 .719 97 104 12 3 3 1 1
BSN (3 yrs)
128 453 425 40 108 21 1 7 57 2 0 19 43 .254 .289 .358 .647 80 152 10 2 7 0
CHW (2 yrs)
134 503 449 51 137 22 2 6 52 1 4 43 34 .305 .370 .403 .773 101 181 16 3 8 2
NYY (1 yr)
8 12 12 1 1 0 1 0 0 0 0 0 3 .083 .083 .250 .333 -10 3 0 0 0 0
BAL (1 yr)
16 43 41 2 7 1 0 0 2 0 0 2 4 .171 .209 .195 .404 14 8 1 0 0 0 1
941 3337 2996 364 848 160 26 50 444 8 11 280 217 .283 .349 .404 .753 103 1210 107 25 35 1 29
Mike Bresina sponsor(s) this page.
8-03-36: Hank Majeski of Eau Claire had seven hits in seven times at bat (3 singles, 2 doubles, a triple and a home run). Also in the game, Eau Claire had 34 hits which became the all-time league record.
8-31-36: Cal Lahman held on to the batting leadership with a .409 average and he was followed by Hank Majeski at .373. Ralph Waldo led pitchers with a 13-6 record and Henry Ruffing was 18-9.
8-02-53: Hank Majeski, who was a Cleveland infielder and began his career in Eau Claire in 1935, was honored in a special ceremony at the Bears' park (Carson Park) for his election to the Eau Claire Baseball Hall of Fame.
A history of the Sports Reference Sponsorship System
You are here: BR Home Page > MLB Players > M Listing > Hank Majeski Statistics and History


text:
Brief Case | March 2019
Individual case: Drug reaction with eosinophilia and systemic symptoms
A patient with fever and rash during treatment for orbital cellulitis and cavernous sinus thrombosis.
By Juan Alban, ACP Medical Student Member; Sarah Saleemi, MD, ACP Resident/Fellow Member; Timothy Sita, MD, PhD; Tristan Bice, MD, ACP Resident/Fellow Member; Lily Rotman, MD, ACP Resident/Fellow Member; and Ryan Bolton, MD
Physician editor: Christopher Sankey, MD, FACP
Deputy physician editor: Thomas C. Kingsley, MD, MPH, ACP Member
The patient
A 39-year-old man was admitted with fever and rash. He had been recently hospitalized for orbital cellulitis and cavernous sinus thrombosis and discharged on IV vancomycin. He was on the third of six planned weeks of antibiotic therapy at the time of re-presentation. At this time, he reported two weeks of fevers, conjunctival injection, and nasal erythema. Initial vital signs included a fever to 38.7 °C and tachycardia. Skin examination revealed a diffuse maculopapular rash on his nose, trunk, and arms. Labs were notable for an alanine aminotransferase level (ALT) of 300 U/L (reference range, 40 to 125 U/L), an aspartate aminotransferase (AST) level of 170 U/L (reference range, 40 to 125 U/L), an international normalized ratio of 1.9 (reference range, 0.9 to 1.2), and a vancomycin level in the desired range. The patient's complete blood count showed no leukocytosis, but an absolute eosinophil count of 800 cells/µL (reference range, 0 to 500 cells/µL) was noted. Vancomycin was withdrawn and replaced with daptomycin. Within 24 hours, his fevers resolved and the rash was notably improved. AST and ALT levels decreased at approximately 200 U/L per day. He was discharged from the hospital and subsequently lost to follow-up.
The patient was diagnosed with drug reaction with eosinophilia and systemic symptoms (DRESS). DRESS is a hypersensitivity syndrome triggered by drug exposure and is thought to be mediated by drug-specific T-lymphocytes. DRESS classically entails rash, fever, lymphadenopathy, and organ dysfunction. It typically takes two to six weeks following drug exposure for symptoms to manifest. Patients can experience erythema over greater than 50% of the body surface area; it is often noted initially on the face, upper trunk, and extremities. Involvement of at least one internal organ occurs in approximately 90% of cases, with the liver being the most common (60% to 80% of cases), typically demonstrating hepatocellular involvement with ALT levels twice the level of normal. Kidneys (10% to 30%) and lungs (5% to 25%) are also commonly affected. When the diagnosis is unclear, a skin biopsy may be helpful. Leukocytosis, eosinophil count greater than 700 cells/µL, and atypical lymphocytosis are also commonly noted.
Antiepileptic agents and allopurinol are the most common causative agents of DRESS. Antibiotics, including vancomycin, dapsone, and minocycline, are also commonly implicated. Treatment of DRESS includes withdrawal of the offending drug and supportive care. Skin involvement is often treated with topical corticosteroids. High-dose systemic corticosteroids can be used for severe renal (creatinine level >150% of baseline, presence of hematuria or proteinuria) or pulmonary (dyspnea or hypoxemia) dysfunction. Recovery can take up to nine weeks, although severe cases can persist for months with a relapsing and remitting course.
DRESS syndrome is an uncommon but potentially life-threatening diagnosis in patients who present with skin changes, fever, lymphadenopathy, and organ dysfunction following a recent medication change.
Treatment of DRESS includes withdrawal of the offending drug and initiation of supportive care; high-dose systemic corticosteroids can be used for severe organ dysfunction.
Mr. Alban and Drs. Saleemi, Bice, and Bolton are affiliated with the University of Illinois Hospital and Dr. Sita is affiliated with Northwestern University Medical Center, all in Chicago. Dr. Rotman is affiliated with Massachusetts General Hospital in Boston.
Other cases in this issue
Cases from Oregon Health & Science University
Bonus online case: Cytomegalovirus immune recovery uveitis in AIDS
Hospitals changing practices to curb opioid epidemic
By Alicia Gallegos
By Jay Brahmbhatt, MD, ACP Resident/Fellow Member
Fighting resistance in the ICU


First cut the chicken breast into small bite the sized pieces season it with taco seasoning mix, chili powder, garlic , some salt and pepper. Heat the oil in a large saucepan over medium heat. Add the chicken to the skillet and stirring occasionally until golden about 6 minutes. Add garlic powder, salt and pepper and cook about 1 more minute, then transfer to a large bowl.
Cut each quesadilla into triangle.
2 ripe plum tomatoes and finely chopped.
2 jalapeno, seeded and finely chopped.


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These one bedroom cottages offer partial views of the Pacific Ocean. Guests can enjoy the glow of a fireplace in the separate living room along with the convenience of a fully equipped kitchen area.
The One Bedroom Cottages provide a wonderful space in which to retreat at the end of a long day of exploring the San Diego area attractions and offer a fully equipped kitchen area along with a separate bedroom with a King bed.
With partial views of the Pacific Ocean to the west and the Torrey Pines to the north, this two bedroom cottage provides ample space with a full kitchen and dining nook and two separate bedrooms.
Located along the village side of the property, these two bedroom cottages offer a fully equipped kitchen and convenient access to everything that downtown La Jolla has to offer.


text:
Civil Procedure & Federal Courts Blog
Further Wal-Mart Commentary
By Civil Procedure & Federal Courts Blog
I have written a slightly longer opinion piece about Wal-Mart for the Westlaw Class Action Journal entitled The New Commonality: Rule 23(a)(2) After Wal-Mart v. Dukes. It's behind a paywall, but can be accessed here or at the citation 18 No. 9 Westlaw Journal Class Action 2.
RJE
October 31, 2011 in Class Actions, Recent Decisions, Recent Scholarship | Permalink | Comments (0)
Resnik on AT&T v. Concepcion, Wal-Mart v. Dukes & Turner v. Rogers
Prof. Judith Resnik (Yale) has posted on SSRN Fairness in Numbers: A Comment on AT&T v. Concepcion, Wal-Mart v. Dukes, and Turner v. Rogers, 125 Harv. L. Rev. 78 (2011). Here's the abstract:
Can eighteenth-century constitutional commitments that "courts shall be open" for private rights enforcement be coupled with twentieth-century aspirations that democratic orders provide "equal justice under law"? That question sits at the intersection of three cases, AT&T v. Concepcion, Wal-Mart v. Dukes, and Turner v. Rogers, decided in the 2010 Supreme Court Term. In each decision, Justices evaluated the fairness of particular procedures (class arbitrations, class actions, or civil contempt processes) when making choices about the meaning of governing legal regimes — the Federal Arbitration Act (FAA) and state unconscionability doctrine in AT&T; Rule 23 and Title VII in Wal-Mart; and the Due Process Clause and child support obligations in Turner.
AT&T and Wal-Mart presented related questions about how the form of dispute resolution (individual or aggregate) and the place of dispute resolution (public or private, state or federal) affect the level of public regulation of consumer and employment transactions predicated on boilerplate, rather than negotiated, terms. The issue in Turner was whether state-funded lawyers were required before a person could, at the behest of the child's custodian, be incarcerated for contempt for failure to pay child support. The specific case involved two individuals, but their circumstances illustrated the challenges faced by millions of other lawyer-less litigants in state and federal courts.
Each case exemplifies the challenges that new rights, produced by twentieth-century social movements, pose for courts. When claimants such as consumers, employees, and household members presented themselves as entitled to equal treatment, jurists responded by interrogating their own procedural parameters. Relying on the Due Process Clause, courts developed distinct lines of analyses that — depending on the context — imposed criteria on decisionmaking procedures, mandated subsidies to address resource asymmetries between adversaries, shaped processes to reduce intra-litigant disparities, and facilitated access to courts. Requisite to those efforts was a practice that is intertwined with fairness — the public quality of adjudication that endows an audience with the authority to watch, critique, and respond through democratic channels to the legal norms announced. A "fair and public hearing" became a touchstone of what democratic orders required their courts to provide.
But, as this trio of cases demonstrates, whether seeking to implement those egalitarian aspirations or simply to function, courts have to grapple with economically disparate claimants and a vast volume of eligible rights holders. If eighteenth-century constitutional entitlements to open courts are to remain relevant to ordinary litigants, the question is not whether to aggregate, subsidize, and reconfigure process but how to do so "fairly," in terms of what groups, which claims, by means of which procedures, and offering what remedies. But without public disclosures and oversight of dispute resolution — in and out of court, single file and aggregated — one has no way to know whether fairness is either a goal or a result.
--A
October 31, 2011 in Recent Scholarship | Permalink | Comments (0)
Sossin on Class Actions Against the Crown
Lorne Sossin (York University - Osgoode Hall Law School) has posted Revisiting Class Actions Against the Crown: Balancing Public and Private Legal Accountability for Government Action to SSRN.
Five years ago, I began to notice a trend toward more numerous and wide ranging class actions against the Crown, seeking redress for state action against those claiming they were especially harmed by that action. Some of these class actions – for example, seeking remedies for the Crown's role in the SARS or Mad Cow outbreaks – sought billions of dollars of damages. Many of these class actions, in my view, involved the review of ministerial decision-making and could have been framed as judicial reviews in the conventional administrative law sense. Was the incentive for mass recovery and soaring contingency fees driving more lawyers to frame unfair or unreasonable government decisions as violating tort and contract standards? Was I witnessing another dimension of access to justice and progressive behaviour modification through class actions, or alternatively, did this trend represent a distortion of public accountability through private claims?
October 28, 2011 in Class Actions, Recent Scholarship | Permalink | Comments (0)
Whales as Plaintiffs?
People for the Ethical Treatment of Animals (PETA) is reportedly filing a lawsuit today in federal district court in San Diego against SeaWorld, seeking a declaration that the five killer whales that perform at SeaWorld's San Diego and Orlando parks are being held as slaves in violation of the Thirteenth Amendment to the United States Constitution.
The five plaintiffs are anticipated to be Corky, Kasatka, Ulises, Tilikum, and Katina.
For further details see the story at Signonsandiego.com here.
--PHM
October 26, 2011 in In the News | Permalink | Comments (0)
Conference at New York Law School on Summary Judgment, Iqbal, and Employment Discrimination on April 23, 2012
New York Law School Law Review has announced the following symposium:
The New York Law School Law Review and The Employee Rights Advocacy Institute For Law & Policy ("The Institute") are pleased to present Trial by Jury or Trial by Motion? Summary Judgment, Iqbal and Employment Discrimination, a symposium that will examine the high failure rates of plaintiffs on pre- and post-trial motions in employment discrimination cases and explore potential strategies to reverse this growing trend.
The reality today is that motions for dismissal and for summary judgment are filed in nearly every case. Originally conceived as an efficient means to help plaintiffs in debt collection cases, Federal Rule of Civil Procedure 56 allowed judges to resolve quickly claims where material facts were not genuinely in dispute and the defendant could not mount a defense. Today, the drafters of Rule 56 would not recognize its expanded application, particularly in employment cases.
Encouraging this movement towards pre-trial adjudication of employment discrimination cases are the U.S. Supreme Court's decisions in Bell Atlantic Corp. v. Twombly and Ashcroft v. Iqbal, through which the Supreme Court appeared to raise the quantum of facts that a plaintiff must plead to avoid successfully a motion to dismiss. As summary judgment is the accepted mechanism for evaluating the factual sufficiency of complaints, these rulings raise interesting questions as to whether the Court has blurred the line between motions to dismiss and motions for summary judgment.
The increasing prevalence of pre- and post-trial dispositive motions has had a demonstrably unique effect in cases alleging violations of employment discrimination laws. A substantial and growing body of evidence, both empirical and anecdotal, shows that civil rights cases, and in particular those alleging employment discrimination, are disproportionately susceptible to dismissal before trial as well as to unfavorable JNOV motions after trial.
Papers will be published in a forthcoming issue of the New York Law School Law Review.
For further information, click here.
October 26, 2011 in Conferences/Symposia, Twombly/Iqbal | Permalink | Comments (0)
Everything But the Merits: Analyzing the Procedural Aspects of the Healthcare Litigation (University of Richmond, Nov. 11)
The announcement below is for the University of Richmond Law Review's Fall 2011 Allen Chair Symposium:
Everything But the Merits: Analyzing the Procedural Aspects of the Healthcare Litigation
Ukrop Auditorium, Robins School of Business (Queally Hall)
School of Law Moot Court Room
Each year, the Allen Chair Symposium explores a single topic of national interest. This year, working in collaboration with Professors Carl Tobias and Kevin Walsh, the University of Richmond Law Review presents the 2011 Allen Chair Symposium entitled "Everything But the Merits: Analyzing the Procedural Aspects of the Healthcare Litigation." This year's symposium focuses on the procedural and litigation issues that have permeated numerous challenges to the 2010 Patient Protection and Affordable Care Act. While much of the attention has focused on the constitutionality of the legislation, lawyers litigating these cases had to address critical issues involving the role of states as litigants, the distinction between facial and applied challenges, severability, and other issues. The symposium will bring lawyers and scholars together in order to explore these all too important procedural issues; so join us and be part of this important discussion!
If you are unable to attend the symposium in person, please feel free to participate via the live webcast. Information for the live webcast will be available on November 11, 2011 at 7:30 A.M. E.S.T..
Conference brochure available here.
October 25, 2011 in Conferences/Symposia, Federal Courts | Permalink | Comments (0)
Lahav on Trial by Formula
Alexandra Lahav (University of Connecticut) has posted The Case for Trial By Formula to SSRN.
The civil justice system tolerates inconsistent outcomes in cases brought by similarly situated litigants. One reason for this is that in cases such as Wal-Mart v. Dukes, the Supreme Court has increasingly emphasized liberty over equality. The litigants' right to a "day in court" has overshadowed their right to equal treatment. However, an emerging jurisprudence at the district court level is asserting the importance of what this Article calls "outcome equality" – equal results reached in similar cases. Taking the example of mass torts litigation, this Article explains how innovative procedures such as sampling are a solution to the problem of inconsistent outcomes. Outcome equality, achieved through statistical adjudication, is gaining force on the ground. Despite the Supreme Court's principled stance in favor of liberty in a series of recent opinions, a victory for outcome equality will improve our civil justice system.
To date, the discussion about civil litigation reform has focused on the conflict between the individual's right to participation and society's interest in the efficient disposition of the great volume of outstanding litigation. This conflict is real and is particularly troublesome in mass torts, where tens of thousands of plaintiffs file related cases making it impossible for the courts to hold a hearing for each claimant. But the fixation on this conflict ignores the fact that an individual's right to equal treatment is also a critical value and can conflict with the individual's right to participation. This Article reframes the debate about procedural justice in the mass torts context as a conflict between liberty and equality rather than liberty and efficiency. The rights at stake are not only the individual's right to a day in court to pursue his claim as he wishes, but also the right to be treated as others are treated in similar circumstances. This Article defends district court attempts to achieve equality among litigants by adopting statistical methods and advocates greater rigor in the use of these methods so that courts can more effectively promote outcome equality.
October 21, 2011 in Class Actions, Federal Courts, Federal Rules of Civil Procedure, Mass Torts, MDLs, Recent Scholarship | Permalink | Comments (0)
Borchers on the New PJ Cases
Patrick Joseph Borchers (Creighton University School of Law) has posted J. McIntyre Machinery, Goodyear, and the Incoherence of the Minimum Contacts Test to SSRN.
On June 27, 2011, when J. McIntyre Machinery Ltd. v. Nicastro and Goodyear Dunlop Tire Operations, S.A. v. Brown were handed down, it marked the first time in almost a quarter century that the United States Supreme Court engaged in an extended discussion of the minimum contacts test. That test has for nearly seven decades set the basic parameters of measuring the constitutionality of exercises of state-court personal jurisdiction. The cases were generally assumed to have been accepted for review by the Supreme Court to clarify two areas in which the constitutional boundaries of state-court jurisdiction were unclear. The first stemmed from the Supreme Court's 1987 decision in Asahi Metal Industry Co. v. Superior Court, which produced no majority opinion and thus left unclear whether the forum state sale of an allegedly dangerous product that caused injury to the plaintiff there sufficed to establish jurisdiction. The second was the quantum of unrelated business contacts in the forum state necessary to create jurisdiction. Unfortunately, as to the first issue, the Supreme Court again produced no majority opinion, and left the subject even more muddled than before. The plurality opinion written by Justice Kennedy attempted to re-ground state-court jurisdiction in a dubious sovereignty theory that the Supreme Court had rejected several times before. As to the second issue, the Court held that unrelated sales in the forum were not enough to establish jurisdiction. The Supreme Court appeared to announce a new test that required the defendant's contacts with the forum state be enough so that the defendant is "essentially at home" in the forum, but provided little elaboration as to what is meant by that phrase. This article argues that the two new cases represent a continuation of the Supreme Court's vacillating and unclear jurisprudence in this area, and that the fundamental difficulty is that the Court lacks any clear constitutional rationale for limiting exercises of assertions of state-court jurisdiction.
H/T Legal Theory Blog
October 19, 2011 in Federal Courts, Recent Decisions, Recent Scholarship | Permalink | Comments (0)
Two SCOTUS Cert Grants of Interest
Today, the Supreme Court granted cert in two cases that should be of interest to civ pro and fed courts profs.
Kiobel v. Royal Dutch Petroleum, No. 10-1491, to be argued with Mohammad v. Rajoub, No. 11-88. In the ruling below in Kiobel, residents of Nigeria brought claims under the Alien Tort Statute against corporations (as opposed to individuals within those corporations) that allegedly aided and abetted the Nigerian government in committing human rights abuses directed at the plaintiffs, and the appeals court held their claims fell outside the limited jurisdiction provided by the Alien Tort Statute and had to be dismissed for lack of subject matter jurisdiction. In Mohammed, the court below held that only a natural person is amenable to suit under the Torture Victim Protection Act, and the sons and widow of a decedent allegedly tortured and killed by the Palestinian Authority and the Palestine Liberation Organization could not sue the PA and the PLO under the TVPA. The petitions for review asked whether the issue of corporate civil tort liability under the Alien Tort Statute is a merits question or an issue of subject matter jurisdiction, and whether corporations are immune from tort liability for violations of the law of nations such as torture, extrajudicial executions, or genocide.
SCOTUSblog info is here.
Elgin v. Dept. of Treasury, No. 11-45. Do federal district courts have jurisdiction over constitutional claims for equitable relief brought by federal employees, or does the Civil Service Reform Act impliedly preclude that jurisdiction?
October 17, 2011 in In the News, Supreme Court Cases | Permalink | Comments (0)
Symposium Oct. 21 at Brooklyn Law School: Globalization of the U.S. Litigation Model
From the LSN professional announcements. Notice our fellow blogger Robin Effron is one of the commentators.
IBL Symposium: Globalization of the United States Litigation Model
Friday, October 21, 9:00 am - 5:00 pm, Subotnick Center, 250 Joralemon Street, Brooklyn
CO-SPONSORS: The Dennis J. Block Center for the Study of International Business Law was established by Brooklyn Law School to provide students with the opportunity to study and shape international business law and policy, drawing upon its faculty's depth of scholarship, experience, and strong international and business law curriculum. It sponsors outstanding symposia that bring together leading practitioners, government officials, and legal scholars from around the world to discuss topics including securities regulation, trade, banking, and intellectual property law.
For over three decades, the Brooklyn Journal of International Law has demonstrated a commitment to publishing substantive, scholarly articles, making it one of the top-ranked international journals in the nation. Published three times a year, the journal features articles on public and private international law by leading authors from academia, government, and private practice.
ABOUT THE SYMPOSIUM: Globalization has led to greater connectivity, interdependence, and economic integration. As a result, this has exposed some plaintiffs and defendants as global participants to different litigation systems.
Given the importance of the United States in the process of globalization and the extent to which the United States relies on litigation in various contexts, its litigation system is viewed by some as a model-one to be either imitated or avoided. For example, the United States is generally more receptive to litigation as a means of protecting injured investors or as a tool of corporate governance, as in the use of collective actions through class litigation and derivative lawsuits. In addition, entrepreneurial lawyers are an important part of the litigation model.
The symposium brings together scholars to discuss how the U.S. model has or has not influenced the development of other litigation systems. Three sessions will focus on procedural issues, securities litigation and enforcement, and derivative litigation.
8:30am Registration and Continental Breakfast
9:00am Welcoming Remarks
Michael A. Gerber, Interim Dean and Professor of Law, Brooklyn Law School
Arthur Pinto, Co-Director, Dennis J. Block Center for the Study of International Business Law; Professor of Law, Brooklyn Law School
9:30am Procedural Issues
Linda J. Silberman, Martin Lipton Professor of Law, New York University School of Law
Sergio J. Campos, Associate Professor of Law, University of Miami School of Law
Antonio Gidi, Assistant Professor of Law, The University of Houston Law Center
Commentator: Robin Effron, Associate Professor of Law, Brooklyn Law School
11:15am Securities Litigation and Enforcement
Eugenio J. Cardenas, Doctor of the Science of Law (JSD) Candidate, Stanford Law School
Poonam Puri, Associate Professor of Law, Osgoode Hall Law School York University
Manning G. Warren III, H. Edward Harter Chair of Commercial Law, Brandeis School of Law, University of Louisville
Commentator: James Park, Associate Professor of Law, Brooklyn Law School
12:45pm Luncheon
2:00pm Derivative Litigation
Arad Reisberg, Reader in Corporate and Financial Law & Vice Dean (Research), Director, UCL Centre for Commercial Law, Faculty of Laws, University College London
Martin Gelter, Associate Professor of Law, Fordham University School of Law
Daniel W. Puchniak, Assistant Professor, Faculty of Law, National University of Singapore
Commentator: Minor Myers Assistant Professor of Law, Brooklyn Law School
October 12, 2011 in Conferences/Symposia, Robin Effron | Permalink | Comments (0)
Justice Stevens' Memoir Says Nary a Word About Civil Procedure
Whenever colleagues at one of my former institutions would (tongue in cheek) argue about which required law school course was most important, one of my fellow Civ Pro professors would invariably pronounce Civil Procedure as "the foundation of all law."
Those of us who appreciated the spirit, if not the letter, of this sentiment are brought down a peg or two by Justice John Paul Stevens' recently-published Five Chiefs: A Supreme Court Memoir. In his brief history of the Chief Justices of the Supreme Court and the best-known opinions issued during the term of each, Justice Stevens makes no mention of a single civil procedure case – not even Erie.
Reading this 248-page small book is a pleasant way to spend an evening. I felt that I was sitting on the porch drinking lemonade with the justice. The book is organized chronologically, but some of his recollections seem a bit random. Discussions of death penalty jurisprudence bump up against a lengthy criticism of the redecorating of the justices' conference room. Nonetheless, Justice Stevens' graciousness, integrity, and love of the rule of law illuminate the volume.
So, back to my topic: no civil procedure nuggets. No discussion of why he couldn't find some way to join Justice Brennan (or even Justice O'Connor) in Asahi and felt the need to strike out on his own. (He did mention that in law practice in Chicago, he represented "a surprisingly large number of entrepreneurs who were distributors of products manufactured by others – coin-operated washing machines, auto parts, calculating equipment, magazines, automobiles, and soft drinks," but this did not lead to any discussion of stream-of-commerce.) No mention of Twombly and my favorite line of his dissent: "If Conley's 'no set of facts' language is to be interred, let it not be without a eulogy." No mention of Iqbal, even though he does discuss why he believes sovereign immunity has no place in a democracy. No mention of Shady Grove and that all-important portion of his concurrence with regard to Section 2072(b).
Good read, but don't bother if all you wanted was an inside scoop on some leading civil procedure cases.
October 10, 2011 in Books | Permalink | Comments (0)
Spottswood on Evidence-Based Litigation Reform
Mark Spottswood (Florida State University College of Law) has posted Evidence-Based Litigation Reform to SSRN.
Over the past several centuries, medical practice has undergone a striking revolution. Slowly but surely, practices based on ancient authorities and untested theories of disease, like purging and blood-letting, have given way to more effective therapies developed through systematic experimental testing, like antibiotics. This revolution may still be in progress, but few can deny that it has improved the quality of health care services. This article considers what lessons lawyers can learn from this evidence-based revolution in medicine, and whether a similar approach to designing rules of legal procedure and evidence could succeed.
Complex systems, like the body and the litigation environment, resist intuitive understanding. If one wishes to maximize a particular result in such environments, one must systematically measure the effects of various interventions on that result, whether it be the health of a patient or the accuracy of case-resolutions. For this reason, we should place little confidence in the accuracy of results generated by existing litigation procedures, because we have never conducted systematic investigations to identify which rules generate the most accurate outcomes. The costs of this ignorance, in terms of unjust outcomes in civil and criminal litigation, may be very high even if we cannot currently perceive them.
Unfortunately, measuring the accuracy of adjudication is much harder than keeping track of morbidity or mortality. If we wish to develop our own evidence-based litigation movement, we will need to design investigative approaches that can measure and compare the accuracy of the many different types of outcomes that can resolve disputes. Towards this end, I sketch one possible accuracy-measurement protocol in this Article, while acknowledging that it would be costly to implement. I also offer some commentary on the relevance of this discussion for current theorizing and practice, with a particular emphasis on the danger of making procedural design choices based on existing forms of empirical evidence and the risks of crafting national rules without drawing on a record of comparative rule experience.
October 10, 2011 in Federal Courts, Recent Scholarship | Permalink | Comments (0)
Brescia on Iqbal's impact on employment and housing discrimination litigation
Forthcoming in the Kentucky Law Journal and posted on SSRN, Raymond Brescia has completed an empirical study of Iqbal's effect that, unlike past studies, attempts to focus solely on motions to dismiss going to the specificity of the pleadings.
The abstract for "The Iqbal Effect: The Impact of New Pleadings Standards in Employment and Housing Discrimination Litigation" follows.
Abstract: In May 2009, the Supreme Court issued its decision in Ashcroft v. Iqbal, a case brought by an immigrant of Pakistani descent caught up in the worldwide investigation that followed the horrific attacks of September 11, 2001. In that decision, the Court extended the "plausibility test" first introduced two years earlier, in Bell Atlantic v. Twombly, to all civil pleadings in federal court. That test requires that, in order to satisfy federal pleading requirements, a complaint must allege a plausible set of facts. But what is plausible in a given case may be in the eye of the beholder.
In the two years since the Court reached its decision in Iqbal, that opinion has been cited roughly 25,000 times. The empirical analysis contained in this study attempts to gauge the impact of Iqbal on civil rights cases, specifically cases involving allegations of employment and/or housing discrimination. While several other studies have attempted to answer similar questions, to date, no study has analyzed this impact with reference solely to motions based on the specificity of the pleadings: which is, of course, the central issue in Twombly and Iqbal. In addition, other studies looked exclusively at quantitative results, with no assessment of the manner in which the plausibility standard was being applied by the lower courts. This empirical study attempts to fill that gap in the empirical research.
This study identified over 1850 reported decisions on motions to dismiss in employment and housing discrimination cases filed in federal district court covering the years prior to and after the Court's decision in Twombly. From this group of cases, a smaller sub-set, totaling 634 cases, was identified by excluding those decisions—included in previous studies—that bore no relation to the issue of the specificity of the pleadings. Furthermore, despite this winnowing process, the sample size for this study was still considerably larger than those analyzed in previous studies.
This detailed study yielded the following results. Surprisingly, the dismissal rate in this class of cases during a set time-period immediately prior to the Twombly decision was actually slightly higher than the dismissal rate of decisions issued in the time period between issuance of the Twombly and Iqbal decisions, but then the rate increases considerably after Iqbal. The dismissal rates for all cases pre-Twombly was 61%; between Twombly and Iqbal, it was 56%; but then after Iqbal, it was 72%, an 18% increase from the pre-Twombly period analyzed.
In addition, even more troubling, plaintiffs were far more likely after Iqbal than either before Twombly or immediately thereafter to face a motion to dismiss challenging the sufficiency of the pleadings in the cases analyzed. Indeed, decisions on such motions were generated only 12 times in the first quarter of 2004 (the first quarter analyzed in this study), but then 61 times in the third quarter of 2010 (the last full quarter analyzed): a greater than 500% increase.
Moreover, when it comes to the substance of these decisions, something else appears to be happening. Despite the increased dismissal rate following Iqbal, oddly, in a class of cases analyzed for this study, courts rarely invoked the plausibility standard in the same manner it was utilized by the Court in Twombly and Iqbal; that is, courts rarely found that dismissal was warranted if there was an arguably more plausible, and entirely legal, basis for the challenged conduct. Finally, and similarly, judges rarely, if ever, appear to invoke their own "experience and common sense," as urged to by the Court, when ruling on motions to dismiss in these cases.
These outcomes yield three conclusions. First, district courts are using the Iqbal precedent, though not necessarily Twombly, to dismiss employment and housing discrimination cases at an accelerated rate. Second, although courts may be invoking the Twombly/Iqbal plausibility standard in assessing the sufficiency of the pleadings in employment and housing discrimination cases, they are certainly not relying on or utilizing the plausibility standard as articulated in these two precedents. This suggests that the subjective elements of the plausibility standard may be infecting these outcomes. That is, if district court judges are dismissing cases at a higher rate post-Iqbal, yet are not relying on the guidance the Court has given such lower courts in how to deploy the plausibility standard, it would seem that such courts may feel emboldened to dismiss cases that might have survived such a motion had that motion been decided pre-Iqbal. Finally, regardless of whether there is a dramatic Twombly or Iqbal effect on outcomes, motions to dismiss challenging the sufficiency of the pleadings are much more common since Iqbal, which means that even if some plaintiffs are defeating such motions, it still comes at a price: it increases transactions costs in these cases, and may, as a result, have a chilling effect on lawyers contemplating bringing them in the first place.
October 9, 2011 in Recent Scholarship, Twombly/Iqbal | Permalink | Comments (1)
Call me naïve: I'm just hearing of ALEC's "model" state legislation
Tipped by a Justia article by John Dean (and who knew John Dean was an advocate for "the 99%"?), I visited a web site called ALEC Exposed, maintained by the Center for Media and Democracy. ALEC is the acronym for the innocuous-sounding American Legislative Exchange Council, a corporate-funded clearinghouse that for at least a decade has been "ghost writing" business-friendly legislation that is introduced into state legislatures.
Perusing the more than 800 such "model" bills, I was quickly drawn to the category Tort Reform, Corporate Liability, and the Rights of Injured Americans. Yep, there they were – some 68 bills with familiar double-speak "tort reform" titles like "Class Actions Improvements Act," "Private Enforcement of Consumer Protection Statutes," and "Noneconomic Damage Awards Act."
October 8, 2011 in Current Affairs | Permalink | Comments (0)
My guest month has drawn to a close; thanks for reading me. Contest winner (although I had to break a tie): "Perhaps the adage about hard cases making bad law should be revised to cover easy cases." Burnham v. Superior Court of California, 495 U.S. 604, 640 (1990) (Stevens, J., concurring).
--Brendan Maher
October 2, 2011 | Permalink | Comments (0)
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James R Maxeiner on Hagan on A Human-Centered Design Approach to Access to Justice
James R Maxeiner on Sachs on Finding Law
Asher Steinberg on Some Thoughts on the Hughes Argument and Logical Subsets
Ken Mellquist on Procedural Moves in Stormy Daniels' Lawsuit Against Donald Trump
ohwilleke on SCOTUS Decision in Hamer v. Neighborhood Housing Services: A Question of Time
Vladeck on Thomas on Justice O'Connor
AALS Section on Federal Courts: Annual Award for Best Untenured Article on the Law of Federal Jurisdiction
SCOTUS Decision in Virginia House of Delegates v. Bethune-Hill: Virginia House Lacks Standing to Appeal Ruling Striking Down 2011 Legislative Districts
Volokh on Robot Judges
Grumet on SCOTUS Amicus Briefs by State Attorneys General
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"What are you waiting for? It's Christmas."
The holidays are all about the lights, and, fortunately for us, so is Tony Stark. And so is this Iron Man Christmas ornament from Hallmark.
Suit up for epic excitement as Tony Stark dons his Iron Man armor. This ornament features Iron Man as seen in Avengers: Infinity War, facing off against the grave threat of universal destruction at the hands of Thanos. Best part? You can press the button to make the arc reactor and repulsors light up. We advise you keep it handy to help deflect any attack the Marvel Universe might try to make on your holiday.


text:
In vivo nuclear magnetic resonance studies of hepatic methoxyflurane metabolism. II. A reevaluation of hepatic metabolic pathways.
B S Selinsky, M E Perlman and R E London
Molecular Pharmacology May 1988, 33 (5) 567-573;
B S Selinsky
M E Perlman
R E London
Methoxyflurane (2,2-dichloro-1,1-difluoro-ethyl methyl ether) is believed to be metabolized via two convergent metabolic pathways. The relative flux through these two metabolic pathways has been investigated using a combination of in vivo surface coil NMR techniques and in vitro analyses of urinary metabolites. Analysis of the measured concentrations of inorganic fluoride, oxalate, and methoxydifluoroacetate in the urine of methoxyflurane-treated rats for 4 days after anesthesia indicates that the anesthetic is metabolized primarily via dechlorination to yield methoxydifluoroacetate. The methoxydifluoroacetate is largely excreted without further metabolism, although a small percentage of this metabolite is broken down to yield fluoride and oxalate, as determined by urine analysis of rats dosed with synthetic methoxydifluoroacetate. At early times after methoxyflurane exposure, the relative concentrations of methoxyflurane metabolites indicate that a significant fraction of the metabolic flux occurs via a different pathway, presumably demethylation, to yield dichloroacetate as an intermediate. Direct analysis of dichloroacetate in the urine using water-suppressed proton NMR indicates that the level of this metabolite is below the detection threshold of the method. Measurements made on the urine of rats dosed directly with dichloroacetate indicate that this compound is quickly metabolized, and dichloroacetate levels in urine are again found to be below the detection threshold. These results demonstrate the quantitative importance of the dechlorination pathway in the metabolism of methoxyflurane in rats.
You are going to email the following In vivo nuclear magnetic resonance studies of hepatic methoxyflurane metabolism. II. A reevaluation of hepatic metabolic pathways.
Molecular Pharmacology May 1, 1988, 33 (5) 567-573;


We are saddened to report that Jerry Corbitt, who played guitar and sang on the first two albums by The Youngbloods died on Saturday 8 March. A full obituary will follow. Meanwhile, we would like to extend our condolences to all of his family and friends and say Thank You for his contributions to the world via his music.