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UK 5G can thrive in a post-Huawei world
By Alan Jones 30 September 2020
Blu Wireless CEO Alan Jones believes that the decision to remove Huawei from the UK's 5G infrastructure could be beneficial for the country's communications industry.
(Image credit: Blu Wireless.)
The recent decision by the UK Government on Huawei has put into sharp focus the significant strategic price the UK is now paying for its 'hands off' market driven approach to the communications industry. The move to focus more on the UK's own industrial policy and diversity of supply is certainly the right one for the country. Technology developed here in the UK leads to higher quality jobs resulting in increased GDP per person - UK generated wealth and productivity is good for all.
"Let's not forget, UK developed technology led the world in the '80s with the likes of System X, a world-leading digital switching technology."
Alan Jones, Blu Wireless.
But is this achievable? Absolutely. Recent coverage would indicate the thriving telecoms ecosystem that once existed in the UK is a somewhat distant memory for some. But let's not forget, UK developed technology led the world in the '80s with the likes of System X, a world-leading digital switching technology.
This technology underpinned the UK Telecom's network and industry with GEC, STC and Plessey Edge Lane in Liverpool becoming the largest manufacturing site for System X products. Unfortunately, as UK networks looked to exploit cheaper (foreign government subsidised) technology, there was a lack of will/strategy to further support the UK technology base.
Further commitment from UK government
Now more than ever, we need to ensure the UK communications technology industry is put firmly back on the roadmap and is a core part of the UK's industrial strategy. A strategy that should include increased funding for relevant technology and product development, as well as procurement policies that favour local equipment, software, and services over overseas alternatives.
We are already starting to see further commitment from the UK Government in recognising that leading-edge technologies exist in-country – technologies such as millimetre wave (mmWave) that could form the backbone of the UK's 5G strategy. Given the integral role the Plessey Edge Lane site once played in the UK's once mighty telecoms industry, it's great to see this being revived. A recently announced initiative is the new £7.2 million Liverpool 5G Create project from UK's Department for Digital, Culture, Media and Sports (DCMS) - a great example of a 'Phoenix from the Ashes', reigniting a telecoms technology revival.
Is OpenRAN the answer?
It is also interesting to note that discussions around OpenRAN has gained traction following the UK Government's decision to remove Huawei from the mobile network – OpenRAN being a mechanism to allow UK companies to participate in the future mobile ecosystem.
OpenRAN refers to an initiative within the mobile communications industry which allows interfaces to be 'opened up' between the various constituent sub-systems that make up the mobile network.
For example, the radio network is typically delivered via the base station towers and the core switching equipment which connects to those base stations usually via backhaul connection of some description like fibre or wireless. And of course, the switching network then relays the information to the appropriate recipients on the fixed or mobile networks elsewhere.
"OpenRAN allows operators to choose from smaller UK vendors, of which there are several, who may not be able to deliver a complete Tier 1 product range but can provide interesting technologies and sub-systems."
However, currently, those interfaces are 'closed' which means that an operator such as Vodafone, EE or BT would have to buy a complete system from one vendor, be it Huawei, Samsung or Ericsson. OpenRAN allows operators to choose from smaller UK vendors, of which there are several, who may not be able to deliver a complete Tier 1 product range but can provide interesting technologies and sub-systems which interconnect using OpenRAN and therefore, allow operators to pick and mix from different sources.
To disaggregate that ecosystem, OpenRAN allows those different vendors who have specific equipment in the radio, core switching or software space to interact and interoperate with one another in the same way as the PC and ethernet world. It is for this very reason that it is being considered as an attractive proposition. Interestingly, Japan's operator Rakuten Mobile has a 5G OpenRAN network which some operators are already looking to take advantage of. Most recently, we saw an announcement from Telefonica articulating its approach to OpenRAN through its partnership with Rakuten Mobile to jointly develop the technology along with 5G core networks and supporting operational systems.
"Our role is to provide an efficient way of using gigabit rate mmWave to connect between the front end 5G NR small cells for example and the core network."
What is compelling for us as a business is having the ability to connect to the OpenRAN interfaces for the backhaul connection. Our role is to provide an efficient way of using gigabit rate mmWave to connect between the front end 5G NR small cells for example and the core network. Notably, we are already seeing interest from mobile operators in using our equipment in that regard. This is due to the uniqueness of our mmWave offering. It is the only product in the world that operates across the full licence exempt band: 57-71 GHz. Particularly the top end of that band, from 64-71 GHz, is low loss meaning we can deliver multi-gigabit carrier-grade performance at ranges of up to 3 km in a small, low power form factor using phased arrays to make the connections dynamic and easy to install.
These attributes make it very interesting to mobile operators where deploying 5G NR small cells requires fibre to be run or the deployment of more expensive and more power hungry backhaul equipment. As such, there is a compelling discussion to be had with regards to both OpenRAN as well as the potential of mmWave technology in supporting this initiative.
Hi-tech warfare
The increasing importance of communications within 'Information Warfare' in the defence sector is seen through recent statements from the UK Government. The UK's Defence Secretary, Ben Wallace was quoted in a Sunday Times article stating that "we desperately need to reform and modernise our armed forces if we are to meet emerging threats" and signalled a warning shot to service chiefs that "there will be a shift away from static ground forces towards aerospace equipment such as drones."
Current Tactical Communications in the UK Military is based on the 'Bowman' system, which dates back to the 1990s and operates within the HF-UHF bands, typically providing a maximum usable data rate of 500 kbps per radio. This is now being updated through the Morpheus programme, together with the use of 4G LTE to increase the user rates to 10 Mbps and above – as can be delivered through today's generation of commercial mobile devices.
However, military applications demand increased resilience (ability to operate in the presence of active jamming); security (ability to minimise eavesdropping through encryption) and stealth (reduced radio signature to avoid detection by ESM systems). These additional requirements have historically led to the development of custom radio platforms leading to long and expensive equipment procurement cycles.
"The use of mmWave communications technology is also being considered for tactical military applications as the combination of active beamsteering, wide channel width and dynamic mesh networking deliver a compelling solution."
The use of mmWave communications technology is also being considered for tactical military applications as the combination of active beamsteering, wide channel width and dynamic mesh networking deliver a compelling solution for next generation 5G gigabit grade tactical communication networks. It remains to be seen if ORAN has a role to play in such networks but the demand for military use cases is clear – and Blu Wireless is already active in the development of mmWave communication platforms for the next generation of military communication systems.
Only time will tell as to whether we'll see a rebirth of a thriving telecoms market here in the UK, but one thing is for sure – we have the capability, expertise and drive to become a dominant force once more. The biggest challenge is ensuring we are forthright in our decision making and are investing in the innovative 'home-grown' technologies available to us.
Alan is an accomplished executive with over 25 years' experience in the technology industry, with a technical background, having held senior engineering roles at both Hewlett Packard Labs and Motorola. He went on to be a founding member and executive of IPWireless Inc., a mobile broadband equipment supplier, and was instrumental in the sale of the Company. Alan later went on to co-found Virtuosys Ltd in 2014, where he served as CEO. A pioneer in edge computing, Virtuosys Ltd was acquired by Veea Inc. in 2018. Since that time, Alan served as CEO of Veea Systems Ltd and was a board member of Veea Inc. before joining Blu Wireless as CEO in 2000.
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While the speaker makes his or her lecture, the professional interprets at the same time with the shortest possible delay for the audience. Frequently used in lectures, congresses, conferences and similar events. Opportunity Translations® also offers translation and sound reinforcement equipment in order for the participants of the event to be able to select the audio channel with the original speech or its translation.
This mode consists of the translation of a document of official value, respecting standards set forth in advance by the Commercial Registry Office. Sworn translation may be necessary whenever you need a document for legal purposes to be valid on the Brazilian territory with public faith. This document is also requested when you need legal proof in an international environment, such as, for example, a Brazilian university student seeking to apply for a Bachelor's degree abroad. In this case, the international institution will request a legal translation of his academic record related to the years or the semesters that have already been completed.
When the speaker says a small sentence, the professional translates it afterwards. This modality allows for a more precise translation, since the translator has a few seconds to think of the words he is hearing and their context within the phrase before translating it. It also allows the listeners to understand better what is said, having time to follow up the original phrase and its translation. It is used in press conferences, small meetings, travels and more informal situations.
Commonly known as layout, this consists of the distribution of graphic elements on a given page, whether digital or printed. This technique is used in free translations, making the translation format exactly the same as that of the original document.
Used when it is not necessary for a document to be translated by a certified translator. It offers more freedom in choosing the terms used, but the translator has the same responsibility and commitment to the content as a certified translator. The submission and receipt of the material can be done by e-mail or according to the client´s needs.
We review material both regarding content and disposition of the elements, mainly for documents with standards to be complied with.


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Above All Men reviewed on The Examiner
Eric's novel, Above All Men, received a glowing five-star review by Zack Kopp, the Denver Regional Book Reviewer for The Examiner:
"Eric Shonkwiler's debut novel, Above All Men, recently released by MG Press and available for order now, is the story of war veteran David Parrish fighting to keep his family safe in a near-future America leached of oil. Esteemed writers have praised this book from their hearts. Seasoned editors have taken notice of Shonkwiler. This reporter isn't naming any names, but a mutual friend long a shaker in the guerrilla publishing scene says, "I describe the book as landing somewhere between a soberer Hemingway, a more linear Faulkner, a heavy rotation of Nick Cave's Murder Ballads, a couple'a shots of Bulleit, an infected snakebite, and Cormac McCarthy. Eric's writing style has been compared to Cormac McCarthy, William Faulkner, Ernest Hemingway, William Gay, Marilynne Robinson, James Agee, Edward P. Jones, John Steinbeck, and Denis Johnson." That's how I found out about it.
I started reading. It's a few years from now, and America is collapsing. Crops are drying up and dying off and there is hardly any oil, society's critical addiction, the artificial bloodstream making everything run. People are fleeing from the cities out into the countryside in madly ecstatic suspension of moral law. Parrish labors to keep his family and farm together in the midst of all this elaborate dysfunction, but the murder of a small local child opens old personal wounds for David, making him choose to face his own nature on a hunt for the killer through dust storms and crumbling towns. In Above All Men, Shonkwiler paints a possible future beyond expectation but far from unlikely, when all the little gadgets and pods and pads have died off and we're not connected anymore and we gamble in dirty caves and trade hunks of meat for survival. Shonkwiler renders the degraded deprivation of protagonist David Parrish's unflagging resilience in artful, distinctively crafted language. Before I knew it, I was through the book, feeling unusually satisfied as a reader always in search of that elusive feeling.
"Shonkwiler renders the degraded deprivation of the protagonist's unflagging resilience in artful, distinctively crafted language. Before I knew it, I was through the book, feeling unusually satisfied."
I'm not the only one who likes it. Check out these raves:
"Shonkwiler takes the world on his own terms, and wrestles it to the ground." Tom Lutz, Editor-in-Chief, Los Angeles Review of Books
"Shonkwiler has taken an iconic landscape and filtered it through near-collapse and fear, then through loyalty and love." Susan Straight, National Book Award Finalist
"Sparse and poetic, the words within these pages are as sharp as a corn knife." Frank Bill, author of Donnybrook and Crimes in Southern Indiana
Eric Shonkwiler's writing has appeared in The Los Angeles Review of Books, The Millions, Fiddleblack, [PANK] Magazine, and Midwestern Gothic. He was born and raised in Ohio, received his MFA from the University of California Riverside, and has lived and worked in every contiguous U.S. time zone. Bookstores order via Ingram. Readers can order via the links in this article, or from Amazon, iBookstore, Kindle Store, Barnes & Noble, Nook Store, and other online retailers."

redpajama_set_name: RedPajamaCommonCrawl


The Sterling bar are offering a 20% discount off all food and drinks for the residents of the St Botolph's Building.
Customers can book online at https://www.thesterlingbar.co.uk/reservations/ or give us a call on 0207 929 3641.
This is excluding the month of December during their peak Christmas period.


The Rise Of The Real Life Gabbar! This Time Gabbar Is Angry!
See The Rise Of The Real Life Gabbar! This Time Gabbar Is Back & Angry!!
Salman Khan's Verdict on Wednesday restored the faith of many people in our judiciary/system of law.
But this faith was broken again after just two days on Friday following the news of Salman's verdict being cancelled by the High Court.
After a few raging comments on twitter & Facebook and after spending the weekend with the family while enjoying a blockbuster, it seemed that people had already forgotten about Salman & carried on with their lives & their fight with their biggest enemy Monday.
But since this was not enough another blow came this morning that the former Tamil Nadu Chief Minister Jayalalitha was cleared of her charges on Disproportionate Assets case today!
And the worst part is that they say the Judge took only '10 seconds' to deliver the verdict.
Such examples of powerful & famous people manipulating the law & finding their way out, just forces people to have disbelief in the law.
How can someone get away from a jail sentence of 4 to 5 years in just a few days or a matter of seconds?
Does it imply that only money can buy justice?
As it is shown in the movie 'Gabbar Is Back', that one guy makes an unofficial but an effective organization to fight corruption and bring justice to the society. Though due to the character's method being incorrect, he had to face the consequences and was hanged to death.
But it's the incidents like these that actually fuel a lot of rage inside the hearts of common people & things like this can give rise to a real life Gabbar!!
So do you think that India needs a real life Gabbar?
How can we be as effective as 'Gabbar' without using the unlawful ways that he used in the movie?
7 Ways In Which India Has Changed In The Last T ..
Get Rid Of Your Dull Skin By Eating These Foods ..
Career In Photography : Different Types Of Phot ..


Aiming to combat human trafficking in all forms in Alameda County.
Alameda County United Against Human Trafficking Advisory Council, or "AC United," is a collaborative project led by the Alameda County District Attorney's Office and the Alameda County Social Services Agency.
The Bay Area H.E.A.T. Coalition (BAHC) was established to increase communication, cooperation, and collaboration between local, state, and federal law enforcement, service providers, systems, community members, and existing human trafficking task forces in the Bay Area. BAHC's main purpose is to enhance local efforts, support and coordinate local service providers, and coordinate with task forces throughout the Bay Area.
H.E.A.T. Watch – Labor was started in 2015 by a directive from D.A. Nancy O'Malley. It developed from prior work by the Worker Protection Division, whose cases and initiatives leverage criminal penalties toward justice for exploited workers. The labor team meets quarterly. The purpose of the group is to develop and vet best practices in the enforcement of labor exploitation and the rendering of services to its survivors.
The H.E.A.T. Institute has engaged HEAL Trafficking to provide technical assistance for the development of human trafficking protocols for four Alameda County hospitals: Highland Hospital, UC San Francisco Benioff Children's Hospital Oakland, Alta Bates-Sutter Hospitals, and Kaiser Permanente Oakland Medical Center.


Known as the "sweethearts favorite," the PUT-IN-BAY is depicted passing the Ambassador Bridge, in Detroit. She was built as a "dancing ship" with an enormous ballroom for the express pleasure of those in the dance craze.
1974 | Original: Sold | Print edition: Lithograph | Size: 30" x 24"


text:
John Nelson was an American Negro league baseball pitcher from the 1880s to the 1900s.

Nelson made his Negro league debut in 1887 for the New York Gorhams, and played for New York again the following season. He went on to play several seasons for the Cuban Giants and Cuban X-Giants through 1908.

References

External links
 and Seamheads

Year of birth missing
Year of death missing
Place of birth missing
Place of death missing
Baseball pitchers
Cuban Giants players
Cuban X-Giants players
New York Gorhams players
Philadelphia Giants players

redpajama_set_name: RedPajamaWikipedia


text:
package unito.api;

/**
 * Checks the result of the operation
 * Created by bynull on 03.06.16.
 */
public interface Spec<T, R> {
    void check(T input, R result) throws Exception;
}

redpajama_set_name: RedPajamaGithub


As a reminder, on January 14, 2017, U.S. Customs and Border Protection (CBP) will deploy DRAWBACK, DUTY DEFERRAL, RECONCILIATION, LIQUIDATION, COLLECTIONS and STATEMENTS in the Automated Commercial Environment (ACE). With this transition, transactions supporting these capabilities must be filed in ACE and will no longer be accepted in the Automated Commercial System (ACS).
In addition, beginning January 14, 2017, FDA STANDALONE PRIOR NOTICE submissions will no longer be accepted in ACS. Digital requests must be submitted through ACE or handled through FDA's website. For technical details on submitting electronically to ACE, please reference FDA's supplemental technical documentation.
ABI filing of IMPORTER SECURITY FILING (ISF) transactions will NOT be transitioned to ACE as part of the January 14, 2017 deployment, as previously scheduled. CBP will issue further notification on the ISF deployment date in the near future.
The full Automated Surety Interface (ASI) will not be deployed on January 14 as previously scheduled. An interim solution developed with the sureties will be in place until ASI is deployed in full at a later date.
CBP encourages filers to transmit all available transactions prior to 5pm EST on Friday, January 13, in advance of the cutover. If updates are required to Reconciliation, Drawback or Duty Deferral transactions filed in ACS prior to the cutover, filers will need to work with the Ports/Centers of Excellence and Expertise as appropriate.
With respect to the cutover timeframe specific to statements, CBP will disseminate an update to CSMS 16-000806 (issued September 12, 2016) the week of January 9, 2017.
CBP will have an extended ACE outage period for this deployment beginning Saturday, January 14, 2017 at 10pm EST, and targeted to conclude on Sunday, January 15, 2017 at 8am EST. This outage window will affect all ACE applications, including Manifest and Cargo Release. CBP will issue a CSMS to confirm the conclusion of the outage window.
As a reminder, the operating status of ACE application servers is available by way of the ACE Availability Dashboard.
As with every outage window, ACE may take some time to process transactions that are queued prior to and during the outage. CBP will be monitoring incoming transactions and will address any issues encountered.
For support following the January 14, 2017 deployment, the trade community should contact their assigned ABI Client Representative for technical issues. Immediately following the January 14, 2017 deployment, Client Representatives will have additional resources available to assist with issues that may arise related to the new post-release capabilities in ACE.


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Tag Archives: Chinese New Year
LEGO will make regional exclusive sets available worldwide starting next month [News]
Over the past year, LEGO has produced quite a few special sets with limited availability, including regional and retailer exclusives like the Chinese New Year sets and the Darth Vader Bust. Access to these products has typically been extremely limited, forcing many frustrated LEGO fans both in the US and abroad to go out of their way and pay exorbitant amounts of money from scalpers and other sites to obtain the sets. Starting in May, all that is about to change for the better.
Click to read about the change to LEGO regional and exclusive set availability
Dave Schefcik
Announcement, Chinese New Year, Comic Con, Exclusives, Gift with Purchase, LEGO Forma, Lunar New Year, The LEGO Group
The LEGO Movie 2 Collectible Minifigures, Apocalypseburg and more now available [News]
A new month means new LEGO sets are now available, and while there are significantly less than the huge amount that went on sale in January, there are still a few updates and some sweet promotions.
New Sets for February
First up, 70840 Welcome To Apocalypseburg is now available widely after its VIP early access. You can read our detailed review here. The set includes 3,178 pieces and 12 minifigures for US $299.99 | CA $399.99 | UK £279.99.
Next up, 71023 The LEGO Movie 2 Collectible Minifigures are now available online. These have popped up early in some retail stores before today, but they are now generally available with all your post-apocalyptic favorites and the quartet from the Wizard of Oz. We have all the details in our hands-on review. They are priced at US $3.99 | CAN $4.99 | £2.99 UK.
There is also a bunch of other gear, costumes, masks and more themed for The LEGO Movie 2, including a new 853874 Emmet Construction Pod. (Also of note, the new "sewer babies" pack is not available online but is now on LEGO Store shelves.)
Click to continue reading about LEGO's current promotions
Chinese New Year, Gift with Purchase, New Sets, The LEGO Movie 2
For many around the world, the New Year is just beginning...
With the Chinese New Year less than a week away, we're seeing a number of creations inaugurating the Year of the Pig and a new calendar for over 20 percent of the planet. Joseph Zamara provided a detail-filled scene of how the Lunar New Year is likely to be enjoyed next month in San Francisco, California. Held since the 1860s to celebrate Chinese culture in the United States, this parade draws in hundreds of thousands of visitors each year and is the largest Lunar New Year event outside of Asia. The builder recreated a lively portion of the parade in front of the Dragon Gate in San Francisco's Chinatown. The scene features a ton of popular references to the Lunar New Year, such as dancing dragons and children carrying red envelops containing gifts of money (hóngbāo). There's even a C-pop float to round off the sensory experience.
As a quick note, Joseph states he recently worked with LEGO China's Integration and Engagement team and fifteen other builders to highlight the Lunar New Year in LEGO form (including the Nian beast we recently featured). We're hoping to see many more creations in the days ahead. We wish our readers great happiness and prosperity for the year ahead!
Chinese New Year, Diorama, Joseph Zamara, Lunar New Year, Town
LEGO 40186 Year of the Pig gift with purchase available now [News]
LEGO is giving away a free 40186 Year of the Pig set with eligible purchases over 88 USD, 80 GBP, or 88 CAD. The set celebrates the 2019 Lunar New Year, and comes with a rotating head, movable ears, arms, and legs. Also enclosed is a red money envelope with traditional gold color prints.
The offer is only available through February 7th or while stocks last. Links for the various regional stores are as follows: LEGO US Shop Online | LEGO UK Shop Online |LEGO Canada Shop Online
Chinese New Year, Gift with Purchase, Lunar New Year
A beautiful brick-built boar that will leave you singing, "Hakuna matata!"
Builder keiichi kamei is no stranger when it comes to building phenomenal LEGO sculptures. Earlier this year, you might recall us sharing his New Year lion dance mask. With 2019 being the year of the pig, keiichi is back with a majestic-looking LEGO wild boar. His boar looks like the real deal, thanks to intricate sculpting of the animal's body. A combination of curved and angled slopes form the overall shape of the body, which is nearly void of studs. Meanwhile, the positioning of the legs is reminiscent of how boars trot around while they forage for food. Better watch out for those tusks, though!
Matt Hocker
Animal, Chinese New Year, Creature, keiichi kamei, Sculpture, Zodiac
LEGO to release Exclusive sets inspired by traditional new year festivals for the China and Asia Pacific markets [News]
LEGO announces region specific sets for the China and Asia Pacific Markets that's slated to be released from January 1st, 2019 onwards. At the moment, two sets showing events from the festivities related during the Lunar New Year's celebration are featured. The two sets are scenes celebrating the family dinner on the Eve of Chinese New Year, and the famous Dragon Dance. According to Niels B. Christiansen, Chief Executive Officer of the LEGO Group, this is the first time LEGO has made sets for a specific country or region.
80101 Chinese New Year's Eve Dinner
Click here to learn more about the new sets!
Announcement, China, Chinese New Year, Exclusive
Luck, Prosperity, and LEGO
We've all seen the giant Chinese dragons given life by hidden dancers in their bellies. They're especially popular in parades surrounding the Chinese New Year. But they aren't just for fun. These colorful characters are created to honor the beloved creatures of Chinese tradition and culture. Dragons are a symbol of power and luck. They are also said to represent prosperity and strength. This LEGO build, by Vlad Lisin, is a really cool tribute to their beauty.
Vlad has done a great job of bringing the dragon to life with the details of the face. I'm especially fond of the expressive eyes, eyebrows and cheeks.
Bre Burns
Chinese New Year, Dragon


Manager Jose Mourinho reveals captain John Terry will stay at Chelsea for at least one more season.
As per the club policy, the 34-year-old can only be offered a one-year contract extension and Mourinho says the Englishman is ready to commit his future to Chelsea.
"Everybody wants to stay, especially him [John Terry]," Mourinho told reporters on Friday.
"He's been here all his life. He accepted the politics here that after a certain age to go year by year [with contracts]. He accepted it with a smile and as a challenge.
"Last season he won that challenge by performing so well and getting a one year extension.
"This year he is winning the challenge and the right of getting another one year extension. It's what the club wants, what John wants and what is going to happen."
Asked about his own contract situation, the Portuguese said: "I have two more years [on my contract].
"I want to stay, I think the club are happy too. I'm not waiting for offers, not giving any space for speculation or interest from other clubs.
"I don't need a contract. my story is a non-story. I will stay [for as long as] Mr Abramovich wants me to stay."


If you get a few minutes (actually 23 minutes) please watch this episode of Rhythm and Roots which aired this week on EBRU Television. (Don't worry, I'd never heard of them either.) It's about my group Ensemble East, and has performances and interviews.The series explores traditional music from various cultures. We play "Haru no Yo" and "O-Koto" as well as solos and there are extensive interviews.
Well done James and EE. Though the show may be obscure, it was well done in terms of exposing people to music that they might otherwise find impenetrable on their own. It had a good technical and aesthetic presentation and didn't sell that actual performance short on time as these types of shows often do. Bravo!
Really enjoyed the program. It's always great to get a chance to hear you play.
Totally enjoyed the interviews. Music wasn't bad either!
Thanks all of you for the thoughtful and positive comments. I thought that they did a pretty good job of it. They are used to doing profiles on groups that play 3-5 minute songs, so when I told them that ours were 18 and 20 minutes, they kind of freaked, but then we agreed on doing sections of the pieces. Not my first choice but hey... it's television.
Thank you James, enjoyed that.
Congratulations! That was great to watch. I thought it came off really well.
I laughed out loud when you said, "Let's put it this way....it's not a large movement!"
When Masayo said Japanese music is not as popular as Western, I don't know if the American viewer would understand that this is also true in Japan, not just in America.
Excellent show and the music was nice. Made me miss being in NYC.
This is great! Good for the ensemble... and you sound great!
I wish Ensemble East had videos on YouTube so I could see and hear more of your performances.
Wonderful piece; good energy in the group. It feels like you three really enjoy playing music together.
Nice show; great shakuhachi and koto combination. Thanks!


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Palm responds to Apple's warning
After Apple issues a warning about iTunes and third-party player synchronization, Palm fights back.
Bonnie Cha
June 17, 2009 11:41 a.m. PT
Bonnie Cha Former Editor
Bonnie Cha was a former chief correspondent for CNET Crave, covering every kind of tech toy imaginable (with a special obsession for robots and Star Wars-related stuff). When she's not scoping out stories, you can find her checking out live music or surfing in the chilly waters of Northern California.
Screenshot by Bonnie Cha/CNET
On Tuesday, Apple issued a warning that it does not support iTunes synchronization with "non-Apple digital media players" and that future versions of the software may put an end to any such capability. While Apple didn't point any fingers, it's hard to believe the warning wasn't directed right at the Palm Pre, which shows up as an iPod when connected to iTunes and allows you to sync non-DRM media to the smartphone.
Palm isn't taking it lying down and has responded to Apple's threats. Speaking to John Paczkowski of the Wall Street Journal, Palm spokesperson Lynn Fox said:
Palm's media sync works with the current version of iTunes. If Apple chooses to disable media sync in a future version of iTunes, it will be a direct blow to their users who will be deprived of a seamless synchronization experience. However, people will have options. They can stay with the iTunes version that works to sync their music on their Pre, they can transfer the music via USB, and there are other third-party applications we could consider.
Also, as MyPre.com points out, Apple would have to specifically block the Pre since it shows up as an iPod and any casual changes to iTunes could affect legacy iPod support. Either way, things are getting pretty sticky. Apple, your move.


Beetle goes home. But do not lose your concentration - this task is not as simple as it looks. You will face the most fearsome opponents, there are: elusive time, curious spiders and predatory beetles. Will you? Then go!


text:
Q: ListView Select Problem I have a listview in my program. the problem is that. the list is in single choice mode and when i select any item i have 4 buttons on the footer of my page for that item.. alll i want is to know that. how can i keep that item selected and while cliking any button i can get the selected item.

A: Try this:
listView.setOnItemSelectedListener(new OnItemSelectedListener() {
    public void onItemSelected(AdapterView a, View v, int position, long l) {
        arrayPosition=position;
    }
public void onNothingSelected(AdapterView<?> arg0) {
}

});
where arrayPosition is a static integer variable.
Try this if it helps..

A: If you are using a ListActivity you can use getSelectedItemId() or getSelectedItemPosition(). Alternatively you can bind your own OnItemClickListener to the ListView object. More information can be found in this tutorial.

redpajama_set_name: RedPajamaStackExchange


As a Flipper Affiliate you can offer FlipperSiteDeveloper™ to your customers immediately – no purchase required. Signing up to become an Affiliate is a simple process.
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You will be eligible for special pricing, contact us for pricing details.
Once approved, you will be issued a Certified Partner ID. Your company is now ready to harness the power of Flipper. As an FCP you will have access and use of all the modules that are currently developed for Flipper including surveys and the HTML email manager.
Certified Partner Pricing – Once your staff has completed training and begin selling Flipper, your company will receive discounts on every Flipper Web site your company implements. Contact us for Partner pricing.
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Overnight Stays. The Doggie Pajama Party!
In Your Home or Ours. You Pick.
Whether you chose to have your pet stay with us in one of our sitter's homes, or whether you want us to come to your home, we try to keep your pet's day as normal as possible.
Dog Walks. Saunter. Frolick. Romp.
Standard Walking Hours are 10am to 6pm Monday-Friday. Early mornings, late nights, holidays or weekends are $10 additional.
Cat Care. House Checks. Plants Need Love Too!
Our cat care and house check services include feeding, cuddle and play time, cleaning the litter box, checking mail, watering plants, turning lights on/off, and any other incidentals that will make your life easy while you are away!


Prometheus | If This, Then What?
I've blogged about Ridley Scott before, and though I should know better, I can't help but get excited by the new trailer for Prometheus. Scott is a masterful visual stylist, and when he gets a decent script to build those visuals on, he can come up with some amazing stuff.
Frustratingly, Mark Verheiden's run on Dark Horse Comics, collected in Aliens: Book 1–3, was everything the story could – and should – have been; mindful of what had come before, but moving the story into new territory. (It would have made a great movie trilogy too.) I recommend it heartily, and consider it the true continuation of the Alien saga.


Welcome to BandMix.co.uk Reading, EN!
BandMix.co.uk brings Reading, England musicians wanted and bands together.
As a proven leader in online music services, BandMix.co.uk's thousands of profiles mean thousands of possibilities to connect with the right musicians. Browse the Listings in Reading, EN below or Search for exactly what you are looking for.


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Alibaba Group Generated $38.4 Billion of GMV During the Global Shopping Festival
Alibaba Group Holding Limited announced that it generated RMB268.4 billion (US$38.4 billion) of gross merchandise volume (GMV) on November 11, 2019, an increase of 26% compared to 2018.
"Today we showed the world what the future of consumption looks like for brands and consumers," said Fan Jiang, President of Taobao and Tmall. "We are meeting the growing demand of Chinese consumers and helping them upgrade their lifestyles, while introducing new users to our digital economy from across China and around the world."
In addition to a new record GMV, the total number of delivery orders also reached a new high: 1.292 billion, up 24% from 1.042 billion last year. There were 299 brands to reach RMB 100 million in GMV, including Apple, Nike, Estee Lauder and Giorgio Armani. The top 10 countries selling to China through Alibaba's cross-border platforms were Japan, the U.S., Korea, Australia, Germany, France, the U.K., New Zealand, Italy and Canada.
Highlights from the 2019 11.11 Global Shopping Festival
Total GMV settled through Alipay was RMB268.4 billion (US$38.4 billion), up 26% YoY
More than 200,000 participating brands
1 million new products launched for 11.11
Cainiao Network processed 1.3 billion delivery orders
Top five countries selling to China through our cross-border platforms by GMV: Japan, United States, South Korea, Australia, Germany
299 brands surpassed RMB100 million (US$14.3 million) and 15 of those brands surpassed RMB1 billion (US$143.0 million) in GMV; top brands included:
Apple, Bose, Estée Lauder, Gap, H&M, L'Oréal, Levi's, MUJI, Nestlé, Nike, Philips, The North Face, Under Armour, Uniqlo
The Chinese retail juggernaut kicked off this year's 24-hour shopping bonanza with a live performance by U.S. pop star Taylor Swift followed by live-streamed marketing of over 1,000 brands.
Tags: Alibaba
Noctua Releases New Chromax Line of Fans
Daimler Trucks Launches Ecosystem for Entry into e-mobility
Alibaba Raises Up to $12.9 billion in Hong Kong Listing
Alibaba Group Generated $12 Billion of GMV in the First Hour of the Global Shopping Festival
Alibaba Unveils the Hanguang 800 AI Chip for Cloud Computing Services
Alibaba's Pingtouge Launches Own RISC-V Processor
Alibaba, Tencent, Chinese Car Makers Agree on New Ride-hailing Service
Alibaba and Intel Cloud Deliver Joint Computing Platform for AI Inference at the Edge
Alibaba Group Announces New Boss
Alibaba Cloud Launches Cloud and AI Solutions in Europe


Are there benefits buying a one-bedroom apartment?
Generally, when people look to buy an apartment, they can default to wanting a two bedroom as a minimum. I've found in Melbourne CBD over the years, people are still getting their heads around apartment living and unsure about the vertical world, though in other areas of the world living in studio apartments is a norm. So, when it comes to buying an apartment to live in or as an investment, a lot of people think they can safeguard themselves by investing into a larger apartment.
If you have the budget to purchase a big enough two-bedroom apartment, not any of this new build pokey stuff they're constructing, then it's worth doing your research and planting your money in one. But if you sit on the border of buying a good sized one bedroom or one plus study, then change your focus and grab it.
When you buy a one-bedroom apartment, you'll find some things that will remain consistent with past sales history and most likely the future. Firstly, if you haven't purchased any long-term lease properties through student housing or serviced apartments, then you will see growth. Because the purchase is usually at a lesser level than bigger apartments, the growth will most likely remain consistent in percentage, though don't expect to become a millionaire. On the other hand, if the market topples over and crashes, you'll find that any losses incurred are usually marginal and if there is a need to cash up, you most likely won't stand to lose as much money as bigger apartments.
The other benefit is that the rental return is usually higher than bigger apartments. One-bedroom apartments are usually in quite high demand, especially around the Melbourne CBD. The reason being, is the city attracts a lot of single and young couple professionals who don't need the extra space. Bigger apartments that cater for families or a few extra people may find it harder to place a tenant as the demand isn't has high from that demographic. So due to the higher demand for one-bedroom rentals, you tend to gain a stronger yield out of your investment property and can secure a strong rental return.
Another thing to remember is because your apartment is naturally smaller, you will incur lower Owners Corporation (OC) fees. This is one of the most beneficial factors about buying a one-bedder. OC's can creep up on you over the years and in some cases, whatever capitol growth you may have in your larger apartment, it's not unusual to see the OC fees even out your gains. I've always found with the smaller apartments though, it becomes so much more affordable year to year and helps you achieve more money out of your investment.
At the end of the day, I would just suggest keeping an open mind when you're out looking at apartments. If it's to live in, think whether you need the extra space or not and buy accordingly. If it's investment, I would look more into the one-bedroom apartment range and maybe purchase multiple over the years.
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Everything Trump Touches Dies (Kobo eBook)
By Rick Wilson
#1 New York Times bestseller! A respected, long-time Republican strategist, ad-maker, and contributor for The Daily Beast skewers the disease that is destroying the conservative movement and burning down the GOP: Trumpism.
Includes an all-new chapter analyzing Trump's impact on the 2018 elections.
In the #1 New York Times bestselling Everything Trump Touches Dies, political campaign strategist and commentator Rick Wilson delivers "a searingly honest, bitingly funny, comprehensive answer to the question we find ourselves asking most mornings: 'What the hell is going on?' (Chicago Tribune). The Guardian hails Everything Trump Touches Dies, saying it gives, "more unvarnished truths about Donald Trump than anyone else in the American political establishment has offered. Wilson never holds back." Rick mercilessly exposes the damage Trump has done to the country, to the Republican Party, and to the conservative movement that has abandoned its principles for the worst President in American history.
Wilson unblinkingly dismantles Trump's deceptions and the illusions to which his supporters cling, shedding light on the guilty parties who empower and enable Trump in Washington and in the media. He calls out the race-war dead-enders who hitched a ride with Trump, the alt-right basement dwellers who worship him, and the social conservatives who looked the other way. Publishers Weekly calls it, "a scathing, profane, unflinching, and laugh-out-loud funny rebuke of Donald Trump and his presidency."
No left-winger, Wilson is a lifelong conservative who delivers his withering critique of Trump from the right. A leader of the Never Trump movement, he warned from the start that Trump would destroy the lives and reputations of everyone in his orbit, and Everything Trump Touches Dies is a deft chronicle the tragicomic political story of our time. From the early campaign days through the shock of election night, to the inconceivable train-wreck of Trump's first year. Rick Wilson provides not only an insightful analysis of the Trump administration, but also an optimistic path forward for the GOP, the conservative movement, and the country.
"Hilarious, smartly written, and usually spot-on" (Kirkus Reviews), Everything Trump Touches Dies is perfect for those on either side of the aisle who need a dose of unvarnished reality, a good laugh, a strong cocktail, and a return to sanity in American politics.
Publisher: Free Press
Hardcover (August 7th, 2018): $27.00
CD-Audio (August 7th, 2018): $29.99


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Източният регион () е един от 13-те региона на Буркина Фасо. Граничи с Бенин и Нигер. Площта му е 46 228 квадратни километра, а населението е 1 777 738 души (по изчисления за юли 2018 г.). Столицата на региона е град Фада Нгурма. Разделен е на 5 провинции Гнаня, Гурма, Комонджари, Компиенга и Тапоа.

Източници

Административно деление на Буркина Фасо


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AFM Briefs
Fox Lorber Associates acquires homevid rights; Spano to weather 'Storm'
By Vanessa Torres
Vanessa Torres
's Most Recent Stories
7th Art plugs into 'Circuitry'
Thesp Green grows with UTA
Palm Springs fest to host cinematography event
Fox Lorber Associates has acquired homevideo rights to several new titles, it was announced by Krysanne Katsoolis, senior VP of acquisitions.
Overseas Film Group's "johns," "Jerusalem," "Different for Girls," "Marcello Mastroianni: I Remember, Yes, I Remember," from Anna Maria Tato, and the Swedish "The Other Side of Sundown" have all been picked up by Fox Lorber Home Video for the U.S. Also acquired were two Jackie Chan docus from Media Asia, "My Story" and "My Stunts," pegged for Fox Lorber's WinStar Home Entertainment label.
U.S. television and homevideo rights for Juzo Itami's "Tampopo" and "The Funeral" have also been picked up, as well as five Agnes Varda titles and Louis Malle's "My Dinner With Andre" for worldwide distribution.
Actor Vincent Spano has signed on to direct and star in the special effects-driven "Storm," from indie production and distribution outfit UFO. With only shorts under his belt, Spano will make his feature directing debut with this high-tech thriller about a covert military mission dubbed "Operation Storm."
Olandt, Jeff Beach and Phillip Roth will produce from a script by Patrick Phillips. Beach will also oversee the international sales.


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As the lead singer of Garbage and beyond, Shirley Manson has been rocking the world since 1995.
If your web design and online presence is showing its age, you're showing a brand to the world that has cobwebs in the corner.
I want to discuss is the design changes they have gone through and how each of these changes not only reflected the standards of the day, but the demographics they were going for.
The Sims 4 is coming out and there's controversy surrounding it. Will it be less ambitious and as featureless as SimCity?
Fernando Lazzari has seamlessly married the physical world with digital type in a work of art that pays tribute to friend Julieta Ulanovsky, her city and her work.


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Home > Armed forces
Church in Wales wins contract to train British military chaplains
Chaplains serving UK armed forces will continue to be trained by the Church in Wales, after St Padarn's Institute won a training contract.
Anglican and Catholic Irish Primates in joint Remembrance Sunday commemoration
A two-minute silence has been held at 11 am this morning (Friday) in many parts of the world in commemoration of those who died serving their countries in times of war.
Regimental church offers mental health care for army reservists
A regiment of Canadian army reservists can soon expect to have greater access to mental health services with the launch of a new ministry in the diocese of Edmonton.
Military chaplains in fight against forces' suicides
Military chaplains are working across the globe to care for the spiritual wellbeing of armed forces personnel in a bid to prevent suicide – a significant issue amongst military veterans.
Bishops express concern at extension of UK's anti-Daesh airstrikes
75 years after Coventry Cathedral was destroyed in an aerial bombing campaign that blitzed the city around it; the Bishop of Coventry has warned against the "unintended consequences" of both physical and ideological collateral damage during a debate over whether or not Britain should expand its anti-Daesh campaign in Iraq to also include targets in Syrian territory.
Archbishop of Canterbury speaks on UK's anti-Daesh military campaign
The Archbishop of Canterbury, Justin Welby, has said that the "Just War" criteria have been met to justify military action against Daesh (IS, ISIL, ISIS) in Syria; but warned that merely bombing Daesh targets would "confirm their dreadful belief that what they are doing is the will of God." He called for a holistic approach to tackling Daesh, which should include a "global theological component".
Defence Minister addresses Armed Forces Covenant Training Day
Church of England parishes have been reminded of the vital role they can play in helping support the Armed Forces, veterans and their families at a training day aimed at promoting the Armed Forces Covenant.
Japanese Anglicans among those opposing new US military base
Okinawa Christian Council Committee statement cautions against use of force to ensure peace
Abp Welby announces new Bishop to the Forces and Bishop to the Falkland Islands
The Archbishop of Canterbury, the Most Revd Justin Welby, has appointed the Bishop at Lambeth, the Rt Revd Nigel Stock, as Bishop to the Forces and Bishop to the Falkland Islands


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All Classifieds Legals Legals
DISTRICT COURT SUMMIT COUNTY, STATE OF
81632 | 09/07/2018 | Ad id: 8-0000294874
DISTRICT COURT SUMMIT COUNTY, STATE OF COLORADO Court Address: 501 N. Park Ave. P.O. Box 269 Breckenridge, CO 80424 Case Number: 2018 CV 030071 Plaintiff: MARRIOTT OWNERSHIP RESORTS, INC., a Delaware corporation v. Defendants: Glenn L. Bieler, et al. SHERIFF'S COMBINED NOTICE OF SALE AND RIGHT TO CURE and/or REDEEM SALE NO. 2018 C 0491 Under the Judgment and Decree entered against defendants Donald F. Stark and Carlene E. Stark on August 3, 2018, in the above-entitled action, I am ordered to sell the following property: Resort Interest No. 24, Condominium Unit No. 7324, Designated Unit Type Studio Designated Season Gold, MOUNTAIN VALLEY LODGE (formerly Hotel Breckenridge, a Condominium Hotel), according to the Map filed June 30, 1992, at Reception No. 424104, and according to the Condominium Declaration For Hotel Breckenridge, a Condominium Hotel, recorded June 30, 1992 at Reception No. 424105, First Supplemental Declaration of Condominium and Timeshare Ownership for Mountain Valley Lodge recorded September 20, 1994 at Reception No. 476347 and amendments thereto recorded April 27, 1995, at Reception No. 490152, September 5, 1995, at Reception No. 498382 and December 5, 1995 at Reception No. 504604. The Judgment and Decree directs me to foreclose on the following lien: Notice of Assessment Lien recorded on May 5, 2017, at Reception No. 1140471 of the records of the Clerk and Recorder in Summit County, Colorado, and to apply the proceeds as directed in the Judgment and Decree. The Plaintiff named above is the judgment creditor in this action and the current owner of the evidence of debt (the judgment entered herein) secured by the property being sold. The outstanding balance due and owing on such judgment as of August 3, 2018, is detailed below: $4,266.70 representing: $3,331.10 for delinquent condominium assessments, $519.60 in costs, and $416.00 for attorneys' fees, plus interest to be accrued on the judgment at the rate of 18% per annum. If you are the owner of the real property, or if you are a person who might be liable on the indebtedness secured by the assessment lien, you may have certain statutory rights to cure. Such rights are provided to you under Colo. Rev. Stat. §38-37-108, §38-38-103 and §38-38-104, and Colo. Rev. Stat. §38-38-301, §38-38-304, §38-38-305 and §38-38-306. If the sale date is continued to a later date, the deadline to file a notice of intent to cure by those parties entitled to cure may also be extended. In order to exercise these rights, you must comply with the provisions of the statutes. In the event of any conflict between this notice and the statutes, the statutes are controlling. Therefore, you may wish to read the statutes and consult an attorney of your choice.Intent to cure or redeem as provided by the aforesaid laws must be directed to or conducted at the office of the Sheriff for Summit County, 501 N. Park Avenue, Breckenridge, Colorado 80424. If the borrower believes that a lender or servicer has violated the requirements for a single point of contact in section 38-38-103.1 or the prohibition on dual tracking in section 38-38-103.2, the borrower may file a complaint with the Colorado attorney general, the CFPB, or both, but the filing of a complaint will not stop the foreclosure process. Colorado Attorney General 1300 Broadway, 10th Floor Denver, Colorado 80203 (800) 222-4444 www.coloradoattorneygeneral.gov Federal Consumer Financial Protection Bureau P.O. Box 4503 Iowa City, Iowa 52244 (855) 411-2372 www.consumerfinance.gov I shall offer for public sale to the highest bidder, for cash, at public auction, all the right, title and interest of the defendant in said property on November 2, 2018,at 10:00 a.m. at the Office of the Summit County Sheriff, 501 N. Park Avenue, Breckenridge, Colorado 80424. NOTICE: THE LIEN BEING FORECLOSED MAY NOT BE A FIRST LIEN. DATED this 20th day of August,2018. JAIME FITZSIMONS Sheriff of Summit County, Colorado By: Administrative Assistant to the Sheriff Erin Opsahl LARSEN & LYNCH LLC Diane R. Larsen #11349 175 Main Street; Unit C-104 Edwards, CO 81632 Office: 970-926-9100 Fax: 970-926-9101 Email: Email Me ATTORNEY FOR PLAINTIFF Published in the Summit County Journal First Publication: September 7, 2018. Last Publication:October 5, 2018. 0000294874
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Jessica Clara Schidlow
Drexel University Thomas R. Kline School of Law
Health Law & Managed Care
Prescribing Politics: A Call for Stronger First Amendment Protection of Physician-Patient Communications from State Interference in the Practice of Medicine
Law Student Writing Competition Winner
"The health of my patient will be my first consideration; I will respect the secrets which are confided in me . . . . I will not permit considerations of religion, nationality, race, party politics or social standing to intervene between my duty and my patient; I will maintain the utmost respect for human life . . . . Even under threat, and I will not use my medical knowledge contrary to the laws of humanity"
-Declaration of Geneva (Physician's Oath) [1]
The Physicians' Oath is the moral bedrock of medical practice that touts, above all else, to protect the best interests of the patient.[2] Insofar as those interests are predicated on the physicians' dual knowledge of their patients' needs together with relevant clinical expertise, open and forthright physician-patient communication is vital to achieving positive health outcomes. At the same time, states have the authority to regulate physician speech that occurs pursuant to the licensed practice of medicine.[3] Professional standards of care differ from state-to-state, though, informed consent laws in all fifty states require doctors notify their patients of the material risks accompanying a given medical treatment or procedure.[4] To a greater extent, however, states are passing laws that seek to regulate the content of physician-patient communications beyond the scope considered for traditional informed consent. Such provisions toe a fine line between acceptable professional regulation and physicians' constitutionally protected speech.
The degree of constitutional protection afforded to physician-patient communications from government regulation is the source of on-going judicial debate. Supreme Court precedent on the issue is unclear, pushing lower courts to establish a judicial standard based on their interpretations of those narrow and ephemeral statements of the Court.[5] The outcome is a tangled web of conflicting precedent.[6]
Most recently, the Federal Appellate Courts examined the relationship between state regulations over the practice of medicine and physicians' First Amendment rights through several cases involving reproductive rights, gun rights, and even public rights to confidential company information.[7] This article examines the latter cases to determine how the courts position such restrictions on physician speech within the context of the First Amendment.
Specifically Part II explores the courts' conceptualization of physician speech, and, relatedly, the level of judicial protection afforded from state regulations over physician-speech. Part III examines the current case law vis-à-vis regulations of physician speech of two distinct types: (1) those that compel physician-patient communications; and (2) those that restrict physician-patient communications. In Part IV I suggest that physician speech be granted the highest level of constitutional protection from undue government interference in professional practice. Applying a standard of strict scrutiny, the regulatory provisions surveyed in this article breakdown under the "sufficiently narrowly tailored to the compelling state interest" analysis.[8] Further, I implore the courts to be especially skeptical of state-imposed regulatory laws through which the articulated state interest is markedly undermined by the law's effect. Of particular concern are the laws that operate under the guise of a public heath objective to fulfill states' political and moral agendas. Finally, in Part V, I recommend that the Supreme Court relieve physicians from their untenable position as spokespersons for state ideology by establishing a precedent through which content-based restrictions of any kind between physicians and their patients are unconstitutional.
Physician Speech Under the First Amendment
The relationship between the First Amendment and the states' authority to regulate the medical profession is a bit enigmatic insofar as no single, comprehensive judicial understanding of physician speech regulation has readily emerged.[9] To the extent the Supreme Court has addressed the issue of restrictions on physician speech, it has done so briefly through two non-binding court opinions.[10] Accordingly, the Federal Appellate Courts, relying on their own interpretations of these Court statements, guide our treatment of physician speech under the First Amendment.[11] Yet the Federal Appellate Courts disagree as to whether physician-patient communication, as an inextricable component of treatment, should be classified as conduct, outside the scope of First Amendment protection, or, rather, as constitutionally protected commercial speech.[12] Among the courts that hold physician-speech to the traditional commercial standard, proposed speech regulations receive minimal judicial scrutiny such that, generally, one is upheld so long as the language is "truthful, non-misleading, and relevant"[13]; others apply a more stringent standard, upholding a provision only if it "directly advances" the states' "substantial interest."[14] Relatedly, the issue of whether content-based and speaker-targeted regulations on physician speech should be distinguished as between those that prohibit speech and those that compel speech is an issue of protracted judicial debate.[15] Traditionally, the courts have applied a heightened scrutiny standard exclusively to content-based restrictions.[16]
It follows that three conflicting standards of protection have emerged within the Federal Appellate Courts: the Ninth Circuit classifies physician-patient communications as conduct subject to minimal First Amendment protection[17]; the Fifth and Eighth Circuits treat physician speech like traditional commercial speech such that state-imposed regulations are subject only to rational basis review[18]; and the Third and Fourth Circuits also apply a commercial speech standard yet they afford physician speech greater protection under the First Amendment, subjecting proposed laws to intermediate scrutiny.[19]
First Amendment concerns are raised when a state seeks to regulate physician speech in a manner that wholly conflicts with the professional standards of practice. Of particular concern are the provisions that undermine, be it in spirit or in effect, statutorily imposed informed consent laws.[20] By virtue of the courts' inconsistent standards of review, state governments are, nonetheless, free to project legislative ideology onto the First Amendment language of the constitution.
Examining Laws That Regulate Physician-Speech
Laws That Compel Physician Speech
A state provision that pushes the intended boundaries of traditional informed consent, may harm the physician-patient relationship and impede upon the physician's fundamental rights.[21] To date, the states' have enjoyed the broadest regulatory power in the context of reproductive rights, the latest by reason of abortion consent laws and fetal protection laws.
Abortion Consent Laws
In the landmark case, Planned Parenthood of Southeastern Pennsylvania v. Casey, the Supreme Court upheld a Pennsylvania statute provision requiring physicians to share pre-scripted information with their patients prior to an abortion procedure.[22] Under Casey, informed consent requirements that do not impose a "substantial obstacle" on a woman's right to obtain an abortion are valid if they are "reasonable."[23] To this end, the Court defines reasonableness as "truthful, non-misleading, and relevant."[24] Less clear is whether the Court intended to establish the undue burden test as the exclusive standard for assessing the validity of state-mandated physician-speech in the context of abortion regulation; more precisely, the confusion arises from the tests application, or lack thereof, in the wake of First Amendment challenges.[25]
The incomplete analysis of the proposed informed consent provision left room for Federal Appellate courts to interpret Casey as having created a rational basis standard of review for compelled-speech provisions in the context of abortion.[26] Thus, the courts have given broad deference to the states to direct communications between physicians and their patients.[27]
Relying on a lenient interpretation of Casey, many states have implemented cumbersome abortion consent requirements. For example, states such as Texas and South Dakota enacted laws requiring physicians to perform an ultrasound and to communicate certain information about the ultrasound images to patients prior to the procedure.[28] Whereas the general abortion consent provisions require that certain information be made available, these "speech-and-display" provisions mandate receipt of this information, even if a physician has reason to believe that its delivery poses a danger to the woman's health.[29] Moreover, a number of state-mandated abortion consent provisions contain immaterial, misleading, and even inaccurate information that would, in the context of another medical procedure, be considered a breach of the professional standards of care and thus entirely at odds with the states' informed consent laws.[30]
This misalignment between the fundamental purpose of statutorily defined practice of medicine standards and states' growing abortion consent provisions should raise more than a few judicial eyebrows. Still, the Supreme Court declines to institute a heightened standard of scrutiny for state-compelled physician-speech regulations and, by willfully refusing to do so, has acquiesced to promoting state interests above the health interests of patients.
Forced Reporting of Prenatal Substance Use
Criminalization for maternal substance use reemerged in response to public fears surrounding a substantial rise in the incidence of maternal crack use during the latter part of the nineteen-eighties and early nineteen-nineties.[31]
Ostensibly aimed at government interests in enhancing maternal-fetal health, several states amended their neglect, abuse, and homicide statutes to include infants who are born chemically dependent on controlled substances to which they were exposed in utero.[32] Collectively referred to as Chemical Endangerment Laws, the statutory inclusion of newborn chemical dependency as a "harm" has led to the prosecution of over two hundred women across eighteen states.[33]
Under amended law, physicians' rendering health care services through government subsidized facilities are required to perform a urine analysis on any patient suspected of prenatal drug use.[34]In the event that a woman tests positive for an illicit substance, regardless of amount, these laws compel physicians' to report the case to local authorities, thereby subjecting their own patients to potential criminal sanctions.[35]
Upon enactment of the reporting mandates for prenatal substance use, the American Medical Association Board of Trustees issued a statement condemning all persecutory actions against women for fetal harm, suggesting, "[P]regnant women will be likely to avoid seeking prenatal . . . . care for fear that their physicians' knowledge of substance abuse . . . . could result in a jail sentence rather than proper medical treatment."[36] The American College of Obstetricians and Gynecologists Committee on Ethics voiced similar concerns that these regulations undermine the physician-patient relationship and usurp the physicians' ability to deliver proper treatment, further compromising the health of both the mother and her unborn child.[37]
In effect, fetal protection laws directly undermine the states' articulated objective of improving maternal-fetal health. Despite the absolute failure of these laws to achieve the states' public health goals, the courts continue to allow the government to arrogate the parties' rights to engage in confidential, health-promoting dialog under the First Amendment.
Laws That Prohibit Physician Speech
The practical effects of prohibitive speech statutes are arguably more injurious than those that compel physician speech. Information that is compelled can still be weighed against the opinion of another physician, for example, but when physician speech is banned altogether, the patient is deprived of information that should be communicated for the purposes of obtaining truly informed consent.[38] The dangers posed by regulations that prohibit physician-patient communications are epitomized by Pennsylvania's latest "fracking" provision and Florida's law prohibiting physicians from questioning patients about gun ownership.
The Medical-Gag Rule
The use of hydraulic fracturing, a method used to extract natural gas and oil from the ground, expanded dramatically over the past decade with the advent of more efficient drilling technologies.[39] As the geographical spread of "fracking" continues to grow, so too do the concerns about its health implications; notably, several of the chemical solutions used in the fracking process contain known or probable carcinogens that pose significant health risks to individuals who may be directly or indirectly exposed.[40] Still a number of other chemical components are withheld from public knowledge under laws that protect companies' "confidential proprietary information" or trade secrets.[41]
In 2012, the Pennsylvania legislature amended the existing oil and gas law known as Act 13.[42] Included for the first time were two provisions, together referred to as the "Medical Gag" rule, requiring medical professionals to sign non-disclosure agreements in the event they should need to obtain any information related to chemical trade secrets.[43] In effect, this law bans physicians from discussing industry information with patients whom they suspect of being exposed to and/or sickened by toxic fracking chemicals.[44] Likewise, the Act's gag rule prohibits physicians from discussing cases of potential or known exposure with professional colleagues.[45]
These provisions restrict the physicians' ability to communicate critical health information and thus implicates both physicians' ethical obligations to act in the best interests of their patients, as well as patients' First Amendment interests in receiving non-deceptive medical advice.[46] As a whole, the Act directly interferes with medical standards of care by prohibiting the professional exchange of information for the purposes of protecting public health, and wholly contradicts the state's informed consent laws insofar as they limit patients' ability to determine the underlying cause of their illness. So, physicians are positioned in an absurd catch twenty-two: they can ignore their professional and ethical duties or they can violate the law. In either event, there are serious legal and professional consequences.
Despite its questionable constitutionality, legal challenges to Act 13 under the First Amendment have thus far been unsuccessful.[47] Still, it is inexplicable, at least from a public policy perspective, that the immediate health and safety of the public—our children, elders, and infirm—could fall second to corporate interests.
Limiting Communication About Gun Ownership
In 2011 the National Rifle Association (NRA) proposed, and the state of Florida approved, a law seeking to limit physician-patient communications around gun ownership.[48] The Privacy of Firearm Owners Act, aptly referred to as the "Physician Gag Law", seeks to prohibit physicians from inquiring about a patients' private gun ownership or of such ownership by the patients' family members, and from entering such information into medical records.[49] A physician who violates the law, exposes him or herself to potential disciplinary action by the Florida Board of Medicine, substantial fines, and/or criminal charges.[50]
Legal challenges to the Act came swiftly from doctors, medical organizations, and advocacy groups such as the American Civil Liberties Union.[51] Upholding physicians' First Amendment claims, the U.S. District Court for the Southern District of Florida issued a permanent injunction blocking the law from taking effect.[52] On appeal, however, a three-judge panel of the Eleventh Circuit vacated the district court's ruling, holding the Act to be a "presumptively reasonable regulation of professional conduct."[53] Since 2012, the circuit court has issued two additional opinions upholding the Act under a legal pretense that the Act protects citizens' Second Amendment rights to bear arms.[54] Classifying the Act as a regulation on professional conduct as opposed to speech, the Eleventh Circuit circumvented all First Amendment analysis.
All the same, these outcomes necessarily rely on a legal fiction: that state and/or federal laws permit physicians' to interfere with their patients' lawful ownership, possession, and/or use of firearms. Physicians' basic questioning about gun ownership hardly constitutes a threat to patients Second Amendment rights; restricting communications about gun access does, however, limit the physician's ability to assess for patient risk and undermines their professional and ethical obligations to deliver honest information regarding the safety concerns implicated by certain activities.[55]
On June 21st, 2016, the Eleventh Circuit Court of Appeals, sitting en banc, heard the first round of oral arguments in this latest battle between physicians and gun-rights activists.[56] There is a strong possibility though that this case will reach the Supreme Court on the free-speech claim. Should that be the case, the Supreme Court will have the opportunity to establish a clear position on the regulation of physician-speech, a position that, hopefully, rejects political intrusions into the practice of medicine absent the strictest level of judicial scrutiny.
RESTRICTIONS ON PHYSCIAN SPEECH CALL FOR STRICT JUDICIAL SCRUTINY
The cases discussed above invoke the question: to what extent does the First Amendment prevent the government from imposing additional regulations on the content of physicians' communications with their patients? Although the Supreme Court generally holds content-based restrictions on commercial speech to a heightened standard of scrutiny, the Court has failed to articulate a comparable standard for content-based regulations on physician speech.[57] As a result, government regulations on physician-speech regularly withstand judicial review to the detriment of individuals' fundamental rights.
The Unfortunate Consequences of Minimal Judicial Scrutiny
As precedent stands, states are encouraged to adopt regulatory laws that unduly infringe upon citizens' rights to free-speech, no matter how attenuated the state interest may appear from the language and/or effect of the provision. Often the laws that seek to direct physician-patient dialogue are adopted under the pretense of public health; yet many of these speech-regulatory provisions contradict the evidence-based practices espoused by the medical community and, in fact, thwart the efforts of the well-suited professionals who serve the populations most frequently targeted by the laws' negative effects.[58]
The abortion consent laws and fetal protection provisions were enacted pursuant to the states' articulated interest in protecting the health of women and that of their potential offspring.[59] In theory this is a laudable goal, however, in effect these laws directly undermine the states' purported goals; women who defer obstetric care, take care into their own hands, or deny care all together for fear of condemnation ultimately cause greater harm to themselves and, where relevant, to their fetus'.[60]
The fact that states' continue to rely on largely discredited scientific evidence to promote maternal-fetal health suggests that the interest being protected is one of ideology rather than of public health concern. If the states truly wished to protect maternal-fetal health at every stage, they would adopt policies aimed at prevention and early intervention as opposed to the existing laws that are punitive and restrictive in nature. Ensuring women have access to proper healthcare, including access to contraceptives and effective addiction treatment facilities will, in all probability, contribute to improved maternal-fetal health.[61]
Equally, the speech-restrictive fracking and gun-ownership statues are grounded in weak or otherwise questionable state interests.
We can only assume absent any clear articulation, that the state interest underlying the Medical Gag rule is either the protection of corporate trade secrets or the attainment of natural gases. In either event, the interest should not suffice to outweigh the tremendous public health concerns implicated by these latest fracking procedures.
As noted earlier, Florida's Physician Gag Law is grounded in the state's interest in protecting citizens' Second Amendment rights to bear arms. If we blindly accept the state's Second Amendment argument, are we then to understand that the right to bear arms unquestionably trumps both the fundamental right to free speech as well as the government's obligation to act in the best interest of the public health and welfare of its citizens?
While there is no judicial test that can unequivocally expose ideological agendas concealed within state proposed regulations, the courts can protect vulnerable populations from politically-motivated speech regulations by applying strict scrutiny to any provision that seeks silence or compel physician speech in the context of patient treatment.
Strict Scrutiny as an Appropriate Alternative
The inextricability of physician-patient communications from treatment under the practice of medicine suggests that physician speech ought to be held to a higher standard than all forms of commercial speech. The commercial speech standard fails to protect physicians' First Amendment rights as well as the constitutional rights and the health-related interests of their patients. Ideology-based laws threaten general welfare by undermining the kind of open and honest communication that leads to informed healthcare consumerism and, ultimately, to improved public health outcomes.[62]
What's more, the physician's ability to communicate with his or her patient is already limited by duties imposed by state licensing and ethics boards, the violations of which carry sufficiently punitive results.[63] Likewise, patients' are legally empowered to penalize physicians through the imposition of tort liability for medical malpractice.[64]
Given their extensive medical knowledge and specialized training, physicians deserve the broadest freedoms to communicate with their patients so that, physician and patient together may determine a treatment option best suited to the patients' unique needs.
Therefore, any regulation that undermines, contradicts, or takes discretion away from physicians' to determine what is in the best interest of their patients' health, should be subject to strict scrutiny such that the provision will only survive if it is narrowly tailored to a compelling state interest that cannot be achieved through less restrictive means.
From women's health issues to gun safety, political intrusions into the practice of medicine is a disturbing trend. Agenda-backed laws that seek to regulate physician speech threaten evidence-based practice standards, delivery of safe, quality medical care, and undermine the trust-based relationship between physicians and their patients. Yet state-mandates on physician-speech, regardless of their ulterior aims, will continue to survive this weak standard of judicial scrutiny without so much as nod to First Amendment rights.
To bring about any real change, regulatory laws that lack a strong, evidence-based foundation should be repealed and, moving forward, steps taken to ensure the free exercise of professional judgement so that physicians' can deliver care that is in the best interests of their patients. To ensure that physician-patient communications enjoy as many First Amendment protections as possible, the Supreme Court should also consider an explicit category of professional speech that commands the highest level of judicial scrutiny regardless of the content of or the context in which such speech is delivered.
[1] World Medical Association, Declaration of Geneva, adopted by the 2nd General Assembly of the WMA, Geneva, Switzerland, 1948 (last revised by the 173rd WMA Council Session, Divonne-les-Bains, France, 2006).
[2] Though the words "best interests" are not found within the traditional language of the Declaration of Geneva, they are often read into modern forms of the Physician's Oath ; see, e.g., Peter Tyson, The Hippocratic Oath Today, PBS (Apr. 12, 2016, 3:54 PM), http://www.pbs.org/wgbh/nova/body/hippocratic-oath-today.html.
[3] See Planned Parenthood of Se. Pa. v. Casey, 505 U.S. 833, 884 (1992) (plurality opinion) (noting that the practice of medicine is subject to "reasonable licensing and regulation by the state"). See also, Wollschlaeger v. Governor of Florida, 760 F.3d 1195, 1217 (11th Cir. 2014) ("To define the standards of good medical practice and provide for administrative enforcement of those standards is well within the State's long-established authority to regulate the profession."), aff'd, 797 F.3d 859 (2015).
[4] See Canterbury v. Spence, 464 F.2d 772 (D.C. Cir. 1972) (setting forth the standard for the types of information a physician must provide a patient prior to treatment so that a patient can make an informed decision about whether to proceed with the recommended treatment).
[5] See Robert Post, Informed Consent to Abortion: A First Amendment Analysis of Compelled Physician Speech, 2007 U. ILL. L. REV. 939, 944 ("Although the Court has decided a number of cases about professional advertising, 'the Supreme Court and lower courts have rarely addressed the First Amendment contours of a professional's freedom to speak to a client.'" (quoting Daniel Halberstam, Commercial Speech, Professional Speech, and the Constitutional Status of Social Institutions, 147 U. Pa. L. Rev. 771, 834 (1999))).
[6] See infra Part III (examining cases from the circuit courts' and discussing the courts' application of First Amendment law to physician-patient communications.).
[7] See, e.g., Wollschlaeger; Casey; Sellers v. State, 935 So. 2d 1207 (Ala. Crim. App. 2005); and Gas Drilling Awareness Coalition v. Powers (M.D. Pa. Apr. 2012) respectively.
[8] See Sorrell v. IMS Health Inc., 131 S. Ct. 2653, 2667-68 (2011) ("a prohibition of professional speech is permissible only if it 'directly advances' the State's 'substantial' interest in protecting clients from ineffective or harmful professional services, and is 'not more extensive than necessary to serve that interest.").
[9] See Supra note 5
[11] See infra note 24.
[12] See, e.g., Pickup v. Brown, 740 F.3d 1208, 1227-29 (9th Cir. 2014), (using a "continuum" model to describe the difference between regulations of "conduct," which receive little First Amendment protection, and speech about conduct, which receives some First Amendment protection).
[13] See King v. Governor of the State of New Jersey, 767 F.3d 216, 236 (3d Cir. 2014) ("In the context of commercial speech, the Supreme Court has treated compelled disclosures of truthful factual information differently than prohibitions of speech, subjecting the former to rational basis review and the latter to intermediate scrutiny.").
[15]See Zauderer v. Office of Disciplinary Counsel of Sup. Ct. of Ohio, 471 U.S. 626, 651 (1985) ("The First Amendment interests implicated by disclosure requirements are substantially weaker than those at stake when speech is actually suppressed . . . . where their policies implicate rights so fundamental that strict scrutiny must be applied.").
[16] See, e.g., Pickup, 740 F.3d at 1231 ("[C]ontent- or viewpoint based regulation[s] . . . must be closely scrutinized."); Wollschlaeger, 760 F.3d at 1239 ("Content-based statutes . . . are presumptively invalid." (quoting R.A.V., 505 U.S. at 382)).
[17] See, e.g., supra note 12 at 1229 (noting that where a state regulation on physician conduct has an "incidental effect on speech," First Amendment concerns are lessened).
[18] See, e.g., Lakey, wherein the court dismissed a compelled-speech challenge of Texas's display-and-describe requirement; see also, Rounds (turning on the application of the truthful-and-not-misleading test articulated in Casey).
[19] See, e.g., Stuart v. Camnitz, 774 F.3d 238 (4th Cir. 2014); see also, N.J. STAT. ANN. § 45:1-54 (West 2016) (prohibiting mental health professionals from practicing "conversion therapy" with minors).
[20] See, e.g., Camnitz at 254 (The court states: "The rupture of trust comes with replacing what the doctor's medical judgment would counsel in a communication with what the state wishes told. It subverts the patient's expectations when the physician is compelled to deliver a state message bearing little connection to the search for professional services that led the patient to the doctor's door.").
[21] See, e.g., Gayland O. Hethcoat II, In the Crosshairs: Legislative Restrictions on Patient-Physician Speech About Firearms, 14 DePaul J. Health Care L. 1, 18 (2011) ("When a regulation goes further than discriminating in content and discriminates in viewpoint . . . the odds of withstanding judicial review become even greater, if not insurmountable.").
[22] See Casey at 833.
[25] See Lauren Paulk, Article, What Is an "Undue Burden"? The Casey Standard as Applied to Informed Consent Provisions, 20 UCLA WOMEN'S L.J. 71, 97 (2013) (noting that "courts differ in their manner of addressing First Amendment challenges in the context of abortion regulations, leaving a split in the [c]ircuits on how to address informed consent provisions").
[26] See Camnitz at 249 ("the plurality simply stated that it saw 'no constitutional infirmity in the requirement that the physician provide the information mandated by the State here.' That particularized finding hardly announces a guiding standard of scrutiny for use in every subsequent compelled speech case involving abortion." (quoting Casey, (plurality opinion)), cert. denied, (2015).
[27] See infra Part III
[28] See supra note 18.
[30] See, e.g., ARIZ. REV. STAT. ANN. § 36-2153 (2015) (requiring physicians to inform women seeking abortions of the medically unsubstantiated "fact" that it may be possible to reverse the effects of a medication abortion); N.C. GEN. STAT. ANN. § 90-21.85(b) (2011) (requiring physicians to perform ultrasounds on women seeking abortions to display the image and to describe the fetus, even if the woman actively averts her eyes), invalidated by Camnitz at 238; and Rounds at 735 (Planned Parenthood argued that the compelled disclosure was untruthful and misleading because it implied a "causal link between abortion and suicide" that was not established by medical authority. The majority held that the state did not need to establish conclusive proof of causation between abortion and the increased risk of suicide and suicide ideation in order to mandate the disclosure of the "identification [of suicide and suicide ideation as] a medical risk.").
[31] See Lynn M. Paltrow, et al., Year 2000 Overview: Governmental Responses to Pregnant Women Who Use Alcohol or Other Drugs, Report of the Women's Law Project and National Advocates for Pregnant Women, available at www.advocatesforpregnantwomen.org/articles/index.htm.
[32] Id. at 467 ("In some states that have not amended their laws, government officials have, by regulation or practice, extended existing civil child abuse laws to pregnant women despite the lack of legislative intent or specific authority to do so.").
[36] Report of American Medical Ass'n Board of Trustees, Legal Interventions During Pregnancy, 264 JAMA 2662, 267 (1990).
[37]American College of Obstetricians and Gynecologists, Committee on Ethics, Committee Opinion 321 Maternal Decision Making, Ethics and the Law, 106 Obstetrics & Gynecology 1127 (2005).
[39] Hydraulic Fracturing or "fracking″ refers to a method of recovering oils and natural gases from the earth; pressurized water, industrial additives, and sand are blasted down into underground wells to fracture or break open rock formations that trap oil or gas. See Philippe A. Charlez, Rock Mechanics: Petroleum Applications 239 (1997).
[40] See Theo Colborn et. al., Natural Gas Operations from a Public Health Perspective, 17 Hum. & ecological Risk Assessment: Int'l J. 1039, 1040, 1045-46 (2011) (listing chemicals found in fracking fluid with ten or more known adverse health effects); Agents Classified by the IARC Monographs, Volumes 1-109, Int'l Agency for Res. on Cancer, available at http://monographs.iarc.fr/ENG/Classification/index.php (last updated Oct. 30, 2013) (containing a list of chemicals suspected or known to be carcinogenic to humans).
[41] See Rebecca Jo Reser, State and Federal Statutory and Regulatory Treatment of Hydraulic Fracturing, 80 DEF. COUNS. J. 90, 93 (2013).
[42] 58 PA. CONS. STAT. ANN. § 3222.1.
[43] Id. § 3222.1(b)(11).
[46] See, e.g., Pickup, at 1229 (noting that the first amendment "safeguards individuals' thought processes and expression against government suppression."); Casey, at 916 (Stevens, J., concurring in part and dissenting in part) ("Decisional autonomy must limit the State's power to inject into a woman's most personal deliberations its own views of what is best.").
[47] See Shannon Zabel, Docs v. Glocks: The Need For First Amendment Protection In Preventative Care, 24 Temp. Pol. & Civ. Rts. L. Rev. 483 (2015).
[50] See FLA. STAT. § 790.338 (2014) (codifying Florida's Firearm Owners Privacy Act).
[52] Wollschlaeger v. Farmer, 880 F. Supp. 2d 1251, 1257, 1270 (S.D. Fla. 2012).
[53] Wollschlaeger, 760 F.3d at 1203 (upholding Florida law as a legitimate regulation on physician conduct with only an incidental effect on speech).
[55] See American Academy of Pediatrics, Policy Statement: Firearm-Related Injuries Affecting the Pediatric Population, 130 PEDIATRICS 1416, 1421 (2012) ("The AAP recommends that pediatricians incorporate questions about the presence and availability of firearms into their patient history taking and urge parents who possess guns to prevent access to these guns by children.").
[56] Katheryn Hayes Tucker, 11th Circuit to Weigh Safety Against Rights at Docs v. Glocks En Banc Hearing, Daily Reporter, June 17, 2016.
[58] See Stuart v. Loomis, 992 F. Supp. 2d 585, 597 (M.D.N.C. 2014) (stating that the Supreme Court has repeatedly acknowledged the state's "interest in protecting the integrity and ethics of the medical profession" and declaring that the "state's regulation of professional speech must be consistent with the goals and duties of the profession" (citing Washington v. Glucksberg, 521 U.S. 702, 731 (1997)), aff'd sub nom. Camnitz,, cert. denied, (2015)).
[59] David C. Brody & Heidee McMillin, Combating Fetal Substance Abuse and Governmental Foolhardiness Through Collaborative Linkages, Therapeutic Jurisprudence and Common Sense: Helping Women Help Themselves, 12 HASTINGS WOMEN'S L.J. 252 (2001).
[61] See Page McGuire Linden, Drug Addiction During Pregnancy: A Call for Increased Social Responsibility, 4 AM. U. J. GENDER & L. 105, 134 (1995) (stating negative effects of substance abuse during pregnancy are improved by providing prenatal care and drug treatment).
[62]See Conant v. Walters, 309 F.3d 629, 639 (9th Cir. 2002) ("An integral component of the practice of medicine is the communication between a doctor and a patient. Physicians must be able to speak frankly and openly to patients."); see also, Trammel v. United States, 445 U.S. 40, 51 (1980) ( "[T]he physician must know all that a patient can articulate in order to identify and to treat disease; barriers to full disclosure would impair diagnosis and treatment.").
[63] See supra note 5.
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Jessica has her M.A. in Clinical & Counseling Psychology and worked as an out-patient child & family-based therapist before pursuing a legal education. Jessica is an Accelerated J.D. candidate at Drexel University Thomas R. Kline School of Law. Jessica's interests include family law, contract law, medical law, women's rights, legal academics, and the relationship between psychology and the law. She plans to sit for the Pennsylvania & New Jersey bar exams in the summer of 2017.
Jessica.Schidlow@gmail.com
drexel.edu/law/


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Stonewall is a charity founded in 1989 by a small group of women and men who had been active in the struggle against Section 28 of the Local Government Act.
Its aim from the outset was to create a professional lobbying group that would prevent prejudice against and attacks on lesbians, gay men and bisexuals. Stonewall has subsequently put the case for equality on the mainstream political agenda by winning support within all the main political parties and now has offices in England, Scotland and Wales.
We support Stonewall through it's Global Diversity Champions programme - the best-practice employers' forum for international organisations who are committed to LGBT equality across the world. We have annual membership to the programme, attend the yearly Workplace Conference and take part in the Workplace Equality Index.