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Squash Habañero Chutney
A great big THANK YOU to TasteSpotting, for graciously adding my Squash Habañero Chutney recipe to the Patrón Social Club: "TasteSpotting this summer brings the perfection of Patrón into your kitchen with entertaining tips, ideas, and recipes created especially for Patrón." (Links below)
About the recipe:
I like it fiery hot. Whenever I mix up a big batch of my homemade Habañero Chutney, I'm usually the only one who ends up enjoying it. So, for the whole room of dinner guests to eat and enjoy, I make a version that includes apple and squash, which temper the heat of the Habañero.
Making a chutney is really quite simple. It just takes a little bit of patience to stand next to the stove, which just happens to be my favorite spot in the house.
The chutney is the perfect accompaniment to a simple grilled Flat Iron Steak.
My Step-by-Step Photos Recipe on the official Patrón Social Club website
Prepped & Ready to Cook!
Slowly Cooking Chutney. Grilling Flat Iron Steak on Grill
Grilled Flat Iron, Squash Habañero Chutney
About the Habañero Chili
About Flat Iron Steak (my current favorite beef cut)
Recipe posted soon
Tagged as club, Flat Iron, Flatiron, food blogger, food photographs, food photos, food writer, foodie, Grilled Steak, Habañero Chutney, habanero, LA foodie, los angeles, patron, patron social, pumpkin, spicy chutney, Squash, steak, tastespotting
Wonder Twins
On Wednesday evenings I cook dinner at my sister Janet's house in San Dimas. It's the only night of the week when all the kids are home for dinner, and it's the one night a week I get to spend some quality time with my family. I usually grill up some flat iron (or flank) steak and serve it with bacon-wrapped baby potatoes or some other bacon-wrapped side. The kids love steak and bacon, but it's definitely a treat in my sister's very healthy household. She always provides the veg and salad, and the kids help me prepare dinner after homework.
Janet has four kids and is an incredible mother. I don't have kids (except for my three dogs that I treat like kids!), so I've always made an effort to be a part of their lives. Cody is 19 and is currently training to be an EMT and firefighter like his dad. Camron is 22 and lives nearby. The twins, Kindal and Chace are the kids that I spend the most time with now, and today the twins are turning thirteen!
My two passions in life are food (obviously) and music, so those are the things that I've always shared with the twins. As I posted in the "About" section of the blog, a few years ago I started the "Chef Monkey" cooking club just so I could spend more quality time with my niece and nephews. Up until a few months ago, we held regular classes at my sister's home, but now with the kids after-school schedules so overbooked (soccer, basketball & homework), we hold the club during the summer months only.
The Chef Monkey club motto is "We Cook Because We Can… Duh!". A fun and important part of the club is making up songs to help the kids (and us grownups!) remember food terms. I still sing the "Mother Sauce Rap" when I'm making a pot of Béchamel or any of the five classic French "mother" sauces: Béchamel, Veloute, Español, Tomato, and Hollandaise.
The Mother Sauce Rap:
Béchamel is white
It's so easy to get right
Velouté is made with stock
The flavor really rocks
Español is brown
It's used all over town
Tomato sauce is easy
Sometimes we make it cheesy
Our favorite Hollandaise
It's just lemon, butter and eggs
This is what we call…
the Mother Sauce Rap 2, 3, 4…
The Mother Sauce is Wrapped… Out!
Over the years the kids cooked for firefighters (at the fire station!), volunteered at a women's shelter, and catered special "Panini Night" fundraising events. This past summer we held a "Chef Monkey Cooking Camp" at Alexandria House, a transitional residence for women and children. The Chef Monkeys got to share their joy of cooking with kids less fortunate, and at the end of the lesson we enjoyed the meal together. It was amazing and we plan to do again next summer.
When the twins were five I started teaching them how to play guitar. My husband Peter taught me, so I would learn a few chords then show the kids. I've played piano and written songs since I was five, but guitar really changed my life and I loved sharing it. When Chace learned to play the drums, we started a band and called it "Kitten's Whip". The name was because of Kindal's fiery attitude. Nicknamed "Kitten", she has always had that "rebel rocker" thing going, even as a toddler. Chace has always been the calmer one, and he would often roll his eyes at his twin sister (he still does).
For the twin's fifth birthday, Peter and I held a "Rock Show" in our back garden. They performed to the Monkee's "I'm a believer" and Madonna's "Don't Tell Me". The twins didn't actually play guitar for that "gig", but had a great time being on "stage", singing to all the fans. We had tour posters, t-shirts and a packed garden full of friends cheering them on in the "audience". It was crazy but the kids loved it! Two years later, Kitten's Whip was on stage at the world-famous Whisky-a-GoGo.
The gig was for my 40th birthday and it's something we thought was "once in a lifetime"… until January 8th, 2007 when we played on stage at the Troubadour. This time it was for Peter's 50th and we opened for his band, Rubylith. The twins were just turning eleven and the whole family joined in for this gig. Kindal on guitar and vocals, Chace on guitar and vocals, Cody on drums, Camron on base, myself and Janet on guitar, with her husband Paul acting as our stage "security". Even our brother Greg flew in to play keyboards with us. He lives in Scotland with our dad and came in for both the Troubadour and Whisky gigs.
We played two songs at the Troubadour show and it was important to me that we all play our instruments on stage (no cheating!), and also that we put on a good show for Peter and his friends. Band practice was held every week at my sister's house and it was hilarious. Week after week of Poison's "Nothing but a good time" and Motley Crue's raucous version of "Smoking in the Boys Room" would sometimes turn into a chorus of "we are never going to get the timing down!". We did, and it was fantastic fun.
I remember being in the dressing room before I went on the Whisky-a-GoGo stage (for my 40th). Kindal came in and I asked her if she was nervous, because I was getting nervous. I mean… this was the stage where I used to see "X" and Motely Crue perform when I was a teenager. At just SEVEN years old, she looked up, smiled and said "No way. I'm not nervous… I'm just really excited!". That changed my attitude right then for the Whisky gig, and also at the Troubadour show. We practiced those two songs for an entire year, got on stage, and NAILED IT. It was awesome.
We still play music together regularly. Besides the electric guitars, the twins each have an acoustic and a drum set. Kindal even writes her own songs and Chace backs her up when they perform for friends. Needless to say, whenever I spend time with the kids we are either cooking or playing guitar… usually both.
Over the years, friends have asked "are you trying to get signed?" or "are you trying launch music careers for the kids?". Living in Los Angeles has many benefits, especially with Uncle Peter's job (he's a VP at a movie studio). So that means the kids get to attend movie premieres every so often, and we get to rent out a legendary nightclub for a special evening, but it also means that no one believes you when you say "we're just doing this for fun". It's not about playing on stage and trying to be "famous". For me it's about the precious time we spend together… the weekly visits, working together, learning together, laughing, struggling, then coming together at the end and delivering.
Whether it's cooking with the twins or playing music with the twins, they both fill me with so much joy and love, that I never missed having my own children.
So on this, their thirteenth birthday I want to say… thank you to my super, fantastic wonder twins. Thank you Kindal and Chace for always being so good to your crazy Aunt Jo.
Here's to many more years of music, cooking and wonderful adventures together.
Happy Birthday! xoxo
Update: Photos from the twins 13th Birthday Dinner at "Claim Jumper"!
Chace with his date, Marissa
Kindal with her date, Tony
A Teen Food Fest
Chace… attempting death by chocolate!
he survived (with help from Tony) !
"I'm not telling you what I'm wishing for!"
Kindal and her best friend Ilana…. who is also an original "Chef Monkey"!
Wrapping up the evening…
Chace & Marissa
Tony & Kindal
Chef Monkeys
Kitten's Whip
Rubylith (Peter's band)
Alexandria House
Whisky-a-GoGo
Chef Monkeys on YouTube
Our birthday gift to the twins: Dinner at Michael Mina in San Francisco!
" Wonder Twins" Written by Jo Stougaard ©MyLastBite.com All Rights Reserved. No usage allowed including copying or sharing without written permission.
Filed under Family Stories, Food Stories (written by me)
Tagged as a-gogo, angeles, birthday, blogger, bloggers, Chef, club, cooking, family, food, food blog, food bloggers, food blogs, jo, kitten, kitten's, la, los, los angeles, molecular gastronomy, monkey, monkeys, my last bite, mylastbite, troubadour, twins, whip, whisky, whisky a gogo


The Lord immediately forgives us of everything thing that we ever do that is wrong because He is love and mercy itself. The premise is that we have to stop doing a questionable behavior in order for the forgiveness to mean anything, because until we stop the Lord's love and mercy can not enter in and find a place with us. It is never that the Lord is not willing to forgive us, but that we are unwilling to change our behavior and let His forgiveness have effect in our life.


Divorce and Family Law Blog | Nebraska Legal Group, P.C.
Undoubtedly, one of the most serious aspects of any divorce or paternity case is how the Divorce Court (or the parties themselves), will ultimately determine the issue of child custody and visitation. While the path of a child custody case in the Omaha courts is fairly predictable, clients get in trouble when they lose sight of the overall importance of custody agreements, especially when their divorce lawyers fail to keep them focused on the impact these decisions will have on the children.
While it certainly should not be a go-to move in the normal course of your divorce case, there ARE certain situations in which you should consider terminating your divorce lawyer and hiring a new one.
Going through a divorce can leave you feeling like you are not in control of your life. But by being informed, cooperative and organized, you can actually control the legal expenses related to your divorce case.
Law schools typically do not offer courses on divorce law. So when people graduate from law school, they know nothing, or close to it, about this type of case.
If you and your spouse agree on most of the major aspects of your divorce and can communicate with each other in a civil manner, you can save time, money and anxiety by getting a mediated divorce.
Many people think there are dozens of decisions to make in a divorce and that all of the marital assets are "up for grabs" in the divorce process. That is not true. While people picture a 100-yard football field, what we are really dealing with in most divorces is a 10-yard football field.
Most people enter the divorce process thinking their case has to be handled a certain way and that the lawyer will dictate the process. Lawyers will tell you the way they want to proceed or how it normally goes, but the truth is that your case does not have to be handled in one particular way.


Saving until you have a large deposit will reduce interest over the years of repayments.
Spend some time discussing with your partner what kind of home you want. Buying a smaller home may save you some money, but will it be big enough for future family growth? You also need to decide on the suburb you want to live in.
When you go to inspect homes, don't just look at the inside, but also the outside surroundings. Tall trees close by may come crashing over your home in the next gale. High buildings could make getting solar energy impossible. You also need to know there is close access to the kind of amenities you need or will need in the future.
Never purchase a home without having a building and pest inspection done. This will find out any faults in the home that are not readily visible and can save a lot of heartache in the future.
Check for wet patches in the ground outside the home. This could point to a break in the plumbing or water seepage from another property.
Don't be blinded by an attractive garden or the staging. You need to look beyond that to ensure the home will work for you. Are there enough power points? Is there Internet access? Do the taps or cistern leak? Are the rooms big enough?
Look at the orientation of the home. If the living area faces north or northeast, it will be much more pleasant to live in, with natural light and warmth in those areas. But if they face south or west they will be either too dark and cold or too glary for comfort.
Look at how much storage there is. With homes becoming smaller by the year, some are short on storage and there is nowhere much to add cupboards. That said, creative use can be made of the spaces under the bed, under the stairwell or in some hidden corner.


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Oil tumbles as new virus strain revives demand fears
in Closing Bell Story / Commodity Pricing / Crude Oil News / Energy News by— Oil & Gas 360
December 21, 2020	Share Print
LONDON -Oil prices tumbled on Monday as a fast-spreading new coronavirus strain that has shut down much of Britain and led to tighter restrictions in Europe sparked worries about a slower recovery in fuel demand.
Brent crude was down $2.23, or 4.3%, at $50.03 a barrel by 1421 GMT, while U.S. West Texas Intermediate (WTI) crude fell $2.21, or 4.5%, to $46.89.
Both contracts had lost as much as $3 earlier in the session, their biggest daily drop in six months.
"Reports of a new strain of the coronavirus has weighed on risk sentiment and oil. New mobility restrictions across Europe are also not helping as European oil demand will suffer," said UBS oil analyst Giovanni Staunovo.
"Investors need to be mindful that the road to higher oil demand and prices will remain bumpy."
Brent climbed above $50 last week for the first time since March, buoyed by optimism stemming from COVID-19 vaccines.
But a new COVID-19 strain, said to be up to 70% more transmissible than the original, has renewed fears about the virus that has killed about 1.7 million people worldwide.
More countries closed their borders to Britain on Monday, causing travel chaos and raising the prospect of UK food shortages.
"The new strain of the coronavirus in the UK has shown us that the vaccine optimism holding Brent above $50 per barrel could be deflated in a fleeting moment," said Rystad Energy analyst Louise Dickson.
The new virus strain has already been detected in other countries, including Australia, the Netherlands and Italy.
Russian Deputy Prime Minister Alexander Novak said the new strain had an impact on oil prices, adding that recovery of global oil markets was happening slower than previously expected and could take two to three years.
The negative sentiment overshadowed the rollout of a new vaccine in the United States, a deal among U.S. congressional leaders for a $900 billion coronavirus aid package and European regulatory approval on Monday for the use of the COVID-19 vaccine jointly developed by U.S. company Pfizer and its German partner BioNTech.
The approval by Europe's medicines regulator puts the region on course to start inoculations within a week.
Tags: 360 News Desk, new virus strain, OAG360, Oil, tumbles

redpajama_set_name: RedPajamaCommonCrawl


A Building, Electrical, Mechanical, and Plumbing Permit should be applied for and received prior to any work taking place in Milford Township.
Inspectors work part time and require 24 hours notice for inspections. Inspections cannot be scheduled directly with the inspector, please call Township Offices to schedule an inspection at 248-685-8731. Exact times for inspections are not possible, see the range below (and are subject to change).
Homeowners may obtain permits without a license, if you are going to do the work. As the general contractor you will be responsible for the work and to make sure it meets the current Michigan Building Codes.
This function is provided by Oakland County. Please read all information prior to submitting payment.


The PR Verdict: A (PR Perfect) for Prince Harry.
The headlines are too easy: "The Trouble With Harry." "Dirty Harry." Prince Harry's escapade in Las Vegas—a strip poker game that ended with photos of a naked royal—was almost a gift to the tabloids. And yet the Crown may have a PR ace up its sleeve in Harry.
Harry has always been the heir apparent for royal scandal. As third in line for the throne, the pressure to conform to royal standards of propriety is relatively low. Need we go into his father's anatomical declarations of love for Camilla Parker Bowles? Please, let's not.
And yes, the young prince occasionally acts out. But this latest adventure had a curious side effect: Harry's generation seems smitten with him. He is like his peers, caught in some NSFW (Not Suitable For Work) photos. Among Harry's generation, fame—in any context—is gold. Sealing the turn from scandal to success was Harry's appearance at a charity event, where he acknowledged his escapade with self-effacing humor (read about it here). Scandal averted, Harry is now the unlikely hero.
The PR Verdict: A (PR Perfect) for Prince Harry. If Buckingham Palace is smart, they'll continue to rap Harry's knuckles—and keep him in front of his adoring public, continuing his mother's legacy: Could he become the People's Prince?
The PR Takeaway: Mini-scandals can move the PR dial. After doing something naughty but harmless, a public appearance for charity and self-effacing humor are the golden tickets to winning the public's, and the media's, hearts. The ploy was used to excellent effect by Fred Willard in the US; days after the actor was caught with his pants down in an X-rated movie theater, he joked about the incident brilliantly on late night TV. Prince Harry should continue to do good works, which offset his occasional lad-like behavior; both bring a younger generation closer to the Crown.


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Security Systems F.C. are a football club from Otse, Botswana, currently playing in the Botswana Premier League.

History
Systems won promotion to the 2012-13 Botswana Premier League, but failed to pay the subscription fee and were denied a spot in the top flight. They then lost to BR Highlanders in the promotion playoffs in 2013-14.

Systems were then deregistered after the 2013-14 season and merged with second division Tsholofelo Rolling Boys. Rolling Boys were promoted again after the 2016 season and changed their name back to Security Systems for their first season in the top flight.

References

Football clubs in Botswana

redpajama_set_name: RedPajamaWikipedia


When you're overwhelmed with debt, it's hard to know where to turn or how to find resources that will help you the most. Maybe you've heard Dave Ramsey talk about money on the radio, listened to his podcast, or even read one of his books. But how can you find all the right "Dave Ramsey budget forms" for getting started? There are so many great forms to choose from!
Below you'll find a short list of free Dave Ramsey budget forms that will be the most helpful to you as you're getting started. I tried to keep this list simple, with the basic budget forms you might need to get started. If you want more options, click here for my longer list with tons of pretty Dave Ramsey printables.
Now, without further ado… here are some forms to get you started.
Use this Monthly Cash Flow form to organize everything you need to pay and your debt minimum payments. Next to everything write the due date.
Then, use this Spending Plan form to create your budget. You need a column PER PAYDAY which will change every month. If you're paid weekly or bi-weekly, some months will have more than four pay columns.
Like Dave says, you've got to tell your money what to do or it will leave. Be diligent about using these budgeting forms, and know where your money is going — every penny of it!
If you get paid a variable income rather than a set amount each payday, it can be somewhat confusing to get started. Dave has this Irregular Income form to help you plan for each income source.
As you're setting up your budget, you may find that you need to call certain utilities, creditors, or other billing companies and request to change billing cycles. Usually there's no problem when you try to tweak your "due by" dates, within reason. Don't be intimidated! Many companies are happy to help if they feel it will help them receive your payments in a timely manner.
If you're pretty far behind with your bills and can't seem to get current, here are helpful tips about what to do when you can't pay your bills.
While we were paying off debt, I found encouragement in memorizing bible verses about money and thinking through what the bible has to say about money, contentment, and wealth. I've created these 24 printable scripture cards about money to help you stay inspired, too. They're perfect for carrying along in your purse or bible and pulling out as you go about your day!
I also designed a beautiful Budget Binder Toolkit that has really helpful budgeting forms, plus all the printables are easy to use. It's easy to print them, fill them out, and put them in a three pronged binder. Everything you need is there in one easy PDF file. There's even a "spending journal" printable! You can learn more about the Budget Binder Toolkit here.
You can do this! One step at a time, my friend. Just keep putting one foot in front of the other, and you'll get there. It's worth it!
Before you go, take a minute and tell us about some Dave Ramsey Budget Forms that have been helpful to you. We'd love to know.
Cook at home more often. We used to waste so much money going out to eat! This is a constant struggle for us as a busy family. Try a program like emeals (the link takes to you a free 14-day trial) to help you create simple, inexpensive meals at home if you struggle in this area like I do. You'll save MORE money on your groceries each month than the small amount you pay for their service.
Create a budget. Mvelopes is the online budgeting program we personally use and LOVE. In fact, we purchased a lifetime membership several years ago when they offered it to us. It's like a virtual cash envelope system, and it syncs with your bank accounts. Here's my full Mvelopes review, or you can click here for a free 30 day trial of Mvelopes.
My husband and I took a FP course years ago, but we never fully followed the plan. We're not doing well again and I was looking around online, wishing I had access to the FP stuff now, just quickly, not the whole book to go through. Then today I saw your request to join my group boards and I immediately saw this post! How awesome is our God?! Something that others might think is insignificant is actually Him working in our lives.
If you have previously taken the course, you can contact over of the local group's leaders and all about getting one for a discounted rate since you already took the course. I was able to get the new course for only $50 and took it all over again just as a refresher.


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By Farrell Fritz P.C. on January 5, 2022
Posted in E-discovery, ESI, FRCP, Legal Hold, Preservation Obligation, Spoliation
Ephemeral messaging applications are considered solutions for data protection and privacy concerns (Blink, And I'm Gone: E-Discovery Challenges and Considerations With Ephemeral Messaging). However, courts are wary of ephemeral messaging applications given they can empower a litigant to avoid discovery obligations. A recent decision from the District Court for the District of Arizona, details the consequences of using improperly ephemeral messaging applications (Fed. Trade Comm'n v Noland, 2021 WL 3857413 [D. Ariz. Aug. 30, 2021]).
The Federal Trade Commission (the "FTC") was conducting an investigation into the operations of Success By Health ("SBH") and its principals James Noland ("Noland"), Thomas Sacca ("Sacca"), and Scott Harris ("Harris"). On May 16, 2019, Noland learned, through the inadvertent disclosure of a bank subpoena, of the FTC's investigation. Soon thereafter, Noland, Sacca, Harris and SBH's employees began using – at Noland's direction – two messaging applications for the purpose of discussing important SBH business. The first application, Signal, is a mobile messaging application with automated deletion functionality; and the second application, ProtonMail, is an encrypted email service provider.
On May 29, 2019, after learning that its investigation had been disclosed, the FTC instructed SBH, Noland, Sacca and Harris to "suspend any ordinary destruction of documents, communications and records." At the conclusion of the investigation, on January 8, 2020, the FTC filed a lawsuit against SBH, Noland, Sacca and Harris (collectively "Defendants"), alleging Defendants operated an illegal pyramid scheme and made false statements to consumers. Soon thereafter, the FTC obtained a temporary restraining order ("TRO") and the appointment of a receiver to operate SBH. Pursuant to the TRO, Defendants were required to transfer to the receiver control of all methods for handling communications. Defendants, however, failed to disclose the existence of Signal or ProtonMail. It was not until October 2020 that the FTC learned Defendants had used Signal and ProtonMail as means to communicate.
The FTC promptly filed a motion for sanctions pursuant to FRCP 37(e)(2), arguing Defendants intentionally spoliated documents when they migrated SBH's communication platform to Signal and ProtonMail, and did so only after the duty to preserve arose. In opposition, Defendants argued the decision was caused by security concerns presented by a former employee and his fellow saboteurs.
As highlighted by the Court, FRCP 37(e) was "completely rewritten in 2015 to provide[] a nationally uniform standard for when courts can give an adverse inference instruction… to remedy the loss of ESI." Specifically, a party seeking sanctions under FRCP 37(e)(2) must first show "(1) the ESI should have been preserved in the anticipation or conduct of litigation; (2) the ESI is lost because a party failed to take reasonable steps to preserve it; and (3) the ESI cannot be restored or replaced through additional discovery" (Noland, 2021 WL 3857413, at *6). If each of these elements are satisfied, courts then determine whether the nonmovant "acted with the intent to deprive another party of the information's use in the litigation" (id.).
Here, the Court concluded that the FTC easily carried its burden in showing that "Defendants acted with the intent to deprive the FTC of the information contained in the Signal and ProtonMail messages." According to the Court, "the most decisive factor" in reaching this conclusion was the timing of Defendants' migration to Signal and ProtonMail. Further, the Court rejected Defendants' argument that the use of these applications was in response to security concerns, as Defendants failed to provide any evidence that SBH was being hacked, or threatened. As a result of Defendants' systematic efforts to destroy relevant communications through Signal and ProtonMail, the Court granted the FTC's motion for sanctions and granted the FTC an adverse inference instruction that the deleted Signal and ProtonMail communications were relevant to the litigation and supportive of the FTC's position.
While ephemeral messaging technologies may be ideal security solutions, companies must avoid implementing such technologies, if a duty to preserve has been triggered or is ongoing. Therefore, when advising a client about messaging applications, it is critical to be conversant with the client's data retention policies and active litigation holds, if any.
Thank you to second year associate, James Maguire in the Firm's Uniondale office, for his research assistance related to today's blog.
Posted in Cyber Crime, Cyber Security, Cyber Threat, ESI, FinCEN, SARs
In a few short weeks, the global loss attributable to cybercrime is expected to surpass $6 trillion.* Therefore, in an effort to protect financial institutions and consumers from further loss, agencies including the United States Securities and Exchange Commission (A Cybersecurity Wake Up Call: SEC Sanctions Eight Firms for Cybersecurity Deficiencies) and the United States Department of the Treasury Financial Crimes Enforcement Network ("FinCEN"), are prioritizing cybersecurity enforcement actions and offering guidance on how to detect and report suspicious ransomware attacks (Advisory on Ransomware and the Use of the Financial System to Facilitate Ransom Payments) (the "Advisory"), respectively.
The chilling factual predicate for the Advisory involves a marked increase in both cybercriminal activity and the sophistication of ransomware methods used by criminals who have successfully attacked critical U.S. infrastructure. In its effort to educate financial institutions about identifying cyberattacks, the Advisory offers 12 financial "red-flag indicators" including: (i) detecting IT enterprise activity (i.e., malicious cyber activity), which is connected to ransomware cyber indicators (e.g., suspicious registry or system file changes); (ii) awareness that a payment is in response to a ransomware incident; (iii) a customer's convertible virtual currency ("CVC") address being connected to ransomware related activity; (iv) an irregular transaction between an entity in a high risk sector (e.g., government, financial, healthcare), and cyber insurance companies ("CIC"); (v) receipt of funds by a CIC or incident response company that sends the equivalent amount to a CVC exchange; (vi) a customer who shows limited knowledge of CVC, yet requests information or purchases CVC; (vii) a large CVC transaction sent by a customer with limited history of CVC transactions; (viii) a customer who has not registered with FinCEN as a money transmitter, but who appears to be executing offsetting transactions between various CVCs; (ix) a customer using a foreign-located CVC exchanger in a high-risk jurisdiction; (x) a customer receiving CVC from an external wallet and immediately initiating multiple trades with no apparent related purpose; (xi) a customer initiating a transfer of funds through a "mixing service" (i.e., a mechanism used to launder ransomware payments); and (xii) a customer using an encrypted network to communicate with the recipient of a CVC transaction.
Additionally, the Advisory provides updated guidance relevant to a financial institution's obligation to file suspicious activity reports ("SARs"). For example, the Advisory updates an October 2020 advisory to include an obligation to identify and immediately report any suspicious transactions associated with ransomware attacks. The importance of complying promptly with this new reporting obligation cannot be overstated because, according to FinCEN, ransomware attacks are serious and evolving and "require immediate attention." Similarly, information sharing among financial institutions about attacks, attempted attacks, and vulnerabilities is invaluable for preventing future attacks. And, financial institutions need not worry that such information sharing would run afoul of confidentiality requirements, as Section 314(b) of the USA Patriot Act explicitly permits financial institutions, upon notice to the Department of the Treasury, to share information with one another in order to identify and report suspicious activities.
As the Advisory suggests, financial institutions must take an active role in detecting and reporting ransomware attacks if we are going to thwart further ransomware attacks. An advisable first step for financial institutions is to update cybersecurity policies to include these "red-flag indicators" and require personnel file immediately SARs, especially those associated with ransomware attacks. And so, as noted by the Advisory "[p]roactive prevention through effective cyber hygiene, cybersecurity controls, and business continuity resiliency is … the best defense against ransomware."
* Cybercrime to Top $6 Trillion in 2021, According to Cybersecurity Ventures
** The Advisory notes a 42 percent increase in cyber-crime compared to 2020 and observes the new and more savvy methods include (i) extortion schemes; (ii) anonymity-enhanced cryptocurrencies (e.g., Bitcoin); (iii) unregistered convertible virtual currency ("CVC") "mixing" services, (i.e. a mechanism used to launder ransomware payments); and (iv) the use of "fileless" ransomware, which embeds a malicious code directly into a computer's memory, allowing cybercriminals to circumvent antivirus and malware defenses.
*** Because financial institutions are involved with processing ransom payments to cybercriminals, the institutions themselves are becoming more vulnerable to attacks.
**** During the November 8, 2021 arrest of two cybercriminals for a series of ransomware attacks on Kaseya, a multi-national information technology software company, Deputy Attorney General Lisa Monaco stated that the FBI was able to identify the two cybercriminals because Kaseya acted "almost immediately after [it] was hit" by the ransomware attacks (Attorney General Merrick B. Garland, Deputy Attorney General Lisa O. Monaco and FBI Director Christopher Wray Deliver Remarks on Sodinokibi /REvil Ransomware Arrest
By Farrell Fritz P.C. on October 27, 2021
Posted in Cooperative, Discovery, E-discovery, ESI, Sanctions
For some, discovery is merely a necessary evil in the litigation process. And so, it should come as no surprise that the discovery process is often ripe with gamesmanship. A recent decision reminds practitioners, however, that discovery is meant to be cooperative, and gamesmanship – especially repetitive and intentional gamesmanship – may be met with "death penalty sanctions" (Heslin v Jones, (2021 WL 4571198 [Tex Dist, Travis County, Sept. 27, 2021]).
The facts of the underlying litigation are not relevant. Rather defendants' flagrant refusal to comply with their discovery obligations is what warrants discussion. On October 18, 2019, the Court ordered expedited discovery, including written discovery and depositions, to be conducted with respect to a particular cause of action. For two months defendants failed in "numerous respects" to comply with the Court's order, necessitating motion practice. On December 20, 2019, the Court held "[d]efendants in contempt for intentionally disobeying [a discovery] order" ("Order"), but reserved "all additional remedies" based on defendants' representations that they would promptly remediate any discovery deficiencies. Defendants, however, reneged on their promise.
In response, the Court entered a default judgment on liability as against defendants. In issuing this severe sanction, Justice Gamble detailed defendants' history of contumacious and intentional discovery failures and concluded that the imposition of "lesser remedies…would be inadequate in light of the history of the Defendants conduct in this court" given the reality that "judicial admonishments, monetary penalties, and non-dispositive sanctions have all been ineffective at deterring the [discovery] abuse" and "general bad faith approach to litigation" engaged in by defendants. Therefore, because lesser sanctions had proven ineffective when previously ordered, the Court determined that anything shy of the default judgment on liability "would not adequately serve to correct the Defendants' persistent discovery abuses" and "unwarranted disregard for the Court's authority."
Although this case illustrates egregious discovery misconduct, it serves as an important reminder that discovery gamesmanship and win-at-all-costs tactics will not be tolerated during the discovery process. And where, as here, the games are indicative of a bad faith approach to litigation, judges can, and will, reach into their arsenal and impose significant sanctions.
By Farrell Fritz P.C. on September 29, 2021
Posted in Cyber Crime, Cyber Security, Cyber Threat, ESI, SEC
The U.S. Securities and Exchange Commission ("SEC") recently identified cyberthreats as an enforcement priority (see 2021 Examination Priorities). Within months of the Commission's announcement, the Commission brought three enforcement actions* which resulted in sanctions against eight investment advisory firms who failed to report cyber related attacks, failed to adopt, or failed to implement proper cybersecurity policies in violation of Rule 30(a) of Regulation S-P (17 C.F.R. § 248.30(a)) (the "Safeguards Rule").**
In each of the three matters, the various firms had their email accounts compromised causing customer data – including personal identifiable information – to be exposed. A common thread tying the breaches together was that the firms' compromised email accounts failed to comply with firm policy (i.e., did not implement multi-factor authentication despite policy requirements or recommendations to implement)*** and the firms' respective responses to the breaches were insufficient according to the Commission. In exchange for agreeing to cease and desist from future violations of the charged provisions, the firms paid penalties of between $200,000 to $300,000.
A mid-year report on the state of cybercrime, conducted by a cyber investigation response team, revealed that over 70% of ransomware attacks targeted organizations with over $1 billion in revenue.**** In addition, a recent survey conducted by the U.S. Small Business Administration found that "88% of small business owners felt their business was vulnerable to a cyberattack."***** These statistics suggest that cybercriminals more often take a "go big or go home" approach presumably to secure a maximum ransom payment through each cyberattack. And so, it is crucial that companies focus on having and implementing cybersecurity policies, such as (a) an Incident Response Plan, which outlines instructions on how to respond to and resolve data breaches; and (b) a Cyber Liability Insurance Policy, which covers costs associated with data breaches, including lost income due to a cyberattack. By doing so, companies can avoid the business, financial, and reputational risks posed if they fall prey to a cyberattack.
*Matter of Cetera Advisor Networks LLC et. al., SEC 1940 Act Release No. 5834 [Aug. 30, 2021]; Matter of Cambridge Investment Research, Inc. et. al., SEC 1940 Act Release No. 5839 [Aug. 30, 2021]; Matter of KMS Financial Services, Inc., SEC 1940 Release Act No. 5840 [Aug. 30, 2021]).
**The Safeguards Rule requires registered broker-dealers and investment companies to adopt written policies and procedures reasonably designed to "(1) insure the security and confidentiality of customer records and information; (2) protect against any anticipated threats or hazards to the security or integrity of customer records and information; and (3) protect against unauthorized access to or use of customer records or information that could result in substantial hardship or inconvenience to any customer."
***See The Invaluable Benefits of Multi-Factor Authentication
****See First Half of 2021 Sees Triple Digit Rise in Cybercrime
*****See Stay Safe From Cybersecurity Threats
Posted in ESI, FRE
When confronted with an issue of first impression – how to authenticate text messages – the Colorado Court of Appeals chose not to reinvent the wheel. Rather, it wisely borrowed from the Federal Rule of Evidence ("FRE") 901.
In People v Heisler, the defendant and victim had been romantically involved. They remained in touch after they broke up but eventually, the victim began dating another person and requested Heisler stop texting her.
Heisler ignored the victim's request and continued – with increasing frequency – to text and write letters to the victim, who did not respond or reciprocate. Approximately nine months later, uninvited and unannounced, Heisler traveled from his home in Florida to the victim's doorstep in Colorado. The victim called the police and Heisler was charged with felony stalking and harassment.
At trial, the court admitted into evidence Heisler's text messages to the victim. Ultimately, Heisler was found guilty of harassment but acquitted of the stalking charge. Heisler appealed, arguing the court's decision to admit his text messages was error as the text messages were not properly authenticated under CRE 901(a).*
The Two-Step Process
In upholding the trial court's decision to admit into evidence the text messages, the appellate court noted the burden to authenticate evidence is low, and requires a prima facie showing only. Then, after considering a two-leveled approach used to authenticate emails and social media posts,** the appellate court propounded the following two-step process to authenticate text messages:
Step 1: A witness with personal knowledge must testify that printouts of the text messages accurately reflect the content of the text messages; and
Step 2: A witness with personal knowledge must provide testimony establishing the identity of the purported sender of the text message.
Seems simple, right? Not really. How, for example, do you establish the "identity of the purported sender?" Fortunately, the appellate court identified four methods and held the proponent must establish at least two of the four methods:
(a) the phone number was assigned to or associated with the purported sender;
(b) the substance of the text message(s) was recognizable as being from the purported sender;
(c) the purported sender responded to an exchange in such a way as to indicate circumstantially that he or she was in fact the author of the communication; and/or
(d) any other corroborative evidence under the circumstances.
In Heisler, the victim satisfied Step 1 when she testified she recognized the pictures of the text messages and that they were a fair and accurate depiction of the texts she personally received. The victim satisfied Step 2(a) when she testified she recognized the phone number as belonging to Heisler because that was the number she used to communicate with him. Finally, the victim satisfied Step 2(b) when she testified she recognized the content of the text messages as being from Heisler.
Interestingly, Heisler did not object that the text messages were not his or that the printouts were not accurate. Rather, Heisler objected to the text messages because the victim had deleted her responses to his messages.
The appellate court was unpersuaded, stating that prosecution established the printouts accurately reflected the content of the messages the victim received and that Heisler authored the text messages. The court further reasoned that the text messages were admitted as evidence of texts the victim received from Heisler, not as evidence of a conversation between the two. Thus, the text messages were properly authenticated.
Text messages, like any other evidence, must be authenticated to be properly admitted into evidence. Now, practitioners in Colorado state court, like those in the federal courts and countless other state courts, can rest soundly knowing that the process of authenticating text messages involves a fairly straightforward two-step process.
* CRE 901(a) requires that the evidence be sufficiently authenticated by the proponent and authentication "is satisfied by evidence sufficient to support a finding that the [evidence] in question is what its proponent claims [it to be]." FRE 901(a) states the same.
** Under CRE 901, an e-mail and a social media post may be authenticated (1) through the testimony of a witness with personal knowledge that the e-mail is what it is claimed to be or (2) "through consideration of distinctive characteristics shown by an examination of [the] contents and substance" of the e-mail under the circumstances of the case (see People v Bernard, People v Glover).
Thank you to second year associate, Jaclyn Ruggirello in the Firm's Uniondale office, for her research assistance related to today's blog.
Fit For Discovery: The Discoverability of Wearable Devices
By Farrell Fritz P.C. on September 1, 2021
Posted in Discovery, ESI, Litigation Hold, Preservation Obligation
It is estimated that more than 100 million people are wearing an Apple Watch* and another approximately 31 million people are using the Fitbit.** It is further predicted that sales and use of these devices will continue to grow. And so, as people increasingly look for wearables that both "make technology more personal" and include a "cool factor"*** we are reminded that wearables are a repository of information (The Document Demand That Seeks Electronically Stored Information) that could be discoverable in a litigation depending on the relevance of the data. The Bartis case, pending in the Eastern District of Missouri, is an interesting decision on point. (Bartis v. Biomet, Inc., 2021 WL 2092785 [E.D. Mo. May 24, 2021]).
In Bartis, multiple plaintiffs alleged they sustained personal injuries, including permanent mobility issues, as a result of the implantation of an artificial hip manufactured by Biomet, Inc. ("Biomet"). During discovery, plaintiff Guan Hollins ("Hollins") advised, in response to an interrogatory, that he wore continuously a Fitbit to track his number of steps, heart rate, and sleep. As a result, defendants demanded Hollins produce "all data from the Fitbit and any other wearable device or other fitness tracker." Hollins objected claiming such data was "unreliable" because he began wearing the Fitbit after revision surgery removing the Biomet artificial hip.
Defendants filed a motion to compel the production of Hollins' Fitbit data, arguing the data was relevant to Hollins' alleged permanent, physical injuries resulting from implantation of Biomet's defective artificial hip. In opposition, Hollins claimed the request was a "fishing expedition" and reiterated his objection that the data was unreliable.
The Court ordered Hollins to produce the demanded data. Noting, specifically, that Hollins had provided inconsistent responses as to whether he experienced difficulty or pain walking/ jogging due to the alleged defective hip implant, the Court found Biomet's demand for Fitbit data was hardly a fishing expedition where, as here, the data was relevant and could reveal whether Hollins was walking or jogging substantial distances. Further, the Court rejected Hollins argument that the Fitbit data was unreliable, stating that this argument went to the admissibility and weight of the data.
Although Judge Ross aptly observed there was "surprisingly little precedent" involving wearable devices, there can be no doubt that these wearable devices – and the data they store – are here to stay. Therefore, the next time you issue a litigation hold or craft a document demand, you should consider the various wearable devices that may be repositories for potentially relevant information.
*There are more than 100 million people wearing an Apple Watch, says analyst
**Fitbit Revenue and Usage Statistics (2021)
***There are more than 100 million people wearing an Apple Watch, says analyst
An ESI protocol is intended to allow parties to agree on, among other things, how data will be accessed and produced in connection with a litigation. As part of the protocol, parties should negotiate the process for crafting search terms, identifying the universe of data to be searched, and validating search term results. Critical to the negotiation process is understanding that the goal is to discover data that will support the party's arguments at summary judgment or trial.
Tip 1: Let the party with the data determine the best search terms.
It is common practice for the requesting party to propose search terms. However, this often means that the attorney, with more limited facts than the party in possession of the data, is left to guess at search terms that are likely to identify potentially responsive data. And so, it may be valuable to incorporate into one's ESI protocol a mechanism that allows the responding party to propose initial search terms based on each document request. After all, it is the responding party who has access to the data and the custodians and who, therefore, may be best situated to understand which search terms to use. Because the process is an iterative one, the parties can meet and confer to discuss refinement and iterations as necessary (see Tip 3).
Tip 2: Tailor your search terms to the type of system and data being searched.
When formulating an ESI protocol, it is important to identify the data to be searched. For example, are the search terms being run across a party's entire network? Only e-mail servers? Text messages?
Knowing the data to be searched will also help inform a party's search terms. For example, communication styles differ between formal work emails and informal messaging applications like Skype for Business. And so, search terms should be tailored to reflect these distinctions.
Tip 3: Detail how the iterative process will work.
An adversary may contend you have but a single bite at the search term apple. But, no matter how deliberate the initial bite is, revisions are almost always necessary. And so, to afford your client the greatest protection against an adversary who refuses to permit revisions, be sure to delineate an iterative process in your ESI protocol. This process may include iterative sampling, measurement of results, and validation that the technology worked as expected.
Tip 4: Keep the final product in mind.
Throughout the often tedious process of crafting search terms, be sure not to lose sight of the ultimate goal—how will I use the data at summary judgment or trial? Take into consideration how the data will physically look, fit together to form cohesive evidence, and best support your arguments. Thinking about how discovered data will be presented to a judge or jury should inform your decisions when crafting search terms and your ESI protocol.
*For clarity, today's blog discusses search terms in connection with processing and reviewing data, not identifying data for preservation.
The Invaluable Benefits of Multi-Factor Authentication
Posted in Cyber Security, ESI, Uncategorized
The need to input a username and password when logging into a computer is a "single factor" authentication. But, from a security perspective, that single factor authentication only goes so far. Consider, for example, the ramifications if a hacker steals or guesses your username and password. What information could be compromised?
For law firms, cybercrime and data breaches have become a major concern because of the confidential and sensitive information lawyers have access to and often store on their computers.* Recently, the New York City Law Department, a 1,000 lawyer agency responsible for representing the City of New York and guarding the personal information for thousands of city employees, was snakebit by a cyber-attack. The cause of the cyber-attack was a stolen email password from a Law Department employee. The aftermath, however, has been devastating in many respects. First, attorneys for the Law Department have been unable to access files. This in turn has necessitated requests for adjournments and compromised counsel's ability to represent zealously its clients. Second, the security lapse revealed the Law Department was alarmingly disorganized in its handling of confidential information, such as clients' medical records. Third, as a result of the hack, the Law Department's Chief Information Technology Officer was reassigned and replaced.
Regrettably, the incident may have been avoidable. Indeed, the Law Department was sluggish in maintaining its network's systems and failed to comply with a 2019 directive from New York City's Cyber Command Division to implement multi-factor authentication on all systems. Specifically, multi-factor authentication requires a user to enter multiple credentials to verify their identity within a system. Multiple factors may include confirmation of (a) something known to the user (password); (b) something a user possesses (phone or code); or (c) other personal identifiers (biometrics or voice recognition). The benefits of implementing multi-factor authentication is rudimentary in nature, as increasing the amount of layers of security will decrease the likelihood of cyberattacks. For example, had the Law Department implemented multi-factor authentication prior to the breach, the cyber-criminal would have needed the employee's password and cell phone to access the network. Further, multi-factor authentication can protect a law firm's network from more sophisticated cyberattacks such as phishing.**
In sum, with many law firms still working remotely, improving the security of a firm's network may feel like a moving target. Nevertheless, as the title of this blog post suggests, implementing multi-factor authentication will not only help law firms protect clients' interests, but also save them the embarrassment of spending a significant amount of money and time to resolve a preventable disruption.
*An October 2020 American Bar Association report found 29% of law firms reported a security breach, with 36% reporting past malware infections to their systems (https://www.americanbar.org/groups/law_practice/publications/techreport/2020/cybersecurity/
** See Rise of Mobile Phishing Scams ; Phishing Risks Associated with Social Media
Big Law's Internal Audit of Associate Billing Reveals Padded Bills Associated with Document Review
By Farrell Fritz P.C. on July 1, 2021
Posted in Document Review, ESI
We have heard it many times before – document review in today's e-ubiquitous world is expensive. But imagine a client's surprise when it learns an already expensive litigation task was plagued by associate over-billing.
According to a recent complaint filed with the Illinois Attorney Registration and Disciplinary Commission ("IADRC") (see In the Matter of Stephanie Alexandra Gerstetter), an associate litigation attorney at Reed Smith, LLP, Stephanie Gerstetter ("Gerstetter"), was assisting a more senior associate with two separate document review projects. Specifically, Gerstetter was tasked with using the software program Relativity to analyze and code for production digitally stored documents. Unbeknownst to Gerstetter, Relativity was tracking and logging the time she spent reviewing documents.
In June 2020, Reed Smith performed an internal inquiry into Gerstetter's billing practices, and learned Gerstetter billed materially more time to the two document review projects than Relativity indicated she invested in conducting the review. Specifically, the complaint alleges that for a document review in August 2019, Gerstetter billed 29.2 hours despite logging only 23.5 hours in Relativity; and for a second project in March 2020 Gerstetter "recorded billing entries on 49 separate days totaling 197.7 hours of purported time that she claimed to have spent reviewing and coding documents" but "only worked 33 separate days totaling 113.1 hours."* As a result of Gerstetter's overbilling, Reed Smith billed its client for approximately $42,000 of legal services Gerstetter never performed.*
While the need for accurate time keeping cannot be overstated, this case is an interesting reminder of that obligation. Moreover, in a world where attorney compensation and success are often judged by productivity and the billable hour, it is critically important that firms, too, comply with their responsibility to monitor attorney billing practices to avoid ethical pitfalls and malpractice issues, obligations attendant to time keeping and billing entries.
*The complaint asserts one claim against Gerstetter for "Creation of False Billing Entries, Charging and Collecting Unreasonable Fees" and cites violations of Rules 1.5(a) (Fees) and 8.4(c) (Misconduct) of the Illinois Rules of Professional Conduct.
**Reed Smith offered a refund or a credit to its client.
Boilerplate Objections and Discovery Games Require Little Effort but Result in Big Sanctions
By Farrell Fritz P.C. on June 9, 2021
Posted in Cooperative, Discovery, Duty to Preserve, ESI, FRCP, Motion to Compel, Preservation, Rule 37, Sanctions
Bursztein v Best Buy Stores, L.P., (2021 WL 1961645 [SD NY 2021]) involves a personal injury lawsuit arising from plaintiff Perla Bursztein's slip and fall accident in a New York City Best Buy store.
During discovery, Bursztein requested: (i) video surveillance footage of the accident; (ii) maintenance, and repair records for the location of the accident; and (iii) Best Buy's customer safety policy. In response, Best Buy produced two documents, interposed boilerplate specific objections to Plaintiff's requests and claimed it did not maintain surveillance footage of the accident and other critical records.
However, this claim was at odds with deposition testimony provided by Spencer Stanfield ("Stanfield"), the general manager of the store where the accident occurred, who testified repair and maintenance requests were logged on a Facilities' Request System and surveillance footage of the incident had been preserved by him. And so, Plaintiff served post-deposition demands seeking the surveillance footage and the relevant entries on the Facilities' Request System. Best Buy, however, responded with the same boilerplate objections as previously interposed and further stated it no longer had possession of the requested materials.
Fatigued by Best Buy's discovery games, Plaintiff filed a Rule 37 motion seeking sanctions against defendants for failure to comply with discovery obligations and spoliation of evidence. In opposition, Best Buy submitted an affidavit from Stanfield, claiming he misunderstood at deposition the question concerning the video footage.
Finding Rule 37 (e) the "sole source" to address the loss of relevant ESI, the Court observed sanctions are appropriate when (a) there was anticipated or actual litigation triggering the duty to preserve ESI; (b) the relevant ESI should have been preserved at the time the litigation was anticipated or ongoing; (c) the ESI must have been lost because a party failed to take reasonable steps to preserve it; and (d) the lost ESI cannot be replaced through other discovery.
Ultimately, the Court granted Plaintiff's motion and held she was entitled to the fees and costs associated with the motion and "permitted to present evidence at an eventual trial regarding the spoliation of liability-related ESI." In concluding sanctions were appropriate, the Court noted that Best Buy: "thwarted and disrupted discovery throughout the life of this case" by using dilatory and obstructive tactics; "repeatedly flouted their discovery obligations, failed to promptly communicate with opposing counsel, and repeatedly lodged baseless boilerplate objections to Plaintiff's discovery requests;" and engaged in nothing short of a "paradigm of discovery abuse." Further, given the conflict between Stanfield's deposition testimony and his affidavit, the Court concluded that video surveillance of the incident likely existed at one point and that Best Buy failed to preserve relevant ESI.
This decision serves as an important reminder that preservation obligations and discovery obligations must be taken seriously. Indeed, as more and more decisions are demonstrating, there is no room for boilerplate objections, discovery games, or negligent/willful failures to preserve potentially relevant ESI.


text:
Schools chief in Connecticut restricts media access
GROTON >> A school board member has criticized Superintendent Michael Graner's request that board members not speak to the media.
Graner sent a newsletter to school board members last week, saying he submitted the board's proposed $75.1 million budget to Town Manager Mark Oefinger. He advised that all requests from news reporters be referred to school board Chairwoman Rita Volkmann.
The Day of New London reports that school board member Shelley Gardner wrote to Graner that he should fight for freedom of speech, not suppress it.
Graner said he was relaying a decision the board made in Janurary.
Rosanne Kotowski, co-founder of a local political action committee, said she was disappointed by the request. She said she believes school board members will not be very candid with the media or public.


text:
Q: Change values conditionally in Pandas DF with multilevel columns Given the following DF with multilevel columns:
arrays = [['foo', 'foo', 'bar', 'bar'],
          ['A', 'B', 'C', 'D']]
tuples = list(zip(*arrays))
columnValues = pd.MultiIndex.from_tuples(tuples)
df = pd.DataFrame(np.random.rand(6,4), columns = columnValues)
df['txt'] = 'aaa'
print(df)

yields:
        foo                 bar            txt
          A         B         C         D
0  0.080029  0.710943  0.157265  0.774827  aaa
1  0.276949  0.923369  0.550799  0.758707  aaa
2  0.416714  0.440659  0.835736  0.130818  aaa
3  0.935763  0.908967  0.502363  0.677957  aaa
4  0.191245  0.291017  0.014355  0.762976  aaa
5  0.365464  0.286350  0.450263  0.509556  aaa

Question: how do i efficiently change values in the foo sub-columns to 100 if their values < 0.5 for the huge DF?

the following works:
In [41]: df.foo < 0.5
Out[41]:
       A      B
0   True  False
1   True  False
2   True   True
3  False  False
4   True   True
5   True   True

In [42]: df.foo[df.foo < 0.5]
Out[42]:
          A         B
0  0.080029       NaN
1  0.276949       NaN
2  0.416714  0.440659
3       NaN       NaN
4  0.191245  0.291017
5  0.365464  0.286350

but if i try to change the value it throws me:
In [45]: df.foo[df.foo < 0.5] = 100
C:\Users\USER\AppData\Local\Programs\Python35\Scripts\ipython:1: SettingWithCopyWarning:
A value is trying to be set on a copy of a slice from a DataFrame.
Try using .loc[row_indexer,col_indexer] = value instead

if i try to use locators:
In [46]: df.foo.loc[df.foo < 0.5] = 100
...
ValueError: cannot copy sequence with size 2 to array axis with dimension 6

the same error for df.foo.loc[df.foo < 0.5, 'foo'] = 100
if i try:
df.loc[df.foo < 0.5, 'foo']

i get:
KeyError: 'None of [       A      B\n0   True  False\n1   True  False\n2   True   True\n3  False  False\n4   True   True\n5   True   True] are in the [index]'

Solutions - timeit comparison against DF with 10M rows:
In [19]: %timeit df.foo.applymap(lambda x: x if x >= 0.5 else 100)
1 loop, best of 3: 29.4 s per loop

In [20]: %timeit df.foo[df.foo >= 0.5].fillna(100)
1 loop, best of 3: 1.55 s per loop

John Galt:
In [21]: %timeit df.foo.where(df.foo < 0.5, 100)
1 loop, best of 3: 1.12 s per loop

B. M.:
In [5]: %timeit u=df['foo'].values;u[u<.5]=100
1 loop, best of 3: 628 ms per loop

A: Here's one way using where -- df['foo'] = df['foo'].where(df['foo'] < 0.5, 100)
In [96]: df
Out[96]:
        foo                 bar            txt
          A         B         C         D
0  0.255309  0.237892  0.491065  0.930555  aaa
1  0.859998  0.008269  0.376213  0.984806  aaa
2  0.479928  0.761266  0.993970  0.266486  aaa
3  0.078284  0.009748  0.461687  0.653085  aaa
4  0.923293  0.642398  0.629140  0.561777  aaa
5  0.936824  0.526626  0.413250  0.732074  aaa

In [97]: df['foo'] = df['foo'].where(df['foo'] < 0.5, 100)

In [98]: df
Out[98]:
          foo                   bar            txt
            A           B         C         D
0    0.255309    0.237892  0.491065  0.930555  aaa
1  100.000000    0.008269  0.376213  0.984806  aaa
2    0.479928  100.000000  0.993970  0.266486  aaa
3    0.078284    0.009748  0.461687  0.653085  aaa
4  100.000000  100.000000  0.629140  0.561777  aaa
5  100.000000  100.000000  0.413250  0.732074  aaa

redpajama_set_name: RedPajamaStackExchange


text:
#Military – #Veterans – #Alcohol – Family Impacts
It's well documented and understood from many people's lived-experience that; the military have a long-standing historical relationship with alcohol.
But it's not just the individual who faces the consequences and impacts of any over indulgence. Excessive use of alcohol also threatens livelihoods, family relationships, social interactions and ultimately, it can destroy the health and wellbeing of both individuals and their loved ones.
It's no secret that substance use often affects the lives of former members of the UK Armed Forces. This can take many forms – from self-medication to help come to terms with a traumatic experience to difficulty transitioning from the heavy episodic drinking culture. (Rob Stebbings, policy and communications officer, Adfam)
A study published in 2007 (see here) found that the "prevalence of alcohol related harm and alcohol dependence within the UK Armed Forces is greater than in the general population". A question which is often raised (see here) is; are the military drinking too much?
Adjusting to civilian life after a career in the armed forces can be hugely challenging, and that's even without the PTSD that many veterans may be struggling with. Around 15,000 people leave the forces every year, and many try to cope with the transition by self-medicating – especially with alcohol, something that may have been a central part of their forces life. (Battle Lines – DDN)
Experiences and needs of families of former members of the UK Armed Forces with substance use problems: The University of York and Adfam, funded by the Forces in Mind Trust (FiMT), is looking at "the experiences and needs of adult family members of former members of the UK Armed Forces with substance use problems."
The findings from this research will be used to develop a new peer support intervention for this group of families. One part of the project is an online survey which aims to find out about the experiences and needs of this group of families. The survey can be accessed HERE and should take about 45 minutes to complete.
Note: The Forces in Mind Trust works to "provide an evidence base that will influence and underpin policy making and service delivery in order to enable ex-Service personnel and their families to lead successful civilian lives."
Posted in Addictions, Military, Public Health AlcoholFamilyMilitaryVeterans
‹ Previous#Veterans: self-medicating 'civvy' stress
Next ›#Addiction #Recovery – Secular Logical Science Based Approaches


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I've been involved in Bible translation in one way or another for over 30 years and along the way I also studied for an MA in Biblical Interpretation. So I thought it would be interesting to look at how translation and interpretation are connected in Bible translation. If you are translating the Bible then you are not interpreting it, right? Well, as with many issues in translation, things are not quite as black and white as many people think.
So the translator translates and leaves the interpretation to the reader/scholar/preacher? Well, it's not quite that simple. Translation inevitably involves some degree of interpretation. It may sound obvious, but first of all you have to understand something before you can translate it. A translator has to research a passage in its original context and language and come to a decision about what it means before he can then re-express this in his/her language. (This is an over-simplification.) But the translator must also understand what the author takes for granted, what information is implicit in the passage, and then decide whether or not to make this explicit for the reader in his/her translation. For example, in Acts 15.20 it has been decided that the Gentiles should 'abstain from the things polluted by idols' (ESV). Many other translations find it helpful to make explicit what is implied here: The New Living Translation says: 'abstain from eating food offered to idols' and the Good News version spells it out: 'not to eat any food that is ritually unclean because it has been offered to idols'.
Often, though, translators have to interpret because they are constrained by their language. Many languages in West Africa, for example, (including Kouya) do not have a passive voice. Therefore when translating a verse like Matthew 28.18 (All authority in heaven and on earth has been given to me) translators need to use the active form and say who is doing the action, like this, for example: God has given me all authority in heaven and on earth. Now in this case it's not too difficult to work out who the actor or agent is, but in other places it may not be so obvious, yet translators have to make a decision, so they need to interpret.
Or it could be that a certain expression in a language needs an object that is not required in the original language of the Bible. For example in Acts 17.12 (Many of the Jews believed, as did also a number of prominent Greek women and many Greek men.) the texts simply says 'believed', but if it's not possible in the language to say 'believed' without specifying who they believed in, the translator has to make a decision. So does Luke mean here that they believed in God or in Jesus? If we look at the broader context, we read that Paul and Silas are bringing the Good News about Jesus to the people of Berea, so we can conclude that they believed in Jesus. Also it wouldn't make much sense to say that Many of the Jews believed in God because Jews already believed in God, but were now also trusting Jesus.
Sometimes languages have grammatical features which can force the translator to make choices that those translating into English, French or Italian for example don't have to make. Many languages make a distinction between 'inclusive we' (which includes the person/s being addressed) and 'exclusive we' (which doesn't include the person being spoken to, meaning: 'us, but not you'.) This is a feature in Malagasy languages and I wrote about it in another blog post. Since the original Greek does not make this distinction, the translator is forced to interpret; it is mostly obvious which 'we' should be used, but in some contexts the translator has to make a theological decision.
Another complication the translator may have to face is when a language uses different sets of words to show greater or lesser respect. This is the case in the Ntandroy language of southern Madagascar. So for example the word Anjomba is used to translate 'house' when referring to God's house or Temple, whereas traño is the everyday word for 'house' (though God would refer to his own house as traño). This applies to verbs too, depending on whether the person being referred to commands more respect than the person speaking. So in the case of Jesus turning water into wine at the wedding in Cana, when Mary says to the servants: Do whatever he tells you! (John 2.5), referring to Jesus, should the translators use a verb for 'tell' which shows more or less respect?! A mother would normally refer to her son as her inferior, but then did Mary know at this point that Jesus is no ordinary son…? Once again, the translator has to interpret the situation and make a theological decision.
I could go on with more examples, but this blog post is already too long. Hopefully though it gives you some insight into the kinds of decisions that Bible translators face and helps you to see that the line between translating and interpreting is a bit more blurred than you thought!
Posted on May 14, 2018 May 12, 2018 by SuePosted in Bible TranslationTagged Bible Translation, Ivory Coast, languages, Madagascar.
The 'righteousness of God' in Romans (1:17 etc). Is it righteousness from God, imputed to us, or proof that God is right(eous) in the way He acts? The Greek genitive δικαιοσύνη θεοῦ can mean either. The translator is therefore forced to interpret.
Another excellent post. I've learned more about this as I've learned, and had to communicate in, more different languages.
Another time when interpretation is necessary is when the source language (e.g. NT Greek) contains a word that is used in the New Testament (and even by that author) with more than one meaning – i.e. there's more than one target (e.g. English) word that could be used. Years ago, as I started studying Greek at bible school (All Nations), I was amazed that just about all the 'offices' of the early church are like that. Hardly surprising really, as they were "inventing a new organisation". Apostle, elder, bishop, deacon – all have simple, non-church meanings as well (roughly, messenger, old man, overseer/foreman, servant). It became even more of an issue when I learned that they all also have feminine forms. And that the NIV had decided that all the feminine occurrences carried their 'non-church' meanings.