Post-G7, the event we saw as the "end-summer break" that we were looking for, a certain trend has set in: a steadily weakening dollar and strengthening yen, continued but weaker upward pressure on the euro, and higher yields across the board. In trading terms our recommendation of marginal lengthening in euros and CHF was too early, but our investment view is that USD yields must rise still more and EUR yields fall. The fundamental differences between the two economies should logically lead to an uncoupling of interest rates, but the "tradition" that Europe merely follows meekly where the USA leads is going to be hard to break.
Last week we had to deal with a loss of confidence in the US recovery, this week, to judge by the equity markets, confidence has returned. We do not share it, neither do most economic commentators, but for this week at least, the pro-Bush propagandists are ahead. The 57,000 extra jobs were greeted like the greatest news in months; never mind that growth in the US working population requires almost double that number of new jobs for unemployment not to increase.
For years we have been astounded by the willingness of the US consumer to spend, increasing household debt to do so. It does not require great foresight to realise that a small increase in interest rates on a small base washes through to a sharply increased interest burden. It is as if the obvious does not occur to the US consumer until it actually happens.
The obvious has happened. Interest charges have gone up, and re-mortgaging, a nice source of fresh cash for spending, has lost its attraction. The cash-in-the pocket of the summer tax cuts has been spent, so there is nowhere for the consumer to turn to continue his or her spendthrift ways. This should lead to the consumer increasing savings rates and to decreasing household indebtedness. The published data suggest that this is happening. The trough at 2Ѕ% savings rate was finally left behind at end 2002 and the rate is now 1 percentage point higher. Consumer credit as a proportion of disposable income has also receded by a percentage point from its peak of almost 25%. Add to this the cheaper dollar, and there are now two tentative elements of the beginning of rebalancing which we enumerated in early 2000 (the others were Federal deficit, corporate debt, overvalued equities and the external deficit). Still a long way to go, especially as the Administration policy opposes all these rebalancing moves. It is only our faith in market forces that lets us anticipate eventual rebalancing and that a new, healthy economy will eventually emerge despite, not because of, US economic policy. But when? In 2000, we said ten years, and we see no reason to change that horizon.
The bond market has turned rather quiet at the moment. We are seeing some clients put on smart trading strategies, and there is a general search for yield while massive shifts in yield curves are not expected in the immediate future. The trend to higher USD yields is well established (and we see this partly as the other side of the dollar devaluation coin). Our concept (and it is not only ours) that Euroland could uncouple for the USA on interest rates is yet unproven, although we affirm that the euro zone cannot afford both a stronger currency and higher rates. Whether such uncoupling will happen will have to wait until Trichet begins his reign.
Many months ago we warned readers about the risk of illiquidity in the then much-vaunted structured products. Such products have indeed proven extremely illiquid, and there is not much to do except let them run to maturity; there is simply no market, not even from the original sponsors of these issues.
Periods like the current calm are often followed by a major shift. From our argument above it could come from the US consumer setting the example to the Administration about not spending beyond one's means. It could also come from more currency realignment, including the euro making a serious bid (if Trichet likes the idea) to share the burden and privilege of being a reserve currency.
Generally stay short, but new cash going a little longer in euros and Swiss Francs.


text:
Roger Wolcott Sperry Ph.D. [Zoology], M.A. [Psychology]
Nobel co-recipients David H. Hubel, Torsten N. Wiesel
The President's National Medal of Science - Biological Sciences 1989
Psychologist, Philosopher, Zoologist, Neuroanatomist. Functional specialization of cerebral hemispheres. Split-brain studies. Duality of consciousness. Mind and consciousness. High ethical standards. Authorship generosity.
Ralph Gerard, "I know of nobody else who has disposed of cherished ideas of his doctoral and postdoctoral sponsors, at that time the acknowledged leaders in their fields."
Roger Sperry, Biographical memoir by Theodore J. Voneida, National Academies Press, 19 pages
Painting: Tim Tompkins PaintHistory.com
Name: Roger Wolcott Sperry
Birth: 20 August 1913, Hartford, CT, USA
Death: 17 April 1994, Pasadena, CA, USA
Institution: California Institute of Technology (Caltech), Pasadena, CA, USA
Award: "for his discoveries concerning the functional specialization of the cerebral hemispheres"
Subject: neurophysiology
Honoring Roger Sperry
Mentor Master's Psychology: R.H. Stetson
Mentor Doctoral Zoology: Paul Weiss
Mentor Post Doc Psychology: Karl S. Lashley

redpajama_set_name: RedPajamaCommonCrawl


text:
Community remembers pilot, 2 nurses killed in Rochelle medical helicopter crash
December 11, 2012 (ROCHELLE, Ill.)
PHOTOS: Rochelle medical helicopter crash kills 3
The helicopter was traveling from Rockford to Mendota to pick up a patient. According to the FAA, the aircraft was destroyed when it went down in a Lee County cornfield midway between the two cities at about 8:30 p.m. Monday.
According to hospital officials, the victims are identified as pilot Andy Olesen, 65, flight nurse Jim Dillow, R.N., 40, and flight nurse Karen Hollis, R.N., 48.
No patients were on board.
Pastor Ralph Kuespert with Bethlehem Lutheran Church counseled Olesen for six years. He says Olesen was just a week away from retirement.
"They had a retirement party that was planned for this weekend and also he and his wife were going to fly to Denmark for Christmas," said Kuespert, who was called to Olesen's home Monday night.
Olesen, the hospital says, was employed by Air Methods, the contracted provider of aircraft services.
"Andy was an experienced pilot when he began flying for Air Methods in 1994 and had been a pilot for REACT for about five years," according to Rockford Memorial news release.
Dillow is said to have joined Rockford Memorial Hospital in 1996. Hospital officials say he was an experienced critical care nurse and emergency room nurse and had more than 10 years of experience as a flight nurse.
Hollis, a mother of two, began her career at Rockford Memorial in 1986, according to the hospital, and worked as a critical care nurse. She held leadership positions as a clinical resource coordinator and a trauma nurse coordinator and had more than 10 years of experience as a flight nurse.
Rockford Memorial Hospital officials describe themselves as a very tight-knit family.
"Karen grew up here, Jim grew up here. Andy left and came back. We definitely have a whole in our hearts for our family members," said Ron Meadors, Rockford Memorial Hospital.
"They were all about saving and helping other people. To have them lost on a mission where there were going to help somebody in need of our services adds to that pain," said Rockford Health System CEO Gary Kaatz.
Earlier in the day Rockford Health System representatives released a statement which read, "Our hearts are heavy. We grieve the loss of three heroes who dedicated their careers to serving others."
Pieces of the medical helicopter could be seen all over the football-sized field Tuesday.
Michael Bernardin said he remembered the terrifying sounds from above his farmhouse when the crash happened.
"All of the sudden, I seen a red light come out of the sky, and [it] nose dove right into the ground out here. And I thought, 'Holy cow, there's something out there.'' So the wife and I got in the pickup and started looking for the helicopter," Bernadin said.
The "REACT" helicopter is Rockford Memorial Hospital's only aircraft, which usually transports high-risk patients in the region.
There was no word Tuesday on an official cause for the crash.
ABC7 is told that shortly after takeoff, the pilot communicated with the tower, told them he had encountered some sort of bad weather. He said he had already turned the chopper around and was heading back to the hospital, but air traffic control lost contact with the pilot about 10 minutes later.
The National Transportation Safety Board is heading up the investigation along with the FAA.
"My agency was beginning a search for that aircraft when a farmer in the area located wreckage of the aircraft in a field," said Lee County Sheriff John Varga. "No survivors at the crash site. Being that there was snow and darkness, we made sure the scene was secured."
Meanwhile, hospital officials said they already had several group sessions with hospital employees and would likely spend the rest of the Tuesday in similar sessions trying to help everyone cope with the loss.
"It's very difficult to accept that happening. And it's very difficult to be a pastor at those times. You do search for words," said Kuespert.


text:
Hardcover, 6.5 x 9 in. / 320 pgs / 200 duotone.
Catalog: FALL 2004
Andreas Feininger: That's Photography
Essays by Otto Letze and Thomas Buchsteiner.
"The camera is superior to the eye, and the photograph can, and ideally should, portray the world more graphic than reality itself." --Andreas Feininger
The basic principles underlying the photographic art of Andreas Feininger are clarity, simplicity and organization. The eldest son of painter Lyonel Feininger, he was born in Paris in 1906. Upon completion of training as a cabinet-maker at the Bauhaus in Weimar in the early 1920s, he went on to study architecture in the state schools of Weimar and Zerbst. It was while working as an architectural photographer in Stockholm that he developed the sweeping vistas and fine balance for which his pictures were famous. Emigrating to New York following the outbreak of World War II, Feininger was hired as a photo-editor by Life magazine. In his own work, he captured images of urban canyons, skyscrapers, bridges and elevated railways in concentrated, atmospheric photographs that are regarded as classical works today. He applied the same enthusiasm to nature studies: his detail images of insects, flowers, shells, wood and stones imbue these forms with a sculptural character. That's Photography presents the work of this classic photographer, who died in 1999.
ANDREAS FEININGER MONOGRAPHS + ARTIST'S BOOKS
FORMAT: Hardcover, 6.5 x 9 in. / 320 pgs / 200 duotone.
LIST PRICE: CANADA $53.95
D.A.P. CATALOG: FALL 2004


text:
NewsSpecial WireAt least 80 dead as plane catches fire while...
NewsSpecial Wire
At least 80 dead as plane catches fire while landing in Iran
Iran Focus: Tehran, Iran, Sep. 01 – At least 80 people were killed as an Iranian airliner crash-landed in the north-eastern city of Mashad, official media reported. Iran Focus
Tehran, Iran, Sep. 01 – At least 80 people were killed as an Iranian airliner crash-landed in the north-eastern city of Mashad, official media reported.
State television showed footage of the charred plane at the crash site.
The state-run news agency Fars said that the Russian-made Tupelov plane crashed at 14:40 local time.
Some 140 people were aboard the Iran Air plane which was on route from the southern port city of Bandar-Abbass to Mashad, according to Mohammad-Hassan Mortazavi-Far, the logistical chief of airports in Khorassan Province.
The official news agency IRNA said that 147 people were on board the airliner and that at least 80 of them had been killed while some 50 others had made it out alive.
The report said that the plane's front tyre burst and caught fire due to a mechanical failure while landing. The fire rapidly spread throughout the aircraft.
Previous articleAt least 80 dead as plane catches fire while landing in Iran
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text:
Home » Big Brother 22 » Big Brother- Wednesday Recap for 8/19/20
Big Brother- Wednesday Recap for 8/19/20
Good morning ya'll! It's eviction day again but it feels like it's been a lot longer than a week. No matter who leaves, I'm glad this week is ending. It's been crazy watching so many people repeat their past games so far, even when they don't think they're doing it. The house is also starting to form a weird combination of past seasons too.
For example: Kaysar is overplaying and loyal to a fault. Nicole F is using 'I'm a victim, feel sorry for me, someone was mean to me' bit it works. Dani trash talks everyone until her comments become personal. Christmas only thinks about teams, comp wins and sides. Memphis wants to repeat BB10 except be Dan this time. Cody wants a redo for BB16 except be Derrick. DaVonne gets lost trying to solve her alliance mysteries without realizing what all her research will cost her in the end. We've all witnessed Nicole A repeat last summer, even if it was all in her head this time. This is exactly what they did before.
The vibe from certain seasons is recurring too. The big alliance (the one Kaysar kept trying to warn people about) formed quickly with everyone unknowingly reporting back to it) (BB16) There's the small core alliance where each are working a specific person outside of it. (Brigade, BB12) Unfortunately, there's even a sprinkling of BB19 because the entire house is going against 2 people and making it too personal. I still hear a little bit of talk about Janelle and Kaysar being dangerous players but most of it is personal. I hear a lot more talk about how Janelle is a terrible person, saying she's toxic and making up lies about them to justify their dislike of them. She isn't on the block but the entire week has been about Janelle.
There was more talk yesterday about putting Janelle on slop than there was the upcoming hoh and the plan to evict her. NicF wants to be the one to replace herself with Janelle as a have not since they choose this year. Christmas, Dani and NicF were annoyed when they found out Kaysar will probably make Janelle a have not. They feel robbed of the pleasure and even discussed the order people would choose in the hope they'll still be able to do it. (Remember when they thought it was so mean the way Memphis did it?)
As for the game talk, it was more of the same with a couple of exceptions. NicA had another melt down but this one included (sort of) making up with Janelle and Kaysar. She'd started doubting her thoughts all week and considered she might be wrong. It didn't last, she kept going back and forth and I honestly don't know what she thinks now.
Instead of people being a bit leary of DaVonne moving forward, she's solidly on the outside of her alliance at this point. Here's my recap but its by player instead of by conversations. They were just the same conversations from the day before so it seems nuts to type the same stuff again. I may not be consistent with this depending on the house activity from week to week but for now, it makes sense to end each week with where the players are alligned and what their plans are moving forward.
Memphis There isn't a lot to say here because he stayed out of most everything. That's hard to do when you're the hoh but he did. Like him or not, he did exactly what he wanted this week. Sure, his alliance doesn't fully trust him but he was already #6 in the 6 person alliance he started. (The Committee) He isn't the biggest target unless David stays and wins hoh and I think Tyler can point David at Janelle or Kaysar anyway.
Janelle talking to Memphis about why no one went after Jackson last year
Nicole A She's going home unless something crazy happens and by crazy, I mean something that benefits the large group. She finally told Jan and Kay why she was so angry with them, said she felt set up and said they didn't try hard enough to save her. They saw it as some sort of breakdown, forgave her and continued trying to keep her in the house. The large group knows this happened and knows Jan and Kay still want her to stay. They also don't need to keep NicA to go after the 2 of them because the whole house is after them. Other than Day and maybe Enzo, (if he was looking far ahead) NicA doesn't help the larger group.
David In spite of his horrible campaigning and Day considering changing her mind to keep NicA, it looks like he's staying. He had one good convo that I saw and it was with Bayleigh. I think it got her fully back on board with him. (Out of Bay and Day, she was the one most likely to work with Jan & Kay) He still has no idea how to play this game but it looks like he'll have the chance to keep trying to learn.
Kaysar He was still trying to save NicA when I finally went to bed. He plans to work on everyone again today. Kevin has even started trying to tell him it isn't going to happen. He had a meeting that included Bay and Day to see if they would commit. I can fault him for not knowing when to give up but he isn't wrong with the way he's thinking. He gets that Day and Bay want to try and ride the middle because they feel ok with both "sides." What he can see but they can't is there really aren't sides. There's one large alliance with extra people at the bottom of it. He knows they are sitting ducks if they don't try to break up the big group. Even after all the crap NicA has talked about Jan and Kay, he hugged her, consoled her and apologized for not being able to do more to save her. (Kaysar is an amazing human but there's a reason he never makes jury)
Janelle She also tried hard to save NicA but she sees the writing on the wall more than Kaysar. Shes in a mess and knows shes the biggest target. (My girls gotta win hoh tonight or its gonna be a rough week ahead)
DaVonne She did way too much this week and dug herself into a hole. She'd rather keep NicA but doesn't trust Janelle and Janelle is closer to Bay than her. She's afraid to have 2 close allies (Bay and NicA) that are so close to Janelle. She also doesn't want to stand out going against her group so soon. Just because she pieced some things together and realized Cody, Tyler and Dani weren't going to be loyal to her, doesn't mean she's ready to openly go against them yet. Her original plan of trying to work both sides was a good one but I don't think she realizes she can't do that anymore. You can't work both sides when one side only has 2 people in it. There's nowhere to hide. She got in the middle of too much stuff this week and Dani was able to twist it too easily. Day is in trouble imo and I hate it for her because she was looking pretty good at first.
Bayleigh Her situation is pretty similar to Day's except her closest side friendship was with Janelle and that was hurting her with the larger group. Last week Dani trusted Day a lot more than Bay. Maybe she realized this because she ran and told everything yesterday to Cody & co. She spilled everything Jan and Kay were trying to do. That's great for now but I think all she accomplished is making Day a target before her. She isn't off the list tho.
Kevin He's made himself and easy pawn moving forward. He and Janelle finally had a convo about needing to come together but it happened to late. Kevin isn't to blame for all the stupid things NicA thought this week but he is to blame for continuing to put fuel in her crazy train. He finally laid off telling Dani everything Jan and Kay were doing but only after there was nothing left to tell. He's working with them at the moment trying to save NicA but he'll run from them as soon as NicA is evicted.
Ian He knows NicF has an alliance without him which she continues to deny. He's told her he was fine with it and said he didn't mind being the Britney in the new brigade because Britney did get taken close to the end. I don't know if he means this or not but unless he's changed, I don't think he'll turn on Nicole. He stayed loyal to Britney on his season and what he's building with Nicole looks very similar. I think he's sincere about wanting to work with Kaysar but he's also sincere about not wanting to do it until Janelle is gone.
Dani It's her birthday this week and if you haven't witnessed Dani having her birthday on her previous seasons, well, you're in for a treat. She becomes very demanding and completely obnoxious. You'd think it should be deemed a national holiday. She's already been in the DR wanting to know if she's getting a cake and presents. She has successfully moved Day out of her way with Cody and Enzo and she was making progress on taking over NicF's spot with Cody. She stumbled a little this week when Day started trying to catch people in lies. At first, Dani thought Tyler was lying and told him. Once she figured out the truth, she went to Tyler and told him she knew it was Day and not him. This made Dani trust Tyler again. (Guess what Dani? Now Tyler doesn't trust you) Tyler, Enzo and Cody have already had conversations about not trusting Dani. She's not in trouble yetand they want her on their team. They just know they have to watch out for her now.
Christmas She's actually not playing too bad but she's really annoying. She's probably burned bridges with Jan and Kay if they realize she was lying all this week. Kaysar has a good relationship with her though and because Jan and Kay won't have any numbers, they may keep trying to work with her and keep telling her things. I truly believe this is Tyler's intended final 2 and that alone should keep her safe for a while. The BB19 wants to jump out of her occasionaly and it doesn't take much for her to get on board with NicF and Dani's nasty comments about Janelle. Everyone waited for Janelle and NicA to have a confrontation this week which didn't happen. If there is one this summer, somehow I can see it being between Janelle and Christmas. Christmas likes to fight other people's battles since it makes her feel like part of the team and she's easily manipulated. (I have no reason to think this other than I just do) She's still talking about wanting to take over for Julie. I have no idea what got this started.
Cody He was mad when he realized the hoh comp is probably going to be a crap shoot tonight. He's got a lot of people on his side but he's definitely a target for Jan and Kay. Janelle was working on Memphis last night trying to get him to see that too. Memphis won't because he thinks he has a final 2 with Cody. He's probably in the best position as far as alliances that are actually loyal to him but not as far as visibility. He's definitely a target and he knows it. It's why he got so worked up this week. He'll push for Kaysar to go over Janelle. I think Ian would love to see Cody gone. He may not want to do it himself but he knows it would better his position with NicF.
Nicole F We need to get prepared for NicF to be around for a while. It's no secret that I can't stand the whiny, victim game she plays but let's face it, it works and this season, it's working well. The only person who wants to go after her is Janelle and she's the number one target moving ahead. I could see Nicole being around for a long time and I may as well prepare for it. I've criticized her in the past and made jokes about her inability to play without a showmance. I have my answer as to if she can or not. (She can) Nicole F is very good at this game. She spent the week complaining about Janelle and worrying about what kind of edit Janelle is going to get. That's my biggest problem with Nicole's game. It isn't because her game is trying to play the 'sweet girl from the midwest who everyone is mean to.' It's because it isn't really her game but her focus is trying to convince us that it is. Truthfully, if Nicole was a player who whispered into the camera 'haha, they're all suckers and they're really falling for the sweet girl act,' I'd probably love her as a player. (She won't so I don't)
Enzo He's in a great position. Everyone loves him and he's the comic relief for the house. I actually think he may be more well liked than he was in his first season plus he has the benefit of knowing he may need to win some comps this time. Even Day and Bay, who are skeptical about the guys they're working with, make comments about still trusting Enzo. They don't put him in the same category as the other guys. Kay and Jan also think Enzo, along with Memphis, are the only guys in the house they might be able to get on their side. Enzo is like Memphis in that the only side he's on is his own but unlike Memphis, he does a great job hiding it.
Tyler He did a good job convincing his alliance they needed to keep David for their own reasons. They don't and it's purely for Tyler's benefit. There's been a few jokes within his alliance about him outsmarting all of them and he even joked last night that he had an alliance with the entire house. They were all just joking around but it caught my attention. I could see a scenario down the road when someone feels betrayed by Tyler. He could always use that conversation to say 'hey, I told you I had an alliance with the entire house, it's not my fault you didn't believe me.' Hell get his way this week and I'm probably most interested in his moves the next couple weeks.
There will probably be more scrambling today. I can appreciate Nicole A not going down without a fight. It's just been painful to watch her take on the wrong fight. It's made me feel very tired this week and at this point, I'm just ready for someone to be evicted (I don't even care who anymore) and move on to the next HOH.
Have a great Thursday!


text:
Q: Hide checkout fields when selecting multiple delivery methods in WooCommerce I use code that hides the checkout fields if the Local Pickup shipping method is selected:
    // Conditional Show hide checkout fields based on chosen shipping methods
add_action( 'wp_footer', 'custom_checkout_field_script' );
function custom_checkout_field_script() {

    // HERE your shipping methods rate IDs
    $local_pickup = 'local_pickup:3';
    $pickpoint = 'wc_custom_shipping_pickpoint';

    $required_text = esc_attr__( 'required', 'woocommerce' );
    $required_html = '*';
    ?>

    <?php
}

The problem is that I can't do this for multiple delivery methods. I need to specify local_pickup:3, local_pickup:6 and local_pickup:9. Hiding fields only works correctly with one specified delivery method.
Please help me to solve this problem. Thank you!

A: You need to define multiple delivery methods in the array.
Define array like this
$local_pickup  = array( 'flat_rate:2','flat_rate:7' );

Now, where you compare $(ismc).val() == localPickup replace with below code. You have to find the selected method in the array so you can use includes.
localPickup.includes( $(ismc).val() )

Complete code.
// Conditional Show hide checkout fields based on chosen shipping methods
add_action( 'wp_footer', 'custom_checkout_field_script' );
function custom_checkout_field_script() {

    // HERE your shipping methods rate IDs
    $local_pickup  = array('flat_rate:2','flat_rate:7');
    $required_text = esc_attr__( 'required', 'woocommerce' );
    $required_html = '*';
    ?>

    <?php
}

Tested and works

A: The above code does not make fileds not required. Only solution I've found to work around is fill up hidden fields with placeholder value.
// Conditional Show hide checkout fields based on chosen shipping methods
add_action( 'wp_footer', 'custom_checkout_field_script' );
function custom_checkout_field_script() {

    // HERE your shipping methods rate IDs
    $local_pickup  = array('inpost_paczkomaty:15');
    $required_text = esc_attr__( 'required', 'woocommerce' );
    $required_html = '*';
    ?>

    <?php
}

A: Please try below solution this solution is also a working on many criteria.
add_filter('woocommerce_checkout_fields', 'xa_remove_billing_checkout_fields');

function xa_remove_billing_checkout_fields($fields) {
$shipping_method ='free_shipping:1'; // Set the desired shipping method to hide the checkout field(s).
global $woocommerce;
$chosen_methods = WC()->session->get( 'chosen_shipping_methods' );
$chosen_shipping = $chosen_methods[0];

if ($chosen_shipping == $shipping_method) {
unset($fields['billing']['billing_address_1']); // Add/change filed name to be hide
unset($fields['billing']['billing_address_2']);
}
return $fields;
}

redpajama_set_name: RedPajamaStackExchange


From the time that you purchase The Emotion Code Certification program, you have 6 months to complete all requirements. If all requirements are not completed within the 6 month window you will be allowed to purchase an extension. The fee to extend is $100 for one month, $200 for two months and $300 for three months. However, if you have extenuating circumstances, you can contact our certification department.


There's nothing to beat having a serviced apartment for your holiday haven in a busy foreign city. It's like having a piece of home for your personal space, rather than an impersonal hotel room.
The best part would be the classy, neat features and stylish amenities that you may not have at home such as the marvellous pool, multi-cuisine dining, extensive gym, sauna, jacuzzi, et al that go to enhance your vacation. The cherry on top would be the service that lets you come back to a fresh, clean room after you'd left it like you had a personal tsunami in there.
5/5 Great staff and location, with a terrific friendly staff?


Over the past few years, our office has dealt with a number of "bad used car" cases where a dealer sells a vehicle that breaks down shortly after the sale, or that won't pass DEQ, or where a dealership has made false or misleading claims to the client in order to facilitate the sale. On occasion, we have run into the following situation: a potential client comes to us and, after an initial evaluation of the facts, we learn that the client has already signed a waiver and / or release of any potential claims. The waiver may take the following form: "in exchange for [small payment amount or token services provided by seller], consumer releases seller from any and all actions, causes of actions, claims, known or unknown, etc., including any alleged violations of the unlawful trade practices act, the truth-in-lending act, unlawful debt collections, the Magnuson-Moss warranty act…" The list can go on and on.
The question then becomes: did the potential client truly sign away all potential claims and would we be risking a motion for summary judgment by filing a new case? The true answer, of course, depends on the particular facts involved. However, consumer attorneys should look hard at the circumstances surrounding the purported waiver. In the context of consumer rights and protections granted by statute, the waiver may very well be unenforceable.
Waiver, in Oregon, is "the intentional relinquishment of a known right." Waterway Terminals Company v. P.S. Lord Mechanical Contractors, 242 Or 1, 26 (1965). "It is a truism that a contract validly made between competent parties is not to be set aside lightly. When two or more persons competent for that purpose, upon a sufficient consideration, voluntarily agree to do or not to do a particular thing which may be lawfully done or omitted, they should be held to the consequences of their bargain. The right to contract privately is part of the liberty of citizenship, and an important office of the courts is to enforce contractual rights and obligations. As this court has stated, however, contract rights are [not] absolute; …equally fundamental with the private right is that of the public to regulate it in the common interest." Bagley v. Mt. Bachelor, Inc., 356 Or 543, 551 (2014) (internal citations omitted).
"Statutory rights may be waived, but only to the extent that they serve no broader public policy but are directed solely to the protection of the individual who purports to waive them." In re Leisure, 334 Or 244, 253 (2003) (emphasis added). "[W]aiver is not appropriate when it is inconsistent with the provision creating the right sought to be secured and a right conferred on a private party, but affecting the public interest, may not be waived or released if such waiver or release contravenes the statutory policy." Clark v. Capital Credit & Collection Services, 460 F3d 1162, 1170 (9th Cir 2006) quoting New York v. Hill, 528 US 110, 116 (2000). Put more simply: "[w]here legislation is intended to secure general objectives of public policy as well as to protect the interests of individuals, it may not be circumvented by private agreement." McKinney v. Employment Division, 21 Or App 730, 737 (1975). See also: Welker v. Teacher Standards and Practices Commission, 152 Or App 190, 197 (1998) citing Turney v. J.H. Tillman Co., 112 Or 122, 132, (1924).
When confronted with a potential waiver, it is important to look to the impact on the individual consumer, but it is equally important to look to the underlying policy concerns behind the statute. Consumers do not have to show a specific injury to the public in a specific instance in order to invoke the public policy concerns and void contract term. "In determining whether an agreement is illegal because it is contrary to public policy, '[t]he test is the evil tendency of the contract and not its actual injury to the public in a particular instance.'" Bagley v. Mt. Bachelor, Inc., 356 Or 543, 552 (2014) quoting Pyle v. Kernan, 148 Or 666, 673-674 (1934). However, it is also important to examine the specific circumstances of each individual waiver because waivers often are enforced "only if the waiver was 'knowing' or 'intelligent,' which means the individual has 'sufficient awareness of the relevant circumstances and likely consequences' of his decision. Clark v. Capital Credit & Collection Services, 460 F3d 1162, 1171 (9th Cir 2006) quoting Brady v. United States, 397 US 742, 748 (1970). As such, a waiver or release of claims that is negotiated by two attorneys on behalf of their respective clients is more likely to be enforceable than a take-it-or-leave-it waiver signed by a consumer as part of a transaction with little or no explanation.
In the most recent case addressing whether an anticipatory release is valid, the court summarized the law as follows: "We glean from those decisions that relevant procedural factors in the determination of whether enforcement of an anticipatory release would violate public policy or be unconscionable include whether the release was conspicuous and unambiguous; whether there was a substantial disparity in the parties' bargaining power; whether the contract was offered on a take-it-or-leave-it basis; and whether the contract involved a consumer transaction. Relevant substantive considerations include whether enforcement of the release would cause a harsh or inequitable result to befall the releasing party; whether the releasee serves an important public interest or function; and whether the release purported to disclaim liability for more serious misconduct than ordinary negligence. Nothing in our previous decisions suggests that any single factor takes precedence over the others or that the listed factors are exclusive. Rather, they indicate that a determination whether enforcement of an anticipatory release would violate public policy or be unconscionable must be based on the totality of the circumstances of a particular transaction. The analysis in that regard is guided, but not limited, by the factors that this court previously has identified; it is also informed by any other considerations that may be relevant, including societal expectations." Bagley v. Mt. Bachelor, Inc., 356 Or 543, 560 (2014).
When a potential client has signed a waiver or release of claims, the inquiry into the facts should dive deeper to see whether such waiver is valid and enforceable. In the context of consumer transactions, as opposed to an arms-length business transaction, or a settlement negotiation involving experienced lawyers on both sides, the answer may very well be that it is not.
Jordan Roberts is a partner at the Roberts Law Group PC.
This entry was posted in Uncategorized on December 4, 2015 by Michael Fuller.


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text:
#include <config.h>

#include "api_posdb.h"

#include <string>
#include <vector>

using namespace std;

#include <xapian.h>
#include "testsuite.h"
#include "testutils.h"

#include "apitest.h"

/// Simple test of NEAR
DEFINE_TESTCASE(near1, positional) {
    Xapian::Database mydb(get_database("apitest_phrase"));
    Xapian::Enquire enquire(mydb);
    Xapian::Stem stemmer("english");
    enquire.set_weighting_scheme(Xapian::BoolWeight());

    // make a query
    vector<Xapian::Query> subqs;
    Xapian::Query q;
    subqs.push_back(Xapian::Query(stemmer("phrase")));
    subqs.push_back(Xapian::Query(stemmer("fridge")));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 2);
    enquire.set_query(q);

    // retrieve the top ten results
    Xapian::MSet mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("phrase")));
    subqs.push_back(Xapian::Query(stemmer("near")));
    q = Xapian::Query(Xapian::Query::OP_NEAR, subqs.begin(), subqs.end(), 2);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 3);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("phrase")));
    subqs.push_back(Xapian::Query(stemmer("near")));
    q = Xapian::Query(Xapian::Query::OP_NEAR, subqs.begin(), subqs.end(), 3);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 1, 3);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("phrase")));
    subqs.push_back(Xapian::Query(stemmer("near")));
    q = Xapian::Query(Xapian::Query::OP_NEAR, subqs.begin(), subqs.end(), 5);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 1, 3);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("phrase")));
    subqs.push_back(Xapian::Query(stemmer("near")));
    q = Xapian::Query(Xapian::Query::OP_NEAR, subqs.begin(), subqs.end(), 6);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 1, 2, 3);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("leave")));
    subqs.push_back(Xapian::Query(stemmer("fridge")));
    subqs.push_back(Xapian::Query(stemmer("on")));
    q = Xapian::Query(Xapian::Query::OP_NEAR, subqs.begin(), subqs.end(), 3);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 4, 5, 6, 7, 8, 9);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("leave")));
    subqs.push_back(Xapian::Query(stemmer("fridge")));
    subqs.push_back(Xapian::Query(stemmer("on")));
    q = Xapian::Query(Xapian::Query::OP_NEAR, subqs.begin(), subqs.end(), 4);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 4, 5, 6, 7, 8, 9, 10);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("leave")));
    subqs.push_back(Xapian::Query(stemmer("fridge")));
    subqs.push_back(Xapian::Query(stemmer("on")));
    q = Xapian::Query(Xapian::Query::OP_NEAR, subqs.begin(), subqs.end(), 5);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 4, 5, 6, 7, 8, 9, 10, 11);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("leave")));
    subqs.push_back(Xapian::Query(stemmer("fridge")));
    subqs.push_back(Xapian::Query(stemmer("on")));
    q = Xapian::Query(Xapian::Query::OP_NEAR, subqs.begin(), subqs.end(), 6);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 4, 5, 6, 7, 8, 9, 10, 11, 12);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("leave")));
    subqs.push_back(Xapian::Query(stemmer("fridge")));
    subqs.push_back(Xapian::Query(stemmer("on")));
    q = Xapian::Query(Xapian::Query::OP_NEAR, subqs.begin(), subqs.end(), 7);
    enquire.set_query(q);

    // retrieve the top twenty results
    mymset = enquire.get_mset(0, 20);
    mset_expect_order(mymset, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("leave")));
    subqs.push_back(Xapian::Query(stemmer("fridge")));
    subqs.push_back(Xapian::Query(stemmer("on")));
    q = Xapian::Query(Xapian::Query::OP_NEAR, subqs.begin(), subqs.end(), 8);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 20);
    mset_expect_order(mymset, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("leave")));
    subqs.push_back(Xapian::Query(stemmer("fridge")));
    subqs.push_back(Xapian::Query(stemmer("on")));
    // test really large window size
    q = Xapian::Query(Xapian::Query::OP_NEAR, subqs.begin(), subqs.end(), 999999999);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 20);
    mset_expect_order(mymset, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14);

    return true;
}

/// Test NEAR over operators
DEFINE_TESTCASE(near2, positional) {
    Xapian::Database mydb(get_database("apitest_phrase"));
    Xapian::Enquire enquire(mydb);
    Xapian::Stem stemmer("english");
    enquire.set_weighting_scheme(Xapian::BoolWeight());

    // make a query
    vector<Xapian::Query> subqs;
    Xapian::Query q;
    subqs.push_back(Xapian::Query(Xapian::Query::OP_AND,
			    Xapian::Query(stemmer("phrase")),
			    Xapian::Query(stemmer("near"))));
    subqs.push_back(Xapian::Query(stemmer("and")));
    q = Xapian::Query(Xapian::Query::OP_NEAR, subqs.begin(), subqs.end(), 2);
    enquire.set_query(q);

    // retrieve the top ten results
    Xapian::MSet mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 1);

    subqs.clear();
    subqs.push_back(Xapian::Query(Xapian::Query::OP_AND,
			    Xapian::Query(stemmer("phrase")),
			    Xapian::Query(stemmer("near"))));
    subqs.push_back(Xapian::Query(stemmer("operator")));
    q = Xapian::Query(Xapian::Query::OP_NEAR, subqs.begin(), subqs.end(), 2);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 2);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("operator")));
    subqs.push_back(Xapian::Query(Xapian::Query::OP_AND,
			    Xapian::Query(stemmer("phrase")),
			    Xapian::Query(stemmer("near"))));
    q = Xapian::Query(Xapian::Query::OP_NEAR, subqs.begin(), subqs.end(), 2);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 2);

    return true;
}

/// Simple test of PHRASE
DEFINE_TESTCASE(phrase1, positional) {
    Xapian::Database mydb(get_database("apitest_phrase"));
    Xapian::Enquire enquire(mydb);
    Xapian::Stem stemmer("english");
    enquire.set_weighting_scheme(Xapian::BoolWeight());

    // make a query
    vector<Xapian::Query> subqs;
    Xapian::Query q;
    subqs.push_back(Xapian::Query(stemmer("phrase")));
    subqs.push_back(Xapian::Query(stemmer("fridge")));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 2);
    enquire.set_query(q);

    // retrieve the top ten results
    Xapian::MSet mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("phrase")));
    subqs.push_back(Xapian::Query(stemmer("near")));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 2);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("phrase")));
    subqs.push_back(Xapian::Query(stemmer("near")));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 3);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 1);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("phrase")));
    subqs.push_back(Xapian::Query(stemmer("near")));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 5);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 1);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("phrase")));
    subqs.push_back(Xapian::Query(stemmer("near")));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 6);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 1, 2);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("leave")));
    subqs.push_back(Xapian::Query(stemmer("fridge")));
    subqs.push_back(Xapian::Query(stemmer("on")));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 3);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 4);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("leave")));
    subqs.push_back(Xapian::Query(stemmer("fridge")));
    subqs.push_back(Xapian::Query(stemmer("on")));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 4);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 4);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("leave")));
    subqs.push_back(Xapian::Query(stemmer("fridge")));
    subqs.push_back(Xapian::Query(stemmer("on")));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 5);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 4);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("leave")));
    subqs.push_back(Xapian::Query(stemmer("fridge")));
    subqs.push_back(Xapian::Query(stemmer("on")));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 6);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 4);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("leave")));
    subqs.push_back(Xapian::Query(stemmer("fridge")));
    subqs.push_back(Xapian::Query(stemmer("on")));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 7);
    enquire.set_query(q);

    // retrieve the top twenty results
    mymset = enquire.get_mset(0, 20);
    mset_expect_order(mymset, 4);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("leave")));
    subqs.push_back(Xapian::Query(stemmer("fridge")));
    subqs.push_back(Xapian::Query(stemmer("on")));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 8);
    enquire.set_query(q);

    // retrieve the top 20 results
    mymset = enquire.get_mset(0, 20);
    mset_expect_order(mymset, 4);

    // test really large window size
    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("leave")));
    subqs.push_back(Xapian::Query(stemmer("fridge")));
    subqs.push_back(Xapian::Query(stemmer("on")));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 999999999);
    enquire.set_query(q);

    // retrieve the top 20 results
    mymset = enquire.get_mset(0, 20);
    mset_expect_order(mymset, 4);

    // regression test (was matching doc 15, should fail)
    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("first")));
    subqs.push_back(Xapian::Query(stemmer("second")));
    subqs.push_back(Xapian::Query(stemmer("third")));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 9);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset);

    // regression test (should match doc 15, make sure still does with fix)
    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("first")));
    subqs.push_back(Xapian::Query(stemmer("second")));
    subqs.push_back(Xapian::Query(stemmer("third")));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 10);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 15);

    // regression test (phrase matching was getting order wrong when
    // build_and_tree reordered vector of PostLists)
    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("milk")));
    subqs.push_back(Xapian::Query(stemmer("rare")));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 2);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 16);

    // regression test (phrase matching was getting order wrong when
    // build_and_tree reordered vector of PostLists)
    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("rare")));
    subqs.push_back(Xapian::Query(stemmer("milk")));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 2);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 17);

    return true;
}

/// Test PHRASE over operators
DEFINE_TESTCASE(phrase2, positional) {
    Xapian::Database mydb(get_database("apitest_phrase"));
    Xapian::Enquire enquire(mydb);
    Xapian::Stem stemmer("english");
    enquire.set_weighting_scheme(Xapian::BoolWeight());

    // make a query
    vector<Xapian::Query> subqs;
    Xapian::Query q;
    subqs.push_back(Xapian::Query(Xapian::Query::OP_AND,
			    Xapian::Query(stemmer("phrase")),
			    Xapian::Query(stemmer("near"))));
    subqs.push_back(Xapian::Query(stemmer("and")));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 2);
    enquire.set_query(q);

    // retrieve the top ten results
    Xapian::MSet mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset);

    subqs.clear();
    subqs.push_back(Xapian::Query(Xapian::Query::OP_AND,
			    Xapian::Query(stemmer("phrase")),
			    Xapian::Query(stemmer("near"))));
    subqs.push_back(Xapian::Query(stemmer("operator")));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 2);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset, 2);

    subqs.clear();
    subqs.push_back(Xapian::Query(stemmer("operator")));
    subqs.push_back(Xapian::Query(Xapian::Query::OP_AND,
			    Xapian::Query(stemmer("phrase")),
			    Xapian::Query(stemmer("near"))));
    q = Xapian::Query(Xapian::Query::OP_PHRASE, subqs.begin(), subqs.end(), 2);
    enquire.set_query(q);

    // retrieve the top ten results
    mymset = enquire.get_mset(0, 10);
    mset_expect_order(mymset);

    return true;
}

/// Test getting position lists from databases
DEFINE_TESTCASE(poslist1, positional) {
    Xapian::Database mydb(get_database("apitest_poslist"));

    Xapian::Stem stemmer("english");
    string term = stemmer("sponge");

    Xapian::PositionIterator pli = mydb.positionlist_begin(2, term);

    TEST(pli != mydb.positionlist_end(2, term));
    TEST(*pli == 1);
    pli++;
    TEST(pli != mydb.positionlist_end(2, term));
    TEST(*pli == 2);
    pli++;
    TEST(pli != mydb.positionlist_end(2, term));
    TEST(*pli == 3);
    pli++;
    TEST(pli != mydb.positionlist_end(2, term));
    TEST(*pli == 5);
    pli++;
    TEST(pli != mydb.positionlist_end(2, term));
    TEST(*pli == 8);
    pli++;
    TEST(pli != mydb.positionlist_end(2, term));
    TEST(*pli == 13);
    pli++;
    TEST(pli != mydb.positionlist_end(2, term));
    TEST(*pli == 21);
    pli++;
    TEST(pli != mydb.positionlist_end(2, term));
    TEST(*pli == 34);
    pli++;
    TEST(pli == mydb.positionlist_end(2, term));

    return true;
}

DEFINE_TESTCASE(poslist2, positional && writable) {
    Xapian::WritableDatabase db = get_writable_database();

    Xapian::Document doc;
    doc.add_term("nopos");
    Xapian::docid did = db.add_document(doc);

    // Check what happens when term doesn't exist - should give an empty list.
    // Threw RangeError in Xapian < 1.1.0,
    TEST_EQUAL(db.positionlist_begin(did, "nosuchterm"),
	       db.positionlist_end(did, "nosuchterm"));

    // Check what happens when the document doesn't even exist - should give
    // an empty list.  Threw DocNotFoundError in Xapian < 1.1.0.
    TEST_EQUAL(db.positionlist_begin(123, "nosuchterm"),
	       db.positionlist_end(123, "nosuchterm"));

    TEST_EQUAL(db.positionlist_begin(did, "nopos"),
	       db.positionlist_end(did, "nopos"));

    Xapian::Document doc2 = db.get_document(did);

    Xapian::TermIterator term = doc2.termlist_begin();

    {
	Xapian::PositionIterator i = term.positionlist_begin();
	TEST_EQUAL(i, term.positionlist_end());
    }

    Xapian::Document doc3;
    doc3.add_posting("hadpos", 1);
    Xapian::docid did2 = db.add_document(doc3);

    Xapian::Document doc4 = db.get_document(did2);
    doc4.remove_posting("hadpos", 1);
    db.replace_document(did2, doc4);

    {
	Xapian::PositionIterator i = db.positionlist_begin(did2, "hadpos");
	TEST_EQUAL(i, db.positionlist_end(did2, "hadpos"));
    }

    db.delete_document(did);
    // Check what happens when the document doesn't exist (but once did).
    TEST_EQUAL(db.positionlist_begin(did, "nosuchterm"),
	       db.positionlist_end(did, "nosuchterm"));

    return true;
}

/// Test playing with a positionlist, testing skip_to in particular.
/// (used to be quartztest's test_positionlist1).
DEFINE_TESTCASE(poslist3, positional && writable) {
    Xapian::WritableDatabase db = get_writable_database();

    vector<Xapian::termpos> positions;

    Xapian::Document document;
    document.add_posting("foo", 5);
    document.add_posting("foo", 8);
    document.add_posting("foo", 10);
    document.add_posting("foo", 12);
    db.add_document(document);

    Xapian::PositionIterator pl = db.positionlist_begin(1, "foo");
    Xapian::PositionIterator pl_end = db.positionlist_end(1, "foo");

    TEST(pl != pl_end);
    TEST_EQUAL(*pl, 5);
    ++pl;
    TEST(pl != pl_end);
    TEST_EQUAL(*pl, 8);
    ++pl;
    TEST(pl != pl_end);
    TEST_EQUAL(*pl, 10);
    ++pl;
    TEST(pl != pl_end);
    TEST_EQUAL(*pl, 12);
    ++pl;
    TEST(pl == pl_end);

    pl = db.positionlist_begin(1, "foo");
    pl.skip_to(5);
    TEST(pl != pl_end);
    TEST_EQUAL(*pl, 5);

    pl.skip_to(9);
    TEST(pl != pl_end);
    TEST_EQUAL(*pl, 10);

    ++pl;
    TEST(pl != pl_end);
    TEST_EQUAL(*pl, 12);

    pl.skip_to(12);
    TEST(pl != pl_end);
    TEST_EQUAL(*pl, 12);

    pl.skip_to(13);
    TEST(pl == pl_end);

    return true;
}

// Regression test - in 0.9.4 (and many previous versions) you couldn't get a
// PositionIterator from a TermIterator from Database::termlist_begin().
//
// Also test that positionlist_count() is implemented for this case, which it
// wasn't in 1.0.2 and earlier.
DEFINE_TESTCASE(positfromtermit1, positional) {
    Xapian::Database db(get_database("apitest_phrase"));
    Xapian::TermIterator t(db.termlist_begin(7));
    TEST_NOT_EQUAL(t, db.termlist_end(7));
    Xapian::PositionIterator p = t.positionlist_begin();
    TEST_NOT_EQUAL(p, t.positionlist_end());

    try {
	TEST_EQUAL(t.positionlist_count(), 1);
	t.skip_to("on");
	TEST_NOT_EQUAL(t, db.termlist_end(7));
	TEST_EQUAL(t.positionlist_count(), 2);
    } catch (const Xapian::UnimplementedError &) {
	SKIP_TEST("TermList::positionlist_count() not yet implemented for this backend");
    }

    return true;
}

redpajama_set_name: RedPajamaGithub


text:
Last edited by Nilmaran
3 edition of Infant attachment and three-year emotional expression found in the catalog.
Infant attachment and three-year emotional expression
Kirsten Blokland
by Kirsten Blokland
Published 1993 by National Library of Canada in Ottawa .
Thesis (M.A.)--University of Toronto, 1993.
Series Canadian theses = Thèses canadiennes
Pagination 2 microfiches : negative.
(Attachment and Emotion, page ) The quality of the attachment has "profound implications for the child's feelings of security and capacity to form trusting relationships" (Book). Simply stated, a positive early attachment will likely yield positive physical, socio-emotional, and cognitive development for the child. Epidemiological studies reveal a 16–18% prevalence of mental disorders among children aged 1 to 5 years, with somewhat more than half being severely affected (1– 3).There is evidence that many disturbances occurring in the first year of life that are commonly thought to be transient, e.g., infantile colic ("screaming baby"), persist beyond the first year in about one .
In the field of infant development, attachment refers to a special bond characterized by the unique qualities of maternal-infant or primary caregiver-infant relationships. The attachment bond has several key elements: (1) an attachment bond is an enduring emotional relationship with a specific person; (2) the relationship brings safety, comfort. According to Bowlby, an infant's internal working model of attachment develops into seven more developmental stages that occur across the life span. influences the child's subsequent responses to other people. deteriorates after the age of 24 months. has minimal impact on the child's subsequent responses to other people.
Child neglect and its consequences. British psychiatrist and psychoanalyst John Bowlby, the founding father of attachment theory, described attachment as an emotional bond that impacts behavior. In Study 1, emerging adults (Mage = , SD = ) completed a survey about perceived parental warmth, adult attachment, and interest in infants to determine if adult attachment .
Economic consequences of land reforms
Bothwell V1
Trap Door
Dissembling fictions
The astronomical almanac for the year
Sense of Smell (Senses)
Index of Navigation and Vessel Inspection Circulars (NVICs).
Development trends in Berkshire
Tralee draft development plan, 1996
Survey and analysis of aquaculture development research priorities and capacities in Asia
Declaration of Paris
Contra verse
Infant attachment and three-year emotional expression by Kirsten Blokland Download PDF EPUB FB2
Understanding Attachment: Parenting, Child Care, and Emotional Development - Kindle edition by Mercer, Jean. Download it once and read it on your Kindle device, PC, phones or tablets.
Use features like bookmarks, note taking and highlighting while reading Understanding Attachment: Parenting, Child Care, and Emotional Development/5(3). The relation between the secure/insecure mother-child attachment and the emotional sphere of the child is reported in the studies [11, 12].
We suggest the presence of the happy face expressions of. "We seem to be living in the 'Age of Attachment,'" writes psychologist Jean Mercer, author of Understanding Attachment: Parenting, Child Care, and Emotional is surprised how often the term "attachment" comes up in discussions about baby.
to observe attachment relationships between a human caregiver and child. [1] The most common and empirically supported method for assessing attachment in infants (12monthsmonths) is the Strange Situation Protocol, developed by Mary Ainsworth (see Patterns of Attachment;[2]).File Size: KB.
Months: 'Warming up' the Bond. When the infant is between weeks of age, the stage for developing secure attachment is being set. During this pre-attachment period the mother will 'warm up' the emotional bond with her sensitive and consistent responses.
The emotional bond that forms between the infant and primary caregiver during the first year is called attachment Whenever his parents try to teach Brad. Attachment is the emotional bond that forms between infant and caregiver, and it is the means by which the helpless infant gets primary needs met.
Insecure attachment does not necessarily cause 'significant emotional harm or injury' nor does secure attachment cure the tely it is likely to be a result of a combination of different genetic and environmental factors which impact on very early brain development which influence the myriad of behaviours that are seen in.
Understanding Attachment. Attachment is an emotional bond with another person. Bowlby believed that the earliest bonds formed by children with their caregivers have a tremendous impact that continues throughout life. He suggested that attachment also serves to keep the infant close to the mother, thus improving the child's chances of survival.
Different methods, examining infants at different ages, give rise to slightly different estimates of the timetable of infant ability to discriminate, categorize and understand the meaning of emotional expressions. Infants begin to differentiate and recognize social signals within the first few months of life by abstracting information that is.
Around age 4 months, infants can begin distinguishing the different emotional expressions of others. Later, around age 6 months, babies begin to mimic the emotions and expressions they see in others. At birth, babies treat caregivers more or less interchangeably, unequipped as they are, by and large, to distinguish among people.
Effects of Secure and Insecure Attachment. The type of emotional attachment established during the first four or five years usually lasts a lifetime.
The pattern of early attachment significantly influences the quality of love relationship an individual will have as a teenager, adult, and even as a parent with his or her own children. If the infant learns that their base of security is either unresponsive or unreliable, exploration will be adversely affected along with the infant's expression of needs.
In Mary Ainsworth designed the 'Strange Situation Paradigm' to study the attachment behaviours of infants and young children in the laboratory. The attachment bond is the emotional connection formed by wordless communication between an infant and you, their parent or primary caretaker.
A landmark report, published in by The Committee on Integrating the Science of Early Childhood Development, identified how crucial the attachment bond is to a child's development.
During the first years of life children develop early attachment relationships with their primary caregivers. These attachment relationships, either secure or insecure, will shape children's socio-emotional development.
In the USA, the predominant curricular approach is the one that situates the child at the center of the curriculum. child toward his or her mother when first meeting someone new. This new "use" of the other to navigate a social situation (often considered a social advance) is entirely de pendent on the young child's ability to dif ferentiate and respond to another's affective expression (which could be considered an emotional advance).
The Four Infant Attachment Styles - Straight to the Point, Quick Understanding. This page about infant attachment styles will please you if: You are interested in the academic understanding of infant bonding and the psychology of children.
You are in the mood for straight-to-the-point scientific parenting talk. Inevitably a strong attachment results in the development of infants who rate higher on sensitivity, acceptance, cooperation in addition to emotional accessibility (Ainsworth et.
Attachment is the deep emotional bond between a baby and the person who provides most of their care. Just as most parents feel a strong connection with their newborn after birth, babies also become attached to their parents. Attachment takes place throughout a child's development, but this document focuses on babies.
Parents of infants and young children face many challenges when dealing with negative emotions such as crying, distress, fear and anger. If children experience such emotions chronically, and these are not mitigated by parents, evidence suggests that the stress can result in irreversible brain damage.
These changes can increase the likelihood of serious problems in children's. Participants were asked to judge the point at which the emotional expression had disappeared or emerged, respectively. Individuals who were highly anxious with respect to attachment were more likely to perceive the offset (Study 1) as well as the onset (Studies 2 and 3) of the facial expressions of emotion earlier than other people.
Developing a secure attachment with your child can help them in many ways. Children with a strong bond with a parent/guardian are more likely to have higher self-esteem, perform better in school, have positive relationships, and manage stress.
Here are four simple ways you can develop an attachment with your child.Bonding at months: what it looks like and how to respond.
Your baby learns about the world and forms relationships by watching parents, siblings and the people around her. She watches the way your face reacts when she does something – for example, when she smiles at .
erum-c.com - Infant attachment and three-year emotional expression book © 2020


text:
Q: Is there a way that I can copy rows from one sheet to the other excluding existing one? I'm trying to create a code in Google Apps Scripts for the spreadsheet I'm currently working on. I have two sheets namely "Source" and "Destination" and the following consideration are...

*

*Source have all the data and needed to be transferred to the Destination.

*Don't copy the rows from the source sheet that are already existing in the destination sheet.

*Only copy the rows with cells in column A that contains today's date.

A: Since you are have not provided any code. I think the best approach would be to look at the documentation and other answered questions here to plan your approach to solving the problem.
Since you are working at sheet to sheet level. I think a good starting point could be using range data (https://developers.google.com/apps-script/reference/spreadsheet/sheet see getRange()) to read many rows of the source and compare them with the destination data. But your problem is extremely loosely defined.
That being said there are so many unanswered questions. What happens when the source and destination grow larger? I would suspect the cost of comparing the data between both the sheets would increase as well. Even if you were to process 10,000 rows of the first sheet against the contents of the destination the destination sheet would keep growing and you would have to compare each batch of the source rows against all rows of the destination.


The Education Bureau has defended its choice to liken Beijing-Hong Kong relationship to one between a school principal and a teacher in a newly-released teaching package, despite criticism from the public.
"The analogy is intended to allow students to grasp complicated, difficult and abstract concepts through everyday life examples that they can relate to. This kind of teaching method is often used in other subjects," the bureau said in a statement on Friday.
The video in question. Photo: GovHK.
Its remarks came after the Education Bureau recently issued new guidelines to schools requiring them to teach 51 hours of Basic Law-related material to secondary students between Form 1 and Form 3. The bureau also released a revised teaching package on Wednesday.
Basic Law teaching material. Photo: GovHK video.
Education sector lawmaker Ip Kin-yuen said on an RTHK programme on Friday that the analogy is "problematic" because it fails to highlight the uniqueness of the One Country, Two System policy.
Basic Law Promotion Steering Committee member Simon-Hoey Lee, speaking on the show, said the analogy was not meant to be all-encompassing, but to demonstrate the power difference between the Chinese government and Hong Kong.
"We need to consider the fact that the audience is secondary school students. The material cannot be too complicated," he said. He added that the package was made after some teachers said they had difficulty teaching students about the Basic Law.
Ip Kin-yuen. File Photo: Ip Kin-yuen, via Facebook.
"The issue is that the nature of the relationship in this analogy is completely different," he said. The lawmaker argued that the analogy would fit Beijing's relationship with Chinese provinces and cities, but not Hong Kong as it has a different status.
Ip added that the content of government materials must be professional and accurate, as they are considered authoritative.
In response, Lee said he will consider the feedback. He said the Department of Justice, the Education Bureau and a number of teachers took part in the process of creating the package.
Another member of the Basic Law promotion body and secondary school principal Choi Yuk-lin said teachers are free to adapt the materials for their classes.
Under the new guideline, schools are expected to incorporate Basic Law teaching in four subjects: Chinese history, life and society, history and geography. The bureau says the programme consists of activities that are already part of the school curriculum, and does not constitute "additions" to the syllabus.
In January, the Education Bureau was criticised for proposing the mandatory curriculum without consulting advisers.


It was announced this week that a Tetris movie was in the works. This should make everyone question the sanity and intelligence of the decision makers in Hollywood. Of course movies based on every nostalgic childhood experience look like a gold mine to the studios so this is to be expected. But expected or not it is a sad state of the entertainment industry when a studio will spend millions on stupid ideas like the Tetris movie instead of getting behind the many talented independent filmmakers out there. Since the studios turn a blind eye to these film makers, they are forced to fund their own projects through one of the crowdfunding sites or through their own hard work and day job.
One such group of filmmakers is experiencing this even as we speak. The production team behind the award winning horror film Truth or Dare (Check out our review of this film here), Jessica Cameron and Jonathan Higgins, are actively trying to raise the money for their next set of films. It is a very ambitious project but it sounds like something every film fan should get behind. They are making what can only be described as an American Cross Country Horror Trilogy, 2 brand new films and one documentary chronicling their journey. This is a major undertaking and if you are tired of the crap Hollywood is putting out, it is time to put your money where your mouth is!
So please go to their campaign site and support this group of film makers. It is about time that we as a critical audience use our money to tell Hollywood that we prefer original ideas over things like Tetris: the Movie!
October 1, 2014 in Good Nerd Bad Nerd, Indigogo, Jessica Cameron, Jonathan Higgins, Kill the PA.


This was a 1st project fit-out with this fashion brand and was completed within an 8 week time-frame.
Oakwoods completed the refurbishment of a Le Creuset Store at Cheshire Oaks.
Oakwoods worked with Listed Building Officers, Archaeologists and had asbestos removal carried out on this Grade 2 Listed Building.
Oakwoods removed all items from the existing Hunter Store at the high end Luxury Outlet Centre, Bicester Village, this was in preparation for a move to a new location on the same site.
Oakwoods installed a new Foyles Book Store in Bond Street, Chelmsford within a 12 week time-frame.


This is a 12 LED 3" X 6" Interior Compartment Light by Maxxima, 4-hole surface mount with 2-wire connection. This new & improved compartment light is perfect for overhead cab or other interior lighting. Its refrigeration-safe design and the super bright LED output make it the most durable and versatile lighting option.


text:
The North Atlantic Conference was a short-lived intercollegiate athletic conference of HBCUs that existed only during the 1946 season. The league had members in the state of Pennsylvania.

Football champions
1946 – Cheyney State

See also
List of defunct college football conferences

References

Defunct college sports conferences in the United States
College sports in Pennsylvania

redpajama_set_name: RedPajamaWikipedia


How to get the cheapest price for your train ticket Ebenhofen to Duesseldorf-Bilk?
The most popular departure dates and times to travel to Duesseldorf-Bilk from Ebenhofen are more expensive, so try to be flexible if possible.
Our system will always offer you the best fares for your tickets from Ebenhofen to Duesseldorf-Bilk.
Advance tickets from Ebenhofen to Duesseldorf-Bilk are the cheapest train tickets. You may book up to 3 months in advance.
Need help to buy your rail ticket from Ebenhofen to Duesseldorf-Bilk?
Questions , remarks about your rail trip Ebenhofen to Duesseldorf-Bilk?


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Copyright © 2017 National Benefit Consultants, Inc.


text:
Q: Form Sending file but not form element via Ajax I am trying to send a file and some information to a php page to upload to the server and store in the database.  The form uploads the file to a documents folder and then stores the details in the database  perfectly.  However the other elements of the form, are not being sent.
Below is my code.
     $(document).ready(function(){
        $("#but_upload").click(function(){
            var fdata = new FormData()
            fdata.append("lead_id", $("lead_id").val());
            var files = $('#file')[0].files;
            // Check file selected or not
            if(files.length > 0 ){
                fdata.append('file',files[0]);
                $.ajax({
                    url:'upload3.php',
                    type:'post',
                    data:fdata,
                    contentType: false,
                    processData: false,
                    success:function(response){
                        if(response != 0){
                            $("#show_message_document").fadeIn();
                        }else{
                            alert('File not uploaded');
                        }
                    }
                });
            }else{
                alert("Please select a file.");
            }
        });
    });

My form
  <form method="post" action="" enctype="multipart/form-data" id="myform">
    <input type="file" id="file" name="file" />
    <input type="hidden" id="lead_id" name="lead_id" value="<?php echo $lead_id; ?>">
    <input type="button" class="button" value="Upload" id="but_upload">
  </form>

My Php
   $lead_id = ($_POST['lead_id']);

A: You're trying to get "lead_id" without any selector, either use "#lead_id" or "[name=lead_id]".
Working code:
<script type="text/javascript">
    $(document).ready(function(){
        $("#but_upload").click(function(){
            var fdata = new FormData();
            fdata.append("lead_id", $("#lead_id").val());
            var files = $('#file')[0].files;
            // Check file selected or not
            if(files.length > 0 ){
                fdata.append('file',files[0]);
                $.ajax({
                    url:'upload.php',
                    type:'post',
                    data:fdata,
                    contentType: false,
                    processData: false,
                    success:function(response){
                        if(response != 0){
                            $("#show_message_document").fadeIn();
                        }else{
                            alert('File not uploaded');
                        }
                    }
                });
            }else{
                alert("Please select a file.");
            }
        });
    });
</script>

Hope this helps!!