Overall survival (OS) was improved by 21 percent in patients with relapsed or refractory multiple myeloma who were on Kyprolis (carfilzomib) plus dexamethasone rather than dexamethasone plus Velcade (bortezomib), according to results of the phase 3 ENDEAVOR trial announced by Amgen.
The median OS was 47.6 months in the Kyprolis arm versus 40.0 months in Velcade arm. The safety data were consistent with previously reported study outcomes. The full updated results from the trial will be presented at the 16th International Myeloma Workshop, which is being held in New Delhi from March 1 to 4, 2017.
"For an incurable disease like multiple myeloma, a major treatment goal for oncologists and hematologists is to help patients live as long as possible," study co-author and investigator Meletios A. Dimopoulos, M.D., professor of Clinical Therapeutics at the National and Kapodistrian University of Athens, School of Medicine said in a statement. "Based on these data, we now know that Kyprolis not only significantly extended progression-free survival (PFS)compared to Velcade, but also OS, making it a clinically meaningful advance in the treatment of relapsed or refractory multiple myeloma."
The phase 3 ENDEAVOR study randomized 929 patients to receive Kyprolis as a 30-minute infusion along with dexamethasone (464 patients) or Velcade and dexamethasone (465 patients). Kyprolis was administered at a starting dose of 20 mg/m2 on days one and two of cycle. If tolerated, the dose was escalated to 56 mg/m2 on day eight of cycle one. After this point, the 56 mg/m2 dose was maintained on days nine, 15 and 16 and throughout subsequent cycles. In the control arm, patients received Velcade at 1.3 mg/m2. The majority of patients received Velcade subcutaneously (75 percent).
The median age of patients enrolled in the trial was 65 years. All but 7 percent of patients had ECOG PS of 0 or 1 (about 50 percent ECOG 0), and about 20 percent of the patients had high-risk cytogenetic by fluorescence in situ hybridization. The primary endpoint was PFS, with OS, objective response rate (ORR), duration of response and safety as secondary measures.
Kyprolis and dexamethasone reduced the risk of progression by 47 percent compared with Velcade and dexamethasone. The median PFS with Kyprolis was 18.7 versus 9.4 months with Velcade. The advantage in PFS seen with Kyprolis was consistent across subgroups.
The ORR was 77 percent with Kyprolis versus 63 percent with Velcade. The complete response rate with Kyprolis was 13 percent versus 6 percent with Velcade. The rate of very good partial response or better with Kyprolis was 54 percent compared with 29 percent with Velcade.
Grade 3 adverse events (AEs) occurred more frequently in the Kyprolis arm compared with Velcade (73 percent vs 67 percent). Additionally, serious AEs were more common with Kyprolis (48 percent vs 36 percent). However, dose reductions associated with AEs were more frequent with Velcade versus Kyprolis (48 percent vs 23 percent). Treatment discontinuation due to AEs and on-study deaths were comparable between the two arms.
Grade 3 or higher hematologic adverse events occurred in a similar proportion of patients in both groups, including anemia, thrombocytopenia, neutropenia, upper respiratory infection and pneumonia. However, there was an increase in the incidence of hypertension and dyspnea with Kyprolis versus Velcade. The most frequent non-hematologic grade 3 or higher AEs were diarrhea, fatigue, dyspnea, pyrexia, constipation and insomnia.
Peripheral neuropathy occurred in 5 percent of patients treated with Velcade and 1.3 percent of those in the Kyprolis arm. The proportion of patients with grade 2 or higher peripheral neuropathy was significantly higher with Velcade (32 percent versus 6 percent).


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redpajama_set_name: RedPajamaGithub


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The 'noise' over Provincial Administration
"Look at the Constitution. Read it. And then look at the people asking you to vote for it. Then ask yourself: What's the worst that it can come to (in its implementation)? If you trust the letter and the spirit, vote 'Yes', if you trust the spirit but not the letter, vote 'No' " –Talkshow Guest, (was it Charles Kanjama or Chris Foot, one of the two).
The controversy over the provincial administration has the media and politicians talking at each other. The debate is unwarranted. IMHO, it is just politics. The Constitution is very clear at the Sixth Schedule (17): "Within five years after the effective date, the national government shall restructure the system of administration commonly known as the provincial administration to accord with and respect the system of devolved government established under this Constitution."
I find it stupid for some MPs and journalists too, to argue that this role does not lie with the folks at Harambee House. Seriously, I think it does. Or what do you understand by "national government?" Harambee House, in case you forgot, is the Office of the President, who, as we say, he is the Head of Government. So once again, President Kibaki and his mandarins knew what they meant when they said the Provincial Administration will be "restructured". And I think the Committee of Experts gave the mandate to these fellows at OP, deliberately.
You remember the PS at OP, Francis Kimemia, saying recently that "tumefunga kutengeneza districts hadi tujenge hizi tumetengeneza kwanza, ingawa watu walikuwa wanataka tuendelee" (We're not coming up with other districts until we build the ones we've set up, 284 in total).
Such a statement came just early this month, just days after the new Constitution was promulgated.
So this issue about "devolution" and "two parallel systems" and that the existence of the provincial administration will be "undermining the county governments", to me, it seems like flummery. For real. It is just politics.
The guys out calling news conferences saying the chiefs, DCs, PCs, DOs "should just go home" have seriously not understood the letter, even as they are right about the spirit.
I doubt that the devolution will work the way it is structured--47 counties and the national government. There's a huge gap, (regions must have been somewhere, only that someone said they were expensive, so some said abolish counties and have the regions, and people said, we need to have a say in our affairs at a local level).
For now, the powers are still tilted towards the centre, only the money will be going to the grassroots. Hopefully that will be in 2012. Or what do you guys think?
PS: Now, if this is the kind of controversy over chiefs, DCs, Dos and PCs. What'll happen when it comes to the date of elections? I see fireworks.
NB: I am on leave and didn't think I'd blog, but then again, the fingers were itching.
Shaking off the 'leave' hangover :)
I don't think these fellows will pay tax!

redpajama_set_name: RedPajamaCommonCrawl


Follow the Vikings' way from northeast Scotland to the land of the midnight sun. Our enthusiastic historian and expert naturalist reveal the Orkney and Shetland islands, from Stone Age villages and Viking relics, to world class distilleries and spectacular birdlife. We follow migrating whales along Norway's dramatic coast, visit picturesque fishing villages and toast our Arctic Circle crossing. In Spitsbergen, we enter a polar wonderland, where delicate wildflowers adorn tundra and the summer sun never sets. This spectacular wilderness is the breeding ground of walruses, reindeers, various birds and polar bears.
Our staff welcome you aboard Polar Pioneer mid-afternoon in Aberdeen, Scotland, before we start sailing north.
Among Orkney's archipelago of 70 windswept islands, a treasure trove of archaeology, history and wildlife awaits. We follow the passage of time – from 5000-year-old, World Heritage-listed, Neolithic sites to Viking relics, from reminders of World War II occupation to present-day crofting communities. Imposing sea cliffs teem with seabirds, inviting our Zodiacs and kayakers to explore coastlines. At Fair Isle we visit traditional crofts to admire local knitwear and nearby colonies of fulmars, kittiwakes, guillemots, gannets, shags and puffins.
Warmed by Gulf Stream currents and near 24-hours' daylight, the Shetland's 100 islands are peppered with nature reserves and archaeological sites. These include the complex Stone, Bronze and Iron Age settlement of Jarlshof, the world's best preserved broch (fortified Iron Age tower) on Mousa, and remnants of Viking conquest along the coast.
As we sail towards Norway, our historian and naturalist delight us with fascinating talks and inspire our birdwatching.
An intricate maze of islands protects Norway's coastline. We celebrate crossing the Arctic Circle and visit special places, like Sør Gjaeslingan, once home to a busy cod-fishing fleet. Today it provides fantastic birdlife, including kittiwakes, terns and skuas that migrate here each summer. Continuing north, we pass by Torghatten, a mountain with a distinctive hole through it, and learn the fable of lost love and a troll's arrow. Majestic scenery delights in Lofoten Islands, from romantic beaches to narrow fjords hemmed by granite walls. Share the water with orcas, the skies with puffins.
We cross the Barents Sea, past often fog-shrouded Bear Island, favourite nesting ground for fulmars, kittiwakes, guillemots and gulls. Beyond Spitsbergen's South Cape, we explore South Spitsbergen National Park, a sanctuary for barnacle geese and eider ducks, before entering the iceberg-laden waters of Hornsund. Surrounded by polar desert on a grand scale, we search for reindeer, ringed and bearded seals and the mighty polar bear. Learn of human history dating back 400 years and if lucky, we'll encounter the elusive beluga whale.
We disembark in Longyearbyen, bid goodbye to expedition staff and are transferred to the airport for our onward journey.
The trip was simply brilliant, a great adventure providing us with wonderful memories and exceptional insight into this fragile environment. Thank you all so very much.
We cannot thank you enough and know well that the experiences our 3 children had with Aurora will change their lives, their understanding of the world and their place in it.
Opt for a self-drive tour of spectacular southern Scotland and explore at your own pace.


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Cast irons and their Classification
cast iron, cementite, ductile iron, eutectic, Ferrite, graphite, gray iron, malleable iron, SG iron, white iron,
The term 'cast iron' represents a large family of ferrous alloys. Cast irons are multi-component ferrous alloys, which solidify with a eutectic. The major elements of cast irons are iron, carbon (2 % or more), silicon (1 % to 3 %), minor elements (less than 0.1 %), and often alloying elements (less than 0.1%). Cast iron has higher carbon and silicon contents than steel. The structure of cast iron displays a richer carbon phase than that of steel because of its higher carbon content. Cast iron can solidify according to the thermodynamically metastable Fe-Fe3C (iron carbide) system or the stable iron-graphite system depending principally on composition, cooling rate, and melt treatment.
Cast iron in its basic form is a brittle material which has a very little impact strength. It has a little or practically no toughness when compared to low carbon steels. It has a fraction of the tensile strength of low carbon steels. When a cast iron piece fails it does not deform in a noticeable way and appears to snap apart or break in a manner consistent with a snap. There is no early warning of a failure. The graphite phase which is pure carbon acts as a natural defect in the material. The iron is so saturated with carbon that graphite forms (free carbon) and causes the cast iron to be weaker. Much smaller amounts of carbon is combined with iron (Fe) in the form of iron carbide (Fe3C, cementite) which is hard and brittle.
During the solidification process, when the metastable route is followed, the rich carbon phase in the eutectic is the iron carbide and when the stable solidification route is followed, the rich carbon phase is graphite. Referring only to the binary Fe-Fe3C or iron-graphite system, cast iron can be defined as an iron-carbon alloy with more than 2 % C. However silicon and other alloying elements can considerably change the maximum solubility of carbon in austenite. Therefore, in exceptional cases, alloyed cast iron with less than 2 % C can solidify with a eutectic structure and therefore still belong to the family of 'cast irons'.
The formation of stable or metastable eutectic is a function of many factors, which include the nucleation potential of the liquid, chemical composition, and cooling rate. The first two factors control the graphitization potential of the iron. A high graphitization potential results in irons with graphite as the rich carbon phase, while a low graphitization potential result in irons with iron carbide.
The two basic types of eutectics, the stable austenite-graphite and the metastable austenite-iron carbide, have wide differences in their mechanical properties, such as strength, hardness, toughness, and ductility. Therefore, the basic purpose of the metallurgical processing of cast iron is to influence the type, amount, and morphology of the eutectic in order to achieve the desired mechanical properties.
The properties of cast iron can be varied widely by varying the percentages of carbon and silicon, by alloying with various metallic elements, and by varying the practices of melting, casting, and heat treatment.
The metallurgy of cast irons has many similarities to that of steel, but the differences are important to the metallurgist who works with cast irons. Since the common grades of steel contain low amount of alloying elements, they are normally be considered as binary iron-carbon alloys and the iron-carbon diagram (Fig. 1) can be used to interpret their structures under conditions of slow or near-equilibrium transformation.
Fig 1 Iron carbon diagram
The cast irons, however, contain appreciable amounts of silicon in addition to higher carbon contents, and hence they are to be considered ternary Fe-C-Si alloys. The additional constituent silicon changes the iron-carbon diagram. A section through the ternary Fe-Fe3C-Si diagram at 2 % silicon (which approximates the silicon content of many cast irons) provides a convenient reference for discussing the metallurgy of cast iron (Fig 2). The diagram resembles the binary Fe-Fe3C diagram, but shows important differences characteristic of ternary systems. Eutectic and eutectoid temperatures change from single values in the Fe-Fe3C system to temperature ranges in the Fe-Fe3C-Si system. The eutectic and eutectoid points shift to lower carbon contents. It also represents the metastable equilibrium between iron and iron carbide (cementite), a metastable system. The silicon that is present remains in solid solution in the iron, in both ferrite and austenite, so it affects only the conditions and the kinetics of carbide formation on cooling, not the composition of the carbide phase.
Fig 2 Section through the ternary Fe-Fe3C-Si diagram at 2 % silicon
Some of the silicon may precipitate along with the carbide, but it cannot be distinguished as a different phase. The solidification of certain compositions occurs not in the metastable system, but rather in the stable system, where the products are iron and graphite rather than iron and carbide. In short, the addition of silicon to a binary iron-carbon alloy decreases the stability of Fe3C, which is already metastable, and increases the stability of ferrite. As the silicon content in the Fe-C-Si system increases, the carbon contents of the eutectic and eutectoid decrease, while the eutectic and eutectoid temperatures increase.
It is convenient to combine the effect of the silicon with that of the carbon into a single factor, which is called the carbon equivalent (CE). The CE of a cast iron describes how close a given analysis is to that of the eutectic composition. The CE of the eutectic without silicon is at 4.3 %. As the silicon content of iron is increased, the carbon content of the eutectic is decreased. There is a linear relation and can be expressed as a simple equation given below.
CE = % C+ 1/3 % Si = 4.3 (at 0 % silicon)
A CE of 3.9 represents an alloy of lower carbon and silicon content (hypoeutectic) than the eutectic composition, and a CE of 4.6 represents an alloy of greater carbon and silicon content (hypereutectic) than the eutectic composition. Irons of the same CE value may be obtained with different carbon and silicon values.
Other values representing the CE of cast irons have also been proposed. When appreciable amount of phosphorus is present in the iron, the phosphorus content of the iron is included in the CE equation which is as follows.
CE = % C+ (% Si+% P)/3
Thus, an iron with 3.2 % C, 2 % Si, and 0.4 % P has a CE value of 4.0 and is hypoeutectic. An iron with 3.2 % C, 2 % Si, and 1.3% P has a CE value of 4.3 and is eutectic. An iron with 3.2 % C, 2.6 % Si, and 1.3 % P has a CE value of 4.5 and is hypereutectic. The total carbon and silicon contents of the alloy, as related in the CE value, not only establish the solidification temperature range of the alloy, but are also related to the foundry characteristics of the alloy and its properties. Cast irons of constant CE, but with appreciably different carbon and silicon contents, do not have similar casting properties. Carbon is more than twice more effective in preventing solidification shrinkage than the CE equation indicates. However, silicon is more effective in keeping thin sections from becoming hard. There are similar differences in some of the use properties, and these limit the value of CE in specifications.
The main factors which have influence on the micro structure of the cast iron are (i) chemical composition, (ii) cooling rate, (iii) liquid treatment, and (iv) heat treatment. In addition, the following aspects of combined carbon in cast irons need to be considered.
In the original cooling or through subsequent heat treatment, a matrix can be internally decarburized or carburized by depositing graphite on existing sites or by dissolving carbon from them.
Depending on the silicon content and the cooling rate, the pearlite in iron can vary in carbon content. This is a ternary system, and the carbon content of pearlite can be as low as 0.50 % with 2.5 % Si.
The measured hardness of graphitic cast irons is influenced by the graphite, especially in gray cast iron. Martensite micro hardness may be as high as 66 HRC or as low as 54 HRC in gray cast iron (58 HRC in ductile).
The critical temperature of iron is influenced (raised) by silicon content, not by the carbon content.
Classification of cast irons
Historically, the first classification of cast iron was based on its fracture. Initially cast iron was classified into two types namely white cast iron and gray cast iron as given below.
White cast iron – It exhibits a white, crystalline fracture surface since fracture in this cast iron occurs along the iron carbide plates. It is the result of metastable solidification (Fe3C eutectic). White cast iron is named such since this iron is having characteristic white fracture surface. This cast iron is formed when the carbon in solution in the liquid iron does not form graphite on solidification but remains combined with the iron, often in the form of massive carbides. The carbon is present in the form of carbides mainly Fe 3C and Cr7C3. Sometimes in white cast irons there are present complex carbides such as (Fe,Cr)3C from additions of 3 to 5 % Ni and 1.5 to 2.5 % Cr, (Cr,Fe) 7C3 from additions of 11 to 35 % Cr or those containing other carbide-forming elements. White cast iron is hard and brittle and produces white, crystalline fracture surface. White cast iron has high compressive strength (more than 1380 N/sq mm) and good retention of strength and hardness at elevated temperature. It is very often used for its excellent resistance to wear and abrasion. The massive carbides in the microstructure are chiefly responsible for these properties. White cast irons are produced by chilling some surfaces of the cast mould. Chilling prevents formation of graphite during solidification of the cast iron. Applications of white cast irons include brake shoes, shot blasting nozzles, mill liners, crushers, pump impellers and other abrasion resistant parts.
Gray cast iron – It exhibits a gray fracture surface consisting of ferrite and dispersed graphite flakes. When the composition of the iron and the cooling rate at solidification are suitable, a substantial portion of the carbon content separates out of the liquid to form flakes of graphite. The fracture path of such iron follows the graphite flakes. The fracture surface of this iron appears gray because of the predominance of exposed graphite. Gray cast iron is the result of stable solidification produced at slow cooling. It has several unique properties that are derived from the existence of flake graphite in the microstructure. It possesses high compressing strength, fatigue resistance and wear resistance. It is relatively soft and can be machined and welded easily. It has hardness conducive to good wear resistance. It resists galling under boundary-lubrication conditions. It has very good properties for use in vibration damping or moderate thermal shock applications. It is used for engine cylinder blocks, gears, flywheels, water pipes, brake discs, and machine tool structures etc.
Presently the common classification scheme divides cast irons into four basic types. These are (i) white cast iron, (ii) gray cast iron, (iii) ductile cast iron, and (iv) malleable cast iron. While the white cast iron and gray cast iron are described above, the ductile cast iron and malleable cast iron are described below.
Ductile cast iron – It derives its name from the fact that, in the as-cast form, it exhibits measurable ductility. By contrast, neither white nor gray iron exhibits significant ductility in a standard tensile test. It is also known as nodular iron or spheroidal graphite cast iron. It is similar to gray iron in composition but during casting of ductile cast iron the graphite is caused to nucleate as spherical particles instead of flakes. This is achieved through the addition of a very small but definite amount of magnesium and/or cerium to the molten iron through a process step called nodulizing. The ductile cast iron consists of spheroid nodular graphite particles in ferrite or pearlite matrix. It is produced from the same raw materials as gray iron, but these materials are to be purer especially with respect to sulphur. Casting properties of ductile cast iron such as fluidity etc. are similar to those of gray cast iron. Main advantage of ductile cast iron over gray cast iron is its combination of high strength with ductility. They also possess good fatigue strength, wear resistance, shock resistance, and high modulus of elasticity. Martensitic ductile cast irons and austempered ductile cast irons exhibit even better properties. Applications of nodular (ductile) cast irons include automotive engine crankshafts, heavy duty gears, military vehicles, and railway wagons.
Malleable cast iron – It is cast as white cast iron, then "malleabilized" (i.e., heat treated to impart ductility to an otherwise brittle material). The micro structure consists of ferrite and particles of free graphite. This cast iron encompasses a form of graphite called temper carbon. This form of graphite is produced by the heat treatment of white cast iron. When a white cast iron is heated for an extended period of time (about 60 hours) at a temperature of 960 deg C, the cementite decomposes into austenite and graphite. By slow cooling from 960 deg C, the austenite transforms into ferrite or pearlite depending on the cooling rate and the diffusion rate of carbon. The ductility and toughness of malleable cast iron falls between that of ductile cast iron and gray cast iron. Now a days malleable cast irons have been replaced by the more economically produced ductile irons cast for many uses. Malleable cast irons besides ductility have good machinability. Ferritic malleable cast irons are more ductile and less strong and hard, than pearlitic malleable cast irons. Applications of malleable cast irons include parts of power train of vehicles, bearing caps, steering gear housings, agricultural equipment, and railroad equipment.
With the advent of metallography, and as the body of knowledge pertinent to cast iron increased, other classifications based on microstructural features became possible. These classifications are made due to graphite shape or due to the matrix of the structure and are given below.
Graphite shape – Due to the graphite shape cast irons are classified as (i) lamellar (flake) graphite (FG), (ii) spheroidal (nodular) graphite (SG), (iii) compacted (vermicular) graphite (CG), and (iv) temper graphite (TG). Temper graphite results from a solid-state reaction (malleabilization).
Matrix of the structure – Due to the matrix of the structure cast irons are classified as (i) ferritic, (ii) pearlitic, (iii) austenitic, (iv) martensitic, and (v) bainitic (austempered).
Besides the four basic types, there are other specific forms of cast iron to which special names have been applied. These are given below.
Chilled iron – It is white iron that has been produced by cooling very rapidly through the solidification temperature range.
Mottled iron – It is an area of the casting that solidifies at a rate intermediate between those for chilled and gray iron, and which exhibits microstructural and fracture-surface features of both types.
Compacted graphite cast iron – It is also known as vermicular iron. It is characterized by graphite that is interconnected within eutectic cells, as is the flake graphite in gray iron. The graphite in compacted graphite cast iron is coarser and more rounded than the graphite in gray cast iron. Its structure is intermediate between the structures of gray cast iron and ductile cast iron. The unique combinations of properties obtainable in compacted gray cast irons make them superior to either gray or ductile cast irons. The major applications are disc-brake rotors and diesel-engine heads. Compacted graphite cast iron can be produced by carefully controlling the amount of magnesium added as an inoculant in a process very similar to the process used to make ductile cast iron.
High-alloy graphitic iron -They are used primarily for applications requiring corrosion resistance or a combination of strength and oxidation resistance. They are produced in both flake graphite (gray cast iron), or spheroidal graphite (ductile cast iron).
Lastly, a classification used frequently by the floor foundry worker divides cast irons into two categories. These are (i) common cast irons which are used for general-purpose applications mainly unalloyed or low alloy cast irons, and (ii) special cast irons which are used for special applications and are generally high alloy cast irons. Special cast irons differ from common cast irons mainly in the higher content of alloying elements (more than 3 %), which promote microstructures having special properties for elevated- temperature applications, corrosion resistance, and wear resistance. A classification of the main types of special high-alloy cast irons is shown in Fig. 3.
Fig 3 Main types of special high alloy cast irons


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Pinós è un comune spagnolo di 308 abitanti situato nella provincia di Lleida, nella comunità autonoma della Catalogna.

Altri progetti

Collegamenti esterni

Pinos

redpajama_set_name: RedPajamaWikipedia


This study is looking for people aged 50-80 with suspected sleep apnea and who are experiencing changes in their thinking skills but do not have dementia (referred to as Mild Cognitive Impairment).
The aim of this study is to examine if using CPAP for three months is associated with a slower rate of cognitive decline and/or beneficial effects in daytime functioning.
Patients will be offered assessments of their sleep (to confirm sleep apnea) and an evaluation of their thinking skills (to confirm mild cognitive impairment).


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Pentagon Unveils Secure Mobile Device Plan
Military releases a new plan to accelerate the adoption of mobile devices and apps for both classified and unclassified use
Dark Reading Staff
The Department of Defense on Tuesday released a plan to accelerate the adoption of commercial mobile devices and secure mobile applications in the military for use with both unclassified and classified information.
The plan, which follows up on a mobile device strategy released in June 2012, grows out of an increasing recognition by top military officials and in high-level military strategy documents that mobile technologies will play a key role on the battlefield and for broader U.S. military success via improved collaboration and information sharing.
"This is not simply about embracing the newest technology," DOD CIO Teri Takai said in a statement accompanying the plan. "It is about keeping the Department's workforce relevant in an era when information accessibility and cybersecurity play a critical role in mission success." Takai added that military personnel are increasingly reliant on mobile technology "as a key capability enabler for joint force combat operations."
Have a comment on this story? Please click "Discuss" below. If you'd like to contact Dark Reading's editors directly, send us a message.
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Franchise Fundamentals
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What is the Technology Fee and Why Should I Charge My Franchisees One?
By Carlie Smith on August 10, 2020
Businesses are increasingly defined by the technologies they use internally or that they offer to their customers; franchisors are no exception Technology is interwoven into the way that businesses think about themselves and the world. For example, Amazon famously declared itself first a technology company that "just happens to do retail." Developments in technology distinguish companies from their competition and open new growth opportunities.
Your franchise business likely depends of an array of systems to interact with customers, provide goods and services, and link franchisees to you and each other. Or, perhaps, those advancements are still aspirations for your system, and you want to leave the door open to introduce those technologies later.
Having the technology fee disclosed in your Franchise Disclosure Document ("FDD") and included in your Franchise Agreement provides you with the flexibility to implement technologies systemwide and have your franchisees help bear the cost.
Continue Reading What is the Technology Fee and Why Should I Charge My Franchisees One?
Franchise Disclosure Document ("FDD") Items 5, 6, and 7 Explained
By Carlie Smith on July 23, 2020
Items 5, 6, and 7 of a Franchise Disclosure Document ("FDD") are all about money – how much the franchisor charges for the goods and services it provides franchisees before the franchised business opens, how much the franchisee will pay to the franchisor throughout the business relationship, and how much the franchisee will need to invest to open the business. After reading Items 5, 6, 7, the franchisee must understand how much things cost, how much they'll be paying you, and when they will be making payments.
It is important for you to give accurate estimates to avoid litigation risks and help prospective franchisees evaluate their ability to successfully finance and open the business.…
Continue Reading Franchise Disclosure Document ("FDD") Items 5, 6, and 7 Explained
Trademark Registration 101
Your trademark is a critical asset in your franchise system. You work hard to cultivate the brand associated with the trademark and you carefully monitor how your franchisees and competitors use your trademarks. Registering your trademark with the U.S. Patent and Trademark Office gives you additional legal protections for this valuable intellectual property.
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How Non-Competition Agreements Protect Franchisors
By Ashley Nielsen, CFE & Carlie Smith on July 1, 2020
You have worked hard to grow your business and brand. The last thing you want to do is give it all away. A carefully drafted non-competition agreement can protect your brand and trade secrets.
Well-drafted, enforceable non-compete agreements include the following elements:
Narrow List of Prohibited Activities
Courts are increasingly focusing on balancing former franchisees'…
Leasing Issues in Franchising
By Jessica Elliott on July 1, 2020
For lease sign at industrial park. Focus on words.
A properly negotiated lease is critical to protecting your franchised business as well as the franchise network and brand. For franchisors, entering into a commercial lease agreement is an important step as the location out of which a business operates is critical to its success. Indeed, the adage "location, location, location" is much more than a cliché: Your business should be in a prime spot with heavy traffic and other quality (non-competing!) businesses nearby that attract patrons. Aside from location, there are other issues inherent in leasing, most notably, securing a lease that protects your ownership interest in your franchised business.
Franchisors often encounter these scenarios: changes in your business model, competition from nearby competitors, struggling franchisees, and a need to assign the lease to a new party. Here are a few key considerations in negotiating and executing a lease agreement that will help you address these situations.…
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What Is an FDD and Why Do I Need One?
By Ashley Nielsen, CFE on July 1, 2020
"FDD" is the commonly used acronym for "Franchise Disclosure Document." The purpose of an FDD is to provide important information to people who are interested in purchasing franchises.
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New NASAA FDD State Cover Pages for 2020
By Carlie Smith on January 1, 2020
When you update your FDD for 2020, the first few pages of your will look very different than they have in the past. NASAA has updated the state cover page requirements. NASAA updated the cover pages with the intention of better helping franchisees understand and use the FDD.
Below are summaries of the changes to the 2020 state cover pages. As you familiarize yourself with the changes, the new state cover pages may help you to more effectively and efficiently answer prospective franchisees' questions about the content of your FDD.
Continue Reading New NASAA FDD State Cover Pages for 2020


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Bryan County News
Bryan's Favorites
Bryan County's Anna Chafin to get emerging leader award
Richmond Hill Garden Club announces 2022 scholarship
Change to quarantine requirements for students in Bryan County Schools
Stavrev named Bryan County Schools spelling bee champ
Fort McAllister to host Rides on River
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Community announcements for Aprill 10
Magnolia Manor on the Coast is partnering with United Hospice to deliver the Five Wishes Living Will program at 6 p.m. Wednesday at 141 Timber Trail in Richmond Hill.
The program focuses on defining emotional, personal and spiritual needs in addition to medical wishes in the event one is unable to make them for themself.
A complimentary dinner will be served at 6 p.m. in the main dining room.
For more information, call Kelly Wood at 756-4300 ext. 102.
Immortal Six Hundred meeting set
The Immortal Six Hundred Camp of the Sons of Confederate Veterans will meet at 6:30 p.m. Thursday in the South Bryan Connection facility just behind the library at 9611 Ford Ave. Snacks and fellowship will begin at 6:30 p.m., and the meeting starts at 7 p.m. Admission is free, and the public is invited.
For more information, call William Hagin at 912-414-3850 or Al Perry at 912-585-9144.
Preschool open house
Richmond Hill Montessori Preschool will hold an open house from 10 a.m. to noon Saturday at the new facility at 2933 Highway 17. The public is invited to explore the new state-of-the-art school that includes a wing for every stage of a child's development as well as a 2,500-square-foot indoor playground and more.
Refreshments will be provided.
Free practice LSAT
Prospective law school students can take the LSAT practice test for free from Savannah Law School and Kaplan Test Prep from 10 a.m.-1 p.m. Saturday at SLS, 516 Drayton St. in Savannah. Attendees will take the mock test under test conditions.
To register, go to http://bit.ly/10kOeyq, email mkerns@savannahlawschool.org, or call 525-3913.
Crisis Center fundraiser
The UnMaskerade fundraiser is set for 6:30 p.m. Saturday at the Hoskins Center at 5000 Ranger St. in Savannah.
The event, which benefits the Rape Crisis Center, will feature comedian Roz McCoy and have a live and silent auction.
Costs are $100 per guest and $700 per eight-person table.
To RSVP, call 233-3000. For more information, go to rccsav.org or facebook.com/rccsav.
Gospel festival
Magnolia Manor on the Coast will host its second annual Gospel Music Festival by the Lake from 10 a.m.-2 p.m. Saturday at 141 Timber Trail in Richmond Hill
New Horizons, Maude and JC Thompson and Terry Brown will perform.
Admission is free. Visitors are encouraged to bring chairs and blankets. Hot dogs and drinks provided while they last. For more information, call Julie at 756-4300, ext. 101.
Asperger support
The Richmond Hill Asperger support group will meet at 7 p.m. April 16 in the community room of the Richmond Hill Public Library, 9607 Ford Ave. For more information, email rhaspergergroup@aol.com.
Fundraiser dinner
The August Birth Month of Bryan Missionary Baptist Church is sponsoring a fundraiser dinner from 11 a.m. to 7 p.m. April 19 and 20. Dinners are $10 and slabs of ribs are $20.
The menu includes barbecue ribs, barbecue chicken, fried fish, potato salad, backbone and rice, collard greens and cornbread.
For more information call Dolly Greene at 756-2412 or on the day of the dinner at 727-2163.
Dinners can be picked up in the church fellowship hall at 16525 Highway 144 East, Richmond Hill.
Theater group meeting
The Richmond Hill Community Theater will hold its annual meeting at 3 p.m. April 21 at 151 Brisbon Hall Drive in Richmond Hill. Election of officers and other business will take place.
The public is invited.
Those interested in being on the RHCT board can email Jacqueline Scott at jackizscott@gmail.com no later than April 18.
Canaan Missionary Baptist Church in Richmond Hill will celebrate its 100th anniversary at 7 nightly April 24-26.
Events on April 28 include Sunday school at 10:30 a.m. and Holy Communion at 11:30 a.m.
Bark Park fundraiser
A Bark Park wine and cheese fundraiser is set for 5 p.m. April 25 at Marker 107 on Kilkenny Road in South Bryan.
The event, which is raising money for a dog park in Bryan County, will include a range of fine wines, cheeses and hors d'oeuvres, as well as live music by Roger Widener and silent and live auctions.
Tickets are $35 in advance and $40 at the door.
Tickets can be purchased at the www.bryancountybarkpark.com and the following Richmond Hill businesses: the Richmond Hill-Bryan County Chamber of Commerce; PawParazzi; Ella's of Richmond Hill; and Awakening Yoga Studio.
Arts On The Coast Spring Show will be open from 10 a.m.-2 p.m. May 3-4 and noon-4 p.m. May 5 at the AOC Gallery, 2591 Highway 17, suite 101.
The event will feature paintings, mixed media and sculptures by local artists. Artists' reception will be 6 p.m.-9 p.m. May 4.
Have a fundraiser, group meeting, church announcement or other nonprofit events you'd like to have announced?
Email announcements and contact information to lwynn@bryancountynews.net or fax to 756-5907.


Inspiration: One teacher said "God is a good God and the devil is a bad devil." This helped me realize that God is love and doesn't torture us with bad things to discipline us. It is the devil who tempts us and if we give in to him, he becomes the tormentor and blames it all on God.
Inspiration: One Christian leader was dying of tuberculosis and although many were praying for him he got steadily worse. He had to stop his ministry and move in with his parents as he was getting weaker and weaker. As he was close to death, he said to himself "I am going to walk outside to a certain tree and praise God." He was so weak he could hardy walk, but he kept praising God and God's power started to heal him. It wasn't long before he was totally healed, all from praising God.
Inspiration: A student struggled with sexual thoughts even after he had received Jesus into his heart. It got him depressed and he questioned if he was really a child of God since he had so many impure thoughts. He thought that when you were "saved" you got a new mind. What he did not realize was that when you get saved, only your spirit is renewed. You don't get a new body nor a new mind at that time. This scripture helped him to understand that one's mind had to be renewed to God's ways which takes time. Studying the Bible and worshipping Jesus at home and at church helps one renew their mind to the mind of Christ.
Inspiration: A single person, desperate to get married, received this scripture and it gave him comfort to wait on the Lord and not rush into marriage. Waiting on the Lord helped this person to see that he had made the right choice.
Inspiration: A doctor felt God's call to leave his profession and go in a new direction he had received from the Lord in prayer. He had financial concerns on how he was to provide for his wife and children in this new calling. As he read this scripture, he was comforted. All he needed was to trust in God's provision for his wife and children.
Inspiration: Today's society and pressures make most people selfish. At College or University, the common expression in conversations is: "How is this going to benefit me?" Bumperstickers say "He who has the most toys when he dies, wins." I realized it is only by the saving grace of Jesus and renewing one's life to His ways, that one can escape the world of selfishness and enter into the Christian life of selflessness.
Inspiration: A fast food store worker shared his testimony one day. He said at age four, his parents divorced and he lived one year with his mother. His mother didn't want him and sent him to his Dad. His Dad didn't want him and sent him to his grandparents. At the age of seven, his grandparents gave up on him and he was moved from foster home to foster home. It was at Christmas time when he shared his story and I wept hearing he had no family that cared about him nor tried to keep in touch with him. The good news is that he has committed his life to Jesus and is in God's family. God sent him a friend to share Christmas with.
Inspiration: In the business world, I had to work with people who would curse and swear and afterwards I often had their swear words rolling around in my head. Although I was able to take authority over the spirit of profanity in my life, I felt I needed to have a talk with one particular colleague. I shared my thoughts in a respectful way and from that day on he stopped cursing Jesus' name. Later on he asked me more about my faith in Jesus.
Inspiration: A systems engineer had to stop looking at TV as it fueled lustful thoughts in him. Instead he used that time to study the Bible, to pray and to go to as many Christian teaching sessions as possible. He tried to walk in the Spirit as best he could. Being totally on fire for the Lord helped minimize the temptations of the devil.
Inspiration: A student had a vision of this scripture and how it would apply to King David. In the Bible, the enemy was trying to kill the Israelites and especially the King. This student pictured the enemy as having hundreds or even thousands of their best archers all shooting at King David, yet all these arrows could not kill him as God was his shield.
Inspiration: My prayer at my job was that I would be like Daniel in the Bible who had "God's excellence" on him. God blessed my work tremendously to the point where one year I was the top employee among seven different cities. God promoted me by blessing my work and letting me produce much for the company. Every year God blessed my work to the extend I was given free vacations in exotic resort places along with the other top performers from my firm. The top salesmen in the entire nation gave a speech at one of these trips and he said "I give all the glory to God". This blessed me since all the non Christians heard it.
Inspiration: I have seen many miracles right before my eyes. Healing miracles are awesome but salvation miracles are even greater. One day some people from our church went to a rough neighborhood in town to share Jesus and bring food to the poor. We would pray beforehand to ask God where to send us. A husky tattooed-man drinking beer came up to me on the street one day and started talking. Minutes later he started to cry, and I was able to lead him in prayer to Jesus. It was God's power that hit him. This showed me that witnessing becomes easier the more time one spends praying in the Holy Spirit before one goes out.
Inspiration: A Christian salesman worked for many years in a large firm. One day he had a meeting with his boss who wanted to evaluate his work. This Christian received an excellent evaluation and the boss used two words to describe this employee – integrity and sincerity. This Christian was blessed to hear this as he wanted his life to be a good example in the workplace.
Inspiration: A couple who have worked for the Lord these last 60 years spent time feeding the poor. The husband said it was very humbling to see how poor these people really were.
Inspiration: I have seen more than one family get greedy over an inheritance. This greed caused strife and division. My friend was caught in the middle of an inheritance fight. He prayed and sought the Lord's help. He worked hard to keep the family together and today they are getting along quite well.
Inspiration: One Bible teacher says this is one of the most important parables in scripture since so many people listen to the Word of God but can't tell you a week later what was said since the devil has stolen it from them. This teacher said to make notes during the service so that you will not forget. You must apply the Word of God before you see the harvest.
Inspiration: A Bible teacher said this is a vital scripture to help Christians in all areas especially with finances and healing. People need to pray constantly and have God's thoughts and His Word running through their minds and hearts so that they can rest on the solution and not get anxious about the problem. When you constantly quote the scripture solution for your problem and back up your belief with corresponding actions, then the Holy Spirit will bring to pass the scripture solution you are praying for and acting upon.
Inspiration: One lady in our church had her car stolen. She was so upset she was in tears and prayed to the Lord. After prayer, she felt a peace within her as if God was close to her. A few days later she got a call from the police who had found her car undamaged, and returned it to her.
Inspiration: A church leader taught me to pray over church meetings that people's lips would be sealed from speaking out against the will of God. This leader said that he had a trouble maker in his church, and when he prayed this way, he noticed the trouble maker remained silent in meetings.
Inspiration: One Bible teacher gave the best definition of grace that I had ever heard. He said today's language has narrowed that definition down to mercy or unmerited favour. However that is only part of it. He said that grace is God's power and ability to do in you what you can not do by yourself. This is why Paul emphasized in his writings in the Bible that with God's grace (His power and ability) Christians could accomplish things they could not do by themselves.
Inspiration: A couple with a tremendous healing ministry, have so much of the anointing of the Holy Spirit on them because of their prayer life. They want to know Jesus, understand His prospective, His priorities, His plan for their lives and how to minister to others. I recently heard the husband speak in a stadium of about 30,000 people. Jesus did miracles in that service and healed people. These miracles happened because these church leaders heard and obeyed the Holy Spirit's directions.
Inspiration: One family was struggling to keep its members close together since some of the relatives liked to quarrel causing hurt and division. This Bible scripture, along with the scriptures on love and forgiveness, helped the more mature family members act in love towards the family members that stir up strife.
Inspiration: A businessman says he needs to cast his cares upon the Lord constantly. His major care is his personal reputation and dignity, and he realizes that this causes him to be overly concerned about what other people think of him. He says he needs to die to his reputation and stop taking on so many cares and worries. He uses this scripture to help him to stop worrying.
Inspiration: I worked for a large corporation, and one of my team mates came up to me and said: "I want the peace you have in your life." He went on to say that the stresses of life got him down so much that he wanted to escape from it all. I was grateful that God let my light shine with His peace in the workplace.
Inspiration: When I read this scripture, I see that sin really hurts my relationship with Jesus. I used to see sin as just hurting me. Now I see that sin is direct rebellion against God's laws and that I need to teach myself to hate sinning.
Inspiration: During my teenage years, I would have one foot with Jesus and one foot with the people-pleasing crowd. I was afraid to leave the people pleasers because I was too concerned about what they thought of me rather than what God thought of me. When I committed my life to Jesus and asked for the baptism of the Holy Spirit, God gave me the courage to jump in with both feet into His camp and to trust Him with my life. I was no longer a people pleaser but a God pleaser.
Inspiration: In the 1980's, when a well known evangelist sinned, Christian Television got a bad rap from the public. Christians themselves were quick to judge, criticize and point fingers at the sin instead of praying for the situation. A Bible teacher told us that immature Christians do not realize that when you harshly judge another for their sin, you are judged in the same manner. The mature Christians help restore those who have fallen.
Inspiration: I have met two Christian women who have used their God given beauty as a gift from the Lord. In their younger years, these women competed in beauty pageants. One went on to become a church leader's wife and the other does Bible teaching in her church.
Inspiration: An accounts manager was carrying the burden of his career reputation for years. This burden would often give him anxiety and fear. When he gave all of this burden to the Lord, he felt a weight lift off his shoulders.
Inspiration: An evangelist would have his team pray for a long time before they went out to share Jesus and pray for the sick. They would ask God which areas of the city they should to go to, even if it meant a rough area of town. They would pray this scripture for God's protection and God always protected them.
Inspiration: The president of an organization did a Bible study on "Who we are in Christ." This president learned through his study that Christians are: children of God, redeemed, saved, sanctified, justified, forgiven, loved and blessed tremendously. The blessings include, health, the ability to gain wealth for His purposes and most importantly, eternal life. He says we need to meditate on these scriptures to understand more of God's spiritual blessings.
Inspiration: A Bible teacher addressed a group of Christians by asking: "How many of you are hot and on-fire for God?" None of the audience put their hand up. He then asked them: "How many of you are cold?" None of them put up their hand. The teacher went on to read this Bible scripture and all were convicted of their luke warm state.
Inspiration: A computer programmer prays this scripture to help keep his thoughts pure. The enemy tries to tempt this person with thoughts of lust; however, he rebukes those thoughts and focuses on the Word of God.
Inspiration: Some close friends made a list of attitudes to work on before they got married. They had excellent marriage counseling and that helped them control the anger, frustration and irritations that pop up in marriage. They made a point of never going to bed at night angry. Their marriage is so strong now that people come to them for marriage counseling.
Inspiration: I took a course on the roots of anger. The speaker explained that so much of anger is developed in the childhood years through various circumstances. The course taught me that many people carry hurts for years and when these hurts flair up, they get so angry that they cannot control their anger nor their tongue.
Inspiration: As Bible College students, we were taught to quote chapter and verse when we teach others as the Holy Spirit speaks to people through the Bible. By teaching this way, God's Word would go forth with power and accomplish great things.
Inspiration: We would often go out two by two into the streets and neighborhoods to share Jesus. Most of the time we shared with people in their homes. One afternoon I came across about 10 tough guys. Fear and intimidation tried to get me to walk away and be quiet. However I took courage and shared my testimony before them all. I was amazed to find they listened closely and let me pray for them.
Inspiration: A worship leader and his wife were unable to have children. A friend of theirs felt led by the Lord to build a wooden crib for a baby, asking the Lord to fill the crib for this barren couple. Intellectually, it seemed strange to give the gift of a crib at a time when the couple was unable to have a baby. However God honoured their faith and in time, the wife became pregnant and had a baby so that this "Faith Crib" was filled.


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Jenzack Partners, LLC v. Stoneridge Associates, LLC
JENZACK PARTNERS, LLC
STONERIDGE ASSOCIATES, LLC, ET AL.
Argued February 14, 2018
Action seeking, inter alia, to foreclose a mortgage on certain real property owned by the defendant Jennifer Tine et al., and for other relief, brought to the Superior Court in the judicial district of Middlesex, where the named defendant et al. were defaulted for failure to appear; thereafter, the action was withdrawn as to the defendant Joseph Tine; subsequently, the matter was tried to the court, Domnarski, J.; judgment for the plaintiff and of strict foreclosure, from which the defendant Jennifer Tine appealed to this court; thereafter, the court, Domnarski, J., granted the plaintiff's motion for attorney's fees, and the defendant Jennifer Tine filed an amended appeal. Reversed in part; new trial.
Richard P. Weinstein, with whom, on the brief, was Sarah Black Lingenheld, for the appellant (defendant Jennifer Tine).
Houston P. Lowry, with whom, on the brief, was Dale M. Clayton, for the appellee (plaintiff).
DiPentima, C. J., and Lavine and Eveleigh, Js.
EVELEIGH, J.
The defendant Jennifer Tine[1] appeals from the judgment of strict foreclosure rendered by the trial court in favor of the plaintiff, Jenzack Partners, LLC. On appeal, the defendant claims that the trial court improperly: (1) held that Sovereign Bank had assigned the defendant's guarantee to the plaintiff and the plaintiff had standing to foreclose on the mortgage; (2) determined that the plaintiff had established the amount of debt due on the subject note; and (3) granted attorney's fees and costs to the plaintiff. We agree with the defendant's second claim and, accordingly, we reverse the judgment of the trial court only as to Jennifer Tine.
The following facts and procedural history are relevant to our resolution of the issues on appeal. On July 13, 2006, the named defendant, Stoneridge Associates, LLC (Stoneridge), obtained a construction loan in the amount of $1, 650, 000 from a nonparty, Sovereign Bank (Sovereign). At that time, Stoneridge executed a promissory note (Stoneridge note) evidencing its promise to repay the loan. The note was secured by various personal guarantees; Premier, Gattinella, Snow and Joseph Tine each executed guarantees in favor of Sovereign guaranteeing repayment of the sums due under the note. See footnote 1 of this opinion. On December 23, 2008, the Stoneridge note was modified via a modification agreement. On the same date, the defendant executed a limited guarantee in favor of Sovereign guaranteeing repayment of the sum due under the Stoneridge note as modified. In order to secure their respective guarantees, the defendant and Joseph Tine executed a mortgage (Tine mortgage) in favor of Sovereign on their residential property located at 8 Black Birch Drive in Cromwell.[2] The defendant's nonrecourse guarantee limited her liability solely to her interest in the Cromwell property. On August 27, 2009, and May 6, 2010, the defendant executed reaffirmations of her guarantee in connection with subsequent modifications of the Stoneridge note.
On March 22, 2012, Sovereign assigned its mortgage and interests in the Stoneridge note to the plaintiff.[3]In August, 2012, the plaintiff commenced this action, seeking, inter alia, to foreclose on the Tine mortgage. In the operative revised complaint dated April 2, 2013, the plaintiff alleged that, because Stoneridge had defaulted on the underlying Stoneridge note, the plaintiff was entitled to declare the entire balance of the note due and payable. The plaintiff alleged that Sovereign had assigned all of its interests in the Stoneridge note, including continuing guarantees executed by Premier, Gattinella, Snow and Joseph Tine, the limited guarantee executed by the defendant, and the Tine mortgage.[4] Because the plaintiff was the current holder of the Stoneridge note, the plaintiff claimed it was entitled collect on all underlying guarantees and foreclose on the mortgage.
On April 26, 2013, the defendant filed an answer that denied the substance of the complaint and asserted as special defenses lack of consideration, unclean hands, and equitable estoppel. A bench trial was held on August 16, 2016. At trial, the plaintiff claimed that the assignment of the Stoneridge note necessarily carried with it an assignment of all underlying guarantees, including the defendant's limited guarantee secured by the Tine mortgage. The plaintiff also introduced into evidence exhibit 22, a computation of the current amount due on the note. In response, the defendant claimed that the court lacked subject matter jurisdiction to render a judgment of foreclosure against her because her guarantee was not specifically assigned to the plaintiff in the allonge. The defendant also claimed that the plaintiff failed to establish the amount of debt due on the note because evidence of the computation of debt, which included a starting balance provided to the plaintiff by Sovereign, was inadmissible hearsay. Following the trial, both parties filed posttrial briefs. On December 1, 2016, the trial court issued a memorandum of decision entering an order of strict foreclosure on the Tine mortgage. The court held that the plaintiff had standing to foreclose the mortgage that secured the defendant's guarantee and that the plaintiff had established the amount of debt due on the note through the testimony of William Buland, the plaintiff's authorized representative, and the computation of debt in exhibit 22. This appeal followed. Additional facts will be set forth as necessary.
On appeal, the defendant argues that the trial court improperly (1) held that the plaintiff had standing to foreclose on the Tine mortgage; (2) determined that the plaintiff's exhibit 22 was sufficient to establish the amount due on the subject note; and (3) awarded the plaintiff attorney's fees and expenses. Although we agree with the defendant's second claim and, accordingly, reverse the trial court's judgment and remand the case for a new trial, we address both the defendant's first claim, which pertains to subject matter jurisdiction, and her third claim as an issue likely to arise on remand.
The defendant's first claim is that the court improperly found that the plaintiff had standing to bring an action to foreclose on the Tine mortgage. She argues that the plaintiff lacked standing because her limited guarantee was not specifically assigned from Sovereign to the plaintiff in the allonge. In response, the plaintiff argues that the court properly found that it had standing to foreclose the Tine mortgage because the assignment of the Stoneridge note operated as an assignment of the underlying guarantees securing it. We agree that the plaintiff has standing.
We set forth our standard of review and applicable legal principles. ''The issue of standing implicates the trial court's subject matter jurisdiction and therefore presents a threshold issue for our determination.'' (Internal quotation marks omitted.) D'Amato Investments, LLC v. Sutton, 117 Conn.App. 418, 421, 978 A.2d 1135 (2009). ''Standing is the legal right to set judicial machinery in motion. One cannot rightfully invoke the jurisdiction of the court unless he [or she] has, in an individual or representative capacity, some real interest in the cause of action, or a legal or equitable right, title or interest in the subject matter of the controversy. . . . When standing is put in issue, the question is whether the person whose standing is challenged is a proper party to request an adjudication of the issue . . . . Because standing implicates the court's subject matter jurisdiction, the plaintiff ultimately bears the burden of establishing standing. . . . Because a determination regarding the trial court's subject matter jurisdiction raises a question of law, [the standard of] review is plenary.'' (Internal quotation marks omitted.) Valley National Bank v. Marcano, 174 Conn.App. 206, 210-11, 166 A.3d 80 (2017).
         ''A guarantee, similar to a suretyship, is a contract, in which a party, sometimes referred to as a secondary obligor, contracts to fulfill an obligation upon the default of the principal obligor.'' (Internal quotation marks omitted.) One Country, LLC v.Johnson, 137 Conn.App. 810, 816, 49 A.3d 1030 (2012), aff'd, 314 Conn. 288, 101 A.3d 933 (2014). Our Supreme Court has recognized the general principle that ''a guarantee agreement is a separate and distinct obligation from that of the note or other obligation.'' JP Morgan Chase Bank, N.A. v.Winthrop Properties, LLC, 312 Conn. 662, 675, 94 A.3d 622 (2014). As our Supreme Court stated, ''a guarantor's liability does not arise from the debt or other obligation secured by the mortgage; rather, it flows from the separate and distinct obligation incurred under the guarantee ...


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text:
Robb: Is Maricopa County turning blue?
Robert Robb: Maricopa County was less in favor of Trump and more in favor of legalizing weed than the rest of the state. That's different.
Robb: Is Maricopa County turning blue? Robert Robb: Maricopa County was less in favor of Trump and more in favor of legalizing weed than the rest of the state. That's different. Check out this story on azcentral.com: http://azc.cc/2gcU7NW
Robert Robb
Robert Robb, The Republic | azcentral.com Published 6:01 a.m. MT Nov. 21, 2016
Democrats narrowed the registration disadvantage and won some seats. But is it the start of a new trend? (Photo: Michael Chow, Michael Chow/The Republic)
Democrats had a pretty good election in Maricopa County. There are at least some indications they might have turned the corner on being more frequently competitive here.
Since the 2014 election, Democrats reduced their registration disadvantage to Republicans in the county by nearly 30,000 voters.
Kyrsten Sinema has turned what should be a perennially contested congressional district in the central part of the metro area into a reliably Democratic seat, at least as long as she occupies it. Democrats outnumber Republicans in the district by just 2 percentage points, a difference easily made up by the GOP advantage in actual turnout. Yet the GOP only fielded token opposition to Sinema, who garnered 61 percent of the vote.
Democrats won three legislative seats in the county in districts in which Republicans actually have the registration advantage.
And, of course, Democrats captured two of the county offices up for grabs, defeating Republican incumbents Joe Arpaio for sheriff and Helen Purcell for recorder.
Democrats could do well in some races
Arpaio and Purcell were obviously highly damaged candidates, and were ultimately done in by independents and disaffected Republicans. Arpaio's Democratic opponent, Paul Penzone, received 158,000 more votes in Maricopa County than did Hillary Clinton. That wasn't because of Democratic ticket-splitters.
A better assessment of the baseline standing of the two parties comes from the race for county school superintendent. Neither of the major party candidates were incumbents. Neither side mounted much of a campaign, so the results reflect instinctive party identification, including the default position of independents.
The Republican, Steve Watson, received 51.4 percent of the vote. The Democrat, Michelle Robertson, received 48.6 percent.
That's a difference of less than 3 percentage points. That's still a substantial GOP advantage. But one narrow enough that, with money and issues, a Democrat can make a game of it.
By way of contrast, in 2012 Democrats didn't even bother to field a candidate for most county offices.
County used to vote more conservatively
In past elections, Maricopa County has voted more conservatively and Republican than the rest of the state.
For example, Mitt Romney won Maricopa County by nearly 11 percentage points in 2012. His margin in the rest of the state was less than 7 percentage points.
However, in this election, Maricopa County was actually less conservative and Republican in some key races than the balance of the state.
Donald Trump took Maricopa County by just 3 percentage points, 49 percent to 46 percent. He won the rest of the state by 5 percentage points.
Proposition 205, the legalization of recreational marijuana, narrowly lost in Maricopa County, 49.2 percent in favor and 50.8 percent opposed. It did somewhat worse in the balance of the state, where 47.3 percent were in favor and 52.7 percent were opposed -- even though legalization actually carried in two of the more populous of the other 14 counties, Pima and Coconino.
ROBB: Best campaign of 2016? No on Prop. 205
So, Maricopa County was less in favor of Trump and more in favor of legalizing weed than the rest of the state. That's different.
A trend? Not yet, but keep an eye on it
Now, I don't want to make too much of this. As I've written, the biggest recent political story in Arizona hasn't really been the rise of independents but the disappearance of the Democratic Party.
Democrats haven't won a statewide election since 2008. In 2014, they fielded perhaps the most impressive slate of candidates for state offices in Arizona's history. And, except for David Garcia in the state superintendent race, they all got smoked. And even Garcia lost narrowly to Republican Diane Douglas, who seemed totally lost on the campaign trail.
VALDEZ: How did Arizona Democrats wind up on life support?
The Republican registration advantage in the county, nearly 150,000 voters, remains daunting. And there were some counterexamples in 2016.
John McCain won Maricopa County by even more than he won the balance of the state, a return to the historical norm. But, then again, McCain ran a superb campaign and his Democratic opponent, Ann Kirkpatrick, ran a stinky one. In a big-dollar race, that might get amplified in the state's major advertising market.
So, too early to call the Democrats' improved fortunes in Maricopa County a trend. This was a weird election year.
But it is a development worth noting. And worth watching, particularly to see if Democrats continue to narrow the registration disadvantage leading into the 2018 election.
Reach Robb at robert.robb@arizonarepublic.com.
Read or Share this story: http://azc.cc/2gcU7NW
Cattle grazing on Arizona trust land isn't just about the money
If Ted Cruz and Alexandria Ocasio-Cortez found common ground, why can't others?


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Burgertime World Tour (XBOX 360) Review
Adam Chapman | Dec 12, 2011
Having grown up a fan of the original Burgertime game for NES, I was understandably excited earlier when it was announced that a newly updated, HD graphics version of the game would be released later in the year. When it finally was available for purchase online, I jumped at the opportunity, excited to play an updated version of what my inner child remembers and considers a classic. Unfortunately, Burgertime: World Tour isn't a complete success, and one of the more anticipated games ends up being much more than simply a letdown.
To say that the original game was light on story would be far too kind, but when it was first created story wasn't necessary if the gameplay was enjoyable. This new version of the game tries to give the game a story concept, and I appreciate the attempt despite it being unneeded. You're a caricature of an Italian-looking Chef, who must combat other Chefs from different countries, including their unique ingredients. You travel across four different "worlds" with a total of 50 levels to complete, including some difficult boss battles. The gameplay is enjoyable, as it manages to carry over the basic concepts from the original game quite smoothly. As giant ingredients try to kill you, you must jump around them or pepper-spray your way through them so that you can run over burgers, cheese, lettuce and buns to create the required amount of hamburgers for the level. Jumping is a big addition for the game, as it wasn't an option in the original game, leading to sad deaths which seemed to happen in slow motion as you realized you were out of pepper-spray and watched an enemy hot dog slowly kill you as you stood helplessly before it.
The game isn't that hard to beat, as to progress to the last level you simply have to finish each level regardless of how many lives or how much time it took to complete. But the game has replay value, with challenging trophies/achievements to complete, ranging from earning five stars for each of the 50 levels, or finishing each of the 50 levels without losing a life (not in a row, though, as each playthrough of a level if counted separately).
The graphics are sharp and crisp, and whereas the original NES game featured a black screen with a grid in the middle that you ran around on, this new game boasts bright colours and a generally fun visual sense of style. However, all of the colours and characters on the screen can prove to a bit busy at times, as an enemy ketchup spray starts to meld into the background, making it harder to focus on it and avoid it (yep, this is definitely an odd game to describe without visuals).
With all of this fun gameplay, bright colours and good graphics, what's my major issue with this game, you might ask? The lack of a good multiplayer mode is this game's biggest problem, especially after the original marketing and presentation earlier this year. The multiplayer mode is included, but it doesn't feel very well thought-out or designed, as instead of having a face-off mode on separate grids, you fight against your opponent with only one burger between the two of you, making it less enjoyable as a competition, as well as unnecessarily complicated. The scoring issue doesn't improve the situation, as it's possible to wait at the bottom of the grid for an opponent to finally get the top bun to the bottom level of the grid, and just run over it and get more points for finishing the burger than those the other player garnered for making it all possible in the first place.
The first-player mode is enjoyable, competitive, and has a variety of difficult challenges to keep the player invested and interested in playing the game further. If only the multiplayer could have been better put together, because as it stands it simply isn't as much fun as it could have been with just some simple tweaks. That being said, when I hear the start-up music, which sounds very similar to the original Burgertime theme music, my inner child gets giddy with excitement.
Unfortunately, Burgertime: World Tour isn't a complete success, and one of the more anticipated games ends up being much more than simply a letdown.
↠ Candleman Review
↠ Shovel Knight: Specter of Torment Switch Review
↠ Disney Universe (XBOX 360) Review
↠ Ever Oasis Review
↠ Digimon All-Star Rumble (PS3) Review
File Under: Arcade, Indie Game, Microsoft, Platformer, Xbox
Name: Burgertime World Tour Review Score: 7
Xbox 360 , PlayStation 3 , Nintendo Wii
Puzzle , Platformer
E (Everyone)