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Will Plan
Bequest of Property, Louisiana Inheritance, Louisiana Trust, Property in Trust, Specific Bequests, Will Plan
Louisiana Trust Code Rules Regarding Shifting a Trust Beneficiary's Interest in Principal
Many people who put their estate plan in place do not understand the rules regarding the shifting of a trust beneficiary's interest in principal.
Occasionally, people who are putting their estate legal program in order want to make a bequest, in trust, for others - often grandchildren. Since the grandchildren are often young and immature, the grandparents often want to put stipulations on the bequest.
A common request goes something like, "I want to leave $100,000 to my grandchild when I die, but I want it to be in a trust. And if my grandchild doesn't go to college, or does drugs, or goes to jail, then that money will go back to other people I designate."
Well, you can certainly leave $100,000 in trust for another, but there are restrictions on your ability to shift that trust principal to someone else. One such restriction in the Louisiana Trust Code provides that the interest of a principal beneficiary is acquired immediately upon the creation of the trust. Once the grandparent passes away, the trust for the grandchild is created and that trust is for the grandchild only while the grandchild is alive.
What you CAN control is when the grandchild gets the principal. You could give the trustee the discretion regarding distributions of principal to the grandchild. So if the grandchild goes to jail, the trustee could exercise his or her discretion and perhaps never distribute the principal to the grandchild while the grandchild is alive.
Other controls you have include certain powers to direct principal when the grandchild dies. if the grandchild dies with descendants, you can state in the trust that the principal vests in one or more of his descendants. If the grandchild dies without descendants, you can direct who the principal vests in upon the grandchild's death.
And if you do not direct where the principal vests upon the beneficiary's death, then his interest vests in his heirs or legatees, subject to the terms of the trust.
In other words, get good legal help when you are leave a bequest, either through your last will and testament or your revocable living trust, to individuals (such as grandchildren) who you are unsure how they will turn out from a maturity standpoint. Failing to comply with the rules regarding the shifting of a beneficiary's interest in principal can cause all kinds of legal problems for your descendants in the future.
This post is for informational purposes only and does not provide legal advice. Please do not act or refrain from acting based on anything you read on this site. Using this site or communicating with Rabalais Estate Planning, LLC, through this site does not form an attorney/client relationship.
Louisiana Estate Planning Attorney
www.RabalaisEstatePlanning.com
Tagged: shifting interest in principal, trust vesting, trust beneficiary dies, who gets trust when beneficiary dies, louisiana trust beneficiary, Louisiana bequest to trust, Baton Rouge estate planning lawyer, Baton Rouge trust attorney
Independent Executor, Independent Administrator, Louisiana Probate, Louisiana Succession, Succession, Will Plan
Why You Don't Need a Death Certificate to Begin the Louisiana Succession
Here's the typical situation: Survivors of the deceased wait to schedule something with the estate attorney until after the family receives the death certifcates - which always takes either weeks or months to come in. Finally, they sit down with the estate attorney, like myself, and say something like, "Well, before we get started, let me give you a death certificate because I know you will be needing this. Do you want an original or copy?"
Then, I respond to their dismay, "I don't need one."
Death certificates are not typically filed at the courthouse as part of the Louisiana Succession process. While the judge needs proof that the deceased actually died, along with information about whether they were married, where they lived, when the deceased died, and whether they had children, the judge does not need to see a death certificate. These facts are typically evidenced, or proven, by affidavits.
Typically, instead of filing death certificates at the courthouse, two people who have knowledge of the above mentioned facts each sign what is commonly referred to as an, "Affidavit of Death, Domicile, and Heirship."
The statement we often hear from survivors that "It won't do any good to see the attorney because we don't have death certificates yet," is inaccurate. Waiting weeks or months to get the death certificates is unnecessary waiting.
What do you need to get started on the Louisiana Probate (also known as "Succession")? You need the original Will, if one exists, and you need two people familiar with the family circumstances (such as a surviving spouse or adult children) to sign the appropriate Affidavits of Death, Domicile, and Heirship."
In addition, if you can compile a list of assets and debts of the deceased as of the date of death, that would be helpful, but this detailed information typically is needed later, not at the very beginning.
The family WILL need death certificates to, for example, have the executor open an estate account after the judge confirms the executor (or appoints an administrator). And after the judge signs the final Judgment of Possession, which orders third parties to transfer assets to heirs, the heirs will need a death certificate, with this Judgment, before the financial institution will release the funds or investments to the heirs listed in this Judgment.
Since delays are one of the main complaints about probate, it makes sense to meet with the attorney and get started on this process as soon as practical after the death of a loved one, rather than delaying until you receive death certificates, which can take weeks or months to arrive.
Tagged: Death certificate and Succession, Death certificate and probate, death certificate and Louisiana Succession, Does estate attorney need death certificate, who needs death certificate, original or copy of death certificate, Louisiana death certificate
Louisiana Inheritance, Louisiana Succession, Will Plan
Will Prepared Through Suze Orman Kit Invalid in Louisiana
I was contacted recently after a father passed away. The adult children were hoping to get their father's estate settled quickly and easily. They mentioned that their father had been diagnosed with pancreatic cancer, that the diagnosis allowed only a short time to live, so he did a "quickie" Suze Orman will to specify how he wanted to leave his estate.
When I heard about the Will, I told myself I needed to see it. The son told me that the Will was three pages long. I said, "Hang up. Take a picture of each page and text them to me." He did.
Whenever I review a Will for the first time, I always look for two things. First, I confirm that the Will meets the validity requirements for a last will and testament. And second, I look at the actual words and terms used in the Will for bequests, appointments, and other ancillary provisions.
In general, it's pretty easy to make a valid will. But the trickery comes in using all of the right terms in all of the right places.
In this matter though, it took me about three seconds to determine that the Will was invalid.
In Louisiana, there are two types of Wills: olographic and notarial. The olographic will is entirely handwritten. This will was typed. The notarial testament is typically typed, but must be signed "at the end of the testament and on each other separate page." Of the three pages, only one was signed.
In addition, to be a valid notarial testament, the notary and two witnesses must sign a certain declaration that is inserted at the end of the testament. In this Will, there was no notary signature, just the signatures of two witnesses.
So, in about three seconds. I discovered two reasons that this Will is invalid. And yet, there was a third problem. For a notarial testament to be valid, the notary and witnesses must sign a declaration that is worded as described in our Louisiana statute. The declaration in the Will must be at least "substantially similar" to the declaration provided in the Louisiana statute. The declaration at the end of this purported Will was not substantially similar to the declaration provided by Louisiana law.
Since the Will was invalid, it didn't make sense to even look at the terms of the purported Will, since they would have no legal effect - at all. It's unfortunate that this man's final wishes to leave his legacy a certain way would not be followed. Instead, state law will determine who inherits his estate.
The moral of this story is that you should be careful about using the "do-it-yourself" estate planning tools that are out there. Many things can and do go wrong when you attempt to take shortcuts in the estate process.
Tagged: Suze Orman Will kit, Suze Orman living trust, Suze orman valid in Louisiana, Is Suze Orman will valid in Louisiana, estate planning baton rouge, estate planning attorney Baton Rouge
Two Types of Louisiana Last Wills: Part Two - The Notarial Testament
In the other post to this two-part series, we discussed the ins and outs of the olographic testament in Louisiana. In this post we address the more common type of testament: the notarial testament.
Mainly since the olographic testament has the requirement that it be written entirely in the hand of the testator, notarial testaments are more common. Notarial testaments are generally type written and computer generated, typically by an attorney.
There are strict formality requirements that must be met for a notarial testament to be deemed valid by a judge in the proper state court. All notarial testaments must be in writing and dated. And the following requirements must be met when the testator knows how to sign his name and to read and is physically able to do both:
(1) In the presence of a notary and two competent witnesses, the testator shall declare or signify to them that the instrument is his testament and shall sign his name at the end of the testament and on each other separate page.
(2) In the presence of the testator and each other, the notary and witness shall sign the following declaration, or one substantially similar: "In our presence the testator has declared or signified that this instrument is his testament and has signed it at the end and on each other separate page, and in the presence of the testator and each other we have hereunto subscribed our names this __ day of _________, ____.
Note that there are many court cases where judges have been forced to decide whether the formality requirements of a notarial testament have been met.
Note also that there are other notarial testament requirements for circumstances where: a testator is literate and sighted but physically unable to sign; the testator does not know how to read, or is physically impaired to the extent he cannot read; the testator knows how to and is physically able to read braille; or for a person who has been legally declared physically deaf or deaf and blind and who is able to read sign language, braille, or visual English.
Because notarial testaments are generally prepared by lawyers trained in the intricacies of estate planning, and can use their experiences to serve their clients, notarial testaments are generally more thorough than the customary olographic testament prepared often by a do-it-yourselfer.
Provisions in notarial testaments typically appoint executors, authorize the independent administration, waive bond requirements for executors, trustees and usufructuaries, leave assets in a testamentary trust for minors, irresponsible heirs, heirs receiving certain government benefits, and to keep property in the bloodlines for more than one generation.
In Louisiana, some notarial testaments bequeath usufruct to a surviving spouse and name naked owners who are entitled to ownership of assets at the termination of the usufruct.
In addition, most notarial testaments address reasonable contingencies, such as what happens if one or more of the executors or heirs predecease the testator.
Tagged: Louisiana olographic will, handwritten will in louisiana, is handwritten will valid in louisiana, is olographic will valid, how to write your own will in louisiana
Bequest of Property, Louisiana Succession, Will Plan
Two Types of Louisiana Last Wills: Part One - The Olographic Testament
In Louisiana, there are only two forms of valid Wills (known by our Louisiana law as "testaments." The two forms are: olographic and notarial. This post addresses the less popular olographic (some people refer to it as an "holographic" Will).
When we discuss whether a handwritten Will is valid, we must look to the terms of the Louisiana statute that defines and olographic testament. Note that there are many, many court cases where lawyers have argued, and judges have determined, whether someone's handwritten attempt at a Will is valid, and if so, how it should be interpreted.
Nonetheless, our Louisiana law states that "An olographic testament is one entirely written, dated, and signed in the handwriting of the testator." The statute goes on to state, in part, what it means to be dated and signed, including the fact that writings after the signature do not make the testament invalid and such writing may be considered by the court, in its discretion, as part of the testament.
Many people think that if they just meet the validity requirements of an olographic testament, then everything will go hunky-dory when they pass away. But those people should think again.
It's easy to make a valid olographic testament, but problems often surface after the death of the testator because the wording was either insufficient, ambiguous, errors were made, reasonable contingencies were not addressed, or bequests were made outright to people when they should not have due to age or financial immaturity.
The bottom line on Louisiana olographic Wills is that it is possible, if not simple, to write your own Will that would be recognized by a Louisiana court as a valid Will. However, if the reason you attempted to write your own Will was to save some costs today, know that the future costs to your estate and your heirs (both financial and emotional costs) will far outweigh any savings you felt you realized by making your own olographic testament.
Tagged: Baton Rouge estate planning attorney, Lafayette estate planning lawyer, Louisiana wills and trusts lawyer, New Orleans estate planning, handwritten will, are handwritten wills valid, holographic will louisiana, olographic will valid in louisiana, problems with olographic wills, can you make your own will
Louisiana Succession, Louisiana Probate, Will Plan
What Legal Matters to Address When Loved One Dies Unexpectedly
This post describes what estate legal issues typically get addressed after the unexpected death of a loved one.
Many people pass away after a long life due to natural causes, or they pass away after a prolonged illness. The death does not come as a shock or surprise to survivors, and the legal affairs are often in order with trusted loved ones having access to all of the estate information.
However, sometimes death comes completely unexpected, perhaps due to a medical issue (for example, a heart attack) or due to some type of accident. When this happens, questions often instantly arise among the survivors. Questions like:
Did he have his legal affairs in order?
Did she have a will or a trust?
How do we cover funeral expenses?
What did the deceased own and owe?
How will income taxes be handled?
What happens to all personal effects?
How do we deal with the deceased's business?
How do the monthly bills keep getting paid?
Who is responsible for dealing with all of this?
All of these questions that survivors have often lead to a statement, "We need to talk to an estate lawyer."
Perhaps the best reason to talk to an estate settlement lawyer sooner rather than later is because there is so much uncertainty that can be eliminated by talking to an estate attorney that can quickly map out a suggested plan of action to deal with the various estate issues involved.
If you are in this circumstance, make sure you quickly locate the last will and testament or trust of the deceased - the last will needs to be filed at the courthouse.
Although every estate settlement is unique, it often helps when all of the "parties" gather together for a meeting with the estate attorney. The "parties" will include the executor that is named in a will, along with all of the people who will inherit from the deceased.
These parties often have questions and they may be nervous that estate issues will be handled improperly. However, when all of the parties get together with an estate attorney who can lay out a plan for getting all matters addressed, the parties often start gaining peace of mind. When the parties know that communication will flow freely, and there will be transparency throughout the estate settlement process, heirs start to let their guard down because they know that their rights are going to be preserved. It's usually the failure to communicate, and the uncertainty from the failure to communicate, the causes heirs to lose trust in one another, and then relationships get damaged - often permanently.
Even though every estate settlement is different, most start with the family producing the last will and testament, and then the estate attorney prepares and files the necessary court pleading at the courthouse, to get the executor "confirmed." If no last will and testament exists, then the court will often appoint an "administrator" to handle the things that an executor would have handled if an executor was named in a will.
Once the executor is confirmed by a judge, or an administrator appointed by a judge, then that personal representative can gain access to information from third parties regarding estate details, and the personal representative can open an estate account and get access to the deceased's previously frozen accounts.
From there, a good estate attorney will develop a good short and long term plan for dealing with the various estate issues, and few surprises will surface during the process because a good estate settlement plan was created from the get-go.
Tagged: Unexpected death
Bequest of Percentages, Bequest of Property, Louisiana Probate, Will Plan
Don't Handwrite Changes on Your Last Will and Testament
I've seen many people over the years want to make changes to their existing last will and testament. Without knowing any better, they pull out their existing will, grab pen or pencil, and cross through the things they want to change while writing in replacement provisions.
For example, someone may want to change their executor. They feel that the previous executor they named (let's call him "Joe") is now a bum, and they want to replace Joe with Fred.
Or, let's say a Will provides a specific bequest either to an individual or charity of $100,000. But the testator now wants to change that bequest to $5,000.
There are a couple of Louisiana laws that are in play here. First, Louisiana law provides, in pertinent part, that a revocation of a testamentary provision occurs when the testator clearly revokes the provision or legacy by a signed writing on the testament itself.
So, the Louisiana rules are somewhat relaxed to permit the revocation of a provision in a last will by a signed writing that is not dated but which clearly revokes the provision.
However, regarding a replacement provision, the formalities are more stringent. Louisiana law provides that, "Any other modification of a testament must be in one of the forms prescribed for testaments.
Example: A woman pulls out her old will naming Joe as the executor. She scratches through Joe's name, writes in Fred's name, and signs the change. The result would be that Joe is no longer the executor because she revoked the provision by a signed writing, but Fred will not be the executor, because this modification is not in one of the forms prescribed for testaments - it does not meet the formality requirements of an olographic testament because it is not dated.
Be very careful when you attempt to change your Will. Your safest bet is to work with an attorney who understands the rules as they relate to revocations and modifications of testaments.
Tagged: Change Last Will and Testament, Write on Will, Handwritten Will, Louisiana estate law, Louisiana estate attorney, Rabalais Estate Planning
Will Plan, Usufruct
Do Mom's Heirs Get Money When Dad (With Lifetime Usufruct) Sells Home?
We get this question often. Here's the situation. Mom dies with a last will and testament leaving Dad the lifetime usufruct of her estate, and naming her children as the naked owners. Dad then decides to sell the family home. Do Mom's kids get any of the money from the sale?
No. They don't. Dad's usufruct will continue over the proceeds of the sale. Mom's kids may have to sign to allow the sale to take place, but they are not entitled to any sale proceeds.
Tagged: Louisiana usufruct, Usufructuary Sells Home
Usufruct, Will Plan
When Bequeathing Usufruct, Consider Leaving Naked Ownership in Trust
Across America, people typically leave their estates to their survivors through a living trust (with the goal to avoid probate) or a last will and testament.
When a married person leaves their estate through their last will and testament, they often either leave their surviving spouse the ownership of their estate or they leave their spouse the usufruct of their estate. One of the concerns about leaving ownership of their estate to their spouse is that, potentially, the surviving spouse could ultimately leave the entire marital estate to someone other than the children (such as, a 2nd spouse).
In Louisiana, some married people write a will and leave the usufruct of their estate to their spouse, in order to protect the children's future inheritance. They leave their spouse the usufruct (often for the lifetime of the surviving spouse), and they name their children as the naked owners. However, this can cause complications under a couple of different scenarios.
When a married person dies after having written a will leaving his spouse usufruct and naming others as naked owners, then a Succession will be necessary after the first spouse dies. All of the naked owners, along with the surviving spouse, are participants (also known as "Petitioners") in the Succession, and all must agree on how Succession matters are being handled and accounted for. Successions can be complicated and, typically, the more participants involved, the more misunderstanding that occurs. In addition, with multiple parties to a Succession, especially a number of naked owners who are concerned about protecting their future inheritance, things can get tense. Sometimes relationships among siblings and their spouses can be imperfect so when they all must participate and agree on all matters related to the Succession, it can get tricky.
So let's say go ahead and assume that the Succession gets completed and, subsequently, the surviving wife wants to sell the home. Because there are naked owners, they all must participate in the listing and selling of the home. The naked owners, in addition to the surviving spouse, must sign all of the real estate closing paperwork, often even if the first spouse to die granted his wife, as usufructuary, the authority to dispose of nonconsumable things. When a surviving spouse sells the home or other property over which there are naked owners, those naked owners often have a false expectation that they are to receive some of the proceeds of the sale of the home or other property. And sibling relationships can make it difficult for everyone to agree on all aspect of the sale of property subject to usufruct.
So when a married person writes a will and leaves their spouse usufruct of their estate, they should consider leaving the naked ownership in a testamentary trust for the benefit of the naked owners, with the surviving spouse as the trustee of that testamentary trust.
It will be easier to complete the Succession after that married person dies because the surviving spouse will be the only participant in the Succession. The surviving spouse will be the only participant because she will continue to own her half of the community property, she will inherit the usufruct of the deceased spouse's half of the community property, and she will be the trustee of a trust which holds the children's naked ownership interest. Now you won't have so many personalities involved trying to settle the estate or Succession.
In addition, under this "naked ownership in trust" bequest, the surviving spouse can sell the house or other property subject to usufruct, without having to get the agreement and signatures of all of the naked owners. In essence, the surviving spouse can sign for the naked owners on the sale paperwork because she is the trustee of a trust which owns the children's naked ownership interests.
While, on its face, the Will may initially appear more confusing when you leave the naked ownership in trust with your spouse as trustee of this testamentary trust, you'll likely be doing your spouse a big favor while also protecting the interests of your children or other naked owners.
Tagged: usufruct and naked ownership, what is a naked owner, Louisiana naked owner, naked ownership in trust, louisiana usufruct
Bequest of Property, Forced Heirship, Louisiana Succession, Will Plan
Collation Explained - Louisiana Estate Planning Law
When someone asks me what "Collation" means, it's typically because they've seen the word referenced in a last will and testament, and they don't know what it means.
This post describes a little history and current application of Louisiana collation law.
Back in the pre-1990's, there was a presumption in Louisiana estate law that parents were supposed to, from an inheritance standpoint, treat their children equally. If a parent made a gift to one child during the parent's lifetime, collation laws required that gift to be considered as an advance on that child's inheritance.
So, back in the pre-1990's, parents were permitted, in their last will and testament, to dispense their lifetime gifts from collation so that lifetime gifts would not be considered an advance on a child's inheritance.
Then, in the 1990's the Louisiana Collation law changed significantly in a way that reduces the scope and application of collation by limiting the right to demand collation to children who qualify as forced heirs, and collation only applies with respect to gifts made within three years prior to the parent's death.
Now, under collation law, if a child is 24 and not otherwise disabled, he or she is not permitted to demand collation. And a grandchild is not permitted to demand collation, even if he or she qualifies as a forced heir.
Nonetheless, many attorneys still include a provision in their client's wills stating, in effect, that the client's lifetime gifts are exempt from collation.
I haven't seen or heard anyone around our office discuss a potential collation claim in decades. Collation claims just don't come up much any more due to its limited scope. I suppose, however, it does not hurt to keep the "dispense from collation" provision in Louisiana last wills, even though it causes some confusion because clients have no idea what it means.
However, now with this post, you know!
Tagged: Louisiana Collation law, Collation and estate planning, Collation and forced heirship, Paul Rabalais Collation, What does collation mean, Collation and forced heirship law, Dispense from collation, Exempt gifts from collation
Independent Executor, Keep Property in Family, Louisiana Succession, Probate, Succession, Will Plan
Deceased Owned Property in Many Parishes: How To Transfer To Heirs in a Succession
This post describes how the real estate of a deceased person, who owned property in multiple Louisiana parishes, gets transferred the right way to the heirs.
We recently started working on a Succession. The deceased lived in Jefferson parish but owned property in several different parishes. He didn't own property in Jefferson Parish, but he owned property in St. Tammany, Tangipahoa, Plaquemines, and St. Landry Parishes. The daughter, who was named the executor of her father's Will, thought she was going to have to travel all around the state to register the children as the new owner of all of their father's property.
I explained the procedure for getting the property transferred as follows:
(1) Succession Opened. The proceeding to open a Succession after someone dies must be brought in the district court of the parish where the deceased was domiciled at the time of his death. In this matter, the deceased was domiciled in Jefferson Parish, even though he did not own a home or other real estate in Jefferson Parish. All court pleadings, petitions, Lists of Assets and Debts, court orders, and all other court documents of the Succession will be filed in the Jefferson Parish Succession Suit record.
(2) Judgment of Possession. At the conclusion of the Succession, the district court judge in Jefferson Parish will sign a court order that we prepare called a Judgment of Possession. We will ensure that all of the various legal descriptions of all of the deceased's different properties around the state are listed on this Judgment of Possession.
(2) Certified Copies of JOP. Once signed, we will request that the clerk of court of Jefferson Parish issue multiple certified copies of this Judgment of Possession (JOP).
(3) Record JOP in Parishes. We will record a certified copy of the JOP in the conveyance records in each parish where the deceased owned real estate. This will show all third parties and title examiners that ownership has been transferred from the deceased to the heirs (or, since there was a Last Will, to the legatees (children)).
In this matter, the deceased also owned real estate in Mississippi. I told the family that the Louisiana Succession would not transfer the Mississippi property. The family must hire another law firm in Mississippi to go through the ancillary probate in Mississippi to transfer the Mississippi property from the deceased to the heirs.
Many people who have property in multiple states transfer those multiple properties to one Living Trust so that no probate proceedings are necessary after the death of the Trust Maker.
Tagged: Judgment of Possession, Ancillary Probate, Property in Multiple Louisiana Parishes, Paul Rabalais Succession attorney, Jefferson Parish Succession Lawyer
Bequest of Percentages, Louisiana Succession, Will Plan, Usufruct
What is Required in Louisiana to Become an Independent Executor or an Independent Administrator?
Tagged: Louisiana independent executor, Louisiana independent administrator, What is an independent executor, Independent Administration of Estates, Probate attorney Baton Rouge, Louisiana Succession attorney, Lafayette Succession lawyer
Avoid Estate Tax, Keep Property in Family, Louisiana Trust, Property in Trust, Revocable Living Trust, Will Plan, Usufruct
The Double Step Up In Basis: Traditional Planning Makes Kids Pay Extra Capital Gains Tax
This describes how the traditional methods of estate planning for married couples causes children or other heirs and beneficiaries to pay extra capital gains tax due to the failure to take advantage of the double step-up in basis.
In the old days (about a decade ago), the emphasis on estate planning was always avoiding estate tax. Married couples would arrange their wills and trusts so that when the first spouse died, assets were left either in usufruct or to an irrevocable trust so that the assets of the first spouse to die would not be included, for estate tax purposes, in the estate of the surviving spouse. Assets were left to trusts commonly referred to as A/B trusts, credit shelter trusts, survivor's and family trusts, QTIP trusts, or bypass trusts. The goal was to, by leaving assets to an irrevocable trust at the death of the first spouse, those assets would escape estate taxation upon the death of the surviving spouse.
However, this planning method did not have the best capital gains tax result. In community property states, all of the community property would get a step up in basis upon the first spouse's death (to the value at the date of the first spouse's death), but only the assets that the surviving spouse owned would recognize another step up in basis when the surviving spouse died. The family was forfeiting another step up in basis.
Now, for almost all families, the fact that all the assets get lumped into the estate of the surviving spouse is irrelevant for federal estate tax purposes. Each estate can exempt $11.2 (for deaths in 2018) from the estate tax. And since new portability law allows the surviving spouse to use any part of the exemption that went unused by the first spouse to die, married couples can shield $22.4 million) from the estate tax. Simply put, estate tax is not an issue for most families.
So now, married couples should consider doing the opposite. They should consider arranging their affairs to that all marital assets get included in the estate of the surviving spouse. So long as the total is less than the estate tax exemptions, there will be no estate tax but the heirs will benefit from another step-up in basis when the surviving spouse dies. Then, if the heirs sell previously appreciated assets, there will be no tax to pay.
A simple way to include assets in the estate of the surviving spouse is to leave ownership of those assets to the surviving spouse (through a Last Will), Or if a married couple has a living trust to avoid probate, they can provide that the trust does not become irrevocable upon the death of the first spouse. However, if there is a blended family situation, or the couple is worried that the survivor may attempt to leave assets to a second spouse, or if the surviving spouse may need to qualify for Medicaid upon entering a nursing home, that couple may want to reconsider whether or not to put the surviving spouse in complete control of the marital assets.
Tagged: double step up in basis, capital gains tax, credit shelter trust, revocable trust for surviving spouse, Paul Rabalais
Can Person With Usufruct Make Improvements and Alterations to Property?
This explains whether someone who has the Louisiana usufruct has the right to make improvements or alterations to property.
Let's say, for example, that Husband and Wife entered into marriage later in life as a blended family. They each have their own kids. They decide to move into Wife's home. Wife doesn't want husband kicked out of her home (by her kids) if she dies before him. So she writes a Will and leave Husband the lifetime usufruct of the home. Wife later dies. Succession gets completed. Husband has usufruct, and is living in, the home. Wife's children are the naked owners.
Now Husband wants to make some improvements to the home (mancave, outdoor kitchen, hot tub, etc.). Can he do it?
Louisiana law says that, in this instance, Husband can make improvements and alterations AT HIS COST AND WITH THE WRITTEN CONSENT OF THE NAKED OWNER. If the naked owners don't give consent, Husband may, AFTER NOTICE TO THE NAKED OWNERS AND WITH APPROVAL OF THE COURT, MAKE AT HIS COST THOSE IMPROVEMENTS AND ALTERATIONS THAT A PRUDENT ADMINISTRATOR WOULD MAKE.
In most cases, parties in these situations don't think to seek out what the rules are and to see if they are in compliance with the rules. They tend to just do what they want because they thing they can. Then, the naked owners start to scream at the usufructuary, and all hell breaks loose.
Better, in these cases, to ask first for permission, rather than to act first and ask for forgiveness later.
Tagged: Usufruct Rights, Usufruct make improvements, Usufructuary Make alterations, Naked owner rights, Louisiana usufruct and improvements to property, Paul Rabalais Usufruct
Independent Executor, Louisiana Probate, Louisiana Succession, Probate, Succession, Will Plan
How To Get an Executor of a Succession Confirmed
The purpose of this post is to walk you through the detailed steps of getting an executor of a Louisiana Succession confirmed. Once confirmed by the court, the executor can then access accounts of the decedent, sell Succession assets, and have other powers that enable the executor to start the process of settling an estate.
Just being named as an executor in a Will does not give the named executor the authority to act. They must first go through the process of getting confirmed by a court. The following are the steps to getting an executor confirmed:
(1) Must have the original last will and testament - the one that was actually signed. The will names the executor.
(2) A petition to probate the Will and ask the judge to confirm the executor.
(3) The executor will sign a Verification of the above-mentioned Petition.
(4) Two people who knew the deceased will each sign an Affidavit of Death, Domicile, and Heirship. This proves to a judge that the deceased died and that he had a Will and whether the deceased had forced heirs.
(5) The executor signs an Oath that they will faithfully perform their duties as executor.
(6) We will prepare and file and submit the court order that we want the judge to sign confirming that the executor has been confirmed.
(7) We will prepare Letters of Independent Executorship. The clerk of court will make several certified copies. The executor needs certified copies of these Letters to move frozen financial accounts into an estate account.
(8) We have the named executor sign an Application for Tax ID Number. This number is necessary so that the executor can open an estate account.
So we file all the court pleadings and we wait - often a few weeks - for the court pleadings to be processed. We get it back and get certified copies of the Letters to the newly confirmed executor. And we are off and running.
Tagged: get executor confirmed, how to confirm an executor, Louisiana executo, Louisiana executor confirmation, Letters of Administration', Letters of Independent Executorship, Letters of Independent Administration, Paul Rabalais estate, Paul A. Rabalais estate planning lawyer, Succession lawyer Paul Rabalais, Succession Lawyer Louisiana, Probate lawyer Louisiana, Probate attorney Louisiana
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text:
JumpCast
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Boris, Bullingdon and The Riot Club
Fiona Underhill
11/12/2019 883 views0
The Riot Club (directed by Lone Scherfig) is not my favourite film of the decade (although it is definitely in my Top 10) but I believe it is one of the most important films of the decade. Especially when viewed in a double-bill with a film like I, Daniel Blake, it explains so much about British society and how we've got to where we are now in the UK. In this essay I discuss the film in the context of other representations of the Bullingdon Club in popular culture and discuss some of the antics Boris Johnson and David Cameron got up to during their time at Oxford University. If you're British or have a passing interest in British politics, I strongly urge you to watch this essential (and entertaining) film.
2016 is a year which will live in infamy as having far-reaching consequences for Western politics. In June, there was the Brexit vote in the UK and in November, Donald Trump was elected President of the United States. There have been few attempts (with varying degrees of success) to address this socio-political moment in American film, although there have been some impressive takes on gentrification and Black Lives Matter, including Blindspotting. In the UK, things have been troubled since 2010, when the Conservative Party, led by David Cameron were voted in to "clean up" the mess of the 2008 crash. This led to years of austerity – crack downs on public services, leading to a huge rise in homelessness and those in need of food banks. Of course, the desire to deflect blame onto refugees and scapegoat immigrants from countries such as Poland has led to Brexit. This increasingly divided society was addressed in 2016's I, Daniel Blake (directed by Ken Loach) about the frustrations of a disabled man being forced to jump through endless hoops to receive any financial help from the state. At the other end of the scale, there is a film which identifies just exactly where former UK Prime Minister David Cameron and current PM Boris Johnson come from – the breeding ground of Eton School and Oxford University which fosters Britain's ruling elite and creates the culture of those who have gone on to lead the country. It is one of the most important films of the decade and it is Lone Scherfig's The Riot Club.
Screenwriter Laura Wade adapts her own 2010 play Posh which has almost a single-location, taking place on one night, in real time (apart from a prologue and epilogue). The central event is a dinner for The Riot Club, a secret society made up of a small group of 'elite' Oxford University students (but not officially recognized by the university). The Riot Club is a thinly-veiled representation of the Bullingdon Club, of which both David Cameron and Boris Johnson were members (as well as some former Kings). The Bullingdon is said to have started as a Cricket Club in 1780, but gradually the social activities (chiefly the infamous dinners) took over as their main preoccupation. The Bullingdon has featured in various incarnations in literature and television, as well as film. In Evelyn Waugh's 1928 novel Decline and Fall, it is amusingly known as the Bollinger: "there is a tradition behind the Bollinger; it numbers reigning kings among its past members. At the last dinner, three years ago, a fox had been brought in in a cage and stoned to death with champagne bottles. What an evening that had been!"
Danish director Lone Scherfig has transitioned from the Dogme 95 school of film-making to making British period films (An Education, Their Finest) and those dealing with middle-and-upper class English characters in more contemporary times (One Day, The Riot Club). As is often the case, a more objective outsider's viewpoint on a country's society can be valuable. The combination of two women (Wade and Scherfig) putting the ultimate boy's club under a microscope and revealing their true natures is something to be relished. The women characters are pivotal in exposing particular weaknesses and the nastiest elements of the club. Wade introduced the character of Lauren (played by Holliday Grainger) into the film in a much more important role (she is only briefly referred to in the play). As well as being a girl – something these boarding school boys have little experience of – she is also Northern and from a state school. She represents everything that certain members of the club fear and despise.
Max Irons plays Miles and Sam Claflin plays Alistair Ryle – two 'freshers' who are set up as rivals from the first day when Ryle's parents demand that Alistair get his older brother Seb's old room. The amenable Miles agrees to a swap and then shows Ryle up further by being smoother with the girls than he is. Ryle has an inferiority complex because of being in his brother's shadow, "only" going to Harrow (not Eton) and a chip on his shoulder which is displayed by him "well, actuallying" those he considers inferior (women and poor people). When Ryle is mugged, he is consoled by Harry Villiers (Douglas Booth), who (in the precise and detailed costume design work of Steven Noble) is wearing almost the exact same outfit as Ryle – a 'uniform' virtually unchanged since The Sloane Ranger Handbook was published in 1982 (a couple of years before Johnson and Cameron were at Oxford). It consists of Barbour jackets and gilets (in racing green or navy), Oxford shirts, chinos (in cream or khaki) and brown brogues (the Oxford shoe) or loafers. Sloanes are named after Sloane Square in the London borough of Kensington & Chelsea and Princess Diana was the unofficial Patron Saint of the Sloanes. When Johnson and Cameron entered Oxford, there were two "bibles" that their set was influenced by – The Sloane Ranger Handbook (1982) and the television adaptation of Waugh's Brideshead Revisited (1981). As Johnson's sister Rachel notes in the Channel 4 docudrama When Boris Met Dave (2009); "it was a time when the dreaming spires and Thatcherism collided, and it was an incredible petri-dish for pushiness and ambition to become a virus that infected a whole generation." The lives of modern day Sloanes are chronicled in the "structured" reality television series Made in Chelsea, which started in 2011.
The other members of the club are made up of Guy 'Bell-End' Bellingfield (Matthew Beard), George (Jack Farthing), Toby aka Tubes (Olly Alexander, from the band Years & Years) and Ed (God's Own Country's Josh O'Connor). The Club President James Leighton-Masters is played by Freddie Fox, who like Max Irons, is descended from acting royalty. There is also the older Hugo (Sam Reid) who knew and coveted Miles at Westminster and the super-rich Greek Dimitri (Pride's Ben Schnetzer). Dimitri is the source of internal snobbery within the club, he is only valued for his enormous wealth – his roll of cash is used to pay people off whenever needed. However, he represents bourgeois new-money and, like the Greek-German Prince Philip, is looked down upon for not being an upper-class Englishman with the proper breeding. It seems that you can send your children to the best English boarding schools, where they will acquire the best cut-glass accents, but if they aren't titled, they will always be outsiders. Villiers' house is the only one of the club-members that we see – it is a traditional stately home, which has to be opened to the public to pay for its upkeep. This is one of the reasons why they resent Dimitri so much, their wealth is tied to land and property, whereas he has an endless supply of ready cash. When the boys get drunk and puke up in Dimitri's brand new "beautiful British car," he puts the keys through the letterbox of a Charity Shop and just abandons it.
The structure of The Riot Club follows the play in having an extended scene which is the fateful dinner at The Bull's Head. The film spends 40 minutes introducing the ten club members, their relationships and rivalries and crucially establishing Miles and Lauren's relationship. It also depicts the initiation and hazing rituals, which will be familiar from American pop culture depictions of fraternities in US colleges. The room trashing initiation is used by the real Bullingdon Club. In When Boris Met Dave, Lloyd Evans explains; "In order to become a member, you had to suffer vandalism and a certain amount of violence. Once you became a member, you then acquired the right to inflict vandalism and a certain amount of violence on other people, often on blameless innocents. But you compensate them, financially. You don't count the social or the emotional damage you've done, you just throw money at them. Which actually, is a further insult because it assumes that the only thing that matters to the victim is the money and the one thing you couldn't care less about is the money. So, the British ruling elite has this ritual at its heart." Once the action moves to The Bull's Head, the film spends 40 minutes depicting the events of the dinner which escalates into completely trashing the place and violently assaulting the landlord. It then has a 30-minute sequence which shows the aftermath, including a 'council-of-war' which is beautifully lit and shot in a cloister and the dialogue becomes amusingly militaristic "you don't leave a man out on the field". There are internal disputes over who should be blamed and Villiers' Uncle Jeremy (Tom Hollander) swoops in to clean up the mess.
For those who may view the representation of the club dinner in The Riot Club as grossly exaggerated from the real-life antics of the Bullingdon and other similar societies, the attitude is more important than the actions. Ryle riles up these public school boys into a Lord of the Flies-style frenzy through a rallying speech "I am sick to fucking death of poor people." Ryle 'suffers' perceived humiliations at the hands of Charlie (Natalie Dormer), an escort who refuses to go under the table and 'service' all ten of the club members and Lauren, who he summons to the dinner and who also refuses to perform this task. He is most aggrieved by the landlord Chris (Gordon Brown) and his daughter Rachel (Jessica Brown Findlay) and the fact that Chris will take their pay-offs, but keeps the moral high-ground; "there's going to be no country left for us because of people like him." Compared to the grievous bodily harm Ryle and the others end up inflicting on Chris, some of the stories that have emerged of real Oxford societies appear tame in comparison, including members of the Bullingdon allegedly throwing a pot plant through a restaurant window during Johnson and Cameron's time. They still reveal important character traits about the club-members, however. In a neat parallel with how he announced the Brexit vote and then resigned, leaving his fellow Tories to mop up the mess, Cameron apparently scarpered before a small group, including Johnson were arrested. In 2015, an infamous scandal occurred when it was leaked that David Cameron allegedly put an appendage in a dead pig's mouth as part of an initiation ceremony for the Piers Gaveston Society. The pig's head was resting on the lap of a society member at the time and the story was leaked as part of a dispute with Lord Ashcroft (a big Tory donor who fell out with Cameron). When these allegations were made, it was immediately associated with the first episode of Black Mirror (The National Anthem, 2011), in which the Prime Minister has to have sex with a pig on live television in order for a kidnapped princess to be released.
One of the criticisms leveled at The Riot Club was that the casting – of a group of charming, good-looking "hot young things" – and the actions of the characters in the first half of the film glamourises the Bullingdon. I think this is the precise effect that Scherfig is trying to have on her audience. The first half of the film seduces us – we are even perhaps envious of these boys, their hedonism and what they manage to get away with. This makes the brutal attack on the landlord all the more shocking and it is at this point that we can address our own complicity. After all, a large proportion of the population have been seduced by the Bullingdon boys. While the extreme actions of the fictional Riot Club may be hyperbolized, the vitriol Ryle and the others feel towards 'normal' people rings true. Johnson, Cameron, George Osborne and many of their contemporaries in politics and the media are fostered in an environment that reinforces them being the elite of society. They come from the 'top' schools, go to the 'top' universities and get into the 'top' exclusive clubs. It's all about being considered 'the right sort of chap', being from the right families and having the right connections, which begin at prep school and last well into adult life – to the tops of their chosen professions. Scherfig and Wade's The Riot Club exposes exactly what sort of people are running the UK, imposing austerity and other punishing policies on the most vulnerable in society.
The writing is razor-sharp, as are the performances; particularly Sam Claflin as Ryle. Claflin communicates every emotion Ryle goes through almost entirely through incredibly subtle changes in his mouth and how much he is clenching his teeth from one scene to another. The embarrassment because of his parents, shame and inferiority when he is compared with his brother, humiliation at the hands of the muggers, the landlord, Miles and Lauren. All of this resentment is then transformed into a smug satisfaction when his seething sermonizing rallies the club into action, but is quickly followed by manipulation and scheming to try and get out of trouble. And then there is the last triumphant smile when he realizes that not only will he get off scott-free, but he will be rewarded for his actions at the club dinner. The final shot of the film really is a microcosm of British society, especially when viewed in direct comparison with something like I, Daniel Blake. There will be no consequences for a man like Ryle, the boys club will rally and protect their own. As it says at the start of Waugh's Decline and Fall; "that's the public school system all over. They may kick you out, but they never let you down."
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Game of Thrones Ep4Pt5 - I'm not aFreyd - Gamespresso Plays
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Meet Marcus Holloway in new video for Watch Dogs 2
The first episode of a new video series promoting Watch Dogs 2, titled "Remote Access" introduces players to the series' new main character, Marcus Holloway.
While future episodes in the video series will focus on different aspects of the world of Watch Dogs 2, such as the environment and the story, the first episode goes in-depth about Marcus, as well as DedSec and their motivations.
"When you meet Marcus Holloway in the story, he's a young hacker who is for the first time having a sense of community and family with other hackers," Watch Dogs 2 scriptwriter Lucien Soulban says in the video.
The video also reveals more information on Marcus' closest friend in the game, a character named "The Wrench."
"Wrench is the resident engineer, and also 'problem solver,'" says Shawn Baichoo, who voices Wrench in the game.
Watch Dogs 2 is set to bring a lot of changes to the series from the first title, beyond just a change of protagonist. Set in the new location of San Francisco, Ubisoft has confirmed the entire game can be played in stealth without killing a single person.
Watch Dogs 2 is set to launch later this year for PS4, Xbox One and PC on November 15th.
PS4Ubisoftwatch dogs 2


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Partnerships: One Path to Training to Ease Talent Shortages
Pick your industry. Some long-timers are realizing that the next generation of expertise their teams require isn't being groomed as they need it.
Jim George
Yet, market conditions continue to change and knowledgeable staff veterans continue to retire. Why the talent gap? Blame continues to be placed on a lack of sufficient budget, a suitable pool of qualified recruits, or even a coordinated plan of action.
Fortunately, we're starting to hear stories where industrious people are taking their own initiative to make things better. I want to share one such success story in the packaging industry. It started with one individual's observations that fostered an idea. Momentum accelerated quickly around that idea with the resolve of industry peers having a shared need. The Institute of Packaging Professionals got involved, eventually with an assist from PMMI. The partnership that blossomed has proven essential for the impending launch of a much-needed new training course–but more on that later.
An idea germinates
Let me take you back to the beginning. Six years ago, Jennifer Benolken wanted to develop a packaging engineering group at a former employer in medical devices. But no training course existed with the requisite focus on just that industry segment, and her one-time employer lacked an on-site packaging facility for learning. Furthermore, an existing handbook on medical device packaging was dated.
"I was struggling with my group and didn't really have anything to give these junior professionals," says Benolken, today an MDM and Regulatory Specialist in Packaging Engineering at DuPont. Once upon a time, she notes, senior professionals had spare time to coach green recruits on medical device packaging—and junior associates were allowed to learn from their mistakes, because at that stage of their careers, any missteps generally weren't crucial to the company's bottom line. Those days are gone. "Now, you're expected to be perfect from day one," Benolken says. But today's senior packaging experts have little or no time to help train them as they go.
Adding to the challenge, those interested in learning about medical device packaging are at another disadvantage. While any packaged food or household product is readily available for observation and discussion, medical device packages lack similar exposure. "You can't go to the store and point out to people, 'Hey, I packaged that (medical device),'" Benolken explains.
That's when the idea for a focused training course, developed by industry experts, came to her. Over the past few years, she and others have been marshalling the expertise of IoPP's Medical Device Packaging Technical Committee to create a course this industry segment so sorely needs. The project was slowed but never halted by the COVID-19 pandemic. IoPP staff jumped into the planning several years ago to help with the coordination and eventually handle marketing and registration.
IoPP, in turn, has been working with PMMI through the logistics to hold the inaugural Fundamentals of Medical Device Packaging course at PACK EXPO International, beginning with this fall's show in Chicago (Oct. 23-26). The objective was for an in-person immersion course in which students could learn concepts in the classroom and then observe how medical device packaging is made on actual machines. PACK EXPO provides an ideal environment for the course; the classroom will be at McCormick Place during the show and will include time on the show floor with machinery demonstrations and discussion at booths of participating exhibitors.
Fundamentals of Medical Device Packaging will be offered through IoPP and cover the basics of packaging regulations, standards, materials, equipment, sterilization, design, qualification, and troubleshooting. It targets professionals with two to three years of industry experience to continue to build, strengthen and sustain their technical expertise in medical device packaging. In this first classroom session, 14 industry professionals have volunteered as instructors in one or more segments of the course.
More partnerships needed
Now, about that partnership. This is exactly what the packaging industry needs more of, given the continuing shortage of experienced packaging engineers and related professionals who, with additional training, can be shaped to become tomorrow's leaders. Creative partnerships can make more of these successes possible and help ease staff shortages.
Each of us knows of others in our networks who may be outside of packaging and contemplating a new career direction, or who are mulling a move elsewhere within packaging. These individuals are the low-hanging fruit that could be trained or retrained to ease the staff shortages in our industry. They might be unaware of all the opportunities in packaging, but they do share one thing in common: They want to make a difference in the world. It's up to us in this industry to build the associations that can help them make those richly rewarding careers possible and keep the knowledge moving forward.
The author, Jim George, is the Director of Education at IoPP. For more information on IoPP, visit www.iopp.org.
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With high value placed on traceability and brand protection, this ultra-thin label is designed to 'snip and ship' to track goods—from pallets to individual shipments—with near real-time positioning.
Scan from a Distance, Enlarge Product Information for the Blind


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Athena Karkanis Talks about Husband's Support during Pregnancy
by Sumila Tuladhar January 1, 2023
written by Sumila Tuladhar January 1, 2023
Canadian actress Athena Karkanis delivered a memorable performance as Grace Stone in the Netflix series Manifest.
Karkanis began playing the role of Stone in Manifest in 2018. She appeared in every episode leading up to the season three finale, in which she was brutally murdered. The actress tried her best to protect her loved ones throughout the season.
Her outstanding performance as a mother and wife on screen has led some to wonder if she possesses the nurturing quality in real life.
Athena Karkanis's real-life partner
According to Nicki Swift, Karkanis is reportedly dating a Canadian journalist, but no solid evidence supports that claim. That being said, she has a partner/husband but is yet to reveal his identity.
The actress made a comparison between her pregnancy and Stone's situation. As a mother, Karkanis compared pregnancy to the Manifest series, in which her character goes through numerous body changes and hormonal shifts that a significant other cannot fully understand.
A post shared by Athena Karkanis (@athenakarkanis)
In an interview with Cinema Blend, Karkanis said, "I remember, during my second pregnancy, having this epiphany that pregnancy is a very lonely thing. Because as much as my partner was extremely supportive, and I have no complaints about how he handled it, I just remember things like the nausea, and it's all, like, nothing for him."
"He can feel bad for me, and make me a cup of hot ginger water or whatever. But there are these things that, it's just me. I'm doing that," she added.
The fact that the actress's partner showed her a lot of support throughout her pregnancy indicates that everything in their relationship has been going smoothly up to this point.
Athena Karkanis with her on-screen husband, Josh Dallas. (Source: Instagram)
Moreover, Karkanis appears close to her on-screen husband on Manifest, Josh Dallas. The audience loved their on-screen chemistry, which was undoubtedly influenced by their real-life friendship.
She also posted a photo of herself with Dallas on Instagram on April 2, 2021, and considered Dallas to be one of the most generous actors she had ever met. The actress believed playing the role of Stone would not be easier without a partner like him.
Athena Karkanis is a mother of two kids
Karkanis is the best fictional mother and a wonderful mother to her children outside the set. She has two kids, an older daughter, and a younger son, just like in the show Manifest.
However, Karkanis has not revealed details about her children. She posted a picture of her two kids on Instagram on November 15, 2021, but only after covering their faces with a heart and smiley face.
Athena Karkanis with her kids (Photo: Instagram)
She wrote alongside the photo, "I found myself overcome with emotion, thinking about how momentous this return to the stage is. As a performer (who's first many years of her career were on the stage) and as a lover of theatre and dance, I felt so happy and grateful to be there and to be sharing it with my children."
Athena Karkanis's character met a tragic end in the 'Manifest'
Karkanis gave an excellent performance alongside Dallas in the show. However, her character Stone died tragically at the end of Season 3 of the show after being murdered.
As a spoiler, the tragedy did not end with Stone being stabbed; she died from her wounds with Cal by her side.
Athena KarkanisManifest
Sumila Tuladhar
Sumila is a Nepal-based freelance content writer and lifelong learner with an ongoing curiosity to learn new things. She writes on various topics by combining her curiosity with experience from her profession. She has recently completed her Bachelor's in International Business Management from Herald College.
What Is Athena Karkanis' Ethnicity? Inside Her Early Life
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Meet Botley, the code to fun! As the newest member of the Learning Resources family, Botley introduces coding in an easy, friendly way. Children as young as 5 can learn to code with Botley, and with his advanced features, he'll grow with them for many play-filled years to come. Botley is ready to use right out of the box – he'll have kids coding in minutes. And that's not all that makes Botley unique; he's 100% screen-free, and the only coding robot that includes a 77-piece activity set! Here are just some of the fun interactive features Botley offers:• Detect objects – and avoid them!• Follow looping commands• Navigate obstacle courses• Follow black lines. Botley also has additional hidden features to unlock!


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Samuel de Missy, francoski poslovnež in politik, * 30. oktober 1755, † 20. oktober 1820.

Bil je izvoljen v Narodno skupščino Francije leta 1789. Zaradi sklepov francoske revolucije, ki je prepovedala sužnjelastništvo, je de Missy izgubil večino svojega premoženja.

Glej tudi
 seznam francoskih politikov
 seznam članov Narodne skupščine Francije (1789)

Rojeni leta 1755
Umrli leta 1820
Francoski poslovneži
Francoski politiki
Člani Narodne skupščine Francije (1789)

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import { Inject, Injectable, InjectionToken } from "@angular/core";
import { ApiKeyService } from "./api-key.service";

export let API_KEY = new InjectionToken<string>("stub.api.key");

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 *
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@Injectable()
export class StubApiKeyService extends ApiKeyService {
  private key: string;

  constructor(@Inject(API_KEY) key: string) {
    super();
    this.key = key;
  }

  getKey(): string {
    return this.key;
  }

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    this.key = apiKey;
  }

  isAuthenticated(): boolean {
    return this.key != null && this.key.length >= 1;
  }
}

redpajama_set_name: RedPajamaGithub


Dr PC Jocelyn, from the Royal Infirmary, Edinburgh, was secretary of the Scottish Region of the ACB in 1959 and he and Miss P Burton gave papers at ACB Regional Meetings in 1960 and 1959 respectively.
In 1960 the International Congress of Clinical Chemistry was held in Edinburgh and was organised by, among others, Sam Frazer.
In 1962 John A Owen, who had been in Melbourne since leaving the department in 1957, was appointed and, a few months later, he was Acting Head of Department when CP Stewart retired.
CP Stewart was an able and popular lecturer and a leading clinical biochemist with an international reputation. He created a teaching department and a service laboratory of note, with little help from the clinicians other than Derrick Dunlop, Professor of Therapeutics and Clinical Medicine, with whom he worked in close collaboration and with mutual respect. Stewart and Dunlop wrote the text book "Clinical Chemistry in Practical Medicine" which ran to six editions. (This gives a very fair presentation of the application of laboratory work in clinical practice at the time and it was the local "bible" for medical students and housemen). He co-edited the first thirteen volumes of "Advances in Clinical Chemistry from 1958 to 1964 (volumes 1 to 9 with H Sobotka and 10 to 13 with O Bodansky) and "Toxicology: Mechanisms and Analytical Methods" (volume 1 & 2 (1960 and 1961) with A Stolman) published by Academic Press (London).
A Chair of Clinical Chemistry was established in 1962 and, the following year, L. Gordon Whitby was appointed to this newly created Chair.
L Gordon Whitby had graduated at Cambridge University (1st Class Honours, Biochemistry, 1948, PhD, 1951 and Medicine, 1956) and had held appointments in the Royal Postgraduate Medical School, Hammersmith Hospital, London (1958 to 1960) and Addenbrooke's Hospital, Cambridge (1960 to 1963). A year after joining the chemical pathology department at the Hammersmith, he was awarded a Rockefeller travelling scholarship (1959) and, as a Research Fellow, he spent a year in the National Institutes of Health, Bethesda, Maryland, U.S.A. He studied adrenal hormone metabolism in the laboratory of Dr J Axelrod and was awarded his MD from Cambridge in 1961 on the basis of this work.
In 1966 J Douglas Crombie, who had been providing services for the Royal Hospital for Sick Children, Edinburgh, in a small laboratory in the department at the Royal Infirmary, was promoted to Medical Assistant and moved to the R.H.S.C.
L Barry Roberts succeeded Crombie in 1966. Roberts later was appointed as Top Grade Biochemist in Hull prior to being appointed as Top Grade Biochemist at Glasgow Western Infirmary in 1975. He retired in 1994.
In 1967 Ronald GS Leask was appointed as Senior Registrar at Stobhill General Hospital, Glasgow and was succeeded by RJ Georges. Georges was the first non-medically qualified candidate to gain the M.R.C.Path. by examination.
John Seth was appointed as lecturer in Clinical Chemistry at Edinburgh University in 1969.
Peter CP Wong studied for PhD under AF Smith from 1972 to 1976.
In 1984, Ian W Percy-Robb, Senior Lecturer, who had been a member of the department since 1968, was appointed to a personal Chair of Pathological Biochemistry in Glasgow University and as Honorary Consultant to Glasgow Western Infirmary and retired in 2000.
Laila Tibi studied for PhD under AF Smith from 1985 to 1990. She was appointed as Senior Biochemist in 1992 at St Albans City Hospital. The lab at St Albans moved to Hemel Hempstead in 1996 and in 2001 she was appointed as Principal Biochemist at Hemel Hempstead. The hospital at Hemel Hempstead later came together with Watford General Hospital to become West Hertfordshire Hospitals.
Cathy M Sturgeon was initially appointed as a Research Fellow in the Immunoassay Section of the Royal Infirmary of Edinburgh and developed a special interest in tumour markers. She was a founder member of the European Group on Tumour Markers, which was one of the earliest groups to consider quality issues of these assays, and Director of the UK National External Quality Assessment Service (UK NEQAS) unit at the Royal Infirmary of Edinburgh. She was awarded Medal of Excellence for Scientific Cooperation by the Medical Faculty of the Charles University in Prague and presented with the Morton K Schwartz Award for Significant Contributions in Cancer Research Diagnostics for a scientist who has achieved national and international status for groundbreaking work in clinical diagnostic research in cancer and who is considered to be among the world's foremost experts in that specific arena, by the American Association of Clinical Chemistry in 2009. She was one of the Science Council's "Top 100 Scientists" in the "Monitor-Regulator" group in 2014.
Kay S Walker, Grade A trainee, won the John King Award in 2001 for a paper entitled "A case of self diagnosis".
Lee Campbell was appointed as a Grade A Trainee in 2002 and as Senior Biochemist in Edinburgh Royal Hospital for Sick Children in 2005.
Patrick Twomey was appointed as consultant in Ipswich in 2003.
Dr Michael Crane was appointed as a Grade A Trainee on 2005.


Commands /skyblock new - Creates a new island for the player/party if they don't already have one. /skyblock home - Teleports the player to their island/party's island.... Commands /skyblock new - Creates a new island for the player/party if they don't already have one. /skyblock home - Teleports the player to their island/party's island.
6/05/2015 · Do you want to remove all your recent searches? All recent searches will be deleted how to say clothes in spanish Commands /skyblock new - Creates a new island for the player/party if they don't already have one. /skyblock home - Teleports the player to their island/party's island.
Commands /skyblock new - Creates a new island for the player/party if they don't already have one. /skyblock home - Teleports the player to their island/party's island.
That's not about the map but this was my first skyblock and I didn't know that and my start was much slower than it needed to be. But this is an awesome pack and I'm really enjoying it. If you want a good video series relating to this, Wilx has an excellent one on youtube, but it can also be fun to fiddle around and figure things out.


I just got my system and have installed the iPhone software for remote viewing. I noted in one of the videos that the iPhone version only shows 4 cameras in the standard mode and to watch more you have save as favorites, then scroll to the page you want. I did that but somehow managed to duplicate the first page on page 2. Now I can't figure out how to delete the second page of favorites and ad the last two cameras in my system.
Any directions would help. I'm using the TechPro Lite version on an iPhone 4S.
You will need to go to the app and click on the icon that look like a star and your favorites list will show up. To delete swipe on top of the name and hit delete. Unfortunately you can't delete just one camera of your favorites list.


Apple trees grow everywhere here. Huge, splendid, gnarly old trees, fighting the taller forest growth for sunlight and littering the ground with fruit. I've been noticing them from time to time, always with a shock of pleasant surprise in the discovery of their identity, (why, that's an apple tree)! They are especially prolific in the park where we hiked on Monday.
Prince Edward Island National Park was established on the site of an early settlement. Naturally, the settlers wanted fruit trees. Now the settlers are long gone, and even the remains of their houses and fences have been consumed by moss and the slow decay of rain, wind, and time. But the trees remain. Running rampant all over the park, unkempt, rugged, surprising. Apples and peaches spreading their bounty to the wild expanse.
Back to the park today. Invigorating wind, a brisk hike under a grey sky. I think I'll leave the pictures to tell the story. We also went back to check on our dolmen. It still stands!
Being here at the beginning of 'off season' has some serious perks - namely, that access to the park is now free! There are also some oddities - come to find out, the church we'd been planning to attend this morning only has services during the summer. The idea of a seasonal church is...odd. And a bit sad. We had to scout around for another place to worship, and after church, we headed out to P.E.I. National Park.
The brother and I hung around the beach; chatting, finding cool rocks, sheltering from the fierce wind.
The beach was littered with smooth rocks of all shapes and sizes, and I was just commenting that we ought to make a cairn or dolmen, when I noticed that some other people'd had the same idea. We added our two little structures to the collection. The cairn with the balancing rocks on top probably won't last long, but it was fun to make!
Goodness, I don't like being a tourist, and I've realized that I'm in danger of becoming a snob. You know, one of those unbearable people who is all, 'ick! Tourism!' It's as if my hermit streak shows up with undue strength when I find myself in a new place. I crave solitude, an escape from the beaten path. Not to mention the fact that I'm an utter cheapskate.
ANYWHO, it has come to my attention that my last two posts have been rather too full of complaints about tourism. I'll try to be a bit more positive from now on, because I truly am enjoying it here.
It's so nice to take pictures of something that isn't my house!
And the ocean is lovely.
And the people are some of the friendliest I've ever encountered.
And there are lighthouses. Lots and lots of them - predominately red and white.
Today was lighthouse day (and, incidentally, a chance for me to indulge my non-touristy/hermit/beaten-path-shunning tendencies to the full).
I'm glad I brought so many layers. After yesterday's warm weather, I was starting to think that I'd over-packed. But today was overcast, windy, and quite chilly, and I was thankful to pull on a sweater. Every Islander I've had a minute's conversation with today has apologized for the weather and held out hopes that we'll see the sun again soon.
The tourist season is almost over here. Many of the tourist areas have already closed down. We've passed through several towns where a good many of the buildings are dark and deserted...waiting for next years' inundation of tourists to revitalize them.
I'll admit to a smidgen of disappointment. We drove across Confederation Bridge, and my first glimpse of Prince Edward Island was exciting - red shores, colorful coastal town, lighthouses. But, as we progressed further inland, I was overwhelmed by the conviction that I'd really seen it all before. P.E. Island is farming country. Missouri is farming country. There isn't a huge difference between the two. I like farming country, truly I do, but I had been picturing something a bit more...unusual.


Hi, the design team at my work has a creative cloud for teams membership. We tried to change the administrator account to design@wynyardgroup.com (which allows emails to be received by the whole design team). However we aren't receiving any verification emails and no longer can log in using this email or make any admin changes. As a result, I think this has messed with the billing information and it is saying there is a payment error. The forums, chat AND phone aren't working and we would like to sort this out asap.


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FICTION>
Contemporary Women>
The Unbreakables - EPUB
The Unbreakables
by Lisa Barr
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A delicious, sharp novel about a woman who jets off to France after her perfect marriage collapses, putting the broken pieces of herself back together while rediscovering her own joie de vivre—a lust for life, art, and steamy sex.
"Artful, feminist, and emotionally gripping. The Unbreakables is a remarkable tribute to a woman's strength in the face of heartbreak and adversity." — Helen Hoang, author of The Kiss Quotient
The worst birthday ever might just be the gift of a lifetime…
It's Sophie Bloom's forty-second birthday, and she's ready for a night of celebration with Gabe, her longtime, devoted husband, and her two besties and their spouses. Dinner is served with a side of delicious gossip, including which North Grove residents were caught with their pants down on Ashley Madison after the secret on-line dating site for married and committed couples was hacked. Thirty-two million cheaters worldwide have been exposed…including Sophie's "perfect" husband. To add insult to injury, she learns Gabe is the top cheater in their town.
Humiliated and directionless, Sophie jumps into the unknown and flees to France to meet up with her teenage daughter who is studying abroad and nursing her own heartbreak. After a brief visit to Paris, Sophie heads out to the artist enclave of Saint-Paul-de-Vence. There, for the first time in a long time, Sophie acknowledges her own desires—not her husband's, not her daughter's—and rediscovers her essence with painful honesty and humor, reawakening both her sensuality and ambitions as a sculptor.
As she sheds her past and travels the obstacle-filled off beaten path, Sophie Bloom is determined to blossom. Allowing her true self to emerge in the postcard beauty of Provence, Sophie must decide what is broken forever...and what it means to be truly unbreakable.
Imprint: Harper Paperbacks
BISAC1: FICTION / Contemporary Women
BISAC2: FICTION / Family Life / Marriage & Divorce
BISAC3: FICTION / Romance / General
"Readers will delight in this effervescent cocktail of second chances, female strength, mother-daughter bonding and the truths that set us free. Smart, sure and sexy, The Unbreakables is unforgettable." - — Pam Jenoff, NYT bestselling author of The Orphan's Tale
"Lisa Barr has written a fun, sexy, satisfying tale of a woman getting her groove back. From the Rodin Museum in Paris to the South of France, The Unbreakables has unexpected moments of warmth and human connection, and charts a woman's journey back to herself." - — Cristina Alger, USA Today bestselling author of The Banker's Wife
"The Unbreakables is a sensual, evocative story about a woman scorned taking the necessary risks to find herself again. From the suburbs of Chicago to the south of France, Barr takes us on an exhilarating journey through love, lust, betrayal, friendship and family. A fabulous read!" - — Elyssa Friedland, author of The Intermission
"Artful, feminist, and emotionally gripping. The Unbreakables is a remarkable tribute to a woman's strength in the face of heartbreak and adversity." - — Helen Hoang, author of The Kiss Quotient
"Sit back and enjoy this sexy and satisfying read about a woman who has no choice but to start over after a massive betrayal. The Unbreakables by Lisa Barr is an empowering read about love, sex, friendship, and everything in between." - — Brenda Janowitz, Popsugar
The Unbreakables offers a compelling midlife coming of age story that takes readers from a Chicago suburb to Paris and on to the enticing south of France. Lisa Barr's exceptional contemporary storytelling delivers unforgettable characters, surprising twists and a passionate tale of self-discovery and forgiveness that will resonate long after the last page is turned. - — Patricia Sands, author of the bestselling Love in Provence series
"This exquisitely wrought novel will appeal to readers who believe in the redemption of new beginnings." - — Publishers Weekly
"The Unbreakables is a well-crafted novel about heartbreak, passion, and reclaiming one's life. The strength of this novel lies in the way Sophie's emotions almost radiate from the page." - Booklist
Barr's latest (after Fugitive Colors) is full of vivid details that transport readers from a Chicago suburb to the art world in France. For fans of women's fiction in the style of Kristin Hannah. - Library Journal
https://d2wawpwx3aybf6.cloudfront.net/hc-audio/9780062931382.mp3
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by Thornton Wilder
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by Linnea Hartsuyker
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by R. F. Kuang
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The Trials of Teaching Evolution in 2008
Reality BaseBy Melissa LafskyAugust 27, 2008 8:51 PM
The New York Times has a report this week on the hoops teachers are jumping through to teach evolution in public schools. Specifically, it follows the efforts of David Campbell, a Florida biology teacher who does an astonishing job of compromising, tip-toeing, and cajoling, all to get his students to accept—and maybe even learn—the process of evolution. Overall, the piece paints a bleak picture for teachers, made all the worse by the lack of a clear nationwide mandate for teaching the subject. Despite all the scientific evidence we have, some states are still stacking obstacles in the path of instructors who want to devote class time to human evolution. This summer, Louisiana passed a law protecting the right of local schools to teach "alternative" (i.e., non-scientific) theories for the origin of species, while the Florida Department of Education didn't explicitly require its public schools to teach evolution—or, as the legislature calls it, "the organizing principle of life science"—until February of 2008. Even if teachers manage to dodge sketchy state restrictions, there's still the matter of parents. Campbell, who helped write Florida's standards on teaching evolution, found himself barraged with complaints from angry parents when he taught the subject, and was even undermined by his colleague and fellow bio teacher, who offered a competing lesson plan she called "Evolution or NOT." (Her backup plan for what to tell particularly curious students? "I think God did it.") The U.S. is teetering on the edge of losing its place as the world's premiere harbor for science research. With experts already foretelling our demise as a science superpower—and, with China already set to surpass the U.S. in published physics papers by 2012, there's been nothing to suggest the predictions are wrong—we're not doing ourselves any favors by undermining basic science education with religious dogma. It's tragic to think that tomorrow's preeminent biochemists or geneticists could be sidelined by high school lessons questioning whether there's Biblical evidence for the origin of human life.