putting the ball in your court

Ngày tải lên: 15/12/2013, 05:15

Ngày tải lên: 27/06/2014, 23:20

... summarize the main idea in your own words as much as possible. Why? Because writing the main idea in your own words requires you to process the information instead of just copying it. In other words, ... gloss by taking the main idea, reducing it, and rewriting it in the margin. When you glossed, you simply found the central idea in the topic sentence and more or less copied it. The point of this ... you take the ideas in the text you’re reading and put those ideas into your own words. You can do this by summarizing or para- phrasing what you read. PUTTING IT IN YOUR OWN WORDS 193 other paragraphs....

Ngày tải lên: 25/10/2013, 17:20

... throw them into the freezer in their original packaging, which can cause ice crystals to build up in the bag. Instead, rewrap them in another plastic freezer bag as well. Before you freeze them, ... baking sheet lined with parchment paper or plastic wrap in the freezer and chill for 10 to 20 minutes. Place the food in a single layer on the lined baking sheet, leaving about 1 inch between the ... select thick, industrial-looking crates rather than thin-walled store-cupboard-style crates. 4. Integrated Freezers These are the absolute latest in freezer de- sign. The freezer is integrated into the kitchen...

Ngày tải lên: 15/01/2014, 11:01

... rates sink and find less margin for error. They’re headed for the toilet—and even in there the good seats are already taken. There’s your choice: Mountain or toilet? We’re climbing CRM Mountain ... addressing is the creation of increased value of the customer. That is, they are trying to make customers more valuable to the firm by selling them more products and services, by increasing their ... shopping. The supermarket also adds value when its stock clerks will lead customers to the items they cannot find, rather that simply sending them to find the items for themselves. Such initiatives...

Ngày tải lên: 23/01/2014, 23:20

... growth in your asset, but you also increase leverage on your taxes. Ken Here’swhatwe’redoing.Wegettheseloans,and the tenantsarepayingthemo.at’s the point. Robert Andthey’repayingitowithafter-taxdollars. Ken ... mortgages. Tom And they were doing it for things like vacations, boats, cars, and other things. And the reality is that the reason they were doing that is because they got to deduct the interest o their ... after in ationhasfallen.So the harderpeoplework, the lessthey’remakingbecause the governmentand the Federal Reserve, the banking system, they’re basically stealing it from them. Robert Canwebring in the bagsofcoinsrightnow?ankyou. 33 Sacred Cow #8: Invest for the Long Term in a Well-Diversified...

Ngày tải lên: 08/02/2014, 18:12

... had represented the data in the operation was a complete mismatch to the processing model within the auto insurance application. While all the data was there, the way in which the data was organized ... authority. They simply take their lumps in the review, and then everybody goes back to doing what they were doing with no real change in behavior, other than some additional animosity in the organization. If ... is. In designing the original interface, Spencer's team focused inward, basing their decisions on the service development team's understanding of the service implementation. The path...

Ngày tải lên: 18/02/2014, 09:20

... the Court s reasoning. It was a right used by the Court from the beginning, since its eighth ruling in 1990 and throughout the transition. The repeated reliance on human dignity enabled the Court ... example in mind which could solve the problems they faced in constitu- tional adjudication. As this book explains, the strategy worked, in the narrow sense that the Court was able to construct the ... are involved. For instance, in the Czech Republic, judges are appointed by the president of the Republic with the approval of the senate (Art 84). In Romania, three judges are appointed by the...

Ngày tải lên: 18/02/2014, 11:20

... affect the ability to finish reviewing your permit application in a timely manner or result in the determination that your permit application is incomplete and cannot be acted upon. The City ... elements found in your event. The Citywide Process provides a coordinated approach to the planning, review, and on-site management of your event. The permit process begins when you submit your permit ... The city recognizes that the public has a legitimate interest in possessing information concerning special events, particularly as they directly relate to potential impacts of the event on the...

Ngày tải lên: 19/02/2014, 03:20

... building the personality, the dimension, the interconnection between your brand and the consumer, the greater the connection, the greater the bond, the greater the loyalty, the greater the sales, ... positioning promises. The customer’s perspective has got to be what THEY want. Whether they trust in their dealings with you, they trust in the construction of the product, they trust in the ... manufacturers in Beijing China. These are the notes of my talk, reformatted for you so that they are much easier to follow. The core of the speech centered around building, maintaining and sustaining...

Ngày tải lên: 14/03/2014, 19:20

... to the insurance limit, including principal and any accrued interest through the date of the closing. In most cases, the FDIC provides access to accounts on the next business day by arranging ... identity theft). The scammers are doing anything to make their mailings look authentic, even including fake signatures of FDIC officials,” said Matthew Alessandrino, the FDIC’s Assistant Inspector ... institution to assume the insured deposits. The account owners can then decide whether to remain as customers of the other bank or move their money elsewhere. If the FDIC cannot find another...

Ngày tải lên: 15/03/2014, 10:20

... 33. Plaintiffs possessed adequate income and assets and had adequate cr~dit history to qualify for the loans requested, the value and/or the e~ity they had in their properties were sufficient to support the loans, and Defendant was aware of those facts. 34. Defendant's discrimination against Plaintiffs was intentional and willful. WHEREFORE, each Plaintiff asks jUdgment against Defendant for: (a) Actual damages in an amount to be proved at trial; (b) Compensatory damages in an amount to be proved at trial; (c) Punitive damages, not exceeding the lesser of $500,000 or one per centum of the net worth of the Defendant; (d) Appropriate injunctive relief; (e) Reasonable attorneys' fees·and costs of suit; and (f) Further relief as this court deems just and proper. COUNT II FAIR HOUSING ACT 35. Plaintiffs adopt and reallege ~~ 1 through 28 of this Complaint and incorporate them by reference as ~ 35 of Count II. 36. This claim is brought under the Fair Housing Act, 42 U.S.C. §§ 3601, et ~ section 3613(a) (1) (A) of this Act allows a civil action to be brought by any person damaged. under the Act. sections 3605(a) and (b) (1) provides that it shall be unlawful for any person or entity whose business includes engaging in residential real-estate-related transactions to 8 JURISDICTION AND VENUE 2. Jurisdiction of this court arises under 28 U.S.C. § 1343(a) (4), 42 U.S.C. § 3613(a) (1) (A) and 15 U.S.C. § 1691e(f). 3. Venue is proper in the Northern District of Illinois since some of the acts and transactions complained of occurred in this district. THE PARTIES 4. Plaintiff Selma S. Buycks-Roberson is an African- American citizen of the united States who resides in Broadview, Illinois. 5. Plaintiff Renee Brooks is an African-American citizen of the united States who resides in Chicago, Illinois. 6. Plaintiff Calvin R. Roberson is an African-American citizen of the united States who resides in Chicago, Illinois. 7. Defendant citibank is a federal savings bank that offers residential mortgage loans ("home loans") . CLASS ACTIONS ALLEGATIONS 8. (a) Plaintiffs are citibank home loan applicants; they bring this action on behalf of themselves and all other African- American home loan applicants similarly situated. This action is brought as a class action pursuant to Rule 23(b) (2) and Rule 23(b) (3) of the Federal Rules of Civil Procedure. (b) The class consists of all African-Americans who filed applications for home loans to citibank and were rejected on or after July 6, 1992 because they are African-American and/or 2 § 1691(a); and (iii) whether Plaintiffs are entitled to an award of actual, compensatory or punitive damages. (f) The wrongful conduct alleged herein has been taken generally against all members of the class in that African- American home loan applicants have had their loan applications rejected on the basis of their race or color, or because of the racial composition of the neighborhoods in which their properties were located, or both, pursuant to the policies, practices or procedures of Defendant. (g) The common questions of fact and law predominate over questions affecting only individual class members. (h) A class action is superior to other available methods for the fair and efficient adjudication of the controversy in that: (i) a mUltiplicity of suits with consequent burden on the courts and Defendant should be avoided; and (ii) it would be unduly burdensome for all class members to intervene as parties-plaintiffs in this action. THE FACTS Ms. Buycks-Roberson 9. On or about April 4, 1992, Plaintiff Selma Buycks- Roberson applied for a home loan of approximately $43,700 from citibank. 10. The purpose of the loan was to refinance an existing mortgage of approximately $43,500 on Ms. Buycks-Roberson's home, located at 2057 South 25th Avenue in Broadview, Illinois. 11. The property that Ms. Buycks-Roberson attempted to refinance is located in a neighborhood in which the African- 4 because the racial composition of the neighborhoods in which their properties were located was predominantly African-American. (c) The class is so numerous that joinder of all persons is impracticable. Plaintiffs are informed and believe that many home loan applications to Defendant by African- Americans were illegally rejected. On information and belief, Defendant rejected the home loan applications of many dozens of African-American applicants because of their race or color, and/or because of the racial composition of the neighborhoods in which their properties were located. (d) Plaintiffs will fairly and adequately protect the interests of all class members, as they are members of the class and their claims are typical of the claims of all class members. Plaintiffs are incensed by the treatment they have received and will aggressively pursue their as well as the class's interests. Plaintiffs' interests in obtaining injunctive relief and monetary damages for the violations of the above-mentioned federal statutes are consistent with and not antagonistic to those of any person within the class. (e) The common questions of law and fact include: (i) whether Defendant had a policy, practice or procedure to reject home loan applications on the basis of the applicants' race or on the basis of the racial composition of the neighborhoods in which their properties were located; (ii) whether the conduct alleged herein is in violation of Title 42 U.S.C. §§ 1981 and 1982; 42 U.S.C. § 3605 and 15 U.S.C. 3 43. Because of the Defendant's malicious refusal to deal with Plaintiffs and its policy of· discrimination against Plaintiffs because of race or color, Plaintiffs claim punitive or exemplary damages. WHEREFORE, Plaintiffs ask jUdgment against Defendant for: (a) Actual damages in an amount to be proved at trial; (b) Compensatory damages in an amount to be proved at trial; (c) Punitive damages; (d) Appropriate injunctive relief; (e) Reasonable attorneys' fees and costs of suit; and (f) Further relief as this Court deems just and proper. SELMA S. BUYCKS-ROBERSON; ... 33. Plaintiffs possessed adequate income and assets and had adequate cr~dit history to qualify for the loans requested, the value and/or the e~ity they had in their properties were sufficient to support the loans, and Defendant was aware of those facts. 34. Defendant's discrimination against Plaintiffs was intentional and willful. WHEREFORE, each Plaintiff asks jUdgment against Defendant for: (a) Actual damages in an amount to be proved at trial; (b) Compensatory damages in an amount to be proved at trial; (c) Punitive damages, not exceeding the lesser of $500,000 or one per centum of the net worth of the Defendant; (d) Appropriate injunctive relief; (e) Reasonable attorneys' fees·and costs of suit; and (f) Further relief as this court deems just and proper. COUNT II FAIR HOUSING ACT 35. Plaintiffs adopt and reallege ~~ 1 through 28 of this Complaint and incorporate them by reference as ~ 35 of Count II. 36. This claim is brought under the Fair Housing Act, 42 U.S.C. §§ 3601, et ~ section 3613(a) (1) (A) of this Act allows a civil action to be brought by any person damaged. under the Act. sections 3605(a) and (b) (1) provides that it shall be unlawful for any person or entity whose business includes engaging in residential real-estate-related transactions to 8 JURISDICTION AND VENUE 2. Jurisdiction of this court arises under 28 U.S.C. § 1343(a) (4), 42 U.S.C. § 3613(a) (1) (A) and 15 U.S.C. § 1691e(f). 3. Venue is proper in the Northern District of Illinois since some of the acts and transactions complained of occurred in this district. THE PARTIES 4. Plaintiff Selma S. Buycks-Roberson is an African- American citizen of the united States who resides in Broadview, Illinois. 5. Plaintiff Renee Brooks is an African-American citizen of the united States who resides in Chicago, Illinois. 6. Plaintiff Calvin R. Roberson is an African-American citizen of the united States who resides in Chicago, Illinois. 7. Defendant citibank is a federal savings bank that offers residential mortgage loans ("home loans") . CLASS ACTIONS ALLEGATIONS 8. (a) Plaintiffs are citibank home loan applicants; they bring this action on behalf of themselves and all other African- American home loan applicants similarly situated. This action is brought as a class action pursuant to Rule 23(b) (2) and Rule 23(b) (3) of the Federal Rules of Civil Procedure. (b) The class consists of all African-Americans who filed applications for home loans to citibank and were rejected on or after July 6, 1992 because they are African-American and/or 2 § 1691(a); and (iii) whether Plaintiffs are entitled to an award of actual, compensatory or punitive damages. (f) The wrongful conduct alleged herein has been taken generally against all members of the class in that African- American home loan applicants have had their loan applications rejected on the basis of their race or color, or because of the racial composition of the neighborhoods in which their properties were located, or both, pursuant to the policies, practices or procedures of Defendant. (g) The common questions of fact and law predominate over questions affecting only individual class members. (h) A class action is superior to other available methods for the fair and efficient adjudication of the controversy in that: (i) a mUltiplicity of suits with consequent burden on the courts and Defendant should be avoided; and (ii) it would be unduly burdensome for all class members to intervene as parties-plaintiffs in this action. THE FACTS Ms. Buycks-Roberson 9. On or about April 4, 1992, Plaintiff Selma Buycks- Roberson applied for a home loan of approximately $43,700 from citibank. 10. The purpose of the loan was to refinance an existing mortgage of approximately $43,500 on Ms. Buycks-Roberson's home, located at 2057 South 25th Avenue in Broadview, Illinois. 11. The property that Ms. Buycks-Roberson attempted to refinance is located in a neighborhood in which the African- 4 because the racial composition of the neighborhoods in which their properties were located was predominantly African-American. (c) The class is so numerous that joinder of all persons is impracticable. Plaintiffs are informed and believe that many home loan applications to Defendant by African- Americans were illegally rejected. On information and belief, Defendant rejected the home loan applications of many dozens of African-American applicants because of their race or color, and/or because of the racial composition of the neighborhoods in which their properties were located. (d) Plaintiffs will fairly and adequately protect the interests of all class members, as they are members of the class and their claims are typical of the claims of all class members. Plaintiffs are incensed by the treatment they have received and will aggressively pursue their as well as the class's interests. Plaintiffs' interests in obtaining injunctive relief and monetary damages for the violations of the above-mentioned federal statutes are consistent with and not antagonistic to those of any person within the class. (e) The common questions of law and fact include: (i) whether Defendant had a policy, practice or procedure to reject home loan applications on the basis of the applicants' race or on the basis of the racial composition of the neighborhoods in which their properties were located; (ii) whether the conduct alleged herein is in violation of Title 42 U.S.C. §§ 1981 and 1982; 42 U.S.C. § 3605 and 15 U.S.C. 3 43. Because of the Defendant's malicious refusal to deal with Plaintiffs and its policy of· discrimination against Plaintiffs because of race or color, Plaintiffs claim punitive or exemplary damages. WHEREFORE, Plaintiffs ask jUdgment against Defendant for: (a) Actual damages in an amount to be proved at trial; (b) Compensatory damages in an amount to be proved at trial; (c) Punitive damages; (d) Appropriate injunctive relief; (e) Reasonable attorneys' fees and costs of suit; and (f) Further relief as this Court deems just and proper. SELMA S. BUYCKS-ROBERSON; ... 33. Plaintiffs possessed adequate income and assets and had adequate cr~dit history to qualify for the loans requested, the value and/or the e~ity they had in their properties were sufficient to support the loans, and Defendant was aware of those facts. 34. Defendant's discrimination against Plaintiffs was intentional and willful. WHEREFORE, each Plaintiff asks jUdgment against Defendant for: (a) Actual damages in an amount to be proved at trial; (b) Compensatory damages in an amount to be proved at trial; (c) Punitive damages, not exceeding the lesser of $500,000 or one per centum of the net worth of the Defendant; (d) Appropriate injunctive relief; (e) Reasonable attorneys' fees·and costs of suit; and (f) Further relief as this court deems just and proper. COUNT II FAIR HOUSING ACT 35. Plaintiffs adopt and reallege ~~ 1 through 28 of this Complaint and incorporate them by reference as ~ 35 of Count II. 36. This claim is brought under the Fair Housing Act, 42 U.S.C. §§ 3601, et ~ section 3613(a) (1) (A) of this Act allows a civil action to be brought by any person damaged. under the Act. sections 3605(a) and (b) (1) provides that it shall be unlawful for any person or entity whose business includes engaging in residential real-estate-related transactions to 8 JURISDICTION AND VENUE 2. Jurisdiction of this court arises under 28 U.S.C. § 1343(a) (4), 42 U.S.C. § 3613(a) (1) (A) and 15 U.S.C. § 1691e(f). 3. Venue is proper in the Northern District of Illinois since some of the acts and transactions complained of occurred in this district. THE PARTIES 4. Plaintiff Selma S. Buycks-Roberson is an African- American citizen of the united States who resides in Broadview, Illinois. 5. Plaintiff Renee Brooks is an African-American citizen of the united States who resides in Chicago, Illinois. 6. Plaintiff Calvin R. Roberson is an African-American citizen of the united States who resides in Chicago, Illinois. 7. Defendant citibank is a federal savings bank that offers residential mortgage loans ("home loans") . CLASS ACTIONS ALLEGATIONS 8. (a) Plaintiffs are citibank home loan applicants; they bring this action on behalf of themselves and all other African- American home loan applicants similarly situated. This action is brought as a class action pursuant to Rule 23(b) (2) and Rule 23(b) (3) of the Federal Rules of Civil Procedure. (b) The class consists of all African-Americans who filed applications for home loans to citibank and were rejected on or after July 6, 1992 because they are African-American and/or 2 § 1691(a); and (iii) whether Plaintiffs are entitled to an award of actual, compensatory or punitive damages. (f) The wrongful conduct alleged herein has been taken generally against all members of the class in that African- American home loan applicants have had their loan applications rejected on the basis of their race or color, or because of the racial composition of the neighborhoods in which their properties were located, or both, pursuant to the policies, practices or procedures of Defendant. (g) The common questions of fact and law predominate over questions affecting only individual class members. (h) A class action is superior to other available methods for the fair and efficient adjudication of the controversy in that: (i) a mUltiplicity of suits with consequent burden on the courts and Defendant should be avoided; and (ii) it would be unduly burdensome for all class members to intervene as parties-plaintiffs in this action. THE FACTS Ms. Buycks-Roberson 9. On or about April 4, 1992, Plaintiff Selma Buycks- Roberson applied for a home loan of approximately $43,700 from citibank. 10. The purpose of the loan was to refinance an existing mortgage of approximately $43,500 on Ms. Buycks-Roberson's home, located at 2057 South 25th Avenue in Broadview, Illinois. 11. The property that Ms. Buycks-Roberson attempted to refinance is located in a neighborhood in which the African- 4 because the racial composition of the neighborhoods in which their properties were located was predominantly African-American. (c) The class is so numerous that joinder of all persons is impracticable. Plaintiffs are informed and believe that many home loan applications to Defendant by African- Americans were illegally rejected. On information and belief, Defendant rejected the home loan applications of many dozens of African-American applicants because of their race or color, and/or because of the racial composition of the neighborhoods in which their properties were located. (d) Plaintiffs will fairly and adequately protect the interests of all class members, as they are members of the class and their claims are typical of the claims of all class members. Plaintiffs are incensed by the treatment they have received and will aggressively pursue their as well as the class's interests. Plaintiffs' interests in obtaining injunctive relief and monetary damages for the violations of the above-mentioned federal statutes are consistent with and not antagonistic to those of any person within the class. (e) The common questions of law and fact include: (i) whether Defendant had a policy, practice or procedure to reject home loan applications on the basis of the applicants' race or on the basis of the racial composition of the neighborhoods in which their properties were located; (ii) whether the conduct alleged herein is in violation of Title 42 U.S.C. §§ 1981 and 1982; 42 U.S.C. § 3605 and 15 U.S.C. 3 43. Because of the Defendant's malicious refusal to deal with Plaintiffs and its policy of· discrimination against Plaintiffs because of race or color, Plaintiffs claim punitive or exemplary damages. WHEREFORE, Plaintiffs ask jUdgment against Defendant for: (a) Actual damages in an amount to be proved at trial; (b) Compensatory damages in an amount to be proved at trial; (c) Punitive damages; (d) Appropriate injunctive relief; (e) Reasonable attorneys' fees and costs of suit; and (f) Further relief as this Court deems just and proper. SELMA S. BUYCKS-ROBERSON;...

Ngày tải lên: 15/03/2014, 10:20

... be the subject of appeals in the near future. The Supreme Court in Janus did reaffirm the viability of its decision in Stoneridge, by finding “no reason to treat participating in the drafting ... contributed to the creation of the misstatements, regarding their management of a Schwab fund. 21 In the court s original order on June 6, 2011, the court found that the SEC’s complaint adequately ... control over the content of the message, the underlying subject matter of the message, and the ultimate decision of whether to communicate the message.” 8 Conversely, another court in the same...

Ngày tải lên: 30/03/2014, 14:20

... through, they must pay the owner for the interest according to the price and terms in the agreement. Keep in mind that, if the company or the nontransferring owners buy the interest, the transferring ... owners the right to purchase the transferring owner’s interest at the price the proposed buyer is willing to pay (assuming the interest is being sold, not gifted). In other words, the company and the ... ei- ther the company or the continuing owners can buy an owner’s interest to stop the transfer of an owner’s interest. In the case of a corporation, if the corporate entity, rather than the continuing...

Ngày tải lên: 18/04/2014, 14:03

... Mary from remaining in the home payment free until they receive an official, written eviction notice. In fact, they are doing their neighbors, and the lender, a favor by maintaining the property ... scams.• The book also explains how to make the most of your situation if your income and mortgage payments preclude keeping your house. It explains: how long you’ll be able to stay in your house—and ... foreclosure complaint that the lender has filed in the local court. They have 30 days to respond. They visit a lawyer, who tells them they may be able to put off the foreclosure sale by filing a response...

Ngày tải lên: 18/04/2014, 14:12

... equity in your house and the home value curve in your community is trending up rather than down. On the other hand, the Housing and Economic Recovery Act of 2008 provides massive funding for the ... one of the strategies explained in later chapters. Whether or not your foreclosure will go through court. • In fewer than half the states, foreclosures go through court; in the others, your ... sold in 21 days. In some other states, the lender may accelerate the loan as soon as you fall behind in your payments, and the law does CHAPTER 1 | FORECLOSURE: THE BIG PICTURE | 7 4 Negotiating...

Ngày tải lên: 18/04/2014, 14:14

Ngày tải lên: 12/05/2014, 16:39