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Comics Porns – 37 Monsters (RAPED) 13-year-old Virgin Girl
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Comics have been around since the 1800s and have influenced the world in many different ways. They have a special place in the hearts of many people, including those in the adult entertainment industry, who have taken to the pages of comics to express their desires. In recent years, comics have become more of a mainstream medium, with more people reading them. This has led to the development of the comics porn industry. This is not to say that comics have only been used for porn, but it does mean that more people are using them to make their fantasies come true.
Porn comics are a type of comic book that focuses on pornographic themes and typically features depictions of sexual intercourse. The term "porn comic" is sometimes used to refer to pornographic comic books in general, but the term is most often used to refer to the erotic comics from the United Kingdom, which are noted for their erotic content.
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What are Porn Comics?
Porn comics are a type of comic strip that features pornographic content. They are usually drawn to appeal to the male audience, often depicting the female in sexual positions such as being taken from behind. This comic is a brief history of the porn comic genre.
Porn comics are comics that are created by artists who have the explicit purpose of portraying sex in a comic. A lot of them contain pictures and words that are not appropriate for children, and some even include violence. They are usually sold online and on sites like Sex Comics and nhentai, but they can also be bought online on websites like Amazon.com or Ebay.com.
Porn comics are a type of comic book that is used primarily for pornographic purposes. They are also known as "adult comics" or "hentai comics". It is a medium that is designed to be read by both men and women.
What is the History of Porn Comics?
1. The Origins of Porn Comics
Porn comics were developed in the early 1900s. This began with the publication of the first pornographic comic, "Yankie" in the New York World. The word "porn" comes from the word "pornography" which means "writing, pictures, or pictures of prostitutes." The first pornographic comic was designed to teach sex education to children. This was the start of the pornographic comic industry and the publication of pornographic comics. In the beginning, the comics were distributed in small numbers for personal use and not for public distribution. However, in the 1960s, the pornographic comic industry became more widespread and was distributed to a larger audience.
2. The Evolution of Porn Comics
Porn comics have been around for a long time. They have been around since the 1800s and have evolved a lot since then. The first porn comic was called "The Pearl" and was published in 1867. The comic was about a man and his wife. The comic was published in France and was written by a man named Charles Louis Philippe. It was the first comic ever to be published and it had a big impact on the world of porn comics. It was a big success and it became the first comic ever to be translated into other languages. It was also the first porn comic to be published in the United States. Today, the comic is seen as a classic and is still popular.
3. The Modern Day Porn Comic
Porn comics first appeared in the 1930s and 1940s, but there is no exact date for when they first started. The first comic book to show nudity was in 1938 and included a woman taking a bath. This was a story called "The Naked Lady." It was a satirical story about a woman who takes a bath and gets surprised by her husband. The story was meant to mock the prudishness of the time. It was not the first comic with nudity in it. The first comic with nudity was called "The Adventures of Sham-Fu." It was created in 1934 and was about a Chinese man who had to fight crime in a Chinese martial arts style. He fought to avenge his mother's death.
4. Conclusion.
Porn comics can be traced back to the 1800s in France and Italy. In the late 1800s, porn comics began to be popular in newspapers. However, the first porn comic that was published in America was in 1938. It was an erotic comic that was published in a magazine called "Pulps." The first erotic comic that was published in America was called "The Red Light Girl."
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What happened to ComicsPorns.com?
The original website of comicsporns.com, was launched in 2006. The site was created by a group of artists and writers who wanted to share their passion for comic books and porn. They were the first to bring together the two worlds and it became an instant hit. However, in 2020, the website was taken down due to legal issues and copyright infringement.
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Review: CAROUSEL
When you walk into a Spiegeltent and Post Modern Jukebox is playing, you know you're in for a swinging good time. Tease Industries first production outside of the Perth International Burlesque festival is in tandem with Sugar Blue and has set the bar high for itself. The big guns have arrived in the form of Bombshell Academy Headmistress and internationally acclaimed performer Lila Luxx, herself the ultimate showgirl who joined the group in two group numbers as well as her own mesmerizing Light Box act. I was looking forward to this show after seeing what a success the festival was this year.
All of the acts were a grouping of performances of either Penelope Pop and The Sugar Duchess, bringing the cute and sassy sex appeal to their acts, or Tipsy Twosome Fifi Fontaine and Lulu Liqueur bring the sex appeal and smouldering. This is smart because you can easily see the rapport onstage between these two sets of performers onstage. These duets were the sweet filling of the show, bringing the Showgirl sweetness which we all crave at these shows. Favourites from each set include Penelope and Sugar's "Cream" act and the "Gimmie More" show given by Fifi and Lulu with MC Veronica Jean Jones.
There were other supporting cast members in Mia Matthiessen singing all the accompaniment for the performers except for the "Gimmie More" act. I always love seeing live accompaniment to acts and the more ways it can be included in modern Burlesque the better. Bobbie Sox was resident showboy on duty, bringing his suave swing dance technique to the stage, and was the meat in the cutest "Fuzzy Follies" routine with Penelope and Sugar. There are few routines I could watch again easily, this is definitely one of them. MC for the evening was Veronica Jean Jones, a drag queen with my favourite type of mouth: Filthy. However, some of her setups fell flat on the audience, including a lisp joke which you could tell the audience felt uncomfortable listening to.
This show was a great representation of what traditional styled performance can be in modern Burlesque. It can be cute and campy, without necessarily being chaste. However the shows name is "Carousel", in part because of it being marketed as a tribute to Ziegfeld Follies and the idolization and reverence given in Burlesque to them. This is always a winning idea, but I felt this show was more a tribute to Crazy Horse and their iconic work rather than the ideal of the historically classic American Showgirl. I would have loved to have seen more acts that focused on those who became icons because of Ziegfeld, such as Faith Bacon (the first fan dancer in Burlesque), Lucille Ball, Fanny Brice (made famous by Barbara Streisand in Funny Girl) and Billie Burke (who later become Glinda the Good Witch in the Wizard of Oz), even parody of what a womaniser Ziegfeld was would have been a good juxtaposition in our modern burlesque that rails against shitty behaviour by successful men. But I am also looking at this in a literal sense. The modern showgirl is a completely different behemoth compared to Ziegfelds ideal.
For a first attempt by Tease Industries, this is a high quality show that just needs a little direction to bring it back to focus. Stay tuned to the Tease, because I suspect we're going to have more great work coming from this production house in the future, and I for one look forward to it.

subset: commoncrawl


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All not-for-profit applicants must now pre-qualify on the NYS Grants Reform website at grantsreform.ny.gov/grantees in order to apply for certain New York State grant solicitations. Potential not-for-profit applicants are strongly encouraged to begin the process of registering and prequalifying immediately, as this is a lengthy process.
New York State Energy Research and Development Authority
The New York State Energy Research and Development Authority (NYSERDA) seeks proposals for the development and implementation of educational training programs in energy efficiency (EE), renewable energy (RE), and advanced technology (AT) for high school students. Proposers will be asked to develop and implement programs that prepare students for careers and/or post-secondary education, with a focus on Science, Technology, Engineering, and Mathematics (STEM) skills. Programs should deliver appropriate, high school-level content in EE, RE and/or AT; provide opportunities for students to acquire college credits, industry certifications, job experience, or other career-focused experiences; and, where appropriate, use non-traditional approaches to teaching and learning, such as multidisciplinary instruction and project-based learning to help students explore real-world problems and issues.
- Public, parochial or proprietary school districts, departments of education or BOCES accredited by the NYS Education Department;
- Have NYS licensed and certified teaching staff committed to this project with documented experience in curriculum development and teaching in energy, science, technology, engineering, mathematics, career preparation, and/or related areas;
- Possess experience integrating new material into existing curricula and/or developing new stand-alone curricular materials meeting local and NYS Department of Education standards for use in the secondary school;
- Demonstrate connections to New York State-registered apprenticeship or pre-apprenticeship programs, community colleges or four-year schools;
- Demonstrate plans to engage business and industry partners and professional organizations; and
- Establish or demonstrate a relationship with the NYS Department of Labor Career Centers.
Funding: $1,750,000 is available. NYSERDA anticipates awarding approximately eight to 15 contracts, with a maximum award of $200,000 per contract.
Deadline: March 26, 2014
Contact: Debora Moran
Program Opportunity Notice
2664 Round 2
NYS Energy Research and Development Authority
17 Columbia Circle
Albany, NY 12203-6399
Phone: (518) 862-1090 ext. 3488
Email: email@example.com
Website: www.nyserda.ny.gov/Funding-Opportunities/Current-Funding-Opportunities/PON-2664-Clean-Energy-Training-for-High-School-Students.aspx


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Aesthetically, it wasn't pretty last night, and Atlanta played a playoff-style road game — meaning, they were more than content to keep it choppy and ugly — but the Capitals remained patient, received solid if unspectacular netminding from Semyon Varlamov, and eventually wore the Thrashers down enough to get them to succumb. It seemed perfectly scripted that Matt Bradley would provide the game-winner in such a slogging. But for us, there was one standout moment from last night, and it was uglier than the hockey itself:
If that isn't targeting the head, what is?
"I just came in on the forecheck," the assailant said afterward. "I thought I had a pretty good angle. I haven't seen him play, but he's a skilled good lateral movement player. If anything, I just tried to reach out and get a piece of him."
Oh, Armstrong reached out and got a piece of him alright.
"I was going to go right through him. I think he kind of bailed on the hit a little bit. I didn't mean to get my arms up into his neck or anything like that. [I just did] I saw the replay and I just tried to get a piece of him as he came by me. It's just one of those plays."
Yea, just one of those plays . . . that keeps on plaguing our game.
"I didn't mean to do that."
Armstrong should be suspended — most especially by the criteria which has been applied to suspensions of Capitals' players this season for hits up high.
- Mathieu Perreault recovered from Armstrong's attack and, while he didn't register a point, he played a third consecutive effective and reliable game of his most recent stint last night. More and more he is offering Bruce Boudreau reliable and disciplined shifts, and more and more he's staking a case to be, perhaps, just perhaps, yet another addition to the postseason roster. Not only did he look more comfortable on the ice last night, he appeared to have some chemistry with Alexander Semin. After the game he said it was hard to get into the flow of the game because of the whistles, but he did say he believed that Semin and he had something brewing.
- Of the blow to the head he suffered from Assailant Armstrong: "I was trying to make a play and I saw him at the last second, he had his elbow pretty high, I think," the young center said. "[At the] last second, I tried to turn but he kinda got me in the head, I got a bit of a headache." He told us that he thought it should have been a penalty and that he thought it was an elbow. Not only did he take the cheap shot high from Armstrong, but he said he got cut with a high stick on the very next shift. The fact he came back for the third period with five more shifts and another four minutes of ice time shows he is one tough little bugger and has a lot of heart and grit. Small wonder he's become a conspicuous fan favorite.
- Gabby had no comment on the officiating, but we're sure he'll be waiting to see where the NHL Wheel of Justice will come down on this one.
- Last night's effort from Semyon Varlamov doesn't make things any easier for Boudreau. If this is the real Varly, the one we saw last spring, then Boudreau would be foolish not to start him and see what else he has. For Boudreau, Varly laying an egg last night would have forced him to stick with Jose Theodore down the stretch, since he has had the better second half. Instead, he now has to give Varly another shot. If he does well in his next start, then Gabby has a real pickle on his hands, you have to think. Whoever earns the start against the Penguins come Tuesday night, you would think, will offer us a strong clue as to whom the ehad coach is leaning toward with the postseason in mind.
- Teams that win Stanley Cups usually have strong and vocal veterans. Mike Knuble qualifies. He is extremely thoughtful and knowledgeable about hockey and what it takes for a good team to succeed in the postseason. Last night he again offered us interesting observations about leading questions of the day. We asked him about Varly. While many guys would be happy to have one great goalie, Knuble noted, "You can't have one guy with all of the confidence and the other guy with none." A good and interesting point.
- Alexander Semin certainly appears locked in and ready for the playoffs. Despite not earning a point last night, he made some fantastic plays, moved fast and effectively all over the ice, and made presence known. His puck control was exceptional again, and last night was the first time in five games he didn't record a point. Despite not scoring he still ended up +1. While the other Alex is struggling a bit, Semin's offense and renewed energy, or interest, is certainly a boost for the team.


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Breathing for Stress Relief
Mind precedes all mental states.
Mind is their chief; they are all mind-wrought.
– The Dhammapada
If you cannot breathe correctly you cannot control your mind, so how could you develop even the most rudimentary internal skills if your mind is not subservient to your intentions. The first key is learning to breathe correctly. Breathing is the one thing we all do naturally, however just because we take in air and expel air does not mean we are making use of this powerful energy component for health, longevity, and power.
To have these things we must make correct breathing our natural way. Breathing properly will greatly enhance the health potential of all internal martial art and health practices. There are many forms of breathing practiced in Indian and Daoist yoga, meditation and other disciplines that focus on particular results. The following practice should, in my view, be the first method learned by anyone to help relieve stress and bolster the immune system in meditation practice and during martial arts training.
The Natural Breath – Tian-Bixi (天鼻息)
I am talking about what is known in Daoist Yoga (Daoyin) as natural breathing (Tian-Bixi), Post Natal Breathing, or Diaphragmatic Breathing. Detailed studied worldwide conclude that diaphragmatic breathing can reduce stress-induced hypertension it also increases oxygenation to all cells of the body and augments our immune system response. This method does not have to be a part of meditation practice although it can be the very foundation of sound training in Zen or Daoist practices. Tian-Bixi can be practiced as a simple exercise in breathing trained until it becomes the way you naturally breathe twenty-four hours a day seven days a week. Before undertaking any other health or martial skills we should first perfect Tian-Bixi way as our normal breathing pattern.
Medical science has shown a direct correlation between stress and suppression of the immune system. As we experience higher levels of stress our immune system creates fewer antibodies and we become more susceptible to invasions of bacteria and viruses. Proper breathing also helps to increase vascular circulation. Learning to breathe correctly with Tian-Bixi as explained in this article you can obtain many benefits for your health and internal arts practice.
Tian-Bixi aids in supplying an adequate supply of oxygen to the bodies' cells. This is a major component in longevity and energy production. When there is not enough oxygen to supply the needs of your cells, you begin to feel tired and run-down. This tiredness may eventually lead to irritability or nervous tension. Your thoughts may become clouded and you may begin to suffer from lack of concentration and a loss of memory. This depleted oxygen condition leads to more tension and stress. As our system experiences stress energy is needed to combat it. Sound breathing practices that relax the body and mind are essential to developing energy, longevity and an enhanced immune system.
Training Tian-Bixi
When practicing meditation, standing practice (Zhan Zhuang) or internal martial arts for health, or just sitting quietly practicing the method. Your primary goal is working to make this breathing method the way your body breaths naturally all the time. To achieve this diligently practice the method every day for at least fifteen to twenty minutes mindfully for a period of no less than 21 days. Also after practice while going about your daily routine breathe this way as often as possible throughout the day. After a month or so of consistent practice, you should notice that you are breathing in this way without having to think about it.
Beginning Training
Tian-Bixi is also known as Post-Natal breathing because it is the way an infant breathes when first born. We continue to breathe this way after birth for a few months; however, as stress begins to invade our lives we use the diaphragm muscles less and less and eventually most of us become shallow chest breathers. We can reverse this process and perhaps as Lao Tzu, author of the Daodejing says, "return to the relaxed state of a newborn" if we practice diligently for 21 days.
It is best to begin sitting upright in a chair or on the floor. Later it can be trained during standing exercise. Start by taking a deep breath through the nose. Then slowly exhale all of the air in your lungs out of your mouth. Lean slightly forward and push the last of the air out. This is a cleansing breath to start with your lungs full of fresh air. Sit up and inhale normally.
Now inhale slowly, focus on your body, and feel the air passing through your nostrils. Follow it as it travels down your airways. Imagine the air sinking deeper into the lower abdomen down into the lower belly and filling the area often called the center point or lower field (Dantian). Experience the feeling of the abdominal and low back area expanding due to the upper diaphragm pressing downward. It is important to pay attention to these feelings.
Before you exhale pause for a second then exhale slowly through the mouth and notice your low back and abdomen contracting slightly as the air pours out of your mouth. Do not exhale completely, just enough to feel the emptiness in the lower abdominal area. Before you inhale again pause for a second and notice how the body feels now, what has changed from before when you were filled with air.
Begin again inhaling as before and experience the entire process of inhalation, slight pause, and exhalation followed by a slight pause. Continue in this way for some time concentrating on how it feels to breathe correctly. Be aware of the rhythmic expansion and contraction of the lower abdomen, sides, and back.
Also, notice how the body feels stable while sitting and breathing in this manner. It is important that you do not try to stop your thoughts. If your mind wanders gently bring it back to feeling your breath and the sensations caused by Post-Natal breathing.
Use this for your beginning training in standing meditation or sitting practice for at least 21 to 30 days. You should allow your mind and body time to adapt to the diaphragmatic breathing method replacing your previous breathing manner with Tian-Bixi as a natural habit.
Breathing and Forms Training
Tests show that the best results are obtained when the Internal martial arts student learns to breathe in a chosen manner independent of forms practice and then leaves that breathing to the automatic adjustment made by the brain as the need for oxygen increases and decreases during the exercise. Sports science shows that once the pattern of breathing is established it is best to let the body do it for us and not interfere." The respiratory center of the brain, which receives chemical, reflex, somatic and cerebral inputs, is a good computer in automatically regularizing the rate, depth, and pattern of respiration under various situations. Artificial regulation during physical exercise is not the best for health." – (Journal of American Medical Association 246:1967, 1981)
Some instructors recommend matching breathing with internal martial arts forms training. They claim that they are following the Daoist practice. But Daoist philosophy emphasizes inaction or non-interfere (Wuwei). There are however a few exceptions such as when using so-called reverse breathing (Fan Huxi) during the delivery of a powerful strike. For the most part, Taijiquan and other forms of internal practice for health should use the Tian-Bixi as the base and let the body regulate the rate of breathing. This is true natural breathing.


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Your Book Social Media Profile Awaits
In order for any independent author to make it to the best-sellers list, he or she will need at least five professionally written reviews of the published book. And nothing is more pleasing to an author than he or she reading the published reviews of their readers.
"Do you know that a succinct review of your book can boost your book-sales dramatically? In fact, that very review could be the reason you make it to the best-sellers' list."
If your book receives more than 20 positive reviews on Amazon, the book title would be automatically recommended to others browsing through the same category of titles your book belong to. And if the book receives more than 50 positive reviews, Amazon would list the title in its daily newsletter and recommend it to new readers who just completed a similar read.
Amazon has its own leaderboard of reviewers that receives credit for every book that they review, and you can view all of them from this link, https://www.amazon.com/review/top-reviewers. You may even write them directly and ask them to review your book via the email address that they provide you on their profile page.
The best way to have your book quickly review is to approach these reviewers via their email addresses and propose your book(s) to them for free in exchange for their honest review(s). It is important that you approach the right reviewer that would be interested in your book's genre, as others (who are not a fan of your genre) may consider your approach as an abuse.
We know how critical it is for authors to get their book reviewed, so we have stepped up to help our Indie Writers Support members with the quest. And with our compiled list of 1000s of reviewers, any one of our AUTHORS can receive up to 10 new reviews within the next month.
List of Amazon Book Reviewers by Genres
Audible audiobook Reviewers; http://indiewritersupport.com/page/audible-audiobook-reviewers
Barnes & Noble Book Reviewers; http://indiewritersupport.com/page/barnes-noble-book-reviewers
A full list of Independent Bookstores in the U.S.A Selling eReaders and eBooks; http://indiewritersupport.com/page/independent-bookstores-in-the-u-....
Good luck. These lists are accessible by logging into the Indie Writers Support network (www.indiewritersupport.com). Sign in at http://indiewritersupport.com/?xgi=5L8oWKMvg5p6f5.
Views: 1883
Do we have reviewers working for Indie Writers Support? I can sure use some reviews. Thank you. Linda


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Regions and Chapters
Find Your Chapter and Region
CUPA-HR has four regions. Each region has a board of directors that develops programming and works closely with the chapters in the region. A representative from each region board also serves on the CUPA-HR board of directors.
CUPA-HR has 41 chapters. Chapters are affiliated with the association, but operate independently. They also plan local meetings and seminars that take place throughout the year. Chapter events are open to all higher ed HR professionals, regardless of membership in the national organization.
To find a CUPA-HR chapter near you, click on your state in the interactive map below and select the link from the pop-up box.
Eastern Region | Midwest Region | Southern Region | Western Region
Interested in Forming a Chapter?
The association provides incorporation materials, bylaw templates and other forms of support for developing chapters. Contact CUPA-HR at 877-287-2474 or via email for more information.


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So I go away on a cruise for a week and the Supreme Court of the United States decides to put out a series of major decisions that shows the division among the justices and the deepening politicization of the Court. But this is not a Constitutional Law blog. If you want heady analysis about the meaning of the Affordable Healthcare Act decision or the Arizona Immigration Law decision go to my favorite ConLaw blog SCOTUSblog.com.
I just want to pipe in on something curious in the dissenting opinion of Scalia, Thomas, Alito and Kennedy. Throughout their dissenting opinion, they make reference to Judge Ginsburg's opinion. While that is not unusual, especially for this court which has lately taken to sniping at each other in their opinions, what is strange is that they refer to it as the dissent. In fact, they call it "the dissent" 15 times!
That's no typo. That kind of mistake would never make its way into a Supreme Court decision that gets reviewed by the judge's law clerks (who are all the tops of their Ivy League Law School classes) and then by the judges themselves to make sure they are painstakingly accurate. Then to do so on a decision that is as highly anticipated as this one was would never occur in error.
This "mistake" was done to send a message to the conservatives out there that Justice Roberts flipped side at the last minute. It tells the world that Ginsburg opinion was all set up to be the dissent, but when Roberts flipped, it became the concurring opinion instead. But it also tells the world that these justices are not from your father's Supreme Court. We are witnessing a highly personalized, fractured, politicized court that is not scared to let everyone know exactly where they stand and what is going on behind closed doors. In Judge Kagan's last few decision, she has openly derided the opinion of Judge Thomas. Alito and others have used harsh words to describe what they see as a court ruling based on "parental instincts" in a case involving juveniles being sentenced to life imprisonment, which I see as a direct dig against the female-heavy left side of the court. So this dissent issue is just the latest salvo in the political battle waging in what is supposed to be a non-partisan (ok at least, less-partisan) branch of our government.


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Last Updated on 11 September 2022 by Ray Plumlee
The importance of exercise isn't only reserved for youngsters and adults; it is equally important in the elderly too. Older adults who are more into physical activity and exercise find fewer health issues in them; they have better overall health, there are fewer immobility issues in them, and they have less health-related expenditure. Sadly, many older adults don't know how valuable these activities can be. Many of them aren't aware of the overall recommended activity plan for exercises like aerobic conditioning, muscle strengthening, flexibility, and balance training.
In this article, we will be covering the art of engaging older adults into physical activity and exercise and what benefits and the outcome it would bring.
What Benefits It Brings:
The benefits of physical activity are multiple in every one of us, however, in older adults, the idea of physical activity is to ensure decreased mortality rate, healthy physical and cognitive functioning with normal aging. The main focus of physical activity is to enhance strength, flexibility, mobility, and fitness, all of which correlate with:
• Improved daily functioning
• Enhanced independence
• Reduced risk of falls and fall-related injury
Moreover, exercise induces socializing and reduces mental issues, lessen the natural decline of aerobic capacity with age, muscle mass, strength, and the damaging effects of this phenomenon. Muscle loss is natural in older adults, but adopting physical activity can slow it down. Even aerobic activities can improve neuropsychiatric symptoms and cognition in patients with dementia.
In short, exercise and physical activity have got some potential even when it comes to older adults. So, it's better to start now than never.
Overview of Some Physical Activity Plan:
Healthcare providers are advised to recommend exercises that fall in any of the following four categories:
• Aerobic exercise
• Muscle strengthening
• Flexibility
• Balance
Aerobic Exercise:
Aerobic exercise focuses on the large muscle groups to strengthen and support organs like the heart and lungs so that the individual may get an improved utilization of oxygen. The exercises included in this category are; brisk walking, jogging, swimming, water aerobics, tennis, golf but with no cart, aerobic exercise classes, dancing, bicycle riding, cardio equipment like elliptical machines, stair climbing machines, stationary bicycles, and treadmills
Guidelines that should be followed prior to initiating aerobic exercise in older adults are:
• Activities are not necessarily confined to one time but can be divided across the day.
• If an intensive exercise plan cannot be achieved in an individual with chronic medical conditions, the better approach is to use exercises, like short walks. These exercises should not harm individuals.
Muscle Strengthening:
Muscle-strengthening comes in different activities like weight training, weight-bearing calisthenics, or resistance training. These activities progressively increase muscle strength and endurance – all that is required is a gradual increase in resistance with time.
However, there is some limitation when it comes to frail people because they cannot endure all the hard activities. The best approach is to adopt light exercises that a person can easily perform, like getting up from a chair, climbing stairs. The guidelines for frail adults, when muscle strengthening is recommended, are as follows:
• The weight should be maintained initially that a person can lift it for eight times without muscle fatigue. After that, maintain it up to the level of 10 to 15 times of lifting. Then again increase the weight such that a person can lift it for eight times. This gradual approach can bring positive results. The weight has to be decreased if a person fails to lift it eight times at first.
• Normal breathing is required while weight lifting, that is, exhaling when lifting or pulling elastic band.
• The movement mustn't be hurried, slow movement with repetition is necessary. Two to three seconds for lifting, one second to hold, and three to four seconds for coming down again.
• Joints mustn't be tightened or locked.
• Patients must be told they will have muscle soreness at first and is normal and lasts for a few weeks.
• For chronic pain, such activities should be recommended that shouldn't worsen the pain. In this case, a more gradual increase in muscle strengthening is required.
• Patients can also perform it at home using exercise equipment or homemade weights like soup cans, water bottles, or empty milk jugs having water or sand.
Flexibility is one of the best forms of training to maintain good physical health and to perform daily chores easily. It includes shoulder and upper arm stretches, calf stretches, and yoga.
Guidelines for flexibility training in older adults are:
• Plan flexibility training two times a week for 10 minutes.
• Stretching is effective when done after aerobic or strengthening activities as the body is warmed.
• Breathing should be normal during stretching exercises.
• There should be no bouncing in stretching.
• Stretching should be slowly and gradually. It is advised to hold the desired position for 10 to 30 seconds.
• A slight pull during stretching is normal but should not be on the verge of pain.
Balance Training:
Balance training is designed for people having a history of falling and immobility. It works by providing stability to avoid falls and fall-related injuries. Different researches have proved tai chi as the best training for improving balance and risk of falls.
Moreover, it targets gait patterns like heel-to-toe walking, basic movements using the center of gravity, and focusing the sensory systems for maintaining balance.
When the patient is at risk for falls, starting physical therapy would help improve strength and balance.
In short, enhancing physical activities in older adults with the help of different exercises may prove to be effective in maintaining strength and balance so that they may continue a healthy living. All that is required is to understand the underlying medical condition of the elderly and then plan accordingly.
I am chief medical resident doctor in Internal Medicine at a tertiary care hospital. I am also an author and editor at StatPearls publishing, a medical website with thousands of PubMed indexed articles and MCQs.


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A look at key developments in the Paris attacks investigation
PARIS – Police raided an apartment in suburban Paris as they searched for the suspected mastermind of last week's attacks that killed 129 people. Here are some of the key developments Wednesday:
POLICE RAID: Police swooped down on the Paris suburb of Saint-Denis in a pre-dawn raid of an apartment where they believed the mastermind of last week's attacks was holed up, but it was not clear Wednesday evening whether he had been inside. The seven-hour siege ended with two deaths and eight arrests. Paris prosecutor Francois Molins said Islamic State militant Abdelhamid Abaaoud was not among those arrested, but there was no immediate word if he was among the dead. Molins described the dead as a woman who blew herself up with an explosive vest and a man "who was hit by projectiles and grenades."
LIFE MUST GO ON: President Francois Hollande urged his countrymen to defy terrorists by going back to their normal way of life, visiting cafes, museums and sports stadiums, and not caving in to fear and xenophobia. In a speech following the police siege, Hollande proclaimed that France is "at war" with the Islamic State group, but warned against overreactions and said no anti-Muslim, anti-Semitic or xenophobic acts will be tolerated. In a speech to French mayors he stressed that "life must resume in full" and promised extra security to ensure that museums and popular tourist sites can reopen. "Our duty is to get on with our lives."
NAVAL BUILDUP: Britain said one of the Royal Navy's most advanced warships, the HMS Defender, will support a French aircraft carrier that is on its way to help operations against IS militants in Syria. Defense Secretary Michael Fallon said the British ship will provide air defense cover for the Charles de Gaulle carrier, which has left the French port city of Toulon.
ISLAMIC STATE REPEATS CLAIM: The Islamic State group again claimed responsibility for the attacks in Paris. In its English language magazine, the group said it will continue its violence and "retaliate with fire and bloodshed" for insults against the Prophet Muhammad and "the multitudes killed and injured in crusader airstrikes." The magazine also included a claim that the group killed a Chinese and a Norwegian hostage and photographs of the bomb that it said brought down a Russian airliner over Egypt's Sinai Peninsula on Oct. 31.
SOCCER SCHEDULE STANDS: European soccer body UEFA said all 40 Champions League and Europe League matches scheduled for next week will go ahead as planned, including Paris Saint-Germain's away match against Swedish club Malmo. France's sports secretary said French league games would also go ahead. France's national soccer stadium was among the targets in the attacks on Friday, leading to sporting events in Paris and other cities being canceled over the weekend. On Tuesday an exhibition match between Germany and the Netherlands was canceled and the stadium in Hannover, Germany, was evacuated because of a bomb threat.
MANHUNT FOR FUGITIVE: A Spanish security official said French authorities have sent out a bulletin to police across Europe asking them to watch out for a Citroen Xsara car that could be carrying Salah Abdeslam, a fugitive wanted in the Paris attacks. The official spoke on condition of anonymity because of department rules preventing the official from being named. The security official said the bulletin was sent to authorities across Europe, not only to Spain.
PAPAL SECURITY: Pope Francis' personal security detail was nearly doubled during his general audience, and military police were out in force as Italy and the Vatican beefed up security around the Holy See following the Paris attacks and ahead of Francis' big Jubilee Year starting Dec. 8. Italy is already planning to close the airspace over Rome during special Jubilee celebrations. Rome's prefect, Franco Gabrielli, said authorities were prepared to shoot down drones and ultralight aircraft if they violate the air space ban.
BAND MEMBERS 'HORRIFIED': Members of the band Eagles of Death Metal said they're home safe after the Paris attacks and "are horrified and still trying to come to terms with what happened." The U.S. band was to perform at the Bataclan concert hall in Paris last Friday when the deadly attacks occurred. Eighty-nine people were killed at the hall.


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The new ABC drama series MISSING follows a mother who finds out her son has been kidnapped while studying abroad. Fortunately, for her son, Becca Winstone is ex-CIA and nothing is going to stop her from finding her son and making the people responsible for his abduction pay. With two episodes having aired so far and eight more to go, MISSING is building into a fascinating mystery story as there seems to be more going on than a simple kidnapping. Somehow Becca's past with the agency may have provoked the events that are happening today. In a special exclusive interview, producer and writer Gregory Poirier shared a few key insights on what is upcoming on this intriguing series.
MISSING seems to be doing quite well right now, as the audience seems to be picking up on it for the 8 p.m. timeslot on Thursdays.
GREGORY: That's amazing because it's such a difficult time. Obviously, it is probably the toughest timeslot on television. But we've been very lucky that everyone found it.
It's a story that resonates, particularly as parents are concerned about their children traveling abroad these days. So it is very timely. Could you share how you got involved with this project?
GREGORY: I was lucky. I was approached by my co-executive producers, Gina Matthews and Grant Scharbo. Gina had this idea and she actually had thought it through quite a bit by the time she contacted me. She basically had the idea of this woman whose son disappears and she goes looking for him. She essentially had the entire first act of the pilot figured out by the time I came to meet her about it. That was great. As to what drew me to it? It really was the emotional story that's being told. It was not so much the opportunity to blow things up and run around Europe — although that's all great! But, for me, it was the family story, the emotional story that she had laid the groundwork for and that's what sucked me in.
For you, what was the best part about working on this series for the first season?
GREGORY: That's really hard to say. I mean, from a perspective of a writer, the greatest thing about it was the freedom. You have to spend more time with these characters. Because I've only done features in the past in which you have to take your characters throughout an entire arc or journey in an hour and a half, the idea of having all this extra time to deal with these characters was really appealing to me. It turned out to be one of the great joys from a writer's perspective. As a producer, just being able to travel around Europe and going to all these beautiful places and working with all these great people. I mean, our cast is amazing. We got people you just don't get for TV shows. So that was a real pleasure. There was no downside to this, I have to say. It was fun all the way through.
You did get a remarkable cast put together for this show. How did that happen? It was cool to see Ashley Judd's name associated with it, but then as you start watching the series, you think, "oh my gosh, I recognize a lot of film actors."
GREGORY: A lot of that is because of Ashley. Ashley was sort of the linchpin to this whole thing. She was honestly the piece we never thought we'd get. We always dreamed of getting Ashley for this. But she sort of has a reputation for turning everything down in television and we never really thought it would happen. Then when it did, it just opened up for the rest of it. Then you can talk to people like Sean Bean, Adriano Giannini, and Cliff Curtis and say, " Ashley's in it." That sort of changes the landscape 'cause all of a sudden everyone wants to be in it. But even our guest stars — like Joaquim de Almeida in Episode 2 — and with all kinds of amazing guest stars like Keith Carradine. It just really worked out well.
Since you brought up Keith Carradine, I am dying to know: Is Keith going to have an expanded storyline? He's had such minimal screentime so far. Is he going to play a larger part?
GREGORY: Yeah, it's so funny because we have a couple of great actors in the pilot that are in it for about 3 seconds. I was joking with Keith and he said, "Oh my god, people are going to look at that and think 'poor Keith Carradine, what's happened to his career to take a walk on part?'" and I said, "No, no, no. We're going tell people, 'That's all we can afford of Keith Carradine.'" The truth is we have a lot of Keith Carradine coming up. He just happened to just be layered in there in the pilot. He's an integral part of the show.
Another thing I'm curious about is we've only seen 2 episodes, and the third episode might be change point for this, but there seems to be a lack of strategy and a lot of reactionary stance as far as the story. Is there going to be a strategy developed to derail or trap these kidnappers?
GREGORY: Yes. It actually becomes much more [strategized]. It's reactionary all the way through in a sense that there's a mystery that she's trying to solve. It never becomes "Death Wish" where she's going around trying to kill everybody that took her kid. It remains a mystery, but it becomes much more active in the sense of her sort of taking the reins. In fact at the end of Episode 3 Becca gets a piece of information that really leads her somewhere in the mystery and she becomes much more active in chasing down the kidnappers.
It seems like that would be something vital for her — to stop just chasing the kidnappers and find a way to trap them.
GREGORY: Exactly. But I think there's an emotional shift she has to make. She has to sort of realize that. Giancarlo sort of said it to her in the second episode, "You have to stop thinking like a mom, and you have to start thinking like you're looking for another missing asset. That's the only way you're going to find him." I think it takes Becca awhile for her to really get to that point. But once she does, her search becomes more practical.
Is there something you can share about going to all these different European cities? Is it just a chase kind of thing, or is there actual meaning behind each city?
GREGORY: There is. Through the flashbacks you start to see that all these cities tie in with Becca's past. There are things that might have happened with her that led to this kidnapping in the present. So the cities become a part of that. We tried to make it so that while we are going around to all these different places, it's not just a travel log. We really wanted it to have a feel as to why we were in all these different places. That each stop we made had a story reason for being there as opposed to just being there.
Thus are the cities a clue in and of themselves?
GREGORY: Yeah, in some ways. Especially further down in the show. Obviously Becca went to Rome because that's where her son was and the trail led to Paris. But as the show starts to go on, Becca has more concrete reasons for each place that she goes.
Will the 10-year gap be explained if all these are things that are arising out of her past?
GREGORY: Definitely. We'll explain all that. I'd love to say. Obviously I can't answer all these questions, but by the end of this season, all your questions will be answered. It's not one of those shows where you'll get to the end and go, "Oh god, I don't know anymore now than I did before."
That's hopeful! Maybe you could tease a little bit about what's coming up for the next couple of episodes, "Ice Queen" and "Tell Me No Lies."
GREGORY: I can tell you that in "Ice Queen" — one of the cool things about "Ice Queen" is that it's an episode where we start to follow Michael's story, rather than just following Becca's. So we actually find out in Episode 3 — well, we don't know exactly where he is — but you see where he is, we see whose got him, and we see what he's going through on a daily basis as he tries to figure out all this too. So that's one of the coolest things about it. And I can tell you that in Episode 4 there is a major, major twist, which will sort of turning everything on its head that you think you might have figured out already.
We love those actually!
GREGORY: But I can't tell you what that is. [Laughter]
So what would you say are like little clues or visual things that people should pay attention to as they watch these episodes?
GREGORY: I would say pay attention to everything. Because we hide things in there that you may not even realize until you see it the second time or after the fact and you'll realize that's why that was in there. But there's little clues as to who has him and why in every single episode — and they're not even always things that Becca sees until later. But they are always there. I think it's one of those shows where you need to pay attention. I hate to say that about a TV show, but it's true.
With the tantalizing prospect of finding out what is really going on and what big twist lies ahead, be sure to tune in for MISSING on Thursday nights at 8:00 p.m. on ABC.
"Television Composer Kim Planert Talks The Magic of Composing for the New Series MISSING"
"Previewing the New Drama Series MISSING: A Spy Tale That Will Send Shivers Down Every Parent's Spine (with video interview with Adriano Giannini, Cliff Curtis and Nick Eversman)"
"Ashley Judd Previews Her Spectacular Role on MISSING"
Where to find this article:


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What Exactly Does Upside Down Mean in X Y?
A term with a meaning and is traditionally used at the research of math is that which does upside-down mean in mathematics.
You can find several questions that come into mind whenever we believe in what exactly does upside-down mean in mathematics, therefore let us start with considering some of these kinds.
Whenever you take a look at the photograph of the pub and also you also find it professional college essay writers down, what exactly does this imply? It means that if you turn the corner of this bar you may locate sides to be downward or you'll discover sides are coming down. Thus, in case you get in the pub and also turn the corner on the most suitable side, you may discover sides to be to the side, in the event you change the corner onto the left hand you will find the sides to be on your left.
The word"up side down" has a very different significance in the normal meaning of this word. It is really an abbreviation https://expert-writers.net/buy-essay for"inverse-square-law." This means that, when you rotate the bar, it is in an identical position because it had been in when it had been in its own placement. What exactly does this indicate?
To ensure it is clear, what does upside-down mean in math usually means with no to improve the place of the object you could change the management of rotation. This can be understood by looking at a soccer, for those who proceed it and also flip on the ball to the hand , it is likely to proceed at the same way before becoming flipped upside down down, as it failed again.
There is no foundation but a few of these nice things about using this type of mathematics is that it permits one to do the job. Additionally, http://users.wpi.edu/~jdp/downloads/automatic-essay-writer.html the language used from the language isn't entirely of a form that is rigid.
By way of instance, the words"upright"external" are commonly used but they do not link with Angular Momentum or Angular Velocity. If we attempt to employ them to things which have an angular pace afterward we receive words like up turn and turn that is .
You may discover that this exact helpful when coping with charts that are technical which deal with Angular Momentum or Angular Velocity. Don't forget that what exactly does upside me-an that you can rotate an object without changing its position.
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text: Wondering how many of you have a project car or are all your cars done. And since I got you here what Buick are you holding out for?. This year I said no to alot of new projects because I'm holding out for a convertible, a business coupe, or a 4 door flat top. What is your project car and goals?


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Tweetbot For Mac Alpha App Removed Due To New Twitter Rules
With Twitter's latest announcement, they've added a limit to the amount of users a third-party application can support. The limit allows up to 100,000 user tokens, anything beyond will have to be negotiated with Twitter.
Due to the changes, Tapbots has removed the download link to its Tweetbot for Mac Alpha application and released the following update to their blog:
As some of you may have already noticed the download link for the Tweetbot for Mac alpha no longer works. Twitter's latest API Changes means now we have a large but finite limit on the number of user tokens we can get for Tweetbot for Mac. We've been working with Twitter over the last few days to try to work around this limit for the duration of the beta but have been unable to come up with solution that was acceptable to them. Because of this we've decided its best for us to pull the alpha.
The full-list of Twitter third-party-access rules can be found on the Tapbots blog. They note "with the above rules being in place its easy to see why continuing the public alpha/beta would be problematic."
This can especially be a problem for Tapbots because if a user downloads Tweetbot and logs in, one token vanishes. If that user then decides to leave Tweetbot for whatever reason, the third party developers will never regain that token unless the user personally revokes it from Twitter.
Having launched in beta in early July, the application will no longer be out for beta testing. The company does note that Tweetbot will hit the Mac with a price tag in the near future though.


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Podcasting is like your own radio show only on-demand and without the expensive air time that traditional radio has. This show exists because of the idea that we can share our knowledge with others in an entertaining and engaging way. That's what a podcast is all about.
Join Ely with today's guest Scott Patton, Creator of the Power Podcast Course (over 1500 students strong), as they talk about why podcasting is such a powerful way to get your message out there and position yourself as an expert. It's drives, traffic, SEO, content marketing, expert status and networking all bundled into one amazing and fun tool that any of us can get into without an expensive setup.
In his first year Scott's podcast got over 375,000 subscribers and over 1 million downloads and she shares how you can get started with your own podcast as well!
In this show you'll discover:
- How to turn your car into a "University Of Wheels"
- What advantages podcasts have over other traditional media
- How to get started with your first show
- What you can do if you're not sure you have enough to say
- Why introverts are many times the best hosts
- And much, much more!
- Scott's Udemy Course ($147 course for only $19!)
- Power Podcast: Social Media Business Podcasting Success
- Sales Dogs by Blair Singer
Download This Episode:
- Episode 091 Driving Your Marketing – Scott Paton: "Power Podcasters" – How To Become The Expert With Your Own Show & Only 20 minutes"
Click Below To Subscribe To Driving Your Marketing:


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The Impact of the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 on the Family Law PractitionerJoeseph Schwartz & Kevin J. Larner
June 5, 2008 — 1,118 views
IntroductionThe Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 ("BAPCPA")1 was enacted on April 20, 2005, when it was signed into law by President George W. Bush. The enactment of BAPCPA brought to an end a turbulent decade-long legislative reform initiative, the end product of which represents "one of the most comprehensive overhauls of the Bankruptcy Code in more than twenty-five years." 2 This overhaul significantly changes consumer bankruptcy law by imposing many new requirements on debtors before bankruptcy relief will be granted. 3 Included within the changes resulting from the passage of BAPCPA are significant modifications to the manner in which bankruptcy law and family law interact. For the family law practitioner, knowledge of these changes is essential, due to the frequency with which family law and bankruptcy issues overlap. This paper will attempt to outline the major changes to the Bankruptcy Code that are associated with family law and particularly to how child support obligations are treated in bankruptcy, and will point out the many new issues that the family law practitioner will have to face as a result of BAPCPA's passage.
The list below briefly summarizes certain changes to the Bankruptcy Code that are most significant to a family law practitioner:
- § 101(14A) of the Bankruptcy Code is added to give a uniform definition of the term "domestic support obligation;"
- § 507(a)(1) of the Bankruptcy Code is amended to provide domestic support obligations a first priority claim among unsecured claims;
- § 362 of the Bankruptcy Code is amended to expand the scope of the exceptions to the automatic stay for domestic support obligations, to include within the exception income withholding orders, revocation of licenses, seizure of tax refunds and other common support collection techniques;
- § 523(a) of the Bankruptcy Code is amended to broaden the scope of domestic support related debts that are nondischargeable in a bankruptcy case;
- § 547(c)(7) of the Bankruptcy Code is amended to broaden the scope of prepetition payments on support debts that are not avoidable as preferences in a bankruptcy case; and
- The Bankruptcy Code is amended so that in order for a chapter 11 or a chapter 13 debtor to obtain a confirmation of his plan with the accompanying discharge, that debtor must be current on all support payments.
§ 101(14A): The Definition of Domestic Support ObligationsUnder the Amended Code, 4 a new term, "domestic support obligation," is used whenever the Bankruptcy Code affects alimony, maintenance or child support payments. Section 101(14A) has been added to the Amended Code, which defines a "domestic support obligation" as a debt that accrues before, on, or after the date of the order for relief5, and which includes interest that accrues pursuant to applicable nonbankruptcy law. 6 This definition broadens the scope of the obligations covered by the Bankruptcy Code, as it includes a debt owed to or recoverable by "(i) a spouse, former spouse, or child of the debtor, or such child's parent, legal guardian or responsible relative; or (ii) a governmental unit." 7
To qualify as a "domestic support obligation," the debt must be "in the nature of alimony, maintenance, or support (including assistance provided by a governmental unit) of such spouse, former spouse, or child of the debtor or such child's parent, without regard to whether such debt is expressly so designated." 8 It must be "established or subject to establishment before, on, or after the date of the order of relief" pursuant to: (i) a separation agreement, divorce decree, or property settlement agreement; (ii) an order of a court of record; or (iii) a determination made in accordance with applicable nonbankruptcy law by a governmental unit. 9 It does not apply to a debt assigned to a nongovernmental entity, unless it was assigned voluntarily by a spouse, former spouse, child or parent solely for the purpose of collecting the debt. 10
Prior to the implementation of BAPCPA, the Former Code defined these support-type obligations on a section-by-section basis, which led to some inconsistency throughout the Former Code. 11 Now, under the Amended Code and with BAPCPA's definition of "domestic support obligation," there will now likely be a uniform understanding of those family law debts and how those debts are dealt with under the Bankruptcy Code.
§ 507(a)(1): The Priority of Domestic Support ObligationsUnder the Amended Code, Section 507(a)(1) of the Bankruptcy Code is amended to accord first priority status to allowed unsecured claims for domestic support obligations that, as of the bankruptcy petition date, are owed to or recoverable by a spouse, former spouse, or child of the debtor, or the parent, legal guardian, or responsible relative of the child. First priority status is granted without regard to whether such claim is filed by the claimant or by a governmental unit on behalf of such claimant, on the condition that funds received by such unit be applied and distributed in accordance with nonbankruptcy law. In contrast, under the Former Code, allowed unsecured claims for debts owed to a spouse or former spouse for alimony, maintenance or support of a spouse or child had seventh priority unsecured status.
The importance of this change lies in the meaning of priorities, which determine the order in which claims are paid from the property of the bankruptcy estate. In addition to elevating the priority of domestic support obligations under the Amended Code, what is included as a domestic support obligations is expanded. By elevating domestic support obligations to first priority status, these obligations have priority over all unsecured claims in a bankruptcy case, including most administrative claims. Administrative claims include professional fees incurred during a bankruptcy case. This means that unless a domestic support creditor agrees to accept a lesser payment, that creditor will be fully paid before other unsecured creditors, as long as there are sufficient assets in the estate to allow a distribution to unsecured creditors. 12
§ 362: The Automatic Stay and Exceptions TheretoGenerally, upon the commencement of a bankruptcy proceeding, all prior judgments and enforcement actions against the debtor are stayed automatically. 13 However, the Bankruptcy Code enumerates certain exceptions to this general rule. Prior to the implementation of BAPCPA, under § 362(b)(2) of the Former Code, relevant examples of one such exceptions to the automatic stay were for actions or proceedings (1) "for the establishment of paternity;" or (2) "for the establishment or modification of an order for alimony, maintenance or support." 14
BAPCPA makes several revisions to the automatic stay provisions of the Bankruptcy Code, all of which appear to broaden the scope of the exceptions to the automatic stay for support-related proceedings. First, BAPCPA replaces the reference to "alimony, maintenance or support" in § 362(b)(2)(A) with the term "domestic support obligations," which is broader than the former reference in the Bankruptcy Code. Second, BAPCPA adds to the exceptions to the automatic stay actions or proceedings concerning: (1) child custody or visitation; (2) the dissolution of a marriage (except to the extent such proceeding seeks division of property that is property of the estate); and (3) domestic violence. 15 Third, BAPCPA permits as an exception to the automatic stay the "withholding of income that is property of the estate or property of the debtor for payment of a domestic support obligation under a judicial or administrative order." 16 Fourth, BAPCPA authorizes the reporting of overdue support owed by a parent to any consumer-reporting agency pursuant to section 466(a)(7) of the Social Security Act. 17 Fifth, BAPCPA permits the interception of tax refunds as authorized by sections 464 and 466(a)(3) of the Social Security Act or analogous state law. 18 Finally, BAPCPA allows medical obligations, as specified under title IV of the Social Security Act, to be enforced notwithstanding the automatic stay. 19
These changes could have a significant impact on child support collection practices. A common procedure used in collecting support payments is an income withholding order. Under the Former Code, the withholding of a debtor's income was barred by the automatic stay upon the filing of a bankruptcy petition if the debtor's income was property of the bankruptcy estate. 20 Now, after the implementation of BAPCPA, under the Amended Code, the use of income withholding orders is expressly excepted from the automatic stay. 21
Moreover, under the Amended Code, a debtor's driver's license, professional or occupational license, or recreational license can be withheld, suspended or restricted as a result of the debtor's failure to pay a domestic support obligation without regard to the automatic stay. 22 Further, the Amended Code adds an exception to the automatic stay to allow support creditors to seize tax refunds, which should make it less troublesome for support creditors to collect from debtors in bankruptcy cases. 23
The legislative history behind the addition of the foregoing provisions included the following:
This key provision will mean that support deducted from an employee's wages by an employer and paid to the support creditor will not be interrupted. This provision applies to both the ongoing support obligations and support arrears. In addition, other means of enforcement will remain available after the filing of a bankruptcy petition. Such enforcement tools include: (1) the revocation or non-renewal of drivers, professional and recreational licenses; (2) the reporting of overdue support to credit reporting agencies; (3) the interception of tax refunds to pay support arrears; and (4) the collection of medical support obligations. 24
As a result, the changes to the automatic stay provisions of the Bankruptcy Code implemented by BAPCPA will likely have a profound effect on support creditors in receiving payment from debtors upon the filing of a bankruptcy case.
§ 523(a)(5) & (15): Nondischargeability of Certain DebtsOther important changes to the family law practitioner brought about by BAPCPA are those made to §§ 523(a)(5) and 523(a)(15) of the Bankruptcy Code, which address the nondischargeability of debts in a bankruptcy case. Generally, one of the major benefits a consumer debtor seeks by filing for bankruptcy is obtaining a clean slate by receiving a discharge of all prepetition debts upon the completion of the bankruptcy case. Under § 523 of the Bankruptcy Code, however, certain debts maybe excepted from discharge and would need to be paid even upon the completion of the bankruptcy case.
Under the Former Code, § 523(a)(5) excepted from discharge all domestic obligations for support, alimony or maintenance to a spouse, former spouse or child of the debtor. 25 Further, under the Former Code, non-support obligations and property distribution obligations were also excepted from discharge under certain circumstances. 26 However, under the Former Code, a debtor maintained the ability to seek to discharge non-support obligations and property distribution obligations. 27
Under the Amended Code, all domestic support obligations, as defined in § 101(14A), are excepted from discharge. 28 Further, under the Amended Code, all debts to a spouse, former spouse or child incurred in the course of a divorce or separation, whether or not designated as a "domestic support obligation," are excepted from discharge in a bankruptcy case. 29
To summarize the implications of the changes to § 523, a recent treatise on the effects of BAPCPA states that the impact of the changes to §§ 523(a)(5) and (15) are as follows:
Essentially, the combination of amended §§ 523(a)(5) and (15) would be to exclude from discharge all marital and domestic relations obligations, whether support in nature, property division, or hold-harmless, provided that they were incurred in the course of a divorce or separation or established in connection with a separation agreement, divorce decree, or other order of a court of record or a determination made in accordance with state or territorial law by a governmental unit. 30
However, while BAPCPA does add some certainty into the discharge arena where it did not exist before, questions may still arise in certain cases. For example, under the Former Code, several courts had ruled that attorney's fees arising out of divorce proceedings owed by the debtor to a former spouse were dischargeable notwithstanding § 523. 31 While it appears that the changes made by BAPCPA to sections 523(a)(5) and (15) cause these types of debts to fall within the nondischargeability provisions, these sorts of issues that fall along the edges of the Amended Code will still most likely have to be decided in the coming months and years by the courts.
The final significant change to the dischargeability provisions of the Bankruptcy Code as a result of BAPCPA relates to the timing requirements for filing nondischargeability complaints. Under the Former Code, complaints under § 523(a)(5) could be filed at any time, but complaints under § 523(a)(15), could only be filed within sixty days of the date of the first meeting of the creditors. Under the Amended Code, just as under § 523(a)(5), complaints under § 523(a)(15) can be filed at any time, "and the debtor's discharge would automatically exclude both (a)(5) and (a)(15) debts from discharge unless a complaint for determination is filed." 32
§ 547(c)(7): Protection of Domestic Support Claims Against Preference ActionsUnder the Bankruptcy Code, payments made (1) to or for the benefit of a creditor; (2) on account of a debt of the debtor; (3) while the debtor was insolvent; (4) on or within ninety (90) days before the filing of the petition; and (5) that enables the creditor to receive more than she would under a chapter 7 proceeding, is an avoidable transfer that can be recovered by a debtor or a trustee appointed for the debtor. 33 The Former Code, however, contained an exception to a debtor's or a trustee's ability to avoid and recover payments made by a debtor to a spouse, former spouse or child for alimony, maintenance or support. 34
The implementation of BAPCPA has changed the Bankruptcy Code so as to except from avoidance and recovery any payment made by a debtor that falls within the term "domestic support obligation," as defined in § 101(14A). 35 Thus, after BAPCPA, under § 547(c)(7) of the Amended Code, all domestic support payments made by a debtor within ninety days prior to the filing of the bankruptcy will remain with the support creditor and cannot be avoided.
The Requirements for Obtaining Confirmation and Discharge in Cases Involving Domestic Support ObligationsOne other significant change to the Bankruptcy Code put into place with the implementation of BAPCPA is the establishment of self-executing checkpoints within the Bankruptcy Code to ensure the continuing payment of domestic support obligations by debtors. For example, BAPCPA added a new provision to the Bankruptcy Code, providing that if a Chapter 13 debtor fails to make any payment on a domestic support obligation that first became payable post-petition, the support creditor may move to have the case converted to a chapter 7 or to have the bankruptcy case dismissed entirely. 36 Additionally, a Chapter 13 debtor may not obtain a discharge of debts at all unless the debtor certifies that he has paid off all domestic support obligations. 37 Finally, BAPCPA amends the Bankruptcy Code to require a Chapter 11 debtor to demonstrate that it is current on his domestic support obligations in order to confirm a Chapter 11 plan. 38 Since confirmation of a plan is a requisite predecessor to a chapter 11 discharge, the requirement that all postpetition chapter 11 debts be paid in full limits the debtor's ability to obtain a discharge. Moreover, in Chapter 11 bankruptcy cases, a support creditor has the power to require payment in full of all domestic support obligations on the effective date of the plan. 39
Other Miscellaneous BAPCPA Provisions Affecting Family Law IssuesBAPCPA also amends the Bankruptcy Code to require trustees in chapter 7, 11, 12, and 13 cases to provide certain notices to child support claimants and governmental enforcement agencies. 40 For example, the Amended Code now requires trustees to provide written notice to a domestic support creditor of the right to use the services of a state child support enforcement agency established under sections 464 and 466 of the Social Security Act in the state where the support creditor resides for assistance in collecting child support during and after the bankruptcy case. 41 The Amended Code requires this notice (i) to include the address and telephone number of the agency; and (ii) to explain the claimant's right to payment under the applicable chapter of the Bankruptcy Code. 42 Moreover, if the debtor is granted a discharge, the trustee must then notify both the child support claimant and the state agency that the debtor was granted a discharge, as well as provide them with the debtor's last known address. 43 Further, the trustee must also provide the name and address of the debtor's last known employer, the name of each creditor holding a debt that is not discharged or that was reaffirmed. 44
Finally, BAPCPA amends the Bankruptcy Code to make exempt property liable for nondischargeable domestic support obligations, notwithstanding any contrary provision of applicable nonbankruptcy law. 45
ConclusionBAPCPA has made significant changes to consumer bankruptcy law. This paper has discussed most of those changes to the Bankruptcy Code significant to the family law practitioner. As can be seen from the discussion above, the changes to the Bankruptcy Code brought about by BAPCPA aim to prevent debtors from using the bankruptcy system as a way to avoid support obligations, while at the same time attempting to ease the support creditor's ability to obtain payments.
1. BAPCPA amends 11 U.S.C. § 101 et seq. (the "Bankruptcy Code"). A majority of the provisions of BAPCPA became effective for all bankruptcy cases filed on or after October 17, 2005.
2. Susan Jensen, A Legislative History of the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005, 79 Am. Bankr. L.J. 485 (Summer 2005).
3.The amendments also impose significant modifications with respect to commercial bankruptcy law.
4. Throughout this paper, to distinguish between the Bankruptcy Code provisions that were in effect before BAPCPA and those that came into effect because of BAPCPA, we will refer to those sections as the "Former Code" and the "Amended Code," respectively.
5. The order for relief is usually the date that a debtor files its bankruptcy petition.
7. Id.
8. Id.
9. Id.
10. Id.
11. Compare, e.g., 11 U.S.C. § 362(b)(2)(B) (1994) with 11 U.S.C. § 523(a)(5) (1994).
12. It should be noted that under the Amended Code, all secured claims will still be paid before domestic support obligations. Some commentators have noted that because BAPCPA also expands the rights of secured creditors, the significance of the changes in priority under § 507 do not significantly advance the cause of support creditors. See, e.g., National Women's' Law Ctr., Statement of Joan Entmacher on the Bankruptcy Bill, April 13, 2005, http://www.nwlc.org/details.cfm?id=2212§ion=newsroom.
13. 11 U.S.C. § 362(a).
14. Id. § 362(b)(2)(A) (1994).
15. Id. § 362(b)(2)(A) (2005).
16. Id. § 362(b)(2)(C) (2005).
17. Id. § 362(b)(2)(E) (2005).
18. Id. § 362(b)(2)(F) (2005).
19. Id. § 362(b)(2)(G) (2005).
20. See Id. § 362(b)(2)(B) (Former Code).
21. See id. § 362(b)(2)(C) (2005).
22. Id. § 362(b)(2)(D)(2005).
23. Id. § 362(b)(2)(F)(2005).
24. Stmt. of Phillip L. Strauss, Dep't of Child Support Svcs., San Francisco, reprinted in 22-4 Am. Bankr. Inst. J. 6 (May 2003).
25. 11 U.S.C. § 523(a)(5) (1994).
26. See 11 U.S.C. § 523(15); see also In re Dexter, 250 B.R. 222, 223 (Bankr. D. Md. 2000).
27. See, e.g., In re Moeder, 220 B.R. 52, 55-56 (BAP 8th Cir. 1998) ("the burden of proof lies with the debtor to show that an exception to nondischargeability under § 523(a)(15)(A) or (B) applies in a given case"); Gamble v. Gamble (In re Gamble), 143 F.3d 223, 226 (5th Cir. 1998) (upholding bankruptcy court's assignment of "the initial burden of showing that § 523(a)(15) was applicable to the debt in question" to the plaintiff and then assigning "the burden of proving that one of the exceptions applied to take it out" to the debtor); In re Jodoin, 209 B.R. 132, 140 (BAP 9th Cir. 1997) ("once the Plaintiff demonstrates that the debtor incurred the debt in connection with divorce, the burden shifts to the debtor to prove subparts (A) and (B)"); but see In re Butler, 186 B.R. 371, 373 (Bankr. D. Vt. 1995) (holding that the burden is on the creditor to prove all parts of § 523(a)(15)).
28. 11 U.S.C.. § 523(a)(5) (2005).
29. Id. § 523(a)(15) (2005).
30. Hon. William Houston Brown & Lawrence Ahern III, 2005 Bankruptcy Reform Legislation with Analysis, 32 (2005).
31. See, e.g., In re Lowther, 321 F.3d 946 (10th Cir. 2002); Adams v. Zentz0, 963 F.2d 197 (8th Cir. 1992).
32. Brown & Ahern, supra, note 30, at 32.
33. 11 U.S.C. §§ 547(b)(1) – (5) (2005).
34. Id. § 547(c) (7)(Former Code).
35. 11 U.S.C. § 547(c)(7) (2005).
36. 11 U.S.C. § 1307(c) (2005).
37. Id. § 1328(a).
38. Id. § 1129(a)(14).
39 Id. § 1129(a)(9)(B).
40. See Id. §§ 704(c)(1), 1106(c)(1), 1202(c)(1), 1302(d)(1).
41. Id.
42. Id.
43. Id.
44. Id.
45. Id. § 522(c)
For more infromation on these topics, please contact Joseph Schwartz or Kevin Larner.
Joeseph Schwartz & Kevin J. Larner
Riker Danzig


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Finding Similarities Between and Life
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The Essentials of – The Basics


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Cross-process Rendering
Surfaces save us
The proper way to render across processes on Apple platforms is to use an
Though the headers don't declare it,
IOSurfaceRefare toll-free bridged. If calling an API that takes
IOSurfaceReffrom Swift, use
unsafeBitCast(surface, to: IOSurfaceRef.self)
An IOSurface is a kernel-managed . . .
The Law
Atomics are hard
Swift 5 turns on exclusivity checking by default. This has some interesting interactions with atomics, especially when running under the Thread Sanitizer (TSAN). If you've ever seen a TSAN report on some simple Swift code that looks obviously correct then you're probably running into this issue:
// Incorrect! Do not use this!
. . .
Take Delight in Small Joys
Extensions everywhere
This is a small post about a small joy. I really enjoy how natural extensions can feel in Swift.
I consider it quite unfortunate that
UnsafeMutableRawBufferPointer.baseAddress is optional. It makes that type so ugly to use in practice. I also dislike having to specify alignment on allocation; a sensible default is
Int.bitWidth / 8 on . . .
Fixed-sized Arrays
Who doesn't like a tuple with 1024 elements?
Let's say we want to
statfs() a mount point to determine which BSD device name it belongs to. In english, that means discover that
/Volumes/MyDisk comes from
struct statfs fsinfo;
if (statfs(path, &fsinfo) != 0) {
The equivalent Swift code, along with a POSIX error helper:
func . . .
A simple exercise in leverage
The new
Codable protocol is flexible enough to allow a different encoded representation from the in-memory representation which is a nice property to have in a serialization mechanism. Today I'm going to build
SingleValueCodable to automate that work when dealing with
RawRepresentable types.
The Setup
I want to encode . . .
AMD System V ABI Reference
An ABI reference for quick lookup. If you crash or just want to step through disassembly, check the contents of the registers to see where parameters are being passed.
self or address to hold return value
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Size & Stride
A quick word of warning to those of you using
UnsafePointer and
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sizeof a type tells you how many bytes it takes to hold that type in memory.
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If you are doing pointer arithmetic on
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A Grand Day out at Kew Gardens. : The Alpine House into the Palms House..
Following on from my last Kew post, after I left the Princess of Wales Conservatory, you find yourself at the start of the rock garden with Alpine Plants and the fairly new Davies Alpine House, which is the latest addition to Kew's glasshouses. It opened in 2006, the first new glasshouse to be commissioned for two decades.
I was surprised to find not many Alpine Plants showing well though out the rock garden, so I spent most of my time in the Alpine House.