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Something to not overlook also is Pinterest, on almost all of my popular posts I spend the time to make a Pinterest specific image for them. If you don't know how to use Adobe Photoshop you can use a free online tool like Canva to create images. There are also plenty of WordPress plugins that add pin buttons to your blog as well. There are plenty of ways you can use Pinterest to drive traffic, see more tips on Buffer's blog.
Be transparent and create your story. What did you suffer through? Are you a reluctant leader or are you the hero leading the charge? Ensure you properly relay your story so that you can bridge the emotional bond between people who have no idea about who you are. Why should they listen to you? What "secrets" have you uncovered over the years? What failures did you suffer through or lessons did you learn along your journey?
SEO – I have a full guide on YouTube SEO. You'll basically want to research a video keyword in YouTube's Autocomplete dropdown, then craft your video title/description to include your keyword. Write a long description and embed it on your blog to get more views. Create a nice custom thumbnail and make your videos long and thorough, just like your blog posts should be.
Legal Disclaimer: This video is intellectual property of Deadbeat Inc. We assume no responsibility or liability for any errors or omissions in the content of this channel. This content is for educational purposes only, and is not tax, legal, or professional advice. Always do your own due diligence. Any action you take on the information in this video is strictly at your own risk.
Hayes says a few plug-ins are closely vetted and offer reliable options for bloggers that need advanced design and linking features. "AAWP is by far the most useful and trusted plug-in we have worked with," says Hayes. "It adds a lot of versatility to our articles and gives us a range of dynamic design options improving the visual design and bolstering the trustworthiness of our reviews."
Great post and right on target. I found that if you blog and/or do videos that sharing little stories will help connect you to potential leads. I do how-to videos and posts and I always tell personal stories or my own experiences that relate to the subject. It works and I get personal messages from people about it. It makes you more real and down to earth in the viewer's eyes. Once they like you and trust you they will become a lead and hopefully a sale. They may very well become a regular buyer because you will be their go to person. For best results it's best to blog daily and do at least one video a day.
When an Instagrammer posts a product picture on Instagram, they usually tag the brand they are promoting in the comment as well as a link to the specific product. This means that when people are browsing and reading the comments your brand will be on the eyes of potential customers. If they click on the tag, they will be directed to your Instagram page, and if they copy and paste the link to the product you will gain more traffic so it's a win-win situation.
Great stuff here Sean – thanks for all of these insights and sharing some best practices when it comes to affiliate marketing. I've never been comfortable giving it a shot, but after reading this post and your perspective on how and when to do it, I may just have to give it a try. Especially considering I'm already mentioning and recommending services and products on my site, I'm just not getting the potential rewards associated with doing so. Thanks again.
Rizzo adds, "roundup lists can also rank higher in Google search results because they tend to be more specific. In other words, don't do a post entitled 'Best Laptop Computer' because you will be competing with some of the largest websites out there such as CNET, PC Magazine and so on and will have a difficult time getting traffic," says Rizzo. "Instead, think about deeper pieces of content like 'Best Security Camera System for Small Businesses,' which has fewer searches but far less competition."
Firstly, pick a topic that you're interested in that also has a lot of market potential. Think of something that you like, and consider whether there would be many products associated with it, or much of an audience. You can find a topic (or "niche," as affiliates call it) with a little research. You'll find lessons to help you with this process in the market research section of Affilorama's free lessons.
This was early 2013 and Facebook had kicked into high-gear. So Henry tried his hand at Facebook ads. And it was a hit. He was able to reach the right people and pack the nightclub. Shortly after, he sold it for a big profit. But it was then that he realized how he could combine the power of advertising and affiliate marketing to really take things to the next level.
Writing content for your blog or website about picking or buying a product available on Amazon. Now more than ever, people go online to research their buying options. If you're a mom blogger, you can write an article on picking a low-cost vacuum with a link to your top choice or several links to your top choices. A food blogger can link to cooking tools. A photography site can link to cameras and other photography equipment.
Many Instagrammers use shortened link services such as Hootsuite (Ow.ly) and Bitly (Bit.ly). While shortened links are practical to use in posts and on other networks, I don't recommend using one in your bio unless it's consistent with everything else. Also, it helps if the link is customized or branded. For instance, an account for women's shoes uses bit.ly/sixinchheels, which would be acceptable.
It's highly advisable when working with influencers in your affiliate program to work out an agreement with them where they get some free product and create their own content for their feed featuring your product. Followers are a lot more likely to engage with a sponsored post that has a personal touch attached to it. The ultimate reason we work with influencers in the first place is because they influence people to buy certain products. There's no better way to do this than with a personalized post consisting of product you gave to them.
Let's say I save the affiliate pin for my favorite Pinterest affiliate marketing course to a general group board called 'Bloggers Share Your Best Pins.' In the group board, there are pins about parenting, DIY, recipes, fashion, weight loss, and all sorts of topics. Because the board is a free-for-all, there are no relevant keywords for, well, any topic. How is the Pinterest algorithm supposed to determine that my pin is about affiliate marketing? Sometimes you have to put yourself in the Pinterest algorithm's shoes, as strange as that sounds. How can you make its job easier? Signal exactly what your pin is about by using the right keywords and posting ONLY to relevant boards.
It's important to do some research into both your potential Influencer and their followers to see if this affiliate partnership is a good fit. While there's no need to go over-board and nit-pick every single post, scrolling through and reading the comments on a few dozen will give you a good sense of whether this Influencer is right for your business.
Before we can get into affiliate links, first we need to talk about the affiliate program. An affiliate program is hosted by a company that wants to use marketers who are not employed by the company to promote their product or service. These marketers, and their social media accounts, are often related to the product or niche in some way. For example, a health blogger might sign up for an affiliate program promoting vitamins.
Most successful affiliate marketers focus on a market or topic that they have knowledge of or are passionate about — preferably, both. Your niche market doesn't have to have mass appeal and a huge audience either. As long as there's some type of audience following the topic and products or services that relate to it, it has affiliate profit potential.
You can put up banners on your site, to promote your affiliate offers. Most affiliate programs will usually provide their own creatives when you sign up for their offers. All you have to do is insert the banner on a highly trafficked page (your affiliate tracking is usually embedded within the code). Banner ads in the right locations can do a great job of driving sales.
However, when you are ready, search for the right product or company that's relevant to your audience. When Henry quit smoking, his story was part and parcel to the bigger picture of selling electronic cigarettes as an affiliate. Although his blog's success was short-lived at the time, at it's apex, it was generating over $30,000 because he nurtured his audience and built that emotional bond before ever trying to sell them anything as an affiliate.
Hi Ally, You don't need anything like Leadpages or autoresponders to use affiliate links on Pinterest. All you need are to be a part of some affiliate programs and a Pinterest account as I mentioned above! I pay for neither Leadpages nor an autoresponder, I'm not sure why they would be necessary for affiliate marketing? Maybe I have misunderstood. Gemma


text: UncategorizedFabulous Looks Of The Day: September 15th, 2016byThe Fashion Bomb StaffPosted on September 15, 2016September 16, 2016402 views0 minute read The Fashion Bomb Staff Previous Article Uncategorized Show Review: Kimora Lee Simmons Spring 2017 Posted on September 15, 2016September 16, 2016byThe Fashion Bomb Staff View Post Next Article Uncategorized Bomb Product of the Day: J. Bailey's Kimono Bomber Jacket Posted on September 16, 2016September 16, 2016byThe Fashion Bomb Staff View Post Subscribe Subscribe now to our newsletter Subscribe You May Also Like View Post Fashion News Featured Vogue Italia Posts (Then Deletes) Image of Black Man Wearing Ku Klux Klan Hood, Conceived by Artist Mous Lamrabat Posted on June 25, 2019June 25, 2019byClaire View Post Beauty Claire's Life Hair Claire's Life: Girl + Hair's Meet N Greet at Target! Posted on June 24, 2019byClaire View Post Fashion Discussion Featured Do the BET Awards Need a Style Intervention? Posted on June 24, 2019June 24, 2019byClaire View Post Fashion Featured On the Scene Top Ten Best Dresses Top 10 Looks From the 2019 BET Awards: Ciara in Jean Paul Gaultier, Rihanna in Fenty, Fantasia in Pajtim Raci, and More! Posted on June 24, 2019June 24, 2019byMorgan Smith View Post Claire's Life Featured Claire Sulmers Upcoming Events: THIS Saturday, Girl + Hair in Brooklyn, Boss Babes do Brunch 6/29, Essence Fest, and More! Posted on June 20, 2019byClaire View Post Fashion Nova Adrienne Bailon is the Ultimate Cutie in this Pink Fashion Nova Set! Posted on June 19, 2019byJennet Jusu View Post Fashion Featured Shopping Style You Should Know The Newest Fenty Release Has All The Feels Of Summer On The Islands Posted on June 19, 2019June 20, 2019byMorgan Smith View Post Fashion Fashion Bomb Daily Shop Featured Shopping You Should Know New Arrivals On The Fashion Bomb Daily Shop From Oyemwen and Sai Sankoh! Posted on June 19, 2019June 20, 2019byMorgan Smith

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Taurus Directory is human edited free general web directory.Your listing with review in maximum 24 hours
Title: » Adult Students « (click to visit this website)
URL: http://uiu.edu/admissions/military/veterans/index.html [Broken Link? Please Let Us Know]
Listed in the following Categories: - Colleges and Universities
Description: Adult students are generally referred as those students who are involved in learning any kinds of formal or non-formal education. They are also called as mature learners and adult learners.
Listing Added: 2012-10-22 06:25:49
Web Archives: Wayback Machine
PageRank: 0


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Escape The Restroom - WC Escape: Toilet Escape
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In this game, you try to find and use items to escape from the restroom. You can use the box which has Japanese words and in the right hand corner to look at the items. And you have to click on and select the items to use. Another names of this game are WC Escape and Toilet Escape.
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EASE--An Application-Based CAD System for Process Design. IEEE Trans. on CAD of Integrated Circuits and Systems 6(6): 1032-1038 (1987)
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F&J SPECIALTY PRODUCTS, INC. is the leading North American manufacturer of traditional and microprocessor based air sampling instruments and high-tech airflow calibration systems for the nuclear power industry. Products lines include AC/DC air sampling systems for radiological emergency response ...
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01dB, brand of ACOEM, contributes to reducing noise and vibrations to levels complying with regulations or set out in sustainable development strategies. 01dB is aimed at the industrial sector, towns, transportation, the public works and construction sector, wind power and the leisure ...
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Appetite-suppressant drugs and other diet pills:"Wonder" products that permanently reduce weight do not exist. Products that promise immediate or effortless weight loss will not work in the long run. Appetite suppressants, which often contain a stimulant like caffeine or hoodia, are associated with side effects including nausea, nasal dryness, anxiety, agitation, dizziness, insomnia and elevated blood pressure. Alli reduces fat absorption; following the package directions will reduce risk of side effects, which may include oily diarrhea and anal discharge. With any product, side effects may be worse if you exceed the recommended dosage.
About: Laura is a health coach whose passion to help others overcome addiction and gain a satisfying life comes from her own history: For years she battled addiction (to food, cigarettes and many other things) and was taught to believe that as a woman, she was less valuable than a man. Trapped in her own mind and truly miserable, Laura one day realized that the key to overcoming her addictions was to make deliberate choices for every single thing she did — a mindset that taught her just how valuable she is. Now, she's an extraordinarily strong-willed champion of women's health who shares her knowledge and expertise with others. A true inspiration on so many levels.
A while back ago, more than 100 years ago actually, a group of dedicated fishermen decided to create a brand named Bumble Bee Seafoods. Today, it has turned out to be one of America's biggest branded shelf-table seafood company. It offers a variety of pouched and canned tuna, salmon, sardines and specialty seafood products.this brand has actually marketed a very significant loyalty and consumer awareness based on their nutritional value, quality, and of course, the affordability of their products. The Bumble Bee headquarters has recently been transferred to San Diego, and in addition to it all, besides investing in the employees and the local communities, the Bumble Bee is dedicated to promoting nothing more than a healthy lifestyle and a way to preserve the precious resources. They are most committed at carrying out the sustainability initiatives in more than just their fisheries. Make sure you read more about this brand on their site now!
The efficacy of Nutrisystem boils down to portion control. A tiny tray of frozen tuna casserole doesn't provide a lot of nutrients or satisfaction, but if that's all you have for dinner, you're keeping calorie count low. We entered in a couple Nutrisystem meals and found their point count to be mid-high, between 7 and 9. Ultimately, tiny amounts of not-wholesome foods doesn't teach you to eat well.
Listen up: Skipping meals will not make you lose weight faster. If a hectic day makes a sit-down meal impossible, stash an energy bar or a piece of fruit in your car or tote, keep snacks in your office desk drawer, and make a point of getting up to grab a nosh — anything that will keep you from going hungry! Going long periods of time without food does double-duty harm on our healthy eating efforts by both slowing down your metabolism, and priming you for another binge later in the day. (Think: You've skipped breakfast and lunch, so you're ready to takedown a whole turkey by dinner!) Make it your mission to eat three meals and two snacks every day, and don't wait longer than three to four hours without eating. Set a "snack alarm" on your phone if needed.
The Mayo Clinic Diet is generally safe for most adults. It does encourage unlimited amounts of vegetables and fruits. For most people, eating lots of fruits and vegetables is a good thing — these foods provide your body with important nutrients and fiber. However, if you aren't used to having fiber in your diet, you may experience minor, temporary changes in digestion, such as intestinal gas, as your body adjusts to this new way of eating.
About: The best word to describe Chanden's blog is sassy. She's not afraid to write a little rough around the edges (if you know what we mean), and she's got a fun personality which comes through her posts as she works to get fit and change her eating habits. She does that by creating healthy recipes and offering cooking tips that she used to drop 70 pounds since she started her blog in March 2015. She also shares her own personal journey and thoughts, and her recipes are in a league of their own.
How would you like to meet Kelly? This Colorado girl succeeded in doing what she thought was impossible – she joined a weight loss programe and finally started saying no to the cake that she felt was offered to her at every corner she turned. She made the determination of not being that fat again, and started the process of losing weight. At the same time, she created this blog, to serve her as a journal and so that by it she could keep track of her improvements or setbacks. Soon she transformed her blog into a source of all kinds of healthy recipes and foods that will give you a lot of energy and will not harm your waistline. Kelly claims that this is the best decision that she has ever made in her life and welcomes you to her blog with arms wide open and plenty to read about. So cuddle up, open her site and enjoy all the tips and advice, as well as the recipes.
Given that all participants in the study were overweight and "healthy", what was not studied, and could have been very useful, was what was the impact of the two diets on participants' blood sugars (HbA1c), insulin levels, and on some measure of inflammation. It is possible that there could have been little difference in weight loss between the two diets but big differences in the impact on risk factors related to diabetes.
Lindsay, a registered dietitian and new mom, has a passion for nutrition and healthy living. She shares that passion on The Lean Green Bean. She provides healthy recipes, nutrition information, tips for new moms, and workout advice. Her focus is on balance: She's all about helping you live a healthy lifestyle without feeling like you're giving anything up. Visit the blog.
My morning beverage of choice is a tall glass of spring water. When I get to work I will have my apple cider vinegar water, and then some tea. Hydration plays a huge part in your weight loss. 😎 #fitmom #keto #lowcarb #foodplan #mealplan #lunch #dinnerideas #dinner #lunchideas #intermittentfasting #beforeandafter #beforeandafterweightloss #fitness #fitnessjourney #weightlossjourney #weightloss #tea #acv #Applecidervinegar #hydrate
I can't do anything about the fires today; or stopping the disasters facing my brothers and sisters around the world. My feeling - is it sadness? Maybe. It comes and goes and the next step I take is to ask myself, "How can I love myself with this feeling?" "How can I feel this shitty and still know I am a vital human being." Then I ask myself, "What can I do today to contribute to my purpose, even with this feeling in my body?" All this sits side by side, steeping like a cup of tea.
Bonus: Save money by choosing meals that use in-season produce and combining your meals with your local grocery store's sales flyer. And don't forget about leftovers! Use them to create new meals (for instance, make a stir-fry with leftover cooked meats and veggies) or have a weekly night where all the leftovers get put out and everyone in the family can eat their favorites again.
Barley got its hunger-fighting reputation after Swedish researchers found that eating barley or rye kernels for breakfast kept blood sugar on an even keel. That's because the carbs in barley and rye kernels are "low glycemic index," meaning they raise blood sugar more slowly than some other carbohydrate foods. This helps you avoid a spike, and then a drop, in blood sugar, which can leave you feeling famished.
I laid on the floor, crying, and said "so this is being an adult." Then I belly laughed. ⠀ My feelings were all over the place, stress was present but it wasn't unbearable, I had a lot of work, but not too much that I was drowning, Cooper was gone, but I knew he was okay and happy with his dad—I was seemingly okay, but I didn't feel okay. ⠀ So I did what I do when I feel off, I reach into my toolbox and grab the tool that makes the most sense in that moment. First, it was calling a friend. She allowed me to cry. Knowing that I didn't want advice, I just needed someone to receive my vulnerability without judgement. ⠀ I laid on the floor because I liked the way the pressure of my body felt on the ground. I cried, well, I sobbed. I was in pain and my body hurt. She listened, and then said something that made me laugh. Within moments I was in the depths of pain, then belly laughing. "So this is being an adult", I said. But looking back now, it has nothing to do with being an adult, but being a human. Allowing ourselves to feel the full range of human emotions without fucking judging them. ⠀ Self care can feel like a bunch of bullshit and fantasy land ideas. So how can you filter the BS and get through your hard as hell moments? 👉🏽Don't focus on being 100% better. Try just 1%. Because 1% is a whole hell of a lot better than nothing. By the way, this crying ordeal was last night—we all have bad days and moments and adulting is hard AF sometimes. As I was about to hang up the phone, I said "I feel 3% better". Not 1, or 2, I felt a confident 3% better. That, was progress. ⠀ Maybe you need to draw your feelings, cry them out, dance them out, call a friend and just speak, yell, masterbate, breathe, watch a show, mediate—whatever you need to do, remind yourself that 1⃣ you're so human. You're imperfect and it's okay to have off days. 2⃣ self care is all about trial and error. Adjust and pivot with each present moment. 3⃣ 1% better IS better. Reframe what progress looks like to you 💓
The Mayo Clinic Diet is designed to help you lose up to 6 to 10 pounds (2.7 to 4.5 kilograms) during the initial two-week phase. After that, you transition into the second phase, where you continue to lose 1 to 2 pounds (0.5 to 1 kilogram) a week until you reach your goal weight. By continuing the lifelong habits that you've learned, you can then maintain your goal weight for the rest of your life.
I saw a post on pinterest for your pumpkin spice drink and started clicking around! Congratulations on your weight loss! I have just started working out regularly for the first time (just about) in my whole life. But what I've been learning slowly, even before I began the physical regimen, is how important it is to eat real food. Thanks to people around me who love food and their families health enough to really get informed about it, I've been seeing just how misinformed we are and how duped we can be by clever marketing that claims to be "healthy". When I learned where skim milk comes from and how it's made (and, for instance that it's used to fatten pigs up) and that real dairy fats (in moderation) are linked to weight loss but "fat-free" items quite the opposite, I was stunned! Then I thought, of course! People were eating the real things long before heart disease and obesity ravaged our culture. When you start to learn about real nutrition instead of what we've been sold by industries, it can be a really great weight loss tool. And, I have to say thank you for using things like coconut milk in some of your recipes! I have a dairy intolerance and it's nice to know that for the pumpkin spice recipe, at least, I wouldn't have to tweak it myself!!! I look forward to reading more and trying some of your creations!
Dr. Angela Duckworth, author of GRIT: The Power of Passion and Perseverance, has spent her career looking into what it takes for children and adults to succeed. She has investigated our mythology around talent or giftedness and effort. She is passionate about working with young students and teaching them to apply her strategies towards developing grit. Her work targets students who are considered talented and those who are considered not so talented.
How would you like to meet Kelly? This Colorado girl succeeded in doing what she thought was impossible – she joined a weight loss programe and finally started saying no to the cake that she felt was offered to her at every corner she turned. She made the determination of not being that fat again, and started the process of losing weight. At the same time, she created this blog, to serve her as a journal and so that by it she could keep track of her improvements or setbacks. Soon she transformed her blog into a source of all kinds of healthy recipes and foods that will give you a lot of energy and will not harm your waistline. Kelly claims that this is the best decision that she has ever made in her life and welcomes you to her blog with arms wide open and plenty to read about. So cuddle up, open her site and enjoy all the tips and advice, as well as the recipes.
I can completely relate to your struggles with weight. At times, I almost felt like I was reading my own story. Take out the college dorm stuff and throw in 2 jobs, one of them at a gym, and add a baby and I'd say our stories are pretty similar. My husband is deployed now, and I started running (did my first 5K 10 days ago). I'm down a solid 15 lbs in 2 months… and I haven't even been strict with my "diet". Keep running, girl! You can do it! 🙂
In 2008 between US$33 billion and $55 billion was spent annually in the US on weight-loss products and services, including medical procedures and pharmaceuticals, with weight-loss centers taking between 6 and 12 percent of total annual expenditure. Over $1.6 billion a year was spent on weight-loss supplements. About 70 percent of Americans' dieting attempts are of a self-help nature.[24][25]
Weight loss programs online should be simple to use, with websites that are easy to navigate. You should have no trouble finding and accessing various tools and features within the service, and customer service representatives should be easy to access by phone, email and live chat if you do have any questions. The best websites also provide FAQs, knowledgebases and articles to help you use the service and diet effectively.
Even though grains have been promoted as healthy starches, consuming them is one of the fastest ways to pack on the pounds. Plus as you probably know by now, the gluten found in most grains can increase inflammation in your body and put a strain on your digestive system. And store-bought bread often has added high fructose corn syrup, sugar and preservatives.
Packaged meal programs: Many diet plans rely on meal-replacement bars, shakes, or other snack type foods. Still others rely on frozen entrees as a major part of your diet. Ask yourself if you are okay with a bulk of your diet relying on prepackaged snacks, shakes, or frozen meals, or if you prefer the flexibility of cooking your own meals or eating out frequently.
Kendall's movement is catching on. After becoming certified in Women's Fitness, Weight Loss, and Fitness Nutrition by the National Academy of Sports Medicine, she's been called on to speak at countless conferences to help connect people to what she calls their "Come to Fitness" moment. Recently making an appearance at the Black Girls Run! Sweat With Your Sole Conference in 2013, Kendall held multiple massive Q&A sessions where she took rapid-fire questions and shared resources and tips with people to help them get the answers they need.
Some popular beliefs attached to weight loss have been shown to either have less effect on weight loss as commonly believed or are actively unhealthy. According to Harvard Health, the idea of metabolism being the "key to weight" is "part truth and part myth" as while metabolism does affect weight loss, external forces such as diet and exercise have an equal effect.[44] They also commented that the idea of changing one's rate of metabolism is under debate.[44] Diet plans in fitness magazines are also often believed to be effective, but may actually be harmful by limiting the daily intake of important calories and nutrients which can be detrimental depending on the person and are even capable of driving individuals away from weight loss.[45]
There's a pretty dizzying amount of research backing up this regime as a solid option to enhance your health, lower cholesterol, and encourage healthy, lasting weight loss. DASH (the acronym stands for Dietary Approaches to Stop Hypertension) has you loading up on fruits, vegetables, and whole grains (surprise!) and removing foods high in saturated fat from your diet. Research also shows that this diet may even ward off the onset of type 2 diabetes.
As my middle 30's were here, I ate better, more home cooked meals, but again didn't do any exercise. I was tracking calories, but I wasn't eating enough. I didn't know how many calories I needed in a day, I just thought I wasn't suppose to eat. At work the other day, I was cleaning my desk drawer out and came across papers that had my calorie intake for the day on it and it said I was eating 800, 900 and 1000 calories on a high day! I was shocked, well no wonder I wasn't losing any weight, I wasn't eating enough. You can't go from eating way over 2000 calories a day to practically nothing. But back then I didn't care, I did that for a few months and gave up. The scale didn't move, so I figured again, this is the weight my body is comfortable with. (image of my calorie count from January 2009)
Like protein, fiber slows the rate at which your body plows through carb calories so you feel full for longer and maintain steadier blood sugar levels, one reason why research consistently links fiber intake to weight loss. That means fibrous whole grain bread tends to be a better choice than white bread and also explains why fruits, which contain fiber and valuable vitamins in addition to sugar, beat straight-up candy every time.
Counseling and community: In-person group meetings typically meet at a community center or business on regular basis. Participants might engage in a group discussion, breakaway groups or one-on-one sessions with other members or program counselors. Some weight loss programs rely on internet-based forums and communities or mobile applications for meal planning, counseling, group interaction and support.
Books to help you lose weight or change your eating habits are a dime a dozen -- and that's a very good thing. A good diet book can be an affordable approach to starting and maintaining a healthy eating plan. Many even have free online support forums or extensive websites that can be accessed for free or a small fee. The best diet books not only give you an overview of how their program works, but also offer menu plans, recipes and exercise guidance. Best of all, you can usually try before you buy by checking out the book at your local library.
Sleeping for more than five hours a night might seem like a luxury for some, but it can have a serious impact on your overall health. Not getting the recommended 7-8 hours of shut-eye a night puts you at risk for fatigue the next day, which means you're more likely to crave and snack on high-calorie comfort food. Try to go to bed sooner so you can get a little more sleep, which will help you eat less. And to blast fat even faster, don't miss these essential ways to boost your metabolism.
For us ladies there is a dreaded week each month that we hold onto water weight (and usually a bar of chocolate) and guess what, you will be much more forgiving at the end of the week weigh in if you know once a month you just happen to be 5 pounds heavier. You'll say to yourself, yep that's my pattern, it's OK and it will be gone next week. See… sometimes homework can be beneficial.
A similar program, TOPS (Est. $32 per year, plus $5 chapter dues), pairs a wealth of educational material with group meetings in your community, also called "chapters." TOPS, which stands for Take Off Pounds Sensibly, uses The Food Exchange System, which users say is easy to understand and follow. It has categories of foods with similar serving sizes and caloric loads, and it's easy to swap one food for another. You can even purchase exchange cards that give you food options within categories at a glance, as well as a variety of other accessories, such as food prep tools scaled to accurate portion sizes.
The MIND diet, or Mediterranean-DASH Intervention for Neurodegenerative Delay, is a sort of hybrid between the DASH diet and the Mediterranean diet. It features foods meant to slow the progression or development of Alzheimer's disease, the most common form of dementia and an incurable neurodegenerative condition that more than 5 million Americans are living with, according to the Alzheimer's Association. (12) Some research backs up this notion, including a study published in September 2016 in Alzheimer's Dementia that found a link between following the MIND Diet and a reduced risk of the disease. (13)
I think we can all relate to this feeling, because, let's face it—losing weight is hard AF. It takes a lot more than just a spurt of motivation and a trip to the produce section at the grocery store to really see lasting results. And thankfully for us, the internet has helped us all obtain the information we need to lose weight by the simple click of a button.


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When you are renting a 5, 10, 15, 20, 30 or 40 yard dumpster, you want a company you can trust with prices that make you smile. Give us a call today and see the difference we can make in your next construction or clean out project.
Simply give us a call and we will help you figure out your dumpster rental needs.
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Most cities or municipalities do not have many regulations regarding dumpster rental as long as you keep the dumpster entirely on your own property during the rental period. If you need to place your container on the street in any way, you will likely have to obtain a permit from the appropriate building permit office in your town. You can check with your local public works department to be sure.
Most Brookside dumpster rental companies will take care of securing this permit for you if you rent from them. Make sure that if you're planning to put the dumpster on the street, the company has made the appropriate arrangements. You should also ensure that you get the permit in a timely manner and at the correct cost. If you thought the dumpster company was getting a permit and they did not, you will be the one who will have to pay the fine that is issued by the authorities.
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Renting a new dumpster can be a lifesaver when you have a serious project ongoing at home. These kind of rentals are great for trash removal, furniture fingertips, and useless hauling, among other things. However, it is necessary to remember that booking a dumpster does not automatically mean that your dumpster expert will be on the floor to move the trash into the container for you. Ensure you know exactly what is actually included in advance when you rent a new dumpster so that you never run into almost any surprises on the way.
Good, that you've chosen to rent a new dumpster to clear the tons of trash cumulated at your job location. You have to know the type and size of dumpster of which best fits the needs you have before you go in advance with the rental procedure. Roll off dumpster should be your decision if you are looking out and about to dump large tons of rubbish in the major commercial and residential tasks. Before you place an order for the roll off rubbish bin, it is crucial for you to know the dimensions of your garbage container in order that you accommodate the required place to placed the dumpster at your undertaking location. If you are running a home rehabilitation, commercial undertaking or manufacturing clean up, the space you allow for for the garbage box should be double the size of its height and width.
At first you may want to try to have a rummage sales. Make the costs on the things very low so that you can just eliminate. Do not try to earn cash at your rummage sales, you are getting it to eliminate things. It is advisable to sell ones items for reasonable to someone that may use them as well as fix these people than to simply throw these people in the dumpster and end up at a junkyard.
With warmer weather around the corner, many homeowners are looking ahead to help spring demolition projects. As you become outside to create some significant property advancements, count on your at-home trash hauler for cost-effective demolition solutions. From disposing of old, dilapidated fences and garden storage sheds to carting off deck and Jacuzzi tubs, a close junk carrying business are available in especially convenient. Some waste and rubbish removing services may even arrange to acquire and remove any unwanted cars or trucks without getting you a solitary dime. Be sure to ask about totally free car carrying service when you call.
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In most places there is a limit to the amount of trash getting put to your curbside and is normally picked up one time per week. Many small businesses like restaurants, small office buildings or even apartment things do not want to possess the eyesore of numerous disposal bins sitting in front of the website. Dumpster rentals are a fantastic choice in such cases. The dumpster can be placed towards the returning of the developing, to the side or even most anyplace out of sight. The one thing to consider is that the Roll Off For Rent in Brookside organization will need to have gain access to via a roadway or drive way to pick up along with unload your dumpster.
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Dumpster scuba dving is a phrase to describe going through trash containers for 'treasures'. Whilst it may sound terrible to some people it's actually fun and can allow you to be a lot of money.
Have you any idea local rules and laws and regulations for disposing of all of the crap cleaned out in your home or industrial space? Unless you, and you leave your fridge or busted TV for the wrong place, you might get ticketed. experts are generally trained in crap disposal. If they help you weight the truck or simply just pick up your dumpster you leased, they'll understand the proper ultimate resting spot for each item. Sometimes, that can imply a monetary gift center or possibly a recycling facility--your rubbish might be another woman's treasure! That's not the only good thing about working with crap haulers. You'll also save all of the time it'd take you they are driving items to your landfill or even recycling heart yourself. Rather, you'll be able to take in air a sigh of relief when the truck or even dumpster pulls out, knowing that your hard work is done.
Depending on the extent of non-public property the actual tenant that is left behind, you may have a huge cleaning venture before you. Whether or not you have a group or just by yourself and an link, emptying the actual rental is a venture that can take several days. If you've been smart and chosen a dumpster, you made this venture easier in yourself. You can take every little thing out to the actual dumpster instead of having to worry about what will be recyclable as well as can be generously donated to charity. Dumpster rental corporations will often look after sorting as a result of items devote their dumpsters to observe what can head out to charity or why not be reused and what can go to recycling centers. You will find hired a dumpster, you'll need to carry this project yourself to reduce your costs along with your local rubbish company.
If you handle massive projects such as construction, residence renovation as well as green property cleanup, it is crucial for you carry help from professional to complete the actual project productively. People take a due care to complete the actual project punctually, but they forget about post problems with the venture such as rubbish hauling. You are about to generate massive tons of rubbish on finishing of the venture. Tons of rubbish piled up for too long period of time might lead to whole lot many problems such as triggering environmental pollution, dispersing infectious conditions, occupying no cost space within your arena, blocking the growth within your further jobs and so on. Clearing such a massive trash in self kills much of your a serious amounts of also wants huge purchase of terms of carry and job. Piling rubbish for longer time period may toss you within unnecessary difficulties.It invitations penalty by you for being a resource for making environmental pollution.
You may be concerned about the price of something like that. Maybe you will not be sure that you're heading to need something of that nature. Sit down making a list of everything that are going to possibly be thrown out. Currently think about what your location is going to need to have to take it and just how you are going to understand it there. In case you still will not be convinced that you want a dumpster for rent, estimate how much time it really is to take you to take away all of the extra and trash from your home as well as yard. It might just be worth the money to save you all of the time it is going to carry to clean up as well as dispose of every little thing.
There are many occasions when you may need a Roll Off For Rent in Brookside, NJ. You could possibly purchased a brand-new second home that you consider a log cabin. You got the great price around the cabin having a gorgeous property and water rights. Now the cabin wants to have some redecorating done. The first item you notice that needs to be studied care of would be the roof. The cover is starting to leak and the shingles are slowly and gradually being supplied off of the roof top as the fingernails are developing from it.
Have you been happy with the way your home seems to be right now? Are you experiencing clutter invisible in your wardrobes and crevices? Has the item spilled away into your storage area? Your attic?
Please use the form below to contact us. We look forward to working with you and will get back to you as soon as possible. All fields are required


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We have used the iOS 11 wallpaper, and it was outstanding. However now its time for iOS 12, a combination of an unbelievable AI and AR features along with gorgeous iOS default wallpaper. Also New Dynamic Desktop on MacOS Mojave. The wallpaper is now available across all the iPhone's who …Read More »
How to Setup Enable Dynamic Desktop in MacOS Mojave on Mac: Set Dynemic Wallpaper
As you have seen how beautifully you can create your own desktop by enabling dark mode and accent colors. Likewise, macOS Mojave also brings dynamic mode in your mac. The all-new feature allows your desktop to adjust dynamically regarding color tones and brightness the wallpaper and it varies depending upon …Read More »
How to Create a Partition on Mac to Install MacOS Mojave 10.14, 10.14.4
Just think how beautiful it is to use the new macOS Mojave on our mac without deleting the old High Sierra. It is very simple to install both the versions on your mac; only you have to create disk partition to take advantage of Mojave. Thanks to inbuilt disk utility …Read More »
mojave install stuck: MacOS Mojave 10.14 Update Failure/Stuck/Installation Error [Fixed]
Today we will show you the best solutions to fix macOS Mojave 10.14 update failure. The failure of the update can cause losing data on mac, so it is necessary to prefer preventive measure if you're facing high sierra update installation error. Follow the next lines of the article and …Read More »
MacOS 10.14 Mojave Won't download and Install on Mac, MacBook Air/Pro [Stuck]
Getting the new update and installing on Mac is quite simple, whenever any update will be available for your Mac or MacBook, it will notify you. Moreover, if you have enabled auto update, it will update directly without asking your permission. But sometimes we face difficulties when MacOS won't download …Read More »


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Seaclusion waterfront retreat sleeps 12
- House35 m²
- Sleeps: 12
- Bedrooms: 4
- Bathrooms: 2
- Min. Stay: 1 - 7 nights
Location ideal in the heart of the Gold coast stunning modern 4 bed 2 bath,Pool
Property Manager
Holly Westaway
- Languages:
- english, french
About Holly Westaway
Holly and Craig are very experienced hosts with 6 properties. Our focus is making your stay enjoyable. All our properties are kitted out with everything and more.
Holly Westaway purchased this House in 2008
Why Holly Westaway chose Gold Coast
Location. Quiet waterfront and in heart of Gold coast. Close to Horse racing ,golf, beach and theme parks. Modern stylish with pool and large usable back yard for soccer or cricket
What makes this House unique
One level modern luxury home 4 large Bedrooms , 2 King Rooms sleeps 12 Ideal for 2 families large back yard with artificial turf for soccer or cricket large pool with beach entry raised patio area with water views 2 large bathrooms with bath/spa tubs stunning timber floors open plan Ducted Air conditioning large gourmet kitchen 4 Car secure off street parking 1 undercover Great position being in the heart of the Gold Coast. Close to public transport but walking distance to Surfers Paradise.
- Parking
- Air Conditioning
- Children Welcome
- Washer & Dryer
- Internet
- Heater
- Satellite or Cable
- Hot Tub
- Accessible
- Swimming pool
- 2 Bathrooms
House Rules
Please consider the following guidelines when booking this property:
Cancellation Policy
No refunds for cancellations made after payment is made
10 Reviews
Beautiful house, wonderful host
Our stay at Seaclusion was wonderful. Our host was always so responsive to messages and great to deal with. The house had absolutely everything you could imagine needing. Great stay here
Thankyou for your lovely review, we are glad you enjoyed your stay!
Beautiful location, family friendly home to relax in.
The home was spacious and comfortable for our family to enjoy.
The pool was definitely a highlight for our children and the location of the kitchen overlooking the pool made it enjoyable to utilise whilst watching the kids.
Holly the owner was very accommodating and easy to contact during our stay.
Would recommend if you have a large family or two smaller families.
Would definitely consider returning for another holiday in the future.
Thankyou for your kind words, we are so glad you enjoyed your stay and would welcome you back anytime! All the best
Decent home, hard to contact Holly at times
I am writing this review, as I was unhappy with how unresponsive the owners were throughout our ordeal on the last two days there, and the feedback they had given, in terms of the bond etc. To be fair we did not deserve our bond back, as we were very loud, left a hole in their wall, and few minor things that in retrospect will not add up to our bond, but what they had blamed us for is unacceptable. Within our time at the property, the bins were not emptied when we checked upon arrival (they were full to the brim of beer bottles and cans) , circuit breaker tripped, gate code loss power, the sink had fallen through due to poor installment, the BBQ had also caught a light due to no rocks being in the drip tray to soak up the fat (this shouldn't of been our job to check, there was also no fire extinguisher) the damage to the wall and vent due to the BBQ catching fire was out of our control. In terms of the BBQ catching fire, in the feedback they gave us, they said the neigbours saw the BBQ unattended when it caught fire, when really,our dark skinned friend was there very much the whole time (My friends and I find this to be very offensive). They also blamed us for multiple hole damages in the room with the bunkbed and double bed, when in fact, who ever "installed" the tv is to blame as they suck at their job (we have video evidence of this already being there upon arrival) They also blamed us for cigarettes being left everywhere, but that can't be true if neither my friends or myself smoke. In all honesty it, seems like the tenants of the house never really checked anything properly, and then blamed the next owner for mistakes of their own, or previous owners. BE VERY CAREFUL when booking this house, it did, and still does feel like they scammed us, especially with all that happened coincidentally and the fibs that the neighbours told.
Kyle, you know we were very hesitant to accept your booking in the first place but you assured me you were not here for schoolies, we should have stuck with our gut feeling. YOURS IS THE FIRST BOND WE HAVE EVER CLAIMED. We are extremely disappointed in the way you treated our home and the damages caused. We had to replace the bbq and repaint walls and ceiling due to your damages. photos are taken before and after every guest.
Excellent property
Over all very easy to work with Holly the property just needs to fix a couple of light globes and the bathroom spa but we loved the property and would stay again no problems
The house was amazing and perfect for a large group.
The house had so much space, a beautiful pool area and great view of the canal. Will definitely be coming back.
Beautiful family friendly house
Beautiful house with all the luxuries as well as family friendly! Close to everything needed for a fun family holiday- theme parks and shopping . Holly was super helpful and easily contactable. Thank you Holly , your house is awesome and your management of the property exceptional !
Thankyou for taking the time to write a review, it is greatly appreciated. We are very glad you enjoyed your stay and look forward to you staying again next year. Thankyou for your kind words and for leaving the house so Tidy.


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$55.00 $0.00
These handcrafted baskets feature a richly textured random weave pattern. They are perfect for organization and storage. Made from water hyacinth, a fast-growing sustainable material. Two sizes 18"l x 15"w x 9.5"h, 18.5"h x 18"dia.
Inquire - $163.00
Set of 3, open seagrass woven baskets with handles in black.
L: 12"H x 16"Diameter
M: 11"H x 14"Diameter
S: 10"H x 12"Diameter
Material: Seagrass
Colour: Black
Inquire - $19.00
Little iron mouse keeps the door open and the cat in. Well, maybe the cat!


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The evening was hectic, and I almost forgot about the #LunarEclipse. I had literally just put my son to bed when I remembered, "The #eclipse!" We went out to see if the sky was clear.
Clouds were rushing across the sky, but for the most part, it was clear, and we had a perfect view of the #moon looking like a dark brown chunk of rock in the sky.
(Then I spent 10 minutes fighting with camera settings while he went back to bed.)
I went back out about an hour later to check out the view as the moon left the earth's shadow, and caught these two photos, taken about the same time with different exposures so that you can see either the lit portion of the moon, or the part that's still in the earth's shadow.
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California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115. (Santa Clara County Super. Ct. No. 114CV267182)
Plaintiff law firm Pahl & McCay sued William Brooks for unpaid legal fees, and Brooks cross-complained for fraud. After all evidence was presented at trial, the cross-complaint was dismissed for failing to comply with the one-year statute of limitations for attorney misconduct, and the jury returned a verdict in favor of plaintiff for the unpaid legal fees. On appeal, defendant argues his fraud claim was not subject to the one-year limitations period, and the dismissal prejudiced his defense in the original action. Finding no prejudice from the asserted error, we will affirm the judgment.
Defendant William Brooks is a Santa Cruz County real estate broker and developer, and is the sole owner of Brooks Properties, LLC. He conducts general real estate business through that entity, and forms additional limited liability companies to operate specific development projects.
Brooks formed a limited liability company to manage a development project in downtown Santa Cruz, and in 2007 that entity borrowed $1.76 million from Santa Cruz County Bank (SCC Bank). He signed the loan agreement in his capacity as a member of Brooks Properties, and he and Brooks Properties personally guaranteed the loan. Originally formed as Pacific Garden Place, LLC, the entity's name was later changed to Park Pacific, LLC, and Park Pacific borrowed additional money from SCC Bank.
SCC Bank held a first lien on the downtown Santa Cruz property, and two other entities—Lighthouse Bank and Bay Side Capital Partners—acquired subordinate liens to secure outstanding loans on another of defendant's development projects, which was in financial distress. When Park Pacific could not make the monthly payments to SCC Bank, defendant and an SCC Bank representative discussed defendant having the project re-permitted and finding a buyer in lieu of foreclosure. Under that scenario, Lighthouse Bank and Bay Side Capital would each receive some money, and Brooks would recover his permitting costs through a sales commission. But the arrangement never came to fruition, and in 2012 SCC Bank foreclosed on the Park Pacific property. The bank was the foreclosing beneficiary with a $271,657 deficiency remaining on the loan, and the junior lienholders received nothing.
In July 2012 Lighthouse Bank, Bayside Capital Partners, LLC, and Park Pacific, LLC, collectively retained the law firm of Pahl & McCay to sue SCC Bank for fraud related to the foreclosure. Brooks Properties maintained a deposit account at SCC Bank, and shortly after the lawsuit was filed SCC Bank seized the $118,000 balance in that account to offset the Park Pacific loan deficiency. SCC Bank then sued Brooks for breach of guaranty to collect the remaining $163,088 deficiency. Brooks retained Pahl & McCay to defend that action, in which defendant cross-complained against SCC Bank for conversion regarding the $118,000. Later that year the trial court issued a writ of attachment for the $163,088 deficiency upon the filing of an undertaking.
Brooks became increasingly disenchanted with the litigation as SCC Bank pursued his assets, and he pressed named partner Stephen Pahl (who was a founding shareholder of Lighthouse Bank, and a member of Lighthouse Bank's board of directors and loan committee chair) to settle the litigation. Dissatisfied with what he viewed as Pahl's lack of initiative, defendant extracted himself from the litigation without Pahl's assistance or knowledge, settling with SCC Bank and withdrawing from the fraud case in March 2013. The following month, Pahl & McCay sent defendant a letter terminating their representation.
In June 2014 Pahl & McCay sued Brooks for breach of contract and related claims, seeking payment for legal services rendered in the lawsuit by SCC Bank. Defendant alleged as affirmative defenses that plaintiff violated the Rules of Professional Conduct and committed professional negligence by not obtaining a valid conflict waiver and by not representing him diligently and with undivided loyalty. Brooks also cross-complained against plaintiff Pahl & McCay, Stephen Pahl, and Lighthouse Bank alleging fraud and conspiracy. That cross-complaint is the subject of this appeal. Defendant alleged in the first cause of action that plaintiff and Pahl induced him to join Lighthouse Bank in suing SCC Bank and concealed that the lawsuit would likely result in a retaliatory claim against him to enforce the Park Pacific loan guaranties; that plaintiff and Pahl concealed from defendant their primary allegiance to their client Lighthouse Bank such that defendant's interests were subordinated to those of Lighthouse Bank; and that had he "known the true facts" he would not have sued SCC Bank for fraud or engaged plaintiff to defend him in SCC Bank's lawsuit. He sought compensation for the money seized by SCC Bank ($118,000) and attorney's fees related to the fraud action. The second cause of action, dismissed during trial by stipulation, alleged a conspiracy among the cross-defendants.
The case was presented to a jury in October 2015. At the close of evidence, cross-defendants successfully moved for a directed verdict on Brooks's cross-complaint on grounds that the remaining cause of action was barred by the one-year statute of limitations in Code of Civil Procedure section 340.6, subdivision (a) for attorney wrongdoing. The jury returned a verdict for plaintiff, awarding damages of $22,104, the outstanding balance for legal services rendered. Brooks's motion for new trial or judgment notwithstanding the verdict was denied.
The statute of limitations for fraud is three years. (Code Civ. Proc., § 338, subd. (d).) A shorter statute of limitations governs attorney malpractice claims, including constructive fraud. In "[a]n action against an attorney for a wrongful act or omission, other than for actual fraud, arising in the performance of professional services," a one-year statute of limitations applies. (Code Civ. Proc., § 340.6, subd. (a).) "The exception for actual fraud in section 340.6 was intended to apply to intentional fraud, not constructive fraud resulting from negligent misrepresentation." (Quintilliani v. Mannerino (1988) 62 Cal.App.4th 54, 69-70.)
The Civil Code defines "actual fraud" as one of two types of fraud rendering a contract voidable. (Civ. Code, §§ 1566, 1571.) Actual fraud consists of intentional misrepresentation, negligent misrepresentation, suppression of fact, a promise made without any intent to perform, and "[a]ny other act fitted to deceive," when committed "with the intent to deceive ... or induce [another party] to enter into the contract." (Civ. Code, § 1572 ; Masters v. San Bernardino County Employees Retirement Assn. (1995) 32 Cal.App.4th 30, 41.) The acts constituting actual fraud are essentially the same as the those constituting deceit in Civil Code section 1710. (5 Witkin, Summary of Cal. Law (11th ed. 2017) Torts, § 883, p. 1208.) Fraudulent concealment, a form of intentional misrepresentation, requires a duty to disclose the concealed fact. (Graham v. Bank of America, N.A. (2014) 226 Cal.App.4th 594, 606.)
Civil Code section 1572 provides: "Actual fraud, within the meaning of this chapter, consists of any of the following acts, committed by a party to the contract, or with his connivance, with intent to deceive another party thereto, or to induce him to enter into the contract: [¶] 1. The suggestion, as a fact, of that which is not true, by one who does not believe it to be true; [¶] 2. The positive assertion, in a manner not warranted by the information of the person making it, of that which is not true, though he believes it to be true; [¶] 3. The suppression of that which is true, by one having knowledge or belief of the fact; [¶] 4. A promise made without any intention of performing it; or, [¶] 5. Any other act fitted to deceive."
In contrast to actual fraud, "constructive fraud" is defined as "any breach of duty which, without an actual[] fraudulent intent, gains an advantage to the person in fault ... by misleading another to his prejudice." (Civ. Code, § 1573.) "Constructive fraud allows conduct insufficient to constitute actual fraud to be treated as such where the parties stand in a fiduciary relationship." (Estate of Gump (1991) 1 Cal.App.4th 582, 601.) " '[] In its generic sense, constructive fraud comprises all acts, omissions and concealments involving a breach of legal or equitable duty, trust, or confidence, and resulting in damages to another. [Citations.] Constructive fraud exists in cases in which conduct, although not actually fraudulent, ought to be so treated—that is, in which such conduct is a constructive or quasi fraud, having all the actual consequences and all the legal effects of actual fraud.' [Citation.] Constructive fraud usually arises from a breach of duty where a relation of trust and confidence exists." (Barrett v. Bank of America (1986) 183 Cal.App.3d 1362, 1368-1369; Tyler v. Children's Home Society (1994) 29 Cal.App.4th 511, 548 [a constructive fraud claim "allows relief for negligent omissions constituting breach of duty in a confidential relationship"].) Included in the realm of constructive fraud are an attorney's fiduciary breaches lacking fraudulent intent or motive. (Stoll v. Superior Court (1992) 9 Cal.App.4th 1362, 1368.)
Cross-defendants argue that the actual fraud exception in Civil Code section 340.6 (hereafter "section 340.6") does not apply to Brooks's cross-complaint because the sole claim is based on violations of professional obligations embodied in the Rules of Professional Conduct. They argue that this case comes within section 340.6's one-year limitations period under Lee v. Hanley (2015) 61 Cal.4th 1225 (Lee) as a " 'claim [] whose merits necessarily depend on proof that an attorney violated a professional obligation in the course of providing professional services,' " regardless of how the cause of action is labeled.
Cross-defendants' reliance on Lee is misplaced because that case addressed the reach of the one-year limitations period, not the scope of the express exception to that period. Lee did not involve a fraud claim. (Lee, supra, 61 Cal.4th at p. 1231.) The plaintiff in Lee sued her former attorney for failing to return a retainer balance, alleging breach of contract, breach of fiduciary duty, and related equitable violations (id. at p. 1242 [dis. opn. of Corrigan, J.]), and in the context of a demurrer the Supreme Court addressed whether "refusal to return a former client's money after the client terminated representation was 'a wrongful act or omission... arising in the performance of professional services' under section 340.6(a)." (Id. at p. 1229.) While the Supreme Court held that the one-year time bar in section 340.6 applies to causes of action "when the merits of the claim will necessarily depend on proof that an attorney violated a professional obligation—that is, an obligation the attorney has by virtue of being an attorney—in the course of providing professional services" (Lee, at p. 1229), it expressly dissociated the actual fraud exception from that holding. "Such claims," the court continued, "brought more than one year after the plaintiff discovers or through reasonable diligence should have discovered the facts underlying the claim are time-barred by section 340.6(a) unless the plaintiff alleges actual fraud." (Ibid., italics added.) The trial court in Lee was found to have erred in sustaining the demurrer because the complaint could be "construed to allege" conversion which does not necessarily depend on proof that the attorney violated a professional obligation, even though the allegations, if true, may establish that the attorney also violated certain professional obligations. (Id. at p. 1240.) But as Lee did not involve a claim of actual fraud, applying its interpretation of the reach of the one-year limitations period to the actual fraud exception to that same period would effectively eliminate the exception. (In re J.W. (2002) 29 Cal.4th 200, 209 [principles of statutory construction dictate "that every part of a statute serves a purpose and that nothing is superfluous"].)
Cross-defendants' reliance on Prakashpalan v. Engstrom (2014) 223 Cal.App.4th 1105 (Prakashpalan) is similarly misplaced. The court in Prakashpalan addressed whether the three-year limitations period in Code of Civil Procedure section 338, subdivision (d) or the three-year limitations period in Probate Code section 16460 (with different triggering acts) applied to fraud-based claims relating to an attorney's disbursement of aggregate settlement proceeds held in a client trust account. (Prakashpalan, at pp. 1122-1123.) The court concluded Probate Code section 16460 (which applies to claims for breach of an express trust) governed over the more general limitations statute for fraud because the limitations period under the Probate Code was triggered by the trustee's specific duty to provide an accounting. (Prakashpalan, at pp. 1124-1125.) The court went on to conclude that the statute of limitations had not been triggered because the accounting was incomplete as measured by the Rules of Professional Conduct applicable to aggregate settlements. (Ibid.)
Citing Prakashpalan, cross-defendants argue that defendant's fraud claim falls within section 340.6's one-year limitations period because it is premised on a breach of professional obligations under former rule 3-310 of the Rules of Professional Conduct, and an attorney's disclosure duties are more particularized in the rule than the Civil Code. But the fraud-based claims in Prakashpalan were excepted from section 340.6's one-year limitations period even though the attorney's handling of the settlement proceeds arose from the provision of professional services. (Prakashpalan, supra, 223 Cal.App.4th at p. 1122, fn. 4.) The appellate court was thus wrestling with which of two pertinent limitations statutes to apply, opting for Probate Code section 16460 as the more specific statute. The court also observed that the accounting duty imposed by the Rules of Professional Conduct relating to client trust funds was more particularized than the general duty not to omit or misrepresent facts in Civil Code section 1710. (Prakashpalan, at pp. 1124-1125.) But significantly, that observation was not made in the context of determining which limitations statute to apply; rather it was made in the context of determining whether the extent of the accounting provided to the plaintiffs in that case should trigger or toll the limitations period under Probate Code section 16460. (Prakashpalan, at p. 1125.) Here, even if the Rules of Professional Conduct prescribe Pahl & McCay's duties with greater specificity than the Civil Code, it does not follow that section 340.6's actual fraud exception should be disregarded. Actual fraud, no matter the source of duty, is exempt from section 340.6's one-year time bar.
Former rule 3-310 of the Rules of Professional Conduct was amended and renumbered rule 1.7 in November 2018. --------
The actual fraud exception in section 340.6 applies to all allegations of intentional fraud. (Quintilliani v. Mannerino, supra, 62 Cal.App.4th at pp. 69-70.) The relevant test is not whether the alleged attorney misconduct is necessarily related to a violation of the Rules of Professional Conduct, but whether it is alleged to arise from intentional misrepresentation or concealment of a material fact with the intent to deceive. (See Civ. Code § 1572, ante, fn.1.) It was an error to dismiss the cross-complaint as time- barred under the one-year limitations period in section 340.6(a), rather than applying that section's three-year exception for actual fraud.
Brooks argues that he alleged actual fraud, he presented evidence of actual fraud, and his proposed intentional misrepresentation and concealment jury instructions (CACI 1900 and 1901) were for actual fraud. The cross-complaint alleged fraud by concealment: That cross-defendants induced defendant to sue SCC Bank while concealing the likelihood of a retaliatory claim, and that cross-defendants' primary allegiance was to Lighthouse Bank such that defendant's interests were subordinated.
On appeal Brooks argues that he provided sufficient evidence from which a jury could have inferred the falsity of at least one of the following representations in the July 2012 engagement letter: "[W]e are unaware of the existence of any actual conflicts between you and [Lighthouse Bank]"; "we can envision potential conflicts ... [that] we do not believe ... are likely to occur"; "if an actual conflict does arise between you and [Lighthouse Bank], it may become necessary for us to withdraw from representation"; and "We will ... notify you promptly if we form the opinion that a conflict of interest exists."
Brooks points to the following evidence to demonstrate falsity: Pahl was a director, a shareholder, officer, and loan committee chair of Lighthouse Bank; Lighthouse Bank had sued Brooks in the past; Pahl regarded Brooks as someone who did not pay his bills; Pahl knew or assumed Brooks had guaranteed a loan from SCC Bank; Pahl did not warn Brooks that a lawsuit against SCC Bank could trigger action on that loan; Pahl knew Brooks's participation in a lawsuit against SCC Bank would benefit Lighthouse; and a conflict of interest actually arose when Brooks asked Pahl to settle the case, and Pahl did nothing in response.
We are mindful of the high standards governing non-suit: Conflicting evidence must be disregarded, and all legitimate inferences drawn from the evidence must be indulged in favor of the claimant, with presumptions, inferences, and doubts being resolved in the claimant's favor. (North Counties Engineering, Inc. v. State Farm General Ins. Co. (2014) 224 Cal.App.4th 902, 919-920.) Even under that standard, we find the evidence of intentional concealment insufficient to support defendant's fraud claim.
The gravamen of defendant's claim was that Pahl failed to disclose his relationship with Lighthouse Bank in his engagement letter, inducing defendant to contract with Pahl & McCay for legal services. Contrary to defendant's professed ignorance of Pahl's relationship with Lighthouse Bank, the evidence at trial unequivocally established that Pahl's role had been specifically and consistently displayed to defendant in his capacity as a Lighthouse Bank shareholder. There could be no concealment given those positive disclosures.
Undisputed evidence also established both Pahl and Brooks were organizers and founding shareholders of Lighthouse Bank, which opened for business in 2007. As a shareholder Brooks received the bank's 2008-2012 annual reports, all of which identified Pahl as a member of the board of directors by name, professional capacity (senior partner and chairman of Pahl & McCay), and photograph. Brooks also received Lighthouse Bank's annual meeting notices and proxy statements with Pahl's name appearing on both documents as a current board member and secretary, and the proxy statement referencing Pahl's investments and compensation. A plaque hanging in the Lighthouse Bank lobby displays the names of the bank organizers, including both Brooks and Pahl. And Pahl had sued Brooks in 2008 on behalf of Lighthouse Bank.
"To establish prejudice, a party must show 'a reasonable probability that in the absence of the error, a result more favorable to [the party] would have been reached.' " (Diaz v. Carcamo (2011) 51 Cal.4th 1148, 1161.) Defendant acknowledges that evidence supporting his fraud claim, which was presented to the jury before his cross-complaint was dismissed, "also constitutes a defense to [plaintiff's] complaint for legal fees owing on the separate and distinct theory of professional negligence and/or misconduct." By returning a general verdict for plaintiff on the breach of contract cause of action, the jury necessarily rejected defendant's affirmative defenses, and by rejecting those defenses, the jury also necessarily rejected his fraud claim.
Defendant argues he was prejudiced because the jury was susceptible to confusion, with the cross-complaint being dismissed after he presented his case, and "before [he] had any opportunity to clarify the issues for the jury in closing argument regarding the complaint and the cross-complaint." But the motion for directed verdict on the cross-complaint was heard and granted on the fourth day of trial, after the close of evidence. Defendant had the remainder of that day and evening to prepare for the next morning's closing argument and any clarification he wished to present to the jury. On this record we see no reasonable probability that a result more favorable to defendant would have been reached on either the underlying action or his cross-complaint had the latter been submitted to the jury.
The judgment is affirmed. Respondents shall be entitled to their costs on appeal.
Grover, J.
/s/_________ Elia, Acting P. J. /s/_________ Danner, J.


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Billericay Bowling Club
Reports CMBL "A" TEAM
R.H.P. "A" 11th June Away
Another tough away match, our fourth out of five, and against strong opposition. A cold evening, on a heavy green - not much going for us !!
Terry Cannon's rink (Jim Collins, David Palmer & Ken Pipe) struggled from the outset against a very accurate skip who made full use of his particularly straight woods. Never in the chase, losing fourteen ends, lost 10-24.
Brian Hyland's rink (Tony Dalton, Hazel Smith, & Dave Wood) put up a stronger fight, but were always playing catch up. Despite a strong finish the were beaten 19-25.
A match result of 29-49 meant that we came away pointless.
P.M.L."A" 4th June Home
After a day of incessant rain we were blessed with a dry evening, albeit the damp green did not play as fast as we have come to expect.
Ken Pipe's rink (Dave Wood, Mike Yates, & Val Dalton) got off to a blistering star leading 9-0 after four ends, but only managed to win one of the next eleven to find themselves trailing 11-14. Sharing the points on the remaining ends they completed the game losing 15-18. Terry Cannon's rink (Jim Collins, Hazel Smith & David Palmer) after a hesitant start dominated the game during the second half winning all but one end after the eleventh.They emerged winners 22-10.
A 6 point to 2 victory by 37 shots to 28 is a very satisfactory result against a strong PML team and will cement our middle of table position.
David Palmer
Ingatestone "A" 28th May Away
We faced a very strong Ingatestone team which included both the Palmers and the Dodsons and played on their difficult green.
David Wood's rink (Mike Yates, Hazel Smith & David Palmer) up against an in-form Bernie Palmer trailed throughout but managed to keep the score reasonably close, only going down by three shots at the end 14-17
Jim Collins' rink (Tony Dalton, Mick Delay & Val Dalton) bowled superbly and after scoring a 5 on the eighth end, followed by a couple of threes, built up a substantial lead, sufficient enough to secure the bonus points, Notwithstanding the fact that they dropped a 4 on the final end they emerged winners 23-15.
This meant a win for the team 37-32 and 6 points which are enough to lift us from the bottom of the table.
Next week our first home game.
David Palmer
Witham "A" 21st May Away
One look at the very lush, heavily watered green and we knew that it was going to be difficult. Even the two opposition skips were overheard saying how heavy it was playing.
Having said this both rinks put up a very good performance before going down. Terry Cannon's rink (Mike Yates, Barbara Rowland & David Palmer) were always in contention but the rub of the green certainly favoured the opposition who brought off some very delicate wicks to steal ends !! The final score was 13-18
Dave Wood's rink (Tony Dalton, Mick Delay, & Val Dalton) also played a very close match before conceding 11-17.
So a defeat by 24 shots to 35 meant zero points for us. We always knew that life in Division 2 was not going to be easy, but with two difficult matches behind us now, I am confident that things will improve.
David Palmer
Great Baddow "C" 14th May Away
Not the welcome to Division 2 that we were hoping for !! Travel conditions meant that we were all late in arriving, but with 5 minutes to go before the start Dave Wood reported that he was just 15 minutes away. A decision was taken to start the trial ends and the match hoping that he would arrive in time. One hour and 40 minutes later he appeared by which time the rink in which he was due to play, bowling just 6 woods against 8, was 20 shots down. We could, of course have elected to bowl three woods conceding 25% of the score, but decided against this expecting to have a complete rink early in the match. Consequently Terry Cannon's rink (Dave Wood, Barbara Rowland & David Palmer) lost 8-26. Fortunately some excellent bowling by Ken Pipe's rink (Tony Dalton, Mick Delay, & Val Dalton) finished an extremely tight match, in which the lead had fluctuated wildly, winning 17-12. In the circumstances very happy to come away with 2 points.
David Palmer
David Palmer


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