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Request for a bill of particulars4/18/2024 In federal courts the Federal Rules of Civil Procedure have replaced the use of a bill of particulars with a motion for a more definite statement. State codes of Civil Procedure impose rules that govern the use of bills of particulars in civil actions brought in state court. It is not to be used as a discovery device to learn the evidence or strategy to be used at trial by the opposing party. A bill of particulars is neither a Pleading nor proof of the facts it states, but, rather, an elucidation of a pleading. It also serves to expedite the orderly progress of judicial proceedings by reducing, if not eliminating, the need for the amendment of ambiguous or vague pleadings. Its function is to give the party who requests it knowledge of what the opposing party has alleged in order to protect the party requesting the bill from surprise and in order to establish the real issues of the action. A bill can be submitted either voluntarily or pursuant to a court order for compliance with the demand. Although usually requested by a defendant, it can be demanded by a plaintiff if the defendant makes a counterclaim for a setoff or asserts a defense against him or her. In civil actions a bill of particulars is a written demand for the specifics of why an action at law was brought. Contact Schlam Stone & Dolan partner John Lundin at if you or a client has a question regarding discovery obligations (and what to do if a litigant is not honoring those obligations).A written statement used in both civil and criminal actions that is submitted by a plaintiff or a prosecutor at the request of a defendant, giving the defendant detailed information concerning the claims or charges made against him or her. As this decision shows, a bill of particulars is intended to amplify the allegations of a pleading, not as a substitute for discovery devices, such as interrogatories. ![]() The scope of discovery in New York is broad, but it does not include the device discussed here: a demand for a bill of particulars. Accordingly, the defendants' separate motions, among other things, to strike the complaint insofar as asserted against each of them must be denied.Ī big part of complex commercial litigation is giving, receiving and evaluating evidence (this is called "discovery"). The defendants failed to demonstrate that the plaintiffs' delay in providing amended bills of particulars was willful. Accordingly, the order dated May 2, 2017, must be vacated.Ĭontrary to the defendants' contentions, the amended bills of particulars were sufficient given that the parties' depositions have not been held. Since CPLR 3104 did not authorize the J.H.O./Referee to determine the defendants' separate motions, among other things, to strike the complaint insofar as asserted against each of them based upon the defendants' objections to the plaintiffs' amended bills of particulars, and there exists no order of reference authorizing the J.H.O./Referee to determine the defendants' motions, the J.H.O./Referee was without authority to determine the defendants' separate motions, inter alia, to strike the complaint insofar as asserted against each of them. Since a bill of particulars is not a disclosure device but a means of amplifying a pleading, the present dispute over the contents of the plaintiffs' amended bills of particulars is not part of any disclosure procedure that CPLR 3104 authorizes a referee to supervise. We reverse.Īlthough the defendants are correct that the plaintiffs raise for the first time on appeal the contention that the J.H.O./Referee lacked authority under CPLR 3104 to issue the order dated May 2, 2017, this contention may be reached since it involves a question of law that is apparent on the face of the record and could not have been avoided by the Supreme Court if it had been brought to its attention. In the order appealed from, the Supreme Court denied the plaintiffs' motion to vacate. ![]() Thereafter, the plaintiffs moved to vacate that order. 03450, holding that a bill of particulars is not a discovery device, explaining:īy order dated May 2, 2017, a J.H.O./Referee granted the separate motions of the defendants New York Community Hospital and Hassan Farhat, the defendants Metropolitan Jewish Home Care, Inc., Metropolitan Jewish Health System, Home First, Inc., and Beth Israel Medical Center, and the defendants Yury Zamdborg and Ilya Bilik, inter alia, to strike the complaint insofar as asserted against each of them on the ground that the amended bills of particulars served by the plaintiffs in response to the defendants' motions failed to comply with multiple prior court orders directing the plaintiffs to provide the defendants with supplemental or amended bills of particulars. ![]() New York Community Hosp., 2021 NY Slip Op. On June 2, 2021, the Second Department issued a decision in Kramarenko v. ![]() Categories Commercial, Discovery/Disclosure Bill of Particulars Not a Discovery Device
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Four elements trainer earth kingdom4/18/2024 ![]() measure and compare Rei/Ajala’s biceps(only if you already asked rei to measure her before) added the option to come inside Lyka and Anka’s mouths during the scene where they enter Nami’s store. sex with Nami, Una, Lyka,, Anka and mysterious shadow girl(? also optional) – One of the elder council will show you how to use a stalagmite(optional of course) – Bumfun with Nagina or the spirit(left both accessible for bughunt purposes but if you got the white serpernt, that should work too) – Sex with Katara, while everyone watches. – There will be a scene with Zhuli and Varrick using a bottle Hint, Scenes that take place at the beach are where you’ll do most of your searching. – You’ll be required to find food and drinks for a party. I will probably take that part out in future versions, but for now it’s in.I’m going to forget a lot of the smaller changes and stuff I did like the changes I did to the volleyball game during book 2’s love route on Ember Island, but the biggest changes are as follows. If they weren’t pregnant there will be an option to retroactively make them pregnant. Oogi and Senna(optional of course)… ’nuff said.įinally, the pregnancies can be ended in an organic way for Korra, Jinora and Kuvira. Korra can give you a job… using her feet! And if you don’t interfere with the cardgame, she and her daughter will both provide some missionary fun. You might be under surveillance while being rewarded though…Īll the BeiFongs… all of them… will get something up the bum during a scene.Ī new visitor! Korra’s mom will arrive on the island. You’ll be rewarded by getting a hand and blow something from both her and her mother afterwards. Izumi will lose something which you’ll have to help her with. 2 from the beifong sisters, 2 from opal, 1 from izumi(bj scene), 1 from hawky, 1 from fishtits(talk to asami and kyĪ first), 1 from tylee(before handjob scene), 1 from katara on the beach, 1 from zhuli (during the new scene with her and varrick) Like I said, once you see Ikki jump(you’ll know it when you see it) you’ll have reached the end of the build.īottle locations. ![]() Serial fucking everyone on Ember Island island during the party(As you might imagine I took some major shortcuts to make this possible so don’t let your fantasy go wild) added the option to come inside Lyka and Anka’s mouth during the scene where they enter Nami’s store. If you ended up with the serpent no bumfun because the white serpent doesn’t buttocks. – Bumfun with Nagina or the spirit depending on whom you chose. – Sex with katara, while everyone watches. Hint, scenes which take place at the beach are where you’ll do most of your searching. I’m going to forget a lot of the smaller changes and stuff I did like the changes I did to the volleyball game during book 2’s love route on Ember Island, but the biggest changes are as follows.
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Reiboot crack registration code4/18/2024 ![]() Press the Home button until iTunes give a notification that the device is in recovery mode. When the device starts then releases the power button but holds the Home Button. After this press the Power and Home buttons for 10 seconds. You have to connect your iPhone/iPod to your Mac and turn off your device completely. Tenorshare Reiboot Crack can put the device into DFU mode so that the user can install the update manually. Before you start the process you have to read the procedure precisely. Tenorshare Reiboot Pro Registration Code Freeįurthermore, the extra thing about the recovery process is that it has some complex steps that you need to follow. You can recover almost every iDevice with this application. Tenorshare Reiboot 9.2.0 is fully compatible will all iOS devices. So, it can exit the DFU mode with one click easily. This software is easy to use and light-weighted. You can install this on Windows as well as MacOSX. Therefore, This can be installed on any Operating System. The only solution that is provided by Tenorshare is in the form of the Tenorshare Reiboot Registration Code Free software. ![]() In this mode, the device firmware is starting to get an update, and sometimes your device is stuck in that mode. The other issue that is faced by most users is the DFU mode which is the Device firmware Update mode. Also, without this application, the device’s data will also be lost. There is no need to waste the time restoring the device. ![]() But with Reiboot Pro Patch the user can solve the issue with a single click. The only solution that a user thinks of is to reset the device. Sometimes when the device gets a firmware update then it starts to unresponsive or restarts the device continuously. With a single click, the device gets back from the recovery mode without any factory reset or data loss. These tools help the user to put or get back their iDevice into recovery mode. Tenorshare Reiboot Pro 9.2.0 Crack Download is one of the best handy tools for iOS devices that has powerful features and tools.
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Ancient nordic glyphs4/18/2024 Symbols themselves were thought to have power. Symbols and motifs visually convey (instantly and across language barriers) messages that were deeply meaningful to the women and men that held them. The stories of Odin, Thor, Freya, or the Viking heroes that we have now were all passed on by careful word of mouth until they were finally written down as the sagas by descendants of the Vikings centuries later. So, while the Norse culture was very rich in poetry, stories, and songs, this was all transmitted orally. The Vikings also had letters (known as runes), but writing itself was sacred and even magical. Thanks to the Marvel movies, nearly everyone now knows about Thor's hammer (Mjölnir) which was a very popular choice for Vikings to use in their jewelry as represented in this ancient Danish artifact to the right. The cosmic forces and fate were active in everything. There was no separation (as there so often is today) between faith and reality. The spirituality of the Norse Vikings was so ingrained in their culture and thought process that they had no word for religion. ![]() Symbols played an important role in Norse culture. Vegvisir (Post Viking Age Icelandic: Compass)ĭragon (Jormungandr and other Norse Dragons)Ĭats, Bears (Freya's Cats, Berserker Bears, etc) Ægishjálmr (Post Viking Age Icelandic: Helm of Awe) "By the end of the 10th century the Vikings in Ireland had adopted Christianity, and with the fusion of cultures it is often difficult to distinguish between Viking and Irish artifacts at this time." or Slavic, English, etc. The National Museum of Ireland stated the following: Many of the last few generations of these Vikings were often the children of a Celtic mother. ![]() We offer an entire separate article discussing the controversy of their origin. Other examples of non-Viking aged symbols include the Troll Cross (not shown) which is based on later Swedish folklore.īy the end of the Viking age, Vikings were already beginning to blend with the cultures they settled in. Two other very popular symbols known as the ' Viking Compass' (Vegvisir) and the ' Helm of Awe' (Ægishjálmur) which were both first found in Icelandic magic books from the 19th century (roughly 800 years after the Viking Age ended). Also, we would add that many of our customers are not just fans of what happened during "the Viking Age" but the entire history of our Nordic ancestors. But of course, just as we can still interpret these runes a thousand years later, it makes sense that many of the Vikings were able to do so as well. As well, the original true meaning of these symbols are simply educated guesses by archaeologists, anthropologists, and historians.Ī few symbols that are often considered 'Viking' actually have no proof of ever being used during the Viking age, such as the the Elder Futhark runes which most scholars believe were replaced by the Younger Futhark runes around the beginning of the Viking Age. ![]() Some of these iconic images were primarily used before or not until well after the Viking age. It is helpful to understand the true origin and background of each symbol.
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There are many different open source licenses but they all must comply with the Open Source Definition - in brief: the software can be freely used, modified and shared. Programs released under this license can be used at no cost for both personal and commercial purposes. Open Source software is software with source code that anyone can inspect, modify or enhance. Freeware products can be used free of charge for both personal and professional (commercial use). DimScreen is 100% FREE and can be used even on legacy Windows OS versions such as Windows XP.įreeware programs can be downloaded used free of charge and without any time limitations. It can reduce and increase brightness on any screen, finally enabling desktop PC users to easily set their monitor or TV brightness levels depending on their environment (day or night) or content that they are enjoying (bright documents, multimedia, gaming). The only alternative to this issue can be found in the setting called “ Startup dimming” that can set the display brightness to the desired level on app startup.ĭimScreen is a very useful app that does its advertised job very well. The user can set its preferred key combination, but the ability to set a shortcut for a specific brightness amount (let’s say 70%) is not possible. However, only three keyboard shortcut tools are offered – activation of the app, decreasing brightness and increasing the brightness. User can click on its icon and access a large dropdown menu with 0-100% brightness selection in the steps of 10%, and a Settings window where keyboard shortcuts can be assigned. Its interface is truly minimal after the app has settled to your taskbar. ![]() Simply extract the app to any location on your local or external storage drive, and run the app. This app changes this status quo by introducing a lightweight background service that will monitor for user’s keyboard shortcuts and switch the brightness according to the users’ needs.ĭim Screen app is distributed online as a portable archive that features no automated installer and uninstaller. While laptop users have enjoyed this feature for decades as one of the best ways to prolong the life of the finite built-in battery, PC desktop users have never gotten a streamlined way to regulate the brightness of their monitor. ![]() ![]() DimScreen is a useful system utility that can help all PC users, and not only laptop owners, to easily control the screen brightness of a PC display.
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Convert pdf files to jpg4/18/2024 If you don’t want to upload PDF documents via our online tool at all or have restrictions concerning online software, the Smallpdf Desktop App is the ideal alternative. Therefore, both JPG and PDF files won’t be stored on Smallpdf’s servers longer than the stated period. We have a built-in system to remove both uploaded and converted files after every hour. You don’t have to worry about file retention at Smallpdf. Then, if you want the file in JPG format, you can always switch it back to PDF or JPG. Optical Character Recognition (OCR) is available for Pro users to transform scans into editable. The result will be an image file that looks exactly how you want it to.Ĭonversely, if you wish to edit written content, converting the PDF to a Word file would be better. These tools allow you to apply any changes you’d like before you turn your PDF into a JPG. You can merge, split, annotate, or even eSign the file before saving it as an image using the PDF2JPG converter. Although we don’t have an image editor, there are many tools on our site to edit your file while it’s still in PDF format. It depends on what you want to accomplish. In our example, you’d have the entire page, including the graph and the text, as one image. ![]() On the other hand, if you want to convert and edit the file page by page, go for the first option. Say you have a PDF containing a report with a summarizing graph this option creates an image just with that graph. The latter will extract each image from your PDF file into a standalone JPG image so you can edit individual images. The first option will save each page of the PDF file as a JPG.
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Tribal wars points table4/17/2024 ![]() In what's also called the First French and Indian War, England, allied with the Iroquois Confederacy, battled France, with support from the Wabanaki Confederacy, for fur trade and territory control in Colonial Connecticut, Massachusetts, New Hampshire and New York. With rising tensions among the Spanish and Pueblo Indians in New Mexico, the Pueblos, led by Po-Pay, sieged Santa Fe, destroying Spanish settlements and forcing the colonists into a 12-year retreat. Pueblo Revolt: August 10 to September 21, 1680 It ended with Metacom’s death on August 12, 1676. Metacom and his coalition retaliated, attacking colonists and settlements, who were aided by the Mohawks and Mohegans. Also known as the Great Narragansett War, Metacom, named King Philip by the English, took place in Rhode Island, Massachusetts, Connecticut and coastal Maine. ![]() The execution of three of Wampanoag Chief Metacom's men, in addition to increasing encroachment on Native American land, spurred one of the deadliest conflicts per capita in American history. Lawrence River against French-supported Algonquian-speaking tribes. Fearing more attacks, many Pequots left their territory and the war ended with the Treaty of Hartford, which dissolved the Pequot nation.Ĭoveted beaver pelts, traded with the English for firearms, tools and other supplies, were the focus of the bloody 60-year fur trade battle led by the Iroquois Confederacy of Ohio's St. With the British competing to control the fur and wampum trade in Colonial Connecticut, tensions led to a series of conflicts, including a May 26, 1637, attack by English militia and Narragansett and Mohegan tribe members against the Pequot at Mystic, ending in hundreds of Pequot deaths, many of them children and women. The English retaliated, attacking Native American villages, raiding and destroying crops and forcing them from their land. As part of the decades-long Powhatan Wars, Powhatan Chief Opechancanough led an attack that left nearly 350 of some 1,200 colonists dead.
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Best editing app to make youtube videos4/17/2024 ![]() Editing tools include speed, sound and colour adjustments, freeze frame and reframe options, and a handy horizon levelling tool that can help correct wobbly camera work and ensure your final video appears level. GoPro's own app allows users to sync footage to their smartphone in order to begin editing clips before uploading them directly to YouTube. ![]() GoPro footage continues to feature highly among the most popular videos on YouTube, with riveting, adrenaline-fueled video of everything from skateboarding to cycling and skydiving. Subscription required for increased storage That shouldn't put off YouTubers who are serious about their editing because the KineMaster offers a slick and intuitive interface and a wealth of features. ![]() The app is free to download and use on iOS and Android devices, but it requires a subscription of $4.99 a month to remove ads, create videos without a watermark and to export at the highest quality (1080p and 4K). However, we did think it wasn't quite as pro-looking as we would have liked. Users can edit multiple layers of video (up to nine depending on your device) and overlay up to four audio tracks on a single clip. The powerful range of tools includes eight blending modes and overlays plus a reverse function that permits focal shifts and in-camera transitions. When we tested it, we appreciated the intuitive and slick interface and impressive range of features. It offers dozens of editing options and features that you might normally expect to find in professional editing software, including a chroma key that can composite multiple videos for green screen post-production. If you're looking for one of the best video editing apps for YouTube that allows green screen edits, the KineMaster app is one of the most advanced smartphone editing apps available. Subscription required to remove watermark A monthly subscription for a paid plan starts at $9.99/£9.98. A free starter package includes 2GB of storage. You can access Adobe Stock for imagery and graphics.Īvailable for both iOS and Android devices, Premiere Rush comes as part of Adobe’s Creative Cloud package, so videos can be edited across Adobe’s suite, including on Premiere Pro. Audio features include voiceovers and ducking. When we tested it, we appreciated how the app allows you to edit up to four video tracks and three audio tracks with a range of tools such as customised titles, colour corrections, speed adjustments, and a slew of transition options (though we found the editing options a bit limited). As a result, it's more streamlined than its big sibling, with large icons and an intuitive drag-and-drop functionality that helps to make video editing on the go quick and easy. This video editing app also syncs your projects to the cloud, so you can access your footage from anywhere.Premiere Rush aims to give smartphone users many of the tools from the top-rated desktop software but without requiring hours of study and practice. It works across all devices, and because the video editor has a built-in camera function, you can capture footage and then edit and share to social media from a phone, tablet, or desktop.Īdobe Rush provides professionally designed motion graphics templates right inside the app, and you can find even more of these on Adobe Stock. This video app allows you to do almost everything you need with regard to titles and branding. The export options make it easy to post on social media platforms like Facebook, Instagram, Snapchat, Twitter, and Vimeo. This video maker app is much easier to use than Adobe Premiere, and gives you four video tracks and three audio tracks to place sound design and music. If you want one of the most robust apps to make edits, Rush is a great choice. ![]() Adobe Premiere Rush is a cool video editor with music that allows you to quickly edit video clips and upload them to your favorite social networks.
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News anchor green screen background4/17/2024 The trending templates in this solid color can be edited with the maker or downloaded as it is. The green screen templates include a woman working and thinking on a green screen and a businessman showing off his profits.Ĭhanging the narrative of green screen templates download, Storyblocks is one of its kind in the world. This royalty-free platform has taken upon the world from animals in a green screen to human acting and recording in one. To access a wide range of happy birthday green screen templates, find Videvo at your bedside. Mixkit has got to be your first choice if you care about your visuals and profits in the media industry. The news template includes a news anchor with a green screen, a newscaster with a tablet in a green wall, and a journalist sharing the news. You can rely on this royalty-free marketplace to provide you news template green screen. The templates include a woman in front of the green screen, a retro television in green background, a builder working on a solid green screen, and animals.Īre you a journalist in the creative industry? Or a news anchor making your way in the field? The green screen templates download present a wide variety of workability in the media industry. There is a green screen video call, and Santa Claus is taking a video call on the green screen. The frame rate of these templates can be decided as a user finds it necessary. A stage opening in green screen, ocean with a green background, and special smoking effects in the green screen are some examples of the templates.Įnvato Elements has covered you all if you are looking for a video call template green screen. The green screen templates are provided in great quality. Offering presentations, video effects, sound effects, and PNG images, Pikbest knows it all. Pikbest is one of the most renowned platforms to access the best templates green screen. You can also use happy birthday green screen templates via Videezy. The templates include colorful confetti falling on the green screen, a flock of seagulls flying on the green screen, or a woman dancing on the green screen. With Videezy, all creative professionals can take control of their workplace.Īs far as green screen templates are concerned, Videezy doesn't stay behind. The first website to provide the user with royalty-free assets is Videezy. The subsection introduces ten impeccable platforms for green screen templates download. Let us start! Shall we? 1. Hence, websites such as Envato Elements take pride in providing templates and effects. The pre-designed templates allow the users to save time and create something out of the box. 02 Bonus Tips: Green Screen Templates for Filmora Video Editor Part 1: 10 Popular Websites to Download Green Screen TemplatesĪre you a film producer? Or are you a content creator on YouTube? If you are any of these, you would surely understand the template green screen and its importance in the industry.
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Clone mac hard drive to smaller ssd4/17/2024 Be sure to check the instructions provided by the software vendor and create the bootable media if necessary.ħ. Create a bootable USB or DVD: Some cloning software requires you to create a bootable USB or DVD to initiate the cloning process. Research and select the one that suits your needs best.Ħ. There are several reliable options available, such as EaseUS Todo Backup, Clonezilla, and Macrium Reflect. Gather necessary tools: To clone your hard drive to an SSD, you’ll need the appropriate cloning software. Before proceeding, ensure that your computer meets these requirements to avoid any compatibility issues.ĥ. ![]() Identify system requirements: Each cloning software has its own set of system requirements. If the data size exceeds the capacity of the smaller SSD, you’ll need to free up space by removing unnecessary files or transferring some data to an external storage device.Ĥ. Evaluate the data size: Assess the size of the data on your current hard drive. It’s recommended to have at least 20% free space on the destination drive to ensure smooth operation.ģ. Check the available space: Before attempting to clone a bigger hard drive to a smaller SSD, make sure that the SSD has enough space to accommodate the data on the hard drive. You can use an external hard drive, cloud storage, or a backup software to create a secure backup of your data.Ģ. ![]() ![]() This ensures that if something goes wrong during the process, you won’t lose your important files. Back up your data: It’s crucial to create a backup of your data before attempting any disk cloning. Before starting the cloning process, it’s important to take a few preparatory steps to ensure a successful and hassle-free experience. |