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This exuberant autobiography takes us through movie director Norman Jewison’s entire career, from the fluffy Doris Day comedies of his early years to his most powerful dramas. Over more than forty years, he has made films that are not only highly entertaining, but at times manage to make a valuable moral statement about the world.

Jewison, who was born in Canada in 1927, describes a pivotal moment in his life when, after World War II, he traveled through the American South in his Canadian military uniform and was browbeaten by a bus driver after he, not understanding the system of segregation, chose to sit in the back of a bus. The incident made a powerful impact on him, and eventually resulted in a determination to portray the ugliness of racial injustice cinematically. The outcome of this determination is a collection of groundbreaking movies which illuminate the inequities in an America divided into black and white.

Jewison’s powerful 1967 drama In the Heat of the Night stars Sidney Poitier as strong, outspoken black Philadelphia police detective Virgil Tibbs, who ends up stranded at a Mississippi train depot in the middle of the night. When a wealthy factory owner is murdered, Tibbs is hauled in for questioning and ends up collaborating with chief of police Bill Gillespie to solve the crime. The entire film crackles with racial tension as Tibbs comes up against dangerously violent citizens stirred up by the businessman’s death and Tibbs’ powerful and unyielding presence.

Jewison expressed doubts about being able to get the movie made to Senator Robert F. Kennedy; Kennedy urged him to persist, saying, The time is right for a movie like this. Kennedy was right; the film was received with critical acclaim and recognized as revolutionary for its time, the first portrayal of a strong, independent black man who did not back down in the face of white aggression.

Jewison has continued to make pointed statements about race; in the 1984 A Soldier’s Story, an Army investigator (Howard Rollins) looks into the murder of an unpopular black sergeant in the South; the 1999 drama The Hurricane, depicts the true story of boxer Hurricane Carter’s conviction and imprisonment for a crime he didn’t commit, and the man’s ultimate vindication.

Jewison’s cinematic range covers just about every genre. The Russians Are Coming! The Russians Are Coming! (1966) is a hilarious and touching account of a Russian submarine which beaches itself on a sandbar off the coast of Martha’s Vineyard. Part of the crew goes ashore and causes a panic among the island’s residents; when the rest of the crew manages to free the submarine, it ends up tooling into the town harbor, threatening a violent confrontation which is averted when the islanders and the Russians must work together to save a small boy from danger. The movie was a resounding success in the Soviet Union as well as in the U.S., and may have done as much for détente between the two superpowers as any politician in either country.

Moonstruck (1987), an off-beat romantic comedy starring Cher and Nicholas Cage; In Country (1989), a brooding analysis of the effects of the Vietnam War on an emotionally damaged vet (Bruce Willis) and his niece (Emily Lloyd), herself an orphan of a soldier who didn’t make it home; The Cincinnati Kid (1965), in which Edward G. Robinson and Steve McQueen face off in a gritty and psychologically intense poker game are all markedly different from each other, as are all his movies. One trait each of Jewison’s movies does have in common with all the others is a deep understanding and sympathy for human nature; even his villains exhibit a depth and a complexity uncommon in moviemaking.

The book contains inside info on the making of each of Jewison’s movies and plenty of fascinating tidbits about the actors and other celebrities he’s dealt with over the years. The result is a book which offers insight into the author, a great overview of his movies, and a thoroughly enjoyable read.

Aldene Fredenburg is a freelance writer living in southwestern New Hampshire and frequently contributes to Tips and Topics. She has published numerous articles in local and regional publications on a wide range of topics, including business, education, the arts, and local events. Her feature articles include an interview with independent documentary filmmaker Ken Burns and a feature on prisoners at the New Hampshire State Prison in Concord. She may be reached at amfredenburg@yahoo.com amfredenburg@yahoo.com .

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Supplies

Supplies you will need before you bring your new puppy home: The first thing you’ll need is a travel crate for your dog’s trip home. You’ll also need to buy some high quality puppy food and bowls for food and water. Your vet, breeder or shelter personnel can tell you which brands of food are the best. Other items you’ll need to get in advance of the new puppy’s arrival are: an adjustable collar, a leash, toys and bedding. Don’t forget to make an appointment with your veterinarian for your puppy’s first check-up!

No food should ever be fed to a dog unless that food is put into some type of a container. The practice of putting food on newspapers or directly on a cage floor or the ground serves no purpose except to contaminate the food from the surroundings. This method also contaminates the surroundings from the food, draw flies, increase parasite transmission and soil the dog’s coat. The money, time and energy a dog owner thinks he is saving by such feeding practices are completely wiped out by the loss of the dog, the time spent to clean floors and combat insects, or the effort needed to put a food-soiled coat back into show condition.

Crate Training

Crate training is a method by which your dog is taught to stay in a crate within your house for prolonged periods of time. This is an especially useful technique for dogs that would otherwise tear up the house when left alone. The best time to start crate training is when your dog is still a puppy. Leave him in the open crate for brief periods of time at first and then begin closing the door behind him.

Make sure that your puppy’s crate experience is always positive by giving him treats and rewards whenever he enters the crate. Once he is comfortable, you can leave him in the crate for increasing periods of time - give him his meals there as well.

Never use the crate as punishment. You want your dog to feel that his crate is a safe refuge, not a prison. Furthermore, the crate is a place where your dog can go to feel safe and secure while you and your family are away from home for a few hours. When you’re home, your dog should be out of his crate and socializing with his human family.

Obedience

Teaching basic obedience skills to a dog can be exciting as well as challenging. Having problems on where to begin? Start by doing your homework. A student can only be as good as his trainer, right?

The first lesson in obedience is to get your dog to pay attention to the commands. You want to start by calling his name and then using a keyword like “watch” or “look” afterwards. This way, he will associate the words to a command. Once you’ve got his attention, the lessons can begin.

You want your dog to be able to pay attention for a short length of time. Try keeping his attention by doing attention exercises. One example would be to hold a toy or dog treat in near your mouth and then give him the keyword command.

Each time he takes the time to watch, praise him. The more you do this exercise, the more time he should be able to pay attention to you. Try getting him to watch for at least a minute. Let him know that he is doing a good job by rewarding him. Dogs learn best this way.

Because dogs have such short attention spans, they get distracted pretty easily. Choose a place that is free of other distractions such as other pets, children or loud noises. Training sessions should only last approximately 30 minutes tops. Usually, if you go over this time limit, the dog will get restless and easily distracted.

If your dog isn’t learning very quickly, you may become frustrated. Don’t take that frustration out on your animal. A few things to remember before starting your obedience lessons:

1) Never cause pain to your dog (this will cause him to shy away or become aggressive to you.)

2) If he begins to become distracted, change the tone of your voice (this doesn’t mean raising it)

3) Consistency can not be stressed enough (animals are like children, if you’re not consistent, they will become confused as to what is expected)

Teaching your dog basic obedience commands will make for a more obedient and more pleasant dog to be around.

The first command to start off with would be to sit. You must use the word sit while teaching him so that he can relate the word with the action. Start by gently pushing his backside down and saying the word “sit.” Eventually he will catch on to the concept.

The second command is “down.” Dogs can become pretty hyper when they get excited. Jumping up on their owner’s lap is usually how they express their excitement. If you have a big dog or have other people over, you might not want them pouncing about. When they jump up, tell them “down.” Do not pet them or act excited to see them while they are on you. Continue to tell them “down,” and even place their legs down if you have to.

Next is the command of “stay.” This command is a good one to know especially if you have a rambunctious hyper dog. You can teach him stay, for example, by putting a treat or something desirable on the ground. As he moves toward it, tell him “Stay.” Another good idea would be to put your hand up while saying the word “stay.” When he begins to become obedient in this area, you can move further away from him. This will cause him to become more daring and he will probably take a step forward to see how much he can get away with. When he does this, continue to put your hand out and tell him “stay.” He has to know that even though you are moving away, you can still see what he’s doing and expect him to continue to obey.

After you’ve mastered the stay command, you will move on to the come command. Once your dog has learned to sit and stay, he will need a command to know when it’s ok to get up and approach you. They may be a bit confused at first, but with a change in the tone of your voice, he will soon understand. Put a little excitement in your voice when saying the word “come”. He will pick up on it. You might also want to pat your leg when you say come.

Stand is the last command to achieve. This is where your dog is allowed to get a little excited but not in a pouncing kind of way. When teaching your dog to stand, pat your hands on your chest and, once again, put a little excitement in your voice, so that he knows he’s aloud, under certain circumstances. He will begin to know the difference.

Teaching your dog basic obedience, if possible, should be taught as soon as you and your dog are ready. Remember be consistent with the commands and don’t forget to have fun!

Arild Myklebust runs the free doggroomingtips.ws http://doggroomingtips.ws website. Visit now, to get more useful Dog Tips & Articles and also a Free Email Newsletter. For other topics, check out his freetips.ws http://freetips.ws website.

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Adding dietary nutritional supplements to our diets has for years been advocated by nutritionists and nutritional research scientists.

Now, the American Medical Association has reversed its long held policy regarding the need for nutritional supplements.

The AMA now recommends daily use of these nutrients they had previously considered unnecessary for health.

Doctors now recognize the absolute need for everyone to take dietary nutritional supplements every day.

The AMA has finally recognized and accepted the preponderance of data that proves a direct link proving that the nutrients in our diets are so poor that they are a major cause of our diseases.

While the most commonly recognized nutritional supplements are vitamins, many more nutrients are classified as nutritional supplements. They include:

1) Minerals,
2) Amino acids,
3) Enzymes,
4) Essential fatty acids,
5) Fiber

Our health and wellbeing is greatly dependent on the food we eat. There simply is no other way to obtain the nutrients we need except through eating.

As early as 1936 the Government reported on the impact of depleted soils. One excerpt from this report states:

Laboratory test prove that the fruits, the vegetables, the grains, the eggs, and even the milk and the meats of today are not what they were a few generations ago (which doubtless explains why our forefathers thrived on a selection of foods that would starve us!) .

In agreeing with what nutritionists and research scientists have been saying for years, the medical profession is confirming that our food no longer is capable of providing the essential elements our bodies need.

At first glance this may seem unimportant but it is a major change in policy that should not go unrecognized by the general public.

The reasons for this complete reversal of policy are many:

1) Soils are depleted of the nutrients they once provided.
2) Fruits and vegetables are picked too early.
3) Processing destroys nutrients especially enzymes.

Every element needed for growth, health, wellness, and even survival must come from the food we eat. This is because our bodies are closed systems.

Virtually every leading cause of death today was either unknown or only a minor health concern 50 years ago. Scientific research has proven a definite and immediate link for this to the changes in the food we eat,

Americans, in general, want to improve their health. Over 43% of Americans now take some form of nutritional supplements.

Probably this is a result of having experienced a general feeling of being tired, exhausted, or a sustained feeling of simply not feeling the way we think we should feel.

This indicates that we are concerned enough to take some action. The question is whether it is enough.

We probably picked our nutritional supplement, most likely a vitamin or two, based on some advertisement that described our symptoms .

The problem is, if we believe that our diet is deficient in one or two vitamins, is it realistic to assume that we are getting all the other nutrients that we get from the same source?

We are the victims of advertisers who tell us part truths.

Companies that market food make large sums of money by capitalizing on our desire to be healthy. Two of the biggest buzz-words in food advertising today are Free Radicals and Anti-Oxidants .

Free radicals have been proven to cause aging and disease, make changes in DNA structures, suppress the immune system and cause many other health related problems.

Anti-oxidants are vitally important to our health because they destroy free radicals.

Fruit juices provide vitamin C which provides anti-oxidants.

Where this line of advertising is misleading, and possibly dangerous, is that the public is led to believe that simply drinking a glass of juice a day will significantly improve one’s health. The glass of juice is beneficial but it certainly is not the cure-all to our nutritional deficiencies.

Vitamin C and anti-oxidants are absolutely vital for health, but so are the myriad of other vitamins, minerals, enzymes, amino acids, and essential fatty acids that our bodies need.

Furthermore, anti-oxidants are produced by many other elements of our diet, not just vitamin C, and vitamin C is needed for many other processes in the body.

If one is truly concerned about their health and that of their family, they need a complete dietary nutritional supplement.

Paul Wallace has researched nutritional supplements. The deeper he looks, the more he is convinced of their benefits. For a FREE 10 part course on the nutrients required for health, visit www.vitaminsimprovehealth.com/course_on_vitamins.htm http://www.vitaminsimprovehealth.com/course_on_vitamins.htm .

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If there has ever been a growth field, it is computer security certification. With a good computer security certificate from a reputable college, you can go anywhere. Even if you go to one of those IT training schools the you see advertised on daytime television, your certification computer security will probably open doors for you. There are all kinds of jobs for computer security experts, from Homeland security to private industry. You can help prevent data theft, write computer security software, or investigate hackers for law enforcement. For a security certified network professional, the sky is the limit.

I had never expected to get into computer security certification when I was growing up. If anything, I was on the other side of the law. Many of the experts in computer security certification were hackers when they were kids. I used to try to break into all kinds of things just to see if I could do it. It wasn’t a matter of malicious intent. I just wanted to test the boundaries and see what holes computer security systems had in them. To me, it was more of a game or an intellectual exercise than an act of vandalism. Unfortunately, law enforcement did not see it that way. I was caught when I was 16 years old, breaking into the offices of a major multinational corporation. Because of my age I got off with probation, but I realized that I had to turn my life around.

I got my computer security certification training after a few years of soul-searching. To be honest, I was tempted to give up computer hacking altogether, but finally I realized that this was not the course for me. I was just too fascinated by computer networking and the security issues that it involved. I knew that, if I did not go into computer security, it was only a matter of time before I would get into trouble again. Temptation would overwhelm me, and I would suddenly found myself hacking into something or other. Although a I could get away with it for years this time (I had learned from my mistakes) is still didn’t seem to be worth the risk. In the long run, I would get caught. That is why I got my computer security certification. As a certified information security auditor, I can make my hobby into my life and stay on the right side of the law.

John Mailer has written many articles about dogs and puppies and how to train them.His main business is as an internet marketer. www.howtostartonlinehomebusiness.com http://www.howtostartonlinehomebusiness.com

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Radio Control Boats

Like regular boat racing, remote control boat racing offers some real excitement to the modeling enthusiast. Keeping a well maintained model boat in top condition takes a lot of effort and dedication but the rewards are plenty. A well maintained model boat will run longer, and win more races then a poorly maintained boat. Radio Control boats come in many sizes and types. Most of these model craft are powered by either nitro, or battery. The key to keeping one of these craft in good order starts with proper storage. The key to proper storage is having a good boat cover.

Nitro Vs. Electric

Electric motors require large batteries. These batteries may cost up to $30.00 each and will usually last for 5-6 minutes of racing time. Rechargeable Batteries will require time to cool off prior to being recharged and so running multiple races will usually require keeping extra batteries on hand. Nitro boats on the other hand do not require expensive rechargeable batteries. A 10-12 ounce tank of fuel will last up to 12 minutes in a race. Running additional races requires nothing more then a refilled tank. the only disadvantage to running a model on nitro is the noise made by the motor, which is considerably louder then the noise made by an electric motor.

Model Boat Covers

The easiest way to ensure your model boat stays in good working order is to provide it with a proper cover while it is in storage. Model boat covers are available through most modeling and specialty hobby stores as well as from various online sources. These boat covers may be made from a number of different materials in a variety of grades. These boat covers may be custom made to fit your specific model boat or they may be sold off the shelf in a variety of different sizes and styles. The strongest will protect against mold, mildew, water, Ultraviolet light, and dust. The basic ones will protect against light and moisture. No matter which grade you purchase both will go a long way to ensuring that your model boat lasts for many years to come.

Kerry Ng is a successful Webmaster and publisher of The Boat Cover Blog. Click here for more helpful information about Boat Covers: www.boatcoverinfoblog.com/boat-covers http://www.boatcoverinfoblog.com/boat-covers

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We’re told by Jesus to go out into the whole world and tell others about the Good News?

But just how can we do that?

A lot of people think you need to be a Bible scholar r attend seminary. They worry that they don’t know enough. Or they’re not comfortable talking about spiritual issues.

If that’s you, relax. You can be an effective witness of your faith with your lifestyle. Here’s my top ten suggestions on how to share your faith with a nonbeliever:

1. Look for common interests. With most people, it does little good to hit people over the head with a Bible. Instead, talk about common interests, problems, experiences. In other words, build a relationship.

2. Listen more than you talk for the first few minutes. Ask questions. How did that make you feel? What did you think about then? Then what? Open -ended questions are always the best.

3. Empathize. Sympathize. Let your eyes and body language convey to the person that you are listening and understand. Don’t pass judgment. Don’t ever say I know just how you feel. you don’t.

4. Ask questions that let you go for Biblical direction. Have you read what the Bible says about this? Or Can we see what the Bible says about this? Always present the Bible as an authoritative resource. Try some humor.You know the acronym for BIBLE: Basic…Instructions…Before…Leaving…Earth.

5. Share your story. Tell about your life BC - Before Christ. And your life AC - After Christ. Learn to be able to give your personal testimony in three minutes or left.

6. Don’t be afraid to say you don’t know the answer to a particular question or problem. Offer to check it out and promise to get back with an answer or scriptural reference. And do so.

7. Remember your witness. Often, before a friend or coworker seeks spiritual counsel, they’ve been watching you for weeks. If you stress out or lose your temper, apologize. No one expects you to be perfect. It’s how you handle difficulties that often open the door for a conversation.

8. Seek out open doors for a continuing dialogue. Don’t try to deal with every issue in one meeting. Take time to discuss one or two in depth. Try to arrange follow up discussion times.

9. Invite them to church. There they can find true spiritual community. Offer to pick them up and drive them and treat them to lunch afterwards. Surveys show that more than 90% of those invited to attend a church service by a freind will do so.

10. Practice lifestyle evangelism. Have a Bible always handy. Wear Christian T-shirts or jewelry where appropriate. Many a spiritual conversation has started because of a T-shirt.

See? That’s not so hard, is it? Evangelism is all about just being you. And that, anyone can do.

Mike Fletcher publishes the Online Christian Shopper ( www.onlinechristianshopper.com http://www.onlinechristianshopper.com ), which specializes in evangelism products like Christian T-Shirts and Christian jewelry.

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Many brides ask whether or not they should purchase wedding insurance. In my opinion the answer should be an unequivocal Yes. According to TheWeddingReport.com the average cost of a wedding today is more than $26,000. That’s more than some people pay for a car, and you wouldn’t think of not insuring your brand new car, would you? It just makes sense, then, to purchase a wedding insurance policy that will cover many of your wedding costs if you need to postpone or cancel the ceremony and reception. This type of wedding insurance is crucial especially if your cost of rescheduling the wedding will be very high.

Many couples overlook wedding insurance when planning a wedding because they don’t believe they will need it. After all, there is nothing romantic or exciting about wedding insurance and what could possibly go wrong. If you were to ask couples who had their wedding and reception planned in New Orleans before Hurricane Katrina hit, what advice do you think they would give you. Now a hurricane is an extreme weather condition, but wedding insurance provides coverage for just such a weather event. Wedding insurance, however, will not cover postponement of your wedding due to a rainy day.

Once you’ve selected your vendors and submitted your deposits, you have made a serious investment. Wedding insurance protects your investment throughtout the planning process, and the event itself. Consider these events that are covered in your wedding insurance policy.

*the caterer or your reception venue closes down unexpectedly before your wedding
*your wedding photographs are damaged or lost
*a family or wedding party member is injured or becomes ill or dies
*lost or stolen wedding rings*
*your wedding attire (if your dress is damaged or fails to arrive)

Sorry kids, you’re out of luck if either of you gets cold feet. Changing your mind at the last minute is not covered by wedding insurance.

Just like any other type of insurance, you can purchase wedding insurance in a number of different policies. When compared to the cost of the event itself, wedding insurance is relatively inexpensive and as important to your special day as your bridal gown, cake and flowers. Whether you are having a destination wedding or a large wedding in your home town it is a good idea to purchase insurance for your wedding and a small price to pay for peace of mind.

Sheilah Marshall is a wedding planner/decorator and webmaster. For wedding supplies and more wedding related advice visit us at www.allthatsclassy.com http://www.allthatsclassy.com

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Anyone who decides to bathe their cat, must be prepared for a long afternoon. Most cats do hate getting wet and they’ll probably be very clear about letting you know that they don’t like what you’re doing. So think it through ahead of time. Get everything you need lined up and be prepared to remain patient, kind and good humored in the face of your cat’s wrath.

Before you begin bathing your cat, you will need to gather a few supplies. At the minimum, you will need two absorbent terry cloth towels, a pet safe shampoo, a pet safe conditioner, a sponge, and a sprayer attachment for your sink or tub. If you don’t have a sprayer attachment, you should have a pitcher or large cup that you can use to scoop clean water over your cat’s body. Ideally, you should also have a non-skid mat to help your cat feel more secure.

If you decide to bathe your cat in the tub, you may have a harder time holding on to him if he becomes frightened. However, it is usually easier to keep him contained if he escapes in a bathroom than in the kitchen.

Place your non-skid mat in the bottom of the sink or tub. Add two to three inches of warm water and gently place your cat in the tub. Talk to him quietly and reassure him. He will most likely settle down within a few seconds. Once he is calm, begin to wet him down. If the sprayer attachment scares him too badly, you may have to pour water over him using your pitcher or cup, instead. Do not pour water on his head. You will clean his face later.

Once your cat is wet enough to shampoo, apply the shampoo with your hand, massaging your cat’s fur and talking kindly and calmly to him while you do. Rinsing the shampoo is probably the most difficult part of the bath. It’s important you do it thoroughly even if your cat objects, because the residue from the shampoo will irritate his skin.

Now, work a palm sized dollop of conditioner into your cat’s coat and then rinse it out. This step is actually optional if the cat has short hair. However, conditioner will not hurt a short haired cat, so, if he is not too upset, you may still want to use it.

Once your cat’s body is clean, dampen your sponge and use it to carefully wipe down his face. Pay close attention to the area under his eyes.

The drying stage is the easiest. Wrap your cat in a towel and rub him down. Change towels when the first one is wet. Get your cat as dry as possible. If you have a long-cat, some people suggest a hair dryer, but most cats are afraid of the sound. Use your judgment. If you do use a dryer be careful that it doesn’t get too hot for his skin. Tell your kitty he smells wonderful and is going to look so beautiful now that he’s clean.

Copyright 2007 Ron King. This article may be reprinted if the resource box is left intact and the links live.

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Fraud Lawsuits in California

The various ways a victim can be defrauded are as limitless as the bounds of human ingenuity. But under California law, wrongful actions are generally characterized as civil fraud only under one of the following legal theories:

1. Intentional Misrepresentation. Probably the most common type of fraud is a false statement. But not every false statement is fraudulent. The elements of a claim for intentional misrepresentation are:

a. An intentionally or recklessly false statement of fact. Not every false statement is a false statement of fact. Statements of opinion generally are not actionable. Sales talk, or puffing ( This is the best location in the county! ), is generally not actionable. However, if the defendant claims to be an expert or there are other reasons to expect that the victim would rely upon the defendant’s opinion as a statement of fact, an opinion may be treated by the court as a statement of fact. Also, a statement need not be made directly to the victim. For instance, if the defendant made the false statement to a third person with the expectation that the statement would be repeated to the victim, the victim may have a valid claim for fraudulent misrepresentation.

b. Intention to defraud. If a representation of fact was intentionally false and a material part of the transaction (e.g., this house does not have flooding problems ), it is likely the false promise was made with the intention to defraud the victim.

c. Reasonable reliance upon the false statement. The victim must have actually relied upon the statement to change his or her position (e.g., the victim would not have purchased the house if he or she knew the truth). The false statement need not be the only reason the victim changed his or her position, but it must be at least part of the reason. Also, the victim’s reliance on the false statement must be reasonable. If the victim knew or should have known the statement was false, the victim did not reasonably rely. The sophistication of the victim will play a role in determining whether his or her reliance on the statement was reasonable; e.g., a sophisticated real estate investor’s reliance on a representation about the qualities of a house may not be reasonable while an unsophisticated buyer’s reliance may be. Even an unsophisticated victim, however, may not put faith in representations which are preposterous, or which are shown by facts within his observation to be so patently and obviously false that he must have closed his eyes to avoid discovery of the truth. Seeger v. Odell (1941) 18 Cal. 2d 409.

d. Resulting in damages. There must be measurable damages that were caused by the fraud. It is not enough that the victim was told a lie (e.g., A famous movie star once slept in this house ); the victim must also be able to prove some type of damage resulted from the lie.

2. Negligent Misrepresentation. A claim for negligent misrepresentation is generally the same as a claim for intentional misrepresentation, except the victim must only prove the defendant did not have a reasonable basis to believe its statement of fact was true (as opposed to proving the defendant knew its statement was false). If the defendant’s false statement was both honestly made and based upon reasonable grounds, however, there is no claim. Punitive damages are not available for negligent misrepresentations.

3. Concealment. A claim for fraud may also arise if the defendant concealed or failed to disclose a material fact during a transaction, causing damage to the victim. The elements of a claim for fraudulent concealment are:

a. The defendant failed to disclose or concealed a material fact with an intent to defraud the victim.

b. The defendant had a duty to disclose. There is not always a duty to disclose facts during a transaction. If there is a duty, it generally arises in one of four different circumstances: (i) The defendant is in a fiduciary relationship (such as being a partner) with the victim; or (ii) The defendant took steps to hide important information from the victim (as opposed to simply failing to tell the victim); or (iii) The defendant disclosed some information to the victim, but the disclosed information is misleading unless more information is given; or (iv) The defendant is aware of key information and knows the victim is unlikely to discover that information. In addition, California laws may create a duty to disclose in certain transactions. For example, sellers of residential property in California generally are required to make written disclosures about the condition of the house.

c. The victim must have been unaware of the fact and would not have acted as he or she did if he or she knew of the fact.

d. The victim sustained damages as a result of the concealment.

4. False Promise. A claim of fraud may arise if a defendant entered into a contract and made promises that it never intended to perform. The elements of a false promise claim are:

a. The defendant made a promise.

b. The promise was important to the transaction.

c. At the time he or she made the promise, the defendant did not intend to perform it.

d. The defendant intended the victim to rely upon the promise.

e. The victim reasonably relied upon the promise.

f. The defendant did not perform the promise.

g. The victim was harmed as a result of defendant not carrying out his or her promise.

h. The victim’s reliance on the defendant’s promise was a substantial factor in causing the victim’s harm.

It is important to understand that a broken promise, alone, is not a sufficient basis for a fraud claim. More than a mere broken promise is required. The victim must also prove that the defendant did not intend to perform the promise at the time the promise was made. In practice, it is usually difficult to tell the difference between a broken promise and a promise made without an intention to perform. Courts generally look for circumstantial evidence to support a false promise claim (as opposed to a broken promise claim), such as the defendant broke its promise immediately after making it.

Characterization of a claim as fraud has many advantages to a victim; primarily, the victim may be able to recover punitive damages in addition to actual damages. Also, the measure of damages is generally more liberal under fraud and other tort theories, allowing victims a more complete recovery. But even if a wrongful action does not fall under the definition of fraud, it still may lead to a valid legal claim. For instance, a broken promise - while not necessarily fraudulently - may still constitute a valid breach of contract claim. While punitive damages and emotional distress damages are generally not available for breach of contract in California, the victim still should be able to recover his or her monetary damages.

This article constitutes general information only and should not be relied upon as legal advice.

Michael Abney is a business and real estate litigation attorney in Orange County, California and a partner in Drosman Abney & Percival, LLP. An honors graduate of Harvard Law School, Michael has been a California lawyer for 19 years. You can contact Michael at www.DapLawyers.com http://www.DapLawyers.com or (949) 727-0880

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Have you ever wondered where or what the origins of babydoll lingerie are? Well, look no further! The babydoll - sometimes spelled baby doll or baby-doll - can trace its origins to the short bed jackets trimmed with lace and the wide variety of bed capes worn by women in the 1930s and 1940s. At the time, a babydoll nightgown had a hemline that came to about 6 inches above the knee. Most still do today.

The name “babydoll” is said to have come from a 1956 movie by that name (”Baby Doll”), which starred Carroll Baker as a 19 year old virgin. The style of nightgown worn in the movie soon became popular amongst the general public.

Later, the babydoll was transformed into a short day wear dress. Because the style invoked a sense of innocence and youthfulness, the babydoll was soon to be found back in the bedroom, only this time in a more provocative style. Since many babydolls are styled to have a very short hemline, revealing the buttocks, they are quite popular and help to enhance sexual foreplay.

Babydolls have evolved into a very popular form of fine sexy lingerie, playing on fantasies. With their very short hemline, the legs appear longer and some styles draw attention to the breasts by purposely exposing them. Most often a babydoll is sold as a set with a matching pair of panties or a thong. There are also styles of babydolls that are low key in nature and are marketed as a short nightgown and not as fine sexy lingerie worn for a romantic evening.

Today, due to its popularity, babydoll lingerie can be found in fine lingerie boutiques in their own separate category. Some styles resemble those of the 1960s and 1970s, while others vary considerably and are pointed more toward the fine sexy lingerie market.

One style that has gained notoriety recently is called the “fembot”. This particular style of babydoll lingerie was first seen in the movie, “Austin Powers: International Man of Mystery”, and features a marabou clad bra with a sheer pleated skirt and a marabou hemline.

Babydolls can be seen with a variety of decorations, from lace, faux fur and ruffles to bows and ribbons. Most have thin or spaghetti straps.

The history of the babydoll is a fairly short one, being a relatively recent innovation. But, it has vaulted into prominence in the fine lingerie market and should continue to be a popular form of fine sexy lingerie for years to come.

Dagmar Anderson is an associate of Lingerie Seductions, an online fine lingerie store that strives to offer their customers the best in elegant fine lingerie in an easy to navigate shopping environment. Their complete online catalog of fine sexy lingerie is available for viewing at: www.lingerieseductions.com http://www.lingerieseductions.com

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