Metal Storage Cabinets – Metal Storage Cabinets Are Great For Garage Renovations

Garage makeovers seem to be increasing in popularity these days, and metal storage cabinets are correspondingly becoming more and more popular as one of the go-to choices for materials. Choosing metal cabinetry will provide you with many different options, both in terms of design and appearance and functionality. There are metal storage cabinets for all kinds of situations, so it’s important to get a sense of what will be available to you.


The first question you have to ask yourself is what kind of cabinetry and design that you’ll be looking for. One option will be cabinets that hang from the walls and are permanently installed. These can be hung from traditional methods, or can be hung using slat walls or rails. This will really help you achieve a great look and feel, and will complete a workshop of any kind.
The style you end up with will depend on the brand you select, your comfort installing with different materials and the amount of money that you’d like to spend. Because slat walls are so convenient and can always can be changed or altered, they are a very popular option but of course you can choose anything that works for you.

There are also many other options that are not permanent. For example, you can take advantage of metal rolling storage cabinets that can be wheeled around anywhere you need. These are great for holding supplies or tools that you might need for a particular project. Of course there are also freestanding cabinet units that don’t get hung from walls but that you’ll generally leave in the same place over time.

One thing to consider is what purpose you have with your project. You might want to create a great workshop where you can work on your car or your motorcycle. In this case, having a rolling toolkit will help you complete all of your tasks as easily as possible. Alternatively, you might be looking simply for a good looking, all purpose storage solution. In this case, hanging cabinets and tall freestanding units may be more appropriate.

Of course, metal storage cabinets aren’t your only option. You’ll have to choose from many other materials, including plastic, rubbers and composites and woods. You should base your decision on several different factors. Think about the look you are trying to achieve, the functionality and durability that you’re looking for and the price that you are willing to pay. Taking all of this into consideration you’ll be able to find the perfect material for any kind of project.

When you choose metal storage cabinets for your garage renovations, you’ll be impressed with the wide range of possibilities at your disposal. best garage shelving units can get all kinds of different cabinets, from permanent installed and wall-hanging cabinets, to metal rolling storage cabinets. Remember to choose based on the capabilities that you need and the design that you’d like, and you’ll always end up with a great choice that really helps you make the most out of your garage.

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Weight Loss With Strength Training

Strength training isn’t just for muscle men. It is the best way to help your body turn into a weight loss machine. https://arbuthnotdrug.com may not initially make much sense to you as muscle is very heavy (it is heavier than fat.) But each extra pound of muscle on your body will another 50 calories per day, even when you’re doing absolutely nothing. Imagine yourself with 10 extra pounds of muscle. That muscle will burn an extra 500 calories a day which will certainly turn your body into a fat burning machine. Think about how much easier it will be to burn off extra calories when your using so many more calories a day?

I recommend this strength training strategy not just to men but also to women. Too many women think that strength training is just for men. And even when women do lift weights they usually do it in a “girlie” way. Instead of lifting heavy weights for muscle they lift a small amount of weight a lot of times for this mythological thing people call “toning.”

“Toning” does not actually exist. It’s a myth. Muscle can only get bigger or smaller. It cannot get “toned.” That doesn’t actually mean anything. The top way to grow your muscle (which is the purpose of strength training) is to lift heavy weights. Why? Because the body responds to these heavy weights by growing more muscle. Lifting light weights many times is actually an awful way to go about strength training.

Yes ladies, I’m telling you that you should train like a real man. You should lift heavy weights for a small amount of reps. In fact I recommend only doing one set of about 8 reps for each muscle area. How much weight should you lift? As much as you can lift without injuring yourself! The more weight you lift the more it will stress your body and the more likely your body will respond by growing new muscle.


That new muscle is the key to your fat burning power, particularly in the long run. Most diets fail because they do nothing to speed up your metabolism. In fact most diets actually slow down your metabolism with restricted calorie intake. But by adding new muscle to your body you are actually speeding up your metabolism in a way that will make it easier to burn off fat and to keep it off! You know how everyone says that it is so difficult to maintain fat loss? That’s because most people who lose weight starve it off but don’t do anything to really change their bodies at an intrinsic level. When you add muscle to your body you are becoming fit in a much more permanent way then you are by starving fat off your body.

What about that common fear among women that they will become “too muscular.” This is a mostly nonsensical fear. It takes a lot of weight lifting to get to the stage of being muscular in a manly way for a woman. And if you do see yourself beginning to develop more muscles than you would like (as unlikely as that is) you can always begin to slow down or stop your strength training. If you get to that point then you are likely set with your muscle needs anyway. But again, these circumstances are unlikely to develop anyway. Do not let this irrational fear stop you from doing what you need to do to improve your health.

It is recommended that you choose an online diet program that includes a free strength training program. Probably the best example of that is The Day Off Diet which is includes an excellent strength training program (free of charge) with it’s diet program (which is also very effective.)

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Why we need to customise the t-shirts?

T-shirts printings now become a popular industry in the segment of clothes. Many ask why this industry is gaining so much of boom over the last few years? It may be answered by those stores who have a lot of printed clothes than the normal clothing in the store. Even the many apparel stores also provide a good range of printed stuff in the showrooms.

The increase of the printed material over the other content in the store is because of high demand in the customers. We can see many local companies also opened because of the high demand in the customers, t-shirt printing Ottawa is also a very famous company among the local region of the western world.

Helps you to give a statement

All this printed stuff helps you to provide your desired comment to the others. Only you need to custom the shirt, and you will get what you want in the end. Self printings give some extra advantage of your choice. You can print the desired image, slogan, special message on the shirt to the give needed statement in the others and finally it helps you to express your feeling with a unique way.

The main reason to customising the t-shirts

We know that everyone in this world wants a unique personality for a more significant impact on the others. Even some think that the charm of the character comes from the clothes we wear. That is why many spend so much time to decide what to wear in public. We see many girls wasting their so much time only to choose what to wear on a special occasion. Customising the cloth may help you in this matter, and you may get the faster decision on the clothing wearing.

On the other hand, many sports and other organisation field give so much emphasis on the use of printed shirts to reveal their identity among the other. We can see a sports team with their name and number printed on the t-shirts and many organisations wanted their employees to wear special printed t-shirts and shirts in the office. These are the few main reasons for the customising the t-shirts however there some other reason is existed like wishing and giving thanks to anyone who you like the most. It always helps you to express and reveal your depth of the heart.

 

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Every Single Thing to Know about Downloading Books, Games and Movies

Nowadays getting all the entertaining stuff to become easier for the people, so as movies, episodes, games, and books, etc. these are also the common thing which people require when dealing with the downloading process of these things like the books, games, and many other things also. People need , or you can say an appropriate website from where they can easily download the stuff which they want to. So, how people know that which is the best source to download all these things?

There is no need to worry about the same concept at all because there are lots of different and simple methods present which provide the users with the same feature that is downloading feature. People can easily download the books, games, movies, songs and many other files which they want from the best and most reputed website and, i.e. telecharger-gratuitement-2019.com. With the help of it, one can easily go through all the basic or the entertaining things easily. In other words, you can say that the same website allows people in getting all types of entertaining stuff in it which is mentioned above.

Know more about the same concept

Well, now as know that there are hundreds, or you can say thousands of different websites present that contain all these things, i.e. games, books, movies, and all other stuff in it, so it is necessary for you also to know how to find the most appropriate site or how to know which is the most appropriate website for downloading all these things. Therefore, here the entire process relates to reviews. Reviews only are the best source from which people can take advantage.

It means that whenever people and individuals need to download any of these things like the games, movies, songs, serials, books, and many other files, they should take the assistance from reviews. The same thing or option helps them in many ways, and it also provides the benefits which are discussed below –

  • People are able to know each and every single thing related to the downloading process of all this stuff.
  • They should also know about the cost factor after dealing with reviews related to the same concern.
  • By the help of reviews, people should know the best site also to download all these things like books, movies, and games. Etc.

Therefore, these are some main benefits which people get from taking the help of reviews.

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How Do You Choose A Family Dentist?

It is often suggested that there one should at least two visits to the dentist twice a year but most of us know we do not even go for those as well. We still somewhere are cautious that what kind of food will harm our teeth, but in a family not all are that conscious. Kids never see or think before they eat ans it is their teeth which is most likely to get damaged. Hence it is important that a family dentist should be there so that all of the family members could push each other for the routine check ups. But finding such a family dentist is not that easy as it often sounds to many.

Tips On Finding The Right Family Dentist

Time is an important criterion when it comes to family affairs. Make sure that the dentist you choose for your family can fix you an appointment within couple of weeks.  Once you appoint him as your family dentist you need to make sure that regarding any kind of emergency he is available at best within two days maximum. Hence you need to go for that dentist who can manage his routines timely.

A family means that there must be children in it. A good compatibility with a doctor is very important especially in case of children. Hence you need to make sure that the family dentist is very comfortable with the children and suggest them simple ways of dental care that they do not hesitate to visit the dentist again.

For finding family dentist sherman oaks experts believe that acquaintance with modern dental technologies and know-how is a very important criterion for choosing a dentist. This is indeed difficult to know this. You as the head of the family need to go a check ups and research on your known if you want to choose such a professional as a family dentist.     A good way to know about the atmosphere in the clinic is through the behaviour of the receptionist. In north hollywood dental clinics often has many rush of patients but the receptionists behaviour is one that can hold all the patients in the clinic and make them feel comfortable.

Choosing family dentists is indeed not easy job. At the same time one should not change the family dentist quite often. One always develops the compatibility with family dentists which takes time especially for children and this compatibility is affected grossly when you change your family dentist. In case you need orthodontists your family dentist is the best person to give you the right advice.Need additional information? : Dr Zacharia from Sydney

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What Makes Essential to check Background through online?

Everyone wants to remain safe with their employees. They don’t want any misunderstanding because to run the business smoothly. If you are the owner or HR, then it will be your responsibility to check the background of every employee. Before hiring anyone, you can obtain personal information through an online website. The free criminal background check will protect your company effectively. That’s why; it becomes essential to consider Free Criminal Background Check to be ensured about every individual in your business.

It can be helps with the proper permission of government and police. Whenever you are going to access the website, then it must require verifying personal details. Not everyone can reveal the information because such websites are connected with the local court rooms. No doubt, it becomes easy for all of us to find any information anywhere and anytime. It will help to know about social security, terrorism, criminal offense and much more. Now, in the article, we are going to discuss about the importance to check history records.

Importance to be noted

There are some points that will allow you to use past records website and check their validation among all.

  • Protect business: With the foremost purpose to protect the business, it is important to have looked at employee behavior. You can check the past records that will make you ensured about the credibility of an individual. In case, if you are getting difficulty in finding the information, then you can take legal advice from advocate and other expert. They will guide to how to remain safe before hiring the candidate.
  • Check driving records: The Free Criminal Background Check also includes driving, murder and criminal records. Sometimes, when you hire the employee without identifying the records, then it can be a chance of police investigation. That indicates that your reputation for business goes decline.
  • Ensure right candidate: It is important to recognize every candidate with their personal details. It includes home address, phone member, family member’s qualification, college studies. Firstly, you have to fill all the details in the website so that it will access the character with past records.

Hence, these above paragraphs show the importance of having Free Criminal Background Check through online. If you want to remain safe, then you can investigate the background of employee and address their history.

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What Do You Need To Know About Payday Loans?

Payday loan is a short term loan that is useful to remain financially strong. If you are facing financial issues, then you can take Payday loan that depends on your income. The loans are only for a short time with a limited amount. It should be repaid with a single payment instead of getting an installment. You can take a loan from various financial institutions that will be processed within in minutes.

The best thing to apply Payday loan is that it requires fewer documents as it will never recommended credit score.  The Payday lender will firstly check your income and bank details so that they can ensure the recovery of the loan in time. If you are willing to know more about a Payday loan, then you should consider www louisianainstantloans.com as they will offer you reliable information and also provide Payday loans in reasonable interest rates. However, it will help to remain financially strong. Payday is also named as salary. Payroll or cash advance loans regarding unsecured loans. No, in the post, we are going to discuss the role of Payday loans that fulfill the requirement of individuals,

Things to know

Numerous are the things that everyone should know about Payday loans and how it is useful in a short period of time.

  • Repayment in short period: The lenders will provide you the loan only with a short period of time. The purpose of solving the temporary financial problem can be held with the amount of loan to fulfill requirements. You should first read the terms and condition of the service provider and check the duration of repaying the loan carefully.
  • Improve credit score: You always make sure that if you repay the loan on time, then it will improve your credit score. It will help to take the loan from any financial institution that will be registered with your bank account. There will be fewer requirements for documents. The bank will issue credit card so that you can fulfill your important requirements easily.
  • Access quickly: It will be operated easily after checking your income per year. The repayment of the loan is linked with borrower’s payday so that one can deposit the money in advance. The arrangement of credit score will be considered with employment records.

So these points are able to show the effectiveness of Payday loans. Everyone can take the loan and solve the financial conditions.

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Lucrative Aspects Of Solving Long Riddles For Adults

Riddles are not only beneficial for the children but also can offer a lot of advantages to the adults. So, if you are an adult, then it is advised to solve the riddles in the leisure time. Some people think that such puzzles are just a waste of time; however, they are unaware of the benefits of solving long riddles. In the further article, I am going to describe some advantages of solving such puzzles for adults.

Concentration

This is the first and foremost benefits of sharing the riddles. Adults are able to improve such skill by solving the different and long puzzles on a daily basis. Usually, we have to think analytically for getting the answer to the puzzle. Therefore, we are required to have the proper patience and attention. Thus, they can improve the concentration level with ease by answering the maximum puzzles.

Improves the cognitive ability

Puzzles are the ideal option for getting an improvement in the visual performance. Adults can easily enhance the cognitive ability with the help of basic patterns, colors, and shapes involved in the riddles. Such skill is helpful for the advanced reasoning, so it is necessary to have better cognitive ability.

Increment in productivity

This is another benefit of solving the riddles because it has seen that the figuring out the hard puzzles lead to the rise in the productivity level. That’s why adults should always try to start solving the puzzles so that they can get an amazing increment in productivity.

Meditation

The meditation methods and the riddles have a great connection. When we solve the puzzle, then it makes the mind active and healthy. The regular solving puzzles keep the mind healthy for a long time. The process basically relaxes the brain cells, which is helpful for the meditation. In addition to this, we can stay relaxed and reduce the stress.

Furthermore, the riddles can also improve the IQ of the adults. This is the main reason behind the high popularity of such puzzles among adults. They can improve the self confidence as well as productivity. There is no doubt that this activity has the potential to offer some beneficial outcomes to the adults. If we talk about the children, then they are able to improve the vocabulary and also get a huge help in preparation for their further tests and examinations of the school.

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What to Look While Considering Vin-Codes Websites?

Generally, vehicle information is considered with the help of VIN codes that is published in front of dashboards. The purpose to show such numbers because the vehicle can be recognized legally and one can identify easily. However, the number is according to state wise and be allotted to check the vehicle originality.

If you are looking for the best website to know full detail about your vehicle, then https://carsowners.net/ will be a better option for you all. This service provider can provide actual information in the form of registration date and year, model number and personal detail. It includes address, phone number, and their identity card to ensure their nationality. It is important especially for the police department to check out R.C and VIN codes for a safe environment and get prevention from any criminal offense.

You should check the website safely considering public reviews and effective rating. Always make sure that the information should not be leaked privately as the website should be under the control of the government. Now, we have also mentioned some of the information that will make you aware from where we all should consider vehicle information safely.

Things to know

Lots of things that everyone should be know about VIN numbers. It will be easy to check the durability of your R.C and insurance.

  • Reviews and rating: Firstly, you should check the public reviews and rating so that you could consider at foremost. People feedback can show you the effectiveness of the website and the reason to get it in use. Similarly, everyone wants to know clearly and genuinely about their vehicle with full detailed information. It will help to justify the value of it.
  • Approved by the government: It should be compulsory to be approved by the government and regulated according to their VIN records. Even, if there is wrong information, the website could block, or it should be improved because wrong things can lead to some trouble with owner personal details.
  • Updated and informative: The website will be made for the purpose of giving factual knowledge to viewers. There should be updated information with VIN numbers in accordance with 17 characters of verification.

However, you should check every alternative and gets the best solution to improve the knowledge about vehicle identification numbers. In case, if there is any issue, then you get to consult with the transport department and get your registration proper.

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What to do while finding the right job vacancy for you?

So you are the one who is searching for the right job for you so that you can get settle down in your life. If you are finding the job vacancy for you, then you should search for it but by keeping some things in your mind. Here in the post, we will talk about some things which you should keep in your mind so that you can find the right job vacancy for you which will suit according to your qualification. There are some sites also which will help you in finding the job within your locality which will now let you go out. You can search the job in your locality with the help of the https://headfinder.net/ site as it will suggest you the right thing for you.

Things to keep in mind:-

There are many things which you should keep in your when it comes to finding the right job vacancy for you. Those things which you should remember are:-

Online sites

The world has become digitalize that is why when it comes to finding the job then you should try for it on the online platform. You should search for the job vacancy on the online site because most of the companies put the job vacancies details on their official and other job searching site. It will be the best option for you because the online platform will let you meet with the right job vacancy within your locality.

Talk to friend and family

You should ask from your friends and family for the job vacancy because your friends and relatives know your taste well and they know what kind of job you can do. You should ask from them because they will suggest you the right thing for you. Asking from friends can make an individual hesitated that is why you should ask from your friends as they are your good wisher and will suggest what is good for you.

Try for the internship first

It is a very good idea to do the internship first before you get in any job. You should get the internship in any particular working so that you will become trained in the work well. After getting trained properly, you will get the right job vacancy for you in which you will get also selected because of your experience in the internship.

So use these tips and search for the right job vacancy for you.

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Reasons to invest in car rental services

If you are looking for those ways by which you can make your traveling better, then there is one way by which you can make your trip more entertaining and enjoyable. You should take a car on rent from the car rental services because it is the best way by which one can make their traveling better and comfortable. There are many reasons which will make an individual to take the car on rent. You can take the services from the solorentacar marbella‌‌ also because they are excellent in their working.

Reasons:-

Several reasons are there which will make an individual to hire the car on rent from the car rental services. Those reasons are:-

Rent for discovering

One should take the car on rent because when they take the car on rent, then it will let an individual discover and explore more with different places. You should hire the car which is automatic because by the help of that car you can discover more in driving.

Don’t look like a tourist

When an individual goes in a car, then it will let the look like that are residential people of that particular place. A tourist will always look different from other people that are why you should hire the car on rent so that you will also not look like the tourists at that place where you went for the trip.

Affordability

If you go to a big city for the trip, then you should hire the car on rent. At the big cities the taxi rents are very much, and if you do not hire the car, then it will cost you a lot whereas if you take the car on rent, then it will cost you less. You should hire the car because it will cost you at one time and you don’t have any need to pay for it again and again.

Entertaining trip

By taking the car on rent, one can make their trip more entertaining because if you travel by the help of bus and trains, then it will make your trip very much exhausted. Preventing you from the exhausted trip, one should take the car on rent.

Now hire the solorentacar marbella‌‌ and brings the best for your cost. If you are interested, then you can take help from the post and can let you understand that one should hire the car so that you will enjoy at your trip a lot.

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Marriage Proposal – Romantic Place and Destination

If you want to arrange a special wedding proposal for your partner, then you should plan the place where it can be executed.  Hotels, fountain area or national parks from where you can spend the time with holding your hand make you feel special.

Always went on all such places where you both can feel special and enjoy as per your required needs. Wedding proposal 007 will provide you with a beautiful location where you can spend some time sharing love, feelings and emotion. Just the capture the moment with photographs and video so that you should look and have lots of fun at that time. Now, you will able to get some more information in the better of a wedding proposal.

Additional information

Mostly people can’t get the solution of their doubt as they feel some complexion during the proposal. Always make sure that your wedding proposal 007 will be a better option to make you both feel happy. There are some points that will tell you some more method to apply and can easily impress your partner.

  • Propose publicly: If you are going to propose your partner then firstly you should take the permission is an indirect way and then give them a shocking surprise. The best and beautifully located place will able to impress their heart as they will definitely show you, exceptional love. No doubt, everyone wants to experience the moment with a partner and taking the faraway so that one can spend some part of life with them.
  • Handwritten note: You should give them a handmade note and write your own views in the way of expressing feeling and emotion. They will surely feel love and special intention for you. You can propose them in that a situation where there will be a chance of accepting the proposal.
  • Capture photos and videos: At the time, when you are at the beautiful location to experiencing the moment, you should always capture those moment which will feel special in your life. Undoubtedly, wedding proposal 007 are the one who can provide you better pictures and videos to experience the moment by seeing it again and again.

As a result will automatically will be I your favour if you consider all those above mentioned points. However, it could be easy to judge their gesture and have a chance of saying yes yo your proposal.

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Questions to ask before choosing the right cooler

Thinking about the cooler is not enough. There are many questions which you should ask from yourself when you will go to buy the cooler. There are many people who are confused in deciding that which cooler will be the perfect option for them. If you are also one of them, then you should go for the information given in the further paragraphs. Buying the best cooler for the money is not as easy as you think because of the multiple options. You need to put little efforts before choosing any one piece so that you will meet with reliable result further.

Questions:-

Several questions are there which you should ask before you choose the cooler for you. Some of those questions are:-

How much area you have to install?

When you go to buy the cooler for you, then you much look at the place where you have though to install the cooler. You should measure that area so that you can find that how much size do you need which can be installed at that particular place.

What kind of quality do you want?

There are different coolers which are available in the market, and it is obvious that you want the one which will lead to worth your money. Yes, there is no doubt in it that if you spend much money on the coolers, then it will help you to get extra features in it such as energy saving, water saving and other also. But it is only one time investment, but if you buy the other ones of low quality, then you have to spend much more money on it. That is why you should buy the best cooler for the money.

What is your budget?

It is the most important thing on which you should focus. There are numbers of options you can find in the market for the coolers with different prices. You should fix your budget that you can spend on the cooler and then you should go to search the options which will come within your budget. By this means you will get the best cooler for you at an affordable price.

Hope that you are satisfied with the above mentioned information and will ask these questions from yourself when you will go to buy the best cooler for the money. Remember to look at your requirements always from the cooler.

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How to chose main Weight Loss diet

Do YOU look for an efficient Weight Loss Product ?

If you just type Weight Loss on Google, you will find a lot of things. Few good, a lot of scam.

So how can YOU find a good option ?

We could give you HUNDREDS of small worthy pieces of advice, write a complete methodology integrating the most effective insights we could get during those years in the diet and weight loss coaching. Yet that would take literally months, and become a really complex method.

I AM ASHAMED

I have a secret to confess that I AM ASHAMED OF : despite all the high price we put on our coaching services, every one can reach results without, because following the Golden Keys to Weight Loss with a good diet will bring effective weight loss with Phen24.

“Slim ! Help me find the right diet !” I shouted.

He smiled, raised his eyebrow. “For ?” he asked.

“For people reading Enjoy Weight Loss Secrets who just want some easy to get and to use, enjoyable, safe and efficient diet basis”.

“Are you crazy ?”

I am. Slim is crazy too, turned out.

So we did IT.

WE CRAZY ONES DID IT

We ordered 2 dozens of products. How did we chose ? The best way we could :

We chose those that were getting real efficiency feedback (not only on their sales page), that past clients used to order and found working or that got some positive medical, and only if they were matching our ethical and technical key points. We also asked our beloved boss to use his contacts in the affiliate world to confirm which products were giving few refunding requests from clients.

Oh My, THAT WAS FUN.

And it went worse as we read those books, listened to those CDs…

Some were just.. let’s be the kind and positive guys… not fit.

We Gave Those Producs to have them real-world tested

Others were really good, and some were outstanding. From those, we gave those products each to five volunteer patients during the past year and a half that we were not coaching for weight loss, but were given access to the advice of this site.

Then we took feedback, and saw results.

Strange indeed, the best products were not the ones we thought. Some have strange sales pages, or use a basis that in itself might not be sufficient (yet in fact other insights in the producs compensate for these shortcuts).

Yet all were compliant to our 7 Golden Keys, and turned out to be sufficient to make our patients successfully lose weight 5 times out of 5 (from 10 pounds to an unexpected 85 pounds, most within the 20-40 pounds range).

Well, ok I guess you just want to get the product will work best for you now ?

Just wait for a few more seconds before rushing to the order page please,  I’m going to detail each of those 3 that proved the most efficient, and that we feel like recommending to YOU.

(Note that 5 other products gave good results but seem less 7 Golden Keys compliant or more random by themselves in the long run and should need a few more indications to ensure they will bring you results ; we disqualified one product for having not responded to a refund request from one of our past clients).

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The Real Truth Behind Losing That Belly Fat, In Next To No Time At All!

Lose Belly Fat Naturally

What is the fastest & healthy way to lose belly fat naturally? Here is a question that has been asked so many times before. I have come across a lot of people going to extreme measures just to lose belly fat. Many of the things they have done have eventually harmed their bodies more than it has done good.Here are a couple of tips for the healthiest and fastest ways to lose belly fat with https://www.sportzfuel.com/.

* Never Ever Skip Breakfast

Many times we usually skip breakfast because we’re late or we think that it will help us with our weight loss goals. Breakfast is said to be the most important meal in the day. When we skip breakfast after many hours of sleep, our bodies go into a starvation mode. When this happens, our metabolism rate slows down because it tries to conserve energy and burn less fat. It is advised that you have a heavy breakfast.

Eat More Meals More Often

Yes, you heard me right! A good tip for losing belly fat in fastest way is to eat more often. When you eat more often though, your portion sizes will have to decrease. It is recommended that you have around 5 to 6 small meals a day to prevent you from binging on snacks and junk food and also to stop you from overeating at meal times.

Look Out For What You Are Eating

All weight loss goals begin and end in the kitchen. What you eat accounts for between 85 to 90 percent of losing weight. The most proven way to lose belly fat is by maintaining a very strict diet regimen. Your meals need to have a good balance of protein and carbohydrates. Switch from regular bread to whole wheat bread, try brown rice instead of white, eat more fruits and vegetables and also try out skimmed milk instead of the regular milk. With a few changes in your meal plan, you can go a long way towards losing belly fat.

Exercise Regularly

Cardio workouts are one of the best forms of exercises for people looking to lose belly fat. Cardio workouts include cycling, boxing, jogging/running and even rowing. These are workouts that really make you sweat and get your heart pumping. With cardio workouts, you might want to do some lifting of weights and abs exercises too. Lifting weights helps with increasing muscle density. With all these, you will not only lose belly fat but also tone your abs at the same time. Who does not want a set of perfectly tight abs?

Stay Hydrated

Stay hydrated b y drinking a lot of water. Water helps to keep your liver functioning right which helps in the fat burning process. If you are a beer drinker, try cutting down your alcohol consumption or even switching to Light Beers instead of regular ones. Also, try hot green tea for a change. It is said that green tea helps in the neutralization of fatty foods.

Quickest Ways to Lose Belly Fat for Men & Women

There are not many articles that will teach you to lose belly fat in 1 week because losing belly fat in 1 week is too extreme and can cause unhealthy side effects. Even though I can’t tell you how much fat you can lose in one week but here I will share with several simple steps that you can do to burn belly fat in shortest time possible.

  1. Cut junk foods and high calorie foods
  2. Drink more water each day
  3. Exercise for 45 minutes each day
  4. Do yoga or Pilates to strengthen your entire body

1 Cut Junk Foods & High Calorie Foods

Toss away any food that high is high in sugar, fat, cholesterol and calories, the examples are chip, cookies and candy. These foods provide no nutrition to your meals only full of calories. This means no matter how hard you do your exercise you won’t lose any weight at all.

2 Drink More Water Each Day

You should drink 8 to 10 glasses of water each day. This is useful to help your body flush out toxins and excess water. This way you will reduce belly bloat and as a result appear slimmer.

3 Do Exercise for 45 Minutes a Day

This exercise will keep your heart rate up. When you do proper workout consistently you will burn calories and lose belly fat fast. Some examples of exercises that you should do are jogging, biking, and swimming.

4Do Yoga or Pilates to Strengthen Your Entire Body

Yoga or Pilates is useful to strengthen your entire body. You should perform any type of exercise that build muscle mass and keep your metabolism high. The more muscles that you build the more calories and fat that you burn.

Remember the key to lose fat and maintain your weight is to incorporate all steps above into your lifestyle. When you do the steps above regularly you will lose weight and maintain your body shape.These are just a few tips for the fastest way to lose belly fat. You need to be consistent with your exercise and workouts and also faithful to your diet regimens to reap the benefits of belly fat loss.

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An ultimate guide to online marketing services

Nowadays, online marketing services are on hype. These services are providing enormous benefits to the users. It is known as digital marketing that is quite cheaper and cost effective as well.  If you want to promote your business, then one needs to make the use of online services. It is really beneficial because one can enhance the awareness of the brand.

It would be quite difficult to find a person who isn’t making the use of the official online website.  They are sharing their products on the official websites. The best thing is that they are attracting millions of users at ones. Therefore, if you want to become a successful businessman, then one needs to invest money in the SEO services.  Following are the most popular online marketing services.

  • SEO services

It is First and foremost service that is providing enormous benefits to website owners. If you want to improve the ranking of your website in search engine, then you should lookout an SEO professional company. Make sure that the company is providing you enough experienced and skilled person that will improve the ranking of your website within a few days. Apart from that, it is almost similar to promotions. After choosing the SEO services, you don’t have to spend money on promotion and other things. A professional will automatically promote your website on the social networking site.

  • Website Design

It is another most popular service. If you want to create a new website, then you have to hire an expert website designer. Make sure that you are choosing an expert that will create the fantastic design of the website. Before choosing a designer, you should check the portfolio of him. If he can create a website for the Mobile, Tablet, and Desktop, then it would be a reliable option for you. Howeverhttps://designful.ca is one of the most popular websites that is providing online marketing services at reasonable worth.

  • Graphic design

Last but not least, flyers and brochures are quite important for the business. It is an integral part of the promotion. With the help of a graphic designer, one will able to grab high-end designs of Flyers and brochures.  It will save time and cost.

Conclusive details

In a nutshell, with the help of online marketing services, you will able to create a strong presence of the business. You should always hire a professional company for online marketing services.

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The Real Causes of Deadly Medical Errors Doctor Shortages NOT MedMal Lawsuits



Two Wall Street Journal articles today highlight the real reason for medical errors, which kill up to 100,000 hospital patients annually, and for the shortages in doctors across the country. And in neither case do lawsuits for medical malpractice, or premium levels for medical malpractice insurance, play any role.

The U.S. government reports that medical errors are among the leading cause of death in America today, and are the real source of so many medical malpractice lawsuits. The Wall Street Journal article points out that the occurrence is entirely the fault of the practitioners:

According to a two-pronged survey of operating-room and critical-care nurses conducted by their professional associations and VitalSmarts, a global training and consulting firm, 85% of 2,383 nurses surveyed said they’d been in a situation where measures put in place to reduce errors – including checklists or hand-off protocols — warned them of a problem that would have otherwise harmed a patient. That’s the good news. The bad is that 58% of the nurses said they’d been in situations where it was either unsafe to speak up or they were unable to get others to listen.

The report focuses on what causes this type of communication breakdown, including three concerns that are rarely discussed by health-care teams: dangerous shortcuts, incompetence and disrespect. Among respondents to a separate survey of 4,235 nurses, 84% reported working with people who take potentially dangerous shortcuts, such as not washing hands for long enough, with 34% saying shortcuts had led to near misses and 26% saying they caused harm to patients. Some 19% say incompetence or lack of required skills have harmed patients and 20% say that disrespect is making them seriously consider leaving their profession.

Hmmm, nothing about medical malpractice premiums or lawsuits in there. Want to end medmal lawsuits? Try ending deadly medical errors first, instead of letting “dangerous shortcuts, incompetence, and disrespect” go unpunished.

Then there’s the nationwide shortage of doctors, which pro-tort reformers like to link to medmal suits and medmal insurance premiums. But many states already have limits on medmal lawsuits. As I posted last week, there’s been a doctor shortage in Texas even after the state enacted a very tough limit on medmal suits.

So what does the WSJ article today say is the cause of a worsening doctor shortage? OBAMACARE!! What a big surprise!! Promise everyone free health insurance and, POOF, we don’t have enough doctors to treat all these new patients. From that article:

The new federal health-care law has raised the stakes for hospitals and schools already scrambling to train more doctors. Experts warn there won’t be enough doctors to treat the millions of people newly insured under the law. At current graduation and training rates, the nation could face a shortage of as many as 150,000 doctors in the next 15 years, according to the Association of American Medical Colleges. That shortfall is predicted despite a push by teaching hospitals and medical schools to boost the number of U.S. doctors, which now totals about 954,000.

The greatest demand will be for primary-care physicians. These general practitioners, internists, family physicians and pediatricians will have a larger role under the new law, coordinating care for each patient. The U.S. has 352,908 primary-care doctors now, and the college association estimates that 45,000 more will be needed by 2020. But the number of medical-school students entering family medicine fell more than a quarter between 2002 and 2007.

So if you want to cure the doctor shortage, let’s repeal ObamaCare! Longtime readers of this site know that I consider ObamaCare to be every bit as violative of the Commerce Clause as current medmal “reform proposals.” But now the article gives us another reason to oppose it, as if we needed another reason.

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Trial Lawyers Group President Urges New Congress to Support 7th Amendment



In November I wrote on the remarks by Gibson Vance, President of the American Association for Justice, the largest trial lawyers’ association in the world, at the National Convention of the Federalist Society on November 20. Mr. Vance discussed the history of the right to civil jury trials, as protected in the 7th Amendment of the Constitution, and the current dangers to our rights through mechanisms such as federal preemption of state jury decisions.

Today, Mr. Vance reiterated many of those points in an article posted on the Huffington Post, titled “Constitutional Conservatives and the 7th Amendment.” He urged newly elected Congressmen from the ranks of Constitutional conservatives and Tea Party members to protect our 7th Amendment rights in future votes. You can read the entire article there, and here are some excerpts:

The constitutional conservatives’ stated commitment to our country’s founding principles is at this point widely known. But what is not widely known is where this group will come down regardingtort reform” – or limiting people’s 7th Amendment right to trial by jury.

The right to a trial by jury for civil suits dates back almost 800 years, to the signing of the Magna Carta. Article 39 of the Magna Carta specifically guaranteed the right to a jury trial for civil suits and criminal cases.

Our Founding Fathers also agreed with the importance of a trial by jury. In the words of James Madison, “In suits at common law, trial by jury in civil cases is as essential to secure the liberty of the people as any one of the pre-existent rights of nature.”

Votes on tort reform will be one of the first true tests of newly-elected Constitutional Conservatives. In fact, the House will vote on Wednesday to repeal the health care reform law and take steps toward creating an alternative plan that would include limiting the legal rights of patients. These members should consider how this idea conflicts with the limited government they promote.

The concept of tort reform is an assault on states’ rights and individual freedom. Though politics may try to disguise our commonalities, constitutional conservatives claim adherence to very similar principles as do trial attorneys: preserving and promoting individual liberty, responsibility and the rule of law.

Our founding fathers had no intention of making the 2nd Amendment more or less important than the 7th, or any other part of the Bill of Rights. We cannot pick and choose which parts of the Constitution to follow or to ignore.

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Supreme Court Again Expands Use of Forced Arbitration Clauses



Unfortunately, the Supreme Court has taken another opportunity to expand the use of forced arbitration clauses in consumer contracts, denying us the right to negotiate such clauses out and take our claims to a jury. On the heels of the landmark ATT Mobility v. Concepcion decision, the Court held in CompuCredit v. Greenwood, that companies that promise to repair an individual’s credit can force customers into arbitration, instead of to a judge or jury trial, under the Federal Arbitration Act (FAA), even though the 1996 the Credit Repair Organizations Act gives consumers “the right to sue,” because the latter act doesn’t explicitly overrule the FAA. The impact of this decision extends the scope of the FAA and represents another in a string of decisions approving of forced arbitration clauses in consumer contracts.

A 1965 Supreme Court decision included a powerful summary of the detriments of arbitration: “Arbitration differs from judicial proceedings in many ways: arbitration carries no right to a jury trial as guaranteed by the Seventh Amendment; arbitrators need not be instructed in the law; they are not bound by rules of evidence; they need not give reasons for their awards; witnesses need not be sworn; the record of proceedings need not be complete; and judicial review, it has been held, is extremely limited.”

Forced arbitration clauses are never negotiable by the consumer, and the proceedings are heavily biased towards the business. The FAA might now be the most powerful anti-jury trial federal law on the books, with consumers trapped.

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Rick Perry Panics And Trashes Founders States Rights Jury Trials



Governor Rick Perry took the gloves off in the CNN-Tea Party Express debate, declaring war on the 7th and 10th Amendments by calling for “federal tort reform,” as follows:

“…one of the things that’s really important, one of the things that the Fed Reserve chairman said was the most powerful, one of the most powerful thing that happened, was tort reform that we passed in that state. You want to talk about some powerful job creation, tell the trial lawyers to get out of your state and to quit costing businessmen and women. That’s what needs to happen in the states. and it’s also what needs to happen at the federal level, passing federal tort reform at those federal levels.”

So never mind that SEVEN conservative experts on constitutional law, including the leading anti-ObamaCare professor in America and two noted ANTI-civil litigation experts, have written that federal tort reform is an unconstitutional abridgement of states’ rights. Never mind that the long list of REPUBLICANS who agree with that assessment include former Texas judge and current Congressman Ted Poe; Rep. Ron Paul; Sen. Tom Coburn; Tea Party favorite Rep. Morgan Griffith of Virginia; and veteran Rep. John Duncan of Tennessee. Never mind that the co-founder of the Tea Party Patriots, Mark Meckler of Texas, also says that tort law is a province of the states. Forget about the long letter by the bi-partisan National Conference of State Legislators, co-signed by a Texas state representive, that warned Congress against enacting federal tort reform because it violates states’ rights.

Has Rick Perry or his vaunted team ever read what the Founding Fathers actually wrote about the right to a jury trial for civil suits? What about James Madison’s famous admonition that the 7th Amendment right is “as essential in securing the liberty of the people as any of the pre-eminent rights of nature,” and Thomas Jefferson’s clear principle that trial by jury in all cases is “the only anchor ever yet imagined by man, by which a government can be held to the principles of its constitution.” Doesn’t he realize that
the protection of any of our inalienable rights depends, in large measure, on the right to unfettered access to state and local courts?

Conservatives like Rick Perry who think that “tort reform” can be limited to just medical malpractice cases are dreaming. When any of our rights are compromised, ALL of our rights are limited, including the rights to freely exercise our religion, bear arms, express our opinions without fear of being muzzled, and enjoy the benefits of our private property and labor freely offered.

No, Perry didn’t care about constitutional principles at all. He felt the heat of all the criticism he was taking from the other candidates and grasped for the big applause line – “kill all the lawyers.” He shot his mouth off in the heat of battle. Sound like a real President to you? What will he say when he’s up against a real tough guy, like Ahmadinijad? If he’s ignorant on some of the basic writings of our Founding Fathers, distrustful of local juries, and willing to throw the Constitution overboard for an applause line, how are we supposed to trust him with our lives and fortunes?

Ideas have consequences. I’ll discuss the real-world consequences of Rick Perry’s federal tort reform for victims in my next post. For starters, the consequences are that Rick Perry breaks his promises; that he’s a phony “states’ righter;” he’s flip-flopped on the use of federal power and the Constitution as they apply to abortion, marriage, and the civil jury process; he’s not a real “Tea Party” leader or representative; and he’s a classic “crony capitalist.” What else is there?

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Quote of the Day Sen Tom Coburn Opposes HR 5 Federal Tort Reform Laws



What I worry about as a fiscal conservative and also as a constitutionalist, is that the first time we put our nose under the tent to start telling Oklahoma or Ohio or Michigan what their tort law will be, where will it stop? In other words, if we can expand the commerce clause enough to mandate that you have to buy health insurance, then I’m sure nobody would object to saying we can extend it enough to say what your tort law is going to be. Then we are going to have the federal government telling us what our tort laws are going to be in healthcare, and what about our tort laws in everything else? Where does it stop?

One of the things our founders believed was that our 13 separate states could actually have some unique identity under this constitution and maybe do things differently, and I think we ought to allow that process to continue as long as we are protecting human and civil rights.

So says Sen. Tom Coburn, Republican from Oklahoma and a veteran doctor, in a new interview with Medscape, a pro-tort reform website. Thank God there are more clear-eyed Constitutional conservatives now in Congress like Sen. Coburn, who recognizes what the Founding Fathers were actually doing when they enacted the Commerce Clause and the Bill of Rights. The Commerce Clause in no way justifies the imposition of federal tort reform laws such as H.R. 5, the medical malpractice tort reform bill to federally limit civil suits against health care providers, drug and device companies, and insurance companies. He reiterates the point that I made here on May 6, that if health insurance isn’t “commerce,” then neither is health litigation. Sen. Coburn also recognizes that the so-called “state flexibility” section in H.R. 5 is a joke and doesn’t protect states’ rights at all, in contradiction to the 10th Amendment.

Sen. Coburn joins the following SEVEN Constitutional scholars in opposing H.R. 5 and the wholesale destruction of states’ rights through sweeping federal tort reform laws:

Prof. John Baker, LSU Law School
Prof. Randy Barnett, Georgetown Law Center
Rob Natelson, Independence Institute
Walter Olson, Cato Institute
Ted Frank
Prof. Ilya Somin, George Mason Law School
Prof. Jonathan Adler, Case Western Reserve Law School

Sen. Coburn is joined by Tea Party Patriots co-founder Mark Meckler and real conservatives in Congress such as Reps. Ron Paul, John Duncan, Morgan Griffith, Lee Terry, and many others.

Sen. Coburn’s vote for Constitutional limits on Congressional power is a breath of fresh air, and we should support him with calls and e-mails to our Congressmen and Senators.

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The Constitutions Police Power Including Tort Law Isnt Subject to Federal Authority



The Supreme Court’s decision in the Obamacare case (Acrobat document) highlighted the limits of federal authority over states’ and individual rights. Over and over again, Chief Justice Roberts wrote of the Constitution’s enumerated powers for the federal government and of the need to protect states from an overreaching federal government. He defined states’ rights in terms of the inherent “police power” which is reserved for the states. Here is a key quote:

The Constitution may restrict state governments–as it does, for example, by forbidding them to deny any person the equal protection of the laws. But where such prohibitions do not apply, state governments do not need constitutional authorization to act. The States thus can and do perform many of the vital functions of modern government–punishing street crime, running public schools, and zoning property for development, to name but a few–even though the Constitution’s text does not authorize any government to do so. Our cases refer to this general power of governing, possessed by the States but not by the Federal Government, as the ‘police power.’ See, e.g., United States v. Morrison, 529 U. S. 598, 618-619 (2000).

And Justice Roberts was unwilling to enable the federal government to mandate the purchase of health insurance under the Commerce Clause, in contradiction to the “police power” of the states.

“The Commerce Clause is not a general license to regulate an individual from cradle to grave, simply because he will predictably engage in particular transactions. Any police power to regulate individuals as such, as opposed to their activities, remains vested in the States… The Government argues that the individual mandate can be sustained as a sort of exception to this rule, because health insurance is a unique product… The proximity and degree of connection between the mandate and the subsequent commercial activity is too lacking to justify an exception of the sort urged by the Government. The individual mandate forces individuals into commerce precisely because they elected to refrain from commercial activity. Such a law cannot be sustained under a clause authorizing Congress to ‘regulate Commerce.'”

Justice Roberts cited the U.S. v Morrison case, in which then-Chief Justice Rehnquist wrote several times that the Constitution reserved the “police power” to the states, and quoted from the Supreme Court’s ruling in the U.S. v Lopez case: “[W]e always have rejected readings of the Commerce Clause and the scope of federal power that would permit Congress to exercise a police power.”

Paul Clement, who argued the case against Obamacare before the Court, also asserted that “the police power resides with the states” in a debate at the 2011 Federalist Society national convention. In the brief filed for the State of Florida before the Court, he asserted that the Constitution “reserves the plenary police power to the states” (page 17 of the brief).

So what is included under the umbrella of the constitutional “police power?” Well, one of the Republicans’ favorite legal experts and anti-Obamacare theorists says that tort law is a “police power” not subject to federal authority:

Prof. Randy Barnett, in May 2011: “But tort law — the body of rules by which persons seek damages for injuries to their person and property — has always been regulated by states, not the federal government. Tort law is at the heart of what is called the ‘police power’ of states… Indeed, if Congress now can regulate tort law, which has always been at the core of state powers, then Congress, and not the states, has a general police power.”

And other top Republican, anti-Obamacare constitutional experts clearly agree with Prof. Barnett’s conclusion that Congress has no business regulating tort law through, for instance, federal limits on awards in medical malpractice lawsuits.

Virginia Attorney General Ken Cuccinelli, in November 2011, writing about a Senate bill to cap awards in medical malpractice cases: “The legislation is breathtakingly broad in its assumptions about federal power, particularly the same power to regulate commerce that lies at the heart of all the lawsuits (including Virginia’s) against the individual mandate of the 2010 federal health-care law… This legislation expands federal power, tramples the states and violates the Constitution.”

Sen. Mike Lee on Fox Business Network in March: “It’s the states that license and regulate health care, health insurance companies. It’s the states that come up with the system of tort laws that govern medical malpractice lawsuits.”

Prof. John Baker, in June 2011: “To justify their efforts to nationalize medical malpractice law, House Republicans are stretching the Supreme Court’s New Deal Commerce Clause jurisprudence almost as far as Democrats did for Obamacare.”

Carrie Severino of the Judicial Action Network, in October 2011: “The law’s own justification for its constitutional authority should be chilling to anyone committed to limited federal power… Congress would be nationalizing purely local activity because state-by-state solutions would require a lot of resources and hard work.”

Rob Natelson, writing about the Founders’ intentions in the Constitution in his monograph titled, ‘The Roots of Judicial Federalism’: “Reserved to the states would be nearly all the authority they had exercised previously, including power over state court procedures and over existing areas of substantive jurisdiction. With a few exceptions, therefore, the states were left in exclusive possession of the law of torts, contracts, inheritance, property, and criminal law.”

So there’s no argument among top Republican experts – tort law just isn’t a federal issue, and the Obamacare decision only made that point perfectly clear.

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Trial Lawyer For Religious Freedom Speaks At Rally



Robert Muise, Esq., is the co-founder of the American Freedom Law Center, a nonprofit litigation firm fighting for religious freedom in courtrooms nationwide. AFLC is one of the conservative religious liberty litigation firms that I refer to as the “Trial Lawyers For Religious Freedom,” a group that includes the Alliance Defense Fund, the Becket Fund, and and the Thomas More Law Center, which Muise also founded.

Earlier this year, AFLC filed a lawsuit against the Obamacare contraception mandates on behalf on the Catholic group “Priests For Life.” On Friday, Mr. Muise spoke at one of the scores of “Stand Up For Religious Freedom” rallies held nationwide, to discuss the lawsuits.

Mr. Muise, a Catholic, co-founded AFLC with David Yerushami, an Orthodox Jew, and highlighted the nonsectarian nature of religious freedom in his remarks. “This is not just a Catholic issue, it’s an American issue.” You can watch Muise’s remarks here:

Republicans who condemn trial lawyers should remember that champions of religious freedom such as Muise are filing their suits under the same Constitution and Bill of Rights as trial lawyers filing medical malpractice and product liability claims.

Do anti-trial lawyer Republicans want to “tort reform” the religious freedom lawsuits filed by AFLC, ADF, and the Catholic groups and limit their rights in court?

Do anti-trial lawyer Republicans want to give orders to state courts on the procedures for hearing such suits, just as they do in H.R. 5, the bill to federally limit medmal awards?

Do anti-trial lawyer Republicans want to impose federal wage controls on trial lawyers for religious freedom, like they propose in H.R. 5 for attorneys filing medmal lawsuits?

When will the Republicans who slam trial lawyers realize that the Founding Fathers created ONE process for the disposition of civil suits for ALL claims – religious freedom, gun rights, property rights, AND medmal AND product liability claims? And protected the right to a jury trial for ALL civil suits in the 7th Amendment – a right now demanded by Catholic Bishops and charities around the country?

Because sooner or later, if the “tort reform” movement gets its way in Congress to protect health care professionals from negligence, some group might try to “tort reform” away our religious freedom.

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Quote of the Day Archives



But federalism is as much a question of deeds as words. It often takes the form of a concrete decision by this Court that respects the legitimacy of a State’s action in an individual case. Here, recognition of that federalist ideal, embodied in specific language in this particular statute, should lead us to uphold California’s law, not to strike it down. We do not honor federalist principles in their breach.

So wrote that noted champion of the 7th and 10th Amendments, Supreme Court Justice Stephen Breyer, on the last page of a dissent from a majority decision today that pre-empts and overrules California consumer protection law in favor of the Federal Arbitration Act (“FAA”). Yes, I’m joking – I don’t see Justice Breyer’s name on many lips of Constitutional conservatives or Tea Party websites. And in fact, Justice Breyer has sided with pro-pre-emption Justices in other cases, notably over medical device regulation, a subject I addressed last year. But in the decision announced today in AT&T Mobility LLC v Concepcion, Justice Breyer and the three other Democrat-nominated Justices supported states’ rights and dissented from the majority’s pre-emption hammer. In so doing, they supported states which want to allow their citizens to exercise their 7th Amendment right to a civil jury trial when trapped by forced arbitration clauses in a consumer contract (in this case, a cell phone contract).

In contrast, each of the Republican-nominated Justices, led by Justice Scalia (who apparently has never met a pro-pre-emption argument he didn’t like), struck down California state law and court decisions enabling class action lawsuits against forced arbitration clauses in consumer contracts. So even when a state acts to protect its citizens from such abusive contracts, the FAA trumps the state law. When faced with language in Section 2 of the FAA that should protect states’ ability to revoke any contract (“save upon such grounds as exist at law or in equity for the revocation of any contract”), the majority flattens it:

Although §2’s saving clause preserves generally applicable contract defenses, nothing in it suggests an intent to preserve state-law rules that stand as an obstacle to the accomplishment of the FAA’s objectives

So Constitutional principles like states’ rights and civil jury trials are “obstacles” to be removed or ignored.

Justice Thomas was the swing vote in this case, but still voted to abandon states’ rights. He hesitated before joining the assault by writing a concurring opinion in which he asserts that he adheres to views on pre-emption expressed in a previous opinion, Wyeth v. Levine on the regulation of drugs, but then he “reluctantly” joins the Court’s opinion.

The practical impacts of the decision could be enormous. As the dissent notes, it will force an end to many class actions, as few consumers and fewer attorneys will bring an individual case for small amounts of damages. Forced arbitration clauses are now buried in consumer contracts for everything from computers, credit cards and cell phones, to employee handbooks and nursing home admissions contracts. The decision also threatens the rights of employees as well. Employers are increasingly inserting arbitration clauses, with bans on class action suits, into employment contracts. It will be far more difficult for employees to fight discrimination, because they will be unable to file class action suits.

If the 7th and 10th Amendments are to be reinvigorated, Congress will have to take specific and strong action to enable Americans to opt out of forced arbitration clauses in consumer and employment contracts.

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Randy Barnett Vows to Lead Fight Against Federal Medmal Limits



Prof. Randy Barnett was one of the leading theorists among Tea Party activists and Republicans in the court battles against Obamacare. He was co-counsel for the complaint filed by the NFIB, which was eventually the basis for the Supreme Court ruling that Obamacare is an excessive use of federal power and an invalid exercise of the Commerce Clause and the Necessary and Proper Clause.

Prof. Barnett has also been a staunch opponent of federal tort reform bills, and for the same reason as his opposition to Obamacare. Last year, he wrote in May, and again in November, that tort law belongs to the states, and thus is beyond the reach of federal authority. “Indeed, if Congress now can regulate tort law, which has always been at the core of state powers, then Congress, and not the states, has a general police power.” He’s been joined in that view by other libertarian and conservative legal scholars, such as John Baker, Carrie Severino, Ilya Somin, and Rob Natelson, and by elected Republicans such as Virginia Attorney General Ken Cuccinelli, Senators Tom Coburn and Mike Lee, and numerous House Republicans who honor federalism.

While GOP leadership has quoted and promoted Prof. Barnett’s views on Obamacare, they’ve completely ignored him on the subject of federal tort reform, and in the process overridden opposition by constitutional conservatives in both houses. House leaders attached H.R. 5, a bill mandating federal limits on damages in medical malpractice lawsuits, to two bills to ensure House approval, and Senate GOP leaders attached their version of H.R. 5 to a Republican “jobs bill.”

Now Prof. Barnett has taken his opposition further, vowing to lead court challenges to any enacted federal medmal law. He is convinced that the Supreme Court’s Obamacare ruling makes a constitutional challenge to such a law much more likely to succeed. He participated in a teleforum on the post-Obamacare environment run by the Federalist Society for members on July 17, and the Society finally posted the podcast last week. As a member of the Federalist Society, I was entitled to participate, so I asked Prof. Barnett about the impact of the decision on federal tort reform bills, and specifically on the federal medmal limits pushed by GOP leaders.

Prof. Barnett responded by saying that the jurisdictional basis for federal tort reform can now be “easily challenged,” He added, “I will help lead that challenge if ever enacted, and I think we would actually have an easier time defeating that than defeating the (Obamacare) mandate… In fact, this court would strike that down (referring to federal medmal limits)… I’ll be involved in the lawsuit.

You can download and listen to the entire podcast from the Federalist Society’s website (MP3 file). My question and his response start just after the 51:10 mark.

Prof. Barnett isn’t the first Tea-Party-side constitutional scholar to write that the SCOTUS Obamacare decision makes a federal law limiting medmal damages more likely to be found unconstitutional. On July 27, Rob Natelson of the Independence Institute and the Tenth Amendment Center posted, “Obamacare Decision Suggests U.S. Malpractice Bill Unconstitutional,” in which he wrote, “Chief Justice Roberts’ health care opinion strongly suggests that the Necessary and Proper Clause is simply not broad enough to include the kind of control over state courts that H.R. 5 would impose… It seems clear that the Supreme Court will not tolerate efforts by Congress to dictate rules and procedures to state courts. In light of this new information, the sponsors of H.R. 5 should honor their oath to support the Constitution by promptly withdrawing the bill.”

So it’s likely the same group of legal libertarian and conservative scholars who opposed Obamacare will also oppose federal limits on medmal damages and other federal tort reform bills. Republican leaders who insist on capping victims’ rights in federal law now face the embarrassing spectacle of seeing their brightest legal stars publicly opposing them in public and in the courts.

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