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Employees who sue for age discrimination under the Age Discrimination in Employment Act (ADEA) must prove that, if not for illegal age discrimination, their employer wouldn?t have taken an adverse employment action.
That is, a terminated employee must show that but for the former employer?s desire to discriminate against older workers, he wouldn?t have been fired. If there were other, valid reasons, the employee won?t win.
That?s why when age may be an issue, em??ployers are better off having several good reasons for terminating the employee. That makes it much harder for the employee to pin down age as the real and only reason for termination. He may be able to knock out one reason, but another may save the day.
Recent case: David was age 41 when he was fired from his job as a hospital pharmacy technician. He helped pharmacists in the control, distribution, preparation and charging of drugs.
Other duties included stocking crash carts with appropriate drugs such as anesthetics so they were always ready to be used in medical emergencies.
David found himself under the microscope when a new supervisor discovered that one of the crash carts lacked two essential drugs. She issued David an oral warning. She also said David was ?slow to complete his daily tasks as compared to other technicians and new hires.?
A few months later, David got his first written warning, this time for allegedly not stocking a dispenser with antibiotics needed for the crash carts. Ten days later, David got a second written warning, this time for allegedly losing several medications that were essential for emergency anesthesia.
Management then concluded that it was time to terminate David for his apparently careless approach to tracking and stocking drugs.
David sued, alleging he had really been fired because he was 41 years old. He pointed out that all other new hires were considerably younger and that the comment on his slow work was really proof he was being punished for being older.
In court, David claimed he might not have been responsible for the second cart incident because he hadn?t worked that particular day. Hospital representatives agreed that might have been the case. But they also argued that it wouldn?t matter. It still had two good reasons to fire David that had nothing to do with his age.
The court agreed with the hospital. It said that because David only chipped away at the underlying reasons for the first written warning, he hadn?t proved age discrimination.
Because age is the ?but for? factor, and because it was clear there were two other good reasons for termination, it follows that David could not prove age discrimination. The case was dismissed. (Grimsley v. Richardson Hospital Authority, No. 3:09-CV-2011, ND TX, 2012)
Final note: David also thought his supervisor?s comment that he worked slower than new hires was direct evidence of age discrimination just because those new hires were younger. The court rejected that argument, too.
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Transgenic AquAdvantage salmon grow twice as fast as wild Atlantic salmon. Image: Barrett & McKay Photography / AquaBounty
The first genetically engineered (GE) animal for human consumption?a fast-growing salmon?has come a step closer to the dinner table, with a piece of paperwork posted online on December 22 by the US Food and Drug Administration (FDA).
The FDA?s draft environmental assessment concludes that the fish poses no foreseeable risk to nature. After 60 days of public comment, the FDA may issue a final assessment and approval?at which time AquaBounty, of Maynard, Mass., can begin selling the fish.
However, the draft assessment was dated 4 May, suggesting that the FDA had kept its conclusions under wraps for several months. Advocates on both sides of the issue speculate that political interference may be responsible. ?I think it was controversial, and it was an election year,? says Patty Lovera, assistant director of Food and Water Watch, a Washington, D.C., group opposed to GE food animals. An FDA spokeswoman, Morgan Liscinsky, declined to comment on accusations that the process had been politicized, and says it?s possible that the agency could request further studies after the public comment period.
Delays would not shock AquaBounty's CEO, Ron Stotish, whose company has been seeking FDA approval for the fish since 1995. When he was alerted to the decision today, he didn?t initially believe it. ?I said, ?I?ll wait until I see it because I?ve received calls like this before and it never happened,?? he says. The FDA has reviewed more than 50 safety studies, including one that shows the engineered salmon poses no more of an allergic potential than a wild salmon. The engineered Atlantic salmon contains an active growth-hormone gene from a Chinook salmon that allows it to reach market weight in 18 months rather than three years.
Anti-GE groups still have a long list of concerns. Lovera would like to see more studies done on the potential health risks of the salmon, published in peer-reviewed journals and conducted by scientists with no affiliation to AquaBounty. However, it?s not clear where the money to conduct such tests would come from, as?federal research funding rarely supports GE animals.
The GE salmon are currently kept within enclosed, inland tanks to prevent the small risk that the nearly sterile females will breed with wild salmon. But Lovera still worries that once the fish are approved, manufacturers will file for permits to keep them within nets in the open ocean in order to lower costs. ?This is basically the final step and we think the FDA has given a strong signal that they will accept the fish, and that is a mistake,? she says.
Stotish counters that as part of their application, AquaBounty has promised to not sell the fish to farmers who do not have enclosed, inland tanks. After 17 years and $60 million spent trying to win FDA approval, Stotish is still cautious. ?We are not so foolish to think that this process will suddenly be normal for us,? he says.
This article is reproduced with permission from the magazine Nature. The article was first published on December 22, 2012.
Source: http://rss.sciam.com/click.phdo?i=b3182958be4d02ba37d0c4285035979b
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CAIRO (Reuters) - Standard & Poors' cut Egypt's long-term credit rating on Monday and said another downgrade was possible if deepening political turbulence undermines efforts to prop up the economy and public finances.
Egypt's popular uprising two years ago drove away tourists and foreign investors alike, helping push its budget deficit into double digits as a percentage of national output and worsening its balance of payments.
A divisive battle over a new constitution this month has also prompted the government to delay urgent austerity measures and put a crucial $4.8 billion IMF loan on hold.
S&P reduced Egypt's long-term sovereign rating to 'B-' from 'B', but left its short-term rating at 'B' for both foreign- and local-currency debt. It kept its negative outlook on the rating - suggesting it sees another cut as the most likely next move.
"A further downgrade is possible if a significant worsening of the domestic political situation results in a sharp deterioration of economic indicators such as foreign exchange reserves or the government's deficit," S&P said.
Some Egyptians have said recently they had withdrawn funds from banks out of concern that they would be frozen by the authorities.
Seeking to quell what it called these "public rumors", the central bank on Monday said it was taking all steps needed to safeguard deposits in Egyptian banks whether denominated in local or foreign currencies.
Egypt's domestic debt was equivalent to 69.7 percent of gross domestic product as of the end of September while its foreign debt was 13.1 percent of GDP, according to the finance ministry.
Egypt reached an initial accord with the International Monetary Fund (IMF) last month for a financial support package, but later put on hold a series of austerity measures deemed necessary to secure IMF approval.
The government then asked the IMF to delay until January a meeting to approve the loan, which looks increasingly vital to prop up government finances but requires it to take unpopular measures on taxation and spending.
The measures included increases in sales tax on goods and services ranging from alcoholic beverages, cigarettes and mobile phone calls to automobile licenses and quarrying permits.
President Mohamed Mursi withdrew them within hours of their being announced after criticism from his opponents and the media.
(Reporting by Patrick Werr; Editing by Patrick Graham and Hugh Lawson)
Source: http://news.yahoo.com/p-cuts-egypt-rating-political-strife-131727460--business.html
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DENVER (AP) ? In the span of about five minutes, Peyton Manning threw his third touchdown pass of the afternoon, Von Miller knocked the opposing quarterback out of the game and the Denver Broncos completely demoralized the tenacious-but-overmatched Cleveland Browns.
During that third-quarter flurry Sunday, the Broncos looked a lot like the best team in the AFC, and with one more Sunday like this one, they could go into the playoffs as just that.
Manning threw for a season-high 339 yards and three scores and Miller was in on two sacks, the second of which ended Brandon Weeden's day, leading Denver to a 34-12 win ? a victory that pulled the Broncos (12-3) into a tie with Houston for the best record in the conference.
Miller finished with 1? sacks to move to 17? for the season, beating Elvis Dumervil's franchise record by half a sack.
The Broncos carry a 10-game winning streak, second longest in franchise history, into the final week at home against Kansas City (2-13). The Texans, who hold the tiebreaker against Denver, have lost two of three and they close the season at Indianapolis (10-5).
Manning finished 30 for 43 and has 4,355 yards this season, moving him past John Elway and Jake Plummer for second on the franchise's single-season passing list. He wasn't perfect ? he threw an interception late in the first half for Denver's first turnover inside the opponent's 10-yard line all season ? but when he was clicking, the Broncos couldn't be stopped, at least not by Cleveland (5-10).
His first two touchdown throws came with Browns cornerback Sheldon Brown draped all over the Denver receivers and only the smallest of windows available for Manning to hit. But he hit them. The first went to Demaryius Thomas for 22 yards, the second to Eric Decker for 10, and the Broncos had a 14-3 lead after their first two possessions.
Both passes wrapped up 80-yard drives in which Manning ran his version of the hurry-up, getting the offense to the line quickly, barking out audibles, switching from runs to passes, then back again. He even once used cadence to draw an offside penalty on third-and-2 to keep a drive going.
The Broncos passed the 30-point mark for the 10th time this season.
Oh, there were frustrations. Denver finished with a season-high 11 penalties; the interception that ended the second-quarter drive; Broncos kick returners bobbled the ball twice, but recovered both; and Browns lineman Billy Winn plowed guard Zane Beadles into Manning, altering the trajectory of a pass 30 feet into the air for an incompletion.
Manning pounded his orange-gloved fist into the turf after that one.
Meanwhile, Weeden and Browns running back Trent Richardson (nine carries, 53 yards), both rookies, showed signs of how good they might be some day. With the help of a questionable personal foul call against Champ Bailey, Weeden poked his way to a 45-yard drive for a field goal that cut Cleveland's deficit to 14-6 early in the third quarter.
But Manning responded with a 91-yard touchdown drive, highlighted when he threw a dart that slammed off Decker's hands and dropped into those of receiver Brandon Stokley. Just another Broncos first down ? and another sign this was not Cleveland's day.
Two plays later, Manning hit Decker for an 8-yard touchdown to make it 21-6.
Three plays after that, Miller slammed Weeden to the turf, injuring his right shoulder. Weeden slammed his helmet to the ground on the sideline and walked slowly to the locker room ? his day complete after going 12 for 19 for 104 yards. Manning had surpassed that total after his second pass of the second quarter. And it got worse from there. Late in the fourth quarter, Richardson had to be carted off the field with a left ankle injury; the Browns offered no report on the injury.
___
Online: http://pro32.ap.org/poll and http://twitter.com/AP_NFL
Source: http://news.yahoo.com/mannings-3-tds-lead-broncos-34-12-win-001801005--spt.html
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?Mobile has really been kicking butt.?
That?s what Neil Patel of Quick Sprout told us when we asked him about the future of the internet. He went on to say:
?It?s going to be more tablet and mobile based in the next few years. We?re going to start seeing a lot less laptops and computers and more and more mobile phones for everything.?
?Want to buy something? Cool. Click a button and it?s charged to your mobile phone.?
Neil?s right:? we asked 20 of the world?s top online entrepreneurs about the trends that would define the future of online business and ?mobile? was the most common answer (online video was #2). If you have a website and you?re not thinking about mobile, then you?re missing out on the biggest thing to happen to the Internet since broadband.
There are now more than 1.2 billion mobile web users worldwide and 25% of US internet users are mobile only. Mobile searches have quadrupled in the last year and this phenomenon is not going away any time soon.
Below, I?ll explain what makes mobile users different based on research from Google Mobile. Then I?ll share the mobile content, design, email marketing, and sales copy strategies that I learned directly from experts like Syed Balkhi and Yanik Silver.

Mobile users experience the web differently. First of all, the screen is smaller. This can be a problem, as Shane Ketterman points out on CopyBlogger:
?What happens when readers feel cramped or have to work hard to navigate your site or read your content? They leave.?
In order to keep visitors around, keep your pages straightforward and your links ?thumb-sized? ? especially call-to-action buttons.
Mobile users are often accessing the web on the go and therefore they?re more likely to be using the web to meet an immediate, specific need.
According to a Google Mobile Ads study, Nine out 10 mobile searches result in an action and 88% of these users take action within the first day.
Smartphones and tablets are becoming more and more powerful with every iteration, but they still can?t compete with the big boys (laptops and desktops) in terms of speed.
So if you?re load times are lagging on those devices, you?ll definitely be turning mobile users away. Try removing unnecessary plugins, images, and eliminating any Flash or Javascript.
Mobile devices are so convenient to use that they?re often used as a supplement to other activities. 72% of people use their smartphones while consuming other media, a third while watching TV.
So keep in mind that you likely won?t have the full attention of your mobile audience.
Mobile users can access the web from anywhere and that changes what they?re able to search for online. For instance, 70% use their smartphones while shopping in a store to help make purchasing decisions.
Your online audience is no longer guaranteed to be sitting at a desk. Think about your niche:? from what other locations and situations might your audience be accessing your site?
?

Syed Balkhi is one of the world?s most forward-thinking bloggers, especially when it comes to content. His latest project, List25, has earned over 200,000 Facebook likes in just over a year.
He told us that ?easy to consume? content is the wave of the future, as more and more people spend their online hours casually browsing mobile devices:
?We?re seeing an emergence of infographics and motion graphics. We?re going towards an age of data consumption and we need to make it as easy to consume as possible, because people?s attention span is so low. To captivate that short attention span, you have to have very, very compelling content that?s very easy to consume.?
Income Diary is a strong proponent of writing long content because it ranks better (the average front-page search result is 2,000+ words) and because it?s more likely to be shared (as demonstrated by Neil Patel).
But Syed?s right too. As more and more people go mobile, more and more web users will be browsing your site while waiting in line, watching TV, and otherwise unable to engage with in-depth content. You can make your content more ?easy-to-consume? by putting an emphasis on visuals and videos ? and keeping text to a minimum.
Jacob Cass is a graphic designer at NYC-based firm Ammirati (clients include Nintendo, Zynga, and Jerry Seinfeld). When we asked him about the future of web design, he immediately start talking about mobile:
?Responsive design is at the top of my list. A responsive website is a website that adapts to the screen that you?re viewing it on. For example, a website will change its look when you?re viewing it on a mobile device, versus a large screen.?
Upgrading to a responsive web design may be the single most important thing you can do to make your website more mobile friendly.
If you?re wondering how to make the? switch over to responsive web design, Jacob gave us this advice, ?For my site, I used the Skeleton responsive boilerplate. There?s really no reason to redo everything if there are already frameworks in place. Another good one to explore is Bootstrap, by Twitter.?

?More and more people are going to be reading your email on little screens.?
David Risley, from Web Domination 20
Nearly all mobile users are using their device to check their email.
According to Andigo New Media, your first priority should be to limit scrolling on the email:? ?left to right scrolling is an absolute no-no but even north/south scrolling should be limited whenever possible.?
David Risley earns a six-figure income through email marketing. In our interview, he told us that optimizing your emails for mobile devices mostly comes down to keeping it as simple as possible ? especially since some mobile devices aren?t so great at displaying email:
?The nice smart phones are pretty good at scaling the email up and down. But not everybody?s walking around with an iPhone, so you have to just keep things as simple as you can.?
If you?ve got an email list, then try opening your emails with a variety of different mobile devices to see how they look.
?You?ve got to balance the device with the message.?
Yanik Silver, from Web Domination 20
Yanik Silver is the creator of Instant Sales Letters and quite possibly the world?s leading expert in online copywriting. He?s also one of the first copywriters to recognize that online sales letters should adapt for mobile users.
His first advice is to keep it short:
?You?ve got to make sure that your copy is ideal for someone coming off of a mobile device. Maybe that means even shorter paragraphs. Maybe that means keeping it really tight and engaging.?
Silver also sees a sales video as a way to level the copywriting playing field across all devices:
?For someone to scroll through on their iPhones through a twenty page sales letter is
going to be a lot tougher than watching a three minute video about it.?
These sales page videos don?t have to be flashy in order to be effective on mobile. Michael Dunlop uses a video that?s just voiceover and text for his Web Domination sales page. What matters it that mobile users can digest your entire message with just one touch of the screen.

The devices are small, but the mobile web is big? and only getting bigger.
The sooner you start running your website with a mobile audience in mind, the soon you?ll be able to benefit from this fast-growing demographic.
In this post, I reviewed mobile content, design, email marketing, and sales copy, but that?s really only scratching the surface. If you have any insights into mastering the mobile web ? or questions about it ? let us know in the comments.
Source: http://www.incomediary.com/mobile-web-content-design-email-sales
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When you want to improve self esteem, you need to increase your self perception. Perception is an immediate recognition or appreciation and when you apply this to yourself, you will improve self esteem. When you gauge your self esteem, you should base it on what you believe, what you love and not what you have.
Loving yourself is the way to improve self esteem. List the things where you believe that you have an important role to play in your life and in others lives. If people around you can see that you value yourself then they will give the same value to you and even better.
Learn to trust yourself. Oftentimes, we think that we can't do some tasks most people can and this is because we lack self trust. You are almost half done with the task when you trust yourself. Improve your self esteem by getting rid of doubts that are holding you back from performing your best potential.
You are unique. Always believe that you are unique and you have your own unique talents and capabilities that can diversely contribute to the world. If you do what you love, you may increase your self esteem. Being an expert on the things that you love can actually add more to your knowledge and experience thus a great way to improve self esteem.
Challenge yourself. If you haven't done an activity that you really like, challenge yourself to do it. This way, you can test your self confidence and you can positively change it. For example, exercise; set a goal that you can finish an actual 1 hour of exercise and you will be amazed with your self if you achieve your goal. Pushing yourself means building trust in your capabilities.
It may not be easy to improve self esteem instantly however taking one step at a time is a sure way to achieve your goal. When you need more push try using subliminal audio tool, it contains a lot of positive affirmations and these can motivate you to improve self esteem. Subliminal audio releases subliminal messages that target your subconscious mind. This is more effective when you listen to it while you are asleep. When you wake up, you will be amazed how energetic you are to take the steps to improve your self esteem. Remember, love yourself and everything will follow, self esteem, self trust and self perception.
Find out how to Improve Self Esteem can assist you in finding harmony in your life, be more alert and develop a strong sense of self belief will help you in so many other areas of your life at Clear Away Stress Now.
Source: http://articles.submityourarticle.com/improve-self-esteem-by-loving-yourself-308710
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Education loans imply a good deal for individuals as their potential depends upon the cash that is to be provided to all of them. Attending college is becoming a growing number of high-priced each college calendar year which is why student loans are very important for you to pupils and parents as well. Thus, in case you are considering university or perhaps student education loans especially, below are great tips and guidelines that would put your university life inside standpoint.
A single. Collect numbers
Gather statistics imply you need to today have a look at what kind of money is required to be able to truck schooling. Which means you need to have at least an idea the amount will be the price of your tuition and costs of your respective preferred study course. In addition to that, you need to be in a position to have an estimate regarding other outlays such as journey expenses, school text books, room and also table, expenses, private expenses, and other things.
2. Research about education loans
Should you have the information stated earlier, then this second step to adopt is to look tanie chwilowki as a student mortgage that is good for you. Most school loans aren?t the same because not every settlement ideas are compatible with just about all. Gain as much details as possible so that you can choose between your options available for you.
Three or more. Forms of education loan
You?ll find a few kinds of lending options readily available for university student bills: backed (depending on financial will need, and the govt will subsidize the interest charges till education and learning is done), unsubsidized (absolutely no financial require, interest accumulation begins quickly), direct Additionally financial products (Parent or guardian Loan for you to Undergrad College student), personal loans, and home collateral lending options.
Some. Distinguish and compare student education loans
Each one of the student loans reaches very least slightly distinct. Assess the types of student education loans to be able to restrict your selection procedure. They are various in terms of settlement phrases, grace period of time, as well as fees and penalties.
A few. Financial Need to have Student Loans
Such a student loan includes a low interest price which is in the govt for young students along with fiscal need. A person?s eye rate on this type of mortgage won?t start off before college student bez bik pozyczki has begun payment in the amount thus making it simpler and economical when weighed against additional education loans.
Some. Non-Financial Require Student Loans
This is fairly similar to the monetary will need education loan, the sole distinction could it be isn?t depending on the monetary need for your family and also the rate of interest starts off even though the university student remains to be in college.
6. Federal government In addition (Father or mother Mortgage regarding Undergraduate College students)
This type of student loan isn?t based on the economic wants in the college student. The mother and father from the child may sign up for this sort of education loan. Additionally, it doesn?t consider the family revenue as well as resource whenever looking for an education loan. How much qualifications is dependant on the educational expenditure less additional loans, scholarships and grants big t this individual pupil is approved pertaining to.
8. Exclusive Loans
People who A company named cutesamedayloans.com shown us a knowledge are providing such a financial loans usually are firms, financial institutions, as well as finance institutions. These lenders offer non-public student loans for undergrad as well as students. A person?s eye rates within this type of loan are actually higher therefore it is certainly not suited to individuals to decide on such a bank loan.
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With this kind of education loan, a house value mortgage as well as personal credit line may be the method homeowners truck college education. One particular possible edge here is a tax tax deductible awareness.
15. Decide on along with handle effectively
In the a variety of school loans mentioned previously, pick one or higher that?s suited to your requirements your financial budget. Make certain that when you have picked the kind of student loan that you like, you might really manage it nicely and handle the down sides which comes as you go along.
School loans were made for 2 causes. One is to help you a student economically of their hunt for college, and the some other reason is usually to enable them to become older people. With school loans, trainees has the capacity to face responsibilities which can be actually crucial as soon as that they step beyond their particular studying a long time straight into everyday routine.
Remember though these loans accomplish ultimately need to be reimbursed, following graduation if not sooner.
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What do real estate and online marketing have in common? Together they can create a
comprehensive strategy that is guaranteed to become a requirement with your business. Okay, maybe not something completely in common, but you get the idea.
Besides, if you aren?t using online marketing tools for your real estate business now, then it?s better now than never to make sure you are staying competitive. But like with any industry, there are certain real estate marketing tools which all agents and businesses need to know about and should be staples for any marketing strategy.
1. Facebook, Twitter, Pinterest, and others
You already have a Facebook and Twitter, but have you created an account on Pinterest for your company? How about a LinkedIn or Google+ account? While having profiles on major networks are well and good, don?t forget about the other big name contenders which can also serve a purpose for your business. For example, Pinterest has become hugely popular with all types of industries, even realtors can utilize it for content marketing efforts.
2. Email marketing generation software
Mail Chimp and Constant Contact are the biggest subscription and email marketing services that can help you manage all of your leads beyond your real estate lead capture software. All of those interested users coming in from your website, landing pages, Facebook, or even viewers watching your online video can all be engaged and become subscribers and potential long-term customers. Don?t leave work without email marketing!
3. Lead generation software
Complimentary to email marketing is lead generation, which is normally the follow-up of collecting email and user information to keep your leads warm. Any reasonable list of real estate marketing tools will have some sort of lead generation software like RealLead or Share-a-Sale, but lead generation doesn?t have to be a stand alone thing. It can be integrated into your content marketing, like video.
4. Video and image editing programs
Having clear and professional looking photos is essential for any real estate company, but sometimes the programs can be expensive or even require valuable time to learn everything. You can always rely on the Internet to provide easy and comprehensive editing tools for all of your pictures and video, though!
5. SMS services for gathering data and promotions
While you?re out and about, don?t miss anything when you have fully utilized texting SMS services for collecting and organizing phone numbers and being able to blast out information over SMS for marketing promotions. SMS through email and SMS shortcodes are some of the ways you can do that.
There are several other real estate video marketing tools you can use to see great results, such as QR code generators that can be used on all of your digital and traditional marketing materials as well as instantly creating a mobile version of your website through Instant Mobilizer. Or, you can browse real estate buying website Zillow for potential research purposes.
However, the biggest chunk of your online marketing will more than likely come in the form of content marketing?especially with video. The great thing about video is that most of these tools can be embedded and integrated with your video player for a fully-formed online campaign. And most of these tools are all budget friendly to boot!
Are you using any of these marketing tools for your real estate business?

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