Brief for the Plaintiff-Appellant Lucas Rosa in the United States Court of Appeals for the First Circuit Lucas Rosa V. Park West Bank and Trust Company on appeal from the United States District Court for the District of Massachusetts

The District Court fundamentally misconceived the law as applicable to the Plaintiffs claim by concluding that there may be no relationship, as a matter of law, between telling a bank customer what to wear and sex discrimination. It also misapplied Rule 12(b)(6) to the extent that it resolved any factual questions beyond the allegations of the Complaint regarding the basis of the Bank\u27s different treatment of the Plaintiff. Finally, because the District Court incorrectly dismissed the single federal claim in Plaintiffs Complaint, it improperly dismissed Plaintiffs pendant state claims for want of federal court jurisdiction

Brief for the Plaintiff-Appellant Lucas Rosa in the United States Court of Appeals for the First Circuit Lucas Rosa V. Park West Bank and Trust Company on appeal from the United States District Court for the District of Massachusetts

The District Court fundamentally misconceived the law as applicable to the Plaintiffs claim by concluding that there may be no relationship, as a matter of law, between telling a bank customer what to wear and sex discrimination. It also misapplied Rule 12(b)(6) to the extent that it resolved any factual questions beyond the allegations of the Complaint regarding the basis of the Bank\u27s different treatment of the Plaintiff. Finally, because the District Court incorrectly dismissed the single federal claim in Plaintiffs Complaint, it improperly dismissed Plaintiffs pendant state claims for want of federal court jurisdiction

The Freedom to Marry for Same-Sex Couples: The Opening Appellate Brief of Plaintiffs Stan Baker Et Al. In \u3cem\u3eBaker Et Al. V. State of Vermont\u3c/em\u3e

As the first state to prohibit slavery by constitution, and one of the few states which, from its inception, extended the vote to male citizens who did not own land, the State of Vermont has long been at the forefront of this nation\u27s march toward full equality for all of its citizens. In July 1997, three same-sex couples challenged Vermont to act as a leader yet again, this time in affording full civil rights to the State\u27s gay and lesbian citizens. Stan Baker and Peter Harrigan, Nina Beck and Stacy Jolles, and Holly Puterbaugh and Lois Farnham were denied marriage licenses by their respective town clerks in the summer of 1997. They sued the State of Vermont and the towns, arguing that the marriage statutes allowed them to marry, and that if the law did purport to limit marriage to different sex unions it would be unconstitutional. The trial court dismissed their claims in December 1997, and the couples appealed to the Vermont Supreme Court. The court heard oral arguments on the case on November 18, 1998

The Freedom to Marry for Same-Sex Couples: The Opening Appellate Brief of Plaintiffs Stan Baker Et Al. In \u3cem\u3eBaker Et Al. V. State of Vermont\u3c/em\u3e

As the first state to prohibit slavery by constitution, and one of the few states which, from its inception, extended the vote to male citizens who did not own land, the State of Vermont has long been at the forefront of this nation\u27s march toward full equality for all of its citizens. In July 1997, three same-sex couples challenged Vermont to act as a leader yet again, this time in affording full civil rights to the State\u27s gay and lesbian citizens. Stan Baker and Peter Harrigan, Nina Beck and Stacy Jolles, and Holly Puterbaugh and Lois Farnham were denied marriage licenses by their respective town clerks in the summer of 1997. They sued the State of Vermont and the towns, arguing that the marriage statutes allowed them to marry, and that if the law did purport to limit marriage to different sex unions it would be unconstitutional. The trial court dismissed their claims in December 1997, and the couples appealed to the Vermont Supreme Court. The court heard oral arguments on the case on November 18, 1998

The Freedom to Marry for Same-Sex Couples: The Opening Appellate Brief of Plaintiffs Stan Baker Et Al. In \u3cem\u3eBaker Et Al. V. State of Vermont\u3c/em\u3e

As the first state to prohibit slavery by constitution, and one of the few states which, from its inception, extended the vote to male citizens who did not own land, the State of Vermont has long been at the forefront of this nation\u27s march toward full equality for all of its citizens. In July 1997, three same-sex couples challenged Vermont to act as a leader yet again, this time in affording full civil rights to the State\u27s gay and lesbian citizens. Stan Baker and Peter Harrigan, Nina Beck and Stacy Jolles, and Holly Puterbaugh and Lois Farnham were denied marriage licenses by their respective town clerks in the summer of 1997. They sued the State of Vermont and the towns, arguing that the marriage statutes allowed them to marry, and that if the law did purport to limit marriage to different sex unions it would be unconstitutional. The trial court dismissed their claims in December 1997, and the couples appealed to the Vermont Supreme Court. The court heard oral arguments on the case on November 18, 1998

Occupational cooling practices of emergency first responders in the United States: A survey

This is an accepted manuscript of an article published by Taylor & Francis in Temperature on 29/07/2018, available online: https://doi.org/10.1080/23328940.2018.1493907 The accepted version of the publication may differ from the final published version.© 2018 Informa UK Limited, trading as Taylor & Francis Group. Despite extensive documentation directed specifically toward mitigating thermal strain of first responders, we wished to ascertain the degree to which first responders applied cooling strategies, and what opinions are held by the various agencies/departments within the United States. An internet-based survey of first responders was distributed to the International Association of Fire Chiefs, International Association of Fire Firefighters, National Bomb Squad Advisory Board and the USA Interagency Board and their subsequent departments and branches. Individual first responder departments were questioned regarding the use of pre-, concurrent, post-cooling, types of methods employed, and/or reasons why they had not incorporated various methods in first responder deployment. Completed surveys were collected from 119 unique de-identified departments, including those working in law enforcement (29%), as firefighters (29%), EOD (28%) and HAZMAT technicians (15%). One-hundred and eighteen departments (99%) reported heat strain/illness to be a risk to employee safety during occupational duties. The percentage of departments with at least one case of heat illness in the previous year were as follows: fire (39%) HAZMAT (23%), EOD (20%) and law enforcement (18%). Post-cooling was the scheduled cooling method implemented the most (63%). Fire departments were significantly more likely to use post-cooling, as well as combine two types of scheduled cooling compared to other departments. Importantly, 25% of all departments surveyed provided no cooling whatsoever. The greatest barriers to personnel cooling were as follows–availability, cost, logistics, and knowledge. Our findings could aid in a better understanding of current practices and perceptions of heat illness and injury prevention in United States first responders. Abbreviations: EOD: explosive ordnance disposal; HAZMAT: hazardous materials.This project is financially supported by the United States Government through the United States Department of Defense (DOD).Published versio

Ultrasonic vocalization playback as an affective assay at both neural and behavioral levels: Implications for understanding adversity-induced emotional dysfunction

[Abstract restricted