Environmental Law - Northcoast Environmental Center v. Glickman

In Northcoast Environmental Center v. Glickman, the United States Court of Appeals for the Ninth Circuit held that a less deferential standard of reasonableness applied to its review of legal questions that determined the applicability of the National Environmental Policy Act (NEPA,). Thus, when no facts are in dispute, an agency\u27s decision not to prepare an Environmental Impact Statement (EIS) will be upheld unless it is unreasonable. When facts are in dispute, however, the Supreme Court decision of Marsh v. Oregon Natural Resources Council, which applied an arbitrary and capricious standard of review, controls. The Ninth Circuit also decided that district court had not abused its discretion by declining to follow an exception to the Administrative Procedure Act (APA), which allows a judge to look beyond the administrative record in an appeal. The district court refused to look at documents outside the record based on a finding that they were unnecessary and cumulative. The Ninth Circuit agreed even though Northcoast Environmental Center\u27s documents fit within an exception to the APA

Environmental Law - Northcoast Environmental Center v. Glickman

In Northcoast Environmental Center v. Glickman, the United States Court of Appeals for the Ninth Circuit held that a less deferential standard of reasonableness applied to its review of legal questions that determined the applicability of the National Environmental Policy Act (NEPA,). Thus, when no facts are in dispute, an agency\u27s decision not to prepare an Environmental Impact Statement (EIS) will be upheld unless it is unreasonable. When facts are in dispute, however, the Supreme Court decision of Marsh v. Oregon Natural Resources Council, which applied an arbitrary and capricious standard of review, controls. The Ninth Circuit also decided that district court had not abused its discretion by declining to follow an exception to the Administrative Procedure Act (APA), which allows a judge to look beyond the administrative record in an appeal. The district court refused to look at documents outside the record based on a finding that they were unnecessary and cumulative. The Ninth Circuit agreed even though Northcoast Environmental Center\u27s documents fit within an exception to the APA

Environmental Law - City of Auburn v. U.S. Government

In City of Auburn v. U.S. Government; the United States Court of Appeals for the Ninth Circuit held that the plain language of the Interstate Commerce Commission Termination Act (lCCTA) preempts state and local permitting laws regarding railroad operations. The court reasoned that since the ICCTA gave the Surface Transportation Board (Board), a federal agency, exclusive jurisdiction over certain railroad matters, railroad companies were required to follow only federal permitting laws, not those of a state or city. Thus, Burlington Northern Railroad is not subject to the environmental permitting laws of the city of Auburn. The court also held that the Board did not abuse its discretion in approving Burlington\u27s proposal to reacquire the Stampede Pass railroad line without conducting a full Environmental Impact Statement. The court determined that the Board\u27s sixty-page environmental assessment, constituted a thorough, independent investigation of the environmental consequences of reopening Stampede Pass. Thus, the investigation was sufficient to satisfy the National Environmental Policy Act (NEPA). Consequently, the Board\u27s decision not to conduct an EIS was neither arbitrary nor capricious and was therefore upheld

The impact of angel investors on founders of new ventures in the medical technology industry

Thesis (S.M.)--Harvard-MIT Division of Health Sciences and Technology, 2011.Cataloged from PDF version of thesis.Includes bibliographical references (p. 50-53).Founders of new ventures in the medical technology (Medtech) industry require capital to establish, sustain, and grow their companies. Most founders must seek some form of external capital to meet these demands; in Medtech, the most well-known and prestigious of these is venture capital (VC). However, another type, angel investors, may be as important as VCs. Angels are accredited investors that invest their own money directly in new ventures. Founders of new Medtech ventures may choose to seek capital from angel investors in addition to, or instead of, venture capitalists. Unfortunately, there is little research available on outcomes for founders and their firms when angel investors are involved. Like VCs, angels seek financial returns from their investments; however, there may be additional and different motivations at play that make angels willing to grant more friendly terms to founders. As a result, it may actually be advantageous for founders to seek capital from angel investors. This paper addresses the question of whether founders of new ventures in the Medtech industry have better outcomes in terms of ownership and control of the company when one or more investment rounds involve angel investors in addition to, or in place of, VCs. Ownership is measured by the amount of equity owned just prior to an IPO, and control by the presence of founders as employees or directors at the time of the IPO. Analyzing S-is from the last 10 years of initial public offerings (IPOs), a dataset was constructed that comprised the shareholders of the 63 Medtech companies that experienced an IPO between 2001 and 2010. Of these, 18 companies had some presence of angel ownership that could be gleaned from the S-1; of those, 12 had at least a 5% stake belonging to angels. Results presented in the paper show, for the first time, those founders of Medtech firms with angel investors as shareholders at the time of IPO have significantly greater ownership of shares and significantly greater control of the firm as an employee or director than founders of firms without angels present. Angel-backed firms required less investment capital and no more time to reach the IPO, and, importantly, did not suffer with respect to the overall valuation of the firm. On the contrary, there was a trend of firms - and founders themselves - seeming to benefit from a valuation perspective, and significantly better from a multiple perspective, when angel investors were present. Even when firms received backing from venture capitalists, angel investor involvement also seemed to generally improve the performance of the firm and of the founders along the measured dimensions.by Alan R. Braly.S.M

Operative Treatment of Cervical Myelopathy: Cervical Laminoplasty

Cervical spondylotic myelopathy (CSM) is a degenerative process which may result in clinical signs and symptoms which require surgical intervention. Many treatment options have been proposed with various degrees of technical difficulty and technique sensitive benefits. We review laminoplasty as a motion-sparing posterior decompressive method. Current literature supports the use of laminoplasty for indicated decompression. We also decribe our surgical technique for an open-door, or “hinged”, laminoplasty

A Summer Internship with U.S. Senator Patty Murray - Regional Office, Everett, Washington

During the summer of 1996,1 participated in the US Senate internship program in the Everett Regional office of Senator Patty Murray. This was a fairly new office, having begun only five months before I started in July, as well as a small office. (It had one part- time person, my supervisor, which became two upon my arrival.) There was no precedent for what my job entailed so it was designed as the summer progressed. My supervisor was Jill McKinney, a very friendly and helpful woman who had been in the “political industry of staffing for various Congress-people over the years. She was very knowledgeable in her work, however, being in charge of the northwestern counties of Washington was a fairly new situation for her. I feel this was beneficial to my learning experience because sometimes she wasn’t able to help me and I was forced to go into some situations without forewarning. This provided some very exciting and very stressful events over the summer