Summary of FDIC v. Rhodes, 130 Nev. Adv. Op. 8

The Court determined that (1) 12 U.S.C. § 1821(d)(14)(A) (the “FDIC extender statute”)[1] preempts any similarly applicable state law, in this case NRS 40.4055(1)[2]; and (2) the Court refused to adopt a rule that a state statute of repose cannot be preempted by federal law. [1] “Under the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (FIRREA),…the [FDIC] acts as a conservator or receiver for failed financial institutions. 12 U.S.C. § 1821(d)(2)(A) (2012). FIRREA extends the time period for the FDIC, in its capacity as the failed institution\u27s conservator or receiver, to bring a contract claim that has otherwise been barred by a state statutory time limitation: [T]he applicable statute of limitations with regard to any action brought by [the FDIC] as conservator or receiver shall be- (i) in the case of any contract claim, the longer of— (I) the 6-year period beginning on the date the claim accrues; or (II) the period applicable under State law. 12 U.S.C. § 1821(d)(14)(A) (2012)” [2] “Nevada provides for a shorter six-month time limitation for deficiency judgment actions under NRS 40.455(1), which states that upon application of the judgment creditor or the beneficiary of the deed of trust within 6 months after the date of the foreclosure sale or the trustee\u27s sale held pursuant to NRS 107.080, respectively, and after the required hearing, the court shall award a deficiency judgment to the judgment creditor or the beneficiary of the deed of trust. . .

Micronutrients in chronic heart failure

Heart failure (HF)-associated mortality remains high, despite guideline-recommended medical therapies. Poor nutritional status and unintentional cachexia have been shown to have a strong association with worse survival in HF patients. Importantly, micronutrient deficiencies are potential contributing factors to the progression of HF. This review aims to summarize contemporary evidence on the role of micronutrients in the pathophysiology and outcome of HF patients. Emphasis will be given to the most well-studied micronutrients, specifically, vitamin D, vitamin B complex, coenzyme Q10 and L-carnitine