Composition and Conservation Value of Epiphytic Lichen Communities on Common Ash in North-Western Alps: A First Assessment

In the western sector of the Alps, and particularly in the Aosta Valley, lichenological communities on broad-leaved trees have received very little attention, and information about lichen species associated with common ash (Fraxinus excelsior L.) are still scanty. Therefore, in this study, we analyzed epiphytic lichen communities of ash trees to estimate their composition, their conservation value, and their association with some key environmental variables. Our results show that lichen communities appear to be different in terms of occurrence and frequencies in different sampling sites. The tested environmental variables contribute to shape the lichen communities, which are significantly different (p Lecanora impudens and Rinodina polyspora) were included in the red list of Italian epiphytic lichens

In the Wake of Low v. Henry: Is Pre-Suit Discovery Now a Reality in Texas.

Following the Texas Supreme Court decision in Low v. Henry, the issue of whether an attorney may be liable for filing a “groundless pleading” has come to the forefront of Texas jurisprudence. This recent decision ought to pique Texas attorneys’ attention. In reprimanding egregious attorney conduct, did the Texas Supreme Court’s tightening of the Texas Rules of Civil Procedure increase the duties and responsibilities of all Texas attorneys by establishing what may amount to pre-suit discovery? Yet, courts presume pleadings and motions are filed in good faith, and the party seeking sanctions bears the burden of rebutting this presumption. The significant portion of the Texas rules mandate an attorney must certify that any pleading or motion signed by him or her is being brought in good faith with sufficient evidentiary support or basis in law. Further, they require the suit not be brought simply to harass the other party or to cause delay or increase litigation costs. Pre-Low, attorneys could make allegations requiring evidentiary support, because attorneys are not expected to have all relevant evidence and information before discovery has begun. Following Low, however, attorneys must know making such allegations expose them to liability via sanctions if the evidence is ultimately not acquired during discovery. While the Texas Supreme Court has moved toward tightening the procedural rules, the Low decision may result in unintended, adverse consequences. It is possible the Court did not intend to further restrict litigation by implementing what amounts to a requirement for pre-suit discovery. The Court’s intention is irrelevant, however, as the requirement now has precedential value. Thus, while the Court may not have intended the cumbersome requirement, attorneys ought now to conduct themselves as though such restrictions were fully intended or else subject themselves to the possibility of sanctions

In the Wake of Low v. Henry: Is Pre-Suit Discovery Now a Reality in Texas.

Following the Texas Supreme Court decision in Low v. Henry, the issue of whether an attorney may be liable for filing a “groundless pleading” has come to the forefront of Texas jurisprudence. This recent decision ought to pique Texas attorneys’ attention. In reprimanding egregious attorney conduct, did the Texas Supreme Court’s tightening of the Texas Rules of Civil Procedure increase the duties and responsibilities of all Texas attorneys by establishing what may amount to pre-suit discovery? Yet, courts presume pleadings and motions are filed in good faith, and the party seeking sanctions bears the burden of rebutting this presumption. The significant portion of the Texas rules mandate an attorney must certify that any pleading or motion signed by him or her is being brought in good faith with sufficient evidentiary support or basis in law. Further, they require the suit not be brought simply to harass the other party or to cause delay or increase litigation costs. Pre-Low, attorneys could make allegations requiring evidentiary support, because attorneys are not expected to have all relevant evidence and information before discovery has begun. Following Low, however, attorneys must know making such allegations expose them to liability via sanctions if the evidence is ultimately not acquired during discovery. While the Texas Supreme Court has moved toward tightening the procedural rules, the Low decision may result in unintended, adverse consequences. It is possible the Court did not intend to further restrict litigation by implementing what amounts to a requirement for pre-suit discovery. The Court’s intention is irrelevant, however, as the requirement now has precedential value. Thus, while the Court may not have intended the cumbersome requirement, attorneys ought now to conduct themselves as though such restrictions were fully intended or else subject themselves to the possibility of sanctions

Effects of cervical headgear and pendulum appliance on vertical dimension in growing subjects: a retrospective controlled clinical trial

Summary OBJECTIVE : To analyze the effects on vertical dentoskeletal dimension produced by cervical headgear (CHG) or Pendulum (P) both followed by full fixed appliances in growing patients with Class II malocclusion