Burger King Corp. v. Rudzewicz, 105 S. Ct. 2174 (1985)

Civil Procedure-PERSONAL JURISDICTION-DUE PROCESS LIMITS THE REACH OF FLORIDA\u27S LONG-ARM STATUTE IN BRINGING CONTRACT DEFENDANTS TO THE HOME OF THE WHOPPE

Sinclair Investments (UK) Ltd v Versailles Trade Finance Ltd (in Administration) Court of Appeal [2011] EWCA Civ 347

THE PURSUIT OF PROPRIETARY REMEDIES FOR BREACH OF FIDUCIARY DUTYThere is an old adage that if an opportunity looks too good to be true, then it almost certainly is. Despite this, the law reports are filled with examples of people seeking redress for the fallout from “get rich quick” schemes that have gone wrong. One type of scam, exemplified by the fraudulent investment scheme run by Bernard Madoff from the United States and which collapsed in 2008, is known as a “Ponzi1 scheme”.2 The wrongdoer in such a scheme invites “investments” promising a high rate of return. The funds subscribed are not in fact invested (or if they are, they are invested in vehicles which produce a lower rate of return than that promised). Instead, the money from new subscribers is used to pay the rewards to earlier subscribers. In due course the scheme is bound to collapse, because there will be a point at which the new funds coming in are insufficient to make the payments to existing subscribers, and the bubble of new investment can continue only for as long as there is confidence on the part of subscribers, encouraging fresh deposits. When the scheme begins to unravel, it falls apart very quickly, since the assets held by the wrongdoer are inevitably inadequate to reimburse all of the subscribers in full. In the ensuing insolvent liquidation, subscribers stand to recover only a small fraction of their subscription as unsecured creditors unless they can demonstrate that they have a proprietary interest in some of the remaining assets. Sinclair Investments (UK) Ltd v Versailles Trade Finance Ltd is a case involving what the judge at first instance called a “classic Ponzi scheme”

Spread Trustee Company Ltd v Hutcheson

EXEMPTING A trustee for gross negligenceCan an exemption clause exclude a trustee’s liability for gross negligence? That was the question which the Privy Council was required to consider in this appeal from the Guernsey Courts. Guernsey has developed substantial activities in finance and trusts, and now has legislation (the Trusts (Guernsey) Law 2007) creating a legal framework for this business. The legislative framework was first introduced in 1989, and amended in 1990. The effect of an exemption clause had never been considered in litigation in Guernsey prior to the introduction of legislation.

EC86-1862 Nebraska Commercial Turfgrass Disease Control Guide For Profession Turfgrass Managers

This extension circular contains four-color photos to help professional turfgrass managers identify the different turfgrass diseases in Nebraska. Tables are included that describe the disease, the common name of fungicides, trade names, and descriptions of how to control these diseases

EC86-1862 Nebraska Commercial Turfgrass Disease Control Guide For Profession Turfgrass Managers

This extension circular contains four-color photos to help professional turfgrass managers identify the different turfgrass diseases in Nebraska. Tables are included that describe the disease, the common name of fungicides, trade names, and descriptions of how to control these diseases

Molecular characterization of cDNA encoding resistance gene-like sequences in Buchloe dactyloides

Current knowledge of resistance (R) genes and their use for genetic improvement in buffalograss (Buchloe dactyloides [Nutt.] Engelm.) lag behind most crop plants. This study was conducted to clone and characterize cDNA encoding R gene-like (RGL) sequences in buffalograss. This report is the first to clone and-characterize of buffalograss RGLs. Degenerate primers designed from the conserved motifs of known R genes were used to amplify RGLs and fragments of expected size were isolated and cloned. Sequence analysis of cDNA clones and analysis of putative translation products revealed that most encoded amino acid sequences shared the similar conserved motifs found in the cloned plant disease resistance genes RPS2, MLA6, L6, RPM1, and Xa1. These results indicated diversity of the R gene candidate sequences in buffalograss. Analysis of 5' rapid amplification of cDNA ends (RACE), applied to investigate upstream of RGLs, indicated that regulatory sequences such as TATA box were conserved among the RGLs identified. The cloned RGL in this study will further enhance our knowledge on organization, function, and evolution of R gene family in buffalograss. With the sequences of the primers and sizes of the markers provided, these RGL markers are readily available for use in a genomics-assisted selection in buffalograss

James B Beard: The Father of Contemporary Turfgrass Science

James B Beard (24 Sept 1935 to 8 May 2018) can rightly be considered the “Father” of contemporary turfgrass science. During his career, he was known for setting a standard that provided the foundation for turfgrass science through his thorough approach to research, teaching, mentoring and communications. The books he published outlined a vision for an evolving scientific discipline. He trained and mentored \u3e45 domestic and international doctoral and master students and numerous post-doctoral trainees, who in turn continued to raise the quality of contemporary turfgrass science in the USA and internationally. He led the effort to change the name of Division C- 5 of the Crop Science Society of America (CSSA) from Turfgrass to Turfgrass Science, making C-5 an important and a vital part of the society. His subsequent rigorous education and mentoring of others continued to strengthen the division. He recognized the importance of quality, peer-reviewed science and the need for C-5 to be represented on the Crop Science Journal (CSJ) Editorial Board to expedite this goal. His leadership and encouragement led to the creation of a C-5 Technical Editor position on the CSJ Editorial Board in 2002. Beard provided the vision and worked with other leaders worldwide to develop the International Turfgrass Society (ITS) and the ITS Research Journal. The ITS and its leaders and members have been instrumental in enhancing turfgrass science internationally. Beard’s leadership, along with others in turfgrass academia and industry, resulted in the USGA Turfgrass and Environmental Research Program that provides a competitive grant-fund source for turfgrass research. Beard appreciated and vigorously studied history and contributions to turfgrass science by those who went before us. He leaves behind a legacy in science that deserves recognition and respect. It is our hope that this synopsis of Beard’s career accomplishments will inspire present and future turfgrass scientists to follow in his footsteps

Heat tolerance around flowering in wheat identified as a key trait for increased yield potential in Europe under climate change

To deliver food security for the 9 billon population in 2050, a 70% increase in world food supply will be required. Projected climatic and environmental changes emphasize the need for breeding strategies that delivers both a substantial increase in yield potential and resilience to extreme weather events such as heat waves, late frost, and drought. Heat stress around sensitive stages of wheat development has been identified as a possible threat to wheat production in Europe. However, no estimates have been made to assess yield losses due to increased frequency and magnitude of heat stress under climate change. Using existing experimental data, the Sirius wheat model was refined by incorporating the effects of extreme temperature during flowering and grain filling on accelerated leaf senescence, grain number, and grain weight. This allowed us, for the first time, to quantify yield losses resulting from heat stress under climate change. The model was used to optimize wheat ideotypes for CMIP5-based climate scenarios for 2050 at six sites in Europe with diverse climates. The yield potential for heat-tolerant ideotypes can be substantially increased in the future (e.g. by 80% at Seville, 100% at Debrecen) compared with the current cultivars by selecting an optimal combination of wheat traits, e.g. optimal phenology and extended duration of grain filling. However, at two sites, Seville and Debrecen, the grain yields of heat-sensitive ideotypes were substantially lower (by 54% and 16%) and more variable compared with heat-tolerant ideotypes, because the extended grain filling required for the increased yield potential was in conflict with episodes of high temperature during flowering and grain filling. Despite much earlier flowering at these sites, the risk of heat stress affecting yields of heat-sensitive ideotypes remained high. Therefore, heat tolerance in wheat is likely to become a key trait for increased yield potential and yield stability in southern Europe in the future