Privileged Communications between Counsel and the Corporate Client

At present inconsistent lower federal appellate court decisions governing the use of the attorney-client privilege and work-product doctrine apply to the discovery of communications between counsel and the corporate client. Because of the distinctions that have developed in the application of the corporate attorney-client privilege and work-product doctrine due to the unique factual settings in which the issues have arisen, prior case law may not be totally preempted by the Supreme Court decision in Upjohn. This article will explore some of these divergent opinions to determine the probable effect that the Court\u27s decision in Upjohn will have upon communications between counsel and the corporate client

Privileged Communications between Counsel and the Corporate Client

At present inconsistent lower federal appellate court decisions governing the use of the attorney-client privilege and work-product doctrine apply to the discovery of communications between counsel and the corporate client. Because of the distinctions that have developed in the application of the corporate attorney-client privilege and work-product doctrine due to the unique factual settings in which the issues have arisen, prior case law may not be totally preempted by the Supreme Court decision in Upjohn. This article will explore some of these divergent opinions to determine the probable effect that the Court\u27s decision in Upjohn will have upon communications between counsel and the corporate client

Privileged Communications between Counsel and the Corporate Client

At present inconsistent lower federal appellate court decisions governing the use of the attorney-client privilege and work-product doctrine apply to the discovery of communications between counsel and the corporate client. Because of the distinctions that have developed in the application of the corporate attorney-client privilege and work-product doctrine due to the unique factual settings in which the issues have arisen, prior case law may not be totally preempted by the Supreme Court decision in Upjohn. This article will explore some of these divergent opinions to determine the probable effect that the Court\u27s decision in Upjohn will have upon communications between counsel and the corporate client

Use of Cholecystokinin to Prevent the Development of Parenteral Nutritionâ Associated Cholestasis

Peer Reviewedhttps://deepblue.lib.umich.edu/bitstream/2027.42/142290/1/jpen0100.pd

Tissue-Specific Features of the T Cell Repertoire After Allogeneic Hematopoietic Cell Transplantation in Human and Mouse

T cells are the central drivers of many inflammatory diseases, but the repertoire of tissue-resident T cells at sites of pathology in human organs remains poorly understood. We examined the site-specificity of T cell receptor (TCR) repertoires across tissues (5 to 18 tissues per patient) in prospectively collected autopsies of patients with and without graft-versus-host disease (GVHD), a potentially lethal tissue-targeting complication of allogeneic hematopoietic cell transplantation, and in mouse models of GVHD. Anatomic similarity between tissues was a key determinant of TCR repertoire composition within patients, independent of disease or transplant status. The T cells recovered from peripheral blood and spleens in patients and mice captured a limited portion of the TCR repertoire detected in tissues. Whereas few T cell clones were shared across patients, motif-based clustering revealed shared repertoire signatures across patients in a tissue-specific fashion. T cells at disease sites had a tissue-resident phenotype and were of donor origin based on single-cell chimerism analysis. These data demonstrate the complex composition of T cell populations that persist in human tissues at the end stage of an inflammatory disorder after lymphocyte-directed therapy. These findings also underscore the importance of studying T cell in tissues rather than blood for tissue-based pathologies and suggest the tissue-specific nature of both the endogenous and posttransplant T cell landscape

Building the Games Students Want to Play: BiblioBouts Project Interim Report #3

The University of Michigan's School of Information and its partner, the Center for History and New Media at George Mason University, are undertaking the 3-year BiblioBouts Project (October 1, 2008 to September 30, 2011) to support the design, development, testing, and evaluation of the web-based BiblioBouts game to teach incoming undergraduate students information literacy skills and concepts. This third interim report describes the BiblioBouts Project team’s 6-month progress achieving the project's 4 objectives: designing, developing, deploying, and evaluating the BiblioBouts game and recommending best practices for future information literacy games. This latest 6-month period was marked by extensive progress in the deployment and evaluation of the alpha version of BiblioBouts. Major tasks that will occupy the team for the next 6 months are applying evaluation findings to game redesign and enhancement. For general information about game design, pedagogical goals, scoring, game play, project participants, and playing BiblioBouts in your course, consult the BiblioBouts Project web site.Institute of Museum and Library Serviceshttp://deepblue.lib.umich.edu/bitstream/2027.42/69157/1/bbInterimReportToIMLS03.pd

ICAR: endoscopic skull‐base surgery

n/

Rising rural body-mass index is the main driver of the global obesity epidemic in adults

Body-mass index (BMI) has increased steadily in most countries in parallel with a rise in the proportion of the population who live in cities(.)(1,2) This has led to a widely reported view that urbanization is one of the most important drivers of the global rise in obesity(3-6). Here we use 2,009 population-based studies, with measurements of height and weight in more than 112 million adults, to report national, regional and global trends in mean BMI segregated by place of residence (a rural or urban area) from 1985 to 2017. We show that, contrary to the dominant paradigm, more than 55% of the global rise in mean BMI from 1985 to 2017-and more than 80% in some low- and middle-income regions-was due to increases in BMI in rural areas. This large contribution stems from the fact that, with the exception of women in sub-Saharan Africa, BMI is increasing at the same rate or faster in rural areas than in cities in low- and middle-income regions. These trends have in turn resulted in a closing-and in some countries reversal-of the gap in BMI between urban and rural areas in low- and middle-income countries, especially for women. In high-income and industrialized countries, we noted a persistently higher rural BMI, especially for women. There is an urgent need for an integrated approach to rural nutrition that enhances financial and physical access to healthy foods, to avoid replacing the rural undernutrition disadvantage in poor countries with a more general malnutrition disadvantage that entails excessive consumption of low-quality calories.Peer reviewe

Height and body-mass index trajectories of school-aged children and adolescents from 1985 to 2019 in 200 countries and territories: a pooled analysis of 2181 population-based studies with 65 million participants

Summary Background Comparable global data on health and nutrition of school-aged children and adolescents are scarce. We aimed to estimate age trajectories and time trends in mean height and mean body-mass index (BMI), which measures weight gain beyond what is expected from height gain, for school-aged children and adolescents. Methods For this pooled analysis, we used a database of cardiometabolic risk factors collated by the Non-Communicable Disease Risk Factor Collaboration. We applied a Bayesian hierarchical model to estimate trends from 1985 to 2019 in mean height and mean BMI in 1-year age groups for ages 5–19 years. The model allowed for non-linear changes over time in mean height and mean BMI and for non-linear changes with age of children and adolescents, including periods of rapid growth during adolescence. Findings We pooled data from 2181 population-based studies, with measurements of height and weight in 65 million participants in 200 countries and territories. In 2019, we estimated a difference of 20 cm or higher in mean height of 19-year-old adolescents between countries with the tallest populations (the Netherlands, Montenegro, Estonia, and Bosnia and Herzegovina for boys; and the Netherlands, Montenegro, Denmark, and Iceland for girls) and those with the shortest populations (Timor-Leste, Laos, Solomon Islands, and Papua New Guinea for boys; and Guatemala, Bangladesh, Nepal, and Timor-Leste for girls). In the same year, the difference between the highest mean BMI (in Pacific island countries, Kuwait, Bahrain, The Bahamas, Chile, the USA, and New Zealand for both boys and girls and in South Africa for girls) and lowest mean BMI (in India, Bangladesh, Timor-Leste, Ethiopia, and Chad for boys and girls; and in Japan and Romania for girls) was approximately 9–10 kg/m2. In some countries, children aged 5 years started with healthier height or BMI than the global median and, in some cases, as healthy as the best performing countries, but they became progressively less healthy compared with their comparators as they grew older by not growing as tall (eg, boys in Austria and Barbados, and girls in Belgium and Puerto Rico) or gaining too much weight for their height (eg, girls and boys in Kuwait, Bahrain, Fiji, Jamaica, and Mexico; and girls in South Africa and New Zealand). In other countries, growing children overtook the height of their comparators (eg, Latvia, Czech Republic, Morocco, and Iran) or curbed their weight gain (eg, Italy, France, and Croatia) in late childhood and adolescence. When changes in both height and BMI were considered, girls in South Korea, Vietnam, Saudi Arabia, Turkey, and some central Asian countries (eg, Armenia and Azerbaijan), and boys in central and western Europe (eg, Portugal, Denmark, Poland, and Montenegro) had the healthiest changes in anthropometric status over the past 3·5 decades because, compared with children and adolescents in other countries, they had a much larger gain in height than they did in BMI. The unhealthiest changes—gaining too little height, too much weight for their height compared with children in other countries, or both—occurred in many countries in sub-Saharan Africa, New Zealand, and the USA for boys and girls; in Malaysia and some Pacific island nations for boys; and in Mexico for girls. Interpretation The height and BMI trajectories over age and time of school-aged children and adolescents are highly variable across countries, which indicates heterogeneous nutritional quality and lifelong health advantages and risks