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ao3feed-turn · 5 years ago

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Becoming Your Sacrifice

read it on the AO3 at https://ift.tt/2J2HS5H

by IWroteTheOther51

When Alexander Hamilton gets drafted for the Revolutionary war, he ends up getting a spot as a treasury secretary but on the midst of all of the war that's going on in america, he also ends up falling in love with one of his bestfriends and aide de camp, John Laurens, an american soldier whose married to another women but John never really loved his wife, his father Henry Laurens finds out that Alex is pregnant with John's child, so he pays someone to shut Alex up about the whole thing...and life just goes down hill from their, war is shit, everyone sucks, and no one plays games during these dark times. And lastly...you can't really trust anyone.

Words: 5, Chapters: 1/?, Language: English

Fandoms: Hamilton - Miranda, Turn (TV 2014)

Rating: Explicit

Warnings: Graphic Depictions Of Violence, Major Character Death, Rape/Non-Con, Underage

Categories: Other

Characters: Alexander Hamilton, John Laurens, Gilbert du Motier Marquis de Lafayette, Thomas Jefferson, Elizabeth "Eliza" Schuyler, Aaron Burr, Hercules Mulligan, George Washington, Angelica Schuyler, James Madison, Margaret "Peggy" Schuyler, Maria Reynolds, Philip Hamilton, Charles Lee, Theodosia Prevost Burr, Martha Washington, George III of the United Kingdom, Theodosia Burr Alston, Angelica Hamilton, John Adams, Frances Laurens, Henry Laurens (1723-1792), Dolley Madison, George Eacker, Philip Schuyler, Martha Laurens Ramsay, Alexander Hamilton Jr., Samuel Seabury (1729-1796), Theodosia Burr, John Church Hamilton, Rachel Faucette Buck, Philip Hamilton (1782-1801), John Barker Church, James Laurens (1765-1775), John Jay, James Hamilton Sr. (c.1718-1799), Henry Knox, James Reynolds (fl.1783-1792), William P. Van Ness, Hugh Mulligan Jr., Nathanael Greene, Nathaniel Pendelton, Philip Schuyler (1733-1804), Charles Lee (1732-1782), Thomas Conway (1735-c.1800), David Hosack (1769-1835), Richard Montgomery (1738-1775), Alexander Hamilton (Cat), Levi Weeks (1776-1819), Charles Lee (1758-1801), John Baker White (1794–1862), Charles Lee (1732-1782)'s Wife, Benjamin Tallmadge, Caleb Brewster, Anna Strong, Abraham Woodhull, Edmund Hewlett, John Graves Simcoe, John André, Benedict Arnold, Mary Woodhull, Tench Tilghman, Peggy Shippen, Abigail (Turn), Richard Woodhull, Selah Strong, Nathaniel Sackett, Robert Rogers, Robert Townsend (1753-1838), Samuel Tallmadge, Samuel Townsend, Martha "Patsy" Parke Custis, Ensign Baker, Nathan Hale (1755-1776), Nathaniel Tallmadge, Akinbode | Jordan, John Parke Custis, Cicero (Turn), Philomena Cheer, Elizabeth Gwillim Simcoe, James Rivington, William Bradford (Turn), John Robeson, Lola (Turn), Aberdeen (Turn), Henry Clinton (1730-1795), Lieutenant Gamble (Turn), 2nd Continental Light Dragoons, Samuel Graves (1713-1787), Mary Floyd Tallmadge, Captain Wakefield, Charles Scott, Freddy Morgan, Thomas "Sprout" Woodhull, Sarah Livingston (Turn), Queen's Rangers, Captain Joyce, William Howe 5th Viscount Howe, Austin Roe, Lucas Brewster, Reverend Worthington, Lucy Scudder, Lydia Ketcham, Rachel Clark, Dr. Mabbs, Corporal Eastin, Walter Havens, Awasos, Mary Graves (1772-1860), Richard Grosvenor 1st Earl Grosvenor (1731-1802), Thomas Lynch Jr, Sarah Townsend (1724-1800), Patience Wright, Thomas Woodhull Sr, Francis Marion (c.1732-1795), Edmund Hewlett's Mother, Becky Redman, Hannah Ketcham, Elizabeth Lloyd Loring (1744-1831), Bridget Graves (1750-1795), Captain Jim Ryder, Lieutenant Chaffe (Turn), Rachel Peale, Colonel Jonathan Cooke, William "Billy" Lee (Turn), Peyton Randolph (1721–1775), John Randolph (1727–1784), Keturah Strong Woodhull, Sarah "Sally" Townsend (1760-1842), William André (1760-1802), Mopsey (Dog)

Relationships: Alexander Hamilton/John Laurens, Alexander Hamilton/Elizabeth "Eliza" Schuyler, Alexander Hamilton/Thomas Jefferson, Thomas Jefferson/James Madison, Aaron Burr/Alexander Hamilton, Gilbert du Motier Marquis de Lafayette/Hercules Mulligan, Maria Reynolds/Elizabeth "Eliza" Schuyler, Alexander Hamilton/George Washington, Aaron Burr/Theodosia Prevost Burr, George Washington/Martha Washington, Alexander Hamilton/John Laurens/Gilbert du Motier Marquis de Lafayette/Hercules Mulligan, Alexander Hamilton/Gilbert du Motier Marquis de Lafayette, Alexander Hamilton/John Laurens/Elizabeth "Eliza" Schuyler, John Laurens/Gilbert du Motier Marquis de Lafayette, Theodosia Burr Alston/Philip Hamilton, Alexander Hamilton/John Laurens/Gilbert du Motier Marquis de Lafayette, Alexander Hamilton/Angelica Schuyler, Gilbert du Motier Marquis de Lafayette/George Washington, Alexander Hamilton/Maria Reynolds, Benjamin Tallmadge/George Washington, Thomas Jefferson/Angelica Schuyler, Adrienne de Lafayette/Gilbert du Motier Marquis de Lafayette, George III of the United Kingdom/Samuel Seabury, Aaron Burr & George Washington, Martha Manning/Margaret "Peggy" Schuyler, Gilbert du Motier Marquis de Lafayette/Hercules Mulligan/George Washington, James Madison & Elizabeth "Eliza" Schuyler, John Adams & Richard Henry Lee, Adrienne de Lafayette/Gilbert du Motier Marquis de Lafayette/Angelica Schuyler, George Eacker/Philip Hamilton (1782-1801), Thomas Jefferson/John Laurens, Aaron Burr/John Laurens, Philip Hamilton/Lucy Jefferson Lewis, Dolley Madison & James Madison, John Laurens/Original Male Character(s), Alexander Hamilton/John Laurens/Angelica Schuyler/Elizabeth "Eliza" Schuyler, Caleb Brewster & John Laurens, Jonathan Bellamy (d.1777)/John Laurens, Nathan Hale (1755-1776)/Benjamin Tallmadge/George Washington, Jane Jefferson/George Washington, Aaron Burr/George Washington, Theodosia Prevost Burr/Angelica Schuyler, Thomas Jefferson/Gilbert du Motier Marquis de Lafayette, John Barker Church/Angelica Schuyler, Alexander Hamilton & Hercules Mulligan, Charles Lee/Gilbert du Motier Marquis de Lafayette, Theodosia Prevost Burr/Jacques Marcus Prevost, Hercules Mulligan/Elizabeth Sanders Mulligan, Abigail Adams/John Adams, Alexander Hamilton & Gouverneur Morris (1752-1816), Jonathan Bellamy (d.1777) & Aaron Burr, John Adams/John Hancock/Charles Thomson, Caleb Brewster/Margaret "Peggy" Schuyler, Robert Townsend/Abraham Woodhull, John André/Alexander Hamilton, John Graves Simcoe/Anna Strong, Edmund Hewlett & Anna Strong, Edmund Hewlett/John Graves Simcoe, Nathan Hale (1755-1776)/Benjamin Tallmadge, Robert Townsend & Mary Woodhull, Benedict Arnold/Benjamin Tallmadge, Anna Strong/Abraham Woodhull, Caleb Brewster & Anna Strong, Anna Strong/Selah Strong, Edmund Hewlett/Original Female Character(s), Edmund Hewlett/Richard Woodhull, John Graves Simcoe/Lola (Turn), Aaron Burr/Angelica Schuyler, Dolley Madison/Margaret "Peggy" Schuyler, John Laurens/James Madison, Aaron Burr/Alexander Hamilton/John Laurens

Additional Tags: American Revolution, Mpreg, Gay Founding Fathers (Hamilton), Explicit Sexual Content, Fluff, Angst, Family Issues, Dysfunctional Family, Politics, Canon-Typical Violence, Mental Health Issues, Unplanned Pregnancy, Pregnancy Scares, Forced Pregnancy, Secrets, Developing Relationship, Relationship(s), Slave Trade, Shameless Smut, BDSM, LGBTQ Themes, Porn, Jealousy, Kinks, Bromance to Romance, War, Humiliation, Praise Kink, Soulmates, Boys Kissing, French Kissing, Neck Kissing, Drunken Confessions, Marriage Contracts, Hand & Finger Kink, Finger Sucking, Breast Fucking, Cock Tease, Orgasm Delay/Denial, Multiple Orgasms, Crossdressing, Angst with a Happy Ending, Falling In Love, Love Confessions, Boys In Love, Idiots in Love, Friendship/Love, Slow Build, Slow Romance, Not Suitable/Safe For Work, Possessive Behavior, Thomas Jefferson Being an Asshole, Bisexual Alexander Hamilton, Human Disaster Aaron Burr, Poor Aaron Burr, Aaron Burr is So Done, Angst and Tragedy, Male Slash, Implied/Referenced Homophobia, Homophobic Henry Laurens, Homophobic Language, Hamilton References, Hurt Alexander Hamilton, Henry Laurens' A+ Parenting, Illnesses, HIV/AIDS, First Kiss, Gender Identity, Fist Fights, Fights, George Washington is a Dad, Some Humor, Dark Past, Emotional Hurt/Comfort, Gang Rape, Semi-Public Sex, Blow Jobs, First Time Blow Jobs, Anal Sex, Oral Sex, Rough Oral Sex, Post Mpreg, Penises, Painplay, Painful Sex, Lesbian Sex, Body Worship, Sharing Body Heat, Sharing a Bed, Sad with a Happy Ending, Minor Original Character(s), Secret Children, Substance Abuse, Suicide Attempt, Suicide Notes, Domestic Violence, Confessional Sex, Protectiveness, Historical Inaccuracy, Historical References

read it on the AO3 at https://ift.tt/2J2HS5H

#fanfic #turn: washingtons spies #turn amc #IFTTT #ao3feed

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ao3feed-whamilton · 5 years ago

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Becoming Your Sacrifice

read it on the AO3 at https://ift.tt/2J2HS5H

by IWroteTheOther51

Words: 5, Chapters: 1/?, Language: English

Fandoms: Hamilton - Miranda, Turn (TV 2014)

Rating: Explicit

Warnings: Graphic Depictions Of Violence, Major Character Death, Rape/Non-Con, Underage

Categories: Other

read it on the AO3 at https://ift.tt/2J2HS5H

#ao3feed #fanfic #whamilton #hamilton #alexander hamilton #george washington

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evoldir · 4 years ago

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Fwd: Graduate position: UBradford.HumanMicrobiome

Begin forwarded message: > From: [email protected] > Subject: Graduate position: UBradford.HumanMicrobiome > Date: 17 February 2021 at 08:26:08 GMT > To: [email protected] > > > *Adaptation and community dynamics of the human oral microbiome over > centuries of evolution* > > A funded PhD studentship is available at the University of Bradford, > UK, with Dr Conor Meehan and Dr Andrew Tedder, in collaboration with Dr > Camila Speller at UBC. > > > The human microbiome is composed of two categories of microbes: commensals > (beneficial to the host) and pathogens (detrimental to host health). While > we know quite a lot about modern microbiomes in terms of what bacteria > live there, how they enter the body and how the specific body site select > for certain bacteria, little is known about the historical evolution > of the human microbiome. How have commensals and pathogens interacted > over the past thousand years in and on our bodies? What bacteria rely > on what other bacteria for survival and has this changed over time? > > > Understanding three core aspects of the human microbiome (evolution, > adaptation and interconnectedness) would better allow us to examine the > effect of diet and human health on our resident microbes and in turn > understand how shaping the microbial community in our bodies could better > benefit our health. > > This project aims to address these questions, focussing on the human oral > cavity microbiome. Using dental calculus microbiome whole genome data > collected over 5000 years from Yorkshire archaeological skeletons, we will > reconstruct the evolution of the human oral microbiome in Northern England > and examine the influence of diet, antibiotic exposure and urbanisation > on this community. Next, by combining this dataset with modern global > samples, we can extensively explore the human oral microbiome community > ecology, including genetic exchange and metabolic handovers. This will > allow us to investigate whether modern microbiomes interact and respond > to change better than historical counterparts. > > > This type of historical and wide-ranging investigation of the community > dynamics of the oral microbiome has never been performed and will > extensively advance our understanding of this crucial aspect of human > health with high relevance to the local Bradford community. We are looking > for an enthusiastic PhD candidate, preferably with a background in some > (but not necessarily all) of the following topics: bioinformatics, > molecular evolution, microbial ecology, phylogenetics > > The application deadline is Friday 26th > March 2021. Formal applications must be submitted here: > https://ift.tt/3bffLxO > Informal enquires can be sent via email to either [email protected] > or [email protected] > > > > Andrew Tedder > via IFTTT

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freeminimaps · 4 years ago

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RiverEdge Dental - Bradford

We are a modern, family-friendly dental practice in Bradford that strives to enhance your oral health and give you a lasting healthy smile. We work with patients of all ages including very young children as well as the elderly. If there are any aspects of your oral health that you would like to improve, the knowledgeable dental team at RiverEdge Dental will work with you to exceed your needs and expectations. Our dentists and dental specialists will provide you with a comprehensive list of treatment options so that you can be in full control of your dental care and get a beautiful, healthy smile. See you soon! Call us at – 905-775-0075

RiverEdge Dental – Bradford was originally published on Business directory and remarkable travel blog!

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ao3feed-lams · 5 years ago

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Becoming Your Sacrifice

read it on AO3 at https://ift.tt/2J2HS5H

by IWroteTheOther51

Words: 7, Chapters: 1/?, Language: English

Fandoms: Hamilton - Miranda, Turn (TV 2014)

Rating: Explicit

Warnings: Graphic Depictions Of Violence, Major Character Death, Rape/Non-Con, Underage

Categories: Other

read it on AO3 at https://ift.tt/2J2HS5H

#IFTTT #ao3feed #fanfic #Hamilton #lams

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eccleshill2 · 17 days ago

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#eccleshill dental #best orthodontist in Bradford #orthodontist Bradford UK #emergency orthodontist Bradford #schedule orthodontist appointment Bradford #orthodontist for gap teeth Bradford #correcting teeth with braces Bradford

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ao3feed-tmnt2k12 · 5 years ago

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Apprehension

read it on the AO3 at https://ift.tt/2C6cdfT

by PrincessGemma12

Deception, manipulation, love, lust, anger, fear, joy... this turtle wasn't one of their own, they weren't... weren't like THIS. Leonardo and his family were kind, they were caring, they were... they were... so ridiculously horny. A little goofing off wouldn't hurt, right? Right? It didn't matter that he was in the Foot, right? Right!?!?

Or: Raph's in the Foot, raised by Shredder, and Leo doesn't know what the hell he wants. (I suck at summaries, I think this is better than it probably sounds XD.)

Words: 2128, Chapters: 1/?, Language: English

Series: Part 1 of The Third Brother of Deimos and Phobos

Fandoms: Teenage Mutant Ninja Turtles (TV 2012), Teenage Mutant Ninja Turtles - All Media Types

Rating: Explicit

Warnings: Graphic Depictions Of Violence, No Archive Warnings Apply, Rape/Non-Con, Underage

Categories: F/M, M/M, Multi, Other

Characters: Leonardo (TMNT), Raphael (TMNT), Donatello (TMNT), Michelangelo (TMNT), Splinter (TMNT), Hamato Yoshi | Splinter, Shredder (TMNT), Oroku Saki | Shredder, April O'Neil (TMNT), Casey Jones (TMNT), Chris Bradford, Xever | Fishface, The Kraang (TMNT), The Foot Clan (TMNT), Ice Cream Kitty (TMNT), Leatherhead (TMNT), Karai (TMNT), Miwa, Original Characters, Tiger Claw (TMNT), Foot Bots (TMNT)

Relationships: Leonardo/Raphael (TMNT), Donatello/Leonardo (TMNT), Karai/Leonardo (TMNT), Karai/Raphael (TMNT), Donatello (TMNT)/April O'Neil, April O'Neil/Raphael (TMNT), Casey Jones/Raphael (TMNT), Casey Jones/Leonardo (TMNT), Splinter/Tang Shen, Minor or Background Relationship(s), Karai & April O'Neil (TMNT), Michelangelo & Raphael (TMNT), Leonardo & Michelangelo (TMNT), Leonardo & Splinter (TMNT), Leonardo & April O'Neil (TMNT), Donatello & Leonardo (TMNT), Raphael (TMNT)/Original Male Character(s), Casey Jones/Karai (TMNT)

Additional Tags: Eventual Smut, Eventual Romance, Eventual Relationships, Eventual Fluff, Eventual Happy Ending, Maybe - Freeform, Top Raphael, Bottom Leonardo, Topping from the Bottom, Vaginal Fingering, Vaginal Sex, Anal Sex, Anal Fingering, Sex Toys, Improvised Sex Toys, Implied/Referenced Child Abuse, Implied/Referenced Self-Harm, Implied/Referenced Torture, Implied/Referenced Drug Use, Implied/Referenced Homophobia, Implied/Referenced Abuse, Implied/Referenced Incest, Underage Drinking, Underage Sex, Consensual Underage Sex, Underage Smoking, Underage Drug Use, Extremely Underage, minor smutty stuff when the kid's are 15 but nothing extreme until AFTER the farmhouse, several arc story, Cigars, Dark Comedy, Dark Fantasy, Foot Raphael (TMNT), The Author Regrets Nothing, What Have I Done, Masturbation, Mutual Masturbation, Frottage, Intersex, Intersex Leonardo, Post-Episode: s02e03 Follow the Leader, So many tags, too many tags, Minor A/B/O, Blood and Violence, Blood Kink, Mild Painplay, Mild Kink, Jealous Raphael, Raphael is a Little Shit, Older Sibling Leonardo (TMNT), Protective Donatello (TMNT), Hurt Donatello (TMNT), Michelangelo is Tired of People's Shit, Leo Is Confused, Everyone Has Issues, Mental Health Issues, Mental Instability, Self-Harm, Self-Esteem Issues, Self-Lubrication, Erotic Games, Asphyxiation, Oral Sex, Good Parent Splinter (TMNT), he's stressed af, I think I got everything, I Don't Even Know, Not Beta'd, Not Actually Unrequited Love

read it on the AO3 at https://ift.tt/2C6cdfT

#IFTTT #ao3feed #fanfic #tmnt #tmnt 2012 #teenage mutant ninja turtles

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57dentalcare · 2 years ago

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Dentist in Bradford

Looking for a top-notch dentist in Bradford? Look no further! Our dental clinic is here to cater to all your oral health needs. Whether you need a routine check-up, teeth cleaning, or advanced dental treatments, our experienced and friendly team is ready to provide exceptional care. We use state-of-the-art technology to ensure your comfort and satisfaction. Achieve a dazzling smile and maintain excellent dental health with us. Book your appointment today!

Visit Us: https://57-dental.com/

#Dentist in Bradford

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valoansdallastx · 6 years ago

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Game of Thrones Live Concert Experience coming to Virginia Beach

Contents

Type 094) ballistic

Earnings conference call

Bradford rotary honor

Secretary robert wilkie

20-city amphitheater tour

There’s a lot of event space in the venue that we can sell for private and corporate events and social events." In addition to a full-service restaurant and bar, there will also be space for live.

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Learn tricks of the trade from top beauty experts, watch live styling sessions. by a fun and family-friendly programme of events. www.savourkilkenny.com 56 How it Is: Part 2, Sept 3-7, Everyman:.

The Game of Thrones Live Concert Experience is coming to Jiffy Lube Live on Sunday, Sept. 15. Check out InsideNoVaTix to get tickets to some top events in Northern Virginia. Search for more local.

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The "Game of Thrones Live Concert Experience" will come to Veterans United Home Loans Amphitheater with tickets costing up to $340.

The Game of Thrones Live Concert Experience fell nothing short of my expectations. It was a great show. The only problem was the venue. I believe this show should have been held at the Sony Centre or the Scotiabank arena as the Budweiser Stage was definitely not an appropriate venue for this type of event since it is outside.

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Experience the Excitement, Terror, Heartbreak, and History of Emmy® Award-Winning Game of Thrones Composer Ramin Djawadi’s Music In A Stunning Outdoor Concert Experience . The critically acclaimed Game of Thrones Live Concert Experience will return this fall for a 20-city amphitheater tour, bringing the music of Emmy® Award-winning Game of.

Find tickets for Game of Thrones Live Concert Experience in Virginia Beach, Virginia at Veterans United Home Loans Amphitheater on Tuesday, September 17, 2019. Veterans United Home Loans Amphitheater is located at 3550 Cellar Door Way in Virginia Beach, VA

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The Game of Thrones Live Concert Experience is coming to the Xfinity Center in Mansfield on Sept. 10 as part of a 20-city amphitheater tour. fans will get a chance to relive the greatest musical. “Game of Thrones” fans who are dreading the end of their beloved HBO series will get one final chance to celebrate their favorite fantasy when the “Game of Thrones Live Concert Experience. the.

The post Game of Thrones Live Concert Experience coming to Virginia Beach appeared first on VA Loans Dallas TX.

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rodger967044-blog · 7 years ago

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Sexuality Articles.

A lot of guys possess a quite unsatisfactory understanding from women sexuality. What compatibility, besides her grow older as well as her convenience, encompassed her, he performed not know, yet even within this fantastic activity there was an one thing neither out of time neither location: a something which this seemed to be as if no one else could have made as serious, or done with such a touching and natural sky. Today he proudly wears this. And also likes his bosom. Explore his collection of manuals on sexuality to find out present day sexual techniques as well as help managing significant sex-related problems in males and females. Various other initiatives feature the village-based birth control laborers as well as extended immunisation plans, nutritional as well as kid survival, cancer cells treatment, and raised engagement of media in health learning. The faces of people visualized in this particular account were pixelated at the request of Wang Lunyan, the mama of overlooking Chinese girl He Yuting. Besides the stereotypes and also generalizations regarding women as well as youngsters, culture is pounded with pictures of sexual activity and also violence everyday. This is actually a time for reflecting on those girls that have actually meant improvement to make a much better everyday life for all, and also who our experts remember in our souls as brave and also strong. ( HealthDay)-- When that relates to attaining climaxes during sexual activity along with a routine partner, direct women still hang back males and homosexual ladies, a brand-new study recommends.

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bradfordzone · 7 years ago

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Children’s Oral Health Part of the debate - in Westminster Hall - 31 October 2017 Judith Cummins Labour, Bradford South 10:07am

#children&039;s oral health

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stogutrosenberry · 7 years ago

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“A gift to the construction industry”: catchy quotes from Court of Appeals argument on OSHA’s silica standard

OSHA took the long road to adopt a standard to address respirable crystalline silica. Although the final rule was issued in March 2016, it is being challenged by both industry and labor groups. The first says OSHA went too far, the other says OSHA didn’t go far enough.

The long road, however may be coming close to end. The U.S. Court of Appeals for the District of Columbia Circuit heard oral arguments last week from parties that are challenging the rule. Judges Merrick Garland, David Tatel and Karen LeCraft Henderson spent more than two hours listening to arguments from the National Stone, Sand and Gravel Association (NSSGA), the Brick Industry Association (BIA), the U.S Chamber of Commerce, the North America Building Trades, the United Steelworkers and others. Attorneys with the Department of Labor’s Office of the Solicitor were there, too, to defend the OSHA rule.

I enjoyed listening (and relistening) to the court’s audio of the oral argument. What made it particularly enjoyable was listening to the judges—they did their homework!

Judges Garland and Tatel, in particular, probed, cajoled, and challenged the attorneys to clarify their arguments. The judges pressed the attorneys on issues concerning economic feasibility, health risks, and the legal standard for substantial evidence. There were plenty of references to prior litigation on OSHA health standards. They mentioned significant previous court decision on OSHA standards, such as for asbestos, lead and formaldehyde. I felt a bit like an outsider, listening to the attorneys speak about those rulings. They described them as if they were old friends who remain relevant today. And like relationships with old friends, we don’t always agree about what she said or remember events in the same way.

There were times during the oral arguments that the presenting attorney rose to a judge’s challenge for a cogent response. But I cringe a few times when I heard nervous laughter from an industry attorney who knew he was stumped by the judge’s question.

Below are just some of my favorite quotes and exchanges. The text doesn’t capture the animation I heard in the audio from the courtroom or the commitment of the attorneys to their arguments. I’ve included a time stamp at each quote so you can listen for yourself. (I had difficulty distinguishing Judge Garland’s from Judge Tatel’s voice. If I incorrectly attribute the quotes, please leave a comment and I’ll correct it.)

NSSGA and BIA argue that OSHA overstates the risk of health harm caused by exposure to respirable crystalline silica. Their attorney, William L. Wehrum, said:

“We assert that OSHA had a thumb on the scale. We believe the record makes clear that OSHA came to this rulemaking with a determined goal of reducing the level of the standard. We believe it clouded OSHA’s judgement and caused it to lose objectivity, which we believe permeates the entire proceeding.” [00:02:36]

Judge Tatel chimed in:

“You say that OSHA had its thumb on the scale, which is a curious statement given our standard of review. The question is: is there significant evidence in the record to support OSHA’s position for what it did? You can certainly point to contrary evidence, but OSHA has explained all that. …You have to make your argument in terms of our specific standard of review, which is the substantial evidence question. Our case law is very specific about that.”

Sounding like a law professor Tatel added:

“What’s your best argument regarding the substantial evidence test?” [00:04:19]

Wehrum had difficulty providing a short and sweet and precise answer.

Judge Garland addressed the problem for the court of dueling scientists. William Wehrum tried to describe the evidence from his side’s experts, but Garland interrupted:

“We have scientists on both sides and the law here is quite clear. When there are scientists on both sides, OSHA is permitted to take the ones that are most likely to protect worker safety. There is supposed to be a thumb on the scale in terms of safety. …That’s what our own case says. It is perfectly appropriate for OSHA to weight in favor of worker safety. That’s right, isn’t it. [00:09:56]

William Wehrum: “Correct your honor to a point, but that dosen’t insulate OSHA from review.

Soundly a bit frustrated, Garland said:

“That’s what we doing here, but it is not enough to say there is a plausible mechanism. You have to be able to show that OSHA’s studies are not themselves substantial evidence.”

The attorney representing the U.S. Chamber of Commerce was also schooled by Judge Garland. This time it was a math problem.

Attorney Michael Connolly argued that there are so few deaths today is the U.S. from silicosis that OSHA has not met its burden of demonstrating that exposure to respirable silica poses a significant risk of harm to workers. Connolly pointed to the low number of silicosis deaths reported on death certificates and compared to the millions of workers in silica-related industries.

Judge Garland asked [00:18:50]:

“Is that the right division? Dividing the total number of deaths that are reported on the death certificates by the total number of workers in industry? Or is the right number the total number of deaths at a certain level of exposure? That is, in terms of the 1 in 1,000 test.

(The “1 in 1,000” comes from a 1980 Supreme Court ruling about OSHA’s benzene standard. The Supreme Court justices did not offer a specific ratio but indicated that the threshold likely fell somewhere between 1 death per 1 billion (which would not be considered significant) to 1 death per 1,000 (which would be significant.))

Judge Garland continued:

“It’s not supposed to be just 1 over the entire population of the United States, or 1 over everybody who works. It’s supposed to be 1 over 1,000 people who work at a certain exposure level, isn’t that right?”

Michael Connolly: “Sure. That’s correct.”

Judge Garland:

“Isn’t it exposed to silica at a certain exposure levels that matters? Not all people who may have been exposed to silica? [20:03]

Score one for the judge.

I wish I’d been in the courtroom for that exchange. I would have turned my head to see if Judge Garland’s remark brought a smile to the attorneys who were defending OSHA’s rule.

Labor Department attorney Kristen Lindberg was charged with responding to some of the arguments raised by the industry petitioners. Among her excellent synopsis was this:

[00:35:00] “It’s worthwhile to step back a little bit and review the support OSHA had in the record for its findings. Their risk assessment findings were supported by nearly all of the occupational health and medical organizations that commented on the rule, including NIOSH, the American Cancer Society, the American College of Occupational and Environmental Medicine, the American Thoracic Society, the Association of Occupational and Environmental Clinics, and the American Public Health Association.”

“… Industry petitioners want you to reject conclusions that have overwhelming support among scientists and that were supported by the independent peer reviewers who scrutinized OSHA’s risk assessment. They want you to reject this extensive body of scientific evidence on the flimsy basis that there are flaws in some of the studies that OSHA relied upon and that there is uncertainty in epidemiology. They want you to impose a legal burden on OSHA that the agency could never meet.”

[00:36:53] “The broad support for OSHA’s conclusions within the scientific community should increase the court’s confidence that OSHA’s analysis is sound. The courts understand that OSHA, in marshalling scientific evidence to support a risk assessment, cannot ever reach perfection because the science those risk assessments are based on is not perfect. There will be flaws in studies, there will be stronger and weaker studies, there may be some uncertainty, but what OSHA has done here, its extensive analysis based on a huge body of evidence conforms fully with the OSH Act and with the requirements of courts that have interpreted the OSH Act.”

Bradford Hammock argued the case on behalf of the National Association of Home Builders and other industry groups. He tried to convince the judges that OSHA’s requirements for the construction industry are not technological feasible.

Victoria Bor, the counsel for North America’s Building Trades Unions dismissed Mr. Hammock’s assertions. Her argument began with the following [00:67:40]

“By way of context, Table 1, which is the centerpiece of the construction standard, is a gift to the construction industry. Most OSHA standards set a permissible exposure limit and require employers to monitor their workplaces and devise their own strategies following the hierarchy of controls to bring exposures below the permissible exposure limit (PEL). The silica standard gives employers options. They can follow the traditional approach or they can follow Table 1, which is in effect is a manual that lists 19 of the 23 construction tasks that most commonly generate significant silica exposure, and specifies control strategies for each. Employers who fully and properly implement the controls listed on Table 1 are freed from monitoring their workplace and have a safe harbor for complying with the PEL.

“…OSHA assumes that most employers will follow table, which is a completely reason assumption because it tells employers exactly what they have to do, frees them from monitoring, and gives them a safe harbor for complying with the PEL.”

“Now rather than accepting this gift, as Mr. Hammock already explained to you, the industry petitioners point to Table 1 and argue that to the extent it requires the use of respirators….OSHA is conceding that the standard isn’t feasible. …The petitioners’ argument completely ignores that Table 1 does not require employers to comply with the PEL. What it requires is for employers to implement the listed controls. So whether the PEL can be reached without the use of respirators—the question that the industry petitioners focus on— is actually completely irrelevant.”

Victoria Bor continued:

“What is relevant, as Ms. Goodman [of the Labor Department] said, is that the typical employer can comply with Table 1 most of the time. On this question, the petitioners argument on feasibility rests on vague assertions that in certain circumstances, certain employers may not be able to use certain of the wet methods listed in Table 1 at some time. …Petitioners point to no evidence that undermines OSHA’s conclusions that most employers will be able to comply with Table 1 by utilizing those controls most of the time.”

There was dead silence after her rebuttal. None of the judges asked Victoria Bor to clarify or further defend her arguments. They seemed convinced.

The excerpts above are just some of memorable moments from the oral argument. Another was a lengthy argument by the unions and rebuttal by the Labor Department about OSHA’s provisions for medical surveillance and medical removal protections. It was the one time that the Labor Department’s case seemed on shaky ground.

If you listen to the audio for yourself you’ll hear the word “grapple” used numerous times by attorneys for the unions. You’ll hear the Labor Department attorneys repeat the phrase”de minimis benefit.” You’ll hear one judge say to an industry attorney “it’s not your principle argument, it’s your only argument” and another judge mention “a shopping list.” You’ll hear all the parties claim that OSHA’s decisions are, or are not, “supported by the record.” Finally you’ll hear many references to previous Supreme Court and Appeals Court decisions on other OSHA standards.

It’s been many years since OSHA started down the road toward a comprehensive silica standard. People will disagree on when the agency actually hit the road, but they know that last week’s stop at the U.S. Court of Appeals means the road may soon be coming to an end.

Judges Garland, Henderson, and Tatel are now at the wheel. They will decide whether OSHA’s rule will stand as is, or whether the agency needs to make a U-turn.

I relished listening to the oral arguments. I’ll be eager to read the judge’s opinion when it’s issued.

Article source:Science Blogs

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evoldir · 4 years ago

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Fwd: Graduate position: UBradford.HumanMicrobiome

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