However, the Court further explained the Court of Appeals had addressed this issue “on a number of occasions.” The Court then went on to cite various opinions in which the Court of Appeals indicated nominal damages were sufficient to support a claim for breach of fiduciary duty. In an opinion issued on March 12, 2021, the Court noted “the issue of whether a plaintiff is required to prove actual damages in support of breach of fiduciary duty and constructive fraud claims” was one of first impression for the Court. The defendant appealed to the North Carolina Supreme Court. The trial court then pointed to a long line of case law in which courts have held an award of nominal damages is sufficient to support an award of punitive damages. Because “nominal damages” are in fact “damages”, the defendant missed its chance to argue an award of nominal damages could not support a claim for breach of fiduciary duty. He did not specifically argue the claim required proof of “actual damages”. The trial court indicated it was “skeptical” that the defendant was correct, but ultimately held it did not have to decide this issue because the defendant had not properly preserved it at trial.ĭuring the trial, the defendant argued a claim for breach of fiduciary duty required proof of some “injury” or “damages”. Moreover, he could not be punished if there was no underlying claim to support such an award. In short, the defendant argued that if there was no harm, there was no foul. The defendant argued the award of punitive damages could not stand in light of the jury’s determination that the company had not suffered any actual damages. The defendant wondered the same thing and filed a post-trial motion asking the court to set aside the verdict. How could a jury find there were no damages, but award $1 in nominal damages and $250,000 in punitive damages? You would be justified in questioning this odd result. However, the jury then went on to award the company $250,000 in punitive damages! Yikes. In essence, the jury said, ‘we don’t think the company was damaged by the defendant’s breach, but we’ll throw it a dollar in recognition of the fact the defendant did something wrong.’ The jury then awarded the company $1.00 in “nominal damages.” This individual claim was dismissed early on by the trial court, but don’t forget it because it will be important later.Īs for the derivative claim, the jury decided the defendant did breach his fiduciary duty to the company, but the company had not been damaged by the breach. This included two separate claims for breach of fiduciary duty: (1) one claim asserted “derivatively” on behalf of one of the companies, and (2) a separate claim asserted directly by the plaintiff on his own behalf. Compagna, the plaintiff brought various claims against his business partners arising out of their alleged efforts to dilute his interest in various limited liability companies. The North Carolina Supreme Court and the North Carolina Business Court have recently indicated this is not a correct assessment. In other words, if a defendant breached a fiduciary duty, but there was no harm resulting from his conduct, there was no claim. For example, the North Carolina Pattern Jury Instruction for a breach of fiduciary duty indicates a plaintiff must prove that “ the defendant’s proximately caused damage to the plaintiff.” It has typically been understood that a claim for breach of fiduciary duty required a plaintiff to prove some harm resulting from the breach. Such claims seek redress when officers, directors, managers and others who control business operations abuse their power or neglect their responsibilities. Breach of Fiduciary Duty in North Carolina Apby Jeremy Sugg No Harm, No Foul: Are actual damages required to punish a breach of fiduciary duty in North Carolina?Ĭlaims for breach of fiduciary duty are common in business and commercial litigation.
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You may retry all the failed requests in a new batch after the longest retry-after value. You should retry each failed request from the batch using the value provided in the retry-after response header from the JSON content. Multiple requests can be throttled in a single batch. The batch itself succeeds with a status code of 200 (OK). Requests in a batch are evaluated individually against throttling limits and if any request exceeds the limits, it fails with a status code of 429 and an error similar to the preceding sample response. JSON batching allows you to optimize your application by combining multiple requests into a single JSON object. Continue to use the recommended Retry-After delay and retry the request until it succeeds.Īll the resources and APIs described in the Service-specific limits provide a Retry-After header except when noted.įor a broader discussion of throttling in the Microsoft Cloud, see Throttling pattern.īest practices for discovering files and detecting changes at scale describes best practices in details. If the request fails again with a 429 error code, you are still being throttled.Wait the number of seconds specified in the Retry-After header.Backing off requests using the Retry-After delay is the fastest way to recover from throttling because Microsoft Graph continues to log resource usage while a client is being throttled. The failed response includes the Retry-After response header. When you implement error handling, use the HTTP error code 429 to detect throttling.
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Then mix the fresh juice with syrup, tequila, and liqueur. Whether you are making a pitcher or a single drink, this recipe is simple and straightforward! Shake with ice and then serve in an ice filled glass. To make a blood orange margarita mix together orange juice, lime juice, and simple syrup with tequila and orange liqueur. There are many of them on the market and you can pick one up for a moderate price. Tip: For the best flavor use a 100% agave tequila. Alcohol – Orange liqueur (I like Grand Marnier) and tequila.Any syrup with a fairly mild flavor will do.) (FYI – I had a brown sugar syrup on hand so that is what I used. Simple Syrup – Just enough to make it sweet again.Blood oranges – It’s in the name! □ One orange will generally make 2 drinks.I have a few different drink recipes I’ve been working on (I’m thinking my Mai Tai should be next up!), but I had this beautiful fruit on hand so this one gets posted first. 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Now we will connect to the SQLite database using JAVA if exists otherwise it will create a new database and then connect to it.įollowing is the JAVA program which is used to connect a database if it exists otherwise first it will create a database and then connect to it. Now we need to add downloaded JDBC driver jar file ( sqlite-jdbc-version.jar) to our classpath like shown in our following programs. If JAVA setup available in our PC, now we will install SQLite-JDBC driver for that download latest JDBC driver sqlite-jdbc-version.jar from available list of JDBC drivers. In case if JAVA setup is not available means follow Java Tutorial for JAVA installation. on Windows, Linux, and Mac OS platform.īefore we proceed to interact with SQLite using JAVA language first we need to make sure that JAVA setup available in our PC. This JDBC driver is known as the SQLite-JDBC package which contains both JAVA classes and SQLite libraries to perform different operations like connect to the database, create tables, insert data in tables, etc. We can easily interact with SQLite in JAVA language using a JDBC driver. Here we will learn how to use SQLite in JAVA programming language to connect SQLite database, CREATE Table, INSERT, UPDATE, DELETE and SELECT operations on SQLite tables using JDBC driver with examples. But only A Hundred Drums, a Denver-based DJ with a tendency for deep frequencies and ancestral sounds, could properly introduce the Dead Rocks audience to the massive scope of what was in store for the three-day holiday. There are a hundred DJs and producers living in Denver putting on great shows every night of the week, and a hundred national acts stopping through our city on a monthly basis to blow our faces off. Regardless of which show you chose to attend, you got to witness something special - a carefully curated lineup dedicated to Denver’s thriving bass community.ĭenver is known as the “Bass Capital of the World” for good reason. Even though you probably need two weeks off of work and a few dozen IVs to recover, I’m sure it was worth it. You witnessed some of the best music the bass community has to offer. If you managed to keep the party going through all five of Zeds Dead’s unique sets, congratulations. Recently, they’ve also expanded the Dead Rocks experience to include a 4th of July Jamboree at Civic Center Park and a Dead Rocks Hangover show at Mission Ballroom. Every year DC and Hooks, the DJ duo known as one of the most iconic bass producers in the history of the genre, Zeds Dead, bring their eclectic range of electronic tunes to Red Rocks in celebration of our country’s independence day. He aspires to travel the world taking photos for non-profit organizations or to work for one of the top EDM photography teams like aLIVE Coverage.Zeds Dead knows how to throw a party, there’s no doubt about that. This pursuit and travels inspired Bearlosophy, his photographic journal of all his adventures. He has traveled from coast to coast and around the world looking what he calls The Bear Necessities of Life the simple things that make you smile, or you find visually moving. Since then he has attended every live music festival from Spirit of Suwannee’s, Purple Hatters Ball (Jam Bands), to Let It Roll Drum & Bass Festival in the Czech Republic.Ĭhris has an eclectic palate for music from Shpongle and Bassnectar to Oliver Heldens and Porter Robinson, he vibes with it all. In 2010 his friends showed him a video from Bonnaroo of Pretty Light’s “I Know the Truth” and he immediately dived on in. The weekends were filled with dance music from the 80’s and 90’s like La Bouche’s “Be My Lover” and Corona’s “Rhythm of the Night”. Website | Facebook | Twitter | Instagram | SoundCloud | YouTubeĬhristopher, or Brown Bear as his Festival Family and most of his friends call him, got his humble beginnings in the dance music scene when he was a child from none other than his mother. At work I just take time and all through my coffee break time. I run for the bus dear, but while ridin’ I think of us dear. It is surely going to be an event to check out so if you are in Colorado and want to immerse yourself in some good old fashioned dubstep, make sure to check them out July 2 and 3, 2018! Check out Zeds Dead – Coffee Break on SoundCloud: Most recently, Zeds Dead have announced that their very own event at Red Rocks, Deadrocks, has been expanded to two days. I remember hearing this song at The Hangout Festival when Zeds Dead performed and feeling every beat and drop in my body. The way they took such a timeless song as “I Say a Little Prayer” and managed to filter it through the most trembling basslines, creating something new and all their own, made this track the popular anthem it was. They combined their signature hip-hop and dubstep to create heavy basslines and drops with a sample from Aretha Franklin’s “I Say a Little Prayer”. The track comes from the two very talented Canadian producers, Dylan Mamid and Zachary Rapp-Rovan. “Coffee Break” was one of the major dubstep anthems during 2011. Six years ago in 2011, I went to my first ever Ultra Music Festival and got a taste of what was to become one of the largest gatherings of EDM in the world. I was just getting into the scene, first listening to the artists I mentioned above. The incredible drops that rattled speakers and bodies alike were something to behold and be a part of. Artists like Skrillex, Alvin Risk, and Zeds Dead were coming into the scene with a force and talent that the masses could not get enough of. Six years ago, the electronic music community was getting down to some of the most epic, filthy dubstep that has ever been heard. This Throwback Thursday, I would like to take it back to one of my favorite tracks with Zeds Dead’s “Coffee Break”. For this week’s Throwback Thursday, enjoy a “Coffee Break” from an era of filthy dubstep! Unable to set data to NULL in query results.Unable to show index fields in PostgreSQL 9.0.The fields of PostgreSQL compound index were displayed incorrectly.Display export profiles in the same group of queries.Integer column exported in Number format when exporting Excel file.Support Active Directory authentication method for SQL Server.To upgrade, please visit our Customer Center. 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The owners are lovely and they have great cocktails and diversity. “I always wanted a bar like what I imagined Cheers would be,” says Loretta Andro Chung, co-founder of Dyke Beer. The spontaneity is valuable, especially in a city with so many lesbians and queer folks, and so few steady options, especially not centered around cis gay men. It’s exciting to see the space form its own identity, take on a life of its own.” As opposed to a weekly party, The Bush offers a consistent space for people to drop in whenever they want to be surrounded by community space. “This is exactly what we wanted,” says Nikke Alleyne, who co-founded The Bush with longtime friend Justine LaViolette (they met at The Woods, of course). The Bush, a grassroots neighborhood opened in Bushwick in April 2023, regularly filling up since its very first night and attracting a stream of regulars to sip cocktails, dance and feel safe and seen. Mary’s, a sibling bar to Ginger’s, Park Slope’s only lesbian bar, opened a Greenpoint pub in April 2023. Since 2022, New York City has more than doubled its lesbian spaces, going from three mainstays-Cubbyhole, Henrietta Hudson and Ginger’s (all well-loved modernized relics from the 1990s)-to six, and counting! Oddly Enough, a lesbian-owned queer cocktail bar in Bed-Stuy offers pepperoncini martinis and brown butter deviled eggs in a chic chandelier-lit dining room. In a city with dozens of gay bars (gay men have clubs, lounges, cabarets, sports bars, karaoke bars, piano bars and dive bars), so few remain for lesbians, with none opening in the last 30 years. Beach Haven on Staten Island drew in women’s softball teams and professionals in the 1970s and 1980s 70 Grove Street wasn’t a pizza place but popular dance clubs Duchess, Grove and Pandora’s Box Crazy Nannies collected a diverse crowd in The Village from 1991-2004 Bum Bum Bar offered lesbian Latinas in Queens a place to dance from 1991-2018 and the list of long-gone space continues. Decades ago, New York City was home to a plethora of lesbian bars in every borough. |
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