Pleading

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3 LOHR RIPAMONTI & SEGARICH LLP 1 Roberto G. Ripamonti (SBN 259123) Alec Segarich (SBN 260189) 2 , 4F 140 Geary Street San Francisco, CA 94108 3 -0448 Telephone: (415) 294 -3275 Facsimile: (415) 354 4 Email: [email protected] .com Email: [email protected] 5 Attorneys for Plaintiff and the putative class 6 7 SUPERIOR COURT OF CALIFORNIA, COUNTY OF FRESNO 8 UNLIMITED CIVIL DIVISION 9 10 for herself ANDREA HERINGTON CASE NO.: , 11 individually and on behalf of all others COMPLAINT CLASS ACTION similarly situated 12 Plaintiff, 13 BREACH OF CONTRACT vs. 14 BOARD OF TRUSTEES OF CALIFORNIA 15 , operating as STATE UNIVERSITY CALIFORNIA STATE UNIVERSITY, 16 -50 , and D OES 1 , FRESNO 17 Defendants. 18 19 20 21 22 23 24 25 26 27 28 - 1 - HERINGTON V. BOARD OF TRUSTEES OF CAL. STATE UNIVERSITY

4 1 CLASS ACTION COMPLAINT 1. ”), individually and on 2 (“Ms. Herington Plaintiff ANDREA HERINGTON behalf of other students and former students similarly situated, brings this class action 3 ts BOARD OF TRUSTEES OF CALIFORNIA STATE 4 complaint against Defendan -50, for breach UNIVERSITY (operating as California State University, Fresno), and DOES 1 5 failed to provide to of contract. California State University, Fresno (hereafter “Fresno State”) 6 the tuition members the services and accredited training programs it advertised as -paying class 7 8 its Psychiatric Mental Health Nurse Practitioner (“PMHNP”) program , despite receiving their tuition. Ms. Herington therefore seeks to obtain redress for all persons injured as a result 9 of 10 their failure to provide the promised accredited training . In brief , Fresno State operates the PMHNP program out of its School of 2. 11 . The program i s a one -master’s program designed to “prepare primary care 12 Nursing -year post a full range of psychiatric services to patients throughout 13 nurse practitioners to provide the life 14 d the program as a “formally constructed program that meets the ” Fresno State advertise cycle. lt requirements for national certification by the American Nurse Credentialing Center as an Adu 15 Psychiatric and Mental Health or Family Psychiatric and Mental Health Nurse Practitioner.” 16 Further, Fresno State’s published materials and orientation seminars all touted the fact that the 17 program meets the requirements for national certification by the 18 American Nurse Credentialing standardized Center (ANCC). Based on these representations, Fresno State entered into 19 20 contracts with dozens of nursing students hoping to receive thei r c ertificate of completion from lly certified psychiatric nurse pr actitioners. , nationa 21 E ach the program and become accredited student paid Defendant tuition in excess of several thousand dollars. The terms of the 22 standardized 23 contract established the price students were required to pay for their classes, and ure and quality of the classes and the academic credits they would receive by established the nat 24 enrolling 25 . In fact, Fresno State’s PMHNP program is not only currently unaccredited, but 3. 26 it has never had accreditation from the Commission on Collegiate Nursing Education (CCNE), 27 and graduates cannot become certified by the ANCC. Despite taking thousands of dollars of 28 - - 2 HERINGTON V. BOARD OF TRUSTEES OF CAL. STATE UNIVERSITY

5 tuition from each of 1 its students and promising them an accredited training program which they could use to get national certification, Fresno State instead provided a substandard curriculum 2 equired take r which was not accredited, the graduates of which were not even legally able to 3 . Eve certification exams the accreditation n worse, as the ANCC seemingly failed to confirm 4 status of Fresno State as it has administered the certification exams for the past four years, 5 students of the program who successful ly pass e had their results nullified the boards hav ed 6 after the fact Fresno State’s lack of accreditation , once the ANCC became aware of . 7 8 Shockingly, Fresno State continued to recruit more students into its program even after it knew . It also m 9 ade oral statements through its professors to current about its lack of accreditation students that the issue would be resolved and that “accreditation was not needed for their 10 By failing to provide courses that were properly accredited by the CCNE, program.” 11 12 s with the students of its Defendant breached its contract PMHNP program. class action complaint, alleges the following upon 4. 13 Ms. Herrington , in this personal knowledge as to herself and he as to all other matters, 14 r own acts and experiences, and stigation conducted by her attorneys. 15 upon information and belief, including inve 16 PARTIES 5. 17 is a natural person and a citizen of the State of Plaintiff Andrea Herrington California. ractitioner amily nurse p , and a former student of the 18 d f She is a registered nurse an Fresno State PMHNP program. 19 is the State of 6. 20 Defendant Board of Trustees of the California State University 21 California acting in its higher education capacity. California State University, Fresno is one of several universities that is governed by the Board of Trustees of the Californi a State 22 University. 23 24 7. The true names and capacities, whether individual, corporate, associate, 25 representative, alter ego or otherwise, of defendants and/or their alter egos named herein as at this time, and are DOES 1 through 50 inclusive are presently unknown to Ms. Herington 26 27 therefore sued by such fictitious names pursuant to California Code of Civil Procedure § 474. will amend this Complaint to allege the true names and capacities of DOES 1 28 Ms. Herington 3 - - HERINGTON V. BOARD OF TRUSTEES OF CAL. STATE UNIVERSITY

6 is further informed and Ms. Herington through 50 when the same have been ascertained. 1 believe and based thereon allege that DOES 1 through 50 were and are, in some manner or 2 3 for the events, happenings, and damages way, responsible for and liable to Ms. Herington 4 hereinafter set forth below. 8. 5 is informed and believes and thereon alleges that at all times Ms. Herington herein mentioned, the subsidiaries, affiliates and other related entities of Defendant 6 were , and at all times herein mentioned, each was agents, servants and employees of Defendant 7 acting with in the purpose and scope of such agency and employment and Defendant ratified 8 also is informed and and approved the acts of such agents and employees. Ms. Herington 9 believe and thereon allege that at all times herein mentioned, the employees of Defendant 10 , its 11 subsidiaries, affiliates and other related entities were agents, servants and employees of 12 Defendant , and at all times herein mentioned, each was acting within the purpose and scope of ratified and approved the said agency and employment, and Defendant 13 acts of such agents and 14 employees. 15 JURISDICTION & VENUE 9. The amount in controversy exceeds the jurisdictional minimum for this court. 16 17 The unlawful acts and practices alleged herein occurred in, or concern, the County of Fresno in 18 the State of California. 19 Venue is proper in Fresno County under California Code of Civil Procedure § 10. 395.5. Defendant’s principal place of business is in operating the campus of Fresno State is in the 20 21 county of Fresno, California. Further, Fresno County is where the obligation or liability arose, or the breach occurred. 22 23 This class action is brought pursuant to California Code of Civil Procedure § 382. 11. The monetary damages and restitution sought by Plaintiffs exceed the minimal jurisdiction limits 24 25 stablished according to proof at trial. of the Superior Court and will be e has 26 12. Plaintiff complied with any and all requirements of the California Tort 27 Claims Act (Gov. Code §§ 810- 996.6) (the “Act ”) and exhausted her remedies by submitting Complaint in this et forth 28 . rding the claims s claims meeting the requirements of the Act rega - - 4 HERINGTON V. BOARD OF TRUSTEES OF CAL. STATE UNIVERSITY

7 ’s Risk to CSU claims her 1 submitted Herington , Ms. March 12, 2019 On 13. o CSU’s general counsel ), relating to 2 Management and Public Safety Departmen t ( as well as t March 19 (Claim No. 2018 -0034 97). On the claims described below , 2019, Ms. Martha 3 received Guiditta sent a letter confirming that the claim was , and an investigation begun. 4 However, no further notice was provided to Plaintiff on the status of the investigation, and more 5 claim was presented to Defendant. 6 than 45 days has passed since the COMMON ALLEGATIONS 7 OF FACT 14. Whenever reference in this Complaint is made to any act or transaction of 8 rectors, 9 Fresno State, such allegation shall be deemed to mean that the principals, officers, di , perfo Fresno State committed, knew of representatives of employees, agents, or 10 rmed, authorized, ratified, or directed such act or transaction on behalf of Fresno State while actively 11 engaged in the scope of their duties. 12 13 Ms. Herington is a graduate of Fresno State’s nursing program, graduating with 15. 14 a bachelor of science in nursing in 1995. She was a speaker at the graduation and graduated honor society. From 1996 to 1998 she 15 with honors and as a member of the Sigma Theta Tau worked in orthopedics and neurology at Huntington Memorial Hospital in Pasadena, CA. She 16 transferred to the inpatient rehabilitation unit at the University of Southern California, and 17 18 family nurse practitioner specialty eventually received her Master’s Degree in nursing with a . practitioner 19 from UCLA in 1999. She has more than 18 years of experience as a nurse 20 Program in 2017, after ’s PMHNP Ms. Herington first heard about Fresno State 16. online psych programs. The PMHNP program at Fresno S researching 21 tate openly advertised itself in its online course catalog and marketing material as a “formally constructed program 22 23 that meets the requirements for national certification by the American Nurse Credentialing 24 or Family Psychiatric and Mental Health Center as an Adult Psychiatric and Mental Health Nurse Practitioner.” Since 2014, California has required that all nurse practitioners have 25 26 national certification and attend a school accredited by the ANCC. Ms. Herington intended to practice as a certified PMH Nu rse Practitioner upon graduating and passing the B oards 27 , and 2017, and was relied on the advertisements in selecting the program. She applied in fall 28 - 5 - HERINGTON V. BOARD OF TRUSTEES OF CAL. STATE UNIVERSITY

8 accepted into the program that s ummer 1 . She paid her tuition to Fresno State, entering into a contract with . 2 the school 17. However, near the end of her first semester, Ms. Herington fell severely ill. She 3 applied for a medical withdrawal from the term, which was granted by Dean Griffin Meyers. 4 the second week of She submitted the final approval forms for the medical withdrawal in 5 December 2017. 6 7 18. of 2018 After recovering from her illness, Ms. Herington decided in the spring to reapply for admission back into the Fresno 8 program after speaking with several classmates 9 from the 2017 class. She to the graduate office as required turned in the appropriate forms 10 . several days before the due date and also completed the online application with Nursing CAS 19. However, Ms. Herington was initially denied readmission, because multiple 11 y sign her withdrawal paperwork, causing her three “W’s” 12 administrators had failed to properl to incorrectly appear as “F’s” on her transcript. After several months of complaints and 13 s with administrators, the error was eventually corrected, and she was able to 14 repeated meeting re-enroll in the fall 2018 semester. 15 At the orientation , Dean Jody Hironaka -Juteau gave an for fall 2018 students 16 20. 20 minute PowerPoint presentation to all the students discussing 17 , among other approximate 15- 18 topics, how the PMHNP program and the nursing school was properly accredited by the CCNE and certified by the ANCC. 19 20 21. Ms. Herington did well in her first semester, earning 2 A’s on her midterms . At 21 the same time, Ms. Herington spent weeks cold calling and emailing different doctors and who 22 clinics to find a “ preceptor ” (an experienced practitioner in the field supervises students 23 . Eventually Ms. Herington paid 515 unpaid hours of required clinical practice) during their called “Goals Healthcare” to help her find a preceptor; they succeeded in 24 $495 to an agency 25 . Ms. Herington was going to be t ding her a position at TMS Health Solutions fin heir first 26 Psychiatric Nurse Practitioner hire ever, and gave her the option for a permanent job upon graduation and certification. 27 28 However, on October 19, 2018, Ms. Herington rece 22. ived an email from Sylvia - 6 - HERINGTON V. BOARD OF TRUSTEES OF CAL. STATE UNIVERSITY

9 Miller, the nursing chair of the School of Nursing, which stated: 1 2 Andrea, “Hello The School of Nursing has been notified that some of the students who previously graduated from this program have been denied eligibility to take 3 the certification. The School of Nursing has been in contact with the ANCC and is working to resolve this matter. The program will continue with this Cohort as 4 planned.” 5 who received this same email were Ms. Herington and many other students 23. 6 understandably concerned, as Psychiatric Nurse Practitioners in the state of California must be 7 certified in order to practice and bill for services including Medicare and MediCal populations, 8 ngent upon her receiving and because her employment opportunity with TMS was conti 9 national certification. She emailed several of Fresno State’s administrators , including Dean 10 Sylvia Miller and Dr. Janice Sanders, but received no response. Worried about her economic 11 future and the likelihood she would not only lose her job, but also have wasted all the clinical 12 hours she had already worked, she emailed President Castro asking for clarification. 13 24. Given that the students who had been denied eligibility to take the national 14 2018, Ms. Herington boards by the ANCC had informed the school of their denials in August 15 it alleges and believes Fresno State was completely aware of its lack of accreditation when 16 enrolled 2018 and spring 2019 semesters, including Ms. Herington. Ms. students for the fall 17 Herington further alleges and believes that Fresno State withheld the fact of its lack of 18 intentionally, and continued advertising their program as being fully accredited accreditation 19 dents s with stu ed its contract after it knew it was not, and intentionally breach and certified . 20 25. Ms. Herington and the other students in her cohort were all frequently advised 21 to stay in the program, and increased increasingly sporadic updates in which the administration 22 s continuing and that they we re generally that the PMHNP program wa would only say 23 ith the ANCC towards a solution.” Ms. Herington eventually realized that there “working w 24 for the school to be retroactively accredited by the ANCC was no possibility , and that any 25 further time spent in the program was only wasting more of her mon She filed ey and career. 26 ed a refund for her spring tuition on the paperwork to withdraw from the school and request 27 November 2, 2018. When Ms. Herington sought her instructor Dr. Santy’s signature on the 28 - 7 - HERINGTON V. BOARD OF TRUSTEES OF CAL. STATE UNIVERSITY

10 1 and told “it seems like you are blaming withdrawal forms, she was chastised for quitting, Fresno State” for the problem. 2 26. 3 After Ms. Herington withdrew from the program, the remaining students in her 4 cohort continued asking for guidance from the administration, only to be told there was no new 5 updates about the situation. They were, however, encouraged by Dr. Sanders and Dean Miller 6 to stay in the program. Eventually, on February 13, 2019, the dean emailed all current students, stating 27. 7 t the school’s late 8 that they had reached a “determination” with the ANCC, and confirmed tha 9 all of 2019 could not retroactively apply to students prior attempt to gain accreditation in the f all 2019 semester. to those in the f 10 for individuals who were able to begin or The email further stated that “ 28. 11 process prior to ANCC’s discovery that the PMHNP program was complete the certification 12 not accredited, the following determinations have been made: 13 To allow currently certified individuals and those who had passed the • 14 ertification exam prior to ANCC’ NP s discovery that the PMH PMHNP c 15 -Graduate Program was not accredited to maintain certification for up Post to five (5) years from the date of notification to the clinicians, while they 16 -Graduate seek completion of a nationally accredited PMHNP Post cannot demonstrate completion of program. Individuals in this group who 17 a nationally accredited PMHNP Post -Graduate program by the end of the 18 five -year period may face revocation of certification. 19 • To allow graduates of the PMHNP Post -Graduate program who 20 commenced the application process prior to discovery your PMHNP Post - 21 Graduate Program was not nationally accredited to be deemed conditionally eligible to test (or retest, as applicable) once during the three 22 (3) months following the date of notice to the graduates. Passing test held for up to five (5) years to allow these individuals to scores will be 23 -Graduate demonstrate completion of a nationally accredited PMHNP Post 24 program from the date of ANCC’s notification letter to the impacted graduates. Failure to timely demonstrate completion of a nationally 25 -Graduate program may result in cancellation of accredited PMHNP Post the test scores. 26 27 -Graduate Program All other graduates or students of your PMHNP Post • 28 will be ineligible to test or receive certification unless and until they can - - 8 HERINGTON V. BOARD OF TRUSTEES OF CAL. STATE UNIVERSITY

11 demonstrate completion of a nationally accredited PMHNP Post -Graduate 1 program . 2 every student who had graduated These determinations effectively meant that 29. 3 years had their entire degree and from Fresno State’s PMHNP program in the previous five 4 invalidated, and would need to repeat the program entirely clinical program work (and redo 5 d not their hundreds of clinical hours) yet or lose their license within 5 years. Those who ha 6 , including Ms. Herington, would likewise be ineligible to sit for the national boa graduated rds 7 and clinical work from scratch. and would need to start their schooling 8 30. Having been harmed by Fresno State’s actions and its breach of contract , the 9 Plaintiff prays for damages as alleged below. 10 CLASS ALLEGATIONS 11 31. Ms. Herington brings this action pursuant to and the Class, , on behalf of herself 12 California Code of Civil Procedure § 382, on behalf of herself and a Class defined as follows: 13 Class Description 14 students who were enrolled in the Psychiatric Mental All current and former Health Nurse Practitioner (“PMHNP”) program at California State University, 15 time between March 1, 2015 and the present . Fresno at any 16 Excluded from the Class is any judge, justice, or judicial officer presiding over 32. 17 families and judicial staff. this matter and the members of their immediate 18 Ms. Herington s the right to modify the Class description and the Class 33. reserve 19 period based on the results of discovery. 20 . Upon information and belief, there 34. over 100 students have been Numerosity 21 ince March 2015 , such that joinder of all Class members is enrolled in the PMHNP program s 22 While the exact number and identities of the Class members are unknown at this impracticable. 23 of Defendant’s time, such information can be ascertained through investigation and discovery 24 and tuition records enrollment . The disposition of the claims of the Class in a single class 25 action will provide substantial benefits to all parties and to the Court. 26 35. . There are many questions Common Questions of Law and Fact Predominate 27 of law and fact common to the claims of Ms. Herington and the Class, and those questions 28 9 - - HERINGTON V. BOARD OF TRUSTEES OF CAL. STATE UNIVERSITY

12 predominate over any questions that may affect individual members of the Class. Common 1 2 questions for the Class include but are not limited to the following: 3 Whether Fresno State entered into a valid contract with Class members by (a) accepting their tuition in exchange for promised services ; 4 (b) Whether Fresno State’s failure to provide an accredited training program to its 5 -paying students constitutes a breach of that contract; tuition 6 ense of Ms. Whether Fresno State was unjustly enriched by its scheme at the exp (c) 7 Herington and the Class; 8 Whether Ms. Herington and the Class have been dam 9 aged by the breach; (d) ies and the Class are entitled to restitution of all mon Whether Ms. Herington (e) 10 and the Class; and 11 acquired by Defendant from Ms. Herington Whether Ms. Herington and the Class are entitled to consequential damages (e) 12 stemming from Defendant’s breach. 13 s liability to Ms. Fresno State’ . The factual and legal bases of Typicality 14 36. Class members are the same. All members of the class were parties 15 and to the other ngton Heri ’s failure to obtain proper standardized contract with Fresno State, and Fresno State to a 16 reach then 17 caused accreditation breached each contract in the same manner. Fresno State’s b 18 injury to Ms. Herington and to all of the other Class members . Ms. Herington and the other 19 s unlawful and Class members have all suffered harm and damages as a result of Fresno State’ wrongful conduct with respect to its breach of the contract 20 . 37. 21 Additionally, Fresno State has acted and failed to act on grounds generally 22 in marketing and selling its applicable to the Ms. Herington and the other Class members services , requiring the Court’s imposition of uni and subsequently breaching its contract form 23 relief to ensure compatible standards of conduct toward Class 24 members. Adequacy of Representation 38. 25 . Ms. Herington will fairly and adequately represent and protect the interests of the Class. Ms. Herington 26 has retained counsel with substantial experience in prosecuting complex and class action litigation. Ms. Herington and 27 her 28 counsel are committed to vigorously prosecuting this action on behalf of the Class, and - 10 - HERINGTON V. BOARD OF TRUSTEES OF CAL. STATE UNIVERSITY

13 nor her sts counsel have any intere Herington have the financial resources to do so. Neither Ms. 1 2 adverse to those of the Class. suffered, . Ms. Herington and the Class members of Class Action Superiority 39. 3 Fresno State’s unlawful and wrongful conduct. and will continue to suffer, harm as a result of 4 5 A class action is superior to other available metho ds for the fair and efficient adjudication of the present controversy. Individual joinder of all members of the class is impractical. Even if 6 7 individual Class members had the resources to pursue individual litigation, it would be unduly ourts in which the individual litigation would proceed. Individual litigation burdensome to the c 8 magnifies the delay and expense to all parties in the court system of resolving the controversies 9 10 llows a Fresno State’s common course of conduct. The class action device a engendered by 11 single court to provide the benefits of unitary adjudication, judicial economy, and the fair and 12 equitable handling of all class members' claims in a single forum. The conduct of this action as a class action conserves the resources of the parties and of the judicial system, and protects the 13 rights of the class member. Furthermore, for many, if not most, class members, a class action is 14 . the only feasible mechanism that allows therein an opportunity for legal redress and justice 15 16 ACTION FIRST CAUSE OF Breach of Contract 17 (On Behalf of Ms. Herington and the Class) 40. Once Ms. Herington paid her first tuition to the Board of Trustees of California 18 Defendant to provide State University , a contract existed between her and the Defendant, for 19 . certain educational services accredited by the CCNE as part of the PMNHP program 20 members of this class action signed and entered into substantially 41. All proposed- 21 similar contracts with Defendant providing for the same CCNE accredited educational services 22 as part of the PMNHP program. 23 Fresno State advertised the terms of the PMNHP program offered at its campus 42. 24 in its advertising material and on its website. 25 43. By enrolling in classes under the PMNHP program, the proposed class offered 26 to purchase Defendant’s advertised educational services at the advertised prices, and by 27 accepting the students’ enrollment, Fresno State accepted the students’ offers. 28 11 - - HERINGTON V. BOARD OF TRUSTEES OF CAL. STATE UNIVERSITY

14 44. These offers were supported by consideration in that the students would receive 1 the benefit of a higher education that has been accredited by the CCNE, which they would be 2 able to use to get licensed nationally by the ANCE, and Defendant would receive the benefit of 3 4 being paid tuition. The terms of the obligations and education to be provided by Defendant were 45. 5 advertising, and the website rly and definitely in its course catalog materials, its listed clea of 6 7 Fresno State, which declared that the program was a “formally constructed program that meets 8 the requirements for national certification by the American Nurse Credentialing Center as an Adult Psychiatric and Mental Health or Family Psychiatric and Mental Health Nurse 9 10 Practitioner .” 46. Through their actions in failing to acquire or retain accreditation of the CCNE 11 as promised, the Board of Trustees breached the contract and did not provide the product the 12 13 students had contracted to receive. 47. 14 Indeed, the lack of accreditation rendered the program professionally worthless, 15 and all members of the class were and are forced to not only retake a new educational program, but also repeat the hundreds of supervised hours of clinical work that is required of all students 16 seeking national certification. 17 18 48. Defendant, without legal excuse, failed to provide Ms. Herington or the Class members 19 educational services that met the promised minimum standards. 20 49. Defendant therefore breached its contract with Ms. Herington and all Class 21 . members 50. s wrongful breach 22 eable, and proximate result of Fresno State’ As a direct, forese alleged herein, Ms. Herington and the Class seek damages in an amount to be determined 23 accordin 24 g to proof at the time of trial, but in an amount in excess of the jurisdictional . Ms. Herington and the Class also seek equitable and injunctive 25 requirements of this Court specified in the prayer for relief. ’ fees as relief, plus the right to attorneys 26 PRAYER FOR RELIEF 27 28 WHEREFORE, Ms. Herington, on behalf of herself, and the Class, and in the public - - 12 HERINGTON V. BOARD OF TRUSTEES OF CAL. STATE UNIVERSITY

15 1 interest, pray for judgment and relief as follows: A. a proper class 2 With respect to the class claims, a declaration that the action is be appointed as an adequate class representative, and that her , that Ms. Herington action 3 counsel be appointed as class counsel; 4 the Fresno State to fully fulfill and perform For injunctive relief compelling B. 5 terms of its contract, 6 . sible if pos In the alternative, and wh 7 C. ere appropriate, rescission or restitution, or other appropriate equitable relief; 8 D. For compensatory and consequential damages in an amount to be determined 9 according to proof at the time of trial; 10 For interest at the highest legal rate commencing from the earliest date allowed 11 E. by law; 12 For costs of suit incurred herein; F. 13 For reasonable attorneys G. 14 ’ fees pursuant to Code of Civil Procedure Section ilable basis 15 1021.5, if the Court finds such section applicable ; and , or any other ava H. For other and further relief as the Court may deem just and proper. 16 17 Respectfully submitted, 30 April d: Date , 2019 18 19 _____________________________ 20 Roberto Ripamonti Attorney for Plaintiff Andrea Herington 21 and the putative Class 22 23 24 25 26 27 28 13 - - HERINGTON V. BOARD OF TRUSTEES OF CAL. STATE UNIVERSITY

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