Organizing A Garage Sale – Tips For Organizing A Garage Sale

Organizing a garage sale seems like a lot of work for people who have no experience with the task. It will certainly take some planning and legwork, but it shouldn’t be too difficult when you know how to proceed. When you’re getting ready to clear out your garage for any reason, consider all of the following tips for organizing a garage sale will help make the process as easy as possible while ensuring that it’s also successful and hassle free.

The first thing you have to do is consider what the ultimate goal of your project is. Are you clearing out your garage so you can move forward with those garage makeovers and renovations that you’ve always wanted to do? Are you looking to clear out more space so you can finally keep both of your cars in the garage? Knowing what you’re trying to accomplish will give you a clear sense of how much you need to get rid of.

Now that you know what you’re doing, you need to pick out a date and stick with it. This will help you plan all of the details such as creating and distributing flyers. It will also help you manage your time correctly, so that you can get everything prepared for the sale. This is truly one of the most important tips that you can utilize, because nothing is worse than either going through all of the trouble and then not having anyone show up, or having to run around at the last minute to make sure you can get the sale together.

Ultimately, organizing a garage sale is going to come down to what kinds of items you will be selling or trying to sell. One helpful way to get this done is to create a few different piles of objects and belongings. One will have all of the items you are definitely willing to sell, one will be an undecided pile and others will be things you’re definitely keeping. This will help you organize and make easy decisions about what to keep and what to get rid of.

best garage shelving units should absolutely take is to determine a value for everything beforehand, and you should attach labels to everything as well. This will make it easier on both you and the potential consumer, and it will enable you to really have a good sense of the value of the possessions you are putting up for sale. Then you won’t make any hasty or bad decisions at the last moment.

Of course you really don’t need a guide to complete this kind of task. It should be relatively simple and straightforward. Still, it’s always helpful to have some guidelines and general rules that you can follow or apply in order to make things easier and more successful. Organizing a garage sale can actually be easy and fun, and it will enable you to complete your goals whatever they may be in terms of storage, organization and space for your garage.

Garcinia Cambogia Extract Review

These days more and more people are becoming aware of the importance of losing weight and staying healthy and fit, so it’s no wonder that the market has seemingly been flooded with all manner of weight loss products. However, with this new awareness has also come knowledge, so that the vast majority of people are now looking for natural products that don’t have some of the dangerous side effects of drugs that may contain harmful chemicals. One such natural product that has created a veritable storm in the weight loss market is Garcinia Cambogia extract.

Garcinia Cambogia was featured on the Dr. Oz show and he was so excited about it, that he called it “the Holy Grail” of weight loss.

What is Garcinia Cambogia?

Garcinia Cambogia is a flowering evergreen tree native to Indonesia and India, but also grown in other countries. Its fruit is yellow in color and resembles a small pumpkin. It has a sweet sour taste and is used in Indian cooking to add flavor to their curries. It is the rind of the fruit that is dried and powdered and used as a weight loss supplement. Dr. Julie Chen, a leading scientist and the special guest on Dr. Oz’s show, said that research has shown that the dieters who took Garcinia Cambogia extract lost weight 2-3 times faster than those who didn’t take Garcinia Cambogia extract.

How does Garcinia Cambogia help in weight loss?

Garcinia Cambogia works in two distinct and effective ways to help with weight loss.

The main component of Garcia Cambogia is HCA or hydroxycitric acid. The extract from the rind of this fruit is known to be rich in HCA. It is a known fact that carbohydrates and sugars are converted into fat and stored in your body for future energy requirements. An enzyme called citrate lyase is responsible for this conversion of carbs into fat and HCA has been shown to chemically block this enzyme.

Garcinia Cambogia is also a natural appetite suppressant. It gives a feeling of being full, preventing those hard to resist and annoying hunger pangs. It assists in putting an end to cravings for food and emotional eating.

In summary, Garcinaia Cambogia helps prevent the formation and storage of fat and helps eliminate your feelings of hunger and craving for food. That is why Dr. Chen called it a ‘dual action fat buster’ on Dr. Oz’s show.

Why did Dr. Oz call Garcia Cambogia call it the Holy Grail of weight loss?

Garcia Cambogia extract also helps in weight loss in other ways apart from the two mentioned above. has found that stress and depression are important contributing causes for emotional eating and resultant weight gains. Decreases in serotonin levels have been shown to be closely related to depression and stress, and according to Dr. Chen, Garcinia Cambogia increases the levels of serotonin. This can help in reducing stress and depression helping to reduce or avoid any emotional eating. This is a blessing for those who tend to eat too much food when they are emotionally challenged.

Cortisol is a fat building hormone produced in your body and apparently the secretion of this hormone is increased when you don’t get sufficient sleep or don’t sleep well. The extracts of Garcinia Cambogia have been shown to help you to sleep well. Good sleep prevents your body from producing excess cortisol.

Garcia Cambogia has also shown to help boost a person’s metabolism resulting in burning more calories and fat, ultimately leading to weight loss.

Dr. Oz and Dr. Chen further discussed the results of a study conducted on 60 obese patients. The results of the study showed that men who consumed 1200 calories per day and took Garcinia Cambogia lost 14 pounds after 8 weeks and men who took a placebo lost 6 pounds.

It also appears to enhance the body’s immunity and general health, as the results concluded that the levels of LDL, triglyceride and serum leptin were considerably decreased and the levels of HDL and serotonin were considerably increased.

Dr. Chen said that this fruit also helped in building lean muscle mass and decreasing fat.

As you can see, Garcia Cambogia extract appears to provide numerous benefits, so it’s no wonder that Dr. Ozcalled it the Holy Grail of weight loss.

Are you interested in buying Garcia Cambogia extract?

There are numerous Garcia Cambogia extract supplements in the market today, so make sure that you follow Dr. Oz’s recommendations and instructions before you buy the product, namely;

Look for the name Garcia Cambogia on the label of the bottle. It should contain more than 50% of HCA.

It can boost metabolism if it contains potassium and calcium.

It should not contain any artificial ingredients and harmful chemicals. It should not contain anyfillers and binders.

Garcinia Cambogia extract, Dr. Oz’s “Holy Grail of weight loss” does indeed appear to be a miraculous weight loss supplement. Make sure to follow Dr. Oz’s recommendations before buying and then lose weight and enjoy the other health benefits as well.

Planning to buy a t-shirt, go for the printed one

We all wear t-shirts to cover up the body, but now the whole scenario is changed.  Today mostly wear clothes only to increase their image among the others. That is why now clothes become the main feature of the fashion industry. T-shirts companies spend an enormous amount of money on the Models to endorse their brands in the market.

T-shirts printings become a very nice product for the fashion industry. The companies like Ottawa t-shirt printing gain massive popularity among the youngster these days. Printing t-shirts become the primary source of sex appeal among the youth in colleges and schools. There are so many advantages of wearing shirts worth prints; some of them are mentioned below.

It increases your overall personality

It helps to improve your character; t-shirts with prints always give you some charm which you are always looking for. It is also excellent to enhance confidence because if you are wearing the stuff which everyone want to wear, then it still gives more benefits to your image.

Used by many Political parties

Many political parties started to give personalize merchandise to their workers and local people area of the region. Through these printed t-shirts they want to get the faith of the people by providing free printed t-shirts with their logos and the name of the political parties. On the other hand, many wear special printed stuff to support their favorite political parties. Eventually, it is beneficial for the political parties too.

Give great messages

By wearing the printed t-shirts, you can give your message among the others very quickly. You only need to write the word on the t-shirts by ordering the printer companies. These companies provide you with the necessary stuff on the t-shirts. And you can easily give your message by only wearing the printed message shirt.

On the other hand, you can also wear some available stuff from the market. Many shop keepers have differently printed t-shirts with different self-written messages written on shirts like save the earth, save the environment, stop pollution, save the water, water is life and so on.

Finally, we can say that all these printed shirts give a significant impact on the others hence spending on the printed shirts is quite a worthful thing to do. There is nothing like waiting when it comes to getting these T-shirts as there are many options available both online and offline.

Exploring the different uses of armour thyroid

The thyroid is a small butterfly-shaped organ found in the front of the neck area. Though small in size, the thyroid glands play a huge role in controlling major body functions such as metabolism, reproduction, and body temperature. These glands produce the crucial thyroid hormone which enables proper body functioning. The thyroid glands just like other body organs become less active as one gets older and therefore people develop some conditions like hypothyroidism and hyperthyroidism. Hypothyroidism can be treated using alternative medications such as armour thyroid which is extracted from pig glands.

Hypothyroidism is a condition caused by low production levels of thyroid hormones by the thyroid glands and is mainly caused by aging. The symptoms of this disease differ with age and vary in severity. The only way to determine whether you have hypothyroidism is to have a blood test done because most of the moderate symptoms are mistaken for signs of other ailments. Constant monitoring of the thyroid stimulating hormone is recommended so as to avoid thyroid disorders.

Another use of thyroid armour is fighting aging-related problems. Due to aging the metabolic rate of the body goes down thus affecting various body functions including the breakdown of fats which results in weight gain. This medication helps restore the functions of the thyroid glands and thereby enhancing the production of thyroid hormones which breakdown excess fat in the body and help build muscle. This helps increase energy levels in old people and subsequently enabling them to become more active. It also prevents the development of goiter which occurs due to low levels of thyroid hormones. Armour thyroid also plays the role of stimulating the production of thyroid hormones from the thyroid glands.

Thyroid supplements are now available to help solve thyroid problems. Women over 40 years are at most risk of having developing this condition. These supplements come in two forms: natural and synthetic. Natural supplements are administered depending on the age of the person and thyroid condition. Medications should be followed up with frequent blood tests and temperature monitoring to ensure that the drug is working as needed. Interested in article topic? – Dr Zacharia from SydneyLiving a healthy lifestyle and involving yourself in some physical activities can help in sustaining the production of thyroid hormones. Go online for the best solutions on how to treat thyroid disorders. provides customized programs and plans on how best to treat these disorders.

Go Through the Importance and Ways to Download Games

These days’ games become the best, or you can say the foremost part of every person’s life. People require games to utilize their free time properly, to get the best experience or to entertain themselves. So, when it comes to entertainment, games are the first thing that comes to mind of each and every single person. There are different categories of games available, and people need to select these categories, or you can say according to their choice and taste. The categories of games refer to that some games are considered under the category of action games, fighting games, simulation-based games and many more. So, it totally depends on the people that which category of games they prefer to play.

Now, it’s time to know that from where people can download games if they really want to play it in their device? Well, individuals can easily download the games in their device by simple from their game stores if they are using mobile. On the other side, if people are talking about downloading games on laptops and computers, then there are various sources and websites present which contains lots of games. So, from these websites, people can simply grab the games which they want to play without paying any worth.

Various ways to download games

Here you find the most important and simple ways to download the games easily and freely. You only need to make sure that you are applying the simple methods to download games in your system –

  • Game stores – well, if people want to download the games in their mobile, then they simply have to download them from their respective game stores. It means that they if people have Android mobile then they have to download it from Play Store and if they have IOS mobile, then they should go with their Apple Store to download games.
  • Websites – another simple and easy method to download the games is by making the use of websites. People should first find the most appropriate and the best sites which contains all types of games in it. After that, they have to download the games which they want simply for free. The same method is the best when people have to download games for their PC and laptops.

In a nutshell, these are the two main methods by which individuals can simply download and play games in their respective devices.


Tips to search the background of any person

A free background check is beneficial for individuals because they can take a lot of benefits without paying the fee. The free process can give you the complete details of the person, and that can also help for the location information. There are different reasons to find out the details of the person, and some reasons are essential to understanding. People want to know the information for employees and business partners. On the other hand, some people are finding the information from the search engine, but they are getting less information. The demand of some people is to find the real location or address with the mobile number of the person that you can find with the paid services.  Some people don’t want enough information, so they choose the search engine option to the facility.

Help with technology

The technology is providing many facilities to the investigation. There are different situations in which you can take the real information of any person with the help of the services that you can take from some sites. There are many online sites which are completing the demand of people by giving the contact details and criminal background information. These are used for various purposes like as if you are an employee then you may face with that. On the other hand, some tasks are performed with the help of the court details for the criminal activities. So, technology is good for the free background check process.

Tips to know: –

  • Serf the search engine

Your first step to follow to find the details of the person is to have a right kind of the search engine like as Google search engine. The source may help to find out the general information of the person. The step is essential to follow, and you should care about some basic things. A person should keep the correct name information with the proper spelling, and you need to find out these with the free background check sites and take the help of search engine also. If you use a good type of the search engine, then it may help you, and you can take the information without any issue. There are no issues when you search online details.

  • Go with the local resources

The second main step that you should follow is to take the help of local country court to the criminal details and other information. The main advantage of the court is to get the free details and free background check that is enough for you.




What Is Payday Loans And How Payday Loan Work?

A payday loan is a specific loan term in the financial world. A payday loan is also known as an unsecured loan because there is no need of any collateral. Even, you don’t have need of any guarantor to applying for such loan term. Some people know payday loan as instant cash because you can get instant cash after getting the approval of the loan by the payday loan company. You may have knowledge or not, but payday loan is an expensive loan term compare than other loan terms.

Most of the people like to use a payday loan in the case of a financial emergency. In simple words, if they have an urgent need for money for a short period of time, then they would like to use payday loan. No doubt, they have to pay the highest rate of interest on payday loan, but they can complete their financial needs on time. If you don’t have knowledge regarding a payday loan, then you can get from They are one of the well-known payday loan service providers.

Payday Loan Overview:

There is no set definition of payday loan. It is a specific kind of loan then can help to complete your financial needs on time. There are many names of payday loan term such as instant cash, salary loan, etc. Actually, a payday loan is an expensive way to borrow, i.e. you will have to pay the highest rate of interest for a payday loan. Instead of that, most of the people like to use a payday loan. There are many good reasons behind the popularity of payday loans.

How do payday loans work?

Payday loans are simple to apply. You can apply online for your payday loan. Unlike other loan terms, there will be no need of collateral or guarantor. You just need to complete the formalities like a bank account, your information, etc. Once, your loan gets approval then you can receive the amount of loan in your account within the next 24 hours. It is really simple and easy to apply for a payday loan but choosing the right company matters a lot.

There are numbers of things that are must to take into consideration. You will have to consider more and more about the company. You should know about the reputation of the company, the license of the company and many more. In addition, always find a professional and reliable company for a payday loan.

Impossible Riddles – How To Solve?

Riddles are categorized according to the level of difficultness. If you just want to relax by solving riddles, then simple riddles are an ideal choice. In contrast, if someone wants to experience a high level of difficulty then impossible riddles will be the perfect option. We can also share the puzzles with other people for having a great fun time and entertainment.

Methods of solving impossible riddles

Well, it is not a cup of tea to crack the impossible riddles because these are too difficult to solve. We have to think a lot in order to find the logic behind the puzzle. There are many methods by which such kind of questions can be answered. The most popular methods are described further.

Practice flexibility – sometimes it has seen that people instantly respond to the question and give the wrong answer. They don’t consider each point and can’t evaluate the correct answer. You should try to practice solving puzzles in different ways. By this, you will come to know about the way of getting possibilities.

Solve popular riddles – while there are numerous riddles, but we all know at least a few popular ones. So, we should always start with the riddles, which we have already solved. Try such puzzles daily and find the maximum possible ways to get the right answer. It will help us a lot in relating the answer and puzzle.

Consider the information properly – it is necessary to understand the riddle in a proper manner for getting the answer. In case, we are unable to understand the context of the puzzle then it will be impossible to find out the answer. So, always understand the sentence and link that with the possible answers. You should also try to play with the different meaning of words.

Break down the riddle – this is the best ever way to get the perfect answer to the riddle. In this method, you are only required to cut down the whole puzzle into two parts. After this, understand both the parts individually and then try to connect them with the possible answers. By this, we can get help in understanding the riddle properly.

Apart from these, you should also be patient while finding out the answer to the riddle. Don’t give answer fast because it will always be wrong. Always take proper time and choose the best suitable option for the answer.


What Vehicle Identification Number Indicates?

No doubt, it is important for every individual to update the information with Vehicle Identification Number legally under the government rules and regulation. It will increase the value of your vehicle with proper R.C. Every vehicle could be allotted with a unique number so that it could be easy to find information in a particular way.

Actually, VIN code is important to show in public with the point of view to follow legal guidelines. The characters include vehicle’s series, year of launching, model & body type, restraint system, and engine code. That is the way to generalize the factual concept of VIN number. If you are willing to know about your vehicle, then will surely provide you the way from where you can write the VIN and check out full details instantly.

What does it include?

Numerous are the points that will show the information which is included in the Vehicle Identification Number.

  • Originality: The Vin-codes show the originality of your vehicle. It is legally controlled under the government guidelines. All such things could be managed with the help of unique alphabetical code. It will make you sure about R.C is complete or not. That will be your responsibility to fill all the necessary information on the behalf of vehicle number that will be store to a government department.
  • Personal details: The person who is the owner of the vehicle could be mentioned in the registration copy. The verification code that shown manufactured company, state code, phone number, and personal address will be written in accordance with the approval from central government. VIN is a small metallic rectangular shaped plate at the front side of the vehicle.
  • Registration/ model number: The legal registration number can be published in accordance with particular brands and transcription. The vehicle identification number is well being allotted from the transport department that signifies vehicle permit. That is essential to judge originality so that it can be applicable in every city. You can take vehicle anywhere with being attached with proper R.C. your vehicle will remain safe under the vision of police as they will help to make prevent from scams and frauds.

It will make them updated with their Vehicle Identification Number and make prevention from illegal offenses. When the allotment of the number will be published in your car, then you make sure that the name plate will be original and genuine.

Ways to find out the job vacancies

Nowadays, it is very hard to get a job; it does not matter that how many degrees you are having and how much you qualified. Getting a job has become so hard, and for standing in life, it is very important to get a job. There are many ways by which you can find the job vacancies some are traditional, and on the other hand, some are modernized. One has to be very much careful when it comes to finding the job. Traditional ways are not so worthy in this modernized world that is why it will be better for you to go with the new ways such as searching on the internet with the help of some sites. You can take help from the as this site will let you find different jobs in different localities.


There are many ways by which you can find the job vacancies. Some of those ways are mentioned here which are sufficient to let you understand. Those are:-


Most of the job advertisements come on the networking sites. If you are finding a new job, then you must try on the networking site because these sites can help you in finding the right job. Today almost every company use to post about their job vacancy on different websites that is why one should check the networking site so that he can find that which job will suit him.


It is also a very reliable option with which you should definitely go with. You should ask from the people and companies that is there any kind of job vacancy present or not. It is a reliable option which you should definitely choose this option because a physical interaction with the person will give a better impact as compared to the networking manner.

Company website

If you have decided to do work in a particular company, then you should check the website of that company on a regular basis. Due to the regular checking, you will get to know about the vacancies in the company so that when you will find the job vacancy, you can try that company for getting the job.

Hope that you are satisfied with the above information and will use these ways to find the job vacancy among the companies. So find the best job for you and makes your career bright.

Things to check before taking a car on rent

Are you the one who is looking for the best car to take on rent so that they can make their trip much comfortable? If yes then you should go for the car rental services and take a car so that you will not find any need to change your bus and taxi again and again. It does not matter that you are taking the car on rent for the first time or nor because there are some things which you have to look at every time when you will go to hire a car. You can check out the to know that what you will get from the car rental Marbella services. While hiring the car from any service provider does not matter, but you have to look at some things every time.

What to check?

There are many things which one has to check when he will go to take a car on rent. Those things are:-


You should look that have you done all your paper working before taking the car on rent. It is very important to fulfill all the documents and do all the paperwork so that you can find the best car for you without having any trouble in future. Every car rental company will ask from you for doing the paperwork as they are giving your car and it is their duty to do so. If some damage will happen to their car then, who will bear the claim that is why it is important to do the paper working so that the service provider will get the security for their car.

Check the car

It is an important thing which one should look definitely when one goes to take the car on rent. You should check the car because if some damage is already in the car, then you should be aware of them. Unfortunately, if you will meet with the accident, then you have to bear the cost of that what you damage by getting aware of the previous damage.

Controlling the car

There is no doubt in it that you are expert in driving and you can drive smoothly with ease. It will be best for you if you will learn about the specifications of that particular car.

These are some of the things which you must check when you will go to take the car on rent.

What to Say When Proposing You Partner for Marriage?

The way of talking and expressive views will give you an opportunity to treat your partner good. While proposing your partner, it is important to say some say the loving words like “I Love You” or “Will You Marry Me?” You might be sure about the right way and suitable timing to propose your partner. That will make you feel comfortable and can get a chance of acceptation. However, every individual wants to impress the partner so that they with can feel special at the moment of a wedding proposal.

Wedding proposal New York plays an important role to give you the way to propose your partner and the best location from where you can impress and express your emotion. You can go with their advice and ask them about any doubts. Generally, the beautiful location will enhance the mood into romance and will able to spend some part of life together. Here is some important information that will show you aspects of enhancing wedding proposal.

When to say?

You should consider the right time so that your partner can accept your proposal comfortably. As there are some points that everyone could pay attention and follow it at the time of proposal.

  • Surprise party: The surprising and shocking parties might be responsible for attracting your partner with your exceptional attitude and feelings. You can feel them special with your loving vocabulary words and experience the beautiful moment together. Give them gifts and greeting cards especially hand written will attract them more.
  • Consider their family: You can also consider their family so that after their approval you can propose without any hesitation. It is important because of the family reputation as you can propose with free mind comfortably.
  • Record through messages: You can record the voice messages with the most appropriate way and unique method to adopt while proposing your partner. It also includes bending your knees, saying the effective words. Secondly, you should consider the wedding proposal New York as the most popular service provider that will give you the way of proposing. If you want to experience the moment, then respect their feelings and can establish behaviour towards them.

Undoubtedly, it will make your wedding proposal effective, and you can easily impress your partner at a suitable time.

Tips to choose the best cooler

Coolers are the necessity of the summer to lead a happy and comfortable time. In summer, you have to deal with numbers of problems such as sweating and odor also, but with the help of the coolers, one can make their surroundings cool so that they can feel fresh. Because of the sweating in summer, it does not feel fresh in the day, but by keeping the desired temperature, you can make it possible. You should also definitely go for it, and if you are looking for the best cooler for the money, then you can go for the given mentioned tips.


There are many tips which can help you in finding the right cooler for you. Some of those tips are:-


When it comes to buying the cooler or any other thing, then the price comes first in mind. There are multiple options you can find in the market for the coolers with variant prices also. It is up to you that which will come within your budget with the features which will complete your requirements. You should get restricted with the budget so that you will go for those options only which will come within the fixed limits. It will let you find the right option from the limited options otherwise it can create a mess for you among numbers of varieties.


If you go to buy the best cooler for the money, then you should surely check the reviews of the coolers. When you watch the reviews of the coolers, then it will help you in finding the best piece for you. With the help of the reviews, you can find out that which coolers has which features and by this means you can get to know that which model will complete their needs and requirements.


It is obvious that you cannot change the positions of the coolers on a regular basis because of its heavy weight. But when you buy the one piece which is having the feature of easy portability, then you should choose that one only. With the help of easy convenience, you can clean the particular place daily and can change its installation place also easily.

Coolers are important in summers, and it is important to understand that how you will pick the best cooler for the money because you will not buy the new piece every year.

How to Lose Weight Fast But Safely

How to Lose Weight Fast… This idea, this desire resonates within the whole diet industry.

It also creates amongst this industry an urge to feed this need you might have… with anything they can label “lose weight fast”.

And then to TRICK you into buying it.

1 – First, There are Things You Need to Know

2 – Set Up Your Path

Then Set Up a Customized Path, tailored for successfully Losing Weight Fast. You Will Find the Framework to succeed in our How To Lose Weight Guide.

Then adjust your Options like this so this How To fits the “Fast ” Weight Loss requirements that give the best results :

Key 1 – Take Control

  • Focus on your weight loss at least 15 minutes each day. Chose your meals in advance before buying.
  • We’re not about making you spend money, but a fast weight loss product with proven record can double or triple your Weight Loss rate.
  • No way to avoid taking medical advice, because in losing weight fast, losing weight hits harder on your body.
  • Rather get your fridge and home of transformed and bad food, and plan your meals and shopping with healthy food.

Key 2 – Move

  • Go to the Gym 3-4 times a week. Go for Strengh Training (to avoid getting a skinny but fast result)
  • Do Cardio training. Raise progressively the time up to  3 times 45 minutes.

Key 3 – Feed Your Emotions

  • Be careful on this one. The harder your diet and program, and the more emotional sustaining you will need.
  • Use Hypnosis CDs or Self Hypnosis on a daily basis
  • Learn to use NLP techniques (submodalities to lessen hunger, augment well-being, heighten motivation, and relax)
  • Be ready to stand against the hunger when you will lessen quantities (it’s a matter of holding a few days), and the three-days compulsion to eat transformed food when you eat some
  • Enforce your will (ready some healthy food like fruits and spouts for the moments you will feel the need to eat

Key 4 – Watch Nutrition Quality

  • No way you can go fast if you take any bad food. Get rid of sodas, and limit transformed / white food to the BARE minimum.
  • Drink a lot of water and take weight loss pills like Phen24.
  • Assure a good level of protein.
  • Lessen salt.
  • Ensure taht at least 40% of what you eat are fruits & vegetables.

Key 5 – Adjust Nutrition Quantity

  • Really Stick to Avoid Backlash : eat of everything

Key 6 – Watch over Nutrition Regularity

  • Eat every 3 hours (lesser quantities), and nothing except water in between
  • Really Stick to Avoiding Backlash : eat of everything (except Bad Food)

Key 7 – Unfolding the Path You Set Up

  • Pilot yourself every day.
  • Chose carefully your objectives, and with qualified  medical advice. Aiming over 5 pounds per week Weight Loss endangers your health, and programs some BackLash : there will be a price.
  • Yet take 3 to 7 days to get to your diet rythm progressively (it is safer in the end and avoids Backlash)
  • Read every day your Vision Scenery everyday, to put up your objectives every day.

Now you know How to Lose Weight Fast, and you know it is within your reach.

Be careful, be focused on it, stick to your process and to good emotions.

Enjoy !

Diet FAQ

I have been asked a lot of questions about the healthy side of loosing weight. This page lists the top dieting questions. I will add pertinent healthy diet questions as they come in. So you might save some time by checking this page before you send an email.

Question: Should I see my doctor before dieting?

Answer: Absolutely! It is important to see your doctor for a consultation before starting any diet and exercise program + PhenQ. Do not run the risk of injury or possible health impairment believing you can move forward without an evaluation by a licensed health care practitioner.

Question: What is the best healthy way to lose weight?

Answer: Have a medical evaluation, reduce your caloric intake and increase your daily physical activity. How much and how fast you lose weight depends on several factors. However, the primary foundation of effective diet programs includes diet and exercise. The diet program I recommend that effectively incorporates these principles is Strip That Fat.

Question: Are all diets really safe?

Answer: The general answer is no. It depends on the type of diet and regimen followed. A high protein and low carbohydrate diet will cause you to lose weight. However, it should be used only for a short term weight loss because of the possible health complications if used long term. The food you choose for protein is very important and what carbohydrates you do use should be high in fiber. If your diet plan does not include all food groups you could miss out on essential minerals and vitamins. If your diet calls for less than 2,000 calories per day it is almost impossible to get all the necessary nutrients.

Question: What diet program do you recommend and why?

Answer: I recommend Strip That Fat because of the foundational strategy is sound and realistic. First, since there may be foods you don’t like, you have the choice to eat the foods you do like. I remember one diet I tried that required you to eat miniature spinach quiches for breakfast. I think that was the last time I held my breath while eating. It was horrible for me.

Next, regardless of your size it utilizes exercise regimens that anyone can do. And since it seems there is never enough time in the day it includes exercises suitable for your busy schedule.

And finally the program focuses on long term weight loss. Oh, you will have significant short term loss, but unlike most diets Strip That Fat will give you long term weight loss and weight management. You can read my full review here.

Question: Can I lose weight without exercising?

Answer: Yes, by reducing your calories, BUT chances are you may gain all the weight back and then some. Been there done that. I lost 20 pounds on a popular diet, not exercising, but surrendered to the temptation of foods I missed and gained back more than I lost in a short period of time. Exercising your bodies large muscle groups is essential metabolic control and weight loss. Regular exercise results in many health benefits aside from weight loss. Choose a diet plan that includes a regimen of exercise and healthy eating.

Question: What is the relationship between metabolism and weight loss?

Answer: Contrary to popular belief a slow metabolism is rarely the cause for excessive weight gain. It is your physical activity and what you eat and drink that determines how much you weigh. Metabolism has to do with processing what you consume and turns it into energy for the body. It combines the calories from you food and drink with oxygen to release the energy your body needs to function. Your basal metabolic rate (BMR) is the number of calories your body needs to do these basic functions. Of course, your size, gender and age are involved in determining your BMR.

Question: Does low thyroid activity affect weight loss?

Answer: Experts tell us that an under active thyroid could be a physiological barrier to losing weight. If so all the popular weight loss programs will not work for you. Regardless how hard you work if you have an under active thyroid you will lose little, if any, weight. The good news about low thyroid activity is it is easily treated. However, undiagnosed and not treated over time problems will arise. A simple blood test by your physician can accurately diagnose low thyroid activity. Symptoms of low thyroid activity include puffy face, hand and feet along with constantly feeling tired & fatigue, mood swings of varying degrees, joint pain and muscle aches, gain weight easily, depressed and anxious, easily irritated, memory problems and not able to think clearly.

Question: Can I eat my favorite dessert and then just burn it off with exercise?

Answer: Not really. There is a well known National League baseball player that would get on the treadmill to burn 300 calories so he could so he could jump off and eat his favorite chocolate chip cookie. Actually, your favorite dessert could equal hours of exercise because of the way carbohydrates are assimilated in the body. The bottom line, it is easier to not eat 300 calories than to burn 300 calories.

Question: What role does water play in weight loss?

Answer: Good hydration is vital to maintaining a healthy body. Choosing water instead of a sugar or caffeine beverage will help you lose weight. Experts say a person should drink at least eight glasses of water a day. For me I believe the volume of water depends on your size and physical activity. The important point is, don’t wait until you’re thirsty to drink…you are already dehydrated at that point. Drinking lots of water helps reduce the feeling of hunger.

Question: Can drinking coffee help me lose weight?

Answer: According to the Mayo Clinic website you should keep in mind that caffeine is a stimulant and too much can cause nervousness, insomnia and other problems. Also, some caffeinated beverages, such as specialty coffees, are high in calories and fat. So instead of losing weight, you might actually gain weight.

Question: How can I get rid of belly fat?

Answer: Your belly or abdominals is comprised of six muscles, five of which are interior and generally not visible; however, all have a function in our trunk area movement and posture. It is the superficial rectus abdominis muscle that gives the six pack appearance when you are physically fit. It can become more defined by doing sit-ups, leg-lifts and other exercises. However, you must remove the fat from your stomach in front of this abdominal muscle so it can be seen. The old adage, ‘you are what you eat’ is never more true than in a regimen to become physically fit. You must learn which foods add fat and which burn fat, when to eat, and how much to eat.

Question: What is “weight cutting”?

Answer: Weight cutting generally refers to the practice of rapid weight loss by athletes before a sporting competition. This is particularly true in sports that have different levels of competition with qualifying weight restrictions. Usually a burst diet is followed and/or water weight is lost just before completing. Nutritionists do not recommend this  for the normal dieter desiring long term weight loss.

An Ultimate Guide to SEO services

Gone are the days when people spend money on the flyers and brochures. Nowadays, most of the people are promoting their business via the online commercial website. It is really beneficial because one will able to increase the sale of a business within a few days. Did you know thousands of international brands are available on Facebook and Instagram? With the help of a business page, they are promoting their business. It is really beneficial because one can create a strong presence of a business. Therefore, you should always hire an SEO professional for further tasks.

SEO contains a lot of things such as white hat, Blackhat and Gray hat services.  Most of the professionals are making the use of white hat services that is a little bit slower but improving the rank of the website genuinely.  Let’s discuss the important details about SEO services.

  • The big picture

Are you familiar with SEO services? Nowadays, SEO has become an integral part of every website. It is really beneficial that will optimize your official website properly. Within a few days, you will grab your website in the Frontpage.  All things depend on the relevance, like if professional is posting the organic content on the official website then surely it will attract a lot of viewers.

  • Authority of the domain

It is one of the most important tasks that will give you an estimate about ranking.  It is really beneficial that is known as the proprietary score. Most of the users of the website are checking the Authority of the domain. If you have a strong authority of domain, then you can attract more traffic. All things depend on the quality links. It would be beneficial during the guest post articles.

  • On-site Optimization

It is the main part of the SEO services. With the help of onsite optimization, one will able to witness the improvement in ranking. Make sure that you are using the best keyword that is related to your website. After that, one has to post the relevant or organic content on the official website. However, if you don’t have knowledge about SEO services, then would be a beneficial website for you.

  • Link building

In some respects, most of the people are making the use of Link building articles. It is the best option that will attract traffic from the other website.

Apart from that, you should always use white hat SEO techniques because it will improve the rank within a few days.

Texas Legislature Might Make Bad Loser Pays Bill Even Worse

On December 15, I posted about a bill proposed by Texas Governor Rick Perry to force a losing plaintiff in a civil suit pay all legal costs for the defendant, a revolutionary step away from the American rule, in effect for over 200 years, to the British rule of “Loser Pays.” I discussed the reasons why Texans should reject such a move. Now I hear that the Texas legislature might make a bad bill even worse. Attorney Steve Waldman of Houston sent the following to his e-mail list this week:

The initial “Loser Pays” bill applied only to “abusive civil actions.” However, a jury finding against a plaintiff might also find the lawsuit “an abuse of the civil justice process,” which was all it took to bankrupt both the plaintiff and his lawyer. Such a law would scare plaintiffs with legitimate claims away from filing lawsuits. The new version of “Loser Pays”… permits defendants to recover their litigation costs in all lawsuits, not just “abusive civil actions.” It throws small businesses under the bus by including breach of contract cases. The new law also allows for unlimited recovery of costs against winning or losing plaintiffs, meaning a plaintiff can win a lawsuit and owe the defendant money! Any plaintiff – winner or loser – can be forced into bankruptcy!

Steve sent me the original version of the bill, and the newer (and worse) version. I invite Texas attorneys and other “7th Amendment advocates” there to review the bills, then contact your state representatives and tell them to reject the entire concept. It’s a smack in the face of the Founding Fathers’ vision for the right to have a local jury hear a citizens’ claims, since it erects economic barriers to the filing of a suit. I’ll bet Texas doesn’t make it more expensive for its citizens to bear arms in self-defense!

The other strange aspect of this issue in Texas is the inaction of two important groups of attorneys in Texas. First, the state bar association hasn’t issued an official statement for or against the bill; and second, the official association of Texas defense attorneys seems to be all over the ballpark on it. The defense attorneys were against the original bill but are apparently happy with the revised version. Little do they realize that “tort reforming” away civil suits not only abridges unalienable rights, but eventually reduces the need for defense attorneys.

And where are the Tea Party groups in Texas? Why aren’t they raising hell about the business community stripping Texans of their rights?!

I’ve already posted several times on the impact of limits in Texas law on medical malpractice lawsuits. A sweeping “Loser Pays” statute is a clear and present danger to Texans, and they should tell their legislators to reject it.

Victims of Iranian Terrorism Urge Senate to Hold Iran Responsible for Murder of 241 American Servicemen

There is ONE bill in the U.S. Senate that takes $1.8 billion of Iran’s funds stored in a U.S. account and reserves them to compensate Iran’s American terrorism victims. The Iran sanctions bill now under consideration by the Senate has one special section, co-sponsored by Senators Mark Kirk and Robert Menendez and supported by Senators of both parties. Section 503 would compensate the American victims of Iranian terrorism and keep Iran from using the funds to build nuclear weapons and fund terrorism. But a big Wall Street firm is working behind the scenes to stop the Senate from helping the victims. The families of our servicemen killed or wounded by Iranian terrorism need your help!

Some history: Iranian terrorists killed 241 of our servicemen, and injured many more, in the 1983 bombing of the Marine Corps barracks in Beirut, Lebanon. For years, the 1300 survivors and families of those killed have sought justice in American courts for that attack, and were ultimately awarded a judgment in federal court of over $2.6 billion against Iran. Their attorneys then identified and attached an account of $1.8 billion in Iranian central bank funds in a bank in NYC to satisfy that judgment. Then the families of the servicemen killed in the 1996 Iranian bombing of the Khobar Towers in Saudi Arabia won a judgment and now stand to share in that account.

But without special legislation, the order freezing the funds could be lifted, possibly enabling Iran to recover the money. Lynn Smith Derbyshire, whose brother was killed in the barracks bombing and is now national spokesperson for the Beirut Marine families, says, “The Government of Iran will continue to do everything it can to hurt Americans. We see no reason to enable Tehran’s campaign of terror. Allowing the Iranian Government to get this frozen money back would do just that.” Section 503 of the Iran sanctions bill, which is numbered S. 2101, was approved by the Senate Banking Committee on February 2 and awaits Senate floor action.

But a Wall Street powerhouse, the Depository Trust and Clearing Corporation (“DTCC”), opposes Section 503 and is trying to kill it behind closed doors. DTCC works with financial institutions from around the world to ensure that financial transactions clear smoothly and quickly. But one of DTCC’s business partners is Clearstream, a European financial institution at the heart of the transfer of Iran’s funds into New York City. Intentionally or not, DTCC is, in effect, trying to help Clearstream recover the $1.8 billion in Iran’s funds, by sending high-priced Washington lobbyists into Congressional offices to “amend” the bill. Their “amendments” could actually kill the families’ pursuit of justice and enable Iran to recover the $1.8 billion.

It’s time for the Senate to shut the door on DTCC and support the families of our terrorism victims. No other bill before the Senate actually takes Iran’s money and reserves it for Iran’s American victims. The Beirut Marine families are urging Americans to contact Senators to support Section 503 of S. 2101 without DTCC’s “poison pills” and approve it in the Senate quickly.

Religious Liberty Isnt Subject to Obamas Fairness Doctrine

Catholic churches and Catholic-based social services groups have filed lawsuits throughtout America to defend religious liberty from President Obama’s mandate to pay for abortion-inducing, baby-killing drugs, in violation of official Church teachings. For the first time in American history, a President is trying to impose a narrow definition of “religious institution,” in order to implement a political agenda. The definition could force the closure of Catholic-based services organizations, such as AIDS clinics, schools, and hospitals. If successful, the mandate would serve as the template for Uncle Sam to define any religious organization as it sees fit, and dictate hiring, financial, and all organizational decisions.

All this is lost on Obama, who apparently sees his mission as telling the churches and all of the religions in the U.S. how to operate or face closure. Now he has created, out of thin air, a new constitutional standard for religious liberty. In an interview with a New Orleans TV station, Obama said it’s “not fair” for the Catholic Church to deny abortion-inducing, baby-killing drugs to its employees. Somehow this former professor of Constitutional law thinks that he can dictate a Fairness Doctrine on Catholics and any other church in America. Where did he make this up?

Our Founding Fathers must be rolling over in their graves. They knew that religious liberty was the reason why many left England, and in the First Amendment they defended the right of all faiths to practice in accordance with their own doctrines. And they practoced what they enshrined in law. The first Catholic Bishop in the U.S., John Carroll, was a close friend of George Washington and sought, at Washington’s request, to persuade the French to provide assistance to the colonies seeking freedom from England. And Washington, though not a Catholic, donated the first funds to build the first Catholic church in Alexandria, Virginia, near his home at Mount Vernon.

Fortunately, the Founders created a civil justice system and protected the right to seek justice before a local jury. Many of the Catholic groups have exercised that right, protected under the Seventh Amendment to the Constitution, to ask a local jury to hear their cases. They don’t want to entrust their precious, God-given right to a federal judge nominated by any President.

Senate Bill Amends Some Maritime Liability Limits But Still Obstructs 7th Amendment Rights

The most recent Senate proposal to change maritime liability limits in response to the Deepwater Horizon disaster is a departure from the clear lifting of maritime liability immunities that the U.S. House passed on July 1 through the “SPILL Act,” H.R. 5503. In an effort to persuade Senators from those states with strong commercial shipping and fishing interests, Senate leadership introduced S. 3663, the Clean Energy Job and Oil Company Accountability Act of 2010, which folds changes in maritime liability law into a broader energy bill. First, the good news about those sections in the Senate bill that end decades of discrimination between sea-based and land-based accidents:

1. The bill amends the Death on the High Seas Act to enable families to recover non-pecuniary losses, such as for the loss of a loved one and a decedent’s pre-death pain and suffering, for victims of negligence on sea-based oil rigs and cruise ships. Victims of land-based oil rig accidents have never faced the federal limit in DOHSA suffered by sea-based victims, and this bill would end the inequitable treatment.

2. The bill repeals the maritime punitive damages ratio established in Exxon Shipping Co. v. Baker, 128 S.Ct. 2605 (2008), which unfairly limited punitive damages in general maritime law to a 1:1 ratio with compensatory damages.

3. The bill exempts oil spill claims from the liability limit under the Limitation on Liability Act.

Now for the bad news:

1. The Senate bill leaves the Jones Act intact and doesn’t enable seamens’ surviving family members to recover noneconomic damages for loss of care, comfort and companionship. This unfairly discriminates between workers in land-based shipping, who face no artificial federal liability limit, and seamen, who would continue to see their 7th Amendment rights obstructed by this special interest legislation.

2. The Senate bill completely exempts commercial fishing from any change in liabilitity limits. The CDC annually reports that commercial fishing is the most dangerous job in America, yet the bill discriminates against them. Commerical fishermen would thus also continue to see their 7th Amendment rights obstructed.

3. The bill doesn’t repeal LOLA, not even for personal injuries and wrongful deaths,but merely increases the liability limit to an amount equal to three times the value of the vessel. But a maritime oil rig is completely worthless after it sinks, as indicated in a federal court filing by Transocean, claiming a rig value equal only to the costs of raising it from the ocean floor. By not repealing LOLA, the bill leaves open the possibility that the families of Deepwater Horizon workers killed in the rig explosion will receive no compensation. In essence, they might be able to exercise their 7th Amendment rights, but without an equitable remedy.

Few or no Republicans support S. 3663, because of the energy legislation in it. A month after seeing a voice vote on the floor of the House in support of the SPILL Act, we now have little momentum to pass this Senate bill or any other which would assist the BP victims and end the discriminatory maritime liability limits, a huge letdown. Here is a summary of the bill and a section-by-section analysis.

Sen Rand Paul Clarence Thomas 10th Amendment Advocates Agree on Commerce Clause Abuse

When he addressed conservatives at CPAC last week, Sen. Rand Paul discussed the abuse of the Commerce Clause is at the heart of the pro-tort reform movement, and which is on view again especially this week with the continued markup of H.R. 5 by the House Judiciary Committee. Here are Sen. Paul’s comments:

Early on in my campaign I stopped by a book publisher in Shepherdsville, Ky. It’s near Louisville. This book publisher had published Barry Goldwater’s “The Conscience of a Conservative,” the first edition… Barry Goldwater mentions one Supreme Court case in that book: Wicker v. Filburn, many know it. A farmer in California wants to grow 20 acres of wheat. The government says you can only grow 10 acres of wheat. He said, by what authority do you tell me this? And they say, the Commerce Clause, and he said, well, I’m not even going to sell the wheat. I’m going feed it to my cattle, and they say to him, well, by your inactivity, by not doing anything, can you indirectly affect the price of wheat, and they enforce this. That ruling was in the ’40s. For 60 and 70 years now we’ve been working with this notion that the Commerce Clause says that our government can do anything. Until Obamacare came along.

They scoffed at us when we said it wasn’t constitutional. Nancy Pelosi looked like a deer in the headlights; she couldn’t believe that anyone would question the constitutionality. Judge Napolitano asked Representative Clyburn about the constitutionality and Representative Clyburn readily admitted, most of the things we do in Washington have no constitutional authority. It is amazing and appalling.

This Supreme Court case that will be more, about much more than health care. It’s going to be about whether or not we believe that our government should be restrained by the Constitution. I think for 60 or 70 years we’ve been gradually going down this road of becoming more of a majoritarian rule, a democracy. Jefferson said democracy would be nothing more than a mob rule. Our Founding Fathers knew the difference between a republic and a democracy.

Our understanding of the Commerce Clause has become so broad that I often will say, if my shoes were made in Tennessee, they’ll regulate my walking in Kentucky. Recently Senator Coburn in one of the committee hearings asked Elena Kagan, he said, well, do you think the government through the Commerce Clause could regulate you eat three vegetables a day? Her response was, yes. (Emphasis mine.)

Sen. Paul identified himself with a small but growing body of conservative thought that recognizes that the Commerce Clause has become a sledgehammer of excessive power wielded from Washington. As I wrote on January 13, Supreme Court Justice Clarence Thomas voiced his concern when writing a dissent to the Supreme Court’s decision to not hear a case on point, in which the Commerce Clause was used as the basis to criminalize the purchase of body armor by those convicted of violent felonies. Wrote Justice Thomas, “Congress arguably could outlaw ‘the theft of a Hershey kiss from a corner store in Youngstown, Ohio, by a neighborhood juvenile onthe basis that the candy once traveled . . . to the store from Hershey, Pennsylvania.’.. The Government actually conceded at oral argument in the Ninth Circuit that Congress could ban possession of french fries that have been offered for sale in interstate commerce. Such an expansion of federal authority would trespass on traditional state police powers.”

States’ rights advocates are seeking more aggresive action to defend the 10th Amendment from the overreach of the Commerce Clause. The Tenth Amendment Center is trumpeting a new bill introduced in the Arizona state legislature which would attempt to nullify the Commerce Clause altogether. “If passed by the Arizona State Legislature and signed by the governor, SB 1178 will amend the Arizona Revised Statutes in order to provide that all goods grown, manufactured or made in Arizona and all services performed in Arizona, when such goods or services are sold, maintained, or retained in Arizona, shall not be subject to the authority of the Congress of the United States under its constitutional power to regulate commerce.” That’s an amazing step, essentially an act of civil disobedience, and symptomatic of a rising tide of disgust over the loss of states’ rights.

But it’s not enough yet. A majority of Americans say that they don’t want the Commerce Clause to be used as a basis to compel ObamaCare. But what many Americans, especially in the business community, still don’t recognize is the abuse arising from the flip side of the Commerce Clause: the abuse of basic rights arising from applying the Commerce Clause to prohibit/pre-empt action by the states, to the point of abridging the right to civil jury trials (the 7th Amendment) and states’ rights (the 10th Amendment).

No issue demonstrates the disconnect among mainstream Republicans than the medical malpractice movement, personified by H.R. 5, which would sharply limit all health care lawsuits (not just medmal suits) against a wide range of companies (not just doctors). When Rep. Hank Hohnson challenged Judiciary Committee Republicans to stand up for the 7th Amendment during last week’s debate on H.R. 5, one Republican, Rep. Bob Goodlatte, asserted that the Supreme Court had already decided that there was no conflict, which was really a retreat to stare decisis. But most of the committee’s Republicans wouldn’t hesitate to override Supreme Court decisions counter to their views on abortion, prayer in public schools, and the “establishment of religion” clause. Movements like the Tea Party groups and the Tenth Amendment Center are all about overturning long-held political and judicial doctrines in favor of a return to Constitutional principles.

As long as H.R. 5 advances through the House, Republican leaders will be unable to claim that they’re intent on curbing the Commerce Clause and on restoring the primacy of the Bill of Rights.

Washington GOP Traps Romney With Big Oil Protection Bill

Mitt Romney will be the Republican nominee for President, but he can’t stop the “Washington GOP” from putting him in an untenable position on various issues. For instance, Republicans in both houses have introduced bills which would protect all oil companies, domestic and foreign, from any liability for deadly accidents from the rig to final distribution. The sponsors of the bills (the Senate’s “Domestic Fuels Act,” S. 2264, and the House companion bill, the “Domestic Fuels Protection Act,” H.R. 4345) want us to believe – they guarantee – that the bills would not discharge Big Oil, including Big Foreign Oil, from deaths and injuries due to negligence. But the language of the bills say otherwise. For instance,

1. As long as a storage tank meets new EPA regulations or guidelines, no entity can be held liable under any federal, state, or local law.

2. The bills give complete immunity to all fuel corporations if a claim is based on the fuel being put into an engine. This immunity extends to every entity on the petroleum chain of commerce, including entities that design, manufacture, sell, distribute or store fuel, fuel additives, blend stocks, vehicles, engines, and non-road equipment.

3. These bills wipe out state and federal consumer protection laws and state product liability laws. Even if injured consumers prove that the product is dangerous and defective and caused catastrophic harm, the manufacturers and retailers will be completely immune, even if they intentionally or recklessly expose consumers to serious health risks.

Once again, the Washington GOP is trying to force legislation through the Congress that would ignore and crush the states’ rights to run their own civil litigation systems and compromise Americans’ 7th Amendment right to a civil jury trial. Additionally, I don’t understand why the Washington GOP wants to extend total immunity to foreign oil companies, especially Hugo Chavez’ nationalized oil company, which Chavez uses to raise revenues for his nefarious ventures and to crush democracy in Venezuela.

The Washington GOP has trapped its new Presidential nominee by forcing him to defend a special protection bill for Hugo Chavez and domestic oil companies while Americans are being hammered by record-high gas prices. I’m as pro-oil production as any Republican, and Republicans have already aggressively pursued legislation to promote increased oil production in the U.S. These bills are unnecessary and unwise, both legally and politically.

Rob Natelson Proves Founding Fathers Opposed Federal Takeover of State Tort Law

In their zeal to adopt a federal malpractice reform bill to dictate procedures to state courts, many Republicans in Congress are doing precisely what they rightly accuse Democrats of doing: blithely disregarding the Constitution’s clear limits on federal power.

Their proposals, once encapsulated in H.R. 5 and then slipped into the Senate Republican “jobs bill,” not only violate the true meaning of the Constitution, but also likely run afoul of such modern Supreme Court cases as New York v. United States and Printz v. United States, which voided efforts to impose unfunded federal mandates on state officials. The same Virginia attorney general who brought the first suit against Obamacare has threatened to challenge this measure in court as well.

The effort to impose federal control over state courts and state civil justice violates one of the core principles of our federal system: That most judicial matters are local. Keeping courts and procedures local is, in fact, a crucial protection for individual liberty.

As I show in my new paper, “The Roots of American Judicial Federalism,” one of the chief causes of the American Revolution was the British effort to undercut local courts by centralizing the administration of justice. As I also explain, after the Revolution Americans deliberately enshrined the local-control principle in our Constitution.

In other words, medical malpractice reform, like most other aspects of civil justice, is a matter for state, not federal, law. (Emphasis added.)

So wrote Rob Natelson, Senior Fellow in Constitutional Studies at the Independence Institute in Colorado, in a post titled, “Congress, Butt Out! The Constitution Reserves Malpractice Reform for the States” to introduce his newest research study, The Roots of American Judicial Federalism. Rob Natelson is one of the most respected constitutional scholars in America; was Montana’s best known political activist — leading, among other campaigns, the most successful petition-referendum drive in Montana history — and in June 2000, was the runner-up among five candidates in the party primaries for Governor of Montana.

The Roots of American Judicial Federalism is not Rob Natelson’s first foray into the federal medical malpractice debate. In April, he became the first of a long line of conservative and Tea Party-side activists and scholars who oppose federal medmal laws on federalism grounds. In his letter to Congress, he spelled out the constitutionally based objections to H.R. 5, the primary bill desired by the medical groups to limit all health care lawsuits, including those filed for medical malpractice. “H.R. 5 flagrantly contravenes the limitations the Constitution places places upon Congress, and therefore violates both the Ninth and Tenth Amendments. H.R. 5 is purportedly an exercise of the Constitution’s Commerce Power. Yet as I shall explain, its subject-matter–civil actions in federal and state courts–is not within the Constitution’s meaning of ‘Commerce.’ Nor can H.R. 5 be justified under the Necessary and Proper Clause as incidental to the regulation of interstate Commerce.”

In the opening page of Roots, Natelson explains that the Founding Fathers were committed to reserving tort law for the states, even years before the drafting of the Constitution.

In drafting the Constitution, the Framers provided for additional federal judicial authority. Like the post-1768 pre-Revolutionary pamphleteers, however, they rejected proposals for a central government with power over all activities with inter-jurisdictional impact. Instead, they limited federal authority to items specifically enumerated. Reserved to the states would be nearly all the authority they had exercised previously, including power over state court procedures and over existing areas of substantive jurisdiction. With a few exceptions, therefore, the states were left in exclusive possession of the law of torts, contracts, inheritance, property, and criminal law.

When the Constitution became public in September, 1787, opponents argued that the Constitution could be construed to permit Congress or the federal courts to exceed prescribed limits. They contended that the new government might interfere with criminal and civil justice within the states. The Constitution, they said, should be rewritten to prevent manipulation of its terms by legal “sophistry.”

To quiet such apprehensions, the Constitution’s proponents explained to the ratifying public that the Constitution, if adopted, would grant only restricted authority to the new government. The Constitution’s proponents listed for the ratifying public numerous areas in which the federal government would have no power and the states would enjoy exclusive power. Among the areas listed were several pertaining to state judicial systems.

The remainder of the study reveals the detailed writings of the Founding Fathers in support of judicial federalism. Professor Natelson quotes them time and again, including in letters and pamphlets that many Americans have probably never read before:

Like earlier authors, the writers of the 1774 pamphlets emphasized that judicial matters should be administered locally. In his Novanglus, (John) Adams pointed out that the dispute between colonists and the British government was not limited to taxes:

“Is the threepence upon tea our only grievance? Are we not in this province deprived of the privilege of paying our governors, judges, &c.? Are not trials by jury taken from us? Are we not sent to England for trial? Is not a military government put over us? Is not our constitution demolished to the foundation?”

Alexander Hamilton, in A Full Vindication of the Measures of Congress, agreed:

“Give me the right to be tried by a jury of my own neighbors, and to be taxed by my own representatives only. What will become of the law and courts of justice without this? The shadow may remain, but the substance will be gone. I would die to preserve the law upon a solid foundation; but take away liberty, and the foundation is destroyed.”

Professor Natelson discusses the assurances that delegates to the Constitutional Convention gave to the public that the right to a civil jury trial would not be abridged:

At the New york convention, Hamilton underscored exclusive state jurisprudence over internal state administration, arguing that state powers are “civil and domestic–to support the legislative establishment, and to provide for the administration of the laws.” He added that:

“Were the laws of the Union to new-model [reform] the internal police of any state; were they to alter, or abrogate at a blow, the whole of its civil and criminal institutions; were they to penetrate the recesses of domestic life, and control, in all respects, the private conduct of individuals,–there might be more force in the objection; and the same Constitution, which was happily calculated for one state, might sacrifice the welfare of another.”

Chancellor Robert R. Livingston assured the convention that state power over traditional areas of judicial power was exclusive:

“They tell us that the state governments will be destroyed, because they will have no powers left them. This is new. Is the power over property nothing? Is the power over life and death no power? . . .In one word, can [Congress] make a single law for the individual, exclusive purpose of any one state?”

Natelson concludes by discussing the fight to recognize the right to a civil jury trial and the states’ right to run their own civil justice systems through a Bill of Rights.

Federalists had to go beyond representing the meaning of disputed provisions. They also had to promise that they would support a bill of rights once the Constitution was ratified. Five of the 11 ratifying state ratifying conventions had accompanied their approval with suggested amendments. The two states that thus far had refused to ratify, North Carolina and Rhode Island, determined to stay out of the union until a bill of rights was proposed.

Among the restrictive amendments were some restraining the federal judiciary. Thus, the Fourth Amendment regulated judicially-issued warrants, the Fifth barred double jeopardy, the Seventh prescribed jury trial in civil cases, and so on. The Ninth and Tenth Amendments were the declaratory amendments. They highlighted the limited scope of federal powers, including federal powers over judicial matters.

Although the Ninth Amendment is widely misunderstood today, its principal role was as a protection for federalism, including judicial federalism. It affirmed that Congress was no more able to impair the independence of the state judiciaries after adoption of the Bill of Rights than had been true before adoption.

The Tenth Amendment, based on the most popular proposal from the states, reinforced that whatever was not given was reserved. It may have been targeted specifically against claims raised during the Confederation period that, despite the Articles’ limits on congressional power, Congress enjoyed additional “inherent” authority merely by virtue of being a sovereign.

In other words, both the Ninth and Tenth Amendments rendered explicit the Constitution’s implicit restraints on Congress and the federal judiciary, as explained by Federalist essayists during the ratification debates. Both amendments protected the exclusive sphere of the states, including the integrity of the state courts.

Rob Natelson’s study is a enormously revealing and powerful paper that will assist real constitutional conservatives in their fight against the federal takeover of state courts. The tort reform movement finds itself without intellectual ammo, and cannot cite any writing from the Founding Fathers in support of their positions (I’ve offered free dinner on that). I will post quotes from this outstanding paper throughout the coming weeks.

Sen Tom Coburn Splits With AMA Medical Groups Over Federal Tort Reform Bills

An article in today’s “Roll Call” newspaper, which covers Congress, discusses the extensive influence that Sen. Tom Coburn has over members of the debt reduction “supercommittee” charged with finding over $1 trillion in federal budget cuts ovr a ten-year period. It appears that Sen. Coburn’s own “Back to Black” deficit reduction plan, which he released in July, is the basis for many pollicy proposals under consideration by the supercommittee.

That could be a positive development in the fight to protect each state’s right under the 10th Amendment to the Constitution to run their own civil justice systems and each American’s right under the 7th Amendment to seek a jury trial for civil suits, including medical malpractice lawsuits. Sen. Coburn’s “Back to Black” plan doesn’t call for unconstitutional federal tort reform in any way. Instead it relies on the states to manage their own legal systems, and specifically enables any injured patient to take a medical malpractice case to state court. Sen. Coburn also recognizes the terrible toll on patients as a result of deadly medical errors.

Sen. Coburn recommends that the federal government fund expert panels and health courts to resolve medical disputes, ideas implemented in some states and which do not, in practice, always protect a patient’s rights. But it preserves the patient’s right to access the state court system at any point; the state panels and health courts aren’t a mandatory step. The Senator disagreed with federal tort reform solutions on constitutional grounds in an interview posted on June 30, and this plan is consistent with his objection. I’m not endorsing the plan, but at least it protects our constitutional rights from federal “tort reform” efforts.

In contrast, the American Medical Association and numerous medical groups are asking the supercommittee to squash our constitutional rights and grant total immunity to medical professionals from their errors. They sent a letter to the supercommittee that ignores the clear consensus against federal tort reform by respected conservative legal experts such as Professor Randy Barnett; longtime tort reform proponents Walter Olson and Ted Frank; Republican Members of Congress such as Sen. Coburn and Reps. Ted Poe, John Duncan, and Ron Paul; and the largest association of state legislators in the country. Rolling over the Constitution and Bill of Rights is nothing new for the AMA and most of their fellow medical lobbying groups, the co-conspirators in the enactment of ObamaCare, with its equally unconstitutional individual mandate to buy health insurance.

The Founding Fathers’ insistence on individual liberty and state sovereignty over their legal systems means nothing to “Big Medicine.” They’re the walking definition of “Crony Capitalism” for continuously lobbying for national health care with total civil immunity. Limits in the Constitution on the enumerated powers for the federal government, and the 7th and 10th Amendments, are mere bumps in the road for the AMA and their cronies, which wants to interfere in local health care and tort law decisions so they can shape and manage our lives. There’s nothing “constitutionally conservative” about federal “tort reform” laws which would ignore the Founding Fathers, shut down local juries, and deprive Americans of our unalienable rights. The supercommittee should reject these blatant attempts by Big Medicine, and instead seek real reductions in the federal deficit.

Tort Reform Movement Again Confronts Social Conservatives

One of my primary themes here is to remind readers that the Founding Fathers honored and protected the civil litigation process for all types of civil suits, including those filed by my friends and allies in the social conservative movement. The 7th Amendment protects the right to a jury trial for civil suits for standard tort claims arising from accidents, defective products, and medical malpractice… and that right also protects our religious liberty, gun rights, property rights, and so on. One of the points I make with my conservative friends is that “the tort reform movement is coming for you” in ways they would never imagine. This week, we might have the third instance in two years, and the second this year, in which tort reform confronts social conservatives.

In a 5-4 decision in the Pliva vs. Mensing case, the Supreme Court ruled that federal legislation regulating generic drugs pre-empts state law, effectively immunizing generics from state court cases. The decision also leaves generics in a favorable legal position compared to brand-name drugs, since the Court decided in Wyeth vs. Levine two years ago that the federal law regulating brand-names doesn’t pre-empt state law, a point that Justices acknowledged in the Mensing decision. As generics constitute upwards of 70% of all drug sales, the Mensing decision marks a major step forward in the tort reform movement’s campaign to eliminate lawsuits immediately upon FDA approval.

For the pro-life movement, this raises the specter that the makers of generic forms of RU-486, the “morning-after pill,” can count on federal pre-emption to immunize them from civil suits over the pill’s dangerous side-effects. So the Mensing decision may have created a permanent safe harbor for generic RU-486, foreclosing an important tool in the pro-life movement’s fight to ban RU-486. As I posted on August 28, 2010, trial lawyers have assisted the pro-life and womens’ health causes for decades, by pursuing dangerous abortifacients, unsafe drugs, and defective medical devices, all approved by a FDA asleep at the switch. Civil suits might be the last line of defense for champions of the unborn against the new wave of abortifacient technology, but not if the technology is immunized through pre-emption in federal law.

This comes after the Supreme Court decisions in the Iqbal and Twombly cases, which also impact social conservatives, especially those who litigate on behalf of their causes. I’ve written often on those cases and the potential impact on all plaintiffs. The Alliance Defense Fund wrote an important letter in early 2010 to Congress over its concern that the decisions could threaten every American’s religious liberty through imposition of an uncertain “plausibility” standard, which invites “defensive lawyering” and subjective dismissals of complaints by individual judges.

And the House Judiciary Committee is still preparing to act on H.R. 966, the “Lawsuit Abuse Reduction Act,” the tort reform movement’s bill to unnecessarily impose sanctions on plaintiffs’ attorneys as a means of preventing lawsuits. As I wrote on March 10, “LARA” could “scare away nonprofits or small firms specializing in religious liberty cases from filing suits against large entities, for fear that a judge could impose costly sanctions.rights to protect religious liberty against infringement by various parties.” If “LARA” had been in effect last year, social conservatives might not have filed a lawsuit that forced the University of Illinois to back down from threatening to fire a professor for discussing Christianity in his history class.

Social conservatives should look over their shoulder; the tort reform movement is coming for them, case by case.