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Tort 26

Tort 26


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Cocoa wheat:

Mix eggs with sugar until they triple in volume and light in color. Mix the flour with the cocoa and then sift it. Add 2 tablespoons of the solid mixture to the liquid and mix at medium speed. We do this until we finish incorporating the whole solid mixture. Pour the composition into a 19 cm tray, lined with baking paper and leave it at 170 degrees C for 20-30 minutes. We check the worktop with a toothpick.

Chocolate mousse:

Mix the whipped cream and then let it cool. Prepare the gelatin according to the instructions on the package. I melted the gelatin granules in the microwave. In a small saucepan, put the whipped cream on the fire. We leave it until it is hot. It doesn't have to boil. Add the broken chocolate to the pieces and mix it with a whisk until it melts. Add gelatin and mix a little more. Take the chocolate off the heat and let it cool. When it has cooled, put it in the fridge for 20-30 minutes. We take out the chocolate cream and mix it. Incorporate the whipped cream into the chocolate cream. Cut the worktop into 3 sections. We syrup the first section. Add 1-2 tablespoons of cream. We stretch evenly. We add the second section of the countertop that we syrup. Put 1-2 tablespoons of cream. We also syrup the last section. Leave the cake in the fridge overnight. The next day, we coat the cake in butter cream (mix 300 g butter + 120 g powdered sugar). I colored the butter cream with a little pink dye. Sprinkle powdered sugar on the work table and spread the sugar paste with a rolling pin. We cut circles of different sizes. Melt the chocolate in a bain-marie. We leave it for 3 minutes after it has melted, and then we pour it on the surface of the cake and let it flow easily. Let it harden. We decorate with edible roses (I used natural ones, because I didn't find edibles), candies, chocolates and colored circles. I cut the cake slices harder because the white chocolate hardened. Even if the slices were harder to cut, I was very happy with this decor and I will repeat it.


Cake 26 - Recipes

Fried nuts.

This is a wonderful taste of nuts, delicate pastry and charming aroma. Each family has its own recipe for doing this cake wonderful. Someone prefers a walnut, a hazelnut or an almond.

    • Eggs 8 pcs.
    • 200g sugar
    • Flour 400g
    • 300g butter for the dough and 100g for the filling
    • ½ box of boiled condensed milk
    • Soda Soda (Soda + Vinegar)
    • Nuts 200g
    • vanillin
    • cinnamon to taste

    1. Sand the flour through a sieve or a small-hole hammer so that there are no lumps.

    2. Make a burnt soda: a third of a teaspoon of soda mixed with vinegar, soda with the sauce should dissolve.

    3. Place the nuts with a coffee grinder or rolling pin. The pieces should be small, they should not turn into powder.

    4. If you use almonds, they should be cut into thin slices.

    5. Do not be upset if you have regular condensed milk in your arsenal. Put the jar in a pot of water and cook for 1, 5 - 2 hours, when you bake the cakes, it will be ready.

    1. Beat the eggs with the sugar until a fairly thick mass is formed with a mixer.

    2. Soften a little with a spoon (it can be easily heated, but not completely melted) and add the eggs with sugar.

    3. Add flour with constant stirring, add hydrated soda and 1/3 of the nuts, if you want you can put raisins in the same place. Stir until soft.

    4. Divide the dough into 3-4 pieces, depending on how many cakes you want to get as a result.

    5. Grease a baking sheet or pan with sunflower oil. Sprinkle with flour so that the dough does not burn. Spread the pieces of dough evenly. After 15-20 minutes at an oven temperature of 200 ° C, remove the cake and place a new one.

    6. Check the preparation of the cakes, piercing them with a toothpick or a match, the dough should not remain.

    7. As a result, you will get 3-4 red cakes.

    1. Remove the butter, add the remaining nuts, condensed milk, vanilla sugar (one bag is enough) and half a tablespoon of cinnamon. Mix well.

    2. Spread each cake filling, for beauty you can sprinkle powdered sugar over the cake.

    3. To keep the filling from leaking and freezing, refrigerate the cake for a while.

    Eat cold. Enjoy your tea!

    For such a sweet, amazing cake, any perfect fruit or black tea.


    Simple cake top

    I do not claim that it is perfect simple countertop recipe for cake but this option seems very easy to do, following a few simple steps.

    Good luck to you and Happy Birthday to all!

    I hope that in the new year all your wishes will be fulfilled and that you will have only good things.

    The holidays are gone, the holidays are the same and we are slowly resuming our usual rhythm.

    Among the following recipes you will find some that we have prepared for the holidays, they will certainly be useful for the following, salads, light meals, with meat, vegetables and basic recipes, simple and easy to prepare as it is today.

    First of all, the ingredients must be kept for two hours at room temperature, to be fresh and the utensils we will use to be washed and degreased well.

    • After mixing the eggs with the sugar, the flour sifted beforehand will be easily incorporated, with slow movements from top to bottom, so we will obtain a fluffy, slightly aerated top.
    • We do not use any growth agent (baking powder, baking soda & # 8230) on this countertop because it will influence the final shape.
    • The oven must be preheated, and after baking we do not remove it immediately, but we open the door, and leave it there for about 10 minutes. Only then remove the form and let it cool completely to room temperature.
    • The top is cut when completely cold, with a serrated bread knife, with a very thin blade.
    • If we want a top with cocoa, reduce the amount of flour and complete with cocoa, do not add fish.
    • We can flavor the top with various essences, coffee extract, vanilla, lemon peel, orange, lime. Depending on our taste and the type of cake we chose to make.

    • flour - 470 grams
    • eggs - 1 piece
    • condensed milk - 1 can
    • soda - 1 teaspoon.
    • egg - 2 pieces
    • milk - 500 milliliters
    • sugar - 1 cup
    • vanilla sugar - 1 piece
    • butter - 200 grams
    • flour - 2 tbsp
    • nuts for decoration - 1 cup.

    A cake that is cooked without an oven. Step by step recipe

    1. First, prepare the cream. In a saucepan, mix the milk, eggs, flour and regular vanilla sugar. Bring to a simmer, stir until the cream thickens and remove from the heat.
    2. In the cream, immediately add the butter and mix. Cover the pan with a lid.
    3. Mix condensed milk with egg and chopped soda. Slowly add the sifted flour and mix well.
    4. Knead the dough, divide it into pieces and roll. About 8 o'clock.
    5. Put the pan on the fire and grease with butter. Fry all the cakes in a row. It bakes very quickly.
    6. Put cakes on the bowl, grease with cream, if there are leftovers from unevenness, chop them with nuts and crush them on top of the cake.

    Give the cake a small infusion and you can continue to consume spiritual tea. And be sure to try a three-layer truffle cake without oven and original TOP-5 toast.


    2010 Georgia Code TITLE 50 - STATE GOVERNMENT CHAPTER 21 - WAIVER OF SOVEREIGN IMMUNITY AS TO ACTIONS EX CONTRACTU STATE TORT CLAIMS ARTICLE 2 - STATE TORT CLAIMS § 50-21-26 - Notice of claim against state time for commencement of action examination of records to facilitate investigation of claims confidential nature of documents and information furnished

    O.C.G.A. 50-21-26 (2010)
    50-21-26. Notice of claim against state time for commencement of action examination of records to facilitate investigation of claims confidential nature of documents and information furnished


    (a) No person, firm, or corporation having a tort claim against the state under this article shall bring any action against the state upon such claim without first giving notice of the claim as follows:

    (1) Notice of a claim shall be given in writing within 12 months of the date the loss was discovered or should have been discovered provided, however, that for tort claims and causes of action which accrued between January 1, 1991, and July 1 , 1992, notice of claim shall be given in writing within 12 months after July 1, 1992

    (2) Notice of a claim shall be given in writing and shall be mailed by certified mail or statutory overnight delivery, return receipt requested, or delivered personally to and a receipt obtained from the Risk Management Division of the Department of Administrative Services. In addition, a copy shall be delivered personally to or mailed by first-class mail to the state government entity, the act or omissions of which are asserted as the basis of the claim. Each state government entity may designate an office or officer within that state government entity to whom a notice of claim is to be delivered or mailed

    (3) No action against the state under this article shall be commenced and the courts shall have no jurisdiction thereof unless and until a written notice of claim has been timely presented to the state as provided in this subsection

    (4) Any complaint filed pursuant to this article must have a copy of the notice of claim submitted to the Department of Administrative Services together with the certified mail or statutory overnight delivery receipt or receipt for other delivery attached as exhibits. If failure to attach such exhibits to the complaint is not cured within 30 days after the state raises such issue by motion, then the complaint shall be dismissed without prejudice and

    (5) A notice of claim under this Code section shall state, to the extent of the claimant's knowledge and belief and as may be practicable under the circumstances, the following:

    (A) The name of the state government entity, the acts or omissions of which are asserted as the basis of the claim

    (B) The time of the transaction or occurrence out of which the loss arose

    (C) The place of the transaction or occurrence

    (D) The nature of the loss suffered

    (E) The amount of the loss claimed and

    (F) The acts or omissions which caused the loss.

    (b) No action may be commenced under this article following presentation of a notice of claim until either the Department of Administrative Services has denied the claim or more than 90 days have elapsed after the presentation of the notice of claim without action by the Department of Administrative Services, whichever occurs first.

    (c) The Department of Administrative Services shall have the authority to examine and copy any records of any state government entity to facilitate the investigation of a claim. Each state government entity shall make available to the Department of Administrative Services, incidental to any investigation of a claim, all such records notwithstanding any other provision of law which designates such records as confidential or which prohibits disclosure of such records provided, however, that the Department of Administrative Services shall be bound by such provision of law and shall not make further disclosure of such records except as permitted by such provision of law. The Department of Administrative Services may enforce the authority granted under this subsection by subpoena which may be enforced, upon application by the department, by the Superior Court of Fulton County, Georgia, in the same manner as subpoenas issued under Chapter 13 of this title, the "Georgia Administrative Procedure Act," may be enforced.

    (d) Any document or information gathered or prepared by the Department of Administrative Services in connection with the investigation undertaken as a result of the notice of claim shall be considered privileged and confidential and shall not be subject to discovery by any claimant in any proceeding under this article except as otherwise provided by law.

    Disclaimer: These codes may not be the most recent version. Georgia may have more current or accurate information. We make no warranties or guarantees about the accuracy, completeness, or adequacy of the information contained on this site or the information linked to on the state site. Please check official sources.


    Reynolds v. Bordelon: The Beginning of the End for the Tort of Spoliation

    Imagine getting into a car accident. The airbags do not deploy, making the risk of injury much worse. The car’s airbags are possibly defective, and there might be a products liability claim against the vehicle manufacturer. However, a third party accidentally destroys the vehicle before an inspection for defects takes place. Can you hold that person liable for negligence? The Louisiana Supreme Court in Reynolds v. Bordelon answered “no.” [1]

    The Reynolds decision marked the first time the Louisiana Supreme Court addressed the tort of negligent spoliation of evidence, and the Court has never decided whether intentional spoliation is actionable under Louisiana tort law. [2] Although the facts of Reynolds are limited to negligent spoliation by a third party, the Court’s reasoning can be applied to all claims alleging tortious spoliation. Based on the strong language of Reynolds and the Court’s reliance on California jurisprudence eliminating spoliation claims, the Louisiana Supreme Court will likely expand its holding in Reynolds to all spoliation torts in the future.

    I. Louisiana Civil Code Article 2315: The Foundation of Louisiana Tort Law

    Louisiana Civil Code article 2315 provides: “Every act whatever of man that causes damage to another obliges him by whose fault it happened to repair it.” [3] “Fault” as used in Article 2315 is the violation of a duty owed by a wrongdoer to a victim. [4] Therefore, to hold a defendant liable based on negligence, or any tort – based cause of action, a court must first consider whether the defendant owed a duty to the plaintiff. [5]

    Courts, including the Supreme Court in Reynolds, often use public policy considerations to decide whether a duty exists. [6] Such considerations include: deterring undesirable conduct, avoiding the deterrence of desirable conduct, compensating victims, satisfying the community’s sense of justice, allocating resources (including judicial resources) properly, encouraging predictability, and deferring to legislative will. [7] The Reynolds Court found no duty to preserve evidence based on these considerations and concluded that no cause of action for negligent spoliation of evidence exists under Louisiana law. [8]

    II. No Cause of Action for Negligent Spoliation of Evidence

    Into the Reynolds, the plaintiff was involved in a multi-car accident where his airbags failed to deploy. [9] The plaintiff sued the manufacturer of his vehicle under the Louisiana Products Liability Act for an alleged airbag defect. [10] Despite being put on notice of the need for preservation, both the plaintiff’s insurer and the custodian of the vehicle after the accident failed to preserve his vehicle for inspection purposes. [11] The insurer paid the plaintiff what was due under the policy and took title of the vehicle then, the custodian auctioned the vehicle to a salvage yard for parts. [12] As a result, Reynolds brought a negligence action against his insurer and the custodian for their failure to preserve his vehicle. [13] The Court held “that no cause of action exists for negligent spoliation of evidence.” [14]

    The Court reached this result for several policy reasons. First, negligent spoliation of evidence is “so unintentional an act” that a duty to preserve evidence will likely not deter future conduct. [15] This is especially true among third parties who have no interest in the underlying case. [16] Second, any damages that result from negligent spoliation will likely be highly speculative in nature. [17] Third, a cause of action for negligent spoliation necessarily expands the number of potential plaintiffs and defendants and may open the floodgates to speculative litigation. [18] Finally, this cause of action would require certain persons and industries to undergo costly and unnecessary evidence storage. [19] In the Reynolds case, the Court used these public policy considerations to establish a categorical “no duty” rule for preserving evidence. [20]

    III. What Comes Next? Reynolds and the Future of the Tort of Spoliation in Louisiana

    Into the Reynolds, the plaintiff brought suit against a third party spoliator. However, the decision will likely lead to the elimination of all spoliation torts in future cases. Following Reynolds, a negligence cause of action against a first party spoliator likely does not exist. Moreover, the decision provides support for the argument that intentional spoliation is not actionable under Louisiana tort law. Therefore, Reynolds likely marks beginning of the end of the tort of spoliation in Louisiana.

    From the outset, the Court’s language in Reynolds evidences an intent to eliminate the tort of negligent spoliation entirely. [21] The Court never expressly limited its holding and often discussed the tort of negligent spoliation generally. [22] Further, the Court discussed alternative legal remedies a litigant has against first party spoliators, which would be unnecessary if the Court’s analysis was limited to third party spoliation. [23] Nonetheless, even if the holding is limited to its facts, Reynolds can be applied by analogy to a negligent, first party spoliator. Thus, a negligence cause of action against a first party spoliator likely does not exist.

    Even more dramatically, Reynolds may lead to the elimination of a cause of action for the tort of intentional spoliation. Into the Temple Community Hospital v. Superior Court, the California Supreme Court held that there is no tort cause of action for intentional, third party spoliation. [24] The California Supreme Court issued this ruling one year after it held that there is no cause of action for intentional, first party spoliation under California law. [25] Although there is an obvious difference between negligent and intentional spoliation, the policy considerations that informed the Reynolds decision also informed the California Supreme Court’s decisions. [26] Furthermore, the Reynolds Court quoted Temple Community Hospital and adopted some of that decision’s logic to bolster its holding. [27] Thus, Reynolds may even lead to the Louisiana Supreme Court concluding that there is no cause of action for intentional spoliation of evidence.

    Citing policy considerations and adopting much of the reasoning set forth in California jurisprudence, the Louisiana Supreme Court held that there is no cause for action for negligent spoliation of evidence under Louisiana tort law. Although the underlying facts involved a negligent third party spoliator, the Reynolds decision may be the first in a line of cases that repudiate the tort of spoliation altogether.

    [1] Reynolds v. Bordelon, No. 2014 – C – 2362, 2015 WL 3972370, at * 1 (La. June 30, 2015).

    [2] EEA Danielle Borel, Comment, The Land of Oz: Spoliation of Evidence in Louisiana, 74 La. L. Rev. 507, 516 (2014) (explaining spoliation and providing a detailed history of Louisiana appeal decisions related to a tort cause of action for spoliation).

    [3] The. Civ. Code art. 2315 (2015).

    [4] William E. Crawford, Tort Law § 2.1, into the 12 Louisiana Civil Law Treatise 57 (2nd ed. 2009) (“Fault consists of the violation of a duty owed by the actor to the victim.”).

    [5] Id. at § 2.3, at 58 (“Before finding negligence, the court must find that the defendant owed a duty to the plaintiff.”).


    2011 New Mexico Statutes Chapter 41: Torts Article 4: Tort Claims, 41-4-1 through 41-4-30 Section 41-4-26: Home rule municipality tort claims ordinances severability applicability.

    A. Any provision of an ordinance adopted by a home rule municipality providing for the insurance or self-insurance of tort liability risks of the home rule municipality is declared to be severable if any part or application of such ordinance is held invalid.

    B. Any home rule municipality which has adopted an ordinance providing for the insurance or self-insurance of any or all of the tort liability risks of the municipality, shall not be eligible to participate in the public liability fund created pursuant to Section 41-4 -23 NMSA 1978.

    C. A home rule municipality which has adopted an ordinance insuring or self-insuring its tort liability risks prior to July 1, 1978 or which has adopted an ordinance after July 1, 1978 insuring or self-insuring its tort liability risks pursuant to Subsection B of Section 41-4-25 NMSA 1978 may elect to be covered by the public liability fund created pursuant to Section 41-4-23 NMSA 1978 for the subsequent calendar years by:

    (1) giving notice of the repeal of its ordinance to the risk management division prior to December 1 of any calendar year and

    (2) paying such assessments as may be determined by the risk management division. Occurrences giving rise to claims arising during any period of time [in] which a home rule municipality had a valid or invalid ordinance insuring or self-insuring its risks shall be governed by the ordinance in effect at the time the claims arose and not by the public liability fund created pursuant to Section 41-4-23 NMSA 1978.

    Disclaimer: These codes may not be the most recent version. New Mexico may have more current or accurate information. We make no warranties or guarantees about the accuracy, completeness, or adequacy of the information contained on this site or the information linked to on the state site. Please check official sources.

    Subscribe to Justia's Free Newsletters featuring summaries of federal and state court opinions.


    Resetting the Clinical Negligence Compensation System in England

    Recently it was announced that the British government will review our tort-based clinical negligence system and publish a consultation paper on the topic this year.

    Our clinical negligence system is a major driver of cost in the National Health Service (NHS), and is an area of ​​acute concern.

    In 2017, the National Audit Office (NAO) published a report on the rising costs of clinical negligence claims and the effect on trusts (hospitals and other care organizations) in the NHS.

    “The cost of clinical negligence claims is rising at a faster rate year-on-year, than NHS funding, & # 8221 the report states. & # 8220Between 2010-11 and 2015-16, the average percentage of a trust’s income spent on contributions to pay for the Clinical Negligence Scheme for Trusts increased from 1.3% to 1.8%. Our analysis indicates that this percentage is likely to rise to about 4% by 2020-21. The increasing costs of clinical negligence are adding to the significant financial pressures already faced by many trusts. ”

    Into the The Law Society Gazette, John Hyde reports on the government review, stating that ministers are currently & # 8220working on a total overhaul of the & # 8216outdated & # 8217 system of clinical negligence compensation within the NHS. & # 8221

    “Health minister Nadine Dorries told the health and social care committee that a review of the system was going‘ at pace ’and could involve all claims against the NHS,” Hyde writes.

    Melanie Rowles, of the Medical Protection Society, has stated that in the past ten years, the cost of annual clinical negligence claims for the NHS has risen by over 200%. Over £ 2.4 billion in claims was paid in 2018/19.

    She argues that & # 8220bold reforms & # 8221 are needed to make matters of clinical negligence & # 8220more predictable, fair, and transparent. & # 8221

    These concerns are nothing new. In 2001, & # 8220Learning from Bristol: the report of the public inquiry into children & # 8217s heart surgery at the Bristol Royal Infirmary 1984 -1995 & # 8221 was published. The report outlines how the tort-based clinical negligence system is out of alignment with other policy initiatives on quality and safety, and offers a rich, critical, and reflective discussion of the need for change.

    In 2003, the former Chief Medical Officer Sir Liam Donaldson’s seminal report, & # 8220Making amends: a consultation paper setting out proposals for reforming the approach to clinical negligence in the NHS, & # 8221 was published. It is as relevant today as it was then in expressing the challenges and issues facing our tort-based compensation system and possible alternatives, such as a no-fault system.

    The review and forthcoming consultation paper on the clinical negligence system will return to the forefront several key issues that require open and informed discussion, including the system & # 8217s rising costs. The notion that patients have an inalienable right to sue for negligent harm will also need discussion.

    Nadine Dorries & # 8217 evidence and discussion from February 2, 2021 can be found on parliamentlive.tv. Dorries spoke about the outdated practices and system for determining how clinical negligence compensation is calculated.

    This committee hearing is well worth listening to, as several key issues relating to patient safety and the clinical negligence system are discussed. The patient safety system and the clinical negligence system are key drivers of costs to the NHS, and need to be looked at hand in hand.


    Cake with three types of mousse, in three colors

    This wonderful cake with three types of mousse, in three colors, is an anniversary cake in which we combined the bitter and sweet taste of chocolates with the sour taste of berries.

    I think I reconciled all tastes with this combination.

    Syrupy cocoa top, dark chocolate mousse, white chocolate mousse and berry mousse.

    Even if I worked something on it, the end result crowned all the effort, especially in taste.




    You can also find a recipe on the blog Chocolate cake with lemon cream and berries, which I highly recommend.

    But, from the same category of cakes with mousse creams, I also recommend it Chocolate Duo Cake Recipe.


    Recipes for everyone

    TABLE: 6 eggs 150g sugar 100g flour 50g butter 1 teaspoon vanilla sugar 2 tablespoons rum
    FILLING: 300g whipped cream 2 tablespoons orange peel
    GLAZE: 150g household chocolate 100g sugar 2 tablespoons the water

    Beat eggs with sugar and vanilla, first hot, in a bain-marie, then cold, with the bowl placed in another bowl with cold water. Repeat this process 3 times, then add the rum, flour and mix until smooth. Grease a narrower and taller shape with butter (it can be a pot or a pan with a diameter of 15 & # 8211 16cm) and pour the prepared composition into it. Bake the top on the right heat, then leave it to cool. Remove it from the bowl and cut it in half, horizontally. Hollow out each side to make room for the filling. The lower countertop digs deeper. Fill the bottom top with whipped cream mixed with orange peel. Fill the hole in the top and put it over the first one. For the icing, melt the chocolate together with the sugar. When you have obtained a homogeneous composition, take the bowl off the heat and pour the icing over the cake placed on a plate. Refrigerate the cake until ready to serve. (Daniel Petre)

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    This entry was posted on April 21, 2010 at 9:08 am and is filed under Desert. You can follow any responses to this entry through the RSS 2.0 feed. Both comments and pings are currently closed.

    5 answers to & # 8220Tort “Indiana” & # 8221

    Aaa, welcome back sir & # 8217 Cuckoo! Sweet, because bitter was the lack. To be received!

    Good morning to Santa Claus, do you give us or do you not give us, do you give us or do you not give us? What are we doing, Mr. Cucui, abandoning this beautiful project? Do you let it burn in the oven?


    Video: Śmietankowy tort owocowy


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