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Full Complaint
Case 1:18-cv-01612-CKK Document 11 Filed 11/17/18 Page 1 of 602 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ESTATE OF ROBERT P. HARTWICK, § HALEY RUSSELL, HANNAH § HARTWICK, LINDA K. HARTWICK, § ROBERT A. HARTWICK, SHARON § SCHINETHA STALLWORTH, § ANDREW JOHN LENZ, ARAGORN § THOR WOLD, CATHERINE S. WOLD, § CORY ROBERT HOWARD, DALE M. § HINKLEY, MARK HOWARD BEYERS, § DENISE BEYERS, EARL ANTHONY § MCCRACKEN, JASON THOMAS § WOODLIFF, JIMMY OWEKA OCHAN, § JOHN WILLIAM FUHRMAN, JOSHUA § CRUTCHER, LARRY CRUTCHER, § JOSHUA MITCHELL ROUNTREE, § LEIGH ROUNTREE, KADE L. § PLAINTIFFS’ HINKHOUSE, RICHARD HINKHOUSE, § SECOND AMENDED SUSAN HINKHOUSE, BRANDON § COMPLAINT HINKHOUSE, CHAD HINKHOUSE, § LISA HILL BAZAN, LATHAN HILL, § LAURENCE HILL, CATHLEEN HOLY, § Case No.: 1:18-cv-01612-CKK EDWARD PULIDO, KAREN PULIDO, § K.P., A MINOR CHILD, MANUEL § Hon. Colleen Kollar-Kotelly PULIDO, ANGELITA PULIDO § RIVERA, MANUEL “MANNIE” § PULIDO, YADIRA HOLMES, § MATTHEW WALKER GOWIN, § AMANDA LYNN GOWIN, SHAUN D. § GARRY, S.D., A MINOR CHILD, SUSAN § GARRY, ROBERT GARRY, PATRICK § GARRY, MEGHAN GARRY, BRIDGET § GARRY, GILBERT MATTHEW § BOYNTON, SOFIA T. BOYNTON, § BRIAN MICHAEL YORK, JESSE D. § CORTRIGHT, JOSEPH CORTRIGHT, § DIANA HOTALING, HANNA § CORTRIGHT, MICHAELA § CORTRIGHT, LEONDRAE DEMORRIS § RICE, ESTATE OF NICHOLAS § WILLIAM BAART BLOEM, ALCIDES § ALEXANDER BLOEM, DEBRA LEIGH § BLOEM, ALCIDES NICHOLAS § BLOEM, JR., VICTORIA LETHA § Case 1:18-cv-01612-CKK Document 11 Filed 11/17/18 Page 2 of 602 BLOEM, FLORENCE ELIZABETH § BLOEM, CATHERINE GRACE § BLOEM, SARA ANTONIA BLOEM, § RACHEL GABRIELA BLOEM, S.R.B., A § MINOR CHILD, CHRISTINA JEWEL § CHARLSON, JULIANA JOY SMITH, § RANDALL JOSEPH BENNETT, II, § STACEY DARRELL RICE, BRENT § JASON WALKER, LELAND WALKER, § SUSAN WALKER, BENJAMIN § WALKER, KYLE WALKER, GARY § WHITE, VANESSA WHITE, ROYETTA § WHITE, A.W., A MINOR CHILD, § CHRISTOPHER F. -
Iran's Strategy for Export of Natural
Iran’s Strategy for Export of Natural Gas Statement by: M.A. Sarmadi-Rad Director of Regional Economic Cooperation MFA of Islamic Republic of Iran WORKING PARTY ON GAS UN/ECE 15th SESSION JANUARY 2005 GENEVA In the Name of God, The Compassionate, the Merciful Mr. Chairman, Ladies and Gentlemen, First of all I would like to express my sincere gratitude to the organizers of this meeting for inviting me to make this presentation. It is indeed a pleasure for me to be here and share with you my point of view regarding Iran’s strategy for exporting natural gas. As for natural gas we all know that demand for natural gas has been growing much faster than the demand for other primary energy resources. It is also expected that the share of natural gas in the primary energy basket to increase rapidly. The growth rate of world demand for natural gas will average 3.1%. It is also no secret that European countries will be even more dependent on natural gas in the coming decades. Projected natural gas supply and demand for 2020 and 2030 reveal that European countries will have to find new sources of supply to satisfy their additional demand. Russia, currently the main supplier of natural gas to Europe, may not be able to meet this increasing demand. Because Russia, as is widely expected, will have to meet the growing demand for natural gas in FSU countries and in its domestic market. Iran, located strategically in the vicinity of Russia, the CIS countries and the Caucasus, as well as on the eastern border of Europe, has the potential to export large quantities of natural gas both to EU markets in the west and to the growing energy markets of South Asia and beyond. -
COUNCIL IMPLEMENTING REGULATION (EU) No 945/2012 of 15 October 2012 Implementing Regulation (EU) No 267/2012 Concerning Restrictive Measures Against Iran
L 282/16 EN Official Journal of the European Union 16.10.2012 COUNCIL IMPLEMENTING REGULATION (EU) No 945/2012 of 15 October 2012 implementing Regulation (EU) No 267/2012 concerning restrictive measures against Iran THE COUNCIL OF THE EUROPEAN UNION Annex IX to Regulation (EU) No 267/2012. Heading I in Annex IX to Regulation (EU) No 267/2012 should Having regard to the Treaty on the Functioning of the European therefore be amended. Union, (3) Furthermore, the entry for one entity included in the list set out in Annex IX to Regulation (EU) No 267/2012 Having regard to Council Regulation (EU) No 267/2012 of should be amended, while certain persons and entities 23 March 2012 concerning restrictive measures against should be removed from that list. Iran ( 1 ), and in particular Article 46(2) thereof, (4) In order to ensure that the measures provided for in this Whereas: Regulation are effective, this Regulation should enter into force on the day of its publication, (1) On 23 March 2012, the Council adopted Regulation (EU) No 267/2012 concerning restrictive measures against HAS ADOPTED THIS REGULATION: Iran. Article 1 (2) In view of the situation in Iran, and in accordance with Annex IX to Regulation (EU) No 267/2012 shall be amended as Council Decision 2012/635/CFSP of 15 October 2012 set out in the Annex to this Regulation. amending Decision 2010/413/CFSP concerning 2 restrictive measures against Iran ( ), the Council Article 2 considers that additional persons and entities should be included in the list of natural and legal persons, entities This Regulation shall enter into force on the date of its and bodies subject to restrictive measures set out in publication in the Official Journal of the European Union. -
Foreign Affairs in Court: Lessons from CJEU Targeted Sanctions Jurisprudence
Article Foreign Affairs in Court: Lessons from CJEU Targeted Sanctions Jurisprudence Elena Chachko† INTRODUCTION ............................................................................................................................................ 2 I. THE MAKING OF EU SANCTIONS .............................................................. ................................................. 6 A. EU Foreign and Security Policy .................................................................................................. 6 B. Sanctions Decision-Making ......................................................................................................... 8 C. EU Iran Sanctions ........................................................................................................................ 9 D. EU Syria Sanctions .................................................................................................................... 11 II. CJEU JUDICIAL REVIEW OF CFSP SANCTIONS .............................................................. ........................ 12 A. Jurisdiction ................................................................................................................................. 12 B. Standard of Review .................................................................................................................... 14 C. Early Reforms ............................................................................................................................ 18 III. METHODOLOGY ............................................................. -
Grader Operators' Handbook
1 Schedule “A” Policy 3204 GRADER OPERATORS’ HANDBOOK 2 Athabasca County Grader Operator Hand Book Table of Contents Page I. SAFETY A. Accident Prevention 3 B. Planning Ahead 3 C. Accident Checklist 4 D. Working Alone 4 - 5 II. GRADER OPERATION A. Prestart Checks 5 B. Start-Up 6 C. Operating Safety Tips 7 D. Service & Repair 8 E. Parking & Disabled Grader 9 III. MAINTAINENCE STANDARDS A. Hazards / Unsafe Conditions 1. Responsibility 10 2. Types 10 B. Gravel Surface Maintenance 1. Regular Roadway Summer Maintenance 11-12 2. Intersections 12 3. Pulling Shoulders 12-13 4. Regravelling 13-14 5. Winter Maintenance 14-15 6. Dust Control 15 7. Railway Crossing 16 8. Bridges 16 3 I. SAFETY A. ACCIDENT PREVENTION: 1. Stop Accidents Before They Stop You i. Even the best and safest grader must still be operated with care and knowledge of its capabilities. Common sense, observance of safety rules and alertness on the job will result in “ACCIDENT FREE” days. ii. Accidents don’t just happen – they are caused by human error. So the person who has the ultimate responsibility is the grader operator – YOU! B. PLANNING AHEAD: 1. Records show that a majority of accidents are caused by a disregard for Safety Rules – OBEY THEM! 2. If you have questions don’t be afraid to ask your maintenance foreman. 3. Dress Properly For The Job – Find out what items are required and wear them. (Safety shoes, hearing protection, safety vests, etc.) 4. Understand Your Grader – Read the Operators Manual and know your machines limitations. 5. Use All the Safety Equipment your grader is equipped with. -
Caspian Oil and Gas Complements Other IEA Studies of Major Supply Regions, Such As Middle East Oil and Gas and North African Oil and Gas
3 FOREWORD The Caspian region contains some of the largest undeveloped oil and gas reserves in the world. The intense interest shown by the major international oil and gas companies testifies to its potential. Although the area is unlikely to become “another Middle East”, it could become a major oil supplier at the margin, much as the North Sea is today. As such it could help increase world energy security by diversifying global sources of supply. Development of the region’s resources still faces considerable obstacles. These include lack of export pipelines and the fact that most new pipeline proposals face routing difficulties due to security of supply considerations,transit complications and market uncertainties. There are also questions regarding ownership of resources, as well as incomplete and often contradictory investment regimes. This study is an independent review of the major issues facing oil and gas sector developments in the countries along the southern rim of the former Soviet Union that are endowed with significant petroleum resources: Azerbaijan, Kazakstan,Turkmenistan and Uzbekistan. Caspian Oil and Gas complements other IEA studies of major supply regions, such as Middle East Oil and Gas and North African Oil and Gas. It also expands on other IEA studies of the area, including Energy Policies of the Russian Federation and Energy Policies of Ukraine. The study was undertaken with the co-operation of the Energy Charter Secretariat, for which I would like to thank its Secretary General, Mr. Peter Schütterle. Robert Priddle Executive Director 5 ACKNOWLEDGEMENTS The IEA wishes to acknowledge the very helpful co-operation of the Energy Charter Secretariat, with special thanks to Marat Malataev, Temuri Japaridze, Khamidulah Shamsiev and Galina Romanova. -
Geopolitics of the Iranian Nuclear Energy Program
Geopolitics of the Iranian Nuclear Energy Program But Oil and Gas Still Matter CENTER FOR STRATEGIC & CSIS INTERNATIONAL STUDIES A Report of the CSIS Energy and National Security Program 1800 K Street, NW | Washington, DC 20006 author Tel: (202) 887-0200 | Fax: (202) 775-3199 Robert E. Ebel E-mail: [email protected] | Web: www.csis.org March 2010 ISBN 978-0-89206-600-1 CENTER FOR STRATEGIC & Ë|xHSKITCy066001zv*:+:!:+:! CSIS INTERNATIONAL STUDIES Geopolitics of the Iranian Nuclear Energy Program But Oil and Gas Still Matter A Report of the CSIS Energy and National Security Program author Robert E. Ebel March 2010 About CSIS In an era of ever-changing global opportunities and challenges, the Center for Strategic and International Studies (CSIS) provides strategic insights and practical policy solutions to decision- makers. CSIS conducts research and analysis and develops policy initiatives that look into the future and anticipate change. Founded by David M. Abshire and Admiral Arleigh Burke at the height of the Cold War, CSIS was dedicated to the simple but urgent goal of finding ways for America to survive as a nation and prosper as a people. Since 1962, CSIS has grown to become one of the world’s preeminent public policy institutions. Today, CSIS is a bipartisan, nonprofit organization headquartered in Washington, D.C. More than 220 full-time staff and a large network of affiliated scholars focus their expertise on defense and security; on the world’s regions and the unique challenges inherent to them; and on the issues that know no boundary in an increasingly connected world. -
Wiiw Research Report 367: EU Gas Supplies Security
f December Research Reports | 367 | 2010 Gerhard Mangott EU Gas Supplies Security: Russian and EU Perspectives, the Role of the Caspian, the Middle East and the Maghreb Countries Gerhard Mangott EU Gas Supplies Security: Gerhard Mangott is Professor at the Department Russian and EU of Political Science, University of Innsbruck. Perspectives, the Role of This paper was prepared within the framework of the Caspian, the the project ‘European Energy Security’, financed from the Jubilee Fund of the Oesterreichische Na- Middle East and the tionalbank (Project No. 115). Maghreb Countries Contents Summary ......................................................................................................................... i 1 Russia’s strategic objectives: breaking Ukrainian transit dominance in gas trade with the EU by export routes diversification ............................................................... 1 1.1 Nord Stream (Severny Potok) (a.k.a. North European Gas Pipeline, NEGP) ... 7 1.2 South Stream (Yuzhnyi Potok) and Blue Stream II ......................................... 12 2 The EU’s South European gas corridor: options for guaranteed long-term gas supplies at reasonable cost ............................................................................... 20 2.1 Gas resources in the Caspian region ............................................................. 23 2.2 Gas export potential in the Caspian and the Middle East and its impact on the EU’s Southern gas corridor ................................................................. -
The Brewing Crisis in the Persian Gulf: New Rules for Old Games No
ISPSW Strategy Series: Focus on Defense and International Security Issue The Brewing Crisis in The Persian Gulf: New Rules for Old Games No. 624 Yossef Bodansky June 2019 The Brewing Crisis in The Persian Gulf: New Rules for Old Games Yossef Bodansky June 2019 Executive Summary * Although the unfolding crises throughout the greater Middle East are increasingly driven by, and unfold according to, heritage-based frameworks and dynamics - the outcome of the Moscow Summit will have disproportionate influence over the next phases of these crises, and, consequently, the future of the region. The escalating confrontation between Iran and the US is both influencing and influenced by the mega-trends set by Russia and China. * Even though both Russia and China are not satisfied with the Iranian and Iran-Proxy activities and policies in the Iraq-Syria-Lebanon area - it is far more important for them to support Iran in the confrontations with the US in order to expedite the consolidation of the New Silk Road. * The US keeps escalating its covert war with Iran - both in the Persian Gulf and in Syria. The extent of the escalation and the focusing on objectives of great importance for Iran cannot but lead to Iranian harsh reaction. * Qassem Soleimani continues traveling clandestinely throughout the Middle East - preparing his vast and growing forces, both Iranian and Iran-Proxy, for the fateful clash with the US and its allies should Khamenei give the order. About ISPSW The Institute for Strategic, Political, Security and Economic Consultancy (ISPSW) is a private institute for research and consultancy. The ISPSW is an objective, task-oriented and politically non-partisan institute. -
Iran Sanctions
Iran Sanctions Kenneth Katzman Specialist in Middle Eastern Affairs July 9, 2009 Congressional Research Service 7-5700 www.crs.gov RS20871 CRS Report for Congress Prepared for Members and Committees of Congress The Iran Sanctions Act (ISA) Summary Iran is subject to a wide range of U.S. sanctions, restricting trade with, investment, and U.S. foreign aid to Iran, and requiring the United States to vote against international lending to Iran. Several laws and Executive Orders extend sanctions to foreign companies that do business with Iran, as part of an effort to persuade foreign firms to choose between the Iranian market and the much larger U.S. market. A formal U.S. effort to curb international energy investment in Iran began in 1996 with the Iran Sanctions Act (ISA). No firms have been sanctioned under it and the precise effects of that law on energy investment in Iran—as separate from other factors affecting international firms’ decisions on whether to invest in Iran—has been unclear. While international pressure on Iran to curb its nuclear program has increased the hesitation of many major foreign firms to invest in Iran’s energy sector, hindering Iran’s efforts to expand oil production beyond 4.1 million barrels per day, some firms continue to see opportunity in Iran. This particularly appears to be the case for companies in Asia that appear eager to fill the void left by major European and American firms and to line up steady supplies of Iranian oil and gas. ISA was first passed at a time of tightening U.S. -
May 2016,ISSN 0474–6279 4 Member Country Focus Centre for Dialogue Iran Oiliran Show Appointment Newsline Obituary
Visit our website www.opec.org The ultimate resource It has been a common response throughout the history a more creative, more dynamic and more competitive en- of human societies to look elsewhere for solutions to ergy sector. In this, the role of each country’s national oil complex challenges. When man first set out across the company, under the inspiring leadership of their respec- Tigris-Euphrates river valley, he went not only in search of tive ministries, should not be overlooked. And together, better living conditions but also knowledge and wisdom. in various ways, they have each been able to start putting It is not much different today. Developing countries together programmes of action and investment, research of the ‘global south’ — in Africa, Asia, and the Middle and development, that promises to make each country a Commentary East — often find themselves looking to other countries leader in its own right. for the newest approaches to economic development and What the Oil Show in Iran also demonstrated, as one the latest technological innovations. of our feature articles in this edition suggests, is the coun- Sometimes lost in this rush for the ‘newest’ and the try’s resilience. That is to say, even without necessarily ‘latest’ is the recognition that local communities often having access to all the inputs, materials and resources have a better understanding of local challenges, and that that companies might want or desire, they have still found the people on the ground may have some of the greatest a way to move forward — and not only move forward but insights. -
Overseas Market Information Country Profile
Overseas Information Overseas Market Information Country Profile - Iran Economic Overview Import in the Engineering Sector Iran’s economy is heavily dependent on oil revenues. Though oil Given below is a table showing total import by Iran in the sector’s share of GDP has declined from 30-40% in 1970s to engineering sector during 2001-2002 and 2002-2003 : 15.2% during 2001-2002, the oil exports accounted for over 80% (Value in US$ Million) of the Country’s total export revenue and 40-50% of the Government budget. The economy was hit hard by the plunge Sl. No. Product Groups 2001-02 2002-03 % change in oil prices in 1997-1998 and early 1999 but have since 1. Industrial and mechanical recovered with the rebound in oil prices. Overall economic machinery & equipment 3471.2 3702.2 6.7 activity during the last three successive years has been strong 2. Industrial and electric with real GDP growing by 5.7% (2000-2001), 4.8% (2001-2002) instruments 1494.5 1354.8 (-) 9.3 and 5.8% (2002-2003). The share of different sectors in GDP 3. Ironware 1512.2 1304.6 (-) 13.7 during 2002-2003 was as follows : 4. Agricultural and road Oil & Gas - 18.6% construction machinery 408.0 366.0 (-) 10.4 TOTAL 6885.9 6727.6 (-) 2.3 Agriculture - 11.8% Industries & Mining - 19.4% Major Countries of Import Services - 50.2% Main sources of Iran’s import are Germany, Switzerland, UAE, The Third Five-Year Plan (which began in March 2000), targets France, Italy, South Korea, China, Russia, Japan, Brazil, UK and the creation of 750,000 new jobs per year, average annual real India etc.