Category Archives: Business

Procedural Posture

Procedural Posture

Plaintiffs, owners and subdividers, appealed from a judgment of the Superior Court of Los Angeles County (California) in favor of defendant contractor on a cross-complaint for damages for breach of an excavation and grading contract.

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Plaintiffs entered into a contract with defendant for certain excavation and grading work on lots and streets, together with street improvement work, in a subdivision. After defendant performed 98 percent of the work, a dispute arose regarding payment for additional work, and defendant ceased performance. Plaintiffs immediately employed others to do street improvement work called for by the contract and thereafter sued defendant and his bonding company for breach of contract. The trial court determined that plaintiffs were entitled to nothing against defendant and his bonding company and allowed defendant recovery on his cross-complaint. The court affirmed. The contract between the parties was divisible and the doctrine of substantial performance was thus applicable. Under the circumstances, the fact that defendant did not perform the second phase of the contract did not prevent his recovering for work done under the first phase. Plaintiffs were not entitled to a setoff representing a payment by them to others after defendant ceased performance under the contract because there was substantial evidence to support the finding that defendant completed all the grading required.


The judgment allowing defendant recovery on his cross-complaint was affirmed. Plaintiffs were ordered to pay to defendant additional attorney’s fees on this appeal in an amount to be determined by the trial court.

Procedural Posture

Procedural Posture

Defendant rival developers appealed the judgment of Superior Court of the City and County of San Francisco (California) that they intentionally interfered with plaintiff developer’s prospective economic relationship with defendant trade association. Plaintiff cross-appealed the dismissal of its causes of action against defendant trade association for breach of contract and against defendant rival developers for interference with contract.

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Plaintiff developer sought to build an apparel mart and courted defendant trade association as a potential lessor. When defendant rival developers ultimately won defendant trade association’s business, plaintiff filed suit for breach of contract, interference with contract, and negligent and intentional interference with economic advantage. Defendant rival developers were found to have intentionally interfered with plaintiff’s economic advantage and they appealed. The trial court nonsuited the breach of contract and interference with contract claims and plaintiff cross-appealed. The court affirmed the nonsuit of the breach and interference with contract claims because the alleged contract failed due to unsatisfied conditions precedent. The judgment that defendant rival developers interfered with plaintiff’s economic advantage and the order denying defendants’ motion for judgment notwithstanding the verdict were reversed because defendants raised the competition privilege as an affirmative defense and plaintiff failed to defeat the privilege as plaintiff could not prove that defendants committed an unlawful or illegitimate act which was independently actionable.


The court reversed the judgment against defendant rival developers that they interfered with plaintiff developer’s prospective economic advantage because the competition privilege was an affirmative defense, and reversed the order denying defendants’ motion for judgment notwithstanding the verdict. The court affirmed the nonsuit of plaintiff’s causes of action for breach of contract and interference with contract because no contract existed.

What Are The Different Job Roles In A Movie Production Company

What Are The Different Job Roles In A Movie Production Company

Getting involved with any movie production company has its ups and downs. Although this industry is very competitive, they are also fascinating and chosen by many talented people. Age is never a factor here. All that’s required is a person’s ability to express their thoughts and emotions through writing and acting.

It’s that type of industry that believes in the survival of the fittest. You can learn all about business video production with DreamCube to enhance the skills that benefit you in the field of movie production. Here are some of the job roles to consider in a movie production company:

  • Producer

From the beginning of production of a movie till the very end, the producer looks after every chore there is. He is considered as the leader who unites every crew member together. The producer is in charge of tasks from gathering crew members and assigning them roles, to raising a budget for a film and everything in between.

He is practically the most important person in a movie production company.

  • Director

A director is a person who is responsible for looking after all the creative aspects of the production of a movie. He can direct the actors and guide the technician crew such that everything that’s written on the script is presented in such a manner that it is enjoyed by maximum people.

It’s the director’s imagination and potential that either makes or breaks a movie.

  • Screenwriter

Screenwriters are the ones who are responsible for creating storylines and characters that make up a movie script. They either create the script with real-life experiences or transfigure a fictional story into the script.

Screenwriters have to keep in mind that what they write can be easily enacted by the actors and understood by the audience.

  • Editor

Combining all the shots and scenes and making a movie out of it is the task that an editor needs to handle. The director tells how the movie should look like and the editor makes it happen.

Even if the script and the acting are remarkable, how the movie is presented to everyone is in the hands of the editor.

  • Cinematographer

A cinematographer controls the camera and lighting at the sets where the movie is being shot. He is the one who takes care of the effects of lighting, colors, and looks that are important aspects to keep in mind while shooting a movie.

The change in lighting and camera angles with every scene is the key feature that a cinematographer needs to keep in mind.

  • Graphic Designer

Graphic Designers ensure the preparation of movie posters and digital content of the movie. Creating a captivating atmosphere so that audiences are glued to their seats is what they are responsible for.

Presenting all the fictional characters and places in such a way that they look realistic, is the reason why graphic designers are popular in this field.

Although all of the above-mentioned people are important, they are still incomplete without each other.

The Gold Price in Australia

The Gold Price in Australia

Just like every other country and financial market in the world, the gold price in Australia is determined by the gold fixing standard, a benchmark created by the major players in the gold bullion market who are members of the London Bullion Market Association.

Gold Price Performance

If you go to any reputable website that offers comprehensive gold price performance statistics, you’ll easily see why gold is so popular as an investment method.

While the daily and monthly gold price performance may fluctuate in percentages based on supply and demand, as well as investor sentiment and country-specific economic environments, you can also see the detailed long-term results.

For the past 20 years, however, the long-term graphs show a sure and steady increase in the gold price Australia. Even with fluctuations in the economy country-wide, the price of gold has typically climbed from approximately $500 per ounce in 2002 to about $2,200 per ounce in 2021. That is a total increase of more than 125% – not bad at all for an investment!

The Role of Australia in the Gold Market

In 2010 Australia was listed as one of the world’s top three largest gold producers and it was also credited with being the country with the biggest and most unmined gold deposits globally as per the US Geological Survey’s gold statistics and information research center.

In 2003 an Australian businessman launched a brand new ETF (Exchange-Traded Funds) company called ETF Securities. This asset management firm started the first gold ETF security trading on the Australian Stock Exchange and originally stood for 0.1 ounces or 3.1 grams of gold.

Australia is also one of the few countries which still make use of gold pool programs to issue gold certificates. These gold certificates allow investors to avoid the risks associated with owning and storing physical gold and instead represent the gold price of their gold investment, which is held by a secure bank or similar gold reserve.

A commonly popular gold bullion coin is the Australian Gold Nugget, minted by the Perth Mint and usually featuring a kangaroo on its reverse side. Because they are produced in limited annual series, their overall value increases every year, over and above the value of the gold used in the production of the coin. The Australian Gold Nugget is available in different sizes and denominations, from as small as 1/20th of an ounce to as large as 1kg of 24-carat gold.

In 2011 the Perth Mint set a new world record by creating a one-tonne gold coin, the largest in the world. Although the face value of the gold coin was set at $1 million AUD, its minted value was over $53 million.

The Future of the Gold Price in Australia

Given the rich untouched gold deposits of the country as a whole, it’s fair to say that the gold price in Australia will continue to enjoy a stable future as it remains a popular global commodity and a great source of investment.

(10) Free Email Marketing Tools to Save You Time and Money

(10) Free Email Marketing Tools to Save You Time and Money

Digital marketing has changed significantly over the last few years, but what hasn’t changed is its efficacy. Among all the digital marketing channels, email marketing continues to be the satta most effective. Over 3.5 billion people use email. Over 85% of B2B marketers use email marketing to promote new business. More than 77% of B2C marketers use email marketing to nurture their audience. If you haven’t gotten on the email marketing bandwagon yet, now is the time to get on. Here are 10 of the best free marketing tools to help save you time and money and help you grow your business.

HubSpot Email Marketing – Most Popular Email Marketing Tool

HubSpot is one of the best-known email marketing tools. Its free version supports small business’ email marketing requirements. As well as being free, it is absolutely easy to use.

HubSpot Email Marketing integrates with other HubSpot tools like free-forever CRM. You can create a centralised database for all your contacts, organise your contacts and lists, and track and manage email performance.

Sendinblue – Best free Email Marketing Tool

Sendinblue has an unlimited subscriber limit. You can send up to 9000 monthly emails and 300 daily emails. This marketing communication platform offers customer relationship management and landing page creation, along with its email marketing tools.

You can choose over 70 design templates to create great-looking emails. The best part – the templates are responsive. You can preview a design to ensure it looks exactly the way you want it to, on any screen format. Other features include A/B testing and automatic optimising of your campaigns.

GetResponse – Best Email Marketing Tool for Templates

GetResponse is a powerful yet easy-to-use email marketing platform that offers signup forms, landing pages, and emails. GetResponse boasts of 99% email delivery, higher response rates, and more results. Some of its features include auto-responders, drag-and-drop editor, A/B split testing, advanced analytics, and scalable workflows based on every customer’s journey.

Omnisend – Most Sophisticated Email Tool

Omnisend’s free plan only includes sending emails, but it is good enough to support all your small and medium business email marketing requirements. Omnisend automates email delivery by using behavioural triggers. You can time your communications according to your customers’ convenience.

Get comprehensive insights about your audience so you can send relevant email marketing messages to each customer. Easily design and create engaging newsletters using Product Picker, a time-saving feature that lets you select the product you want to include in your email.

Mailchimp – Most Well-Known Email Marketing Tool

Mailchimp’s free plan offers basic email marketing features, like email creation and email scheduling. The smart recommendation feature gives you precise audience insights so you can optimise your email marketing efforts. Use the Content Manager feature to design your emails. You can store all your files and images for easy access. You can automate all your emails to push targeted emails like welcome emails, abandoned cart reminders, and order confirmations to individual customers.


What makes MailerLite stand out is its pop-up customiser. Other features include drag-and-drop email builder and landing page builder. It also has a built-in photo editor and a rich text editor to create fantastic and stunning emails.

You can create responsive landing pages to go with your emails to help drive conversions. To choose the best email variations, you can run A/B split tests. MailerLite also gives you a comprehensive report on each campaign that includes statistics like open rate, click rate, and unsubscribe rate.

Mailjet – An Intuitive and Collaborative Tool

Create responsive emails and customise your pre-designed templates with Mailjet. Its real-time collaborative feature lets you collaborate seamlessly with your team. You can create relevant emails and personalised emails for every subscriber, so you get improved results from your email marketing campaign efforts. Mailjet can be integrated with your CRM, and you can manage your mail list from a single dashboard.

EmailOctopus – Best to Send Unlimited Emails

This is an intuitive and straightforward marketing tool. It might not offer as many free features as some other free marketing tools on this list, but it allows you to send many more emails per month. If your business represents other brands, this tool allows you to send as many emails as like, to any number of email addresses. You can integrate EmailOctopus with third-party applications like WordPress, MailOptin, and Zapier and exchange customer data between these tools.

Benchmark Email – Best to Design Responsive Emails

If you want to design responsive emails so your newsletters and emails can be viewed on any device, Benchmark Email is a good bet. You can add and edit images from the platform itself, making it simpler and quicker to design your emails. You can also add stickers, various kinds of effects, and different texts to make your messages more attractive. Choose from several kinds of predesigned templates. The code editor allows you to view the email design even as you edit it.

SendPulse – Best Multi-Channel Email Marketing Platform

Choose from a massive range of professional, predesigned templates that are easily customisable with the drag-and-drop editor. You can automate your emails so that they go out to individual receivers at the right time. Analyse the effectiveness of each email marketing campaign. Understand each subscriber – click rates, read rates, and unread rates.


There are various free email marketing tools that you can choose from for your email marketing campaigns. But the best would be a tool that suits your business’s unique requirements. As well as investing in a free email marketing tool, consider investing in business insurance (click here for more information) that can help support your business. Your email subscribers will have more trust in your brand when they know you have protected your business with business insurance.


m2media. 2021. Our Pick of the Best Email Marketing Software for Australia. [ONLINE] Available at: [Accessed 12 March 2021].

Sprout Social. 2020. 11 Free Email Marketing Tools to Save You Time and Money. [ONLINE] Available at: [Accessed 12 March 2021].

Themeisle. 2021. 6 Best Free Email Marketing Services Compared. [ONLINE] Available at: [Accessed 12 March 2021].

Alles über die Auswahl der richtigen Ladegabeln

Alles über die Auswahl der richtigen Ladegabeln

Das Einkaufen für Ladegabeln ist eine der aufregendsten Erfahrungen des Lebens. Nun, vielleicht ist das etwas übertrieben, aber es kann teuer und überwältigend sein, wenn Sie Ihre Hausaufgaben nicht richtig machen. Gehen Sise nicht davon aus, dass jede Palettengabel gleich ist. Wenn Sie den Rat hier befolgen, finden Sie glücklicherweise eine Palettengabel mit der richtigen Größe, die Ihren Anforderungen am besten entspricht.

So wählen Sie die richtige Größe

Jetzt beginnt der Spaß – die richtigen Palettengabeln aufheben. Verweilen Sie auf dem Weg, auf dem Sie diese Palettengabeln verwenden möchten. Anwendungen für Palettengabeln sind nur durch die Nennbetriebskapazität und die Vorstellungskraft begrenzt. Bauunternehmer in der Bauindustrie nutzen Palettengabeln optimal, um Baumaterialien wie Ziegel, Blöcke, Zäune, Abstellgleise, Schnittholz und Dachmaterial auf und zwischen Baustellen zu transportieren. Mit Ladegabeln können solche Lasten von den Bauarbeitern mit Hilfe kleinerer Fahrzeuge wie Kompaktlader schnell gezogen werden, als wenn sie von Hand be- und entladen würden.

Auf dem Bauernhof sind diese Gabeln nicht zu schlagen. Bemühen Sie sich, mit schweren Paletten mit Dünger oder Saatgut umzugehen, Zaunpfosten zu ziehen oder Heuballen ohne Palettengabeln zu bewegen. Der Einfallsreichtum der Palettengabeln für den Landwirt hört hier nicht auf. Stellen Sie sich den Landwirt vor, der die Palettengabeln auf einem Traktor mit angebautem Greifer und hydraulischem T-Pfosten-Fahrer optimal nutzt. Sie können schnell und problemlos Zäune aufstellen.

Jeder mit Palettengabeln ausgestattete Kompaktlader oder Traktor spart dem Bediener stundenlange Arbeit und erleichtert in vielen Szenarien Aufgaben, die auf keine andere Weise erledigt werden könnten.

Möchten Sie auch hochwertige Ladegabeln online kaufen? Haben Sie überprüft, was Boscaro zu bieten hat? Überprüfen Sie es noch heute!

Ask For Yourself Do You Really Need An Independent Financial Planner

Ask For Yourself Do You Really Need An Independent Financial Planner

Are you looking to hire an independent financial planner to guide you through your plans and goals? Before doing so, you need to ask yourself a few questions. If you are like most people today, you are looking to hire someone because you want to take control of your future. You are looking for someone who will give you advice and plan how you can achieve your financial goals. It’s a little confusing when it comes to deciding if you need a financial planner or not. In reality, no one can truly tell you what your financial goals should be or what they would recommend. You have to decide on your own. Most people are willing to hire someone to help them achieve their goals. The problem lies with those that don’t take action.

Do I Really Need An Independent Financial Planner

Do I really need a financial planner? No, you do not. However, if you plan to succeed in life and are serious about reaching your financial goals, you should hire a financial planner. Here are three reasons why.

Independent planners are good at developing a personalized financial plan for you. You do not have to worry about getting someone who will give you the same plan that everyone else has. If you want a good financial plan, then you should try to get one. A personalized financial plan means that it will be customized to your particular needs. They can suggest different options that may be better for you. They can also make suggestions and changes that can be beneficial to your personal situation.

Financial independence is important, but true independence doesn’t just happen. It takes work and determination on your part. A good plan is a great way to achieve financial independence.

Financial independence doesn’t happen overnight, and it won’t happen without a little bit of planning. You should think about what you want to accomplish with your money and how you plan to get there. Then, make a plan – think about your goals and develop a strategy to reach them. Get professional help if you need it. Don’t be afraid to ask for help, and independence is very attainable.

A financial plan gives you the freedom to set your own goals and have peace of mind knowing that you are in charge of your financial future. This is important because it allows you to make smart financial decisions. Independence is very attainable. There are many things you can do to achieve financial independence.

Do You Really Need An Independent Financial Planner

The decision to hire a financial planner or not is a personal one. It is a wise one, as the effects of hiring a wrong financial planner can be very damaging to your wealth and security. Before you decide to go for a planner, you should ask for a trial run to get some unbiased advice from the planner on how to structure your finances. You should also look for reviews of the services of the planner by family and friends. After you are done with your search, you can choose your needs’ right financial planner.

Independent financial planners are highly skilled individuals who have gained a considerable amount of experience over the years in providing advice to people on how to manage their money. Their objective is to ensure that their clients maximize the potential of their hard-earned wealth. They work in such a way that they help you achieve the best life possible without falling into debt or bankruptcy.

When Do You Need To Hire An Independent Financial Planner

There are several important reasons that you might need to engage the services of such an expert. First and foremost, if you have a complex financial situation, it is in your best interests to consider engaging a qualified planner’s services. A planner’s skill set and experience can truly make a big difference in how well you achieve your financial goals and objectives. Besides, an experienced planner can help you set up a workable budget and assist you with tax planning and advice on how to minimize your financial obligations.

Another reason you might need to hire a financial planner is when you are setting up your retirement accounts. When you are first approaching retirement, you will likely have a fairly clear picture of what you want to accomplish. However, as time passes and you have accumulated more debt, you may begin to realize that you have a lot of wiggle room on the income side as compared to your debt level.

When this occurs, a financial planner can help you determine where the additional funds will come from to reach your retirement goals. A good financial planner can also help you develop a workable budget and initiate savings efforts that will allow you to reach your goals without the need for out-of-pocket contributions or access to a 401(k) account.

Most Expensive Places to Buy Property in Germany

Most Expensive Places to Buy Property in Germany

A country with a high standard of living, a booming economy, and an excellent healthcare system, Germany is a place that anyone would enjoy living in. With the seemingly low cost of living when compared with other big European cities, Germany seems like quite an affordable place to live. However, there are still a couple of cities where the houses are a bit expensive. Naturally, the countryside areas have more affordable housing, whereas the more cosmopolitan regions are more expensive to live in. These are some of the most expensive cities to buy property in Germany:


One of the most enjoyable places to live in Germany, Hamburg has been labeled by many as the “perfect” city. There might be a little downpour of rain now and again, but if you don’t mind that then you will find Hamburg as a lovely place to settle. The never-ending canals, green parks, and beautiful metropolis center all contribute to the amazing aesthetic of the city. It is not one of the more well-known German cities, but it has certainly grown in popularity in recent years, and it will only keep moving forward.


Written in German as Köln, this city is one that is very rich in culture, and allows you to enjoy the German lifestyle and tradition to the fullest. It is a gorgeous city, and it has its fair share of history, so you have a lot of tourist attractions to visit in this city. It is often regarded as the German capital for the television and film industries, as well as the cultural capital of West Germany. It is a great spot for people of different age groups, as there are wonderful museums, festivals and a thriving nightlife in the city.


The fifth-largest state in Germany, Frankfurt am Main is a very metropolitan-styled city, and it is the financial capital of Germany. Being the financial capital of a country like Germany makes it one of the biggest and most important cities in the world. The city has some great universities that attract students from all around the world. The universities give the city of Frankfurt an international feel, with people of different backgrounds coming together as one in the city. That can only make for a highly vibrant and energetic community.


Buy Property in Germany

Often regarded as THE most expensive city to live in in Germany, Munich is a city full of grandeur and magnificence. The city is very prosperous while still maintaining a close-knit community feeling. The green spaces contribute to this togetherness, as well as the highly elegant cultural life of the residents. One of the most interesting and captivating parts of Munich, especially to foreigners, is Oktoberfest. The festival brings together millions of people from around the world to enjoy German beer and celebrate together.


Located in the south-west of Germany, Düsseldorf is a city known for its fashion industry, and it is regarded as one of the most beautiful in the world. The city has a very modern feel to it, and the art scene contributes to the allure of the city. The city is pretty safe and by all ramifications, a wealthy city.

paraphrase tool

The Importance Of Rewording An Essay

Rewording is a very simple vocabulary, this is a word that comes from the word “word” doing it again is known as rewording. While in an exam room, the adrenalone is always at the highest point. A student is trying to run with time and to ensure that they are getting it right as per what the examiner wants from the questions. In this rush, it is very common for a student to make mistakes or use a word that may not fit exactly what they wanted to express in their essay.  The paraphrase tool is what you need to ensure you are having the correct words in whatever you are writing.

Below are some of the advantages that a student or an editor may get by using the paraphrasing tool in rewording their text data;

Better Results

The level of results you get entirely depends on the effort you make, either by reading and revising or the tools that you used to ensure you have the correct results. The paraphrase tool gives you the option to get better results by helping you reword your text to a better vocabulary that can put your ideas in a better position of description. At no charge, anyone even students can acces this powerful tool online and utilize it to better themselves.

Quality Text Data

paraphrase tool

Quality in text data means a lot to whoever you want to submit the text to. For instance, an employer can not give an employee a contract to produce poor or low-quality text data, then he won’t spend his or her money on you. But an awkward thing with many employers is that they always think that text dealing with text data is the easiest job on this earth. But the wearer of the shoe knows where it pinches most, text data needs a lot of effort and energy to deal with. That is why the paraphrase tool has designed a way you can make your text data to be of high quality and avoid any noise from your employer.

Better Vocabulary

Sometimes a student may think that they have delivered the best, only to be torn down by the results that come after the test has been marked. There is no need to wait for such surprises, paraphrase tool is all you need to get you where you have always dreamt to be. Visit it today from the above link and have your success journey.

Stocks Online

Useful Tips To Buy Tesla Stocks Online

Tesla is one of the topmost electric vehicle manufacturing company. It offers a range of choices for people to buy the bulk of stocks at a cheaper cost. TSLA is a perfect choice to earn more profits in your business. It is an elegant option for investors to gain more profitability in their firm. You can explore earning reports and invest in value stocks. This company access through two segments like energy generation and automotive segment. To buy these shares, you have to choose the best online broker. It allows you to buy stocks and undergo exchange easily. Many investors are gaining wonderful solutions for purchasing these stocks.

Outlook Of Tesla Stocks:

It offers more than millions of shares at the best price to investors. It is a perfect choice to earn high returns on business in less time. It allows you to purchase an eco-friendly and electric automobiles at your required cost. TSLA is selling these products successfully online at the best stock price. Before investing in these shares, you need to understand the stocks and company. It allows you to invest in great and effective products. It keeps increasing your firm rapidly in the market. However, it maximizes your financial performance for a certain period.

Consider Your Portfolio:

To invest in shares, you need to consider the portfolio. It allows you to purchase stocks based on the analysis. You have to explore fund operations and other essential things. You might consider business needs and dividends. It is very important to purchase shares in the stock market. It let you undergo stock exchanges without issues. In addition, it assists you to increase your business position. It helps you sell stocks in trading easily. It let you view complete details of the shares before investing.

Advantages Of Buying Stocks:

TSLA is a popular option among various investors. The majority of young investors are searching for the best company to buy shares. It will be sold depending on the third quarter of the earnings. It offers a strong investment solution for businesses and individuals. It helps you buy shares at a current value. It provides a long term solution for investors. It allows you to purchase autonomous vehicles as per your need. It let you earn high profits in the future years. It offers various opportunities to choose stocks on sales. You might gain more tax credits and increase the demand for your products. So, get expert help and obtain more profits on your business.  You can get more information such as releases at

Disclaimer: The analysis information is for reference only and does not constitute an investment recommendation