![]() Categories Apps Tags fm gb whatsapp old version, gb whatsapp download, gb whatsapp old version 6.10 download, gb whatsapp old version 6.25 download, Gbwhatsapp old version 6.70 download, Gbwhatsapp old version 7.60 apk download, Gbwhatsapp old version 8. You won’t experience any security-related issues because it has the same license as the original product. You’ll believe it to be one of the best apps and that it has the newest features. Sharing this amazing GB WhatsApp APK with your friends would be greatly appreciated. I sincerely hope you will enjoy this information. If you want even more enhanced capabilities, GB WhatsApp Pro v17.00 Download right away and install it on your device. GBWhatsApp furthermore provides the same security and plans as genuine WhatsApp. I wish you much enjoyment using the official GBWhatsApp Old Version. One of the main reasons some of you are using or want to use our app is the availability of additional functionality. GBWhatsApp Old Version is the modified version of WhatsApp which has the same visual design as the original app but more features. The message was hidden after being given but not detected.Create themes that other GBWA users can utilize.Although you can connect to WhatsApp online, not all of its functions work there.Instead of 30 seconds, sharing of video statuses is limited to 7 minutes.Fully functional GB MOD Beautiful themes may be obtained for free from certain GBWhatsApp Dual/Multiple sites that offer theme-changing options.Hide recording status and writing status.The capacity to submit ten or more pictures.You can include stickers from Google Play.For GB WhatsApp users, new and personalized emojis.Click twice to see the concealed online status.You can send video files up to 50 MB in size.Send voluminous audio, video, and picture files.You can also send your contact a 100 MB audio file and a 50 MB video clip. Send Maximum Pictures: Additionally, you are able to send up to 90 photos at once, which is more than what the official WhatsApp app permits. Revocation of many messages at once: This feature allows you to cancel several communications at once. Real-time location sharing: Users of GB Whatsapp 2024 have the option to make real-time location sharing public.Īmazing effects: Users can add beautiful and unique effects to images and videos before emailing them to friends and family. Message filtering: The GB Whatsapp APK contains a message filtering feature that enables users to filter their messages while also having the option to delete conversations.Īnti-revoke message feature: This contains an anti-revoke message functionality. Language: This feature is one of the greatest because it lets you pick a language from the list of ones that are already installed. ![]() You can hide your position as a voice recorder by doing so. You can designate the notice as read from there to show unread messages.Ĭhoose all chats: This program’s main screen allows you to choose all conversations at once. Users who want to use the app privately will find this to be especially helpful.Ĭhanging contacts: You can modify a contact’s media visibility in your gallery. Options for Privacy: The GB WhatsApp Old Version APK has privacy features like the ability to hide your online status as well as double and blue ticks. Previous Messages: The history of all communications sent and received from your contacts and groups is available.ĭND: The software has a Do Not Disturb (DND) feature that enables users to turn off notifications for predetermined intervals of time.Īnti-Ban Function: With the anti-ban feature included in WhatsApp Old Version APK, users can use the program without worrying about WhatsApp banning them. Make your favorite typeface uniquely yours by utilizing this feature. Large file transfer: Unlike the official WhatsApp client, this software enables users to share large files up to 100MB in size.įantastic Font: Do you detest obsolete typefaces? The typeface of your choosing can then be chosen using this option. Options for customization: The GB WhatsApp Old Version APK gives users the ability to alter the chat windows’ backgrounds, fonts, and colors. GBWhatsApp Old Version Download Information: App Name We provide consumers with all previous versions of GBWhatsApp. There are numerous previous versions of GB WhatsApp that have been made available. ![]() If you wish to install the GBwhatsapp APK, you do not need to remove WhatsApp beforehand. ![]() Similar to OGWhatsApp, but with many enhanced features, is GBWhatsApp. It’s yet another impressively modified WhatsApp version. The first version of WhatsApp that has consistently received updates up until this point is GBWhatsApp.
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![]() ![]() Survival mode: The default mode where players have to survive in a hostile environment by gathering resources, crafting tools and items, building shelters, and fighting enemies.It has different game modes that offer different challenges and experiences. This mode has some restrictions, such as a 100-minute gameplay limit and a fixed world seed. ![]() Demo mode: A mode where players can try out the game for free for a limited time.This mode is useful for exploring or watching other players. Spectator mode: A mode where players can fly through the world and observe without interacting with anything.If the player dies, the world is deleted. Hardcore mode: A variant of survival mode where the difficulty is locked on hard and the player has only one life.This mode is designed for custom maps that have their own objectives and rules. Adventure mode: A mode where players can only interact with certain blocks or items that are specified by map makers.This game also has other modes that offer different gameplay experiences: Players can also use commands or data packs to modify the game behavior or add new features. In both modes, players can customize their worlds by changing the game rules, such as turning off mob spawning, enabling cheats, or altering the day-night cycle. Players can also fly freely and place or remove blocks instantly. Players do not have health or hunger bars and cannot take damage or die. In creative mode, players have unlimited resources and can build anything they want without any limitations. Experience points can be used to enchant items or brew potions that grant special effects. Players can also gain experience points by killing mobs or performing certain actions. Players have health and hunger bars that need to be maintained by eating food and avoiding damage. In survival mode, players have to survive in a hostile environment by gathering resources, crafting tools and items, building shelters, and fighting enemies. The gameplay of this game depends on the mode and the settings of the world. This is a sandbox game that gives players a lot of freedom and possibilities. You can play however you want and create your own adventures. There is no fixed goal or storyline in the game. This is a game that encourages creativity and exploration. To access these dimensions, you need to build special portals using specific materials. The game also has different dimensions, such as the Overworld (the main dimension), the Nether (a hell-like dimension), and the End (a dark dimension where the final boss resides). Some biomes are more dangerous than others, especially at night or underground. Each biome has its own features, such as terrain, weather, plants, animals, and structures. The world of this game is divided into different biomes, such as forests, deserts, oceans, mountains, and caves. You can interact with the environment by breaking and placing blocks, using items, crafting, farming, trading, and more. You can explore the world by walking, jumping, flying, or using vehicles. When you enter your world, you will spawn at a random location. You can also play online with other players on multiplayer servers or realms. You can choose the name, seed, difficulty, and game rules of your world. To start playing the game, you need to create a new world or join an existing one. In creative mode, players have unlimited resources and can build anything they want without any restrictions. In survival mode, players have to gather resources, craft tools and items, build shelters, and fend off enemies. It can be played in two main modes: survival and creative. The controls for other platforms can be found on the official Minecraft unblocked website or in the game settings. F1 key to toggle the heads-up display (HUD).The advanced controls for PC can be customized in the options menu. Mouse wheel to scroll through the hotbar.Right mouse button to place blocks or use items. ![]() 4/22/2024 0 Comments Window tint percentages chart![]() ![]() I just had tint shop put a 20% tint on the back of my car, which matched the stripes on my front doors and my windshield. What percent tint are they used on the factory rear window? On September 14, 2020, I joined the LinkedIn group. They look great on both sides, but the back is slightly lighter than the front. You will need 20% more than the factory’s rear quarter to match. The Sahara and Rubicon come with standard tinted rear windows, both hardtops and softtops. The back windows are not tinted, but they are rather smoked glass with a 999 UV b resistance in the 0 UV rating tint. A window set designed with an 18-grain chrome tint gives your Jeep’s aggressive styling a whole new look. These replacement Rear Soft Top Windows from Mopar are factory-made replacements for your original Jeep CJ window. The window style is in all factory colors, so you can match your existing style and make it look like it was manufactured in the original. Since its inception over 30 years ago, the company has provided the most extensive range of vehicle window tint installation services. It includes the original tailgate bars and the same connector rail for attaching them to the side windows. These kits are precision machine cut to reduce installation time and effort because they are equipped with state-of-the-art CAD software. A five percent shade of limo tint is also known as a five percent shade of limo tint. The window set is ideal for your Jeep, including the Bestop Replace-a-Top Super NX or factory soft top. No matter what percentage you choose, window tint can help keep your Jeep cooler in the summer and provide a little extra privacy. If you live in a state that has strict tint laws, you’ll need to make sure you stay within the legal limits. ![]() Just be aware that very dark tints can make it difficult to see out of your Jeep, especially at night. Of course, you can always go darker if you want. This will allow you to see out of the front windows while still keeping the back windows fairly light. In general, most Jeep Wranglers will look best with a 20 % tint on the front windows and a 5% or 6% tint on the rear windows. The answer depends on a few factors, including the state you live in and how much light you want to let in. If you’re looking to add a little privacy to your Jeep Wrangler, or just want to keep the sun out of your eyes, you may be wondering what percentage of window tint is best. ![]() ![]() ![]() If you increased the sales in a retail store you worked for, include the percentage by which you increased sales. For example, instead of saying that you raised money for your organization, include the amount of money you raised. Use numbers to describe your accomplishments as much as possible. If you didn't participate in clubs or sports but held an after-school job instead, focus more on work responsibilities, training, mentoring and on-the- job skills. For example, instead of talking about all the clubs and sports you participated in, choose just one or two and go into greater detail about your involvement with that organization. Focus on the length of commitmentīecause it's ideal to keep your resume to one or two pages, it's important to choose just one or two key experiences you participated in over a longer period. Keep your resume to one or two pages and narrow down what you include to highlight only your greatest accomplishment and things that best represent you as a candidate. Here are some bonus tips to help you create your high school academic resume. Tips for creating a high school academic resume Hobbies like collections you've grown, things you've built or other ways you enjoy spending your time ![]() Passions like making models, reading books or playing guitar Projects like websites you've built, art portfolios or public service projects Social media followings if you've built an impressive number Include any interests that make you especially unique as an applicant. Related: High School Resume Tips and Example 7. If possible, use numbers to measure your impact on the organization. Emphasize leadership opportunities as well as the growth opportunities you received while there. Start with the most recent job and provide a description that includes the company name, your title, the period in which you were employed-or if you are still employed there-and some key accomplishments from the time you were with the company. If you participated in sports, list teams that you were involved in, the length of time you participated and any accomplishments or leadership roles you held within that team. Use action words and include quantifiable results you achieved through your role. Note whether you were a member or held a leadership position and detail specific ways you were involved with the organization. Include any organizations you've participated in through your school or in the community. You may also want to include any AP classes you've taken. Include any academic achievements and awards as well as your GPA if it's above 3.0. Add your educationĪdd the name of your school and note when you will be graduating, if you're still anticipating an upcoming graduation date. If you are applying to college as a photography major, for example, an Instagram page with your photos could be a great way to share your work. You may also want to include a link to your LinkedIn profile that highlights skills, professional experience and community service, an online portfolio or even an Instagram page if it's appropriate. Include your email address and phone number. You can bold it and make the font larger than other text on the document, but make 14 point font the maximum size. Include your name and contact information ![]() Related: Best Font for a Resume: How to Choose Type and Size 2. Here is how the elements should be ordered: Your resume should look simple and clean and be easily readable. The best fonts for your resume at Arial, Calibri or Helvetica. You should have one-inch margins on all sides and use font that's between 10 and 12 points. Your resume should be in reverse chronological order with the most recent experiences listed first in each section. Related: 6 Universal Rules for Resume Writing 1. Include your name and contact information. Here are the basic steps you should follow to create a high school academic resume. How to create a high school academic resume It can be a great way to set yourself apart from other college applicants and give the admissions office a more in-depth look at who you are as a person. ![]() While this resume will include your work history, it is designed to focus more on your high school academic accomplishments, community service and extracurricular activities. View more jobs on Indeed View More What is a high school academic resume?Ī high school academic resume is designed to accompany your college application and give admissions offices a snapshot of your accomplishments, work history, extracurricular activities and hobbies. ![]() 4/22/2024 0 Comments Nier automata huge 2b ass![]() ![]() ![]() It seems like it's merits are the fact it mixes a lot of gameplay ideas onto an RPG package, but it seems like it's weird for the sake of being weird - mostly. A single player game that actually has an end game, kinda like FFXV.Ĭlick to expand.Nier is a game that morphs quite a bit the more you play it. Has satisfying progression for levels, weapons and attacks for your bot. Starts off as a shmup, goes into 3d action adventure, side scrolling action, open world and linear segments, puzzle, Atari-esque mini games, Metroidvania and probably more but I haven't finished it in a while so I don't remember them all Nier meshes many genres of games together. She is closer to 2b but has some unique skills as well. I forgot the last playable character's designation.A.something. The game's story warrants 2-3 playthroughs with 2b and 9s playing very differently. Music is basically unmatched, I dare you to find a "favorite music in a game" thread and not see this game mentioned. Ok since people seem to have selective amnesia, Nier is awesome because: Maybe I'm wrong, maybe the fandom is really just all about dat booty. Personally, I really appreciate the existence of niche cult games, even if many them don't appeal to me at all.Īnyway, that's a lot of text for a mostly pointless counter argument to why every game should have modern save features. If it became too conventional it might appeal to more people but it wouldn't have the same kind of passionate following. I think a large part of the reason Nier as a whole has such a passionate fanbase is due how it does unconventional things, which has an extreme appeal to a smaller subset of people. I'm not going to say the intro of Nier Automata necessarily benefits from this archaic implantation, but I think there's merit to at least try out different things. To me, that totally dissolves any tension in fighting the boss and even makes the entire fight pointless. I think an example of the extremes a forgiving checkpoint/save system can be pushed to is Godfall, where you can literally throw yourself into the boss until he dies, due to the checkpoint system. As a whole, I agree with you that most modern games greatly benefit from efficient and forgiving save systems.īut even so I would argue that you could design a game where a punishing save structure can be a part of whatever experience you're trying to make. ![]() ![]() ![]() I love Kindle and Audible and I hate to give it a bad review but on Mac, this app is garbage. I hate to buy the books twice because I obviously can only do this with the hard copy now (with the added inconvenience of not having the reference on the screen next to what I’m working on). It is infuriating to try to learn something while your app can’t stay on the intended page and 2/3 of your learning time is getting annoyed and fighting the program just to keep the page. I gave up on it a few times, then came back because I already paid for the book and was determined to get through it. ![]() When I ordered another book, this time on Python, it was the same wretched experience. Unfortunately, I forgot about that experience and, being busy with work, didn’t have time for Kindle until recently. Here are the latest news about Kindle: 11.10.23. Then I’d get it right and halfway through the page it would start doing it again. Provides apps for Android, iOS, Blackberry, Windows Phone, Mac, PC and the family of ereading devices The best Kindle alternatives are: Nook, Kobo, Audible. So then I’d have to go back the other way. Clicking to find the page would also result in it going much further than I intended it to. Then I would have to go back and find the page I was on. I didn’t click anything, I didn’t hit any keys. With no input from me whatsoever, the pages jumped forwards or backwards by 2-8 pages. Seven months ago I purchased a book on Javascript and attempted to work my way through it. However, using it on MacOS is frustrating. I’ve used Kindle for years and I have always loved it. It would be nice to at least put bullet points in the "notes" section. I usually have to copy and paste my exported highlights and notes into OneNote and then reformat eveything. I also wish that you could do more formatting with any notes that you take. That way I could export the notes I know I need and found to be highly applicable and important to my work at the time, while still keeping the entirety of my highlights and notes on the app in the event that I need to export all of them in the future. For example, if I only wanted to export the highlights and notes that I starred rather than every highlight and note, then I could do so by applying a filter. I wish that, just as we can filter our highlights and notes in the app, we could do the same when exporting highlights and notes. I do wish there were some more features, particularly when it comes to exporting highlights and notes. If required books for my courses were available on Kindle and had corresponding page numbers, it was typically more cost effective, easier to organize notes, and allowed me to easily read and take notes anywhere. The past two years has found me using it more often for grad school. I've been using this app for years now, but it's been a while since I've used it for leasurely reading. Wish It Had More Features and Capabilities ![]() 4/22/2024 0 Comments Freecell solitaire game online![]() ![]() Two available FreeCells - Move a sequence of three cards Three available FreeCells - Move a sequence of four cards Four available FreeCells - Move a sequence of five cards However, if you want to move a sequence of cards to reach another card you need, you can move them depending on the number of open FreeCells on the table. How Many Cards Can I Move in FreeCell?įor the most part, you are limited to moving one card at a time. However, it’s important to remember that it can't be moved again once placed in a HomeCell. You can also use cards sitting in one of the four FreeCells back to the tableau or a HomeCell whenever you need to. Generally, you can move cards from your tableau to a free cell at any time during the game. Step Four: Use Your FreeCells SparinglyĮach FreeCell can hold one card at a time. Sometimes, stacks of cards (more on moving a sequence of cards later). In that case, you can move a single card from another pile into the previously empty column. Suppose you have played all of the cards in one column. The card’s suit doesn’t matter when moving cards from column to column in the tableau.įor example, you can place a black 7 of Hearts on a red 8 of Diamond or a red 10 of Spades on a black Jack of Clubs. Like the card game Klondike, cards must alternate between opposite colors (i.e., black to red or red to black). However, you must follow specific FreeCell rules when moving a card from one column to another, such as:Ĭards must be placed in descending order from King to Ace. In that case, you have two choices: Move the card to a FreeCell or move it to another column. Step Two: Shift Cards in The Tableauĭuring gameplay, you will often run into scenarios where a card you need is blocked behind another card in the tableau piles. That’s because once a card is in the HomeCell, it can’t be moved again. However, don’t place a card in the foundation pile if you think you might need it later. ![]() Your goal is to build up one HomeCell for each suit. That means you can move it as soon as an Ace becomes available. Start building HomeCells as soon as possible. Learn step-by-step instructions for playing the game of FreeCell below. ![]() You’re ready to dive into gameplay now that you know the basics. FreeCell - Where you can temporarily place any card during the game. HomeCell - Also called the foundation piles, you place cards of the same suit in descending order from Ace to King. The cards should slightly overlap the previous cards in each column.īe sure to leave space above the tableau for four foundation piles (i.e., HomeCells) and four FreeCells. Then, deal seven cards to the first four piles and six cards to the remaining piles in descending order. This row is the beginning of the solitaire tableau. Card Layoutįirst, shuffle the cards and begin dealing one row of eight cards side-by-side face up. Learn more about card layout and basic FreeCell rules below. You play FreeCell with a standard 52-pack of cards (be sure to take out the Jokers). Each HomeCell (also called foundation piles) can only hold one suit of cards (i.e., Hearts, Diamonds, Spades, and Clubs). The object of the game (which is the same in most solitaire games) is to build four suit-specific HomeCells in ascending order, starting with the King and ending with the Ace. Step-by-Step Instructions For Playing FreeCellĪre you ready to start learning all about FreeCell? Get started now. In this article, you will learn the basics of FreeCell, including: If you’re ready to level up your Solitaire skills, we’re here to help. ![]() However, no matter how challenging FreeCell is, it’s still one of the most fun Solitaire games to play. Unlike Klondike Solitaire or Pyramid Solitaire, FreeCell is considered very difficult (especially for Solitaire newbies). Sometime in the 1960s, the then 10-year old Paul Alfille invented what would later become one of the most popular variants of Solitaire: FreeCell. ![]() 4/22/2024 0 Comments Create vector from image inkscape![]() ![]() Choose between single and multiple scans. To open Inkscape’s tracing engine, click Path on the menu bar, then select Trace Bitmap. You’ll discover how to create a vector image adopting a flat design style. use Inkscape to create vector graphics - explore flat design - explore vector graphics By the end of this project, you will learn how to use Inkscape to draw a vector graphic starting from a picture. There are some other formats you can export to as well, such as PDF and EPS. Click File on the menu bar, and then select Import. Import a suitable bitmap image by using the menu File Import. In this 1-hour long project-based course, you will learn how to. Save the vector imageįile > Save and select Inkscape SVG to save the image as a vector. If you have trouble figuring out which is the original, try double clicking on one and if you see a bunch of squares and lines, that is the vector. Now use the mouse to drag the scanned image off of the original. Manually close the scan dialog window since you are done with it. The scanned image will be output exactly on top of the original, so it may not look like anything happened, but we will soon find out in the next step. Import the image into Inkscape, the free vector drawing tool, by going to File > Import. Once you are done, click OK once to execute the scan. You will need to begin with a high resolution bitmap. If you see some details missing, increase the number of scans and update the preview again. Select the Grays option, set the number of scans to 2, and check the box for Remove Background.Ĭlick the Update button in the preview to see a rough preview (the end result will be higher quality). With the newly imported image selected, click Path > Trace Bitmap.Ī dialog window will appear. An import dialog will pop-up, click OK to accept the defaults. In Inkscape, click File > Import and locate the image you just saved. You can search for images online or take a digital photo of a line drawing you made. High contrast images work best such as black and white line drawings, outlines, and silhouettes. ![]() If you haven’t yet installed Inkscape, download it for free (Mac, Windows, or Linux) and then run the installer. This will convert the pixels of the bitmap into line paths that a machine (like a lasercutter) can follow. In this how-to we will show you how to trace a bitmap image in Inkscape to create a vector image. ![]() Inkscape is a free vector drawing program that can be used for creating design files for CNC (Computer Numerically Controlled) machines such as a lasercutter, electronic (vinyl) cutter, milling machine and more. ![]() 4/22/2024 0 Comments Medieval minecraft house![]() Now take some spruce planks and start filling your ground floor. After this, put three spruce trapdoors and finally add a door. Then at a little free section, place three stones, three spruce fences. To make the main entrance to the house, you have to break some stones on one side of the wall. After doing this, your structure will look something like this: Step 4: Build a Doorway + Add the Flooring Repeat the same process with the corner blocks of the tower. Try to keep the pattern as random as possible to get a more natural look.Īfter this, it’s time to replace the main corner blocks with polished andesite. You can also randomly texture the walls with cobblestone and stone bricks. Use stones or blocksĪnd stack them on one another with a total of 5 blocks high. With the layout provided, now let’s start laying our foundation. If you want to add a basement, find land where you can dig easily! Step 3: Build The Foundation The overall shape of the house will be an L-shape, so find a nice flat area to build your house. Step 2: Find a Nice Flat Place For Minecraft Medieval House Here is the list of all the things you need to gather if you build want to build this house for survival: Below is the layout in which we’re going to build our house: Let’s get building, Step 1: Layout and Materials Neededįirst, let’s talk about the basic materials that you’ll need in the construction of this structure. So get ready to design, create, and build. Pretty easy to build from gathered materials, this house could be a great survival place. This construction would fit perfectly in the middle of any medieval village or in a forest. This is a simple build with some traditional style architecture. This medieval house was constructed by BlueNerd. Easy Medieval House by BlueNerd Minecraft How to Build an Easy Medieval House Stylish & Compact Medieval House by Cubey Step 10: Decorate Your Minecraft Medieval House.Step 5: Add The Frame to Build Minecraft Medieval House.Step 4: Build a Doorway + Add the Flooring.Step 2: Find a Nice Flat Place For Minecraft Medieval House.– Additionally, you can build a farming area and a stable to rest your royal horses or Donkeys. – On the top floor, you can also create a library or extra relaxing area. – On the second floor, you can create a bedroom, a portion brewing area, and a walk-out balcony for sniping mobs(enemies). ![]() It has a lot of storage space and a crafting table. – A kitchen is generally built on the main or the ground floor. There is also direct access from the basement to the mining shaft (a small area to install a furnace). ![]() – A basement including furnaces and lots of chest storage. But first, let me tell you some basic features of any Minecraft medieval house.īelow listed are a few common things that are usually included in Minecraft Medieval House: In this blog, I’m going to tell you how to build a Minecraft medieval house in just ten simple steps. So if you’re excited to build your first medieval Minecraft house, keep on reading. These houses will give you aesthetic and authentic antiquated vibes. Whether you want a sturdy Minecraft castle built from stone or a simple rustic village dwelling fashioned from oak, you can make a house in any shape and size. Today in this blog, I’m going to tell you about the Minecraft Medieval House. ![]() ![]() If you’re looking for some house inspirations, you’ve landed on the right page. So, basically in this game, you can build any type of house. Part from Netflix nowadays, unusual Minecraft houses are probably the second most popular thing on this planet! Soon after its first launch, it immediately became really famous, and now everyone is addicted to this fantastic game (including me). ![]() ![]() ![]() ![]() Unlike interrogatories and deposition testimonies, a Bill of Particulars is conclusive as to the items and amounts claimed and no other evidence is admissible at trial. Contact Schlam Stone & Dolan partner John Lundin at if you or a client has a question regarding discovery obligations (and what to do if a litigant is not honoring those obligations).As stated in the blog “ It’s Not a Discovery Device, But…”, a Demand for Bill of Particulars is NOT a discovery device, but an extension of the complaint or a cross-complaint. As this decision shows, a bill of particulars is intended to amplify the allegations of a pleading, not as a substitute for discovery devices, such as interrogatories. The scope of discovery in New York is broad, but it does not include the device discussed here: a demand for a bill of particulars. ![]() (Internal quotations and citations omitted).Ī big part of complex commercial litigation is giving, receiving and evaluating evidence (this is called "discovery"). Accordingly, the Defendants' Demand for a Verified Bill of Particulars is vacated. The Defendants may not avoid the limitation on the number of interrogatories by simply calling it a demand for a bill of particulars. However, such requests are improper in a bill of particulars and must be sought in the form of interrogatories pursuant to Rule 11-a of the Commercial Division Rules or by another appropriate disclosure device. Significantly, the majority of the requests vaguely ask the Plaintiff to "state the basis for the allegations" for nearly every paragraph of the 95 paragraph, highly detailed complaint (Requests 13-75). To wit, the Defendants' Demand for a Verified Bill of Particulars seeks the identification of witnesses with knowledge of relevant information (requests 1 and 2), and a computation of damages (request 11). Here, the Defendants' Demand for a Verified Bill of Particulars, which contains 75 paragraphs, excluding subparts, seeks details more appropriately developed at a deposition and not consonant with the purposes of a bill of particulars. In this case, no such expansion was requested or provided. In addition, the commercial division rules limit interrogatories to 25, including subparts, unless the court provides a different limit in the preliminary conference order. When a bill of particulars is replete with palpably improper evidentiary requests, the proper remedy is vacatur of the bill of particulars. In other words, the purpose of the bill of particulars is to amplify the pleading, limit the proof, and prevent surprise at trial, but it is not a vehicle to obtain evidentiary material. In fact, although the drafters of the CPLR also recommended its abolishment in conjunction with the expansion of the disclosure statutes now found in article 31, the Legislature retained the bill of particulars, not as a disclosure device, but in its traditional and limited role as a means of amplifying a pleading. The bill of particulars has been abolished in many jurisdictions, including in the federal courts, as broader disclosure statutes have rendered them superfluous. 32944(U), vacating a demand for a bill of particulars because it was being used as a discovery device, explaining: On September 8, 2020, Justice Borrok of the New York County Commercial Division issued a decision in Orentreich v. ![]() Categories Commercial, Discovery/Disclosure Demand for a Bill of Particulars Vacated Because it Was Being Used as a Discovery Device ![]() |
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