Jewish Federation Apartments Essay

The Jewish Federation Apartments is a ‘humanitarian’ housing public service organization for the elderly, those who are 62 years and above, and those who may be impaired in terms of mobility, those who are 18 years or older. The Jewish Federation Apartments is a public service offering founded and run by the Jewish Federation of Greater Buffalo. Preservation of the elderly people’s dignity, safety and decency of the occupants of the apartments is the main aim for maintaining the Jewish Federation Apartments. Through the years of activity, the Jewish Federation Apartments offer not only housing but also integrated social activities that encourage the apartments’ occupants to integrate not only with their family members, if any, and the community. Jewish Federation Apartments 1) Describe the agency’s mission statement. Identify the client base of the agency including the cultural groups The Jewish Federation Apartments was started by the Jewish Federation of Greater Buffalo to offer housing and humanitarian care to the elderly as well as those who may be mobility-impaired. The main mission of the Jewish Federation Apartments organization is to offer public service to those aged 62 years and those who are 18 years and older and are mobility-impaired. The main mission is to safeguard the dignity, decency and safety of occupants while offering social services. In any given community or society the elderly and mobility-impaired may feel the need for loving care that would give them the feeling of being a ‘normal’ part of the community. As it may be noted, both the elderly and mobility-impaired may have a sense of need to move around like any other member of the community. The mission of the Jewish Federation Apartments is to ensure that those who qualify to be tenants in the apartments get affordable housing in a safe environment and that their dignity and decency is sustained. Only those who are successful in qualifying for tenancy based on the Jewish tradition would attain residence in the Jewish Federation Apartments. The Board of Directors’, all offering their services voluntarily, goal is to ensure that the personal dignity, physical, emotional and spiritual life is of enhanced quality. These are all in the fulfillment of the Jewish Federation Apartments’ mission. According to the president of the Jewish Federation Apartments, that I interviewed, the place is predominantly occupied by Jews but this may only be so due to the fact that the apartments are a public service offered by the Jewish Federation of Greater Buffalo. Another reason this may be so is due to the fact that qualification for occupancy/tenancy is guide by the Jewish tradition. This, and many factors, has seen the apartment’s occupancy be mainly of Jewish oriented persons, though there are other cultures and other religious occupants such as the Polish, Italians and Persians. The Jewish Federation Apartments has always advertised or sought to attract applicants from all cultures religions, ethnicities and communities and this has seen it achieve its current diversity of occupancy cultures. The Jewish Russian community seems to be one that has the highest occupancy numbers; however, other communities are also increasing in number. In the past approximately half of the Jewish Federation Apartments was from the Jewish Russian community that moved to America a long time back. However, in recent years, this has changed and the Jewish Russian community seems to be reducing to about 35-40% of the whole community says the Jewish Federation Apartments president. Despite having an open invitation to all ethnics and religions and communities, the Jewish Federation Apartments seems to have low attraction of the African American community. The main reason why there seems to be no African Americans is that, the community seems slow to accepting change from their communities and neighborhoods. The African Americans seem not too keen on moving from their neighborhoods. This then explains why Jewish Federation Apartments’ occupancy has no African Americans despite there being a waiting list of the community, reveals the Jewish Federation Apartments president during the interview. Current occupation in the apartments is mainly of whites as African American communities are slow in taking up the challenge of change that may come from moving from their communities. In the past the African American were tenants in the apartments, however, they seem to have moved out since currently there are only a white population of tenants remaining. All these were revelations from the interview that I carried out with the president of the Jewish Federation Apartments. Despite there being a waiting list from the African Americans at the Jewish Federation Apartments, they do not want to move there yet. 2) Describe the agency’s cultural and linguistic competency plan Culturally, the Jewish Federation Apartments agency has been diversified, however with a reduced attention and interest from the African American community. The agency’s efforts to attract all communities to consider occupancy at the apartments have been generally attractive and open to all. Advertisement for apartments is open to everyone who is over 62 years and those who are above 18 and are mobility-impaired. The culture of the agency is to care safeguard and ensure that every tenant’s decency and dignity is enhanced. The current situation seems to lean more on the Jewish setting. Since the agency is in a predominantly white community, the cultural orientation may be leaning to the whites’ culture. The African American community on the other hand seem to be holding on to their cultures since they seem adamant about moving to the Jewish Federation Apartments despite a past occupancy and application for consideration for tenancy. Jewish Federation Apartments agency culture is that of a friendly and social environment that allows the tenants to interact though there are policies that govern occupancy of the premises by ‘outsiders’. One may therefore be right to say that the agency is well out to protect the qualified tenants and the community of Jewish Federation Apartments. One culture that the Jewish Federation Apartments community seems to have adapted is that of organized friendly activities that ensure all tenants have some sought of meeting point to engage in friendly socializing activities. In this way, many who may be old and rather disoriented would be uplifted emotionally and spiritually. By using a clear and concise tenant handbook, the agency’s aim is to give clear tenancy regulations that must be followed. By doing this, the agency is able to enhance the culture of organization and responsibility. This means that tenants are able to correlate and live peacefully with one another. The cultural plan of the agency is to maintain an open community culture that would ensure that all tenant correlate and live with harmony under the rules and regulations. Adequate, clear and precise communication has been one main challenge for the agency. Clear communication among all thee different language speakers, understanding each other and having clear and understandable communication with the agency are among the language challenges the agency faced. The legal tenancy documents print language, as well as all kinds of communication have to be clear and understandable. Linguistically, there has to be clear communication in order for all to understand each other. In order to make this possible, the agency would have to produce/print communication materials in understandable tenants’ languages. In the past, the agency printed documents in two main languages; English and Russian. This may be a sign that other language speaker, though of minority groups, may also desire to be able to get materials written in their language so they can understand. Legal documents are important and crucial and must be well understood to avoid any legal or regulatory conflicts. The agency may make plans to ensure that all tenants get these legal tenancy documents in languages that they can understand, however, since people who speak other languages seem to be quite few to justify the cost of translating these documents to specific individual languages. Past translations made to Russian have proven challenging since Russian tenant challenge the agency for not giving accurate translations. This may be a challenge of language translation that may affect may other language translations unless there be a specialized organization making standard and accurate translations. Lack of an official translation made the U. S. Department of Housing and Urban Development (HUD), want to translate English to other languages such as Russian, Spanish, French, Polish, Chinese and other languages. Though this has not been done by HUD yet, it would give positive response if done, says the agency president. If the U. S. Department of Housing and Urban Development (HUD) translated, the tenants may feel that the translation was done accurately and of higher standard. In the past, the agency had tried to make Russian translations as this would seem cost effective considering the Russian population that justified the translation efforts. The main translators that the agency has used in the past for the Russian language were the language institute as well as Russian translators. This has however not proven to be fully accepted by the Russian community. The community claims that the translations are not accurate hence posing a translation challenge to the agency. The main plans made by the agency to bridge cultural and language barriers are: †¢ From the interview with the Jewish Federal Apartments’ president, it seemed apparent that language would be most tasking and most challenging to the agency to deal with. During meetings tenants have had to come with translator who would translate to them so they would understand the meeting proceedings. †¢ The agency has made efforts to have its notices written in Russian as well and placed on the bulletin board. This would be a sign that the agency is making an effort towards fulfilling the laid out cultural and linguistic competence outlined by the National Standards on Culturally and Linguistically Appropriate Services (CALS). †¢ In an effort to make communication between the agency and the tenants clear, when a tenant goes to the agency offices, he/she has to go with a translator who may be a relative, friend or fellow tenant. This, as easy as it my seem, is one of the many culturally and linguistically challenging issue that the agency may have to address urgently as availability of a good and accurate translator may require one who is neutral well versed with both languages i. e. the agency’s and tenant’s languages. †¢ English training is offered by the agency twice a week at the agency premises. This seems to be one of the agency plans to make communication with the tenant s easier and cost effective instead of having to translate all communication materials and finding a translator for each tenant speaking other languages. The main challenge with this kind of plan may be the ability, willingness and availability of the tenants to attend the classes. Great efforts were made in housing and urban development programs to facilitate affordable housing. Culturally competent services did not have a successful impact. To prove this, one may say that even with bilingual services and culturally appropriate information, caregivers do not consider that many minorities did not read or write in their native tongue, so that traditional mainstream communication methods were not reaching them. More importantly there were still not enough minority providers and caregivers (cited in Lecca et al, 1998). All plans by the agency to ensure that it conforms to the standards of CALS may seem rather wanting. However in order to ensure standard culturally and linguistically appropriate services, the agency would have to put more effort into ensuring that all tenants cultural and language needs are considered and integrated into the agency’s policies and culture. It may be recommended to the agency to work with HUD and CALS and other human service organizations to ensure a level of conformity to the standardized operational policies. Cultural competence is based on an organization’s policies, principles and structures working effectively across all cultures. Organizations have to contain the capacity to value diversity in cultures and linguistics, carry out self assessment to ensure they can manage the dynamics of visible diversity, have cultural knowledge and adapt to the diversity and cultural differences of the people and communities they serve/work with. In this way all individuals will have a sense of care and respect, decency and dignity as well as pride in their culture and language. This is the agency’s main objective and one that may help it conduct a self assessment to ensure conformity to these basin cultural competence guidelines . Organizational processes of policy making, management and administration as well as service delivery should be based on the foundation of cultural competence by considering and integrating the community or those they serve in all processes. The agency’s capacity to offer effective communication and convey information that is easily comprehended by all persons including those with low English proficiency, seemingly low literacy, and/or any form of disability would only be reviewed by the agency itself. The current situation at the agency implies a need for this to be accomplished to ensure all tenants’ cultural, linguistic and communication needs are well catered for. 3) Examine how the policies are implemented The Jewish Federation Apartments agency follows policies developed by the U. S. Department of Housing and Urban Development (HUD). The HUD leases are the ones that have to be implemented and used by every house and its rules have to be followed. Individual human and support services offered by the agency have to be in the preferred language and communication medium of the tenants and community served. For this to be accomplished, the human service organizations such as the agency have to ensure that the policies conform to the government and/or local mandates that may be governing language access. Besides the lease document developed by HUD, the agency has house rules it has developed and documented. This two guiding documents have used at the agency by all tenants and observed by the staff, all communicated in English and Russian. All documents pertaining to the lease and house rules are communicate and provided to all tenants so as to ensure smooth operations at the agency apartments. According to Lecca et al, the health social and human service practitioners of today are no longer faced with patients/consumers of only one culture, but also with those who are of different cultural backgrounds and with different needs. With the changing and current demographic settings, agencies and human service providers have then to be culturally competent so as to meet the rapidly growing minority population. 4) Design a cultural and linguistic competency policy for the agency and suggestions of implementation strategies to improve the cultural and linguistic competency of the agency. Most social scientists and human service experts agree that if our community is more educated, better trained and healthier, productivity is an inevitable result. Housing projects and alternative community training employment and educational services have also incorporated culturally based competence service and methodologies with some success. In order for the agency to be competent in cultural and linguistic policies, there has to be a level of commitment that is not dependent on the availability of resources but rather on the aim of equitable, respectful, understandable and effective human service delivery. In order for this to be effective, a change in policy and policy implementation processes has to be implemented. Linguistically and culturally all ethnic and religious communities must be equally considered and served. All services offered by the agency have to be equally and clearly communicated to all culturally and linguistically diverse tenants. This kind of communication must also be clear, concise and understandable in the tenants preferred language and mode. In a bid to make this quest for equal, clear and understandable communication, the agency must collect all relevant data and information on all the tenants’ ethnicity, religious, cultural and family background before the lease of tenancy is offered and tenancy in commenced. Culturally and linguistically competent policies and communication frameworks have then to be implemented to ensure that the agency is culturally and linguistically competent. A policy or policies that may be implemented would be: †¢ Board of Directors and staff must exhibit behavior that can help build trust and understanding in the diverse agency. †¢ The agency has to strive to promote a feeling of acceptance for all tenants and staff to ensure both do work together to make the agency culturally and linguistically competent. †¢ The agency must be culturally and linguistically sensitive to the values of its management and operational processes and techniques. †¢ When the Jewish Federation Apartments’ tenants express doubts, concerns and feelings of need for some help or action to be taken on any given issues, whether it concerns their tenancy, environment or service, the agency must demonstrate acceptance and understanding of the problems by identifying clearly, the employees concerns and discussing them thoroughly. †¢ The agency must show consideration, respect and understanding to all tenants at the apartments. †¢ Since minorities may not be prompt and willing to reveal that they may not understand the language of communication, all modes of communication such as diagrams should be used to ensure that agency-tenants communication is clear and understandable. †¢ All communication whether verbal or written should be in the tenant’s preferred language, respectable, concise and understandable. †¢ The agency should implement strategies to recruit, retain and promote at all levels of the organization, diverse staff and leadership that represents the demographic qualities of the Jewish Federal Apartments’ tenants. In the past the agency seemed to have been challenged by the notion or reality of having to conform to standard culturally and linguistically competence. Currently this may be achieved if only the agency would: †¢ Work with the existing standard and well known translators to make translation of all communication materials that all can understand. †¢ If translators are needed the agency should try and have staff be the ones translating other that tenants bringing their own translators. This would help them avoid situations where a tenant’s own translator, being a relative or friend, being unable to translate some word that may be embarrassing. †¢ The agency should offer language assistance at no cost and inform the tenants that this service is available by posting a notice on the notice board. This would ensure that all tenants are informed of the ‘right’ to language assistance. †¢ Knowledge and general understanding of the Jewish Federal Apartments tenants’ cultures should be encouraged for all staff. This would help them communicate effectively especially in case of an emergency. In conclusion, in order for the agency to attain effective and efficient culturally and linguistically competence, it will have to embrace the fact that diversity of cultures, languages, ethnics e. t. c. in inevitable. This will then help the agency ensure that its prepared for competent service delivery. References Jewish Federation Apartments (2007), Tenant Selection. Retrieved April 19, 2009, from http://www. jewishfederationhousing. org/selection. html Lecca, Pedro J. , Quervalu, I. , Nunes, J. V. , & Gonzales, H. F. (1998). Cultural Competency in Health, Social and Human Services: Directions for the Twenty-first Century. NY: Garland Publisher. Fong, Rowena (Ed). (2004). Culturally Competent Practice with Immigrant and Refugee Children and Families (Social Work Practice with Children and Families). NY: The Guilford Press. U. S. Department of Health and Human Services Office of Minority Health (2001), National Standards for Culturally and Linguistically Appropriate Services in Health Care. Retrieved April 14, 2009, from http://www. omhrc. gov/templates/browse. Aspx? lvl= 2&lvlID=15 U. S. Department of Housing and Urban Development’s Office of Policy Development and Research (2009), About HUD. Retrieved April 16, 2009, from http://www. hud. gov/ about /index. cfm Personal communication, April, 2009

Ben Franklin and Thomas Paine Essay

From the end of the 1700s and through the early 1800s, America was beginning to see a change in civilization. People were moving from Puritan thoughts and ways towards a new way of a less superstitious, more scientific and intellectual interchange. This movement called the Age of Enlightenment influenced the styles and writings of those like Benjamin Franklin and Thomas Paine. The Age of Enlightenment was a period of questioning and appliance of reasoning to explore many subjects, such as civil rights, often left untouched. People were leaving behind their Puritan pasts and advocating the use of scientific method instead of superstitious beliefs of religion. The Enlightenment takes its name from those who wanted to contribute to a brighter future and society. According to Henry Clark, â€Å"Paine’s importance rests on the fact that he was an idealist, a man who envisaged a happier way of life for all men in the future, who thought in the light of first principles such as the equality and sacredness of all souls before God, and who, since he believed that in the past the life of the common people had been miserable, demanded a sharp break with the past, with tradition† (Clark). He wrote â€Å"Common Sense† even though he was acting in treason because he held firm to his beliefs that America should be independent.. He uses many techniques while writing, one being the overall patriotic and simple tone. Staying away from Latin phrases or philosophical arguments, Paine wrote â€Å"Common Sense† in simple terms, referring to the Bible and making the overall tone similar to that of a sermon. For example, he writes, â€Å"In the following pages I offer nothing more than simple facts, plain arguments and common sense† (Paine 335). He wanted to make sure that all Americans could understand the idea of independence, and that independence from England could be achieved. Paine also uses a number of aphorisms to introduce his argument. By doing so in â€Å"The American Crisis†, he captures the readers, allowing them to understand these small, witty statements on a personal level. For example, Paine writes, â€Å"The harder the conflict, the more glorious the triumph† (Paine 345). By using aphorisms, he was able to hint the audience of what is to come throughout his writings. In another example he writes, â€Å"These are the times that try men’s souls† (Paine 345). These aphorisms make the reader think and ask themselves questions that are later answered through the text. The Age of Enlightenment was also evident in Benjamin Franklin’s writings. The Autobiography† establishes in literary form the first example of the fulfillment of the American Dream. He writes of the possibilities of life in America through his own rise from the lower middle class as a youth to one of the most admired men in the world as an adult. Furthermore, he states that he achieved his success through a solid work ethic. For instance he writes, â€Å"It was about this time that I conceived the bold and arduous project of arriving at moral perfection† (Franklin 307). He wants have that American dream, so he comes up with the thirteen virtues to help him. He proved that even undistinguished people can, through industry, become great figures of importance in America in his writings. His â€Å"The Autobiography† also reflects idealism. He somewhat writes of intellectual flourishment and political thought and during part two, he is trying to live them out. According to Betsy Erkkila, â€Å"while the Revolution is not present as part of the manifest content of Franklin’s narrative, it is present as the political or narrative unconscious of Franklin’s â€Å"Life†Ã¢â‚¬â€œas a scene of social crisis, bloody contest, and challenge to traditional structures of authority in family, society, church, and state† (Erkkila). This meaning that even though it wasn’t spoke of directly, the revolution was desired by Franklin so others could have the American dream and achieve as he did. In conclusion, the Age of Reason, or The Enlightenment was a good period for the New World. Through the literary works of those such as Paine and Franklin, they helped create and mold the definition of America and the American dream. Franklin and Paine used numerous styles of writing such as aphorisms, themes like the American dream to help America succeed.

Land Law – Proprietary Estoppel

Proprietary estoppel protects a person who has a non contractual agreement over land but they have suffered a detriment due to them acting upon a reliance based on an assurance made by the claimant. There has been much discussion in recent case law and academic commentaries as to the elements which make up the nature of proprietary estoppel. Unconscionaibility is a major point for discussion in deciding whether it should be treated as a separate element or if it is linked into the three main elements.This essay will consider and discuss the nature of proprietary estoppel and the two views on unconscionaibility; whether there will always be unconscionaibility if there has been a non-performance of an assurance causing the claimant to suffer a detriment based on the assurance which they relied on or if unconscionaibility should be proven as a separate element in each case.The starting point of proprietary estoppel was in the case of Willmott v Barber (1880) where five criteria were lai d down, which had to be satisfied by a person claiming proprietary estoppel and the courts applied these criteria to a wide range of proprietary estoppel claims.However these criteria were criticised for being too strict leading to the broader approach established in Taylor Fashions Ltd v Liverpool Trustees Co Ltd (1982) where Oliver J stated: ‘whether, in particular individual circumstances, it would be unconscionable for a party to be permitted to deny that which, knowingly or unknowingly, he has allowed or encouraged another to assume to his detriment’. Although the approach became broader there still remained essential elements which must be satisfied for a successful claim.The more modern approach towards proprietary estoppel is based on three main elements, firstly an assurance of land or property being made to the claimant, the claimant relying on the assurance which has been made and finally the claimant suffering a detriment as a consequence of relying on the a ssurance made. The main point for discussion and questioning in proprietary estoppel is the role of unconscionaibility and whether it should be treated as a fourth element which too must be satisfied in order for a claim to be successful or if unconscionaibility is interlinked with the other elements of proprietary estoppel.Proprietary estoppel acts as ‘a sword and a shield’ and can be used in one of two ways. ‘Put positively, the reason why it is possible to use proprietary estoppel to generate a property interest in a favour of a claimant despite the absence of the normal formality rules is because of the need to prevent unconscionable conduct. This is why unconscionaibility is the foundation of estoppel. It is the antidote to the otherwise fatal absence of formality. ’ This is one of the views on unconscionaibility which suggest that unconscionaibility is at the heart of proprietary estoppel rather than a separate element of it.The first element of propr ietary estoppel is encouragement where the claimant’s belief that they would have some rights over land or property has been encouraged by the promisor and this could have been done actively or passively. Active encouragement is seen in common expectation cases where the claimant has been actively persuaded through an express representation as in Inwards v Baker (1965) where a son was actively encouraged to build on his fathers land in the expectation that it would be his in the future.Common expectation cases are dealt with more generously by judges, compared to passive cases, as the promisor has lead the claimant to have a reasonable belief that they would acquire the land therefore leading them to rely upon that assurance causing them to suffer a detriment. It would be seen as unconscionable in a common expectation case for the claimant to have been encouraged to suffer a detriment for the promisor to then go back on their assurance, meaning that unconscionaibility is inst antly a running theme in the elements as it can be seen at the first instance and should therefore not be treated as a separate element.The encouragement could also be passive, for example a land owner standing by watching someone build on their land knowing that somebody is acting under a mistaken belief. The nature of a passive expectation made to the claimant can be distinguished in commercial and domestic cases as was seen in Cobbe v Yeoman’s Row Management Ltd (2008) where the House of Lords established that the expectation of an interest in land should not be vague in a commercial situation.The expectation should be for ‘a certain interest in land’ for proprietary estoppel purposes which was not the expectation held by Cobbe therefore the expectation was held to be too vague. Lord Scott stated ‘Unconscionaibility in my opinion plays a very important part in the doctrine of equitable estoppel, in unifying and confirming, as it were, the other elements. If the other elements appear to be present but the result does not shock the conscience of the court, the analysis needs to be looked at again. This statement shows how case law endorses the unconscionaibility approach as being interlinked with the other elements of proprietary estoppel however if all of the elements are not satisfied there can not be a claim for proprietary estoppel as is the case here. In domestic (family) cases, the nature of the expectation doesn’t have to be so specific as long as there is an interest or right in land that would amount to a significant expectation. The assurance made must be clear enough so that claimant is found to have relied upon.Lord Walker stated in the case of Thorner v Major (2009) â€Å"There is no definition of proprietary estoppel that is both comprehensive and uncontroversial†¦the doctrine is based on three main elements, although they express them in slightly different terms: a representation or assurance made to the c laimant; reliance on it by the claimant; reliance on it by the claimant; and detriment to the claimant in consequence of his (reasonable) reliance† One view on unconscionaibility stated that ‘Once there has been detrimental reliance on an assurance, it is unconscionable to withdraw it’ therefore if it cannot be proven that an assurance existed then it wont be unconscionable for it to be withdrawn showing that unconscionaibility is a running theme within proprietary estoppel rather than a separate element. One difficulty in deciding these kinds of cases is that although an assurance has been made to the claimant in the way of a will, the claimant is also aware that the will could be revoked at any time therefore the question to be asked is whether their reliance based on the assurance was adequate. The second element of proprietary estoppel is reliance where the claimant must have been encouraged to rely on the promisor’s assurance which has caused them to s uffer a detrimental loss by changing their position and there must be a sufficient causal link between this in that the encouragement must have caused the detriment suffered.Reliance can not be treated as an element alone it has to have caused a change in the position of the claimant, if no detriment has been suffered then there can be no claim for proprietary estoppel. There are several ways in which the courts can show how the claimant was influenced to rely on the encouragement; firstly is by clearly showing that there has been a change in position by the claimants positive act, for example the claimant spending money on the land or making property improvements based on the assurance that it will become theirs, causing them to suffer a detriment. Where the claimant has acted in a way different to what he would had the assurance not been made nd relied on this can also show how the encouragement has influenced the reliance causing a detriment as in Jones (AE) v Jones (FW) (1977) w here a son acted on the assurance of property becoming his left his job and house to live with his father, however had the assurance not had been made he would not have done this leading to the detriment that he suffered. There can be a presumption made that the claimant relied on the assurances given to them based on there conduct and in these cases the burden is put onto the other party to prove that the claimant did not rely on the promises made and this is hard to prove as it is a subjective matter based on the claimants state of mind. This was the case in Greasley v Cooke (1980) where the defendant did not have to prove that she relied on assurances as it was presumed from her conduct.The final element of proprietary estoppel is that the person must have suffered a detriment due to the reliance on the assurance which has caused a change in their position. The detriment suffered can be in many forms not just that of financial detriment although it must be substantial in making i t unconscionable for the land owner to withdraw their promise of land to the claimant. Walton v Walton (1994) shows where financial detriment wasn’t the main detriment suffered, the claimant had suffered a personal detriment as he had spent years of his life relying on the assurance made to him that the farm would one day be his, and he couldn’t get those years of his life back. Public policy in formalities of contracts plays a major part in the deciding claims for proprietary estoppel.Section 2 Law of Property (Miscellaneous Previsions) Act 1989 states that (1) A contract for the sale or other disposition of an interest in land can only be made in writing and only by incorporating all the terms which the parties have expressly agreed in one document, or where contracts are exchanged, in each. This act stops informalities in land transfers where a claimant would be expected to sign up a contract but hasn’t done so, as in Cobbe, and this is where they would turn to proprietary estoppel to try and show that the detriment which they have suffered is due to the unconsionability of the removal of the assurance which they had originally relied on. Proprietary estoppel acts as a way around formalities and a form of protection for those who have not followed contractual formalities in the transfer of land.Why should people be able to use proprietary estoppel to make a claim for land where they have followed formalities and drawn up a contract as in Cobbe, it can be seen that it is not unconscionable for the promisor to withdraw as there is no contractual agreement. However in domestic cases where there wouldn’t always be an expectation of a legal contract to be drawn up proprietary estoppel can stop unfair decisions being made due to the lack of formalities where it would be unconscionable for the defendant to suffer a detriment due to an assurance on which they have relied. There are clearly two competing arguments against proprietary esto ppel, the first being that ‘once there has been detrimental reliance on an assurance, it is unconscionable to withdraw it. Indicating that unconscionaibility is a function of the three elements. If unconscionaibility was seen as a separate element then it would be pointless in having formalities as it wouldn’t matter whether it was unconscionable or not as long as the other elements had been satisfied. The second view on unconscionaibility is that of it being a separate fourth element and in some circumstance this can be seen as being successful for example in commercial cases where the first three elements of proprietary estoppel have been established but it would be unconscionable for the claimant to benefit due to the lack of formalities and contractual agreement.Therefore although in some cases unconscionaibility being treated as a separate element is beneficial in some circumstances, it should be treated as function of assurance, reliance and detriment as a withdra wal of the assumption in most cases is unconscionable. Bibliography Roger Sexton and Barbara Bogosz, Complete Land Law: text, cases and materials, (2nd edn. Oxford University Press 2011) Diane Chappelle, Land Law, (8th edn. Pearson Longman, London 2008) Martin Dixon â€Å"Proprietary Estoppel and Formalities in Land Law and the Land Registration Act 2002: A Theory of Unconscionaibility† (2003) 2 Modern Studies in Property Law ——————————————– [ 1 ].Roger Sexton and Barbara Bogosz, Complete Land Law: text, cases and materials, (2nd edn. Oxford University Press 2011) 323 [ 2 ]. Willmott v Barber (1880) 15 Ch. D. 96 [ 3 ]. Taylors Fashions Ltd v Liverpool Victoria Trustees Co. Ltd (1982) QB 133 [ 4 ]. Roger Sexton and Barbara Bogosz, Complete Land Law: text, cases and materials, (2nd edn. Oxford University Press 2011) 328 [ 5 ]. Nigel Gravells, Land Law: Text and materials, (4 th edn. Sweet and Maxwell, London 2010) 589 [ 6 ]. Martin Dixon â€Å"Proprietary Estoppel and Formalities in Land Law and the Land Registration Act 2002: A Theory of Unconscionaibility† (2003) 2 Modern Studies in Property Law, 177 [ 7 ]. Inwards v Baker (1965) 2 QB 29 [ 8 ].Diane Chappelle, Land Law, (8th edn. Pearson Longman, London 2008) 87 [ 9 ]. Cobbe v Yeoman’s Row Management Ltd (2008) 1 WLR 1752 [ 10 ]. Roger Sexton and Barbara Bogosz, Complete Land Law: text, cases and materials, (2nd edn. Oxford University Press 2011) 330 [ 11 ]. Roger Sexton and Barbara Bogosz, Complete Land Law: text, cases and materials, (2nd edn. Oxford University Press 2011) 343 [ 12 ]. Thorner v Major (2009) 1 WLR 776 [ 13 ]. Diane Chappelle, Land Law, (8th edn. Pearson Longman, London 2008) 90 [ 14 ]. Roger Sexton and Barbara Bogosz, Complete Land Law: text, cases and materials, (2nd edn. Oxford University Press 2011) 338 [ 15 ].Roger Sexton and Barbara Bogosz, Complete Land Law: text, cases and materials, (2nd edn. Oxford University Press 2011) 338 [ 16 ]. Roger Sexton and Barbara Bogosz, Complete Land Law: text, cases and materials, (2nd edn. Oxford University Press 2011) 338 [ 17 ]. Greasley v Cooke (1980) 1 WLR 1306 [ 18 ]. Diane Chappelle, Land Law, (8th edn. Pearson Longman, London 2008) 89 [ 19 ]. Law of Property (Miscellaneous Previsions) Act 1989 (s. 2) (1) [ 20 ]. Diane Chappelle, Land Law, (8th edn. Pearson Longman, London 2008) 89 [ 21 ]. Martin Dixon â€Å"Proprietary Estoppel and Formalities in Land Law and the Land Registration Act 2002: A Theory of Unconscionaibility† (2003) 2 Modern Studies in Property Law, 179

Art Essay Example | Topics and Well Written Essays - 500 words - 47

Art - Essay Example The smaller frame has a golden lining around it making the breakage of the black color clearer and more defined. The entire frame seems to be made out of wood. In the painting that appears in the picture, there are two people, a male and a female, who seem to be dancing. The girl is shorter than the man and she is in the foreground of the picture. The girl may be shorter than the man because she is leaning forward. She is wearing a short white dress with a purple band around her waist. The lower waist of the girl’s skirt is flared and seems to have pleats. The girl is leaning forward and is supported by the man from behind. She has spread her hands in the air to look like she is flying. Her left hand is spread lower than her right hand. She has lifted her right leg way up in the air from behind. The whole body of the girl can be seen. The girl in the picture appears to be smiling. Her eyes seem to be closed and her face is facing down at an angle. Her hair is short and black. The man in the picture is standing straight behind the girl. He is wearing a white shirt with a dark suit. The man has a black hat that has a red flower and white feather on the front left side. He seems to be looking down towards what the girl is doing. The man has yellow, long and curly hair. Both the man and the girl are averagely slender. The man and girl look like they are in a forest. Several green leafy trees can be seen around them and behind them. The blue clear sky is visible in the background. Not the whole sky can be seen because it is blocked by the trees. Only some parts of the sky are visible through the spaces left by the trees. The picture is an up-close photograph of a painting that shows two people performing. The background of the picture is not clear. It is difficult for one to pinpoint that the plantations behind the two people are actually trees. Color variations have also been used to show the different features of

A Hotel Fire Strategy Assignment Example | Topics and Well Written Essays - 2000 words

A Hotel Fire Strategy - Assignment Example The admeasurements of the staircases are also not provided. We assume width of each staircase to admeasure 1400 mm and of 5 meters height. â€Å"Elements of structure such as structural frames, beams, columns, load bearing walls and floor structures† are insulated from fire. The hotel owners have left nothing to chance while preparing the building for the hotel. Adequate care and provisions have been made that chances of fire is remote and even if it does takes place, it causes minimum damage (Buildings Other Than Dwelling Houses, 2007, p71). My work is to organize fire strategy for the entire hotel and comprises compartmentation, fire suppression, other internal fire spread and external fire spread Compartmentation The cinema on the ground floor has sprinklers. These sprinklers become automatically activated in the event of a fire. The closest sprinkler to the spot of the fire gets first activated. The heat above 45 degrees is immediately sensed by the sprinklers setting off water jets sprouting towards the fire. There are 30 sprinklers spread over the cinema. Four sprinkles are fixed on each wall totaling 16 all around the walls. Another 14 sprinklers guard the ceiling, 3 each in four rows and two hover over the screen (Buildings Other Than Dwelling Houses, 2007, p783). The cinema is one whole auditorium. So it is not possible to compartmentalize by means of walls or any other partition. The walls, floor and ceiling are, however, fire-proof. There are four large exit point that lead outside the building premises from the cinema. There are another four exit points that lead to the lobby of the ground floor. But these exit points have a wall in between the lobby and the exit points. There is a t en-foot passage between the exit points and the wall that lead to the main entrance of the hotel. An emergency exit almost the size of the passage width at one end of this passage leading outside the building premises is opened at the end of the shows to enable the viewers make their exit. Viewers are not allowed to exit from the hotel lobby except in emergency situations such as fire. The capacity of the cinema is 200 persons. In case of fire towards the exits leading outside the building, the viewers will naturally make exit from the exit points towards the lobby. A hundred viewers will exit from the lobby which will be opened for the exiting viewers in view of the emergency situation, and another hundred will exit from the emergency exit leading outside the building. The doors leading into the cinema are fire-proof. However, the large, dark curtains within the doors are not fire proof. Nevertheless, fire to these curtains will not result in large scale damage since the walls and floor are fire-proof. The seating arrangement in the cinema is fire-proof. The screen is not fire-proof. But sprinklers overhead will sprout water jets immediately the screen catches fire. Overall, the complete cinema is well-prepared for evacuation in case of fire. There are three fire

Employee Benefits Essay Example | Topics and Well Written Essays - 750 words

Employee Benefits - Essay Example Companies also offer these benefits as acts of appreciation in order to take care of the well being of its human capital. The purpose of this paper is to study different types of employee benefits and its how they can be utilize as part of a company’s strategic plan. Two types of mandatory fringe benefits that employees working for companies receive are social security and unemployment insurance benefits. Companies match the 7.65% percent employees pay to the federal government for their social security pension plan and Medicare benefits. The unemployment insurance is an insurance the employer buys from a governmental agency that pays employees money in case the employee gets fired for up to year on a bi-weekly basis. Other mandatory benefits employees received from companies are a certain amount of sick days and vacation days per year. The typical approximate benefit of accumulated vacation and sick days is ten sick days a year ten vacation days per year. The other types of benefits companies can offer are voluntary benefits to their employees. A benefit package a company can offer to their employees includes benefits such as health plan, dental plan, company cars, gas allowance, Christmas bonus, flexible time, tuition assistance, training and development opportunities, child day care, elderly care and credit unions among others. A total package of benefits is offered by companies for two main strategic reasons. These two strategic objectives are to enable a company to recruit top talent and in order to retain trained employees in the firm. Offering benefits such as child day care is a very valuable benefit for a single mother. It enables these women to work, while having the reassurance that their children are receiving a proper care which at times costs thousands of dollars a month. A health plan is a benefit that protects the health of the employees and provides the medical financial assistance needed in those times when employees

Staffing Strategy for a New Plant Essay Example | Topics and Well Written Essays - 750 words

Staffing Strategy for a New Plant - Essay Example In the same way, the high population will act as a major source of labor that is essential in the production facilities of the company. One of the major advantages of Minneapolis is the advanced education system that has resulted to high number of skilled human resource. For example, University of Minnesota, one of the major higher institutions of learning in the region produces high number of graduates that will play a major role of providing key staff including the plant manager, product designers, assemblers and warehouse workers. Based on the high initial capital of establishing the new plant, Household Consumer Enterprises should ensure that the plant manager come from inside the current managerial ranks. In this way, the company will not incur high costs in terms of the high salaries that an external manager will demand. In the same way, since the company aims at producing closely related products, an internal manager has adequate knowhow on the challenges faced by the products in the market. In this regard, an internal manager will adequately drive the new plant towards attaining its initial goals as soon as he gets into the office. During the hiring process, staffing should be based on both the person/job match and person/organisation match. In reference to the person/job match, the company will look for potential employees who have adequate knowledge especially to deal with the production and designing of the household products produced by the company. As a result of hiring skilled employees, the level of motivation among the workers will be increased leading to a higher productivity. In the same way, Household Consumer Enterprises should ensure that a person-organisation match is maintained during the hiring process. In addition to flexible benefits and sustainable salaries, Carless (2005) notes that employees are attracted to the firms that offer ideas of authority, leadership and social relationships. In this regard, it is vital for

Significant principles of project management Research Paper

Significant principles of project management - Research Paper Example And the success or failure of one phase can have a significant influence on other project management tasks. In this scenario, project management is a systematic method for managing, controlling and setting up project tasks and resources from its beginning to completion (Barkley, 2006, p. 14; Kerzner, 2006; TechTarget, 2008; Haughey, 2009). In addition, these resources and tasks can be divided into different stages depending on the size of a project. These stages could be initiation, planning, executing, controlling, and completion or termination of the project. In reality, this standard method of the project management can be used to manage any kind of project, because its fundamental goal is to organize the different tasks of project development. In addition, project management is a kind of plan administration that pays attention especially on developing and organizing project activities and tasks. Simply like there are billions of ice cream tastes, there are billions of kinds of pr ojects and the nature of a project varies from organization to organization. In this scenario, efficient and successful project management can defeat them both. Additionally, project management considers projects normally as a provisional attempt to produce an exclusive service or product. In addition, for the majority of organizations today, everything is a project; on the other hand, others believe that projects are particular and high level tasks that happen occasionally. In fact, a project is an exclusive thing. Alternately, the formation of a new implementation is exclusive, while the preservation and everyday support of an existing application is not accordingly exclusive (Tomayko & Hallman, 1989; Luckey & Phillips, 2006). In addition, a number of researchers believe that project management is simply a set of a wide variety of tasks and activities that are distributed to a number of people by a responsible authority normally acknowledged as a project manager. Additionally, in efficient project management there is no space for goobers. In addition, the successful project management focuses on serious trade of receiving work performed on time, within allocated budget and according to client’s needs and requirements. Furthermore, the successful project management involves various other attributes such as leadership, execution and owning the project capacity. Also, it is an excellent response to sign off on the project and know that we and our project team play a significant role in the project’s success. The benefits of project management for the organizations are countless. The effective use of project management allows organizations to organize project tasks and assign resources. In this scenario, organizations can also track the progress of project. Additionally, project management is helpful for controlling the project tasks and guiding the development (Barkley, 2006; Tomayko & Hallman, 1989; Luckey & Phillips, 2006). Project organizations and the importance of leadership and sponsorship In view of the fact that the project is a team activity in which people

Rachel Perkins Essay Example | Topics and Well Written Essays - 3250 words

Rachel Perkins - Essay Example This certainly is an underlying theme in some of her films, including One Night the Moon (Aboriginal tracker is ignored by a white farmer, which leads to the death of the white farmer’s missing daughter) and Blood Brothers – Freedom Ride (Aboriginal individuals ride from town to town, telling the experience of the Aborigines, and urging action). However, her films are just as likely to either portray whites sympathetically, as in different segments of her documentary series, First Australians, or eschew white-Aboriginal conflict at all, in favor of universal themes. Radiance and Bran Nue Dae are excellent examples of this. Moreover, the overarching themes that she uses, when she does address the whites-Aboriginal conflicts, are that the Aboriginal peoples are resilient and able to overcome their social issues. This essay will detail how Rachel Perkins challenges the narrative of white oppression by demonstrating how her themes are focused around universality and overcom ing adversity, as well as show how another theme, which relates to the overall themes of minimizing white oppression, that of the use of music, is a common thread through much of her films. Resilience and Activism First Australians was Perkins’ television documentary, and this film focuses upon the history of the Aborigine peoples, with every episode of the seven part series focusing upon a different region of Australia. Perkins did not re-enact the drama and violence that occurred, but, rather, made the film in true documentary fashion by using pictures, interviews, diaries and voiceover narration. In this film, one of the themes, which is prominent in the films of Perkins, was that of resilience. Perkins did not necessarily want to make a documentary about the horrors of the history of the Aborigine peoples, but, rather, wanted to show how the Aborigine people overcame their precarious situation. Perkins did this, as a filmmaker, but focusing upon individual stories which w ere personal and character-based. These stories were narrated through visual and written sources which were left behind by the settlers as they reflected upon the past. The scenes, which were narrated by Perkins, was interspersed by historian analysis, and these historians were experts on the Aborigine and the early settlers (Collins, 2010). As an example of the resilience that Perkins showed through her documentary, one of the stories that she focused on was that of Bennelong, an Aborigine person who was kidnapped by governor Arthur Phillip. Phillip later befriended Bennelong (Konoshi, 2009). This is an example of resilience, as the story of Bennelong is one of overcoming adversity. Bennelong was taken from his wife and kidnapped, yet he not only did not despair in this situation, but made friends with his captor and became a sort of ambassador and mediator between the British and the Aborigine peoples. While he was able to straddle both worlds – that of the white man and th e Aborigine – he chose his own culture and died a respected elder in his tribe (Smith, 2009). That Perkins chose to focus on this story shows that she wanted to show triumph with the tragedy, and she sympathetically portrayed both Bennelong and his captor, later friend, Arthur Phillip (Konoshi, 2009). Another of the themes which is present this work is the interaction between the whites and the Aborigine population. While it certainly would have been easy for Perkins, as an Aborigine filmmaker, to show the Aborigine population as an oppressed people, and the whites as the oppressor, First Australians took a more nuanced approach. She chose to focus on the way that the whites and the Aborigine helped one another throughout the years. In addition to the story of Benn

PERSONAL ETHICAL DEVELOPMENT EXERCISE Assignment

PERSONAL ETHICAL DEVELOPMENT EXERCISE - Assignment Example Mental well being of an individual is the overall result of his mind, body and soul. Therefore, it is essential to deal with the various issues confronting an individual in all these aspects. I will try to understand the various issues concerning the people of my responsibility and guide them in their mental requirements. I will assume the role of a mentor who can approach and assist them in any difficult situation. I will be greatly aware of my role as a leader in the physical well being of my people and I will always seek ways to ensure that they are physically and mentally fit. I will make sure that they go through physical training programs regularly and motivate them about the need of a sound body for a sound mind. In order to encourage them in maintaining their good health, I will also conduct such programs that motivate them. In keeping the unity and values of family relationship intact, I will encourage constant cooperation among the family members and such activities as sharing, discussions, entertainments, etc will be encouraged. I will always ensure that the people in the family and friend-circle know each other very deeply. I will encourage my acquaintances to share each other and motivate and help mutually. In the areas of education and career, I will always be cooperative with and helpful to other individuals of the group and I will ensure that there is long lasting harmony and unity in the group. I will be useful to all my colleagues and mates in their needs and will always search for their assistance and cooperation at times of need. Finances/Stewardship As a leader, I will always be careful about dealing with the finances and use my stewardship in the most effective way. I will look into the needs of my people and make use of the resources for their assistance. I will also motivate them as a steward and would not let go anything wrong about in my responsibility. I will always make sure that the people entrusted to me are at ease and comfort, and I will give priority to their needs. Service/Philanthropy In areas of service and charity, I will always maintain decorum and propriety in my activities and the people who reach out for my service or philanthropy will never be dissatisfied or frustrated about my role. I will always ensure that the people in need are given the best treatment and their comforts are always looked for. PERSONAL MISSION WORKSHEET Why do I desire to become as an organizational leader The role of an organizational leader is inevitable in the contemporary context of business and I feel it is the best way to be an agent of change in the industry. In the progress of an organization, the role of the leader is often emphasized and as a leader I desire to get the organization progressing, to get it operating at high efficiency in order to meet its short-term goals as well as the long term goals. "In a large complex organization and environment only a 100% fully engaged human leader can hope to achieve these lofty requirements to fulfill their duties. Thus, leadership is not for everyone, and leadership is one with responsibility. A leader must be able to

Customer service - M Coursework Example | Topics and Well Written Essays - 1250 words

Customer service - M - Coursework Example It is vital for Tesco to build trust amid customers regarding prices and its stability to attain increased competitiveness. Tesco in order to meet its standards has undertaken initiatives to create immense value for its customers as well as shareholders through leveraging its experiences. The vision of Tesco is â€Å"to offer simple, transparent, and convenient products which reward its customers’ loyalty and strengthen their bond with the business† (Tesco Plc, 2014). Tesco complies with requisite legal aspects and best business practices to meet its customer demand for securing increased profit. The aim of Tesco is to provide best services to every customer in order to enhance customer loyalty towards the brand. The objective of the study is to understand the importance of legal aspects, customer service standards, and performances relevant to Tesco and its customers. Customers are bestowed with numerous rights and protections in order to get the best results and prevent offensive practices within the business. Tesco understands the legal rights of consumers and hence provides proper information about its products to them. Moreover, to ensure effective management of the customer services, Tesco provides helpline numbers and customer helpdesk and resolve their queries and complaints. From the perspective of organisational requirements, it is important for Tesco to provide a better shopping experience and deliver a proper after sales services for encouraging customers engage in repeated sales. Customer satisfaction is the key to success and hence it is important to understand and track their changing needs. Ensuring ethical operation and knowing customers are essential for business to sustain in the long-run. Every company needs to follow certain rules and legislation, along with external regulations to manage customers in a fair and efficient mann er. It is observed that complying with legal aspects enhance the quality of services.

Why did relations between the soviet union and the US change in the years 1943-1956 Essay Example for Free

Why did relations between the soviet union and the US change in the years 1943-1956 Essay The first reason is that Roosevelts death in April 1945 brought an end to any superficial unity that still existed at the end of World War 2 in 1943. Truman was now the American President, and relations between him and Stalin were deteriorating very quickly indeed, especially when Stalin was such a determined character and Truman was less willing to compromise, compared to Roosevelt. The second reason is that America had developed the atomic bomb in June 1945. This played a major part in the change in Trumans attitude at the Potsdam Conference in the same year. The successful development of the atomic bomb had lifted Truman on his high horse, and this links back to his attitude that clashed with Stalin. Now Truman was even more arrogant, and as a result, it made Stalin even more determined to get his way. The third reason is that as a result of Churchills Iron Curtain Speech, the Truman Doctrine and Marshall Aid, Stalin had responded to these by forcing communism on Eastern Europe, then Comecon and Cominform, and hence the Berlin Crisis. This point marks the peak of the Cold War when relations between the USSR and the USA were at their worst. This was because of the Berlin Blockade, when America had humiliated Stalin so devastatingly, with Stalin on the verge between firing at the airplanes, or ignoring them and keeping the blockade up. This is another example of Stalins stubborn nature, as seen in the Potsdam Conference mentioned in the previous paragraph. Finally, the fourth and last reason is that as a result of the Berlin Crisis, President Truman had signed the NATO agreement in 1949, which was a clear union of America and Western Europe against the USSR and Eastern Europe, and most importantly, against Communism. This made Stalin furious, and he responded in defence with the Warsaw Pact in 1955. This move shows that he is not to be outdone, and hence here at the peak of tension and conflict from 1943-56 we see the complete change that has occurred in the relation between the two powers.

Osteoma of Temporal Bone: A Case of Post Aural Swelling

Osteoma of Temporal Bone: A Case of Post Aural Swelling Introduction:- Osteomas are benign tumours of the lamellar bones. In routine ENT practice they are commonly seen as dense radio opaque shadows arising from within the paranasal sinuses. Osteoma of the temporal bone occurs infrequently, and when they occur, are seen most common in the external ear canal. Osteoma originating from the middle ear is very rare. That from the mastoid are rarer. We document such a rare presentation of osteoma arising from the mastoid. Case report:- Presenting case of a previously healthy 32-year-old woman, referred to the ENT clinic for assessment of a left retroauricular mass that had been slowly increasing in size for past 1 year. This patient was asymptomatic, but reported unsightly appearance of this mass. On examination, she was found to have a 3 cm X 3cm globular hard bony swelling above and behind the left mastoid process fixed to the underlying bone. It was non tender. Detailed ENT examination including facial nerve function was normal. There were no bony exostoses in the external ear canal. CT scan of the petrous temporal bones demonstrated a bone tumour arising from the left mastoid cortex with no other associated abnormality of the petrous temporal bone, suggesting a typical mastoid osteoma (Fig. 2). Surgical resection was performed under local anaesthesia via a retroauricular incision. Following skin dissection and exposure of the bone tumour, the tumour was completely resected by a mastoid drill with cutting burr(fig 3a,b,c). Finally the edges of the bone were polished with a round burr and the incision closed in layers. She had an uneventful postoperative period(fig 4). Histopathology confirmed an osteoid osteoma(fig 5). Discussion:- Osteoma is a slow growing tumor formed by mature bone tissue. Osteoid osteoma is a primary bone tumor accounting for 10% of all primary bone tumors.1  It mostly occurs in long bones. In the skull it mainly affects the  frontoethmoid region. Very uncommonly it affects the temporal bone.  They are rare in the sphenoid sinus and extremely rare on temporal and occipital squama.2 In the temporal region, osteomas are essentially reported in the external auditory canal, or more rarely in the middle ear,along the auditory canal or the styloid process, in the temporomandibular joint, in the apex of the petrous temporal bone or in the internal auditory canal 3 and only exceptionally in the mastoid 4. It has higher incidence in female patients,predominantly in the 2nd and 3rd decade of life and is rare in puberty. 6 As illustrated by the case reported here, osteomas arising from outer cortex of the mastoid are associated with minimal or no symptoms. They are essentially responsible for unsightly deformity of the retroauricular region, or even detachment of the external ear in the case of a very large, anterior tumour. Mastoid osteomas can cause local tenderness and interfere with wearing glasses. Even though it is normally asymptomatic it may produce pain by invasion of surrounding structures or widening of periosteium.If located in the external auditory canal it may lead to occlusion progressing to chronic otitis externa (30% of cases) and conductive hearing loss7,8.In the present case patient did not have any complaints and swelling was removed for cosmetic reasons. While the exact etiology of osteomas is not well understood, they are thought to arise from preosseus connective tissue. There is some evidence that osteomas are of congenital nature 9. The most widely accepted theories for the etiopathogenesis of osteomas include embryogenesis and metaplasia following recurrent local irritation and trauma. Three types of mastoid osteomas have been described, based on structural characteristics.10,11,12 †¢ Compact: The most frequent one. Comprising dense, compact and lamellar bone, with few vessels and Haversian canals system. Those with dense sclerotic bone are called ivory osteoma. Compact osteomas have a wider base and are very slow growing †¢ Cartilaginous: Comprising bone and cartilaginous elements †¢ Spongy: Rare type. Comprised by spongy bone and fibrous cell tissue,with tendency to expand to the diploe and involving the internal and external lamina of the affected bone, have bone marrow and also known as cancellous or osteoid osteomas. They are more likely to be pedunculated and grow relatively faster. †¢ Mixed: Mixture of spongy and compact types. It is important to differentiate osteomas from exostoses. They should be considered separate clinical entities. Osteomas are bony growths that are single,unilateral and pedunculated and arise from the tympanosquamous or tympanomastoid suture lines laterally, whereas exostoses are multiple, usually bilateral and broad based and are found medial to the sutures of the temporal bone 13. Osteomas are true bone tumors and exostoses are thought to be a reactive condition secondary to multiple cold-water immersions or recurrent otitis externa. Disagreement still exists whether external auditory canal exostoses and osteoma should be considered as separate histopathological entities. JE Fenton et al in their study have concluded that they cannot be differentiated on routine histopathological examination 14. Osteoma occurrence may be syndromic or non syndromic. They may occur as a feature of Gardener’s syndrome, which is characterized by multiple intestinal polyps, epidermoid inclusion c ysts, fibromas of the skin and mesentery and osteomas. Osteomas in Gardener’s syndrome have a predilection for membranous bones and as such the mandible and maxilla are more commonly involved 15. Non-contrast computed tomography of the petrous temporal bones is the examination of choice for diagnosis and staging. It reveals a rounded bone lesion of the outer cortex of the mastoid, with regular margins, with a pedunculated or sessile implantation base. Superficial mastoid osteoma presents no signs of intrapetrosal extension and the mastoid air cells remain perfectly aerated. In rare cases, the osteoma can extend medially into the petrous temporal bone adjacent to the facial nerve, lateral semicircular canal or ossicles. In these cases, imaging can define the anatomical relations with these structures before considering surgical resection 3,4,16-18. Imaging is also useful to define the differential diagnosis between osteoma and other mastoid bone tumours, especially osteosarcoma, bone metastases, multiple myeloma, giant cell tumour, lesions encountered in Paget’s disease or fibrous dysplasia 3,4. Signs suggestive of a malignant lesion are rapid growth, pain and a poorly delimited, heterogeneous, osteolytic appearance on CT. Treatment is indicated for osteomas that are symptomatic or cosmetically unacceptable. Excision or drilling of superficial lesions of the mastoid and squama is a simple procedure. At surgery, since the lesions are always limited to the external cortex a cleavage plane is always encountered when tumor meets normal bone19. In mastoid osteomas extending into the fallopian canal and bony labyrinth, complete excision is not indicated since there may be damage to these structures .Follow up is needed in cases where partial excision is  done or where expectant treatment is adopted. Surgical resection usually raises few technical problems: retroauricular incision adapted to the size of the lesion, exposure of the osteoma, then resection with a bone chisel or curette or by reaming, depending on the size of the osteoma and its sessile or pedunculated implantation. A retroauricular subcutaneous depression may be observed after the operation 20. Conclusions:- Osteomas are tumors predominantly arising from the long bones and rarely from the flat bones of the skull. When present they should be treated as per the symptoms of the patient. Osteomas present within the ear need to be dealt carefully, for fear of damage to vital structures.Osteomas present on the mastoid or squamous portion of the temporal bone need to be dealt for cosmetic purposes or if they are causing symptoms. References:- 1. Kransdorf MJ, Stull MA, Gilkey FW, et al. Osteoid osteoma. Radiographics 1991; 11:671 -96 2. Sente M, Topolac R, Peic-Gavran K, Aleksov G. Frontal sinus osteoma as a cause of purulent meningitis. Med Pregl 1999;52(3-5):169-72 3. Dominguez Pà ©rez AD, Rodrà ­guez Romero R, Domà ­nguez Durà ¡nE, Riquelme MontaËÅ"no P, Alcà ¡ntara Bernal R, Monreal Rodrà ­guezC. El osteoma en la mastoids, ActaOtorrinolaringol Esp 2011;62:140—3. 4. KimCW, Oh SJ, Kang JM, Ahn HY. Multiple osteomas in the middle. Eur Arch Otorhinolaryngol 2006;263:1151—4. 5. D’Ottovai LR, Piccirillo E, De Sanctis S, et al. Mastoid osteomas: review of the literature and presentation of two clinical cases.Acta Otorinolaringol Ital 1997;17:136—9. 6. Dugert E, Lagleyre S, Brouchet A, Deguine O, Cognard C, Bonneville F. Osteoid Osteoma Invading the Posterior Labyrinth of the Petrous Bone AJNR Am J Neuroradiol. 2010 Oct;31(9):1764-6 7 .Gupta OP, Samant IC. Osteoma of mastoid.laryngoscope 1972;82:172-6 8. Bruton DM,Gonzalez C.Mastoid osteoma.Ear Nose Throat J 1991;70:161-2 9. Yamasoba T, Harada T, Okunao T, Nomura Y. Osteoma of themiddle ear. Report of a case. Arch Otolaryngol Head Neck Surg 1990;116:1214-6. 10. Varshney S. Osteoma of temporal bone. Indian J of Otol 2001;7:91-2. 11. Probost LE, Shanken L, Fox R. Osteoma of the mastoid bone. J Otolaryngol 1991;20:228-30. 12. Singh I, Sanasam JC, Bhatia PL, Singh LS. Giant osteoma of the mastoid. Ear Nose Throat J 1979;58. 13 Sheehy JJ. Diffuse exostoses and osteomata of the external auditory canal: A report of 100 cases. Otolaryngol Head Neck Surg 1982;90:337-42 14. Fenton JE, Turner J, Fagan PA. A histopathological review of temporal bone exostoses and osteoma. Laryngoscope 1996;106:624-8. 15. Earl H Harley, Robert G Berkowitz. Imaging case study of the month, Osteoma of the middle ear. Ann Otol Rhinol Laryngol 1997;106:714 16. Quesnel AM, Lee DJ. Extensive osteomas of the temporal parietaloccipital skull. Otol Neurotol 2011;32:e3—4. 17.Ben-Yaakov A, Wohlgelernter J, Gross M. Osteoma of the lateral semicircular canal. Acta Otolaryngol 2006;126:1005—7. 18. Gungor A, Cincik H, Poyazoglu E, et al. Mastoid osteomas: reportof two cases. Otol Neurotol 2004;25:95—7. 19. Antonio Denia, Fransisco Perez, Rinaldo R, Canalis R, Malcolm D Graham. Extracanalicular osteomas of the temporal bone. Arch Otolaryngol 1979;105:706-9. 20. Probst LE, Shankar L, Fox R. Osteoma the mastoid bone. J Otolaryngol 1991;20:228—30

Globalization and Income Inequality in Latin America

Globalization and Income Inequality in Latin America Ivan Mendoza Globalization and Income Inequality in Latin America and The Caribbean Introduction Over the past two decades, â€Å"developing countries have gradually committed themselves to more engagement with the global economy by following the path of trade liberalization and openness toward international markets† (J.D.K. Chap. 10 p.416). As a result, â€Å"many developing countries have experienced increases in within- country income inequality. The growing income inequality has coincided with the period of increasing exposure of countries to globalization through an increased of trade flows and investment across international borders. These development have sparked a large debate in the academic and policy circles about the effects of globalization on income inequality within- countries† (J.D.K. Chap. 10 p.564). This paper will discuss whether globalization has contributed to within- country income inequality by focusing on one aspect of globalization, mainly the countries’ trade flows, specifically exports. Test- Hypothesis Considering that â€Å"the interest of developing countries might be more in line with those of the developed/ advanced countries, reflects the integration of emerging and developing countries to the global economy through a rapid pace of trade globalization to create opportunities that will create speed economic growth and development. This wave of trade liberalization has had a great impact on the income inequality within developing countries. Therefore, I argue that globalization should lead to an increase of the income inequality within emerging and developing countries, in other words, an increase in total trade (exports) is highly related to the increase of the income inequality within a developing country. Method and Data Collection In order to test the hypothesis that an increase in exports is highly related to the increase of the income inequality of developing countries, I will examine the economic growth and trade of emerging and developing countries, with emphasis on the region of Latin America and the Caribbean. Some of the countries in the region have experienced rapid economic growth and development, but â€Å"in the last years this growth has slowdown† (WEO p. 56), so examining their growth is a good way to study the effects of globalization and the within-country income inequality. Also, we might find other aspects of globalization that are associated with income inequality. In order to test the hypothesis, I collected data to show the economic performance of 32 developing countries in the Latin America and the Caribbean region covering the period of 1996-2013. This data has been collected from reliable sources such as World Economic Outlook (October 2014) released by the International Monetary Funds (IMF) and the World Development Indicators (WDI) report from World Bank (WB). This data contains the dependent variables and the expansionary variable along with other supplemental data. Moreover, to accomplish the objective of this paper; providing some evidences on the effects of globalization on income inequality within developing countries I will be using the following data table: (i) the Real Gross Domestic Product (GDP) table, which shows the annual percentage economic performance for the selected developing countries, (ii) the Trade table, which shows the sum of exports and imports percentage in terms of GDP percentage, this reflects the integration of the countries in the global economy. (iii) the Exports of good and services table, since exports is a component of trade and GDP, it shows the effects of trade on GDP because if exports is positive, then GDP increases, (iv) Gini Index, which is the standard measure for income inequality. Relationship between the variables Considering the effects of globalization on the income inequality within a country, we have trade as the variable for globalization and â€Å"the amount of income inequality within a country is generally measured by using the Gini Index. The Gini Index ranges from 0 to 100, where a value of 0 indicates that everyone has the same income (that is, perfect inequality) and a value of 100 indicates that all the income is earned by one individual (that is, maximum inequality)† (p. 564). However, since most of these countries economy depends on trade, as we can see on the Trade (% GDP) table (high percentage means they import more than what they export/produce) to simplify the relationship between globalization and income inequality, I will using the Export of goods and services, which is one of the components of trade. So, using the data of Exports (% GDP) as the expansionary variable and Gini index as the dependent, we can see for the selected countries that have experience decreas e in Exports shares, can be associated with a decrease of income inequality. For example, in countries such as Colombia, Dominican Republic, El Salvador, Paraguay and Peru after 2006 their exports have gone through a period of highs and lows along the same range and inequality has moved accordinly to the change in exports, but most of the time its been going down. Although inequality has gone in most of the selected countries, in cases such as Costa Rica and Panama, theres been period where Exports goes increase and the Gini index still goes down. This shows that the impact of Exports (trade) on income inequality is not significant as expected and that there might be other components of globalization affecting income inequality. Conclusion In conclusion, the evidences show that there is positive relationship between trade liberalization and the income distribution within developing countries in the Latin America and the Caribbean; As Exports (trade) increases/ decreases the level of income inequality, according to the Gini Index, increases/ decreases. However, we found that there is not a significant change on income inequality when Exports changes. Discussion Moreover, this finding provides an exploratory support to other hypotheses that other components of globalization might have a greater impact on within- country income inequality. â€Å"Other factors that drive income inequality are the importance of technology in virtually all sectors of the global economy, and the advances in information and communication technology (ICT) that helped make globalization possible.† (J.D.K. Chap. 14 p. 564). Source: World Economic Outlook (IFM p.189) https://www.imf.org/external/pubs/ft/weo/2014/02/pdf/text.pdf Trade (% of GDP) Country Average20062007200820092010201120122013 (1996- 2005) Antigua and Barbuda37.6 119.7117.4116.3 105.1106.0104.897.8 Argentina 25.2 36.2 36.2 36.7 30.6 32.5 33.9 29.9 29.3 Bahamas, The 102.3 100.1 100.7 100.0 87.5 90.2 101.0 107.7 Barbados 88.8 94.4 94.4 99.6 86.0 96.9 93.0 96.8 Belize 115.2 122.8 122.3 131.9 107.7 115.6 124.3 Bolivia 51.4 74.5 76.1 82.9 68.6 75.5 82.5 85.1 Brazil 22.4 25.8 25.2 27.1 22.1 22.8 24.5 26.6 27.6 Chile 61.0 71.9 75.8 81.0 66.8 69.8 72.9 68.4 65.5 Colombia 35.1 38.2 36.3 38.1 34.3 33.7 38.7 38.2 37.4 Costa Rica 92.6 104.4 102.2 100.6 84.0 79.1 79.2 78.7 73.9 Dominica 101.7 89.8 93.1 99.4 87.3 90.9 86.9 88.6 Dominican Rep. 77.5 68.0 66.7 64.7 52.5 57.2 60.4 59.1 57.6 Ecuador 49.5 59.7 62.6 68.1 52.1 62.1 66.0 64.0 63.6 El Salvador 65.8 71.8 74.2 76.6 61.9 68.8 74.6 69.7 72.2 Grenada 99.5 80.1 82.4 77.7 69.4 70.9 74.0 73.3 Guatemala 55.9 66.8 67.9 64.1 57.1 62.1 64.0 61.0 58.6 Guyana 203.2 Haiti 47.8 59.5 52.2 56.9 56.7 73.7 67.6 61.4 Honduras 114.3 133.1 135.1 135.7 96.9 109.4 122.2 120.6 117.5 Jamaica 90.0 100.8 101.3 113.6 86.9 80.9 83.9 83.4 Mexico 51.3 56.4 57.1 58.1 56.0 60.9 63.7 66.4 64.2 Nicaragua 60.4 76.8 82.6 87.8 77.9 85.5 95.8 101.0 92.9 Panama 144.5 146.2 145.4 149.0 138.7 139.7 158.3 154.8 137.7 Paraguay 93.6 107.8 103.5 103.5 96.3 106.6 102.7 99.9 92.7 Peru 36.6 51.1 53.9 56.6 46.4 50.0 55.2 51.7 48.4 St. Kitts and Nevis 103.2 88.4 83.6 86.6 72.9 77.2 74.6 80.3 St. Lucia 116.1 112.7 105.1 114.5 101.0 113.0 106.7 103.6 St. Vincent and the Grenadines 103.4 88.0 89.8 92.2 86.0 84.0 84.6 85.7 Suriname 66.3 Trinidad and Tobago 99.2 118.7 102.3 107.1 90.9 92.4 151.0 Uruguay 43.1 62.0 59.2 65.2 55.3 53.4 54.0 55.8 Venezuela, RB 49.9 58.7 56.2 51.8 38.5 46.1 49.6 50.4 Source: World Development Indicators. http://databank.worldbank.org/data/views/reports/tableview.aspx?t=tableviewsavedlg=1 Exports of good and services (% of GDP) Country Average20062007200820092010201120122013 (1996- 2005) Antigua and Barbuda 65.0 48.0 45.1 46.4 46.6 46.1 47.6 46.3 Argentina 14.0 20.4 19.8 19.9 17.4 17.5 17.8 15.8 14.5 Bahamas, The 43.2 44.7 46.7 46.0 39.9 40.9 43.6 44.8 Barbados 42.3 44.9 45.3 46.0 41.5 46.3 39.3 42.5 Belize 52.5 61.1 61.1 62.3 51.6 58.2 61.2 Bolivia23.2 41.8 41.8 44.9 35.7 41.2 44.1 47.3 Brazil 11.3 14.4 13.4 13.7 11.0 10.9 11.9 12.6 12.6 Chile 31.2 42.4 43.8 41.5 37.2 38.1 38.0 34.2 32.6 Colombia* 16.0 17.6 16.5 17.8 16.0 15.9 18.7 18.3 17.7 Costa Rica** 45.3 49.1 48.7 45.4 42.3 38.2 37.2 37.2 35.1 Dominica 44.9 37.8 35.8 35.9 32.4 35.7 33.8 38.8 Dominican Rep.* 36.2 30.0 28.8 25.5 22.2 23.0 25.0 25.1 26.0 Ecuador* 24.0 30.3 31.9 34.2 25.2 28.7 31.5 30.9 30.5 El Salvador* 25.6 25.7 25.9 26.9 23.2 25.9 28.0 25.6 26.4 Grenada 39.1 23.0 24.9 23.0 22.6 21.8 23.7 24.1 Guatemala 22.5 24.9 25.6 24.7 24.0 25.8 26.6 24.9 23.7 Guyana 94.9 Haiti 12.6 14.5 13.2 12.7 14.1 12.1 13.4 13.3 Honduras 51.0 56.1 53.5 51.3 39.5 45.8 51.3 50.4 47.9 Jamaica 37.5 40.1 39.7 41.9 34.5 31.3 30.4 30.4 Mexico 25.4 27.6 27.7 27.9 27.3 29.9 31.2 32.631.7 Nicaragua 20.0 27.0 29.0 31.3 30.9 35.9 40.1 43.0 40.5 Panama** 73.9 76.7 76.1 78.7 75.5 70.6 79.3 79.8 71.0 Paraguay* 51.6 58.7 56.7 54.0 51.5 55.1 52.6 51.3 49.7 Peru* 17.5 30.2 30.5 28.4 25.2 26.6 29.7 26.6 23.7 St. Kitts and Nevis 42.2 37.4 33.7 31.3 23.9 28.8 31.3 34.3 St. Lucia 53.7 43.2 39.9 45.3 46.1 50.2 43.2 44.7 St. Vincent and the Grenadines 43.8 34.7 31.0 30.2 28.5 26.9 27.5 27.6 Suriname 24.5 †¦ Trinidad and Tobago 54.3 81.4 65.2 71.4 52.3 58.9 88.1 Uruguay21.3 30.3 29.1 30.2 28.0 27.2 26.8 26.2 Venezuela, RB 30.2 36.5 31.1 30.8 18.1 28.5 29.9 26.2 Source: World Development Indicators. http://databank.worldbank.org/data/views/reports/tableview.aspx?t=tableviewsavedlg=1 Change in Income Inequality is the Selected Countries http://databank.worldbank.org/data/views/reports/chart.aspx# Works Cited Frieden, Jeffry, and Lake, David, and Kenneth Schultz. Chapter Ten-â€Å"Development: Causes of the Wealth and Poverty of Nations†, World Politics: Interests, Interactions, Institutions. 2nd Ed. New York: W. W. Norton, 2012. p. 386-418. Print . Chapter Fourteen-â€Å"The Future of International Politics†, World Politics: Interests, Interactions, Institutions. 2nd Ed. New York: W. W. Norton, 2012. p. 534- 577. Print IMF (International Monetary Fund). World Economic Outlook. Washington, DC. 2014. https://www.imf.org/external/pubs/ft/weo/2014/02/pdf/text.pdf IMF (International Monetary Fund). Chapter Four: Globalization and Inequality. World Economic Outlook. Washington, DC. 2007. http://www.imf.org/external/pubs/ft/weo/2007/02/pdf/c4.pdf World Bank (WB). World Development Indicators. Trade (% of GDP) http://databank.worldbank.org/data/views/reports/tableview.aspx?t=tableviewsavedlg=1 World Bank. World Development Indicators. Exports of goods and services (% of GDP) http://databank.worldbank.org/data/views/reports/tableview.aspx?t=tableviewsavedlg=1 World Bank. World Development Indicators. Gini Index. Created 12/12/2014 http://databank.worldbank.org/data/views/reports/chart.aspx#

How Our Universe Was Created :: essays papers

How Our Universe Was Created Creation Stories, myths that explain the origin of the universe, or cosmos. The origin of the cosmos forms one of the principal themes of mythology throughout the world. (Rev. Bruce Vawter). Cosmogony has attempted to explain everything from the Greek deities Uranus (sky god) and Gaea (earth goddess), to say the creation of humankind, after which the mythic cosmos comes to resemble the world of human experience. In mythic history, the earliest era of the world is usually the closest to perfection-a Golden Age or Garden of Eden. There are thirty-five religions that I have heard of and countless others that have not been documented. I have always wondered why we Latinos, African, Asians, Italians, Indians, and the rest of the cultures on this earth practice different religions and ideas. The answer is billions of years ago, in a galaxy far away, an intergalactic council was formed. The council members consisted of dozens of what we call Gods. Each was a ruler of a planet. And on each of these planets there were people who worshiped their Creator (God). The climate of each world was different from the other. Each planet could only sustain life for its people. The inhabitant’s needed a particular climate so that they could survive. Even there agriculture was dependant on the climate as well. One day the supreme deity who created each of the Gods, decided to allow each of the member’s to unite it’s people with the other. They wondered how they would be this since all of the planets differed in climate and no one could survive on the others planet. So it was decided that they would all create what today is know as the Milky Way. With careful planning the RNA/DNA was joined to create a human that would be able to withstand various climates and be able to eventually procreate. Fifteen billion years ago, give or take five billion years, the entirety of our universe was compressed into the confines of an atomic nucleus. Known as a singularity, this is the moment before creation when space and time did not exist. According to the prevailing cosmological models that explain our universe, an ineffable explosion, trillions

Cluniac Monasticism Essay -- History

Cluniac Monasticism Assess the strengths and weaknesses of Cluniac monasticism between the tenth and twelfth centuries. The nature of Cluny lay in the circumstances of it’s foundation. It was endowed with a measure of independence by it’s founder, Duke William, allowing the monks to elect their own abbot, placing the abbey directly under the guardianship of St Peter and the Apostolic See. As a house dedicated to reviving strict Benedictine observance Cluny was not unique, but it was this indepencence, the succesion of talented abbots and it’s organisation set up by Abbot Berno that laid the foundations of the abbey’s later greatness. The independence granted Cluny in it’s foundation charter was esssential in the development of Cluny free from the interference of lay magnates and local bishops. It’s direct dependence on Rome was not initially of great importence; other foundations had beemn bequeathed to the apostles before. However, this was an important foundation upon which later abbots were to build. By seeking papal approval for Cluniac reforms the abbots forged a valuble direct link to the papacy, whilst gain officail public regognition and endorsement of the Cluniac regieme. In obtaining the right to accept monks from other orders in 931 Odo had confirmed the righht of the Cluniacs to reform others houses, while Cluny gained freedom from the local bishops under Abbot Odilo in 998. it was ‘the subsequent growth, under far straiter papal oversight, of Cluny’s exemption from episcopal control in spiritual matters, that did most to consolidate Cluny’s subject houses under itâ⠂¬â„¢s own central authority’ . This meant Cluny was immune to challenges to it’s authority from both without and within the church. Cluny became of particular note to sucessive Popes, with it’s reputation for reform, and the papacy continued to support the cluniacs, with Pope John XIX giving Cluny’s monks complete freedom from interference whereever they were in 1024. However, this would have been nothing without the exemplary spiritual life that was seen to exist at Cluny. The continual use of vocal prayer was popular with the laity, with many wishing to be included in the prayers of the monks. The personal qualities of the abbots were also much admired, as was the way of life practised at Cluny. The cluniac model of benedictine obervence was seen by many by the time of Abb... ... riches of success. The Cluniacs were criticised by those who favoured a more eremetic style of monasticism, and the stricter Cistercians. They were also criticised by laymen and other factions within the church. As an order, their popularity was on the wane by the twelfth century. The main strenghts of cluniac monasticism lay in its independence, it’s early spiritual energy, it’s observence of the benedictine rule and it’s sainly abbots. These provided very well for Cluny for a significant period, but over-growth of the order led to a slackening in observence of the Rule, and with the disasterous abbacy of Pons and a basic shift in religious opinion these strenghts became weaknesses that Bibliography Evans, Monastic Life at Cluny 910-1157 (Oxford University Press, 1931) Ed. Hunt, Cluniac Monasticsm in the central middle ages, (Macmillan, 1971) Lynch, The Medeval Church, (Longman, 1992) Cowdrey, The Cluniacs and the Gregorian Reform, (Oxford, 1970) Lawrence, Medeval Monasticism, (Longman, 1989) Southern, Western Society and the Church in the Middle Ages, (Pelican, 1970) Ed. Holmes, The Oxford Illustrated History of Medeval Europe, (Oxford, 2001)

Hamlet Feminist Criticism

This lack of prior knowledge of her being allows the reader to question the importance of her history. The question of the importance of her life is delegated and her current presence Is the only one that matters for the existence of the play. This shows the negative portrayal already to be brought about because of her underdeveloped, backbreaking. Sometimes words are needed in defense, for no words can be Just as negative. â€Å"Frailty; thy name Is woman. Is one of the most impacting quotes In the whole play.It directly states of the nature in which the feminine world is to be perceived. Woman, according to the time, were supposed to be mentally unstable, and fully dependent on their male spouse. This was no better exemplified than In Hamlet. Aphelia, after having taken orders from her father her whole life, his death made her go mad. She was then no longer able to function, ultimately resulting in her death. Gertrude, Hamlet's mother, quickly re-married to be supported by her lat e husband's brother. This shows her weakness to be successful without a partner and lack of self- assurance.Aphelion's specific death, that by drowning, can be linked directly with being a woman. â€Å"In his discussion of the ‘Aphelia complex,' the phenomenology's Gaston Bachelor traces the symbolic connections between women, water, and death. Drowning, he suggests, becomes the truly friendly death In the dramas of literature and life, one which is a beautiful immersion and submersion in the female element. Water is the profound and organic symbol of the liquid woman whose eyes are so easily drowned in tears, as her body is the repository of blood, amniotic fluid, and milk. Aphelion's brother Alerts states that he has once again became man after crying tears. Tears which are liquid, liquid being feminine, and friendly being weakness. The idea of women being signs of sexuality has been present for thousands of years. Aphelia is especially known for this, being a woman constan tly entangled within flowers and white linens. The scene In which Aphelia becomes mad, passing out flowers to those around can be contrived as symbolism for, â€Å"deflowering† herself.She publicly has humiliated herself, her family, and the female name for her actions. It was Montreal Day numerous critics now teeny Delved Tanat It was snapper's anger against women for making his characters act in these ways. An interesting aspect of some of the criticism on Aphelion's behavior has to do with those who act out the plays, themselves. Earlier renditions, when females were not as welcome on the stage, men played Aphelia and tended to react with more emotions to make Aphelia seem even weaker not only mentally but also in a physical aspect.When portrayed by a female, the pity and fragility were still present, Just not in the mocking demeanor as when portrayed by men. In other places, Aphelion's lines were shortened and censored because many did not believe in her place in the play at all. As time went on however, she is portrayed as childlike and frail in contrast to mad and dangerous. Hamlet's negative portrayal of women can be linked to many historical beliefs, but the examples are certain. The reader's lack of prior knowledge concerning Aphelia allows one to question the importance of her history.Woman, according to the time in which Hamlet was written, were supposed to be mentally unstable and fully dependent on their male spouse; Gertrude and Aphelia were prime example's of this phenomenon. Aphelion's specific death, that by drowning, can be linked directly with being a woman for water's liquidity. The idea of a woman being a sign of sexuality has been a common thought for thousands of years, this showing the ability for the plays modern day relevance.

Lifestyle Disease Essay

Lifestyle disease which may also be referred to as Non-Communicable Disease, has in recent times become an issue of grave concern for governments both globally and regionally. The World Health Organization (WHO) Secretary-General, during a General Assembly Summit (first ever summit on deadly chronic illnesses) in 2011 deemed in a statement â€Å"†¦the spread of non-communicable diseases as a socio-economic and development challenge of epidemic proportions†¦Ã¢â‚¬  . In another report from WHO, Dr. Ala Alwan, the organization’s Director-General for non-communicable diseases further states, â€Å"lifestyle diseases are responsible for 63 percent of global deaths based on WHO’s estimates for 2008.† Here in the Caribbean Governments have begun taking steps to arrest the problem of lifestyle disease through an initial Heads of Government meeting of Caricom held in September 2007 to â€Å"start a campaign to galvanise the Region against the scourge of such disorders as obesity, high blood pressure, diabetes, stroke, heart attack and some kinds of cancer.† So what is meant by the term lifestyle disease? Lifestyle disease has been defined as being a disease that is associated with the way an individual or group of people live their lives and can be caused by such factors as poor diet and nutrition, lack of exercise and chronic stress. Poor diet and nutrition is a major cause of lifestyle disease in both adults and children. Individuals in these modern times live a â€Å"fast-paced lifestyle† and have become â€Å"wrapped up in raking in the moolah† and take very little time to nourish their bodies properly. Many persons now eat out more often than before, consuming a lot of ‘fast food’ and ‘junk food’ with high salt content and saturated fat. Individuals are also consuming more meat and eating less fruits and vegetables and getting less fibre in their diets. Many persons also because of their busyness skip meals causing many to overeat and others due to their circumstances may under eat therefore not getting proper or enough nutrients into their bodies. The drinks being consumed also contribute to poor nutrition. The sodas individuals drink especially children have high sugar content which is not healthy. The habitual consumption of alcoholic drinks can also affect one’s health in a negative way. What one eats is important to one’s health and the practice of poor nutrition and diet can have negative long term effects on one’s health such as high blood pressure, high cholesterol and  diabetes. Another major contributor to lifestyle disease is lack of exercise. According to WHO, â€Å"physical inactivity causes 2 million deaths a year worldwide†. In a world where one has access to many types of exercise gadgets and various exercise videos, individuals fail to avail themselves with these devices and have become lazy, and lead more sedentary lives. People including children now choose to spend more time indoors instead of going outside and doing any kind of physical activity to stimulate the heart. They are either watching television or sitting in front of a computer playing or working, or on a tablet or phone for many hours at a time. Many persons even in the work place do not use the stairs and instead choose to use the elevator or escalator to move from one floor to the next. It is said that laughter is the best medicine but do you know that exercise can cause your body to release chemicals that cheer you up? The human body was meant to move and lack of physical activity can lead to such health issues as obesity, lack of energy, stress and it can also affect the heart. Lifestyle disease is associated with the daily habits of people and is a direct result of the lifestyle someone lives. It can be caused by several factors such as bad food habits, physical inactivity and stress, all of which negatively affect one’s body thus contributing to disease.